United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R02-85/012
March 1985
Superfund
Record of Decision:
D'lmperio Property, NJ

-------
           D'IMPERIO PROPERTY, HAMILTON TOWNSHIP, NEW JERSEY

                           Record of Decision
                                Abstract

     The D'Imperio Property site is an inactive waste disposal dump
located in a semi-rural region of Atlantic County within the New Jersey
Pinelands Reserve.  The site is relatively flat with slopes ranging from
one to three degrees.  Two wetlands are located to the north and south
of the site, approximately 2000 and 4000 feet away, respectively.  The
site lies in a cleared area with wastes deposited randomly on the surface
and seme wastes partially buried.  The exact period of disposal activities
at the D'Imperio site is unknown.  However, it is believed that unauthorized
dumping took place fron the late 1960's to 1976.  A limited field inves-
tigation was conducted in the fall of 1980 which indicated that the ground
water underlying the site was contaminated with volatile organics.  The
site was subsequently included on the EPA Interim Priorities List.

     The selected remedial alternative for the D'Imperio site includes
excavation and transportation of 3900 cubic yards of contaminated waste
and soil and surface drums to a RCRA-regulated disposal site; construction
of a RCRA cap following completion of the excavation; and pumping and
treating contaminated ground water from two affected aquifers prior to
reinjection or surface discharge.  The treatment process is estimated to
take 17 months and will provide for the removal of both organic and
inorganic contaminants.  After 17 months an evaluation will be made to
determine the effectiveness of the cleanup program as well as the need
to continue pumping and treating the contaminated ground water.  The
estimated capital cost of this selected remedial alternative is $4,251,551,
with operations and maintenance costs estimated to be 1,169,449.

-------
                        Record of Decision
                  Remedial Alternative Selection


Site

D'Imperio Property, Hamilton Township, New Jersey

Documents Reviewed

I am basing my decision primarily on the following documents
describing the analysis of cost-effectiveness of remedial
alternatives for the D'Imperio Property site.

    - D'Imperio Property Remedial Investigation and Feasibility
      Study Report, NUS Corporation, February 1385.

    - Staff summaries and recommendations.

    - Responsiveness Summary dated March 1985.

Description of Selected Remedy

1.  Excavation of 3900 cubic yards of surface drums, contaminated
    waste and soil, and transportation of these materials to
    a RCRA approved hazardous waste disposal site.

2.  Construction of a RCRA cap following the excavation of the
    dump area.

3.  Pumping of contaminated groundwaters from the Upper Cohansey
    and Middle Cohansey aquifers, and treating such groundwaters
    prior to reinjection or surface discharge (to be determined
    during design of remedy).  The treatment process will provide
    for the removal of both organic and inorganic contaminants.
    At the currently estimated rates of groundwater extraction
    and treatment, It will take about 17 months to clean up the
    aquifers to levels which are consistent with appropriate
    RCRA, SDWA, and Statue drinking water quality standards.  At
    that time, an evaluation will be made to determine the effective-
    ness of the cleanup program as well as the need to continue
    pumping and treatment or establish alternate concentration
    limits.

-------
                               -2-
Declarationa

Consistent wi-th the Comprehensive Environmental Response Compen-
sation and Liability Act of 1980 (CERLCA), and the National
Contingency Plan (40 CFR Part 300), I have determined that the
excavation of contaminated mate-rials for disposal at a RCRA
approved hazardous waste facility in conjunction with capping the
site/ and pumping and treatment of contaminated groundwater is
the selected remedial alternative for the D'Imperio site.

It has been determined that the implementation of this alternative
will provide adequate protection of public health, welfare and
the environment.  The State of New Jersey has been consulted and
agrees with the proposed remedy.

I have also determined that the action being taken is appropriate
when balanced against the availability of Trust Fund monies for
use at other sites.  In addition, the removal of contaminated
materials to a secure hazardous waste facility, capping the site,
and pumping and treating contaminated groundwater is cost-effective,
implementable and technically sound when compared to other remedial
action alternatives, and is necessary to protect public health,
welfare and the environment.
Date                          Christopher J. Daggett
                              Regional Administrator

-------
           SUMMARY FOR REMEDIAL ALTERNATIVE SELECTION

                    D'Imperio Property Site
                 Hamilton Township/ New Jersey


Site Location and Description

The D'Imperio Property Site is an inactive waste disposal dump
in Hamilton Township, Atlantic County, New Jersey  (See Figure 1)
The location of the site "is within a triangle formed by the
intersections of U.S. Route 322 (Blackhorse Pike), Route 40,
and Cologne Road (See Figure 2).  The boundary of the site
generally follows the treeline bordering an open disposal area.

The D'Imperio Property Site is located in a semi-rural region of
Atlantic County within the New Jersey Pinelands Reserve.  The
National Parks and Recreation Act of 1978 mandated the protection
of the Pinelands Area.  The Act established the Pinelands
National Reserve, encompassing all or part of 56 municipalities
in southern New Jersey.  It also authorized the establishment
of a planning entity responsible for preparing a Comprehensive
Management Plan.                                        -

To comply with the federal statute, Governor Byrne issued an
Executive Order on February 8, 1979, providing for the
establishment of the Pinelands Planning Commission and making
most development in the Pinelands area subject to Commission
approval.  In June 1979, the State Legislature passed the
Pinelands Protection Act, thereby endorsing the designation of
the Pinelands Commission as the regional planning entity.  The
Pinelands Comprehensive Management Plan sets out the strategy
to achieve the goals of preserving, protecting and enhancing
the significant values of the land and water outlined in the
state and federal legislation.

The Comprehensive Management Plan of the Pinelands Protection
Act designates the site area land classification as a "Regional
Growth Area".  This designation allows for commercial, industrial
and moderately high residential development.
                      T
The site itself is relatively flat with slopes ranging from one
to three percent.  The nearest surface water are two wetlands
to the north and south of the site, approximately 2,000 and
4,000 feet away, respectively.  The north wetland is named
Babcock Swamp and is drained by Babcock Creek which is tributary
to the Great Egg Harbor River.  The southern wetland is unnamed
and is drained by Gravelly Run, which is also tributary to the
Great Egg Harbor River.

The site vegetation is predominantly indigenous mixed pine and
deciduous trees with thick herbaceous ground cover.  The site
lies in a cleared area with wastes deposited randomly on the
surface and partially buried.

-------
                              -2-
Site History

Little is known of waste disposal activities at the D'Imperio
Site.  The' exact period of disposal activities is unknown.
However, it is believed that the unauthorized dumping took
place from the late 1960's to 1976.  In the late 1970's, the
Atlantic County Public Health Department informed the New
Jersey Department of Environmental Protection (NJDEP) of the
existence of the site.  A limited field investigation was
conducted by the consulting firm Woodward-Clyde Associates for
a potential developer of the site in the Autumn of 1980.  The
results of this investigation indicated that the groundwater
underlying the site was contaminatied with volatile organics.
Subsequently, the D'Imperio Site was ranked on the EPA Interim
Priorities List.  A Remedial Action Master Plan was completed
for the site in June 1982.

A State Superfund Contract between the USEPA and NJDEP was
signed in September 1982 and provided for the funding of a
Remedial Investigation and Feasibility Study (RI/FS) and the
installation of a security fence.  EPA's consultant NUS has
undertaken the work necessary to complete the RI/FS.

Site Geology

The D'Imperio Property Site is situated in the Atlantic Coastal
Plain Physiographic Province.  This is a lowland region where
elevations are usually less than 100 feet above mean sea level
and local relief is minimal.  The drainage pattern is poorly
developed and low swampy areas are common.

In overall geologic character, the coastal plain can be described
as a wedge of semi-consolidated, Cretaceous and Tertiary
sedimentary deposits that overlap older crystalline rocks of the
Piedmont Province to the west.  This wedge dips less than one
degree eastward, and thickens toward the Atlantic coast.  It
includes strata o£ sand, silt, clay and occasional beds of
marl, gravel and peat,
                      X
Below the Cohansey Sand is the Kirkwood Formation.  It is not
exposed in the eastern part of the Coastal Plain, but it is
known to be an extensive subsurface unit, lithologically similar
to the Cohansey, and in places hydrologically continuous with it.

-------
                              -3-
The Cohansey Sand unit occurs throughput most of the New Jersey
Coastal Plain and underlies the D'Imperio Site.  The Cohansey
Sand includes beds of sand/ gravelly sand, and subordinate
clay.  The'sands are typically fine to medium-grained with
scattered lenses of gravel. ^The sands are generally unconsoli-
dated, but in places are cemented by iron oxides.  Inter-beds
of clay, usually less than 10 feet thick, occur in most sections
of the Cohansey Sand.  Individual beds within the Cohansey are
lenticular; stratigraphic contacts are often gradational and
interfingering.  Thickness of the Cohansey Sand ranges from
more than 200 feet near the coast, to about 50 feet in parts of
Cumberland County, approximately 20 miles west of the site.

Most of the site area is directly underlain by unconsolidated
sediment of the Cohansey Sand.  A small area skirting the
southern edge of the site is underlain by a gravelly sand,
probably belonging to the Bridgeton Formation.

Strata at the site is primarily sand, however, two extensive  -
intervals of clay are predominant.  For purposes of reference,
these units are named the upper and lower clay.  The sands are
subdivided on the basis of their position relative to the lower
clay; the Upper-Cohansey and Mid-Cohansey are above and below
the lower clay, respectively.  All of the stratigraphic units
exhibit some degree of variability.  The clay units include
distinct lenses of silt and sand, and grade into silty and
sandy clays.  Sandy intervals are likewise variable.  Thin
lenses of clay and silt occur in the sand units, and variable
amounts of interstitual silt and clay are also present.

The upper clay is well defined with sharp contacts above and
below.  It usually is 5 feet thick or less, and is located at
a depth of about 10 to 15 feet.  Although designated a clay
unit for stratigraphic purposes, in many areas silt or clayey
fine sand is the predominant grain size.

The lower clay interval is of more concern because of its
influence on the groundwater regime.  The top of the clay is at
a depth of about 30 to\45 feet and the thickness ranged from 6
to 17 feet.  The clay thins rapidly in a northwesterly direction,
Contacts between the clay and the units above and below are
gradational and interfingering.  Consequently, the thickness
variations may reflect lithofacies changes rather than thinning
or thickening of a well defined bed.

The sand strata below the lower clay (Mid-Cohansey) is quite
distinct throughout the site, unlike the other sand zones,
which would be difficult to correlate without the clay marker
beds.  This lower sand is coarser grained and contains less
silt and clay than upper sands.  It is distinctly colored a
deep brown, yellow, or brownish red.

-------
                              -4-


REMEDIAL INVESTIGATION ACTIVITIES AND.RESULTS

Remedial Investigation Activities;

The remedial investigation of the D'Imperio Site included the
following activities:

- Electromagnetic resistivity and magnetometer surveys

- Collection of eighteen surface soil samples from sixteen test
  pits and analyses via gas chromatograph (GO screening (1-3
  samples) and priority pollutant analyses (15 samples)

- Collection of twelve waste samples and analyses via GC screening

- Drilling of fifteen monitoring wells in the Upper Cohansey
  and Middle Cohansey aquifers

- Collection of thirty-eight groundwater samples from new and
  existing monitoring wells and priority pollutant analyses of
  all samples

- Collection of twelve potable water samples from private wells
  ranging from 1400 to 3200 feet downgradient of the site and
  priority pollutant analyses of all samples

- Collection of six air samples and organic analyses of all
  samples

The results of these investigative activities indicate that the
wastes disposed of at the D'Impe.rio site have resulted in the
contamination of the underlying groundwater in the Upper and
Middle Cohansey Aquifers.  In addition, the soil adjacent to
and underlying the disposal area was found to be contaminated.

