superfund five-year review report south jersey clothing ...under the current site use. the...
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Superfund Five-Year Review Report South Jersey Clothing Company and Garden State Cleaners Sites
Buena Borough, Atlantic County, N~w Jersey
Prepared by: u.S. Environmental Protection Agency
Region II New York, New York
September 2009
Five-Year Review Summary Form
SITE IDENTIFICATION
Site name (from WasteLAN): South Jersey Clothing Co. and Garden State Cleaning Co.
EPA 10 (from WasteLAN): NJD980766828/ NJD053280160
Region: 2 State: NJ City/County: Town of Minotola, Buena Borough, Atlantic County
SITE STATUS
NPL status: • Final 0 Deleted 0 Other (specify)
Remediation status (choose all that apply): 0 Under Construction. Constructed.Operating
Multiple OUs?-. YES [j NO IConstruction completion date: 3/18/1999
Are portions of this site in use or suitable for reuse? • YES 0.7 acres 0 NO 0 N/A
REVIEW STATUS
Lead agency: .EPA 0 State 0 Tribe 0 Other Federal Agency
Author name: Rick Robinson
Author title: Remedial Project Author affiliation: EPA Manager
Review period:- 3/2004 to 9/2009
Oate(s) of site inspection: N.A. Daily operating facility
Type of review: o Post-SARA 0 Pre-SARA o NPL-Removal only o Non-NPL Remedial Action Site o NPL Stateffribe-Iead • Policy o Regional Discretion
Review number: 0 1 (first). 2 (second) 0 3 (third) 0 Other (specify)
Triggering action: o Actual RA Onsite Construction at au #1 o Actual RA Start at OU# 1 • Construction Completion o Previous Five-Year Review Report o Other (specify)
Triggering action date (from WasteLAN): 3/18/1999
Does the report include recommendation(s) and follow-up action(s)? .yes 0 no Is the remedy protective of the environment? • yes o no
["OU" re fers to operable unlt. ] ** [Review period should correspond to the actual start and end dates of the Five-Year Review in WasteLAN.]
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Five-Year Review Summary Form (continued)
Issues, Recommendations, and Follow-~ Actions
The South Jersey Clothing Co. and the Garden State Cleaners sites (the Sites) have on-going remedial activities including the operation and maintenance of a groundwater pump and treatment remedy, and groundwater monitoring activities. As expected by the decision documents, these activities are subject to routine modifications and adjustments. EPA is currently collecting data to evaluate and characterize the capture of the downgradient plume. Residential wells with PCE concentrations that exceed MCLs are no longer in use for potable purposes or have treatment systems. Additional potential sources of groundwater contamination have been identified at both Sites. EPA is currently evaluating these data. In addition, EPA is continuing to monitor vapor intrusion and evaluate the need for mitigation on properties adjacent to the Sites.
Protectiveness Statement
The remedy at the Sites is protective in the short-term. In order to be protective in the long-term, the potential vadose zone source areas at both Sites need to be addressed, and the capture of the contaminant plume needs to be documented. The discovery of potential additional source areas on the Sites does not impact the protectiveness of the remedy since the groundwater extraction and treatment system is capturing and controlling these potential source areas. Residential wells with PCE concentrations that exceed MCLs are no longer in use for potable purposes or have treatment systems. Residences in the vicinity of the plume are monitored semi-annually. Furthermore, there are no exposure pathways that could result in unacceptable risks under the current Site use. The groundwater contaminants are treated via an extraction/treatment facility. In addition, there is a Classification Exemption Area to restrict groundwater use within the area of the plume.
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Table of Contents
Five-Year Review Summary FODm
I. Introduction - 4
II . Site Chronology 4
I I I . Background. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
IV. Remedial Objectives 9
V. Progress Since the' Last Five-Year Review 12
VI. Five-Year Review Process 15
VII. Technical Assessment 18
VIII. Issues 22
IX. Recommendations and Follow-Up Actions 23
X. Statement of Protection ',' 23
XI. Next Five-Year Review ' 24
Tables
Table 1. - Chronology of Site Events 4
Table 2. - Issues ' 22
Table 3. - Recommendations and Follow-up Actions '" 23
Table 4. - Comparison of the Maximum Detected Concentration to the Groundwater Primary Drinking Water Standards (MCLs) 25
Table 5. - Documents, Data, and Information Reviewed in Completing the Five-Year Review 26
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I. Introduction
This second five-year review for the South Jersey Clothing Co. (SJCC) and the Garden State Cleaners Co. (GSC) Superfund Sites (the Sites), located in Buena Borough, Atlantic County, New Jersey, was conducted by Rick Robinson, the Remedial Project Manager (RPM), in accordance with the Comprehensive Five-Year Review Guidance, OSWER Directive 9355.7-03B-P (June 2001). The purpose of five-year reviews is to assure that implemented remedies protect public health and the environment and that they function as intended by the decision documents. This report will become part of the Sites' files.
The 1991 Record of Decision (ROD) for the Sites included remedies for the remediation of source area soils, and the containment, remediation and treatment of contaminated groundwater. While the remedies are intended to restore the Sites to unlimited use without restriction, it will take more than five years to accomplish this level of cleanup. A policy review is triggered by the preliminary close-out report, which was signed March 18, 1999.
II. Site Chronology
Table 1 summarizes Site-related events from discovery to the present.
