Superfund Record of Decision Asbestos Dump OU 3 Millington NJ

                                    EPA/ROD/R02-98/053
                                    1998
EPA Superfund
     Record of Decision:
     ASBESTOS DUMP
     EPA ID: NJD980654149
     OU03
     MILLINGTON, NJ
     09/08/1998

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EPA 541-R98-053


                          RECORD OF DECISION
                                 for
                            Operable Unit 3
                                of the
                      Asbestos Dump Superfund Site

                  Great Swamp National Wildlife Refuge
                        Morris County, New Jersey

                             September 1998

                              Prepared for
                     U.S. Fish and Wildlife Service
              Environmental and Facilities Compliance Branch
                  12795 W. Alameda Parkway, Suite 215
                             P.O. Box 25287
                       Denver, Colorado 80225-0287
                              Prepared by:

                         SEA CONSULTANTS INC.
                       485 MASSACHUSETTS AVENUE
                  CAMBRIDGE, MASSACHUSETTS 02139-4018

               under contract to and in conjunction with



                FOSTER WHEELER ENVIRONMENTAL CORPORATION

                Foster Wheeler Environmental Corporation
                       143 Union Blvd, Suite 1010
                        Lakewood,  Colorado 80228
                 USFWS Contract No. 14-48-0010-93-004
                           Task Order 95-042

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DECLARATION FOR THE RECORD OF DECISION

SITE NAME AND LOCATION

Asbestos Dump Superfund Site
Operable Unit 3
Great Swamp National Wildlife Refuge
Harding Township, Morris County, New Jersey

STATEMENT OF BASIS AND PURPOSE

This Record of Decision (ROD) has been prepared for Operable Unit 3 (OU-3) of the Asbestos Dump Superfund Site,
located at the Great Swamp National Wildlife Refuge (GSNWR) in Morris County, New Jersey. The site is located
within the northcentral portion of a designated Wilderness Area along Great Brook, just east of Long Hill Road.
The location of the GSNWR is shown on Figure 1 of Appendix I, and OU-3 is located on Figure 2 of Appendix I.

The Asbestos Dump Superfund Site is composed of four properties (the Millington plant [OU-1], the New Vernon Road
and White Bridge Road sites [OU-2], and the former Dietzman Tract [OU-3]), and was added to the National
Priorities List (NPL) in September 1983 (CERCLIS No. NJD980654149). Remedial activities at OU-3 are completely
independent from the activities at OU-1 and OU-2. The United States Department of the Interior (DOI), acting
through the U.S. Fish and Wildlife Service (USFWS) , is the lead agency for the remediation of OU-3, and the
United States Environmental Protection Agency (EPA) is the oversight agency. This ROD documents DOI's and EPA's
selection of the remedial action for OU-3 and has been prepared in accordance with the reguirements of the
Comprehensive Environmental Response, Compensation and Liability Act of 1980, as amended (CERCLA), 42 U.S.C.
°9601 et seg. and to the extent practicable, the National Oil and Hazardous Substances Pollution Contingency Plan
(NCP), 40 CFR Part 300. The remedial action is intended to address the environmental risks that have been
observed to exist, based on the data summarized in the tables provided in Appendix II. An administrative record
for the site, established pursuant to the NCP, 40 CF 300.800, contains the documents that form the basis for
DOI's selection of the remedial action. An index of the administrative record is attached as Appendix III.

This document is the third ROD for the Asbestos Dump Superfund Site. The first ROD (EPA, September 30, 1988)
addressed asbestos contamination at the Millington Site (OU-1) where the selected remedy included the
installation of a soil cover and slope stabilization. The second ROD (EPA, September 22, 1991) selected the
solidification/stabilization and capping of asbestos contaminated soils at the New Vernon Road and White Bridge
Road properties (OU-2).

The New Jersey Department of Environmental Protection (NJDEP) has been consulted on the planned remedial action
in accordance with CERCLA °121(f), 42 U.S.C. °9621(f), and it concurs with the selected remedy (see Appendix IV) .
This document also provides a response to public comment of the Proposed Plan for OU-3 (USFWS, December 1997).
The Responsiveness Summary is provided in Appendix V, which also includes responses to NJDEP comments.

ASSESSMENT OF THE SITE

For many years, several discrete areas of OU-3 were used for the disposal of refuse collected from neighboring
communities. Along with refuse, asbestos containing material (ACM) and other industrial wastes from the former
National Gypsum Company (NGC) Plant in Millington, and possibly other sources, were trucked to the site and
landfilled. The disposal of ACM at OU-3 began in the early 1960s and continued until 1968 when the USFWS acguired
the property.

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OU-3 consists of three contiguous ACM disposal areas, including:

              Site A (a 5-acre ACM dump);

       •      Site B (a half-acre dump consisting of refuse covered with ACM);

       •      An unimproved access road  (UAR) ,  surfaced  with ACM,  leading to  Sites  A and B; and  three  small
              refuse areas (RAs)  adjoining Site B,  including:

              RA #1;

              RA #3; and

              RA #6

As part of  a  non-emergency removal action, 207 buried drums,  of which 69 contained  hazardous and solid  waste
products,  were  removed  from Site A in September 1997  (IT Corporation,  December 1997).  There  is no  evidence  to
suggest that  a  substantial release of contaminants occurred from  these  drums. Analytical  results from past
surface water, groundwater and soil  samples  located in the vicinity of  the drum removal  action  have  reported
detectable concentrations of hazardous substances in these media, some of which were subseguently identified as
components  of drum contents  (e.g. mercury,  trichloroethene (TCE)  , and  methylene chloride). During  the drum
removal action, however, potentially impacted soils were stockpiled for characterization prior to disposal.  In
addition,  the soil from the excavation pits was sampled to document  closure conditions. Post excavation sampling
indicated that the remaining contaminant concentrations in soil were below NJDEP soil clean-up  criteria and other
to be considered (TBC)  criteria and applicable or relevant and appropriate reguirements (ARARs). The stockpiled
soil was  also demonstrated to be  below applicable  clean-up  standards  (IT Corporation,  1997) .  The  minimal
concentrations of detected contaminants suggest only minor  releases of volatile organics and metals from  these
drums over time.

A baseline risk assessment performed for the site (Foster Wheeler,  May 1997) has determined lead to be the only
contaminant of risk to human health, whereas several metals  (barium, cadmium, chromium, lead,  mercury, thallium,
vanadium,  and zinc) were determined to pose the greatest  risk to ecological  receptors,  such  as certain species
of wildlife.  Extensive  environmental  testing  performed on  shallow  groundwater, surface water,  sediment,  soils
and biota  indicates that  the metals  arecontained  in soil  and ACM,  and  are  not leachable at  levels  above
regulatory  criteria used  to  classify the  tested  material  as a  hazardous waste or  transferable to  other
environmental media. Therefore,  the  route of exposure to  the  limited contaminants of risk  is through direct
contact with  soils or sediments.

In addition,  the baseline  risk assessment performed for OU-3  did  not  identify asbestos  as  a contaminant  of
concern (COG) under  existing  conditions. However, because  of the ubiguitous nature of  asbestos on  the surface
of the site,  and potential future  uses of the site,  all alternatives  for  remediating the site considered the
presence of asbestos at the surface.  The potential  future route of  exposure  to  high-risk levels of asbestos  is
primarily through inhalation.

DESCRIPTION OF THE SEIiECTED REMEDY

The response action at OU-3 needs to address the human health and environmental threats associated with the  three
contiguous disposal areas  and three small refuse areas.  The  selection of a remedy for OU-3  is complicated  by
several factors that are unigue to the site. These factors,  outlined in the Feasibility Study (SEA,  June 1997),
include variable surface water levels,  the objectives of the USFWS to provide adeguate environments for fish and
wildlife species, the  sensitivity  of these fish and wildlife  species  (some  of  which  are federally protected),
relatively weak and/or unstable subsurface soils,  and potential seismic (earthguake)  loads from a nearby  fault
zone.

Based on the  Feasibility Study evaluation,  an independent  value engineering study (Hanscomb,  June  1997),  and
additional data collected by USFWS (Foster Wheeler,  Pre-Design Data Report,  September 1997),  Alternative  3 was
selected as the  preferred remedy.  The major  components  of the selected remedy,  including those  partially  or

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totally addressed by interim removal actions in 1997 and early 1998, include the following:

• Removal and off-site disposal of buried drums (this work was undertaken and completed in
September 1997);

• Removal and off-site disposal of lead impacted soils (completed in Spring, 1998);

• Consolidation (partially addressed in Spring 1998) and Capping of ACM;

• Short-term Dewaltering and Water Diversion, and Long-term Drainage Improvements (partially
conducted in Summer 1997) ;

• Assessment of Wetland Impacts and Wetlands Restoration;

• Implementation of institutional controls to ensure the continued integrity of the drainage
improvements and capping activities (e.g. limiting visitor access to daylight hours,
prohibiting other than passive uses such as bird watching, hiking and photography); and,

• Appropriate environmental monitoring to confirm the effectiveness of the remedy (e.g. surface
water, groundwater and biota monitoring and sampling).

The selected remedial action, Alternative 3, will result in the protection of human health and the environment,
meets statutory reguirements under CERCLA, and complies with the selected ARARs. The selected remedial action
also coincides with the USFWS' desire to manage OU-3 as an integral part of the GSNWR.

DECLARATION OF STATUTORY DETERMINATIONS

The selected remedy designated as Alternative 3 meets the reguirements for remedial actions set forth in CERCLA
°121, 42 U.S.C. °9621: (1) it is protective of human health and the environment; (2) it attains a level or
standard of control of the hazardous substances, pollutants and contaminants, which at least attains the legally
applicable or relevant and appropriate reguirements (ARARs) under federal and state laws; (3) it is
cost-effective; (4) it utilizes permanent solutions and alternative treatment technologies to the maximum extent
practicable, and (5) it satisfies the statutory preference for remedies that employ treatment to reduce the
toxicity, mobility, or volume of the hazardous substances, pollutants or contaminants at a site.

A review of the remedial action pursuant to CERCLA ° 121 (c) , 42 U.S.C. °9621 (c) , will be conducted five years
after the commencement of the remedial action to ensure that the remedy continues to provide adeguate protection
to human health and the environment. The site may also be subject to a Deed Notice to comply with NJDEP
reguirements.

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Site:

Site name:

Site location:
RECORD OF DECISION FACT SHEET
US FISH & WILDLIFE SERVICE
Operable Unit 3 Asbestos Dump Superfund Site

Great Swamp National Wildlife Refuge, Harding
Township, Morris County, New Jersey
HRS score:
(for Asbestos Dump Superfund
Site, including OU-3)

Listed on the NPL:

Record of Decision:

Date signed:

Selected remedy:

Estimated Construction
Completion:
39.61
September 1983

Consolidation and Capping of ACM, Dewatering, Drainage
Improvements, Institutional Controls and Monitoring
December 31, 1998

Estimated $3,908,803 (in 1997 dollars)

Estimated $273,571 (NPV in 1997 dollars, 30 years assumed)
Capital cost:

Annual Maintenance cost:

Present-worth cost:

Lead Agency:

United States Fish and Wildlife Service, Environmental and Facilities Compliance Branch
Estimated $4,182,374 (NPV in 1997 dollars, 7% annual interest rate,
30 year maintenance period assumed)
Primary Contact:

Secondary Contact:

Main PRP:

Waste:

Waste type:

Waste origin:

Estimated waste
Quantity:
Ms. Krista A. Doebbler (303) 987-6807

Mr. Billy J. Umsted (303) 987-6801

National Gypsum Company (liability to U.S. settled in bankruptcy
proceedings)
Asbestos Containing Material (ACM) and Lead Contaminated Soil
and Solid Waste

OU-3 was used as a former dump site

Approximately 36,800 cubic yards of ACM and approximately 3,800
cubic yards of additional Lead Contaminated Soil and Solid Waste
Contaminated medium:
Soils
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RECORD OF DECISION
DECISION SUMMARY

Operable Unit 3 Asbestos Dump Superfund Site
Great Swamp National Wildlife Refuge

Harding Township, Morris County, New Jersey

Department of the Interior
United States Fish and Wildlife Service
United States Environmental Protection Agency

TABIiE OF CONTENTS
page
SITE NAME, LOCATION AND DESCRIPTION 1
SITE HISTORY AND ENFORCEMENT ACTIVITIES 2
HIGHLIGHTS OF COMMUNITY PARTICIPATION 5
SCOPE AND ROLE OF OU-3 RESPONSE ACTION 6
SUMMARY OF REMOVAL, ACTIONS AND INTERIM RESPONSES 7
SUMMARY OF SITE CHARACTERISTICS 8
SUMMARY OF SITE RISKS 14
REMEDIAL ACTION OBJECTIVES 19
DESCRIPTION OF REMEDIAL ALTERNATIVES 22
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 28
SELECTED REMEDY 33
STATUTORY DETERMINATIONS 35
DOCUMENTATION OF SIGNIFICANT CHANGES 37

ATTACHMENTS

APPENDIX I. FIGURES
APPENDIX II. TABLES
APPENDIX III. ADMINISTRATIVE RECORD INDEX
APPENDIX IV. STATE LETTER OF CONCURRENCE
APPENDIX V. RESPONSIVENESS SUMMARY
APPENDIX VI. LIST OF ACRONYMS
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LIST OF TABLES

TABLE 1 Summary Of Detected Contaminants - Drum Removal Post Excavation Sampling Results
TABLE 2 Listing Of Detections Exceeding TBCs In Soil Samples From Refuse Areas
TABLE 3 Summary Of Pre-Phase II Analytical Results For Soil Samples Collected by ESE
TABLE 4 Summary Statistics For Analytical Detections In Phase II RI Surface Soil Samples
TABLE 5 Listing of Analytical Detections Exceeding TBCs in Surface Soil Samples
TABLE 6 Summary Statistics for Analytical Detections in Phase II RI Subsurface Soil Samples
TABLE 7 Listing of Analytical Detections Above TBCs in Subsurface Soil Samples
TABLE 8 Summary of Results for Mercury and Lead Leachability Analyses of Surface and Subsurface Soil
Samples
TABLE 9 Summary Statistics for Analytical Detections in Unfiltered Phase II RI Groundwater Samples
TABLE 10 Asbestos Analytical Results for Phase II RI Groundwater Samples
TABLE 11 Summary Statistics for Analytical Detections in Phase II RI Sediment Samples
TABLE 12 Summary Statistics for Analytical Detections in Phase II RI Surface Water Samples
TABLE 13 Human Health and Ecological Contaminants of Concern
TABLE 14 Summary of Guidance Values and TBC Criteria Considered in Selection of the Site Specific
Cleanup Goals for Lead and Mercury
TABLE 15 Summary of Ambient Asbestos Air Monitoring

LIST OF FIGURES
FIGURE 1 Site Location Map
FIGURE 2 Great Swamp National Wildlife Refuge Map
FIGURE 3 OU-3 Summary Site Base Map
FIGURE 4 Regional Bedrock Geology Map
FIGURE 5 Schematic Geologic Cross-Section
FIGURE 6 Potentiometric Surface Map
FIGURE 7 Biotic Barrier Detail
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SITE NAME, LOCATION AND DESCRIPTION

Operable Unit 3 of the Asbestos Dump Superfund Site (OU-3) is located on property acquired for the Refuge and
formerly owned by Nicholas Dietzman (the former Dietzman Tract) , just east of Long Hill Road in the Great Swamp
National Wildlife Refuge (GSNWR) in Morris County, New Jersey. The GSNWR, as shown in Figure 1 of Appendix I,
is approximately 7,409 acres and is owned by the United States and managed by the United States Fish and Wildlife
Service (USFWS) for wildlife habitat and recreational uses. OU-3 lies entirely within Harding Township. The
location of OU-3 within GSNWR is shown on Figure 2 of Appendix I.

The Asbestos Dump Superfund Site was added to the National Priorities List (NPL) in September 1983 (CERCLIS No.
NJD980654149) and is composed of three distinct operable units. Remedial activities at the other operable units
(the Millington plant [OU-1] and the New Vernon Road and White Bridge Road sites [OU-2]) are independent from
OU-3. The remedial actions at OU-1 and OU-2 have been conducted by the Environmental Protection Agency (EPA) as
the lead agency. The United States Department of the Interior (DOI), acting through USFWS, is the lead agency
for the remediation of OU-3, while EPA is the oversight agency.

For more than fifteen years, several discrete areas of OU-3 were used for the disposal of refuse collected from
neighboring communities. Along with refuse, asbestos containing material (ACM) and other industrial wastes from
the former National Gypsum Company (NGC) Plant in Millington were trucked to the site for disposal. The disposal
of ACM at OU-3 began in the early 1960s and continued until 1968 when the USFWS acquired the property. The
discrete areas of OU-3 are shown on Figure 3 (Appendix I), and include:

Site A (a 5-acre, ACM dump);

• Site B (a half-acre dump consisting of refuse covered with ACM);

• An unimproved access road (UAR), which leads to Sites A and B; and

• Three small Refuse Areas (RAs) adjoining Site B.

OU-3 consists of contaminated areas located in wetlands and woodlands in the northcentral section of the GSNWR.
Site A is a 5-acre dump in which up to 70 to 80 percent of the filled material may lie below the water table
during peak surface water conditions (e.g. flood elevations). It is surrounded on the east, south, and west by
Great Brook and to the north by upland forest. Asbestos tile and siding fragments underlain by fibrous asbestos
are contained in the dump. The ACM is approximately 6 ft. thick in the central portion of Site A, 2-4 ft. thick
on the southern boundary, and 1-3 ft thick on the northeastern boundary (Foster Wheeler/SEA, June 1997). The
ground surface at Site A is also littered with refuse, urethane foam, asbestos tile, and scrap metal. Buried
drums were also formerly located at the site (Foster Wheeler, May 1997) , and were removed in September 1997 (IT
Corporation, 1997).

Site B is a one-half acre dump located in the upland section of the wetland area. There is a small palustrine
wetland on the northern portion of the site, however, the site is generally not saturated. The dump consists of
light gray to black mottled clay that is overlain by glass and metal debris and fibrous ACM. The ACM and refuse
are underlain by organic-rich clays and silty sands ranging in thickness from a few inches to several feet. The
average thickness of the asbestos material in Site B is 2 ft. and is underlain by a 2-ft. thick layer of metal,
glass and refuse, some of which contains elevated levels of lead and other metals (Foster Wheeler/SEA, June
1997).

The UAR is basically a 1,100 foot long path that begins at Long Hill Road and progresses northeast across OU-3
to just beyond Site B. The road averages about 17 feet in width and is surfaced with approximately 9 inches of
ACM cover (tile and siding fragments) . The total area of the UAR impacted by ACM is estimated to be about 0.4
acres (Foster Wheeler/SEA, June 1997).

The three RAs, RA #1, RA #3, and RA #6, comprise approximately 1.6 acres. RA #3 and RA #6 are located north of
the UAR, near Site B. RA #1 is located immediately northeast of the junction between Old Great Brook and the UAR.
The areas are comprised of scattered household refuse (metal and glass debris).
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GSNWR is located within the Great Swamp Watershed and the hydrologic setting of OU-3 is complex. Groundwater is
at or near the surface most of the year. Great Brook and large wetlands around Site A control local hydrology.
The old channel of Great Brook runs between Sites A and B, but flow was diverted in 1997 so that most water flows
clockwise around Site A, through New Great Brook or through a new channel extending south-southwest from upstream
of OU-3, and into the upper reaches of the impounded waters of Waterfowl Management Pool #1. The horizontal flow
gradient across much of the site is low and the water table nearly flat. Therefore, groundwater flow in the
shallow aguifer across OU-3 appears to discharge to Old and New Great Brooks.

In addition to the estimated 185,000 annual visitors to GSNWR, there are 440 residents within a one mile radius
of OU-3. However, most of these residents are upwind and hydraulically upgradient of OU-3. The Wilderness Area,
approximately 3,660 acres, where OU-3 is located serves as an outdoor laboratory: more than eight (8) miles of
hiking trails are available to the public for recreational purposes. The remaining 3,749 acres are designated
as a Management Area where various practices are implemented to sustain and enhance habitat.

The refuge trails, boardwalks, and observation facilities are open to visitors, however, they are only permitted
in designated areas and only during daylight hours. Trails are open to foot traffic only. Camping or collecting,
disturbing, or destroying plants or animals is strictly forbidden by USFWS.

SITE HISTORY AND ENFORCEMENT ACTIVITIES

Regarding site ownership, OU-3 and the surrounding area (about 104 acres) was entitled to Nicholas Dietzman in
1918. In 1967, Mr. Dietzman sold approximately 35 acres to USFWS, and the remaining portions of the tract were
sold to USFWS the following year.

During the 1950s and 1960s, ACM, household waste, and industrial waste materials originating from the NGC plant
in Millington, New Jersey, and possibly other sources, were deposited at the Asbestos Dump Superfund Site. In
addition, several refuse areas on OU-3 discussed above, had also been used to dispose of refuse collected from
neighboring communities.

The Asbestos Dump Site was included on the National Priorities List (NPL) on September 8, 1983. In September
1984, the U.S. EPA issued a notice letter to NGC notifying the company of its liability as a Potentially
Responsible Party (PRP) and offering it an opportunity to conduct a Remedial Investigation and Feasibility Study
(RI/FS). On April 1, 1985, EPA issued an Administrative Order to NGC to conduct the RI/FS for all of the sites
comprising the Asbestos Dump Site. The RI was performed in 1985 and 1986 and a report was submitted to EPA by
NGC in May 1987 (Hart, 1987).

EPA determined that the RI failed to adeguately characterize the nature and extent of contamination at two of
the three operable units, including OU-3. On October 28, 1990, NGC filed a voluntary bankruptcy petition under
Chapter 11.

OU-3 has been the focus of several additional investigations. A brief listing of the previous studies and reports
on OU-3 is appended to the Proposed Plan (USFWS, December 1997), as Attachment A. Pre-1996 analytical data were,
summarized and data needs were identified in the Phase II Remedial Investigation Work Plan (Foster Wheeler, July
1996). Separate from OU-3, five Areas Of Concern (AOCs, and subseguently referred to as Limited Action Areas or
"LAAs") located in Long Hill Township were investigated as part of the Phase II RI. The LAAs are not part of
OU-3, but are being addressed as part of DOI's response actions related to the Asbestos Dump Superfund Site.
These five LAAs included the Old Farm Road, Site #5, Site #7, the former McDonough Property and the Conroy
Property. OU-3 and the Old Farm Road are located within the Wilderness Area, and the four remaining LAAs are in
the active management area of GSNWR.

During the Spring and Summer of 1996, the Phase II RI was conducted to fill data needs, assess risks to human
health and the environment, and provide the necessary data for preliminary identification of remedial
alternatives for OU-3. The Final Phase II RI Report (Foster Wheeler, May 1997) summarized the results of field
investigations conducted at OU-3, and included a baseline risk assessment. OU-3 was found to contain about 36,800
cubic yards of ACM, 3,800 cubic yards of refuse debris, an estimated 207 buried drums at Site A, and areas of
metal-impacted soil and ACM.
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In September 1996, USFWS prepared an Action Memorandum for the Removal of ACM in four of the LAAs. The Kansas
City District Army Corps of Engineers (COE) prepared a Design Analysis and issued a Contract to implement the
ACM removal to address potential immediate threats to human health and the environment The work included
excavation and off-site removal actions and was conducted by the COE in the Fall of 1996. For two of the sites,
the Conroy and former McDonough properties, the removal effectively addressed about 95 percent of the delineated
ACM. The remaining ACM was covered and the area revegetated. No further action will be needed at these two sites.
For Sites #5 and #7, surficial ACM was also removed. However, some surface and subsurface ACM with no immediate
direct potential human exposure was left in place. USFWS will address subsurface and
surface ACM at Sites #5 and #7 and the Old Farm Road site in activities separate from the remedial action for
OU-3. Close-out documentation for these LAA removal actions will be provided upon completion.

In June 1997, USFWS completed a Feasibility Study (FS) Report (SEA, 1997). The FS Report outlined general
response actions that would satisfy the remedial action objectives for the site and recommended a remedial
action, taking into account:

• The contaminants of concern;

• All media of concern;

• All sources of concern;

• Exposure routes and potential receptors;

• Acceptable contaminant levels, ranges, or goals for each exposure route;

• Applicable or Relevant and Appropriate Reguirements (ARARs); and

• Community Acceptance.

In June 1997, the USFWS commissioned an independent value engineering study of the FS Report (Hanscomb, 1997).
The value engineering study generally validated the findings, conclusions and recommendations of the FS. The
major components of the recommended remedial action included the following:

• Removal of the buried drums (completed in September, 1997);

• Consolidation (underway Spring, 1998) and Capping of ACM;

• Removal and off-site disposal of lead impacted soils (completed Spring, 1998);

• Short-term Dewatering and Water Diversion, and Long-term Drainage Improvements (partially
conducted during Summer, 1997);

• Appropriate environmental monitoring to confirm the effectiveness of the remedy (e.g.
surface water, groundwater and biota monitoring and sampling);

• Implementation of institutional controls to ensure the continued integrity of the drainage
and capping activities (e.g. limiting visitor access to daylight hours, prohibiting other than
passive uses such as bird watching, hiking, and photography); and

• Assessment of Wetland Impacts and Wetlands Restoration.

The FS and value engineering studies also recommended the collection of additional pre-design data to reduce
uncertainty and confirm certain assumptions. The additional data was collected in the spring and summer of 1997
(Foster Wheeler, September 1997), and the drums were removed in September of 1997 (IT Corporation, December
1997).
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HIGHLIGHTS OF COMMUNITY PARTICIPATION

The RI report, FS report and Value Engineering Report for the site were released to the public when each report
was finalized. The Proposed Plan was issued for public comment on December 12, 1997 (USFWS, 1997) . These
documents were made available to the public in the USFWS administrative record file at the Refuge Liaison's
office and the information repositories at the Long Hill Township Free Public Library, 91 Central Avenue,
Stirling, New Jersey and the Harding Township Kirby Municipal Building, Town Clerk's Office, Blue Mill Road, New
Vernon, New Jersey. The notice of availability for the above-referenced documents was published in the
Echoes-Sentinel and Newark Star- Ledger on December 10, 1997 and in the Chatham Courier, Daily Record and
Observer-Tribune on December 11, 1997. The public comment period on these documents was held from December 12,
1997 to January 16, 1998 and extended upon reguest to February 27, 1998.

Throughout the Asbestos Dump Superfund Site's history, community concern and involvement have been high. For
OU-3, freguent informal meetings were the preferred method of information distribution reguested by the public
during early community relations scoping interviews. Conseguently, USFWS hosted three Community Information Open
House forums to which it invited all interested citizens and representatives of village and county agencies.
Guests were allowed to participate in informal discussions, presentations, and guestion-and-answer sessions. Many
of the public's concerns and guestions have been directly addressed during the planning, investigation, reporting
and feasibility phases of the project. Nine fact sheets have been distributed to a mailing list of over 150
interested parties. Periodic briefings have been held for several elected officials and a USFWS liaison position
and telephone hotline was staffed to facilitate information transfers.

On December 17, 1997, USFWS conducted a public meeting as reguired by CERCLA at Greenwood Village Fire Station,
529 Green Village Road, Green Village, NJ to inform local officials and interested citizens about the Superfund
process, to present the proposed remedy, review past removal activities at the site, and to respond to any
guestions regarding OU-3 from area residents and other attendees.

A Technical Assistance Grant was awarded by EPA to a stakeholder group on approximately February 16, 1998. The
Great Swamp Watershed Association will be able to use this grant to assist its participation in reviewing
response actions for all operable units of the Asbestos Dump Superfund Site, including OU-3.

Responses to the comments received at the public meeting and in writing during the public comment period are
included in the Responsiveness Summary (see Appendix V) . USFWS plans to continue public involvement and community
participation throughout the design and construction phases of the selected remedy.

SCOPE AND ROLE OF OU-3 RESPONSE ACTION

The major components of the selected remedial action are consistent with the remedy as evaluated in the FS and
validated by the value engineering study. The remedy will include:

• Removal of the buried drums from Site A (completed in September 1997) including post-
excavation and waste classification sampling;

Consolidation of ACM from Site B and UAR onto Site A (completed Spring, 1998);

• Covering of ACM at Site A with a biotic barrier;

• Removal and off-site disposal of lead impacted soil from Site B and RAs (completed Spring,
1998) including post-excavation sampling;

• Short-term Dewatering and Water Diversion, and Longterm Drainage Improvements (partially
completed during Summer 1997);

• Appropriate environmental monitoring to confirm the effectiveness of the remedy (e.g.
surface water, groundwater and biota monitoring and sampling);
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• Implementation of institutional controls to ensure the continued integrity of the drainage
and capping activities (e.g. limiting visitor access to daylight hours, prohibiting other than
passive uses such as hiking, bird watching and photography); and,

• Assessment of wetland impacts and wetland restoration.

The remedy addresses ACM, metal contaminated soils and reduces the potential for contaminated groundwater due
to the buried drums. Lead contaminated soil and debris (greater than 218 mg/kg of lead) at Site B and RA#1 and
RA#6 have been excavated and disposed off-site. Additional sampling to determine the distribution and
concentration of mercury contamination in soils at Site A was conducted to determine if "hot spots" existed which
merited the removal and disposal of such soils as hazardous waste. "Hot spots" were considered to be areas of
elevated mercury in soil or waste where the mercury was found to be leachable at levels above the RCRA toxicity
characteristic leaching procedure (TCLP) criteria (0.2 mg/L) or where it might exist at concentrations above the
RCRA universal treatment standards (UTS)(260 mg/kg)(40 CFR 268.40 Subpart D Treatment Standards). Based on the
results of all sampling, no areas of elevated mercury meeting this "hot spot" designation were found.

Risks posed by metals in Site A and ACM on site are being addressed through consolidation of Site B and UAR ACM
onto Site A and capping of the ACM through installation of a "biotic barrier". The biotic barrier is a
multi-layered cap with a protective biotic barrier layer to prevent burrowing animals from penetrating the cap,
and a vegetative layer to support vegetation and prevent erosion. Temporary dewatering to facilitate biotic
barrier construction, water diversion and drainage improvements to ensure long-term integrity of the containment
measure, and institutional controls are other components of the final remedy. The conditions at these areas pose
a threat to human health and the environment and required response actions are due to risks from direct ingestion
(metal contaminated soils), inhalation of asbestos fibers, and uptake of metals by ecological receptors.

SUMMARY OF REMOVAL ACTIONS AND INTERIM RESPONSES

Following completion of the OU-3 FS and value engineering phases, several interim response actions and removal
actions were identified as candidates for early implementation as risk reduction activities. These actions are
consistent with the NCP and EPA guidance which "emphasizes a bias for actions which eliminate, reduce, or control
site hazards as early as possible" (EPA 1990 - Guidance on Expediting Remedial Design and Remedial Action,
EPA/540/G-90/006, OSWER Directive 9355.5-02, August 1990). In addition, all of the activities conducted so far
were determined to be common components of several of the evaluated alternatives, and therefore would be
implemented at some point in any one of these candidate remedial alternatives which includes the selected
alternative. It was determined that each of these actions will help achieve compliance with ARARs or help to meet
remedial action objectives for the site.

Interim responses included improving site access and making drainage improvements. These were conducted as
necessary precursory steps for the two removal actions conducted at OU-3. Specific interim response actions taken
include the following:

• Two immediate response actions were performed to improve Site A access and to temporarily lower
surface water and enhance passive site drainage. Access to Site A was improved by upgrading the
surface of the UAR and clearing dense vegetation covering Site A. The site drainage was
enhanced by clearing the channel constriction and blockage where the UAR crosses the Old Great
Brook Channel northwest of Site A and placing a culvert system in the channel to maintain
vehicle access to Site B. These activities were conducted between July 29 and August 1, 1997
(IT Corporation, 1997).

• Interim drainage improvements were made by constructing a by-pass channel to divert Great Brook
surface water flow away from Site A toward Pool #1 at a point upstream from Site A and removing
channel blockages downstream of Site A in the New Great Brook channel leading into Pool #1 near
Long Hill Road. This was accomplished in early to mid-July 1997 by USFWS personnel using a
specialized aguatic excavator unit.
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Two Removal Actions were identified which addressed potential sources and contaminants of concern which were
considered to pose higher levels of risk relative to other conditions at OU-3. Specific actions which have been
taken or are underway at OU-3 include:

• Drum excavation, removal, and off-site waste disposal at Site A was initiated and completed in
September, 1997 (IT Corporation, 1997). The source control measure included excavation of 207
buried drums, and was undertaken as a non-emergency, time-critical removal action to eliminate
continued or future leaching of drum contents to groundwater. Sixty-nine of the 207 drums
contained product and were characterized for disposal. 50 of these drums were subseguently
designated hazardous waste and disposed off-site at permitted facilities. Post-excavation soil
samples were collected from the excavations, or the excavator bucket when the excavation was
greater than four feet in depth. Analytical results from these grab samples indicated results
below ARARs and To Be Considered (TBC) criteria, confirming that contaminants in drums had not
been released above regulatory standards before or during removal and indicating that
contamination of shallow groundwater is not a future concern (IT Corporation, 1997). TBC's
include criteria, advisories, guidelines or proposed standards developed by federal or state
programs that may provide useful information or recommended procedures if no ARARs address a
particular situation, or if existing ARARs do not provide the desired protection. These
standards were addressed as part of the evaluation of sampling results. A summary of
post-excavation sampling results is provided in Table 1 (Appendix II).

• Excavation, removal, and off-site disposal of lead-contaminated soils and debris
(concentrations greater than 218 mg/kg lead) at Site B, RA#6, and RA#1 was initiated in
February, 1998 and was completed in Spring 1998 (USFWS 1998). This latter action also includes
the consolidation of ACM from Site B onto Site A for future covering under the Site A biotic
cap described in the selected remedy. This step was reguired because the friable ACM at Site B
needed to be removed to gain access to the debris layer demonstrating elevated lead
concentrations.

