United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R02-90/120
September 1990
&EPA
Superfund
Record of Decision
Pomona Oaks Well
Contamination, NJ
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50272-101
REPORT DOCUMENTATION i. REPORT NO. 2.
PAGE EPA/ROD/R02-90/120
4. Title and Subtitte
SUPERFUND RECORD OF DECISION
Pomona Oaks Well Contamination, NJ
First Remedial Action - Final
7. Author(e)
9. Performing Organization Name and Add re M
12. Sponaoring Organization Nam and Addraaa
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
3. Recipient'* Acceaaion No.
S.
Report Date
09/26/90
6.
8.
10.
11.
(C)
(G)
13.
Performing Organization RepL No.
Project/Taak/Work Unit No.
CorrtracqC) or Gr ant(G) No.
Type o< Report * Period Covered
800/000
14.
IS. Supplementary Note*
16. Abatract (Umrt: 200 words)
The 354-acre Pomona Oaks Well Contamination site is comprised of a 193-residence
subdivision and an adjacent shopping center in Galloway Township, Atlantic County, New
Jersey. The site overlies a surficial unconsolidated sand aquifer. Home construction
at the site began in 1972, and private wells within the surficial aquifer were
initially used as the water supply. In 1982, onsite residents complained of foul
tasting well water, and subsequent investigations from 1982 to 1985 confirmed the
presence of onsite ground water contamination. Possible contamination sources include
two nearby gas stations, a salvage yard, a dry cleaner, and onsite residential septic
tanks. In 1985, all homes were hooked to a municipal water supply by the State,
eliminating public exposure to ground water contamination. Further sampling conducted
from 1986 to 1990 revealed only low-level ground water contamination. This Record of
Decision (ROD) provides a final remedy for the ground water. Because ground water
contaminant levels no longer exceed health-based or State standards, there are no
contaminants of concern at the site.
(See Attached Page)
17. Document Analyaia a. Deacriptora
Record of Decision - Pomona Oaks Well Contamination, NJ
First Remedial Action - Final
Contaminated Medium: gw
Key Contaminants: None
b. Wentifiera/Open-Ended Terma
c. COSAT1 Reid/Group
18. Availabiity Statement
19. Security Claaa (Thia Report)
None
20. Security Claaa (Thia Page)
None
21. No. olPagea
84
22. Price
(See ANSI-Z39.18)
See Instructions on Revene
OPIIONAL FORM 272 (4-77)
(Formerly NTIS-35)
department ot Commerce
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EPA/ROD/R02-90/120
Pomona Oaks Well Contamination, NJ
irst Remedial Action - Final
Abstract (Continued)
The selected remedial action for this site is no further action, because onsite
investigations revealed that the source of contamination was a singular event, and that
the contamination dispersed through natural attenuation and/or biodegradation. Ground
water monitoring will be continued. No costs are associated with this no action
remedial action.
PERFORMANCE STANDARDS OR GOALS: Not applicable.
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DECLARATION STATEMENT
RECORD OF DECISION
POMONA OAKS WELL CONTAMINATION SITE
Site Name and Location
Pomona Oaks Well Contamination Site
Galloway Township, Atlantic County, New Jersey.
Statement of Basis and Purpose
This decision document presents the selected remedial action for
the Pomona Oaks site in Galloway Township, New Jersey, which was
chosen in accordance with the requirements of the Comprehensive
Environmental Response, Compensation and Liability Act of 1980,
as amended by the Superfund Amendments and Reauthorization Act of
1986, and, to the extent practicable, the National Oil and
Hazardous Substances Pollution Contingency Plan. 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 Pomona Oaks site is to take no
further remedial action. In 1985, in response to a ground water
contamination problem, the residents of the Pomona Oaks
subdivision were connected to a public water supply system from
the neighboring Town of Absecon. The residential wells were
sealed, thus removing the immediate health risk to the residents.
This action was funded by the State of New Jersey.
A remedial investigation was conducted from October 1988 to March
1989. Data obtained during this investigation has shown that the
ground water contamination in the Pomona Oaks subdivision no
longer exists above health risk or drinking water standards.
Therefore, no further remedial action is considered appropriate.
However, since ground water contamination did exist in the Pomona
Oaks area at one time, as well as the fact that contamination
above New Jersey Safe Drinking Water Act standards has been
identified in some potable wells in the Pinehurst area,
downgradient of the subdivision, continued ground water sampling
is necessary to monitor the overall ground water quality in the
area.
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-2-
Declarations
In accordance with the requirements of the Comprehensive
Environmental Response, Compensation and Liability Act, as
amended by Superfund Amendments and Reauthorization Act, and the
National Contingency Plan, I have determined that no further
remedial action is necessary to protect human health and the
environment at the Pomona Oaks site. However, a program to
monitor ground water in the Pomona Oaks subdivision and the
adjacent area will be implemented.
Because hazardous substances will not remain on the site above
health based levels, the five year review will not apply to this
action.
Constantine Sidamon-Eristo
Regional Administrator
Date
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DECISION SUMMARY
POMONA OAKS WELL CONTAMINATION SITE
Pomona, New Jersey
Site Location and Description
The Pomona Oaks Well Contamination Site (the site) includes a
residential subdivision and an adjacent shopping center in the
Pomona area of Galloway Township, Atlantic County, New Jersey.
Atlantic City is located 10 miles to the southeast.
The residential subdivision contains about 200 single family
homes built in the 1970s and has a population of approximately
800 to 1000 people. It is bordered by White Horse Pike, Pomona -
Port Republic Road and Donna Drive and is surrounded by
undeveloped wooded areas, scattered residences and small "strip"
type shopping areas. Some of the outlying areas are farms.
Southwest of the subdivision is a combination gas station -
convenience store and a "strip" mall containing a dry cleaner
(see Figure 1). Another gas station and a salvage yard are
located to the west and northwest of the intersection of Pomona -
Port Republic Road and White Horse Pike. The subdivision
includes about 25 percent of the 354 acre study area. The
population of the area to the south and east of the subdivision,
called Pinehurst, may be as high as one thousand people.
The Pomona Oaks subdivision has both municipal water and sewers.
Pinehurst, up until this year, relied on private residential
wells for potable water and individual septic systems for waste
water disposal. Municipal sewer lines are now being installed
near Willow Avenue. The municipal water is supplied to the
Pomona Oaks subdivision from two sources, a transmission line
from the neighboring town of Absecon and a production well
northwest of the intersection of Pomona - Port Republic Road and
Jimmie Leeds Road.
Soils in the study area consist of nearly level to gently
sloping, well drained, permeable, loamy sand. The two soil units
in the area are the Klej loamy sand and the Fort Mott sand. The
Klej loamy sand is susceptible to water erosion due to flooding,
wind erosion where large areas are exposed for growing crops, and
ground water pollution because of its permeability.
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o
LEGEND
CAS STATIONS
SALVAGE YARD/CAS
STATION
POMONA PLAZA
A. RESIDENTIAL WELL
• PIEZOMETER
LOCATION
MONITOR WELL
LOCATION
P-6
POMONA OAKS
SUBDIVISION
.RW-2O
\
\
ii
11
fcRW-9
^Pff
WHITE HORSE PIKE
ROUTE 3O
SCALE
NO SCALE
D
MA
REM III
POMONA OAKS SITE
RESIDENTIAL WEM- SAMPLE LOCATIONS
FIGURE
1
r r .lOHNSDN * MAI HOTRA.P.C.
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Major surface water features in the area include the North Branch
of Absecori Creek. This intermittent stream is roughly parallel
to, and south of White Horse Pike. It flows to the southeast for
approximately two and one half miles into the Atlantic City
reservoirs. Small intermittent tributaries from the North Branch
drain the eastern and southern part of the study area. Jimmie
Leeds Road is the local drainage divide for the study area.
Surface water in the site area flows to the south and east, south
of Jimmie Leeds road and to the north, north of Jimmie Leeds
Road. The north flowing tributaries flow into Morses Mill Stream
and to the northeast into the Mullica River. The wetlands
associated with these two surface water systems are not
contaminated and would not be affected by the decision presented
in this document. Similarly, no floodplain assessment will need
to be prepared. The only surface water impoundment in the
immediate area is a small storm-water detention basin located in
a triangular parcel of land at the intersection of Donna Drive
and Louis Ave (see Figure 1).
The Pomona Oaks subdivision is located on a very slight
topographic rise in a relatively flat lowland area. Elevations
within a one mile radius of the site range from 50 to 70 feet
above mean sea level.
The Pomona Oaks site is located in the Atlantic Coastal Plain
physiographic province. The New Jersey Coastal Plain consists of
a wedge-shaped mass of unconsolidated Cretaceous and Tertiary age
sediments - clay, silt, sand and gravel that dip and thicken to
the southeast. The geology of the Pomona Oaks area is fairly
simple. The Tertiary age Cohansey Formation is the major
unconfined aquifer and extends from the surface to approximately
205 feet. Below is the Kirkwood Clay, a major aquitard in the
area. The Cohansey Formation is mainly unconsolidated sandstone
with grain sizes that range from fine silt to gravel. There are
interbedded clay and gravel lenses throughout. However, none of
the clay lenses are laterally consistent enough to divide the
Cohansey Formation into separate aquifers. Previous studies in
the area had encountered a ten foot thick clay layer, referred to
as the Middle Cohansey Clay, at 90 to 100 feet below the surface.
Such a layer was found in monitoring well no. 1, but was not
found in any of the other wells. This clay layer graded into
more permeable silt and sand within a few hundred feet laterally.
The water table in the shallow Cohansey is approximately 15 feet
below the ground surface and recharge occurs throughout the study
area. This aquifer serves as the major source of water for this
part of southern New Jersey.
The New Jersey American Water Company production water well that
supplies some of the water to the Pomona Oaks subdivision is
screened in the lower Cohansey aquifer (at a depth of about 160
feet below the surface). The residential wells for the houses to
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the southeast of the subdivision, in Pinehurst, are screened at
various depths from about 30 to 120 feet below the surface.
Except for occasional transient species, no federally listed or
proposed threatened or endangered flora or fauna are known to
exist within the study area. There is no federally designated
wild and scenic rivers, or environmentally significant
agricultural land in the vicinity of the site. Additionally, the
site does not lie within the coastal zone as defined by the State
of New Jersey. Accordingly, the Wild and Scenic Rivers Act, the
Farmland Protection Policy Act and the Coastal Zone Management
Act are not considered applicable or relevant and appropriate for
this project. Because of the developed condition of the site,
proposed activities will probably have no effect on resources on,
or eligible for nomination to, the National Register of Historic
Places. Furthermore, the recommended "no-action" alternative
does not necessitate further evaluation of impacts to cultural
resources.
The Pomona Oaks site is within the New Jersey Pinelands
Protection Area. The Pinelands Protection Area was established
to provide a balance between legitimate economic and social needs
for development while providing protection for the natural flora
and fauna, ground water and other natural resources.
Site History and Enforcement Activities
Construction of homes in the Pomona Oaks subdivision began in
1972. Initially, homes within the subdivision relied upon
private wells as the source of potable water and upon individual
septic systems for wastewater disposal. By 1982, all of the
homes in the subdivision were connected to the public sewer
system.
In June of 1982, residents complained to the Atlantic County
Health Department (ACHD) of foul tasting well water. Potable
well water samples were collected from two private homes on Terry
Lane. Sample results showed elevated levels of benzene (184 and
550 parts per billion (ppb)). From October 1982 to January 1983,
ACHD sampled potable water from 81 homes in the Pomona Oaks
subdivision. The concentrations of volatile organic compounds
(VOCs) detected in 16 of the residential wells were reported at
levels exceeding New Jersey drinking water standards which, at
that time, were 100 ppb for total volatile organics or 50 ppb for
a single contaminant. The chemicals found, and the corresponding
drinking water standards, are listed on Table 1. The
contaminants with the highest concentrations were benzene - 2,060
ppb and 1,2-dichloroethane - 880 ppb. Residents were advised by
the ACHD not to use the water for drinking or cooking.
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TABLE 1
VOLATILE ORGANIC COMPOUNDS DETECTED IN POMONA OAKS
SI -JIVISION WELLS 1982 - 1985
(all levels in parts per billion)
(MCLs are 1982-1985 standards)
Compound
Highest Reported
Level
Maximum Contaminant
Level - NJ Interim
Criteria - 1985
Benzene 2060
Chlorobenzene 58
Dichlorobenzene (includes p,m,o) 76
Chloroform
1,2-dichloroethane
1,1-dichloroethane
1,1-dichloroethene
trans-l,2-dichloroethene
1,1,1-trichloroethane
1,1,2-trichloroethane
Trichloroethene
1,1,2,2-Tetrachloroethene
1,1,2,2-Tetrachloroethane
Toluene
Ethylbenzene
Total Xylenes
Methylene chloride
Trichlorofluoromethane
2-chlorovinylether
Napthalene
31
880
60
4.3
9.3
170
46
25
25
3
14
8
204
50
7
36
9
5
50 c
5 b
5
50 c
5
50 c
5
5
5
50 c
50 c
440 (SDWA)
5
b = Primary drinking water standard for total trihalomethanes
c = The NJ Interim Criteria for total volatile organic toxic
pollutants (1985)
(SDWA)
Safe Drinking Water Act
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The New Jersey Department of Health (NJDOH) performed a health
survey from December 1982 through January 1983 of 37 households
in the affected area. The survey included air, water and
biological monitoring at the homes. Volatile organics such as
benzene and toluene were detected in the air samples from several
homes. The results of water sampling were similar to the results
obtained by ACHD, with benzene detected between 49 and 89 ppb in
8.1 percent of the homes, and lower concentrations of chlorinated
hydrocarbons detected in up to 21.6 percent of the homes tested.
In February 1984, NJDOH advised these residents to shower in an
alternate water supply if/when possible.
On January 30, 1984, the New Jersey Department of Environmental
Protection (NJDEP) hired Camp Dresser & McKee (COM) to identify,
evaluate and recommend alternatives that would provide a long
term potable water supply to the residents of Pomona Oaks. On
June 5, 1984, NJDEP requested assistance from the Environmental
Protection Agency (EPA) to mitigate the impact of ground water
contamination on Pomona Oaks residents. On October 1, 1984, the
Pomona Oaks Well Contamination site was proposed for addition to
the National Priorities List; the site was finalized on June 1,
1986. :
On March 30, 1985, EPA collected potable water samples from 22
Pomona Oaks homes. This effort focused on homes within the
apparent path of the contamination, that had never been sampled,
or had only been sampled on one occasion and were found to have
non-detectable or low levels of contamination. One additional
home was found to have contaminants at levels that exceeded NJDEP
standards. That home began receiving bottled water.
On May 17 and 18, 1985, EPA collected a second round of samples
from 65 Pomona Oaks homes and two nearby businesses. This effort
focused on the western part and the perimeter of the subdivision.
None of these locations were found to have contamination that
exceeded NJDEP guidelines.
On August 23, 1985, the hookups of all 193 homes within the
subdivision to the Absecon water supply were completed. The
American Water Works Company was retained by NJDEP to develop
plans for a new production well, screened in the lower Cohansey
aquifer, to serve as a supplemental supply well for the
subdivision. In October 1987, the production well construction
and controlled test pumping was completed.
Between November 1985 and January 1986, many of the existing
residential wells in the subdivision were sealed and abandoned,
according to well abandonment reports filed with NJDEP. These
reports indicate that most of the wells on St. Joseph Drive were
screened at a depth of 110 to 120 feet; the rest were screened at
about 60 feet.
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It was not known at that time whether the contamination in the
Pomona Oaks subdivision was a result of a short term or
continuing release. The concentration of benzene appeared to
decrease after December 1982, suggesting that the contamination
may have resulted from a short term spill. A health threat no
longer existed for the residents of Pomona Oaks after an
alternative water supply was provided, and the exposure pathway
was eliminated by sealing all residential wells in the
subdivision. However, a number of homes to the southeast and
presumably downgradient of the subdivision still relied on
individual private wells for their potable water.
