Superfund Record of Decision Burnt Fly Bog Marlboro Township NJ


                                    EPA/ROD/R02-98/143
                                    1998
EPA Superfund
     Record of Decision:
     BURNT FLY BOG
     EPA ID:  NJD980504997
     OU03
     MARLBORO TOWNSHIP, NJ
     09/30/1998

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EPA 541-R98-143

                                       RECORD OF DECISION


                                       Burnt Fly Bog Site

                       Marlboro Township, Monmouth County, New Jersey


                                         September 1998

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DECLARATION FOR THE RECORD OF DECISION

SITE NAME AND LOCATION

Burnt Fly Bog Site
Marlboro Township, Monmouth County, New Jersey

STATEMENT OF BASIS AND PURPOSE

This decision document presents the selected remedial action for the Westerly Wetlands, Northerly Wetlands, and
Tar Patch Area at the Burnt Fly Bog Superfund Site, which was chosen in accordance with the reguirements of the
Comprehensive Environmental Response, Compensation and Liability Act of 1980, as amended (CERCLA) , and to the
extent practicable, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). This decision
document explains the factual and legal basis for selecting the remedy for the third operable unit of the Site.

The New Jersey Department of Environmental Protection concurs with the selected remedy (Appendix V) . The
information supporting this remedial action is contained in the Administrative Record for the Site, the index
of which can be found in Appendix IV to this document.

ASSESSMENT OF THE SITE

Actual or threatened releases of hazardous substances from the Burnt Fly Bog Site, if not addressed by
implementing the response action selected in this Record of Decision, may present an imminent and substantial
threat to public health, welfare, or the environment.

DESCRIPTION OF THE SELECTED REMEDY

The selected remedy represents the third and final operable unit planned for the Burnt Fly Bog Superfund Site.
It addresses contaminated soil present on the three remaining contaminated areas on the site, including the
Westerly Wetlands, Northerly Wetlands, and Tar Patch Area.

The major components of the selected remedy include:

1. Excavation and off-site disposal of contaminated soil from the Northerly Wetlands;
2. Excavation and off-site disposal of contaminated soil from the Tar Patch Area;
3. Backfilling the excavated area in the Northerly Wetlands and re-establishing wetlands;
4. Backfilling the excavated area in the Tar Patch Area and creating wetlands;
5. Provision of additional security fencing around the Westerly Wetlands, and the recording of a Deed
Notice for the Westerly Wetlands, Northerly Wetlands, and Tar Patch Area;
6. Monitoring of surface water and sediment in the Westerly Wetlands, surface water and sediment in the
existing sedimentation basin located in the Downstream Area, and surface water, sediment and, if
necessary, biota in Burnt Fly Brook; and
7. Biological sampling in the Westerly Wetlands.

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DECLARATION OF STATUTORY DETERMINATIONS

The  selected  remedy is  protective of human  health and  the environment,  complies with Federal  and State
requirements  that  are  legally  applicable or  relevant  and  appropriate  to  the  remedial   action,   and is
cost-effective. The remedy utilizes  permanent  solutions and  alternative treatment  (or resource  recovery)
technologies to the maximum extent practicable for this Site.  However,  because treatment of the principal threats
of the Site was not  found to be practicable, this remedy does not satisfy the statutory preference for treatment
as a principal element of the remedy.

Because this remedy will result in hazardous substances  remaining on the Site above health-based levels,  a review
will be conducted  within  five years after commencement of the remedial action to ensure that the remedy continues
to provide adequate protection of human health and the environment.  This review will include an  evaluation of
the  data  and  information obtained in connection with remedial  components 6  and  7 above,  as  well as other
appropriate components of the selected remedy.

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                                         RECORD OF DECISION

                                          DECISION SUMMARY

                                    Burnt Fly Bog Superfund Site
                                 Marlboro Township, Monmouth County
                                              New Jersey

                                          Table of Contents

                                                                                       Page

Site Name, Location, and Description                                                     3

Site History and Enforcement Activities                                                  4

Highlights of Community Participation                                                    6

Scope and Role of Response Action                                                        7

Summary of Site Characteristics                                                          8

Summary of Site Risks                                                                   14

Remedial Action Objectives                                                              18

Description of Remedial Alternatives                                                    18

Summary of Comparative Analysis of Alternatives                                         25

Selected Remedy                                                                         34

Statutory Determinations                                                                38

Documentation of Significant Changes                                                    40


Appendices


Appendix I                     Figures

Appendix II                    Tables

Appendix III                   Total Risk Summary

Appendix IV                    Administrative Record Index

Appendix V                     NJDEP's Letter of Concurrence

Appendix VI                    Responsiveness Summary

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SITE NAME, LOCATION AND DESCRIPTION

The Burnt Fly Bog (BFB) Superfund Site is located near the intersection of Texas and Spring Valley Roads in
Marlboro Township, Monmouth County, New Jersey. It is situated approximately thirty miles northeast of Trenton,
and about five miles from the Atlantic Ocean (Figures 1 and 2) . While the entire Burnt Fly Bog encompasses about
1700 acres, the Site is limited to the approximately sixty acres of the study area affected by contamination.
The Site is identified on the Marlboro Township Tax Map as Block 146, lot 47, and parts of
lot 2, lot 3, lot 4, lot 5, lot 7, lot 8, and lot 49, and on the Old Bridge Township Tax Map as Block 13003, lot
23.11, and parts of lot 24.11 and lot 31. The majority of the waste was originally deposited in lot 47, a ten
acre parcel located in the southeastern area (Uplands Area) of the Site. Much of the waste then migrated to other
parts of the Site.

The BFB Site consists of the following sub-sites: Uplands Area, Tar Patch Area, Northerly Wetlands, Westerly
Wetlands, and Downstream Area Figure 3). The Uplands Area had several abandoned oil storage and treatment lagoons
containing residual oil sludges and agueous wastes, contaminated waste piles, and buried or exposed drummed
wastes. The Westerly Wetlands, Northerly Wetlands, and the Downstream Area had contamination in the surface
water, surface soil, and the shallow subsurface soil. It is believed that this contamination was the
result of uncontrolled discharges and runoff from the Uplands Area waste sources. The Tar Patch Area comprises
two areas that were previously referred to as the Tar Patch and the Contaminated Soils Area, and which are
located adjacent to each other. The core of the combined Tar Patch Area, which is approximately 4 acres in
extent, is devoid of any vegetation. The material is more sandy, and this area is contaminated to a maximum depth
of approximately 6 feet. The total area of Tar Patch Area contamination is nearly 5.5 acres. The Westerly
Wetlands is the largest of the sub-sites covering an area of approximately 21 acres. The area of the contaminated
Northerly Wetlands is approximately 2.5 acres while the Downstream Area contamination, prior to remediation,
covered an area of 3 acres.

Two auto salvage yards and a few residences are found near the Site. The predominant land use within the township
includes residential development, agricultural land, open spaces and wooded lands.

The Site is located in a fringe area of the New Jersey Pine Barrens. The New Jersey Pine Barrens is an
environmentally sensitive area in the State. The interior of Burnt Fly Bog is considered an undisturbed
wilderness area with documented reports of wildlife including red and gray fox, several species of sguirrel,
rabbits, white-tailed deer, opossum, raccoon, skunk, and seasonal birds. Other wildlife that makes this area its
habitat includes various reptiles and amphibians. The Westerly Wetlands and Northerly Wetlands are rated moderate
to high in value as wetland systems. No federally listed threatened or endangered plant species are present on
the Site. The Westerly Wetlands provides habitat to a greater diversity of wildlife than the other habitats on
the Site, and certain species occurring on the Site are likely to be found only in the Westerly Wetlands. The
Westerly Wetlands had significant loss of plant cover as the result of a past oil fire and/or potentially toxic
effects on plants from excessive levels of contaminants. Most of the affected area has experienced good progress
toward re-establishing indigenous plant life.

The entire Site is located in the outcrop area of the Englishtown Formation. In the Westerly Wetlands, a
relatively impermeable clay layer is at or near the ground surface. Ground water flowing through the overlying
upper sand layer discharges to the surface of the Westerly Wetlands which is inundated most of the year. The
Westerly Wetlands receives drainage from the Uplands Area, Northerly Wetlands, Tar Patch Area, and parts of the
surrounding 1,700 acres of bog and pine barrens. Surface water flows in a south-westerly direction through the
Westerly Wetlands, into the Downstream Area, through the sedimentation basin, and eventually into Burnt Fly
Brook. The combined flow in Burnt Fly Brook flows into Deep Run at a distance of approximately one mile from the
Site. Deep Run is a groundwater recharge source for the potable wells in the City of Perth Amboy.

SITE HISTORY AND ENFORCEMENT ACTIVITIES

In or about 1952, activities that were responsible for the initial contamination at the Site began. During this
period, different portions of the Site were used for reprocessed oil storage or settling lagoons, oil
reprocessing filter cake storage, sanitary landfill activities, and sand and gravel pit operations.

Before 1950, the BFB Site was still an undeveloped area. In about 1950, Champion Chemical Company established

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an oil reprocessing facility located on Orchard Place in Morganville, New Jersey, approximately two miles east
of the Site. About the same time, Eagle Asphalt Company purchased that portion of the present BFB Superfund
Site comprising the area around the four lagoons in the Uplands Area. These lagoons were developed for use as
oil storage facilities and as settling ponds to handle the reprocessed oil. These facilities were operated until
the property was sold in November 1964 to a Mr. Eckel.

In 1960, sanitary landfill operations began at another portion of the future Burnt Fly Bog Site, reportedly
receiving local trash. The owner/operator, Mr. Towler died in 1961, and the landfill discontinued operations.
Subseguently, Mr. Dominick Manzo purchased the property in December 1963, reopening the landfill and operating
it with the approval of the municipality until 1967. In July 1965, Mr. Manzo acguired the former Eagle Asphalt
Company property from Mr. Eckel. This purchase, coupled with the purchase of an adjoining plot in July 1968,
brought under one ownership adjoining plots of land that together would eventually become known as the Burnt Fly
Bog Superfund Site.

In 1969, the Middlesex County Court ordered the closure of the landfill. Aside from the deposition of excavated
fill from a sewer construction project in Hazlet, New Jersey in July 1979, there have been no operations at the
Site since 1969. On October 26, 1973, a fire started and burned at the Site for 16 hours before it was finally
extinguished.

The New Jersey Department of Environmental Protection (NJDEP) is the lead agency for this Site. An Environmental
Information Document pertaining to the Site was prepared by Dames and Moore for NJDEP in 1982. Contamination of
soil, ground water and surface water was found to exist from the improper disposal of hazardous substances at
the Site. The Site was then included on the National Priorities List in 1983. Based on the findings in the
report, a Record of Decision (ROD) was issued in November 1983. The ROD called for off-site removal of
contaminated soil and waste from the Uplands Area, and for a supplemental Remedial Investigation and Feasibility
Study (RI/FS) to further investigate the wetland areas. The Uplands Area remediation was performed under Operable
Unit One (OU-1).

Ebasco Services Inc. was engaged by NJDEP to provide design engineering services for the removal from the Uplands
Area of contaminated soil and waste, which included drummed wastes, agueous wastes and sludges from lagoons, and
wastes from an Asphalt Pile. Between 1985 and 1990, NJDEP conducted several remedial actions in
this area in accordance with the reguirements of the ROD. These remedial actions included the removal of the
Asphalt Pile, removal of lagoon liguids, excavation and off-site disposal of approximately 85,000 tons of
contaminated soil, and installation of a clay cap over the area. In addition, about 600 cubic yards of
PCB-contaminated soil was removed in 1992 for incineration off-site.

Ebasco also performed an RI/FS for the Westerly Wetlands and the Downstream Area between 1984 and 1987. As part
of the investigations, sampling and analysis of soil, surface water, and ground water were performed. The results
of the RI/FS are summarized in the January 1988 Westerly Wetland Remedial Investigation Final Report and the
January 1988 Westerly Wetland Ultimate Remedy Feasibility Study Final Report which are included in the
Administrative Record for this Site, and are summarized in this document. Following the RI/FS, lead
mobility studies and a water budget analysis were also performed by Ebasco. Based on the findings of these
investigations and studies, another ROD was issued in September 1988. This ROD called for the excavation and
off-site disposal of contaminated soil from the Downstream Area, containment of the contaminated soil in the
Westerly Wetlands through the installation of a sedimentation basin and appropriate diversion controls,
construction of a security fence, and treatability studies on the most promising treatment technologies for
the contaminated materials in the Westerly Wetlands, Northerly Wetlands and Tar Patch Area. Investigation of the
Westerly Wetlands and remediation of the Downstream Area, including construction of the sedimentation basin,
constituted Operable Unit Two (OU-2).

In August 1992, Frederic R. Harris, Inc. was contracted by NJDEP to perform the remedial design for the removal
of the contaminated soil in the Downstream Area and for the construction of the sedimentation basin. As part of
the design investigations, Harris also delineated the Tar Patch Area. The results of these investigations are
summarized in the May 1994 Final Field Sampling and Testing Results Report - Tar Patch Area. Removal of the
contaminated soil in the Downstream Area and sedimentation basin construction commenced in September 1995 and
the work was completed by the end of 1996. A security fence along Spring Valley Road was also constructed.

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Remedial  activities  pertaining to  the remaining  contaminated  areas,  namely, Westerly  Wetlands,  Northerly
Wetlands, and Tar Patch Area are being done  under  Operable Unit Three (OU-3) .  In  June 1993,  BCM Engineers  was
contracted by NJDEP to perform a supplemental feasibility  study  of these three areas.  Treatability  studies on
soil washing and chemical  dechlorination  were  performed as part of this  feasibility study.  The results  of  the
study are summarized in the October 1997 Final Supplemental  Feasibility Study Report for Burnt Fly Bog Site which
is included in the Administrative Record for this Site.

The United  States  Environmental Protection  Agency  (EPA)  performed an ecological assessment of the  Westerly
Wetlands based on the  results of a field study conducted in 1991.  The  results of this assessment are summarized
in the June 1992 Ecological Assessment Final Report.

Soil  sampling  in the Northerly Wetlands  was  performed by NJDEP in  1995 in  order to fully  delineate  the
contamination in this portion of the Site. The results of this sampling are shown in the January 1997 Northerly
Wetlands  Field Sampling Report. Surface soil sampling was  also  performed in the Westerly Wetlands  in 1996 to
confirm the established  levels  of contamination in this area. The results  of this sampling are summarized in  the
September 1997 Westerly Wetlands Field Sampling Report. In addition, surface water  and sediment in Burnt  Fly
Brook have been sampled since 1992,  at guarterly intervals.

EPA initiated a cost recovery action under the Comprehensive Environmental Response, Compensation, and Liability
Act, as amended  (CERCLA),  in January 1997 against several parties to recover monies  expended at the Site. This
action is ongoing.

HIGHLIGHTS OF COMMUNITY PARTICIPATION

In 1981,  concerned residents organized the Burnt Fly  Bog Citizens' Advisory Committee (BFBCAC).  BFBCAC,  which
originally was  composed of  residents from Marlboro and  Old Bridge Townships,  now includes citizen representatives
from Marlboro and Old Bridge Townships, Marlboro Township officials,  as well as officials  from Monmouth  County
and Middlesex County. The Committee functions as the liaison between NJDEP and the local community.

Since the establishment  of NJDEP's  Community Relations Program in 1982,  representatives of NJDEP have met with
BFBCAC on a  regular  basis.  All pertinent Site data,  reports, and events have been  shared and  discussed with
BFBCAC to enable its  input to  be incorporated into the decision-making  process involving  Site  activities.  In
1998, a group known  as the Monmouth County Environmental Coalition (MCEC)  received  a Technical Assistance Grant
from EPA  to hire technical advisors to review technical reports pertaining to this Site on behalf
of the residents.

Community concerns have focused primarily on the potential environmental  and  human health risks posed  by  the
Site. The ingestion of contaminated ground or surface water has been of major concern to the community because
of the high lead concentrations at the Site.

Moreover, residents and officials of neighboring communities have expressed concern about contaminant migration
to Deep Run which receives drainage from the Site.

Several public meetings have been held to present the  findings  of various  studies  conducted for the  Site.  In
August 1983,  a public meeting was held  to  discuss the  remedial alternatives  that were  evaluated for the Uplands
Area and  to  receive  public comments before the  issuance of the  1983  ROD.  Similarly,  a public meeting was also
held on March 29, 1988 before the 1988 ROD was issued.

Additional RI reports,  the Supplemental FS  report,  and the Proposed Plan dated  February 1998 for  the  third
operable unit (OU-3) were released to the public for comment on February 4, 1998. The public comment period  was
originally  scheduled  for  a  duration  of  30  days.   Based  on reguests  for a  time extension by  the  MCEC  and
potentially responsible parties  (PRPS),  the  public  comment period was  extended by 60 days  and  ended on  May 4,
1998. These documents  were  made available to the public in the Administrative Record file at the NJDEP file room
at 401, East State Street,  Trenton,  New Jersey,  and the information repositories at:

Monmouth  County Library                    Marlboro Township Municipal
Building                                   1979 Township Drive

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1 Library Court Marlboro, New Jersey 07746
Marlboro, New Jersey 07746

On February 19, 1998, NJDEP conducted a public meeting at the Marlboro Township Municipal Building to inform
local officials and interested citizens about the Superfund process, to discuss the findings of the remedial
investigations, the supplemental feasibility study, and the proposed remedial activities at the Site, and to
respond to any guestions from the area residents and others who attended.

NJDEP's responses to the comments received at the public meeting, and in writing during the 90-day public comment
period, are included in the Responsiveness Summary (see Appendix VI).

SCOPE AND ROLE OF RESPONSE ACTION

As a result of the BFB Site complexities and as is discussed above, the work has been divided into three operable
units. A ROD was issued in 1983 for OU-1 for the remediation of the Uplands Area, and for conducting
investigations in the wetland areas. A second ROD was issued in 1988 for OU-2 which provided for an interim
remedy for the Westerly Wetlands portion of the Site. It called for the removal of contaminated materials from
the Downstream Area, construction of a sedimentation basin, and the performance of treatability studies on
the most promising treatment technologies for the remediation of Site soil. These treatability studies were
performed as part of a supplemental feasibility study. Remedial Actions have already been completed for OU-1 and
OU-2.

