### SUPERFUND FINAL SITE CLOSE OUT REPORT ASBESTOS DUMP SITE MEYERSVILLE,MORRIS COUNTY, NEW JERSEY

November 2009

Prepared by U.S. EnvironmentalProtection Agency, Region II 290 Broadway New York, New York 10007I. INTRODUCTION This Final Close Out Report documents that the U. S. Environmental Protection Agency (EPA) has completed all response actions for the Asbestos Dump Site in accordance with Close Out ProceduresforNational Priorities List Sites (OSWERDirective 9320.2-09A-P, January 2000). The Asbestos Dump Site (Site) consists offoUf separate properties which were addressed in three discrete operable units (OUs). OUI consists oftheMillington site, located in Millington, New Jersey. OU2 consists oftheNew Vernon Road and White Bridge Road "satellite" sites, both ofwhich are located in Meyersville, New Jersey. OU3 consists ofthe third satellite site, known as the Dietzman Tract, which is located in Harding Township, New Jersey. The Site was placed on the National Priorities List (NPL) in September 1983. A Remedial Investigation (RI) for the Site was conducted bythe National Gypsum Company (NGC), the Potentially Responsible Party (PRP), between 1986 and 1987. The RI sufficiently delineated the nature and extent ofcontamination for 

## au 1; however, EPA determined that additional investigations were needed to complete the characterizationofcontamination for OU2 and OU3. Subsequent 

### RI activities for OU2 were conducted by EPA and completed in 1991. OU3 

### RI activities were conductedbythe U.S. Fish and Wildlife Service (FWS) and completed in 1997. Records ofDecisions (RODs) for each ofthe three operable units, OUl, OU2 and OU3, were signed in September 1988, September 1991 and September 1998, respectively. The selected remedy for OUI included the installation ofa soil cover, slope stabilization, monitoring and implementation ofinstitutional controls. The remedy for OU2 consisted ofthe solidification/stabilization ofasbestos-contaminated soils at the New Vernon Road and White Bridge Road sites along with monitoring and implementation ofinstitutional controls. The OU3 remedy consisted ofremoval and off-site disposal ofnon-asbestos-containing contaminated materials, consolidation and capping ofasbestos-containing materials, and implementation of institutional controls. Remedial actions for the Site were completed bythe year 2000. As aresult ofthese actions, cleanup levels protective ofhuman health and the environment have been achieved for the Site. Given the natureofthis Site, the Final Close Out Report will summarize the history, remedies and remedial actions taken for each individual 

### au. II. SUMMARY OF SITE CONDITIONS Background

Manufacturing ofasbestos-containing material (ACM) began at the Millington site in 1927 by Asbestos, Ltd., which engaged in the fiberization and sale ofasbestos until 1946. While the propertyhad changed ownership over the years, ACM continued to be produced until 1975 when the plant was closed by NGC, the owner at the time. During the period in which the asbestos manufacturing facility was in operation, asbestos-containing waste hadbeen disposed of on the Millington site. When the Millington site had reached its capacity for on-site disposal,



### - 1 ­asbestos-containing waste materials were disposed ofoff-site at the New Vernon Road, White Bridge Road, and the Dietzman Tract sites. Background

- Operable Unit One OUI consists ofthe Millington site which is an II-acre commercial property located at 50 Division Avenue in Millington, New Jersey. The site is bounded on the westbythePassaic River, on the north by the Millington Train Station, and on the east and south by commercial and private residences, respectively. Currentlyowned byTifaLtd., this parcel was formerly utilized as an asbestos processingplant thathad several previous owners. Manufacturing of asbestos products at the Millington sitebegan in 1927 by Asbestos Ltd., which engaged in the fiberization and sale ofasbestos until 1946. From 1946 until 1953, the plant was owned and operated by Smith Asbestos, Inc., amanufacturer ofasbestos roofing and siding. During this later period, asbestos sediment from water settling ponds was disposed ofon-site. In May 1953, the propertywas acquired byNGC, which manufactured cement asbestos siding and roofing sheets at the plant until 1975. During this period, waste products, consisting of broken siding and asbestos fibers were dumped on a five-acre area ofthe property. This included a 330 by75-foot area (laterreferred to as the asbestos mound) where predominantly asbestos fibers were disposed. Itis estimated that 90,000 cubic yards ofasbestos waste were disposed ofon-site. Background

- Operable Unit Two

OU2 includes the New Vernon Road and White Bridge Road sites. The OU2 New Vernon Road site is located at 237 New Vernon Road in Meyersville, Long Hill Township, Morris County, New Jersey. Itconsists ofapproximately 30 acres ofland and is currentlyboundedby the Great SwampNational Wildlife Refuge (GSNWR) to the north, tracts ofwooded and wetland areas to the east and south, and New Vernon Road to the west. The propertypreviouslyincluded two residences and a large garage structure. From 1945 through 1980, the privatelyowned New Vernon Road site was used for farming. From 1968 to 1971, ACM generated byNGC, including asbestos fibers, broken asbestos tiles, and siding, was deposited throughout the site. Large amounts ofACM were deposited in the central portion ofthe property in a large depression. Asbestos had also been detected in other. areas ofthe property. In 1998, the government acquired the New Vernon Road site from theresidential owners. In January 2002, EPA, the New Jersey Department ofEnvironmental Protection (NJDEP) and the FWS reached an agreement on the terms ofthe transfer ofaportion ofthe New Vernon Road site to the FWS to expand the GSNWR. In September 2002, an approximate 25-acre portion of the New Vernon Road site was formally transferred to the FWS and is now part ofthe GSNWR. The remaining five-acre portion, which contains the area ofsolidified asbestos-containing material, was transferred to the State ofNew Jersey.

.

- 2 ­TheWhite Bridge Road site is located at 651 White Bridge Road in Long Hill Township, NJ. 

### It is approximatelytwo miles away from the New Vernon Road site and consists ofapproximately 12 acres ofland, as well as adjoining property, which is part ofthe GSNWR, in Meyersville, New Jersey. The site is bounded byWhite Bridge Road to the north, the GSNWR to the east and southeast, Black Brook to the southwest, and a wooded lot to the west. Oneprivate residence, including a two-storyhome, garage, two sheds and three stables, is currently located onthe site. Theproperty also includes a series offenced-in grazing fields. From 1945 through 1969, the White Bridge Road site had beenused for farming. In 1970, the propertywas purchased bythe currentresidents. From 1970 to 1975, ACM, including asbestos tiles and siding from the NGC, was disposed ofon the property. Subsequentto these disposal activities, the current owner converted the property into a horse farm with stables, ahorse riding track, and grazing fields. Thehorse riding track was comprised oflarge amounts ofACM mixed with soils. ACM had also been detected in other areas ofthe site. Theremedy for theWhite Bridge Road portion ofOU2 was completed and this portion ofthe site was deleted from the NPL in February 2002. Background