Laboratory analyses of groundwater samples obtained from existing
and newly constructed monitoring wells indicated significant
levels of volatile organics.  Contaminant plumes were mapped in
both the Upper Cohansey and Middle Cohansey Aquifers.  The
Upper Cohansey has significantly greater levels of contaminants
than the Middle Cohansey.  Organic compounds detected in high
concentrations in groundwater samples taken from the upper
aquifer included:  2-butanone (MEK), 1,2-dichloroethane, ethyl-
benzene, trichloroethylene and toluene.  Appendix A includes a
list of concentration ranges for critical contaminants detected
in on-site monitoring wells as well as the established acceptable
daily intakes (ADI) and preliminary protective concentration limits
(PPCL) for these contaminants.  An isocontour map of the contam-
inants in the shallow aquifer indicates that the bulk of the
contaminants are within 200 feet of the site and the forward

-------
                               -5-
 edge of the  plume  is  moving  in  a  southwesterly  direction  and  is
 approximately 800  feet from  the site.   A similar  map of the
 Middle Cohansey indicates  that  the  aquifer  also flows in  a
 southwesterly- direction and  the center  of the plume  is approxi-
 mately 400 feet from  the site.

 The laboratory results of  twelve  potable water  samples obtained
 1400 to 3200 feet  downgradient  of the site  indicated that none
 of  the wells were  affected by the contaminants  detected at the
 D'Imperio site.

 The results  of laboratory  tests on  soil samples obtained  during
 the remedial investigation indicated that organic base neutral,
 acid compounds and volatile  organics exist  at the ground  surface
 to  depths of ten feet.   The  highest concentration of contaminants
 included; acetone, 2-butanone (MEK), bis (2-ethylhexyl) phthalate
 and di-n-butyl phthalate.

 The current  condition of scattered  drums at the ground surface
 and surface  waste  material pose a serious threat  to  the public
 and the environment.   The  priority  pollutant contamination
 contained in these items provides a potential for harm for those
 who come in  direct contact with these materials.   Detrimental
 impacts to the local  environment  may also result  from the release
 of  contaminants  from  those containers which may be intact.  The
'migration of pollutants into the  underlying groundwater has
 resulted in  the contamination of  the Upper  Cohansey  and Middle
 Cohansey Aquifers. The removal of  the  remaining  highly contam-
 inated source material will  lessen  potential for  further
 contamination.

 Screening of Remedial Action Technologies

 The evaluation of  the results of  the remedial investigation
 provided the basis for the clean-up goals and objectives  for
 site remediation.   The clean-up goals and objectives established
 for the D'Imperio\Site include  the  following:

     'Eliminate the future  risk  of contaminated  groundwater
      ingestion by  present  and potential users in  the vicinity
      of the  site.

     "Miminize the  risk to  the public from exposure to wastes
      and contaminated soils  in  the  site area.

     "Prevent the migration of contaminants  from wastes left on
      the site.

     "Protect the public and  on-site workers from  health impacts
      resulting from the implementation  of the remedial action.

-------
                              -6--
Th e initial step in the evaluation of remedial alternatives is
the screening of potential remedial technologies.  The screening-
procedure was used to eliminate those technologies which were
technically infeasible and environmentally unacceptable.  The
procedure used consists of. the five steps as follows:

'Identify site problems and pathways of contamination.

'Identify general response actions that properly address site
 problems and meet clean-up goals and objectives.

"Screen the technologies implied by each response action to
 eliminate inappropriate and infeasible technologies.

'Assembly of the remaining technologies into operable remedial
 alternatives.

'Screen the remaining alternatives eliminating those which do
 not adequately protect the public health, welfare and environ-
 ment as well as those alternatives whose cost are significant
 when compared with the benefits provided to the public health
 and/or environment.

A comprehensive list of remedial technologies was screened in
accordance with established procedures.  The results of the
screening procedures identified the feasible remedial action
components which when integrated would result in establishing
remedial alternatives.

REMEDIAL ALTERNATIVE COMPONENTS

Source Control/Removal & Disposal

Excavation and removal of waste materials and highly contaminated
soils is a component of a remedial alternative which would
reduce the source of groundwater contamination.  Final disposal
of the wastes coajd be either in an on-site landfill or off-site
in a permitted Hazardous Waste Management Facility (HWMF).
                      '<
The material proposed for excavation include, the waste containers,
bulk sludges, and highly contaminated soils adjacent to the
containers and sludges.  The intent of the excavation is to
remove the most contaminated source material and minimize the
total volume of excavation.

The excavation area is shown in Figure 3.  The area corresponds
to the general location of the waste containers and sludges
identified during the field investigation.  The average excavation
depth of 5 feet, is based upon visual observations of waste
materials made during the digging of test pits and laboratory
results of soil samples.

-------
                              -7-
Excavation of the waste containers and soils would be performed
with conventional earthmoving equipment, including dozers,
loaders/ backhoes, and clamshells.  The remedial alternatives
for final disposal of the excavated material are discussed
below.

1.  On-Site Landfill

    An on-site landfill was sized to accomodate waste containers,
    sludges and contaminated soils excavated from the D'Imperio
    Site.  A typical landfill section is shown in Figure 4.  A
    plan view location of the proposed on-site landfill area
    required is illustrated in Figure 5.  The average waste
    thickness would be ten feet with the bottom of the landfill
    at three feet below the existing grade.
                                               •
    The landfill incorporates a two-liner design with both
    leachate collection and leak detection zones.  Synthetic
    membranes of polyvinyl chloride (PVC) were chosen as the
    liner material because of their compatability with the
    dominately volatile organic carbon character of the wastes.
    A 5,000 gallon underground storage tank would be used to
    collect liquids from the leachate collection and detection
    zones.

    A double-layer cap is used consisting of a 50 mil PVC membrane
    and a 2 foot clay layer beneath a 1 foot sand drainage layer.
    Additional soil with a vegetative cover is on top of the
    drainage layer.  A geotextile filter fabric is used between
    the vegetative cover and drainage layer to reduce clogging of
    the drainage layer with soil fines and to add a physical
    barrier to provide further protection for the cap.

    The proposed on-site landfill location as shown on Figure 5
    was selected because of it's proximity to the D'Imperio
    Site and it's accessibility for post-closure maintenance
    and monitoring..  The landfill must also be excluded from
    work areas associated with any groundwater recovery system.
                      \
    The Pinelands Commission has informed us in a letter dated
    March 13, 1985 that the disposal of hazardous and toxic
    waste is prohibited in the Pinelands.

-------
                              -8-
    The State of New Jersey has also adopted regulations governing
    the siting of new hazardous waste facilities.  The proposed
    on-site Landfill will violate the following portions of
    these regulations:

    1. For the purpose of protecting the population of the
       State:

       No land emplacement or impoundment type of new major
       commercial hazardous waste facility shall be sited within
       2,000 feet of any structure which is routinely occupied
       by the same person or persons more than 12 hours per
       day, or by the same person or persons under the age of
       18 for more than two hours per day;

    2. For the purpose of protecting environmentally sensitive
       areas, no new hazardous waste facility shall be sited in
       or on:

       The Pinelands Area as established by NJSA 12:18A-11A of
       the Pinelands Protection Act, NJSA 13:18 A-l et seq.

    3. For the purposes of protecting groundwater:

       Land emplacement and impoundment type of new major
       commercial hazardous waste facilities shall be prohibited
       in the following areas:

       a. In areas within one mile of a water supply well or
          well field producing over 100,000 gallons per day,
          unless it can be demonstrated to satisfaction of the
          Department or Commission, as appropriate, that natural
          hydrologic barriers isolate the site from the aquifer
          being pumped;

2.  Off-Site Disposal

    The excavation and^removal from the site of waste materials
    and highly contaminated soils is a feasible alternative.
    These materials would be manifested for transport from the
    site to a secure hazardous waste disposal facility in
    accordance with RCRA requirements.

Capping

A surface cap can be constructed to prevent precipitation and
surface runoff from infiltrating . into any areas containing
contaminated materials.  Capping of the D'Imperio Site would
be performed after the excavation of source material and
grading of the area.  Figure 3 shows the area which would be
capped.

-------
                              -9-


A cap will consist of low permeability clay (hydraulic conduct-
ivity £ 10""? cm/sec) and a flexible membrane.  The cap would be a
double layer_RCRA cap as shown in Figure 6.

The clay barrier would be constructed with clay brought in from
off-site borrow areas and compacted in 6 to 8 inch lifts to
meet compaction requirements.  Total clay thickness would be 24
inches.  On top of the clay barrier would be a 50 mil synthetic
liner and a minimum 12-inch sand drainage layer which will act
as a conduit for any water that infiltrates the topsoil.  A
geotextile fabric would be placed on top of the drainage layer
to minimize clogging.  A minimum 24-inch cover layer of uncompacted
topsoil/ loam or organic humus material capable of supporting
vegetation would be placed over the geotextile fabric.

Groundwater Recovery and Treatment

The goal of any groundwater pumping and treatment option is to
restore the groundwater in the underlying aquifers to drinking
water quality in accordance with  EPA'.s Draft Groundwater
Protection Strategy so as to protect the aquifer for future
drinking water usage.  Groundwater restoration is also being
considered to comply with the requirements of RCRA.  Based upon
a literature search it was learned that sorption coefficients
for similar organic compounds, to those found in the groundwater
were in the range 7 to 10 ug/g of clay material.  Using the
values and the average levels of 2-butanone and the aquifer
clay content of the site, it was calculated that the groundwater
contaminants exceed the sorption capacity of the soil by nine
times.  This indicates that within the recovery well boundary,
natural renovation of the groundwater is not practical and
removal is mandatory because little attenuation would occur.
Theoretically, if contaminant transport to the wells moves as
quickly as the water front, the aquifer would be cleaned by
removing one pore volume.  However, rather than plug flow, a
conservative estimate of three pore volumes was used as the
estimate of the quantity of the groundwater to be treated to
cleanse the aquifer.  SAfter pumping and treating three, pore
volumes, the effectiveness of this remedial action will be
evaluated and the need to pump and treat an additional quantity
of groundwater will be determined.

Contaminated groundwater pumped from the confined and unconfined
aquifers underlying the site will require treatment for metals
and organics prior to disposition.  The effluent from the
treatment system can be discharged to off-site surface water
via piping to Adams Branch or injected on-site into the underlying
recovery systems.  The groundwater recovery systems were designed

-------
                             -10-
by utilizing the.computer optimization model "Best wells",
which determined the optimium number and location of recovery
wells to maximize production from the aquifers.  Maximization
of groundwater extraction rates results in reduction of the
pumping and treatment system operation and maintenance duration.
It is noted that the reinjection alternatives are estimated
to be able to operate at more than twice the pumping and
treatment rates than the surface water discharges (i.e. 750
gpm vs 350 gpm).  These rates would be further refined during
design.

1.  Treatment and Discharge to Adams Branch

    The results of modeling the aquifer production for the
    off-site discharge resulted in a maximum recovery of 350
    gpm.  Groundwater treatment would begin with the removal of
    suspended particles and soluble inorganics.  The adjust-
    ment of pH in conjunction with precipitation, floculation,
    and sedimentation would remove soluble substances and
    suspended solids.  The next phase of treatment would
    involve the reduction of organic contaminants.  The use
    of the air stripping process would effectively remove the  .
    organic contaminants with the exception of MEK.   The
    effluent from the treatment process would be discharged
    to Adams Branch via construction of 3, 100 foot discharge
    pipe.

    This alternatives will require obtaining a NJPDES permit
    from the New Jersey Department of Environmental Protection.
    In addition, use of the air stripping process will require
    compliance with New Jersey's air emission requirements.

