United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROOm02-87/049
September 1987
SEPA
Superfund
Record of Decision
Cooper Road Dump, NJ
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TECHNICAL REPORT DATA
(Pleat read Inttnicitons on the revene before completing)
1. REPORT NO.
EPA/ROD/RO2-87/049
3. RECIPIENT'S ACCESSION NO.
k. TITLE AND SUBTITLE
SUPERPUND RECORD OF DECISION
Cooper Road, NJ
First Remedial Action - Final
S. REPORT DATE
September 30, 1987
I. PERFORMING ORGANIZATION CODE
. AUTHOR(S)
I. PERFORMING ORGANIZATION REPORT NO
9. PERFORMING ORGANIZATION NAME ANO ADDRESS
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME ANO ADDRESS
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
13. TYPE OF REPORT ANO PERIOD COVERED
Final ROD Report
14. SPONSORING AGENCY CODE
800/00
5. SUPPLEMENTARY NOTES
6. ABSTRACT
The Cooper Road site consists of a 100-square foot dumping area located in Voorhees
Township, Camden County, New Jersey. In 1982 several dozen,, one-to-two ounce, glass
vials containing unknown liquids were discovered at the site.- Some vials were broken,
but most remained intact, sampling of the vials by the New Jersey Department of
Environmental Protection (NJDEP) indicated the presence of benzene, ethylbenzene,
xylene, naphthalene and other contaminants. NJDEP requested the owners of the property
perform a complete and total removal of all vials. No response from the site owners
followed. The site changed ownership in June 1983, and upon request by NJDEP, the new
owners removed all vials and six inches of underlying soil. Subsequent sampling of soil
and ground water indicate no contaminants present above normal background levels.
EPA determined that no significant risk or threat to public health and the
environment exists and therefore no further action will be taken at this site. There
are no implementation issues or costs associated with this no action remedy.
KEY WORDS ANO DOCUMENT ANALYSIS
DESCRIPTORS
b.lOENTIFIERS/OPEN ENDED TERMS
c. COSATi Field/Croup
Record of Decision
Cooper Road, NJ
First Remedial Action - Final
Contaminated Media: none
Key contaminants: none
8. DISTRIBUTION STATEMENT
19. SECURITY CLASS / This Report!
None
21. NO, OP PAGE
20. SECURITY CLASS (Tins page I
None
22. PRICE
P«rm 2220-1 (R«». 4-77) PNKVIOU* COITION is OMOWKTK
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DECLARATION STATEMENT
RECORD OF DECISION
Cooper Road Dump
SITE NAME AND LOCATION
Cooper Road Dump, Voorhees Township, Camden County, New Jersey
STATEMENT OF PURPOSE
This decision document presents the selected remedial action
for the Cooper Road Dump site, developed in accordance with
the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980, as amended by the Superfund Amendments
and Reauthorization Act of 1986, and to the extent practicable,
the National Oil and Hazardous Substances Pollution Contingency
Plan, 40 CFR Part 300, November 20, 1985.
STATEMENT OF BASIS
I am basing my decision on the following documents, which are
contained in the administrative record and characterize the
area and evaluate the relative merits of remedial alternatives
for the Cooper Road site:
--Proposed Remedial Action Plan with Attachments, Cooper Road
Dump site, August 198"
- Sampling Trip Reports for the Cooper Road site, prepared by
NUS Corporation, August and September 1987
- State, EPA, and property owner documents describing site
conditions and previous cleanup activities
- Health Consultation for the Cooper Road site, prepared by the
Agency for Toxic Substances and Disease Registry, August 1987
- The attached Decision Summary for the site
- The attached Responsiveness Summary for the site, which
incorporates public comments received
- Staff summaries and recommendations
DESCRIPTION OF SELECTED REMEDY
The selected alternative is to take no further remedial action
at the Cooper Road site. Previous cleanup activities have
effectively and permanently addressed any and all public health
and environmental concerns related to the site. Furthermore,
it is recommended to initiate the administrative procedures to
delete the Cooper Road site from the National Priorities List.
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DECLARATIONS
Consistent with the Comprehensive Environmental Response, Com-
pensation and Liability Act, as amended, and the National Oil
and Hazardous Substances Pollution Contingency Plan, 40 CFR Part
300, I have determined that the selected remedy is protective
of human health and the environment, attains Federal and State
requirements that are applicable or relevant and appropriate
for this action, and is cost effective. Furthermore, the remedy
represents a permanent solution for the Cooper Road site.
The State of New Jersey has been consulted and agrees with the
selected remedy, as is documented in the attached letter of
concurrence.
I have also determined that this decision to take no further
remedial action is appropriate when balanced against the
availability of Superfund monies for use at other sites.
