United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R02-89/091
September 1989
SEPA
Superfund
Record of Decision
Pepe Field, NJ
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT HO.
EPA/ROD/R02-89/091
X Rodplonf* AcMMion No.
4. Ho* and Subtftto
SUPERFUND RECORD OF DECISION
• Pepe Field, NJ
^ First Remedial Action - Final
B. Audi
I a PKrfi
S. R*portDit»
09/29/89
Author!*)
8. Performing Organization Ropt No.
9. Performing Organization Nun* ind AddiMc
10. PretKVTMk/WofklMINo.
11. Contr»ct(C) or Gr«nt(G) No.
(C)
(G)
12. Sponsoring Organization Nun* and Addnra*
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. Typo of Report A Ptriod Covered
800/000
14.
15. Supplementary NOIM
II
16. Abetract(Umrt:200worde)
The Pepe Field site is a former disposal area in the town of Boonton, Morris County,
New Jersey. The 3-acre site is an inactive, municipally owned recreational facility in
a predominantly residential area. From 1935 to 1950 the E.F. Drew Company used the site
to dispose of wastes generated from processing vegetable oils and soap products.
Materials reportedly deposited onsite by the E.F. Drew Company were diatomaceous earth
and activated carbon filter residue; incinerator and boiler ash; boiler ash; lime
!ludge; and soap residue. Residents living adjacent to the site complained about
bjectionable odors originating from the site. To reduce odor emissions, the town
mplemented elements of the odor abatement program proposed by the Drew Company. During
the 1960s the town covered the site with soil and installed a leachate collection and
treatment system. Although these measures reduced the the odor problems, some incidents
were still reported. Investigations revealed gas concentrations exceeding the lower
explosive limit in the soil vapor at the perimeter of the site and in an apparent soil
gas plume extending below the property adjacent to the site. The primary contaminants
of concern affecting the soil found in the landfill include hydrogen sulfide and methane
gases. (Continued on next page)
NJ
17. Document AneJyele a, Deecriptora
Record of Decision - Pepe Field,
First Remedial Action - Final
Contaminated Medium: soil
Key Contaminants: hydrogen sulfide gas,
b. Identlflera/OpeivEndad Term*
methane gas
i
e. COSAT1 Hold/Group
ia AvaUabUty Ttatemenl
1ft. Security Ctae»(Thla Report)
None
None
21. NaofPtgo*
44
22. Prtot
(SwANSU3t.1l)
Or MUNAL rOHM 272 (4-77)
(FormMty NTIS-35)
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EPA/ROD/R02-89/091
Pepe Field, NJ
16. Abstract (Continued)
The selected remedial action for this site includes maintaining the site cover;
installing and maintaining a landfill gas collection and treatment system using carbon
adsorption; disposing of carbon offsite; upgrading and maintaining the existing leachate
collection and treatment system; ground water monitoring; and implementing deed „
restrictions to prevent waste disruption. The estimated present worth cost for this
remedial action is $1,293,700, which includes an estimated O&M cost of $108,000 for the
first two years and $93,000 for the next 28 years.
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DECLARATION STATEMENT
RECORD OF DECISION
Pepe Field
SITE NAME AND LOCATION
Pepe Field
Boonton, Morris County, New Jersey
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the Pepe Field site, chosen in accordance with the requirements of
the Comprehensive Environmental Response, Compensation, and Liability
Act of 1980, as amended by the Superfund Amendments and
Reauthorization Act of 19"86 and, to the extent applicable,
the National Oil and Hazardous Substances Pollution Contingency
Plan. This decision document explains the factual and.legal
basis for selecting the remedy for this site.
The State of New Jersey concurs with the selected remedy. The
information supporting this remedial action decision is contained
in the administrative record for the site.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response actions
selected in this Record of Decision, may present an imminent and
substantial endangerment to public health, welfare, or the
environment.
DESCRIPTION OF THE SELECTED REMEDY
The remedy presented in this document represents all planned
activities for the site. Prior actions by the Town of Boonton
included the installation of a landfill cover, surface water
controls, and a leachate collection and treatment system. The
selected remedy, together with these prior actions, will properly
close the site and satisfy State of New Jersey requirements for such
facilities.
The major components of the selected remedy include the following:
- installation and maintenance of a landfill gas collection and
treatment system;
- upgrading and maintenance of the leachate collection and
treatment system;
- maintenance of the site cover;
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-2-
- implementation of a ground water monitoring program; and
- establishment of deed restrictions to prevent waste disruption
DECLARATION OF STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that are
legally applicable or relevant and appropriate to the remedial
action, and is cost-effective. The remedy utilizes permanent
solutions and alternative treatment (or resource recovery)
technologies to the maximum extent practicable for this site.
However, because treatment of the principal threats of t ie site
was 'not found to be practicable or justified, this remedy does not
satisfy the statutory preference for treatment as a principal
element.
Because this remedy will result in potentially hazardous
substances remaining on the site above health-based levels, a
review will be conducted within five years after commencement of the
remedial action to ensure that the remedy continues to provide
adequate protection of human health and the environment.
William J/Mu^zy/rf^i, P.E. Date
Acting Regional Administrator
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DECISION SUMMARY
PEPE FIELD
Boonton, New Jersey
SITE DESCRIPTION
The Pepe Field site is located in the Town of Boonton, Morris County,
New Jersey (Figure 1). The Town of Boonton is an urbanized area with
a 1980 census population of 8,620. Boonton Township is located less
than one-half mile north of Pepe Field; this rural township had a
population of 3,273 in 1980. The site is situated west of County
Route 511 (Boonton Avenue), and is bordered by Wootton Street and
Hillside Avenue. It covers an area of approximately three acres.
The site is situated in a residential area and is currently an
inactive recreational facility owned by the Town of Boonton. The
facility includes tennis courts, a baseball field, a playground and a
refreshment stand (Figure 2).
The Pepe Field site is a former disposal site which was used for the
disposal of wastes generated from the processing of vegetable oils
and soap products. The cover fill at the disposal site is typically
a mixture of brown, fine to medium sand intermixed with a fine
granular ash material with small amounts of slag. The thickness of
the cover fill ranges from two to seven feet with an average
thickness of approximately three feet.
A treatment system is operated by the Town of Boonton to reduce
odors. A 14-foot deep gravel curtain drain extends along the
southwestern end of the site for 150 feet. The drain intercepts
shallow ground water and leachate from the site and diverts it to a
sump in a pumphouse located at the eastern end of Hillside Avenue.
A solution of fifty percent hydrogen peroxide is injected into the
sump pump discharge manhole. This treated effluent is then
discharged intermittently to the storm sewer on Hillside Avenue.
The site topography is gently sloping to the south-southwest, with a
relief of approximately 15 feet. Presently, no surface water exists
on-site. As explained above, treated leachate is discharged from the
leachate pumphouse to a storm sewer. Surface site drainage is also
discharged into the storm sewer system. The storm sewers drain into
the Rockaway River about 3,000 feet from Pepe Field.
There are no potable wells in the immediate area or hydraulically
downgradient of the site. The Rockaway River, which receives both
storm water runoff and ground water discharge from the area, is used
as a drinking water supply by Jersey City, New Jersey.
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Concession
Building
House
Site Layout
Ptpe Field
Boonton Town, NJ
Source: Rogers, Golden & Halpern, 1903
Not to Seal
FIGURE 2
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SITE HISTORY AND ENFORCEMENT ACTIVITIES
Until the early 1930s, the area known as Pepe Field was a marsh
containing several small streams which discharged to a nearby lake.
The site was bounded to the north by Wootton Avenue which was
essentially at its current elevation. At that time, the site was
owned by the Gustav Bentley family of Boonton; many early records of
the site refer to it as Bentley's Field. Beginning around 1935, and
continuing until about 1950, the E.F. Drew Company (Drew Company)
used the area for the disposal of wastes from its plant in Boonton,
New Jersey. These wastes were generated in the course of processing
edible vegetable oils and soap products. During the time that the
site was used for waste disposal, Mr. Bentley was an employee of the
Drew Company. According to an affidavit provided by Daniel Padavano,
an employee of the Drew Company from 1929 to 1964, the only materials
deposited on the site by Drew were diatomaceous earth and activated
carbon filter residue from edible oil processing and purification;
incinerator ash from the burning of wood and paper; boiler ash; lime
sludge from the treatment of wastewater from oil processing; salt
residue from glycerin processing; and soap residue from the
manufacture of cleansing and soap products for household and
industrial use. Although Mr. Padavano acknowledged that nickel
catalysts were used at the plant, he denied that those materials were
disposed of at Pepe Field.
Mr. Padavano was responsible for transporting wastes to Pepe Field
and used his personal vehicles for waste transport. Waste material
was reported to have been deposited several times a week and covered
with a sand and gravel mixture obtained from a gravel operation
located in Montville, New Jersey. The quantity of wastes which the
Drew Company disposed of at the site is not known.
In 1947, the Boonton Board of Health requested that the Drew Company
cease waste disposal at the site by June 30, 1947. The Boonton Board
of Health also requested that the waste be covered in 1948. This was
not done and the site remained an open, unused area until the
mid-1960s.
During the time that the Drew Company used the site for waste
disposal, complaints were registered by residents living adjacent to
Pepe Field about objectionable odors originating from the site. In
1949, the Town of Boonton responded to the complaints and conducted
sampling of the wastes at Pepe Field to determine the source of the
odor. Hydrogen sulfide was detected in liquid waste samples. In
March 1951, the Drew Company proposed an odor abatement program which
included placement of a cover over the site, construction of a
leachate collection trench around the exposed portion of the waste,
and construction of a concrete pit for chemical treatment of the
leachate. Although this proposal was reviewed and approved by a
consulting firm retained by the Town of Boonton, the Drew Company did
not implement the plan.
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In 1965, the Town of Boonton retained Industrial Hygiene Services to
conduct air sampling and to evaluate potential health hazards due to
hydrogen sulfide generated by the site. Detectable levels of
hydrogen sulfide (1 part per million (ppm)) and mercaptans (4 ppm)
were found only beneath a grate in the drainage system for the site.
The levels found did not, in the opinion of Industrial Hygiene
Services, pose any health hazard.
During the 1960s, the Town of Boonton implemented the elements of the
odor abatement program proposed, but not carried out, by the Drew
Company. In the early 1960s, the site was covered with up to 10 feet
of soil in preparation for use for athletic activities. In 1969, the
present leachate collection and treatment system was installed.
These measures reduced the frequency and severity of odor problems,
however, some incidents were still reported.