2.  Treatment and On-Site Injection

    The results of modeling the aquifer production and the
    influence of injecting the treated effluent into the
    unconfined aquifer would result in a maximum recovery of
    750 gpm.  Groundwater treatment would begin with the
    removal of suspended particles and soluble inorganics.
    The adjustment of pH in conjunction with precipitation,
    floculation, and sedimentation would remove soluble
    substances and suspended solids..  The next phase of treat
    ment would involve the reduction of organic contaminants.
    The use of the air stripping process would effectively
    remove the remaining organic contaminants with the exception
    of MEK.  The effluent from the treatment process would be
    reinjected into the underlying unconfined aquifer via use
    of a pressurized injection system.  Operational problems
    have been encountered in similar injection systems when
    bacterial iron has clogged the injection well screens.
    Fine tuning of extraction and recharge rates to optimize

-------
                             -11-


    system performance would also be an operational disadvantage.
    This alternative will require obtaining a NJPDES permit
    from the _New Jersey Department of Environmental Protection.
    In addition, use of the air stripping process will require
    compliance with New Jersey's air emission requirements.

Methyl Ethyl Ketone (HER) Treatment

MEK is a common solvent that may enter the body via ingestion,
inhalation, or skin absorbtion on direct contact.  It is a
volatile organic contaminant found in high concentrations (up
to 260,000 ppb) in the underlying aquifer.  These concentrations
exceed the acceptable daily intake (ADI) of 700 ppb for MEK.
This contaminant is not effectively removed via carbon adsorption
or air stripping.  MEK can be effectively removed via use of
a steam stripping unit.  However, in order to achieve removal
efficiencies in the 90 percent range, it would be necessary
to preheat the influent to approximately 120"F.

The entire treatment scheme would include; removal of metals,
soluble substances and suspended solids via pH adjustment in
conjunction with precipitation, floculation, and sedimentation,
heating the influent prior to steam stripping and effluent
disposal.

Use of the steam stripping process will also require compliance •
with New Jersey air emission requirements.  In view of the
limited carbon adsorption efficiency for MEK,'New Jersey air
emission requirements for the process at the proposed treatment
rates may be violated.  During design, limiting of pumping
and treatment rates would be considered so as to not result
in air emission violations.

Evaluation of Remedial Alternatives

The following evaluation of the seven remedial action alternatives
will consider their present worth cost as well as their effective-
ness in minimizing the
-------
                             -12-
                         Table No. 1
             Remedial Alternatives for Evaluation

1.  Excavate approximately 3900 cubic yards of contaminated
    material and dispose of this material in an on-site RCRA
    landfill.  Provide RCRA cap over  dump and surrounding
    area.  Pump and treat groundwater (except MEK) on-site
    and inject effluent into underlying aquifer.

2.  Excavate approximately 3900 cubic yards contaminated
    material and dispose of this material in an on-site RCRA
    landfill.  Provide RCRA cap over  dump and surrounding
    area.  Pump and treat groundwater (except MEK} on-site
    and discharge off-site to Adams Branch.

3.  Excavate approximately 3900 cubic yards of .contaminated
    material and dispose of this material in an off-site RCRA
    approved facility.  Provide RCRA  cap over dump and surround-
    ing area.  Pump and treat groundwater (except MEK) on-site
    and inject effluent into underlying aquifer.

4.  Excavate approximately 3900 cubic yards of contaminated
    material and dispose of this material in an off-site RCRA
    landfill.  Provide RCRA cap over  dump and surrounding area.
    Pump and treat groundwater (except MEK) on-site and discharge
    off-site to. Adams Branch.

5.  No Action-Continue Monitoring

6.  Excavate approximately 3900 cubic yards of contaminated
    material and dispose of this material in an on-site RCRA
    landfill.  Provide RCRA cap over  dump and surrounding area.
    Pump and treat groundwater (including MEK) on-site and
    discharge off-site to Adams Branch.

7.  Excavate appr9ximately 3900 cubic yards of contaminated
    material and dispose of this material in an off-site RCRA
    landfill.  ProvidevRCRA cap over  dump and surrounding area.
    Pump and treat groundwater (including MEK) on-site and
    discharge off-site to Adams Branch.

-------
                              -13-


Alternative No.  1

This  alternative includes groundwater  recovery  (750  gpm)  from
both  the  Upper Cohansey and Middle Cohansey aquifers, treatment
via precipitation,  floculation and sedimentation  for the
removal of metals,  and air stripping for  removal  of  organics
(except MEK).  The  effluent from the treatment  process will be
injected  into the unconfined  aquifer.   In addition,  the remaining
drums and contaminated soil (approximately 3900 cubic yards)
will  be excavated and disposed in an on-site landfill constructed
in accordance with  current RCRA requirements.   The dump area
will  then be backfilled and graded prior  to the construction
of a  RCRA approved  cap.  A groundwater  monitoring program will
be designed to evaluate the performance of the  capped dump site
and on-site landfill for a thirty year  period.

The goals and objectives established for site remediation will
be met through the  implementation of this alternative.  The
groundwater quality will be restored to meet all  of  the
current State guidelines for  drinking water (100 ppb total
volatile organics and 50 ppb  any individual organic  constituent).
MEK removal would not achieve these guidelines.  The proposed
cap will prevent the migration of contaminants off-site as
well as minimize the risk to  the public from exposure to the
waste left on the site.

It should be noted that this  alternative will violate provisions
of the New Jersey Pinelands Comprehensive Management Plan
with  regard to the landfilling of toxic wastes.  Also, the
proposed on-site landfill will violate  the New Jersey .regulations
for siting new hazardous waste facilities.  This alternative
will require obtaining a NJPDES permit  from the NJDEP for the
groundwater injection of the  treated effluent.

Alternative No.  2

This alternative includes groundwater recovery (350 gpm)  from
both the Upper Cohansey and Middle Cohansey aquifers, treatment
via precipitation, floculation and sedimentation for the
removal of metals, and air stripping for removal of organics
(except MEK).   The effluent from the treatment process will
be discharged  to Adams Branch.  In addition,  the remaining
drums and contaminated soil (approximately 3900 cubic yards)
will be excavated and disposed in an on-site  landfill constructed
in accordance  with current RCRA requirements.   The dump area
will then be backfilled and graded prior to the construction
of a RCRA approved cap.  A groundwater monitoring program
will be designed to evaluate the performance  of the capped dump
site and on-site landfill for  a thirty year period.

-------
                             -14-
The goals and objectives established for site remediation will
be met through the implementation of this alternative.  The
groundwater quality will be restored to meet all of the current
State guidelines for drinking water (except for MEK removal).
The proposed cap will prevent the migration of contaminants
off-site as well as minimize the risk to the public from
exposure to the waste left on-site.

It should be noted that this alternative will violate provisions
of the New Jersey Pinelands Comprehensive Management Plan
with regard to surface water discharges and the landfilling
of toxic wastes.  As previsouly indicated, the proposed
on-site landfill will violate the New Jersey regulations for
siting new hazardous waste*facilities.

Alternative No. 3

This alternative includes groundwater recovery (750 gpm) from
both the Upper Cohansey and Middle Cohansey aquifers, treatment
via precipitation, floculation and sedimentation for the
removal of metals, and air stripping for removal of organics
(except MEK).  The effluent from the treatment process will be
injected into the unconfined aquifer.  In addition, the remaining
drums and contaminated soil (approximately 3900 cubic yards)
will be excavated and transported off-site to a RCRA approved
hazardous waste disposal site.  The dump area will then be
backfilled and graded prior to the construction of a RCRA
approved cap.  A groundwater monitoring program will be designed
to evaluate the performance of the capped dump site and the
on-site landfill for a thirty year period.

The goals and objectives established for site remediation
will be met through the implementation of this alternative,
The groundwater quality will be restored to meet all of the
current State guidelines for drinking water (except for MEK
removal).  The proposed cap will prevent the migration of
contaminants off-site as well as minimize the risk to the
public from exposure to the waste left on the site.

This alternative will require obtaining a NJPDES permit from
the NJDEP for the groundwater injection of the treated
effluent.

-------
                             -15-


Alternative No. 4

This alternative includes groundwater recovery (350 gpm) from
both the Upper Cohansey and Middle Cohansey aquifers, treatment
via precipitation, floculation and sedimentation for the
removal of metals, and air stripping for removal of organics
(except MEK).  The effluent from the treatment process will be
discharged to Adams Branch.  In addition, the remaining drums
and contaminated soil (approximately 3900 cubic yards) will be
excavated and transported off-site to a RCRA approved hazardous
waste disposal site.  The dump area will then be backfilled and
graded prior to the construction of a RCRA approved cap.  A
groundwater monitoring program will be designed to evaluate the
performance of the capped dump site and on-site landfill for a
thirty year period.

The goals and objectives established for site remediation will
be met through the implementation of this alternative.  The
groundwater quality will be restored to meet all of the
current State guidelines for drinking water (except for MEK
removal).  The proposed cap will prevent the migration of
contaminants off-site as well as minimize the risk to the
public from exposure to the waste left on the site.

It should be noted that this alternative will violate provisions
of the New Jersey Pinelands Comprehensive Management Plan
with regard to surface water discharges.

Alternative No. 5

No Action - Continue Monitoring

This alternative would not meet the goals and objectives for
site remediation.  The potential future risk of ingesting
contaminated groundwater by users in the vicinity of the site
would remain.  Als^o, the migration of contaminants from
wastes remaining on site and the exposure to the public from
these contaminants at,'* and near ground level will not be
eliminated.

-------
                             -16-


Alternative No. 6

This alternative includes groundwater recovery (350 gpm)
from both the Upper Cohansey and Middle Cohansey aquifers,
treatment via precipitation, floculation and sedimentation
for the removal of metals, and steam stripping for removal
of organics (including MEK).  The effluent from the treatment
process will be discharged to Adams Branch.  In addition, the
remaining drums and contaminated soil (approximately 3900
cubic yards) will be disposed in an on-site landfill constructed
in accordance with current RCRA requirements.  The dump area
will then be backfilled and graded prior to the construction
of a RCRA approved cap.  A groundwater monitoring program
will be designed to evaluate the performance of the capped
dump site and on-site landfill for a thirty year period.
                                               •
The goals and objectives established for site remediation will
be met through the implementation of this alternative.  The
groundwater quality will be restored to meet the all of
current State guidelines for drinking water.  The proposed
cap will prevent the migration of contaminants off-site as
well as minimize the risk to the public from exposure to the
waste left on-site.

It should be noted that this alternative will violate provisions
of the New Jersey Pinelands Comprehensive Management Plan with
regard to surface water discharges and landfilling of toxic
wastes.  The proposed on-site landfill will violate the New'
Jersey regulations for siting new hazardous waste facilities.

Alternative No. 7.

This alternative includes groundwater recovery (350 gpm) from
both the Upper Cohansey and Middle Cohansey aquifers, treatment
via precipitation, floculation and sedimentation for the
removal of metals< and steam stripping -for removal of organics
(including MEK).  The .effluent from the treatment process
will be discharged to Adams Branch.  In addition, the remaining
drums and contaminated soil (approximately 3900 cubic yards)
will be excavated and transported off-site to a RCRA approved
hazardous waste disposal site.  The dump area will then be
backfilled and graded prior to the construction of a RCRA
approved cap.  A groundwater monitoring program will be
designed to evaluate the performance of the capped dump site
and on-site landfill for a thirty year period.

-------
                             -1.7-
The goals and objectives established for site remediation will
be met through the implementation of this alternative.  The
groundwater quality will be restored to meet all of the
current State guidelines for drinking water.  The proposed
cap will prevent the migration of contaminants off-site as
well as minimize the risk to the public from exposure to the
waste left on the site.

It should be noted that this alternative will violate provisions
of the New Jersey Pinelands Comprehensive Management Plan with
regard to surface water discharges.  In addition, operation
of the steam stripping unit will require obtaining an air
emission permit from the NJDEP.

Community Relations
                                              *
A public meeting was held on December 14, 1982 at the Atlantic
County Community College to discuss the work to be undertaken
by EPA's consultant as part of the RI/FS.  Notices of the
meeting were sent to all local officials and interested
parties as outlined in the D'Imperio Property Community
Relations Plan.  At this meeting, EPA officials provided an
overview of the Superfund program.  They also discussed the
RI/FS activities which were to be performed as part of the
D'Imperio project.  Following this presentation, the meeting
was concluded with a question and answer session.