_ _
Date Chris'topherf J. /DSggett
Regional Administrator
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DECISION SUMMARY - SEPTEMBER 1987
COOPER ROAD DUMP
NEW JERSEY
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II
NEW YORK
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TABLE OF CONTENTS
PAGE
I. SITE LOCATION AND DESCRIPTION 1
II. SITE HISTORY 2
A. Origin of Problem 2
B. Initial Response Actions ..... 2
C. Remedial Investigation 3
III. RISK ASSESSMENT 5
Selection of Potential Contaminants of Concern . . 6
Exposure Pathways 7
Risk Characterization 7
Environmental Impacts 8
III. ENFORCEMENT ACTIVITIES 8
IV. COMMUNITY RELATIONS 8
Vo ALTERNATIVES EVALUATION 9
VI. SELECTED REMEDY 10
Vli. FIGURES ' 11
1. Site Location Map . . 11
2. Site Layout Map . 12
3. Geologic Cross Section Map 13
VIII. TABLE .14
Ranges of Chemical Concentrations by Medvamr
1-A: Sampling Data from Private Potable and
Site Well ' . 14
1-B: Sampling Data from Soils 15
ATTACHMENTS
A - State Letter of Concurrence
B - Responsiveness Summary
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Decision Summary
Cooper Road Dump
I. SITE LOCATION AND DESCRIPTION
The Cooper Road site is located approximately 500 feet west of
Cooper Road and 500 feet south of the intersection of Treebark
Terrace and Courtland Drive in Voorhees Township, situated in
the north central part of Camden County, New Jersey (Figure 1).
The dump encompasses a surface area of less than 100 square
feet, in the vicinity of a naturally occurring sand bluff.
Several dozen one to two ounce glass vials containing liquid
chemicals of unknown nature were found partially buried along the
top edges of an excavated soil pit area which formerly existed
at the site. Some of the vials were broken; however, most were
intact.
The area directly surrounding the site was formerly a pine
woodlands and, at present, is being developed for residential •
purposes. To the east on the opposite side of Cooper Road are
several private homes and industrial/office buildings. The
population in the area has grown significantly within the past
ten years due to substantial new construction of residential
homes. Construction of a ten unit residential development is
currently underway on the immediate site area, with the nearest
existing home approximately 300 feet northwest of the site.
Four, aquifers- exist beneath the- site, separated by clay layers
of-varying thickness (Figure 3). The upper clay layer occurs
approximately 70 to 140 feet below grade, and, being somewhat
permeable, allows a hydraulic connection between the first and
second aquifers from the soil surface. The nearest drinking
water well is on a residential property approximately 500 feet
southeast of the site, screened in the second or lower aquifer.
The two public water supply wells within the Township's bound-
aries are screened in a yet deeper aquifer over 1000 feet from
the soil surface; these wells'service most older homes and all
of the newer residential developments.
-There are several surface water discharge points in the vicinity
of the site which exist approximately 80 feet below the grade
of the dump area. Groundwater beneath the site thus could
potentially discharge to (a) the headwaters of the north branch
of the Cooper River, located 1000 feet northeast of the site;
(b) to a stream 1000 feet southwest of the site which feeds
into Las Bresas Lake at the end of Martindale Court in Voorhees
Township, located 2200 feet southwest of the site; and (c) to
a stream located 2000 feet southeast of the site which feeds
Cedar Lake, 3000 feet to the east.
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II. SITE HISTORY
A. Origin of Problem
In early 1982, a number of small glass vials of unknown origin
and composition were discovered to have been dumped at the
former sand borrow pit area identified as the Cooper Road site.
B. Initial Response Actions
In mid-1982/ the New Jersey Department of Environmental Protect-
ion (NJDEP) was informed of the presence of the vials by the New
Jersey State Police. NJDEP inspected the site and noted the
presence of about two dozen, one to two ounce vials lying on
the soil surface. Subsequent analysis of the contents of the
vials indicated the presence of several hazardous substances
including benzene, ethylbenzene, xylene, bis (2-chloroethoxy)
methane, naphthalene and hexachlorocyclopentadiene. Believing
that the vials posed a potential threat to human health or the
environment, NJDEP, on October 28, 1982, issued a Directive
Letter to the owner of the property to remove the hazardous
materials.
Since no reply to this letter was received as of June 1983, the
site was proposed by NJDEP as a candidate for .Superfund cleanup
under the authority of the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA). Due to its
potential for significant risk, to human health or the .environment,
primarily through the: groundwater route, the Cooper Road site
was thus included on the first proposed update to the National
Priorities List (NPL) of Superfund sites that was published in
August 1983.
Ownership of the site changed shortly after June 1983, and the
new site owner became the Cinnamerican Company. While an update
to the list of Superfund sites was being prepared, the Environ-
mental Protection Agency (EPA) and NJDEP determined that the
State, through its enforcement efforts, would attempt to get
responsible parties to initiate cleanup activities at the site.
A surface cleanup was accomplished in May 1984, pursuant to a
Directive Letter issued by NJDEP to the site owner at that
time. All vials were removed, as well as all soil to a depth
of six inches below any container. Two 24-inch soil core
samples were extracted from the excavated area. In addition, a
background soil sample was obtained during a separate sampling
event in May 1985 from a visually clean area away from the
dumped vials.
Mo significant levels above background levels of any hazardous
substances attributable to the vials were detected in the surface
soils at the excavated area. The background sample was found to
be free of any significant level of organics; some metals were
detected, but at levels generally found in the soils throughout
the State of New Jersey.
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Specificaily, lead and chromium were detected in soils (a)
beneath the site immediately after the vials were removed; and
(b) in the background sample, at maximum levels of 4.9 and 7.2
parts per million (ppm), respectively.
EPA was apprised of the surface cleanup and received copies of
the appropriate documents from NJDEP relative to this activity.
