Record of Decision White Swan Cleaners/Sun Cleaners Area Groundwater Contamination Superfund Site Wall Township Manasquan Borough Sea Girt Borough Monmouth County New Jersey


RECORD OF DECISION
White Swan Cleaners/Sun Cleaners Area Groundwater Contamination Superfund Site
Wall Township, Manasquan Borough, Sea Girt Borough
Monmouth County, New Jersey

United States Environmental Protection Agency
Region II
September 2013

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DECLARATION STATEMENT

RECORD OF DECISION

SITE NAME AND LOCATION

White Swan Cleaners/Sun Cleaners Area groundwater Contamination Superfund Site
Wall Township, Manasquan Borough, Sea Girt Borough
Monmouth County, New Jersey
EPA ID# NJSFN0204241

STATEMENT OF BASIS AND PURPOSE

This decision document presents the Selected Remedy for the contaminated soils and
groundwater at the White Swan Cleaners/Sun Cleaners Area Groundwater Contamination
Superfund Site (White Swan/Sun Cleaners Site) located in Wall Township, Sea Girt Borough
and Manasquan Borough, Monmouth County, New Jersey. The selected remedy was chosen in
accordance with the requirements of the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA), as amended, and to the extent practicable, the
National Oil and Hazardous Substances Pollution Contingency Plan (NCP). This decision is
based on the Administrative Record file established for this Site.

The New Jersey Department of Environmental Protection (NJDEP) concurs with the selected
remedy.

ASSESSMENT OF THE SITE

The response action selected in this Record of Decision (ROD) is necessary to protect public
health, welfare or the environment from actual or threatened releases of hazardous substances
into the environment.

DESCRIPTION OF THE SELECTED REMEDY

The Selected Remedy described in this document addresses soil, groundwater and sediment
contamination at the White Swan/Sun Cleaners Site.

The major components of the selected remedy include:

•	Excavation and off-Site disposal of contaminated soils at the White Swan Cleaners
source area;

•	In-situ soil vapor extraction/air sparging of soils and shallow groundwater at the Sun
Cleaners source area;

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•	Construction of a groundwater extraction and treatment system to capture and treat the
most highly contaminated groundwater at the Site;

•	Monitored natural attenuation for lesser contaminated groundwater;

•	Establishment of a Classification Exception Area, which is an institutional control, to
limit exposure to contaminated groundwater until groundwater meets the cleanup goals;
and

•	Indoor air monitoring of buildings in close proximity to groundwater contamination, and
installation of vapor mitigation systems, as necessary.

DECLARATION OF STATUTORY DETERMINATIONS

Part 1: Statutory Requirements

The Selected Remedy is protective of human health and the environment, complies with Federal
and State requirements that are legally applicable or relevant and appropriate to the remedial
action, and is cost-effective. EPA has determined that the Selected Remedy represents the
maximum extent to which permanent solutions and treatment technologies can be utilized in a
practicable manner at the Site.

Part 2: Statutory Preference for Treatment

The Selected Remedy meets the statutory preference for the use of remedies that involve
treatment as a principal element.

Part 3: Five-Year Review Requirements

Because this remedy will not result in hazardous substances, pollutants, or contaminants
remaining on-site above levels that allow for unlimited use and unrestricted exposure, but may
take more than five years to attain the remedial action objectives and cleanup levels for soil,
sediment and groundwater, a policy review may be conducted within five years of construction
completion at the Site to ensure that the remedy is, or will be, protective of human health and the
environment.

ROD DATA CERTIFICATION CHECKLIST

The following information is included in the Decision Summary section of this ROD. Additional
information can be found in the Administrative Record file for this Site.

•	Chemicals of concern and their respective concentrations may be found in the "Site
Characteristics" section.

•	Baseline risk represented by the chemicals of concern may be found in the "Summary of
Risks" section.

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Cleanup levels established for chemicals of concern and the basis for these levels can be
found in the "Remedial Action Objectives" section.

Current and reasonably anticipated future land use assumptions and current and potential

future uses of groundwater used in the baseline risk assessment and ROD can be found in

the "Current and Potential Future Site and Resource uses" section.

Estimated capital, operation and maintenance (O&M), and total present worth costs,

discount rate, and the number of years over which the remedy cost estimates are

projected can be found in the "Description of Alternatives" section.

Key factors that led to selecting the remedy may be found in the "Comparative Analysis

of Alternatives" and "Statutory Determinations" sections.

Walter E. Mugdan, Director
Emergency & Remedial Response Division
EPA-Region II

Date

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RECORD OF DECISION

DECISION SUMMARY

White Swan Cleaners/Sun Cleaners Area Groundwater Contamination Superfund Site
Wall Township, Manasquan Borough, Sea Girt Borough
Monmouth County, New Jersey

U.S. Environmental Protection Agency
Region II
New York, New York
September 2013

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Table of Contents

SITE NAME, LOCATION AND BRIEF DESCRIPTION	3

SITE HISTORY AND ENFORCEMENT ACTIVITIES	3

HIGHLIGHTS OF COMMUNITY PARTICIPATION	5

SCOPE AND ROLE OF THE RESPONSE ACTION	5

SUMMARY 01 SITE CHARACTERISTICS	6

CURRENT AND POTENTIAL FUTURE SITE AND RESOURCE USES	11

SUMMARY OF RISKS	11

REMEDIAL ACTION OBJECTIVES	 17

DESCRIPTION 01 ALTERNATIVES	18

COMPARATIVE ANALYSIS OF ALTERNATIVES	24

PRINCIPAL THREAT WASTE	31

SELECTED REMEDY	32

STATUTORY DETERMINATIONS	34

DOCUMENTATION OF SIGNIFICANT CHANGES	36

Appendices

APPENDIX I	Figures

APPENDIX II	Tables

APPENDIX III	Responsiveness Summary

APPENDIX IV Administrative Record Index
APPENDIX V	State Letter of Concurrence

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SITE NAME, LOCATION AND BRIEF DESCRIPTION

The White Swan Cleaners/Sun Cleaners Area Groundwater Contamination Site (White
Swan/Sun Cleaners Site, or Site), EPA ID# NJSFN0204241, is an area of soil and groundwater
contaminated with dry cleaning chemicals and/or their breakdown products in portions of three
municipalities: Wall Township, Manasquan Borough and Sea Girt Borough, New Jersey. The
Site includes two source areas located approximately 0.2 miles apart that contributed the same
contaminant, tetrachloroethylene (PCE), to the soils, sediments and groundwater. The former
White Swan Cleaners was located at 1322 Sea Girt Ave, Wall Township, N.J. and the former
Sun Cleaners was located at 2213 Route 35 (also known as Manasquan Circle) in Wall
Township.

Densely packed residential/commercial neighborhoods are located to the north, east and south of
the two former dry cleaners. To the west, there are mixed residential, commercial and rural areas.
According to the 2000 census, the population density of Wall Township and Sea Girt is 825 and
1,953 people per square mile, respectively. The Site covers approximately two and one half
square miles. The two former dry cleaners are located on either side of Route 35 and Manasquan
Circle, a heavily travelled highway system. The Site is bordered on the north by Hannabrand
Brook and Wreck Pond, which flow east into the Atlantic Ocean, a distance of approximately
two miles. To the southeast, the Site is bordered by Judas Creek, Mac Pond and Stockton Lake,
which also flow east into the Atlantic Ocean. Impacted groundwater in the vicinity of the Site is
utilized by many of the residents through shallow irrigation wells, but not as a potable water
supply. All of the Wall Township, Manasquan and Sea Girt residents in the Site area get their
drinking water from the public water supply which uses deep wells that are not impacted by the
Site contamination.

The U.S. Environmental Protection Agency (EPA) has been designated as the lead agency for
cleanup of the Site, with the New Jersey Department of Environmental Protection (NJDEP)
functioning in a support role. The remedial investigation at the Site has been conducted by a
potentially responsible party, Bank of America, who purchased the White Swan property through
a series of bank mergers and acquisitions.

SITE HISTORY AND ENFORCEMENT ACTIVITIES

The White Swan Cleaners and Sun Cleaners both operated from approximately 1960 through
1991. They both used the same chemical, tetrachloroethylene (aka PCE or Perc) as a dry
cleaning solvent and disposed of their used solvent on the ground or in their septic tanks, from
which it migrated to the groundwater. In the late 1990s, a resident of Magnolia Avenue notified
the Monmouth County Health Department (MCHD) that their private irrigation well contained
PCE. Subsequent sampling identified three irrigation wells containing PCE at levels up to 595
parts per billion (ppb). From 1997 to 1998, MCHD sampled an additional 29 irrigation wells
located east of Route 35, and found extensive PCE contamination, with levels of up to 1,100 ppb.
Subsequently, approximately 100 irrigation wells were sampled by MCHD and the NJDEP, and
levels of up to 1,648 ppb of PCE were detected.

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In 1999, MCHD sampled Hannabrand Brook and Wreck Pond and found PCE levels ranging
from 0.8 ppb to 16 ppb, in excess of the NJDEP Surface Water Quality Standard of 0.34 ppb for
PCE in fresh water. PCE was not detected in surface water to the south in Mac Pond and
Stockton Lake. In 2002, PCE was detected at 5 ppb in the surface water of Judas Creek near
Route 71. Subsequent surface water sampling in 2003 showed PCE at levels up to 996 ppb in
Judas Creek, east of the Sea Girt Mall.

PCE was not detected in the Sea Girt Municipal Wells initially. However, in late 1999, PCE was
detected at levels below the NJ groundwater quality criteria of 1 ppb at 0.63 ppb in one of the
municipal wells. Sea Girt installed an air stripper treatment system to remove volatile organic
compounds (VOCs) from the water prior to distribution.

In January 2000, soil samples were collected by NJDEP at the White Swan property at depths
ranging from 3.5 to 6.5 feet below ground surface (bgs). PCE was detected in samples up to
0.340 parts per million (ppm). Groundwater samples collected at the time indicated PCE at levels
of up to 670 parts per billion (ppb), TCE at levels of up to 97 ppb and DCE at levels of up to 25
ppb. NJDEP concluded that the White Swan property was a source of groundwater
contamination.

In 2001, NJDEP collected soil samples from the Sun Cleaners property that revealed the
presence of PCE at levels of up to 1,900 ppm. Groundwater sampling on the property showed
PCE at levels of up to 15,500 ppb. These data confirmed the Sun Cleaners property as a source
of groundwater contamination.

NJDEP determined that VOCs in the shallow groundwater might be volatilizing and entering the
unsaturated zone soils. These vapors could also be impacting the indoor air quality of buildings
in the vicinity of soil and groundwater contamination. NJDEP collected indoor air samples from
approximately 30 locations and found PCE present in some of the samples. As a result, NJDEP
requested EPA's assistance to evaluate the regional PCE contamination in December 2001.
EPA began an investigation of indoor air in late 2001 that included approximately 300 samples
from 220 locations. The sampling included homes, schools and businesses. As a result, vapor
mitigation systems were installed in six residences and two commercial properties. Additionally,
NJDEP continued to sample and install vapor mitigation systems in structures with PCE above
health based levels in indoor air. Eventually, a total of 29 buildings received systems during this
phase. Indoor air sampling continued while the remedial investigation was being conducted and
is ongoing. To date, a total of 34 vapor mitigation systems have been installed.

EPA conducted soil sampling at the White Swan and Sun Cleaners properties in early 2003. At
the White Swan property, the highest PCE soil concentration detected was 57 ppm located 20
feet below ground surface (bgs). At the Sun Cleaners property the highest PCE concentration
detected was 1,200 ppm, located 14 feet bgs.

The Site was proposed for the National Priorities List (NPL) on April 30, 2003 and was listed as
final on September 23, 2004.

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The Sun Cleaners property was owned and operated by Circle Dry Cleaning Corp from 1960 to
1982 when it was purchased by Anne E. Anton who re-sold it to Silvia Harte, aka Silvia
Biddelman (Kat-Sil Ltd.). She operated Sun Cleaners from 1982 through 1991 when it went into
bankruptcy. The property is currently owned by Marsha Danino, aka Royal Majestic Builders.
Bank of America (BOA) purchased the White Swan property through a series of bank mergers
and acquisitions. The White Swan Dry Cleaners was originally owned and operated by Harry B.
White from 1964 to 1982. He sold it to Charles Mahoney in May, 1982 and then it was
purchased by Ocean County National Bank (Summit Bank)in Sept, 1983. In 1986 the dry
cleaners ceased operations and the building was converted to a bank office.

ENFORCEMENT ACTIVITIES

To date, EPA has named one potentially responsible party (PRP) for Site contamination, BOA.
On September 21, 2006, EPA issued BOA an administrative order on consent that required it to
conduct a remedial investigation and feasibility study (RI/FS). Following review and approval
of the planning documents, the remedial investigation field activities began in August 2007. The
purpose of the investigation was to determine the nature and extent of contamination at the Site.
Soil, groundwater, surface water and sediment samples were collected and analyzed through
2008, 2009 and 2010. Most of the RI field work was completed by 2010. Subsequent to the
field operations, the remedial investigation report, risk assessment, and feasibility study
developed. Concurrent with this work, EPA performed extensive vapor investigations in and
under structures in proximity to the groundwater contaminant plume.

HIGHLIGHTS OF COMMUNITY PARTICIPATION

The RI/FS reports and the Proposed Plan for the Site were released to the public for comment on
August 19, 2013. These documents were made available to the public in the administrative
record file maintained at the Wall Township Public Library, Reference Section, 2700 Allaire
Road, Wall, N.J., and at the EPA Region II Records Center located at 290 Broadway, New York
City. The notice of availability for these documents was published in The Asbury Park Press on
August 20, 2013, and the Coast Star on August 22, 2013. A public comment period on these
documents was held from August 20, 2013 through September 19, 2013.

In addition, on August 27, 2013, a public meeting was conducted at the Wall Township
Municipal Center, 2700 Allaire Road, Wall, N.J. to discuss the findings of the RI/FS and to
present EPA's preferred alternative to local officials and the community. At this meeting, EPA
representatives presented the proposed cleanup plan and answered questions about all of the
remedial alternatives developed as part of the RI/FS. Comments which were received by EPA at
the public meeting and in writing during the public comment period are addressed in the
Responsiveness Summary (see Appendix III).

SCOPE AND ROLE OF THE RESPONSE ACTION

This action, or operable unit, is the first and only action planned for the Site. The action
addresses contaminated soils, groundwater, sediments and indoor air.

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SUMMARY OF SITE CHARACTERISTICS

In general, the topography in the area of the site is flat, but slopes gently toward the east. The
two dry cleaners were located on local high points approximately 44 to 47 feet above mean sea
level (msl) for the White Swan property and 46 to 51 feet above msl for the Sun Cleaners
property. Surface water infiltrates into the ground very rapidly due to the well-sorted sandy soil
on the Site. Approximately 20 inches of the 46 inches per year of annual precipitation penetrate
the ground to recharge the aquifer. The Sun Cleaners property has a steep slope to the west
where the headwaters of Judas Creek are located, but generally drains east into Judas Creek,
which is culvertized under Route 35 and the Sea Girt Mall. There are two well-defined overland
drainage pathways that border the north and south sides of the Site. They both flow from Route
35 east towards the Atlantic Ocean. On the north is Hannabrand Brook, which flows east into
Wreck Pond then into the Ocean. Wreck Pond is tidal.

Hannabrand Brook is a perennial (gaining) stream that accepts some flow from the shallow
groundwater as it flows east. On the south is Judas Creek, which flows out of the culvert from
under the Sea Girt Mall then east into Mac Pond then east into Stockton Lake. Judas Creek was
observed to be intermittent and partially dry between the Sea Girt Mall and Mac Pond. It is
contributing water to the shallow groundwater until it reaches Mac Pond. Manasquan pumps
"make-up" water from a deep well into Mac Pond to maintain its water level. Judas Creek flows
all year from Mac Pond to Stockton Lake. Stockton Lake is also tidal. Judas Creek may not be
intermittent during exceptionally wet years with higher amounts of precipitation.

There are several narrow and discontinuous wetlands located along Hannabrand Brook and Judas
Creek. Stockton Lake and Wreck Pond both have coastal wetland areas.

The Site is rural with heavily developed, densely packed residential and commercial
neighborhoods especially between Route 35 and the Atlantic Ocean. Residential and
commercial establishments in the Site area are serviced by municipal drinking water and sewer
service. City water service began in Wall Township in 1964 and sewer service began around
1984.

The White Swan/Sun Cleaners Site is approximately two square miles and contains
approximately 4,000 to 6,000 residents depending on the season. See Figure 1.

Geology

The site is located within the New Jersey Coastal Plain Physiographic Province. The Coastal
Plain geology is composed of a seaward (eastward) thickening wedge of unconsolidated
sediments, which ranges in thickness from zero feet on the northwestern margin of the Coastal
Plain to more than 6,000 feet at the Atlantic Ocean shoreline. The Coastal Plain strata in the Site
area strike northeast and dip gently to the southeast about 20 feet per mile.

The two significant formations at the site are the Cohansey Sand and the underlying Kirkwood
Formation of Miocene-Pliocene Age. The thickness of these two formations is over 130 feet in

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the Site area. They consist of alternating interbedded sand, gravel, silt and clay. The Cohansey
Formation is light-colored quartz sand containing minor amounts of pebbly sand, fine-to-coarse
grained sand, silty and clayey sand with interbedded clay. The Kirkwood Formation tends to be
finer grained and darker colored. Regionally, clay beds are found in the basal part of the
formation. The western part of the Site is underlain by the outcropping Cohansey Formation,
which is underlain by the lower Kirkwood member. The elevated topographic areas south of the
Sea Girt Mall, including the two former dry cleaners properties, which are sources of
groundwater contamination are presumed to be the edge or cap of the Cohansey Formation. To
the east of Route 35, the Kirkwood Formation is capped by thin (5' to 25') alluvial sand, gravel,
silt and clay stringers of the Cape May Formation. The majority of the saturated sediments
encountered in the sub-surface investigation consist of medium sands, silty sands, silts and clays.

The site investigation revealed a 30 to 50 foot thick low permeability unit across much of the site
that contains high levels of silt and some clay. This layer acts to hydraulically separate the
shallow, permeable sandy deposits from the deeper permeable deposits used by Sea Girt
Borough and other municipalities for their potable water supply. It was observed that there is
some porosity associated with the upper part of the inter-aquifer low permeability unit (IALPU),
as PCE contamination penetrated approximately 6 feet into the top. There was no contamination
found in the deep zone, under the IALPU. The top of the IALPU is 70 feet bgs in the western
part of the site and 50 feet bgs near the ocean.

The top of the water table, or saturated zone, is about 12 to 15 feet bgs. The regional
groundwater flow, or hydraulic gradient, across the Site is generally east towards the ocean. The
contamination from the two source areas flows east-northeast into a central mixing zone near Old
Mill Road and Laurel Ave, then part of the shallow contaminated groundwater flows northeast
into Hannabrand Brook and Wreck Pond, part flows to the southeast towards Judas Creek and
Stockton Lake, but the majority flows east to the Atlantic Ocean. The deeper zones flow almost
due east because they are not draining into the surface water bodies to the north and south.

The average lateral seepage velocity from west to east in the shallow and intermediate zones is
0.3 to 0.5 feet per day, whereas the downward vertical seepage velocity through the IALPU is
0.0006 ft/day, which is three orders of magnitude lower.

SOIL CONTAMINATION
White Swan Soils

In 2001, the PRP excavated the septic tank, associated piping and some contaminated soil from
the White Swan property parking lot. Approximately 20 tons of soil were excavated and
transported off-Site to a licensed facility for disposal. However, significant soil contamination
remains at the property, to a depth of 25 feet bgs, which is 10 feet below the water table. During
the remedial investigation, a total of 52 soil samples were collected from 13 borings in 2008. In
2009, 16 additional subsurface soil samples were collected from 10 additional borings. Soil
samples from the unsaturated zone below the asphalt pavement at the White Swan property
showed PCE contamination at levels ranging from 1 ppm to a maximum of 160 ppm at a depth
of 0-7 feet bgs. The levels of PCE in soils just below the water table were up to 28,000 ppm (17 -

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25 feet bgs). PCE mass in the soils at the White Swan property is estimated to be approximately
4,360 pounds. Maximum TCE and cis-1, 2, DCE levels on the property are 32 ppm and 37 ppm
respectively. (See Table 1).

Sun Cleaners Soils

At the Sun Cleaners property, a total of 48 subsurface soil samples from 13 soil borings were
collected in 2008. PCE contamination in the unsaturated zone soils at the Sun Cleaners property
was found to be as high as 51 ppm (at a depth of 6 to 13 feet bgs) with a total PCE soil mass of
approximately 140 pounds. The maximum TCE level was 3.8 ppm and the maximum cis-1,2,
DCE level was 31 ppm. These levels were notable lower than levels detected prior to the RI in
2000. (See Table 2)

Surface Water and Sediments

NJDEP surface water samples from 2003 showed levels of PCE at 996 ppb in Judas Creek east
of the Sea Girt Mall near Sea Girt Ave. These levels were above the NJ surface water quality
standard of 0.34 ppb in fresh water. In 2008, RI surface water samples collected 500 feet
downgradient showed significantly lower levels of PCE at 31 ppb, 13 ppb, 6.3 ppb, 4.1 ppb, 12
ppb and 13 ppb, between Mac Pond and Stockton Lake.

Judas Creek sediment samples showed PCE at 4.4 ppm near Manasquan High School and 0.79
ppm and 0.81 ppm near Route 71. These are above the site specific NJDEP ecological screening
criteria of 0.45 ppm for sediments.

In 2000, in Hannabrand Brook, NJDEP found PCE at 1 ppb in surface water near St. Catherine's
Cemetery and 2 ppb in Wreck Pond. During the RI, PCE was found at 1.1 ppb in the unnamed
tributary surface water that feeds into Hannabrand Brook and up to 5.9 ppb in the surface water
of Hannabrand Brook itself. Wreck Pond surface water showed PCE levels up to 0.25 ppb
(estimated) at the Route 71 Bridge.

PCE was found at 0.21 ppm in the Hannabrand Brook sediments near St. Catherine's Cemetery.
Sediments in the unnamed tributary had PCE levels as high as 1.8 ppm and 4.1 ppm (estimated)
in Hannabrand Brook. (See Tables 3, 4, 5, 6 for a summary of surface water and sediment data)

Groundwater Contamination

Field investigations began in 2007. In order to begin to characterize the contamination, 21
Membrane Interface Probe (MIP) penetrations were completed at the White Swan property and

18 were completed at the Sun Cleaners property. 91 groundwater samples were collected from

19 temporary well locations at the White Swan property. At the Sun Cleaners property, 136
groundwater samples were collected from 17 temporary well locations.

The regional groundwater investigation to determine the nature and extent of the Site-wide
groundwater contaminant plume started with 525 MIP penetrations, followed by 512
groundwater samples from 169 temporary well locations in phase one. The second phase of the

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investigation took place in 2009, and included the collection of 31 groundwater samples from 10
temporary well locations. Based on the findings of widespread groundwater contamination
through the use of temporary wells, 60 permanent monitoring wells were installed in 21
locations. Six piezometers and six stream gauges were installed to define the groundwater flow
direction. The monitoring wells were sampled in April and May 2009, September through
November 2009, and in March 2010. (See Table 7)

The findings of the study indicated that the contaminants of concern at the Site are primarily
PCE and its associated breakdown products, trichloroethene (TCE) and cis-l,2,-dichloroethene
(DCE) and vinyl chloride. During the RI, PCE was found in groundwater as high as 75,000 ppb
underlying the White Swan property and 61,000 ppb underlying the Sun Cleaners property.

PCE and its breakdown products continue to migrate in groundwater from the two source areas
located near Route 35 eastward toward the Atlantic Ocean, approximately two miles away.

There are narrow contaminant plumes emanating from the two source areas. These two
contaminant plumes join and mix in an area underlying Old Mill Road and Laurel Ave. The
joined contaminant plume then expands laterally as it moves generally eastward. The
contaminant plume is bounded by and discharges to local surface water bodies to the north and
south including: Hannabrand Brook, Wreck Pond, Judas Creek and Stockton Lake, and also the
Atlantic Ocean. Although there is movement of contamination within the plume, these
boundaries are considered stable. The PCE contamination within the groundwater generally
sinks deeper as it proceeds to the east, but was not found below the IALPU around 75 feet bgs.
The total PCE mass in the plume is estimated to be 4,730 pounds across the entire Site.

The areas of the plume in close proximity and downgradient of the two source areas that contain
the highest levels of groundwater contamination are referred to as the Near Field areas, and
generally contain concentrations of PCE over 1,000 ppb. The Near Field areas include
groundwater underlying the Sun Cleaners property and extending over 1,000 feet downgradient,
and groundwater underlying the White Swan property and extending approximately 700 feet
downgradient. The remainder of the groundwater plume is referred to as the Far Field. The Far
Field area of groundwater contamination generally includes areas where PCE has been detected
between the levels of 1 ppb and 1,000 ppb. However, within the large Far Field area, there are a
number of "hot spots", which are smaller localized areas of PCE contamination near 1,000 ppb
or greater. (See Figures 2 and 3)

The groundwater investigation included a Dense Non Aqueous Phase Liquids (DNAPL) Source
Assessment. A DNAPL source may be present if the ground water concentrations of a
contaminant exceed 1% of its solubility. In the case of PCE, 1% of its solubility (206,000 ppb)
is 2,060 ppb. The White Swan source area had PCE at levels up to 75,000 ppb and the Sun
Cleaners had PCE levels up to 61,000 ppb. However, DNAPL was not observed in any of the
groundwater samples or soil borings. The same is true for TCE and DCE; while the
concentrations in groundwater were well over 1% of their solubilities, no DNAPL was observed
during the RI.

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Monitored Natural Attenuation Evaluation

During the three rounds of groundwater sampling conducted at the site, natural attenuation
indicator parameters analyzed for included: oxidation reduction potential, dissolved oxygen,
temperature, pH, specific conductivity, ferrous ion, carbon dioxide, cations (sodium, potassium,
calcium, magnesium), anions (chloride, sulfate, nitrate, alkalinity), methane, ethane, ethene, total
organic carbon, total dissolved solids, total suspended solids, total Kjeldahl Nitrogen, ammonia
and nitrate/nitrite.

Monitoring well analytical and geochemical data obtained during the RI suggest that because of
the high lateral hydraulic conductivity and generally aerobic nature of the unconfined aquifer,
contaminant migration dominates and there is limited natural degradation of VOCs. However,
elevated levels of TCE and c-DCE were found within the plume, indicating that some reductive
dechlorination is occurring across the plume. The low organic content of the mostly sandy
aquifer means that sorption rates are low and the contaminants move with the groundwater flow.
Dilution and dispersion of contamination are prevalent, as contaminated groundwater comes in
contact with large volumes of uncontaminated water moving through the aquifer. Adsorption
occurs when contaminants attach to the soil particles and when dissolved chemicals in
groundwater are removed from solution. Because of the low site-specific dispersion coefficient,
adsorption rates are low and the contaminant mass moves at essentially the same rates as the
linear groundwater velocity. The dominant natural attenuation processes within the Site aquifer
are dilution and dispersion. In addition, as evident from indoor air investigations at the Site,
some volatilization is occurring.

Indoor Air

In the vicinity of the shallow groundwater contamination, VOCs may escape or volatilize from
the groundwater and permeate the unsaturated zone soils. This vapor can penetrate basement
walls and floors in occupied dwellings. EPA has sampled the sub-slab air and/or indoor air of
over 400 residences and commercial buildings in order to evaluate this exposure pathway and
will continue to sample buildings in the vicinity of the contamination to assess the potential risk
to occupants. The highest level of PCE vapor in sub-slab air was found to be 9,500 |ig/m3 below
a residence near Christie Lane and Sea Girt Ave. To date, thirty-four vapor mitigation systems
have been installed by EPA and NJDEP in buildings where indoor air PCE levels exceeded
health based levels. The systems are designed to vent vapors from beneath the foundation,
thereby preventing vapors from entering the building. These systems are monitored to ensure
they are performing properly. Sampling of residences and buildings overlying the groundwater
plume will continue. Additional vapor mitigation systems will be installed, as needed, to prevent
unacceptable risks to occupants of buildings in accordance with NJDEP/EPA protocol.

Summary

Based upon a review of all data generated during the RI/FS, it is apparent that VOCs, primarily
PCE, are the primary contaminants of concern at the Site. The data indicates that soils in the two
source areas (the White Swan and Sun Cleaners properties) contain elevated levels of PCE. It is
evident that these two source areas contributed significant amounts of PCE to the aquifer and are

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a continuing source of groundwater contamination at the Site. The PCE contamination
originating at the two source areas migrates and dissolves in the groundwater and then flows to
the east-northeast into a central mixing zone near Old Mill Road and Laurel Ave, then part of the
shallow contaminated groundwater flows northeast into Hannabrand Brook and Wreck Pond,
part flows to the southeast towards Judas Creek and Stockton Lake, but the majority flows east to
the Atlantic Ocean. Sediment contamination in Hannabrand Brook was detected and is resulted
from the discharge of the plume to that water body. The deeper zones flow almost due east
because they are not draining into the surface water bodies to the north and south.

The plume of VOC contamination is approximately one mile wide and two miles long. As this
groundwater contamination moves eastward, it moves downward toward a low permeability
layer and spreads laterally. Although the contamination penetrates into the top five feet of the
low permeability layer, it was not found below it.

Chemical and geochemical data collected at the Site provide strong evidence that natural
attenuation of VOC contamination is occurring in groundwater. The primary mechanism of
attenuation is dispersion and dilution. However, without remediation to address highly elevated
levels of VOC contamination in the source areas, as well as the areas of highest groundwater
contamination, restoration of the aquifer would take over 400 years.

Volatilization of PCE and TCE is occurring from the shallow groundwater, and vapor phase PCE
is entering the air spaces within the soil vadose zone, especially in the areas of the plume with
high levels of PCE contamination. Elevated levels of PCE in the vapor phase are accumulating
under some building slabs and are migrating into indoor air. To date, 34 out of approximately
450 structures sampled required the installation of vapor mitigation systems. These structures
are generally located above the most highly contaminated areas of the groundwater plume.

CURRENT AND POTENTIAL FUTURE SITE AND RESOURCE USES

Land Uses: Currently, both of the Site source properties are located in mixed
residential/commercial areas in a densely populated part of Wall Township. Therefore, future
residential and commercial use of these sites is anticipated.

Ground and Surface Water Uses: Groundwater is classified as IIA, a drinking water aquifer.
Groundwater in the vicinity of the Site contamination is only being used for irrigation purposes.
Residences and businesses in the immediate vicinity of the Site are connected to municipal water
supplies. The groundwater contaminant plume may continue to migrate and threaten additional
irrigation wells located downgradient of the site.

Residents and seasonal visitors may use the surface water bodies for fishing, swimming, boating
and other forms of recreation.

SUMMARY OF RISKS

As part of the RI/FS, EPA conducted a baseline risk assessment to estimate the current and
future effects of contaminants on human health and the environment. A baseline risk assessment
is an analysis of the potential adverse human health and ecological effects of releases of

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hazardous substances from a site in the absence of any actions or controls to mitigate such
releases, under current and future land uses. The baseline risk assessment includes a human
health risk assessment and an ecological risk assessment. It provides the basis for taking action
and identifies the contaminants and exposure pathways that need to be addressed by the remedial
action. The remedial alternative that was chosen for the site addresses contamination at the site.
The risks and hazards for the site was presented in the baseline risk assessment will be
summarized in this section.

Human Health Risk Assessment

A four-step process is utilized for assessing site-related human health risks for a reasonable
maximum exposure scenario: Hazard Identification - uses the analytical data collected to
identify the contaminants of potential concern at the site for each medium, with consideration of
a number of factors explained below; Exposure Assessment - estimates the magnitude of actual
and/or potential human exposures, the frequency and duration of these exposures, and the
pathways (e.g., ingesting contaminated well-water) by which humans are potentially exposed;
Toxicity Assessment - determines the types of adverse health effects associated with chemical
exposures, 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 assessment of site-related risks. The
risk characterization also identifies contamination with concentrations which exceed acceptable
levels, defined by the National Contingency Plan (NCP) as an excess lifetime cancer risk greater
than 1 x 10"6 - 1 x 10"4, an excess of lifetime cancer risk greater than 1 x 10"6 (i.e., point of
departure) combined with site-specific circumstances, or a Hazard Index greater than 1.0;
contaminants at these concentrations are considered chemicals of concern (COCs) and are
typically those that will require remediation at the Site. Also included in this section is a
discussion of the uncertainties associated with these risks.

Hazard Identification

In this step, the chemicals of potential concern (COPCs) in each medium were identified based
on such factors as toxicity, frequency of occurrence, fate and transport of the contaminants in the
environment, concentrations, mobility, persistence, and bioaccumulation. The risk assessment
focused on groundwater, soil, surface water and sediments associated with the White Swan/Sun
Cleaners groundwater plume to determine if the media may pose significant risk to human
health. Analytical information that was collected to determine the nature and extent of
contamination revealed the presence of volatile organic compounds, specifically cis-1,2-
dichloroethlyene, tetrachloroethylene, trichloroethylene and vinyl chloride, in the shallow
groundwater at concentrations of potential concern.

A comprehensive list of all COPCs can be found in the BHHRA, entitled "Final Baseline Human
Health Risk Assessment White Swan Cleaners/Sun Cleaners Area Groundwater Contamination
Superfund Site Wall Township, Monmouth County, New Jersey" (June 2012). This document is
available in the Administrative Record file. This Record of Decision (ROD) focuses on a site-
wide evaluation, which includes the groundwater, soil and surface water and sediment that
receive groundwater discharge (i.e., Wreck Pond, Mac Pond, Stockton Lake, Hannabrand Brook

12

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and Judas Creek). The contaminated media, concentrations detected, and concentrations utilized
to estimate potential risks and hazards for the COCs at the Site are presented in Table 8.

Exposure Assessment

Consistent with Superfund policy and guidance, the BHHRA is a baseline human health risk
assessment and therefore assumes no remediation or institutional controls to mitigate or remove
hazardous substance releases. Cancer risks and noncancer hazard indices were calculated based
on an estimate of the reasonable maximum exposure (RME) expected to occur under current and
future conditions at the site. The RME is defined as the highest exposure that is reasonably
expected to occur at a site. For those contaminants for which the risk or hazard exceeded the
acceptable levels, the central tendency estimate (CTE), or the average exposure, was also
evaluated.

Exposure pathways were identified for each potentially exposed population and each potential
exposure scenario for exposure to groundwater, soil, surface water and sediment. Exposure
pathways assessed in the BHHRA are presented in Table 9 and included exposure to
groundwater for residents, surface and subsurface soil for construction workers, utility workers
and resident/transient visitors, and surface water and sediment for transient visitors. Completed
pathways were evaluated for incidental ingestion, dermal contact, and inhalation. Typically,
exposures are evaluated using a statistical estimate of the exposure point concentration, which is
usually an upper-bound estimate of the average concentration for each contaminant, but in some
cases may be the maximum detected concentration. A summary of the exposure point
concentrations for the COCs in groundwater can be found in Table 8, while a comprehensive list
of the exposure point concentrations for all COPCs can be found in the BHHRA.

Toxicity Assessment

Under current EPA guidelines, the likelihood of carcinogenic risks and noncancer hazards due to
exposure to site chemicals are considered separately. Consistent with current EPA policy, it was
assumed that the toxic effects of the Site-related chemicals would be additive. Thus, cancer and
noncancer risks associated with exposures to individual COPCs were summed to indicate the
potential risks and hazards associated with mixtures of potential carcinogens and
noncarcinogens, respectively.

Toxicity data for the human health risk assessment were provided by the Integrated Risk
Information System (IRIS) database, the Provisional Peer Reviewed Toxicity Database
(PPRTV), or another source that is identified as an appropriate reference for toxicity values
consistent with EPA's directive on toxicity values. This information for the COCs is presented
in Table 10 (noncancer toxicity data summary) and Table 11 (cancer toxicity data summary).
Additional toxicity information for all COPCs is presented in the BHHRA.

Risk Characterization

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Noncarcinogenic risks were assessed using a hazard index (HI) approach, based on a comparison
of expected contaminant intakes and benchmark comparison levels of intake (reference doses,
reference concentrations). Reference doses (RfDs) and reference concentrations (RfCs) are
estimates of daily exposure levels for humans (including sensitive individuals) which are thought
to be safe over a lifetime of exposure. The estimated intake of chemicals identified in
environmental media (e.g., the amount of a chemical ingested from contaminated drinking water)
is compared to the RfD or the RfC to derive the hazard quotient (HQ) for the contaminant in the
particular medium. The HI is obtained by adding the hazard quotients for all compounds within
a particular medium that impacts a particular receptor population.

The HQ for oral and dermal exposures is calculated as below. The HQ for inhalation exposures
is calculated using a similar model that incorporates the RfC, rather than the RfD.

HQ = Intake/RfD

Where: HQ = hazard quotient

Intake = estimated intake for a chemical (mg/kg-day)

RfD = reference dose (mg/kg-day)

The intake and the RfD will represent the same exposure period (i.e., chronic, subchronic, or
acute).

As previously stated, the HI is calculated by summing the HQs for all chemicals for likely
exposure scenarios for a specific population. An HI greater than 1.0 indicates that the potential
exists for noncarcinogenic health effects to occur as a result of site-related exposures, with the
potential for health effects increasing as the HI increases. When the HI calculated for all
chemicals for a specific population exceeds 1.0, separate HI values are then calculated for those
chemicals which are known to act on the same target organ. These discrete HI values are then
compared to the acceptable limit of 1.0 to evaluate the potential for noncancer health effects on a
specific target organ. The HI provides a useful reference point for gauging the potential
significance of multiple contaminant exposures within a single medium or across media. A
summary of the noncarcinogenic hazards associated with these chemicals for each exposure
pathway is contained in Table 12.

It can be seen in Table 12 that the HI for noncancer effects is elevated for exposure to
groundwater that may be used in the future for potable uses and showering under a residential
setting.

For carcinogens, risks are generally expressed as the incremental probability of an individual
developing cancer over a lifetime as a result of exposure to a carcinogen, using the cancer slope
factor (SF) for oral and dermal exposures and the inhalation unit risk (IUR) for inhalation
exposures. Excess lifetime cancer risk for oral and dermal exposures is calculated from the
following equation, while the equation for inhalation exposures uses the IUR, rather than the SF:

Risk = LADD x SF

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Where: Risk = a unitless probability (1 x 10"6) of an individual developing cancer

LADD = lifetime average daily dose averaged over 70 years (mg/kg-day)

SF = cancer slope factor, expressed as [1/(mg/kg-day)]

These risks are probabilities that are usually expressed in scientific notation (such as 1 x 10"4).
An excess lifetime cancer risk of 1 x 10"4 indicates that one additional incidence of cancer may
occur in a population of 10,000 people who are exposed under the conditions identified in the
assessment. Again, as stated in the NCP, the point of departure is 10"6 and the acceptable risk
range for site-related exposure is 10"6 to 10"4.

A summary of the estimated cancer risks are presented in Table 13. The results indicated that
there are elevated cancer risks for future residents that may use the groundwater for potable
purposes and for showering.

Vapors

The potential for vapor intrusion into a building's indoor air is being addressed through an
ongoing EPA sampling program. The investigation includes collection and analysis of sub-slab
air samples, and indoor air samples in structures overlying the groundwater contaminant plume.
Levels of contaminants are compared to health-based standards for each structure. Where
health-based standards are exceeded, vapor mitigation systems have been installed. Sampling is
ongoing throughout the area overlying the plume, and additional indoor air ventilation systems
will be installed, as needed, to prevent unacceptable risk to occupants of the buildings.

Therefore, a quantitative risk analysis was not needed.

The evaluation of potential outdoor vapor exposure to residents, commercial customers,
commercial workers and construction workers indicated that the pathway was incomplete.
Therefore a quantitative analysis was not needed.

Uncertainties

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 chemistry sampling and analysis
environmental parameter measurement
fate and transport modeling
exposure parameter estimation
toxicological data

Two of the primary sources of uncertainty identified in the HHRA were associated with exposure
assessment. The risk assessment assumed exposure to groundwater without treatment. This is a
hypothetical scenario as the community is served by municipal water supplies that meet State
and Federal drinking water standards. In addition, for some compounds, the statistical method

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that was used to derive the exposure point concentration indicated that the estimated value may
not be reliable and for some compounds the maximum detected concentration was used. These
uncertainties may have resulted in over- or under-estimation of the actual risk. More specific
information concerning uncertainty in the health risks is presented in the baseline human health
risk assessment report.

Ecological Risk Assessment

A screening-level ecological risk assessment was conducted to evaluate the potential for
ecological effects from exposure to the presence of elevated VOCs in ground water that
discharges to surface water and sediments associated with the Hannabrand Brook and Judas
Creek stream systems. The SLERA focused on evaluating the potential for impacts to sensitive
ecological receptors from Site-related contaminants of concern through exposure to surface
water and sediment from Wreck Pond, Hannabrand Brook, and Judas Creek, which includes Mac
Pond and Stockton Lake. Surface water and sediment concentrations were compared to
ecological screening values as an indicator of the potential for adverse effects to ecological
receptors for each water body system. A complete summary of all exposure scenarios can be
found in the SLERA.

Hannabrand Brook System: There is a potential for adverse effects to fish and aquatic
invertebrates from exposure to contaminated groundwater that is discharging to Hannabrand
Creek. The sediment screening criteria were exceeded for PCE in three locations, resulting in
hazard indices (His) of 9.1, 4 and 1.4, which are above the acceptable value of 1. The calculated
His for these three samples were reduced to 4.1, 1.8 and 0.7 when more appropriate screening
values were used (i.e., freshwater criteria instead of salt water criteria). The PCE detections in
the sediment are considered to be site-related. The surface water screening criteria was not
exceeded for Hannabrand Brook.

Judas Creek System: There is a potential for adverse effects to aquatic fish and invertebrates
from exposure to contaminated groundwater that may be discharging to Judas Creek. The
sediment screening criteria were exceeded for PCE in two locations, resulting in His of 9.8 and
1.8, which are above the acceptable value of 1. The calculated His for these two samples were
reduced to 4.4 and 0.8 when more appropriate screening values were used (i.e., freshwater
criteria instead of salt water criteria). However, the PCE detections in the sediment may be
associated with runoff from an industrial area instead of groundwater discharge. The surface
water screening criteria was not exceeded for Judas Creek.

Based on the results of the ecological risk assessment a remedial action is necessary for
Hannabrand Brook to protect the environment from actual or threatened releases of hazardous
substances.

Risk Assessment Summary

In summary volatile organic compounds, specifically cis-l,2-dichloroethylene,
tetrachloroethylene, trichloroethylene, and vinyl chloride, in shallow groundwater associated
with White Swan/Sun Cleaners contributed to unacceptable risks and hazards to future residents,

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as well as to ecological receptors in Hannabrand Brook. It is EPA's judgment that although the
risks associated with soil exposure at the source areas are within or below EPA's acceptable
values, the soil concentrations of PCE and TCE are above concentrations that are associated with
an adverse impact to groundwater, thus there is a need to address the soil through a remedial
action.

Based on the results of the human health and ecological risk assessments, the response action
selected in the Record of Decision is necessary to protect the public health or welfare of the
environment from actual or threatened releases of contaminants into the environment.

REMEDIAL ACTION OBJECTIVES

Remedial action objectives are specific goals to protect human health and the environment.

These objectives are based upon available information and standards such as applicable or
relevant and appropriate requirements (ARARs) and risk-based levels established in the risk
assessment.

The following remedial action objectives (RAOs) for contaminated soil and groundwater address
the human health risks and environmental concerns at the site:

•	Prevent or minimize current and future human exposures, including ingestion of
groundwater and/or inhalation of vapors, from Site-related VOCs in groundwater that
present a risk to public health and the environment;

•	Prevent or minimize migration of Site-related soil contamination to groundwater;

•	Restoration of the Site groundwater to meet drinking water standards within a reasonable
time frame; and

•	Prevent or minimize the migration of Site-related contaminated groundwater to surface
water and sediment that presents a risk to the environment.

To achieve these RAOs, cleanup goals for both unsaturated zone soil and groundwater at the site
were identified.

The remediation goal for soil was derived considering both New Jersey's Residential Direct
Contact Soil Remediation Standard of 2 ppm for PCE in soil, as well as the protection of
groundwater. To derive a cleanup goal to protect groundwater, the SESOIL model was used and
supports a goal of 1 ppm for PCE. To ensure both protection of public health and protection of
groundwater from contribution of PCE from soils, the lower of these two numbers, 1 ppm for
PCE, has been selected for soils at the Site. Considering distribution of all contaminants in the
soil, it is believed that remediating soil to meet the 1 ppm goal for PCE will also address all other
contaminants in soils to acceptable levels. It is estimated that a total of 5,100 cubic yards of soil
at the White Swan source area and 9,600 cubic yards of soil at the Sun Cleaners source area
exceed the 1 ppm remediation goal for PCE.

17

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Cleanup goals for groundwater are the New Jersey Class II-A Ground Water Quality Criteria.
For the primary contaminants of concern at the Site, these standards include: 1 ppb for PCE; 1
ppb for TCE and 70 ppb for DCE.

DESCRIPTION OF ALTERNATIVES

The Comprehensive Environmental Response, Compensation and Liability Act (CERCLA)
requires that each remedial alternative be protective of human health and the environment, be
cost effective, comply with other statutory laws, and utilize permanent solutions and alternative
treatment technologies and resource recovery technologies to the maximum extent practicable. In
addition, the statute includes a preference for the use of treatment as a principal element for the
reduction of toxicity, mobility or volume of hazardous substances. Consistent with expectations
set out in the Superfund regulations, none of the remedies rely exclusively on institutional
controls to achieve protectiveness. Potential applicable technologies were identified and
screened using effectiveness, implementability and cost as the criteria, with the most emphasis
on the effectiveness of the remedial technology. Those technologies that passed the initial
screening were then assembled into two remedial alternatives for soil contamination and five
remedial alternatives for groundwater contamination.

All of the groundwater remedial alternatives, with the exception of the No Action Alternative
(Alternative 1), would include institutional controls (Classification Exception Area (CEA) and
well drilling restrictions) to minimize the public's potential exposure to contaminated
groundwater until the groundwater meets the remediation goals. However, consistent with
expectations set out in Superfund regulations, none of the alternatives rely exclusively on
institutional controls to achieve protectiveness. Soil alternatives do not require institutional
controls.

The time frames presented below for construction do not include the time for pre-design
investigations, remedial design, or contract procurements. One of the soil technologies evaluated
would take more than five years to implement, and one technology would take less than five
years. However, each of the groundwater alternatives would take longer than five years to
achieve remediation goals. Therefore, a review will be conducted every five years (five-year
review) after the initiation of the remedial action, until remediation goals are achieved.

Alternatives for Source Area Soils
Alternative 1 - No Action

The No Action alternative was retained, as required by the National Oil and Hazardous
Substance Pollution Contingency Plan (NCP), and provides a baseline for comparison with other
alternatives. No remedial actions would be implemented as part of the No Action Alternative.
Furthermore, institutional and engineering controls would not be implemented.

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Total Capital Cost $0

Operation and Maintenance $0

Total Present Net Worth $0

Timeframe 0 years

Alternative 2 - In-Situ Soil Vapor Extraction/Air Sparging for Sun Cleaners and White
Swan Source Area Soils

Alternative 2 includes the in-situ vapor extraction (ISVE) and air sparging (AS) of soil and
shallow ground water in the two soil source areas. This alternative would involve the injection
of air into the subsurface groundwater, enabling a phase transfer of VOCs from a dissolved state
to the vapor phase. The contaminated air enters the unsaturated, contaminated soils, where a
SVE system creates a negative pressure through a series of extraction wells. The extraction
wells are used to collect the contaminated air, which is then treated to remove contaminants
through the use of catalytic oxidizers or granular activated carbon (GAC). This alternative may
include the use of a series of recirculating groundwater remediation wells (RGRWs), which
would apply the same principals as explained above, but would provide for both air sparging and
ISVE to be implemented within well casings of a series of wells. Specific details of the
implementation of this technology would be determined during the RD phase.

Active operation of the ISVE/AS system may be intermittent over the estimated 10 year time
frame to achieve goals.

Total Capital Cost $1.8 million

Operation & Maintenance $1.8 million

Total Present Net Worth $3.6 million

Timeframe 10 years

Alternative 3 -Excavation and Disposal of Soils at the Sun Cleaners and White Swan
Source Areas

Alternative 3 would include excavation, removal, and off-site treatment and/or disposal of all
soil containing more than 1 ppm of PCE from the White Swan and Sun Cleaners source areas.
There are approximately 5,100 cubic yards of soils exceeding the cleanup criteria at the White
Swan property and approximately 9,600 cubic yards at the Sun Cleaners property. Treatment or
disposal would occur at RCRA-permitted facilities in accordance with regulatory requirements
for these soils. Excavation would be accomplished with commonly used construction
equipment, by methods widely used for impacted soils in cases where the soil contamination is
relatively shallow, less than 25 feet below ground surface. Sheet piling and de-watering would
be required as excavation would go below the water table to maximize mass reduction. The
contaminated groundwater generated during soil excavation would be collected and properly
treated. Traffic controls would be required because of the close proximity to the Manasquan
Traffic Circle and Sea Girt Avenue. This alternative would be completed in approximately one
year. Demolition and disposal of the White Swan Bank building may be required to facilitate the
excavation.

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Total Capital Cost $8 million

Operation and Maintenance $0

Total Present Net Worth $8 million

Time frame 1 year

Alternative 4 - In-Situ Soil Vapor Extraction/Air Sparging at the Sun Cleaners Source
Area and Excavation and Disposal of Soils at the White Swan Source Area

Alternative 4 includes ISVE/AS of soil and shallow groundwater in the Sun Cleaners source area
(as described in Alternative 2) and excavation and off-site disposal of contaminated soils at the
White Swan source area (as described in Alternative 3). ISVE/AS would be preferred at the Sun
Cleaners source area as there is relatively low estimated PCE mass as compared to the White
Swan source area. Excavation and off-Site disposal would be more appropriate at the White
Swan source area because it contains a much higher mass of PCE contamination at a relatively
shallow depth (less than 25 feet) compared to the Sun Cleaners source area. In addition, based
on its topography and location, excavation would be much easier to implement at the White
Swan source area compared to the Sun Cleaners source area. ISVE/AS is expected to be a
slower process for removal of PCE compared to excavation due to mass transfer limitations.
Significant mass removal by ISVE/AS could be expected at the Sun Cleaners source area over a
period of roughly 10 years, and systems would be operated periodically until soil is remediated.
Soil excavation at White Swan would take less than one year. Demolition and disposal of the
White Swan Bank building may be required to facilitate the excavation.

Total Capital Cost
Operation and Maintenance
Total Present Net Worth
Time frame

$4.5 million
$0.9 million
$5.4 million
10 years (Sun)

1 year (White Swan)

Alternatives for Groundwater

Alternative 1 - No Action

The No Action Alternative was retained, as required by the NCP, and provides a baseline for
comparison with other alternatives. Under this alternative, no remedial actions would be
implemented. Furthermore, this alternative would not involve any monitoring of groundwater or
institutional controls. Contaminants in the groundwater would continue to migrate uncontrolled.

Total Capital Cost $0

Operation and Maintenance $0

Total Present Net Worth $0

Time frame N/A

Alternative 2 -In-Situ Vapor Extraction and Air Sparging/MNA/ICs/Vapor Remediation

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This alternative would treat contaminated groundwater in-situ in the Near Field areas, which
generally contain PCE levels of greater than 1,000 ppb, through the use of the ISVE/AS
technologies. ISVE/AS in the Near Field areas of highest groundwater contamination would
involve the injection of air into the subsurface groundwater, enabling a phase transfer of VOCs
from a dissolved state to the vapor phase. The contaminated air enters the unsaturated soils,
where a SVE system creates a negative pressure through a series of extraction wells. The
extraction wells are used to collect the contaminated air, which is then treated to remove
contaminants through the use of catalytic oxidizers or GAC. This alternative may be
implemented through the use of a series of RGRWs, which would apply the same principals as
explained above, but would provide for both air sparging and ISVE to be implemented within
well casings of a series of wells. Specific details of the implementation of this technology would
be determined during the RD phase of the project.

During the RD, an evaluation of individual Far Field "hot spots" for treatment through the
ISVE/AS technology would be performed to assess the effectiveness of treatment.

MNA would be implemented in the Far Field portion of the groundwater contaminant plume,
concurrent with ISVE/AS in the Near Field areas. With the performance of an active
remediation of the most contaminated groundwater in the Near Field areas, modeling shows that
Far Field groundwater would be restored to drinking water standards in a much shorter
timeframe than without remediation (roughly 70 years vs. 400 years). The implementation of
MNA requires long-term monitoring of contaminants as they naturally attenuate through
dilution, adsorption, volatilization and/or biodegradation until groundwater returns naturally to
concentrations below the remediation goals. MNA is expected to be very effective in the Far
Field, in conjuction with active treatment in Near Field areas, as the aquifer is prolific, with a
groundwater migration rate of approximately a half foot per day. In the Far Field area, due to the
aerobic nature of the Site aquifer, dispersion and dilution are likely to be the predominant
mechanism of attenuation. Based on preliminary modeling, it is estimated that, in conjuction
with active treatment in the Near Field areas, the natural attenuation timeframe for aquifer
restoration in the Far Field area will be approximately 50 to 70 years.

To determine the appropriate area of the plume for active treatment as compared to MNA, EPA
performed modeling. As part of the modeling effort, EPA evaluated active remediation of all
portions of the plume containing levels of PCE exceeding: 100 ppb; 150 ppb; 200 ppb; 250 ppb;
500 ppb; and 1,000 ppb. Upon analysis of the modeling results, it was determined that there was
little to be gained from a remediation timeframe perspective, by implementing a costly, large-
scale active treatment remedy in the Far Field area that would present numerous
implementability and operation and maintenance challenges, and be disruptive to a large portion
of the community. Based on the modeling results, it was determined that active treatment of
groundwater with approximately 1,000 ppb of PCE or greater, coupled with MNA, would result
in the restoration of the Site in a reasonable timeframe.

Attenuation processes for VOCs in groundwater would be closely monitored concurrent with
other aspects of the selected remedy. Additional monitoring wells would be installed throughout
the plume and sampled regularly, along with the existing well network. In addition, surface
water and sediment sampling and analysis would be included in the long-term monitoring plan.

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A CEA would be established to limit the installation of additional wells in the area of
groundwater contamination until cleanup standards have been met.

This alternative would address the potential for indoor air contamination by continuing EPA's
current program of sampling sub-slab and indoor air associated with structures overlying the
groundwater contaminant plume. Where elevated VOC levels are detected, vapor mitigation
systems would be installed and maintained in accordance with NJDEP/EPA protocol. In
addition, systems already installed at the Site would be maintained until the groundwater is
remediated.

Total Capital Cost $5.4 million

Operation and Maintenance $5.4 million

Total Present Net Worth $10.8 million

Time frame (ISVE/AS) 10 years

Full Groundwater Restoration Approx. 70 years

Alternative 3 - In-Situ Chemical Oxidation (ISCO)/MNA/ICs/Vapor Remediation

ISCO would involve injecting an oxidant or oxidant releasing compound into wells located
within the most highly contaminated groundwater, generally containing PCE at levels of greater
than 1,000 ppb in the Near Field areas. The oxidant would mix with the contaminants, and cause
them to decompose. When the process is complete, only water and innocuous breakdown
products would be left in the treated area. Monitoring would be required to determine the
effectiveness of the treatment.

Although final details of the implementation of this alternative would be developed in the RD
phase, for costing purposes, it was assumed that sodium permanganate would be the oxidant of
choice. Lines of injection well clusters would be installed perpendicular to groundwater flow.
Each cluster would be comprised of three wells installed to different depths. It is estimated that
the implementation of this alternative would require the installation of approximately 40
injection well clusters near and downgradient of the Sun Cleaners source area and 19 injection
well clusters near and downgradient of the White Swan source area.

During the RD, an evaluation of individual Far Field "hot spots" for treatment through the ISCO
technology would be performed to assess the effectiveness of treatment.

Monitored Natural Attenuation for the Far Field area of the plume would be the same as
discussed above for Alternative 2, above.

A CEA would be established to limit the installation of additional wells in the area of
groundwater contamination until cleanup standards have been met.

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systems would be installed and maintained in accordance with NJDEP/EPA protocol. In
addition, systems already installed at the Site would be maintained until the groundwater is
remediated.

Total Capital Cost
Operation and Maintenance
Total Present Net Worth
Time frame (ISCO)

$7.9 million
$3.7 million
$11.6 million
10 years

Full Groundwater Restoration

Approx. 70 years

Alternative 4 - Extraction and Treatment/MNA/ICs/Vapor Remediation

Alternative 4 would include construction and operation of a groundwater treatment plant and an
extraction well system to collect and treat contaminated groundwater in the Near Field areas
immediately downgradient from both source areas. This alternative would target the most highly
contaminated groundwater at the Site, generally containing PCE at levels of greater than 1,000
ppb. It is estimated that two extraction wells would be required for each source area and an
additional three may be needed to address downgradient hot spot areas pending further
evaluation in the RD. A groundwater extraction and treatment system would be constructed and
operated for approximately 30 years. It would consist of groundwater extraction wells, the
associated underground piping and a treatment plant. The extraction system layouts and flow
rates would be designed to maximize capture of contaminated groundwater from the targeted
areas, which would then combined and pumped to a treatment plant.

Treatment of groundwater in the plant would be achieved by several methods including air
stripping and GAC adsorption units, and the treated water would likely be discharged to a
surface water body such as Judas Creek, the sanitary sewer system, or re-injected into the
aquifer.

During RD, it would be determined if additional extraction wells would be used to treat hot spots
areas within the Far Field portion of the groundwater plume.

Monitored Natural Attenuation for the Far Field area of the plume would be the same as
discussed above for Alternative 2, above.

A CEA would be established to limit the installation of additional wells in the area of
groundwater contamination until cleanup standards have been met.

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Total Capital Cost
Operation and Maintenance
Total Present Net Worth
Time frame (Pump & Treat)
Full Groundwater Restoration

Approx. 70 years

$7.3 million
$6.2 million
$13.5 million
30 years

COMPARATIVE ANALYSIS OF ALTERNATIVES

In selecting a remedy, EPA considered the factors set out in CERCLA § 121, 42 U.S.C. § 9621,
by conducting a detailed analysis of the viable remedial response measures pursuant to the NCP,
40 CFR § 300.430(e)(9) and OSWER Directive 9355.3-01. The detailed analysis consisted of an
assessment of the individual response measure against each of nine evaluation criteria and a
comparative analysis focusing upon the relative performance of each response measure against
the criteria.

Threshold Criteria - The first two criteria are known as "threshold criteria" because they are the
minimum requirements that each response measure must meet in order to be eligible for selection
as a remedy.

1. Overall Protection of Human Health and the Environment

Overall protection of human health and the environment addresses whether each alternative
provides adequate protection of human health and the environment and describes how risks
posed through each exposure pathway are eliminated, reduced, or controlled, through treatment,
engineering controls, and/or institutional controls.

Soil

The No Action Alternative is protective of human health and the environment, as levels of
contamination in surface soil do not pose unacceptable risks. However, under the No Action
Alternative, contaminants in soils would continue to migrate and act as a source of groundwater
contamination.

Alternatives 2, 3 and 4 provide for the in-situ treatment or excavation and off-site disposal of
contaminated soil. Alternatives 2, 3 and 4 are considered protective of human health and the
environment, and in addition, would remove soil contaminants, which are a continuing source of
groundwater contamination.

Groundwater

The No Action Alternative (Alternative 1) is not considered protective of human health and the
environment, because it does not prevent the current and future use of contaminated groundwater
which could present an unacceptable human health risk. It also does as not address contaminated
vapors emanating from Site groundwater.

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The remaining alternatives are considered protective. Alternatives 2, 3, and 4 involve active
treatment which would significantly reduce the time to achieve remediation goals within the
aquifer. Alternatives 2, 3, and 4 all include Monitored Natural Attenuation, vapor mitigation
where appropriate, and institutional controls to minimize potential exposure to contaminated
groundwater until remediation goals have been achieved.

2. Compliance with applicable or relevant and appropriate requirements (ARARs)

Section 121 (d) of CERCLA andNCP § 300.430(f) (1) (ii) (B) require that remedial actions at
CERCLA sites at least attain legally applicable or relevant and appropriate Federal and State
requirements, standards, criteria, and limitations which are collectively referred to as "ARARs,"
unless such ARARs are waived under CERCLA section 121(d) (4).

Applicable requirements are those cleanup standards, standards of control, and other
substantive requirements, criteria, or limitations promulgated under Federal environmental or
State environmental or facility siting laws that specifically address a hazardous substance,
pollutant, contaminant, remedial action, location, or other circumstance found at a CERCLA
site. Only those State standards that are identified by a state in a timely manner and that are
more stringent than Federal requirements may be applicable. Relevant and appropriate
requirements are those cleanup standards, standards of control, and other substantive
requirements, criteria, or limitations promulgated under Federal environmental or State
environmental or facility siting laws that, while not "applicable " to a hazardous substance,
pollutant, contaminant, remedial action, location, or other circumstance at a CERCLA site,
address problems or situations sufficiently similar to those encountered at the CERCLA site that
their use is well-suited to the particular site. Only those State standards that are identified in a
timely manner and are more stringent than Federal requirements may be relevant and
appropriate.

Compliance with ARARs addresses whether a remedy will meet all of the applicable or relevant
and appropriate requirements of other Federal and State environmental statutes or provides a
basis for invoking a waiver.

25

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Soil

Alternative 1, No Action, would not meet the Site established soil cleanup standard of 1 ppm in a
reasonable timeframe. Both of the two active remediation technologies, excavation and ISVE
would achieve the soil remediation goal, although excavation would achieve the goal more
quickly. The ISVE and excavation technologies incorporated in Alternatives 2, 3 and 4 would
comply with location and action-specific ARARs.

Groundwater

Alternative 1, No Action, would not involve any action to remediate VOC-contaminated
groundwater, and would not comply with chemical-specific ARARs for groundwater.
Alternatives 2, 3 and 4 are all expected to comply with chemical-specific ARARs in the Near
Field, but would achieve these goals in differing timeframes. Full restoration of the aquifer is
estimated to take 70 years for Alternatives 2, 3, and 4. All alternatives would comply with
location-specific and action-specific ARARs.

A complete list of ARARs can be found in Table 14 of this ROD.

Primary Balancing Criteria - The next five criteria, criteria 3 through 7, are known as "primary
balancing criteria". These criteria are factors with which tradeoffs between response measures
are assessed so that the best option will be chosen, given site-specific data and conditions.

3. Long-term effectiveness and permanence

A similar degree of long-term effectiveness and permanence refers to expected residual risk and
the ability of a remedy to maintain reliable protection of human health and the environment over
time, once cleanup levels have been met. This criterion includes the consideration of residual
risk that will remain on-site following remediation and the adequacy and reliability of controls.

Soil

Soil Alternative 1, No Action, would not be effective or permanent, as contaminated soils would
not be remediated and there would be no controls put in place to prevent contamination from
continuing to migrate to groundwater. Alternative 3 would provide long-term effectiveness and
permanence through the complete excavation and off-site disposal of VOC-contaminated soil.
Alternatives 2 calls for in-situ remediation through ISVE/AS, and would be effective and
permanent once the soils reach the cleanup goals. Alternative 4 combines excavation and
ISVE/AS at the different source areas, and would be effective in the long-term.

Groundwater

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Alternative 1, No Action, is not effective in the long term. Under this alternative, it is estimated
that groundwater contaminants could remain at the Site for over 400 years, and there would be
no provisions to monitor the fate and transport of the contaminants.

Alternatives 2, 3, and 4 would all be effective and permanent in the long term. All of these
alternatives would ultimately result in groundwater contaminant levels being reduced to meet the
remediation goals throughout the aquifer in approximately 70 years. However, Alternative 4
would require a longer timeframe to achieve the remediation goals in the Near Field area (30
years) compared to Alternatives 2 and 3 (10 years). Alternative 3, ISCO, may be less effective in
the long-term compared to the other alternatives as it is expected to be substantially more
difficult to implement and manage, leading to more uncertainty with respect to its long-term
effectiveness compared to Alternatives 2 and 4.

4. Reduction of toxicity, mobility, or volume

Reduction of toxicity, mobility, or volume through treatment refers to the anticipated
performance of the treatment technologies that may be included as part of a remedy.

Soil

Alternative 1 would not result in a reduction in toxicity, mobility or volume since no treatment of
soil contamination would be conducted. Alternatives 2, ISVE/AS would reduce the volume of
the majority of the VOC contaminants in soil (estimated at 99% removal) through treatment.
Alternative 3, excavation, would remove 100% of the contaminants in soil, but is not likely to
include treatment, as the excavated soils will likely be disposed of at an off-Site landfill without
treatment.

Alternative 4 combines the ISCE/AS and excavation technologies at the different source areas
and would also be effective in reducing the toxicity, mobility and volume of contaminants in
soils at the Sun Cleaners source area through treatment, and the volume contaminants in soils at
the White Swan source area.

Groundwater

All groundwater alternatives would reduce groundwater contaminant concentrations over time
through natural attenuation processes. However, Alternative 1, No Action, would require over
400 years to achieve the groundwater remediation goals. Alternatives 2 (ISVE/AS) and 3
(ISCO) would reduce toxicity, mobility, and volume in the Near Field area of highest
groundwater contamination through in-situ treatment. Alternative 4 (extraction and treatment)
would reduce mobility and volume of Near Field groundwater. All three alternatives which
include active treatment of the Near Field groundwater (Alternatives 2,3 and 4), would provide
for the reduction in volume of groundwater contaminants to restore the aquifer to meet drinking
water standards through treatment and attenuation processes in approximately 70 years.

-------
Alternative 3, ISCO, involves injecting an oxidant into the aquifer which would break down
VOCs. However, an intermediate product of this reaction, vinyl chloride, is more toxic than
TCE and PCE. In addition, ISCO can cause increased volatilization of VOCs, providing the
potential of localized indoor air concerns.

5. Short-Term Effectiveness

Short-term effectiveness addresses the period of time needed to implement the remedy and any
adverse impacts that may be posed to workers, the community and the environment during
construction and operation of the remedy until cleanup levels are achieved.

Soil

Alternative 1, No Action, would not include a remedial action, and therefore, there would be no
short-term impacts to workers or the community.

Alternatives 2, 3 and 4 would include construction work and would be expected to have
moderate short-term impacts on the community, as both source areas are located in a highly
developed commercial area, near residential communities. Potential risks would include
physical hazards where heavy equipment is used, increased vehicular traffic, and noise, air
emissions, and hazards from handling contaminated soils.

These short-term risks can be managed through appropriate planning and monitoring during
construction. Air emissions generated during ISVE/AS and excavation operations can be
controlled and monitored. Disruption of the community would be relatively lower for ISVE/AS
compared to excavation, as excavation would require numerous trucks to transport contaminated
soils from the source areas via existing roadways. Construction activities to implement
Alternatives 2, 3 or 4 are all estimated to take approximately twelve months to complete.

Groundwater

Alternative 1, No Action, would have no short-term impacts because it involves no remedial
action.

Alternatives 2, 3 and 4 are expected to have short-term impacts, which would include physical
hazards, noise, disruption of local traffic, emissions and dust. In addition, significant short-term
risks would be posed by Alternative 3, ISCO, including the handling and storage of chemical
oxidant in a densely populated residential area. Further, Alternative 3 would have the potential
to increase contaminated vapors in residential areas. Careful monitoring and management would
be required under Alternative 3 to assure public safety over the course of the 10 years estimated
to implement this Alternative in the Near Field area.

Alternatives 2 and 3 would require the installation of numerous injection and sampling points
throughout a highly developed residential and commercial area in the Near Field part of the Site.
Alternative 4, extraction and treatment of groundwater, would require the installation of several

-------
extraction wells in the Near Field area. Conveyance piping installation would be required in the
sub-surface utility corridors in some streets near the source areas.

Of the active remedial alternatives, it is estimated that Alternatives 2 and 3 could be constructed
more quickly (1 year) than Alternative 4 (24 months). While short-term disruption of the
community would take place under Alternatives 2, 3 and 4, Alternative 3, ISCO would present
the most disruption to the community and is the least effective in the short term.