In 1965, the Town of Boonton began negotiations, with Mr. Bentley for
the purchase of the site- for use as a recreational facility. The
site had been used on an informal basis by local children for many
years. In 1970, the Town concluded the purchase of the property and
began developing it for more formal use, including Little League
baseball. The site remained in use until 1984, at which time the
Town of Boonton closed the facility in anticipation of the beginning
of the remedial investigation to be conducted in accordance with the
requirements of the Comprehensive Environmental Response, Compen-
sation, and Liability Act of 1980 (CERCLA). A four-foot high chain
link fence, installed by the Town, currently surrounds the field.
In May 1979, samples were taken of the leachate and from the storm
sewer by the New Jersey Department of Environmental Protection
(NJDEP). Results showed that the concentrations of organic compounds
were below detection levels and that concentrations of metals were
low. In November 1981, NJDEP resampled the leachate. This time,
compounds detected included alpha-BHC (23.2 parts per billion (ppb)),
bis(2-ethylhexyl) phthalate (37.7 ppb), and trace metals. Based on
these results, Pepe Field was proposed for inclusion on the National
Priorities List (NPL).
A Cooperative Agreement between the NJDEP and the United States
Environmental Protection Agency (EPA) to perform a remedial
investigation and feasibility study (RI/FS) was finalized in October
1984 and the RI/FS was initiated in the fall of 1985.
In 1983, NJDEP ordered the Drew Company to install ground water
monitoring wells around the site in accordance with the New Jersey
Pollutant Discharge Elimination System (NJPDES) program. This was
held in abeyance pending the outcome of the RI/FS. The Town of
Boonton has instituted court action against the Drew Company for
recovery of past and future costs associated with the wastes at the
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site and is awaiting the findings of the RI/FS. EPA is currently
evaluating enforcement actions that can be taken consistent with the
findings of the RI/FS and the implementation of the selected remedy
embodied in this Record of Decision (ROD).
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The RI/FS report and the Proposed Plan for the Pepe Field site were
released to the public for comment on August 15, 1989. These two
documents were made available to the public as part of the
administrative record and at an information repository maintained at
the EPA Docket Room in Region II. They were also made available at
the Boonton-Holmes Library and at the Boonton Town Municipal
Building. The notice of availability for these two documents
appeared in the Daily Record and Star Ledger. A public comment
period on the documents and the proposed remedy was held from August
15, 1989 to September 22, 1989. In addition, a public meeting was
held on September 6, 1989. At this meeting, representatives from
NJDEP and its consultant, EA Engineering, Science, and Technology,
Inc., answered questions about problems at the site and the remedial
alternatives under consideration. A response to the comments
received during this period is included in the Responsiveness
Summary, which is part of this ROD.
SCOPE OF THE RESPONSE ACTION
This Record of Decision addresses all planned activities for the
site. It documents the selected approaches for preventing direct
contact with site wastes, for preventing migration of landfill gases,
for collecting and treating leachate, and for monitoring ground water
quality. The selected remedy augments the measures already taken by
the Town of Boonton in covering the site and building a partial
leachate collection system. There is currently no ground water
problem associated with this site, nor is one expected in the future;
however, ground water monitoring will ensure that this evaluation is
correct.
SUMMARY OF SITE CHARACTERISTICS
A Phase I remedial investigation was performed from 1985 to 1986, to
determine the nature and extent of contamination at, and emanating
from, the Pepe Field site and to evaluate its significance. This was
accomplished through the following techniques:
Geophysical Surveys, including electromagnetic terrain
conductivity profiling, resistivity sounding, and a
magnetometer survey.
Test Borings to determine the waste distribution and
hydrogeologic profile, and to obtain samples to chemically
characterize soil and fill materials at the site.
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Monitoring Well Installation and Sampling to assess ground
water quality and the potential for off-site migration.
Surface Water Sampling to chemically characterize leachate
and to determine the impact of the storm water outfall from
the site on the Rockaway River.
Air and Soil Vapor Sampling to better define the potential
for air transport of contaminants and to further characterize
air contaminants.
The geophysical surveys were conducted primarily to guide the
placement of test borings and ground water monitoring wells. The
areas of apparent anomalies coincided closely with available
information about the locations used for waste disposal. These were
the areas where the test borings and the on-site monitoring wells
were located. The remaining areas of investigation are described
below.
In general, the results of sampling the various media showed several
parameters above local background concentrations, but at levels which
were below established limits or values which would be expected to
cause health effects. Because the reliability of the analytical
results were considered to be critical in making judgments about the
site, a Phase II remedial investigation was initiated in February
1988. The results of both phases are discussed together on a media-
specific basis. More extensive and detailed information can be found
in the Phase I and Phase II remedial investigation reports.
Test Borings
The subsurface materials encountered during the test boring program
are divided into cover fill, waste material, or underlying soil. The
cover fill at the disposal site is typically a mixture of brown, fine
to medium sand, intermixed with a fine, granular ash material with
small amounts of slag. The thickness of the cover fill ranges from
two to seven feet, with an average thickness of three feet.
The waste material appears as a black-to-dark-gray oily ash substance
with a tar-like consistency. Small white nodules of diatomaceous
earth are randomly interspersed in the black matrix. Unsaturated
samples of waste resemble oily fly ash and exhibit a moderate
hydrogen sulfide odor. Saturated samples are viscous and tarry, and
exude a strong hydrogen sulfide odor. The thickness of the waste
material ranges up to thirteen feet. The area! extent of the waste
material has been assessed by geophysical methods, soil vapor
analysis, and test borings. These efforts indicate that ash fill may
extend beyond the southern and western boundaries of the site,
however, significant quantities of oil-containing waste emitting
hydrogen sulfide and methane do not appear to be present off-site.
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Test borings encountered a marsh deposit beneath the waste material.
The buried marsh deposits extend beyond the southern and western
boundaries of the site and may also be a source of methane. The
marsh sediment is underlain by dark green, stiff silt and dense,
silty, very fine sand with infrequent lensoidal clay and sand. The
presence of this silt is estimated not to be extensive beyond the
site boundaries.
Samples from test borings were identified as either cover fill,, waste
material, or underlying soil. Chemical analytes found in
concentrations above background levels were: cover fill — organic
acids, volatile organic compounds, alcohols, ketones, polynuclear
aromatic hydrocarbons, phthalate esters, pesticides, metals, and
sulfur compounds; waste materials — organic acids, volatile organic
compounds, alcohols, aldehydes, phthalate esters, styrene, metals,
and sulfur compounds; and underlying soil — organic acids, volatile
organic compounds, ketones, phthalate esters, metals, and sulfur
compounds.
Although the analytes listed above were present in concentrations
above background levels, they were not at levels high enough to
produce health effects, except in the waste itself. There were some
samples which were composites of both cover fill and waste that
contained metals at levels which, if representative of the surface
soils, would be of concern. Therefore, surficial soil samples (0 to
6 inches in depth) were taken at fourteen locations as part of the
Phase II work. These samples were analyzed for metals. The results
were within the range of background concentration levels.
Monitoring Well Installation and Sampling
Installation of ground water monitoring wells, both on-site and
off-site, served to establish the local geology and hydrogeology as
well as provide ground water samples for evaluation. The site is
located on an apparent outwash lens approximately 30 feet thick. The
hill situated north of the site is a manifestation of an abrupt
lateral change in lithology from a moderately sorted, stratified
outwash sand and gravel deposit to a dense, very poorly sorted,
unstratified till composed of silt, sand, gravel, and boulders. The
outwash deposit is underlain by till which intersects the surface
near the northeast corner of the site and comprises the hill north of
the site. There may be a bedrock core to the hill but its depth is
not known.
There are hydrogeologic differences between the outwash and till
aquifers. The monitoring wells which are screened in the outwash
sand exhibit a higher potentiometric level than those screened in the
lower till aquifer. Pump test data, however, indicate they are at
least partly connected.
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Ground water conditions at the site which are important consid-
erations for remediation are:
The shallow silt layer is, at least locally, not
saturated.
The shallow silt serves as a local semi-confining layer,
and water perches within the waste and within the fill
south of the site.
• The silt significantly retards vertical ground water
migration.
Ground water quality directly beneath the site does not
appear to be significantly impacted by the leachate.
• The gravel curtain installed along the southern perimeter
of the site intercepts the major portion of leachate
flow.
Ground water in the shallow sand aquifer appears to
underflow the gravel curtain.
Recharge of the shallow sand aquifer is by leakage through
the upper silt layer from the perched water table and by
underflow from the till deposit to the north.
• The lower till is recharged from the till upgradient and
from leakage through the lower silt layer.
Samples of ground water obtained from downgradient wells during the
Phase I investigation were found to have elevated concentrations of
metals and organic acids in comparison to the upgradient well.
Results of analysis of samples of ground water during Phase II were
similar for metals; however, organic acids were not detected. The
concentrations of metals were below drinking water standards.
Surface Water Sampling
During both the Phase I and Phase II investigations, samples were
taken of treated and untreated leachate, and storm sewer water, at
downgradient and background locations. In addition, during the Phase
I work, samples were taken from the Rockaway River at locations
upstream and downstream from the outfall from Pepe Field.
During the Phase I investigation, both treated and untreated leachate
samples were found to have elevated levels of metals, volatile
organic compounds, phthalate esters, pesticides, and sulfur compounds
with respect to upgradient surface waters. Phase II surface water
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sampling results were the same as for Phase I except that no
pesticides were detected. The results of sampling of the Rockaway
River showed no detectable difference between the upstream and
downstream locations.
Air and Soil Vapor Sampling
Two sampling efforts were made to find high concentrations of
hydrogen sulfide in the breathing zone air during the Phase I
investigation. The first effort utilized sampling tubes with a
detection limit of one ppm. The only samples which showed detectable
levels were those taken inside the leachate pumphouse. Those samples
showed levels as high as 15 ppm. In comparison, the Occupational
Safety and Health Administration (OSHA) standard for an eight-hour
exposure is 20 ppm.
During the second sampling effort, samples were analyzed with a
portable gas chromatogra'ph with a detection limit of two ppb. Of 8.0
samples taken in the breathing zone, only 14 showed detectable
levels; for those samples, the results ranged from two to five ppb.
The only locations showing higher concentrations were the leachate
pumphouse, a crack in the tennis court pavement, and a crack in the
retaining wall near the paved play area. At these locations, the
concentrations were still below one ppm. After the second attempt at
direct measurement of hydrogen sulfide levels which could produce
health effects, it was decided to rely on calculated values based on
soil vapor results.
In contrast, levels of hydrogen sulfide, thiols (mercaptans), and
methane were easily and consistently detected in soil vapor samples
obtained from the vadose zone. Samples containing more than 60
percent methane were obtained below the infield of the baseball
field. Samples containing 50 to 60 percent methane were found at the
fence line along Wootton Street. Hydrogen sulfide was found at
similarly high levels under the infield (2,000 ppm), but the
concentration dropped off rapidly toward the edges of the site and
was found at only two to five ppm in samples of soil gas along the
perimeter.