However, these documents, and the conclusion contained therein,
related only to the surface soil cleanup. Subsurface conditions,
including any potential groundwater contamination, were never
addressed.
Thus, EPA determined in October 1984 that further characterization
of subsurface site conditions was necessary to properly determine
whether a release of contamination into the underlying soils
and/or groundwater had occurred in the vicinity of the vials.
With this additional evaluation, EPA believed it would then be
able to make a proper determination on whether additional
remedial measures, beyond those conducted by the owners of the
property in 1984, were necessary to protect human health or the
environment. The site was then placed finally on the NPL in
November 1984-.
C. Remedial Investigation
Due to the moderately low ranking of. the. site, on the NPL, and'
because-of the- s.unface cleanup which, was-previously conducted,
funds' for additional evaluation to further characterize the
potential for subsurface contamination did not
become available until fiscal year 1986. During 1986, EPA and
NJDEP held several discussions and reviews of existing data in
order to determine the scope of additional study necessary.
In September 1986, EPA and NJDEP agreed to conduct subsurface
soil and groundwater sampling that required the installation of a
groundwater monitoring well at' the site. EPA directed its
field contractor, NUS, to perform this additional work. After
EPA and NJDEP review and approval of a work plan for these
activities/ the well was installed and soil samples collected
for laboratory analysis in early April 1987 (Figure 2). The
groundwater from the well was also sampled later that month.
All data were subjected to EPA's quality assurance/quality
control process for validation. Analysis of the soil detected
trace amounts of chloroform, bis (2-ethylhexyl) phthalate, lead,
chromium, arsenic and nickel (Table 1-B). The maximum lead and
chromium levels were not significantly different from those
levels detected three years previously, at 4.7 and 6.4 ppm,
respectively.
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The groundwater indicated the presence of trace levels of
barium/ beryllium/ chromium/ copper, lead, vanadium, iron,
zinc, and sodium, as well as other elements normally associated
with background surficial aquifers in southern New Jersey.
Two metals in these groundwater samples were preliminarily
indicated to be above EPA's Primary Drinking Water Regulations
(40 CFR,.Part 141): lead, detected at 105 parts per billion
(ppb), compared to a standard of 50 ppb; and chromium, detected
at 116 ppb, also with a standard of 50 ppb. However, lead and
silver were also detected in a clean blank sample prepared for
data validation purposes. It is believed that the blank
contamination was introduced at the laboratory which conducted
the analysis. The presence of this laboratory contamination,
in turn, raised some question as to the validity of the reported
metal values for the groundwater samples.
As a result, confirmatory groundwater sampling was conducted in
mid-August 1987. This analysis detected lead and chromium at
7 and 15 ppb, respectively, significantly below the drinking
water standard of 50 ppb. With this sampling event, there was
no detection of any metals in the blank. An additional round
of groundwater sampling, conducted in early September 1987,
also found no significant levels of any contaminants in the
groundwater nor in the blank. Thus, the latter two rounds of.
groundwater data are-considered valid and representative of
actual groundwater quality. • • .
During the second round of sampling in mid-August, four homes
with private wells located within a half mile of the site were
also sampled. Three of the private wells are located within
1000 feet of the site at 504, 508 and 512 Cooper Road, and one
domestic well located 3/4 mile from the site at 709 Cooper Road.
Written records to confirm the depth of these wells could not
be found. Through discussions with homeowners, two of these
wells are understood to have been screened at least 140 feet
below the land surface. Further discussions with a well drilling
company which operates throughout Camden County indicate that
this is a normal depth for the installation of private wells
within 'the county; thus, the other two private wells are also
believed to be screened at this appropriate depth.
At this depth/ the private wells would be screened within the
second aquifer from the soil surface (Mount Laurel)/ and thus
be separated from any potential contamination which could exist
within the upper aquifer (Cohansey/Kirkwood) by the confining
semi-permeable clay unit of approximately 100 foot vertical
thickness. EPA's testing of these private wells confirmed that
no contaminants are present which could potentially produce any
adverse health effects based on federal guidance and criteria,
with no lead or chromium detected in any well.
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Within a one mile radius of the Cooper Road site, the upper
aquifer (Cohansey/Kirkwood) in which the monitoring well at the
site is screened has not been found to be tapped for any domestic,
irrigation or industrial use.
There are no known industries located within a half mile radius
of the site. Those industries and homes within a one mile
radius of the site that have individual wells in use are believed
to also be screened in the Mount Laurel aquifer. All results
of well sampling within the Mount Laurel 'in the vicinity of this
site were consistent with State background levels and have not
indicated any levels of any contaminants which could adversely
affect human health.
All homes within one mile of the site in the southeast, down-
gradient direction are supplied public water from the New
Jersey Water Company (NJWC). NJWC owns and operates water
supply wells at two locations within Voorhees Township: (1)
Well #20, located near the intersection of Evesham Road and
Haddonfield/Berlin Road, at 482 foot depth and one million
gallon/day (MGD) pumping .capacity; and (2) Well #21, located
along Giggsboro Road, comprising of three actively pumping
wells at 1100, 998 and 1016 foot depths and 2, 2 a.id 1.1 MGD,
respectively.