6. Implementability

Implementability addresses the technical and administrative feasibility of a remedy from design
through construction and operation. Factors such as availability of services and materials,
administrative feasibility, and coordination with other governmental entities are also considered.

Soil

Alternative 1, No Action, would be the easiest both technically and administratively to
implement, since no additional work would be performed at the Site to address soil
contamination.

Alternatives 2 (ISVE/AS), 3 (excavation), and 4 (ISVE/AS and excavation) are all technically
implementable and use proven, readily available technologies. A pilot study would be needed
prior to design of an ISVE/AS system under Alternatives 2 and 4.

Alternatives 3 (excavation) would involve a greater degree of difficulty to implement compared
to Alterantive 2 (ISVE/AS). Alternative 3 (excavation), would be especially difficult to conduct
at the Sun Cleaners source area because of the steep slope located on one side of the property and
the close proximity to the heavily traveled Route 35 and Manasquan Circle. By comparison, the
White Swan source area would be easier to excavate as is it topographically flatter and it is
located on a lesser traveled road. In addition, excavation would remove significantly more
contaminant mass from the White Swan source area compared to the Sun Cleaners source area
(4,360 pounds of PCE mass at White Swan vs. 140 pounds of PCE at Sun Cleaners).

Groundwater

Alternative 1, No Action, would be the easiest both technically and administratively to
implement, as no additional work would be performed to address groundwater contamination.

Alternatives 2 (ISVE/AS), 3 (ISCO) and 4 (extraction and treatment) include technologies that
are all considered technically implementable, proven, and readily available. Issues requiring
resolution in order to implement Alternatives 2, 3 and 4 include acquisition of land, subsurface
work within public streets and private property for installing system components.

Alternatives 2 (ISVE/AS) and 3 (ISCO) would have a greater amount of infrastructure required
on private land compared to Alternative 4 (extraction and treatment). For this reason,
Alternatives 2 and 3 would require substantial access to private properties during construction

29

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and operation of the systems and would be more disruptive to the community compared to
Alternative 4 during construction and operation.

Alternative 2 (ISVE/AS) would require regular maintenance to prevent metals fouling in the
system. Alternative 3 (ISCO) would present safety hazards associated with the storage and
handling of chemical oxidants near developed areas. Further generation of contaminated vapors
could be exacerbated through the implementation of ISCO and therefore indoor air would need
to be more closely monitored in the treatment area under Alternative 3. Alternative 3 (ISCO)
would require the conduct of a pilot study prior to full-scale implementation.

Alternative 4 would be easier to implement technically, compared to Alternatives 2 (ISVE/AS)
and 3 (ISCO) given that groundwater extraction and treatment is a highly proven technology, and
vendors are readily available. However, Alternative 4 could present some administrative
problems during the remedial design phase, due to the need to obtain access agreements for the
plant location, piping required under public streets, and determination of the most appropriate
discharge option.

Establishment of institutional controls, such as a groundwater CEA, could be easily implemented
through the current NJDEP certification and permitting process. Monitored Natural Attenuation,
which is part of all three active groundwater alternatives, requires access to install additional
monitoring wells across the whole plume area. The indoor air investigations and remediation that
are part of each active alternative would also require access to numerous private properties.
Obtaining the required access for above activities is expected to be implementable.

7. Cost

Includes estimated capital and O&M costs, and net present worth value of capital and O&M
costs.

Soil

Alternative 1 has no cost, but provides no protection of human health and the environment.

The present worth cost associated with Alternative 2, In-situ Vapor Extraction at both source
areas is $3,600,000. The present worth cost associated with Alternative 3, Excavation and
disposal of both source area soils is $8,000,000. The present worth cost associated with
Alternative 4, which includes the exaction and disposal of soils at the White Swan source area
and the treatment of soils at the Sun Cleaners source area through ISVE/AS is $5,400,000.

Groundwater

Alternative 1, No Action, has no associated costs, but is not considered protective of human
health and the environment.

The present worth cost of Alternative 2, ISVE/AS, is $10,800,000. The present worth cost for
Alternative 3, ISCO, is $11,600,000. The present worth cost of Alternative 4, extraction and

-------
treatment, is $13,500,000. Alternative 4 is the most expensive, however, the costs for all three
active groundwater remediation alternatives are the same order of magnitude.

8.	State acceptance

Indicates whether based on its review of the RI/FS reports and the Proposed Plan, the state
supports, opposes, and/or has identified any reservations with the selected response measure.

The State of New Jersey concurs with EPA's Selected Remedy, Alternatives 4 for soil and 4 for
groundwater.

9.	Community acceptance

Summarizes the public's general response to the response measures described in the Proposed
Plan and the RI/FS reports. This assessment includes determining which of the response
measures the community supports, opposes, and/or has reservations about.

EPA solicited input from the community on the remedial response measures proposed for the
site. Oral comments were recorded from attendees of the public meeting. Written comments
were received from a number of parties during the public comment period.

During the public comment period, a great deal of comments were received from members of the
community and other parties. Some commenters preferred Alternative 3 for soils, as compared
to EPA's preferred Alternative 4. In addition, a great deal of questions regarding the ongoing
use of irrigation wells, exposures to Site contamination and local flooding concerns were asked.
Further, the community expressed a desire to have Site remediation expedited to the extent
possible.

The Responsiveness Summary, located in Appendix III, addresses all comments received during
the public comment period.

PRINCIPAL THREAT WASTE

Principal threat wastes are considered source materials, i.e., materials that include or contain
hazardous substances, pollutants or contaminants that act as a reservoir for migration of
contamination to groundwater, surface water, or as a source for direct exposure. Contaminated
groundwater is generally not considered to be source material; however Non-Aqueous Phase
Liquids (NAPLs) in groundwater may be viewed as source material.

Investigations conducted to determine whether NAPL may be present beneath the Site did not
identify the existence of NAPL. However, based on levels of groundwater contamination, it is
possible that some NAPL exists at the Site, and if encountered during the remediation of the Site,
it will be removed.

31

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Soils contaminated at the White Swan and Sun Cleaners source areas are considered to be
principal threat wastes. These soils will be addressed in the selected remedy. Addressing these
soils through the implementation of the selected remedy will have a positive impact on
groundwater remedy, as they are currently acting as ongoing sources of groundwater
contamination at the Site.

SELECTED REMEDY

Based upon consideration of the results of site investigations, the requirements of CERCLA, the
detailed analysis of the remedial alternatives and public comments, EPA has determined that
Alternative 4 for source soils and Alternative 4 for groundwater comprise the appropriate remedy
for Site contamination. This remedy best satisfies the requirements of CERCLA Section 121 and
the NCP's nine evaluation criteria for remedial alternatives, 40 CFR § 300.430 (e) (9). This
remedy includes the following components:

• Excavation and off-site disposal of contaminated soils at the White Swan source area;

• In-situ soil vapor extraction/air sparging of soils and shallow groundwater at the Sun
Cleaners source area;

• Construction of a groundwater extraction and treatment system to capture and treat the
most highly contaminated groundwater at the Site;

• Monitored natural attenuation for lesser contaminated groundwater;

• Establishment of a CEA, which is an institutional control, to limit exposure to
contaminated groundwater until the groundwater meets the cleanup goals; and

• Indoor air monitoring of buildings in close proximity to groundwater contamination, and
installation of vapor mitigation systems, as necessary.

Prior to implementation of the remedy, pre-design investigations will be conducted to further
delineate the areal extent of VOC-contaminated groundwater. In addition, waste characterization
sampling will be performed to determine the disposal destination of the PCE-contaminated soil.
Furthermore, additional investigations will be conducted in residential and commercial buildings
in the vicinity of the plume to identify any indoor air VOC contamination that presents a health
risk. Vapor mitigation systems would be installed in any buildings where health based standards
are exceeded in accordance with NJDEP/EPA protocol.

As part of the selected remedy, contaminated soils at the White Swan source area will be
excavated using standard construction equipment. Demolition and disposal of the structure
currently on the White Swan property may be required to facilitate the excavation. It is estimated
that approximately 5,100 cubic yard of soils will be excavated to a depth of approximately 25
feet. This excavation will go below the water table, and sheet piling and dewatering would be
required. This will remove the highly contaminated smear zone of soil contamination and
remove significant PCE mass. All soil will be transported for off-Site disposal at an appropriate,

-------
permitted facility. Stormwater runoff and dust will be controlled during remedial construction
through standard methods. Post-excavation soil samples will be collected from the sidewalls of
the excavated area to verify that the remediation goal of 1 ppm of PCE has been achieved.
Subsequently, the excavation will be backfilled with clean fill and the property will be restored.

At the Sun Cleaners source area, soils and shallow groundwater will be remediated through the
operation of a soil vapor extraction/air sparging system. This alternative will include the
injection of air into the soils and shallow groundwater at the source area, enabling a phase
transfer of VOCs from a dissolved state into the vapor phase. A SVE system will then extract
the contaminated vapor, which will be treated to remove contaminants. Post-remediation soil
samples will be collected and analyzed to verify that remediation goals have been met.

The groundwater component of the selected remedy will consist of pumping groundwater in the
Near Field area, which is the area of highest VOC contamination at the Site, via extraction wells
and conveying it to a groundwater treatment system. The groundwater treatment system is
expected to handle between 70 and 200 gallons per minute of contaminated groundwater and will
include air stripping and granulated activated carbon, if necessary, to remove VOCs. An
evaluation of discharge options will be performed in the remedial design phase of the project to
determine the best option for the disposal of treated groundwater. The number of extraction
wells and the exact extraction rate will also be determined based on evaluations to be performed
during the remedial design of the remedy.

For groundwater in the Far Field area, contamination will be addressed through monitored
natural attenuation. Attenuation of VOCs in groundwater will be closely monitored concurrent
with other aspects of the remedy. Surface water and sediments will continue to be monitored to
evaluate the impact of the remedy over time.

A number of localized "hot spots" of groundwater contamination have been identified in the Far
Field area. These Far Field Hot Spots generally have PCE contamination at levels of
approximately 1,000 ppb or higher. These hot spot areas in the Far Field will be further
evaluated in the remedial design and may be addressed through the groundwater extraction and
treatment system, or smaller, localized treatment systems.

Preliminary modeling conducted during the RI/FS indicates that it will take approximately 30
years to achieve the remediation goals through the implementation of the selected remedy in the
Near Field area, and 70 years for the entire aquifer to be restored through the implementation of
the selected remedy. The estimated present worth cost of the Selected Remedy is $5,400,000 for
soils and $13,500,000 for groundwater.

Indoor air contamination will be addressed by ongoing sampling of sub-slab and indoor air in
structures overlying the groundwater contaminant plume. Where elevated VOC levels are
detected, vapor mitigation systems will be installed and maintained in accordance with
NJDEP/EPA protocol. In addition, systems already installed at the Site will be maintained.

A groundwater CEA will be established to limit use of contaminated groundwater until the
groundwater meets the remediation goals.

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Based on all available information, EPA and the State of New Jersey believe the Selected
Remedy provides the best balance of trade-offs among the response measures with respect to the
nine evaluation criteria. EPA believes that the Selected Remedy will be protective of human
health and the environment, will comply with ARARs, will be cost effective, and will utilize
permanent solutions and alternative treatment technologies to the maximum extent practicable.

STATUTORY DETERMINATIONS

As was previously noted, CERCLA § 121(b)(1) mandates that a remedial action must be
protective of human health and the environment, cost-effective, and utilize permanent solutions
and alternative treatment technologies or resource recovery technologies to the maximum extent
practicable. Section 121(b)(1) also establishes a preference for remedial actions which employ
treatment to permanently and significantly reduce the volume, toxicity or mobility of the
hazardous substances, pollutants, or contaminants at a site. CERCLA § 121(d) further specifies
that a remedial action must attain a degree of cleanup that satisfies ARARs under federal and
state laws, unless a waiver can be justified pursuant to CERCLA § 121(d)(4).

Protection of Human Health and the Environment

The Selected Remedy, Alternatives 4 for soils and Alternative 4 for groundwater, will be
protective of human health and the environment by providing for the removal of contaminated
soil and the treatment of contaminated groundwater at the Site. Furthermore, the implementation
of vapor mitigation, as needed and institutional controls as part of the Selected Remedy will
insure that impacts to human health and the environment are minimized. Implementation of the
Selected Remedy will not present unacceptable short-term risks or adverse cross-media impacts.

Compliance with ARARs

EPA expects that the Selected Remedy will comply with ARARs. The soil component of the
Selected Remedy will meet the remediation goal of 1 ppm for PCE, derived to protect
groundwater. For the White Swan source area, this goal will be achieved through the excavation,
transportation and off-site disposal of contaminated soil in accordance with applicable Resource
Conservation and Recovery Act (RCRA) and Department of Transportation requirements. For
the Sun Cleaners source area, the remediation goal will be achieved through ISVE/AS. Federal
and State ARARs will be met for this part of the remedy. The groundwater component of the
Selected Remedy will be designed to meet Federal and State ARARs for groundwater. Pursuant
to the New Jersey Ground Water Quality Standards (GWQSs), N.J.A.C. 7:9C et seq., the
groundwater at the site is classified as Class IIA. The more restrictive of Federal or State
drinking water standards and the applicable GWQSs are being used as groundwater cleanup
levels.

Cost Effectiveness

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EPA has determined that the Selected Remedy is cost-effective and represents a reasonable value
for the money to be spent. In making this determination, the following definition was used: "A
remedy shall be cost-effective if its costs are proportional to its overall effectiveness." (NCP
§300.430(f)(l)(ii)(D)). EPA evaluated the "overall effectiveness" of those alternatives that
satisfied the threshold criteria (i.e., were both protective of human health and the environment
and ARAR-compliant). Overall effectiveness was evaluated by assessing three of the five
balancing criteria in combination (long-term effectiveness and permanence; reduction in toxicity,
mobility, or volume through treatment; and short-term effectiveness). Overall effectiveness was
then compared to costs to determine cost-effectiveness. The relationship of the overall
effectiveness of the selected remedy was determined to be proportional to costs and hence, these
alternatives represent a reasonable value for the money to be spent. The Selected Remedy is
cost-effective as it has been determined to provide the greatest overall protectiveness for its
present worth costs.

Utilization of Permanent Solutions and Alternative Treatment Technologies

EPA has determined that the Selected Remedy utilizes permanent solutions and treatment
technologies to the maximum extent that is practicable. Site soil contamination will be
permanently addressed through a combination of removal (the excavation and off-Site disposal
of contaminated soils at the White Swan source area) and treatment (the use of ISVE/AS to
permanently treat soils in-situ at the Sun Cleaners source area). The Selected Remedy will
address groundwater contamination related to the Site through extraction and treatment to
permanently remove contaminants. Furthermore, VOCs in groundwater which are not captured
by the extraction system will be permanently addressed by natural attenuation processes, such as
dilution and dispersion. Indoor air contamination, where detected, will be addressed through
individual vapor treatment systems.

Preference for Treatment as a Principal Element

The Selected Remedy meets EPA's statutory preference for the use of remedies that involve
treatment as a principal element. The toxicity, mobility, and volume of the contaminants in the
groundwater will be reduced through extraction and treatment of the Site's most highly
contaminated groundwater through air stripping, and activated carbon, if necessary. Lesser
contaminated groundwater will not be actively treated, but will be addressed through natural
attenuation processes, such as dilution and dispersion. Although soils at the White Swan source
area will be excavated and disposed of off-Site without treatment, soils as well as shallow
groundwater at the Sun Cleaners source area will be treated in-situ through the ISVE/AS
technology.

Five-Year Review Requirements

The Selected Remedy will not result in contaminated soil or contaminated groundwater
remaining on-site above levels that allow for unlimited use and unrestricted exposure. However,
the Selected Remedy will take more than five years to attain the cleanup levels for soil and

-------
groundwater. Therefore, a policy review will be conducted within five years of construction
completion for the Site to ensure that the remedy is, or will be, protective of human health and
the environment.

DOCUMENTATION OF SIGNIFICANT CHANGES

The Proposed Plan for the site was released for public comment on August 20, 2013. The
comment period closed on September 19, 2013. The Proposed Plan identified Soil Alternative 4
and Groundwater Alternative 4 as the preferred alternatives to address soil and groundwater
contamination at the site. Upon review of all comments submitted, EPA has determined that no
significant changes to the preferred alternative, as it was presented in the Proposed Plan, are
warranted.

36

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APPENDIX I
FIGURES

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IMAGE SOURCE:

USGS 7.5 MINUTE SERIES
TOPOGRAPHIC QUADRANGLE
ASBURY PARK, NEW JERSEY, 1989

W

NEWJERSE

LEGEND

APPROXIMATE
SITE BOUNDARY

QUADRANGLE LQCATTON

FIGURE 1
SITE LOCATION MAP

FEASIBILITY STUDY

WHITE SWAN CLEANERS / SUN CLEANERS
AREA GROUND WATER CONTAMINATION
SUPERFUND SITE

amed *

285 DAVIDSON AVENUE, SUITE 405
SOMERSET, NJ 08873
(732) 302-9500

SCALE IN FEET

2000

July 2013

-------
.DEBORAH CT

¦VtpsPEpr

OLD MILL

mpondWLJ

Garrett or

WHITE SWAN
PROPERTY
SOURCE AREA

•JZBSEYi'AVF

.CENTfiAi,.

_§Hoi|LR5-

WRECK
POND

FAR FIELD
AREA

NEAR FIELD
AREA N

m»yoRK

WTRBRK-01

BARLOW

NEAR FIELD
m, AREA

MAC,
POND

SUN PROPERTY
SOURCE AREA



FAR FIELD /
AREA



LEGEND

0 Monitoring Well (MW)

© Irrigation Well
® Municipal Supply Well
® Stream Gauge (SG)

® Piezometer (PZ)

Streams
Lakes

cross sections
ground water elevation contour (10/5/2009)
® hydropunch sample location

Hydropunch Ground Water PCE Concentration (ug/L)

10 25 50 100 150 200 250 500 750 1000 1200

Note:

Maximum PCE concentration measured within the Shallow (S),
lntermediate-1 (1-1), and Intermediate (I) monitoring zones within
the unconfined Lower Kirkwood Formation.

Image Source:

New Jersey 2007 - 2008 High Resolution Orthophotography
NJ Office of Information Technology
Office of Geographic Information Systems

FIGURE 2

IDENTIFICATION OF SOURCE/NEAR-FIELD
AND FAR-FIELD REMEDIAL AREAS

FEASIBILITY STUDY

WHITE SWAN CLEANERS / SUN CLEANERS
AREA GROUND WATER CONTAMINATION
SUPERFUND SITE

285 DAVIDSON AVENUE, SUITE 405
SOMERSET, NJ 08873
Of f f W W (732) 302-9500

-------
Wall Township

---' '	" -#t:"

XHkW^|X:' / .•;

SvJ ¦ "'IStfKjNSraSU v^':

FIGURE 3
EXTENT OF PCE IN GROUND WATER

LEGEND

PROPOSED PLAN

PCE CONCENTRATION
IN PARTS PER BILLION

WHITE SWAN CLEANERS / SUN CLEANERS
AREA GROUND WATER CONTAMINATION
SUPERFUNDSITE

JULY 2013

CONTOUR REPRESENTS HIGHEST
CONCENTRATION OF PCE IN GROUND
WATER AT ANY GEOGRAPHIC POINT

LOCALIZED AREAS OF ELEVATED
PCE CONCENTRATION

WHITE SWAN
PROPERTY

SUN
PROPERTY

SEA GIRT
MUNICIPAL
WELL FIELD

Sea Girt
Borough

Spring Lake
Borough

Spring Lake
Heights Borough

WRECK

POND

Manasquan
Boroucih

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APPENDIX II
TABLES

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Table 1

White Swan Property Soil Detections and Screening Criteria Exceedances
White Swan Cleaners/Sun Cleaners Area Ground Water Contamination Superfund Site

Parameter:
SSSSC

Volatile Organic Compounds (mg/kg)

1,2-Dichlorobenzene

1,4-Dichlorobenzene

1,4-Dioxane (p-dioxane)

Acetone

Chloroform

cis-1,2-Dichloroethylene

Methyl acetate

Methyl Ethyl Ketone

Methyl Isobutyl Ketone

Tetrachloroethylene (PCE)

Toluene

trans-1,2-Dichloroethene

Trichloroethylene (TCE)

Semi-Volatile Organic Compounds (mg/kg)

Benzaldehyde

Benzo(a)anthracene

Benzo(a)pyrene

Benzo(b)fluoranthene

Benzo(g,h,i)perylene

Benzo(k)fluoranthene

Benzyl butyl phthalate

Bis(2-ethylhexyl) phthalate

Chrysene

Dibenz(a,h)anthracene

11

1

NC

12

0.2

0.2

14

0.6

NC

0.005

4

0.4

0.007

6,100

0.5

0.2

0.6

30,000

6

150

35

52

0.2

Location

Sample ID

Date















































BKG-04

B-R-BKG-04-0.0-2.0

05-Apr-10

0.0046 U

0.0046 U

0.093 R

0.0093 U

0.0046 U

0.0046 U

0.0046 U

0.0093 U

0.0093 U

0.0046 U

0.0046 U

0.0046 U

0.0046 U

0.2 U

0.2 U

0.2 U

0.022 J

0.2 U

0.02 J

0.2 U

0.026 J

0.022 J

0.2 U

BKG-04

B-R-BKG-04-3.0-4.0

07-Apr-10

0.0054 U

0.0054 U

0.11 R

0.011 U

0.0054 U

0.0054 U

0.0054 U

0.011 U

0.011 U

0.0054 U

0.0054 U

0.0054 U

0.0054 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.044 J

0.18 U

0.18 U

BKG-05

B-R-BKG-05-0.0-2.0

05-Apr-10

0.005 U

0.005 U

0.1 R

0.01 U

0.005 U

0.005 U

0.005 U

0.01 U

0.01 U

0.005 U

0.005 U

0.005 U

0.005 U

0.21 U

0.023 J

0.031 J

0.033 J

0.21 U

0.026 J

0.024 J

0.052 J

0.034 J

0.21 U

BKG-05

B-R-BKG-05-3.0-4.0

05-Apr-10

0.0042 U

0.0042 U

0.084 R

0.0084 U

0.0042 U

0.0042 U

0.0042 U

0.0084 U

0.0084 U

0.0042 U

0.0042 U

0.0042 U

0.0042 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.024 J

0.18 U

0.18 U

WS-BKG-02

B-WS-BKG-02-0.0-2.0

05-Apr-10

0.0049 U

0.0049 U

0.098 R

0.0098 U

0.0049 U

0.0049 U

0.0049 U

0.0098 U

0.0098 U

0.0049 U

0.0049 U

0.0049 U

0.0049 U

0.22 U

0.034 J

0.044 J

0.044 J

0.024 J

0.04 J

0.22 U

0.035 J

0.05 J

0.22 U

WS-BKG-02

B-WS-BKG-02-3.0-4.0

05-Apr-10

0.0045 U

0.0045 U

0.091 R

0.0091 U

0.0045 U

0.0045 U

0.0045 U

0.0091 U

0.0091 U

0.0045 U

0.0045 U

0.0045 U

0.0045 U

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.02 J

0.19 U

0.19 U

WS-01

B-WS-01-000.0-002.0

10-Feb-08

0.0093 U

0.003 J

0.088 R

0.0088 U

0.0044 U

0.0044 U

0.0044 U

0.0088 U

0.0088 U

0.0044 U

0.0044 U

0.0044 U

0.0044 U

0.19 U

0.087 J

0.11 J

0.1 J

0.069 J

0.079 J

0.19 U

0.19 U

0.13 J

0.02 J

WS-01

B-WS-01-008.0-010.0

10-Feb-08

0.0049 U

0.0049 U

0.098 R

0.0098 U

0.0049 U

0.0049 U

0.0049 U

0.0098 U

0.0098 U

0.0049 U

0.0049 U

0.0049 U

0.0049 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

WS-01

B-WS-01-015.0-016.0

10-Feb-08

0.0043

0.0043

0.086

0.039

0.0043

0.0043

0.0043

0.0094

0.0086

0.0034

0.0043

0.0043

0.0043

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-01

B-WS-01-020.5-021.0

10-Feb-08

0.0039

0.0037 U

0.074 R

0.022

0.0037 U

0.0037 U

0.0037 U

0.0061 J

0.0074 U

0.0074

0.0037 U

0.0037 U

0.0037 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-01

B-WS-01-021.0-023.0

10-Feb-08

0.0057 U

0.0057 U

0.11 R

0.011 u

0.0057 U

0.0057 U

0.0057 U

0.011 u

0.011 U

0.0057 U

0.0057 U

0.0057 U

0.0057 U

0.24

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.026 J

0.19 U

0.19 U

0.19 U

WS-02

B-WS-02-000.0-002.0

12-Feb-08

0.004 U

0.004 U

0.08 R

0.008 U

0.004 U

0.004 U

0.004 U

0.008 U

0.008 U

0.004 U

0.004 U

0.004 U

0.004 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-02

B-WS-02-009.6-010.4

12-Feb-08

0.0047 U

0.0047 U

0.095 R

0.005 J

0.0047 U

0.0047 U

0.0047 U

0.0095 U

0.0095 U

0.069

0.0047 U

0.0047 U

0.0047 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-02

B-WS-02-023.5-024.5

12-Feb-08

0.22 U

0.22 U

4.4 U

0.44 U

0.22 U

0.22 U

0.22 U

0.44 U

0.44 U

0.56

0.22 U

0.22 U

0.22 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-03

B-WS-03-000.0-002.0

14-Feb-08

0.0047 U

0.0047 U

0.094 R

0.0094 U

0.0047 U

0.0047 U

0.0047 U

0.0094 U

0.0094 U

0.0027 J

0.0047 U

0.0047 U

0.0047 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-03

B-WS-03-008.0-009.0

14-Feb-08

0.0043 U

0.0043 U

0.087 R

0.0087 U

0.0043 U

0.0043 U

0.0043 U

0.0087 U

0.0087 U

0.0043 U

0.0043 U

0.0043 U

0.0043 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-03

B-WS-03-013.0-014.0

14-Feb-08

0.28 U

0.28 U

5.5 U

0.55 U

0.28 U

0.28 U

0.28 U

0.55 U

0.55 U

0.71

0.28 U

0.28 U

0.28 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-03

B-WS-03-019.0-020.0

14-Feb-08

0.34 U

0.34 U

6.9 U

0.69 U

0.34 U

0.34 U

0.34 U

0.69 U

0.69 U

1

0.34 U

0.34 U

0.34 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-03

B-WS-03-022.0-023.0

14-Feb-08

0.31 U

0.31 U

6.1 U

0.61 U

0.31 U

0.31 U

0.31 U

0.61 U

0.61 U

2.6

0.31 U

0.31 U

0.31 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-04

B-WS-04-000.0-002.0

11-Feb-08

0.0042 U

0.0042 U

0.083 R

0.0083 U

0.0042 U

0.0042 U

0.0042 U

0.0083 U

0.0083 U

0.014

0.0042 U

0.0042 U

0.0042 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-04

B-WS-04-014.0-015.0

11-Feb-08

0.24 U

0.24 U

4.7 U

0.47 U

0.24 U

0.24 U

0.24 U

0.47 U

0.47 U

3.3

0.24 U

0.24 U

0.24 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-04

B-WS-04-019.0-020.0

11-Feb-08

0.29 U

0.29 U

5.8 U

0.58 U

0.29 U

0.29 U

0.29 U

0.58 U

0.58 U

1.6

0.29 U

0.29 U

0.29 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-04

B-WS-04-023.0-024.0

11-Feb-08

0.0045 U

0.0045 U

0.09 R

0.0042 J

0.0045 U

0.01

0.0045 U

0.009 U

0.009 U

0.44

0.0045 U

0.0045 U

0.004 J

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-05

B-WS-05-000.0-002.0

11-Feb-08

0.0043 U

0.0043 U

0.087 R

0.0087 U

0.0043 U

0.0043 U

0.0043 U

0.0087 U

0.0087 U

0.0084

0.0043 U

0.0043 U

0.0043 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-05

B-WS-05-017.0-019.0

11-Feb-08

0.0055 U

0.0055 U

0.11 R

0.0068 J

0.0055 U

0.0055 U

0.0055 U

0.011 U

0.011 U

0.02

0.0055 U

0.0055 U

0.0055 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-05

B-WS-05-022.5-023.5

11-Feb-08

0.27 U

0.27 U

5.4 U

0.54 U

0.27 U

0.27 U

0.27 U

0.54 U

0.54 U

1

0.27 U

0.27 U

0.27 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-07

B-WS-07-000.0-002.0

13-Feb-08

0.24 U

0.24 U

4.7 U

0.47 U

0.24 U

0.24 U

0.24 U

0.47 U

0.47 U

2.6

0.24 U

0.24 U

0.16 J

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-07

B-WS-07-007.2-008.2

13-Feb-08

0.0047 U

0.0047 U

0.094 R

0.0051 J

0.0047 U

0.0047 U

0.0047 U

0.0094 U

0.0094 U

0.0047 U

0.0047 U

0.0047 U

0.0047 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-07

B-WS-07-021.5-022.5

13-Feb-08

0.0045 U

0.0045 U

0.089 R

0.017

0.0045 U

0.0021 J

0.0045 U

0.0043 J

0.0089 R

0.32

0.0045 U

0.0045 U

0.0044 J

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-08

B-WS-08-000.0-002.0

14-Feb-08

0.25 U

0.25 U

4.9 U

0.49 U

0.25 U

0.23 J

0.25 U

0.49 U

0.49 U

7.9

0.25 U

0.25 U

0.24 J

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.27 U

0.18 U

0.18 U

WS-08

B-WS-08-004.5-006.0

14-Feb-08

0.0042 U

0.0042 U

0.083 R

0.0083 U

0.0042 U

0.0016 J

0.0042 U

0.0083 U

0.0083 U

0.056 J

0.0042 U

0.0042 U

0.0042 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

WS-08

B-WS-X-03-021408

14-Feb-08

0.2 U

0.2 U

1.9 J

0.4 U

0.2 U

0.2 U

0.2 U

0.4 U

0.4 U

0.62 J

0.2 U

0.2 U

0.2 U

0.17 U

0.17 U

0.17 U

0.17 U

0.17 U

0.17 U

0.17 U

0.17 U

0.17 U

0.17 U

WS-08

B-WS-08-016.0-017.0

14-Feb-08

0.28 U

0.28 U

5.7 U

0.57 U

0.28 U

0.12 J

0.28 U

0.57 U

0.57 U

42

0.28 U

0.28 U

0.24 J

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-08

B-WS-08-022.0-023.0

14-Feb-08

600 U

600 U

12,000 U

1,200 U

600 U

600 U

600 U

1,200 U

1,200 U

28,000 J

600 U

600 U

600 U

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.3

0.88

0.19 U

0.19 U

WS-09

B-WS-09-000.0-002.0

13-Feb-08

0.23 U

0.23 U

4.6 U

0.46 U

0.23 U

0.23 U

0.23 U

0.46 U

0.46 U

0.58

0.23 U

0.23 U

0.23 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-09

B-WS-09-007.5-008.5

13-Feb-08

0.0043 U

0.0043 U

0.087 R

0.0087 U

0.0043 U

0.0043 U

0.0043 U

0.0087 U

0.0087 U

0.024

0.0043 U

0.0043 U

0.0043 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-09

B-WS-09-014.0-015.0

13-Feb-08

0.25 U

0.25 U

4.9 U

0.49 U

0.25 U

0.25 U

0.25 U

0.49 U

0.49 U

2.2

0.25 U

0.25 U

0.25 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-09

B-WS-X-01 -021308

13-Feb-08

0.31 U

0.31 U

6.1 U

0.61 U

0.31 U

0.31 U

0.31 U

0.61 U

0.61 U

3

0.31 U

0.31 U

0.31 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-09

B-WS-09-019.0-020.0

13-Feb-08

0.3 U

0.3 U

6 R

0.6 U

0.3 U

0.3 U

0.3 U

0.6 U

0.6 U

1.3

0.3 U

0.3 U

0.3 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-09

B-WS-09-022.0-023.0

13-Feb-08

0.27 U

0.27 U

5.4 R

0.54 U

0.27 U

0.27 U

0.27 U

0.54 U

0.54 U

5.1

0.27 U

0.27 U

0.27 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-11

B-WS-11-000.0-002.0

12-Feb-08

0.22 U

0.22 U

4.3 U

0.43 U

0.22 U

0.22 U

0.22 U

0.43 U

0.43 U

27

0.22 U

0.22 U

0.19 J

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-11

B-WS-11-006.5-007.0

12-Feb-08

0.46 U

0.46 U

9.3 U

1.2

0.46 U

37

0.61

0.93 U

0.93 U

160

0.46 U

0.48

32

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-11

B-WS-11-013.5-014.0

12-Feb-08

0.0053 U

0.0053 U

0.11 R

0.011 u

0.0033 J

0.012

0.0053 U

0.011 U

0.011 U

0.55

0.0053 U

0.0053 U

0.004 J

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-11

B-WS-11-017.0-018.0

12-Feb-08

0.3 U

0.3 U

5.9 U

0.59 U

0.3 U

0.3 U

0.3 U

0.59 U

0.59 U

0.89

0.3 U

0.3 U

0.3 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-11

B-WS-11-022.0-023.0

12-Feb-08

0.3 U

0.3 U

6 U

0.6 U

0.3 U

0.3 U

0.3 U

0.6 U

0.6 U

1.2

0.3 U

0.3 U

0.3 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-12

B-WS-12-000.0-002.0

13-Feb-08

0.27 U

0.27 U

5.4 R

0.54 U

0.27 U

0.071 J

0.062 J

0.54 U

0.54 U

7.7

0.27 U

0.27 U

0.085 J

0.046 J

0.2 U

0.2 U

0.2 U

0.2 U

0.2 U

0.026 J

0.056 J

0.2 U

0.2 U

WS-12

B-WS-12-009.0-010.0

14-Feb-08

0.26 U

0.26 U

5.2 R

0.52 U

0.26 U

0.26 U

0.26 U

0.52 U

0.52 U

0.45

0.26 U

0.26 U

0.26 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

WS-12

B-WS-12-022.0-023.0

14-Feb-08

0.29 U

0.29 U

5.8 R

0.58 U

0.29 U

0.29 U

0.29 U

0.58 U

0.58 U

2.1

0.29 U

0.29 U

0.29 U

0.072 J

0.2 U

0.2 U

0.2 U

0.2 U

0.2 U

0.2 U

0.2 U

0.2 U

0.2 U

WS-13

B-WS-13-000.0-002.0

13-Feb-08

0.24 U

0.24 U

4.7 R

0.47 U

0.24 U

0.24 U

0.24 U

0.47 U

0.47 U

0.85

0.24 U

0.24 U

0.24 U

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.027 J

0.26

0.19 U

0.19 U

WS-13

B-WS-13-004.0-004.5

13-Feb-08

0.24 U

0.24 U

4.7 U

0.47 U

0.24 U

0.24 U

0.24 U

0.47 U

0.47 U

0.55

0.24 U

0.24 U

0.24 U

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.03 J

0.19 U

0.19 U

0.19 U

WS-13

B-WS-13-022.0-023.0

13-Feb-08

0.0051 U

0.0051 U

0.1 R

0.01 U

0.0051 U

0.0097

0.0051 U

0.01 U

0.01 U

0.28 J

0.0051 U

0.0051 U

0.0045 J

0.2 U

0.2 U

0.2 U

0.2 U

0.2 U

0.2 U

0.2 U

0.2 U

0.023 J

0.2 U

WS-13

B-WS-X-02-021308

13-Feb-08

0.0049 U

0.0049 U

0.098 R

0.0098 U

0.0049 U

0.0084

0.0049 U

0.0098 U

0.0098 U

0.19 J

0.0049 U

0.0049 U

0.0039 J

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-15

B-WS-15-000.0-002.0

10-Feb-08

0.0047 U

0.0047 U

0.094 R

0.0094 U

0.0047 U

0.0047 U

0.0047 U

0.0094 U

0.0094 U

0.0047 U

0.0047 U

0.0047 U

0.0047 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

WS-15

B-WS-15-008.0-009.0

10-Feb-08

0.0045 U

0.0045 U

0.09 R

0.009 U

0.0045 U

0.0045 U

0.0045 U

0.009 U

0.009 U

0.01

0.0045 U

0.0045 U

0.0045 U

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.025 J

0.19 U

0.19 U

0.19 U

WS-15

B-WS-15-018.0-019.0

11-Feb-08

0.005 U

0.005 U

0.1 R

0.01 U

0.005 U

0.005 U

0.005 U

0.01 U

0.01 U

0.033

0.005 U

0.005 U

0.005 U

0.2 U

0.2 U

0.2 U

0.2 U

0.2 U

0.2 U

0.028 J

0.2 U

0.2 U

0.2 U

WS-19

B-WS-19-000.0-002.0

13-Feb-08

0.0041 U

0.0041 U

0.082 R

0.0045 J

0.0041 U

0.0041 U

0.0041 U

0.0082 U

0.0082 U

0.053

0.0041 U

0.0041 U

0.0041 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-19

B-WS-19-015.5-016.5

13-Feb-08

0.26 U

0.26 U

5.1 U

0.51 U

0.26 U

0.26 U

0.26 U

0.51 U

0.51 U

0.73

0.26 U

0.26 U

0.26 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-19

B-WS-19-022.0-023.0

13-Feb-08

0.0047 U

0.0047 U

0.095 R

0.0059 J

0.0028 J

0.0024 J

0.0047 U

0.0095 U

0.0095 U

0.33

0.0047 U

0.0047 U

0.0047 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-26

B-WS-26-018.0-019.0

19-Jan-09

0.0051 U

0.0051 U

1 R

0.0051 U

0.0051 U

0.0018 J

0.0051 U

0.0051 U

0.0051 U

0.2

0.0051 U

0.0051 U

0.0012

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-27

B-WS-27-018.0-019.0

19-Jan-09

0.006 U

0.006 U

1.2 R

0.006 U

0.006 U

0.006 U

0.006 U

0.006 U

0.006 U

0.0016

0.006 U

0.006 U

0.0012 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-28

B-WS-28-008.6-008.8

19-Jan-09

0.53 U

0.53 U

100 R

0.53 R

0.53 U

0.53 U

0.53 U

0.53 R

0.53 U

1.8

0.53 U

0.53 U

0.1 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-28

B-WS-28-018.5-018.7

19-Jan-09

0.0062 U

0.0062 U

1.2 R

0.0062 U

0.0062 U

0.0006 J

0.0062 U

0.0062 U

0.0062 U

0.04

0.0062 U

0.0062 U

0.0012 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

Page 1 of 4

-------
Table 1

White Swan Property Soil Detections and Screening Criteria Exceedances
White Swan Cleaners/Sun Cleaners Area Ground Water Contamination Superfund Site

Parameter:
SSSSC

Volatile Organic Compounds (mg/kg)

1,2-Dichlorobenzene

1,4-Dichlorobenzene

1,4-Dioxane (p-dioxane)

Acetone

Chloroform

cis-1,2-Dichloroethylene

Methyl acetate

Methyl Ethyl Ketone

Methyl Isobutyl Ketone

Tetrachloroethylene (PCE)

Toluene

trans-1,2-Dichloroethene

Trichloroethylene (TCE)

Semi-Volatile Organic Compounds (mg/kg)

Benzaldehyde

Benzo(a)anthracene

Benzo(a)pyrene

Benzo(b)fluoranthene

Benzo(g,h,i)perylene

Benzo(k)fluoranthene

Benzyl butyl phthalate

Bis(2-ethylhexyl) phthalate

Chrysene

Dibenz(a,h)anthracene

11

1

NC

12

0.2

0.2

14

0.6

NC

0.005

4

0.4

0.007

6,100

0.5

0.2

0.6

30,000

6

150

35

52

0.2

Location

Sample ID

Date















































WS-29

B-WS-29-019.3-019.6

19-Jan-09

0.6 U

0.6 U

120 R

0.6 R

0.6 U

0.064 J

0.6 U

0.6 R

0.6 U

1.8

0.6 U

0.6 U

0.12 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-30

B-WS-30-008.4-008.8

19-Jan-09

0.0044 U

0.0044 U

0.87 R

0.0044 U

0.0044 U

0.0014 J

0.0044 U

0.0044 U

0.0044 U

0.04

0.0044 U

0.0044 U

0.0009 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-30

B-WS-30-017.5-017.8

19-Jan-09

0.0059 U

0.0059 U

1.2 R

0.0059 U

0.0059 U

0.0059 U

0.0059 U

0.0059 U

0.0009 J

0.01

0.0008 J

0.0059 U

0.0012 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-30

B-WS-30-019.4-019.6

19-Jan-09

0.62 U

0.62 U

120 R

0.62 R

0.62 U

0.62 U

0.62 U

0.62 R

0.62 U

7.1

0.62 U

0.62 U

0.12 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-31

B-WS-31 -013.6-013.9

19-Jan-09

2 U

2 U

400 R

2 R

2 U

2 U

2 U

2 R

2 U

42

2 U

2 U

0.4 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-31

B-WS-31 -018.0-018.2

19-Jan-09

55 U

55 U

11,000 R

55 R

55 U

55 U

55 U

55 R

55 U

1,300

55 U

55 U

11 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-31

B-WS-31 -019.0-019.2

19-Jan-09

310 U

310 U

62000 R

310 R

310 U

310 U

310 U

310 R

310 U

9,800

310 U

310 U

62 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-32

B-WS-32-019.2-019.4

16-Feb-09

0.0049 U

0.0049 U

0.98 U

0.0049 U

0.0049 U

0.0004 J

0.0049 U

0.0049 U

0.0049 U

0.036

0.0049 U

0.0049 U

0.001 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-33

B-WS-33-018.4-018.7

16-Feb-09

0.0056 U

0.0056 U

1.1 U

0.0055 J

0.0056 U

0.0005 J

0.0056 U

0.0056 U

0.0056 U

0.016

0.0056 U

0.0056 U

0.0011 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-34

BA-WS-34-028.3-028.7

16-Feb-09

0.0057 U

0.0057 U

1.1 U

0.0054 J

0.0057 U

0.0057 U

0.0057 U

0.0057 U

0.0057 U

0.0035

0.0057 U

0.0057 U

0.0011 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-34

BA-WS-X-01-021609

16-Feb-09

0.0059 U

0.0059 U

1.2 U

0.0051 J

0.0059 U

0.0059 U

0.0059 U

0.0059 U

0.0059 U

0.0005 J

0.0059 U

0.0059 U

0.0012 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-35

BA-WS-35-026.4-026.8

16-Feb-09

0.005 U

0.005 U

1 U

0.005 U

0.005 U

0.005 U

0.005 U

0.005 U

0.005 U

0.0024

0.005 U

0.005 U

0.001 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

Notes:

1.	'SSSSC' designates Site-specific Soil Screening Criteria

= exceeds SSSSC

2.	BOLD = detection

3.	TCL Volatile Organic Compounds and Semi-Volatile Organic Compounds quantitated by Method SOM01.2 or Method 8260B.
TAL Metals quantitated by Method ILM05.3 and ILM05.4.

4.	Results are expressed in milligrams per kilogram (mg/kg).

5.	'NC' indicates screening criteria is not available.

6.	'NA' indicates the parameter was not analyzed for.

7.'U'	designates the analyte is not detected at or above the listed reporting limit.

8.	'J' designates reported concentration is an estimated value.

9. 'R' designates that the reported sample result is not usable.

Page 2 of 4

-------
Table 1

White Swan Property Soil Detections and Screening Criteria Exceedances
White Swan Cleaners/Sun Cleaners Area Ground Water Contamination Superfund Site





Parameter:

Di-n-butyl phthalate

Fluoranthene

lndeno(1,2,3-c,d)pyrene

Phenanthrene

Pyrene

Metals (mg/kg)

Aluminum

Antimony

Arsenic

Barium

Beryllium

Cadmium

Calcium

Chromium

Cobalt

Copper

Iron

Lead

Magnesium

Manganese

Mercury

Nickel

Potassium

Sodium

Vanadium

Zinc





SSSSC

620

840

0.6

300,000

550



3,900

6

19

1,300

0.5

1

NC

NC

59

3,100

NC

59

NC

42

0.1

31

NC

NC

78

600

Location

Sample ID

Date





















































BKG-04

B-R-BKG-04-0.0-2.0

05-Apr-10

0.2 U

0.03 J

0.2 U

0.2 U

0.021 J



8,220

5.7 U

5.4

29.2

0.46 J

0.088 J

1,650

11.5

3 J

13.1

10,800

17

1,720

126

0.033 J

7.5

470 J

3.3 U

472 U

23.4

BKG-04

B-R-BKG-04-3.0-4.0

07-Apr-10

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U



6,820

4.9 U

2.4

12.1 J

0.23 J

0.41 U

164 J

9.9

1.4 J

3.3

6,870

3.5

391 J

37

0.084 U

3.8

385 J

2.9 U

408 U

11

BKG-05

B-R-BKG-05-0.0-2.0

05-Apr-10

0.21 U

0.05 J

0.21 U

0.21 U

0.041 J



10,600

5.3 U

4.3

32.7

0.52

0.096 J

1,790

14.4

3 J

11.5

12,700

22

1,860

100

0.048 J

6.6

628

3.1 U

439 U

21

BKG-05

B-R-BKG-05-3.0-4.0

05-Apr-10

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U



11,400

5.7 U

3.6

15.1 J

0.31 J

0.47 U

203 J

29.4

1.2 J

7.4

12,700

5.4

493

21.1

0.09 U

9.9

443 J

3.3 U

471 U

21.8

WS-BKG-02

B-WS-BKG-02-0.0-2.0

05-Apr-10

0.22 U

0.071 J

0.022 J

0.026 J

0.06 J



7,980

6.1 U

3.4

27.8

0.4 J

0.095 J

506 U

11.2

1.8 J

5.6

8,770

32.7

884

88.7

0.059 J

4.5

407 J

506 U

15.8

23.6

WS-BKG-02

B-WS-BKG-02-3.0-4.0

05-Apr-10

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U



14,500

6.3 U

4.3

15.5 J

0.34 J

0.53 U

143 J

18.4

1.3 J

6

14,200

4.6

379 J

27.5

0.016 J

3.3 J

403 J

528 U

22.8

7.9

WS-01

B-WS-01-000.0-002.0

10-Feb-08

0.19 U

0.2

0.058 J

0.1 J

0.2



8,170 J

0.73 J

4.2 J

25

0.2 J

0.41 U

3130

14

4.1 U

8.2

11,400 J

20.1

1,090

69.4 J

0.033 J

6.2

432

43.5 J

18.9

28.1

WS-01

B-WS-01-008.0-010.0

10-Feb-08

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U



5,440 J

4.4 U

1.2 J

9.2 J

0.1 J

0.36 U

68 J

7.2

3.6 U

6.7

5,950 J

3.1

241 J

12.4 J

0.095 U

2.9 J

233 J

13.9 J

9.6

6.5

WS-01

B-WS-01-015.0-016.0

10-Feb-08

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-01

B-WS-01-020.5-021.0

10-Feb-08

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-01

B-WS-01-021.0-023.0

10-Feb-08

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U



2,020 J

4.9 U

0.84 J

4.9 J

0.048 J

0.41 U

405 U

4.4

4.1 U

1.2 J

1,860 J

3.3

36.2 J

13.9 J

0.015 J

0.5 J

141 J

12.8 J

4.7

4.9 U

WS-02

B-WS-02-000.0-002.0

12-Feb-08

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-02

B-WS-02-009.6-010.4

12-Feb-08

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-02

B-WS-02-023.5-024.5

12-Feb-08

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-03

B-WS-03-000.0-002.0

14-Feb-08

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-03

B-WS-03-008.0-009.0

14-Feb-08

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-03

B-WS-03-013.0-014.0

14-Feb-08

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-03

B-WS-03-019.0-020.0

14-Feb-08

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-03

B-WS-03-022.0-023.0

14-Feb-08

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-04

B-WS-04-000.0-002.0

11-Feb-08

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-04

B-WS-04-014.0-015.0

11-Feb-08

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-04

B-WS-04-019.0-020.0

11-Feb-08

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-04

B-WS-04-023.0-024.0

11-Feb-08

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-05

B-WS-05-000.0-002.0

11-Feb-08

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-05

B-WS-05-017.0-019.0

11-Feb-08

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-05

B-WS-05-022.5-023.5

11-Feb-08

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-07

B-WS-07-000.0-002.0

13-Feb-08

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-07

B-WS-07-007.2-008.2

13-Feb-08

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-07

B-WS-07-021.5-022.5

13-Feb-08

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-08

B-WS-08-000.0-002.0

14-Feb-08

0.18 U

0.18 U

0.18 U

0.018 J

0.18 U



8,600

0.44 J

3.4

25.9

0.29 J

0.42 U

1,010

13.8

4.2 U

4

12,000

9

931

67.8

0.021 J

4.8

421

418 U

18.3

26.2

WS-08

B-WS-08-004.5-006.0

14-Feb-08

0.18 U

0.18 U

0.18 U

0.018 J

0.18 U



2,650 J

4.7 U

0.95

6.1 J

0.081 J

0.39 U

139 J

5.3

3.9 U

2.1

4,200

2.2

264 J

35.6

0.37 U

2.4 J

147 J

394 U

6.4

4.7 U

WS-08

B-WS-X-03-021408

14-Feb-08

0.17 U

0.17 U

0.17 U

0.17 U

0.17 U



4,210 J

4.3 U

1.2

8.9 J

0.088 J

0.36 U

72.7 J

5.9

3.6 U

2.2

4,800

2.2

221 J

32.1

0.018 J

2.6 J

143 J

362 U

6.8

4.3 U

WS-08

B-WS-08-016.0-017.0

14-Feb-08

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-08

B-WS-08-022.0-023.0

14-Feb-08

0.082 J

0.19 U

0.19 U

0.19 U

0.19 U



1,000

0.22 J

0.27 J

2.4 J

0.013 J

0.39 U

67.1 J

3.8

3.9 U

1.1 J

1,300

1.9

38.2 J

4.1

0.36 U

0.39 J

94.3 J

387 U

3.6 J

4.6 U

WS-09

B-WS-09-000.0-002.0

13-Feb-08

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-09

B-WS-09-007.5-008.5

13-Feb-08

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-09

B-WS-09-014.0-015.0

13-Feb-08

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-09

B-WS-X-01-021308

13-Feb-08

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-09

B-WS-09-019.0-020.0

13-Feb-08

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-09

B-WS-09-022.0-023.0

13-Feb-08

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-11

B-WS-11-000.0-002.0

12-Feb-08

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-11

B-WS-11-006.5-007.0

12-Feb-08

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-11

B-WS-11-013.5-014.0

12-Feb-08

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-11

B-WS-11-017.0-018.0

12-Feb-08

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-11

B-WS-11-022.0-023.0

12-Feb-08

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-12

B-WS-12-000.0-002.0

13-Feb-08

0.2 U

0.2 U

0.2 U

0.2 U

0.2 U



10,300

0.31 J

3.2

25.4

0.28 J

0.41 U

622

15.6

5

4.5

14,200

6.6 J

1,230

121

0.1 U

6.1

510

56.8 J

21.1

19.6

WS-12

B-WS-12-009.0-010.0

14-Feb-08

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U



3,970

4.8 U

1.1

10 J

0.2 J

0.4 U

161 J

11.4

4 U

2.7

8,160

2.7 J

514

98.2

0.0092 J

3.4

282 J

404 U

10.9

7.9

WS-12

B-WS-12-022.0-023.0

14-Feb-08

0.2 U

0.2 U

0.2 U

0.2 U

0.2 U



2,190

0.29 J

0.24 J

5.9 J

0.067 J

0.42 U

322 J

5.1

4.2 U

1.9 J

2,330

3 J

165 J

11.2

0.086 U

1.1 J

182 J

418 U

4.7

7.8

WS-13

B-WS-13-000.0-002.0

13-Feb-08

0.19 U

0.19 U

0.19 U

0.19 U

0.025 J



10,400

5 U

3.4

30

0.31 J

0.42 U

2,510

14.2

4.2

10.7

14,100

14.4 J

2,310

86

0.069 J

6.3

409 J

154 J

24.1

64.4

WS-13

B-WS-13-004.0-004.5

13-Feb-08

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U



4,590

0.27 J

1.2

14 J

0.13 J

0.38 U

121 J

8.6

3.8 U

2.1

5,240

3.1 J

690

36.7

0.011 J

3.8

403

381 U

9

8.4

WS-13

B-WS-13-022.0-023.0

13-Feb-08

0.2 U

0.02 J

0.2 U

0.2 U

0.024 J



3,260

0.44 J

0.55 J

9.8 J

0.086 J

0.41 U

326 J

9.6

4.1 U

3.2

4,470

3 J

395 J

37.6

0.022 J

2.7 J

277 J

407 U

7.7

15.8

WS-13

B-WS-X-02-021308

13-Feb-08

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-15

B-WS-15-000.0-002.0

10-Feb-08

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U



5,670

0.25 J

2.9

16.5

0.25 J

0.41 U

258 J

11.2

4.1 U

2.7

14,100

4

695

36.8

0.0083 J

3.6

382 J

192 J

14.6

11

WS-15

B-WS-15-008.0-009.0

10-Feb-08

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U



9,750

5 U

2.1

40.2

0.38 J

0.42 U

317 J

9.9

4.2 U

6

12,800

5.1

1,690

171

0.083 U

8.9

349 J

192 J

16.7

21.1

WS-15

B-WS-15-018.0-019.0

11-Feb-08

0.2 U

0.2 U

0.2 U

0.2 U

0.2 U



905

4.8 U

0.32 J

5.3 J

0.028 J

0.4 U

46.4 J

3.1

4 U

1.3 J

1,610

3

27.6 J

7.1

0.032 J

0.49 J

135 J

15.7 J

3.4 J

4.8 U

WS-19

B-WS-19-000.0-002.0

13-Feb-08

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-19

B-WS-19-015.5-016.5

13-Feb-08

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-19

B-WS-19-022.0-023.0

13-Feb-08

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-26

B-WS-26-018.0-019.0

19-Jan-09

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-27

B-WS-27-018.0-019.0

19-Jan-09

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-28

B-WS-28-008.6-008.8

19-Jan-09

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-28

B-WS-28-018.5-018.7

19-Jan-09

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

Page 3 of 4

-------
Table 1

White Swan Property Soil Detections and Screening Criteria Exceedances
White Swan Cleaners/Sun Cleaners Area Ground Water Contamination Superfund Site





Parameter:

Di-n-butyl phthalate

Fluoranthene

lndeno(1,2,3-c,d)pyrene

Phenanthrene

Pyrene

Metals (mg/kg)

Aluminum

Antimony

Arsenic

Barium

Beryllium

Cadmium

Calcium

Chromium

Cobalt

Copper

Iron

Lead

Magnesium

Manganese

Mercury

Nickel

Potassium

Sodium

Vanadium

Zinc





SSSSC

620

840

0.6

300,000

550



3,900

6

19

1,300

0.5

1

NC

NC

59

3,100

NC

59

NC

42

0.1

31

NC

NC

78

600

Location

Sample ID

Date





















































WS-29

B-WS-29-019.3-019.6

19-Jan-09

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-30

B-WS-30-008.4-008.8

19-Jan-09

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-30

B-WS-30-017.5-017.8

19-Jan-09

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-30

B-WS-30-019.4-019.6

19-Jan-09

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-31

B-WS-31-013.6-013.9

19-Jan-09

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-31

B-WS-31 -018.0-018.2

19-Jan-09

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-31

B-WS-31-019.0-019.2

19-Jan-09

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-32

B-WS-32-019.2-019.4

16-Feb-09

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-33

B-WS-33-018.4-018.7

16-Feb-09

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-34

BA-WS-34-028.3-028.7

16-Feb-09

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-34

BA-WS-X-01-021609

16-Feb-09

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

WS-35

BA-WS-35-026.4-026.8

16-Feb-09

NA

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

Notes:

1.	'SSSSC' designates Site-specific Soil Screening Criteria

= exceeds SSSSC

2.	BOLD = detection

3.	TCL Volatile Organic Compounds and Semi-Volatile Organic Compounds quantitated by Method SOM01.2 or Method 8260B.
TAL Metals quantitated by Method ILM05.3 and ILM05.4.

4.	Results are expressed in milligrams per kilogram (mg/kg).

5.	'NC' indicates screening criteria is not available.

6.	'NA' indicates the parameter was not analyzed for.

7.	'U' designates the analyte is not detected at or above the listed reporting limit.

8.	'J' designates reported concentration is an estimated value.

9. 'R' designates that the reported sample result is not usable.

Page 4 of 4

-------
Table 2

Sun Property Soil Detections and Screening Criteria Exceedances
White Swan Cleaners/Sun Cleaners Area Ground Water Contamination Superfund Site





Parameter:

O)
O)

E

(0
T3
C
D

o

Q.

E
o

o

o
'c
(5
U)

1—

o

Acetone

Chloroform

cis-1,2-Dichloroethylene

Methyl acetate

Methyl Ethyl Ketone

Tetrachloroethylene (PCE)

Toluene

trans-1,2-Dichloroethene

Trichloroethylene (TCE)

Vinyl Chloride

O)
O)

E

(0
T3
C
D

o

Q.

E
o

o

o
'c
(5
U)

o

Acenaphthene

Acetophenone

Anthracene

Benzo(a)anthracene

Benzo(a)pyrene

Benzo(b)fluoranthene

Benzo(g,h,i)perylene

Benzo(k)fluoranthene

Benzyl butyl phthalate

Bis(2-ethylhexyl) phthalate

Caprolactam

Carbazole

Chrysene

Di-n-butyl phthalate

Di-n-octylphthalate

Fluoranthene





SSSSC

o

12

0.2

0.2

14

0.6

0.005

4

0.4

0.007

0.005


(5

































BKG-01

B-R-BKG-01-0.0-2.0

07-Apr-10

O
>

0.0088 U

0.0044 U

0.0044 U

0.0044 U

0.0088 U

0.0044 U

0.0044 U

0.0044 U

0.0044 U

0.0044 U

o

*

0.19 U

0.19 U

0.03 J

0.29

0.44

0.56

0.13 J

0.71

0.19 U

0.03 J

0.19 U

0.051 J

0.49

0.19 U

0.19 U

0.97

BKG-02

B-R-BKG-02-0.0-2.0

07-Apr-10



0.0083 U

0.0042 U

0.0042 U

0.0042 U

0.0083 U

0.0042 U

0.0042 U

0.0042 U

0.0042 U

0.0042 U

'E

0.19 U

0.19 U

0.039 J

0.17 J

0.19 J

0.23

0.054 J

0.25

0.19 U

0.038 J

0.19 U

0.022 J

0.22

0.19 U

0.19 U

0.51

BKG-02

B-R-X-01-040710

07-Apr-10



0.0085 U

0.0043 U

0.0043 U

0.0043 U

0.0085 U

0.0043 U

0.0043 U

0.0043 U

0.0043 U

0.0043 U

w

0.19 U

0.19 U

0.026 J

0.16 J

0.18 J

0.25

0.06 J

0.19 J

0.19 U

0.067 J

0.19 U

0.021 J

0.24

0.19 U

0.19 U

0.42

BKG-03

B-R-BKG-03-0.0-2.0

07-Apr-10



0.009 U

0.0045 U

0.0045 U

0.0045 U

0.009 U

0.0045 U

0.0045 U

0.0045 U

0.0045 U

0.0045 U



0.2 UJ

0.2 U

0.024 J

0.16 J

0.2

0.29

0.065 J

0.26

0.2 U

0.088 J

0.2 U

0.031 J

0.24

0.2 U

0.2 U

0.57

BKG-03

B-R-BKG-03-3.0-4.0

07-Apr-10



0.0082 U

0.0041 U

0.0041 U

0.0041 U

0.0082 U

0.0041 U

0.0041 U

0.0041 U

0.0041 U

0.0041 U



0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.031 J

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

SC-BKG-02

B-SC-BKG-02-0.0-2.0

05-Apr-10



0.01

0.0046 U

0.0046 U

0.0046 U

0.0093 U

0.0046 U

0.0046 U

0.0046 U

0.0046 U

0.0046 U



0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.028 J

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.021 J

SC-BKG-02

B-SC-BKG-02-3.0-4.0

05-Apr-10



0.0096 U

0.0048 U

0.0048 U

0.0048 U

0.0096 U

0.0048 U

0.0048 U

0.0048 U

0.0048 U

0.0048 U



0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

SC-BKG-03

B-SC-BKG-03-0.0-2.0

05-Apr-10



0.011 U

0.0054 U

0.0054 U

0.0054 U

0.011 U

0.0054 U

0.0054 U

0.0054 U

0.0054 U

0.0054 U



0.22 U

0.22 U

0.22 U

0.22 U

0.024 J

0.034 J

0.22 U

0.025 J

0.22 U

0.041 J

0.22 U

0.22 U

0.035 J

0.22 U

0.22 U

0.041 J

SC-BKG-03

B-SC-BKG-03-3.0-4.0

05-Apr-10



0.01 U

0.0051 U

0.0051 U

0.0051 U

0.01 U

0.0051 U

0.0051 U

0.0051 U

0.0051 U

0.0051 U



0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.033 J

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

SC-04

B-SC-04-000.0-002.0

07-Jan-08



0.012 U

0.0071 U

0.0058 U

0.0058 U

0.012 U

0.0058 U

0.0058 U

0.0058 U

0.0058 U

0.0058 U



0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.032 J

0.18 U

SC-04

B-SC-04-005.0-010.0

07-Jan-08



0.01 U

0.0051 U

0.0051 U

0.0051 U

0.01 U

0.0036 J

0.0051 U

0.0051 U

0.0051 U

0.0051 U



0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

SC-04

B-SC-04-012.0-015.0

07-Jan-08



0.01 U

0.005 U

0.005 U

0.005 U

0.01 U

0.005 U

0.005 U

0.005 U

0.005 U

0.005 U



0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

SC-05

B-SC-05-000.0-002.0

08-Jan-08



0.009 U

0.006

0.0045 U

0.0045 U

0.009 U

0.39

0.0045 U

0.0045 U

0.0045 U

0.0045 U



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-05

B-SC-05-008.0-010.0

08-Jan-08



0.0099 U

0.0035 J

0.0049 U

0.0049 U

0.0099 U

0.0049 U

0.0049 U

0.0049 U

0.0049 U

0.0049 U



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-05

B-SC-05-017.0-018.0

08-Jan-08



0.0092 U

0.0041 J

0.0046 U

0.0046 U

0.0092 U

0.19

0.0046 U

0.0046 U

0.0046 U

0.0046 U



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-06

B-SC-06-000.0-002.0

09-Jan-08



2 U

1 u

1 U

1 U

2 U

33

1 U

1 U

1 U

1 U



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-06

B-SC-06-007.0-010.0

09-Jan-08



0.52 U

0.26 U

0.26 U

0.26 U

0.52 U

1.4

0.26 U

0.26 U

0.26 U

0.26 U



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-06

B-SC-06-017.0-018.0

09-Jan-08



0.5 U

0.25 U

0.25 U

0.046 J

0.5 U

0.5

0.25 U

0.25 U

0.25 U

0.25 U



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-07

B-SC-07-000.0-002.0

09-Jan-08



2.9 U

1.5 U

1.5 U

1.5 U

2.9 U

42

1.5 U

1.5 U

1.5 U

1.5 U



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-07

B-SC-07-008.0-010.0

09-Jan-08



4.3 U

2.1 U

31

2.1 U

4.3 U

47

2.1 U

2.1 U

3.8

2.1 U



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-07

B-SC-07-012.0-014.0

09-Jan-08



3.1 U

1.5 U

2.9

1.5 U

3.1 U

51

1.5 U

1.5 U

1.2 J

1.5 U



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-07

B-SC-07-017.5-019.0

09-Jan-08



0.53 U

0.26 U

0.4 J

0.26 U

0.53 U

3.7 J

0.26 U

0.26 U

0.081 J

0.26 U



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-07

B-SC-X-02-010908

09-Jan-08



0.57 U

0.28 U

0.063 J

0.28 U

0.57 U

0.5 J

0.28 U

0.28 U

0.28 U

0.28 U



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-08

B-SC-08-000.0-002.0

07-Jan-08



0.01 U

0.0058 U

0.005 U

0.005 U

0.01 U

0.097

0.005 U

0.005 U

0.0018 J

0.005 U



0.18 U

0.18 U

0.18 U

0.041 J

0.042 J

0.04 J

0.022 J

0.041 J

0.18 U

0.18 U

0.18 U

0.18 U

0.054 J

0.18 U

0.18 U

0.081 J

SC-08

B-SC-08-008.5-010.0

07-Jan-08



0.038

0.0047 U

0.067

0.0047 U

0.014

0.0047 U

0.0047 U

0.0047 U

0.0047 U

0.0047 U



0.04 J

0.024 J

0.064 J

0.11 J

0.12 J

0.12 J

0.053 J

0.095 J

0.022 J

0.21 U

0.069 J

0.035 J

0.13 J

0.082 J

0.21 U

0.3

SC-08

B-SC-08-014.0-016.5

07-Jan-08



0.05

0.005 U

0.19

0.005 U

0.018

0.029 J

0.0037 J

0.005 U

0.069 J

0.0071



0.2 U

0.2 U

0.2 U

0.025 J

0.023 J

0.028 J

0.2 U

0.2 U

0.2 U

0.2 U

0.2 U

0.2 U

0.028 J

0.2 U

0.2 U

0.05 J

SC-09

B-SC-09-000.0-002.0

07-Jan-08



0.01 u

0.005 U

0.005 U

0.005 U

0.01 u

0.005 U

0.005 U

0.005 U

0.005 U

0.005 U



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-09

B-SC-09-007.5-009.5

07-Jan-08



0.009 U

0.0045 U

0.0045 U

0.0045 U

0.009 U

0.11

0.0045 U

0.0045 U

0.0045 U

0.0045 U



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-09

B-SC-09-013.0-014.0

07-Jan-08



0.018

0.005 U

0.0043 U

0.0043 U

0.0043 J

0.0043 U

0.0043 U

0.0043 U

0.0043 U

0.0043 U



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-12

B-SC-12-000.0-002.0

08-Jan-08



0.45 U

0.23 U

0.66

0.23 U

0.45 U

1.1

0.23 U

0.23 U

0.068 J

0.23 U



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-12

B-SC-12-005.0-008.0

08-Jan-08



0.0091 U

0.0045 J

0.0041 J

0.0045 U

0.0091 U

0.097

0.0045 U

0.0045 U

0.0045 U

0.0045 U



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-12

B-SC-12-018.0-019.0

08-Jan-08



0.46 U

0.23 U

0.23 U

0.23 U

0.46 U

0.68

0.23 U

0.23 U

0.23 U

0.23 U



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-13

B-SC-13-000.0-002.0

10-Jan-08



0.51 U

0.25 U

0.067 J

0.25 U

0.51 U

3.5

0.25 U

0.25 U

0.083 J

0.25 U



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-13

B-SC-13-006.0-006.5

10-Jan-08



1.9 U

0.97 U

0.97 U

0.97 U

1.9 U

32

0.97 U

0.97 U

0.33 J

0.97 U



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-13

B-SC-13-010.5-011.0

10-Jan-08



0.52 U

0.26 U

0.26 U

0.26 U

0.52 U

4

0.26 U

0.26 U

0.057 J

0.26 U



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-13

B-SC-13-012.0-014.0

10-Jan-08



0.013 U

0.0067 U

0.0067 U

0.0067 U

0.013 U

0.0067 U

0.0067 U

0.0067 U

0.0067 U

0.0067 U



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-13

B-SC-13-016.5-017.0

10-Jan-08



0.58 U

0.29 U

0.29 U

0.29 U

0.58 U

5 J

0.29 U

0.29 U

0.29 U

0.29 U



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-13

B-SC-X-03-011008

10-Jan-08



0.012 U

0.0062 U

0.0062 U

0.0062 U

0.012 U

0.0055 J

0.0062 U

0.0062 U

0.0062 U

0.0062 U



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-14

B-SC-14-000.0-002.0

08-Jan-08



0.46 U

0.23 U

0.26

0.23 U

0.46 U

6.2

0.23 U

0.23 U

0.21 J

0.23 U



0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

SC-14

B-SC-14-005.0-006.0

08-Jan-08



0.49 U

0.24 U

0.24 U

0.24 U

0.49 U

6.6

0.24 U

0.24 U

0.051 J

0.24 U



0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

SC-14

B-SC-14-018.0-019.0

08-Jan-08



0.011 U

0.0058

0.055 J

0.0053 U

0.011 U

0.29

0.0053 U

0.002 J

0.084

0.0053 U



0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.034 J

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

SC-14

B-SC-X-01 -010808

08-Jan-08



0.0098 U

0.0046 J

0.03 J

0.0049 U

0.0098 U

0.15 J

0.0049 U

0.0049 U

0.0068

0.0049 U



0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.019 J

0.18 U

0.06 J

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

SC-15

B-SC-15-000.0-002.0

09-Jan-08



0.0084 U

0.0042 U

0.0016 J

0.0042 U

0.0084 U

0.073

0.0042 U

0.0042 U

0.0042 U

0.0042 U



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-15

B-SC-15-003.0-005.0

09-Jan-08



0.49 U

0.25 U

0.25 U

0.25 U

0.49 U

1.3

0.25 U

0.25 U

0.25 U

0.25 U



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-15

B-SC-15-016.5-017.5

09-Jan-08



0.44 U

0.22 U

0.12 J

0.22 U

0.44 U

2.8

0.22 U

0.22 U

0.053 J

0.22 U



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-18

B-SC-18-000.0-002.0

08-Jan-08



0.41 U

0.2 U

0.2 U

0.2 U

0.41 U

0.74

0.2 U

0.2 U

0.2 U

0.2 U



0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

SC-18

B-SC-18-005.0-006.0

08-Jan-08



0.43 U

0.21 U

0.21 U

0.21 U

0.43 U

1.6

0.21 U

0.21 U

0.21 U

0.21 U



0.17 U

0.018 J

0.17 U

0.17 U

0.029 J

0.17 U

0.17 U

0.17 U

0.17 U

0.17 U

0.17 U

0.17 U

0.048 J

0.17 U

0.17 U

0.17 U

SC-18

B-SC-18-012.0-013.0

08-Jan-08



0.52 U

0.26 U

0.26 U

0.26 U

0.52 U

0.48

0.26 U

0.26 U

0.26 U

0.26 U



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-18

B-SC-18-017.0-019.0

08-Jan-08



0.009 U

0.0053

0.031

0.0045 U

0.009 U

0.47

0.0045 U

0.0045 U

0.016

0.0045 U



0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

SC-19

B-SC-19-000.0-002.0

10-Jan-08



0.0099 U

0.005 U

0.005 U

0.005 U

0.0099 U

0.029

0.005 U

0.005 U

0.005 U

0.005 U



0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

SC-19

B-SC-19-008.0-010.0

10-Jan-08



0.013 U

0.0066 U

0.0066 U

0.0066 U

0.013 U

0.0066 U

0.0066 U

0.0066 U

0.0066 U

0.0066 U



0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

0.18 U

SC-19

B-SC-19-012.0-014.0

10-Jan-08



0.012 U

0.0059 U

0.0044 J

0.0059 U

0.012 U

0.0087

0.0059 U

0.0059 U

0.0059 U

0.0059 U



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-19

B-SC-19-016.0-017.5

10-Jan-08



0.5 U

0.25 U

0.25 U

0.25 U

0.5 U

2.3

0.25 U

0.25 U

0.25 U

0.25 U



0.17 U

0.02 J

0.17 U

0.17 U

0.17 U

0.17 U

0.17 U

0.17 U

0.017 J

0.17 U

0.17 U

0.17 U

0.17 U

0.17 U

0.17 U

0.17 U

SC-21

B-SC-21-000.0-002.0

10-Jan-08



0.01 U

0.0051 U

0.0051 U

0.0051 U

0.01 U

0.014

0.0051 U

0.0051 U

0.0051 U

0.0051 U



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-21

B-SC-21-008.5-010.0

10-Jan-08



0.49 U

0.25 U

0.25 U

0.25 U

0.49 U

0.34

0.25 U

0.25 U

0.25 U

0.25 U



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-21

B-SC-21-015.0-016.0

10-Jan-08



0.46 U

0.23 U

0.23 U

0.23 U

0.46 U

0.34

0.23 U

0.23 U

0.23 U

0.23 U



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

Notes:

1.	'SSSSC' designates Site-specific Soil Screening Criteria

= exceeds SSSSC

2.	BOLD = detection

3.	TCL Volatile Organic Compounds and Semi-Volatile Organic Compounds quantitated by Method SOM01.2.
TAL Metals quantitated by Method ILM05.3 and ILM05.4.