In addition to the interim responses and removal actions taken in 1997 and 1998 at OU-3, a removal action was
completed in the fall of 1996 which addressed surficial ACM at four LAAs not considered part of OU-3 - the Conroy
Property, the former McDonough Property, Site #7 and Site #5 (USFWS, 1996 - Action Memorandum, COE 1996 - Design
Analysis and Scope of Work, and COE - New York District 1997 Close-Out Documents for ACM Removal at LAAs) . These
four LAAs, which fie in the Long Hill Township portion of Great Swamp NWR, were previously designated AOCs and
further classified as LAAs in the OU-3 RI/FS Work Plans (Foster Wheeler 1996). A supplemental interim removal
action is being initiated during the Spring of 1998 at Sites #5 and #7 to address residual surficial ACM. This
removal action coincides with the mobilization for the OU-3 removal action addressing the lead-contaminated soil
at Site B described above (USFWS 1998 - Action Memorandum).

SUMMARY OF SITE CHARACTERISTICS

Four primary sources of contamination were characterized at OU-3 during the Phase II RI. They include ACM present
throughout most of Sites A and B and the UAR; organic and inorganic waste materials formerly present in buried
drums at Site A; refuse/debris buried 2-3 feet below grade at Site B and scattered around the periphery of the
RA's with elevated levels of metals, particularly lead; and metals, particularly mercury, contained in the ACM
at Site A. The sources, concentrations and specific location of contaminants are discussed below.

1. Site Geology and Hydrogeology

Topography at OU-3 is flat, ranging from just over 235 feet to 228 feet in elevation. GSNWR is located within
the north-central Piedmont Physiographic Province and is underlain by sandstones and shales with minor
conglomerates and basalt. The northeast-trending syncline underlying GSNWR isbounded by the tectonically active
Ramapo Fault on the west and by ridges of resistant basalt forming the Watchung Mountains to the northeast, east,
and south. Present-day seismicity along the Ramapo Fault was recently manifested in the March 10, 1979
Bernardsville Earthguake (Richter magnitude 2.4). The epicenter for the event is estimated to be 1000 to 1500
ft west of OU-3.
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Unconsolidated deposits, consisting of glacial drift and glacial lake sediments, overlie bedrock at GSNWR. The
glacial lake deposits underlying OU-3 consist of low peRMeability, varved (laminated) silts and clays, and are
55-80 feet thick. The upper 5-15 feet of these sediments are swamp deposits with a locally high organic content.
Figure 4 presents a regional bedrock geology map of the GSNWR. area. Figure 5 shows a schematic geologic cross
section of the GSNWR local area.

GSNWR is in Great Swamp Watershed and the hydrologic setting of OU-3 is complex. Groundwater is at or near the
surface most of the year. Great Brook and large wetlands around Site A control local hydrology, where the shallow
groundwater and surface water show a strong interaction. A second, lower aguifer, exists in sand and gravel
beneath the thick varved clay layer. The deeper aguifer serves as a potable water source in the region. The
shallow groundwater is not used as a potable source near OU-3. The channel of Great Brook runs between Sites A
and B, but historically flow had been split so that some water flows clockwise around Site A in a new channel.
This flow has been partially diverted by water diversion elements of the interim actions described above. Site
A lies in the upper reaches of the impounded waters of Waterfowl Management Pool #1 when higher water levels are
retained.

The low permeability glacial lake deposits serve as a confining layer to the underlying sand and gravel deposits,
which constitute the deep aguifer beneath GSNWR. Shallow groundwater flow in the shallow aguifer across OU-3
appeam to discharge to Great Brook. Groundwater contained within the Site A waste mound discharges directly to
the Great Brook and wetlands surrounding the site. The horizontal flow gradient across much of the site is low
and the water table nearly flat (Figure 6, Appendix I) . Although an upward gradient has been widely reported for
the region, data collected during and after the Phase II RI indicated a seasonal downward flow component at OU-3.

2. Site Soils

The upper four to six feet of material at Site A consists of ACM (variable-sized pieces of asbestos
tiles/shingles, as well as fibrous and cemented masses of ACM) . Locally commingled with the ACM waste are
substantial amounts of other debris, including polyurethane foam fragments and metallic debris, and some native
soils. The upper 4-5 feet of material at Site B consists of 1-2 feet of fibrous ACM underlain by a 1-2 foot layer
of glass and metal debris. Approximately 40,600 cubic yards of ACM and refuse debris have, been delineated at
OU-3. Ninety-five (95) percent occurs at Site A where the majority of the ACM is non-friable. In contrast to Site
A, the majority of ACM at Site B is friable, but is only 1-2 feet thick. Less than one foot of non-friable ACM
covers the unimproved access road at OU-3.

Eight drums containing Resource Conservation and Recovery Act (RCRA)-hazardous levels of trichloroethene (TCE),
mercury and methylene chloride were excavated from Site A, removed and properly disposed during the Phase II RI.
Prior investigations also found drums with other wastes including corrosive liguids characterized as strong acids
(Hart, 1987) . Due to high water conditions during the Phase II field investigation, the full extent/number of
drums could not be determined at that time. Some excavated drums were in relatively sound condition while others
were severely deteriorated and leaking or even empty. Soil and groundwater sampling indicate these wastes
(specifically TCE and mercury and possibly methylene chloride) had been leaking into the environment (albeit,
at relatively low guantities up to that time). Using geophysical surveying technigues, additional suspected drums
were located. In September 1997, 207 drums were excavated from the site as an interim, non-emergency removal
action deemed necessary to eliminate potential impacts to groundwater from drum contents. The drum removal
activities also included site preparation, stabilization of the UAR and installation of a reinforced gravel
access road to Site A, temporary lowering of the surface water at OU-3, short-term dewatering, excavation of the
drums, and overpacking of 69 drums of waste (including 50 recovered drums containing product and 19 drums
containing Investigation Derived Waste), backfilling of the excavations and off-site disposal of the drummed
waste and asbestos-contaminated solid waste to approved facilities (IT Corporation, 1997).

Surface soils sampled at Site A during the Phase II RI contained levels of arsenic, lead, mercury, nickel,
thallium, and vanadium which exceeded guidance levels. The Phase II showed that Site B contains several metals
(primarily lead) in surface soils in excess of guidance levels. This contamination is less widespread in
subsurface soils, and appears to be limited to ACM and the underlying debris layer. Several isolated areas of
elevated metals contamination (especially lead) in surface soils adjacent to Site B are associated with RA#1,
#3, and #6.
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As a follow-up to the recommendations made in the FS, the Service took additional steps to delineate the extent
and potential leachability of the elevated lead found in soils at and near Site B and the elevated mercury levels
found in soils at Site A. During the pre-design data collection task, samples were collected at Site B and RA#6
and the results used to plan the removal action completed in late spring 1998. Also, mercury contaminated soil
sampling was done on a grid over Site A to determine overall distribution as well as to take follow-up samples
from suspected areas of elevated mercury to plan the scope and reguirements of the remedial alternative for Site
A. In addition, three follow-up samples were collected from the area where ruptured drums containing
mercury-contaminated wastes (up to 318 mg/kg mercury) were removed during the Phase II RI in 1996.

When the pre-Phase II RI data (Hart 1987 and ESE 1992) and Phase II RI data (Foster Wheeler, May 1997) are
combined with the pre-design data grid sampling and potential hot spot sampling (Foster Wheeler, September 1997),
there is substantial sampling density across Site A for mercury. Furthermore, the analytical results from
post-excavation samples from the 1997 drum removal can now be considered which support the conclusion that no
mercury "hot spots" (as defined in the Fate and Transport section which follows) exist within the soils at Site
A (see Table 1) (IT Corporation, 1997) that would reguire such soils to be considered hazardous waste under RCRA.

Soils remaining on site would therefore need to be considered for direct surface exposure but would not be
considered hazardous under RCRA nor considered leachable or have a potential to impact groundwater (not leachable
tinder RCRA TCLP).

Summaries of the soil data collected are provided in Appendix II of the ROD. Table 1 summarizes data from the
post-excavation samples from the drum removal action. Tables 2, 3, 4, 5, 6 and 7 summarize Phase II RI soil
analytical testing results. Table 8 summarizes results from analytical testing for leachability of metals in
selected site soils (Pre-Design Data Report, Foster Wheeler, 1997). Leachability tests using the RCRA toxicity
characteristic leaching procedure show that the metals in Site A soils do not leach at levels above RCRA
hazardous waste characteristic criteria. The analytical results, leachability tests, and additional discussion
of the distribution and behavior of mercury at Site A and lead at Site B is available in the "Contaminant Fate
and Transport" section and in the "Summary of Site Risks" section.

3. Groundwater

Shallow groundwater samples taken from Site A showed low level detections of contaminants suspected to be
originating from the formerly buried drums. Most of the Phase II RI groundwater sampling results from 1996 showed
good agreement with sampling conducted during the Site Assessment (ESE 1992) . There were detections of organic
compounds (benzene, TCE, and alpha-BHQ in excess of guidance levels in three Site A monitoring wells during the
Phase II RI. Metals were not a concern based on the Phase II RI results. Lead was detected in samples from seven
of fifteen monitoring wells. The maximum concentration detected (7.1 ug/L) was less than one-half the State
criteria. Mercury was detected in all six Site A monitoring wells, but none of the detections exceeded the State
criteria. Furthermore, mercury was found at lower levels in filtered samples than unfiltered samples, which
indicates that mercury present at Site A in ACM is not soluble or leachable. Sampling in 1997 of shallow ground
water taken from temporary wellpoints during a dewatering test on the Site A ACM mound showed no detections of
organic compounds, and inorganic constituents were below regulatory levels. Supplemental sampling of shallow
groundwater from Site A monitoring wells in 1997 prior to the drum removal action showed results comparable to
the 1996 Phase II RI results. The only organic contaminant above regulatory levels was alpha-BHC in one
monitoring well and metals were below guidance levels (Foster Wheeler 1997 -- Pre-design Data Report).

Unlike previous sampling, asbestos (with fibers greater than 10 microns in size) was not detected in any of the
site monitoring wells during the 1996 Phase II RI. Since several Site A monitoring wells are screened in ACM,
the lack of asbestos detections for fibers greater than 10 microns in size in Phase II RI groundwater sampling
has been attributed to use of the EPA-approved low-flow purging method. Sampling of shallow ground water pumped
from the central part of Site A during a dewatering test in 1997 showed detections of total asbestos fibers in
only 2 of 5 samples collected, but both were below EPA guidance levels. Shallow groundwater sampled from Site
A monitoring wells in 1997 prior to the drum removal action showed no detections in 3 of 5 wells sampled. For
the two wells where fibers were detected, the results were above the 7 million fibers per liter (MFL) standard.
However, the laboratory noted excess turbidity in the samples which suggested that sampling procedures could have
unnecessarily agitated the water column in the well, thereby elevating the asbestos fiber count (Foster Wheeler
1997 -- Pre-design Data Report). These results indicate asbestos fibers are not migrating through the Site A ACM
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wastes.Tables 9 and 10 provide a summary of statistics for analytical detections in unfiltered Phase II
groundwater samples, and asbestos analytical results, respectively.

The groundwater sampling plan was designed to assess the shallow aquifer groundwater quality only, and at Site
A specifically the monitoring wells provided samples of groundwater in direct contact with waste. As described
in the previous Site Geology and Hydrogeology section, there is a confining unit (approximately 60 feet in depth)
beneath the site. The aquifer below the confining layer is the most prevalent source of domestic well water for
the immediate vicinity. It is unlikely that contaminants would migrate downwards because of the confining layer
and seasonal artesian conditions. However, as there are several domestic drinking water wells in the vicinity
(albeit primarily upgradient or side gradient relative to OU-3), drinking water standards were considered as
ARARs,

4. Sediment

Phase II sediment sampling results correlated well with results from the 1991/92 Site Assessment. The only
contaminants detected in sediments above ecological guidance levels involved chromium, mercury, and nickel in
sediments immediately west (downstream) of Site A. ACM tile/shingle fragments were observed throughout much of
the new Great Brook channel surrounding Site A coinciding with the locations where the three metals were
detected. Aside from the channel adjoining Site A, contaminants were not detected above ecological screening
levels in either the old or new Great Brook Channel. Table 11 provides analytical results for sediment samples
collected during the Phase II RI.

5. Surface Water

Only two of 13 surface water samples collected at OU-3 during the Phase II RI exhibited detectable lead (both
below State criteria), and none revealed detectable asbestos. These findings were in contrast to findings
reported in the Site Assessment where anomalous lead and asbestos results were reported adjacent to and
downstream from Site A (ESE, 1992). One TCE detection exceeding guidance levels in surface water immediately
adjacent to the western part of Site A was also reported. That finding may have been indicative of minor leakage
from the buried drums which were subsequently removed. Methylene chloride was detected in most of the samples,
however, this is a common laboratory contaminant. Based on the concentrations and locations of the detections,
the compound was not believed to be a site specific contaminant.

Three inorganic analytes were detected above ARARs. Manganese was detected in 100 percent of samples, however,
these detections were believed to be reflective of naturally elevated concentrations based on background sampling
which also exceeded the ARAR by a factor of 2.5. Arsenic and thallium were each detected in one of fourteen
samples. While those concentrations exceeded ARARS, these analytes were not included as contaminants of concern
in the risk assessment as surface water was not a human health exposure pathway at the site and the distribution,
total detections and concentration of these analytes did not meet screening criteria as ecological contaminants
of concern. See the "Summary of Site Risks" section for additional discussion. Table 12 summarizes Phase II
surface water analytical results.

6. Air Quality

A year-long air quality study was conducted at OU-3 in 1996. Weekly air sampling from six monitoring stations
located throughout Sites A and B detected asbestos fibers at concentrations exceeding EPA background levels in
only one out of 419 samples. That detection occurred March 28, 1996 at a station located adjacent to Site B. That
detection slightly exceeded the EPA background level for indoor air quality for school building occupancy.
Further comparison to OSHA exposure standards shows the detection below the 8-hour time-weighted average
concentration. It should be noted that test pits were excavated at both Site A and Site B during the last two
weeks of June and snapping turtles were actively nesting at Site A in early to mid-June. Both activities
substantially disturbed soils at Site A near the active air monitoring stations, yet levels were not elevated
above standards. Air monitoring conducted during the 1997 drum removal activities showed no detections at
perimeter stations and only two readings above standards within open excavations. Workers at these two
excavations were fully protected with personal protective equipment.

7. Contaminant Fate and Transport
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Concentrations of asbestos, lead, mercury, and TCE were detected in several media at OU-3, with the potential
to migrate unless the sources are eliminated or isolated. The primary sources of these contaminants are
summarized as asbestos in Site A and Site B, lead in Site B surface and subsurface soils and in some RA#6 soils,
mercury in Site A surface soils and some drums, and TCE in some Site A drums. Based on OU-3 ' s hydrologic setting,
several primary, potential mechanisms for contaminant transport exist (e.g. leaching of contaminants such as TCE
from deteriorated drums into groundwater, erosion of ACM or contaminated soil and suspension in surface waters,
or airborne transport of asbestos fibers or contaminated soil particulates). Phase II RI air guality monitoring
and groundwater and surface water sampling results have shown that currently, these physical transport mechanisms
are only weakly active in the pathways sampled at the site. However, the potential exists for contaminant
transport to continue or increase in the future if non-friable ACM deteriorates to a friable form. The drum
removal activity completed in September 1997 was conducted to reduce the risk for releases to environmental media
from damaged or deteriorated drums. The removal of lead-impacted soils and debris from Site B and Refuse Areas
which was completed in late Spring 1998 was conducted to reduce the risk of direct exposure and reduce the risk
of additional environmental releases.

Following the completion of the RI and FS, the distribution of mercury in soils at Site A was characterized to
further reduce some uncertainty and gather pre-design data to determine if "hot spots" existed which merited the
disposal of such soils as hazardous wastes (see discussion in Section 2 - Site Soils) . "Hot spots" were
considered to be areas of elevated mercury in soil or waste where the mercury was found to be leachable at levels
above the RCRA TCLP criteria (0.2 mg/L) or where it might exist at concentrations above the RCRA universal
treatment standard (UTS) (260 mg/kg) (40 CFR 268.40 Subpart D Treatment Standards). Based on the results of all
sampling, no areas of elevated mercury meeting this "hot spot" designation were found. Since no mercury was found
above the RCRA action levels (TCLP or UTS) which would be classified as RCRA hazardous waste, the
mercury-contaminated soil and ACM waste mound to be covered in place at the site would not be considered a RCRA
hazardous waste landfill. The only material which exceeded either criteria was the single drum of
mercury-contaminated waste (reported to contain mercury at 318 mg/kg) which was removed and disposed of as
hazardous waste during the Phase II RI (Sample SWS02101) .

Most inorganic mercury compounds have low solubility and under most natural conditions, there is little soluble
inorganic mercury. The presence of low concentrations of mercury below regulatory standards in groundwater at
Site A supports this because lower concentrations were found in filtered samples than unfiltered ones. Slightly
elevated concentrations of mercury in downstream fish tissue, however, suggests that mercury present at elevated
levels in soils and possibly from drums previously at Site A is capable of migrating into nearby environmental
media because it is exposed to erosion from the surface of Site A. Leachability tests on soil samples during the
1997 pre-design sampling indicates elevated mercury in ACM and soils at Site A is not soluble or leachable
(Foster Wheeler, 1997) (Table 8). The low levels of mercury detected in post-excavation samples during the 1997
drum removal further supports that the mercury at Site A is not leachable.

From the perspective of migration and transport, chlorinated volatile organic compounds such as TCE which were
found at high levels in the formerly buried drummed waste in direct contact with groundwater at Site A posed a
significant potential threat to groundwater and surface water.TCE can leach into groundwater fairly readily. The
present data suggests that significant TCE releases did not occur prior to the removal of the buried drums.
Post-excavation samples (IT Corporation, 1997) demonstrated that drums had not released significant
concentrations of volatile organic compounds into Site A soils either before or during removal (Table 1).

SUMMARY OF SITE RISKS

Based upon the results of the RI, a baseline risk assessment was conducted to estimate the risks associated with
current and future site conditions. The baseline risk assessment estimates the human health and ecological risk
which could result from the contamination at the site if no remedial action were taken.

The baseline human health risk assessment evaluated risks associated with exposure to contaminants from ingestion
of surface soils, surface water, and groundwater, and contaminants from inhalation of asbestos. Based on
available regulatory values and guidance, only lead in OU-3 surface soils was shown to be a final human health
contaminant of concern (COG).

The ecological risk assessment evaluated risks to target species based on modeling ingestion of contaminants and
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found that several metals, but primarily lead and mercury, were final COG's. The discussion of the human and
ecological health risks involved in the site are discussed below. Table 13 summarizes the human health and
ecological receptors final COCs. Table 14 lists the guidance values and TBC criteria that were used in the
development and selection of the clean-up goals for the COCs lead and mercury to protect both human health and
ecological receptors at the site.

Human Health Risk Assessment

USFWS conducted a baseline risk assessment to evaluate the potential risks to human health and the environment
associated with the OU-3 Asbestos Dump site in its current state. The human health risk assessment used a
five-step process described below to evaluate information in assessing risk. The Risk Assessment focused on
contaminants in the surface soil, surface water, groundwater, and ambient air which are likely to pose
significant risks to human health and the environment. Of the four COG's identified in surface soil on site
(lead, beryllium, arsenic and total polycyclic aromatic hydrocarbons (PAHs)), only lead was considered to be a
final COG. The other inorganics, including mercury, were not chosen as COCs based on both the gualitative and
guantitative risk analysis described below. A more complete discussion of this process can be found in the RI,
Appendix H. There were no COC's for human health identified in surface or groundwater.

A five-step process was utilized to assess site-related human health risk from exposure to contaminants present
at the site. The steps included: COG identification—identifies the contaminants of concern, based on several
factors including freguency of occurrence, concentration and comparison to site background and EPA risk-based
screening levels. Exposure Assessment -- estimates the type and magnitude of exposure to human populations,
through characterization of the exposure setting, determination of potentially exposed populations,
identification of exposure pathways, and estimation of exposure point concentrations. Toxicity
Assessment—identifies the chemical specific adverse health effects and the relationship between the magnitude
of exposure (dose) and adverse effect (response). Risk Characterization-- summarizes the combined outputs of the
exposure and toxicity assessment to provide a guantitative assessment of site-related risks. Uncertainty
Analysis-- evaluates the sources of uncertainty associated with the data, default parameters, calculations and
toxicity information used to estimate risk.

The baseline risk assessment addressed the potential risks to human health by identifying several potential
exposure pathways by which the public may be exposed to contaminant releases at the site under current and future
land-use conditions. However, given current limits to access within the Wilderness Area, and the likelihood for
the site to continue its present status as a Wilderness Area in a wildlife refuge, there was not a significant
distinction between present vs. future land use. The pathways that represent patentially complete exposure routes
for humans include ingestion of surface soils during work-related or trespass-related activities and inhalation
of contaminated soils and particulates during wind/dust storm events. Although workers or trespassers are
unlikely to consume surface water or groundwater on site, these media were evaluated in response to strong
community concerns about this potential pathway.

For this risk assessment, the chemical detections in abiotic media were evaluated by comparison of exposure point
concentrations (i.e. the medium-specific maximum detected COG concentration) to target levels (MCLs, which are
based on human health impacts) and EPA risk based soil screening levels (SSLs). The EPA SSLs were used as a
conservative approach to screen contaminant concentrations in surface soil, as the default assumptions are chosen
to be protective of human health for most site conditions and assume a residential exposure scenario. Chemicals
that exceeded the SSLs (arsenic, barium, beryllium, manganese, mercury, thallium, vanadium, total PAHs, and
Aroclor 1248) were evaluated guantitatively for cancer and non-cancer risks through estimation of chemical
intakes from ingestion for three exposure populations - biological worker, and adult and child trespassers.
Inhalation exposure to mercury was also evaluated for the three exposure populations. For the carcinogenic
chemicals, arsenic, beryllium, and total PAHs produced cancer risk values within EPA's target risk range of 10
-6 to 10 -4, for which cancer risks are managed, for the biological worker only. Benzo(a) pyrene and Aroclor 1248
produced cancer risk values below 10 -6.

Noncarcinogenic risks for arsenic, beryllium, barium, manganese, mercury, thallium, and vanadium produced hazard
guotient values less than 1.0 for all three populations. As noted above, lead was the only soil contaminant which
was determined to be a COG. Lead concentrations in six of the 41 samples exceeded the New Jersey industrial soil
cleanup level, and the arithmetic mean of the lead concentrations was above residential cleanup levels. The
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exceedances were detected in soils clustered around or adjacent to Site B. Mercury concentrations in soil
produced noncancer quotient values for both ingestion and inhalation that were well below the benchmark value
of 1.0. Additionally, during the RI field program, hundreds of measurements were taken of site soils with a
portable mercury vapor analyzer. No detections were recorded, which indicates that human exposure to volatile
mercury is not a concern at OU-3. The results of the human health risk assessment were based on surface soils
at the 0-2 ft. interval and a data set that had been validated, which may be a subset of the field sampling data
provided in tables found in Appendix II. Validation of data followed EPA guidelines. The information presented
in the tables is for contamination extent, and is not the database used for the risk assessment.

Ambient air sampling results are presented in Table 15. Only ten samples from the on-site sampling stations
during the Phase II RI had detections of asbestos fibers, and these were generally at the laboratory detection
limit of 15.4 f/mm 2 . Of the samples where asbestos was detected, only one (March 28, 1996 at Station 7 near Site
B) had fibers present at levels above the EPA background level. Based on the available analytical results, the
risk from inhalation of asbestos fibers at OU-3 is very low, as one sample exceeded the EPA's maximum allowable
asbestos level for air in school buildings. The IRIS cancer slope factor for asbestos is based on fiber counts
using the phase contrast microscopy (PCM) methodology, which is non-specific for asbestos and will measure any
fibrous material. Transmission electron microscopy (TEM) was used at the site, because it is specific for
asbestos fibers and there was significant potential for nonspecific fiber contamination. It is inappropriate,
according to the IRIS database, to apply the cancer slope factor to measurements made by other analytical
techniques. For this reason, we used an EPA benchmark value for asbestos in school buildings. The EPA background
value or maximum allowable asbestos level at which air within school buildings is considered clean and the
building accessible was used for the evaluation of the TEM results. This is a benchmark value, therefore it is
inappropriate to assign a cancer risk associated with one sample which had a slight exceedance of the benchmark
value out of 419 samples obtained.

In summary, the estimated human health risks at OU-3 are primarily due to direct exposure to lead. The lead
concentrations only slightly exceed the EPA residential soil cleanup level of 400 mg/kg (EPA 1994, OSWER
Directive 9335.4-12). Based on Phase II RI data and considering the findings of prior risk assessments, present
conditions do not appear to pose significant risks to biological workers and trespassers who may visit the site
periodically and participate in non-intrusive activities. Were significant physical alteration of the land to
occur, it could produce conditions where risk levels could increase. However, this is considered unlikely given
the site's status as a Wilderness Area. A more complete description of the Human Health Risk Assessment can be
found in Appendix H and Section 6.3 of the Phase II Remedial Investigation Report.

Ecological Risk Assessment

A multiple step process was utilized for assessing the potential effects of site contamination on wildlife at
OU-3. The site characterization included a wildlife survey, benthic and fish community surveys, and
characterization of habitats present at the site. The Assessment and Measurement endpoints provided evaluation
of benthic invertebrate and fish community structure, mammalian and fish body condition and a quantitative
assessment of wildlife exposure concentrations. Representative Receptors were chosen to model risk for multiple
trophic levels for which complete exposure pathways exist. Exposure Pathways identified the routes by which
biological receptors become exposed to the contaminated source media. Identification of COCs chose chemicals to
be evaluated based on frequency of detection, comparison with background concentrations, and toxicological
properties. Exposure Assessment evaluated the data by comparison to state and federal regulatory and
to-be-considered guidance documents and evaluation of fish, frog and mammalian tissue contaminant concentrations.
The Risk Characterization evaluated the chemicals selected as potential COCs in the exposure assessment and
quantitatively evaluated risk to six representative receptors. The Uncertainty section presents the source of
uncertainty associated with the data, toxicological literature information and calculation of risk for the chosen
species.

Both qualitative and quantitative evaluations were used to measure the impact of contaminants on wildlife found
on or near the site. These evaluations included a wildlife survey, a benthic invertebrate community analysis,
fish condition and community analysis, mammalian necropsy and histopathological analysis, wildlife tissue
analyses and a quantitative risk assessment which modeled risk to receptor species (white-footed mouse,
cottontail rabbit, American Robin, red fox, great blue heron and mink) from direct ingestion of contaminated
soils alone. The surface water and groundwater detections were compared to three benchmark values for selection
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of potential COCs. None of the detections exceeded the benchmarks and therefore were not carried through to the
quantitative analysis. In addition, a site specific risk analysis from ingestion of both dietary prey items and
soil/sediment was performed for the great blue heron and mink assuming consumption of soil/sediment using the
highest detected concentrations in the fish and frog tissue samples. Lead and mercury were considered the
definitive drivers of potential risk for the site based on the elevated Hazard Quotient values for the great blue
heron and mink.

Overall, findings indicated that the potential risk to ecological receptors under conditions present at the time
of the risk assessment is limited to a few COCs found at levels above ecological screening levels. The
predominant ecological risk drivers are lead at Site B and mercury at Site A from direct exposure and ingestion
of soils. Barium, cadmium, copper, chromium, nickel, selenium, thallium, vanadium, zinc and Arochlor 1248
represent lesser contributors to the estimated risk based on modeling exposure for the representative receptors
and tissue concentrations found in fish, frogs, and mamalian species. Modeling of risk, based on the contribution
from soil ingestion alone, shows that under current conditions, some species will continue to experience some
risk from metals at OU-3, particularly at higher levels in the food web. The local wildlife communities have been
impacted and would likely continue to be adversely impacted by the site, but OU-3 does not appear to be causing
acute impairment or a widespread regional problem. Elimination of the direct exposure pathway from contaminant
sources to wildlife would significantly decrease the risks associated with the OU-3 site. Approaches to eliminate
wildlife exposure pathways are addressed under the Remedial Action Objectives section. A more complete
description of the Ecological Risk Assessment can be found in Appendix E and Section 6.2 of the Phase II Remedial
Investigation Report.

Uncertainties in the Risk Assessment

The procedures and inputs used to assess risks in this evaluation, as in all such assessments, are subject to
a wide variety of uncertainties. It is considered sound practice to assess the type of degree of uncertainty
associated with the data and assumptions used in risk assessments. In general, the main sources of uncertainty
include:

• environmental chemistry sampling and analysis;

• environmental parameter measurement;

• contaminant fate and transport modeling;

• exposure parameter estimation; and

• toxicological reference data.

Uncertainty in environmental sampling arises in part from the potentially uneven distribution of chemicals in
the media sampled. Conseguently, there is significant uncertainty as to the actual levels present. For this risk
assessment, maximum detected concentrations were used for comparison to the final guidance values. This approach
is conservative as compared to traditional risk assessments, where the 95% Upper Confidence Limit (UCL) on the
arithmetic mean is used as the concentration term. When statistical analysis of multiple samples is performed,
the mean can be an order of magnitude less than the maximum concentration.

Environmental chemistry-analysis error can stem from several sources including the errors inherent in the
analytical methods and characteristics of the matrix being sampled. In addition, the chemical specific guidance
values and EPA SSLs for some of the inorganic constituents were below or similar to background levels of
chemicals in soils. This approach tends to overestimate risk based on chemical concentrations that may only
slightly exceed background concentrations. Uncertainty of contaminant fate and transport between various media
results from uncertainty regarding chemical species and their distribution in the various media.

Uncertainties in an exposure assessment are related to estimates of exposure parameters such as how often an
individual would actually come in contact with the chemicals of concern, the period of time over which such
exposure would occur, and in the models used to estimate the concentrations of the chemicals of concern at the
point of exposure. For a biological worker, the assumption was made for a presence at the site for 250 days per
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year for 25 years, which is extremely conservative when realistic work assignments and career durations are
considered. Also, the conditions and samples collected for the risk assessment may not reflect overall the
average concentrations seen in the soil and water resources due to the high amount of precipitation in 1996.
Surface water concentrations may have been decreased due to dilution.

Because 1996 was unusually wet, the ambient air concentrations of asbestos under some of the sampling conditions
may not reflect average concentrations over several years duration. Due to the dust suppression effect of rain,
snow, and high water events as well as lusher vegetation, the risk associated with asbestos inhalation may have
been underestimated. However, follow-on air guality sampling during drier conditions in 1997 during the drum
removal action at Site A supports the findings of the 1996 sampling events. Calculation of the potential risk
from exposure to subsurface soil contamination and the contents of buried drums could not be specifically
addressed in the risk assessment due to the lack of a documented complete exposure pathway to humans or
ecological receptors.

More specific information concerning public health risks, including a guantitative evaluation of the degree of
risk and the uncertainty analysis associated with various exposure pathways, is presented in the Risk Assessment
Report.

REMEDIAL ACTION OBJECTIVES

Remedial action objectives (RAOs) are specific goals to protect human health and the environment; they specify
the contaminant(s) of concern, the exposure route(s), receptor (s), and acceptable contaminant level(s) for each
exposure route. These objectives are based on available information, site specific ARARs, TBCs, and risk-based
levels established during the risk assessment and feasibility study. RAOs include several site-specific cleanup
goals which are defined as medium-specific numerical concentrations established on an operable unit specific
basis at levels considered protective of human and ecological receptors for a specified exposure route.
Protectiveness may be accomplished by reducing exposure in the specific pathway by any of several methods or
combinations of methods called alternatives, which are summarized and evaluated in the Alternatives Analysis
sections. Follow-on interim actions and removal actions which have been completed to address risks at OU-3 and
partially or totally meet one or more RAOs are noted in this listing.

All medium-specific and source-specific RAOs include meeting Federal and State ARARs. In addition, the following
medium-specific remedial action objectives were established:

Groundwater

• Prevent ingestion of impacted groundwater;

• Restore the shallow overburden groundwater at the points of compliance (drum removal at Site A
eliminated many potential sources of organic contaminants);

• Prevent the spread of contamination to unimpacted portions of the shallow overburden
aguifer (drum source removal activities have addressed this objective);

• Minimize the impact to site wetlands; and

• Demonstrate shallow groundwater guality through surface water and shallow aguifer
groundwater monitoring, and maintenance of related remedial actions.
Surface Water
Protect unimpacted surface water by preventing the occurrence of disposal area seeps (drum removal
has addressed the source of volatile organic compounds at the western side of Site A) ;
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• Demonstrate that no related impacts occur in the future through monitoring of the surface
water along Great Brook and in the wetlands adjacent to disposal area Site A; and

• Minimize, as practicable, the impact to site wetlands.

Sediment

• Protect unimpacted sediment by preventing the migration of contaminants through surface
water;

• Prevent unacceptable risks associated with impacted sediment (i.e., mercury and asbestos in
sediment around Site A) .

• Demonstrate that no related impacts occur in the future through monitoring of the sediment
along Great Brook and in the wetlands adjacent to disposal areas Site A and Site B; and

• Minimize, to the extent practicable, the impact to the site wetlands, in accordance with
applicable requirements for the protection of wetlands, floodplains, riverways, and wildlife
species.

Air

• Protect unimpacted air by preventing the migration of airborne contaminants; and

• Provide monitoring of air quality during remediation activities to assure that no related
impacts occur in the future.

Soils

• Prevent unacceptable risks associated with impacted soils by eliminating direct exposure to
humans and wildlife (e.g. excavation and removal, containment by covering or capping,
perimeter fencing, etc. are a few possible alternatives among the many available that would
eliminate or reduce direct exposure). (Note: the removal of lead impacted soils completed ii
late Spring 1998 at Site B and RAs has partially addressed this objective);

• Prevent the spread of contamination to unimpacted medium during and following remediation;

• Minimize, as practicable, the impact to site wetlands; and

• Provide monitoring and maintenance of the related remedial actions.