- Operable Unit Three

OU3 consists ofthe former DietzmanTract which is a seven-acre parcel ofland located in GSNWR, abouttwo miles southeast ofthe New Vernon Road portion ofthe site. The GSNWR, currently ownedbythe FWS, covers approximately7,400 acres ofswamp, wooded, and wetland areas. Therefuge is managed byFWS for a wildlife habitat and for recreational purposes. In addition to 185,000 annual visitors, there are approximately440 residents ofthe neighboring community within a one-mileradius ofOU3. The DietzmanTract included the· following four discrete areas: 1) Site A - a five-acre asbestos-contaminated dump; 2) Site B - a half-acre dump consisting ofrefuse and covered with ACM; 3) Unimproved Access Road (UAR) - aroad surfaced with ACM which leads to Site A and Site B; and 4) three small refuse areas adjoining Site B (Refuse Areas #1,3 and 6). The above-mentioned four discrete areas ofOU3 were used for the disposal ofrefuse collected from neighboring communities. Along with refuse, ACM and other industrial wastes from the NGC plant in Millington were trucked to the OU3 site for disposal. The disposal ofACM began in 1959 and ended in 1968 when the FWS acquired the property. Approximately40,000 cubic yards ofACM and refuse were delineated at OU3. Remedial Investigation/Feasibility Study (RI/FS)

In April 1985, EPA issued an Administrative Order to NGC to conduct the RIfFS at the four properties comprising the Site. NGC performed RI activities in 1986 and 1987 (hereinafter referred to as theNGC RI). EPA performed oversight ofthese activities. In May 1987, the RI report was submitted to EPA. Upon review, EPA determined that while the NGC RI had adequatelycharacterized contamination at the Millington site, the RI failed to adequately characterize the nature and extent ofcontamination at the New Vernon Road, White Bridge

- 3 ­**III~** H I 1'1 ,I IIRoad and DietzmanTract sites. In August 1990, EPA collected and analyzed soil and dust samples at the New Vernon Road and White Bridge Road sites. Contrary to datareported inNGC's RI report, high levels of asbestos were detected. EPA determined that an immediateremoval action was necessaryto address the imminent threat posedby the sites. During removal activities in 1990, EPA initiated a RVFS at the New Vernon Road and White Bridge Road aU2 sites to supplement the NGC RI and fully characterize the nature and extent ofasbestos contamination. Field work was completed in the fall of 1990 and the RI and FS reports were completed in June 1991. FWS initiated a RVFS in 1996 for the OU3 Dietzman Tract to fillthe data gaps from the NGC RI. The supplemental RIfFS for aU3 was completed in 1997. 

### RUES

- Operable Unit One

RIfFS activities were initiated byNGC in 1986 and completed in 1987. Theprimary , contaminant ofconcern was asbestos. Soil borings and historical information revealed that the upland portion ofsite contained broken asbestos tiles and siding, whilethe asbestos mound was found to contain predominantly asbestos fibers. The upland and asbestos mound portions ofthe site were covered with varying thicknesses oftopsoil; however, exposed areas ofasbestos fibers were observed onthe slope ofthe asbestos mound adjacent to the Passaic River. The asbestos mound was heavily vegetated with thick underbrush and deciduous trees. Extensive slope stability analyses indicated that the asbestos mound was relatively stable; however, the slope was unprotected from surface erosion and the potential destabilizing effects offlooding along thePassaic River. Analysis ofgroundwater samples revealed low concentrations ofmercury and asbestos related to disposal activities at the site. Mercury was detected in groundwater at concentrations exceeding drinking water standards in a limited number ofsamples; however, the limitedmercury contamination remained withinthe footprint ofthe landfill and did not pose an unacceptable human health risk. As a result, groundwater alternatives were not evaluated. Asbestos was detected at concentrations substantiallybelow the still proposed EPA drinking water standard. The RI and FS reports were completed in September 1988. 

### RUES

- Operable Unit 

### Two

EPA initiated a RIfFS in the fall of 1990 to supplement the NGC RI and to fully characterize the extent ofasbestos contamination. The RI included a hydrogeological investigation, extensive sampling and subsequent laboratory analysis ofsubsurface soils, sediments, surface water, groundwater, potable water and air. The dataindicated the presence ofelevated levels of asbestos in the soil atboththe New Vernon Road and White Bridge Road residential properties. Withrespect to groundwater, samplingresults indicated that asbestos was not detected at levels above the analytical detection limit for all groundwater samples analyzed. Asbestos was determined to be present in the air atboth aU2 sites as a result ofsoil contamination. EPA determinedthat an immediateremoval action was necessaryto address the imminent threat



### - 4 ­posed bythe contamination. Removal activities were conducted inthe fall of 1990 to temporarily reduce the potential for airborne asbestos fibers and to restrict access. Removal activities included installation offences, air and soil sample collection, decontamination ofthe residences, and visual inspection ofACM. RI field work was completed in 1990, and the RI and FS reports were completed in June 1991. RUES

- Operable Unit Three

The supplemental RI, known as the Phase II RI, for OU3 was needed to fill data gaps remaining from prior investigations to characterize the nature and extent ofcontamination at OU3. Another goal ofthe Phase II RI was to collect geotechnical data for evaluation ofremedial alternatives in the FS. RI activities included, but were not limited to, the following: I) characterization ofthe organic and inorganic contaminants and asbestos in the site media; 2) sampling ofgroundwater from 15 monitoring wells; 3) sampling ofsurface water; and 4) excavation ofdrums from Site A. EarlyPhase II RI field activities commenced in January 1996. Removal actions were conducted in Fall of 1996 and air quality monitoringwas completed in December 1996. The Phase II RI report was completed and submitted to EPA in 1997. Thereport indicated that OU3 was found to contain approximately 36,800 cubic yards ofACM, 3,800 cubic yards ofrefuse debris, an estimated 207 buried drums at Site A, and areas ofmetal-impacted soil and ACM. Buried drums located at Site A were removed in September 1997. FWS completed its FS report in 1997 which outlined general response actions that would satisfythe remedial action objectives for OU3 and recommend aremedy. FWS commissioned an independent value engineering study ofthe FS report which validated its findings, conclusions and recommendations. Record ofDecision (ROD)

The cleanup goal for the Site was to contain the migration ofasbestos. For OU1 and OU3, asbestos-containingmaterial was consolidated into the respective landfill areas for each OU and then capped. For OU2, the asbestos-containing material (having greater than 0.5% asbestos, which is the Transmission Electron Microscopy analytical method detection limit) was consolidated into one area, solidified and then capped. On-site ambient air monitoring was conducted during the RI. For OU1, OU2 and OU3, almost all samples from several rounds ofair monitoringhad results less than the 0.1 fibers/cc standard. There were a few samples slightly above the 0.01 fibers/cc standard; however, the human health risk assessment concluded that there was no significant human health risk posedby airborne asbestos. Again, to mitigatepotential future risks, the remediation goal for the site involved the capping ofasbestos-containing material since this material could be apotential source ofairborne asbestos.