4.	Results are expressed in milligrams per kilogram (mg/kg).

5.	'NC' indicates screening criteria is not available.

6.	'NA' indicates the parameter was not analyzed for.

7.'U'	designates the analyte is not detected at or above the listed reporting limit.

8.	'J' designates reported concentration is an estimated value.

Page 1 of 2

-------
Table 2

Sun Property Soil Detections and Screening Criteria Exceedances
White Swan Cleaners/Sun Cleaners Area Ground Water Contamination Superfund Site





Parameter:

Fluorene

lndeno(1,2,3-c,d)pyrene

Phenanthrene

Pyrene

Metals (mg/kg)

Aluminum

Antimony

Arsenic

Barium

Beryllium

Cadmium

Calcium

Chromium

Cobalt

Copper

Iron

Lead

Magnesium

Manganese

Mercury

Nickel

Potassium

Selenium

Sodium

Vanadium

Zinc





SSSSC

110

0.6

300,000

550



3,900

6

19

1,300

0.5

1

NC

NC

59

3,100

NC

59

NC

42

0.1

31

NC

7

NC

78

600

Location

Sample ID

Date





















































BKG-01

B-R-BKG-01-0.0-2.0

07-Apr-10

0.19 U

0.13 J

0.27

0.47



8,060

6.1 U

1.7

10.2 J

0.48 J

0.079 J

3,630

17.9

8.5

54.5

17,400

19.5

6,440

222

0.03 J

14

195 J

3.6 U

511 U

29.9

23.3

BKG-02

B-R-BKG-02-0.0-2.0

07-Apr-10

0.19 U

0.058 J

0.2

0.25



2,400

4.8 U

1.4

9 J

0.11 J

0.12 J

1,510

5.7

0.71 J

6.9

3,530

19.6

593

36.5

0.03 J

1.7 J

206 J

2.8 U

399 U

7.1

27.1

BKG-02

B-R-X-01-040710

07-Apr-10

0.19 U

0.069 J

0.2

0.25



2,820

5.5 U

1.4

8.9 J

0.13 J

0.12 J

1,360

6

1.1 J

8.5

4,110

20.4

605

39

0.029 J

2.8 J

171 J

3.2 U

456 U

8.7

24.5

BKG-03

B-R-BKG-03-0.0-2.0

07-Apr-10

0.2 U

0.073 J

0.21

0.27



5,530 J

5.8 U

10.6 J

34.6

0.24 J

0.15 J

904

13.9

1.2 J

6.4

7,150

149

533

39.1

0.048 J

2.9 J

375 J

3.4 U

487 U

12.6

36.9

BKG-03

B-R-BKG-03-3.0-4.0

07-Apr-10

0.18 U

0.18 U

0.18 U

0.18 U



5,360

4.3 U

2.5

12.8 J

0.2 J

0.36 U

221 J

8.8

1.2 J

3.5

6,120

11

397

24.6

0.0063 J

2.7 J

225 J

2.5 U

361 U

10.7

9.7

SC-BKG-02

B-SC-BKG-02-0.0-2.0

05-Apr-10

0.19 U

0.19 U

0.19 U

0.024 J



5,020

6.1 U

5.6

15.5 J

0.18 J

0.084 J

505 U

7.8

0.8 J

4.9

6,920

55.6

305 J

30.2

0.027 J

2 J

165 J

3.5 U

505 U

11.8

32.8

SC-BKG-02

B-SC-BKG-02-3.0-4.0

05-Apr-10

0.18 U

0.18 U

0.18 U

0.18 U



2,320

5.5 U

1.9

4.5 J

0.12 J

0.46 U

459 U

8.7

0.7 J

1.2 J

5,100

2.5

169 J

18.3

0.086 U

2.2 J

151 J

3.2 U

459 U

6.1

5.2 J

SC-BKG-03

B-SC-BKG-03-0.0-2.0

05-Apr-10

0.22 U

0.22 U

0.022 J

0.037 J



11,800

6.6 U

6.4

28.2

0.39 J

0.24 J

855

16.1

2.1 J

9.7

13,200

125

957

53.8

0.07 J

6

321 J

3.8 U

549 U

27.4

74.3

SC-BKG-03

B-SC-BKG-03-3.0-4.0

05-Apr-10

0.18 U

0.18 U

0.18 U

0.18 U



4,320

5 U

2.3

7.5 J

0.2 J

0.41 U

23.7 J

8.9

1.2 J

2.4

7,130

2

233 J

26.4

0.1 u

1.9 J

354 J

2.9 U

414 U

13.1

4.4 J

SC-04

B-SC-04-000.0-002.0

07-Jan-08

0.18 U

0.18 U

0.18 U

0.18 U



546

4.9 U

0.81 U

2 J

0.41 U

0.41 U

57.5 J

2.2

4.1 U

2 U

537

6.7

26.8 J

2.9

0.1 u

3.2 U

46.4 J

2.8 U

5.2 J

2.1 J

4.9 U

SC-04

B-SC-04-005.0-010.0

07-Jan-08

0.18 U

0.18 U

0.18 U

0.18 U



2,740

4.5 U

0.66 J

4.9 J

0.37 U

0.37 U

117 J

4.7

3.7 U

1.9 U

3,320

3.2

140 J

13.2

0.097 U

3 U

103 J

0.25 J

6.8 J

6.3

4.5 U

SC-04

B-SC-04-012.0-015.0

07-Jan-08

0.19 U

0.19 U

0.19 U

0.19 U



2,750

5.1 U

0.78 J

4 J

0.42 U

0.42 U

425 U

4.3

4.2 U

2.1 U

2,910

2

81.8 J

5.8

0.093 U

3.4 U

101 J

3 U

4.3 J

6.2

5.1 U

SC-05

B-SC-05-000.0-002.0

08-Jan-08

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-05

B-SC-05-008.0-010.0

08-Jan-08

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-05

B-SC-05-017.0-018.0

08-Jan-08

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-06

B-SC-06-000.0-002.0

09-Jan-08

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-06

B-SC-06-007.0-010.0

09-Jan-08

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-06

B-SC-06-017.0-018.0

09-Jan-08

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-07

B-SC-07-000.0-002.0

09-Jan-08

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-07

B-SC-07-008.0-010.0

09-Jan-08

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-07

B-SC-07-012.0-014.0

09-Jan-08

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-07

B-SC-07-017.5-019.0

09-Jan-08

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-07

B-SC-X-02-010908

09-Jan-08

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-08

B-SC-08-000.0-002.0

07-Jan-08

0.18 U

0.023 J

0.038 J

0.078 J



5,130

4.5 U

1.8 U

11.3 J

0.37 U

0.37 U

31,100

7.5

3.7 U

4

6,620

15.4

10,900

39.8

0.017 J

3 U

212 J

0.29 J

33 J

13.6

13.4

SC-08

B-SC-08-008.5-010.0

07-Jan-08

0.037 J

0.055 J

0.25

0.24



6,890

0.36 J

3.3

276

0.48 U

0.48

2,070

10.1

4.8 U

4.3

7,770

102

569

31.3

0.071 J

3.8 U

270 J

0.27 J

21.1 J

14.1

375

SC-08

B-SC-08-014.0-016.5

07-Jan-08

0.2 U

0.2 U

0.025 J

0.042 J



8,530

5.5 U

1.8

23

0.46 U

0.46 U

1,030

11.2

4.6 U

2.3 U

8,130

9.4

496

31.2

0.014 J

3.7 U

304 J

0.52 J

16.9 J

15.3

19.9

SC-09

B-SC-09-000.0-002.0

07-Jan-08

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-09

B-SC-09-007.5-009.5

07-Jan-08

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-09

B-SC-09-013.0-014.0

07-Jan-08

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-12

B-SC-12-000.0-002.0

08-Jan-08

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-12

B-SC-12-005.0-008.0

08-Jan-08

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-12

B-SC-12-018.0-019.0

08-Jan-08

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-13

B-SC-13-000.0-002.0

10-Jan-08

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-13

B-SC-13-006.0-006.5

10-Jan-08

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-13

B-SC-13-010.5-011.0

10-Jan-08

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-13

B-SC-13-012.0-014.0

10-Jan-08

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-13

B-SC-13-016.5-017.0

10-Jan-08

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-13

B-SC-X-03-011008

10-Jan-08

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-14

B-SC-14-000.0-002.0

08-Jan-08

0.19 U

0.19 U

0.19 U

0.19 U



8,070

5.3 U

2.9

19.3

0.44 U

0.44 U

167 J

12.4

4.4 U

3.3

10,100

5.1

826

54.4

0.1 U

4

342 J

0.22 J

18.9 J

18

12.5

SC-14

B-SC-14-005.0-006.0

08-Jan-08

0.18 U

0.18 U

0.18 U

0.18 U



5,700

5 U

2.4

12.3 J

0.41 U

0.41 U

420

12.4

4.1 U

3.4

8,110

5.4

707

33.9

0.012 J

4.1

206 J

0.28 J

64.1 J

15.2

9.8

SC-14

B-SC-14-018.0-019.0

08-Jan-08

0.19 U

0.19 U

0.19 U

0.19 U



493 J

5 U

0.83 U

1.4 J

0.42 U

0.42 U

416 U

2.4 J

4.2 U

1.8 U

1,120 J

0.96

10.5 J

6 J

0.095 U

3.3 U

47.8 J

2.9 U

416 U

1.8 J

5 U

SC-14

B-SC-X-01 -010808

08-Jan-08

0.18 U

0.18 U

0.18 U

0.18 U



1,090 J

4.8 U

0.64 J

2.4 J

0.4 U

0.4 U

67.3 J

6.8 J

0.38 J

2 U

2,530 J

1.1

73 J

9.1 J

0.099 U

0.93 J

55 J

0.25 J

7.3 J

4.8

4.8 U

SC-15

B-SC-15-000.0-002.0

09-Jan-08

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-15

B-SC-15-003.0-005.0

09-Jan-08

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-15

B-SC-15-016.5-017.5

09-Jan-08

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-18

B-SC-18-000.0-002.0

08-Jan-08

0.18 U

0.18 U

0.18 U

0.18 U



4,940

4.7 U

2.3

8.5 J

0.029 J

0.039 J

275 J

8

3.9 U

3.1

6,940

12.3

257 J

25

0.08 U

3.1 U

140 J

2.7 U

23.4 J

12.3

7.4

SC-18

B-SC-18-005.0-006.0

08-Jan-08

0.17 U

0.17 U

0.022 J

0.17 U



2,090

4.6 U

0.88

3.9 J

0.38 U

0.38 U

350 J

12.3

0.92 J

3

4,820

6

338 J

20.3

0.017 J

1.8 J

71.1 J

2.7 U

30 J

8.1

4.6 U

SC-18

B-SC-18-012.0-013.0

08-Jan-08

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-18

B-SC-18-017.0-019.0

08-Jan-08

0.18 U

0.18 U

0.18 U

0.18 U



344

5 U

0.83 U

1.4 J

0.41 U

0.41 U

414 U

1.6

0.11 J

2 U

874

0.83 U

4 J

2

0.086 U

3.3 U

33.4 J

2.9 U

414 U

1.3 J

5 U

SC-19

B-SC-19-000.0-002.0

10-Jan-08

0.18 U

0.18 U

0.18 U

0.18 U



2,140

4.7 U

1.1

4.2 J

0.39 U

0.39 U

388 U

4.8

0.67 J

1.9 U

3,030

0.96

149 J

15.5

0.08 U

1.2 J

388 U

2.7 U

4.3 J

6.9

4.7 U

SC-19

B-SC-19-008.0-010.0

10-Jan-08

0.18 U

0.18 U

0.18 U

0.18 U



1,030

4.7 U

0.3 J

2.6 J

0.39 U

0.39 U

393 U

3.9

0.37 J

2 U

1,830

0.88

36.7 J

7.7

0.09 U

0.41 J

393 U

2.8 U

393 U

3.6 J

4.7 U

SC-19

B-SC-19-012.0-014.0

10-Jan-08

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-19

B-SC-19-016.0-017.5

10-Jan-08

0.17 U

0.17 U

0.17 U

0.17 U



1,540

4.4 U

1.2

3.1 J

0.37 U

0.37 U

64.5 J

8.6

0.74 J

1.8 U

4,080

1.6

107 J

17.1

0.089 U

0.99 J

366 U

2.6 U

5.2 J

7.8

4.4 U

SC-21

B-SC-21-000.0-002.0

10-Jan-08

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-21

B-SC-21-008.5-010.0

10-Jan-08

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

SC-21

B-SC-21-015.0-016.0

10-Jan-08

NA

NA

NA

NA



NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

Notes:

1.	'SSSSC' designates Site-specific Soil Screening Criteria

= exceeds SSSSC

2.	BOLD = detection

3.	TCL Volatile Organic Compounds and Semi-Volatile Organic Compounds quantitated by Method SOM01.2.
TAL Metals quantitated by Method ILM05.3 and ILM05.4.

4.	Results are expressed in milligrams per kilogram (mg/kg).

5.	'NC' indicates screening criteria is not available.

6.	'NA' indicates the parameter was not analyzed for.

7.	'U' designates the analyte is not detected at or above the listed reporting limit.

8.	'J' designates reported concentration is an estimated value.

Page 2 of 2

-------
Table 3

Judas Creek Surface Water Detections and Screening Criteria Exceedances
White Swan Cleaners/Sun Cleaners Area Ground Water Contamination Superfund Site

Parameter:

O)
3

(0
T3
C
3

o

Q.

E
o

o

o
'c
(5
U)

1—

o

Acetone

Chloromethane

cis-1,2-Dichloroethylene

Tert-Butyl Methyl Ether

Tetrachloroethylene (PCE)

Toluene

Trichloroethylene (TCE)

O)
3

(0
T3
C
3

o

Q.

E
o

o

o
'c
(5
U)

O

Benzo(a)anthracene

Benzo(a)pyrene

Benzo(b)fluoranthene

Benzo(g,h,i)perylene

Benzo(k)fluoranthene

Bis(2-ethylhexyl) phthalate

Chrysene

Di-n-butyl phthalate

Fluoranthene

lndeno(1,2,3-c,d)pyrene

Phenanthrene

Phenol

Pyrene

Pesticides/PCBs (ug/L)

alpha Endosulfan

Total Metals (ug/L)

Aluminum

NJDEP SWQC

o

NC

NC

NC

70

0.34

1,300

1

o

0.038

0.0038

0.038

NC

0.38

1.2

3.8

2,000

130

0.038

NC

10,000

830

62

NC

Location

Sample ID

Date

to
o

ft

o

JC-02

SW-JC-02-121707

17-Dec-07

>

5 U

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

5.1 U

5.1 U

5.1 U

5.1 U

5.1 U

5.1 U

5.1 U

5.1 U

5.1 U

5.1 U

5.1 U

5.1 U

5.1 U

0.051 U

2,960

JC-02

S W-J C-X-01-121707

17-Dec-07

5 U

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

E

-------
Table 3

Judas Creek Surface Water Detections and Screening Criteria Exceedances
White Swan Cleaners/Sun Cleaners Area Ground Water Contamination Superfund Site

Parameter:

Arsenic

Barium

Beryllium

Cadmium

Calcium

Chromium

Cobalt

Copper

Cyanide

Iron

Lead

Magnesium

Manganese

Mercury

Nickel

Potassium

Selenium

Sodium

Thallium

Vanadium

Zinc

Dissolved Metals (ug/L)

Aluminum

NJDEP SWQC

0.017

2,000

6

3.4

NC

92

NC

1,300

140

NC

5

NC

NC

0.05

500

NC

170

NC

0.24

NC

7,400

NC

Location

Sample ID

Date

JC-02

SW-JC-02-121707

17-Dec-07

10 U

23.5 J

5 U

5 U

6,720

10.9

50 U

26.2

10 U

3,190 J

74.3 J

1,930 J

31.2 J

0.14 J

2.9 J

3,500 J

35 U

16,400

25 U

10.4 J

66.9

210

JC-02

SW-JC-X-01-121707

17-Dec-07

5.4 J

26.7 J

0.18 J

5 U

6,840

15.8

1.2 J

34.6

10 U

4,110 J

128 J

2,220 J

38.6

0.28

4 J

3,640 J

35 U

20,900

25 U

13.3 J

75.5

354

JC-03

SW-JC-03-121707

17-Dec-07

10 U

200 U

5 U

5 U

5,280

10 U

50 U

25 U

10 U

1,100

6.1 J

1,900 J

50 J

0.2 U

1.3 J

4,460 J

35 U

13,300

25 U

2.5 J

47.2 J

268

JC-03

SW-JC-03-061708

17-Jun-08

10 u

19.8 J

5 U

5 U

6,480

5.2 J

0.78 J

14.1 J

1.7 J

1,640

18.5

1,340 J

37.8

0.037 J

40 U

2,640 J

35 U

2,610 J

25 U

4.7 J

46.4 J

70.2 J

JC-04

SW-JC-04-121807

18-Dec-07

10 u

200 U

5 U

5 U

6,600

10 U

50 U

25.5

10 U

1,240

74.3

1,920 J

21

0.2 U

2.9 J

4,330 J

35 U

35,200

25 U

4.7 J

52.7 J

379

JC-04

SW-JC-04-061708

17-Jun-08

3.8 J

39.3 J

0.36 J

5 U

17,000

23.5

0.9 J

10.9 J

10 u

6,380

13.3

4,150 J

33.6

0.037 J

40 U

5,300

35 U

44,000

25 U

17.1 J

61.5

54.1 J

JC-04AS

S W-J C-04A-061708

17-Jun-08

5.1 J

24.4 J

5 U

5 U

11,400

2.1 J

0.46 J

18 J

1.7 J

1,930

9.4 J

2,310 J

100

0.2 U

40 U

3,280 J

35 U

15,800

25 U

1.9 J

65.1

65.1 J

JC-04Aw

SW-JC-04A-121807

18-Dec-07

4.4 J

49.9 J

5 U

0.38 J

23,300

10 U

1.5 J

41.9

4.5 J

4,170

41.5

5,780

143

0.2 U

6 J

4,630 J

35 U

165,000

25 U

10.9 J

218

154 J

JC-05

SW-JC-05-121807

18-Dec-07

10 u

18.1 J

5 U

5 U

7,530

10 u

50 U

11.8 J

10 u

782

8.1 J

2,140 J

28.2

0.2 U

1.6 J

3,890 J

35 U

64,200

25 U

2.4 J

61

157 J

JC-05

SW-JC-05-061708

17-Jun-08

10 u

54.3 J

5 U

0.5 J

14,000

1.4 J

1.8 J

5.6 J

10 u

510

10 U

5,000 U

83.6

0.2 U

3 J

3,620 J

35 U

35,500

25 U

1.2 J

60 U

200 U

JC-06

SW-JC-06-121807

18-Dec-07

10 u

27.1 J

5 U

5 U

15,400

10 u

50 U

6.2 J

10 u

503

4 J

3,900 J

46.4

0.2 U

1.6 J

4,410 J

35 U

43,000

25 U

50 U

47.7 J

200 U

JC-06

SW-JC-06-061608

16-Jun-08

11.3

138 J

1.2 J

5 U

19,600

32

50 U

71.2

10 u

19,400

151

5,520

192

0.14 J

14.4 J

4,100 J

35 U

21,800

25 U

29.7 J

286

200 U

JC-07

SW-JC-07-121807

18-Dec-07

3.4 J

30.7 J

0.15 J

5 U

7,390

10 u

1.4 J

15.9 J

10 u

3,400

23.5

2,240 J

71

0.038 J

3.2 J

4,100 J

35 U

34,400

25 U

7.5 J

70.1

232

JC-07

SW-JC-07-061608

16-Jun-08

10 u

47.6 J

5 U

5 U

15,800

4.8 J

50 U

13 J

4.8 J

4,010 J

21.9 J

3,720 J

107 J

0.2 U

3.3 J

3,230 J

35 U

22,000 J

25 U

4.8 J

48.7 U

200 U

JC-07

SW-JC-X-01 -061608

16-Jun-08

10 u

31.6 J

5 U

5 U

15,100

0.83 J

0.98 J

3.8 J

10 u

582 J

10 U

3,830 J

47.8 J

0.2 U

2.3 J

3,040 J

35 U

32,000 J

25 U

0.86 J

28.9 U

54.6 J

JC-08

SW-JC-08-121807

18-Dec-07

4 J

71.4 J

1 J

5 U

20,600

10 u

1.6 J

11 J

10 u

11,400

9.7 J

5,740

205

0.037 J

2.6 J

4,600 J

35 U

27,000

25 U

7.8 J

203

200 U

JC-08

SW-JC-08-061608

16-Jun-08

10 u

43.1 J

5 U

5 U

21,700

10 u

50 U

3 J

10 UJ

661

10 U

5,590

38.2

0.2 U

1.7 J

3,780 J

35 U

37,700

25 U

50 U

27 U

200 U

JC-09

SW-JC-09-121807

18-Dec-07

10 u

48.4 J

5 U

5 U

24,700

1.5 J

50 U

5.4 J

10 u

1,360

7.7 J

5,390

45.9

0.2 U

0.94 J

3,610 J

35 U

30,300

25 U

1.5 J

43.6 J

200 U

JC-09

SW-JC-09-061608

16-Jun-08

10 u

44.3 J

1.2 J

5 U

7,580

1.1 J

0.71 J

5.8 J

10 u

3,170

10 U

2,310 J

68.3

0.2 U

40 U

3,340 J

35 U

13,500

25 U

2 J

58 U

200 U

JC-10

SW-JC-10-121707

17-Dec-07

10 u

41.3 J

0.31 J

5 U

22,900

10 u

50 U

25 U

10 u

1,180

2.8 J

4,810 J

46.8 J

0.2 U

0.89 J

3,340 J

35 U

37,800

25 U

50 U

37.1 J

200 U

JC-10

SW-JC-10-061608

16-Jun-08

10 u

46.6 J

0.45 J

5 U

17,800

1.1 J

50 U

4.6 J

10 u

1,440

10 U

4,370 J

50

0.2 U

40 U

3,640 J

35 U

23,000

25 U

1 J

34 U

200 U

JC-11

SW-JC-11-121707

17-Dec-07

10 u

35.7 J

0.12 J

0.58 J

38,900

10 u

50 U

25 U

10 u

1,240

5.5 J

60,500

39.7 J

0.2 U

1.1 J

21,200

35 U

508,000

25 U

50 U

40.5 J

200 U

JC-11

SW-JC-11-061608

16-Jun-08

10 u

36.5 J

5 U

0.64 J

43,000

0.91 J

50 U

5.4 J

10 u

868

10 U

85,000

37.3

0.2 U

40 U

29,500

35 U

738,000

3.4 J

50 U

23.9 U

200 U

JC-12

SW-JC-12-121707

17-Dec-07

4.7 J

14.4 J

5 U

0.69 J

292,000

10 u

50 U

25 U

10 u

1,070

10 u

931,000

2.9 J

0.2 U

40 U

271,000

3.4 J

7,970,000

25 U

50 U

60 U

119 J

JC-12

SW-JC-12-061608

16-Jun-08

7.1 J

16.4 J

5 U

1 J

287,000

3.8 J

50 U

9.4 J

10 u

2,200

10 u

929,000

34.3

0.2 U

40 U

291,000

35 U

8,060,000

7.7 J

1.9 J

20 UJ

200 U

Notes:

1.	'NJDEP SWQC' designates the New Jersey Surface Water Quality Criteria (Fresh Water- Human Health)

= exceeds NJDEP SWQC

2.	BOLD = detection

3.	TCL Volatile Organic Compounds, Semi-Volatile Organic Compounds and Pesticides/PCBs quantitated by Method SOM01.2
TAL Metals quantitated by Method ILM05.3 and ILM05.4.

4.	Results are expressed in micrograms per liter (ug/L).

5.	'NC' indicates screening criteria is not available.

6.	'NA' indicates the parameter was not analyzed for.

7.	'IT designates the analyte is not detected at or above the listed reporting limit.

8.	'J' designates reported concentration is an estimated value.

9.	'UJ' designates that the analyte was not detected at or above the listed reporting limit; the limit is an approximate value.

Page 2 of 3

-------
Table 3

Judas Creek Surface Water Detections and Screening Criteria Exceedances
White Swan Cleaners/Sun Cleaners Area Ground Water Contamination Superfund Site

Parameter:
NJDEP SWQC

Arsenic

Barium

Beryllium

Cadmium

Calcium

Chromium

Cobalt

Copper

Iron

Lead

Magnesium

Manganese

Mercury

Nickel

Potassium

Sodium

Thallium

Vanadium

Zinc

0.017

2,000

6

3.4

NC

92

NC

1,300

NC

5

NC

NC

0.05

500

NC

NC

0.24

NC

7,400

Location

Sample ID

Date

JC-02

SW-JC-02-121707

17-Dec-07

10 U

200 U

5 U

5 U

6,050

10 U

4.1 J

25 U

254 J

9.9 J

1,510 J

22.9 J

0.2 U

2 J

3,200 J

15,000

25 U

1.4 J

41.1 J

JC-02

S W-J C-X-01-121707

17-Dec-07

10 U

200 U

5 U

5 U

6,290

10 U

3.7 J

25 U

408

16.5 J

1,530 J

22.9

0.2 U

1.4 J

3,280 J

16,000

25 U

2 J

42.2 J

JC-03

SW-JC-03-121707

17-Dec-07

10 U

200 U

5 U

5 U

5,200

10 U

5.3 J

25 U

336

6.3 J

1,820 J

55.7 J

0.2 U

1.4 J

4,430 J

10,000

25 U

50 U

45.6 J

JC-03

SW-JC-03-061708

17-Jun-08

3.9 J

12.9 J

5 U

5 U

5,940

1.8 J

1.6 J

9.8 J

317

11.9

1,090 J

33.5

0.2 U

40 U

2,490 J

2,560 J

25 U

1.5 J

28.9 J

JC-04

SW-JC-04-121807

18-Dec-07

10 U

200 U

5 U

5 U

6,640

10 U

4.1 J

23.8 J

518

64.3

1,890 J

23.9

0.2 U

3.3 J

4,330 J

36,700

25 U

3.2 J

47.1 J

JC-04

SW-JC-04-061708

17-Jun-08

10 u

20.6 J

5 U

5 U

16,200

1.1 J

2.3 J

3 J

98.9 J

3.7 J

3,780 J

30

0.058 J

40 U

4,330 J

44,700

25 U

2.4 J

16.7 J

JC-04 As

SW-JC-04A-061708

17-Jun-08

4.1 J

20.6 J

5 U

5 U

10,700

1.6 J

1.9 J

13.8 J

1,280

7.7 J

2,160 J

70.3

0.2 U

40 U

2,990 J

14,800

25 U

1.2 J

55.8 J

JC-04 Aw

S W-J C-04 A-121807

18-Dec-07

10 u

27.9 J

5 U

5 U

20,400

10 U

4.5 J

16 J

266

9 J

4,670 J

108

0.2 U

2.9 J

4,160 J

161,000

25 U

1.6 J

98.9

JC-05

SW-JC-05-121807

18-Dec-07

10 u

20.5 J

5 U

5 U

9,180

10 u

4.2 J

8.7 J

227

4.7 J

2,600 J

38.1

0.2 U

1.9 J

3,840 J

67,800

25 U

1.2 J

59.3 J

JC-05

SW-JC-05-061708

17-Jun-08

10 u

46.7 J

5 U

5 U

13,300

10 u

1.4 J

3 J

89.8 J

10 U

5,000 U

73

0.2 U

40 U

4,120 J

31,900

25 U

50 U

60 U

JC-06

SW-JC-06-121807

18-Dec-07

10 u

27.9 J

5 U

5 U

15,200

10 u

2.6 J

4.5 J

267

10 u

3,840 J

48

0.2 U

1.6 J

4,360 J

42,400

25 U

50 U

45.1 J

JC-06

SW-JC-06-061608

16-Jun-08

10 u

36.5 J

5 U

5 U

14,800

10 u

50 U

2.8 J

201

10 u

3,740 J

43.3

0.2 U

40 U

2,960 J

31,000

25 U

50 U

27.1 U

JC-07

SW-JC-07-121807

18-Dec-07

10 u

200 U

5 U

5 U

5,940

10 u

4.3 J

7.3 J

386

3 J

1,800 J

42.5

0.2 U

1 J

3,770 J

35,900

25 U

50 U

31.2 J

JC-07

SW-JC-07-061608

16-Jun-08

10 u

30.6 J

5 U

5 U

14,200

0.83 J

50 U

3.9 J

433 J

10 u

3,230 J

87.1

0.2 U

40 U

3,040 J

20,400

25 U

50 U

20 U

JC-07

SW-JC-X-01 -061608

16-Jun-08

10 u

33.2 J

5 U

5 U

15,100

0.77 J

50 U

2.8 J

652 J

10 u

3,390 J

90

0.2 U

40 U

3,080 J

21,600

25 U

50 U

20 U

JC-08

SW-JC-08-121807

18-Dec-07

4.1 J

47 J

5 U

5 U

20,300

10 u

50 U

25 U

4,560

10 u

5,240

155

0.044 J

40 U

4,480 J

27,600

25 U

50 U

165

JC-08

SW-JC-08-061608

16-Jun-08

10 u

41.2 J

5 U

5 U

20,800

10 u

50 U

25 U

200 U

10 u

5,380

36.1

0.2 U

1.8 J

3,640 J

36,300

25 U

50 U

25.6 U

JC-09

SW-JC-09-121807

18-Dec-07

10 u

42.2 J

5 U

5 U

22,800

0.32 J

2.3 J

3.1 J

347

10 u

4,930 J

41.4

0.2 U

40 U

3,280 J

29,200

25 U

50 U

27.7 J

JC-09

SW-JC-09-061608

16-Jun-08

10 u

40.4 J

0.62 J

5 U

7,840

10 u

1.8 J

3.2 J

1,110

10 u

2,380 J

64.6

0.2 U

40 U

3,390 J

14,100

25 U

0.79 J

34.1 U

JC-10

SW-JC-10-121707

17-Dec-07

10 u

38.4 J

0.13 J

5 U

23,000

10 u

5.3 J

25 U

222

10 u

4,830 J

46.7 J

0.2 U

0.86 J

3,320 J

38,100

25 U

50 U

32.6 J

JC-10

SW-JC-10-061608

16-Jun-08

10 u

50.3 J

5 U

5 U

18,000

10 u

1.5 J

2.3 J

579

10 u

4,430 J

49.8

0.2 U

40 U

3,610 J

23,400

25 U

50 U

30.3 U

JC-11

SW-JC-11-121707

17-Dec-07

10 u

31.2 J

5 U

0.39 J

41,100

10 u

1.6 J

25 U

263

10 u

67,600

40 J

0.2 U

1.4 J

23,500

566,000

25 U

50 U

34.9 J

JC-11

SW-JC-11-061608

16-Jun-08

10 u

31.5 J

5 U

0.49 J

44,200

10 u

0.66 J

2 J

206

10 u

89,700

39

0.2 U

40 U

31,300

777,000

4.3 J

50 U

20 U

JC-12

SW-JC-12-121707

17-Dec-07

5.8 J

14 J

5 U

0.78 J

296,000

10 u

50 U

25 U

33.2 J

10 u

931,000

15 U

0.2 U

40 U

277,000

8,020,000

25 U

50 U

60 U

JC-12

SW-JC-12-061608

16-Jun-08

3.6 J

11.7 J

5 U

0.72 J

283,000

10 u

50 U

1.7 J

200 U

10 u

914,000

21.7

0.2 U

40 U

293,000

8,130,000

8.1 J

50 U

20 UJ

Notes:

1.	'NJDEP SWQC' designates the New Jersey Surface Water Quality Criteria (Fresh Water- Human Health)

= exceeds NJDEP SWQC

2.	BOLD = detection

3.	TCL Volatile Organic Compounds, Semi-Volatile Organic Compounds and Pesticides/PCBs quantitated by Method SOM01.2
TAL Metals quantitated by Method ILM05.3 and ILM05.4.

4.	Results are expressed in micrograms per liter (ug/L).

5.	'NC' indicates screening criteria is not available.

6.	'NA' indicates the parameter was not analyzed for.

7.	'IT designates the analyte is not detected at or above the listed reporting limit.

8.	'J' designates reported concentration is an estimated value.

9.	'UJ' designates that the analyte was not detected at or above the listed reporting limit; the limit is an approximate value.

Page 3 of 3

-------
Table 4

Hannabrand Brook Surface Water Detections and Screening Criteria Exceedances
White Swan Cleaners/Sun Cleaners Area Ground Water Contamination Superfund Site

Parameter:
NJDEP SWQC

Volatile Organic Compounds (ug/L)

Acetone

Carbon Disulfide

cis-1,2-Dichloroethylene

Tert-Butyl Methyl Ether

Tetrachloroethylene (PCE)

Toluene

Trichloroethylene (TCE)

Vinyl Chloride

Semi-Volatile Organic Compounds (ug/L)

Benzyl butyl phthalate

Bis(2-ethylhexyl) phthalate

Diethyl phthalate

Di-n-butyl phthalate

Fluoranthene

Phenol

Pyrene

Pesticides/PCBs (ug/L)

Endrin Aldehyde

Total Metals (ug/L)

Aluminum

Arsenic

Barium

Beryllium

Cadmium

NC

NC

NC

70

0.34

1,300

1

0.082

150

1.2

17,000

2,000

130

10,000

830

0.059

NC

0.017

2,000

6

3.4

Location

Sample ID

Date

HB-01

SW-HB-01-121907

19-Dec-07

5 U

0.5 U

0.5 U

0.44 J

0.5 U

0.5 U

0.5 U

0.5 U

5.1 U

1.2 J

5.1 U

5.1 U

5.1 U

5.1 U

5.1 U

0.098 U

152 J

10 U

43.3 J

0.31 J

0.27 J

HB-01

SW-HB-01-061808

18-Jun-08

1.4 J

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

4.8 U

0.65 J

4.8 U

4.8 U

4.8 U

4.8 U

4.8 U

0.097 U

94.5 J

10 U

50.3 J

5 U

5 U

HB-02

SW-HB-02-121907

19-Dec-07

2 J

0.51

0.5 U

0.39 J

0.5 U

0.5 U

0.5 U

0.5 U

4.8 U

4.8 U

4.8 U

4.8 U

4.8 U

4.8 U

4.8 U

0.096 U

147 J

10 U

43.7 J

5 U

5 U

HB-02

SW-HB-02-061808

18-Jun-08

5 U

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

0.63 J

1.1 J

4.9 U

0.51 J

4.9 U

1.6 J

4.9 U

0.1 U

631

10 U

56.9 J

0.53 J

5 U

HB-03

SW-HB-03-121907

19-Dec-07

1.6 J

1.4

0.5 U

0.32 J

0.5 U

0.5 U

0.5 U

0.5 U

5 U

5 U

5 U

5 U

5 U

5 U

5 U

0.1 U

126 J

10 U

41 J

5 U

5 U

HB-03

SW-HB-03-061808

18-Jun-08

5 U

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

5.1 U

5.1 U

5.1 U

5.1 U

5.1 U

5.1 U

5.1 U

0.096 U

80.9 J

10 U

52 J

5 U

5 U

HB-04

SW-HB-04-121907

19-Dec-07

2.2 J

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

5.1 U

0.7 J

5.1 U

5.1 U

5.1 U

5.1 U

5.1 U

0.1 U

287

10 U

34.8 J

5 U

5 U

HB-04

SW-HB-04-061808

18-Jun-08

3.9 J

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

5 U

5 U

5 U

5 U

5 U

5 U

5 U

0.1 U

569

10 U

44.2 J

5 U

0.56 J

HB-05

SW-HB-05-121907

19-Dec-07

1.9 J

0.74

0.5 U

0.31 J

0.5 U

0.5 U

0.5 U

0.5 U

6.5 U

2.2 J

6.5 U

6.5 U

6.5 U

6.5 U

6.5 U

0.14 U

163 J

10 U

45.7 J

5 U

5 U

HB-05

SW-HB-05-061808

18-Jun-08

5 U

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

4.9 U

4.9 U

4.9 U

4.9 U

4.9 U

4.9 U

4.9 U

0.099 U

101 J

10 U

52.6 J

5 U

5 U

HB-06

SW-HB-06-121907

19-Dec-07

2 J

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

5.2 U

0.78 J

5.2 U

5.2 U

5.2 U

5.2 U

5.2 U

0.093 U

314

10 U

33.5 J

5 U

5 U

HB-06

S W-H B-06-061708

17-Jun-08

3.3 J

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

5.3 U

5.3 U

5.3 U

5.3 U

5.3 U

5.3 U

5.3 U

0.1 U

156 J

10 U

36.5 J

5 U

5 U

HB-07

SW-HB-07-121907

19-Dec-07

1.7 J

0.5 U

0.5 U

0.28 J

0.5 U

0.5 U

0.5 U

0.5 U

5.2 U

5.2 U

5.2 U

5.2 U

5.2 U

5.2 U

5.2 U

0.1 U

103 J

10 U

41.2 J

5 U

5 U

HB-07

SW-HB-07-061708

17-Jun-08

5 U

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

5 U

5 U

5 U

5 U

5 U

5 U

5 U

0.098 U

97.4 J

10 u

47.3 J

5 U

5 U

HB-08

SW-HB-08-121907

19-Dec-07

2.1 J

1.3

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

4.8 U

4.8 U

4.8 U

4.8 U

4.8 U

4.8 U

4.8 U

0.093 U

194 J

10 u

38.2 J

5 U

5 U

HB-08

SW-H B-08-061708

17-Jun-08

5 U

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

5.2 U

5.2 U

5.2 U

5.2 U

5.2 U

5.2 U

5.2 U

0.099 U

104 J

10 u

40.7 J

5 U

5 U

HB-09

SW-HB-09-121907

19-Dec-07

2.4 J

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

4.9 U

4.9 U

4.9 U

4.9 U

4.9 U

4.9 U

4.9 U

0.098 U

251

10 u

35.2 J

5 U

5 U

HB-09

SW-H B-09-061708

17-Jun-08

1.7 J

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

4.8 U

4.8 U

4.8 U

4.8 U

4.8 U

4.8 U

4.8 U

0.094 U

134 J

10 u

44.4 J

5 U

5 U

HB-10

SW-HB-10-121907

19-Dec-07

1.5 J

1.7

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

1 J

0.75 J

4.9 U

4.9 U

4.9 U

4.9 U

4.9 U

0.11 U

168 J

10 u

200 U

5 U

5 U

HB-10

SW-HB-10-061708

17-Jun-08

2.1 J

0.5 U

0.5 U

0.5 U

1.1

0.5 U

0.5 U

0.5 U

5 U

5 U

5 U

5 U

5 U

5 U

5 U

0.097 U

197 J

10 u

13.2 J

5 U

5 U

HB-11

SW-HB-11-121807

18-Dec-07

1.7 J

13

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

4.7 U

4.7 U

4.7 U

4.7 U

4.7 U

4.7 U

4.7 U

0.094 U

190 J

10 u

15.7 J

5 U

5 U

HB-11

SW-HB-11-061708

17-Jun-08

5

0.5 U

0.38 J

0.26 J

16

1.7

0.35 J

0.5 U

4.8 U

4.8 U

4.8 U

4.8 U

4.8 U

0.89 J

4.8 U

0.094 U

92.9 J

10 u

39.3 J

5 U

5 U

HB-12

SW-HB-12-121807

18-Dec-07

5 U

27

0.87

0.5 U

0.32 J

0.5 U

0.3 J

0.5 U

1 J

6.9 U

6.9 U

6.9 U

1.2 J

6.9 U

0.91 J

0.13 U

19,000

7.8 J

170 J

1.1 J

2.8 J

HB-12

SW-HB-12-061608

16-Jun-08

1.9 J

0.5 U

2.6

0.5 U

0.8

2.4

1

0.39 J

0.71 J

4.7 U

4.7 U

4.7 U

4.7 U

4.7 U

4.7 U

0.1 U

18,100

23.8

212

1.6 J

5 U

HB-13

SW-HB-13-121907

19-Dec-07

2.2 J

0.5 U

0.5 U

0.5 U

0.23 J

0.5 U

0.5 U

0.5 U

4.9 U

0.85 J

4.9 U

4.9 U

4.9 U

4.9 U

4.9 U

0.099 U

442

10 u

38 J

5 U

0.39 J

HB-13

SW-HB-13-061708

17-Jun-08

5 U

0.5 U

0.5 U

0.5 U

0.3 J

0.5 U

0.5 U

0.5 U

4.8 U

4.8 U

4.8 U

4.8 U

4.8 U

0.87 J

4.8 U

0.095 U

114 J

10 u

43.3 J

5 U

5 U

HB-14

SW-HB-14-121807

18-Dec-07

5 U

1.4 J

2.1

0.5 U

5.9

0.5 U

1

0.5 U

5 U

5 U

5 U

5 U

5 U

5 U

5 U

0.1 U

276

3.8 J

34.7 J

5 U

5 U

HB-14

SW-HB-14-061608

16-Jun-08

2 J

0.5 U

0.5 U

0.5 U

0.5

0.5 U

0.5 U

0.5 U

0.79 J

4.7 U

4.7 U

4.7 U

4.7 U

4.7 U

4.7 U

0.059 J

83.5 J

10 u

35.6 J

5 U

5 U

HB-15

SW-HB-15-121807

18-Dec-07

5 U

0.5 U

0.5 U

0.5 U

0.25 J

0.5 U

0.5 U

0.5 U

5 U

5 U

0.67 J

0.61 J

5 U

5 U

5 U

0.11 u

450

10 u

33.4 J

0.21 J

5 U

HB-15

SW-HB-X-02-121807

18-Dec-07

1.9 J

7.6

0.5 U

0.5 U

0.24 J

0.5 U

0.5 U

0.5 U

4.9 U

0.61 J

4.9 U

4.9 U

4.9 U

4.9 U

4.9 U

0.1 u

427

10 u

35.5 J

5 U

5 U

HB-15

SW-HB-15-061608

16-Jun-08

2.4 J

0.5 U

0.5 U

0.5 U

0.23 J

0.5 U

0.5 U

0.5 U

4.7 U

4.7 U

4.7 U

4.7 U

4.7 U

4.7 U

4.7 U

0.096 U

104 J

10 u

38.3 J

5 U

5 U

HB-16

SW-HB-16-121707

17-Dec-07

5 U

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

6.2 U

6.2 U

6.2 U

6.2 U

6.2 U

6.2 U

6.2 U

0.1 U

425

10 u

23.5 J

0.17 J

0.9 J

HB-16

SW-HB-16-061608

16-Jun-08

6.1

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

1 J

4.8 U

4.8 U

0.55 J

4.8 U

4.8 U

4.8 U

0.096 U

683 J

10 u

27.2 J

5 U

5 U

HB-16

SW-H B-X-02-061608

16-Jun-08

6.3

0.5 U

0.5 U

0.22 J

0.5 U

0.5 U

0.5 U

0.5 U

2.7 J

2.4 J

4.7 U

0.69 J

4.7 U

1 J

4.7 U

0.096 U

328 J

10 u

26.4 J

5 U

5 U

HB-17

SW-HB-17-121707

17-Dec-07

5 U

0.5 U

0.5 U

1.3

0.5 U

0.5 U

0.5 U

0.5 U

5 U

5 U

5 U

5 U

5 U

5 U

5 U

0.098 U

784

10 u

37.6 J

5 U

5 U

HB-17

SW-HB-17-061608

16-Jun-08

5.1

0.5 U

0.5 U

1.4

0.5 U

0.5 U

0.5 U

0.5 U

0.59 J

4.7 U

4.7 U

4.7 U

4.7 U

4.7 U

4.7 U

0.095 U

200 U

2.6 J

31.1 J

5 U

5 U

HB-18

SW-HB-18-121707

17-Dec-07

5 U

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

5 U

5 U

5 U

5 U

5 U

5 U

5 U

0.099 U

487

10 u

27.3 J

5 U

0.8 J

HB-18

SW-HB-18-061608

16-Jun-08

5.5

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

0.5 U

0.57 J

4.7 U

4.7 U

4.7 U

4.7 U

4.7 U

4.7 U

0.1 U

200 U

10 u

20.3 J

5 U

5 U

Notes:

1.	'NJDEP SWQC' designates the New Jersey Surface Water Quality Criteria (Fresh Water- Human Health)

= exceeds NJDEP SWQC

2.	TCL Volatile Organic Compounds quantitated by Method SOM01.2.

3.	BOLD = detection

4.	TCL Volatile Organic Compounds, Semi-Volatile Organic Compounds and Pesticides/PCBs quantitated by method SOM01.2.
TAL Metals quantitated by Method ILM05.3 and ILM05.4.

5.	Results are expressed in micrograms per liter (ug/L).

6.	'NC' indicates screening criteria is not available.

7.	'NA' indicates the parameter was not analyzed for.

8.'U'	designates the analyte is not detected at or above the listed reporting limit.

9.	'J' designates reported concentration is an estimated value.

10.	'UJ' designates that the analyte was not detected at or above the listed reporting limit; the limit is an approximate value.

Page 1 of 3

-------
Table 4

Hannabrand Brook Surface Water Detections and Screening Criteria Exceedances
White Swan Cleaners/Sun Cleaners Area Ground Water Contamination Superfund Site

Parameter:

Calcium

Chromium

Cobalt

Copper

Cyanide

Iron

Lead

Magnesium

Manganese

Mercury

Nickel

Potassium

Sodium

Thallium

Vanadium

Zinc

Dissolved Metals (ug/L)

Aluminum

Arsenic

Barium

Beryllium

Cadmium

NJDEP SWQC

NC

92

NC

1,300

140

NC

5

NC

NC

0.05

500

NC

NC

0.24

NC

7,400

NC

0.017

2,000

6

3.4

Location

Sample ID

Date

HB-01

SW-HB-01-121907

19-Dec-07

8,000

10 U

1.9 J

25 U

10 U

564

10 U

3,760 J

71.8

0.031 J

2 J

2,580 J

22,600

25 U

50 U

20.7 J

200 U

10 U

41.6 J

0.16 J

5 U

HB-01

SW-HB-01-061808

18-Jun-08

7,360

10 U

50 U

3.7 J

2.7 J

1,190

10 U

3,660 J

46.3

0.2 U

40 U

2,620 J

16,400

25 U

50 U

60 U

200 U

10 U

49.9 J

5 U

5 U

HB-02

SW-HB-02-121907

19-Dec-07

8,460

10 U

1.7 J

25 U

10 U

521

10 U

3,820 J

63.2

0.07 J

1.8 J

2,670 J

22,400

25 U

50 U

17.6 J

200 U

10 U

45 J

5 U

5 U

HB-02

SW-HB-02-061808

18-Jun-08

8,260

0.72 J

50 U

7 J

1.8 J

3,080

10 U

3,780 J

107

0.2 U

3.4 J

2,640 J

16,600

25 U

2.6 J

60 U

74.4 J

10 U

46.8 J

5 U

5 U

HB-03

SW-HB-03-121907

19-Dec-07

8,690

10 u

1.5 J

25 U

10 U

476

10 U

3,700 J

59.9

0.039 J

1.4 J

2,600 J

23,100

25 U

50 U

17 J

200 U

10 U

44.6 J

5 U

5 U

HB-03

SW-HB-03-061808

18-Jun-08

8,520

10 u

50 U

3.2 J

1.9 J

973

10 U

3,690 J

42.4

0.2 U

2.1 J

2,710 J

19,100

25 U

0.73 J

60 U

200 U

10 U

46.3 J

5 U

5 U

HB-04

SW-HB-04-121907

19-Dec-07

8,070

10 u

1.3 J

4.8 J

10 U

953

10 U

2,760 J

72.3

0.2 U

12.5 J

2,820 J

28,600

25 U

50 U

21 J

124 J

10 U

35.7 J

5 U

5 U

HB-04

SW-HB-04-061808

18-Jun-08

8,730

2.1 J

50 U

7.1 J

2.8 J

2,920

10 U

2,920 J

74.6

0.2 U

8.6 J

2,850 J

26,800

25 U

1.5 J

60 U

77.3 J

10 U

38.3 J

5 U

5 U

HB-05

SW-HB-05-121907

19-Dec-07

8,730

10 u

1.7 J

25 U

10 U

518

10 U

3,650 J

61.4

0.087 J

1.4 J

2,580 J

23,300

25 U

50 U

17.2 J

200 U

10 U

44.4 J

5 U

5 U

HB-05

SW-HB-05-061808

18-Jun-08

8,430

10 u

50 U

2.2 J

2 J

902

10 U

3,590 J

38.2

0.2 U

40 U

2,710 J

19,000

25 U

0.54 J

60 U

200 U

10 U

49.8 J

5 U

5 U

HB-06

SW-HB-06-121907

19-Dec-07

7,410

10 u

50 U

5.1 J

10 U

1,010

10 U

2,520 J

72.2

0.2 U

11.8 J

2,660 J

27,300

25 U

50 U

20.3 J

130 J

10 U

31.8 J

5 U

5 U

HB-06

SW-H B-06-061708

17-Jun-08

7,550

0.81 J

50 U

2.1 J

10 u

1,750

2 J

2,710 J

33.5

0.2 U

40 U

2,760 J

26,000

25 U

0.63 J

5.2 J

68.8 J

10 U

29.8 J

5 U

5 U

HB-07

SW-HB-07-121907

19-Dec-07

8,710

10 u

50 U

25 U

10 u

591

10 U

3,510 J

59.2

0.2 U

1.9 J

2,520 J

22,900

25 U

50 U

16.2 J

200 U

10 U

41.6 J

5 U

5 U

HB-07

SW-H B-07-061708

17-Jun-08

8,770

0.72 J

0.69 J

2.5 J

10 u

885

10 u

3,620 J

38.7

0.05 J

40 U

2,760 J

19,200

25 U

50 U

10.9 J

200 U

10 u

43.5 J

5 U

5 U

HB-08

SW-HB-08-121907

19-Dec-07

7,910

10 u

50 U

3.2 J

10 u

855

10 u

2,980 J

71.5

0.029 J

6.9 J

2,690 J

25,200

25 U

50 U

17.9 J

113 J

10 u

34.7 J

5 U

5 U

HB-08

SW-H B-08-061708

17-Jun-08

8,120

0.69 J

0.52 J

25 U

10 u

1,230

10 u

3,180 J

36.8

0.2 U

40 U

2,780 J

22,200

25 U

50 U

7.6 J

200 U

10 u

42.4 J

5 U

5 U

HB-09

SW-HB-09-121907

19-Dec-07

7,790

10 u

50 U

4 J

10 u

914

10 u

2,750 J

70.4

0.2 U

9.8 J

2,700 J

26,200

25 U

50 U

20.1 J

138 J

10 u

35.7 J

5 U

5 U

HB-09

SW-H B-09-061708

17-Jun-08

8,170

0.68 J

0.47 J

2.1 J

10 u

1,570

2.2 J

3,070 J

54.6

0.2 U

40 U

2,880 J

24,600

25 U

50 U

8.9 J

72.5 J

10 u

42.4 J

5 U

5 U

HB-10

SW-HB-10-121907

19-Dec-07

4,440 J

10 u

50 U

7 J

10 u

201

10 u

1,490 J

15 U

0.2 U

40 U

2,710 J

9,300

25 U

50 U

28.9 J

200 U

10 u

200 U

5 U

5 U

HB-10

SW-H B-10-061708

17-Jun-08

6,070

0.94 J

1.4 J

10.4 J

10 u

1,040

3.9 J

1,330 J

89.6

0.2 U

40 U

2,450 J

5,020

25 U

1.3 J

11.5 J

59.4 J

3.3 J

11.7 J

5 U

5 U

HB-11

SW-HB-11-121807

18-Dec-07

7,890

0.48 J

50 U

5.3 J

10 u

2,040

10 u

2,400 J

38.6

0.2 U

40 U

3,040 J

12,900

25 U

50 U

40.4 J

115 J

10 u

200 U

5 U

5 U

HB-11

SW-H B-11-061708

17-Jun-08

17,000

0.62 J

0.41 J

25 U

2.1 J

1,900

1.2 J

5,000

29.6

0.2 U

40 U

3,230 J

21,100

25 U

50 U

11.8 J

200 U

10 u

42.8 J

5 U

5 U

HB-12

SW-HB-12-121807

18-Dec-07

29,600

26.8

4.8 J

51.6

10 u

15,900

237

7,090

106

0.36

31.5 J

5,560

19,300

25 U

33.5 J

181

132 J

10 u

22.2 J

5 U

5 U

HB-12

SW-H B-12-061608

16-Jun-08

35,800

27.5

50 U

67.2

2 J

33,900

238

7,520

156

0.34

38.8 J

5,940

18,600

25 U

37.4 J

201

200 U

4.6 J

35.3 J

5 U

5 U

HB-13

SW-HB-13-121907

19-Dec-07

8,250

10 U

1.3 J

5.3 J

10 u

1,220

3.9 J

2,960 J

75.2

0.2 U

10.5 J

2,830 J

27,000

25 U

50 U

24.4 J

132 J

10 u

32.2 J

5 U

0.36 J

HB-13

SW-H B-13-061708

17-Jun-08

7,910

0.71 J

0.6 J

1.8 J

10 u

1,430

10 U

2,950 J

47.3

0.2 U

40 U

2,710 J

23,200

25 U

50 U

6.9 J

200 U

10 u

41.2 J

5 U

5 U

HB-14

SW-HB-14-121807

18-Dec-07

22,800

10 u

50 U

25 U

10 u

900

10 u

6,090

56.4

0.2 U

1.1 J

3,460 J

14,800

25 U

50 U

27.9 J

200 U

10 u

31.7 J

5 U

5 U

HB-14

SW-H B-14-061608

16-Jun-08

9,040

0.62 J

50 U

2.8 J

10 u

1,360

10 u

3,080 J

32.5

0.2 U

3.3 J

2,720 J

23,900

25 U

50 U

20 U

200 U

10 u

33.8 J

5 U

5 U

HB-15

SW-HB-15-121807

18-Dec-07

8,720

10 u

50 U

5.5 J

10 u

1,190

10 u

2,870 J

78.7

0.2 U

8.8 J

2,560 J

26,900

25 U

50 U

20.5 J

137 J

10 u

31.2 J

5 U

5 U

HB-15

SW-H B-X-02-121807

18-Dec-07

9,260

1 J

1.4 J

5.7 J

10 u

1,150

2.8 J

3,040 J

83.7

0.2 U

9.4 J

2,690 J

28,000

25 U

50 U

21 J

175 J

10 u

33.4 J

5 U

5 U

HB-15

SW-H B-15-061608

16-Jun-08

8,480

10 u

50 U

3.2 J

10 u

1,650

10 u

3,080 J

35

0.2 U

4 J

2,570 J

24,900

25 U

50 U

20 U

200 U

10 u

31.2 J

5 U

5 U

HB-16

SW-HB-16-121707

17-Dec-07

77,100

10 u

50 U

25 U

10 u

898

2.8 J

226,000

41.1

0.2 U

5.2 J

71,300

1,860,000

25 U

50 U

10 J

200 U

10 u

28.6 J

5 U

0.92 J

HB-16

SW-H B-16-061608

16-Jun-08

23,800

2.6 J

50 U

9.1 J

10 u

3,900 J

10 u

47,800

65.6

0.2 U

3.8 J

17,600

398,000

3.7 J

2.8 J

20.5 U

200 U

10 u

22.6 J

5 U

5 U

HB-16

SW-H B-X-02-061608

16-Jun-08

24,800

1.4 J

50 U

6.2 J

10 u

2,340 J

4.5 J

52,100

51.8

0.2 U

3.8 J

18,700

432,000

25 U

2.1 J

20 U

200 U

10 u

18.4 J

5 U

5 U

HB-17

SW-HB-17-121707

17-Dec-07

12,900

10 u

50 U

25 U

10 u

2,100

13.8

3,340 J

38

0.2 U

1.3 J

3,110 J

23,900

25 U

2.1 J

31.4 J

200 U

10 u

29.3 J

5 U

5 U

HB-17

SW-H B-17-061608

16-Jun-08

16,000

0.58 J

50 U

5.7 J

3.9 J

2,620

10 u

4,900 J

90.8

0.2 U

40 U

2,980 J

27,400

25 U

1.6 J

20 U

200 U

10 u

23.3 J

5 U

5 U

HB-18

SW-HB-18-121707

17-Dec-07

76,100

10 u

50 U

25 U

10 u

1,050

10 u

219,000

44.2

0.2 U

5.4 J

69,400

1,800,000

25 U

50 U

11.1 J

109 J

10 u

25.3 J

5 U

0.78 J

HB-18

SW-H B-18-061608

16-Jun-08

120,000

1 J

50 UJ

3.4 J

10 u

708

10 u

362,000

27.3

0.2 U

40 U

112,000

3,080,000

4.7 J

50 UJ

20 UJ

200 U

10 u

21.5 J

5 U

5 U

Notes:

1.	'NJDEP SWQC' designates the New Jersey Surface Water Quality Criteria (Fresh Water- Human Health)

= exceeds NJDEP SWQC

2.	TCL Volatile Organic Compounds quantitated by Method SOM01.2.

3.	BOLD = detection

4.	TCL Volatile Organic Compounds, Semi-Volatile Organic Compounds and Pesticides/PCBs quantitated by method SOM01.2.
TAL Metals quantitated by Method ILM05.3 and ILM05.4.

5.	Results are expressed in micrograms per liter (ug/L).

6.	'NC' indicates screening criteria is not available.

7.	'NA' indicates the parameter was not analyzed for.

8.	'U' designates the analyte is not detected at or above the listed reporting limit.

9.	'J' designates reported concentration is an estimated value.

10.	'UJ' designates that the analyte was not detected at or above the listed reporting limit; the limit is an approximate value.

Page 2 of 3

-------
Table 4

Hannabrand Brook Surface Water Detections and Screening Criteria Exceedances
White Swan Cleaners/Sun Cleaners Area Ground Water Contamination Superfund Site

Parameter:
NJDEP SWQC

Calcium

Chromium

Cobalt

Copper

Iron

Lead

Magnesium

Manganese

Mercury

Nickel

Potassium

Selenium

Silver

Sodium

Thallium

Vanadium

Zinc

NC

92

NC

1,300

NC

5

NC

NC

0.05

500

NC

170

170

NC

0.24

NC

7,400

Location

Sample ID

Date

HB-01

SW-HB-01-121907

19-Dec-07

7,740

10 U

4.6 J

25 U

301

10 U

3,600 J

68.4

0.029 J

1.9 J

2,530 J

35 U

10 U

21,900

25 U

50 U

19.1 J

HB-01

SW-HB-01-061808

18-Jun-08

7,400

10 U

50 U

2.5 J

757

10 U

3,600 J

46.6

0.2 U

2.2 J

2,500 J

35 U

10 U

16,400

25 U

0.79 J

60 U

HB-02

SW-HB-02-121907

19-Dec-07

8,420

10 U

4 J

25 U

336

10 U

3,780 J

65.9

0.033 J

1.9 J

2,660 J

35 U

10 U

22,300

25 U

50 U

18.6 J

HB-02

SW-HB-02-061808

18-Jun-08

7,660

0.59 J

50 U

3.1 J

628

10 U

3,570 J

45.4

0.2 U

1.9 J

2,580 J

35 U

10 U

16,300

25 U

0.87 J

60 U

HB-03

SW-HB-03-121907

19-Dec-07

8,700

10 u

3.9 J

25 U

258

10 U

3,750 J

62.9

0.2 U

1.8 J

2,580 J

35 U

10 U

23,200

25 U

50 U

18.2 J

HB-03

SW-HB-03-061808

18-Jun-08

8,280

10 u

50 U

3.1 J

540

10 U

3,640 J

40.5

0.2 U

40 U

2,700 J

35 U

10 U

18,600

3.2 J

0.63 J

60 U

HB-04

SW-HB-04-121907

19-Dec-07

7,770

10 u

4.3 J

3.4 J

460

10 U

2,640 J

75.8

0.2 U

11.8 J

2,700 J

35 U

10 U

27,800

25 U

50 U

19.1 J

HB-04

SW-HB-04-061808

18-Jun-08

8,520

0.56 J

50 U

3 J

1,480

10 U

2,820 J

69

0.2 U

5.4 J

2,850 J

35 U

10 U

26,500

25 U

50 U

60 U

HB-05

SW-HB-05-121907

19-Dec-07

8,760

10 u

1.5 J

25 U

225

10 U

3,710 J

58.8

0.2 U

1.2 J

2,610 J

35 U

10 U

23,300

25 U

50 U

17.4 J

HB-05

SW-HB-05-061808

18-Jun-08

8,840

10 u

50 U

2.5 J

503

10 U

3,750 J

37.8

0.2 U

40 U

2,740 J

35 U

10 U

19,900

25 U

50 U

60 U

HB-06

SW-HB-06-121907

19-Dec-07

7,360

10 u

4.3 J

4 J

476

10 U

2,530 J

74.5

0.2 U

11.3 J

2,660 J

35 U

10 U

27,400

25 U

50 U

19.7 J

HB-06

SW-H B-06-061708

17-Jun-08

7,580

0.82 J

1.9 J

3.6 J

1,080

10 U

2,730 J

27.4

0.029 J

40 U

2,890 J

35 U

10 U

26,200

25 U

50 U

4.4 J

HB-07

SW-HB-07-121907

19-Dec-07

8,790

10 u

4.3 J

25 U

377

10 U

3,620 J

64.9

0.2 U

1.3 J

2,610 J

35 U

10 U

23,400

25 U

50 U

17.7 J

HB-07

SW-H B-07-061708

17-Jun-08

8,740

10 u

2 J

25 U

508

10 U

3,630 J

39.7

0.033 J

40 U

2,760 J

35 U

10 u

19,200

25 U

50 U

10 J

HB-08

SW-HB-08-121907

19-Dec-07

7,840

10 u

4.5 J

25 U

574

10 u

2,990 J

80.1

0.2 U

7.1 J

2,570 J

35 U

10 u

25,100

25 U

50 U

17.7 J

HB-08

SW-H B-08-061708

17-Jun-08

8,270

0.76 J

1.2 J

1.8 J

761

10 u

3,230 J

35.9

0.2 U

40 U

2,910 J

35 U

10 u

22,700

25 U

50 U

7.3 J

HB-09

SW-HB-09-121907

19-Dec-07

7,990

10 u

2.6 J

25 U

514

10 u

2,840 J

69.6

0.2 U

9.1 J

2,780 J

35 U

10 u

27,100

25 U

50 U

19.4 J

HB-09

SW-H B-09-061708

17-Jun-08

7,970

0.64 J

1.9 J

25 U

917

10 u

3,000 J

48.1

0.2 U

40 U

2,760 J

35 U

10 u

24,200

25 U

50 U

7.3 J

HB-10

SW-HB-10-121907

19-Dec-07

4,180 J

10 u

2.3 J

6.1 J

75.6 J

10 u

1,460 J

15 U

0.2 U

40 U

2,660 J

35 U

10 u

9,210

25 U

50 U

16.6 J

HB-10

SW-H B-10-061708

17-Jun-08

5,980

0.91 J

2.9 J

8.1 J

552

1.4 J

1,320 J

86.5

0.2 U

40 U

2,540 J

35 U

10 u

4,220 J

25 U

1.3 J

13.2 J

HB-11

SW-HB-11-121807

18-Dec-07

5,290

10 u

2.6 J

5.4 J

285

10 u

1,640 J

15 U

0.2 U

40 U

2,740 J

35 U

10 u

10,500

25 U

50 U

25.8 J

HB-11

SW-H B-11-061708

17-Jun-08

17,500

10 u

1.2 J

25 U

1,340

2.1 J

5,120

34

0.2 U

40 U

3,200 J

35 U

10 u

21,700

25 U

50 U

11.8 J

HB-12

SW-HB-12-121807

18-Dec-07

14,800

10 u

2.3 J

25 U

396

10 u

4,430 J

32.3

0.2 U

0.98 J

3,790 J

35 U

10 u

28,300

25 U

50 U

12.8 J

HB-12

SW-H B-12-061608

16-Jun-08

18,800

10 u

50 U

1.7 J

2,390

10 u

4,660 J

58.3

0.2 U

40 U

4,540 J

35 U

10 u

18,600

25 U

0.52 J

20 U

HB-13

SW-HB-13-121907

19-Dec-07

7,930

10 u

3 J

3.5 J

441

10 u

2,860 J

70.7

0.2 U

8.9 J

2,680 J

35 U

10 u

26,300

25 U

50 U

18.7 J

HB-13

SW-H B-13-061708

17-Jun-08

7,930

0.65 J

1.6 J

2.2 J

877

10 u

2,980 J

47.6

0.2 U

40 U

2,650 J

35 U

10 u

23,600

25 U

50 U

6.8 J

HB-14

SW-HB-14-121807

18-Dec-07

22,200

10 u

1.9 J

25 U

296

10 u

5,980

57.8

0.2 U

40 U

3,320 J

35 U

10 u

14,600

25 U

50 U

8.3 J

HB-14

SW-H B-14-061608

16-Jun-08

9,240

10 u

50 U

2.3 J

874

10 u

3,220 J

33

0.2 U

2.7 J

2,760 J

35 U

10 u

26,400

25 U

50 U

20 U

HB-15

SW-HB-15-121807

18-Dec-07

8,460

10 u

2 J

7.3 J

422

10 u

2,820 J

75.1

0.2 U

8.2 J

2,640 J

3.3 J

10 u

27,200

25 U

50 U

17.4 J

HB-15

SW-H B-X-02-121807

18-Dec-07

9,340

0.43 J

2.1 J

4.3 J

452

10 u

3,070 J

80.1

0.2 U

7.9 J

2,660 J

35 U

10 u

28,200

25 U

50 U

18.1 J

HB-15

SW-H B-15-061608

16-Jun-08

8,220

10 u

50 U

3.4 J

891

10 u

2,960 J

29.7

0.2 U

3.6 J

2,500 J

35 U

10 u

24,400

25 U

0.75 J

20 U

HB-16

SW-HB-16-121707

17-Dec-07

70,000

10 u

3.1 J

25 U

199

10 u

202,000

44.8

0.2 U

5.1 J

64,400

35 U

0.79 J

1,680,000

25 U

50 U

8.1 J

HB-16

SW-H B-16-061608

16-Jun-08

23,700

10 u

50 U

2.7 J

158 J

10 u

49,600

22.8

0.2 U

2.1 J

17,800

35 U

10 u

414,000

4.2 J

0.82 J

20 U

HB-16

SW-H B-X-02-061608

16-Jun-08

23,700

0.59 J

50 U

3.4 J

233

10 u

49,400

18

0.2 U

40 U

17,500

35 U

10 u

412,000

25 U

50 U

20 U

HB-17

SW-HB-17-121707

17-Dec-07

12,700

10 u

2.7 J

25 U

282

10 u

3,190 J

29.2

0.2 U

0.98 J

3,130 J

35 U

10 u

22,800

25 U

50 U

6.4 J

HB-17

SW-H B-17-061608

16-Jun-08

15,200

10 u

50 U

3.9 J

902

10 u

4,690 J

65.6

0.2 U

40 U

2,920 J

35 U

10 u

26,500

25 U

0.73 J

20 U

HB-18

SW-HB-18-121707

17-Dec-07

73,900

10 u

2.3 J

25 U

191

10 u

213,000

43.2

0.2 U

5.6 J

67,600

35 U

10 u

1,760,000

25 U

50 U

7.4 J

HB-18

SW-H B-18-061608

16-Jun-08

127,000

0.63 J

50 UJ

3.1 J

200 U

10 u

383,000

16.1

0.2 U

40 U

122,000

35 U

10 u

3,360,000

5.4 J

50 UJ

20 UJ

Notes:

1.	'NJDEP SWQC' designates the New Jersey Surface Water Quality Criteria (Fresh Water- Human Health)

= exceeds NJDEP SWQC

2.	TCL Volatile Organic Compounds quantitated by Method SOM01.2.

3.	BOLD = detection

4.	TCL Volatile Organic Compounds, Semi-Volatile Organic Compounds and Pesticides/PCBs quantitated by method SOM01.2.
TAL Metals quantitated by Method ILM05.3 and ILM05.4.