An important part of the Phase II work was the expanded soil gas
investigation. The high methane concentrations in the soil beneath
the ball field and inside the fence along Wootton Street were
confirmed. Soil gas samples taken outside the fence, in the margin
between the sidewalk and Wootton Street, were also found to have very
high methane levels. Conversely, methane concentrations on the far
side of Wootton Street were very low or non-detectable. Soil gas
sampling along the western side of the site and at the southwestern
corner disclosed one area where methane might be migrating away from
the site. In the back yard of a residence on Pepe Way, two high
readings were found about halfway between the site and the back of
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the house. Due to soil conditions and a high water table, samples
could not be obtained either near the site or near the house. Thus,
the origin and extent of the off-site methane could not be
determined.
In April 1988, a sampling team from NJDEP performed a soil gas survey
for methane in the suspected plume area. High readings, in
concentrations of greater than 100 percent of the lower explosive
limit (LEL), were found extending from the site to a point about 18
feet from the house on Pepe Way. The concentrations then fell
rapidly to non-detectable levels at a point ten feet from the house.
The crawl spaces under the house were checked at the same time and no
detectable levels of methane or hydrogen sulfide were found. The
house on Pepe Way, and several houses along Wootton Street, were
checked during May 1989. At that time, no detectable levels of
methane or hydrogen sulfide were found in any of the dwellings.
Miscellaneous Sampling -
In July 1988, a sampling team from NJDEP took test boring samples at
Pepe Field. These samples were taken for the purpose of evaluating
the likelihood that the waste would be classified as hazardous for
disposal if a remedial action involving removal were undertaken.
These samples were intended to be biased toward the worst case.
Therefore, they were taken as close as possible to the areas from
which the four waste samples with the highest metals concentrations
were taken, as determined from the Phase I remedial investigation.
The samples were then analyzed for the purpose of determining whether
or not they would be defined as "characteristic" waste in accordance
with the regulations of the Resource Conservation and Recovery Act
(RCRA). With the exception of one sample, which exceeded the EP
Toxicity criteria for lead by a narrow margin, all samples would not
be classified as hazardous waste.
Contaminant Fate and Transport
No surface water body is directly impacted by the site. Treated and
untreated leachate are discharged to the storm sewer system, which
ultimately enters the Rockaway River. Samples of river water
obtained above and below the point of discharge showed no appreciable
difference in chemical quality. Based on the results of chemical
analyses of samples of treated and untreated leachate, the remedial
investigation concluded that dermal contact with leachate, and
inhalation of volatile organic compounds volatilizing from the storm
sewer system, are not matters of human health concern at Pepe Field.
Subsurface conditions at the site were explored to depths of up to 80
feet below grade. Bedrock was not encountered at these depths. The
overburden beneath the fill at the site is made up of a shallow
outwash sand aquifer, averaging 16 feet in thickness, underlain by a
till aquifer. Both aquifers are under semi-confined conditions as a
result of overlying silt deposits. A depositional "pinch-out" of the
11
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outwash sand and the silt layers occurs immediately north of the
site, north of which the till aquifer is unconfined. The direction
of ground water flow in the outwash sand is to the south, while that*
in the till is to the southeast. The following dissolved analyt
were found in downgradient ground water at levels above the
background concentrations: octanoic acid (18 ppb), decanoic acid
ppb), dodecanoic acid (46 ppb), barium (57 ppb), calcium (63,400
ppb), iron (8,228 ppb), lead (3.7 ppb), magnesium (31,957 ppb),
manganese (268 ppb), mercury (0.2 ppb), potassium (8,233 ppb), sodium
(44,330 ppb), zinc (245 ppb), sulfate (86,000 ppb), and sulfide (500
ppb). Based on the results of chemical analyses of samples of ground
water taken immediately upgradient and downgradient of the site, the
remedial investigation concluded that dermal contact with, and
ingestion of, ground water are not matters of human health concern at
Pepe Field.
Two soil layers of concern were identified at Pepe Field, the waste
material, which contained the greatest degree of contamination, and
the cover fill. Only the surficial layer of the cover fill was of
concern from a human health perspective based upon possible routes of
exposure. The routes under consideration were contact with soil
during athletic activities on the ballfield, soil ingestion by
children on the site, and exposure via inhalation of fugitive dust
emissions (wind erosion) from the site. Nickel and carbon disulfide
were the identified contaminants of greatest concern for the first
two routes of exposure, and nickel for the third. Air modeling was
performed in order to estimate the air concentration of nickel
resulting from wind erosion at the site.
The air investigation at Pepe Field consisted of a soil-vapor survej
and air sampling and analysis. The air investigation results
indicate that hydrogen sulfide, methanethiol, and methane generated
from biodegradation of the waste material accumulate in the vadose
zone. Discharge to the atmosphere is locally inhibited by the
presence of pavement on the site surface. However, cracks in the
pavement result in identifiable point sources of emission. Natural
venting in the unpaved areas may be enhanced by increased soil
moisture or lower barometric pressure.
Atmospheric concentration levels resulting from point sources related
to leachate (pumphouse, storm drain catch basins, and accesses to
untreated leachate in the abandoned drainage pipe) may also increase
after rainy periods as a result of increased leachate flow.
The accumulation of combustible gases generated at Pepe Field was
identified as a potential hazard. Field investigations showed
concentrations of combustible gas in excess of the lower explosive
limit in the soil vapor at the perimeter of the site and in an
apparent soil gas plume extending below an adjacent property.
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SUMMARY OF SITE RISKS
Human Health Risks
A baseline risk assessment, that is, an assessment of the risk posed
by the site if no action were taken, was performed in accordance with
the provisions of the Superfund Public Health Evaluation Manual.
This procedure consists of identifying contaminants of concern and
their concentrations, and then using these values along with an
evaluation of exposure pathways to estimate human intake of each
contaminant. The estimated intake is used with a toxicity assessment
factor to develop a characterization of the risk associated with the
site. Toxicity assessment factors fall into two categories, cancer
potency factors and reference doses.
Cancer potency factors (CPFs) have been developed by EPA's
Carcinogenic Assessment Group for estimating excess lifetime cancer
risks associated with exposure to potentially carcinogenic chemicals.
CPFs, which are expressed in units of (mg/kg-day)"', are multiplied
by the estimated intake of a potential carcinogen, in mg/kg-day, to
provide an upper-bound estimate of the excess lifetime cancer risk
associated with exposure at that intake level. The term "upper
bound" reflects the conservative estimate of the risks calculated
from the CPF. Use of this approach makes underestimation of the
actual cancer risk highly unlikely. Cancer potency factors are
derived from the results of human epidemiological studies or chronic
animal bioassays to which animal-to-human extrapolation and
uncertainty factors have been applied.
Reference doses (RfDs) have been developed by EPA for indicating the
potential for adverse health effects from exposure to chemicals
exhibiting noncarcinogenic effects. RfDs, which are expressed in
units of mg/kg-day, are estimates of lifetime daily exposure levels
for humans, including sensitive individuals, that is not likely to be
without an appreciable risk of adverse health effects. Estimated
intakes of chemicals from environmental media (e.g., the amount of a
chemical ingested from contaminated drinking water) can be compared
to the RfD. RfDs are derived from human epidemiological studies or
animal studies to which uncertainty factors have been applied (e.g.,
to account for the use of animal data to predict effects on humans).
These uncertainty factors help ensure that the RfDs will not
underestimate the potential for adverse noncarcinogenic effects to
occur.
Excess lifetime cancer risks are determined by multiplying the intake
level with the cancer potency factor. These risks are probabilities
that are generally expressed in scientific notation (e.g., IxlO"6 or
IE"6). An excess lifetime cancer risk of IxlO"6 indicates that, as a
plausible upper bound, an individual has a one in one million chance
of developing cancer as a result of site-related exposure to a
carcinogen over a 70-year lifetime under the specific exposure
conditions at a site.
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A multi-technique hazard identification scheme was used to identify
the analytes at Pepe Field that are above background concentrations
and present the greatest potential risks. The contaminants
identified for detailed evaluation were: hydrogen sulfide,
ethanethiol, methanethiol, methane, nickel, bis(2-ethylhexyl)
phthalate, and carbon disulfide.
Inhalation of hydrogen sulfide, and to a lesser extent, methane-
thiol and ethanethiol emitted by the soil vapor from Pepe Field was
identified as potentially causing adverse health effects. Exposure
to these compounds was modeled and potential levels of exposure were
calculated. Although perceptible by smell, the concentrations are
not sufficient to cause adverse health effects on a mean-case
exposure basis. Estimates of exposure during high-emission scenarios
were also modeled, and exposure estimates were still well below
concentrations associated with adverse health effects. The
worst-case scenarios modeled indicated that no adverse health effects
would be expected if all-of the hydrogen sulfide contained in the
soil was emitted into the air within a 24-hour period. If all of the
hydrogen sulfide in the soil were released within 15 minutes (most
likely an impossible scenario) , annoying health symptoms such as mild
eye or throat irritations, nausea, or dizziness may be observed for a
short period of time. Based on these calculations, no adverse health
effects are expected to result from gaseous releases from the Pepe
Field site.
The modeling exercises and field investigations did indicate,
however, that sufficient gases are being released from the site to
produce unpleasant odors. These odors may be the result of the
thiol, as well as the hydrogen sulfide emissions since, although
being emitted from the site at lower concentrations, the thiols have
characteristically unpleasant odors which are detectable at
concentrations significantly lower than hydrogen sulfide. These
odors, while unpleasant, are not expected to cause adverse health
effects. There may be significant negative social and economic
implications associated with these unpleasant odors, however.
Exposure to carbon disulfide via ingestion and dermal contact was
considered. Carbon disulfide exposure is related to a number of
noncarcinogenic health effects, but these are not expected to occur
because the lifetime average daily intake was estimated to be far
below the acceptable daily intake (ADI). Exposures to bis
(2-ethylhexyl) phthalate were not considered in the baseline risk
assessment because only the deeper soils contain detectable
quantities of this substance.
Exposure to nickel via inhalation of wind-borne soil erosion,
ingestion, and dermal contact with surficial soil, was considered.
The cumulative daily dose resulting from worst-case exposure
assumptions was below the ADI, so noncarcinogenic effects are not
expected to occur.