A second public meeting was held on November 19, 1984 at the
Hamilton Township Municipal Building to discuss the work
conducted as part of the remedial investigation and the
results obtained from this work.  Letters were sent to local
and county officials and other interested parties notifying
them of the meeting.  A copy of the draft remedial site
investigation report was transmitted to the township clerk's
office for public review.  An EPA fact sheet was made available
to the public at.^the meeting.  Approximately 35 persons
attended.  EPA officals and their consultant discussed the
results of the remedial investigation and answered questions
related to the work, being performed at the D'Imperio site.

A third public meeting was held on March 6, 1985 at the
Hamilton Township Municipal Building to discuss the remedial
alternatives.  An information package including an agenda and
fact sheet were provided to the approximately 40 people who
attended.  Copies of the draft feasibility study and notification
of the public meeting were sent to local officials and other
interested parties for public review.  EPA officials and
their consultant discussed the remedial alternatives and
responded to the concerns and questions raised by the public.

-------
                             -18-
More detailed information regarding the Community Relations
Program is included in the attached Responsiveness Summary.

Enforcement

The EPA had initially identified two landowners as potential
responsible parties (PRP's).  Notice Letters were transmitted
to these parties in March 1982.  One landowner indicated that
the dumping did not occur on his property and, therefore,
declined to undertake any cleanup action.  The other party
responded by saying that he could not undertake any remedial
actions due to the lack of financial resources.  In August
1982, a Notice Letter was sent to a third landowner.  This
party responded by indicating that he had no responsibility
for the dumping.   However, he did offer to cooperate fully
in EPA activities.

In March 1985, EPA sent notice letters to the three potential -
responsible parties.  To date, none of these parties have
offered to implement the remedial design or cleanup.  Currently,
the EPA is continuing to search for additional responsible
parties.

Recommended Alternative

According to the CFR Part 300.68 (J), cost-effective is
described as the lowest cost alternative that is technically
feasible and reliable and which effectively mitigates and
minimizes damages to and provides adequate protection of
public health, welfare and the environment.  A cost comparison
of the remedial alternatives is presented in Appendix B.  The
evaluation of the seven remedial alternatives leads to the
conclusion that Alternative #7 is the appropriate cost-effective
alternative which achieves the recommended cleanup goals.
The alternative includes the excavation and disposal of waste
materials at an o^f-site RCRA facility, the treatment of
contaminated groundwater including MEK removal via steam
stripping, and the discharge of the treated groundwater to a
surface stream.

In general, the alternatives evaluate various combinations of
three major cleanup components.  They include the method of
disposal of the waste materials (on vs off-site), the level
of groundwater pumping and treatment with particular emphasis
on the degree of MEK removal, and the location of the discharge
of the extracted groundwater after treatment (injection vs.
surface stream).

-------
                             -19-
It was determined that disposal of source materials was more
appropriate at an off-site RCRA facility than in a facility
to be constructed, at the site.  The reasons for ruling out on-
site disposal are as follows.  The State of New Jersey has
established and recently adopted siting criteria for hazardous
waste facilities.  These criteria which are used in connection
with the delegation of the RCRA program to the State would
discourage the siting of a hazardous waste landfill in the
Pinelands area.  In addition, the Pinelands Comprehensive
Management Plan prohibits the construction of a RCRA landfill
in the environmentally sensitive Pinelands.

Furthermore, as a matter of policy, it is not efficient and
therefore not effective to construct and operate a small
hazardous waste containment system in such an environmenally
sensitive area.  In fact, there would be some concern about
the technical reliability of an on-site landfill in the event
of a system failure.  Rather than having a number of small
landfill sites scattered about, it is more efficient and thus
more effective to operate and maintain a fewer number of
larger, properly sited and comprehensively monitored disposal
facilities.

A second component of the recommended alternative involves
the level of groundwater cleanup including the degree of MEK
removal required.  The RCRA goal is to clean up groundwater
to background conditions.  With the exception of MEK, the
application of standard treatment technology is expected to
reduce contaminant levels to a point which will approach
background.  It is estimated that it will take 17 months to
achieve this goal.  After that time, an evaluation will be
made to determine whether alternate concentration limits are
appropriate.

Since the levels of MEK in the groundwater (up to 260 ppm)
are significantly>higher than the acceptable daily intake
concentration (700 ppb), EPA has determined that MEK removal
is required.  Unlike the volatile organic compounds, a steam
stripping process must be utilized to effectively, remove MEK
from the groundwater.  In order to minimize the operation and
maintenance costs associated with the steam stripping operation,
an evaluation will be made during the design phase to identify
the most appropriate operational conditions (pumping locations
and stripping duration periods).  In essence, the unit would
be used only when necessary as opposed to steam stripping the
entire plume potentially resulting in substantial cost savings.

-------
                             -20-
A third component of Alternative #7 is the discharge of the
treated grpundwater to Adams Branch.  The Pinelands Commission
has notified-EPA that the Pinelands Comprehensive Management
Plan prohibits the direct discharge of wastewater into any
surface body of water.  A summary of the appropriate regulations
contained in the Pinelands Comprehensive Management Plan,
including waiver procedures is included as Appendix C.

On March 20, 1985, EPA officials met with representatives of
the NJDEP and Pinelands Commission to discuss the surface
water discharge issue.  Both EPA and NJOEP feel that the
surface discharge is more reliable and environmentally sound
than groundwater injection.  Thus, it has been decided that a
waiver of the surface discharge rule be requested from the
Pinelands Commission.

Agency officials and representatives of the NJDEP are scheduled
to meet with the Pinelands Commission to present their argument
for a temporary surface water discharge.  EPA feels that the
waiver may be obtained in the near future.  However, if the
waiver is denied, Alternative #7 would be modified to include
injection of the treated groundwater to the unconfined aquifer;
Although not as preferable, reinjection of the treated ground-
water is an acceptable alternative.

Based upon the above discussion, the Agency and the State of
New Jersey recommend the implementation of Alternative 17.
This Alternative is cost-effective, reliable and best achieves
the established cleanup goals.

The following listed figures represent a cost estimate for
the proposed remedial actions.  The EPA will be responsible
for paying 100% of the cost of project design.  Cost sharing
for project implementation is 90% Federal and 10% State of
the cost to implement the remedial action as well as the
cost of conducting the groundwater recovery treatment plan
which is expected to continue for about 17 months.  The
remaining monitoring costs will be borne by the State of
New Jersey.

-------
                               -21-


           Cost Summary for Remedial Alternative No. 7


  Remedial Measure      Capital      Present Worth     Total Cost
    Components           Cost           of O&M	   Present Worth

1. Excavation and
   Offsite Disposal   $2,153,639      $    0           $2,153,639

2. Cap Site,
   Monitoring and
   Post Closure
   Maintenance           620,906        330,670           951,576

3. Groundwater
   Recovery              236,522        157,846 -         394,368

4. Treatment  Plant
   and Operation       1,053,084        680,933         1,734,017

5. Discharge  Line        187,400      	0	         187,400

              TOTAL   $4,251,551      $1,169,449       $5,421,000


  Consistency With Other Environmental Laws

  The final recommended remedial alternative for the D'Imperio
  Site will require the removal of 3900 cubic yards of surface
  drums, waste material and contaminated soil.  These materials
  will be manifested for transport from the site to a secure
  facility in accordance with RCRA requirements.  If the Agency
  recommended the less costly alternative of on-site disposal
  of source material, it would have violated the State regulations
  and Pinelands Comprehensive Management Plan for siting hazardous
  waste facilities.*.

  Constructing a cap oveV the dump and surrounding area is
  another component of the recommended remedial alternative.
  The cap will be constructed in accordance with current RCRA
  requirements.  Also part of the recommended remedial alternative
  is the recovery, treatment and discharge to surface waters
  (or the aquifer) of contaminated groundwater.  In accordance
  with RCRA,  groundwater must be cleaned up to background
  concentrations or appropriate alternate concentration limits
  or maximum  contaminant levels.  The cleanup program is
  expected to achieve these RCRA requirements.  A New Jersey
  Pollutant Discharge Elimination System Permit will be obtained
  for the effluent discharge to Adams Branch.  In addition,  the
  operation of the steam stripping unit will require an air
  emission permit from the NJDEP.

-------
                             -22-
Although the Pinelands Commission currently prohibits any new
surface discharge in its jurisdictional area, the Agency
feels that the temporary discharge of the treated groundwater
would not result in any long term detrimental impacts and
would be environmentally preferable to groundwater reinjection.
As previously discussed, EPA feels that a waiver of the
Pinelands Commission rule prohibiting a surface discharge may
be obtained in the near future.  If the waiver is not approved,
the treated groundwater will be reinjected in accordance with
NJDEP permit requirements.  An Environmental Assessment which
addresses the impacts of the discharge to Adams Branch is
included in the Responsiveness Summary.

Operable Units

Since the recommended remedial alternative includes numerous
individual components, it is expected that the remedial
measures will proceed in a phased manner.  The initial phase
would include the excavation of source material, backfilling
and grading.  The next component of the cleanup would be to
cap the site area.  Following this work, a discharge line
would be constructed from the site to Adams Branch {if the
surface discharge is approved).  Finally, a groundwater
recovery system and treatment units would be constructed and
operated until the contaminants in the underlying aquifers
are reduced to acceptable RCRA and State drinking water
quality levels.


Operation and Maintenance

Upon completion of the recommended remedial action, monitoring
of the site will be necessary to evaluate the quality of the
local groundwater.

Future Actions   \

Schedule              "*-                    Date

- Final Record of Decision                 March 1985
- Obligate Design Funds                    March 1985
- Amend State Superfund Contract           April 1985
- Continue search for responsible
   parties                                 March-September 1985
- Initiate Design                          April 1985
- Complete Design                          September 1985
   (for first phase excavation)

-------
                                      APPENDIX A
	Compound

Benzene

2-Butanone
(methyl ethyl ketone)

1,2-Oichloroethane

Ethylbenzene

Tetrachloroethylene

Toluene

Trichloroethylene

Xylene

Arsenic

Chromium

Lead
0. CONTAMINANTS
Media
Monitoring Wells
Monitoring Wells
Monitoring Wells
Monitoring Wells
Monitoring Wells
Monitoring Wells
Monitoring Wells
Monitoring Wells
Monitoring Wells
Monitoring Wells
Monitoring Wells
AND ADI AND PPCL LEVELS
Concentration Range1
1-70 U9/I
6-260,000 ug/l
14-3,200 ug/l
3-1,100 ug/i
2.6-20,000 ug/l
1-29.000 ug/l
5-5,700 ug/l
6-4,725 ug/l
20-900 ug/l
20-2.110 ug/i
10-5.000 ug/i
AD|2
NA
700
NA
4,750
NO
15.000
NO
80,000
NA
63,000
NO
PPCL3
0.673
NA
0.94
4,750
1.0 "
15,000
1.84
NA
NA
5.0
5.0
1  Range of low to high concentrations in micrograms per liter (ug/l)

2  AOI - Acceptable Daily Intake Level, ug/l
   Reference (USEPA, May ^984)
                               ^
3  PPCL - Preliminary Protective Concentration Limit, ug/l
   Reference (USEPA, Memo,  1984)

-------
                              APPENDIX B

            REMEDIAL ALTERNATIVES PRESENT COST COMPARISON


                                                 TOTAL  PRESENT WORTH
   REMEDIAL ALTERNATIVE          CAPITAL           INCLUDING O&M

1.  Source removal,  dispose
   on-slte and cap  site.
   Pump groundwater, air
   strip and Inject effluent.    $3,044,014           $3,656,000


2.  Source removal,  dispose
   on-slte and cap  site.
   Pump groundwater, air strip
   and off-site discharge.       2,836,514           3,631,000


3.  Source removal,  dispose
   off-site and cap site.
   Pump groundwater, air
   strip and inject effluents.   4,354,658           4,439,782


4.  Source removal,  dispose
   off-site and cap site.
   Pump groundwater, air
   strip and off-site
   discharge.                    4,147,168            4,416,000