Table 1. - Chronology of Site Events
Event Date(s)
New Jersey Department of Environmental Protection (NJDEP) investigated well water odor complaint at the Sites South Jersey Clothing Company (SJCC) owners removed an area of contaminated soils from the Site SJCC signed an Administrative Consent Order with NJDEP requiring the company to intensify monitoring and take measures to restrict migration of contaminants in groundwater SJCC installed and put into operation a groundwater extraction and treatment system Public Water Supply system was installed, by Buena Borollgh, to alleviate the threat associated with contaminated groundwater
January 1981
May 1981
January 1984
July 1985
1985
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Garden State Cleaners Priorities List
SJCC placed on National
andRemedial Investigation Completed
Record of Decision was
Design of small-scale system completed for
Construction of SVE at
operationSVE at GSC
EPA
Completion of design system for SJCC and GSC
Approval of Remedial
United States Army Corpcontract for
Demolition of SJCC
COE awards contract for system for SJCC treatment system for Construction of the SVE groundwater extraction completed
Joint final
Operational and
Interim Remedial
s
and
Commence
First Five-Year Review
(GSC) placed on National
Priorities List
Feasibility Study
signed
Soil Vapor Extraction (SVE) GSC (OU1)
GSC completed
determined soil cleanup goals were met at GSC
for groundwater treatment
Action Report for GSC OU1
of Engineers (COE) awards demolition of SJCC building
building completed
the construction of SVE and groundwater extraction and
SJCC and GSC at SJCC and the Sites
treatment system were
inspection by EPA, NJDEP, and COE
Preliminary Close-out Report Signed
Functional demonstration period
Action Report Approved
operation of Long-Term Remedial Action
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March 1989
October 1989
August 1991
September 26, 1991
August 1993
May 1994
June 1994 - March 1995
March 1995
August 1995
September 1995
October 1996
May 1997
June 1997
January 1999
February 22, 1999
March 18, 1999
March 1999 -February 2000
September 26, 2000
September 27, 2000
March 2004
COE submits the Remediation System Evaluation Report April 2005
EPA starts Vapor Intrusion investigation March 2006
Second Five-Year Review September 2009
III. Background
Physical Characteristics
The South Jersey Clothing Company and Garden State Cleaners are located in a predominantly rural residential area and one of New Jersey's prime agricultural areas in Buena Borough, Atlantic County, New Jersey.
Site Geology/Hydrogeology
The geology in the region surrounding the Sites is known as the New Jersey Coastal Plain, which consists of a sequence of unconsolidated sediments composed of thousands of feet of clay, silt, sand and gravel layers. These deposits form an independent and isolated aquifer system, bounded by the Atlantic Ocean, the Delaware River, and the rocky Appalachian Highlands of northern New Jersey. The aquifer is known as the Kirkwood-Cohansey Aquifer System, a water table aquifer beneath the Sites, and consists of Tertiary-age Cohansey Sand and the underlying Miocene-age Kirkwood Formation. The base of the aquifer is defined by a clay bed lying within the Kirkwood Formation. This clay bed lies approximately 270 feet below the ground surface.
The subsoil beneath the Sites is made up of four units. The uppermost hydrogeologic unit, unit 1, extends from the ground surface to approximately 70 feet below ground surface (bgs). The water table is located at approximately 25 feet bgs. The groundwater flows to the south at approximately 0.07 ft/day. The unit is composed of medium to coarse sand with little silt. Poorly sorted fine to coarse sand and discontinuous clay lenses were generally found within the upper half of the unit, between the ground surface and the water table.
Unit 2 is composed of medium to fine sand and some silt with discontinuous layers of medium to coarse sand and thin lenses of gray silt or clay. The unit is located between 70 feet and approximately 130 feet bgs. Groundwater flows slower in unit 2 than in unit 1, as unit 1 is comprised of more transmissive sediments.
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Unit 3 is composed of fine to medium sand and clay. The unit is located between approximately 130 feet and 150 feet bgs. The thickness, elevation and lithology of unit 3 vary across the Sites so that the layer is relatively impermeable to the vertical movement of groundwater and contamination.
Unit 4 is comprised of medium to fine sand and clay lenses, similar to unit 2. Groundwater flow within unit 4 is to the southeast at approximately 0.06 ft/day. The bottom of the Kirkwood-Cohansey Aquifer System likely occurs at approximately 270 feet bgs.
History of Contamination
On April 3, 1981, a resident of the town of Minotola, in Buena Borough, called the New Jersey Department of EDvironmental Protection (NJDEP) and complained of a noxious odor emanating from her drinking water. A subsequent investigation by NJDEP revealed that water from the resident's well had levels of trichloroethene (TCE) as high as 12,000 parts per billion (ppb), along with a lesser amount of other volatile organic compounds (VOCs). The investigation then focused on the adjacent SJCC manufacturing facility where it was discovered that liquid and solid industrial waste had been discharged onto the ground behind the facility.
According to one of the company owners, the disposal method from 1972 until early 1981 was to discharge the waste on the ground in areas around the building and railroad tracks. Approximately 26,000 gallons of TCE were used at the facility from 1972 to 1982. In addition to TCE, tetrachloroethene (PCE), chloroform, 1, 1, 1-trichloroethane, p-dichlorobenzene, ethylbenzene, chlorobenzene, toluene, xylene, styrene, and 1,2-dichloroethane were subsequently detected in soil behind the facility. The source of these compounds was probably sludge or liquid waste containing TCE and mineral oil. In addition, SJCC's owners reported that a fire at the facility in 1979 resulted in the release of an estimated 275 gallons of TCE from an on-site storage tank.