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Nicjcel is carcinogenic only when inhaled, so the carcinogenic risk
from eroded soils was calculated. The area of the baseball diamond
was considered the area best available for erosion. The emission of
nickel from this surface was estimated using a wind-blown dust
equation. The on-site concentration of nickel in air was calculated
using a "box-model". The on-site risk was estimated to be 6.2xlO~7
and, therefore, was considered insignificant. The off-site air
concentrations estimated based on generic applications of the
Industrial Source Complex Long Term Model provided more realistic
ambient air concentrations for off-site dispersion. The risks based
on these model results ranged from 4.4xlO"10 to 3.7xlO"9 and,
therefore, were also considered to be insignificant.
Environmental Risks
Pepe Field is in the middle of a residential neighborhood in an
extensively developed area. It is not surprising, therefore that no
environmentally sensitive ecosystems with potential exposure to
contaminants released from the site were identified. No critical
habitats are affected by the site contaminants. No endangered
species or habitats of endangered species are affected by the site
contaminants. No detriment to environmental quality is expected.
Potential Future Risks
Although the risks presented by Pepe Field in :." r -• •'• state are
limited, there are several possible situations develop
which would increase the risk.
The accumulation of the methane generated at Pepe Field was
identified as a potential threat to public welfare. Field
investigations showed concentrations of combustible gas far in excess
of the lower explosive limit (LEL) in the soil vapor at the perimeter
of the site and in the soil vapor of at least one adjacent private
property. The threat posed by combustible gas is not associated with
its release to the atmosphere, but with its potential migration into
the buildings on-site or nearby basements and accumulation to
explosive levels. Since the methane gas concentration is high at the
perimeter and off-site, however, construction on adjacent property or
installation of a new sewer line under Wootton Street could open new
pathways for gas migration.
A second possible development involves the progress of the anaerobic
digestion of the waste at Pepe Field. At this time, the high levels
of metals (nickel, lead, chromium) in the waste show no tendency to
migrate into ground water at levels of concern. Two factors exist at
this time which tend to limit leachability. First, the anaerobic
process tends to keep the metals in a reduced state in which their
solubility is relatively low. Second, the wastes which show the
highest levels are those which are very oily in nature; the oil would
tend to exclude water from the matrix, thereby reducing metal
leaching. As the landfill continues to age, however, the oils will
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be consumed by the anaerobic process and the chemical nature of the
system will change. In that case the metals could become more
leachable. The more likely case, considering the age of the
material, is that as each successive layer of oil is consumed, the
exposed metals will be leached gradually into the ground water
without ever approaching levels which would affect human health or
the environment. The worst case should be anticipated, however, and
ground water monitoring should be continued with the results watched
closely for new trends.
A third possibility for an increase in risk would occur if the
landfill cover were not maintained. A significant elevation
difference exists across the site, so that the cover could be eroded,
especially if the paved areas started to deteriorate. If the waste
were uncovered, and if the waste after weathering had the same
susceptibility to wind erosion that the current cover has, and if one
assumes the maximum concentration of nickel found in the waste (1,300
ppm), then the cancer risk due to inhalation could be as high as
4xlO"5. This represents a compounding of several "worst case"
assumptions, but it does indicate the need for cover maintenance.
Summary
Actual or threatened releases of hazardous substances from this site,
if not addressed by implementing the response action selected in this
Record of Decision, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
DESCRIPTION OF ALTERNATIVES
Based on ~he remedial investigation and risk assessment, the remedial
objective for the Pepe Field site was determined to be landfill
closure in accordance with New Jersey Solid Waste Regulations
(N.J.A.C. 7:26-2A.9). The implementation closure would address the
threat posed by landfill gases and their migration off-site. To this
end, a large number of technologies were screened to determine their
applicability to the site. The technologies found to be applicable
at Pepe Field were grouped to form remedial alternatives. The
alternatives identified were then evaluated based on the criteria of
implementability, effectiveness, and cost. Two of the alternatives
(Excavation with Off-site Incineration and Excavation with On-site
Solidification/ Stabilization) were dropped as a result of this
screening. The remaining alternatives, which are described below,
were then subjected to a more detailed individual and comparative
analysis. Appropriate costs for monitoring, and for maintenance of
the cover and leachate system, have been added to those in the
feasibility study. Cost and construction time estimates for each
alternative are presented in Table 1.
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Alternative 1: Excavation and Off-site Disposal
This alternative would involve the excavation and disposal of the
waste material at an industrial waste landfill. The waste would be
excavated, mixed with cement kiln dust to control free oil and water,
and loaded into lined bulk trailers for transport. The waste
quantity was estimated to be 16,000 cubic yards (34,000 tons). It is
estimated that as many as 10 truck loads of waste could be removed
from the site during each day of operation. With five days of
operation each week, the excavation would be expected to require
approximately 18 weeks. The cover fill would be stripped,
stockpiled, and backfilled on a daily basis. Due to the limited size
of the site, it would be necessary to backfill the pit as the
excavation proceeded. The excavation would be conducted in
compliance with New Jersey Solid Waste Regulations concerning
landfill disruption.
It is anticipated that a'small fraction of the waste might be
classified as hazardous based on the EP Toxicity tests for metals.
This material would require stabilization before disposal. This cost
has not been estimated.
Dewatering of the site would be required to permit excavation of the
waste. A low permeability silt layer underlies the waste and creates
a perched water table which saturates a portion of the waste.
Recharge to the water table is from horizontal flow through the site
from the hillside north of the site, vertical flow from the outwash
aquifer immediately below the silt layer, and precipitation. It is
expected that recharge to the area of excavation could be
significantly reduced by the installation of a row of wellpoints,
installed to a depth of approximately 30 to 40 feet, along the
upgradient perimeter of the site (along Wootton Street). Removal of
approximately 170 gallons per minute from the wellpoint system should
lower the water table to below the silt layer at the upgradient
perimeter of the site and significantly reduce the piezometric head
of the outwash aquifer over the entire site. This would eliminate
the horizontal flow through the site and reduce considerably the
upward movement of water through the silt layer. It is assumed that
water removed by the upgradient wellpoint system could be discharged
to a storm sewer or otherwise directed to surface drainage.
Removal of water from the excavation would still be required. This
would be accomplished by the construction of sumps and pumping of
water from the open excavation. Water saturating the waste and
surrounding soil, and precipitation, would accumulate in the
excavation at an estimated rate of approximately 4,000 gallons per
day. Water removed from the excavation would require on-site
treatment before discharge or removal from the site for off-site
treatment. On-site treatment is expected to be most cost-effective.
Treatment would be primarily for odor control (sulfide removal) using
activated carbon adsorption. Because the water removed from the
excavation would likely be high in suspended solids, prefiltration
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would also be necessary. Prefiltration would significantly reduce
the solids loading on the carbon filter. Because a caustic-
impregnated carbon is necessary for effective removal of sulfides,
used carbon cannot be regenerated and must be disposed of by
landfilling. The cost estimate prepared for this alternative assume™
disposal of the carbon in an industrial waste landfill. Carbon usage
was estimated using the average concentrations of sulfur compounds
detected in the raw leachate samples collected during the remedial
investigation; the estimated carbon usage would be approximately
2,000 pounds per month during operation of the dewatering system.
Effluent from the treatment system would be discharged to a storm
sewer or otherwise directed to surface drainage. It would be
necessary to obtain an NJPDES permit before water could be discharged
to surface waters.
No maintenance or monitoring would be required after completion of
the removal.
Alternative 2: Passive Perimeter Controls
This alternative would involve the construction of a high
permeability trench vent around the entire perimeter of the site.
The outer wall of the trench would be lined with a low permeability
polyvinyl chloride (PVC) liner to prevent gases from passing through
the vent by diffusive flow. Geotextile fabric would be placed
between the trench wall and the liner to protect the liner. It is
assumed that approximately 1,450 linear feet of a three-foot wide
trench would be excavated to a depth equal to or greater than the
seasonal low water table. The geotextile fabric and liner would be
placed, and the trench backfilled with gravel, to approximately three*
feet below the ground surface. Perforated PVC pipe would then be
placed along the full length of the trench. Vent stacks
approximately ten feet tall would also be installed along the trench.
The trench would be backfilled to the ground surface with gravel.
The perforated piping and vents would ensure that a pathway for gas
flow to the atmosphere would remain open should the surface of the
trench become blocked with snow and ice or vegetation. Drainage
channels would be constructed along the trench as necessary to
prevent surface water flow into the vent.
In order to accurately determine the depth to water and subsequent
depth of the trench vent, it would be necessary to install
approximately four shallow piezometers (less than 15 feet deep)
screened in the perched water table at the site. Ideally, the
piezometers would be installed in time to allow field measurement of
the seasonal low water table although water table measurements taken
during a period of the year not likely to represent the seasonal low
could be used to estimate the seasonal low water table. For cost
estimating purposes, it was estimated that the low water table in the
area of the site would average approximately 10 feet below the ground
surface.
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Operation and maintenance requirements for the trench vent are
expected to be minimal. Monitoring of off-site soil vapor would be
required to ensure the effectiveness of the system. It was assumed
that monitoring would consist of the collection and evaluation of
soil vapor data every six months for two years following the
implementation of the alternative and annually thereafter.
In addition to installation and maintenance of the trench vent, this
alternative would also include maintenance of the site cover,
operation and maintenance of the leachate collection and treatment
system, and monitoring of ground water and leachate. Deed
restrictions to prevent waste disruption would be sought.
Alternative 3: Active Interior Gas Venting With Cap
This alternative would involve capping the site, installing gas
collection piping and vacuum blowers, and venting the gas through
stacks to the atmosphere-.
Pilot testing would be required before an active gas venting system
could be designed. At Pepe Field, pilot testing would involve
installation of test wells at areas of the site currently paved.
Pressure test probes would also be installed at several distances
from the test wells. Tests would then be run at several vacuum
pressures. The pressure gradient created by each test well would be
determined by measuring the vacuum pressure at the test probes. The
radius of influence of the test well could then be determined for
various vacuum pressures and the most cost-effective combination of
blower size and collection system spacing determined. It may also be
necessary to perform meteorological testing at the site to determine
prevailing wind direction and velocity. This information could be
used during site-specific dispersion modeling to determine the most
effective stack height and location, and gas discharge velocity.
For cost estimating purposes, it was assumed that PVC gas collection
piping would be placed in trenches backfilled with gravel. Pipe runs
would be placed approximately every 50 feet over the entire site.
Blowers would be installed and gas discharged through vent stacks.
Unpaved portions of the site would also be capped.
Manholes would be provided for access to valves and gauges and for
repair or maintenance of the collection system piping. Long-term
operation and maintenance of the blowers and collection system, as
well as routine soil vapor monitoring as described for Alternative 2,
would be required as part of this alternative.
