United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
E PA/ROD/R02-89/092
September 1989

       Is
Superfund
Record of Decision
Vineland State School, NJ

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50272-101
REPORT DOCUMENTATION i. REPORT no. 2.
PAGE EPA/ROD/R02-89/092
4. Tltf* and Subtitle)
SUPERFUND RECORD OF DECISION
Vineland State School, NJ
First Remedial Action - Final
7. Author(a)
9. Performing Organization Hunt and Address
12. Sponsoring Organization Hun* and Address
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
X Recipient's Accession No.
5. Report Oats
09/30/89
8.
8. Performing Organization Rept No.
10. ProjecVTaak/Work Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
13. Typa of Report * Period Covered
800/000
14.
 IS. Supplementary Note*
 16. Abstract (Limit: 200 worda)
  The 195-acre  Vineland State School site  is  in the northern part of the city  of
 Vineland, Cumberland County, New Jersey.   The  site,  commonly referred to  as the
 Vineland Developmental Center, is a residential treatment facility for mentally
 handicapped women and is comprised of numerous buildings to care for the  1,300
 residents.  In addition to the facility,  the site includes farmland, a hospital care
 facility, facility maintenance shops, and an unregulated incinerator.  The  site
 overlies three aquifers which serve as major sources of drinking water for  the  county.
 There were numerous allegations of improper  waste disposal at five separate onsite
 subsites.  Subsite 1,  a former landfill which  has since been used to covered  and
 vegetated, reportedly had been used to dump  mercury- and arsenic-contaminated
 pesticides.  Data from the remedial investigation, however, could not confirm these
 allegations.   At  subsite 2, PCB-contaminated fluid spilled and spread over  a  1-acre
 area.  The State  remediated subsite 2 in  1988, which included demolishing and disposing
 of approximately  3,900 tons of PCB-contaminated soil and concrete pads offsite.
 Subsite 3 was  a garbage dump for 10 years before being backfilled and used  as a
 baseball field.    Subsites 4 and 5 were pits where transformer oils and chemicals were
 dumped in the  mid 1950s.  Investigation results of the subsites excluding subsite 2,
 which was cleaned up in 1988, revealed only  low levels of contamination.   (Continued on
 next page)	
 17. Document Analysis a. Descriptor*
   Record of Decision - Vineland  State  School,  NJ
   First Remedial Action - Final
   Contaminated Media: none
   Key Contaminants:   none

   b. kfentifiers/Open-Ended Terms
   c. COSAT1 Raid/Group
18. AvallataUty SUtamsrt
19. Security CUsa (This Report)
None
20. Security CUsa (This Paos)
None
21. No. of Pages
104
22. Price
(SssANSt-Z39.ie)
                                     Se» Inttructioru on Hewers*
      rUHM 2/« \4-/7)
(Formerly KTIS-35)
      t of Conwrwr ov

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EPA/ROD/R02-89/092
Vineland State School, NJ .

16.  Abstract (Continued)

 The selected remedial action for this site is no further action.  The risks posed by the
 ontamination in these areas are within the acceptable range as determined by the State
 nd EPA.  As a precautionary measure, however, ground water and disposal areas will be
monitored.  No costs were specified for this remedial action.

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                       DECLARATION STATEMENT

                        RECORD OF DECISION

                      Vineland State School


Site Name and Location

Vineland State School, City of Vineland, Cumberland County,
New Jersey

Statement of Basis and Purpose

This decision document presents the selected remedial action for
the Vineland State School site, which was chosen in accordance
with the requirements of the Comprehensive Environmental
Response, Compensation and Liability Act of 1980 (CERCLA), as
amended by the Superfund Amendments and Reauthorization Act of
1986 (SARA) and, to the extent applicable, the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP).  This
decision document explains the factual and legal basis for
selecting the remedy for this site.

The State of New Jersey concurs with the selected remedy.  The
information supporting this remedial action decision is contained
in the administrative record for the site.

Description of the Selected Remedy

The selected alternative for the Vineland State School site is to
take no further remedial action.  The Vineland site includes five
separate areas or subsites.  Of the five areas investigated, only
subsite 2 was found to be significantly contaminated.  In 1988,
PCB-contaminated soils in this area were cleaned up by the New
Jersey Department of Environmental Protection.  In addition, a
public water supply was extended to service homes in the vicinity
of the site.

Investigation results of the four other areas indicated very low
levels of contamination.  The risks posed by the contamination in
these areas is within the acceptable range as determined by the
New Jersey Department of Environmental Protection and the
Environmental Protection Agency.  Therefore, no further remedial
action is considered necessary.  However, as a precautionary
measure, a program to monitor groundwater and the existing
disposal areas will be implemented.  This monitoring program will
be provided to the public for comment prior to implementation.
The New Jersey Department of Health and the Agency for Toxic
Substances and Disease Registry concur with the selected remedial
action.

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                               -2-
Declarations

In accordance with the requirements of CERCLA, as amended by
SARA, and the NCP, I have determined that no further remedial
action is necessary to protect human health and the environment
at the Vineland State School site.  However, a program to monitor
groundwater and the existing disposal areas will be implemented.

Because hazardous substances will remain on-site, a review will
be performed within five years to ensure that the selected
remedial action provides adequate protection of human health and
the environment.
William J/Mu'sz#ri>ski/ P.E.               DateT
Acting Regional Administrator

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                         DECISION SUMMARY

                      VINELAND STATE SCHOOL

                       Vineland,  New Jersey


I. Site Location and Description

The Vineland State School is located in the northern part of the
City of Vineland, Cumberland County, New Jersey (see Figure 1).
The site includes five separate areas or subsites and is
approximately 35 miles west of Atlantic City.  It was placed on
the National Priorities List in December 1982.  The site is
currently referred to as the Vineland Developmental Center.

The Vineland Developmental Center is a residential treatment
facility for mentally handicapped women operated by the New
Jersey Department of Human Services.  The 195 acre site is
comprised of numerous buildings to house, feed, educate and care
for the needs of the approximately 1300 residents at the
institution.  Also, the facility has the administration and
maintenance facilities to support the institutions' operation, as
well as large open areas for recreational purposes.  Vineland
Children's Residential Treatment Center (the location of subsite
3) is a short-term counseling and treatment center for
emotionally disturbed teenagers operated by the New Jersey
Department of Human Services.

Subsites 1, 2 and 5 are located on the grounds of the Vineland
Developmental Center (VDC).  Subsite 4 is located on a vacant lot
owned by the VDC.  Subsite 3 is located approximately two
thousand feet north of subsite 4 on Vineland Children Residential
Treatment Center (VCRTC) property.  All five areas or subsites
are situated within a mile northeast of the intersection of Main
Road and Landis Avenue.

The area surrounding the Vineland State School is primarily
residential, on land that was formerly orchards and agricultural
fields.  This region of southern New Jersey historically was one
of the most intensively farmed areas of the eastern United
States.  Cumberland County is located in the Coastal Plain
physiographic province.  This area is characterized by level to
gently sloping topography.  Located almost entirely in the
Delaware River basin, Cumberland County land surface consists of
a broad, silty sand and gravel plain gently sloping toward the
Delaware Bay.  Elevations in the Vineland area range from 30-100
feet above mean sea level.  Although occasional pits or small
depressions are found throughout the county, most of these are
manmade and were created by mining operations for sand used in
the glassware industry*

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Three aquifers are important in the Vineland area.  The uppermost
Bridgeton formation, which ranges in thickness from 0 to 30 feet,
is not generally used as a major aquifer.  For the most part, it
lies above the water table.  This formation serves as a
collecting unit for the Cohansey-Kirkwood aquifer, below, where
communication is not impaired by clay lenses.  The Cohansey-
Kirkwood aquifer is a major source of potable water for
Cumberland County.  Except for areas partially confined by clay
layers, this aquifer is characterized by a high permeability, a
relatively thick saturated zone, a great capacity to accept
recharge, and the ability to yield abundant supplies of water.
Throughout most of the area, there is hydraulic interconnection
from the ground surface to 180 feet.  However, there is a local
clay layer present 58 to 66 feet below the surface.

The lower Kirkwood aquifer is separated from the Cohansey-
Kirkwood aquifer by a semi-confining clay layer of lignitic clay
about 30 to 90 feet thick.  Wells drawing from this aquifer are
screened 200 to 350 feet below the surface.

Private wells in the area (maximum depth - 90 feet) tap the
Bridgeton and Cohansey-Kirkwood aquifers.  The City of Vineland
has 13 to 15 wells varying in depth from 100 to 300 feet, some of
which may tap the lower Kirkwood aquifer.

Site History and Enforcement Activities

The Vineland Developmental Center has been in existence as a
residential treatment facility for mentally handicapped women
since the late 1800's.  Until the 1960's, the VDC was nearly
self-sufficient, relying on its own farming and livestock for
most food needs.  A hospital care facility as well as maintenance
shops for painting, carpentry and plumbing are located on the
site.  Water needs were met by two wells on the grounds up until
1970, when the facility started receiving water from the City of
Vineland.  An unregulated incinerator existed at the site and
there were allegations of improper waste disposal at subsites,
which will be discussed below.

As a result of allegations made by current and former employees
of the VDC, investigations on behalf of the New Jersey Department
of Health Services (NJDHS) were conducted beginning in March
1980.

These investigations were carried out by the New Jersey
Department of Environmental Protection (NJDEP), the United States
Environmental Protection Agency (EPA) and the City of Vineland.
Detailed accounts of activities on a subsite basis are presented.

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Subsite 1

This subsite, located at the eastern portion of the VDC grounds,
is vest of the campground at Spring Road and east of the
recreational pavilion.  Figure 2 shows the location of all five
subsites.  The subsite is flat and covered with what appears to
be healthy vegetation.  It comprises approximately 3 acres and
slopes gently to the north.

Subsite 1 is the only subsite to be ranked on the EPA National
Priorities List (NPL).  The site received a Hazardous Ranking
System score of 40.84 and was ranked 237 of the 418 NPL sites.
It was placed on the NPL in 1982.  The site was a landfill from
the 1920's to the late 1950's.  Subsequently, the landfill was
covered with a foot of soil and vegetated.

This subsite was ranked on the NPL based allegation of dumping of
mercury- and arsenic-based pesticides and the potential impact of
mercury on private drinking water wells near the site.  However,
during the RI, there were no data which confirmed these
allegations.

The NJDEP responded, beginning in March 1980, with the following
actions:

   - Obtaining six rounds of potable water samples;
   - Installing three monitoring wells;
   - Performing a conductivity survey;
   - Performing exploratory excavations; and
   - Collecting two rounds of surface soil sampling.

Phase I of a Remedial Investigation was. conducted from December
1986 through May 1987.  These activities included —

   - Installing four observation wells to a depth of 35 feet.
   - Performing geophysical surveys including magnetometer and
     ground penetrating radar.
   - Sampling three potable wells.
   - Obtaining samples from 18 soil borings.
   - Installing two additional monitoring wells.

In addition, on July 12, 1989, the Emergency Response Team (ERT)
of the EPA collected 16 soil samples.

Subsite 2

Subsite 2 is located in the northwest part of the VDC complex.
It was a storage area for three electrical transformers.

In the mid 1970's, the transformers were removed by a scrap metal
company.  During the process, polychlorinated biphenyl (PCB)-
contaminated fluid was spilled.  Since the time of the spill,

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contaminated fluid was spilled.  Since the time of the spill,
both vehicles and natural transport mechanisms (i.e., rainwater
runoff, wind erosion) spread PCB contamination over a 1-acre
area.

The VDC notified NJDEP of the spill in late 1982.  In January
1983, the first of ten rounds of sampling was conducted to
confirm and identify the extent of the contamination.
Subsequently, the NJDEP contracted with E.G. Jordan Company to
delineate the contamination and prepare a remedial design for the
removal of the PCB-contaminated material„

The remedial action at VDC was performed for the NJDEP by
Chemical Waste Management (CWM) of Oak Brook, Illinois.  The on-
site work began in June 1988 and was completed in October 1988
using state funds at a cost of approximately $1.5 million.  This
action included the demolition, removal, transportation and
disposal of approximately 3,900 tons of PCB-contaminated soil and
concrete pads.  In addition, the removal, transportation and
proper disposal of approximately 112 tons of gasoline-
contaminated soil, 6 tons of asbestos materials, 81 tons of
building rubble and debris, and 22 tons of additional
construction debris were undertaken.  All materials was disposed
of at the CWM hazardous waste landfill facility in Model City,
New York.

Also included in this action was sampling of all excavated areas
to ensure established cleanup levels were achieved, the
installation of a fence, and construction of an asphalt cap and
drainage system at the remediated area.

Subsite 3

Subsite 3 is located on a five acre area within the Vineland
Children's Residential Center, northeast of the intersection of
Maple Avenue and Becker Drive.  According to information provided
to the NJDEP, this area was used by the Vineland State School as
a garbage dump for approximately ten years.  Based on a 1963
aerial photograph, the site contained a pit approximately 50 X
100 feet with an access road to Maple Avenue.  Residual chemical
substances used by the VDC, particularly those used in farming
operations, is alleged to have been disposed at this site.
According to Vineland Developmental Center employees, the pit
received incinerator and coal ash, "unburnable wastes", carpentry
wood waste, kitchen garbage, paint waste and thinners.  Since
1963, the pit was backfilled and a baseball field was built on
the south side of this subsite.

As a result of the information received by NJDEP, three
monitoring wells were installed and groundwater samples were
collected in May 1984.

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     - Two rounds of composite surface soils were conducted in
       April and May 1985; and

     - In July 1989, the EPA's ERT collected 15 soil samples.


Subsite 4

Subsite 4 is located east of the VDC grounds and Spring Road and
south of Maple Avenue.

The Vineland State School used this site as a soil excavation
pit.  A former employee informed the Vineland Health Department
that, during the period from 1952 to 1957, he was ordered to dig
a pit and dump gallons of oil from two transformers.  Another
small area was reportedly used to dispose of human body parts
packed in glass jars filled with formaldehyde.  The site was last
used by the New Jersey Department of Transportation as a
maintenance yard from 1966 to 1970.  As a result of the above
allegations, the NJDEP installed three monitoring wells and
obtained split-spoon soil samples in May 1984.  Also, in April
1985, the first of two rounds of composite surface soil samples
were obtained by the NJDEP.

Subsite 5

Subsite 5 is an approximately 6,000 square foot area in a vacant
lot, near a water tower in the northeast corner of the parking
lot.  A former VDC employee informed the NJDEP that he was
directed by the Vineland Developmental Center to dig a pit ten
feet deep for the purpose of disposing of a truckload of chemical
substances contained in bags and rusted five-gallon metal
containers.  As a result of this allegation, the following
actions were taken:

     - In May 1984, a monitoring well was installed and sampled;

     - Composite split spoon samples were taken;

     - In April 1985, the first of two composite surface soil
       samples were obtained; and

     - In July 1989, the EPA's ERT collected 2 surface soils
       samples.

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Highlights of Community Relations

The remedial investigation and feasibility study (RI/FS) report
and the Proposed Plan for the vineland state School site were
released to the public for comment on September 8,  1989.  These
two documents were made available to the public in the
administrative record and an information repository.  The
administrative record is maintained at the EPA Docket Room in
Region II, Jacob Javits Federal Building, 26 Federal Plaza, New
York, New York 10278.  The main information repository is located
at the Vineland City Library, 1058 East Landis Ave, Vineland, New
Jersey 08630.

The notice of availability of the documents was published in the
Vineland Daily Journal on September 7 and 8, 1989.   The public
comment period on the RI/FS report and proposed plan extended to
September 28, 1989.

An informal information meeting was held on September 20, 1989 to
brief local and school officials, and some concerned residents
on the results of the investigation at the site.  In addition, a
formal public meeting was held on September 25, 1989.  At this
meeting, representatives from the New Jersey Department of
Environmental Protection answered questions about problems at the
site and the no-further-action alternative under consideration.
Responses to the major comments received during this period are
included in the Responsiveness Summary, which is attached to this
Record of Decision.

SUMMARY OF SITE CHARACTERISTICS

Subsite 1

Subsite 1, a former landfill, is currently an open grassy field.
Soil borings confirmed the presence of the landfill.  Fill
material, such as sand, ash, metal, leaves, wood, glass and
ceramic material, was encountered to a depth of 9 feet in the
central portion of the site.  Prior to the RI/FS, investigations
of the soil indicated the presence of polynuclear aromatic
hydrocarbons (PAHs) and metals including arsenic, lead, mercury
and zinc at levels above or near background.

In Phase I of the remedial investigation and feasibility study,
the following chemicals were detected in the surface soils:
PAHs; p,pl-dichlorophenyl trichloroethane (DDT), and its
transformation products — p,pl-dichlorophenyl dichloroethene
(DDE) and p,pl-dichlorophenyl dichloroethane (DDD); dieldrin;
lead; mercury; arsenic and chromium.

The highest concentrations of DDT and its transformation products
(DDD and DDE) were detected at the northwestern boundary of the
site at a depth of 0 - 6 inches below the surface.   The highest

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dieldrin concentrations were detected at the center of the site
at 0 to 6 inches.  The highest concentrations of PAHs and
inorganics were also detected at the center of the site (see
Table 1 and Figure 3).

ERT surface soils samples collected in July 1989 showed maximum
levels for DDT at 115 parts per billion (ppb), DDD at 30.7 ppb,
DDE at 100.9 ppb, and dieldrin at 63.6 ppb.

Potable well sampling was conducted from 1980 to 1984 for
homeowners residing in the area adjacent to the site.  As a
result of the sampling, mercury was observed in one well at a
concentration of 1 ppb.  In a second round of sampling at 105
Spring Road, the concentration was 2.2 ppb, slightly above the
EPA Primary Drinking Water Standard of 2 ppb for mercury.  A
third round of sampling conducted by the Vineland Health
Department showed 2.0 ppb.  Arsenic was detected at a
concentration of 39 ppb. at 351 Spring Road during the second
round of analysis.

Because of the concentrations of mercury detected above the
Primary Drinking Water Standards in the potable well at 105
Spring Road and the potential for mercury migration toward the
Spring Road residents from the alleged mercury dump site, NJDEP
provided for the installation of public water to homes not
already connected.

During the remedial investigation, two rounds of groundwater
samples were obtained from monitoring wells.  The results of the
first round of samples showed only low levels of metals.  The
second round of groundwater results indicated levels of arsenic
in MW-3 at 90 ppb.  This level of arsenic is above the EPA
Primary Drinking Water standard of 50 ppb.

A conductivity survey was performed to determine the locations of
conductive wastes.  Test pits were dug in those areas where
anomalies were found to a depth of 12 to 15 feet.  Soil samples
were collected and composited from each test pit.  Waste samples
were also collected and analyzed.  No significant deposits of
buried waste were overlooked.

The analysis of the waste samples revealed five heavy metals as
primary contaminants of concern:  arsenic; cadmium; lead;
mercury; and selenium.

Organic compounds detected in the waste samples at levels above
background soils were di-n-butyl phthalate (4.0, 2.5 and 1.1
parts per million (ppm), compared to 0.3 ppm in the background
sample), and isophorone (22 ppm compared to no background
detection).

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Subsite 2

Ten rounds of soil sampling were performed from January 1983 to
April 1987 to determine the horizontal and vertical extent of PCB
contamination resulting from the former spill of transformer oil.
The PCB data collected as a result of these sampling events were
used to prepare design documents for the subsequent cleanup of
subsite 2.

All of the contaminated material in subsite 2 has been removed
and disposed of at appropriate facilities.  Confirmatory sampling
after completion of the action showed that cleanup goals were
achieved and no further remediation was required.  Therefore, no
further characterization of subsite 2 was made.

Subsite 3

Subsite 3, a former landfill, is currently an open grassy field
with a baseball field in the southeastern portion.  Soil borings
confirmed the presence of the landfill down to a depth of 16.5
feet below the surface (see Figure 4).  Fill material was similar
to that found at subsite 1.

The following chemicals were detected in the surface soil at this
site:  PAHs; DDT and its transformation products  (DDD and DDE);
lead; arsenic; chromium; di-n-butylphthalate; bis (2-ethylhexyl)
phthalate; dieldrin and endosulfan.  All of the chemicals were
detected at depth.  The range of concentrations detected for each
chemical by depth is presented in Table 2.

Inorganic surface soil (0-6 inches) results from the first round
of sampling in April 1985 showed calcium, magnesium, nickel and
potassium above the background levels.  Calcium concentrations
above background (876 ppm) were 3,160, 1,300 and 2,500 ppm.  The
nickel concentration was detected at 78 ppm, which is above the
background level of 6.3 ppm.

ERT soil sampling, completed in July 1989, showed maximum
concentrations of DDT at .025 ppm, DDD at .003 ppm, DDE at .024
ppm, dieldrin at .032 ppm, and lead at 220 ppm.

Groundwater sampling from subsite 3 showed arsenic at a
concentration of 54 ppb, 1,1-dichloroethene (DCE) at 18 ppb, and
trichloroethene (TCE) at 23 ppb.

Subsite 4

Subsite 4, a former gravel pit and New Jersey Department of
Transportation maintenance yard, is currently an open grassy lot
with a portion of the site serving as a drainage basin (see
Figure 5).  Transformer oil was allegedly disposed of at this
location.  Investigations of surface soils revealed one sample

                                8

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containing lead.  RI/FS Phase I investigations showed the fol-
lowing chemicals in the soil samples:  DDT and its transformation
products  (DDD and DDE); dieldrin; lead and chromium.  The range
of detected concentrations for each chemical are presented in
Table 3.

Results of the first round of water samples indicated slightly
elevated levels of antimony at 11 ppb, arsenic at 13 ppb, total
chromium at 20 ppb, lead at 10 ppb, and total phenols at 10 ppb.
On September 27, 1984, the monitoring wells were resampled.
Results showed the presence of fluoro-trichloromethane up to a
level of 21 ppb, bis (2-ethylhexl) phthalate at 23 ppb,
diethylphthaiate at 44 ppb, 1,1-dichloroethane (DCA) at 11 ppb,
and 1,1,1-trichloroethane  (TCA) at 10 ppb.