In July of 1981, Exxon inspected three gasoline storage tanks at
the Exxon Gas Station on White Horse Pike and Pomona - Port
Republic Road. One of the tanks was reported to have deep pits
but no holes. According to Exxon, the tank was placed out of
service. Tanks were excavated, opened and lined with fiberglass.
Work was completed in June 1982.
In December 1986, EPA initiated a Remedial Investigation and
Feasibility Study (RI/FS). The remedial investigation was
designed to determine the nature, extent and source of the ground
water and soil contamination at the site, which includes the
Pomona Oaks subdivision, Pomona Plaza shopping center and those
residents downgradient of the subdivision. The RI fieldwork,
conducted from October 1988 to March 1989, included a soil gas
survey, subsurface soil sampling, sediment sampling, monitoring
well and piezometer installation, one round of sampling from the
monitoring wells, two rounds of residential well sampling (in
Pinehurst), aquifer slug testing, and gamma logging of wells.
The feasibility study was to develop and evaluate alternatives to
address the contamination at the site. As a result of the
findings of the remedial investigation, it was determined that a
feasibility study need not be done.
Findings of the Remedial Investigation
A soil gas survey, which is a screening technique used to
determine volatile organic contamination present in the soil, was
used to help locate monitoring wells. The survey included the
subdivision itself, potential source areas, and non-contaminated
background areas. The results showed the presence of some
volatile aromatic compounds (often associated with petroleum
products) in two areas. The first area, located on the northwest
end of Father Keis Drive, had a maximum level of 523 parts per
billion of total volatile organics. The second area, around
Pomona Plaza and Cumberland Farms had a maximum total volatile
organics level of 55.8 ppb (see Figure 2).
Soil samples were collected from the deep wells at all of the
monitoring well locations. All samples were screened on location
for volatile organics. Based on this screening, three samples
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i n i "i i ri r
SAMPLE LOCATIONS
• ATLANTIC «V(
A WHITE HORSE PIKE
O POMONA ROAD
O POMONA PLAZA
A LANGLEY AVENUE
• DONNA DRIVE
D ROSEMARIE AVENUE
• ALL OTHER SAMPLE LOCATIONS
SCALE
I 5890
DATE
MAY. 1989
REM III
POMONA OAKS SITE
SOIL GAS CONTOUR MAP-TOTAL VOC's
FIGURE
ft MALHOTRA.P.C.
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from each boring were collected from above the water table
(approximately 12 to 15 feet) and sent to an EPA contract
laboratory for Target Compound List organics and Target Analyte
List inorganic analysis. No contaminants were found at levels
exceeding NJDEP Soil Cleanup Objectives.
Surficial sediment samples were collected from a drainage basin
in the northern part of the subdivision. The samples were
analyzed for volatile organics and inorganics. No compounds were
detected at levels above NJDEP Soil Cleanup Objectives.
Ground water samples were collected from the 19 monitoring wells
installed during the RI. The monitoring wells were installed at
three depths - shallow, intermediate and deep. The locations of
these wells are illustrated on Figure 1. The monitoring wells
were installed within the Pomona Oaks subdivision, upgradient and
downgradient of the subdivision. One of the monitoring wells was
installed in the Pinehurst area, which is downgradient. With two
exceptions, sample results from all monitoring wells were within
NJDEP guidelines. Benzene was found at 8 ppb in monitoring well
no. 1 (shallow, 20-30 feet), which is upgradient of the Pomona
Oaks subdivision and immediately adjacent to the salvage yard.
This concentration is above the current NJDEP Maximum Contaminant
Level (MCL) of 1.0 ppb for benzene. MCLs are enforceable
standards based on health risks associated with an individual's
consumption of two liters of water per day over a 70 year period.
In monitoring well no. 6 (intermediate, 88-98 feet) which is
immediately downgradient of the subdivision, 1,2-dichloroethane
was found at 6.8 ppb. This level is above the NJDEP MCL of 2.0
ppb for this compound. Trichloroethene was also found at a level
of 1.1 ppb, which is slightly above the NJDEP MCL of 1.0 ppb for
this compound. Follow-up samples collected on May 2, 1990
confirmed the presence of benzene in the shallow monitoring well
at location MW-1. Confirmatory samples from the three wells at
location MW-6 - shallow, intermediate and deep - showed no
compounds present at levels above NJDEP MCLs.
Residential wells in the Pinehurst area were sampled in the
winter of 1988 and again in August 1989. The Pinehurst area is
southeast and downgradient of the Pomona Oaks subdivision. Some
chemicals detected in the winter of 1988 sampling effort appeared
to exceed NJDEP MCLs. However, the chemical data was rejected
when it failed a detailed quality assurance/quality control
review. Another round of samples was collected in August 1989.
The results showed some compounds at levels slightly above
current NJDEP MCLs. They are presented below.
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RESIDENTIAL WELL SAMPLING RESULTS - August 1989
(all levels in parts per billion)
Compound Maximum Level Maximum Contaminant
Reported Level - NJDEP
Trichloroethene 3.1 1.0
Tetrachloroethene 1.7 1.0
Mercury 3.8 2.0
The five residents that showed these levels of contamination were
resampled on May 2, 1990 along with the monitoring wells
mentioned previously. Two of the five again showed levels of
mercury above the NJDEP MCL. The values were 3.9 and 4.0 ppb,
compared to the NJDEP MCL for mercury of 2.0 ppb. One of these
wells also had trichloroethene present above the NJDEP MCL (3.8
ppb as compared with the standard of 1.0 ppb). In the other
three wells, contaminant levels were less than NJDEP MCLs or
completely absent.
In a separate effort, the Atlantic County Health Department has
identified 22 residences out of 109, as of August 9, 1990, in the
Pinehurst area that have contaminants over NJDEP MCLs. The major
contaminants are trichloroethene, tetrachloroethene and mercury.
The area where the contamination was found includes Zenia Avenue
on the north, Poplar Avenue on the south, White Horse Pike on the
west, and Jimmie Leeds Road on the east. Although some of these
contaminants were also found in the Pomona Oaks subdivision in
1982 and 1983, it is believed that the chemicals now present in
Pinehurst are not related to the Pomona Oaks contamination.
Ground water velocity flow rates calculated during the remedial
investigation show that the Pomona Oaks contaminants could not
have travelled that far into the Pinehurst area in the last eight
years. Secondly, benzene and total xylenes, among other
contaminants, are absent in the Pinehurst area and were major
constituents-of the Pomona Oaks subdivision contamination.
Trichloroethene and tetrachloroethene, the major components of
the Pinehurst problem, were found at very low levels (25 ppb) as
compared to benzene and 1,2 DCA in the Pomona Oaks subdivision.
Data obtained during the remedial investigation has shown that
the ground water contamination in the Pomona Oaks subdivision no
longer exists above health risk or drinking water standard
levels. It has been concluded that the source of the
contamination was a singular event or events and that the
resultant ground water contamination had dispersed over time
through natural attenuation, volatilization and/or
biodegradation.
8
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Highlights of Community Relations
A Community Relations Plan was prepared for the Pomona Oaks site
and finalized in September 1988. This document identifies issues
of community concern regarding the Pomona Oaks site and describes
a program of community activities to be conducted by EPA to
address these issues. This document has been placed in the
information repositories.
Community involvement was solicited at the initiation of the
remedial investigation. A public meeting was held on
September 20, 1988 in the Pomona School on Genoa Avenue in
Pomona. At the meeting, EPA officials and the sub-contractor,
C.C. Johnson & Malhotra P.C. Inc., explained the remedial
investigation activities that were to be performed. Also, the
RI/FS Work Plan was placed in the local repositories for public
review.
The RI report was released on May 29, 1990 and the Proposed Plan
was released on July 20, 1990. Both of these documents, produced
for the Pomona Oaks site, were made available to the public in
the administrative record and at the four information
repositories in the Pomona Oaks area. 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 in the Galloway
Township Municipal Building, 300 East Jimmie Leeds Road, Absecon,
New Jersey 08201. The notice of availability for the Proposed
Plan was published in the Atlantic City Press on July 20, 1990.
A public comment period was held from July 20, 1990 to August 31,
1990. In addition, a formal public meeting was held on July 31,
1990. At this meeting, representatives from EPA, the Agency for
Toxic Substances and Disease Registry and 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
Types and nature of contaminants
Twenty volatile organic compounds, particularly benzene and
chlorinated hydrocarbons, were detected in 50 domestic wells in
the Pomona Oaks subdivision between 1982 and 1985. The
concentrations detected in 16 of the residential wells were
reported at levels exceeding the New Jersey drinking water
guidelines. The samples were collected over a three year period
by the ACHD (80 homes in 30 separate sampling events), the NJDOH
(36 homes in 2 events), and the EPA (65 homes in 2 events).
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Some of the compounds detected, the highest reported levels, and
the MCLs for drinking water are presented in Table 1.
These compounds are classified into two groups. The first group,
found in the wells in the eastern part of the development,
includes volatile aromatic compounds, which are lighter than
water (i.e., benzene, toluene, ethylbenzene and xylene). These
are often associated with petroleum products. The presence of
two distinct types of contamination at different locations in the
subdivision suggests two separate sources of contamination.
The second group consists of chlorinated hydrocarbons, usually
heavier than water (i.e., 1,1,1-trichloroethane (1,1,1-TCA),
dichlorobenzene, trichloroethene (TCE), methylene chloride
and 1,1-dichloroethane (1,1-DCA)). These compounds were
frequently used as solvents to remove grease and break down oil.
These were found in the western part of the subdivision.
SOURCES OF CONTAMINATION
The sources of contamination were not identified during the
remedial investigation. There was not enough contamination
present in the soil or the ground water to give an indication of
its origin. Potential sources include two nearby gas stations,
a local automobile salvage yard, and the now closed septic
systems of the Pomona Plaza Shopping Center and the residences in
the subdivision.
Exxon Gas Station (Pomona Garage)
This gas station, located to the west of the subdivision, is
considered a potential source of contamination due to waste type
and possible on-site waste disposal. In an interview conducted
by the NJDEP Division of Water Resources, the owner, Mr. Charles
Filling, stated that a product loss of about 200-300 gallons had
been noticed in the spring of 1982. In July 1982, it was
reported that three gas storage tanks were dug up and lined with
fiberglass. One of the tanks was reported to have had deep pits
but no holes.
Cumberland Farms Store and Gas Station
This business, located to the southwest of the subdivision, is
considered to be a potential source of contamination because of
the close proximity of its gas tanks to the contaminated ground
water as well as the corresponding waste type. Cumberland Farms
installed gas tanks at this location in 1974. The gas tanks had
not been tested for leaks as of October 1985.
10
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Pomona Garage Salvage Yard
This automobile junkyard, located to the west of the subdivision,
is adjacent to the Pomona Garage between Langley Avenue and White
Horse Pike. Benzene was detected at a level of 8 ppb in the
shallow monitoring well (MW-1) immediately downgradient
(southeast) of the property. Samples taken on May 2, 1990
confirmed the finding.
Pomona Oaks Shopping Plaza
This plaza, located to the southwest of the subdivision, may be
considered a potential source of contamination mainly due to an
inadequate septic system and a laundromat/dry cleaner on the
property. Wastes were emptied into the septic system which
overflowed regularly. The laundromat/dry cleaner moved out of
the shopping center in 1976. In late 1982, the Atlantic County
Health Department sampled the septic tank and found methylene
chloride at 280 ppb, trans-l,2-DCA at an estimated 1,050 ppb, TCE
at 670 ppb, chlorobenzene at 10 ppb, toluene at an estimated
6,400 ppb, and total dichlorobenzenes at 550 ppb. In December of
1983, the county had the owners install and sample two monitoring
wells. Results showed one well clean and the other to contain 10
ppb of chloroform. The ACHD concluded that, if the Pomona Plaza
was a source of contamination in the past, the chemicals were no
longer present and cleanup was not appropriate.
Residential Septic Tanks
It is possible that the ground water was contaminated by overflow
of private septic systems. Degreasing chemicals which are used
to clean septic systems contain 1,1,1-TCA and TCE. The septic
systems were used up until 1982.
KNOWN OR POTENTIAL ROUTES OF MIGRATION OF THE CONTAMINATION
The potential routes of migration for chemicals at the Pomona
Oaks site include migration from soil to ground water, migration
of shallow ground water to deeper ground water, lateral migration
of on-site ground water to off-site areas, migration into air by
volatilization or by suspension of soil, and biotransformation of
chemicals into more toxic and/or more mobile products.
Ground Water
Ground water is the primary pathway of contaminant migration
documented to date at the Pomona Oaks site. Benzene was detected
in one shallow well (MW-1S) located downgradient of the salvage
yard. Chloroform and other chlorinated hydrocarbons were
detected in the downgradient residential wells. Inorganics above
background included mercury.
11
-------
The chemicals detected in ground water may have resulted from the
direct percolation of liquid wastes through the soil and/or by
the leaching of constituents contained in soil by infiltrating
precipitation.
The initial encounter with contamination in the subdivision was
from a residential well on Terry Lane near monitoring well no. 3.
This well was screened at approximately 60 feet below the
surface.
Data gathered during the remedial investigation in 1989 confirmed
the southeast flow direction for the ground water in the Pomona
Oaks area. More specifically, flow direction in the upper and
middle (100 feet below the surface) Cohansey is to the east
across the subdivision and to the southeast, east of Avenue A
(see Figure 3). The ground water flow changes direction from
east to southeast, because the North Branch stream acts as a
shallow ground water discharge area. Flow direction in the deep
Cohansey aquifer (down to 200 feet) is slightly east of south.
This deep part of the aquifer is affected by pumping from the
Atlantic City Municipal Wellfield, to the south.
Ground water velocities in the Cohansey vary in the vertical and
horizontal directions. They are calculated from the hydraulic
gradient (measured changes in elevation of water table from well
to well) and hydraulic conductivity (a numerical value
representing the aquifer's ability to transmit water). Hydraulic
gradient in this area is about seven feet per mile. Hydraulic
conductivity varied greatly depending on the composition of the
material around the well. Very tightly packed silt or clay had
very low hydraulic conductivity while coarse gravel beds had very
high values. Generally, the hydraulic conductivity is lower at
lower depths. The sediments near the surface are not packed as
tightly as the sediments below. However, in this type of
depositional environment, intertidal continental shelf, the
sediments are not homogeneous. Clay, silt, sand and gravel are
intermixed as rivers bring in different size particles from the
west and stormy seas from the east rework the beaches, sometimes
forming channels with gravel and organic material and sometimes
forming thick clay deposits in intertidal pools.
The ground water velocity varies in the Pomona Oaks area. In
June 1989, a period of heavier than usual rainfall, the average
value for the shallow Cohansey was 140 feet per year, the middle
was 23 feet per year, and the deep was 77 feet per year. This
indicates that there is a zone at about 100 feet below the
surface where ground water flow is more restricted. Vertical
ground water flow rates were also calculated. The ground water
is flowing downward at a rate of 0.35 to 0.54 feet per year. The
contamination found in the subdivision in June of 1982, that is
denser than water, should be moving in a southeasterly direction
at a rate of 23 to 77 feet per year and sink at a rate of 0.35 to
12
-------
r
\
LCOEND
•AS STATIONS
MONITOftINO WELL LOCATION
riCZOMCTDt LOCATION
SCALE
I 13090
NOTE DATA COLLECTED ON !/?T/89
FIGURE 3
NCM III
POMONA OAKS SITE
SHALLOW WATER LEVEL MAP
SCALE'A3 SHOWN • JULY I9»t
-------
0.54 feet per year. Therefore, contamination should have been
present in the intermediate or deep wells at location MW-5 or
MW-6 after 7 years. In fact, 1,2-DCA at 6.8 ppb and TCE at 1.1
ppb were found in the first round of samples from MW-6
intermediate (88 - 98 feet). However, the well was resampled
again on May 2, 1990 and these chemicals were not detected. As
expected, compounds lighter than water were not found in
intermediate and deep wells downgradient of the subdivision. If
they were still present in the ground water in 1989, they should
have been present in the shallow wells at MW-5 or MW-6. Benzene
was not found in any of the downgradient wells. Since the
Cohansey is an unconfined aquifer, open to the surface, and the
ground water table is about 15 feet below the surface in an
extremely porous medium, most of these compounds are believed to
have volatilized. It is also believed that the remaining
contaminants in the ground water have biodegraded in seven years.