All of these NJWC wells in Voorhees Township are. screened
within the Potomac-Raritan-Magothy-aquifer system, which is
separated, from the Cohansey aquifer by the Hor.nerstown/Navesink,
Marshalltown, Woodbury Clay and Merchantvilie confining zones.
Also, the NJWC wells are doubles-cased through the Woodbury Clay
formation in order to minimize the potential of cross-flow from
the upper aquifers to the Potomac-Raritan-Magothy aquifer.
The NJWC water supplied to Voorhees Township is regularly tested
by NJWC biannually for the presence of contaminants, more often
than is required annually by NJDEP's "A-280" public water supply
testing program. These sampling results have not indicated any
detectable levels of any tested contaminants.
III. Risk Assessment
This section is a general public health evaluation which follows
the guidelines established by EPA for risk assessments under
CERCLA. The risk assessment provides a quantitative estimate
of risk levels under existing conditions, in the absence of
further remedial action. This is used to determine whether any
additional remedial action at the site is: warranted. The risk
assessment was developed as follows: identify contaminants of
potential concern; describe potential pathways of exposure
associated with site contaminants; estimate levels of exposure
and determine populations affected; and characterize current
and potential risks to human health and the environment.
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Selection of Potential Contaminants of Concern
According to the SUperfund Public Health Evaluation Manual (EPA
1986)/ contaminants of concern are selected to focus the public
health evaluation on the contaminants most likely to pose health
risks. The following assessment of present site conditions is
provided to confirm that no potentially adverse health risks
exist at the site.
Through concurrence with NJDEP, EPA's Maximum Contaminant
Levels (MCLs), promulgated under the Safe Drinking Water Act,
and NJDEP's Interim Action Levels for Selected Organics in
Drinking Water have been established as the applicable or
relevant and appropriate requirements (ARARs) for the ground-
water in the vicinity of the site.
No organics of any significant concentration, according to EPA
and NJDEP ARARs, were detected in the soils, groundwater or
potable water supplies in the vi-cinity of the site during the
field investigation.
Analysis of the initial round of groundwater samples collected
at the site in April 1987 tentatively indicated that two metals,
lead and chromium, were above EPA's and NJDEP's drinking water
ARARs. This initial detection of lead and chromium was considered
questionable due to the detection of metals in the laboratory
blank.. As noted previously, confirmatory groundwater sampling
conducted in mid-August 1987 indicated lead and chromium, at 7
and 15 ppb, respectively, with no blank contamination (Table 1-A).
The EPA has not established action levels for chemicals of
concern in soils. The NJDEP has developed action levels for
certain metals in soils based on background or multiples of
background, metal concentrations. These .numbers are used in
State cleanup programs, both publicly and privately funded,
such as the Environmental Clea'nup Responsibility Act.
Of the metals found at the Cooper Road site, State soil action
levels have been established for two: chromium at 100 ppm, and
lead at 100 ppm. Concentrations of chromium and lead at the
Cooper Road site are well below these State action levels, at
a maximum of 6.4 and 4.7 ppm, respectively. All of the trace-
levels of metals found in the on-site soils were at levels
typically found in background soils throughout the State of
New Jersey (Table 1-B).
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Therefore, since no contamination in the underlying soils and
groundwater at the site has been detected above any applicable
or relevant and appropriate standard which would indicate a
potential health threat, there are no contaminants of concern
at this site.
Exposure Pathways
Since no residual contaminants from the vials were found to be
present in the soils or groundwater after the vials were removed,
potential exposure to residual contamination from the site
through the groundwater, surface water, soils and air appears
to be non-existent. Sampling results from the remedial
investigation confirm this determination.
The low, background levels of lead and chromium in soils at
the site do not have any direct contact health risk potential
because the levels detected were several orders of magnitude
lower than any levels which could potentially produce any
adverse health effects, according to EPA's Public Health
Evaluation Guidance, assuming either (a) inadvertent, and
unlikely, ingestion of 100 milligrams/soil/day for 50 days/year
for 30 years; or (b) normal daily dermal contacts. In addition,.
the owners of the site-have-previously removed approximately
forty vertical feet of the original soils at the. s.i.te.-during May
•1986, over which an estimated twenty feet of new fill has been
placed. • .
For the sake of caution, a conservative approach was adopted
utilizing a model to simulate the maximum impact associated
with a potential release of the trace levels of chromium and
lead detected in the soil into the groundwaters or surface
waters in the vicinity of the site. It was found that potential
releases of lead and chromium from site soils would dissipate
to concentrations below drinking water standards less than 1000
feet from the site's monitoring well. Since there-are no
receptors utilizing the surfac'e aquifer for drinking purposes
within 1000 feet of this well, it was concluded that no potential
adverse effects to human health or the environment exist nor
would occur in the future as a result of the release of trace
metals from the background soils into the groundwater.
Risk Characterization
A risk characterization assessment based on all available data
generated during the remedial investigation was conducted.
This assessment concluded that, because no contaminants of
potential concern exist in the groundwater or soils at this
site, no cancer, risk exceeding 10~6 for groundwater ingestion
or soils exposure exists. This indicates that one would not
expect even one incidence of cancer in a hypothetical population
of 1,000,000 people who could possibly ingest the groundwater
or be exposed to soils at the site.