Uplands Area (OU-1)

Several remedial actions were conducted in the Uplands Area between 1985 and 1990. The activities included the
removal of a pile of oily material mixed with soil called the Asphalt Pile, removal of lagoon liguids and sludge
material, excavation and off-site disposal of approximately 85,000 tons of soil contaminated with PCBs and lead,
and installation of a clay cap over the area and re-vegetation of the surface. Approximately 600 cubic yards of
PCB-contaminated soil was also removed for incineration off-site. The clay cap is being inspected and maintained
at regular intervals in order to preserve its structural integrity.

Downstream Area Remedial Action and Sedimentation Basin Construction (OU-2)

Approximately 6300 cubic yards of soil contaminated with PCBs and lead were removed off-site for disposal from
the Downstream Area in 1996. A sedimentation basin was constructed in the Downstream Area after removing the
contaminated soil. The capacity of the basin is such that it can fully contain storm flow resulting from a
hundred year storm event within the catchment area. Accumulation of sediment in the basin is being monitored at
regular intervals. The collected sediment will be sampled and analyzed before disposal. A security fence along
Spring Valley Road was also constructed to prevent trespassers from entering the Site.

The third operable unit authorized by this ROD is based on remedial investigations performed to date and a
determination that further remedial action is reguired for unremediated areas of the Site. Therefore, as further
explained in this ROD, EPA and NJDEP have identified Excavation and Off-site Removal of Contaminated Soil, and
Wetland Restoration for the Tar Patch Area and Northerly Wetlands, and Limited Action for the Westerly Wetlands
portion of the BFB Site.

OU-3 is the final response action for this Site.

SUMMARY OF SITE CHARACTERISTICS

Remedial Investigation

The RI for the Westerly Wetlands was performed in three stages between 1984 and 1987 and consisted of sampling
and analyses of soil/sediment, surface water and groundwater. Chemical analysis of all samples was performed for
PCBs, lead, and other chemical compounds. Chemical analysis of the wetlands soil indicated a large extent and
high degree of PCB and lead contamination. The maximum concentration of PCB contamination detected in soil was
254 milligrams/kilogram (mg/kg). PCBs were not present in surface water. Lead contamination was found

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in the soil within the delineated boundaries of PCB contamination and outside. The maximum concentration of lead
contamination detected in soil was 31,000 mg/kg. Lead was also found in surface water samples. The maximum
concentration of total lead detected in surface water was 1,900 micrograms/liter (Ig/L); the maximum
concentration of dissolved lead was 1,600 Ig/L.

NJDEP soil cleanup criteria established as the action levels for the Site at that time were 5 mg/kg for PCBs and
250 mg/kg for lead. Utilizing a remediation level of 5 mg/kg for PCBs, the results of the Stage I investigation
identified an approximate volume of 58,000 cubic yards of PCB-contaminated soil in the Westerly Wetlands. The
results of the Stage II investigation refined this estimate to 62,600 cubic yards of PCB-contaminated soil. The
results of the Supplemental Stage II investigation increased the volume of contaminated soil within the Westerly
Wetlands to 76,400 cubic yards after including lead-contaminated soils, using a threshold level of 250 mg/kg for
lead. In addition, the Supplemental Stage II investigation evaluated soils in an area immediately down-gradient
of the Westerly Wetlands, which was designated as the Downstream Area. The Downstream Area was remediated in 1996
with the removal off-site of approximately 6300 cubic yards of contaminated soil.

Water Budget

A water budget for the Site was prepared utilizing data gathered during the Supplemental Stage II investigation.
The study was intended to obtain surface water, ground water, and site-specific meteorologic data and to discuss
and develop a water budget for the Westerly Wetlands. Data were collected through the installation of hydrologic
monitoring equipment including stream gauges and a small number of geohydrologic cluster well point systems as
well as meteorologic monitoring equipment.

Data compiled by the investigation included the following: a rainfall database, hydrographs, ground water flow
rates, hydraulic conductivity of the ground water, and permeability of the Woodbury Clay layer. The significant
components of the water budget of the Westerly Wetlands identified by the investigation include: precipitation,
direct runoff, delayed runoff, ground water discharge, and evapotranspiration.

The results of the study indicated that the primary hydrologic pathway of contaminant transport is through
surface water runoff. Surface water runoff (direct runoff plus delayed runoff) accounts for between 44.2 and 48.5
percent of the precipitation that falls on the drainage basin.

Laboratory Lead Mobility Study

The purpose of the lead mobility study was to determine the mobility of lead in the soil and the potential for
off-site migration of lead through either surface water or ground water. The study was also intended to focus
the direction of Site remediation efforts toward the contaminant transport pathways of greatest environmental
concern.

The results of the investigations indicated the following:

• Lead concentrations in fine particle soil fractions (<74 microns) were 3 to 10 times higher
than in overall bulk soil samples.
• A large fraction of the lead bound to contaminated soils was potentially available for leaching
to surface waters.
• The source of lead in surface waters may be lead mobilized from surface soils.
• Specification studies suggested that up to 20 percent or more of the total lead concentration
may be available for release to surface waters under appropriate mixing conditions.
• The reservoir of lead remaining in Site soils may be sufficient to maintain surface water lead
concentrations in the range of 0.1 mg/L to 1.0 mg/L for more than 10 years.
• Lead in the soil did not appear to be undergoing rapid downward migration into or through the
ground water aquifer.
• Lead concentrations in soil leachate were attenuated by subsurface soils.
• Lead concentrations in ground water were less than 0.04 mg/L even at relatively shallow depths
(10 to 15 feet).

Feasibility Study (1988)

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The Feasibility Study that was performed following the RI identified fourteen different alternatives for detailed
evaluation. These alternatives included seven innovative/alternative remedial treatment technologies. However,
because treatability data were not available for the innovative/alternative treatment technologies, these
alternatives could not be fully evaluated. Therefore, a final remedial action could not be selected for the
Westerly Wetlands without a complete evaluation of the innovative/alternative technologies.

Since the results of previous studies had identified potential risks to human health and the environment, it was
decided that an interim remedial action for the Westerly Wetlands was necessary to prevent off-site migration
of contaminants. Several remedial alternatives were evaluated before selecting the interim remedy in the OU-2
ROD issued on September 29, 1988.

The interim action selected in the OU-2 ROD was containment without capping of the Westerly Wetlands. This action
consisted of construction of a drainage system and a sedimentation basin to prevent off-site migration of
contaminants, and the installation of a security fence around the perimeter of the Westerly Wetlands to prevent
human access to the area. In addition, excavation and off-site disposal of contaminated soil present in the
Downstream Area was identified as a final remedy for that portion of the Site. The ROD also recommended
that treatability studies be performed on the most promising innovative/alternative remedial technologies for
the remaining areas of concern, namely, the Westerly Wetlands, Northerly Wetlands, and Tar Patch Area.

Ecological Assessment

In 1991, EPA conducted sampling of biota within the Westerly Wetlands with the purpose of performing an
ecological assessment for this Site. In addition to biota sampling, EPA also conducted limited soil sampling.

Results of the ecological assessment indicated the following:

• Plants on Site are accumulating low levels of lead.
• Worms are accumulating lead.
• Lead and PCBs pose a risk to avian predators (e.g. woodcock) of soil invertebrates such as
earthworms.
• PCBs pose a risk to predatory mammals (e.g. red fox and mink) but not to herbivorous mammals
such as deer.
• PCBs do not pose a risk to avian predators at higher trophic levels (e.g. red-tailed hawk).

Functional Assessment of the Wetlands

Five separate ecological investigations were performed as part of the functional assessment study covering the
Westerly Wetlands, Northerly Wetlands and Tar Patch Area. The purpose of the investigations was to assess the
functions and values of the biological communities on the Site. The investigations, which were conducted during
the autumn of 1993, included survey and mapping of major plant communities, a wildlife survey, a survey for
threatened and endangered species, an assessment of habitat quality using Habitat Evaluation Procedures
(HEP), and an assessment of the functions and values of wetlands using the Wetland Evaluation Technique (WET).

Six plant communities, including three wetland and three upland plant communities, were identified on the Site.
Burnt Fly Bog provides habitat for a moderate diversity of wildlife species, particularly birds. Reptiles and
amphibians are also likely to be present. The Westerly Wetlands provides habitat to a greater diversity of
wildlife than the other habitats on the Site and certain species occurring on the Site are likely to be found
only in the Westerly Wetlands. This is due primarily to the larger size and more diverse habitat structure of
the Westerly Wetlands.

The results of the field survey for threatened and endangered plant species indicated that no individual
specimens of the five species of concern identified by NJDEP, namely, Barrett's sedge, swamp pink, yellow-fringed
orchid, Knieskern's beaked rush, and coastal oceanorous were present. However, based on the habitat requirements
of each species of concern, potential habitat for four of the species occurs in the study area.

Habitat Evaluation Procedures (HEP) were used to identify the quality of habitat that could be impacted by the
proposed remedial activities for the BFB Site. The results of the HEP analysis indicate that Burnt Fly Bog

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provides moderate to optimal habitat for a number of species that are likely to occur on the Site. Due to the
presence of older and larger trees in the Northerly Wetlands than in the Westerly Wetlands, the Northerly
Wetlands provides moderate to optimal habitat for canopy dwelling birds and small mammals as well as cavity
nesting birds. The Westerly Wetlands, with more areas of open water interspersions and vegetation than the
Northerly Wetlands, provides moderate to optimal habitat for amphibian species and birds that utilize this type
of habitat. In addition, due to the larger area of the Westerly Wetlands compared to the Northerly Wetlands, the
Westerly Wetlands provides habitat for larger numbers of individual species as well as species that reguire a
larger home range.

Wetland Evaluation Technigues were used to assess the water guality functions provided by the wetlands on the
Site. An evaluation of the entire wetlands system (BFB Wetlands System) as well as separate analyses for the
Northerly Wetlands and Westerly Wetlands were conducted. Results were generated for four categories: social
significance, effectiveness, opportunity, and habitat suitability.

For social significance, the BFB Wetlands System was rated generally higher than either the Westerly Wetlands
or Northerly Wetlands, because the BFB Wetlands System is the most diverse of the wetland areas. For
effectiveness, the BFB Wetlands System, the Northerly Wetlands, and the Westerly Wetlands all rated moderate to
high for the evaluated functions and values. For opportunity, WET rated the BFB Wetlands System, the Northerly
Wetlands, and the Westerly Wetlands generally high. For habitat suitability evaluation, all three wetland
assessment areas received similar ratings. The majority of ratings received by each wetland assessment area for
habitat suitability evaluation were low to moderate.

Tar Patch Area Delineation

A phased sampling of the Tar Patch Area was conducted by Frederic R. Harris, Inc. in 1993 in order to fully
delineate the contamination present in the soil in this area. The sampling consisted of collection and analysis
of surface and subsurface soil samples for PCBs and lead.

Using the most stringent NJDEP Soil Cleanup Criteria at that time for lead and PCBs as reference levels, the
total volume of contaminated soil above 0.49 mg/kg for PCBs and 400 mg/kg for lead was determined to be 29,600
cubic yards, spread over an area of approximately 5.5 acres. The maximum depth of contamination is 6 feet. The
maximum contaminant concentrations detected in the soil in the Tar Patch Area were 1060 mg/kg for PCBs and 53,000
mg/kg for lead. However, a lead concentration of 70,000 mg/kg was detected in a sample taken from
tarry material found in this area.

Northerly Wetlands Sampling

The Northerly Wetlands was sampled in two phases in 1995 in order to complete the delineation of contamination
extent and determine the volume of contaminated soil present in this part of the Site. Surface and subsurface
soil samples were collected, and were analyzed for PCBs and lead. The volume of contaminated soil above 0.49
mg/kg for PCBs and 400 mg/kg for lead was determined to be 4000 cubic yards, the maximum depth being 2 feet. The
maximum contaminant concentrations detected in the Northerly Wetlands were 150 mg/kg for PCBs and 34,800
mg/kg for lead. The contamination was found to be spread over approximately 2.5 acres.

Westerly Wetlands Sampling

Surface soil samples were taken in 1996 to determine the levels of PCB and lead contamination in the soil, as
well as to confirm the lateral extent of contamination within the Westerly Wetlands. The results indicated that
the area of contamination remained largely unaltered (during this sampling phase, the maximum lead concentration
was 11,000 mg/kg and the maximum PCB concentration was 129 mg/kg) . It was also noted that surface PCB contaminant
levels established during the 1996 sample event within the Westerly Wetlands were demonstrated to be generally
less than the contaminant concentrations measured during the previous investigations in the 1980's.

The total volume of contaminated soil in the Westerly Wetlands is estimated at 73,300 cubic yards based on the
cleanup criteria of 0.49 mg/kg for PCBs and 400 mg/kg for lead. The area covered by contamination is
approximately 21 acres, the maximum depth of contamination being 4 feet.

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Quarterly Monitoring of Surface Water and Sediment in Burnt Fly Brook

Surface water and sediment in Burnt Fly Brook have been sampled and analyzed for PCBs and lead at four locations
in Burnt Fly Brook since March 1992, at approximately three-month intervals. The sampling points are located at
the point where surface water from the Site discharges into Burnt Fly Brook, 200 feet upstream and downstream
of this point, and approximately a half-mile downstream of the point at which surface water flows from the Site
into Burnt Fly Brook.

PCBs have not been detected in water samples collected during the guarterly monitoring. Lead contaminant levels
have not been found to be consistent, and are likely subject to seasonal variations in the rate of flow in Burnt
Fly Brook. Recent surface water samples indicated that lead levels were below the human health criteria and acute
aguatic Freshwater criteria, which are 5 micrograms per liter and 65 micrograms per liter, respectively. However,
they were found to be slightly above the aguatic chronic freshwater criteria of 2.5
micrograms per liter. Lead has also been consistently detected at the upstream background sample location in
Burnt Fly Brook, which indicates potential sources other than the BFB Site.

The most recent sediment sample data indicated no detectable PCBs in Burnt Fly Brook. Lead levels in sediment
were found to be below thesediment screening criteria described in the Ontario Ministry of the Environment and
Energy publication entitled, "Guidelines for the Protection and Management of Aguatic Sediment guality in
Ontario, August 1993".

Treatability Study

A treatability study was conducted in 1996 and early 1997 to evaluate the effectiveness of treatment technologies
on Site soils in remediating lead and PCB contamination, as specified in the 1988 ROD. Before the studies were
performed, several innovative technologies were evaluated, including KPEG, B.E.S.T., Bio-Clean, and incineration,
the four technologies identified in the 1988 ROD for further evaluation. Soil Washing and Chemical Dechlorination
technologies were finally chosen for the treatability study.

The treatment program consisted of testing the effectiveness of these two technologies, alone and in combination,
on soil specimens obtained from the Site. Over 180 different combinations of soil, reagents,
temperature, and concentrations were performed and analyzed to evaluate the two technologies. Based on the
results of the different treatment sample combinations, optimum soil washing processes and optimum chemical
dechlorination processes were developed. Results of the study indicated that remediation of Site soil to ecology
based cleanup levels could be achieved by using these two technologies in succession. However, owing to
limitations in the soil characteristics and laboratory detection levels, it was not possible to achieve
reduction in concentrations to human health based levels which are more stringent. The residual soil after
treatment was tested and found to be deficient in properties to support re-establishment of wetlands. Further
modification of the treated soil would be necessary to neutralize acidity and to minimize microbial toxicity in
order to make it suitable for the re-establishment of wetlands.

SUMMARY OF SITE RISKS

Based upon the results of all RI efforts, a baseline risk assessment was conducted to estimate the risks
associated with current and future conditions at the three remaining contaminated areas. The baseline risk
assessment estimates the human health and ecological risk which could result from the contamination at the Site
if no further remedial action was taken. Details of this risk assessment are summarized in the May 1994 report
entitled Public Health Evaluation.

Human Health Risk Assessment

The reasonable maximum human exposure is evaluated. A four-step process is used for assessing Site-related human
health risks for a reasonable maximum exposure scenario: Hazard Identification - identifies the contaminants of
concern at the Site based on several factors such as toxicity, freguency of occurrence, and concentration.
Exposure Assessment - estimates the magnitude of actual and/or potential human exposures, the freguency and
duration of these exposures, and the pathways (e.g. ingesting contaminated water) by which human beings are
potentially exposed. Toxicity Assessment - determines the types of adverse health effects associated with

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chemical exposures, and the relationship between magnitude of exposure (dose) and severity of adverse effects
(response). Risk Characterization - summarizes and combines outputs of the exposure and
toxicity measurements to provide a quantitative (e.g. one-in-a-million excess cancer risk) assessment of
Site-related risks.

The Baseline Risk Assessment that was conducted for the BFB Site evaluated the potential human health risks
associated with three distinct areas of the Site, namely, Westerly Wetlands, Northerly Wetlands, and Tar Patch
Area. In addition, it also evaluated Burnt Fly Brook which is found downstream of the BFB Site.

The initial step in the risk assessment process was the selection of contaminants of concern which would be
representative of Site risks. Lead and PCBs are the predominant contaminants of concern (COG). However, several
inorganic analytes, and volatile and semi-volatile organic compounds were also included as COCs. Those chemicals
which were thought to contribute most to the Site risk, based on factors such as frequency of detection and
concentration, were retained as COCs. The full list of the COCs can be found in the Public Health Evaluation
report.

An important factor that impacts the risk assessment is the assumed future use of the Site. Since the Westerly
Wetlands is unlikely to be developed due to the restrictions placed on protected wetlands, current and future
use will remain as undeveloped wetland. As such, an exposure scenario for this area included an adult and child
trespasser only. For the Westerly Wetlands, exposure of a Site trespasser to soil, sediment, surface water, and
blueberries was evaluated. Potential exposure to the Northerly Wetlands and Tar Patch Area soil and sediment was
evaluated for the current trespasser and the hypothetical future resident of this area. Exposure of area
residents to Burnt Fly Brook sediment and surface water, and ingestion by residents of edible biota such as deer
and waterfowl which may forage on the Site were also investigated as potential exposure
pathways of concern for the Site.

EPA has determined that an acceptable cancer risk range is 10 -4 to 10 -6, which can be interpreted to mean that
an individual may have a 1 in 10,000 to a 1 in 1,000,000 increased chance of developing cancer as a
result of Site-related exposure to a carcinogen over a 70-year lifetime under the specific exposure conditions
at the Site. EPA toxicity values were used to quantify risk based on the exposure scenarios described for the
Site. Lead, one of the predominant COCs at the Site, does not have an assigned EPA toxicity value. Therefore,
the risk from lead exposure could not be quantified using standard risk assessment methodologies.

