PB98-963811
EPA 541-R98-143
March 1999
EPA Superfund
Record of Decision:
Burnt Fly Bog
Marlboro Township, NJ
9/30/1998
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RECORD OF DECISION
Burnt Fly Bog Site
Marlboro Township, Monmouth County, New Jersey
September 1998
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declaration for the record of decision
SITE NAME AND LOCATION
Burnt Fly Bog Site
Marlboro Township, Monmouth County, New Jersey
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for the Westerly
Wetlands, Northerly Wetlands, and Tar Patch Area at the Burnt Fly Bog Superfund
Site, which was chosen in accordance with the requirements of the Comprehensive
Environmental Response, Compensation and Liability Act of 1980, as amended
(CERCLA) , and to the extent practicable, the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP). This decision document explains the
factual and legal basis for selecting the remedy for the third operable unit of
the Site.
The New Jersey Department of Environmental Protection concurs with the selected
remedy (Appendix V) . The information supporting this remedial action is
contained in the Administrative Record for the Site, the index of which can be
found in Appendix IV to this document.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from the Burnt Fly Bog
Site, if not addressed by implementing the response action selected in this
Record of Decision, may present an imminent and substantial threat to public
health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
The selected remedy represents the third and final operable unit planned for the
Burnt Fly Bog Superfund Site. It addresses contaminated soil present on the
three remaining contaminated areas on the Site, including the Westerly Wetlands,
Northerly Wetlands, and Tar Patch Area.
The major components of the selected remedy include:
1. Excavation and off-site disposal of contaminated soil from the Northerly
Wetlands;
2. Excavation and off-site disposal of contaminated soil from the Tar Patch
Area;
3. Backfilling the excavated area in the Northerly Wetlands and re-
establishing wetlands;
4. Backfilling the excavated area in the Tar Patch Area and creating
wetlands;
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5. Provision of additional security fencing around the Westerly Wetlands, and
the recording of a Deed Notice for the Westerly Wetlands, Northerly
Wetlands, and Tar Patch Area;
6. Monitoring of surface water and sediment in the Westerly Wetlands, surface
water and sediment in the existing sedimentation basin located in the
Downstream Area, and surface water, sediment and, if necessary, biota in
Burnt Fly Brook; and
7. Biological sampling in the Westerly Wetlands.
DECLARATION 07 STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the environment, complies
with Federal and State requirements that are legally applicable or relevant and
appropriate to the remedial action, and is cost-effective. The remedy utilizes
permanent solutions and alternative treatment (or resource recovery) technologies
to the maximum extent practicable for this Site. However, because treatment of
the principal threats of the Site was not found to be practicable, this remedy
does not satisfy the statutory preference for treatment as a principal element
of the remedy.
Because this remedy will result in hazardous substances remaining on the Site
above health-based levels, a review will be conducted within five years after
commencement of the remedial action to ensure that the remedy continues to
provide adequate protection of human health and the environment. This review
will include an evaluation of the data and information obtained in connection
with remedial components 6 and 7 above, as well as other appropriate components
of the selected remedy.
Jeanne M
Regional
Date
3o/? a
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RECORD OF DECISION
DECISION SUMMARY
Burnt Fly Bog Superfund Site
Marlboro Township, Monnouth County
New Jersey
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Table of Contents
Page
Site Name, Location, and Description 3
Site History and Enforcement Activities 4
Highlights of Community Participation 6
Scope and Role of Response Action 7
Summary of Site Characteristics 8
Summary of Site Risks 14
Remedial Action Objectives 18
Description of Remedial Alternatives 18
Summary of Comparative Analysis of Alternatives 25
Selected Remedy 34
Statutory Determinations 38
Documentation of Significant Changes 40
Appendices
Appendix
I
Figures
Appendix
II
Tables
Appendix
III
Total Risk Summary
Appendix
IV
Administrative Record Index
Appendix
V
NJDEP's Letter of Concurrence
Appendix
VI
Responsiveness Summary
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SITE NAME, LOCATION AND DESCRIPTION
The Burnt Fly Bog (BF3) Superfund Site is located near the
intersection of Texas and Spring Valley Roads in Marlboro Township,
Monmouth County, New Jersey. It is situated approximately thirty
miles northeast of Trenton, and about five miles from the Atlantic
Ocean (Figures 1 and 2). While the entire Burnt Fly Bog encompasses
about 1700 acres, the Site is limited to the approximately sixty acres
of the study area affected by contamination. The Site is identified
on the Marlboro Township Tax Map as Block 146, lot 47, and parts of
lot 2, lot 3, lot 4, lot 5, lot 7, lot 8, and lot 49, and on the Old
Bridge Township Tax Map as Block 13003, lot 23.11, and parts of lot
24.11 and lot 31. The majority of the waste was originally deposited
in lot 47, a ten acre parcel located in the southeastern area (Uplands
Area) of the Site. Much of the waste then migrated to other parts of
the Site.
The BFB Site consists of the following sub-sites: Uplands Area, Tar
Patch Area, Northerly Wetlands, Westerly Wetlands, and Downstream Area
(Figure 3). The Uplands Area had several abandoned oil storage and
treatment lagoons containing residual oil sludges and aqueous wastes,
contaminated waste piles, and buried or exposed drummed wastes. The
Westerly Wetlands, Northerly Wetlands, and the Downstream Area had
contamination in the surface water, surface soil, and the shallow
subsurface soil. It is believed that this contamination was the
result of uncontrolled discharges and runoff from the Uplands Area
waste sources. The Tar Patch Area comprises two areas that were
previously referred to as the Tar Patch and the Contaminated Soils
Area, and which are located adjacent to each other. The core of the
combined Tar Patch Area, which is approximately 4 acres in extent, is
devoid of any vegetation. The material is more sandy, and this area
is contaminated to a maximum depth of approximately 6 feet. The total
area of Tar Patch Area contamination is nearly 5.5 acres. The
Westerly Wetlands is the largest of the sub-sites covering an area of
approximately 21 acres. The area of the contaminated Northerly
Wetlands is approximately 2.5 acres while the Downstream Area
contamination, prior to remediation, covered an area of 3 acres.
Two auto salvage yards and a few residences are found near the Site.
The predominant land use within the township includes residential
development, agricultural land, open spaces and wooded lands.
The Site is located in a fringe area of the New Jersey Pine Barrens.
The New Jersey Pine Barrens is an environmentally sensitive area in
the State. The interior of Burnt Fly Bog is considered an undisturbed
wilderness area with documented reports of wildlife including red and
gray fox, several species of squirrel, rabbits, white-tailed deer,
opossum, raccoon, skunk, and seasonal birds. Other wildlife that
makes this area its habitat includes various reptiles and amphibians.
The Westerly Wetlands and Northerly Wetlands are rated moderate to
high in value as wetland systems. No federally listed threatened or
endangered plant species are present on the Site. The Westerly
Wetlands provides habitat to a greater diversity of wildlife than the
other habitats on the Site, and certain species occurring on the Site
are likely to be found only in the Westerly Wetlands. The Westerly
Wetlands had significant loss of plant cover as the result of a past
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oil fire and/or potentially toxic effects on plants from excessive
levels of contaminants. Most of the affected area has experienced
good progress toward re-establishing indigenous plant life.
The entire Site is located in the outcrop area of the Englishtown
Formation. In the Westerly Wetlands, a relatively impermeable clay
layer is at or near the ground surface. Ground water flowing through
the overlying upper sand layer discharges to the surface of the
Westerly Wetlands which is inundated most of the year. The Westerly
Wetlands receives drainage from the Uplands Area, Northerly Wetlands,
Tar Patch Area, and parts of the surrounding 1,700 acres of bog and
pine barrens. Surface water flows in a south-westerly direction
through the Westerly Wetlands, into the Downstream Area, through the
sedimentation basin, and eventually into Burnt Fly Brook. The
combined flow in Burnt Fly Brook flows into Deep Run at a distance of
approximately one mile from the Site. Deep Run is a groundwater
recharge source for the potable wells in the City of Perth Amboy.
SITE HISTORY AND ENFORCEMENT ACTIVITIES
In or about 1952, activities that were responsible for the initial
contamination at the Site began. During this period, different
portions of the Site were used for reprocessed oil storage or settling
lagoons, oil reprocessing filter cake storage, sanitary landfill
activities, and sand and gravel pit operations.
Before 1950, the BFB Site was still an undeveloped area. In about
1950, Champion Chemical Company established an oil reprocessing
facility located on Orchard Place in Morganville, New Jersey,
approximately two miles east of the Site. About the same time, Eagle
Asphalt Company purchased that portion of the present BFB Superfund
Site comprising the area around the four lagoons in the Uplands Area.
These lagoons were developed for use as oil storage facilities and as
settling ponds to handle the reprocessed oil. These facilities were
operated until the property was sold in November 1964 to a Mr. Eckel.
In 1960, sanitary landfill operations began at another portion of the
future Burnt Fly Bog Site, reportedly receiving local trash. The
owner/operator, Mr. Towler, died in 1961, and the landfill
discontinued operations. Subsequently, Mr. Dominick Manzo purchased
the property in December 1963, reopening the landfill and operating it
with the approval of the municipality until 1967. In July 1965, Mr.
Manzo acquired the former Eagle Asphalt Company property from Mr.
Eckel. Thi3 purchase, coupled with the purchase of an adjoining plot
in July 1968, brought under one ownership adjoining plots of land that
together would eventually become known as the Burnt Fly Bog Superfund
Site.
In 1969, the Middlesex County Court ordered the closure of the
landfill. Aside from the deposition of excavated fill from a sewer
construction project in Kazlet, New Jersey in July 1979, there have
been no operations at the Site since 1969. On October 26, 1973, a
fire started and burned at the Site for 16 hours before it was finally
extinguished.
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The New Jersey Department of Environmental Protection (NJDEP) is the
lead agency for this Site. An Environmental Information Document
pertaining to the Site was prepared by Dames and Moore for NJDEP in
1982. Contamination of soil, ground water and surface water was found
to exist from the improper disposal of hazardous substances at the
Site. The Site was then included on the National Priorities List in
1983. Based on the findings in the report, a Record of Decision (ROD)
was issued in November 1983. The ROD called for off-site removal of
contaminated soil and waste from the Uplands Area, and for a
supplemental Remedial Investigation and Feasibility Study (RI/FS) to
further investigate the wetland areas. The Uplands Area remediation
was performed under Operable Unit One (OU-1).
Ebasco Services Inc. was engaged by NJDEP to provide design
engineering services for the removal from the Uplands Area of
contaminated soil and waste, which included drummed wastes, aqueous
wastes and sludges from lagoons, and wastes from an Asphalt Pile.
Between 1985 and 1990, NJDEP conducted several remedial actions in
this area in accordance with the requirements of the ROD. These
remedial actions included the removal of the Asphalt Pile, removal of
lagoon liquids, excavation and off-site disposal of approximately
85,000 tons of contaminated soil, and installation of a clay cap over
the area. In addition, about 600 cubic yards of PCB-contaminated soil
was removed in 1992 for incineration off-site.
Ebasco also performed an RI/FS for the Westerly Wetlands and the
Downstream Area between 1984 and 1987. As part of the investigations,
sampling and analysis of soil, surface water, and ground water were
performed. The results of the RI/FS are summarized in the January
1988 Westerly Wetland Remedial Investigation Final Report and the
January 1988 Westerly Wetland Ultimate Remedy Feasibility Study Final
Report which are included in the Administrative Record for this Site,
and are summarized in this document. Following the RI/FS, lead
mobility studies and a water budget analysis were also performed by
Ebasco. Based on the findings of these investigations and studies,
another ROD was issued in September 1988. This ROD called for the
excavation and off-site disposal of contaminated soil from the
Downstream Area, containment of the contaminated soil in the Westerly
Wetlands through the installation of a sedimentation basin and
appropriate diversion controls, construction of a security fence, and
treatability studies on the most promising treatment technologies for
the contaminated materials in the Westerly Wetlands, Northerly
Wetlands and Tar Patch Area. Investigation of the Westerly Wetlands
and remediation of the Downstream Area, including construction of the
sedimentation basin, constituted Operable Unit Two (OU-2).
In August 1992, Frederic R. Harris, Inc. was contracted by NJDEP to
perform the remedial design for the removal of the contaminated soil
in the Downstream Area and for the construction of the sedimentation
basin. As part of the design investigations, Harris also delineated
the Tar Patch Area. The results of these investigations are
summarized in the May 1994 Final Field Sampling and Testing Results
Report - Tar Patch Area. Removal of the contaminated soil in the
Downstream Area and sedimentation basin construction commenced in
September 1995 and the work was completed by the end of 1996. A
security fence along Spring Valley Road was also constructed.
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Remedial activities pertaining to the remaining contaminated areas,
namely, Westerly Wetlands, Northerly Wetlands, and Tar Patch Area are
being done under Operable Unit Three (OU-3). In June 1993, BCM
Engineers was contracted by NJDEP to perform a supplemental
feasibility study of these three areas. Treatability studies on soil
washing and chemical dechlorination were performed as part of this
feasibility study. The results of the study are summarized in the
October 1997 Final Supplemental Feasibility Study Report for Burnt Fly
Bog Site which is included in the Administrative Record for this Site.
The United States Environmental Protection Agency (EPA) performed an
ecological assessment of the Westerly Wetlands based on the results of
a field study conducted in 1991. The results of this assessment are
summarized in the June 1992 Ecological Assessment Final Report.
Soil sampling in the Northerly Wetlands was performed by NJDEP in 1995
in order to fully delineate the contamination in this portion of the
Site. The results of this sampling are shown in the January 1997
Northerly Wetlands Field Sampling Report. Surface soil sampling was
also performed in the Westerly Wetlands in 1996 to confirm the
established levels of contamination in this area. The results of this
sampling are summarized in the September 1997 Westerly Wetlands Field
Sampling Report. In addition, surface water and sediment in Burnt Fly
Brook have been sampled since 1992, at quarterly intervals.
EPA initiated a cost recovery action under the Comprehensive
Environmental Response, Compensation, and Liability Act, as amended
(CERCLA), in January 1997 against several parties to recover monies
expended at the Site. This action is ongoing.
HIGHLIGHTS OF COMMUNITY PARTICIPATION
In 1981, concerned residents organized the Burnt Fly Bog Citizens'
Advisory Committee (BFBCAC). BFBCAC, which originally was composed of
residents from Marlboro and Old Bridge Townships, now includes citizen
representatives from Marlboro and Old Bridge Townships, Marlboro
Township officials, as well as officials from Monmouth County and
Middlesex County. The Committee functions as the liaison between
NJDEP and the local community.
Since the establishment of NJDEP's Community Relations Program in
1982, representatives of NJDEP have met with BFBCAC on a regular
basis. All pertinent Site data, reports, and events have been shared
and discussed with BFBCAC to enable its input to be incorporated into
the decision-making process involving Site activities. In 1998, a
group known as the Monmouth County Environmental Coalition (MCEC)
received a Technical Assistance Grant from EPA to hire technical
advisors to review technical reports pertaining to this Site on behalf
of the residents.
Community concerns have focused primarily on the potential
environmental and human health risks posed by the Site. The ingestion
of contaminated ground or surface water has been of major concern to
the community because of the high lead concentrations at the Site.
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Moreover, residents and officials of neighboring communities have
expressed concern about contaminant migration to Deep Run which
receives drainage from the Site.
Several public meetings have been held to present the findings of
various studies conducted for the Site. In August 1983, a public
meeting was held to discuss the remedial alternatives that were
evaluated for the Uplands Area and to receive public comments before
the issuance of the 1983 ROD. Similarly, a public meeting was also
held on March 29, 1908 before the 1908 ROD was issued.
Additional RI reports, the Supplemental FS report, and the Proposed
Plan dated February 1990 for the third operable unit (OU-3) were
released to the public for comment on February 4, 1998. The public
comment period was originally scheduled for a duration of 30 days.
Based on requests for a time extension by the MCEC and potentially
responsible parties (PRPS), the public comment period was extended by
6o days and ended on May 4, 1998. These documents were made available to
the public in the Administrative Record file at the NJDEP file room at
401, East State Street, Trenton, New Jersey, and the information
repositories at:
Monmouth County Library Marlboro Township Municipal
Building 1979 Township Drive
1 Library Court Marlboro, New Jersey 07746
Marlboro, New Jersey 07746
On February 19, 1998, NJDEP conducted a public meeting at the Marlboro
Township Municipal Building to inform local officials and interested
citizens about the Superfund process, to discuss the findings of the
remedial investigations, the supplemental feasibility study, and the
proposed remedial activities at the Site, and to respond to any
questions from the area residents and others who attended.
NJDEP's responses to the comments received at the public meeting, and
in writing during the 90-day public comment period, are included in
the Responsiveness Summary (see Appendix VI).
SCOPE AND ROLE OF RESPONSE ACTION
As a result of the BFB Site complexities and as is discussed above,
the work has been divided into three operable units. A ROD was issued
in 1903 for OU-1 for the remediation of the Uplands Area, and for
conducting investigations in the wetland areas. A second ROD was
issued in 1988 for OU-2 which provided for an interim remedy for the
Westerly Wetlands portion of the Site. It called for the removal of
contaminated materials from the Downstream Area, construction of a
sedimentation basin, and the performance of treatability studies on
the most promising treatment technologies for the remediation of Site
soil. These treatability studies were performed as part of a
supplemental feasibility study. Remedial Actions have already been
completed for OU-1 and OU-2.
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Uplands Area (OU-l)
Several remedial actions were conducted in the Uplands Area between
1985 and 1990. The activities included the removal of a pile of oily
material mixed with soil called the Asphalt Pile, removal of lagoon
liquids and sludge material, excavation and off-site disposal of
approximately 85,000 tons of soil contaminated with PCBs and lead, and
installation of a clay cap over the area and re-vegetation of the
surface. Approximately 600 cubic yards of PCB-contaminated soil was
also removed for incineration off-site. The clay cap is being
inspected and maintained at regular intervals in order to preserve its
structural integrity.
Downstream Area Remedial Action and Sedimentation Basin Construction
fOU-2)
Approximately 6300 cubic yards of soil contaminated with PCBs and lead
were removed off-site for disposal from the Downstream Area in 1996.
A sedimentation basin was constructed in the Downstream Area after
removing the contaminated soil. The capacity of the basin is such
that it can fully contain storm flow resulting from a hundred year
storm event within the catchment area. Accumulation of sediment in
the basin is being monitored at regular intervals. The collected
sediment will be sampled and analyzed before disposal. A security
fence along Spring Valley Road was also constructed to prevent
trespassers from entering the Site.
The third operable unit authorized by this ROD is based on remedial
investigations performed to date and a determination that further
remedial action is required for unremediated areas of the Site.
Therefore, as further explained in this ROD, EPA and NJDEP have
identified Excavation and Off-site Removal of Contaminated Soil, and
Wetland Restoration for the Tar Patch Area and Northerly Wetlands, and
Limited Action for the Westerly Wetlands portion of the BFB Site.
OU-3 is the final response action for this Site.