### - 5 ­ROD

- Operable Unit One On September 30, 1988, EPA issued a ROD for 

## au 1. Themajor components ofthe selected remedy include the following: 1) installation ofa two-foot soil cover on areas ofexposed or minimally covered asbestos; 2) installation ofa chain-link securityfence to restrict access to the asbestos mound; 3) construction ofslope protection/stabilizationmeasures alongthe asbestos mound embankment; 4) construction ofsurface runoffdiversion channels on top ofthe asbestos mound; 5) operation and maintenance oftheremedy; 6) long-term monitoring; 7) institutional controls to restrict on-site groundwaterusage and limit development on the asbestos fill areas; and 8) treatability studies oftechnologies for permanent destruction orimmobilization of asbestos. ROD - Operable Unit Two On September27,1991, EPA issued a ROD documenting the Remedial Actions (RAs) for OU2. The ROD documented the remedial actions for boththe New Vernon Road property and the White Bridge Road property. The major components ofthe selected remedy include the following: I) in-situ solidification/stabilization ofasbestos-contaminated soils; 2) appropriate environmental monitoringto confirm the effectiveness oftheremedy; and 3) implementation of institutional controls to restrict future subsurface activities and assure the integrity ofthe treated waste. EPA issued an Explanation ofSignificant Differences (ESD) on October 20, 1993 to modify the remedy specified in the OU2 ROD. TRC and TAMS Consultants, Inc. initiated the Remedial Design (RD) in 1991 under contract with EPA and performed a solidification/stabilization treatability study as part ofthe RD. Basedupon the results ofthe treatability study, the solidification/stabilization depth was changed priorto the issuance ofthe Final Design Report in January 1993 to requirethat the solidified/stabilized mass beconstructed above the groundwater table. ROD

- Operable Unit Three On September 8, 1998, EPA issued a ROD for OU3. The major components ofthe selected remedy include the following: 1) access improvements; 2) long-term drainage improvements, and short-term erosion control measures; 3) drum removal activities (which were completed in September 1997 as a time-critical, non-emergency removal priorto implementation ofthe preferred alternative), including post-excavation and waste classification sampling; 4) removal and off-site disposal ofsoils with lead concentrations greater than 218 milligrams perkilogram (mglkg) (completed, Spring 1998); 5) consolidation ofSite B ACM into Site A (completed, Spring 1998); 6) placement ofa biotic cover over Site A; 7) implementation ofinstitutional controls to ensure the continued integrity ofthe drainage and cover activities; and 8) assessment ofwetland impacts and wetlands restoration.



### - 6­

### Remedy J

### mplementation RemedyImplementation

- Operable Unit One

OUI remedial action activities were conducted pursuant to the 1988 ROD. The U.S. Army Corps ofEngineers (USACE) provided oversight during all remedial activities. USACE contracted with IT Corporation (IT) to completethe remedial actions in accordance with the contract documents and all applicable state andfederal regulations. Mobilization activities began onJune 17, 1999 and included the delivery ofgeneral materials, initiation ofsoil erosion and sediment control measures, and clearing and grubbing activities. The primaryremedial construction activities included, but were not limited to, access road construction, retaining wall construction for slope stabilization, and cap construction operations These construction activities included movement ofcontaminated soil, intrusion ofsurface soil, construction ofdrainage channels, and on-site relocation ofACM. IT graded and compacted the north, south, and east roadways for improved access to the site. Access road construction activities for the south access road began onJuly 8, 1999. The retaining wall was installed at the toe ofthe asbestos mound for stabilizationpurposes. The wall is on average ten feet in height and 516 feet long. Work activities associated with the installation ofthe retaining wall beganonJuly 26, 1999 and were completed on May 15,2000. An access path was installed between thebase ofthe wall and the edge ofthe Passaic Riverto allow for access during operations and maintenance activities. Work activities associated with the access path were completed onNovember 12, 1999. Surface water runoffcontrols consisted ofthe construction ofdrainage channels and the installation ofdrains to divert runofffrom the asbestos mound. Drainage construction controls were initiated on August 10, 1999 and were completed onDecember22, 1999. Asbestos-contaminated material was relocated from the toe ofthe asbestos mound to the on­ site disposal area. Relocation activities were started onJuly 13, 1999 and were completed on November 23, 1999. Upon completion ofthe relocation activities, IT graded the asbestos mound and disposal area in preparation for cap construction activities. Capping activities, which began on August 16, 1999, included, butwere not limited to, closing the asbestos mound, relocating excavated material, grading the ACM to the required elevations, installation ofa geotextile and geogrid material, and the placement and grading ofa two-foot soil cover. On sloped surfaces, the cap consisted ofa four-inch layer ofcrushed stone, followed by geotextile fabric, geogrid, a second layer ofcrushed stone, structural fill material, and topsoil. On level surfaces, the cap consists ofa layer ofcontrolled fill, geotextile fabric, embedded portion ofthe geogrid, a second layer ofcontrolled fill, and topsoil. Capping material was compacted in accordance with the specification requirements. Upon completion ofthecap construction activities, IT performed site restoration and project close out activities. Siterestoration included final site grading, drainage ditch construction, placement oftopsoil, landscaping and planting, a final verification survey, site maintenance and cleanup, and demobilization ofall temporary facilities and utilities. Site restoration activities were initiated on April 1, 2000 and were concluded on May 15, 2000. In April 2000, a final

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# ..,,­inspection was conducted byEPA, USACE and IT. Thepurpose oftheinspection was to ensure that the work activities were completed in accordance with theproject specifications. As part ofthe final site inspection, EPA and NJDEP determined that the remedy was operational and functional. In September 200I, EPA approved the Final RA Report as well as the 30-Year Operations and Maintenance (O&M) Plan. NJDEP is currentlyresponsible for operation and maintenance activities. TheO&M Plan documents the installation ofa six-foothigh chain link security fence with surrounds the site on its north, east and south limits. A double swing gate is located on the northeastern corner ofthe site whichprovides access to the OUI site. Furthermore, the O&M Plan specifies that periodic inspections are conducted ofall 

## au 1design components includingtheretaining wall, perimeter access fence, capped area, and mowing/pruning ofthe ACM cover and surrounding areas. Monitoring ofsurface water and sediment sampling ofthe Passaic River, along with groundwatermonitoringperformed in accordance with theNew Jersey landfill closure requirements and the Sampling and Analysis Plan, are included in the O&M Plan. Currently, groundwater, surface water and sediment sampling is conducted once every five years. In addition to O&M activities, the OUI site is protected byinstitutional controls. A Deed Notice was filed byTifaRealty, Inc" in the Morris County, New Jersey, Office ofthe County Clerk, on September 8, 2008 for the OU 1Millingtonpropertydesignated as Block 12301, Lot 1 on the Long Hill Township tax map. TheDeedNotice has been filed in Deed Book 21152, Page 508. The Millington property consists ofapproximately 11 acres, with therestricted area comprising approximately five acres. The landfill, which is located onthe five-acre restricted area, is surroundedbya fence, and contains approximately 90,000 cubic yards ofasbestos and asbestos-containingmaterials. The types ofrestrictions placed onthe OUI Millington property significantly limit anytype ofintrusion onto the landfill, therebyrestricting on-site groundwater usage and limiting development on the asbestos fill areas. Any use ofthe landfill area must be designed to protect the integrity ofthe components ofthe landfill. 