In addition, the source specific objectives included the following:

• Reduce the potential for precipitation to percolate through the debris mass;

• Reduce the potential for groundwater and/or surface water to contact or infiltrate through
the debris mass (the surface water lowering from drainage and diversion actions has
partially addressed this objective);

• Prevent the generation of disposal area seepage (the drum removal action at Site A has
addressed this objective);

• Prevent direct contact with and ingestion of soils and debris within the disposal areas;

• Control gas emissions so that explosive gases (e.g. methane) do not represent a hazard;
prevent the inhalation of gas-containing hazardous substances, pollutants, or contaminants;
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• Minimize the potential for slope failure of the disposal areas or any future action;

• Minimize the potential for excessive settlement of the disposal areas due to any future
action or seismic occurrence;

• Minimize the impact to site wetlands; and

• Provide long-term monitoring and maintenance of the disposal area remedial actions to assure
that gases and water are being properly controlled and that the remedy is functioning
properly.

DESCRIPTION OF REMEDIAL ALTERNATIVES

CERCIA °121(b)(1), 42 U.S.C. °9621(b)(1), mandates that a remedial action must be protective of human health and
the environment, be cost effective, and utilize permanent solutions and alternative treatment technologies or
resource recovery technologies to the maximum extent practicable. Section 121(b)(1) also establishes a preference
for remedial actions which employ, as a principal element, treatment to permanently and significantly reduce the
volume, toxicity, or mobility of the hazardous substances, pollutants and contaminants at a site. CERCLA °121(d),
42 U.S.C. °9621(d), further specifies that a remedial action must attain a level or standard of control of the
hazardous substances, pollutants, and contaminants, which at least attains ARARs under federal and state laws,
unless a waiver can be justified pursuant to CERCLA °121(d)(4), 42 U.S.C. °9621(d)(4).

The FS evaluation of alternatives for site remediation involved two major phases: the Development and Screening
of Alternatives, and Detailed Analysis of Alternatives. In order to address the RAOs for the site, a wide range
of technologies and process options were screened for possible use at the site. Final technologies were selected
only if they could meet the overall project objectives. Several broad technology types or process options were
identified and each was evaluated with respect to the effectiveness, implementability and cost. For example,
these technologies included the installation of sheeting and slurry walls, solidification, thermal treatment,
encapsulation, several innovative technologies and total removal.

Many of these technologies did not pass the screening stage for various technical, cost, or implementability
reasons. One innovative technology involving a type of vitrification (thermal treatment resulting in an
asbestos-free glass) was bench tested. The technical result of the test was promising, but the capital costs,
permitting expenses and operating costs were prohibitive.

The technologies that passed the screening process were grouped together to develop six alternatives to remediate
the site. These alternatives were further evaluated against the criteria established by the NCP and described
above.

The FS evaluated six remedial alternatives for addressing the contamination associated with OU-3. The remedial
alternatives, as well as the associated estimated costs and implementation time frames, are each described below.
The time frames provided are approximate implementation periods and include reasonable assumptions for planning
and design. Some planning and design work takes longer to complete, depending on the complexity of the
alternative. Operation and maintenance (O&M) periods were estimated as a present-worth cost for a 30-year period
in accordance with ARARs. The time to implement a remedial alternative reflects only the time reguired to
construct or implement the remedy and does not include the time reguired to design the remedy, negotiate with
the responsible parties, or procure contracts for design and construction, or conduct operation and maintenance
at the site. The remedial alternatives were:

Alternative 1 - No Action:

Capital Cost: $0
Operation and Maintenance Cost: $95,654
Present-Worth Cost: $95,654
Implementation Time: None

CERCLA and the NCP reguire the evaluation of No Further Action as a baseline to which other alternatives are
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compared. No active remediation or containment of asbestos or other site contaminants would be performed.
Monitoring of the site is planned, which explains the estimate for O&M costs without a capital cost. That
monitoring is only consistent with surface water monitoring and wildlife management as currently practiced under
standing Refuge management plans.

Alternative 2 - Institutional Controls and Monitoring:

Capital Cost: $20,680
Operation and Maintenance Cost: $285,049
Present-Worth Cost: $305,729
Implementation Time: 3 months

Alternative 2 includes institutional controls along with limited O&M activities. Surface water monitoring and
wildlife management would be conducted by Refuge personnel as currently practiced. In addition, monitoring would
also include air sampling.

Current institutional controls, such as securing deed restrictions, restricting site access, and securing land
use restrictions, are in-place and would have to be maintained to conform to the intent of this remedial
alternative.

Future use of the Site would be restricted in accordance with the exposure assumptions used in the baseline risk
assessment to provide assurance there would be no inappropriate use of soils, surface water, or groundwater at
the site. Modification to the Refuge Management Plan would be needed to document any public use or personnel use
restrictions.

This alternative would require a review of the remedial action every five years pursuant to CERCLA Section 121(
c ), 42, U.S.C. Section 9621 ( c ), because implementing this alternative would result in hazardous substances
remaining on-site above health-based levels. Additional remedial actions could be required depending on the
results of such a review.

Alternative 2A - Drum Removal, Dewatering, Institutional Controls and Monitoring:

Capital Cost: $693,909
Operation and Maintenance Cost: $285,049
Present-Worth Cost: $978,958
Implementation Time: 6 months

Alternative 2A is similar to Alternative 2, with the addition of temporary dewatering and drum removal. The same
O&M activities described above would also be implemented. Long-term monitoring of the site would include surface
water and biota sampling, as is the current Refuge management practice. Air sampling would also be initiated.

The drum removal activities completed in September 1997 included site preparation, stabilization of the
Unimproved Access Road and installation of a reinforced gravel access road to Site A, lowering of the surface
water at OU-3 by channel improvements in the Old Great Brook channel, short-term dewatering through localized
sump pumps, excavation of 207 drums (both empty and containing wastes) , and overpacking of approximately 50 drums
of waste (and an additional 19 drums of investigation derived waste), backfilling of the excavations, and
off-site disposal of the drummed waste and asbestos-contaminated solid waste to an approved facility.
Post-excavation soil samples were collected from the excavations. Analytical results indicated contaminant
concentrations below ARAR and TBC criteria.

Based on all of the information collected to date, it is anticipated that future risk associated with hazardous
wastes at Site A will be reduced to acceptable levels by the drum-removal operations at Site A.

This alternative would require a review of the remedial action every five years pursuant to CERCLA Section 121(
c ) , 42 U.S.C. Section 9621( c ), because implementing this alternative would result in hazardous substances
remaining on-site above health-based levels. Additional remedial actions could be required depending on the
results of such a review.
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Alternative 3 - Drum and Lead-Impacted Soil Removal, Consolidation and Covering of ACM, Dewatering, Water
Diversion, Drainage Improvements, and Institutional Controls:

Capital Cost: $3,908,803
Operation and Maintenance Cost: $273,571
Present-Worth Cost: $4,182,374
Implementation Time: 15 months

Alternative 3 includes implementation of source control. The source control activities generally include access
improvements, short-term dewatering, drum removal, containment, long-term surface water drainage improvements,
institutional controls, and O&M activities.

The access improvements and drum removal activities were conducted in September 1997, prior to final remediation
at Site A. The drum removal activities were the same as stated in Alternative 2A.

The containment consists of a "biotic barrier" that will be constructed over Site A once all of the drums have
been removed and the ACM from Site B and UAR have been relocated to Site A. This alternative provides for the
installation of a cover over the ACM area consistent with the National Emission Standards for Hazardous Air
Pollutants (NESHAPS) of the Clean Air Act. The thickness and construction specifications of the cover which best
meet the NESHAPs, as well as the Refuge Management Plan, Wilderness and Wetlands ARARs, are design details to
be determined during the remedial design phase. The purpose of the biotic barrier is to prevent animals from
burrowing into the underlying ACM, to cover the ACM so that the ACM is not subject to deterioration and erosion
by wind or water, and to prevent direct human and animal contact with ACM.

The proposed biotic barrier will consist of several layers, as exemplified in Figure 7 of Appendix I . The
uppermost layer will likely consist of topsoil that is vegetated with grass or indigenous, shallow rooted plants
to minimize erosion. Underneath the topsoil layer there may be layers of common fill, geotextiles or a layer of
stone, sized to make it difficult for burrowing animals to penetrate. Geosynthetics, such as filter fabric, may
be used to prevent mixing between the overlying and underlying materials. The filter fabric will permit water,
but not solids, to pass through. The layer of stone may also be substituted for other geotextile materials (e.g.,
High Density Polyethylene geogrid or geonet mesh) that are capable of acting as a deterrent to burrowing animals.
These materials will have performance capabilities similar to meshes used in animal enclosures and may be used
in lieu of stone to address the USFWS and public desire to limit the amount of truck traffic to and from the
site. In addition, the use of on-site fill materials may assist in achieving a "no net fill" impact to the
Wilderness Area, by using on-site borrow to fill to the cover depth reguired by EPA. The details of the design
will be finalized during the remedial design phase of the project, and will be contingent upon EPA approval.

Excavation, removal, and off-site disposal of lead-contaminated soils and debris (concentrations greater than
218 mg/kg lead) from Site B, and RAs was completed in late Spring 1998. The remaining ACM from the UAR, Site B,
and refuse areas will be placed inside the biotic barrier area at Site A prior to cover installation. Along with
placement and construction of the biotic barrier, the proposed remedy would also include the abandonment of the
existing monitoring wells. Following removal of the ACM and lead-impacted soil and debris from Site B and RAs,
and post-excavation sampling to confirm residual asbestos at less than one percent, the excavated areas will be
graded to a smooth surface and allowed to revegetate naturally. A mixture of annual grass and perennial grass
native to the Refuge will be planted to prevent erosion during the revegetation process.

Since no mercury was found above the RCRA action levels (TCLP or UTS) which would be classified as RCRA hazardous
waste, the mercury-contaminated soil and ACM waste mound to be covered in place at the site would not be
considered a RCRA hazardous waste landfill. The only material which exceeded either criteria was the single drum
of mercury contaminated waste removed and disposed of as a hazardous waste during the Phase II RI.

Temporary lowering of the surface water at Site A over what has been already accomplished through drainage
improvements may be conducted utilizing localized dewatering through wellpoints or sump pumps, if necessary, to
install the cover over Site A. In addition, long-term drainage improvements would be designed into the remedial
action around the periphery of Site A to keep high surface water levels from potentially eroding away the cover
materials. Recent drainage improvements and pilot dewatering tests during 1997 have demonstrated some success
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in surface water management.

The removal of the drums from Site A has eliminated the primary potential source of groundwater contamination
within the Site A mound. Due to the interaction of shallow groundwater with surface water at Site A, surface
water sampling is the most appropriate monitoring method for both groundwater and surface water guality and will
be conducted as part of the long-term monitoring at Site A. In response to stakeholder concerns, shallow aguifer
groundwater monitoring will also be a component of the monitoring plan. Sample freguency and specific sampling
points will be determined during remedial design.

Institutional controls would be established in accordance with the mission of the Refuge and consistent with the
surrounding Wilderness area. Specific controls will be developed in detail during preparation of the final
Maintenance and Monitoring Plan. Controls currently envisioned include limiting visitor access to daylight hours,
limiting uses to passive recreation such as bird watching, photography or hiking, and prohibiting heavy vehicles.
Long-term monitoring of the site would consist of surface water and wildlife monitoring, as is the current Refuge
practice. Other 0& M activities would include mowing in a manner consistent with the wilderness setting and
regular inspection of the integrity of the biotic barrier.

It is anticipated that up to approximately 2-acres of wetlands may be impacted by these proposed activities.
However, final design considerations may mitigate the impacts to a smaller acreage or even expand wetlands over
current site conditions. Therefore, this option would also include an assessment of wetland impacts and
restoration of wetland areas.

This alternative would reguire a review of the remedial action every five years pursuant to CERCLA Section 121(
c ) , 42 U.S.C. Section 9621( c ), because implementing this alternative would result in hazardous substances
remaining on-site above health-based levels or ARARs. Additional remedial actions could be reguired depending
on the results of such a review.

Alternative 4 - Drum Removal, Excavation of ACM and other Waste, Dewatering, On-Site Landfilling, Waste
Consolidation, and Institutional Controls:

Capital Cost: 38,721,236
Operation and Maintenance Cost: $1,195,675
Present-Worth Cost: $9,916,911
Implementation Time: 3 Years

This alternative includes the construction of an off-OU-3, but on-Refuge, lined landfill (2 acres) with five new
monitoring wells, access improvements, short-term dewatering, drum excavation and off-site disposal, excavation
and on-site relocation of about 40,600 cubic yards of ACM and refuse debris, post-excavation sampling, limited
backfilling, institutional controls, and O&M activities.

A lined landfill is constructed with a low permeability bottom liner. The contaminated materials are then placed
on the liner and covered with another low permeability liner. This facility effectively serves two purposes: it
restricts the infiltration of rain water and also captures any water that may be in the waste. Captured water,
called leachate, would be collected and treated prior to disposal or discharge.

The proposed location of the 2-acre lined facility has not been identified at this time, and an environmental
impact/foundation analysis study would have to be completed. Construction of the lined facility would be
completed prior to other activities, and will include site preparation, installation of five wells, and
constructing the liner. The facility would include short-term mechanisms for leachate collection during
construction, as well as a long-term leachate collection system and monitoring system to prevent releases to the
environment. The waste relocation activities would include site preparation, excavation and relocation of the
40,600 cubic yards of ACM/refuse debris, confirmatory testing at the excavation perimeter and selected
backfilling and covering of about 308,000 sg. ft. with a 6-inch-thick layer of native topsoil (5,700 cubic
yards), and seeding of the topsoil with local plant species. The excavation would include the removal of the
asbestos-tainted sediment, which has been accounted for in the 40,600 cubic yards. The drum removal activities
have been conducted as a separate phase prior to excavation of waste at Site A.
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The short-term leachate collection system would involve the collection of leachate and off-site disposal at a
water treatment facility. The long-term system would consist of a composite liner system with gravity feed
through a high permeability leachate collection layer and to an underground collection chamber. The chamber would
be visually inspected periodically and the collected leachate would be either disposed off-site or treated on
site for on-site disposal.

Once all materials have been disposed at the lined facility, the area would be encapsulated with a low-
permeability cover. Native topsoil (3,300 cubic yards) would be placed over the covered area, which would be
seeded with local shallow-rooted plant species. The final cover system would include a passive gas collection
system; a minimum 5-percent top slope and maximum 33-percent side slopes are also recommended for the final
cover. A passive gas collection system allows the gases resulting from the decay of waste materials as a
preferred pathway of escape. This reduces the possible danger of gas buildup under the liner.

Temporary lowering of the surface water at OU-3 and localized dewatering through wellpoints, or sump pumps would
likely be reguired to excavate the waste at Sites A and B. In addition, drainage improvements and other
mitigation measures would be reguired around the periphery of Site A to assist in the dewatering effort and
prevent migration of potential contaminants from the excavation.

Short-term monitoring of the excavation activities is included in this alternative, and would include upstream
and downstream turbidity and environmental testing of surface water and air, as well as post-excavation sampling
of soils and sediment. The long-term groundwater monitoring program, as reguired for ARARs for this type of
constructed facility, would include installation of five new wells at the lined facility and sampling from the
five wells on a guarterly basis. Additional O&M would include visiting the encapsulated area on a guarterly basis
to inspect the integrity of the biotic barrier and drainage improvement areas. Institutional controls would be
put in place to ensure that no inappropriate use of soils, surface water, or groundwater would occur.

This alternative would reguire a review of the remedial action every five years pursuant to CERCLA Section 121(
c ), 42 U.S.C. Section 9621 ( c ), because implementing this alternative would result in hazardous substances
remaining on-site above health-based levels. Additional remedial actions could be reguired depending on the
results of such a review.

Alternative 5 - Drum Removal, Excavation of ACM and other Waste, Dewatering, and Off-Site Disposal:

Capital Cost: $14,179,495
Operation and Maintenance Cost: $0
Present-Worth Cost: $14,179,495
Implementation Time: 3 Years

Alternative 5 includes implementation of source control activities and includes access improvements, short-term
dewatering, drum excavation and off-site (off-Refuge) disposal, excavation and off-site disposal of about 40,600
cubic yards of ACM and refuse debris, post-excavation sampling, and limited backfilling. The drums and ACM would
be disposed at approved off-site waste disposal facilities.

The waste excavation activities would include site preparation, excavation and off-site disposal of the drummed
waste (done) and 40,600 cubic yards of ACM/refuse debris, confirmatory testing and selected backfilling of
308,000 sg. ft. with 6-inch-thick layer of native topsoil (5,700 cubic yards), and seeding of the topsoil with
local plant species. As noted above, the drum removal activities have been conducted as a separate phase prior
to excavation of waste at Site A.

Temporary lowering of the surface water at OU-3, localized dewatering through wellpoints or sump pumps, drainage
improvements, and other mitigation measures (i.e. silt curtains) would be reguired to excavate the waste at Sites
A and B. In addition, short-term monitoring of the excavation activities is included in this alternative.

To minimize the impact to the Wilderness Area, excavation work should again be done in phases at a pace that is
consistent with the Refuge's objectives, and it is recommended that excavation work be done in stages with
lightweight, wide track eguipment.
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SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

In selecting a remedy, DOI and EPA considered the factors set out in CERCLA °121, 42 U.S.C. °9621, by conducting
a detailed analysis of the viable remedial alternatives pursuant to the NCP, 40 CFR °300.430(e) (9) and EPA OSWER
Directive 9355.3-01. The detailed analysis consisted of an assessment of the individual alternatives against each
of nine evaluation criteria and a comparative analysis focusing upon the relative performance of each alternative
against those criteria.

The following "threshold" criteria must be satisfied by any alternative in order to be eligible for selection:

1. Overall protection of human health and the environment addresses whether or not a remedy
provides adeguate protection and describes how risks posed through each exposure pathway
(based on a reasonable maximum exposure scenario) are eliminated, reduced, or controlled
through treatment, engineering controls, or institutional controls.

2. Compliance with ARARs addresses whether or not a remedy would meet all of the applicable
(legally enforceable), or relevant and appropriate (reguirements that pertain to situations
sufficiently similar to those encountered at a Superfund site such that their use is well suited to
the site) reguirements of federal and state environmental statutes and reguirements or provide
grounds for invoking a waiver.

The following "primary balancing" criteria are used to make comparisons and to identify the major trade-offs
between alternatives:

3. Long-term effectiveness and permanence refers to the ability of a remedy to maintain
reliable protection of human health and the environment over time, once cleanup goals have
been met. It also addresses the magnitude and effectiveness of the measures that may be
reguired to manage the risk posed by treatment residuals and/or untreated wastes.

4. Reduction of toxicity, mobility, or volume via treatment refers to a remedial technology's
expected ability to reduce the toxicity, mobility, or volume of hazardous substances, pollutants
or contaminants at the site.

5. Short-term effectiveness addresses the period of time needed to achieve protection and any
adverse impacts on human health and the environment that may be posed during the
construction and implementation periods until cleanup goals are achieved.

6. Implementability refers to the technical and administrative feasibility of a remedy, including
the availability of materials and services needed.

7. Cost includes estimated capital and operation and maintenance costs, and the present-worth costs.

The following "modifying" criteria are considered fully after the formal public comment period on the Proposed
Plan is complete:

8. State acceptance indicates whether, based on its review of the RI/FS report and the Proposed
Plan, the State supports, opposes, and/or has identified any reservations with the preferred
alternative.

9. Community acceptance refers to the public's general response to the alternatives described in
the Proposed Plan and the RI/FS reports. Factors of community acceptance to be discussed
include support, reservation, and opposition by the community.

A comparative analysis of the remedial alternatives based upon the evaluation criteria noted above follows.

• Overall Protection of Human Health and the Environment
-------
Alternatives 3, 4 and 5 will provide for overall protection of human health and the environment.

• Compliance with ARARs

Alternative 1 would not be effective in complying with ARARs because compliance with chemical-specific ARARs can
not be adequately assessed under this alternative.

Under Alternatives 2 and 2A, the existing site conditions and access restrictions would not be consistent with
allowing public use of Wilderness Areas. In addition, a remedial alternative that leaves site conditions largely
unchanged is considered inconsistent with location-specific ARARs or TBCs that address management of general
public use of National Wildlife Refuge Systems under Executive Order 12996, management of wilderness areas under
the Wilderness Act and specifically management of the GSNWR Wilderness Area under the Great Swamp NWR Wilderness
Area Act.

Under Alternatives 3 and 4, ACM and other site related contaminants would either be excavated and permanently
removed from the site or direct exposure and access will otherwise be restricted. Removal or containment of site
contaminants is consistent with the location-specific ARARs cited above.

Under Alternative 5, ACM and other site related contaminants would be excavated and permanently removed from the
site. Restoration of the site is consistent with location-specific ARARs.

• Long-Term Effectiveness and Permanence

Alternatives 1 and 2 would not be an effective approach in the long term because the contaminants of concern
could impact the surrounding environment. As a result, the human health and ecological risks will remain.

Alternative 2A is expected to be an effective long-term alternative for addressing the drummed waste. However,
the alternative does not address 99 percent of the ACM and the refuse debris. It is, therefore, only marginally
effective in the long term.

Alternatives 3, 4 and 5 are effective long-term approaches. There are longer-term risks associated with
Alternative 3, however, they are expected to be limited. Covering the waste in place does not provide the same
level of assurances as relocation of the waste to engineered facilities, and long-term monitoring will be
required.

Alternative 4 also poses a limited long-term risk to the surrounding environment, however, by relocating the
waste to a secure lined facility outside the Wilderness Area, this risk can be controlled.

Alternative 5 will pose no long-term human health or ecological risk to the surrounding environment and will not
require long-term monitoring.

• Reduction in Toxicity, Mobility, or Volume via Treatment

Reduction of toxicity, mobility, and volume of the contaminants of concern could not be determined for
Alternatives 1 and 2.The monitoring component is only a means to assess the actual and relative concentrations
of contaminants. Monitoring to date has shown some reduction in contamination through time, but the duration is
too short to be conclusive. Modeling has not been conducted to determine the effectiveness over time.

Alternative 2A is an effective mechanism to reduce the toxicity, mobility, and volume of the compounds associated
with the drummed waste, but is only marginally effective in reducing the toxicity, mobility, and volume of the
ACM and refuse debris.

Alternatives 3, 4 and 5 are effective overall approaches to reduce the toxicity, mobility, and volume of the
contaminants of concern. Alternative 3 would remediate the hazardous waste and restrict the mobilization of
compounds. This would reduce the toxicity and volume of compounds to concentrations that are below
chemical-specific ARARs and risk based levels. Monitoring would be in place to evaluate if the remedial
objectives are being achieved through these activities.
-------
By relocating the waste to a secure lined facility outside the Wilderness Area, Alternative 4 also controls
toxicity, mobility and volume.

Alternative 5 is the most effective alternative, since all materials will be disposed off site, and there is no
longer human or ecological exposure to the waste sources.

• Short-Term Effectiveness

Alternatives 1 and 2 would not be effective in the short-term because existing conditions are impacting the
environment. In addition, Alternative 2A would not be effective in the short-term because certain contaminants
of concern are related to the refuse debris and ACM, which are not addressed by this alternative.

Alternatives 3, 4 and 5 present additional short-term impacts to the environment that can be overcome. It is
anticipated that the potential short-term risks associated with these activities can be mitigated through
fast-tracking and phasing (as discussed in Chapter 7 of the FS) , proper planning/design, conventional health and
safety procedures, and sensitivity to the Wilderness Area and goals of the Refuge.

• Implementability

Alternative 1 is readily implementable in that it reguires no further action. Alternative 2 can be implemented
with limited coordination and impact to the Wilderness Area. The implications of available funding do not have
an impact on the implementation of either Alternative 1 or 2.

The remaining alternatives are more complicated to implement since they involve more extensive planning,
design, and construction issues. These issues include permitting issues; detailed design issues; dewatering
activities; the excavation, handling, and disposal of waste materials; potential backfilling and replication
of wetlands and floodplain areas; evaluation of on-site disposal areas (Alternative 4); and health and safety
concerns.

Cost

The cost comparison for the remedial alternatives indicates a significant disparity in costs. The estimated total
present value for each alternative, including the cost for drum removal, are as follows:

Alternative 1: $95,654
Alternative 2: $305,729
Alternative 2A: $978,958
Alternative 3: $4,182,374
Alternative 4: $9,916,911
Alternative 5: $14,179,495

• State Acceptance

The State of New Jersey concurrence letter for the selection of Alternative 3 is provided in Appendix IV.

• Community Acceptance

USFWS held three informal open-house meetings for the public during the various stages of the site investigation
to present information and findings. USFWS was responsive to community concerns expressed at these meetings, and
where appropriate, included additional activities during the RI/FS phases to address the guestions or concerns.
The consideration of additional incomplete exposure pathways (e.g. surface and groundwater ingestion) during the
risk assessment was the result of expressed community concerns.

At the December 17, 1997 public meeting, interested community members met with USFWS representatives to discuss
the proposed remedial alternative for the site. Each of the alternatives developed and considered under the
Feasibility Study was presented at the December 17 meeting. Specific guestions and concerns expressed at this
-------
meeting are provided in Appendix V. Community response to the preferred alternative was generally positive.
Concerns were expressed regarding cost and possible short term impacts from consolidation activities, which were
addressed at the public meeting (see also Appendix V) . USFWS responses to the concerns expressed both at the
public meeting and in writing during the public comment period (December 12, 1997 - February 27, 1998) are
provided in the Responsiveness Summary (Appendix V) .

After considering the community response, no significant changes in the proposed remedial action are needed to
address most community concerns.

SEIiECTED REMEDY

After reviewing the alternatives and public comments, DOI, USFWS, and EPA have determined that Alternative 3 is
the appropriate remedy for the site. This remedy has been selected because it best satisfies the reguirements
of CERCLA °121, 42 U.S.C. °9621, and the NCP's nine evaluation criteria for remedial alternatives, 40 CFR
°300.430(e) (9). Since this remedy leaves waste on site, it will reguire a 5-year review in accordance with
Section 121(c) of CERCLA.
The major components of the selected remedy are as follows:

1. Access improvements;
2. Long-term drainage improvements, and short-term erosion control measures;
3. Drum removal activities (which were completed in September 1997 as a time-critical, non-
emergency removal prior to implementation of the preferred alternative), including post-
excavation and waste classification sampling;
4. Removal and off-site disposal of lead contaminated soils (completed, Spring 1998);
5. Consolidation of Site B ACM into Site A (completed, Spring 1998);
6. Placement of a biotic cover over Site A;
7. Implementation of institutional controls to ensure the continued integrity of the drainage
and cover activities (e.g. limiting visitor access to daylight hours, prohibiting other than
passive uses such as hiking, bird watching and photography); and,
8. Assessment of wetland impacts and wetlands restoration.

After completion of the remedial activities noted above, a long-term O&M and monitoring program will begin. USFWS
will mow the biotic cover and prune vegetation. Monitoring of biota and surface water will continue in the
vicinity of OU-3, as is currently done by the Refuge. Monitoring will be in accordance with NJ landfill closure
reguirements. Shallow aguifer groundwater monitoring will also be a component of the monitoring plan, however
sampling freguency and sample locations will be determined during remedial design. Additional O&M will include
visiting the covered area on a guarterly basis to inspect the integrity of the cover materials and drainage
improvement areas.

Initial access and short-term dewatering already completed at the site include:

• Implementation of surface water management improvements evaluated during the Value Engineering Study;

• Improving the UAR, from the parking area at Long Hill Road to 25 ft beyond the Old Great Brook
channel; and

• Placement of a temporary culvert system at the former location of the Old Great Brook Culvert.

In addition, the drum removal activities (completed in September 1997) also included the clearing of Site A;
temporary lowering of the surface water by channel clean-out in the Old Great Brook channel, the use of sump
pumps as needed; the excavation and overpacking of drums; post-excavation soil sampling; the partial backfilling
of the drum excavations; and the off-site disposal of the drummed waste and asbestos contaminated solid waste
to a permitted facility. Additional short-term control measures will include installation of a silt curtain to
prevent erosion into the wetlands during remediation.

Prior to covering Site A, long-term drainage improvements will be constructed to keep surface water from eroding
the Site A slopes. The long-term drainage improvements will include temporary lowering of surface water along
-------
the periphery of the site; consolidation of waste from the periphery of Site A, including mercury-impacted
sediment; and regrading of the unimpacted area around Site A, to a distance of approximately 25 ft beyond the
final limit of waste. Final cover activities at Site A will also include relocation of the asbestos containing
material associated with the UAR and Site B. Following the consolidation of waste, the entire Site A surface will
be cleared, grubbed and graded for the biotic cover materials.

The proposed biotic barrier will likely consist of the layers exemplified in Figure 7 of Appendix I. This detail
meets USFWS goals of using on-site materials to achieve a "no net filling" of the Wilderness Area and limits the
amount of off-site material that would otherwise be trucked to the site. The details of the design, including
the final requirements for cover depth, Will be finalized during the remedial design phase of the project and
will be contingent upon EPA approval.

The uppermost layer will consist of 6 inches of topsoil that is capable of supporting grass or indigenous,
shallow rooted plants. The plant structure will minimize erosion. Underneath the topsoil layer there will be
layers of common fill and geotextiles. Geosynthetics, such as filter fabric, will be used to prevent mixing
between the overlying and underlying materials. The filter fabric will permit water, but not solids, to pass
through. The stone layer previously proposed will likely be substituted by a geotextile material (e.g., High
Density Polyethylene geogrid mesh) that is capable of acting as a deterrent to burrowing animals. Again, the
geotextiles will be used in lieu of stone to address the USFWS and public desire to limit the amount of truck
traffic to and from the site, and assist in achieving a no net fill impact to the Wilderness. The geogrid mesh
will be monitored and maintained on a regular basis, as part of the long term maintenance of the site. The long
term maintenance is required under CERCLA (40 CFR 264) and will be presented in the Remedial Action Work Plan.

As a result of the cover and drainage improvements, it is anticipated that up to 2 acres of wetlands and 2 acres
of flood storage could be impacted and need restoration to comply with ARARs. However, final design details and
criteria may reduce this impact or even create wetland gain instead of loss. The former location of Site B and
the Refuse Areas may be considered for wetlands replication and flood storage. This work would be initiated after
Site A is completed and the other areas (Site B, UAR and RAs) are remediated. Any wetlands replication will be
required to meet USFWS, EPA and NJDEP wetlands mitigation standards.

Once the remedial activities fire completed, the silt curtain and temporary culvert will be removed.

Capital costs for implementation of Alternative 3 are estimated at $3,908,803. Present worth O&M costs are
estimated at $273,571 (for a 30 year period) for a total present worth cost of $4,182,374.

STATUTORY DETERMINATIONS

As previously noted, CERCLA °121 (b) (1) , 42 U.S.C. °9621(b) (1) , mandates that a remedial action must be protective
of human health and the environment, cost effective, and utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum extent practicable. Section 121 (b) (1) also
establishes a preference for remedial actions which employ treatment to permanently and significantly reduce the
volume, toxicity, or mobility of the hazardous substances, pollutants, or contaminants at a site. CERCLA °121(d),
42 U.S.C. °9621(d), further specifies that a remedial action must attain a degree of cleanup that satisfies ARARs
under federal and state laws, unless a waiver can be justified pursuant to CERCLA °121(d)(4), 42 U.S.C.
°9621(d) (4) .

For the reasons discussed below, DOI and EPA have determined that the selected remedy meets the requirements of
CERCLA °121, 42 U.S.C. °9621.

Protection of Human Health and the Environment

Alternative 3, the cover/dewatering/water diversion/drainage improvements alternative, will actively reduce the
toxicity, mobility, and volume of the compounds observed throughout the Site. By excavating the drummed waste
and lead-impacted soil and disposing of the material off-site, the concerns associated with the drums and lead
COG no longer exist. Furthermore, through covering the remaining ACM waste, mercury-contaminated soils and
sediment, the exposure of humans and biota to these sources is controlled. This alternative also includes the
monitoring mechanisms to evaluate any remaining impacts to human health and the environment. Overall protection
-------
of human health and the environment is high.

Compliance with ARARs

This alternative provides for extensive field activity to excavate and relocate hazardous materials, conduct
post-excavation sampling to assure chemical specific ARARs and TBC criteria are attained, and to restrict
exposure to hazardous materials remaining on-site. As a result, it will change the existing conditions and have
an impact on the Wilderness Area. The alternative must protect the character and value of the Wilderness Area,
and all improvements must be performed in accordance with location-specific ARARs and TBC criteria (e.g. U.S.
Great Swamp NWR Wilderness Area Act, U.S. Wilderness Act, Endangered Species Act, U.S. Protection of Wetlands
and Floodplains Executive Orders, U.S. Fish and Wildlife Coordination Act, U.S. Emergency Wetlands Resources Act
of 1986, and the U.S. Clean Water Act).

This alternative will reguire post-closure monitoring and ensure future use of the land is consistent with
management objectives for the surrounding Wilderness Area. Institutional controls already afforded the site under
several ARARs (see above) allow active management strategies to achieve Wilderness Area protection. Therefore,
as a result of this alternative, public use of the land may be restricted to passive or non-intrusive activities
such as bird watching or hiking.

A monitoring program will be implemented to ensure future compliance with chemical-specific ARARs. Drum and
lead-impacted soil removal, and the placement of a biotic barrier cover are expected to reduce the toxicity,
mobility, and volume of the contaminants of concern, to levels where certain compounds (i.e. benzene, TCE and
lead) are no longer a threat. Other compounds (e.g. asbestos and mercury) will be addressed by minimizing the
mobility to levels that will meet chemical-specific ARARs.

Action-specific ARARs associated with the proposed work will be complied with. These include, for example,
National Emission Standards for Hazardous Air Pollutants (NESHAPS, 40 CFR 61.151) related to in-situ
placement/consolidation or remediation of asbestos and ACM, RCRA standards for hazardous waste generators,
transporters and disposal facilities (40 CFR 262, 263, 264) and applicable Land Ban Restrictions (40 CFR 268);
Clean Water Act; New Jersey Hazardous Waste Management Regulations; New Jersey Water Pollution Control
Regulations; and New Jersey Soil Erosion and Sediment Control Standards.

Cost-Effectiveness

The total present worth cost (capital costs and O&M over a 30 year period) for this alternative is $4,182,374.
This is a moderate cost which still ensures long-term effectiveness in meeting ARARs and protecting human health
and the environment.