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This conclusion was confirmed by the Agency for Toxic Substances
and Disease Registry (ATSDR), under the Centers for Disease
Control. ATSDR's August 28, 1987 Health Consultation concluded
that the groundwater does not pose a threat to public health.
Environmental Impacts
Because there were no residual contaminants left in the soils
or groundwater, there are no resultant environmental impacts
expected from the Cooper Road site. This determination of no
significant environmental impact is confirmed through comparison
of Ambient Water Quality- Criteria with concentrations of contam-
inants detected in the groundwater at the site (Table 1-A) .
The surface waters in the area which could have potentially been
affected by possible releases of contaminants from the soils
and/or groundwater at the site include the headwaters of the
north branch of the Cooper River located 1000 feet northeast of
the site, a stream 1000 feet southwest, and a stream located
2000 feet southeast of the site which feeds Cedar lake. Low
level, ubiquitous lead and chromium concentrations in the upper
aquifer and soils were revealed during the remedial investigation.
The model which determined the worst-case potential for release
of.lead and chromium from the background soils into the ground-
water at the site confirmed that no- potential, adverse environ-
mental impact exists.
IV.. ENFORCEMENT' ACTIVITIES' . •
As discussed previously, the. owners of the site property in
1984 performed the surface cleanup of the vials and surrounding
soils to NJDEP and EPA satisfaction. Since the generator(s)
of the vials have not been found, and because their placement at
the site appears to have been done without the knowledge of
the property owner, no additional enforcement actions are
anticipated.
V. COMMUNITY RELATIONS
Community involvement was solicited at "the conclusion of the
remedial investigation at the Cooper Road site. The Preferred
Remedial Action Plan with supporting attachments, which identified
EPA's and NJDEP's preferred remedial alternative of no further
action for this site, was released to the public information
repositories on August 28, 1987. The public comment period,
initiated on this date, solicited public comment through September
25, 1987. A public meeting was held on September 10, 1987 to
present EPA's preferred remedial alternative and provide an
opportunity for public participation. Town officials and
citizens who live in the vicinity of the site attended.
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Specific concerns raised during the public comment period,
including comments made at the public meeting, are addressed
in the attached Responsiveness Summary. It should be noted
that most of the public comments involved the nearby Buzby
Landfill. A transcript of the public meeting is available in
the Administrative Record located at the information repositories
and at the regional office.
VI. ALTERNATIVES EVALUATION
The remedial alternative for the Cooper Road" site was developed
and evaluated using the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980, as amended by the
Superfund Amendments and Reauthorization Act of 1986, and the
National Oil and Hazardous Substances Pollution Contingency
Plan (NCP), 40 CFR Part 300.
The Superfund legislation requires that each remedy selected for
a site must be protective of human health and the environment,
cost effective, and in accordance with statutory requirements.
Permanent solutions to toxic waste contamination problems are
to be achieved wherever possible. Under the NCP, specifically
40 CFR Part 300.68(j), the cost-effective remedy is the lowest
cost alternative that is technically feasible and reliable and
which effectively mitigates and minimizes damages to and provides
adequate protection of public health, welfare, and the environment
The- results of field investigations reveal chat no levels of
contaminants attributable to the contaminants known to have
existed prior to the removal at Cooper Road remain in the
environment at the site. Because EPA's and NJDEP'-s evaluation
of the cleanup performed at the Cooper Road site indicates that
there is no longer a source of contamination nor is there any
migration of contaminants in the air, groundwater, surface water
or soil, additional potentially feasible remedial actions such
as capping,.further soils removal and/or groundwater treatment
are not necessary to protect human health or the environment.
In addition, since there is no further potential for risk at
the site due to the lack of any residual contamination in the
surface soils or the groundwater at the site, no continued
monitoring of the shallow underlying aquifer is necessary to
address the possibility of unexpected off-site migration of
hazardous substances.
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VII. SELECTED REMEDY
As noted previously, cleanup activities conducted at the site
have effectively and permanently addressed any and all public
health or environmental concerns related to the Cooper Road
site. The selected remedy for the Cooper Road site therefore
calls for no additional remedial actions to be taken, and was
arrived at by evaluating all site data which were available
after completion of the remedial investigation. The remedy
was selected in accordance with the "statutory requirements
established in CERCLA and, to the extent practicable, the NCP,
The selected remedy complies with all legally applicable or
relevant and appropriate requirements in a cost effective
manner, and requires no treatment technologies or special
engineering considerations. The remedy requires no operation
and maintenance, no temporary storage requirements nor safety
requirements for implementation. The selected remedy is pro-
tective of human health and the environment.
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- Figxjre 1: Site Location Map
^ ~ "fc
* / _ — f ' % ,0*^ ^^f »
- - -
V .*..,.
(QUAD) CLCMCNTON,
SITE LOCATION MAP
COOPER ROAD SITE, VOORHEES TWP.t N.J.
SCALE: T-2000*
($
QUADRANGLC LOCATION
FIGURE 1
CX3RPORATONI.
> .A Halliburton Company
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Figure 2: Site Layout Map
WOODS Of VOOftHIf S
COOPf n ROAD Wf LL
SITE MAP
COOPER ROAD SITE, VOORHEI8 TWP., N.J.