5.	Results are expressed in micrograms per liter (ug/L).

6.	'NC' indicates screening criteria is not available.

7.	'NA' indicates the parameter was not analyzed for.

8.'U'	designates the analyte is not detected at or above the listed reporting limit.

9.	'J' designates reported concentration is an estimated value.

10.	'UJ' designates that the analyte was not detected at or above the listed reporting limit; the limit is an approximate value.

Page 3 of 3

-------
Table 5

Judas Creek Sediment Detections and Screening Criteria Exceedances
White Swan Cleaners/Sun Cleaners Area Ground Water Contamination Superfund Site

Parameter:
SSSSC

Volatile Organic Compounds (mg/kg)

Acetone

cis-1,2-Dichloroethylene

Methyl acetate

Methyl Ethyl Ketone

Tetrachloroethylene (PCE)

Toluene

Trichloroethylene (TCE)

Semi-Volatile Organic Compounds (mg/kg)

2-Methylnaphthalene

4-Methylphenol (p-cresol)

Acenaphthene

Acenaphthylene

Acetophenone

Anthracene

Benzaldehyde

Benzo(a)anthracene

Benzo(a)pyrene

Benzo(b)fluoranthene

Benzo(g,h,i)perylene

Benzo(k)fluoranthene

Benzyl butyl phthalate

Biphenyl (diphenyl)

Bis(2-ethylhexyl) phthalate

Carbazole

Chrysene

Dibenz(a,h)anthracene

12

0.2

14

0.6

0.005

4

0.007

5

31

74

300,000

2

1,500

6,100

0.5

0.2

0.6

30,000

6

150

90

35

24

52

0.2

Location

Sample ID

Date

JC-01

SED-JC-01-121707

17-Dec-07

0.0055 J

0.0052 U

0.0052 U

0.01 U

0.0052 R

0.0052 R

0.0052 R

0.028 J

0.2 U

0.26

0.024 J

0.2 U

0.33

0.2 U

1.9

2.4

4

0.9

2.9

1.2

0.2 U

0.67

0.38

2.9

0.25

JC-01

SED-JC-01-061708

17-Jun-08

0.011 u

0.0055 U

0.0055 U

0.011 U

0.0055 R

0.0055 R

0.0055 R

0.062 J

0.19 U

0.59

0.042 J

0.047 J

0.75

0.028 J

4.4

5.9

8.7 J

1.8 J

7.4

2

0.027 J

1.1

0.96

6.6

0.52

JC-02

SED-JC-02-121707

17-Dec-07

0.042

0.011 U

0.011 U

0.022 U

0.011 U

0.011 U

0.011 U

0.32 U

0.32 U

0.045 J

0.056 J

0.32 U

0.096 J

0.32 U

0.87 J

1.3

2.9 J

0.55 J

1.8

0.51

0.32 U

2.2

0.11 J

1.7 J

0.15 J

JC-02

SED-JC-X-01-121707

17-Dec-07

0.045

0.012 U

0.012 U

0.019 J

0.012 R

0.012 R

0.012 R

0.31 U

0.31 U

0.069 J

0.052 J

0.31 U

0.15 J

0.31 U

1.4 J

2 J

4.3 J

0.88 J

2.6 J

0.48

0.31 U

2.9

0.22 J

2.7 J

0.24 J

JC-02

SED-JC-02-061708

17-Jun-08

0.037 U

0.018 U

0.018 U

0.037 U

0.018 U

0.018 U

0.018 U

0.44 U

0.44 U

0.059 J

0.079 J

0.076 J

0.14 J

0.44 U

1.2

2.3

5 J

1.1 J

4.1

0.44 U

0.44 U

1.8

0.25 J

3

0.26 J

JC-03

SED-JC-03-121707

17-Dec-07

0.011 J

0.0097 U

0.0097 U

0.029

0.0097 R

0.0097 R

0.0097 R

0.33 U

0.33 U

0.33 U

0.33 U

0.33 U

0.053 J

0.33 U

0.49

0.81 J

1.6 J

0.38 J

1.3 J

1.1

0.33 U

1.2

0.094 J

1.1

0.1 J

JC-03

SED-JC-03-061708

17-Jun-08

0.015 U

0.0075 U

0.0075 U

0.015 U

0.0075 R

0.0075 R

0.0075 R

0.22 U

0.22 U

0.22 U

0.22 U

0.22 U

0.22 U

0.22 U

0.074 J

0.14 J

0.3 J

0.071 J

0.19 J

0.22 U

0.22 U

0.22 U

0.023 J

0.17 J

0.22 U

JC-04

SED-JC-04-121807

18-Dec-07

0.057

0.0088 U

0.0088 U

0.028

0.0088 R

0.0088 R

0.0088 R

0.3 U

0.3 U

0.14 J

0.3 U

0.3 U

0.29 J

0.3 U

0.64

0.64

1.1 J

0.22 J

0.71

0.3 U

0.3 U

1.5

0.12 J

0.89

0.076 J

JC-04

SED-JC-04-061708

17-Jun-08

0.006 J

0.0065 U

0.0042 J

0.013 U

0.0065 U

0.0065 U

0.0065 U

0.25 U

0.25 U

0.15 J

0.25 U

0.067 J

0.44

0.25 U

1.1

1.1 J

1.8 J

0.35 J

1.3 J

0.25 U

0.25 U

1.5

0.16 J

1.3 J

0.1 J

JC-04AS

SED-JC-04A-061708

17-Jun-08

0.14

0.13

0.0075 J

0.13

0.14 J

0.015 R

0.038 J

0.32 U

0.32 U

0.11 J

0.082 J

0.076 J

0.31 J

0.045 J

2.8

3.9 J

6.1 J

1.6 J

5.7 J

0.53

0.32 U

2.9

0.45

4.7

0.45 J

JC-04Aw

SED-JC-04A-121807

18-Dec-07

0.047

0.012 U

0.0067 J

0.038

0.012 R

0.012 R

0.012 R

0.042 J

0.37 U

0.34 J

0.11 J

0.37 U

0.86 J

0.37 U

8.2

11 J

17 J

5.3 J

15 J

0.74

0.37 U

6.2

1.4

14

1.5 J

JC-05

SED-JC-05-121807

18-Dec-07

0.011 u

0.0056 U

0.0056 U

0.011 u

0.011

0.0056 U

0.0056 U

0.21 U

0.21 U

0.21 U

0.21 U

0.21 U

0.21 U

0.21 U

0.091 J

0.11 J

0.18 J

0.052 J

0.14 J

0.21 U

0.21 U

0.21 U

0.21 U

0.16 J

0.21 U

JC-05

SED-JC-05-061708

17-Jun-08

0.012 U

0.0059 U

0.0059 U

0.012 U

0.0059 U

0.0059 U

0.0059 U

0.22 U

0.22 U

0.12 J

0.22 U

0.024 J

0.35

0.22 U

0.88

0.96

1.5

0.23 J

0.8

0.22 U

0.22 U

0.25

0.13 J

1.1

0.084 J

JC-06

SED-JC-06-121807

18-Dec-07

0.013 U

0.0064 U

0.0064 U

0.013 U

0.0064 U

0.0064 U

0.0064 U

0.22 U

0.22 U

0.22 U

0.22 U

0.22 U

0.22 U

0.22 U

0.082 J

0.14 J

0.22 J

0.082 J

0.15 J

0.22 U

0.22 U

0.22 U

0.22 U

0.14 J

0.024 J

JC-06

SED-JC-06-061608

16-Jun-08

0.011 U

0.0055 U

0.0055 U

0.011 U

0.0055 U

0.0055 U

0.0055 U

0.024 J

0.23 U

0.15 J

0.23 U

0.23 U

0.29

0.23 U

1

1.1

1.8

0.23 UJ

0.95

0.23 U

0.23 U

0.23 U

0.26

1.4

0.11 J

JC-07

SED-JC-07-121807

18-Dec-07

0.016

0.0067 U

0.0067 U

0.013 U

0.0067 U

0.0067 U

0.0067 U

0.28 U

0.28 U

0.28 U

0.28 U

0.28 U

0.042 J

0.28 U

0.29

0.35

0.64

0.17 J

0.48

0.35

0.28 U

0.28 U

0.048 J

0.51

0.044 J

JC-07

SED-JC-07-061608

16-Jun-08

0.0049 J

0.0058 U

0.0058 U

0.012 U

0.0058 U

0.0067

0.0058 U

0.23 U

0.031 J

0.13 J

0.23 U

0.23 U

0.41 J

0.23 U

1.4 J

1.5 J

2.5 J

0.23 UJ

1.3 J

0.23 U

0.23 U

0.23 U

0.31 J

1.8 J

0.19 J

JC-07

SED-JC-X-01-061608

16-Jun-08

0.014 U

0.007 U

0.007 U

0.014 U

0.007 U

0.007 U

0.007 U

0.27 U

0.27 U

0.27 U

0.27 U

0.27 U

0.27 U

0.27 U

0.27 U

0.27 U

0.032 J

0.27 UJ

0.27 U

0.27 U

0.27 U

0.27 U

0.27 U

0.27 U

0.27 U

JC-08

SED-JC-08-121807

18-Dec-07

0.0074 J

0.0053 U

0.0053 U

0.011 U

0.0053 U

0.0053 U

0.0053 U

0.22 U

0.22 U

0.17 J

0.22 U

0.22 U

0.32

0.22 U

1.8

1.8

2.7

0.67

2.6

0.22 U

0.22 U

0.22 U

0.42

2.7

0.2 J

JC-08

SED-JC-08-061608

16-Jun-08

0.0085 J

0.03 J

0.0056 UJ

0.011 UJ

0.22 J

0.0056 UJ

0.092 J

0.03 J

0.23 UJ

0.13 J

0.23 UJ

0.23 UJ

0.24 J

0.23 UJ

1.4 J

1.6 J

2.5 J

0.47 J

1.7 J

0.23 UJ

0.23 UJ

0.47 J

0.26 J

2 J

0.18 J

JC-09

SED-JC-09-121807

18-Dec-07

0.58 U

0.29 U

0.095 J

0.58 U

4.4

0.29 U

0.29 U

0.2 U

0.2 U

0.2 U

0.2 U

0.2 U

0.2 U

0.2 U

0.026 J

0.2 U

0.2 U

0.2 U

0.2 U

0.2 U

0.2 U

0.2 U

0.2 U

0.04 J

0.2 U

JC-09

SED-JC-09-061608

16-Jun-08

0.01 U

0.0052 U

0.0052 U

0.01 U

0.0042 J

0.0052 U

0.0052 U

0.21 U

0.21 U

0.13 J

0.21 U

0.21 U

0.16 J

0.21 U

0.79

0.82

1.3

0.22 J

0.97

0.21 U

0.21 U

0.21 U

0.21

1.2

0.08 J

JC-10

SED-JC-10-121707

17-Dec-07

0.012 U

0.0058 U

0.0058 U

0.012 U

0.081

0.0058 U

0.0058 U

0.1 J

0.21 U

0.62

0.026 J

0.21 U

1.1 J

0.21 U

2.7 J

2.2 J

3 J

0.7 J

2.8 J

0.042 J

0.034 J

0.21 U

0.47

3.3 J

0.34 J

JC-10

SED-JC-10-061608

16-Jun-08

0.85 U

0.42 U

0.14 J

0.85 U

0.79

0.42 U

0.42 U

0.23 U

0.23 U

0.075 J

0.04 J

0.23 U

0.22 J

0.23 U

0.84 J

0.83 J

0.99 J

0.22 J

1 J

0.23 UJ

0.23 UJ

0.23 U

0.082 J

0.98 J

0.1 J

JC-11

SED-JC-11-121707

17-Dec-07

0.028 U

0.014 U

0.014 U

0.028 U

0.0065 J

0.014 U

0.014 U

0.59 U

0.59 U

0.18 J

0.099 J

0.59 U

0.35 J

0.59 U

2.2

3.1

5.9 J

1.1

4.1

0.59 U

0.59 U

3.4

0.4 J

4

0.29 J

JC-11

SED-JC-11-061608

16-Jun-08

0.054 J

0.007 U

0.007 U

0.026 J

0.007 U

0.007 U

0.007 U

0.29 U

0.29 U

0.29 U

0.29 U

0.29 U

0.29 U

0.29 U

0.097 J

0.12 J

0.27 J

0.044 J

0.13 J

0.29 U

0.29 U

0.29 U

0.29 U

0.2 J

0.29 U

JC-12

SED-JC-12-121707

17-Dec-07

0.0064 J

0.0051 U

0.0051 U

0.01 u

0.0051 U

0.0051 U

0.0051 U

0.21 U

0.21 U

0.21 U

0.21 U

0.21 U

0.029 J

0.21 U

0.12 J

0.13 J

0.29 J

0.058 J

0.3 J

0.21 U

0.21 U

0.21 U

0.026 J

0.25

0.21 U

JC-12

SED-JC-12-061608

16-Jun-08

0.0095 U

0.0048 U

0.0048 U

0.0095 U

0.0048 U

0.0048 U

0.0048 U

0.2 U

0.2 U

0.2 U

0.2 U

0.2 U

0.2 U

0.2 U

0.2 U

0.2 U

0.2 U

0.2 U

0.2 U

0.2 U

0.2 U

0.2 U

0.2 U

0.2 U

0.2 U

JC-S-1

SED-JC-S-1-062909

29-Jun-09

0.024

0.0049 J

0.0053 U

0.01 J

0.0053 U

0.0053 U

0.0053 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

JC-S-2

SED-JC-S-2-062909

29-Jun-09

0.01 u

0.0022 J

0.005 U

0.01 u

0.036

0.005 U

0.0032 J

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

JC-S-3

SED-JC-S-3-062909

29-Jun-09

0.0065 J

0.0055 U

0.0055 U

0.011 u

0.0055 U

0.0033 J

0.0055 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

JC-S-3

SED-JC-S-X-01-062909

29-Jun-09

0.0041 J

0.0053 U

0.0053 U

0.011 u

0.0053 U

0.0027 J

0.0053 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

\

Notes:

1.	'SSSSC' designates Site-specific Soil Screening Criteria

= exceeds SSSSC

2.	BOLD = detection

3.	TCL Volatile Organic Compounds, Semi-Volatile Organic Compounds and Pesticides/PCBs quantitated by Method SOM01.2.
TAL Metals quantitated by Method ILM05.3 and ILM05.4.

4.	Results are expressed in milligrams per kilogram (mg/kg).

5.	'NC' indicates screening criteria is not available.

6.	'NA' indicates the parameter was not analyzed for.

7.	'U' designates the analyte is not detected at or above the listed reporting limit.

8.	'R' designates that the reported sample result is not usable.

9.	'J' designates reported concentration is an estimated value.

10.	'NJ' designates that the analyte has been "tentatively identified"; the reported concentration is an approximate value.

11.	'UJ' designates that the analyte was not detected at or above the listed reporting limit; the limit is an approximate value.

Page 1 of 3

-------
Table 5

Judas Creek Sediment Detections and Screening Criteria Exceedances
White Swan Cleaners/Sun Cleaners Area Ground Water Contamination Superfund Site

Parameter:

Dibenzofu ran

Di-n-butyl phthalate

Di-n-octylphthalate

Fluoranthene

Fluorene

lndeno(1,2,3-c,d)pyrene

Naphthalene

Phenanthrene

Phenol

Pyrene

Pesticides/PCBs (mg/kg)

PCB-1254 (Aroclor 1254)

PCB-1260 (Aroclor 1260)

4,4-DDD

4,4-DDE

4,4-DDT

Aldrin

alpha Endosulfan

alpha-Chlordane

Beta BHC

beta Endosulfan

delta BHC

Dieldrin

Endosulfan Sulfate

Endrin

Endrin Aldehyde

SSSSC

NC

620

2,400

840

110

0.6

6

300,000

5

550

0.2

0.2

3

2

2

0.04

2

0.03

0.002

2

NC

0.003

1

0.6

NC

Location

Sample ID

Date

JC-01

SED-JC-01 -121707

17-Dec-07

0.088 J

0.062 J

0.2 UJ

4.7

0.2

0.97

0.11 J

2.7

0.2 U

4.1

0.038 U

0.038 U

0.02

0.024

0.07

0.002 U

0.002 U

0.0027 NJ

0.002 U

0.0038 U

0.002 U

0.013

0.0029 NJ

0.0038 U

0.003 J

JC-01

SED-JC-01 -061708

17-Jun-08

0.22

0.12 J

0.19 U

15

0.46

1.9

0.28

6.4

0.19 U

8.1

0.041

0.023 J

0.018

0.032

0.083

0.0019 U

0.0019 U

0.0088

0.0019 U

0.0037 U

0.0019 U

0.014

0.0036 NJ

0.0046 NJ

0.0028 NJ

JC-02

SED-JC-02-121707

17-Dec-07

0.32 U

0.083 J

0.32 UJ

2.1 J

0.32 U

0.58

0.32 U

0.73 J

0.32 U

2.1 J

0.12

0.15

0.04

0.057

0.055

0.0032 U

0.0032 U

0.034

0.0032 U

0.0062 U

0.0022 J

0.022

0.0059 NJ

0.0062 U

0.0062 U

JC-02

SED-JC-X-01 -121707

17-Dec-07

0.036 J

0.092 J

0.31 R

4.2 J

0.069 J

0.94 J

0.31 U

1.4 J

0.31 U

4.1 J

0.074

0.1

0.044

0.055

0.046

0.0031 U

0.0031 U

0.023

0.0031 U

0.0061 U

0.0031 U

0.02

0.0054 NJ

0.0061 U

0.0061 U

JC-02

SED-JC-02-061708

17-Jun-08

0.44 U

0.075 J

0.44 U

5.1

0.046 J

1

0.44 U

1.2

0.44 U

3.3

0.086

0.084 J

0.011

0.021

0.02

0.0044 U

0.0044 U

0.0073 NJ

0.0044 U

0.0085 U

0.0044 U

0.0069 J

0.0085 U

0.0085 U

0.0085 U

JC-03

SED-JC-03-121707

17-Dec-07

0.33 U

0.14 J

0.33 UJ

1.4

0.33 U

0.37 J

0.33 U

0.46 J

0.33 U

1.2 J

0.075

0.066

0.0058 J

0.0085 NJ

0.025

0.0033 U

0.0033 U

0.0073

0.0033 U

0.0063 U

0.0033 U

0.0066

0.0063 U

0.0063 U

0.0063 U

JC-03

SED-JC-03-061708

17-Jun-08

0.22 U

0.1 J

0.22 U

0.29

0.22 U

0.063 J

0.22 U

0.089 J

0.22 U

0.18 J

0.043 U

0.043 U

0.004 J

0.0047

0.0059

0.0022 U

0.0022 U

0.0029 NJ

0.0022 U

0.0043 U

0.0022 U

0.0025 J

0.0043 R

0.0043 U

0.0043 U

JC-04

SED-JC-04-121807

18-Dec-07

0.071 J

0.3 U

0.14 J

1.6

0.13 J

0.25 J

0.3 U

1.3

0.3 U

1.6

0.072

0.058 U

0.0034 J

0.0058 U

0.003 NJ

0.003 U

0.003 U

0.01

0.003 U

0.0058 U

0.003 U

0.0031 J

0.0058 U

0.0058 U

0.0058 U

JC-04

SED-JC-04-061708

17-Jun-08

0.081 J

0.25 U

0.25 R

4.2

0.17 J

0.35 J

0.25 U

2.1

0.25 U

2.8 J

0.032 J

0.048 U

0.0029 J

0.0048 U

0.004 NJ

0.0025 U

0.0025 U

0.0089 NJ

0.0025 U

0.0048 U

0.0025 U

0.0048 U

0.0048 R

0.0048 U

0.0048 U

JC-04AS

SED-JC-04A-061708

17-Jun-08

0.062 J

0.18 J

0.32 R

10

0.12 J

1.6 J

0.32 U

3

0.32 U

8

0.033 J

0.062 U

0.0098 NJ

0.0076 NJ

0.022 NJ

0.0032 U

0.0025 NJ

0.027 NJ

0.0032 U

0.0044 NJ

0.0032 U

0.013 NJ

0.0036 NJ

0.0062 U

0.021

JC-04Aw

SED-JC-04A-121807

18-Dec-07

0.19 J

0.37 U

0.37 R

20

0.34 J

5.5 J

0.06 J

9

0.37 U

19

0.072 U

0.072 U

0.0099 NJ

0.013 NJ

0.016 NJ

0.0037 U

0.0037 U

0.057

0.0037 U

0.0072 U

0.0037 U

0.0092

0.0057 NJ

0.0065 J

0.0075 NJ

JC-05

SED-JC-05-121807

18-Dec-07

0.21 U

0.21 U

0.21 UJ

0.19 J

0.21 U

0.058 J

0.21 U

0.079 J

0.21 U

0.19 J

0.041 U

0.041 U

0.0041 U

0.0041 U

0.0041 U

0.0021 U

0.0021 U

0.0029

0.0021 U

0.0041 U

0.0021 U

0.0041 U

0.0041 U

0.0041 U

0.0041 U

JC-05

SED-JC-05-061708

17-Jun-08

0.061 J

0.22 U

0.22 U

2.7

0.14 J

0.29 J

0.22 U

1.7

0.22 U

1.6

0.043 U

0.043 U

0.0043 U

0.0043 U

0.0043 U

0.0022 U

0.0022 U

0.007

0.0022 U

0.0043 U

0.0022 U

0.015

0.0043 U

0.0043 U

0.0043 U

JC-06

SED-JC-06-121807

18-Dec-07

0.22 U

0.22 U

0.22 UJ

0.18 J

0.22 U

0.079 J

0.22 U

0.063 J

0.22 U

0.17 J

0.043 U

0.043 U

0.0043 U

0.0043 U

0.0043 U

0.0022 U

0.0022 U

0.0017 NJ

0.0022 U

0.0043 U

0.0022 U

0.0023 J

0.0043 U

0.0043 U

0.0043 U

JC-06

SED-JC-06-061608

16-Jun-08

0.097 J

0.23 U

0.23 U

3.3 J

0.2 J

0.38

0.23 U

2.5

0.23 U

2.2

0.044 U

0.044 U

0.0044 U

0.0044 U

0.0044 U

0.0023 U

0.0023 U

0.002 J

0.0023 U

0.0044 U

0.0023 U

0.0044 U

0.0044 U

0.0044 U

0.0044 U

JC-07

SED-JC-07-121807

18-Dec-07

0.28 U

0.28 U

0.28 UJ

0.81

0.28 U

0.18 J

0.28 U

0.35

0.28 U

0.74

0.054 U

0.054 U

0.0054 U

0.0054 U

0.0054 U

0.0025 J

0.0028 U

0.012

0.0028 U

0.0054 U

0.0028 U

0.009

0.0054 U

0.0054 U

0.0054 U

JC-07

SED-JC-07-061608

16-Jun-08

0.082 J

0.23 U

0.23 U

3.5 J

0.17 J

0.51 J

0.23 U

2.8 J

0.23 U

2.7 J

0.045 U

0.045 U

0.0045 U

0.0045 U

0.0045 U

0.0023 U

0.0023 U

0.0027 NJ

0.0023 U

0.0045 U

0.0023 U

0.0045 U

0.0045 U

0.0045 U

0.0045 U

JC-07

SED-JC-X-01-061608

16-Jun-08

0.27 U

0.27 U

0.27 U

0.034 J

0.27 U

0.27 U

0.27 U

0.27 U

0.27 U

0.027 J

0.053 U

0.053 U

0.016 J

0.0042 J

0.0053 U

0.0027 U

0.0027 U

0.0016 J

0.0027 U

0.0053 U

0.0027 U

0.0053 U

0.0053 U

0.0053 U

0.0053 U

JC-08

SED-JC-08-121807

18-Dec-07

0.098 J

0.029 J

0.054 J

5.4

0.18 J

0.73

0.027 J

3.7

0.22 U

4.5

0.042 U

0.042 U

0.0042 U

0.0042 U

0.0042 U

0.0022 U

0.0022 U

0.0027 NJ

0.0022 U

0.0042 U

0.0022 U

0.0032 J

0.0042 U

0.0042 U

0.0042 U

JC-08

SED-JC-08-061608

16-Jun-08

0.082 J

0.23 UJ

0.23 UJ

3.9 J

0.15 J

0.53 J

0.23 UJ

2.3 J

0.23 UJ

2.5 J

0.045 UJ

0.045 UJ

0.0028 NJ

0.0045 UJ

0.0045 UJ

0.0016 NJ

0.0023 UJ

0.0073 J

0.0023 UJ

0.0045 UJ

0.0023 UJ

0.005 J

0.004 J

0.0045 UJ

0.0035 NJ

JC-09

SED-JC-09-121807

18-Dec-07

0.2 U

0.2 U

0.2 UJ

0.048 J

0.2 U

0.2 U

0.2 U

0.028 J

0.2 U

0.05 J

0.039 U

0.039 U

0.0039 U

0.0039 U

0.0039 U

0.002 U

0.002 U

0.0032

0.002 U

0.0039 U

0.002 U

0.0083

0.0039 U

0.0039 U

0.0039 U

JC-09

SED-JC-09-061608

16-Jun-08

0.091 J

0.21 U

0.21 U

2.8

0.14 J

0.27

0.21 U

2.1

0.024 J

1.8

0.04 U

0.04 U

0.004 U

0.004 U

0.004 U

0.001 J

0.002 U

0.002 J

0.002 U

0.004 U

0.002 U

0.0027 J

0.0023 NJ

0.004 U

0.004 U

JC-10

SED-JC-10-121707

17-Dec-07

0.34

0.077 J

0.21 R

8

0.62

0.82 J

0.066 J

6.4

0.21 U

6.1

0.041 U

0.041 U

0.0071

0.0024 J

0.0026 NJ

0.0021 U

0.0021 U

0.0088

0.0021 U

0.0041 U

0.0021 U

0.0073

0.0041 U

0.0041 U

0.0041 U

JC-10

SED-JC-10-061608

16-Jun-08

0.028 J

0.23 UJ

0.23 UJ

2.2 J

0.087 J

0.25 J

0.23 U

1.1

0.23 U

1.4 J

0.045 U

0.045 U

0.031

0.0038 J

0.014

0.0015 NJ

0.0023 U

0.0078

0.0023 U

0.0045 U

0.0023 U

0.015

0.0045 U

0.0045 U

0.0045 U

JC-11

SED-JC-11-121707

17-Dec-07

0.089 J

0.092 J

0.44 J

6.9

0.15 J

1.2

0.06 J

2.7 J

0.59 U

5.6

0.11 U

0.11 U

0.014 NJ

0.012 NJ

0.016

0.0059 U

0.0059 U

0.05

0.0031 J

0.011 U

0.0059 U

0.05

0.011 U

0.011 U

0.011 U

JC-11

SED-JC-11-061608

16-Jun-08

0.29 U

0.29 U

0.29 U

0.36

0.29 U

0.051 J

0.29 U

0.089 J

0.29 U

0.25 J

0.057 U

0.057 U

0.0057 U

0.0057 U

0.0057 U

0.0029 U

0.0029 U

0.002 J

0.0029 U

0.0057 U

0.0029 U

0.0057 U

0.0057 U

0.0057 U

0.0057 U

JC-12

SED-JC-12-121707

17-Dec-07

0.21 U

0.21 U

0.21 UJ

0.4

0.21 U

0.065 J

0.21 U

0.13 J

0.21 U

0.3

0.04 U

0.04 U

0.004 U

0.004 U

0.004 U

0.0021 U

0.0021 U

0.0021 U

0.0021 U

0.004 U

0.0021 U

0.004 U

0.004 U

0.004 U

0.004 U

JC-12

SED-JC-12-061608

16-Jun-08

0.2 U

0.2 U

0.2 U

0.2 UJ

0.2 U

0.2 U

0.2 U

0.2 U

0.2 U

0.2 U

0.039 U

0.039 U

0.0039 U

0.0039 U

0.0039 U

0.002 U

0.002 U

0.002 U

0.002 U

0.0039 U

0.002 U

0.0039 U

0.0039 U

0.0039 U

0.0039 U

JC-S-1

SED-JC-S-1-062909

29-Jun-09

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

JC-S-2

SED-JC-S-2-062909

29-Jun-09

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

JC-S-3

SED-JC-S-3-062909

29-Jun-09

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

JC-S-3

SED-JC-S-X-01-062909

29-Jun-09

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

Notes:

1.	'SSSSC' designates Site-specific Soil Screening Criteria

= exceeds SSSSC

2.	BOLD = detection

3.	TCL Volatile Organic Compounds, Semi-Volatile Organic Compounds and Pesticides/PCBs quantitated by Method SOM01.2.
TAL Metals quantitated by Method ILM05.3 and ILM05.4.

4.	Results are expressed in milligrams per kilogram (mg/kg).

5.	'NC' indicates screening criteria is not available.

6.	'NA' indicates the parameter was not analyzed for.

7.	'U' designates the analyte is not detected at or above the listed reporting limit.

8.	'R' designates that the reported sample result is not usable.

9.	'J' designates reported concentration is an estimated value.

10.	'NJ' designates that the analyte has been "tentatively identified"; the reported concentration is an approximate value.

11.	'UJ' designates that the analyte was not detected at or above the listed reporting limit; the limit is an approximate value.

Page 2 of 3

-------
Table 5

Judas Creek Sediment Detections and Screening Criteria Exceedances
White Swan Cleaners/Sun Cleaners Area Ground Water Contamination Superfund Site

Parameter:

Endrin Ketone

gamma-Chlordane

Heptachlor epoxide

Metals (mg/kg)

Aluminum

Antimony

Arsenic

Barium

Beryllium

Cadmium

Calcium

Chromium

Cobalt

Copper

Cyanide

Iron

Lead

Magnesium

Manganese

Mercury

Nickel

Potassium

Selenium

Sodium

Vanadium

Zinc

SSSSC

NC

0.03

0.009

3,900

6

19

1,300

0.5

1

NC

NC

59

3,100

13

NC

59

NC

42

0.1

31

NC

7

NC

78

600

Location

Sample ID

Date

JC-01

SED-JC-01 -121707

17-Dec-07

0.0031 J

0.0035 NJ

0.002 U

4,860

4.9 UJ

4.4

10.8 J

0.41 U

0.22 J

980

14 J

4 U

16.2

NA

11,800

89.1

931

76.5

0.056 J

19

405 U

2.8 U

405 U

42.2

62.1

JC-01

SED-JC-01 -061708

17-Jun-08

0.011 NJ

0.0076 NJ

0.0019 U

8,060

0.35 J

8.8

21.1

0.26 J

0.6

1,720

29.1

3.4 J

38.5

0.55 J

21,300

134

1,280

155

0.17

16.9

361 J

3.4 U

129 J

63.6

113

JC-02

SED-JC-02-121707

17-Dec-07

0.0062 U

0.033 J

0.0039 NJ

17,500

0.44 J

12

54.3

0.89

0.44 J

1,980

75.2 J

7 U

96.4 J

NA

23,100

816

2,430

89.9 J

1.5

18

697 U

0.8 J

697 U

108

130

JC-02

SED-JC-X-01 -121707

17-Dec-07

0.0036 NJ

0.019 J

0.0033 NJ

20,100

8.4 UJ

14.1

57.8

1

0.52 J

2,290

102 J

7 U

152 J

NA

27,600

1,200

2,890

93.2

1.5

22.3

697 U

1.1 J

697 U

133

148

JC-02

SED-JC-02-061708

17-Jun-08

0.0085 U

0.0052 NJ

0.0044 U

20,000

1.2 J

19.3

95.8

1.1

1.6

3,690

65.7

5.6 J

195

1 J

26,500

565

2,700

120

0.64

22.3

833 J

7.6 U

1,090 U

104

234

JC-03

SED-JC-03-121707

17-Dec-07

0.0063 U

0.0061 NJ

0.0018 NJ

6,040

1.3 J

4.5

48.5

0.67 U

1.3

4,630

32.8 J

6.7 U

67.9

NA

16,100

408

1,270

177 J

0.52 J

11.8

670 U

0.51 J

670 U

25.4

191

JC-03

SED-JC-03-061708

17-Jun-08

0.0043 U

0.0026

0.0022 U

6,230

0.41 J

2.6

32.2

0.56 U

0.56 U

1,410

21.8

1.4 J

23.8

1.4 J

8,410

184

784

45.6

0.31

5.9

331 J

3.9 U

555 U

20.8

79.8

JC-04

SED-JC-04-121807

18-Dec-07

0.0058 U

0.0089

0.003 U

3,580

0.54 J

0.95 J

10.6 J

0.65 U

0.12 J

1,480

48 J

6.5 U

48.2

NA

6,920

696

904

23.2

0.051 J

8.6

654 U

4.6 U

654 U

19.1

109

JC-04

SED-JC-04-061708

17-Jun-08

0.0048 U

0.0097 NJ

0.0025 U

2,340

0.47 J

1.1 J

10.6 J

0.65 U

0.65 U

1,230

33.1

0.9 J

40

3.5 U

5,020

209

707

17.8

0.061 J

5.9

202 J

4.5 U

647 U

13.8

64.4

JC-04AS

SED-JC-04A-061708

17-Jun-08

0.0088

0.024 NJ

0.0085 NJ

7,750

0.63 J

2.5

35.9

0.76 U

1.2

2,310

39.1

2.7 J

54.1

0.42 J

10,500

204

1,430

48.4

0.12 J

25.6

485 J

5.3 U

757 U

40.8

199

JC-04Aw

SED-JC-04A-121807

18-Dec-07

0.011

0.057

0.0097

9,990

1.1 J

3.2

52.1

0.85 U

0.61 J

5,100

58.4 J

8.5 U

91.8

NA

15,400

500

2,280

98.4

0.16 J

20.2

849 U

0.73 J

1,050

53.8

357

JC-05

SED-JC-05-121807

18-Dec-07

0.0041 U

0.0028

0.0021 U

2,900

0.31 J

1.1

13.1 J

0.47 U

0.14 J

1,140

6.8 J

4.8 U

11.2

NA

3,940

24.5

610

25.6

0.034 J

3.7 J

475 U

3.3 U

475 U

10.7

42.8

JC-05

SED-JC-05-061708

17-Jun-08

0.0043 U

0.005 NJ

0.0037

2,440

6.2 U

0.99 J

10 J

0.51 U

0.51 U

582

6.3

0.8 J

6.9

2.8 U

4,080

27

514 U

17.7

0.027 J

4.1 U

179 J

3.6 U

514 U

7.9

22.5

JC-06

SED-JC-06-121807

18-Dec-07

0.0043 U

0.0017 NJ

0.0022 U

1,600

5.3 UJ

0.49 J

6.1 J

0.45 U

0.078 J

574

4.7 J

4.4 U

5.4

NA

2,560

25.1

429 J

14.3

0.45 U

2.1 J

445 U

3.1 U

445 U

6.2

22.2

JC-06

SED-JC-06-061608

16-Jun-08

0.0044 U

0.0015 NJ

0.0023 U

945

5.9 U

0.64 J

6.5 J

0.077 J

0.14 J

480 J

3.6

0.36 J

3.7

3.1 U

1,350

13.8 J

252 J

6.6

0.12 U

3.9 U

112 J

3.4 U

28.9 J

4.9 U

21

JC-07

SED-JC-07-121807

18-Dec-07

0.0054 U

0.0067 NJ

0.002 J

4,610

7.2 UJ

2.2

13.4 J

0.6 U

0.065 J

831

9.8 J

6 U

7.4

NA

5,030

25

521 J

20.2

0.039 J

2.8 J

596 U

0.34 J

596 U

10.3

16.9

JC-07

SED-JC-07-061608

16-Jun-08

0.0045 U

0.0022 NJ

0.0023 U

790

6.1 U

1 U

4.9 J

0.078 J

0.1 J

286 J

2.4 J

0.37 J

3.2

3.3 U

980 J

16.4 J

142 J

4.4 J

0.11 u

4.1 U

83.6 J

3.6 U

28.9 J

5.1 U

20.8 J

JC-07

SED-JC-X-01-061608

16-Jun-08

0.0053 U

0.0027 U

0.0027 U

1,030

7 U

1.2 U

3.5 J

0.064 J

0.58 U

420 J

5.2 J

0.4 J

3.1

3.7 U

1,900 J

16.3 J

274 J

11.4 J

0.16 U

4.7 U

98.2 J

4.1 U

43.7 J

5.8 U

10.6 J

JC-08

SED-JC-08-121807

18-Dec-07

0.0025 NJ

0.0025 NJ

0.0022 U

1,460

5.4 UJ

1.6

5.8 J

0.45 U

0.15 J

1,570

7.8 J

4.5 U

9.5

NA

4,780

9.7

736

27.8

0.37 U

2.9 J

450 U

3.2 U

450 U

7

57.7

JC-08

SED-JC-08-061608

16-Jun-08

0.0058 J

0.0061 NJ

0.0019 NJ

1,470

6 U

0.54 J

4.4 J

0.29 J

0.5 U

634

13.5

1.2 J

17.4

2.7 UJ

3,400

37 J

473 J

14.9

0.11 U

8.1

158 J

3.5 U

438 J

6.8

90.6

JC-09

SED-JC-09-121807

18-Dec-07

0.0039 U

0.0025

0.0014 J

2,870

5.4 UJ

0.86 J

16.5 J

0.45 U

0.066 J

1,980

5.9 J

4.5 U

10.2

NA

4,500

24.8

762

23

0.39 U

2 J

452 U

0.23 J

452 U

10.2

16.8

JC-09

SED-JC-09-061608

16-Jun-08

0.0034 J

0.0014 NJ

0.002 U

1,860

5.2 U

2.2

11 J

0.45

0.11 J

1,370

6.9

1.4 J

8.7

3 U

4,390

9.2 J

991

101

0.11 U

3.4 U

94.8 J

3 U

139 J

7.6

49.6

JC-10

SED-JC-10-121707

17-Dec-07

0.0023 J

0.0085

0.0032 NJ

1,280

5.1 UJ

0.72 J

4.3 J

0.43 U

0.039 J

592

5.1 J

4.3 U

7.2

NA

3,200

17.8

375 J

13.1

0.43 U

2 J

428 U

3 U

428 U

5.6

16.1

JC-10

SED-JC-10-061608

16-Jun-08

0.0037 J

0.0061

0.0027 NJ

1,060

6.3 U

1.2

5.8 J

0.13 J

0.53 U

508 J

3.7

0.39 J

5.6

2.6 U

2,400

21.4 J

263 J

10.6

0.13 U

1.7 J

110 J

3.7 U

53.8 J

6.1

11.6

JC-11

SED-JC-11-121707

17-Dec-07

0.0078 J

0.036 NJ

0.012

7,270

13.9 UJ

6.2

28.4 J

1.2 U

0.54 J

2,350

34.9 J

11.6 U

77.1

NA

15,400

111

3,140

63.4

0.23 J

11.5

1,240

8.1 U

5,270

26.9

157

JC-11

SED-JC-11-061608

16-Jun-08

0.0057 U

0.0029 U

0.0029 U

1,790

8.1 U

1.8

4.6 J

0.1 J

0.11 J

1,010

3.2

1.8 J

13.7

4 U

4,550

6.2 J

1,300

28.4

0.14 U

5.4 U

194 J

4.7 U

1,550

8.7

14.8

JC-12

SED-JC-12-121707

17-Dec-07

0.004 U

0.0021 U

0.0021 U

614

5.1 UJ

0.39 J

1.7 J

0.43 U

0.035 J

429 U

3.3 J

4.3 U

4.7

NA

912

38.4

198 J

3.5

0.49 U

0.76 J

429 U

3 U

700

2.7 J

15.1

JC-12

SED-JC-12-061608

16-Jun-08

0.0039 U

0.002 U

0.002 U

1,130

5.7 U

0.83 J

3 J

0.07 J

0.47 U

163 J

3.5

0.46 J

10.4

3 U

1,560

5.5 J

465 J

9.1

0.1 U

3.8 U

245 J

3.3 U

1,360

4.7 U

6.7

JC-S-1

SED-JC-S-1-062909

29-Jun-09

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

JC-S-2

SED-JC-S-2-062909

29-Jun-09

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

JC-S-3

SED-JC-S-3-062909

29-Jun-09

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

JC-S-3

SED-JC-S-X-01-062909

29-Jun-09

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

Notes:

1.	'SSSSC' designates Site-specific Soil Screening Criteria

= exceeds SSSSC

2.	BOLD = detection

3.	TCL Volatile Organic Compounds, Semi-Volatile Organic Compounds and Pesticides/PCBs quantitated by Method SOM01.2.
TAL Metals quantitated by Method ILM05.3 and ILM05.4.

4.	Results are expressed in milligrams per kilogram (mg/kg).

5.	'NC' indicates screening criteria is not available.

6.	'NA' indicates the parameter was not analyzed for.

7.'U'	designates the analyte is not detected at or above the listed reporting limit.

8.'R'	designates that the reported sample result is not usable.

9.	'J' designates reported concentration is an estimated value.

10.'NJ'	designates that the analyte has been "tentatively identified"; the reported concentration is an approximate value.

11.'UJ'	designates that the analyte was not detected at or above the listed reporting limit; the limit is an approximate value.

Page 3 of 3

-------
Table 6

Hannabrand Brook Sediment Detections and Screening Criteria Exceedances
White Swan Cleaners/Sun Cleaners Area Ground Water Contamination Superfund Site

Parameter:

Volatile Organic Compounds (mg/kg)

2-Hexanone

Acetone

Carbon Disulfide

cis-1,2-Dichloroethylene

Methyl acetate

Methyl Ethyl Ketone

Tetrachloroethylene (PCE)

Toluene

Trichloroethylene (TCE)

Semi-Volatile Organic Compounds (mg/kg)

4-Methylphenol (p-cresol)

Acenaphthene

Acetophenone

Anthracene

Benzaldehyde

Benzo(a)anthracene

Benzo(a)pyrene

Benzo(b)fluoranthene

Benzo(g,h,i)perylene

Benzo(k)fluoranthene

Benzyl butyl phthalate

Bis(2-ethylhexyl) phthalate

Caprolactam

Carbazole

SSSSC

NC

12

4

0.2

14

0.6

0.005

4

0.007

31

74

2

1,500

6,100

0.5

0.2

0.6

30,000

6

150

35

8

24

Location

Sample ID

Date

HB-01

SED-HB-01-121907

19-Dec-07

0.013 U

0.0083 J

0.0066 U

0.0066 U

0.0066 U

0.013 U

0.0066 U

0.0066 U

0.0066 U

0.22 U

0.12 J

0.22 U

0.2 J

0.22 U

0.77 J

0.74 J

1 J

0.24 J

0.87 J

0.031 J

0.077 J

0.068 J

0.15 J

HB-01

SED-HB-01-061808

18-Jun-08

0.013 U

0.013 U

0.0064 U

0.0064 U

0.0064 U

0.013 U

0.0064 U

0.0064 U

0.0064 U

0.21 U

0.21 U

0.023 J

0.21 U

0.21 U

0.023 J

0.033 J

0.036 J

0.21 UJ

0.026 J

0.21 U

0.21 U

0.21 U

0.21 U

HB-02

SED-HB-02-121907

19-Dec-07

0.012 U

0.026

0.0059 U

0.0059 U

0.0059 U

0.012 U

0.0059 U

0.0059 U

0.0059 U

0.21 U

0.21 U

0.21 U

0.21 U

0.21 U

0.056 J

0.065 J

0.095 J

0.027 J

0.075 J

0.21 U

0.053 J

0.21 U

0.21 U

HB-02

SED-HB-02-061808

18-Jun-08

0.011 U

0.011 u

0.0054 U

0.0054 U

0.0054 U

0.011 U

0.0054 U

0.0054 U

0.0054 U

0.21 U

0.21 U

0.021 J

0.21 U

0.21 U

0.033 J

0.04 J

0.049 J

0.027 J

0.03 J

0.21 U

0.21 U

0.21 U

0.21 U

HB-03

SED-HB-03-121907

19-Dec-07

0.014 U

0.012 J

0.0069 U

0.0069 U

0.0069 U

0.014 U

0.0069 U

0.0069 U

0.0069 U

0.22 U

0.22 U

0.22 U

0.22 U

0.22 U

0.069 J

0.087 J

0.17 J

0.037 J

0.091 J

0.22 U

0.088 J

0.22 U

0.22 U

HB-03

SED-HB-03-061808

18-Jun-08

0.011 U

0.011 u

0.0057 U

0.0057 U

0.0057 U

0.011 U

0.0057 U

0.0057 U

0.0057 U

0.22 U

0.22 U

0.22 U

0.22 U

0.22 U

0.074 J

0.088 J

0.097 J

0.077 J

0.09 J

0.22 U

0.22 U

0.22 U

0.22 U

HB-04

SED-HB-04-121907

19-Dec-07

0.07 U

0.15

0.035 U

0.035 U

0.035 U

0.03 J

0.035 U

0.035 U

0.035 U

0.51 U

0.18 J

0.51 U

0.67 J

0.51 U

3

3.6

5.9

1.3

3.9

0.097 J

2.4

0.51 U

0.35 J

HB-04

SED-HB-04-061808

18-Jun-08

0.027 U

0.053

0.014 U

0.014 U

0.014 U

0.023 J

0.014 U

0.014 U

0.014 U

0.41 U

0.16 J

0.064 J

0.65

0.11 J

4.3

5.2

6.5

0.82 J

4.8

0.41 U

1.5

0.41 U

0.42

HB-05

SED-HB-05-121907

19-Dec-07

0.011 U

0.012

0.0054 U

0.0054 U

0.0054 U

0.011 u

0.0054 U

0.0054 U

0.0054 U

0.21 U

0.21 U

0.21 U

0.021 J

0.21 U

0.09 J

0.1 J

0.12 J

0.037 J

0.11 J

0.21 U

0.062 J

0.21 U

0.025 J

HB-05

SED-HB-05-061808

18-Jun-08

0.016 U

0.016 U

0.0082 U

0.0082 U

0.0082 U

0.016 U

0.0082 U

0.0082 U

0.0082 U

0.22 U

0.22 U

0.03 J

0.051 J

0.22 U

0.42

0.57

0.9

0.16 J

0.45

0.22 U

1

0.22 U

0.072 J

HB-06

SED-HB-06-121907

19-Dec-07

0.011 U

0.011 U

0.0053 U

0.0053 U

0.0053 UJ

0.011 U

0.0053 U

0.0053 U

0.0053 U

0.22 U

0.22 U

0.22 U

0.22 U

0.22 U

0.22 U

0.024 J

0.037 J

0.22 U

0.022 J

0.22 U

0.055 J

0.22 U

0.22 U

HB-06

SED-HB-06-061708

17-Jun-08

0.016 U

0.016 U

0.0078 U

0.0078 U

0.0078 U

0.016 U

0.0078 U

0.0078 U

0.0078 U

0.22 U

0.22 U

0.063 J

0.22 U

0.057 J

0.22 U

0.22 U

0.22 U

0.22 U

0.22 U

0.22 U

0.22 U

0.22 U

0.22 U

HB-07

SED-HB-07-121907

19-Dec-07

0.011 U

0.0052 J

0.0057 U

0.0057 U

0.0057 U

0.011 U

0.0057 U

0.0057 U

0.0057 U

0.2 U

0.2 U

0.2 U

0.2 U

0.2 U

0.2 U

0.2 U

0.025 J

0.2 U

0.2 U

0.021 J

0.049 J

0.2 U

0.2 U

HB-07

SED-HB-07-061708

17-Jun-08

0.012 U

0.012 U

0.0062 U

0.0062 U

0.0062 U

0.012 U

0.0062 U

0.0062 U

0.0062 U

0.21 U

0.21 U

0.081 J

0.21 U

0.11 J

0.038 J

0.05 J

0.067 J

0.05 J

0.043 J

0.21 U

0.21 U

0.21 U

0.21 U

HB-08

SED-HB-08-121907

19-Dec-07

0.014 U

0.025

0.0069 U

0.0069 U

0.0069 U

0.014 U

0.0069 U

0.0069 U

0.0069 U

0.2 U

0.2 U

0.2 U

0.2 U

0.2 U

0.095 J

0.11 J

0.16 J

0.044 J

0.13 J

0.2 U

0.062 J

0.2 U

0.2 U

HB-08

SED-HB-08-061708

17-Jun-08

0.011 U

0.03 J

0.0055 U

0.0055 U

0.0055 U

0.012 J

0.0055 U

0.0027 J

0.0055 U

0.2 U

0.2 U

0.027 J

0.2 U

0.2 U

0.027 J

0.032 J

0.037 J

0.029 J

0.031 J

0.2 U

0.2 U

0.2 U

0.2 U

HB-09

SED-HB-09-121907

19-Dec-07

0.015 U

0.012 J

0.0076 U

0.0076 U

0.0076 U

0.015 U

0.0076 U

0.0076 U

0.0076 U

0.28 U

0.037 J

0.28 U

0.061 J

0.28 U

0.48

0.61

0.86

0.24 J

0.73

0.033 J

0.18 J

0.28 U

0.063 J

HB-09

SED-HB-09-061708

17-Jun-08

0.012 U

0.012 U

0.006 U

0.006 U

0.006 U

0.012 U

0.006 U

0.006 U

0.006 U

0.21 U

0.21 U

0.032 J

0.21 U

0.21 U

0.034 J

0.054 J

0.053 J

0.055 J

0.048 J

0.21 U

0.21 U

0.21 U

0.21 U

HB-10

SED-HB-10-121907

19-Dec-07

0.014 U

0.0068 J

0.0068 U

0.0068 U

0.0068 U

0.014 U

0.0068 U

0.0068 U

0.0068 U

0.26 U

0.26 U

0.26 U

0.26 U

0.26 U

0.26 U

0.035 J

0.058 J

0.26 UJ

0.052 J

0.03 J

0.096 J

0.26 U

0.26 U

HB-10

SED-HB-10-061708

17-Jun-08

0.0098 U

0.0098 U

0.0049 U

0.0049 U

0.0049 U

0.0098 U

0.0062

0.0041 J

0.0021 J

0.21 U

0.21 U

0.21 U

0.21 U

0.21 U

0.21 U

0.21 U

0.21 U

0.21 U

0.21 U

0.21 U

0.21 U

0.21 U

0.21 U

HB-11

SED-HB-11-121807

18-Dec-07

0.02 U

0.046

0.0099 U

0.0099 U

0.0099 U

0.0086 J

0.027

0.02

0.0074 J

0.22 U

0.22 U

0.22 U

0.22 U

0.22 U

0.029 J

0.22 U

0.22 UJ

0.22 U

0.22 U

0.22 U

0.22 U

0.22 U

0.22 U

HB-11

SED-HB-11-061708

17-Jun-08

0.77 U

0.77 U

0.38 U

0.38 U

0.24 J

0.77 U

1.8

0.38 U

0.38 U

0.21 U

0.21 U

0.042 J

0.21 U

0.027 J

0.027 J

0.038 J

0.033 J

0.028 J

0.033 J

0.21 U

0.21 U

0.21 U

0.21 U

HB-12

SED-HB-12-121807

18-Dec-07

0.026 R

0.026 R

0.013 R

0.013 R

0.013 R

0.026 R

0.013 R

0.013 R

0.013 R

1.9 R

1.9 R

1.9 R

1.9 R

1.9 R

1.9 R

1.9 R

1.9 R

1.9 R

1.9 R

1.9 R

1.9 U

1.9 R

1.9 R

HB-12

SED-HB-12-061608

16-Jun-08

0.21 R

0.67 J

0.1 R

0.1 R

0.072 J

0.58 J

0.1 R

0.043 J

0.1 R

2.1 R

2.1 R

1.5 J

2.1 R

0.47 J

2.1 R

0.24 J

0.24 J

2.1 R

2.1 R

2.1 R

2.1 U

2.1 R

2.1 R

HB-13

SED-HB-13-121907

19-Dec-07

0.013 U

0.012 J

0.0065 U

0.0065 U

0.0065 U

0.013 U

0.0065 U

0.0065 U

0.0065 U

0.26 U

0.26 U

0.26 U

0.26 U

0.26 U

0.26 U

0.031 J

0.034 J

0.26 UJ

0.032 J

0.028 J

0.078 J

0.26 U

0.26 U

HB-13

SED-HB-13-061708

17-Jun-08

0.014 U

0.018

0.0071 U

0.0071 U

0.0071 U

0.008 J

0.0071 U

0.0071 U

0.0071 U

0.25 U

0.25 U

0.063 J

0.25 U

0.046 J

0.25 U

0.25 U

0.25 U

0.25 U

0.25 U

0.25 U

0.25 U

0.25 U

0.25 U

HB-14

SED-HB-14-121807

18-Dec-07

0.3 R

0.15 J

0.15 R

0.15 R

0.15 R

0.3 R

4.1 J

0.15 R

0.072 J

1.7 R

1.7 R

1.7 R

1.7 R

1.7 R

0.36 J

0.51 J

0.63 J

0.37 J

0.39 J

0.2 J

1.7 U

1.7 R

1.7 R

HB-14

SED-HB-14-061608

16-Jun-08

0.074 UJ

0.084 J

0.037 UJ

0.024 J

0.037 UJ

0.075 J

0.097 J

0.037 UJ

0.06 J

0.68 UJ

0.68 UJ

0.54 J

0.68 UJ

0.15 J

0.095 J

0.13 J

0.12 J

0.68 UJ

0.13 J

0.68 UJ

0.68 U

0.68 UJ

0.68 UJ

HB-15

SED-HB-15-121807

18-Dec-07

0.015 U

0.0065 J

0.0075 U

0.0075 U

0.0075 U

0.015 U

0.0075 U

0.0075 U

0.0075 U

0.21 U

0.21 U

0.21 U

0.21 U

0.21 U

0.11 J

0.12 J

0.13 J

0.079 J

0.093 J

0.042 J

0.21 U

0.21 U

0.21 U

HB-15

SED-HB-X-02-121807

18-Dec-07

0.013 U

0.013 U

0.0063 U

0.0063 U

0.0063 U

0.013 U

0.0063 U

0.0063 U

0.0063 U

0.22 U

0.22 U

0.22 U

0.22 U

0.22 U

0.11 J

0.12 J

0.2 J

0.057 J

0.13 J

0.22 U

0.22 U

0.22 U

0.22 U

HB-15

SED-HB-15-061608

16-Jun-08

0.015 U

0.015 U

0.0073 U

0.0073 U

0.0073 U

0.015 U

0.0073 U

0.0073 U

0.0073 U

0.25 U

0.042 J

0.25 U

0.078 J

0.25 U

0.47

0.51

0.59

0.16 J

0.49

0.25 U

0.29

0.25 U

0.049 J

HB-16

SED-HB-16-121707

17-Dec-07

0.013 U

0.013 U

0.0063 U

0.0063 U

0.0063 U

0.013 U

0.0063 U

0.0063 U

0.0063 U

0.2 U

0.2 U

0.2 U

0.2 U

0.2 U

0.2 U

0.02 J

0.2 U

0.2 UJ

0.2 U

0.2 U

0.2 U

0.2 U

0.2 U

HB-16

SED-HB-16-061608

16-Jun-08

0.01 U

0.024

0.0058

0.0052 U

0.0052 U

0.011

0.0052 U

0.0052 U

0.0052 U

0.066 J

0.2 U

0.2 U

0.2 U

0.2 U

0.054 J

0.064 J

0.055 J

0.027 J

0.065 J

0.2 U

0.2 U

0.2 U

0.2 U

HB-16

SED-HB-X-02-061608

16-Jun-08

0.0097 U

0.0097 U

0.0048 U

0.0048 U

0.0048 U

0.0072 J

0.0048 U

0.0048 U

0.0048 U

0.039 J

0.2 U

0.2 U

0.2 U

0.2 U

0.072 J

0.078 J

0.083 J

0.028 J

0.078 J

0.2 U

0.2 U

0.2 U

0.2 U

HB-17

SED-HB-17-121707

17-Dec-07

0.022 U

0.022 U

0.011 U

0.011 U

0.011 U

0.022 U

0.011 U

0.011 U

0.011 U

0.45 U

0.45 U

0.45 U

0.45 U

0.093 J

0.45 U

0.45 U

0.45 U

0.45 UJ

0.45 U

0.45 U

0.45 U

0.45 U

0.45 U

HB-17

SED-HB-17-061608

16-Jun-08

0.0095 U

0.014

0.0047 U

0.0047 U

0.0047 U

0.0063 J

0.0047 U

0.0047 U

0.0047 U

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.19 UJ

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

HB-18

SED-HB-18-121707

17-Dec-07

0.013 U

0.013 U

0.0065 U

0.0065 U

0.0065 U

0.013 U

0.0065 U

0.0065 U

0.0065 U

0.21 U

0.21 U

0.21 U

0.21 U

0.21 U

0.21 U

0.21 U

0.21 U

0.21 UJ

0.21 U

0.21 U

0.21 U

0.21 U

0.21 U

HB-18

SED-HB-18-061608

16-Jun-08

0.013 U

0.013 U

0.0063 U

0.0063 U

0.0063 U

0.013 U

0.0063 U

0.0063 U

0.0063 U

0.22 U

0.22 U

0.22 U

0.22 U

0.22 U

0.22 U

0.22 U

0.22 U

0.22 UJ

0.22 U

0.22 U

0.22 U

0.22 U

0.22 U

HB-S-1

SED-HB-S-1-063009

30-Jun-09

0.01 U

0.054

0.005 U

0.005 U

0.005 U

0.025

0.005 U

0.005 U

0.005 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

HB-S-2

SED-HB-S-2-062909

29-Jun-09

0.011 U

0.012

0.0055 U

0.0055 U

0.0055 U

0.0049 J

0.0055 U

0.0055 U

0.0055 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

HB-S-3

SED-HB-S-3-063009

30-Jun-09

0.04 U

0.04 U

0.008 J

0.014 J

0.02 U

0.039 J

0.13 J

0.0077 J

0.028 J

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

HB-S-4

SED-HB-S-4-063009

30-Jun-09

0.012 J

0.18

0.0052 J

0.0082 U

0.0082 U

0.077

0.0082 U

0.0036 J

0.0082 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

HB-S-5

SED-HB-S-5-063009

30-Jun-09

0.027 J

0.028 U

0.014 U

0.022

0.014 U

0.12

0.16 J

0.014 R

0.097 J

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

HB-S-6

SED-HB-S-6-063009

30-Jun-09

0.0044 J

0.0091 U

0.0046 U

0.0046 U

0.0046 U

0.0044 J

0.32

0.0037 J

0.0046 U

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

HB-S-7

SED-HB-S-7-063009

30-Jun-09

0.012 U

0.11 J

0.0058 R

0.0058 R

0.0058 R

0.017

0.65 J

0.0034 J

0.0044 J

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

Notes:

1.	'SSSSC' designates Site-specific Soil Screening Criteria

= exceeds SSSSC

2.	BOLD = detection

3.	TCL Volatile Organic Compounds, Semi-Volatile Organic Compounds and Pesticides/PCBs quantitated by Method SOM01.2.
TAL Metals quantitated by Method ILM05.3 and ILM05.4.

4.	Results are expressed in milligrams per kilogram (mg/kg).

5.	'NC' indicates screening criteria is not available.

6.	'NA' indicates the parameter was not analyzed for.

7.	'U' designates the analyte is not detected at or above the listed reporting limit.

8.	'R' designates that the reported sample result is not usable.

9.	'J' designates reported concentration is an estimated value.

10.	'NJ' designates that the analyte has been "tentatively identified"; the reported concentration is an approximate value.

11.	'UJ' designates that the analyte was not detected at or above the listed reporting limit; the limit is an approximate value.