Utilization of Permanent Solutions and Alternative Treatment Technologies to the Maximum Extent Practicable

The selected remedy utilizes permanent solutions and treatment technologies to the maximum extent practicable.
The selected remedy provides the best balance of trade-offs among the alternatives with respect to the evaluation
criteria. Through off-site disposal of drums and lead-impacted soils, addressing the means of transport through
covering remaining waste, this alternative is expected to reduce the toxicity, mobility, and volume of all
contaminants of concern to concentrations that are below the risk-based levels. Covering of the remaining sources
of contamination with long-lasting materials will limit the routes of exposure. Monitoring of the covered areas
will provide the data to assess the effectiveness and lead to any corrective actions. Therefore, the biotic
barrier, in conjunction with monitoring activities, is expected to be effective in the long-term.

By removing the hazardous waste materials from the sites, this alternative effectively reduces the toxicity,
mobility, and volume of the associated compounds. Furthermore, by installing covers over the ACM and refuse
debris, this alternative restricts the means of transport and mobility of contaminants of concern. This in turn
reduces the volume and toxicity of the contaminants. Monitoring will also be implemented to evaluate if the
remedial objectives are being achieved through these activities and/or natural attenuation. This alternative is,
therefore, considered to be an effective mechanism to reduce the toxicity, mobility and volume.

In the short-term, this alternative is expected to change the existing conditions of each source area and the
-------
potential release of contaminants from drums at Site A. Therefore, the alternative will address the existing
short-term impacts and some additional short-term impacts to the environment will occur. The additional impact
can again be minimized with sensitivity to the Wilderness Area and through proper design and planning (i.e.
implementation of an approved Remedial Action Work Plan and Construction Contingency Plan, to possibly include
such elements as minimum tool provisions and seasonal scheduling). With the proper controls in place, this option
can effectively address the short-term concerns.

Preference for Treatment as a Principal Element

The proposed alternative: meets the statutory preference for treatment as a principal element. Remedial treatment
technologies evaluated during the FS were included on the basis of their effectiveness in addressing the
principal threats to site, particularly in regard to the buried drums in Site A, lead contaminated soils in Site
B, and the refuse areas and friable and non-friable ACM throughout the site. Drummed waste, and other material
determined to be an environmental threat, will be treated through removal from the site. The ACM remaining on
site will not be treated but confined. Engineering and institutional controls will maintain the integrity of the
remedy. Consolidation and covering of the balance of refuse and ACM within Site A minimizes potential impacts
to human health or the environment, and proper biotic barrier construction, maintenance, and monitoring further
prevents future impacts to human and ecological receptors.

DOCUMENTATION OF SIGNIFICANT CHANGES

There are no significant changes from the preferred alternative presented in the Proposed Plan.
-------
APIENDIX I

FIGURES

-------
APPENDIX II
TABLES
SAMPLE ID
LABORATORY ID

METALS (mg/Kg)
Aluminum
Arsenic
Barium
Berylium
Cadmium
C a 1 c i um
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Sodium
Vanadium
Zinc
VOLATILE
ORGANICS (mg/Kg
Benzene
Chlorobenzene
Ethyl benzene
Toluene
Trichloroethene
Vinyl chloride
Total Xylenes
NJDEP
Residential Direct
Contact SOIL CLEANUP
CRITERIA (mg/Kg)

None
20
700
1
1
None
None
None
600
None
400
None
None
14
250
None
63
None
370
1,500

)
3
37
1,000
1,000
23
2
410
Table 1
Summary of Detected Contaminants
Drum Removal Action Post Excavation Sampling
NJDEP
Non - Residential Direct
Contact SOIL CLEANUP
CRETERIA (mg/Kg)
NJDEP
Impact to Groundwater
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
19,400
2.1
254
1.4
0.21
5, 180
35.5
6.7
20.3
11,400
10. 1
1,840
296
0. 11
14
461
1.8
201
55.3
37.3
ND
ND
ND
ND
ND
ND
ND
Travel Blank
ND
ND
ND
ND
ND
ND
ND
12,400
3.4
174
0.99
0.33
2, 170
24
5.1
17.7
8,690
11. 6
1,480
121
NA
10.5
226
ND
ND
46.5
42.8
ND
ND
ND
ND
ND
ND
ND
-------
SAMPLE ID
LABORATORY ID
Table 1
Summary of Detected Contaminants
Drum Removal Action Post Excavation Sampling
NJDEP
Residential Direct
Contact SOIL CLEANUP
CRITERIA (mg/Kg)
NJDEP
Non - Residential Direct
Contact SOIL CLEANUP
CRETERIA (mg/Kg)
NJDEP
Impact to Groundwater
SOIL CLEANUP
CRITERIA (mg/Kg)*
BASE/NEUTRAL
ORGANICS (mg/Kg)
Benzo(a)anthracene
Benzo(b)fluoranthene
Benzo(a)pyrene
Bis(2-Chloroethyl)ethe
Bis(2-Ethylbexyl)phth
Chrysene
Fluoranthene
Hexachlorobutadiene
2-Methylnaphthalene
Naphthalene
Pyrene
ND
ND
ND
ND
ND
ND
.014 J
ND
ND
ND
ND
0.018 J
ND
ND
ND
ND
ND
0.016 J
ND
0.024 J
ND
0.017 J
0.015 J
0.022 J
0.012 J
ND
ND
0.022 J
0.031
ND
ND
ND
0.021 J
ACID EXTRACTIBLE
ORGANICS (mg/Kg)
4-Methylphenol
2,4-Dimethylphenol
Phenol
ND
ND
ND
ND
ND
ND
-------
Table 1
Summary of Detected Contaminants
Drum Removal Action Post Excavation Sampling
SAMPLE ID
LABORATORY ID
NJDEP
Residential Direct
Contact SOIL CLEANUP
CRITERIA (ing/Kg)
METALS (mg/Kg)
Aluminum
Arsenic
Barium
Berylium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Sodium
Vanadium
Zinc
NJDEP
Non - Residential Direct
Contact SOIL CLEANUP
CRETERIA (mg/Kg)
None
20
47,000
1
100
None
None
None
600
None
600
None
None
270
2,400
None
3, 100
None
7,100
1,500
NJDEP
Impact to Groundwater
SOIL CLEANUP
CRITERIA (mg/Kg)*
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
261
1.9
0.41
6,040
45.2
6.3
30.9
17,600
12.2
2,280
359
0.19
19.3
1,340
ND
318
71.1
48.3
VOLATILE
ORGANICS (mg/Kg)
Benzene
Chlorobenzene
Ethyl benzene
Toluene
Trichloroethene
Vinyl chloride
Total Xylenes
2
410
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
-------
Table 1
Summary of Defected Contaminants
Drum Removal Action Post Excavation Sampling
SAMPLE ID
LABORATORY ID
NJDEP
Residential Direct
Contact SOIL CLEANUP
CRITERIA (ing/Kg)
NJDEP
Non - Residential Direct
Contact SOIL CLEANUP
CRETERIA (mg/Kg)
NJDEP
Impact to Groundwater
SOIL CLEANUP
CRITERIA (mg/Kg)*
BASE/NEUTRAL
ORGANICS (mg/Kg)
Benzo(a)anthracene
Benzo(b)fluoranthene
Benzo(a)pyrene
Bis(2-Chloroethyl)ethe
Bis(2-Ethylhexyl)phth
Chrysene
Fluoranthene
Hexachlorobutadiene
2-Methylnaphthalene
Naphthalene
Pyrene
ACID EXTRACTIBLE
ORGANICS (mg/Kg)
4-Methylphenol
2,4-Dimethylphenol
Phenol
NA
NA
NA
^Criteria are determined on a case-by-case basis for inorganics.
-------
Table 1
Summary of Detected Contaminants
Drum Removal Action Post Excavation Sampling
SAMPLE ID
LABORATORY ID
Travel Blank
21451
97-G8-058-011-SL
22841
NJDEP
Residential Direct
Contact SOIL CLEANUP
CRITERIA (mg/Kg)
METALS (mg/Kg)
Aluminum
Arsenic
Barium
Berylium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Sodium
Vanadium
Zinc
NJDEP
Non - Residential Direct
Contact SOIL CLEANUP
CRETERIA (mg/Kg)
None
20
47,000
1
100
None
None
None
600
None
600
None
None
270
2,400
None
3,100
None
7,100
1,500
NJDEP
Impact to Groundwater
SOIL CLEANUP
CRITERIA (mg/Kg)*
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
None
17,400
4 .7
221
1.1
0.2
2, 800
28.6
6 . 4
15.3
11,400
9.8
1, 610
281
ND
12
439
2.9
269
72.7
34.5
VOLATILE
ORGANICS (mg/Kg)
Benzene
Chlorobenzene
Ethyl benzene
Toluene
Trichloroethene
Vinyl chloride
Total Xylenes
2
410
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
-------
SAMPLE ID
LABORATORY ID
Table 1
Summary of Detected Contaminants
Drum Removal Action Post Excavation Sampling
Travel Blank
21451
NJDEP
Residential Direct
Contact SOIL CLEANUP
CRITERIA (mg/Kg)
NJDEP
Non - Residential Direct
Contact SOIL CLEANUP
CRETERIA (mg/Kg)
NJDEP
Impact to Groundwater
SOIL CLEANUP
CRITERIA (mg/Kg)*
BASE/NEUTRAL
ORGANICS (mg/Kg)
Benzo(a)anthracene
Benzo(b)fluoranthene
Benzo(a)pyrene
Bis(2-Chloroethyl)ethe
Bis(2-Ethylhexyl)phth
Chrysene
Fluoranthene
Hexachlorobutadiene
2-Methylnaphthalene
Naphthalene
Pyrene
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ACID EXTRACTIBLE
ORGANICS (mg/Kg)
4-Methylphenol
2,4-Dimethylphenol
Phenol
^Criteria are determined on a c
ND
ND
ND
-------
TABIiE 2 Listing of Detections Exceeding TBCs in Soil Samples from Refuse Areas
(All results reported in ing/Kg)
Sample ID Sample Date Location
Compound/Analyte
Result
Res.TBCs
Indus.TBCs

1
47,000
100

600
20
600
1
600
1
600
6
600
1
1
20
100

J-qualifler = Estimated value

RA = Refuse Area

TBC = New Jersey Residential and Industrial Surface Soil To Be Considered Criteria (N.J.A.C. 7:26D)

Inorganic TBCs for subsurface soils (104-suffix on sample ID) are determined on a site-specific basis in New
Jersey.

Table Revised 10/97
SSB05102
SSB06102
SSB06102
SSB06102
SSB06102
DSB06201
DSB06201
SSB06104
SSB06201
SSB07102
SSB08102
SSB08102
DSB08102
SSB08104
SSB12102
SSB14102
SSB14102
06/06/96
06/06/96
06/06/96
06/06/96
06/06/96
07/15/96
07/15/96
06/06/96
07/15/96
06/06/96
06/06/96
06/06/96
06/06/96
06/06/96
06/07/96
06/07/96
06/07/96
RA #6
RA #6
RA #6
RA #6
RA #6
RA #6
RA #6
RA #6
RA #6
RA #6
RA #6
RA #6
RA #6
RA #6
RA #3
RA #1
RA #1
Beryllium
Barium
Cadmium
Chromium
Lead
Arsenic
Lead
Beryllium
Lead
Beryllium
Lead
Thallium
Lead
Beryllium
Beryllium
Arsenic
Cadmium
1.70
8,380
3.00
188
1,320
31.3
3,020
1.00
2,810
1.10
7,280
4.3
559
1.10
1.20
40
2.60

J
J

J
J
J

1
700
1

400
20
400
1
400
1
400
4
400
1
1
20
1

-------
Summary Statistics for Analytical Detections in Phase II RI Subsurface Soil Samples
COMPOUND/ANALYTE
Volatiles (ug/Kg)
1,1,1-Trichloroethane
Acetone
Methylene chloride
Trichloroethene (TCE)
Semi-Volatiles (ug/Kg)
2-methylnaphthalene
4-chloro-3-methylphenol
Acenaphthene
Acenaphthylene
Anthracene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(g,h,i,)perylene
Benzo(k)fluoranthene
Bis(2-ethylhexyl)phthalate
Carbazole
Chrysene
Dibenzofuran
Dibenzo(a,h)anthracene
Di-n-butyl phthalate
Fluoranthene
Fluorene
Hexachlorobutadiene
Indeno(1,2,3-cd)pyrene
Naphthalene
Phenanthrene
Phenol
Pyrene
Pesticides/PCBs(ug/Kg)
4,4'-DDD
4,4'-DDE
4,4'-DDT
Alpha-chlordane
Aroclor 1248
Dieldrin
Gamma-Chiordane
Heptachlor
Methoxychlor
Total
Number of
Samples
Total
Number of
Detections

6
3
Location of
Maximum
Surf.Soil
TBC
50
630
110
850
1500
690
1500
110
1000
2200
510
1300
320
210
330
3100

510
310
230
3100
660
1800
STP05102
SSS21101
STP05102
STP19202
STP05102
STP05102
STP05102
STP05102
SSB08102
STP05102
SSB14102
STP05102
STP05102
STP05102
STP05102
STP08102
STP05102
STP05102
STP08102
STP05102
STP05102
STP05102
SFW01102
STP05102
3100000
C
4700000
C
23000000
900
90
900
C
9000
46000
32000
88000
C
90
7800000
3100000
3100000
8000
900
3100000
C
47000000
2300000
C
8000
C
C
20000
-------
Summary Statistics for Analytical Detections in Phase II RI Subsurface Soil Samples
Page 2 of 2
COMPOUND/ANALYTE
Inorganics (mg/Kg)
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
Cyanide(mg/Kg)
Total
Number of
Samples

51
51
51
51
51
51
51
51
51
4 6
51
45
51
45
51
51
51
51
51
51
51
51
47
39
Total
Number of
Detections
51
40
17
51
51
51
46
51
45
51
Total number of samples does not include Rejected data

Background sample is SFW01102

NA = Background values are not applicable to organics

ND = Not Detected

(1)I_SOIL = New Jersey Industrial Surface Soil Criteria(N.J.A.C. 7:26D)

(2)R_SOIL = New Jersey Industrial Surface Soil Criteria(N.J.A.C. 7:26D)

C= information not available.
laximum
Value
12400
3.2
42
8380
2. 1
11.4
161000
240
2 9
532
373000
7280
286000
905
50
497
2150
18
8.0
2460
20
7240
3470
1.4
Location of
Maximum
STP17102
SSB08102
SSS28101
SSB06102
SSS21101
SSS28101
SSS25101
STP10102
SSB05102
SSS28101
STP05102
SSB08102
SSS24101
SSB14201
STP03102
STP03102
STP19202
STP05102
SSS28101
STP05102
STP05102
STP05102
SSS28101
SSB08102
Bkgd
Value
14600
ND
2 . 5
37
0.5
ND
274
20
5.8
10
19200
7.3
2150
97
0.3
11
480
0 . 9
ND
146
ND
34
35
ND
Surf.Soil
TBC
700
1
1
-------
TABIiE 5 Listing of Analytical Detections Exceeding TBCs in Surface Soil Samples
Sample ID Sample Date Location
Compound/Analyte
Result
Units Residential TBC
SSB05102
SSB06102
SSB06102
SSB06102
SSB06102
SSB06201
SSB07102
SSB08102
SSB08102
DSB08102
SSB12102
SSB14102
SSB14102
SSB29102
SSB31102
SSB35102
SSB35102
SSB36102
SSB39102
SSB39102
SSS21101
SSS23101
SSS23101
SSS24101
SSS25101
SSS26101
SSS27101
SSS27101
SSS28101
SSS28101
SSS28101
SSS28101
SSS28101
06/06/96
06/06/96
06/06/96
06/06/96
06/06/96
07/15/96
06/06/96
06/06/96
06/06/96
06/06/96
06/07/96
06/07/96
06/07/96
06/21/96
06/20/96
06/21/96
06/21/96
06/21/96
06/24/96
06/24/96
06/19/96
06/19/96
06/19/96
06/19/96
06/19/96
06/21/96
06/21/96
06121/96
06/21/96
06/21/96
06/21/96
06/21/96
06/21/96
RA #6
RA #6
RA #6
RA #6
RA #6
RA #6
RA #6
RA #6
RA #6
RA #6
RA #3
RA #1
RA #1
Site A
Site A
Site B
Site B
Site B
Site B
Site B
Site A
Site A
Site A
Site B
Site B
Site B
Site B
Site B
Site B
Site B
Site B
Site B
Site B
Beryllium
Barium
Cadmium
Lead
Zinc
Lead
Beryllium
Lead
Thallium
Lead
Beryllium
Arsenic
Cadmium
Beryllium
Beryllium
Beryllium
Cadmium
Beryllium
Cadmium
Lead
Beryllium
Beryllium
Cadmium
Beryllium
Beryllium
Beryllium
Beryllium
Lead
Arsenic
Barium
Cadmium
Lead
Zinc
1.7
8380 J
3
1320 J
2560 J
2810
1.1
7280 J
4.3 J
559 J
1.2 J
40
2.6
1.2 J
1.5 J
1.2 J
4
1 J
1.2 J
583 J
2.1
2 J
1.1 J
1.2 J
1.2 J
1.2 J
1.3 J
3860 J
41.8 J
1420
11.4
1120 J
3470 J
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
1
700
1
400
1500
400
1
400
4
400
1
20
1
1
1
1
1
1
1
400
1
1
1
1
1
1
1
400
20
700
1
400
1500
J-gualifler = Estimated value

RA = Refuse Area

TBC = New Jersey Residential and Industrial Surface Soil To Be Considered Criteria (N.J.A.C. 7:26D)
Table Revised 10/97
Page 1 of 2

Industrial TBC

1
47,000
100
600
1500
600
1
600
6
600
1
20
100
1
1
1
100
1
100
600
1
1
100
1
1
1
1
600
20
47000
100
600
1500
-------
TABIiE 5 Listing of Analytical Detections Exceeding TBCs in Surface Soil Samples
Sample ID Sample Date Location
Result
Compound/Analyte

Aroclor 1248
Mercury
Nickel
Thallium
Vanadium
Mercury
Arsenic
Benzo[a]anthracene
Benzo[a]pyrene
Benzo[b]fluoranthene
Benzo[k]fluoranthene
Mercury
Nickel
Thallium
Vanadium
Mercury
Mercury
Nickel
Aroclor 1248
Cadmium
Cadmium
Lead
J-qualifler = Estimated value

RA = Refuse Area

TBC = New Jersey Residential and Industrial Surface Soil To Be Considered Criteria
Table Revised 10/97
Units Residential TBC
STP03102
STP03102
STP03102
STP03102
STP03102
STP04102
STP05102
STP05102
STP05102
STP05102
STP05102
STP05102
STP05102
STP05102
STP05102
STP08102
STP10102
STP12102
STP16102
STP16102
STP17102
STP17102
06/25/96
06/25/96
06/25/96
06/25/96
06/25/96
06/24/96
06/25/96
06/25/96
06/25/96
06/25/96
06/25/96
06/25/96
06/25/96
06/25/96
06/25/96
06/21/96
06/24/96
06/24/96
06/14/96
06/14/96
06/13/96
06/13/96
Site A
Site A
Site A
Site A
Site A
Site A
Site A
Site A
Site A
Site A
Site A
Site A
Site A
Site A
Site A
Site A
Site A
Site A
Site B
Site B
Site B
Site B
510 J
50.1
497
9.9
4020
28.2
37.1
1500 J
690 J
1500 J
1000 J
27.1
440 J
19.6
7240
40.2
42.5 J
258 J
1500 J
1.4 J
2.5 J
442 J
ug/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
ug/kg
ug/kg
ug/kg
ug/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
ug/kg
mg/kg
mg/kg
mg/kg
490
14
250
4
370
14
20
900
660
900
900
14
250
4
370
14
14
250
490
1
1
400
Page 2 of 2

Industrial TBC

2000
270
2400
6
7100
270
20
4000
660
4000
4000
270
2400
6
7100
270
270
2400
2000
100
100
600
(N.J.A.C. 7:26D)
-------
TABIiE 6 Summary Statistics for Analytical Detections in Phase II RI Subsurface Soil Samples
Page 1 of 2
COMPOUND/ANALYTE
Volatiles (ug/Kg)
Acetone
Methylene chloride
Trichloroethene (TCE)
Semi-Volatiles (ug/Kg)
1,2,4-trichlorobenzene
Acenaphthene
Acenaphthylene
Anthracene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(g,h,i,)perylene
Benzo(k)fluoranthene
Benzyl butyl phthalate
Bis (2-ethylhexyl)phthalate
Carbazole
Chrysene
Dibenzo(a,h)anthracene
Diethyl phthalate
Dimethyl phthalate
Di-n-butyl phthalate
Fluoranthene
Indeno(1,2,3-cd)pyrene
Naphthalene
Phenanthrene
Pyrene
Pesticides/PCBs(ug/Kg)
4,4'-ODD
4,4' -DDE
4,4'-DDT
Alpha-chlordane
Aroclor 1248
Aroclor 1254
Dieldrin
Gamma-Chlordane
Total
Number of
Samples

20
20
20

20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20

20
20
20
20
20
20
20
20
Total
Number of
Detections

3
18
7

1
1
1
2
4
4
6
1
5
1
20
2
5
1
1
1
11
4
3
1
4
7

4
5
5
7
1
1
2
7
Percentage
of Detections
15
90
35
5
5
5
10
20
20
30
5
25
5
100
10
25
5
5
5
55
20
15
5
20
35
20
25
25
35
5
5
10
35
Minimum
Value
3
3
3
31
26
61
46
34
39
34
59
30
270
23
27
39
44
32
790
21
63
54
72
130
23
15
2
4
4
28
61
6
4
Mean
Value
15
20
14
31
26
61
67
143
152
118
59
114
270
336
30
150
44
32
790
131
248
91
72
165
144
86
41
303
142
28
61
8
177
Maximum
Value
29
61
36
31
26
61
88
280
250
290
59
240
270
2,500
33
330
44
32
790
810
550
110
72
250
490
290
130
1,300
950
28
61
10
1,200

Location of
Maximum
SSB33106
STP18104
SSB34104
SFW01106
SSB04104
STP21104
STP21104
STP21104
SSB38104
SSB38104
SSB08104
SSB38104
STP18104
STP13104
STP21104
STP21104
SSB08104
STP18104
STP18104
STP18104
STP21104
STP21104
SSB34104
STP21104
STP21104
SSB34104
DTP18104
DTP18104
SSB34104
SSB33106
SSB38104
STP18104
SSB34104
Number of
Bkgd Detections
Value Above Bkgd
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Residential
Soil
TBC
1,000,000
49,000
23,000
68,000
3,400,000
-
10,000,000
900
660
900
-
900
1,100,000
49,000
-
9,000
660
10,000,000
10,000,000
5,700,000
2,300,000
900
230,000
-
1,700,000
3,000
2,000
2,000
-
490
490
42
-
Is Maximum
Value Above
Residential TBC?

No
No
No

No
No

No
No
No
No

No
No
No

No
No
No
No
No
No
No
No

No
No
No

No
No
No
-------
TABIiE 6 Summary Statistics for Analytical Detections in Phase II RI Subsurface Soil Samples
Page 2 of 2
COMPOUND/ANALYTE
Hep-Mor
Inorganics (mg/Kg)
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
Cyanide
Total
Number of
Samples
20

26
26
26
26
26
26
26
26
26
24
26
24
26
24
26
26
26
26
26
26
26
26
26
20
Total
Number of
Detections
2

26
4
22
24
23
6
25
24
24
21
26
23
24
22
10
24
25
19
6
19
6
24
25
4

Percentage
of Detections
10
100
15
85
92
88
23
96
92
92
88
100
96
92
92
38
92
96
73
23
73
23
92
96
20

Minimum
Value
2
19
0.8
1.3
25
0.4
0.4
414
12
2.9
7.8
4.9
3.9
693
22
0.1
7
12
0.8
0.3
111
1.4
12
21
1.3

Mean
Value
29
20,864
6.0
117
152
53
5.0
60,943
34
11
127
45,404
499
53,989
478
2.0
429
743
2.6
3.7
206
6.2
32
604
2.1

Maximum
Value
57
86,600
16
2,400
952
1,200
10
1,200,000
119
37
798
225,000
5,840
1,200,000
2,550
8
9,400
1,700
8.3
8.7
752
14
48
4,700
3.2

Location of
Maximum
SSB34104
SFW01106
STP15104
SSB33106
STP15104
SSB33106
STP15104
SSB33106
STP-13-104
DTP18104
STP15104
DTP18104
STP15104
SSB33106
STP15104
STP13104
SSB33106
SSB21104
DTP18104
STP15104
STP13104
STP15104
SSB20104
SSB33106
SSB38104

Bkgd
Value
NA
86600
ND
7.9
40
0.8
ND
931
22
7.0
14
20800
4.8
2230
820
ND
12
899
1.0
ND
147
ND
39
29
ND
Number of
Detections
Above Bkgd
-
0
3
5
20
13
5
20
12
13
14
11
19
11
2
9
13
8
13
5
14
5
6
19
0
Residential
Soil
TBC
150
-
14
20
700
1
1
-
-
-
600
-
400
-
-
14
250
-
63
110
-
2
370
1,300
1,100
Is Maximum
Value Above
Residential TBC?
No
Yes
Yes
Yes
Yes
Yes
Yes

Yes
No
Yes

No
No

Yes
No
Yes
No
Total number of samples does not include Rejected data.

Data have been included for estimated concentrations related to some sample dilutions; this has resulted in some maximum values at or above reporting limits for some inorganic
constituents .

Background sample is highest of SFW01104 and SFW01106

NA = Background values are not applicable to organics

ND = Not Detected
TBC New Jersey Criteria for Residential Soil (N. J.A.C. 7:26D)
-------
TABIiE 7
listing of Analytical Detections Above TBCs* in Subsurface Soil Samples
(All results reported in ing/Kg)
Sample ID
SSB06104
SSB08104
SSB30104
SSB34104
SSB34104
SSB34104
SSB34104
SSB38104
SSB38104
SSB40104
SSB44104
STP13104
STP13104
STP13104
STP15104
STP15104
STP15104
STP15104
STP15104
STP15104
STP15104
STP15104
STP15104
STP18104
STP18104
STP18104
STP18104
STP18104
STP18104
STP18104
DTP18104
DTP18104
DTP18104
DTP19104
DTP18104
DTP18104
DTP18104
DTP18104
Sample Date
06/06/96
06/06/96
06/20/96
06/21/96
06/21/96
06/21/96
06/21/96
06/24/96
06/24/96
06/26/96
06/26/96
06/20/96
06/20/96
06/20/96
06/14/96
06/14/96
06/14/96
06/14/96
06/14/96
06/14/96
06/14/96
06/14/96
06/14/96
06/14/96
06/14/96
06/14/96
06/14/96
06/14/96
06/14/96
06/14/96
06/14/96
06/14/96
06/14/96
06/14/96
06/14/96
06/14/96
06/14/96
06/14/96
Location
RA #6
RA #6
Site A
Site B
Site B
Site B
Site B
Site B
Site B
OFR-LAA
OFR-LAA
Site A
Site A
Site A
Site B
Site B
Site B
Site B
Site B
Site B
Site B
Site B
Site B
Site B
Site B
Site B
Site B
Site B
Site B
Site B
Site B
Site B
Site B
Site B
Site B
Site B
Site B
Site B
Compound /Anal yte
Beryllium
Beryllium
Beryllium
Beryllium
Cadmium
Chromium
Copper
Lead 1700
Thallium
Beryllium
Beryllium
Beryllium
Chromium
Nickel
Arsenic
Barium
Cadmium
Chromium
Copper
Lead
Manganese
Thallium
Zinc
Cadmium
Chromium
Copper
Lead
Manganese
Thallium
Zinc
Arsenic
Cadmium
Chromium
Copper
Lead
Manganese
Thallium
Zinc
Result
1
1.1
2.3
2.5 J
4.2 J
57.9 J
108 J
1700 J
2.7
1.2
1.3
1.9 J
119 J
264 J
40.2
952
10.4
95.8
798
5840 J
2550
14
3260
7.7
57.8
571
1160 J
1360
4.1
1840
25
6.6
71.4
730
1490 J
1600
13.1
2560
TBC*
1
1
1
1
1

400
4
1
1
1

250
20
700
1

400

4
1500
1

400

4
1500
20
1

400

4
1500
J-gualifler = Estimated value

RA = Refuse Area. OFR-LAA = Old Farm Road Limited Action Area

Inorganic TBC's for subsurface soils are determined on a site-specific basis.

(Residential Surface Soil Criteria shown for reference only)
-------
TABIiE 8

Summary of Results for Mercury and Lead Leachability Analyses
of and Subsurface Soil Samples
Sample ID Sample Date Location
Contaminant
STP15104
STP16102
MD-06
MD-17
MD-19
MD-21
STP15104
STP16102
LD-15
LD-16
LD-17
LD-18
LD-27
6/14/96
6/14/96
6/5/97
6/5/97
6/5/97
6/5/97
6/14/96
6/14/96
6/11/97
6/11/97
6/11/97
6/11/97
9/24/97
Site B
Site B
Site A
Site A
Site A
Site A
Site B
Site B
RA #6
RA #6
Site B
Site B
RA #6
Mercury
Mercury
Mercury
Mercury
Mercury
Mercury
Lead
Lead
Lead
Lead
Lead
Lead
Lead
Total
Analysis
Result (mg/kg)

0.06U
6.2J
19.8
10.8
16.0
6.34
5,840J
196J
787
3,400
1,150
42.2
1,230
TCLP Result
(ug/L)

5.0U
5.0U
0.33
0.20U
0.20U
0.20U
2,300
30. OU
254.0
4,770.0
63.6
50. OU
165
TCLP
Std.
(ug/L)
200
200
200
200
200
200
5,000
5,000
5,000
5,000
5,000
5,000
5,000
U - gualifier = Below method detection limit
J - gualifier = Estimated concentration
RA = Refuse Area
TCLP = Toxicity Characteristic Leaching Procedure - An EPA procedure to determine the potential
leachability of a constituent as specified in the Resource Conservation and Recovery Act(RCRA)
mg/kg = milligram per kilogram
ug/L = microgram per liter
-------
TABIiE 9 Summary Statistics for Analytical Detections in Unfiltered Phase II RI Groundwater Samples
Page 1 of 1
(All results reported in ug/L)

Compound /Anal yte
Volatiles
Benzene
Chlorobenzene
Methyl chloride
Trichloroethene (TCE)
Semi -Volatiles
Bis (2-ethylhexyl)phthalate
Pesticides
Alpha-BHC
Beta-BHC
Delta-BHC
Inorganics
Aluminum
Arsenic
Barium
Beryllium
Calcium
Chromium
Cobalt
Copper
Iron
Load
Magnesium
Manganese
Mercury
Nickel
Potassium
Sodium
Vanadium
Zinc
Total
Number of
Samples
16
16
16
16

16
15
15
15
8
16
16
16
16
14
16
16
15
12
16
7
16
16
16
16
16
15
Total
Number of
Detections
3
2
16
1

5
1
1
1
8
3
16
1
16
3
8
13
15
3
16
7
7
11
16
16
14
15
Total
Number of
Samples
16
16
16
16
Total
Number of
Detections
3
2
16
1

Percentage
of Detections
19
13
100
6

Minimum
Value
2.5
1.5
1.5
1.8

Mean
Value
2.4
2.3
2.8
1.8

Maximum
Value
2.8
3.0
5.6
1.8

Location of
Maximum
SGS03101
SGS03101
SES04101
SGS10101
Number of
Bkgd Detections
Value Above Bkgd
NA
NA
NA
NA
Ground
Water
ARAR
1
5
30
1
Number of
Detections
>ARAR
3
0
0
1
31
3.1
14.6
35.0
SES03101
NA
7
7
7
100
19
100
6
100
21
50
81
100
25
100
100
44
69
100
100
88
100
0.11
0.03
0.01
102
6
14
1.6
6790
4
1.4
1.4
53
4.8
3710
27
0.11
4
520
3030
1.4
9
0.11
0.03
0.01
1685
8
69
1.6
45705
13
6
13
7684
6.1
11961
507
0.37
14
2746
14164
10
32
0.11
0.03
0.01
6160
10
137
1.6
106000
25
19
50
40300
7.1
39000
1860
0.79
39
6720
36300
30
93
SGS10101
SGS10101
SGS10101
SES02101
SGS06101
SGS10101
SES03101
SGS10101
SGS06101
SGS06101
SGS09101
SES03101
SGS06101
SGS06101
SGS06101
SGS02101
SGS06101
SGS01101
SGS06101
SES03101
SGS08101
NA
NA
NA
1860
ND
102
ND
20300
ND
3.8
15
4670
6.4
7790
1060
ND
7.2
1100
5560
8.8
31.9
—
—
—
8
3
16
1
16
3
8
13
15
3
16
7
7
11
16
16
14
15
30

0.02
0.2
2000
20

100
15
2
100
5000
Total number of samples does not include Rejected data
FW-01 Is the background well
NA = Background values are not applicable to organics
ND = Not Detected
ARAR = New Jersey Ground Water Quality Standards N.J.A.C. 7:9-6
-------
Table 13 Human and Ecological Contaminants of Concern*
Environmental Analyte
Medium
Concern
Human Health Lead
Risk

Ecological

Barium
Cadmium
Risk Chromium
Lead
Mercury
Thallium
Vanadium
Zinc
* When determining cleanup goals
Table 14
Analyte

Lead

Mercury
Surface Soil

Surface Soil
Surface Soil
Surface Soil/Sediments
Surface Soil
Surface Soil/Sediments
Surface Soil
Surface Soil/Sediments
Surface Soils
Site-Specific Site-Specific Cleanup Goal Source
Cleanup Goal
218 mg/kg

700 mg/kg
1 mg/kg
370 mg/kg
218 mg/kg
1 mg/kg
4 mg/kg
370 mg/kg
1,500 mg/kg
, the more stringent value contained in

NOAA. ER-M Screening Guideline for Sediment Quality

NJ Unrestricted Use (formerly Residential) Direct Contact
NJ Unrestricted Use (formerly Residential) Direct Contact
NOAA ER-M Screening Guideline for Sediment Quality
NOAA ER-M Screening Guideline for Sediment Quality
NOAA ER-M Screening Guideline for Sediment Quality
NJ Unrestricted Use (formerly Residential) Direct Contact
NJ Unrestricted Use (formerly Residential) Direct Contact
NJ Unrestricted Use (formerly Residential) Direct Contact
an identified ARAR or TBC source was utilized.