The first round of surficial soil sampling, taken in April and
May 1985, showed elevated levels of calcium at 15,400 ppm
(background-?20 ppm), and magnesium 9,050 ppm (background-433
ppm) .

A second round of surface soil samples showed elevated levels of
chromium at 36 ppm (5 ppm background), copper at 120 ppm (21 ppm-
background), and lead 260 ppm (36 ppm background).

Subsite 5

Subsite 5, a portion of the former agricultural area of the VDC,
is currently an open field (see Figure 6).  Pesticides contained
in bags and metal containers were allegedly buried at this site.
The following chemicals were detected in the soil:  DDT and its
transformation products (DDD and DDE); chromium; lead and PAHs.
The range of detected concentrations for each chemical is
presented in Table 4.

The first round of analysis of water samples for the monitoring
wells showed low concentrations of antimony at 14 ppb, arsenic at
22 ppb, zinc at 150 ppb, and cyanide at 23 ppb in the
groundwater.  A second round of samples for organic analysis
showed diethylphthalate at 31 ppb, fluorotrichloromethane at 90
ppb, TCE at 26 ppb, and DCE at 18 ppb.

The metals analysis for the split-spoon soil sample showed
arsenic at 1.9 ppm, total chromium at 6.4 ppm, lead at 5.4 ppm
and total phenols at 0.15 ppm.  Sample results from the two
composite surface soil samples did not show any chemicals at
levels greater than background.

ERT surface soil samples, collected in July 1989, showed maximum
concentrations of DDT at 139 ppb, DDD at 34.2 ppb, and DDE at
249.9 ppb.

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SUMMARY OF SOIL AND GROUNDWATER SAMPLING RESULTS

The purpose of performing the remedial investigation activities
was to expand the data base as well as to improve the data
quality for samples obtained at the VDC site.  Data obtained
prior to the remedial investigation lacked the quality control
necessary to demonstrate the unequivocal presence and
concentration of chemicals.  Tables 20-22 show the chemicals
found during the remedial investigation, background levels and
New Jersey soil action levels.

The metals data shows that all concentrations are below the New
Jersey action levels.  The state level for lead includes a range
from 250 - 1000 mg/kg.  The Agency for Toxic Substances and
Disease Registry currently considers lead levels above 1,000
mg/kg a health risk.

With the exception of one sample, all pesticide results were
considered to be within the New Jersey soil action level.  DDE
was detected at subsite 3 at 21 mg/kg.  Although the State does
not have a specific action level for DDE, the concentration of 21
mg/kg can be considered elevated.  However, the sample was
obtained as a composite from 0-12 feet.

The results of samples tested for polynuclear aromatic
hydrocarbons (PAHs) show only elevated levels at subsite 3
obtained at depths 0 - 12 feet.  All other sampling results
indicated PAHs at concentrations below the New Jersey soil action
levels.

The groundwater data for the VDC site is summarized in Table 23.
For subsite 1, pre-remedial investigation data showed elevated
levels of methylene chloride (suspected laboratory contaminant)
and arsenic to levels of 90 ppb.  Phases 1 and 2 of the remedial
investigation failed to detect any arsenic.  However, one sample
found nickel at a level of 41 ppb.  The New Jersey Safe Drinking
Water Act maximum contaminant level (NJSDWA MCL) is 13.4 ppb. The
results of sampling the other four monitoring wells at subsite 3
failed to detect any nickel.

The results of initial investigations of the subsite 3
groundwater showed elevated levels of arsenic at 54 ppb and the
volatile organics, 1,1-dichloroethene and trichloroethene at
levels ranging from 15 ppb to 23 ppb.  Phase I RI data failed to
detect any arsenic or volatile organics in the groundwater.
However, the data did indicate nickel at 179 ppb.

Pre-remedial investigation data showed levels of volatile
organics including 1,1-dichloroethene at 11 ppb.  This level
exceeds the NJSDWA MCL of 7 ppb.  Sampling during phase 1 of the
remedial investigation did not detect any volatile organics.


                                10

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Pre-remedial investigation sampling of subsite 5 monitoring wells
detected the volatile organics, trichloroethene and 1,1-
dichloroethene.  Subsequent sampling during the remedial
investigation failed to detect any volatile organics.

SUMMARY OF SITE RISKS

There were originally five distinct areas of contamination at the
Vineland Developmental Center.  Based on results of the Remedial
Investigation, none of the allegations of illegal dumping have
been substantiated.

Subsite 2 was found to have PCB-contaminated soil.  This site has
since been cleaned up by the NJDEP in 1988.  Subsequently, an
extensive post-remediation sampling effort was performed (97
samples) to determine the effectiveness of the soil cleanup.  The
results of this sampling episode showed that the site was
remediated to the established target levels (1 ppm PCBs in soils,
5 ppm PCBs in soils underlying the asphalt cap).  Therefore,
subsite 2 was not evaluated as part of the risk assessment.
In terms of groundwater, inorganic chemicals are the only
confirmed compounds detected.  Subsurface soils at subsites 1 and
3 contained what might be expected from former ash landfills,
namely, inorganics and PAHs.  Low levels of several pesticides
were detected in surface soils at subsites 1 and 3 as well.  At
subsites 4 and 5, contamination is limited to low levels of
inorganics and pesticides found in surface soils.

The chemical concentrations reported in the soils and ground-
water of subsites 1, 3, 4 and 5 were evaluated to develop a
subset of chemicals of concern.  As a result, several chemicals
detected at low concentrations were not included among the
chemicals of concern.  Phthalates were determined to be the
result of laboratory contamination.  Chromium and arsenic
concentrations were well-within New Jersey background soil
levels.  With one exception, pesticides were all well within New
Jersey background soil concentrations.  Four classes of chemicals
were identified in soils — PAHs (carcinogenic and non-
carcinogenic) , lead, mercury, and DDE.  The chemicals of concern
in the soils by site are as follows:

     Subsite No. 1- PAHs (carcinogenic and non-carcinogenic)
                    Lead
                    Mercury

     Subsite No. 3- PAHs (carcinogenic and non-carcinogenic)
                    Lead
                    DDE

     Subsite No. 4- Lead

     Subsite No. 5- None

                                11

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Average and maximum concentrations were determined for each
chemical of concern at each site.  Also, concentrations at two
different soil depths were evaluated:  zero to two feet; and zero
to twelve feet.  These represent two different potential exposure
scenarios.  The shallow soil concentrations represent those for
current site conditions and use.  The deeper soil concentrations
are those to which humans could potentially be exposed during
excavation activities.

The chemicals of concern and their corresponding concentration
values for the four subsites are presented in Table 5.

Groundwater Exposure Assessment

During previous investigations, NJDEP identified nine private
wells adjacent to the VDC.  Mercury was found at levels above the
maximum contaminant levels at one of the homes.  The level found
at this home was 2.2 ppb which is slightly higher than the
NJSDWA MCL of 2.0 ppb.  Because of the concentration of mercury
detected slightly above the NJSDWA MCL and the concern of mercury
migration towards the other residences from the alleged mercury
dump site, NJDEP provided for the installation of public water to
houses not already connected.  According to the NJDEP, there are
no longer any residential wells in use in the immediate vicinity
of the site.  The Vineland Water District draws from the lower
Kirkwood-Cohansey aquifer.  Due to the depth of the wells, and
other hydrogeologic conditions, these wells will not likely
become contaminated.

However, it should be noted that numerous rounds of groundwater
samples were collected from monitoring wells installed at each
subsite prior to and during the remedial investigation.  In some
cases, the resulting groundwater data indicates that maximum
contaminant levels (MCLs) are exceeded.  However, the data shows
a number of inconsistencies in the identification of compounds
and concentrations.  For instance, during the pre-remedial
investigation work, trichloroethene was detected in three
monitoring wells at subsite 3 at levels ranging from 15 to 23
ppb.  Subsequent sampling during the remedial investigation
failed to detect any trichloroethene.  Notwithstanding the
possible groundwater contamination, it is unlikely that the low
levels detected in the shallow monitoring wells found on-site
would impact the water quality of the lower aquifer.  Therefore,
there are no current human health risks associated with exposure
to groundwater.
                                12

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Soil Exposure Assessment

Subsite 1

Subsite 1 is the most accessible to VDC residents.  It is
situated across the street from residential dormitories and
surrounded by a campground, playground, a pavilion and public
soccer field.  VDC residents are the population likely to
experience the greatest degree of exposure to surface soils.
Dermal contact and inhalation exposure are limited by the grass
cover.  Off-site residents may also be exposed to surface soils.
VDC employees are another group that come in contact with subsite
1, especially workers responsible for routine grounds
maintenance.

In addition, a potential for exposure exists if new construction
takes place at this site.  Construction workers themselves would
be exposed, and during excavation, the potential exists for dust
to be generated and thereby expose population downwind.  Air
dispersion modeling and a downwind inhalation exposure scenario
were developed for VDC residents.  Tables 6 through 10 identify
some of the assumptions made for these analyses.

Subsite 3

Like subsite I, subsite 3 is an open grassy field with no areas
of exposed soil.  Therefore, direct contact and ingestion is
minimized by the grass cover.  Nevertheless, conservative
exposure scenarios were developed for incidental ingestion and
dermal contact with surface soils by VCRTC clients and off-site
children.  Because the site is situated at one end of a
recreation area on VCRTC grounds, digging or other disruption of
topsoil is not expected.  Consequently, exposure scenarios were
not developed for VCRTC employees.  An exposure scenario for
construction workers was not developed because, according to the
VCRTC superintendent, additional building construction is not
planned.  Most probable case exposure scenarios were developed
for off-site children and are presented in Table 7.  Future
construction worker and fugitive dust inhalation scenarios were
not developed because no future construction is planned.

Subsite 4

The location of subsite 4 in the middle of a residential property
and its history as a former gravel pit combine to yield an
attractive play area for nearby children.  An exposure scenario
for age group 4- to 12-year olds was developed and is presented
in Table 7.  Future development is expected.  Given its location,
it will likely be sold and residential properties will be
constructed on it.  Therefore, a future construction worker
scenario was developed identical to subsite 1 and is presented in


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Table 9.  A future scenario for inhalation of fugitive dusts was
also developed and is presented in Table 12.

Subsite 5

Subsite 5 is a small, poorly defined site north of the water
tower and south of the former sewage digestion house.  The site
lies at the edge of a former agricultural field that is now
overgrown with weeds and alfalfa.  There are no organized
activities and the area is not frequented by residents.  For
purposes of this risk assessment, conservative estimates of
exposure frequency of once-per-month were chosen for VDC
residents.  All other exposure parameters for the soil ingestion
and dermal contact scenario are identical to those used for
subsite 1.  Access and use of subsite 5 by off-site children and
VDC workers is expected to be less than for subsite 1.  However,
scenarios for surface soil exposure from subsite 1 were used for
subsite 5 (See tables 7*and 8).  Contaminants of concern were not
detected above background at subsite 5.  Therefore, future
construction worker and fugitive dust scenarios were not  .
developed.

Toxicity Assessment

Cancer potency factors (CPFs) have been developed by EPA's
Carcinogenic Assessment Group for estimating excess lifetime
cancer risks associated with exposure to potentially carcinogenic
chemicals.  CPFs, which are expressed in units of (mg/kg/day)-1,
are multiplied by the estimated intake of a potential carcinogen,
in mg/kg/day, to provide an upperbound estimate of the excess
lifetime cancer risk associated with exposure at that intake
level.  The term "upperbound" reflects the conservative estimate
of the risks calculated from the CPF.  Use of this approach makes
underestimation of the actual cancer risk highly unlikely.
Cancer potency factors are derived from the results of human
epidemiological studies or chronic animal bioassays to which
animal-to-human extrapolation and uncertainty factors have been
applied.  Cancer potency factors for the VDC chemicals of concern
are listed in Tables 14, 15, and 16.

Reference doses (RfDs) have been developed by EPA for indicating
the potential for adverse health effects from exposure to
chemicals exhibiting non-carcinogenic effects.  RfDs, which are
expressed in units of mg/kg/day, are estimates of lifetime daily
exposure levels for humans, including sensitive individuals, that
is not likely to be without an appreciable risk of adverse health
effects.  Estimated intakes of chemicals from environmental media
(e.g., the amount of a chemical ingested from contaminated
drinking water) can be compared to the RfD.  RfDs are derived
from human epidemiological studies or animal studies to which
uncertainty factors have been applied (e.g., to account for the
use of animal data to predict effect on humans).  These

                                14

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uncertainty factors help ensure that the RfDs will not
underestimate the potential for adverse non-carcinogenic effects
to occur.

Reference doses for the VDC chemicals of concern are listed in
Tables 14, 15 and 16.  The principal toxicological properties of
the contaminants of concern for the VDC are included in Appendix
A.

SUMMARY OF HUMAN HEALTH RISKS

The magnitude and type of risks associated with the chemicals of
concern at the site depend on the nature, duration, and frequency
of exposure to contaminants, and the characteristics of the
exposed populations.  To determine the appropriate response to
the chemicals observed at the VDC, a baseline public health risk
assessment was conducted assuming no future remedial actions.
Current risk levels were quantified for VDC clients, VDC workers,
VCRTC clients, and off-site children.  Future risk levels were
projected for these populations and construction workers (in the
event that institutional or residential construction would occur
at subsites 1 or 4).

Risks were based on two potential exposure scenarios — most
probable case and worst case.  The most probable case scenario
was based on the geometric mean of the contaminant concentrations
and reasonable assumptions regarding magnitude and duration of
exposure.  The worst case scenario was based on the maximum
concentration detected and exaggerated estimates of exposure
magnitude and duration.

Human health risks were also estimated for each site and for the
VDC as a whole.  Because of the close proximity of the four VDC
sites, it is reasonable to assume that certain populations may be
exposed to more than one site.  Therefore, across the entire VDC,
the risks from each of the four sites were combined for each
potentially exposed population.  Combining risks in this manner
effectively results in a total site risk characterization.

To evaluate the significance of the resulting total site risk,
the estimates are compared to target risk levels.  EPA has
adopted target risk levels for both carcinogens and non-
carcinogens.

EPA's guidelines indicate that the total incremental carcinogenic
risk for an individual resulting, from exposure at a hazardous
waste site should be between 10   (one additional cancer in a
10,000,000 populations) and 10~4 (one additional cancer in a
10,000 population).  Therefore, remedial alternatives should
reduce total potential carcinogenic risks to levels less than
10'4.  Based on EPA guidelines, the risk characterization refers
to the carcinogenic risk estimates as being "below the target

                                15

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range" when risks are less than 10 ; "within the target range"
when risks are 10  to 10" ; and "above the target range" when the
risks are greater than 10" .

Non-carcinogenic risk estimates are determined by dividing
exposure-dose levels for each non-carcinogen by the appropriate
dose/response criterion for the particular contaminant.  The
resulting ratio is termed a risk ratio.   The sum of the risk
ratios for individual contaminants is called the hazard index
(HI).  If this ratio is less than or equal to 1.0,  no adverse
health effects are anticipated from the predicted exposure-dose
level.  If the ratio is greater than 1.0, the predicted exposure-
dose level could potentially cause adverse health effects.  This
determination is not absolute because derivation of the relevant
standards or guidelines involves the use of multiple safety
factors.  Therefore, the potential for adverse health effects for
a mixture having a hazard index in excess of 1.0 must be assessed
on a case-by-case basis.  Hazard Indices were determined for each
potentially exposed population at each of the four sites.

It is concluded, based on the most probable case scenarios of the
public health risk assessment, that the carcinogenic and non-
carcinogenic risk estimates for all five populations are well
within the acceptable range that EPA would use to establish
cleanup levels, for each of the four sites, including subsite 1,
individually, as well as the total site risk for each population.
Table 17 summarizes the risks for the most probable case.

Total site carcinogenic risks calculated under the worst case
scenario were below or within the target risk range of 10"4 to
10  for all populations except the VDC residents and off-site
children.  Table 18 summarizes the risk for the worst case risks.

For VDC residents, the total site cancer risk exceeded the target
range by approximately ten-fold for the worst case scenario.  The
elevated risk is driven by the maximum concentration of
carcinogenic PAHs at subsite 1.  For off-site children, the total
site cancer risk was only slightly above the target range at 1.13
x 10'* for the worst case  risk scenario.  The carcinogenic risks
for off-site children were driven by the maximum concentration of
carcinogenic PAHs detected at subsites 1 and 3.

Total site non-carcinogenic risks calculated for the worst case
scenario were below a target HI of 1.0 for VCRTC clients.   The
total site non-carcinogenic risks were above 1.0 for VDC
residents, VDC workers, off-site children, and construction
workers.  The elevated HI for VDC residents and workers was
determined by the maximum concentration of lead at subsite 1; the
elevated HI for off-site children was due to the maximum
concentration of lead at both subsites 1 and 4; and the elevated
HI for construction workers was due to the maximum concentration
of lead at both subsites 1 and 4.

                               16

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Environmental Risks

This section assesses potential ecological risks posed by
chemicals at the four subsites of the VDC in the absence of any
future remedial actions.  The four sites are all located in
upland areas.  Surrounding environs are primarily residential
urban in character with small wood lots interspersed within and
among the neighborhoods.  The grounds of the VDC are intensively
managed and maintained by the staff.  No wetland or floodplain
areas are located within the four identified subsites.  None of
the subsites are within a half mile of either identified wetland
or 100 year floodplain.  Based on the residential nature of the
area, and the limited habitat available, no rare, threatened or
endangered species are likely to occur at the VDC.  Based on the
wildlife identified at the VDC, a songbird was selected as a
representative sensitive biological receptor for purposes of the
risk assessment.  Results of the VDC ecological risk assessment
demonstrate that cumulative Hazard Indices for a sensitive
representative biological receptor (songbird) range from 0.026 to
2.4.  Because the greatest HI generated under the absolute worst
case scenario is below 10, no significant risks to wildlife
populations are expected from any of the four VDC subsites under
existing conditions (see Table 19).

Discussion of No Further Action

With the completion of the remedial action at subsite 2 and the
findings contained in the RI report, this document proposes that
subsites 1-5 require no further action.  Most probable case
human health risks, estimated to result from exposure to site
chemicals, were well within the acceptable range that EPA uses to
establish cleanup levels for Superfund sites.  No adverse health
effects were predicted due to exposure to non-carcinogens.  The
probability of ecological impacts were estimated to be
negligible.  These baseline estimates, developed considering no
remedial action, indicate that further response actions to reduce
risks of exposure to the substances present at VDC are not
warranted at the present time.

In addition, EPA and NJDEP have concluded that no further action
is needed at subsite 2.  Similarly, no action is needed at the
other subsites, including subsite 1, the NPL site.  This was
based on the fact that the allegations of improper dumping of
mercury- and arsenic-based pesticides was not substantiated
during the RI, the levels of contaminants found at the site were
on the whole below action levels, and the landfill on subsite 1
was closed with a foot of soil and vegetated.

However, due to the fact that low levels of hazardous substances
will remain on the site, and the observed inconsistencies in some
groundwater measurements, a monitoring program will be developed
and implemented.  The monitoring program will focus on sampling

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and evaluating groundwater quality.  If this program identifies
the existence of any undisclosed sources of contamination or
other site-related groundwater problems, appropriate action will
be taken by HJDEP.

In addition, an inspection program will be developed and
implemented involving the existing disposal areas.  If soil
disruption is observed, sampling will be performed and
appropriate action taken to protect against exposure to the
disposed materials.

The monitoring programs for groundwater and the disposal areas
will be developed and provided to the public for comment prior to
implementation.  Public input will also be obtained relative to
any appropriate actions which may be necessary at the site.
                                18

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                          ROD FACT SHEET
ROD Cover memo to Regional Administrator

Site

Name      Vineland State School (Vineland Developmental Center)
Location  City of Vineland, Cumberland County, New Jersey
EPA

HRS
RANK
USEPA - Region II, 26 Federal Plaza, NY, NY

40.84  (August 9, 1982)
Ranked No. 237 out of 418 NPL sites
ROD

Date
Remedy

LEAD
Agency
Contact
PRPs
September 29, 1989
No Action, subsite 2 remediated in 1988

State
NJDEP
Joe Maher (609) 633-0765  Site Manager
Andrew Marinucci  (609) 984-9792  Tech. Coord.
Matthew Westgate  (212) 264-3406 USEPA Proj. Mgr.

Vineland Developmental Center
State of new Jersey Department of Human Services
WASTE

Type
Medium
Origin
Quantity
Pesticides - DDT, DDD, DDE, Dieldrin
Landfill material including incinerator ash
Polynuclear aromatic Hydrocarbons
Metals - Lead, mercury

Soils (very low levels)
Vineland Development Center
No estimate
                                19

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                           APPENDIX A
DDT and Derivatives (ODD and DDE)

DDT is a chlorinated pesticide that was widely used from the mid-
1940 's until 1972.  DDT can be converted to ODD and DDE by the
action of sunlight (EPA, 1984).  The pesticide and its
transformation products are persistent in soil and water, and
they are widely dispersed by erosion, runoff, and volatilization.
Leaching of DDT from soils with high organic content is expected
to be slow; however, leaching to groundwater has been observed.
Because of its low water solubility and high-lipid solubility,
DDT accumulates to high levels in the tissues of humans and other
species (Doull et al., 1980).

DDT is effectively absorbed by humans and other species from the
gastrointestinal  (GI)  tract.  Because of its high lipid
solubility, the insecticide can accumulate to relatively high
concentrations in adipose tissue.  DDT is poorly absorbed after
dermal exposure, especially when applied as a powder or when
present as contaminated soil.  The acute toxicity in rats, as
measured by an LD50, is 100-fold greater when DDT is orally
administered as opposed to dermally (Doull et al., 1980).

DDT has been shown to cause liver tumors in mice and rats, and
lymphomas and pulmonary tumors in mice.  It is, therefore,
classified as a probable human carcinogen (Group B2) by the EPA
Carcinogen Assessment Group (CAG) (EPA, 1984).  ODD and DDE have
also been shown to produce liver tumors (i.e., hepatomas) in
mice.   The International Agency for Research on Cancer (IARC)
has, therefore, classified these chemicals as probable human
carcinogens (Group B2) by the CAG.