Page 1 of 3

-------
Table 6

Hannabrand Brook Sediment Detections and Screening Criteria Exceedances
White Swan Cleaners/Sun Cleaners Area Ground Water Contamination Superfund Site

Parameter:

Chrysene

Dibenz(a,h)anthracene

Dibenzofuran

Di-n-butyl phthalate

Di-n-octylphthalate

Fluoranthene

Fluorene

lndeno(1,2,3-c,d)pyrene

Naphthalene

Phenanthrene

Pyrene

Pesticides/PCBs (mg/kg)

4,4-DDD

4,4-DDE

4,4-DDT

alpha BHC

alpha Endosulfan

alpha-Chlordane

Beta BHC

Dieldrin

Endrin

Endrin Aldehyde

Endrin Ketone

gamma-Chlordane

SSSSC

52

0.2

NC

620

2,400

840

110

0.6

6

300,000

550

3

2

2

0.002

2

0.03

0.002

0.003

0.6

NC

NC

0.03

Location

Sample ID

Date

HB-01

SED-HB-01-121907

19-Dec-07

1 J

0.074 J

0.064 J

0.22 U

0.22 UJ

2.2 J

0.13 J

0.26 J

0.22 U

1.7 J

1.8 J

0.0043 U

0.0037 J

0.0043 U

0.0022 U

0.0022 U

0.0022 U

0.0022 U

0.0043 U

0.0043 U

0.0043 U

0.0043 U

0.0022 U

HB-01

SED-HB-01-061808

18-Jun-08

0.031 J

0.21 UJ

0.21 U

0.21 U

0.21 U

0.054 J

0.21 U

0.21 UJ

0.21 U

0.021 J

0.056 J

0.004 U

0.004 U

0.004 U

0.0021 U

0.0021 U

0.0021 U

0.0021 U

0.004 U

0.0022 J

0.0034 NJ

0.0073

0.0026 NJ

HB-02

SED-HB-02-121907

19-Dec-07

0.087 J

0.21 U

0.21 U

0.21 U

0.21 UJ

0.12 J

0.21 U

0.03 J

0.21 U

0.046 J

0.11 J

0.0041 U

0.0041 U

0.0041 U

0.0021 U

0.0021 U

0.0021 U

0.0021 U

0.0041 U

0.0041 U

0.0041 U

0.0041 U

0.0021 U

HB-02

SED-HB-02-061808

18-Jun-08

0.038 J

0.21 UJ

0.21 U

0.21 U

0.21 U

0.085 J

0.21 U

0.024 J

0.21 U

0.042 J

0.087 J

0.0041 U

0.0041 U

0.0041 U

0.0021 U

0.0021 U

0.0021 U

0.0021 U

0.0041 U

0.0041 U

0.0041 U

0.0041 U

0.0021 U

HB-03

SED-HB-03-121907

19-Dec-07

0.12 J

0.22 U

0.22 U

0.22 U

0.22 UJ

0.18 J

0.22 U

0.042 J

0.22 U

0.093 J

0.15 J

0.0042 U

0.0042 U

0.0042 U

0.0021 U

0.0021 U

0.0017 J

0.0021 U

0.0042 U

0.0042 U

0.0042 U

0.0042 U

0.0013 NJ

HB-03

SED-HB-03-061808

18-Jun-08

0.11 J

0.022 J

0.22 U

0.22 U

0.22 U

0.19 J

0.22 U

0.071 J

0.22 U

0.12 J

0.2 J

0.0043 U

0.0043 U

0.0043 U

0.0022 U

0.0022 U

0.0022 U

0.0022 U

0.0043 U

0.0043 U

0.0043 U

0.0043 U

0.0022 U

HB-04

SED-HB-04-121907

19-Dec-07

5

0.39 J

0.11 J

0.056 J

0.074 J

5.3

0.26 J

1.3

0.51 U

3.8 J

7.6

0.0084 J

0.015

0.01 U

0.0052 U

0.0052 U

0.0056 NJ

0.003 NJ

0.01 U

0.01 U

0.01 U

0.01 U

0.0048 NJ

HB-04

SED-HB-04-061808

18-Jun-08

6

0.31 J

0.086 J

0.41 U

0.41 U

11

0.22 J

0.97 J

0.41 U

3.8

7.3

0.0065 NJ

0.012

0.01 NJ

0.0042 U

0.0042 U

0.0055 NJ

0.0042 U

0.0081 U

0.0081 U

0.0053 J

0.0078 J

0.0044 NJ

HB-05

SED-HB-05-121907

19-Dec-07

0.13 J

0.21 U

0.21 U

0.21 U

0.21 UJ

0.26

0.21 U

0.036 J

0.21 U

0.17 J

0.21 J

0.0041 U

0.0041 U

0.0041 U

0.0021 U

0.0021 U

0.0021 U

0.0021 U

0.0041 U

0.0041 U

0.0041 U

0.0041 U

0.0021 U

HB-05

SED-HB-05-061808

18-Jun-08

0.61

0.052 J

0.22 U

0.22 U

0.22 U

1.3

0.022 J

0.2 J

0.22 U

0.5

0.84

0.0042 U

0.0042 U

0.0042 U

0.0022 U

0.0022 U

0.0027 NJ

0.0022 U

0.0042 U

0.0042 U

0.0042 U

0.0022 NJ

0.002 NJ

HB-06

SED-HB-06-121907

19-Dec-07

0.028 J

0.22 U

0.22 U

0.22 U

0.22 UJ

0.032 J

0.22 U

0.22 U

0.22 U

0.22 U

0.03 J

0.0042 U

0.0042 U

0.0042 U

0.0022 U

0.0022 U

0.0022 U

0.0022 U

0.0042 U

0.0042 U

0.0042 U

0.0042 U

0.0022 U

HB-06

SED-HB-06-061708

17-Jun-08

0.22 U

0.22 U

0.22 U

0.22 U

0.22 U

0.22 U

0.22 U

0.22 U

0.22 U

0.22 U

0.22 U

0.0043 U

0.0043 U

0.0043 U

0.0022 U

0.0022 U

0.0022 U

0.0022 U

0.0043 U

0.0043 U

0.0043 U

0.0043 U

0.0022 U

HB-07

SED-HB-07-121907

19-Dec-07

0.021 J

0.2 U

0.2 U

0.2 U

0.2 UJ

0.032 J

0.2 U

0.2 U

0.2 U

0.2 U

0.027 J

0.004 U

0.004 U

0.004 U

0.002 U

0.002 U

0.002 U

0.002 U

0.004 U

0.004 U

0.004 U

0.004 U

0.002 U

HB-07

SED-HB-07-061708

17-Jun-08

0.058 J

0.21 U

0.21 U

0.21 U

0.21 U

0.086 J

0.21 U

0.047 J

0.21 U

0.039 J

0.099 J

0.004 U

0.004 U

0.004 U

0.0021 U

0.0021 U

0.0012 J

0.0021 U

0.004 U

0.004 U

0.004 U

0.004 U

0.0021 U

HB-08

SED-HB-08-121907

19-Dec-07

0.14 J

0.2 U

0.2 U

0.2 U

0.2 UJ

0.25

0.2 U

0.047 J

0.2 U

0.12 J

0.21

0.0039 U

0.0039 U

0.0039 U

0.002 U

0.002 U

0.0012 J

0.002 U

0.0039 U

0.0039 U

0.0039 U

0.0039 U

0.001 NJ

HB-08

SED-HB-08-061708

17-Jun-08

0.04 J

0.2 UJ

0.2 U

0.2 U

0.2 U

0.069 J

0.2 U

0.027 J

0.2 U

0.03 J

0.067 J

0.004 U

0.004 U

0.004 U

0.002 U

0.002 U

0.001 J

0.002 U

0.004 U

0.004 U

0.004 U

0.004 U

0.002 U

HB-09

SED-HB-09-121907

19-Dec-07

0.81

0.058 J

0.28 U

0.28 U

0.28 U

1.2

0.043 J

0.25 J

0.28 U

0.54

1.3

0.0052 J

0.0054 J

0.0054 U

0.0028 U

0.0028 U

0.0056 NJ

0.0028 U

0.0054 U

0.0054 U

0.0054 U

0.0054 U

0.0039 NJ

HB-09

SED-HB-09-061708

17-Jun-08

0.053 J

0.21 U

0.21 U

0.21 U

0.21 U

0.078 J

0.21 U

0.048 J

0.21 U

0.03 J

0.09 J

0.0042 U

0.0042 U

0.0042 U

0.0021 U

0.0021 U

0.0015 J

0.0021 U

0.0042 U

0.0042 U

0.0042 U

0.0042 U

0.0012 NJ

HB-10

SED-HB-10-121907

19-Dec-07

0.055 J

0.26 U

0.26 U

0.26 U

0.26 U

0.07 J

0.26 U

0.26 U

0.26 U

0.027 J

0.076 J

0.0082

0.011

0.0029 J

0.0026 U

0.0026 U

0.0026 U

0.0026 U

0.0051 U

0.0051 U

0.0051 U

0.0051 U

0.0026 U

HB-10

SED-HB-10-061708

17-Jun-08

0.21 U

0.21 U

0.21 U

0.21 U

0.21 U

0.21 U

0.21 U

0.21 U

0.21 U

0.21 U

0.21 U

0.004 U

0.004 U

0.004 U

0.0021 U

0.0021 U

0.0021 U

0.0021 U

0.004 U

0.004 U

0.004 U

0.004 U

0.0021 U

HB-11

SED-HB-11-121807

18-Dec-07

0.051 J

0.22 U

0.22 U

0.22 U

0.22 UJ

0.088 J

0.22 U

0.22 U

0.22 U

0.031 J

0.071 J

0.0042 U

0.0027 J

0.0024 J

0.0022 U

0.0022 U

0.0068

0.0022 U

0.0027 J

0.0042 U

0.0042 U

0.0042 U

0.0048

HB-11

SED-HB-11-061708

17-Jun-08

0.042 J

0.21 U

0.21 U

0.21 U

0.21 U

0.058 J

0.21 U

0.025 J

0.21 U

0.044 J

0.06 J

0.0023 J

0.0041 U

0.0041 U

0.0021 U

0.0021 U

0.022

0.0021 U

0.0036 J

0.0041 U

0.0041 U

0.0041 U

0.021

HB-12

SED-HB-12-121807

18-Dec-07

1.9 R

1.9 R

1.9 R

1.9 R

1.9 R

0.41 J

1.9 R

1.9 R

1.9 R

1.9 R

0.4 J

0.031 J

0.033 J

0.037 R

0.019 R

0.019 R

0.019 R

0.019 R

0.037 R

0.037 R

0.037 R

0.037 R

0.019 R

HB-12

SED-HB-12-061608

16-Jun-08

0.26 J

2.1 R

2.1 R

2.1 R

2.1 R

0.37 J

2.1 R

2.1 R

2.1 R

2.1 R

0.39 J

0.041 R

0.036 J

0.041 R

0.021 R

0.03 J

0.07 J

0.021 R

0.041 R

0.041 R

0.041 R

0.041 R

0.018 NJ

HB-13

SED-HB-13-121907

19-Dec-07

0.041 J

0.26 U

0.26 U

0.26 U

0.26 U

0.053 J

0.26 U

0.26 U

0.26 U

0.26 U

0.065 J

0.005 U

0.005 U

0.005 U

0.0026 U

0.0026 U

0.0026 U

0.0026 U

0.005 U

0.005 U

0.005 U

0.005 U

0.0026 U

HB-13

SED-HB-13-061708

17-Jun-08

0.25 U

0.25 U

0.25 U

0.25 U

0.25 U

0.25 U

0.25 U

0.25 U

0.25 U

0.25 U

0.25 U

0.0049 U

0.0049 U

0.0049 U

0.0025 U

0.0025 U

0.0025 U

0.0025 U

0.0049 U

0.0049 U

0.0049 U

0.0049 U

0.0025 U

HB-14

SED-HB-14-121807

18-Dec-07

0.59 J

1.7 R

1.7 R

1.7 R

1.7 R

0.9 J

1.7 R

0.41 J

1.7 R

0.33 J

1.3 J

0.082 J

0.062 J

0.033 R

0.017 R

0.017 R

0.033 J

0.017 R

0.033 R

0.033 R

0.033 R

0.033 R

0.028 J

HB-14

SED-HB-14-061608

16-Jun-08

0.14 J

0.68 UJ

0.68 UJ

0.68 UJ

0.68 UJ

0.26 J

0.68 UJ

0.68 UJ

0.68 UJ

0.12 J

0.25 J

0.013 UJ

0.013 UJ

0.013 UJ

0.0068 UJ

0.0068 UJ

0.0068 UJ

0.0068 UJ

0.013 UJ

0.013 UJ

0.013 UJ

0.013 UJ

0.0068 UJ

HB-15

SED-HB-15-121807

18-Dec-07

0.15 J

0.21 U

0.21 U

0.21 U

0.21 UJ

0.21 J

0.21 U

0.07 J

0.21 U

0.087 J

0.29 J

0.0023 J

0.0041 U

0.0041 U

0.0021 U

0.0021 U

0.0023

0.0021 U

0.0041 U

0.0041 U

0.0041 U

0.0041 U

0.0023

HB-15

SED-HB-X-02-121807

18-Dec-07

0.16 J

0.22 U

0.22 U

0.22 U

0.22 UJ

0.23

0.22 U

0.054 J

0.22 U

0.084 J

0.25

0.0038 J

0.0022 J

0.0042 U

0.0022 U

0.0022 U

0.0024

0.0022 U

0.0042 U

0.0042 U

0.0042 U

0.0042 U

0.0025

HB-15

SED-HB-15-061608

16-Jun-08

0.6

0.053 J

0.25 U

0.25 U

0.25 U

1.1

0.047 J

0.18 J

0.026 J

0.51

0.95

0.0049 U

0.0025 J

0.0049 U

0.0012 NJ

0.0025 U

0.0031

0.0025 U

0.0049 U

0.0049 U

0.0049 U

0.0049 U

0.0024 J

HB-16

SED-HB-16-121707

17-Dec-07

0.2 U

0.2 U

0.2 U

0.2 U

0.2 UJ

0.021 J

0.2 U

0.2 U

0.2 U

0.2 U

0.025 J

0.0039 U

0.0039 U

0.0039 U

0.002 U

0.002 U

0.002 U

0.002 U

0.0039 U

0.0039 U

0.0039 U

0.0039 U

0.002 U

HB-16

SED-HB-16-061608

16-Jun-08

0.065 J

0.2 U

0.2 U

0.2 U

0.2 U

0.13 J

0.2 U

0.029 J

0.2 U

0.056 J

0.12 J

0.004 U

0.004 U

0.004 U

0.002 U

0.002 U

0.002 U

0.002 U

0.004 U

0.004 U

0.004 U

0.004 U

0.002 U

HB-16

SED-HB-X-02-061608

16-Jun-08

0.088 J

0.2 U

0.2 U

0.2 U

0.2 U

0.19 J

0.2 U

0.031 J

0.2 U

0.11 J

0.15 J

0.0039 U

0.0039 U

0.0039 U

0.002 U

0.002 U

0.002 U

0.002 U

0.0039 U

0.0039 U

0.0039 U

0.0039 U

0.002 U

HB-17

SED-HB-17-121707

17-Dec-07

0.45 U

0.45 U

0.45 U

0.45 U

0.45 UJ

0.074 J

0.45 U

0.45 U

0.45 U

0.45 U

0.068 J

0.0087 U

0.0087 U

0.0087 U

0.0045 U

0.0045 U

0.0045 U

0.0045 U

0.0087 U

0.0087 U

0.0087 U

0.0087 U

0.0045 U

HB-17

SED-HB-17-061608

16-Jun-08

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.021 J

0.19 U

0.19 U

0.19 U

0.19 U

0.19 U

0.0037 U

0.0037 U

0.0037 U

0.0019 U

0.0019 U

0.0019 U

0.0019 U

0.0037 U

0.0037 U

0.0037 U

0.0037 U

0.0019 U

HB-18

SED-HB-18-121707

17-Dec-07

0.21 U

0.21 U

0.21 U

0.21 U

0.21 UJ

0.21 U

0.21 U

0.21 U

0.21 U

0.21 U

0.21 U

0.0041 U

0.0041 U

0.0041 U

0.0021 U

0.0021 U

0.0021 U

0.0021 U

0.0041 U

0.0041 U

0.0041 U

0.0041 U

0.0021 U

HB-18

SED-HB-18-061608

16-Jun-08

0.22 U

0.22 U

0.22 U

0.22 U

0.22 U

0.22 U

0.22 U

0.22 U

0.22 U

0.22 U

0.22 U

0.0043 U

0.0043 U

0.0043 U

0.0022 U

0.0022 U

0.0022 U

0.0022 U

0.0043 U

0.0043 U

0.0043 U

0.0043 U

0.0022 U

HB-S-1

SED-HB-S-1 -063009

30-Jun-09

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

HB-S-2

SED-HB-S-2-062909

29-Jun-09

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

HB-S-3

SED-HB-S-3-063009

30-Jun-09

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

HB-S-4

SED-HB-S-4-063009

30-Jun-09

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

HB-S-5

SED-HB-S-5-063009

30-Jun-09

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

HB-S-6

SED-HB-S-6-063009

30-Jun-09

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

HB-S-7

SED-HB-S-7-063009

30-Jun-09

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

Notes:

1.	'SSSSC' designates Site-specific Soil Screening Criteria

= exceeds SSSSC

2.	BOLD = detection

3.	TCL Volatile Organic Compounds, Semi-Volatile Organic Compounds and Pesticides/PCBs quantitated by Method SOM01.2.
TAL Metals quantitated by Method ILM05.3 and ILM05.4.

4.	Results are expressed in milligrams per kilogram (mg/kg).

5.	'NC' indicates screening criteria is not available.

6.	'NA' indicates the parameter was not analyzed for.

7.'U'	designates the analyte is not detected at or above the listed reporting limit.

8.'R'	designates that the reported sample result is not usable.

9.	'J' designates reported concentration is an estimated value.

10.'NJ'	designates that the analyte has been "tentatively identified"; the reported concentration is an approximate value.

11.'UJ'	designates that the analyte was not detected at or above the listed reporting limit; the limit is an approximate value.

Page 2 of 3

-------
Table 6

Hannabrand Brook Sediment Detections and Screening Criteria Exceedances
White Swan Cleaners/Sun Cleaners Area Ground Water Contamination Superfund Site

Parameter:

Heptachlor epoxide

Metals (mg/kg)

Aluminum

Antimony

Arsenic

Barium

Beryllium

Cadmium

Calcium

Chromium

Cobalt

Copper

Cyanide

Iron

Lead

Magnesium

Manganese

Mercury

Nickel

Potassium

Selenium

Silver

Sodium

Vanadium

Zinc

SSSSC

0.009

3,900

6

19

1,300

0.5

1

NC

NC

59

3,100

13

NC

59

NC

42

0.1

31

NC

7

1

NC

78

600

Location

Sample ID

Date

HB-01

SED-HB-01-121907

19-Dec-07

0.0022 U

461

5.7 U

0.3 J

4.6 J

0.11 J

0.045 J

111 J

1.2

4.8 U

2.4 U

NA

1,010

3.6 J

63 J

8.5

0.12 U

3.8 U

51.9 J

3.3 U

0.95 U

476 U

1.5 J

2.4 J

HB-01

SED-HB-01-061808

18-Jun-08

0.0021 U

270

6 U

1 U

3.6 J

0.5 U

0.5 U

502 U

1.5

0.087 J

0.46 J

2.8 U

409 J

4.6

502 U

1.5

0.11 U

4 U

29.9 J

3.5 U

1 U

502 U

5 U

6 U

HB-02

SED-HB-02-121907

19-Dec-07

0.0021 U

375

5.4 U

0.9 U

1.7 J

0.036 J

0.45 U

84 J

0.9

4.5 U

2.2 U

NA

809

1.7 J

104 J

4.5

0.13 U

0.38 J

51.6 J

3.1 U

0.9 U

448 U

1.4 J

2.3 J

HB-02

SED-HB-02-061808

18-Jun-08

0.0021 U

365

6.7 U

1.1 U

2.7 J

0.56 U

0.56 U

558 U

1.2

0.31 J

0.73 J

2.4 U

743 J

2.6

558 U

7.1

0.11 U

4.5 U

35.7 J

3.9 U

1.1 U

558 U

5.6 U

6.7 U

HB-03

SED-HB-03-121907

19-Dec-07

0.0021 U

497

5.7 U

0.95 U

3.6 J

0.054 J

0.054 J

268 J

1.1

4.8 U

2.4 U

NA

1,100

3.2 J

77.2 J

7.2

0.097 U

0.55 J

64.1 J

3.3 U

0.95 U

477 U

1.8 J

3 J

HB-03

SED-HB-03-061808

18-Jun-08

0.0022 U

492

6.3 U

0.5 J

2.8 J

0.53 U

0.53 U

529 U

1.5

0.34 J

1.1 J

2.9 U

1,100 J

3.1

529 U

6.3

0.1 U

4.2 U

72.7 J

3.7 U

1.1 U

529 U

5.3 U

6.3 U

HB-04

SED-HB-04-121907

19-Dec-07

0.0052 U

6,150

13.4 U

3.5

65.8

0.71 J

2.4

2,060

17.9

11.2 U

57.5

NA

11,400

59.9 J

648 J

42.1

1.1 U

39

319 J

7.8 U

2.2 U

1,120 U

17.6

126 J

HB-04

SED-HB-04-061808

18-Jun-08

0.0024 NJ

2,460

10.9 U

1.2 J

20.4 J

0.91 U

0.91 U

908 U

10.4

3 J

22.6

4.9 U

6,040 J

20.6

908 U

31.9

0.19 U

17.3

170 J

6.4 U

1.8 U

908 U

9.4

44.9

HB-05

SED-HB-05-121907

19-Dec-07

0.0021 U

411

5.5 U

0.92 U

2.8 J

0.031 J

0.46 U

84 J

1.3

4.6 U

2.3 U

NA

914

3.2 J

55.8 J

4.9

0.45 U

3.7 U

51.7 J

3.2 U

0.92 U

460 U

1.4 J

2.3 J

HB-05

SED-HB-05-061808

18-Jun-08

0.0022 U

488

5.6 U

0.93 U

4.4 J

0.47 U

0.47 U

467 U

2.9

0.27 J

2 J

2.7 U

1,080 J

8.7

467 U

7.2

0.1 U

3.7 U

33.6 J

3.3 U

0.93 U

467 U

4.7 U

5.6 U

HB-06

SED-HB-06-121907

19-Dec-07

0.0022 U

724

5.3 U

0.34 J

4.5 J

0.44 U

0.37 J

341 J

2.5

4.4 U

2.4

NA

2,360

3.8 J

208 J

25.2

0.12 U

1.8 J

45.5 J

3.1 U

0.89 U

442 U

3.2 J

5.3 J

HB-06

SED-HB-06-061708

17-Jun-08

0.0022 U

701

6.3 U

0.85 J

4.8 J

0.11 J

0.53 U

275 J

2

0.21 J

1.4 J

3.2 U

1,120 J

3.4

34.7 J

12.2

0.016 J

4.2 U

37.5 J

3.7 U

1.1 U

23.3 J

5.3 U

6.3 U

HB-07

SED-HB-07-121907

19-Dec-07

0.002 U

714

5.5 U

0.28 J

4.3 J

0.46 U

0.063 J

388 J

1.4

4.6 U

2.8

NA

1,870

3.4 J

247 J

13.1

0.1 u

1.3 J

60 J

3.2 U

0.91 U

457 U

4.6

4.5 J

HB-07

SED-HB-07-061708

17-Jun-08

0.0021 U

421

5.4 U

0.42 J

4.3 J

0.1 J

0.45 U

150 J

1.8

0.23 J

1.4 J

2.9 U

1,150 J

5.4

83.7 J

4.3

0.12 U

3.6 U

55.7 J

3.2 U

0.91 U

13.7 J

4.5 U

5.4 U

HB-08

SED-HB-08-121907

19-Dec-07

0.002 U

313

5.2 U

0.87 U

1.6 J

0.44 U

0.048 J

80 J

0.87 U

4.4 U

2.2 U

NA

398

2.4 J

63.5 J

1.3 U

0.082 U

3.5 U

34.1 J

3 U

0.87 U

436 U

0.89 J

1.6 J

HB-08

SED-HB-08-061708

17-Jun-08

0.002 U

340

5.8 U

0.96 U

2.3 J

0.057 J

0.48 U

75 J

1.3

0.13 J

0.89 J

2.4 U

671 J

3.8

56.5 J

4.1

0.0099 J

3.9 U

33.3 J

3.4 U

0.96 U

16.1 J

4.8 U

5.8 U

HB-09

SED-HB-09-121907

19-Dec-07

0.0028 U

1,820

7.2 U

0.84 J

20.5 J

0.25 J

0.57 J

613

5.2

6 U

8.4

NA

3,260

22.2 J

216 J

27.3

0.6 U

7.7

124 J

4.2 U

1.2 U

598 U

6

29.2 J

HB-09

SED-HB-09-061708

17-Jun-08

0.0021 U

877

0.45 J

1.1 U

17.5 J

0.26 J

0.53 U

315 J

2.6

0.26 J

9.3

2.9 U

1,080 J

24.4

79.1 J

4.4

0.012 J

4.3 U

63.5 J

3.7 U

1.1 U

19.4 J

5.3 U

8.3

HB-10

SED-HB-10-121907

19-Dec-07

0.0026 U

2,210

6.5 U

0.9 J

7.9 J

0.074 J

0.069 J

348 J

2.5

5.5 U

2.7 U

NA

1,090

3.9 J

145 J

3.7

0.15 U

0.56 J

171 J

3.8 U

1.1 U

545 U

3.3 J

4.9 J

HB-10

SED-HB-10-061708

17-Jun-08

0.0021 U

2,410

6.1 U

0.84 J

6.8 J

0.081 J

0.51 U

235 J

2.6

0.33 J

0.56 J

2.8 U

1,330 J

5.3

219 J

5.9

0.062 J

4.1 U

161 J

3.6 U

1 U

14.2 J

5.1 U

6.1 U

HB-11

SED-HB-11-121807

18-Dec-07

0.0017 J

1,530

5.6 U

0.82 J

3.9 J

0.035 J

0.47 U

147 J

2.7

4.7 U

1.8 J

NA

1,790

9.1

140 J

5

0.44 U

0.98 J

88.8 J

0.32 J

0.94 U

471 U

4.6 J

4.8 J

HB-11

SED-HB-11-061708

17-Jun-08

0.0018 J

2,570

5.2 U

1.5

9.3 J

0.12 J

0.44 U

559

4.5

0.81 J

7.3

0.13 J

3,220 J

17.6

477

13.7

0.11 U

3.5 U

157 J

3 U

0.87 U

47.8 J

8.3

8.7

HB-12

SED-HB-12-121807

18-Dec-07

0.019 R

10,500 J

42.1 R

5.2 J

76.7 J

0.91 J

1.3 J

8,150 J

17 J

35.1 U

28.1 J

NA

9,250 J

279 J

1,650 J

35 J

3.8 U

19.4 J

749 J

3.5 J

7 R

3,510 U

21.4 J

105 J

HB-12

SED-HB-12-061608

16-Jun-08

0.06 J

12,200 J

57 R

11.2 J

131 J

1.2 J

2.9 J

15,200 J

20.8 J

4.9 J

55.1 J

28.8 R

16,100 J

204 J

2,170 J

76.3 J

0.26 J

34.6 J

921 J

33.2 U

9.5 R

485 J

47.5 U

145 J

HB-13

SED-HB-13-121907

19-Dec-07

0.0026 U

513

0.34 J

1.2 U

7.3 J

0.028 J

0.12 J

144 J

1.6

5.8 U

2.9 U

NA

1,040

8 J

55.5 J

11.6

0.14 U

1.9 J

56 J

4.1 U

1.2 U

581 U

1.9 J

7.3 J

HB-13

SED-HB-13-061708

17-Jun-08

0.0025 U

943

7.4 U

1.3

6.8 J

0.072 J

0.62 U

147 J

2.9

0.59 J

1.9 J

3.1 U

1,350 J

11.6

114 J

4.7

0.012 J

5 U

120 J

0.59 J

1.2 U

21.5 J

6.2 U

10.2

HB-14

SED-HB-14-121807

18-Dec-07

0.017 R

16,900 J

46.7 R

9.1 J

110 J

1.2 J

1.6 J

3,910 J

27.5 J

38.9 U

49.6 J

NA

15,900 J

215 J

1,860 J

33.3 J

2.8 U

22.8 J

880 J

27.3 U

7.8 R

3,890 U

36 J

64.7 J

HB-14

SED-HB-14-061608

16-Jun-08

0.0068 UJ

8,450 J

18.4 UJ

4.4 J

52 J

1 J

0.98 J

2,770 J

13.2 J

2.6 J

19.8 J

8.7 UJ

12,300 J

105 J

988 J

24.3 J

0.12 J

13.1 J

410 J

10.7 U

3.1 UJ

152 J

19.1 J

71 J

HB-15

SED-HB-15-121807

18-Dec-07

0.0021 U

1,210 J

5.6 U

0.74 J

5.3 J

0.081 J

0.54

280 J

5.1 J

4.7 U

5.9 J

NA

2,240 J

20.2 J

169 J

5

0.11 u

5.2

115 J

3.3 U

0.93 U

465 U

4.5 J

24.6 J

HB-15

S E D- H B-X-02-121807

18-Dec-07

0.0022 U

699 J

5.6 U

0.37 J

1.8 J

0.042 J

0.1 J

218 J

2 J

4.6 U

1.5 J

NA

1,210 J

4.8 J

158 J

3.8

0.46 U

1.9 J

70.4 J

3.3 U

0.93 U

465 U

2.6 J

7.6 J

HB-15

SED-HB-15-061608

16-Jun-08

0.0025 U

2,570

7.2 UJ

1.3

15.2 J

0.41 J

1.5

991

7.9

2.5 J

21.2 J

3.7 U

4,600 J

1.2 U

436 J

15

0.061 J

13

161 J

4.2 U

0.32 J

91.1 J

8.2

66.2 J

HB-16

SED-HB-16-121707

17-Dec-07

0.002 U

264

5.3 U

0.32 J

0.3 J

0.018 J

0.44 U

91 J

0.89 U

4.4 U

1.9 J

NA

613

2.9

106 J

2.6

0.34 U

0.69 J

41.6 J

3.1 U

0.89 U

444 U

1.5 J

3.8 J

HB-16

SED-HB-16-061608

16-Jun-08

0.002 U

1,350

6 UJ

2.3 J

5.4 J

0.18 J

0.23 J

554

4.4 J

0.75 J

10.3 J

2.4 U

4,630 J

24.2 J

461 J

10.9 J

0.017 J

6.4

192 J

3.5 U

1 U

113 J

6.4

29.3 J

HB-16

SED-HB-X-02-061608

16-Jun-08

0.002 U

1,200

2 J

0.79 J

2.9 J

0.094 J

0.11 J

430 J

3.1 J

0.49 J

10.5 J

2.7 U

2,120 J

0.95 U

342 J

7.7 J

0.12 U

3.8 U

140 J

3.3 U

0.95 U

100 J

4.7 U

17.4 J

HB-17

SED-HB-17-121707

17-Dec-07

0.0045 U

2,590

11.8 U

1.2 J

31.1 J

0.037 J

0.1 J

800 J

5.9

9.8 U

9.4

NA

4,080

42.1

469 J

16.7

1 U

2.4 J

200 J

6.9 U

2 U

984 U

7.2 J

33.3

HB-17

SED-HB-17-061608

16-Jun-08

0.0019 U

366

4.7 UJ

0.79 U

2 J

0.02 J

0.39 U

151 J

0.91

0.23 J

1.3 J

2.6 U

585 J

0.79 U

101 J

2.6

0.086 U

3.1 U

26.8 J

2.8 U

0.79 U

34.4 J

3.9 U

8.6 J

HB-18

SED-HB-18-121707

17-Dec-07

0.0021 U

1,170

5.6 U

3

1.4 J

0.23 J

0.47 U

2,510

7.2

4.7 U

0.72 J

NA

6,140

4.2

804

18.6

0.4 U

1.5 J

1,130

3.3 U

0.93 U

466 U

9.2

13.6

HB-18

SED-HB-18-061608

16-Jun-08

0.0022 U

1,910

5.7 UJ

4

4.8 J

0.35 J

0.091 J

2,850

11.1

1.4 J

1.9 J

2.8 U

8,740 J

7.4

1,290

36.3

0.017 J

3.8 U

1,670

3.3 U

0.95 U

1,060

11.9

21.9 J

HB-S-1

SED-HB-S-1 -063009

30-Jun-09

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

HB-S-2

SED-HB-S-2-062909

29-Jun-09

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

HB-S-3

SED-HB-S-3-063009

30-Jun-09

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

HB-S-4

SED-HB-S-4-063009

30-Jun-09

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

HB-S-5

SED-HB-S-5-063009

30-Jun-09

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

HB-S-6

SED-HB-S-6-063009

30-Jun-09

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

HB-S-7

SED-HB-S-7-063009

30-Jun-09

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

NA

Notes:

1.	'SSSSC' designates Site-specific Soil Screening Criteria

= exceeds SSSSC

2.	BOLD = detection

3.	TCL Volatile Organic Compounds, Semi-Volatile Organic Compounds and Pesticides/PCBs quantitated by Method SOM01.2.
TAL Metals quantitated by Method ILM05.3 and ILM05.4.

4.	Results are expressed in milligrams per kilogram (mg/kg).

5.	'NC' indicates screening criteria is not available.

6.	'NA' indicates the parameter was not analyzed for.

7.	'U' designates the analyte is not detected at or above the listed reporting limit.

8.	'R' designates that the reported sample result is not usable.

9.	'J' designates reported concentration is an estimated value.

10.	'NJ' designates that the analyte has been "tentatively identified"; the reported concentration is an approximate value.

11.	'UJ' designates that the analyte was not detected at or above the listed reporting limit; the limit is an approximate value.

Page 3 of 3

-------
Table 7

Summary of PCE and Breakdown Product Detections and Screening Criteria Exceedances in

Monitoring Well Ground Water Samples
White Swan Cleaners/Sun Cleaners Area Ground Water Contamination Superfund Site

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o

o
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0
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0
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o

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CN

LU

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0
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o

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-C

o
CO

LU

o

H

0
c
0
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H—i

0

o

^3
-C

0
;o

^3
.c
O

Parameter:

re

SSGWSC

o
>

70

1

1

1

Location

Sample ID

Date

MW-R-1S

MW-R-1 S-092909

29-Sep-09

1.6

0.5 U

0.5 U

0.5 U

MW-R-3S

MW-R-3S-050609

06-May-09

88 U

26,000

53 J

88 U

MW-R-3S

MW-R-3S-102709

27-Oct-09

24 U

13,000

27

24 U

MW-R-3S

MW-R-X-03-102709

27-Oct-09

31 U

14,000

24 J

31 U

MW-R-31-1

MW-R-311-110209

02-Nov-09

0.5 U

4.5

0.5 U

0.5 U

MW-R-31-1

MW-R-X-04-110209

02-Nov-09

0.5 U

4.2

0.5 U

0.5 U

MW-R-311

MW-R-311-031010

10-Mar-10

0.5 U

0.4 J

0.5 U

0.5 U

MW-R-3I

MW-R-3I-050609

06-May-09

0.5 U

6.7

0.5 U

0.5 U

MW-R-3I

MW-R-31-110309

03-Nov-09

0.5 U

5

0.5 U

0.5 U

MW-R-3D

MW-R-3D-050109

01-May-09

0.5 U

0.23 J

0.5 U

0.5 U

MW-R-4S

MW-R-4S-043009

30-Apr-09

2,100

61,000

1,200

130 J

MW-R-4S

MW-R-X-1-043009

30-Apr-09

2,100

61,000

1,100

120 J

MW-R-4S

MW-R-4S-101409

14-Oct-09

640

51,000

1,000

160 U

MW-R-4I

MW-R-4I-043009

30-Apr-09

0.5 U

0.95

0.5 U

0.5 U

MW-R-4D

MW-R-4D-043009

30-Apr-09

0.5 U

0.54

0.5 U

0.5 U

MW-R-5S

MW-R-5S-042409

24-Apr-09

110

2,300

44

9 U

MW-R-5S

MW-R-5S-102209

22-Oct-09

96

1,700

36

4.3 U

MW-R-51-1

MW-R-511-042909

29-Apr-09

530

11,000

300

49 U

MW-R-51-1

MW-R-511-102309

23-Oct-09

800

13,000

290

38 U

MW-R-5I

MW-R-5I-042909

29-Apr-09

0.36 J

8.4

0.26 J

0.5 U

MW-R-5I

MW-R-51-103009

30-0ct-09

0.27 J

12

0.5 U

0.5 U

MW-R-7S

MW-R-7S-050609

06-May-09

1.4

240

3.5

1.1 U

MW-R-7S

MW-R-7S-102109

21-Oct-09

1.2

260

2.7

0.9 U

MW-R-7I

MW-R-71-051209

12-May-09

2.1

440

3.3

1.7 U

MW-R-7I

MW-R-X-2-051209

12-May-09

1.8

410

3.2

1.7 U

MW-R-7I

MW-R-71-102209

22-Oct-09

1.9

480

3.2

1.5 U

MW-R-8S

MW-R-8S-052809

28-May-09

0.5 U

7.5

0.5 U

0.5 U

MW-R-8S

MW-R-8S-100709

07-0ct-09

0.5 U

7.7

0.5 U

0.5 U

MW-R-8I

MW-R-8I-052809

28-May-09

0.5 U

11

0.5 U

0.5 U

MW-R-8I

MW-R-X-3-052809

28-May-09

0.5 U

12

0.5 U

0.5 U

MW-R-8I

MW-R-81-100209

02-0ct-09

0.5 U

13

0.5 U

0.5 U

MW-R-9S

MW-R-9S-051309

13-May-09

0.5 U

4.3

0.5 U

0.5 U

MW-R-9S

MW-R-9S-100809

08-0ct-09

0.5 U

4.9

0.5 U

0.5 U

MW-R-9I

MW-R-91-051409

14-May-09

0.5 U

19

0.5 U

0.5 U

MW-R-9I

MW-R-91-100709

07-0ct-09

0.5 U

12

0.5 U

0.5 U

MW-R-1 OS

MW-R-10S-051809

18-May-09

2

78

1.5

0.5 U

MW-R-1 OS

MW-R-10S-101409

14-Oct-09

0.96

45

0.74

0.5 U

MW-R-101

MW-R-101-051909

19-May-09

15

910

11

3.2 U

MW-R-101

MW-R-101-101909

19-Oct-09

14

810

9.4

2.4 U

MW-R-101

MW-R-X-02-101909

19-Oct-09

14

790

9.6

2.4 U

MW-R-12S

MW-R-12S-050709

07-May-09

0.5 U

13

0.22 J

0.5 U

MW-R-12S

MW-R-12S-102009

20-0ct-09

0.5 U

11

0.5 U

0.5 U

MW-R-121

MW-R-121-051109

11-May-09

3

400

3.7

1.5 U

MW-R-121

MW-R-121-102009

20-0ct-09

4

410

4.7

1.4 U

MW-R-13S

MW-R-13S-051109

11-May-09

0.5 U

1.7

0.5 U

0.5 U

Page 1 of 2

-------
Table 7

Summary of PCE and Breakdown Product Detections and Screening Criteria Exceedances in

Monitoring Well Ground Water Samples
White Swan Cleaners/Sun Cleaners Area Ground Water Contamination Superfund Site

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o
CO

LU

o

H

0
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0
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0

o

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0
;o

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Parameter:

re

CO

o

H—1

0
H

o
f—

C
>

SSGWSC

o
>

70

1

1

1

Location

Sample ID

Date

MW-R-13S

MW-R-13S-100709

07-0ct-09

0.5 U

1.2

0.5 U

0.5 U

MW-R-131

MW-R-131-051209

12-May-09

0.5 U

33

0.27 J

0.5 U

MW-R-131

MW-R-131-100209

02-0ct-09

0.5 U

33

0.28 J

0.5 U

MW-R-131

MW-R-X-01-100209

02-0ct-09

0.5 U

33

0.27 J

0.5 U

MW-R-141

MW-R-141-051209

12-May-09

0.5 U

0.21 J

0.5 U

0.5 U

MW-R-141

MW-R-141-100109

01-Oct-09

0.5 U

0.25 J

0.5 U

0.5 U

MW-R-16S

MW-R-16S-050809

08-May-09

15

660

13

2.5 U

MW-R-16S

MW-R-16S-101309

13-Oct-09

31

1,100

22

3.5 U

MW-R-161-1

MW-R-1611-101309

13-Oct-09

3.3

210

2.2

0.9 U

MW-R-161-1

MW-R-1611-031210

12-Mar-10

2.7

96

1.5

0.5 U

MW-R-161

MW-R-161-051409

14-May-09

0.33 J

1.3

0.5 U

0.5 U

MW-R-161

MW-R-161-101909

19-Oct-09

0.29 J

0.7

0.5 U

0.5 U

MW-R-17S

MW-R-17S-102109

21-Oct-09

800

38,000

900

85 U

MW-R-17S

MW-R-17S-031110

11-Mar-10

1,100

6,400

460

82

MW-R-17S

MW-R-X-01-031110

11-Mar-10

1,100

6,300

450

79

MW-R-171-1

MW-R-1711-102209

22-Oct-09

0.74

40

1

0.5 U

MW-R-171-1

MW-R-1711-031110

11-Mar-10

3.3

8.2

0.9

0.5 U

MW-R-18S

MW-R-18S-102009

20-0ct-09

0.5 U

1.2

0.5 U

0.5 U

MW-R-211-1

MW-R-2111-101209

12-Oct-09

0.5 U

6.2

0.5 U

0.5 U

MW-R-211-1

MW-R-2111-031010

10-Mar-10

0.5 U

3.1

0.5 U

0.5 U

MW-R-211

MW-R-211-101309

13-Oct-09

0.5 U

5.1

0.5 U

0.5 U

MW-WS-1S

MW-WS-1 S-042909

29-Apr-09

0.65

230

2.7

0.5 U

MW-WS-1S

MW-WS-1 S-102909

29-Oct-09

0.3 J

17

0.5

0.5 U

MW-WS-2S

MW-WS-2S-050409

04-May-09

77

8,200

54

31 U

MW-WS-2S

MW-WS-2S-102909

29-Oct-09

31

1,700

14

4.7 U

MW-WS-3S

MW-WS-3S-050509

05-May-09

200 J

75,000

350

280 U

MW-WS-3S

MW-WS-3S-110309

03-Nov-09

140 J

62,000

260

170 U

MW-WS-3I

MW-WS-3I-050509

05-May-09

0.5 U

8

0.5 U

0.5 U

MW-WS-3I

MW-WS-31-110309

03-Nov-09

0.5 U

12

0.5 U

0.5 U

MW-WS-4S

MW-WS-4S-050109

01-May-09

25

2,000

17

7.9 U

MW-WS-4S

MW-WS-4S-103009

30-0ct-09

25

2,700

18

7.1 U

MW-WS-5S

MW-WS-5S-042909

29-Apr-09

0.5 U

2

0.5 U

0.5 U

MW-WS-5S

MW-WS-5S-103009

30-0ct-09

0.5 U

1.2

0.5 U

0.5 U

MW-WS-6S

MW-WS-6S-050409

04-May-09

1.2 J

360

1.9

1.7 U

MW-WS-6S

MW-WS-6S-102909

29-Oct-09

1.6

340

1.6

1.2 U

MW-WS-7S

MW-WS-7S-042809

28-Apr-09

0.5 U

2.1

0.5 U

0.5 U

MW-WS-7S

MW-WS-7S-110209

02-Nov-09

0.5 U

2.5

0.5 U

0.5 U

Notes:

1.	SSGWSC = Site Specific Ground Water Screening Criteria

= exceeds SSGWSC

2.	BOLD = detection

3.	TCL Volatile Organic Compounds, Semi-Volatile Organic Compounds and Pesticides/PCBs quantitated by Method SOM01.2.
TAL Metals quantitated by Method ILM05.4.

4.	Results are expressed in micrograms per liter (ug/L).

5.	'IT designates the analyte is not detected at or above the listed reporting limit.

6.	'J' designates reported concentration is an estimated value.

Page 2 of 2

-------
TABLE 8

Summary of Chemicals of Concern and
Medium-Specific Exposure Point Concentrations

Scenario Timeframe: Future
Medium:	Groundwater

Exposure Medium: Shallow/Intermediate Groundwater

Exposure Point

Chemical of Concern

Concentration
Detected

Concentration
Units

Frequency
of Detection

Exposure Point
Concentration
(EPC)

EPC
Units

Statistical Measure

Min

Max

Shallow/
Intermediate
Groundwater

Cis-l,2-dichloroethylene

0.5

2,100

^g/L

29/96

350

^g/L

99% CH UCL

Tetrachloroethylene (PCE)

0.5

61,000

^g/L

56/96

4,400

^g/L

95% HB UCL

Trichloroethylene (TCE)

0.5

1,150

^g/L

30/96

240

^g/L

99% CH UCL

Vinyl Chloride

0.5

125

^g/L

2/96

16

^g/L

97.5% CH UCL

CH UCL: Chebyshev Upper Confidence Limit
HB UCL: Hall's bootstrap Upper Confidence Limit

Summary of Chemicals of Concern and Medium-Specific Exposure Point Concentrations

This table presents the chemicals of concern (COCs) and exposure point concentrations (EPCs) for each of the COCs in groundwater. The table includes the range of
concentrations detected for each COC, as well as the frequency of detection (i.e., the number of times the chemical was detected in the samples collected at the site),

the EPC and how it was derived.

-------
TABLE 9 Selection of Exposure Scenarios

Scenario
Timeframe

Medium

Exposure
Medium

Exposure
Point

Receptor
Population

Receptor
Age

Exposure
Route

Type of
Analysis

Rationale for Selection or
Exclusion

of Exposure Pathway

Current/
Future

Soil

Subsurface
Soil

Soil

Construction
Worker

Adult

Dermal, Ingestion
and Inhalation

Quant

Potential for exposure during
excavation.

Utility Worker

Adult

Dermal, Ingestion
and Inhalation

Quant

Potential for exposure during
excavation.

Current/
Future

Soil

Surface Soil

Soil

Construction
Worker

Adult

Dermal, Ingestion
and Inhalation

Quant

Potential for exposure during
excavation.

Utility Worker

Adult

Dermal, Ingestion
and Inhalation

Quant

Potential for exposure during
excavation.

Resident/
Transient Visitor

Adult, child/Adult, teen,
older child, younger
child

Dermal, Ingestion
and Inhalation

Qual

Potential exposure considered de
minimus.

Current/
Future

Surface
Water

Surface Water

Wading: Wreck Pond, Mac

Pond, Stockton Lake
Boating, Fishing, Crabbing:
Wreck Pond

Transient Visitor

Adult, teen, older child,
younger child

Dermal, Ingestion
and Inhalation

Quant

Potential for exposure during
recreational activities.

Wading: Hannabrand Brook,
Judas Creek

Teen and older child

Dermal, Ingestion
and Inhalation

Quant

Biota: Wreck Pond

Adult, teen, older child,
younger child

Ingestion

Quant

Current/
Future

Sediment

Sediment

Wreck Pond, Mac Pond,
Stockton Lake

Transient
Visitors

Adult, teen, older child,
younger child.

Dermal, Ingestion
and Inhalation

Quant

Potential for exposure during
recreational activities.

-------
Scenario
Timeframe

Medium

Exposure
Medium

Exposure
Point

Receptor
Population

Receptor
Age

Exposure
Route

Type of
Analysis

Rationale for Selection or
Exclusion

of Exposure Pathway

Hannabrand Brook, Judas
Creek

Teen and older child

Future

Groundwater

Groundwater

Potable Water

Resident

Adult and younger child

Dermal, Ingestion
and Inhalation

Quant

Potential for exposure if untreated
water is used in the future.

Current

Groundwater

Groundwater
- Irrigation
Well

Lawn Watering
Swimming Pools

Resident

Adult and younger child

Dermal, Ingestion
and Inhalation

Quant
/Qual

Potential for exposure from using
irrigation wells.

Current

Groundwater

Soil Gas in
Subsurface
Soil (Indoor
Air)

Vapors

Commercial
Customer

Adult, teen, older child,
younger child

Inhalation

EPA
Lines of
Evidence

EPA has collected indoor air samples
within the study area. A separate
report discussing the details of the
investigation and its results will be
provided as an appendix to the
HHRA.

Resident

Adult and younger child

Future

Commercial
Worker

Adult

Construction
Worker

Adult

Current

Soil Gas in
Subsurface
Soil (Outdoor
Air)

Commercial
Customer

Adult, teen, older child,
younger child

Inhalation

Qual

PCE was not detected in ambient air
samples collected by EPA.

Resident

Adult and younger child

Future

Commercial
Worker

Adult

Construction
Worker

Adult

-------

Rationale for Selection or

Scenario

Medium

Exposure

Exposure

Receptor

Receptor

Exposure

Type of

Exclusion

Timeframe

Medium

Point

Population

Age

Route

Analysis

of Exposure Pathway

Quant = Quantitative risk analysis performed; Qual=Qualitative risk analysis performed

Summary of Selection of Exposure Pathways

The table describes the exposure pathways that were evaluated for the risk assessment, and the rationale for the inclusion of each pathway. Exposure media, exposure points, and characteristics of

receptor populations are included.

-------
TABLE 10
Non-Cancer Toxicity Data Summary

Pathway: Oral/Dermal

Chemical of Concern

Chronic/
Subchronic

Oral RfD
Value

Oral RfD
Units

Absorp.
Efficiency
(Dermal)

Adjusted
RfD

(Dermal)

Adj.
Dermal
RfD Units

Primary Target
Organ

Combined
Uncertainty

/Modifying
Factors

Sources of
RfD:

Target
Organ

Dates of
RfD:

Cis-1,2-
dichloroethylene

Chronic

2.0E-03

mg/kg-day

1

2.0E-03

mg/kg-
day

Renal toxicity

3000

IRIS

10/12/10

Tetrachloroethylene
(PCE)

Chronic

6.0E-03

mg/kg-day

1

6.0E-03

mg/kg-
day

Neurotoxicity

1000

IRIS

02/12/12

Trichloroethylene
(TCE)

Chronic

5.0E-04

mg/kg-day

1

5.0E-04

mg/kg-
day

Decreased thymus
weight; fetal

cardiac
malformation;
decreased PFC
response

1000

IRIS

09/30/11

Vinyl Chloride

Chronic

3.0E-03

mg/kg-day

1

3.0E-03

mg/kg-
day

Hepatotoxicity

30

IRIS

09/02/09

Pathway: Inhalation

Chemical of Concern

Chronic/
Subchronic

Inhalation
RfC

Inhalation
RfC Units

Inhalation
RfD

Inhalation
RfD Units

Primary Target
Organ

Combined
Uncertainty

/Modifying Factors

Sources of
RfD:

Target Organ

Dates:

Cis-1,2-
dichloroethylene

Chronic

USEPA NCEA-
STSC

04/06/10

Tetrachloroethylene
(PCE)

Chronic

4.0E-02

mg/m3

Neurotoxicity

1000

IRIS

02/12/12

Trichloroethylene
(TCE)

Chronic

2.0E-03

mg/m3

Decreased
thymus
weight; fetal

cardiac
malformation;
decreased PFC
response

1000

IRIS

09/30/11

Vinyl Chloride

Chronic

1.0E-01

mg/m3	

Hepatotoxicity

30

IRIS

09/02/09

-------
Key

IRIS: Integrated Risk Information System, U.S. EPA	CalEPA: California Environmental Protection Agency
	: No information available

Summary of Toxicity Assessment

This table provides non-carcinogenic risk information which is relevant to the contaminants of concern in all media. When available, the chronic toxicity data
have been used to develop oral reference doses (RfDs) and inhalation reference doses (RfDi).

-------

TABLE 11

Cancer Toxicity Data Summary

Pathway: Oral/Dermal

Chemical of Concern

Oral
Cancer
Slope
Factor

Units

Adjusted
Cancer Slope
Factor

(for Dermal)

Slope Factor
Units

Weight of
Evidence/

Cancer
Guideline
Description

Source

Date

Cis-l,2-dichloroethylene

D

IRIS

09/02/09

Tetrachloroethylene (PCE)

2.1E-03

(mg/kg/day)1

2.1E-03

(mg/kg/day)1

B1

IRIS

02/12/12

Trichloroethylene (TCE)

4.6E-02

(mg/kg/day)1

4.6E-02

(mg/kg/day)1

A

IRIS

09/30/11

Vinyl Chloride

7.2E-01

(mg/kg/day)1

7.2E-01

(mg/kg/day)1

A

IRIS

09/02/09

Pathway: Inhalation

Weight of

Inhalation

Evidence/

Chemical of Concern

Unit Risk

Units

Slope Factor

Slope Factor
Units

Cancer
Guideline
Description

Source

Date

Cis-l,2-dichloroethylene

D

IRIS

09/02/09

Tetrachloroethylene (PCE)

2.6E-07

(Hg/m3)1

2.6E-07

(Hg/m3)1

B1

IRIS

09/30/11

Trichloroethylene (TCE)

4.1E-06

(Hg/m3)1

4.1E-06

(Hg/m3)1

A

IRIS

02/12/12

Vinyl Chloride

4.4E-06

(Hg/m3)1

4.4E-06

(Hg/m3)1

A

IRIS

02/04/10

Key:

EPA Weight of Evidence:

IRIS: Integrated Risk Information System. U.S. EPA

A - Known human carcinogen

	: No information available

B1 - Probable human carcinogen
D - Not classifiable as a human carcinogen

Summary of Toxicity Assessment

This table provides carcinogenic risk information which is relevant to the contaminants of concern in all media. Toxicity data are

provided

for both the oral and inhalation routes of exposure.

-------
TABLE 12

Risk Characterization Summary - Noncarcinogens

Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Adult

Medium

Exposure
Medium

Exposure
Point

Chemical of Concern

Primary Target
Organ

Non-Carcinogenic Hazard

Ingestion

Dermal

Inhalation

Exposure
Routes
Total

Shallow
Groundwater

Drinking
Water

Drinking
Water
Tap/Shower

Cis-l,2-dichloroethylene

Kidney

4.7

0.19

4.9

Tetrachloroethylene (PCE)

Nervous System

20

3.4

57

80

Trichloroethylene (TCE)

Immune
System/Cardiac

13

0.81

66

80

Vinyl Chloride

Liver

0.15

0.0044

0.024

0.18

Hazard lndexTotal*=

168

Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Child

Medium

Exposure
Medium

Exposure
Point

Chemical of Concern

Primary Target
Organ

Non-Carcinogenic Hazard

Ingestion

Dermal

Inhalation

Exposure
Routes
Total

Shallow
Groundwater

Drinking
Water

Drinking
Water
Tap/Shower

Cis-l,2-dichloroethylene

Kidney

11

0.56

12

Tetrachloroethylene (PCE)

Nervous System

46

10

235

291

Trichloroethylene (TCE)

Immune
System/Cardiac

30

2.4

254

287

Vinyl Chloride

Liver

0.35

0.013

0.35

0.72

Hazard lndexTotal*=

597

-------
	not available at this time due to no reference dose being available - non-cancer hazards are underestimated

*Hazard Index Total also includes non-site related compounds, which are not shown, therefore the exposure routes total and hazard index total may not be the
same.

Summary of Risk Characterization - Non-Carcinogens

The table presents hazard quotients (HQs) and subsequent Haazrd Index (HI) for each route of exposure and the hazard index (sum of hazard quotients) for

exposure to groundwater. The hazard quotients from exposure to soil, surface water and sediment were below a hazard index of 1 for all site-related
compounds. The Risk Assessment Guidance for Superfund states that, generally, an HI greater than 1 indicates the potential for adverse non-cancer effects.

-------
TABLE 13

Risk Characterization Summary - Carcinogens

Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Adult

Medium

Exposure
Medium

Exposure
Point

Chemical of Concern

Carcinogenic Risk

Ingestion

Dermal

Inhalation

Exposure
Routes Total

Shallow
Groundwater

Drinking Water

Drinking
Water
Tap/Shower

Cis-l,2-dichloroethylene

Tetrachloroethylene (PCE)

9E-05

1E-05

6E-04

7E-04

Trichloroethylene (TCE)

1E-04

6E-06

5E-04

7E-04

Vinyl Chloride

1E-04

3E-06

1E-05

1E-04

Total Risk =

2E-03

Scenario Timeframe: Future
Receptor Population: Resident
Receptor Age: Child

Medium

Exposure
Medium

Exposure
Point

Chemical of Concern

Carcinogenic Risk

Ingestion

Dermal

Inhalation

Exposure
Routes Total

Shallow
Groundwater

Drinking Water

Drinking
Water
Tap/Shower

Cis-l,2-dichloroethylene

Tetrachloroethylene (PCE)

5E-05

1E-05

2E-03

3E-03

Trichloroethylene (TCE)

6E-05

5E-06

2E-03

2E-03

Vinyl Chloride

6E-05

2E-06

2E-04

2E-04

Total Risk =

5E-03

Summary of Risk Characterization - Carcinogens

The table presents cancer risks for groundwater exposure. Cancer risk from exposure to soil, surface water and sediment were below or within the
acceptable risk range. As stated in the National Contingency Plan, the point of departure is 1CT6 and the acceptable risk range for site-related
exposure is 10"6to 10"4.

-------
Table 14

Potential ARARs and To Be Considered (TBC) Criteria
White Swan Cleaners/Sun Cleaners Area Ground Water Contamination Superfund Site

POTENTIAL CHEMICAL-SPECIFIC ARARS OR TBC CRITERIA

REGULATOR

CRITERION

CITATION

DESCRIPTION

COMMENTS

NJ Statutes and
Rules

Brownfield and Contaminated
Site Remediation

NJSA

58:10B-2, 12.

Provides specific numeric remediation criteria for contaminants
in soil and groundwater

Soil Remediation Standards
(SRS)

NJAC 7:26D

Establishes direct-contact standards for soils; acts as primary
basis for setting numerical criteria for soil cleanups for ingestion
and dermal contact

SRS for inhalation pathway are not an
ARAR (USEPA letter, May 12, 2010).

Groundwater Quality
Standards

NJAC 7:9C

Establishes standards for the protection of ambient groundwater
quality; primary basis for setting numerical criteria for
groundwater cleanups (e.g., PCE=1 ppb); establishes
mechanism for Classification Exception Area (CEA)

Includes standards for groundwater
under the Pinelands Protection Act,
NJSA 13:18A-1 et seq.

Surface Water Quality
Standards

NJAC 7:9B

Establishes standards for the protection and enhancement of
surface water resources (e.g., PCE=0.34 ppb in fresh water, 1.6
ppb in saline water)

Potentially applicable where ground
water discharges to surface water

NJ Statutes and
Rules

Safe Drinking Water Act
(SDWA)

NJAC 7:10

Establishes allowable levels of contaminants in public drinking
water

Primary Maximum
Contaminant Levels (MCLs)

Establishes MCLs that are generally equal to or more stringent
than the Federal Safe Drinking Water Act MCLs (e.g., PCE = 1
ppb)

Secondary MCLs

Establishes standards for public drinking water systems for those
contaminants which impact the aesthetic qualities of drinking
water

N/A: Contaminants Of Potential Concern
(COPCs) not addressed

Federal Acts and
Regulations

SDWA Primary/Secondary
MCLs

40 CFR 140,
143

Establishes allowable levels of contaminants in public drinking
water

These standards are less stringent than
applicable state standards

SDWA MCL Goals (MCLGs)

40 CFR 141

The level of a contaminant in drinking water below which there is
no known or expected risk to health

TBC as non-enforceable public health
goals

Federal Acts and
Regulations

Resource Conservation and
Recovery Act (RCRA)

40 CFR 264

Establishes procedures for hazardous waste (HW) treatment,
storage, and disposal facilities

Potentially applicable if HW is managed
during remediation

Page 1 of 5

-------
Table 14

Potential ARARs and To Be Considered (TBC) Criteria
White Swan Cleaners/Sun Cleaners Area Ground Water Contamination Superfund Site

POTENTIAL LOCATION-SPECIFIC ARARS OR TBC CRITERIA

REGULATOR

CRITERION

CITATION

DESCRIPTION

COMMENTS

NJ Statutes and
Rules

Flood Hazard Control Act

NJAC 7:13

Floodplain Use and Limitations which establishes limits on land
development within flood hazard areas

Portions of Hannabrand Brook and areas
adjoining Wreck Pond & Stockton Lake
lie within the 100-year floodplain (see Fig
7 from SLERA)

NJ Statutes and
Rules

Waterfront Development
Law

NJSA 12:5-3

Regulates the construction or alteration of a dock, wharf, pier,
bulkhead, bridge, pipeline, cable or other similar development on
or adjacent to tidal waterways

Potentially applicable for construction
activities performed in the vicinity of
Wreck Pond, Stockton Lake, or other
tidal areas

NJ Statutes and
Rules

Wetland Act of 1970

NJSA 13:9A-1
et seq

Requires permits for regulated activity disturbing coastal
wetlands

Potentially applicable for construction
activities performed in the vicinity of a
coastal wetland

NJ Statutes and
Rules

Freshwater Wetlands
Protection Act

NJSA 13:9B-1
et seq

Requires permits for regulated activity disturbing freshwater
wetlands

Potentially applicable for construction
activities performed in the vicinity of a
freshwater wetland

NJ Statutes and
Rules

Coastal Area Facility Review
Act (CAFRA)

NJSA 13:19-1
et seq

Regulates activities within the CAFRA area including
construction, relocation, and enlargement of buildings and
associated work such as excavation

Potentially applicable for construction
activities performed east of Route 71
(see Fig 6 from SLERA)

NJ Statutes and
Rules

Endangered Plant Species
List Act

NJSA 13:1 B et
seq.

Establishes the requirement to protection threatened and
endangered plant species in New Jersey by developing and
adopting a list

Not applicable - no threatened or
endangered plant species were observed
on or near the Site

NJ Statutes and
Rules

Endangered and Non-Game
Species Conservation Act

NJSA 23:2A-1

Standards for the protection of Federal and NJ threatened and
endangered species

Potentially applicable for construction
activities performed in beach areas
having suitable habitat for least
tern/piping plover and possibly, the
northeastern beach tiger beetle

NJ Statutes and
Rules

Stream Encroachment
Permit

N.J.S.A.
58:16A-50 et
seq.; N.J.A.C.
7:8-3.15

Construction of structures and placement of fill within flood
hazard areas including floodplains and floodways

Potentially applicable for construction
activities performed in floodplains and
floodways (e.g., treatment facilities)

Page 2 of 5

-------
Table 14

Potential ARARs and To Be Considered (TBC) Criteria
White Swan Cleaners/Sun Cleaners Area Ground Water Contamination Superfund Site

POTENTIAL LOCATION-SPECIFIC ARARS OR TBC CRITERIA

REGULATOR

CRITERION

CITATION

DESCRIPTION

COMMENTS

Federal Acts and
Regulations

National Environmental Policy
Act (NEPA)

40CFR6,
Appendix A

Statement of Procedures on Floodplain Management and
Wetlands Protection. Establishes policy and guidance to avoid
the occupancy and modification of floodplains, or the destruction
or modification of wetlands

Potentially applicable for construction
activities performed in areas of wetlands
associated with Judas Creek and/or
Hannabrand Brook

Federal Acts and
Regulations

Coastal Zone Management
Act

16 USC 1451

Protection and management of coast zone from land uses within
the coastal zone

Potentially applicable for construction
activities performed which may impact
the coastal zone

Federal Acts and
Regulations

Endangered Species Act

40 CFR 400
50 CFR 17,
81, 223, 224,
226, 402

Standards for the protection of threatened and endangered
species (wildlife, marine and anadromous species and plants)
and establish cooperation with the Federal and State
Governments

Potentially applicable for construction
activities performed in beach areas
having suitable habitat for least
tern/piping plover and possibly the
northeastern beach tiger beetle

Federal Acts and
Regulations

Fish and Wildlife
Conservation Act

16 USC 2901
et seq.

Established EPA policy and guidance for promoting the
conservation of non-game fish and wildlife and their habitats

Potentially applicable for construction
activities performed which may impact
non- game fish and wildlife and their
habitats

Federal Acts and
Regulations

Protection of Migratory Game
& Insectivorous Birds

16 USC 703

Preservation of migratory birds and habitat

Potentially applicable for any area with
nesting migratory birds

Federal Acts and
Regulations

National Historic Preservation
Act

16 USC 469
et seq.; 40
CFR 6301

Establishes procedures to provide for preservation of historical
and archaeological data that might be destroyed through
alteration of terrain as a result of a Federally licensed activity or
program

Stage IA (White Swan) and IB (Sun)
surveys indicated low potential for
archaeological remains

Page 3 of 5

-------
Table 14

Potential ARARs and To Be Considered (TBC) Criteria
White Swan Cleaners/Sun Cleaners Area Ground Water Contamination Superfund Site

POTENTIAL ACTION-SPECIFIC ARARS OR TBC CRITERIA

REGULATOR

CRITERION

CITATION

DESCRIPTION

COMMENTS

NJ Statutes and
Rules

Well Construction and
Maintenance

NJAC 7:9D

Establishes requirements for construction and decommission
(sealing) of wells, and well driller / pump installer licensing

Applicable if wells are constructed or
decommissioned

NJ Statutes and
Rules

New Jersey Soil Erosion and
Sediment Control Act

NJSA 4:24-39
et seq

To establish soil erosion and sediment control standards for
Department of Transportation certification of its projects to the
Soil Conservation Districts

Potentially applicable for construction
disturbing surface soil or sediment

NJ Statutes and
Rules

New Jersey Air Pollution
Control Act

NJAC 7:27-8,
16

Establishes standards for discharge of pollutants to air

Potentially applicable for air emission
streams from treatment options

NJ Statutes and
Rules

Pollutant Discharge
Elimination System

NJAC 7:14A

Establishes standards for discharge of pollutants to surface and
ground waters

Potentially applicable if wastewater is
discharged to surface or ground water

NJ Statutes and
Rules

Technical Requirements for
Site Remediation (TRSR)
and Administrative
Requirements for the
Remediation of Contaminated
Sites (ARRCS)

NJAC 7:26E-
8

Identifies requirements for institutional controls for contaminated
soils left in place, and for contaminated groundwater; identifies
administrative requirements for site remediation that may be
applicable

Potentially applicable if chemical
residuals in soils left in place are above
the industrial SRS; potentially applicable
to CEA and MNA implementation

NJ Statutes and
Rules

Noise Control

NJAC 7:29

Establishes allowable noise levels

Potentially applicable in residential areas

Federal Acts and
Regulations

SDWA

40 CFR 144-
147

Underground injection control regulations that provide for the
protection of underground sources of drinking water

Potentially applicable if water is re-
injected following treatment

Federal Acts and
Regulations

Clean Water Act (CWA)

33 USC 1251
et seq.

Procedures to preserve surface water quality by reducing direct
pollutant discharges into waterways, finance municipal
wastewater treatment facilities and manage polluted runoff

National Pollution Discharge
Elimination System (NPDES)

40 CFR 122-
125

Establishes requirements for discharges associated with
industrial activity, to water bodies or wetlands

Water quality standards and best
management practices apply, and a
discharge permit is required

Ambient Water Quality
Criteria (AWQC)

40CFR131,
401

Provides criteria developed for the protection of freshwater and
marine aquatic life and for the protection of human health from
the ingestion of water and/or organisms

Potentially applicable if water is
discharged to surface water

General Pretreatment
Regulations for Existing and
New Sources of Pollution

40 CFR 403

Prohibits discharge of pollutants to a Publically Operated
Treatment Works (POTW) which cause or may cause pass-
through or interference with operation of the POTW

Potentially applicable if water is
discharged to a POTW

Page 4 of 5

-------
Table 14

Potential ARARs and To Be Considered (TBC) Criteria
White Swan Cleaners/Sun Cleaners Area Ground Water Contamination Superfund Site

POTENTIAL ACTION-SPECIFIC ARARS OR TBC CRITERIA

REGULATOR

CRITERION

CITATION

DESCRIPTION

COMMENTS

Federal Acts and
Regulations

Fish and Wildlife
Coordination Act

16 USC 661-
666

Requires consultation when a federal department or agency
proposes or authorizes any modification of any stream or other
water body and adequate provision for protection offish and
wildlife resources

Potentially applicable if water is
discharged to surface water.

Federal Acts and
Regulations

Toxic Pollutant Effluent
Standards

40 CFR 129

Establishes effluent standards or prohibitions for certain toxic
pollutants such as pesticides and PCBs

N/A: Pollutants regulated not identified as
COPCs

Federal Acts and
Regulations

RCRA

42 USC 6901
et seq.; 40
CFR 260-270

Establishes responsibilities and standards for the management
of hazardous and non-hazardous waste

Potentially applicable to solid waste
streams from treatment options

Federal Acts and
Regulations

Hazardous Materials
Transportation Act (HMTA)

49 USC 1801-
1813; 49 CFR
107, 171-177

Regulates transportation of hazardous materials in commerce

Potentially applicable for transportation of
treatment waste streams

Federal Acts and
Regulations

Clean Air Act (CAA)

42 USC 7401

Establishes requirements to preserve air quality and to reduce
air pollution

National Ambient Air Quality
Standards (NAAQs)

40 CFR 50

Establishes primary and secondary standards for six pollutants
to protect the public health and welfare

Potentially applicable to air emission
streams from treatment options

National Emission Standards
for Hazardous Air Pollutants
(NESHAPs)

40 CFR 63

Establishes regulations for specific air pollutants (such as
benzene and PCE)

Potentially applicable to air emission
streams from treatment options

Federal Acts and
Regulations

Occupational Safety and
Health Act (OSHA)

29 USC 651-
678; 29 CFR
1910, 1926

Regulates worker health and safety by establishing permissible
exposure levels (PELs)

Applicable to remedy construction and
operation

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APPENDIX III
RESPONSIVENESS SUMMARY

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APPENDIX III

RESPONSIVENESS SUMMARY
White Swan Cleaners/Sun Cleaners Area Groundwater Contamination Superfund Site
Wall Township, Manasquan Borough, Sea Girt Borough
Monmouth County, New Jersey

INTRODUCTION

This Responsiveness Summary provides a summary of the public's comments and concerns
regarding the Proposed Plan for the White/Swan Cleaners/Sun Cleaners Area Groundwater
Contamination Superfund Site's (Site) preferred remedy, and EPA's response to those
comments. All comments summarized in this document have been considered in EPA's final
decision for the selection of remedial alternatives for the Site.

This Responsiveness Summary is divided into the following sections:

I.	BACKGROUND OF COMMUNITY INVOLVEMENT AND CONCERNS:

This section provides the history of community involvement and interests
regarding the Site.

II.	COMPREHENSIVE SUMMARY OF MAJOR QUESTIONS, COMMENTS,
CONCERNS AND RESPONSES: This section contains summaries of oral
comments received by EPA at the public meeting, EPA's responses to these
comments, as well as responses to written comments received during the public
comment period.

The last section of the Responsiveness Summary includes attachments, which document public
participation in the remedy selection process for this Site. They are as follows:

Attachment A contains the Proposed Plan that was distributed to the public for review

and comment;

Attachment B contains the public notices that appeared in the Asbury Park Press and the

Coast Star;

Attachment C contains the transcript of the public meeting; and

Attachment D contains the written comments received by EPA during the public

comments period.

I BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS

On August 20, 2013, EPA released the Proposed Plan and supporting documentation for the
groundwater remedy to the public for comment. EPA made these documents available to the

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public in the administrative record repositories maintained at EPA Region 2 office (290
Broadway, New York, New York) and at the Wall Township Public Library (2700 Allaire Road,
Wall, New Jersey). EPA published notices of availability of these documents in the Asbury Park
Press and the Coast Star newspapers on August 20 and 22, respectively. EPA opened a public
comment period which ran from August 20, 2013 through September 19, 2013. On August 27,
2013, EPA held a public meeting at the Wall Township Municipal Center to inform local
officials and interested residents about the Superfund process, to present the preferred remedial
alternative for the Site, solicit oral comments, and respond to any questions.

II COMPREHENSIVE SUMMARY OF MAJOR QUESTIONS. COMMENTS.
CONCERNS AND RESPONSES

PART 1: Verbal Comments

This section summarizes commens received from the public during the public comment priod,
along with EPA's responses.

A. SUMMARY OF QUESTIONS AND EPA'S RESPONSES FROM THE PUBLIC
MEETING CONCERNING THE WHITE SWAN CLEANRES/SUN CLEANERS
AREA GROUNDWATER CONTAMINATION SITE - AUGUST 27, 2013

A public meeting was held on August 27, 2013 at 7:00 p.m. in the Wall Township Municipal
Center, Wall Township, New Jersey. In addition to a brief presentation of the investigation
findings, EPA presented the Proposed Plan and preferred alternatives for the Site, received
comments from meeting participants, and responded to questions regarding the remedial
alternatives under consideration. Attachment C includes the entire transcript of the public
meeting.

A summary of comments raised by the public following EPA's presentation is presented below:
Communication

1.	Why wasn't the Proposed Plan provided to the community earlier?

EPA response: Upon completion of the remedial investigation, the Proposed Plan was
completed and immediately released to the public at the start of the public comment period
on August 20. A public notice was published in two newspapers and the Proposed Plan was
available on EPA's website. In addition, postcards announcing the public comment period
and availability of the Proposed Plan were sent to everyone on EPA's mailing list.