As part of the remedial investigation, 20 residential wells,
evenly distributed in an arc to the southeast (downgradient) of
the subdivision (see Figure 1), were selected for private well
sampling. These 20 homes were chosen because it was expected
that the Pomona Oaks contamination would have travelled this far
in eight years if the ground water flow rate was 365 feet per
year or greater. It was determined that the average flow rate
was much less. Even at the maximum flow rate for the
intermediate part of the aquifer, which was 124 feet per year,
the leading edge of the contamination would be no further than
Coolidge Avenue and Avenue B (see Figure 1).
As previously discussed, it is believed that the contamination
found in the Pinehurst area is not related to the contamination
in the Pomona Oaks subdivision. Although the potential path of
migration would allow for ground water to travel from the Pomona
subdivision to the Pinehurst area, the compounds found in
Pinehurst are not in the same proportions as those found in the
subdivision. For instance, the two most prevalent volatile
organic "sinkers" in Pinehurst are trichloroethene (TCE) and
tetrachloroethene (PCE). The compound 1,2-DCA was not found.
In the Pomona Oaks subdivision, 1,2-DCA was present at 880 ppb
and TCE and PCE were present at a maximum level of 25 ppb each.
Also, there were compounds found in Pinehurst that were never
detected in the Pomona Oaks subdivision, most notably mercury.
Finally, any contamination from the 1982 - 1985 event in the
subdivision would have sunk to the level of the intermediate and
deep monitoring wells (at least 90 feet below the surface), as
shown by the contamination in the MW-6 intermediate well. Most
of the homes in the Pinehurst area have wells screened at a
relatively shallow depth, usually less than 60 feet.
Benzene was detected in the shallow well at location MW-1 at a
level of 8 ppb. This monitoring well is upgradient of the Pomona
Oaks site area. The shallow water table is 14 feet below the
13
-------
ground surface. Evidence indicates that benzene contamination is
coming from Charles Filling's automobile salvage yard. This
property is less than 50 feet to the northwest and upgradient of
this well. This situation has been reported to the New Jersey
Department of Environmental Protection's Southern Bureau of
Regional Enforcement for follow-up investigation.
MIGRATION IN AIR
Volatile organics may enter the air pathway from the soil or
ground water. VOCs present in soil can volatilize and become
airborne. Volatization from soil may be enhanced by disturbance
of the soil. During the RI, only one soil sample was found to
contain traces of chloroform and toluene. Therefore, it is
unlikely that significant migration of chemicals from soil to air
occurs at this time.
VOCs present in the ground water may also volatilize and be
released into ambient air when water is pumped out of a well and
utilized. The New Jersey Department of Health focused on this
exposure pathway in 1983, when they studied Pomona Oaks
residents' exposure to benzene while showering and using
contaminated water. This pathway was eliminated when the
residents were given an alternate water supply.
MIGRATION IN SURFACE WATER
Local surface water features often function as shallow ground
water discharge points in the Pinelands area. Since no
downgradient surface water bodies or wetlands have been
identified near the study area, there is no potential for
exposure to the contaminants via surface water. Furthermore, no
streams or creeks flow through the Pomona Oaks site. The North
Branch stream is about three quarters of a mile to the southeast
of the Pomona Oaks subdivision but is not considered to be
affected by the Pomona Oaks site.
MIGRATION IN SOIL
No migration pathway in soil has been identified for the
chemicals detected at the Pomona Oaks site. No surficial soil
sampling was conducted during the RI. Organic chemicals were not
present either in subsurface (2-4 feet) or deeper (10-14 feet)
soil samples.
SUMMARY OF SITE RISKS
The baseline risk assessment (public health evaluation) in the RI
report addresses the potential hazards to public health
associated with the Pomona Oaks site under the no-action
alternative. The results are summarized here.
14
-------
Data from all EPA sampling events were combined into a single
data base for use in this risk assessment. These combined data
were then reviewed and evaluated, along with historical data and
information on the physical characteristics of the site, in order
to establish patterns and levels of contamination at the site.
Since only a limited number of compounds of potential public
health concern were detected at the site, the detailed indicator
selection process normally used was not necessary. Instead, all
chemicals detected in ground water, organic and inorganic, were
screened. This screening process is used to identify the highest
risk chemicals at the site, which are referred to as chemicals of
concern.
Concentration levels of chemicals detected during the RI at the
Pomona Oaks site along with frequency of detection, presence in
the field and trip blanks, and site background concentrations for
ground water are presented in Tables 2 and 3. Whether a compound
is selected for the purpose of risk characterization is also
noted in the tables. Those selected were chloroform,
trichloroethene, 1,1,1-trichloroethane, 2-butanone, benzene,
toluene, 1,1-dichloroethane, tetrachloroethene and barium (see
Table 4). Benzene was included as one of the chemicals of
concern because of it's carcinogenic property, and the fact that
it was found in past ground water sampling events (1982-1985) at
significant concentrations.
Ground water is the principal source of potential exposure to
those area residents still dependent upon residential wells for
their water needs. There are an estimated 200 residential wells
serving a population of about 1000 people downgradient of the
Pomona Oaks subdivision.
The concentrations of the chemicals of concern in ground water
are given in Table 5.
The possibility of exposure through dermal contact with and/or
inhalation or ingestion of soil is very low. Exposure due to
volatilization of volatile organic compounds present in the
ground water, for the purpose of this evaluation, was considered
a possibility at the site. When water is pumped to the surface
and used, VOCs could be released during dishwashing, while
showering and when watering lawns and gardens. However, exposure
by this route is minimal because the compounds are generally
absent in the ground water.
RISK CHARACTERIZATION
EPA's Carcinogenic Assessment Group has developed cancer potency
factors for estimating excess lifetime cancer risks associated
with various levels of lifetime exposure to potential human
carcinogens. The cancer potency factor (CPF), (in units of
15
-------
SIT!
OF" OI5J3RM I C COMCE
Z M
I ON!
1
1
1 COMPOUNDS
1 Winy I CM or i O*
Iftcvton*
IH» thy l»r>« Chloride
I 1, l-Dichlor-09tlt»n*
1 1 • l-Dic*loro9th«ne
•Chloroform
I 1 1 2-DicHloro«tft«rt*
1 Trich I oro»t*"»»n*
1 T*tr *e* 1 or o*th«ne
I B*r\z»n»
ITolu*n*
1 2*But.«non«
t 1 • 1 » l-Tncf"tloro»tK«rto
IC«r*bon T« trichloride
IDl»thylphth«l«t»
1 0 i — n-Buty 1 phtha 1 «t»
lbl9C2-Ethylh»xyl )Phtl->«l«t»
l«lph«-BHC
lg«mn«-BHC CLind«n»)
!««,«' -DDT
11.3. 5-Cyc lol->»ptr«i»nc
OBSERVED <
FREQUENCY
1/39
3/39
3/39
1/39
9/39
22/39
1/39
8/39
6/39
1/39
«/39
6/39
11/39
1/39
3/39
1/39
«/39
2/39
1/39
1/39
2/39
rONCENTRflTIONS
CONCENTRPTJON
RRNGE CU6/L)
0.^7 J
0.3 B - 5 J
0.2 - O.*
O.6
0.9 - 2.4
0.2 6 - 6.9 B
6.6
O.5 - 3.1
0.4 - 1.7
B
0. 1 B - O.2 B
0.2 B - 0.9 B
O.2 - 2.7
0.3
20 - 25
O.9 J
2 J - 64
0. 1 - 0. 14
0.056
0.52
31 JN - 70 JN
CONCENTRHTION
RUNGE CUG/L)
—
—
—
—
—
2 J
—
—
—
—
—
19 JN
HRX i nun
FIELD/TRIP
BLANK CONC.
CU6/LJ
—
74
—
—
—
—
—
—
—
—
—
78
31
~
—
— '
SELECTED
N
N
N
N
Y
Y
N
Y
Y
Y
Y
Y
Y
N
N
N
N
N
N
N
N
DflTP QUALIFIERS
J : Indicates an estimated value.
JN : Presumptive evidence of presence of compound at *n ••ti»«t*d valu*.
6 : Indicates results are blank subtracted.
« Considers samples collected fro» nW-BS,HU-8I.ar%d nu-BO.
-------
OF" i
I C
1
1
! COMPOUNDS
I R 1 LHTI i num
IB«riuin
1 Cadm i urn
IC*lcium
(Chromium C Total )
1 Cob* It
I Copper
1 Iron
ILeed
(Magnesium
(Manganese
1 Mercury
1 Nickel
(Potassium
(Silver
(Selenium
(Sodium
1 Waned i um
IZinc
OBSERVED
FREQUENCY
32/39
38/39
3/39
38/39
9/39
4/39
24/39
27/39
17/39
38/39
26/39
13/39
5/39
37/39
2/39
2/39
39/39
1/39
30/39
lONCENTRRTIONS
CONCENTRATION
RANGE CUG/L)
230 - 139OO J
26> - 890
0.5 - 1.2
120 - 255OO
7.4 - 18.3 J
5 - 9.9
9.9 - 320
58 - 3530
6 - 17. 1 MS
455 - 15-4OO
«5.2 - 250
0.2 - 3.8
5.5 - 17.9
420 - 6100
1 - 1
2.3 JN - 3 UJ
1400 - *49OO
3.6
2? - 767
Cl)
CONCENTRRTION
RANGE CUG/L>
9-
-------
T M IE 4
P 0 B 0 N A OAKS SITE
POTENTIAL EIPOSURE AND RISKS ASSOCIATED KITH IN 6 E S T I ON OF
6ROUNDNATEA
CHEHICAL
Chlorofen
Trichlore-
Jthtni
Moroethne
i
i
1
I 2-Butinone
i
1
1
I Ben:vnr
.' Toluene
i
•
il,l-Dichloro-
iitfcine
JTetrichlorc-
Irthene
I
• Itriui
CONCENTRATION
(U6/L)
BAXIflJ"
6
3.1
2.4
0.9
e
0.2
2.4
1.7
690
EIP2SURE
3.52
0.54
2.18
5.15
2.22
2.36
2.16
2.09
164.93
CHRONIC DAILY
INTAKE
(S6/K6/DAY)
CARCINO-
GENIC
4.29 E-C5
6.56 E-06
—
—
2.7 E-05
—
2.65 E-05
2.54 E-05
—
NONCARCI-
NOBENIC
1.02 E-04
—
6.96 E-05
1.49 E-04
~
6.64 E-05
6.32 E-OS
—
6.06 E-05
5.36 E-03
SUBCHRONIC
DAILY
INTAKE
(H6/K6/MY)
NONCARCI-
N06ENIC
2.39 E-04
_
1.63 E-04
3.5 E-04
1.6 E-04
1.46 E-04
1.42 E-03
1.25 E-02
!
CANCER
POTENCY
FACTOR
(Hfi/Kfi/DAY)
6.1 E-03
1.1 E-02
..
—
2.9 E-02
—
9.1 E-02
5.1 E-02
—
REFERENCE
DOSE
(H6/K6/DAY)
CHRONIC
1.0 E-02
—
9.0 E-02
5.0 E-02
~
3.0 E-01
1.0 E-01
1.0 E-02
5.0 E-02
SUBCHRONIC
1.0 E-02
_
9.0 E -01
5.0 E-01
—
4.0 E-01
1.0
1.0 E-01
5.0 E-02
! TOTAL
1 1
1 1
i
1
1
1
1
1
EICESS ! HAZARD
LIFETIME I INDEI
CANCER RISK! (CHRONIC)
t
2.62 E-07 ! 1.0 E-02
1
7.26 E-08 ! -
i
- ! 7.43 E-04
!
i
1
! 2.98 E-03
1
1
i
1
1
7.83 E-07 ! -
1
1
I mwr
1
1
- ! 2.26 E-04
1
2.14 E-06 ! 6.32 E-04
1
1
1
1.29 E-06 ! 6.06 E-03
1
1
I
t
1
- ! 0.107
1
t
1
1
1.06 E-06 ! 0.12
1
1
HAZAftC
INDEI
(SUBCHRONIC)
2.39 E-02
_
1,6! E-04
7.0 E-04
—
4.0 E-04
1.46 E-04
1.42 E-03
0.25
0.27
Note : Eipoiurt Conctntrttion t 951 upDtr Confidence Liiit (UCL) on fieoietric bin.
-------
TABLE 5
POMONA OAKS SITE
CONCENTRATION OF CHEMICALS OF CONCERN IN GROUNDWATER
Compound
ORGANICS
Benzene
2-Butanone
Chloro-
form
Federal
SDWA
MCLS
(ug/1)
5
NR
NR
NJSDWA
MCLS
(ug/1)
l
NR
100 (c)
Frequency^*)
1/39
6/39
22/39
Exposure^)
Concen-
tration
(ug/1)
2.22
0.9
6.9
Maximum
Concen-
tration
(ug/1)
8
0.9
6.9
1,1,1-Tri- 200
chloro
ethane
Trichloro- 5
ethene
Toluene NR
1,1-Di- NR
chloro
ethane
Tetra- NR
chloro
ethane
INORGANICS
Barium 1000
26
NR
NR
11/39
8/39
4/39
9/39
6/39
2.4
0.54
2.36
2.18
2.09
2.7
3.1
0.2
2.4
1.7
1000
38/39
164.93
.890
(a) Number of samples in which the chemical was detected over
the total number of samples
(b) 95% Upper Confidence Limit on Geometric Mean
(c) New Jersey Standard for Total Trihalomethane
NR = Not Reported
-------
(mg/kg (milligrams per kilogram) of body weight/day)"1), is a
number which, when multiplied by the lifetime average daily dose
of a potential carcinogen (in mg/kg of body weight/day), yields
the upper-bound lifetime excess cancer risk for exposure at that
dose. The term "upper-bound" reflects the conservative estimate
of the risk from the CPF. Use of this method 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. This multiplication approach can be used for low doses
corresponding to cancer risks lower than 10"2. An excess lifetime
cancer risk of 1 x 10^, for example, represents the incremental
probability of one in a million that an individual will develop
cancer as a result of exposure to a carcinogenic chemical over a
70 year lifetime under specified exposure conditions.
EPA's guidelines state 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
1,000,000 people) and 10"4 (one additional cancer in 10,000
people). Any numbers above the target range, or greater than
10"4, are unacceptable and will trigger some kind of remedial
action. Excess lifetime cancer risk numbers for Pomona Oaks are
identified on Table 4.
For those chemicals exhibiting non-carcinogenic effects, health
criteria numbers are based on EPA Reference Doses (RfD). In
general, the reference dose is an estimate of an average daily
exposure to an individual below which there will not be an
appreciable risk of adverse health effects. Doses that are
significantly higher than the RfD may indicate that an inadequate
margin of safety could exist for exposure to that substance and
that an adverse health effect could occur. RfDs are expressed in
units of mg/kg of body weight/day. 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 effects of humans). These uncertainty factors
help insure that the RfDs will not underestimate the potential
for adverse non-carcinogenic effects to occur. The RfD values
were obtained from the EPA Integrated Risk Information System
where available. From this data, a Hazard Index number is
generated. If this number is less than or equal to one, no
adverse effects are anticipated from the exposure and dose level.
If the number is greater than one, the exposure and 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. Hazard Indices for the Pomona Oaks residents were
calculated and are printed on Table 4.
16
-------
A risk characterization was performed on all of the chemicals of
concern at the Pomona Oaks site and excess cancer risk numbers or
hazard index numbers were calculated for ingestion of ground
water and inhalation of compounds released from ground water.