{NOT TO •CAkll
FIQUAE t
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Figure 3: Geologic Cr^^ Sect ion Map
Approximate Location of
Cooper Road Site
oSE
Ml Laurel Sand
Weoonoh Formation
Potomac - Rarllan- Magolhy
Aquifer System
~ Ml la
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TABLE 1
RANGES OF CHEMICAL CONCENTRATIONS BY MEDIUM
Concentration ranges for detected organic and inorganic contaminants
in groundwater and subsurface soils are provided below. Ambient
Water Quality Criteria (AWQC) for the protection of aquatic life
are included in this table* The AWQC are an Applicable or Relevant
and Appropriate Requirement (ARAR) for protection from ingestion of
two liters of water and/or ingestion of 6.4 grams of aquatic organ-
isms daily for 70 years. Drinking water ARARs, developed from the
Safe Drinking Water Act "Maximum Contaminant Levels" (MCLs) are
also included. There are no federal ARARs for soil. However, the
State of New Jersey has established soil cleanup objectives which
have been used in its Environmental Cleanup Responsibility Act
(ECRA) program; these levels are included for comparison purposes.
Concentration ranges presented only represent the detected levels
of the various chemicals. No tentatively identified compounds are
listed. All water concentrations are in micrograms per liter
(parts per billion).
Table 1-A:. Sampling Data from Private Potable Wells and Site Well
WELL SAMPLE CONCENTRATIONS
CHEMICAL
volatile- organics
PCBs/ pesticides
acids/ dioxins
bis(2-ethylhexyl)
phthalate
aluminum
barium
berrylium
chromium
copper
iron
lead
sodium
vanadium
zinc
Site
Private
MCL
ND '
ND
ND
2.4
5190-81000
44-150
2.3-2.5
1 5-116"*
15-75
68-8860
7-105
1360-10200
7.4-170
8.4-149
ND
ND
ND
ND
37-102
12-59
ND
ND
ND-11
322-686
ND
1150-1800
ND
8.8-11
AWQC
ECRA
NA
NA
1000
NA
1000**
300**
50
NA
NA
5000**
NA
NA
NA
NA
16
18
NA
8.2
NA
NA
320
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
*
**
not available or applicable
questionable data due to blank contamination
contaminants which may adversely affect the aesthetic quality
of drinking water, such as taste, odor, color and appearance,
and which thereby may deter public acceptance as a drinking
water.
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-15-
Table 1-Bt Sampling Data from Soils
Chemical
Pesticides
PCB's
acids
dioxins
bis (2-ethylhexyl
phthalate
chloroform
arsenic
barium
berrylium
cadmium
chromium (total)
copper
lead
mercury
nickel
selenium
silver
zinc.
Sample
Concentration*
1984 1985 1987
State
Cleanup
Objective*
Average Soil
Concentration
'~ New Jersey
in
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
NA
NA
NA
NA
NA
NA
NA
NA.
NA,
NA
NA-
NA",
ND
ND
5.9
ND
8.7
7.2
5.2
4.9
ND
2. .9
ND
ND
9. .6
.039
7.6
.0023
ND
ND
ND
6.4
ND
4.7
ND
5. ,8
ND
ND
i a
NA
NA
NA
NA
NA
NA
20
400
1
3
100
170
250-1000**
1 •
100
4
5
35'0
not available
not available
not available
not available
not available
not available
5
not available
not available
1-4
5-48
0.5-53.6
1-180
0.147
11'. 1-86. 5
0.01-4
not" available
4-.5'-16.8
*
*«r
ND
NA
parts per million
depends on location within State
no detection
not applicable
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ULU4JK RDM) DCMP SITE
The U.S. Environmental Protection Agency (EPA) era ducted a public comment
period from August 29, 1987 through September 25, 1987 for interested parties
to ounaait on EPA's preferred approach for addressing the Cooper Road r>rnp
site. EPA also held a public meeting on Septenber 10, 1987 at the Voorhees
Township Hall to describe the preferred approach.
This responsiveness sunnary is required by Superfund policy for the
purpose of providing EPA and the public with a sunnary of citizen contents and
concerns about the site, as raised during the public uuimtait period, and EPA's
to those concerns. All of the contents summarized in this document
will be factored into EPA's final decision for addressing the Cooper Road Dump
site.
This responsiveness sunnary for the Cooper Road Dump site is divided into the
following sections:
I. Overview.. This- section provides., a brief description of the Cooper
Road Dump site and the cleanup actions taken to date.
Community Involvement and Concerns-. This- section • provides-
a brief history of community interest in the Cooper Road r>»"p site since
its discovery in 1982.
XII. fimmary of the Ma"ior Questions and Orroents P*^»jved Purina the
Coanent Period and EPA Responses to Garments. This section summarizes
najor questions and comments made verbally to EPA during the public
meeting and the public comment period, and provides EPA responses to
nts.
IV. Remaining Concerns. This section summarizes community concerns that EPA
should be aware of as they prepare to undertake the process of removing
the Cooper Road Dump site from the National Priorities List (NPL).
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- 2 -
z.
The Cooper Road Dump Site is located in Voorhees Township, New Jersey in the
north central part of Camden County. The site is approximately one quarter
mile frcn Cooper Road and is at the top of a 40-foot high sand bluff.