Acute exposures to DDT result in neurotoxic effects, however,
fatalities have not been reported.  Chronic exposure can result
in liver toxicity in experimental animals.

Dieldrin

Dieldrin is a highly persistent, chlorinated cyclodiene
pesticide.  This compound is manufactured by oxidizing the
related pesticide, aldrin.  Dieldrin is also a major metabolite
of aldrin (Hawley, 1981).

Dieldrin is poorly soluble in water but has high-lipid
solubility.  Because of its chemical and biological stability, it
tends to bioconcentrate in animal tissues.  Dieldrin's

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persistence in the environment is aided by its strong absorption
to organic matter in soils (Doull et al., 1980).

Dieldrin can be absorbed from the GI tract and through the skin.
The efficiency of absorption of the pesticide from contaminated
soil is unknown.

Dieldrin has caused liver tumors in laboratory animals, prompting
EPA to classify it as a Class B2 probable human carcinogen.  The
EPA CAG has determined that dieldrin has a relatively high
potency, exceeding those of TCE, chlordane, benzene, and the
polycyclic aromatic hydrocarbon, benzo(a)pyrene (BaP).  Dieldrin
is also acutely toxic to humans and other species; it has caused
human fatalities when inadvertently ingested.  Causes of death
were related to dieldrin's toxic effects on the nervous system.
Dieldrin can also penetrate through intact skin, as is
demonstrated by the dose agreement between acute lethal doses to
rats when given orally -or applied dermally.  In subchronic and
chronic animal studies, dieldrin has been shown to cause liver
damage (Doull et al., 1986; and NAS, 1977).

Carcinogenic PAHs

PAHs, also known as polynuclear aromatic hydrocarbons, are a
family of multi-ring aromatic compounds commonly found in fossil
fuels and formed from the incomplete combustion or pyrolysis of
organic materials.  Several hundred PAH compounds have been
identified.  PAHs almost always exist as mixtures in the
environment.  PAHs are poorly soluble in water and absorb tightly
to soils.  The major removal mechanism is predicted to be
microbial degradation (EPA, 1984).

Some of the PAHs are produced or imported for commercial
purposes.  For example, naphthalene is used in commerce as a moth
repellent.  This use accounts for the highest single
environmental release of the compound.  Naphthalene is also used
in the production of other chemical products, such as phthalic
anhydride, carbaryl insecticide, dye intermediates, and synthetic
tanning agents.  Anthracene is used as an intermediate in dye
production, as a wood preservative, as a pesticide, and in
special uses in the electronic industry.  Acenaphthene, fluorene,
flouranthene, phenanthrene, and pyrene are manufactured or
imported in relatively small quantities for special commercial
uses, including Pharmaceuticals, pigments, plastics, pesticides,
and photography.  The remaining PAHs (i.e., BaP, acenaphthylene,
benzo(a)anthracene, chrysene, dibenz(a,h)anthracene,
benzo(b)flouranthene, benzo(k)flouranthene, benzo(g,h,i)perylene,
and indeno(1,2,3-cd)pyrene) have no uses in commerce other than
as research standards.

There are many animal studies demonstrating the carcinogenic
potential of individual PAHs.  However, only limited information

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is available on the effects of complex mixtures of PAHs in the
environment.  Seven PAH compounds have been classified as
potential human carcinogens (CAG B2 classification):
benzo(b)flouranthene; benzo(k)flouranthene; benzo(a)anthracene;
BaP; chrysene; dibenzo(a,h)anthracene; and indeno(l,2,3,-
cd)pyrene.  Several other PAHs are mutagenic but have not been
shown to be carcinogenic (i.e., anthracene, benzo(g,h,i,)-
perylene, fluoranthene,  fluorene, phenanthrene and pyrene).  it
is not certain what effect interactions of carcinogenic and non-
carcinogenic PAHs have on the carcinogenic potential of the
mixture.  Complete mixture information is largely derived from
mouse skin application experiments with extracts of coal tar
products and gasoline or diesel exhaust.  Numerous
epidemiological studies of worker populations have shown  clear
association between PAH-containing materials (e.g., soots, tars,
and oils) and increased cancer risk (IARC, 1985).  Occupational
studies involving worker exposures to PAHs from emissions of coke
ovens, foundry processes, coal gas production,  roofing tar, and
coal combustion have reported increased risk of lung and other
cancers.  It is difficult to define the specific causative
agent(s) in studies of complex mixtures.  Non-carcinogenic
effects of PAH exposures have also been reported in animal
studies.  These effects include weight loss, kidney and  liver
function changes, bronchitis, and serum enzyme changes (Knobloch,
et al., 1969).  Animal studies have found PAHs to cross the
placenta, and teratogenic effects have been reported (Pucknat,
1981).

PAHs are highly lipid-soluble and are absorbed via the GI tract,
skin and lungs (EPA 1984).  Studies in whole animals indicate
that several structurally related PAHs are readily absorbed from
the GI tract and tend to localize primarily in body fat tissues,
including the breast (NAS, 1977).

Many of the PAHs produce tumors in mouse skin when applied
topically in solvents or coal-tar products.  Therefore, dermal
contact is a potentially important route of exposure for these
compounds.  However, the degree of skin absorption of PAHs from
contaminated soils is not known (EPA, 1984).

EPA has derived CPFs for oral and inhalation exposures to BaP.
These potency factors have been retracted by EPA and are
undergoing review.  However, due to lack of supplementary data,
these values are still used to assess the carcinogenic risks
associated with the mixture of carcinogenic PAHs.  Potency
factors are not available for the other carcinogenic PAHs.  Using
the factor for BaP to represent the potency of the seven
identified carcinogenic compounds is a widely accepted assumption
for risk assessment.

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Lead

Lead is a naturally-occurring metal widely distributed throughout
nature in a variety of minerals.  It is used in the production of
storage batteries, gasoline additives, pigments and ceramics,
bullets, solder, cable coverings, caulking lead, piping, type
metal, brass and bronze, and bearing metals.  Lead is soluble in
water, especially in acidic water.  In soils and sediments, lead
is absorbed by minerals; dissolution into water is somewhat
limited (NAS, 1977).

GI absorption of lead depends on age, diet, and other factors.
Adults absorb 15 percent of ingested lead and usually retain less
than 5 percent of the amount absorbed.  Children absorb 40 to 50
percent of ingested lead, and retention is as high as 30 percent
(Klaassen et al., 1986).  Absorbed lead is excreted by both
kidneys and the GI tract.  Although soft-tissue levels appear to
be in balance in adults, bone lead content may increase with age.
Bone is the storage site for at least 90 percent of the total
lead body burden in adults and approximately 70 percent in
growing,children (NAS, 1977).

Because of decades of medical observation and scientific research
on lead, the degree of uncertainty about the health effects of
lead is quite low.  There are no known beneficial effects of lead
exposure.  It appears that some of the more subtle observed
health effects (e.g., changes in the levels of specific blood
enzymes and changes in children's neurological development) may
occur at blood levels so low as to be essentially without a
threshold.

Acute lead toxicity in adults as a result of a single exposure is
rare because lead is poorly absorbed through the digestive
system.  Because it is so poorly absorbed, about 35 days of
exposure are required for lead levels in the blood to rise to the
point where toxic effects are evident.  This effect level is
between 10 and 15 micrograms per deciliter (ug/dl) of blood.
The classic signs of chronic lead poisoning are loss of appetite,
metallic taste, severe constipation, anemia, pallor, malaise,
weakness, insomnia, headache, nervous irritation, muscle and
joint pain, fine tremors, brain disorders, and colic (i.e.,
abdominal cramps).  Some individuals develop weakness in the
extensor muscles of the arm and leg, leading to "wrist drop or
foot drop".

These symptoms are only evident at relatively high blood lead
levels.  Other less easily-detectable effects have been
associated with blood levels as low as 10 ug/dl.  The most
serious effects involve the central nervous system; in children,
these include hyperactivity, poor classroom behavior, and
decreased IQ scores.  These effects are evident at blood levels
of approximately 30 to 50 ug/dl.  Deficiencies in red blood

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function, although less severe, are detectable at blood levels as
low as 10 ug/dl.

Other systems adversely affected by lead include the GI system,
kidneys, thyroid and adrenal glands, joints, and testes.
The only study involving human exposure to lead and cancer has
been one in which a significant increase in deaths due to cancer
of the digestive organs and respiratory system were observed
among lead smelters and battery plant workers.  However, IARC
considers this to be inadequate evidence of carcinogenicity in
humans.

Twelve studies involving rats and mice have associated tumor
formation (most often in the kidney) with ingestion of high doses
of lead salts.  Based on these findings, IARC has classified lead
in Category 3 due to inadequate evidence in humans, yet
sufficient evidence in animals.  Based on the same strength and
type of evidence, EPA classified lead as a Group B2 probable
human carcinogen.

Unavoidable background levels of lead in food and drinking water
result in high average lead intakes among the U.S. population.
The average daily adult intake from drinking water is 26
micrograms per day (ug/day) (HAS, 1977) .  Adult intake from food
is 100 to 300 ug/day.  These exposure levels are higher than the
EPA oral acceptable daily intake of 1.4 ug/kg/day or 98 ug/day
for an average 70 kilograms (kg) adult (EPA, 1986).  As a result
of these background exposures, EPA concluded that any significant
increase above present lead levels in air, water, and soil
represents a cause for concern regarding effects on human health.

Mercury

The major source of mercury in the environment is the natural
degassing of the earth's crust, as well as emissions from mining
and smelting industries.  There are various chemical species of
mercury present in the environment, all of which can be
classified as either inorganic or organic.  The toxicological
effects of mercury depend on the particular biochemical form.
Methyl mercury, which is an organic form of mercury, is the most
toxic.  Although methylated forms of mercury are not emitted
directly into the atmosphere, inorganic forms may be methylated
in the environment by microbes in soil or water.  Methyl mercury
causes degeneration and necrosis of neurons in focal areas of the
cerebral cortex, and degeneration of ganglion cells leading to
the clinical signs of paresthesia, ataxia, dysarthria, and
deafness in that order.  Some partial paralysis has occurred
(complete paralysis in severe cases), as well as loss of sight
and speech,  tremors and personality or behavioral changes.
Methyl mercury has been shown to be teratogenic in humans,
causing palsy, convulsions, and mental retardation in infants
(Gossel and Bricker, 1984).

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Two forms of inorganic mercury are mercuric and mercurous
mercury.  Acute ingestion of high levels of mercuric mercury
causes severe abdominal cramps due to corrosive ulceration,
bleeding and necrosis of the GI tract, accompanied by shock and
circulatory collapse.  If death does not occur, renal failure
occurs due to necrosis of the renal tubules leading to anuria
(inability to urinate), and uremia (excess of blood urea).  Not
all renal damage is irreversible.

Chronic oral or inhalation exposure to low levels of mercuric
mercury leads to immunologic glomerular disease, often evidenced
by proteinuria, which is usually reversible after exposure
ceases.  This nephropathy is often accompanied by detectable
neuropathy (Klaassen et al., 1986).

Mercurous mercury is less toxic and less corrosive than the
mercuric form, due to decreased solubility.  However, when it was
used in toothpaste, acrodynia or "pink disease" was observed,
producing vasodilation, hyperkeratosis, and hypersecretion of
sweat glands.  This is thought to be a hypersensitivity response
(Matheson et al., 1980).

The EPA CA6 classifies inorganic mercury as a Group D compound;
that is, not classifiable due to lack of evidence as a human
carcinogen.  Methyl mercury has not been evaluated for its
carcinogenicity potential.

Non-carcinogenic PAHs

Non-carcinogenic PAHs represent a wide array of compounds.
However, toxicity information is limited to a few select
compounds.  For the purposes of this report, the toxicity of this
set of compounds will be estimated by using naphthalene as a
surrogate in a manner similar to that used for BaP for
carcinogenic PAHs.  Naphthalene was chosen because more toxicity
information is available than for other non-carcinogenic PAHs.
The following discussion, therefore, is restricted to
naphthalene.

Naphthalene, also called naphthalin, naphthene, moth flake, tar
camphor, or white tar, is a white solid that exhibits the
characteristic mothball odor.  Chemically, it is composed of two
fused benzene rings.  Naphthalene occurs naturally in the roots
of Radix and Herba ononids. is formed in cigarette smoke by
pyrolysis, and is a photodecomposition product of carbaryl, a
naphtylcarbamate insecticide.  Naphthalene also occurs in crude
oil, cracked petroleum products, coke oven emissions, and high
temperature carbonization of bituminous coal (American Petroleum
Institute, 1959).  Ingestion of Naphthalene, in the form of
mothballs, has resulted in no adverse effects in several cases
described.  The ingested material was excreted in the feces in an
unchanged form.  The co-ingestion of fats facilitates the

-------
absorption and other systemic effects of naphthalene (Moeschline,
1965).  In severe cases, ingestion has caused gastroenteric
distress, tremors, and convulsions.  Within two to seven days,
moderate to severe anemia may develop, followed by hemoglobin
damage, and a yellowish-brown color to the serum.  In some cases,
this  leads to disruption of renal function and even death due to
respiratory failure (Diechman and Gerade, 1969).

Naphthalene is acutely irritating to the eye.  It is also a
primary skin irritant.  Because naphthalene may volatilize and
sublime at room temperature, inhalation is a primary exposure
route.  The signs and symptoms of toxicity due to inhalation of
naphthalene vapors resemble those observed from oral or dermal
exposure.  Naphthalene vapors may cause eye and respiratory
irritation, headache, nausea, and profuse perspiration.

Chronic effects of oral administration of a naphthalene-
isopropanol mixture resembled ethanol intoxication but subsided
after a few days (Gadsden et al., 1958).  The effects on the eye
were more severe.  Corneal ulceration and cataracts have been
observed as well as general opacities (Adams, 1930).
Repeated inhalation of naphthalene vapors may produce malaise,
headache, and vomiting.

Daily oral administration of naphthalene to rabbits at 1 gram per
kilogram (g/kg) produced effects in the eye that were slightly
visible after only three doses and markedly visible after 20
days.  A dose of 1.5 g/kg day produced white spots in the rabbit
eye periphery but were distributed over the whole retina of young
animals (Shimotori, 1972).

NTP recently tested naphthalene for carcinogenic activity in
mice; results of the study have not yet been published.  EPA
determined that the dose at which acute effects have been
observed in humans is three to five orders of magnitude higher
than the exposure levels to specific subpopulations associated
with mothball use and cigarette smoking (EPA, 1982).  EPA,
therefore, concluded that there appears to be little acute risk
from environmental exposure to naphthalene; however, severe
adverse effects are possible from accidental ingestion of
substantial quantities of naphthalene.

-------
                     FIGURE  1
         PROJECT LOCATION MAP
VINELAND DEVELOPMENTAL CENTER
          VINELAND, NEW JERSEY

-------
                                                          SITE 3
 PARK
AVENUE
                       MAPLE AVENUE
                SEWAGE QUESTION HOUSE
PIQOERY AND SLAUGHTER HOUSE

        SITE 1
                                      NUMERATOR
         HOSPITAL AND
         8AMTARUM
                                  POWER HOUSE
                                     LANOIS AVENUE
  NOT TO SCALE
                                         FIGURE  2
                      PREVIOUS BUILDING LOCATIONS
                  VNELAND DEVELOPMENTAL CENTER
                              VINELAND, NEW JERSEY
                  	ECJO^NCQ

-------
             • 1MB  IDENTIFIED
                    EXTENT OF FIU.
                ME*


        tllltlNC MONITOHINC WILL
   ta.tl  MUM or riLLTki rut
lii"""' MPTH Of FILL CONTOUN
             MONITOMIN6 WILL
^-»—•— riNtt             MW-II

        PHAW I MM. kAMKE

•^•-  \     6'-. a A    V./.LL   "-" -I
        /^^   _          _.,	1,1
                                                                                                                                   FIGURE 3
                                                                                                                         FILL AREAS - SITE 1
                                                                                                          VINELAND DEVELOPMENTAL CENTER
                                                                                                                      VINELAND. NEW JERSEY

-------
                                                         IDENTIFIED
                                                         EXTENT OF FLL

  LtfitUft
  	» ~—'MTOMHTV LIM
  '**• i - — DIMM or ru.i CONTOUR
     ^   CIIS1MM MONITODIN8 WILL

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    I3.tl   MUM Of PILL IN fill

         FMAlt I
                         FIGURE  4
               FILL AREAS - SITE a
VINELAND DEVELOPMENTAL CENTER
            VINELAND, NEW JERSEY
	tCJORCKNCQ -

-------
LEGEND

MW»42
        EXISTING MONITORING WELL

        PHASE I SOIL BORING

    !^.  PHASE I MONITORING WELL

—--—. PROPERTY LINE       v

- *— * - FENCE             J
  40
       ALLEGED TRANSFORMER
       OIL DISPOSAL AREA
                                       200FEET           TIGDRE*
                                        SITE 4, SOIL BORING AND
                                   MONITORING WELL LOCATIONS
                              VINELAND DEVELOPMENTAL CENTER
                                           VINELAND, NEW JERSEY
                              	'.	—	 ECJORDANCQ

-------
FORMER SEWAGE
DIGESTION HOUSE-=i	
        V         II
         )-^
                                     EXISTING MONITORING

                                     P^ASE I SOIL BORING

                                     PHASE I MONITORING WELL
                                     PHASE • SON. SAMPLE
                      200'"T           TJGlfflE S
                        SITE 5, SOIL BORING AND
                  MONITORING WELL LOCATIONS
              VINELAND DEVELOPMENTAL CENTER
                          VINELAND, NEW JERSEY
              	'•	ECJORDANCO

-------
                                   TABLE   1
                    CHEMICALS DETECTED IN SITE NO.  1 SOILS

                            REMEDIAL INVESTIGATION
                         VINELAND DEVELOPMENTAL CENTER
                                       RANGE OF CONCENTRATIONS («e/kg)
CHEMICAL
PAHs
Carcinogens2
Noncarcinogens2
DDT
DDD
DDE
Dieldrin
Lead
Mercury
Arsenic
Chromium
0-2 FT. DEPTH

BDL-3.175
BDL-4.057
0.008-0.150
- BDL-0.02
BDL-0.120
BDL-0.068
BDL-208
BDL-0.8
BDL-5.2
2.1-11
0-12 FT. DEPTH1

3
3
3
3
3
3
BDL-529
BDL-3 . 7
BDL-13
BDL-36
NOTES:

1 Excavation exposure represents one public health risk assessment scenario.
  Excavation was assumed to extend to 12 feet; however, composite samples
  extended to 17 feet.  It was assumed that chemical concentrations detected
  in the 0 to 17-foot composite samples conservatively (protectively) represent
  chemical concentrations at 0 to 12-foot depths.

2 Carcinogenic PAHs are the sum of the seven USEPA potential carcinogens:
  benzo(a)anthracene; benzo(a)pyrene; benzo(b)fluoranthene; benzo(k)
  fluoranthene; chrysene; indeno(l,2,3-cd)pyrene; and dibenzo(a,h)
  anthracene (USEPA, 1986).

3 This chemical was not analyzed for in Phase 1.  Therefore, there is only
  0 to 2-foot data.

BDL = Below Detection Limit
 '.89.93T
0001.0.0

-------
                    CHEMICALS DETECTED IN SITE NO.  3 SOILS

                            REMEDIAL INVESTIGATION
                         VINELAND DEVELOPMENTAL CENTER
                                       RANGE OF CONCENTRATIONS (mg/kg)
CHEMICAL
PAHs
Carcinogens2
Noncarcinogens2
DDT
DDD
DDE
Lead
Arsenic
Chromium
Di-n-butylphthalate
Bis(2-ethylhexyl)phthalate
Dieldrin
Endosulfan
0-2 FT. DEPTH

BDL-3.719
BDL-5.597
BDL-0.018
BDL-0.021
BDL-0.021
12-48
NA
NA
BDL-0.440
BDL-0.730
BDL-31
BDL-27
0-12 FT. DEPTH1

BDL-17.650
BDL-23.410
BDL-0.170
BDL-1.6
BDL-21
3.1-193
BDL-2.4
3.2-8.4
BDL-0 . 230
BDL-0.730
BDL-31
BDL-27
NOTES:

1 Excavation exposure represents one public health risk assessment scenario.
  Excavation was assumed to extend to 12 feet; however, composite samples
  extended to 17 feet.  It was assumed that chemical concentrations detected
  in the 0 to 17-foot composite samples conservatively (protectively) represent
  chemical concentrations at 0 to 12-foot depths.

2 Carcinogenic PAHs are the sum of the seven USEPA potential carcinogens:
  benzo(a)anthracene; benzo(a)pyrene; benzo(b)£luoranthene; benzo(k)
  fluoranthene; chrysene; indeno(l,2,3-cd)pyrene; and dibenzo(a,h)
  anthracene (USEPA, 1986).

BDL = Below Detection Limit

NA  = Not analyzed for in Phase 2 samples.  Phase 1 samples were composite
      samples (0-15+ feet).  Therefore, there is no 0-2 feet data available
     for this chemical.
6.89.93T
0002.0.0

-------
                                   TABLE   3
                    CHEMICALS DETECTED IN SITE NO. 4 SOILS

                            REMEDIAL INVESTIGATION
                         VINELAND DEVELOPMENTAL CENTER
                                       RANGE OF CONCENTRATIONS (mg/kg)
CHEMICAL
DDT
DDD
DDE
Dieldrin
Lead
Chromium
0-2 FT. DEPTH
0-0.022
0-0. 0182
*
*
3.1-410
2.1-9.8
0-12 FT. DEPTH1
BDL-0.310
BDL-0.0182
BDL-0.1102
BDL-0.0232
1.4-410
2.1-17
NOTES:

1 Excavation exposure represents one public health risk assessment scenario.
  Excavation was assumed to extend to 12 feet; however, composite samples
  extended to 17 feet.  It was assumed that chemical concentrations detected
  in the 0 to 17-foot composite samples conservatively (protective) represent
  chemical concentrations at 0 to 12-foot depths.