SUMMARY OF SITE CHARACTERISTICS
Remedial Investigation
The RI for the Westerly Wetlands was performed in three stages between
1984 and 1987 and consisted of sampling and analyses of soil/sediment,
surface water and groundwater. Chemical analysis of all samples was
performed for PCBs, lead, and other chemical compounds. Chemical
analysis of the wetlands soil indicated a large extent and high degree
of PCB and lead contamination. The maximum concentration of PCB
contamination detected in soil was 254 milligrams/kilogram (mg/kg).
PC3s were not present in surface water. Lead contamination was found
in the soil within the delineated boundaries of PCB contamination and
outside. The maximum concentration of lead contamination detected in
soil was 31,000 mg/kg. Lead was also found in surface water samples.
The maximum concentration of total lead detected in surface water was
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1,900 micrograms/liter (yg/L); the maximum concentration of dissolved
lead was 1,600 pg/L.
NJDEP soil cleanup criteria established as the action levels for the
Site at that time were 5 mg/kg for PCBs and 250 mg/kg for lead.
Utilizing a remediation level of 5 mg/kg for PCBs, the results of the
Stage I investigation identified an approximate volume of 58,000 cubic
yards of PCB-contaminated soil in the Westerly Wetlands. The results
of the Stage II investigation refined this estimate to 62,600 cubic
yards of PCB-contaminated soil. The results of the Supplemental Stage
II investigation increased the volume of contaminated soil within the
Westerly Wetlands to 76,400 cubic yards after including lead-
contaminated soils, using a threshold level of 250 mg/kg for lead. In
addition, the Supplemental Stage II investigation evaluated soils in
an area immediately down-gradient of the Westerly Wetlands, which was
designated as the Downstream Area. The Downstream Area was remediated
in 1996 with the removal off-site of approximately 6300 cubic yards of
contaminated soil.
Water Budget
A water budget for the Site was prepared utilizing data gathered
during the Supplemental Stage II investigation. The study was
intended to obtain surface water, ground water, and site-specific
meteorologic data and to discuss and develop a water budget for the
Westerly Wetlands. Data were collected through the installation of
hydrologic monitoring equipment including stream gauges and a small
number of geohydrologic cluster well point systems as well as
meteorologic monitoring equipment.
Data compiled by the investigation included the following: a rainfall
database, hydrographs, ground water flow rates, hydraulic conductivity
of the ground water, and permeability of the Woodbury Clay layer. The
significant components of the water budget of the Westerly Wetlands
identified by the investigation include: precipitation, direct runoff,
delayed runoff, ground water discharge, and evapotranspiration.
The results of the study indicated that the primary hydrologic pathway
of contaminant transport is through surface water runoff. Surface
water runoff (direct runoff plus delayed runoff) accounts for between
44.2 and 48.5 percent of the precipitation that falls on the drainage
basin.
Laboratory Lead Mobility Study
The purpose of the lead mobility study was to determine the mobility
of lead in the soil and the potential for off-site migration of lead
through either surface water or ground water. The study was also
intended to focus the direction of Site remediation efforts toward the
contaminant transport pathways of greatest environmental concern.
The results of the investigations indicated the following:
Lead concentrations in fine particle soil fractions (<74 microns)
were 3 to 10 times higher than in overall bulk soil samples.
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A large fraction of the lead bound to contaminated soils was
potentially available for leaching to surface waters.
The source of lead in surface waters may be lead mobilized from
surface soils.
Specification studies suggested that up to 20 percent or more of
the total lead concentration may be available for release to
surface waters under appropriate mixing conditions.
The reservoir of lead remaining in Site soils may be sufficient
to maintain surface water lead concentrations in the range of 0.1
mg/L to 1.0 mg/L for more than 10 years.
Lead in the soil did not appear to be undergoing rapid downward
migration into or through the ground water aquifer.
Lead concentrations in soil leachate were attenuated by
subsurface soils.
Lead concentrations in ground water were less than 0.04 mg/L even
at relatively shallow depths (10 to 15 feet).
Feasibility Study (1988)
The Feasibility Study that was performed following the RI identified
fourteen different alternatives for detailed evaluation. These
alternatives included seven innovative/alternative remedial treatment
technologies. However, because treatability data were not available
for the innovative/alternative treatment technologies, these
alternatives could not be fully evaluated. Therefore, a final
remedial action could not be selected for the Westerly Wetlands
without a complete evaluation of the innovative/alternative
technologies.
Since the results of previous studies had identified potential risks
to human health and the environment, it was decided that an interim
remedial action for the Westerly Wetlands was necessary to prevent
off-site migration of contaminants. Several remedial alternatives
were evaluated before selecting the interim remedy in the OU-2 ROD
issued on September 29, 1988.
The interim action selected in the OU-2 ROD was containment without
capping of the Westerly Wetlands. This action consisted of
construction of a drainage system and a sedimentation basin to prevent
off-site migration of contaminants, and the installation of a security
fence around the perimeter of the Westerly Wetlands to prevent human
access to the area. In addition, excavation and off-site disposal of
contaminated soil present in the Downstream Area was identified as a
final remedy for that portion of the Site. The ROD also recommended
that treatability studies be performed on the most promising
innovative/alternative remedial technologies for the remaining areas
of concern, namely, the Westerly Wetlands, Northerly Wetlands, and Tar
Patch Area.
Ecological Assessment
In 1991, EPA conducted sampling of biota within the Westerly Wetlands
with the purpose of performing an ecological assessment for this Site.
In addition to biota sampling, EPA also conducted limited soil
sampling.
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Results of the ecological assessment indicated the following:
Plants on Site are accumulating low levels of lead.
Worms are accumulating lead.
Lead and PCBs pose a risk to avian predators (e.g. woodcock) of
soil invertebrates such as earthworms.
PCBs pose a risk to predatory mammals (e.g. red fox and mink) but
not to herbivorous mammals such as deer.
PCBs do not pose a risk to avian predators at higher trophic
levels (e.g. red-tailed hawk).
Functional Assessment of the Wetlands
Five separate ecological investigations were performed as part of the
functional assessment study covering the Westerly Wetlands, Northerly
Wetlands and Tar Patch Area. The purpose of the investigations was to
assess the functions and values of the biological communities on the
Site. The investigations, which were conducted during the autumn of
1993, included survey and mapping of major plant communities, a
wildlife survey, a survey for threatened and endangered species, an
assessment of habitat quality using Habitat Evaluation Procedures
(HEP), and an assessment of the functions and values of wetlands using
the Wetland Evaluation Technique (WET) .
Six plant communities, including three wetland and three upland plant
communities, were identified on the Site. Burnt Fly Bog provides
habitat for a moderate diversity of wildlife species, particularly
birds. Reptiles and amphibians are also likely to be present. The
Westerly Wetlands provides habitat to a greater diversity of wildlife
than the other habitats on the Site and certain species occurring on
the Site are likely to be found only in the Westerly Wetlands. This
is due primarily to the larger size and more diverse habitat structure
of the Westerly Wetlands.
The results of the field survey for threatened and endangered plant
species indicated that no individual specimens of the five species of
concern identified by NJDEP, namely, Barrett's sedge, swamp pink,
yellow-fringed orchid, Knieskern's beaked rush, and coastal oceanorous
were present. However, based on the habitat requirements of each
species of concern, potential habitat for four of the species occurs
in the study area.
Habitat Evaluation Procedures (HEP) were used to identify the quality
of habitat that could be impacted by the proposed remedial activities
for the BFB Site. The results of the HEP analysis indicate that Burnt
Fly Bog provides moderate to optimal habitat for a number of species
that are likely to occur on the Site. Due to the presence of older
and larger trees in the Northerly Wetlands than in the Westerly
Wetlands, the Northerly Wetlands provides moderate to optimal habitat
for canopy dwelling birds and small mammals as well as cavity nesting
birds. The Westerly Wetlands, with more areas of open water
interspersions and vegetation than the Northerly Wetlands, provides
moderate to optimal habitat for amphibian species and birds that
utilize this type of habitat. In addition, due to the larger area of
the Westerly Wetlands compared to the Northerly Wetlands, the Westerly
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Wetlands provides habitat for larger numbers of individual species as
well as species that require a larger home range.
Wetland Evaluation Techniques were used to assess the water quality
functions provided by the wetlands on the Site. An evaluation of the
entire wetlands system (BFB Wetlands System} as well as separate
analyses for the Northerly Wetlands and Westerly Wetlands were
conducted. Results were generated for four categories: social
significance, effectiveness, opportunity, and habitat suitability.
For social significance, the BFB Wetlands System was rated generally
higher than either the Westerly Wetlands or Northerly Wetlands,
because the BFB Wetlands System is the most diverse of the wetland
areas. For effectiveness, the BFB Wetlands System, the Northerly
Wetlands, and the Westerly Wetlands all rated moderate to high for the
evaluated functions and values. For opportunity, WET rated the BFB
Wetlands System, the Northerly Wetlands, and the Westerly Wetlands
generally high. For habitat suitability evaluation, all three wetland
assessment areas received similar ratings. The majority of ratings
received by each wetland assessment area for habitat suitability
evaluation were low to moderate.
Tar Patch Area Delineation
A phased sampling of the Tar Patch
Harris, Inc. in 1993 in order to f
present in the soil in this area,
collection and analysis of surface
PCBs and lead.
Area was conducted by Frederic R.
ully delineate the contamination
The sampling consisted of
and subsurface soil samples for
Using the most stringent NJDEP Soil Cleanup Criteria at that time for
lead and PCBs as reference levels, the total volume of contaminated
soil above 0.49 mg/kg for PCBs and 400 mg/kg for lead was determined
to be 29,600 cubic yards, spread over an area of approximately 5.5
acres. The maximum depth of contamination is 6 feet. The maximum
contaminant concentrations detected in the soil in the Tar Patch Area
were 1060 mg/kg for PCBs and 53,000 mg/kg for lead. However, a lead
concentration of 70,000 mg/kg was detected in a sample taken from
tarry material found in this area.
Northerly Wetlands Sampling
The Northerly Wetlands was sampled in two phases in 1995 in order to
complete the delineation of contamination extent and determine the
volume of contaminated soil present in this part of the Site. Surface
and subsurface soil samples were collected, and were analyzed for PCBs
and lead. The volume of contaminated soil above 0.49 mg/kg for PCBs
and 400 mg/kg for lead was determined to be 4000 cubic yards, the
maximum depth being 2 feet. The maximum contaminant concentrations
detected in the Northerly Wetlands were 150 mg/kg for PCBs and 34,800
mg/kg for lead. The contamination was found to be spread over
approximately 2.5 acres.
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Westerly Wetlands Sampling
Surface soil samples were taken in 1996 to determine the levels of PCS
and lead contamination in the soil, as well as to confirm the lateral
extent of contamination within the Westerly Wetlands. The results
indicated that the area of contamination remained largely unaltered
{during this sampling phase, the maximum lead concentration was 11,000
mg/kg and the maximum PCB concentration was 129 mg/kg). It was also
noted that surface PCB contaminant levels established during the 1996
sample event within the Westerly Wetlands were demonstrated to be
generally less than the contaminant concentrations measured during the
previous investigations in the 1980's.
The total volume of contaminated soil in the Westerly Wetlands is
estimated at 73,300 cubic yards based on the cleanup criteria of 0.49
mg/kg for PCBs and 400 mg/kg for lead. The area covered by
contamination is approximately 21 acres, the maximum depth of
contamination being 4 feet.
Quarterly Monitoring of Surface Water and Sediment in Burnt Fly Brook
Surface water and sediment in Burnt Fly Brook have been sampled and
analyzed for PCBs and lead at four locations in Burnt Fly Brook since
March 1992, at approximately three-month intervals. The sampling
points are located at the point where surface water from the Site
discharges into 3urnt Fly Brook, 200 feet upstream and downstream of
this point, and approximately a half-mile downstream of the point at
which surface water flows from the Site into Burnt Fly Brook.
PCBs have not been detected in water samples collected during the
quarterly monitoring. Lead contaminant levels have not been found to
be consistent, and are likely subject to seasonal variations in the
rate of flow in Burnt Fly Brook. Recent surface water samples
indicated that lead levels were below the human health criteria and
acute aquatic Freshwater criteria, which are 5 micrograms per liter
and 65 micrograms per liter, respectively. However, they were found
to be slightly above the aquatic chronic freshwater criteria of 2.5
micrograms per liter. Lead has also been consistently detected at the
upstream background sample location in Burnt Fly Brook, which
indicates potential sources other than the BFB Site.
The most recent sediment sample data indicated no detectable PCBs in
Burnt Fly Brook. Lead levels in sediment were found to be below the
sediment screening criteria described in the Ontario Ministry of the
Environment and Energy publication entitled, "Guidelines for the
Protection and Management of Aquatic Sediment quality in Ontario,
August 1993".
Treatability Study
A treatability study was conducted in 1996 and early 1997 to evaluate
the effectiveness of treatment technologies on Site soils in
remediating lead and PCB contamination, as specified in the 1988 ROD.
Before the studies were performed, several innovative technologies
were evaluated, including KPEG, B.E.S.T., Bio-Clean, and incineration,
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the four technologies identified in the 1988 ROD for further
evaluation. Soil Washing and Chemical Dechlorination technologies
were finally chosen for the treatability study.
The treatment program consisted of testing the effectiveness of these
two technologies, alone and in combination, on soil specimens obtained
from the Site. Over 180 different combinations of soil, reagents,
temperature, and concentrations were performed and analyzed to
evaluate the two technologies. Based on the results of the different
treatment sample combinations, optimum soil washing processes and
optimum chemical dechlorination processes were developed. Results of
the study indicated that remediation of Site soil to ecology based
cleanup levels could be achieved by using these two technologies in
succession. However, owing to limitations in the soil characteristics
and laboratory detection levels, it was not possible to achieve
reduction in concentrations to human health based levels which are
more stringent. The residual soil after treatment was tested and
found to be deficient in properties to support re-establishment of
wetlands. Further modification of the treated soil would be necessary
to neutralize acidity and to minimize microbial toxicity in order to
make it suitable for the re-establishment of wetlands.
SUMMARY OF SITE RISKS
Based upon the results of all RI efforts, a baseline risk assessment
was conducted to estimate the risks associated with current and future
conditions at the three remaining contaminated areas. The baseline
risk assessment estimates the human health and ecological risk which
could result from the contamination at the Site if no further remedial
action was taken. Details of this risk assessment are summarized in
the May 1994 report entitled Public Health Evaluation.
Human Health Risk Assessment
The reasonable maximum human exposure is evaluated. A four-step
process is used for assessing Site-related human health risks for a
reasonable maximum exposure scenario: Hazard Identification -
identifies the contaminants of concern at the Site based on several
factors such as toxicity, frequency of occurrence, and concentration.
Exposure Assessment - estimates the magnitude of actual and/or
potential human exposures, the frequency and duration of these
exposures, and the pathways (e.g. ingesting contaminated water) by
which human beings are potentially exposed. Toxicity Assessment -
determines the types of adverse health effects associated with
chemical exposures, and the relationship between magnitude of exposure
(dose) and severity of adverse effects (response). Risk
Characterization - summarizes and combines outputs of the exposure and
toxicity measurements to provide a quantitative (e.g. one-in-a-million
excess cancer risk) assessment of Site-related risks.
The Baseline Risk Assessment that was conducted for the BFB Site
evaluated the potential human health risks associated with three
distinct areas of the Site, namely, Westerly Wetlands, Northerly
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Wetlands, and Tar Patch Area. in addition, it also evaluated Burnt
Fly Brook which is found downstream of the BFB Site.
The initial step in the risk assessment process was the selection of
contaminants of concern which would be representative of Site risks.
Lead and PCBs are the predominant contaminants of concern (COC).
However, several inorganic analytes, and volatile and semi-volatile
organic compounds were also included as COCs. Those chemicals which
were thought to contribute most to the Site risk, based on factors
such as frequency of detection and concentration, were retained as
COCs. The full list of the COCs can be found in the Public Health
Evaluation report.
An important factor that impacts the risk assessment is the assumed
future use of the Site. Since the Westerly Wetlands is unlikely to be
developed due to the restrictions placed on protected wetlands,
current and future use will remain as undeveloped wetland. As such,
an exposure scenario for this area included an adult and child
trespasser only. For the Westerly Wetlands, exposure of a Site
trespasser to soil, sediment, surface water, and blueberries was
evaluated. Potential exposure to the Northerly Wetlands and Tar Patch
Area soil and sediment was evaluated for the current trespasser and
the hypothetical future resident of this area. Exposure of area
residents to Burnt Fly Brook sediment and surface water, and ingestion
by residents of edible biota such as deer and waterfowl which may
forage on the Site were also investigated as potential exposure
pathways of concern for the Site.
EPA has determined that an acceptable cancer risk range is 10"* to 10"6,
which can be interpreted to mean that an individual may have a 1 in
10,000 to a 1 in 1,000,000 increased chance of developing cancer as a
result of Site-related exposure to a carcinogen over a 70-year
lifetime under the specific exposure conditions at the Site. EPA
toxicity values were used to quantify risk based on the exposure
scenarios described for the Site. Lead, one of the predominant COCs
at the Site, does not have an assigned EPA toxicity value. Therefore,
the risk from lead exposure could not be quantified using standard
risk assessment methodologies.
PCBs, benzo(a)pyrene, and benzo(b)fluoranthene are the main compounds
associated with carcinogenic risk. The total risk for the Westerly
Wetlands trespasser was estimated to be 1.49 x 10~\ The dermal and
ingestion pathways for soil and sediment containing PCB compounds are
the primary contributors to carcinogenic risk. Ingestion of on-site
blueberries was not shown to contribute significantly to elevated
carcinogenic or non-carcinogenic risk.
The total risk for the combined Northerly Wetlands/Tar Patch Area
trespasser scenario was estimated to be 1.07 x 10~3. The dermal and
ingestion pathways for soil and sediment containing PCB compounds are
the primary contributors to carcinogenic risk. The total carcinogenic
risk for a future resident living on the Northerly Wetlands/Tar Patch
Area of the Site was estimated at 7.5 x 10 3. Here too, the dermal and
ingestion pathways for soil and sediment are the primary contributors
to carcinogenic risk.
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To assess the overall potential for non-carcinogenic effects posed by
more than one contaminant, a hazard index (HI) was developed. This
index measures the assumed exposures to several chemicals at low
concentrations simultaneously, which could result in adverse health
effects. In accordance with this approach, a hazard quotient (i.e.,
the ratio of the level of exposure to an acceptable level) greater
than 1.0 indicates a potential for adverse non-carcinogenic health
effects. The HI is summed for all media common to a particular
receptor.
With regard to non-carcinogenic effects, based on the calculated His,
the trespasser scenario for the Westerly Wetlands, Northerly Wetlands
and Tar Patch Area, and the future residential scenario for the
Northerly Wetlands/Tar Patch Area do not contribute to an unacceptable
non-carcinogenic risk.