PCBs, benzo(a)pyrene, and benzo(b)fluoranthene are the main compounds associated with carcinogenic risk. The
total risk for the Westerly Wetlands trespasser was estimated to be 1.49 x 10 -3. The dermal and ingestion
pathways for soil and sediment containing PCB compounds are the primary contributors to carcinogenic risk.
Ingestion of on-site blueberries was not shown to contribute significantly to elevated carcinogenic or
non-carcinogenic risk.

The total risk for the combined Northerly Wetlands/Tar Patch Area trespasser scenario was estimated to be 1.07
X 10 -3. The dermal and ingestion pathways for soil and sediment containing PCB compounds are the primary
contributors to carcinogenic risk. The total carcinogenic risk for a future resident living on the Northerly
Wetlands/Tar Patch Area of the Site was estimated at 7.5 X 10 -3. Here too, the dermal and ingestion pathways
for soil and sediment are the primary contributors to carcinogenic risk.

To assess the overall potential for non-carcinogenic effects posed by more than one contaminant, a hazard index
(HI) was developed. This index measures the assumed exposures to several chemicals at low concentrations
simultaneously, which could result in adverse health effects. In accordance with this approach, a hazard quotient
(i.e., the ratio of the level of exposure to an acceptable level) greater than 1.0 indicates a potential for
adverse non-carcinogenic health effects. The HI is summed for all media common to a particular
receptor.

With regard to non-carcinogenic effects, based on the calculated His, the trespasser scenario for the Westerly
Wetlands, Northerly Wetlands and Tar Patch Area, and the future residential scenario for the Northerly
Wetlands/Tar Patch Area do not contribute to an unacceptable non-carcinogenic risk.

Risk associated with ingestion and dermal contact of contaminated soil, ingestion of brook sediment, dermal

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contact with brook surface water, and ingestion of brook surface water could not be quantified based on exposure
to lead, since no EPA verified toxicity values are available for lead. Although risk to lead was not quantified,
concentrations of lead in Tar Patch Area and wetland soils (see Table 1 in Appendix II) may be considered a risk
with respect to ingestion and dermal contact based on comparison to EPA Screening Levels (400 mg/kg lead) and
NJDEP Soil Cleanup Criteria for lead (also 400 mg/kg lead). A qualitative evaluation for exposure to brook
sediment and surface water determined that lead exposure associated with ingestion of brook sediment and dermal
contact with brook surface water did not exceed a level calculated to be an acceptable intake of lead in soils
and drinking water. The intake of lead associated with ingestion of venison and waterfowl was shown to be
insignificant, when modeled to an acceptable lead intake associated with exposure to contaminated soils.

Ecological Risk Assessment

Ecological Risk Assessment involves a qualitative and/or semi-quantitative appraisal of the actual or potential
effects of a hazardous waste site on plants and animals. A four-step process is used for assessing Site-related
ecological risks for a reasonable maximum exposure scenario: Problem Formulation - a qualitative
evaluation of contaminant release, migration, and fate; identification of contaminants of concern, receptors,
exposure pathways, and known ecological effects of the contaminants; and selection of endpoints for further
study. Exposure Assessment - a quantitative evaluation of contaminant release, migration, and fate;
characterization of exposure pathways and receptors; and measurement or estimation of exposure point
concentrations. Ecological Effects Assessment - literature reviews, field studies and/or tests linking
contaminant concentrations to effects on ecological receptors. Risk Characterization - measurement or estimation
of both current and future adverse effects.

The ecological evaluation of the BFB Site included an Ecological Risk Assessment conducted by EPA in 1992, as
well as a follow-up Environmental Risk Assessment performed in 1994 by BCM Engineers Inc. for NJDEP.

The EPA Ecological Risk Assessment consisted of a comprehensive sampling and analysis program of abiotic and
biota media, laboratory bioassays, and calculated risk for selected species of wildlife representing several
trophic levels. The scope of the assessment was limited to the Westerly Wetlands. On the basis of standard risk
assessment modeling methods utilized by EPA, no organisms, except woodcock under a high exposure scenario, were
found to be at risk for lead. Mammalian predators, including red fox, and mink, and avian predators of soil
invertebrates, such as woodcock, were found to be at risk because of the presence of PCBs. Based on the applied
EPA reference dose, red-tailed hawk, an avian predator, was determined not to be at risk from PCBs. Herbivorous
or primarily herbivorous wildlife (e.g., white tailed deer, voles, and mice) were also
determined not to be at risk. Based on EPA tissue bioassays, shrews are very likely to be adversely affected by
PCB levels in their tissues. Comparison of Burnt Fly Bog forage species tissue levels to the Great Lakes
International Joint Commission Predator Protection Levels for PCBs indicates that woodcock, red-tailed hawk, red
fox and mink may all be at risk from feeding at the Site.

The follow-up Environmental Risk Assessment performed in 1994 focused on those species that were determined not
to be at risk in the EPA study. The Environmental Risk Assessment evaluated the effects of Site-related
contaminants of concern, namely PCBs and lead, on the Site's natural resources in the Westerly Wetlands,
Northerly Wetlands, and Tar Patch Area. Natural resources include existing flora and fauna, wetland communities,
and sensitive species or habitats. A wetlands delineation performed at the Site identified approximately 25 acres
of wetland areas within the three contaminated areas. No federally listed or proposed threatened or endangered
flora or fauna are known to occur at or near the Site. The Environmental Risk Assessment considered the effects
of lead on red-tailed hawk, fox, and deer, and PCBs on red-tailed hawk.

The Environmental Risk Assessment did not arrive at conclusions that were different from those presented in the
1992 EPA Ecological Risk Assessment. It confirmed that lead posed a risk only to avian predators (e.g. woodcock)
of soil invertebrates (e.g. earthworms).PCBs pose a risk to predatory mammals such as red fox and mink, butnot
to herbivorous mammals such as deer. PCBs do not pose a risk to avian predators at the higher trophic levels
(e.g. red-tailed hawk), except when evaluated against the Great Lakes International Joint Commission Predator
Protection Levels for PCBs.

The Environmental Risk Assessment suggests that concentrations of lead in soil may cause phytotoxicity in some
species of plants, including threatened and endangered plant species that could potentially occur at the Site.

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Significant uptake of PCBs into plant tissue was not measured.

REMEDIAL ACTION OBJECTIVES

Remedial Action Objectives are  specific goals to protect human health and the environment.  These objectives  are
based on  available  information,  applicable or  relevant  and  appropriate reguirements  (ARARs),  and  risk-based
levels established in the risk assessment.

The following remedial action objectives  were  established for cleanup activities for the remaining unremediated
portions of the BFB Site:

       •      Minimize exposures  to PCBs  and lead in soil at  levels  exceeding State  and Federal soil  cleanup
              criteria,  while minimizing  the extent of wetlands  to be  excavated;
       •      Minimize/control  releases of contaminants in sediment  into surface waters during  storm events;
       •      Minimize/control  exposures  to PCBs and lead in  soil  to ecological receptors;  and
       •      Restore the wetlands to a productive ecosystem.

DESCRIPTION OF REMEDIAL ALTERNATIVES

CERCLA  reguires  that the  selected Site  remedy be protective  of human health  and the  environment be cost
effective,  comply  with  other  applicable  or  relevant  and  appropriate  reguirements,   and  utilize  permanent
solutions,  alternative   treatment  technologies,  and  resource  recovery alternatives  to  the  maximum  extent
practicable. In addition, the statute includes a preference for  the use of treatment as  a principal element  for
the reduction of toxicity, mobility, or volume of the hazardous  substances.

Three different soil cleanup criteria for lead and PCBs were  used  during the evaluation of alternatives  in  the
Supplemental Feasibility Study. The soil cleanup criteria were established based on the  most current NJDEP soil
cleanup criteria, EPA screening  levels,  and values derived  from  the  ecological  risk assessment. They  are as
follows:

              NJDEP  Soil Cleanup  Criteria (residential)  of 0.49  mg/kg  for PCBs and 400  mg/kg for lead.

       •      EPA Screening Levels of 1 mg/kg  for PCBs and 400 mg/kg for lead.

       •      Ecological risk assessment  based numbers of 5 mg/kg  for  PCBs and 8,950 mg/kg for  lead.

Volumes of contaminated  soil present in the three areas of concern above the  three sets of cleanup criteria  are
shown in the Supplemental Feasibility Study Report.  The estimated  costs  of remediation  using the three sets of
cleanup criteria for the different remedial alternatives considered are also shown in the  report.

The remedy selection process  described herein is based on the  most  stringent human health based cleanup criteria
of 0.49 mg/kg for PCBs and 400 mg/kg for lead  (note:  these levels are  also  more stringent than the  ecological
risk assessment based numbers described above).

Use of these criteria will allow for unrestricted use of portions  of the Site in  the future.

The Supplemental  FS  report  evaluates in  detail six  remedial alternatives  for  addressing  the  contamination
associated  with  the Westerly  Wetlands  and Northerly Wetlands,  and seven  alternatives  for  addressing  the
contamination associated with the  Tar Patch Area. The Westerly  Wetlands and Northerly  Wetlands were  evaluated
separately from the Tar  Patch Area  because  the  natural characteristics  of the wetland  areas and the  Tar Patch
area are distinctly different, and the contaminant distributions  are also different, hence,  warranting different
considerations in the remedy selection process. For ease of identification in this ROD, the remedial alternatives
for the wetland  areas   (Westerly  Wetlands and Northerly Wetlands)  are listed  as Alternative W-l through
Alternative W-6,  while those for the Tar Patch Area are listed as  Alternative TP-1 through Alternative TP-7.

The remedial alternatives are described in detail below. Implementation times given include  the time  necessary
to construct and implement the remedy but do not include the time reguired for design or award of a contract  for

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the performance of the work.

Westerly Wetlands and Northerly Wetlands

Alternative W-l - No Action

Westerly Wetlands
Capital Cost: $0
O&M Cost: $0
Present Worth Cost:
Construction Time:
     Not Applicable
$0
Northerly Wetlands

Capital Cost: $0
O&M Cost: $0
Present Worth Cost:
Construction Time:
     Not Applicable
$0
The Superfund program requires that the "No Action" alternative be considered  as  a baseline  for  comparison of
other alternatives. The no action alternative involves no remedial action to reduce the toxicity, mobility or
volume of contamination in the Westerly Wetlands  and Northerly Wetlands. These portions of  the Site will  remain
in theirpresent condition. The wetland system can continue to function as a valuable hydrologic resource and
continue to provide habitat for a wide variety of flora and fauna.  The contaminated sediment  left
behind will present a risk to  some species  (small mammal and avian) for an undetermined period of time. However,
the natural processes  of  the  wetland ecosystem including vegetation growth, decay, and sediment build-up are
expected to  gradually cover the contaminated areas  over  time,  thus  reducing the  risk  of  exposure  to the
ecological receptors.  The  effectiveness  of this  cover process would  require  careful monitoring.  Over the past
ten years, obvious visible  changes  have been observed in the wetland  areas  with  a steady improvement  in the
vegetation.

Before surface water leaves the Site, the sedimentation basin that has already been  constructed in the Downstream
Area will  collect  any contaminated  sediment that may migrate  in  storm flows  originating from the rest  of the
Site. Although the presence of lead  was  detected  in surface  water within the Westerly Wetlands in the past, the
on-going monitoring of surface water and sediment in Burnt  Fly Brook  immediately downstream of the Site has not
shown appreciable levels of lead in  the water  (refer to the  section on Quarterly Monitoring of Surface Water and
Sediment on page 13). Because this alternative would result in contaminants remaining on Site,  CERCLA requires
that  the  Site be  reviewed every  five years. If justified by  the  review,  further  remedial  action  may be
implemented to address the contaminated soil.
Alternative W-2 - Limited Action and Institutional Controls
Westerly Wetlands

Capital Cost: $76,400
Annual O&M Cost: $3,850
      (for 30 years)
Present Worth Cost: $136,000
Construction Time: 6 months
                        Northerly Wetlands

                        Capital Cost:  $41,600
                        Annual O&M Cost:  $1,950
                             (for 30 years)
                        Present Worth Cost:  $71,000
                        Construction Time:  6 months
Alternative W-2 consists of  the  installation of additional security  fencing in areas where  fencing has not
already been provided,  and the  recording of a Deed Notice for the contaminated areas of the Site to  restrict
future use of the  Site.  Protection of human health will be achieved by  constructing the fence which will prevent
potential exposure to  contaminants  through direct contact.  The wetland system can continue to function as  a
valuable hydrologic  resource and continue to provide  habitat for a wide variety  of  flora  and fauna. The
contaminated sediment left behind will  present a risk to some  species  (small  mammals  and  avian  species)  for an
undetermined period of time. However, the natural processes of the wetland ecosystem including vegetation growth,
decay, and sediment build-up  are  expected to gradually cover the contaminated  areas over time, thus reducing the
risk  of  exposure  to  ecological  receptors.  The  effectiveness of  this cover process  would require  careful
monitoring over the past ten years,  obvious visible changes have  been observed in the wetland  areas
with a steady improvement in the vegetation.
Before surface water leaves the Site, the existing sedimentation basin in the Downstream Area will collect any

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contaminated sediment that may migrate in storm flows originating from the rest of the Site. Although lead was
detected in surface water within the Westerly Wetlands in the past, the on-going monitoring of surface water and
sediment in Burnt Fly Brook immediately downstream of the Site has not shown appreciable levels of lead in the
water (refer to section on Quarterly Monitoring of Surface Water and Sediment on page 13) . Because this
alternative would result in contaminants remaining on Site, the Site will be reviewed every five years in
accordance with the reguirements of CERCLA.

Alternative W-3 - Excavation, Off-site Disposal, and Wetland Restoration

Westerly Wetlands Northerly Wetlands
Capital Cost: $28,202,000
Annual O&M Cost: $4,250
(for 7 years)
Present Worth Cost: $28,227,000
Construction Time: 1 year 6 months
Capital Cost: $2,583,000
Annual O&M Cost: $4,250
(for 7 years)
Present Worth Cost: $2,608,000
Construction Time: 6 months
Alternative W-3 consists of the excavation and off-site disposal of contaminated soil present in the Westerly
Wetlands and Northerly Wetlands. The excavated areas will be backfilled with clean loamy soil that is capable
of sustaining wetland vegetation. Wetlands will be restored in the areas affected by excavation. The newly
created wetlands will be monitored for at least seven years to ensure proper restoration of wetlands.

Alternative W-4 - Consolidation, and Wetland Restoration

Capital Cost: $7,660,000
Annual O&M Cost: $10,200 (for 30 years)
Present Worth Cost: $7,835,000
Construction Time: 2 years

(Costs associated with this alternative are not shown separately for the two wetland areas as the remedial
activities will be focused on the combined area.).

Alternative W-4 consists of partial relocation of contaminated soil into areas within the impacted areas of the
Westerly Wetlands and Northerly Wetlands for consolidation. The consolidation areas will be chosen so as not to
impede drainage within the Site. The soil will be allowed to remain in place for a year in order for it to
consolidate by its own weight. An impermeable soil cap will be constructed on top of the consolidated soil to
limit exposure to contamination. The excavated areas will be backfilled with clean loamy soil that is capable
of sustaining wetland vegetation. Wetlands will be restored in the backfilled areas. The newly created wetlands
will be monitored for at least seven years to ensure proper restoration of wetlands. The consolidated areas will
be maintained for 30 years with periodic inspection of the cap to ensure that its structural integrity is
maintained. Because this alternative would result in contaminants remaining on Site, CERCLA reguires that the
Site be reviewed every five years. If justified by the review, further remedial action may be implemented to
address the contaminated soil.
Alternative W-5 - Pyrokiln Thermal Treatment, and Wetland Restoration
Westerly Wetlands

Capital Cost: $67,920,000
Annual O&M Cost: $4,250
(for 7 years)
Present Worth Cost: $67,945,000
Construction Time:
6 years 4 months
Northerly Wetlands

Capital Cost: $4,090,000
Annual O&M Cost: $4,250
(for 7 years)
Present Worth Cost: $4,115,000
Construction Time:
2 years 3 months
Alternative W-5 involves the incineration of the contaminated soil in a rotary kiln while adding inorganic
additives to promote thermal volatilization and/or encapsulation. The resultant ash is a mass of stabilized slag

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of insoluble, inert particles. Fluxing compounds are required to be added to promote the formation of nodules
of the required size. A pilot study would be required to determine the required fluxing compounds, before full
scale implementation. The residual material after treatment will not be suitable for the establishment of
wetlands and hence will be disposed of off-site. The excavated areas will be backfilled with clean loamy soil
that is capable of sustaining wetland vegetation. Wetlands will be restored in the backfilled areas. The newly
created wetlands will be monitored for at least seven years to ensure proper restoration of wetlands.

Alternative W-6 - Soil Washing, Chemical Dechlorination, and Wetland Restoration

Westerly Wetlands Northerly Wetlands
Capital Cost: $104,695,000
Annual O&M Cost: $3,550
(for 7 years)
Present Worth Cost: $104,720,000
Construction Time:
6 years 4 months
Capital Cost: $7,790,000
Annual O&M Cost: $3,550
(For 7 years)
Present Worth Cost: $7,815,000
Construction Time:
2 years 6 months
Alternative W-6 involves high-energy contacting and mixing of contaminated soil with an aqueous solution in a
series of mobile washing units for soil washing treatment. After soil washing is completed, the material will
undergo chemical dechlorination treatment. The soil washing/chemical dechlorination technologies will
only remediate the soil to the higher remediation goals of 5 mg/kg for PCBs and 8950 mg/kg for lead. Treated soil
will be disposed of off- Site, because it will not be suitable for establishing wetlands. The excavated areas
will be backfilled with clean loamy soil that is capable of sustaining wetland vegetation. Wetlands will be
restored in the backfilled areas. The newly created wetlands will be monitored for at least seven years to ensure
proper restoration.