Soil Cleanup
Soil Cleanup

Soil Cleanup
Soil Cleanup
Soil Cleanup

Criteria
Criteria

Criteria
Criteria
Criteria

Summary of Guidance Values and TBC Criteria Considered in Selection of the Site-Specific Cleanup Goals for Lead and Mercury
Site- Medium
Specific
Cleanup
Goal

218 Surface
mg/kg Soil
1 mg/kg Surface
OU-3-
Surface Soil
Background
Concentration
(based on
Phase II RI
data)
7.3 mg/kg

Soil 0.3 mg/kg
/Sediment

NOAA
ER-M
Screening
Guidance
for
Sediment
Quality*
218 mg/kg

0.71
mg/kg**

NOAA New Jersey New Jersey EPA
Adverse Unrestricted Restricted Use Residential
Effects Use (formerly (formerly Scenario
Threshold Residential) Industrial) Soil
(AET) for Direct Direct Contact Screening
Sediment Contact Soil Soil Criteria Level (SSL)
Quality* Criteria
300 mg/kg 400 mg/kg 600 mg/kg 400 mg/kg

1.0 mg/kg 14 mg/kg 270 mg/kg 23 mg/kg
(ingestion
10 mg/kg
(inhalation)
Region III
BTAG
Screening
Level for
Soil

0.01 mg/kg

0.06 mg/kg
( fauna )

RCRA Action
Levels -
TCLP & UTS

TCLP 5 . 0 mg/L

TCLP 0.2 mg/L
UTS 260 mg/kg

*Basis for establishing site-specific cleanup goal. A cleanup goal is defined as a medium-specific numerical concentration established as a operable-unit specific
remedial action objective considered protective of human and ecological receptors for an exposure route. Protectiveness may be achieved by reducing exposure.
**ER-M Value was rounded up to the next whole number for the site-specific cleanup goal value
TCLP -Toxicity Characteristic Leaching Procedure
UTS - Universal Treatment Standard
-------
Table 15 Summary of Ambient Asbestos Air Monitoring Results from January through December - Great Swamp National Wildlife Refuge*
Page 1 of 1
Base
Sampling Date 1

Feb. 15

Feb. 21

Feb. 27
Mar 4,

Mar 10,

Mar 16,
Mar 22,

Mar 28,
Apr 3,

Apr 9,
Apr 15,
Apr 21,
Apr 27

May 9,
May 15

July 8,

July 14
July 20

, 1996

, 1996
1996

1996

1996
1996

1996
1996
1996
through May 3, 1996

1996
through July 2, 1996

1996

, 1996
through Dec 31, 1996

ND
ND

ND
ND
ND
ND

ND
ND

ND
ND
2

ND
7.7 f/mm2,
0.018 f/cc**

ND
ND

ND
ND
15.4 f/mm2,
0.0056 f/cc
ND
ND
ND
15.9 f/mm2,
0.0029 f/cc
ND

ND
31.0 f/mm2,
0.0053 f/cc
ND
OU-3 Site A
3 4

ND
ND
31.0 f/mm2,
0.0053 f/cc

ND
ND

ND
ND
ND
ND

ND
ND

ND
15.4 f/mm2,
0.0028 f/cc
ND

ND
ND

ND
ND
ND
ND

ND
ND

ND
ND
5

ND
ND

ND
ND
ND
ND

ND
ND

ND
ND
OU-3 Site B
6 7

ND
ND

ND
15.4 f/mm2,
0.0026 f/cc
ND

ND
ND

ND
ND
ND

ND
ND
31.0 f/mm2,
0.0054 f/cc

ND
ND

ND
ND
15.4 f/mm2,
0.0026 f/cc

ND
ND
98.9 f/mm2,
0.0250 f/cc
ND

ND
ND
ND

ND
ND

ND
ND
FBI

ND
ND

ND
ND
7.7 f/mm2,
NA f/cc
ND

ND
ND
ND

ND
ND

ND
ND
Blanks
FB2

ND
ND

ND
ND
15.4 f/mm2,
NA f/cc
ND

ND
ND
ND

ND
ND

ND
ND
EPA
LB Std. +
70
ND f/mm 2

ND
7.7 f/mm2,
NA f/ccA
ND

ND
ND

ND
ND
ND

ND
ND
62 f/mm2,
NA f/cc

ND
ND
+EPA Standard based on indoor school air guality
f/mm2 = fibers per square millimeter
f/cc = fibers per cubic centimeter
NA = no volume or air was sampled (blank filter), therefore there is no conversion to f/cc.
* = All detections of asbestos are chrysolite fibers except for one detection of amosile Fibers (A).
** = Laboratory unable to achieve required analytical sensitivity due to insufficient volume of air sampled; sample received wet due to rain/snow.
A = Asbestos type detected was amosite.

Samples from the following dates were not analyzed, but have been archived: 8/19, 8/31, 9/12, 9/24, 10/6, 10/18, 10/30, 11/11, 11/23, 12/5, 12/17, and 12/29.
-------
APPENDIX III

USFWS Operable Unit 3 of the
ASBESTOS DUMP SUPERFUND SITE
ADMINISTRATIVE RECORD INDEX
DOCUMENT
DATE
5/29/87
11/18/91
TITLE OF DOCUMENT

Fred C. Hart Associates, Inc. Draft
Remedial Investigation study for the
Asbestos Dump Superfund Site,
Morris County, NJ

McLaren/Hart Environmental
Engineering Corp. Revised Draft
Supplemental Remedial Investigation
Work Plan for the Asbestos Dump -
Dietzman Tract Site Operable Unit 3,
Millington, NJ

Environmental Science &
Engineering, Inc. Site Assessment
Report Operable Unit 3 - Asbestos
Dump Site (Dietzman Tract)
GSNWR, Morris County, NJ
Brown, K.W., et al. Expert Report for 5/14/92
the Dietzman Tract
3/92
DATE PLACED
IN FILE
8/8/96
8/8/96
DATE OF
UPDATES
8/8/96
8/8/96
Foster Wheeler Environmental Corp. 7/1/96
Phase II Remedial Investigation Work
Plan and Attachments, Final, Version
3.1
8/8/96
Fact Sheet 1 12/1/95

Fact Sheet 2 5/1/96

Fact Sheet 3 9/1/96

EPA Comments on Draft Phase II 5/20/96
Remedial Investigation Wok Plan

USFWS Action Memorandum for the 9/1/96
Removal at the LAAs (includes both
the ACOE Statement of Work on
Removal and the Limited Action
Areas Site Characterization Report

Wetlands Permit Compliance 8/96
Submission
9/13/96

9/13/96

8/8/96

9/13/96
9/13/96
Amendment 001 to the ACOE
Statement of Work on LAA Removal
Actions
9/12/96
9/24/96
-------
Amendment 002 to ACOE Statement
of Work on LAA Removal Actions
9/27/96
10/10/96
Preliminary Review of ARARS and March 1996
AOC's of the Asbestos Dump
Superfund Site, Great Swamp
National Wildlife Refuge

U.S. Army Corps of Engineers,
Kansas City District, Design Analysis,
Removal of Asbestos Containing
Materials in the LAAs
10/10/96
September 1996 1/28/97
U.S. Fish and Wildlife Service 10/1/96
Review of the Presence of
Endangered or Threatened Species in
the Great Swamp National Wildlife
Refuge

Foster Wheeler Environmental Corp.- 10/96
Supplemental Sampling at LAA's

U.S. Army Corps of Engineers, 11/18/96
Kansas City District, Removal of
Asbestos Containing Material in the
LAA's Modification of Contract
1/28/97
1/28/97
1/28/97
Fact Sheet 4
11/96
Foster Wheeler Environmental Corp.- 12/96
Supplemental Sampling at the: Conroy
Property - Indoor Air Monitoring
1/28/97

1/28/97
State of New Jersey Authorization for 10/4/96-Verbal 1/28/97
Fresh Water Wetlands Statewide
General Permit for Removal of
Asbestos Containing Material in the
LAA1 s
1/7/97
Fact Sjeet 5 2/97

EPA Comments on Draft Phase II 3/27/97
Remedial Investigation Report

Fact Sheet 6 5/97

Foster Wheeler Environmental Corp. 5/97
Pilot Treatability Study for Water
Management OU-3 of the Asbestos
Dump Superfund Site, Technical
Memorandum, GSNWR, Morris
County

EPA Comments on Draft Feasibility 5/19/97
Study Report
5/19/97

6/5/97

5/19/97

9/19/97
7/7/97
-------
EPA: Superfund Technical Assistance
Grant (TAG) Handbook(s):
Applying For Grant 9/93
• Managing Your Grant 4/94
Procurement - Using TAG Funds 4/94
The Application Forms with 9/93
Instructions
EPA: Guidance for Community
Advisory Groups (CAGs) at
Superfund Sites
A Quick Reference Fact Sheet 2/13/97
Guidance Document
2/14/97
Foster Wheeler Environmental Corp. 5/97
USFWS Final Remedial Investigation
Report for the Asbestos Dump
Superfund Site, Operable Unit 3-
Volumes I, II, & III

SEA Consultants Inc./Foster 6/97
Wheeler Environmental Corp.
USFWS Final Feasibility Study
Report for the Asbestos Dump
Superfund Site (OU-3) and Three
Areas of Concern, Volume I - Report,
Volume II - Appendices

Hanscomb Engineers - Value 6/24/97
Engineering Report

Fact Sheet 7 8/97

IT Corporation Final Action 8/97
Memorandum for Drum Removal
Action Site A
5/19/97
5/19/97
5/19/97
5/19/97
5/19/97

5/19/97

6/5/97
7/7/97
8/12/97

8/27/97

8/27/97
Rapid Response Risk Reduction Work 7/97
Plan
9/19/97
Foster Wheeler Pre-Design Data 9/97
Report, Volumes I & II
IT Corporation Letter Work Plan for 9/97
Drum Removal Oversight and ACM
Delineation
9/19/97

9/29/97
EPA Comments on Proposed
Remedial Action Plan
1/15/98
3/3/98
Action Memorandum for Removal 2/98
Action at Operable Unit 3/Site B and
Limited Action Areas
12/5/97
2/10/98
USFWS Proposed Plan for the
Asbestos Dump Superfund Site
Operable Unit 3
12/97
12/10/97
-------
Fact Sheet 8 12/97 3/2/98

IT Corporation Final Report, Risk 12/5/97 3/2/98
Reduction Drum Removal Project
(Volume I) OU-3 Site A

Work Plan: Removal and Restoration 2/98 3/3/98
Action for OU-3 (Site B) and Limited
Action Areas

U.S. Army Corps of Engineers, New 6/97
York District, Close-out Documents
for the Removal of Asbestos
Containing Materials in (4) Limited
Action Areas at the Great Swamp
National Wildlife Refuge,
1997.(Available in the Administrative
Record only; not available at local
repositories.)

Fact Sheet 9 5/98 6/98

New Jersey Department of 2/19/98 3/3/98
Environmental Protection Comments
on the Proposed Plan

Guidance Expediting Remedial 8/90
Design and Remedial Action,
EPA/540/G-90/006, OSWER
Directive 9355.5-02
-------
APPENDIX IV

STATE LETTER OF CONCURRENCE

U.S. Environmental Protection Agency
Region 2
290 Broadway
New York, NY 10007-1866

Attn: Jeanne M. Fox, Regional Administrator

Re: Millington Asbestos Dump
Operable Unit 3

Dear Ms. Fox:

This is in regard to the Record of Decision (ROD) for the Millington Asbestos Dump, Operable Unit 3
(OU3), located in Harding Township, Morris County, New Jersey.

The New Jersey Department of Environmental Protection ((NJDEP) Site Remediation Program, has reviewed
the following selected remedy:

1. Access improvements;
2. Long-term drainage improvements, and short-term erosion control measures;
3. Drum removal activities (which were completed in September 1997 as a time-critical,
non-emergency removal prior to implementation of the preferred alternative), including
post-excavation and waste classification sampling;
4. Removal and off-site disposal of lead contaminated soils (completed, Spring 1998);
5. Consolidation of Site B Asbestos-Containing Material (ACM) into Site A (completed, Spring
1998);
6. Placement of a biotic cover over Site A;
7. Implementation of institutional controls to ensure the continued integrity of the drainage
and cover activities (e.g. limiting visitor access to daylight hours, prohibiting other than
passive uses such as hiking, bird watching and photography); and
8. Assessment of wetland impacts and wetlands restoration.

This is to advise you that NJDEP concurs with the selected remedy as being protective of human health
and the environment.

-------
APPENDIX V

RESPONSIVENESS SUMMARY

ASBESTOS DUMP OPERABIiE UNIT 3 SUPERFUND SITE

INTRODUCTION

A responsiveness summary is required by Superfund policy. It provides a summary of agency and citizens' comments
and concerns received during the public comment period. It also provides the United States Department of the
Interior's (DOI) responses to those comments and concerns. All comments summarized in this document have been
considered in DOI's final decision for selecton of a remedial alternative for the Asbestos Dump Operable Unit
3 site.

OVERVIEW

Public response to the preferred alternative has been generally positive. Responses from DOI, acting through the
United States Fish and Wildlife Service (USFWS) , to the concerns expressed both at the public meeting and as
written submittals during the public comment period are provided below. A transcript of the public meeting is
provided in Attachment A and a copy of all written comments submitted during the public comment period has been
provided in Attachment B.

BACKGROUND ON COMMUNITY INVOLVEMENT

USFWS sought to be very sensitive to the community concerns about OU-3 and activities taking place at GSNWR. As
a result, USFWS provided extensive information to local, state and federal regulators, neighboring communities
and other interested parties during the course of the RI/FS process. Information was provided through informal
information sessions, briefings, periodic mailings, one on one discussions, a hotline administered by USFWS
personnel and media coverage. In addition, USFWS hosted three "Open Houses" in May 1996, February 1997 and May
1997.

The questions expressed at the three Open Houses included technical issues such as data collection procedures,
additional discharge impacts to the Great Swamp because of proposed expansion of upstream point and non-point
source contributors, the effects of water level fluctuations on the physical properties of asbestos, and
clarification of remedial alternatives under consideration. In addition, the open houses provided an opportunity
for interested parties to comment on concerns regarding staging area visibility and quality of contractors and
sub-contractors on the project. Many of these concerns were addressed by field activities and all were considered
during appropriate phases of the project. Many of the concerns expressed at these earlier gatherings were
repeated at the Public Meeting on December 17, 1997, for which responses are provided below.

SUMMARY OF COMMUNITY RELATIONS ACTIVITIES

USFWS has conducted an ambitious community relations program throughout this project. Activities related directly
to information distribution and public comment are described below. A more comprehensive history of community
relations activities is provided in the body of the Record of Decision.

The RI report, FS report, and Value Engineering report were placed in public access repositories during the month
when each report was finalized, May, June and July 1997, respectively. The Proposed Plan for the site was
released to the public for comment on December 12, 1997. These documents are available to the public in the
administrative record file at USFWS Liaison office at GSNWR, the EPA Docket Room in Region II, New York and the
information repositories at Long Hill Township Free Public Library, 91 Central Avenue, Stirling, NJ and the
Harding Township Kirby Municipal Building, Town Clerk's Office, Blue Mill Road, New Vernon, NJ. The notice of
availability for the above-referenced documents was published in the Newark Star-Ledger on December 10, 1997.
Public comments on these documents were accepted from December 12, 1997 to February 27, 1998.
-------
On December 17, 1997, USFWS conducted a public meeting at the Green Village Volunteer Fire Station, Green
Village, New Jersey, to inform local officials and interested citizens about the Superfund process, to review
current and planned remedial activities at the site, and to respond to any guestions from area residents and
other attendees. A transcript of the public meeting is provided in Attachment A.

In addition, six letters were received during the public comment period, including a reguest for an extension
of the public comment period. The extension was granted for a period of 30 days. Responses were prepared and
incorporated into the ROD responsiveness summary. Copies of the letters can be found in Attachment B.

A summary of comments from the public meeting, written comments received during the comment period and after the
close of the extended comment period, and DOI's responses, is provided below.

SUMMARY OF COMMENTS AND RESPONSES

Oral and written comments received from stakeholders and NJDEP are summarized below along with DOI's responses.
The comments are organized in the following three categories: Proposed Remedy (Proposed Plan), Superfund
Process/Procedural Issues, and Miscellaneous.

Proposed Remedy (Proposed Plan):

Comment 1: A resident asked how the consolidation of waste would physically be completed at the site. Another
resident asked a similar guestion and reguested clarification regarding the condition of the 55-gallon drums
which were removed from Site A, particularly with regard to their potential impact on groundwater.

Response: The purpose of consolidation at Site A is to relocate small, scattered deposits of ACM to one central
location, minimize the footprint of the remaining asbestos area to be covered (Site A) , and minimize impacts on
surrounding wetlands. Rather than cover those areas where ACM exists only to a depth of two to three feet at the
periphery of Site A, the plan calls for excavation and relocation of that fringing ACM to the central area of
Site A. Also, the small volume of ACM from the unimproved access road (UAR) , Site B, and Refuse Area #1 would
be placed beneath the "biotic barrier" within the remaining Site A area, so that only one cover will be reguired.
This will minimize necessary maintenance and inspection to a single location, rather than several independent
areas. Following the relocation of the ACM and removal of lead-impacted soil and debris from Site B and refuse
areas, the excavated areas will be graded to a smooth surface and revegetated with grasses native to the Refuge.

Impacts to groundwater from drums buried at Site A were demonstrated to be negligible. Based on analytical
results from post-excavation soil sampling conducted at the time of the drum removal action, there were no
significant leaks from the drums which might pose a continuing source of contamination to the site
groundwater.These observations and findings are summarized in the Risk Reduction Final Report (IT Corporation,
1997) documenting the drum removal activities. The report has been made part of the Administrative Record for
this Record of Decision.

Comment 2: A stakeholder guestioned the discussion of the results of the drum removal interim action.

Response: The drum removal was undertaken to remove potential hazardous wastes from the site. The scope was to
identify and locate potential drums and remove them while minimizing the amount of disturbance of ACM to avoid
unnecessarily increasing the risk from airborne asbestos. The removal action was undertaken as a risk reduction
step that addressed the potential for releases of contamination before any catastrophic incidents occurred. The
only absolutely certain way to determine there are no remaining drums containing hazardous wastes would be to
excavate the entire mound. However, doing that would elevate the short-term inhalation risk substantially, raise
the risk of a release of asbestos into surrounding surface water, and be prohibitively expensive. Remedial
designs will take into account all known site conditions so that appropriate design data are available for
completing the final design package.

The drum removal activities are summarized below from the detailed information presented in the Immediate
Response Action, Rapid Response Risk Reduction Final Report prepared by IT Corporation (IT), on behalf of the
U.S. Army Corps of Engineers, dated December 1997. This report was released after the preparation of the Proposed
Plan and therefore the information was unavailable at the time.
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The combined geophysical work performed at the site (Foster Wheeler - January 1996 and IT - August/September
1997) identified a total of 127 anomaly locations based on a modeling of magnetic and other survey data. An
anomaly is an interpretation of the magnetic or other geophysical readings that suggests a buried mass of metal
over a size threshold which could represent a drum. Ninety-nine (99) of the 127 anomaly locations were selected
for excavation because the potential mass of metal that each was modeled to contain exceeded recorded readings
in excess of 400 kilograms. The excavations, numbering EX001 to EX0085, often covered more than one anomaly and
were prioritized seguentially. The excavations were generally performed in order of the decreasing magnitude
observed. The last twelve test pits (EX074 to EX085) encountered only minimal amounts of metal, no drums and no
visible contamination, and became the justification not to continue the excavations for smaller potential masses
of metal. Therefore, the remaining 28 anomaly locations were not excavated because it was determined from
excavation results that drums were not likely to be present in the remaining lesser magnitude anomalies. 207 drum
carcasses were removed, of which 69 contained product. Fifty of those drums were subseguently determined to
contain RCRA characteristic hazardous waste and were properly disposed of as hazardous. Substantial amounts of
varied scrap metal debris, including auto and bus bodies and a bulldozer, were also retrieved from the site and
properly disposed of off-site. An additional 19 55-gallon drums containing investigation derived wastewater were
also disposed of off-site.

Comment 3: NJDEP reguested that the phrase "Excavation of Other Waste" be added to the summary description of
Alternative 3 in Table 2 of the Proposed Plan.

Response: This phrase has been added to those passages in the ROD where Alternative 3 is described in order to
clarify all activities which comprise the alternative.

Comment 4: Several residents asked for clarification regarding the term "institutional controls and monitoring"
that were: evaluated for Alternatives 2, 2A, 3 and 4. One resident specifically asked if these controls are
intended to be activities in perpetuity or short term. A second resident asked if the monitoring program
specifics would be provided.

Response: Institutional controls for a site may encompass a variety of passive controls and management practices,
including access restrictions, land use restrictions, easements or deed restrictions. Several ARARs already
afford the site institutional controls not usually available to typical Superfund sites. Institutional controls
specifically envisioned for OU-3 would be developed in detail during the design phase and refined during the
preparation of the Site Operations and Maintenance (O&M) Plan. The USFWS wishes to maintain institutional
controls that are consistent with the rest of the surrounding Wilderness Area. Proposed controls
would allow visitor access to the site during proscribed daytime hours for activities such as birdwatching,
hiking, and photography. However, visitor amenities which were present in the past such as a parking lot, trail
heads and stream crossings would not be re-established. Monitoring includes surface water and biota sampling as
is the current Refuge practice. Groundwater monitoring of the shallow aguifer will also be performed at locations
and on a schedule to be determined during the remedial design. During the construction phase of the selected
remedial alternative, air sampling will also be conducted to ensure adeguate control of asbestos during
consolidation and containment activities. USFWS is reguired to plan for a 30-year monitoring program, however
much of the proposed monitoring is already integral to the existing USFWS Refuge Management Plan, such as
upstream/downstream water sampling and biota sampling, and is expected to be an important element of the O&M Plan
into the indefinite future. The final plan for the site will be submitted to EPA for review and approval and will
be made available as part of the public record.

Comment 5: A resident asked for clarification regarding revegetation of the covered area in Site A. Specifically,
the resident was interested if the native species there now would be allowed to revegetate the area, and whether
the proposed planting would allow for wildlife habitat in the future.

Response: The final design for the biotic barrier will include a wetlands restoration component that will specify
wetland species consistent with the natural vegetation on the site perimeter where it transitions to wetland and
upland species over the upper cover area. However, to ensure that the integrity of the biotic barrier is not
compromised by intrusive root systems, only shallow rooted species will be reintroduced. Long-term monitoring
will include routine inspection of the cover, and if necessary, controls such as mowing and pruning will be
employed. The wetland habitat will be consistent with the surrounding area, and conseguently the wildlife habitat
is not expected to be impacted, and in fact some enhancement is expected.
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Comments 6 & 7: A resident commented on the fact that ten local communities in the immediate area have enacted
rigorous ordinances or standards regarding activities that might impact the swamp. The resident was concerned
that USFWS and their contractors implementing the selected remedy be in compliance with local groundwater and
surface water protection standards. Primary concern focused on potential impacts to groundwater guality in the
area, since many residents rely on private wells for potable water.

Response: The ARARs analysis and selected remedy work plans and design will consider regulatory reguirements at
all government levels. Furthermore, the selected remedy does take into account that there are numerous private
domestic water wells in the vicinity of the GSNWF, although most or all are in an up-gradient or side-gradient
location relative to OU-3 (see discussion in the Summary of Site Characteristics section of the ROD).

Private wells in the area were not at risk from the uncontrolled site and will not be adversely impacted by these
remedial actions. Shallow groundwater was sampled from the site and analyzed during the Phase II Remedial
Investigation (Foster Wheeler, 1997) and again during dewatering tests and prior to the drum removal action.
Results were compared to the most stringent applicable drinking water standards (NJAC 7:9-6). Metals detected
in groundwater were below state guidance criteria and asbestos with fibers greater than 10 microns in size was
not detected during the Phase II RI in any of the site monitoring wells, despite the fact that some of the wells
were screened in ACM. Removal of lead-impacted soil (Spring 1998) has addressed groundwater guality issues from
leachable metals. Two hundred and seven 55-gallon drums were removed from Site A, of which 50 contained some
organic and some metal wastes. Post excavation sampling from soils beneath drums removed from the site indicate
that leakage from the drums was minimal, where it was detectable at all (IT Corporation, 1997).

In addition, the detectable contaminant concentrations (all of which were below or just slightly above guidance
criteria for drinking water) were detected in shallow groundwater, the upper water bearing zone, which is not
used as an aguifer and directly discharges to surface water. Due to a thick confining layer of clay in the area,
private wells screened below this layer in the deeper aguifer are not likely to be impacted by site contaminants.
The selected remedy will protect groundwater guality through removal of lead-impacted soils at Site B, removal
of drums containing Resource Conservation and Recovery Act (RCRA) hazardous wastes from Site A, and containment
of other wastes with a biotic barrier. Although these source control activities have been demonstrated to be
protective of groundwater guality, groundwater monitoring of the shallow aguifer will be performed as part of
the site O&M plan.

Comment 8: EPA and a stakeholder expressed concern that groundwater monitoring was not explicitly identified as
a component of Alternative 3. The stakeholder also suggested that insufficient data exists in regard to assessing
the need for future groundwater monitoring.

Response: The FS recommended the need for additional environmental testing and determining the nature of the ACM
waste and associated drummed material at Site A. Since then, USFWS has been actively collecting data at the site,
and the selected remedy for OU-3 is consistent with the analytical results that have been observed since the FS
was prepared. The additional analytical testing has been summarized in the Predesign Data Report (Foster Wheeler,
September 1997) and the Rapid Response Risk Reduction Final Report (IT Corporation, December 1997). Key
information collected after the FS and Value Engineering study has been included in summary tables in Appendix
II of the ROD.

In summary, the data which was reviewed relative to the need for post-remediation groundwater monitoring includes
all data collected (pre-Phase II RI, Phase II RI and post-Phase II RI), such as:

• monitoring wells sampled before and during the Phase II RI,
• monitoring wells sampled in August 1997 prior to the drum removal action,
• analytical testing of water pumped from temporary well points during the Junel997 dewatering
pilot test,
• surface and subsurface soil samples collected before, during and after the Phase II RI,
• lead leachability at Site B, as determined through TCLP analysis,
• leachability tests for mercury on surface soil samples collected in June 1997 prior to drum
removal activities,
• analytical tests of the excavated drum contents, dewatering water, and post-excavation soil
samples taken from test pits from the drum removal interim action during September 1997.
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When considered collectively, all of this additional data indicates that source control through drum removal has
been successful. The post-drum excavation samples did not indicate exceedances above NJDEP residential soil
standards or soil impact to groundwater standards.

Furthermore, it was determined (Foster Wheeler, May 1997, September 1997) that the refuse material and soil from
Site B and RA#6 demonstrating elevated lead levels above 218 ppm or failing TCLP testing would be removed for
off-site disposal, which has now been completed. The mercury in surface ACM/soil at Site A is not leachable to
groundwater in concentrations above RCRA toxicity characteristic critera and is not being considered for off-site
removal (see also discussion in Summary of Site Characteristics - sections on Site Soils and Contaminant Fate
and Transport in the ROD).

The additional information collected to date, coupled with the presence of a thick confining clay layer below
the site indicates that impacts to groundwater from OU-3 are negligible. The hydrology at the site does show
strong interaction of shallow groundwater within the Site A ACM mound with the surrounding surface water and low
probability of interaction with groundwater in the deeper aguifer below the site. An effective monitoring program
for the shallow Site A groundwater can be designed for the points of recharge from and discharge to the
surrounding surface water and therefore surface water monitoring will be made part of the O&M for OU-3. Sampling
in this fashion would help to monitor for impacts from upstream sources which we know the GSWA is very concerned
about. In response to concerns about groundwater guality, however, shallow aguifer groundwater monitoring will
be performed. More details about O&M sampling specifications will be developed during the remedial action work
plan and remedial design phases.

Comment 9: A resident expressed concern that even non-friable asbestos be controlled during construction
activities, as handling could allow some release of asbestos due to deterioration. The resident asked if air
monitoring for asbestos would be part of the selected remedy.

Response: The construction phase of the selected remedy will include appropriate controls to ensure air-borne
asbestos is minimized and migration in surface water in contained. On-site air monitoring will be a component
of the construction plan. Once asbestos and ACM have been consolidated and covered, and is therefore no longer
accessible, air monitoring will be discontinued, but surface water and biota sampling will be ongoing.

Comment 10: In an oral comment, a resident reguested additional information regarding the nature and permanence
of the biotic barrier proposed for installation over the ACM and debris. The resident expressed concern that
erosion or material failure will allow release of the underlying material to the environment. A written comment
submitted by a resident also concerned the nature of the proposed barrier, and expressed skepticism that the
proposed biotic barrier would be sufficient to protect human health and the environment. The resident
particularly was concerned about exposures to children or animals due to digging or burrowing activities. The
resident proposed that the asbestos-containing material at the site be permanently removed.

Response: The biotic cover will be an engineered design with multiple components and specifications selected for
their durability and performance, and there will be long term maintenance. The design will include specific
reguirements regarding final slope of the cover and vegetative growth to minimize erosion. In addition, the
selected remedy includes drainage controls which are specifically designed to minimize potential erosion around
the periphery of the cover. The synthetic high permeability filter fabric employed in the biotic barrier design
will be a warranteed material which must meet engineering specifications. The biotic barrier itself is intended
to be permeable, since the ACM is inert and will not mobilize in groundwater. Given the inert nature of the ACM
and potential buoyancy problems that would be associated with an impermeable cap, USFWS has elected to place the
permeable biotic barrier over Site A.

Long-term monitoring outlined in the selected remedy includes periodic inspections of the cover to identify
potential damage or intrusion from either vegetation or burrowing wildlife. Corrective actions in response to
observed deficiencies will be outlined in the long term O&M plan.

The Feasibility Study and independent Value Engineering Report both recommended this option, as meeting the
necessary criteria outlined in the Record of Decision Alternatives Analysis.
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Since no mercury was found above the RCRA action levels (TCLP or UTS) which would be classified as RCRA hazardous
waste, the mercury-contaminated soil and ACM waste mound to be covered in place at the site would not be
considered a RCRA hazardous waste landfill and is not subject to RCRA capping requirements. The only material
which exceeded either criteria was the single drum of mercury contaminated waste removed and disposed of as
hazardous waste during the Phase II RI which was reported to contain mercury at 318 mg/kg (sample SWS02101).

Comment 11: A stakeholder posed several design related guestions about cover specifications and topographic
configurations of Alternative 3. Also, they asked for additional explanation of future public access limitations
and requested reconsideration of restoring the Great Brook channel close to its natural configuration by removing
the temporary culvert system.

Response: With regard to the design related details, it is premature to provide substantial details at the
Proposed Plan stage, however, there will be ample opportunities to review and comment upon the designs during
the remedial action work plan and detailed design phases. The final cover design for Site A will include minimum
soil covers, erosion control features, minimum slope requirements and vegetative cover that will minimize the
potential for erosion, and will be reviewed and approved by EPA. In accordance with ARARs, USFWS will also
develop an O&M Plan that includes periodic visits to the site to investigate signs of erosion and take corrective
action.

Future public access to OU-3 will be consistent with the Refuge Management Plan of the Wilderness Area. USFWS
is considering a more natural appearing crossing that is more consistent with a wilderness environment such as
a ford or system of stepping stones.

Comment 12 : A resident requested additional information regarding precautions to be taken in order to ensure that
material brought onto the site as part of the biotic barrier materials is clean.

Response: Design phase construction documents will include specifications regarding quality control requirements
for the cover material. The contractor will be required to provide analytical results to document that the
material is clean, and otherwise meets the engineering specifications, prior to delivery of the material to the
site.

Comment 13: A resident requested additional information regarding how asbestos was classified in regards to the
cost estimate developed for the alternatives analysis.

Response: Asbestos is not a RCRA-specified hazardous waste, however, it is classified as a special waste which
requires specific handling and disposal procedures in accordance with federal regulations 40 CFR 61.150, 40 CFR
61.154 and New Jersey regulations NJAC 7:26-2A and 7:26-6. The cost estimates were developed using estimated
quantities, current price quotes from disposal contractors, and cost data from recent actions conducted at the
refuge.

Comments 14& 15: In an oral comment, one resident asked what the immediate hazards of the site are, and why there
is a need to remediate it now, versus using the Alternative No. 1, which calls for no action. The comment was
in reference both to the value of the risk reduction and the cost of implementing the selected remedy. A written
comment from two residents also urged the selection of the "no action" alternative, citing cost and the lack of
discernible existing long term health effects on individuals who have resided in the area over an extended period
of time.

Response: The ecological baseline risk assessment for the site demonstrated that there are existing or were
potential (leaking drum contents) adverse impacts to wildlife species at the site due to the presence of a number
of metals. The selected remedy specifically addresses impacts to wildlife through design criteria for the biotic
barrier which will minimize exposure to the ACM and debris remaining on-site. The human baseline risk assessment
demonstrated potential impacts due to the presence of lead. Asbestos was deemed to pose no inhalation risks under
current conditions, but could pose future risk to human health or the environment. Similarly, the biotic barrier
will protect human health from potential future risks due to inhalation.
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The selected remedy is required to meet the requirements for remedial actions set forth in CERCLA ° 121, 42
U.S.C. ° 9621. Accordinqly, the remedy must: be protective of human health and the environment, achieve a level
of control of the site contaminants that attains the ARARs identified for the site, be cost effective, utilize
permanent solutions and alternative treatment technoloqies as practicable, and reduce the toxicity, mobility or
volume of the site contaminants. Implementinq the "No action" alternative does not meet these criteria, as
described in the RI/FS and Proposed Plan. Throuqh the alternatives analysis described more fully in the FS,
Alternative No. 3 was demonstrated to best meet all of the selection criteria.

