PB98-963805
EPA 541-R98-053
October 1998
EPA Superfund
Record of Decision:
Asbestos Dump OU 3
Millington, NJ
9/8/1998

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U.S. Fish and Wildlife Service

RECORD OF DECISION
for
Operable Unit 3
of the
Asbestos Dump Superfund Site
Great Swamp National Wildlife Refuge
Morris County, New Jersey
FOSTER © WHEELER
FOSTER WHEELER ENVIRONMENTAL CORPORATION
S E A Consultants Inc.
Industrial Economics Inc.
USFWS Contract No. 14-48 0010-93-004

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RECORD OF DECISION
for
Operable Unit 3
of the
Asbestos Dump Superfund Site
Great Swamp National Wildlife Refuge
Morris County, New Jersey
September 1998
Prepared for
U.S. Fish and Wildlife Service
Environmental and Facilities Compliance Branch
12795 W. Alameda Parkway, Suite 215
P.O. Box 25287
Denver, Colorado 80225-0287
Prepared by :
SEA CONSULTANTS INC.
485 Massachusetts Avenue
Cambridge, Massachusetts 02139-4018
under contract to and in conjunction with
FOSTER © WHEELER
FOSTER WHEELER ENVIRONMENTAL CORPORATION
Foster Wheeler Environmental Corporation
143 Union Blvd., Suite 1010
Lakewood, Colorado 80228
USFWS Contract No. 14-48-0010-93-004
Task Order 95-042

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DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCA TJON
Asbestos Dump Superfund Site
Operable Unit 3
Great Swamp National Wildlife Refuge
Harding Township, Morris County, New Jersey
ST A TEMENT OF BASIS AND PURPOSE
This Record of Decision (ROD) has been prepared for Operable Unit 3 (OU-3) of the Asbestos Dump
Superfund Site, located at the Great Swamp National Wildlife Refuge (GSNWR) in Morris County,
New Jersey. The site is located within the northcentral portion of a designated Wilderness Area
along Great Brook, just east of Long Hill Road. The location of the GSNWR is shown on Figure 1
of Appendix I, and OU-3 is located on Figure 2 of Appendix I.
The Asbestos Dump Superfund Site is composed of four properties (the Millington plant [OU-1], the
New Vernon Road and White Bridge Road sites [OU-2], and the former Dietzman Tract [OU-3]),
and was added to the National Priorities List (NPL) in September 1983 (CERCLIS No.
NJD980654149). Remedial activities at OU-3 are completely independent from the activities at OU-
1 and OU-2. The United States Department of the Interior (DOI), acting through the U.S. Fish and
Wildlife Service (USFWS), is the lead agency for the remediation of OU-3, and the United States
Environmental Protection Agency (EPA) is the oversight agency. This ROD documents DOl's and
EPA's selection of the remedial action for OU-3 and has been prepared in accordance with the
requirements of the Comprehensive Environmental Response, Compensation and Liability Act of 1980,
as amended (CERCLA), 42 U.S.C. §9601 et seq. and to the extent practicable, the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP), 40 CFR Part 300. The remedial action is
intended to address the environmental risks that have been observed to exist, based on the data
summarized in the tables provided in Appendix It. An administrative record for the site, established
pursuant to the NCP, 40 CFR 300.800, contains the documents that form the basis for DOl's selection
of the remedial action. An index of the administrative record is attached as Appendix III.
This document is the third ROD for the Asbestos Dump Superfund Site. The first ROD (EPA,
September 30, 1988) addressed asbestos contamination at the Millington Site (OU-1) where the
selected remedy included the installation of a soil cover and slope stabilization. The second ROD
(EPA, September 22, 1991) selected the solidification/stabilization and capping of asbestos
contaminated soils at the New Vernon Road and White Bridge Road properties (OU-2).
The New Jersey Department of Environmental Protection (NJDEP) has been consulted on the planned
remedial action in accordance with CERCLA §121(0, 42 U.S.C. §9621(0, and it concurs with the
selected remedy (see Appendix IV). This document also provides a response to public comment of the
Proposed Plan for OU-3 (USFWS, December 1997). The Responsiveness Summary is provided in
Appendix V, which also includes responses to NJDEP comments.
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ASSESSMENT OF THE SITE
For many years, several discrete areas of OU-3 were used for the disposal of refuse collected from
neighboring communities. Along with refuse, asbestos containing material (ACM) and other
industrial wastes from the former National Gypsum Company (NGC) Plant in Millington, and
possibly other sources, were trucked to the site and landfilled. The disposal of ACM at OU-3 began
in the early 1960s and continued until 1968 when the USFWS acquired the property.
OU-3 consists of three contiguous ACM disposal areas, including:
•	Site A (a 5-acre ACM dump);
•	Site B (a half-acre dump consisting of refuse covered with ACM);
•	An unimproved access road (UAR), surfaced with ACM, leading to Sites A and B;
and three small refuse areas (RAs) adjoining Site B, including:
•	RA #1;
•	RA #3; and
•	RA #6
As part of a non-emergency removal action, 207 buried drums, of which 69 contained hazardous and
solid waste products, were removed from Site A in September 1997 (IT Corporation, December
1997). There is no evidence to suggest that a substantial release of contaminants occurred from
these drums. Analytical results from past surface water, groundwater and soil samples located in the
vicinity of the drum removal action have reported detectable concentrations of hazardous substances
in these media, some of which were subsequently identified as components of drum contents (e.g.
mercury, trichloroethene (TCE), and methylene chloride). During the drum removal action,
however, potentially impacted soils were stockpiled for characterization prior to disposal. In
addition, the soil from the excavation pits was sampled to document closure conditions. Post
excavation sampling indicated that the remaining contaminant concentrations in soil were below
NJDEP soil clean-up criteria and other to be considered (TBC) criteria and applicable or relevant
and appropriate requirements (ARARs). The stockpiled soil was also demonstrated to be below
applicable clean-up standards (IT Corporation, 1997). The minimal concentrations of detected
contaminants suggest only minor releases of volatile organics and metals from these drums over
time.
A baseline risk assessment performed for the site (Foster Wheeler, May 1997) has determined lead
to be the only contaminant of risk to human health, whereas several metals (barium, cadmium,
chromium, lead, mercury, thallium, vanadium, and zinc) were determined to pose the greatest risk to
ecological receptors, such as certain species of wildlife. Extensive environmental testing performed
on shallow groundwater, surface water, sediment, soils and biota indicates that the metals are
contained in soil and ACM, and are not leachable at levels above regulatory criteria used to classify
the tested material as a hazardous waste or transferable to other environmental media. Therefore, the
route of exposure to the limited contaminants of risk is through direct contact with soils or
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sediments.
In addition, the baseline risk assessment performed for OU-3 did not identify asbestos as a
contaminant of concern (COC) under existing conditions. However, because of the ubiquitous nature
of asbestos on the surface of the site, and potential future uses of the site, all alternatives for
remediating the site considered the presence of asbestos at the surface. The potential future route of
exposure to high-risk levels of asbestos is primarily through inhalation.
DESCRIPTION OF THE SELECTED REMEDY
The response action at OU-3 needs to address the human health and environmental threats associated
with the three contiguous disposal areas and three small refuse areas. The selection of a remedy for
OU-3 is complicated by several factors that are unique to the site. These factors, outlined in the
Feasibility Study (SEA, Junr 1997), include variable surface water levels, the objectives of the
USFWS to provide adequate environments for fish and wildlife species, the sensitivity of these fish
and wildlife species (some of which are federally protected), relatively weak and/or unstable
subsurface soils, and potential seismic (earthquake) loads from a nearby fault zone.
Based on the Feasibility Study evaluation, an independent value engineering study (Hanscomb, June
1997), and additional data collected by USFWS (Foster Wheeler, Pre-Design Data Report, September
1997), Alternative 3 was selected as the preferred remedy. The major components of the selected
remedy, including those partially or totally addressed by interim removal actions in 1997 and early
1998, include the following:
•	Removal and off-site disposal of buried drums (this work was undertaken and completed in
September 1997);
•	RemovaJ and off-site disposal of lead impacted soils (completed in Spring, 1998);
•	Consolidation (partially addressed in Spring 1998) and Capping of ACM;
•	Short-term Dewatering and Water Diversion, and Long-term Drainage Improvements
(partially conducted in Summer 1997);
•	Assessment of Wetland Impacts and Wetlands Restoration;
•	Implementation of institutional controls to ensure the continued integrity of the drainage
improvements and capping activities (e.g. limiting visitor access to daylight hours,
prohibiting other than passive uses such as bird watching, hiking and photography); and,
•	Appropriate environmental monitoring to confirm the effectiveness of the remedy (e.g.
surface water, groundwater and biota monitoring and sampling).
The selected remedial action, Alternative 3, will result in the protection of human health and the
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environment, meets statutory requirements under CERCLA, and complies with the selected ARARs.
The selected remedial action also coincides with the USFWS' desire to manage OU-3 as an integral
part of the GSNWR.
DECLARA TION OF STA TUTOR Y DETERMINA HONS
The selected remedy designated as Alternative 3 meets the requirements for remedial actions set forth
in CERCLA §121, 42 U.S.C. §9621: (1) it is protective of human health and the environment; (2) it
attains a level or standard of control of die hazardous substances, pollutants and contaminants, which at
least attains the legally applicable or relevant and appropriate requirements (ARARs) under federal and
state laws; (3) it is cost-effective; (4) it utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable, and (S) it' satisfies the statutory preference for
remedies that employ treatment to reduce the toxicity, mobility, or volume of the hazardous substances,
pollutants or contaminants at a site.
A review of the remedial action pursuant to CERCLA §121(c), 42 U.S.C. §9621(c), will be conducted
five years after the commencement of the remedial action to ensure that the remedy continues to
provide adequate protection to human health and the environment The site may also be subject to a
Deed Notice to comply with NJDEP requirements.
John Berry	/
Assistant Secretary, Policy,
ixS. Department of the Inte
.stistant Secretary, Polioy, Management & Budget
.S. Department of the Interior
Jeanne M. Fox f7 Sxs	/
Regional A^miniM^Or	if
U.S. Environmental Protection Aygency

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RECORD OF DECISION FACT SHEET
US FISH & WILDLIFE SERVICE
Site:
Site name:
Site location:
HRS score:
(for Asbestos Dump Superfiind
Site, including OU-3)
Listed on the NPL:
Operable Unit 3 Asbestos Dump Supcrfund Site
Great Swamp National Wildlife Refuge, Harding
Township, Morris County, New Jersey
39.61
September 1983
Record of Decision:
Date signed:
Selected remedy:
Estimated Construction
Completion:
Capital cost:
Annual Maintenance cost:
Present-worth cost:

X
]
Consolidation and Capping of ACM, Dewatering, Drainage
Improvements, Institutional Controls and Monitoring
December 31, 1998
Estimated $3,908,803 (in 1997 dollars)
Estimated $273,571 (NPV in 1997 dollars, 30 years assumed)
Estimated $4,182,374 (NPV in 1997 dollars, 7% annual interest rate,
30 year maintenance period assumed)
Lead Agency;
United States Fish and Wildlife Service, Environmental and Facilities Compliance Branch
Primary Contact:	Ms. Krista A. Doebbler (303)987-6807
Secondary Contact:	Mr. Billy J. Umsted (303)987-6801
Main PRP:
National Gypsum Company (liability to U.S. settled in bankruptcy
proceedings)
Waste:
Waste type:
Asbestos Containing Material (ACM) and Lead Contaminated Soil
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and Solid Waste
OlJ-3 was used as a former dump site
Approximately 36,800 cubic yards of ACM and approximately 3,800
cubic yards of additional Lead Contaminated Soil and Solid Waste
Soils
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RECORD OF DECISION
DECISION SUMMARY
Operable Unit 3 Asbestos Dump Superfund Site
Great Swamp National Wildlife Refuge
Harding Township, Morris County, New Jersey
r$9H *Vituiuv*
sncMvaoc
# & \
Department of the Interior
United States Fish and Wildlife Service
United States Environmental Protection Agency

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TABLE OF CONTENTS
page
SITE NAME, LOCATION AND DESCRIPTION	I
SITE HISTORY AND ENFORCEMENT ACTIVITIES	2
HIGHLIGHTS OF COMMUNITY PARTICIPATION	5
SCOPE AND ROLE OF OU-3 RESPONSE ACTION	6
SUMMARY OF REMOVAL ACTIONS AND INTERIM RESPONSES	7
SUMMARY OF SITE CHARACTERISTICS	8
SUMMARY OF SITE RISKS	14
REMEDIAL ACTION OBJECTIVES	19
DESCRIPTION OF REMEDIAL ALTERNATIVES	22
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES	28
SELECTED REMEDY	33
STATUTORY DETERMINATIONS	35
DOCUMENTATION OF SIGNIFICANT CHANGES	37
ATTACHMENTS
APPENDIX I.	FIGURES
APPENDIX II.	TABLES
APPENDIX III.	ADMINISTRATIVE RECORD INDEX
APPENDIX IV.	STATE LETTER OF CONCURRENCE
APPENDIX V.	RESPONSIVENESS SUMMARY
APPENDIX VI.	LIST OF ACRONYMS
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LIST OF TABLES
TABLE
1
TABLE
2
TABLE
3
TABLE
4
TABLE
5
TABLE
6
TABLE
7
TABLE
8
TABLE
9
TABLE
10
TABLE
II
TABLE
12
TABLE
13
TABLE
14
TABLE
15
Summary Of Detected Contaminants - Drum Removal Post Excavation
Sampling Results
Listing Of Detections Exceeding TBCs In Soil Samples
From Refuse Areas
Summary Of Pre-Phase II Analytical Results For Soil Samples Collected by
ESE
Summary Statistics For Analytical Detections In Phase II RI
Surface Soil Samples
Listing of Analytical Detections Exceeding TBCs in Surface Soil Samples
Summary Statistics for Analytical Detections in Phase II RI Subsurface
Soil Samples
Listing of Analytical Detections Above TBCs in Subsurface Soil Samples
Summary of Results for Mercury and l^ead Leachability Analyses of
Surface and Subsurface Soil Samples
Summary Statistics for Analytical Detections in Unfiltered Phase II RI
Groundwater Samples
Asbestos Analytical Results for Phase 11 RI Groundwater Samples
Summary Statistics for Analytical Detections in Phase II RI Sediment Samples
Summary Statistics for Analytical Detections in Phase II RI Surface Water
Samples
Human Health and Ecological Contaminants of Concern
Summary of Guidance Values and TBC Criteria Considered in Selection
of the Site Specific Cleanup Goals for Lead and Mercury
Summary of Ambient Asbestos Air Monitoring
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LIST OF FIGURES
FIGURE 1
FIGURE 2
FIGURE 3
FIGURE 4
FIGURE 5
FIGURE 6
FIGURE 7
Site Location Map
Great Swamp National Wildlife Refuge Map
OU-3 Summary She Base Map
Regional Bedrock Geology Map
Schematic Geologic Cross-Section
Potcntiomelric Surface Map
Biolic Barrier Detail
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SITE NAME, LOCA TIONAND DESCRIPTION
Operable Unit 3 of the Asbestos Dump Superfund Site (OU-3) is located on property acquired for the
Refuge and formerly owned by Nicholas Dielzman (the former Dietzman Tract), just east of Long Hill
Road in the Great Swamp National Wildlife Refuge (GSNWR) in Morris County, New Jersey. The
GSNWR, as shown in Figure 1 of Appendix I, is approximately 7,409 acres and is owned by the United
States and managed by the United States Fish and Wildlife Service (USFWS) for wildlife habitat and
recreational uses. OU-3 lies entirely within Harding Township. The location of OU-3 within GSNWR
is shown on Figure 2 of Appendix I.
The Asbestos Dump Superfund Site was added to the National Priorities List (NPL) in September 1983
(CERCLIS No. NJD980654149) and is composed of three distinct operable units. Remedial activities
at the other operable units (the Millington plant [OU-1] and the New Vernon Road and White Bridge
Road sites [OU-2]) are independent from OU-3. The remedial art Ions at OU-1 and OU-2 have been
conducted by the Environmental Protection Agency (EPA) as the lead agency. The United Slates
Department of the Interior (DOI), acting through USFWS, is the lead agency for the remediation of
OU-3, while EPA is the oversight agency.
For more than fifteen years, several discrete areas of OU-3 were used for the disposal of refuse
collected from neighboring communities. Along with refuse, asbestos containing material (ACM)
and other industrial wastes from the former National Gypsum Company (NGC) Plant in Millington
were trucked to the site for disposal. The disposal of ACM at OU-3 began in the early 1960s and
continued until 1968 when the USFWS acquired the property. The discrete areas of OU-3 are shown
on Figure 3 (Appendix I), and include:
•	Site A (a 5-acre ACM dump);
•	Site B (a half-acre dump consisting of refuse covered with ACM);
•	An unimproved access road (UAR), which leads to Sites A and B; and
•	Three small Refuse Areas (RAs) adjoining Site B.
OU-3 consists of contaminated areas located in wetlands and woodlands in the northcentral section of
the GSNWR. Site A is a 5-acre dump in which up to 70 to 80 percent of the filled material may lie
below the water table during peak surface water conditions (e.g. flood elevations). It is surrounded on
the east, south, and west by Great Brook and to the north by upland forest. Asbestos tile and siding
fragments underlain by fibrous asbestos are contained in the dump. The ACM is approximately 6 ft.
thick in the central portion of Site A, 2-4 ft. thick on the southern boundary, and 1-3 ft thick on the
northeastern boundary (Foster Wheeler/SEA, June 1997). The ground surface at Site A is also littered
with refuse, urethane foam, asbestos tile, and scrap metal. Buried drums were also formerly located at
the site (Foster Wheeler, May 1997), and were removed in September 1997 (IT Corporation, 1997).
Site B is a one-half acre dump located in the upland section of the wetland area. There is a small
palustrine wetland on the northern portion of the site, however, the site is generally not saturated. The
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dump consists of light gray to black mottled clay that is overlain by glass and metal debris and fibrous
ACM. The ACM and refuse are underlain by organic-rich clays and silty sands ranging in thickness
from a few inches to several feet. The average thickness of the asbestos material in Site D is 2 ft. and is
underlain by a 2-ft. thick layer of metal, glass and refuse, some of which contains elevated levels of
lead and other metals (Foster Wheeler/SEA, June 1997).
The UAR is basically a 1,100 foot long path that begins at Long Hill Road and progresses northeast
across OU-3 to just beyond Site D. The road averages about 17 feet in width and is surfaced with
approximately 9 inches of ACM cover (tile and siding fragments). The total area of the UAR impacted
by ACM is estimated to be about 0.4 acres (Foster Wheeler/SEA, June 1997).
The three RAs, RA #1, RA #3, and RA #6, comprise approximately 1.6 acres. RA #3 and RA #6 arc
located north of the UAR, near Site B. RA #1 is located immediately northeast of the junction
between Old Great Brook and the UAR. The areas are comprised of scattered household refuse (metal
and glass debris).
GSNWR is located within the Great Swamp Watershed and the hydrologic setting of OU-3 is complex.
Groundwater is at or near the surface most of the year. Great Brook and large wetlands around Site A
control local hydrology. The old channel of Great Brook runs between Sites A and B, but flow was
diverted in 1997 so that most water flows clockwise around Site A, through New Great Brook or
through a new channel extending south-southwest from upstream of OU-3, and into the upper reaches
of the impounded waters of Waterfowl Management Pool #1. The horizontal flow gradient across
much of the site is low and the water table nearly flat. Therefore, groundwater flow in the shallow
aquifer across OU-3 appears to discharge to Old and New Great Brooks.
In addition to the estimated 185,000 annual visitors to GSNWR, there arc 440 residents within a one
mile radius of OU-3. However, most of these residents are upwind and hydraulically upgradient of
OU-3. The Wilderness Area, approximately 3,660 acres, where OU-3 is located serves as an outdoor
laboratory: more than eight (8) miles of hiking trails are available to the public for recreational
purposes. The remaining 3,749 acres are designated as a Management Area where various practices
are implemented to sustain and enhance habitat.
The refuge trails, boardwalks, and observation facilities are open to visitors, however, they are only
permitted in designated areas and only during daylight hours. Trails are open to foot traffic only.
Camping or collecting, disturbing, or destroying plants or animals is strictly forbidden by USFWS.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
Regarding site ownership, OU-3 and the surrounding area (about 104 acres) was entitled to Nicholas
Dietzman in 1918. In 1967, Mr. Dietzman sold approximately 35 acres to USFWS, and the remaining
portions of the tract were sold to USFWS the following year.
During the 1950s and 1960s, ACM, household waste, and industrial waste materials originating from
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the NGC plant in Millington, New Jersey, and possibly other sources, were deposited at the Asbestos
Dump Superfund Site. In addition, several refuse areas on OU-3 discussed above, had also been used
to dispose of refuse collected from neighboring communities.
The Asbestos Dump Site was included on the National Priorities List (NPL) on September 8, 1983. In
September 1984, the U.S. EPA issued a notice letter to NGC notifying the company of its liability as a
Potentially Responsible Party (PRP) and offering it an opportunity to conduct a Remedial Investigation
and Feasibility Study (RI/FS). On April I, 1985, EPA issued an Administrative Order to NGC to
conduct the RI/FS for all of the sites comprising the Asbestos Dump Site. The Ri was performed in
1985 and 1986 and a report was submitted to EPA by NGC in May 1987 (Hart, 1987).
EPA determined that the RI failed to adequately characterize the nature and extent of contamination at
two of the three operable units, including OU-3. On October 28, 1990, NGC filed a voluntary
bankruptcy petition under Chapter 11.
OU-3 has been the focus of several additional investigations. A brief listing of the previous studies and
reports on OU-3 is appended to the Proposed Plan (USFWS, December 1997), as Attachment A. Pre-
1996 analytical data were summarized and data needs were identified in the Phase II Remedial
Investigation Work Plan (Foster Wheeler, July 1996). Separate from OU-3, five Areas Of Concern
(AOCs, and subsequently referred to as Limited Action Areas or "LAAs") located in Long Hill
Township were investigated as part of the Phase II Rl. The LAAs are not part of OU-3, but are being
addressed as part of DOI's response actions related to the Asbestos Dump Superfund Site. These five
LAAs included the Old Farm Road, Site #5, Site #7, the former McDonough Property and the Conroy
Property. OU-3 and the Old Farm Road are located within the Wilderness Area, and the four
remaining LAAs are in the active management area of GSNWR.
During the Spring and Summer of 1996, the Phase II RI was conducted to fill data needs, assess risks to
human health and the environment, and provide the necessary data for preliminary identification of
remedial alternatives for OU-3, The Final Phase II RI Report (Foster Wheeler, May 1997) summarized
the results of field investigations conducted at OU-3, and included a baseline risk assessment. OU-3
was found to contain about 36,800 cubic yards of ACM, 3,800 cubic yards of refuse debris, an
estimated 207 buried drums at Site A, and areas of metal-impacted soil and ACM.
In September 1996, USFWS prepared an Action Memorandum for the Removal of ACM in four of the
LAAs. The Kansas City District Army Corps of Engineers (COE) prepared a Design Analysis and
issued a Contract to implement the ACM removal to address potential immediate threats to human
health and the environment The work included excavation and off-site removal actions and was
conducted by the COE in the Fall of 1996. For two of the sites, the Conroy and former McDonough
properties, the removal effectively addressed about 95 percent of the delineated ACM. The remaining
ACM was covered and the area revegetated. No further action will be needed at these two sites. For
Sites #5 and #7, surficia! ACM was also removed. However, some surface and subsurface ACM with
no immediate direct potential human exposure was left in place. USFWS will address subsurface and
surface ACM at Sites #5 and #7 and the Old Farm Road site in activities separate from the remedial
action for OU-3. Close-out documentation for these LAA removal actions will be provided upon
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completion.
In June 1997, IJSFWS completed a Feasibility Study (FS) Report (SF.A, 1997). The FS Report
outlined general response actions that would satisfy the remedial action objectives for the site and
recommended a remedial action, taking into account:
•	The contaminants of concern;
•	All media of concern;
•	All sources of concern;
•	Exposure routes and potential receptors;
•	Acceptable contaminant levels, ranges, or goals for each exposure route;
•	Applicable or Relevant and Appropriate Requirements (ARARs); and
•	Community Acceptance.
In June 1997, the USFWS commissioned an independent value engineering study of the FS Report
(Hanscomb, 1997). The value engineering study generally validated the findings, conclusions and
recommendations of the FS. The major components of the recommended remedial action included the
following:
•	Removal of the buried drums (completed in September, 1997);
•	Consolidation (underway Spring, 1998) and Capping of ACM;
•	Removal and off-site disposal of lead impacted soils (completed Spring, 1998);
•	Short-term Dewatering and Water Diversion, and Long-term Drainage Improvements
(partially conducted during Summer, 1997);
•	Appropriate environmental monitoring to confirm the effectiveness of the remedy (e.g.
surface water, groundwater and biota monitoring and sampling);
•	Implementation of institutional controls to ensure the continued integrity of the drainage
and capping activities (e.g. limiting visitor access to daylight hours, prohibiting other than
passive uses such as bird watching, hiking, and photography); and
•	Assessment of Wetland Impacts and Wetlands Restoration.
The FS and value engineering studies also recommended the collection of additional pre-design data to
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reduce uncertainty and confirm certain assumptions. The additional data was collected in the spring
and summer of 1997 (Foster Wheeler, September 1997), and the drums were removed in September of
1997 (IT Corporation, December 1997).
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The RI report, FS report and Value Engineering Report for the site were released to the public when
each report was finalized. The Proposed Plan was issued for public comment on December 12, 1997
(USFWS, 1997). These documents were made available to the public in the USFWS administrative
record file at the Refuge Liaison's office and the information repositories at the Long Hill Township
Free Public Library, 91 Central Avenue, Stirling, New Jersey and the Harding Township Kirby
Municipal Building, Town Clerk's Office, Blue Mill Road, New Vernon, New Jersey. The notice of
availability for the above-referenced documents was published in the Echoes-Sentinel and Newark
Star- Ledger on December 10, 1997 and in the Chatham Courier, Daily Record and Observer-Tribune
on December 11, 1997. The public comment period on these documents was held from December 12,
1997 to January 16, 1998 and extended upon request to February 27, 1998.
Throughout the Asbestos Dump Superfund Site's history, community concern and involvement have
been high. For OU-3, frequent informal meetings were the preferred method of information
distribution requested by the public during early community relations scoping interviews.
Consequently, USFWS hosted three Community Information Open House forums to which it invited
all interested citizens and representatives of village and county agencies. Guests were allowed to
participate in informal discussions, presentations, and question-and-answer sessions. Many of the
public's concerns and questions have been directly addressed during the planning, investigation,
reporting and feasibility phases of the project. Nine fact sheets have been distributed to a mailing list
of over 150 interested parties. Periodic briefings have been held for several elected officials and a
USFWS liaison position and telephone hotline was staffed to facilitate information transfers.
On December 17, 1997, USFWS conducted a public meeting as required by CERCLA at Greenwood
Village Fire Station, 529 Green Village Road, Green Village, NJ to inform local officials and interested
citizens about the Superfund process, to present the proposed remedy, review past removal activities at
the site, and to respond to any questions regarding OU-3 from area residents and other attendees.
A Technical Assistance Grant was awarded by EPA to a stakeholder group on approximately February
16, 1998. The Great Swamp Watershed Association will be able to use this grant to assist its
participation in reviewing response actions for all operable units of the Asbestos Dump Superfund Site,
including OU-3.
Responses to the comments received at the public meeting and in writing during the public comment
period are included in the Responsiveness Summary (see Appendix V). USFWS plans to continue
public involvement and community participation throughout the design and construction phases of the
selected remedy.
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SCOPE AND ROLE OF OU-3 RESPONSE ACTION
The major components of the selected remedial action are consistent with the remedy as evaluated in
the FS and validated by the value engineering study. The remedy will include:
•	Removal of the buried drums from Site A (completed in September 1997) including post-
excavation and waste classification sampling;
•	Consolidation of ACM from Site B and UAR onto Site A (completed Spring, 1998);
•	Covering of ACM at Site A with a biotic barrier;
•	Removal and off-site disposal of lead impacted soil from Site B and RAs (completed
Spring, 1998) including post-excavation sampling;
•	Short-term Dewatering and Water Diversion, and Long-term Drainage Improvements
(partially completed during Summer 1997);
•	Appropriate environmental monitoring to confirm the effectiveness of the remedy (e.g.
surface water, groundwater and biota monitoring and sampling);
•	Implementation of institutional controls to ensure the continued integrity of the drainage
and capping activities (e.g. limiting visitor access to daylight hours, prohibiting other than
passive uses such as hiking, bird watching and photography); and,
•	Assessment of wetland impacts and wetland restoration.
The remedy addresses ACM, metal contaminated soils and reduces the potential for contaminated
groundwater due to the buried drums. Lead contaminated soil and debris (greater than 218 mg/kg of
lead) at Site B and RA#1 and RA#6 have been excavated and disposed ofT-site. Additional sampling to
determine the distribution and concentration of mercury contamination in soils at Site A was conducted
to determine if "hot spots" existed which merited the removal and disposal of such soils as hazardous
waste. "Hot spots" were considered to be areas of elevated mercury in soil or waste where the mercury
was found to be lcnchable at levels above the RCRA toxicity characteristic leaching procedure (TCLP)
criteria (0.2 mg/L) or where it might exist at concentrations above the RCRA universal treatment
standards (UTS) (260 mg/kg) (40 CFR 268.40 Subpart D Treatment Standards). Based on the results of
all sampling, no areas of elevated mercury meeting this "hot spot" designation were found.
Risks posed by metals in Site A and ACM on site are being addressed through consolidation of Site B
and UAR ACM onto Site A and capping of the ACM through installation of a "biotic barrier". The
biotic barrier is a multi-layered cap with a protective biotic barrier layer to prevent burrowing animals
from penetrating the cap, and a vegetative layer to support vegetation and prevent erosion. Temporary
dewatering to facilitate biotic barrier construction, water diversion and drainage improvements to
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ensure long-term integrity of the containment measure, and institutional controls are other components
of the final remedy. The conditions at these areas pose a threat to human health and the environment
and required. response actions are due to risks from direct ingestion (metal contaminated soils),
inhalation of asbestos fibers, and uptake of metals by ecological receptors.
SUMMARY OF REMOVAL ACTIONS AND INTERIM RESPONSES
Following completion of the OU-3 FS and value engineering phases, several interim response
actions and removal actions were identified as candidates for early implementation as risk reduction
activities. These actions are consistent with the NCP and EPA guidance which "emphasizes a bias
for actions which eliminate, reduce, or control site hazards as early as possible" (EPA 1990 -
Guidance on Expediting Remedial Design and Remedial Action, EPA/540/G-90/006, OSWER
Directive 9355.5-02, August 1990). In addition, all of the activities conducted so far were
determined to be common components of several of the evaluated alternatives, and therefore would
be implemented at some point in any one of these candidate remedial alternatives which includes the
selected alternative. It was determined that each of these actions will help achieve compliance with
ARARs or help to meet remedial action objectives for the site.
Interim responses included improving site access and making drainage improvements. These were
conducted as necessary precursory steps for the two removal actions conducted at OU-3. Specific
interim response actions taken include the following:
•	Two immediate response actions were performed to improve Site A access and to
temporarily lower surface water and enhance passive site drainage. Access to Site A was
improved by upgrading the surface of the UAR and clearing dense vegetation covering
Site A. The site drainage was enhanced by clearing the channel constriction and
blockage where the UAR crosses the Old Great Brook Channel northwest of Site A and
placing a culvert system in the channel to maintain vehicle access to Site B. These
activities were conducted between July 29 and August 1, 1997 (IT Corporation, 1997).
•	Interim drainage improvements were made by constructing a by-pass channel to divert
Great Brook surface water flow away from Site A toward Pool #1 at a point upstream
from Site A and removing channel blockages downstream of Site A in the New Great
Brook channel leading into Pool #1 near Long Hill Road. This was accomplished in
early to mid-July 1997 by USFWS personnel using a specialized aquatic excavator unit.
Two Removal Actions were identified which addressed potential sources and contaminants of
concern which were considered to pose higher levels of risk relative to other conditions at OU-3.
Specific actions which have been taken or are underway at OU-3 include:
•	Drum excavation, removal, and off-site waste disposal at Site A was initiated and
completed in September, 1997 (IT Corporation, 1997). The source control measure
included excavation of 207 buried drums, and was undertaken as a non-emergency, time-
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critical removal action to eliminate continued or future leaching of drum contents to
groundwater. Sixty-nine of the 207 drums contained product and were characterized for
disposal. 50 of these drums were subsequently designated hazardous waste and disposed
off-site at permitted facilities. Post-excavation soil samples were collected from the
excavations, or the excavator bucket when the excavation was greater than four feel in
depth. Analytical results from these grab samples indicated results below ARARs and To
Be Considered (TBC) criteria, confirming that contaminants in drums had not been
released above regulatory standards before or during removal and indicating that
contamination of shallow groundwater is not a future concern (IT Corporation, 1997).
TBC's include criteria, advisories, guidelines or proposed standards developed by federal
or state programs that may provide useful information or recommended procedures if no
ARARs address a particular situation, or if existing ARARs do not provide the desired
protection. These standards were addressed as part of the evaluation of sampling results. A
summary of post-excavation sampling results is provided in Table 1 (Appendix II).
• Excavation, removal, and off-site disposal of lead-contaminatcd soils and debris
(concentrations greater than 218 mg/kg lead) at Site B, RA#6, and RA#l was initiated in
February, 1998 and was completed in Spring 1998 (USFWS 1998). This latter action
also includes the consolidation of ACM from Site B onto Site A for future covering
under the Site A biotic cap described in the selected remedy. This step was required
because the friable ACM at Site B needed to be removed to gain access to the debris
layer demonstrating elevated lead concentrations.
In addition to the interim responses and removal actions taken in 1997 and 1998 at OU-3, a removal
action was completed in the fall of 1996 which addressed surficial ACM at four LAAs not
considered part of OU-3 - the Conroy Property, the former McDonough Property, Site #7 and Site
#5 (USFWS, 1996 - Action Memorandum, COE 1996 - Design Analysis and Scope of Work, and
COE - New York District 1997 Closc-Out Documents for ACM Removal at LAAs). These four
LAAs, which lie in the Long Hill Township portion of Great Swamp NWR, were previously
designated AOCs and further classified as LAAs in the OU-3 Rl/FS Work Plans (Foster Wheeler
1996). A supplemental interim removal action is being initiated during the Spring of 1998 at Sites #5
and #7 to address residual surficial ACM. This removal action coincides with the mobilization for
the OU-3 removal action addressing the lead-contaminated soil at Site B described above (USFWS
1998 - Action Memorandum).
SUMMARY OF SITE CHARACTERISTICS
Four primary sources of contamination were characterized at OU-3 during the Phase II RI. They
include ACM present throughout most of Sites A and B and the UAR; organic and inorganic waste
materials formerly present in buried drums at Site A; refuse/debris buried 2-3 feet below grade at Site B
and scattered around the periphery of the RA's with elevated levels of metals, particularly lead; and
metals, particularly mercury, contained in the ACM at Site A. The sources, concentrations and specific
location of contaminants arc discussed below.
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1.
Site Geology and Hydrogeology
Topography at OU-3 is flat, ranging from just over 235 feet to 228 feel in elevation. GSNWR is
located within the north-central Piedmont Physiographic Province and is underlain by sandstones and
shales with minor conglomerates and basalt. The northeast-trending syncline underlying GSNWR is
bounded by the tectonically active Ramapo Fault on the west and by ridges of resistant basalt forming
the Watchung Mountains to the northeast, east, and south. Present-day seismicity along the Ramapo
Fault was recently manifested in the March 10, 1979 Dernardsville Earthquake (Richter magnitude
2.4). The epicenter for the event is estimated to be 1000 to 1500 ft west of OU-3.
Unconsolidated deposits, consisting of glacial drift and glacial lake sediments, overlie bedrock at
GSNWR. The glacial lake deposits underlying OU-3 consist of low permeability, varved (laminated)
silts and ctays, and are 55-80 feet thick. The upper 5-15 feet of these sediments are swamp deposits
with a locally high organic content. Figure 4 presents a regional bedrock geology map of the GSNWR
area. Figure 5 shows a schematic geologic cross section of the GSNWR local area.
GSNWR is in Great Swamp Watershed and the hydrologic setting of OU-3 is complex. Groundwater is
at or near the surface most of the year. Great Brook and large wetlands around Site A control local
hydrology, where the shallow groundwater and surface water show a strong interaction. A second,
lower aquifer, exists in sand and gravel beneath the thick varved clay layer. The deeper aquifer serves
as a potable water source in the region. The shallow groundwater is not used as a potable source near
OU-3. The channel of Great Brook runs between Sites A and B, but historically flow had been split so
that some water flows clockwise around Site A in a new channel. This flow has been partially diverted
by water diversion elements of the interim actions described above. Site A lies in the upper reaches of
the impounded waters of Waterfowl Management Pool #1 when higher water levels are retained.
The low permeability glacial lake deposits serve as a confining layer to the underlying sand and gravel
deposits, which constitute the deep aquifer beneath GSNWR. Shallow groundwater flow in the shallow
aquifer across OU-3 appears to discharge to Great Brook. Groundwater contained within the Site A
waste mound discharges directly to the Great Brook and wetlands surrounding the site. The horizontal
flow gradient across much of the site is low and the water table nearly flat (Figure 6, Appendix I).
Although an upward gradient has been widely reported for the region, data collected during and after
the Phase II RI indicated a seasonal downward flow component at OU-3.
2. Site Soils
The upper four to six feet of material at Site A consists of ACM (variable-sized pieces of asbestos
tiles/shingles, as well as fibrous and cemented masses of ACM). Locally commingled with the ACM
waste are substantial amounts of other debris, including polyurethane foam fragments and metallic
debris, and some native soils. The upper 4-5 feet of material at Site B consists of 1-2 feet of fibrous
ACM underlain by a 1-2 foot layer of glass and metal debris. Approximately 40,600 cubic yards of
ACM and refuse debris have been delineated at OU-3. Ninety-five (95) percent occurs at Site A where
the majority of the ACM is non-friable. In contrast to Site A, the majority of ACM at Site B is friable,
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but is only 1-2 feet thick. Less than one foot of non-friable ACM covers the unimproved access road at
OU-3.
Eight drums containing Resource Conservation and Recovery' Act (RCRA)-hazardous levels of
trichloroethene (TCE), mercury and methylene chloride were excavated from Site A, removed and
properly disposed during the Phase II RI. Prior investigations also found drums with other wastes
including corrosive liquids characterized as strong acids (Hart, 1987). Due to high water conditions
during the Phase II field investigation, the full extent/number of drums could not be determined at that
time. Some excavated drums were in relatively sound condition while others were severely
deteriorated and leaking or even empty. Soil and groundwater sampling indicate these wastes
(specifically TCE and mercury and possibly methylene chloride) had been leaking into the environment
(albeit, at relatively low quantities up to that time). Using geophysical surveying techniques, additional
suspected drums were located. In September 1997, 207 drums were excavated from the site as an
interim, non-emergency removal action deemed necessary to eliminate potential impacts to
groundwater from drum contents. The drum removal activities also included site preparation,
stabilization of the UAR and installation of a reinforced gravel access road to Site A, temporary
lowering of the surface water at OU-3, short-term dewatering, excavation of the drums, and
overpacking of 69 drums of waste (including 50 recovered drums containing product and 19 drums
containing Investigation Derived Waste), backfilling of the excavations and off-site disposal of the
drummed waste and asbestos-contaminated solid waste to approved facilities (IT Corporation, 1997).
Surface soils sampled at Site A during the Phase II RI contained levels of arsenic, lead, mercury,
nickel, thallium, and vanadium which exceeded guidance levels. The Phase II RI showed that Site B
contains several metals (primarily lead) in surface soils in excess of guidance levels. This
contamination is less widespread in subsurface soils, and appears to be limited to ACM and the
underlying debris layer. Several isolated areas of elevated metals contamination (especially lead) in
surface soils adjacent to Site B are associated with RA#1, #3, and #6.
As a follow-up to the recommendations made in the FS, the Service took additional steps to delineate
the extent and potential leachability of the elevated lead found in soils at and near Site B and the
elevated mercury levels found in soils at Site A. During the pre-design data collection task, samples
were collected at Site B and RA#6 and the results used to plan the removal action completed in late
spring 1998. Also, mercury contaminated soil sampling was done on a grid over Site A to determine
overall distribution as well as to take follow-up samples from suspected areas of elevated mercury to
plan the scope and requirements of the remedial alternative for Site A. In addition, three follow-up
samples were collected from the area where ruptured drums containing mercury-contaminated wastes
(up to 318 mg/kg mercury) were removed during the Phase II RI in 1996.
When the prc-Phase II RI data (Hart 1987 and ESE 1992) and Phase II RI data (Foster Wheeler, May
1997) are combined with the pre-design data grid sampling and potential hot spot sampling (Foster
Wheeler, September 1997), there is substantial sampling density across Site A for mercury.
Furthermore, the analytical results from post-excavation samples from the 1997 drum removal can now
be considered which support the conclusion that no mercury "hot spots" (as defined in the Fate and
Transport section which follows) exist within the soils at Site A (sec Table 1) (IT Corporation, 1997)
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that would require such soils to be considered hazardous waste under RCRA.
Soils remaining on site would therefore need to be considered for direct surface exposure but would not
be considered hazardous under RCRA nor considered leachable or have a potential to impact
groundwater (not leachable under RCRA TCLP).
Summaries of the soil data collected are provided in Appendix II of the ROD. Table 1 summarizes
data from the post-excavation samples from the drum removal action. Tables 2, 3, 4, 5, 6 and 7
summarize Phase II RI soil analytical testing results. Table 8 summarizes results from analytical
testing for lcachability of metals in selected site soils (Pre-Design Data Report, Foster Wheeler, 1997).
Leachability tests using the RCRA toxicity characteristic leaching procedure show that the metals in
Site A soils do not leach at levels above RCRA hazardous waste characteristic criteria. The analytical
results, leachability tests, and additional discuss-on of the distribution and behavior of mercury at Site
A and lead at Site B is available in the "Contaminant Fate and Transport" section and in the "Summary
of Site Risks" section.
3. Groundwater
Shallow groundwater samples taken from Site A showed low level detections of contaminants
suspected to be originating from the formerly buried drums. Most of the Phase II RI groundwater
sampling results from 1996 showed good agreement with sampling conducted during the Site
Assessment (ESE 1992). There were detections of organic compounds (benzene, TCE, and alpha-
BHC) in excess of guidance levels in three Site A monitoring wells during the Phase II RI. Metals
were not a concern based on the Phase II RI results. Lead was detected in samples from seven of
fifteen monitoring wells. The maximum concentration detected (7.1 ug/L) was less than one-half the
State criteria. Mercury was detected in all six Site A monitoring wells, but none of the detections
exceeded the State criteria. Furthermore, mercury was found at lower levels in filtered samples than
unfiltered samples, which indicates that mercury present at Site A in ACM is not soluble or leachable.
Sampling in 1997 of shallow ground water taken from temporary wellpoints during a dewatering test
on the Site A ACM mound showed no detections of organic compounds, and inorganic constituents
were below regulatory levels. Supplemental sampling of shallow groundwater from Site A
monitoring wells in 1997 prior to the drum removal action showed results comparable to the 1996
Phase II RI results. The only organic contaminant above regulatory levels was alpha-BHC in one
monitoring well and metals were below guidance levels (Foster Wheeler 1997 — Pre-design Data
Report).
Unlike previous sampling, asbestos (with fibers greater than 10 microns in size) was not detected in any
of the site monitoring wells during the 1996 Phase II RI. Since several Site A monitoring wells are
screened in ACM, the lack of asbestos detections for fibers greater than 10 microns in size in Phase II
RI groundwater sampling has been attributed to use of the EPA-approved low-flow purging method.
Sampling of shallow ground water pumped from the central part of Site A during a dewatering test in
1997 showed detections of total asbestos fibers in only 2 of 5 samples collected, but both were below
EPA guidance levels. Shallow groundwater sampled from Site A monitoring wells in 1997 prior to
the drum removal action showed no detections in 3 of 5 wells sampled. For the two wells where
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fibers were detected, the results were above the 7 million fibers per liter (MFL) standard. However,
the laboratory noted excess turbidity in the samples which suggested that sampling procedures could
have unnecessarily agitated the water column in the well, thereby elevating the asbestos fiber count
(Foster Wheeler 1997 — Pre-design Data Report). These results indicate asbestos fibers arc not
migrating through the Site A ACM wastes. Tables 9 and 10 provide a summary of statistics for
analytical detections in unfiitered Phase II groundwater samples, and asbestos analytical results,
respectively.
The groundwater sampling plan was designed to assess the shallow aquifer groundwater quality only,
and at Site A specifically the monitoring wells provided samples of groundwater in direct contact with
waste. As described in the previous Site Geology and Hydrogcology section, there is a confining unit
(approximately 60 feet in depth) beneath the site. The aquifer below the confining layer is the most
prevalent source of domestic well water for the immediate vicinity. It is unlikely that contaminants
would migrate downwards because of the confining layer and seasonal artesian conditions. However,
as there are several domestic drinking water wells in the vicinity (albeit primarily upgradient or side
gradient relative to OU-3), drinking water standards were considered as ARARs.
4.	Sediment
Phase II sediment sampling results correlated well with results from the 1991/92 Site Assessment. The
only contaminants detected in sediments above ecological guidance levels involved chromium,
mercury, and nickel in sediments immediately west (downstream) of Site A. ACM tile/shingle
fragments were observed throughout much of the new Great Brook channel surrounding Site A
coinciding with the locations where the three metals were detected. Aside from the channel adjoining
Site A, contaminants were not detected above ecological screening levels in either the old or new Great
Brook Channel. Table 11 provides analytical results for sediment samples collected during the Phase II
RI.
5.	Surface Water
Only two of 13 surface water samples collected at OU-3 during the Phase II RJ exhibited detectable
lead (both below State criteria), and none revealed detectable asbestos. These findings were in contrast
to findings reported in the Site Assessment, where anomalous lead and asbestos results were reported
adjacent to and downstream from Site A (ESE, 1992). One TCE detection exceeding guidance levels
in surface water immediately adjacent to the western part of Site A was also reported. That finding
may have been indicative of minor leakage from the buried drums which were subsequently removed.
Methylene chloride was detected in most of the samples, however, this is a common laboratory
contaminant. Based on the concentrations and locations of the detections, the compound was not
believed to be a site specific contaminant.
Three inorganic analytes were detected above ARARs. Manganese was detected in 100 percent of
samples, however, these detections were believed to be reflective of naturally elevated concentrations
based on background sampling which also exceeded the ARAR by a factor of 2.5. Arsenic and
thallium were each detected in one of fourteen samples. While those concentrations exceeded ARARs,
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these analytes were not included as contaminants of concern in the risk assessment as surface water
was not a human health exposure pathway at the site and the distribution, total detections and
concentration of these analytes did not meet screening criteria as ecological contaminants of concern.
See the "Summary of Site Risks" section for additional discussion. Table 12 summarizes Phase II
surface water analytical results.
6.	Air Quality
A year-long air quality study was conducted at OU-3 in 1996. Weekly air sampling from six
monitoring stations located throughout Sites A and B detected asbestos fibers at concentrations
exceeding EPA background levels in only one out of 419 samples. That detection occurred March 28,
1996 at a station located adjacent to Site B. That detection slightly exceeded the EPA background level
for indoor air quality for school building occupancy. Further comparison to OSHA exposure standards
shows the detection below the 8-hour time-weighted average concentration. It should be noted that test
pits were excavated at both Site A and Site B during the last two weeks of June and snapping turtles
were actively nesting at Site A in early to mid-June. Both activities substantially disturbed soils at Site
A near the active air monitoring stations, yet levels were not elevated above standards. Air monitoring
conducted during the 1997 drum removal activities showed no detections at perimeter stations and only
two readings above standards within open excavations. Workers at these two excavations were fully
protected with personal protective equipment.
7.	Contaminant Fate and Transport
Concentrations of asbestos, lead, mercury, and TCE were detected in several media at OU-3, with the
potential to migrate unless the sources are eliminated or isolated. The primary sources of these
contaminants are summarized as asbestos in Site A and Site B, lead in Site B surface and subsurface
soils and in some RA#6 soils, mercury in Site A surface soils and some drums, and TCE in some Site A
drums. Based on OU-3's hydrologic setting, several primary, potential mechanisms for contaminant
transport exist (e.g. leaching of contaminants such as TCE from deteriorated drums into groundwater,
erosion of ACM or contaminated soil and suspension in surface waters, or airborne transport of
asbestos fibers or contaminated soil particulates). Phase II RI air quality monitoring and groundwater
and surface water sampling results have shown that currently, these physical transport mechanisms are
only weakly active in the pathways sampled at the site. However, the potential exists for contaminant
transport to continue or increase in the future if non-friable ACM deteriorates to a friable form. The
drum removal activity completed in September 1997 was conducted to reduce the risk for releases to
environmental media from damaged or deteriorated drums. The removal of lead-impacted soils and
debris from Site B and Refuse Areas which was completed in late Spring 1998 was conducted to
reduce the risk of direct exposure and reduce the risk of additional environmental releases.
Following the completion of the RI and FS, the distribution of mercury in soils at Site A was
characterized to further reduce some uncertainty and gather pre-design data to determine if "hot spots"
existed which merited the disposal of such soils as hazardous wastes (see discussion in Section 2 - Site
Soils). "Hot spots" were considered to be areas of elevated mercury in soil or waste where the mercury
was found to be leachable at levels above the RCRA TCLP criteria (0.2 mg/L) or where it might exist
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at concentrations above the RCRA universal treatment standard (UTS) (260 mg/kg) (40 CFR 268.40
Subpart D Treatment Standards). Based on the results of all sampling, no areas of elevated mercury
meeting this "hot spot" designation were found. Since no mercury was found above the RCRA action
levels (TCLP or UTS) which would be classified as RCRA hazardous waste, the mercury-contaminated
soil and ACM waste mound to be covered in place at the site would not be considered a RCRA
hazardous waste landfill. The only material which exceeded either criteria was the single drum of
mercury-contaminated waste (reported to contain mercury at 318 mg/kg) which was removed and
disposed of as hazardous waste during the Phase II RI (Sample SWS02101).
Most inorganic mercury compounds have low solubility and under most natural conditions, there is
little soluble inorganic mercury. The presence of low concentrations of mercury below regulatory
standards in groundwater at Site A supports this because lower concentrations were found in filtered
samples than unfiltered ones. Slightly elevated concentrations of mercury in downstream fish tissue,
however, suggests that mercury present at elevated levels in soils and possibly from drums previously
at Site A is capable of migrating into nearby environmental media because it is exposed to erosion from
the surface of Site A. Leachability tests on soil samples during the 1997 pre-design sampling indicates
elevated mercury in ACM and soils at Site A is not soluble or leachable (Foster Wheeler, 1997) (Table
8). The low levels of mercury detected in post-excavation samples during the 1997 drum removal
further supports that the mercury at Site A is not leachable.
From the perspective of migration and transport, chlorinated volatile organic compounds such as TCE
which were found at high levels in the formerly buried drummed waste in direct contact with
groundwater at Site A posed a significant potential threat to groundwater and surface water. TCE can
leach into groundwater fairly readily. The present data suggests that significant TCE releases did not
occur prior to the removal of the buried drams. Post-excavation samples (IT Corporation, 1997)
demonstrated that drums had not released significant concentrations of volatile organic compounds into
Site A soils either before or during removal (Tabic 1).
SUM MAR Y OF SITE RISKS
Based upon the results of the RI, a baseline risk assessment was conducted to estimate the risks
associated with current and future site conditions. The baseline risk assessment estimates the human
health and ecological risk which could result from the contamination at the site if no remedial action
were taken.
The baseline human health risk assessment evaluated risks associated with exposure to contaminants
from ingestion of surface soils, surface water, and groundwater, and contaminants from inhalation of
asbestos. Based on available regulatory values and guidance, only lead in OU-3 surface soils was
shown to be a final human health contaminant of concern (COC).
The ecological risk assessment evaluated risks to target species based on modeling ingestion of
contaminants and found that several metals, but primarily lead and mercury, were final COC's. The
discussion of the human and ecological health risks involved in the site are discussed below. Table 13
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summarizes the human health and ecological receptors Final COCs. Table 14 lists the guidance values
and TBC criteria that were used in the development and selection of the clean-up goals for the COCs
lead and mercury to protect both human health and ecological receptors at the site.
Human Health Risk Assessment
USFWS conducted a baseline risk assessment to evaluate the potential risks to human health and the
environment associated with the OU-3 Asbestos Dump site in its current state. The human health risk
assessment used a five-step process described below to evaluate information in assessing risk. The
Risk Assessment focused on contaminants in the surface soil, surface water, groundwater, and ambient
air which are likely to pose significant risks to human health and the environment. Of the four COCs
identified in surface soil on site (lead, beryllium, arsenic and total polycyclic aromatic hydrocarbons
(PAHs)), only lead was considered to be a final COC. The other inorganics, including mercury, were
not chosen as COCs based on both the qualitative and quantitative risk analysis described below. A
more complete discussion of this process can be found in the RI, Appendix H. There were no COCs
for human health identified in surface or groundwater.
A five-step process was utilized to assess site-related human health risk from exposure to
contaminants present at the site. The steps included: COC identification—identifies the
contaminants of concern, based on several factors including frequency of occurrence, concentration
and comparison to site background and EPA risk-based screening levels. Exposure Assessment --
estimates the type and magnitude of exposure to human populations, through characterization of the
exposure setting, determination of potentially exposed populations, identification of exposure
pathways, and estimation of exposure point concentrations. Toxicity Assessment—identifies the
chemical specific adverse health effects and the relationship between the magnitude of exposure
(dose) and adverse effect (response). Risk Characterization— summarizes the combined outputs of
the exposure and toxicity assessment to provide a quantitative assessment of site-related risks.
Uncertainty Analysis— evaluates the sources of uncertainty associated with the data, default
parameters, calculations and toxicity information used to estimate risk.
The baseline risk assessment addressed the potential risks to human health by identifying several
potential exposure pathways by which the public may be exposed to contaminant releases at the site
under current and future land-use conditions. However, given current limits to access within the
Wilderness Area, and the likelihood for the site to continue its present status as a Wilderness Area in a
wildlife refuge, there was not a significant distinction between present vs. future land use. The
pathways that represent potentially complete exposure routes for humans include ingestion of surface
soils during work-related or trespass-related activities and inhalation of contaminated soils and
particulates during wind/dust storm events. Although workers or trespassers are unlikely to consume
surface water or groundwater on site, these media were evaluated in response to strong community
concerns about this potential pathway.
For this risk assessment, the chemical detections in abiotic media were evaluated by comparison of
exposure point concentrations (i.e. the medium-specific maximum detected COC concentration) to
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target levels (MCLs, which are based on human health impacts) and EPA risk based soil screening
levels (SSLs). The EPA SSLs were used as a conservative approach to screen contaminant
concentrations in surface soil, as the default assumptions are chosen to be protective of human health
for most site conditions and assume a residential exposure scenario. Chemicals thai exceeded the
SSLs (arsenic, barium, beryllium, manganese, mercury, thallium, vanadium, total PAHs, and Aroclor
1248) were evaluated quantitatively for cancer and non-cancer risks through estimation of chemical
intakes from ingestion for three exposure populations - biological worker, and adult and child
trespassers. Inhalation exposure to mercury was also evaluated for the three exposure populations.
For the carcinogenic chemicals, arsenic, beryllium, and total PAHs produced cancer risk values
within EPA's target risk range of 10-6 to 1(H, for which cancer risks are managed, for the biological
worker only. Benzo(a) pyrene and Aroclor 1248 produced cancer risk values below 1(K
Noncarcinogenic risks for arsenic, beryllium, barium, manganese, mercury, thallium, and vanadium
produced hazard quotient values less than 1.0 for all three populations. As noted above, lead was the
only soil contaminant which was determined to be a COC. Lead concentrations in six of the 41
samples exceeded the New Jersey industrial soil cleanup level, and the arithmetic mean of the lead
concentrations was above residential cleanup levels. The exceedances were detected in soils clustered
around or adjacent to Site B. Mercury concentrations in soil produced noncancer quotient values for
both ingestion and inhalation that were well below the benchmark value of 1.0. Additionally, during
the RI field program, hundreds of measurements were taken of site soils with a portable mercury vapor
analyzer. No detections were recorded, which indicates that human exposure to volatile mercury is not
a concern at OU-3. "Hie results of the human health risk assessment were based on surface soils at the
0-2 ft. interval and a data set that had been validated, which may be a subset of the field sampling data
provided in tables found in Appendix II. Validation of data followed EPA guidelines. The information
presented in the tables is for contamination extent, and is not the database used for the risk assessment.
Ambient air sampling results are presented in Table 15. Only ten samples from the on-site sampling
stations during the Phase 11 Rl had detections of asbestos fibers, and these were generally at the
laboratory detection limit of 15.4 f/mm^ . Of the samples where asbestos was detected, only one
(March 28, 1996 at Station 7 near Site B) had fibers present at levels above the EPA background level.
Based on the available analytical results, the risk from inhalation of asbestos fibers at OU-3 is very low,
as one sample exceeded the EPA's maximum allowable asbestos level for air in school buildings. The
IRIS cancer slope factor for asbestos is based on fiber counts using the phase contrast microscopy
(PCM) methodology, which is non-specific for asbestos and will measure any fibrous material.
Transmission electron microscopy (TEM) was used at the site, because it is specific for asbestos fibers
and there was significant potential for nonspecific fiber contamination. It is inappropriate, according to
the IRIS database, to apply the cancer slope factor to measurements made by other analytical
techniques. For this reason, we used an EPA benchmark value for asbestos in school buildings. The
EPA background value or maximum allowable asbestos level at which air within school buildings is
considered clean and the building accessible was used for the evaluation of the TEM results. This is a
benchmark value, therefore it is inappropriate to assign a cancer risk associated with one sample which
had a slight exceedance of the benchmark value out of 419 samples obtained.
In summary, the estimated human health risks at OU-3 are primarily due to direct exposure to lead. The
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lead concentrations only slightly exceed the EPA residential soil cleanup level of 400 mg/kg (EPA
1994, OSWER Directive 9335.4-12). Based on Phase II RI data and considering the findings of prior
risk assessments, present conditions do not appear to pose significant risks to biological workers and
trespassers who may visit the site periodically and participate in non-intrusive activities. Were
significant physical alteration of the land to occur, it could produce conditions where risk levels
could increase. However, this is considered unlikely given the site's status as a Wilderness Area. A
more complete description of the Human Health Risk Assessment can be found in Appendix H and
Section 6.3 of the Phase II Remedial Investigation Report.
Ecological Risk Assessment
A multiple step process was utilized for assessing the potential effects of site contamination on
wildlife at OU-3. The site characterization included a wildlife survey, bcnthic and fish community
surveys, and characterization of habitats present at liie site. The Assessment and Measurement
endpoints provided evaluation of benthic invertebrate and fish community structure, mammalian and
fish body condition and a quantitative assessment of wildlife exposure concentrations.
Representative Receptors were chosen to model risk for multiple trophic levels for which complete
exposure pathways exist. Exposure Pathways identified the routes by which biological receptors
become exposed to the contaminated source media. Identification of COCs chose chemicals to be
evaluated based on frequency of detection, comparison with background concentrations, and
toxicological properties. Exposure Assessment evaluated the data by comparison to slate and federal
regulatory and to-be-considered guidance documents and evaluation of fish, frog and mammalian
tissue contaminant concentrations. The Risk Characterization evaluated the chemicals selected as
potential COCs in the exposure assessment and quantitatively evaluated risk to six representative
receptors. The Uncertainty section presents the source of uncertainty associated with the data,
toxicological literature information and calculation of risk for the chosen species.
Both qualitative and quantitative evaluations were used to measure the impact of contaminants on
wildlife found on or near the site. These evaluations included a wildlife survey, a benthic
invertebrate community analysis, fish condition and community analysis, mammalian necropsy and
histopathological analysis, wildlife tissue analyses and a quantitative risk assessment which modeled
risk to receptor species (white-footed mouse, cottontail rabbit, American Robin, red fox, great blue
heron and mink) from direct ingestion of contaminated soils alone. The surface water and
groundwater detections were compared to three benchmark values for selection of potential COCs.
None of the detections exceeded the benchmarks and therefore were not carried through to the
quantitative analysis. In addition, a site specific risk analysis from ingestion of both dietary prey
items and soil/sediment was performed for the great blue heron and mink assuming consumption of
soil/sediment using the highest detected concentrations in the fish and frog tissue samples. Lead and
mercury were considered the definitive drivers of potential risk for the site based on the elevated
Hazard Quotient values for the great blue heron and mink.
Overall, findings indicated that the potential risk to ecological receptors under conditions present at
the time of the risk assessment is limited to a few COCs found at levels above ecological screening
levels. The predominant ecological risk drivers arc lead at Site B and mercury at Site A from direct
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exposure and ingestion of soils. Barium, cadmium, copper, chromium, nickel, selenium, thallium,
vanadium, zinc and Arochlor 1248 represent lesser contributors to the estimated risk based on
modeling exposure for the representative receptors and tissue concentrations found in fish, frogs, and
mamalian species. Modeling of risk, based on the contribution from soil ingestion alone, shows that
under current conditions, some species will continue to experience some risk from metals at OU-3,
particularly at higher levels in the food web. The local wildlife communities have been impacted
and would likely continue to be adversely impacted by the site, but OU-3 does not appear to be
causing acute impairment or a widespread regional problem. Elimination of the direct exposure
pathway from contaminant sources to wildlife would significantly decrease the risks associated with
the OU-3 site. Approaches to eliminate wildlife exposure pathways are addressed under the
Remedial Action Objectives section. A more complete description of the Ecological Risk
Assessment can be found in Appendix E and Section 6.2 of the Phase II Remedial Investigation
Report.
Uncertainties in the Risk Assessment
The procedures and inputs used to assess risks in this evaluation, as in all such assessments, are
subject to a wide variety of uncertainties. It is considered sound practice to assess the type of degree
of uncertainty associated with the data and assumptions used in risk assessments. In general, the
main sources of uncertainty include:
•	environmental chemistry sampling and analysis;
•	environmental parameter measurement;
•	contaminant fate and transport modeling;
•	exposure parameter estimation; and
•	toxicological reference data.
Uncertainty in environmental sampling arises in part from the potentially uneven distribution of
chemicals in the media sampled. Consequently, there is significant uncertainty as to the actual levels
present. For this risk assessment, maximum detected concentrations were used for comparison to the
final guidance values. This approach is conservative as compared to traditional risk assessments,
where the 95% Upper Confidence Limit (UCL) on the arithmetic mean is used as the concentration
term. When statistical analysis of multiple samples is performed, the mean can be an order of
magnitude less than the maximum concentration.
Environmental chemistry-analysis error can stem from several sources including the errors inherent
in the analytical methods and characteristics of the matrix being sampled. In addition, the chemical
specific guidance values and EPA SSLs for some of the inorganic constituents were below or similar
to background levels of chemicals in soils. This approach tends to overestimate risk based on
chemical concentrations that may only slightly exceed background concentrations. Uncertainty of
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contaminant fate and transport between various media results from uncertainty regarding chemical
species and their distribution in the various media.
Uncertainties in an exposure assessment are related to estimates of exposure parameters such as how
often an individual would actually come in contact with the chemicals of concern, the period of time
over which such exposure would occur, and in the models used to estimate the concentrations of the
chemicals of concern at the point of exposure. For a biological worker, the assumption was made for
a presence at the site for 250 days per year for 25 years, which is extremely conservative when
realistic work assignments and career durations are considered. Also, the conditions and samples
collected for the risk assessment may not reflect overall the average concentrations seen in the soil
and water resources due to the high amount of precipitation in 1996. Surface water concentrations
may have been decreased due to dilution.
Because 1996 was unusually wet, the ambient air concentrations of asbestos under some of the
sampling conditions may not reflect average concentrations over several years duration. Due to the
dust suppression effect of rain, snow, and high water events as well as lusher vegetation, the risk
associated with asbestos inhalation may have been underestimated. However, follow-on air quality
sampling during drier conditions in 1997 during the drum removal action at Site A supports the
findings of the 1996 sampling events. Calculation of the potential risk from exposure to subsurface
soil contamination and the contents of buried drums could not be specifically addressed in the risk
assessment due to the lack of a documented complete exposure pathway to humans or ecological
receptors.
More specific information concerning public health risks, including a quantitative evaluation of the
degree of risk and the uncertainty analysis associated with various exposure pathways, is presented
in the Risk Assessment Report.
REMEDIAL ACTION OBJECTIVES
Remedial action objectives (RAOs) are specific goals to protect human health and the environment;
they specify the contaminant(s) of concern, the exposure route(s), receptors), and acceptable
contaminant level(s) for each exposure route. These objectives are based on available information, site
specific ARARs, TBCs, and risk-based levels established during the risk assessment and feasibility
study. RAOs include several site-specific cleanup goals which are defined as medium-specific
numerical concentrations established on an operable unit specific basis at levels considered protective
of human and ecological receptors for a specified exposure route. Protectiveness may be accomplished
by reducing exposure in the specific pathway by any of several methods or combinations of methods
called alternatives, which are summarized and evaluated in the Alternatives Analysis sections. Follow-
on interim actions and removal actions which have been completed to address risks at OU-3 and
partially or totally meet one or more RAOs arc noted in this listing.
All medium-specific and source-specific RAOs include meeting Federal and State ARARs. In
addition, the following medium-specific remedial action objectives were established:
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Groundwater
Prevent ingestion of impacted groundwater;
Restore the shallow overburden groundwater at the points of compliance (drum removal at
Site A eliminated many potential sources of organic contaminants);
Prevent the spread of contamination to unimpacted portions of the shallow overburden
aquifer (drum source removal activities have addressed this objective);
Minimize the impact to site wetlands; and
Demonstrate shallow groundwater quality through surface water and shallow aquifer
groundwater monitoring, and maintenance of related remedial actions.
Surface Water
Protect unimpacted surface water by preventing the occurrence of disposal area seeps
(drum removal has addressed the source of volatile organic compounds at the western side
of Site A);
Demonstrate that no related impacts occur in the future through monitoring of the surface
water along Great Brook and in the wetlands adjacent to disposal area Site A; and
Minimize, as practicable, the impact to site wetlands.
Sediment
•	Protect unimpacted sediment by preventing the migration of contaminants through surface
water;
•	Prevent unacceptable risks associated with impacted sediment (i.e., mercury and asbestos in
sediment around Site A).
•	Demonstrate that no related impacts occur in the future through monitoring of the sediment
along Great Brook and in the wetlands adjacent to disposal areas Site A and Site B; and
•	Minimize, to the extent practicable, the impact to the site wetlands, in accordance with
applicable requirements for the protection of wetlands, floodplains, riverways, and wildlife
species.
Air
Protect unimpacted air by preventing the migration of airborne contaminants; and