2 Concentration data were based on only one detection above detection limit.

* Non-detect

BDL = Below Detection Limit
6.89.93T
0003.0.0

-------
                                   TABLE   4
                    CHEMICALS DETECTED IN SITE NO. 5 SOILS

                            REMEDIAL INVESTIGATION
                         VINELAND DEVELOPMENTAL CENTER
                                       RANGE OF CONCENTRATIONS (mg/kg)
CHEMICAL
IDT
DDE
DDD
Chromium
Lead
PAHs
Carcinogens2
Noncarcinogens2
0-2 FT. DEPTH
0.056-0.370
0.067-0.320
*
2.9-18
2.1-10

*
*
0-12 FT. DEPTH1
BDL-0.370
BDL-0.320
*
2.9-18
2.1-10

BDL-0.172
BDL-0 . 135
NOTES:

1 Excavation exposure represents one public health risk assessment scenario.
  Excavation was assumed to extend to 12 feet; however, composite samples
  extended to 17 feet.  It was assumed that chemical concentrations detected
  in the 0 to 17-foot composite samples conservatively (protectively) represent
  chemical concentrations at 0 to 12-foot depths.

2 Carcinogenic PAHs are the sum of the seven USEPA potential carcinogens:
  benzo(a)anthracene; benzo(a)pyrene; benzo(b)fluoranthene; benzo(k)
  fluoranthene; chrysene; indeno(l,2,3-cd)pyrene; and dibenzo(a,h)
  anthracene (USEPA, 1986).

* Non-detect

BDL = Below Detection Limit
6.89.93T
0004.0.0

-------
                                   TABLE 5
         MAXIMUM AND MOST REPRESENTATIVE (AVERAGE) CONCENTRATIONS FOR
                             CHEMICALS OF CONCERN
                           SITE NOS.  1, 3, 4, AND 5

                            REMEDIAL INVESTIGATION
                         VINELAND DEVELOPMENTAL CENTER
                                            CONCENTRATIONS (mg/kg)
SITE
1



3




4
5
CHEMICALS OF CONCERN
PAfls
Carcinogenic1
Noncarcinogenic2
Lead
Mercury
PAfls
Carcinogenic1
Noncarcinogenic2
DDE
Lead
Lead
No chemicals of concern
0-2
AVERAGE3

0.203
0.339
1.11
0.146

0.973
1.187
—
26.2
15.37
FT.
MAXIMUM

3.175
4.057
208
0.8

3.791
5.597
...
48
410
0-12
AVERAGE3

-—
5.68
0.093

0.985
1.076
0.001
25.18
4.35
FT.
MAXIMUM

— —
529
3.7

17.650
23.410
21.0
193
410
(see Subsection 2.2.2)
NOTES:

1 Carcinogenic PAH concentrations are the sum of the seven potentially
  carcinogenic PAHs:   benzo(a)anthracene; benzo(a)pyrene; benzo(b)
  fluoranthene;  benzo(k)fluoranthene; chrysene; indeno(l,2,3-cd)pyrene; and
  dibenzo(a,h)anthracene.

2 Noncarcinogenic PAH concentrations are the sum of the noncarcinogenic PAHs.

3 All concentrations  were' lognormal distributions.  These averages represent
  geometric means converted back to their arithmetic value (see Subsection 2.2.5)
6.89.93T
0008.1.0

-------
                                   TABLE 6
              SOIL INGESTION AND DERMAL CONTACT EXPOSURE SCENARIO
                          VDC RESIDENTS - SITE NO. 1

                            REMEDIAL INVESTIGATION
                         VINELAND DEVELOPMENTAL CENTER
EXPOSURE
PARAMETER
    MOST
PROBABLE CASE
WORST CASE
Average Body Weight

Frequency of Exposure

Soil Ingestion Rate

Surface Area Exposed
  (hands and feet)

Soil Deposition Factor

Exposure Duration
  65 kg
            t
  30 events/year

  1.0 g/event

  1,954 cm2 (I)

           2
  0.5 mg/cm

  30 years
65 kg

150 events/year

2.5 g/event

2,306 cm2 (2)


         2
1.5 fflg/cm

78 years
(1)  50th percentile (Anderson et al., 1985)
(2)  95th percentile (Anderson et al., 1985)
7.89.19T
0002.0.0

-------
                                   TABLE  7
              SOIL INGESTION AND DERMAL CONTACT EXPOSURE SCENARIO
                 OFF-SITE CHILDREN - SITE NOS. 1, 3, 4, and 5

                            REMEDIAL INVESTIGATION
                         VINELAND DEVELOPMENTAL CENTER
EXPOSURE
PARAMETER
    MOST
PROBABLE CASE
WORST CASE
Average Body Weight

Frequency of Exposure

Soil Ingestion Rate

Surface Area Exposed
 (hands and feet)

Soil Deposition Factor

Exposure Duration
  28 kg   '

  30 events/year

  0.2 g/event

  902.5 cm2(l)

           2
  0.5 tag/cm

  5 years
28 kg

60 events/year

1.0 g/events

1,058 cm2 (2)

         2
1.5 mg/cm

10 years
(1)  50th percentile (Anderson et.al., 19fa5)
(2)  95th percentile (Anderson et al., 1985)
7.89.19T
0003.0.0

-------
                                   TABLE  8
              SOIL INGESTION AND DERMAL CONTACT EXPOSURE SCENARIO
                        VDC WORKERS - SITE NOS. 1 and 5

                            REMEDIAL INVESTIGATION
                         VINELAND DEVELOPMENTAL CENTER
EXPOSURE
PARAMETER
    MOST
PROBABLE CASE
WORST CASE
Average Body Weight

Frequency of Exposure

Soil Ingestion Rate

Surface Area Exposed
  (hands and forearms)

Soil Deposition Factor

Exposure Duration
  70 kg

  12 events/year

  100 nig/event

  2,300 on2 (1)

           2
  0.5 rng/on

  20 years
70 kg

24 events/year

250 mg/event

2,830 cm2 (2)

         2
1.5 mg/on

30 years
(1)  50th percentile (Anderson et al., 1985)
(2)  95th percentile (Anderson et al., 1985)
7.89.19T
0004.0.0

-------
                                   TABLE  9
              SOIL INGESTION AND DERMAL CONTACT EXPOSURE SCENARIO
                   CONSTRUCTION WORKERS - SITE NOS. 1 AND 4

                            REMEDIAL INVESTIGATION
                         VINELAND DEVELOPMENTAL CENTER
EXPOSURE
PARAMETER
    MOST
PROBABLE CASE
WORST CASE
Average Body Weight

Frequency of Exposure

Soil Ingestion Rate

Surface Area Exposed
  (hands and forearms)

Soil Deposition Factor

Exposure Duration
  70 kg

  20 events/year

  100 mg/event

  2,300 cm2 (1)

           1
  0.5 rag/cm*'

  1 year
70 kg

40 events/year

250 mg/event

2,830 cm2 (2)

         9
1.5 mg/cm~

1 year
(1)  50th percentile (Anderson et al., 1985)
(2)  95th percentile (Anderson et al., 1985)
7.89.19T
0005.0.0

-------
                                   TABLE  10
                INHALATION OF FUGITIVE DUSTS EXPOSURE SCENARIO
                          VDC RESIDENTS - SITE NO. 1

                            REMEDIAL INVESTIGATION
                         VINELAND DEVELOPMENTAL CENTER
EXPOSURE
PARAMETER
Average Body Weight
MOST
PROBABLE CASE
65 kg ,
WORST CASE
65 kg
Frequency of Exposure
  Wind Erosion Only
14 days/year
  Wind Erosion & Bulldozing   5 days/year

                                   3
Inhalation Rate

Duration of Exposure

Distance from Source

Exposure Period
0.5 m /hour

24 hours/day

50 meters

1 year
28 days/year
10 days/year

1.6 m /hour

24 hours/day

50 meters

1 year
7.89.19T
0006.0.0

-------
                                  TABLE   11
              SOIL INGESTION AND DERMAL CONTACT EXPOSURE SCENARIO
                          VCRTC CLIENTS - SITE NO. 3

                            REMEDIAL INVESTIGATION
                         VINELAND DEVELOPMENTAL CENTER
EXPOSURE
PARAMETER
    MOST
PROBABLE CASE
WORST CASE
Average Body Weight

Frequency of Exposure

Soil Ingestion Rate

Surface Area Exposed
  (hands and feet)

Soil Deposition Factor

Exposure Duration
  53 kg

  30 events/year

  100 mg/event

  2,003 on2 (1)

           2
  0.5 mg/cm

  1.2 years
53 kg

60 events/year

250 mg/event

2,366 cm2 (2)

         2
1.5 mg/cm

2.4 years
(1)  50th percentile (Anderson et al., 1985)
(2)  95th percentile (Anderson et al., 1985)
7.89.19T
0007.0.0

-------
                                  TABLE   12
                INHALATION OF FUGITIVE DUSTS EXPOSURE SCENARIO
                        OFF-SITE CHILDREN - SITE NO. 4

                            REMEDIAL INVESTIGATION
                         VINELAND DEVELOPMENTAL CENTER
EXPOSURE
PARAMETER
Average Body Weight
MOST
PROBABLE CASE
28 kg
WORST CASE
28 kg
Frequency of Exposure
  Wind Erosion Only
14 days/year
  Wind Erosion & Bulldozing   5 days/year

                                   3
Inhalation Rate

Duration of Exposure

Distance from Source

Exposure Period
1.0m /hour

24 hours/day

50 meters

1 year
28 days/year
10 days/year

3.2 m /hour

24 hours/day

50 meters

1 year
7.89.19T
0008.0.0

-------
                                  TABLE   13
              SOIL LNGESTION AND DERMAL CONTACT EXPOSURE SCENARIO
                          VDC RESIDENTS - SITE NO. 5

                            REMEDIAL INVESTIGATION
                         VINELAND DEVELOPMENTAL CENTER
EXPOSURE
PARAMETER
    MOST
PROBABLE CASE
WORST CASE
Average Body Weight

Frequency of Exposure

Soil Ingestion Rateq
  65 kg

  12 events/year

  1.0 g/event
(1)  50th percentile (Anderson et al., 1985)
(2)  95th percentile (Anderson et al., 1985)
65 kg

30 events/year

2.5 g/event
Surface Area Exposed
Soil Deposition Factor
(hands and feet)
Exposure Duration
1,954 on2 (1)
2
0.5 rag/cm
30 years
2,306 on2 (2)
2
1.5 mg/on
78 years
7.89.19T
0009.0.0

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                                         TABLE    14
                             SELECTED DOSE/RESPONSE DATA  - ORAL EXPOSURE

                                     REMEDIAL  INVESTIGATION
                                  VINELAND DEVELOPMENTAL  CENTER
                  12-Jul-89
Contaminant of Concern
Carcinogenic Effects
Carcinogenic PAHs
DOT
ODD
DOE
Oleldrin
Noncarcinogera
DDT * Metabolites
Dleldrln
Lead
Mercury
Naphthalene
Dose/Response
Value Unit

1.15E+01 
-------
                                            TABLE
t
                        SELECTED DOSE/RESPONSE DATA •  INHALATION  EXPOSURE

                                    REMEDIAL INVESTIGATION
                                 VINELAND DEVELOPMENTAL  CENTER
                    12-Jul-89
•
Contaminant of Concern
Carcinogenic Effect*
Carcinogenic PAHs
DOT
ODD (1)
DDE (1)
Dieldrin
Noncarcinogenic Effects
DDT * mtabolites (1)
Dieldrin (1)
Lead
Mercury <1)
Naphthalene (1)
Dose/Response
Value Unit

6.10E+00 («g/kg/day)-1
3.406-01 (ing/kg/day)-!
2. 406-01 (ing/kg/day)- 1
3.40E-01 (ng/kg/day)-1
1.60E+01 (mg/kg/day)-1
'

5.00E-04 mg/kg/day
5.00E-05 mg/kg/day
4.30E-M mg/kg/day
3.00E-04 mg/kg/day
4.00E-01 mg/kg/day
Source

SPHEM
IRIS
IRIS
IRIS
IRIS

IRIS
IRIS
NAAQS
IRIS
SPHEM
Date

10/86
5/89
5/89
5/89
5/89

5/89
5/89
5/89
5/89
7/88
Study
Type

INN
DIET
DIET
DIET
DIET
'

DIET
DIET
NAAQS
NON
DIET
Relative
Absorption
Factor
,
1.00
1.00
1.00
1.00
1.00

1.00
1.00
1.00
1.00
1.00
(1) .oral dose/response values have been used to estimate inhalation exposure risks
IRIS - Integrated Risk Inforation System
SPHEM - Superfund Public Health Evaluation Manual
NAAQS • National Anfcient Air Quality Standard
INH - Inhalation study
DIET - animal diet study
NON • nonspecified route of exposure, based on effects of methyl mercury at specified blood concentrations

-------
                                          TABLE
                          SELECTED DOSE/RESPONSE DATA -  DERMAL  EXPOSURE  (1)

                                       REMEDIAL INVESTIGATION
                                    VINELAND DEVELOPMENTAL CENTER
                    IZ-Jul-89
•
Contaminant of Concern
Carcinogenic Effects
Carcinogenic PAHs
DOT
ODD
DOE
Dieldrln
Noncarclnogenlc Effects
DOT * metabolites
Dleldrin
Lead
Mercury
Naphthalene
Dose/Response
Value Unit
•

1. 156+01 (ng/kg/day)-1
3.40E-01 (ing/kg/day)-*
2.40E-01 (mg/kg/day)-1
3.40E-01 (Ma/kg/day)-!
1.60E+01 (ing/kg/day)-!

5.00E-04 ev/kg/day
5.00E-OS mg/kg/day
6.00E-M mg/kg/day
3.00E-04 ng/kg/day
4.00E-01 ng/kg/day
Source

SPHEN
IRIS
IRIS
IRIS
IRIS

IRIS
IRIS
MCLG
IRIS
SPHEN
Date
'

10/86
5/89
5/89
5/89
5/89
'
5/89
5/89
5/89
5/89
7/88
Study
tw*

DIET
DIET '
DIET
DIET
DIET
•
DIET
DIET
DW
NON
DIET
Relative
Absorption
Factor

0.50
0.50
0.50
0.50
0.50

0.50
0.50
0.10
0.10
0.50
(1)  oral dose/response values have been used to estimate dermal  exposure  risks
IRIS - Integrated Risk information System
SPHEM - Superfund Public Health Evaluation Manual
MCLG - Maximun Contaminant Level Goal
DU - drinking water study
DIET - animal diet study
NON • nonspeclfied route of exposure, based on effects of methyl  mercury at specified blood concentrations

-------
                                  TABLE   17
                      SUMMARY OF MOST PROBABLE CASE RISKS
                     AT THE VINELAND DEVELOPMENTAL CENTER

                            REMEDIAL INVESTIGATION
                         VINELAND DEVELOPMENTAL CENTER
                                       INCREASED LIFETIME CANCER
                                           RISK PROBABILITY
                                               SITE
POPULATION
VDC Clients
VDC Workers
VCRTC Clients
Off-site Children
Construction Workers
SITE NO.l
1.69x10 tt
1.97xlO~7
1.94xlO"7
1.64xlO~8
SITE NO. 3
1.67xlO~7
9.72x!0"7
SITE NO. 4
*™
SITE NO. 5
—
OVERALL VDC
1.69x10 "
1.97xlO~7
1.67xlO"7
1.13xlo"6
1.64xlO~8
                                   NONCARCINOGENIC HAZARD INDICES
                                               SITE
POPULATION
VDC Clients
VDC Workers
VCRTC Clients
toff-site Children
Construction Workers
SITE NO.l
3.25x10 a
2.37x10"*
__
1.68X10"3
6.90x!0"4
SITE NO. 3
--
__
1.36xlO~2
3.l4xlO~2
~~
SITE NO. 4
—
..
_-
1.82x10
1.22x10
SITE NO. 5
--
__
__
2
3
OVERALL VDC
3.25x10 •*
2.37xlO"4
1.36xlO"2
5.13xlO"2
1.90xlO"3
 .89.19T
0030.0.0

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                                  TABLE   18
                          SUMMARY OF WORST CASE RISKS
                     AT THE VINELAND DEVELOPMENTAL CENTER

                            REMEDIAL INVESTIGATION
                         VINELAND DEVELOPMENTAL CENTER
POPULATION
                                       INCREASED LIFETIME CANCER
                                           RISK PROBABILITY
                                               SITE
SITE NO.l  SITE NO.3  SITE NO.4  SITE NO.5  OVERALL VDC
VDC Clients
VDC Workers
VCRTC Clients
Off-site Children
Construction Workers
9.76xlO~4
3.25xlO~5
...
5.13xlO°5
l.SlxlO"6
..
--
8.76xlO~6 —
6.12X10"5
• « <•!<»
9.76xlO~4
T- 3.25xlo"5
8.76xlO°6
1.13x10"*
l.SlxlO"6
POPULATION
                                   NONCARCINOGENIC HAZARD INDICES
                                               SITE
SITE NO.l  SITE NO.3  SITE NO.4  SITE NO.5  OVERALL VDC
VDC Clients
VDC Workers
VCRTC Clients
Off-site Children
Construction Workers
6.29
2.21
_-
2.38
3.85
^ —
--
0.15
0.54
*•
•«>
—
--
4.65
0.72
6.29
2.21
0.15
7.57
4.57
7.89.19T
0044.0.0

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                                   TABLE  19
                 CUMULATIVE NONCARCINOGENIC RISK1 TO SONGBIRDS
              FROM INGESTION OF CONTAMINATED VDC SOILS AND BIOTA

                            REMEDIAL INVESTIGATION
                         VINELAND DEVELOPMENTAL CENTER
                                                  SCENARIOS2
VDC SITE
1
3
4
5
MOST PROBABLE
0.026
0.23
0.036
NA3
REALISTIC WORST CASE
1.5
0.60
0.95
NA
1  Risk values represent hazard indices (His), where HI = body dose (mg/kg/day)
   divided by standard (mg/kg/day).

2  For assumptions used in risk assessment, see Subsection 1.5 and Appendix A for
   risk assessment templates.

3  NA - Risk assessment not applicable because no chemicals of concern were
   detected above analytical limits.
7.89.19T
0025.0.0

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                                   TABLE  20
                           INORGANIC CONCENTRATIONS

                           SITE 80S. 1, 3, 4, AND 5

                            REMEDIAL INVESTIGATION
                         VINEIAHD DEVELOPMENTAL CENTER
                      MAXIMUM CONCENTRATION
SITE
1



3



4



5



CHEMICAL
Arsenic
Chroaiua
Lead
Mercury
Arsenic
Chroaiua
Lead

Arsenic
Chroaiua
Lead

Arsenic
Chroaiua
Lead
s.

o-z iT.
5.2
11
208
0.8
..
..
48

3.7
9.8
410

2.9
5.9
8.9

(ai/kg)
o-i2 FT.
13
36
529
3.7
2.4
8.4
193

2.7
17
410

12
18
8.9

NJ BACKGROUND
(ag/kg) RANGE
0.3-17.1
0.8-20.7
ND-44.0
ND-0.26
0.3-17.1
0.8-20.7
ND-44.0

0.3-17.1
0.8-20.7
ND-44.0

0.3-17.1
0.8-20.7
ND-44.0

New Jersey Soil
Action Levels (imAen\

20
100
250-1000
1

20
100
250-1000

20
100
250-1000

20
100
250-1000
















NOTES:

1 Fields, 1989.

2 One concentration exceeded the NJ background range at this depth (B-112;
  3- to 5-foot depth).  All other concentrations were within the NJ background
  range (Fields, 1989).

3 "Within" indicates the detected cheaical concentration is within the NJ
  background range.  "Exceeds" indicates that concentrations exceed the NJ
  background range.

ND « Non-detect

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                                   TABLE  21
                           PESTICIDE CONCENTRATIONS

                           SITE NOS. 1, 3, 4, AND 5

                            REMEDIAL INVESTIGATION
                         VINELAND DEVELOPMENTAL CENTER
                      MAXIMUM CONCENTRATION
                                               NJ BACKGROUND
New Jersey Soil
SITE
1
3
4
5
CHEMICAL
DDT
DDD*
DDE*
Dieldrin
DDT
DDD*
DDE*
DDT
DDD*
DDE*
Dieldrin
DDT
DDE*
0-2 FT.
0.150
0.020
0.120
0.068
0.018
0.021
0.021
0.022
0.018
0.370
0.320
0-12 FT.
—
0.170
1.600
21.000
0.310
0.018
0.110
0.023
0.370
0.320
(•8/kg) RANGE
0.003-4.600
0.002-1.200
0.003-4.600
0.003-4.600
0.002-1.200
0.003-4.600
Action. Levels
1-10
1-10
1-10
1-10
NOTES:

1 Fields, 1989.

2 "Within" indicates the detected chemical concentration is within the NJ
  background range.  "Exceeds" indicates that concentrations exceed the NJ
  background range.

* There were no specific NJ background ranges for these two pesticides.  They
  were evaluated against the NJ background range for DDT (see Subsection
  2.2.2).