Comments 16 & 17: A resident asked if the conclusions resultinq from the risk modelinq for the site, and
ultimately the choice of Alternative 3 as the selected remedy, were weiqhted in favor of human health, or was
the mission of the GSNWR qiven priority as it relates to the protection of wildlife? In related comments, NJDEP
requested that ecoloqical clean-up quidance values be added to the table of Contaminants of Concern (Table 4 in
the Proposed Plan) alonq with the NJDEP residential soil criteria; a stakeholder qroup also had comments about
the content of Table 4 - Human Health and Ecoloqical Contaminants of Concern.

Response: The baseline risk assessment was conducted in order to demonstrate what the impacts would be to human
health as well as the environment, includinq wildlife, if no action was taken to remediate the site. The risk
assessment conducted durinq the RI phase of the project indicated that there was relatively qreater potential
risk to the ecoloqical receptors on site than there would be to human receptors. Protection of the ecoloqical
receptors was therefore an important element of the alternatives analysis. That evaluation included
consideration of the Refuqe mission reqardinq protection of wildlife. The selected remedy specifically addresses
impacts to wildlife throuqh desiqn criteria for the biotic barrier which will minimize exposure to the ACM and
debris remaininq on-site. Table 13 of the ROD reflects the contaminants of concern for both human and ecoloqical
receptors. The Table was adapted from Table 4 of the Proposed Plan, and amended to show ecoloqical quidance
values as well as residential soil quidance values established to protect human health.

The intent of the Proposed Plan is to provide a short synopsis of pertinent site information and present the
preferred alternative for the public's review. Not every detail in the administrative record can be included in
this summary in the spirit of brevity. Table 4 of the proposed plan provides a brief summary of the contaminants
of concern (COG) that were addressed in qreater detail in the RI (Foster Wheeler, May 1997) and FS (SEA/ Foster
Wheeler, June 1997). An expanded table summarizinq the contaminants of concern relative to human health and
ecoloqical risk criteria is provided in Appendix II of the ROD. Furthermore, lead was determined to be the only
COG posinq potential risk to human health based on the extensive baseline risk assessment performed as part of
the RI phase. The risk assessment is presented in Chapter Six and Appendix H of the Final RI Report (Foster
Wheeler May 1997).

Comment 18: A stakeholder qroup expressed the need to reconsider whether future risks have been reduced because
of the drum removal action and called into question the characterization of several materials and contaminated
media at the site.

Response: Followinq drum removal from Site A and lead-contaminated soil removal from Site B and RA#6, materials
potentially classified as a hazardous waste will have been removed from OU-3. ACM is not characterized as a
hazardous waste but is considered a special waste. Groundwater sampled from monitorinq wells screened within the
mound which has slightly exceeded ARARs previously is expected to come into compliance without continued
contributions by releases from drum sources which have been removed. The mercury in surface soil (ACM) at Site
A has been shown not to be potentially classified as a characteristic hazardous waste throuqh TCLP tests and will
be brouqht into compliance with NJDEP soil cleanup criteria and sediment quidance levels throuqh cappinq.

In reqard to the potential risk from the possibility of remaininq buried drums and the elevated levels of mercury
at Site A, see also response to comments 2, 6, 7, 8, and 19.

Comment 19: A stakeholder expressed concern that the topic of mercury contaminated surface soils was not
adequately discussed in the Proposed Plan with reqard to the need for removal of potential hot spots.
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Response: As a follow up to the recommendations made in the FS, USFWS has taken steps to clearly delineate the
extent and potential leachability of the elevated mercury levels found at Site A during the Phase II RI and
Pre-Design Data Report investigation. The mercury delineation was done on a grid to determine overall
distribution as well as follow-up "hot spot" samples from suspected areas of elevated mercury. "Hot spots" were
considered to be areas of elevated mercury in soil or waste where the mercury was found to be leachable at levels
above the RCRA TCLP criteria (0.2 mg/L) or where it might exist at concentration; above the RCRA universal
treatment standard (UTS) (260 mg/kg) (40 CFR 268.40 Subpart D Treatment Standards). When the pre-phase II RI data
and Phase II RI data are combined with the grid sampling and potential hot spot sampling, the sampling density
across Site A is substantial. To address potential hot spots specifically, the follow-up samples (MD-13, 14, and
15) were collected in June 1997 from the area where ruptured drums containing mercury-contaminated wastes (up
to 318 mg/kg mercury) were removed during Phase II RI in 1996. In two of the three samples, mercury was reported
as not detected. In the third sample, a detectable concentration of mercury was reported at only .522 mg/kg.
Furthermore, the analytical results from the post-excavation samples from the drum removal can now also be
considered which also indicate no mercury hot spots exist on site.

Summaries of the data collected is provided in Appendix II of the ROD. Collectively, the data indicates that the
mercury is not leachable to groundwater and therefore no hot spots are present on Site A which merit removal or
addressing in a fashion other than capping the site with a biotic barrier to prevent direct human and biological
exposure and to prevent erosion into surrounding wetlands and surface water bodies.

Comment 20: A resident asked about future use limitations on the site. Was the site going to be returned to a
condition that would allow passive activities such as bird watching, or would the site be restricted from visitor
use in perpetuity?

Response: See Response to Comment 4, 5 and 11. Furthermore, the intent of the selected remedy is to allow the
site to become accessible to visitors for these kinds of activities. The Refuge Management Plan already restricts
access to some areas of the Wilderness Area in order to protect the wildlife and environmental resources. The
access restriction referred to as possible "institutional controls" is not intended to eliminate visitor foot
traffic on open trails, but rather will likely relate to activities that could potentially damage the biotic
barrier. The remedial design and O&M Plan will ultimately stipulate the nature and extent of access restrictions
in concert with the Refuge Management Plan. As a result, the end use of the site will be consistent with the
existing plan for the Wilderness Area.

Comment 21: A stakeholder requested additional explanation of the disposition of the ACM in the UAR.

Response: As part of the remedial design, the USFWS plans to reduce the footprint of Site A, since it is located
within an environmentally sensitive area. However, current design allows for final disposition of the ACM at the
UAR (approximately 520 cubic yards) within the consolidated materials at Site A.

Comment 22: A stakeholder pointed out that comments on asbestos remediation are included in the comments on the
removal action.

Response: The public comment period for the Proposed Remedial Action Plan (PRAP) closed in February 1998, after
the Removal Action Work Plan for Site B had been finalized. The Work Plan will be part of the public record,
although public comments are not being taken as part of the ROD. However, confirmation sampling at Site B
following the removal action for lead-contaminated soils demonstrated that asbestos remediation at the one
percent level has been achieved.

Comment 23: NJDEP requested that the RAO for prevention of contamination spreading be expanded to include the
phrase "during and after remedial activities."

Response: This has been added to the RAO discussion in the ROD.

Comment 24: In a written comment, the Passaic River Coalition, a local watershed association, expressed support
for the selected remedy and urged the USFWS to move forward with the project.
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Response: USFWS agrees with this comment and is pleased that Passaic River Coalition concurs with the selected
remedy.

Superfund Process/Procedural Issues

Comment 25: A resident requested clarification regarding the implementation schedule for the selected remedy.
When does the 15 month timeframe identified in the Proposed Plan begin?

Response: The 15 month estimated time for completion of implementation for the selected remedy was calculated
from the end of the public comment period. The remedial action will commence following public notice of the ROD,
and is expected to be completed within approximately six months. The ROD was submitted to EPA for review in early
April, and it is anticipated that the ROD will be signed in August. In order to take advantage of the naturally
lower waters at the Site during the summer months, the Remedial Action is planned for Summer 1998.

Comment 26: Several residents requested clarification regarding the funding mechanism for the 30 year O&M costs
reflected in the Proposed Plan. How were the costs developed and how will USFWS ensure that the money will be
available in the future?

Response: O&M costs are based on engineering estimates of net present value, calculated for a 30 year period
assuming a four percent growth rate and seven percent interest rate. The cost breakdown is provided in Table 28
of Appendix K in the FS (SEA, 1997) . The 30-year period is a typical requirement of Subtitle C and Subtitle D
landfills and the USFWS is obligated to fund the program. USFWS funding, as with all federal agencies, is
determined on an annual basis and is subject to congressional appropriation. The details of the funding
requirements will be described in the O&M plan once the remedial action has been designed and is completed.

Comment 27: NJDEP requested clarification regarding the discussion of Alternative 3's effect on mobility,
toxicity, and volume of waste.

Response: The discussion in the ROD has been modified to clarify this issue.

Comment 28: NJDEP requested more explanation of the estimated costs of components of Alternative 3.

Response: The discussion in the ROD has been modified, but the difference pointed out by NJDEP is for two
separate elements. The $600,000 in the Draft Action Memo is for Drum Removal only, while the $4,182,374 is for
the total remediation package of Alternative 3.

Comment 29: NJDEP noted that USFWS' schedule for Alternative 3 is very aggressive. They recommended relaxation
of the schedule to accommodate unanticipated delays.

Response: USFWS understands NJDEP's suggestion, but has deliberately planned a schedule to take into account
measures to minimize short-term and overall impacts to the Refuge and stakeholders while designing and
implementing the selected remedy. Several of the ARARs require minimizing short-term impacts. In order to do
this, and because of the seasonal nature of the wildlife nesting and migration habits and Refuge water management
practices for forage and weed control, compressing the schedule is desirable. Furthermore, funding considerations
also encourage completing the remedy as quickly as is reasonable and safety done.

Comment 30: The EPA and a resident asked if the NJDEP concurs with the selected remedy.

Response: Written comments received from NJDEP are provided in Attachment V. DOI response to these comments are
provided herein. NJDEP comments on the Proposed Plan were generally limited to requests for additional
clarification on issues discussed in the Plan, but were in agreement with the alternative selected. DOI responses
to the comments provided by NJDEP have been incorporated into the Responsiveness Summary, and where appropriate,
clarifications have been incorporated into the relevant sections of the ROD. The additional information requested
by NJDEP was available in documents that are part of the Administrative Record for the Asbestos Dump Site, and
do not represent new data or new information not otherwise available in prior documents. NJDEP concurrence is
indicated in the comments as well as its concurrence letter (Appendix IV).
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Comment 31: A resident asked about the nature of the Army Corps of Engineers involvement in the project, both
as a permitting agency for wetlands issues and as a contractor party to the actions taken to date at the site.
In particular, the resident reguested clarification about the permits that may be necessary for the dewatering,
drainage improvements, etc. which are part of the selected remedy.

Response: The State of New Jersey has been delegated authority to administer the Clean Water Act Section 404
Permit Program which includes criteria for evaluating impacts to waters and wetlands of the U.S. The USFWS is
reguired to substantively comply with all permit reguirements related to these activities. The involvement to
date from the Army Corps has not been in the capacity of a permitting agency, but strictly as a contracting
agency. However, the Army Corps is also obligated to meet the permitting reguirements, as would any other
engineering firm or construction contractor.

Miscellaneous Questions

Comment 32: EPA acknowledged that it was still reguired to send a supporting letter to DOI for the Proposed Plan.
EPA also reserved its final remedy approval until after review of the Draft ROD.

Response: USFWS acknowledges EPA's procedural reguirements and the seguential nature of many of the CERCLA
process steps.

Comment 33: A resident reguested clarification regarding how the 100-year flood plain elevation was established.
In addition, the resident asked if there was adeguate information available regarding surface water elevations
at the site and the freguency or extent of fluctuations during storm events.

Response: The 100-year flood plain was established based on Soil Conservation Service mapping and work done by
Apgar Consultants in the 1980's (Apgar, 1983). The 100 year flood elevations were confirmed based on detailed
recent investigation of the hydrology, based in part on data provided by visual gauges and electronic monitors
to gauge water surface elevations at multiple locations throughout the site. The area experienced a 100-year
storm event in October 1996, prior to deployment of the monitors, but observations from several sources indicate
that the flood elevations estimated are appropriate.

Comment 34: A resident commented on her interest in seeing the selected remedy for OU-3 fit into an overall
regional plan to protect GSNWR, particularly given potential upstream sources of contaminants.

Response: The hydrology of the site as influenced by upstream inflows and downstream discharges was considered
in the selected remedy and will be considered during remedial design. The OU-3 site is on the National Priority
List and as such is under a regulatory mandate for remedial action. The remedy was selected in accordance with
the reguirements of CERCLA and the NCP. Other regional issues may be addressed through other actions separate
from the remediation of OU-3.

Comment 35: Several residents raised issues regarding other upstream land uses or contaminant sources outside
of OU-3 or GSNWR which they believe might have impact on the GSNWR.

Response: As indicated by USFWS at the beginning of the public meeting, the purpose of the meeting was to allow
residents and interested parties to comment on the results of site investigations, the proposed plan and selected
remedy for OU-3. Comments unrelated directly to these issues are not within the scope of the proposed remedial
action and USFWS has no direct response to these comments.

Comment 36: NJDEP had some comments regarding the Draft Action Memorandum for Site B Removal Action. They
reguested specifically that the ACM cleanup criteria be identified.

Response: USFWS excavated Site B to less than one percent asbestos, as documented by laboratory analysis of
post-excavation samples.

Comment 37: NJDEP stated that it found the OU-3/Site B actions acceptable.

Response: USFWS is pleased NJDEP concurs with this planned set of actions.
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Comment 38: NJDEP has requested post-excavation sampling at Site B and other sites or placement of "Declaration
of Environmental Restrictions" on the sites if there are levels of residual contamination above acceptable
levels.

Response: The removal action at Site B and the OU-3 Refuse Areas included post-excavation soil sampling for lead
and asbestos. Proposed actions at other sites not in OU-3 are not part of the OU-3 ROD. USFWS expects that the
removal actions will address contamination effectively to manage future risk. Management of the Refuge areas will
be cognizant of conditions in the future and will adapt its management plans and practices accordingly to
minimize future risks to employees, visitors, and biota.
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APPENDIX V

RESPONSIVENESS SUMMARY
ATTACHMENT A

TRANSCRIPT OF PUBLIC MEETING
PROPOSED PLAN FOR TBE ASBESTOS DUMP
SUPERFUND SITE OPERABLE UNIT December 17, 1997

Page 1
[1]
[2]
[3]
[4] IN RE:
[5] PROPOSED PLAN FOR THE ASBESTOS PUBLIC
DUMP SUPERFUND SITE OPERABLE UNIT HEARING
[6] NO. 3
[7]
GREAT SWAMP NATIONAL WILDLIFE REFUGE,
[8] MORRIS COUNTY, NEW JERSEY
[9]
Wednesday, December 17, 1997
[10] Green Village Fire Department
529 Green Village Road
[11] Green Village, New Jersey
7:30 p.m.
[12]
[13] PRESENT:
[14] SYDNE MARSHALL, PhD
foster Wheeler Environmental Corporation
[15] For the department of the Interior,
U.S. Fish & Wildlife Service
[16]
Bill Koch, Manager
[17] Great Swamp National Wildlife Refuge
[18] PAUL COSTELLO, SEA Consultants
[19] KRISTA DOEBBLER, Project Manager
U.S. Fish and Wildlife Service
[20]
[21]
[22]
TAYLOR & FRIEDBERG
[23] Certified Shorthand Reporters
120 Washington Street
[24] Morristown, NJ 07960
973-285-0411
[25]
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Page 2
[1]
[2] MR. KOCH: Good evening and welcome.
[3] My name is Bill Koch. I'm the manager of the
[4] Great Swamp National Wildlife Refuge.
[5] I want to thank you all for taking time
[6] out of your busy holiday schedule to be here
[7] tonight for us to be able to present to you and
[8] have you comment on the preferred alternative, the
[9] preferred option for cleaning up the asbestos dump
[10] site on the Great Swamp National Wildlife Refuge.
[11] The site is located on the east side of
[12] Long Hill Road in Harding Township on the former
[13] Dietzman tract, and - and that's about all I'm
[14] going to get into at this point.
[15] I would like to turn the program over
[16] to Sydne Marshall, who is the community relations
[17] specialist for Foster Wheeler Environmental, one
[18] of our contractors to the Fish and Wildlife
[19] Service, Sydne.
[20] MS. MARSHALL: Okay. Welcome again
[21] this evening. We're glad that you came. We're
[22] glad we have a nice turnout tonight.
[23] I thought I would first start out by,
[24] number one, hoping and asking that you have all
[25] signed in. You've signed the sheet coming in. If
[1]
[2] you have not signed it, please sign it on your way
[3] out. This way we can keep people informed, keep
[4] you on the mailing list; if you're not already on
[5] the mailing list, we can add your name.
[6] I thought I would start out just by
[7] summarizing some of the community relations
[8] activities that U.S. Fish and Wildlife Service has
[9] sponsored basically over the past couple of years.
[10] It seems that they have really made an effort to
[11] be active and to try to incorporate comments from
[12] the community all along the way.
[13] First of all, they have set up two
[14] information repositories, one in the Long Hill
[15] Township free public library, and one at the
[16] Harding Township municipal building. And I hope
[17] that some of you have taken time to go there, to
[18] look at all of the various documents that are part
[19] of the public record that relate specifically to
[20] this project.
[21] There have been periodic meetings with
[22] local officials and telephone calls with people.
[23] They've been monitoring community concerns by
[24] telephone and by sponsoring three open houses,
[25] which we've had here in the past at this fire
Page 3
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PROPOSED PLAN FOR THE ASBESTOS DUMP
December 17,1997 SUPERFUND SITE OPERABLE UNIT