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•	Provide monitoring of air quality during remediation activities to assure that no related
• impacts occur in the future.
Soils
•	Prevent unacceptable risks associated with impacted soils by eliminating direct exposure to
humans and wildlife (e.g. excavation and removal, containment by covering or capping,
perimeter fencing, etc. are a few possible alternatives among the many available that would
eliminate or reduce direct exposure). (Note: the removal of lead impacted soils completed
in late Spring 1998 at Site B arid RAs has partially addressed this objective);
•	Prevent the spread of contamination to unimpactcd medium during and following
remediation;
•	Minimize, as practicable, the impact to site wetlands; and
•	Provide monitoring and maintenance of the related remedial actions.
In addition, the source specific objectives included the following:
•	Reduce the potential for precipitation to percolate through the debris mass;
•	Reduce the potential for groundwater and/or surface water to contact or infiltrate through
the debris mass (the surface water lowering from drainage and diversion actions has
partially addressed this objective);
•	Prevent the generation of disposal area seepage (the drum removal action at Site A has
addressed this objective);
•	Prevent direct contact with and ingestion of soils and debris within the disposal areas;
•	Control gas emissions so that explosive gases (e.g. methane) do not represent a hazard;
prevent the inhalation of gas-containing hazardous substances, pollutants, or contaminants;
•	Minimize the potential for slope failure of the disposal areas or any future action;
•	Minimize the potential for excessive settlement of the disposal areas due to any future
action or seismic occurrence;
•	Minimize the impact to site wetlands; and
•	Provide long-term monitoring and maintenance of the disposal area remedial actions to
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assure that gases and water are being properly controlled and that the remedy is functioning
properly.
DESCRIPTION OF REMEDIAL ALTERNATIVES
CERCLA §121 (b)( 1), 42 U.S.C. §9621(b)(l), mandates that a remedial action must be protective of
human health and the environment, be cost effective, and utilize permanent solutions and alternative
treatment technologies or resource recovery technologies to the maximum extent practicable. Section
121(b)(1) also establishes a preference for remedial actions which employ, as a principal element,
treatment to permanently and significantly reduce the volume, toxicity, or mobility of the hazardous
substances, pollutants and contaminants at a site. CERCLA §121(d), 42 U.S.C. §9621(d), further
specifies that a remedial action must attain a level or standard of control of the hazardous substances,
pollutants, and contaminants, which at least attains ARARs under federal and state laws, unless a
waiver can be justified pursuant to CERCLA § 121(d)(4), 42 U.S.C. §9621(d)(4).
The FS evaluation of alternatives for site remediation involved two major phases: the Development and
Screening of Alternatives, and Detailed Analysis of Alternatives. In order to address the RAOs for the
site, a wide range of technologies and process options were screened for possible use at the site. Final
technologies were selected only if they could meet the overall project objectives. Several broad
technology types or process options were identified and each was evaluated with respect to the
effectiveness, implementability and cost. For example, these technologies included the installation of
sheeting and slurry walls, solidification, thermal treatment, encapsulation, several innovative
technologies and total removal.
Many of these technologies did not pass the screening stage for various technical, cost, or
implementability reasons. One innovative technology involving a type of vitrification (thermal
treatment resulting in an asbestos-free glass) was bench tested. The technical result of the test was
promising, but the capital costs, permitting expenses and operating costs were prohibitive.
The technologies that passed the screening process were grouped together to develop six alternatives to
remediate the site. These alternatives were further evaluated against the criteria established by the NCP
and described above.
Tho FS evaluated six remedial alternatives for addressing the contamination associated with OU-3.
The remedial alternatives, as well as the associated estimated costs and implementation time frames,
are each described below. The time frames provided are approximate implementation periods and
include reasonable assumptions for planning and design. Some planning and design work takes longer
to complete, depending on the complexity of the alternative. Operation and maintenance (O&M)
periods were estimated as a present-worth cost for a 30-year period in accordance with ARARs. The
time to implement a remedial alternative reflects only the time required to construct or implement the
remedy and does not include the time required to design the remedy, negotiate with the responsible
parties, or procure contracts for design and construction, or conduct operation and maintenance at the
site. The remedial alternatives were:
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Alternative 1 - No Action:
Capital Cost:
Operation and Maintenance Cost:
Present-Worth Cost:
Implementation Time:
$95,654
$95,654
None
$0
CERCLA and the NCP require the evaluation of No Further Action as a baseline to which other
alternatives are compared. No active remediation or containment of asbestos or other site contaminants
would be performed. Monitoring of the site is planned, which explains the estimate for O&M costs
without a capital cost. That monitoring is only consistent with surface water monitoring and wildlife
management as currently practiced under standing Refuge rvianagement plans.
Alternative 2 - Institutional Controls and Monitoring:
Alternative 2 includes institutional controls along with limited O&M activities. Surface water
monitoring and wildlife management would be conducted by Refuge personnel as currently practiced.
In addition, monitoring would also include air sampling.
Current institutional controls, such as securing deed restrictions, restricting site access, and securing
land use restrictions, are in-place and would have to be maintained to conform to the intent of this
remedial alternative.
Future use of the Site would be restricted in accordance with the exposure assumptions used in the
baseline risk assessment to provide assurance there would be no inappropriate use of soils, surface
water, or groundwater at the site. Modification to the Refuge Management Plan would be needed to
document any public use or personnel use restrictions.
This alternative would require a review of the remedial action every five years pursuant to CERCLA
Section 121 ( c ), 42 U.S.C. Section 9621 ( c ), because implementing this alternative would result in
hazardous substances remaining on-site above health-based levels. Additional remedial actions could
be required depending on the results of such a review.
Alternative 2A - Drum Removal, Dewatering, Institutional Controls and Monitoring:
Capital Cost:
Operation and Maintenance Cost:
Present-Worth Cost:
Implementation Time:
$20,680
$285,049
$305,729
3 months
Capital Cost:
Operation and Maintenance Cost:
$693,909
$285,049
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l'resent-Worth Cost:
Implementation Time:
$978,958
6 months
Alternative 2A is similar to Alternative 2, with the addition of temporary dewatering and drum
removal. The same O&M activities described above would also be implemented. Long-term
monitoring of the site would include surface water and biota sampling, as is the current Refuge
management practice. Air sampling would also be initiated.
The drum removal activities completed in September 1997included site preparation, stabilization of the
Unimproved Access Road and installation of a reinforced gravel access road to Site A, lowering of the
surface water at OU-3 by channel improvements in the Old Great Brook channel, short-term
dewatering through localized sump pumps, excavation of 207 drums (both empty and containing
wastes), and ovcrpacking of approximately 50 drums of waste (and an additional 19 drums of
investigation derived waste), backfilling of the excavations, and off-site disposal of the drummed waste
and asbestos-contaminated solid waste to an approved facility. Post-excavation soil samples were
collected from the excavations. Analytical results indicated contaminant concentrations below ARAR
and TBC criteria.
Based on all of the information collected to date, it is anticipated that future risk associated with
hazardous wastes at Site A will be reduced to acceptable levels by the drum-removal operations at Site
A.
This alternative would require a review of the remedial action every five years pursuant to CERCLA
Section 121 ( c ), 42 U.S.C. Section 9621 ( c ), because implementing this alternative would result in
hazardous substances remaining on-site above health-based levels. Additional remedial actions could
be required depending on the results of such a review.
Alternative 3 - Drum and Lead-Impacted Soil Removal, Consolidation and Covering of
ACM, Dewatering, Water Diversion, Drainage Improvements, and Institutional Controls:
Alternative 3 includes implementation of source control. The source control activities generally
include access improvements, short-term dewatering, drum removal, containment, long-term surface
water drainage improvements, institutional controls, and O&M activities.
The access improvements and drum removal activities were conducted in September 1997, prior to
final remediation at Site A. The drum removal activities were the same as stated in Alternative 2A.
The containment consists of a "biotic barrier" that will be constructed over Site A once all of the drums
Capital Cost:
Operation and Maintenance Cost:
Present-Worth Cost:
Implementation Time:
$3,908,803
$273,571
$4,182,374
15 months
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have been removed and the ACM from Site B and UAR have been relocated to Site A. This alternative
provides for the installation of a cover over the ACM area consistent with the National Emission
Standards for Hazardous Air Pollutants (NESHAPS) of the Clean Air Act. The thickness and
construction specifications of the cover which best meet the NKSHAPs, as well as the Refuge
Management Plan, Wilderness and Wetlands ARARs, are design details to be determined during the
remedial design phase. The purpose of the biotic barrier is to prevent animals from burrowing into the
underlying ACM, to cover the ACM so that the ACM is not subject to deterioration and erosion by
wind or water, and to prevent direct human and animal contact with ACM.
The proposed biotic barrier will consist of several layers, as exemplified in Figure 7 of Appendix I. The
uppermost layer will likely consist of topsoil that is vegetated with grass or indigenous, shallow rooted
plants to minimize erosion. Underneath the topsoil layer there may be layers of common fill,
geotextiles or a layer of stone, sized to make it difficult for burrowing animals to penetrate.
Geosynthetics, such as filter fabric, may be used to prevent mixing be *een the overlying and
underlying materials. The filter fabric will permit water, but not solids, to pass through. The layer of
stone may also be substituted for other geotextile materials (e.g., High Density Polyethylene geogrid or
geonet mesh) that are capable of acting as a deterrent lo burrowing animals. These materials will have
performance capabilities similar to meshes used in animal enclosures and may be used in lieu of
stone to address the USFWS and public desire to limit the amount of truck traffic to and from the
site. In addition, the use of on-site fill materials may assist in achieving a "no net fill" impact to the
Wilderness Area, by using on-site borrow to fill to the cover depth required by EPA. The details of
the design will be finalized during the remedial design phase of the project, and will be contingent upon
EPA approval.
Excavation, removal, and off-site disposal of lead-contaminated soils and debris (concentrations greater
than 218 mg/kg lead) from Site B, and RAs was completed in late Spring 1998. The remaining ACM
from the UAR, Site B, and refuse areas will be placed inside the biotic barrier area at Site A prior to
cover installation. Along with placement and construction of the biotic barrier, the proposed remedy
would also include the abandonment of the existing monitoring wells. Following removal of the ACM
and lead-impacted soil and debris from Site B and RAs, and post-excavation sampling to confirm
residual asbestos at less than one percent, the excavated areas will be graded lo a smooth surface and
allowed to revegetate naturally. A mixture of annual grass and perennial grass native to the Refuge
will be planted to prevent erosion during the revegetation process.
Since no mercury was found above the RCRA action levels (TCLP or UTS) which would be classified
as RCRA hazardous waste, the mercury-contaminated soil and ACM waste mound to be covered in
place at the site would not be considered a RCRA hazardous waste landfill. The only material which
exceeded either criteria was the single drum of mercury contaminated waste removed and disposed of
as a hazardous waste during the Phase II RI.
Temporary lowering of the surface water at Site A over what has been already accomplished through
drainage improvements may be conducted utilizing localized dewatering through wellpoints or sump
pumps, if necessary, to install the cover over Site A. In addition, long-term drainage improvements
would be designed into the remedial action around the periphery of Site A to keep high surface water
25

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levels from potentially eroding away the cover materials. Recent drainage improvements and pilot
dewatering tests during 1997 have demonstrated some success in surface water management.
The removal of the drums from Site A has eliminated the primary potential source of groundwater
contamination within the Site A mound. Due to the interaction of shallow groundwater with surface
water at Site A, surface water sampling is the most appropriate monitoring method for both
groundwater and surface water quality and will lie conducted as part of the long-term monitoring at Site
A. In response to stakeholder concerns, shallow aquifer groundwater monitoring will also be a
component of the monitoring plan. Sample frequency and specific sampling points will be determined
during remedial design.
Institutional controls would be established in accordance with the mission of the Refuge and consistent
with the surrounding Wilderness area. Specific controls will be developed in detail during preparation
of the final Maintenance and Monitoring Plan. Controls currently envisioned include limiting visitor
access to daylight hours, limiting uses to passive recreation such as bird watching, photography or
hiking, and prohibiting heavy vehicles. Long-term monitoring of the site would consist of surface
water and wildlife monitoring, as is the current Refuge practice. Other 0& M activities would include
mowing in a manner consistent with the wilderness setting and regular inspection of the integrity of the
biotic barrier.
It is anticipated that up to approximately 2-acres of wetlands may be impacted by these proposed
activities. However, final design considerations may mitigate the impacts to a smaller acreage or even
expand wetlands over current site conditions. Therefore, this option would also include an assessment
of wetland impacts and restoration of wetland areas.
This alternative would require a review of the remedial action every five years pursuant to CERCLA
Section 121 ( c ), 42 U.S.C. Section 9621 ( c ), because implementing this alternative would result in
hazardous substances remaining on-site above health-based levels or ARARs. Additional remedial
actions could be required depending on the results of such a review.
Alternative 4 - Drum Removal, Excavation of ACM and other Waste, Dewatering, On-Site
Land filling, Waste Consolidation, and Institutional Controls:
This alternative includes the construction of an ofT-OU-3, but on-Refuge, lined landfill (2 acres) with
five new monitoring wells, access improvements, short-term dewatering, drum excavation and off-site
disposal, excavation and on-site relocation of about 40,600 cubic yards of ACM and refuse debris, post-
excavation sampling, limited backfilling, institutional controls, and O&M activities.
A lined landfill is constructed with a low permeability bottom liner. The contaminated materials are
Capital Cost:
Operation and Maintenance Cost:
Present-Worth Cost:
Implementation Time:
$8,721,236
$1,195,675
$9,916,911
3 Years
26

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then placed on the liner and covered with another low permeability liner. This facility effectively
serves two purposes: it restricts the infiltration of rain water and also captures any water that may be in
the waste. Captured water, called leachate, would be collected and treated prior to disposal or
discharge.
The proposed location of the 2-acre lined facility has not been identified at this time, and an
environmental impact/foundation analysis study would have to be completed. Construction of the lined
facility would be completed prior to other activities, and will include site preparation, installation of
five wells, and constructing the liner. The facility would include short-term mechanisms for leachate
collection during construction, as well as a long-term leachate collection system and monitoring system
to prevent releases to the environment. The waste relocation activities would include site preparation,
excavation and relocation of the 40,600 cubic yards of ACM/refuse debris, confirmatory testing at the
excavation perimeter and selected backfilling and covering of about 308,000 sq. ft. with a 6-inch-thick
layer of native topsoil (5,700 cubic yards), and seeding of the topsoil with local plant species. The
excavation would include the removal of the asbestos-tainted sediment, which has been accounted for
in the 40,600 cubic yards. The drum removal activities have been conducted as a separate phase prior
to excavation of waste at Site A.
The short-term leachate collection system would involve the collection of leachate and off-site disposal
at a water treatment facility. The long-term system would consist of a composite liner system with
gravity feed through a high permeability leachate collection layer and to an underground collection
chamber. The chamber would be visually inspected periodically and the collected leachate would be
either disposed off-site or treated on site for on-site disposal.
Once all materials have been disposed at the lined facility, the area would be encapsulated with a low-
permeability cover. Native topsoil (3,300 cubic yards) would be placed over the covered area, which
would be seeded with local shallow-rooted plant species. The final cover system would include a
passive gas collection system; a minimum 5-percent top slope and maximum 33-percent side slopes are
also recommended for the final cover. A passive gas collection system allows the gases resulting from
the decay of waste materials as a prefened pathway of escape. This reduces the possible danger of gas
buildup under the liner.
Temporary lowering of the surface water at OU-3 and localized dewatering through wellpoints or sump
pumps would likely be required to excavate the waste at Sites A and B. In addition, drainage
improvements and other mitigation measures would be required around the periphery of Site A to assist
in the dewatering effort and prevent migration of potential contaminants from the excavation.
Short-term monitoring of the excavation activities is included in this alternative, and would include
upstream and downstream turbidity and environmental testing of surface water and air, as well as post-
excavation sampling of soils and sediment. The long-term groundwater monitoring program, as
required for ARARs for this type of constructed facility, would include installation of five new wells at
the lined facility and sampling from the five wells on a quarterly basis. Additional O&M would
include visiting the encapsulated area on a quarterly basis to inspect the integrity of the biotic barrier
and drainage improvement areas. Institutional controls would be put in place to ensure that no
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inappropriate use of soils, surface water, or groundwater would occur.
This alternative would require a review of the remedial action every Five years pursuant lo CERCLA
Section 121( c ), 42 U.S.C. Section 9621 ( c ), because implementing this alternative would result in
hazardous substances remaining on-site above health-based levels. Additional remedial actions could
be required depending on the results of such a review.
Alternative 5 - Drum Removal, Excavation of ACM and other Waste, Dewatering, and Off-
Site Disposal:
Alternative 5 includes implementation of source control activities and includes access improvements,
short-term dewatering, drum excavation and off-site (off-Refuge) disposal, excavation and off-site
disposal of about 40,600 cubic yards of ACM and refuse debris, post-excavation sampling, and limited
backfilling. The drums and ACM would be disposed at approved off-site waste disposal facilities.
The waste excavation activities would include site preparation, excavation and off-site disposal of the
drummed waste (done) and 40,600 cubic yards of ACM/refuse debris, confirmatory testing and
selected backfilling of 308,000 sq. ft. with 6-inch-thick layer of native topsoil (5,700 cubic yards), and
seeding of the topsoil with local plant species. As noted above, the drum removal activities have been
conducted as a separate phase prior to excavation of waste at Site A.
Temporary lowering of the surface water at OU-3, localized dewatering through wellpoints or sump
pumps, drainage improvements, and other mitigation measures (i.e. silt curtains) would be required to
excavate the waste at Sites A and B. In addition, short-term monitoring of the excavation activities is
included in this alternative.
To minimize the impact to the Wilderness Area, excavation work should again be done in phases at a
pace that is consistent with the Refuge's objectives, and it is recommended that excavation work be
done in stages with lightweight, wide track equipment.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
In selecting a remedy, DOI and EPA considered the factors set out in CERCLA §121, 42 U.S.C. §9621,
by conducting a detailed analysis of the viable remedial alternatives pursuant to the NCP, 40 CFR
§300.430(e)(9) and EPA OSWER Directive 9355.3-01. The detailed analysis consisted of an
assessment of the individual alternatives against each of nine evaluation criteria and a comparative
analysis focusing upon the relative performance of each alternative against those criteria.
Capital Cost:
Operation and Maintenance Cost:
Present-Worth Cost:
Implementation Time:
$14,179,495
$0
$14,179,495
3 Years
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The following "threshold" criteria must be satisfied by any alternative in order to be eligible for
selection:
1.	Overall protection of human health and the environment addresses whether or not a remedy
provides adequate protection and describes how risks posed through each exposure pathway
(based on a reasonable maximum exposure scenario) are eliminated, reduced, or controlled
through treatment, engineering controls, or institutional controls.
2.	Compliance with ARARs addresses whether or not a remedy would meet all of the applicable
(legally enforceable), or relevant and appropriate (requirements that pertain to situations
sufficiently similar to those encountered at a Superfund site such that their use is well suited to
the site) requirements of federal and state environmental statutes and requirements or provide
grounds for invoking a waiver.
The following "primary balancing" criteria are used to make comparisons and to identify the major
trade-offs between alternatives:
3.	Long-term effectiveness and permanence refers to the ability of a remedy to maintain
reliable protection of human health and the environment over time, once cleanup goals have
been met. It also addresses the magnitude and effectiveness of the measures that may be
required to manage the risk posed by treatment residuals and/or untreated wastes.
4.	Reduction of toxicity, mobility, or volume via treatment refers to a remedial technology's
expected ability to reduce the toxicity, mobility, or volume of hazardous substances, pollutants
or contaminants at the site.
5.	Short-term effectiveness addresses the period of time needed to achieve protection and any
adverse impacts on human health and the environment that may be posed during the
construction and implementation periods until cleanup goals are achieved.
6.	Implementability refers to the technical and administrative feasibility of a remedy, including
the availability of materials and services needed.
7.	Cost includes estimated capital and operation and maintenance costs, and the present-worth
costs.
The following "modifying" criteria arc considered fully after the formal public comment period on the
Proposed Plan is complete:
8.	State acceptance indicates whether, based on its review of the RI/FS report and the Proposed
Plan, the State supports, opposes, and/or has identified any reservations with the preferred
alternative.
9.	Community acceptance refers to the public's general response to the alternatives described in
29