Results of the Quantitative Risk Characterization
The results of the calculation for potential carcinogenic risks
and non-carcinogenic risks through inhalation (using contaminated
ground water during showering) pathway are summarized in Tables 6
and 7. Non-carcinogenic risk due to subchronic exposure by
children under 6 years old is presented in Table 8.
The excess cancer risk for carcinogens is in the range of 10"8 to
10*. The hazard index numbers for non-carcinogens were well
below 1.
The results of the calculation for potential carcinogenic risk
and non-carcinogenic risks through the ingestion of ground water
pathway are presented in Table 4. Non-carcinogenic risks due to
subchronic exposure are also presented in Table 4.
The cancer risk for carcinogens is in the range of 10"8 to 10"6.
The hazard index numbers for non-carcinogens via chronic and
subchronic ingestion routes are below 1.
The total site risks, where the assumption is made that a person
will ingest all of the carcinogenic or non-carcinogenic
contaminants simultaneously, are presented on Table 4. These
totals are also within the range considered acceptable for
carcinogens and below 1 for non-carcinogens.
The risk characterization for people in contact with ground water
shows that there are no, or insignificant risks.
Sources of Uncertainty
Uncertainty in environmental sampling arises in part from the
potentially uneven distributions of chemicals in the samples.
Typically, this problem is encountered more frequently in soil
than in water. The collection of "grab samples" allows an
estimate of the variation in the chemical composition in the area
to be made. Environmental chemistry analysis error can stem from
several sources including the errors inherent in the analytical
methods, or the characteristics of the matrix being sampled. For
this RI, the analytical methods chosen were all approved by EPA.
Procedural or systematic error was minimized by subjecting the
data to a strict laboratory quality control review and data
validation process. Several samples were flagged with a "J" or
other data qualifier, indicating that these chemicals were
detected but the reported levels were estimated. Although these
estimated results may add an additional degree of uncertainty to
17
-------
I IMOGE1IM 1 C K? T
I F1
1 C
I C I MMRILRIT I OIM
I r
CHEMICnL
Bonzooo
Ch 1 or of or-m
1 . l-DicHlor-o«tHan«
Totrech 1 or-o*th«n*
Tr i ch 1 oro*t.H*o*
CONCENTRRTION
rmxinuH
e.o
6.9
2.4
1.7
3.1
EXPOSURE
2.22
3.52
2. 18
2.09
O.54
AIRBORNE
CONCENTRRTION
IN n SHOWER
STRLL
CUG/CU.M)
37
58.66
36.33
34.03
9.O
HUMAN INTRKE
FRCTOR
CCU.«/ICG-OHV>
3.69 E-O4
3.6O E-O4
3.60 E-01
3.6B E-O4
3.6O E-O4
CHRONIC
DRILY
INTRICE
CCDI)
1.36 E-05
2.15 E-O5
1.33 E-05
1.29 E-05
3.31 E-O6
SLOPE
FRCTOR
2.9 E-O2
9. 1 E-O2
9. 1 E-02
3.3 E-O3
1.7 E-02
TOTflL
LIFETIME
EXCESS CRNCER
RRTE
CDIMENSIONLESS)
3.94 E-07
1.74 E-O6
1.21 E-06
4.22 E-O9
5.62 E-O9
3.44 E-O6
Not* i Exposure Concentration = 95X Upper Confidence Limit on Geometric Mean.
-------
i i_e:
CHEMICOL
ChlcM-ofcM-«
1.1.1-TCC
2-Bu^aoon*
Toluen*
1 . l-OicHloro«than«
T»tr»ch 1 or o«t.h«rt*
CONCENTRRTION
(UG/L)
rmxinun
6.9
2.7
O.9
0.2
2.4
1.7
EXPOSURE
3.52
2.-W
5.15
2.36
2. IO
2.09
AIRBORNE
CONCENTRHTION
IN R SHOWER
STRLL
58.66
-13.84
85.83
39.33
36.33
34.83
MUMRN INTRKE
FRCTOR
CRDULT)
(CU.H/KG-ORV)
8.59 E-04
8.59 E-O4
8.59 E-O4
8.59 E-O4
8.59 E-O4
8.59 E-O1
CHRONIC
DRILY
INTRKE
-------
8
i i»4o«3E:r* T
r sic
i c
SITE
x c i
CHEniCRL
Chloroform
t,I.l-TCE
2-Bui.anort*
Tolu*n»
1 . l-Oichlo*-oc»t»Mn«
T»tr-»chlof-o«tK»r*»
CONCENTRRTION
rmxinun
6.9
2.7
O.9
O.2
2.«
1.7
EXPOSURE
3.52
2.-4O
5.15
2.36
2.18
2.09
FURBORNE
CONCENTRATION
IN R SHOWER
STRLL
58.66
43.81
85.83
39.33
36.33
—
34.83
HUMHN INTRKE
FRCTOR
< CHILD)
CMG/K6-DRV)
2.22 E-05
1.66 E-O5
3.26 E-05
1.49 E-O5
1.38 E-05
1.32 E-OS
SUBCHRONIC
REFERENCE
DOSE
l.O E-O2
3.O E-01
3.0 E-O
4.0 E-01
l.O E-O
1.0 E-01
TOTHL
HO2RRO
INDEX
(DIMENSIONLESS>
2.22 E-03
5.53 E-05
1.O8 E-O5
3.72 E-05
1.38 E-O5
1.32 E-O4
2.46 E-O3
Not* ( 1.1.1-TCE = 1, 1. l-Ti-ichloro»thao«.
Exposur* Coocontration = 95^ Uppor- Confidence Limit CUCL> on 6«o«*tric Mean.
-------
the concentration levels, they were considered valid results and
were used in the assessment.
With respect to exposure scenarios evaluated in this risk
assessment, risks for certain individuals within an exposed
population will be higher or lower depending on their actual
drinking water intakes, body weights, showering habits, etc.
Toxicological data error is a large source of error in any risk
assessment. According to EPA's Guidelines for Carcinogenic Risk
Assessment (1986), there are major uncertainties in extrapolating
both from animals to humans and from high to low doses. There
are important species differences in uptake, metabolism, and
organ distribution of carcinogens, as well as species and strain
differences in target site susceptibility. Human populations are
variable with respect to genetic constitution, diet, occupational
and home environment, activity patterns and other cultural
factors.
There is also uncertainty in assessing the toxicity of a mixture
of chemicals. In this assessment, the effects of exposure to
each of the contaminants present have initially been considered
separately. However, these substances occur together throughout
the site and individuals may be exposed to mixtures of chemicals.
Prediction of how these mixtures of toxicants will interact must
be based on an understanding of the mechanisms of such
interactions. Individual compounds may react chemically,
yielding a new toxic component or causing a change in the
biological availability of an existing component, or may interact
by causing different effects at receptor sites. Suitable data
are not available to characterize the effects of chemical
mixtures similar to those present at Pomona Oaks. Consequently,
chemicals were assumed to act addictively, and potential health
risks were evaluated by summing excess cancer risks and
calculating hazard indices for chemicals exhibiting carcinogenic
and non-carcinogenic effects, respectively. This approach
assumes no synergistic or antagonistic interactions among the
chemicals considered and that all chemicals have the same toxic
end points arid mechanisms of action. To the extent that these
assumptions are incorrect, the actual risk may be under or over-
estimated.
Environmental Assessment
The residual chemical contaminant concentrations at the Pomona
Oaks site are so low that it is reasonable to conclude they are
not likely to result in any adverse impact on the environment.
There are no endangered or threatened species in the immediate
area of the site.
18
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Description of No Action Alternative
Section 121(d), Degree of cleanup (1), of the Comprehensive
Environmental Response, Compensation and Liability Act, as
amended by the Superfund Amendments and Reauthorization Act,
states "Remedial actions selected under this section or otherwise
required or agreed to by the President under this Act shall
attain a degree of cleanup of hazardous substances, pollutants,
and contaminants released into the environment and of control of
further release at a minimum which assures protection of human
health and the environment. Such remedial actions shall be
relevant and appropriate under the circumstances presented by the
release or threatened release of such substance, pollutant or
contaminant".
Data obtained during the remedial investigation has shown that
the ground water contamination in the Pomona Oaks subdivision no
longer exists above health risk or drinking water standard
levels. It has been concluded that the source of the
contamination was a singular event or events and that the
resultant ground water contamination had dispersed over time
through natural attenuation and/or biodegradation.
Since there is no current source of contamination in the Pomona
Oaks Subdivision, source control is not necessary. Likewise,
since the area wide ground water contamination no longer exists
above standards, there is no need to develop and evaluate ground
water remediation alternatives. Therefore, EPA, in conjunction
with the NJDEP have decided that "No Action" is appropriate for
the Pomona Oaks Subdivision.
As part of the "No Action" remedy, EPA will continue to monitor
the existing wells in the Pomona Oaks area. Also, EPA will
provide technical assistance to the NJDEP in it's study of the
ground water contamination in the Pinehurst area.
This decision is based on the following facts;
The -immediate threat to the residents of the Pomona Oaks
subdivision was removed by the installation of the alternate
water supply in 1985;
The remedial investigation shows that the high concentrations
of chemicals that were present during the 1982 to 1985 period
have significantly decreased to below drinking water standards
suggesting dispersion and/or biodegradation of contaminants over
time;
The contamination is not currently present in the Pomona Oaks
subdivision and, therefore, did not come from a continuous
source, but most likely discrete events;
19
-------
Most of the compounds found were at levels below relevant and
appropriate federal and/or state standards;
The Baseline Risk Assessment showed that the chemicals of
concern present at the Pomona Oaks site do not pose a
significant health threat; and
The Baseline Risk Assessment illustrates the fact that the
probability of ecological impacts was estimated to be
negligible.
The source of contamination in the Pinehurst area, downgradient
of the Pomona Oaks subdivision, is presently undetermined.
The New Jersey Department of Environmental Protection is
currently working with Galloway Township and the Atlantic County
Health Department to determine it's source and provide an
alternate water supply to the affected residents in Pinehurst.
Explanation of Significant Changes
The Proposed Plan for the Pomona Oaks site was released for
public comment on July 20, 1990. The Proposed Plan identified
No Action as the preferred alternative. EPA reviewed all written
and verbal comments submitted during the public comment period.
Upon review of these comments, it was determined that no : , -
significant changes to the remedy, as it was originally
identified in the Proposed Plan, were necessary. :
20
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POMONA OAKS WELL CONTAMINATION SITE
GALLOWAY TOWNSHIP, NEW JERSEY
RESPONSIVENESS SUMMARY
This Responsiveness Summary provides a summary of citizen's
comments and concerns, and the U.S. Environmental Protection
Agency's (EPA's) responses to those comments and concerns,
relating to the Remedial Investigation (RI) and Proposed Plan for
the Pomona Oaks Well Contamination Site (site) in Galloway
Township, New Jersey. All comments received during the public
comment period will be considered in EPA's final selection of a
remedy for the site.
EPA invited public comment, from July 20, 1990 through August 31,
1990, on the RI and the Proposed Plan for the site. The public
comment period was announced on July 20, 1990 in the Atlantic
City Press and the Beachcomber News. Additionally, the Proposed
Plan was distributed by mail to the individuals on the mailing
list maintained for the site.
In addition, the EPA held a public meeting on July 31, 1990 at
the Galloway Township Municipal Building in Galloway Township,
New Jersey to discuss the results of the RI and present EPA's
preferred remedial alternative for the site.
In general, public comment was positive as evidenced by the lack
of criticism for EPA's Proposed Plan. However, residents remain
concerned about potential long-term health effects from exposure
to site contaminants. Additionally, residents and local
officials strongly encouraged continued EPA monitoring of the
nearby Pinehurst ground water contamination problem.
This responsiveness summary is organized in the following
sections.
I. RESPONSIVENESS SUMMARY OVERVIEW
This section briefly describes the background of the site and
outlines EPA's preferred remedial alternative.
II. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
This section provides a brief history of community interest and
concerns regarding the site.
III. SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED DURING THE
PUBLIC COMMENT PERIOD AND EPA RESPONSES TO THESE COMMENTS
-------
This section summarizes both oral comments received by EPA at the
public meeting and written comments submitted during the public
comment period, and provides EPA's responses to these comments.
IV. REMAINING CONCERNS
This section discusses community concerns that the EPA should be
aware of as they prepare to undertake further remedial activities
at the site.
Attached are three appendices. Appendix A contains the Proposed
Plan for the site. Appendix B contains the sign-in sheet of
attendees at the July 31, 1990 public meeting. Appendix C
contains the public notice issued to the Atlantic City Press and
the Beachcomber News, which was printed on July 20, 1990,
announcing the public comment period and availability of the RI
and Proposed Plan for public review.
I. RESPONSIVENESS SUMMARY OVERVIEW
A. Site Background
The site includes the Pomona Oaks residential subdivision (193
homes) and an adjacent shopping center in Galloway Township,
Atlantic County, New Jersey. Atlantic City is located ten miles
to the southeast. The study area is bordered on the south by
White Horse Pike (U.S. Route 30), on the east by Willow Avenue,
on the north by Jimmie Leeds Road, and on the west by Pomona-
Port Republic Road. The actual subdivision boundaries go as far
as Donna Drive on the eastern side (see Figure 1).
The Pomona Oaks subdivision is a residential neighborhood
containing single family homes built in the 1970s. It is
surrounded by undeveloped wooded areas, scattered residences and
small "strip" type shopping areas. Some of the outlying areas
are farms. A gas station is located on the southwestern boundary
of the Pomona Oaks subdivision. A Globe gas station and a gas
station/salvage yard are also located to the west and northwest,
respectively. The Pomona Plaza Shopping Center, which includes a
dry cleaner, is located to the southwest.
Initially, residences within the subdivision relied on individual
septic systems for waste water disposal and on private' wells for
their source of potable water. In 1982, all of the homes in the
subdivision were connected to the public sewer system. The
residential potable wells were screened in the Cohansey
Formation, an unconfined aquifer that extends from the surface to
approximately 200 feet.
In June 1982, several residents on Terry Lane notified the
Atlantic County Health Department (ACHD) of foul tasting well
water. Subsequent sampling of residential wells in the
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POMONA OAKS
SUBDIVISION
SALVAGE YARD/GAS
STATION
A RESIDENTIAL WELL
PIEZOMETER
LOCATION
MONITOR WELL
LOCATION
ROUTE 3O
WHITE HORSE PIKE
SCALE
NO SCALE
RFM III
POMONA OAKS SITE
RESIDENTIAL WELL SAMPLE LOCATIONS
DATE
MAY 1989
r r
* MAI MOTRA.P.C
-------
subdivision by the EPA, the New Jersey Department of
Environmental Protection (NJDEP) and the ACHD through 1985
revealed the presence of twenty volatile organic compounds.
As a result of these findings, residents were advised by the ACHD
not to use the water for drinking or cooking. In June 1984,
NJDEP requested assistance from EPA to mitigate the impact of the
ground water contamination. By August 1985, after a number of
different sampling events conducted by the NJDEP and the ACHD,
all 193 homes in the Pomona Oaks subdivision were connected to
the municipal water supply of the neighboring community of
Absecon by the NJDEP using New Jersey Spill Compensation Fund
monies. Between November 1985 and January 1986, the existing
private wells were sealed by the NJDEP, also using Fund monies.
The alternate supply of water removed the immediate health risk
to the residents of the Pomona Oaks subdivision. However, there
are a number of homes to the southeast of the subdivision that
continue to rely on private residential wells for their potable
water supply.
B. Remedial Investigation Summary
The site was proposed for the National Priorities List (NPL) on
October 1, 1984 and finalized on June 1, 1986. In 1988, EPA
initiated a remedial investigation (RI) to determine the nature,
extent and source of the contamination, and to sample the
residential wells downgradient of the subdivision to determine if
they were contaminated. The RI field work, conducted from
October 1988 to March 1989, included investigations to
characterize the geologic and hydrologic conditions in the area
and any contamination of soils, sediments and ground water in the
Pomona Oaks subdivision.
Soil samples were collected from the deep wells at eight
monitoring well locations. The results showed that no
contaminant levels exceeded the NJDEP Soil Cleanup Objectives.