Tar Patch Area

Alternative TP-1 - No Action

Capital Cost: $0
O&M Cost: $0
Present Worth Cost: $0
Construction Time: Not applicable

The Superfund program requires that the "No Action" alternative be considered as a baseline for comparison of
other alternatives. The no action alternative involves no remedial actions to reduce the toxicity, mobility or
volume of contamination in the Tar Patch Area. This part of the Site will continue to remain in its present
unvegetated condition, thus remaining vulnerable to more severe erosion and transport of contaminants downstream.
Before surface water leaves the Site, the sedimentation basin that has already been constructed in the Downstream
Area will collect sediment that may migrate in storm flows originating from the rest of the Site. Because this
alternative would result in contaminants remaining on Site, CERCLA requires that the Site be reviewed every five
years. If justified by the review, further remedial action may be implemented to remove or treat the contaminated
soil.

Alternative TP-2 - Limited Action and Institutional Controls

Capital Cost: $60,000
Annual O&M Cost: $3,600 (for 30 years)
Present Worth Cost: $114,700
Construction Time: 2 months
Alternative TP-2 consists of the installation of security fencing around the Tar Patch Area, and the recording
of a Deed Notice for the contaminated area to limit future use of the area. Protection of human health will be
achieved by constructing the fence which will prevent potential exposure to contaminants through direct contact.
Before surface water leaves the Site, the sedimentation basin that has already been constructed in the Downstream

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Area will collect sediment in storm flows originating from the rest of the Site, including the
Tar Patch Area. Because this alternative would result in contaminants remaining on Site, the Site will be
reviewed every five years in accordance with the reguirements of CERCLA.

Alternative TP-3 - Excavation, Off-site Disposal, and Wetland Establishment

Capital Cost: $13,965,000
Annual O&M Cost:: $1,100 (for 7 years)
Present Worth Cost: $13,975,000
Construction Time: 1 year

Alternative TP-3 consists of the excavation and off-site disposal of contaminated soil present in the Tar Patch
Area. The excavated areas will be backfilled with clean loamy soil that is capable of sustaining wetland
vegetation. Wetlands will be created in the area affected by excavation. The newly created wetlands will be
monitored for at least seven years to ensure proper establishment of wetlands.

Alternative TP-4 - Consolidation, and Wetland Establishment

Capital Cost: $2,670,000
Annual O&M Cost: $6,200 (for 7 years)
Present Worth Cost: $2,765,000
Construction Time: 1 year 6 months

Alternative TP-4 consists of partial relocation of contaminated soil into areas within the impacted Tar Patch
Area for consolidation. The consolidation areas will be chosen so as not to impede drainage within the Site. The
soil will be allowed to remain in place for a year to allow it to consolidate by its own weight before
constructing the cap. An impermeable soil cap will be constructed on top of the consolidated soil to limit
exposure to the contaminated soil. The excavated areas will be backfilled with clean loamy soil capable of
sustaining wetland vegetation. Wetlands will be created in the backfilled areas. The newly created wetlands will
be monitored for at least seven years to ensure proper establishment of wetlands. The consolidated areas will
be maintained for 30 years with periodic inspection of the cap to ensure that its structural integrity is
maintained. Because this alternative would result in contaminants remaining on Site, CERCLA reguires that the
Site be reviewed every five years. If justified by the review, further remedial action may be implemented to
address the contaminated soil.

Alternative TP-5 - Pyrokiln Thermal Treatment, and Wetland Establishment

Capital Cost: $29,045,000
Annual O&M Cost: $1,100 (for 7 years),
Present Worth Cost: $29,050,000
Construction Time: 3 years 1 month

Alternative TP-5 involves the incineration of the contaminated soil in a rotary kiln and adding inorganic
additives to promote thermal volatilization and/or encapsulation. The resultant ash is a mass of stabilized slag
of insoluble, inert particles. Fluxing compounds are reguired to be added to promote the formation of nodules
of the reguired size. A pilot study to determine the reguired fluxing compounds would be reguired before full
scale implementation. The residual material after treatment will not be suitable for the establishment of
wetlands and hence will be disposed of off-site. The excavated areas will be backfilled with clean loamy soil.
Wetlands will be created in the backfilled areas. The newly created wetlands will be monitored for at least seven
years to ensure proper establishment of wetlands.

Alternative TP-6 - Soil Washing, Chemical Dechlorination, and Wetland Establishment

Capital Cost: $34,525,000
Annual O&M Cost: $1,100 (for 7 years)
Present Worth Cost: $34,530,000
Construction Time: 3 years 1 month

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Alternative TP-6 involves high-energy contacting and mixing of contaminated soil with an agueous solution in a
series of mobile washing units, to perform soil washing. After soil washing is completed, the material will
undergo chemical dechlorination treatment. The soil washing and chemical dechlorination technologies will only
remediate the soil to the higher remediation goals of 5 mg/kg for PCBs and 8950 mg/kg for lead. Treated soil will
be disposed of off-site as it will not be suitable for establishing wetlands. The excavated areas will be
backfilled with clean loamy soil. Wetlands will be created in the backfilled areas. The newly created wetlands
will be monitored for at least seven years to ensure proper establishment of wetlands.

Alternative TP-7 - Capping-and Engineering Controls

Capital Cost: $2,485,000
Annual O&M Cost: $6,200 (for 30 years)
Present Worth Cost: $2,580,000
Construction Time: 4 months

Alternative TP-7 involves the construction of an impermeable soil cap over the contaminated area. The cap will
limit exposure to the contaminated soil and prevent erosion of contaminated soil during storm flows. Engineering
controls will be provided to facilitate the movement of storm water originating in upstream areas, around the
capped area. The capped area will be maintained for 30 years with periodic inspection of the cap to ensure that
its structural integrity is preserved. Because this alternative would result in contaminants
remaining on Site, CERCLA reguires that the Site be reviewed every five years. If justified by the review,
further remedial action may be implemented to address the contaminated soil.

SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

In accordance with the NCP, a detailed analysis of each remedial alternative was conducted with respect to each
of the nine criteria described below. This section discusses and compares the performance of the remedial
alternatives when considered against these criteria. All selected alternatives must at least attain the Threshold
Criteria. The selected alternative should provide the best balance among the nine criteria. The Modifying
Criteria were evaluated following the public comment period.

The evaluation criteria are described below:

Threshold Criteria

1. Overall protection of human health and the environment addresses whether or not an alternative
provides adeguate protection and describes how risks posed through each pathway are eliminated,
reduced, or controlled through treatment, engineering controls, or institutional controls.

2. Compliance with applicable or relevant and appropriate reguirements (ARARs) addresses whether or not
an alternative will meet all of the ARARs of the Federal and State environmental statutes or provide
a basis for invoking a waiver.

Primary Balancing Criteria

3. Long-term effectiveness and permanence refers to the magnitude of residual risk and the ability of
an alternative to maintain reliable protection of human health and the environment over time, once
remedial objectives have been met.

4. Reduction of toxicity. mobility, or volume through treatment addresses the statutory preference for
selecting remedial actions that employ treatment technologies that permanently and significantly
reduce toxicity, mobility, or volume of the hazardous substances as a principal element.

5. Short-term effectiveness refers to the period of time that is needed to achieve protection, as well
as the alternative's potential to create adverse impacts on human health and the environment during
the construction and implementation period.

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6. Implementability is the technical and administrative feasibility of a remedy, including the
availability of materials and services needed to implement a particular alternative.

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

Modifying Criteria

8. Support Agency acceptance indicates whether, based on its review of the RI and FS reports and the
ROD, the support agency 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. Responses to public comments are addressed in the
Responsiveness Summary (see Appendix VI).

Westerly Wetlands and Northerly Wetlands

The following presents a comparative analysis of the alternatives for the Westerly Wetlands and Northerly
Wetlands based upon the evaluation criteria noted above.

Overall Protection of Human Health and the Environment

Alternatives W-3 and W-5 provide for the maximum protection of human health and the environment on-site, since
under each of these alternatives, all contaminated soil would be excavated and treated on site or managed
off-site in some manner. Alternative W-6 will be less protective of human health, because contaminated soil will
be remediated to ecological risk-based cleanup levels. However, each of these three alternatives results in
significantly increased impact to the environment during implementation, because large portions of moderate and
optimal wetland habitat would be destroyed to gain access, and to excavate contaminated media. The Westerly
Wetlands would be impacted to a greater extent as the excavation alternative would destroy a larger area of more
valuable wetlands. These three alternatives will also significantly extend the period of time needed for the
whole Site ecosystem to be fully restored. There is also a level of uncertainty associated with the capabilities
and effectiveness of Alternative W-5. In addition, Alternative W-5 will result in air emissions that will reguire
collection and treatment. Alternative W-4 provides a lesser degree of protection of human health, because
contaminated soil will remain on Site consolidated under an impermeable soil cap. Due to excavation, however,
the impacts to the wetland ecosystem will be the same as for Alternatives W-3, W-5, and W-6. Alternative W-2
provides even lesser degree of protection of human health since all contaminated material will be allowed to
remain within the wetlands, and this alternative will rely on engineering and institutional controls to prevent
contaminants from migrating off-site, and to control human exposure to on-site contaminated media left in the
wetlands. However, this alternative will not reguire destruction of any moderate and optimal wetland habitat in
the Westerly Wetlands, thus allowing for continued occurrence of natural processes (i.e., sedimentation) which
are expected to reduce exposure to soil contaminants over time. The Northerly Wetlands would not have the same
degree of natural sedimentation and humification, because of the local hydrology and the type of vegetation. The
ecosystem will be hydrologically functional and continue to support species diversity. The existing sedimentation
basin within the Downstream Area will continue to prevent any off-site migration of contaminated sediment.
Alternative W-l provides the least protection of human health since all contaminated material will be allowed
to remain within the wetlands without any engineering and institutional controls to limit exposures. Similar to
Alternative W-2, Alternative W-l will provide some environmental benefit by leaving moderate and optimal wetland
habitat undisturbed, thereby allowing for natural processes to continue.

Compliance with ARARs

Alternatives W-3, W-5 and W-6 are expected to provide similar degrees of compliance with ARARs. Off-site disposal
of treated material in Alternative W-5 and Alternative W-6 will be performed in accordance with Resource
Conservation and Recovery Act (RCRA) Land Disposal Restrictions. In Alternative W-3, contaminated soil will be
disposed of off-site in accordance with RCRA land disposal reguirements and Toxic Substances Control Act (TSCA)
regulations. Transport of materials will be done in compliance with United States Department of Transportation
(USDOT) regulations for hazardous materials transportation. Air emissions during field operations will be

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monitored and controlled to satisfy the requirements of the Clean Air Act. Fresh water wetlands will be restored
in areas impacted by remedial activities, thereby meeting the requirements of the Fresh Water Wetlands Protection
Act, and the Endangered Species Act.

Action-specific and location-specific ARARs will be met during the implementation of Alternative W-4. Wetlands
will be created in the excavated areas, except in capped areas. The loss of any wetlands will be mitigated.

Alternatives W-l and W-2 will not attain chemical-specific to-be considered (TBC) criteria for surface soils as
site soil will be allowed to remain in place, untreated. Although there are current exceedances of New Jersey
Surface Water Quality Standards, Alternatives W-l and W-2, in conjunction with the sedimentation basin,
are also expected to meet chemical-specific ARARs for surface water. Alternatives W-l and W-2 will meet
action-specific ARARs.

Long-Term Effectiveness and Permanence

Alternatives W-3 and W-5 are expected to be the most effective remedies in the long-term with respect to on-site
protection of human health and the environment. Alternative W-6 is slightly less effective than Alternatives W-3
and W-5 since it reduces contamination to ecological risk-based cleanup levels only. Alternatives W-5 and W 6
are expected to treat the contaminated soil and, thereby, would result in less residual, untreated wastes than
in the case of the other alternatives. Alternative W-3 will provide long-term
effectiveness through the removal of contaminated soil from the Site for disposal off-site. Except for monitoring
of wetland restoration, no other controls will be required with Alternatives W-3, W-5 and W-6. There will be
uncertainty associated with the duration and the effectiveness of wetland restoration.. There is no certainty
that all of the natural services and biological diversity currently provided by the existing ecosystem can ever
be suitably restored, or if so, how long full restoration will take.

Alternatives W-2 and W-4 are expected to be less effective in the long-term because contaminated soil will remain
on Site without treatment. Exposure to contamination will be prevented through the construction of an impermeable
soil cap on consolidated soil in the case of Alternative W-4. In Alternative W-2, human exposure to contaminated
soil will be prevented by constructing a security fence, and by imposing use restrictions by filing a Deed Notice
on the property. The existing sedimentation basin will collect sediment in storm flows before surface water
leaves the Site. The wetland system will remain unaffected by Alternative W-2, and sediment build-up from
seasonal wetland processes are expected to gradually create a natural protective barrier on top of the
contaminated soil. Careful monitoring of these natural processes will be needed to insure reduction in ecological
exposure risks over time. Five year reviews of these alternatives will be required due to the continued presence
of contamination.

Alternative W-l is the least effective in the long-term because the contaminated soil will remain within the
wetlands without any engineering and institutional controls to limit exposure. Five year reviews will be required
due to the continued presence of contamination. The wetland system will remain unaffected and natural
sedimentation from seasonal wetland processes is expected to create a protective cover over time. The existing
sedimentation basin will collect sediment in storm flows before surface water leaves the Site.

Reduction in Toxicity, Mobility, or Volume

Alternatives W-5 and W-6 provide the greatest potential reduction of toxicity, mobility, or volume through
treatment of the contaminated soil. Alternative W-5 will remediate the soil by thermal treatment.

Alternative W-6 will reduce toxicity of the soil by soil washing and chemical dechlorination.

Alternative W-4 provides a limited reduction in contaminant mobility by placing an impermeable soil cap over
consolidated areas of contaminated soil. Toxicity and volume will not be reduced.

Alternative W-3 provides reduction in mobility of the contaminants by excavation and off-site disposal in a
landfill. Toxicity and volume will not be reduced by this alternative.

Alternatives W-l and W-2 provide no reduction in toxicity, mobility or volume of the contaminated soil.

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Short-term Effectiveness

Alternative W-l presents the least short-term risk to human health and the environment, because it involves no
remediation and no disturbance of existing contamination within the wetlands. While the wetland areas remain
contaminated, the risk of exposure to the contaminants is expected to be significantly mitigated by natural
re-vegetation and sedimentation processes over time. However, while no increases in risk result in the
short-term, remedial response objectives are not achieved.

Alternative W-2 can be considered to pose slightly greater short-term risk than Alternative W-l, because it
involves the construction of a perimeter fence around portions of the Site where a fence has not already been
constructed. However, the environmental impacts of constructing the fence at the periphery of the Site is
minimal.

The remaining alternatives, all of which involve Site remediation, present greater short-term risks to human
health and the environment. There will be short-term health risks associated with large scale movement of
contaminated soil. Exposure controls such as the use of personal protective eguipment and implementation of dust
control measures will minimize short-term risks. The existing sedimentation basin in the Downstream Area will
be used to capture sediment released downstream during construction operations. Off-site transportation of
contaminated soil in Alternative W-3 will slightly increase potential short-term exposure risks to the adjacent
community and the environment. The longer time reguired to implement Alternatives W-5 and W-6 will also increase
the short-term risk. The impacts caused to the existing ecosystem as a result of W-3, W-4, W-5, and W-6 will be
immense. There will be short-term risks to the ecosystem, biodiversity and habitat, because of such large scale
disruption to the environment.

Implementability

Alternative W-l is the most implementable of the alternatives because it reguires that no action be taken.

Alternative W-2 can be implemented easily because it involves only the construction of a perimeter fence and the
implementation of institutional controls (i.e., Deed Notice) by the State of New Jersey.

Among alternatives that involve Site remediation, Alternative W-3 is easier to implement than the others.
Excavation of contaminated soil, off-site disposal, and backfilling with clean fill material to restore wetlands
can be done using common earthmoving machinery and eguipment. The existing sedimentation basin can be used for
capturing any sediment migration during field operations.

Alternative W-4 will be slightly more difficult to implement because of the longer time reguired to complete the
work. The consolidated soil will be allowed to settle for a year before the impermeable soil cap is constructed.
Alternative W-4 also can be implemented using conventional earthmoving machinery and eguipment.

Alternatives W-5 and W-6 are the alternatives that are most difficult to implement, because they involve the
on-site setup and operation of the treatment processes. These alternatives also take the longest time to
implement.

Cost

Total present worth cost estimates for implementing the alternatives range from $0 to $112,535,000. Alternative
W-l does not entail any cost because it reguires that no action be taken. The next least costly alternative is
Alternative W-2 with a present worth of $207,000. Alternative W-4 costs the least among alternatives that involve
active Site remediation. The present worth cost for alternative W-4 is $7,835,000. Alternatives W-3 and W-5 cost
$30,835,000 and $72,060,000 to implement, respectively. Alternative W-6 at a cost of $112,535,000 is the
alternative with the highest cost to implement.

When only capital costs for alternatives are compared, they follow the same trend as for present worth costs.

Tar Patch Area

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The following presents a comparative analysis of the alternatives for the Tar Patch Area based upon the
evaluation criteria.

Overall Protection of Human Health and the Environment

Alternatives TP-3 and TP-5 provide for the maximum protection of human health and the environment on-site,
because all contaminated soil would be excavated and treated on-site or managed off-site in some manner.
Alternative TP-6 will be less protective of human health, because contaminated soil will be remediated to
ecological risk based numbers. There is a level of uncertainty associated with the capabilities and effectiveness
of Alternative TP-5. In addition, Alternative TP-5 will result in air emissions that will reguire collection and
treatment. Alternative TP-4 and TP-7 provide a lesser degree of protection of human health, because contaminated
soil will be allowed to remain on Site under an impermeable soil cap. There will be some impact to the ecosystem
that exists within the Site, during remedial operations under Alternatives TP-3, TP-4, TP-5, TP-6 and TP-7.
Alternative TP-2 provides even a lesser degree of protection of human health and the environment since all
contaminated material will be allowed to remain on the Site. This alternative will rely on engineering and
institutional controls to prevent contaminants from migrating off-site, and to control human exposure to on-site
contaminated media but will continue to allow exposure to the biological receptors. The existing sedimentation
basin within the Downstream Area will continue to prevent any off-site migration of contaminated sediment.
Alternative TP-1 provides the least protection of human health since all contaminated material will be allowed
to remain within the Site without any engineering and institutional
controls to limit exposures.