5.  No Action-
   Continue Monitoring.             50,000              357,000

                 •>
6.  Source removal',  dispose
   on-site and cap sifce.
   Pump groundwater, steam
   strip and off-site
   discharge.                     2,940,897           4,635,000


7.  Source removal,  dispose
   off-site and cap site.
   Pump groundwater, steam
   strip and off-site
   discharge.                     4,251,551           5,421,000

-------
                        APPENDIX C

     The Pinelands Protection Act, N.J.S.A. 1.3:18A-i ot soq.
(L. 1979, e.lll), will impact on the selection of a remedial
alternative.  The Comprehensive Management Plan, ("CMP"),
adopted by the Pinelands Commission pursuant to N.J.S.A.
]3:18A-8, provides the framework for the coordination of all
governmental programs affecting the natural and cultural
resources of the pinelands area.  No State approval,
certificate, license, consent, permit, or financial assistance
for the construction of any structure or the disturbance  .
of any land within the pinelands area shall bo granted unless
such approval or grant conforms to the provisions of the CMP;
however, the Pinelands Commission is authorized to waive strict
compliance with the CMP upon a finding that such waiver is
necessary to allevate extraordinary hardship or to satisfy
a compelling public need, is consistent with the purposes and
provisions of the Pinelands Protection Act and the National
Parks and Recreation Act of 1973,  16 U.S.C, 46i et seq., and
would not result in substantial impairment of the resources
of the pinelands area.  N.J.S.A. 13:18A-10c.  The wai.er .
procedures are set forth in Sections 4*501 to 4-507 of the
CMP and are also found in N.J.A.C. 7:50-4.31to 4.60.  Based
on the procedures set forth therein, it is not likely that a
waiver would be granted for on-site disposal of tho 3900
cubic yards of contaminated material; however, it appears that
a waiver based on compelling public need would be granted for
the discharge of treated groundwater to the Adams Branch.
                                  Susan Saveca
                                  March 25, 1985

-------
D'DffERIO SITE VICINITC MAP




                       iFICUIE 1

-------
                            UNNAMED
                            WETLAND
BASE MAP O A PORTION OF THE U.S.OS. MAYS LANCWNO.NJ QUAORANOLE (JB MINUTE SERIES, 1989, PHOTOREVISED 1972). CONTOUR
                                    FIGURE #2
                                SITE LOCATION MAP
                     D'IMPERIO SITE. HAMILTON TOWNSHIP, NJ

-------
 EXCAVATION
  AREA
   FIGURE 03

        EXCAVATION AND CAPPING LIMITS
D'IMPERIO SITE, HAMILTON TOWNSHIP, NJ

-------
24* KCDCO TOP8WL
                                                                                                                 CEMTCKJNE 4* OU. LCACWIC OOLLfCinN IMMMOU
                                                                                                                                                    POM!
it' now zoNe(ioi»io~cni/Mc)
BOMLPLDOU PVCUNDKKMildoaAK)

t4*CLAT
                                                                                  IWCMATt COLLECTION MPC
                                                                                          orretmw
ntTCMPM)

UAOWtt OOLLCCnON

BOWL njCXMJE FVC LMO)(Kl|ilfc»ytac)

LEAK OCTtCTION

9O

14" CLAY (K«l>llf«MAM fDMEAMUTY)
                                                                                                                                UNDfMWXMDfTOMae TWK
                                                                                                                                    PQMUAOUTE
                                                                                                                                    (8000 MLUMS)
                                                             FIGURE  ti-H
                                              TYPICAL  RCRA LANDFILL CROSS SECTION

-------
                                         KIEJDAN ANDTROCKI
                                         (5)  CALT, INC.
                                              (?)  MARTIN A. 3ILBERO
                                                   (5)  ROBERT MORGAN AND JOHN COREA
                                                         (?)  CO-ENGLISH LIMITED
                                                              (7)  FRANCESCO D'lMPEWO
                                                  FIGURE  #5
                                                  LANDFILL LOCATION
PROPOSED
 RCRA
LANDFILL
                                                                          PROPERTY LINE
                                                                          PROPOSED MONITORING
                                                                          EXISTING MONITORING ¥

-------
CAP"
PROPOSED
DOUBLE
LINER2

                                           2' VEGETATIVE COVER
                                           QEOTEXTILE FILTER FABRIC
                                           1  DRAINAGE LAYER
                                           20 MIL (MIN.) LINER1

                                           2' CLAY (10~7 CM/SEC PERMEABILITYI
                               • lAfji f*^rf »*•••••••••»*
                               : WASTE K.v.?.?.-sx
                                                    •*»••••*«
                                                    •••••••••I
                                              NOTE. 1. 60 100 MIL IS FREQUENTLY USED
                                                     BY INDUSTRY
                                                   2. SOME VARIATIONS OF THE CAP AND
                                                     DOUBLE LINER ARE ACCEPTABLE
                                                         GEOTEXTILE FILTER FABRIC
              o
            o
              -o-
                 Of LEACHATE COLLECTION
                 AND REMOVAL SYSTEM
O-
o
o
30 MIL (MIN.I LINER

V LEAK DETECTION.
COLLECTION. REMOVAL SYSTEM  |
                                                        30 MIL (MIN.) LINER1
                                                        .           ••
                                                       K 2' CLAY (10 -J CM/SEC
                                                               PERMEABILITYI
                                                                             COMPOSITE LINER
 SOUnCE: HSCD 1/85
                            FIGURE  ?6
                      RCRA CAP AND DOUBLE  LINER
                D'IMPERIO SITE. HAMILTON TOWNSHIP. NJ
                                NOT TO SCALE

-------
                  REMEDIAL INVESTIGATION/FEASIBILITY STUDY
                           RESPONSIVENESS SUMMARY

                                    FOR

                          D'IMPERIO PROPERTY SITE
                                 NEW JERSEY

                           BASED ON COMMENTS FROM
                               PUBLIC MEETING
                               MARCH 6, 1985
LEACHATE COLLECTION

Issue:        What will you do with the leachate  water collected from the site?
             Where will you take it?

Discussion:   The leachate collected from  the  proposed onsite landfill  is
             expected to be minimal.  That which is collected  will  be drained
             into a  5000 gallon tank, monitored, and periodically pumped.  The
             pumped  liquid  will be  taken to  an approved  treatment  facility.
             The choice  will  depend on the type of  contaminants in  the
             leachate.    The  facility  must meet  all Federal   and  State
             regulations.

ONSITE  LANDFILL
Issue:
Discussion
Issue:
Discussion:
It looks like the liner will be approximately 10 feet below the
surface.  What is the depth to the water table in the area?  Will
the groundwater in the area drain into the tank?  This tank will
fill  very quickly  then.

There is a  high  water table in south New  Jersey—approximately 15
feet below  the  surface.  The Federal regulation  requires that the
liner from the  landfill be 8 feet above the water table.   We do
not expect a problem with groundwater  getting into  the tank
because '-of  the  placement of the tank.

Why are you requiring an 8  foot buffer between the liner and the
water table?   Is this a standard?
We don't want  the water table  to  affect the
site.   The  8  foot  standard   is  contained
Conservation  and  Recovery Act and the cleanup
sites must meet all  RCRA  standards.
                                              integrity of the
                                              in  the  Resource
                                               of all  Superfund
Issue:

Discussion:
How long do you actually think the  bottom  liner will hold?

The systems  that  EPA  installs  are designed for approximately a
30-year  life.   During this  period, ongoing  monitoring  would
provide early warning  of potential groundwater contamination.

-------
                                   - 2 -
Issue:
Discussion:
Issue:
 The  state-of-the-art  landfills  of  20  years ago are our problems
"of_today.   These  new sites are the problems of our future.  You
 can't keep digging up these sites every 30 years.

 That 1s a problem with  landfill ing hazardous  material.   Today's
 technology  is  much more  advanced  than 20 years  ago.   Based on
 what we know today,  this is the best  we can  do.   Hopefully  10 to
 20 years from now we will not look back on this as a  problem.

 You  say the liners  last for 30 years.   How  long have you had
 experience with liners?  Are the liners designed for the seasonal
 temperature differences  we have in  south  New Jersey?   These
 liners  do not  last even  seven years.   Would  it not be better to
 just remove the material  now instead  of digging it up every few
 years?  To protect  the quality of life for  the people in the
 future  and  the  Pinelands Commission designated growth area, I am
 opposed to onsite disposal for  this site.
Discussion:
 We are here  tonight  to get just that  information  from you.
 hear  you  saying you do not want onsite disposal  of the waste.
I
MONITORING PROGRAM
Issue:
 Who  will  be overseeing the monitoring program?
Discussion:   The  New  Jersey Department  of  Environmental  Protection  (NJDEP)
             will  be  overseeing the-monitoring program for this  site.

Issue:       The monitoring plan is  currently  set  up for 30 years.   What
             prevents the  agency from deciding to walk away from the site?

Discussion:   The  money has already been earmarked for this site.   The  State  of
             New Jersey will have the money for this monitoring  program  in the
             bank at the time of cleanup.  This  money will be used  to  cover
             the  cost of monitoring  the program.
                    \
Issue:       What happens  jf the State decides not  to follow through for the
             full  30  years?

Discussion:   The  intent is for the  State  to  follow  through in monitoring this
             site.   The State will   agree  to  monitor this site for 30  years.
             It passed a $100  million  bond issue in 1981 that is set aside for
             operation costs,  which  include monitoring.

-------
                                   - 3 -
Issue:
 Will  there be an Insurance  policy on  this site 1n the event the
•State decides to not follow through with the monitoring program?
Discussion:   In order to  get the construction  money for cleaning up the site,
             the State must also obligate funds for operation  and  maintenance
             of the  system.   NJDEP has agreed to this stipulation.   If NJDEP--
             or EPA—does not fulfill  its contract, then  the  citizens  should
             take action  to  ensure that the proper work is done.

Issue:       Why 30  years of monitoring?

Discussion:   That number  1s  contained in RCRA.

Issue:       What happens after  30 years?

Discussion:   That's  a good question.  Nothing we build will last forever.

Issue:       What happens if NJDEP  decides  to  not use the money  to  clean  up
             the site?

Discussion:   The State has  signed an agreement with EPA to  implement this
             cleanup.   They  must use the funds  for  this site.
Issue:
 Is  there a timetable  when the State must start and finish  the
 work?
Discussion:   The State will  operate and  maintain whatever program is put into
             place.  The  Federal  Government  will actually hire the contractor
             to design and construct the chosen alternative for this site.

SURFACE HATER IMPACTS

Issue:       You mentioned Adams  Branch.  What is it?  Where is it?

Discussion:   It is  a stream  that  begins near the racetrack and flows west.
                    v
Issue:       What are  you intending to put into Adams Branch?

Discussion:   The treated  water from the  site  could,  according to one of  the
             qptlons,  be  drained  into Adams Branch.   The other option would be
             to re-inject the  water back  into  the ground.

Issue:       The Adams Branch is an open body of water.   Would  treated  water
             be flowing into this open area?   In looking at what to do with
             the water,  keep  in mind  that the people here do not want  a
             surface  discharge.

Discussion:   Yes.  Remember that the water would be  treated to New Jersey
             water quality standards.

-------
                                   -  4  -
Issue:
Discussion:
Issue:



Discussion:

Issue:

Discussion:


Issue:
            Once you  remove  most  of the contaminated  soil,  would this help
            cleanup the groundwater?

            Yes.  We  do believe that once the wastes are removed,  we will
            have to pump the groundwater and  strip the volatiles  for two
            years and  either drain it into the Adams Branch or pump it back
            into the  ground.

            What  really filters  the groundwater in New Jersey now?  It's
            sand.   The State continues to allow  companies to remove sand from
            all over  this state.  This should be stopped.

            The State believes  there  is more than enough  sand and  gravel.

            Does anyone know  where Adams  Branch goes?

            Under  Cologne Road into Babcock  Creek, then into  the  bay and
            eventually  into the ocean.