In addition, this alternative would also include operation and
maintenance of the leachate collection and treatment system, and
monitoring of ground water and leachate. Deed restrictions to
prevent waste disruption would be sought.
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Alternative 4: Active Interior Gas Collection and Treatment
with Cap
Construction for this alternative would involve all of the elements
of Alternative 3 except that the gases would be treated before beird
vented. Gas treatment would be required primarily for hydrogen "
sulfide removal and odor control. For this reason, carbon adsorption
was selected as the most effective gas treatment method. Gas would
be passed through activated carbon columns in series before being
discharged through a stack. Because a caustic-impregnated carbon is
required for hydrogen sulfide removal, carbon from this system could
not be regenerated. Carbon which has reached capacity would be
removed for off-site disposal at an industrial waste landfill. One
carbon unit would be taken off-line for carbon change-over while
another remained in service.
Carbon usage was estimated by calculating the quantity of hydrogen
sulfide detected in the vadose zone during soil vapor sampling
performed as part of the remedial investigation. It was assumed that
this quantity would be withdrawn from the site each day. An average
concentration of 280 ppm of hydrogen sulfide was detected in soil
vapor at the site. With a maximum depth to ground water of ten feet,
soil porosity of 0.3, and plume area of 2.5 acres, a total of
approximately 9 pounds per day of hydrogen sulfide would be withdrawn
from the site. An adsorption capacity of 20 percent was assumed for
the carbon and a 20 percent factor was included to account for carbon
consumption by other compounds present in the gases (e.g.. thiols).
This calculation resulted in a monthly carbon usage of approximately
1,600 pounds.
In addition to installation and maintenance of the cap and gas
collection and treatment system, this alternative includes operation
and maintenance of the leachate system and monitoring of ground
water, leachate and off-site soil gas. Deed restrictions to prevent
waste disruption would be sought.
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TABLE 1
PEPE FIELD REMEDIAL ALTERNATIVES COST SUMMARY
Remedial Alternative
1. Excavation/Disposal
Cost—Present Worth Basis
($Thousands)
Capital O&M3 Total
6,873 0 6,873
Time2
(Mos)
2. Passive Perimeter
Controls
3. Interior Gas Venting
255
379
465
566
720
945
4. Interior Gas Venting/
Treatment with Cap
5. No Action/Monitoring
413 1,235 1,648
410
410
1 Present worth of 0 & M with 10 percent discount rate.
2 Construction time only—in months.
3 Operation and Maintenance. Includes monitoring cost.
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Alternative 5: No Action with Monitoring
This alternative would involve monitoring of the contaminant levels
in ground water, leachate and off-site soil gas. In addition, deed
restrictions to prevent waste disruption would be sought. Monitoring!
data would be reviewed on a periodic basis to determine whether
additional measures were needed.
Maintenance of the cover and operation of the leachate treatment
system would be consistent with NJPDES requirements.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
This section presents a comparative evaluation of the alternatives
discussed in the preceding section. This is accomplished through an
assessment of how each alternative relates to the others with respect
to the nine criteria that EPA has developed to address the
requirements of section 121 of the Superfund Amendments and
Reauthorization Act of 1986 (SARA).
Overall Protection of Human Health and the Environment
Excavation and Off-site disposal, and Active Interior Gas Collection
and Treatment with Cap (Alternatives 1 and 4) both fully achieve the
remedial objectives and thus provide the greatest protection of
public health and the environment. Both alternatives would mitigate
combustible conditions at the site and eliminate air emissions.
Active Interior Gas Venting would mitigate combustible conditions,
but would include direct discharge of the vented gases to the
atmosphere. This discharge would not present a risk to the public
health or the environment, but would result in localized odors.
Passive Perimeter Controls would eliminate the primary safety concern
at the site, the development of combustible conditions in off-site
structures. This alternative would eliminate off-site migration of
gases through the subsurface soil. Air emissions from the site
would, however, continue at the current rate. As evaluated in the
RI, these emissions do not present a risk to the public health or the
environment, but result in odors. Under the No Action alternative,
current conditions would persist and the potential for the
development of combustible conditions in off-site structures would
remain.
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Compliance with ARARs
Alternatives 1, 2, 3, and 4 would meet applicable or relevant and
appropriate requirements (ARARs) of Federal and State environmental
laws.
Alternative 5 (No Action/Monitoring) would not meet the requirements
of the New Jersey Solid Waste Regulations with respect to landfill
closure (N.J.A.C. 7:26-2A.9). Therefore, Alternative 5 is not
considered further in this analysis.
Long-Term Effectiveness and Permanence
Excavation and Off-site Disposal, and Active Interior Gas Collection
and Treatment with Cap were considered to be most effective in the
long term. Both alternatives would mitigate combustible conditions
and eliminate air emissions at the site. Passive Perimeter Controls
would relieve combustible conditions at the perimeter of the site,
but would not address interior site conditions or air emissions.
Active Interior Gas Venting would reduce combustible conditions at
the site and control air emission. Vented gases would, however, be
directly vented through an on-site stack.
Reduction of Toxicity, Mobility, or Volume through Treatment
The reduction of toxicity, mobility, or volume of waste material
through treatment is not involved in the comparison of alternatives
for this site. The potentially hazardous substances which remain on
the site have not shown evidence of mobility during the time that
they have been there. Therefore, waste treatment is considered
unnecessary at this time and highly unlikely to become necessary in
the future.
Alternatives 2, 3, and 4 include treatment of leachate. The purpose
of this treatment, however, is to reduce odors, not toxicity.
Additionally, Alternative 4 includes treatment of collected landfill
gases.
Short-Term Effectiveness
Excavation and Off-site Disposal (Alternative 1) would be the least
effective alternative in the short term. Risks to the community,
site workers, and the environment resulting from implementation of
this alternative are expected to be greater than for the other
alternatives considered, although not significant. Excavation and
off-site disposal would also require the most time to implement. The
short-term effectiveness of the three remaining alternatives
(excluding No Action) are considered to be basically equivalent. The
No Action alternative is not considered effective.
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Implementability
Excluding No Action, Passive Perimeter Controls would be the most
easily implemented alternative. Construction requires readily
available materials and services and few technical or administrati
setbacks are anticipated. For the active venting alternatives,
testing would be required during design and specialized personnel may
be needed during startup.
Considerable difficulties could be expected during implementation of
Excavation and Off-site Disposal. Design and operation and
maintenance of two dewatering systems and a water treatment system
would be necessary. An NJPDES permit would be required prior to
discharge of the treated water to surface waters. Also, on-site
mixing of the waste with cement kiln dust would most likely be
necessary to minimize free oil and water.
Cost
All costs in this section are the combined construction, and
operation and maintenance costs for the life of the remediation. All
are stated on a present worth basis.
The alternative having the lowest cost is Alternative 2, Passive
Perimeter Controls. The cost is $720,000.
The next least expensive is Alternative 3, Active Interior Gas
Venting with Cap. The cost is $945,000.
The third ranking alternative, based on this criterion, is
Alternative 4, Active Interior Gas Venting with Cap and Treatment.
The cost is $1,648,000.
The most expensive alternative is Alternative 1, Excavation and
Off-site Disposal. The cost is $6,873,000.
Support Agency Acceptance
The New Jersey Department of Environmental Protection, being the lead
agency for this remedial investigation and feasibility study, concurs
with the selected remedy for the Pepe Field site.
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Community Acceptance
A public meeting was held on September 6, 1989 in Boonton, New Jersey
to present the findings of the remedial investigation, to describe
the alternatives evaluated in the feasibility study, including the
preferred alternative identified in the Proposed Plan, and to receive
questions and comments from the community. Attendance at the meeting
was very good and there were many comments. Since the meeting,
written comments have been received from several parties. The
comments from the public, and responses to those comments, are
presented in detail in the Responsiveness Summary. The following
three areas seemed of most concern to the community:
1. The overwhelming choice of the local residents was Alternative
1, Excavation and Off-site Disposal. They expressed the
opinion that any other alternative would be a "band-aid"
approach which would leave the community to deal with risks
which might develop in the future.
2. Residents who live in the immediate area of Pepe Field stated
that the sulfide odors are their most important problem.
Whether or not the hydrogen sulfide concentrations reach health
effect levels as defined in the risk assessment, the odors in
their homes and yards are often high enough to cause nausea,
headaches and loss of sleep. Their position is that if
Superfund does not address the odor problem, it is providing no
benefit to the community.
3. The preferred alternative, identified in the Proposed Plan, was
described in the feasibility study report as including 29 vent
stacks with a height of ten feet. The opinion was expressed
that this would detract greatly from the appearance of the
neighborhood.
SELECTED REMEDY
Based upon consideration of the requirements of CERCLA, the risk
assessment for the site, the detailed analysis of the alternatives,
and public comments, both the State and EPA have determined that Gas
Collection and Treatment is the most appropriate remedy for the Pepe
Field site in Boonton, New Jersey. The actual degree of, or
necessity for, treatment will be determined during remedial design.
In addition, the existing leachate collection and treatment system
will be upgraded. It is expected that upgrading this system will
reduce odors. These actions will be designed and implemented to
allow, to the maximum extent possible, unrestricted use of the
baseball field and other recreational areas.
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The remedial investigation and risk assessment did not find any
current health risk at Pepe Field. The remedial objective for the
site is compliance with an identified relevant and appropriate
requirement, the New Jersey Solid Waste Regulations for landfill
closure (N.J.A.C. 7:26-2A.9). The major components of the selected
remedy include the following:
- installation and maintenance of a landfill gas collection and
treatment system
- upgrading and maintenance of the leachate collection and
treatment system
- maintenance of the site cover
- ground water quality monitoring
- deed restrictions to prevent waste disruption
The major construction associated with this remedy is the
installation of the collection and treatment system for the landfill
gases. The affect of this remedial approach will be not only
compliance with the ARAR, but protection against potential future
risks identified in the Summary of Site Risks.
The construction costs for the selected remedy are shown in Table 2.
The total of $390,700 includes $42,000 for Engineering and
Administration, and $70,000 for contingency. The operation and
maintenance costs are shown in Table 3. The total annual cost for
operation and maintenance is $108,000 for the first two years and
$93,000 for the next 28 years. The present worth of the operation
and maintenance costs, using a ten percent discount rate, is
$903,000. The total present worth of the project, therefore, is
$1,293,700.
