United States        Off ice of
          Environmental Protection   Emergency and
          Agency           Remedial Response
EPA/ROD/R02-93/223
September 1993
&EPA   Superfund
         Record of Decision
       •»

         Woodland Township
         Route 72 Dump, NJ

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                                      State of New Jersey
                        Department of Environmental Protection and Energy
                             Division of Responsible Party Site Remediation
                                            CM 028
                                     Trenton. NJ 08625-0028

Jeanne M. Fox                                                              -          Karl J. Delaney
Acting Commissioner                                                                      Director
       CERTIFIED MAIL
       RETURN RECEIPT REQUESTED
       -•   faw 0*901
       Mr.  Larry Granite
       Project Manager
       USEPA Region II
       26 Federal Plaza
       New York, NY  10278
       Dear Mr. Granite:

       Re:   Woodland Township  Superfund Sites
            Woodland Township,  Burlington County

       Enclosed please find a copy of the Subsurface  Soils  (Operable Unit 2) Record of
       Decision  for the  above referenced  sites  signed September  28,  1993.    As  we
       discussed  on September  29,  1993,  you will  make copies of  the document  and
       distribute them to  the  appropriate people in your office.

       If you have  any questions,  feel  free to contact me at  (609)  633-1455.

                                                  Sincerely,
                                                  Gwen Barunas,  Case Manager
                                                  Bureau  of  Federal Case Management
       enclosure
                                 Atewyersey Is an Equil Opportunity Employer
                                          Keeyded Paper

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                          ROD FACT SHEET

SITES

Name:  Woodland Township Route 72 and Route 532 Sites
Location:  Woodland Township, Burlington County, New Jersey
EPA Region:  2
HRS Score:  Route 72 site  - 31.17 (July 5, 1983)
            Route 532 site - 34.98 (July 5, 1983)

SECOND OPERABLE UNIT RODS

Date Signed:  September 28, 1993
Remedy for the subsurface soils:  No further action

LEAD

Agency:  NJDEPE Remedial and Enforcement Leads
Primary USEPA contact:   Rick Robinson (212) 264-4425
Primary NJDEPE contact:  Gwen Barunas  (609) 633-1455

WASTE

No remedial action for the subsurface soils is necessary to
ensure protection of public health and the environment.

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     SUPERFUND  RECORD  OF DECISION
 WOODLAND  TOWNSHIP SUPERFUND
          WOODLAND  TOWNSHIP
            BURLINGTON  COUNTY
                NEW  JERSEY
                              SITES
PREPARED BY:
N.J. DEPARTMENT OF ENVIRONMENTAL PROTECTION AND ENERGY
SITE REMEDIATION PROGRAM
BUREAU OF FEDERAL CASH MANAGEMENT
SEPTEMBER 1993

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         *

          \      UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

          $                          REGION II

                             JACOB K. JAVITS FEDERAL BUILDING

                             NEW YORK. NEW YORK 1O278-OO12
         2 4  SEP  1993

        Jeanne  Fox, Acting Commissioner
        State of New Jersey
        Department of  Environmental
          Protection and  Energy
        401  East State Street, CN  402
        Trenton, New Jersey  08625-0402

        Re:  Records of Decision
             Woodland  Township Route 532  and Route  72  Superfund Sites
             Burlington County, New Jersey

        Dear Commissioner Fox:

             Draft Records of Decision  (RODs)  have  been prepared for the
        Woodland Township Route 532 and Woodland Township Route 72
        Superfund sites located in Burlington  County,  New Jersey.

             The United States Environmental Protection Agency (EPA)
        concurs with the  "No Further Action" remedy for the subsurface
        soils at the sites, and has determined that,  based on the
        administrative record for  the  sites, the draft RODs are
        consistent with Section 121 of the  Comprehensive Environmental
        Response, Compensation, and Liability  Act,  as amended, (CERCLA),
        42 U.S.C. Section 9601 et  seq.  This  finding shall not affect
        EPA's right to take response and  enforcement actions pursuant to
        Sections  104,  106 and 107  of CERCLA.

                                             Sincerely,
                                             William J. Muszynski, P.E.
                                             Acting Regional Administrator
PRINTED ON RECYCLED PAPER

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           WOODLAND TOWNSHIP SUPERFUND  SITES
                    RECORD  OF  DECISION
                    TABLE OF CONTENTS



DECLARATION  STATEMENT  	     1

DECISION  SUMMARY  .  . .	    3

ADMINISTRATIVE  RECORD  INDEX  	    13


ATTACHMENT  1  -  FIGURES

ATTACHMENT  2  -  TABLES

ATTACHMENT  3  -  RESPONSIVENESS  SUMMARY

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                         DECLARATION  STATEMENT

                           RECORD OF  DECISION

                   WOODLAND TOWNSHIP ROUTE  72 SITE

Site  Name and Location

Woodland Township  Route 72 Site,  Burlington County,  New Jersey.

Statement of  Basis and Purpose

This decision  document presents the selected remedial  action  for  subsurface
soils  it  ttfe   Woodland   Township  Route  72  site,  which was  chosen  in
accordance  with the  Comprehensive  Environmental Response,  Compensation,
and  Liability  Act  of  1980, as amended  by the Superfund  Amendments  and
Reauthorization Act  of 1986 and, to the extent practicable, the National Oil
and  Hazardous Substances  Pollution  Contingency  Plan.   This  decision is  based
on the  administrative record for  the  site.

The  U.S.  Environmental Protection  Agency concurs  with the selected remedy.


Description of the Selected Remedy

This is the second and  final  operable  unit for the  site.   A previous  Record
of  Decision,   signed  on  May   16,   1990,  addressed the   remediation  of
contaminated  surface  materials, sediments and ground~~water at  the  site.  This
decision  document addresses  the  subsurface  soils.

The  New Jersey  Department  of  Environmental  Protection and  Energy  has
selected  no further  action for the  second operable unit.

Declarations

No remedial action for the subsurface soils is necessary to ensure protection
of public health and  the  environment.

The  New Jersey  Department  of  Environmental  Protection and  Energy  will
conduct a five-year  review for this operable  unit.
 Jeanne M.  Fox,  Acting Commissioner                    Date
 New  Jersey Department of
 Environmental Protection  and Energy

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                         DECLARATION  STATEMENT

                           RECORD OF  DECISION

                  WOODLAND TOWNSHIP ROUTE 532 SITE

Site  Name and Location

Woodland Township Route  532  Site, Burlington  County,  New  Jersey.