            Has  anyone  walked and  surveyed  the  Adams Branch?   In 1980
            portions  of  the  stream  were  dredged,  and  areas  along the  river
            were  logged.  There  are also some log roads that have dammed
            parts  of this creek.   Because  of these  past  practices,  I  am
            opposed to discharging into  the Adams Branch.

            We  have looked at  portions of the Branch but have not looked at
            the entire stream  as yet.   This information is helpful  to us.
            Subsequent to the meeting,  we performed an  onsite investigation
            of Adams  Branch and have  prepared an environmental assessment for
            potential surface water discharge to Adams Branch.

            What route would  you take to  discharge into Adams Branch?

            A  preliminary  alignment  being considered would  follow the
            Blackhorse Pike, then cross under the  highway somewhere near
            Cologne "Road, and continue along  Cologne Road prior  to discharge
            to Adams  Branch.

Issue:       Who gives you the right to discharge wastewater  to the stream?

Discussion:  The State DEP issues the  permit.

AIR QUALITY

Issue:       Can you explain air stripping to me?

Discussion:   In  this particular case, air stripping  is  pumping  the water and
            spraying  it  into a  packed column where air is used to volatilize
            the contaminants.
Discussion:
Issue:

Discussion:

-------
                                   - 5 -
Issue:
Discussion
Issue:
Discussion
             W111  all these contaminants be stripped by pumping the water into
                air?
Issue:
            Not exactly, this will be done in a controlled situation such  as
            in  a  packed column.   The nature  of  these contaminants  is  such
            that they volitilize easily and can  be stripped by air.

            When  the contaminated water  is pumped into  the air, we have air
            pollution.

            The volatilized material  will be discharged to the air; however,
            we  will constantly monitor the  air to  ensure that all air
            regulations are adhered to.   I can assure you that this will  be a
            restrictive permit and appropriate' controls  to  limit air
            emissions will be implemented.

            Will the air we breath  have all these  organics in it?
Discussion:   The  air will  be monitored continuously so there  will  be no risk
             to the  general public.

REMEDIAL INVESTIGATION FINDINGS

Issue:        Exactly what is in this pit (landfill)?

Discussion:   Mainly the  contaminants are toluene and acetone — primarily
             solvents.   The contaminant  listing is  included in the  study
             results.  These  studies  are  available  at  the  municipal  building
             (Mays  Landing).

Issue:        What has  gone  into  this  study  that would ensure that  the
             treatment— oxidation or incineration—is safe?

Discussion:   First of all,  we are not considering incineration for this site.
             We  believe  that pumping  the  groundwater  and treating  it  along
             with excavation of source material will correct the  problem here.
                          \
Issue:        How  long did it take to contaminate the two zones?

Discussion:   We  believe  about  10  years.  The zones are  the Upper Cohansey  and
             Lower Cohansey Aquifei — a total  of about 85 feet in depth.

-------
                                   - 6 -
PINELANDS COMIISSION  ISSUES
Issue:
Discussion:
Issue:

Discussion:
Issue:

Discussion:



Issue:



Discussion:



Issue:

Discussion:
Most of  the  land  in Atlantic  County  is in the Pinelands.   When
the Pinelands Commission prohibits a landfill  in the area,  how
can you even  suggest to dispose of this  material  on this site?

We  are  currently  checking  into  the  Pinelands  Commission
regulations  to determine  how feasible  this  option is.   This
information  will be verified prior  to the record of decision
(ROD).

Does the Pinelands Commission have the last word?

The  EPA and  NJDEP  will  sit  down  and  discuss  the  various
alternatives  with  the  Commission.  A  mutually  agreeable solution
will become the recommended alternative.  The  chosen alternative
must be  acceptable  to  all  the  parties  that have authority over
health  and  environment.

What will be  the input from the Pinelands  Commission?

The  Pinelands  Commission's  concern  is  for  water  and  the
environment.  The Commission will have to  approve the recommended
alternative for this site.

Since the Pinelands  Commission  stipulated  that there be no toxic
dumps within  the Pinelands, why even  consider the onsite landfill
unless  you  feel you  can override the  Commission's plan?

It may be that  the Pinelands Commission will not allow an onsite
landfill.  It  still must be determined  whether the Pinelands
Commission's  rules are  appropriate.

What are "appropriate rules"?

There aVe  some local  ordinances  that  can be overruled  by the
State and Federal  Government for the good of  the citizens.  The
Pinelands  Commission's ordinances may have  been approved and
adopted by  the  State in accordance with federal law establishing
the Pinelands.   If  that is  true,  then onsite  disposal  would not
occur.
POLICY ISSUES

Issue:
Are you considering bringing toxic wastes from other areas to the
D'Imperio  Property?   I read this in the newspaper.
Discussion:   No.   This has never been considered nor will it be.

-------
                                   - 7 -
Issue:
Discussion
Issue:
Discussion:
Issue:
Discussion
Issue:
Discussion:



Issue:


Discussion:
You did say this  1s  a  small site and that small  sites may not
receive the priority  ranking to get the work done.

There are 95 sites currently 1n  New Jersey.   This  site  is  ranked
15.   This is partly due to the fact that the  site  1s so close  to
people.   This site may be small in size but is not  a  low priority
site; therefore  the work  will  get  done.
You said the site is number 15 on the New Jersey list.
the site's number on the national list?
        What is
I'm not sure.   I  don't know  if  it 1s in the top 100 out of  over
800 sites.   The number is not the most critical component on  this
site because the  study of the problem is now finished,  and  design
and implementation will  begin this year.

My concern is not the number but rather  the time frame  when ,this
site will  be cleaned  up.

Within the next  30 days, EPA will select the  method for cleaning
up this site.   The document is called the  record of decision
(ROD).   It  will  take 3 to 6  months  to design  the  implementation
plan.  Our  goal  is by September 30 to obligate  money for  the
cleanup of this  site.

In the study, there is a section on incineration.   It  appears to
be dismissed from further consideration because an incinerator is
not available.    You  should  know that many people  are  concerned
about incinerators and would not like to see one used here.  What
are our options  if we do not like the alternative chosen?

The EPA will notify you of the decision.   We came here  tonight to
receive  your  input.   Your concerns  will  be  part of   the
information used in making the  final  decision.
What  ii the chain of  command  in  this state?
whom—EPA, DEP,  Pinelands Commission?
Who reports to
In looking at any waste solution,  we must look at the applicable
State and  Pinelands  Commission  rules and regulations.   The  EPA
and State  must  agree  on  the  solution.  The  solution  must  comply
as fully as possible  with all  applicable regulations.   Certainly,
we will  need to look  at  the  Pinelands  Commission's  regulations
and determine the applicable  standards for this area.

-------
                                   - 8 -
Issue:


Discussion:



Issue:


Discussion:



Issue:


Discussion:
Issue:


Discussion:


Issue:


Discussion:

Issue:
Discussion:
Issue:
After the cleanup,  the land will be a dead  area,  won't 1t?   I
mean, no houses could be built  on  it.

The area within the  fence—1  to  2  acres—will  be  controlled,  but
the area outside the fence,  after  the cleanup,  will  not  have  any
restrictions placed  on Its  use.

How did  the government let us  get  Into  this mess?  Who  wasn't
doing his job?

Many of the sites on  the Superfund 11st were here before  the
environmental  agencies  were  formed.   The common  practice  for
disposal of  wastes was to deposit them In dumps.

Don't EPA  rules forbid the  building  of.a  landfill  over an
aquifer?

No.  The EPA  regulations under  RCRA do not  forbid  the  practice
but the design must  include precautions  to prevent  contamination
of the aquifer.   The  Pinelands Commission's regulations,  however,
may forbid the locating of  a  landfill over an aquifer.

Do  these suggested  alternatives  follow  DEP's criteria  for
disposal of  waste?

Yes.  The suggested  alternatives could be accepted  by DEP.   The
DEP will, of course, be involved in  the final decision.

Who  bears  the responsibility if you discharge toxics into  this
Branch and problems  develop in the future?

The EPA does.

The State of New Jersey Hazardous  Waste Siting Commission is
intending to build a  treatment  facility somewhere  in  the state.
Could itxbe here?  Or,  could the wastes from this  site  be taken
there?        \

The site will  not  be  the D'Imperio Property Site.   However, if
the State had a treatment facility,  EPA  would certainly  consider
using that  site. It would be preferable to sending it across
several  states.

Could we not  contain  the D'Imperio material  now and then dispose
of  it when  the  new  site is opened?  That  would be  preferable to
30 years on the  site.
Discussion:  Those are  very good suggestions that we will  consider.

-------
                                   - 9 -
Issue:
What Is the possibility of the no-action alternative?
Discussion:   Because of  the potential for future Impact on water supplies, the
             no-action alternative has been eliminated.
Issue:
How can we  prevent these problems from occurring again?  The
government should stand  up  to industry and  refuse  to let them
make this material 1f they cannot  reuse  it.
Discussion:   The  Resource  Conservation  and Recovery Act (RCRA) now regulates
             landfills  and  hazardous chemicals.

SITE RESPONSIBILITY

Issue:        Has  the  owner  of this site paid anything to.clean  up  this site?

Discussion:   The   potential  responsible  parties   (PRP)  are  contacted  to
             determine  their financial capability and liability as part of the
             Superfund  program.

-------
            CWoodland
  March 11, 1985
  Mr. Christopher J. Daggett, Reg. Administrator
  U. S. Environmental Protection Agency
  Region 11
  26 Federal Plaza
  New York, NY 10278

  RE:  D'Imperio Property Hazardous Waste Site

  Dear Mr. Daggett:

  I attended the public information hearing regarding  the  D'Imperio Property
  hazardous waste site in Mays Landing, N.J.  on March  6, 1985.   I appreciated
  the opportunity to listen to your agency's  proposals as  well as to state my
  views and have my questions answered.

  As President of the Woodlands Condominium Homeowners,  I  represent over 650
  homeowners.  By this time next year,  or sooner,  there  will be  approximately
  750 homeowners at the Wopdlands.  After hearing  the  presentation, listening
  to others'comments and opinions and having  my own  questions answered, I am
  absolutely convinced that establishing an onsite landfill  is NOT  in the best
  interests of the environment or of the many, many  residents in the surrounding
  area.  I am opposed to alternatives LA and  IB.    I am  also opposed to any form
  of incineration should a "mobile incinerator" become available at a later date,
  as mentioned in your agency's report, pages 2-19 through 2-21.

  I favor Alternative 2B, Groundwater treatment and  offsite  discharge with a
  cap and offsite landfill.  This would include excavation of 3,900 cubic yards
  of hazard waste (as well as all drums and containers), capping of 1.5 acres
  of contaminated soil remaining after  excavation,  and withdrawal of contaminated
Woodlands Club  House  •  Associdfun Management  OH.re  • Mays Landing.  NJ 08330 •  1609) 641-8699

-------
Page -2-
Mr. Christopher J. Daggett
March 11, 1985
groundwater treatment by air stripping.  It is my opinion that Alternative 2B
offers the most efficient, safe, and cost effective solution.  I urge you to
select this alternative and move into action as soon as is practicable.

Thank you,
Sincerely,
                      /x
Georg"¥ S. R. Gross, Jr.
Assoc. Pres.

GSRG/dpb

cc:  William Gormley, State Senator
     Robert Hughey, Commissioner, N.J. Dept. Environmental Protection
     William J. Hughes, Congressman
     John Frisco, Chief,  N.J. Remedial Action Branch
     John H. Rosenberger, Esq.
     Woodlands Condominium Association Board Members

-------
V)
              The   Pinelands  Commission
               P.O. Box 7,  New Lisbon, N. J. 08064  (609)894-9342
                                March 13, 1985
Mr. Donald Lynch,  P.E.,  Project Manager
Southern New Jersey Remedial Action Section
New Jersey Remedial Action Branch
U.S. Environmental Protection  Agency
Region II
2b Federal Plaza
New York, New York  10278
                                 Re:  D'Imperio Property
                                       Superfund Site
Dear Mr. Lynch:
Thank you for providing us  with  a  copy of  "Feasibility Study
of Alternatives - D'Imperio Property  Site, Township of Hamilton,
Atlantic County, New Jersey."