### RemedyImplementation

- Operable Unit One

- Treatability Studies {Or PermanentDestruction orImmobilization of Asbestos The OU 1ROD required that, after the implementation ofthe cap, EPA conducttreatability studies to evaluate anyinnovative treatment technologies that maybe effective in permanently remediating asbestos. Upon completion ofthese studies, EPA would evaluate the applicability ofthese technologies to the Site and maychooseto select such a technology in a future ROD. Sincethe issuance ofthe OUI ROD, EPA hasperformed treatability studies on two technologies and evaluated a third technologyfor potential applicabilityto the OUI site. The results ofthese studies/evaluations are presentedbelow. As part ofthe OU2 activities, EPA evaluated asbestos remedial technologies. Solidification/stabilization ofACM, in addition to capping, was selected as part ofthe remedy for OU2 in the September 1991 ROD. The solidification/stabilizationprocess served to further immobilize asbestos in the soils, providing an extra level ofprotection, should the integrityof the capbe compromisedbyerosion or otherunforeseen circumstances in the future. A



### - 8 ­Treatability Study was conducted in the design phase for OU2. Theresults ofthe Treatability Study demonstrated that solidification/stabilization ofACM above the water table would be effective at immobilizing the ACM. The solidification/stabilization component ofthe OU2 remedy was successfully implemented at the White Bridge Road site in December 1997 and at the New Vernon Road site in September 2000. Although the solidification/stabilization technology used as part ofthe OU2 remedyprovides an additional level ofprotection to the OU2 sites, it does not result in thepermanent destruction ofasbestos orreturn the site to unrestricted use. Long-term O&M activities are still required at OU2. The solidification/stabilizationtechnology would notbe appropriate or cost efficient for use at OUI. The OUI landfill currentlyhas a protective cap constructed overthe ACM. Any additional level ofprotection that the application ofthe solidification/stabilization technology may afford is not necessary at this industrial site. The institutional controls which have been put in place as well as the established O&M procedures are expected to assure that the integrity of the cap is not compromised and this remedy should remain fully protective ofhuman health and the environment over time. Anotherinnovativetechnology, involving a type ofvitrification (thermal treatmentresulting in an asbestos-free glass), was bench-tested for evaluationofthe OU3 remedy priorto the 1997 OU3 Feasibility Study. This technology did not pass the feasibility study screeningprocess. The technical result ofthe benchtest proved to bepromising; however, the capital costs, permitting expenses and operating costs were prohibitive. Thermochemical asbestos conversion (destruction) technologies were developed bythe private sector in the 1990's and early 2000's to convert ACM to non-hazardous waste. These technologies are still considered to be relatively new and have yet to beimplemented at any Superfund site. For OU 1, implementation ofthethermochemical treatment would involve the excavation ofapproximately 90,000 cubic yards oflandfill material, which would be a huge undertaking. Furthermore, the excavated material would have to be treated and either returned to the landfill as backfill material or shipped off-site for disposal. The thermochemical treatment technologies are currently being considered for use at an EPA Region 9 site; however, the cost ofimplementing such a technology maybeprohibitive. Based on available treatment rates, the cost for implementingthe asbestos destruction technology at OUI ofthe Asbestos Dump Site was estimated to be well over $90 million. Given the substantial cost to implement this asbestos treatment technology and the lack ofavailable dataregarding its long-term effectiveness, EPA does not believe that this technology is appropriate to use at the Asbestos Dump Site at this time. EPA believes that the OUI remedy, including the cap constructed over the ACM waste, is protective and will remain protective. Deed restrictions are inplace to assure that the landfill cap is not disrupted in the future and the State ofNew Jersey is performingroutine O&M to assure the integrity ofthe cap. Based on review ofthe above technologies, EPA does not believe that any ofthe technologies are warranted for the site and does not phln to modifyor change the selected remedy.

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I 111 I III I· II II I I 1,1 11,·1 I I**IIII'~** I**~a1'** I ,1,,11 , IIIIH I If 1,1 I ,I I III IIIRemedvImplementation

- Operable Unit Two On September 27, 1991, the Regional Administratorissued a ROD documenting the RA for OU2, the New Vernon Road and White Bridge Road properties. For clarity, this section will describe the remedial construction activities for theNew Vernon Road and White Bridge Road properties separately. New Vernon Road Remedial action commenced at the New Vernon Road propertyin June 1994. The construction was performed in two separatephases, marked by schedule milestones ofSubstantial Completion and Final Completion. The first phasetook placebetween August 1994 and December 1994 and included the following: 1) excavation and consolidation ofACM; 2) in-situ solidification/stabilization ofACM; 3) impermeable cover and perimeterinfiltration trench construction; 4) placement ofrip rap alongthe sides ofthe cap for slope stability protection; and 5) backfill ofexcavation areas excluding topsoil and seeding. Both clean and contaminated excavation was conducted at the New Vernon Road property. An area, known as Area A, was designated as a clean excavation area. Theclean soils from Area A were excavated and deposited in a clean stockpile area for subsequent use as backfill material. A number ofadditional contaminated excavation areas were identified. The asbestoscontaminated soils were excavated from these sites and hauled to Area A and theprimary solidification area and spread in 12-inch lifts for subsequent solidification. Backfill materials were obtained from on-site and off-site sources. On-site fill was obtained from Area A. Offsite fill materials were used for backfilling the additional excavation areas. An area approximately 3.9 acres in size was solidified to a depth ofthree feet below the preexisting grade. Solidification was performed bymixing ACM with cement groutvia an on-site batch mixing plant. The solidification process was considered to be complete when the grout mixture had set, and quality control sampleresults indicated that the solidifiedmass conformed to the specified design criteria. A protective impermeable cap over and a perimeterinfiltration trench around the solidified area was constructed. The cap consisted ofsix inches ofstone screenings, a geomembrane liner constructed of60-mil High DensityPolyethylene to prevent infiltration through the solidified mass, a geocomposite drainage layer, a 24-inch layer ofcommon fill, and a vegetative layer consisting ofsix inches oftopsoil and grass. Toprevent erosion and maintain slope stability of cover soils, a layeroffour-inch stone fill underlainbynon-woven filter fabric wasplaced along the side slopes ofthe filled area, directly overthe perimetertrench. Runoffand infiltration water from the cap area drains through the stone layerinto the perimeter trench. The second phase ofremedial action activities began on March 27, 1995 and was intended to include site restoration work such as final grading with topsoil, grass establishment, planting, wetlands restoration, asphalt paving, and demobilization. The secondphase was halted when EPA issued a Stop Work Order onMarch 30, 1995. The Stop Work Order was issued to allow