Risk associated with ingestion and dermal contact of contaminated
soil, ingestion of brook sediment, dermal contact with brook surface
water, and ingestion of brook surface water could not be quantified
based on exposure to lead, since no EPA verified toxicity values are
available for lead. Although risk to lead was not quantified,
concentrations of lead in Tar Patch Area and wetland soils (see Table
1 in Appendix II) may be considered a risk with respect to ingestion
and dermal contact based on comparison to EPA Screening Levels (400
mg/kg lead) and NJDEP Soil Cleanup Criteria for lead (also 400 mg/kg
lead). A qualitative evaluation for exposure to brook sediment and
surface water determined that lead exposure associated with ingestion
of brook sediment and dermal contact with brook surface water did not
exceed a level calculated to be an acceptable intake of lead in soils
and drinking water. The intake of lead associated with ingestion of
venison and waterfowl was shown to be insignificant, when modeled to
an acceptable lead intake associated with exposure to contaminated
soils .
Ecological Risk Assessment
Ecological Risk Assessment involves a qualitative and/or semi-
quantitative appraisal of the actual or potential effects of a
hazardous waste site on plants and animals. A four-step process is
used for assessing Site-related ecological risks for a reasonable
maximum exposure scenario: Problem Formulation - a qualitative
evaluation of contaminant release, migration, and fate; identification
of contaminants of concern, receptors, exposure pathways, and known
ecological effects of the contaminants; and selection of endpoints for
further study. Exposure Assessment - a quantitative evaluation of
contaminant release, migration, and fate; characterization of exposure
pathways and receptors; and measurement or estimation of exposure
point concentrations. Ecological Effects Assessment - literature
reviews, field studies and/or tests linking contaminant concentrations
to effects on ecological receptors. Risk Characterization -
measurement or estimation of both current and future adverse effects.
The ecological evaluation of the BFB Site included an Ecological Risk
Assessment conducted by EPA in 1992, as well as a follow-up
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Environmental Risk Assessment performed in 1994 by BCM Engineers Inc.
for NJDEP.
The EPA Ecological Risk Assessment consisted of a comprehensive
sampling and analysis program of abiotic and biota media, laboratory
bioassays, and calculated risk for selected species of wildlife
representing several trophic levels. The scope of the assessment was
limited to the Westerly Wetlands. On the basis of standard risk
assessment modeling methods utilized by EPA, no organisms, except
woodcock under a high exposure scenario, were found to be at risk for
lead. Mammalian predators, including red fox, and mink, and avian
predators of soil invertebrates, such as woodcock, were found to be at
risk because of the presence of PCBs. Based on the applied EPA
reference dose, red-tailed hawk, an avian predator, was determined not
to be at risk from PCBs. Herbivorous or primarily herbivorous
wildlife (e.g., white tailed deer, voles, and mice) were also
determined not to be at risk. Based on EPA tissue bioassays, shrews
are very likely to be adversely affected by PCB levels in their
tissues. Comparison of Burnt Fly Bog forage species tissue levels to
the Great Lakes International Joint Commission Predator Protection
Levels for PCBs indicates that woodcock, red-tailed hawk, red fox and
mink may all be at risk from feeding at the Site.
The follow-up Environmental Risk Assessment performed in 1994 focused
on those species that were determined not to be at risk in the EPA
study. The Environmental Risk Assessment evaluated the effects of
Site-related contaminants of concern, namely PCBs and lead, on the
Site's natural resources in the Westerly Wetlands, Northerly Wetlands,
and Tar Patch Area. Natural resources include existing flora and
fauna, wetland communities, and sensitive species or habitats. A
wetlands delineation performed at the Site identified approximately 25
acres of wetland areas within the three contaminated areas. No
federally listed or proposed threatened or endangered flora or fauna
are known to occur at or near the Site. The Environmental Risk
Assessment considered the effects of lead on red-tailed hawk, fox, and
deer, and PCBs on red-tailed hawk.
The Environmental Risk Assessment did not arrive at conclusions that
were different from those presented in the 1992 EPA Ecological Risk
Assessment. It confirmed that lead posed a risk only to avian
predators (e.g. woodcock) of soil invertebrates (e.g. earthworms).
PCBs pose a risk to predatory mammals such as red fox and mink, but
not to herbivorous mammals such as deer. PCBs do not pose a risk to
avian predators at the higher trophic levels (e.g. red-tailed hawk),
except when evaluated against the Great Lakes International Joint
Commission Predator Protection Levels for PCBs.
The Environmental Risk Assessment suggests that concentrations of lead
in soil may cause phytotoxicity in some species of plants, including
threatened and endangered plant species that could potentially occur
at the Site. Significant uptake of PCBs into plant tissue was not
measured.
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REMEDIAL ACTION OBJECTIVES
Remedial Action Objectives are specific goals to protect human health
and the environment. These objectives are based on available
information, applicable or relevant and appropriate requirements
(ARARs), and risk-based levels established in the risk assessment.
The following remedial action objectives were established for cleanup
activities for the remaining unremediated portions of the BFB Site:
Minimize exposures to PCBs and lead in soil at levels exceeding
State and Federal soil cleanup criteria, while minimizing the
extent of wetlands to be excavated;
Minimize/control releases of contaminants in sediment into
surface waters during storm events;
Minimize/control exposures to PCBs and lead in soil to ecological
receptors; and
Restore the wetlands to a productive ecosystem.
DESCRIPTION OF REMEDIAL ALTERNATIVES
CERCLA requires that the selected Site remedy be protective of human
health and the environment, be cost effective, comply with other
applicable or relevant and appropriate requirements, and utilize
permanent solutions, alternative treatment technologies, and resource
recovery alternatives to the maximum extent practicable. In addition,
the statute includes a preference for the use of treatment as a
principal element for the reduction of toxicity, mobility, or volume
of the hazardous substances.
Three different soil cleanup criteria for lead and PCBs were used
during the evaluation of alternatives in the Supplemental Feasibility
Study. The soil cleanup criteria were established based on the most
current NJDEP soil cleanup criteria, EPA screening levels, and values
derived from the ecological risk assessment. They are as follows:
NJDEP Soil Cleanup Criteria (residential) of 0.49 mg/kg for PCBs
and 400 mg/kg for lead.
EPA Screening Levels of 1 mg/kg for PCBs and 400 mg/kg for lead.
Ecological risk assessment based numbers of 5 mg/kg for PCBs and
8,950 mg/kg for lead.
Volumes of contaminated soil present in the three areas of concern
above the three sets of cleanup criteria are shown in the Supplemental
Feasibility Study Report. The estimated costs of remediation using
the three sets of cleanup criteria for the different remedial
alternatives considered are also shown in the report.
The remedy selection process described herein is based on the most
stringent human health based cleanup criteria of 0.49 mg/kg for PCBs
and 400 mg/kg for lead (note: these levels are also more stringent
than the ecological risk assessment based numbers described above).
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Use of these criteria will allow for unrestricted use of portions of
the Site in the future.
The Supplemental FS report evaluates in detail six remedial
alternatives for addressing the contamination associated with the
Westerly Wetlands and Northerly Wetlands, and seven alternatives for
addressing the contamination associated with the Tar Patch Area.
The Westerly Wetlands and Northerly Wetlands were evaluated separately
from the Tar Patch Area because the natural characteristics of the
wetland areas and the Tar Patch area are distinctly different, and the
contaminant distributions are also different, hence, warranting
different considerations in the remedy selection process. For ease of
identification in this ROD, the remedial alternatives for the wetland
areas (Westerly Wetlands and Northerly Wetlands) are listed as
Alternative W-l through Alternative W-6, while those for the Tar Patch
Area are listed as Alternative TP-1 through Alternative TP-7.
The remedial alternatives are described in detail below.
Implementation times given include the time necessary to construct and
implement the remedy but do not include the time required for design
or award of a contract for the performance of the work.
Westerly Wetlands and Northerly Wetlands
Alternative W-l - No Action
Westerly Wetlands
Capital Cost: $0
O&M Cost: $0
Present Worth Cost: $0
Construction Time:
Not Applicable
Northerly wetUnti?
Capital Cost: $0
O&M Cost: $0
Present Worth Cost:
Construction Time:
Not Applicable
$0
The Superfund program requires that the "No Action" alternative be
considered as a baseline for comparison of other alternatives. The no
action alternative involves no remedial action to reduce the toxicity,
mobility or volume of contamination in the Westerly Wetlands and
Northerly Wetlands. These portions of the Site will remain in their
present condition. The wetland system can continue to function as a
valuable hydrologic resource and continue to provide habitat for a
wide variety of flora and fauna. The contaminated sediment left
behind will present a risk to some species (small mammal and avian)
for an undetermined period of time. However, the natural processes of
the wetland ecosystem including vegetation growth, decay, and sediment
build-up are expected to gradually cover the contaminated areas over
time, thus reducing the risk of exposure to the ecological receptors.
The effectiveness of this cover process would require careful
monitoring. Over the past ten years, obvious visible changes have
been observed in the wetland areas with a steady improvement in the
vegetation.
Before surface water leaves the Site, the sedimentation basin that has
already been constructed in the Downstream Area will collect any
contaminated sediment that may migrate in storm flows originating from
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the rest of the Site. Although the presence of lead was detected in
surface water within the Westerly Wetlands in the past, the on-going
monitoring of surface water and sediment in Burnt Fly Brook
immediately downstream of the Site has not shown appreciable levels of
lead in the water (refer to the section on Quarterly Monitoring of
Surface Water and Sediment on page 13). Because this alternative
would result in contaminants remaining on Site, CERCLA requires that
the Site be reviewed every five years. If justified by the review,
further remedial action may be implemented to address the contaminated
soil.
Alternative W-2 - Limited Action and Institutional Controls
Westerly Wetlands Northerly Wetlands
Capital Cost: $76,400
Annual O&M Cost: $3,850
(for 30 years)
Present Worth Cost: $136,000
Construction Time: 6 months
Capital Cost: $41,600
Annual O&M Cost: $1,950
(for 30 years)
Present Worth Cost: $71,000
Construction Time: 6 months
Alternative W-2 consists of the installation of additional security
fencing in areas where fencing has not already been provided, and the
recording of a Deed Notice for the contaminated areas of the Site to
restrict future use of the Site. Protection of human health will be
achieved by constructing the fence which will prevent potential
exposure to contaminants through direct contact. The wetland system
can continue to function as a valuable hydrologic resource and
continue to provide habitat for a wide variety of flora and fauna.
The contaminated sediment left behind will present a risk to some
species (small mammals and avian species) for an undetermined period
of time. However, the natural processes of the wetland ecosystem
including vegetation growth, decay, and sediment build-up are expected
to gradually cover the contaminated areas over time, thus reducing the
risk of exposure to ecological receptors. The effectiveness of this
cover process would require careful monitoring. Over the past ten
years, obvious visible changes have been observed in the wetland areas
with a steady improvement in the vegetation.
Before surface water leaves the Site, the existing sedimentation basin
in the Downstream Area will collect any contaminated sediment that may
migrate in storm flows originating from the rest of the Site.
Although lead was detected in surface water within the Westerly
Wetlands in the past, the on-going monitoring of surface water and
sediment in Burnt Fly Brook immediately downstream of the Site has not
shown appreciable levels of lead in the water (refer to section on
Quarterly Monitoring of Surface Water and Sediment on page 13).
Because this alternative would result in contaminants remaining on
Site, the Site will be reviewed every five years in accordance with
the requirements of CERCLA.
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Alternative W-3 - Excavation, Off-site Disposal, and Wetland
Restoration
Westerly Wetlands
Northerly Wetlands
Capital Cost: $28,202,000
Annual O&M Cost: $4,250
Capital Cost: $2,583,000
Annual O&M Cost: $4,250
(for 7 years)
Present Worth Cost: $28,227,000
Construction Time: 1 year 6 months
(for 7 years)
Present Worth Cost: $2,608,000
Construction Time: 6 months
Alternative W-3 consists of the excavation and off-site disposal of
contaminated soil present in the Westerly Wetlands and Northerly
Wetlands. The excavated areas will be backfilled with clean loamy
soil that is capable of sustaining wetland vegetation. Wetlands will
be restored in the areas affected by excavation. The newly created
wetlands will be monitored for at least seven years to ensure proper
restoration of wetlands.
Alternative W-4 - Consolidation, and Wetland Restoration
Capital Cost: $7,660,000
Annual O&M Cost: $10,200 (for 30 years)
Present Worth Cost: $7,835,000
Construction Time: 2 years
(Costs associated with this alternative are not shown separately for
the two wetland areas as the remedial activities will be focused on
the combined area.).
Alternative W-4 consists of partial relocation of contaminated soil
into areas within the impacted areas of the Westerly Wetlands and
Northerly Wetlands for consolidation. The consolidation areas will be
chosen so as not to impede drainage within the Site. The soil will be
allowed to remain in place for a year in order for it to consolidate
by its own weight. An impermeable soil cap will be constructed on top
of the consolidated soil to limit exposure to contamination. The
excavated areas will be backfilled with clean loamy soil that is
capable of sustaining wetland vegetation. Wetlands will be restored
in the backfilled areas. The newly created wetlands will be monitored
for at least seven years to ensure proper restoration of wetlands.
The consolidated areas will be maintained for 30 years with periodic
inspection of the cap to ensure that its structural integrity is
maintained. Because this alternative would result in contaminants
remaining on Site, CERCLA requires that the Site be reviewed every
five years. If justified by the review, further remedial action may
be implemented to address the contaminated soil.
Alternative W-5 - Pyrokiln Thermal Treatment, and Wetland Restoration
Westerly Wetlands
Northerly Wetlands
Capital Cost: $67,920,000
Annual O&M Cost: $4,250
(for 7 years)
Capital Cost: $4,090,000
Annual O&M Cost: $4,250
(for 7 years)
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Present Worth Cost: $67,945,000 Present Worth Cost: $4,115,000
Construction Time: Construction Time:
6 years 4 months 2 years 3 months
Alternative W-5 involves the incineration of the contaminated soil in
a rotary kiln while adding inorganic additives to promote thermal
volatilization and/or encapsulation. The resultant ash is a mass of
stabilized slag of insoluble, inert particles. Fluxing compounds are
required to be added to promote the formation of nodules of the
required size. A pilot study would be required to determine the
required fluxing compounds, before full scale implementation. The
residual material after treatment will not be suitable for the
establishment of wetlands and hence will be disposed of off-site. The
excavated areas will be backfilled with clean loamy soil that is
capable of sustaining wetland vegetation. Wetlands will be restored
in the backfilled areas. The newly created wetlands will be monitored
for at least seven years to ensure proper restoration of wetlands.
Alternative W-6 - Soil Washing. Chemical Dechlorination, and Wetland
PgS tQTff t,j-Qn
Westerly Wetlands Northerly Wetlands
Capital Cost: $104,695,000 Capital Cost: $7,790,000
Annual O&M Cost: $3,550 Annual O&M Cost: $3,550
(for 7 years) (For 7 years)
Present Worth Cost: $104,720,000 Present Worth Cost: $7,815,000
Construction Time: Construction Time:
6 years 4 months 2 years 6 months
Alternative W-6 involves high-energy contacting and mixing of
contaminated soil with an aqueous solution in a series of mobile
washing units for soil washing treatment. After soil washing is
completed, the material will undergo chemical dechlorination
treatment. The soil washing/chemical dechlorination technologies will
only remediate the soil to the higher remediation goals of 5 mg/kg for
PCBs and 8950 mg/kg for lead. Treated soil will be disposed of off-
Site, because it will not be suitable for establishing wetlands. The
excavated areas will be backfilled with clean loamy soil that is
capable of sustaining wetland vegetation. Wetlands will be restored
in the backfilled areas. The newly created wetlands will be monitored
for at least seven years to ensure proper restoration.
Tar Patch Area
Alternative TP-1 - No Action
Capital Cost: $0
O&M Cost: $0
Present Worth Cost: $0
Construction Time: Not applicable
The Superfund program requires that the "No Action" alternative be
considered as a baseline for comparison of other alternatives. The no
action alternative involves no remedial actions to reduce the
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toxicity, mobility or volume of contamination in the Tar Patch Area.
This part of the Site will continue to remain in its present
unvegetated condition, thus remaining vulnerable to more severe
erosion and transport of contaminants downstream. Before surface
water leaves the Site, the sedimentation basin that has already been
constructed in the Downstream Area will collect sediment that may
migrate in storm flows originating from the rest of the Site. Because
this alternative would result in contaminants remaining on Site,
CERCLA requires that the Site be reviewed every five years. If
justified by the review, further remedial action may be implemented to
remove or treat the contaminated soil.
Alternative TP-2 - Limited Action and Institutional Controls
Capital Cost: $60,000
Annual O&M Cost: $3,600 (for 30 years)
Present Worth Cost: $114,700
Construction Time: 2 months
Alternative TP-2 consists of the installation of security fencing
around the Tar Patch Area, and the recording of a Deed Notice for the
contaminated area to limit future use of the area. Protection of
human health will be achieved by constructing the fence which will
prevent potential exposure to contaminants through direct contact.
Before surface water leaves the Site, the sedimentation basin that has
already been constructed in the Downstream Area will collect sediment
in storm flows originating from the rest of the Site, including the
Tar Patch Area. Because this alternative would result in contaminants
remaining on Site, the Site will be reviewed every five years in
accordance with the requirements of CERCLA.
Alternative TP-3 - Excavation, Off-site Disposal, and Wetland
Establishment
Capital Cost: $13,965,000
Annual O&M Cost: $1,100 (for 7 years)
Present Worth Cost: $13,975,000
Construction Time: 1 year
Alternative TP-3 consists of the excavation and off-site disposal of
contaminated soil present in the Tar Patch Area. The excavated areas
will be backfilled with clean loamy soil that is capable of sustaining
wetland vegetation. Wetlands will be created in the area affected by
excavation. The newly created wetlands will be monitored for at least
seven years to ensure proper establishment of wetlands.
Alternative TP-4 - Consolidation, and Wetland Establishment
Capital Cost: $2,670,000
Annual O&M Cost: $6,200 (for 7 years)
Present Worth Cost: $2,765,000
Construction Time: 1 year 6 months
Alternative TP-4 consists of partial relocation of contaminated soil
into areas within the impacted Tar Patch Area for consolidation. The
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consolidation areas will be chosen so as not to impede drainage within
the Site. The soil will be allowed to remain in place for a year to
allow it to consolidate by its own weight before constructing the cap.
An impermeable soil cap will be constructed on top of the consolidated
soil to limit exposure to the contaminated soil. The excavated areas
will be backfilled with clean loamy soil capable of sustaining wetland
vegetation. Wetlands will be created in the backfilled areas. The
newly created wetlands will be monitored for at least seven years to
ensure proper establishment of wetlands. The consolidated areas will
be maintained for 30 years with periodic inspection of the cap to
ensure that its structural integrity is maintained. Because this
alternative would result in contaminants remaining on Site, CERCLA
requires that the Site be reviewed every five years. If justified by
the review, further remedial action may be implemented to address the
contaminated soil.