In May 1984, during the investigation by NJDEP of off-site groundwater contamination associated with SJCC, elevated levels of PCE from a well located east of GSC led NJDEP to suspect GSC as a possible source. During the ensuing inspection of GSC, which is two blocks south of SJCC, the owners acknowledged discharging wastes onto the ground without a NJPDES permit. Soil sa~ples obtained from the immediate area of the discharge pipes
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contained PCE. This discharge ended as of February 1985, and all effluents were then disposed of in accordance with the guidelines established by NJDEP. Four soil samples were obtained from beneath two discharge pipes and a PCE recycle tank. The highest concentration of PCE was 43,000 ppb and TCE was 16,500 ppb.
Land and Resource Use
The SJCC Site is a 1.2 acre property located on the northwest corner of Central and Atlantic Avenues in Minotola, Buena Borough, NJ, approximately 30 miles southeast of Philadelphia, PA. The South Jersey Clothing Company is bankrupt, out of business, and no longer exists. The Long-Term Remedial Action (LTRA) groundwater extraction and treatment system for the Sites is located on the former SJCC property. The GSC Site is located on Summer Road, approximately 500 feet south of SJCC. Garden State Cleaners still operates a dry cleaning business on the property. The land downgradient of the Sites is primarily residential with some small businesses. The surrounding area is predominantly rural and one of NJ's prime agricultural areas. Approximately 5,500 persons permanently reside in Buena Borough and the nearby communities of Buena and Landisville, according to 2000 census data.
Buena Borough has a municipal water system that serves 75 percent of its population. This system's wells are located approximately 2,000 feet upgradient of the site. All residents in the vicinity of, and 4000 feet downgradient of, the Sites obtain their water from the municipal water system. However, some residences just south of Wheat Rd «1,500 feet south of Garden State Cleaners) obtain water from private wells. Approximately 9,000 people obtain drinking water, and 3,800 acres of farmland are irrigated from wells within 3 miles of the sites.
There are no surface water features in the immediate vicinity of either site. The nearest surface water streams, Blackwater Branch and Deep Run, are located approximately 1.0 mile west and 1.2 miles south of the sites, respectively. Surface runoff from SJCC travels into a drainage ditch next to the railroad tracks located adjacent to the site and eventually discharges near the headwater of the Blackwater Branch. Surface water at GSC appears to infiltrate directly into the soil surrounding the building.
Initial Response
In November 1989, EPA began a federally funded remedial investigation/feasibility study (RI/FS) for the Sites. These
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activities were combined due to the proximity of SJCC and GSC to
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one another. The purpose of the RI/FS was to determine the nature and extent of contamination associated with the Sites.
RI field work was conducted in two phases; from December 1989 through February 1990, and from January 1991 through April 1991. Phase I of the RI included primarily shallow and subsurface soil sampling, shallow and intermediate monitoring well installation, and groundwater sampling. Phase II included shallow soil sampling, intermediate and deep monitoring well installation, and groundwater sampling activities.
The investigation revealed soil contamination extending from the northwest corner of the SJCC manufacturing building to the adjacent railroad bed. According to information obtained from NJDEP files, this was the same area where the wastes were reported to have been disposed of.
In addition, EPA identified extensive VOC contamination (primarily TCE and PCE) in the upper portion of the groundwater aquifer underlying the Sites. This contamination was found to be migrating in a southeasterly direction to approximately 3,500 feet from the Sites, and downward into the intermediate-depth aquifer. A total of seven VOCs detected in the groundwater samples exceeded the State and federal maximum contam~nant levels (MCLs) for drinking water.
A Feasibility Study was conducted to develop and evaluate five different remedial alternatives for both the contaminated soil and groundwater at the Sites.
IV. Remedial Objectives
Remedy Selection
On September 26, 1991, EPA issued a ROD which selected the following remedial action objectives for the Sites:
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• Restore the contaminated groundwater plume to levels below federal and state MCLs.
• Restore the groundwater to its beneficial use, which is a drinking water aquifer.
• Achieve cleanup levels of 1 part per million (ppm) each for PCE and TCE in contaminated soils on the Sites.
These goals would be achieved by the following remedial action components:
• Extraction of contaminated groundwater above the cleanup standards;
• Treatment of the extracted groundwater via air stripping and carbon adsorption;
• Reinjection of the treated groundwater upgradient from the Sites; and
• Appropriate environmental monitoring to ensure the effectiveness of the remedy.
• In-situ vapor extraction (SVE) of soil contaminated with VOCs.
EPA and NJDEP determined that, given the predominance of TCE and PCE at the Sites, there were elevated health risks through direct contact with the soil. Based on NJDEP's established Interim Soil Action Level of 1 ppm for total VOCs in soil, the levels of 1 ppm for each of these compounds would be used as the goal for cleanup of the contaminated soils at the Sites. This EPA/NJDEP soil cleanup goal was specified in the ROD, along with the drinking water cleanup standard of 1 part per billion (ppb) for both TCE and PCE. Furthermore, the ROD stated that the goal of the groundwater remedy was to restore the contaminated groundwater plume to levels below federal and State MCLs.
Remedy Implementation
The remedial design (RD) and remedial action (RA) phases of the project were broken into operable units. The SVE soil remedy for
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the Sites were designated as operable unit one (OUl) and the groundwater remedy as operable unit two (OU2). The design for the soil and groundwater systems was completed in August 1995.
Under an Interagency Agreement (lAG) with EPA, the Philadelphia District of the COE managed the remedial action activities for the Sites. The remedial activities were conducted as planned, and no additional areas of contamination were identified at that time.
Construction of the GSC SVE system was completed in the spring of 1994. The system was operated from June 1994 through March 1995, when EPA determined that the cleanup level goals for the site were met. Completion of this OUI at the GSC site was documented with the approval of the Remedial Action Report on September 13, 1995.