Page 4
[1]
[2] station. One - the first was in May of 1996, the
[3] second was in February '97, and the previous
[4] meeting to this was in May '97.
[5] This, in fact, is the only meeting that
[6] U.S. Fish and Wildlife Service was reguired to
[7] have for the public. It comes at a time when the
[8] proposed plan is available for - the proposed
[9] plan with the remedies, possible remedies for OU-3
[10] is available for public view. And they very much
[11] want your input on the proposed plan.
[12] We're looking for comments from you.
[13] You'll notice there is a court reporter here. Any
[14] comments that you make will be part of the public
[15] record. And, of course, there will be a
[16] responsiveness summary that follows this meeting,
[17] and will, in fact, incorporate any responses to
[18] comments that come in in the mail, also to U.S.
[19] Fish and Wildlife Service. Ultimately, all of
[20] this information will be incorporated into the
[21] record of decision, and will be made available for
[22] public view when it is completed.
[23] I have been asked to set the ground
[24] rules for tonight. I guess I'm the meanest guy on
[25] the project or something. We are hoping that if
[1]
[2] you have comments to make, that you will stand up
[3] or you can sit if you're loud enough, but the
[4] important thing is for us to hear your name and if
[5] you could please then spell your name, after you
[6] said it so that the court reporter can get it
[7] accurately.
[8] We are hoping very much that the
[9] discussion tonight will focus solely on OU-3.
[10] That is the purpose of this meeting. We know
[11] there are other concerns that you folks may have,
[12] and there will be other opportunities in the
[13] future to discuss those concerns, but the
[14] discussion tonight will be limited to OU-3. We're
[15] going to be fairly strict about that.
[16] I think at this point we will - I'm
[17] sorry. Written responses to comments.
[18] MR. KOCH: Will everybody's comments be
[19] responded to in writing?
[20] MS. MARSHALL: Individually? I think
[21] I'm going to defer to Kris about it.
[22] MS. DOEBBLER: My understanding is that
[23] we have to prepare a document that is actually
[24] called written response to comments.
[25] MS. MARSHALL: It will appear in the
Page 5
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Page 6
[1]
[2] document as a whole, but I'm not sure they'll get
[3] individual responses to the comments.
[4] MR. COSTELLO: It's an appendix.
[5] MS. MARSHALL: Okay. And that will
[6] become part of the what we call the responsiveness
[7] summary.
[8] If you don't feel comfortable making a
[9] comment this evening, if something occurs to you
[10] in the future, you have until January 16 to send
[11] in written comments. We do have forms in the
[12] front for written comments. You don't have to use
[13] a form, you can just write something down on a
[14] piece of paper and send it in. It will be mailed
[15] to Kris Doebbler in Colorado. The address is on
[16] the sheet that is available in the outer room
[17] in there.
[18] Okay. I'm now going to now turn over
[19] the meeting to Paul Costello, who is here with us.
[20] He is working from SEA Consultants. He's been
[21] assisting Foster Wheeler Environmental in
[22] preparing the feasibility study, and in preparing
[23] the proposed plan, and he's going to summarize and
[24] describe to you the various alternatives that are
[25] right now under consideration.
[1]
[2] MR. COSTELLO: Thank you, Sydne.
[3] Does everyone have a copy of the
[4] proposed plan? Would you like one? We have some
[5] up here. I'll be referencing this document
[6] verifying and defining some points.
[7] A VOICE: Do you have enough?
[8] MR. COSTELLO: Oh, sure.
[9] MS. DOEBBLER: Briefly, while Paul is
[10] getting ready here, I just wanted to reiterate
[11] what Sydne had said earlier about our public
[12] involvement process, and let you know this
[13] certainty will not be the end of our public
[14] involvement process. We'll continue to keep you
[15] informed as best we can. We'll continue to send
[16] out our fact sheets, and whenever necessary,
[17] whenever an activity is coming up, we are always
[18] happy to hear from anyone. And I'd like Robin
[19] Burr - right there, Robin is our local community
[20] site liason. He has a real nice presentation
[21] he's prepared that he can bring over to show you
[22] or your organization at any time, and he's always
[23] available to do that. And give him a call. His
[24] number, I think, most of you probably have it or
[25] it's in the proposed plan. Julie knows it by
Page 7
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Page
[1]
[2] heart. But I do appreciate you all being here and
[3] continuing to be a part of our process. It's been
[4] a really good experience for us to work with this
[5] community.
[6] MR. COSTELLO: Thanks, Kris.
[7] MR. KOCH: Excuse me one moment. This
[8] is Kris Doebbler, the project engineer with the
[9] Fish and Wildlife Services, Environmental and
[10] Facility Compliance Branch. Recently - that's
[11] the new title. It used to be the service
[12] pollution control offices. They have greater
[13] responsibilities. So if you had noticed that
[14] change in the office that Kris worked for, same
[15] person, just a little more responsibility and
[16] reorganization.
[17] MS. DOEBBLER: My supervisor Billy
[18] Umpstead may have cards with the updated address.
[19] MR. UMPSTEAD: Yes, I do. And this is
[20] my boss, Paul Camp.
[21] MS. DOEBBLER: We're all here.
[22] MR. COSTELLO: All set?
[23] MS. DOEBBLER: Yes.
[24] MR. COSTELLO: Thank you. It's a
[25] pleasure for me to be here. My name is Paul
Page 9
[1]
[2] Costello. I've been working on this project for
[3] the last couple of years with Foster Wheeler. And
[4] Mark Griswold, Foster Wheeler's project manager is
[5] in the audience as well. We have been working
[6] very closely in the last couple of years.
[7] The last time we met at the open house
[8] in May was to present the conclusions from our
[9] feasibility study. Many of you way have been
[10] here. The feasibility study was conducted in
[11] accordance with federal regulation to present the
[12] contaminants of concern at the site, define what
[13] all the limit of waste may be, define what the
[14] objectives of the cleanup would be, present a
[15] screening of available technologies to address
[16] those concerns, and outline some alternatives to
[17] cleanup the site.
[18] After that feasibility study was
[19] completed, Fish and Wildlife Services assembled a
[20] team of independent engineers and environmental
[21] scientists, seven in total, and that feasibility
[22] study underwent an independent value engineering
[23] study. That document was completed the month
[24] after we met with you, and that document is right
[25] here. That is called the value engineering
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Page 10
[1]
[2] report.
[3] The value engineering report generally
[4] substantiated the feasibility study. In general,
[5] the feasibility study concluded that there is a
[6] wide range of alternatives to address this site,
[7] ranging from a "no action" alternative, which is
[8] reguired under CERCLA that we at least look at,
[9] and then several other alternatives that generally
[10] ramp up the activities to clean up the site.
[11] If you look at page 3 of the proposed
[12] plan, in the upper right-hand corner, those
[13] alternatives are presented in the proposed plan.
[14] Alternative No. 1, as I said, is a "no
[15] action plan.
[16] Alternative No. 2, ramps up the
[17] activities a little bit more. It reguires
[18] institutional controls to limit access to the
[19] site, putting up fences, putting up warnings, and
[20] monitoring the site, generally, the surface water
[21] in the biota, the animals surrounding the site.
[22] That would allow for some protection, however, it
[23] doesn't generally address the issues at the site.
[24] Alternative No. 2A addresses the same
[25] things, but also looked into the removal of the
[1]
[2] potential drumn problem that we had at the site.
[3] That work has actually been conducted by the Corps
[4] of Engineers, and that work has been completed.
[5] We addressed that problem early on as a
[6] recommendation in the feasibility study because of
[7] the potential threat that that posed. As a
[8] result, 250 drums were removed from the site a few
[9] months ago.
[10] Alternative 3 then looked at some of
[11] the other problems. It called for the drum
[12] removal action, and then containing the asbestos
[13] problems at the site, controlling the surface
[14] water, preventing the surface water from eroding
[15] away the cap on top of the asbestos. So
[16] protecting the public health and the environment
[17] even further.
[18] In addition, that alternative called
[19] for monitoring of the site in the future. So that
[20] once that - the asbestos was somewhat contained,
[21] Fish and Wildlife Services would monitor the
[22] surface water and the biota and to make sure that
[23] over the years that remedial action was doing what
[24] it was designed to do.
[25] Alternative No. 4 went a step even
Page 11
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Page 12
[1]
[2] further and looked at excavating out all of the
[3] material at the site and putting it someplace on
[4] site at another location. And this - for this
[5] alternative, the material would be hauled and put
[6] on a liner so that there would be even more
[7] protection than the situation that may be out
[8] there now.
[9] Alternative five was the last
[10] alternative. We looked at excavating the stuff
[11] totally, and sending it to a facility that's
[12] permitted to handle it.
[13] The feasibility study also recommended
[14] that we look at removing the drums, and that's
[15] been done. But also said that, you know we can't
[16] make a decision on these things until we get some
[17] more information. The feasibility study
[18] recommended that additional surface water,
[19] groundwater sampling be undertaken to get a better
[20] feel for any potential leaching of that material
[21] in the future. It also looked at characterizing
[22] the asbestos to see if it could be treated in
[23] place, just to get more information. As a result,
[24] in September, all that data, that's sizeable, was
[25] presented in this predesign data report. That's
Page 13
[1]
[2] dated September 1997.
[3] As a result of the additional data that
[4] was collected, as a result of the value
[5] engineering study, the best and preferred option
[6] that we are recommending is Alternative No. 3.
[7] And this was actually the preferred alternative
[8] from the value engineering study, but the
[9] additional data, as I suggested, has reinforced
[10] that even further.
[11] Now, the decision to select Alternative
[12] 3 was based on the guidelines presented in the
[13] federal regulations. Each one of these
[14] alternatives has been weighted against nine
[15] criteria. If you will look on Figure No. 3 at
[16] the back of the proposed plan, each one of these
[17] alternatives was weighted first and foremost
[18] against protecting the public health and the
[19] environment. That's the first alternative.
[20] The second alternative, to make sure
[21] the remedy is complying with all of the regulatory
[22] reguirements. That's another criteria. There has
[23] to be short-term effectiveness and long-term
[24] effectiveness. This remedy has to survive the
[25] years, and the monitoring program has to support
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Page 14
[1]
[2] that the remedy is performing as designed. You
[3] have to look at a reduction of toxicity, mobility
[4] and volume. In other words, that materials aren't
[5] leaching into other sources that may cause
[6] potential harm to the public or the environment.
[7] It has to be implementable. You have to be able
[8] to construct it. The cost and state acceptance.
[9] The final reason why we're here tonight
[10] is the public acceptance. It has to be accepted
[11] by the public, which is the purpose for this
[12] meeting this evening.
[13] Just briefly,, to talk about the third
[14] alternative, the drums have been removed from the
[15] site. The remaining material is
[16] asbestos-containing material that is generally
[17] nonfriable. All of the surface water, groundwater
[18] tested to date does not indicate the presence of
[19] any asbestos in the groundwater surface water.
[20] There are some lead-contaminated soils
[21] at Site B. This is Site A. Site B is upwind a
[22] little bit in the refuge area that we're calling
[23] them. Fish and Wildlife Services has scheduled
[24] removal of those materials. And that work may be
[25] done in a couple of months. Kris can discuss that
[1]
[2] in a minute.
[3] The cap that we're proposing on top of
[4] the asbestos, the concern would be airborne
[5] particulates and burrowing animals that may get
[6] into that material. As a result, we're proposing
[7] a cap that's two-feet thick that will meet the
[8] minimum regulatory reguirements. That's one of
[9] the criteria. It will consist of six inches of
[10] clean soil to grade the site; 15 inches of a
[11] biotic barrier, a crushed stone so that animal
[12] can't burrow into it and get at the asbestos; and
[13] finally, a vegetative layer six-inches thick and
[14] we'll plant vegetative material, whatever, species
[15] along the edges and tightly seal the top to wake
[16] it compatible to the wilderness area. Each one of
[17] those layers his a filter fabric in-between it so
[18] these materials can't get cross - cross into each
[19] other.
[20] So with that said, that's what the
[21] proposed plan in a nutshell is recommending. That
[22] Alternative No. 3, the cost of each of these
[23] alternatives, if you look at table No. 6, as I
[24] said, each one of these alternatives looked at
[25] remediating the site further - further and doing
Page 15
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Page 16
[1]
[2] different things. Alternative No. 1, for example,
[3] the $95,000 solution, off site removal of all of
[4] this material at the time we prepared this report
[5] was $15 million. However, in the past couple of
[6] weeks the price for shipping asbestos off site has
[7] been driven even higher. That may even be higher.
[8] That would have to be looked at.
[9] But we're recommending alternative No.
[10] that has a price tag of about $4 million, and
[11] that work is scheduled to be done, implemented
[12] over a year to 15 months. So with that said, I'll
[13] turn the floor back over.
[14] MS. MARSHALL: We would like to open
[15] this up now to any comments that you may have on
[16] the proposed plan and OU-3.
[17] Yes. Can you state your name please.
[18] MR. GREENWAY: Roger Greenway,
[19] G-R-E-E-N-W-A-Y. Are you open to guestions, also?
[20] MS. MARSHALL: Well, we prefer
[21] comments.
[22] MR. GREENWAY: I would just be
[23] interested in the description of how the
[24] consolidation would be physically completed? If
[25] that's appropriate.
[1]
[2] MR. COSTELLO: I can answer that.
[3] Site B is about five acres in size.
[4] A VOICE: Site A. You said site B.
[5] MR. COSTELLO: Oh, sorry. Site A.
[6] Sorry. Site A. Thank God site B isn't five
[7] acres.
[8] Site A is also located in a wilderness
[9] area and has a lot of wetlands surrounding it.
[10] The purpose of the project, one of the objectives
[11] would be to limit the impact of wetness because of
[12] it being in the wilderness area and a refuge area.
[13] so as far as consolidation, the waste back in this
[14] area here is only two to three feet deep. So
[15] rather than just cover that, we can lose the
[16] wetlands back here, we will pull that back and
[17] place it on top of the landfill.
[18] This area here is relatively flat. It
[19] is within a hundred-year flood zone. So the
[20] surface water implication with this whole area, if
[21] we were to just come in and fill it, we
[22] potentially would damage an acre or two of
[23] wetlands. So we would rather consolidate it, pull
[24] the waste back, and then have less of a foot
[25] print. Hopefully, the idea would be to reduce
Page 17
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Page 18
[1]
[2] this to possibly two and a half to four acres of
[3] size through consolidation. Once we put the cap
[4] on them, there would be no net change in wetlands
[5] implications or flood plain area.
[6] MR. GREENWAY. Thank you.
[7] MS. FENSKE: Helen Fenske, Green
[8] Village, F-E-N-S-K-E, representing the Morris
[9] Parks and Land Conservancy.
[10] It's hard to make a statement rather
[11] than ask a guestion, but I noticed on page six
[12] where you talk about the modeling of risk and what
[13] went into weighing the ultimate decision to go
[14] with three, you do say some species will continue.
[15] Species, I suppose, do not mean humans, it means
[16] wildlife? Will continue to experience some risk
[17] for metals and OU-3, particularly at highest levels
[18] in the food web. Thus the local wildlife
[19] communities have been adversely impacted and would
[20] likely continue to be adversely impacted by the
[21] site and so forth.
[22] My concern is, as you weigh it, is the
[23] weighting - and this is a guestion, I guess, is
[24] the weighting based on human health as opposed to
[25] the mission of the refuge, which is primary also
Page 19
[1]
[2] for wildlife. And where does the weighting come
[3] Do we sacrifice the wildlife and does humans
[4] take precedent? And what led to that in terms of
[5] the way - what went into that Alternative 3? I'm
[6] rambling a little bit because its hard to ask a
[7] guestion when I'm trying to make it into a
[8] statement.
[9] MS. DOEBBLER: Mark Griswold would be
[10] happy to address that for you.
[11] MR. GRISWOLD: I will be pleased to
[12] answer that. The statement on page 6 - Mark
[13] Griswold with Foster Wheeler. The statement on
[14] page 6 refers to the risk that was modeled as a
[15] baseline condition. If nothing was done,
[16] Alternative 1 was done, that's the impact that you
[17] might still see at the site over time.
[18] MS. FENSKE: Is the species human or
[19] wildlife?
[20] MR. GRISWOLD: Wildlife species. We
[21] found that the risk assessment showed there was
[22] more impact, potential impact at the ecological
[23] sources then there was to human resources,
[24] primarily, because they're humans - human,
[25] because of the fact this is a wildness setting
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Page 20
[1]
[2] There is very infrequent access to the site by
[3] biologists and people from the refuge and
[4] trespassers and visitors to the site. So the
[5] amount of exposure they would have is very
[6] limited. So based on the current conditions,
[7] there's - there is very little risk to visitors
[8] to the site.
[9] So the risk modeling that was done was
[10] based on more impact demonstrated through the
[11] sampling process to the variety of species that
[12] modeled up the food chain to the predators.
[13] Predators were impacted more by the lead and the
[14] mercury at the site if nothing was done.
[15] Alternative 3 would, basically, address
[16] that by covering the materials so that none of the
[17] animals would be directly exposed to it. And
[18] that's how they would be put in contact with the
[19] materials which had the mercury, the lead,
[20] and even some other metals. So if we covered it,
[21] they cannot burrow in it, via - does not eat
[22] prey, herons eating frogs that will be swimming,
[23] they're not going to be in contact with it, and,
[24] therefore, that will address, that remedy will
[25] address that alternative condition.
Page 21
[1]
[2] MS. FENSKE: Okay. Thank you.
[3] MS. MARSHALL: Yes, sir.
[4] MR. STILLINGER: My name is Frank
[5] Stillinger, S-T-I-L-L-I-N-G-E-R. My comment,
[6] which you can easily rephrase into a guestion, the
[7] phrase "institutional controls and monitoring" are
[8] not well defined. Are these intended to be
[9] activities in perpetuity or short term?
[10] MS. MARSHALL: Do you want to address
[11] that?
[12] MS. DOEBBLER: We are required to write
[13] into the proposed plan a 30-year monitoring.
[14] That's what's required.
[15] A VOICE: Three zero?
[16] MS. DOEBBLER: Three zero.
[17] MR. STILLINGER: And "institutinal
[18] controls" what does that mean?
[19] MR. COSTELLO: If you look on page 8,
[20] Alternative No. 2. It talks about monitoring
[21] includes institutional monitoring, includes
[22] institutional controls along with 0 & M
[23] activities. Surface water monitoring and wildlife
[24] management would be conducted by refuge personnel
[25] currently practiced. Current institutional
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page 22
[1]
[2] controls, such as securing deed restriction,
[3] restricting site access, securing land use
[4] restrictions, I'm reading the bottom of page 8
[5] now, are in place and will have to be maintained
[6] to conform to the intent of this remedial
[7] alternative.
[8] So the monitoring will be consistent
[9] with the surface water in current wildlife
[10] monitoring that the refuge is doing. And
[11] institutional controls will be consistent with
[12] what is said on page 8.
[13] As far as Alternative 3, it's on page
[14] 9, the middle of the page, institutional controls
[15] will be established, long-term monitoring of the
[16] site would consist of surface water and wildlife
[17] monitoring, as is the current refuge practice.
[18] Other 0 & M activities would include mowing in a
[19] manner consistent with the wilderness setting, so
[20] forth and soon.
[21] So in other words, the refuge is
[22] currently managing wildlife at the site, and that
[23] would continue.
[24] Surface water, they're currently taking
[25] samples around the site, that will continue. In
[1]
[2] addition, there will be some extra mowing because
[3] now you have a cap so you need to maintain that
[4] area and make sure it's not settling or animals
[5] aren't burrowing into the cap. No trees would
[6] affect the integrity of the underlaying layers.
[7] We can answer that officially in the written
[8] comments.
[9] MS. MARSHALL: Sir?
[10 MR. FOX: My name is Paul Fox, F-O-X.
[11] Just one guestion.
[12] Alternative 3 talks about implementing
[13] the institutional controls on the opposite page.
[14] It's defined as access restrictions. My
[15] understanding is one of the things we
[16] considering in regard to the site, is being able
[17] to return the site to be publicly accessible in
[18] regardd to bird watching and that sort of activity.
[19] Is that still the intent or is it the intent to,
[20] in fact, restrict access in perpetuity?
[21] MS. DOEBBLER: Our intent is to open it
[22] up for - and Bill, you can expound on this. My
[23] understanding is that the refuge would like to
[24] have the trails that are currently closed in that
[25] area opened, and the birds like this area. It's a
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[1]
[2] nice upland area. We would like to be able to let
[3] people out there to watch those birds and watch
[4] the wildlife. Access restrictions can
[5] things, like, we don't want to have heavy
[6] equipment, such as tractors or bulldozers that
[7] might rip up the integrity of the cap. So by
[8] access restrictions doesn't necessarily mean human
[9] restriction. And that will be part of the
[10] wilderness management plan. The refuge will have
[11] to put that in their management plan and that will
[12] be up to the refuge how they choose to manage that
[13] Site.
[14] MS. MARSHALL: Yes, ma'am.
[15] MS. HINKLE: Penny Hinkle, H-I-N-K-L-E.
[16] take it then that Area A. Which would
[17] be three or four acres as its capped, will not be
[18] really allowed to revert to whatever the native
[19] species that were there, you've taken trees down
[20] and so on, it will be some kind of grass? You're
[21] talking about mowing.
[22] MR. COSTELLO: To some extent. We
[23] won't necessarily be mowing. The wetland species
[24] that we put in there subsequent, will be
[25] consistent with that area, and the botanists from
[1]
[2] the refuge area will be involved in developing
[3] that final design plan. There are some wetland
[4] species that will be shallow-rooted, they will be
[5] more than adequate and they won't damage anything.
[6] MS. HINKLE: And they will provide some
[7] type of wildlife habitat?
[8] MR. COSTELLO: Right. As far as large
[9] trees, that most likely will not be permitted. It
[10] will be wetland habitat. We have done that in the
[11] past to bring back wetlands on former sites.
[12] MR. BURR: We're not going to make the
[13] top of the cap a golf course. It's not going to
[14] be just a Kentucky bluegrass topping. Make sure
[15] you understand, that's not the intention.
[16] MS. DOEBBLER: Unless Bill wants it to
[17] be a golf course.
[18] A VOICE: He can feed the geese.
[19] MR. COSTELLO: I'll lose a lot of
[20] balls, that's for sure.
[21] MS. FENSKE: This area is in the
[22] wilderness area, isn't it? So you are constrained
[23] by that.
[24] MS. MARSHALL: Yes.
[25] MS. SOMMERS: Julia Somers,
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Page 26
[1]
[2] S-0-M-E-R-S.
[3] We are sort of - I've been waiting to
[4] see if we were going to verge into guestions and
[5] that was allowable, and you do seem to be
[6] answering a couple of guestions and I do have one.
[7] In your presentation you said that
[8] Alternative 3 would take an estimate of about 15
[9] months to complete. When does that 15 months or
[10] did that 15 months begin?
[11] MR. COSTELLO: It begins with this
[12] meeting here tonight.
[13] MS. SOMERS: Thank you. Another thing
[14] that is referred to in this remedial plan is
[15] monitoring, and from what you said this evening, I
[16] understand that apart from the sort of physical
[17] monitoring, you are talking about chemical
[18] sampling of water. But is there anything else
[19] beyond that as far as taking of samples of tissues
[20] of animals or anything else?
[21] MS. DOEBBLER: Yes. That would be
[22] consistent with what the refuge currently does.
[23] They have a program in place for surface water and
[24] bio-sampling. Robin or Bill, you may want to
[25] expound on that, but that would be in conjunction
[1]
[2] with what they already do. They would continue to
[3] do that around the site, downstream, upstream.
[4] MS. SOMERS: Well, then, I guess I have
[5] really a mini statement, which is that it would be
[6] very useful, I think, to have the kind of
[7] monitoring program that you anticipate included in
[8] here, and since it is over truly a long term
[9] you're talking about 30 years.
[10] MS. DOEBBLER: Yes.
[11] MS. SOMERS: I would like to see how
[12] you propose to fund it.
[13] MS. DOEBBLER: The five point - what
[14] is it up there? 4.1 million includes the 30 years
[15] of monitoring.
[16] MS. SOMERS: It does?
[17] MS. DOEBBLER: Yes.
[18] MS. SOMERS: Invested how?
[19] MR. COSTELLO: We have to make - we
[20] estimate that the capital cost would be about 3.9
[21] million, and the present value of the long-term
[22] monitoring over a 30-year period, is looked at to
[23] be $300,000. That's part of this cost. And what
[24] will happen is, once the remedy is constructed,
[25] operations and maintenance plan would be developed
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[1]
[2] in accordance with the federal regulations which
[3] will become a public document, and periodic
[4] sampling and results, a yearly report has to be
[5] submitted to EPA, and that's also public
[6] information. After a period of five years, EPA
[7] will open up that monitoring plan for comments,
[8] either to add to it or subtract from it. So it's
[9] all -
[10] MS. SOMERS: Not as far as the funding
[11] is concern?
[12] MR. COSTELLO: Not as far as the
[13] funding. So Fish and Wildlife Services, I
[14] believe, will set that money aside to fund it,
[15] proposed initial monitoring for 30 years,
[16] MS. FENSKE: It will not be subject to
[17] annual cuts, it will be there?
[18] MS. DOEBBLER: Yes.
[19] MS. FENSKE: As a dedicated fund?
[20] MS. DOEBBLER: Yes.
[21] MS. FENSKE: And the staff to undertake
[22] it will be there? We know all about staff cuts.
[23] MS. DOEBBLER: I'll come out and do it
[24] myself. How's that?
[25] MS. SOMERS: They did not put us up to
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[1]
[2] these guestions, by the way.
[3] MS. DOEBBLER: That's a very fair
[4] guestion.
[5] MS. SOMERS: Sorry, Julia Somers again.
[6] Going back and forth. It does seem to me that
[7] over a 30-year period, that is an extremely modest
[8] sum of money to continue a monitoring program of
[9] any -
[10] MR. COSTELLO: That's the present value
[11] of that money. So that assumes six, seven percent
[12] interest over a period of years. I don't have the
[13] number in front of me. It's based on annuities
[14] spread over 30 years with certain compounded
[15] interest and so forth.
[16] MS. SOMERS: That will be useful to
[17] have that set out in the plan so that - as was
[18] indicated by the earlier guestion from
[19] Ms. Fenske, we can be assured that the funding
[20] isn't going to disappear somewhere.
[21] MR. COSTELLO: We can add it in
[22] response to the written comments for that
[23] guestion, we can put that in there, make sure we
[24] calculate that number.
[25] MS. MARSHALL: The gentlemen in back of
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Page 30
[1]
[2] Ms. Summers had 2 question - a statement.
[3] MR. CASSA: Yes. George Cassa,
[4] C-A-S-S-A. I have two comments.
[5] The first concerns the - Figure 3,
[6] cleanup evaluation criteria on the back of your
[7] handout. The second item is compliance with
[8] applicable or relevant and appropriate
[9] requirements concerning compliance apparently with
[10] federal and state environmental laws and
[11] standards, etcetera.
[12] My comment would be, I would hope that
[13] you have already taken into account or, if not,
[14] you will take into account the very rigorous local
[15] standards which have been enacted and are in the
[16] process of being enacted in the ten towns
[17] surrounding the swamp.
[18] The main concern that I would have is
[19] that the protection of the swamp has been the
[20] focus of many of these local regulations, and if
[21] it's learned that the owner and contractors of a
[22] remediation within the swamp itself are allowing
[23] themselves more freedom than, say, a private
[24] developer would have on his own property, a lot of
[25] the work that has gone to raise the level of
[1]
[2] environmental standards may be lost.
[3] I think that if you wanted to get
[4] copies of the applicable requirements, you would
[5] probably not have any trouble in getting them
[6] directly from local governing bodies.
[7] The second comment concerns a statement
[8] which I do not find in this handout but which
[9] appeared in some of the preliminary materials
[10] which was circulated to the Harding Township
[11] governing body, there was a statement to the
[12] effect that contamination of water was not
[13] considered a risk because the nearest source of
[14] public drinking supply was some ten miles away.
[15] I'm assuming that the contractors are
[16] aware that all of the public - all of the
[17] drinking water in the immediate area is from
[18] private wells, and there is a great concern that I
[19] have specifically because there's about five
[20] houses between my own and that site, that what
[21] you're doing will not even for an interim period
[22] make the situation any worse than it already is.
[23] MS. MARSHALL: Thank you for your
[24] comments.
[25] MS. SOMERS: I just had a quick
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Page 32
[1]
[2] question, which was based also on Figure 3,
[3] No. 8. It indicates that one of the processes
[4] that you go through is a state acceptance. And I
[5] was wondering if that was complete?
[6] MS. DOEBBLER: Is there anyone from New
[7] Jersey DEP here tonight?
[8] Everything, as you probably know from
[9] documentation that we've had circulating, New
[10] Jersey DEP is not a party to the draft federal
[11] facilities agreement which we're negotiating with
[12] the EPA. However, they received everything, and
[13] before it is finalized, for comment and review.
[14] And that's their involvement. So they receive
[15] everything. When EPA does pre-publication for
[16] final document storage in the repository and as
[17] part of the record, they get it ahead of time.
[18] MS. SOMERS: This comment indicates
[19] they actually have to take some kind of action.
[20] Because it says that "they agree with or oppose,"
[21] or are you assuming that because they don't have
[22] anything to say, that they, therefore, have no
[23] comment on the preferred alternative?
[24] MS. DOEBBLER: Helen, would you like to
[25] add anything to this about New Jersey's
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[1]
[2] involvement in the process?
[3] MS. SHANNON: The fact that they have
[4] looked at this information and haven't
[5] opposed it, one has to assume that they are not -
[6] I mean, Kris, you can - as I've kind of said, you
[7] might want to get in touch with the project
[8] manager who - from the state and see if you can
[9] get, perhaps, a concurrence letter from them that
[10] actually concurs, but I would just assume, you
[11] know, that if they're not opposing it,they
[12] certainly would be here tonight, I would think, or
[13] actually would have said - given you comments
[14] prior.
[15] MS. SOMERS: I think you assume too
[16] much.
[17] MS. MARSHALL: They have been
[18] represented at past meetings, there have been DEP
[19] people who have come.
[20] MS. SHANNON: Actually, from the OU-1
[21] and 2 areas, the state has been involved in that,
[22] and have had very minor comments on the plans -
[23] the remedies that occurred there.
[24] MR. KOCH: Helen, could you identify
[25] yourself for the reporter.
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Page 34
[1]
[2] I'm sorry. Helen Shannon, EPA.
[3] MR. CASSA: George Cassa again.
[4] Its my understanding that in New
[5] Jersey since 1944, the Corps of Engineers have
[6] acceded or granted the enforcement of certain
[7] environmental regulations to the State of New
[8] Jersey DEP under a program that is applicable
[9] nationwide, but only one or two states are taking
[10] advantage of that. But the comment that I have
[11] is, it's not clear given that the Corps of
[12] Engineers appear to be a party to this project,
[13] what, if any, effort does the DEP have to play at
[14] all?
[15] In particular, it would seem that the
[16] selected alternative specifically reguires
[17] dewatering, drainage improvement, and some
[18] diversion of creeks or brooks. It's not very
[19] clear. If that is the case, it does seem to me
[20] that federal reguirements are now under the
[21] jurisdiction of the state, and I would hope that
[22] might be clarified, if possible.
[23] MR. KOCH: Bill Koch. The program I
[24] believe you're referring to, Mr. Cassa -
[25] MR. CASSA: Cassa.
[1]
[2] MR. KOCH: - is the 404 wetlands fill
[3] internment program that the Corps has given to the
[4] New Jersey DEP, one of the few states in the
[5] nation to assume that. And this project, I might
[6] need a little help on this, we may not in every
[7] instance reguire- be reguired to obtain the
[8] permit, however, we must meet the intent of the
[9] permits; such in the instance of the state permit
[10] if it's a wetland fill permit, we would be
[11] expected to meet the intent and - but we wouldn't
[12] have to obtain that permit in writing. Is that -
[13] am I right on that? Can anyone back me up on
[14] that?
[15] MS.DOEBBLER: Yes, you have to - we
[16] have to substantively comply with all permit
[17] reguirements, and the Corps of Engineers is
[18] actually serving as a contractor to us. They're
[19] not a party to this proposed plan, they are
[20] actually - we would go out and hire an
[21] independent engineering firm. That's exactly the
[22] capacity that they are to us. So if they go out
[23] and do work for us, they're - they're reguired to
[24] comply with all of the permitting reguirements.
[25] They don't get to skip anything because they're
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[1]
[2] the Corps working as a contractor for us.
[3] MR. CASSA, But I would then presume
[4] that documentation of some sort would exist in the
[5] record that would prove that the intent is met
[6] even if the official permit form is not filled
[7] out?
[8] MS. DOEBBLER: Yes, sir. And it is
[9] in - to date what we've done is in the
[10] repository, soil erosion control plans, things
[11] like that, wetlands permitting.
[12] MS. MARSHALL: Yes.
[13] MR. GREENWAY: Roger Greenway.
[14] I had a comment on the nature of the
[15] material. I've heard it ddescribed as being
[16] nonfriable. However, I realize that nonfriable
[17] material can be made friable by moving it and
[18] handling it. So my concern is that the material
[19] be kept constantly wet during this consolidation
[20] process.
[21] I also have concern, I didn't see air
[22] monitoring in Alternative 3 in this document,
[23] although, I did see it in other alternatives, and
[24] I think it's important that we have continuous
[25] upwind /downwind air monitoring for airborne
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[1]
[2] asbestos during the consolidation phase and
[3] capping, phase of the projects.
[4] MS. DOEBBLER: Yes, we agree. And we
[5] have done air monitoring on the other actions that
[6] we've taken on the site periphery and personal
[7] monitoring on the workers, and we will continue to
[8] do that.
[9] MR. GREENWAY: That is part of the
[10] plan?
[11] MR. COSTELLO: That's part of the
[12] construction plan. There will be air monitoring
[13] done during the course of construction, as it has
[14] been from day one. The long-term monitoring,
[15] since the asbestos is no longer exposed, it's
[16] being covered, that air monitoring is not
[17] reguired.
[18] MR. GREENWAY: Right. Thank you.
[19] MR. STILLINGER: Technical issues
[20] concerning -
[21] MS. MARSHALL: Can you give your name,
[22] please.
[23] MR. STILLINGER: Frank Stillinger.
[24] Figure 4, the capping structure, at
[25] least on a guick survey, I wasn't clear on how
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Page 38
[1]
[2] permanent this structure was intended to be. In
[3] particular, whether it would be subject to water
[4] erosion down at least through the vegetative layer
[5] at the top. It wasn't clear what this filter
[6] fabric was and how permanent it will be. And
[7] particularly, it wasn't clear whether one would
[8] have to revisit the site and redo this structure
[9] to neutralize the underlying nasty stuff.
[10] MR. COSTELLO: To address your guestion
[11] how permanent, it's intended to be permanent.
[12] As far as erosion of the vegetative
[13] layer, that's where the drainage control component
[14] of the design comes in. Consolidation, pulling
[15] back the waste, we'll make sure that the slopes up
[16] to the hundred year flood elevation are adeguately
[17] protected so it doesn't erode. If this
[18] costly materials, possibly we'll look into that.
[19] However, we can do that with wetland material so
[20] it's more aesthetically pleasing.
[21] As far as the filter fabric, the filter
[22] fabric material is a - a general material that's
[23] used on a lot of construction sites and it has
[24] some warranty service for many, many years, and
[25] it's a very durable material. It's a synthetic
[1]
[2] material. And does that answer your guestion?
[3] MR. STILLINGER: The word "permanent"
[4] seems to have a very flexible definition.
[5] MR. COSTELLO: As far as the long-term
[6] monitoring -
[7] MR. STILLINGER: Permanent press means
[8] about two washings. I assume you mean more
[9] permanent than that?
[10] MR. COSTELLO: Part of the long-term
[11] monitoring of the site in addition to any -
[12] looking for animals burrowing into the cap, a walk
[13] over the whole area is reguired periodically on a
[14] guarterly basis to make sure that the integrity of
[15] the cap - that no areas are being eroded, that
[16] the integrity of these materials are being
[17] sustained. If the - if the filter fabric becomes
[18] damaged, you'll notice it with settlement at the
[19] surface and as part of the monitoring plan,
[20] corrective actions will be outlined. So that if
[21] there is damage that's detected, Fish and Wildlife
[22] Services will have to repair it.
[23] MS. SOMERS: Julia Somers.
[24] I'm curious to know how the elevation
[25] of the 100-year flood plain was established?
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Page 40
[1]
[2] MR. COSTELLO: That's all outlined in
[3] the feasibility study. I can show you after the
[4] meeting where it's outlined, but it's based on
[5] soil conservation surface mapping on the site and
[6] work done by Apgar in the mid-'80s.
[7] MS. SOMERS: It's my understanding that
[8] water - surface water elevations through this
[9] site rise very rapidly based on even a two-year
[10] storm event.
[11] MR. COSTELLO: Right.
[12] MS. SOMERS: And so I was concerned
[13] that if you were using a standard 100-year flood
[14] elevation, it may not, in fact, reflect reality
[15] for this site.
[16] MR. COSTELLO: We were very fortunate
[17] as well last ymr.
[18] MS. SOMERS: Yeah, we had one.
[19] MR. COSTELLO: Two of them. I was
[20] actually there the day after it happened. So we
[21] monitored surface water during that storm, and
[22] that was - I believe it was a 200-year storm
[23] MS. SOMERS: Did you monitor it three
[24] days later?
[25] MR. COSTELLO: Through visual
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[1]
[2] observations of the elevations of the surface
[3] water along Long Hill Road which had become
[4] flooded. We have a pretty good idea what the
[5] surface water elevation was last October 19.
[6] MS. DOEBBLER: Mark Griswold.
[7] MR. GRISWOLD: Mark Griswold with
[8] Foster Wheeler.
[9] One of the points that the feasibility
[10] and value engineering study pointed out was how
[11] the surface water reacted to the storm events.
[12] Currently as we speak, there are electronic
[13] monitoring devices in a number of wells and
[14] surface water structures in the streams out there
[15] that record elevations of the water every 30
[16] minutes. And we go out there every six months and
[17] download that on the computers so we can plot it;
[18] initial round of that data, first six months -
[19] the first three months of those monitors being in
[20] the site. It's in the predesign interim report,
[21] and it will be done. We'll have instantaneous
[22] records, voluminous data on the behavior of the
[23] surface water out there. Before the surface water
[24] was restructed this summer during the surface
[25] water control activities that took place, as well
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Page 42
[1]
[2] as after, during construction, and we'll continue
[3] monitoring after that. So we'll have a good sense
[4] of that.
[5] MS. SOMERS: How long do you anticipate
[6] that monitoring to continue?
[7] MR. GRISWOLD: We can leave them in
[8] place as part of this program. Those are fairly
[9] durable instruments. You put new batteries in it
[10] time to time.
[11] MS. DOEBBLER: Some of them are in
[12] wells that will be abandoned, but the rest of them
[13] can be left in place.
[14] MR. GRISWOLD: We can redeploy them in
[15] a number of places. It will get us very good
[16] readings on that.
[17] MS. SOMERS: It will be useful data, I
[18] think, to have it.
[19] MS. FENSKE: Helen Fenske again.
[20] First of all, I'd like to compliment
[21] you on the public process. I think your effort
[22] has been substantial, and the information that you
[23] shared with all of us has transmitted a sense of,
[24] I think, genuine partnership. And the process of
[25] involvement has been wonderful. It's been one of
[1]
[2] the best that I've had in my 35 years of
[3] experience. So I would like to say cheers for
[4] that.
[5] And my second point is, that we often
[6] refer to the preservation of Great Swamp as two
[7] battles. One, was first to establish the refuge.
[8] And in looking back that was almost simple
[9] compared to the second battle, which is
[10] continuous, which is to prevent it from just
[11] becoming a cesspool. In that process, and it's
[12] been going on now almost eight years, the emphasis
[13] has been on regional. It came from DEP
[14] establishing an advisory committee of the DEP
[15] The message coming out, we can no longer protect
[16] Great Swamp unless it's a regional approach. And
[17] the ten towns that have gotten together; they have
[18] made real headway, and the ordinances that are
[19] beginning to become - beginning to be passed, are
[20] based on that regional approach to protect the
[21] whole watershed. I'm being very windy about this.
[22] Superfund Site No. 3 is downstream of a
[23] hundred and eighty acres, as you know, the Miele
[24] landfill, directly downstream and yet because of
[25] your charge and your mission, you had to just
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Page 44
[1]
[2] focus on this piece, and it appears to me that
[3] it's - because of your constraints, it was
[4] unrelated to the regional approach and what might
[5] happen.
[6] Now, this meeting tonight is an
[7] investment and/or a process to decide that a $4
[8] million investment is the best thing to be put in
[9] place to handle this. And yet it seems to me it's
[10] unrelated to what might happen upstream in an area
[11] that hasn't been investigated very much, except
[12] for Mr. Fox's review a little bit with EPA. DEP
[13] has repeatedly said there's no - no problem here.
[14] We have no scientific basis. That's because they
[15] have not done any investigation. But you've got a
[16] stake in that. And I just wondered how this
[17] solution relates to that regional approach? I'm
[18] wondering if you wouldn't comment on it. I mean,
[19] so you're looking at this and this could be very
[20] successful and then have a bomb explode further on
[21] up with a lot of new information once they get
[22] into it. And it seems to me that you can't be an
[23] island in this whole regional approach.
[24] MS. MARSHALL: We really appreciate
[25] your comments, but I know that I am being told
[1]
[2] that we need to keep this just on OU-3 for
[3] tonight. These other issues will be discussed,
[4] MS.FENSKE: This is on - how does
[5] this site relate to the regional water shed?
[6] MS. DOEBBLER: I'll just briefly,
[7] Sydne, and we can speak afterwards, too.
[8] MS. FENSKE: I think you anticipated
[9] this guestion. So that's okay. I still want to
[10] persist with it.
[11] MS. DOEBBLER: I think that we can
[12] share with you later on what's up with the
[13] upstream site. But I will say that Operable Unit
[14] is on the national priority list. The way we
[15] deal with sites in the Department of the Interior
[16] where we get our money, is we have to go in and
[17] get in line and those sites that get priority are
[18] the ones that have EPA or state regulatory
[19] concerns that we have to deal with. So that's why
[20] OU-3 is on the top of our priority list. However,
[21] I don't think any of us would argue that that
[22] upstream site has got to be addressed, and we need
[23] to learn more about it. I think we all agree with
[24] that.
[25] MS. FENSKE: Okay. A fragmented
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Page 46
[1]
[2] approach to managing water and its hazardous waste
[3] over the years since the Clean Water Act was
[4] passed, has been fragmented, has not succeeded as
[5] a result. I mean, the world of enlightenment is
[6] you have to deal with a water shed. What comes
[7] from upstream, and you're downstream. And I can
[8] understand what's happening. It was a priority,
[9] but it's still a piece, and today with EPA going
[10] the water shed route, the nation going the water
[11] shed route, certainly this state, it seems to me,
[12] that you've got to relate - there's got to be
[13] some protective measures taken of your cleanup
[14] measures, cleanup efforts here on this project,
[15] and some effort has to go in to thinking about how
[16] that protection should take place. A protection
[17] isn't just sealing it and monitoring it, it's
[18] anticipating what's going to happen upstream.
[19] Oh, well.
[20] MR. BURR: Robin Burr again from Fish
[21] and Wildlife Service.
[22] Helen, Miele landfill was indirectly
[23] considered during the study investigation and will
[24] be in the monitoring of this project because we
[25] did sampling upstream of the site. That's all I
[1]
[2] can say. So it is a very narrow focus. We did
[3] consider the presence of Miele because monitoring
[4] will include an upstream station. I want you to
[5] be sure you understand that, and the public here
[6] understands that, also.
[7] MS. FENSKE: That's a good comment.
[8] MR. BURR: That's all I'll say now.
[9] MR. JANSEN: Robert Jansen.
[10] MS. MARSHALL: I'm sorry to interrupt
[11] you? Can you spell your name for the court
[12] reporter.
[13] MR. JANSEN: J-A-N-S-E-N.
[14] MS. MARSHALL: Thank you.
[15] MR. JANSEN: Upstream, once we got
[16] sewer plants, we were dumping into the Black Brook
[17] and coming down through the landfill and into the
[18] Great Swamp. Thats where they get rid of their
[19] water. It's true. Again, it's upstream. What
[20] are we going to do about them, their sewer plants?
[21] MS. MARSHALL: Well, right now we have
[22] to focus on OU-3. Your comment is in the record.
[23] And it will be discussed in a future meeting.
[24] MR. JANSEN: Two: 25 years ago, I'm -
[25] not an environmentalist, I admit that, this place
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Page
[1]
[2] would have been a metropolitan airport and
[3] everybody seemed to be against at that time.
[4] Certain people. And I thought I saw nothing wrong
[5] with it at that time, and I see nothing wrong with
[6] it now, making it into an airport.
[7] MS. MARSHALL: Okay. Thank you for
[8] your comment.
[9] Yes.
[10] MS. TIELMANN: I have a guestion.
[11] MS. MARSHALL: Could you state your
[12] name, please.
[13] MS. TIELMANN: T-I-E-L-M-A-N-N.
[14] You investigated an alternative for the
[15] propect of having it off site. That was one of
[16] the alternatives. I'm curious to know how you
[17] classified this ACM in your cost estimate for
[18] disposing it off site? Is it considered a
[19] hazardous waste, or is it considered construction
[20] debris, RD 27, what is it classified as?
[21] MR. COSTELLO: Asbestos is considered
[22] special waste. It has its own set of regulations
[23] for off-site disposal. The cost we use in our
[24] cost estimate was based on the Corps of Engineers'
[25] work that they did last year removing some of the
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[1]
[2] asbestos that was on site. Asbestos just cannot
[3] loaded into a dump truck and shipped away. It
[4] needs to be placed in bladder bags and handled
[5] specially. It has to be sent to a special
[6] facility. It has to have a special permit to
[7] handle that. It's not guite a RCRA hazardous
[8] waste, TSCA waste, it's a special waste.
[9] MS. MARSHALL: Yes, sir.
[10] MR. SCAFF: Harold Scaff.
[11] MS. MARSHALL: Would you spell your
[12] name, please.
[13] MR. SCAFF: S-C-A-F-F.
[14] MS. MARSHALL: Thank you.
[15] MR. SCAFF: I'm confused on things.
[16] What is the immediate hazard of this OU-3 or
[17] whatever they're calling it, Dietzman site? Are
[18] we in danger today? Is there a hazard immediate
[19] right now? What's the danger?
[20] MR. COSTELLO: Similar to what Helen
[21] said earlier, you have to plan for the future.
[22] One of the potential future risk was the presence
[23] of the drums at the site, but that's been
[24] alleviated at this point. Now asbestos has been
[25] left in place and some lead-contaminated soil also
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Page 50
[1]
[2] at Site B. Based on the risk assessment that
[3] Foster Wheeler completed and summarized in our
[4] report, lead is an ecological and potential health
[5] risk. So that will be alleviated in the coming
[6] months.
[7] Groundwater is relatively clean.
[8] Surface water is relatively clean. So the
[9] potential risk, if it migrates out of the soil
[10] that it's in, so it needs to be managed properly.
[11] There's no immediate risk, to answer your guestion
[12] that way. So we're trying to deal with potential
[13] future risk. As far as the asbestos in the mound,
[14] if it's left uncovered, the airborne particulates,
[15] wildlife gets to dig into it and carry it around
[16] through the ecosystem, so we need to deal with
[17] that by just simply covering the asbestos in
[18] accordance to the regulations.
[19] MR. SCAFF: If there is no immediate
[20] risk and it's been there for 40 years, is it
[21] getting better or worse?
[22] MR. COSTELLO: If you look on page -
[23] MR. SCAFF: I read it briefly. I
[24] haven't gone into it in great detail. I don't
[25] understand why we want to fix it if it ain't
[1]
[2] broke. Stirring up asbestos is about the worse
[3] thing you can do. If you just leave things alone,
[4] I think we're - you know, I worry more about
[5] fooling with it then leaving it them.
[6] MR. GRISWOLD: Mark Griswold with
[7] Foster Wheeler.
[8] I'll try to clarify how we calculated
[9] the risk. We followed all of the procedures that
[10] are reguired by EPA and all their guidance
[11] manuals, and based on the sampling that we did, we
[12] found that there were several metals present in
[13] the soils at the site. Based on the modeling that
[14] was done, direct contact with said soils over a
[15] period of time and the assumption you would get
[16] dirt on your hands, eat food after you've had that
[17] in your mouth - to get the soil in your mouth
[18] after touching it, that would be out of direct
[19] contact by humans. It would be impacted - you
[20] won't have direct contact with the soil at the
[21] site. So that's how that modeling was done.
[22] The same thing for the impacts to the
[23] wildlife. It was based on their consumption of it
[24] by living and eating it, from being there. We
[25] found that animals out there did have detectable
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[1]
[2] concentrations at low levels in their tissues from
[3] being exposed to materials. The best way to
[4] handle that is for some of the materials to be
[5] encapsulated, covered, and some materials can be
[6] removed from the site.
[7] MR. SCAFF: We have some three-acre
[8] piece sitting there all by itself, how is that
[9] affecting the whole - it's - it's - and I don't
[10] see animals picking up truckloads and running over
[11] an area. What they pick up on their feet would be
[12] minute. I hear you, but I don't see where this
[13] disturbance is creating any hazard more than
[14] anywhere near what you're proposing to do, stir it
[15] up and move it around.
[16] MS. DOEBBLER: Actually, your point is
[17] well taken, and that is one of the main reasons
[18] that our value engineering study came up with that
[19] big risk, was picking it up and hauling it all to
[20] another site in some other landfill somewhere else
[21] in the country that then you have the risk of
[22] machines scooping it up, putting it in trucks, the
[23] trucks hauling down your roads past your homes.
[24] In fact, we're talking, like, 2200 truckloads to
[25] get it out of there, and that was definitely
[1]
[2] Chemical, and it's a refuge for cars, trucks, and
[3] so on, and they grind it. It is in the air. They
[4] don't - I worked on their doors - I'm a garage
[5] door man, by the way. I sat in the dust. The
[6] dust is up in the rafters. I don't know how many
[7] times - people work in it, and that's upstream
[8] from us. Where that goes, I think any residue
[9] will probably go into the Whippany river and down
[10] away from us but not down this way. But there
[11] they are. They're operating with dust. We're
[12] talking a little dust from a truck turning over?
[13] This is dust in the air every day.
[14] MR. SCAFF: What they want to do -
[15] what you're talking about is nothing compared to
[16] what they're talking about disturbing.
[17] MS. MARSHALL: Mr.Cassa, do you have
[18] a guestion?
[19] MR. CASSA: Yes, since my last comment -
[20] was phrased as a comment and not a guestion, there
[21] was no response for the comment. But I am
[22] concerned about the possibility that the lead
[23] levels which are addressed in some of the
[24] materials which were deemed not a hazard because
[25] of the fact that drinking water is not taken from
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Page 55
[1]
[2] a a nearby area, I think that's incorrect. And I'm
[3] really asking now and not commenting, does your
[4] recommendation take into account the fact that
[5] there are probably anywhere from 12 to 24 private
[6] wells within a one-mile radius of that site? And
[7] if it does not, how would that impact the
[8] recommendation that you would make?
[9] MR. COSTELLO: Summarizing, the risk
[10] assessment did take that into account, and the
[11] lead levels we are seeing in the groundwater were
[12] compared, the levels right them around the dump
[13] were compared to the drinking water standards. In
[14] the recent investigations that were conducted in
[15] the past few months, conducted additional
[16] investigations that were recommended in the FS, so
[17] we have a better handle on what is the leachable
[18] component of the lead in the soils, and those
[19] soils, as I said, will be addressed separately and
[20] may be hauled off site. So we are investigating
[21] the potential leachable lead levels in the soils.
[22] MR. CASSA: Then in order to address
[23] what might have to be hauled off the site, would
[24] you treat that separately or is it commingled with
[25] the asbestos?
[1]
[2] MR. COSTELLO: That would be treated
[3] separately. So the lead problem would be
[4] addressed possibly by an off-site removal and the
[5] lead materials that - it's in the refuge area of
[6] Site B, and the refuge area is upland of Site A.
[7] MR. CASSA: It's my understanding that
[8] the drums that were removed were tested
[9] individually, and that it was concluded that they
[10] were either intact or the leakage was relatively
[11] insignificant. Is that also correct?
[12] MR. COSTELLO: Post-excavation samples
[13] of the soils once the drums were removed,
[14] demonstrated there was no significant leakage of
[15] the drums, correct. That information is
[16] summarized in this report dated September 1997.
[17] MR. GRISWOLD: It's in the close out
[18] report that's currently being prepared. It's not
[19] part of that sampling. But there is a report to
[20] be prepared on this.
[21] MR. CASSA: The same wells that I'm
[22] referring to, are also downstream of the Rolling
[23] Knolls landfill where, from what I've read, there
[24] are materials in there for which tests don't
[25] exist. So we don't know what may be coming out of
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[1]
[2] that underground toward the water supply in our
[3] local area, as well as a hundred or more other
[4] wells along that line. So I would just say to
[5] emphasize the fact, that I think these two sites
[6] are at least linked underground if no other way.
[7] MR. COSTELLO: Robin.
[8] MR. CASENBERG: Point of clarification
[9] about groundwater. I'm sorry, Mr. Casenberg.
[10] I'm not a geologist, and, again, just I think the
[11] point of confusion from your standpoint is to
[12] realize that most of your drinking wells - most
[13] of the drinking wells are in what they call the
[14] deeper groundwater. We are not testing - there's
[15] not groundwater less than ten feet deep.They
[16] generally screen more than ten feet.
[17] MR. CASSA: Generally, more than ten.
[18] Some of them are only 20, some are 7 or 800.
[19] MR. BURR: You have a confining layer
[20] of clay within the swamp, which you have to be
[21] sure you know what level the drinking wells are
[22] versus the level of the contamination. I want you
[23] to read the documents and make sure you understand
[24] that, consider that, when you're reading the
[25] documents.
[1]
[2] MR. COSTELLO: Robin makes a good point
[3] there. There is a cross section of the Site A in
[4] the feasibility study report, and Site A is
[5] underlined by a very thick layer of clay, and
[6] organic silts, highly low permeability. It's like
[7] ten to minus seven centimeters per second. What's
[8] happening, it acts as a natural liner. That's a
[9] depth of six or seven feet. It's right below the
[10] - it's extends down to some great depth.
[11] MR. BURR: During the time of the drum
[12] excavation at Site A, we excavated down to clay
[13] every time and the majority of those pits were six
[14] to eight feet, if I'm not wrong, I believe they
[15] were, sir, just showing you that Site A is
[16] generally sitting on an area of thick clay. You
[17] should understand that and the public should
[18] understand that before you walk away tonight.
[19] MR. COSTELLO: We also did a counter
[20] feasibility study, we did extensive geotechnical
[21] testing of that layer to come up with permeability
[22] and grain size, and it classified as clay/silt.
[23] All those results are in the feasibility study.
[24] MS. FENSKE: Had these drums rusted
[25] out, say you had not removed them what was in
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Page 59
[1]
[2] them that would have gone into the water?
[3] MS. DOEBBLER: We found primarily two
[4] compounds. It was -
[5] MR. COSTELLO: Mark has the actual
[6] numbers. Of the 50 drums, mercury was found in -
[7] MR. GRISWOLD: I think the data I
[8] looked at very quickly, and it wasn't a report we
[9] generated, I have reviewed the data from an
[10] independent reviewer, one drum had mercury
[11] compounds in it, or two drums, and the other 40
[12] some drums had organic compounds like
[13] trichloroethylene, a solvent, and I think
[14] methylene chloride was another one.
[15] MS. DOEBBLER: Butadiene.
[16] MS. FENSKE: So it is logical, now that
[17] this is - these drums have been removed and
[18] you're going into this Alternative 3, that the
[19] water quality and the dangers will be contained
[20] and lessened, is that correct?
[21] MS. DOEBBLER: Yes. That's why getting
[22] the drums out was part of the - all of the
[23] alternative.
[24] MS. FENSKE: Which to my way of
[25] thinking is worth $4 million. Because it could
[1]
[2] have been a much worse problem further on down.
[3] MR. KOCH: I'm not responding to it.
[4] Bill Koch. I'm not responding to any particular
[5] question, but a concern that Mr. Scaff had about
[6] the expense. Just in the general scheme of
[7] things, $4 million is a lot of money to all of us,
[8] however, hazardous waste cleanup is a very
[9] expensive process, and that's relatively not a
[10] lot. That's not a lot of money in the scheme of
[11] cleaning up hazardous waste. So I'm just trying
[12] to put that a little bit in perspective, even
[13] though 4 million is a lot of money. 14 is a lot
[14] more, but still that's not a lot. Four million is
[15] not a lot in the scheme of dealing with this type
[16] of thing.
[17] MR. SCAFF: I go back at that point. A
[18] dollar or 4 million, we're looking at a risk of
[19] nil to none as far as everything I've heard
[20] tonight. That this thing, the only way we're
[21] going to get in trouble is by stirring it up. I
[22] don't see how spending a nickel out there is going
[23] to make an improvement. We haven't got a hazard
[24] that's going to bite us today. We haven't got a
[25] hazard that is going to bite us in five or ten
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[1]
[2] years. It seems to be a very minimal situation.
[3] It seems to be contained by its own physical
[4] nature.
[5] MR. BURR. If I may address that.
[6] Something we also considered if we did nothing,
[7] sir, then we would have to leave that site totally
[8] restricted.
[9] MR. SCAFF: Is it restricted now?
[10] MR. BURR: The public is losing - the
[11] public is paying a price for that. Currently you
[12] are paying the price.
[13] MR. SCAFF: There are a lot of places
[14] on the swamp we're paying the price for not going
[15] in there.
[16] MR. BURR: That you should have access
[17] I'm just saying, you are paying the price.
[18] Don't presume you're not paying a price for not
[19] doing that.
[20] MR. SCAFF: Well, we all pay the price
[21] for the swamp.
[22] MR. COSTELLO: The other thing we need
[23] to consider is that asbestos is - the
[24] environmental surface water is rising and falling
[25] significantly on a daily basis and may be
[1]
[2] relatively inert now, that's not to say in the
[3] future.
[4] MR. SCAFF. You're telling me that the
[5] surface water in the Great Swamp raises and falls
[6] at a great rate every day?
[7] MR. COSTELLO: All the time, yeah.
[8] MR. JANSEN: Build a dam out there.
[9] MR. SCAFF: By the structures you build
[10] out there, you contain the groundwater at a
[11] constant level.
[12] MS. MARSHALL: Yes.
[13] MS. HINKLE: Penny Hinkle.
[14] I was just looking at the map of
[15] relative positions of Site A and B, and I gather
[16] you have rerouted Great Brook around Site A so
[17] that then in moving the asbestos from Site B to
[18] Site A, you don't have to cross the brook; is that
[19] correct? I mean, how are you going to get that
[20] asbestos? Why not just consolidate it there and
[21] have a smaller area capped?
[22] MS. DOEBBLER: We considered that,
[23] capping Site B in place? Is that what you're
[24] asking?
[25] MS.HINKLE: Yes.
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[1]
[2] MS.DOEBBLER: We did consider that.
[3] MS. HINKLE: It seems a little risky to
[4] move it.
[5] MS. DOEBBLER: We've installed three
[6] corrugated steel culverts between sites A and B.
[7] There is good road now that runs between A and B
[8] and we used to haul the material over. We didn't
[9] neccessarily reroute the brook, but we have made it
[10] accessible to get over the site. And one of the
[11] reasons we chose not to consolidate B at the Site
[12] area, was because from a refuge standpoint, a
[13] visitor access standpoint. Now if we get Site B
[14] over to Site A, Site B will be clean and can be
[15] dealt with with the hiking trails through the
[16] access over them. It's contained, it will be
[17] capped over on Site A. The cost of transporting B
[18] to A is not that significant as opposed to the
[19] capping and all of the controls that go with
[20] capping.
[21] MR. JANSEN: I have a question to ask.
[22] MS. MARSHALL: Your name, please,
[23] again.
[24] MR. JANSEN: Jansen.
[25] MS. MARSHALL: Thank you.
[1]
[2] MR. JANSEN: This Fish and Wildlife
[3] Services, what are we going to do about the geese?
[4] They're crapping all over the place. We can't
[5] even walk out in our field out here. We cannot
[6] walk out in our field out here. There are feces
[7] all over the place. What are we going to do about
[8] that? And that drains into the ground, it goes
[9] down into the swamp, and into the wildlife. What
[10] are we going to do about that? You don't know?
[11] MR. KOCH: That's a whole other
[12] subject.
[13] MR. JANSEN: That's my life.
[14] MR. KOCH: There are many topics on
[15] wildlife that we can spend months talking about.
[16] MR. JANSEN: What are talking about?
[17] I'll tell you what we're talking about, is shit.
[18] MS. DOEBBLER: Thank you.
[19] MR. JANSEN: You're welcome.
[20] MS. MARSHALL: Any other comments? Are
[21] there any more comments about OU-3,4?
[22] MS. FENSKE: That's a great finale.
[23] MS. HINKLE: One further comment is
[24] that I'm sure it would be comforting to everyone
[25] to know that if this is the case, that fill that
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[1]
[2] is brought in to cap Site B- A, is clean. I'm
[3] sure there are- can you describe the precautions
[4] that will be taken?
[5] MR. COSTELLO: We're dealing with very
[6] similar sites from the Fish and Wildlife Services
[7] both up and down the East Coast, and during the
[8] design phase, we'll prepare specification
[9] documents that will have the guality control
[10] reguirements for fill as far as gradation and
[11] environmental testing. We will be testing the
[12] material on a regular basis as it comes in. The
[13] contractor will be reguired to submit that, and
[14] we'll ensure that not contaminated material is
[15] brought into the site.
[16] MS. FENSKE: You won't see yourself in
[17] the paper then.
[18] MR. MARSHALL: Any other comments? I
[19} don't want to end this before everybody has had a
[20] say this evening. Okay.
[21] Well, things may occur to you between
[22] now and January 16. We welcome you to submit
[23] further comments to us in writing. They will be
[24] incorporated in the record of decision. And I
[25] thank you very much for attending and very much
[1]
[2] for your comments/guestions. Thanks very much.
[3] (Time noted: 8:53 p.m.)
[4]
[5]
[6]
[7]
[8]
[9]
[10]
[11]
[12]
[13]
[14]
[15]
[16]
[17]
[18]
[19]
[20]
[21]
[22]
[23]
[24]
[25]
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Page 67
[1]
[2] CERTIFICATE
[3]
[4] I, VIOLA S. ZBOROWSKI, a Notary Public
[5] and C.S.R. of the State of New Jersey, License No.
[6] X01122, do hereby certify that the foregoing is a
[7] true and accurate transcript of the testimony as
[8] taken stenographically by and before me at the
[9] forth.
[10] I DO FURTHER CERTIFY that I am neither
[11] a relative nor employee nor attorney nor counsel
[12] of any of the parties to this action, and that I