- 10­EPA to investigate the technical and contractual issues related to the placement ofbackfill material which EPA determined did not meet the contract specifications. EPA subsequently issued a Cure Notice, on April 7, 1995, to CDM Federal Programs Corporation (CDM), an EPA contractor, for failure to meet the contract specification for the use offill at both the New Vernon Road and White BridgeRoad properties. The Cure Response at the New Vernon Road property included the removal ofall unacceptable fill, at no cost to the government. Approximately 30,000 cubic yards ofunacceptable backfill material was removed at the New Vernon Road property. In June 1998, the government acquired the New Vernon Road property and the property owners were permanentlyrelocated. TheCure Response cleanup activities at New Vernon Road were initiated in July 1998 and completed byMarch 1999. The USACE provided oversight ofthe Cure Response cleanup activities. In September 2000, EPA approved the Remedial Action Report for the New Vernon Road portion ofOU2. In June 2001, an O&M planfor the New Vernon Road site was finalized. The overall objective ofthe O&M Plan is to provide for periodic inspection, maintenance, and monitoring to evaluate and maintain the effectiveness ofthe remedy implemented at the site. The landfill cap, perimeter infiltration trench and environmental monitoring, are the key components ofthe O&M Plan. Environmental monitoring includes the collection and analysis ofgroundwater and monitoring ofwildlife species from the area around the New Vernon Road site. In January 2002, EPA, NJDEP and the FWS reached an agreement on the terms ofthetransfer ofaportion ofthe New Vernon Road propertyto FWS to expand the GSNWR. In September 2002, an approximate 25-acreportion ofthe New Vernon Road property (Block 225, Lot 30) was formally transferred to FWS and is now in use as part ofthe Refuge. This Lot also includes the residential structures alongNew Vernon Road. Theremaining five-acre portion ofthe property (Block 225, Lot 30.03), which contains the solidified ACM, was transferred to the State ofNew Jersey. NJDEP is conducting the O&M activities on the five-acre parcel ofthe property. Subsequent to the division ofthe New Vernon Road property between NJDEP and FWS, separate Deed Notices were filed for Block 225, Lots 30 and 30.03. The Deed Notice for Block 225, Lot 30 was filed in the Morris County, New Jersey, Office ofthe County Clerk on August 20, 2002. The Deed Notice includes a "Limited Subsurface Use Area" which exists within 10 feet ofthe foundation ofthe residences. This area is restricted because it could notbefully investigated for the presence ofasbestos because such investigation would have compromised the integrity ofthe substructure. Digging and excavating more than 12 inches below the surface ofthe Limited Subsurface Area is prohibited unless approved by EPA or NJDEP. The Deed Notice for Block 225-Lot 30.03, which pertains to the five-acre capped OU2 parcel, was filed in the Morris County, New Jersey, Office ofthe County Clerk on October 22, 2002. The Deed Notice specifies the restrictions placed on the capped area ofOU2. The Deed Notice does not permit any disturbance ofthe surface or subsurface ofthe capped area including, but not limited to filling, drilling, excavation, orthe removal oftopsoil, sediments, rock orminerals, orby

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I II I I I I·, II II I I I I lill I**l'II'fl.(~lJlt.** I" 1,1 I fill,. [ ff "I I" [ r' 1'1 1.Jd IIconstruction, planting anything otherthan grass orwildflowers, or changingthe topographyin anymanner; however, topsoil maybe added to makerepairs in accordance with the Deed Notice. Changing, damaging orremovingthe perimetertrench around the solidified mass, the manholes or the monitoring wells is also prohibited. White BridgeRoad Remedial construction activities for the White Bridge Road propertywere initiated in June 1994. The first phase ofactivities included excavation, solidification, backfilling and construction ofthe impermeable cover. Field work occurred between August 1994 and December 1994. ACM was excavated and consolidated into one central area oftheWhite BridgeRoad property. A higher volume ofACM was excavated than initially anticipated; therefore, a settlement analysis ofthe solidified mass was performed. Analytical results indicated that additional settlement ofup to nine inches could occur, which wouldplace the solidified mass in contact with the groundwater. As a result, theinitial design solidification depth was reduced to ensure that the solidified mass did not come in contact with the water table. This change in design was documented in an ESD, dated October20, 1993. Approximately2.5 acres ofland were solidified at the White Bridge Road site. The final depth ofthe solidified ACM was approximately 2.5 feet below the ground surface. An impermeable coverwas constructed overthe solidified mass. The cover consisted ofsix inches ofstone screenings, an impermeable high densitypolyethylene liner, a geonet drainage layer, 24 inches ofcommon fill, and six inches oftopsoil which was subsequently seeded. A perimetertrench was also installed in conjunction with the impermeable liner. Thetrench was three feet deep and five feet wide located on three sides ofthe landfill approximatelythree feet from the edge ofthe solidified mass. A minimum ofa nine-inch layer ofcourse aggregate was placed at thebottom ofthe trench followed byperforated and corrugated flexible pipe lain on the stone bed. At original grade, the geotextile fabric was wrapped across the top ofthe trench and overlapped. Furthermore, the trench was finished with a sloped layer offour-inch stone. A drainage layer, consisting ofgeosynthetic materials was placed overthe geomembrane and common fill was placed overthe drainage layer. The final layer consisted oftopsoil which was seeded to stabilize the soil and establish grass cover. The second phase ofremedial construction activities included site restoration. Site restoration includedtopsoil placement, fence construction, monitoring well installation, stockpile removal, seeding and landscape replacement. This phasewas conductedbetween March and November 1995. After implementation ofthe first phase oftheremedy, EPA discovered that some ofthe fill material, which was used bythe contractoronthe White BridgeRoad property, had originated from a facility subject to the New Jersey Cleanup Responsibility Act, now the Industrial Site RecoveryAct. On April 7, 1995, EPA issued a CureNotice to CDM, indicatingthat this material failed to meetthe contract specifications for fill. This was the same CureNotice that was issued for the New Vernon Road property, as described in the previous section.

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­Approximately 1,010 cubic yards ofthis unacceptable fill material, whichhad been used inthree areas on the White Bridge Road property, had to be addressed. Theworkperfonned under the Cure Notice Response Workplan was completed onAugust 28, 1995 and was perfonned at no cost to EPA orthe State. Remedial construction activities for the White Bridge Road site were completed in October 1995. The Final Remedial Action Report, preparedby COM, was approved by EPA in December 1997. In April 2000, EPA conducted activities at White Bridge Road to re-establish the vegetative cover and install a trench drain onthe surface ofthe cap. An O&M Plan was written for the White Bridge Road site inJuly 2001. The O&M Plan includes the maintenance and monitoring ofsite features includingthe landfill cap, perimeterinfiltration trench, and environmental monitoring. O&M obligations are sharedbetween both the property owners and NJDEP. Propertyowners are largely responsible for mowing and maintaining the capped area along with maintaining other site features while NJDEP is primarilyresponsible for the environmental monitoring activities. Details ofthe O&M obligations are outlined in the January 2001 Deed Notice

.

. OnJanuary 5,2001, the owners ofthe OU2 White Bridge Road property filed a Deed Notice

with the Morris County Clerk. EPA and the State ofNew Jersey agreed on the tenns ofthe Deed Notice. The Deed Notice has the same general restrictions as those included in the New Vernon Road Deed Noticewhereby any disturbance ofthe surface or subsurface cap is strictly prohibited. In addition, the White Bridge Road Deed Notice specifically prohibits the following: horseback riding; any type ofpasturingwhat would result in a pennanentpattern on the solidification area orthat will cause damage to the vegetative cover; any activity that might compromise the integrity ofthe solidified mass orits cap; and moving the fence posts installed onthe top ofthe solidifiedmass area. In February 2002, EPA deleted the White Bridge Road portion ofthe site from the NPL. 