Statement of  Basis  and Purpose

This decision  document presents the selected remedial  action for subsurface
soils  at  the  Woodland  Township  Route  532  site,  which   was  chosen  in
accordance  with the  Comprehensive Environmental  Response,  Compensation,
and  Liability  Act of  1980, as  amended by  the  Superfund  Amendments and
Reauthorization  Act of 1986 and,  to the extent  practicable,  the National  Oil
and  Hazardous Substances  Pollution Contingency  Plan.   This decision  is  based
on  the  administrative record for the site.

The  U.S.  Environmental Protection  Agency  concurs  with the selected remedy.


Description of the Selected Remedy

This is the second and final  operable  unit for  the  site.   A  previous Record
of  Decision,   signed  on  May   16,  1990,   addressed  the  remediation   of
contaminated  surface  materials, sediments and ground water  at the  site.   This
decision  document addresses  the  subsurface soils.

The New Jersey  Department  of  Environmental  Protection  and  Energy  has
selected  no further action  for  the  second  operable  unit.

Declarations

No remedial action  for the subsurface soils is necessary to ensure  protection
of  public health and  the environment.

The New Jersey  Department  of  Environmental  Protection  and  Energy  will
conduct a five-year  review for  this operable unit.
 Jeanne M.  Fox,  Acting Commissioner           Date
 New  Jersey Department of
 Environmental Protection  and Energy

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                                     -3-

                           DECISION  SUMMARtES

   Woodland Township Route  532  and Woodland Township  Route 72  Sites

SITE NAME, LOCATION AND DESCRIPTION

The Woodland Township Route  72 site and  Woodland  Township  Route 532  site
are both  located  in   Woodland  Township,  Burlington  County,  New  Jersey
(Figure  1).    Both  of  the  sites  are  situated  within  the   Preservation Area
District of  the  New  Jersey Pinelands.  The  Route 532 site also  falls within
the designated  "special agricultural area" of the Pinelands.

The Route  532  site  is approximately  20 acres in size and  is  located  on  tax
block  4210,  lot  1.    The  site  is  at the  end  of  ah  unpaved  access road
approximately 1/8  mile south  of Route  532.   The unnamed site access road
meets  Route 532  approximately 1  1/8 miles west  of  the  intersection  of Route
532  and  Route  72.  Goodwater Run,  an  intermittent  stream, and Bayley Road
border the  site  to the east.   An  unpaved  forest fire  control road  runs along
the southern edge  of the site.   Active commercial  cranberry bogs are  located
approximately 1  mile  west-southwest  of  the site.

The  Route  72 site is  approximately  12  acres  in size and  is  located  on  tax
block 5501, lot 15  and  tax block  6301, lot 1.   The site  is  1/4  mile south
of Route  72 along Crawley  Road.  Crawley  Road  is  labeled  as  Sooey Road on
United  States  Geological  Survey   maps.    Crawley  Road  meets   Route   72
approximately  1 1/3  miles  southeast of  the intersection  of  Route  532  and
Route  72.  Pope  Branch,  an intermittent  stream,  is  located  approximately  500
feet to the north  and  1,000  feet  west of  the  site.   An  active commercial
cranberry bog  is  located  approximately .1/2  mile northwest of  the site.

One private residence is located  within  a  3-mile  radius of each  site.   The
sites  are  approximately 3 miles apart, and  are  at  an  average elevation  of  125
feet above  mean  sea  level.   The  Route 532 site  has approximately  20  feet
of relief, while the  Route 72  site has roughly 10 feet of  relief.   Both sites
are characterized by  loose  sandy soils.

Both  sites  overlie  the  Cohansey  and  Kirkwood   Aquifers.    Of  the   two
formations,  the  high-yielding Cohansey Aquifer  is  the major source  of  potable
water   for  the  area  and  was  impacted  by  the   past   disposal  practices
associated  with the  sites.   In addition,  the  Woodland  Township  sites   are
located in  a regional  recharge  area for these aquifers.  The Cohansey  Aquifer
also  provides  the  base  flow  of many  regional  surface  water  bodies (e.g.,
streams,  bogs).  There are discontinuous  clay layers  beneath  the sites.

In  September  1983,  both sites  were proposed for  inclusion on  the  National
Priorities  List (NPL)  of Superfund sites.   The sites  were added to the NPL in
September  1984.

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                                     -4-

SITE HISTORY  AND ENFORCEMENT  ACTIVITIES

Route  532 Site

Early  records  indicate ownership of the  Route 532 site  by  Francis  Estlow.
In  1973,  Estlow  sold the  property to  Cohen, Weiss and  Krell.   In 1976,
Airtime,  Incorporated  purchased  the property  and subsequently  sold it to  its
present owners,  Joseph  and Albert  Spitzer.

An aerial  photograph from  1951  shows that a  pine  forest existed in  the  study
area  prior to the beginning of disposal operations.   The  exact  date disposal
began  is  unknown; however, it is estimated to have begun  between  1951 and
1956.   The  western  half of the Route  532 site was  organized  into a series
of bermed lagoons  when  the  disposal  began.   A  1956 photo  indicated  these
lagoons   contained  black   liquid  waste.    It  was  also   evident  from  the
photograph  that  this  waste was released  along an on-site road  and flowed
toward a  depression.

By  1962, most of  the  disposal  areas  had been regraded.  In  a  1962  aerial
photograph,  new  bulldozer  scrape  marks  indicate that the disposal area was
being  enlarged.    The  black  liquid,  previously dumped  on  site,  had  also
breached  the lagoon  berm  and was flowing  into  the  nearby  pine forest.   A
second flow  was  observed  extending from  the  eastern border  toward the  path
of Goodwater  Run.

A  1984  photograph  indicated that the  site  remained essentially unchanged
between  1962 and 1984.   Denuded areas could be  observed where the two
liquid  flows moved  off site.    The photograph also  shows  partially buried
drums  on the downslope edges of the former lagoons and  road on the western
half  of the site.   Partially  buried drums and  general  refuse  were  piled  along
former roads  on tbe  eastern half  of  the property at that  time.   No  site
controls were  in  place  from 1962  to  1986.   In  1986, potentially  responsible
parties (PRPs)  constructed  a  security fence to  restrict site access.

Route  72 Site

The  Route   72  site  was  owned by  Francis  Estlow   until  1957,  when   the
property  was  purchased by Rudolf  Kraus.  Rudolf  and/or Eleanor Kraus  also
owned Industrial  Trucking  Services Corporation, the company that  reportedly
transported  the  waste materials  to  the sites  for disposal.   Cohen,  Weiss and
Krell   purchased  the  property  in April  1964.   It  is  unclear from Woodland
Township records  when  the  property  was   acquired  by  its current  owner,
Airtime,  Inc.