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APPENDIX V

RESPONSIVENESS SUMMARY
ATTACHMENT B

IiETTERS SUBMITTED DURING THE PUBLIC COMMENT PERIOD

Krista Doebbler
U.S. Fish & Wildlife Service
755 Parfet Street, Suite 200
Denver, CO 80225-0207

Re: Asbestos Dump Superfund Site
Operable Unit No. 3 (OU-3)

Dear Ms. Doebbler:

This is in response to your letter dated December 4, 1997 transmitting copies of the following:

1. Revised Draft Proposed Plan for OU-3; and

2. Revised Draft Action Memorandum for the Removal Action at OU-3/Site
B and Limited Action Areas.

The New Jersey Departmenc of Environmental Protection has reviewed these documents And comments are
offered below.

A. Proposed Plan

1. On Page 3, in Table 2 entitled "Remedial Alternatives Evaluation for
OU-3", the description of Remedial Alternative 3 should include the
"Excavation of Other Waste" to show that the removal and off-site
disposal of lead and mercury "hot spots" is; one of the planned
activities (see "Implementation" Pages 13 and 14)

2. On Page 6, in Table 4 entitled "Human Health and Ecological
Contaminants of Concern", in addition to the New Jersey Residential
Soil Criteria, the applicable ecological cleanup criteria should be
provided for each analyte.

3. Under "Remedial Action Objectives", the second bullet item should be
revised to state that the spread of any contamination to any
surrounding media during and after remedial activities will be prevented.

4. On Page 11, under "Reduction of Toxicity, Mobility, and Volume", the
language in the third paragraph of this section should be revised to
more accurately identify the effect the preferred alternative will
have on the toxicity, mobility and volume of contamitation at the
site. Such issue can be taken with the statement that Alternative
3 will "remediate the hazardous waste". Excavation and off-site
disposal is not considered "treatment" that will reduce the
toxicity, mobility, or volume of the hazardous waste and restricting
the mobility of compound (e.g., Abestos-Containing Material or ACM)
by consolidation and capping does not reduce their toxicity or the
volume of material.
-------
5. On Page 11, under "Cost", the Proposed Plan shows an Estimated
Present Net Worth Cost of $4,182,374 for Alternative 3; however,
Page 16 of the Draft Action Memorandum shows Estimated Cost of
$600,000. The applicable difference between these two (2) figures
should be explained.

6. On Page 16, in "Attachment B", the anticipated project schedule for
OU-3 is very ambitious. At present, the schedule is approximately
two (2) months behind. It is recommended that "breathing room" for
other unanticipated delays be included. Perhaps the summer of 1999
might be a more realistic prediction for implementation of the
remedial actions.

B. Draft Action Memorandum

1. On Pages 13 and 14, under "Proposed Actions":

a. The soil cleanup criteria for the ACM must be identified.

b. The proposed actions for OU-3/Site B are acceptable.

c. The proposed actions for the Site B Refuse Areas, Sites 5 and
7, and the Old Farm Road Site must include post-excavation
sampling for lead and/or asbestos. These data are necessary
to either confirm complete cleanup or for inclusion in a
Declaration of Environmental Restrictions (DER), should there
be soil contamination which will remain at the site after
implementation of the remedy.

d. The proposed actions for any area/site which will result in
contamination being left behind above the applicable soil
cleanup criteria will reguire the placement of a DER on the
deed for that property. The levels of residual contamination,
as determined from post-excavation sampling, must be recorded
in a DER.

Should you have any guestions or reguire additional information, please do not
hesitate to contact me at (609)633-6621.

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January 26, 1998

Ms. Krista Doebbler
U.S. Fish and Wildlife Service Project Manager
12795 W. Alameda Parkway, Suite 215
Lakewood, Colorado 80228

Dear Mr. Doebbler:

Re: Great Swamp National Wildlife Refuge, Asbestos Dump Superfund Site, Operable
Unit 3, Morris County, New Jersey

The Passaic River Coalition is a watershed association, which has been involved in matters related to
the Great Swamp National Wildlife Refuge for almost 30 years. We are familiar with the site on the
Passaic River in Millington, and have followed the investigations of the sites in the Refuge for some
time.

From our observations, the managers of the Refuge have done much to clean up the dump sites of drums,
eguipment, and other metal objects. We agree that the "do nothing" alternative is not acceptable. We
have reviewed the caping alternative with Refuge Manager Bill Koch, and agree that the alternative
being proposed by the Refuge management team is the best alternative and most cost effective. The
management of the site as a meadow is an appropriate use of the site.

We believe it is important to move forward with the preferred alternative and bring this project to
closure. We support the preferred alternative.

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DAVID LUSTEADER
Box 474
NEW VERNON, NEW JERSEY 07976
January 31, 1998
Krista Doebler, Project Manager
Fish and Wildlife Service
12795 W. Alameda Parkway
Suite 215
Lakewood, Colorado 80228

Dear Ms. Doebler:

I am writing regarding the asbestos dump known as the Dietzman Tract on Long Hill Road, Harding
Township, New Jersey. The Service is open for public comment on its plan for handling of a 6-acre
asbestos dump.

I understand that the proposal is to put 2.25 feet of dirt and rock over it. I am opposed to this
measure. The asbestos and any other toxic materials should be excavated and removed to a proper dump
for such materials for the following reasons:

1. The current asbestos dump is on the edge of the
Great Swamp. The U.S. Fish and Wildlife Service should
not be a party to maintain a hazardous condition which has
the potential to imperil the area. A 2.25 foot cap of
dirt and rock can be easily breached. I am sure at one
time the Grand Canyon was not very deep.

2. There can be no guarantees that the asbestos is
permanently sealed. Water undoubtedly can percolate
through the area and cause the asbestos to spread.
Children might find a deserted area a fine playground,
unaware that digging in the area could be fatal to them.
Animals can burrow.

This asbestos dump has been mismanaged for a number of years. The Service should do the right thing
and have it finally removed. The citizens of the community should be protected. The Great Swamp should
be protected. The reputation of the Service should be protected.

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PLEASANTVILLE ROAD
NEW VERNON, N.J. 07976

January 10, 1998

William Koch
152 Pleasant Plains Road
Basking Ridge, N.J. 07920

Dear Mr. Koch;

We are writing this letter in reference to the Asbestos Dump Superfund; Dietzeman Tract.
Having lived in the immediate area for over fifty years and seeing no ill effect affect from the site we feel
that there should be no action taken.

It didn't have any negative effect on the people living in the immediate vicinity. They all lived
long healthy lives and didn't die from anything caused from the abestos site.

The site should be left in its natural state for others to enjoy not made a mess of. There are far
better things the government should the money for in the Great Swamp.

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Ms. Julia M. Sonera, Executive Director
GREAT SWAMP WATERSHED ASSOCIATION
P.O. Box 300
New Vernon, New Jersey 07976

Re: Asbestos Dump Site
Technical Advisor Grant

Dear Ms. Sonera;

Apgar Associates has completed a review of the following documents in accordance with Task II of the
GSWA Technical Advisor Grant:

Proposed Plan for the Asbestos Dump Superfund Site Operable Unit No.3 (12/97)
Draft Action Memorandum for Romovdl Action at Operable Unit No.3/Site B and Limited Action
Areas (2/98)
Removal and Restoration Action Work Plan for Operable Unit 3 (2/98)

The review of these documents considered the adequacy of the proposed remediation relative to site
conditions, identified risks, and relevant regulatory laws regulations, or guidance. Consistency of
the proposed remedy with prior documents was also assessed as well as consistency between the three
documents. My comments are as follows:

Comments on the Proposed Plan

1. Under the "What are the remaining concerns?" section of the Proposed Plan,
ecological risks are discuued and Table 4 is referenced. Table 4 does not
show ecological risk criteria. The table should be clarified as to whether
concentrations shown in Table 4 era from subsurface or surface soil samples.
The claim that only lead to a risk to human health is not supported by the
data provided in Table 4.
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Ms. Julia M. Sonera, Executive Director
GREAT SWAMP WATERSHED ASSOCIATION
February 27, 1998
Page 2

2. The same section includes a discussion of the buried drums and refers to
their existence as "formerly" and "now removed". I do not feel these
remarks should be made with the certainty and completeness inferred. As
discussed in the drum removal report, geophysical surveys identified "several
hundred anomalies characteristic of drum-sized targets or larger". However,
the USACOE limited identification and subseguent investigation of the
anomalies to the 100 largest. The reason for this was not stated. As the
nature and characteristics of the remaining anomalies which were not
investigated are unknown, any discussion of the drum removal activities
would be incomplete without mentioning that some drums may still be buried
at the site. Accordingly, any evaluation of remedition alternatives must
consider the possibility that drums may have been missed during the removal
activities and could represent a potential for future groundwater
contamination. I have noted that the drum removal report refers to 10
anomalies which trend off-site but were not investigated. The Proposed Plan
makes no mention of this situation nor how it will be addressed.

3. Of particular concern is the fact that the groundwater monitoring component
of the selected alternative has been eliminated since publication of the Final
Feasibility Study Report. The reason for this is not fully explained in the
Proposed Plan. I can only find two statements in the Proposed Plan that
mention groundwater monitoring. The first is a statement in the drum
removal discussion "that additional sampling has confirmed that groundwater
is not a future concern". The second is a statement in the Pre-Design Date
Report summary section that "Sampling indicates that groundwater from
dewatering or pumped water can be expected to be sufficiently free of
contaminants to minimize future treatment and monitoring needs at Site A".
I suspect that the additional sampling being referred to is that conducted
during the dawatering test. Certainly the sampling conducted during this test
was not sufficient to justify such broad statements or make final decisions
regarding long term monitoring. Such statements conflict with basic
conclusion contained in the Final Feasibility Study. These statements also
conflict with another statement on page 11 of the Proposed Plan which says
"Monitoring to date is inconclusive".

The Final Feasibility Study Report specifically recommended future
groundwater monitoring because of concern over future groundwater
contamination and the fact that groundwater currently exceeds ARARs. As
discussed above in Comment 2, concern over future contamination is still
valid from a perspective of drummed waste. Further, the data collected
during a 3-day pump test at one point on the site would certainly not be
sufficient to contradict the volume of data collected during the RI phase of
this project. The USFWS should carefully explain and justify this change in
long term site monitoring as it is significant.
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Ms. Julia M. Sonera, Executive Director
GREAT SWAMP WATERSHED ASSOCIATION
February 27, 1895
Page 3

4. Under Alternative 2A, the Proposed Plan states that "Based on all of the
Information collected to date, it is anticipated that future risk associated with
hazardous wastes at Site A will be reduced to acceptable levels by the drum-
removal operations at Site A. "Ignoring the conclusions regarding drum
removal certainty, this statement should be reconsidered in light of the
massive amounts of exposed asbestos at Site A, unknown Quantities of
asbestos is soils, groundwater which exceeds ARARs at Site A, and the
detections of mercury in surface soil samples collected from Site A during
the Pre-Design Date Report activities.

5. The discussion of Alternative 3 includes the need to remove mercury-
contaminated "hot spots". There no discussion in the Final Feasibility
Study Report about excavation of mercury "hot spot". It is also unstated
what is considered "hot". While the Pre-Design Study did include grid
sampling for mercury in surface soils at Site A, this grid was very large (100'
Intervals) and inappropriate for identifying "spots". Further, the sampling
revealed that the remedial action objective for mercury in surface a soils (1
ppm) was exceeded over the vast majority of Site A.

A review of the Removal Action Memorandum and the Removal Action Work
Plan reveals no mention of any mercury "hot spot" removal or coordination of
such a removal activity with the current removal activity. Such coordination
would include, at a minimum, preventing the placement of waste from the
Refuse Areas and Site 9 over the "hot spots". Further, the proposed
regrading of Site A identified in the Work Plan would seriously compromise
the value of all surface soil mercury data collected to date. As Alternative 3
is the proposed remedy, it is important that the mercury "hot spot" issue be
discussed, evaluated with respect to remedial action objectives, adeguately
justified through comparative analysis with other alternatives, and integrated
into the overall remediation program.

6. The discussion of Alternative 3 should also include removal of ACM-
contaminated sediment from the waters adjacent to the site in order to
prevent downstream mobilization of this material. Discussion of capping for
Alternative 3 should include the need to provide engineering controls for
prevention of cap erosion at the waters edge. The Proposed Plan should
clearly indicate the intended topographic configuration of the final cap. The
advantages and disadvantages of the different capping systems should be
discussed; specifically, it should be clearly noted that a permeable cap will
only reduce and not eliminate discharges from the waste material into the
surrounding surface water bodies.

The Proposed Plan should clearly state whether future public access to Site
A will be allowed. The removal of the culvert following remedial activities
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Ms. Julia M. Sonera, Executive Director
GREAT SWAMP WATERSHED ASSOCIATION
February 27, 1998
Page 4

should be reconsidered as this is the only method of accessing the various
Refuse Areas, the UAR, and Site "B" locations for maintenance purposes.

7. The final disposition of the UAR ACM should also be included in the detailed
description of Alternative 3. Although not discussed in the Removal Action
Memorandum, the Work Plan indicates this ACM is to remain. If so, capping
with 8 inches of soil (as described in the Work Plan) is inadeguate in
consideration of the proposed use of Site A and maintenance reguirements.

8. Specific comments regarding asbestos clean-up at the various Refuse Areas
and Site B are provided in comments on the removal action.
Comments on the Removal Action Memorandum

1. Section I indicates the purpose of the memorandum is to document "approval
of the proposed removal action". As the NJDEP never responds to document
submittals and the USEPA, as of 2/23/98, had only received but not
reviewed the memorandum, it is not clear whom has approved the action
other than the site owner. The USEPA representative went so for as to claim
USEPA approval was not reguired for removal actions. Further, it is unlikely
the NJDEP would ever explicitly approve an ACM removal action using a
95% visual clean-up goal.

2. Section I indicates that lead contaminated waste above 218 ppm will be
disposed of off-site at an approved facility. This directly contradicts the
Work Plan which states that waste with lead concentrations above 218 ppm
but below 400 ppm will be disposed of an Site A.

3. As field work is being initiated in February, discussion of accomplishing the
removal work "before the onset of winter weather" should be removed from
Section 1.

4. Section II A 4 indicates that the origin of the LAA ACM is suspected to be
OU1 of the Asbestos Superfund Site, in light of this statement, the
USF&WS should explain what efforts have been undertaken to have the
LAAs included in the Site and/or the status of such efforts. Considering the
expense related to disposing the material offsite, a detailed discussion of this
issue is appropriate, relevant and of interest to the general public.

5. Section II C, should clearly indicate that the USF&WS received no comments
from either the NJDEP or USEPA regarding the proposed removal action.

6. Section V makes no mention of the UAR ACM while the Work Plan states it
will be covered. The draft Scope of Work from the Adminstrative Record File
-------
Ms. Julia M. Sonera, Executive Director
GREAT SWAMP WATERSHED ASSOCIATION
February 27, 1998
Page 5

states the VARACM lato be removed. These differences should be
eliminated. Considering the guantity of the ACM, the proximity to Site A,
and the future use of the UAR, it would be ideal if all ACM were, removed
from the UAR.

7. The general ACM removal strategy discussed in Section V is removal of ACM
to a limit of 96% based on visual observation. Unfortunately, determination
of gross asbestos concentration in soils by visual methods is impossible.
Further, federal and state laws define Asbestos Containing Material as
material that; contains 1% or more of asbestos, not 5%. Remediating 5%
would mean that ACM, as defined under federal and state law, would remain
on site. Accordingly, long term monitoring would be reguired at the site. It
does not appear that this possibility was previously considered.

Additionally, only "contour grading and seeding" of the remaining material (as
identified in the memorandum would be a violation of the containment
standards contained in 40 CFR 81.151 if the remaining material contained
saboatas is excess of 1%. It should be noted that the NJDEP is currently
reguiring soil clean-up criteria of 0.25% asbestos (determined analytically) at
similar sites in northern New Jersey. Consideration should be given to
collecting abestos confirmation samples from ACM removal sites to
demonstrate clean-up to the 1% level.

8. Section V states that soil not remediated to the 5% visual concentration
would be covered with 8 inches of soil. Although it is not clear whether this
would comply with the standards established in 40 CFR 61.151, the
USF&WS would be reguired to plant and maintain vegetation over such a
cover. This maintenance would have to be freguent enough to prevent the
growth of vegetation that could penetrate the 8 inch layer and compromise
the cover. A cover of this nature would be extremely prone to being
compromised by burrowing animals. These issues should bo considered and
balanced against the benefit of using a 2 foot thick cover (as specified in 40
CFR 81.151) reguiring only minimal maintenance.

9. The Community Relations Plan discussed in Section VI should be added to
the Administrative Record File.
Comments on the Work Plan

1. The eighth bullet on page 1-5 should include clearing and grubbing as an
activity reguiring air monitoring noise control.
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Ms. Julia M. Sonera, Executive Director
GREAT SWAMP WATERSHED ASSOCIATION
February 27, 1998
Page 6

2. The plan does not discuss measures to be taken during on-site transport of
material (i.e. using tarps over material being transported in trucks). This
should be discussed.

3. Covering of the UAR ACM with only 6 inches of soil would nessitate
freguent maintenance to prevent vegetation from compromising the cover.
This maintenance issue should be considered and balanced against the
benefit of using a 2 foot thick cover (as specified in 40 CFR 61.151)
reguiring only minimal maintenance. Further, as future access to Site A will
be over the UAR, a cover only 6 inch thick would be an inappropriate choice
for such a use.

4. Section 3.1.3 indicates Now Jersey clean fill reguirements are presented in
the CSAP. While the CSAP does list reguirement for lead, reguirements for
other site contaminants are not listed.

5. As stated previously, the final disposition of lead contaminated material with
concentrations between 218 ppm, and 400 ppm differs between the Work
Plan and the Removal Action Memorandum.

6. The Work Plan includes no provision for asbestos confirmation samples. As
an appropriate asbestos clean-up standard for areas to be only regraded
following excavation) is 1%, asbestos confirmation samples should be
reguired. Protocols should be established in advance regarding measures to
be taken should confirmation samples exceed 1%.

7. The Work Plan indicates material consolidated at Site A from Site B and the
Refuse Areas may be used for cover material. As some of this material
would have asbestos associated with it, none should be used as cover
material unless analytical samples have confirmed concentration of asbestos
below 1%.

8. No discussion is provided in the Work Plan as to how TCLP date will be used
for determining final on-site and off-site disposal options.

9. A discussion should be provided an to why the RAB material will be disposed
of off-site regardless of concentration.

10. The draft Scope of Work from the Administrative Record File for the project
reguires the use of a real-time fibrous aerosol monitor for both eras and
perimeter monitoring. Eguipment of this nature would assess the releases of
asbestos fibers during remediation activities and would serve to immediately
alert workers as to when activities were resulting in exceedences of airborne
asbestos levels. The Work Plan, however, reguires only filter cartridge
sampling which would be analyzed overnight following the end of the work
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Ms. Julia M. Sonera, Executive Director
GREAT SWAMP WATERSHED ASSOCIATION
February 27, 1998
Page 7

day. Any corrective actions taken in the event of excessive analytical results
would be only after the fact. Consideration should be given to using a mix of
real time monitors and filter cartridge samplers to provide for an appropriate
mix of real time data and accurate phase contrast or TEM laboratory analyses.

11. Provisions should be made for accurately establishing "downwind" and
"upwind" sampling locations. These provisions should include a simple
weather monitoring/wind vana station.

12. Regrading of Site A should be reconsidered in light of the proposed mercury
"hot spot" removal. Regrading of the site would negate the value of any
previously collected mercury surface soil data and would only serve to
further homogenize the waste.

These comments should be considered as starting points for further discussion and
exploration of the various issues identified. Please contact me if you have any
questions or comments regarding this information. I am available to discuss these
matters directly with USF&WS personnel at your direction.

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APPENDIX VI
LIST OF ACRONYMS
ACM
AOC
ARAR
CERCLA
COG
COE
DO I
DOT
EPA
ER-M
FFA
f/mm 2
FS
GSNWR
HRS
LAA
MCL
MFL
ing/Kg
MSL
NA
NCP
ND
NESHAPS
NGC
NJ
NJDEP
NPL
NOAA
OFR
OSHA
OU-3
O&M
POTW
PRP
QA/QC
RA#1
RA#3
RA#6
RAO
RCRA
RI
ROD
SEA
SSL
TBC
TCE
TCLP
UAR
UCL
ug/L
ug/Kg
USFWS
Asbestos Containing Material
Area of Concern
Applicable or Relevant and Appropriate Requirements
Comprehensive Environmental Response, Compensation, and Liability Act of 1980
Contaminant of Concern
United states Corps of Engineers, Kansas City District
Department of Interior
Department of Transportation
Environmental Protection Agency
Effects Range - Median (NOAA, 1994)
Federal Facilities Agreement
fibers per sguare millimeter
Feasibility Study
Great Swamp National Wildlife Refuge
Hazard Ranking System
Limited Action Area
Maximum Contaminant Level
Million Fibers Per Liter
milligrams per kilogram
Mean Sea Level
Not Applicable
National Oil and Hazardous Substances Pollution Contingency Plan
Not Detected
National Emission Standards for Hazardous Air Pollutants
National Gypsum Company
New Jersey
New Jersey Department of Environmental Protection
National Priorities List
National Oceanic and Atmospheric Administration
Old Farm Road Satellite Area
Occupational Safety and Health Administration
Operable Unit 3 of the Asbestos Dump Superfund Site
Operation & Maintenance
Publicly-owned Treatment Works
Potentially Responsible Party
Quality Assurance/Quality Control
Refuse Area Number One
Refuse Area Number Three
Refuse Area Number Six
Remedial Action Objective
Resource Conservation and Recovery Act
Remedial Investigation
Record of Decision
SEA Consultants Inc.
Soil Screening Level
To Be Considered (Criteria)
Trichloroethylene
Toxicity Characteristic Leaching Procedure
Unimproved Access Road
Upper Confidence Limit
micrograms per liter
micrograms per kilogram
United States Fish & Wildlife Service
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