STATUTORY DETERMINATIONS
Superfund remedy selection is based on the requirements of CERCLA,
the provisions of the Superfund Amendments and Reauthorization Act of
1986 and, to the extent practicable, the regulations contained in the
National Contingency Plan. The primary requirement is that EPA and
State support agencies undertake remedial actions that achieve
adequate protection of human health and the environment. In
addition, section 121 of CERCLA establishes several other statutory
requirements and preferences. These specify that when complete, the
selected remedial action for a site must comply with applicable or
relevant and appropriate environmental standards established under
Federal and State environmental laws unless a statutory waiver is
justified. The selected remedy must also be cost-effective and
utilize permanent solutions and alternative treatment technologies or
resource recovery technologies to the maximum extent practicable.
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Finally, the statute includes a preference for remedies that employ
treatment that permanently and significantly reduces the volume,
toxicity, or mobility of hazardous wastes as their principal element.
The following sections discuss how the selected remedy for Pepe Field
meets these statutory requirements.
Protection of Human Health and the Environment
The selected remedy is protective of human health by preventing
migration of landfill gases, by preventing contact with buried
wastes, and by upgrading and maintaining a leachate collection and
treatment system. It is further protective of the environment
through the monitoring of ground water quality.
Compliance with Applicable or Relevant and Appropriate
Requirements (ARARs)
The selected remedy will comply with all ARARs. There are no
location-specific ARARs identified for Pepe Field.
Chemical-specific ARARs exist for ground water, surface soil and
leachate. Ground water quality at the site already meets the
standards of the New Jersey Safe Drinking Water Act. Surface soils
at the site already meet the NJDEP Action Levels for surface soils or
are within local background levels. Leachate quality will comply
with NJPDES requirements for discharge to either a Publicly Owned
Treatment Works (POTW) or to the Rockaway River. This decision will
be made during the design phase.
There are several action-specific ARARs. First, the ARAR which
covers the requirements for Solid Waste Landfill Closure. Removal
and disposal of any waste encountered in the excavation for the gas
collection system will also be consistent with those regulations.
Emissions from the gas treatment system will comply with New Jersey
Air Pollution Regulations. Ground water monitoring will be performed
according to the requirements of the NJPDES program.
Cost-Effectiveness
The selected remedy is cost-effective because it provides overall
effectiveness relative to its cost. The remedy will ensure a greater
degree of protection of public health and the environment for its
estimated cost than the other alternatives which were considered.
27
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utilization of Permanent solutions and Alternative Treatment or
Resource Recovery Technologies to the Maximum Extent Practicable
(MEP)
The State and EPA have determined that the selected remedy represent
the maximum extent to which permanent solutions and treatment
technologies can be utilized in a cost-effective manner at the Pepe
Field site. Of those alternatives that are protective of human
health and the environment and comply with ARARs, the State and EPA
have determined that this selected remedy provides the best balance
of tradeoffs in terms of long-term effectiveness and permanence,
reduction in toxicity, mobility, or volume achieved through
treatment, short-term effectiveness, implementability, and cost.
While none of the alternatives used treatment of waste as a principal
element, the selected remedy includes treatment of leachate and
landfill gases.
Preference for Treatment'as a Principal Element
This remedy utilizes permanent solutions and alternative treatment
technologies, to the maximum extent practicable for this site.
However, because treatment of the principal threats of the site was
not found to be practicable or justified, this remedy does not
satisfy the statutory preference for treatment as a principal
element. The potentially hazardous substances which remain on-site
have not shown evidence of mobility during the time that they have
been there, therefore, treatment is considered unnecessary at this
time and highly unlikely to become necessary in the future.
Documentation of Significant Changes
After consideration of public comments regarding the Proposed Plan
and the feasibility study report, the State and EPA have not selected
the remedy which was preferred in the Proposed Plan. Rather, Gas
Collection and Treatment, which includes elements of Alternatives 2
and 4, has been selected for implementation at the Pepe Field site.
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TABLE 2
SELECTED REMEDY
Construction Costs
Item
Trench excavation
Trench backfill
Gravel
4" PVC pipe
6" PVC pipe
PVC liner
Geotextile fabric
Dispose waste en-
countered during
excavation
Removal of "clean"
excavated material
Grading
Piezometers
Appurtenant Equipment
(valves, gauges,
manholes)
Blower
Blower housing
Carbon columns
Pilot testing
Engineering
Units Cost Quantity
cu yd $13.25 1,615
cu yd 2.85 1,615
cu yd 18.40 1,615
foot 3.00 1,520
foot 4.00 1,820
sq ft 1.25 17,400
sq ft 1.25 17,400
ton 140 490
CU yd 2.70 1,380
sq yd 1.25 3,225
foot 50 60
lump sum
ea 7,500 4
lump sum
ea 12,000 2
lump sum
Construction Subtotal
and Administrative § 15%
Contingency § 25%
Construction Total
Total
$ 22,000
5,000
30,000
4,500
3,200
22,000
22,000
69,000
4,000
5,000
3,000
15,000
30,000
10,000
24,000
10.000
$ 278,700
$ 42,000
S 70.000
$ 390,700
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TABLE 3
SELECTED REMEDY OPERATION AND MAINTENANCE COSTS
Annual Operation and Maintenance of Gas Collection and Treatment
First 2 years;
Monitoring—twice annual soil vapor sampling,
analysis and interpretation § $15,000 each $ 30,000
0 & M of system § 5% construction subtotal 14,000
Carbon replacement 9,525 Ibs/year @ $3.55/lb 34,000
Carbon disposal 4.25 tons/year @ $95/ton 500
Total Annual 0 & M $ 78,500
28 years thereafter:
Monitoring—once annual soil vapor sampling,
analysis and interpretation @ $15,000 each $ 15,000
0 & M of system § 5% construction subtotal 14,000
Carbon replacement 9,525 Ibs/year § $3.55/lb 34,000
Carbon disposal 4.25 tons/year @ $95/ton 500
Total Annual 0 & M $ 63,500
Annual Operation and Maintenance of Leachate System $ 15,000
Annual Site Cover Maintenance $ 1,000
Annual Monitoring Cost for Ground Water and Leachate $ 13,500
Total Annual O&M Costs First 2 years $108,000
Next 28 years $ 93,000
Present Worth of O&M Costs (10% discount rate) $903,000
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PEPE FIELD
Boonton, Morris County, New Jersey
Responsiveness Summary
A. Overview
The New Jersey Department of Environmental Protection's (NJDEP's)
recommended alternative, which was detailed in the August 15, 1989,
Proposed Plan, addressed solid waste landfill closure requirements
for the landfill. The preferred alternative specified the
installation of passive perimeter controls for the venting of methane
gas, maintenance of the existing cover, operation and maintenance of
the leachate collection and treatment system, and monitoring of
ground water, leachate, and off-site soil gas.
It became clear from comments received during the public comment
period that many residents and the Boonton Town Council strongly
prefer the excavation and disposal of the waste at an off-site
industrial waste disposal facility. The only identified potentially
responsible party, Drew Chemical Corporation, has taken the position
that the Pepe Field site should not have been placed on the National
Priorities List (NPL) and, therefore, should not be remediated under
the Comprehensive Environmental Response, Compensation, and Liability
Act (CERCLA). However, Drew has stated that, if any of the
alternatives described in the feasibility study report were to be
undertaken, other than the No Action Alternative, it would consider
Alternative 2, Passive Perimeter Controls, the most appropriate.
After consideration of all comments received on the Proposed Plan and
the feasibility study report, however, the State and EPA selected Gas
Collection and Treatment for the site.
B. Background on Community Involvement
Community interest in the site dates back to 1948 when the Boonton
Board of Health ordered the E.F. Drew Corporation to cover the site.
Actually the dump remained open although inactive until the
mid-1960s. At that time the site was covered with a layer of fill
material.
Over the years, the site has been the source of many complaints,
primarily because it produces an unpleasant odor associated with
hydrogen sulfide. The odor varies in intensity, sometimes forcing
residents to keep their windows closed. There have been complaints
of headaches and nausea caused by the hydrogen sulfide fumes. The
odor is usually most pronounced after a rainfall. The Town of
Boonton provided a leachate treatment facility for the leachate
collected from the field. The leachate is collected in a manhole and
treated with hydrogen peroxide in an effort to minimize odor
generation. This facility performs marginally, and odor problems
persist.
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Of increasing concern is the nature of the leachate, which is
collected in the on-site trench system and then directed off-site,
previously into the Town's sanitary sewer system and presently into
the Town storm sewer system. In addition to the hydrogen sulfide
odor, the discharge has exhibited corrosive properties.
Another issue which has involved the community is whether the Drew
Chemical Corporation will be held accountable as a responsible party.
In 1985, the Town won a decision in U.S. District Court that upheld
the Town's right to sue Drew. The Town decided at that point to wait
until completion of the Superfund remedial investigation/feasibility
study before proceeding further.
C. Summary of Comments Received During Public Comment Period
Comments raised during the Pepe Field public comment period on the
draft feasibility study report and Proposed Plan are summarized
briefly below. The comment period was held from August 15, 1989 to
September 22, 1989. In addition, written comments were received from
the Town of Boonton, the Drew Chemical Corporation and several local
residents. The comments are categorized by relevant topics.
Evaluation of Remedial Alternatives
Comment: NJDEP was asked for clarification of its reasoning for
preferring Alternative 2.
Response: CERCLA, as amended, established a procedure for selecting
the appropriate remedy at a Superfund site. There are nine criteria
to be considered. The first two, Overall Protection of Human Health
and the Environment, and Compliance with Applicable or Relevant and
Appropriate Requirements (Federal or State environmental laws), are
threshold criteria which every alternative must meet to qualify for
further consideration. For Pepe Field, all of the alternatives
evaluated in the feasibility study meet the requirement for Overall
Protection. All of the alternatives except one comply with
Applicable or Relevant and Appropriate Requirements (ARARs); the No
Action Alternative does not meet the relevant and appropriate
requirements of the New Jersey Regulations for Solid Waste Landfill
Closure (N.J.A.C. 7:26-2A.9). Based on information available, and
relative to the five balancing criteria, Alternative 2 appeared to
offer the best balance of tradeoffs.
The last two criteria, support agency (in this case EPA) acceptance
and community acceptance, are referred to as modifying criteria.
Comments from the community or the support agency may also bring out
new facts which lead to modifying the preferred alternative or
choosing a different alternative. If warranted, the decision process
described above would be repeated using the new information. This
process has led to the selection of a remedy different from that
identified in the Proposed Plan.
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Comment: There was concern that an alternative would be chosen which
would address the methane gas problem, but not the odor from hydrogen
sulfide.
Response: Applicable and relevant requirements in this case pertain
to solid waste landfill closure. To meet these requirements, the
agency must install a landfill gas venting system, and maintain the
leachate collection system and the site cover.
An integral part of the selected remedy is the upgrading and
maintenance of the leachate collection system. It is believed that,
through proper operation and maintenance, this upgraded system will
significantly reduce odors associated with the presence of hydrogen
sulfide. Additionally, treatment of the landfill gases is included
in the remedy.