A 1951  aerial  photograph  of  the site  illustrates  conditions prior to the  waste
disposal operation.   Probable  concrete  pads, possible basement space, a  utility
building  and a sidewalk  can be observed.  An unpaved  road  connected  the
site  to the  perimeter road of  the  Coyle  Airport.   Crawley  Road  and  a  fire
road  north  of  the site  were  also present.

A 1956 photograph shows  several  trenches elongated  in an  east-west  direction
on  the northern  third  of  the  site.   The  trenches were located on  both  sides

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                                     -5-

of Crawley  Road.  The central  portion of the  site was  covered  with  general
refuse and  stained soils.   Small depressions  containing  standing liquid  were
evident on  the  western  half of  the  site.  The southern  portion of the site
west  of  Crawley Road  contained  a  wide  depression with  standing liquid in  it.
The southern  portion east of Crawley  Road contained  several  shallow trenches
oriented  along a north-south axis.

Between   1956  and  1962, the  site  layout  remained  unchanged  based on  a
1962   photograph.    However,  the  trenches  were  apparently deepened, and
those  in  the northern  and southern portions  of the site  contained  a standing
light-colored liquid.

A  1984  photograph did not  identify any changes to the site since 1962.  The
outlines  of  trenches  and  depressions  could be  observed.   Drums,  stained soils,
and general refuse were  identifiable in the central'portion of the  site.   Much
of the pine forest at the  edge of  the  site  had regenerated,  while   on-site
disposal  areas  remained unvegetated.   This site was  also  uncontrolled between
1962  and  1986.   In 1986,  the PRPs  constructed  a  security  fence to  restrict
site access.

Enforcement History

The  New Jersey  Department of  Environmental Protection and  Energy  (DEPE)
was  advised of environmental  problems at the sites by the  Burlington  County
Health  Department  in April 1979.   The DEPE  subsequently conveyed  the
information  to the  U.S. Environmental Protection Agency  (EPA).   At about the
same   time, a biologist  investigating  endangered  species for the  DEPE also
reported  environmental problems at the  sites.

Due  to the similarities of the  two  sites  (i.e.,  PRPs,  waste disposal practices,
location   and  physical/chemical characteristics),  enforcement efforts  for the
sites  have  been combined.   The  DEPE  issued a directive  on March 4,  1985
to the Rohm  and Haas   Company, the  Minnesota Mining  and Manufacturing
(3M)   Company,  Hercules, Inc.,  and  other  companies identified  as PRPs  to
arrange  for the investigation  and  remediation of the sites.   On  March 27,
1985, the  DEPE entered into  an  Administrative  Consent Order (ACO) with
Hercules,  Incorporated to help  pay  for  the  investigative and  administrative
costs.   On July  6,  1987,  the DEPE  entered  into  similar ACO  with 3M, and
Rohm and  Haas Company.

On January 2,  1990,  the DEPE entered  into a second Administrative  Consent
Order (ACO II) with Hercules,  3M and  Rohm  and Haas.   The purpose  of this
ACO  was to  compel  the PRPs to remove  liquids and  sludges  from   isolated
locations on  the sites' surfaces.

A third  order, ACO  III, was signed with  Hercules,  3M and Rohm  and  Haas  on
June   15,  1990.   It required  the  PRPs  to excavate  for off-site disposal  all
visibly contaminated surface soils  from  both sites, as  specified   in the  Record
of  Decision  (ROD)  dated  May 16,  1990.  The  ROD  estimated  there  was  a
total  of  54,000 cubic yards of contaminated  surface  materials and sediments
 (soils, sludges,  debris, etc.) and IS  cubic yards  of  radiologically  contaminated
surface  materials  at the  two  sites.

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                                     -6-

The  excavation  and off-site disposal of the  surface  materials was conducted
in  1990.   The  actual  amount  of contaminated  materials  and  sediments
removed from  the Route 72  and  532  sites  was  37,200  and  60,200  cubic
yards, respectively,  compared  to the  ROD estimate of  54,000  cubic yards.
Part  of the reason for the  higher  volumes is that much of t-he  contaminated
subsurface  soils   was   removed  along   with  the   removal  of  the  visibly
contaminated  surface  materials.  These soils  had been  acting as a  source of
continuing  contamination  of  the groundwater.  The excavation  of the  soil  was
intended to minimize cross-media impacts of  contaminated  soil on the ground
water.   The  removal  of additional subsurface soils  further  reduced  these
impacts, thereby  enhancing the  effectiveness of the remedy.

Subsequent to  the excavation  of the contaminated  surface  materials,  the  sites
were graded to prevent  soil erosion.   Protective vegetative and  mulch covers
were also  established  to prevent erosion.  The  May  1990  ROD  calls for the
final  restoration of the  sites  after  the  remedial  actions  are completed.

On August 15,  1991, the  fourth  AGO (AGO IV)  was  signed  with  Hercules,
3M,  and Rohm  and Haas.   The purpose of this  AGO was to require  the  PRPs
to extract  and  treat  contaminated  ground  water as specified  in  the  ROD and
to perform  a  remedial  investigation  and feasibility  study  (RI/FS),  and  remedial
action, if  necessary,  for the  subsurface soils.
HIGHLIGHTS OF COMMUNITY PARTICIPATION

A  Community  Relations  Plan  (CRP)  was  developed  to  ensure  the  public
opportunities for  involvement in site-related decisions.   In addition,  the  CRP
was used by the  DEPE to determine, based  on  community  interviews, activities
to  ensure  public  involvement and  to  provide opportunities for the community
to  learn about  the  sites.

On February 10,  1986, a public meeting  was  held to explain the initial  RI/FS
to  the  public and to  report  on  progress being made at the site.  The results
of  the  RI/FS were  presented in  a  public  meeting  held on  January  31,  1990.
A  ROD, which selected  a   remedy  for  the contaminated  surface  materials,
sediments  and  ground water, was signed on  May 16, 1990.

The supplemental  Rl  report and  the  Proposed  Plan,  which  addressed  the
subsurface  soils,  were released to the public for comment in August  1993.
These  documents  were  made   available  to   the  public   at  the information
repositories  at the  Woodland Township  Municipal Building located  on Main
Street  in Chatsworth,  and at the  Pinelands Commission located  on  Springfield
Road in New Lisbon.  A copy  of  the administrative  record file for the sites
is  located at the previously-mentioned  information repositories,  as  well as in
the DEPE's  Bureau  of  Community Relations, 401  East State Street in  Trenton.
The notice  of availability for the  above-referenced documents  was  published
in  The Burlington County Times on August 19,  1993.   The  public  comment
period  on these documents  was  held from August 19, 1993 through September
 17, 1993  (30 calendar days).

