Watershed Association Supports Landfill Listing on Superfund

On June 16, the Great Swamp Watershed Association submitted comments to the U.S. Environmental Protection Agency (EPA) supporting the agency's April 30, 2003, proposed addition of the Rolling Knolls landfill to its National Priorities List. If the listing is finalized, the contaminated site will be eligible for a federally administered cleanup. The retired landfill occupies 187 acres in Chatham Township. Forty of those acres overlap onto the Great Swamp National Wildlife Refuge, a federal nature preserve in Somerset and Morris counties.

Before it closed to dumping in 1968, Rolling Knolls had swallowed over three decades' worth of municipal and industrial wastes. It had been forgotten by government agencies, a pockmark on the edge of the Refuge, until six years ago, when Watershed Association consultants began an investigation that unearthed it as an environmental and public health hazard. Pollutants and pharmaceutical compounds -- including mercury, PCB's, barbiturates and muscle relaxants -- have lingered at Rolling Knolls in high concentrations.

"The site has had a measurable impact on its surrounding environment," said environmental engineer Paul Fox. If current laws require toxic chemicals to be disposed of in sealed vessels, then Rolling Knolls is an open container: the same contaminants found on-site were detected in off-site surface water, sediments, groundwater, and fish. Fox noted that the Wildlife Refuge on Rolling Knolls' southwestern border is home to several endangered and threatened species.

Even more critically, the pollution may pose a threat to human health. Water from Rolling Knolls flows into the Passaic River, which provides drinking water to 1.2 million residents of Central New Jersey.

These findings were serious enough to provoke an investigation by the U.S. Environmental Protection Agency (EPA). Using its Hazardous Ranking System (HRS), the EPA assessed whether Rolling Knolls was eligible for federal remediation. Rolling Knolls received an HRS score of 58.31, more than double the minimum NPL requirement, and was proposed for listing. However, Fox believes that the EPA investigation was incomplete. "It was developed without any groundwater migration, groundwater to surface water migration, or air migration score," Fox said, noting that Rolling Knolls' HRS would have been higher if these criteria had been included in the investigation.

Rolling Knolls is located in a geologically sensitive area. It sits atop a peninsula of sand and gravel deposits that a receding glacier scratched out of rock some 16,000 years ago. The Wildlife Refuge surrounds this peninsula on three sides. A thick swatch of clay, more than 150 feet thick, runs underneath the sand and gravel and extends across the swamp. Because the permeability of these layers is very different -- if the deposits are cotton, the clay is Gore-Tex -- chemicals present in Rolling Knolls' soil might seep through the deposits and off of the clay, and into the region's water supply. 

"The geological data clearly show that any shallow groundwater found under the [Rolling Knolls] site would only have one place to be discharged-- the Great Swamp and its surface water bodies," said Fox. "We believe this to be a serious matter."
The EPA did not include pharmaceutical pollutants in its HRS score, either. Fox called the presence of these compounds "a significant concern."

Still, Rolling Knolls' NPL listing makes clear that the EPA thinks that a cleanup merits federal aid. What is unclear is the kind of aid it will receive. Current Superfund legislation delimits two classes of federally administered cleanups-for industrial or federal facilities. Industrial facilities are sites where it is possible to locate former users of the site as liable for the cleanup; the federal designation exists for the "orphan" sites whose polluters are defunct. The federal government pays for federal facility cleanups, but Superfund work at these facilities has been known to proceed slowly. For now, Rolling Knolls has been proposed as an industrial, rather than federal, facility.

"Federal funds are available to assist cleanups like this one, through the Superfund program," said Julia Somers, Executive Director of the Watershed Association. "With the new emphasis on brownfield remediation and reuse, this site can become a real community asset."

"Sufficient information exists to identify viable former users of the site," Fox said, agreeing with the EPA's designation. "Listing this site as a federal facility would only serve to exacerbate the present site remediation backlog at the Department of Interior and would not result in an expedient investigation and remediation of the site."

The Great Swamp Watershed Association was created in 1981 to protect the Great Swamp watershed basin and relies solely on membership and contributions for support. For information on how to become a member, call the Watershed Association at 973-966-1900, or visit www.greatswamp.org.

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