Ground water samples were collected from the 19 monitoring wells
installed during the RI. These monitoring wells were screened at
three distinct depths - shallow, intermediate and deep. With two
exceptions, sample results from all monitoring wells were within
drinking water standards. Follow up samples collected in May
1990 confirmed the presence of benzene in monitoring well MW-l,
which is located northwest of the subdivision.
Ground water samples were collected from the residential wells in
Pinehurst in the winter of 1988 and again in August 1989. The
results showed some compounds at levels slightly above Maximum
Contaminant Levels (MCLs). MCLs are standards for drinking water
based on a consumption of two liters per day over a 70 year
period. Contaminant levels above MCLs might increase the risk of
a person's health being adversely affected.
-------
Upon review of the analytical results of the RI, the Agency for
Toxic Substances and Disease Registry (ATSDR) concluded, "... the
levels of VOCs [volatile organic compounds] in the water samples
do not pose a public health threat either from the ingestion of
the water or from the inhalation of VOCs that may escape from the
water during typical domestic uses in the home. While marginally
elevated levels of lead and mercury were detected in a limited
number of samples, no immediate health threat is apparent."
ATSDR goes on to recommend "continue to monitor well water for
the presence of organic and inorganic chemical contamination...".
Also, the ACHD has been notified of these results and they have
been in contact with the five residences that had contaminant
levels above the MCLs.
In a separate effort, the ACHD has identified twenty residences
in the Pinehurst area that have contaminants over MCLs. The
major contaminants are trichloroethene, tetrachloroethene and
mercury. The area where the contamination was found includes
Zenia Avenue on the north, Poplar Avenue on the south, White
Horse Pike on the west and Jimmie Leeds Road on the east.
Although some of these contaminants were also found in the Pomona
Oaks subdivision in 1982 and 1983, it is believed that the
chemicals now present in Pinehurst are not related to the
contamination at the site. Ground water velocity flow rates
calculated during the RI show that the contamination at the site
could not have travelled into the Pinehurst area in the last
eight years. Secondly, benzene and total xylenes, among other
contaminants, are absent in the Pinehurst area and were major
constituents of the Pomona Oaks subdivision contamination.
Trichloroethene and tetrachloroethene, the major components of
the Pinehurst problem, were found at very low levels (25 ppb) in
the Pomona Oaks subdivision. The contamination present in the
Pinehurst area is probably related to residential septic systems,
now in the process of being replaced by a sewer system.
Additionally, the RI findings indicate that contaminant
concentrations at the Pomona Oaks site are low enough to conclude
that there will be no adverse impact on the environment. There
are no endangered or threatened species in the immediate area.
C. EPA's Preferred Alternative - No Further Action
EPA, in conjunction with NJDEP have determined that "No Action"
is appropriate for the Pomona Oaks subdivision.
Data obtained during the RI has shown that the ground water
contamination in the Pomona Oaks subdivision no longer exists
above health risk or drinking water standard levels. It has also
been concluded that the source of the contamination was a
singular event or events and that the resultant ground water
contamination has dispersed over time through natural attenuation
and/or biodegradation.
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The Comprehensive Environmental Response, Compensation and
Liability Act of 1980 (CERCLA), as amended by the Superfund
Reauthorization Act of 1986 (SARA), states that remedial actions
selected under this program should assure protection of human
health and the environment. Additionally, such remedial actions
should be relevant and appropriate to the circumstances present.
Since there is no current source of contamination in the Pomona
Oaks subdivision, source control is not necessary. Likewise,
since the original ground water contamination in the Pomona Oaks
subdivision no longer exists above standards, there is no need to
develop and evaluate ground water remediation alternatives.
However, EPA and NJDEP are proposing that further study be
undertaken for the ground water contamination in the Pinehurst
area to determine the nature and extent of the contamination, and
its source.
The preference for this "No Action" alternative for the site is
based on the following facts:
-the immediate threat to the residents of the Pomona Oaks
subdivision was removed by the alternate water supply in 1985;
-the RI shows that the high concentrations of chemicals that were
present during the 1982 to 1985 period have significantly
decreased to below drinking water standards in 1989 suggesting
dispersion of contaminants over time;
-the contamination is not currently present in the Pomona Oaks
subdivision and therefore did not come from a continuous source,
but most likely a discrete event;
-most of the compounds found were at levels below relevant and
appropriate federal and/or state standards;
-the Baseline Risk Assessment showed that the chemicals of
concern present at the site do not pose a significant health
threat;
-the Baseline Risk Assessment illustrates that the probability of
ecological impacts is negligible; and
-the source of contamination in the Pinehurst area, downgradient
of the Pomona Oaks subdivision, is presently undetermined. The
State of New Jersey is currently working with Galloway Township
and the ACHD to provide alternate water to the affected residents
in Pinehurst.
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II. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERN
Community interest and involvement at the site has varied since
1982. Community concern was initiated when several new wells
were installed in 1982 and discussions among residents revealed a
common concern - foul smelling water. This led to the formation
of an informal neighborhood association to bring this issue to
the attention of local officials. Testing conducted at that time
by the ACHD revealed the presence of volatile organic compounds.
Community concern was increased further when, in late 1982 and
early 1983, a health survey was conducted by the New Jersey
Department of Health for the residents on a voluntary basis.
Although the results of these tests were inconclusive, the ACHD
recommended that residents discontinue use of residential wells
as a source for drinking, cooking, showering and other personal
purposes. The ACHD began providing water to the residents whose
residential wells were affected. Some residents chose instead to
utilize filtration units sponsored by Galloway Township.
From 1982 to 1985, discussions were conducted among township
officials, NJDEP, EPA, representatives from the New Jersey Spill
Compensation Fund, and the New Jersey American Water Company to
install public water lines to provide water to the residents.
Community interest remained at a moderate level through these
discussions because residents felt that the cost of this project
should not be their responsibility. In March 1985, EPA began
providing bottled water to the residents whose wells exceeded
drinking water standards. This delivery of bottled water lasted
until the entire development was connected to the Absecon water
supply.
In 1988, when EPA began its remedial investigation, community
concern was generally low. Residents did express frustration
with regard to the quality and quantity of information provided
to them by the involved government agencies. Residents' concerns
regarding the health effects of past exposure to contamination at
the site were significant. The residents also viewed the
contamination problem as one that hurt the community image and
devalued properties. Residents exhibited pride when discussing
the expected growth of the area because of the expanding
commercial base and were hopeful that any remediation effort in
the community would minimally affect its image.
Throughout the RI, and at the recent public meeting to present
the Proposed Plan, residents have continued to express
dissatisfaction with the resolution of financial responsibility
for all that has ensued. Residents are pursuing legal action
against a perceived potentially responsible party. Residents
remain worried about the potential long-term health effects from
exposure to site contaminants and are interested in long-term
health monitoring.
-------
III. SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED DURING THE
PUBLIC COMMENT PERIOD AND EPA RESPONSES TO THESE COMMENTS.
Comments raised during the public comment period for the site and
the EPA responses are summarized in the following section.
Comments received during the public comment period are organized
into six categories: Remedial Investigation, Health and Safety,
Drinking Water Standards, Public Water Supply, Superfund Process
and Other Issues.
A. Remedial Investigation
Comment:
A member of the local citizens group concerned about the site
asked what had happened to the contaminants at the site.
Specifically, since the concentrations of contaminants were
higher in 1982 than they are now, what had happened to them?
EPA Response:
Several of the contaminants found at the Pomona Oaks subdivision
volatilize very rapidly. EPA believes that the reduction in
concentrations of contaminants indicated by analyses in 1982 and
1988 is the result of volatilization and biodegradation.
Comment:
A resident asked why some samples had been rejected and whether
this problem affected the Proposed Plan.
EPA Response:
On certain ground water samples collected, the laboratory
provided by the EPA Contract Lab Program, exceeded the holding
time for the samples. That is, they were not analyzed by the lab
in the amount of time allowed by the EPA after the sampling
event. This data could not be used in developing EPA's Proposed
Plan. EPA is certain that the decisions made in preparation of
the Proposed Plan were not compromised by the rejected results.
B. Health and Safety
Comment:
A Galloway Township councilman and a resident asked if long-term
health monitoring could be conducted.
Agency for Toxic Substances and Disease Registry/EPA Response:
Any acute affects from this site would have been experienced by
residents long ago. Since residents have been connected to a
-------
public water system for several years, the only concern at this
time should be long-term affects with cancer being the primary
concern. In a small population, such as that of the Pomona Oaks
subdivision, it is difficult to conduct a health study that will
demonstrate increased incidences of cancer for many reasons.
These factors include: size of the population, transient nature
of the population, length of time for chronic affects to develop
and difficulties in utilizing physician's records. There are
sources of information that interested parties might utilize
regarding long-term health monitoring. The ACHD might be able to
provide some information. Additionally, the New Jersey State
Department of Health maintains a database called a cancer
registry to determine if areas in the state have an unusually
high rate of cancer compared to the general population. Anyone
interested should consult these sources.
Comment:
A Galloway Township councilman and a member of the local citizens
group concerned about the site asked if EPA knew how long the
residents in the Pomona Oaks subdivision had been exposed to the
contaminants.
EPA Response:
EPA has been unable to determine how long the residents have been
exposed to contaminants because of the lack of information
regarding testing of wells in the Pomona Oaks subdivision prior
to 1982.
C. Drinking Water Standards
Comment:
A member of the local citizens group concerned about the site
asked if current EPA and New Jersey drinking water standards are
the same. He indicated that in 1982 they were not.
EPA Response:
Current Federal and State drinking water standards have been
developed utilizing many different health and water quality
studies. Since 1982, the drinking water standards of the EPA and
the State of New Jersey have become more stringent and now
conform more closely. However, they are not identical for all
compounds. In development of the risk assessment and Proposed
Plan for the site, when Federal and State standards were not
identical, the more stringent standard was used.
8
-------
Comment:
A member of the local citizens group concerned about the site
asked what was EPA's drinking water standard for benzene.
EPA Response:
The federal drinking water standard for benzene was identified as
five parts per billion (5 ppb).
D. Public Water Supply
Comment:
A Galloway Township councilman indicated that he believed that
the New Jersey American Water Company was improperly charging
customers who utilized the water supply lines provided by EPA.
He stated that the rate included a cost of capitalization for the
lines which the New Jersey American Water Company did not pay.
He requested that this information be turned over to the Board of
Public Utilities (BPU) for investigation.
EPA Response:
The Board of Public Utilities is a regulatory authority with
jurisdiction over public water supply company service and other
utilities. EPA suggests that the Galloway Township councilman
solicit the support of the Galloway Township council and present
this matter to the BPU.
Comment:
A former Mayor of Galloway Township asked about the possibility
of the new municipal well, operated by the New Jersey American
Water Company, changing the pattern of migration of any
contaminants remaining. He also asked how this would be
monitored.
EPA Response:
It is possible that an increase or change in the usage of the
aquifer may cause current ground water flow conditions to change.
Since the original ground water contamination in the Pomona Oaks
subdivision no longer exists above standards, there should not be
a problem with migration of contaminants. However, the New
Jersey American Water Company and the NJDEP as the regulatory
agency, will be responsible for monitoring the quality of water
pumped from that well.
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E. superfund Process
Comment:
A member of the local citizens group concerned about the site
asked about the process for sending in written comments and their
incorporation in the decision-making process.
EPA Response:
The Proposed Plan outlines EPA's and NJDEP's preferred
alternative for remediation of the site. However, a decision
would not be made until all comments received during the public
comment period have been considered. Written and verbal comments
on this Proposed Plan were welcome through August 31, 1990 and
would be documented in the Responsiveness Summary section of the
Record of Decision.
Notice of the final decision would be made available to the
public at the information repositories for the site and through a
press release. The final decision would be accompanied by an
explanation of any significant changes from the Proposed Plan.
EPA and NJDEP rely on public input to ensure that the remedy
selected for each Superfund site is fully understood and that the
agencies have considered the concerns of the local community, as
well as ensuring that the selected remedy provides an effective
solution.
Comment:
A former Mayor of Galloway Township feels that the processes and
programs (i.e., the Superfund studies, the New Jersey Spill
Compensation Fund, etc.) utilized to remediate the site move too
slowly and feel somewhat like a roller coaster ride for the local
citizens. He wondered what the community and the appropriate
government agencies could do to expedite these processes and
provide better mechanisms for community involvement.
EPA Response:
EPA is continuously trying to improve the Superfund program. In
1989, the EPA issued a report on the program entitled, A.
Management Review of the Superfund Program (also known as the
"90-Day Study"). Among other things, this report has identified
areas for improvement to the program. Currently, recommendations
for improvement to smooth, streamline and shorten the Superfund
process are being implemented. One Superfund program, called the
Technical Assistance Grant Program (TAG), is designed to provide
funds to citizens groups who are affected by Superfund sites for
the purpose of retaining technical experts of their own. These
experts can independently evaluate and explain technical reports
to citizens.
10
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F. Other Issues
Comment:
A Galloway Township councilman asked if the contamination at the
Federal Aviation Administration (FAA) facility was related to the
contamination of the Pomona Oaks subdivision. She indicated that
the ground water flow observed at the Pomona Oaks subdivision, if
extrapolated towards the FAA facility, would indicate that ground
water would flow from the FAA facility towards the Pomona Oaks
subdivision. She also indicated that there was little
communication about the FAA site activities to the community.
EPA Response:
The Superfund program is currently conducting remedial
activities at the FAA facility. The types of contamination found
there are unlike those at the Pomona Oaks subdivision and EPA
sees no relationship between the two sites. The Superfund
program is required to provide information on site activities to
the public at strategic points during the remedial process.
Comment:
A former Mayor and several councilmen of Galloway Township, as
well as several residents, urged EPA to remain involved in the
Pinehurst contamination problem.
EPA Response:
NJDEP is the lead agency for the Pinehurst contamination problem.
EPA will continue to sample monitoring wells in the Pomona Oaks
subdivision and will provide technical and other support to NJDEP
in its investigation of Pinehurst.
Comment:
A former Mayor of Galloway Township wanted to know what the
mechanism for recalling EPA's assistance was, if through testing
done by EPA, other agencies, or the community indicated that the
contamination had returned.
EPA Response:
EPA will continue to monitor the site as stated in the Proposed
Plan. EPA does not anticipate that contamination will "return"
to the site. However, should EPA discover through its monitoring
efforts, or be presented with evidence that suggests that
contamination levels increase, EPA could investigate further
through the Superfund mechanism.
11
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Comment:
A member of the local citizens group concerned about the site
asked that if contamination levels had decreased, would the ban
on well drilling in the area be lifted.
EPA Response:
The NJDEP has juristiction over well restriction areas. EPA has
provided the NJDEP with copies of the RI report and any other
appropriate data.
IV. REMAINING CONCERNS
The primary area of concern which should be considered is the
perception that EPA's "No Action" alternative means that EPA will
no longer be involved as the area ground water contamination
problems are investigated. Additionally, the continued
investigation of the Pinehurst contamination problem will keep
alive many of the issues (i.e., health and safety, public water
supply, drinking water standards) that have concerned residents
of the Pomona Oaks subdivision.
Even more, many individuals repeatedly suggested and requested
that EPA remain involved in the resolution of the ground water
contamination problems in the area, including Pinehurst and
Pomona Oaks. The careful maintenance of communication lines
between EPA NJDEP, ACHD, residents and local officials will
alleviate the fears that EPA is no longer concerned with the area
ground water problem and the resolution of the related issues.
12
-------
APPENDIX A
-------
Proposed Plan (Revised Edition)
EPA
Region 2
Pomona Oaks Well
Contamination Site
Galloway Township, New Jersey
July 1990
INTRODUCTION
The Pomona Oaks Well Contamination site
includes the Pomona Oaks residential subdivision
(nearly 200 homes) and an adjacent shopping
center in Galloway Township, Atlantic County,
New Jersey. Atlantic City is located ten miles to
the southeast The study area is bordered on the
south by White Horse Pike (U.S. Route 30), on
the east by Willow Ave., on the north by Jimmie
Leeds Road, and on the west by Pomona-Port
Republic Road. The actual subdivision boundaries
go as far as Donna Drive on the eastern side (see
Figure 1).