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                                     -7-

On  August 31,  1993,  the  DEPE  held  a  public meeting  at  the Woodland
Township Municipal  Building,  to  present  the findings  of the supplemental  Rl
report  and the Proposed Plan,  and to respond to questions and comments  from
area residents and  other  attendees.   A  Responsiveness Summary  is  part  of
this  ROD.

This  decision document   presents  the  selected remedial  actions  for  the
Woodland Township Route  532 and Route 72 sites,  chosen in accordance  with
the Comprehensive  Environmental Response,  Compensation,  and  Liability Act
(CERCLA),  as  amended by the Superfund  Amendments and  Reauthorization  Act,
and,  to  the  extent  practicable,  the  National  Oil and  Hazardous  Substances
Pollution  Contingency  Plan (NCP).  The  remedial action  decisions for these
sites  are  based on  the  administrative record.
SCOPE  AND ROLE OF  OPERABLE  UNIT

The remedial action described  in  the  May  1990  ROD was the  first  of two
planned  operable  units  for the  sites.   As discussed above,  the  first operable
unit action  was to  address  the  remediation of contaminated  surface  materials,
sediments  and  ground  water  at  the  sites.    The  excavation  and  off-site
disposal of the surface materials  and  sediments was completed  in the  Fall  of
1990.   The design  of  the ground water  remedy is  currently underway.   After
the  ROD  was  signed,  a study  was conducted  to  more  fully characterize  the
presence  and  extent of  contamination in the  subsurface  soils  (the  second
operable  unit).

Based   on  the  results  of  both  the  Rl   for  the   subsurface  soils  and risk
assessments performed for the sites,  no further action  is  necessary  for  the
second operable  unit.

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                                      -8-

SUMMARY OF SITE CHARACTERISTICS

The  supplemental Rl is  comprised  of  two rounds  of subsurface soil sampling.
The  locations of the sampling  are  shown  in  Figures 2  and 3.   A summary  of
the  subsurface  soil data  and  a  comparison  to the DEPE's proposed  cleanup
criteria  is presented in Tables  1  and  2.   Continuous  split spoon  samples were
collected  from  grade  until  the water table,  refusal (blow counts  exceeding
200) or  a  depth  of  20 feet,  whichever - came  first.   The  first round  of
sampling  was conducted  in  1991.   The samples  were collected  on a regularly
spaced  grid  (50  x  50  feet)  that  covered the  disturbed area of  both  sites.
The  sampling results  are  as follows:

Route  72

Two locations were identified.as  ha.v.incj .contaminants  exceeding  the  DEPE's
then proposed cleanup criteria  for  subsurface soils.  The  DEPE  determined  that
the  proposed cleanup criteria  were not applicable  or relevant and appropriate
requirements  for the Route  532  and Route  72  sites.   However, since the
proposed  cleanup criteria  were useful  in  evaluating  the sampling  results,  they
were regarded as  "to  be considered"  information.

At   one  location,   bis  (2-ethylhexyl)  phthalate,   xylenes,  and   clorobenzene
exceeded the  criteria;  the  other  location  had trichloroethene,  xylenes,  and
clorobenzene exceeding the  criteria.

Route  532

Four locations were identified  as  having  contaminants exceeding  the DEPE soil
cleanup criteria.   Three  locations contained  one  or  more  of  the  following
organic compounds:    bis  (2-chloroethyl)  ether,  carbon  tetrachloride,  1,2-
dichloroethane,  tetrachloroethene  and xylenes.   Zinc  exceeded  the proposed
soil  cleanup  criteria at one  location.

The  quantity of soil  exceeding the soil  cleanup criteria was estimated to  be
3,000  to 4,000 cubic yards  total for both sites.

The  second  round of sampling was  conducted  in  1993.  The  purpose  of this
effort  was  to further delineate the contaminated  areas  that  were identified  in
the  1991 sampling  round.    The  distance  between  soil  sampling locations
ranged from  10 to 35  feet depending on the  area  under  investigation.  The
results of the 1993  work are as  follows:

Route   72

Three  sample locations  were  identified as having  one  or  more  of  the following
compounds  exceeding soil  cleanup  criteria:  chlorobenzene,  styrene,  xylenes,
and  bis  (2-ethylhexyl)  phthalate.   The  volume  of  soil  exceeding the   criteria
is approximately 400  cubic yards.

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                                     -9-

Route  532

Two   sampling   locations   were   identified   as   having    xylenes   and
tetrachloroethene  at  concentrations exceeding  soil  cleanup  criteria.    The
estimated volume of soil  exceeding the criteria is  400  cubic  yards.

The  1993  subsurface soil sampling  program  better  delineated  the  extent of
residual  contamination at the two  sites.

SUMMARY OF SITE RISKS

A  risk  assessment  was  performed  to  evaluate  the  potential  risks  to  human
health  associated  with the Woodland Township Route  532 and  Route 72  sites
in  their  current state.    Because the  remedy  for  the surface" materials  and
sediments  has  already   been   implemented,  and   the   1990  ROD  included
remediation of  the  ground water  at  the  sites, the  risk  assessment evaluated
the potential  impacts associated with  the  subsurface soils.

To  evaluate human  health risks, a four-step process was  utilized  for assessing
site-related risks  for  a  reasonable maximum  exposure scenario.   These steps
are:  Hazard  Identification  -  identifies the contaminants of concern at  the  site
based  on  several  factors  such  as  toxicity,  frequency  of  occurrence,  and
concentration;   Exposure  Assessment -  estimates  the  magnitude  of actual
and/or potential human  exposures, the frequency and duration of these expo-
sures, and the pathways  (e.g.,  ingesting contaminated soil) by  which  humans
are  potentially  exposed;  Toxicity  Assessment  -   determines  the types of
adverse  health effects  associated  with exposures  to site contaminants,  and
the relationship between  magnitude of  exposure  (dose) and severity  of  adverse
effects  (response);  and  Risk   Characterization -  summarizes  and combines
outputs  of the exposure  and toxicity  assessments to provide  a quantitative
(e.g.,  one-in-a-million excess cancer risk)  assessment of site-related  risks.