Compliance with ARARs

Alternatives TP-3, TP-5 and TP-6 are expected to provide similar degrees of compliance with ARARs. Off-site
disposal of treated material in Alternative TP-5 and Alternative TP-6 will be performed in accordance with RCRA
Land Disposal Restrictions. In Alternative TP-3, off-site disposal of contaminated soil will be disposed of
off-site in accordance with RCRA land disposal reguirements and TSCA regulations. Transport of materials will
be done complying with USDOT regulations for hazardous materials transportation. Air emissions during field
operations will be monitored and controlled to satisfy the reguirements of the Clean Air Act. Fresh water
wetlands will be restored in areas impacted by remedial activities, thereby meeting the reguirements of the Fresh
Water Wetlands Protection Act, and the Endangered Species Act.

Action-specific and location-specific ARARs will be met during the implementation of Alternative TP-4 and
Alternative TP-7. In the case of Alternative TP-4, wetlands will be created in the excavated areas, except in
capped areas. The loss of any wetlands will be mitigated.

Alternatives TP-1 and TP-2 will not attain chemical-specific TBC criteria for surface soils as site soil will
be allowed to remain in place, untreated. Alternatives TP-1 and TP-2 will meet action specific ARARs.

Long-Term Effectiveness and Permanence

Alternatives TP-3 and TP-5 are expected to be the most effective in the long-term, as fair as on-site protection
of human health and the environment is concerned. Alternative TP-6 is slightly less effective than Alternatives
TP-3 and TP-5 since it reduces contamination to ecological risk-based cleanup levels only. This will result in
lessresidual, untreated wastes than in the case of the other alternatives. Alternative TP-3 will provide
long-term effectiveness through the removal of contaminated soil from the Site for disposal Off-site. Except for
monitoring of wetland establishment, no other controls will be reguired for Alternatives TP-3, TP-5 and TP-6.
For each of these alternatives, there will be uncertainty associated with the effectiveness of wetland
establishment after the area is remediated.

Alternatives TP-2, TP-4 and TP-7 are expected to be less effective in the long-term because contaminated soil
will remain on Site without treatment. Exposure to contamination will be prevented by constructing an impermeable
cap in Alternatives TP-4 and TP-7. In Alternative TP-2, human exposure to contaminated soil will be prevented
by constructing a security fence, and by imposing restrictions such as institutional controls. The existing
sedimentation basin will collect any contaminated sediment that may migrate in storm flows before surface water
leaves the Site. Five year reviews will be reguired due to the continued presence of contamination on Site.

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Alternative TP-1 is the least effective in the long-term because contaminated soil will be allowed to remain on
Site without any engineering and institutional controls to limit exposure. Five year reviews will be reguired
due to the continued presence of contamination. The existing sedimentation basin will collect sediment in storm
flows before surface water leaves the Site.

Reduction in Toxicity, Mobility, or Volume

Alternatives TP-5 and TP-6 provide the greatest potential reduction of toxicity, mobility, or volume through the
treatment of the contaminated soil. Alternative TP-5 will remediate the soil by thermal treatment. Alternative
TP-6 will reduce toxicity of the soil by soil washing and chemical dechlorination.

Alternatives TP-4 and TP-7 provide a limited reduction in contaminant mobility by placing an impermeable soil
cap over the contaminated soil. Toxicity and volume will not be reduced.

Alternative TP-3 provides reduction in mobility of the contaminants by excavation and off-site disposal in a
landfill. Toxicity and volume will not be reduced by this alternative.

Alternatives TP-1 and TP-2 provide no reduction in toxicity, mobility or volume of the contaminated soil.

Short-term Effectiveness

Alternative TP-1 presents the least short-term risk to human health and the environment, because it involves no
remediation and no disturbance of existing contamination within the Tar Patch Area. However, while no increases
in risk result in the short-term, remedial response objectives are not achieved.

Alternative TP-2 can be considered to pose slightly greater short-term risk than Alternative TP-1 because it
involves the construction of a perimeter fence around the contaminated area. However, the environmental impacts
of constructing the fence at the periphery of the Tar Patch Area is minimal.

The remaining alternatives, all of which involve Site remediation, present greater short-term risks to human
health and the environment. There will be short-term health risks associated with large scale movement of
contaminated soil, except in the case of Alternative TP-7 where there will be less disturbance. Exposure controls
such as the use of personal protective eguipment and implementation of dust control measures will minimize any
short-term risks. The existing sedimentation basin in the Downstream Area will be used to capture
sediment released downstream during construction operations. Off-site transportation of contaminated soil in
Alternative TP-3 will slightly increase potential short-term exposure risks to the adjacent community and the
environment. The longer time reguired to implement Alternatives TP-5 and TP-6 will also increase the short-term
risk. There will also be some short-term impact caused to the existing ecosystem surrounding the Tar Patch Area,
because of remedial operations in this area.

Implementability

Alternative TP-1 is the most easily implementable of the alternatives because it reguires that no action be
taken.

Alternative TP-2 can also be implemented easily because it involves the construction of a perimeter fence, and
the implementation of a declaration of environmental restriction by the State of New Jersey.

Among the alternatives that involve Site remediation, Alternative TP-7 is easier to implement than the others.
The impermeable soil cap will be placed directly on top of the contaminated soil with minimal movement of the
soil.

Alternative TP-3 is easier to implement than the remaining alternatives. Excavation of contaminated soil,
off-site disposal, and backfilling with clean fill material to establish wetlands can be done using common
earthmoving machinery and eguipment. The existing sedimentation basin can be used for capturing any sediment
migration field operations.

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Alternative TP-4 will be slightly more difficult to implement because of the longer time reguired to complete
the work. The consolidated soil will be allowed to settle for a year before the cap is constructed.

Alternatives TP-5 and TP-6 are the most difficult to implement because they involve the on-site setup and
operation of the treatment processes. These alternatives also take the longest time to implement.

Cost

Total present worth cost estimates for implementing the alternatives range from $0 to $34,530,000. Alternative
TP-1 does not entail any cost because it reguires that no action be taken. The next least costly alternative is
Alternative TP-2 with a present worth of $114,700. Alternatives TP-4 and TP-7 with comparable costs are the least
costly among alternatives that involve active Site remediation. The present worth cost for Alternative TP-4 is
$2,765,000 and the cost for TP-7 is $2,580,000. Alternatives TP-3 and TP-5 cost $13,975,000 and $29,050,000,
respectively, to implement. Alternative TP-6 at a cost of $34,530,000 is the alternative with the highest cost
to implement.

When capital costs for alternatives are considered, they follow the same trend as for present worth costs.

SEIiECTED REMEDY

NJDEP and EPA have determined after reviewing the alternatives and public comments, that the appropriate remedy
for the three areas is as follows:

(a) limited Action with Institutional Controls (Alternative W-2) for the Westerly Wetlands;
(b) Excavation, Off-site Disposal, and Wetland Restoration (Alternative W-3) for the Northerly Wetlands;
and
(c) Excavation, Off-site Disposal, and Wetland Establishment (Alternative TP-3) for the Tar Patch Area.

Westerly Wetlands

The selected remedy for the Westerly Wetlands is Limited Action with Institutional Controls. NJDEP and EPA
believe that this alternative is protective of human health by controlling potential exposure to contamination
through the installation of a security fence and, from a long-term perspective, as a result of the anticipated
sediment build up from vegetative humification, which is expected to form an increasing protective barrier over
the contaminated soil. Since the extent of vegetative humification would be considerably much less in
the Northerly Wetlands, the Northerly Wetlands and the Tar Patch Area would continue to be active contamination
sources for the Westerly Wetlands, unless remediated. Although the selected remedy does not fully mitigate the
ecological risks posed by the Westerly Wetlands contamination, remediation of the Westerly Wetlands would cause
significant ecological impacts to this area and it is uncertain if these wetlands could be effectively restored.
As a result, the selected remedy will preserve the existing wetland system and reguire monitoring of the area
to confirm that conditions do not deteriorate and the above-described natural protective barrier continues to
develop. Additional security fencing will be installed around the Westerly Wetlands where fencing has not already
been provided.

The capital cost for the selected remedy for the Westerly Wetlands has been estimated at $76,400. The annual
operation and maintenance cost will be approximately $3,850. The total net present value of the cost of the
selected remedy is $136,000.

The existing wetland system, which has been rated moderate to high in value, will remain hydrologically
functional and continue to provide habitat, because no intrusive remedial measures will be undertaken within this
portion of the Site. The natural processes of the wetland ecosystem, including continued vegetation growth and
sediment build up, is expected to gradually mitigate the potential for contaminant migration and the potential
for exposure to the contaminated areas for both ecological and human receptors. In addition, removal of
contaminated soil from Northerly Wetlands and Tar Patch Area, which are located upstream of the Westerly
Wetlands, will also eliminate the potential for migration of contaminated sediment through surface water runoff
into the Westerly Wetlands.

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A sedimentation basin has already been constructed at the most downstream location within the BFB Site. This
basin will collect any contaminated sediment that may migrate in the near term during storm flows. Thus, most
of the particulate matter in the surface water will be captured in the sedimentation basin before surface water
leaves the Site. Dissolved contaminants in surface water will be monitored at the single discharge point beyond
the sedimentation basin.
Accumulation of sediment in the sedimentation basin will be monitored on a regular basis and sediment will be
excavated and removed for off site disposal at appropriate intervals. Natural sedimentation within the wetlands
over time will also be monitored regularly through the implementation of a monitoring plan to ensure that the
anticipated natural covering and containment of contamination is occurring. Monitoring will include biological,
surface water and sediment sampling in the Westerly Wetlands, surface water, sediment and, if
necessary, biological sampling in Burnt Fly Brook, and surface water and sediment sampling in the sedimentation
basin. The monitoring plan will be developed in consultation with the Biological Technical Assistance Group
(B-TAG) and will be implemented to monitor the effectiveness of this remedy selected for the Westerly Wetlands.

A Deed Notice will be prepared for filing with the appropriate authorities to control future use of the Westerly
Wetlands area. Because this remedy will result in contaminants remaining on Site, the Site will be reviewed every
five years in accordance with the requirements of CERCLA.

Northerly Wetlands

The selected remedy for the Northerly Wetlands is Excavation, Off-site Disposal and Wetland Restoration, which
involves the excavation and off-site disposal of all contaminated soil present in the Northerly Wetlands, and
the re-establishment of wetlands in the disturbed areas. Since this area is located immediately upgradient of
the Tar Patch Area and surface water runoff flows from the Northerly Wetlands into the Tar Patch Area., this
remedy will complement the remedy selected for the Tar Patch Area and prevent any recontamination of the Tar
Patch Area after its remediation. The contamination in the Northerly Wetlands is spread over a smaller area,
approximately 2.5 acres in extent, within mature forest habitat. When compared to the Westerly Wetlands, it
contains a smaller volume of contaminated soil that is easily accessible.

The excavation alternative provides for the maximum protection of human health and the environment on-site as
all contaminated soil will be excavated and removed off-site. Though the existing wetland areas will be destroyed
during excavation, the extent of the contaminated Northerly Wetlands is small when compared to the contaminated
Westerly Wetlands, and the wetland can be restored in the disturbed areas after backfilling with clean loamy
soil. Off-site disposal of the contaminated soil will be done in accordance with RCRA land disposal requirements,
and TSCA and USDOT regulations. Excavating and removing the contaminated soil off-site will result in a remedy
that is effective in the long-term, and permanent. Mobility of the contaminants will be reduced by removing the
contaminated soil to a landfill, although toxicity and volume will not be reduced. There will be minimal
short-term risk to the adjacent community and the environment during the remedial action. The remedial activities
are easily implementable using commonly available earthmoving machinery. A residential soil cleanup level of 0.49
mg/kg for PCBs and 400 mg/kg for lead will be used, because the Northerly Wetlands is more easily accessible to
trespassers. In addition, it will allow most of the contamination to be excavated, thus preventing the further
spreading of PCBs and lead into the Tar Patch Area and the Westerly Wetlands. Approximately 4,000 cubic yards
of contaminated soil will be excavated and removed, and approximately 2.5 acres of wetlands will be re-
established. The capital cost of the remedial activities in the Northerly Wetlands has been estimated at
$2,583,000. The annual operation and maintenance cost will be approximately $4,250. The total net present value
of the cost of the selected remedy is $2,608,000. EPA uses a PCB residential soil cleanup number of 1.0 mg/kg
instead of the NJDEP number of 0.49 mg/kg. The difference between the two volumes generated from these cleanup
levels is estimated to be 50 cubic yards, resulting in an implementation cost difference of $21,100 for the
Northerly Wetlands which will be borne by NJDEP.

The newly created wetlands will be monitored for at least seven years to ensure proper restoration of wetlands.
The Deed Notice will be extended to cover this area in order to preserve the wetland ecosystem that will be
restored.

Tar Patch Area

The selected remedy for the Tar Patch Area is Excavation, Off-site Disposal, and Wetland Establishment, which

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involves the excavation and off-site disposal of contaminated soil present in the Tar Patch Area, and the
establishment of wetlands in this area. For the Tar Patch Area, the cleanup goal is based on visual contamination
instead of an actual cleanup level. However, the excavation in this area should also meet the residential soil
cleanup goal as described for the Northerly Wetlands. The visual goal was chosen because the
contaminated area is clearly defined due to its lack of vegetation. If an exact number was specified for the Tar
Patch Area, it would include vegetated portions of the Westerly Wetlands Area. By removing this area, a
continuing source of contamination to the Westerly Wetlands can be removed without destroying heavily vegetated
wetland areas. In addition, excavation of the Tar Patch Area would also mitigate the migration of contaminants
into the Westerly Wetlands due to ground-water movement and surface water runoff.

Approximately 29,000 cubic yards of visibly contaminated soil from the unvegetated portion of the Tar Patch Area,
which is approximately 4 acres in extent, will be excavated. Excavated soil will be disposed of off-site in
accordance with TSCA, RCRA and USDOT regulations. Excavated areas will be backfilled with clean loamy soil that
is capable of sustaining wetland vegetation. Wetlands will be created in the area, which is now devoid of any
vegetation, and in any wetland areas affected by the remedial activities. The newly created wetlands
will be monitored for at least seven years to ensure proper restoration of wetlands. The Deed Notice will be
extended to cover this area in order to preserve the wetland ecosystem that will be restored.

The capital cost for the selected remedy for the Tar Patch Area has been estimated at $13,965,000. The annual
operation and maintenance cost will be approximately $1,100. The total net present value of the cost of the
selected remedy is $13,975,000. Because the cleanup goal is based on visual contamination in the Tar Patch Area
instead of actual cleanup numbers, a cost differential was not determined.

Excavation and removal of the contaminated soil is preferred over capping in place, because of the unstable
nature of the contaminated material present in the Tar Patch Area under extreme temperature conditions, and
consideration for long-term maintenance costs.

Summary

The selected remedy for the remaining areas of concern at the BFB Site is consistent with the remedy that was
chosen in the past for the Uplands Area, and the more recent provision of the sedimentation basin as an interim
remedy. Access controls that are already in place for the Uplands Area and the Downstream Area will be extended
to cover the Westerly Wetlands, the Tar Patch Area, and the Northerly Wetlands. The overall remedy provides the
most cost-effective approach to restore a contiguous wetland ecosystem with only limited, low cost, long-term
maintenance reguirements. The selected remedial action is protective of human health and the environment to the
extent practicable, limits disturbance and destruction of large areas of valuable wetland habitat, and, hence,
minimizes the potential for migration of contaminants downstream. No additional response actions are contemplated
at the Burnt Fly Bog Site at this time.

STATE ACCEPTANCE

The New Jersey Department of Environmental Protection supports the selected remedy presented in this Record of
Decision for the Westerly Wetlands, Northerly Wetlands, and Tar Patch Area. The State agrees to fund all
additional costs incurred during remedial action due to the application of NJDEP's more stringent PCB residential
cleanup criteria. The State does not waive its rights to challenge this later.

COMMUNITY ACCEPTANCE

Community acceptance was evaluated after the close of the public comment period. Written comments received during
the public comment period, as well as verbal comments during the public meeting were evaluated.

The majority of comments received during the public comment period originated from the MCEC and PRPS. While
supporting the selected remedy for the Northerly Wetlands and the Tar Patch Area, the Coalition has urged that
removal of contaminated sediment from any "Hot Spots" within the Westerly Wetlands be considered, particularly
adjoining the Tar Patch Area. The PRPs, while being supportive of the remedy for the Westerly Wetlands, are
opposed to the remedy chosen for the Northerly Wetlands and the Tar Patch Area. They recommend that a limited
action alternative similar to the one proposed for the Westerly Wetlands be considered for the Northerly Wetlands

-------
and the Tar Patch Area.

The county health officers  and many others present at the public meeting were supportive of the selected remedy.

STATUTORY DETERMINATIONS

The selected remedy satisfies the statutory requirements of section 121 of  CERCLA, which mandates that a remedial
action be protective  of human health  and  the environment, cost effective, and utilize permanent  solutions  and
alternative treatment technologies to  themaximum extent  practicable.  Section  121  also  establishes a preference
for remedial actions which employ treatment to  permanently  and significantly reduce the  volume,  toxicity,  and
mobility of the hazardous substances,  pollutants, or contaminants at a Site.  CERCLA
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 section 121(d)(4).

For the reasons discussed below, NJDEP and EPA have determined that the selected  remedy meets  the requirements
of Section 121 of CERCLA.

Protection of Human Health and the Environment

The selected remedy for Site  soils  is protective of human health  and the  environment,  since it involves  the
excavation and off-site disposal of  contaminated soils  from  the Tar Patch Area  and  the Northerly Wetlands and,
due to  conditions which  are  favorable  for  vegetative  humification and  sediment build-up,  allows for  the
development and monitoring of a natural protective  cover for  the contamination in  the Westerly Wetlands while
preserving the  ecological  integrity of the wetland system.   Once  the contaminated soil  is  removed from  the
Northerly Wetlands and Tar  Patch Area, wetlands will be established  in the excavated areas which will result in
the formation of  contiguous wetlands  from the Westerly  Wetlands  through  the  Northerly Wetlands.  Institutional
controls such as Deed Notices and engineering controls such as  a perimeter  fence  and  the sedimentation basin will
also contribute to the mitigation of human risk related to any exposure to  remaining contaminants.

With the appropriate  engineering controls,  the  excavation and removal of  soil from the Tar Patch  Area  and
Northerly Wetlands will not create unacceptable short-term risks or cross-media impacts.