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                          TABLE  22

                Polynuclear Aromatic Hydrocarbons
                         Sites 1,  3 and 5

                      Remedial Investigation
                   Vineland Development  Center
                      Maximum Concentration  New Jersey  Soil
Site

1

3

5 	 	

Chemical

PAH(C)
PAH(N)
PAH(C)
PAH(N)
PAH(C)
PAH(N)
ma/ ka
0-2 ft.
3.175
4.057
. 3.719
5.597
_

Action Levels ma/ka
0-12 ft.
10
10
17.65 10
23.41 10
.172 10
.135 10
C - Carcinogins
N - Noncarcinogins

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SITE  CHEMICAL
        TABLE
CONTAMINANT CONCENTRATIONS
 SITE NOS. 1, 3, 4, AND 5

                       NEW JERSEY SAFE
MAXIMUM CONCENTRATION  DRINKING WATER ACT  MCL's
      January 1983
      Mercury
      Arsenic
      Lead

      November 1986
      Arsenic
  0.5 ppb
 52.0 ppb
   20 ppb
   90 ppb
      Remedial Investigations-1987
      Nickel             41 ppb
 2.0 ppb
50.0 ppb
50.0 ppb
50.0 ppb


13.4 ppb
      May 1984
      Mercury
      Arsenic
      Lead
  0.3 ppb
 54.0 ppb
   20 ppb
      September 1984
      1,1-Dichloroethene  18.0 ppb
      Trichloroethene     23.0 ppb

      Remedial Investigation-1987
      Nickel           179.0 ppb
      Silver            48.0 ppb
      Mav 1984
      Antimony
      Arsenic
      Chromium (total)
      Lead
      Phenols
 14.0 ppb
 21.0 ppb
 20.0 ppb
 10.0 ppb
 10.0 ppb
      SEPTEMBER 1984
      1,1-Dichloroethene  11.0 ppb

      Remedial Investigation-1987
      CLEAN
      Mav 1984
      Antimony
      Arsenic
      Zinc
      Cyanide
 14.0 ppb
 22.0 ppb
150.0 ppb
 23.0 ppb
 2.0 ppb
50.0 ppb
50.0 ppb
                        2.0 ppb
                        1.0 ppb
                        13.4 ppb
                        50. ppb
50.0 ppb
50.0 ppb
50.0 ppb
3500 ppb
                         7.0 ppb
 50 ppb

200 ppb
(NJAC GW STDS)

-------
                      Responsiveness Summary
                             for the
             Completion of the Remedial  Investigation
                             at the
               Vineland State School Superfund Site
                          Vineland City
                  Cumberland County,  New Jersey


This Community Relations Responsiveness Summary is prepared as a
part of the Record of Decision (ROD)  for the Vineland State
School site.  Currently, this site is referred to as the Vineland
Developmental Center  (VDC).  This Responsiveness Summary is
divided into the following sections:

A.   Overview

This section briefly discusses the conclusions of the Remedial
Investigation Study (RIS) and remedial actions taken by the New
Jersey Department of Environmental Protection (NJDEP), and
summarizes public reaction to the NJDEP and United States
Environmental Protection Agency (USEPA)  Proposed Plan.

B.   Background on Community Involvement and Concerns

This section provides a brief history of community interest
concerning the Vineland State School Superfund site and a
chronology of community relations activities conducted by NJDEP
and USEPA prior to and during the RIS.

C.   Summary of Major Questions and Comments Received During the
Public Comment Period and NJDEP's Response

This is a summary of major questions and comments directed to
NJDEP and USEPA during the September 25, 1989 public meeting
regarding  the results of the RI/FS and sent to NJDEP during the
public comment period.  NJDEP's/USEPA's responses are included in
this section.

D.   Remaining Concerns

This is a discussion of remaining community concerns of which
NJDEP and USEPA should be aware.

Attachments

A.   Agenda, Fact Sheet, Press Notice, Public Meeting Notice
for the September 25, 1989 public meeting.

B.   Agenda, Fact Sheet, Press Notice, Public Meeting Notice

-------
for the November 13, 1986 public meeting.

C.   Press Release regarding completion of PCB contaminated
soils removal, January 10, 1989.

0.   List of speakers at the September 25, 1989 public meeting.

E.   Proposed Plan for the Vineland State School site, September
1989.

A.   Overview

At the time of the public comment period, NJDEP and USEPA had
proposed a "no action" alternative for the Vineland State School
site in Vineland, N.J.

For Sites 1,3,4 and 5 of the Vineland State School Superfund
site, NJDEP and USEPA propose that "no action" is the appropriate
remedy to ensure protection of human health and the environment
at these sites.  This proposed no action response at Sites 1,3,4
and 5 is based on an assessment of the nature and extent of
contamination presently existing at the sites and an assessment
of the present and future risks posed to public health and the
environment.  At Site 2, NJDEP performed a removal action to
mitigate the human health and environmental threat posed by the
PCB-contaminated soil.  In addition, the public water supply was
extended to service all the homes adjacent to the Superfund site
which had residential potable wells.  This action was performed
as a precautionary measure to ensure the protection of public
health.

As indicated by comments received during the comment period, the
officials of both the Vineland State School and the local
government support the NJDEP and USEPA selection of the "no
action" alternative.  One citizen, Mrs. Dorothy Lang, President
of the citizens' group, W.A.T.E.R, would like to see continued
monitoring of the site.  She also stated that the NJDEP and USEPA
should agree to take action if site-related ground water problems
are discovered.

 B.   Background on Community Involvement and Concerns

Community involvement has been significant at this site.  Mrs.
Dorothy Lang, a resident of Maple Avenue, adjacent to the School,
has spearheaded a campaign to expedite investigation and
remediation at this site.

Early in 1983, Mrs. Lang formed W.A.T.E.R. (Watch Against Toxic
Effluent Residue).  This organization has conducted a letter-
writing campaign in order to inform and involve the public and
elected officials at the federal, state, county and municipal
levels.  Numerous letters were addressed to the New Jersey

-------
Department of Hunan Services (NJDHS) and NJDEP requesting prompt
action.

The first round of attention generated by these letters came
after an article appeared in the Vineland Times Journal on April
7, 1983 detailing allegations by a crane operator formerly
employed at the Vineland State School.  In response to this
story, W.A.T.E.R. began notifying local residents of its demands
that the State pay for a municipal water line connection to
residents on Spring Road due to contamination found in the
underlying aquifer.  This campaign helped to obtain a December
1983 commitment for funding from the New Jersey Spill
Compensation Fund for a waterline extension.  Under this
authorization, the City of Vineland completed construction of the
water main and billed each resident who, in turn, submitted a
claim to the Spill Fund for reimbursement.

Direction of this citizen campaign changed with the waterline
connection and was then focused on expedited site cleanup at the
Developmental Center.  Mrs. Lang enlisted the involvement of the
Communication Workers of America (CWA), Local 1040.  Letters
continued to be written and petitions containing as many as 500
signatures were circulated in an attempt to focus attention on
the site.

The CWA, Local 1040, the union representing 400 employees at the
school, launched its own campaign on March 15, 1985.  At this
rally, employee and union officials vowed to wear buttons stating
"CWA-Toxic Dump Site-Local 1040" and to keep pressure on the
State until all contaminated areas were cleaned up.  CWA began to
ask state and national union membership chapters for backing.

In March 1985, the NJDEP prepared and presented to NJDHS a
detailed report of the findings of the preliminary
investigations.  The recommendations contained in this report to
NJDHS were to conduct a comprehensive Remedial Investigation/
Feasibility Study (RI/FS) at Sites 1, 3, 4 and 5, and to complete
a design and removal of the PCB-contaminated soil at Site 2.  A
detailed cost estimate and scope of work were provided to support
the recommendations.

While awaiting NJDHS's attempt to obtain a supplemental
appropriation from the State Legislature's Joint Appropriations
Committee to implement the recommendation, NJDEP drafted the
necessary bid documents to hire a consulting engineer to conduct
the work.

In June 1985, the Joint Appropriations Committee denied NJDHS's
request for monies.  Subsequently, the NJDHS and the NJDEP
entered into a Memorandum of Understanding in which the NJDEP
agreed to authorize the necessary monies subject to NJDHS
reimbursement.  In August 1985, Geoffrey Perselay, Acting

-------
Commissioner of the NJDHS, announced the appropriation of
necessary funding to conduct a RI/FS and the removal and disposal
of PCB contamination at VDC.

The NJDEP finalized the bidding documents in September 1985 and
bids for both the RI/FS and Design were solicited in October
1985.  In August 1986, after overcoming delays resulting from the
lack of adequate liability insurance for hazardous waste
contractors and consultants, a "Notice to Proceed" was given to
E.G. Jordan Company of Portland, Maine.  This $530,000 contract
was awarded for conducting a RI/FS at sites 1,3,4 and 5 and an
engineering design for PCB removal at site 2.

On November 11, 1986, the NJDEP held a public meeting to discuss
the initiation of the Remedial Investigation and the start of the
Site 2 PCB-contaminated soil removal project.

The public concerns focused on —


1.  The health of employees and residents at the Vineland State
    School, especially since four employees have had cancer (2
    leukemia deaths and 2 mastectomies).

2.  When the actual cleanup was to occur.

3.  The proximity of the five alleged sites to recreational
    playing fields.

4.  The need for exchanges of information.

NJDEP addressed these concerns in the following ways:

1.  NJDEP recommended that the New Jersey Department of Health
    meet with Vineland State School officials and concerned
    citizens to evaluate the cancer issue and determine the data
    collection needs to evaluate worker and VDC resident health
    issues.  Samples taken during 1985 showed no health risk;

2.  NJDEP agreed to conduct an information briefing to discuss
    the PCB soil removal when the cleanup project was about to be
    initiated;

3.  NJDEP responded that samples taken during 1985 showed no
    health risk at these locations; and

4.  NJDEP set up repositories at Vineland City Hall Mayor's
    office, the Vineland Public Library, and the Vineland State
    School Administration Building.  Also, the Mayor's office and
    Mrs. Dorothy Lang, a concerned  citizen, were notified as
    additional information became available.

-------
The NJDEP held a briefing on May 4, 1988 with local officials to
discuss the Site 2 remedial action project regarding PCB soil
removal.  The project was completed in November 1988,  and press
releases (March 29, 1988 and January 10, 1989) and a fact sheet
(May 4, 1988) were issued.

At the completion of the Remedial Investigation (RI) study, the
NJDEP and USEPA held a briefing on September 20, 1989 with
Vineland State School officials, local officials,  union
representatives, a citizens group representative and Senator
Lautenberg's representative, to discuss the RI study findings and
the NJDEP's and USEPA's proposed plan, and to gather input of
those involved.  This meeting was followed by a public meeting on
September 25, 1989 to present the RI study findings and solicit
public comment.
DATE
Chronology of Community Relations Activities

  Event
Early 1983




12/83


3/15/88



3/85
4/85
6/85
  W.A.T.E.R. (Watch Against Toxic
  Effluent Residue) was formed to get
  citizens actively involved in Vineland State
  School site issues.

  NJDEP commits funds from the New Jersey Spill
  Compensation Fund for a waterline extension.

  CWA, local 1040, holds rally to bring
  attention to the need for cleanup at the
  Vineland State School site.

  NJDEP issues detailed report to NJDHS of the
  findings of the preliminary investigations
  and recommends a comprehensive Remedial
  Investigation at sites 1,3,4 & 5 and removal
  of PCB-contaminated soils at Site 2.

  Briefing held between NJDEP, NJDHS and local
  officials to discuss progress of proposed
  remedial actions at the VDC site.

  NJDEP and NJDHS enter into a Memorandum of
  Understanding in which NJDEP agreed to
  authorize the necessary monies to fund a
  Remedial Investigation (RI) and PCB Design
  and Remediation subject to NJDHS
  reimbursement.
8/20/85
  NJDHS announces the appropriation of
  Necessary funding to conduct a RI (5 sites)

-------
                    and removal and disposal of PCB-contaminated
                    soils at VDC Site 2).
8/21/85




4/86


10/24/86





11/13/86
3/29/88
5/4/88
1/10/89
9/7/89 and  9/8/89
9/8/89
Rally held at Cumberland County College by
W.A.T.E.R. and CWA, local 1040, members
regarding delays in initiating site cleanup
activities.

Community Relations Plan (CRP) prepared by
NJDEP.

Notices sent to those listed on the contact
list of the CRP announcing the 11/13/86
public meeting.  Press release also issued at
this time.

Public meeting held at the Vineland City Hall
Council Chambers to discuss the initiation of
the RI and Design Study for soil excavation.
Approximately 40 people attended including
citizens, local, state and county officials,
CWA Union officials and media representa-
tives.  Fact sheet issued at this meeting.

Press release issued announcing award of
contract to perform removal of PCB-
contaminated soils and PCB-contaminated
structures at the Vineland State School.

Briefing held to discuss remedial action for
PCB soils removal and remedial construction
for the Vineland State School site.  Fact
sheet also issued at this time.

Press release issued announcing completion of
PCB-contaminated soils and structures at the
Vineland State School site.

Public announcement issued in "Vineland
Daily" newspaper describing NJDEP and USEPA
Proposed Plan and its availability along with
the Remedial Investigation Study (RIS)
documents in several local repositories.

Proposed Plan, RIS, Site 2 documents
(construction plans, design report and plans
and specifications) as well as "as
built" drawing of waterline extension were
placed in five locations:  Vineland City
Hall; Vineland Public Library; Vineland State
School Administration Building; NJDEP in
Trenton and USEPA in New York.  The public

-------
                    comment period was from September 8, 1989 to
                    September 28, 1989.

NOTE:  Proposed Plan and Site 2 documents were given to Mrs.
Dorothy Lang of the W.A.T.E.R. citizens group.

A notice of the September 25, 1989 public meeting and the
availability of the Proposed Plan, RI/FS and other related
documents were sent to those listed on the contact list of the
Community Relations Plan and those listed from the November 13,
1988 public meeting sign-in sheet.

9/20/89                       NJDEP and USEPA held a briefing
                              for municipal officials, VDC
                              administrators, CWA
                              representatives, a
                              representative of the citizens
                              group W.A.T.E.R., and a
                              representative for Senator
                              Lautenberg at the Vineland
                              Developmental Center.

9/25/89                       A public meeting was held at the
                              Vineland City Hall Council Chambers
                              to discuss the completion of the
                              RI/FS and Proposed Plan.

Ongoing telephone contact and written correspondence was
maintained throughout the project between NJDEP and state and
local officials, VDC officials, CWA officials and Dorothy Lang of
W«A*x*E*R*

C.   Summary of Major Questions and Comments Received During the
Public Comment Period and NJDEP's Response.

On September 8, 1989, the Remedial Investigation/Feasibility
Study, Proposed Plan, and Site 2 cleanup documents were placed in
the three local repositories  (listed in chronology).  These same
documents were also placed in repository at the NJDEP
Headquarters Building, 401 East State Street, 6th Floor, Trenton,
NJ and USEPA, Region II office, 26 Federal Plaza, New York, NY.

The public comment period was from September 8, 1989 through
September 28, 1989.  Comments were received during the September
20, 1989 briefing at Vineland State School with local officials
and at the September 25, 1989 public meeting.  One written
comment was received by NJDEP and USEPA during this period.

Following is a summary, of all major comments/questions received
by NJDEP and USEPA at the briefing with local officials, public
meeting and during the comment period.  Because only limited
comments/questions were received, they are in order of receipt.

-------
Comments by Mrs. Dorothy Lang

Mrs. Dorothy Lang is the President of W.A.T.E.R., a local
citizens group.  She expressed concern that NJDEP did not locate
all the dumped material at the Vineland State School site.  She
strongly requested that the NJDEP and USEPA develop a groundwater
monitoring program in order to adequately protect the local
aquifer.  She also stated that NJDEP should agree to take action
if site-related ground water problems are later discovered.

Response:  Based on the information of past disposal practices
at the Vineland State School by both current and former employees
of the institution and the findings of the field investigations
conducted, NJDEP has adequately characterized the nature and
extent of hazardous contaminants existing at the five (5)
subsites.  Any future leaching of hazardous waste contaminants to
groundwater is not anticipated for the following reasons:

1.   The native acidic groundwater, the high soil permeability
and shallow horizontal groundwater gradient combine to
create a conducive environment to contaminant leaching of
waste materials buried more than 20 years ago should have
resulted in chemical leaching to groundwater.  Current
sampling results indicate the groundwater is not contaminated.

2.   The findings of the RI/FS did not substantiate large
quantities of hazardous waste material burial at Site 1 as
reported to the NJDEP and the low levels of PAHs,
pesticides and metals remaining at the various subsites
are highly immobile having strong absorption/adsorption to
soils and low water solubility.

However, as a result of continued public concern, NJDEP and USEPA
proposes to develop a monitoring program to assure that our
conclusions are correct.  This monitoring program will consist of
perimeter downgradient monitor wells at the site boundaries to
monitor ground water quality.

Additional Comments of Mrs. Dorothy Lang

Mrs. Lang requested that a City of Vineland public supply well
located one block from the Vineland State School be tested at six
(6) month intervals by the N.J. Department of Human Services,
owner of the Vineland State School site, for the contaminants of
concern at the Superfund site.  She noted that the MA-280" state
law which stipulates periodic monitoring of public water supply
wells requires water quality analysis only every three years
which is an insufficient time interval in her opinion.

Response:  The perimeter groundwater monitoring program to
be developed and implemented by NJDEP will include sampling of


                                8

-------
monitor wells that are between the Vineland State School site and
the City of Vineland Supply Well #11 near the intersection of
Brewster Road and Maple Avenue, approximately 3600 feet from Site
3  (the closest of the 5 subsites).  If site related ground water
problems are detected during the monitoring, sufficient lead time
would be available to take the necessary actions to protect the
supply well.

A  final request of NJDEP and EPA made by Mrs. Lang was to insure
that all residences in the northeast quadrant of the City be
connected to the City of Vineland public water supply.

Response:  All residences in the area bordered by Landis
Avenue to the south, Jay Terrace/Linwood Avenue/Alps Place/Chapel
Avenue to the east, Main Road/Becker Drive to the west, and Oak
Road to north are connected to the City of Vineland Public Water
Supply.  The concern for potable water usage in the northeast
quadrant of the City will be addressed by NJDEP's perimeter
monitoring program.  This monitoring will detect any site-related
groundwater contamination emanating from the Vineland State
School sites.  If site-related groundwater problems are detected,
the necessary steps to protect public health will be taken by
NJDEP.

Comment of Mr. George White

Mr. George White, Senior Staff representative of the
Communications Workers of America (CWA), Local 1040 (Trenton,
NJ) .  His concern is that Union workers (400 at Vineland State
School) be protected in their everyday endeavors at the Vineland
State School site.  Specifically, he was concerned about dermal
and airborne exposures from the sites.

Response:  Current risk levels and future risk levels assuming
no further remedial actions were projected for Vineland State
School workers as well as all other subpopulations (Vineland
State School clients, Vineland Children's Residential Treatment
Center, off-site children, and future construction workers) that
could potentially be exposed to the five subsites for all
exposure pathways as part of the Public Health Risk Assessment.
This risk assessment demonstrated that carcinogenic and
non-carcinogenic risk estimates were below or within target risk
levels adopted by USEPA under the most probable case and
worst-case risk-exposure scenarios for the Vineland State School
workers.

Comment of Mr. Joseph Barr

A comment was made by Mr. Joseph Barr, retired Vineland State
School employee, regarding past disposal activities at the
Vineland State School sites.  He was concerned that NJDEP has not
located all the disposal areas and would like to see additional

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investigations conducted for hazardous waste material.  He was
further concerned that soil runoff during storms may have
transported hazardous materials off-site.  Mr. Barr requested
monitoring every 3 years at the site.

Response:  NJDEP investigated all the site areas that were
reported as disposal or spill locations by both current and
former employees of the institution and comprehensively
delineated the nature and extent of contamination at each of the
areas.  The NJDEP monitoring program to be developed and
implemented will evaluate groundwater quality from the entire
Vineland State School site and not just the five (5) subsite
areas that were investigated under this Superfund investigation.
With regard to surface runoff, surface soils were not found to
contain levels of contamination that are considered
hazardous and, therefore, surface runoff does not pose a health
risk to any of the subpopulations in the site area.

0.   Remaining Concerns

All issues or concerns that were raised during the public comment
period have been addressed in this responsiveness summary.
Concerns with regard to future site-related ground water quality
will be addressed by NJDEPs proposed monitoring program.