The risk assessment began with selecting  contaminants of  concern  which
would be  representative  of  site risks.   These  contaminants  included  bis (2-
ethylhexyl)    phthalate,    DDT,    1,2-dichloroethane,    polycyclic   aromatic
hydrocarbons,  chlorobenzene,  ethylbenzene  and  zinc.    These  chemicals  of
potential concern are shown in Table  3. The concentrations of the chemicals
of  potential  concern  used in the risk  assessment  are shown  in  Tables 4  and
5.

The baseline  risk assessment evaluated the  health  effects which could result
if  a current  or future trespasser were exposed  to contamination as  a result
of  dermal  absorption  of  constituents following  dermal  contact,  incidental
ingestion  of  contaminants,  inhalation  of  volatile  organics, and  inhalation of
fugitive dusts.  The  assumptions used for each  exposure  pathway  are shown
in  Tables  6,  7 and  8.

For risk assessment purposes,  individual  contaminants are typically separated
into  two  categories  of  health  hazard  depending  on   whether  they  exhibit
carcinogenic  or noncarcinogenic effects.   Current federal  guidelines  for accept-
able  exposures are  an individual lifetime  excess carcinogenic risk in the  range
of  10"4  to  10"6, representing a probability of  approximately  one  in ten

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                                     -10-

thousand  to  one  in  one million  that an  individual  could develop  cancer due
to exposure.   The noncarcinogenic effects (e.g., systemic  effects)  posed by
each  contaminant  are  summarized as  a "Hazard  Index"  (HI) for a  particular
exposure  pathway.   The HI  compares  the chronic exposures to contaminants
within an exposure  pathway  to  their respective reference  doses, the reference
dose  being  a measure,  with many built-in safety factors, of a contaminant's
threshold  for causing toxicity.  Generally, only Hazard Indices greater than  1.0
are identified with potential adverse  health  effects.

The. results  of  the baseline risk assessment  indicate that,  for all  pathways
evaluated, the subsurface  soils  at the  site pose  an acceptable risk.   For  the
Route  72 site, the total carcinogenic risks  for  the  soil  pathway are 5.0x10'13
and   3.5x10'10  for  the  probable   and  worst   cases,   respectively.     This
carcinogenic risk  is well below the DEPE's target carcinogenic  risk of 1x10"6.
The  Hazard  Index was  estimated  to  be  0.003  for the most  probable case and
0.57  for  the  worst case.   Current  federal guidelines  for  acceptable  exposures
are a  maximum Hazard Index equal  to  1 .0.

For the Route  532  site, the total carcinogenic risks  for  the soil  pathway  are
2.9x10"12 and  2.6x10"10  for  the  most probable  and  worst cases,  respectiv^ly.-
The  total noncarcinogenic  hazard indices are 0.0067  for the  most  probable
case  and  0.061   for  the  worst  case.   As  with  the  Route  72  site,  the
carcinogenic  and  noncarcinogenic risks  are  well below the current federal  and
state  guidelines.   The hazard  indices  and  cancer  risks  associated with  the
potential  exposure pathways are presented  in Tables 9,  10, 11  and 12.
                          • -   .•*                              .»  •         .
The  procedures and  inputs  used to assess  risks in this  evaluation,  as  in  all
such  assessments, are subject to a  wide variety  of  uncertainties.   In  general,
the main sources  of uncertainty include:

•    environmental sampling and analysis;
•    environmental parameter measurement;
•    fate and  transport  modeling;
•    exposure  parameter  estimation; and
•    toxicological  data.

Uncertainty  in environmental sampling  arises  in  part  from   the  potentially
uneven distribution  of  chemicals  in the  medium  sampled.   Consequently, there
is significant  uncertainty  as to  the   actual  levels  present.    Environmental
sample analysis  error  can  stem  from  several  sources  including  the  errors
inherent  in  the  analytical  methods and  characteristics  of  the  matrix  being
sampled.

Uncertainties  in  the  exposure   assessment  are  related to   estimates  of how
often  an individual  would  actually come  in  contact  with  the  chemicals of
concern,  the period of  time over  which  such exposure  would occur, and  in
the  models  used  to  estimate the concentrations  of the  chemicals  of  concern
at the  point  of  exposure.

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                                     -11-

Uncertainties in toxicological data occur  in extrapolating  both  from animals to
humans  and  from  high  to  low  doses  of  exposure,  as  well  as from  the
difficulties  in  assessing  the  toxicity of a  mixture of  contaminants.    These
uncertainties  are  addressed  by  making  conservative  assumptions concerning
risk  and exposure parameters throughout  the  assessment.   As  a result, the
Risk Assessment  provides upper-bound estimates  of  the risks,  and  is  highly
unlikely  to  underestimate actual risks  related to the  site.

More  specific  information   concerning  public  health  risks,   including  a
quantitative evaluation of the degree of  risk associated  with various  exposure
pathways,  is  presented  in the Risk Assessment Addendum.

Ecological  risks were characterized  prior to  the May  1990  ROD.   Subsequent
to the  remedial action  in  1990, native vegetation  has grown  at the  sites.
Therefore,  it  is likely  that  the  presence  of contaminants  in  the subsurface
soils do not pose significant risks  to  this vegetation.

DISCUSSION OF THE "NO FURTHER ACTION"  REMEDY

The  DEPE  has  selected  "No Further Action" for the  subsurface  soils at both
sites because  of  the following:

•    Based  on  the  risk  assessment addendum,  no unacceptable  exposures  to
     hazardous  substances  contained  in  the  subsurface  soils  will occur under
     current or future use scenarios.  The  calculated carcinogenic risks were
     not  greater   than   the  DEPE's   acceptable  risk   of  1x10'6  or  EPA's
     acceptable risk  range  of  1x10"*  to  1x10's,  while  the   calculated non-
     carcinogenic  risk did not exceed  the  Hazard  Index of  1.0.

•    Soil flushing studies conducted  by Rutgers University  on  behalf  of  the
     PRPs  indicate  that the  soils at both  sites are amenable  to flushing.   It
     is  possible that the infiltration of  precipitation  may flush  the remaining
     volatile contaminants from  the  subsurface  soils;   these  contaminants (i.e.,
     xylenes,  tetrachloroethene,  and chlorobenzene)  would  be  captured and
     treated by the  ground  water treatment system.

•   The potential  exists for natural  processes  such   as  biotic  and  abiotic
     degradation,    flushing   and  volatilization to   reduce   the  low  level
     concentrations  of   contaminants  in the subsurface soil,  including  those
     exceeding  the  soil  cleanup criteria.   Two  sampling   locations at the  Route
     532 site had notable reductions in  the  level of  contaminants between  the
     1991   sampling  event  and  the  1993  sampling  event,  indicating  that
     natural processes  are  reducing the low level concentrations  remaining.