Numerous vials containing benzene, bis (2-chloroethoxy) methane, and
hexc^lorocyclopentadiene were discovered partially buried near the bluff in
1982. Ihe site was proposed by the state to be placed on the National
Priorities List (NFL) , a roster of the national hazardous waste sites, in
August 1983, and was formally added to the NFL in November 1984.
In May 1984, at the request of the New Jersey Department of Environmental
Protection (NJCEP) , the site owner removed the vials and visibly contaminated
soil to a depth of six inches below any containers. These wastes were placed
in two fifty-five gallon drums and transported to an amrwuJ hazardous waste
landfill in Pennsylvania. Upon completion of this removal action, soil
samples were analyzed and shown to be clean. Additional soil sampling in 1985
revealed no contamination. Subsequently, the* owner removed and backfilled the
area with approximately thirty feet of topsoil. Early in 1987 a groundwater
well was installed and sampled. Sampling of the well at that time revealed
elevated concentrations of lead. Because one of the samples identified as
containing lead was a "blank11 sample (a sample known to be uncontaminated and
used to. ensure the accuracy of the test results) , the test results for that
sampling round were rejected (i.e., not accepted as accurate). In 1987, EPA
conducted both soil, and groundwater sampling, that showed no residual
contamination . .
At the September 10, 1987 public meeting, EPA presented its preferred approach
for addressing the site. EPA's sampling of the soil and groundwater at the
site has now been completed and the results have confirmed that there is no
residual contamination from the vials at the site. EPA and NJLfclP agree that
previous cleanup at the Cooper Road Dump site has effectively and permanently
addressed public health and environmental concerns. Consequently, EPA and
NJEEP are recoanending that no further remedial actions be taken at the site,
and EPA would like to initiate procedures to delete the Cooper Road D>imp site
from the NFL.
H. BAOGRXND GN OTMKTIY HTODVBIBrr AMD CONCERNS
Local officials and residents have expressed concerns to NJEEP and EPA and
have contacted their state and local representatives have since the discovery
of the Cooper Road Dump Site in 1982. Community concern focused on the
following:
Potential health impacts of community exposure to tie contaminants
at the site. Residents have expressed concern that contaminants
released from the broken vials found at the site may have migrated
into the groundwater and exposed nearby residents to a health threat
through ingestion of contaminated groundwater.
-------
effects en baaing values moulting fro» tfce
bwd stigpB at having a Suparfund cite vittdn tte aa
ts hove expressed concern that housing values could
y decrease and that resale of hcuoos might be
difficult if the area is perceived to be contaminated with hazardous
of the site from the National Priorities List (NFL) .
Several residents and local officials expressed concern that since
the site does not pose a threat to public health and safety, it
should be renewed frcn the NFL.
A public oosment period was held from August 29, 1987 to Septeober 25, 1987 to
receive ocooents from the public regarding EPA's preferred approach for
addressing the Cooper Read Dump site. The public meeting was held on
September 10, 1987 at 7:00 p.m. in the Voorhees Township Han, Voorhees, Hew
Jersey. The Meeting was attended by EPA officials, nenbers of EPA's
contractor staff, local officials and interested residents.
TTT. SdtMRY GF QQESnCNS AND G9MBKTS MU&LVED CORING *n» FOBLIC CCfMENT
AND EFA'S BE5FC16E ID COMBOS
Apprcodjnately 35 interested area residents attended EPA's Septenber 10, 1987
public aecting. Ccnments and EPA responses nade during the Septeober 10
public meeting are sunnarized below and organized into the following
categories: .
A. *»•'*«•* "i*i activities;
B. Identification and roles of potentially responsible parties (PRPs)
and
C. Other
Several caments were received regarding Buzby landfill, a landfill in
Voorhees "township. These connents are sunmarized under Category C: Other
A. iflMUUAL ACTIvTTIES
1. CEMBiT: Several residents expressed concern that EPA's recent
sanpling at the duop site would not reveal contaminatian because the
site owner excavated more soil in 1986. Residents claimed that the
soils removed from the site in 1986 were contaminated and had been
improperly HSiygart of in a wetland area in the town.
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- 4 -
EPA explained that the vials along with all eon to a
dsyttl of six inches below any container were removed to an appiusnad
hazardous waste landfill in Pennsylvania. After the removal, soil
sanpling was conducted prior to any activities that would have
disturbed the soil. Subsequent soil and groundwater sampling shows
no evidence of residual contaminants at the site. Current
development on the site does not pose any risk to public health or
the environment.
2. COtSfT: Several residents inquired about details of randial
activities. They wanted to know who was responsible for requiring
and supervising the cleanup and how mch the site investigation and
cleanup had cost to date.
EPA RESPONSE: EPA stated that the cleanup was performed by the
owner of the property at the request and under the supervision of
the KJEEP. EPA added that the total cost of the site investigation
has not yet been determined, but it is estimated to be in the tens
of thousands of dollars.