Compliance with ARARs

Since most of the  Site is classified as wetlands,  the selected  remedy must  comply with the NJ Freshwater Wetlands
Protection Act Rules, Section 404 of the Federal Clean Water Act and Executive Order 11990 which require that
actions be taken to minimize the destruction,  loss or degradation of wetlands and  to preserve  and  enhance  the
natural and beneficial values of wetlands. Any actions which disturb or impact wetlands would additionally
require development of a wetlands mitigation plan. Since the contaminated soils in the Northerly
Wetlands and Tar  Patch Area will be excavated and  disposed of off site, the selected soil remedy  would meet
chemical-specific, location specific and action-specific Federal and State ARARs  and TBCs for  the contaminated
soils. Although the remedial  alternative  for  the Westerly Wetlands will  not meet  chemical-specific  ARARs  and
TBCs,  it  does  provide adequate  level  of protection of  human health and the  environment while limiting  the
disturbance and destruction of large areas of valuable wetland habitat.

Cost-effectiveness

Of the alternatives which most effectively address the threats posed by Site contamination, the selected remedy
is cost-effective as it has been determined to provide  the greatest overall effectiveness in  proportion to  its
cost.  The selected remedy results in a net present value  of the estimated  total project cost for all three areas
of $16,719,000.

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

The selected  remedy  represents the maximum  extent to  which permanent  solutions  and  alternative  treatment
technologies can be utilized in  a cost-effective manner for the BFB  Site. Excavation and Removal of contaminated
soil,  from  the Northerly Wetlands  and Tar Patch Area  will   offer  a permanent  solution to  the risks posed

-------
contaminated soils in these two areas. The sedimentation basin that has already been constructed upstream of
Burnt Fly Brook will collect sediment leaving the Westerly Wetlands during runoff and storm flows, thus reducing
potential migration of contaminants into downstream surface water bodies. As a result of the implementation of
the monitoring program to be developed in accordance with this ROD, monitoring data will be obtained to determine
the effectiveness of the remedy selected for the Westerly Wetlands. The sediment collected in the basin will be
removed off-site for disposal at regular intervals. In summary, the selected remedy provides the best balance
of tradeoffs with respect to the nine evaluation criteria.

Preference for Treatment as a Principal Element

The selected remedy will not satisfy the statutory preference for treatment as a principal element because
treatment of the principal threats of the Site was not practicable.

Treatability studies performed on contaminated soil from the Site using soil washing and chemical dechlorination
technologies showed that contaminant levels could not be reduced to human health based cleanup levels. It was
also found that the treated material was unsuitable for creating wetlands on Site.

The remedy provides for excavation and off-site disposal of contaminated soil from the Northerly Wetlands and
Tar Patch Area, in accordance with RCRA and TSCA regulations. Based on the available data, EPA and NJDEP do not
anticipate treatment of the contaminatedsoil prior to off-site landfill disposal. However, if the need for
treatment arises during the remedial action, based on the nature and PCB-concentration of the material generated,
such treatment will be performed prior to landfill disposal.

DOCUMENTATION OF SIGNIFICANT CHANGES

The Proposed Plan for the Site was released to the public on February 2, 1998. The Proposed Plan identified the
preferred alternatives for the Westerly Wetlands, Northerly wetlands, and the Tar Patch Area. NJDEP and EPA
reviewed all written and verbal comments received during the 90-day public comment period. Upon review of these
comments, NJDEP and EPA determined that no significant changes to the selected remedy, as originally identified
in the Proposed Plan, were necessary.

-------
                              APPENDIX I

                               FIGURES

Figure No.                     Title

      1                       Regional Site  Location Map

                              Site  Location  Map

                              Site  Map




                               APPENDIX II

                                 Tables

   Table No.               Title


          1.            Maximum and Average  Lead and PCB Concentrations in Soil

          2.            Areas and Volumes of Contaminated Soil

          3.            Estimate of Costs for Selected Remedy

-------
                                         TABLE 1
                MAXIMUM AND AVERAGE LEAD AND PCB CONCENTRATIONS IN SOIL
               AREA

    Tar Patch Area

    Northerly Wetlands

    Westerly Wetlands
            AT BURNT FLY BOG

             Lead  (mg/kg)

          Maximum       Average

           53,000        2,203

           34,800        8,168

           31,000       11,575
                     PCB (mg/kg)

                  Maximum   Average

                    1,060     8.6

                     150     78.4

                     254     51.9
Note:
     mg/kg - milligrams per kilograms
     (From Ecological Risk Assessment BCM 1993)
     Source BCM Engineers Inc. (BCM Project No.  00-516-094)
         Item
         Area
        Volume
                                   Table 2

                     Areas and Volumes of Contaminated Soil

                            Burnt fly Bog Site
Westerly Wetlands
   21 acres
  73,300 cu yd
Northerly Wetlands
   2.5 acres
  4,000 cu yd
Tar Patch Area
   5.5 acres
 29,600 cu yd
  Note
       Source Burnt Fly Bog Site Supplemental Feasibility Study Report - October 1997

       These volumes are approximated based on a soil cleanup level of 0.49 mg/kg for PCBs.
         Sub-site
     Westerly Wetlands
     Norherly Wetlands
       Tar Patch Area
                                         Table 3

                          Estimated Costs for Selected Remedy

                                   Burnt fly Bog Site
        Capital Cost
           $76,400
         $2,583,000
         $13,965,000
       Annual O&M Cost
        $3,850
        $4,250
        $1,100
     Present Worth cost
         $136,000
        $2,608,000
        $13,975,000,
  Note:
        Source Burnt Fly Bog Site Supplemental Feasibility Study Report - October 1997

-------

      APPENDIX III

Total Risk Summary Tables

           Table 1
                                 TOTAL RISK SUMMARY
                              FROM THE WESTERLY WETLANDS
                             USE: CURRENT/FUTURE TRESPASSER

                                      BURNT FLY BOG
                       MONMOUTH AND MIDDLESEX COUNTIES, NEW  JERSEY
                                  CARCINOGENIC RISK
                                                     RME
                                                                      AVERAGE
     SURFACE SOIL AND SEDIMENT - INGESTION
     SURFACE SOIL AND SEDIMENT - DERMAL
     SURFACE SOIL - INHALATION
     SURFACE WATER - DERMAL
     BLUEBERRIES - INGESTION
                                         TOTAL:
                        4.37E-04
                        1.04E-03
                        1.52E-06
                           *
                        1.21E-05
                        1.49E-03
 8.01E-05
 1.90E-04
 3.61E-07
    *
 8.55E-06
 2.79E-04
                               NONCARCLNOGENIC RISK - ADULT
     SURFACE SOIL AND SEDIMENT-INGESTION
     SURFACE SOIL - INHALATION
     SURFACE WATER - DERMAL
     BLUEBERRIES - INGESTION
                                         TOTAL:
                                                     RME
                                                  7.85E-04
                        2.70E-04
                        2.49E-02
                        2.59E-02
AVERAGE

 1.02E-04

 1.01E-04
 1.41E-02
 1.43E-02
                               NONCARCINOGENIC RISK - CHILD
    SURFACE SOIL AND SEDIMENT-INGESTION
    SURFACE SOIL - INHALATION
    SURFACE WATER - DERMAL
    BLUEBERRIES - INGESTION
                                          TOTAL:
                           RME

                         7.33E-03
                            *
                         9.62E-04
                         1.16E-01
                         1.24E-01
AVERAGE

  9.52E-04

  2.14E.04
  6.56E-02
  6.68E-02
    Notes:
    *=The only COPC for the specified route of exposure is  lead  for which  toxicity values  are not available.
    RME = Reasonable Maximum Exposure.
    BCM Project No: 00-0516-0902

-------

                                     Table 2

                               TOTAL RISK SUMMARY
                             FROM THE NORTHERN AREA
                             USE . CURRENT TRESPASSER

                                 BURNT FLY BOG
                 MONMOUTH AND MIDDLESEX COUNTIES, NEW JERSEY
                             CARCINOGENTIC RISK

    CURRENT TRESPASSER
    SURFACE SOIL AND SEDIMENT - INGESTION
    SURFACE SOIL AND SEDIMENT - DERMAL
    SURFACE SOIL - INHALATION
                                          TOTAL:
         RME

       3.32E-04
       7.40E-04
       1.15E-06
       1.07E-03
AVERAGE

4.53E-05
6.23E-05
1.46E-07
1.08E-04
                             NONCARCINOGENIC RISK
                                                   RME
                                                                     AVERAGE
    SURFACE SOIL AND SEDIMENT - INGESTION
    SURFACE SOIL AND SEDIMENT - DERMAL
    SURFACE SOIL - INHALATION
       3.88E-03
       9.78E-04
       1.17E-05
TOTAL: 4.87E-03
1.89E-03
2.48E-04
8.40E-06
2.13E-03
                               NONCARCINOGENIC RISK - CHILD
                                                   REM
                                                                     AVERAGE
    SURFACE SOIL AND SEDIMENT - INGESTION
    SURFACE SOIL AND SEDIMENT - DERMAL
    SURFACE SOIL - INHALATION
       3.62E-02
       2.07E-03
       4.81E-05
TOTAL: 3.83E-02
1.77E-02
5.25E-04
3.42E-05
1.82E-02
    Notes:
    *=The only COPC for the specified route of exposure is lead  for which  toxicity values  are not available.
    RME = Reasonable Maximum Exposure.
    BCM Project No.: 00-0516-0902

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                                 Table 3

                             TOTAL RISK SUMMARY
                           FROM THE NORTHERN AREA
                            USE: FUTURE RESIDENT

                               BURNT FLY BOG
               MONMOUTH AND MIDDLESEX COUNTIES, NEW JERSEY

                           CARCINOGENTIC RISK
    FUTURE RESIDENT
    SURFACE SOIL AND SEDIMENT - INGESTION
    SURFACE SOIL AND SEDIMENT - DERMAL
    GROUNDWATER - INGESTION
    GROUNDWATER - DERMAL
     RME

    2.32E-03
    5.18E-03
                                              TOTAL: 7.50E-03
        AVERAGE

       3.17E-04
       2.87E-04
                                                                         6.04E-04
                         NONCARCINOGENIC RISK - ADULT
                                                   RME
                                                                 AVERAGE
    SURFACE SOIL AND SEDIMENT - INGESTION
    SURFACE SOIL AND SEDIMENT - DERMAL
    GROUNDWATER - INGESTION
    GROUNDWATER - DERMAL
2.71E-02
6.85E-03
                                          TOTAL: 3.40E-02
1.32E-02
1.74E-03
    *
    *
1.50E-02
                         NONCARCINOGENIC RISK - CHILD

                                                   RME
                                                                  AVERAGE
     SURFACE SOIL AND SEDIMENT - INGESTION      2.53E-01
     SURFACE SOIL AND SEDIMENT - DERMAL         1.45E-02
     GROUNDWATER - INGESTION                         *
     GROUNDWATER - DERMAL                            *
                                         TOTAL: 2.68E-01
                 1.24E-01
                 3.67E-03
                    *
                    *
                 1.27E-01
     Notes:
     *=The only COPC for the specified route of exposure is  lead  for which toxicity values  are not available.
     RME = Reasonable Maximum Exposure.

-------
                                                                                
                                                                                       TABIiE 4
          Westerly
          Wetlands
       Soil/Sediment
   Westerly
   Wetlands
 Surface Water
                                                                           Compounds of Potential Concern
 Westerly
 Wetlands
Blueberries
 Westerly
   Wetlands
Groundwater
Northern Area
  Soil/Sediment
Burnt Fly
Brook Sediment
Burnt Fly
Brook Surface
  Water
     lead
     copper
     zinc
     PCBs
     elthybenzenene
     toluene
     xylene
     2,4-dimethyl phenol
     4-methyl phenol
     phenol
lead
mercury
zinc




aluminum
arsenic
barium
beryllum
chromium
lead
silver
vanadium
zinc
aldrin
methoxychlor
                                                                     lead
                 cadmium
                 copper
                 lead
                 zinc
                 PCB
                 ethylbenzene
                 methylene chloride
                 toluene
                 2-methylnaphylene
                 benzo(a)anthracene
                 benzo(a)pyrene
                 benzo(b)fluoranthene
                 benzo(g,h,1)perylene
                 benzo(k)fluoranthene
                 bis[2-ethythexyl]phthalate
                 chrysene
                 fluoranthene
                 naphthalene
                 phenanthrene
                 phenol
                 pyrene
                                                                                                                      lead
                                                                                                                                             lead

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                                     Table 7
             TOXICITY ASSESSMENT SUMMARY TABLE - NONCARCINOGENS
CHEMICAL

ORAL EXPOSURE
Aldrin
Arsenic
Aluminum
Barium
Beryllium
Bis(2-ethylhexyl)phthalate
Cadmium
Chromium
Copper
2,4-Dimethyl phenol
Ethylbenzene
Fluoranthene
Mercury
Methoxychlor
Methylene chloride
4-Methyl phenol
Naphthalene
Phenol
Pyrene
Silver
Toluene
Vanadium
Xylenes
Zinc
CHRONIC RfD
(mg/kg/day)
3.0E-05
3.0E-04
2.9E-00
7.0E-02
5.0E-03
2.0E-02
l.OE-03
5.0E-03
3.71E-02
2.0E-02
l.OE-01
4.0E-02
3.0E-04
5.0E.03
6.0E-02
5.0E-03
4.0E-02
6.0E-01
3.0E-02
5.0E-03
2.0E-01
7.0E-03
2.0E+00
3.0E-01
(D
(D
(5)
(D
(D
(D
(D
(3)
(4)
(D
(D
(D
(2)
(D
(D
(2)
(2)
(D
(D
(D
(D
(2)
(D
(D
     RfD BASIS
(species,  exposure)
                rat; diet
                human; d water
                not known
                human; d water
                rat; drinking water
                guinea pig, diet
                human; chronic
                rat; drinking water
                human; NA
                mouse; gavage
                rat; gavage
                mouse; gavage
                rat; oral
                rabbit; gavage
                rat; drinking water
                rat; gavage
                rat; gavage
                rat; gavage
                mouse; gavage
                human; iv
                rat; gavage
                rat; drinking water
                rat; gavage
                human; diet supplements
                                                                                  CRITICAL  EFFECT
                            liver toxicity
                            skin changes
                            not known
                            increased blood pressure
                            no effects observed
                            increased liver weight
                            kidney toxicity
                            no effects observed
                            g.i.  tract irritation
                            clinical/hemat.  changes
                            liver and kidney toxicity
                            nephrotox.,  hemat.  et al
                            kidney toxicity
                            reproductive toxicity
                            liver toxicity
                            resp.  distress,  cyanosis,
                            low body weight gain
                            fetotoxicity
                            kidney toxicity
                            skin argyria
                            liver/kidney wt change
                            no effect observed
                            hyperactivity,  low b.w.
                            decreased ESOD
death
                                                                                                           (6)
                                                                                                                 CONFIDENCE
                                                                                                                   LEVEL
                                                                                                                  UF  AND  MF*
med/UF=l,000, MF=1
med/UF=3, MF=1
not known
  UF=3,000,  MF=1
low/UF=100,  MF=1
med/UF=l,000, MF=1
high/UF=10,  MF=1
low/UF=500,  MF=1
NA
low/UF=3,000, MF=1
low/UF=l,000, MF=1
low/UF=3,000, MF=1
UF=1,000
UF=1000, MF=1
med/UF=100;  MF=1
UF=1,000
UF=10,000
low/UF=100;  MF=1
UF=3000, MF=1
UF=3,  MF=1
med/UF=l,000; MF=1
UF=100
med/UF=100,  MF=1
UF=10
*UF=Uncertainty Factor, MF=Modifying Factor, NA=not applicable, Confidence Levels = high, medium (med),  or  low.
(1) IRIS
(2) HEAST
(3) Oral RFD for Hexavalent Chromium
(4) The Oral RfD for Copper is extrapolated from a drinking water  standard  (1.3 mg/1)  suggested  in  HEAST
(5) EPA-ECAO (cited in Region III Rusk-Based Concentration Table,  Fourth Quarter 1993)
(6) ESOD = erythrocyte superoxide dismutase concentration
(7) Calculated from inhalation reference concentrations  (RfCs) cited in IRIS or HEAST
(8) Inhalation RfC withdrawn from HEAST

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                                   Table  8

               TOXICITY ASSESSMENT SUMMARY  TABIiE  -  CARCINOGENS
WEIGHT OF
EVIDENCE
B2
A
B2
B2
B2
B2
B2
B2
B2
B2
B2
Bl
B2
B2
B2
B2
B2


(D
(D
(D
(D
(D
(D
(D
(D
(D
(D
(D
(D
(D
(D
(D
(D
(D
                                                     SLOPE
                                                  FACTOR (SF)
                                                (I/(ing/kg/day))
          SF BASIS
     (species,  exposure)
CHEMICAL                     EVIDENCE            (I/(mg/kg/day))    (species, exposure)      TARGET ORGAN

ORAL EXPOSURE

Aldrin
Arsenic
Beryllium
Benzo[a]anthracene
Benzo[b]fluoranthene
Benzo[k]fluoranthene
Benzo[a]pyrene
Bis(2-ethylhexyl)phthalate
Chrysene
Methylene chloride
Polychlorinated biphenyls

INHALATION EXPOSURE

Cadmium                        Bl      (1)        6.
Benzo[a]anthracene             B2      (1)        6.
Benzo[a]pyrene                 B2      (1)        6.1E+00
Benzo[b]fluoranthene           B2      (1)        6.1E-01
Benzo[k]fluoranthene           B2      (1)        6.1E-02
Chrysene                       B2      (1)        6.1E-03

* NA=not applicable.
(1) IRIS
(2) HEAST
(3) Arsenic slope factor calculated from proposed unit risk of 5E-05 l(ug/l)  cited in IRIS
(4) Cited in EPA Region III  Risk-Based Concentration Table, Fourth Quarter 1993
    (TEF approach to PAH carcinogenicity,  see text Section 4)
(5) Withdrawn from HEAST
                                                1.7E-01
                                                1.75E-00
                                                4.3E-00
                                                7.30E-01
                                                  30E.01
                                                  30E.02
                                                  30E-00
                                                  4E-02
                                                7.30E-03
                                                7.5E-03
                                                7.7E-00
                                                  3E+00
                                                  1E-01
(1)
(3)
(1)
(4)
(4)
(4)
(1)
(1)
(4)
(1)
(1)
(1)
(4)
(5)
(4)
(4)
(4)
mouse; diet
human, drinking water
rat; drinking water
NA
NA
NA
mouse, diet
mouse, diet
NA
mouse; d water/inhal
rat, diet
human; inhalation
NA
hamster, inhalation
NA
NA
NA
liver
skin
total tumors  (>1 type)
NA
NA
NA
stomach
liver
NA
liver
liver
lung, trachea
NA
respiratory tract
NA
NA
NA