-------
                                     -12-
•    The no  further action with  monitoring  remedy  complies  with the DEPE's
     cleanup  criteria   through   natural  attenuation.     Although  hazardous
     substances are not  present above  health-based levels in the  subsurface
     soils,  the  DEPE has  decided to conduct monitoring and a  five-year review
     to  ensure that the  remedy  continues to be  protective of  human health
     and the environment.

In  summary,  the  DEPE and  EPA  believe  that  no remediation  of the  subsurface
soils  is necessary  to  ensure  protection  of human  health  and  the environment.

U.S.  EPA ACCEPTANCE

EPA concurs with  the  No Further Action remedy.  EPA's  letter of concurrence
is  attached to this ROD.

DOCUMENTATION  OF  SIGNIFICANT CHANGES

There  are  no  significant  changes  from  the  preferred  remedial  approach
presented  in the  Proposed Plan.

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                                   -13-
WOODLAND TOWNSHIP  ROUTE 532/WOODLAND TOWNSHIP  ROUTE 72  SITES
                      ADMINISTRATIVE  RECORD  FILE
                          INDEX OF  DOCUMENTS
1 .    Subsurface  Soil  Investigation, Route  72 and Route 532  Sites. Woodland
     Township.   Burlington   County.   New   Jersey.    prepared    by    EEC
     Environmental, Inc.,  November,  1992.

2.    Subsurface  Soil  Contaminant Characterization, Route 72  and  Route  532
     Sites,  Woodland  Township.  Burlington  County, New Jersey,  Volumes I  and
     ii,  prepared  by Harding Lawson Associates, May 18, 1993.

3.    Evaluation of Human Health Risk  Following  Soil Remediation at the  Route
     72 and  Route 532 Sites,  Woodland  Township,  Burlington  County,  New
     Jersey,  prepared  by ENVIRON Corporation, July,  1393.

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   SUPERFUND RECORD OF DECISION
WOODLAND TOWNSHIP SUPERFUND SITES
       WOODLAND TOWNSHIP
        BURLINGTON COUNTY
            NEW JERSEY
       ATTACHMENT 1 -  FIGURES

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 Route 532
                                ' Woodland
                                 Route 532
                                 Site
         Cranberry Bogs
Chatsworth
       Cranberry Bogs

         Cranberry Bogs
                                          Shoal Branch
         Dukes Bridge
                                                                            Woodland  /
                                                                            Route 72  /
                                                                            Site      /   Covle    ^   '
                                                                                   (     Air Field
                                                                                    XN^            /
Figure 1

SV.M|<:: I isu-li =- Approx. 3000 l\vt
                  Cranberry Bogs
                                                                                    Au-ii t'f l)L-l:iil

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   SUPERFUND RECORD OF DECISION
WOODLAND TOWNSHIP SUPERFUND SITES
       WOODLAND TOWNSHIP
        BURLINGTON COUNTY
            NEW JERSEY
        ATTACHMENT 2 - TABLES

-------

®||i;||f |ff |f| || |l||l|t
jmiMXiM TABLE
il!i;p:i;S01IL;-:SAMPLING
I
LOCATIONS


4Hipif If 11 IXCEEDING NJDEPE TBC CRITERIA1 (3/8/93)
'::X;-:.;:;;:- J4;¥££if: •£.& '^Wy^lf'?
Location Depth
Below
Grade
7NL-13 4-6'



7NL-13/10E 6-8'
7NL-I3/10S 6-8'


NOTES:
Concentrations for 7NIy-13/10S
and duplicate samples.
P^^^^.,^'.ROirrE:72
1'ai-umeter


bis'(2-ethylhexj-l)phthaljite
Chlorobenzene
Xylcne (ToLiI)
Styrenc
bis(2-ethylhexyl>phthalate
bis(2-ethylhexyl)phthalate
Chlorobcnzene
Xylene (Total)

SITE ' -:-:.'.'/:... •..--, •
Concentration T1{C
(ppm) Criteria
(ppm)
320 -4-;
4j I
40 10
46 23
81 49
205 49
1.5 1
20^ 10

"
TBC
Criteria
Applied
Residential
Ground Water
Ground Water
Residential
Residential
Residential
Ground Water
Ground Water

were detemiincd-liy calculating the average of the original



SOURCE: Harding Ijwson Associates (Project No. 19008)

-------
•B
i
I.
I
I
i
                                  i
                                  -   , •"- SOIL SAMPLING LOCATIONS' ?,"',
                                  EXCEEDING NJDEPE TBC CRITERIA (3/8/93)
                                   ,    ,  '  --;  -ROUTE532SITE:.
 Location   Depth          Parameter      Concentration   TBC         TBC
           Below                             (ppm)      Criteria      Criteria
           Grade                                       (pp
-------
Table 3 ': Substances or Concern for the Route 72 and Route 532 Sites
Public Health Evaluation
Substance
DEHP*
DDT
1,2,-dichloroethane
1,1,2,2-tetrachloroethane
PAHse
Cblorobenzene
Ethylbenzene
Lead
Route 72 Site
X
X
X

X
X
X
X
Route 532 Site
X
X

X


X
X
Notes:
• bis(2-etbylhexyl)phthalate
b DDT and its metabolites
c PAHs included the potential carcinogens benzo(a)pyrene, benzo(b)fluoranthene,
benzo(a)anthracene, indeno(1^3-cd)pyrene, and chrysene

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Table 4 : Exposure Point Concentration of Substances of Concern
In Surface Soil
Route 72 Site

Carcinogen
DDT*
PAHse
1,2-Dichloroethane
Chlorobenzene
Ethylbenzene
bis(2-ethylhexyl)phthalate
Lead
Zinc1
Pre-Remediation
Most
probable1*
concentration
(ug/kg)
4,008
1,770
291
5
5
13,645
184310
1,600,000
Worst case*
concentration
(ug/kg)
2,000,000
2,670
1,600
5
6
2,300,000
18,126,000
230,000,000
Post-Remediation* -
Most probableb
concentration
(ug/kg)
0.1
ND '
NDf
7.4
10.4
1,797
4,033"
35,020
Worst case*
concentration
(ug/kg)
13.8
ND
NDf
4,500
28,000*
320,000*
271,754b
345,000
Notes:
1 1991 and 1993 data combined
b Geometric mean concentrations used for most probable case
' Maximum concentrations used for worst case
d DDT metabolites include DDD and DDE geometric mean concentrations were summed to
represent the most probable concentration
* PAHs included in the study are the potential carcinogens benzo(a)pyrene
benzo(b)fluoranthene, benzo(a)anthracene, indeno(l,2,3-cd)pyrene, and chrysene
' No value exceeded the detection limit
1 Found at 6-8 feet in 1993
k Estimated using zinc percent reduction as a surrogate
' Included to estimate lead soil concentrations