2.	A commenter requested to be included on the mailing list.

EPA response: Individuals who provide their contact information will be included in future
mailings regarding the Site.

3.	Is EPA's presentation on EPA's website?

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EPA response: Yes.

4.	Describe the actions taken to notify and receive input from the local governments of Wall
Township, Sea Girt and Manasquan.

EPA response: EPA briefed representatives of all three municipalities about the Proposed
Plan prior to the public meeting. Monmouth County Health Department officials were also
briefed. EPA was contacted by Congressman Smith's office and provided his office with a
briefing at their request.

Technical Comments

5.	Soil Alternative 3 provides for the remediation of soil in 1 year, while Alternatives 2 and
4 can take up to ten years. A number of members of the community voiced that they
would prefer Alternative 3, which includes excavation of soils at both source areas as
compared to the preferred soil alternative, Alternative 4, which provides for excavation
at the White Swan property in approximately a year and cleanup of the Sun Cleaners
property through the use of SVE, which may take up to 10 years. This was based on a
number of concerns, including public health and real estate values. A number of
commenters indicated that the additional cost was justified.

EPA response: EPA evaluates all alternatives based on the nine evaluation criteria and
selects the alternative that represents the best overall alternative. Cost is considered, but only
as one of nine criteria. For the soils remediation, different technologies are being proposed
for the different source areas based on differences in the physical characteristics of the two
properties, including the topography and location, and also on the distribution of
contaminants. Excavation at the Sun Cleaners source area presents a number of
implementability concerns such as difficulty in performing excavation due to a steep slope on
the west side of the property and its location on a highway traffic circle. Further, there are
significantly lower concentrations and mass of PCE located in Sun Cleaners soils as
compared to soils at the White Swan source area. All of these factors were considered by
EPA in proposing soil Alternative 4. In addition, EPA believes that most of the soil
contamination at the Sun Cleaners property will likely be remediated in less than 10 years
through the ISVE/AS technology.

6.	Was the contractor who performed the work chosen by the federal government? Was a
New Jersey Licensed Site Remediation Professional (LSRP) involved?

EPA response: No, the contractor who performed the remedial investigation and feasibility
study was chosen by Bank of America, the potentially responsible party for the Site. EPA
also selected a contractor who oversaw all of the work. A Superfund site does not require an
LSRP's involvement in cleanup activities.

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7.	Why were no innovative technologies considered for this project? Specifically, were
reductive dechorinization or injectable slurry of a reductive compound considered?

There are products that are available that can be injected that will reduce the chlorinated
solvents within months. Why is injection of agents to the aquifer considered too difficult,
but vapor extraction is not?

EPA response: Fifteen to twenty technologies were initially considered and are discussed in
the feasibility study report. Distribution of any agent to the aquifer would be challenging and
very disruptive in this densely developed community. Soil vapor extraction with air sparging
was also not selected for groundwater in part for the same reasons.

8.	Have there been any investigations of another dry cleaners located in Manasquan?

EPA response: Yes, the remedial investigation included identifying other sources of Site
contamination.

9.	Has the dry cleaners located near Foodtown that backs up to Judas Creek been tested?

EPA response: Yes, that facility and other facilities were investigated as potential sources
during the remedial investigation. That facility was determined to not be a contributing
source of Site contamination.

10.	A resident expressed concern about the extent of groundwater contamination and its
proximity to her home and requested clarification as to where the groundwater
contamination is located.

EPA response: The commenter was shown the extent of groundwater contamination relative
to her home on a large map.

11.	A commenter whose property is near two piezometers expressed concern about the water
quality and property value and asked how many wells are around the Site.

EPA response: The piezometers in the right of way near your property are needed to
evaluate water levels of the aquifer throughout the implementation of the remedy. There are
approximately 70 groundwater monitoring wells and 15 piezometers installed at the Site.

12.	A commenter asked how often the monitoring wells and piezometers are tested.

EPA response: EPA tested the Site well network three times during the remedial
investigation between 2007 and 2010. The wells in question were not recently sampled;
however, the contractor has recently performed a survey of all wells to determine if any were
damaged by Superstorm Sandy last fall. The results of that survey indicate no significant
damage. All wells will all be sampled periodically for water levels and chemical constituents
throughout the life of the project, until the groundwater is fully remediated. Although
piezometers or wells at the Site may be located just outside the extent of groundwater

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contamination, they are necessary and will provide EPA with important aquifer water level
information over time needed to assess progress during the cleanup process.

13.	Can the map EPA is displaying at the meeting, which is an aerial photograph of the area
which outlines the area of groundwater contamination, be sent to the attendees of this
meeting?

EPA response: That map is included in the administrative record for the Site which is
available to the public at the Wall Township Library, and at EPA's offices in New York.
Also, on EPA's website, there is a link to the Proposed Plan which includes that map, as well
as the PowerPoint presentation provided at the public meeting with all of the maps, and the
entire remedial investigation and feasibility study reports. Also, a copy of the administrative
record on disk may be requested from EPA's Records Center in New York.

14.	A resident expressed concern about potential flooding impacts along Judas Creek
resulting from the proposed groundwater treatment plant discharge and opposed the
discharge to Judas Creek as it would exacerbate flooding. A description of the discharge
of water to Judas Creek was requested.

EPA response: EPA has three options for the discharge of treated groundwater under the
pereferred alternative, groundwater extraction and treatment. Treated groundwater can be: 1)
discharged to surface water (Judas Creek or another surface water body); 2) reinjected to the
aquifer; or 3) sent to a publically owned treatment works. These options will be further
evaluated in the remedial design phase and a determination will be made then as to what is
the best option. EPA does not intend to exacerbate local flooding conditions by
implementing the remedy.

15.	A commenter asked if public input on the treated groundwater discharge option will be
accepted during remedial design of the remedy, as flooding issues are of concern if the
surface water discharge option were selected.

EPA response: EPA will make the design documents public, and will contact state and local
officials to evaluate flooding issues and assure compliance with all local state and federal
wetlands and floodplain requirements.

16.	A resident asked if an application would be required to determine the quantity of effluent
allowed if EPA were to discharge treated groundwater to Judas Creek. The resident
further asked EPA to specify the timing of such an application, and if permit applications
are available to the public.

EPA response: Yes. Depending on the location of the proposed discharge, EPA would be
required to obtain a NJDEP surface water discharge permit equivalency. The review time

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within NJDEP can vary, but generally complete permit applications are reviewed within
approximately 90 days. NJDEP makes permit applications available to the public.

17.	A resident asked if EPA would permit an expansion of the flood boundary.

EPA response: The Superfund program does not set flood boundaries and the project
would comply with existing boundaries.

18.	What is the estimated amount of water that could be discharged to Judas Creek under the
proposed alternative?

EPA response: The preliminary estimate of water to be treated and discharged by the
proposed groundwater treatment plant is between 70 and 200 gallons per minute.

19.	A resident asked for clarification regarding some maps displayed at the meeting, the time
frames that the maps were prepared, as well as future investigations.

EPA response: The remedial investigation sampling took place from 2007 to 2010. After
which the remedial investigation and feasibility study reports were developed, reviewed and
finalized. Earlier investigations were performed at the Site, prior to its listing on the NPL, by
Monmouth County and the State of New Jersey. After a remedy is selected, a remedial
design will be performed which will include additional sampling and possibly pilot studies.

20.	A resident asked for an explanation of why some data are reported in units of parts per
billion and some data are presented in units of parts per million.

EPA response: Soil contamination is often measured in units of parts per million and
groundwater contamination is often measured in units of parts per billion.

21.	A commenter asked if consideration was given to actively remediating the groundwater
in the Far Field of the Site, given the potential that it will take 50 to 70 years to restore
this groundwater.

EPA response: Yes. Active remediation in the Far Field area was considered during the
development of the Feasibility Study. It was eliminated from consideration based on a
number of factors including implementability, cost, and short-term and long-term impacts to
the community. Furthermore, it did not significantly shorten the overall time estimated to
restore the aquifer.

22.	A commenter asked if in-situ technologies, including six-phase heating, were considered,
and if so, why this technology was ruled out. Furthermore, the commenter wanted to
know if in-situ technologies were ruled out only based on cost.

EPA response: The feasibility study identified a wide range of technologies. All
technologies that were initially considered are presented in the appendices to the Feasibility

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Study Report, as well as why some of them were ruled out. The resistive heating technology
mentioned can be effective, but is very expensive. It is generally most effectively
implemented over a small area containing high levels of contamination. There are equally
effective technologies that were retained and are more cost-effective. Technologies are not
screened out solely based on costs.

23.	At the Sun property, the reports indicated that an underground storage tank was located
on the property, but was not encountered. Considering the plan to leave soils in place,
one commenter requested assurances that there are no underground tanks that contain
contamination. In addition, the commenter asked if the site was fully investigated for
underground tanks through excavation and ground-penetrating radar.

EPA response: EPA thoroughly investigated the Sun property by digging with a backhoe to
the water table in targeted areas, based on geophysical investigations, and no underground
tanks were encountered.

Cost

24.	A commenter asked if EPA's cost estimate for the groundwater pump and treat
alternative assumes that surface water discharge would be the discharge option.
Furthermore, the commenter asked if costs would increase if another option were used
and if EPA could estimate a range of costs that may be required.

EPA response: For cost-estimating purposes, surface discharge to Judas Creek was
assumed. The cost would change if another option were used. There are many aspects of the
remedy that will be determined in the remedial design phase, which may cause the costs of
implementing the remedy to change. The cost estimates developed for the alternatives
presented in the Feasibility Study are preliminary and considered sufficiently adequate for
cost comparison and remedy selection purposes. The cost of the remedy will be revised
during the remedial design.

25.	A commenter asked if surface water discharge of treated groundwater was a factor used
in developing the cost estimate for groundwater Alternative 4, and if so, was this based
on cost.

EPA response: There has not been a final determination regarding the disposition of treated
groundwater and there are several options that will be further developed and evaluated in the
remedial design phase if this alternative is selected. The surface water discharge option was
used only for cost-estimating purposes in the feasibility study, based on the determination
that this option may be the easiest to implement compared to other options. It has yet to be
determined which is the most appropriate option for treated groundwater.

Enforcement

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26.	A commenter asked if this Superfund project was publically funded, or funded by a
responsible party.

EPA Response: To date, the remedial investigation and feasibility study have been privately
funded by a potentially responsible party. The potentially responsible party has also
reimbursed EPA for costs it has incurred in overseeing the investigation.

27.	A resident asked who was the party responsible for Sun Cleaners, and who currently
owns the former Sun Cleaners property.

EPA response: Sun Cleaners was a small family business and the former owners are now
deceased and left no appreciable assets. The property is currently privately owned.

28.	A resident asked if EPA would put a lien on the Sun Cleaners property?

EPA response: After the selection of the remedy for the Site, EPA will enter into
enforcement negations with all identified potentially responsible parties. EPA will consider
all appropriate enforcement tools.

29.	A commenter asked if towns within the Site will have to bear the costs associated with
the cleanup.

EPA response: At this time, none of the towns are considered to be potentially responsible
parties, so they are not expected to bear cleanup costs.

Local Schools

30.	A resident indicated that there is an ongoing project at Manasquan High School in the
area of the Site that includes the building of a retaining wall and construction of drainage
channels.

EPA response: EPA will inquire as to this effort and other relevant local projects during the
design of the selected remedy.

31.	A resident wanted to know if the Manasquan School District was contacted about EPA's
public meeting.

EPA response: Local school officials were not individually notified of the meeting, but the
meeting was widely advertised. Further, EPA has reached out to local officials from all
three towns impacted by the Site, Wall Township, Sea Girt, and Manasquan, to brief them on
the project prior to the meeting. In addition, because indoor air sampling has been performed
at Manasquan High School and other schools as part of the Site investigations, school
officials are aware of the Superfund project. School districts located in the area of the Site
will be put on the mailing list for future mailing. Please note that schools within the plume

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area have been included in EPA's indoor air sampling program, and indoor air levels were
below levels of concern.

32.	A resident indicated that schools located outside, but near the Site should also be notified
about Site meetings as the limits of groundwater contamination may spread over time.

EPA response: The extent of the groundwater contamination will be monitored over time as
part of Site cleanup. School districts impacted by the Site groundwater contamination will be
notified to discuss future indoor air sampling in schools.

33.	A resident indicated that the creek next to Old Mill School floods and asked if there were
risk factors associated with that flooding.

EPA response: The Old Mill School is not within the area of Site contamination.

Use of Local Irrigation Wells

34.	A resident asked if any risks are posed by Site contamination to residents who grow
vegetables on their property.

EPA response: No. There is not a problem with harvesting fruit or vegetables on private
property in the vicinity of the Site. The contaminated groundwater associated with the Site is
located twelve to sixty feet below the ground surface, so it is not reaching the surface soil
that residents would use to grow produce. The only contaminated soils of concern are
located on the two former dry cleaners' properties. Furthermore, the contaminants of
concern at this Site are volatile organic compounds, which are not taken up by plant systems.

35.	A resident who had attended a meeting in Sea Girt in 2002, indicated that at that meeting,
residents were instructed by the Monmouth County Health Department to not use water
from their irrigation wells to fill their swimming pools or water their gardens. The
resident asked what changes have happened at the Site since that time that now indicate
that these uses of groundwater are no longer posing a risk.

EPA response: EPA did not provide such a direction to the public. The Agency for Toxic
Substances and Disease Control (ATSDR) performed a Health Evaluation in 1999, 2002 and
2004. They evaluated incidental ingestion of VOCs in irrigation well water during outdoor
use (e.g., irrigation, gardening, swimming pools), and determined that PCE concentrations
posed no public health concern, provided that the well water was used only for nonpotable
purposes. Additional environmental data became available since the initial assessment and
ATSDR modified their recommendation to say that residents with homes overlying the most
elevated levels of groundwater contamination should have children wait approximately one
week before swimming in a pool filled with irrigation well water to give the PCE time to
volatilize out of the water. ATSDR also indicated that home-grown vegetables would not

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incorporate PCE from irrigation well water, thus there is no elevated exposure concerns due
to ingestion of irrigated produce.

As part of remedial investigation activities, EPA recently performed a risk assessment, which
indicated that risks posed by periodic exposure to contaminated groundwater from irrigation
wells used for watering lawns and filling swimming pools in the vicinity of the Site were
within EPA's acceptable risk range. Copies of these documents are available in the Wall
Township public library and directly through EPA.

36.	A commenter expressed concern about residents that are using the aquifer to water their
lawns and water produce.

EPA response: Please see EPA's response to the previous comment.

37.	A commenter inquired whether a local plant nursery in the area of the plume perpetuates
the groundwater contamination problem by pumping their irrigation well.

EPA response: There are at least two local nurseries extracting groundwater and using it to
water their stock within the area of the Site's groundwater contaminant plume. There are
also numerous private irrigation wells which draw from the contaminant plume.

Groundwater extracted from these private wells within the plume can have a localized impact
on contaminant distribution.

38.	A resident inquired if a recently installed irrigation well is a concern.

EPA response: According the the ATSDR evaluation and the EPA risk assessment; use of
irrigation wells on private property within the plume does not pose unacceptable risks under
the exposure scenarios developed for those wells.

39.	A commenter asked if there have been any surveys of the number of irrigation wells
located within the plume, and if not, how would the types of uses of these wells be
determined.

EPA response: While EPA and other entities have sampled some irrigation wells, EPA did
not perform such a survey and is not aware of one. However, the State of New Jersey
permits wells and may be able to provide this information. As for the specific uses of each
well, the ATSDR analyzed that and made a number of use assumptions that were used in a
model to develop health risks posed by the exposures.

40.	Regarding the approximately 100 shallow private irrigation wells contaminated at the
Site, a commenter wanted to know what EPA's plans were to inspect, monitor, upgrade
or close these wells to prevent further cross contamination prior to and during
remediation activities. The commenter was concerned that a number of these wells may

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be old and could be transmitting surface water down to lower aquifers, and requested that
these wells be evaluated to assure they are not working against the remedy.

EPA response: To the best of EPA's knowledge, the irrigation wells are 50 feet deep or
shallower. The bottom of the contamination within the aquifer at the Site is about 75 feet
beneath the surface. Therefore, it is unlikely that the irrigation wells could be conduits for
contamination to move to lower zones of the aquifer. However, during the cleanup at the
Site, groundwater within the entire extent of the contaminant plume will be sampled and any
results showing localized areas of concern will be addressed.

41.	A commenter wanted to know if there is a moratorium on future shallow groundwater
wells in the plume area.

EPA response: Part of the proposed remedy includes the establishment of a Classification
Exception Area, which would limit and require appropriate restriction on the installation of
new wells within the plume.

Vapor Intrusion

42.	A number of residents had concerns regarding the potential for vapor intrusion of Site
contamination into the indoor air of their homes and wondered about the extent of EPA's
indoor air investigation.

EPA response: Vapor intrusion sampling is ongoing within the area of the groundwater
plume. Residents that wish their homes to be sampled should contact Matthew Westgate,
EPA's project manager. If a resident within the impacted area makes such a request, the
home will be included in a future sampling event.

43.	A commenter requested a map that shows where the 35 homes requiring vapor
remediation systems are located compared to all of the 450 homes EPA sampled for
vapor contamination.

EPA response: EPA does not have such a map, however, most of the homes that required
vapor remediation system are located close to the source area, above areas of the very high
levels of groundwater contamination.

44.	A resident expressed concern about the safety of small children at a home which was
sampled previously for indoor air contaminants.

EPA response: If the home was sampled previously as part of EPA's indoor air program
and no system was installed, it was determined that contaminant levels were not posing
unacceptable risks. Please contact EPA's project manager to obtain those data and he will
evaluate your situation and consider including your home in an upcoming sampling event.

45.	A resident asked how a slab house is tested for vapor.

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EPA response: A small hole is drilled through the slab and a sampling port is installed
through which a sample is collected. Then the hole is sealed.

46.	A resident expressed concern about family members' exposure to PCE in indoor air over
a long period of time. The resident wanted to know what cancers are associated with
exposure to Site contamination through indoor air, and what health impacts can be
expected by long-term residents.

EPA response: The potential cancers associated with various levels of exposure to PCE, the
primary contaminant of concern at the Site, are cancers of the liver and kidneys. EPA cannot
speak to a specific individual's potential health impacts. EPA looks at levels of PCE in
homes, determines if the risk levels associated with those levels are acceptable or
unacceptable, and makes determinations regarding how to address the contamination.

47.	A resident wanted to know if there is a government program to address years of past
exposure to residents.

EPA response: While EPA does not conduct those types of assessments, the NJ Department
of Health does. The federal ATSDR evaluated risks posed by scenarios including the use of
irrigation well water by residents. Also, there are many doctors associated with the
University of Medicine and Dentistry of New Jersey (UMDNJ) who specialize in
environmental exposure. EPA can provide more information about these and other resources
upon request.

Note that although EPA has found some elevated levels of PCE in indoor air at the Site, out
of over 400 homes sampled, only 35 required vapor mitigation systems.

Real Estate

48.	A resident inquired as to what disclosures would a seller of a home need to make to a
potential buyer in a real estate transaction, and if a potential buyer could require the seller
to sample for contamination.

EPA response: EPA suggests these questions be referred to a real estate broker or attorney.

49.	A resident commented that EPA's estimated time frame of 30 years to remediate
groundwater is too long, and is not acceptable.

EPA response: EPA has extensive experience in the field of groundwater remediation.
Groundwater remediation is a complicated technical process that often takes on the order of
30 years, depending on the severity of the contamination and the characteristics of the
aquifer. At this Site, the contamination took 40 years to spread throughout this aquifer and it
is likely that it will take a similar amount of time to restore the aquifer to drinking water
quality.

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50.	Mayor Luttman of Wall Township reiterated the community's desire for the cleanup to be
started and completed as quickly as possible, and that testing of indoor air within all schools
potentially impacted by Site contamination be completed.

EPA response: EPA looks forward to working with all local officials in an effort to expedite
this important project to the extent possible.

NJDEP

51.	A commenter asked if there was documentation of state concurrence on the proposed
cleanup plan.

EPA response: The NJDEP has provided a verbal concurrence on the proposed plan. If the
state concurs with the selected remedy, they will provide written concurrence at that time.

52.	A commenter asked if the state will be accepting public comments on the Proposed Plan.
The commenter also inquired whether the public has an appeal process if the state agrees
with the Proposed Plan.

EPA response: This is a federal lead Superfund Site and only EPA is accepting comments
on the Proposed Plan. Comments will be accepted through September 19, 2013. All
comments received during the public comment period will be considered and addressed by
EPA prior to the selection of the final cleanup remedy for the Site.

PART 2: Oral comments received during the public comment period outside of the
public meeting

During the public comment period, and outside of the public meeting, EPA received a
number of questions and comments primarily regarding local real estate issues and indoor air
sampling requests for individual homes. These comments were also reiterated during the
public meeting and in written comments, and EPA's responses are shown in this
Responsiveness Summary.

PART 3: Written Comments

Comments from Bank of America

1. Contrary to EPA's characterization of the Site's groundwater contamination as being one
plume, the RI data clearly establish that there are two largely distinct and separate
groundwater plumes at the Site, and the edges of these plumes overlap in a limited area
(primarily Laurel and Magnolia Avenues and Old Mill Road). Where the plumes
overlap, they retain their separate characteristics. The two plumes also exhibit distinct
characteristics relative to solvent daughter product ratios. Further, a contaminant plume
is defined by a longitudinal center of mass aligned along an orientation controlled by the
hydraulic gradient.

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EPA response: EPA disagrees with the comment. As stated in the Proposed Plan, the Site
groundwater contamination emanates from two separate source areas. As the contaminated
groundwater from these two sources flows in a primarily easterly direction, it joins and mixes
together in the area around Old Mill Road, Laurel Avenue and Magnolia Avenue, after which
the combined plume continues to migrate to the northeast, east and southeast. The
contaminated plume also sinks deeper in the aquifer as it migrates downgradient. There are
not two separate plumes exhibiting different characteristics after they join together in the
mixing area. For the purposes of EPA's study, the widely accepted industry standard
definition of the term "plume" refers to all areas of groundwater contamination at the Site
(above 1 part per billion in this case) that flow downgradient from the source areas. Both
source areas contributed the same contaminant, PCE, to the plume. The PCE from the White
Swan source areas was found to be completely indistinguishable from the PCE that
originated from the Sun Cleaners source area once combined in the groundwater plume. The
theory that White Swan's PCE contamination would mix in the plume yet remain separate
and head off in a different direction after such contact was not proven during the remedial
investigation despite a number of attempts to do so. Isotope and Daughter Product Ratio
studies conducted by the responsible party failed to differentiate the PCE molecules from
different sources in the plume, therefore no determination of the source contributions could
be made based on the data gathered during the remedial investigation. The intricate
combinations of groundwater flow patterns present in the entire plume during the 40 years
the contamination was spreading were not fully characterized during the remedial
investigation, therefore assumptions based on present day flow pathways could not be used to
identify fate and transport of separate sources over the years.

Wall Township

2.	Wall Township supports the residents fully and is in favor of the most palatable, effective
and efficient solution available to cleanup the Site. The township urges EPA to take into
account the long-term and short-terms needs of residents in cleaning up the Site and will
not accept unreasonable delays. Wall Township looks forward to seeing more detailed
remediation plans as they are developed, especial those pertaining to facility noise,
disruption of traffic patterns, potential interruption of services, and storm runoff.

EPA response: EPA plans to communicate regularly with local township officials related to
this cleanup throughout the remedial design and construction phases to assure local issues are
addressed as appropriate.

3.	Wall Township, on behalf of some residents, requested additional regularly scheduled air
quality testing to take place at the Old Mill School.

EPA response: EPA will consider this request in planning its next round of indoor air
sampling.

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Manasquan

4.	Although the Manasquan governing body supports the EPA project as a whole, it objects
to EPA's proposed Alternative 4 for groundwater. This is based on the concern that
treated effluent from the groundwater treatment plant would be discharged to Judas
Creek. The Borough believes that existing flooding problems could be exacerbated if as
much as 200 gallons per minute were discharged to the creek. Manasquan requests that
EPA consider a plan where treated groundwater would be re-injected to the aquifer.

EPA response: EPA's Proposed Plan did not make a final determination that plant effluent
would be discharged to Judas Creek as part of Alternative 4. It was indicated that several
options to address the disposition of treated groundwater would be further evaluated in the
remedial design phase of the project before making a final determination. The options that
will be further evaluated include discharge to surface water (Judas Creek, or another surface
water body), reinjection to the ground, or discharge to a publically owned treatment works
(POTW). Numerous members of the community expressed similar concerns regarding
flooding in the vicinity of Judas Creek. EPA has no intention of worsening local flooding
issues and will evaluate a number of options for disposition of treated groundwater before
making a final determination.

Comments from the Community and Interested Citizens
Time frame

5.	A resident asked why it took EPA 20 years to complete its study of this Superfund Site,
and if residents were notified of risks.

EPA response: While Site groundwater contamination was originally discovered by local
officials in 1997, the Site was included on the National Priorities List of Superfund sites in
2004, and that is when EPA began activities to investigate the Site contamination. EPA's
work to determine the nature and extent of the large contaminant plume at the Site was
detailed and extensive. These studies were completed in 2013. Even prior to initiating the
site-wide investigation, in 2001, EPA began to evaluate potential exposure routes and found
that that groundwater was not posing significant immediate risks as the community was using
municipal water supplies that were tested regularly and met all New Jersey drinking water
standards. EPA evaluated potential risks posed to the public through the use of contaminated
irrigation wells and determined that the risks posed were within EPA's acceptable ranges.
The only exposure pathway of immediate concern was the exposure to vapor contaminated
with PCE in indoor air. This exposure route has been found at unacceptable levels to date in
35 out of 450 homes sampled. Where elevated vapors were found, individual vapor
ventilation systems were installed. Residents and public officials have been notified of
EPA's work periodically throughout the Site study.

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6.	A resident was concerned that the cleanup may take up to 70 years. EPA is requested to
select the alternatives that will clean up the Site contamination as quickly as possible. To
this end, Alternative 3 for soils and Alternatives 2 or 3 for groundwater are
recommended.

EPA response: All alternatives, other than the No Action alternative, will result in
approximately 70 years for the full restoration of groundwater to meet drinking water
standards through a combination of source removal, active groundwater treatment and
monitored natural attenuation. The No Action alternative would result in a cleanup time
estimated to be over 400 years. Alternative 3 for soils is estimated to take approximately one
year to remediate both source area properties. Alternative 4, EPA's preferred alternative, is
estimated to take one year to remediate the White Swan Property through soil excavation and
up tolO years to fully treat soils at the Sun Cleaners property in-situ. However, it is likely to
take less than 10 years to remove most of the soil contamination at the Sun Cleaners property
because it is expected that most of the soil contamination is readily mobile and will be treated
quickly. However, there may be small amounts of residual contamination bound up in the
less permeable parts of the unsaturated zone that may take up to 10 years to address. Further,
there are currently no unacceptable human health risks posed by exposure to soils at either
property. The soil remediation on both properties is not being performed to address soil
risks, but rather to address the impacts of the soil contamination as a source to the
groundwater contamination. Soil at both properties will be fully remediated before
groundwater goals are met in the aquifer.

7.	A resident asked what the timeline would be to begin remedial construction activities.

EPA response: After all public comments are considered, EPA will select a remedy,
documented in the Record of Decision (ROD.) After the ROD, EPA will provide an
opportunity for potentially responsible parties to enter into a consent decree, a legal
document through which they agree to implement the selected remedy. Once a consent
decree is lodged with the court, the responsible parties are obligated to begin the remedial
design phase of the work. The time frame for remedial designs can vary - but it is likely to
take at least 18 months to complete design of the remedy. Due to the above, it is likely to
take several years before construction of the remedy can be initiated. EPA will keep the
community updated on progress through periodic Site Updates.

Indoor Air

8.	A commenter inquired if a home in the area of the Site were to be purchased, could the
home be sampled for potential indoor air contamination.

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EPA response: Residents who would like their home sampled should provide their name
and address to EPA. The indoor air investigation at the Site is ongoing and the next round of
sampling is expected to take place in the winter of 2014.

Real Estate

9. A local resident asked what a homeowners's legal responsibility would be regarding
disclosure of previously collected indoor air results relating to the Site.

EPA response: EPA suggests that this question be referred to a real estate broker or attorney.

Risk

10.	A local resident asked if the Sea Girt and Spring Lake beaches are safe. She indicated
that there was no mention of this in the site file, only that the ponds are not safe for fish.

EPA response: The surface water bodies impacted by the Site's groundwater contaminant
plume do not pose any unacceptable human health risks. There is an elevated ecological risk
posed in Hannabrand Brook and Judas Creek. Although the plume reaches the Atlantic
Ocean, it is very dilute and deep by the time it is discharged into the ocean. The dilution
factor of the ocean would immediately reduce any contaminants to nondetectable levels, and
there are no unacceptable health risks for people who use the beach.

11.	A local resident asked if someone has a house where the basement has been ventilated,
what is the cancer risk? What are the health implications for living in this area, even if
there are low levels detected?

EPA response: When EPA installs a vapor mitigation system in a particular home, the air is
re-tested to assure that levels are below health based standards.

12.	A local resident asked if a cracked, old basement would present any added problems with
respect to contamination.

EPA response: This residents home has already been sampled for possible vapor intrusion
and no unacceptable levels of PCE in the air were detected.

13.	A local resident stated that a document on EPA's website indicates that EPA is working
to determine whether, under current conditions, there are any potential or actual human
exposures to contaminants at the site, and whether contaminated groundwater migration
is under control. The resident wondered if there still are current exposures and if
groundwater migration is occurring.

EPA response: All actual and potential human exposures to Site contamination have been
evaluated in detail in EPA's risk assessment, which is part of the administrative record for
the Site. The local sources of drinking water are not impacted by Site contamination. Direct

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human exposure to soils at the source areas was determined not to cause an unacceptable
risk. Surface water and sediments impacted by the Site are not posing elevated risks to
humans. Where elevated levels of indoor air contamination related to the Site have been
detected, indoor air ventilation systems have been installed that address this exposure. EPA
has not yet sampled indoor air or subslab air in all buildings that may be impacted throughout
the area of groundwater contamination. This effort is ongoing, and individual vapor
mitigation systems will continue to be installed where levels of concern are detected.

The nature and extent of groundwater contamination has been determined during the
remedial investigation. Groundwater contamination is not under control, and that is why
EPA has proposed a groundwater remedy that includes extraction and treatment of the most
highly contaminated groundwater, monitored natural attenuation of lesser contaminated
groundwater and institutional controls.

14. A local landscaper who uses an irrigation well within the Site's groundwater plume asked
a number of questions about the use of this well in his business:

a.	What is the likelihood of toxins being absorbed by plants?

EPA response: Plants do not take up the PCE contamination in the water.

b.	Are employees that are in direct contact with the water in harm's way?

EPA response: The PCE contamination in water can transfer to air upon spraying it
with a hose. The sub-slab air and indoor air at the greenhouse facility have been
sampled a number of times in the past, and no levels above the health based standards
were found that required an indoor air mitigation system. Exposure to indoor and
outdoor air is not posing unacceptable risks at this time.

c.	Are there products that can clean water prior to its coming into contact with the
plants?

EPA response: It is not clear what is meant by the term "products." There are a
number of technologies designed to remove volatile contaminants from groundwater,
including air sparging, air stripping and use of granular activated carbon.

d.	Is it possible to have our well water tested?

EPA response: Yes. Your well has been tested previously and will be tested again
during the remedial design phase of the project.

e.	What happens to the chemicals in the water when they come out of the hose?

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EPA response: If irrigation well water containing PCE is sprayed, the PCE will
generally volatilize from the water droplets to the air and dissipate.

f. We are concerned about bad press. Is there literature that we could provide to our
customers assuring them that our business and products are safe?

EPA response: EPA will provide you with some literature regarding indoor air
sampling that may meet your needs and will follow up with you.

Judas Creek

15.	A local resident asked if EPA has collected soil samples within the wetlands and
transitions/buffer area along Judas Creek between the Manasquan High School Athletic
Fields and the Willow Way Homeowners. If so, the resident requested the results? If
not, the resident asked if EPA plans on taking the soil samples prior to construction in the
aforementioned transition area of Judas Creek? Since the Manasquan Board of Education
is planning on building a retaining wall within these wetland areas, including driving
pilings approximately thirty feet into the ground, should the core soil samples be taken
first, and any construction postponed in order to test this area for contaminants?

EPA response: All data are presented in the remedial investigation report. On Figure 67 of
the RI Report, a map indicates sampling locations described in the comment. Sample
location JC08 is downgradient of Mac Pond, adjacent to athletic fields. This location had no
contaminants detected in 2007, and in 2008, 13 ppb of PCE was detected in surface water,
and there was 0.22 ppm of PCE in the sediments. A second location referred to as JC09 is
adjacent to the baseball fields, closer to Route 71. This sample had 6.3 ppb of PCE in the
surface water and 4.4 ppm of PCE in the sediments.

EPA will take additional samples in Judas Creek during the remedial design phase of the
project. EPA does not regulate construction activities at the Manasquan High School, but is
available to discuss the data collected around Judas Creek.

16.	A commenter requested that EPA reconsider the proposed added flow of water to Judas
Creek. It may exacerbate flooding in the area that seems to be getting worse over time.

EPA response: EPA is proposing that groundwater in the most contaminated areas of the
Site be extracted and treated. The method of disposition of the treated groundwater has not
yet been determined, and will be determined during the remedial design phase of the project.
The options include discharge to Judas Creek, or another surface water body, discharge to the
ground, or discharge to a POTW. EPA understands that there is a flooding problem for some
residential properties abutting Judas Creek. This will be taken into consideration during
remedial design. EPA has no intention of worsening flooding conditions.

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17.	A local resident asked if soil and air from a private property and home can be tested?

EPA response: Site-related soil contamination has been delineated and is limited to soils on
the two former dry cleaners' properties. Therefore, there is no basis to perform soil sampling
on any private residential properties. As for indoor air sampling, EPA will sample homes as
part of our ongoing sampling program based on the location relative to the groundwater
plume and history of each property.

Technical Aspects of the Cleanup

18.	A local resident stated a preference for Alternative 3 for soil and either Alternatives 2 or
3 for groundwater to assure the quickest cleanup possible.

EPA response: EPA carefully evaluated each alternative against the nine criteria in order to
propose the best overall alternatives. EPA considered time frames for cleanup of the
different alternatives, but also considered other factors including, long-term effectivenesss,
short-term effectiveness, implementability and cost. When evaluated against the nine
criteria, EPA believes that soil Alternative 4 and groundwater Alternative 4 present the best
balance of tradeoffs among the alternatives. Note that for all groundwater alternatives
(except the No Action alternative), regardless of the technology implemented, the overall
restoration of the site-wide groundwater contaminant plume would be approximately 70
years.

19.	A concerned citizen indicated that the scope of the proposed remedy appears limited
relative to the magnitude of the contamination problem. The plume is like other
Superfund sites (Bridgeport and Vineland) where much larger and more aggressive
systems are in place. While the nature of the contamination is different, the resident still
questioned the adequacy of the groundwater treatment.

EPA response: The proposed alternative for groundwater is expected to effectively address
groundwater contamination in a reasonable timeframe at this particular Site. Each Superfund
site is unique. Contaminant and aquifer characteristics vary greatly between the White
Swan/Sun Cleaners Site and the two Sites mentioned by the commenter.

20.	The concerned citizen indicated that the Near Field and Far Field groundwater
contamination zones are defined by PCE levels above and below 1,000 ppb. The citizen
asked how that level was determined and if more active treatment of areas of lower levels
of contamination would result in shorter cleanup time frames.

EPA response: EPA performed modeling to determine the appropriate areas for active
treatment and monitored natural attenuation. Based on modeling results, which are included
in the administrative record for the Site, active treatment of groundwater with approximately
1,000 ppb of PCE or greater would result in the restoration of the Site in a reasonable time

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frame. EPA also evaluated active remediation for groundwater containing various levels of
PCE including 100 ppb, 150 ppb, 200 ppb, 250 ppb, and 500 ppb.

21.	A citizen asked how the anticipated treatment of Far Field hot spots would affect the
estimated groundwater treatment costs.

EPA response: Depending on how the Far Field hot spots would be addressed, it is possible
that treatment costs may increase.

22.	An interested party commented that at this site, PCE and TCE in the groundwater can
enter homes via the vapor intrusion route. Subslab ventilation systems are being utilized
in the near term to protect the health of impacted residents. These systems, considered
temporary, are effective as long as they are properly maintained. The long-term or
permanent solution to the problem is to reduce groundwater contaminant levels to a point
where the in-house temporary systems are no longer needed. Evaluation of the
effectiveness of groundwater actions should not only consider the time necessary to meet
drinking water standards in the aquifer, but also include the time to reduce contaminant
levels such that the ventilation systems can be removed.

EPA should perform an evaluation to determine whether more aggressive remedial action
can reduce the footprint or number of homes requiring ventilation systems. The ultimate
goal of the remedy should be to clean up the groundwater in a reasonable time frame
while also reducing the reliance on the temporary ventilation systems. Residents may
prefer to not have to rely on the systems longer than absolutely necessary. Evaluation of
the benefits of more aggressive remedial action should be performed in this context.
Modifications to the proposed remedy may be considered depending on the results of this
evaluation.

EPA response: The long-term goal at this Site is groundwater restoration to meet
drinking water standards. Meeting these standards will also assure that individual vapor
mitigation systems are no longer needed. Due to the nature and distribution of the VOC
contamination in the shallow aquifer at the Site and the local geology, it is appropriate for
EPA to maintain ventilation systems in impacted homes until the aquifer in the vicinity of
the home is fully restored in order to assure protection of human health.

Note that most of the homes in which vapor ventilation systems have been installed are in
or close to the areas of the plume that will be actively extracted and treated.

23.	A local resident asked if treatability studies were performed. If so, did they include pilot-
scale equipment and testing to determine effectiveness? Are these studies available to
the public?

EPA response: Some very basic and preliminary treatability studies were performed during
the remedial investigation and feasibility phases. Additional treatability and/or pilot-scale
studies may be done as part of remedial design activities.

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24.	A local resident asked if institutional controls will be placed on the White Swan and Sun
Cleaners properties to prevent any use or redevelopment during implementation of the
remedy.

EPA response: While source soils at the two properties continue to contribute to
groundwater contamination, they do not pose unacceptable direct contact risks to humans,
even prior to cleanup. After soil remediation, the Sites can be redeveloped and will have no
use restrictions placed on them (other than any local zoning or other restrictions that may
apply). Since the groundwater contamination at the Site will take many years to remediate
fully, any future use of the property will need to consider the potential for indoor air
contamination, the same as all other properties overlying the groundwater contaminant
plume. A Classification Exception Area will be established to restrict use of the impacted
aquifer until it is fully remediated.

25.	A commenter asked if considering that it will potentially take 50 to 70 years to attenuate
the Far Field groundwater contamination, did EPA consider active remediation
techniques in these areas?

EPA response: Yes, active remediation of the entire plume, as well as varying portions of
the Far Field, were developed in the feasibility study and this is discussed in detail in the
feasibility study report. EPA evaluated active remediation of all portions of the plume with
levels of PCE exceeding 100 ppb, 150 ppb, 200 ppb, 250 ppb, 500 ppb and 1,000 ppb.

After analysis, it was determined that there is little to be gained, from a remediation time
frame perspective, by implementing a costly, large-scale active treatment remedy in the Far
Field area that would present numerous construction and operation and maintenance
challenges, and be disruptive to a large portion of the community. Based on modeling
results, active treatment of groundwater with approximately 1,000 ppb of PCE or greater
would result in the restoration of the Site in a reasonable time frame.

26.	A resident asked if alternative in-situ technologies, including six-phase heating, were
considered and if so, why they were ruled out. Based on successful remediation of PCE
contamination at similar commercial and government facilities including NASA Cape
Canaveral requiring months rather than years, this would be worthy of consideration.

EPA response: In-situ heating was considered only briefly in the early part of the screening
of the remedial alternatives and was ruled out based on cost. It is a technology that is more
appropriate at sites where there are much smaller areas of high-level contamination.

27.	A resident indicated that EPA's plan states that significant mass removal by ISVE/AS
could be expected at the Sun Cleaners source area over a period of roughly 10 years and
systems would be operated periodically until soil is remediated. The resident wanted to
know what EPA meant by the term "periodically." The resident further indicated that the

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approach to cleaning up the White Swan property is soil excavation, which is anticipated
to take one year. The resident wanted to know why the same approach not being
proposed for the Sun Cleaners source area, and if Bank of America had input into the
proposed soil cleanup methods.

EPA response: Treatment of soils through the in situ vapor extraction technology is a fairly
common remedial action and often these systems are very effective at the beginning of
operations in removing contaminant mass from soils. However, as contaminant mass in the
vapor spaces in soils decreases over time the plant may be turned off to allow the
contaminants present in the soil and soil vapor to reach equilibrium. So it may be most
effective to turn the ISVE plant off for a period of time and then turn it back on. This is what
is meant by operation of the plant "periodically". If this were to take place at the Site, it
would be determined based on sampling during the remedial action and the purpose would be
to reach cleanup goals in the most effective manner.

There are a number of reasons that EPA proposed different remedial technologies at the two
different source areas. These include: differences in the mass and distribution of the
contaminants in soils at the two properties; topographical differences; and different access
conditions at the two properties.

As Bank of America developed the feasibility study, under EPA oversight, they did have
input on the soil technologies being proposed.

28. A local resident stated that the reason EPA had given for not excavating Sun Cleaners
source area due to topography and location was questionable. The resident indicated that
both sites are in close proximity to the highway and will impact traffic flow in either
case. The resident asked if traffic impact studies had been performed and if alternatives
were explored such as temporary haul roads through an adjacent compost facility to avoid
direct truck traffic into the Highway 35 circle.

EPA response: The short-term impacts of remediation for each alternative on the
community, including potential impacts on local roadways, are always considered in
selecting a remedy. EPA is aware that the community surrounding both source area
properties is heavily developed and accessed by highly traveled roads. The location of the
two properties in itself would not necessarily prevent the implementation of any particular
alternative. EPA had to take into consideration that the excavation alternative at the Sun
property, more so than the White Swan property, would have significant short-term impacts
on traffic due to its location on Manasquan Circle. This, along with other considerations,
particularly the extent and subsurface distribution of contaminants, difficulty in performing
excavation on the slope, and cost, led EPA to propose the ISVE/AS alternative at the Sun
property over the excavation. As the back of the Sun property abuts a steep slope, which
descends into a wetland area, the only alternative for construction equipment at the Site is

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Route 35. While this is possible, it would have significant negative short-term impacts on
the community.

29.	A local resident asked what the expected operating cycles were for the proposed
groundwater extraction and treatment plant. The resident further asked for a description
of the expected sound levels of the plant and the aesthetics of the treatment plant,
including structures, fencing and landscaping.

EPA response: The groundwater extraction and treatment plant will likely be operated
continuously. The treatment system will be enclosed within a building, and if necessary, the
building can be constructed to limit noise to nearby residents. During the remedial design
phase of the project, EPA will work with local officials to assure that the noise level
produced by the plant is not unreasonable and that the aesthetics of the plant are appropriate.
The structure can be painted to best fit into its location. In addition, landscaping may be
added for aesthetics, if appropriate. Fencing is usually constructed around a treatment plant.
All of these decisions are made in the remedial design phase, in consultation with local
officials.

30.	A local resident asked if the Proposed Plan had undergone third-party peer review both
inside and outside EPA.

EPA response: It is not clear what the commenter means by "third party peer review".
However, the Proposed Plan was reviewed extensively within EPA prior to its release to the
public. It was reviewed by senior management, as well as managers in EPA Headquarters
office in Washington D.C. Further, prior to its release, the Proposed Plan was reviewed by
technical representatives of the New Jersey Department of Environmental Protection.

31.	A local resident asked when the Jefferson Avenue piezometers will be closed and
removed, and the area restored. The resident pointed out that based on EPA maps, it
appears that this area is not within the area of Site contamination. The resident asked if a
schedule of the testing of these piezonmeters will be available and reports be accessible.

EPA response: It is important for EPA to evaluate groundwater elevations and
characteristics in the perimeter of the groundwater plume, even in areas that are not
contaminated, but are in close proximity to contamination. This allows a better
understanding of the plume over time. There are no immediate plans to remove any
piezometers or monitoring wells that have been installed to study conditions at the Site.

There is not a set schedule for monitoring piezometers at the Site, but it is expected that data
will be collected from all monitoring wells and piezometers during the remedial design and
remedial action.

32.	A local resident favored Alternative 3 (in-situ chemical oxidation) for groundwater for
reasons discussed at the public meeting.

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EPA response: EPA does not prefer Alternative 3, In-Situ Chemical Oxidation to address
groundwater at the Site for a number of reasons. Compared to other alternatives, this
alternative would pose more significant short-term risks, including the handling and storage
of chemical oxidant in densely populated residential areas. This alternative would have the
potential to increase contaminated vapors in residential areas and would require the
installation of numerous injection and sampling points throughout the community.

33.	A citizen asked if the project will be handled by a private firm for soil and groundwater
disposal.

EPA response: The design and construction of the remedy will be overseen by EPA and
will either be performed by a private contractor hired by potentially responsible parties, or a
government contractor. This is yet to be determined.

34.	A resident asked if groundwater is pumped to the surface, will the contaminants become
airborne and dissipate.

EPA response: Yes, to some extent. If small privately owned irrigation wells are used to
pump and spray water, the PCE is volatilized out of the water droplets.

35.	A resident asked if the cleanup would impact the Highway 35 expansion.

EPA response: EPA will coordinate with local officials regarding any widening of Highway
35 that would impact site remediation activities and change the design plans accordingly.

36.	A local resident asked why the price for the cleanup was so high.

EPA response: Groundwater remediation is complicated and the required extraction system
to address the extensive groundwater contamination this Site is large. Please see the
feasibility study report for detailed cost estimates for each alternative.

37.	A local resident asked if pumping shallow wells within the plume can be an answer for
site contamination, and if this water could be pumped and sprayed over surface water?

EPA response: EPA does not considered spraying of PCE contaminated water in the air
adjacent to densely populated areas to be an acceptable remedy to meet the remedial action
objectives for the Site.

38.	A local resident asked how long it would take the plume to work its way to the ocean
with no cost to anybody.

EPA response: The plume has already reached the Atlantic Ocean. It is estimated that it
would take over 400 years for the entire plume to attenuate through discharge to surface
water bodies if EPA were to take no action to address contamination.

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Irrigation Wells

39.	A local resident asked about EPA's plans to inspect, monitor, upgrade or close private
irrigation wells to prevent further cross contamination prior to and during the remediation
activities.

EPA response: During remedial design, EPA will evaluate the impact of any irrigation wells
on the system that is being designed and at that time will evaluate potential impacts of the
extraction systems on the irrigation wells.

40.	A local resident asked if there was a moratorium on future shallow groundwater wells in
the area.

EPA response: There is no moratorium at this time. However, as part of the remedy, EPA
will establish a Classification Exception Area to restrict future well drilling in the area.

41.	A local resident stated that he was a resident in the area of the plume, and was
considering filling his swimming pool with water from the private irrigation well on his
property. He wondered if this practice would be safe.

EPA response: EPA asked ATSDR to evaluate the use of contaminated irrigation well water
in swimming pools and found that no adverse health effects were likely associated with this
exposure. ATSDR modified their recommendation to say that residents with homes
overlying the most elevated levels of groundwater contamination should have children wait
approximately one week before swimming in a pool filled with irrigation well water to give
the PCE time to volatilize out of the water. Copies of these ATSDR evaluations are available
in the Wall Township public library and directly from EPA. EPA also evaluated this
exposure pathway in the risk assessment performed at the Site and found that risks posed by
this exposure route were within EPA's acceptable risk range.

Communication

42.	Will documentation of the State's concurrence on the remedy be made available to the
public?

EPA response: The State of New Jersey will provide a written letter to EPA indicating the
status of their concurrence on the final remedy to be selected for the Site after consideration
of all public comments. That letter will be part of the public record.

43.	Local residents asked EPA to describe the method and status of notification to and
responses from affected town governments.

EPA response: EPA communicated the status of its investigation activities to the impacted
towns throughout the remedial investigation on a regular basis. Prior to the issuance of the
Proposed Plan, EPA briefed local officials from the three towns impacted by the Site, Wall

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Township, Sea Girt and Manasquan, as well as Congressman Smith's office. Officials from
all townships were present at EPA's August 27, 2013 public meeting and contributed
comments, questions and answers to residents' questions at the meeting. In addition, written
comments on the Proposed Plan were received from Wall Township, Sea Girt and
Manasquan and are addressed in the Responsiveness Summary.

44.	A local resident asked if the Wall Township Board of Health was notified of the
Proposed Plan and what their response was.

EPA response: While EPA did not contact the Wall Township Board of Health specifically
regarding the Proposed Plan, the Monmouth County Health Department was notified and
briefed along with local officials, who were notified of the Proposed Plan.

Liability

45.	A local resident asked if the current owner of the Sun Cleaners site was named as a
potentially responsible party, and what responsibility they would have in implementing
the cleanup?"

EPA response: The current owner of the former Sun Cleaners property has not been named
as a potentially responsible party at this time. After EPA selects the remedy for this Site, the
Agency plans on entering consent decree negotiations for the performance of the work. At
that time, the liabiality status of all parties that may be potentially responsible parties will be
evaluated.

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APPENDIX III
Attachment A

Proposed Plan

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Superfund Program	U.S. Environmental Protection Agency,

Proposed Plan	Region 2

White Swan Cleaners/Sun Cleaners Area Groundwater	\ xvjTv g

Contamination Superfund Site
August 2013

EPA ANNOUNCES PROPOSED PLAN

This Proposed Plan identifies the Preferred Alternative
to address soil and groundwater contamination at the
White Swan/Sun Cleaners Area Groundwater Superfund
Site (Site) located in Wall Township, Sea Girt and
Manasquan, Monmouth County, New Jersey, and
provides the rationale for this preference. Alternatives
have been developed to address soil and groundwater
contaminated primarily with the dry cleaning chemicals
perchloroethylene (PCE), and its breakdown products
trichloroethene (TCE) and cis-1, 2 dichloroethene (cis-
1,2 DCE).

The U.S. Environmental Protection Agency's (EPA's)
preferred alternative to address soil and groundwater
contamination is Alternative 4 for soils and Alternative 4
for groundwater. The major elements of the preferred
alternative include:

•	excavation and off-Site disposal of soils at the
White Swan Cleaners property source area;

•	in-situ soil vapor extraction/air sparging of soils
and shallow groundwater at the Sun Cleaners
property source area;

•	construction of a groundwater extraction and
treatment system to capture and treat the most
highly contaminated groundwater at the Site;

•	monitored natural attenuation for lesser
contaminated groundwater;

•	establishment of a Classification Exemption
Area to prevent exposure to groundwater during
the remediation; and

•	indoor air monitoring of buildings in close
proximity to the groundwater contamination
plume, and installation of vapor mitigation
systems, as necessary.

This Proposed Plan includes summaries of the cleanup
alternatives evaluated for Site soils and groundwater.
This document is issued by EPA, the lead agency for
Site activities, and the New Jersey Department of
Environmental Protection (NJDEP), the support agency.
EPA, in consultation with NJDEP, will select the final
remedy for the soils and groundwater after reviewing
and considering all information submitted during a 30-
day public comment period. EPA, in consultation with
NJDEP, may modify the preferred alternative or select

another response action presented in this Proposed Plan
based on new information or public comments.

Therefore, the public is encouraged to review and
comment on all the alternatives presented in this
document.

EPA is issuing this Proposed Plan as part of its community
relations program under Section 117(a) of the
Comprehensive Environmental Response, Compensation,
and Liability Act (CERCLA, commonly known as
Superfund) and Sections 300.430(f) and 300.435(c) of the
National Oil and Hazardous Substances Pollution
Contingency Plan (NCP). This Proposed Plan summarizes
information that can be found in greater detail in the
Remedial Investigation (RI), Baseline Human Health Risk
Assessment, Feasibility Study (FS) Reports and other
documents contained in the Administrative Record for the
Site.

MARK YOUR CALENDAR

PUBLIC COMMENT PERIOD:

August 20, 2013 - September 19, 2013

EPA will accept written comments on the Proposed Plan
during the public comment period.

PUBLIC MEETING: August 27, 2013

EPA will hold a public meeting to explain the Proposed
Plan and all of the alternatives presented in the Feasibility
Study. Oral and written comments will also be accepted at
the meeting. The meeting will be held in the Wall
Township Municipal Center, Main Meeting room, 2700
Allaire Road, Wall, NJ at 7:00 PM.

For more information, see the Administrative Record
at the following locations:

U.S. EPA Records Center, Region 2
290 Broadway, 18th Floor.

New York, New York 10007-1866
(212)637-4308

Hours: Monday-Friday - 9 am to 5 p.m., by appointment.

Wall Township Public Library,

Reference Section
2700 Allaire Road
Wall, NJ 07719

Hours: Mon - 10am-9pm, Tues-Thurs - 9 am -9 pm,
Fri -1 pm-5pm, Sat - 9am -5 pm

1

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SITE DESCRIPTION

The White Swan Cleaners/Sun Cleaners Area
Groundwater Contamination Site is an area of soil and
groundwater contaminated with dry cleaning chemicals
and/or their breakdown products in portions of three
municipalities: Wall Township, Manasquan Borough
and Sea Girt Borough, New Jersey. The shallow,
unconfined Cohansey and Kirkwood aquifer was
contaminated by chemicals released at two former dry
cleaning facilities located approximately 0.2 miles apart
along Route 35. The two dry cleaners released the same
volatile organic contaminant, PCE, onto the soil and in
to the shallow permeable sandy aquifer. The White
Swan source area is located at 1322 Sea Girt Avenue and
the Sun Cleaners source area is located at 2213 Route
35, (aka 201 Manasquan Circle) in Wall Township. The
groundwater contaminant plume extends from these two
source areas to the east and is approximately one mile
wide and two miles long. That plume is bordered by
Route 35 on the west; Hannabrand Brook and Wreck
Pond on the north, Judas Creek and Stockton Lake on
the south and the Atlantic Ocean on the east (see Figure
1). The former Sun Cleaners building on the west side
of Manasquan Circle was demolished. The property is
currently a vacant lot. The former White Swan building
was used as a branch office for a local bank and is
currently vacant. After the White Swan cleaning
operation ceased, the White Swan property was used as a
branch office by a national bank, but the property is now
vacant.

SITE HISTORY

The two dry cleaners operated from approximately 1960
through 1991. In the early 1990s, a resident of Magnolia
Avenue notified the Monmouth County Health
Department (MCHD) that their private irrigation well
contained PCE. Subsequent sampling identified three
irrigation wells containing PCE at levels up to 1,500
parts per billion (ppb). From 1997 to 1998, MCHD
sampled an additional 29 irrigation wells located east of
Route 35, and found extensive PCE contamination up to
1,100 ppb. Subsequently, approximately 100 irrigation
wells were sampled by MCHD and the NJDEP and
showed up to 1,648 ppb of PCE.

In 1999, MCHD sampled Hannabrand Brook and Wreck
Pond and found PCE levels ranging from 0.8 ppb to 16
ppb, in excess of the NJDEP Surface Water Quality
Standard of 0.34 ppb for PCE in fresh water. PCE was
not detected in surface water to the south in Mac Pond
and Stockton Lake. In 2002, PCE was detected at 5 ppb
in the surface water of Judas Creek near Route 71.
Subsequent surface water sampling in 2003 showed PCE
at levels up to 996 ppb in Judas Creek east of Sea Girt
Mall.

2

PCE was not detected in the Sea Girt Municipal Wells
initially. However, in late 1999, PCE was detected below
the NJ groundwater quality criteria of 1 ppb at 0.63 ppb in
one of the municipal wells. Sea Girt installed an air
stripper treatment system to remove Volatile Organic
Compounds (VOCs) from the water prior to distribution.

In January 2000, soil samples were collected by NJDEP at
the White Swan property at depths ranging from 3.5 to 6.5
feet below ground surface (bgs). PCE was detected in
samples up to 0.340 parts per million (ppm). Groundwater
samples collected at the time indicated PCE at levels up to
670 ppb, TCE at levels up to 97 ppb and DCE at levels up
to 25 ppb. NJDEP concluded the White Swan property
was a source of groundwater contamination.

In 2001, NJDEP collected soil samples from the Sun
Cleaners property which revealed the presence of PCE at
levels up to 1,900 ppm. Groundwater sampling on the
property showed PCE at levels up to 15,500 ppb. These
data confirmed the Sun Cleaners property as a source of
groundwater contamination.

NJDEP determined that VOCs in the shallow groundwater
might be volatilizing and entering the unsaturated zone
soils. These vapors could also be impacting the indoor air
quality of buildings in the vicinity of soil and groundwater
contamination. NJDEP collected indoor air samples from
approximately 30 locations and found PCE present in
some of samples. As a result, NJDEP requested EPA's
assistance to evaluate the regional PCE contamination in
December 2001.

EPA began an investigation of indoor air in late 2001
which included approximately 300 samples from 220
locations. The sampling included homes, schools and
businesses. As a result, indoor air ventilations systems,
similar to radon type systems, were installed in 6
residences and 2 commercial properties. Additionally,
NJDEP continued to sample and install ventilation
systems in structures with PCE above health based levels
in indoor air. Eventually, a total of 29 buildings received
systems during this phase. Indoor air sampling continued
while the remedial investigation was being conducted and
is ongoing.

EPA conducted soil sampling at the White Swan and Sun
Cleaners properties in early 2003. At the White Swan
property, the highest PCE soil concentration detected was
57 ppm located 20 feet bgs. At the Sun Cleaners property
the highest PCE concentration detected was 1,200 ppm,
located 14 feet bgs.

The site was included on the National Priorities List
(NPL) on September 23, 2004.

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Remedial Investigation

On September 21, 2006, EPA issued Bank of America
(BOA), a potentially responsible party (PRP) for the
Site, an administrative order on consent which required
BOA to conduct a remedial investigation and feasibility
study. Following review and approval of the planning
documents, the remedial investigation field activities
began in August 2007. The purpose of the investigation
was to determine the nature and extent of contamination
at the Site. After extensive preliminary field screening
investigations, BOA installed over 60 monitoring wells
and piezometers (groundwater sampling sites). They
collected over 500 groundwater samples using
temporary borings. Soil and groundwater samples were
collected and analyzed through 2008, 2009 and 2010.

Most of the RI field work was completed in 2010.
Subsequent to the field operations, the remedial
investigation report, risk assessment, and feasibility
study were drafted. Concurrent with this work, EPA
performed extensive vapor investigations in and under
structures in proximity to the groundwater contaminant
plume.

SITE CHARACTERISTICS

The Site is located within the New Jersey Coastal Plain.
In general, the topography of the area is flat. The
majority of the Site contains mixed residential housing
and small commercial buildings. There are farms and
woodlands to the west and the Atlantic Ocean coast on
the east.

The Site area is underlain by the Cohansey and
Kirkwood Formations which consist of unconsolidated,
interbedded sand, silt and clay layers gently dipping
towards the east. The ground surface is mostly medium
grained sand which allows surface water to percolate
down and flow to the east. Approximately 75 feet bgs is
a low permeability layer which keeps the groundwater
contamination from going deeper. The top of the water
table, or saturated zone, is about 12 to 15 feet bgs. The
regional groundwater flow across the Site is generally
east towards the ocean, but some of the shallow
contaminated groundwater flows northeast into
Hannabrand Brook and Wreck Pond. To the south,
some shallow contaminated groundwater flows southeast
into Judas Creek and Stockton Lake.

The White Swan facility is located 44 to 47 feet above
mean sea level (msl) and the ground surface slopes to the
east. Hannabrand Brook is located approximately 1,500
feet northeast of the White Swan source area and flows
eastward into Wreck Pond and the Atlantic Ocean. The
Sun Cleaners property is located approximately 1,200
feet to the southwest of the White Swan property at an
elevation of 46 to 51 feet above msl. Surface water

3

from the west of the Sun Cleaners property flows east into
an intermittent stream called Judas Creek, then into Mac
Pond and eventually to Stockton Lake and finally, the
ocean.

The contaminants of concern (CoCs) at the Site include
PCE and its associated breakdown products, TCE and cis-
1, 2-DCE. PCE, TCE and DCE contamination from both
source areas is dissolved in groundwater. The
contaminated groundwater from the separate sources
flows east and meets near Old Mill Road between
Magnolia Ave and Sea Girt Ave. The combined
groundwater contamination continues to migrate east,
northeast and southeast towards the Atlantic Ocean. The
northern boundary of the contaminant plume is
Hannabrand Brook and Wreck Pond. The southern
boundary is Judas Creek, Mac Pond and Stockton Lake.
The extent of the contaminant plume is approximately one
mile wide (north to south) and two miles long (west to
east) (see Figure 1).

The groundwater contaminant plume is underlying an area
of dense residential and commercial development. The
towns impacted by the Site's groundwater plume provide
residents with a public water supply system. Pre-existing
wells within the area of the Site's groundwater
contaminant plume are used for non-potable purposes,
mainly irrigation.

The nearest municipal wells to the source areas are
operated by Sea Girt, and are located about 6,000 feet east
(downgradient) of the Site's source areas. The wells draw
water from depths of 123 feet, 129 feet and 715 feet below
the ground surface. The Borough of Sea Girt installed an
air stripper after detecting PCE at 0.63 ppb (below the NJ
Groundwater Quality Standard) in 1999. Frequent
sampling is performed to assure that all drinking water
standards are met.

White Swan Soils

In 2001, the PRP excavated the septic tank, associated
piping and associated contaminated soil from the White
Swan property parking lot. Approximately 20 tons of soil
were excavated and transported off-Site to a licensed
facility for disposal. However, significant soil
contamination remains at the property, to a depth of 25
feet bgs, which is 10 feet below the water table. During
the RI, in 2008, a total of 52 samples were collected from
13 borings. In 2009, 16 additional subsurface soil samples
were collected from 10 additional borings. Soil samples
from the unsaturated zone below the asphalt pavement at
the White Swan property showed PCE contamination at
levels ranging from 1 ppm to a maximum of 160 ppm at a
depth of 0-7 feet bgs, and up to a maximum of 28,000
ppm at 17 -25 feet bgs (below the water table). PCE mass
in the soil at the White Swan property is estimated to be
approximately 4,360 pounds. Maximum TCE and cis-1,

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2, DCE levels on the property are 32 ppm and 37 ppm
respectively.

Sun Cleaners Soils

At the Sun Cleaners property, a total of 48 subsurface
soil samples from 13 soil borings were collected in 2008.
PCE contamination in the unsaturated zone soils at the
Sun Cleaners property was found to be as high as 51
ppm (at a depth of 6 to 13 feet bgs) with a total PCE soil
mass of approximately 140 pounds. The maximum TCE
level was 3.8 ppm and the maximum cis-1, 2, DCE level
was 31 ppm.

Surface Water and Sediments

NJDEP surface water samples from 2003 showed levels
of PCE at 996 ppb in Judas Creek east of the Foodtown
Mall near Sea Girt Ave. These levels were above the NJ
surface water quality standard of 0.34 ppb in fresh water.
In 2008, RI surface water samples collected 500 feet
downgradient showed significantly lower levels of PCE
at 31 ppb, 13 ppb, 6.3 ppb, 4.1 ppb, 12 ppb and 13 ppb
between Mac Pond and Stockton Lake.

Judas Creek sediment samples showed PCE at 4.4 ppm
near Manasquan High School and 0.79 ppm and 0.81
ppm near Route 71. These are above the site specific
NJDEP ecological screening criteria of .45 ppm for
sediments.

In 2000, in Hannabrand Brook, NJDEP found PCE at 1
ppb in surface water near St. Catharine's Cemetery and 2
ppb in Wreck Pond. During the RI, PCE was found at
1.1 ppb in the unnamed tributary surface water that feeds
into Hannabrand Brook and up to 5.9 ppb in the surface
water of Hannabrand Brook itself. Wreck Pond surface
water showed PCE levels up to 0.25 ppb (estimated) at
the Route 71 Bridge.

PCE was found at 0.21 ppm in the Hannabrand Brook
sediments near St. Catharine's Cemetery. Sediments in
the unnamed tributary had PCE levels as high as 1.8
ppm and 4.1 ppm (estimated) in Hannabrand Brook.

Groundwater

The Site's groundwater plume is contaminated with PCE
at levels ranging from 1 ppb to 75,000 ppb, and
continues to migrate from the two source areas located
near Route 35 eastward to the Atlantic Ocean,
approximately 2 miles away. The plume extends from
the water table at the source areas to a depth of
approximately 70 feet bgs, where a low permeability
layer extends across much of the site. The
contamination does not extend to the north of
Hannabrand Brook or Wreck Pond, and generally not
south of Judas Creek and Stockton Lake.

at the White Swan property and 61,000 ppb at the Sun
Cleaners property.

There are two areas of the plume, in close proximity and
downgradient of the two source areas which generally
contain the highest levels of groundwater contamination.
These two areas are referred to as the Near Field areas and
generally contain concentrations of PCE over 1,000 ppb.
The Near Field areas include groundwater underlying the
Sun Cleaners property and extending over 1,000 feet
downgradient, and groundwater underlying the White
Swan property and extending approximately 700 feet
downgradient. The remainder of the groundwater plume is
referred to as the Far Field. The Far Field area of
groundwater contamination generally includes areas
where PCE has been detected between the levels of 1 ppb
and 1,000 ppb. However, within the large Far Field area,
there are a number of "hot spots," which are smaller
localized areas of PCE contamination that range from 500
ppb up to 3,100 ppb. The PCE contamination within the
groundwater generally sinks deeper as it proceeds to the
east, but was not found below the low permeability zone
around 75 feet bgs.

Indoor Air

In the vicinity of the shallow groundwater contamination,
VOCs may escape or volatilize from the groundwater and
permeate the unsaturated zone soils. This vapor can
penetrate basement walls and floors in occupied
dwellings. EPA has sampled the sub-slab air and/or
indoor air of over 400 residences and commercial
buildings in order to evaluate this exposure pathway and
will continue to sample buildings in the vicinity of the
contamination to assess the potential risk to occupants.
The highest level of PCE vapor in sub-slab air was found
to be 9,500 (ig/m3 below a residence near Christie Lane
and Sea Girt Ave. To date, thirty-four indoor air
ventilation systems have been installed by EPA in
buildings where indoor air PCE levels exceeded health
based levels. The systems are designed to vent vapors
from beneath the foundation, thereby preventing vapors
from entering the building. These systems are monitored
to ensure they are performing properly. Sampling of
residences and buildings overlying the groundwater plume
will continue. Additional indoor air ventilation systems
will be installed, as needed, to prevent unacceptable risks
to occupants of buildings.

During the RI, PCE was found as high as 75,000 ppb

4

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WHAT IS A "PRINCIPAL THREAT"?

The NCP establishes an expectation that EPA will use
treatment to address the principal threats posed by a site
wherever practicable (NCP Section 300.430(a) (1) (iii)
(A)). The "principal threat" concept is applied to the
characterization of "source materials" at a Superfund
site. A source material is material that includes or
contains hazardous substances, pollutants or
contaminants that act as a reservoir for migration of
contamination to ground water, surface water or air, or
acts as a source for direct exposure. Contaminated
ground water generally is not considered to be a source
material; however, Non-Aqueous Phase Liquids
(NAPLs) in ground water may be viewed as source
material. Principal threat wastes are those source
materials considered to be highly toxic or highly mobile
that generally cannot be reliably contained, or would
present a significant risk to human health or the
environment should exposure occur. The decision to
treat these wastes is made on a site-specific basis
through a detailed analysis of the alternatives using the
nine remedy selection criteria This analysis provides a
basis for making a statutory finding that the remedy
employs treatment as a principal element.

PRINCIPAL THREATS

This Proposed Plan addresses soil contamination at both
PCE source areas identified at the Site. These soils are
considered principal threat wastes. Addressing these
contaminated soils will have a positive impact on the
planned groundwater remediation, as they are an
ongoing source of groundwater contamination at the
Site.

SCOPE AND ROLE OF THE ACTION

EPA is addressing the cleanup of this Site through one
phase, or operable unit of long-term cleanup, addressing
the source area soils, sediment, groundwater
contamination, and indoor air contamination.