Comment: The feeling was expressed that Alternative 2 is only a
"band-aid" approach and that Superfund was intended to remove the
problem.
Response: As described above, Alternative 2 was recommended using
the criteria and methodology prescribed under Superfund.
Comment: Preference for Alternative 1 was repeatedly stated together
with the opinion that the choice was based only on difference in
cost, which could be recovered from the responsible party.
Response: First, as described above, cost is only one criterion used
in selecting a remedy. Second, NJDEP and EPA must make remedial
decisions which are consistent with the facts about a site, without
regard to the source of the funds.
Comment: It was noted that the waste would be taken to an industrial
waste facility if Alternative 1 were selected. It was stated that
disposal at such a site, away from a densely populated residential
neighborhood, would be preferable.
Response: NJDEP indicated that the waste would probably be sent to
an approved industrial waste disposal facility if adequate capacity
were available. It might be necessary to send a portion of it to a
hazardous waste disposal facility.
Comment: It was suggested that the top five feet of good soil could
be removed and saved for re-covering the landfill after excavation.
Response: Every effort will be made to use as much of the existing
clean fill as possible during remedial action.
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Comment: A question was asked about what success NJDEP has had in
the past with methane gas collection and monitoring. Inquiry was
also made regarding guarantees that NJDEP would come back and assume
responsibility if something goes wrong in the monitoring process.
Response: Methane gas collection and monitoring systems represent
standard technology. Regarding maintenance, specific
responsibilities will be embodied in either an Administrative Consent
Order or a Memorandum of Agreement between NJDEP and the Town of
Boonton.
Comment: NJDEP was asked about what happened to the pesticide
(Alpha-BHC) that was responsible for placing the site on the NPL.
Response: No definitive conclusion may be drawn from the apparent
presence of alpha-BHC. The presence of alpha-BHC in early sampling
results may have been an anomaly. In subsequent samples, alpha-BHC
was not detected. If the Department were to find evidence of the
presence of additional hazardous substances and/or their presence in
migration pathways, the NJDEP would take appropriate measures to
address the situation.
Comment: Questions were asked regarding the presence of metals in
the landfill. Specific questions focused on how long these metals
will stay in the soil, what kind of a. health threat they present, how
long it will take for them to leach out of the soil and what could be
done in 30 years if these metals present a problem then.
Response: Because of changes which will occur within the landfill
over time, the metals that are present will have an increased
tendency to leach into the ground water. It is expected that this
process would occur over a period of many years, and that metals
would be gradually leached into the ground water without ever
approaching levels which would affect human health or the
environment. However, a ground water monitoring program will be
implemented as a part of the selected remedy and will allow an
evaluation to be made regarding these assumptions. Further, proper
maintenance of the landfill cover will also ensure that no metals
contamination becomes airborne.
Comment: It was submitted that the site should not have been placed
on the NPL and that the site was included due to a single occurrence
of the pesticide alpha-BHC (at 23 parts per billion) in samples of
the leachate taken by NJDEP in 1981. Samples collected by NJDEP in
1979 did not contain this pesticide, nor did subsequent samples
collected by EPA in 1984, or as part of the RI in 1986 and 1988.
NJDEP has expressed that it believes the 1981 finding was a
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laboratory error. Additionally, nothing in the history of the site
would indicate that this pesticide, or for that matter, any other
pesticide, was ever disposed of at the site.
Response: NJDEP has not expressed the opinion that the 1981 finding
was a laboratory error. NJDEP has only raised that as one
possibility. There was no reason to suspect the analysis at the time
the site was evaluated for inclusion on the NPL. When analyses
indicate that a contaminant is indeed present at a site, it is not
necessary to have historical evidence of its disposal.
Comment: The comment was made that the only identifiable problem
associated with the site (i.e., odors), is related to methane and
hydrogen sulfide gas. According to NJDEP, both in the RI/FS report
and at the public meeting held in Boonton on September 6, 1989, no
current threat to human health or the environment exists at the site.
It would be virtually impossible for the hydrogen sulfide to reach
concentrations which would cause adverse health effects. It is
emphasized for the record that neither methane gas nor odors,
especially odors which are not associated in any way with threats to
human health or the environment, are addressed under CERCLA.
Response: While it is the position of NJDEP that there is no current
threat to human health and the environment, it is clear in the RI/FS
reports that this is due to actions taken by the Town of Boonton in
the past. There are metals concentrations in the waste which could
pose a health threat if they were on the surface; they are not
exposed because the Town of Boonton applied a cover to the site. The
leachate also contains metals at levels which could pose a problem;
that this leachate is not in adjacent yards where children play is
because the Town of Boonton installed a leachate collection system.
There is ample evidence that the site is a solid waste landfill,
therefore, the proposed remedial action will be taken to comply with
the applicable or relevant and appropriate requirements (ARARs) as
required by CERCLA, as amended.
Comment: Pepe Field is located on a former marsh area. The decaying
marsh deposits are a natural source of methane, and indeed, NJDEP's
report mentions that the methane concentrations at the site may in
part be a natural phenomenon. The marsh deposits extend beyond the
boundary of the site as well. To the extent substances occur
naturally, even if they are defined as "hazardous" under CERCLA, they
are not subject to CERCLA remedial action.
Response: The entire area was a marsh and the marsh deposits extend
beyond the site boundaries. The high concentrations of methane and
hydrogen sulfide, however, are limited to those areas where the
presence of waste has been established by borings and geophysical
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techniques, and to a limited extent into one adjacent property. An
examination of the data presented in the Phase I RI report show that
the high concentrations of methane are coming from the waste.
Further, the selected remedy, in accordance with the pertinent ARAR(
is not aimed specifically at methane, but rather at supplying a
system to control migration of landfill gases.
Comment: The proposed remedial action will vent explosive gases into
the surrounding neighborhood. Who assumes liability for an explosion
resulting in injury should these gases be ignited?
Response: The remedial action includes treatment of landfill gases.
Although these gases are present at high concentrations in the soil,
even without treatment their concentration in air is always very low,
and, therefore, they cannot ignite or explode.
Comment: The proposed remediation plan does not include funds for
treatment of effluent. What has been done to check if treatment
would be required? What will such treatment cost and who will pay
for it should it be required? How does this alter the economics of
the proposed remedial action plan?
Response: The costs of treating the leachate were not included in
the feasibility study, but were included in Proposed Plan. They are
part of the added costs referred to on page 5 of the Plan. This is
why the operation and maintenance costs presented in the two
documents are different.
Comment: Were the maintenance and monitoring costs escalated over
time to reflect increased costs and then discounted to present value?
How would this affect the economics of the proposed remedial action
plan?
Response: These costs were not escalated before discounting. If
this were done, the cost of Alternative 2 would be slightly more than
$1 million and the ratio between Alternative 1 and Alternative 2
would drop from 10 to 6.5. However, if even a minor portion of the
waste were classified as hazardous for disposal, that ratio would go
up.
Comment: The Town of Boonton is also involved in the pursuit of
cleanup of a piece of property on Division Street, known as the "PVO
Site". The PVO site is under ECRA laws but the cleanup process has
encountered myriad delays since the 1960s. The appropriate treatment
of the Pepe Field site, i.e., Excavation and Off-Site Disposal, will
serve to place the Town of Boonton in a better position to address
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the PVO property, for two reasons. First, it will set a precedent of
"do it once and do it right", and second, it will minimize any
possibility of a delay based on a claim that Pepe Field may
recontaminate PVO.
Response: The sites have no known connection. One site should not
set a precedent for a dissimilar site.
Comment: The "six-month period of construction" mentioned for
Alternative 1 is not consistent with the statement on page 6 of the
Proposed Plan that the excavation would be expected to require
approximately 18 weeks.
Response: The construction period includes not only excavation but
also 1 week for mobilization, 2 weeks to install and start the
wellpoint system for site dewatering, 2 weeks for final grading and
drainage, 1 week for demobilization and 2 weeks for contingency.
Comment: In response to the Town's request for excavation and
removal, NJDEP stated that such a remedy would simply transfer the
waste problem to another site and, therefore, should be disfavored.
This rationale misstates the premise of Superfund Amendments and
Reauthorization Act (SARA). SARA provides "the off-site transport
and disposal of hazardous substances or contaminated materials
without such treatment should be the least favored alternative
remedial action where practical treatment technologies are
available". The language of SARA does not prohibit off-site
disposal, it only requires that the waste be treated in connection
with such disposal.
Response: NJDEP was not referring to any prohibitions of off-site
disposal under SARA when it was stated that excavation and disposal
would simply transfer the problem to another site. Most of the waste
at Pepe Field would not be classified as hazardous for disposal and
would not require treatment. Rather, a reference was being made to
the fact that what is a permanent solution for one community is a new
problem for another. The language of SARA encourages a more
comprehensive approach to environmental problems.
Comment: The Town of Boonton is concerned that the present cover at
Pepe Field is not thick enough to provide protection against contact
with the waste buried there. Steve Austin, from the Boonton Health
Department, and Bill Hoehlein of Killam Associates visited the site
on September 21, 1989 to examine the surficial soil layer in the
vicinity of the baseball field. By visual observation and surficial
probing, it was apparent that the surficial cover is less than six
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inches thick in numerous areas at or near the baseball field. In
several areas, waste material was observed at or near the surface.
Waste material was evidenced by its black color.
Response: The findings reported in this comment differ from those of
the RI/FS. The identification of waste on the basis of a black color
is suspect since some of the cover fill itself is black. In any
case, if it were established that the cover fill were too thin in
some places, this could be readily corrected by adding more fill.
Comment: The landfill closure requirements used as an ARAR require a
clay cap with an overlying drainage layer and a topsoil layer.
Response: The regulations do not require a clay cap. They require
an appropriate cover. The clay cap is required to prevent water
infiltration where contamination of ground water by leachable
materials would be expected. In the case of Pepe Field, the results
of ground water monitoring have established that a clay cap is not
necessary.
Comment: The presentation of Alternative 2 did not adequately
address the issue of ground water control. Without proper ground
water control, increased odors and local drainage problems could
result.
Response: No ground water controls are required. Nothing is planned
for the site that will affect ground water flow. There will be no
increase in odors as a result of ground water flow nor will there be
any change in local drainage problems as a result of the proposed '
remedial action. If there is a change in odors due to leachate
flows, the Department would address that problem.
Comment: Given that at least some of the methane originates from
natural sources outside of the site boundaries, most notably near
certain residences located near the site boundaries, it is dubious
whether even Alternative 1 (excavation and disposal) would solve this
problem.