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the Proposed Plan and the Rl/FS reports. Factors of community acceptance to be discussed
include support, reservation, and opposition by the community.
A comparative analysis of the remedial alternatives based upon the evaluation criteria noted above
follows.
•	Overall Protection of Human Health and the Environment
Alternatives 3, 4 and 5 will provide for overall protection of human health and the environment.
•	Compliance with ARARs
Alternative 1 would not be effective in complying with ARARs because compliance with chemical-
specific ARARs can not be adequately assessed under this alternative.
Under Alternatives 2 and 2A, the existing site conditions and access restrictions would not be
consistent with allowing public use of Wilderness Areas. In addition, a remedial alternative that leaves
site conditions largely unchanged is considered inconsistent with location-specific ARARs or TBCs
that address management of general public use of National Wildlife Refuge Systems under Executive
Order 12996, management of wilderness areas under the Wilderness Act and specifically management
of the GSNWR Wilderness Area under the Great Swamp N WR Wilderness Area Act.
Under Alternatives 3 and 4, ACM and other site related contaminants would either be excavated and
permanently removed from the site or direct exposure and access will otherwise be restricted. Removal
or containment of site contaminants is consistent with the location-specific ARARs cited above.
Under Alternative 5, ACM and other site related contaminants would be excavated and permanently
removed from the site. Restoration of the site is consistent with location-specific ARARs.
•	Long-Term Effectiveness and Permanence
Alternatives 1 and 2 would not be an effective approach in the long term because the contaminants of
concern could impact the surrounding environment As a result, the human health and ecological risks
will ianain.
Alternative 2A is expected to be an effective long-term alternative for addressing the drummed waste.
However, the alternative does not address 99 percent of the ACM and the refuse debris. It is, therefore,
only marginally effective in the long term.
Alternatives 3, 4 and 5 are effective long-term approaches. There are longer-term risks associated with
Alternative 3, however, they are expected to be limited. Covering the waste in place does not provide
the same level of assurances as relocation of the waste to engineered facilities, and long-term
monitoring will be required.
30

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Alternative 4 also poses a limited long-term risk to the surrounding environment, however, by
relocating the waste to a secure lined facility outside the Wilderness Area, this risk can be controlled.
Alternative 5 will pose no long-term human health or ecological risk to the surrounding environment
and will not require long-term monitoring.
•	Reduction in Toxicity. Mobility, or Volume via Treatment
Reduction of toxicity, mobility, and volume of the contaminants of concern could not be determined
for Alternatives 1 and 2. The monitoring component is only a means to assess the actual and relative
concentrations of contaminants. Monitoring to date has shown some reduction in contamination
through time, but the duration is too short to be conclusive. Modeling has not been conducted to
determine the effectiveness over time.
Alternative 2A is an effective mechanism to reduce the toxicity, mobility, and volume of the
compounds associated with the drummed waste, but is only marginally effective in reducing the
toxicity, mobility, and volume of the ACM and refuse debris.
Alternatives 3, 4 and 5 are effective overall approaches to reduce the toxicity, mobility, and volume of
the contaminants of concern. Alternative 3 would remediate the hazardous waste and restrict the
mobilization of compounds. This would reduce the toxicity and volume of compounds to
concentrations that are below chemical-specific ARARs and risk based levels. Monitoring would be in
place to evaluate if the remedial objectives are being achieved through these activities.
By relocating the waste to a secure lined facility outside the Wilderness Area, Alternative 4 also
controls toxicity, mobility and volume.
Alternative 5 is the most effective alternative, since all materials will be disposed off site, and there is
no longer human or ecological exposure to the waste sources.
•	Short-Term Effectiveness
Alternatives 1 and 2 would not be effective in the short-term because existing conditions are impacting
the environment In addition, Alternative 2A would not be effective in the short-term because certain
contaminants of concern are related to the refuse debris and ACM, which arc not addressed by this
alternative.
Alternatives 3, 4 and 5 present additional short-term impacts to the environment that can be overcome.
It is anticipated that the potential short-term risks associated with these activities can be mitigated
through fast-tracking and phasing (as discussed in Chapter 7 of the FS), proper planning/design,
conventional health and safety procedures, and sensitivity to the Wilderness Area and goals of the
Refuge.
31

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• Imnlcmentabilitv
Alternative 1 is readily implementable in that it requires no further action. Alternative 2 can be
implemented with limited coordination and impact to the Wilderness Area. The implications of
available funding do not have an impact on the implementation of either Alternative 1 or 2.
The remaining alternatives are more complicated to implement since they involve more extensive
planning, design, and construction issues. These issues include permitting issues; detailed design
issues; dewatering activities; the excavation, handling, and disposal of waste materials; potential
backfilling and replication of wetlands and floodplain areas; evaluation of on-site disposal areas
(Alternative 4); and health and safety concerns.
• Cost
The cost comparison for the remedial alternatives indicates a significant disparity in costs. The
estimated total present value for each alternative, including the cost for drum removal, arc as follows:
Alternative 1:	$95,654
Alternative 2:	$305,729
Alternative 2A:	$978,958
Alternative 3
Alternative 4
Alternative 5
$4,182,374
$9,916,911
$14,179,495
•	State Acceptance
The State of New Jersey concurrence letter for the selection of Alternative 3 is provided in Appendix
IV.
•	Community Acceptance
USFWS held three informal open-house meetings for the public during the various stages of the site
investigation to present information and findings. USFWS was responsive to community concerns
expressed at these meetings, and where appropriate, included additional activities during the RI/FS
phases to address the questions or concerns. The consideration of additional incomplete exposure
pathways (e.g. surface and groundwater ingestion) during the risk assessment was the result of
expressed community concerns.
At the December 17, 1997 public meeting, interested community members met with USFWS
representatives to discuss the proposed remedial alternative for the site. Each of the alternatives
developed and considered under the Feasibility Study was presented at the December 17 meeting.
Specific questions and concerns expressed at this meeting are provided in Appendix V. Community
32

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response to the preferred alternative was generally positive. Concerns were expressed regarding cost
and possible short term impacts from consolidation activities, which were addressed at the public
meeting (see .also Appendix V). USFWS responses to the concerns expressed both at the public
meeting and in writing during the public comment period (December 12, 1997 - February 27, 1998) are
provided in the Responsiveness Summary (Appendix V).
After considering the community response, no significant changes in the proposed remedial action are
needed to address most community concerns.
SELECTED REMEDY
After reviewing the alternatives and public comments, DOI, USFWS, and EPA have determined that
Alternative 3 is the appropriate remedy for the site. This remedy has been selected because it best
satisfies the requirements of CERCLA §121, 42 U.S.C. §9621, and the NCP's nine evaluation criteria
for remedial alternatives, 40 CFR §300.430(e)(9). Since this remedy leaves waste on site, it will
require a 5-year review in accordance with Section 121( c ) of CERCLA.
The major components of the selected remedy are as follows:
1.	Access improvements;
2.	Long-term drainage improvements, and short-term erosion control measures;
3.	Drum removal activities (which were completed in September 1997 as a time-critical, non-
emergency removal prior to implementation of the preferred alternative), including post-
excavation and waste classification sampling;
4.	Removal and off-site disposal of lead contaminated soils (completed, Spring 1998);
5.	Consolidation of Site B ACM into Site A (completed, Spring 1998);
6.	Placement of a biotic cover over Site A;
7.	Implementation of institutional controls to ensure the continued integrity of the drainage
and cover activities (e.g. limiting visitor access to daylight hours, prohibiting other than
passive uses such as hiking, bird watching and photography); and,
8.	Assessment of wetland impacts and wetlands restoration.
After completion of the remedial activities noted above, a long-term O&M and monitoring program
will begin. USFWS will mow the biotic cover and prune vegetation. Monitoring of biota and surface
water will continue in the vicinity of OU-3, as is currently done by the Refuge. Monitoring will be in
accordance with NJ landfill closure requirements. Shallow aquifer groundwater monitoring will also
be a component of the monitoring plan, however sampling frequency and sample locations will be
determined during remedial design. Additional O&M will include visiting the covered area on a
quarterly basis to inspect the integrity of the cover materials and drainage improvement areas.
Initial access and short-term dewatering already completed at the site include:
• Implementation of surface water management improvements evaluated during the Value
Engineering Study;
33

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•	Improving the UAR, from the parking area at Long Hill Road to 25 ft beyond the Old Great
Brook channel; and
•	Placement of a temporary culvert system at the former location of the Old Great Brook
Culvert.
In addition, the drum removal activities (completed in September 1997) also included the clearing of
Site A; temporary lowering of the surface water by channel clean-out in the Old Great Brook channel,
the use of sump pumps as needed; the excavation and overpacking of drums; post-excavation soil
sampling; the partial backfilling of the drum excavations; and the off-site disposal of the drummed
waste and asbestos contaminated solid waste to a permitted facility. Additional short-term control
measures will include installation of a silt curtain to prevent erosion into the wetlands during
remediation.
Prior to covering Site A, long-term drainage improvements will be constructed to keep surface water
from eroding the Site A slopes. The long-term drainage improvements will include temporary
lowering of surface water along the periphery of the site; consolidation of waste from the periphery
of Site A, including mercury-impacted sediment; and regrading of the unimpacted area around Site
A,	to a distance of approximately 25 ft beyond the final limit of waste. Final cover activities at Site
A will also include relocation of the asbestos containing material associated with the UAR and Site
B.	Following the consolidation of waste, the entire Site A surface will be cleared, grubbed and
graded for the biotic cover materials.
The proposed biotic barrier will likely consist of the layers exemplified in Figure 7 of Appendix I. This
detail meets USFWS goals of using on-site materials to achieve a "no net filling" of the Wilderness
Area and limits the amount of off-site material that would otherwise be trucked to the site. The details
of the design, including the final requirements for cover depth, will be finalized during the remedial
design phase of the project and will be contingent upon EPA approval.
The uppermost layer will consist of 6 inches of topsoil that is capable of supporting grass or
indigenous, shallow rooted plants. The plant structure will minimize erosion. Underneath the topsoil
layer there will be layers of common fill and geotextiles. Geosynthetics, such as filter fabric, will be
used to prevent mixing between the overlying and underlying materials. The filter fabric will permit
water, but not solids, to pass through. The stone layer previously proposed will likely be substituted by
a geotextile material (e.g., High Density Polyethylene geogrid mesh) that is capable of acting as a
deterrent to burrowing animals. Again, the geotextiles will be used in lieu of stone to address the
USFWS and public desire to limit the amount of truck traffic to and from the site, and assist in
achieving a no net fill impact to the Wilderness. The geogrid mesh will be monitored and
maintained on a regular basis, as part of the long term maintenance of the site. The long term
maintenance is required under CERCLA (40 CFR 264) and will be presented in the Remedial Action
Work Plan.
As a result of the cover and drainage improvements, it is anticipated that up to 2 acres of wetlands and
34

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2 acres of flood storage could be impacted and need restoration to comply with ARARs. I lowever,
final design details and criteria may reduce this impact or even create wetland gain instead of loss. The
former location of Site B and the Refuse Areas may be considered for wetlands replication and flood
storage. This work would be initiated after Site A is completed and the other areas (Site B, UAR and
RAs) are remediated. Any wetlands replication will be required to meet USFWS, EPA and NJDBP
wetlands mitigation standards.
Once the remedial activities are completed, the silt curtain and temporary culvert will be removed.
Capital costs for implementation of Alternative 3 are estimated at $3,908,803. Present worth O&M
costs are estimated at $273,571 (for a 30 year period) for a total present worth cost of $4,182,374.
STA TUTOR YDETERMINA TIONS
As previously noted, CERCLA §121 (b)(1), 42 U.S.C. §962l(b)(l), mandates that a remedial action
must be protective of human health and the environment, cost effective, and utilize permanent solutions
and alternative treatment technologies or resource recovery technologies to the maximum extent
practicable. Section 121(b)(1) also establishes a preference for remedial actions which employ
treatment to permanently and significantly reduce the volume, toxicity, or mobility of the hazardous
substances, pollutants, or contaminants at a site. CERCLA §121(d), 42 U.S.C. §9621(d), further
specifies that a remedial action must attain a degree of cleanup that satisfies ARARs under federal and
state laws, unless a waiver can be justified pursuant to CERCLA §121(d)(4), 42 U.S.C. §9621(d)(4).
For the reasons discussed below, DO! and EPA have determined that the selected remedy meets the
requirements of CERCLA §121,42 U.S.C. §9621.
Protection of Human Health and the Environment
Alternative 3, the cover/dewatering/water diversion/drainage improvements alternative, will actively
reduce the toxicity, mobility, and volume of the compounds observed throughout the Site. By
excavating the drummed waste and lead-impacted soil and disposing of the material off-site, the
concerns associated with the drums and lead COC no longer exist. Furthermore, through covering the
remaining ACM waste, mercury-contaminated soils and sediment, the exposure of humans and biota to
these sources is controlled. This alternative also includes the monitoring mechanisms to evaluate any
remaining impacts to human health and the environment. Overall protection of human health and the
environment is high.
Compliance with ARARs
This alternative provides for extensive field activity to excavate and relocate hazardous materials,
conduct post-excavation sampling to assure chemical specific ARARs and TBC criteria are attained,
and to restrict exposure to hazardous materials remaining on-site. As a result, it will change the
existing conditions and have an impact on the Wilderness Area. The alternative must protect the
35

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character and value of the Wilderness Area, and ail improvements must be performed in accordance
with location-specific ARARs and TBC criteria (e.g. U.S. Great Swamp NWR Wilderness Area Act,
U.S. Wilderness Act, Endangered Species Act, U.S. Protection of Wetlands and Floodplains Executive
Orders, U.S. Fish and Wildlife Coordination Act, U.S. Emergency Wetlands Resources Act of 1986,
and the U.S. Clean Water Act).
This alternative will require post-closure monitoring and ensure future use of the land is consistent with
management objectives for the surrounding Wilderness Area. Institutional controls already afforded
the site under several ARARs (see above) allow active management strategies to achieve Wilderness
Area protection. Therefore, as a result of this alternative, public use of the land may be restricted to
passive or non-intrusive activities such as bird watching or hiking.
A monitoring program will be implemented to ensure future compliance with chemical-specific
ARARs. Drum and lead-impacted soil removal, and the placement of a biotic barrier cover are
expected to reduce the toxicity, mobility, and volume of the contaminants of concern, to levels where
certain compounds (i.e. benzene, TCE and lead) are no longer a threat. Other compounds (e.g. asbestos
and mercury) will be addressed by minimizing the mobility to levels that will meet chemical-specific
ARARs.
Action-specific ARARs associated with the proposed work will be complied with. These include, for
example, National Emission Standards for Hazardous Air Pollutants (NESHAPS, 40 CFR 61.151)
related to in-situ placement/consolidation or remediation of asbestos and ACM, RCRA standards for
hazardous waste generators, transporters and disposal facilities (40 CFR 262, 263, 264) and applicable
Land Ban Restrictions (40 CFR 268); Clean Water Act; New Jersey Hazardous Waste Management
Regulations; New Jersey Water Pollution Control Regulations; and New Jersey Soil Erosion and
Sediment Control Standards.
Cost-Effectiveness
The total present worth cost (capital costs and O&M over a 30 year period) for this alternative is
$4,182,374. This is a moderate cost which still ensures long-term effectiveness in meeting ARARs and
protecting human health and the environment.
Utilization Permanent Solutions and Alternative Treatment Technologies to the Maximum
Extent Practicable
The selected remedy utilizes permanent solutions and treatment technologies to the maximum extent
practicable. The selected remedy provides the best balance of trade-offs among the alternatives with
respect to the evaluation criteria. Through off-site disposal of drums and lead-impacted soils,
addressing the means of transport through covering remaining waste, this alternative is expected to
reduce the toxicity, mobility, and volume of all contaminants of concern to concentrations that are
below the risk-based levels. Covering of the remaining sources of contamination with long-lasting
materials will limit the routes of exposure. Monitoring of the covered areas will provide the data to
assess the effectiveness and lead to any corrective actions. Therefore, the biotic barrier, in conjunction
36

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with monitoring activities, is expected to be effective in the long-term.
By removing the hazardous waste materials from the sites, this alternative effectively reduces the
toxicity, mobility, and volume of the associated compounds. Furthermore, by installing covers over the
ACM and refuse debris, this alternative restricts the means of transport and mobility of contaminants of
concern. This in turn reduces the volume and toxicity of the contaminants. Monitoring will also be
implemented to evaluate if the remedial objectives are being achieved through these activities and/or
natural attenuation. This alternative is, therefore, considered to be an effective mechanism to reduce
the toxicity, mobility and volume.
In the short-term, this alternative is expected to change the existing conditions of each source area and
the potential release of contaminants from drums at Site A. Therefore, the alternative will address the
existing short-term impacts and some additional short-term impacts to the environment will occur. The
additional impact can again be minimized with sensitivity to the Wilderness Area and thr™'gh proper
design and planning (i.e. implementation of an approved Remedial Action Work Plan and Construction
Contingency Plan, to possibly include such elements as minimum tool provisions and seasonal
scheduling). With the proper controls in place, this option can effectively address the short-term
concerns.
Preference for Treatment as a Principal Element
The proposed alternative meets the statutory preference for treatment as a principal element. Remedial
treatment technologies evaluated during the FS were included on the basis of their effectiveness in
addressing the principal threats to site, particularly in regard to the buried drums in Site A, lead
contaminated soils in Site B, and the refuse areas and friable and non-friable ACM throughout the site.
Drummed waste, and other material determined to be an environmental threat, will be treated through
removal from the site. The ACM remaining on site will not be treated but confined. Engineering and
institutional controls will maintain the integrity of the remedy. Consolidation and covering of the
balance of refuse and ACM within Site A minimizes potential impacts to human health or the
environment, and proper biotic barrier construction, maintenance, and monitoring further prevents
future impacts to human and ecological receptors.
DOCUMENT A TION OF SIGNIFICANT CHANGES
There are no significant changes from the preferred alternative presented in the Proposed Plan.
37

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APPENDIX I
FIGURES

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Paterson
Mornstown
GREAT SWAMP *
NWR
adison
.. NEWARK
BROOKLYN
• Plain field
STATEN
ISLAND /
Perth
Amboy
—•
New Brunswick.#
Great Swamp National Wildlife Refuge
	Morris County. N J.	
Figure 1
Site Location Map
Source: U.S.F.W.S.. 1987
foster wheeler environmental corporation

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NEW VEKNON
F.XlT M)A
(South Bound)
S V\vX#-
Exit joo
(North Bound)
NORTH
/
OU-3
^/southard (Cl0S£:d)
V/ PARK
OFR
BASKING
KIDCE
GKEKN
VILLAGE,
CHATHAM
/u>»' 7


» : tt-.V'
. .. n >
SOMERSET COUNPr v-*
o\ environmental frnuCAnor-i
CENTER
rord"	*ocJ
i;h^. ,
• \ r
$
<°\
l-i\ Licyoro^Jik/'
00^"

•?\
MORRIS counrr
OUTDOOR EDUCAriO^ CINTER


v
-*o
1J.
Legend
| AlUitkNtSS AK.A
| \dANAut.MKNl AKA
NVAlluN/VnuU ' Bl li'JbS
Kivt k . Ar.i) "jiKl aw,
n .1 ,.J
OUji	arid Areas o< Concern
OU - 3	Cpri QUf! I 'r.it h
1 Jf- K	Old r vjin -,itc
\'i	¦ MIl- If'
f Mf	ioffiu;' M..: '• r.'Mj^h l'fi)j«-:fty
». I'	1 -jfif <>¦/ \Jr ,p«. r t /
¦ '	-i\t t; /
jCOlr in Mtlci
0	5000
Ei; — .=z7-=r^lsr)
Srok* in Tec:
(itosc Mop after USFV/S 1990}
G.eui St/wmp National OtldNfe Refuse
Morris (ouoty. NJ
future 2
Or - - jt Swomp National
Wildlife Refuge
WhfKEK LnviKONMeNTAL CORPORA "101.

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REFUSE
AREA h
REFUSE J
SITE A
GRAPHIC SCALE
£ BROOK
TREEUNE
FOOT PATH/ACCESS RQaO
Gnat "Twni|i Nakkntl YUdJllt Rafug*
OpwmU* OnH Ha. 9
Main Cooaty. N
oiAm-ow. oavoRAiioN

-------
J UAt b< r
Jh %>*V,LL*?E f '
Great SwamD y
Nationol Wildlife
Refuq
*
BtRNARDSVlLLE
/
. MCYERSV1LLE
MHUNGTON
[ _Jfh J
55D
LjpH
+
LEGEND
Boonton Formotion
Hook Mountain Basalt
Towoco Formotion
(pottern indicates conglomerate focies)
Preokness Bosolt
Anticline
FeltviDe Formation
\_3o j Orange Mountoin Bosolt
Possoic Formotion of Olsen (1980)
0	OUJ or A/eo of Concern Site
(see text for e*p1o"Oti©n)
£ 	— -— Fault, bar and bell on
^ do«n thrown side
sou m tot
SyncHne
R»f»rer>ce: P«portm»nt of Interior U.S._Coo*Oflic__Sofy
-------
-tr
I
uo
c
B
<
x>
D
MO'fitto
Chilha
Stilt in Milrl
PI ¦¦nri<-ld
Locauon Map
Recharge
Recharge
Area
Discharge Area
Piezometric Surlace
ol Unconlined Water
Piezomelnc Surlace
ol Unconlined Water
Piezomelnc Surlace
ol Conlined Water
Flowing Well in Sand
Stream
— — Clay and Silt
Sand and Gravel
^ a a) a ><¦
2.000 4,000
1	I
Generalized
Flow Lines
Flowing Well in Bedrock
Scale in Feet
400 -
SOURCE: VECCHIOLI. et al.. 1962
Great Swamp National Wildlife Refuge
Operable Unit 3
	Morris County. N.J.	
FIGURE 5
Greot Swomp NWR
Schemotic Geologicol Cross-Section
FOSTER WHEELER ENVIRONMENTAL CORPORATION
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234 <
1' •; _r
WabSm i
27 , 2$148 /
Site A
GNATHIC 'iCALI
KG END
ijrtfJt ^amp National Wildlife H«fuge
per »b> Urul No '3
Morru Co'iniy. nJ
230 0
flf!'• '\^i.<-	r ^ £s* KQKMfcNTAi ;va-• > j rs
-------
FINAL SLQPC VARIES C3MV MAX.)
PREPARED SUBGRADE
COMPOSITE SYNTHETIC BARRIER
CBIAXIAL HDPE GEOGR1D OVER A
NON-WOVEN, 4.5 OZ/SY FILTER FABRIC)
NOTES
I. The Contractor shall subnit o pannt, layout to the USFVS for review,
prior to installation,
2 The geoQrid and Filter Fabric roll widths shall be a rvninun oF 12 Feet.
3.	The seams oF the composite barrier shall be overlapped a minimun of 6 Inches.
4.	8elo» Elevation 234.5, erosion control nattinQ shall be used For slope protection.
Above Elevation 234.5, the area shall be hydroseeded
5.	Th# vegetative layer and hydrosetd nix shall be as specified and shall toe submitted
to USFVS for revien and approval.
PROPOSED BIOTIC BARRIER DETAIL
BCAUS N.T.S.
FIGURE 7
SfTE A REMEDIAL ACTION DESIGN
GSNWR - OPERABLE UNIT 3
BASKING RIDGE, NEW JERSEY
SEA Consultants, Inc.
BamM^Bgn^nlkdtAe(M
i
wr

r-ri
r * >2
rm*
GAV\NJMILLlNSStrE_R*\C-4A.DVG
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APPENDIX II
TABLES
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P.je I of 6
Table 1
Summary of Detected Contaminants
Drum Removal Action Post Excavation Sampling
SAMPLE ID
LABORATORY ID



n-CM18-0044L
}«5M
r)-GHl»-fr»S-SL
MJ*»
TtitW liuk
n-ct-oei-oa-a.
2*405
»7-GS-»C7-#02-SL
MM
r7-GS-003-M14L
war

NJDST
Njcer
Njncr







MMUMrad
XaJMi^yDh<
laptd U Qmsfniv







CMlid SOfLCUAMUT
CtaOrf KXLCXXANUr
MXLOIANtfr







UuiudA
OUTTJUA imtTlt
annui^id*






METAI J tnn/Ki)









Aluminum
Nooe
None
Nooe
19,400
20,700
NA
22,800
12,400
18,100
Anenic
20
20
¦Nooe
2.1
2.6
NA
3.6
3.4
5.4
Barium
700
47,000
None
254
267
NA
224
174
292
Bcrylium
I
1
None
1.4
1.2
NA
1.1
0.99
1.7
Cadmium
1
100
Nooe
0.21
0.26
NA
0.45
0.33
0.66
Calcium
None
None
Nooe
5,180
3,000
NA
2,960
2,170
5,640
Chromium
Nooe
None
Nooe
33.5
35.8
NA
33.7
24
26.8
CobaJl
None
None
Nooe
6.7
7
NA
8.3
5.1
9.8
Copper
600
600
None
20.3
19.5
NA
19.6
17.7
27.4
Iroo
Nooe
Nooe
Nooe
11,400
11,800
NA
1 J,400
8.690
13,500
Ltad
400
600
Nooe
10.1
11.6
NA
JO.4
11.6
10.6
Mafoejium
Nooe
Nooe
None
1,840
1,930
NA
2.130
1,480
1.320
Mifljtotie
None
None
Nooe
296
297
NA
169
121
459
Mercury
14
270
Nooe
0.11
0.15
NA
0.1
ND
0.1
Nickel
ZJ0
2,400
Nooe
14
14.4
NA
17.8
10.3
15.3
Pounium
Nooe
Nooe
Nooe
461
301
NA
372
226
210
Selenium
6}
3,100
None
1.8
1.7
NA
ND
ND
2.8
Sodium
Nooe
Nooe
None
201
203
NA
179
ND
177
Vanadium
370
7,100
None
35.3
66.6
NA
43.8
46.5
58.2
Zioc
1,300
1,500
None
37.3
41.3
NA
58.1
42.8
44.3
VOLATILE









nROAMC.S.bnc/Kgl









Benzene
3
13
1
ND
ND
ND
0.24
ND
ND
Chlorobeoiene
37
680
1
ND
ND
ND
ND
ND
ND
Elhyl benzene
1,000
1,000
100
ND
ND
ND
ND
ND
ND
Toluene
1,000
1,000
500
ND
ND
ND
ND
ND
ND
Trichloroelhene
23
54
I
ND
ND
ND
ND
ND
ND
Vinyl chloride
2
7
10
ND
ND
ND
ND
ND
ND
Toul Xyleoej
410
1,000
10
ND
ND
ND
ND
ND
ND
*Criteria are determined on a case-by-case basis for inorganics.
rtn'i
-------
Page 2 of 6
Tabic 1
Summary of Detected Contaminants
Drum Removal Action Post Excavation Sampling
SAMPLE in
LABORATORY ID



r7CS-«lt-»04-8L
10SW
r7ylphenol
2.800
10,000
Nooe
ND
ND
NA
ND
ND
ND
2,4-Dimelhylphenol
1,100
10,000
100
ND
ND
NA
ND
ND
ND
Pheool
10,000
10,000
50
ND
ND
NA
ND
ND
ND
~Criteria are determined on a case-by-case basis for inorganics.
nmi
-------
Paje 3 o( 6
Table 1
Summary of Detected Contaminants
Drum Removal Action Post Excavation Sampling
SAMPIJE ID
I.AJIORATORY ID



Travel Bknk
M-CS-ffn-*01-WA
111*4
Trard Bknk
111*5
111M
Trard Bkni
llllt
»7-CM»-0«-5L
1I4S4

Hjvtr

wdmr







UlxW Mrad
KoMMUDM
llfMl ||







CMid ton. CL1ANUP
MM (OIL CLtAMIT
KXldlAMT







cwnu
OUTWA
caimaAi^nLtf *






MTTAIk (mj/K,*









Aluminum
None
None
None
NA
NA
NA
33,000
NA
NA
Anenic
20
20
None
NA
NA
NA
3.9
NA
NA
Barium
700
47,000
None
NA
NA
NA
261
NA
NA
Berylium
1
1
None
NA
NA
NA
1.9
NA
NA
Cadmium
1
100
Nooe
NA
NA
NA
0.41
NA
NA
Ctlcium
None
Nooe
None
NA
NA
NA
6,040
NA
NA
Chromium
None
None
None
NA
NA
NA
43.2
NA
NA
Cobalt
None
None
None
NA
NA
NA
6.3
NA
NA
Copper
600
600
Nooe
NA
NA
NA
30.9
NA
NA
Icon
None
None
Nooe
NA
NA
NA
17,600
NA
NA
Lead
400
600
Nooe
NA
NA
NA
12.2
NA
NA
Ma|Deaium
None
None
Nooe
NA
NA
NA
2.280
NA
NA
Mao|anete
None
None
Nooe
NA
NA
NA
339
NA
NA
Mercury
14
270
Nooe
NA
NA
NA
0.19
NA
NA
Nickel
230
2,400
Nooe
NA
NA
NA
19.3
NA
NA
Po(a»ium
None
None
None
NA
NA
NA
1,340
NA
NA
Selenium
63
3,100
Nooe
NA
NA
NA
ND
NA
NA
Sodium
None
Nooe
Nooe
NA
NA
NA
318
NA
NA
Vaudium
370
7,100
None
NA
NA
NA
71.1
NA
NA
Zinc
1,300
1,300
Nooe
NA
NA
NA
4S.3
NA
NA
VOLATILE









n«CANlCR lmy/Kg»









Benzene
3
13
1
ND
ND
ND
ND
ND
ND
Chlorobcnzene
37
610
1
ND
0.2
ND
ND
ND
ND
Ethyl benzene
1,000
1,000
100
ND
ND
ND
ND
ND
ND
Toluene
1,000
1,000
300
ND
ND
ND
,~JD
ND
ND
Trichloroethene
23
54
1
ND
ND
ND
ND
ND
ND
Vinyl chloride
2
7
10
ND
ND
ND
ND
ND
ND
Total Xylenei
410
1,000
10
ND
ND
ND
ND
ND
ND
~Criteria are determined on a case-by-case basis for inorganics.
M04CtKMK«rmti
-------
r»|e 4 of 6	Tabic I
Summary or Detected Contaminants
Drum Removal Action Post Excavation Sampling
SAMP1£ ID
ijmioratory in
Tool BWak
2*t©«
r7-c»-m-»oTWA
1I1V4
Trtfd Btuk
712*5
»7-GS-0H-»4«-SL
	J1101
Tmd BWik
lllll
*7-C£-«*-«C»-SL
71 454
Hjnrr
n*««
c««i ton. ci-iAffl/r
cxrmiA I ¦«'
BAST/NEUTRAL
Be
Bii(2-Eihyltaeiryl)pbth
Chryieoe
Fluonolbene
lleuchlorobultdicne
2-McJbyln»phlb»lene
N«phlh*lene
Pyrtoe
acid extra cnni.E
0RGAN1CS
4-McJhylphenol
2,4-Dimelhylphenol
Phenol
0.9
0.9
0.66
0.66
49
9
2,300
I
Nooe
230
1,700
2,800
1,100
10,000
Hirmr
llalallalUIIM
Mxl KML CliAJflr
cxrmiA rut
4
4
0.66
3
210
40
10,000
21
None
4,200
10,000
10,000
10,000
10,000
HJVKT
lapwt U 0»wU*<€
mnaiAMir
aumiA	*
'300
30
100
10
100
300
100
100
None
100
100
Nooe
100
50
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
*Criteria are determined on a case-by-case basis for inorganics.
-------
Table 1
Ptgc 5 or 6	Summary of Detected Contaminants
Drum Removal Action Post Excavation Sampling
SAMPLE II)



Trrnrd Bfcni
r7-G*-a»-»W-fL
»7-CS45i-*0*-8L
Tn*d Blank
rj-ct-»s»-n»sL
Trtp Uuk
r7-CS-«5>-«
LABORATORY ID



11451
1I4M
31(37
1ICM
ZJS3t
Z2S44
Z»4I

Hjrxr
Kjtmr
KJtMF








¦ •IMU OkX
Hn
l«f*d u








CoUd (OIL OAANl/T
CaatarftOaajAMJr
•oacuAMvr








CXJTSJUA (Bt/Ij)
aumuiH'U
annu *







MFTAIJI Imf/K,!










Aluminum
None
None
None
NA
17,400
11,100
NA
9960
NA
NA
Artenic
20
20
'None
NA
4.7
4.7
NA
4.3
NA
NA
Barium
700
47,000
None
NA
221
67.6
NA
60
NA
NA
Berylium
1
1
Nooe
NA
1.1
0.71
NA
0.61
NA
NA
Cadmium
1
100
Nona
NA
0.2
ND
NA
ND
NA
NA
Calcium
None
Nods
Nona
NA
2,100
3,090
NA
2000
NA
NA
Chromium
None
None
None
NA
21.6
22.4
NA
20.1
NA
NA
Cotxll
None
None
Nona
NA
6.4
10.2
NA
10.3
NA
NA
Copper
600
600
None
NA
15.3
23.7
NA
21.1
NA
NA
Iron
None
Nooe
None
NA
11.400
23,700
NA
21800
NA
NA
Lead
400
600
None
NA
9.1
1.3
NA
11
NA
NA
Magnesium
None
None
Nona
NA
1.610
3,900
NA
44 30
NA
NA
M*o|ine»e
None
None
Nona
NA
211
221
NA
230
NA
NA
Mercury
14
270
None
NA
ND
0.1
NA
0 09
NA
NA
Nickel
230
2.400
None
NA
12
22
NA
19 3
NA
NA
PoUaiium
None
Nooe
Nooe
NA
439
1,730
NA
1000
NA
NA
Selenium
63
3,100
None
NA
2.9
ND
NA
ND
NA
NA
Sodium
None
None
Nooe
NA
269
213
NA
181
NA
NA
Vuudium
370
7,100
None
NA
72.7
39.4
NA
32.9
NA
NA
Zioc
1,500
1,300
Nooe
NA
34.3
34.1
NA
33.1
NA
NA
VOLATILE










nnOAfflf-s 1^,/v,)










Beucne
3
13
1
ND
ND
ND
ND
ND
ND

Chloiobeuene
37
680
1
ND
ND
ND
ND
ND
ND

Eihyl benzene
1,000
1,000
100
ND
ND
ND
ND
0 140
ND

Toluene
1,000
1,000
300
ND
ND
1.3
ND
ND
ND

TrichJoroe(hcne
2J
34
1
ND
ND
ND
ND
ND
ND

Vinyl chloride
2
7
10
ND
ND
ND
ND
ND
ND

Toul Xylenes
410
1,000
10
ND
ND
ND
ND
0.330
ND

*Criteria are determined on a case-by-case basis for inorganics.
-------
r"e6o"s	Table 1
Summary of Detected Contaminants
Drum Removal Action Post Excavation Sampling
SAMPIF. 10
I-AIIORATOHy in
Travd Bknh
r7-Gs-»)*)inlhr»ceoc
fVcruofb)(luor»nihcoe
Ben2o(i)pyrcne
Bii(2-Chloroclhyl)clhe
Bit(2Eihylhe«yl)phlh
Chryteoe
Ruortolheae
llenichlorobulidiene
2-Methyl naphtha I too
Naphllulrno
Pyrene
ACID EXTRAcmni.E
QRGArtlCS (mi/Kg)
4 Melhylphenol
2.4Dimethylpheool
Phtnol
0.9
0.9
0 66
0.66
49
9
2,300
I
None
230
1,700
2,800
1,100
10,000
Hjrmr
NaUMUIIM
(WMimaiAMf
csrmiA
4
4
0.66
3
210
40
10,000
21
None
4,200
10,000
10.000
10.000
10,000
Hirer
llftd I*
toacLiAmr
arrnuA	*
300
JO
100
10
100
500
100
100
None
100
100
None
100
50
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
ND
ND
ND
Nn
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
0 66
ND
ND
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
ND
NT)
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
NA
NA
NA
0 600
0 044
0 061
0 049
0 049
1
0 048
0 082
0 23
0 0)7
0 064
0 085
12
I 4
0 82
*Criteria are determined on a case-by-case basis for inorganics.
-------
TABLE 2 Listing of Detections Exceeding TBCs in Soil Samples from Refuse Areas
(All results reported in mg/Kg)
Sample ID
Sample Date
Location
Coflipound/Anafyte >
Result
Re$.TBC$
fndus.TJBCs
SSB05102
06/06/96
RA # 6
Beryllium
1.70
1
1
SSB06102
06/06/96
RA #6
Barium
8,380 J
700
47,000
SSB06102
06/06/96
RA #6
Cadmium
3.00
1
100
SSB06102
06/06/96
RA #6
Chromium
188
—
—
SSB06102
06/06/96
RA #6
Lead
1,320 J
400
600
DSB06201
07/15/96
RA #6
Arsenic
31.3
20
20
DSB06201
07/15/96
RA #6
Lead
3,020 J
400
600
SSB06104
06/06/96
RA #6
Beryllium
1.00 J
1
1
SSB06201
07/15/96
RA #6
Lead
2,810
400
600
SSB07102
06/06/96
RA #6
Beryllium
1.10
1
1
SSB08102
06/06/96
RA #6
Lead
7,280 J
400
600
SSB08102
06/06/96
RA #6
Thallium
4.3 J
4
6
DSB08102
06/06/96
RA #6
Lead
559 J
400
600
SSB08104
06/06/96
RA #6
Beryllium
1.10
1
1
SSB12102
06/07/96
RA #3
Beryllium
1.20
1
1
SSB14102
06/07/96
RA #1
Arsenic
40
20
20
SSB14102
06/07/96
RA #1
Cadmium
2.60
1
100
J-qualifter - Estimated value
RA = Refuse Area
TBC = New Jersey Residential and Industrial Surface Soil To Be Considered Criteria (W J.A C. 7.-26DJ
Inorganic TBCs for subsurface soils (104-suffix on sample 10) are determined on a site-specific basis in New Jersey.
Table Revised 10/97
OU-3 ROD
-------
Table 3 Summary of Analytical Results for Soil Samples Collected By ESE
Page 1 of 1


Beneath
Asbestos
Road

rocs








Boring No.
Sample
Depth
ES-1
0-1'
ES-1
3'-5'
ES-2
v-y
ES-2
3'-5*
ES-5
0-1*
ES-5
2'-4'
ES-6
0-1'
ES-6
2*-4'
ES-10
V-2.5*
ES-3
0-8"
ES-3
V-3.5*
ES-4
0-2*
ES-4
2.5'-4.5'
Residential/
Non-
residential
VOL>TlLE;6f
kSANfCSltfyfcfl


mmm*.