3. CCmENT: Several residents questioned the validity of EPA
laboratory sanple results that were used to determine whether
contamination existed at the site. They referred to an incident
when EPA sent a "blank" water sample without contaminants to a
private testing lab in. 1987 and the results, reported it to be
EPA RESPONSE: EPA responded that all samples taken at hazardous
waste sites under EPA's Super-fund program are tested at an EPA
certified laboratory and oonrihirtPri under a rigorous protocol to
ensure that the results are accurate. EPA added that it is not
unusual for minor problems to occur during the testing pii;«**ss. In
this case, the sanple was rejected. EPA regularly inserts "blanks"
containing no contaminants and "spikes" containing contaminants, not
related to the site, tp ensure proper testing at all labs. EPA
stated that results of all tests will be sent to township officials
for their information.
AMD ROLES OF PCTENTIALIX RESFOCIBLE PARTIES (PRPS)
1. GOMENT: Many residents questioned the sequence of ownership of the
site.
EPA BE5KN5E: EPA stated that some confusion exists as to who now
owns the site. The current status and sequence of ownership can be
confirmed through local tax records.
-------
- 5 -
2. caiOIT: A resident asked who would be responsible for the cost
cleanup if the respcnsible party cannot be identified.
KPA raSPOGZ: EPA explained that financial responsibility for the
clean*) of a site in which the potentially respcnsible party (PR?)
remains unknown is oovered by a trust fund of federal nonies. if,
and when, a FRP is identified, EPA any aeek to compel the PRP(s)
through litigation or administrative order to pay the cleanup costs.
1. omBfT: Two residents and a local official believed that there was
not enough advance notice of the meeting.
EPA RESPCN5E: EPA stated that a news release was issued to a major
area newspaper, The Camden Courier Post. The meeting *?y> was
announced at a previous town meeting, at which the news media were
2. GCMffiMT: A resident asked how often HJLJtP tested drinking water to
ensure cleanliness.
EPA KESPCK5E: EPA explained that public water supplies generally
are^ tested quarterly and the- results are sent to the state which
keeps than on public record. ' • .
3. OOMENT: A resilient- expressed concern that, the Buzby Landfill (a
landfill in Voorhees Township) was not placed on the NFL when it was
evaluated in 1983.
EPA RESPCKSE: EPA explained that when the Buzby Landfill was
originally investigated in 1983, it did not score high enough on the
hazardous waste ranking system to be included on the NFL. EPA can
reevaluate the site for NPL status if current data show the site to
rank high enough and if the state requests the site to be nominated
for the NPL. It is the state's prerogative to provide EPA with
candidate sites to put on the NFL. EPA added that due to the great
interest expressed at the September 10 meeting, EPA will Hi en ice the
issue with the state. A IBUUIJ of the public cements at the
meeting will also be sent to the state to make then aware of the
level of concern. In addition, residents were told that they can
write their elected state and Congressional representatives about
their ouiLVitp.
4. GGMQIT: A resident and a local official both asked whether placing
Buzby landfill on the NPL would ensure quicker remediation of the
site.
EPA RESPCKSE: EPA respcndflrt that the state can be effective in
dealing with many hazardous waste sites without placing the sites
the NPL. In other cases it is apparent that placing a site on the
NPL expedites the remedial process.
-------
- 6 -
IV.
Residents ctatad that they are relieved that the Cooper Road Dump site will be
removed from the NPL. The residents, however, do have some remaining
that EPA should be aware of as it prepares to remove the Cooper Road
from the NFL. These concerns include;
The belief that property values have declined as a result of having
a Superfund site in the township. Farmer residents from the
vicinity of the Cooper Road Dump site ^ijtJmttH to have received less
than the market value for their homes when they moved. The
possibility of Buzby landfill becoming a Superfund site has
reinforced the residents' concern about property values in the area.
Some residents are still concerned about soil that was removed from
the site and used as fill in a township wetland area. This soil was
taken from the property that includes the Cooper Road site after the
vials and contaminated soil at the site were d-i«^*»ri of, but
residents were not sure if the situation had been fully addressed.
In reference to this concern, EPA has stated that EPA and NJEEP
sampling has consistently shown no residual contamination at the
site and consequently the situation has been addressed.
Residents would like the data on the groundwater and soil sampling
results.. In addition, they requested that', all. updated material en
the site to be forwarded to the township, so that it would be
available to all interested parties.
-------
: 15 P04
STATI OF NEW JERSEY
DCFARTMINT OF ENVIRONMENTAL PROTECTION
RICHARD T. DEWL1NC, fh.D., FX. COMMISSIONER
CN402
TRENTON, NJ. 03625
609-292-2115
2 8 SEP «87
Mr. Christopher J. Daggett
Regional Administrator
USEPA - Ration II
26 Federal Pl*f a
M«w Tork, N.Y. 10278
D*ar Mr. D«gg«tt:
Thl* !• to fonully notify th« United Staca* Environn«nt«l Protaction Agency
ehat th« Nav Jaraay Dapartacnt of Envirofloantal Protaceion baa raviaved ch«
draft Raeord of Dacitlon for tba Coopar Road Sita aad concur* vlth eha
racomaadad raaady.
In this ca«a> ao further remedial action* are considered appropriate. The
cleanup already conducted at the alte ha* effectively and ptraanently
addressed aay contamination problem* vhich previously existed,
Nav Jaraay fully appreeiatea the importance of the Record of Decision in cbe
cleanup proceas and vill continue to take all reasonable step* to ensur'
that the State's conaitments in this area are net.
Si
Ri
------- |