-------
APPENDIX-IV

BURNT FLY BOG SUPERFUND SITE

ADMINISTRATIVE RECORD FOR OPERABLE UNIT 3

1. Record of Decision, Burnt Fly Bog - 1983
2. Westerly Wetland Remedial Investigation Final Report, Burnt Fly Bog Site - January 1988
3. Westerly Wetland Ultimate Remedy Feasibility Study Final Report, Burnt Fly Bog Site - January 1988
4. Westerly Wetland Lead Mobility Studies Final Report, Burnt Fly Bog Site - February 1988
5. Westerly Wetland Water Budget Final Report, Burnt Fly Bog Site - February 1988
6. Record of Decision, Burnt Fly Bog, Westerly Wetlands - September 1988
7. Ecological Assessment Final Report, Burnt Fly Bog - June 1992
8. Final Field Sampling and Testing Results Report - Tar Patch Area - May 1994
9. Final Design Report, Burnt Fly Bog Sedimentation Pond Design - September 1994
10. Background Investigation Report, Burnt Fly Bog - March 1994
11. Health and Safety Plan for Burnt Fly Bog Westerly Wetlands - September 1993
12. Public Health Evatluation for the Supplemental Feasibility Study of Burnt Fly Bog - May 1994
13. Burnt Fly Bog Wetland Delineation Report - May 1994
14. Functional Assessment Report for the Supplemental Feasibility Study of Burnt Fly Bog - February 1994
15. Environmental Risk Assessment for the Supplemental Feasibility Study of Burnt Fly Bog - March 1994
16. Burnt Fly Bog Superfund Site Treatability Study Final Report - April 1997
17. Burnt Fly Bog Wetlands Restoration and Environmental Evaluation Study - June 1997
18. Final Supplemental Feasibility Study Report for Burnt Fly Bog Site - October 1997
19. Site Review and Update, Burnt Fly Bog (US Department of Health and Human Services, ATSDR) -
December 4, 1997
20. Northerly Wetlands Field sampling Report, Burnt Fly Bog Superfund Site Supplemental Feasibility
Study - January 1997
21. Westerly Wetlands Field Sampling Report, Burnt Fly Bog Superfund Site, Supplemental Feasibility
study - September 1997
22. Superfund Proposed Plan, Burnt Fly Bog Site - February 1998
23. Community Relations Plan - Update for Remedial Actions at the Burnt Fly Bog Superfund, Site,
Marlboro Township, Monmouth County, June 1996
24. Notice of public availability of the Proposed Plan dated February 1998
25. Transcript of the Public Meeting hold on February 19, 1998 in Marlboro September 9, 1998

-------
                                     APPENDIX V

                           NJDEP's Letter of Concurrence

                                        STATE OF NEW JERSEY
Christine Todd Whitman         Department of Environmental Protection    Robert C.  Shinn,  It
Governor                                                                       Comissioner

Ms. Jeanne M. Fox
Regional Administrator                                             SEP 28 1998
U.S. EPA - Region II
290 Broadway
New York, NY 10007-1866

Subject:    Burnt Fly Bog Superfund Site
            Record of Decision (ROD)  - Operable Unit 3

Dear Ms. Fox:

The New Jersey Department of Environmental  Protection (NJDEP)  has  evaluated and concurs  with the  components  of
the selected remedy as described below for  the Burnt at  Fly Bog Superfund Site. The selected remedy corresponds
to the third operable unit for the Site, which is located in Marlboro Township, Monmouth County,  New Jersey.

   The major components of the selected remedy include:

   1.   Excavation and off-site disposal of contaminated soil from the Northerly Wetlands;
   2.   Excavation and off-site disposal of contaminated soil from the Tar Patch Area;
   3.   Backfilling the excavated area in the Northerly Wetlands  and re-establishing wetlands;
   4.   Backfilling the excavated area in the Tar Patch Area and  creating wetlands;
   5.   Provision of additional security fencing around the Westerly Wetlands, and the  recording of Deed
        Notices for the Westerly Wetlands,  Northerly Wetlands, and Tar Patch Area;
   6.   Monitoring of surface water and sediment in the Westerly  Wetlands,  surface water and sediment in
        the existing sedimentation basin located in the Downstream Area,  and surface water,  sediment and,
        if necessary, biota in Burnt Fly Brook; and
   7.   Biological sampling in the Westerly Wetlands.

NJDEP  concurs  that  the  seleced  remedy  is  protective  of  human  health  and  the  environment,   complies with
reguirements, that are legally applicable  or relevant and appropriate  for the remedial  action,  and is cost
effective. Although the State disagrees with the PCB cleanup number selected by EPA, we still  concur with the
remedy since it does not affect the selected cleanup methods.

The State of New Jersey appreciates the opportunity afforded to participate in the Superfund process.

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                                  APIENDIX VI

                            Responsiveness Summary
                         Burnt Fly Bog Superfund Site

This responsiveness summary is divided into the following sections:

A.    Overview
B.    Background on Community Involvement
C.    Summary of Comments received during the Public Comment Period and NJDEP responses.
             -- Part I:  Summary and responses to community concerns voiced at the
                        February 19, 1998 public meeting
             -- Part II: Summary and responses to written concerns received during the
                         public comment period

A.    Overview

This is a summary of the comments and guestions  from the public regarding the Proposed Plan, dated February 1998,
for  remediation  of the  Burnt  Fly  Bog (BFB)  Superfund  Site,  and the New  Jersey Department of  Environmental
Protection's (NJDEP) and U.S. Environmental Protection Agency's  (USEPA)  responses to those comments and
guestions.

A public comment period was  held from February 4, 1998  through  May  4,  1998 to provide interested parties  the
opportunity to comment  on  the Proposed Plan for the BFB Site. During the comment period, NJDEP  held  a  public
meeting on February 19,  1998 at 7:00 PM at the Marlboro Municipal Building to discuss results of the Remedial
Investigation and  Supplemental  Feasibility Study  (RI/SFS)  reports,  and to present  the NJDEP/USEPA preferred
alternative for remediation of the Site.

The preferred remedial alternative  addresses three remaining unremediated areas of the Site under Operable Unit
3. The remedy as such is the preferred remedy for the Westerly Wetlands, Northerly Wetlands and Tar Patch Area
at the BFB  Site. The remedial alternatives that were  evaluated and presented  in  the Proposed Plan were developed
for  remediation  of the  Site  in accordance  with the Comprehensive  Environmental Response,  Compensation  and
Liability Act of 1980 (CERCLA) , as amended, and the National Oil and Hazardous Substances  Pollution Contingency
Plan  (NCP). Specifically, the preferred alternative includes 1)  limited action and  institutional controls  for
the Westerly Wetlands; 2) excavation with off-site disposal  and wetlands restoration for the Northerly Wetlands;
and 3) excavation with off-site disposal and wetlands establishment for the Tar Patch Area.

B.   Background on Community Involvement and Concerns

The Burnt Fly Bog has consistently received attention from  area residents, municipal, state, county and federal
officials  as well  as  the media. In 1981,  concerned residents organized  the Burnt Fly Bog Citizens  Advisory
Committee (BFBCAC). The Committee includes citizen representatives from Marlboro and Old Bridge Townships as well
as officials from Monmouth and Middlesex Counties.  NJDEP  representatives have met regularly with this group since
1981 and continue  to  do so.  In 1998,  a group  known  as  the  Monmouth County Environmental Coalition  received  a
Technical Assistance Grant  from the USEPA to hire technical  advisors to review documents and offer input  to  the
cleanup process.

A primary concern of the community has always been the protection of the Englishtown Aguifer.  Because the Site
is a ground water discharge area located within the Englishtown Aguifer,  there has been no  significant migration
of contaminants into this major water supply resource.  Also, the  Site is  underlain  by Woodbury clay,  which is
a significant aguitard in this region. The Woodbury clay  separates the Englishtown Aguifer from the Lower Magothy
Aguifer, thereby preventing  the migration of contaminants  to the aguifer below. Other issues  of concern have
focused on the potential environmental and public health risks posed by  the  Site.  In particular,  the ingestion
of contaminated water  has been an issue because of the high  concentrations of lead on the  Site.  NJDEP routinely
tests surface water in Burnt  Fly Brook, which receives surface water discharges from the Site,  to monitor water
guality. Residents  and  officials  of  Old  Bridge,  Perth  Amboy  and Matawan  have  also expressed  concern  about
potential contaminant migration to the Deep Run water body,  which receives drainage from Burnt  Fly Brook  and

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recharges the Perth Amboy Wellfield. As an interim remedy, a sedimentation basin was constructed in 1996 at a
downstream location within the Site to capture sediment before surface water leaves the Site. Residents have also
expressed a strong desire to ensure that a remedy does not destroy or significantly impact good guality wetlands.

C. Summary of Comments received during the Public Comment Period and NJDEP/USEPA Responses

Part I: Summary and response to community concerns voiced at the February 19, 1998 public meeting.

Westerly Wetlands Issues

1. COMMENT
A request was made to see the data from the Westerly Wetlands displayed on a grid to determine whether any hot
spots exist within the area, which could be removed.

RESPONSE
Maps showing contaminant concentrations are already available. The Ebasco Remedial Investigations report (1988)
contains full-size drawings showing cross-sections, concentrations, concentration contours etc. The contamination
is found to be widespread throughout the Westerly Wetlands.

2. COMMENT
If humification is allowed to occur while leaving the contamination underneath the "natural" cap, how will it
affect the ground water?

RESPONSE
Humification is the creation of humus or organic matter owing to natural bio-degradation of dead vegetative
matter.

Ground water in the vicinity of the Westerly Wetlands discharges to the surface. Therefore, migration of
contaminants down through the water table is not occurring. Lead and PCBs are expected to be bound with the soil,
not mobilized through surface water runoff. In addition, a sedimentation basin was constructed in 1996 at a
location downstream of the Westerly Wetlands. This basin is designed to collect sediment from storm runoff
originating from contaminated areas, and to allow surface water to continue to flow into Burnt Fly Brook.

3. COMMENT
What would happen if a reversal of hydraulic conditions occurred during dry spells, changing the area into a
ground water recharge area?

RESPONSE
Although there has never been an indication that this would occur, the most likely places for a reversal of
hydraulic conditions to occur would be the Northerly Wetlands and Tar Patch Area. Removal of contaminated soil
from the Northerly Wetlands and the TarPatch Area, as recommended in the preferred alternative, would therefore
eliminate the risk of contaminants entering the Englishtown Aguifer.

4. COMMENT
The Monmouth County health officer stated that, based on 20 years of experience with the Site, he is in agreement
with NJDEP/USEPA's preferred alternative. He would, however, add that at least once a year, the Department, along
with representatives from Old Bridge and Marlboro, inspect the full perimeter of the Site to ensure no breaches
in the fencing occurred.

RESPONSE
Inspection of perimeter access controls on a regular basis will ensure that the integrity of the fencing is
maintained, and will be included in the operations and maintenance program for the Westerly Wetlands. Old Bridge
and Marlboro Township officials are welcome to join the Department officials on these inspections, and should
coordinate such visits with the NJDEP operations manager.

5. COMMENT
Concerns were raised that by leaving contamination in place, NJDEP would be creating a "toxic graveyard".

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RESPONSE
NJDEP and USEPA disagree with the terminology "toxic graveyard". While contamination will be allowed to remain
in the Westerly Wetlands, the process of vegetative humification and sediment buildup will form a barrier,
thereby reducing potential exposure to contaminated sediment. In addition, both agencies support leaving
contamination behind rather than excavating what is currently a thriving ecosystem. It is believed that these
natural processes can successfully cover the contaminated areas within the wetlands. However, extensive
monitoring will be performed to ensure that theseprocesses are occurring and that the remedy remains protective
over the long term. The primary objective is to allow the wetland ecosystem to remain undisturbed while
eliminating potential human exposure through 'restricted access'.

6. COMMENT
Since higher contaminant concentrations are commonly found closer to the source of the problem, hot spots in the
Westerly Wetlands could be expected to be present closer to the Tar Patch Area. As remedial work will be done
in the Tar Patch Area, the hot spots within the Westerly Wetlands can also be remediated with little or no extra
effort in terms of constructing access roads.

RESPONSE
Maps showing contaminant concentrations in the Westerly Wetlands are already available. The Ebasco Remedial
Investigations report (1988) contains full-size drawings showing cross-sections, concentrations, concentration
contours etc. The contamination is found to be widespread throughout the Westerly Wetlands.

After careful evaluation and investigation of the wetland areas downstream and surrounding the Tar Patch Area,
both agencies determined that hot spot removal within the Westerly Wetlands is not appropriate. It is evident
from historic data that high levels of contamination extend throughout the Westerly Wetlands, and that accessing
and excavating any or all of these higher contamination areas would reguire destruction of large areas of high
guality wetland habitat. Also see RESPONSE No. 5 in Part II.

7. COMMENT
Although data has not changed since the 1992 study, there may be greater bioaccumulation of PCBs through the food
chain. Therefore, would NJDEP be willing to extend the remediation of the Tar Patch Area if the trends look like
contamination is greater adjacent to the Tar Patch Area in the Westerly Wetlands?

RESPONSE
Regarding the greater bioaccumulation of PCBs, such guestions are expected to be answered by the comprehensive
monitoring program that the NJDEP and EPA will be implementing. Due to conditions within the Westerly Wetlands
which are favorable for vegetative humification and sediment build-up, the selected remedy will allow for the
development and monitoring of a natural protective cover over the contamination in the Westerly Wetlands while
preserving the ecological integrity of the wetland system.

The remediation of the Tar Patch Area will include a portion of the Westerly Wetlands which is immediately
adjacent and similar in appearance to the Tar Patch Area.

8. COMMENT
Do we have the technology to clean up the Westerly Wetlands?

RESPONSE
The only reliable technology that is currently available is excavation and removal of contaminated soil. While
the removal of contaminated soil from the Westerly Wetlands is technically feasible, the restoration of wetlands
of such high guality has not proven to be as successful. See also RESPONSE No. 5.

Northerly Wetlands and Tar Patch Area

9. COMMENT
How much soil is expected to be removed?

RESPONSE
Approximately 29,000 cubic yards of soil spread over the unvegetated portion of the Tar Patch Area will be

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removed. The area involved is about four acres. In the Northerly Wetlands, approximately 4,000 cubic yards spread
over 2.5 acres will be removed.

10. COMMENT
Will wetlands be created in the Tar Patch Area?

RESPONSE
Upon completion of the removal action, wetlands will be created in the Tar Patch Area and Northerly Wetlands.

11. COMMENT
Can EPA' s Removal Action Program implement the Tar Patch Area remedy more quickly?

RESPONSE
No. NJDEP currently has the lead for this Site and plans to design and construct the selected remedy and,
therefore, EPA does not plan to have its removal branch implement the remedy with remedial money. Furthermore,
EPA does not believe that this Site would meet the criteria for a removal action. Contamination does not
represent any acute threat to human health or the environment, and does not appear to be moving. The
sedimentation basin is in place to ensure no contamination threatens the public wellfields further downstream.

12. COMMENT
Have any TCLP tests been done yet on the material to determine how it is going to be disposed of?

RESPONSE
Appropriate tests will be done during remedial design to determine waste classification for the purpose of
disposal. Based on existing data and previous experience at the Site, it was assumed in the feasibility study
for costing purposes that excavated soil would be disposed of as TSCA regulated material.

13. COMMENT
Will any material being disposed of be used as landfill cover?

RESPONSE
It is expected that, during the classification of soil, the levels of PCBs will most likely prevent the soil from
being used as landfill cover. However, if materials qualify for beneficial re-use, then such an action could be
implemented.

Traffic Issues

14. COMMENT
A number of questions were asked regarding traffic issues during the remediation. The questions focused on what
the plan will be, hours of operation, road restoration, truck routes and the quality of trucks used during the
removal.

RESPONSE
NJDEP representatives will meet with township public safety officials after the 65% design is completed.
Information gathered at that stage would identify any travel restrictions that will be outlined in the bid
documents for the construction contract. The construction contractor will submit the final traffic plan. Trucks
used during removal actions are usually lined and covered on top. In general, hours of operation can be suitably
restricted, and other measures implemented to satisfy community requirements. Damages caused to roads due to
Site-related traffic are also assessed and repaired.

15. COMMENT
Will the truck route go over the remediated Uplands Area?

RESPONSE
Truck routes will be determined during the remedial design stage. Reasonable efforts will be made to prevent
damage to the remediated Uplands Area. If necessary, any damage will be repaired. See also RESPONSE No. 14.

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Ground Water Issues

16. COMMENT

Does the Site have contaminated ground water?

RESPONSE
The nature of the geology at the Site is such that it is a ground water discharge area where essentially ground
water from the Englishtown Aguifer migrates to the surface, thereby creating a wetland environment. The surface
water then flows into Burnt Fly Brook. The Woodbury Clay formation, which underlies the entire Site below the
Englishtown Aguifer, prevents any migration of contaminants into the Magothy Aguifer below it.
Based on our knowledge of Site conditions, EPA and NJDEP are confident that the clay is competent in providing
an impermeable barrier between Site contaminants and Magothy Aguifer. Installing wells through the clay and
potentially providing a conduit for the contaminants to enter the Magothy was not deemed necessary in the
interest of protecting human health and the environment. EPA and NJDEP believe there is no threat to ground water
users from the Site.

17. COMMENT
When the lagoons in the Uplands Area were excavated, was ground water contamination found?

RESPONSE
Some volatile organic compounds and metals were detected in the ground water in the Uplands Area at the time of
the remediation of this area. See also RESPONSE No. 16.

18. COMMENT
Is monitoring well data around the Tar Patch Area, Northerly Wetlands or Westerly Wetlands available to confirm
that there is no ground water contamination migrating off the Site?

RESPONSE
Yes. Data associated with these areas can be obtained from reports available in the repositories.

Ground water in the upper aguifer above the Woodbury Clay discharges to the surface in the Westerly Wetlands.
The surface water drains into Burnt Fly Brook. Surface water flowing into the Brook is being monitored by NJDEP
at guarterly intervals.