### RemedvImplementation

- Operable Unit Three On September 8, 1998, the Regional Administrator signed a ROD for OU3. The United States Department ofthe Interior (001), acting through the FWS, was the lead agency for the remediation ofOU3, and EPA was the oversight agency. The USACE was contracted by the FWS to design the remedies and perfonn construction activities. Construction activities were subcontracted bytheUSACE to the ITCorporation. TheFWS established a three-phase approach for remediatingthe OU3 areas described in the previous OU3 background section. Phase 1 addressed the activities conducted as an emergencyresponse action to install drainage improvements at the OU3 site and remove buried drums from Site A. Access to Site A was improvedby upgrading the surface ofthe UAR and clearing dense vegetation covering SiteA. The site drainagewas enhanced by clearing the channel constriction and blockage where the UAR crosses the Old Great Brook Channel northwest ofSite A, which was alsothe location of a beaver dam. A culvert system was placed inthe channel to maintain vehicle access to Site B and improve site drainage. FWS also conducted interim drainage improvements in July 1997by

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­

I,I!'I' I'i 1,.1, I ',II I III I" I' II I I ' I I III I I I I, 11'.i I**~1flI** I 'lid I ' 11111'1 I 111111 I' I I Ifi I 1,1 'IIconstructing abypass channel to divert Old Great Brook surface water flow away from Site A. After drainage improvements were completed, drum excavation and removal, and off-site disposal ofthe drums and miscellaneous debris were initiated and completed in October 1997. Thenon-emergency, time-critical removal action included the excavation of207 buried drums and was undertaken to eliminate any threat offuture leachingofdrum contents to groundwater. Post-excavation soil samples were collected and the analytical results confirmed that contaminants in the drums had notbeenreleased to the soil and, therefore, were not released to groundwater above the regulatory standardsbefore or during removal. Phase 1work was completed in 1997. The Phase 2 removal action included the excavation, removal, and off-site disposal ofleadcontaminated soils located at Site B, Refuse Area#1, and RefuseArea#6 (as defined in the OU3 background section). The action was initiated in February 1998 and was completed in May 1998. Removal activities also included the consolidation ofACM from Site 

### B onto Site A. Thetotal volume oflead-impacted soils and debris removed and disposed off-site from Site 

### B was approximately 3,460 cubic yards. The total volume ofACM moved from Site B to Site A under the consolidation activities was approximately 740 cubic yards. Phase 3, the final remedial action phase, included the excavation and removal ofACM from the UAR, consolidationofthe excavated UAR material to Site A, backfilling the excavated portions ofthe UAR, and construction ofthe biotic cap on Site A. Cap construction activities included the installation ofan anchor trench on the west side ofthe landfill, compaction oflandfillmaterial, placement ofgeotextile fabric (woven and non-woven) and placement ofgeonet for the biotic barrier. The fabric was placed over the top ofthe landfill surface, with panels or sections ofthe fabric and geonet overlapping at aminimum ofsix inches. Soil material from an on-site stockpile was placed over the goetextile/geonet cap. Construction ofthe biotic cap on the SiteA landfill was considered to be complete after a final inspection was conducted in September 1999. The disturbed and created wetlands areas wererestored byplacinga final soil cover, consisting ofsix inches oforganic sediment, overthe areas. The sediment contained a natural seed bank with species indigenous to adjacent wetlands. The progress ofwetlands restoration efforts continues to bemonitored. The O&M Plan for OU3 inchides maintenance ofthepermanentfeatures such as the surface water drainage improvements and the Site A biotic cap. The O&Mplan also requires the implementation ofa groundwater monitoringprogram that meets the requirements ofthe New Jersey Pollutant Discharge Elimination System regulations. FWS is responsible for implementingthe OU3 O&Mplan. In addition to O&M activities, FWS has implemented institutional controls at OU3 to ensurethe continued integrity ofthe capped areas. OU3 institutional controls include the following: 1) restricted access via a gated road; 2) posted signs indicating closed areas; 3) law enforcement presence; 4) altered trail system to divert peoplefrom the landfill area; and 5) periodic inspections. The OU3 property is located entirely within the Great Swamp National Wildlife

- 14­Refuge). As part ofthe National Wilderness Area, the remediated OU3 area is protected from development or future land uses that might potentially conflict with the remedial design. Any changes to this designation would be subject to Congressional approval. As such, the land will be managed in perpetuityas wildlife habitat with very limited public use and access insofar as these activities are consistent and compatible with the O&M actions that have been prescribed for the site. On September 29, 1999, EPA approved the Final Remedial Action Report for OU3, which signified the completion ofaU3 remedial activities. 

### Community Relations

CommunityRelations

- Operable Unit One The draft RI and FS reports along with the Proposed Remedial Action Plan (PRAP), which identified EPA's preferred remedial alternative, were released to the public on August 19, 1988. All three documents were placed in the publicrepository at the PassaicTownship Hall. A public commentperiod was held from August 19, 1988 through September 9, 1988. A public meeting was held on August 29, 1988 at the Passaic Township Hall to present the RVFS and EPA's proposedremedy and to solicit public input. The issues raised during the comment period were addressed in the Responsiveness Summary Section ofthe ROD. Throughout the remedial process, several public meetingshadbeen held in an effort to keep the public informed ofsite cleanup activities. For example, apublic meetingwas held onApril 15, 1999 at Town Hall in Long Hill Township to discuss details ofEPA's construction plans for the OUI portion ofthe Asbestos Dump Superfund Site. Another meeting was held with town officials on May 5, 1999 to discuss the remedy implementation for OUI. Communication between EPA, town officials and the public also occurredregularlypriorto and during the construction period. Forthe 2005 OUI Five-Year Review, EPA notified the communityofthe initiation ofthe FiveYear Review process bypublishing a notice inthe CourierNews on September 17, 2005. The notice indicated that EPA would be conducting a five-year review ofthe remedies at the Asbestos Dump Site to ensure the remedies remain protective ofpublichealth and are functioning as designed. In addition, the notice indicated that oncethe five-year review process was completed, the results wouldbe made available to the public at the Long Hill Township Free Library. CommunityRelations

- Operable Unit Two OnJuly 8, 1991, EPA issued a notice in two local newspapers, which contained information relevant to the public commentperiod for the site, the date ofthe public meeting and availability ofthe administrative record. Thepublic comment period began on July 8, 1991 and ended on August 7, 1991. Thepublic meetingwas held on July 17, 1991 at the Passaic Township Free Public Library located in Sterling, NJ. The Proposed Plan was presented at themeeting and the

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­**"I'I"III.""'1411~1"Iit"'·'~~P''';i''O~I''!lr'(l.iilll'lll."I,lll,'~lllllld~lili"I,"I.J-'III'li~,U'J** HI I ,I' .". Ipublic was given an opportunityto raise questions and concerns about the site to EPA. In addition, written comments were accepted during the public commentperiod. Responses to the commentsreceived during thepublic comment period were incorporated into the Responsiveness Summary, included inthe ROD. In addition, there was frequent communicationbetween EPA and its representatives and the residents ofthe White Bridge Road and New Vernon Road sites priorto and throughout construction activities. The latest five-year review for OU2 was conducted in 2005, in conjunction with the

## au 1fiveyear review. Accordingly, community notification ofthe intent and scope ofthereview was included inthe OUI notification as described in the section above. CommunityRelations