The remedial activities for this site were conducted
as a joint effort by the U.S. Environmental
Protection Agency (EPA) and the New Jersey
Department of Environmental Protection
(NJDEP). In this instance, EPA is the lead
agency. This Proposed Plan is being distributed in
accordance with Section 117(a) of the
Comprehensive Environmental Response,
Compensation, and Liability Act of 1980, as
amended by the Superfund Amendments and
Reauthorization Act of 1986.
PURPOSE OF THE PROPOSED
PLAN :&:;••-•
*••-" '"•-.'• • ' •
The function of flris Proposed Plan is to identify
the preferred alternative at the Pomona Oaks site,
explain the reasons for the choice, and to solicit
public comment This document was developed by
EPA, in conjunction with NJDEP, and is based
primarily on the information gathered during the
Remedial Investigation. Copies of the Remedial
Investigation report will be made available at the
four information repositories in the Pomona Oaks
area. These are the Stockton State College
Library, the Galloway Township Municipal
Building on Jimmie Leeds Road, the Atlantic
County Public Library in Galloway Township, and
the Pomona School on Genoa Avenue.
COMMUNITY ROLE IN THE
REMEDY SELECTION PROCESS
EPA and NJDEP rely on public input to ensure
that the remedy selected for each Superfund site is
fully understood and that the agencies have
considered the concerns of the local community, as
well as ensuring that the selected remedy provides
an effective solution.
This Proposed Plan and the Remedial
Investigation (RI) report are being made available
to the public during the public comment period.
Written comments on the Proposed Plan or the RI
report will be welcomed through August 31,1990,
and if received by this date, will be considered in
the Record of Decision (ROD) which will formally
document the selected remedy. All written
comments should be addressed to:
Matthew Westgate
Project Manager
U.S. Environmental Protection Agency • Region II
26 Federal Plaza, Room 711
New York, New York 10278
The final remedy selection will be documented in
the ROD only after consideration of all comments
on the remedial alternative addressed in the
Proposed Plan and RI report. A public meeting is
scheduled for July 31,1990 at the Galloway
Township Municipal Building on Jimmie Leeds
Road to present the findings of the RI report and
the Proposed Plan.
-------
"••I*" 7-"*". •> •*•*"•»'• "V.'T." *
SITE BACKGROUND
The Pomona Oaks subdivision is a residential
neighborhood containing single family homes built
in the 1970s. It is surrounded by undeveloped
wooded areas, scattered residences and small
•strip* type shopping areas. Some of the outlying
areas are farms. A gas station is located on the
southwestern boundary of the Pomona Oaks
subdivision. A Globe gas station and a gas
station/salvage yard are also located to the west
and northwest, respectively. The Pomona Plaza
Shopping Center, which includes a dry cleaner, is
located to the southwest.
Initially, residences within the subdivision relied
on individual septic systems for waste water
disposal and on private wells for their source of
potable water. In 1982, all of the homes in the
subdivision were connected to the public sewer
system. The residential potable wells were
screened in the Cohansey Formation, an
unconfined aquifer that extends from the surface
to approximately 200 feet The Cohansey is
mainly sand with interbedded clay and gravel
lenses.
In June 1982, several residents on Terry Lane
notified the Atlantic County Health Department
of foul tasting well water. Subsequent sampling of
residential wells in the subdivision by the EPA, the
NJDEP and the Atlantic County Health
Department through 1985 revealed twenty volatile
organic compounds. These can be classified into
two groups. The first group includes volatile
aromatic compounds, which are lighter than water
(i.e. benzene, toluene, xylene and ethylbenzene)
and are often associated with petroleum products.
The second group consists of chlorinated
hydrocarbons, usually heavier than water (i.e.
1,1,1-trichloroethane, dichlorobenzene and 1,1-
dichloroethane). These compounds were
frequently used as solvents. Some of the
compounds detected, the highest reported levels,
and the maximum contaminant levels (MCL) for
drinking water are presented on the following
page:
FIGURE 1
POMONA OAKS SITE
POMONA OAKS
SUBDIVISION
REM III
POMONA OAKS SITE
SITE STUDY AREA
-------
POMONA OAKS
SUBDIVISION
SALVAGE YARD /GAS
STATION
POMONA PLAZA
4 RESIDENTIAL WELL
PIEZOMETER
LOCATION
MONITOR WELL
LOCATION
SCALE
NO SCALE
DATE
MAY 1989
REM III
POMONA OAKS SITE
RESIDENTIAL WELL SAMPLE LOCATIONS
r C. JOHNSON ft MALHOTRA.P.C.
-------
VOLATILE ORGANIC COMPOUNDS
DETECTED IN POMONA OAKS SUBDIVISION
WELLS 1982-1985
(all levels in parts per billion)
(MCLs are 1982 - 1985 standards)
Compound
Benzene
Chlorobenzene
Dichlorobenzene
Chloroform
1,2-Dichloroethane
1,1-Dichloroethane
Highest
Reported
Level
2060
58
76
31
880
60
1,1-Dichloroethylene 4.3
trans- 1,2-dichloroethylene 9.3
1,1,1-Trichloroethane 170
1,1,2-Trichloroethane
Trichloroethylene
Tetrachloroethylene
Total Xylenes
46
25
25
204
Maximum
Contaminant
Level
1.0
50
6.0
.-
2.0
«
2.0
5.0
«
1.0
5.0
44
Maximum contaminant levels are standards for
drinking water based on consumption of two liters
per day over a seventy year period. Contaminant
concentrations above the MCLs might increase the
chances of a person's health being adversely
affected. As a result of these findings, residents
were advised by the Atlantic County Health
Department not to use the water for drinking or
cooking. In June 1984, NJDEP requested
assistance from EPA to mitigate the impact of the
groundwater contamination. By August 1985, after
a number of different sampling events, all 193
homes in the Pomona Oaks subdivision were
connected to the municipal water supply of the
neighboring community of Absecon by the NJDEP
using Spill Fund monies. Between November 1985
and January 1986, the existing private wells were
sealed by the NJDEP using Spill Fund monies.
The alternate supply of water removed the
immediate health risk to the residents. However,
there are a number of homes to the southeast of
the subdivision that continue to rely on private
residential wells for their potable water supply.
REMEDIAL INVESTIGATION
SUMMARY
The Pomona Oaks site was proposed for the
National Priorities List (NPL) on 10/01/84 and
finalized on 6/01/86. In 1988, EPA initiated a
remedial investigation (RI) to determine the
nature, extent and source of the contamination,
and to sample the residential wells downgradient
of the subdivision to determine if they were
contaminated. The RI field work, conducted from
October 1988 to March 1989, included a soil gas
survey, subsurface soil sampling, sediment
sampling, monitoring well and piezometer
installation, one round of sampling from the
monitoring wells, two rounds of residential well
sampling, aquifer slug testing, and gamma logging
of wells. Findings of the RI include:
1) A soil gas survey, which is a screening
technique used to determine volatile
organic contamination present in the
upper layers of soil, was used to help
locate monitoring wells. The results
showed the presence of some volatile
aromatic compounds (often associated
with petroleum products) in two areas.
The first area, located on the northwest
end of Father Keis Drive, had a maximum
level of 523 micrograms per liter (ug/1) of
total volatile organics. The second area,
around Pomona Plaza and Cumberland
Farms, had a maximum total volatile
organics level of 55.8 ug/L
2) Soil samples were collected from the deep
wells at eight monitoring well locations.
No contaminants were found at levels that
exceeded the NJDEP Soil Cleanup
Objectives.
3) Groundwater samples were collected from
the 19 monitoring wells installed during
the RI. The monitoring wells were
screened at three distinct depths - shallow,
intermediate and deep. The locations of
these wells are illustrated on Figure 1.
With two exceptions, sample results from
all monitoring wells were within drinking
water standards. Benzene was found at 8
pans per billion (ppb) in monitoring well
1 (shallow, 20-30 feet), immediately
adjacent to the salvage yard. This is above
the Maximum Contaminant Level (MCL)
of 1.0 ppb for benzene. In monitoring
well 6 (intermediate, 88-98 feet), 1,2-
dichloroethane was found at 6.8 ppb. This
level is above the MCL of 2.0 ppb for this
compound. Trichloroethene was found at
a level of 1.1 ppb, which is slightly above
the MCL of 1.0 ppb for this compound.
Follow up samples collected on May 2,
1990 confirmed the presence of benzene in
the shallow monitoring well at location
-------
MW-1. Confinnatory samples horn the
three wells at location MW-6, shallow,
intermediate and deep showed no
compounds present at levels above MCLs.
4) Twenty groundwater samples were
collected from the residential wells in the
winter of 1988 and again in August 1989.
These wells are located in the Pinehurst
area, which is to the southeast and
downgradient from the Pomona Oaks sub-
division. Some chemicals detected in this
sampling effort appeared to exceed MCLs.
However, the chemical data was rejected
when it failed a detailed quality assurance/
quality control review. Another round of
samples was collected in August 1989 by
EPA's Environmental Response Team.
The results showed some compounds at
levels slightly above Maximum
Contaminant Levels. They are presented
below:
EPA's ENVIRONMENTAL RESPONSE TEAM
RESIDENTIAL WELL SAMPLING RESULTS
AUGUST 1989
(all levels in parts per billion)
Compound
Trichloroethene
Tetrachloroethene
Mercury
Maximum
Level
Reported
3.1
1.7
3.8
Maximum
Contaminant
Level
1.0
1.0
2.0
The five residents that showed these levels of
contamination were resampled on May 2,1990
along with the monitoring wells mentioned previ-
ously. Two of the five again showed levels of
mercury above the MCLs. The values were 3.9
and 4.0 ppb. The MCL for mercury is 2.0 ppb.
One of these wefe also had Trichloroethene at
levels above the MCLs. (3.8 ppb as compared with
the standard of ifrppb). In the other three wells
contaminant levels were less than MCLs or
completely absent
Upon review of the analytical results, the Agency
for Toxic Substances and Disease Registry
(ATSDR) stated,"... the ATSDR concludes that
the levels of VOCs in the water samples do not
pose a public health threat either from the
ingestion of the water or from the inhalation of
VOCs that may escape from the water during
typical domestic uses in the home. While
marginally elevated levels of lead and mercury
were detected in a limited number of samples, no
immediate health threat is apparent." ATSDR
goes on to recommend "Continue to monitor well
water for the presence of organic and inorganic
chemical contamination...". Also, the Atlantic
County Health Department has been notified of
these results and they have been in contact with
the five residences that had contaminant levels
above the MCLs.
In a separate effort, the Atlantic County Health
Department has identified eleven residences in the
Pinehurst area that have contaminants over MCLs.
The major contaminants are trichloroethene,
tetrachloroethene and mercury. The area where
the contamination was found includes Zenia Ave.
on the north, Poplar Ave. on the south, White
Horse Pike on the west and Jimmie Leeds Road
on the east Although some of these contaminants
were also found in the Pomona Oaks subdivision
in 1982 and 1983, it is believed that the chemicals
now present in Pinehurst are not related to the
Pomona Oaks site contamination. Groundwater
velocity flow rates calculated during the Remedial
Investigation show that the Pomona Oaks
contaminants could not have travelled that far into
the Pinehurst area in the last eight years.
Secondly, benzene and total xvlenes, among other
contaminants, are absent in the Pinehurst area and
were major constituents of the Pomona Oaks
subdivision contamination. Trichloroethene and
tetrachloroethene, the major components of the
Pinehurst problem, were found at very low levels
(25 ppb) in the Pomona Oaks subdivision. The
contamination present in the Pinehurst area is
probably related to residential septic systems, now
in the process of being replaced by a sewer system.
SUMMARY OF SITE RISKS
During the Remedial Investigation, an analysis was
conducted to estimate the health or environmental
problems that could result if the contamination
remained at current levels. This analysis is
commonly referred to as a Baseline Risk
Assessment. In conducting this assessment, the
focus was on the health effects that could result
from direct contact with the groundwater.
Groundwater is the principal source of potential
exposure to those residents still dependant upon
private wells for their water needs.
The possibility of exposure through dermal contact
with and/or inhalation or ingestion of soil is very
low. Exposure due to volatilization or volatile
-------
orpnic compounds (VOGs) present in the
groondwater is a possibility at the Pomona Oaks
site. When the water is pumped to the surface
and used, VOCs could volatilize during
dishwashing, while showering, and when watering
lawns and gardens. However, because of the
extremely low concentrations of the VOCs in the
groundwater, this route of exposure was
determined not to be a problem.
Analytical data has shown the presence of volatile
organic and inorganics in the shallow Cohansey
Aquifer downgradient of the Pomona Oaks
subdivision and volatiles in monitoring wells 1 and
6. VOCs were present in the groundwater at very
low concentrations, usually less than 5 ppb. This
may be due to the depletion of contaminants over
time brought about by degradation and/or
volatilization into the air.
All chemicals detected in the groundwater, organic
and inorganic were subjected to a screening
process as pan of the Risk Assessment. This
screening process is used to identify the 'highest
risk* chemicals at the site, which are referred to as
chemicals of concern. Those selected were
chloroform, benzene, trichloroethene, 2-butanone,
1,1,1-trichloroethane, toluene, tetrachloroethene,
1,1-dicbloroethane and barium.
EPA's Carcinogenic Assessment Group (CAG) has
developed cancer potency factors for estimating
excess lifetime cancer risks associated with various
levels of lifetime exposure to potential human
carcinogens. An excess lifetime cancer risk of 1 x
10"6, for example, represents the probability of one
in a million that an individual will develop cancer
as a result of exposure to a carcinogenic chemical
over a 70 year lifetime under specified exposure
conditions. EPA's guidelines state that the total
incremental carcinogenic risk for an individual
resulting from exposure at a hazardous waste site
should be between 10'7 (one additional cancer in
10,000,000 people) and 10"4 (one additional cancer
in 10,000 people). Any numbers above the target
range, or greater than 10~*, are unacceptable and
will trigger some kind of remedial action. Excess
lifetime cancer risk numbers for Pomona Oaks are
printed in Table 1. The numbers for the five
chemicals of concern that could cause cancer are
within EPA's target range.
TABLE 1
CHEMICAL
dilerefeni
TricMoro-
ethene
1,1,1-Tridi-
lore* than*
2 -tut •nor*
tenzene
Toluene
1.1-OicMero-
etfunt
Tetrad) lore-
ethcnc
Mr It*
CONCENTRATION
(UC/L)
MAXIMUM
6.9
3.1
2.7
0.9
a
0.2
2.4
1.7
890
EXPOSURE
3.52
0.54
2.4
^ 1.15
2.K
2.36
2.16
2.09
164.93
CMKMIC DAILY
INTAKE
(NG/KG/OAT)
CARCINO-
GENIC
4.29 E-05
6.56 £-06
••
••
2.7 E-05
•-
2.65 I -OS
2.54 E-05
•-
NONCARCI-
MGCIIC
1.02 E-04
••
6.96 E-OS
1.49 E-04
. ..