Monitor wells exist around the recently created sedimentation basin. The three ground water monitor wells in this
area are sampled at guarterly intervals to monitor water guality in the upper aguifer near the sedimentation
basin.

19. COMMENT
Are any monitoring wells installed on Site that you could definitely say there's no groundwater pollution from
the Site?

RESPONSE
There are three monitoring wells installed on Site which are located around the sedimentation basin. These wells
are sampled at guarterly intervals to monitor water guality in the upper aguifer near the sedimentation basin.
Based on several rounds of guarterly monitoring, the data generated thus far has not indicated any exceedances
to groundwater guality standards.

Piezometers will be used to monitor the direction of ground water flow. The installation of additional on-site
wells may be considered during the development of a monitoring program for the Westerly Wetlands. Also see
RESPONSE Nos. 17 and 18.

Burnt Fly Brook/Sedimentation Basin Issues

2 0. COMMENT
What levels of lead have been detected in the Burnt Fly Brook and what is the source of the lead?

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RESPONSE
Lead has been detected periodically in the Burnt Fly Brook at several locations downstream of the Westerly
Wetlands discharge point, as well as upstream of the Westerly Wetlands discharge (background sample locations).
Upstream sources, if any, are unknown. Lead surface water levels have been varied; however, during 1996, lead
surface water levels were typically below the New Jersey Surface Water Quality Criteria for human health of five
micrograms per liter.

21. COMMENT
How do you ensure no contamination is entering Burnt Fly Brook?

RESPONSE
Surface water and sediments in the Burnt Fly Brook are currently being monitored for lead and PCBs at guarterly
intervals at the location where surface water flow from the Site enters the Burnt Fly Brook. In addition, routine
maintenance of the sedimentation basin allows for removal of sediment buildup at the appropriate time to ensure
that the basin is working efficiently.

22. COMMENT
When the sedimentation basin fills up, like it has in the recent past, where does the water go and what happens
if it overflows?

An emergency spillway capable of handling a 500-year storm has been built as part of the sedimentation basin
construction.

23. COMMENT
There is concern that no sediment sampling was performed along the banks of the Burnt Fly Brook.

RESPONSE
An extensive investigation of the sediment in Burnt Fly Brook was conducted in 1996. Burnt Fly Brook sediments
were investigated and sampled beginning from the discharge point from the Site for a distance of approximately
1.5 miles down stream, up to the confluence with Deep Run. The only evidence of contamination in sediments was
found in a sample collected at the point at which storm flow from the Site discharges into Burnt Fly Brook. This
location was remediated as part of the remediation of the Downstream Area. In addition, a monitoring program will
be developed to monitor the Westerly Wetlands which will include additional sampling of Burnt Fly Brook.

Various other Issues

2 4. COMMENT
Concerns were expressed at the public meeting regarding how the public could be guaranteed that funding would
be present throughout the cleanup.

RESPONSE
In general, funding for projects cannot be guaranteed. Funding for the Superfund is appropriated annually by
Congress.

25. COMMENT
Concerns were voiced regarding the ecological and biological studies performed and their current value for the
decision-making process.

RESPONSE
Ecological receptors were the predominant concern in evaluating alternatives for the Westerly Wetlands. As
presented in the Feasibility Study, it has been determined that the ecological community is best served by
allowing the natural processes to mitigate future exposure to contaminated soil. The data/studies are considered
appropriate for decision making.

26. COMMENT
Is there any connection to Eagle Asphalt or Champion Chemical?

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RESPONSE
A portion of the Burnt Fly Bog Site was owned by Eagle Asphalt and operated by both Eagle Asphalt and Champion
Chemical Company as a waste oil storage area from 1952 to 1964.

27. COMMENT
What is long-term maintenance?

RESPONSE
Long-term maintenance is estimated to be 30 years for the purpose of determining a present-worth cost. However,
long-term maintenance can be increased or decreased, depending on the needs of the Site. Because contaminants
will remain on Site, the Site will be reviewed every five years in accordance with the reguirements of CERCLA.

2 8. COMMENT
What happens if NJDEP privatizes?

RESPONSE
Any privatization of NJDEP will have no effect on the remediation of the Site.

29. COMMENT
Why was the Uplands Area capped with no wetlands restoration?

RESPONSE
The Uplands Area, historically, was an upland area where artificial lagoons were constructed. It was not a
wetland area. Therefore, no wetland was created in this area.

30. COMMENT
When will actual construction work begin?

RESPONSE
Fence installation around the Westerly Wetlands will begin soon after the ROD is issued. The public procurement
process for the remainder of the remedial work reguires a design contractor to be hired through a bidding
process. Upon completion of the design, a contractor is hired for the construction phase. It is estimated that
it would take at least two years before major construction activities begin.

31. COMMENT
When will the project be bid out, and can it be done earlier so funds cannot be taken away from NJDEP?

RESPONSE
Construction funds are not released by USEPA until a design is 95% complete. A design Scope of Work is being.
prepared and the design contractor will be engaged as soon as funds for this purpose are obtained soon after the
issuance of the ROD. The design contractor will be selected through open competitive bidding. This takes
approximately six months. Upon completion of the design, which should take approximately nine months to complete,
a construction contract will be bid out.

32. COMMENT
When will the design be complete?

RESPONSE
It is anticipated that the design work will be completed in the year 2000.

Part II: Summary and responses to written concerns received during the public comment period

Comments submitted by Blasland, Bouck & Lee on behalf of certain Potentially Responsible Parties:

1. COMMENT
The assumption of unrestricted (residential) future use for the Site when determining cleanup levels is
unreasonable.

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RESPONSE
The Public Health Evaluation for the Supplemental Feasibility Study of Burnt Fly Bog Site considered the
anticipated future land uses for the Westerly Wetlands, Tar Patch, and Northerly Wetlands. Since the Westerly
Wetlands is an isolated wilderness area, it was assumed for the purposes of the Public Health Evaluation that
the Westerly Wetlands would remain an undeveloped wetland area for the foreseeable future. The Northerly
Wetlands, conversely, is a small track of Palustrine Forested Broad Leaved Deciduous wetland that is partially
surrounded by upland areas. The Northerly Wetlands and Tar Patch Area are within several hundred feet of a
residential area. Because of the close proximity to human receptors and the uncertainty of the future use of this
area, the cancer risk for exposure to Northerly Wetlands soil and Tar Patch Area soil containing PCBs
was evaluated for current adult trespassers and hypothetical future residents. Since the cancer risk was
estimated to be 7.5 x 10 -3, well outside EPA's acceptable risk range, the application of the most conservative
soil cleanup criteria for the Northerly Wetlands soil was determined to be appropriate.

The volume of contaminated soil in the Northerly Wetlands above ecological risk based cleanup numbers is only
150 cubic yards less than that based on human health risk based numbers. Limits for the Tar Patch Area cleanup
will be based on visual contamination.

2. COMMENT
The cleanup levels for PCBs and lead should reflect important new data and recognize certain factors not
considered during remedy selection.

RESPONSE
With respect to PCBs, NJDEP is currently using a health based soil cleanup criteria based on an A-280 developed
slope factor of 1.4 (mg/kg-day) -1 and a 10 -6 risk level, resulting in a residential direct contact soil cleanup
criteria of 0.49 mg/kg. While USEPA has conducted a reassessment of cancer dose-response based on PCB mixtures,
NJDEP is in the process of re-evaluating cleanup/screening criteria for PCBs for possible future changes in PCB
soil cleanup criteria. In this interim period, NJDEP is maintaining its health based cleanup criteria for PCBs.
The USEPA residential direct contact soil cleanup criteria for PCBs is 1 mg/kg. The PCB numbers in effect when
the ROD is signed will be used as the cleanup criteria. In accordance with New Jersey State law, cleanup criteria
for carcinogens are based on a 10 -6 risk level. The slope factor used by
NJDEP is 1.4 (mg/kg-day) -1, which is within the newly approved USEPA range of 0.4 to 2.0 (mg/kg-day) -1.

With respect to NJDEP's 400 mg/kg cleanup level for lead, the USEPA Integrated Exposure Uptake Biokinetic (IEUBK)
model is appropriate for establishing the cleanup level for the Northerly Wetlands since NJDEP has determined
that a future residential scenerio and the application of the most conservative soil cleanup criteria is
appropriate for the Northerly Wetlands.

3. COMMENT
The preferred remedy for the Tar Patch Area and Northerly Wetlands is excessively costly. Remedial Action
Objectives can be achieved by choosing a suitable 'Limited Action' alternative for these areas, similar to the
preferred remedy for the Westerly Wetlands.

RESPONSE
EPA and NJDEP believe that the selected remedy provides the best balance of tradeoffs with respect to the nine
evaluation criteria. The Tar Patch Area is located adjacent to, and upstream of, the Westerly Wetlands. A major
portion of this area, approximately 4 acres in extent, is denuded. No wetland vegetation currently exists in this
area. Visibly contaminated soil exhibiting tarry patches can be seen on the surface. The Tar Patch Area is
continuing to act as a source of contamination for other downstream areas, including Westerly Wetlands and Burnt
Fly Brook. Erosion of this non-vegetated area occurs during storm events. On the other hand, the Westerly
Wetlands is a recovering wetland area covering an area of approximately 21 acres, with conditions favorable for
vegetative humification and sediment build-up.

Source removal from the Tar Patch Area has been recommended by choosing excavation and off-site removal of
contaminated soil as the preferred remedy for this part of the Site. However, removal of contaminated soil will
be restricted to the barren areas only. Once the contaminated soil is removed, wetlands will be established in
the excavated areas, which will result in the formation of contiguous wetlands from the Westerly Wetlands to the
Northerly Wetlands.

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The contaminated Northerly Wetlands area is approximately 2.5 acres in extent. It is located upstream of the Tar
patch Area. Unlike in the Westerly Wetlands, there are mature trees within most of the Northerly Wetlands area.
Therefore, the rate of vegetative humification is expected to be less in the Northerly Wetlands when compared
to the scrub/shrub wetland areas within the Westerly Wetlands. Contaminated sediment and soil can continue to
migrate into the remediated Tar Patch Area during storm events. Hence, the preferred remedy for the Northerly
Wetlands is excavation and removal of approximately 4,000 cubic yards of contaminated soil, and restoration of
wetlands in the excavated areas.

The Burnt Fly Bog ecosystem that encompasses approximately 1700 acres in Monmouth County, New Jersey represents
a unigue and valuable natural resource. The discharge of hazardous substances to this ecosystem, which has been
extensively investigated and characterized as the Burnt Fly Bog Superfund Site, represents a truly significant
natural resource injury. The duration of this injury began with the initial discharges to this system, and
continues today with significant concentrations of hazardous substances remaining within the system. As discussed
above, large areas of the Site are still devoid of natural vegetation, and large areas of the system are still
not fully functional wetlands despite the beginning of natural revegetative processes in other areas. In addition
to ensuring the overall protection of human health and the environment, NJDEP and
USEPA are also tasked with restoring and enhancing the natural resources of the State of New Jersey for the
public welfare. Accordingly, the Department is obligated to make every effort to minimize the duration of
identified natural resource injuries and restore these valuable resources of the State whenever restoration is
reasonable, effective, and practicable. Both NJDEP and the USEPA strongly believe that the preferred remedy
which actively remediates the Tar Patch Area and Northerly Wetlands will begin to restore some of the continuing
natural resource injury to the ecosystem in an effective and efficient manner. The Tar Patch Area is devoid of
native vegetation and represents a significant area of the Bog system that remains dysfunctional and unable to
revegetate naturally, apparently due to such high concentrations of contaminants. Thus, it is logical to actively
restore this portion of the Bog resource to a more natural condition and use. It is likewise logical and
appropriate to actively restore the Northerly Wetlands area since this upstream area would represent ;
significant continuing source of recontamination to the immediately adjacent, downstream Tar Patch Area.

Comments submitted by the Monmouth County Environmental Coalition:

4. COMMENT
The limits of excavation within the Tar Patch Area for remedial purposes must be extended into the Westerly
Wetlands to include all areas directly down-gradient of the Tar Patch Area.

RESPONSE
The limits of excavation for the Tar Patch Area will be based on visible contamination and obviously stressed
areas. The visual goal was chosen because the targeted area is clearly defined due to the lack of vegetation in
the area. If an exact number were specified for the cleanup of this area, it would include vegetated portions
of the Westerly Wetlands area as well. The targeted area is approximately 4 acres in extent, and is not capable
of natural re-vegetation as are the other contaminated areas. Existing wetlands surrounding this core area will
not be excavated as part of the remedial activities. Any areas, including wetland areas, disturbed during
construction activities will be restored as part of the remedial operations.

5. COMMENT
Removal of 'Hot Spots' within the Westerly Wetlands must also be included in the preferred remedy for this part
of the BFB Site.

RESPONSE
After careful evaluation and investigation of the wetland areas downstream and surrounding the Tar Patch Area,
both agencies determined that Hot Spot Removal within the Westerly Wetlands is not appropriate. It is evident
from historic data that high levels of contamination extend throughout the Westerly Wetlands, and that accessing
and excavating any or all of these higher contamination areas would reguire destruction of large areas of high
guality wetland habitat.

Sediment samples were taken in the Westerly Wetlands during remedial investigations performed in 1985 on thirteen
transects identified as T-l through T-13. Based on the sampling data, high concentrations of lead and PCBs in
the sediment were found generally along the entire reach of the Westerly Wetlands, in the middle portions of

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these transects. Extensive sediment sampling was again performed in the Westerly Wetlands in!996 to confirm the
extent of the contamination and current levels of contamination at locations where high concentrations were
encountered in 1985.

While hot spot removal was considered as a remedial alternative during Phase I of the Supplemental Feasibility
Study, closer examination of the 1985 and 1996 data revealed that the higher contaminated sediments were not
restricted to small, easily accessible areas close to the barren Tar Patch Area. Rather, the higher contaminated
sediments were distributed along the entire reach of the Westerly Wetlands, and no decreasing
concentration gradient in a down-gradient direction beginning from the Uplands Area was observed. In view of the
above observations, it was concluded during Phase II of the Supplemental Feasibility Study that the Hot Spot
Removal alternative was inappropriate for the Westerly Wetlands. Furthermore, any excavation of sediment from
selected areas within the Westerly Wetlands will result in the loss of large areas of thriving wetlands,
because large extents of uncontaminated wetland areas will be reguired to be destroyed or filled to provide
access for construction eguipment.
Data and other information pertaining to this evaluation can be found in the following reports, which form part
of the Administrative Record for this Site:

Westerly Wetland Remedial Investigation Final Report, Burnt Fly Bog Site - January 1988.

Westerly Wetlands Field Sampling Report, Burnt Fly Bog Superfund Site, Supplemental Feasibility Study - September
1997.

Final Field Sampling and Testing Results Report - Tar Patch Area - May 1994.

Northerly Wetlands Field Sampling Report, Burnt Fly Bog Superfund Site Supplemental Feasibility Study - January
1997.

Final Supplemental Feasibility Study Report for Burnt Fly Bog Site - October 1997.

6. COMMENT
Extensive monitoring of soil and surface water must be conducted in the Westerly Wetlands, Sedimentation Basin,
and Burnt Fly Brook as part of the cleanup operation.

RESPONSE
Periodic monitoring of the Burnt Fly Bog Site will include biological sampling, surface water and soil sampling
in the Westerly Wetlands, surface water, sediment and, if necessary, biological sampling in Burnt Fly Brook, and
surface water and sediment sampling within the sedimentation basin. Specific sampling protocol, analytical
parameters, and sampling freguency will be provided in a Field Sampling and Monitoring Plan which will be
prepared as a component of the remedial action for the Site. In addition and as reguired by CERCLA, for remedial
actions that result in hazardous substances remaining on-site above levels that allow for unrestricted use,
review of the selected remedy will be conducted no less than every five years after initiation of the selected
remedy.

7. COMMENT
It has been stated that lead was detected at the upstream background sample location in Burnt Fly Brook. Is there
any runoff from previously unknown area(s) of BFB discharging into Burnt fly Brook upstream of the existing point
of discharge near the sedimentation basin?

RESPONSE
The sedimentation basin was designed, and constructed in 1996, to fully capture storm runoff originating from
within the BFB Superfund Site. Limits of the contaminated areas within the Site, and hence the overall limits
of the Site, were established through extensive soil sampling conducted in the 1980's and later in 1994, and
1995. Therefore, any low level lead contamination that is detected at the upstream sampling location during the
on-going surface water and sediment sampling in Burnt Fly Brook must originate from other non-point sources in
the upper reaches of the Brook. Lead levels in sediment at the upstream location range from 4.6 mg/kg to 20.5
mg/kg indicating background/ambient conditions.

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Over the past  18  months of operation,  regular inspections  by NJDEP personnel  indicate that  the basin is
functioning as intended. There  is no evidence that Site-related contaminants are bypassing the basin or migrating
off-site by other  means.

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                                      ROD FACT SHEET
SITE
Name
Location/State
EPA Region
HRS Score  (date)
Site ID #
                           Burnt Fly Bog
                           Marlboro Township, New Jersey
                           II
                           40  (10/81)
                           NJD 98050 4997
ROD
Date Signed:
Remedies:
Operating Unit Number:
Capital cost:
Construction Completion:
0 & M in 1999:      $ 9,
         2000:      $ 9,
         2001:
Present worth:
Discount rate:
                        200
                        200
September 30, 1998
Excavation of contaminated soil/sediment
in Tar Patch and Northerly Wetlands Areas;
Limited action and institutional controls
in Westerly Wetlands
      OU-3
      $ 16,624,400
      12/2001
        (1999 dollars)
                    $ 9,200
                                 $    136,000  (30 years)
                                 $  2,608,000  (7 years)
                                 $ 13,975,000  (7 years)
                                 $ 16,719,000
                                 5 %
LEAD
Remedial/Enforcement:
EPA/State/PRP:
Primary contact  (phone):
Secondary contact    (phone)
Main PRP(s):

PRP Contact  (phone):
                                   Remedial  (fund)
                                   State
                                   Anton Navarajah     (609) 777-0340
                                      Thomas Porucznik   (212)  637-4370
                                   Dominick and Carmelo Manzo,
                                   Ace-Manzo, Inc.
                                   N/A
WASTE
Type:
Medium:
Origin:

Est. guantity:
                                   PCBs, Lead
                                   Soil, sediment, surface water
                                   Unlined lagoons filled with
                                                       recycled oil
                                   33,600 cu. yds.

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