There are a number of items in the Pinelands Comprehensive
Management Plan (CMP)  which affect the list of alternatives
and which we would like to  bring to your attention.  Section 6-
304 of the CMP prohibits the direct discharge of wastewater into
any surface body of water;  Section 6-705 permits new landfills
only if a stringent set of  conditions is met and only if the land-
fill is phased out by 1990; and, Sections  6-706 and 6-807 of the
CMP prohibit the disposal of hazardous or  toxic wastes in the Pine-
lands .         \

Given these circumstances it would appear  that the only feasible
option is Alternative 2A.  It  should  also  be noted that any of the
clean-up activities on the  site  will  require an application to the
Pinelands Commission.

If you have any questions concerning  this  response, please feel
free to contact me.
                                 Sincerely,
                                  jrrence  D. Moc-re
                                 Executive Director

TDM/scb
cc: Michael F. Catania,  Director,
      Office of Regulatory Services
      N.J. DEP
     8r. Jorge Berkowitz - N.J.  DEP
     s. Joan Andersoji -v CLerk^.- Hauu.j.j-un j.ww*.  ,  _
                                           ianal  D«<*r

-------
                                                                       DRAFT
                    ENVIRONMENTAL ASSESSMENT FOR THE
                           D1MPERIO PROPERTY SITE
                  SURFACE DISCHARGE OF TREATED EFFLUENT
             TO ADAMS BRANCH AND SURROUNDING WETLAND AREA
1.0  INTRODUCTION
                     >

This environmental  assessment of  the  D'lmperio Property  Site addresses  the
potential effects associated with the surface  discharge of treated groundwater to
Adams  Branch  and  the  surrounding wetland  area.   The following  sections  will
evaluate the various impacts associated with the proposed discharge of a maximum
treatment  plant effluent of 400 gallons per minute (gpm).  The effects of such  a
discharge   were  assessed  as  to  the  potential  toxicological,  ecological,   and
hydrological impacts of such an action.

One proposed remedial measure for the D'lmperio Property Site is  the recovery  and
treatment   of  contaminated   groundwater  identified   beneath  the   site.     The
alternative  proposed  for site  remediation involves  the  construction of  a  recovery
well system  to extract  approximately 350 gallons per  minute  (gpm) from   two
contaminated groundwater plumes  (the  upper and lower  aquifers).   The water
obtained will be treated on site and then be discharged off site into a tributary of
Babcock .Creek known as Adams Branch.

Figure  1 shows  the site and the location of the proposed  drainageway.  The outfall
to Adams  Branch. whitfh discharges into the wetland designated as  Babcock Swamp,
is also shown.             *

Two options are proposed for the treatment of  the groundwater.  These two options
are designed to meet  different objectives, which will  be discussed in  depth  in  a
later section.   The  basic  difference,  however, involves the  use of one treatment
system (option 1) that  will   be designed  to  remove  contaminants  to  below
New Jersey State unofficial  drinking  water criteria with  the exception of Methyl
Ethyl Ketone (MEK), or another (option 2) which  will be designed to  remove MED
                                                             *
to below the New Jersey State drinking water limit.
                                      1

-------
N>
                 ;   * -BABCOCK    - ;
                                "
                                  UNNAMED
                                  WETLAND
      BASE MAP IS A PORTION OF THE U.SO.S. MAYS LANDING, NJ QUADRANGLE (76 MINUTE SERIES,S55. PHOTOREVISED 1972). CONTOUR INTERVAL»IO'.
                                                                                              FIGURE  I
                                      SITE LOCATION MAP
                           D'IMPERIO SITE.  HAMILTON TOWNSHIP. NJ
                                          SCALE: |"=2000*
  IMUS
  CCRFORAT1DN
A Halliburton Company

-------
                                                                         DRAFT
Each  of the treatment options consists  of a two-phase treatment system.  Phase
one, which is common to both options is the inorganics treatment phase.  Suspended
solids and inorganic  contaminants will  be  removed by precipitation  and settling.
Phase two, organics removal,  will  be accomplished by one  of two processes.  The
first option is designed to remove the volatile  organic compounds with the  use  of
an  air stripping  unit.   Option  two will remove the volatile  organics and MEK  with
the use of a steam  stripping unit.

The effluent  from either  of these treatment steps will  be  directed into a gravity
flow drainageway, which will  discharge into Adams  Branch., This drainageway will
                                 h                         •
be  approximately  3,000 feet  long and will carry the  treated  water under  Black
Horse Pike.

The two treatment  system options proposed for groundwater treatment will result
in   different effluent  quality  levels.    Option  one,  the  air  stripping  option,  was
designed  so  that the effluent meet  New Jersey State  drinking water criteria  with
the exception  of  MEK. This criteria  provides that volatile organic contaminants be
removed  to  an  effluent  concentration  of  50  ug/l  of  any  one  contaminant  and
100ug/l of total  volatile organics.   Option  two was designed  to  meet this same
criteria but, in addition, includes  measures for MEK removal.

An  initial  assessment  of  the  impacts  associated  with  the  discharge  of  the
treatment plant effluent to Adams Branch indicates  that no  adverse environmental
impacts should be  observed.  The increased flow is not expected  to alter wetland
areas.  In addition, treatment effluent quality  for  either option  is  not expected  to
adversely affect  benthic  aquatic  communities  or wetland  wildlife.  As such the
proposed  treatment methods  would  satisfactorly treat the groundwater and  would
not require modification to further  protect the wetland environment

2.0   AQUATIC TOXIC1TY ASSESSMENT

Table 1 lists the maximum discharge concentrations  of any  one contaminant  in
either option in  comparison to  the Ambient Water Quality  Criteria (AWQC) for the

-------
                                                                                                                                                           DRAFT-
                                                                             TABIE I

                                                       AQUATIC TOXICITY DATA FOR D1MPERIO PROPERTY SITE
   CAS
  Numlw
Contaminant (PP No.)
 76-09-2    Melhylene Chloride (44VO
 67-84-1    Acetone
 7B-3B-4    1.1-Dlchloroethene (28V)
 76-34-3    1.1-Dlchloroelhane (13)
 07-66-3    Chloroform (23V)
 107-06-2   1.2-Dlchloroelhane (10V)
 78r83-3    2-Bulenone (Methyl ethyl kelone)
 71-6S-6    1.1,1-Trlchloroethane (11V)
 78-87-6    1.2-Dlchloropropane (32V)
 78-01-6    Trlchloroelhene (87V)
 71-43-2    Benzene (4V)
 108-10-1   4-Melhyl-2-PenUnone
            (Methyl Uobutyl kelone)
 127-18-4   Teirechloroethene (85V)
 108-88-3   Toluene (86V)
 108-90-7   Chlorobenzene (7V)
 100-41-4   Ethylbenzene (38V)
            Total Xylenei
Maximum Treated
Ellluenl Discharge
  Concentration
   '  ua/1

       60
       60
       60
       60
       60
       60
      600
       60
       60
       50
       60
       60

       60
       60
       60
       60
       60
                                                                               Ambient Water
                                                                               Quality Criteria.
                                                                             Freshwater Aquatic
                                                                                    life	
Acute
 ua/l
Chronic
  Ufl/l
                                                       11.000*
                                                        NA
                                                       11.600
                                                        NA
                                                       28.800
                                                      118.000
                                                        NA
                                                       18.000
                                                        NA
                                                       46.000
                                                        6.300
                                                        NA

                                                        6.280
                                                       17.600
                                                          260
                                                       32.000
                                                        NA
                   NA
                   NA
                   NA
                   1.240
                 20.000
                   NA
                   NA
                   NA
                 21.900
                   NA
                   NA

                    840
                   NA
                      60"
                   NA
                   NA
                                                                                                  Ambient Water
                                                                                                  Quality Criteria.
                                                                                                Saltwater Aquatic
                                                                                                	  Life
Acute
 un/l
                   12.000*
                  224.000
                    NA
                    NA
                    NA
                  113.000
                    NA
                   31.200
                    NA
                    2.000
                    6.100
                    NA

                   10.200
                    6.300
                      160
                      430
                    NA
Chronic
  UB/I
 6.400*
  NA
  NA
  NA
  NA
  NA
  NA
  NA
  NA
  NA
   700
  NA

   460
 6.000
   129
  NA
  NA
 Aquatic Toxlclty
     Rating
     TIM 96
	mo/I	
                                    1000-100
                                    NA
                                   Over 1000

                                   100-10


                                   Over 1000
                                                                                                                                100-10
» 'Ambient Water Quality Criteria lor llalomethanea
 **FI»h spades exposed for 76 days.   -
 NA - Data not available

-------
                                                                          DRAFT
protection  of freshwater  aquatic  life and  saltwater aquatic life  (USEPA, 1980).
Acute (short-terni exposure) and chronic (long-term exposure) criteria are provided
for volatile  organic  contaminants in Table 1.   Maximum discharge concentrations
are not  listed  for the inorganic  contaminants  since  they  were  not identified  as
"critical" contaminants.  'Inorganics  treatment was included  in  the  design as  a
provisional measure  for a worst case groundwater contamination.

In the absence  of an Ambient Water Quality  Criteria, the Aquatic Toxicity  Rating,
TLMgg  (concentration that will kill  50 percent  of  the exposed   organisms within
96 hours), is provided in Table 1 (Sax, 1984). A range of concentrations is provided
                                                           *
to reflect the variety of different organisms and test conditions used to  determine
the  TLMgg.   The  TLMgg values  give  a  relative  indication of  acute  toxicity.
Additional acute aquatic toxicity data  for methyl ethyl ketone is  shown in Table 2.

In comparison to the maximum  expected  concentration  of  any volatile  organic
contaminant  in  the  effluent,  these  data  indicate  that acute and  chronic toxic
effects to freshwater aquatic life and  saltwater  aquatic life would not be expected.

Chronic  toxic  effects   from  chlorinated  benzenes   have  been  reported  ' at
concentrations as low as 50 ug/l  for a single  species of fish exposed for 7.5 days
(USEPA,  1980).   However, chlorobenzene  was found in  only  two  groundwater
samples (monitoring well sample MW-03 at a concentration of 110 ug/l, 20 percent
dilution only, and residential well sample PW-01 at  a concentration  of 5.3 ug/l).  It
is expected that  the thlorobenzene concentration in the treated  effluent  discharge
will be  significantly  less than  50 ug/l-  Chronic  toxic effects to aquatic life  due to
chlorobenzene would not be expected.

Chronic  toxicity  criteria  or  data  are  not   available  for  some  contaminants.
However, because the contaminants would  in  all probability, mix with the  stream
water and be diluted, chronic toxic effects would be  unlikely.

-------
                                                          TABLE 2

                                      AQUATIC TOXICITY DATA - METHYL ETHYL KETONE<3)
                                                  O'IMPERIO PROPERTY SITE
                                                                                                               DRAFT
o>
Concentration
mo/I
5640
5640
5600
5640
1950
Exposure
(Hours)
24
48
24, 48. and 96
96
24
Species
Sunfish
Sunfish
Mosquito Fish
Sunfish
Brine Shrimp**
Toxic
Effect*
TLM
TLM
TLM
TLM
TLM
Test
Environment
Phila. Tap
Water 20 °C
Phila. Tap
Water 20°C
Turbid
—
Static
Reference
CWQPAV 0001
CWQPAV 0001
CWQPAV 0001
A1 0001
JWPFA5 0024
        *    TLM - Concentration that will kill 50 percent of the organisms exposed.
        **    Saltwater organism

-------
                                                                        DRAFT
These estimates do not address sensitive species, synergestic effects,  or additional
environmental  stresses  to  aquatic  life  resulting  from  temperature  changes,
increased flow rates, total dissolved solids, biological oxygen demand, and so forth.