Alternative TP-5 - Pvrokiln Thermal Treatment, and Wetland
Establishment
Capital Cost: $29,045,000
Annual O&M Cost: $1,100 (for 7 years)
Present Worth Cost: $29,050,000
Construction Time: 3 years 1 month
Alternative TP-5 involves the incineration of the contaminated soil in
a rotary kiln and adding inorganic additives to promote thermal
volatilization and/or encapsulation. The resultant ash is a mass of
stabilized slag of insoluble, inert particles. Fluxing compounds are
required to be added to promote the formation of nodules of the
required size. A pilot study to determine the required fluxing
compounds would be required before full scale implementation. The
residual material after treatment will not be suitable for the
establishment of wetlands and hence will be disposed of off-site. The
excavated areas will be backfilled with clean loamy soil. Wetlands
will be created in the backfilled areas. The newly created wetlands
will be monitored for at least seven years to ensure proper
establishment of wetlands.
Alternative TP-6 - Soil Washing. Chemical Dechlorination, and Wetland
Establishment
Capital Cost: $34,525,000
Annual O&M Cost: $1,100 (for 7 years)
Present Worth Cost: $34,530,000
Construction Time: 3 years 1 month
Alternative TP-6 involves high-energy contacting and mixing of
contaminated soil with an aqueous solution in a series of mobile
washing units, to perform soil washing. After soil washing is
completed, the material will undergo chemical dechlorination
treatment. The soil washing and chemical dechlorination technologies
will only remediate the soil to the higher remediation goals of 5
mg/kg for PCBs and 8950 mg/kg for lead. Treated soil will be disposed
of off-site as it will not be suitable for establishing wetlands. The
excavated areas will be backfilled with clean loamy soil. Wetlands
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will be created in the backfilled areas. The newly created wetlands
will be monitored for at least seven years to ensure proper
establishment of wetlands.
Alternative TP-7 - Capping and Engineering Controls
Capital Cost: $2,485,000
Annual O&M Cost: $6,200 (for 30 years)
Present Worth Cost: $2,580,000
Construction Time: 4 months
Alternative TP-7 involves the construction of an impermeable soil cap
over the contaminated area. The cap will limit exposure to the
contaminated soil and prevent erosion of contaminated soil during
storm flows. Engineering controls will be provided to facilitate the
movement of storm water originating in upstream areas, around the
capped area. The capped area will be maintained for 30 years with
periodic inspection of the cap to ensure that its structural integrity
is preserved. Because this alternative would result in contaminants
remaining on Site, CERCLA requires that the Site be reviewed every
five years. If justified by the review, further remedial action may
be implemented to address the contaminated soil.
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
In accordance with the NCP, a detailed analysis of each remedial
alternative was conducted with respect to each of the nine criteria
described below. This section discusses and compares the performance
of the remedial alternatives when considered against these criteria.
All selected alternatives must at least attain the Threshold Criteria.
The selected alternative should provide the best balance among the
nine criteria. The Modifying Criteria were evaluated following the
public comment period.
The evaluation criteria are described below:
Threshold Criteria
1. Overall protection of human health and the environment addresses
whether or not an alternative provides adequate protection and
describes how risks posed through each pathway are eliminated,
reduced, or controlled through treatment, engineering controls,
or institutional controls.
requirements (ARARs) addresses whether or not an alternative will
meet all of the ARARs of the Federal and State environmental
statutes or provide a basis for invoking a waiver.
Primary Balancing Criteria
3. Long-term effectiveness and permanence refers to the magnitude of
residual risk and the ability of an alternative to maintain
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reliable protection of human health and the environment over
time, once remedial objectives have been met.
4 . Reduction of toxicity, mobility, or volume through treatment
addresses the statutory preference for selecting remedial actions
that employ treatment technologies that permanently and
significantly reduce toxicity, mobility, or volume of the
hazardous substances as a principal element.
5. Short-term effectiveness refers to the period of time that is
needed to achieve protection, as well as the alternative's
potential to create adverse impacts on human health and the
environment during the construction and implementation period.
6. Implement.ability is the technical and administrative feasibility
of a remedy, including the availability of materials and services
needed to implement a particular alternative.
7. Cost includes estimated capital, and operation and maintenance
costs, and net present worth costs.
Modifying Criteria
Support Agency acceptance indicates whether, based on its review
of the RI and FS reports and the ROD, the support agency opposes,
and/or has identified any reservations with the preferred
alternative.
Community acceptance refers to the public's general response to
the alternatives described in the Proposed Plan and the RI/FS
reports. Responses to public comments are addressed in the
Responsiveness Summary (see Appendix VI).
Westerly Wetlands and Northerly Wetlands
The following presents a comparative analysis of the alternatives for
the Westerly Wetlands and Northerly Wetlands based upon the evaluation
criteria noted above.
Overall Protection of Human Health and the Environment
Alternatives W-3 and W-5 provide for the maximum protection of human
health and the environment on-site, since under each of these
alternatives, all contaminated soil would be excavated and treated on-
site or managed off-site in some manner. Alternative W-6 will be less
protective of human health, because contaminated soil will be
remediated to ecological risk-based cleanup levels. However, each of
these three alternatives results in significantly increased impact to
the environment during implementation, because large portions of
moderate and optimal wetland habitat would be destroyed to gain
access, and to excavate contaminated media. The Westerly Wetlands
would be impacted to a greater extent as the excavation alternative
would destroy a larger area of more valuable wetlands. These three
alternatives will also significantly extend the period of time needed
for the whole Site ecosystem to be fully restored. There is also a
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level of uncertainty associated with the capabilities and
effectiveness of Alternative W-5. In addition, Alternative W-5 will
result in air emissions that will require collection and treatment.
Alternative W-4 provides a lesser degree of protection of human
health, because contaminated soil will remain on Site consolidated
under an impermeable soil cap. Due to excavation, however, the
impacts to the wetland ecosystem will be the same as for Alternatives
W-3, W-5, and W-6. Alternative W-2 provides even lesser degree of
protection of human health since all contaminated material will be
allowed to remain within the wetlands, and this alternative will rely
on engineering and institutional controls to prevent contaminants from
migrating off-site, and to control human exposure to on-site
contaminated media left in the wetlands. However, this alternative
will not require destruction of any moderate and optimal wetland
habitat in the Westerly Wetlands, thus allowing for continued
occurrence of natural processes (i.e., sedimentation) which are
expected to reduce exposure to soil contaminants over time. The
Northerly Wetlands would not have the same degree of natural
sedimentation and humification, because of the local hydrology and the
type of vegetation. The ecosystem will be hydrologically functional
and continue to support species diversity. The existing sedimentation
basin within the Downstream Area will continue to prevent any off-site
migration of contaminated sediment. Alternative W-l provides the
least protection of human health since all contaminated material will
be allowed to remain within the wetlands without any engineering and
institutional controls to limit exposures. Similar to Alternative
W-2, Alternative W-l will provide some environmental benefit by
leaving moderate and optimal wetland habitat undisturbed, thereby
allowing for natural processes to continue.
Compliance with ARARs
Alternatives W-3, W-5 and W-6 are expected to provide similar degrees
of compliance with ARARs. Off-site disposal of treated material in
Alternative W-5 and Alternative W-6 will be performed in accordance
with Resource Conservation and Recovery Act (RCRA) Land Disposal
Restrictions. In Alternative W-3, contaminated soil will be disposed
of off-site in accordance with RCRA land disposal requirements and
Toxic Substances Control Act (TSCA) regulations. Transport of
materials will be done in compliance with United States Department of
Transportation (USDOT) regulations for hazardous materials
transportation. Air emissions during field operations will be
monitored and controlled to satisfy the requirements of the Clean Air
Act. Fresh water wetlands will be restored in areas impacted by
remedial activities, thereby meeting the requirements of the Fresh
Water Wetlands Protection Act, and the Endangered Species Act.
Action-specific and location-specific ARARs will be met during the
implementation of Alternative W-4. Wetlands will be created in the
excavated areas, except in capped areas. The loss of any wetlands
will be mitigated.
Alternatives W-l and W-2 will not attain chemical-specific to-be-
considered (TBC) criteria for surface soils as site soil will be
allowed to remain in place, untreated. Although there are current
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exceedances of New Jersey Surface Water Quality Standards,
Alternatives W-l and W-2, in conjunction with the sedimentation basin,
are also expected to meet chemical-specific ARARs for surface water.
Alternatives W-l and W-2 will meet action-specific ARARs.
Long-Term Effectiveness and Permanence
Alternatives W-3 and W-5 are expected to be the most effective
remedies in the long-term with respect to on-site protection of human
health and the environment. Alternative W-6 is slightly less
effective than Alternatives W-3 and W-5 since it reduces contamination
to ecological risk-based cleanup levels only. Alternatives W-5 and W-
6 are expected to treat the contaminated soil and, thereby, would
result in less residual, untreated wastes than in the case of the
other alternatives. Alternative W-3 will provide long-term
effectiveness through the removal of contaminated soil from the Site
for disposal off-site. Except for monitoring of wetland restoration,
no other controls will be required with Alternatives W-3, W-5 and W-6.
There will be uncertainty associated with the duration and the
effectiveness of wetland restoration. There is no certainty that all
of the natural services and biological diversity currently provided by
the existing ecosystem can ever be suitably restored, or if so, how
long full restoration will take.
Alternatives W-2 and W-4 are expected to be less effective in the
long-term because contaminated soil will remain on Site without
treatment. Exposure to contamination will be prevented through the
construction of an impermeable soil cap on consolidated soil in the
case of Alternative W-4. In Alternative W-2, human exposure to
contaminated soil will be prevented by constructing a security fence,
and by imposing use restrictions by filing a Deed Notice on the
property. The existing sedimentation basin will collect sediment in
storm flows before surface water leaves the Site. The wetland system
will remain unaffected by Alternative W-2, and sediment build-up from
seasonal wetland processes are expected to gradually create a natural
protective barrier on top of the contaminated soil. Careful
monitoring of these natural processes will be needed to insure
reduction in ecological exposure risks over time. Five year reviews
of these alternatives will be required due to the continued presence
of contamination.
Alternative W-l is the least effective in the long-term because the
contaminated soil will remain within the wetlands without any
engineering and institutional controls to limit exposure. Five year
reviews will be required due to the continued presence of
contamination. The wetland system will remain unaffected and natural
sedimentation from seasonal wetland processes is expected to create a
protective cover over time. The existing sedimentation basin will
collect sediment in storm flows before surface water leaves the Site.
Reduction in Toxicity. Mobility, or Volume
Alternatives W-5 and W-6 provide the greatest potential reduction of
toxicity, mobility, or volume through treatment of the contaminated
soil. Alternative W-5 will remediate the soil by thermal treatment.
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Alternative W-6 will reduce toxicity of the soil by soil washing and
chemical dechlorination.
Alternative W-4 provides a limited reduction in contaminant mobility
by placing an impermeable soil cap over consolidated areas of
contaminated soil. Toxicity and volume will not be reduced.
Alternative W-3 provides reduction in mobility of the contaminants by
excavation and off-site disposal in a landfill. Toxicity and volume
will not be reduced by this alternative.
Alternatives W-l and W-2 provide no reduction in toxicity, mobility or
volume of the contaminated soil.
Short-term Sf£ectivene=?s
Alternative W-l presents the least short-term risk to human health and
the environment, because it involves no remediation and no disturbance
of existing contamination within the wetlands. While the wetland
areas remain contaminated, the risk of exposure to the contaminants is
expected to be significantly mitigated by natural re-vegetation and
sedimentation processes over time. However, while no increases in
risk result in the short-term, remedial response objectives are not
achieved.
Alternative W-2 can be considered to pose slightly greater short-term
risk than Alternative W-l, because it involves the construction of a
perimeter fence around portions of the Site where a fence has not
already been constructed. However, the environmental impacts of
constructing the fence at the periphery of the Site is minimal.
The remaining alternatives, all of which involve Site remediation,
present greater short-term risks to human health and the environment.
There will be short-term health risks associated with large scale
movement of contaminated soil. Exposure controls such as the use of
personal protective equipment and implementation of dust control
measures will minimize short-term risks. The existing sedimentation
basin in the Downstream Area will be used to capture sediment released
downstream during construction operations. Off-site transportation of
contaminated soil in Alternative W-3 will slightly increase potential
short-term exposure risks to the adjacent community and the
environment. The longer time required to implement Alternatives W-5
and W-6 will also increase the short-term risk. The impacts caused to
the existing ecosystem as a result of W-3, W-4, W-5, and W-6 will be
immense. There will be short-term risks to the ecosystem,
biodiversity and habitat, because of such large scale disruption to
the environment.
Implementabi1itv
Alternative W-l is the most implementable of the alternatives because
it requires that no action be taken.
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Alternative W-2 can be implemented easily because it involves only the
construction of a perimeter fence and the implementation of
institutional controls (i.e., Deed Notice) by the State of New Jersey.
Among alternatives that involve Site remediation, Alternative W-3 is
easier to implement than the others. Excavation of contaminated soil,
off-site disposal, and backfilling with clean fill material to restore
wetlands can be done using common earthmoving machinery and equipment.
The existing sedimentation basin can be used for capturing any
sediment migration during field operations.
Alternative W-4 will be slightly more difficult to implement because
of the longer time required to complete the work. The consolidated
soil will be allowed to settle for a year before the impermeable soil
cap is constructed. Alternative W-4 also can be implemented using
conventional earthmoving machinery and equipment.
Alternatives W-5 and W-6 are the alternatives that are most difficult
to implement, because they involve the on-site setup and operation of
the treatment processes. These alternatives also take the longest
time to implement.
Total present worth cost estimates for implementing the alternatives
range from $0 to $112,535,000. Alternative W-l does not entail any
cost because it requires that no action be taken. The next least
costly alternative is Alternative W-2 with a present worth of
$207,000. Alternative W-4 costs the least among alternatives that
involve active Site remediation. The present worth cost for
alternative W-4 is $7,835,000. Alternatives W-3 and W-5 cost
$30,835,000 and $72,060,000 to implement, respectively. Alternative
W-6 at a cost of $112,535,000 is the alternative with the highest cost
to implement.
When only capital costs for alternatives are compared, they follow the
same trend as for present worth costs.
Tar Patch Area
The following presents a comparative analysis of the alternatives for
the Tar Patch Area based upon the evaluation criteria.
Overall Protection of Human Health and the Environment
Alternatives TP-3 and TP-5 provide for the maximum protection of human
health and the environment on-site, because all contaminated soil
would be excavated and treated on-site or managed off-site in some
manner. Alternative TP-6 will be less protective of human health,
because contaminated soil will be remediated to ecological risk based
numbers. There is a level of uncertainty associated with the
capabilities and effectiveness of Alternative TP-5. In addition,
Alternative TP-5 will result in air emissions that will require
collection and treatment. Alternative TP-4 and TP-7 provide a lesser
degree of protection of human health, because contaminated soil will
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be allowed to remain on Site under an impermeable soil cap. There
will be some impact to the ecosystem that exists within the Site,
during remedial operations under Alternatives TP-3, TP-4, TP-5, TP-6
and TP-7. Alternative TP-2 provides even a lesser degree of
protection of human health and the environment since all contaminated
material will be allowed to remain on the Site. This alternative will
rely on engineering and institutional controls to prevent contaminants
from migrating off-site, and to control human exposure to on-site
contaminated media but will continue to allow exposure to the
biological receptors. The existing sedimentation basin within the
Downstream Area will continue to prevent any off-site migration of
contaminated sediment. Alternative TP-1 provides the least protection
of human health since all contaminated material will be allowed to
remain within the Site without any engineering and institutional
controls to limit exposures.
Compliance with ARARs
Alternatives TP-3, TP-5 and TP-6 are expected to provide similar
degrees of compliance with ARARs. Off-site disposal of treated
material in Alternative TP-5 and Alternative TP-6 will be performed in
accordance with RCRA Land Disposal Restrictions. In Alternative TP-3,
off-site disposal of contaminated soil will be disposed of off-site in
accordance with RCRA land disposal requirements and TSCA regulations.
Transport of materials will be done complying with USDOT regulations
for hazardous materials transportation. Air emissions during field
operations will be monitored and controlled to satisfy the
requirements of the Clean Air Act. Fresh water wetlands will be
restored in areas impacted by remedial activities, thereby meeting the
requirements of the Fresh Water Wetlands Protection Act, and the
Endangered Species Act.
Action-specific and location-specific ARARs will be met during the
implementation of Alternative TP-4 and Alternative TP-7. In the case
of Alternative TP-4, wetlands will be created in the excavated areas,
except in capped areas. The loss of any wetlands will be mitigated.
Alternatives TP-1 and TP-2 will not attain chemical-specific TBC
criteria for surface soils as site soil will be allowed to remain in
place, untreated. Alternatives TP-1 and TP-2 will meet action-
specific ARARs.
Long-Term Effectiveness and Permanence
Alternatives TP-3 and TP-5 are expected to be the most effective in
the long-term, as far as on-site protection of human health and the
environment is concerned. Alternative TP-6 is slightly less effective
than Alternatives TP-3 and TP-5 since it reduces contamination to
ecological risk-based cleanup levels only. This will result in less
residual, untreated wastes than in the case of the other alternatives.
Alternative TP-3 will provide long-term effectiveness through the
removal of contaminated soil from the Site for disposal off-site.
Except for monitoring of wetland establishment, no other controls will
be required for Alternatives TP-3, TP-5 and TP-6. For each of these
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alternatives, there will be uncertainty associated with the
effectiveness of wetland establishment after the area is remediated.
Alternatives TP-2, TP-4 and TP-7 are expected to be less effective in
the long-term because contaminated soil will remain on Site without
treatment. Exposure to contamination will be prevented by
constructing an impermeable cap in Alternatives TP-4 and TP-7. In
Alternative TP-2, human exposure to contaminated soil will be
prevented by constructing a security fence, and by imposing
restrictions such as institutional controls. The existing
sedimentation basin will collect any contaminated sediment that may
migrate in storm flows before surface water leaves the Site. Five
year reviews will be required due to the continued presence of
contamination on Site.
Alternative TP-1 is the least effective in the long-term because
contaminated soil will be allowed to remain on Site without any
engineering and institutional controls to limit exposure. Five year
reviews will be required due to the continued presence of
contamination. The existing sedimentation basin will collect sediment
in storm flows before surface water leaves the Site.
Reduction in Toxicity, Mobility, or Volume
Alternatives TP-5 and TP-6 provide the greatest potential reduction of
toxicity, mobility, or volume through the treatment of the
contaminated soil. Alternative TP-5 will remediate the soil by
thermal treatment. Alternative TP-6 will reduce toxicity of the soil
by soil washing and chemical dechlorination.
Alternatives TP-4 and TP-7 provide a limited reduction in contaminant
mobility by placing an impermeable soil cap over the contaminated
soil. Toxicity and volume will not be reduced.
Alternative TP-3 provides reduction in mobility of the contaminants by
excavation and off-site disposal in a landfill. Toxicity and volume
will not be reduced by this alternative.
Alternatives TP-1 and TP-2 provide no reduction in toxicity, mobility
or volume of the contaminated soil.