RISK SUMMARY

The purpose of the risk assessment is to identify
potential cancer risks and noncancer health hazards at
the site assuming that no further remedial action is taken.
A baseline human health risk assessment was performed
to evaluate current and future cancer risks and noncancer
health hazards based on the results of the remedial
investigation.

A screening-level ecological risk assessment was also
conducted to assess the risk posed to ecological
receptors due to site-related contamination.

Human Health Risk Assessment

As part of the RI/FS, a baseline human health risk
assessment was conducted to estimate the risks and
hazards associated with the current and future effects of
contaminants on human health and the environment. A
baseline human health risk assessment is an analysis of the
potential adverse human health effects caused by
hazardous-substance exposure in the absence of any
actions to control or mitigate these under current and
future land uses.

A four-step human health risk assessment process was
used for assessing site-related cancer risks and noncancer
health hazards. The four-step process is comprised of:
Hazard Identification of Chemicals of Potential Concern
(COPCs), Exposure Assessment, Toxicity Assessment,
and Risk Characterization (see adjoining box "What is
Risk and How is it Calculated").

The baseline human health risk assessment began with
selecting COPCs in the various media (i.e., soil,
groundwater, surface water, and sediment) that could
potentially cause adverse health effects in exposed
populations. The current and future land use scenarios
included the following exposure pathways and
populations:

•	Construction Worker: current/future ingestion, dermal
contact and inhalation of surface and subsurface soil
and future inhalation of outdoor and indoor vapors for
adults

•	Utility Workers: current/future ingestion, dermal
contact and inhalation of surface and subsurface soil
for adults

•	Residents: current/future ingestion and dermal contact
of surface soil, current ingestion, dermal contact and
inhalation of groundwater from lawn watering and
swimming pools, current inhalation of air from
outdoor and indoor vapors, and future ingestion,
dermal contact and inhalation of groundwater for
adults and children

•	Transient Visitors: current/future ingestion and dermal
contact of surface soil, current/future ingestion,
dermal contact and inhalation of surface water and
sediment from Wreck Pond, Hannabrand Brook and
Judas Creek, which includes Mac Pond and Stockton
Lake, and current future consumption of fish and
crabs from Wreck Pond for adults, teens (age 12-17),
older children (age 7-11) and children (age 0-6)

•	Commercial Customers: current inhalation of air from
outdoor and indoor vapors for adults, adolescents and
children

5

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• Commercial Workers: current inhalation of air from
outdoor and indoor vapors for adults

In this assessment, exposure point concentrations were
estimated using either the maximum detected
concentration of a contaminant or the 95% upper-
confidence limit (UCL) of the average concentration.
Chronic daily intakes were calculated based on the
reasonable maximum exposure (RME), which is the
highest exposure reasonably anticipated to occur at the
site. The RME is intended to estimate a conservative
exposure scenario that is still within the range of
possible exposures. Central tendency exposure (CTE)
assumptions, which represent typical average exposures,
were also developed. A complete summary of all
exposure scenarios can be found in the baseline human
health risk assessment.

Surface Soil

Risks and hazards were evaluated for current and future
exposure to surface soil at both source areas. The
populations of interest included adult construction and
utility workers. The cancer risks for both receptor
populations evaluated were within or below the
acceptable EPA risk range of 1.0E-06 to 1.0E-04. The
hazard index for construction workers and utility
workers were below the EPA acceptable value of 1.
There were no contaminants of concern (COCs)
identified for soil (Table 1).

Table 1. Summary of hazards and risks associated with
surface soil.

Receptor

Hazard
Index

Cancer Risk

Construction Worker - Adult

0.17

1E-06

Utility Worker - Adult

0.17

2E-05

There were no COCs identified in the surface soil.

Receptor

Hazard
Index

Cancer Risk

Utility Worker - Adult

0.16

2E-06

There were no COCs identified in the subsurface soil.

Groundwater

Risks and hazards were evaluated for current and future
exposure to groundwater from irrigation wells and private
wells. The populations of interest included adult and child
residents. The cancer risk for the use of the irrigation
wells for both the adult and child residents were within the
acceptable EPA risk range of 1.0E-06 to 1.0E-04. The
hazard indexes for use of the irrigation wells for both adult
and child resident were below the EPA acceptable value
of 1. The cancer risks and hazard indices for future use of
the groundwater for drinking exceed the acceptable EPA
risk ranges and hazard value for both the adult and the
child. The COCs that were identified for groundwater
include four VOCs (Table 3).

Table 3. Summary of hazards and risks associated with
groundwater.

Receptor

Hazard
Index

Cancer Risk

Irrigation Wells - Adult

0.13

1E-04

Irrigation Wells - Child

0.51

1E-04

Swimming Pools - Adult

0.14

1E-04

Swimming Pools - Child

0.17

3E-05

Tap Water (Shallow) - Adult

30

4E-02

Tap Water (Shallow) - Child

87

7E-02

Tap Water (Deep) - Adult

7.5

1E-04

Tap Water (Deep) - Child

18

7E-05

COCs include: tetrachlorethylene (PCE),
trichloroethylene (TCE), cis-l,2-dichloroethylene, and
vinyl chloride

Subsurface Soil

Risks and hazards were evaluated for the potential
current and future exposure to subsurface soil. The
population of interest included adult construction and
utility workers. The subsurface soil, identified as 2-10
feet below ground surface, was evaluated for
construction workers and the cancer risk and non-cancer
hazards were within or below EPA criteria.

Both the cancer risk and hazard indices were below or
within the EPA acceptable values and ranges. There
were no COCs identified in the subsurface soil (Table 2).

Surface Water and Sediment

Risks and hazards were evaluated for current and future
exposure to surface water and sediment from Wreck Pond,
Hannabrand Brook, and Judas Creek, which includes Mac
Pond and Stockton Lake. The populations of interest
included adult, teen, older child, and child transient
visitors for Wreck Pond and teen and older child transient
visitors for Hannabrand Brook and Judas Creek. The
cancer risks and hazard indices for all of the populations
evaluated were below or within the EPA acceptable
values. There were no COCs identified for surface water
or sediment (Table 4). Since there were no COCs
identified for surface water or sediment, the ingestion of
biota from Wreck Pond was considered to be an
incomplete pathway.

Table 4. Summary of hazards and risks associated with
surface water and sediment.

Table 2. Summary of hazards and risks associated with
subsurface soil.

Receptor

Hazard
Index

Cancer Risk

Construction Worker - Adult

0.16

3E-05

6

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Receptor

Hazard Index

Cancer
Risk

Surface Water - Wreck Pond

Transient Visitor - Adult

0.0024

5E-08

Transient Visitor - Teen

0.01

5E-08

Transient Visitor - Older
Child

0.022

1E-07

Transient Visitor - Child

0.0059

3E-08

Surface Water - Hannabrand Brook

Transient Visitor - Teen

0.022

2E-07

Transient Visitor - Older
Child

0.040

2E-07

Surface Water - Judas Creek

Transient Visitor - Teen

0.018

3E-05

Transient Visitor - Older
Child

0.035

4E-05

Sediment - Wreck Pond

Transient Visitor - Adult

0.00031

5E-08

Transient Visitor - Teen

0.0016

6E-08

Transient Visitor - Older
Child

0.0017

5E-08

Transient Visitor - Child

0.00072

3E-08

Sediment - Hannabrand Brook

Transient Visitor - Teen

0.0056

2E-06

Transient Visitor - Older
Child

0.012

2E-06

Sediment - Hannabrand Brook

Transient Visitor - Teen

0.0078

2E-06

Transient Visitor - Older
Child

0.0082

2E-06

There were no COCs identified in the surface water or
sediment.

Vapors

The potential for vapor intrusion into a building's indoor
air is being addressed through an ongoing EPA sampling
program. The investigation includes collection and
analysis of sub-slab soil gas samples, and indoor air
samples in structures overlying the groundwater
contaminant plume. Levels of contaminants are
compared to health-based standards for each structure.

Where health-based standards are exceeded, vapor
mitigation systems have been installed. Sampling is
ongoing throughout the area overlying the plume, and
additional indoor air ventilation systems will be
installed, as needed, to prevent unacceptable risk to
occupants of buildings. Therefore, a quantitative risk
analysis was not needed.

The evaluation of potential outdoor vapor exposure to
residents, commercial customers, commercial workers
and construction workers indicated that the pathway was
incomplete. Therefore, a quantitative analysis was not
needed.

It is EPA's current judgment that although the risks

7

associated with soil exposure are within or below EPA's
acceptable values, the soil concentrations of PCE and TCE
are above concentrations that are associated with an
adverse impact to groundwater, thus there is a need to
address the soil through a remedial action.

Based on the results of the human health risk assessment,
a remedial action is necessary to protect human health
from actual or threatened releases of hazardous substances
in groundwater.

Ecological Risk Assessment

A screening-level ecological risk assessment was
conducted to evaluate the potential for ecological risks
from the presence of elevated VOCs in ground water that
discharges to surface water and sediments associated with
the Judas Creek and Hannabrand Brook stream systems.
The SLERA focused on evaluating the potential for
impacts to sensitive ecological receptors to site-related
constituents of concern through exposure to surface water
and sediment from Wreck Pond, Hannabrand Brook, and
Judas Creek, which includes Mac Pond and Stockton
Lake. Surface water and sediment concentrations were
compared to ecological screening values as an indicator of
the potential for adverse effects to ecological receptors for
each water body system. A complete summary of all
exposure scenarios can be found in the screening level
ecological risk assessment (SLERA).

Hannabrand Brook System: There is a potential for
adverse effects to fish and aquatic invertebrates from
exposure to contaminated groundwater that is discharging
to Hannabrand Brook. The sediment screening criteria
were exceeded for PCE in three locations, resulting in
hazard indices (His) of 4.1, 1.8 and 0.7, two of which are
above the acceptable value of 1. The PCE detections in
the sediment are considered to be site-related. The surface
water screening criteria was not exceeded for Hannabrand
Brook.

Judas Creek System: There is a potential for adverse
effects to aquatic fish and invertebrates from exposure to
contaminated groundwater that may be discharging to
Judas Creek. The sediment screening criteria were
exceeded for PCE in two locations, resulting in His of 4.4
and 1.8, which are above the acceptable value of 1. The
PCE detections in the sediment may be associated with
runoff from an industrial area instead of groundwater
discharge. The surface water screening criteria was not
exceeded for Judas Creek.

Based on the results of the ecological risk assessment, a
remedial action is necessary to protect the environment
from actual or threatened releases of hazardous
substances, which includes the discharge of contaminated
groundwater into surface water bodies at the Site.

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WHAT IS RISK AND HOW IS IT
CALCULATED?

A Superfund baseline human health risk assessment is an
analysis of the potential adverse health effects caused by
hazardous substance releases from a site in the absence of
any actions to control or mitigate these under current- and
future-land uses. A four-step process is utilized for assessing
site-related human health risks for reasonable maximum
exposure scenarios.

Hazard Identification: In this step, the contaminants of
concern at the site in various media (i.e., soil, groundwater,
surface water, and air) are identified based on such factors
as toxicity, frequency of occurrence, and fate and transport
of the contaminants in the environment, concentrations of the
contaminants in specific media, mobility, persistence, and
bioaccumulation.

Exposure Assessment: In this step, the different exposure
pathways through which people might be exposed to the
contaminants identified in the previous step are evaluated.
Examples of exposure pathways include incidental ingestion
of and dermal contact with contaminated soil. Factors
relating to the exposure assessment include, but are not
limited to, the concentrations that people might be exposed
to and the potential frequency and duration of exposure.
Using these factors, a "reasonable maximum exposure"
scenario, which portrays the highest level of human
exposure that could reasonably be expected to occur, is
calculated.

Toxicity Assessment: In this step, the types of adverse health
effects associated with chemical exposures, and the
relationship between magnitude of exposure (dose) and
severity of adverse effects (response) are determined.
Potential health effects are chemical-specific and may
include the risk of developing cancer over a lifetime or other
non-cancer health effects, such as changes in the normal
functions of organs within the body (e.g., changes in the
effectiveness of the immune system). Some chemicals are
capable of causing both cancer and non-cancer health
effects.

Risk Characterization: This step summarizes and combines
exposure information and toxicity assessments to provide a
quantitative assessment of site risks. Exposures are
evaluated based on the potential risk of developing cancer
and the potential for noncancer health hazards. The
likelihood of an individual developing cancer is expressed as
a probability. For example, a 10"4 cancer risk means a
"one-in-ten-thousand excess cancer risk"; or one additional
cancer may be seen in a population of 10,000 people as a
result of exposure to site contaminants under the conditions
explained in the Exposure Assessment. Current Superfund
guidelines for acceptable exposures are an individual lifetime
excess cancer risk in the range of 10"4 to 10"6 (corresponding
to a one-in-ten-thousand to a one-in-a-million excess cancer
risk). For noncancer health effects, a "hazard index" (HI) is
calculated. An HI represents the sum of the individual
exposure levels compared to their corresponding reference
doses. The key concept for a noncancer HI is that a
"threshold level" (measured as an HI of less than 1) exists
below which noncancer health effects are not expected to
occur.

REMEDIAL ACTION OBJECTIVES

Remedial action objectives (RAOs) were developed for
soils and groundwater to address the human health risks
and environmental concerns posed by Site-related
contamination.

RAOs:

•	Prevent or minimize current and future human
exposures, including ingestion of groundwater
and/or inhalation of vapors, from Site-related
VOCs in groundwater that present a risk to public
health and the environment;

•	Prevent or minimize migration of Site-related soil
contamination to groundwater;

•	Restoration of the Site groundwater to meet
drinking water standards within a reasonable time
frame; and

•	Prevent or minimize the migration of Site-related
contaminated groundwater to surface water and
sediment that presents a risk to the environment.

To achieve RAOs, cleanup goals for soils at the Site were
developed. Soil cleanup standards that will be protective
of groundwater were developed by using the SESOIL
model. The cleanup goal calculated through the model is
1 ppm for PCE in soils. It is believed that remediation of
Site soils to this standard will address all Site-related
contaminants.

The remediation goals selected for the groundwater are
based on groundwater applicable or relevant and
appropriate requirements (ARARs) for this Site, which
include the federal and state MCLs, and NJDEP
Groundwater Quality Criteria (GWQC). The Site
groundwater remediation goals are the most conservative
of the above criteria. The remediation goals selected for
the primary contaminants of concerns at this Site are 1 ppb
for PCE and 1 ppb for TCE, which are the state GWQC.

SUMMARY OF REMEDIAL ALTERNATIVES

Potential applicable technologies were identified in the FS
prepared for this Site. These technologies were initially
screened based on effectiveness, implementability and
cost as criteria. Those technologies that passed initial
screening were then assembled into four remedial
alternatives for soil and four remedial alternatives for
groundwater.

All of the alternatives, with the exception of the No
Action alternative, would include the ongoing

8

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investigation and remediation, as appropriate, of indoor
air containing elevated levels of VOCs in structures
overlying the groundwater contaminant plume.

Sampling of indoor and sub-slab air would continue.
Individual vapor mitigation systems would be installed
at each structure determined to have elevated levels of
VOCs in indoor air, and systems installed previous to the
remedy selection would be maintained.

In the process of developing groundwater remedial
alternatives for the Site, a number of groundwater
extraction and treatment scenarios that would address
varying portions of groundwater contamination in the
Far Field area were evaluated, but screened out.

Extensive extraction and treatment of groundwater
throughout the Far Field area, was shown through
modeling as not likely to be highly effective. Extraction
of groundwater throughout the Far Field area would be
highly disruptive to the community, expensive and
would not significantly decrease the overall cleanup time
frame compared to the alternatives that were developed
which rely on active treatment in the Near Field areas
and allow Far Field contamination to attenuate.

All of the groundwater remedial alternatives, with the
exception of the No Action Alternative, would include
the establishment of a Classification Exception Area
(CEA) in accordance with state regulations to minimize
the potential exposure to contaminated groundwater until
the groundwater meets the remediation goals. However,
consistent with expectations set out in Superfund
regulations, none of the alternatives rely exclusively on
institutional controls to achieve protectiveness.

All of the groundwater remedial alternatives, with the
exception of the No Action Alternative, would rely in
part on monitored natural attenuation (MNA) to restore
the lesser contaminated portions of the groundwater
contaminant plume to drinking water standards. With
the performance of an active remediation of the most
contaminated groundwater in the Near Field, modeling
has shown that Far Field groundwater would be restored
to drinking water standards in a much shorter time frame
than without remediation (roughly 70 years vs. 400
years). The implementation of MNA requires long-term
monitoring of contaminants as they naturally attenuate
through dilution, dispersion, adsorption, volatilization
and/or biodegradation, until groundwater returns
naturally to concentrations below the remediation goals.
These processes are expected to be effective at this Site
in areas of lesser groundwater contamination in
conjunction with active treatment in the areas of higher
contamination. In the Far Field area, due to the aerobic
nature of the Site aquifer, dispersion and dilution are
likely to be the predominant forms of natural
attenuation. In addition, since 2000, decreasing

9

contamination concentrations have been observed near the
source areas. EPA believes this dilution trend will
continue in this very prolific, unconfined aquifer, in which
groundwater migrates at approximately one foot per day.
Based on preliminary modeling, it is expected that, in
conjunction with active treatment in the Near Field areas,
the estimated natural attenuation time frame in the Far
Field areas is approximately 50 to 70 years. The MNA
portion of each groundwater alternative listed below (with
the exception of the No Action alternative), would include
the installation and sampling of an estimated nine clusters
of monitoring wells, in addition to surface water and
sediment sampling in the water bodies bounding the Site's
groundwater plume. The exact sampling frequency and
protocol would be established during the remedial design
(RD) phase of the cleanup.

For the groundwater alternatives, EPA chose to actively
address groundwater above 1,000 ppb of PCE based on
modeling which showed active treatment of areas of lower
concentrations (100, 150, 200 and 250 ppb) would not
appreciably speed up the groundwater cleanup time.

The time frames presented below for construction do not
include the time necessary for pre-design investigations,
remedial design, or contract procurements. Each of the
groundwater alternatives will take longer than five years
to achieve remediation goals. Therefore, a five-year
review will be conducted every five years after the
initiation of the remedial action, until remediation goals
are achieved.

Consistent with EPA Region 2's Clean and Green policy,
EPA will evaluate the use of sustainable technologies and
practices with respect to any remedial alternatives selected
for this Site.

A brief summary of the remedial alternatives developed
for the Site is provided below. More detailed descriptions
of the remedial alternatives can be found in the FS report.

Alternatives for Soil Source Areas

Alternative 1 - No Action

The No Action Alternative was retained, as required by
the National Contingency Plan (NCP), and provides a
baseline for comparison with other alternatives. No
remedial actions would be implemented as part of the No
Action Alternative. Furthermore, this alternative would
not involve any monitoring of groundwater or institutional
controls. Contaminants in the soil would continue to
migrate into the groundwater, and VOC contamination
would continue to migrate with groundwater
downgradient. In addition, vapor phase contamination
would continue to migrate into the indoor air of some
structures overlying the plume.

-------
Total Capital Cost	$0

Operation and Maintenance	$0

Total Present Net Worth	$0

Time frame	N/A

Alternative 2 - In-Situ Soil Vapor Extraction/Air
Sparging for Sun Cleaners and White Swan Source
Area Soils

Alternative 2 includes the in-situ vapor extraction
(ISVE) and air sparging (AS) of soil and shallow ground
water in the two soil source areas. This alternative
would involve the injection of air into the subsurface
groundwater, enabling a phase transfer of VOCs from a
dissolved state to the vapor phase. The contaminated air
enters the unsaturated, contaminated soils, where a SVE
system creates a negative pressure through a series of
extraction wells. The extraction wells are used to collect
the contaminated air, which is then treated to remove
contaminants through the use of catalytic oxidizers or
granular activated carbon (GAC). BOA has proposed
that this alternative include the use of a series of
recirculating groundwater remediation wells (RGRWs),
which would apply the same principals as explained
above, but would provide for both air sparging and ISVE
to be implemented within well casings of a series of
wells. Specific details of the implementation of this
technology would be determined during the RD phase.

Active operation of the ISVE/AS system may be
intermittent over the estimated 10 year time frame to
achieve goals.

Total Capital Cost
Operation & Maintenance
Total Present Net Worth
Time frame

$1.8 million
$1.8 million
$3.6 million
10 years

Alternative 3 -Excavation and Disposal of Soils at the
Sun Cleaners and White Swan Source Areas

Alternative 3 would include excavation, removal, and
off-site treatment and/or disposal of all soil containing
more than 1 ppm of PCE from the White Swan and Sun
Cleaners source areas. There are approximately 5,100
cubic yards of soils exceeding the cleanup criteria at the
White Swan property and approximately 9,600 cubic
yards at the Sun Cleaners property. Treatment or
disposal would occur at RCRA-permitted facilities in
accordance with regulatory requirements for these soils.
Excavation would be accomplished with commonly used
construction equipment, by methods widely used for
impacted soils in cases where the soil contamination is
relatively shallow, less than 25 feet below ground
surface. Sheet piling and de-watering would be required
as excavation would go below the water table to

maximize mass reduction. The contaminated groundwater
generated during soil excavation would be collected and
properly treated. Traffic controls would be required
because of the close proximity to the Manasquan Traffic
Circle and Sea Girt Avenue. This alternative would be
completed in approximately one year. Demolition and
disposal of the White Swan Bank building may be
required to facilitate the excavation.

Total Capital Cost	$8 million

Operation and Maintenance	$0

Total Present Net Worth	$8 million

Time frame	1 year

Alternative 4 - In-Situ Soil Vapor Extraction/Air
Sparging at the Sun Cleaners Source Area and
Excavation and Disposal of Soils at the White Swan
Source Area

Alternative 4 includes ISVE/AS of soil and shallow
groundwater in the Sun Cleaners source area (as described
in Alternative 2) and excavation and off-site disposal of
contaminated soils at the White Swan source area (as
described in Alternative 3). ISVE/AS would be preferred
at the Sun Cleaners source area as there is relatively low
estimated PCE mass as compared to the White Swan
source area. Excavation and off-Site disposal would be
more appropriate at the White Swan source area because it
contains a much higher mass of PCE contamination at a
relatively shallow depth (less than 25 feet) compared to
the Sun Cleaners source area. In addition, based on its
topography and location, excavation would be much easier
to implement at the White Swan source area compared to
the Sun Cleaners source area. ISVE/AS is expected to be
a slower process for removal of PCE compared to
excavation due to mass transfer limitations. Significant
mass removal by ISVE/AS could be expected at the Sun
Cleaners source area over a period of roughly 10 years,
and systems would be operated periodically until soil is
remediated. Soil excavation at White Swan would take
less than one year. Demolition and disposal of the White
Swan Bank building may be required to facilitate the
excavation.

Total Capital Cost
Operation and Maintenance
Total Present Net Worth
Time frame

$4.5 million
$.9 million
$5.4 million
10 years (Sun)

1 year (White Swan)

Alternatives for Groundwater

Alternative 1 - No Action

The No Action Alternative was retained, as required by
the NCP, and provides a baseline for comparison with
other alternatives. Under this alternative, no remedial

10

-------
actions would be implemented. Furthermore, this
alternative would not involve any monitoring of
groundwater or institutional controls. Contaminants in
the groundwater would continue to migrate uncontrolled.

Total Capital Cost	$0

Operation and Maintenance	$0

Total Present Net Worth	$0

Time frame	N/A

Alternative 2 -In-Situ Vapor Extraction and Air
Sparging/MNA/ICs/Vapor Remediation

This alternative would treat contaminated groundwater
in-situ in the Near Field areas, which generally contain
PCE levels of greater than 1,000 ppb, through the use of
the ISVE/AS technologies. ISVE/AS in the Near Field
areas of highest groundwater contamination would
involve the injection of air into the subsurface
groundwater, enabling a phase transfer of VOCs from a
dissolved state to the vapor phase. The contaminated air
enters the unsaturated soils, where a SVE system creates
a negative pressure through a series of extraction wells.
The extraction wells are used to collect the contaminated
air, which is then treated to remove contaminants
through the use of catalytic oxidizers or GAC. BOA has
proposed that this alternative be implemented through
the use of a series of RGRWs, which would apply the
same principals as explained above, but would provide
for both air sparging and ISVE to be implemented within
well casings of a series of wells. Specific details of the
implementation of this technology would be determined
during the RD phase of the project.

During the RD, an evaluation of individual Far Field
"hot spots" for treatment through the ISVE/AS
technology would be performed to assess the
effectiveness of treatment.

MNA would be implemented in the Far Field portion of
the groundwater contaminant plume, concurrent with
ISVE/AS in the Near Field areas. Attenuation processes
for VOCs in groundwater would be closely monitored
concurrent with other aspects of the selected remedy. In
addition, surface water and sediment sampling and
analysis would be included in the long-term monitoring
plan.

A CEA would be established to limit the installation of
additional wells in the area of groundwater
contamination until cleanup standards have been met.

This alternative would address indoor air contamination
by continuing EPA's current program of sampling sub-
slab and indoor air associated with structures overlying
the groundwater contaminant plume. Where elevated
VOC levels are detected, vapor mitigation systems

would be installed and maintained. In addition, systems
already installed at the Site would be maintained until the
groundwater is remediated.

Total Capital Cost	$5.4 million

Operation and Maintenance	$5.4 million

Total Present Net Worth	$10.8 million

Time frame (ISVE/AS)	10 years

Full Groundwater Restoration	Approx. 70 years

Alternative 3 - In-Situ Chemical Oxidation
(ISCO)/MNA/ICs/Vapor Remediation

ISCO would involve injecting an oxidant or oxidant
releasing compound into wells located within the most
highly contaminated groundwater, generally containing
PCE at levels of greater than 1,000 ppb in the Near Field
areas. The oxidant would mix with the contaminants, and
cause them to decompose. When the process is complete,
only water and innocuous breakdown products would be
left in the treated area. Monitoring would be required to
determine the effectiveness of the treatment.

Although final details of the implementation of this
alternative would be developed in the RD phase, for
costing purposes, it was assumed that sodium
permanganate would be the oxidant of choice. Lines of
injection well clusters would be installed perpendicular to
groundwater flow. Each cluster would be comprised of
three wells installed to different depths. It is estimated
that the implementation of this alternative would require
the installation of approximately 40 injection well clusters
near and downgradient of the Sun Cleaners source area
and 19 injection well clusters near and downgradient of
the White Swan source area.

During the RD, an evaluation of individual Far Field "hot
spots" for treatment through the ISCO technology would
be performed to assess the effectiveness of treatment.

MNA would be implemented in the Far Field portion of
the groundwater contaminant plume, concurrent with
ISCO in the Near Field areas. Attenuation processes for
VOCs in groundwater would be closely monitored
concurrent with other aspects of the selected remedy. In
addition, surface water and sediment sampling and
analysis would be included in the long-term monitoring
plan.

A CEA would be established to limit the installation of
additional wells in the area of groundwater contamination
until cleanup standards have been met.

This alternative would address indoor air contamination
by continuing EPA's current program of sampling sub-
slab and indoor air associated with structures overlying the
groundwater contaminant plume. Where elevated VOC

11

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THE NINE SUPERFUND EVALUATION CRITERIA

1.	Overall Protectiveness of Human Health and the
Environment evaluates whether and how an alternative
eliminates, reduces, or controls threats to public health and
the environment through institutional controls,
engineering controls, or treatment.

2.	Compliance with Applicable or Relevant and
Appropriate Requirements (ARARs) evaluates whether
the alternative meets federal and state environmental
statutes, regulations, and other requirements that pertain to
the site, or whether a waiver is justified.

3.	Long-term Effectiveness and Permanence considers
the ability of an alternative to maintain protection of
human health and the environment over time.

4.	Reduction of Toxicity, Mobility, or Volume (TMV)
of Contaminants through Treatment evaluates an
alternative's use of treatment to reduce the harmful effects
of principal contaminants, their ability to move in the
environment, and the amount of contamination present.

5.	Short-term Effectiveness considers the length of time
needed to implement an alternative and the risks the
alternative poses to workers, the community, and the
environment during implementation.

6.	Implementability considers the technical and
administrative feasibility of implementing the alternative,
including factors such as the relative availability of goods
and services.

7.	Cost includes estimated capital and annual operations
and maintenance costs, as well as present worth cost.
Present worth cost is the total cost of an alternative over
time in terms of today's dollar value. Cost estimates are
expected to be accurate within a range of +50 to -30
percent.

8.	State/Support Agency Acceptance considers whether
the State agrees with the EPA's analyses and
recommendations, as described in the RI/FS and Proposed
Plan.

9.	Community Acceptance considers whether the local
community agrees with EPA's analyses and preferred
alternative. Comments received on the Proposed Plan are
an important indicator of community acceptance.

levels are detected, vapor mitigation systems would be
installed and maintained. In addition, systems already
installed at the Site would be maintained until the
groundwater is remediated.

Total Capital Cost
Operation and Maintenance
Total Present Net Worth
Time frame (ISCO)

Full Groundwater Restoration

$7.9 million
$ 3.7 million
$11.6 million
10 years

Approx. 70 years

Alternative 4 - Extraction and
Treatment/MNA/ICs/Vapor Remediation

Alternative 4 would include construction and operation of
a groundwater treatment plant and an extraction well
system to collect and treat contaminated groundwater in
the Near Field areas immediately downgradient from both
source areas. This alternative would target the most
highly contaminated groundwater, generally containing
PCE at levels of greater than 1,000 ppb. It is estimated
that two extraction wells would be required for each
source area and an additional three may be needed to
address downgradient hot spot areas pending further
evaluation in the RD. A groundwater extraction and
treatment system would be constructed and operated for
approximately 30 years. It would consist of groundwater
extraction wells, the associated underground piping and a
treatment plant. The extraction system layouts and flow
rates would be designed to maximize capture of
contaminated groundwater from different areas, then
combined and pumped to a treatment plant.

Treatment of groundwater in the plant would be achieved
by several methods including air stripping and GAC
adsorption units, and the treated water would likely be
discharged to a surface water body such as Judas Creek,
the sanitary sewer system, or re-injected into the aquifer.

During RD, it would be determined if additional
extraction wells would be used to treat hot spots areas
within the Far Field portion of the groundwater plume.

Monitored Natural Attenuation for the Far Field area of
the plume would be the same as discussed above for
Alternatives 2 and 3.

A CEA would be established to limit the installation of
additional wells in the area of groundwater contamination
until cleanup standards have been met.

This alternative would address indoor air contamination
by continuing EPA's current program of sampling sub-
slab and indoor air associated with structures overlying the
groundwater contaminant plume. Where elevated VOC
levels are detected, vapor mitigation systems would be
installed and maintained. In addition, systems already
installed at the Site would be maintained until the
groundwater is remediated.

Total Capital Cost
Operation and Maintenance
Total Present Net Worth

12

$7.3 million
$6.2 million
$13.5 million

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Time frame (Pump &Treat) 30 years

Full Groundwater Restoration Approx. 70 years

EVALUATION OF REMEDIAL ALTERNATIVES

Nine criteria are used to evaluate the different remedial
alternatives individually and against each other in order
to select the best alternative. This section of the
Proposed Plan profiles the relative performance of each
alternative against the nine criteria, noting how it
compares to the other options under consideration. The
nine evaluation criteria are discussed below. A more
detailed analysis can be found in the FS.

Overall Protection of Human Health and the
Environment

The No Action Alternatives for soil and groundwater are
not protective of human health and the environment.

While source area soils do not pose a direct risk to
human health, they contribute to groundwater
contamination at the Site, which poses unacceptable
levels of risk to human health. Under the No Action
alternative, VOC contamination in soils would continue
to migrate to groundwater. Groundwater contamination
would continue to migrate uncontrolled, where it may
continue to impact human health and the environment.

All other soil alternatives provide adequate protection of
human health and the environment and are expected to
comply with ARARs.

All groundwater alternatives (other than No Action) are
considered protective. They all include treatment of the
Site's most highly contaminated groundwater, and
include MNA, institutional controls, and appropriate
indoor air mitigation to minimize potential exposure to
contaminated groundwater and vapors emanating from
groundwater until the alternatives are implemented, and
remediation goals have been achieved.

Compliance with Applicable or Relevant and
Appropriate Requirements (ARARs)

The three broad categories of ARARs include chemical-
specific, location-specific and action-specific ARARs.
ARARs have been established for groundwater at this
Site to restore the aquifer to drinking water standards.

No soil ARARs are required to protect against direct
contact with Site soils, as this exposure does not pose
unacceptable risks. However, modeling was performed
to develop a soil cleanup standard for PCE, the primary
contaminant of concern that would be protective of
groundwater. The soil cleanup standard for PCE is 1
part per million (ppm). All soil remediation alternatives,
except the No Action alternative, would meet this
standard eventually. The No Action alternative would

13

not meet standards in a reasonable time frame. Of the two
active remediation technologies, excavation would
achieve soil ARARs more quickly, in 1 year, and ISVE
would take approximately 10 years. The ISVE and
excavation technologies would also comply with location-
and action-specific ARARs such as the Resource
Conservation and Recovery Act.

All of the groundwater alternatives would eventually meet
the groundwater ARARs. The primary contaminant of
concern, PCE, has a NJ GWQC of 1 ppb. The No Action
Alternative would not meet ARARs in a reasonable time
frame, and would not assure that residential drinking
water standards are met in the short term. The alternatives
which include active treatment (Alternatives 2, 3 and 4)
would assure that potable water met the chemical-specific
ARAR for PCE in a much shorter time frame compared to
the No Action alternative. All alternatives would comply
with location- and action-specific ARARs such as the
Freshwater Wetlands Protection Act and the Federal Clean
Water Act.

MNA is a component of each alternative, with the
exception of the No Action alternative. MNA would be
used to address lesser contaminated groundwater in the
Far Field area of the Site. With the performance of an
active remediation of the most contaminated groundwater
in the Near Field, modeling has shown that Far Field
groundwater would be restored to drinking water
standards in a much shorter time frame than without
remediation (roughly 70 years vs. 400 years).

Each alternative, with the exception of the No Action
alternative, includes ongoing indoor air sampling and
installation of remediation systems within buildings to
prevent exposure to unacceptable levels of PCE in indoor
air.

Long-Term Effectiveness and Permanence

The highest degree of permanence and long term
effectiveness is achieved for those alternatives that result
in a greatest removal of contaminants from the Site. The
No Action Alternative would not be effective in the long
term because no actions will be taken to address the
contamination. Some attenuation of contaminants can be
expected over time, but this would not be measured or
monitored under Alternative 1.

For soil, Alternative 2, ISVE/AS, would be effective for
removal of soil contamination in the source area. Since it
is expected that the full remediation would take place
within 10 years, it would be both effective in the long term
and permanent. The magnitude of risk remaining after
implementation of ISVE/AS or excavation for soil
contamination would be similar. ISVE/AS (Alternatives 2
and 4) would achieve contaminant reductions through in-

-------
situ treatment, while excavation (Alternatives and 3 and
4) would rely on physical removal of the contaminated
material. ISVE/AS is estimated to require active
treatment operations for up to 10 years, compared to 1
year for excavation. Excavation would have a higher
degree of certainty of reduction of contaminants since all
contaminated material would be physically removed.
ISVE/AS is expected to be effective at reducing
contamination, but since it is an in-situ technology, it
may not achieve 100% removal of VOCs, as would be
achieved by excavation.

For groundwater, active treatment in the Near Field areas
under consideration would include ISVE/AS
(Alternative 2), ISCO (Alternative 3), or extraction and
treatment (Alternative 4). In comparing these
alternatives, Alternatives 2 and 4 would likely have
similarly high degrees of long-term effectiveness.
Alternative 3, ISCO, could be effective in the long term,
but would be more difficult to implement and manage,
leading to more uncertainty with respect to its long-term
effectiveness compared to Alternatives 2 and 4.

Reduction of Toxicity, Mobility, or Volume Through
Treatment

The No Action Alternatives for both soil and
groundwater would not treat the contaminants and would
not reduce their toxicity, mobility, or volume through
treatment.

For soils, Alternative 2, ISVE/AS would reduce the
volume of the majority of the VOC contaminants in the
soils (estimated at 99% removal) through treatment,
thereby greatly reducing the volume of the contaminants.
Alternative 3, excavation, would remove 100% of the
volume of contaminants, but is not likely to include
treatment in that the excavated soils would likely be
disposed at an off-Site, licensed landfill. Alternative 4
would be effective in reducing toxicity, mobility and
volume through treatment at the Sun Cleaners property.
As stated, excavated soil from the White Swan Cleaners
property may not require treatment at a waste disposal
facility.

For groundwater, Alternative 2 (ISVE/AS), Alternative 3
(ISCO), and Alternative 4 (extraction and treatment)
would all reduce the toxicity, mobility and volume of
groundwater contaminants using different treatment
technologies in the Near Field. ISCO would
permanently destroy contaminants in-situ. ISVE/AS and
extraction and treatment would remove contaminants in
the groundwater and then treat the contaminants in the
air or groundwater stream generated respectively.

14

Short-Term Effectiveness

The No Action Alternatives for soil and groundwater
include no construction or monitoring, and would have no
short-term impacts at the Site.

In addressing contaminated soils, Alternatives 2, 3, and 4
would all have some short-term impacts on workers and
the local community, as the source areas to be remediated
are located in a highly developed commercial area, near
residential communities. Potential risks would include
physical hazards near areas where heavy equipment is
used and from increased vehicles traffic, and noise, air
emissions, and hazards resulting from managing
contaminated soils. These short-term risks can be
managed through appropriate planning and monitoring
during the construction. Air emissions generated during
the ISVE/AS operations can be controlled and monitored.
Disruption to the community would be relatively lower for
ISVE/AS (Alternatives 2 and 4) compared to excavation
(Alternatives 3 and 4), as excavation would require the
transportation of contaminated soils from the source areas
via existing roadways. However, ISVE/AS would require
about 5 months to construct, and 10 years to operate
intermittently, while excavation would take about 1 year
to implement.

For the groundwater alternatives, Alternatives 2
(ISVE/AS), Alternative 3 (ISCO), and Alternative 4
(groundwater extraction and treatment), a number of
short-term risks are possible including, physical hazards,
noise, traffic near areas requiring heavy equipment for
construction, emissions and dust. Additional significant
short-term risks would be presented under Alternative 3
(ISCO), as this alternative would require handling and
storage of a chemical oxidant in a densely populated
residential community. The oxidant would need to be
carefully managed. In addition, Alternative 3 (ISCO)
would also have the potential to increase contaminated
vapors in residential areas. Careful monitoring and
management of vapors would be required to protect public
health. All of the three active groundwater alternatives
would present some disruption of the community;
however, Alternative 3 would require the most disruption
of private property and is the least effective in the short-
term.

Implementability

The No Action Alternatives for soil and groundwater
require no implementation.

For soils, each alternative considered would be technically
implementable and uses proven, readily available
technologies. A pilot study would be needed prior to the
design of the remedy under Alternative 2 (ISVE/AS).
Alternative 3 (Excavation) would be significantly more
difficult to implement at the Sun Cleaners source area

-------
compared to the White Swan source area for a number of
reasons. The topography of the Sun Cleaners property
includes a substantial steep slope, which may require
specialized equipment to assure a safe exaction. In
addition, the Sun Cleaners property is located on a
highly congested traffic circle, which would require
significant rerouting of traffic and disruption to the
community. The White Swan property by comparison,
would be easier to excavate as it is relatively level and
located on a less traveled road. In addition, the
excavation alternative would remove significantly more
mass from the White Swan property compared to the
Sun Cleaners property (4,360 pounds of PCE mass at
White Swan vs. 140 pounds of PCE mass at Sun
Cleaners).

For groundwater, each technology considered is
technically implementable, proven and readily available.
Issues required to implement all alternatives include
acquisition of land, subsurface work within local streets
and private property for installing system components.
Alternative 2 (ISVE/AS) and Alternative 3 (ISCO)
would have the greatest amount of infrastructure
required on private property compared to Alternative 4
(extraction and treatment). For this reason, these
alternatives would be more disruptive to the community
during construction and operation compared with
Alternative 4.

Alternative 2 (ISVE/AS) would require regular
maintenance to prevent metals fouling in the system.
Alternative 3 (ISCO) would present safety hazards
associated with the storage and handling of chemical
oxidants in residential areas. Further generation of
contaminated vapors could be exacerbated through the
implementation of ISCO and indoor air would need to be
closely monitored.

Cost

There are no costs associated with the No Action
Alternatives for soil and groundwater; however, it would
provide no protection to human health or the
environment. The following chart summaries the costs
for rest of the remedial alternatives.

Ground
water

WS&
Sun

2-ISVE/
MNA

5.4

5.4

10.8

Ground
water

WS&
Sun

3-I SCO/
MNA

7.9

3.7

11.6

Ground
water

WS&
Sun

4-P&T/
MNA

7.3

6.2

13.5

State/Support Agency Acceptance

The State of New Jersey agrees with the preferred
alternative in this Proposed Plan.

Community Acceptance

The community's opinion of the preferred alternative will
be evaluated after the public comment period ends and
will be described in the Responsiveness Summary of the
Record of Decision. The Record of Decision is the
document that formalizes the selection of the remedy for a
site.

SUMMARY OF THE PREFERRED ALTERNATIVE

The preferred alternative for the White Swan
Cleaners/Sun Cleaners Area Groundwater Contamination
Site is Alternative 4 for source soils and Alternative 4 for
groundwater. Alternative 4 for soils would include the
ISVE/AS technology to treat soils and associated
groundwater at the Sun Cleaners source area and
excavation and off-site disposal for soils at the White
Swan source area. Demolition and disposal of the bank
building may be necessary. Alternative 4 for groundwater
would include: the extraction and treatment of the most
highly contaminated groundwater in the Near Field
portion of the groundwater plume; MNA for lesser
contaminated groundwater in the Far Field portion of the
groundwater plume, ongoing sub-slab and indoor air
investigation and remediation, and ICs.

ISVE/AS would be implemented for soils at the Sun
Cleaners source area and excavation would be
implemented for soils at the White Swan source area.

Soils located above the water table, as well as soils below
the water table would be addressed, as these are principal
threat wastes. A Site-specific soil cleanup goal of 1 ppm
for PCE has been developed and would be protective of
groundwater. Addressing soils to meet this cleanup
standard is expected to address all Site contaminants.

After completion of soil remediation activities, both
properties containing contaminated soils would be
restored and could be redeveloped.

The most highly contaminated groundwater at the Site, in
the Near Field area, would be remediated through
extraction and treatment. Extraction wells would be
located adjacent to and downgradient the source areas to
address the Site's most highly contaminated groundwater.

Media

Source
Area

Alternative

Capital

Cost

$M

O&M
$M

Present

Worth

$M

soil

WS&
Sun

2-ISVE

1.8

1.8

3.6

soil

WS&
Sun

3-

Excavation

8.0

8.0

soil

WS
and
Sun

4-ISVE for
Sun

Excavation
for WS

4.5

0.9

5.4

15

-------
The groundwater treatment plant would treat the
groundwater by removing the PCE and TCE using air
strippers and activated carbon. The treated groundwater
would be discharged to either to the local
sewer/treatment facility, surface water or re-injected into
the aquifer. Areas of elevated groundwater
contamination (hot spots) in the Far Field area of the Site
would be further evaluated and may be addressed
through either the groundwater extraction and treatment
system, or smaller localized treatment systems.
Determinations regarding whether to address these hot
spots will be made during the RD.

Lesser contaminated groundwater would be addressed
through MNA. Attenuation processes for VOCs in
groundwater would be closely monitored concurrent
with other aspects of the selected remedy. Sediments
would continue to be monitored to evaluate the impact
of the remedy over time.

Indoor air contamination would be addressed by
continuing EPA's current program of sampling sub-slab
and indoor air associated with structures overlying the
groundwater contaminant plume. Where elevated VOC
levels are detected, vapor mitigation systems would be
installed and maintained. In addition, systems already
installed at the Site would be maintained until the
groundwater is remediated.

The preferred alternative would prevent exposure to Site
contaminants by addressing indoor air contamination as
described above, and through the implementation of ICs,
such as a CEA, until the aquifer is restored to drinking
water standards. The total cost of the preferred
alternative to address all Site contamination is estimated
to be $18.9 million.

As is EPA's policy, five-year reviews would be
conducted until remediation goals have been met.

The preferred alternative was selected over the other
alternatives principally because it is expected to achieve
substantial long-term risk reduction through treatment of
the principal threat waste, as well as the most highly
contaminated groundwater contamination.

Based on information currently available, EPA believes
the preferred alternative is protective of human health
and the environment, complies with ARARs and
provides the best balance of tradeoffs among the other
alternatives with respect to the Superfund evaluation
criteria. EPA expects the preferred alternative will
satisfy the statutory requirements of CERCLA Section
1212(b).

Consistent with EPA Region 2's Clean and Green
policy, EPA will evaluate the use of sustainable

16

technologies and practices with respect to any remedial
alternative selected for the Site.

COMMUNITY PARTICIPATION

EPA provided information regarding the cleanup of the
White Swan/Sun Cleaners Superfund Site to the public
through public meetings, the Administrative Record file
for the Site and announcements published in the Coast
Star newspaper. EPA encourages the public to gain a
more comprehensive understanding of the Site and the
Superfund activities that have been conducted there.

For further information on EPA's preferred alternative for
the White Swan/Sun Cleaners Superfund Site, please
contact:

Matthew Westgate	Cecilia Echols

Remedial Project Manager Community Relations
(212) 637-4422	(212) 637-3678

U.S. EPA
290 Broadway, 19th Floor
New York, New York 10007-1866

The dates for the public comment period; the date, the
location and time of the public meeting; and the locations
of the Administrative Record files are provided on the
front page of this Proposed Plan.

-------
GLOSSARY

ARARs: Applicable or Relevant and Appropriate Requirements. These are Federal or State environmental rules and regulations
that may pertain to the Site or a particular alternative.

Carcinogenic Risk: Cancer risks are expressed as a number reflecting the increased chance that a person will develop cancer if
exposed to chemicals or substances. For example, EPA's acceptable risk range for Superfund hazardous waste sites is 1 x 10"4 to 1 x
10"6, meaning there is 1 additional chance in 10,000 (1 x 10"4) to 1 additional chance in 1 million (1 x 10"6) that a person will
develop cancer if exposed to a Site contaminant that is not remediated.

CERCLA: Comprehensive Environmental Response, Compensation and Liability Act. A Federal law, commonly referred to as the
"Superfund" Program, passed in 1980 that provides for response actions at sites found to be contaminated with hazardous
substances, pollutants or contaminants that endanger public health and safety or the environment.

COPC: Chemicals of Potential Concern.

SLERA: Screening Level Ecological Risk Assessment. An evaluation of the potential risk posed to the environment if remedial
activities are not performed at the Site.

FS: Feasibility Study. Analysis of the practicability of multiple remedial action options for the Site.

Groundwater: Subsurface water that occurs in soils and geologic formations that are fully saturated.

HHRA: Human Health Risk Assessment. An evaluation of the risk posed to human health should remedial activities not be
implemented.

HI: Hazard Index. A number indicative of noncarcinogenic health effects that is the ratio of the existing level of exposure to an
acceptable level of exposure. A value equal to or less than one indicates that the human population is not likely to experience
adverse effects.

HQ: Hazard Quotient. HQs are used to evaluate noncarcinogenic health effects and ecological risks. A value equal to or less than
one indicates that the human or ecological population are not likely to experience adverse effects.

ICs: Institutional Controls. Administrative methods to prevent human exposure to contaminants, such as by restricting the use of
groundwater for drinking water purposes.

Nine Evaluation Criteria: See text box on Page 12.

Noncarcinogenic Risk: Noncancer Hazards (or risk) are expressed as a quotient that compares the existing level of exposure to the
acceptable level of exposure. There is a level of exposure (the reference dose) below which it is unlikely for even a sensitive
population to experience adverse health effects. USEPA's threshold level for noncarcinogenic risk at Superfund sites is 1, meaning
that if the exposure exceeds the threshold; there may be a concern for potential noncancer effects.

NPL: National Priorities List. A list developed by USEPA of uncontrolled hazardous substance release sites in the United States
that are considered priorities for long-term remedial evaluation and response.

17

-------
Operable Unit (OU): a discrete action that comprises an incremental step toward comprehensively addressing site
problems. This discrete portion of a remedial response manages migration, or eliminates or mitigates a release, threat of
a release, or pathway of exposure. The cleanup of a site can be divided into a number of operable units, depending on
the complexity of the problems associated with the site.

Practical Quantitation Level (PQL): means the lowest concentration of a constituent that can be reliably achieved among
laboratories within specified limits of precision and accuracy during routine laboratory operating conditions.

Present-Worth Cost: Total cost, in current dollars, of the remedial action. The present-worth cost includes capital costs required to
implement the remedial action, as well as the cost of long-term operations, maintenance, and monitoring.

Proposed Plan: A document that presents the preferred remedial alternative and requests public input regarding the proposed
cleanup alternative.

Public Comment Period: The time allowed for the members of a potentially affected community to express views and concerns
regarding USEPA's preferred remedial alternative.

RAOs: Remedial Action Objectives. Objectives of remedial actions that are developed based on contaminated media, contaminants
of concern, potential receptors and exposure scenarios, human health and ecological risk assessment, and attainment of regulatory
cleanup levels.

Record of Decision (ROD): A legal document that describes the cleanup action or remedy selected for a site, the basis for choosing
that remedy, and public comments on the selected remedy.

Remedial Action: A cleanup to address hazardous substances at a site.

RI: Remedial Investigation. A study of a facility that supports the selection of a remedy where hazardous substances have been
disposed or released. The RI identifies the nature and extent of contamination at the facility and analyzes risk associated with
COPCs.

Saturated Soils: Soils that are found below the Water Table. These soils stay wet.

TBCs: "To-be-considereds," consists of non-promulgated advisories and/or guidance that were developed by EPA, other federal
agencies, or states that may be useful in developing CERCLA remedies.

Unsaturated Soils: Soils that are found above the Water Table. Rain or surface water passes through these soils. These soils
remain dry:

USEPA: United States Environmental Protection Agency. The Federal agency responsible for administration and enforcement of
CERCLA (and other environmental statutes and regulations), and final approval authority for the selected ROD.

VOC: Volatile Organic Compound. Type of chemical that readily vaporizes, often producing a distinguishable odor.

Water Table: The water table is an imaginary line marking the top of the water-saturated area within a rock column.

18

-------
NORTH

SUN
PROPERTY

Wall Towns hi

Spring Lake
Borough

FIGURE 1
EXTENT OF PCE IN GROUND WATER

PROPOSED PLAN

WHITE SWAN CLEANERS / SUN CLEANERS
AREA GROUND WATER CONTAMINATION
SUPERFUND8ITE

JULY 2013

^ 000 PCE CONCENTRATION
IN PARTS PER 3JLLION

CONTOUR REPRESENTS HIGHEST
CONCENTRATION OF PCE IN GROUND
WATER AT ANY GEOGRAPHIC POINT

LOCAL ZED AREAS OF ELEVATED
PCE CONCENTRATION

Wanasquar
Borough

19

-------
APPENDIX III
Attachment B

Public Notice Tear Sheets

-------
Page AS Tuesday, Aug. 20, 2013

Asbury Park Press APP.COM

from

page one

Task force emphasizes natural defenses

Recommendations stress need
to respond to climate change

By Ken Serrano

@KenSerranoAPP

Superstorm Sandy
didn't just strafe the
coastline with damage
and suffering and wreak
havoc on the economies of
New York and New Jer-
sey.

It also brought the cost
of climate change into
clearer focus.

That was the premise
of a federal report that is-
sued recommendations
on how to deal with future
storms based on the les-
sons learned from this
one.

The Hurricane Sandy
Rebuilding Task Force
makes 69 recommenda-
tions, most of them craft-
ed in the sort of policy lan-
guage only wonks could
appreciate. The report is
heavy on touting the re-
sponse to the storm, espe-
cially President Barack
Obama's role.

But investment in re-
silience is a constant
theme:

"For every $1 we put
into resilience and mitiga-
tion, we save $4 down the
road," said Shaun Dono-

van, secretary of the U.S.
Department of Housing
and Urban Development,
in a conference call with
reporters. The recom-
mendations range from
from holding a contest for
architects, engineers, art-
ists, planners and envi-
ronmentalists on finding
smart designs to funnel-
ing federal money to pro-
jects using cutting-edge
science.

Many of the recom-
mendations have already
been carried out, Dono-
van said.

Rules relaxed

HUD's relaxation of
rules that prohibited New
Jersey grant money for
repairing and elevating
homes going toward reim-
bursement of those with
more than 50 percent
damage was one of the ex-
amples he cited in how the
task force has worked on
one recommendation: cut-
ting red tape.

When Obama set up the
task force in December,
he charged it with "identi-
fying and working to re-
move obstacles to resil-

A Jersey Central Power & Light Co. worker tends to
downed power lines caused by Superstorm Sandy in
Asbury Park, newjersey press media file

ient rebuilding while tak-
ing into account existing
and future risks and pro-
moting the long-term sus-
tainability of communi-
ties and ecosystems in the
Sandy-affected region."

Among the 69 recom-
mendations, the task
force report stresses the
importance of green in-
frastructure, natural sys-
tems or engineered sys-
tems that mimic nature
over purely manmade so-
lutions, This isn't a new di-
rection. The U.S. Environ-
mental Protection Agen-
cy has been pushing green

RECOMMENDED BY THE SANDY
REBUILDING TASK FORCE

» Strengthen liquid fuel supply chain.

» Tighten electric grid policies for dealing with storms.

» Find ways to back up wireless and data communications.

» Incorporate future sea-level rise in rebuilding standards
through flood-risk tools.

» Favor green infrastructure, like dunes over seawalls.

Source: Hurricane Sandy Rebuilding Task Force

infrastructure.

"It doesn't mean sea-
walls; it means dunes,"
said Jeff Tittel, director
of the NJ Chapter of the
Sierra Club, "It doesn't
mean retention basins; it
means restoring wet-
lands."

The report cited the ex-
ample of oyster reefs es-
tablished a few years ago
in Alligator River Nation-
al Wildlife Refuge in
North Carolina. The reefs
absorbed the energy from
Sandy-generated waves
and slowed erosion there,
the report said.

Tittel welcomed the re-
port. But he said the big
question isn't so much
what needs to be done but
whether it will be carried
out. "A report without im-
plementation is hallucina-
tion," he said.

Donovan said there's
interest at the local level
in things like using the
best available science to
plot future planning. It's
just a matter of getting
the information to towns
and businesses, he
said."We see that sort of
hunger in the public and
private sector," he said.

But some of the recom-
mendations are going to
take legislative action to
put in place, he said.

The report also recom-
mends tuning up the elec-
tric grid with a new ap-
proach to operations, by

using smart grid technol-
ogy, microgrids (small, in-
dependent grids that can
act like a contained sys-
tem), building controls
and distributed energy.

"This approach would
ensure that problems can
be isolated, surviving
generation can be opti-
mally dispatched (with
priority to essential ser-
vices), and that degrada-
tion can be graceful and
not catastrophic," the re-
port reads. "This ap-
proach would allow build-
ing controls to provide a
minimal level of service
such as basic lights and
refrigeration during
emergencies."

Ken Serrano:
732-643-4029; kserrano
@njpressmedia.com

DEMOLISH

Continued from Page A1

throughout Keansburg,
said Francis Mullan, the
borough's engineer.

Already, the Federal
Emergency Management
Agency has approved
funding for 44 properties,
of which 21 have all the
necessary permits, Mul-
lan said. Of the 21, the
owners of 19 plan to re-
build, he said.

"Keansburg plans to
rebuild intelligently —
the real mission is to save
the next generation," said
Mullan, a vice president
at Middletown's T&M As-
sociates.

FEMA will pay for 90
percent of the cost of de-
molishing a house, haul-
ing away the debris and
dumping it in a landfill,
said Ginger Rogan, depu-

Edward Harper's family moved into this Keansburg home in 1941. Badly damaged during
Sandy, wreckers demolish it on Monday, tanya breen/staff photographer

ty coordinator of Keans-
burg's Office of Emergen-
cy Management.

While Keansburg is re-

sponsible for the balance,
the municipality plans to
pay for the bulk of its
share through contribu-

tions from charities such
as the Robin Hood Foun-
dation, Holmdel Helps
and Rebuild Restore, Ro-

Share the
Happiness of

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To place your announcement visit
NJPressMedia.com/celebrations

"Sandy might've
done my house,
but it didn't do
me."

EDWARD HARPER,

Keansburg, who plans to
rebuild

gan said.

Property owners are
responsible for the cost of
removing asbestos from
the structures and for lay-
ing topsoil on the lot once
the demolition is com-
plete, Mullan said.

"This will take a big
burden off the financial
impact for the property
owners," Mayor Artie Bo-
den said. "Unfortunately,
it still will end up being a
long rebuilding process."

Harper said he, his
wife Elaine Harper, and
his daughter, Karen Har-
per, have been staying
with family during the
process. He plans to re-
build at the same site, al-
though likely a one-story
home instead of the two-
story with the attic that he
moved into in 1941.

"Sandy might've done
my house, but it didn't do
me," Harper said.

As the end of the bull-
dozer cracked through
the house, it exposed vari-
ous items left behind — a
grandchild's booster
chair, a scooter. As the
floor gave way beneath a
cardboard box, a flash of
colorful items tumbled
onto the mound of debris
below it.

Across the street from
the house, Harper's
daughter, Cheryl Stavit-
skie, softly patted her fa-
ther on his lower back. He
put his arm around her
shoulders and shook his
head, breathing out audi-
bly.

"Half the people in
Keansburg have been in
that backyard," said Sta-
vitskie, 39, who grew up in
the house and now lives in
Middletown. "Everybody
always came to the Har-
per house to hang out."

Kevin Penton:
732-643-4009; kpenton
@njpressmedia.com

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facehook.

U. S. Environmental Protection Agency invites public comment on a
taw? proposed plan for cleanup of the White Swan Cleaners/Sun Cleaners
Area Groundwater Contamination Superfund Site, within Wall
Township, Manasquan, and Sea Girt, New Jersey

The U.S. Environmental Protection Agency (EPA) announces the opening of a 30-day
public comment period on the cleanup proposal to address on-site soil and groundwater
contaminated with Tetrachloroethylene (PCE) at the White Swan Cleaners/Sun Cleaners
Area Groundwater Contamination Superfund Site in Wall Township, Manasquan and Sea
Girt, NJ.

Public comment on the preferred cleanup plan, and other cleanup alternatives that were
considered, begins on August 20, 2013 and ends on September 19, 2013. The EPA
encourages the public to attend a public meeting on Tuesday, August 27, 2013 at 7 p.m.
at the Wall Township Municipal Center, Main Meeting Room at 2700 Allaire Road, Wall,
NJ 07719.

The Proposed Plan is available at http://www.eDa.aov/reaion2/superfund/nDl/whiteswan/
or by calling Cecilia Echols, EPA's Community Involvement Coordinator, at (212) 637-
3678 and requesting a copy by mail.

Written comments on the Proposed Plan, postmarked no later than September 19, 2013
may be mailed to Matthew Westgate, EPA Project Manager, at U.S. EPA, 290 Broadway,
19® Floor, New York, NY 10007-1866, or e-mailed no later than September 19, 2013 to
Westgate.Matthew@epa.gov

The Administrative Record file, containing the documents used or relied on in developing
the alternatives and preferred cleanup plan, is available for public review at the following
information repositories:

Wall Township Public Library Reference Section located at 2700 Allaire Road, Wall, NJ
07719

U.S. EPA Region 2, Superfund Records Center, 290 Broadway, 18th Floor, New York,
NY 10007-1866 (212) 637-4308, Mon. - Fri., 9am - 5pm

-------
PAGE 38 THE COAST STAR THURSDAY, AUGUST 22, 2013

BRADLEY BEACH

License debated

BOROUGH

FROM PAGE 37

with inquiries from the audi-
ence as to how many in each
unit.

"One person for the four
units," Mr. Bisgaier stated.
Many residents stated they
felt this was not acceptable.
The applicant has proposed
unit one to house 12 occu-
pants; unit two, 7; unit three,
12; and unit four, 7; for a total
of 38 tenants.

Several residents and
council members Sal Galas-
setti and Norman Goldfarb
stated the property owner
was pricing the units too
high, and instead of lowering
the price to meet market de-
mand, was unfairly burden-
ing the borough with another
undesirable property.

"It's not fair to the borough
to change the use because the
condos won't sell. [...] As long
as I'm sitting here, I will nev-
er go for that," Councilman
Galassetti said. The audience
applauded and cheered.

"We [the planning board]
worked tirelessly with this
builder and for him to do the

ST, JUDE
NOVENA

May the Sacred Heart of Jesus be
adored, glorified, loved and pre-
served throughout the world,
now and forever. Sacred Heart of
Jesus, pray for us. St. Jude, work-
er of miracles, pray for us. St.
Jude, help of the hopeless, pray
for us. Say this prayer 9 times a
day. Say it for 9 days. By the
eighth day, your prayer will be
answered. It has never been
known to fail. Publication must
be promised. Thank yous St.
Jude. W.F.

bait and switch just sickens
me," Mayor Engelstad said.

There are currently three
facilities in the borough of
similar purpose called Ox-
ford Houses, which are pub-
licly funded "democratically
run, self-supporting and drug
free homes." They are locat-
ed at 601 Ocean Park Ave.,
300 Third Ave., and 404
Newark Ave., according to
the organization's directory
on its website, www.oxford-
house.org.

"Ocean Grove and Asbury
Park went downhill because
of all the halfway houses,"
Gloria Gilhooly, of Ocean
Park Avenue, said.

Harvey Rosenberg, chair-
man of the joint subcommit-
tee of the planning and zon-
ing boards, said the borough
had to stand up as a commu-
nity against a builder "being
greedy at the wrong time."

"The builder supposedly
lived there with his brother
as resident for two years,"
and is now trying to change
the use, Mr. Rosenberg said.

"Thank you all for coming
here and taking an interest,"
Councilman Pat D'Angelo
said.

The council was able to
deny the automatic renewal
of the group rental license on
Tuesday evening, but it will
have to abide by the advise of
the DCA as to whether it
must accept the group recov-
ery home as a permitted use
under that license — or
change the group rental li-
cense ordinance.

Brianna Townsend covers Bradley
Beach for The Coast Star. She can be
reached at

btownsend@thecoaststar.com or 732-
223-0076 Ext 26.

SUEANNE GOSS THEC0AST STAR

ONE SIZE-3 FOOT IN FRONT OF THE OTHER

Children up to 12-years-old hit the pavement as participants in the annual Bradley Beach Kids' 5K run this past Friday evening. The
race took off from the corner of Bradley Boulevard and Evergreen Avenue when Mayor Gary Engelstad sounded the starting bell.

Board appoints new member

BY AMANDA STONE

THE COAST STAR

BRADLEY BEACH — The

Bradley Beach Board of Edu-
cation welcomed its newest
member at its meeting Tues-
day night.

Margaret Merenda was
unanimously approved to
serve on the board and sub-
sequently sworn in during
this week's meeting.

Ms. Merenda will be fill-
ing the unexpired term of

former board member Bar-
bara Feeley. The term is
scheduled to expire in De-
cember 2013.

Ms. Merenda was the sole
candidate to run for the va-
cant position.

The seat became vacant in
June following the resigna-
tion of former board mem-
ber Barbara Feeley.

"We knew this was com-
ing because her house was
for sale," Todd Migdon,
board president, had said,

noting she will be missed.

Ms. Feeley had served on
the board since 2006, when
she was appointed to fill a
vacant seat on the board in
February. She ran in April
2006 to fill an unexpired
term, and ran again in 2011.

There is one year left on
Ms. Feeley's term.

Those interested in run-
ning for Ms. Feeley's one-
year, unexpired seat are
required to file with the
Monmouth County Office of

the County Clerk Election
Division by Sept. 12 to run in
the school board election in
November.

Board president Todd
Migdon congratulated Ms.
Merenda.

"Welcome to the team,"
Mr. Migdon said.

Amanda Stone reports for The Coast
Star. She can be reached at
astone@thecoaststar.com or 732-
223-0076 Ext 23.

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"jl	U- S. Environmental Protection Agency invites public comment on a

;	i	P'opastwi 'or ctwrnup of Itm White Swort Cleonfir&'Sun Claoriers Aioo

\ ^mr- ~5	Groundwater Contamination Superfund Site, within Wall Townsbip,

"1f<<	Mnnasquan, and Soa Girt. Now Jersey

Tha U.S. Environmental Protection Agency (EPA) announces tha opening oi a 30-day public
comment period on tha cleanup proposal to address on-site soli and greundivalar contaminated
yvrth TgtraichlOioethytene (PCE) at ihe While Swan Cteanere/Sw Cleaners Area Grounctwa?r> Wall Township Manasquan and Sea Girt, NJ

Public corr.rr>ent on tha preiened cleanup plan, ana other cleanup alternatives that ware
considered ends on September 19, 2013 "he EPA encswrages ttie puWle to attend a pisbl'C
meeting on "uasday, August 27, 2013 at 7 p.m. at (he Wall Township Municipal Caniar, Main
Meeting Room al 2700 Allaire Head Wall NJ 07719

Tha Proposed Plan la available at httn tfwtw ¦»pa.aaWregion2i'suparfundMplA'vhitgs-.yarv' or by
caHing Cecilia Echols, EPA'5 Community Involvement Coordinator, at (212) 637-3673 and
requesting a copy by mall

Written comments on the Proposed Plan, postmarked no later than September IS, .2013 may be
mmted to Matthew Westgste. EPA Prejed Manager, af US EPA. 290 Broadway. 1 Floor
New York, NY 10007-1966, ot a-mailed no later than September 10, 2013 to
Wastgale Matt spa gov

Tlte AdmintslratlRecord lila. containing tus documents used at tel.Mi on in d«vs|op«t\g (he
alternatives arid preferred daanup plan, is available for puMic 'Oviow at tha following
inform atiem repositories

WaH Township FurXic Library Ptetereoc® Sad'On located al 27Q0 Ailane Road Wall. NJ 07719

U.S. EPA Region 2 Suparfurnl Records Center, 2SO Broadway, 16T' Floor New York, MY
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-------
APPENDIX III
Attachment C

Public Meeting Transcript

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 2

------------------------ - -x

WHITE SWAN CLEANERS/SUN CLEANERS AREA

GROUNDWATER CONTAMINATION SUPERFUND SITE

PUBLIC MEETING

------------------------ - -x

Wall Township Municipal Center
2700 Allaire Road
Wall, New Jersey-

August 27, 2013
7:06 p.m.

PRESENT:

CECILIA ECHOLS,

EPA Community Involvement Coordinator

CHLOE METZ,

EPA Risk Assessor

KIM O'CONNELL,

EPA Southern New Jersey Section Chief

STEPHEN POSTEN,
AMEC, Inc.

MATTHEW WESTGATE,

EPA Remedial Project Manager

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MR. WESTGATE: If everyone
could please have a seat, we'd
like to get started. We have a
lot of material to cover.

MS. ECHOLS: Good evening,
everyone. Thank you so much for
coming out tonight.

We are here -- well, first
of all, I'm Cecilia Echols, the
Community Involvement Coordinator
for the White Swan Cleaners/Sun
Cleaners Groundwater Contamination
Superfund Site.

On our agenda, we have a few
speakers and they are Matthew
Westgate, EPA Project Manager; Kim
O'Connell, EPA -- let me see,

Southern New Jersey Remediation
Section Chief; Chloe Metz, EPA
Risk Assessor; and Steven Posten,

AMEC, Inc., and you are over
there.

The purpose of the meeting
tonight is to discuss and receive
public comment on the site's

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proposed cleanup plan.

Please come in. There are
many seats. If you all want to
shift over a little bit, let those
that come in a little after, that
will be fine.

The plan addresses soil and
contaminated groundwater in the
area downgradient of the site.

The site is located within Wall
Township, Sea Girt, Manasquan, in
Monmouth County.

Community Involvement is a
program which seeks community
input in cleaning up Superfund
sites, and that's why we're here
tonight.

The public comment period
began on September -- I'm sorry,
the public comment period began on
August 20 and ends September 19.

Close to one thousand
postcards were sent to residents
or business owners within these
several communities. There was a

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public notice placed in the Asbury
Park Press, along with the Coast
Star on August 20.