Normally, the  presence of  volatile  organic  constituents  at the  concentrations
expected  in  the  effluent from  the  proposed treatment  plant will  not have  any
noticeable  effects  on  the  variability  and  numbers  of  biota  in the  ecological
community.

3.0   ECOLOGICAL EVALUATION

A limited ecological examination of Adams Branch was conducted between Cologne
Avenue and the stream's confluence with Babcock Creek.  This reach  of stream  is
approximately 2 miles in  length and drains into the area surrounding  Babcock Creek
and known as Babcock Swamp,  as  shown on Figure 1. The entire area is designated
as a wetland; however, Adams Branch was dredged in 1980, and this action resulted
in  lowering  the local  water table.   The area surrounding  Adams  Branch has since
become gradational between swampland and upland.

An  initial  reconnassiance  of  the area revealed  that  Adams Branch  was  well
channelized  as a  result  of  the  dredging  operation.  This  action  has severely
disrupted the original streambed.  The excavation of this channel has also affected
the riparian area  (land adjacent to the stream)  for an  average  of 30 feet  from
either bank.  Dredge  spoils from the excavation  of the streambed were deposited
within this riparian area.  The fact that grasses were the only vegetation growing
on the spoils confirmed that dredging was a  recent event.

The channelized stream bed has a width ranging from 8 to  12 feet along its entire
length, including the steep, almost vertical side slopes.  Average water depth along
this  reach  was approximately  10  inches.  The channel depth  increased uniformly
from  3 feet  at  Cologne Avenue  to  approximately 6 feet  at  the Babcock  Creek
confluence.

-------
                                                                         DRAFT
Stream  flow  measurements  were  conducted  for  Adams  Branch  near Cologne
Avenue, the  planned location of the treatment plant outfall.  The velocity of the
stream at this point was approximately 0.2 feet per second (fps), which is a flow of
about 375 gallons per minute (gpm).  The dredging operation has completely altered
and natural  stream conditions below this point.  The  stream is now a channelized
pool with  occasional fast water  (riffle) areas  spanning  slight  changes in stream  bed
elevation.

The stream substrate now consists  of small diameter (1-2 inches), white gravel with
a  finely  graded  sand  intermixed.   Inspection   of  the  substrate indicated  that
                                                         V
favorable  conditions  exist  for  bethic  community  growth;   however,  none  were
clearly visible.  The dredging  activity has apparently interrupted  the growth of the
natural benthic macroinvertebrate community in Adams Branch.

A  small  variety  of  aquatic  macroinvertebrates  was observed  during  the   site
reconnaissance.  Leeches were found in the branches of a fallen  tree submerged in
the stream.  Water  striders were present on the water's surface the entire length of
the stream, while water boatmen were present only in the pooled areas.

Changes in the fish population have also occurred as a result of  the dredging.   The
only fish  observed  were sculpin,  and  these were  inhabiting only an  undredged
tributory of Adams  Branch.  No fish  were observed in Adams  Branch.

The recovery of Adaras Branch to a point where aquatic life  is firmly established is
expected to  take a numbet of  years.   Downstream invertebrate  drift, along  with
airborne deposition of eggs, will enhance recovery of  streambed life.  The physical
changes  to  the   stream,  however,  will  persist, while the aquatic  community
structure shifts to organisms which  favor this type of habitat.

The  projected addition  of  400 gpm  of treated  water,  a  volume  which  effectively
doubles the flow observed  during the survey, would  be noticeable near the  point of

-------
                                                                       DRAFT
discharge.   However, the additional flow  is  not  expected to affect  the  current
streambed  conditions.  The additional flow should not retard the recovery of Adam
Branch.  By the time this flow  reaches  Babcock Creek and  Babcock Swamp, the
impact  of  the  addition  of  400 gpm upstream cannot be  adequately  determined,
although the size of Babcock Creek is such (in excess of 4 times the present flow of
Adams Branch) that any effect would be minimal.

Although the ecological community was  not  examined in  detail, the study area  is
likely  to contain  a wide variety  of wildlife species.   Deer tracks were found  in
numerous areas along  the length of Adams Branch.  Numerous bird species were
also observed in this area.  Of particular note was the observation of a Great Blue
Heron  in this area. This Heron  has been identified as a  sensitive species by the
Pinelands commission.

Considering the  influences  of  dredging  Adams  Branch,  natural fluctuations  in
stream  flow, climate variations, and the  large  volume of  water in Babcock Creek
and Swamp, current assessment techniques would be expected to show little if any
significant  variation  in  the  ecological  community structure  within  the  Adams
Branch area.  Any  differences observed would probably be assigned  to the natural
variability of the system.

4.0   HYDROLOGIC IMPACT ASSESSMENT

The wetland  of concern in this assessment covers a region including  Babcock
                   v
Swamp and the area in between the  Black Horse  Pike and  Route 40.   Babcock
                         \
Creek is the main  stream flowing through this region. The extent of the wetland
covered by the  water impoundments depends  on the flow of Babcock  Creek and the
water  table elevation.   Babcock Creek has three more tributaries, i.e., Man  Killer
Branch,  Jack Pudding  Branch,  and Adams  Branch.   Until  Adams  Branch  was
dredged, the other two tributaries had much better  defined channels in comparison
to Adams Branch.

-------
                                                                         DRAFT
Soil  properties in this area are highly  variable.  However,  they  are  primarily  sand
and  sandy  loams.   Thus,  this  area  has  high  precipitation  infiltration  rate  and
subsurface water movement capability.  The vegetation growth in this wetland area
is  prosperous.  Tall trees and  branches  are  interwoven.  Surface  of the woodland is
covered with tree leaves  and other organic litters.  In addition,  the  surface of the
land is  relatively flat  Because  of the high infiltration capability, flat topography,
and  good surface protection,  the soil erosion  rate caused  by  the overland flow is
presumably  low.

As  mentioned earlier, Adams  Branch has been dredged to  lower the water table.
The  newlydredged  channel  is geometrically well-defined.   Average  width  of the
channel is from  8 feet to  15 feet, and the depth  measured  from  the  bottom to the
bank ranges from 3.5 feet to 6 feet.  The  sinuosity of the  channel  is low.   Thus,
generally speaking, the Adams  Branch  Channel  is relatively straight and uniform.
The  flow  at about  100 feet  downstream  of  the bridge at Cologne Avenue was
measured to be 377 gpm  on March  12, 1985.   This flow was observed to  gradually
increase with increasing  distance  downstream because  of the   distributed  inflow
along the channel caused  by the subsurface seepage at the bank. In  addition, there
are several  upland  gullies draining  surface  water and  shallow  groundwater toward
the channel. Therefore, the  magnitude of the distributed inflow is expected  to be
greater  during the spring runoff and the high precipitation seasons.

Based  on the measurement  of  the channel  cross-section  at distances  of  about
20 feet,  100 feet,  and  3,200 feet below  the  Cologne Avenue  Bridge,  the  power
                     \
function relationships between  the depth  and  the  area  for  those  three  cross-
                           \
sections were individually  determined to be  as follows:
                                       10

-------
                                                                         DRAFT
      A -3.4701-56         @ 20 ft
      A « 6.96D1-15         <§ 100 ft
      A » 5.52D1-34         @ 3200 ft

Where:

      A is the cross-sectional  area in feet2
      0 is the maximum depth in feet

It  is  noteworthy that  the  channel  geometry  is  relatively  uniform  with  the
coefficients  ranging  from 3.47 to 6.96  and the power from 1.15 to 1.56.  Similar
relationships between  the  water depth  and  the wetted perimeter  were  also
determined.    Since  the  flow observed  in  the  channel  was relatively  uniform,
Manning's formula was  used to  calculate the depth  of  the flow under various
potential discharges.  If the treated  groundwater of 400 gpm is discharged directly
into  Adams  Branch   under the  current  conditions  (i.e.,  flow  of  377 gpm),  the
calculated water  depth  under  the  combined flow  will  be 1.1 feet which is 0.3 feet
above the current flow  surface.  The current flow condition does not represent the
high flow  season of the year.  However,  assuming  maximum flow to  be 950 gpm,
the water surface will be elevated to 1.5 feet, which is 0.7 feet  above the current
condition.   Mannings "n" value was  selected to be 0.045 to represent the dredged
channel. The bed slope was calibrated using the measured flow velocity (0.2 fps) at
a distance of 100 feet below the Cologne Avenue Bridge.
                    «
                          \
Peak  discharge of the  overland flow under  a  100 year, 24-hour  rainfall was also
determined  based on  a rainfall  event  of 7.5  inches  and  the selected 550-acres
drainage basin for  Adams  Branch.   The  Soil  Conservation  Service  (SCS) Curve
Number method was used.   Because of the high variability of the  soil properties,
curve  numbers  of 70  and  77, representing  the hydrologic  soil classification  of
types C and 0  and the woodland with  good cover, were selected.  The calculated
                                      11

-------
                                                                        DRAFT
peak discharges were 93 cubic feet per second (cfs) and  121 cfs corresponding to
soil types C .and 0.  These values are high compared with  other river basins in New
Jersey because the selected  soil types C and 0 have lower infiltration capacity.

Flow in Adams Branch is shallow (maximum depth from 5 to 12 inches).  However,
the flow velocity was  measured  to be  only 0.1 to 0.2 fps  at the 100 feet  cross-
section because  of the  flatness of the  channel bed.   Therefore,  the  oxygen
reaeration rate was not high.  This assumption was based on the water color  and
the growth of the aquatic organisms in the channel.  The increased flow resulting
from  the 400 gpm  discharge  is  not  expected  to increase  the reaeration rate
significantly because  of  the  flatness  of the  channel.   Moreover, scouring  of  the
channel will not be greatly  increased when compared to  the  suspended sediment
released from overland flows and the inputs from the other tributaries.

The areas surrounding Adams Branch have no impounded water even though  the
degree of saturation of the soil is high.  There are however,  a significant amount of
standing water  around  the  confluence of  Adams  Branch and Babcock  Creek.
Obviously, flow from  Babcock Creek is much higher than that of Adams Branch.
The large drainage basin of  Babcock Creek and the inflows from  Man Killer  Branch
and  Jack Pudding  Branch  indicate  that the  discharge  from  Adams  Branch is
relatively small in comparison to Babcock Creek.   This conclusion is supported by
the observation of large  channel width and flow  rate observed downstream at  the
Black Horse Pike Bridge over Babcock Creek.

The average evaluation of the area close to Black Horse Pike and the region and in
between Route 40 and  Black  Horse  Pike is about 30 feet,  mean sea level  (msl),
which  is the lowest portion of the entire Babcock  Creek drainage basin. Because of
the topography and  the  soil properties of these areas, the characteristics  of  the
wetland  are, therefore,  more  prominent at  the  downstream  portion  below  the
confluence of Babcock Creek and Adams Branch.

In summary, the increase of the water elevation in Adams  Branch  due  to  the
addition  of 400 gpm discharge was  determined  based  on the current and  the
                                      12

-------
                                                                        DRAFT
presumed high flow conditions.  The additional discharge will not induce any flood
over the  bank.   Also,  there  will not  be any  significant change  in the current
dissolved  oxygen and  suspended  sediment condition  in the Adams  Branch.  The
impact cause by the additional discharge at the downstream portion of the Babcock
Creek will also be insignificant because of the comparatively  high flow inputs from
the Man Killer Branch, Jack Pudding Branch,  and the headwater drainage basin  of
the Babcock Creek.
                                      13

-------
                                                                        DRAFT
                                  REFERENCES

1.    United  States Environmental Protection Agency,  November 28,  1980.  "Water
      Quality Criteria Documents; Availability".  45 Federal Register FR 793.18

2.    Sax,  N.  Irving,  1984.    Dangerous   Properties  of  Industrial   Materials.
      6th edition.  Van Nostrand Reinhold Company.

3.    Oil and Hazardous Wastes Technical Assistance  Program, Oil and  Hazardous
      Waste Technical Assistance Data System. 1985.
                                       14

-------