6.64 E-05
6.32 E-OS
6.06 E-OS
$.36 E-03
SUUNRON1C
DAILY
imn
(H6/K6/DAY)
NONCARC1-
NOGEN1C
2.39 E-04
1.63 E-04
3.S E-04
••
1.6 E-04
1.48 E-04
1.42 E-03
1.25 E-02
CANCER
POTENCY
FACTO*
(NC/K/OAY)
6.1 E-03
1.1 E-02
-•
2.9 E-02
•-
9.1 E-02
S.I E-02
--
REFERENCE
OOSC
(NG/U/OAY)
CHROMIC
1.0 E-02
* *
9.0 E-02
5.0 E-02
•-
3.0 1-01
t.O E-01
1.0 E-02
5.0 E-02
•JKMRONIC
1.0 E-02
"*
9.0 E -01
S.O E-01
••
4.0 E-01
1.0
1.0 E-01
S.O E-02
TOTAL
EXCESS
LIFETIME
CANCER
USX
2.62 E-07
7.26 E-08
•*
••
7.83 E-07
--
2.14 E-06
1.29 E-06
•-
1.08 E-06
HAZARD
INDEX
(CNKMIC)
1.0 E-02
* "
7.43 E-04
2.98 E-03
••
2.28 E-04
6.32 E-04
6.06 E-03
0.107
0.12
HAZARD
INDEX
-------
For those chemicals exhibiting non-carcinogenic
effects, health criteria numbers are based on EPA
Reference doses (RfD). In general, the reference
dose is an estimate of an average daily exposure to
an individual below which there will not be an
appreciable risk of adverse health effects. Doses
that are significantly higher than the RfD may
indicate that an inadequate margin of safety could
exist for exposure to that substance and that an
adverse health effect could occur. From this data,
a Hazard Index number is generated. If this
number is less than or equal to one, no adverse
effects are anticipated from the exposure and dose
level. If the number is greater than one, the
exposure and 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. Hazard Indexes for the
Pomona Oaks residents were calculated and are
printed on Table 1. The hazard indexes for non-
carcinogens are below one.
ENVIRONMENTAL ASSESSMENT
The residential concentrations at the Pomona
Oaks site are low enough to conclude that there
will be no adverse impact on the environment.
There are no endangered or threatened species in
the immediate area.
DISCUSSION OF NO FURTHER
ACTION ALTERNATIVE
Section 121(d), Degree of cleanup (1), under
CERCLA and SARA, states 'Remedial actions
selected under this section or otherwise required
or agreed to by the President under this Act shall
attain a degree of cleanup of hazardous substances,
pollutants, and contaminants released into the
environment and of control of further release at a
minimum which assures protection of human
health and the environment. Such remedial
actions shall be tefevant and appropriate under the
circumstances presented by the release or
threatened release of such substance, pollutant or
contaminant". . •
Data obtained during the remedial investigation
has shown that the ground water contamination in
the Pomona Oaks subdivision no longer exists
above health risk or drinking water standard levels.
It has been concluded that the source of the
contamination was a singular event or events and
that the resultant ground water contamination had
dispersed over time through natural attenuation
and/or biodegradation.
Since there is no current source of contamination
in the Pomona Oaks subdivision, source control is
not necessary. Likewise, since the original ground
water contamination in the Pomona Oaks
subdivision no longer exists above standards, there
is no need to develop and evaluate ground water
remediation alternatives. Therefore, EPA, in
conjunction with NJDEP have decided that "No
Action" is appropriate for the Pomona Oaks
subdivision.
However, EPA and NJDEP, are proposing that
further study be undertaken for the ground water
contamination in the Pinehurst area to determine:
the nature and extent of the contamination, the
potential link between the Pomona Oaks site and
the contamination at Pinehurst, and any other
potential sources of that contamination.
This proposed decision is based on the following
facts:
the immediate threat to the
residents of the Pomona Oaks
subdivision was removed by the
alternate water supply in 1985;
the remedial investigation shows
that the high concentrations of
chemicals that were present
during the 1982 to 1985 period
have significantly decreased to
below drinking water standards in
1989 suggesting dispersion of
contaminants over time;
the contamination is not currently
present in the Pomona Oaks
subdivision and therefore did not
come from a continuous source,
but most likely a discrete event;
most of the compounds found
were at levels below relevant and
appropriate federal and/or state
standards;
the Baseline Risk Assessment
showed that the chemicals of
concern present at the Pomona
Oaks site do not pose a significant
health threat;
the Baseline Risk Assessment
illustrates the fact that the
probability of ecological impacts
-------
was estimated to be negligible; and
the source of contamination in the
Pinehurst area, downgradient of the
Pomona Oaks subdivision, is presently
undetermined. The State of New Jersey is
currently working with Galloway Township
and the Atlantic County Health
Department to provide alternate water to
the affected residents in Pinehurst
COMMUNITY ROLE IN THE
SELECTION PROCESS
EPA and NJDEP solicit and incorporate public
input as pan of the decision making process for
Superfund hazardous waste sites. The Proposed
Plan and other documents have been placed, and
are available at the following repositories:
Pomona School
Genoa Avenue
Pomona, New Jersey 08240
Stockton State College Library
Jimmie Leeds Road
Pomona, New Jersey 08240
Atlantic County Public Library
Galloway Township Branch
30 W. Jimmie Leeds Road
Pomona, New Jersey 08240
Galloway Township Municipal Building
300 East Jimmie Leeds Road
Absecon, New Jersey 08201
Although the Proposed Plan is the one presented
by the EPA and NJDEP, a decision will be made
only after consideration of all comments received
during the 30 day public comment period. Written
and verbal comments on this Proposed Plan will
be welcome through August 31,1990 and will be
documented in the Responsiveness Summary
section of the Record of Decision.
Notice of the final decision will be made available
to the public at the repositories listed above. The
final decision will be accompanied by an
explanation of any significant changes from the
Proposed Plan.
Glossary
* Aquifer: An underground rock or soil
foundation that is capable of supplying water to
wefts and springs,
• Ground Water Water that fills spaces
between sand, soil rock and gravel particles
beneath surface of the earth. Rain water that
does not evaporate or drain to surface water
such as streams, rivers, ponds, or takes, but
slowly seeps into the ground, forming a ground
water reservoir. Groundwater flows
considerably more stowty than surface water,
often along routes that lead to streams, rivers
ponds, lakes and springs.
• National Priorities List (NPL): A raster of
uncontrolled hazardous waste sites nationwide
that pose an actual or potential threat to human
health or the environment, and are eligible for
investigation and cleanup under the federal
Superfund program.
• Proposed Plan: A document that describes
aQ the remedial alternatives considered by U.S.
EPA for addressing contamination at a
Superfund site, including the preferred U.S.
EPA alternative.
• Remedial Action: A series of steps taken to
monitor, control, reduce or eliminate risks to
human health or the environment. These risks
were caused by the release or threatened release
of contaminants form a Superfund Site.
• Remedial Investigation (RI): A Remedial
Investigation Involves collecting and analyzing
technical and background information regarding
a Superfund site to determine the nature and
extent of contamination that may be present
The investigation also determines how
conditions at the site may afiect human health
e cnvirouuieiiLi
• Responsiveaeaa Summary: A Section within
the Record of Decision that present* US.
EPA's responses to public comments on the
Proposed Plan and RI/FS.
• Saperftud: The common name for the
federal program established by the
Comprehensive Environmental Response and,
Liability Act (CERCLA) of I960, as amended in
1986.: The Superfund tow authorizes U.S. EPA
to investigate and cleanup the nation's most
serious hazardous waste sites.
-------
United States Region 2
Environmental Protection Agency 26 Federal Plaza
New York, NY 10278
Official Busineu
Penalty for Private Use
$300
-------
APPENDIX B
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION II
PUBLIC INFORMATION MEETING
FOR
ATTENDEES
(Please Print)
MAILING
NAME STREET CITY ZIP PHONE REPRESENTING LIST
UL£P«
U^ ft.
v?i
Pf-
MOO y
-------
APPENDIX C
-------
TEE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
INVITES
PUBLIC COMMENT ON THE
PROPOSED CLEANUP ALTERNATIVE
FOR THE POMONA OAKS WELL CONTAMINATION SITE
GALLOWAY TOWNSHIP, NEW JERSEY
The U.S. Environmental Protection Agency (EPA) and the New Jersey Department
of Environmental Protection (NJDEP) invite public comment on the Remedial
Investigation Report (RI) and Proposed Plan for the Pomona Oaks Well
Contamination Sit*. As a part of its public participation responsibilities
under section 117(a) of the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), EPA and NJDEP have issued a Proposed
Plan available for public comment. The Proposed Plan which presents EPA's and
NJDEP's preferred remedial alternative for the sit* is available for review at
the locations listed below.
The EPA and the NJDEP are pleased to announce that data obtained during the
remedial investigation indicates that the ground water contamination in the
Pomona Oaks subdivision no longer exists above health risk or drinking water
standard levels and that the site poses no current or potential threat to
human health and the environment. Based on this data which is documented in
the RI, EPA and NJDEP have concluded that the source of the contamination was
a singular event or events and that the resultant ground water contamination
has dispersed over time through natural attenuation and/or biodegradation.
Therefore, EPA, in conjunction with NJDEP, are recooaending ia the Proposed
Plan that a "No Action' alternative be implemented for the Pomona ..Oaks.
subdivision.
EPA and NJDEP will be accepting public comments on the Proposed Plan until
August 31, 1990. In addition, EPA will hold an informational public meeting
at 7:00 p.m. on July 31, 1990 at the Galloway Township Municipal Building on
Jimmie Leeds Road in Galloway Township, New Jersey to present both the
findings of the RI Report and the Proposed Plan.
The EPA will sign a Record of Decision (ROD) which will document EPA's remedy
selection after the public comment period ends and consultation with NJDEP has
concluded. The EPA may select an option other than the proposed alternative
after consideration of all comments received.
Complete documentation of the project findings is presented in the
Administrative Record File which is available at the following locations:
Pomona School
Genoa Avenue
Pomona, New Jersey 08240
Stockton State College Library
Jimmie Leeds Road
Pomona, New Jersey 08240
Atlantic County Public Library
Galloway Township Branch
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30 W. Jimraie Leeds Road
Pomona, New Jersey 08240
Galloway Township Municipal Building
300 East Jinutile Leeds Road
Abeecon, New Jersey 08201
The public may comment in person at the public meeting and/or submit written
comments through August 31, 1990 to:
Matthew Hestgate
Remedial Project Manager
U.S. Environmental Protection Agency
Room 711
26 Federal Plaza
New York, New York 10278
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VALORE-PC
LAW FIRM
MEMBERS OF THE FIRM
Cart J. Valore
Cemfiea Civil Trial Attorney
Thomas P Gallagher
MemDer of NJ ana PA Bars
Anna M Smdoni
David Ewart Vance III. Esq
MBA/CPA.
Member of NJ ana PA Bars
Montanez & Montanez. PC.
Angelina Monranez
Tedrilo Montanez
Commerce Building
1200 Atlantic Avenue
Suite 302
Atlantic City. NJ 08401
Tel 609-348-0588
Fax 609-348-0582
Lir-v.ooc Comn-KT.s
Suite C 4
2l06Ne/.-f?oac
PO Box 321
Lmwood. NJOS22'
Tel 609-926-8866
Fax 609-926-8544
Reply to
4 mciuflmg Protewxvu Ccxpowi'Ons
August 31, 1990
Matthew Westgate, Project Manager
U.S. Environmental Protection Agency
Region II
26 Federal Plaza, Room 711
New York, NY 10278
RE: Pomona Oaks Well Contamination Site
Dear Mr. Westgate:
I am writing to you to formalize written comments on the No
Further Action Alternative addressed in the E.P.A. Proposed Plan
and RI Report in the above captioned matter. I am doing so on
behalf of our clients residing in the Pomona Oaks Subdivision of
Galloway Township.
As to the Agency for Toxic Substances and Disease Registry
(ATSDR) conclusion that "the levels of VOC's in the water samples
do not pose a public health threat..." the Pomona Oaks residents
voice objection insofar as the VOC's found were detected at
dangerous levels and while the subdivision is alternatively
supplied by potable water, exposure could still be had by other
routes; such as, inhalation of volatized chemicals, children
playing in the contaminated soil, etc. Admittedly, the
contamination plume has moved somewhat southeast, and has dispersed
over time through natural attenuation, this identified plume has
certainly not dissipated and is still present in the groundwater as
well as the soil.
In the discussion of no further action alternative section of
the Proposed Plan (Revised Edition) a number of facts are enlisted
on which the no-action decision is based. We submit that these
facts are disputed and inconclusive at best.
The first listed fact is that "the immediate threat to the
residents was removed by the alternative water supply." This is
not a realistic statement, since other routes of exposure are
possible other than through drinking water, and the threat of
exposure to toxic chemicals immediate or otherwise is certainly not
removed.
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Matthew Westgate, Project Manager
August 31, 1990
Page 2
The fact that the chemicals present during the period of 1982
to 1985 have significantly decreased to below drinking water
standards in 1989, suggesting dispersion of contaminants, does not
warrant inaction. Certainly, dispersion is not synonymous with
dissipation and the same health threat posed at the onset is still
present, not to mention the threats posed to the down-gradient
residents and our ecology.
Another fact considered is that the contamination was most
likely caused by a single discrete event. Our investigation has
uncovered repeated opportunities of discharge; besides inventory
discrepancies, gasoline underground tanks were repeatedly replaced
at the Exxon station since 1929 because of leaks. These facts are
suggestive of various discharges. Accordingly, the "single
discrete event" relied on is most inaccurate.
The fact that most of the compounds found were at levels below
relevant and appropriate Federal and/or State standards, seems to
suggest that there is presence of some contamination, even though
below standards. This also suggests that the health and ecological
threats, while reduced, have not been eliminated. Accordingly, it
would seem that any health threat and any adverse impact on our
environment should be eliminated not merely minimized.
Lastly, the down-gradient contamination of the Pinehurst
section was determined to be unrelated to the Pomona Oaks because
of the diverse contaminants and the lack of temporal factor.
Logically, if no action is taken to remove or abate the Pomona Oaks
contamination, the temporal factor will be achieved and the
documented Pomona Oaks contamination will reach the Pinehurst
section, albeit in an attenuated state.
For the various reasons herein presented, we object to the no-
action alternative reached by E.P.A.
Very truly yours,
AMS/cj
cc: Albert J. Slap, Esq.
Esther Berezofsky, Esq.
/
ANNA M. SINDONI
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\
8 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
<
? REGION II
JACOB K. JAVrrS FEDERAL BULDING
NEW YORK. NEW YORK 10278
Ms. Anna Sindone
Carl Valore & Associates P.C.
Linwood Commons
Suite C 4
2106 New Road
Linwood, New Jersey 08221
RE: Pomona Oaks Well Contamination Site
Dear Ms. Sindone:
I am writing in response to your comments on the Environmental
Protection Agency's (EPA's) Proposed Plan for the Pomona Oaks
site. These comments were contained in your letter to me, dated
August 31, 1990.
In general, your letter indicates that you believe that
contamination still exists in the ground water in the Pomona Oaks
subdivision which poses an unacceptable risk to the residents,
and that EPA should remove this contamination. First, I will
summarize EPA's position and then I will address each point made
in your letter.
EPA's investigation of the Pomona Oaks site did not find
contamination in the ground water or in the soil at levels above
EPA or the State's health based criteria, with the exception of
one ground water sample discussed below. In addition, when EPA
does determine that active remediation of ground water is
warranted, the objectives of the remediation are to achieve the
health based criteria that presently exists in the Pomona Oaks
ground water. Therefore, Pomona Oaks already achieves the
objectives if EPA had determined that active remediation was
needed. Below, I will address your comments, point by point.
In the first part of your letter, you refer to the Agency for
Toxic Substances and Disease Registry's comment "the levels of
VOCs in the water samples do not pose a public health threat..."
You state "the Pomona Oaks residents voice objection insofar as
the VOCs found were detected at dangerous levels and while the
subdivision is alternately supplied by potable water, exposure
could still be had by other routes; such as inhalation of
volatilized chemicals, children playing in contaminated soil,
etc."
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EPA respectfully disagrees with your conclusion that residents in
the Pomona Oaks subdivision could still be exposed to
contaminants. The contamination discovered in 1982 is no longer
present in the ground water or the soil of the Pomona Oaks
subdivision.