Methylene
Chloride
56
29
8
15
13
ND
ND
ND
ND
26
21
22
23
49.000/
210,000
Acetone
ND
ND
ND
ND
ND
NO
ND
ND
ND
40
ND
ND
ND
1,000.000/
1.000.000
Benzene
110
ND
30
ND
42
ND
20
9
ND
ND
ND
ND
ND
3.000/13.000
Toluene
44
ND
11
ND
ND
ND
ND
ND
ND
18
ND
ND
ND
1.000.000/
1.000.000
seHrtTdeXTit
i
1
lM:J
wwh
WornKm
mmm
msem

rg&xrm



Bij(2-
ethylhexyl)
phthaiate
ND
ND
ND
ND
ND
ND
1400
ND
ND
1400
ND
ND
ND
49.000/210 000


mwasm
niinirifmi in
SKW*


mrnm

Aluminum
14.300.00
14.300 00
12.800 00
9.110.00
8.330.00
11.800 00
1.000 00
8.490 00
6.000 00
9.660 00
5.430 00
11.200 00
8.740 00

Arsenic
3 70
2 50
4 80
4 10
1 50
2 80
3.40
ND
ND
370
1 20
1 20
1 50
20/20
Banum
75 50
61.50
28 10
40 30
27 40
64.90
260
34 80
17 00
•57 50
3 60
36 60
30 10
700/47 000
Beryllium
048
0 69
0 26
0.55
0.28
0 73
ND
0 27
0 30
0.34
045
0 58
0 56
1/1
Cadmium
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
1/100
Chromium
21 00
23.70
1240
16 80
1060
21 60
10.80
11 50
960
18 20
13 60
16 40
18 20

Cobalt
6 60
13 30
3.00
660
340
1110
240
3 20
4.10
3.80
7 50
6.10
5 50

Copper
31 80
19.30
13.10
11.70
6.90
19 70
8 50
5 30
8 80
1860
19.90
10.40
12.20
600/600
j Iron
18.300.00
23.500 00
9.460.00
25.700.00
10.700 00
24.600.00
6.440.00
8.000.00
10.100.00
21.300 00
11,000 00
17.400 00
18.500 00

I Lead
74 80
7.80
36 50
3.70
1360
9.60
35 80
4 20
4.20
9360
624 00
7 30
3.70
100/600
H Manganese
251.00
1650 00
44.30
241.00
83.00
586.00
29 50
56 00
62.10
89 10
79.20
6 70
64 30

1 Mercury
2.10
ND
008
ND
ND
ND
0,09
ND
ND
ND
ND
ND
ND
14/270
Nickel
20.70
17.20
7.50
6.90
7.50
19 50
5.90
8.00
7.20
10.40
17.50
9 90
1040
250/2 400
Silver
ND
1 20
ND
ND
0 94
ND
ND
ND
ND
ND
0.90
ND
1 00
110/4.100
Vanadium
39 10
43.90
27 70
37 70
24.40
4390
22 30
17,00
19.60
31.50
26 70
33 80
4050
370/7.100
Zinc
155 00
3940
29 00
26 60
26 70
43 70
22 80
24 00
22 20
72 80
62 90
28 60
27 00
1.500/1 500
NOTES:
Source-T»blc 6-3; ESE, 1992
~ - Duplicate Sample at Location FS-14
ug'Vg « micrograms per kilogram
mg/kg « milligrams per kilogram
ND - Not Detected
mO w NJ Soil Cleanup Criteria. NJAC 7 26E
ROD
-------
Paga 1 of 2
TABLE 4	Summary Statistics for Analytical Detections in Phase II R1 Surface Soil Samples

Total
Total






Number of
1_SOIL(l)
Number of
RSOIL<2)
Number of
EPA Soil Screening

Number of
Number of
Percentage
Minimum
Mean
Maximum
location of
Bkgd
Detections
Surf.Soil
Detections
Surf.Soil
Detections
Levels (SSLa)
Compound/Analyte
Samples
Detections
of Detections
Value
Value
Value
Maximum
Value
Above Bkgd
TBC
> I SOIL
TBC
> R_SOIL
Ingestion
Inhalation
Volatile* (eg/Kg)





l.l.l«Trichloroethane
39
6
l)
3
4
6
SSS23I01
NA
-
1000000
0
210000
0
c
1200000
Acetone
39
3
8
4
12
19
SSBI2I02
NA
-
1000000
0
1000000
0
7800000
100000000
Methylene chloride
39
38
97
3
20
no
STPI6I02
NA

210000
0
49000
0
85000
13000
Trichloroethene (TCE)
39
II
28
4
41
130
SSS23IOI
NA

54000
0
23000
0
58000
5000
S«mi-Voliitil«» (tig/Kg):::




2-methylnaphthalene
31
1
3
96
96
96
STP05102
NA

--
-
-
-
3100000
c
4-chloro- 3-meihylphenol
3t
1
3
50
50
50
SSS2I10I
NA
-
10000000
0
10000000
0
C
c
Acetuphthene
3t
4
II
30
216
630
STP05I02
NA
-
10000000
0
3400000
0
4700000
c
Acenaphihykne
31
5
13
31
67
110
STP19202
NA
-

-
-
..
c
c
Anthracene
39
10
26
22
159
850
STP05102
NA
-
10000000
0
10000000
0
23000000
c •

39
17
44
25
197
1500
STPO5I02
NA
-
4000
0
900

900
c
Benzo(a)pyrene
39
16
41
26
143
690
STP05102
NA
-
660
I
660

90
c
BeniofbWuoranihene
39
17
44
23
192
1500
STP05102
NA
-
4000
0
900

900
c
Benzo(|{.h.i)pcrylefie
31
3
8
45
77
110
SSB08102
NA
-
-
-
-
-
C
c
Bento(h
-------
Page 2 of 2
TABU-* 4	Summary Statistic* for Analytical Detection* in Phase II Rl Surface Soil Samples

Total
Total






Number of
ISOIUI)
Number of
RSOIU2)
Number of
KPA Soil Screening

Number of
Number of
Percentage
Minimum
Mean
Maiimum
Location of
Rkgd
Detections
Surf.Soil
Detections
Surf.Soil
Detections
Uvrls (SSLs)
Com pound/A nalyte
Samples
Detection*
of Detection*
Value
Value
Value
Maximum
Value
Above Bkgd
TBC
> l_SOIL
TBC
> R SOIL
Ingestion
Inhalation
Inorganic* (mg/Kg)





Aluminum
51
51
100
617
14500
124000
STTI7I02
14600
10
»
-
-

C
C
f mimony
SI
5
10
08
20
3 2
SSB08102
ND
5
340
0
14
0
31
C
Arsenic
51
39
76
I 0
8
42
SSS28I0I
2 5
25
20
4
20
4
0
750
Barium
51
51
100
13
299
8380
SSB06I02
37
42
47000
0
700
2
5500
6-X>000
Beryllium
51
40
78
03
09
2 1
SSS2II01
05
34
1
12
1
12
0
1300
Cadmium
51
17
33
03
1 9
11.4
SSS28I01
ND
17
100
0
1
9
78
1800
Calcium
51
51
100
274
41300
161000
SSS2510I
274
47
-

-
-
C
C
Chromium
51
51
100
80
48
240
STPI0IO2
20
31
-

-

390
270
Cobalt
51
51
100
1 6
8 5
29
SSB05I02
5 8
32
-

-

C
C
Copper
46
46
100
4 0
83
532
SSS28lOt
10
39
600
0
600
0
C
C
Iron
51
51
100
2150
34529
373000
STP05I02
19200
19
-
-
-

c
C
Lead
45
45
100
5 2
535
7280
SSB08102
7 3
37
600
6
400
8
400
c
Magnnium
51
51
100
660
1446)
286000
SSS24I01
2150
27
-
-
-

c
c
Mangan^e
45
45
100
20
269
O05
SSBI4201
97
3)
-



c
c
Mercury
51
41
to
0 1
68
50
STP0J102
0 3
25
270
0
14
5
23
10
Nickel
51
51
100
5
79
497
STP03102
II
35
2400
0
250
3
1600
13000
Potassium
51
50
98
76
622
2150
ST* 19202
480
30
-
-

_
C
c
Selenium
51
38
75
08
2 5
18
STP05I02
09
32
3100
0
63
0
390
c
Silver
51
16
31
03
16
80
SSS28IO!
ND
14
4100
0
110
0
390
c
Sodium
51
40
78
46
298
2460
STP05I02
146
32
_
-
_

C
c
Thallium
51
6
12
17
6.7
20
STP05I02
ND
6
6
2
4
3
C
c
Vanadium
51
51
too
II
255
7240
STP05I02
34
17
7100
t
370
2
550
c
Zinc
47
47
100
18
331
3470
SSS28I01
35
37
1500
2
1500
2
2)000
c
Cyanide (mg/Kg)
39
1
3
1 4
1 4
1 4
SSB08I02
ND
1
21000
0
1100
0
1600
c
Totaltmrnhfr of samplesdoes not Include Reacted data
Background sample is SFWot 102
N4 m Ractgromnd value J art not applicable to nrftoiict
h'D • Not Selected
(1)1 SOU. • Nt* Jersey Industrial S"rfact Soil Criteria (S J A C
(2) ft SOU. " Jersey Residential Surface Soil Criteria (S J .1 C
C- information not available.
'¦2«n)
* 2AP)
OU-3 ROD
-------
TABLE 5 Listing of Analytical Detections Exceeding TBCs in Surface Soil Samples
Page I of 2
Sara pit ID
Sample Date
Location
Compound/ Analyte
Result
Unite
Residential TBC
Industrial TBC
SSB05I02
06/06/96
RA #6
Beryllium
1.7
mg/kg
1
1
SSB06102
06/06/96
RA #6
Barium
8380 J
mg/kg
700
47000
SSB06I02
06/06/96
RA #6
Cadmium
3
mg/kg
1
100
SSB06I02
06/06/96
RA #6
Lead
1320 J
m^/kg
400
600
SSB06I02
06/06/96
RA 06
Zinc
2560 J
mg/kg
1500
1500
SSB0620I
07/15/96
RA #6
Lead
2810
mg/kg
400
600
SSB07I02
06/06/96
RA #6
Beryllium
1.1
mg/kg
1
1
SSB08102
06/06/96
RA #6
Lead
7280 J
mg/kg
400
600
SSB08102
06/06/96
RA #6
Thallium
4.3 J
mg/kg
4
6
DSB08I02
06/06/96
.RA #6
Lead
559 J
mg/kg
400
600
SSBI2102
06/07/96
RA #3
Beryllium
1.2 J
mg/kg
1
1
SSBI4102
06/07/96
RA #1
Arsenic
40
mg/kg
20
20
SSBI4102
06/07/96
RA #1
Cadmium
2.6
mg/kg
I
100
SSB29I02
06/21/96
Sile A
Beryllium
1.2 J
mg/kg
1
1
SSB3I102
06/20/96
Site A
Beryllium
1.5 J
mg/kg
1
1
SSB35102
06/21/96
Site B
Beryllium
1.2 J
mg/kg
1
1
SSB35I02
06/21/96
Site B
Cadmium
4
mg/kg
1
100
SSB36102
06/21/96
Site B
Beryllium
1 J
mg/kg
1
1
SSB39102
06.'7 4/96
Sits B
Cadmium
1.2 J
mg/kg
1
100
SSB39102
06/24/96
Site B
Lead
583 J
mg/kg
400
600
SSS21SOI
06/19/96
Site A
Beryllium
2.1
mg/kg
1
1
SSS23101
06/19/96
Site A
Beryllium
2 J
mg/kg
1
1
SSS23I0I
06/19/96
Site A
Cadmium
1.1 J
mg/kg
1
100
SSS24I01
06/19/96
Site B
Beryllium
1.2 J
mg/kg
1
1
SSS25101
06/19/96
Sile B
Beryllium
1.2 J
mg/kg
1
1
SSS26I01
06/21/96
Sile B
Beryllium
1.2 J
mg/kg
1
1
SSS27IOI
06/21/96
Site B ;
Beryllium
1.3 J
mg/kg
1
]
SSS2710I
06/21/96
Site B
Lead
3860 J
mg/kg
400
600
SSS2810I
06/21/96
Sile B
Arsenic
41.8 J
mg/kg
20
20
SSS2810I
06/21/96
Site B
Barium
1420
mg/kg
700
47000
SSS28I01
06/21/96
Sile B
Cadmium
11.4
mg/kg
1
100
SSS28101
06/21/96
Site B
Lead
1120 J
mg/kg
400
600
SSS28I0I
06/21/96
Site B
Zinc
3470 J
mg/kg
1500
1500
J-quolifer " Esumaitd Valut
fL4 m Refuse Area
TBC ¦ New Jersey Residential and Industrial Surface Soil To Be Considered Criteria (NJ.A.C. 7:26D)
Table Revised 10/97
-------
TABLE 5 Listing of Analytical Detections Exceeding TBCs in Surface Soil Samples
Page 2 of 2
Sample ID
Sample Date
Location
Compound/Analyte
Result
Units
Residential TBC
Industrial TBC
STP03102
06/25/96
Site A
Aroclor 1248
510 J
ug/kg
490
2000
STP03102
06/25/96
Site A
Mercury
50.1
me/kg
14
270
STP03102
06/25/96
Site A
Nickel
497
mg/kg
250
2400
STP03102
06/25/96
Site A
Thallium
9.9
mg/kg
4
6
STP03102
06/25/96
Site A
Vanadium
4020
mg/kg
370
7100
STP04102
06/24/96
Site A
Mercury
28.2
mg/kg
14
270
STP05102
06/25/96
Site A
Arsenic
37.1
mg/kg
20
20
STP05102
06/25/96
Site A
Benzo[a]anthracene
1500 J
ug/kg
900
4000
STP05102
06/25/96
Site A
Benzo[a]pyrene
690 J
ug/kg
660
660
STP05102
06/25/96
Site A
Benzo[b]f]uoranthene
1500 J
ug/kg
900
4000
STP05102
06/25/96
Sile A
B enzo(k]fl uoranthene
1000 J
ug/kg
900
4000
STP05I02
06/25/96
Site A
Mercury
27.1
mg/kg.
14
270
STP05102
06/25/96
Site A
Nickel
440 J
mg/kg
250
2400
STP05102
06/25/96
Site A
Thallium
19.6
mg/kg
4
6
STP05102
06/25/96
Site A
Vanadium
7240
mg/kg
370
7100
STP08102
06/21/96
Site A
Mercury
40.2
mg/kg
14
270
STP10102
06/24/96
Site A
Mercury
42.5 J
mg/kg
14
270
STP12102
06/24/96
Site A
Nickel
258 J
mg/kg
250
2400
STPI6102
06/14/96
Site B
Aroclor 1248
1500 J
ug/kg
490
2000
STP16102
06/14/96
Site B
Cadmium
1.4 J
mg/kg
1
100
STP17102
06/13/96
Site B
Cadmium
2.5 J
mg/kg
1
100
STP17102
06/13/96
Site B
Lead
442 J
mg/kg
400
600
J-quohfier ¦ Estimated Value
RA • Refuse Area
TBC ¦ New Jersey Residential and Industrial Surface Soil To Be Considered Criteria (NJ.AC. 7:26D)
Table Revised 10/97
-------
TABLE 6
Summary Statistics for Analytical Detections in Phase II R1 Subsurface Soil Samples
Page 1 of 2

Total
Total






Number of
Residential
Is Maximum

Number of
Number of
Percentage
Minimum
Mean
Maximum
Location of
Bkgd
Detections
Soil
Value Above
COMPOUND/ANALYTE
Samples
Detections
of Detections
Value
Value
Value
Maximum
Value
Above Bkgd
TBC
Residential TBC?
Volatiles (ng/Kg)
Acetone
20
3
is

15
29
SSB33I06
NA
-
1,000.000
No
Methylene chloride
20
18
90

20
61
STP18I04
NA
-
49.000
No
Tnchloroethene (TCE)
20
7
35

14
36
SSB34104
NA
-
23,000
No
Semi-Volatiles (tig/Kg)
1,2,4-tnchlorobenzene
20
1
5
3!
31
31
SFW01106
-v
-
68,000
No
Acenaphthene
20
1
5
26
26
26
SSB04104
NA
-
3,400,000
No
Accnaphthylene
20
1
5
61
61
61
STP2I104
NA
--
-
-
Anthracene
20
2
10
46
67
88
STP21104
NA
-
10,000,000
No
Benzo(a)jnthricene
20
4
20
34
143
280
STP2U04
NA
-
900
No
BenzoU)pyrene
20
4
20
39
152
250
SSB38104
NA
-
660
No
Benzo(b)fluoramhetie
20
6
30
34
118
290
SSB38104
NA
-
900
No
Benzo(g,h,i)pery1ene
20
1
5
59
59
59
SSB08104
NA
-
-
-
Benzo(k)fluoramhene
20
5
25
30
114
240
SSB38I04
NA
-
900
No
Benzyl butyl phthalate
20
1
5
270
270
270
STP18104
NA
-
1,100,000
No
Bis(2-ethylhexyl)phtha1ate
20
20
100
23
336
2,500
STP13104
NA
-
49,000
No
Carbazole
20
2
10
27
30
33
STP21I04
NA
-
-

Chrysene
20
5
25
39
150
330
STP2U04
NA
-
9.000
No
Dibenzo(a,h )anthracene
20
1
5
44
44
44
SSB08104
NA
-
660
No
Diethyl phthalate
20
1
5
32
32
32
STP18104
NA
-
10.000,000
No
Dimethyl phthalate
20
1
5
790
790
790
STP18104
NA
-
10,000.000
No
Di-n-butyl phthalate
20
11
55
21
131
810
STP18104
NA
-
5,700.000
No
Fluoranthene
20
4
20
63
248
550
STP21104
NA
-
2,300,000
No
Indeno( 1,2,3-cd)pyrenc
20
3
15
54
91
110
STP2U04
NA
-
900
No
Naphthalene
20
1
5
72
72
72
SSB34104
NA
-
230,000
No
Phenanthrene
20
4
20
130
165
250
STP21104
NA
-
-
-
Pyrtne
20
7
35
23
144
490
STP21104
NA
-
1,700,000
No
Pestid(!ft5/PCB3( .

4.4-DDD
20
4
20
15
86
290
SSB34104
NA
-
3,000
No
4,4'-DDE
20
5
25
2
41
130
DTPI8104
NA
-
2,000
No
4,4-DDT
20
5
25
4
303
1,300
DTPI8104
NA
-
2,000
No
Alpha-chlordane
20
7
35
4
142
950
SSB34104
NA
-
--
-
Arodor 1248
20
1
5
28
28
28
SSB33106
NA
-
490
No
Aroclor 1254
20
1
5
61
61
61
SSB38104
NA
-
490
No
Dieidrin
20
2
10
6
8
10
STPI8I04
NA
-
42
No
Gamma-chlordane
20
7
35
4
177
1,200
SSB34I04
NA
-
-
-
OU-3 ROD
-------
TABLE 6
Summary Statistics for Analytical Detections in Phase II RI Subsurface Soil Samples
Page 2 of 2

Total
Total






Number of
Residential
Is Maximum

Number of
Number of
Percentage
Minimum
Mean
Maximum
Location of
Bkgd
Detections
Soil
Value Above
compound/analyte
Samples
Detections
of Detections
Value
Value
Value
Maximum
Value
Above Bkgd
TBC
Residential TBC?
Heptachlor
20
2
10
2
29
57
SSB34I04
NA
-
150
No
Inorganics (mg/Kg)
Aluminum
26
26
100
19
20,864
86,600
SFWOI106
86600
0
-
-
Antimony
26
4
15
0.8
6.0
16
STP15I04
ND
3
14
Yes
Arsenic
26
22
85
1.3
117
2.400
SSB33I06
7.9
5
20
Yes
Barium
26
24
92
25
152
952
STP15I04
40
20
700
Yes
Beryllium
26
23
88
04
53
1,200
SSB33106
0.8
13
I
Yes
Cadmium
26
6
23
0.4
5.0
10
STPI5104
ND
5
1
Yes
Ctlcium
26
25
96
414
60,943
1,200,000
SSB33106
931
20
-
-
Chromium
26
24
92
12
34
119
STP-13-I04
22
12
-
-
Cobalt
26
24
92
2.9
11
37
DTP18I04
7.0
13
-
-
Copper
24
21
88
7.8
127
798
STP15104
14
14
600
Yes
Iron
26
26
100
4.9
45,404
225,000
DTP18I04
20800
11
-
--
Lead
24
23
96
3.9
499
5,840
STPI5104
4.8
19
400
Yes
Magnesium
26
24
92
693
53,989
1,200,000
SSB33106
2230
11
-
..
Manganese
24
22
92
22
478
2,550
STP15104
820
2

«
Mefcury
26
10
38
0.1
2.0
8
STP13104
ND
9
14
No
Nickel
26
24
92
7
429
9,400
SSB33106
12
13
250
Yes
Potassium
26
25
96
12
743
1,700
SSB21104
899
8
-
-
Selenium
26
19
73
0.8
2.6
8.3
DTP 18104
1.0
13
63
No
Silver
26
6
23
0.3
3.7
8.7
STP15I04
ND
5
110
No
Sodium
26
19
73
111
206
752
STPI3104
147
14
-
-
Thallium
26
6
23
1.4
6.2
14
STP15I04
ND
5
2
Yes
Vanadium
26
24
92
12
32
48
SSB20I04
39
6
370
No
Zinc
26
25
96
21
604
4,700
SSB33I06
29
19
1,500
Yes
Cyanide
20
4
20
1.3
2.1
32
SSB38104
ND
0
1,100
No
Total number of samples does not Include Rejected data.
Data have been Included for estimated concentrations related to some somple dilutions; this has resulted In some maximum values at or above reporting limits for some inorganic constituents.
Background sample Is highest ¦ 'f S WO 1104 and SFW01106
NA ¦ Background values art not applicable to organlcs
ND " Not Detected
TBC New Jersey Criteria for Residential Soil (N.J.A.C ~:26D)
OU-3 ROD
-------
TABLE 7
Listing of Analytical Detections Above TBCs* in Subsurface Soil Samples
(All results reported in rag/Kg)
Sample tp
Sample pile
location
. Compotm
-------
Page I of I
TABLE 8
Summary or Results for Mercury and Lead Leachability Analyses
of Surface and Subsurface Soil Samples
'r^Sampte ID >?;-
Sampler-
^Datc'?
-V,'/
v. Location^:
i,
•^ontamlnaiftj
isTfital 'Analysis#
i>TCLP.'Result'
in
STPI5104
6/14/96
Site B
Mercury
0.06U
5.0U
200
STP16102
6/14/96
Site B
Mercury
6.2J
5.0U
200
MD-06
6/5/97
Site A
Mercury
19.8
0.33
200
MD-17
6/5/97
Site A
Mercory
10.8
0.20U
200
MD-19
6/5/97
Site A
Mercury
16.0
0.20U
200
MD-21
6/5/97
Site A
Mercury
6.34
0.20U
200
STP15104
6/14/96
Site B
Lead
5.840J
2,300
5,000
STP16102
6/14/96
Site B
Lead
196 J
30.0U
5,000
LD-15
6/11/97
RA #6
Lead
787
254.0
5,000
LD-16
6/11/97
RA #6
Lead
3,400
4,770.0
5,000
LD-17
6/11/97
Site B
Lead
1,150
63.6
5,000
LD-18
6/11/97
Site B
Lead
42.2
50.0U
5,000
LD-27
9/24/97
RA n6
Lead
1,230
165
5,000
U - qualifier = Below method detection limit
J-qualifier = Estimated concentration
RA " Refuse Area
TCLP = Toxicity Characteristic Leaching Procedure - An EPA procedure to determine the potential leachability of a
constituent as specified in the Resource Conservation and Recovery Act (RCRA)
mg/kg = milligram per kilogram
ug/L = microgram per liter
-------
TABLE 9	Summary Statistics for Analytical Detections in Unfiltcrcd Phase 11 R1 Groundwater Samplis	P39© 1 Of 1
(All results reported in ug/L)

Total
Total






Number of
Ground
Number of

Number of
Number of
Percentage
Minimum
Mean
Maximum
Location of
Bkgd
Detections
Water
Detections
Compound/Analyte
Samples
Detections
of Detections
Value
Value
Value
Maximum
Value
Above Bkgd
ARAR
> ARAR
Votatitw








Benzene
16
3
19
2.1
2.4
2.8
SGS03I01
NA
-
l
3
Chlorobenzene
16
2
13
1.5
2.3
3.0
SGS03101
NA
-
5
0
Methylene chloride
16
16
100
1.5
2.8
5.6
SES04101
NA
-
30
0
Trichloroethene (TCE)
16
1
6
1.8
1.8
1.8
SGS10101
NA
-
I
1
ScmkVotetiie*










Bis(2*thylhexy1)phthalate
16
5
31
3.1
14.6
350
SES0310I
NA
-
30
1
PesiieWel/FCBs









Alpht-BHC
15
1
7
0.11
0.11
0.11
SGS10101
NA
-
0.02
1
B«o-BHC
IS
1
7
0.03
0.03
0.03
SGS1010I
NA
-
0.2
0
Delta-BHC
IS
1
7
0.01
0.01
0.01
SGS10101
NA
-
-
-
Inorganki











Aluminum
8
8
100 .
102
1685
6160
SES02101
1860
8
-
-
Arsenic
16
3
19
6
8
10
SGS06101
ND
3
8
1
Barium
16
16
100
14
69
137
SGS10101
102
16
2000
0
Beryllium
16
1
6
1.6
1.6
1.6
SE503101
ND
1
20
0
Calcium
16
16
100
6790
45705
106000
SGS10101
20300
16
-
-
Chromium
14
3
21
4
13
25
SGS0610I
ND
3
100
0
Cobalt
16
8
50
1.4
6
19
SGS06101
3.8
8
-
-
Copper
16
13
81
1.4
13
50
SGS09101
15
13
-
-
Iron
IS
15
100
53
76S4
40300
SES03I0I
4670
15
-
-
Lead
12
3
25
4.8
6.1
7.1
SGS06101
6.4
3
15
0
Magnesium
16
16
100
3710
11961
39000
SGS06I01
7790
16
-
-
Manganese
7
7
100
27
507
I860
SGS0610I
1060
7
-
-
Mercury
16
7
44
0.11
0.37
0.79
SGS02101
ND
7
2
0
Nickel
16
11
69
4
14
39
SGS0610I
7.2
11
100
0
Potassium
16
16
100
520
2746
6720
SGS01101
! 100
16
-
-
Sodium
16
16
100
3050
14164
36300
SGS06101
5560
16
-
-
Vanadium
16
14
88
1.4
10
30
SES03101
88
14
-
-
Zinc
15
15
100
9
32
93
SGS08I01
31.9
15
5000
0
Total number of samples does not Include Rejected data
FW-OI is the background well
NA ¦ Background values are not applicable to organic?
ND - Not Delected
ARAR ¦ Sew Jersey Ground Water Quality Standards NJ.A.C. ~:9-6
OU-3 ROD
-------
Table 13 ~ Human and Ecological Contaminants of Concern*
Environmental
Concern
Analyte
Medium
Site-Specific
Cleanup Goal
Site-Specific Cleanup Goal Source
Human Health
Risk
Lead
Surface Soil
218 mg/kg
NOAA ER-M Screening Guideline for Sediment Quality
Ecological Risk
Barium
Surface Soil
700 mg/kg
NJ Unrestricted Use (formerly Residential) Direct Contact Soil Cleanup Criteria
Cadmium
Surface Soil
1 mg/kg
NJ Unrestricted Use (formerly Residential) Direct Contact Soil Cleanup Criteria
Chromium
Surface Soil/Sediments
370 mg/kg
NOAA ER-M Screening Guideline for Sediment Quality
Lead
Surface Soil
218 mg/kg
NOAA ER-M Screening Guideline for Sediment Quality
Mercury
Surface Soil/Sediments
1 mg/kg
NOAA ER-M Screening Guideline for Sediment Quality
Thallium
Surface Soil
4 mg/kg
NJ Unrestricted Use (formerly Residential) Direct Contact Soil Cleanup Criteria
Vanadium
Surface Soil/Sediments
370 mg/kg
NJ Unrestricted Use (formerly Residential) Direct Contact Soil Cleanup Criteria
Zinc
Surface Soils
1,500 mg/kg
NJ Unrestricted Use (formerly Residential) Direct Contact Soil Cleanup Criteria
* When determining cleanup goals, the more stringent value contained in an identified ARAR or TBC source was utilized.
Table 14 ~ Summary of Guidance Values and TBC Criteria Considered in Selection of the Site-Specific Cleanup Goals for Lead and Mercury
Analyte
Site-
Specific
Cleanup
Goal
Medium
OU-3 -
Surface Soil
Background
Concentration
(based on
Phase II RI
data)
NOAA
ER-M
Screening
Guidance
for
Sediment
Quality*
NOAA
Adverse
Effects
Threshold
(AET) for
Sediment
Quality*
New Jersey
Unrestricted
Use (formerly
Residential)
Direct
Contact Soil
Criteria
New Jersey
Restricted Use
(formerly
Industrial)
Direct Contact
Soil Criteria
EPA
Residential
Scenario
Soil
Screening
Level (SSL)
Region III
BTAG
Screening
Level for
Soil
RCRA Action
Levels -
TCLP & UTS
Lead
218
mg/kg
Surface
Soil
7.3 mg/kg
218 mg/kg
300 mg/kg
400 mg/kg
600 ing/kg
400 mg/kg
0.01 mg/kg
TCLP 5.0 mg/L
Mercury
1 mg/kg
Surface Soil
/Sediment
0.3 mg/kg
0.71
mg/kg**
1.0 mg/kg
14 mg/kg
270 mg/kg
23 mg/kg
(ingestion)
10 mg/kg
(inhalation)
0.06 mg/kg
(fauna)
TCLP 0.2 mg/L
UTS 260 mg/kg
•Basis for establishing site-specific cleanup goal. A cleanup goal is defined as a medium-specific numerical concentration established as a operable-unit specific
remedial action objective considered protective of human and ecological receptors for an exposure route. Protectiveness may be achieved by reducing exposure.
**ER-M Value was rounded up to the next whole number for the site-specific cleanup goal value
TCLP -Toxicity Characteristic Leaching Procedure
UTS - Universal Treatment Standard
-------
Table 15 Summary of Ambient Asbestos Air Monitoring Results from January through December - Great Swamp National Wildlife Refuge*
Page 1 of I

Base

OU-3 Site A

OU-3 Site D

Blanks

EPA
Sampling Dale
I
2
3
4
5
6
7
FBI
FB2
LB
S c d .H
	
Feb. 15. 1996
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
f /nn?
Feb. 21, 1996
ND
7.7 t/mm2.
0.011 Dee"
ND
ND
ND
ND
ND
ND
ND
ND

Feb. 27, 1996
ND
ND
ND
ND
ND
ND
ND
ND
ND
7.7 0mm2,
NA 0ccA

Mar 4, 1996
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

Mar 10, 1996
ND
ND
31.0 C/mm2,
0.0053 Pee
ND
ND
ND
15.4 Cmm2,
0.0026 Dee
ND
ND
ND

Mar 16, 1996
ND
ND
ND
IJ.4 Pmm2,
0.0021 Dec
ND
15.4 0mm2.
0.002S Dec
ND
ND
ND
ND

Mar 22, 1996
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

Mar 28, 1996
ND
ND
ND
ND
ND
ND
9S.9 I/mm2.
0.0250 Dee
7.7 I7mm2,
NA Oee
15.4 Dmrra,
NA Dec
ND

Apr 3, 1996
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

Apr 9, 1996
ND
15.4 Pmm2,
0.0056 Pee
ND
ND
ND
ND
ND
ND
ND
ND

Apr 15. 1996
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

Apr 21,1996
ND
ND
ND
ND
ND
ND
ND
ND
15.4 I7mm2,
NA Dee
ND

Apr 27 through May 3, 1996
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

May 9,1996
ND
IJ.9(7mm2,
0.0029 Pee
ND
ND
ND
ND
ND
ND
ND
ND

May 15 through July 2,1996
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

July 8. 1996
ND
ND
ND
ND
ND
3I.O|r/mm2,
0.00$4 Vce
ND
ND
ND
62 Omml,
HA Dec

July 14, 1996
ND
31.0 Pmm2,
0.0053 Pee
ND
ND
ND
ND
ND
ND
ND
ND

July 20 through Dec 31, 1996
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

f/mm2 - fibers per square millimeter
f/cc » fibers per cubic centimeter
NA - no volume of air was sampled (blank filter), therefore there is no conversion to f/cc.
*	- All detections of asbestos are chrysotile fibers except for one detection of amosite fibers (A).
*	• " Laboratory unable to achieve required analytical sensitivity due to insufficient volume of air sampled; sample received wet due to rain/snow.
A " Asbestos type detected was amosite.
Samples from the following dates were not analyzed, but have been archived: 8/19, 8/31,9/12,9/24, 10/6, 10/18, 10/30, 11/11, 11/23, 12/5, 12/17,and 12/29.
USFV/C30I XLS 4/JW7 « 03 AM
-------
APPENDIX III
ADMINISTRATIVE RECORD INDEX
-------
USFWS Operable Unit 3 of the
ASBESTOS DUMP SUPERFUND SITE
ADMINISTRATIVE RECORD INDEX
TITLE OF DOCUMENT
DOCUMENT
DATE
DATE PLACED
IN FILE
DATE OF
UPDATES
Fred C. Hart Associates, Inc. Draft
Remedial Investigation study for the
Asbestos Dump Superfund Site,
Morris County, NJ
5/29/87
8/8/96

McLaren/Hart Environmental
Engineering Corp. Revised Draft
Supplemental Remedial Investigation
Work Plan for the Asbestos Dump -
Dictzman Tract Site Operable Unit 3,
Millington, NJ
11/18/91
8/8/96

Environmental Science &
Engineering, Inc. Site Assessment
Report Operable Unit 3 - Asbestos
Dump Site (Dietzman Tract)
GSNWR, Morris County, NJ
3/92
8/8/96

Brown, K.W., et al. Expert Report for
the Dietzman Tract
5/14/92
8/8/96

Foster Wheeler Environmental Corp.
Phase II Remedial Investigation Work
Plan and Attachments, Final, Version
3.1
7/1/96
8/8/96

Fact Sheet 1
12/1/95
9/13/96

Fact Sheet 2
5/1/96
9/13/96

Fact Sheet 3
9/1/96
9/13/96

EPA Comments on Draft Phase II
Remedial Investigation Wok Plan
5/20/96
8/8/96

USFWS Action Memorandum for the
Removal at the LAAs (includes both
the ACOE Statement of Work on
Removal and the Limited Action
Areas Site Characterization Report
9/1/96
9/13/96

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

Amendment 001 to the ACOE
Statement of Work on LAA Removal
Actions
9/12/96
9/24/96

Amendment 002 to ACOE Statement
9/27/96
10/10/96

-------
TITLE OF DOCUMENT
DOCUMENT
DATE
DATE PLACED
IN FILE
DATE OF
UPDATES
of Work on LAA Removal Actions



Preliminary Review of ARARS and
AOC's of the Asbestos Dump
Superfund Site, Great Swamp
National Wildlife Refuge
March 1996
10/10/96

U.S. Army Corps of Engineers,
Kansas City District, Design Analysis,
Removal of Asbestos Containing
Materials in the LAAs
September 1996
1/28/97

U.S. Fish and Wildlife Service
Review of the Presence of
Endangered or Threatened Species in
the Great Swamp National Wildlife
Refuge
10/1/96
1/28/97

Foster Wheeler Environmental Corp.-
Supplemental Sampling at LAA's
10/96
1/28/97

U.S. Army Corps of Engineers,
Kansas City District, Removal of
Asbestos Containing Material in the
LAA's Modification of Contract
11/18/96
1/28/97

Fact Sheet 4
11/96
1/28/97

Foster Wheeler Environmental Corp.-
Supplemental Sampling at the Conroy
Property - Indoor Air Monitoring
12/96
1/28/97

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

Fact Sheet 5
2/97
5/19/97

EPA Comments on Draft Phase II
Remedial Investigation Report
3/27/97
6/5/97

Fact Sheet 6
5/97
5/19/97

Foster Wheeler Environmental Corp.
Pilot Treatability Study for Water
Management OU-3 of the Asbestos
Dump Superfund Site, Technical
Memorandum, GSNWR, Morris
County
5/97
9/19/97

EPA Comments on Draft Feasibility
Study Report
5/19/97
7/7/97

EPA: Superfund Technical Assistance



-------
TITLE OF DOCUMENT
DOCUMENT
DATE PLACED
DATE OF

DATE
IN FILE
UPDATES
Grant (TAG) Handbook(s):
• Applying For Grant
9/93
5/19/97

•	Managing Your Grant
•	Procurement - Using TAG Funds
4/94
4/94
5/19/97
5/19/97

• The Application Forms with
9/93
5/19/97

Instructions



EPA: Guidance for Community



Advisor>' Groups (CAGs) at
Superfund Sites
• A Quick Reference Fact Sheet
2/13/97
5/19/97

• Guidance Document
2/14/97
5/19/97

Foster Wheeler Environmental Corp.
5/97
6/5/97

USFWS Final Remedial Investigation



Report for the Asbestos Dump
Superfund Site, Operable Unit 3 -
Volumes I, II, & III



SEA Consultants Inc./Foster
6/97
7/7/97

Wheeler Environmental Corp.



USFWS Final Feasibility Study
Report for the Asbestos Dump
Superfund Site (OU-3) and Three
Areas of Concern, Volume I - Report,



Volume II - Appendices



Hanscomb Engineers - Value
6/24/97
8/12/97

Engineering Report



Fact Sheet 7
8/97
8/27/97

IT Corporation Final Action
Memorandum for Drum Removal
8/97
8/27/97

Action Site A



Rapid Response Risk Reduction Work
Plan
7/97
9/19/97

Foster Wheeler Pre-Design Data
9/97
9/19/97

Report, Volumes I & II



IT Corporation Letter Work Plan for
Drum Removal Oversight and ACM
Delineation
9/97
9/29/97

EPA Comments on Proposed
1/15/98
3/3/98

Remedial Action Plan



Action Memorandum for Removal
2/98
12/5/97
2/10/98
Action at Operable Unit 3/Site B and



Limited Action Areas



USFWS Proposed Plan for the
12/97
12/10/97

-------
TITLE OF DOCUMENT
DOCUMENT
DATE
DATE PLACED
IN FILE
DATE OF
UPDATES
Asbestos Dump Superfund Site
Operable Unit 3