Response: NJDEP is not aware of any significant amount of methane
originating from natural sources outside the boundaries of Pepe
Field.
Comment: In installing the vent system that is part of Alternative
2, isn't NJDEP simply changing a water and soil pollution problem
into an air pollution problem?
Response: The selected remedy will include the collection and
treatment of landfill gases.
8
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Comment: The suggestion was made that it would be more cost
effective to take care of everything now than to have to do it 25
years down the road, and have it cost three times as much.
Response: The Department doesn't believe that it will be necessary
to undertake additional remedial measures in the future.
Comment: The question was asked where Pepe Field stands as far as
severity compared to other sites on the Superfund list which have
been given the Alternative 2 option. Another inquiry was made as to
whether Alternative 1 had been turned down at other sites.
Response: All Superfund sites present unique characteristics and,
therefore, cannot always be compared on an individual basis. There
are, however, two other sites within New Jersey in which similar
remedies have been chosen. In each case, an excavation alternative
was rejected as inappropriate.
Comment: Other questions concerned who would make the final decision
with regard to choosing an alternative; when remedial action would be
complete; and if the site would then be removed from the Superfund
list.
Response: The Acting Regional Administrator of the EPA's Region II
Office will make the final decision. Design of the selected remedy
may take about one year to complete. Following that, actual
implementation of the selected remedy would occur, pending the
availability of funding.
Related Concerns about Current Landfill Conditions
Comment: NJDEP was questioned about the depth of the waste and the
depth of the water table.
Response: The lowest level of waste is 12 to 15 feet below the
ground surface; the surface of the shallow ground water aquifer is
approximately 18 feet below the ground surface. The two are
separated by a relatively impermeable layer of silt. There is
perched water within the waste material itself.
Comment: The NJDEP was asked to describe the likelihood for
increased generation of methane gas by the site in the future.
Response: Considering the age of the site, the period of maximum
methane gas production, resulting from biodegradation, has most
likely past. The peak rate is usually reached seven to ten years
after waste is placed in a landfill.
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Comment: NJDEP was asked if the rate of hydrogen sulfide generation
by the landfill could increase.
Response: It is possible that hydrogen sulfide generation could
increase, but, as explained above with regard to methane gas
generation, an increase is not expected.
Comment: NJDEP was asked to describe what action was planned to
address chemicals remaining in the landfill.
Response: Chemicals at the site do not pose a current threat. Long-
term monitoring is planned, and if the situation changes, NJDEP will
take appropriate measures.
Comment: Will the leachate be treated to remove metals?
Response: The discharge of treated leachate will be permitted in
accordance with the requirements of the New Jersey Pollutant
Discharge Elimination System (NJPDES) program. Permit discharge
requirements are currently being investigated. Treatment for metals
is not anticipated, however, due to the low concentrations.
Comment: NJDEP was also asked to explain the cause of pipe corrosion
experienced by local residences.
Response: The agency is aware of only one instance of pipe
corrosion, which occurred when leachate from the site was being
discharged into the municipal sewer system, and is no longer the
case.
Comment: The comment was made that Pepe Field was like Love Canal.
Response: The Pepe Field site is not similar to the Love Canal
situation.
Health Problems
Comment: A statement was made that the odor problems have increased
with time. A comment was made suggesting that the NJDEP sample for
hydrogen inside residences.
Response: It might be possible to monitor the residences, if the
NJDEP is notified immediately when odor problems occur.
Note: Since the September 6, 1989 public meeting, NJDEP has been
awaiting notification of an odor problem so that sampling could
be conducted. Although several rain events have occurred, no
complaints have been received. The NJDEP inquired about odor
problems after one rainstorm, but no positive responses were
received.
10
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Comment: It was asked if hydrogen sulfide is toxic.
Response: Hydrogen Sulfide is toxic at the level of 100 parts per
million. At Pepe Field it was found at trace levels of parts per
billion. That is 100,000 times less than the toxic level. The odor
problem is intermittent, depending on whether or not the leachate
collection system is operating, whether or not there is sufficient
hydrogen peroxide, and the quantity of leachate being received.
Comment: One resident said that she and her family had experienced
headaches and nausea because hydrogen sulfide odors.
Response: NJDEP will inform the New Jersey Department of Health and
request their opinion.
Comment: The question was asked if health risks were considered in
evaluating the implementation of the proposed alternatives.
Response: Yes, several of the remedy selection criteria include this
issue.
Design of Methane Venting System
Comment: NJDEP was asked if combustible levels of methane gas would
be vented from the vent stacks.
Response: The purpose of venting was to prevent accumulation of
methane which would not discharge explosive concentrations of
methane.
Comment: Will odors be associated with the vented gases?
Response: Odors are not anticipated, however, treatment of gases is
included in the selected remedy.
Comment: Why must the proposed vent stacks be ten feet tall? What
will the vent stacks be constructed of?
Response: The height of the stacks was estimated to be ten feet to
prevent people from putting objects in them. They may be made from
plastic or steel, and will be carefully maintained.
Comment: Other questions were asked about what the field would look
like with vent stacks, and how long they would be kept in place.
Response: Although this is not the selected remedy, there would be
great flexibility afforded in design of a passive venting system.
For example, the poles of a Scoreboard could actually be gas vents.
The collection pipes could be connected in a trench under ground.
Specific details would be developed during the design phase, however,
the field would not be covered with stacks.
11
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Comment: Another question asked if other methane venting systems had
been installed in a similar residential area.
Response: This is conventional landfill technology, and many similar
systems have been put in place. The New Jersey Super fund program haij
not completed construction of a similar system at a Superfund site
however, one is currently under construction.
Payment of Remedial Action Costs
Comment: NJDEP was asked who would pay for the cleanup.
Response: As at most Superfund sites, the parties potentially
responsible for causing the problems will be provided the opportunity
to implement the remedy. If the potentially responsible parties
decline, pending the availability of funding, EPA and NJDEP would
implement the remedy and seek to recover costs.
Comment: NJDEP was asked if the State would pay the costs,
regardless of which alternative is chosen, if Drew would not pay.
Response: Pending the availability of funding, EPA and NJDEP would
implement the remedy.
Comment: NJDEP should ask Ashland Oil to pay for Alternative 1.
Response: EPA and NJDEP are not seeking to implement Alternative 1.
Comment: Would Drew Chemical be absolved of all future liability if
the company paid for implementation of the selected alternative?
Response: No, they would not be absolved of future liability.
Comment: Several questions were asked about maintenance costs and
requirements including how the costs are calculated, what tasks are
included, who would supply the manpower, and whether the cost of
maintenance would be the responsibility of the municipal government.
Response: Operation and maintenance costs are calculated for a 30
year period. In this case the actual annual cost is expected to be
$93,000 after the first two years. Operation and maintenance costs
for the first two years will be about $108,000 because more sampling
will be done. The present worth represented by this is $903,000.
This cost includes treatment of landfill gases, treatment of the
leachate, monitoring, and maintenance of the complete system. The
estimate includes labor costs. The maintenance cost would be the
responsibility of the local government because they own the property.
12
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Future Land Use
Comment: NJDEP was asked for clarification of the provision for deed
restrictions.
Response: Basically, the goal of the deed restrictions is to
maintain the integrity of the cover material for the landfill. There
are some hazardous substances in the waste material at a depth of
five to ten feet. If that material were on the surface, it could
present a problem. Restrictions are required to prevent people from
digging it up.
Comment: The question was asked about what could be done with the
field in the future and whether it would be safe for young children
to play there, with the proposed stacks.
Response: The field can be re-opened at any time. There is no known
hazard associated with the surface soil on site. Extra care would
have to be taken if the Town decided to change the field by
installing a grandstand or a new refreshment stand. As indicated
earlier, the field will not be covered with stacks.
Comment: NJDEP was asked how long it would take to get approval for
future construction on the site by the Town.
Response: That would depend on what action was proposed. The NJDEP
would thoroughly review any requests by the Town prior to permitting
construction to proceed.
Comment: NJDEP was asked to clarify the preliminary design for the
trench that would be built to vent methane gas. Of particular
concern was its potential impact on the Town's plan to install a new
sewer line along Wootton Street.
Response: The barrier created by construction of the trench would
not interfere with sewer line installation.
Loss of Property Value
Comment: Concern was voiced that if Alternative 2 were selected,
property values would be lowered because of the presence of stacks
nearby as well as the fact that Alternative 2 is viewed as only a
containment action, rather than a removal of the wastes. NJDEP was
asked how this would affect the resale value of nearby properties,
and whether the State or Federal government would assume financial
responsibility for loss of property value.
Response: Alternative 2 has not been selected, however, there is a
State agency called the Environmental Claims Administration which may
be able to provide assistance. Information is available by writing
David C. Mack, Administrator, Environmental Claims Administration,
CN-402, Trenton, NJ 08625, or by calling 609-633-2947.
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Public Participation Process
Comment: By a show of hands as well as repeated comments, it was
evident that most residents of Boonton preferred Alternative 1.
NJDEP was asked what these people could do to have that choice.
Response: If the residents of Boonton feel an error in judgment has
been made, they can challenge the government in court.
Comment: The question was asked if the only recourse was to take the
government to court. The comment was made that the Town could have
settled this in court with Drew Chemical eight years ago.
Response: The Town may pursue any legal action against Drew Chemical
that it believes is appropriate.
Comment: A request was made for an extension of the public comment
period.
Response: The close of the comment period was extended from
September 13, 1989, to September 22, 1989.
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ATTACHMENT
COMMUNITY RELATIONS ACTIVITIES
FOR THE PEPE FIELD SITE
Community Relations activities conducted for the Pepe Field Landfill
to date have included:
* NJDEP made phone calls to local, County and State officials
announcing finalization of the Cooperative Agreement
(October 10, 1984).
* NJDEP prepared a community relations plan (November 1984).
* NJDEP held a public meeting at the Boonton Town Hall to
discuss initiation of the remedial investigation and
feasibility study (RI/FS) and to respond to citizens'
comments and questions. Approximately 100 people attended,
including residents and elected officials (April 16, 1986).
* NJDEP met with local officials to discuss the Phase I RI
report and plans for the Phase II sampling effort (July 31,
1987).
* NJDEP held a briefing for local officials to discuss the
status of the RI/FS (July 17, 1989).
* NJDEP held a public meeting at the Boonton High School to
discuss the results of the RI/FS and the remedial
alternatives and to respond to citizens' comments (September
6, 1989). Approximately 175 people attended, including
citizens and elected officials. A transcript of the meeting
is available at the Boonton-Holmes Public Library.
* NJDEP allowed an extension of the public comment period.
The comment period lasted from August 15, 1989 to
September 22, 1989.
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