Due to the similarity in subsoil conditions between the Sites, the COE used the data obtained from the SVE system at GSC as the basis of design for the system at the SJCC. Thus, the GSC system served as a pilot project for the soil cleanup work planned at the SJCC site.
In January 1999, EPA completed construction of the SVE system at SJCC property and the groundwater extraction and treatment system for the Sites. With the exception of some minor modifications to the groundwater system, RA activities were performed according to the design specifications set forth in the RD package. The work included:
• Installation and operation of a groundwater extraction, treatment and discharge system to remediate the combined groundwater contaminant plume at the Sites. As originally constructed, this system consisted of 15 extraction wells and 12 injection wells located throughout the town of Minotola. A forcemain, located within the right-of-way to the town's main street, connects piping from these wells to a 510 gallons per minute (gpm) treatment facility. To accommodate the construction of the treatment plant, the SJCC building was demolished. This included the removal of asbestos-containing material, PCB-contaminated material, and kerosene-contaminated material to an approved disposal facility. The treatment building, which is· located at the SJCC site, provides for conventional physical and chemical treatment for the removal of metals and VOCs from the extracted groundwater.
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• Installation and operation of an SVE system to remediate the area of contaminated soil at the SJCC site. This system consisted of five extraction wells, a surface cover and a small treatment system surrounded by fencing. The highest levels of contaminants were detected in the 9 to 10 foot depth range. The SVE system at SJCC operated from February 1999 through February 2001, when EPA determined that the cleanup level goals for the Site were met.
System Operations/Long Term Response Action (LTRA)
EPA has an interagency agreement with the COE to operate and maintain the treatment system. The COE awarded Sevenson Environmental Services (SES) a contract for the LTRA activities at the Sites. LTRA for the treatment plant began on September 27, 2000. EPA plans to transfer the operation of the treatment plant to NJDEP at the conclusion of the LTRA period.
v. Progress Since the Last Five-Year Review
Results of the First Five-year Review
This is the second five-year review for the Sites. The first five-year review, completed by EPA in 2004, concluded that the remedial action for the Sites is protective. However, the review suggested that EPA conduct further investigation of the vapor intrusion pathway, install new extraction wells to capture the leading edge of the plume, and continued monitoring of residential wells currently outside of the outer extent of the contaminant plume.
The remedy assessment summary in the first five-year review noted that:
• Contamination from soils was removed from the Sites by SVE.
• Groundwater extraction and treatment is not fully operating as intended by the decision documents.
• The only known drinking water wells were outside of the outer extent of the contaminant plume.
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Remediation System Evaluation
To address the issues identified in the first five-year review, EPA contracted with the COE to conduct ,a Remediation System Evaluation (RSE) at both Sites. In April 2005, the COE submitted the RSE report which made several recommendations with respect to system effectiveness, cost reduction, and technical improvement. The report also addressed potential ways to enhance remediation, improve reporting and data management .. The RSE findings included:
• The groundwater extraction system was not capturing the leading edge of the contaminant _plume. The RSE recommended that additional extraction wells be installed near the Cleary School and Vine Road.
• Soil gas verification sampling should be done at both Sites to make sure adequate mass has been removed from the vadose zone.
• Treated groundwater was recharged to the subsurface; however, the capacity of the injection system was limiting the volume of water that could be treated.
Follow up Actions to Five-year Review and RSE
Soil
As a result of the findings in the RSE Report, in 2007 and 2008, EPA collected soil gas and membrane interface probe (MIP) samples at both SJCC and GSC. In 2009, EPA collected soil samples beneath the GSC building. The purpose of this investigation was to determine if residual source areas were still present in the subsurface soils at the Sites, and if so, to delineate the nature and extent of the contamination. These investigations confirmed that elevated levels of PCE remain in the subsur£ace soils at the GSC property, and elevated TCE levels remain in the subsurface soils on the SJCC property. Discussion of the results of the sampling can be found in Section VI.
Groundwa ter
At the time of the 2004 five-year review, the COE had noted that several injection wells failed from a buildup of slime, and there was insufficient reinjection capacity at the groundwater treatment plant. The COE found that the cause of the fouling was due, to a naturally occurring bacterium, pseudomonas sp. In 2005,
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the COE started adding a one-percent solution of chlorine which solved the bacteria fouling problem. The COE also installed 12 injection wells to replace the wells lost from bacteria fouling. In 2007 and 2008, the COE also increased the reinjection capacity of the groundwater treatment system by nearly 100 gallons per minute, by installing an injection trench anq redeveloping three of the old injection wells.
In 2006, the COE completed a study that delineated the extent and depth of the contaminant plume in the aquifer, and identified optimal locations for additional extraction wells. The study demonstrated that capture of the down-gradient plume could be achieved by installing additional extraction wells in the intermediate aquifer zone between Martinelli Ave and Wheat Rd, and in the deep aquifer zone between Wheat Rd and Vine Rd. Subsequently, wells EW-16, EW-12A, and EW-18 were installed and put into service. EPA is working on compiling additional information to evaluate capture of the downgradient contaminant plume.
In 2009, two additional extraction wells were installed, one at SJCC (EW-20) and one adjacent to GSC (EW-17), to address source contamination on the properties. Additional time is needed before water-quality trends can be evaluated regarding the capture of these source areas.