- Operable Unit Three Once finalized, the RI report, FS report and ValueEngineering Report for OU3 were released to the public. The Proposed Plan was issued for public comment onDecember 12,1997. These documents were made availableto the public inthe FWS administrative record file at the Refuge Liaison's office and the information repositories at the Long Hill Township Free Public Library, located in Sterling, New Jersey and theHarding Township Kirby Municipal Building, Town Clerk's Office located in Vernon, NewJersey. The notice ofavailability for the abovereferenced documents was published in the Echoes-Sentinel and NewarkStar-Ledger on December 10, 1997 and in the Chatham Courier, DailyRecordand Observer-Tribune on December 11, 1997. The public commentperiod on these documents was held from December 12,1997 to January 16, 1998 and extended upon request to February 27,1998. For OU3, frequent informal meetings had been thepreferred method ofinformation distribution requested by the public during earlycommunityrelations scoping interviews. Conseguently, FWS hosted three CommunityInformation Open House forums to which all interested citizens and representatives ofvillage and county agencies were invited. Attendees participated in informal discussions, presentations, and question and answer sessions. In addition, nine fact sheets had been distributed to a mailing list ofover 150 interested parties. Periodic briefings were also held for several elected officials and a FWS liaison position and telephonehotline was staffed to facilitate information transfers. On December 17, 1997, FWS conducted apublic meetingto inform local officials and interested citizens about the Superfundprocess, to present theproposed remedy, review past removal activities at the OU3 site, and to respond to any questions regarding OU3 from area residents and other attendees. In February 1998, a Technical Assistance Grant was awarded byEPA to a stakeholder group. The Great Swamp Watershed Associationusedthe grant to assist its participation in reviewing response actions for all operable units ofthe Asbestos Dump Superfund Site, including OU3. Responses to commentsreceived at the public meeting and in writing during thepublic comment period were included in the Responsiveness Summary, which was included in the OU3 ROD.

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­Notification ofthe 2005 Five-Year Review was published in theNew Jersey Star-Ledger, including all County editions, on August 1, 2005 and in the Morris CountyDailyRecordon July 29-31,2005. Following the completion ofthe review, the results ofthe Five-Year Review were placed in the public repository, located at the GSNWRheadquarters. III. DEMONSTRATION OFCLEANUPACTIVITY QUALITY ASSURANCE AND QUALITY CONTROL For OUI and OU3, the RA activities were conducted by IT Corporation, under contract with USACE. EPA and the Statereviewed the remedial construction activities for compliance with quality assurance and quality control (QAlQC) protocols. Construction activities at OU1 and OU3 ofthe Sitewere determined to be consistent with the RODs, RD plans and specifications, and RD/RA statements ofwork issued to the contractors. Furthermore, the Quality Control (QC) program for both operable units included inspections and documentation ofsite activities to ensure compliancewith the remedial action contracts. The QC program also established the measures for management and control ofitems or activities affecting quality and to verify and document compliance to the specified requirements as outlined in the contract specification. Themeasures included, but were not limited to, the following: 1) design control; 2) project planning; 3) documents/records control; 4) corrective actions; 5) chemical/analytical testing; 6) subcontractor controls; 7) inspections/audits; 8) investigations and studies; and 9) use of standard QAlQC forms. QualityAssurance Project Plans (QAPPs) had also been developed according to EPA requirements. The QAPPs incorporated EPA and State QA/QC procedures and protocols. EPA analytical methods were used for confirmation and monitoring samples during RA activities. For OU2, the RA activities were conducted by CDM, under contract with EPA. CDM performed oversight ofall field work performed by its subcontractor, Geo-Con. Inspections and tests were performed to ensure that all work was in strict compliance with the contract documents and the Quality Control Plan (QCP). Geo-Con provided a complete inspection and testingprogram that established inspection and testing procedures followed from the beginning through final completion ofeach OU2 RA work item. During the execution ofthe remedial action at the OU2 sites, CDM performed oversight ofQA/QC verification sampling conducted by the subcontractor. Three types ofsamples were collected: asbestos area confirmatory sampling, solidification/stabilization area confirmatory sampling, and clean excavation area confirmatory sampling. In March 1995, EPA issued a Stop Work Order to CDM to address technical and contractual issues related to the backfill material associated with OU2. A Cure Notice was subsequently issued by EPA on April 7, 1995 to CDM for failure to meet the contract specification for the use offill atboth the New Vernon Road and White Bridge Road properties. Corrective action work, regarding thebackfill material, was completed in August 1995 for the WhiteBridge Road Property and March 1999 for theNew Vernon Road property. EPA approved the RA reports for the White Bridge Road and New Vernon Road properties in 1997 and 2000, respectively.

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­**,'I~IIIII"1** I illlill**111111,'II~IIIIIIII";I~~illllll** I**HI'II'~IIIII,1** I 111',1,1'11

### IV. MONITORINGRESULTS Ongoing OUI and OU2 monitoring activities primarily include the inspection ofthe landfill covers, inspection ofinstalled drainage features, inspection ofthe retaining wall (for OUI only) and groundwatermonitoring. Periodic inspections for OUI and OU2 are conductedbyNJDEP. As per the 2005 Five-Year Review Report for OU I and OU2, inspection findings indicated that the landfill covers and drainage/detentionbasins were in good condition. Furthermore, there were no signs ofdamage to the locks, casings or caps ofthe groundwatermonitoringwells. In April 2005, groundwater samples were collectedbyNJDEP from seven monitoring wells located at OUI and six monitoring wells located at OU2. Groundwater was analyzed for asbestos. Monitoringresults indicated that asbestos was notdetected in any ofthe sampled wells. Five surface water samples were also taken from the Passaic River for OUI and asbestos was not detected in any ofthe samples. Thenext sampling event for 

## au 1 and OU2 will be conducted in 2010. For OU3, FWS conducts monitoring activities which include, but are not limited to, inspection ofthe landfill cap, inspection ofdrainage improvements, and groundwatermonitoring. In addition, there is an environmental monitoring component which includes an analysis ofsurface water, groundwater, sediment and biota samples from the area around Site A. Environmental monitoringparameters, which are analyzed for each media, include target compound list (TCL) volatile organic compounds, TCL semivolatile organic compounds, TCLpesticides, polychlorinatedbiphenyls (PCBs), herbicides, target analyte list (TAL) metals, and asbestos. Based on data reviewed inthe 2005 Five-Year Report for OU3, no substantive detection of environmental contaminants (TCL pesticides/PCBs, herbicides, TCLvolatile organic compounds, and TCL semivolatile organic compounds) had been noted in sediment, surface water, or groundwater. Data from October 1999through December 2004 indicated that a number ofTALmetals and asbestos hadbeen detected; however, exceedences ofscreening values had becomeless common for each ofthe TAL metals over the five-year monitoring period. Furthermore, therehavebeen no detections ofasbestos in anymedia at OU3 since December 2002. Results ofthe 2005 Five-Year Review inspection further indicated that there were no substantive issues with regard to the structure or function ofthe landfill. The next sampling event for OU3 will be conducted in 2010. 