Fact Sheet 8
12/97
3/2/98

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

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

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


Fact Sheet 9
5/98
6/98

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

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






-------
APPENDIX IV
STATE LETTER OF CONCURRENCE
-------
of
Christine Todd Whitman
Governor
Department of Environmental Protection
Robert C, Shinn, Jr.
Commissioner
JUL 3 1 m
U.S. Environmental Protection Agency
Region 2
290 Broadway
New York, NY 10007-1866
Attn:
Re:
Jeanne M. Fox, Regional Administrator
Millington Asbestos Dump
Operable Unit 3
Dear Ms. Fox:
This is in regard to the Record of Decision (ROD) for the
Millington Asbestos Dump, Operable Unit 3 (OU3), located in Harding
Township, Morris County, New Jersey.
The New Jersey Department of Environmental Protection ((NJDEP),
Site Remediation Program, has reviewed the following selected
remedy:
1.	Access improvements;
2.	Long-term drainage improvements, and short-term erosion
control measures;
3.	Drum removal activities (which were completed in
September 1997 as a time-critical, non-emergency removal
prior to implementation of the preferred alternative),
including post-excavation and waste classification
sampling;
4.	Removal and off-site disposal of lead contaminated soils
(completed, Spring 1998);
5.	Consolidation of Site B Asbestos-Containing Material
(ACM) into Site A (completed, Spring 1998);
6.	Placement of a biotic cover over Site A;
7.	Implementation of institutional controls to ensure the
continued integrity of the drainage and cover activities
(e.g. limiting visitor access to daylight hours,
prohibiting other than passive uses such as hiking, bird
watching and photography); and
8.	Assessment of wetland impacts and wetlands restoration.
This is to advise you that NJDEP concurs with the selected remedy
as being protective of human health and the environment.
Sew Jersey is An Equal Opportunity Fmpioyer
Recycled Piper
-------
Tharik you for
process.
;unity
Shmn
participate in the Superfund
John Berry, Assistant Secretary,
Krista Doebbler, USFWS, USDOI
Helen Shannon, USEPA
Carlton W. Bergman, NJDEP
Dept. of Interior
-------
APPENDIX V
RESPONSIVENESS SUMMARY
-------
APPENDIX V
RESPONSIVENESS SUMMARY
ASBESTOS DUMP OPERABLE UNIT 3 SUPERFUND SITE
INTRODUCTION
A responsiveness summary is required by Superfund policy. It provides a summary of agency
and citizens' comments and concerns received during the public comment period. It also
provides the United States Department of the Interior's (DOI) responses to those comments and
concerns. Al! comments summarized in this document have been considered in DOI's final
decision for selection of a remedial alternative for the Asbestos Dump Operable Unit 3 site.
OVERVIEW
Public response to the preferred alternative has been generally positive. Responses from DOI,
acting through the United States Fish and Wildlife Service (USFWS), to the concerns expressed
both at the public meeting and as written submittals during the public comment period are
provided below. A transcript of the public meeting is provided in Attachment A and a copy of
all written comments submitted during the public comment period has been provided in
Attachment B.
BACKGROUND ON COMMUNITY INVOLVEMENT
USFWS sought to be very sensitive to the community concerns about OU-3 and activities
taking place at GSNWR. As a result, USFWS provided extensive information to local, state
and federal regulators, neighboring communities and other interested parties during the course
of the RJ/FS process. Information was provided through informal information sessions,
briefings, periodic mailings, one on one discussions, a hotline administered by USFWS
personnel and media coverage. In addition, USFWS hosted three "Open Houses" in May 1996,
February 1997 and May 1997.
The questions expressed at the three Open Houses included technical issues such as data
collection procedures, additional discharge impacts to the Great Swamp because of proposed
expansion of upstream point and non-point source contributors, the effects of water level
fluctuations on the physical properties of asbestos, and clarification of remedial alternatives
under consideration. In addition, the open houses provided an opportunity for interested parties
to comment on concerns regarding staging area visibility and quality of contractors and sub-
contractors on the project. Many of these concerns were addressed by field activities and all
were considered during appropriate phases of the project. Many of the concerns expressed at
these earlier gatherings were repeated at the Public Meeting on December 17, 1997, for which
responses are provided below.
i
-------
SUMMARY OF COMMUNITY RELA TIONS ACTIVITIES
USFWS has conducted an ambitious community relations program throughout this project.
Activities related directly to information distribution and public comment are described below.
A more comprehensive history of community relations activities is provided in the body of the
Record of Decision.
The RJ report, FS report, and Value Engineering report were placed in public access
repositories during the month when each report was finalized. May, June and July 1997,
respectively. The Proposed Plan for the site was released to the public for comment on
December 12, 1997. These documents are available to the public in the administrative record
file at USFWS Liaison office at GSNWR, the EPA Docket Room in Region II, New York and
the information repositories at Long Hill Township Free Public Library, 91 Central Avenue,
Stirling, NJ and the Harding Township Kirby Municipal Building, Town Clerk's Office, Blue
Mill Road, New Vemon, NJ. The notice of availability for the above-referenced documents
was published in the Newark Star-Ledger on December 10, 1997. Public comments on these
documents were accepted from December 12, 1997 to February 27, 1998.
On December 17, 1997, USFWS conducted a public meeting at the Green Village Volunteer
Fire Station, Green Village, New Jersey, to inform local officials and interested citizens about
the Superfund process, to review current and planned remedial activities at the site, and to
respond to any questions from area residents and other attendees. A transcript of the public
meeting is provided in Attachment A.
In addition, six letters were received during the public comment period, including a request for
an extension of the public comment period. The extension was granted for a period of 30 days.
Responses were prepared and incorporated into the ROD responsiveness summary. Copies of
the letters can be found in Attachment B.
A summary of comments from the public meeting, written comments received during the
comment period and after the close of the extended comment period, and DOI's responses, is
provided below.
SUMMARY OF COMMENTS AND RESPONSES
Oral and written comments received from stakeholders and NJDEP are summarized below
along with DOI's responses. The comments are organized in the following three categories:
Proposed Remedy (Proposed Plan), Superfund Process/Procedural Issues, and Miscellaneous.
Proposed Remedy (Proposed Plan):
-------
Comment 1: A resident asked how the consolidation of waste would physically be completed
at the site. Another resident asked a similar question and requested clarification regarding the
condition of the 55-gallon drums which were removed from Site A, particularly with regard to
their potential impact on groundwater.
Response: The purpose of consolidation at Site A is to relocate small, scattered deposits of
ACM to one central location, minimize the footprint of the remaining asbestos area to be
covered (Site A), and minimize impacts on surrounding wetlands. Rather than cover those
areas where ACM exists only to a depth of two to three feet at the periphery of Site A, the plan
calls for excavation and relocation of that fringing ACM to the central area of Site A. Also, the
small volume of ACM from the unimproved access road (UAR) , Site B, and Refuse Area it I
would be placed beneath the "biotic barrier" within the remaining Site A area, so that only one
cover will be required. This will minimize necessary maintenance and inspection to a single
location, rather than several independent areas. Following the relocation of the ACM and
removal of lead-impacted soil and debris from Site B and refuse areas, the excavated areas will
be graded to a smooth surface and revegctated with grasses native to the Refuge.
Impacts to groundwater from drums buried at Site A were demonstrated to be negligible.
Based on analytical results from post-excavation soil sampling conducted at the time of the
drum removal action, there were no significant leaks from the drums which might pose a
continuing source of contamination to the site groundwater. These observations and findings
are summarized in the Risk Reduction Final Report (IT Corporation, 1997) documenting the
drum removal activities. The report has been made part of the Administrative Record for this
Record of Decision.
Comment 2: A stakeholder questioned the discussion of the results of the drum removal
interim action.
Response: The drum removal was undertaken to remove potential hazardous wastes from the
site. The scope was to identify and locate potential drums and remove them while
minimizing the amount of disturbance of ACM to avoid unnecessarily increasing the risk
from airborne asbestos. The removal action was undertaken as a risk reduction step that
addressed the potential for releases of contamination before any catastrophic incidents
occurred. The only absolutely certain way to determine there are no remaining drums
containing hazardous wastes would be to excavate the entire mound. However, doing that
would elevate the short-term inhalation risk substantially, raise the risk of a release of
asbestos into surrounding surface water, and be prohibitively expensive. Remedial designs
will take into account all known site conditions so that appropriate design data are available
for completing the final design package.
The drum removal activities are summarized below from the detailed information presented
in the Immediate Response Action, Rapid Response Risk Reduction Final Report prepared
by IT Corporation (IT), on behalf of the U.S. Army Corps of Engineers, dated December
1997. This report was released after the preparation of the Proposed Plan and therefore the
information was unavailable at the time.
-------
The combined geophysical work performed al the site (Foster Wheeler - January 1996 and IT
- August/September 1997) identified a total of 127 anomaly locations based on a modeling of
magnetic and other survey data. An anomaly is an interpretation of the magnetic or other
geophysical readings that suggests a buried mass of metal over a size threshold which could
represent a drum. Ninety-nine (99) of the 127 anomaly locations were selected for
excavation because the potential mass of metal that each was modeled to contain exceeded
recorded readings in excess of 400 kilograms. The excavations, numbering EX00I to
EX0085, often covered more than one anomaly and were prioritized sequentially. The
excavations were generally performed in order of the decreasing magnitude observed. The
last twelve test pits (EX074 to EX085) encountered only minimal amounts of metal, no
drums and no visible contamination, and became the justification not to continue the
excavations lor smaller potential masses of metal. Therefore, the remaining 28 anomaly
locations were not excavated because it was determined from excavation results that drums
were not likely to be present in the remaining lesser magnitude anomalies. 207 drum
carcasses were removed, of which 69 contained product. Fifty of those drums were
subsequently determined to contain RCRA characteristic hazardous waste and were properly
disposed of as hazardous. Substantial amounts of varied scrap metal debris, including auto
and bus bodies and a bulldozer, were also retrieved from the site and properly disposed of
ofT-site. An additional 19 55-gallon drums containing investigation derived wastewater were
also disposed of off-site.
Comment 3: NJDEP requested that the phrase "Excavation of Other Waste" be added to the
summary description of Alternative 3 in Table 2 of the Proposed Plan.
Response: This phrase has been added to those passages in the ROD where Alternative 3 is
described in order to clarify all activities which comprise the alternative.
Comment 4: Several residents asked for clarification regarding the term "institutional controls
and monitoring" that were evaluated for Alternatives 2, 2A, 3 and 4. One resident specifically
asked if these controls are intended to be activities in perpetuity or short term. A second
resident asked if the monitoring program specifics would be provided.
Response: Institutional controls for a site may encompass a variety of passive controls and
management practices, including access restrictions, land use restrictions, easements or deed
restrictions. Several ARARs already afford the site institutional controls not usually available
to typical Superfund sites. Institutional controls specifically envisioned for OU-3 would be
developed in detail during the design phase and refined during the preparation of the Site
Operations and Maintenance (O&M) Plan. The USFWS wishes to maintain institutional
controls that are consistent with the rest of the surrounding Wilderness Area. Proposed controls
would allow visitor access to the site during proscribed daytime hours for activities such as bird
watching, hiking, and photography. However, visitor amenities which were present in the past
such as a parking lot, trail heads and stream crossings would not be re-established. Monitoring
includes surface water and biota sampling as is the current Refuge practice. Groundwater
monitoring of the shallow aquifer will also be performed at locations and on a schedule to be
determined during the remedial design. During the construction phase of the selected remedial
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alternative, air sampling will also be conducted to ensure adequate control of asbestos during
consolidation and containment activities. USFWS is required to plan for a 30-year monitoring
program, however much of the proposed monitoring is already integral to the existing USFWS
Refuge Management Plan, such as upstream/downstream water sampling and biota sampling,
and is expected to be an important element of the O&M Plan into the indefinite future. The
final plan for the site will be submitted to EPA for review and approval and will be made
available as part of the public record.
Comment 5: A resident asked for clarification regarding revegetation of the covered area in
Site A. Specifically, the resident was interested if the native species there now would be
allowed to revegetate the area, and whether the proposed planting would allow for wildlife
habitat in the future.
Response: The final design for the biotic barrier will include a wetlands restoration component
that will specify wetland species consistent with the natural vegetation on the site perimeter
where it transitions to wetland and upland species over the upper cover area. However, to
ensure that the integrity of the biotic barrier is not compromised by intrusive root systems, only
shallow rooted species will be reintroduced. Long-term monitoring will include routine
inspection of the cover, and if necessary, controls such as mowing and pruning will be
employed. The wetland habitat will be consistent with the surrounding area, and consequently
the wildlife habitat is not expected to be impacted, and in fact some enhancement is expected.
Comments 6 & 7: A resident commented on the fact that ten local communities in the
immediate area have enacted rigorous ordinances or standards regarding activities that might
impact the swamp. The resident was concerned that USFWS and their contractors
implementing the selected remedy be in compliance with local groundwater and surface water
protection standards. Primary concern focused on potential impacts to groundwater quality in
the area, since many residents rely on private wells for potable water.
Response: The ARARs analysis and selected remedy work plans and design will consider
regulatory requirements at all government levels. Furthermore, the selected remedy does take
into account that there are numerous private domestic water wells in the vicinity of the
GSNWR, although most or all are in an up-gradient or side-gradient location relative to OU-3
(see discussion in the Summary of Site Characteristics section of the ROD).
Private wells in the area were not at risk from the uncontrolled site and will not be adversely
impacted by these remedial actions. Shallow groundwater was sampled from the site and
analyzed during the Phase II Remedial Investigation (Foster Wheeler, 1997) and again during
dewatering tests and prior to the drum removal action. Results were compared to the most
stringent applicable drinking water standards (NJAC 7:9-6). Metals detected in groundwater
were below state guidance criteria and asbestos with fibers greater than 10 microns in size was
not detected during the Phase 11 RI in any of the site monitoring wells, despite the fact that
some of the wells were screened in ACM. Removal of lead-impacted soil (Spring 1998) has
addressed groundwater quality issues from leachable metals. Two hundred and seven 55-
gallon drums were removed from Site A, of which 50 contained some organic and some metal
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wastes. Post excavation sampling from soils beneath drums removed from the site indicate that
leakage from the drums was minimal, where it was detectable at all (IT Corporation, 1997).
In addition, the detectable contaminant concentrations (all of which were below or just slightly
above guidance criteria for drinking water) were detected in shallow groundwater, the upper
water bearing zone, which is not used as an aquifer and directly discharges to surface water.
Due to a thick confining layer of clay in the area, private wells screened below this layer in the
deeper aquifer are not likely to be impacted by site contaminants. The selected remedy will
protect groundwater quality through removal of lead-impacted soils at Site B, removal of
drums containing Resource Conservation and Recovery Act (RCRA) hazardous wastes from
Site A, and containment of other wastes with a biotic barrier. Although these source control
activities have been demonstrated to be protective of groundwater quality, groundwater
monitoring of the shallow aquifer will be performed as part of the site O&M plan.
Comment 8: EPA and a stakeholder expressed concern that groundwater monitoring was not
explicitly identified as a component of Alternative 3. The stakeholder also suggested that
insufficient data exists in regard to assessing the need for future groundwater monitoring.
Response: The FS recommended the need for additional environmental testing and
determining the nature of the ACM waste and associated drummed material at Site A. Since
then, USFWS has been actively collecting data at the site, and the selected remedy for OU-3
is consistent with the analytical results that have been observed since the FS was prepared.
The additional analytical testing has been summarized in the Predesign Data Report (Foster
Wheeler, September 1997) and the Rapid Response Risk Reduction Final Report (IT
Corporation, December 1997). Key information collected after the FS and Value
Engineering study has been included in summary tables in Appendix II of the ROD.
In summary, the data which was reviewed relative to the need for post-remediation
groundwater monitoring includes aM data collected (pre-Phase II RI, Phase II R1 and post-
Phase II RJ), such as:
•	monitoring wells sampled before and during the Phase II RI,
•	monitoring wells sampled in August 1997 prior to the drum removal action,
•	analytical testing of water pumped from temporary well points during the June
1997 dewatering pilot test,
•	surface and subsurface soil samples collected before, during and after the Phase
II RI,
•	lead leachability at Site D, as determined through TCLP analysis,
•	leachability tests for mercury on surface soil samples collected in June 1997 prior
to drum removal activities,
•	analytical tests of the excavated drum contents, dewatering water, and post-
excavation soil samples taken from test pits from the drum removal interim
action during September 1997.
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When considered collectively, all of this additional data indicates that source control through
drum removal has been successful. The post-drum excavation samples did not indicate
exceedances above NJDEP residential soil standards or soil impact to groundwater standards.
Furthermore, it was determined (Foster Wheeler, May 1997, September 1997) that the refuse
material and soil from Site B and RA#6 demonstrating elevated lead levels above 218 ppm
or failing TCLP testing would be removed for ofT-site disposal, which has now been
completed. The mercury in surface ACM/soil at Site A is not leachable to groundwater in
concentrations above RCRA toxicity characteristic critera and is not being considered for
off-site removal (see also discussion in Summary of Site Characteristics - sections on Site
Soils and Contaminant Fate and Transport in the ROD).
The additional information collected to date, coupled with the presence of a thick confining
clay layer below the site indicates that impacts to groundwater from OU-3 are negligible.
The hydrology at the site does show strong interaction of shallow groundwater within the
Site A ACM mound with the surrounding surface water and low probability of interaction
with groundwater in the deeper aquifer below the site. An effective monitoring program for
the shallow Site A groundwater can be designed for the points of recharge from and
discharge to the surrounding surface water and therefore surface water monitoring will be
made part of the O&M for OU-3. Sampling in this fashion would help to monitor for
impacts from upstream sources which we know the GSWA is very concerned about. In
response to concerns about groundwater quality, however, shallow aquifer groundwater
monitoring will be performed. More details about O&M sampling specifications will be
developed during the remedial action work plan and remedial design phases.
Comment 9: A resident expressed concern that even non-friable asbestos be controlled during
construction activities, as handling could allow some release of asbestos due to deterioration.
The resident asked if air monitoring for asbestos would be part of the selected remedy.
Response: The construction phase of the selected remedy will include appropriate controls to
ensure air-borne asbestos is minimized and migration in surface water in contained. On-site air
monitoring will be a component of the construction plan. Once asbestos and ACM have been
consolidated and covered, and is therefore no longer accessible, air monitoring will be
discontinued, but surface water and biota sampling will be ongoing.
Comment 10: In an oral comment, a resident requested additional information regarding the
nature and permanence of the biotic barrier proposed for installation over the ACM and debris.
The resident expressed concern that erosion or material failure will allow release of the
underlying material to the environment. A written comment submitted by a resident also
concerned the nature of the proposed barrier, and expressed skepticism that the proposed biotic
barrier would be sufficient to protect human health and the environment. The resident
particularly was concerned about exposures to children or animals due to digging or burrowing
activities. The resident proposed that the asbestos-containing material at the site be
permanently removed.
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Response: The biotic cover will be an engineered design with multiple components and
specifications selected for their durability and performance, and there will be long term
maintenance. The design will include specific requirements regarding final slope of the cover
and vegetative growth to minimize erosion. In addition, the selected remedy includes drainage
controls which are specifically designed to minimize potential erosion around the periphery of
the cover. The synthetic high permeability filter fabric employed in the biotic barrier design
will be a warranteed material which must meet engineering specifications. The biotic barrier
itself is intended to be permeable, since the ACM is inert and will not mobilize in groundwater.
Given the inert nature of the ACM and potential buoyancy problems that would be associated
with an impermeable cap, USFWS has elected to place the permeable biotic barrier over Site
A.
Long-term monitoring outlined in the selected remedy includes periodic inspections of the
cover to identify potential damage or intrusion from either vegetation or burrowing wildlife.
Corrective actions in response to observed deficiencies will be outlined in the long term O&M
plan.
The Feasibility Study and independent Value Engineering Report both recommended this
option, as meeting the necessary criteria outlined in the Record of Decision Alternatives
Analysis.
Since no mercury was found above the RCRA action levels (TCLP or UTS) which would be
classified as RCRA hazardous waste, the mercury-contaminated soil and ACM waste mound to
be covered in place at the site would not be considered a RCRA hazardous waste landfill and is
not subject to RCRA capping requirements. The only material which exceeded either criteria
was the single drum of mercury contaminated waste removed and disposed of as hazardous
waste during the Phase II RI which was reported to contain mercury at 318 mg/kg (sample
SWS0210I).
Comment 11: A stakeholder posed several design related questions about cover specifications
and topographic configurations of Alternative 3. Also, they asked for additional explanation of
future public access limitations and requested reconsideration of restoring the Great Brook
channel close to its natural configuration by removing the temporary culvert system.
Response: With regard to the design related details, it is premature to provide substantial
details at the Proposed Plan stage, however, there will be ample opportunities to review and
comment upon the designs during the remedial action work plan and detailed design phases.
The final cover design for Site A will include minimum soil covers, erosion control features,
minimum slope requirements and vegetative cover that will minimize the potential for
erosion, and will be reviewed and approved by KPA. In accordance with ARARs, USFWS
will also develop an O&M Plan that includes periodic visits to the site to investigate signs of
erosion and take corrective action.
Future public access to OU-3 will be consistent with the Refuge Management Plan of the
Wilderness Area. IJSFWS is considering a more natural appearing crossing that is more
consistent with a wilderness environment such as a ford or system of stepping stones.
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Comment 12: A resident requested additional information regarding precautions to be taken in
order to ensure that material brought onto the site as part of the biotic barrier materials is clean.
Response: Design phase construction documents will include specifications regarding quality
control requirements for the cover material. The contractor will be required to provide
analytical results to document that the material is clean, and otherwise meets the engineering
specifications, prior to delivery of the material to the site.
Comment 13: A resident requested additional information regarding how asbestos was
classified in regards to the cost estimate developed for the alternatives analysis.
Response: Asbestos is not a RCRA-specified hazardous waste, however, it is classified as a
special waste which requires specific handling and disposal procedures in accordance with
federal regulations 40 CFR 61.150, 40 CFR 61.154 and New Jersey regulations NJAC 7:26-2A
and 7:26-6. The cost estimates were developed using estimated quantities, current price quotes
from disposal contractors, and cost data from recent actions conducted at the refuge.
Comments 14& 15: In an oral comment, one resident asked what the immediate hazards of the
site are, and why there is a need to remediate it now, versus using the Alternative No. 1, which
calls for no action. The comment was in reference both to the value of the risk reduction and
the cost of implementing the selected remedy. A written comment from two residents also
urged the selection of the "no action" alternative, citing cost and the lack of discernible existing
long term health effects on individuals who have resided in the area over an extended period of
time.
Response: The ecological baseline risk assessment for the site demonstrated that there are
existing or were potential (leaking drum contents) adverse impacts to wildlife species at the site
due to the presence of a number of metals. The selected remedy specifically addresses impacts
to wildlife through design criteria for the biotic barrier which will minimize exposure to the
ACM and debris remaining on-site. The human baseline risk assessment demonstrated potential
impacts due to the presence of lead. Asbestos was deemed to pose no inhalation risks under
current conditions, but could pose future risk to human health or the environment. Similarly,
the biotic barrier will protect human health from potential future risks due to inhalation.
The selected remedy is required to meet the requirements for remedial actions set forth in
CERCLA § 121, 42 U.S.C. § 9621. Accordingly, the remedy must: be protective of human
health and the environment, achieve a level of control of the site contaminants that attains the
ARARs identified for the site, be cost effective, utilize permanent solutions and alternative
treatment technologies as practicable, and reduce the toxicity, mobility or volume of the site
contaminants. Implementing the "No action" alternative does not meet these criteria, as
described in the RI/FS and Proposed Plan. Through the alternatives analysis described more
fully in the FS, Alternative No. 3 was demonstrated to best meet all of the selection criteria.
Comments 16 & 17: A resident asked if the conclusions resulting from the risk modeling for
the site, and ultimately the choice of Alternative 3 as the selected remedy, were weighted in
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favor of human health, or was the mission of the GSNWR given priority as it relates to the
protection of wildlife? In related comments, NJDEP requested that ecological clean-up
guidance values be added to the table of Contaminants of Concern (Table 4 in the Proposed
Plan) along with the NJDEP residential soil criteria; a stakeholder group also had comments
about the content of Table 4 - Human Health and Ecological Contaminants of Concern.
Response: The baseline risk assessment was conducted in order to demonstrate what the
impacts would be to human health as well as the environment, including wildlife, if no action
was taken to remediate the site. The risk assessment conducted during the RI phase of the
project indicated that there was relatively greater potential risk to the ecological receptors on
site than there would be to human receptors. Protection of the ecological receptors was
therefore an important element of the alternatives analysis. That evaluation included
consideration of the Refuge mission regarding protection of wildlife. The selected remedy
specifically addresses impacts to wildlife through design criteria for the biotic barrier which
will minimize exposure to the ACM and debris remaining on-site. Table 13 of the ROD
reflects the contaminants of concern for both human and ecological receptors. The Table was
adapted from Table 4 of the Proposed Plan, and amended to show ecological guidance values
as well as residential soil guidance values established to protect human health.
The intent of the Proposed Plan is to provide a short synopsis of pertinent site information
and present the preferred alternative for the public's review. Not every detail in the
administrative record can be included in this summary in the spirit of brevity. Table 4 of the
proposed plan provides a brief summary of the contaminants of concern (COC) that were
addressed in greater detail in the RI (Foster Wheeler, May 1997) and FS (SEA/ Foster
Wheeler, June 1997). An expanded table summarizing the contaminants of concern relative
to human health and ecological risk criteria is provided in Appendix II of the ROD.
Furthermore, lead was determined to be the only COC posing potential risk to human health
based on the extensive baseline risk assessment performed as part of the RI phase. The risk
assessment is presented in Chapter Six and Appendix H of the Final RI Report (Foster
Wheeler May 1997).
Comment 18: A stakeholder group expressed the need to reconsider whether future risks
have been reduced because of the drum removal action and called into question the
characterization of several man.-, ials and contaminated media at the site.
Response: Following drum removal from Site A and lead-contaminated soil removal from
Site B and RAU6, materials potentially classified as a hazardous waste will have been
removed from OU-3. ACM is not characterized as a hazardous waste but is considered a
special waste. Groundwater sampled from monitoring wells screened within the mound
which has slightly exceeded ARARs previously is expected to come into compliance without
continued contributions by releases from drum sources which have been removed. The
mercury in surface soil (ACM) at Site A has been shown not to be potentially classified as a
characteristic hazardous waste through TCLP tests and will be brought into compliance with
NJDEP soil cleanup criteria and sediment guidance levels through capping.
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In regard to the potential risk from the possibility of remaining buried drums and the
elevated levels of mercury at Site A, see also response to comments 2. 6, 7, 8, and 19.
Comment 19: A stakeholder expressed concern that the topic of mercury contaminated surface
soils was not adequately discussed in the Proposed Plan with regard to the need for removal of
potential hot spots.
Response: As a follow up to the recommendations made in the FS, USFWS has taken steps
to clearly delineate the extent and potential lcachability of the elevated mercury levels found
at Site A during the Phase II RI and Pre-Design Data Report investigation. The mercury
delineation was done on a grid to determine overall distribution as well as follow-up "hot
spot" samples from suspected areas of elevated mercury. "Hot spots" were considered to be
areas of elevated mercury in soil or waste where the mercury was found to be leachable at
levels above the RCRA TCLP criteria (0.2 mg/L) or where it might exist at concentration;
above the RCRA universal treatment standard (UTS) (260 mg/kg) (40 CFR 268.40 Subpart D
Treatment Standards). When the pre-phase II Rl data and Phase II RI data are combined
with the grid sampling and potential hot spot sampling, the sampling density across Site A is
substantial. To address potential hot spots specifically, the follow-up samples (MD-13, 14,
and 15) were collected in June 1997 from the area where ruptured drums containing
mercury-contaminated wastes (up to 318 mg/kg mercury) were removed during Phase II RI
in 1996. In two of the three samples, mercury was reported as not detected. In the third
sample, a detectable concentration of mercury was reported at only .522 mg/kg.
Furthermore, the analytical results from the post-excavation samples from the drum removal
can now also be considered which also indicate no mercury hot spots exist on site.
Summaries of the data collected is provided in Appendix II of the ROD. Collectively, the
data indicates that the mercury is not leachable to groundwater and therefore no hot spots are
present on Site A which merit removal or addressing in a fashion other than capping the site
with a biotic barrier to prevent direct human and biological exposure and to prevent erosion
into surrounding wetlands and surface water bodies.
Comment 20: A resident asked about future use limitations on the site. Was the site going to
be returned to a condition that would allow passive activities such as bird watching, or would
the site be restricted from visitor use in perpetuity?
Response: Sec Response to Comment 4, 5 and 11. Furthermore, the intent of the selected
remedy is to allow the site to become accessible to visitors for these kinds of activities. The
Refuge Management Plan already restricts access to some areas of the Wilderness Area in
order to protect the wildlife and environmental resources. The access restriction referred to as
possible "institutional controls" is not intended to eliminate visitor foot traffic on open trails,
but rather will likely relate to activities that could potentially damage the biotic barrier. The
remedial design and O&M Plan will ultimately stipulate the nature and extent of access
restrictions in concert with the Refuge Management Plan. As a result, the end use of the site
will be consistent with the existing plan for the Wilderness Area.
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Comment 21: A stakeholder requested additional explanation of the disposition of the ACM in
the UAR.
Response: As part of the remedial design, the USFWS plans to reduce the footprint of Site A,
since it is located within an environmentally sensitive area. However, current design allows for
final disposition of the ACM at the IJAR (approximately 520 cubic yards) within the
consolidated materials al Site A.
Comment 22: A stakeholder pointed out that comments on asbestos remediation are included
in the comments on the removal action.
Response: The public comment period for the Proposed Remedial Action Plan (PRAP) closed
in February 1998, after the Removal Action Work Plan for Site B had been finalized. The
Work Plan will be part of the public record, although public comments are not being taken as
part of the ROD. However, confirmation sampling at Site B following the removal action for
lead-contaminated soils demonstrated that asbestos remediation at the one percent level has
been achieved.
Comment 23: NJDEP requested that the RAO for prevention of contamination spreading be
expanded to include the phrase "during and after remedial activities."
Response: This has been added to the RAO discussion in the ROD.
Comment 24: In a written comment, the Passaic River Coalition, a local watershed association,
expressed support for the selected remedy and urged the USFWS to move forward with the
project.
Response: USFWS agrees with this comment and is pleased that Passaic River Coalition
concurs with the selected remedy.
Superfund Process/Procedural Issues
Comment 25: A resident requested clarification regarding the implementation schedule for the
selected remedy. When does the 15 month timeframe identified in ti Proposed Plan begin?
Response: The 15 month estimated time for completion of implementation for the selected
remedy was calculated from the end of the public comment period. The remedial action will
commence following public notice of the ROD, and is expected to be completed within
approximately six months. The ROD was submitted to EPA for review in early April, and it is
anticipated that the ROD will be signed in August. In order to take advantage of the naturally
lower waters at the Site during the summer months, the Remedial Action is planned for
Summer 1998.
Comment 26: Several residents requested clarification regarding the funding mechanism for
the 30 year O&M costs reflected in the Proposed Plan. I low were the costs developed and how
will USFWS ensure that the money will be available in the future?
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Response: O&M costs are based on engineering estimates of net present value, calculated for a
30 year period assuming a four percent growth rate and seven percent interest rate. The cost
breakdown Is provided in Table 28 of Appendix K in the FS (SEA, 1997). The 30-year period
is a typical requirement of Subtitle C. and Subtitle D landfills and the USFWS is obligated to
fund the program. USFWS funding, as with all federal agencies, is determined on an annual
basis and is subject to congressional appropriation. The details of the funding requirements
will be described in the O&M plan once the remedial action has been designed and is
completed.
Comment 27: NJDEP requested clarification regarding the discussion of Alternative 3's effect
on mobility, toxicity, and volume of waste.
Response: The discussion in the ROD has been modified to clarify this issue.
Comment 28: NJDEP requested more explanation of the estimated costs of components of
Alternative 3.
Response: The discussion in the ROD has been modified, but the difference pointed out by
NJDEP is for two separate elements. The $600,000 in the Draft Action Memo is for Drum
Removal only, while the $4,182,374 is for the total remediation package of Alternative 3.
Comment 29: NJDEP noted that USFWS' schedule for Alternative 3 is very aggressive. They
recommended relaxation of the schedule to accommodate unanticipated delays.
Response: USFWS understands NJDEP's suggestion, but has deliberately planned a schedule
to take into account measures to minimize short-term and overall impacts to the Refuge and
stakeholders while designing and implementing the selected remedy. Several of the ARARs
require minimizing short-term impacts. In order to do this, and because of the seasonal nature
of the wildlife nesting and migration habits and Refuge water management practices for forage
and weed control, compressing the schedule is desirable. Furthermore, funding considerations
also encourage completing the remedy as quickly as is reasonable and safely done.
Comment 30: The EPA and a resident asked if the NJDEP concurs with the selected remedy.
Response: Written comments received from NJDEP are provided in Attachment V. DOl
response to these comments are provided herein. NJDHP comments on the Proposed Plan were
generally limited to requests for additional clarification on issues discussed in the Plan, but
were in agreement with the alternative selected. DOl responses to the comments provided by
NJDEP have been incorporated into the Responsiveness Summary, and where appropriate,
clarifications have been incorporated into the relevant sections of the ROD. The additional
information requested by NJDEP was available in documents that are part of the
Administrative Record for the Asbestos Dump Site, and do not represent new data or new
information not otherwise available in prior documents. NJDEP concurrence is indicated in the
comments as well as its concurrence letter (Appendix IV).
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Comment 31: A resident asked about the nature of the Army Corps of Engineers involvement
in the project, both as a permitting agency for wetlands issues and as a contractor party to the
actions taken to date at the site. In particular, the resident requested clarification about the
permits that may be necessary for the dewatering, drainage improvements, etc. which are part
of the selected remedy.
Response: The State of New Jersey has been delegated authority to administer the Clean Water
Act Section 404 Permit Program which includes criteria for evaluating impacts to waters and
wetlands of the U.S. The USFWS is required to substantively comply with all permit
requirements related to these activities. The involvement to date from the Army Corps has not
been in the capacity of a permitting agency, but strictly as a contracting agency. However, the
Army Corps is also obligated to meet the permitting requirements, as would any other
engineering firm or construction contractor.
Miscellaneous Questions
Comment 32: EPA acknowledged that it was still required to send a supporting letter to DOI
for the Proposed Plan. EPA also reserved its final remedy approval until after review of the
Draft ROD.
Response: USFWS acknowledges EPA's procedural requirements and the sequential nature of
many of the CERCLA process steps.
Comment 33: A resident requested clarification regarding how the 100-ycar flood plain
elevation was established. In addition, the resident asked if there was adequate information
available regarding surface water elevations at the site and the frequency or extent of
fluctuations during storm events.
Response: The 100-year flood plain was established based on Soil Conservation Service
mapping and work done by Apgar Consultants in the 1980's (Apgar, 1983). The 100 year
flood elevations were confirmed based on detailed recent investigation of the hydrology, based
in part on data provided by visual gauges and electronic monitors to gauge water surface
elevations at multiple locations throughout the site. The area experienced a 100-year storm
evert in October 1996, prior to deployment of the monitors, but observations from several
sources indicate that the flood elevations estimated are appropriate.
Comment 34: A resident commented on her interest in seeing the selected remedy for OU-3 fit
into an overall regional plan to protect GSNWR, particularly given potential upstream sources
of contaminants.
Response: The hydrology of the site as influenced by upstream inflows and downstream
discharges was considered in the selected remedy and will be considered during remedial
design. The OU-3 site is on the National Priority List and as such is under a regulatory
mandate for remedial action. The remedy was selected in accordance with the requirements of
CERCLA and the NCP. Other regional issues may be addressed through other action's separate
from the remediation of OU-3.
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Comment 35: Several residents raised issues regarding oilier upstream land uses or
contaminant sources outside of OU-3 or GSNWR which they believe might have impact on the
GSNWR.
Response: As indicated by USFWS at the beginning of the public meeting, the purpose of the
meeting was to allow residents and interested parties to comment on the results of site
investigations, the proposed plan and selected remedy for OU-3. Comments unrelated directly
to these issues are not within the scope of the proposed remedial action and USI WS has no
direct response to these comments.
Comment 36: NJDEP had some comments regarding the Draft Action Memorandum for Site
B Removal Action. They requested specifically that the ACM cleanup criteria be identified.
Response: USFWS excavated Site B to less than one percent asbestos, as documented by
laboratory analysis of post-excavation samples.
Comment 37: NJDEP stated that it found the OU-3/Site B actions acceptable.
Response: USFWS is pleased NJDEP concurs with this planned set of actions.
Comment 38: NJDEP has requested post-excavation sampling at Site B and other sites or
placement of "Declaration of Environmental Restrictions" on the sites if there are levels of
residual contamination above acceptable levels.
Response: The removal action at Site B and the OU-3 Refuse Areas included post-excavation
soil sampling for lead and asbestos. Proposed actions at other sites not in OU-3 are not part of
the OU-3 ROD. USFWS expects that the removal actions will address contamination
effectively to manage future risk. Management of the Refuge areas will be cognizant of
conditions in the future and will adapt its management plans and practices accordingly to
minimize future risks to employees, visitors, and biota.
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APPENDIX V
RESPONSIVENESS SUMMARY
ATTACHMENT A
TRANSCRIPT OF PUBLIC MEETING
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PROSPOSED PLAN FOR THE ASBESTOS DUMP
SUPERFUND SITE OPERABLE UNIT
December 17, 199
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Pi
P)
HI N RE:
IS] PROPOSED PLAN FOR THE ASBESTOS :PUBLC
DUMP SUPERFUNO SITE OPERABLE UNfT: HEARING
|8] NO. 3.
m
GREAT SWAMP NATIONAL WILDUFE REFUSE.:
PI MORRIS: COUNTY, NEW JERSEY
w
WadnMdty, D*c*ntf»r 17,1997
110]	Qraan Vfcgt Fin D«p«rtm»nt
529 Otmo VKoga Road
[11]	Otmti Vtaga, New J«n«y
7:30 p.m.
t'Z)
im PRESENT:
(U) SYDNE MARSHALL PTtD
lotiar WTiatlT Environmental Corporation,
(15] For tfw U.S. dapartmanl of th« Weflof,
U.S. flsh A WHS* Service
[18]
BILL KOCH, Managar
[17] Great Swamp National WUt Rafuga
[i(] PAUL COSTELLO, SEA Corttutanl*
[19]	ICAISTA DOEB8LER, Propel Manager
U.S. Fbh and WfcMe Service
[ZO)
[21]
P2]
TAYLOR & FRIEDBEHG
[23] C«flfflea Shorthand Reporters
120 Washington Street
124]	Morrlnown, NJ 07960
973-285-M11
[25]
W
Pl MR. KOCH: Good evening and welcome.
Pl My name is Bill Koch. I'm the manager of the
Pl Great Swamp National Wildlife Refuge.
Pl I want to thank you all for taking timi»
m out of your busy holiday schedule to be here
{7] tonight for us to be able to present to you and
m have you comment on the preferred alternative, the
1»1 preferred option for cleaning up the asbestos dump
[ioi site on the Great Swamp National Wildlife Refuge,
in] The site is located on the east side of
(i2| Long Hill Road in HardingTownship on the former
[1*1 Dietzman tract, and - and that's about all I'm
(14) going to get into at this point.
[is] I would like to turn the program over
[itj to Sydne Marshall, who is the community relations
(in specialist for Foster Wheeler Environmental, one
[iq of our contractors to the Fish and Wildlife
it«i Service. Sydne.
poi MS. MARSHALL: Okay. Welcome again
pt) this evening. We're glad that you came. We're
pz) glad we have a nice turnout tonight.
I23I I thought I would first son out by,
I24] number one, hoping and asking that you have all
I25i signed in. You've signed the sheet coming in. If
Pag«;
Pag® a
CI
PI you have not signed it, please sign it on your way
[3| out.This way we can keep people informed, keep
HI you on the mailing list; if you're not already on
(5) the mailing list, we can add your name.
Pi I thought I would start out just by
m summarizing some of the community relations
m activities that U.S. Fish and Wildlife Service has
n sponsored basically over the past couple of years.
(iq It seems that they have really made an effort to
lit] be active and to ay to incorporate comments from
(iz) the community all along the way.
[U| First of all, they have set up two
(14]	information repositories, one in the Long Hill
[15]	Township free public library, and one at the
[1*1 HardingTownship municipal building. And I hope
(17] that some of you have taken time to go there, to
(iq look at all of the various documents that are pan
[ibj of the public record that relate specifically to
120] this project.
tnj There have been periodic meetings with
[22] local officials and telephone calls with people.
[23j They've been monitoring community concerns by
(24]	telephone and by sponsoring three open houses,
(25]	which we've had here in the past at this fire
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Page 4
Ml
p; station. One - the first was in May of 1996, the
p; second was in February '97, and the previous
Hi meeting to this was in May '97.
$ This, in fact, is the ooiy meeting that
m U.S. Fish and Wildlife Service was required to
n have for the public. It comes at a time when the
m proposed plan is available for - the proposed
pi plan with the remedies, possible remedies for OU-3
io) is available for public view. And they very much
hi want your input on the proposed plan,
iz] We're looking for comments from you.
m You'll notice there is a court reporter here.Any
i<] comments that you make will be part of the public
is] record. And, of course, there will be a
iq responsiveness summary that follows this meeting,
it] and will, in fact, incorporate any responses to
m comments that come in in the mail, also, to U.S.
is) Fish and Wildlife Service. Ultimately, all of
wi this information will be incorporated into the
?i] record of decision, and will be made available for
si public view when it is completed,
nj I have been asked to set the ground
?*! rules for tonight. I guess I'm the meanest guy on
2S] the project or something. We are hoping that if
Page 6
(1)
pi document as a whole, but I'm not sure they'll get
m individual responses to the comments.
hj MR. COSTELLO: It's an appendix.
is] MS. MARSHALL: Okay.And that will
ps] become part of the what we call the responsiveness
[7] summary.
r If you don't feel comfortable making a
n comment this evening, if something occurs to you
Mq in the future, you have until January 16 to send
(it] in written comments.We do have forms in the
(iz) front for written comments. You don't have to use
(ii] a form, you can just write something down on a
114] piece of paper and send it in. It will be mailed
MS] to Kris Doebbler in Colorado.The address is on
no the sheet that is available in the outer room
Ii7) there.
(m Okay. I'm now going to now turn over
[i»i the meeting to Paul Costello, who is here with us.
[20] He is working from SEA Consultants. He's been
1211 assisting Foster Wheeler Environmental in
122] preparing the feasibility study, and in preparing
[?3] the proposed plan, and he's going to summarize and
{Ml describe to you the various alternatives that are
125] right now under consideration.