Short-term Effectiveness
Alternative TP-1 presents the least short-term risk to human health
and the environment, because it involves no remediation and no
disturbance of existing contamination within the Tar Patch Area.
However, while no increases in risk result in the short-term, remedial
response objectives are not achieved.
Alternative TP-2 can be considered to pose slightly greater short-term
risk than Alternative TP-1 because it involves the construction of a
perimeter fence around the contaminated area. However, the
environmental impacts of constructing the fence at the periphery of
the Tar Patch Area is minimal.
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The remaining alternatives, all of which involve Site remediation,
present greater short-term risks to human health and the environment.
There will be short-term health risks associated with large scale
movement of contaminated soil, except in the case of Alternative TP-7
where there will be less disturbance. Exposure controls such as the
use of personal protective equipment and implementation of dust
control measures will minimize any short-term risks. The existing
sedimentation basin in the Downstream Area will be used to capture
sediment released downstream during construction operations. Off-site
transportation of contaminated soil in Alternative TP-3 will slightly
increase potential short-term exposure risks to the adjacent community
and the environment. The longer time required to implement
Alternatives TP-5 and TP-6 will also increase the short-term risk.
There will also be some short-term impact caused to the existing
ecosystem surrounding the Tar Patch Area, because of remedial
operations in this area.
Implementability
Alternative TP-1 is the most easily implementable of the alternatives
because it requires that no action be taken.
Alternative TP-2 can also be implemented easily because it involves
the construction of a perimeter fence, and the implementation of a
declaration of environmental restriction by the State of New Jersey.
Among the alternatives that involve Site remediation, Alternative TP-7
is easier to implement than the others. The impermeable soil cap will
be placed directly on top of the contaminated soil with minimal
movement of the soil.
Alternative TP-3 is easier to implement than the remaining
alternatives. Excavation of contaminated soil, off-site disposal, and
backfilling with clean fill material to establish wetlands can be done
using common earthmoving machinery and equipment. The existing
sedimentation basin can be used for capturing any sediment migration
field operations.
Alternative TP-4 will be slightly more difficult to implement because
of the longer time required to complete the work. The consolidated
soil will be allowed to settle for a year before the cap is
constructed.
Alternatives TP-5 and TP-6 are the most difficult to implement because
they involve the on-site setup and operation of the treatment
processes. These alternatives also take the longest time to
implement.
Qq ?
Total present worth cost estimates for implementing the alternatives
range from $0 to $34,530,000. Alternative TP-1 does not entail any
cost because it requires that no action be taken. The next least
costly alternative is Alternative TP-2 with a present worth of
$114,700. Alternatives TP-4 and TP-7 with comparable costs are the
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least costly among alternatives that involve active Site remediation.
The present worth cost for Alternative TP-4 is $2,765,000 and the cost
for TP-7 is $2,580,000. Alternatives TP-3 and TP-5 cost $13,975,000
and $29,050,000, respectively, to implement. Alternative TP-6 at a
cost of $34,530,000 is the alternative with the highest cost to
implement.
When capital costs for alternatives are considered, they follow the
same trend as for present worth costs.
SELECTED REMEDY
NJDEP and EPA have determined after reviewing the alternatives and
public comments, that the appropriate remedy for the three areas is as
follows:
(a) Limited Action with Institutional Controls (Alternative W-2) for
the Westerly Wetlands;
(b) Excavation, Off-site Disposal, and Wetland Restoration
(Alternative W-3) for the Northerly Wetlands; and
(c) Excavation, Off-site Disposal, and Wetland Establishment
(Alternative TP-3) for the Tar Patch Area.
Westerly Wetlands
The selected remedy for the Westerly Wetlands is Limited Action with
Institutional Controls. NJDEP and EPA believe that this alternative
is protective of human health by controlling potential exposure to
contamination through the installation of a security fence and, from a
long-term perspective, as a result of the anticipated sediment build-
up from vegetative humification, which is expected to form an
increasing protective barrier over the contaminated soil. Since the
extent of vegetative humification would be considerably much less in
the Northerly Wetlands, the Northerly Wetlands and the Tar Patch Area
would continue to be active contamination sources for the Westerly
Wetlands, unless remediated. Although the selected remedy does not
fully mitigate the ecological risks posed by the Westerly Wetlands
contamination, remediation of the Westerly Wetlands would cause
significant ecological impacts to this area and it is uncertain if
these wetlands could be effectively restored. As a result, the
selected remedy will preserve the existing wetland system and require
monitoring of the area to confirm that conditions do not deteriorate
and the above-described natural protective barrier continues to
develop. Additional security fencing will be installed around the
Westerly Wetlands where fencing has not already been provided.
The capital cost for the selected remedy for the Westerly Wetlands has
been estimated at $76,400. The annual operation and maintenance cost
will be approximately $3,850. The total net present value of the cost
of the selected remedy is $136,000.
The existing wetland system, which has been rated moderate to high in
value, will remain hydrologically functional and continue to provide
habitat, because no intrusive remedial measures will be undertaken
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within this portion of the Site. The natural processes of the wetland
ecosystem, including continued vegetation growth and sediment build-
up, is expected to gradually mitigate the potential for contaminant
migration and the potential for exposure to the contaminated areas for
both ecological and human receptors. In addition, removal of
contaminated soil from Northerly Wetlands and Tar Patch Area, which
are located upstream of the Westerly Wetlands, will also eliminate the
potential for migration of contaminated sediment through surface water
runoff into the Westerly Wetlands.
A sedimentation basin has already been constructed at the most
downstream location within the BFB Site. This basin will collect any
contaminated sediment that may migrate in the near term during storm
flows. Thus, most of the particulate matter in the surface water will
be captured in the sedimentation basin before surface water leaves the
Site. Dissolved contaminants in surface water will be monitored at
the single discharge point beyond the sedimentation basin.
Accumulation of sediment in the sedimentation basin will be monitored
on a regular basis and sediment will be excavated and removed for off-
site disposal at appropriate intervals. Natural sedimentation within
the wetlands over time will also be monitored regularly through the
implementation of a monitoring plan to ensure that the anticipated
natural covering and containment of contamination is occurring.
Monitoring will include biological, surface water and sediment
sampling in the Westerly Wetlands, surface water, sediment and, if
necessary, biological sampling in Burnt Fly Brook, and surface water
and sediment sampling in the sedimentation basin. The monitoring plan
will be developed in consultation with the Biological Technical
Assistance Group (B-TAG) and will be implemented to monitor the
effectiveness of this remedy selected for the Westerly Wetlands.
A Deed Notice will be prepared for filing with the appropriate
authorities to control future use of the Westerly Wetlands area.
Because this remedy will result in contaminants remaining on Site, the
Site will be reviewed every five years in accordance with the
requirements of CERCLA.
Northerly Wetlands
The selected remedy for the Northerly Wetlands is Excavation, Off-site
Disposal and Wetland Restoration, which involves the excavation and
off-site disposal of all contaminated soil present in the Northerly
Wetlands, and the re-establishment of wetlands in the disturbed areas.
Since this area is located immediately upgradient of the Tar Patch
Area and surface water runoff flows from the Northerly Wetlands into
the Tar Patch Area., this remedy will complement the remedy selected
for the Tar Patch Area and prevent any recontamination of the Tar
Patch Area after its remediation. The contamination in the Northerly
Wetlands is spread over a smaller area, approximately 2.5 acres in
extent, within mature forest habitat. When compared to the Westerly
Wetlands, it contains a smaller volume of contaminated soil that is
easily accessible.
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The excavation alternative provides for the maximum protection of
human health and the environment on-site as all contaminated soil will
be excavated and removed off-site. Though the existing wetland areas
will be destroyed during excavation, the extent of the contaminated
Northerly Wetlands is small when compared to the contaminated Westerly
Wetlands, and the wetland can be restored in the disturbed areas after
backfilling with clean loamy soil. Off-site disposal of the
contaminated soil will be done in accordance with RCRA land disposal
requirements, and TSCA and USDOT regulations. Excavating and removing
the contaminated soil off-site will result in a remedy that is
effective in the long-term, and permanent. Mobility of the
contaminants will be reduced by removing the contaminated soil to a
landfill, although toxicity and volume will not be reduced. There
will be minimal short-term risk to the adjacent community and the
environment during the remedial action. The remedial activities are
easily implementable using commonly available earthmoving machinery.
A residential soil cleanup level of 0.49 mg/kg for PCBs and 400 mg/kg
for lead will be used, because the Northerly Wetlands is more easily
accessible to trespassers. In addition, it will allow most of the
contamination to be excavated, thus preventing the further spreading
of PCBs and lead into the Tar Patch Area and the Westerly Wetlands.
Approximately 4,000 cubic yards of contaminated soil will be excavated
and removed, and approximately 2.5 acres of wetlands will be re-
established. The capital cost of the remedial activities in the
Northerly Wetlands has been estimated at $2,583,000. The annual
operation and maintenance cost will be approximately $4,250. The
total net present value of the cost of the selected remedy is
$2,608,000. EPA uses a PCB residential soil cleanup number of 1.0
mg/kg instead of the NJDEP number of 0.49 mg/kg. The difference
between the two volumes generated from these cleanup levels is
estimated to be 50 cubic yards, resulting in an implementation cost
difference of $21,100 for the Northerly Wetlands which will be borne
by NJDEP.
The newly created wetlands will be monitored for at least seven years
to ensure proper restoration of wetlands. The Deed Notice will be
extended to cover this area in order to preserve the wetland ecosystem
that will be restored.
Tar Patch Area
The selected remedy for the Tar Patch Area is Excavation, Off-site
Disposal, and Wetland Establishment, which involves the excavation and
off-site disposal of contaminated soil present in the Tar Patch Area,
and the establishment of wetlands in this area. For the Tar Patch
Area, the cleanup goal is based on visual contamination instead of an
actual cleanup level. However, the excavation in this area should
also meet the residential soil cleanup goal as described for the
Northerly Wetlands. The visual goal was chosen because the
contaminated area is clearly defined due to its lack of vegetation.
If an exact number was specified for the Tar Patch Area, it would
include vegetated portions of the Westerly Wetlands Area. By removing
this area, a continuing source of contamination to the Westerly
Wetlands can be removed without destroying heavily vegetated wetland
areas. In addition, excavation of the Tar Patch Area would also
-------
37
mitigate the migration of contaminants into the Westerly Wetlands due
to ground-water movement and surface water runoff.
Approximately 29,000 cubic yards of visibly contaminated soil from the
unvegetated portion of the Tar Patch Area, which is approximately 4
acres in extent, will be excavated. Excavated soil will be disposed
of off-site in accordance with TSCA, RCRA and USDOT regulations.
Excavated areas will be backfilled with clean loamy soil that is
capable of sustaining wetland vegetation. Wetlands will be created in
the area, which is now devoid of any vegetation, and in any wetland
areas affected by the remedial activities. The newly created wetlands
will be monitored for at least seven years to ensure proper
restoration of wetlands. The Deed Notice will be extended to cover
this area in order to preserve the wetland ecosystem that will be
restored.
The capital cost for the selected remedy for the Tar Patch Area has
been estimated at $13,965,000. The annual operation and maintenance
cost will be approximately $1,100. The total net present value of the
cost of the selected remedy is $13,975,000. Because the cleanup goal
is based on visual contamination in the Tar Patch Area instead of
actual cleanup numbers, a cost differential was not determined.
Excavation and removal of the contaminated soil is preferred over
capping in place, because of the unstable nature of the contaminated
material present in the Tar Patch Area under extreme temperature
conditions, and consideration for long-term maintenance costs.
Summary
The selected remedy for the remaining areas of concern at the BFB Site
is consistent with the remedy that was chosen in the past for the
Uplands Area, and the more recent provision of the sedimentation basin
as an interim remedy. Access controls that are already in place for
the Uplands Area and the Downstream Area will be extended to cover the
Westerly Wetlands, the Tar Patch Area, and the Northerly Wetlands.
The overall remedy provides the most cost-effective approach to
restore a contiguous wetland ecosystem with only limited, low cost,
long-term maintenance requirements. The selected remedial action is
protective of human health and the environment to the extent
practicable, limits disturbance and destruction of large areas of
valuable wetland habitat, and, hence, minimizes the potential for
migration of contaminants downstream. No additional response actions
are contemplated at the Burnt Fly Bog Site at this time.
STATE ACCEPTANCE
The New Jersey Department of Environmental Protection supports the
selected remedy presented in this Record of Decision for the Westerly
Wetlands, Northerly Wetlands, and Tar Patch Area. The State agrees to
fund all additional costs incurred during remedial action due to the
application of NJDEP's more stringent PCB residential cleanup
criteria. The State does not waive its rights to challenge this
later.
-------
38
COMMUNITY ACCEPTANCE
Community acceptance was evaluated after the close of the public
comment period. Written comments received during the public comment
period, as well as verbal comments during the public meeting were
evaluated.
The majority of comments received during the public comment period
originated from the MCEC and PRPS. While supporting the selected
remedy for the Northerly Wetlands and the Tar Patch Area, the
Coalition has urged that removal of contaminated sediment from any
"Hot Spots" within the Westerly Wetlands be considered, particularly
adjoining the Tar Patch Area. The PRPs, while being supportive of the
remedy for the Westerly Wetlands, are opposed to the remedy chosen for
the Northerly Wetlands and the Tar Patch Area. They recommend that a
limited action alternative similar to the one proposed for the
Westerly Wetlands be considered for the Northerly Wetlands and the Tar
Patch Area.
The county health officers and many others present at the public
meeting were supportive of the selected remedy.
STATUTORY DETERMINATIONS
The selected remedy satisfies the statutory requirements of section
121 of CERCLA, which mandates that a remedial action be protective of
human health and the environment, cost effective, and utilize
permanent solutions and alternative treatment technologies to the
maximum extent practicable. Section 121 also establishes a preference
for remedial actions which employ treatment to permanently and
significantly reduce the volume, toxicity, and mobility of the
hazardous substances, pollutants, or contaminants at a Site. CERCLA
further specifies that a remedial action must attain a degree of
cleanup that satisfies ARARs under federal and state laws, unless a
waiver can be justified pursuant to CERCLA section 121(d) (4).
For the reasons discussed below, NJDEP and EPA have determined that
the selected remedy meets the requirements of Section 121 of CERCLA.
Protection of Human Health and the Environment
The selected remedy for Site soils is protective of human health and
the environment, since it involves the excavation and off-site
disposal of contaminated soils from the Tar Patch Area and the
Northerly Wetlands and, due to conditions which are favorable for
vegetative humification and sediment build-up, allows for the
development and monitoring of a natural protective cover for the
contamination in the Westerly Wetlands while preserving the ecological
integrity of the wetland system. Once the contaminated soil is
removed from the Northerly Wetlands and Tar Patch Area, wetlands will
be established in the excavated areas which will result in the
formation of contiguous wetlands from the Westerly Wetlands through
the Northerly Wetlands. Institutional controls such as Deed Notices
and engineering controls such as a perimeter fence and the
-------
39
sedimentation basin will also contribute to the mitigation of human
risk related to any exposure to remaining contaminants.
With the appropriate engineering controls, the excavation and removal
of soil from the Tar Patch Area and Northerly Wetlands will not create
unacceptable short-term risks or cross-media impacts.
Compliance with ARARs
Since most of the Site is classified as wetlands, the selected remedy
must comply with the NJ Freshwater Wetlands Protection Act Rules,
Section 404 of the Federal Clean Water Act and Executive Order 11990
which require that actions be taken to minimize the destruction, loss
or degradation of wetlands and to preserve and enhance the natural and
beneficial values of wetlands. Any actions which disturb or impact
wetlands would additionally require development of a wetlands
mitigation plan. Since the contaminated soils in the Northerly
Wetlands and Tar Patch Area will be excavated and disposed of off-
site, the selected soil remedy would meet chemical-specific, location
specific and action-specific Federal and State ARARs and TBCs for the
contaminated soils. Although the remedial alternative for the
Westerly Wetlands will not meet chemical-specific ARARs and TBCs, it
does provide adequate level of protection of human health and the
environment while limiting the disturbance and destruction of large
areas of valuable wetland habitat.
Cost-effectiveness
Of the alternatives which most effectively address the threats posed
by Site contamination, the selected remedy is cost-effective as it has
been determined to provide the greatest overall effectiveness in
proportion to its cost. The selected remedy results in a net present
value of the estimated total project cost for all three areas of
$16,719,000.
Utilization of Permanent Solutions and Alternative Treatment
Technologies to the Maximum Extent Practicable
The selected remedy represents the maximum extent to which permanent
solutions and alternative treatment technologies can be utilized in a
cost-effective manner for the BFB Site. Excavation and Removal of
contaminated soil from the Northerly Wetlands and Tar Patch Area will
offer a permanent solution to the risks posed contaminated soils in
these two areas. The sedimentation basin that has already been
constructed upstream of Burnt Fly Brook will collect sediment leaving
the Westerly Wetlands during runoff and storm flows, thus reducing
potential migration of contaminants into downstream surface water
bodies. As a result of the implementation of the monitoring program
to be developed in accordance with this ROD, monitoring data will be
obtained to determine the effectiveness of the remedy selected for the
Westerly Wetlands. The sediment collected in the basin will be
removed off-site for disposal at regular intervals. In summary, the
selected remedy provides the best balance of tradeoffs with respect to
the nine evaluation criteria.
-------
40
Preference for Treatment as a Principal Element
The selected remedy will not satisfy the statutory preference for
treatment as a principal element because treatment of the principal
threats of the Site was not practicable.
Treatability studies performed on contaminated soil from the Site
using soil washing and chemical dechlorination technologies showed
that contaminant levels could not be reduced to human health based
cleanup levels. It was also found that the treated material was
unsuitable for creating wetlands on Site.
The remedy provides for excavation and off-site disposal of
contaminated soil from the Northerly Wetlands and Tar Patch Area, in
accordance with RCRA and TSCA regulations. Based on the available
data, EPA and NJDEP do not anticipate treatment of the contaminated
soil prior to off-site landfill disposal. However, if the need for
treatment arises during the remedial action, based on the nature and
PCB-concentration of the material generated, such treatment will be
performed prior to landfill disposal.
DOCUMENTATION OF SIGNIFICANT CHANGES
The Proposed Plan for the Site was released to the public on February
2, 1998. The Proposed Plan identified the preferred alternatives for
the Westerly Wetlands, Northerly wetlands, and the Tar Patch Area.
NJDEP and EPA reviewed all written and verbal comments received during
the 90-day public comment period. Upon review of these comments,
NJDEP and EPA determined that no significant changes to the selected
remedy, as originally identified in the Proposed Plan, were necessary.