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Table £ : Exposure Point Concentration or Substances of Concern
in Surface Soil
Route 532 Site

Carcinogen
DDT
1,1 ,2,2-tetrachloroethane
Ethylbenzene
bis(2-ethylhexyl)phthalate
Lead
Zinc1
Pre-Remediation
Most
probable1* .. .
concentration
(ug/kg)
5,148
-"76
9
10,710
94,210
290,000
Worst case*
concentration
(ug/kg)
412,000
100
19
300,000
1,323,000
610,000,000
Post-Remediation*
Most probable*
concentration
(ug/kg)
0.45
ND<
8
757
6,729f
20,730
Worst case'
concentration
(ug/kg)
4.4
NDe
32,000
55,000
37,930f
1,720,000
Notes:
• .1991 and 1993-data combined
b Geometric mean concentrations used for most probable case
' Maximum concentrations used for worst case
* DDT metabolites include DDD and DDE geometric mean concentrations were summed to
represent the most probable concentration
e No value exceeded the detection limit •
f Estimated using zinc .percent reduction as a surrogate
* Included to estimate lead soil concentrations

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Table 6 : Assumptions for Volatile Organics
Parameter
1. Frequency of contract
2. Breathing rate
3. Duration of exposure
4. Percent absorbance
• .*..•.
5. Body weight
Most Probable Case
2 hours/week for
10 weeks/year
1.7 m'/hour
6 years
100%
45kg
Worst Case
4 hours/week for
20 weeks/year
1.7 m3/hour
6 years
100%
45kg
Table "\ : Assumptions Used in Estimating Exposure
to Direct Contact with Contaminated Soils
Parameter
1. Frequency of contact
2. Duration of exposure
3. Average skin area over period of
exposure
4. Average weight over period of
exposure
5. Quantity of soil contacting skin per
exposure event
6. Direct application absorption rate
7. Incidental ingestion of
contaminated soil • * • ~-~
8. Percentage of ingested soil
absorbed
9. Exposure point concentration
Most Probable Case
2 hours/week for
10 weeks/year
6 years •
5,000cm2
45kg
2gm
12%/12 hours
50 mg/day
100%
Geometric mean
concentration
Worst Case
4 hours/week for
20 weeks/year
6 years
5,000cm2
45kg
10 gm
12%/12 hours
100 mg/day
100%
Maximum concentration

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Table & : Assumptions for Respirable Participate Exposure
Parameter
1. Breathing rate
2. Frequency of contact
3. Percent retention of particulates in
the lungs
4. Percent absorbance of contaminant
5. Duration of contact
Most Probable Case
1.7 mj/hour
2 hours/week for
10 weeks/year
30%
100%
6 years
Worst Case
1.7 mj/hour
4 hours/week for
20 weeks/year
75%
100%
6 years

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Table ^ : Risk Assessment for Potential Carcinogens
Route 72 Site
Substance
DDT
PAHs
DEHP
Total Soil
Derma]
• no&bw
N/A
-
N/A
—
Wont
N/A
-
N/A
—
Ingestioo
rnbabk
5.0E-13
N/A
N/A
5.0E-13
Went
3.5E-10
N/A
N/A
3.5E-10
Inhalation
VOCs
tabibk
N/A
N/A
N/A
—
Went
N/A
N/A
N/A
~
Inhalation
Particulates
i*«t»bk
5.0E-17
N/A
13E-13
1.4E-L5
Went
1.4E-13
N/A
2£E-13
4.2E-13
Total
rnbaUe



5.0E-13
Went



35E-10
- Not detected
Table to : Hazard Assessment for Noncarcinogens
Route 72 Site
Substance
Chlorobenzene
Ethylbeazene
Lead
Total
Dermal
Fratublc
2.1E-4
N/A
N/A
2.1E-4
Went
13E-1
N/A
N/A
13E-1
Ingestioo
Prabcbk
N/A
N/A
33E-3
33E-3
Wont
N/A
N/A
42E-1
4.2E-1
Inhalation
VOCs
rrabtbk
N/A
5.4E-7
N/A
5.4E-7
Went
N/A_
Z2E-2
N/A
12E-2
Inhalation
Particulates
PratuMc
N/A
N/A
7.7E-7
7.7E-7
Went
N/A
N/A
6.0E-4
6.0E-4
Total
Prabtblc



3JE-3
Kent



5.7E-1
— Not detected.

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Table // : Risk Assessment for Potential Carcinogens
Route 532 Site
Substance
DDT
UA2-TCE
DEHP
Total Soil
Dermal
totublc
N/A
N/A
3.0E-13
3.0E-13
Wont
N/A
N/A
L5E-10
1JE-10
Ingestion
Pnbtbk
2.6E-12
N/A
N/A
2.6E-12
Wont
1.1E-10
N/A
N/A
1.1E-10
Inhalation
VOCs
frabtbk
N/A
-
N/A
—
Went
N/A
-
N/A
—
Inhalation
Particulates
Prabobk
1.8E-16
N/A
43E-16
6.1E-16
Wont
4JE-14
N/A
2.6E-13
3.0E-13
Total
Muble



2.9E-12
Wont



2£E-10
- Not detected.
Table 12- :. Hazard Assessment for Noncarcinogens
Route 532 Site
Substance
Etbylbenzene
Lead
Total
Dermal
fnUbk
4.9E-9
N/A
4.9E-9
Worn
2.0E-4
N/A
2.0E-4
Ingestion
ProUblt
N/A
6.7E-3
6.7E-3
Wont.
N/A
6.0E-2
6.0E-2
Inhalation
VOCs
. Prabtbk
3.1E-7
N/A
3.1E-7
Wont
2.9E-4
N/A
Z9E-4
Inhalation
Particulates
Praiwbic
N/A
13E-6
13E-6
Wont
N/A
8.6E-5
8.6E-5
Total
rratuUe


6.7E-3
Went


6.1E-2
- Not detected.