Page S
•'I
31 you have comments to make, that you will stand up
ni or you can sit if you're loud enough, but the
u) important thing is for us to hear your name and if
5] you could please then spell your name after you
m said it so that the court reporter can get it
7] accurately.
i] We are hoping very much that the
ir, discussion tonight will focus solely on OU-3.
si That is the purpose of this meeting. We know
i| there arc other concerns that y?u folks may have,
7i and there will be other opportunities in the
i] future to discuss those concerns, but the
i) discussion tonight will be limited to OU-3.We're
3 going to be fairly strict about that,
c; I think at this point we will - I'm
7] sorry.Written responses to comments,
r MR. KOCH; Will everybody's comments be
responded to in writing?
31 MS. MARSHALL: Individually7 I 'hint
i) I'm going to defer to Kris about it.
r. MS. DOEBBLER; My understanding is that
j] we have to prepare a document that is actually
«] called written response to comments.
»i MS. MARSHALL: It will appear in the
Page 7
Ml
Pi MR. COSTELLO: Thank you, Sydne.
Pi Does everyone have a copy of the
Hi proposed plan? Would you like one? We have some
|sj up here. I'll be referencing this document
n verifying and defining some points.
[7] A VOICE: Do you have enough?
It] MR. COSTELLO: Oh, sure,
m MS. DOEBBLER: Briefly, while Paul is
(ioi getting ready here. J just wanted to reiterate
in] what Sydne had said earlier about our public
M2) involvement process, and let you know this
Mi) certainly will not be the end of our public
(i4] involvement process. We'll continue to keep you
(iq informed as best we can. We '11 continue to send
M*i out our fact sheets, and whenever necessary,
t<7] whenever an activity is coming up, we are always
|tq happy to hear from anyone. And I'd like Robin
(is) Burr - right there, Robin is our local community
m site liaison.He has a real nice presentation
pi] he's prepared that he can bring over to show you
122] or your organization at any time, and he's always
ptf available to do that. And give him a call. His
(34j number, I think, most of you probably have it or
PS) it's in the proposed plan. Julie knows it by


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P«9*»
PI
pj heart. But I do appreciate you all being here and
Pi continuing to be a pan of our process. It's been
w a really good experience for us to work with this
is] community.
m MR. COSTELLO; Thanks, Kris.
(7] MR. KOCH: Excuse me one moment.This
m is Kris Doebbler, the project engineer with the
iq Fish and Wildlife Services, Environmental and
[io| Facility Compliance Branch. Recently - that's
in! the new title. It used to be the service
[ill pollution control offices.They have greater
pq responsibilities. So if you had noticed that
[14] change in the office that Kris worked for, same
MS] person, just a little more responsibility and
[i«] reorganization.
[i7] MS. DOEBBLER: My supervisor Billy
[m Umpstead may have cards with the updated address.
[19]	MR. UMPSTEAD: Yes, I do. And this is
[20]	my boss, Paul Camp.
pi] MS. DOEBBLER: We're all here.
123 MR. COSTELLO: All set?
[23]	MS. DOEBBLER: Yes.
[24]	MR. COSTELLO: Thank you. It's a
[25]	pleasure for me to be here. My name is Paul
P«9« i;
pi
P) report.
m The value engineering report generally
Hi substantiated the feasibility study. In general,
pi the feasibility study concluded that there is a
n wide range of alternatives to address this site,
(7) ranging from a "no action" alternative, which is
n required under CERCLA that we at least look at,
iq and then several other alternatives that generally
lio) ramp up the activities to clean up the site,
in] If you look at page 3 of the proposed
[in plan, in the upper right-hand comer, those
lug alternatives are presented in the proposed plan,
[u] Alternative No. 1, as I said, is a "no
[is] action" plan.
pq Alternative No. 2, ramps up the
1171 activities a little btt rrwre. It requires
pq institutional controls to limit access to the
pq site, putting up fences, putting up warnings, and
po) monitoring the site, generally, the surface water
pi] in the biota, the animals surrounding the site.
1221 That would allow for some protection, however, it
pq doesn't generally address the issues at the site.
P4] Alternative No. 2A addresses the same
pq things, but also looked into the removal of the


PagaS
PI
[2] Costello. I've been working on this project for
PI the last couple of years with Foster Wheeler. And
[4| Mark Griswold, Foster Wheeler's project manager is
[5) in the audience as well. We have been working
m very closely in the last couple of years.
|7] The last time we met at the open house
m in May was to present the conclusions from our
m feasibility study. Many of you may have been
pq here.The feasibility study was conducted in
M'I accordance with federal regulation to present the
Ii2j contaminants of concern at the site, define what
in all the limits of waste may be, define what the
(i4) objectives of the cleanup would be, present a
(is) screening of available technologies to address
pq those concerns, and outline some alternatives to
[i7] clean up the she.
pq After that feasibility study was
pq completed. Fish and Wildlife Services assembled a
pq team of Independent engineers and environmental
pi] scientists, seven in total, and that feasibility
(22] study underwent an independent value engineering
psi study.That document was completed the month
P4| after we met with you, and that document is right
psi here.That is called the value engineering
Pag* r
PI
PI potential drum problem that we had at the site.
[q That work has actually been conducted by the Corps
[4] of Engineers, and that work has been completed.
isi We addressed that problem early on as a
iq recommendation in the feasibility study because of
[7] the potential threat that that posed. As a
[*i result, 250 drums were removed from the she a few
[q months ago.
fiq Alternative 3 then looked at some of
pi] the other problems. It called for the drum
pq removal action, and then containing the asbestos
pq problems at the site, controlling the surface
1*4] water, preventing the surface water from eroding
pq away the cap on top of the asbestos. So
pq protecting the public health and the environment
[17] even further.
pq In addition, that alternative called
pq for monitoring of the site in the future. So that
m once that - the asbestos was somewhat contained,
pi] Fish and Wildlife Services would monitor the
pq surface water and the biota and to make sure that
pq over the years that remedial action was doing what
P4] it was designed to do.
pq Alternative No. 4 went a step even


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Pag® 14
|i)
P) further and looked at excavating out ill of the
p; material at the she and putting it someplace on
H) site at another location. And this - for this
is] alternative, the material would be hauled and put
l«i on i liner so that there would be even more
n protection than the situation that may be out
m there now.
m Alternative five was the last
pc, alternative. We looked at excavating the stuff
;• 1; totally, and sending it to a facility that's
g<3 permitted to handle it.
|ir, The feasibility study also recommended
114; that we look at removing the drums, and that's
(is) been done. But also said that, you know, we can't
ee] make a decision on these things until we get some
ti7] more information.The feasibility srudy
(in recommended that additional surface water,
1101 groundwater sampling be undertaken to get a better
pq feel for any potential leaching of that material
pi) in the future. It also looked at characterizing
[22] the asbestos to see if It could be treated in
p3] place, just to get more information.As a result,
i?<) m September, all that data, that's sizeable, was
r?s] presented in this predesign data report.Tim's
Ml
pi that the remedy is performing as designed. You
r>] have to look at a reduction of toxicity, mobility
w and volume. In other words, that materials aren't
(5] leaching into other sources that may cause
(si potential harm to the public or the environment,
m It has to be implememable.You have to be able
m to construct it.The cost and state acceptance,
n The final reason why we're here tonight
!|ioi is the public acceptance. It has to be accepted
;iti| by the public, which is the purpose for this
|ii7l meeting this evening,
i[1 j) Just briefly, to talk about the third
imi alternative, the drums have been removed from the
Nisi sfte.The remaining material is
iici ? proposed plan in a nutshell is recommending.That
m Alternative No. 3, the cost of each of these
(23) alternatives, if you look at table No. 6, as I
P4| said, each one of these alternatives looked at
(2S) remediating the site further - further and doing
we'll plant vegetative material, whatever, species
along the edges and tightly seal the top to make
it compatible to the wilderness area. Each one of
those layers has a filter fabric in-between it so
these materials can't get cross - cross into each
Page 12 - Page IS C61
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Page 16
PI
Pi different things.Alternative No. l.for example,
[31 the $95,000 solution, off site removal of all of
Kl this materia) at the tiibe we prepared this report
is) was $ 15 million. However, in the past couple of
m weeks the price for shipping asbestos off site has
[7] been driven even higher.That may even be higher,
(i) That would have to be looked at.
m But we're recommending alternative No.
iioi 3 that has a price tag of about $4 million, and
lug that work is scheduled to be done,implemented
jizi over a year to 15 months. So with that said, I'll
lis] rum the floor back over.
l<4j MS. MARSHALL: We would like to open
!Tj this up now to any comments that you may have on
OS] the proposed plan and OU-3.
117) Yes. Can you state your name please.
l
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Paga 20
(I!
P) There is very infrequent access to the site by
Pi biologists and people from the refuge and
Hi trespassers and visitors to the site. So the
is] amount of exposure they would have is very
Pi limited. So based on the current conditions,
pj there's - there is very little risk to visitors
l*; to the site.
rsi So Lhe risk modeling that was done was
Co; based on more impact demonstrated through the
[i 11 sampling process to the variety of species that
P7] modeled up the food chain to the predators
lias Predators were impacted more by the lead and the
[hi mercury at the site if nothing was done.
[is] Alternative 3 would, basically,address
lie; that by covering the materials so that none of the
(it; animals would be directly exposed to it.And
in; that's how they would be put in contact with the
ps; soil materials which had the mercury, the lead,
po] and even some other metals. So if we covered it,
pi; they cannot burrow in it, via - does not eat
m prey, herons eating frogs that will be swimming.
to they re not going to be in contact with it, and,
p<> therefore, that will address, that remedy will
[25i address that alternative condition.
Page 21
!'•
p; MS. FENSKE: Okay.Thank you.
p; MS. MARSHALL: Yes, sir.
Hi MR. STILLINGER: My name is Frank
Pi Stillinger, S-T-I-L-L-I-N-G-E-R. My comment,
Pi which you can easily rephrase into a question, the
Pi phrase "institutional controls and monitoring" are
m not well defined.Are these intended to be
lei activities in perpetuity or short term?
hoi MS. MARSHALL: Do you want to address
in) that'
pz) MS. OOEBBLER: We are required to write
in) into the proposed plan a 30-year monitoring
[mi That's what's required.
lis] A VOICE: Three zero?
|iq MS. DOEBBLER: Three zero.
|17] MR. STILLINGER: And "institutional
pq controls" what does iwan>
|i>) MR. COSTELLO: If you look on page 8,
pot Alternative No. 2. It talks about monitoring
pil includes institutional monitoring, Includes
uzi institutional controls along with O & M
[23] activities. Surface water monitoring and wildlife
pa] management would be conducted by refuge personnel
PS) currently practiced. Current institutional
Paga 22
HI
PI controls, such as securing deed restriction,
pi restricting site access, securing land use
mi restrictions, I'm reading the bottom of page 8
Pi now, are in place and will have to be maintained
pi to conform to the intent of this remedial
f71 alternative.
w So the monitoring will be consistent
m with the surface water in current wildlife
[ioi monitoring that the refuge is doing.And
[n| institutional controls will be consistent with
nzi what is said on page 8.
[13] As far as Alternative 3, it's on page
[M] 9, the middle of the page, institutional controls
[isi will be established, long-term monitoring of the
(i«i site would consist of surface water and wildlife
(i7] monitoring, as is the current refuge practice.
(tq Other O & M activities would include mowing in a
[ioi manner consistent with the wilderness setting, so
pq forth and so on.
pi] So in other words, the refuge is
pz] currently managing wildlife at the site, and that
pi] would continue.
[74] Surface water, they're currently taking
[25] samples around the site, that will continue. In
P«ge 23
I'l
pi addition, there will be some extra mowing because
pi now you have a cap so you need to maintain that
|4] area and make sure it's not settling or animals
[S] aren't burrowing into the cap. No trees would
n affect the integrity of the underlaying layers.
[7] We can answer that officially in the written
i«] comments,
pi MS. MARSHALL: Sir?
[ioi MR. FOX: My name is Paul Fox, FOX.
[11] Just one question.
[iz] Alternative 3 talks about implementing
[ii] the institutional controls on the opposite page.
[14] It's defined as access restrictions. My
[K] understanding is one of the things we were
[iq considering in regard to the she, Is being able
[17] to return the she to be publicly accessible in
pi] regard to bird watching and that son of activity.
[iq Is that still the intent or is it the intent to,
!20| in fact, re stria access in perpetuity?
pi) MS. OOEBBLER: Our intent is to open it
pz] up for- and Bill, you can expound on this. My
pi] understanding is that the refuge would like to
[?4] have the trails that are currently closed in thai
(25] area opened, and the birds like this area. It's a
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Ml
pi nice upland area. We would like to be able to let
pi people out there to watch those birds and watch
pj the wildlife.Access restrictions can mean
[si things, like, we don't want to have heavy
[si equipment, such as tractors or bulldozers that
m might rip up the integrity of the cap. So by
[»i access restrictions doesn't necessarily mean human
m restriction. And that will be part of the
[ioi wilderness management plan.The refuge will have
in] to put that in their management plan and that will
(1?) be up to the refuge how they choose to manage that
[til site.
mi MS. MARSHALL: Yes, ma'am.
osi MS. HINKLE: Penny Hinkle, H-I-N-K-LE.
ps] I take h then that Area A, which would
ii7) be three or four acres as its capped, will zoi be
;M) really allowed to revert to whatever the native
I'.bi species that were there, you've taken trees down
per and so on, h will be some kind of grass? You're
pi! talking about mowing.
[27; MR. COSTELLO: To some extent.We
Irs; won't necessarily be mowing.The wetland species
[7*1 that we put in there subsequent, will be
ps] consistent with that area, and the botanists from
Paga 26
Ml
(71 SO-M-E-RS.
PI We arc son of - I've been waiting to
Hi see if we were going to verge into questions and
m that was allowable, and you do seem to be
m answering a couple of questions and I do have one.
Pi In your presentation you said that
m Alternative 3 would take an estimate of about 15
m months to complete.When does that 15 months or
[ioi did that 15 months begin?
[ii| MR. COSTELLO: It begins with this
[<2) meeting here tonight,
nil MS. SOMERS: Thank you. Another thing
[14| that is referred to in this remedial plan is
[is) monitoring, and from what you said this evening, I
(«l understand that apart from the sort of physical
(i7| monitoring, you are talking about chemical
[id sampling of water. But is there anything else
(i*l beyond that as for as taking of samples of tissues
pel of animaU or anything else?
pi) MS. DOEBBLER: Yes.That would be
(22)	consistent with what the refuge currently does.
(23)	They have a program in place for surface water and
(74) bio-sampling. Robin or Bill, you may want to
(2s) expound on that, but that would be in conjunction


Pag* 25
e:
pi the refuge area will be involved in developing
Pi that final design plan.There are some wetland
w species that will be shallow-rooted, they will be
[5] more than adequate and they won't damage anything,
[si MS. HINKLE: And they will provide some
[7i type of wildlife habitat?
m MR. COSTELLO: Right. As far as large
m trees, that most likely will not be permitted. It
[ioi will be wetland habitat. We have done that in the
[11) past to bring back wetlands on former sites.
[17| MR. BURR: We're not going to make the
(<31 top of the cap a golf course. It's not going to
l") be just a Kentucky bluegrass topping. Make sure
[is] you understand, that's not the intention.
[iq MS. DOEBBLER: Unless Bill wants It to
(17] be a golf course.
[it; A VOICE: He can feed the geese.
(iq MR. COSTELLO: 111 lose a lot of
pq balls, that's for sure.
(71] MS. FENSKE: This area is in the
izt; wilderness area, isn't h? So you are constrained
us; by that.
(?
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Ml
pi in accordance with the federal regulations which
pi will become a public document, and periodic
HI sampling and results, a yearly report has to be
(5) submitted to EPA, and that's also public
m information. After a period of five years, EPA
Pi will open up that monitoring plan for comments,
m either to add to it or subtract from ft. So It's
i») all -
iio) MS. SOMERS: Not as far as the funding
M i] is concern?
112] MR. COSTELLO: Not as far as the
!i3) funding. So Fish and Wildlife Services, I
t>4] believe, will set that money aside to fund ft,
(is] proposed initial monitoring for 30 years.
•i«j MS. FENSKE: It will not be subject to
17] annual cuts, it will be there?
nj MS. DOEBBLER: Yes.
i«] MS. FENSKE: As a dedicated fund?
to) MS. DOEBBLER: Yes.
?ij MS. FENSKE: And the staff to undertake
22) it will be there? We know all about staff cuts.
731 MS. DOEBBLER: I'll come out and do It
myself. How's that?
?s) MS. SOMERS: They did not put us up to
P«g« 30
ii|
(?) Ms. Summers had a question - a statement,
p] MR. CASSA: Yes. George Cassa,
W C-A-S-S-A. I have two comments,
ts] The first concerns the - Figure 3,
is] cleanup evaluation criteria on the back of your
n handout.The second item is compliance with
m applicable or relevant and appropriate
IB] requirements concerning compliance apparently with
|io) federal and state environmental laws and
|mj standards, etcetera.
(12] My comment would be, I would hope that
Mi; you have already taken into account or, if not,
[ui you will take into account the very rigorous local
fi5) standards which have been enacted and are in the
Mo process of being enacted in the ten towns
[17] surrounding the swamp.
Mi] The main concern that 1 would have Is
(i0) that the protection of the swamp has been the
(20] focus of many of these local regulations, and if
pi] it's learned that the owner and contractors of a
[22] remediation within the swamp itself are allowing
pa] themselves more freedom than, say. a private
(?4) developer would have on his own property, a lot of
(xi the work that has gone to raise the level of


Page 29
")
[7] these questions, by the way.
pi MS. DOEBBLER: That's a very fair
m question.
s] MS. SOMERS: Sorry,Julia Somen again.
ks] Going back and forth. It does seem to me
itj over a 30-year period, that is an extremely modest
m: sum of money to continue a monitoring program of
w, any -
pi MR. COSTELLO: That's the present value
i] of that money. So that assumes six, seven percent
71 interest over a period of years. I don't have the
j] number in front of me. It's based on annuities
spread over 30 years with certain compounded
s] interest and so forth,
t) MS. SOMERS: That will be useful to
7) have that set out in the plan so that - as was
¦I indicated by the earlier question from
n Ms. Fenske, we can be assured that the funding
3j isn't going to disappear somewhere.
•; MR. COSTELLO: We can add it in
response to the written comments for that
3j question, we can put that in there, make sure we

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17, question, which was based also on Figure 3,
[31 No . 8. It indicates that one of the processes
I4j that you go through is a state acceptance. And 1
[5) was wondering if that was complete?
dl MS. DOEBBLER: Is there anyone from New
PI Jersey DEP here tonight?
m Everything, as you probably know from
m the documentation that we've had circulating. New
(ioi Jersey DEP is not a party to the draft federal
(M) facilities agreement which we're negotiating with
(12) the EPA. However, they received everything, and
{is) before it is finalized, for comment and review.
!'<) And that's their involvement. So they receive
(¦si everything.When EPA does pre-publication for
[tr, final document storage in the repository and as
[it) part of the record, they get h ahead of time.
p*i MS. SOMERS: This comment Indicates
(i«i they actually have to take some kind of action,
poi Because it says that "they agree with or oppose,"
r? 11 or arc you assuming that because they don't have
72) anything to say, that they, therefore, have no
comment on the preferred alternative?
r?4| MS. DOEBBLER: Helen, would you like to
ps; add anything to this about New Jersey 's
Peg# 34
MJ
[2] I'm sorry. Helen Shannon, EPA.
p] MR. CASSA: George Cassa again.
K] It's my understanding that in New
n Jersey since 1944, the Corps of Engineers have
n acceded or granted the enforcement of certain
m environmental regulations to the State of New
m Jersey DEP under a program that is applicable
n nationwide, but only one or two states are taking
ftoi advantage of that. But the comment that I have
in) is, it's not dear given that the Coips of
(12) Engineers appear to be a party to this project,
list what, if any, effort does the DEP have to play at
|m] all?
(isi In particular, it would seem that the
(i*l selected alternative specifically requires
(i7] dewatering, diainage improvement, and some
(ill diversion of creeks or brooks. It's not very
(iR) clear. If that is the case, it does seem to me
pq that federal requirements are now under the
(21)	jurisdiction of the state, and I would hope that
(22)	might be clarified, if possible.
(73) MR. KOCH: Bill Koch.The program I
(Ml believe you're referring to, Mr. Cassa -
psi MR. CASSA: Cassa.
Page 33
Ml
Pi involvement in the process?
(3i MS. SHANNON: The fact that they have
hi actually looked at this information and haven't
(5) opposed it, one has to assume that they are not -
m I mean, Kris, you can - as I've kind of said, you
Pi might want to get in touch with the project
pi manager who - from the state and see if you can
n get, perhaps, a concurrence letter from them that
(
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ni
Pi the Corps working as a contractor for us.
m MR. CASSA: But I would then presume
hi that documentation of some sort would exist in the
is; record that would prove that the intent is met
Kl even if the official permit form is not filled
n out?
p; MS. DOEBBLER: Yes, sir. And it is
pi in - to date what we've done is in the
po] repository, soil erosion control plans, things
[iij like that, wetlands permitting.
[it; MS. MARSHALL: Yes.
mi MR. GREENWAY: Roger Greenway.
[u] 1 had a comment on the nature of the
ps] material. I've heard it described as being
(tei nonfriable. However, I realize that nonfriable
117) material can be made friable by moving h and
mi handling it. So my concern is that the material
iei be kept constantly wet during this consolidation
2oi process.
71) 1 also have concern, I didn't sep air
32i monitoring in Alternative 3 in this document,
33i although, 1 did see it in other alternatives, and
741 I think it's important that we have continuous
zsi upwind /downwind air monitoring for airborne
Pag« 38
!')
pi permanent this structure was intended to be. In
ni particular, whether it would be subject to water
Hi erosion down at least through the vegetative layer
is] at the top. It wasn't clear what this filter
id fabric was and how permanent it will be. And
in particularly, it wasn't clear whether one would
di have to revisit the site and redo this structure
[9] to neutralize the underlying nasty stuff.
Iioj MR. COSTELLO: To address your question
ini how permanent, h's intended to be permanent.
iiz) As far as erosion of the vegetative
Ii3i layer, that's where the drainage control component
|14] of the design comes in. Consolidation, pulling
lis) back the waste, well make sure that the slopes up
(iq to the hundred year flood elevation are adequately
[t7] protected so it doesn't erode. If this means
(it) costly materials, possibly well look into that.
[ib] However, we can do that with wetland material so
col it's more aesthetically pleasing,
pi] As Car as the fiher fabric, the filter
m fabric material is a - a general material that's
[731 used on a lot of construction sites and it has
some warranty service for many, many years, and
ps) it's a very durable material, h's a synthetic
Page 37
Pi
[r asbestos during the consolidation phase and
p: capping phase of the projects.
h: MS. DOEBBLER: Yes, we agree.And we
Pi have done air monitoring on the other actions that
m we've taken on the site periphery and personal
m monitoring on the workers, and we will continue to
r«i do that.
i»i MR. GREENWAY: That is part of the
i os plan?
¦i) MR. COSTELLO: That's pai. of the
'2; construction plan.There will be air monitoring
i] done during the course of construction, as it has
,4I been from day one.The long-term monitoring,
si since the asbestos is no longer exposed, it's
«] being covered, that air monitoring is not
7i required.
•i MR. GREENWAY: Right.Thank you.
si MR. STILUNGER: Technical issues
¦a: concerning -
'] MS. MARSHALL: Can you give your name,
ai please.
3i MR. STILUNGER: Frank Stillinger.
«! Figure 4, the capping structure, at
least on a quick survey, I wasn't clear on how
Page 39
in
pi material. And does that answer your question?
P] MR. STILUNGER: The word "permanent"
Ki seems to have a very flexible definition,
is] MR. COSTELLO: As far as the long-term
Pi monitoring -
m MR. STILUNGER: Permanent press means
m about two washings. I assume you mean more
m permanent than that?
(io; MR. COSTELLO: Put of the long-term
|i 1) monitoring of the site in addition to any -
(i2) looking for *"<"»'« burrowing into the cap. a walk
n j] over the whole area is required periodically on a
|i4] quarterly basis to make sure that the integrity of
[isj the cap - that no areas are being eroded, that
[iq the integrity of these materials are being
|i7) sustained. If the - If the filter &bric becomes
m«i damaged, youll notice k with settlement at the
M«l surface and as pan of the monitoring plan,
pai corrective actions will be outlined. So that if
(2M there is damage that's detected, Fish and Wildlife
lazi Services will have to repair it.
mi MS. SOMERS:Julia Somers.
I24) I'm curious to know how the elevation
ps) of the 100-year flood plain was established?
age 36 - Page 39 (12)
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1'!
pi MR. C0STELL0: That's all outlined in
pi the feasibility study. I can show you after the
m meeting where it's outlined, but it's based on
p] soil conservation surface mapping on the site and
m work done byApgar in the mid-'80s.
pi MS. SOMERS: It's my understanding that
n water - surface water elevations through this
m site rise very rapidly based on even a two-year
|io) storm event.
,tt] MR. COSTELLO: Right.
[12] MS. SOMERS: And so 1 was concerned
[ii] that if you were using a standard 100-year flood
[I') elevation, it may not, in fact, reflect reality
[is] for this site.
Ik; MR. COSTELLO: We were very fortunate
[it] as well last year.
[i«] MS. SOMERS: Yeah, we had one.
[is] MR. COSTELLO: Two of them. I was
pq actually there the day after it happened. So we
pit monitored surface water during that storm, and
[22] that was - I believe it was a 200-year storm.
[73] MS. SOMERS: Did you monitor it three
p*l days later?
125] MR. COSTELLO: Through visual
Paps 4r
(!)
Pi as after, during construction,and we'll continue
Pi monitoring after that. So we'U have a good sense
HI of that.
[5i MS. SOMERS: How long do you anticipate
m that monitoring to continue?
pi MR. GRISWOLD: We can leave them in
m place as pan of this program.Those arc fairly
m durable instruments.You put new batteries in it
lid time to time.
[ii| MS. DOEBBLER: Some of them are in
li2l wells that will be abandoned, but the rest of them
(is) can be left in place.
(14) MR. GRISWOLD: We can redeploy them in
[is] a number of places. It will get us very good
M3 readings on that.
[17| MS. SOMERS: It will be useful data, I
(m think, to have it.
m MS. FENSKE: Helen Fenske again.
po] First of all, I'd like to compliment
pi] you on the public process. I think your effort
pz] has been substantial, and the information that you
pi] shared with all of us has transmitted a sense of.
[34] I think, genuine partnership. And the process of
psi involvement has been wonderful. It's been one of


Page 41
pi observations of the elevations of the surface
Pi water along Long Hill Road which had become
hi flooded. We have a pretty good idea what the
P] surface water elevation was last October 19.
re MS. DOEBBLER: Mark Griswold.
[7] MR. GRISWOLD: Mark Griswold with
l>] Foster Wheeler.
m One of the points that the feasibility
[id and value engineering study pointed out was how
in] the surface water reacted to the storm events.
[12] Currently as we speak, there are electronic
[1 ii monitoring devices in a number of wells and
[14] surface water structures in the streams out there
09 that record elevations of the water every 30
[it; minutes.And we go out there every six w»«wh« and
ti7i download that on the computers so we can plot it;
[it; initial round of that data, first six months -
[is] the first three months of those monitors being in
m the site. It's in the pre design interim report,
pi] and it will be done. We'll have instantaneous
[Z2] records, voluminous data on the behavior of the
pa] surface water out there. Before the surface water
p«l was restructured summer during the surface
ps] water control activities that took place, as well
P»g« 43
w
pi the best that I've had in my 35 years of
n experience. So I would like to say cheers for
M that.
isi And my second point is, that we often
n refer to the preservation of Great Swamp as two
[7] battles. One, was first to establish the refuge,
m And in looking bock that was almost simple
H compared to the second battle, which is
[io] continuous, which is to prevent it from just
[ill becoming a cesspool.In that process, and it's
[i2] been going on now almost eight years, the emphasis
Mai has been on regional. It came from DEP
(i4j establishing an advisory committee of the DEP.
(iq The message coming out, we can oo longer protect
Mq Great Swamp unless it's a regional approach. And
M7] the ten towns that have gotten together, they have
(iq made real headway, and the ordinances that are
[iq beginning to become - beginning to be passed, arc
poi based on that regional approach to protect the
pil whole watershed. I'm being very windy about this,
pz] Superfund Site No. 3 is downstream of a
P3] hundred and eighty acres, as you know, the Miele
P4j landfill, directly downstream, and yet because of
ps] your charge and your mission, you bad to just


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l<)
pi focus on this piece, and it appears to me that
13] it's - because of your constraints, it was
W unrelated to the regional approach and what might
Pi happen.
is; Now, this meeting tonight is an
m investment and/or a process to decide that a $4
m million investment is the best thing to be put in
IB) place to handle this. And yet it seems to me it's
id unrelated to what might happen upstream in an area
t ij that hasn't been investigated very much, except
iz] for Mr. Fox's review a little bit with EPA. DEP
j] has repeatedly said there's no-no problem here.
>4] We have no scientific basis.That's because they
5] have not done any investigation. But you've got a
s] stake in that. And I just wondered how this
7] solution relates to that regional approach? I'm
q wondering if you wouldn't comment on it. I mean,
si you're looking at this and this could be very
a) successful and then have a bomb explode further on
ij up with a lot of new information once they get
21 into it. And it seems to me that you can't be an
o] island in this whole regional approach.
*i MS. MARSHALL: We really appreciate
si your comments,but I know that I am being told
Page 46
I'l
Pi approach to managing water and its hazardous waste
pi over the years since the Clean Water Act was
1*1 passed, has been fragmented, has not succeeded as
ft a result I mean, the world of enlightenment is
lei you have to deal with a water shed. What comes
P] from upstream, and you're downstream. And I can
m understand what's happening. It was a priority,
m but it's still a piece, and today with EPA going
|io] the water shed route, the nation going the water
in] shed route, certainly this state, it seems to me,
(12] that you've got to relate - there's got to be
(is] some protective measures taken of your cleanup
iu] measures, cleanup efforts here on this project,
lis] and some effort has to go in to thinking about how
(id that protection should take place.A protection
117] isn't just sealing k and monitoring it, it's
in; anticipating what's going to happen upstream.
l«] Oh, well.
po) MR. BURR: Robin Burr again from Fish
pi] and Wildlife Service.
I2?i Helen, Miele landfill was indirectly
[23! considered during the study investigation and will
124) be in the monitoring of this project because we
psj did sampling upstream of the site.That's all I


Page 45
M
5 that we need to keep this just on OU-3 for
r, tonight.These other Issues will be discussed.
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Pago 48
I'l
Pi would have been a metropolitan airport and
Pi everybody seemed to be against it at that time.
Pi Certain people. And 1 thought I saw nothing wrong
is] with it at that time, and I see nothing wrong with
m h now, making it into an airport,
n MS. MARSHALL: Okay.Thank you for
m your comment.
IB) Yes.
[iq MS.TIELMANN: I have a question,
in) MS. MARSHALL: Could you sate your
(i?. name, please.
rx: MS.TIELMANN: T-J-E-L-M-A-N-N.
n*: You investigated an alternative for the
i- 5; prospect of hauling it off site.That was one of
pr, the alternatives. I'm curious to know how you
(17) classified this ACM in your cost estimate for
[it] disposing it off site? Is it considered a
(itr hazardous waste, or is it considered construction
ro debris, RD 27, what is it classified as?
[2t) MR. COSTELLO: Asbesto; is considered
[27 special waste. It has its own set of regulations
[»; for off-site disposal. The cost we use in our
[?*; cost estimate was based on the Corps of Engineers'
[751 work that they did last year removing some of the
P«9*5C
Ml
121 at Site B. Based on the risk assessment that
Pi Foster Wheeler completed and summarized in our
M report, lead is an ecological and potential health
[5] risk. So that will be alleviated in the coming
m months.
[7) Groundwater is relatively clean,
m Surface water is relatively dean. So the
m potential risk, if it migrates out of the soil
[ioi that it's in, so it needs to be managed properly,
in) There's no immediate risk, to answer your question
tiz) that way. So we're trying to deal with potential
[iq future risk.As fu as the asbestos in the mound,
[14] if it's left uncovered, the airborne particulates,
[1 si wildlife gets to dig into it and carry it around
[ic] through the ecosystem, so we need to deal with
[it] that by just simply covering the asbestos in
[it] accordance to the regulations.
[is] MR. SCAFF: If there is no immediate
[20]	risk and it's been there for 40 years, is it
[21]	getting better or worse?
[22]	MR. COSTELLO: If you look on page -
l?3l MR. SCAFF: I read it, briefly. I
[2*1 haven't gone into it in great detail. 1 don't
[25] understand why we want to fix it if it ain't
Page 49
I'l
[2] asbestos that was on site.Asbestos just cannot
P! be loaded into a dump truck and shipped away. It
1*1 needs to be placed in bladder bags and handled
[S) specially. It has to be sent to a special
m facility. It has to have a special permit to
m handle that. It's not quite a RCRA hazardous
m waste,TSCA waste, it's a special waste.
m MS. MARSHALL: Yes, sir.
[i?i MR. SCAFF: Harold Scaff.
in) MS. MARSHALL: Would you spell your
it?! name, please.
1<31 MR. SCAFF: SOA-F-F.
|ui MS. MARSHALL: Thank you.
list MR. SCAFF: I'm con/used on things.
|iq What is the immediate hazard of this OU-3 or
[17] whatever they're calling it, Dietzman she? Are
im we in danger today? Is there a hazard immediate
right now? What's the danger?
W MR. COSTELLO: Similar to what Helen
pi] sajd earlier, you have to plan for the future,
ra One of the potential future risk was the presence
[2Ji of the drums at the site, but that's been
r»] alleviated at this point. Now asbestos has been
ps] left in place and some lead-contaminated soil also
P*0« Si
I'l
[2]	broke. Stirring up asbestos is about the worse
[3]	thing you can do. If you just leave things alone,
M I think we're - you know, I worry more about
is] fooling with it then leaving it there.
PI MR. GRISWOLD: Mark Griswold with
[?) Foster Wheeler.
in I'll try to clarify how we calculated
m the risk. We followed all of the procedures that
[ioi are required by EPA and all their guidance
[it] manuals, and based on the sampling that we did, we
[i2] found that there were several metals present in
jiq the soils at the site. Based on the modeling that
[M] was done, direct contact with said soils over a
list period of time and the assumption you would get
[i«l dirt on your hands, eat food after you've had that
117] in your mouth - to get the soil in your mouth
l<«l after touching it, that would be out of direct
|iq contact by humans. It would be impacted - you
pot won't have direct contact with the soil at the
pi] site. So that's how that modeling was done.
[22]	The same thing for the impacts to the
[23]	wildlife. It was based on their consumption of it
[24]	by living and eating it, from being there. We
psi found that animals out there did have detectable
T A VT Alt A I! V ¦ V V • V VT»TTV%
/«	v\ _ _
4 O
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Ml
p] concentrations at low levels in their tissues from
pi) being exposed to materials.The best way to
Hi handle that is for some of the materials to be
[5] encapsulated, covered, and some materials can be
16] removed from the she.
pi MR. SCAFF: We have some three-acre
pr, piece sitting there all by itself, how is that
jb; alfecung the whole - it's - it's - and I don't
po; see animals picking up truckloads and running over
in] an area. What they pick up on their feet would be
(12! minute. I hear you, but I don't see where this
(til disturbance is creating any hazard more than
[i«] anywhere near what you're proposing to do, stir it
[isi up and move it around.
(is] MS. OOEBBLER: Actually, your point is
gin welJ taken, and that is one of the main reasons
im that our value engineering study came up with that
(i») big risk, was picking it up and hauling it all to
poi another site in some other landfill somewhere else
p
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PI
121 MR. COSTELLO: That would be treated
pi separately. So the lead problem would be
hi addressed possibly by an off-she removal and the
pi lead materials that - it's in the refuge area of
m Site B.and the refuge area is upland of Site A.
(7] MR. CASSA: It's my understanding that
m the drums that were removed were tested
m individually, and that h was concluded that they
pot were either intact or the leakage was relatively
nil insignificant Is that also correct?
[it] MR. COSTELLO: Post-excavation samples
mi of the soils once the drums were removed,
mi demonstrated there was no significant leakage of
ps] the drums, correct.That information is
[in summarized in this report dated September 1997.
-71 MR. GR1SW0L0: It's in the close out
p«i report that's currently being prepared. It's not
ti») pan of that sampling. But there is a report to
130) be prepared on this,
pi} MR. CASSA: The same wells that I'm
[2?i referring to. are also downstream of the Rolling
t»: Knolls landfill where, from what I've read, there
[24; are materials in there for which tests don't
ps; exist So we don't know what may be coming out of
Paga 54
m
pi MR. COSTELLO: Robin makes a good point
Pi there .There is a cross section of the Site A in
K) the feasibility study report, and Site A is
[sj underlined by a very thick layer of clay, and
m organic silts, highly low permeability. It's like
[7| ten to minus seven centimeters per second.What's
m happening, it acts as a natural liner.That's a
1*1 depth of six or seven feet. It's right below the
[in] - it's extends down to some great depth.
[11]	MR. BURR: During the time of the drum
[12]	excavation at She A, we excavated down to clay
psi every lime and the majority of those pits were six
[14] to eight feet, if I'm not wrong, 1 believe they
[is; were, sir, just showing you that Site A is
(iq generally sitting on an area of thick clay. You
|i7] should understand that and the public should
(m understand that before you walk away tonight.
pvi MR. COSTELLO: We also did a counter
poj feasibility study, we did extensive geotechnical
[21] testing of that layer to come up with permeability
I22] and grain size, and it classified as day/silt.
(23]	All those results are in the feasibility study.
(24)	MS. FENSKE: Had these drums rusted
(zsi out, say you had not removed them, what was in


P«9« 57
CO
[7i that underground toward the water supply in our
r>) local area, as well as a hundred or more other
1*) wells along that line. So I would just say to
[sj emphasize the bet, that I think these two sites
m are at least linked underground If no other way.
m MR. COSTELLO: Robin.
[t; MR. CASENBERG: Point of clarification
Pi about groundwater. I'm sorry, Mr. Cascnberg.
(is] I'm not a geologist, and, again, Just I t*«
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PI
pi have been a much worse problem farther on down,
pi MR. KOCH: I'm not responding to it.
(4j Bill Koch. I'm not responding to any particular
P) question, but a concern that Mr. Scaff had about
16) the expense. Just in the general scheme of
[7] things, $4 million is a lot of money to all of us,
m however, hazardous waste cleanup is a very
is) expensive process, and that's relatively not a
[icq lot.That's not a lot of money in the scheme of
in] cleaning up hazardous waste. So I'm just trying
1121 to put that a little bit in perspective, even
in) though 4 million is a lot of money. 14 is a lot
n<] more, but stil] that's not a lot. Four million is
lis] not a lot in the scheme of dealing with this tvpe
(isi of thing.
li7) MR. SCAFF: I go back at that point.A
in] dollar or 4 million, we're looking at a risk of
list nU to none as far as everything I've heard
po] tonight.That this thing, the only way we're
Ri] going to get in trouble is by stirring it up. 1
[Z7] don't see bow spending a nickel out there is going
[73] to nuke an improvement. We haven't got a hazard
[24] that's going to bite us today.We haven't got a
[75] hazard that is going to bite us in five or ten
Pag* 62
t'l
pi relatively inert now, that's not to say in the
PI future.
HI MR. SCAFF: You're telling me that the
d surface water in the Great Swamp raises and falls
to at a great rate every day?
Pi MR. COSTELLO: All the time, yeah.
m MR.JANSEN: Build a dam out there,
m MR. SCAFF: By the structures you build
[ioi out there, you contain the groundwater at a
in) constant level.
[12) MS. MARSHALL: Yes.
[i» MS. HINKLE: Penny Hinkle.
[14] I was just looking at the map of
liq relative positions of Site A and B, and I gather
iiq you have rerouted Great Brook around Site A so
ii7) that then in moving the asbestos from Site B to
|ii] Site A, you don't have to cross the brook; is that
[i»] correct' I mean, bow arc you going to get that
po; asbestos? Why not just consolidate it there and
pi] have a smaller area capped?
P2] MS. DOEBBLER: We considered that.
(73] capping Site B in place? Is that what you're
p4] asking?
ps] MS. HINKLE: Yes.


Page 61
PI
(71 vrarv It sc-rms mlya vrry minimal «niarinn
[jj It seems to be contained by its own physical
K nature
jr. MR. BURR: If I may address that.
Pl Something we also considered if we did nothing,
Pi sir, then we would have to leave that site totally
K restricted
I®) MR. SCAFF: Is it restricted now?
;io) MR. BURR: The public is losing - the
[11]	public is paying a price for that. Currently you
(12)	are paying the price.
|ij] MR. SCAFF: There are a lot of places
in) on the swamp we're paying the price for not going
lis) in there.
|i«i MR. BURR: That you should have access
|17] to. I'm just saying, you arc paying the price.
[i«] Don't presume you're not paying a price for not
[10] doing that.
poi MR. SCAFF: Well, we all pay the price
pi] for the swamp.
PS] MR. COSTELLO: The other thing we need
to consider is that asbestos is - the
p*i environmental surface water is rising and falling
P«] significantly on a daily basis and may be
Pag* 63
Ml
pi MS. DOEBBLER: We did consider that.
pi MS. HINKLE: It seems a little risky to
hi move it.
is] MS. DOEBBLER: We've installed three
m corrugated steel culverts between sites A and B.
(7) There is good road now that runs between A and B
m and we used to haul the material over. We didn't
m necessarily reroute the brook, but we have made it
(ioi accessible to get over the site. And one of the
[iii reasons we chose not to consolidate B at the She
(i2i B area, was because from a refuge standpoint, a;
[ij visitor access Standpoint. Now if we get Site B
(i4| over to Site A, Site B will be clean and can be
[ill dealt with with the hiking trails through the
(iq access over there. It's contained, it will be
[17] capped over on Site A, the cost of transporting B
(ii) to A is not that significant as opposed to the
[ioi capping and all of the controls that go with
capping.
pi] MR. JANSEN: I have a question to ask.
P2i MS. MARSHALL: Your name, please,
pd again.
po MR. JANSEN: Jansen.
psi MS. MARSHALL: Thank you.