Vapor Intrusion
Since the last Five-Year Review, EPA conducted a soil vapor intrusion (SVI) investigation of properties that were located above the groundwater plume to evaluate the SVI exposure pathway. The health-based screening criteria provided in the Draft Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathway from Groundwater and Soils (USEPA 2002) was used to initially evaluate this exposure pathway. The guidance provides calculations of concentrations in groundwater associated with indoor air concentrations at acceptable levels of cancer risk (1 x 10-4 to 1 x 10-6
) and non-cancer hazard (HQ of 1; 0.1 to evaluate additive effects). A summary of the SVI investigation can be found in Section VI.
In 2006, EPA's Environmental Response Team (ERT) collected subslab soil gas samples and indoor air samples from 19 properties. In 2008, ERT performed a second round of sub-slab soil gas and indoor air samples on seven properties. The main areas of concern for vapor intrusion are the properties that are adjacent to the SJCC and GSC sites, where groundwater is shallowest. Elevated readings were detected in sub-slab samples from five properties in close proximity to the Sites. Indoor air
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concentrations at levels slightly above criteria were detected in one property adjacent to SJCC, in an unoccupied basement. EPA will continue to monitor the vapor intrusion pathway for the properties of concern. Evaluation of mitigation strategies will be performed, if deemed necessary by EPA.
Institutional Controls
In 2005, NJDEP established a Classification Exemption Area for the Sites to restrict groundwater use within the area of the plume.
VI. Five-Year Review Process
Administrative Components
The five-year review team consisted of Mr. Rick Robinson, RPM; Mr. Edward Modica, Hydrogeologist; Ms. Julie McPherson, Risk Assessor; Ms. Lora Smith, Risk Assessor, Mr. Tom Gibison, COE Project Manager; Mr. John Chamberlain, COE Geologist.
Community Involvement
EPA's Community Involvement Coordinator for the Sites is Ms. Natalie Loney. An announcement was published in The Press of Atlantic City, the area newspaper, on June 3, 2009, notifying the community of the initiation of the five-year review process. The notice indicated that upon completion of the five-year review, the document would be available to the public at the Borough of Buena Municipal Building located at 616 Central Ave, Minotola, New Jersey. In addition, the notice included the RPM's name, address and telephone number for questions related to the fiveyear review process of the South Jersey Clothing Company and Garden State Cleaners Superfund Sites in general. There were no significant comments received from the public as a result of this notice or based on information received from the other sources involved in the review.
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Document and Data Review
The documents, data, and information which were reviewed in completing this second five-year review are summarized in Table 5 (attached) .
Soil Data Summary
Investigatory field work was conducted in two phases by ERT in June 2007 and June 2008 to characterize subsurface soils in the vadose and saturated zones and delineate the nature and extent of chlorinated VOC contamination source areas. The investigation was conducted using a Geoprobe direct push technology rig and the Membrane Interface Probe (MIP) system. These investigations confirmed that elevated levels of PCE remain in the subsurface soils at the GSC property, and elevated TCE levels remain in the subsurface soils on the SJCC property.
Sampling at GSC indicates that approximately 1,400 cubic yards of contaminated soil above the soil cleanup criteria is still present in the vadose zone. A significant amount of contamination was also found beneath the GSC building and it is believed that the majority of the PCE mass is concentrated at a depth of 7 to 14 ft. PCE was detected in one sample at a concentration of over 14,000 ppm.
Sampling at SJCC indicates two areas of remaining soil contamination. The first area, about 165 cubic yards in volume, is within the top 7 feet of soil, with TCE concentrations of just over 1 ppm. It is appears that this remaining contamination may not have been effectively treated by the SVE system. A geomembrane cap was placed over the ground surface that may have curtailed vertical flow into the vapor extraction wells. The second area of TCE contamination, of approximately 1,000 cubic yards, is within discrete discontinuous clay lenses at a depth of 20 feet below ground surface. TCE concentrations in this zone are over 5,000 ppm. EPA is currently evaluating these data to determine how best to address these source areas.
Groundwater Data Summary
Groundwater data from the Site are collected on a semi-annually basis. For the first sampling event, samples are collected from all of the wells (approximately 100). For the second sampling event, samples are collected from about 50 percent of the wells. All residential wells are included in both sampling events.
Elevated VOC concentrations are primarily found in two areas: immediately west and south of the treatment plant extending to SJCC-8 on Pacific Avenue and east of Central Avenue between
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Martinelli Avenue and Louis Drive. TCE and PCE are the major contributors to the total VOC concentrations with cis-l,2-DCE being a lesser contributor. Recently, extraction wells EW-17 and EW-20 have been installed near the GSC and SJCC properties in order to enhance capture of dissolved product in groundwater near the source areas. In 2007 and 2008, EPA installed extraction wells EW-12A and EW-18to enhance capture in the deep aquifer. Additional monitoring is needed to confirm that increased pumping rates will effectively capture this contamination. See Figures 1-3.
Vapor Intrusion Data Summary
In 2006, EPA's Environmental Response Team collected sub-slab soil gas samples and indoor air samples from 19 properties. In 2008, ERTperformed a second round of sub-slab soil gas and indoor air samples on seven properties. The main areas of concern for vapor intrusion seem to be in the vicinity of the SJCC and GSC properties, where groundwater is shallowest. Elevated readings were detected in sub-slab samples from five properties in close proximity to the Sites. Indoor air concentrations at levels slightly above criteria were detected in one property adjacent to SJCC, in an unoccupied basement. EPA will continue to monitor the vapor intrusion pathway for the properties of concern. Evaluation of mitigation strategies will be performed, if deemed necessary by EPA.
Site Inspection
On February 18, 2009, the five-year review team conducted an inspection of the Sites. No issues of concern were identified.