Attachments

(See listing at beginning of Responsiveness Summary)
                                10

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             TT> I v ? : ,1 tf^'. ^  /^V f r  r> U f. • ^
. , , \.  -
'  I /                 i                         //
             ATTACHMENT A

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                        i fit NEW JERSEY

                       'DEPARTMENT OF

           ENVIRONMENTAL PROTECTION

    ANNOUNCES PROPOSED PLAN FOR THE

      VINELAND DEVELOPMENTAL CENTER

             SUPERFUND SITE, VINELAND,

       CUMBERLAND COUNTY, NEWJERSEY

   The Mew iloroey OepertaieiH of ffnvfrenmental rVeieetfen flUDV) reaofltty eempftted t romediel
 bwcttigatfon etudythat mvoettgated alleged hasardous waete diepoeal feletod t* the VtaeUnd Develop.
 mental Center (VDC) tuperfundlarte hi Vhieland. New Jeroey. Meed MI the remedlol moeaure* that have
 been completed to date and the finding* of tlra remedial Inveetigaiion. HJDtP tt propoelng that no further
 remedial actlono are aeeeeaary t* protect puMto health and tha environment tt thfe ftuperfund iltt.
   AWore a Kooerdef&ecJalon wffi be aim** the hUDi* wrfll oanaMer written and oral comment* through
 September It, 1taj. The final dcctofon document wW include • summery of public comment* and HJGtf
 reepwifteo.    •                            '
   HUOEP wffl *»U• publlo iMMta0 ON t^tomkor !•, 1M9, M »:00 Ml •! tfit Vtaotond CHy H«tl, 7th and
 Wood f trottt, VlMtentf. Mm Joraoy. THo •nmott of tMt nwothia to to (1) dUouvt ttra ftndlnf • af the
 ftomodlal InvMtfvatton; (2J tfoull tho ramtdtal IMOMUTM KrMdy •ofl^Mod by NJOf* to •«•" tnd (J)
 dteain» MJDiT» propfliod »!•» to tah« no tddltton*! octkrn at tM tho.      .
 •  Tko VDC •iipoffHnd tit* b otrnpriMd of flvo tuiMlt*« wftfoh wort Montlftod M hoving Mt«nti«> or
 MttMl rato«a«ii of fMurdout ohomtooli. TlioM MiboltM fmlwd*: two fomtor VDC rtf UM dJaooMl «r*M thcf
 r«M»v*d Mein«i«t«p Mh and toUd wattot gtMratod by tHo VDC (*K** 1 and «); an arM at whtah •€•
 (peJyoMorinatotf Mphanyto) tontamlnattd tnnafotmar eR WM apntad («H* 2); a rtata-ownod vo«ant lot
 formally uood by MM Now Jorooy »op«rtmaiit of Transportation oa a Mabitoiwfioo Vard (aH« 4); and en
 aUofod pocttoldt burial aHo (aHo •). tftoa 1A Md • aro fooatod on tha oampu* ground* of UM VDC, «H« ft Ic
 tooatad at tho roar of tfca VInaJf nd ChMron'a rUatdanttal TrMtmont Comor and aha 4 la loo«tad at tha and
 of a raaMaatioJ atroot apur, M*fan Court.
   AaareaiirtaflAMairemealallnveatifletlematttoer^^
* and e eomamlMtetd> pottMc Ural at • IpHng Uaae! rceUcnea dawngradiant from tha VDC aha. laced on
theaainrtlal flndtogf, MJOffP Implemented the following remadtel meacwrea:
  - ferfarmed e public hearth rick aeteccment ta define the deanup level for PCf contaminated' cell.
                                                 i aanalated of removal and tfUpocal ef
  *• tAeot ejreevetlen aampflng ta eneirre the clean ap Icveto ware achieved.
.  — htetcMetfenofajieepnaftecp, dnmeaecyetem, endceewrltyfenee.
 • — Iholded M J. tpdl Campencatlaii Fund maniac for the City of Vlnotend'c aanatrvetton ef e wetar
  * r«iain a*tea*ian ta acrvtoe eV the.recidance* adjaaant to the Superfufid afte which attained their
    aVhihing waiar Irani private weBa.

   laced an tha racuHc af the recently completed Remedial Inveetlgctfea Hepart hUOff prepcte* that
*«a further acton" to warranted ta enaure preteatfan af human haahJi and the environment at thccc cltce.
Th4* prapeial at **te* 1,3.4 and • to baeed an an aaeeaament af tha nature and extent of oontanUnante
preeeirtfy etlcttea at the aftae and an oeceeemoflt af tho proaae* and future ri»k*paa*dta|Hihne health and
the environment by theeeeoAtamlnante.                          . •

 •round water te ne< aantamlnatad by ch)a rehncalaubeunaaaaajd to not aapcotcd ta be contaminated hi
the future. Mono af the atJetettofia af atopaaal af atojnMaaat auantrtlea af hacarafeia eubatancc* were
aanflrmed. twrfaoe aaO* aaatabi baakji-eund ttvatc af pactfaldca. and meraury, and cparadlc elevated
levehi af FAM* (paJynaeJear arematle hydreeerbane) and load. PAH* and toad are Mbttane** uMe.uHeu* in
urban and aubnitait oaxnVxmonta. tporadle, nlathnhj M§h voJuee of thoao ebemfaato are nnaraHy
eommoA b» thoee emHrooomttit, aiM do not oonatfuiu an onaeoal or ojteeiahre Ha* to pubfle hearth. Meet
•rejbabla eaee rmman baaHh fMu oetfmatod to reooH from oipoewe to the oho ohemieato are wHhhi the
UJ. InvironmoM*! ProtaaHaa Afonoy tat«et range of 10^(f exeeee eenaof I* a petwlatfen of 10,000) te
 evr (1 owooaa aonoer m a peevtoJon of 10,000,000) far •fatima (TO yeart) e«eoM canoar fjaka. Mo advefoe
haafth affect* art pradlctad daa to cj^ctiiretoe)oneaie^a'>nrThepjnbabhi>> af aialoglaalhppceta_afe

rtohjefcBpoearctoSe^BbctanooipMcantattheVPCefeBati
>V|rM
                                giJdk^JaajeV Aa^Bfl*«eaaWa^^ A fJBtAll a**) tjoaiaK JbaalaW
                                f**~"*^ W|?WEfeWv Vf YMV aflBISJ f^W
                   ,;  TtfmtdHrooaltfmtt  .       im r»l I t*l* fl > i
>0itffJfntf,lUOttM    ^VtMUnclrVOiMO        '   VbiotanoVI

            ^ ^aVItUii etfmmtirtt •« tfittVopottel Plan thai
                 '      •
                 JU. Oyattmtftt • r«XH^v^ by NJDEP no) Ie*«r than SaptemtwM.

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           Public  Meeting  Notice
                                  Public Meeting
                                    to Discusa             "     f
                      Results of the Remedial Investigation Study
                                     for the
                     Vineland Developmental Center Buperfund Site


      A public •••tint will  b« held by the New Jersey Department of Environmental
      Protection  to discuss the results of the Reaedial  Investigation Study  and
      the Proposed  Plan for the Vineland Development  Center Superfund site.   The
      meeting will be held on:

                             Monday, September 25, 1989
                                     7:00 PM
                                 Council Chambers
                             Vineland Hunicipsl Building
                                7th 4 Wood Street!
                                   Vinelend, NJ
                                 Cumberland County

      The Remedial  Investigation Study Report  and the  Proposed Plen ere available
      for review at the follotHnf repowftories:
      Vinelend Municipal iuildini
      7th and Vood Streets
      Vinelead, NJ  08360
      Contact:  Linda OeMatte
      (609) 794-4000
      •
      Vineland City Library
      2058 East Ltndls Avenue
      Vinelend. NJ  08360
      Contact:  Anthony Agnesino
      (609} 794*4244
Vineland Developmentel Center
1676 East Landis Avenue
Yin*land, NJ 08360
Contact:  Robert Sftith
(609) 696-6007

Now Jersey Departatent of
 Enviroiwentel Protection
Division of Raserdous Site Mitigation
401 last State Street, 6th Floor
Trenton, NJ  08625
Contact:  Donald lakes
(609) t84-3081
     Coments on the Report and the Proposed Plan should be received by September
     26. 1969 and addressed to:

                              Grace L. linger. Chief
                            Bureau of Cosewnity Relations
                        Division of Rasardons Site Mitigation
                   New Jersey Departa>ent of Environmental Protection
                      CN 413, 401 East State Street. 6th floor
                                Trenton, NJ  08625

     For further  information, please eontect  Donald Kakea, Coevunity Relations
     Coordinator, Division of Ruardous Site Mitigation, at (609) 964*3081.
Ntw Jersey Department of ErwtonmsntU Protector e Bireau of Corrmrity Reteiiom • eo»&94.-308.i

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ATTACHMENT £

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                                                   STATE OF NEW JERSEY
                                           OCPANTMINT OP SNVIRONMCNTAL PROTECTION
                      DIVISION OF HAZARDOUS SITE MITIGATION
                                 Public totting

                                       on
                               Coanenceaeat of the
                    Reaedial Inveetigation/Feaaibility Study

                                       at
                       Vineland Developmental Center Sice
                                    Vineland
                                Cuaberland County
                           Thursday, November 13, 1966
                                    7iOO P.M.
                               Vinaland City Ball
                                Council Chaabera
                              7th and Wood Streete
                                  Vineland, NJ
                                     AGENDA
1.   Opening Rentarka;
     Introduction of NJDEP Pereonnel
2.   Community Input
3.   Overview of Hlatory and
     Statuej
     Introduction of Contractor:
     B.C. Jordan Co.

4.   Presentation:  Reaedlel
     Investigation/Feasibility Study
5.   Qusseiona and Aaavera
BS119tfb
Mr. Charles DeVeese, Chief
Bureau of Site Management
NJDEP

Ma. Grace L. Singer, Chief
Bureau of Community Relations

Mr. Joseph Meher, Site Manager
Bureau of Site Manageaent
Mr.  Mike  Kelrn,  Technical  Director or
Mr. Elliott Thomas, Renedial  Investigation
Coordinator  -  B.C. Jordan Co.
                               Jtnty Is An Equal Opportunity t

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                                 ftatr of fcfrui
                    DEPARTMENT OF ENVIRONMENTAL PROTECTION
                             DIVISION Of HAZARDOUS SITE MITIGATION      ,
                                    CN 028. Trtnton, N. J. 08625
                                        600 • 084 • 2002
HICMAHO C. SALKit. *.«.
  ACT<*o omectoA

                                         NOTICE

                                     PUBLIC MEETING
                                       to Dlacuea
               Initiation of Che Remedial Inveatigation/Feaaibility Study
                          and Deaign Study for Soil Excavation
                                           at
                              - Vinaland Devalopaantal Sita
                                        Vinaland
                                    Cumberland County


    A  public matting  will  be  ha Id by  tha  Nav Jersay  Department of  Environmental
    Protection  (NJDEP)  to  diacues  tha  initiation  of  the  Remedial  Investigation/
    Feaaibility  Study   and  Daaign  Study  for  Soil  Excavation   at   the  Vineland
    Developmental Canter alta.  The meeting trill be held on:

                               Thursday , November 13, 1986
                                        ?.»00 P.M.
                     Vinaland City Hall .- lat Floor Council Chaabera
                                  7th «nd Wood Streeta
       •                               Vineland, NJ

    For  further  information, pleaae contact  Kevin Kratina. Senior Area  Coordinator
    of the Bureau of Community Relationa at (609) 984-3081.


    ES119ifb
                           HfH- Jtnuty Ix AH Equal Offvrtuuiiy

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                                                   •TATf OF NCW JERSEY
                                           DIPAMTMKNT OP INVIMONMCNTAl. PftOTKCTION
                                   FACT SHEET


                                 Public Meeting
                                       on
            Initiation  of  the Remedial laveatlgatioa/Feaeibility Study
                                       •ad
                 Dealga Study for Polychiorinated Blphenyl  (PCB)
                            Contaminated Soil Removal
                                     «t the
                       Vineland Developemental Center Site
                                    Vinelaad
                                Cumberland County
                                November 13. 1986


Site Description

The  Vine land Developmental  Canter  Super fund aite  conaiat* of  three  individual
properties ovnad by the New Jaraay Department of Human Servicea (NJDHS) .  At this
aite the NJDHS eparatea an inatitutioa for the mentally handicapped, the Vinaland
Developmental  Canter  (often  referred  to by  ita  foraer  name  "Vine land  State
School")  and  tha  Vinelaad  Residential  Canter,  a  facility  for  emotionally
diaturbed  children.    The third  property,  a vacant  lot,  formerly aarved  as
gravel pit  area  and was uaed at  one  tine  aa a maintenance  yard area  by the
Jeraey Department of Traaaportatioa.

The 195 acre campus of tha Vine land Developmental Center la eompriaed of numerous
buildings  to house, fead,  educate  and cara for  the needs  of  tha approximately
1400 reaidenta at  the  inatitution,  the  administration and maintenance facilities
to support  the aehoola operatioa,  aa  vail aa large  open  areas  for recreational
purpoaea.   The State School is bordarad oa tha we at  by  Main Road  (NJ Route 55),
oa the eouth by Land i a Avenue, oa  the  aaat  by Spring Road, and oa the aorth by
Maple Avenue.  The majority of the property surrounding tha State School property
is Eonad  rasidaatial.   The aaat  sida  of  the site draina  into Bear Branch Creek
and  the  west  sida  drains  into  Farvla  Branch  Craak.    Bear  Branch  Creek  is
approximately  2000  feet  aaat   of   the   School   sad  Parvin  Braach  Creek  ia
approximately  one  mile southwest  of the  School.   Both streama empty  into  the
Maurice River,  There sra BO kaovn potable water intakes on aitbar of tha creeks.

Site Background

As a  result of  initial  information racaivsd  by XJDEP  in February 1980  froa a
former employee  of  the  State School,   subsequent  information racaived  by Mev
Jaraey  Department  of  Environmental  Protection  (NJDEP)  from  another  foraer
employee  and  current  employees  of  tha  laaeitution,  and  preliminary  remedial
investigation* conducted by NJDEP at tha alleged sites, five individual locations
have  baaa  identified  aa  aithar  contaminated  with  hasardoua  substancea  or
potentially  contaminated  aa a  reault  of  activltiaa  conducted  by  the  Viaaland
                            >H' Jtr**y Is An Equal Opportunity

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State  School  during  the  approxiaate  period  between  1952  and  1976.    Theie
locations have been neaed Sltee 1 through 5.

In  December 1982.  the VDC  site  waa ° included  on  the  initial llat of  proposed
Superfund altas published by United States Environmental Protection, Agency (EPA).
Of  the 97 New Jersey  aitea currently on  the  National Priorlciea list,  the  VDC
•ita ia ranked 50th.

NJDEP  has taken  numeroua  actiona  on  behalf  of  the NJDHS  to invcatigate  the
allegations  of  hazardous waste burial and/or •pillages  at the State  School as
detailed  below.   In addition  to  the NJDIP's action,  following la a  brief aitc
description and auanary of sampling reaulta at each location.

Site I

Thla open grassed field site  is  located  in the northeast  quadrant of the State
School campus  between a  caapground area and a  recreational pavilion.   At thie
location  during  the 1950s and  1960s,  the aehool operated  an  Incinerator and an
adjacent  dump  area  which was  utiliced  for diaposing  of  materials inappropriate
for  incinerator  burning and  the  realdue aah  from the burning process.   It Is
alleged that  containers of mercury  and/or  arsenic baaed aubatancea were dumped
here.

NJDEP  ha a asapled  potable  welle at reaideneea neighboring the  alleged aitea,
Installed  three   aonltoring  wells  and aaapled  theae  welle,  and conducted  an
exploratory excavation in search of the alleged containera of chemical* including
•oil  aampllng  froa  the  excavated  trenchea.    The  City of  Vineland  Health
Department participated  In aplit  sampling  of  the nonltor  walla on one  occasion
and independently aaapled neighboring potable veils on another occasion.  In one
potable  well  on  Spring  Road  the  preaence  of  mercury  was   detected  and
intermittently  exceeded  the  proposed  federal  inter la  priaary   drinking  water
standard  of  2.0  parta  per billion  (ppb).   Araenic  we a  detected  in  two of  the
three monitoring  wells exceeding the  federal  drinking water  standard of 50  ppb
(Well 12  in  1/24/83 (52 ppb) and Well 13 on 11/1/84  (90  ppb).  Higher levels of
various heavy  aetala  (including,  but not  limited  to,  lead,  araenlc,  mercury,
cadmium,  selenium,  and  cine)  above  that  which would  be  expected as naturally
occurring in New Jersey soils and low levele of organics (leaa than 100 ppb total
organica) were detected in foil aaaples from the teat pita.  No eontaainants were
found  in  the aurface  soils  that  would  conatitute a hazard  to  the  community.

Site 2

Thla aite ia located within  the northweat  quadrant of the State School caapue in
and around the atorage abed identified as  Building 129  in  the Campus Site Plan,
NJDEP waa notified  that oil froa three out-of-service  tranafomera were spilled
by  a  acrap metal company contracted by  the  School to reaove the tranaformers.

MJDEP conducted four separate  rounds of soil  sampling in an effort to define the
lateral  and vertical  extent  of  polychlorinated  biphenyl  (PCB)  contamination.
Theae four aaapling rounds provided for the analyais of aaventy soil aaaples.   In
addition, coapoalte eedlaent  samples from two  storm dralna  were obtained  and
analysed.  The presence  of  ?CBs in  soil samples waa detected at level* up to 725
parta per million (ppm).  The State School haa complied with NJDEP'a directive to

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•reet security fencing around the site. and construct a berm around and cover the
alleged spill area  to prevent eontaalnanc runoff.


Site 3

Thla alee eonaista of  the approximate five  acre  northern half of  the  Vineland
Realdential Center  property bordered on  ehe  north  by a city park, on the veit by
ehe  rear  yarda  of the  realdeneea  on Becker  Drive,  on  the  aaat by  th« higher
elevation  open  adjaceac property,  and on the  aouth  by the newly  built recrea-
tional building  and aeven other building* ehat  comprise  the  Residential Center.
The heart  of ehe alleged  duaping  liea approximately 2100 feat north  of Site i.
It la alleged chat  thia location had baen uaed by ehe achool aa a refuae dump for
an  approximate  can year  period  during  ehe  1950s  and  aarly  1960a.    It  la
conceivable  chat outdated agricultural  chemical products  from the VDC farming
operation  could  have been disposed of  at  this location.   In May 1984,  NJDEP
installed three monitoring valla and subsequently  ssmpled these veils  in May and
September  1984.   Araenic vas detected at  54 ppb in one of the three  monitoring
veils,  exceeding ehe federal drinking  vater  atandard  of 50 ppb.  The preaence of
organic chemical compound*  at levels  betveen  105 ppb  and   132  ppb vere  also
detected in each of the three monitoring vella.

Site 4

This sice, s former gravel pit  area and  presently  a vacant lot, la approximately
3.3 acres  in size.   It  Is located vlthln  a residential area  approximately 750
feet east  of ehe  Vineland State School eastern border betveen Spring  Road and
Megan Court, a dead end street spur off of Linvood  Avenue.
It is alleged that betveen 1952 and 1957, transformer oil from retired
transformers vaa  burled at  this  location.  The  alleged dump area  Is  currently
secured by a fence covering an area of approximately 150 feet by 75 feet.   In May
1984, NJDEP installed three monitoring veils and subaequently sampled eheie vella
In May  and  September  1964.   In addition,  soil samples  vere collected  In  the
alleged contaminated area  in May 1984.  Organic  chemical  compounds  up  to 86 ppb
total vas  evident  in  one  of the  three  monitoring veils.   The  security fence
around this  location  has been periodically  vandalized but  ehe State School  has
made repaira as needed to maintain the eecurenees of the duap area.

Site 3

This alee  is an approximately one  hundred square feet area located in a vacant
field near the veatern border of an unnamed dire  road betveen ehe vater cover
parking lot  (adjacent  to  Building  132  on  ebe  Campus Sice Plan) and ehe  farm
•corage shed Identified  aa Building 135 on  ehe Campus  Site  Plan.   Zc  is  alleged
ehat some  time during ehe  period 1952 to 1957, approximately 10  cubic yards of
pasclcides contained in bags  and  rusted  five gallon metal containers vere buried
here in a pie approximately 10 to 15 faet deep.

NJDEP Installed a  monitoring veil at  this alee  In May 1984 and aamplad  here in
May  and  September  1984.   In addition,  one  composite aoil  sample vaa  collected
from the monitor veil boring. The prasencs of organlca at 165 ppb vas detected in
the monitoring veil at this site.

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                                                   SITE 3
  P»ftOC
 AVENUE
!   MOTT08CMC
           SITE LOCATION MAP
VMELAND DEVELOPMENTAL CENTER
          VWELAND. NEW JERSEY
	CCJORCMNGQ

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 Sitee  1.3.4.& 5

 In  addition, NJDEP obtained soil samples froa the ground surface at each of these
 sites  in order to identify the potential for any health risk.  The result* of the
 •aoples indicate that although aooe heavy aetal parameters were found to be above
 background levels, they do not constitute a hazard.

 Current Activities

 Zn  March 1985, the NJDEP prepared and presented to NJDHS a detailed report of the
 findings  of  che  preliminary  investigations.   The recommendation*  contained  in
 this  report  to  NJDHS were to  conduct  a  comprehensive Remedial  Investigation/
 Feasibility  Study (RI/FS)  at  Site*  1.3,4  and  5  and  to  complete a  design and
 removal of  the  PCB contaminated soil at Site  2.   A detailed  cost  estimate and
 •cope  of work vere provided to support tha recommendations.

 While  awaiting NJDHS'a  atteapt to  obtain  a euppleaental  appropriation  froa the
 State  Legislature's  Joint Appropriations  Committee  to inpleaent the  recommen-
 dation, NJDEP drafted the necessary bid docuaente  to hire a consulting engineer
 to  conduct the vork.

 In  June  1985,  the  Joint  Appropriations  Coaaittee denied  NJDHS's  request  for
aonias. Subsequently, the  NJDHS  and che  NJDfP  entered  into  a Memorandum  of
 Understanding in which the NJDEP agreed to authorize the necessary monies subject
 to  NJDHS reiaburseaent.   In August 1985, Geoffrey  Peraelay,  Acting  Commissioner
 of  the NJDHS.  announced the  appropriation of necessary funding  to conduct  a
Reaedial Investigation/Feasibility Study (RI/FS) and  the  reaeval and disposal  of
PCB contamination at VDC.

The NJDEP finallted the bidding documents in September 1965 and bids  for both the
RI/FS  and Design were   solicited  in  October  1985.    In  August  1986,  after
 overcoming delays resulting from the lack of  adequate liability insurance for
hatardous waste contractors and  consultants,  a "Notice to Proceed"  was given  to
 E.G. Jordan  Company  of Portland, Maine.  This  $530,000 contract was awarded for
conducting a RI/FS at cites 1,3,4  and 5; a ground  water study  at  sits 2; and  an
 engineering  design  for  PCB reaoval  at tlte  2.   E.C. Jordan has  developed  a
 14-month schedule for completion of this project based  en one round  of aaapling.
Any  additional   sampling during  che course  of  this  project will  delay  the
schedule.