Page 60 - Page 63 (18)
Min-U-Scriota
tavt nn » mrtnwnir.
-------
PROSPOSED PLAN FOR THE ASBESTOS DUMP
SUPERFUND SITE OPERABLE UNIT
December 17, 199'
Paga 64
t«1
pi MR. JANSEN: This Fish and Wildlife
pi Services, what are wc going to do about the geese?
Hi They're crapping all over the place. We can't
is) even walk out in our field out here.We cannot
m walk out in our field out here,There are feces
m all over the place. What are we going to do about
m that? And that drains into the ground, it goes
[B! down into the swamp, and into the wildlife. What
no) are we going 10 do about that? You don't know?
[i i) MR. KOCH: That s a whole other
[izi subject,
[Hi MR. JANSEN: That's my life.
(1*1 MR. KOCH: There are many topics on
lis] wildlife that we can spend months talking about.
1-«1 MR. JANSEN: What are talking about?
(it) I'll tell you what we're talking about,is shit.
ii«: MS. DOEBBLER: Thank you.
pen MR. JANSEN: You're welcome.
pc? MS. MARSHALL: Any other comments? Are
P'S there any more comments about OU-3,4?
127; MS. FENSKE: That 's a great finale,
pj; MS. HtNKLE: One further comment is
p«; that I'm sure it would be comforting to everyone
pr. to know that if this is the case, that fill that
Pag« 66
m
PS for your commenis/qucstjons.Thanks very much.
Pi (Time noted: 8:53 p.m.)
M
|S1
W
m
l»!
|10S
I11!
VZ
m
m
I'S
PC
1171
ii r,
[i»»
p°i
£21}
RKJ
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PS


Page 65
in
r is brought in to cap Site B - A, is clean. I'm
[T, sure there are - can you describe the precautions
M. that will be taken?
p, MR. COSTELLO: We're dealing with very
[si similar sites from the Fish and Wildlife Services
n both up and down the East Coast, and during the
r*i design phase, we'll prepare specification
w documents that will have the quality control
im requirements for fill as far as gradation and
|i'i environmental testing.We will be testing the
I'S material on a regular basis as it comes in.The
I,Jt contractor will be required to submit that, and
!i*) well ensure that no contaminated material is
m brought into the site,
in MS. FENSKE: You won't see yourself in
117) the paper then.
im MS. MARSHALL: Any other comments? I
(tsi don't want to end this before everybody has had a
E20) say this evening. Okay.
pij Well, things may occur to you between
(22) now and January 16. We welcome you to submit
pi] further comments to us in writing. They will be
r«i incorporated in the record of decision. And I
psj thank you very much for attending and very much
Pag* >7
I'l
PI CERTIFICATE
PI
W I. VIOLA S. ZBOROWSXI. a Notary Pubfc
[ij and C.S.R. o« sr» SUM of Naw Jaraay. (Joans* No.
m XK>1122. do haraby eartty tlml Bia tor*go*iQ to a
[7] tru* and accural* tranacf** tha tastimony as
n takan slenoyiphicaty by and bttora ma M tha
(q Qma, phca and on lha dMa harataMora aat
(10! lorth.
[ill I DO FURTHER CERTIFY Biail am r»«haf
(tq a raMfca nor amptoyaa nor rtlomay roc ooufia*!
[133 o» any oi lha part** to W» action, and thai 1
ti«| am nakhar a raW« not anpkiyaa « aucft
;iq tuorvm ar counsal. inyh* 1 am not ttianelafc
;<«| Maraatad£&&&
m
(i«| Notary PiMc of th» Staia of Maw jaraay
[Wj My Commiaston a^toai Sapfattbaf 2001
pi] Datad
(22)
m
i»i
|2S)


TAYLOR & FRIEDBERG	Min-U-Scri©t®	Cl9) Pa«C 64 - Page
-------
Lawyer's Notes
-------
PROSPOSED PLAN FOR THE ASBESTOS DUMP
SUPERFUND SITE OPERABLE UNIT
December 17, 199"
$
*14 53 13,15,17
$15 16 5
*3.0 53 20
*300,000 27:23
*4 16:10,44:7;59:25,
60:7
*95,000 16 3
/
/downwind 36 25
1
1 10 14.16 2,1916
100-year 39 25;4013
12 55 5
1460 13
15 15:10; 16:12;26:8,9,
10
166 10.65 22
10 41 5
1944 34 5
1996	4:2
1997	13:2,56:16
2
2 10:16; 21:20; 33:21
20 57 18
200-year 4022
2200 52:24
24	55 5
25	47 24
250 11:8
27 48 20
2A 10:24
3
3 10:11; 11:10; 13:6,12,
15; 15:22; 16:10; 19:5;
20:15:22:13; 23:12:26:8;
30 5; 32:2; 36:22; 43:22;
45 14,59:18
3.9 27:20
30 27:9,14; 28:15; 29:14,
41:15
30-year 21:13; 27:22;
297
35 43 2
4
4 11:25:37:24.60 13,18;
64:21
4.1 27 14
40 50 20, 59 11
404 35:2
5
5 53 18
50 59:6
6
6 15 23.19 12,14
7
7 57:18
8
8 21:19; 22:4,12; 32:3
800 57:18
8:53 66 3
9
9 22:14
97 4:3.4
A
abandoned 42:12
able 2:7; 14:7; 23:16; 24:2
acceded 34:6
acceptance 14:8.10;
32:4
accepted 14:10
access 10:18; 20:2; 22:3;
23:14,20; 24.4,8; 61:16;
63:13,16
accessible 2317; 63:10
accordance 911; 28:2;
50 18
account 30:13,14; 55:4,
10
accurately 5:7
ACM 48:17
acre 17:22
acres 17:3,7; 18:2;
24:17;43:23
Act 46:3
action 10:7,15:11:12,
23,32:19
actions 37:5; 39:20
active 3:11
activities 3 8, 10:10,17;
21:9, 23; 22:18; 41:25
activity 7:17:23:18
acts 58:8
actual 59:5
actually 5:23; 11:3; 13:7;
32:19; 33:4,10,13, 20;
35 18, 20:40 20,52:16
add 3:5; 28:8. 29:21;
32:25
addition 11:18; 23:2;
3911
additional 12:18; 13:3,9;
55:15
add ress 6:15; 8:18; 9:15;
10:6,23; 19:10,20:15,24,
25; 21:10; 3810; 55:22;
61:5
addressed 11:5; 45:22;
54:23; 55:19; 56:4
addresses 10:24
adequate 255
adequately 38:16
admit 47:25
advantage 34:10
adversely 18:19,20
advisory 43:14
aesthetically 38:20
affect 236
affecting 52:9
afterwards 4 57
again 2.20; 29 5; 34:3;
42:19; 46:20,47:19,
57:10; 63:23
against 13:14.18:48:3
ago 11:9; 47:24
agree 32:20; 37:4; 45:23;
5312
agreement 32:11
ahead 32:17
ain't 50 25
air 36:21.25; 37:5,12,16;
54:3,13
airborne 15:4:36:25,
50:14
airport 48:2,6
alleviated 4924; 50:5
allow 10:22
allowable 26:5
allowed 24:18
allowing 30:22
almost 43:8,12
alona 51:3
along 3:12; 15:15,-21:22;
41:3:57:4
already 3:4; 27:2; 30:13;
31:22
alternative 2:8; 10:7,14,
16,24; 11.10,18.25; 12:5,
9,10:13:6,7,11,19,20,
14:14; 15:22; 16:2,9; 19:5,
16; 20:15.25; 21:20; 22:7,
13; 23:12;26:8;32:23;
34:16; 36:22; 48:14;
53 18,19:59:18,23
alternatives 6:24; 9:16;
10:6,9,13:13:14,17;
15:23,24; 36.23; <8:16
although 36:23
always 7:17,22
amount 20:5
and/or 44:7
animals 10:21; 15:5,11;
20:17; 23:4; 26:20; 39:12;
51:25; 52:10
annual 28:17
annuities 29:13
answering 26:6
anticipate 27:7; 42:5
anticipated 45:8
anticipating 46:18
anyone 7:18; 32:6; 35:13
anywhere 52:14; 555
apart 26.16
Apgar40:6
apparently 30:9
appear 5:25; 34-12
appeared 31 r
appears 44:2
appendix 6 4
applicable 30:8; 31:4;
34:8
appreciate 8:2; 44:24
approach 43:16,20;
44:4,17,23:46:2
appropriate 16:25:30:8
area 14:22; 15:16; 17:9,
12,12,14,18,20:18.5;
23 4.25,25; 24:2,16,25;
25:2,21,22; 31:17; 3913;
44:10; 52:11; 55:2; 56:5,6;
57:3; 58:16; 62:21; 6312
areas 33:21; 39:15
argue 45:21
around 22:25; 27:3;
50:15, 52:15; 55:12; 62:16
asbestos 2:9; 11:12,15.
20; 12:22; 14:19; 154,12;
16:6; 37:2,15; 48:21; 49:2,
2,24:50:13,17; 51:2;
53:4,11; 55 25; 61:23;
62:17,20
asbestos-containing
14:16
aside 28:14
assembled 9:19
assessment 19:21,50:2;
55:10
asalsting 6:21
assume 33:5,10,15;
35:5; 39:8
assumes 29:11
assuming 31:15; 32:21
assumption 51:15
assured 29:19
attending 65:25
audience 9:5
available 4:8,10,21;
6:16; 7:23:9:15
aware 31:16
away 11:15:31:14; 49:3;
54:10;58:18
B
B 14:21,21; 17:3,4,6;
50:2;56:6; 62:15,17.23;
636,7,11,12,13,14,17;
65:2
back 13:16; 16:13; 17:13.
16,16,24; 25:11;29:6,25;
30:6;35:13;38 15:43:8;
60:17
bags 494
balls 25:20
barrier 15:11
based 1312; 18:24; 20:6,
10; 29:13; 32:2; 40:4,9i
43 20; 48:24; 50:2; 51:11,
13,23
baseline 19:15
basically 3:9:20:15
basis 39:14;44:14;
61:25:65:12
batteries 42:9
battle 43 9
battles 437
become 6:6; 28:3; 41:3;
4319
becomes 39:17
becoming 43:11
begin 26:10
beginning 43:19.19
begins 26:11
behavior 41:22
bejesus 5315
believe 28:14; 34:24;
40:22:58:14
be low 58:9
best 7:15; 13:5; 43:2;
44:8; 52:3
better 1219; 50:21;
55:17
beyond 26.19
big 52:19:53 21
BIN 2:3; 23 22:25:16;
26:24; 34:23; 60:4
Billy 8:17
bio-sampling 26:24
biologists 20:3
biota 10:21;11:22
biotic 15:11
bird 2318
birds 23:25:24:3
bit 10:17,14 22,19:6;
44:12:60:12
bite 60:24,25
Black 47:16
bladder 49:4
bluegrass 25:14
bodies 31 6
body 31 11
bomb 44 20
boss 8:20
botanists 24:25
TAYLOR & FRIEDBERG
Min-U-ScHpt®
(1) $l4-botanis
-------
December 17, 1997
PROSPOSED PLAN FOR THE ASBESTOS DUMP
SUPERFUND SITE OPERABLE UNIT
both 65:7
bottom 22:4
Branch 810
Briefly 7:9; 14:13; 45:6;
50:23
bring 7:21; 25:11
broke 512
Brook47:l6; 62:16.18,
639
brooks 34:18
brought 53:5;65:2,15
Build 62:8,9
building 3:16
bulldozer* 24:6
Burr 7:19; 25:12; 46:20,
20; 47:8; 57:19; 58:11;
Cl:5,10,16
burrow 15:1% 20:21
burrowing 15:5; 23:5;
39 12
busy 2.6
Butadiene 59:15
c
C-A-S-S-A 30:4
calculate 29:24
calculated 51:8
call 6:6; 7.23; 57:13
called 5:24; 9:25; 11:11,
18; 53 25
calling 14:22; 49:17
calls 3:22
came 2:21; 43:13; 52:18
Camp 8:20
can 3 3.5; 5 3,6; 6:13;
7:15,21; 14:25; 16:17;
17:2,15; 21:6; 23 7.22;
24:4; 25:18; 29:19,21,23;
33:6,8;35:13; 36:17;
37:21; 38:19; 40:3; 41:17;
42:7,13,14;43:15;45:7,
11;46:7;47:2,11;51:3;
52:5:63 14; 64:15; 65:3
cap 11:15,15:3,7; 18:3;
23:3,5; 24:7; 25:13; 39:12,
15; 53:10; 65:2
capacity 35:22
capital 27:20
capped 24:17; 62:21;
63:17
capping 37.3,24; 62:23;
63:19,20
cards 8:18
carry 50:15
care 53 6; 54:2
cese 34:19;64:25
CASENBERG 57:8,9
CASSA 30:3.3; 34:3,3.
24.25, 25.36:3; 54:17,19;
55 22, 56:7, 21; 57:17
cause 145
Cedar 53:25
centimeters 58 7
CERCLA 10:8
certain 29:14; 34:6; 48:4
'certainty 7:13; 33:12;
46:11
cesspool 43:11
chain 20:12
change 8:14; 18:4
characterizing 12:21
charge 43:25
cheers 43:3
chemical 26:17; 542
chloride 59:14
choose 24:12
chose 63:11
circulated 31:10
circulating 32:9
clarification 57:8
clarified 34:22
clarify 51:8
classified 48:17,20;
58:22
clay 57:20:58:5.12,16
clay/silt 58:22
clean 9:17; 10:10; 15:10;
46:3; 50:7,8;63:14; 65:2
cleaning 2:9; 60:11
cleanup 9:14; 30:6;
46:13,14:60:8
clear 34:11,19; 37:25;
38:5.7
Close 56:17
closed 23:24
closely 9:6
Coast 65:7
collected 13:4
Colorado 6.15
comfortable 6:8
comforting 64.24
coming 2:25; 7:17; 43:15;
47:17; 50:5; 56:25
comment 2:8; 6:9-, 21:5;
30:12;31:7; 32:13,18,23;
34:10; 36:14; 44:18; 47:7,
22; 48:8, 54:19,20,21;
64:23
commenting 55:3
comments 3:11; 4:12,
14.18; 5:2,17,18,24; 6:3,
11,12,16:15,21; 238;
28:7; 29:22; 30:4; 31:24;
33:13,22.44:25; 64:20,
21:65:18,23
comments/questions
66:2
commingled 55:24
committee 43:14
communities 18:19
community 2:16; 3:7,12,
23; 7:19; 8:5; 535
compared 43:9; 54:15;
5512,13
compatible 1516
complete 26:9:32:5
completed 4:22;9:19,
23; 11:4; 16:24; 50:3
Compliance 8.10; 30:7.9
compliment 42:20
comply 35:16, 24
complying 13 21
component 38:13:55:18
compounded 29:14
compounds 59 4,11,12
computers 41.17
concentrations 52:2
concern 9:12; 15:4;
18:22; 28:11; 30:18;
31:18; 36:18,21:60:5
concerned 40:12; 54 22
concerning 30:9:37:20
concerns 3:23:5:11,13;
9:16; 30:5; 31:7; 45:19
concluded 10:5; 56:9
conclusions 98
concurrence 33:9
concurs 3310
condition 19:15; 20:25
conditions 20:6
conducted 9:10; 11:3;
21:24; 55:14,15
confining 57:19
conform 226
confused 49:15
confusion 57:11
conjunction 26:25
Conservancy 189
conservation 40.5
consider 47:3; 57:24;
61:23; 63:2
consideration 6:25; 532
considered 31:13;
46:23; 48:18.19.21; 61:6;
62.22
considering 2316
consist 15:9:22:16
consistent 22:8,11,19;
24:25; 26:22
consolidate 17:23;
62:20; 63:11
consolidation 16:24;
17:13; 18:3; 36:19; 37:2;
38:14
constant 62:11
constantly 36.19
constrained 25.22
constraints 44:3
construct 14:8
constructed 27:24
construction 37:12,13;
38:23; 42:2; 48:19
Consultants 6:20
consumption 51:23
contact 20:18, 23:51:14,
19,20
contain 62:10
contained 11 20; 59:19;
613; 63:16
containing 11:i2
contaminants 9:12
contaminated 6514
contamination 31:12;
57:22
continue 714,15; 18:14.
16,20; 22:23,25; 27:2;
29:8; 37:7; 42:2,6
continuing 8:3
continuous 36.24.43 10
contractor 3518; 36 2;
65:13
contractors 218; 30:21;
3115
control 8:12:36:10;
38.13; 41:25; 659
controlling 11:13
controls 10:18; 21:7,18,
22; 22:2,11,14; 2313;
63:19
copies 31:4
copy 73
corner 10:12
Corps 11:3:34:5,11;
353.17; 36:2,48:24
corrective 39:20
corrugated 63:6
cost 14:8; 15:22; 27:20,
23; 48:17,23,24;6317
COSTELLO 6:4,19; 7:2,
8.8:6.22,24; 9:2; 17:2,5;
21:19; 24:22; 25:8,19;
26:11:27:19; 28:12;
29:10,21; 37:11; 38:10;
39 5,10; 40:2,11,16,19.
25; 48:21; 49:20; 50 22;
53:17; 559; 56:2.12; 57:7;
58:2,19; 59:5:61:22:62:7;
65:5
COStty 38.18
counter 58:19
country 52:21
couple 39:9:3.6; 14:25;
16:5; 2 6:6
course 4:15; 25:13,17;
37:13
court 4:13,5:6; 47:11
cover 17:15
covered 20:20; 37:16;
52:5
covering 20:16; 50:17
crapping 64:4
creirting 52:13
creeks 34:18
criteria 13:15.22; 15:9;
30:6
cross 15:18,18; 58 3;
62:18
crushed 1511
culverts 636
CUrlOUS 39 24; 48:16
current 20:6,21:25, 22 9,
17
currently 21:25; 22:22,
24; 23 24; 26 22. 41:12;
56:18,61:11
cuts 28:17,22
daily 61:25
dam 628
damage 17 22, 25:5;
39:21
damaged 39:18
danger 49:18,19
dangers 5919
data 12.24,25; 133,9;
*::18, 22;42 17; 59 7,9
date 14:18; 36:9
dated 132; 56:16
day 37:14; 40:20, 54:13,
626
days 40:24
deal 45 15.19,46:6;
50:12,16
dealing 60:15; 655
dealt 63:15
debris 48:20
decide 44:7
decision 4 21.12 16,
13:11; 18:13; 65 24
dedicated 28 19
deed 22 2
deemed 54:24
deep 17:14; 57:15
deeper 57:14
defer 521
define 9 12.13
defined 21:8; 23 14
defining 7 6
definitely 52:25
definition 394
demonstrated 20:10,
56:14
DEP 32:7,10; 33 18, 34 8.
13; 354; 43:13,14; 44:12
Department 45:15
depth 58:9,10
describe 6:24; 65:3
described 36:15
description 16:23
design 25:3;38:14;65:8
designed 1124; 142
detail 5024
detectable 51 25
detected 39 21
developed 27 25
developer 30:24
developing 25.2
devices 4113
dewatering 3417
~ietzman 2 13.49:17
different 16:2
both - different (2)
crl
TAVT	Ol n»Trr\oci>»-
-------
PKOSPOSED PLAN FOR THE ASBESTOS DUMP
SUPERFUND SITE OPERABLE UNIT
December 17, 1997
dig 50:15
direct 5114, 18,20
directly 2017.31:6;
43:24
dirt 51:16
disappear 29 20
discus* 513; 14:25
discussed 453; 47:23
discussion 5:9,14
disposal 48 23
disposing 48.18
disturbance 52:13
disturbing 5416
diversion 3418
documenl 5:23; 6:2; 7:5,
9 23, 24; 28:3.32:16.
36:22
documentation 32:9.
364
documents 3 18,57:23,
25; 65:9
DOEBBLER 5:22; 6:15;
7 9.8 8,17. 21,23; 19 9,
21:12,16; 23:21; 25:16;
26:21; 27:10,13.17;
28 18,20,23.293,32:6,
24; 35:15; 36:8, 37:4; 41:6;
42:11; 45:6, 11; 52:16;
59 3, 15, 21;62 22,63 2.
5.6418
dollar 6018
done 12:15; 14:25; 16:11;
19 15, 16; 20:9,14; 25:10;
36:9; 37:5.13; 40:6; 41:21;
44:15; 51:14,21
door 545
doors 54 4
down 6:13; 24:19; 38:4;
47:17; 52:23; 54:9,10;
58 10,12.60:2,64:9; 65:7
download 41:17
downstream 27:3;
43 22, 24; 46:7, 56:22
draft 32:10
dragged 53:7
drainage 34:17:38:13
drains 64:8
drinking 31:14,17;
54:25, 55:13; 57:12,13,21
drive 53 6
driven 167
drum 11:2, ll;58:ll-
59:10
drums 11:8; 12:14.
14:14; 49 23; 56:8, 13.15;
58:24; 59:6,11,12,17,22
dump 2:9; 49 3; 55:12
dumping 47:16
durable 38 25; 42:9
during 36:19; 37:2.13;
40:21; 41:24; 42 2,46:23;
58:11;65:7
dust 54:5.6,11.12.13
Each 1313,16; 15:16,
IB, 22, 24
earlier 7:11; 29:18; 49:21
early 11:5
easily 21:6
east 2:11;65:7
eat 20:21; 51:16
eating 20:22, 51:24
ecological 19:22; 50:4
ecosystem 50:16
edges 15:15
effect 3112
effectiveness 1323.24
effort 3:"\ 34:13; 42:21;
46:15
efforts 46:14
eight 43:12; 58:14
eighty 43:23
either 28:8; 56:10
electronic 4112
elevation 3816; 39 24;
40:14;41:5
elevations 40:8; 41:2,15
else 26:18,20:52:20
emphasis 43:12
emphasize 57:5
enacted 30:15,16
encapsulated 52:5
end7:l3; 65:19
enforcement 34:6
engineer 88
engineering 9:22,25;
10:3; 13:5,8;35:21;41:10,
52:18
engineers 9:20; 11:4;
34:5.12; 35:17; 48:24
enlightenment 46:5
enough 5:3;7:7
ensure 65:14
environment 11:16;
1319; 14:6
Environmental 2:17;
6:21;8:9.9 20; 30:10;
31:2; 34.7:61:24; 65:11
environmentalist 47:25
EPA 28 5.6; 32:12,15;
34:2; 44.12; 45:18; 46:9;
51:10
equipment 24:6
erode 38:17
eroded 39:15
eroding 11:14
erosion 36:10:38:4,12
establish 43 7
established 22.15; 39:25
establishing 43:14
estimate 26 8; 27:20,
48:17, 24
etcetera 30:11
evaluation 30 6
even 11:17, 25,12:6;
13:10; 16.7,7; 20:20,
31:21; 36:6; 40:9;60:12;
64:5
evening 2:2,2l;6:9;
14:12;26:15,65:20
event 4010
avents41:ll
•very 35.6; 41:15,16;
54:13,58 13,62:6
everybody 48:3; 65:19
everybody's 5:18
everyone 7:3:64:24
Everything 32:8,12,15;
60:19
exactly 35 21
example 16:2
excavated 58.12
excavating 12:2,10
excavation 53:18:58:12
except 44:11
Excuse 8:7
exlat 36:4; 56:25
expected 35:11
expenae 606
expensive 60:9
experience 8:4; 18.16;
43:3
explode 44:20
exposed 20:17; 37:15,
52:3
exposure 20:5
expound 23:22; 26:25
extends 58:10
extensive 58:20
extent 24:22
extra 232
extremely 29:7
F-E-N-S-K-E 188
F-O-X 23:10
fabric 15:17; 38:6,21,22;
39:17
facilities 32:11
Facility 8:10:12:11:496
fact4:5.17:7:16; 19 25;
23:20; 33:3; 40:14; 52:24;
54:25; 55:4; 57.5
fair 29:3
fairly 5:15; 42:8
falling 61:24
falls 62 5
far 17:13; 22:13; 25:8;
26:19; 28:10,12; 38:12,
21; 395; 50:13; 53 2;
60:19:65:10
feasibility 6 22;9 9,10,
18,21; 10:4,5:116;
12:13,17; 40 3; 41:9; 58 4,
20,23
February 4:3
feces 64:6
federal 9 11,13:13; 28 2.
30:10; 32:10; 34:20
feed 2518
feel 6:8:12:20
feet 17:14; 52:11; 57:15.
16:58:9,14
fences 10:19
FENSKE 18 7,7; 19:18,
21:2; 25:21; 28:16,19,21;
29:19:42:19,19.45:4,8,
25; 47:7; 58:24; 59 16,24.
64:22; 65:16
few 11:8, 35:4; 55:15
field 64 5,6
Figure 13:15;30:5;32:2,
37:24
fill 17:21:35:2,10:64:25;
65:10
filled 36 6
fiher 15:17; 38:5, 21, 21;
39:17
final 14:9; 25:3:32:16
finale 64.22
finalized 32:13
finally 15:13
find 31:8
fire 3:25
firm 35:21
first 2:23; 3:13; 4:2;
1317,19,30:5; 41:18,19;
42:20; 43:7; 53:23
Fish 2:18;3:8:4:6,19;
89; 9 19; 11:21; 14:23;
28:13; 39:21;46:20;64:2;
65:6
five 12:9; 17:3,6;27:13;
28:6; 31:19; 60:25
fix 50:25
flat 17:18
flexible 394
flood 17:19; 18:5; 38:16;
39:25; 40:13
flooded41:4
floor 16:13
focus 5:£ 30:20; 44:2;
47:2,22
folks 5:11
followed 51:9
follows 4:16
food 18:18; 20:12; 51:16
fooHng 51:5
foot 17:24
foremost 13:17
form 6:13; 36:6
former 2:12; 25 11
forms 611
forth 18:21; 22:20; 29:6,
15
fortunate 40:16
Foster 2:17; 6:21; 9:3,4;
19 13, 41:8, 50:3: 51:7
found 19 21:51:12,25;
593,6
four 18:2; 24:17;60:14
FOX 23:10,10
Fox's 44 :12
fragmented 4 5:25; 46:4
Frank 21:4; 37:23
free 315
freedom 30:23
friable 36:17
frogs 20:22
front 6:12; 29:13
FS 55:16
fund 27:12; 28:14.19
funding 28 10,13:29:19
further 11:17; 12:2;
1310; 15:25, 25; 44:20;
60:2; 64:23; 65:23
future 5:13; 6:10:11:19.
12:21:47:23; 49:21,22;
50:13:62 3
&-R-E-E-N-W-A-Y 16:19
garage 54:4
gather 62:15
geese 25:18; 64:3
general 10:4:38:22,-60:6
generally 10:3,9,20,23;
14:16; 57:16,17; 58:16
generated 59:9
gentlemen 29:25
genuine 42:24
geologist 57:io
George 303; 343
geotechnical 58:20
gets 50:15
given 33:13; 34:11; 35:3
glad 2:21,22
God 17:6
goes 53:3; 54:8:64:8
goH 2513,17
Good 2:2; 8:4; 41:4; 42:3,
15; 47:7; 58:2; 63:7
governing 31:6,11
gradation 65:10
grade 15:10
grain 58:22
granted 34 .6
grass 24:20
Great 2:4,10:31:18;
43:6,16;47:18; 50:24;
58:10; 62:5,6,16; 64:22
greater 812
Green 18.7
GREENWAY 16:18.18.
22; 18:6; 36:13.13; 37:9,
18
grind 54:3
Griswold 9:4.19:9.11.
13.20.41.6,7,7,42:7,14;
-------
December 17, 1997
PROSPOSED PLAN FOR THE ASBESTOS DUMP
SUPERFUND SITE OPERABLE UNIT
51:6,6; 56:17; 59:7
ground 4 23,04 8
groundwater 1219;
14:17,19; 50:7; 55:11;
57:9,14,15,62 10
guess 4 24,18 2J; 27:4
guidance 51:10
guidelines 1312
guy 4 24
H
H-l-N-K-L-E 24 15
habitat 25 7,10
half 18 2
handle 12 12,44:9:49:7,
52:4; 5312; 5517
handled 49:4
handling 36:18
handout 30 7,31 B
hands 5116
happen 27 24,44 5,10;
46:1B
happened 40 20
happening 46:8; 58:8
happy 7:18; 19:10
hard IB: 10; 196
Harding 2:12,3:16; 31:10
harm 146
Harold 49:10
hasn't 44 11
haul 63:8
hauled 12 5; 55:20,23
hauling 48.15; 52:19,23;
538
haven't 33 4; 50:24,
60:23,24
hazard 49:16, IB; 52:13;
54:24; 60:23, 25
hazardous 46:2.48.19;
49:7; 60:8,11
headway 43:18
health 11:16; 13:18;
18:24; 50:4
hear 5:4;7:18; 52:12
heard 36:15:60:19
heart 8.2
heavy 24:5
Helen 18:7; 32:24; 33 24;
34 2, 42 19,46:22; 49:20
help 35 6
herons 20 22
higher 16.7,7; 18:17
highly 58:6
hiking 63:15
Hill 2:12; 3:14; 41:3
HINKLE 24:15,15; 25:6;
62:13,13,25;633; 6423
hire 35:20
holiday 2 6
homes 52 23
hope 316,30 12; 34:21
Hopefully 17:25
hoping 2:24; 4:25; 5:8
house 97
houses 3.-24:31:20
How's 28:24
huge 53:4
human 18.24; 1918,23;
24:8
humans 18:15; 19:3,24,
24; 51:19
hundred 38:16; 4323;
57:3
hundred-year 17:19
I
Idea 17:25; 41:4
Identify 33:24
Immediate 3117,4916,
18; 50:11,19
Impact 17.11; 19 16,22,
22; 20:10; 55:7
Impacted 18:19,20;
20:13:51:19
Impacts 51:22
implementable 14:7
Implemented 16:11
Implementing 23:12
implication 17:20
Implications 18:5
Important 54; 36:24
Improvement 34:17;
60 23
In-between 15:17
Inches 15:9,10
Include 22:18;474
Included 27:7
Includes 21:21,21; 27:14
Incorporate 3:11; 4:17
Incorporated 4:20;
65:24
Incorrect 55:2
Independent 9:20,22;
35:21; 59:10
Indicate 14:18
Indicated 29:18
Indicates 32:3,18
Indirectly 46:22
Individual 6:3
Individually 5:20; 56:9
inert 62:2
Information 3:14;4:20;
12 17,23:28:6; 33 4;
42:22; 44:21:56:15
Informed 33; 7:15
Infrequent 20:2
Initial 28:15;41.18
Input 4:11
Insignificant 56:11
Installed 63 5
Instance 35 7,9
Instantaneous 41:21
institutional 10:18; 21:7,
17,21.22,25; 22:11,14;
23:13
Instruments 42:9
Intact 56:10
Integrity 23:6,24:7;
39:14,16
intend 53 8
intended 21:8; 38:2,11
Intent 22:6;23:19,19,21;
35 8, II; 36:5
intention 25:15
Interest 29:12,15
Interested 16:23
Interim 31:2i;41:20
Interior 4515
Internment 35:3
interrupt 47:10
Into 2:14;4:20; 10:25;
14:5;15:6,12, IB; 18:13;
19 5,7,21:6,13:23 5;
26:4; 30:13,14; 38:18;
39 12.44:22:47:16,17;
48:6; 49 3; 50:15,24, 53 2,
5; 54 :9; 55:4,10; 59:2,18;
64 8,9,9.65 15
Invested 27:18
investigated 44:11;
48:14
investigating 55:20
investigation 44:15:
46:23
investigations 55:14,16
investment 44:7,8
involved 25:2:33:21
Involvement 7:12,14;
32:14:33 2; 42:25
Island 44:23
Issues 10:23:37:19:45:3
Item 30 7
Itself 30:22;52:8
J
J-A-N-S-E-N 47:13
JANSEN 47:9,9,13,15,
24; 53:24;62:8; 63:21,24,
24:64:2,13,16,19
January 6:10; 65:22
Jersey 32:7,10; 34:5,8;
35:4
Jersey's 32:25
Julia 25:25; 29 5,39:23
Julie 7:25
jurisdiction 34:21
K
keep 3 3, 3; 7:14; 45:2;
53 11
Kentucky 25:14
kept 3619
kind 24:20, 27:6; 32:19:
33:6
Knolls 53 25:56 23
knows 7:25
KOCH 2.2,3; 5:18:8.7;
33:24:34:23, 23,35 2;
60:3,4;64:11,14
Kris 5 21; 6:15; 8:6,8,14,
14:25:33:6
Kuwait 53:25
L
Land 18:9; 22:3
landfill 17:17:43:24;
46:22; 47:17; 52:20; 56.23
large 25:8
last 9:3,6,7; 12:9; 40:17;
41.5; 48:25; 54.19
later 40:24; 45:12
laws 30:10
layer 15:13; 384,13;
57:19:58:5,21
layers 15:17; 23:6
teachable 5517,21
leaching 12:20; 14:5
lead 20:13,19; 50:4;
54:22; 5511,18,21; 56:3,
5
lead-contaminated
14:20,4925; 53:9
leakage 56:10,14
learn 45:23
learned 30:21
least 108; 37:25; 384;
57:6
leave 42:7:51:3.61:7
leaving 51:5
led 19:4
left 42:13.49:25; 50 14
lees 17:24:57:15
lessened 59:20
letter 339
level 30:25; 57:21,22;
62:11
levels 18:17; 52:2; 54:23;
55:11,12,21
liaison 7:20
I&rary3:i5
Ufa 64:13
likely 18:20; 25:9
RmH 10:18; 17:11
limited 5:14; 20:6
limits 9:13
line 45:17; 57:4
Nner 12:6:58.8
linked 57:6
list 3:4, 5:45:14.20
little 8:15:10:17; 14:22;
19:6; 20:7; 35 6; 44 12;
5312; 54:12;60:12;63:3
living 51.24; 531 5
loaded 49:3
local 3:22.7:19,18:18;
30:14,20; 31:6; 57:3
located 2:11; 17:8
location 12:4
logical 59.16
Long 2:12,314:27:8;
41:3:42:5
long-term 1323; 22:15;
27:21,37:14.39 5,10
longer 37 15,43 15
look 318; 10 8,11; 12.14;
1315,14:3; 15:23; 21:19;
38:18:50:22
looked 10:25:11:10;
12 2.10,21; 15:24; 16:8;
27:22; 33:4; 59:8
looking 4:12;39:12;43:8;
44:19,60:18.62:14
lose 17:15:25:19
losing 6i:io
lost '31:2
lot 17:9,25:19:30:24;
38:23,44:21:60.7,10,10,
13.13,14,15,61:13
loud 5:3
low 52:2; 58.6
M
M 21:22, 22:18
ma'am 24:14
machines 52:22
mail 4:18
mailed 6:14
mailing 3:4,5
main 30.18; 5217
maintain 23 3
maintained 22:5
maintenance 27:25
majority 58:13
makes 58.2
making 6:8; 48.6
man 54:5
manage 24.12
managed 50:10
management 21:24;
24.10,11; 53 3
manager 2:3:94; 33:8
managing 22:22; 46:2
manner 22:19
manuals 51:11
Many 9:9; 30:20; 38 24,
24;54:6;64:14
map 62.14
mapping 40.5
Mark 9:4; 199,12,41:6,
7; 51:6; 59 5
Marshall 2 16,20; 5:20,
25:6:5; 16:14,20,213,
10; 23:9; 24:14; 25:24;
2925:31:23:33 17;
3612; 37:21;44:24;
47:10, 14,21:48:7, II;
BroiinH . MmKiii ca~\
-------
.PROSPOSED PLAN FOR THE ASBESTOS DUMP
SUPERFUND SITE OPERABLE UNIT
December 17, 199:
49 9, 11, 14:53 22; 5417,
62 12,63:22,25; 64:20.
6518
material 12 3, 5,20,
14 15, 16; 15:6,14; 16:4;
36:15, 17,18; 38:19,22,
22, 25; 39:2,63:8.65 12,
14
materials 14 4,24;
15:18; 20:16,19;31:9.
38:18,39 16,52:3,4, 5,
54	24,56 5.24
May 4 2.4;5:1 l;fi:18;
9:8,9, 13; 12:7; 14:5,24;
1 5:5; 16:7.15; 26:24; 31:2;
35 6,40 14; 55 20, 56 25,
61	5. 25; 65 21
mean 18:15; 21:18; 24:4,
8,33:6; 39:8; 44:18; 46 5,
62	19
meanest 4 24
means 18 15.38 17; 397
measures 46 13.14
meet 15 7.358, 11
meeting 44.5,16; 5:10;
6:19, 14 12, 26 12.40 4;
44:6; 47:23
meetings 3:21; 33:18
mercury 20 14,19, 59 6,
10
message 43 15
met 9:7, 24; 36:5
metals 18 17; 20:20;
51:12
methylene 59:14
metropolitan 48 2
mkJ-'80s 40:6
middle 22:14
Miele43 23.46:22; 473
might 19:17; 24:7; 33:7,
34:22; 35 5;44 4,10,
55	23
migrates 50:9
miles 3114
million 16:5,10; 27:14,
21,44 8; 53 13,15,17, 20;
59:25; 60:7,13,14,18
mini 27:5
minimal 53:9; 61:2
minimum 158
minor 33:22
minus 58 7
minute 15:2, 52:12
minutes 41:16
mission 18.25; 43:25
mobility 14 3
modeled 1914; 2012
modeling 18:12; 20 9;
51:13,21
modest 29.7
moment 8 7
money 28 14;29 8,H;
45:16,60 7,10,13
monitor 11:21; 40:23
monitored 40:21
monitoring 3:23; 10:20;
11:19,13:25; 21:7,13,20.
21.23:22:8,10,15,17;
26:15,17; 27:7,15,22;
28:7,15; 29:8; 36:22,25;
37:5.7,12.14,16,39:6,
11,19:41:13:42:3.6:
46:17, 24; 47:3
monitors 41:19
month 9:23
months 11:9; 14:25;
16:12; 26:9,9,10;41:16,
18,19; 50:6; 55:15:64:15
more 8:15; 10:17; 12:6,
17,23; 19:22; 20:10,13;
25:5; 30:23; 38:20; 39:8;
45:23; 51.4; 52:13; 57.3,
16,17; 60:14:64:21
Morris 18:8
most 7:24; 25:9; 57:12,
12
mound 50:13
mouth 51:17,17
move 52:15; 63 4
movlnfl 36:17;62:17
mowing 22 18.23:2;
24:21,23
much 4 10; 5:8,33:16;
44:11; 60:2; 65:25,25;
66:2
municipal 316
must 35:8
myself 28:24
N
name 2:3,3:5:5:4,5;
8:25; 16:17; 21:4; 23:10;
37;21;47:11;48:12;
49:12; 53:23; 6322
narrow 47.2
nasty 38:9
nation 35:5; 46:10
National 2 4,10,45 14
nationwide 34:9
native 24:18
natural 58:8
nature 36:14;6l:4
near 52:14
neartoy 552
nearest 3113
necessarily 24:8,23:
639
necessary 7:16
need 23 3:356; 4 5:2,22;
50:16;6l:22
needs 494; 50:10
negotiating 32:11
nel 184
neutralize 38:9
new 8:11; 32 6,9,25;
34:4,7; 35:4; 42:9; 44:21
nice 2.22; 7:20; 24:2
nickel 60 22
nil 60:19
nine 1314
noise 53:14
none 20:16; 60:19
nonfriable 14 17.36 16,
16
noted 66:3
nothing 1915; 20:14;
48:4, 5; 54:15;6l:6
notice 4:13; 39:18
notlced8:13:18:11
number 2:24; 7:24,
29 13. 24,41:13:42:15;
53:14,21
numbers 59 6
nutshell 15.21
o
0 21 22,22 16
objectives 9:14; 17:10
observations 41:2
obtain 357,12
occur 65 21
occurred 33 23
occurs 69
October 41:5
oft 163.6,48:15.18;
53:8,19:55:20,23
Off-site 48 23; 564
office 8:14
Offices 8:12
official 366
officially 237
officials 3:22
often 43:5
once 11:20; 18:3,27:24;
44:21,47:15; 56:13
one 2:17,24; 3:14,15;
4:2;7:4;8:7; 13:13,16;
15:8,16, 24; 17:10; 2311,
15; 26:6; 32:3; 33:5; 34:9;
35:4; 37:14; 38:7; 40:18;
41:9; 42:25; 43:7; 48:15;
49:22,52:17; 53:5:59:10,
14; 63:10; 64:23
one-mil* 55:6
ones 45:18
onty 4:5; 17:14; 34:9;
57:18; 60:20
open 3:24;9:7; 16:14,19;
23:21; 28:7
opened 23:25
Operable 45:13
operating 54:11
operations 27:25
opportunities 5:12
oppose 32:20
opposed 18 24; 33:5;
63:18
opposing 33:11
opposite 23:13	
option 2:9; 13:5
order 55:22
ordinances 4318
organic 58:6; 59:12
organization 7:22
Oli-1 33:20
OU-3 4:9; 5:9,14; 16:16;
18:17; 45:2,20;47:22;
49:16:64:21
out 2:6,23; 3 3.6; 7:16;
12:2,7; 24:3; 28:23; 29:17;
3520,22; 36:7,41:10,14.
16,23; 4315; 50:9; 51:18,
25;52:25;53:15;56:17,
25:58:25; 59:22; 60:22;
62:8,10; 64:5,5,6,6
outer 6.16
outlli.b 9:16
outlined 39:20:40:2,4
over 2:15; 3 9:6:18;7:21;
11:23; 16:12,13:1917;
27:8, 22; 29:7,12,14;
39:13; 46 3; 51:14; 52:10;
53:6,7; 54:12;63 8.10.
14,16,17; 64:4,7
own 30:24; 31:20; 48:22,
61:3
owner 30:21
P
p.m 66:3
page 10:11; 18:11; 1912,
14; 21:19; 22:4,12,13,14;
23 13:50:22
paper 6:14; 53:15; 65:17
Parks 18:9
part 318; 4:14; 6:6; 8:3;
24:9; 27:23; 32:17; 37:9,
11:39:10,19:42:8; 56:19;
59:22
particular 34:15; 38:3;
60:4
particularty 1817; 387
particulates 15:5:50:14
partnership 42:24
party 32:10; 34:12,35:19
passed 43:19:46:4
p««t 3:9,25; 16:5; 25:11;
33:18; 52.23; 55:15
Paul 6:19;7:9; 8:20.25;
2310
pay 61:20
paylng6l:ll, 12,14,17,
18
Penny 24:15:62:13
people 3 3,22,20 3;
24:3:33:19:48 4. 54:7
per 58:7
percent 29:11
performing 142
perhaps 33:9
period 27:22,28:6; 29:7
12,31:21; 51:15
periodic 3:21; 28:3
periodically 39:13
periphery 37.6
permanent 38:2,6,11,
11,39:3.7.9
permeability 58:6,21
permit 358.9.10.12.16;
36:6; 49:6
permha 35:9
permitted 12:12; 259
permitting 35:24; 36:11
perpetuity 21:9; 23:20
persist 4510
person 8:15
personal 37:6
personnel 21:24
perspective 60:12
phase 37:2.3:65:8
phrase 21:7
phrased 54:20
physical 26:16; 61:3
physically 16 24
pick 52:11
picking 52:10.19
piece 6:14:44:2:46:9;
52:8
pits 58 13
place 12:23:17:17,-22:5;
26:23:41:25; 42:8,13;
44:9; 46:16; 47:25; 49:25:
53 11, 24; 62:23,64:4.7
placed 49:4
places 42:15:61:13
plain 18 5:3925
plan 4:8,9,11;6:23;7:4,
25:10:12,13,15; 13:16;
15:21; I6:l6;21:13;
24:10,11,253; 26:14;
27:25,-28:7; 29:17:35:19;
37:10,12,39 19:49:21
plans 33 22:36:10
plant 1514
plants 47:16, 20
play 34:13
please 3 2; 5:5; 16:17;
37:22; 48:12; 4912:63:22
pleased 1911
pleasing 38:20
pleasure 8:25
piot 4117
point 2:14; 5:16; 27:13;
43:5:49:24; 52:16; 57:8,
11; 58:2; 60:17
pointed 41:10
points 7:6; 41:9
pollution 8:12
posed 11 7
positions 62:15
possibility 54:22
possible 4:9; 34 22;
53:12
possibly 18:2:38:18;
56:4 	
-------
December 17, 1997
PROSPOSED PLAN FOR THE ASBESTOS DUMP
SUPERFUND SITE OPERABLE UNIT
Post-excavation 56:12
potential 11:2,7; 12:20;
14:6; 19:22,49 22; 50:4,9,
12; 55:21
potentially 1722
practice 22:17
practiced 21:25
pre-publication 32:15
precaution* 65:3
precedent 19 4
predators 20.12,13
predeslgn I2 25;4l:20
prefer |6:20
preferred 2:8,9; 13:5,7;
32.23
preliminary 319
prepare 5:23:65 8
prepared 7 21,16 4;
56 18, 20
preparing 6 22,22
presence 1418; 47:3;
49 22
present 2 7; 9 8,11,14,
27:21; 29:10; 51:12
presentation 7:20,26:7
presented 10 13.12 25;
13 12
preservation 43:6
press 39 7
presume 36:3;6l:18
pretty 414
prevent 43 10
preventing 11:14
previous 4 3
prey 20 22
price 16:6,10,61:11,12,
14,17,18, 20
primarily 19:24; 53 9,
593
primary 18:25
print 17:25
prior 3314
priority 45 14,17,20;
468
private 30:23; 31 18; 55 5
probably 7:24; 31:5;
32:8; 54 9; 55 5
problem 11:2,5;44:13;
56:3; 60:2
problems ll:ii, 13
procedures 51:9
process 7:12, ]4;8:3;
20 II. 30:16; 33:2, 36:20,
¦42:21, 24,43 11;44:7;
609
processes 32 3
program 2 15,13 25;
26:23, 27:7; 29:8; 34:8, 23;
35 3:42:8
project 3:20;4:25;8:8;
92,4. 17:10; 33 7; 34:12,
35:5.46:14,24
projects 37 3	
properly 50:10
property 30:24
propose 27:12
proposed 4:8,8,11;
6:23; 7:4,25; 10:11,13;
1316; 15:21; 16:16;
21:13,28:15; 3519
proposing 15 3,6;
52:14,53 10,19
prospect 48:15
protect 4 3:15,20
protected 38:17
protecting 11:16; 13.18
protection 10:22, 12:7,
30:19; 46:16,16
protective 46:13
prove 365
provide 25:6
public 3:15.19;4:7.10.
14,22; 7:11,13; 11:16,
13:18; 14:6,10,11; 28:3,
5; 31:14,1M2:21; 47:5;
58:17;6l:10,11
publicly 23:17
pull 17.16,23
pulling 3814
purpose 5:10; 14:11;
17:10
put 12:5; 18:3; 20:18;
24:11,24;28:25,2923.
42:9; 44:8; 60:12
putting 1019,19,123;
52:22
Q
quality 59:19; 65:9
quarterly 39:14
quick 31:25; 37:25
quickly 598
quite 497
R
radius 55:6
rafters 54:6
raise 30:25
raises 62.5
rambling 19:6
ramp 10:10
ramps 10:16
range 10:6
ranging 10:7
rapidly 40:9
rate 62.6
rather 17:15,23; 18:10
RCRA 49 7
RO 48:20
reacled4i:il
read 50:23; 56:23; 57:23
reading 22 4; 57:24
readings 42:16	
ready 7 10
real 7 20,43 18
reality 40:14
realize 36 16; 57:12
really 3 10,8 4,24 18;
27:5; 44:24; 553
reason 149
reasons 52:17; 63:11
receive 32 14
received 32 12
recent 5514
Recently 8 10
recommendation 11:6;
55 4,8
recommended 12:13,
18,55 16
recommending 13:6;
15 21; 16:9
record 319:4:15,21;
32:17; 36:5; 41:15; 47:22;
65 24
records 41:22
redeploy 4214
redo 38:8
reduce 17:25
reduction 14 3
refer 43 6
referencing 7:5
referred 26:14
referring 34 24; 56:22
refers 19:14
reflect 40:14
Refuge 2:4,10; 14:22;
17:12; 18:25; 20 3;21:24;
22:10,17,21; 23 23;
24:10,12,25:2; 26:22;
43 7; 54:2; 56:5,6; 63:12
regard 23:16,18
regional 43:13,16,20;
44:4,17,23; 4 5:5
regular 6512
regulation 9:11
regulations 13:13; 26:2;
30:20; 34:7; 48:22, 50:18
regulatory 13:21; 15:8;
45:18
reinforced 13:9
reiterate 7:10
relate 3:19; 4 5:5; 46:12
relates 44:17
relations 2.16; 3 7
relative 62:15
relatively 17:18; 50:7,8;
56:10,60:9; 62:2
relevant 30:8
remaining 14 15
remedial 11 23; 226;
26:14
remediating 15:25
remediation 30:22
remedies 4:9,9.33 23
remedy 13:21, 24; 14:2;
20:24; 27:24
removal 10:25; 11:12;
14:24; 16:3; 56:4
removed 11.8; 14:14;
52:6; 56:8,13; 58:25,
59:17
removing 12:14; 48:25
reorganization 8:16
repair 3*22
repeatedly 44:13
rephrase 21:6
report 10:2,3; 12.25;
16:4; 28:4; 41:20; 50:4;
56:16,18,19; 58:4; 59:8
reporter 4:13; 5:6; 33:25;
47:12
repositories 3:14
repository 32:16; 36:10
represented 33:18
representing 188
require 357
required 4:6; 10:8,21:12,
14,35:7,23; 37:17,39:13;
51:10; 65:13
requirements 13:22;
15:8; 30:9; 31:4; 34:20;
35 17,24;65I0
requires 10:17;34:I6
reroute 63:9
rerouted 62:16
residue 54:8
resources 19.23
responded 5:19
responding 60:3,4
response 5:24; 29:22;
54:21
responses 417,5.17;
6:3
responsibilities 8:13
responsibility 8:15
responsiveness 4:16;
6.6
rest42:12
restrict 2320
restricted 61:8,9
restricting 22:3
restriction 22 2,24 9
restrictions 22:4; 23:14;
24:4,8
restructured 41:24
result 118; 12:23; 133.
4; 15:6; 46:5
results 28:4; 58:23
return 23:17
revert 24:18
review 32:13; 4412
reviewed 59:9
reviewer 59:10
revisit 388
rid 47:18
right 6:25; 7:19; 9:24;
25:8; 35:13; 37:18; 40:11;
47:2l;49:19; 55:12; 58:9
right-hand 10:12
rigorous 30:14
rip 24:7
rise 409
rising 61 24
risk 18:12,16; 19:14,21;
20:7.9, 31:13; 49:22; 50:2,
5,9,11,13, 20:51 9,
52:19,21; 53 3.4;55 9,
60:18
risky 63 3
river 54 9
Road 2:12; 41:3; 63.7
roads 52:23; 53 7
Robert 47:9
Robin 7:18, 19; 26:24,
46:20; 57:7; 58:2
Roger 16:18,36:13
Rolling 56:22
room6:l6
round 4118
roule 46:10,11
rules 4:24
running 5210
runs 63:7
rusted 5824
s
S-C-A-F-F 49:13
S-O-M-E-R-S 26:2
S-T-i-L-L-l-N-G-E-R 21:5
sacrifice 193
same 8:14; 10:24; 51.22;
56:21
samples 22:25; 26:19;
56 12
sampling 1219; 20 11;
26:18; 28:4;46:25; 51:11;
56:19
sat 54:5
saw 48:4, 53 14
saying 61:17
SCAFF 49:10,10,13,15,
50:19,23; 52:7; 5313,21;
54.14,60:5,17; 61:9,13,
20; 62:4,9
scares 53:15
schedule 2:6
scheduled 14:23; 16:11
scheme 60:6,10,15
scientific 44:14
scientists 9:21
scooping 52:22
screen 57:16
screening 9:15
SEA 6:20
seal 15:15
sealing 4617
second 4 3.13 20; 30 7,
31:7; 43:5,9, 58 7
section 58 3
securing 22:2.3	
-------
PROSPOSED PLAN FOR THE ASBESTOS DUMP
SUPERFUND SITE OPERABLE UNIT
December 17, 199
seeing 5511
seem 26.5; 29:6;HI 5,
19
seemed 48 3
seems 3:10; 39 4; 44 9.
22,46:11:61:2, 3;63:3
select 13 11
selected 34:16
send 6:10, 14;7 15
sending 12:11
sense 42 3.23
sent 49 5
separately 55:19,24;
563
September 12 24; 132;
56:16
Service 219;3 8 i 6,19;
8:11; 38 24;46:21
Services 8:9; 9 19,
11:21; 14:23, 28 13;
39:22; 64:3; 65:6
serving 35:18
set 3:13; 4:23. 8:22;
28:14,29:17,48:22
setting 19 25.22 19
settlement 39 18
settling 23 4
seven 9:21; 29:11; 58:7,9
several 10 9; 51:12
sewer 47:16, 20
shallow-rooted 25:4
SHANNON 33 3,20,34:2
share 4512
shared 42:23
shed 45:5; 46 6.10.11
sheel 2:25;616
sheets 7:16
shipped 49 3
shipping 16 6
shit 6417
short 219
short-term 1323
show 7:21; 40:3
showed 1921
showing 58:15
side 2:11
•Ign 3 2
signed 2:25.25; 3 2
significant 56:14;63:18
significantly 61 25
silts 58:6
Similar 49 20,65:6
Simple 43:8
simply 50:17
s il 5 3
*ite 2:10,11,7.20; 9:12,
17; 10 6, 10, 19, 20,21.
23; 11 2,8,13,19; 12:3,4;
14:15, 21, 21.21; 15:10,
25; 16 3.6; 17:3,4.4, 5.6,
6.8; 18:21; 19:17; 20:2, 4,
8. 14; 22 3,16, 22,25;
23 16, 17; 24:13; 27:3;
3120; 37:6; 38 8; 39:11;
40:5.9, 15; 41:20; 43:22;
45 5,13.22; 46:25; 48:15,
18; 49:2,17,23; 50:2;
51:13, 21; 52:6,20; 53 8,
20; 55:6.20,23; 56:6,6;
58:3.4, 12,15; 61:7;
62:15,16.17.18. 23;
63 10,11,13,14,14,17;
65:2,15
sites 25:11,38:23; 451 5.
17; 57.5; 63:6; 65:6
sitting 52:8; 58:16
situation 12:7; 31:22;
61:2
sbt 159; 18:ll;29:ll;
41:16,18; 58:9,13
six-Inches 15:13
size 17:3; 18:3; 58:22
sizeable 12:24
skip 35:25
slopes 3815
smaller 62:21
SOii 1510; 20:19; 36:10;
40:5,49 25; 50:9; 51:17,
20; 53:10
soils 14:20;51:13,14;
55:18,19.21:56:13
solely 5:9
solution 16:3; 44:17
solvent 5913
someplace 12:3
Somers 25:25; 26:13;
27:4,11.16.18; 28:10,25;
29:5.5,16;31:25; 32:18;
33:15; 39:23,23:40 7,12.
18,23:42:5.17
something 4:25; 6:9,13;
53 2;61:6
somewhat 11:20
somewhere 29:20; 52:20
SOMMERS 25:25
sorry 5:17; 17:5,6; 29:5;
34:2; 47:10; 57:9
sort 23:18; 26:3.16; 36:4
source 3113
sources 145; 1923
speak 41:12; 45:7
special 48:22; 49 5,6,8
specialist 2:17
specialty 49:5
species 15:14; 18:14.15;
19:18, 20; 20:11:24:19,
23; 25:4
specifically 3:19:31:19;
34:16
specification 65:8
spell 5:5; 47:11; 49:11
spend 6415
spending 60:22
sponsored 3 9
sponsoring 3:24
spread 29 14
staff 28:21, 22
stake 4416
stand 5 2
standard 40:13
standards 30 11,15;
31:2; 55:13
standpoint 57:ll;63:l2,
13
start 2:23,3 6
state 14:8; 16:17:30:10;
32:4; 33 8, 21; 34:7.21;
359,45:18.46:11,48:11
statement 18:10; 19:8,
12,13; 27:5; 30:2; 31:7,11
states 34:9; 35:4
Station 4:2;47:4
steel 63 6
step 11:25
still 19:17:23:19:45:9;
46:9;53 21;60:14
STILLINGER 21:4,5,17;
37:19,23,23:39 3,7
stir 52:14
Stirring 51:2;60:21
stone 15:11
storage 32:16
Storm 40:10,21.22,
41:11
streams 41:14
strict 5.15
structure 37:24; 38:2.8
structures 4l:i4;62:9
Study 6:22; 9:9,10.18,
22.23; 10:4,5; 11:6;
12:13,17.13:5.8; 40:3.
41:10; 46:23; 52:18; 58:4,
20.23
Stuff 12:10; 38:9
subject 28:16:38:3;
64:12
submit 65:13, 22
submitted 28.5
subsequent 24 24
substantial 42:22
substantiated 104
substantively 35:16
subtract 28:8
succeeded 46:4
successful 44:20
suggested 13:9
sum 29:8
summarize 6:23
summarized 50:3,56:16
summarizing 37; 559
summary 4:l6;6.7
summer 41:24
Summers 30:2
Superfund 43:22
supervisor 8:17
supply 31:14:57:2
support 1325
suppose 18:15
sure 6:2;7:8; 11:22;
13:20; 23:4; 25:14, 20,	
29 23;38:15; 39:14; 47:5;
57:21,23;64:24; 65 3
surface 10:20; 11:13,14.
22; 12:18; 14:17,19;
17:20; 21:23; 22:9,16.24;
26:23; 39:19:40:5,8,21;
41:2,5.11,14,23,23.24;
50:8; 61:24; 62:5
surrounding 10:21;
17:9; 30:17
survey 37:25
survive 13:24
sustained 39:17
Swamp 2:4,10; 30:17,
19,22; 436,16; 47:18;
57:20:61:14, 21; 62:5;
64:9
swimming 20:22
Sydn«2:l6,19; 7:2.11;
45:7
synthetic 38:25
T
T-l-E-L-M-A-N-N 48:13
table 15:23
tag 16:10
talk 14:13; 18:12
talking 24:21; 26:17,
27:9:52:24:54:12,15,16;
64:15,16,17
talks 21:20:23 12
team 920
Technical 37:19
technologies 9:15
telephone 3:22,24
telling 62:4
ten 30:16:31:14;43:17;
57:15.16,17; 58:7; 60:25
term 21:9; 27:8
terms 19:4
tested 14:18;56:8
testing 57:14; 58:21;
65:11,11
teats 56:24
Thanks 8:6,-66:2
themselves 30:23
therefore 20:24; 32:22
they'll 6:2
they're 19:24; 20:23;
22:24;33:11;35:18, 23,
23. 25:49:17; 54.11.16;
64:4
They Ve 323
thick 15:7.13:58:5.16
thinking 46:15; 59:25
third 14:13
though 60:13
thought 2:23;3:6; 48:4
threat 117
three 3:24; 17:14; 18:14,
21:15. 16; 24:17; 40:23;
41:19; 63:5
three-ecre 52 7
Thus 18:18
TIELMANN 48:10,13
tightly 15:15
times 54:7
tip 53:6
tissues 26:19; 52:2
title 8 11
today 46:9; 49:18;60:24
together 43:17
told 44:25
tonight 2 7,22; 4:24; 5:9
14; 14:9; 26:12; 32:7;
33:12;44:6; 45 3:58 18,
60:20
took 41:25; 53:^
top 11:15; 15:3.15;
17:17; 25:13; 38:5,45:20
topics 64:14
topping 25:14
total 9 21
totally 12:11; 61:7
touch 33:7
touching 51:18
toward 57:2
towns 30:16; 4317
Township 2:12; 3:15,16
31:10
toxicity 143
tract 2:13
tractors 24:6
trails 23 24;63:15
transmitted 42:23
transporting 63:17
treat 55:24
treated 12:22, 56.2
trees 23 5; 24:19.25:9
trespassers 204
trlchloroethylene 59:13
trouble 315; 60:21
truck 49 3; 54:12
truckloads 52:10.24
trucks 52:22.23; 53 6;
54:2
true 47:19
truly 27:8
try 3:11,51:8
trying 197.50 1 2; 60:11
TSCA 49:8
turn 2:15; 6:18; 16:13
turning 54:12
turnout 2 22
two 3:13; 17:14,22; 18:2;
30:4:34:9.398,40:19;
43 6; 47:24:57:5.59 3. 11
two-feet 15 7
two-year 40 9
type 25 7.60 15	
-------
December 17, 1997
PROSPOSED PLAN FOR THE ASBESTOS DUMP
SUPERFUND SITE OPERABLE UNIT
u
U.S 3:8,4 6, 18
ultimate 1813
Ultimately 4:19
Umpstead 8:18,19
uncovered 50:14
under 6:25; 10:8; 34:8, 20
underground 57 2.6
underlaying 23 6
underlined 58 5
underlying 38 9
understands 47:6
undertake 28:21
undertaken 12 19
underwent 9 22
Unit 4 513
Unless 25 16:43 16
unrelated 44:4,10
up 2:9,313.5 2,7:5,17;
917,10 10,10,16,19,19;
16:15.20 12; 23 22; 24 :7,
12; 27 14.28 7, 25;35:13;
38:1 5; 44:21; 45:12; 51:2;
52:10,11.15,18,19,22,
53 24, 54 6; 58 21:60 11,
21; 65 7
updated 818
upland 24 2; 56 6
upper io i2
upstream 27:3;44:10;
45:13, 22, 46 7,16, 25,
47:4,15,19,54:7
upwind 14:21.36 25
use 6:12; 22:3; 48:23
used 8:11;38:23;63:8
JSeful 27:6; 29:16; 42:17
Jslng 40:13
V
/alue 9:22,25; 10:3; 13:4,
i. 27:21, 29:10; 41:10;
>2:18
/eriety 20:11
/¦rlous 3:18; 6:24
regetatlve 15:13,14;
tf:4, 12
'erg* 26:4
rerlfylng 7:6
'ersus 57:22
'la 20:21
'tow 4:10,22
Allege 18:8
'Ultor 63:13
'Isltors 20.4,7
'Isual 40:25
'OICE 7:7; 17:4. 21:15;
5:18
olume 14 4
olumlnout 41:22
w
waiting 26:3
walk 39:12, 58:18; 64:5.6
wants 25 16
warnings 10 19
warranty 38:24
washings 398
waste 9:13; 17:13,24;
38:15; 46:2; 4819,22,
49:8,8.8; 60:8,11
walch 24:3,3
watching 23:18
water 10:20; 11.14,14,
22; 12:1 B; 14:17,19;
17:20; 21:23; 22:9,16, 24
26:18,23; 31:12,17:38:3;
40:8,8, 21,41:3, 5, 11,14,
15,23,23,25; 4 5:5; 46:2,
3,6,10,10; 47:19, 50:8;
54:25; 5513; 57:2; 59 2,
19;6l:24;62:5
watershed 43 21
way 3:2,3,12; 19:5; 29:2,
45:14,50 12; 52:3; 54 5.
10; 57:6; 59:24:60:20
web 18:18
weeks 16:6
weigh 18:22
weighing 18:13
weighted 1314,17
Weighting 18:23.24;
192
welcome 2:2,20; 64:19;
65:22
wells 31:18;41:13;42:12;
55:6; 56:21; 57:4,12,13,
21
wet 36:19
wetland 24:23; 25 3,10
35:10; 38:19
wetlands 17:9,16,23;
18:4; 25:11:35:2; 36:11
wetness 17:11
Whal'a 21:14; 45:12;
46:8,18; 4*19; 58:7
Wheelef 2:17;6:21;9:3,
19:13; 41:8, 50:3:51:7
Wheeler'¦ 9:4
whenever 7:16,17
Whlppany 54 9
whole 6:2; 17:20:39:13;
43 21; 44:23; 52:9; 64:11
wide 10:6
wtkfornMS 15:16; 17:8.
12,22:19; 24:10:25:22
Wildlife 2:4,10,18; 3:8,
4:6,19; 89; 9:19; 11:21;
14:23; 18:16,18,19:2,3.
19,20; 21:23; 22:9.16,22;
24:4; 25:7; 28:13:3921;
46:21; 50:15, 51:23; 64:2,
9.15:65:6
wildnass 19:25
windy 43 21
within 17:19; 30:22; 55:6;
57:20
wondered 44:16
wonderful 42:25
wondering 32:5;44:18
word 39 3
Words 14:4;22:21
work 8:4; 11:3,4; 14:24;
16 11:30:25; 35:23;40:6;
48:25; 54:7
worked 8:14; 54:4
workers 37.7
working 6:20; 9 2,5; 36:2
world 46 5
worry 514
worse 31:22; 50:21; 51:2;
60:2
worth 59:25
write 6 13.21 12
writing 5:19; 35:12;65:23
Written 5:17,24,6.11,
12; 23 7,29:22
wrong 48:4, 5; 58:14
Y
Yeah 40:18; 62:7
year 16:12.3816; 40:17;
48:25
yearly 28:4
years 3 9; 9:3,6; 11:23;
13 25,27:9,14,28:6,15;
2912,14; 38:24, 43 2.12;
46:3; 47:24; 50:20; 61:2
z
zero 21:15,16
zone 17:19
J.S - zone (8)
Min-U-Script®
TAYLOR & FRIEDBERG
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APPENDIX V
RESPONSIVENESS SUMMARY
ATTACHMENT B
LETTERS SUBMITTED DURING THE PUBLIC COMMENT PERIOD
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ChristiAe Todd Whitman
Governor
JStnie orf ^Ne£n ^jcr&cg
Department of Environmental Projection
Robert c. Shinn, Jr.
Commijjio/i(/
££6 I 9 1998
Krinta Doebbler
U.S. Fiah & Wildlife SecvLc«
755 Parfet Street, Suite 200
Denver, CO 80225-0207
Re: Asbestos Dump Superfund Site
Operable Unit No. 3 (0U-3)
Dear Ms. Doebbler:
This is in response co your letter dated December 4, 1997 transmitting copies of
the following:
1.	Revised Draft Proposed Plan for 0U-3; and
2.	Revised Draft Action Memorandum for the Removal Action at OU-'j/Sitft
B and Limited Action Areas.
The New Jersey Department uf Environmental Protection has reviewed these
documents and comments are offered below.
A. Proposed Plan
1.	On Page 3, in Table 2 entitled "Remedial Alternatives Evaluation for
0U*3", the description of Remedial Alternative 3 should include the
"Excavation of Other Waste" to show chat the removal and off-site
disposal of lead and mercury "hot spots" Ik one of the planned
activities (see "Implementation" Pages 13 and 1A)
2.	On Page 6, in Table 4 entitled "Human Health and Ecological
Contaminants of Concern", in addition to the New Jersey Residential
Soil Criteria, the applicable ecological cleanup criteria should be
provided for each analyte.
3.	Under "Remedial Action Objectives", the second bullet item should be
revised to state that the spread of any contamination to any
surrounding media during and after remedial activities will be
prevented.
Ncir }craey Itc Equjl Oppnrtuiuty Bmptoyer
Rrtycicd Payer
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6. On P«ge 11. under "Reduction of Toxicity, Mobility, and Volume". the
language in the third paragraph of thLs section should be revised to
more accurately identify the effect the preferred alternative will
have on the toxicity, nobility and volume of contamination at the
site. Such issue can be taken with t.he statement that Alternative
3 will "reraodiate the hazardous waste". Excavation and off-site
disposal Is not considered "treatnent" that will reduce the
toxicity, mobility, or volume of the hazardous waste and restricting
the nobility of compounds (e.g., Abeston-Containing Material or ACM)
by consolidation and capping does not reduce their toxicity or the
volume of material.
5.	On Page 11, under "Cost", the Proposed Plan shows an Estimated
Present Net Worth Cost of $4,182,376 for Alternative 3; however,
Page 16 of trhe Draft AccLon Memorandum shows Estimated Cost of
$600,000. The applicable difference between these two (2) figures
should be explained.
6.	On Page 16, in "Attachment B" , the anticipated project schedule for
OU-3 is very ambitious. At present, the schedule is approximately
two (2) months behind. It is recommended that "breathing room" for
other unanticipated delays be included. Perhaps the summer of 1999
might be a more realistic prediction for implementation of the
remedial actions.
B. Draft Action Memorandum
1. On Pages 13 and 14, under "Proposed Actions":
a.	The soil cleanup criteria for the ACM must be identified.
b.	The proposed actions for 0U-3/Site B are acceptable.
c.	The proposed actions for the Site B Refuse Areas, Sites 5 and
7, and the Old Farm Road Site must include post-excavation
sampling for lead and/or asbestos. These data, are necessary
to either confirm complete cleanup or for inclusion in a
Declaration of Environmental Restrictions (DER), should there
be coil contamination which will remain at the site after
implementation of the remedy.
d.	The proposed actions for any area/site which will result in
contamination being left behind above the applicable soil
cleanup criteria will require the placement of a DER on the
deed for that property. The levels of residual contamination,
as determined from post-excavation sampling, must be recorded
In a DER.
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Should you have any questions or require additional Information, please do not
hesitate to contact me at (609)633-6621,
// SigcereW .	.
(%t M/j (11
Carlton W, Bergman {/
Bureau of Site Management
Division of Publicly Funded Site Remediation
c: Helen Shannon, USEPA
Steve Byrnes, DEP/BEERA
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246 MADISONVILLE ROAD, BASKING RIDGE, NJ 07920 (90S) 766-7550
PASSAIC RIVER COALITION
January 26, 1998
Ms. Krista Doebbler
U.S. Fish and Wildlife Service Project Manager
12795 W. Alameda Parkway, Suite 215
Lakewood, Colorado 80228
Dear Mr. Doebbler:
Re: Great Swamp National Wildlife Refuge, Asbestos Dump Superfund Site, Operable
Unit 3, Morris County, New Jersey
The Passaic River Coalition is a watershed association, which has been involved in
matters related to the Great Swamp National Wildlife Refuge for almost 30 years. We
are familiar with the site on the Passaic River in Millington, and have followed the
investigations of the sites in the Refuge for some time.
From our observations, the managers of the Refuge have done much to clean up the dump
sites of drums, equipment, and other metal objects. We agree that the "do nothing"
alternative is not acceptable. We have reviewed the caping alternative with Refuge
Manager Bill Koch, and agree that the alternative being proposed by the Refuge
management team is the best alternative and most cost effective. The management of the
site as a meadow is an appropriate use of the site.
We believe it is important to move forward with the preferred alternative and bring this
project to closure. We support the preferred alternative.
Veiy truly yours,
EFF/e
Ella F. Filippone, Ph.D.
Executive Administrator
c: Koch :
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David Lustbaoer
BOX A7A
New Vernon, New Jersey 079/6
CO
January 31, 1998
In
Krista Doebler, Project Manager
Fish and Wildlife Service
12 7 95 W. Alameda Parkway
Suite 215
Lakewood, Colorado 80228
Dear "Ms. Doebler:
I am writing regarding the asbestos dump known as the Dietzman
Tract on Long Hill Road, Harding Township, New Jersey. The
Service is open for public comment on its plan for handling of a
6-acre asbestos dump.
I understand that the proposal is to put 2.25 feet of dirt and
rock over it. I am opposed to this measure. The asbestos and
any other toxic materials should be excavated and removed to a
proper dump for such materials for the following reasons:
1.	The current asbestos dump is on the edge of the
Great Swamp. The U.S. Fish and Wildlife Service should
not be a party to maintain a hazardous condition which has
the potential to imperil the area. A 2.25 foot cap of
dirt and rock can be easily breached. I am sure at one
time the Grand Canyon was not very deep.
2.	There can be no guarantees that the asbestos is
permanently sealed. Water undoubtedly can percolate
through the area and cause the asbestos to spread.
Children might find a deserted area a fine playground,
unaware that digging in the area could be fatal to them.
Animals can burrow.
This asbestos dump has been mir.managed for a number of years.
The Service should do the right thing and have it finally
removed. The citizens of the community should be protected.
The Great Swamp should be protected. The reputation of the
Service should be protected.
Very truly yours,
D2U-
.DAVID LUSTBADER
DL:sm
OPTIONAL FO«M M
FAX TRANSMITTAL jjrof
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fAOftrtCv
TO
f AQ ArtCy
Ptw I
-------
t> . i 7 7 O
1 -> • yj t
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January 6, 1998
GSNWR.OU-3 Comments	„
Ma. Krist* Doebbltf
Pjojeot Manager
US. Fish and Wildlife Service
7$5 Parfet Street, Suite 200 '	,
Denver, CO 8022*0207 '
* '	.	« '1 •
Bec&use the Great Swamp Watershed Association is unable to complete its commqxts on .
die Proposed Plan for the A&e&oS Dump §iie Ppcrabb Unit No. 3 before January 16, 199$, "wc
are requesting that the comment period be extfcqded by at least 30 days,
We look forward to hearing from you soon and hope this extension will be granted..
' Think you.
Sincerely,	" .
Juaa M. Somers
Executive Director
cc: Robin Burr
£
g REAT SWAMP WATERSHED ASSOCIATION
RO. BOX 300 - N®w\Xemon.NJ 07974 • Phoooi OT3 - V66 -1900 • Fax; W3 - 966 -<009
FEB-04-199R
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*• Kun
r - v h
ni^^ANTVIlXE AO AO
NTW VUNON. NJ. 07976
January 10. IMS
WlHUMI Koctl
1(2 Ploawmt PUtfns Rottf
Basking RjdQe. N J.
07B20
Oder Mr. Koch;
Wt are writing tNs letter In reference to the Asbestos Durtip Stiporfund; Dtotzenun Tract.
Having lived In the Immediate ar»a f adkrt UtuHi..
It dtdnt have efiy negsliva ^ffec* on the people Mvina to the Immediate vicinity. They all Gv*d
long healthy ItvM and <*dnt die from anytfwto caused from the abeatos 5fte.
The Site ttboaidtotoltblUBMiiaSifefcfwotbcntocqjoy notwafca meuofr. Thc*c ate tar bcttef
tfcisef tkcepytsnKtU rf»ouid the money (a ia (b« Oreoi Swamp.
Sincerely,