The plant operators are on-site full time and the COE is on-site on a part-time basis. The treatment plant is secured by fencing and all visitors are required to sign in:
Interviews/Meetings
There is regular contact between the plant operators, the COE and EPA. There have been numerous meetings, phone calls, and correspondence, including some with NJDEP. There have been several meetings with Borough representatives as well as some contact with residents over the c~urse of the RA, LTRA, and vapor intrusion investigation.
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VII. Technical Assessment
Question A: Is the remedy functioning as intended by the decision documents?
The 1991 ROD remedy called for the in-situ treatment of contaminated soil via soil vapor extraction (SVE) and treatment of groundwater via total plume extraction, air stripping/carbon adsorption, reinjection of treated water into the aquifer and long-term monitoring of groundwater.
EPA and NJDEP selected a soil cleanup goal of 1 ppm for both TCE and PCE, the contaminants of concern, at both Sites. The goals of the groundwater remedy are to restore contaminated groundwater to levels below federal and state MCLs (1 ppb for TCE and PCE) and to restore groundwater for use as drinking water.
Soil
The 1991 ROD soil remedy called for SVE treatment of chlorinated volatile organic compound (CVOC)-contaminated soils at the Sites. Approximately 1,600 cubic yards of soil were originally treated
by in-situ vacuum using pump induced air flow through contaminated soils. Contaminated vapors were treated with granular activated carbon. The SVE system at GSC operated from June 1994 and was shut down after achieving target levels in March 1995. The SVE system at SJCC operated from February 1999 through February 2001, when EPA determined that the cleanup level goals were met.
In 2005, the RSE recommended that EPA collect soil gas samples at SJCC and GSC to determine if additional source material was present at both Sites. In 2007 and 2008, EPA collected soil gas and membrane interface probe (MIP) samples at SJCC and GSC. In 2009, EPA collected soil samples beneath the GSC building. These samples confirmed that concentrations of TCE and PCE continue to exceed the cleanup goal established in the ROD. The soil remedy did not completely function as intended because additional source material has been found. Additional vadose zone remediation is required. EPA is currently evaluating these data to determine how to address these residual sources.
Groundwater
According to the 1991 ROD, the groundwater remedy for the Sites calls for groundwater extraction, treatment of influent with air stripping and carbon adsorption, and re-injection of· effluent upgradient of the Sites. A groundwater monitoring program was also put into effect to monitor capture and water-quality trends. The
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goal of the remedy is to restore the Sites' groundwater to unlimited use, and to remediate the total plume via extraction from all zones of groundwater contamination exceeding ARARs. Until recently, however, the groundwater remedy had not been fully functional as several extraction wells had not been installed at optimal locations, enabling the plume to move beyond the zone of influence of several extraction wells and into the deeper aquifer. Additionally, clogging of aquifer formation adjacent to injection well screens limited injection capacity and prevented the treatment plant from running at full capacity.
In 2006, the COE completed a study that delineated the extent and depth of the contaminant plume in the aquifer, and identified optimal locations for additional extraction wells. The study demonstrated that capture of the downgradient plume could be achieved by installing additional extraction wells in the intermediate aquifer zone between Martinelli Ave and Wheat Rd, and in the deep aquifer zone between Wheat Rd and Vine Rd. Subsequently, wells EW-16, EW-12A, and EW-18 were installed and put into service. EPA also amended the monitoring program to include new wells. EPA is working on compiling additional information to evaluate capture of the downgradient contaminant plume and more time will be needed to allow for water-quality trends to develop in and adjacent to the plume so that a more considered evaluation of remedy effectiveness can be made.
The difficulties associated with the injection well field have also been addressed. Back in 2004, injection capacity dropped to 150 gpm. New injection wells were installed and put into service to replace failed wells allowing the treatment plant to operate at full capacity. An injection trench was also constructed to serve as a back-up system. It is now estimated that the reinjection system can handle about 500 gpm. For the first half of 2008, total injection flow rates averaged 437 gpm.
Recently, extraction wells EW-17 and EW-20 have been installed near the GSC and SJCC properties in order to enhance capture of dissolved product in groundwater near the source areas.
Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives used at the time of the remedy still valid?
Land use assumptions, exposure assumptions and pathways, and remedial action objectives considered in the decision documents remain valid. Although specific parameters may have changed
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since the time the risk assessment was completed, the process that was used remains valid.
According to the RSE, all residents within the vicinity of and 4,000 feet downgradient of the Sites receive water from a municipal water supply. This water is supplied from two deep wells located approximately 2,000 feet upgradient of the Sites. However, some residences just south of Wheat Rd «1,500 feet south of Garden State Cleaners) obtain water from private wells as depicted in the February 2006 COE Draft Groundwater Model Report. Eleven of these wells are included in EPA's semi-annual monitoring program. Based on data obtained in the October 2008 COE Semi-Annual Compliance Report, PCE contamination in most of the residential wells is below MCLs. The residential wells are largely screened in the shallow aquifer, above the CVOCcontaminated zones. However, four of the eleven residential wells had exceedences of NJDEP water quality standards for PCE. Two of the residential wells that have historically exceeded the MCL were provided treatment systems (wells R-2960 and R-1731). The other two residential wells (R-1615 and R-108) with PCE above MCLs are no longer in use for potable purposes. These homes are on public water. In 2004, well R-108 had the highest PCE concentration detected in the residential wells (123 ppb). While no data were available for the 2005-2007 time period, the PCE concentration in well R-108 has decreased considerably in the Octobe,r 20.08 sampling round (12 ppb). Both wells show a decreasing trend since 2001 and will continue to be monitored. None of the residential wells exceeded the NJDEP water quality standard for TCE. Properly operating treatment systems and an active monitoring program consisting of semi-annual sampling of all eleven wells will ensure the protectiveness of the remedy. In addition, there is a Classification Exemption Area (CEA) to restrict groundwater use within the area of the plume.