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   SUPERFUND RECORD OF DECISION
WOODLAND TOWNSHIP SUPERFUND SITES
       WOODLAND TOWNSHIP
         BURLINGON  COUNTY
            NEW JERSEY
ATTACHMENT 3 -  RESPONSIVENESS SUMMARY

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                        RESPONSIVENESS SUMMARY .
   WOODLAND TOWNSHIP  ROUTE 532  AND ROUTE  72 SUPERFUND SITES
INTRODUCTION

This Responsiveness Summary  provides  a summary  of significant comments
received  from  the  public, regarding  the Proposed  Plan  for  the Woodland
Township Route 532 and  Route 72 Superfund sites.

The public  comment period  extended  from August 19, 1993 through September
17, 1993  to  provide  interested parties  the  opportunity to  comment on  the
Proposed  Plan  for the sites.   During the  comment  period,  the  New  Jersey
Department of Environmental Protection  and  Energy (NJDEPE)  held  a  public
meeting on August 31, 1993  at 7:00 PM at the Woodland Township Municipal
Building~'to discuss the results of the Remedial Investigation  for subsurface
soils and to  present the  preferred remedial alternative.

OVERVIEW

The preferred remedial alternative,  which was presented in the August 1993
Proposed Plan, addresses  the  subsurface  soils  with  the  recommendation  of  "No
Further Action*.   All  visibly  contaminated  surface  soils  have already been
excavated  from   both  sites  and  disposed  of  off-site  by  the  Potentially
Responsible Parties (PRPs) in  accordance with the 1990 Record  of  Decision
(ROD). The "No  Further  Action" with monitoring  remedy  for  the subsurface
soils  will  comply with NJDEPE cleanup  criteria through  natural  attenuation.
Infiltration  of  precipitation  may  flush  the remaining volatile contaminants from
the  subsurface  soil;  treatment  of  contaminated  ground   water,   another
component  of  the  1990  ROD,  is planned  for the future.   The engineering
design for this  system is currently underway.

One comment was  received   during  the public   comment  period  from  the
Pinelands Commission  supporting the  preferred remedial alternative presented
in the Proposed  Plan.  This comment  was based upon  the understanding  that
any degradation of  ground  water caused  by the flushing of contaminants  from
the subsurface  soils will  be  addressed  in the  proposed plan  for remediation
of ground  water.   With the Record  of Decision of which this  Responsiveness
Summary  is  a  part,  the preferred  remedial alternative  identified  in  the
Proposed Plan becomes the selected  remedy  for the sites.

BACKGROUND ON COMMUNITY INVOLVEMENT

Community interest  in  the  Woodland Township Route 532 and  Route  72 dump
sites  has been minimal since  the sites were placed on  the Superfund  National
Priorities List  in 1983.   Most likely, the low population  density in the  area
contributes to the  lack of citizen involvement  with  the sites.  There  is  only
one residence  in  the  immediate vicinity, although  there is evidence  of public
recreational activities.  (Footprints and tire tracks  from trail  motorcycles  have
been  found on  and around the sites.)   In  1986,  fences were erected  around
both  the  Route 532 and Route 72  sites  by the potentially responsible  parties
(PRPs) for the Woodland  sites.  Route  72 is heavily  traveled in the summer
months as an access  route to  the  New Jersey Shore  area but there is  minimal
local  traffic.  There were some complaints  of noxious  odors  during  the  1950s

-------
and  1960s when  waste disposal was being carried  out;  however,  there  has
only been one subsequent  complaint, also* of odors, in 1979.  Two reported
incidents  exist  of  residents wandering onto  the  sites  and requiring  medical
attention  as  a result  of  dermal contact with contaminated materials.   Local
and  county  officials  acted as the  primary  catalysts in bringing the sites to
the attention of the NJDEPE, initially requesting assistance in  sample analyses
and  visiting the sites with NJDEPE officials.

Some of the  key community issues  surrounding these sites include concern for
the  integrity of the  Cohansey  Sand  Aquifer,  the potential  for  surface  water
contamination  threatening a number of commercial cranberry bogs  in the area,
concern for endangered species such as the timber rattle snake and the corn
snake,  and  an  overall concern  for the ecology  of  the area as  part  of  the
significant New .Jersey  Pinelands  Preservation  Area  within  the  Pinelands
National Reserve.

Community  relations  activities conducted  for the Woodland  Township dump
sites to date  have included:

          NJDEPE preparation  of  a  Community Relations Plan (July  1984).

          NJDEPE conducted  a public meeting at'the Chatsworth  Fire  Hall to
          discuss  the initiation of the Remedial Investigation/Feasibility Study
          (RI/FS)  on  February 10,  1986.   Approximately  30 people attended,
          including local residents and officials.  PRP  representatives  and media
          representatives.

          NJDEPE  conducted potable well sampling  episodes in  1985 at the
          one  residence  located  in the immediate  vicinity of  the  sites  and
          again in June 1988 in the area  of  Dukes  Bridge.

          NJDEPE sampled  the  fall  cranberry  harvests in both 1988 and  1989
          with  the  assistance  of the Chatsworth Cranberry  Association  and
          Ocean Spray, Inc.

          NJDEPE  conducted  a  second  public   meeting   at  the  Chatsworth
          Elementary  School on  January  31, 1990 to  discuss  the  results  of
          the RI/FS  and the  preferred alternatives  preliminarily  selected by
          NJDEPE and USEPA  to  clean  up  the sites.   Approximately 35 people
          attended, including  local residents and  officials,  the  New Jersey
          Pinelands Commission's Executive Director and media representatives.
          A  transcript of  this  meeting,  -together  with  other  site-related
          documents  which are not enforcement-sensitive (e.g., RI/FS reports.
          Proposed  Plan) form the  administrative record, which  is available for
          public review at the following  information repositories:

      Woodland  Township  Municipal Building
      Main Street
      Chatsworth, NJ   08019

      New Jersey  Pinelands Commission
      P.O. Box  7.  Springfield  Road
      New Lisbon,  NJ  08064

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New Jersey Department of Environmental Protection and Ertergy
Division  of  Publicly Funded Site Remediation
401  East State Street
Trenton. NJ   08625

     In  June  1990,  the Woodland  Private Study  Group,  a  consortium
     comprising  of 3M,  Rohm  and Haas and  Hercules   Incorporated,
     prepared  the first  of several 'Woodland Sites Reports* serving as a
     community information newsletter.

     NJDEPE conducted  a  third public meeting  at  the  Woodland  Township
     Municipal  Building  on August 31,  1993 to discuss the results  of the
     remedial  investigation and the  preferred  alternative for remediation
     of  subsurface soils at the  sites.  The Township Engineer was the
     only person attending.  A transcript of this meeting, together with
     other site-related documents which  are not enforcement-sensitive, are
     available  for review at the  same  information  repositories  mentioned
     above.

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