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APCAR ASSOCIATES
ENOINCCRO • LAND SURVEYORS • PLANNERS
ROMRT H. POM. P6 . PR
WAVNe r. HOLMAN. P.L.6. £ RR
13 OlMUN PLACE
P.O. WOX 310
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617 497 77037;;
M«. Julia M. Somera, Exeoutive Director
GREAT SWAMP WATERSHEO ASSOCIATION
February 27, 1998
Paps 2
2.	The eeme aootlon Includea a diecuaaion of tho buried drums and rsfers to
their oxiatenca aa "formerly" and "now removed". I do not feel thasa
remarks should ba mada with the certainty and Completeness infarrad. As
discussed in tha drum removal report, geophyeloal aurveye Identified 'several
hundred anomelies characteristic of drum-sized targets or largar*. However,
the USACOE limited Identification and subsequent investigation of the
anomallai to the 100 lergeat. The raason for this was not stated. As tha
nature and characteristics of the remaining anomalies which were not
investigated ere unknown, any discussion of the drum removal activities
would bo incomplete without mentioning that some drums may still be buried
at The *lta. Aooordlngly, any evaluation o 1 remediation alternative* muat
consider the poaalbility that drums may have been mlaeed during the removal
activities and could represent e potential for future groundwater
contamination. I havs noted that tha drum removal report rafara to 10
anomalies which trend off-site but ware not investigated. The Proposed Plan
makes no mention of this situation nor how It will be addressed.
3.	Of particular concern la the fact that the groundwater monitoring component
of the aelected alternative has been eliminated since publication of the Final
Feasibility Study Haport. Tha reason for this is not fully explained in the
Proposed Plan. I can only find two statements In the Propoaed PJen thet
'mention groundwater monitoring. The first is a statement in tho drum
ramoval discussion "that additional sampling has oonflrmad that groundwater
la not i future concern". The second la a statement In the Pre-Dtilgn Data
Report summery section that "Sampling Indicates that groundwartar from
dawstarlng or pumped water can be expected to ba sufficiently free of
contaminants to minlmlce future treatment end monitoring needs at Site A".
I suspect that the additional templing being referred to le that conducted
during the dewatering test. Certainly the sampling conducted during this test
waa not sufficient to justify auch broed etetemanta or make final decisions
regarding long term monitoring. Such statements conflict with baaio
conclusions contained in the Final Feoaibility Study, Theae atatemenia aleo
conflict with another statement on page 11 of the Proposed PI en which saye
"Monitoring to data Is Inconclusive".
The Final Feasibility Study Report speoifloally recommended future
groundwater monitoring because of concern over future groundweter
contamination and the feet thet groundwater currently exceeds AAA Re. Aa
diacueaed above in Comment 2, concern over future contamination Is still
valid from a perspective of drummed waete. Further, the data collected
during a 3-dey pump teat at one point on the she would oertalnly not be
sufficient to contradict the volume of data collected during the Rl phast of
this project. Tho USF&.WS should carefully explain and Justify this ohonge in
long term site monitoring Of Vt h significant.
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Ms. Julia M. Somers, Executive Director
GREAT SWAMP WATERSHED ASSOCIATION
Fobruary 27, 1B90
Page 3
4. Under Alternative 2A, tho Proposed Plan states that "Basad on all of the
information collected to data. It la anticipated that future risk aaaoolated with
hazardous woataa m 5fta A will bo reduced to accaprabla lave la by the drum-
removal operations at Site A." Ignoring the conclusions regarding drum
removal certainty. this statement should bs reconsidered In light of tho
maaalva amounts of exposed esbestos at Slta A, unknown quantities of
aabastos la soils, groundwater which exceeda ARARa at Sito A, and the
detections of mercury In aurfaoe soil samples collected from Sita A during
tha Pre-Deelgn Data Report activities.
6. Tha diaautslon of Alternative 3 includes tha need t~ .-amove mercury-
contaminated "hot spots", There exists no discussion In the Final Feasibility
Study Report about excavation of mercury "hot spots". K Is also unstated
what la conaldersd "hot". While the Pre-Deelgn Study did include grid
sampling for mercury in surface soils at Site A, this grid wea vary large 1100'
Intervals) and Inappropriate for Identifying "apata". Further, the sampling
revealed that the remediel action objective for mercury In surface soils (1
ppm) wbs exceeded over tha vast majority of Site A.
A review of the Removal Action Memorandum and the Removal Action Work
Plan reveals no mention of any mercury "hot spot" removal or coordination of
such a removal activity with the current removal aotlvlty. Suoh coordination
would Inolude, at a minimum, preventing the placement of waste from the
Refuae Areas and Site B over the 'hot spots". Further, the proposed
regrading of Site A Identified In the Work Plan would seriously compromise
the value of all eurfscB soil mercury data collected to date. Aa Alternative 3
la tha proposed remedy, it Is important that the mercury "hot spot" lesus ba
discussed, evaluated with retpeot to remedial eotlon objeotlves. adequately
justified through comparative analysis with other alternatives, and Integrated
into the overall remediation program.
6. The dlsousalon of Alternative 3 should alto inolude removal of ACM*
• contaminated sediment from the waters adjnoent to the site in order to
prevent downstream mobiliution of this material. Dlaouaslon of capping for
Alternative 3 should include the need to provide engineering controls for
prevention of cap erosion at the waters edge. The Proposed Plan should
clearly Indicate the Intended Topographic configuration of the final cap. The
advantage* and dlaadventagss of tha different capping syatama should be
dleousaed; specifically, it should bs clearly noted thet a permeable cap will
only reduce snd not eliminate discharges from the wasta material into tha
surrounding surface water bodies.
Tha Propoeed Plen should clearly state whether "future public access lo Site
A will be allowed. Tho removal of the culvert following remedial activities
CCD.... -17.. i rvrrn * r • c-<->
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oo>i Diortu	. ^-z/-ao • io-oi •	lo rio-	01/ 43/ //uv/;z o/ 0
Ma. Julia M. So mars, Executive D tractor
GREAT SWAMP WATERSHED ASSOCIATION
February 27, 1998
Paga 4
should be reoonsidered ea this Is the only method of accessing the various
Raines Areas, the UAR, and Sits *B" locations for maintenance purposes.
7. The final disposition of tha UAR ACM should alio be Included in the detail id
deeoripikm of Alternative 3. Although not dlicuaaad In the Removal Action
Memorandum, the Work Plan Indicates this ACM U to remain. If to, capping
with 0 Inches of soil (s« desoribed In the Work Plan) is Inadequate In
consideration of tha proposed use of Site A and maintenance requirements.
B. Specific comment# regarding asbsatos clean-up at the various Refuse Areas
and Site B are provided in comments on the removal eotlon.
!
i
Comment* nn the ft«mnvnl Action Mamnmndum
1.	Section I Indicate# the purpose of tha memorandum Is to document "approval
of the proposed removal action'. As the NJDEP nsver responds to dooument
submittals and the USEPA, is of 2/23/98, had only reoelved but not
reviewed the memorandum. It is not olear whom has spprovsd the action
other than the site owner. The USEPA representative went so far aa to olelm
U8EPA approval wee not required for removal actions. Further, h Is unlikely
the NJDEP would ever explicitly approve en ACM removal action using a
86% visual clean-up goal.
2.	Section I Indicates that lead contaminated waste above 218 ppm will be
disposed of off-alte at on approved faoility. This directly oontradlots the
Work Ran which states that waste with lead concentrations above 218 ppm
but below 400 ppm will be disposed of on Site A.
3.	As field work is being initiated In February, discussion of accomplishing the
removal work "before the onist of winter weether* should be removed from
Section I.
4.	Section II A. 4. Indicates that the origin of the LAA ACM is suspected to be
OU1 of tha Asbestos Buperfund Site. In light of this statement, the
USF&WS should explain what efforts have been undertaken to have the
LAAb included In the Sits and/or the status of such efforts. Considering the
expense related to disposing the material offalta, e detailed discussion of this
Issue Is appropriate, relevant, and of interest to the general public.
5.	Section II C. should clearly Indicate that the (JSF&WS received no comments
from either the NJDEP or USEPA regarding tha proposed removal action.
B. Section V makes no mention of the UAR ACM white the Work Plan states it
will be covered. The draft Scope of Work from the Admirwtrative Reoord File
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Ms. Jqlla M. Somaro, Exaoutivo Director
GREAT SWAMP WATERSHED ASSOCIATION
February 27, 1098
Pegs B
states tha UAR ACM la to bo removed. Thete differences should be
eliminated. Considering the quantity Df the ACM, the proximity to Site A,
and the "future use of the UAR, h would be ideal If all ACM ware removed
from the UAH.
7. The general ACM removal strategy diaoussed In Section V It removal of ACM
to a limit of 85% based on visual observation. Unfortunately, determination
of gross eabeatoe concentration in soils by visual methods Is Imposslblo.
Further, federal and state laws define Asbestos Containing Material at
material that containa 1% or mora of asbestos, not E%. Remediating to 5%
would mean that ACM. as defined under federal and state law, would ramain
on site. Accordingly, long t«rm monitoring would be required at tha arte. It
does not appear that this poaaiblllty was previously considered.
Additionally, only "contour grading and seeding" of the ramaining material (•¦
identified In the memorandum} would ba a violation of tha containment
standards contained In 40 CFR 01.151 if tha ramaining material oontained
aabaatos la axoaas of 1 %. It ahould be noted that the NJOEP is currently
requlrlno soli alean-up oriteris of 0.26% asbestos (determined analytically! st
similar sites In northern New Jersey, Consideration should ba given to
collecting asbestos confirmation aamplas from ACM removal sites to
demonstrate aloan-up to the 1 % level.
B, Section V states that icil not remediated to the B% visual concentration
would bo covered with B inches of soiL Although It is not clear whether this
would oomply with the standards established In 40 CFR 61.151, tha
USF&W6 would be required to plant end maintain vagatatlon over such a
cover. Thii maintenance would have to ba frequent enough to prevent the
Growth of vegetation that could panatrate tha 8 inch layer and compromlaa
the cover. A cover of this nature would be extremely prone to being
compromised by burrowing animala, Thaaa lasuaa ahould ba considered and
balanoed agalnat tha benefit of ualng a 2 foot thick cover (as specified In 40
CFR 61.161) requiring only minimal maintenance.
9. The Community Relations Plan discussed in Section VI should be added to
.the Administrative Record File.
Cammtnti on tha Work Plan
1. The eighth buUet on pege 1*5 should Include clearing and grubbing a« an
activity requiring air monitoring and nolsa control.
CCD-79—1 Q30 <*r>'r*C*
ner-.
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^ti\j tur^ru)
2-2/-aa '• ib:o2 :	US MVS-	C17 437 77097;s 7/ 8
Ms. Julia M. Somara, Executive Director
GREAT SWAMP WATERSHED ASSOCIATION
February 27, 1098
Paga S
2.	The plon doos not discuss measures to ba tnkan during on-flto transport of
matarlal (I.e. using tarps over material balng treneported In trucks). This
ihou/d be discussed.
3.	Covering of the (JAR ACM with only 6 Inohea of soil would neoaseitate
frequent maintenance to prevent vegetation from compromising the cover.
This maintenance Issue Should be considered and balanoed against the
benefit of uelng a 2 foot thkik cover (aa specified In 40 CPU 01.161)
requiring only minimal maintenance. Further, at future eeeeaa to B'rte A will
be over the UARt a cover only 6 inch thick would be an Inappropriate choloe
for suah a uio.
4.	Section 3.1.3 Indicate! New Jersey clean fill requirements are presented In
the CSAP. While the CSAP does list requirements for lead, requirements for
other aha oontamlnants are not listed.
5.	Aa stated previously, the final disposition of lead contaminated matarlal with
concentretlone between 218 ppm and 400 ppm differs between the Work
Plan and the Removal Aotlon Memorandum.
6.	The Work Plan inoludes no provision for asbestos confirmation samples. As
an appropriate asbestos clean-up standard (for sress to be only regraded
following excavation) Is 1%, aabastos confirmation samples should be
required. Protocols should be established In advance regarding measures to
be taken should confirmation samples exoeed 1%.
7.	The Work Plan Indicates materiel consolidated et Site A from Site B and the
Refuse Areas may be used for cover mntsrisl. As some of this material
would have asbestos associated with it, none should ba used as cover
material unless analytical samples have confirmed concentrations of asbestos
below 1 %.
8.	No discussion la provided in the Work Plan as to how TCLP data will be used
for determining final on-site and off-slto disposal options.
9.	A discussion should be provided as to why tha RA6 mat aria) will ba dlapossd
of off-she regardleei of concentration.
10.	The draft Scope of Work from the Administrative Record Hie for the project
requires the use of e reel-time fibrous aerosol monitor for both eraa and
perimeter monitoring. Equipment of this neture would esseee the releasee of
esbsstos fibers during remediation activities and would serve to Immediately
alert workers aa to when aoifvltlee were resulting In exoeedences of airborne
asbestos levels. The Work Plan, however, requires only filter aartridge
sampling which would be analyzed overnight following the end of the work'
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Mfl. Julio M. Somen, Exeoirtiva Director
GRJEAT SWAMP WATERSHED ASSOCIATION
February 27, 1998
Page 7
doy. Any oorroctlve actions taken in the event of exaesalve analytical results
would be only After the fact. Consideration should be given to using a mix of
real time monitors and filter cartridge samplers to provide for an approprlata
mix of real time data and accurate phaao contract or TEM laboratory
analyses.
11.	Provisions should ba made for accurately establishing "downwind" and
'upwind" sampling locations. These provision* should include a simple
weather monitoring/wind vane station.
12.	Raflradlng of Site A should ba reoonaidered in light of the proposed meroury
"hot spot* removal. Rogrnding of the alta would negate the value of any
previously colleoted mercury aurfaoe soil data and would only sarve to
further homogenize th« waste.
These comments should be considered as starting points for further discussion and
exploration of the various issues identified. Please contact me If you have any
questions or comments regarding this information. I am available to discuss these
matters diraotly with UGF&WS personnel at your direction.
Vary truly yours,
Projeot Engineer
PDF/baa
FPR-77-iqQO
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P Ptfl
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APPENDIX VI
LIST OF ACRONYMS
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LIST OF ACRONYMS
ACM	-	Asbestos Containing Material
AOC	-	Area of Concern
ARAR	-	Applicable or Relevant and Appropriate Requirements
CERCLA	-	Comprehensive Environmental Response, Compensation, and Liability
Act of 1980
COC	-	Contaminant of Concern
COE	-	United states Corps of Engineers, Kansas City District
DOI	-	Department of Interior
DOT	-	Department of Transportation
EPA	-	Environmental Protection Agency
ER-M	-	Effects Range - Median (NOAA, 1994)
FFA	-	Federal Facilities Agreement
f/mm2	-	fibers per square millimeter
FS	-	Feasibility Study
GSNWR	-	Great Swamp National Wildlife Refuge
HRS	-	Hazard Ranking System
LAA	-	Limited Action Area
MCL	-	Maximum Contaminant Level
MFL	-	Million Fibers Per Liter
mg/Kg	-	milligrams per kilogram
MSL	-	Mean Sea Level
NA	-	Not Applicable
NCP	-	National Oil and Hazardous Substances Pollution Contingency Plan
ND	-	Not Detected
NESHAPS -	National Emission Standards for Hazardous Air Pollutants
NGC	-	National Gypsum Company
NJ	-	New Jersey
NJDEP	-	New Jersey Department of Environmental Protection
NPL	-	National Priorities List
NOAA	-	National Oceanic and Atmospheric Administration
OFR	-	Old Farm Road Satellite Area
OS1IA	-	Occupational Safety and Health Administration
OU-3	-	Operable Unit 3 of the Asbestos Dump Superfund Site
O&M	-	Operation & Maintenance
POTW	-	Publicly-owned Treatment Works
PRP	-	Potentially Responsible Party
QA/QC	-	Quality Assurance/Quality Control
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RA#I
Refuse Area Number One
RA#3
Refuse Area Number Three
RAUG
Refuse Area Number Six
RAO
Remedial Action Objective
RCRA
Resource Conservation and Recovery Act
Ri
Remedial Investigation
ROD
Record of Decision
SEA
SEA Consultants Inc.
SSL
Soil Screening Level
TBC
To Be Considered (Criteria)
TCE
Trichloroethylene
TCLP
Toxicity Characteristic Leaching Procedure
UAR
Unimproved Access Road
UCL
Upper Confidence Limit
ug/L
micrograms per liter
ug/Kg
micrograms per kilogram
USFWS
United States Fish & Wildlife Service
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-REFUSE
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