Soil vapor intrusion (SVI) is evaluated when soils and/or groundwater are known or suspected to contain VOCs. Since
,residences are located above groundwater contaminated with VOCs, primarily TCE and PCE, further investigation into the SVI exposure pathway has been conducted since the last Five-Year Review. The health-based screening criteria provided in the Draft Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathway from Groundwater and Soils (USEPA 2002) was used to initially evaluate this exposure pathway. The guidance provides calculations of concentrations in groundwater associated with indoor air concentrations at acceptable levels of cancer risk (1 x 10- 4 to 1 x 10- 6
) and non-cancer hazard (HQ of 1; 0.1 to evaluate additive effects).
At the SJCC and GSC properties, the potential for vapor intrusion exists with concentrations of TCE and PCE exceeding sub-slab
20
screening levels at both Sites (with a more pronounced effect from TCE at SJCC and PCE at GSC). While no building other than the water treatment facility exists on the SJCC property, any future construction there would need to be done with consideration of the potential for vapor intrusion, based on the most recent groundwater data. An active dry cleaning facility remains at GSC. Along with the optimized capture and treatment system for groundwater, monitoring the vapor intrusion pathway will ensure protectiveness at the GSC facility.
Since the last Five-Year Review, a number of homes and businesses within the extent of the groundwater plume have been evaluated for the vapor intrusion pathway. Several of these buildings, mainly in vicinity of the Sites, where groundwater is shallowest, have sub-slab concentrations of chlorinated VOCs above screening levels. Continued vapor intrusion monitoring in homes/businesses with historic sub-slab contamination and the consideration of mitigation systems for homes/businesses that EPA deems are exposed to, or have the potential to be exposed to, unacceptable risk will ensure protectiveness of the remedy.
Question C: Has any other information come to light that could call into question the protectiveness of the remedy?
As stated in the response to Question A, parts of the contaminant plume had migrated deeper into the Lower Sands beyond the reach of the extraction wells originally installed near the Wheat Road area. This issue has been largely addressed with the recent installation of the extraction wells in optimal locations. However, capture of the contaminant plume needs to be documented.
In 2007 and 2008, EPA collected soil gas and membrane interface probe samples at SJCC and GSC. In 2009, EPA collected soil samples beneath the GSC building. These samples confirmed that elevated levels of PCE remain in the subsurface soils at the GSC property, and elevated TCE levels remain in the subsurface soils on the SJCC property. The finding of additional source areas on the Sites does not impact the protectiveness of the remedy since the groundwater extraction and treatment system is capturing and controlling these source areas. EPA is continuing to monitor vapor intrusion and evaluate the need for mitigation on properties adjacent to the Sites.
Remedy Assessment Summary
• The SVE systems at both Sites did not completely remove all of the sources of groundwater contamination on the SJCC and GSC properties. TCE and PCE concentrations above screening
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levels are still present in the vadose zone. EPA is currently evaluating these data to determine how to address these residual sources.
• Groundwater extraction and treatment is fully operating as intended by the decision documents; however, additional characterization of the capture of the downgradient plume is needed.
• Five properties have elevated sub-slab vapor readings; however, all but one property had indoor air levels within acceptable levels. Continued monitoring of the indoor air in these properties is re.comrnended. Evaluation of mitigation strategies will be performed, if deemed necessary by EPA.
• Four of the eleven residential wells had exceedences of NJDEP water quality standards for PCE. Two of the residential wells that have historically exceeded the MCL for PCE were provided treatment systems (wells R-2960 and R1731). The other two residential wells (R-1615 and R-108) with peE above NJDEP water quality standards are no longer used for potable purposes. These homes are on public water. The remaining drinking water wells are outside of the outer extent of the contaminant plume. Additionally, a CEA has been established to restrict groundwater use within the plume.
VIII. Issues
Table 2. - Issues
Issues
Additional vadose zone contamination identified
Affects Current
Protectiveness (YiN)
Affects Future Protectiveness
(YIN)
N Y
Subslab vee concentrations continue to exceed screening criteria
Downgradient plume capture not fully characterized
N Y
N Y
PCE exceedences in residential wells N Y
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IX. Recommendations and Follow-Up Actions
Table 3. - Recommendations and Follow-up Actions
Reconunendations Party Oversigl:tt Responsible Agency
EPA EPA
EPA EPA
EPA EPA
EPA EPA
Milestoneand
DateFollow-up Actions
Evaluate March 2010 remediation alternatives of vadose zone contamination
Continue indoor Ongoing air monitoring
Continue to EPA working collect and on obtaining evaluate access for groundwater level monitoring data to ensure well complete capture installation of downgradient - Ongoing plume
Ongoing sample residential wells on a semi-annual basis
Continue to
Issue
Vadose zone contamination
Exceedences in subslab VOC concentrations
Downgradient plume capture
PCE exceedences in residential wells
Affects Protectiveness
(Y!N)
Current Future
N
N
N
Y
Y
Y
N Y
X. Statement of Protection
The remedy at the Sites is protective in the short-term. In order to be protective in the long-term, additional vadose zone contamination needs to be addressed and groundwater capture needs to be documented. The discovery of potential additional source areas on the Sites does not impact the protectiveness of the remedy since the groundwater extraction and treatment system is capturing and controlling these potential source areas. Residential wells with PCE concentrations that exceed MCLs are no longer used for potable purposes or have treatment systems. Residences in the vicinity of the plume are monitored semiannually. Furthermore, there are no exposure pathways that could result in unacceptable risks under the current Site use. The groundwater contaminants are treated via an extraction/treatment facility and there is a Classification Exemption Area to restrict groundwater use within the area of the plume.