Field  activities started  October 6, 1986 at site  2.  Nineteen  soil  sample* were
obtained and analysed for PCBs.  Laboratory results froa this sampling effort are
presently being validated by NJDEP's Office of Quality Assurance.  This data will
sealst I.C.  Jordan  In preparing a  design  for  the  contaminated  soil  removal.   A
 eeparate contract for che eoil excavation  and  disposal  will follow after reaoval
specifieatlone ere  complete.   These  specifications will  be completed  10 weeks
after che extent of che PCB contaminated soil has been delineated.
HS119:fb

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VINELAND DEVELOPMENTAL CENTER

       RI/FS OBJECTIVES

REMEDIAL INVESTIGATION

 • DESCRIPTION OF NATURE/QUANTITIES OF
   HAZARDOUS MATERIALS RELEASED
 • DESCRIPTION OF THE HYDROGEOLOQICAL
   SETTING

    • GEOLOGY
    • GROUNDWATER
    •SOILS        .-••
    • SURFACE WATER
    •ONSITE
    •OFFSITE
   EVALUATION OF THE ROUTES OF
   CONTAMINANT MIGRATION
   ASSESSMENT OF ANY PRESENT AND
   POTENTIAL FUTURE IMPACT TO HUMAN
   HEALTH AND THE ENVIRONMENT

    • QUANTITATIVE PUBLIC HEALTH EVALUATION
     VDC CLIENTS
     VOC EMPLOYEES
     OFFStTE RESIDENTS
    • CONTAMINATION BACKGROUND/OTHER SOURCES
    • SITES 1-5

-------
VINELAND DEVELOPMENTAL CENTER
         RI/FS OBJECTIVES

   FEASIBILITY STUDY

    • DETERMINATION OP NEED FOR SOURCE
      CONTROL ACTIONS
    • DETERMINATION OF NEED FOR MIGRATION
      CONTROL ACTIONS
    • DEVELOPMENT AND EVALUATION OF
      APPROPRIATE SOURCE CONTROL AND/OR
      MIGRATION CONTROL ALTERNATIVES
             - SCREEN TECHNOLOGIES
             - ASSEMBLE ALTERNATIVES
             - DETAILED ANALYSIS
    • EVALUATE NO-ACTION ALTERNATIVES
    • RECOMMEND REMEDIAL RESPONSE(S)
    • CONCEPTUAL DESIGN
    • (DELIST SITE FROM NPL)

   SITE 2 PCB REMOVAL

    • CONFIRM EXTENT OF CONTAMINATION
    • ESTABLISH CLEANUP CRITERIA
    • DEVELOP REMOVAL DESIGN
    • SUPPORT NJDEP CONTRACTOR SELECTION
    • MONITOR REMOVAL ACTION
    • SUPPORT SITE CLOSURE

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                                 Cloeeery of Terme


 Adalnistratlve Conaent Order (ACO);   A  binding  legal docu&ent bctveen s govern-
 ment agency and a reeponaible party.  It  is  Issued by  the government  In the fora
 of an  order  that apecifiee  site  mitigation activities to ba mndertaken  by the
 responsible party.                                          '     «

 Contract t    The  legal  agreement that  outlines  federal  and atate  government
 responsibilities  at USEPA-lead  aites on the National Priorities List (luperfund
 aitaa)  aa  authorised  by the  Comprehensive Environmental laaponae, Compensation
 and Liability  Act (CERCU).

 Cooperative Aireeaent;    An agreement  whereby CIEPA traaafara funds and other
 raaources  to  a  atata  for  tha accomplishment of  certain  retediel activities at
 •itaa  on  the  National  Prioritise Liat  (Superfund  aitee)  aa  authorised  by the
 Comprehensive  Environmental Response,  Compensation and Liability Act (CERCU).

 Engineering Pesitn  (Remedial Deelgn);      following   a  feaaibility   atudy,  an
 engineering dealgn ia  executed to  translate the aelected remedy in accordance
 with engineering  criteria in  a  bid  package,  enabling implementation of the aite
 remedy.

 Focused Feasibility Study (TTS);   A limited feasibility atudy which ia performed
 on  a certain  aspect  of aits remediation  and/or when  more  than  one  remedial
 meaaure la conaidered  technically viable  for the  immediate control of a threat.

 Immedlete  Removal Actions (IRAs);  Actions taken to prevent or mitigate immediate
 and aignifleant riak to  human  life, health or to the  environment.

 Initial Remedial Keaauras (IlMa);   Actions that  can be taken e«uickly  to limit
 exposurs or threat of expoaure to  a aignlficant health or environmental haxard at
 aitee where planning for remedial  actlone  ia  underwey.

 Monitoring  Veil;  A well inetalled under atrict design specifications that, when
 aampled, will  rsveal hydrogaologic deta  at ita point of  Installation.  Monitoring
 walla  are  installed  at predetermined  locations, uaually  in  groups,  to  gain
 knowledge  of  aite  conditions  including t  extent  at»d  type  of  ground  water con-
 tamination, eoil types,  depth  to ground  water amd  direction of ground watsr flow.

 National Conelatency Plan (KP)i  The mmaic policy directive for federal response
 *ctlone  mnder  the  Comprehemeive  Environmental  teepcnae.  Compensation  and
 Liability  Act  (ttftCLA).   It eats  forth  the Basard Ranking lyatem and procedures
 mad otandarda  for reeponding to releaaea of hazardous substances, pollutants, and
 contaminants.  The NC? ia t regulation tubject to  regular revision.

National Priorities Liat  (KPL)t    A liet  of  the highent  priority releeaas  or
 potential   releasss   of  hasardouo   eubetances,  based  ttpon  gtate  and  0.8.
Environmental  Protection. Agency (USEPA) Regional  aubmlssiona of candidate iltes
 and tha criteria and methodology  contained in the latard  Ranking Syetsv  (HRS).
 for the purpose of elIocsting  funds for  remedial response under the Comprehensive
 Eavironmentel  Xesponae,  Compeaeatlon and  Liability Act (CtRCLA).   Published  by
 the OltPA,  the KPL la updated  periodically.   Sices on the VPL are commonly called
 fuperfund eitee.
                                                                      over.

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           flJDEP>  Nev Jersey Depertment  of  Environmental Protection.

           KJDEP's Kanaiement Flan for Hatardout Waste Sice Cleanups;   The Nev  Jersey plan
           ueed to develop a  verk schedule and • aystematic approach co reaedial action ac
           hasardoui  waitt sites  and  discharges of  hazardous  materials  which post a threat
           to public  health or the environment.
                                                                               f
           Rsmedisl Action;  («.|.,  Remeval/Treatmant/Conetruction)   The  physical  action
           eoneitcent vith  the eelected reaedy  for a releaec  or threatened release  of a
           haxardoua  aubacance into the environment. The  tera include*,  but  ia not limited
           to  euch   actione   aa   reaoval,  storage,   eonfineaent.   protection ueing  dikes,
           trenchee,  ditchea, flurry vails, clay cover, neutralisation,  cleanup of released
           natardoua  eubetanees or  contaminated  aaterials, recyclint or reuse, diversion,
           destruction,  aegregation of  reactive wastes, dredging  or  excavations,  repair or
           replaeeaent of  leaking  containers,  collection of leachate  and runoff, on-site or
,           off-site  treatment  or  incineration,  provision of  alternate water supplies, and
}           aonitoring required to assure  that such actions  protect public  health and the
I           environaent.

           Remedial Investigation/Feasibility  Study  (RI/FS)t The Keaedial Investigation (RI)
           portion of a RI/FS in  reaedial planning involves  a physical and  other inves-
           tigation  to gather the data necessary  to  determine  the  nature  and  extent  of
|           probleas  at the  site;  establish  reaedial response  criteria  for the  site; and
I           identify technical  and  coat analyses of the alternatives.   The Feasibility Study
|           (FS)  portion of  a RI/FS  in remedial  planning  involves a  atudy  to evaluate
           alternative  reaedial actions from a  technical,   environmental,  and  cost  per-
           spective;   recommend the aost effective reaedy  for adequate protection of human
           health and the  environment; and prepare  a conceptual design,  cost estimates for
           budgetary  purposes, and a  preliminary implementation  schedule for  that action.

           Responsible Party;  Any  person who has discharged a haserdous  substance or is in
           any way responsible  for any hazardous substance which the NJDEP has removed or is
           removing pursuant to the New  Jersey Spill  Compensation  and Control Act and/or the
           Comprehensive Environmental  Response,  Compensation and Liability Act  (CERCLA).

           Spill Compensation  Fund; The  Spill  Compensation  Fund wse  created in  1976  with
           enactment  of the Spill  Compensation and Control Act and became effective on April
           1*  1977.   It  provides  compensation  to  qualified individuals  and businesses that
          have suffered damages aa a result of * discharge of hasardoua substances.

           tuperfund;    The  common  name  for  the   Comprehensive Environmental  Response,
          Compensation and Liability Act  (CEXCIA)   enacted by Congress in  December 1980.
          The Act authorised the  Baited Itataa Environmental Protection Agency (USEPA)  to
          provide long-term  remedies  at hazardous waste eites.  The Act established a fund
           from  apecial  taxes and general revenues,  to  accomplish  the cleanup  of these
           aitaa.

          USEPAt United States Environmental Protection Agency.


          »JDE?
           7/86

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                NEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION
                      DIVISION OF HAZARDOUS SITE MITIGATION
        A Community Relations Program at Superfund Hazardous Vasts Sites
As  part of  the federal/state  program of  cleanup ac  hazardous waate  •ices,  a
Community  Relations Program  is  conducted to  receive  local input  and  to sdviae
local residents and officials about the planned remedial actions at major stagec
of  the  cleanup.     Local briefings  and  meetings  are  conducted  with  elected
officials and residents and generally take place at:


     1)   The commencement  of a remedial investigation/feasibility study so Chat
          local concerns  can  be addressed early in the process.

     2)   The  completion  of  a   feasibility  study  to  discuss  the  alternative
          courses  of remedial action.   There  is a 21-day  comment  period on the
          alternatives during which the feasibility study  is  available in local
          repositories.

     3)   The commencement  of the rsmoval/trsatment/construction stage to advise
          of the expected physical remedial action.

     4)   The completion  of the remedial action.


In' addition  to  the  activities  outlined  above,  there   is  generally  ongoing
communication with local officials  and residents  as  required.   Depending upon
whether the New Jersey Department of Environmental Protection  (DEP) or the United
States  Environmental Protection  Agency  (EPA)  is  the  lead  agency  in remedial
action  at  a  site,  community  relations  activities are  conducted by the relevant
State or Federal agency.

In New  Jersey,  the DEP Community Relations Prograa Is directed by Grace Singer,
Chief,  Bureau  of  Community  Relations  (609) 984-3081.   At Region II.  EPA,  the
Community Relations Coordinator la Lillian Johnson, (212) 264-2515.
7/86
                                                                 over...

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                             STEPS INVOLVED IK A MAJOR HAZARDOUS WASTE SITE CLEANUP
      0)

Site Identified
 and Referred
           (2)

Initial Site Investigation
       (3)

  Site Secured
            (4)

Site Analysis Evaluation
      and Assessment
      (5)

PrioritIzation
           (6)

Determination of Agency Lead
     (NJDEP or USEPA)
       (7)

Coomnity Relations
   Plan Activated
            (8)

  Signing of Contract or
  Cooperative Agreement
      (9)

Hiring of Contractor
for Remedial  Investi-
 gation/Feasibility
    Study
           (10)

      Preparation of
      Feasibility
         Study
       (U)

  Selection of Remedial
    Action Alternative
            (12)

  Hiring of Contractor
 for Engineering Design
      (13)

 Hiring of Construction/
Treatment/Removal  Cleanup
     Contractor
           (14)

      Cleanup Evaluation
        (15)

  Contractor Audit and
        Close out

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                            urPARrwCNJ or
               »l(! UJ'.TJ. M J.
Ml'" _''«,' .">'
Vineland (Cumberland County)
PUBLIC MEETING SCHEDULED TO DISCUSS
DEVELOPMENTAL CENTER REMEDIAL STUDY
   THOMAS H KEAN, GOVERN'
RICHARD T  OEWLING. COMMiS!
                         (STATEWIDE)
                         No. 87/63
                         Immediate  release:
                         October 28,  1986
          TRENTON—The state Department of Environmental Protection (DEP) will hoU
f public meeting Thursday, November 13,In Vlneland, on the Initiation of a Remedial
Investigation/Feasibility Study and Design Study of five sites located at or near
the Vlneland Developmental Center, one of which 1s contaminated with polychlorinate
blphenyls (PCBs).  The Vlneland site 1s ranked 50th of 97 New Jersey Superfund site.1
                                                                  •
on the National Priorities List.
          The contractor selected for the studies 1s E.C. Jordan Company of Pcrtlanc
Maine.  E.C. Jordan has developed a 14-month schedule for completion of the studies,
which will Include an engineering design for removal of PCSs from a site located
within the northwest quadrant of the center campus, a groundwater study at that site
and a full Remedial Investigation/Feasibility Study at the other four sites.
      •  *
          The sites are located on three properties owned by the Department of Human
Services - a developmental center for the mentally handicapped, a residential center
for emotionally disturbed children, and a vacant lot.
          The other four sites, where heavy metal and/or organic contamination has
been found in preliminary DEP tests. Include a grassy field In the northeast quadrant
a five-acre area in the northern half of the residential property, a former gravel p1
In i vacant Tot east of the developmental center, and a vacant field near the water
tower.
          The contamination at all five sites Is presumed to hive resulted from
activities that took place at the Vlneland school between 1952 and 1976.
          DEP officials were first made aware of the problems in 1980, and the site wa.
                                    (more)
                             Let's  protect our earth

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 proposed for Superfund consideration 1n 1982.
          In March of 1985, the DEP prepared a report of Its preliminary findings at
 the site for the Department of Human Services, which announced the appropriation of
 funding for the remedial studies in August of that year.
          Bids for the project Mere solicited that October, and after overcoming delays
 that resulted from lack of adequate liability Insurance for hazardous waste contractors,
 the project was awarded to E.G. Jordan in August 1986.
          Surface and subsurface soil samples from the site contaminated with PCBs are
 currently being examined, the results of which are expected to assist E.G. Jordan 1n Its
 removal plan.  A separate contract for excavation and disposal of PCBs will follow.
          Details of the remedial Investigations will ae presented by E.G. Jordan
representatives at the public meeting, to be held at the Vineland City hall first floor
council chambers, 7th and Wood Streets, at 7 p.m.
          For more information contact Grace Singer of the DEP Hazardous Site Mitigation
Administration at (609) 984-3081.
                                         •dep-

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ATTACHMENT D

-------
                                                            Attachment D
                               LIST OF SPEAKERS



                                     FROM



                            PUBLIC MEETING 9/25/89



                                    FOR THE



                      VINELAND DEVELOPMENTAL CENTER SITE
1.   Mrs. Dorothy Lonf, President of Citizens Group



     Watch A«ainst Toxic Effluent Residue (V.A.T.E.R.)







2.   Mr. George White, Stflior Staff Representative for the



     Coonunicitions Workers of Aaerica (CVA), Local 1060
3.   Mr. Joseph Barr, retired Vineland Developmental Center Employe*

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         Public  Meeting
                      DIVISION OF HAZARDOUS SITE MITIGATION

                                Public Meeting
                                  to Discuss
                     Completion of the Remedial Investigation
                            and NJDEP's Proposed Plan
                                   for the
                   Vineland Developmental Center Superfund Site
                              September 25, 1989
                                   7:00 PM
                              Vineland City Hall
                             7th and Wood Streets
                             Vineland, New Jersey
         Opening Remarks
         and Introductions
         Site History and
         Project Overview
         Presentation of the
         Remedial Investigation
         Study Results

         Presentation of NJDEP's
         Proposed Plan

         Comments/Questions
Mr. Edward Putnam
Assistant Director
Division of Hazardous Site Mitigation
New Jersey Department of
Environmental Protection  (NJDEP)

Mr. Joseph Maher
Site Manager
Bureau of Site Management
Division of Hazardous Site Mitigation
NJDEP

Dr. Mike Keirn
Project Technical Director
E.G. Jordan Company

Mr. Joseph Maher
The floor will be open
for comments and questions
at this time. -
New Jersey Department of Environmental Protection • Bureau of Community Relations (609) 984-3081

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                                               STATE OF NEW JERSEY
                                      DEPARTMENT Of ENVIRONMENTAL PROTECTION
                                  FACT SHEET
                 Vineland Developmental Center  Superfund  Site
                                 Vineland City
                               Cumberland County

                              September 25,  1989

Background;

     The  Vineland   Developmental   Center  (VDC)  la  a  atate   residential
     treatment  facility  for mentally  handicapped women  operated by the  New
     Jeraey Department of Human Services (NJDHS).

     Between  1980  and  1984,  five  distinct  locations  were  identified  by
     former   and   current  employees   where  potentially  hazardous   waste
     materials wsre either buried or spilled.

     Based on the  potential for the waste  material   to  impact public  health
     and  the  environment,  MJDEP  had  the  sits  placed  on  the  National
     Prioritiea List of Superfund sites.

     Between  1980  and 198S, IUDEP  conducted preliminary site investigations
     to confirm the  presence  or absence of  hazardous  waste contamination ac
     the five sites.

     NJDEP's initial Investigations identified the following:

     (1)  contaminated PCB soil at  Site 2
     (2)  mercury  contamination of one  potable well  on Spring  Road,  but
          contaminant source not identified
     (3)  inconclusive results at Sites 1,3,4 and 5

     Based  on  these  initial  findings, NJDEP  proceedsd  with the  following
     actions:

     (1)  Extended  the Vineland  Water Utility's water main  to service  all
          residences,  immediately  adjacent  to  the  VDC,  which obtained  cheir
          drinking water  from private  wells.
     (2)  Awarded   a  contract  to  E.C.   Jordan  Company  to   develop   che
          remediation plan  to clean up the  PCB contaminated soil.
     (3)  Awarded  a  contract to E.C.  Jordan Company  to conduct  a Sup«rfunu
          Remedial Investigation/Feasibility Study.

     NJDEP  completed  the  removal/disposal  of  PCB  contaminated  soil  and
     structures at Sits  2 in November  1988.

—   The  finding's of the recently completed  Remedial Investigation  are as
     follows:

                                                                     over...  .

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                       PROPOSED PLAN






                            FOR






                VINELAND DEVELOPMENTAL CENTER






                        VINELAND, NJ






                      CUMBERLAND COUNTY






                       SEPTEMBER, 1989






PREPARED BY NEW JERSEY DEPARTMENT OF ENVIRONMENTAL PROTECTION

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  Introduction

  The  Vineland  Developmental  Center  (VDC)  Superfund  Site  in  the  City  of
  Vineland,  Cumberland County,  New  Jersey has  had a  Remedial Investigation
  (R.I.)  completed by the  New Jersey Department  of  Environmental Protection
  (NJDEP)  (as  the  designated  lead  agency)  in  conjunction   with  the  U.S.
  Environmental Protection Agency (USEPA)  (as  the  support  agency).   This R.I
  Report  has  been  issued  for  public review  and,  in accordance  with  Section
  117(a)  of   the  Comprehensive  Environmental   Response,  Compensation  and
  Liability Act  (CERLA)  and the Superfund Amendments  and  Reauthorization Act
  (SARA), the NJDEP and USEPA hereby  present the  Proposed Plan.

 The Vineland Developmental Center  (VDC) Superfund Site,  ranked  61st  of the
  109 New Jersey  Sites on the National Priorities  List,  is comprised  of five
  (5) subsites as described in  the  Site  Background section  of this Proposed
 Plan.   The  R.I.  Report  presents  the findings of the investigations of  Sites
  1, 3,  4,  and 5.   At Site 2,  a  PCB (polychlorinated biphenyl)  contaminated
 transformer oil release was previously  investigated and  a removal action was
 completed in November 1988.  The reports  documenting the site investigations
 and  cleanup   at  Site  2   consisting   of  a   Design   Report,   Plans  and
 Specifications,  and  Construction Drawings have  also  been issued for  public
 review and comment.

 The purpose of  this  Proposed Plan  document is  to  (1) identify  the proposed
 remedial action at the  site  and  explain the reasons for  the  preference,  and
 (2) solicit  public review and comment  on the Proposed  Plan.

 A  public  meeting  will   be  held on  September  25,  1989,  7:00 pa,  at  the
 Vineland City   Hall  to  discuss  the  VDC Remedial  Investigation  and  this
 Proposed Plan.   NJDEP and USEPA actively solicit public  comment  on the Draft
 R.I  Report, the  Site  2  documents,  and this  Proposed Plan.   The  public
 comment  period  will  extend until  September  28,  1989.   At the  conclusion  of
 this  specified  comment   period,  NJDEP  and  USEPA  will  consider all  public
 comment  and  relevant information in developing the final plan  to  remedy  the
 contaminants of  concern at  the  VDC.    USEPA,  with  concurrence from  NJDEP,
 wilt  document  the  final plan in  a  Record of  Decision  (ROD) which will
 include  a written response  to each  of the significant comments and other
 Information  submitted by tha  public during tha  comment period.

 Comnents should  be addraaaad  to:

          Grace  L.  Singer,  Chief
          Bureau of Cosnunity Relations
          Division of Hazardous Slta Mitigation
          New Jersey  Department of  Environmental Protection
          401 East State Street,  6th Floor
          CN413
          Trenton,  New Jarsay 08625

For Sites  1,  3,  4 and 5 of the Vineland Developmental Center Superfund Site,
NJDEP and USEPA  propose  that "no action" is the appropriate  remedy to ensure
protection  of  human  health   and  the  environment  at  these  sites.    This

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                                         -3-
 incinerated.   It was alleged by a former employee that approximately 6000 to
 8000 containers of mercury  and/or  arsenic-based  substances  (theorized  to be
 pesticides and/or rodenticides) were buried  in the  disposal  pit adjacent to
 the incinerator.

 Site 2 is  located  in  the northwest quadrant of  the VDC  campus with storage
 and maintenance  buildings  to  the  south,  a  softball  field  to  the  west,  an
 open field to the  north,  and a parking area to  the east.   In  approximately
 1976,  a scrap metal company contracted by VDC to remove and dispose of three
 electrical transformers  spilled  oil  from  the transformers.    This  oil  was
 subsequently  confirmed  to  be contaminated  vith polychlorinated  biphenyls
 (PCBs).

 Site  3  is  located  at  the  northern portion  of  the  VCRTC  property  and
 bordered  on the north by a*city park,  residences on Becker  Drive,  the VCRTC
 buildings  to the south,  and an industrial manufacturer to the east.   It is
 alleged  that this  site was used  as a refuse  dump, similar  to Site  1,  for
 about  10 years during  the  1950's and early  1960's.

 Site 4 is  located  between  Spring  Road and  Megan  Court (a  dead end street
 spur off  Linwood Avenue).  The site,  a formal  gravel pit area  and presently
 a  vacant  lot,  is alleged to have had transformer oil from retired electrical
 transformers  disposed  of here.  It  was also utilized by the  N.J. Department
 of Transportation as a maintenance yard.