EPA recognizes the fact that beginning in June of 1982 and
through 1983, there were significant levels of VOCs in the
shallow Cohansey aquifer beneath the Pomona Oaks subdivision. At
that time, there were a number of routes of exposure for these
contaminants, such as direct ingestion, inhalation of volatilized
chemicals while showering, etc. The Remedial Investigation was
designed to detect contamination from all of these routes of
exposure. EPA sampled ground water from the water table, about
12 feet below the ground surface, to the bottom of the Cohansey
aquifer, 200 feet below the ground surface. With the exception
of one shallow well adjacent to the Pomona Garage Salvage Yard on
Langley Ave, we found no contaminants present above Federal and
State drinking water standards.
EPA collected soil samples from the surface down to the water
table from all of the monitoring well locations. No contaminants
were found at levels that exceeded NJDEP Soil Cleanup Objectives.
As part of the remedial investigation, EPA discovered two
residences with mercury and trichloroethene present above the
Maximum Contaminant Levels (MCLs) in the Pinehurst area,
southeast of the Pomona Oaks subdivision. In a separate effort,
the Atlantic County Health Department has identified twenty
residences in Pinehurst that have trichloroethene,
tetrachloroethene and mercury at levels above MCLs. EPA agrees
with your conclusion that these residents are being exposed to
VOCs through a number of different routes, if they continue to
use their contaminated water for drinking or cooking. They were
advised by EPA and the Atlantic County Health Department not to
use their water for these purposes.
EPA does not agree with your conclusion that this is the same
contamination that was present in the Pomona Oaks subdivision in
1982 and 1983.
In your letter, you refer to EPA's discussion in the Proposed
Plan that our No Action decision was based on a number of facts.
You state "that these facts are disputed and inconclusive at
best." The first listed fact is "the immediate threat to the
residents of the Pomona Oaks subdivision was removed by the
alternate water supply in 1985." You are correct in your
statement that connection to a municipal water supply did not
remove all of the potential exposure pathways. Volatiliza-tion
of floating VOCs in the shallow aquifer could have permeated the
soil and been released to the atmosphere exposing residents.
While these routes of exposure could have existed when the
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contaminants in the ground water were present at high levels,
they were not confirmed at that time. All of the testing done
during the remedial investigation showed that there are only low
levels of contaminants in the ground water and there are no
contaminants in the soil. Therefore, the potential for these
other routes of exposure no longer exists.
The next item that you dispute is EPA's decision to use the No
Action alternative at the Pomona Oaks site. You state "The fact
that the chemicals present during the period of 1982 to 1985 have
significantly decreased to below drinking water standards in
1989, suggesting dispersion of contaminants, does not warrant
inaction." EPA bases the need for evaluating remedial action
alternatives for ground water contamination problems like Pomona
Oaks, on the results of a risk assessment. The calculations for
potential health effects performed in risk assessments are based
only on sample data that has been subjected to our extensive
quality control procedures. These samples reflect current
conditions at the site. In addition, the assumptions used for
risk calculations are extremely conservative and tend to
overstate risk, not understate it. The risk assessment for
Pomona Oaks showed that there is no current risk posed by
contamination of ground water or soil.
You go on to say, "Certainly, dispersion is not synonymous with
dissipation and the same health threat posed at the onset is
still present, not to mention the threats posed to the down-
gradient residents and our ecology." EPA disagrees with this
statement also. As stated above, the risk assessment performed
for Pomona Oaks shows that there is no current health threat. If
EPA had obtained ground water data similar to that found in 1982,
the results of our risk assessment would have clearly shown there
was a threat, and EPA would have developed, evaluated, and chosen
a remedial action appropriate to mitigate that threat. And
finally, based on the remedial investigation and the risk
assessment, it has been concluded that the contamination in the
Pinehurst area is not due to Pomona Oaks past contamination and,
further, that there is no risk to the ecology of the Pomona Oaks
area.
Another point in EPA's Proposed Plan that you disagree with
was that you thought the contamination in Pomona Oaks was due to
a number of releases and not "a discrete event". EPA also
believes that the contamination was due to more than one release
or event, however, in the Proposed Plan, we meant to indicate
that the contamination was not from a continuous source.
In your letter, you suggest that "any health threat and any
adverse impact on our environment should be eliminated not merely
minimized." As indicated before, EPA evaluates the need for
remedial action dependent upon the presence of an unacceptable
human health or environmental risk. Again, EPA has determined
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that this does not exist for the Pomona Oaks site.
Lastly, you state "the down-gradient contamination of the
Pinehurst section was determined to be unrelated to the Pomona
Oaks (sic) because of the diverse contaminants and the lack of
the temporal factor. Logically, if no action is taken to remove
or abate the Pomona Oaks contamination, the temporal factor will
be achieved and the documented Pomona Oaks contamination will
reach the Pinehurst section, albeit in an attenuated state."
EPA, in conjunction with NJDEP, has concluded that the
contamination present in the Pinehurst area is not related to the
contamination in Pomona Oaks, therefore, NJDEP now has the
jurisdiction to investigate the contamination problem in
Pinehurst. EPA will be working with the NJDEP to continue the
investigation of the Pinehurst area.
I hope this response answers the questions you have about the
Pomona Oaks site. If you need any further information or want to
discuss this matter further, please feel free to contact me at
(212) 264-3406.
Sincerely yours,
Matthew Westgate, Project Manager
Southern New Jersey Remedial Action Section
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POMONA OAKS WELLFIELD SITE
ADMINISTRATIVE RECORD FILE
INDEX OF DOCUMENTS
SITE IDENTIFICATION
Background - RCRA and Other Information
p. 1-64 Report: Final Report-Phase I Feasibility Study
to Develop Alternative Groundwater Supplies
and Remediate Groundwater Contamination, prepared
by Paulus, Sokolowski and Sartor. April 29, 1983.
p. 65-83 Report: Draft Report Phase II Investigation
to Develop Alternative Groundwater Supplies and
Remediate Groundvater Contamination, prepared by
Paulus, Sokolowski and Sartor. July 27, 1983.
p. 84-118 Report: Engineer's Report on MGD Pomona Oaks
Production Well, prepared by New Jersey-American
Water Company, January, 1988. Cover letter dated
July 22, 1988.
r
P. 119-182 Report: Aerial Photographic Analysis for Pomona
Oaks Well Contamination Site, prepared by US EPA.
June, 1988.
REMOVAL RESPONSE
Sampling and Analysis Plans
p. 183-184 Memorandum to Robert Cobiella, US EPA, from Edward
W. Blanar, Roy F. Weston, Inc., re: two treatment
alternatives for water supply. June 8, 1984.
Sampling and Analysis Data
p. 185-253 Report: OSC Report, prepared by Anne Tischbein,
TAT Weston/SPER, for John La Padula, US EPA.
December 26, 1985.
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Action Memorandum
p. 254-261 Action Memo to George Zachos, US EPA, from Dick
Dewling, US EPA, re: Immmediate Removal Request.
September 10, 1984.
p. 262-264 Action Memo to Christopher J. Daggett, US EPA,
from Stephen D. Luftig, US EPA, re: Request for
funding to continue remedial activities. December
14, 1987.
REMEDIAL INVESTIGATION
Sampling and Analysis Plans
p. 265-374 Report: Pomona Oaks Contaminated Wellfield Study.
prepared by Camp, Dresser, & McKee, Inc., for
NJDEP. March, 1984.
p. 375-461 Report: Pomona Oaks Exposure Assessment-Volatile
Orqanics in Well Water and Indoor Air, prepared by
New Jersey Department of Health. October, 1984.
p. 462-533 Report: Hvdroqeologic and Water Quality
Investigation of the Atlantic Citv Wellfield.
prepared by Roy F. Weston, Inc. 1984.
p. 534-549 Report: Project status update and recommendations
for 1) preparation of design documents. 2)
providing bottled water to affected residences,
and 3) conducting additional sampling of
residential wells. Under cover to William
Librizzi, US EPA, from John La Padula, US EPA.
March 7, 1985.
p. 550-561 Report: Potable Water Sampling Plan, under cover
letter to John La Padula, US EPA, from Craig A.
Moylan, Roy F. Weston, Inc. May 17, 1985.
(Letter dated May 24, 1985).
p. 562-632 Report: Pomona Oaks Well Contamination Site-
Interim Report, prepared by Camp, Dresser, &
McKee, Inc. April 1, 1987.
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p. 633-795 Report: Pomona Oaks Well station Test Production
Well Installation and Testing, prepared by Malcolm
Pirnie, Inc. December 21, 1987. Cover letter
attached.
p. 796-895 Report: Analytical Report. Pomona Oaks, prepared
by US EPA. September 27, 1989.
p. 896-961 Report: Analytical Report. Pomona Oaks, prepared
by US EPA. May 17, 1990.
p. 962-968 Data: List of organics present in water and soils
sampled. July 17, 1990.
Work Plans
p. 969-1181 Report: Final Work Plan for the Phase I Remedial
Investigation at the Pomona Oaks Well
Contamination Site, prepared by Camp, Dresser &
McKee Inc. July 27, 1987.
p. 1182-1299 Report: Final Work Plan, Remedial Investigation
and Feasibility Study, prepared by EBASCO Services
Inc. August, 1988.
Remedial Investigation Reports
p. 1300-1300 Letter to Matther Westgate, US EPA, from William
J. Barrett, US EPA, re: Air Programs Branch
review of Draft Remedial Investigation and Risk
Assessment. February 15, 1990.
p. 1301-1645 Report: Final Remedial Investigation Report.
prepared by EBASCO Services, Inc. May, 1990.
p. 1646-1680 Report: REM III RI/FS Status Meeting, prepared
by C.C. Johnson & Malhotra, P.C. June 6, 1990.
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Correspondence
p. 1681 Memo to Kenneth Biglane, US EPA, from Fred Rubel,
US EPA, re: request for ERT support. June 27,
1984.
p. 1682-1682 Memo to Fred Rubel, US EPA, from George R. Prince,
US EPA, re: recent ERT activities in response to
June 27, 1984 request. August 8, 1984.
p. 1683-1685 Letter to Ronald Borsellino, US EPA, from John S.
Malleck, US EPA, re: Water Management Division
Review of the Draft Remedial Investigation Report.
(undated)
p. 1686-1687 Letter to Donald Lynch, US EPA, from William P.
Lawler, US EPA, re: Comments on draft Rl report
and draft Risk Assessment. February 15, 1990.
p. 1688-1689 Letter to Ronald Borsellino, US EPA, from Andrew
Bellina, US EPA, re: RCRA review of Pomona Oaks
Draft Remedial Investigation. February 15, 1990.
p. 1690-1691 Memo to Matthew Westgate, US EPA, from Allison
Barry, US EPA, re: Inadequate risk
characterization in Baseline Risk Assessment.
August 6, 1990.
FEASIBILITY STUDY
Proposed Plans
p. 1692-1697 Pamphlet: Proposed Plan (Revised Edition)r
prepared by US EPA. July, 1990.
Correspondence
p. 1698 Memo to Robert Snellings, US EPA, from Royal
Nadeau, US EPA, re: Request for Technical
Assistance. July 3, 1984.
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STATE COORDINATION
Cooperative Agreements / SMOA's
p. 1699-1727
Superfund State Contract Between The State of New
Jersey And The US EPA For Remedial Activities
Related To The Pomona Oaks Well Contamination Site
In The State Of New Jersey.
Correspondence
p. 1728-1729
p. 1730-1731
p. 1732-1733
p. 1734-1735
p. 1736-1737
Letter to William Librizzi, US EPA, from Dr. Jorge
H. Berkowitz, NJDEP, re: Need to develop
alternative water supply due to severe groundwater
contamination. June 5, 1984.
Letter to Richard T. Dewling, US EPA, from George
J. Tyler, NJDEP, re: Update on progress of final
plans for a satellite water system to service
residents. June 29, 1984.
Letter to William Librizzi, US EPA, from Geroge
J. Tyler, NJDEP, re: Groundwater and drinking
water contamination problems. December 7, 1984.
Memo to William Librizzi, US EPA, from John
La Padula, US EPA, re: Rationale for Revised
Funding. March 12, 1985.
Letter to Richard T. Dewling, NJDEP, from William
Librizzi, US EPA, re: The problem of title of
ownership of water mains in relation to the
construction of permanate alternate water
supplies. (Undated - possibly not sent).
ENFORCEMENT
Correspondence
p. 1738-1744
Letter to Mr. Matthew Westgate, US EPA, from Mr.
Rey Morales, NJDEP, Re: Information concerning
Exxon Gas Station, US Highway 30. August 2, 1989.
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HEALTH ASSESSMENTS
ATSDR Health Assessments
p. 1745-1750
Report: Working Draft Health Assessment, prepared
by NJDEP. September 20, 1988.
Correspondence
p. 1751-1754
p. 1755-1759
p. 1760-1761
p. 1762-1762
Memo to Matthew Westgate, US EPA, from Kevin G.
Garrahan, US EPA, re: Review of Risk Assessment.
March 2, 1990.
Letter to Matthew Westgate, US EPA, from Rey
Morales, NJDEP, re: Comments on Draft Remedial
Investigation Report and Risk Assessment Report.
March 15, 1990.
Letter to William Nelson, ATSDR, from Jonathan
Savrin, NJDEP, re: Request for review and
commentary on Remedial Investigation and.Risk .
Assessment. March 28, 1990.
Memo to Matthew Westgate, US EPA, from William
Nelson, ATSDR, re: Review of Draft PRAP. April
26, 1990.
NATIONAL RESOURCE TRUSTEES
Correspondence
p. 1763-1763
p. 1764-1767
Letter to Clifford G. Day, US Fish & Wildlife
Service, from Robert W. Hargrove, US EPA, re:
Informal consultation to determine if there exist
any federal endangered/threatened species or
critical habitats in vicinity of Pomona Oaks
Site. February 14, 1990.
Letter to Ronald Borsellino, US EPA, from Frank
Csulak, US Department of Commerce, re: National
Oceanic & Atmospheric Administration's natural
resource concerns after reviewing draft Remedial
Investigation Report. February 21, 1990.
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p. 1768-1771 Letter to Robert W. Hargrove, US EPA, from Michael
T. Chezik, US Department of Interior, re:
Information on federally listed or proposed
endangered and threatened species within Pomona
Oaks Site area. March 12, 1990.
PUBLIC PARTICIPATION
Community Relations Plan
p. 1762-1796 Report: Final Community Relation Plan, prepared
by EBASCO Services, Inc. September, 1988.
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Pe>Mr pranc fax transmit1 mamo 7671
Btpl.
en
STATE OF NEW JERSEY
DEPARTMENT OF ENVIRONMENTAL PROTECTION
JUDITH A. YASJON, COMMISSIONER
CK40J
TRENTON. K.) OS625.0402
(609) J92-2SIS
Fax: (609) 914-3962
Mr. Constantine Sidamon-Sristoff
Regional Administrator 9 1 ccn
USEPA - Region II ' T 5£P
26 Federal Plaza
New York, NY 10278
Dear .Mr. Sidamon-Eristof f :
The Department of Environmental Protection has evaluated and concurs
with the selected remedy for the Pomona Oaks Well Contamination
Superfund Site as outlined below:
The selected alternative for the Pomona Oaks site is to take no
further remedial action. In 1965, in response to a groundwater
contamination problem, the residents of the Pomona Oaks
subdivision were connected to a public water supply system from
the neighboring town of Absecon. The residential wells were
sealed, thus removing the immediate health risk to the
residents, This action was funded by the New Jersey Department
of Environmental Protection's Spill Fund.
The Remedial Investigation (RI) was conducted from October 1968
to March 1989. Data obtained during the RI has shown that the
groundwater contamination in the Pomona Oaks subdivision no
longer exists above health risk or drinking water standards.
Therefore, no further remedial action is considered
appropriate. However, since groundwater contamination did exist
in the Pomona Oaks area and the fact that contamination is
present above New Jersey Safe Drinking Water Act standards in
the Pinehurst area, downgradient of the subdivision, continued
groundwater sampling la necessary to monitor the overall
groundwater quality in the area.
The Department reserves its final comments on the complete Record of
Decision pending an opportunity to review the completed documents,
including the document's responsiveness summary,
Sincerely,
Judith A. Yaskln
Commissioner
Jt'if) it an Equal Opportunity
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