-------
APPENDIX I
FIGURES
Figure No. litis
1 Regional Site Location Map
2 Site Location Map
3. Site Map
-------
I
j/'nEW YORK
• MARLBORO
PENNSYLVANIA
NEW
Y
REGIONAL SITE LOCATION
Figure 1
-------
mi m
C y ' - ~ V *T
V ^
' '^'^0^-2^7' c>^r_ ? i£*t -.r.-
Vckp^
,-/^^r^-Jy/i'
e^sH;T1 kl
K
Study
/
/
S""..ri T«cnno«09v Propc' Se OC'Ci^t-IOCfi
SCAit
:ooo Fl
Figjre 2
Site Location Map
NORTH
-------
Htfnl Fly flog Sito
MnrmuuV* HI
Wm
Ooi
vj
tCfrr
c,
W««i«Kr W.ii
/
graphic v *i r
u ><>o
-------
APPENDIX II
Tables
Table No. Title
1. Maximumm and Average Lead and PCB Concentrations in Soil
2. Areas and Volumes of Contaminated Soil
3. Estimate of Costs for Selected Remedy
-------
TABLE 1
MAXIMUM AND AVERAGE LEAD AND PCB CONCENTRATIONS IN SOIL
AT BURNT FLY BOG
Lead (mg'kg)
PCB (
Eg/kfc) j
ARIA
M irimnm
Average
Marimnm
A%erage II
:
Tax Pat:h Area
53,000
2.2C3
1,060
8 6 f;
Northerly U'erlaads
3J,300
8.168
! 150
"8 * i:
ji
! Wcsicrlv Wetlands
i
31.000
j 254
51 9 a
Kois
njlig - ciU:gra=i per kilograms
(From Ecolcp^a] Rjsk Asstssce:!;. BCM 1993)
ScLirce BCM E:pk:s lie (ECM PrcjKt Nc 0C-:.1 16-:?:^
-------
Table 2
Areas and Volumes of Contaminated Soil
Burnt flv Bos Siie
! Item
! Westerly Wetlands
| Northerly Wetlands i
Tar Patch Ajea ,
j Area
i 21 acres
1 2 5 acres j
5 5 acres
j Volume
7?.300 cu yd
j 4,000 cu yd
29.600 cu yd
Source Burnt Fly Bcu Site Supplemental Feasibilit\ Stud\ Report - October
1997
These volumes are approximated based on a soil cleanup level of 0.49 ng/kg
for PCBs.
-------
Table 3
Estimated Costs for Selected Remedy
Burnt flv Bog Site
Sub-site !
Capital Cost
1 Annual O&M Cost
Present Wonh Cost I
Westerly Wetlands i
576.400
i S3.S50
SI 36.000 :
Northerly Wetlands .
S2.5S3.000
S4.250
s:. 60s.ooo !
Tar Patch Area
SI 3.96x000
S 1.100
SI3.975.000
Note
Source Burnt Fl\ Bou Sue Supplemental Feasibility Sturf\ Report - October
1007
-------
Total Risk Summary Tables
-------
total risk summary
FROM THE WESTERLY WETLANDS
USE: CURRENT /FUTURE TRESPASSER
BURNT FLY BOG
MONMOUTH AND MIDDLESEX COUNTIES, NEW JERSEY
CARCINOGENIC RISK
RME
AVERAGE
SURFACE SOIL AND SEDIMENT • INGESTION
SURFACE SOIL AND SEDIMENT • DERMAL
SURFACE SOIL - INHALATION ,
SURFACE WATER • DERMAL
BLUEBERRIES • INGESTION
4.37E-04
1.04E-03
1.52E-06
•
1 21E-05
8.01E-05
1 90E-04
3 61E-07
•
8 55E-06
TOTAL:
1.49E-03
2.79E-04
NONCARCINOGENIC RISK
- ADULT
¦
RME
AVERAGE
SURFACE SOIL AND SEDIMENT • INGESTION
SURFACE SOIL - INHALATION
SURFACE WATER • DERMAL
BLUEBERRIES - INGESTION
7.85E-04
•
2.70E-04
2 49E-02
1 02E-04
•
1.01E-04
1 41E-02
TOTAL:
2.59E-02
1.43E-02
NONCARCINOGENIC RISK
- CHILD
RME
AVERAGE
SURFACE SOIL AND SEDIMENT • INGESTION
SURFACE SOIL - INHALATION
SURFACE WATER • DERMAL
BLUEBERRIES • INGESTION
7.33E-03
•
9.62E-04
1.16E-01
9.52E-04
•
2.14E-04
6 5
-------
BCM
Table 2
TOTAL RISK SUMMARY
FROM THE NORTHERN AREA
USE CURRENT TRESPASSER
BURNT FLY BOG
MONMOUTH AND MIDDLESEX COUNTIES. NEW JERSEY
CARCINOGENIC RISK
CURRENT TRESPASSER
SURFACE SOCL and SEDIMENT • INGESTION
SURFACE SOIL .AND SEDIMENT- DERMAL
SURFACE SOIL - INHALATION
RME
3 32E-04
7.40E-04
1 15E-06
AVERAGE
4 5 j E-0 5
6 23E-C5
1 46E-0"
TOTAL:
1.07E-03
1 CSE-04
NONCARCINOGEMC RISK -
ADULT
RME
AVERAGE
SURFACE SOIL AND SEDIMENT - INGESTION
SURFACE SOD- AND SEDIMENT- DERMAL
SURFACE SOIL - INHALATION
3 8SE-03
9 78E-04
L 1TE-05
1 89E-03
2 4SE-04
8 40E-06
TOTAL:
4.87E-03
2 15E-03
NONCARCINOGENIC RISK -
CHILD
RME
AVERAGE
SURFACE SOIL AND SEDIMENT - INGESTION
SURFACE SOIL AND SEDIMENT- DERMAL
SURFACE SOIL - INHALATION
3.62E-02
2.07E-03
4.81E05
L.77E-02
5.25E-04
3 42E-05
TOTAL:
3.83E-02
1.S2E-02
Nates:
**The only COPC for the specified route of exposure is lead for which toxicity
RME * Reasonable Maximum Exposure.
values are not available.
BCM Project No.: 00-0516-0902
-------
BCM
Table 3
total risk summary
FROM THE NORTHERN AREA
USE: FUTURE RESIDENT
BURNT FLY BOG
MONMOUTH AND MIDDLESEX COUNTIES, NEW JERSEY
CARCINOGENIC RISK
RME
FUTURE RESIDENT
SURFACE SOIL AND SEDIMENT - INGESTION 2.32E-03
SURFACE SOIL AND SEDIMENT • DERMAL 5 18E-03
GROUNDWATER - INGESTION , •
GROUND WATER . DERMAL •
AVERAGE
3.17E-04
2.R7E-04
•
•
TOTAL: 7 50E-O3
6 04E-G4
NONCARCINOGEN1C RISK - ADULT
RME
A^'ERAGE
SURFACE SOIL AND SEDIMENT - INGESTION 2.71E-02
SURFACE SOIL AND SEDIMENT - DERMAL * 6 85E-C3
GROUNDWATER - INGESTION •
GROUND WATER - DERMAL
1.32E-02
1 "4E-03
•
¦
TOTAL: 3.40E-02
1.50E-02
NONCARCINOGENIC RISK - CffiLD
RME
AVERAGE
SURFACE SOIL AND SEDIMENT - INGESTION 2.53E-01
SURFACE SOIL AND SEDIMENT - DERMAL ] .43E-02
GROUNDWATER • INGESTION
GROUNDWATER - DERMAL
1.24E-01
3 67E-03
*
•
TOTAL: 2 68E-01
1 27E-01
Notes
"¦The crJy COPC for the specified route of exposure is lead for which toxicity values are not available
RME " Reasonable Maximum Exposure.
BCM Project No 00-0516-0902
-------
Table 4
Compounds of Potential Concern
Westerly
Westerly
Westerly
Westerly
Northern Area
Burnt Fly
Burnt Fly
Wetlands
Wetlands
Wetlands
Wetlands
Soil/Sediment
Brook Sediment
Brook Surface
Soil/Sediment
Surface Water
Blueberries
Groundwater
Water
lead
lead
aluminum
lead
cadmium
lead
lead
copper
mercury
areenlc
copper
zinc
zinc
barium
lead
PCB«
beryMum
zinc
elhylbenzene
chromium
PCB
toluene
lead
ethyfbenzene
xylene
star
methylene chloride
2,4-dfenethyl phenol
vanadium
toluene
4-methyl phenol
zinc
phenol
akjrin
methoxychlor
benzo{a|anlhracene
benzo(a|pyren0
benzo(b|fluoranlhene
benzofg.h.llperytene
benzo(k]fluoranthene
Ms|2-ethyttexyt1 phthalale
chrysene
fluoranthene
naphthalene
phenanthrene
phenol
pyrene
-------
T;i b 1 <-• S
DAI A SUMMARY TAMl.t
WESTERLY WK11.ANI) SURFACE SOU. AND SEDIMENT
IUIRNT FI.Y DOO
MONMOUTH AND MIDDLESEX COUNTIES. NEW JERSEY
DETECTED COMPOUND NUMBER NUMBER FREQUENCY MAXIMUM MINIMUM
OF OF OF CONC CONC
HITS SAMPLES DETECTION
(S) (H/S) g/kg) (mg/kg) (mg/Vg) (n>g/tg) (n>g/Vg) AKAKi
Sarfacr Soli and SrdlmrM
Inofganirt
Copper
lr«d
Zinc
PlTh
Volatile OfKinid
I Ihylhrn/rnc
1 olurnf
loUl Xylrnrt
Hue Nrulial/And ErtiarUblri
2.4 Dmcthylphcnol
4 Mrlhylphrnol
rtx-iK.1
10
97
11
70
12
97
12
91
12
12
12
12
12
12
l)%
100%
92%
71%
17%
«%
17%
1%
t%
1%
96
)l000
290
254
021
0 0)2
0 II
I 9
I I
0 89
4 1
)
5 4
0 1)
00)1
00)2
0 I)
I 9
I I
0 19
96
17060 )2
290
254
021
0 0)2
0 31
I 9
I I
0 19
12)
12)1 2)
4) 12
46 54
0 046
0 00)1
0 057
0 19
0 112
0 106
I
0 5 10
02
001) 2
0 005 • 0 075
0005
0 005 0 07)
0 07
0 07
0 07
250
600
600
1500
1000
1000
1000
10000
10000
10000
0
0
0
49/56
0
0
0
0
0
0
Surfarr Soli
InoiganKf
I «iil
PCHi
71
52
71
71
100%
73%
)I000
254
5
0 1)
11000 1418 10
254 60 28
0 5-2
005 5
250
5
600
2
0
*0/45
Noic\
* / * Nuinbri «Jinn i|K-cifii tTilrna / raimbri exrrding olhcl AKAR
AHAK Applicable « Krkvanl and Appi nprialr KrquiirnKnb
KMI He aiooaltk Maximum I xpmurr dc lnminf d loi ('«»ni|M>unj>ri i unfHkfKe liiml
I llif alillunatic tnran (< 19K /) Ihc MJviinum I it rlilmml | cpticuit (< iill*if. 19ft7). in III? iti^Hiiniiin i tnu ruli ahtxi
IK M li..,cl N" (10 0516 0902
-------
Table 6
DATA SUMMARY TAJU.F.
NORTHERN ARKA SURFACE SOIL AND SEDIMENT
IHJRNT H.V HOG
MONMOUTH ANI) MIDDLESEX COUNTIES, NEW JERSEY
1)1 irCTKDCOKirOUNDS
NliMHF.R
NUMDER
FREQUENCY
MAXIMUM
MINIMUM
RME
average
NON-DETECT
ARAB
ARAR
NUMItl H <>l
OF
OF
OF
CONC
CONC
CONC
CONC
VA1.UE OR
(SITE SPECIFIC)
(Nl
SAMri I S
HITS
SAMPLES
DETECTION
RANGE
RtSIDLN HAL)
F.XCLLI)IN(»
(»)
(S)
2
Mf
2
1
25%
II
17
II
17 5*
o
o
0 66
2
!Wn/o
-------
Ttib 1 e 6 (Cont. )
data summary T/vnu
NOR rill.RN ART A SURFACE SOIL AND StDIMINT
IIURNT ILY DOG
MONMOUTH ANL> MIDDLESEX COUNTIES. NEW JERSEY
DETECTED COMPOUNDS NUMUER NUMUER FREQUENCY MAXIMUM MINIMUM RME AVERAGE NON-DETF.CT ARAR ARAR NUMIIER Ot
OF OF OF CONC CONC CONC CONC VALUF.OR (SITE SPECIFIC) (NJ SAMPLES
HITS SAMPLES DETECTION RANGE RESIDFNIIAI.) EXCEEDING
(II) (S) (ll/S) (n>g/kg) (kiie
2
5
40%
in
17
II
17 5*
70 120
0 66
2
lktLfo(k )fluu< anlhcnc
2
5
40%
10
61
10
« 4*
70 - 120
09
2
-------
Tahlf 6 (Cont.)
DATA SUMMARY TAIII.E
NORTHERN AREASURI ACKSOII. ANDSI DIMKNT
BURNT FLY I>OG
MONMOUTH AND MIDDLESEX COIJNTIES. NEW JERSEY
DETECTED COMPOUNDS NUMflER NIJMHER FREQtlKNCY MAXIMUM MINIMUM RME AVERAGE NON DETECT AKAR ARAR NUMIII R OF
OF OF OF CONC CONC CONC CONC VALUE OR (SI TE SPECH If) (NJ SAMI'l IS
HITS SAMPLES DETECTION RANGE RESIDENTIAL) I XCII DING
(II) (S) (ll/S) (mgftg) (mg^g) (mgflig) (mgAg) (mg/*g) ("ngAg) (mftflig) ARARi
IUk Nfulial/Acn) NrKlabkt (conl'd)
lin(2 rlh)-l)lKX>-lphlhiUlc )
5 100%
51
12
11
21 60
61
49
1
OirywiK 2
5 40%
20
46
20
12 }•
110-120
9
1
MimanlhriK 2
1 40%
II
17
It
17 !•
70 120
2100
0
NlpMlialeiic 2
1 40%
7}
6)
69 1
17 2*
70 120
210
0
riKiumlircitc 2
1 40%
11
11
11
49 !•
70- 120
NA
Pvicik )
1 60%
12
5 2
12
2164*
110 120
1700
0
Notei
n / v - Number exceeding site specific criteria / mimbei exeeding oilier ARAR
AHARt Applicable of Relevant ind Apfttfnilc Requirement*
NA~ No data available
KMI Reasonable Maximum I'xpoMire determined for Compounds of Potential Concern t"*ng either (he 95% upper confidence limit
ol (he atdlimjlK mean (Gilbert, 1987). the Maximum Likelihood Exposure (Ciilberl. 1987). or the maximum concentration
* Ofiedion limits Much exceeded the maximum deletted concentration were removed for the calculation of the average
IU M rin(eit No 00 0M 6 0902
-------
BCM
' Table 7
TOXICITY ASSESSMENT SUMMARY TABLE • NONCaRCINOGENS
CHEMICAL
CHRONIC R/D
(mglig'day)
R/D BASIS
(species; exposure)
CRITICAL EFFECT
CONFIDENCE
LEVEL'
LT AND MF ¦
0 SAL £.\?OSL"R£
AJdnn
3.0E-05
(1)
rat, diet
liver toxicity
medVF-1,000. MF-1
Arsenic
3 0E-04
(1)
human, d water
skin charges
med/UF-3. MF-I
Ajummum
2 9E-00
(5)
not known
not known
not known
Bin urn
7.0E-02
(1)
human, i water
increased blood pressure
VF-3.000. MF-I
Beryllium
J.OE-03
(1)
rat. drinking water
no effects observed
low/LT-100. MF«1
Bis U-e'Jiy'iiexyl) phlhalate
2.0E-02
(1)
guinea pi{-. diet
increased liver weight
med'LT-LOCO. MF"1
Cadmium
I.OE-03
(1)
human: chronic
kidney toxicity
higlvLT-10, MF-I
Chromium
J OE-03
(3)
rat. drinking water
no effects observed
low/LT-JOO. MF» 1
Copper
3 71E-02
(4)
human; NA
g.i. tract irritation
NA "
2.4-Dunethyl phenol
2.0E-02
(1)
mouse, gavage
cIuucal/hemaL changes
low/VF"3,000, MF-1
Ethylbenzene
I.OE-Ol
(1)
rat, lavage
liver and kidney toxicity
low/UF¦ 1.000, MF" 1
Fluoranthene
4.0E-02
(1)
mouse; givagt
nephrolax.heriuJ. et al
low/UF-3.000, MF-1
Mercury
3 OE-04
(2)
rat; oral
kidney toxicity
UF-1.000
Methoxychlor
5 0E-03
(1)
rabbit; pvage
reproductive toxicity
CF-1000. MF-1
Methylene ehlonde
i 0E-02
(1)
rat, drinking water
liver toxicity
med/LT-100, MF-1
4-Milhyl phenol
5 OE-03
(2)
rat. lavage
resp diJUeD, cyanosis, death
LT-1.000
Naphihaleoe
4 0E-02
(2)
rat, lavage
low body weight gain
LT-10,000
Phenol
6.0E-0I
(1)
rat, gavage
fetotoxicity
lowAT-100. MF-1
Pyrene
3.0E-O2 .
(1)
mouse, gavage
kidney loxiciry
UF-3000, MF- I
Slider
5.OE-03
(1)
human; iv
skin, argyria
LT-3, MF - t
Toluene
2.0E-01
(1)
rat, gavage
liver/Vjdney wt change
med/VF-1,000. MF-1
Vanadium
7 OE-03
(2)
rat, drinking water
no effect observed
LT-100
Xylenes
2 0E-K50
(1)
rat; gavage
hyperactivity, low b w
medVF-100.MF-1
Zinc
3 0E-O1
(1)
human; diet supplement!
decreased ESOD (6)
UF-10
' LT - Uocenamry Fictor, MF- Modifying Factor, N'A«not applicable. Confidence Levels - fcjgh. medium (med), or low.