### V. SUMMARY OFTOTAL REMEDIAL CONSTRUCTION COSTS The final remedial action construction costs for OUl, OU2 and OU3 were as follows: 1) OUI costs were approximately $3,500,000; 2) OU2 costs for New Vernon Road were approximately $3,097,744 while the estimated cost for WhiteBridge Road, based on the remedial design, was $2,428,415; and 3) OU3 costs, as funded bythe FWS, were approximately $3,135,000. The total site costs for all operable units, incurredbyEPA to date, are approximately $28,419,734. Additional costs were incurred for the site and paid forbythe National Gypsum Companyprior to its bankruptcy. FWS also spent additional funds ontheremedial investigation and feasibility studies for OU3.

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­VI. PROTECTIVENESS This Site meets all the site completionrequirements as specified in OSWER Directive 9320.2­ 09-A-P, Close OutProcedures/orNational Priorities ListSites. The implemented remedies for OU 1, OU2 and OU3 ofthe Asbestos Dump Superfund Site currentlyprotect human health and the environment becausethe remedial actions have eliminated exposure pathways that could result in unacceptable risks. Furthennore, unacceptable risks are not anticipated as long as the engineered, access and institutional controls are properly monitored and maintained and the site uses remain consistent with the remedies. These controls will ensure the protectiveness of human health and the environment. VII. FIVE-YEAR REVIEW Subsequent to the completion ofthe remedial actions as described in previous sections, hazardous substances, primarilyasbestos-containing materials, remain at all three operable units ofthe Asbestos Dump Site above levels that allow for unlimited use and unrestricted exposure. Pursuant to CERCLA section 121(c), EPA will continue to conduct statutoryFive-Year Reviews to ensure that the implementedremedies remain protective ofhuman health and the environment. The 2005 Five-Year Review report for OU 1and OU2 concluded that the remedies are functioning as intended in the respective RODs. The OUl/OU2 report indicated that aside from continued compliance with institutional controls and monitoring ofengineering controls, there are no issues or recommendations for follow-up activities for OUI and OU2. Due to the presence ofasbestos-containing materials present in the landfill areas ofthe site properties, periodic sampling will continue to be conducted in accordance with the respective O&M plans. Theimplemented remedies for OUI and OU2 oftheAsbestos Dump Superfund Site are currentlyprotective ofhuman health and the environment because there are no exposure pathways that could result in unacceptable risks and none expected as long as the engineered, access, and institutional controls are properly monitored and maintained, and the site uses remain consistent with the remedy. The 2005 Five-Year Review report for OU3 concluded that the remedy is functioning as intended by the ROD. During the last five years ofO&M implementation, there has been ample documentation that the landfill is successfully meeting its intended protectivepurpose. The remedy has also been successful in its habitat restoration and wildlife goals. Numerous species are now found usingthe restored habitat on and around the aU3 landfill. No substantive issues with the structure or function ofthe landfill have been identified. No substantive detections of environmental contaminants have been noted in the sediment, surface water, or groundwater, and it is recommended thatmonitoring for these parameters be continued. Theremedy is functioning as intended and remains protective ofhuman health and the environment.

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­

I 'III U I 1:1 "'!'Thenext Five-Year Review for the Asbestos Dump Superfund Site will be conducted in 2010.

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### BIBLIOGRAPHY

SUPERFUND FINAL CLOSE OUT REPORT Asbestos Dump Superfund Site

Record ofDecision, Asbestos Dump Superfund Site

- Millington Site, September 30, 1988. Remedial Investigation Report

- Millington Site, Fred Hart Associates, Inc., February 29, 1988. Remedial Action Report

- Asbestos Dump OU-l Superfund Site, IT Corporation, February 2000.

I Investigation Report-Asbestos Dump Site, OU1, COM Federal Programs Corporation, March 1, 1995. Asbestos Dump Site

- Millington, Final Remedial Design Report, COM Federal Programs Corporation. Deed Notice-50 Division Avenue, Millington, New Jersey, Book 21152, Page 508, Filed in the Morris County, New Jersey, Office ofthe County Clerk September 8, 2008. Addendum to Remedial Investigation Report-Millington Site, Fred Hart Associates, Inc., April 14, 1988. Five-Year Review Report

- Asbestos Dump Superfund·Site, Operable Unit 1and Operable Unit 

### b September2005. 30-Year Operation and Maintenance Plan for Operable Unit 1 - Asbestos Dump Superfund Site, IT Corporation, September 2001. Record ofDecision, Asbestos Dump Superfund Site

- New Vernon Road and White Bridge Road Sites, September 27,1991. Final Remedial Action Report, Volume I, Asbestos Dump, New Vernon Road Site, COM Federal Programs Corporation, September 26,2000. Final Remedial Action Report, Volume II, Asbestos Dump, New Vernon Road Site, COM Federal Programs Corporation, September 2000. Operation and Maintenance Plan, Asbestos Dump Site, Operable Unit 2, New Vernon Road Property, U.S. EPA, June 2001.Asbestos Dump Site, Operable Unit 2, Final Design Report, TAMS Consultants, Inc.lTRC Environmental Corp., January 1993. New Vernon Road Site, Final Focused Remedial Investigation Report, AllianceTechnologies Corporation, June 10, 1991. Operation and Maintenance Plan, Asbestos Dump Site

- Operable Unit 2, White BridgeRoad Property, U.S. Environmental ProtectionAgency, July 2001. Final Remedial Action Report, Asbestos Dump, White Bridge Road Site, Volume 1, CDM Federal Programs Corporation, December 27,1996. Notice ofIntent to Delete the White Bridge Road Propertyofthe Asbestos Dump Superfund Site, QQerable Unit Two, from the National Priorities List, U.S. EPA, November 26, 2001. Record ofDecision for Operable Unit 3 oftheAsbestos Dump Superfund Site, U.S. Fish and Wildlife Service, September 8, 1998. Five-Year Review, Operable Unit 3 oftheAsbestos Dump Superfund Site, U.S. Fish and Wildlife Service, November 2005. Remedial Action Report, Operable Unit 3, Great Swamp National Wildlife Refuge Site, IT Corporation, August 1999. Remedial Action Work Plan, Operable Unit 3 ofthe Asbestos Dump Superfund Site, Foster Wheeler Environmental Corporation, June 1998. Operation and Maintenance Plan for Operable Unit 3 ofthe Asbestos Dump Superfund Site, IT Corporation, May 1999, Revised August 11, 1999. Phase II Remedial Investigation Report, Operable Unit 3 ofthe Asbestos Dump Superfund Site, Volume 1, FosterWheeler Environmental Corporation, January 1997. Phase II Remedial Investigation Report, Operable Unit 3 oftheAsbestos Dump Superfund Site, Yolume II, FosterWheeler Environmental Corporation, January 1997. Deed Notice for Block 225-Lot 30, Filed in the Morris County, New Jersey, Office ofthe County Clerk on August 20, 2002. Deed Notice for Block 225-Lot 30.03, Filed inthe Morris County, New Jersey, Office ofthe CountyClerk on October 22,2002. Deed Notice for White BridgeRoad Property, Filed in the Morris County, New Jersey, Office of the County Clerk on January 5, 2001.I ,I I J II' I I J IJ I I I I, I I I,**II~** I**~.J~** I ., I I 11"'11 1 1'" III J