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
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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.
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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.
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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
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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.
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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.
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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.
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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
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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.
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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.
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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.
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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.
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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
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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
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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
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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.
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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.
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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
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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
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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.
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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.
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