0) :rjs
(2) HEAST
(3) Orai RJD for Hexavalent Chromium
(*) The Oil RFD for Copper is extrapolated from i drinking water nandard(l 3 tng/1) suggested in HEAST
(!) EPA-tCAO (cited li Region II! Risk-Based Concentration Table. Fourth Quarter 1993)
(6) ESOD » erythrocyte superoxide dismuUse concentration
O) C»;cul»ied from j\halmon reference concentrations (WCs) cned ta IRIS of HE AST
(8) Inhalation R/C wiihdnwn from HEAST
-------
bcm
Table 8
toxic mr .assessment s*jmmaay table • c
Anenjc
A (I)
I 75E-O0
(3)
huaun. dnnlupg wwr
Beryllium
b: (i)
4 3E-00
(1)
rat drinking w
tauJ tumen (> ;
3enzo|a]inthrieene
B2 (I)
730E-OI
(«)
NA
NA
3*ruo(t]3 uorwithene
b: (i)
7 30E-01
(4)
NA
N A
Btruofkjfl uonr'-hene
b: (d
7.30E-02
NA
na ;
8rozo[a)pyr«n(
82 (1)
7 30E-O0
(!)
mouse. diet
r.omash
Bis CI-c-JiyLhexyl) phlhalate
B2 (1)
ME-02
(1)
mouu. diet
Ijtt
Chrysene
B2 (1)
7 30E-O3
(<»)
NA
S A
Methylene chloride
B2 (1)
7.3E-03
(1)
mouse, i waler'mhal
jvn*
PolychJonr.aied btphrnyli
B2 (1)
7.7E^30
(I)
rat. diet
l:ver
INHALATION EXPOSURE
Cadruum
B1 (1)
6.JE-MJ0
(1)
human, inhalation
lunj. tncht*
Ben2o[a)arUir»c«ne
B2 (1)
6.1E-0I
(*)
NA
NA
Benzo| a jpyrenc
B2 (1)
6.1E-00
(3)
hamfier, wh*laUon
reipxitory L-aj
B«(uorb]f1uoraclhen<
B2 (1)
6.1E-01
(<)
NA
Na
BcruofVjCuorvilhcTie
B2 (1)
6 1E-C2
(«)
NA
na
Ctvyter.e
B2 (I)
6.1E-03
(«)
NA
NA
•NA»no( applicable
(i; :*js
C; KEaST
O; Vtcnjc slsp* factor salculaud from propoMd unit rule of JE-OJ 1 (u^'1) ciixd ld 'JUS
i J C ted J EPA Report U1 Rjik-Battd Conoenntton Table. Fourth Quarter 1993
("TET approach w PaH eirnno jemmy. m «>a Section <)
:.1, •J-.iiriwp. irsm HE AST
-------
APPENDIX IV
Administrative Record Index
-------
BURNT FLY BOG SUPERFUND SITE
ADMINISTRATIVE RECORD FOR OPERABLE UNIT 3
1. Record of Decision, Burnt Fly Bog - 1983
2. Westerly Wetland Remedial Investigation Final Report, Burnt Fly Bog Site -
January 1988
3. Westerly Wetland Ultimate Remedy Feasibility Study Final Report, Burnt Fly
Bog Site - January 1988
4. Westerly Wetland Lead Mobility Studies Final Report, Burnt Fly Bog Site -
February 1988
5. westerly wetland Water Budget Final Report, Burnt Fly Bog Site - February
1988
6. Record of Decision, Burnt Fly Bog, Westerly Wetlands - September 1988
7. Ecological Assessment Final Report, Burnt Fly Bog - June 1992
8. Final Field Sampling and Testing Results Report - Tar Patch Area - Kay
1994
9. Final Design Report, Burnt Fly Bog Sedimentation Pond Design - September
1994
10. Background Investigation Report, Burnt Fly Bog - March 1994
11. Health and Safety Plan for Burnt Fly Bog Westerly Wetlands - September
1993
12. Public Health Evaluation for the Supplemental Feasibility Study of Burnt
Fly Bog - May 1994
13. Burnt Fly Bog Wetland Delineation Report - May 1994
14. Functional Assessment Report for the Supplemental Feasibility Study of
Burnt Fly Bog - February 1994
15. Environmental Risk Assessment for the Supplemental Feasibility Study of
Burnt Fly Bog - March 1994
16. Burnt Fly Bog Superfund Site Treatability Study Final Report - April 1997
17. Burnt Fly Bog Wetlands Restoration and Environmental Evaluation Study -
June 1997
18. Final Supplemental Feasibility Study Report for Burnt Fly Bog Site -
October 1S97
Page 1 of 2
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19. Site Review and Update, Burnt Fly Bog (US Department of Health and Hur.an
Services, ATSDR) - December 4, 1997
20. Northerly Wetlands Field Sampling Report, Burnt Fly Bog Superfund Site
Supplemental Feasibility Study - January 1997
21. Westerly WetlandB Field Sampling Report, Burnt Fly Bog Superfund Site,
Supplemental Feasibility Study - September 1997
22. Superfund Proposed Plan, Burnt Fly Bog Site - February 1998
22. Community Relations Plan - Update for Remedial Actions at the Burnt Fly
Bog Superfund Site, Marlboro Township, Monmouth County, June 1996
24. Notice of public availability of the Proposed Plan dated February 1998
25. Transcript of the Public Meeting held on February 19, 1998 in Marlboro
September 9. 1998
Page 2 of 2
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APPENDIX V
NJDBP1 a Letter of Concurrence
-------
SLVT BY'SITE REMED1 AT!ON
Clirisiine Todd Whitman
Covernor
9-28-98
: 55PM
FAX s 632 2360-
JSlat* of ^j«ra
Deparimert of Environmcnta! JJrot«ctiOr\
1 212 do > 40o0 • * 0' "t
<'Vicrc C Shiun, h
Com tnjfii toner
Ms. Jeanne M. Fox
Regional "Ad nti n!$! ritor
U.S. EPA-Region n
290 Broadway
New York, NY 10007-1866
Subject: Burnt Fly Bog Superfnnd Site
Record of Decision (ROD) - Operable Unit 3
Dear Ms. Fox:
The New Jersey Department of Environmental Protection (NJDEP) has evaluated and
concurs with the components of ihe selected remedy &j described below for the Bumi Fly
Bog Superfund Site. The selected remedy corresponds to the third operable unit for the
Site, which is located in Marlboro Township, Monmouth County, New Jersey
The major components of the selected remedy include:
1 Excavation and off-site disposal of contaminated soil from the Northerly Wetlands;
2. Excavation and off-site disposal of contaminated soil from the Tar Patch Area;
3. Backfilling the excavated area in the Northerly Wetlands and re-establishing
wetlands;
4. Backfilling the excavated area in the Tar Patch Area and creating wetlands;
5. Provision of additional security fencing around the Westerly Wetlands, and the
recording of Deed Notices for the Wf.flwly Wetland*, Nnrthwly W*f1anH«, and Tar
Patch Area;
6. Monitoring of surface water and sediment in the Westerly Wetlands, surface water
ind tedimant in th« Minting oodimontation baain loootod in tho Douwatoaam Area,
and surface water, sediment and, if necessary, biota in Burnt Fly Brook; and
7. Biological sampling in the Westerly Wetlands.
NJDEP concurs that the selected remedy is protective of human health and the
environment, complies wilh requirement* that are legally applicable or relevant and
appropriate for the remedial action, and is cost effective. Although the State disagrees
with the PCB cleanup number selected by EPA, we still concur with the remedy since it
does not affect the selected cleanup methods.
ccp ? fl 1MB ..
WU1 - V • -
jrw/ ¦> /in Lqut! Upporiu/iuv fmpfoj ir
Huyclti Pij.>n
-------
SENT BY SITE REMEDIATION ; 9-28-38 : 1:55PM : FAX s SC9 533 2350- I 212 537 4393:? 4/ 4
The State of New Jersey appreciates the opportunity afforded to participate in the
Superfund process
Sincerely,
chard Gwntno !
Assistant dcmmissior
Site Remediation Pregram
2
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APPENDIX VI
Raeponsiveness Summary
-------
Responsiveness Summary
Burnt Fly Bog Superfund Site
This responsiveness summary is divided into the following sections:
A. Overview
B. Background on Community Involvement
C. Summary of Comments received during the Public Comment Period and NJDEP
responses.
— Part I: Summary and responses to community concerns voiced at the
February 19, 1998 public meeting
-- Part II: Summary and responses to written concerns received during the
public comment period
A. Overview
This is a summary of the comments and questions from the public regarding the Proposed
Plan, dated February 1998, for remediation of the Burnt Fly Bog (BFB) Superfund Site,
and the New Jersey Department of Environmental Protection's (NJDEP) and U.S.
Environmental Protection Agency's (USEPA) responses to those comments and
questions.
A public comment period was held from February 4, 1998 through May 4, 1998 to
provide interested parties the opportunity to comment on the Proposed Plan for the BFB
Site. During the comment period, NJDEP held a public meeting on February 19, 1998 at
7:00 PM at the Marlboro Municipal Building to discuss results of the Remedial
Investigation and Supplemental Feasibility Study (RI/SFS) reports, and to present the
NJDEP/USEPA preferred alternative for remediation of the Site.
The preferred remedial alternative addresses three remaining unremediated areas of the
Site under Operable Unit 3. The remedy as such is the preferred remedy for the Westerly
Wetlands, Northerly Wetlands and Tar Patch Area at the BFB Site. The remedial
alternatives that were evaluated and presented in the Proposed Plan were developed for
remediation of the Site in accordance with the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA), as amended, and the National Oil
and Hazardous Substances Pollution Contingency Plan (NCP). Specifically, the preferred
alternative includes 1) limited action and institutional controls for the Westerly Wetlands;
2) excavation with off-site disposal and wetlands restoration for the Northerly Wetlands;
and 3) excavation with off-site disposal and wetlands establishment for the Tar Patch
Area.
1
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B. Background on Community Involvement and Concerns
The Burnt Fly Bog has consistently received attention from area residents, municipal,
state, county and federal officials as well as the media. In 1981, concerned residents
organized the Burnt Fly Bog Citizens Advisory Committee (BFBCAC). The Committee
includes citizen representatives from Marlboro and Old Bridge Townships as well as
officials from Monmouth and Middlesex Counties. NJDEP representatives have met
regularly with this group since 1981 and continue to do so. In 1998, a group known as
the Monmouth County Environmental Coalition received a Technical Assistance Grant
from the USEPA to hire technical advisors to review documents and offer input to the
cleanup process.
A primary concern of the community has always been the protection of the Englishtown
Aquifer. Because the Site is a ground water discharge area located within the
Englishtown Aquifer, there has been no significant migration of contaminants into this
major water supply resource. Also, the Site is underlain by Woodbury clay, which is a
significant aquitard in this region. The Woodbury clay separates the Englishtown
Aquifer from the Lower Magothy Aquifer, thereby preventing the migration of
contaminants to the aquifer below. Other issues of concern have focused on the potential
environmental and public health risks posed by the Site. In particular, the ingestion of
contaminated water has been an issue because of the high concentrations of lead on the
Site. NJDEP routinely tests surface water in Burnt Fly Brook, which receives surface
water discharges from the Site, to monitor water quality. Residents and officials of Old
Bridge, Perth Amboy and Matawan have also expressed concern about potential
contaminant migration to the Deep Run water body, which receives drainage from Burnt
Fly Brook and recharges the Perth Amboy Wellfield. As an interim remedy, a
sedimentation basin was constructed in 1996 at a downstream location within the Site to
capture sediment before surface water leaves the Site. Residents have also expressed a
strong desire to ensure that a remedy does not destroy or significantly impact good
quality wetlands.
C. Summary' of Comments received during the Public Comment Period and
NJDEP/USEPA Responses
Part I: Summary and response to community concerns voiced at the
February 19,1998 public meeting.
Westerly Wetlands Issues
1. COMMENT
A request was made to see the data from the Westerly Wetlands displayed on a grid to
determine whether any hot spots exist within the area, which could be removed.
2
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RESPONSE
Maps showing contaminant concentrations are already available. The Ebasco Remedial
Investigations report (1988) contains full-size drawings showing cross-sections,
concentrations, concentration contours etc. The contamination is found to be widespread
throughout the Westerly Wetlands.
2. COMMENT
If humification is allowed to occur while leaving the contamination underneath the
"natural" cap, how will it affect the ground water?
RESPONSE
Humification is the creation of humus or organic matter owing to natural bio-degradation
of dead vegetative matter.
Ground water in the vicinity of the Westerly Wetlands discharges to the surface.
Therefore, migration of contaminants down through the water table is not occurring.
Lead and PCBs are expected to be bound with the soil, not mobilized through surface
water runoff. In addition, a sedimentation basin was constructed in 1996 at a location
downstream of the Westerly Wetlands. This basin is designed to collect sediment from
storm runoff originating from contaminated areas, and to allow surface water to continue
to flow into Burnt Fly Brook.
3. COMMENT
What would happen if a reversal of hydraulic conditions occurred during dry spells,
changing the area into a ground water recharge area?
RESPONSE
Although there has never been an indication that this would occur, the most likely places
for a reversal of hydraulic conditions to occur would be the Northerly Wetlands and Tar
Patch Area. Removal of contaminated soil from the Northerly Wetlands and the Tar
Patch Area, as recommended in the preferred alternative, would therefore eliminate the
risk of contaminants entering the Englishtown Aquifer.
4. COMMENT
The Monmouth County health officer stated that, based on 20 years of experience with
the Site, he is in agreement with NJDEP/USEPA's preferred alternative. He would,
however, add that at least once a year, the Department, along with representatives from
Old Bridge and Marlboro, inspect the full perimeter of the Site to ensure no breaches in
the fencing occurred.
3
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RESPONSE
Inspection of perimeter access controls on a regular basis will ensure that the integrity of
the fencing is maintained, and will be included in the operations and maintenance
program for the Westerly Wetlands. Old Bridge and Marlboro Township officials are
welcome to join the Department officials on these inspections, and should coordinate
such visits with the NJDEP operations manager.
5. COMMENT
Concerns were raised that by leaving contamination in place, NJDEP would be creating a
"toxic graveyard".
RESPONSE
NJDEP and USEPA disagree with the terminology "toxic graveyard". While
contamination will be allowed to remain in the Westerly Wetlands, the process of
vegetative humification and sediment buildup will form a barrier, thereby reducing
potential exposure to contaminated sediment. In addition, both agencies support leaving
contamination behind rather than excavating what is currently a thriving ecosystem. It is
believed that these natural processes can successfully cover the contaminated areas within
the wetlands. However, extensive monitoring will be performed to ensure that these
processes are occurring and that the remedy remains protective over the long term. The
primary objective is to allow the wetland ecosystem to remain undisturbed while
eliminating potential human exposure through 'restricted access'.
6. COMMENT
Since higher contaminant concentrations are commonly found closer to the source of the
problem, hot spots in the Westerly Wetlands could be expected to be present closer to the
Tar Patch Area. As remedial work will be done in the Tar Patch Area, the hot spots
within the Westerly Wetlands can also be remediated with little or no extra effort in terms
of constructing access roads.
RESPONSE
Maps showing contaminant concentrations in the Westerly Wetlands are already
available. The Ebasco Remedial Investigations report (1988) contains full-size drawings
showing cross-sections, concentrations, concentration contours etc. The contamination
is found to be widespread throughout the Westerly Wetlands.
After careful evaluation and investigation of the wetland areas downstream and
surrounding the Tar Patch Area, both agencies determined that hot spot removal within
the Westerly Wetlands is not appropriate. It is evident from historic data that high levels
of contamination extend throughout the Westerly Wetlands, and that accessing and
excavating any or all of these higher contamination areas would require destruction of
large areas of high quality wetland habitat. Also see RESPONSE No. 5 in Part II.
4
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7. COMMENT
Although data has not changed since the 1992 study, there may be greater
bioaccumulation of PCBs through the food chain. Therefore, would NJDEP be willing to
extend the remediation of the Tar Patch Area if the trends look like contamination is
greater adjacent to the Tar Patch Area in the Westerly Wetlands?
RESPONSE
Regarding the greater bioaccumulation of PCBs, such questions are expected to be
answered by the comprehensive monitoring program that the NJDEP and EPA will be
implementing. Due to conditions within the Westerly Wetlands which are favorable for
vegetative humification and sediment build-up, the selected remedy will allow for the
development and monitoring of a natural protective cover over the contamination in the
Westerly Wetlands while preserving the ecological integrity of the wetland system.
The remediation of the Tar Patch Area will include a portion of the Westerly Wetlands
which is immediately adjacent and similar in appearance to the Tar Patch Area.
8. COMMENT
Do we have the technology to clean up the Westerly Wetlands?
RESPONSE
The only reliable technology that is currently available is excavation and removal of
contaminated soil. While the removal of contaminated soil from the Westerly Wetlands
is technically feasible, the restoration of wetlands of such high quality has not proven to
be as successful. See also RESPONSE No. 5.
Northerly Wetlands and Tar Patch Area
9. COMMENT
How much soil is expected to be removed?
RESPONSE
Approximately 29,000 cubic yards of soil spread over the unvegetated portion of the Tar
Patch Area will be removed. The area involved is about four acres. In the Northerly
Wetlands, approximately 4,000 cubic yards spread over 2.5 acres will be removed.
10. COMMENT
Will wetlands be created in the Tar Patch Area?
RESPONSE
Upon completion of the removal action, wetlands will be created in the Tar Patch Area
and Northerly Wetlands.
5
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11. COMMENT
Can EPA's Removal Action Program implement the Tar Patch Area remedy more
quickly?
RESPONSE
No. NJDEP currently has the lead for this Site and plans to design and construct the
selected remedy and, therefore, EPA does not plan to have its removal branch implement
the remedy with remedial money. Furthermore, EPA does not believe that this Site
would meet the criteria for a removal action. Contamination does not represent any acute
threat to human health or the environment, and does not appear to be moving. The
sedimentation basin is in place to ensure no contamination threatens the public wellfields
further downstream.
12. COMMENT
Have any TCLP tests been done yet on the material to determine how it is going to be
disposed of?
RESPONSE
Appropriate tests will be done during remedial design to determine waste classification
for the purpose of disposal. Based on existing data and previous experience at the Site, it
was assumed in the feasibility study for costing purposes that excavated soil would be
disposed of as TSCA regujated material.
13. COMMENT
Will any material being disposed of be used as landfill cover?
RESPONSE
It is expected that, during the classification of soil, the levels of PCBs will most likely
prevent the soil from being used as landfill cover. However, if materials qualify for
beneficial re-use, then such an action could be implemented.
Traffic Issues
14. COMMENT
A number of questions were asked regarding traffic issues during the remediation. The
questions focused on what the plan will be, hours of operation, road restoration, truck
routes and the quality of trucks used during the removal.
RESPONSE
NJDEP representatives will meet with township public safety officials after the 65%
design is completed. Information gathered at that stage would identify any travel
restrictions that will be outlined in the bid documents for the construction contract. The
6
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construction contractor will submit the final traffic plan. Trucks used during removal
actions are usually lined and covered on top. In general, hours of operation can be
suitably restricted, and other measures implemented to satisfy community requirements.
Damages caused to roads due to Site-related traffic are also assessed and repaired.
15. COMMENT
Will the truck route go over the remediated Uplands Area?
RESPONSE
Truck routes will be determined during the remedial design stage. Reasonable efforts
will be made to prevent damage to the remediated Uplands Area. If necessary, any
damage will be repaired. See also RESPONSE No. 14.
Gromiri wgfcr issues
16. COMMENT
Does the Site have contaminated ground water?
RESPONSE
The nature of the geology at the Site is such that it is a ground water discharge area where
essentially ground water from the Englishtown Aquifer migrates to the surface, thereby
creating a wetland environment. The surface water then flows into Burnt Fly Brook. The
Woodbury Clay formation, which underlies the entire Site below the Englishtown
Aquifer, prevents any migration of contaminants into the Magothy Aquifer below it.
Based on our knowledeg of Site conditions, EPA and NJDEP are confident that the clay
is competent in providing an impermeable barrier between Site contaminants and
Magothy Aquifer. Installing wells through the clay and potentially providing a conduit
for the contaminants to enter the Magothy was not deemed necessary in the interest of
protecting human health and the environment. EPA and NJDEP believe there is no threat
to ground water users from the Site.