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XI. Next Five-Year Review
EPA or the State will conduct another Five-Year Review before September 2014, unless groundwater cleanup objectives are achieved before then and a Final Close-Out Report or deletion of the Sites occurs.
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Table 4. - Comparison of the Maximum Detected Concentration to the Groundwater Primary Drinking Water Standards (MCLs)
Chemical of Potential Concern
(COPC)
Maximum Detected
Concentration (ug/l)
Groundwater Primary Drinking Water Standards
(ug/l)
Location of Maximum Detected
Concentra:tion (Date)
Federal 1 NJDEp2
Trichloroethylene (TCE)
2000 5 1 OW-30
5/7 /2007
Tetrachloroethylene (PCE)
1320 5 1 SJCC6
7/26/2004
Sources: 1 -Groundwater Primary Drinking Water Standards (MCLs) are legally enforceable standards. Refer to: http://www.epa.gov/safewater/mcl.html
2 -New Jersey Drinking Water Standards (MCLs) are legally enforceable standards. Refer to: http://www.state.nj.us/dep/watersupply/standard.html
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, I I , I If* ,I ~ ,i; ~ II I I I I I I I I 'I I
Table 5. - Documents, Data, and Information Reviewed in Completing the Five-Year Review
Record of Decision, EPA, September 1991;
Draft Final Remedial Investigation Report, Ebasco, August 1991;
Draft Final Feasibility Study Report, Ebasco, August 1991;
Final Soil Boring Program Report, SAlC, February 2002;
Record of Decision, EPA, September 26, 1991;
Preliminary Close Out Report, USEPA, March 18, 1999;
Draft Community Relations Plan for the South Jersey Clothing Company & Garden State Cleaners Sites, Ebasco, June 1989;
Remedial Action Report, US Army Corps of Engineers, September 1999;
NJDEP Impact to Groundwater Soil Cleanup Criteria (IGWSCC); http://www.nj.gov/dep/srp/guidance/scc/
USEPA 2002 Draft Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathway from Groundwater and Soils; http://www.epa.gov/osw/hazard/correctiveaction/eis/vapor.htm
Remediation System Evaluation (RSE), US Army Corps of Engineers, April 2005
South Jersey Clothing and Garden State Cleaners Sites Trip Report, August 24, 2006, Lockheed Martin Technology Services to EPA's Emergency Response Team
South Jersey Clothing and Garden State Cleaners Sites Trip Report, February 27, 2009, Lockheed Martin Technology Services to EPA's Emergency Response Team
Source Area Remedial Alternative Memorandum, March 5, 2009, EPA's Emergency Response Team to EPA Region 2
South Jersey Clothing Company/Garden State Cleaners Superfund Site Compliance Reports 2004-2008, Sevenson Environmental Services
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Final Groundwater Model Report - South Jersey Clothing/Garden State Cleaners Superfund Site, U.S. Army Corps of Engineers, May 2006
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,I' '"i.' 11-' I, I I I II', ,
-"'C:I _Tel
Figure 1 Shallow wells
Time vs Concentration SJCC/GSC Superfund Site
June 2009
TeE ~nd peE ConcenlfaUons· SJCC/GSC Stte '" .,-~ .. >
------_.-...
L-._J
.....sn TeE tlncl peE Concentrations ~ $JCCiGSC Site
TeE and peE Coneetltratton•• SJCCJG$C Site
TCE and peE Conc:entratlOns· SJCCIGSC $tte
~ ':I
I 11'1 "
i
eJ '"...,.-_, ~".'
Tee .tnd PeE Concentriiltions· SJCC1GSC sn.
OM)
Tee M'cJ peE Conuntration1o . SJCC/GSC Site
IEW!'1
TeE and peE Conce-ntr.tlOna· SJCC/G$C Sfte
C;'
TCE and peE Corli::entrationll • SJCC/GSC $Jte ....
Tel! a~ PCE eoncentrilUons· SJcelGSe She .....
OD
teE artd PCE eonU"trattons· SJCetGse SiteOW·1SI 0W10
-~.'
r .Jll.t-----------..:::----4 i =:~:I ,,~-....-----_W_.....o....I
Figure 2 '!lllHHHH!HOJ.HH Intermediate wells ~.~.;.;:::~:::;::::=::::;::::
• Time vs Concentration
SJCC/GSC Superfund Site R2960
June 2009
PCE
TCE
• Intermediate wells
;1 i I 11'1 I
TCE and PCE Concentrations, SJCCIGSC Site
Figure 3
Deep well time vs conc.
SJCC/GSC Superfund Site
.OW38 OW27
OW35D
OW33
I : ,~h--;--+_~:::s::::~~~*~=H ...;;.. .."i, t~rc(
j
II II IIow32 i'I',II
Ii • I,
,11500 0 500 i ~i~§_~~~~~i
TCE and PCE Concentrations· SJCC/GSC Site
Deep wells
PCE
TCE
TCE and PCE Concentration.· SJCCIGSC Site
TCE and PCE Concentrations· SJCCiGSC Site
;; t '" r--+-.,.....,.--+-;-.......,.-+-f--.,..-.......,......-_-;--! I -~ , :_rea ] 1~r-++-+_~-.......,.-+-'t""7-......:.""""'"~.............-f
• June 2009
I II"