 Site 5 is .located  in  a vacant field between the parking lot near the water
 tower  and  a  farm  storage shed.    It  is  alleged  that outdated shelf  life
 pesticides  in bags  and 5-galIon  containers (approximately  10 cubic yards)
 were buried at this site  in  the 1950's.

 Scope  of Activities

 From  the   period  1980  to  1965,   NJDEP  conducted  preliminary  remedial
 Investigations  at the five aitea  in  response  to  the information received
 regarding past disposal practical at tha VDC.  These investigations  included:

           installation and sampling of ground water monitor walls at Sites
           1, 3, 4 and  5
          potable wall  sampling at residences adjacent  to tha aite
          surface aoil  sampling at Sitas  1,3,4, and  5
          performance  of a conductivity survey  at Site  1
          teat   pit  exploratory   excavations   at   the   Site   1   locations
          corresponding to the conductivity survey  anomalies  for the purpose
          of visual inspection and subsurface soil sampling.
          delineation  of the extent  of PCB  contaminated soil  at Site 2.

 In  addition,  NJDEP conducted  a response action  in  1984 as  a  result of the
sample  results  from the  five  (5)   rounds  of potable  well  aamples  obtained
between March 1980  and June 1983 at the eight  (8) homes  Immediately adjacent
to  the  VDC.    Specifically,  one  (1)  of  the  sampled residential  wells
 intermittently exceeded the Federal Interim Primary Drinking Vater  Standard
 for mercury (.002 •g/l).   Although the other seven  (7) reaidential  wells did
not  exceed  any  drinking water  standards,  the potential for  contamination  of
these  wells  along  with  the  confirmed contamination  at  one  of  the wells

-------
                                        -5-
 did  reveal  the  pesticide  dieldrin,  for  which no  drlnkinf  water  standard
 exists, at a concentration  of 0.22  ug/1  (ppb).

 Based on the results of the Phase  I R.I, NJDEP and USEPA conducted a Phase 2
 R.I.  consisting of  (1)  soil  sampling  to further characterize the nature and
 extent  of  soil  contaalnation  at  the  surface  which  the  public  could
 potentially  be exposed  to  and  (2)  groundwater  sampling at  Site 1 to confirm
 the existence of dieldrin in  the upgradient nonltor well at Site 1.

 The  Phase  2  ground water sampling  at  Site   1  indicated  no presence  of
 dieldrin nor  any  other contaminants  above  Federal  or  State Drinking Water
 Standards.   The fact that  (1)  characteristics  of the site hydrogeology such
 as  a shallow  horizontal ground water gradient, high  soil  permeability,  and
 acidic  ground  water   combine  to  create  an   environment  conducive  to
 contaminant  leaching,  (2)  the burial  of  waste material  from -vore  than 20
 years ago should result in chemicals leaching to ground water under the site
 specific environment  described  in  1,  (3)  present  ground  water  sampling
 results are  clean,  (4) the  R.I.   did  not substantiate large quantities of
 waste  burial  as  alleged,  and (5)  the  low  levels  of  PAHs, metals,  and
 pesticides   identified   in  the surface  and   subsurface  soils  are  highly
 immobile  having  strong   absorption/adsorption  to   soils   and  low  water
 solubility;  future  leaching  to ground water  is  not  anticipated.    In the
 event  that  leaching ware  to  occur,  private  and public  walls  within  the
 deeper  aquifer would not b« considered at rlak of contamination from the VDC
 because of their  depth and the low levels of  contaminants  existing at the
 sites.   Accordingly, a ground water exposure  scenario is  not considered to
 exist for the  VDC.

 For  soils,  a  comparison of the Identified  contaminant levels to background
 aoils  in  similar  environments  in  southern  New Jersey   resulted   in  the
 following  chemicals  of  concern  in  soil  as  the  indicator  chemicals  for
 conducting a baseline  public  health risk assessment  and  an ecological  risk
 aasessment:

 Site  No.  1:    +Polynuclear Aromatic Hydrocarbons  (PAHs)

               Lead

               Mercury

 Site  No. 3:    +PAHs

               **DDE

               Lead

Site  No. 4:    Lead

Site  No. 5:    Nona

*     PAHS  are  formed  by  the   incomplete   combustion  or  pyrolysis   of
      hydrocarbons  and  from weathering  of fuel  oils.  These chemicals  are
      preaent  in emissions  from stationary combustion  sources  (e.g.,  boilers
      and  furnaces),  as  well as motor vehicle,exhausts.  The presence of PAHs

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                                         -7-
  Noncarcinogenlc  risk  estimates  are determined  by  dividing exposure-dose
  levels for each  noncarcinogen  by the appropriate  dose/response crlttrion for
  the particular  contaminant.   The resulting  ratio  ia termed a  risk ratio.
  The sua of the  risk ratios for  individual contaminants is called th« hazard
  index  (HI).   If this ratio is  lass  than  or  aqual to 1.0, no advert* health
  effects  are  anticipated  from  the  predicted exposure-dose  level.    If the
  ratio   is   greater  than  1.0,  the  predicted   exposure-dose  level   could
  potentially   cause  adverse  health  effects.    This  determination   is  not
  absolute    because  derivation  of  the  relevant  standards  or  guidelines
  involves the  use of'Multiple safety factors.   Therefore, the potential for
  adverse health effects  for  a  mixture having a hazard index is excess of 1.0
  •ust be assessed on  a  case-by-case basis.   Hazard indices were determined
  for each potentially exposed population at each of the four sites.

  It  is  concluded, based  on the  swat probable case  scenarios  of the public
  health  risk  aasessment,   that  the  carcinogenic and  noncarcinogenic   risk
  estimates  for all five populations are  below or  within target risk  levels  at
  each of the four sites  individually  as well as the  total  site risk  for each
  population.  Table ES-1 summarizes the risks for the most  probable case.

 Total  site carcinogenic  risk  calculated  under  the worst-case scenario were
 below  or   within   the  target   risk  range  of  10"   to  10*    for all
 populations except the VDC residents and off-site children.

 For VDC residents,  the  total site cancer risk  exceeded the target  range  .by
 approximately  ten  fold  for the worst-case scenario.   The elevated  risk  is
 driven  by  the  maximum concentration of carcinogenic PAHs at Site  No.  1.
 For off-site  children,  the total  site cancer  risk was only slightly  above
 the  target range   at  1.59x10"   for  the  worst-case  risk  scenario.   The
 carcinogenic  risks  for  off-site   children were   driven  by   the  maximum
 concentration  of  carcinogenic PAHs detected st Site No. 1 and 3.

 Total  aite noncarcinogenic  risks were below  a target  HI  of  1.0  for  VDC
 workers and VCRTC clients.   The total  sit*  noncarcinogenic  risks were  above
 1.0 for VDC residents,  off-site children,  and  construction workers.    The
 elevated HI for VDC residents wss determined by the maximum concentration of
 lead  at Site  No. 1;  the  elevated HI  for off-site  children was due to  the
 maximum concentration of lead st both  Site Nos.  1 and 4;  sad the elevated HI
 for construction workers  wss  due to  the maximum  concentration of  lead  at
 both Site Nos.  1  and 4.

 It  is important to not* thst the worst-case scensrios calculated in  the R.I.
 Report  incorporate sa extensive set of conservative assumptions,  which when
 combined, produce exposure scsnsrlos that are extremely unlikely to  occur in
 the  real world.    This  is  becsuse  the  exposure conditions  (magnitude  and
 duration)   are  the  maximum  and  would be very  unlikely  to represent   the
 long-term   average   for  an  Individual  or  for  the  receptor  population.
 Secondly,   becaua*  maximum  concent ret ions  for   each  chemical  are  used  to
 estimate lifetime doses,  this  factor does not represent  the true  long-term
 daily dose.  This is  true because the  incidence of probable encounters with
 concentrations  approaching  the maximum for  all  chemicals  is  extremely  low
 and the probability that any specific  location contains each chemical  at  its
maximum concentration  is remote.  Accordingly!  the risk management  decisions
 presented in this Proposed Plan ar* based on the  most probable case.

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                                         -9-
 Although the  Proposed  Plan is the one  presented  by the USEPA  snd NJDEP,  a
 decision will  be  s)«de only  after  consideration  of  all  coanents received
 during the 21-day public comment period.  Written and verbal consents on the
 Proposed  Plan will  be  welcome  through  September  28,  1989  and will  be
 documented in  the Responsive Summary section of the final Record of Decision.
 All  written comments  should be addressed to:

                Grace  Singer,  Chief
                Bureau of Community Relations
                Division of  Hazardous Site Mitigation
                NJDEP'
                401  East State Street, 6th Floor
                CN413
                Trenton, Nev Jersey 08625

Notice  of the  final  decision  vill  be  published  and made  available  to the
public  at the  repositories listed previously.   The final  decision will be
accompanied  by an explanation  of  any significant  changes  from the proposed
plan.   Questions  concerning the proposed plan may be directed to  Mr. Donald
Kakas of NJDEP  at 609-984-3081.

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                                       KEY

                                223 ALLEGED WASTE DISPOSAL AREA
  VIMILANO
  -STATI
  SCHOOL
(MOT TO 9CAL1)
                     FIGURE-1
  GENERAL SITE PLAN
VINELAND STATE SCHOOL

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                                  TABU IS-1
                       SUfiARY Of HOST PROBABLE CASE RISKS
                      AT THE VINELAND DEVELOPMENTAL CENTER

                             REMEDIAL INVESTIGATION
                          VINELAND DEVELOPMENTAL CENTER
                                        INCREASED LIFETIME CANCER
                                           RISK PROBABILITY
                                               SITE
POPULATION
VDC Clients
VDC Workers
VCRTC Clients
Off-lit* Children
Construction Workers
SITE NO.l
1.69x10-'
1.97«10-7
m»
1.94«10-T
1.64alO-§
SITE NO. 3 SITE NO.* SITE NO.S OVERALL VDC
••
1.67»10-T
9.72alO-7
•
*
•
•
1.69x10-°
1.97xlO-7
1.67xlO-7
1.13xlO-s
1.64x10-*
POPULATION
              NONCARCINOGENIC  HAZARD INDICES
              	SITE
              NO. 3
VDC Clients
VDC Workers
VCRTC Clients
Off-site Children
Construction Workers
3.25xlO-y  —
2.37xlO-4   —
          1.36xlO-2
1.68x10-3 3.14x10-2
6.90xlO-4   —
1.82x10-2
1.22xlO-3
3.25x10-3
2.37x10-4
1.36x10-^
5.13x10-;
1.90X10-3

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                   „,..,       .
                                   Glossary of Terms

 Administrative  Consent  Order (AGO):   A  binding legal  document between  a government
 agency  and  a  responsible party.    It  is  an order  voluntarily aatsrsd  lato by  ehe
 responsible  party  (aee  below) that  specifies specific  actions or  obligations of  the
 responsible  party, which say  include  site reaedlation.

 Agency  for  Toxic  Substances  and Disease  Registry  (ATSDR);   A branch of  the  United
 States Department of Health and Human Services.

 CERCLA;    Comprehensive Environmental  Response,  Compensation  and  Liability  Act  (see
 Superfund below).

 Focused  Feasibility Study (FFS);   A limited feasibility  study  performed for a certain
 aspect  of site  remediation  and/or when  more than  one remedial measure is considered
 technically  viable for the early  control of • threat.

 Hazard  Ranking  System  (HRS):   The  system set forth in  the  National Contingency Plan
 (See  below)  to  determine  whether a  particular  site  is  eligible for  Inclusion  on the
 National Priorities List (See below).

 Immediate  Removal  Action  (IRA);    Action taken  to prevent  or mitigate immediate  and
 significant  risk to human  life, health or to the environment.

 Initial  Remedial Measure  (IRM)t   Action  that can  be taken  quickly  to limit exposure
 or  threat  of exposure  to  a  significant health  or environmental hazard at sites where
 planning for extended remedial action la underway.

 Leachate;    Liquid  (usually  rain water)  that has  percolated  through  solid  waste  or
 other mediums  and  has extracted  materials from  It.   These materials  can be dissolved
 and/or suspended in the liquid.

 Lead Agency:   The agency  having  primary responsibility  and authority for planning and
 executing the remediation  at a sita.

 Monitoring  Well;   A  well  installed under  strict design  specifications  that,  when
 sampled, will reveal hydrogeologlc  data  at its point of Installation.   Monitoring wells
 are Installed at predetermined locations, usually  in groups,  to gain knowledge of site
 conditions including:   extent and type of ground water contamination, soil-types, depth
 to ground water and direction of  ground water flow.

 National  Oil and  Hazardous  Substances  Pollution  Contingency Plan  (NCP);   The  basic
 regulations  for  federal  response  actions  under  the  Comprehensive  Environmental
 Response, Compensation  and Liability Act (CERCLA)  (Superfund) and amendments.  It sets
 forth the  HRS  and  procedures  and standards  for responding  to releases  of hazardous
 substances.

National Priorities List  (NPL):   The list of the  highest priority hazardous substance
sites determined by the federal  government based on the  HRS.   A site listed on the NPL
 is  eligible  for  federal  funding   under  the  Comprehensive Environmental  Response,
Compensation and Liability Act (CERCLA).  Published by ens United States  Environmental
Protection Agency  (USEPA),  the  NPL is  updated periodically.   Sitas  on the  NPL  are
commonly called Superfund  sites.

New Jersey  Pollution Discharge  Elimination  System  (NJPPES);    Program Implemented  to
regulate any discharges to the state's ground water  or  surface water.
 UDEP;  New Jersey Department of Environmental Protection.
Priority Pollutants:   Originally 65  categories of pollutants  comprised of 114 organic
and  15 inorganic  pollutants,  totalling 129.    Sines 1976  three  compounds  have been
•emoved decreasing  the  number to 126.   The list was officially incorported in the 197?

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              Community Relations Program
              at
              Superfund
              Hazardous
              Waste
              Sites
              As part of the federal/state program of cleanup at hazardous waste sites, a Community Relations
              Program is conducted to receive local input and to advise local residents and officials about
              the planned remedial actions at major stages of the cleanup. Local briefings and meetings are
              conducted with elected officials and residents and generally take place at:


                 1) The commencement of a remedial investigation/feasibility study
                   so that local concerns can be addressed early in the process.

                 2) The completion of a feasibility study to discuss the alternative
                   courses of remedial action. There is a 21-day comment period
                   on the alternatives during which the feasibility study is available
                   in local repositories.

                 3) The commencement of the treatment/construction/removal
                   stage to advise of the expected physical remedial action.

                 4) The completion of the remedial action.


              In addition to the activities outlined above, there is generally ongoing communication with local
              officials and residents as required. Depending upon whether the New Jersey Department of
              Environmental Protection (DEP) or the United States Environmental Protection Agency (EPA)
              is the lead agency in remedial action at a site, community relations activities are conducted by
              the relevant State or Federal agency.
              In New Jersey, the DEP Community Relations Program is directed by Grace Singer, Chief, Bureau
              of Community Relations (609) 984-3081. At Region II, EPA, the Community Relations Coordinator
              is Lillian Johnson, (212) 264-2515.
5/87
Division of Hazardous Site Mitigation
              New Jersey Department of Environmental Protection

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                                                        STATE OF NEW JERSEY
                                              DEPARTMENT OF ENVIRONMENTAL PROTECTION
                                      PLEASE PRINT

Date;                                 Meeting Topic (Site):

(Optional)  Name/Affiliation:	.
The  New  Jersey Department  of Environmental  Protection is  very interested  in what  you
thought of  this meeting  so  that  we can  continue to  improve future  meetings.    Please
complete  this survey before leaving to help us in this effort.

1.    How did you hear of this meeting?
          Newspaper        Television          Posted Notice       Other
         'Radio        	Mailed Notice   	Word of Mouth
2.    Please respond to the following statements using a scale from 1-5, where:

      1-agrte strongly                     4-disagree moderately
      2«agree moderately                   5"dlaagree strongly
      3-neicher agree nor disagree

      a.  Agency representatives spoke clearly and were easily heard.          _

      b.  Technical  aspects were presented in a way I could understand.        _

      c.  Graphics used were visually clear and understandable.                _

      d.  Agency representatives clearly explained their actions and plans.    _

      e.  I had adequate opportunity to talk with agency representatives
         either during the meeting, or privately, before or after the         _
         meeting.

      f.  My  concerns were expressed to Agency representatives either by me
         or  others  during this meeting.                                       _

      g.  I felt "understood1* by agency representatives.                       _

      h.  Agency representatives seemed interested in the opinions
         and questions of those outside of the agency.                        _

      1.  Agency representatives responded adequately to the questions.        _

      j.  I understand the issues covered in this meeting.

      k.  I gained better appreciation of the dilemmas to be confronted.

      1.  I feel a need for more meetings.
                                                                                   ...OVER
                                 V«w /trsf* a on EquaJ Opportune* Employer

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     «•"•»—;"«..•„*                               STATE OF NEW JERSEY

                                    DEPARTMENT OF ENVIRONMENTAL PROTECTION

                                        C! IRISTOPI ll-R J. DACJGI-riY. COMMISSION!!R
                                                  CN 402
                                             TKHNTON. N.J. 08625
                                                609-292-2885
                                SEP 11 1889
 William J.  Muszynski, P.E.
 Acting Regional Administrator
 U.S.  Environmental Protection Agency
 26  Federal  Plaza
 New York, N.Y.  10000

 SUBJECT: Vineland Development Center
          Record of Decision

 Dear  Mr. Muszynski,


 A draft Record of Decision (ROD) has been prepared by the United
 States Environmental Protection Agency  (USEPA) ,  in accordance
 with  the requirements of the Comprehensive  Environmental
 Response, Compensation and Liability Act of 1980 (CERCLA) ,  as
 amended by  the Superfund Amendments and Reauthorization Act of
 1986  (SARA),  for the Vineland Development Center Site in
 Vineland, Cumberland County, New Jersey.


 The sTate of  New Jersey concurs with the remedy  outlined below.

...Description of the Selected Remedy
      selected alternative for the Vineland State School site is to
ii-iake ftp  further remedial action.  The Vineland site includes five
7 separate areas or subsites.  Of the five areas investigated, only
.':.isubsite  2 was found to be significantly contaminated.   In 1988,
• "PCS  contaminated soils in this area were cleaned up by the New
 Jersey Department of Environmental Protection.   In addition, a
 public water supply was extended to service homes in the vicinity
 of the site.

 Investigation results of the four other areas  indicated very low
 levels of contamination.  The risks posed by the contamination in
 these areas is within the acceptable range as  determined by the
 New  Jersey Department of Environmental Protection and the
 Environmental Protection Agency.  Therefore, no further remedial
 action is considered necessary.  However, as a precautionary
 measure,  a program to monitor groundwater and  the existing
 disposal areas will be implemented.  The New Jersey Department of
 Health and the Agency for Toxic Substances and Disease Registry
 concur with the selected remedial action.
                       New Jersey is an Equai Opportunity Employer
                               Recycled Paper

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After review of the final decision document, the State may have
additional comments to be addressed by USEPA.  These comments
would not affect our concurrence with the above remedy.

The State of New Jersey appreciates the opportunity to
participate in this decision making process and looks forward to
future cooperation with USEPA.


                   Very truly yours,



            .   Christopher J. Daggett, Commissioner
           1*  Department of Environmental Protection

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                   UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
          c— Vf r---                  REGION II
   DATE:    <-w- £ w s-r^c

       Record  of Decision  for
 SUBJECT: Vineland State  School

       Stephen D. Luftig,  Director               \
   FROM: Emergency and Remedial Response Division  ^

    TO: William J. Muszynski, P.E.
       Acting  Regional Administrator


       Attached for your approval is the Record  of Decision  for the
       Vineland State  School site in the City of Vineland, Cumberland
       County, New Jersey.

       The New.Jersey  Department of Environmental Protection has the
	     lead for remedial activities at the Vineland site.  The EPA
       project manager for the  site is Matthew Westgate.

       The Vineland State  School, now known as the Vineland
       Developmental Center, is a treatment facility  for mentally
       handicapped women operated by the New Jersey Department of Human
       Services.  The  Vineland  site includes five separate areas or
       subsites.  Of the five areas investigated, only  one,  subsite 2,
       was found to be contaminated to any significant  degree.  This
       area was cleaned  up by the New Jersey Department of Environmental
       Protection in 1988.  The cleanup included the  removal of nearly
       4000 tons of PCB-contaminated soil.

       Although there  were allegations of  illegal dumping, investigation
       of the  other four areas  failed to detect  any significant
       contamination.  If  fact, the risks  associated  with the low
       levels  of contamination  in these areas are considered acceptable
       by EPA  and the  New  Jersey Department of Environmental Protection.
       A public health assessment by the New Jersey Department of Health
       and the Agency  for  Toxic Substances and Disease  Registry support
       this determination.

       In view of the  above, the selected  remedy is to  take  no further
—     remedial action.  However, because  of isolated measurements in
       groundwater above drinking standards, groundwater monitoring will
       continue.  As part  of its earlier actions, the State  has
       connected nearby  residents to a public water supply.

       The remedial investigation report and proposed plan were released
       to the  public on  August  8, 1989.  An informational meeting was
       held on September 20 to brief local and school officials and some
       concerned residents on the results  of the investigation at the
       site.   In addition, a public meeting was  held  on September 26 to
       discuss the investigation and proposed plan.   The comment period
       closed  on September 28,  1989.  The  public generally supported the
       no-further-action remedy with groundwater monitoring.
  REGION II FORM 132O-1 (9/85)

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                               -2-

The Record of Decision has been reviewed by the New Jersey
Department of Environmental Protection, the Agency for Toxic
Substances and Disease Registry, and the appropriate program
offices in Region II, including Groundwater Management and the
Office of Regional Counsel.  Their input and comments are
reflected in this document.  Both the State of New Jersey and the
Agency for Toxic Substances and Disease Registry concur with the
selected remedy.

If you have any questions or would like to further discuss this
Record of Decision, I would be happy to do so at your
convenience.

Attachment

-------