17. COMMENT
When the lagoons in the Uplands Area were excavated, was ground water contamination
found?
RESPONSE
Some volatile organic compounds and metals were detected in the ground water in the
Uplands Area at the time of the remediation of this area. See also RESPONSE No. 16.
7
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18. COMMENT
Is monitoring well data around the Tar Patch Area, Northerly Wetlands or Westerly
Wetlands available to confirm that there is no ground water contamination migrating off
the Site?
RESPONSE
Yes. Data associated with these areas can be obtained from reports available in the
repositories.
Ground water in the upper aquifer above the Woodbury Clay discharges to the surface in
the Westerly Wetlands. The surface water drains into Burnt Fly Brook. Surface water
flowing into the Brook is being monitored by NJDEP at quarterly intervals.
Monitor wells exist around the recently created sedimentation basin. The three ground
water monitor wells in this area are sampled at quarterly intervals to monitor water
quality in the upper aquifer near the sedimentation basin.
19. COMMENT
Are any monitoring wells installed on Site that you could definitely say there's no
groundwater pollution from the Site?
RESPONSE
There are three monitoring wells installed on Site which are located around the
sedimentation basin. These wells are sampled at quarterly intervals to monitor water
quality in the upper aquifer near the sedimentation basin. Based on several rounds of
quarterly monitoring, the data generated thus far has not indicated any exceedances to
groundwater quality standards.
Piezometers will be used to monitor the direction of ground water flow. The installation
of additional on-site wells may be considered during the development of a monitoring
program for the Westerly Wetlands. Also see RESPONSE Nos. 17 and 18.
Burnt Flv Brook/Sedimentation Basin Issues
20. COMMENT
What levels of lead have been detected in the Burnt Fly Brook and what is the source of
the lead?
RESPONSE
Lead has been detected periodically in the Burnt Fly Brook at several locations
downstream of the Westerly Wetlands discharge point, as well as upstream of the
Westerly Wetlands discharge (background sample locations). Upstream sources, if any,
arc unknown. Lead surface water levels have been varied; however, during 1996, lead
8
-------
surface water levels were typically below the New Jersey Surface Water Quality Criteria
for human health of five micrograms per liter.
21. COMMENT
How do you ensure no contamination is entering Burnt Fly Brook?
RESPONSE
Surface water and sediments in the Burnt Fly Brook are currently being monitored for
lead and PCBs at quarterly intervals at the location where surface water flow from the
Site enters the Burnt Fly Brook. In addition, routine maintenance of the sedimentation
basin allows for removal of sediment buildup at the appropriate time to ensure that the
basin is working efficiently.
22. COMMENT
When the sedimentation basin fills up, like it has in the recent past, where does the water
go and what happens if it overflows?
An emergency spillway capable of handling a 500-year storm has been built as part of
the sedimentation basin construction.
23. COMMENT
There is concern that no sediment sampling was performed along the banks of the Burnt
Fly Brook.
RESPONSE
An extensive investigation of the sediment in Burnt Fly Brook was conducted in 1996.
Burnt Fly Brook sediments were investigated and sampled beginning from the discharge
point from the Site for a distance of approximately 1.5 miles down stream, up to the
confluence with Deep Run. The only evidence of contamination in sediments was found
in a sample collected at the point at which storm flow from the Site discharges into Burnt
Fly Brook. This location was remediated as part of the remediation of the Downstream
Area. In addition, a monitoring program will be developed to monitor the Westerly
Wetlands which will include additional sampling of Burnt Fly Brook.
Various other Issues
24. COMMENT
Concerns were expressed at the public meeting regarding how the public could be
guaranteed that funding would be present throughout the cleanup.
RESPONSE
9
-------
In general, funding for projects cannot be guaranteed. Funding for the Superfund is
appropriated annually by Congress.
25. COMMENT
Concerns were voiced regarding the ecological and biological studies performed and their
current value for the decision-making process.
RESPONSE
Ecological receptors were the predominant concern in evaluating alternatives for the
Westerly Wetlands. As presented in the Feasibility Study, it has been determined that the
ecological community is best served by allowing the natural processes to mitigate future
exposure to contaminated soil. The data/studies are considered appropriate for decision-
making.
26. COMMENT
Is there any connection to Eagle Asphalt or Champion Chemical?
RESPONSE
A portion of the Burnt Fly Bog Site was owned by Eagle Asphalt and operated by both
Eagle Asphalt and Champion Chemical Company as a waste oil storage area from 1952
to 1964.
27. COMMENT
What is long-term maintenance?
RESPONSE
Long-term maintenance is estimated to be 30 years for the purpose of determining a
present-worth cost. However, long-term maintenance can be increased or decreased,
depending on the needs of the Site. Because contaminants will remain on Site, the Site
will be reviewed every five years in accordance with the requirements of CERCLA.
28. COMMENT
What happens if NJDEP privatizes?
RESPONSE
Any privatization of NJDEP will have no effect on the remediation of the Site.
29. COMMENT
Why was the Uplands Area capped with no wetlands restoration?
10
-------
RESPONSE
The Uplands Area, historically, was an upland area where artificial lagoons were
constructed. It was not a wetland area. Therefore, no wetland was created in this area.
30. COMMENT
When will actual construction work begin?
RESPONSE
Fence installation around the Westerly Wetlands will begin soon after the ROD is issued.
The public procurement process for the remainder of the remedial work requires a design
contractor to be hired through a bidding process. Upon completion of the design, a
contractor is hired for the construction phase. It is estimated that it would take at least
two years before major construction activities begin.
31. COMMENT
When will the project be bid out, and can it be done earlier so funds cannot be taken away
from NJDEP?
RESPONSE
Construction funds are not released by USEPA until a design is 95% complete. A design
Scope of Work is being prepared and the design contractor will be engaged as soon as
funds for this purpose are obtained soon after the issuance of the ROD. The design
contractor will be selected through open competitive bidding. This takes approximately
six months. Upon completion of the design, which should take approximately nine
months to complete, a construction contract will be bid out.
32. COMMENT
When will the design be complete?
RESPONSE
It is anticipated that the design work will be completed in the year 2000.
Part II: Summary and responses to written concerns received during the
public comment period
Comments submitted bv Blasland. Bouck & Lee on behalf of certain Potentially
Responsible Parties:
1. COMMENT
The assumption of unrestricted (residential) future use for the Site when determining
cleanup levels is unreasonable.
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RESPONSE
The Public Health Evaluation for the Supplemental Feasibility Study of Burnt Fly Bog
Site considered the anticipated future land uses for the Westerly Wetlands, Tar Patch, and
Northerly Wetlands. Since the Westerly Wetlands is an isolated wilderness area, it was
assumed for the purposes of the Public Health Evaluation that the Westerly Wetlands
would remain an undeveloped wetland area for the foreseeable future. The Northerly
Wetlands, conversely, is a small track of Palustrine Forested Broad Leaved Deciduous
wetland that is partially surrounded by upland areas. The Northerly Wetlands and Tar
Patch Area are within several hundred feet of a residential area. Because of the close
proximity to human receptors and the uncertainty of the future use of this area, the cancer
risk for exposure to Northerly Wetlands soil and Tar Patch Area soil containing PCBs
was evaluated for current adult trespassers and hypothetical future residents. Since the
cancer risk was estimated to be 7.5 x 10'\ well outside EPA's acceptable risk range, the
application of the most conservative soil cleanup criteria for the Northerly Wetlands soil
was determined to be appropriate.
The volume of contaminated soil in the Northerly Wetlands above ecological risk based
cleanup numbers is only 150 cubic yards less than that based on human health risk based
numbers. Limits for the Tar Patch Area cleanup will be based on visual contamination.
2. COMMENT
The cleanup levels for PCBs and lead should reflect important new data and recognize
certain factors not considered during remedy selection.
RESPONSE
With respect to PCBs, NJDEP is currently using a health based soil cleanup criteria based
on an A-280 developed slope factor of 1.4 (mg/kg-day)1 and a 10"6 risk level, resulting in
a residential direct contact soil cleanup criteria of 0.49 mg/kg. While USEPA has
conducted a reassessment of cancer dose-response based on PCB mixtures, NJDEP is in
the process of re-evaluating cleanup/screening criteria for PCBs for possible future
changes in PCB soil cleanup criteria. In this interim period, NJDEP is maintaining its
health based cleanup criteria for PCBs. The USEPA residential direct contact soil
cleanup criteria for PCBs is 1 mg/kg. The PCB numbers in effect when the ROD is
signed will be used as the cleanup criteria. In accordance with New Jersey State law,
cleanup criteria for carcinogens are based on a 10'6 risk level. The slope factor used by
NJDEP is 1.4 (mg/kg-day)'1, which is within the newly approved USEPA range of 0.4 to
2.0 (mg/kg-day)'1.
With respect to NJDEP's 400 mg/kg cleanup level for lead, the USEPA Integrated
Exposure Uptake Biokinetic (IEUBK) model is appropriate for establishing the cleanup
level for the Northerly Wetlands since NJDEP has determined that a future residential
scenerio and the application of the most conservative soil cleanup criteria is appropriate
for the Northerly Wetlands.
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3. COMMENT
The preferred remedy for the Tar Patch Area and Northerly Wetlands is excessively
costly. Remedial Action Objectives can be achieved by choosing a suitable 'Limited
Action' alternative for these areas, similar to the preferred remedy for the Westerly
Wetlands.
RESPONSE
EPA and NJDEP believe that the selected remedy provides the best balance of tradeoffs
with respect to the nine evaluation criteria. The Tar Patch Area is located adjacent to, and
upstream of, the Westerly Wetlands. A major portion of this area, approximately 4 acres
in extent, is denuded. No wetland vegetation currently exists in this area. Visibly
contaminated soil exhibiting tarry patches can be seen on the surface. The Tar Patch
Area is continuing to act as a source of contamination for other downstream areas,
including Westerly Wetlands and Burnt Fly Brook. Erosion of this non-vegetated area
occurs during storm events. On the other hand, the Westerly Wetlands is a recovering
wetland area covering an area of approximately 21 acres, with conditions favorable for
vegetative humification and sediment build-up.
Source removal from the Tar Patch Area has been recommended by choosing excavation
and off-site removal of contaminated soil as the preferred remedy for this part of the Site.
However, removal of contaminated soil will be restricted to the barren areas only. Once
the contaminated soil is removed, wetlands will be established in the excavated areas,
which will result in the formation of contiguous wetlands from the Westerly Wetlands to
the Northerly Wetlands.
The contaminated Northerly Wetlands area is approximately 2.5 acres in extent. It is
located upstream of the Tar patch Area. Unlike in the Westerly Wetlands, there are
mature trees within most of the Northerly Wetlands area. Therefore, the rate of
vegetative humification is expected to be less in the Northerly Wetlands when compared
to the scrub/shrub wetland areas within the Westerly Wetlands. Contaminated sediment
and soil can continue to migrate into the remediated Tar Patch Area during storm events.
Hence, the preferred remedy for the Northerly Wetlands is excavation and removal of
approximately 4,000 cubic yards of contaminated soil, and restoration of wetlands in the
excavated areas.
The Burnt Fly Bog ecosystem that encompasses approximately 1700 acres in Monmouth
County, New Jersey represents a unique and valuable natural resource. The discharge of
hazardous substances to this ecosystem, which has been extensively investigated and
characterized as the Burnt Fly Bog Superfund Site, represents a truly significant natural
resource injury. The duration of this injury began with the initial discharges to this
system, and continues today with significant concentrations of hazardous substances
remaining within the system. As discussed above, large areas of the Site are still devoid
of natural vegetation, and large areas of the system are still not fully functional wetlands
despite the beginning of natural revegetative processes in other areas. In addition to
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ensuring the overall protection of human health and the environment, NJDEP and
USEPA are also tasked with restoring and enhancing the natural resources of the State of
New Jersey for the public welfare. Accordingly, the Department is obligated to make
every effort to minimize the duration of identified natural resource injuries and restore
these valuable resources of the State whenever restoration is reasonable, effective, and
practicable. Both NJDEP and the USEPA strongly believe that the preferred remedy
which actively remediates the Tar Patch Area and Northerly Wetlands will begin to
restore some of the continuing natural resource injury to the ecosystem in an effective and
efficient manner. The Tar Patch Area is devoid of native vegetation and represents a
significant area of the Bog system that remains dysfunctional and unable to revegetate
naturally, apparently due to such high concentrations of contaminants. Thus, it is logical
to actively restore this portion of the Bog resource to a more natural condition and use. It
is likewise logical and appropriate to actively restore the Northerly Wetlands area since
this upstream area would represent a significant continuing source of recontamination to
the immediately adjacent, downstream Tar Patch Area.
Comments submitted bv the Monmouth County Environmental Coalition:
4. COMMENT
The limits of excavation within the Tar Patch Area for remedial purposes must be
extended into the Westerly Wetlands to include all areas directly down-gradient of the
Tar Patch Area.
RESPONSE
The limits of excavation for the Tar Patch Area will be based on visible contamination
and obviously stressed areas. The visual goal was chosen because the targeted area is
clearly defined due to the lack of vegetation in the area. If an exact number were
specified for the cleanup of this area, it would include vegetated portions of the Westerly
Wetlands area as well. The targeted area is approximately 4 acres in extent, and is not
capable of natural re-vcgetation as are the other contaminated areas. Existing wetlands
surrounding this core area will not be excavated as part of the remedial activities. Any
areas, including wetland areas, disturbed during construction activities will be restored as
part of the remedial operations.
5. COMMENT
Removal of'Hot Spots' within the Westerly Wetlands must also be included in the
preferred remedy for this part of the BFB Site.
RESPONSE
After careful evaluation and investigation of the wetland areas downstream and
surrounding the Tar Patch Area, both agencies determined that Hot Spot Removal within
the Westerly Wetlands is not appropriate. It is evident from historic data that high levels
of contamination extend throughout the Westerly Wetlands, and that accessing and
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excavating any or all of these higher contamination areas would require destruction of
large areas of high quality wetland habitat.
Sediment samples were taken in the Westerly Wetlands during remedial investigations
performed in 1985 on thirteen transects identified as T-l through T-13. Based on the
sampling data, high concentrations of lead and PCBs in the sediment were found
generally along the entire reach of the Westerly Wetlands, in the middle portions of these
transects. Extensive sediment sampling was again performed in the Westerly Wetlands in
1996 to confirm the extent of the contamination and current levels of contamination at
locations where high concentrations were encountered in 1985.
While hot spot removal was considered as a remedial alternative during Phase I of the
Supplemental Feasibility Study, closer examination of the 1985 and 1996 data revealed
that the higher contaminated sediments were not restricted to small, easily accessible
areas close to the barren Tar Patch Area. Rather, the higher contaminated sediments were
distributed along the entire reach of the Westerly Wetlands, and no decreasing
concentration gradient in a down-gradient direction beginning from the Uplands Area
was observed. In view of the above observations, it was concluded during Phase II of the
Supplemental Feasibility Study that the Hot Spot Removal alternative was inappropriate
for the Westerly Wetlands. Furthermore, any excavation of sediment from selected areas
within the Westerly Wetlands will result in the loss of large areas of thriving wetlands,
because large extents of uncontaminated wetland areas will be required to be destroyed or
filled to provide access for construction equipment.
Data and other information pertaining to this evaluation can be found in the following
reports, which form part of the Administrative Record for this Site:
Westerly Wetland Remedial Investigation Final Report, Burnt Fly Bog Site - January 1988.
Westerly Wetlands Field Sampling Report, Burnt Fly Bog Superfund Site, Supplemental
Feasibility Study - September 1997.
Final Field Sampling and Testing Results Report - Tar Patch Area - May 1994.
Northerly Wetlands Field Sampling Report, Burnt Fly Bog Superfund Site Supplemental
Feasibility Study - January 1997.
Final Supplemental Feasibility Study Report for Burnt Fly Bog Site - October 1997.
6. COMMENT
Extensive monitoring of soil and surface water must be conducted in the Westerly
Wetlands, Sedimentation Basin, and Burnt Fly Brook as part of the cleanup operation.
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RESPONSE
Periodic monitoring of the Burnt Fly Bog Site will include biological sampling, surface
water and soil sampling in the Westerly Wetlands, surface water, sediment and, if
necessary, biological sampling in Burnt Fly Brook, and surface water and sediment
sampling within the sedimentation basin. Specific sampling protocol, analytical
parameters, and sampling frequency will be provided in a Field Sampling and Monitoring
Plan which will be prepared as a component of the remedial action for the Site. In
addition and as required by CERCLA, for remedial actions that result in hazardous
substances remaining on-site above levels that allow for unrestricted use, review of the
selected remedy will be conducted no less than every five years after initiation of the
selected remedy.
7. COMMENT
It has been stated that lead was detected at the upstream background sample location in
Burnt Fly Brook. Is there any runoff from previously unknown area(s) of BFB
discharging into Burnt fly Brook upstream of the existing point of discharge near the
sedimentation basin?
RESPONSE
The sedimentation basin was designed, and constructed in 1996, to fully capture storm
runoff originating from within the BFB Superfund Site. Limits of the contaminated areas
within the Site, and hence the overall limits of the Site, were established through
extensive soil sampling conducted in the 1980's and later in 1994, and 1995. Therefore,
any low level lead contamination that is detected at the upstream sampling location
during the on-going surface water and sediment sampling in Burnt Fly Brook must
originate from other non-point sources in the upper reaches of the Brook. Lead levels in
sediment at the upstream location range from 4.6 mg/kg to 20.5 mg/kg indicating
background/ambient conditions.
Over the past 18 months of operation, regular inspections by NJDEP personnel indicate
that the basin is functioning as intended. There is no evidence that Site-related
contaminants are bypassing the basin or migrating off-site by other means.
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ROD FACT SHEET
SITE
Name
Location/State
EPA Region
HRS Score (date):
Site ID # :
Burnt Fly Bog
Marlboro Township,
II
40 (10/81)
NJD 98050 4997
New Jersey
ROD
Date Signed:
Remedies:
September 30, 1998
Excavation of contaminated soil/sediment
in Tar Patch and Northerly Wetlands Areas;
Limited action and institutional controls
in Westerly Wetlands
Operating Unit Number: OU-3
Capital cost: $ 16,624,400
Construction Completion: 12/2001
0 Sc
M in 1999
2000
2001
$
$
$
9,200
9,200
9,200
(1999 dollars]
Present worth;
Discount rate:
$ 136,000 (30 years)
$ 2,608,000 (7 years)
$ 13.975.000 (7 years)
$ 16,719,000
5 %
LEAD
Remedial/Enforcement:
EPA/State/PRP:
Primary contact (phone):
Secondary contact (phone)
Main PRP(s):
PRP Contact (phone):
Remedial (fund)
State
Anton Navarajah (609) 777-
Thomas Porucznik (212) 637
Dominick and Carmelo Manzo,
Ace-Manzo, Inc.
N/A
0340
4370
WASTE
Type:
Medium:
Origin:
Est. quantity:
PCBs, Lead
Soil, sediment,
Unlined lagoons
3 3,60 0 cu. yds.
surface water
filled with
recycled oil
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