You'll see the presentation
through the Powerpoint
presentation, which is on our site
web page. All of the documents
related to the site are at the
Wall Township Public Library.

I hope everyone signed in
today so you can be included on
the mailing list. Your name may
already be there -- we'll be able
to check that -- but if you're
newly hearing about this meeting,
we hope that you sign in so we can
include you about future meetings
about the site.

Once we receive all of the
comments, after the comment period
closes there will be a Record of
Decision, which will be signed by
the Regional Administrator, and
that's how EPA will clean up the
site.

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We will wait until after the
presentation for any questions,
but I do want to acknowledge
several elected officials here in
the community.

Jo Schuler, she's with
Congressman Smith in the back;

Mayor Todd Luttman; Jeffrey
Foster, Committeeman; George
Newberry, Committeeman.

And now we'll have the
presentation begin.

MR. WESTGATE: My name is
Matt Westgate. I'm the project
manager. I've been on the site a
long time. I think some of you
folks know me already.

We'll wait until the end for
questions. If you can't hear what
I'm saying, things like that, just
speak up.

This project is being
cleaned up under the Superfund
Law. And the Superfund Law is a
law that was set up in 1980 by

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Congress to provide federal funds
for cleanup of hazardous waste
sites. It allows EPA to respond
to emergencies involving hazardous
substances and empowers EPA to
compel potentially responsible
parties to pay for or conduct the
necessary response actions.

Cecilia touched on this a
little bit, but we have a pretty
established process. Site
discovery and hazardous ranking is
the first phase.

Then we go on to preliminary
assessment and site investigation,
where we try to learn more about
the extent of the contamination.

And once we kind of see what
we're up against and how it
impacts the communities, we will
put the site on our Superfund list
or the National Priorities List.

After the listing on the
NPL, that means we can go ahead
and proceed with the Remedial

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Investigation. And that's a very
thorough, comprehensive, years-
long process by which we look at
the aquifer, we look at all the
media involved, the surface water,
the groundwater. That's what
you're looking at here, the
results of our Remedial
Investigation.

Kind of a secondary document
to the Remedial Investigation is
the Feasibility Study, where we
look at the contaminants that we
have and see what media that
they're mixed in. We come up with
a number of remedies or proposed
technologies to deal with that.

And the purpose of the
Feasibility Study is to identify
all the possible ways to deal with
it.

And then this process, where
we have the proposed remedy and
the public meeting, is to sort out
from all those different

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technologies which one we think is
most appropriate.

So, once we get the proposed
remedy in place and after input
from community and from the State
and from everybody involved, we
put together a document called the
Record of Decision where all
that's finalized. In this case,
we1 re hoping to do that by the end
of September.

After the ROD is signed, or
the Record of Decision is signed,
we go into the design phase,
because most of these remedies are
fairly complicated and there's a
lot of designing involved.

After the design is
finished, we put that
specification out for bids and
contractors then will have the
chance to put in their bid on it
to be awarded the contract to do
the remedial action.

Some of the remedial actions

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are short-term and taken care of
in a few years. In this case,
it's going to be a little longer
than that, but eventually we'll
get to the site deletion point.

If a remedial action takes a
long time, we look at it again
every five years. There's a five-
year review built into our process
just to make sure we're on the
right path.

So, getting to White Swan
specifically -- there were two dry
cleaners. The White Swan facility
is on Sea Girt Avenue near Highway
35, and the Sun Cleaners is on the
northwest side of the Manasquan
Circle. And both of them operated
from about 1960 to about 1991.

They used the same dry cleaning
solvent, perchloroethylene or
tetrachloroethylene or PCE, as
it's called.

And what would happen is
that they would have, say, a

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hundred gallons of this material
in their facility, they'd run that
for a few weeks or a few months
until it got dirty and they
couldn't use it anymore, and
they'd either dump it outside on
the ground or put it in a septic
tank, which effectively does the
same thing; dumps it out into the
septic system.

The shallow groundwater in
this area is very close to the
surface, so that perchloroethylene
percolated into the groundwater
and it was carried from west to
east across the site.

I think I said some of
these. Both facilities used
tetrachloroethylene.

The way the site was
discovered was in 1997, there was
a resident on Magnolia Avenue,
which is just east of the White
Swan facility, he happened to be a
chemist. And he noticed there was

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something that wasn't quite right
about his irrigation well water.

So, he brought in a sample to work
and found that they had 1,500
parts per billion PCE in it.

Monmouth County Health
Department was notified after
that. They did some fairly
extensive water sampling and
irrigation well sampling, and they
found significant levels of PCE in
the groundwater.

Then they went to the New
Jersey Department of Environmental
Protection, and they did a lot of
groundwater samplings, surface
water sampling, and they also
picked up on the indoor air
pathway.

Now, as perchloroethylene
was mixed in the shallow
groundwater, it's a very unstable
contaminant and it volatilizes out
of the water as it passes
underneath neighborhoods.

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This vapor, PCE vapor, ends
up in the unsaturated soil zone
that people's basements are set
in. If your basement walls and
the floor are not quite perfectly
sealed up, some of these vapors
end up getting into the house.

We recognize that as an
exposure pathway, and we've been
keeping an eye on that throughout
this whole process.

EPA got involved in 2001, I

think.

Biff, you can correct me on
that, it was about 2001?

MR. LOWRY: Yes.

MR. WESTGATE: Biff is with
the New Jersey Department of
Environmental Protection.

And then between 2 000 and
2003, Bank of America got
involved. You might ask how that
happened.

Under the Superfund Law,
there's very strict liability

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clauses. And back when White Swan
was operating, the White Swan
property and the building were
bought by what was then Ocean
County Bank. Ocean County Bank
was bought by Fleet Bank, and they
were bought by Bank of America.

So, under these very strict
Superfund laws, Bank of America is
partially responsible for this,
and they've really stepped up to
the plate in terms of conducting
our Remedial Investigation.

So, Bank of America's
predecessor started investigations
in 2 000 through 2003. By
September of 2004, the site was
placed on the National Priorities
List, and in 2 00 6 EPA signed an
Administrative Settlement
Agreement with Bank of America to
conduct this Remedial
Investigation and Feasibility
Study.

And because it was such a

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large study that lasts so many-
years and there are a lot of
planning documents that we had to
put together, it wasn't until
early 2007 that we got out to the
field and actually began doing the
investigation.

So, the purpose of that
investigation is spelled out in
the first bullet. It's to
determine the nature and extent in
the soils, the sediments,
groundwater, surface water. In
other words, we want to see all of
the different media that's been
impacted.

We identified the sources of
the contamination. We identified
not only the perc but the
secondary degradation products of
perchloroethylene.

Perchloroethylene.will break
down to trichloroethylene,
bichloroethylene, vinyl chloride,
and eventually methane, and those

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breakdown products were also
present in the groundwater.

We looked at pathways,
exposure pathways, mechanisms, and
rates of contaminant migration to
environmental media trying to get
an idea of how this thing is going
to impact people as we move
forward, concentrations of
contaminants and points of
exposure to humans and ecological
receptors because part of what we
look at is impact to the
ecosystem.

Bank of America performed
this RI with EPA oversight -- our
Remedial Investigation with EPA
oversight. And we had -- we
focussed first on the source
areas, the former White Swan
Cleaners and the Sun Cleaners
properties.

And then we did a very
extensive groundwater
investigation from Highway 35 on

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the west to Atlantic Ocean to the
east. That's two miles. And then
on the north, Wreck Pond and
Hannabrand Brook. On the south,

Judas Creek and Stockton Lake. We
also looked at those surface water
bodies, sampled the sediments in
the surface water bodies.

As part of our soil
investigation, we have looked at
cultural resources to make sure
that we didn't damage any
historical resources in the
process of looking at this and
sampling; obviously, topographic
surveys.

Our phased approach in the
RI started with the soil vapor
survey. And I have to say, it
turned out to be very useful. You
put two-foot deep borings in the
soil and you put this little
sampling module into the holes --
and they put about seven hundred
of them, I guess, all together --

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and you leave it in the ground for
two weeks and it absorbs the PCE
vapors that are in the soil and it
gives us an idea what the
contamination is.

So, when we go to the next
phase, when we start putting
borings and monitoring wells in,
we place the wells where we want
them, not just arbitrarily putting
wells where there's no
contamination.

So, as far as the source
area investigation, we did 68
surface and subsurface soil
samples from 23 borings at White
Swan, 4 8 samples from 13 borings
at Sun. So, it was pretty
extensive.

This is just a plot of White
Swan's property. All these
different dots on there represent
all the different locations that
we did groundwater and soil
sampling.

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This is the same for Sun
Cleaners. This is the southwest
corner of Manasquan Circle where
it goes into Atlantic Avenue.

So, as far as the source
area investigation results,
despite a septic tank and soil
removal in 2 0 01, which was done by
the bank's predecessor, there
still remains a lot of
contamination in there; up to 160
parts per million.

As you go deeper beneath the
surface into -- near the water
table, which is about twelve to
fifteen feet down, you end up with
some pretty high levels, as high
as 28,000 parts per million.

The total PCE mass in the
soil at White Swan was about 4,3 00
pounds.

As far as Sun Cleaners is
concerned, their unsaturated zone
soil contamination ranged up to 51
parts per million, and their total

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PCE mass was 140 pounds.

Here's a picture, just three
layers: The top layer is the
ground surface to seven feet below
the ground surface; the middle
layer seven to seventeen; and the
bottom goes down as far as 25.

The colors that you see
there represent contamination
levels, and the pink or the tan
colors are the higher.

This is Sun Cleaners'
diagram, also their soil
contamination shown at three
levels.

The groundwater
investigation was the biggest part
of this, so we did all these soil
vapor borings to help locate the
contamination.

Next thing we used what1s
called a membrane interface probe,
which is a small drill and rig on
the back of the truck that you
pound into the ground and it has a

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sensor on the bottom of it that
electronically reads the
conductivity in the groundwater
and it gives you an indication
that correlates to the amount of
contamination that it's being
exposed to.

After we use the MIP and we
see where the hot spots or the
higher contamination zones are, we
use a hydropunch, which is a
larger drill and rig mounted on
the back of the truck. It's like
a giant hypodermic needle. You
put it into the ground and collect
discreet groundwater samples from
specific intervals. We did a lot
of this; 719 hydropunch
groundwater samples from 169
borings across the site.

And these very complicated
maps, the one on the left is
shallow, the one in the middle is
intermediate, and the one on the
right is the deeper zone. All

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that information comes from a
combination of these tools and our
monitoring well sampling.

We collected three rounds of
sampling from the groundwater
wells, a total of 148 samples from
60 monitoring wells. And those
are permanent wells that we're
going to use over the course of
the design in the remedial action
to make sure that we know what's
going on with the contamination.

This is an aerial photo of
the whole site, two miles from
left to right. All these little
dots of various colors represent
the hundreds of sample points that
we have.

And this map shows our
permanent monitoring wells.

These pictures also are
printed on the boards so you can
come up later and look closely.

It's kind of hard to see from that
proj ection.

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So, groundwater
investigation results. PCE and
its degradation products, the
plume extends from the two source
areas east to the Atlantic Ocean.

Significant PCE
contamination at White Swan,

75,000 parts per billion. The
breakdown products, TCE and DCE,
were also found at significant
levels, 400 and 190 parts per
billion.

Also found significant
contamination at the Sun Cleaners
source area, levels up to 61,000
parts per billion. Again,
breakdown products were present
there too, TCE and DCE, up to 72 0
in the case of DCE.

Just to give you a
comparison, the New Jersey
groundwater quality standard for
PCE is one part per billion, and
that's our cleanup goal. In order
to restore this aquifer, that's

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where we're headed.

There's a mixing zone in the
vicinity of Magnolia Avenue, Old
Mill Road, and Laurel Avenue,
where these PCE plumes from the
two sources mix and they proceed
to a wider plume.

So, that would be in this
area. And then once they were
mixed together, the plume would go
east, northeast, to Hannabrand
Brook and Wreck Pond and southeast
to Stockton Lake.

PCE contamination is near
the surface of the two source
areas and it sinks as it moves
east. Perchloroethylene is denser
than water, so it actually drops
down in the aquifer as it's moved.

The good news is we found a
low permeability layer that kind
of puts a cap on the bottom of
this thing. The low permeability
layer stretches across most of the
site. The deepest part is about

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75 feet, more or less, beneath the
ground surface. So, that low
permeability layer acts as a stop
and keeps the contamination from
going deeper.

We also found -- you can see
them on some of these more
detailed maps -- we found several
hot spots. Hot spots are zones of
higher contamination. And as best
as I can explain these hot spots,
when the dry cleaners had a batch
of perchloroethylene that they
were going to discard, let's say
it's a hundred gallons, they'd
dump it on the ground and get
fresh, new stuff to run through
their machines.

That hundred gallons would
go down and hit the groundwater
about the same time and be carried
off like that across the site,
from west to east.

The groundwater
contamination is composed mainly

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of PCE with its degradation
products. I already said that,
sorry.

The total PCE mass in the
groundwater is estimated to be
about 4,700 pounds of PCE with 16
percent in the shallow zone, 56
percent in the upper or the middle
zone, and 2 8 percent in the lower
intermediate zone. The 4,7 00
pounds includes not only the full
plume but also the extensive PCE
contamination in the source areas.

This is kind of a very
simplified drawing of the
contamination. The lower PCE
levels are in blue, the green,
yellow. And then as you get
closer to the source areas, you
see the reds, and those represent
the higher.

This is a more complicated
version of these three maps. In
this particular illustration, all
three layers of contamination have

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been combined in one map to show
as if you're looking straight down
as seeing through all seventy feet
of our aquifer and seeing all the
contamination at the same time.

It kind of helps us get a better
handle on it.

You folks can come in and
sit. There are chairs all over
the place.

We did a bunch of cross-
sections across the area just to
give you an idea of what's going
on in the subsurface. I'll
discuss this cross-section here,
this is from B to B2.

So, where B is is the Sun
Cleaners facility. The part up
here with no color is the
unsaturated soil zone. The top
line is the ground surface. And
this line here with the little
triangle on it is the top of the
water table.

So, it's about ninety feet,

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this shows about ninety feet of
cross-section. And you can see
the contamination started in the
soils right here at Sun that
percolated down into the
groundwater.

And you can see the higher
contamination zone is sinking for
some reason. There must be some
clay in this zone here. For some
reason, it comes back up again and
then it starts to sink deeper as
it gets further east.

This spot here is near where
Barlow's Nursery is on Sea Girt
Avenue, and it's a fairly
significant hot spot down deep in
that location.

Here is where the Sea Girt
Municipal Building is.

And then again, this is
Barlow's hot spot here, this is
where the Sea Girt Municipal
Building is, and here's your
Atlantic Ocean.

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So, the contamination sinks
and heads all the way into the
ocean. The contamination, when it
comes up under water, it mixes
with the ocean water and it's
dissipated, so it's essentially
nondetect in the ocean. It's
flushing out into the ocean. Once
it hits the ocean, it's
nondetectable.

As far as surface water and
sediments, we looked at Hannabrand
Brook. This is just a summary of
what we found: 25 sediment
samples collected in 2007 to 2009,
maximum PCE level in the surface
water sample is 5.9 parts per
billion; Judas Creek, thirteen
sediment samples from 2 0 07 to
2 009, maximum 4.4 parts per
million PCE.

That was at a location along
Judas Creek that was upstream of
Route 71.

Thirteen surface water

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samples, a maximum of 31 parts per
billion PCE at a location
downstream from Foodtown, Sea Girt
Mall.

This part, the risk
assessment, Chloe is going to
handle.

MS. METZ: Risk assessment
can get a bit confusing. It gets
technical very quickly, so I'll
try to explain it as easily in the
most straightforward way.

Essentially, Superfund has
what we call a target risk range,
and that's ten to the minus six to
ten to the minus four cancer risk
rating. And that's what we're
aiming for.

We take a look at what
concentrations of contamination we
have in various media and how
people might be exposed to that,
and, with that exposure, what kind
of risk that would present to the
public.

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On the cancer side, an
unacceptable risk would be if a
contaminant poses an excess
lifetime cancer risk greater than
ten to the minus four.

On the noncancer side, the
chemicals that cause noncancer
effects would be what we call a
hazard index greater than one.

So, that means that the
concentration in the media,
whether it's groundwater or soil,
would be greater than what we
consider to be a safe exposure
level.

So, for this site, we had a
couple different scenarios. We've
got -- as Matt mentioned, we
primarily have contaminated
groundwater here. We also have
contaminated soil in source areas.

So, we looked at how a
hypothetical utility worker or
construction worker might be
exposed to those contaminated

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soils.

Those did not pose a risk;
however, the soil is contaminated
and is posing -- is still
contributing contamination to the
groundwater. So, that's the
reason why we1 re looking at
remediating the soils.

The groundwater, surface
water, and sediment is all the
media that are impacted on the
downgradient side. So, as the
groundwater moves away from the
source area, it gets into the
sediment and the surface water.

And, so, for that scenario, we
looked at a hypothetical drinking
water scenario.

As Matt mentioned, everyone
in the community is already on
publically-supplied water, which
is not impacted by this
contamination.

But in the Superfund
program, we always consider the

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possibility that someone can
install a well in the heart of the
contaminated plume, so we look at
what risk would be posed by
someone doing that.

We also considered people
wading in the various water
bodies, Hannabrand Brook and Judas
Creek, and the potential for
people exploring those areas
casually or fishing and looking
for critters, that kind of thing.

What we ended up -- after
looking at all those various
scenarios, the one that really
posed the greatest risk was the
ingestion of groundwater. So,
this is the hypothetical scenario
where someone is drinking
groundwater from this contaminated
plume. So, that is the reason why
we're here to talk about how to
clean that up.

The contaminants that are
posing the risk are

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perchloroethylene,
tetrachloroethylene, vinyl
chloride, and cis-1,2 DCE.

As many of you probably
know, we've also been doing
extensive vapor intrusion sampling
in the community. And, so, as we
get data on a house, we evaluate
those on a case-by-case basis to
determine if there is a risk posed
by the vapors coming from the
subsurface into the home and
whether or not there needs to be
any kind of mitigation system put
on the house to prevent that
pathway from occurring.

So, that's part of our risk
assessment evaluation.

MR. WESTGATE: We also
evaluate the potential ecological
risks from the presence of
elevated volatiles in the
groundwater that discharge to the
surface water and sediments;
comparison of the surface water

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and sediment concentrations to
conservative ecological screening
values, measured as hazard
quotient.

We don't want to exceed the
hazard quotient of one.

So, as far as ecological
risk, we looked at Hannabrand
Brook, which includes Wreck Pond,
and Judas Creek, which includes
Mac Pond and Stockton Lake.

As far as the results are
concerned, the sediment in three
locations within Hannabrand Brook
exceed screening criteria for PCE.

In the Judas Creek system,
the sediment at two locations
within Judas Creek exceeded the
screening criteria.

And the proposed remedial
action that I'm going to talk
about in a minute is going to
address the groundwater which is
discharging into the surface
water. So, that will take care of

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that ecological risk.

The next phase is the
Feasibility Study, and this is
where we get into talking about
the different kind of technologies
that are available to deal with
this stuff.

We identify the remedial
alternatives based on the site-
specific conditions and sampling
results. We eliminate, reduce, or
control the unacceptable risks to
human health and the environment.

This is our Feasibility
Study process. First, we
establish remedial action
objectives, develop preliminary
remediation goals, identify —
well, we did identify and screen
remedial technologies, we develop
remedial action alternatives, and
then evaluate these alternatives
using nine criteria which the EPA
uses to sort these things.

So, remedial action

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objectives, there's four basic
ones. The first one is prevent
and minimize future -- current and
future human exposure to
groundwater, ingestion of
groundwater, or inhalation of
vapors from the site-related
volatiles in the groundwater.

Second is to prevent or
minimize migration of site-related
soil contamination to groundwater.

The third one is restoration
of site groundwater to drinking
water standards. That's a long-
term goal, to restore the aquifer
to drinking water standards.

And the last one is to
prevent or minimize the migration
of site-related contaminated
groundwater to surface water and
sediment that presents a risk to
the environment.

So, the first set of
alternatives that we're looking at
are related to addressing the soil

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contamination. That's the soils
of the two source areas.

The first is required -- our
Superfund law requires that we
include a no action alternative to
kind of give us a baseline to
compare it to.

The second remedial
technology we're thinking of for
the soils has to do with soil
vapor extraction. Essentially,
you put a soil vapor extraction
vacuum system on the ground
surface that pulls the vapors.

This teams up with air sparging.

Air sparging is kind of like
what you see in a fish tank. You
inject air into the shallow
groundwater right underneath this
unsaturated zone, and that
bubbling causes the PCE vapors to
move up into the unsaturated zone
and we collect them with a vacuum
system.

Alternative three is

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excavation and disposal of soils
at the White Swan and Sun Cleaners
source area. Pretty
straightforward, we dig them up an
take them to a hazardous waste
facility where they're treated and
permanently disposed.

Alternative four is a
combination of the soil vapor
extraction and the excavation and
disposal. So, we're thinking the
excavation and disposal at White
Swan and soil vapor extraction at
the Sun Cleaners.

These next bullets kind of
go into more detail of the type of
technologies that were considered.

The volatilized VOCs that
are collected are treated using
catalytic oxidizers and/or
granular-activated carbon. And
the treatment system either can be
encased in a subsurface vault or
in a recirculating groundwater
remediation well, which is kind of

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a thick complicated thing that we
would install to deal with the
vapors.

Excavation and disposal,
it's slightly more complicated
than just digging a regular well.

We have to do sheet piling around
these areas, there might have to
be some dewatering to get the
equipment in there to do the
excavation.

All of the soil and sediment
containing PCE above one part per
million would be pulled out of
there. At White Swan, we have
about 5,100 cubic yards and at Sun
Cleaners we have about 9,600 cubic
yards.

Alternative four is just A
combination of these two
technologies. Both of them are
very effective. Either one of
them would be very effective in
getting PCE out of these
unsaturated zone soils.

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Now we look at the money
part of the analysis.

Obviously, no action doesn't
cost anything.

Alternative two, which is
this vapor extraction with the air
sparging, for White Swan we
estimate about $1.8 million and
the same $1.8 million for Sun.

For excavation and disposal
of soils at Sun and White Swan,
$3.5 million for White Swan and
$4.5 million for Sun. And the
combination is for the sparging at
Sun and excavation at White Swan
is $5.4 million all together.

So, the next phase we look
at groundwater remediation
alternatives. Again, there's that
no action, don't do anything.

Alternative two is a similar
type of process to take the PCE
vapor out of the soil except you
do more air sparging to drive the
PCE out of the groundwater, deeper

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air sparging, and drive it up into
the unsaturated zone.

Obviously, with the
extensive groundwater plume that
we have, it would require quite a
lot of wells distributed
throughout the neighborhood to
collect in this vacuum system to
collect the vapors.

Along with all these
groundwater remedial action
alternatives, we have -- well, the
different technologies, the soil
vapor extraction, the next one
chemical oxidation, they're very
active, aggressive treatment for
the highly contaminated air. But
it's not the whole plume. It's
essentially this area around here.

We're thinking of -- part of
our Proposed Plan is to allow
natural attenuation. And in this
case, it would be monitored, we'd
keep an eye on it. Natural
attenuation would deal with the

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downgradient areas where we have
very low levels of PCE.

And the reason we're leaning
towards natural attenuation as
part of the remedy is because we
did -- we used a model where we
plug in all the information, all
the data that we have, and kind of
run it on fast forward to see how
long the cleanups take.

With aggressive treatment in
the higher contamination areas
versus an aggressive treatment
throughout the whole plume, you
didn't save a lot in terms of
time.

What was it, forty years?

MR. POSTEN: Forty to fifty

years.

MR. WESTGATE: Forty to
fifty years with the aggressive
treatment in the middle. And if
you left it without that
aggressive treatment, it might --

What were the numbers?

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-- about seventy years.

A second thing that's added
on to all these is called
institutional controls.

Institutional controls are
actually controlled by the State
of New Jersey.

It has to do with allowing
people in the future to install
irrigation wells or use certain
highly contaminated parts of this
aquifer. And we want to control
that while we're trying to collect
the vapors.

So, we would work with the
State of New Jersey to establish
wells or an institutional
controlled area to make sure that
we can clean this up without
people pulling contamination all
over the place.

And the final part of all
these groundwater remedial actions
is vapor remediation. The vapor
sampling that I've been doing over

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the past ten years, we're sampling
fifty houses at a time to see
where PCE vapors are and, if need
be, if you're exceeding some
threshold value, we put a radon-
like indoor air system in the
houses.

And thus far, roughly, over
the last ten years, I've sampled
about 450 houses, about 34 of them
had high enough levels inside and
we had to put in these radon-type
ventilation systems.

And that will continue
through our remedial design and
any of the work that we do in the
remedial action work. As the
plume moves along and we get a
better picture of where it's
migrating to, I will sample houses
in the area where the highest
contamination is and work my way
across the site.

The third alternative that
we were looking at for this

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aggressive groundwater treatment
is called in-situ chemical
oxidation. That's where we put a
series of wells across the plume
area and inject various oxidation
agents into groundwater to
accelerate that breakdown from
perchloroethylene to
trichlorethylene to
dichloroethylene, eventually
methane gas.

Of course, we would have to
tweak the aquifer to adjust for
pH. There are certain chemical
parameters that we would have to
make sure were tightly managed so
that these oxidants work
efficiently.

Alternative three also has
the MNA and institutional
controls, monitored natural
attenuation, and it has the vapor
remediation tacked onto it also.

The last alternative that we
were thinking about is called pump

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and treat in the industry, and
that is extraction and treatment.

This is more of a detailed
description of what I just talked
about. 111.1 go back to the pump
and treat.

So, the pump and treat
remedy is putting a number of
groundwater collection wells right
in the source areas for these two
dry cleaners and, based on our
modeling and design work that we
do, possibly putting in
groundwater recovery wells in
these hot spot areas to suck up
the highly contaminated
groundwater.

And it would be carried with
underground piping to a
groundwater treatment plant. And
essentially, it's the same type of
water treatment plan that the
water company would have except in
our case once we pump the
contaminated groundwater, we get

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all the PCE out of that, we
wouldn't discharge it to the
waterlines and sell it to people.

We would either put it back
into the aquifer, we would
discharge to a surface water body,
possibly Judas Creek, or we would
see if the locally-owned treating
works would be interested, the
Sewer Authority would be
interested, in taking that from
us.

All those things are worked
out in the design. Whether the
aquifer could take reinjection or
how much Judas Creek would take in
terms of the clean water coming
out of the plant, it's not
something we're able to design at
this point.

So, basically, going into a
little bit more detail of these
various things, alternative two is
talking about soil vapor
extraction, air sparging -- I'm

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just looking to see if there's
anything that...

Bullet number four talks
about these 24 RGRWs, which are
groundwater recovery wells, and
would have to be installed
throughout the neighborhood and
operated for ten years. That's
kind of -- it's fairly intrusive
to the neighborhood, so we kind of
leaned away from that one.

When you look at alternative
three, again, forty groundwater
circulation wells to treat PCE and
TCE in the Near Field that are
using oxidants injected at the
aquifer.

Pilot studies will be
required to evaluate the
effectiveness. In other words, we
collect a large volume of
groundwater, treat it to see how
it degrades, and adjust our
chemistry based on that.

In this case, treatment is

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also about ten years, construction
takes two years.

Alternative four, our pump
and treat system. I think I hit
all the points there.

The pump and treat plant
that we would build would use air
stripping and granular-activated
carbon to treat the waters. That
would essentially get it down to
below one part per billion.

As far as location of the
groundwater treatment plant, we
haven't quite figured that out
yet. There is a wooded area
behind Foodtown that stretches to
the east, essentially a flood
plain of Judas Creek. We thought
maybe that might be a good
location, but we haven't
approached any landowners to see
if they would lease us this land
or if we could purchase the land.
So, it's really up in the air.

We have a fallback location

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for the groundwater treatment
plant which is the National Guard
Base down Sea Girt Avenue. But
then we'd have to put a lot of
piping going up and down Sea Girt
Avenue to handle our collected
groundwater. So, we're still
working on that.

Construction time for the
groundwater treatment plant is
approximately two years. And it
would have to run for quite a
while to deal with all this
groundwater contamination, and
we're estimating for the design
estimate thirty years.

These are the costs
associated with dealing with the
groundwater.

Alternative two, which is
the air sparging and the soil
vapor extraction, we estimate
$10.8 million.

As far as this chemical
oxidation where we put these

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oxidants into the groundwater and
accelerate the breakdown for the
Near Field and the Far Field hot
spots, we're looking at $11.6
million.

And our extraction and
treatment system or pump and treat
system, we're looking at $13.5
million.

The alternatives are all run
through these nine criteria. In
our Feasibility Study and in our
Proposed Plan to try and help sort
them out.

And if we look at the
main -- the first two are the main
ones, protection of human health
and environment and compliance
with our appropriate regulations.
The next four, long-term
effectiveness and permanence;
reduction of toxicity, mobility,
or volume; short-term
effectiveness, implementability,
and cost.

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Obviously, after this public
meeting and we get the comments
from people, we'll find out about
state acceptance and community
acceptance.

So, here's what we've come
up with.

This is our take for dealing
with the soil source areas. We
prefer alternative four, which is
using the soil vapor extraction
system at the Sun Cleaners site.

And a couple of the major
points -- and, again, this is not
all the nine criteria, but a
couple major points that jumped
out of this presentation.

If we were to do an
excavation and soil removal at the
Sun Cleaners property, it would be
very intrusive to the Manasquan
Circle traffic. And I don't know
about you, but for the past twelve
years when I go through Manasquan
Circle, it's always full and

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everybody is going sixty miles an
hour. So, that's a real issue for
us trying to deal with that
traffic while we have a big
excavation with sheet piling and
all kinds of people around there.

The ISVE system is less
expensive than the excavation;
it's not $4.5 million, it's $1.8
million. It would effectively
deal with the PCE mass, the 140
pounds that exist there at Sun
Cleaners. And the reason we're
leaning away from the excavations
is because just to the west of the
Sun Cleaners property there's a
steep dropoff, I guess about 20,

25 feet, that would be hard to
control with sheet piling keeping
the hole intact. Part of the hole
might slough off down into the
wetlands area, and we don't want
to do that.

Excavation is preferred at
the White Swan. The higher cost

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of this complete excavation and
disposal would be justified to
remove the 4,360 pounds of PCE
that's contained in that
unsaturated zone soil mix. And
the White Swan area, it's more
flat, has less traffic. .It's
easier to dig a hole up there.

So, that's why we're
preferring that combination.

In terms of dealing with the
groundwater, we're again looking
at alternative four. This one
happens to be our pump.and treat
system.

So, the advantage of this
pump and treat system is that we
would seek complete restoration of
groundwater within thirty years.

If you look at some of the
other remedies, the chemical
oxidation, the vapor extraction,
different parts of the plume react
differently to these chemicals.

There's trouble with dosing,

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there's trouble with your pH and
your different chemical primers
shifting, so just it's a little
bit more difficult than what we're
proposing, to just pump out the
central hot spot area or central
core of the plume.

The pump and treat process
is very effective and it's proven
as very successful for the
volatile organic contaminants in
our groundwater. It's really a
no-brainer. There's no question
that air stripping and carbon
polishing will take care of this.

It's less disruptive to the
community in that we don't have
forty well sites distributed
throughout the neighborhood that
we have to go back to load
chemical oxidants and do a lot of
work.

Characteristics of this
shallow aquifer. This is Cohansey
Formation. It's nice, medium-

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grain sand. We put a recovery-
well in a certain location, you've
got a wide area where this
drawdown water is collected, it's
circular.

It's a lot different than
some other parts in New Jersey
where you might have fractured
bedrock or there might be glacial
deposits in there, just a hodge-
podge of clay and gravel.

Pumping and treating in a
medium-grain sand aquifer, it's
very easy to control.

There's also no concerns
with pumping and treating about
generating fugitive vapors that
you might have with chemical
oxidation. In other words, when
you start putting all these
oxidants into the groundwater to
accelerate that breakdown from PCE
to TCE, sometimes you drive vapor
contamination up into the
residential areas, and we don't

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want to do that.

So, there's no chemical
dosing impact. I think I touched
on that a little before.

There's more control over
the treatment process. So, the
actual, you know, where we can see
what the pH is, what the
temperature is. If the treatment
process -- and this is the
equipment that's inside the
groundwater treatment plant -- if
it's not working right, such that
we're starting to see a little bit
more PCE coming out of the
effluent, then we lighten it.

It's very simple to adjust.

It's much more complicated
when the stuff is in the
groundwater, you know, fifty to
seventy feet below the ground
surface.

This pump and treat system
would put more control over the
central contaminated core of the

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58

plume, which would make our
natural attenuation process go
faster.

So, for those reasons, we
think that the pump and treat
alternative is the best.

This goes into some more
detail about monitored natural
attenuation. There's a couple of
factors that you look at when you
look at natural attenuation.

Dispersion of the dissolved
mass after source removal, I
touched on that.

Dilution with cleaner
groundwater. This Cohansey
aquifer, there's a lot of clean
groundwater coming from the west,
so dilution is a big part -- in
our particular instance, it's a
big part of natural attenuation.

And then as part of natural
attenuation, you get adsorption of
the soil -- of the PCE molecules
on the soil and rocks in the

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59

aquifer. It kind of takes them
out of the picture.

And then the degradation
that I talked about before is
natural degradation.

Site data show
concentrations of PCE in the
groundwater plume have already
declined to the degree that
unacceptable impacts to the
environment can be prevented
through MNA mechanisms.

So, we're not worried about
these health effects or the
environmental effects if we
consider natural attenuation.

Our contaminant plume is
very stable. It's kind of
bordered on the north by
Hannabrand Brook and Wreck Pond,
bordered on the south by Judas
Creek, the Atlantic Ocean on the
east kind of contains our plume,
it's not like it can escape. So,
we can keep an eye on it, make

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sure natural attenuation -- if it
doesn't go our way, we can always
adjust the recovery wells that we
installed in the pump and treat
system to handle any
discrepancies.

Source control radiation
through the current source
extraction and treatment system
further adds to the original soil
removal action. So, that's part
of the natural attenuation.

Since the PCE concentrations
will be reduced, the
concentrations of the degradation
product of TCE and cis-l,2-DCE
will also be reduced.

And there will be no demand
on groundwater resources since the
area is on public water. People
aren't drinking this.

Institutional controls, I
covered some of this before.
Administrative methods to prevent
human exposure to contaminants.

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State classification
exception area. This doesn't mean
we'll be closing irrigation wells
that already exist, but we might
put some restrictions on putting
new ones right in our contaminated
zone.

So, if you're in a house
that's downgradient of, let's say,
where Barlow's is, where you have
a hot spot at a certain level,
you'd still be able to put an
irrigation well in there but your
permit would only allow to pump
from noncontaminated parts of the
aquifer.

Vapor intrusion, I think I
touched on that a little bit
before. During the design and
remedial action phases, sampling
of residential and commercial
buildings will continue.

I did 450 houses, I've got
about 1,200 to go.

We'll continue to prevent

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exposure to PCE or TCE vapors
above the health-based levels of
indoor air. And if they are above
those health-based levels, the
federal government will put in
these ventilation systems which
are exactly the same as the
ventilation systems used for
houses that are sitting above
radon formations.

I hit the 450, 34. It's
about seven percent of the houses.

Most of those 450 houses
that are done already are right in
the high contamination zone. I've
gotten as far as Barlow's, so I've
done all these in here and
additional houses that we're
looking at downgradient. Since
the levels of PCE are much lower
in that part of the aquifer, I
don't expect to see too many more
systems.

Not only will we install the
indoor ventilation system, but we

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maintain them as well. If for
some reason there's a pump failure
or something, we have mechanisms
to go and repair it.

The homeowner is expected to
provide the electricity, which it
costs about the same to run the
fan as a 60-watt lightbulb. So,
you would be responsible for that,
but everything else we take care
of; the wiring, fan installation,
testing.

Questions?

MS. ECHOLS: There's
individuals standing.

Would you like to come in
and have a seat -- there's plenty
of seats -- before we get started
with the questions and answers?

Since there are many people
here, we're going to go from one
side of the room to the other for
the questions.

If you feel comfortable
enough to come up to the mic, that

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64

would be fine. Please state your
name. If you're representing
anyone, please state that as well.

Are there any elected
officials here who have a
statement they would like to make?

MAYOR LUTTMAN: We'll wait
until the end.

MR. McMORAN: Bruce McMoran.

MS. ECHOLS: Can everybody
hear him? No.

Would you like to come to
the mic?

MR. McMORAN: My name is
Bruce McMoran. I live at 1210
Hemlock Avenue.

First question is we came
here tonight and we got a 20-page
document, highly technical, which
you went through in your
presentation.

Right?

Why didn't we get this prior
to tonight so we'd get a chance to
read it?

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MR. WESTGATE: We made that
document available on our website,
when we put the announcements in
the paper, when we opened up the
public comment period, which
was --

MR. McMORAN: But it wasn't
sent to us.

MR. WESTGATE: No, we didn't
mail the document out to
everybody.

We mailed little postcards
kind of indicating what we were
proposing to do and how you could
find out more details.

MS. O'CONNELL: I also want
to add, the public comment period
doesn't only include the meeting
tonight. All the comments are
going on the record and they'll be
in our record, but the public
comment period is open until
September 19.

MR. McMORAN: It just would
have been easier if we had this in

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advance.

Turn to Page 13, please.

The column on the right, two-
thirds of the way down it says,
"Long-Term Effectiveness and
Permanence."

Do you see that?

MR. WESTGATE: Yes.

MR. McMORAN: It says, "The
highest degree of permanence and
long-term effectiveness is
achieved for those alternatives
that result in the greatest
removal of contaminants from the
site."

See that?

MR. WESTGATE: Right.

MR. McMORAN: Turn to Page
10, please.

These are the alternatives
two, three, and four for the
removal of the soil. Alternative
three provides removal of all the
soil in a timeframe of one year.

Right?

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MR. WESTGATE: That's
correct.

MR. McMORAN: The other two
alternatives, two and four,
provide for times up to ten years.

Is that right?

MR. WESTGATE: Yes.

The vapor extraction would
be less.

MR. McMORAN: Wouldn't it be
better to remove it all in one
year and be done?

MR. WESTGATE: Yes.

MR. McMORAN: I have no
further questions.

MR. WESTGATE: But it's not
just cost when we look at these
alternatives and we sort them.

Some of the issues with
digging up all the contamination
at Sun Cleaners have to do with
that slope which makes it
difficult to do the excavation, it
has to do rerouting Manasguan
Circle, it has to do with --

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MR. McMORAN: One year as
opposed to ten years.

MR. WESTGATE: I understand.

MS. O'CONNELL: Are you just
talking about the soil
contamination?

The excavation at White Swan
is estimated to take a year and
the treatment of soil through the
soil vapor extraction at the
former Sun property is estimated
to take ten years.

It's an in-situ treatment
that will treat the soil
contamination -- just soil, not
groundwater, it's going to treat
the soil contamination in place
and it's going to take longer.

There's much less
concentrated contamination at Sun
compared to White Swan.

iSo, we did look at long-term
permanence, but the nine criteria
that we weighed, including other
factors, like logistics in the

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community, we look at cost, we
look at effectiveness, we look at
impact to the community, we look
at -- with respect to cost, we can
treat all the soil at Sun in ten
years, but there's much less
contamination there compared to
White Swan.

So, White Swan

MR. McMORAN: Excuse me, but
if you remove all of it in one
year, there will be no further
contamination.

Correct?

MS. O'CONNELL: In the soil.

There's significant
groundwater contamination, yes.

MR. McMORAN: Right.

But the water can continue
to flow through the contaminated
soil for ten years.

Right?

MR. WESTGATE: Right.

MR. McMORAN: Thank you.

MS. ECHOLS: Sir, in the

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middle here.

MR. HENDERSON: Thank you.

My name is David Henderson.

You had mentioned that there
was a potential responsible party,
and I had a couple questions.

Is this publicly funded or
is this responsible party funded?

MR. WESTGATE: For the
design and remedial action, we
have to go through some
negotiations and that will sort
out how much of it is federally
funded and how much is responsible
party.

MS. O'CONNELL: To date, all
of the studies done have been
privately by the PRP. So, to
date, the cost has been privately
funded by the responsible party.

(Pause in proceedings)

MS. O'CONNELL: All of the
work to date, the investigations,
have been paid for privately. EPA
issued an Administrative Order of

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Consent to Bank of America, and
they performed all of the studies
and reimbursed EPA for our
oversight costs.

After the remedy is
selected, we will need to
negotiate another enforcement
order to determine how the future
work will be performed and funded.
So, that's to be determined, but
to date the work has been
privately funded.

MR. HENDERSON: So, the
contractor was chosen by the
federal government?

.MS . 0 1 CONNELL : The
contractor is chosen by Bank of
America. EPA also has a
contractor who oversaw all the
work. EPA approved all of the
work plans. The work was
performed under an Administrative
Order of Consent.

MR. HENDERSON: Is there a
New Jersey licensed site

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remediation professional?

MR. WESTGATE: In Superfund,
we don11 use --

MR. HENDERSON: It's a New
Jersey site, so doesn't a New
Jersey —

MR. WESTGATE: The federal
law does not require an LSRP on
the site.

But Steve Posten is an LSRP.
As a matter of fact, he's a very
high-ranking official in the LSRP
organization. So, he oversaw all
of that.

Again, the Superfund Law was
way before the LSRP program, so on
a federal Superfund site it's not
required.

MR. HENDERSON: Next
question, I took a look at the
alternatives that were proposed,
and I saw that there were four
alternatives. I did not notice
any innovative technologies.

Is there a reason why

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innovative technologies were not
reviewed or considered for
remediation of this project.

I know a number of people
have mentioned that they thought
it was going to take quite a long
time to clean it up, and there are
proven more innovative
technologies that can be
undertaken without invasive
activities at the site, in the
plume, or would take as long as
those other technologies, those
rather usual technologies.

MR. WESTGATE: For
groundwater, you're talking?

MR. HENDERSON: Soils and
groundwater.

MR. WESTGATE: We did
consider some innovative
technologies.

Steve, maybe you can help
me, which ones were looked at as
part of the FS?

MR. POSTEN: Matt talked

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about the Feasibility Study. What
you saw tonight was kind of the
end result of a long process. The
initial phases of that Feasibility
Study looked at a whole range of
other alternatives, some of which
included innovative technology.

So, for example, in-situ
bioremediation, construction of
permeable reactive barriers, which
are walls, the treatment media
that get installed in the ground
that the groundwater moves
through. I would say those are
probably the two -- of the various
innovative alternatives, those are
probably the two that lasted the
longest through the screening
process.

The bioremediation
technology, ultimately EPA decided
not to pursue that because
incomplete breakdown of these
products, which can happen with
the bioremediation, results in the

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generation of vinyl chloride
vapor, which is actually more
dangerous than the PCE or the TCE.

The feeling was that in an
area that's very heavily developed
in residential use, that that
probably wasn't a good thing.

In terms of the permeable
reactive barriers, we looked at
those for the highly contaminated
areas, mostly downgradient of Sun
Cleaners. In that area, though,
the construction of those was not
really any cheaper than some of
the other alternatives that we
looked at, so that they at the end
of the process fell out of the
group.

But there was a pretty
extensive range of technologies
looked at and screened in several
documents for the Feasibility
Study, and those are all available
for public review.

MR. HENDERSON: Did you

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consider a reductive process for
the dechlorinization, injectable
slurry of a reductive process?

MR. POSTEN: We looked at
in-situ bioremediation, which
includes changing the geochemistry
to a reductive chemistry --

MR. HENDERSON: There are
products that are available that
can be injected not by
remediation. There are products
that are available that can be
injected that will reduce the
chlorinated solvents without going
to other products and eliminate
the material within months.

Were any of those
considered?

MR. POSTEN: I can't recall
if those were considered or not.

MR. WESTGATE: Please submit
the comments to us so we —

MR. POSTEN: Again, various
technologies were looked at -- and
there was something on the order

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of fifteen or twenty of them --
I'm sure not every potential
option was looked at, but quite a
few were. And the ones that were
looked at are contained --

MS. O'CONNELL: I mean, we
looked at chemical oxidation, in-
situ chemical oxidation --

MR. HENDERSON: Chemical
oxidation is not very effective on
the chlorinated solvents.

MS. O'CONNELL: It's not at
this site.

But in addition to it not
being effective, there are a lot
of issues with respect to this is
a highly developed community of
commercial and residential --

MR. HENDERSON: That's
exactly why these reductive agents
would be exceptionally applicable.

They could be injected in the hot
spots without intrusiveness into
the community.

MS. O'CONNELL: Well,

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injecting any agent and getting it
to disperse within an aquifer is
always a tricky proposition. It's
never that simple.

And when we looked at, for
example -- even though the
chemical oxidation is not a good
technology, we looked at
distributing the oxidant, and it
would be quite disruptive to
get -- and it would be a number of
injection points to distribute.

This is not a very small area,
even though the area of active
remediation is smaller than the
entire plume.

So, there's a lot of
distribution issues as well.

MR. HENDERSON: How many
injections have you done to
represent that would be such a
problem?

MS. O'CONNELL: Well, when
you're injecting something into
the aquifer, distribution is

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always your issue.

In fact, this is a decent
aquifer, being a sand aquifer, for
that. But we're doing that now in
a site in Camden, we're doing
chemical injection --

MR. HENDERSON: This isn't
making sense to me because it was
stated that this is a good
aquifer, that the soil is sandy,
and the material moves. So, soil
vapor extraction would be perfect,
although we haven't talked about
how you're going to address NAPL
in the soil vapor extraction, but
we'll go on to that as the next
question.

Now, you're telling me it's
difficult to move any product that
is injected because the aquifer is
tricky. So, I'm not sure, which
it is.

Is it not tricky for vapor
extraction and it's tricky for
inj ection?

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MS. O'CONNELL: It would
require a large number of
injection points at a minimum --

MR. HENDERSON: Vapor
extraction would require a lot of
recovery points.

You can't have it both ways.

MS. O'CONNELL: We haven't
selected the extraction for the
groundwater portion of the
plume --

MR. HENDERSON: It sounds
like —

MS. O'CONNELL: We are
proposing it to address the soils
in the very shallow groundwater
underlying the Sun property.

But we did see some problems
with soil vapor extraction,
technical problems like iron
founding and other issues that may
be surmountable but certainly
would be problems.

All of these -- it's never
easy in any of these remedies, but

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we're kind of weighing pros and
cons. So, we did not select
soil -- we did not think soil
vapor extraction was the best
technical option for the
groundwater.

MR. HENDERSON: I think
you've made some bad assumptions
with regard to injection. I think
you ought to look at some of the
literature that's available, some
of the products that are
available.

This can get done for a
fraction of the price in a
fraction of the time using those
technologies.

Thank you.

MS. ECHOLS: Thank you.

Any questions on this side?

Ma'am, would you like to
come up?

Everyone will not be able to
hear you.

Will you please come up?

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Don't forget to state your

name.

MS. TULLY: My name is
Patricia Tully, and I am just
here -- I live on New Brunswick
Avenue next door to some children
that I'm concerned about.

And I just want to know, I
probably won't live long enough to
see this completely finished, but
I just want to know, have they
investigated anything in Manasquan
with the other cleaner that's
downtown?

There's another dry cleaner
in town in Manasquan.

You know, are they doing all
the right stuff?

MR. WESTGATE: The dry
cleaners in general --

MS. TULLY: I just wondered,
do they have certain rules?

MR. WESTGATE: Dry cleaners
in general, back in the '60s up
to, like, 1990, there wasn't a lot

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of controls on the industry.

So, part of what EPA did
when they put together the
Superfund program, they also put
together the RCRA program. And
the RCRA program is designed to
track all these hazardous
chemicals from cradle to grave.

So, any dry cleaners that
would be operating would be
subject to the RCRA rules. In
other words, if they get a hundred
gallons of material they're using
in their facility, they have to
account for a hundred gallons when
they're done with it.

In addition to that, a lot
of the dry cleaners have gotten
away from this mom-and-pop thing
where they have eight or ten
washers in the building. There's
a dry cleaning plant --

MS. TULLY: Where they send
it out?

MR. WESTGATE: Right.

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So, you'll drop off your
clothes at White Swan, and a truck
will come by and pick up a load
and bring back clean ones from
their plant, which is very
controlled.

MS. TULLY: That1s good to

know.

MR. WESTGATE: You don't get
the perc that you had in the past.

MS. TULLY: The other thing
is we're near the bike path and we
are also near a water system and
we're near the playground.

There's a lot of water involved
where we are, near the cemetery.

So, we're -- like, we're not
exactly in the area that we're
talking about, but we're sort of
on the edge of it. And I know our
neighbors are worried that the
people across the street from us
are more worried than we are
because they think they're more
susceptible. We're on the other

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side of Atlantic Avenue.

Is that area contaminated

too?

MR. WESTGATE: To the south?

No.

MS. TULLY: To the south.

We just got our postcard on
Friday for the first time. That's
the first time -- I have friends
who are on the other side that
have been involved, but we never
were notified with a postcard
before to come to a meeting.

So, I just wondered, are we
involved in that?

MR. WESTGATE: South of
Atlantic Avenue, you're talking
east of Manasquan Circle?

MS. TULLY: Yes, east and

south.

MR. WESTGATE: So, here's
Manasquan Circle, and you're
talking about the area down in
here.

Where you see the colors,

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this light blue edge, that's the
outside edge of our contamination.

MS. TULLY: Oh, okay.

MR. WESTGATE: South of
there is clean.

MS. TULLY: I know we're on
the edge of --

MR. WESTGATE: You're here,
where you're not seeing
contamination. The groundwater is
flowing perpendicular to these
blue lines. These blue lines
represent the groundwater
gradient. So, the groundwater is
flowing perpendicular to those
lines, and you're kind of -- we
call it side gradient.

So, you're okay.

MS. TULLY: I just wondered,
and probably some other people are
here for that reason too.

That basically was all I
needed to know. Thank you very
much.

MS. ECHOLS: Thank you.

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Sir?

MR. STRAUB: Good evening.

I'm Carl Straub. I live on Willow
Way in Manasquan.

My property line is in the
middle of Judas Creek, and I'm
about two blocks west of the hot
spot at Barlow's. It doesn't
indicate on your map that I'm in a
very highly toxic area.

But when you're talking
about a thirty-year process of
cleaning water and shooting it
down Judas Creek, I get a little
nervous, particularly because
Judas Creek floods about eighty
feet into my backyard every time
you get a heavy rain because of
all that groundwater coming from
Foodtown, from the wooded area you
mentioned.

So, my question is, what is
the treatment plant you were
speaking of to kind of clean up
the water that's going to be

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pumped out of the more toxic
areas ?

MR. WESTGATE: Okay.

Just to address your
flooding issue, we had a phone
conversation with Congressman
Smith's office about a week or ten
days ago, and this flooding issue
is kind of new to me. I hadn't
heard about it.

This year, we have a high
water table, so I realize there
are some parts of this
neighborhood that now have water
issues.

Our treatment plant we're
proposing or we're thinking of,
the wooded area just downgradient
of the Foodtown.

MR. STRAUB: A new plant?'

MR. WESTGATE: A new plant,
an EPA-constructed groundwater
treatment plant.

There's three alternatives
for dealing with the clean water

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that comes out of that treatment
plant. One is to inject into the
aquifer, a second is to discharge
to Judas Creek if it doesn't
destroy Judas Creek in the
process, or the third is to go to
this publicly-owned treatment
works.

So, I've done a groundwater
pump and treat from beginning to
end before. When we are in
design, we're going to look very
carefully at flooding issues. And
now that I've been sensitized to
it, I understand certain areas are
having that kind of issue. If
putting a ton of water in Judas
Creek is going to cause flooding,
that's the end of that proposal.

MR. STRAUB: There's also
another project that's on the
opposite side of Judas Creek from
our properties on Willow Way, and
that's Manasquan High School is
building a retaining wall in the

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wetlands buffer of Judas Creek to
reorient their football field to
put in a turf field which also
deals with lots of excavation and
drainage channels.

MR. WESTGATE: We have a
monitoring well at Manasquan High
School, and it's clean.

MR. STRAUB: Okay.

MR. WESTGATE: So,
certainly, like you said, this is
going to be a long-term process,
so our groundwater contamination
picture is going to shift and
change.

And, certainly, we're going
to stay on top -- I'm going to
stay on top of it to make sure
that if we're going into new
areas, that I sample the indoor
air of those houses, and, also,
that you don't have any problems
with new construction.

I gave you my card before.

MR. STRAUB: If you don't

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mind, I'll send you a photo of the
flooding.

MR. WESTGATE: I believe you
when you say it's flooded.

MR. STRAUB: Thanks very

much.

MS. ECHOLS: Ma'am?

MS. MAYER: Hi. I'm Pat
Mayer. I live in Sea Girt
Estates, Gregory Place.

So, one, is this
presentation on your website?

MS. ECHOLS: Yes, it is.

MS. MAYER: Maybe you could
give that to us at some point.

I think it's very obvious to
everybody here, based on these
four different alternatives,
alternative three is one year.

I don't know when you guys
consider $8 million, total capital
cost?

MR. WESTGATE: I'm sorry, is
that a soil alternative?

MS. MAYER: Alternative

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three on Page 10.

MR. WESTGATE: Okay, soil.

MS. MAYER: When I see
alternative two, it's going to
take about a ten-year timeframe to
achieve the goals. Alternative
three basically says, if I'm not
mistaken, that it would take a
one-year timeframe.

MR. WESTGATE: The
excavation.

MS. MAYER: One year versus
ten years. As a resident, it's a
no-brainer.

When you talk about $1.8
million, is that over a ten-year
period.

MR. WESTGATE: Yes.

MS. MAYER: So, do you have
any projected costs of what it
will be in ten years as far as
what engineering costs will be?

It's got to escalate from
the 1.8 based on --

MR. WESTGATE: Yes, we

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use --

MS. MAYER: That doesn't
include inflation.

MR. WESTGATE: We built
inflation numbers into that.

MS. MAYER: Okay.

Based on health -- I'm a
cancer survivor -- and real estate
values, again, in my opinion, it
is a no-brainer that for health
concerns you don't want this going
down ten years, thirty years for
all the other people that are
going to be involved in this.

Why would we risk having
safety issues when we could nip it
at the bud after one year?

MR. WESTGATE: Let me just
explain.

We're going to have a pump
and treat groundwater system
collecting the highly contaminated
groundwater. So, the 140 pounds
of PCE mass that's at the Sun
Cleaners, we're going to have a

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vacuum system working on that 140
pounds.

But any of the contamination
that's immediately downgradient,
this pink zone here, is going to
be collected by the groundwater
pump and treat system.

So, it's not like we're
going to ignore the 140 pounds of
PCE in the soil, we just picked a
remedy that's less intrusive to
Manasquan Circle, that's less --

MS. MAYER: Well, I don't
really give a flying flip about
traffic for one year in Manasquan
Circle.

(Applause)

MS. MAYER: I care about my
health. I don't want to go
through cancer again.

Have you ever gone through

it?

MR. WESTGATE: Not cancer,
no; a number of other things.

MS. MAYER: There you go.

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You don't want to go through it.

MR. WESTGATE: I understand.

MS. MAYER: And why, again,
would we risk the health of every
citizen in our community with any
kind of factor when we could just
get rid of it for $8 million?

Are you kidding me?

MR. WESTGATE: There's no
exposure pathway while the SVE
system is operating. The ground
surface is covered up. Nobody,
even if you were walking on the
Sun Cleaners property you would
not be exposed to that PCE in the
soil.

MS. MAYER: My concern,
again, is the health issues over
ten years. And not only that,
more importantly than caring about
the traffic around Manasquan
Circle for one year is my concern
about real estate values.

When people drive through
Manasquan Circle for ten years or

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whatever that is and see vents
here and Superfund cleaning here
and all that, there's got to be
statistics, and I'm sure you guys
know it, about how it can affect
real estate values.

Correct?

MR. WESTGATE: I understand.

MS. MAYER: So, why would we
risk that for ten years or thirty
years when we can nip at the bud
in one year?

So, it may cost $8 million,
but at the end of the day it's
going to cost us significantly
more if we let this go for ten or
thirty years.

So, from a health standpoint
and a real estate standpoint, $8
million sure sounds like a very
small amount of money to spend for
the impact that it can have on all
of us.

Thank you.

(Applause)

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MS. ECHOLS: Before we take
another question, let me just give
the website. So, if you have a
pen, I can give it to you now
because some of you may want to
leave a little earlier and I want
you to have it.

It's www.epa.gov/region02/
superfund/npl/whiteswan, one word.

UNKNOWN: It's on the
postcard.

MS. ECHOLS: Yes, it is on
the postcard.

Ma'am?

MS. VERDE: Hello, Mr.

Westgate. My name is Catherine
Verde. I live in Manasquan, 6
McGreevy Drive, and I'm a parent.
My children are in the Manasquan
School District.

And I'm a little concerned,
you had mentioned earlier some
people had received postcards.

I was wondering, was our
school in any way or form

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contacted about this meeting or
any of the meetings for this
matter?

MR. WESTGATE: We published
an ad in the Asbury Park Press, an
ad in Coast Star.

Ed Donovan, did you put my
ad up in the Manasquan website?

MR. DONOVAN: On the
Manasquan facebook page and I'm
not sure what else.

MR. WESTGATE: You may not
have gotten a postcard.

MS. VERDE: I'm not speaking
as a resident. I definitely did
not get a postcard.

What I'm concerned, and I
want to be clear, did you guys
directly send a mailing or have
some kind of communication with
the school district?

Because I think it would be
imperative that our school
district should be here,
especially when the creek there,

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you were thinking of pumping some
water into that, and that is right
at the buffer, as Mr. Straub said,
of our school.

MR. WESTGATE: I briefed Ed
Donovan of Manasquan about this
meeting, what we're proposing.

Part of my job description
is to explain this and go over
this with officials. If Ed or
somebody from Manasquan called me
up and wanted me to come and brief
them again, I'd be happy to do
that.

School district --

MS. VERDE: It's not your
jurisdiction.

Is that what you're saying?

MR. WESTGATE: I'm federal.
My jurisdiction is the whole
country.

MS. VERDE: Okay.

So, it's safe to say that
the school was not notified with
the exception of maybe putting it

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up on the website.

MR. DONOVAN: I don't know
if we ever contacted the Board of
Education or the Administration at
the school.

MS. VERDE: Okay.

MR. DONOVAN: I think what
Mr. Westgate is saying is that
he'll make himself available to
the Board of Education.

MR. WESTGATE: Yes.

And I have done indoor air
sampling in Manasquan School in
years past, so they know about
this PCE issue. We sent them
sample results.

MS. VERDE: The school
district?

MR. WESTGATE: Manasquan
High School.

MS. VERDE: How long ago was

that?

MR. WESTGATE: I'd have to

look.

MS. VERDE: Okay.

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MR. WESTGATE: I sampled

450 .

Here's my card. Call me up,
and I'll give you that
information.

MS. VERDE: Definitely, yes.

MR. WESTGATE: Actually, I
don't know if I can release the
information to you, but I can
certainly tell you when we did it.

MS. VERDE: That would be
helpful.

MR. WESTGATE: And there
wasn't any systems installed.

MS. VERDE: Okay. Thank you
very much.

MS. ECHOLS: Ma'am, in the

back?

MS. WARNER: My name is
Melissa Warner. I live on
Briarwood Avenue in Sea Girt
Estates.

First of all, we didn't
receive a postcard about tonight's
meeting, just to make a note of

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that.

When you were going over
health risks, potential health
risks, you talked about soil
contamination regarding
construction workers and utility
workers. Then you were talking
about risk to residents, I believe
it was groundwater and vapor.

So, is there any risk
assessment in terms of soil to the
residents in terms of growing
things and harvesting things from
soils on residential property?

MS. METZ: Well, the
contaminated groundwater is twelve
to sixty feet below the ground
surface, so it's not reaching the
surface soil that you would be
growing your produce and things
like that.

The only contaminated soil
that we're looking at is that
directly in the source area, so
that's the two dry cleaning

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properties. That's where we have
soil contamination in the surface
and in the subsurface.

So, because the groundwater
is not coming in contact with the
surface soils where you'd be
growing things, there isn't a risk
posed by that.

Not only that, but the
contaminants we're dealing with
are volatile organic chemicals
that are not taken up into plant
systems and distributed through
the fruit.

So, there are two good lines
of evidence there to suggest that
there's not a problem with
harvesting anything from your
soils.

MS. VERDE: They're the only
soil samples that have been taken
onsite.

Correct?

MS. METZ: Correct.

MS. VERDE: Thank you.

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MS. ECHOLS: Ma'am?

MS. WOOLEY: Ursula Wooley,
Magnolia Avenue.

I'm concerned about the
people in the neighborhood that
are still using that aquifer for
watering their produce, their
gardens, their lawns. They're on
timers and they go off in the
morning for hours.

MR. WESTGATE: Early on in
the site history, we actually got
the ATSDR -- they're part of the
Centers for Disease Control,
they're our risk assessment part
of the federal government.

We had them do an evaluation
looking at the most contaminated
groundwater in our plume and
analyzing using it to fill your
swimming pools, using it to water
your lawn, using it for washing
cars, putting on your vegetable
garden, all of those exposure
pathways.

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And even at the maximum
contaminant level, there was not a
significant risk that would cause
us to go in and, let's say, shut
an irrigation well.

MS. WOOLEY: That's used for
washing your car.

What about the neighbor
that's out in the garden weeding
and breathing it?

You say it dissipates into
the air and breathing in that...

MR. WESTGATE: They looked
at those specific activities
watering lawns, vegetable gardens,
swimming pools. In other words,
people using, being exposed to,
that water a certain amount of
hours every day all through the
season where you'll be growing
lawn or vegetables in your garden.

We analyzed it, we looked at
it. It's safe.

MS. WOOLEY: All right.

MR. WESTGATE: There's

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documents in the public record,

ATSDR Health Assessment, that talk
very specifically about adult
usage, children usage, exposure
time, body weight. It's a pretty
convoluted process.

MS. ECHOLS: Okay, sir.

MR. MCDONALD: Hi. I'm Ed
McDonald, this is my daughter
Olivia. We live on Sea Girt
Avenue right near Rod's.

And my biggest concern is
the vapors, the volatile exposure
in the basement. When I do the
laundry in the basement, every
time I walk in the room I feel
like I'm going to pass out because
it really smells.

You said you're going to
test another twelve hundred homes.

I want to know how far east you
plan on going to test those
volatile organic chemicals.

MR. WESTGATE: Atlantic

Ocean.

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MR. McDONALD: How long do
you estimate that is going to
take?

MR. WESTGATE: I can't give
you a schedule.

The Environmental Response
Team is our national EPA
contractor, and they make
themselves available to me fifty
houses at a time. The last time
they did that was in early July.

I sent out 125 packages to
people in a certain area, and I'm
working my way east. We
identified a number of houses that
we're interested in participating
and signed the access agreements.

I will continue to do that
through the area. But they're not
my contractor. I can't say:

Listen, this is the schedule.

MR. McDONALD: Let's hope
it's not high, right?

What should I do to help
reduce...

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MR. WESTGATE: If you call
me, give me your name, telephone
number, address, the next time my
contractor is available and I'm
sending out these invitations to
have your houses sampled, I'll put
you in that group.

MR. McDONALD: Thank you.

MS. ECHOLS: Ma'am?

MS. BARON: My name i s
Barbara Baron, also on Briarwood
Avenue in Sea Girt Estates.

I've met you. You've been
to my home. You put a canister in
my house in 2001, right before the
end of the year.

I attended a meeting with
EPA that was held in Sea Girt
municipality at that time, where
they instructed us then to empty
our pools if we filled them with
well water because they said that
the perc would come together at
the bottom of a pool, that we
should refill them with city

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water, and they also instructed us
then to not put any well water on
any produce that we had.

And since that time, I never
have. That was the message at the
meeting. There was a big
discussion over whether we should
be paying water and sewer by
refilling our pools with the city
water. A big argument ensued as a
result of that.

I'm wondering, what changes
have happened with the
contamination in the water since
2001 'til now?

MR. WESTGATE: The ATSDR
people that did our analysis never
came to those conclusions. So, as
far as I'm concerned, I trust our
ATSDR people.

MS. 0'CONNELL: The
groundwater plume is contaminated.

So, if you have an irrigation well
within the plume, it's going to be
pulling out contaminated

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groundwater and there's going to
be some exposure.

But the type of exposure for
a swimming pool is different than
if it's in your house and you're
drinking it. There are different
types of exposure. So, that's
what was looked at.

So, when we did our risk
assessment -- we did a risk
assessment recently with respect
to all of the data that we
collected during the
investigation, and it indicated
that while there's some limited
risk, there is going to be some
type of exposure, it's going to be
low for those particular uses.

People can choose not to use
that water

MS. BARON: These are the
instructions that were given at
that meeting.

MS. O'CONNELL: From who?

MS. BARON: From Sea Girt in

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2000 --

MS. O'CONNELL: From the
local officials?

MS. BARON: It's a
government-based meeting held in
Sea Girt Municipal Court, again in
2002. I didn't dream that.

We all walked away, every
single person I know that had a
pool emptied their pool and
refilled it with city water and
never put well water in the pool
since.

So, are you telling me it's
okay to put well water in the
pool?

MR. WESTGATE: Yes.

MS. BARON: Yes. Okay.

That's the first thing.

MS. 0'CONNELL: It's always
advisable if you have a private
well, the recommendation is always
to sample it once a year. That's
not a requirement, but then you
would know what's in your well and

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you can make whatever decision you
want to make.

MS. BARON: Okay.

Last two things quickly.

Since I had the canister in
my house, I also did not receive a
postcard. Neither did any of my
neighbors. I'm wondering why I'm
not on that list, since I've
gotten a big report from you that
I keep on file in case I ever want
to sell my house. And I would
appreciate being on the list. I
did sign in.

And I'd like to echo the
sentiment of some of my neighbors
here. I would also vote for one-
year remediation and the
possibility --

(Applause)

MS. BARON: — and the
possibility of looking into some
alternatives that the first
gentleman spoke about, if there
are other ways to quickly

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remediate it.

Thirty, forty years from
now, I'm going to be well into
retirement and hoping that the
kids that are behind me are living
in a safe place called Sea Girt.

So, thank you.

(Applause)

MS. ECHOLS: Sir?

MR. LAUGHLIN: Eric
Laughlin. I'm the principal at
Old Mill School.

I know that we are not in
the effected area, but I'm just
going to ask that between you and
the Town, that you guys are
communicating with each other and
that the information gets out to
parents.

Because I don't see any
parents from my school back here,
and we do have kids that are in
this area. So, that's what I
would ask you, because, naturally,
parents are going to come at some

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point and ask me questions, and I
want to be able to refer them to
the right place.

Because I found out through
seeing it on the Patch and a
member of our school came and told
me about it.

So, that all I'm asking for,
that there's some communication on
both sides so that parents are
informed, they know what to do and
who to go to.

MS. ECHOLS: Sir, did you
sign in?

MR. LAUGHLIN: Yes, I did.

MS. ECHOLS: Okay. Thank

you.

Any more questions?

Sir?

MR. GRYGIEL: Hello. My
name is Fred Grygiel. I live at
2118 Old Mill Road, Sea Girt;
actually, Wall. It's a misnomer.

(Laughter)

MR. GRYGIEL: But it's nice

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115

on property values.

Speaking of the principal, I
live right across from the school,
and that's really why I'm here,
for a number of reasons.

And it caused some concern
when I heard earlier there was
little direct contact with school
officials. I mean, placing an ad
wherever those ads were placed, to
me, does not constitute contact
with the Board of Education,
contact with the Superintendent,
contact with the building
principal.

So maybe going forward --
not "maybe", I think it's
essential that going forward
especially if the thirty-year
option, which I totally agree with
Pat is just absolutely
unacceptable, thirty years is a
long time for anything.

And the principal reason
being in terms of the risk factors

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for the children who are living in
the area and also attending the
school that1s on the fringe that
may at some point be inside, not
just on the fringe, because these
studies, as far as I know, have
plus or minus attached to the
fringes over time as they may
change as the movement changes.

So, Old Mill School -- I
hope it never happens -- may at
some point be in the zone.

MR. WESTGATE: Old Mill
School is up here, isn't it?

MR. GRYGIEL: Yes. I live
right across the street.

I want to make sure that to
the extent that there is any
variation on those borders -- and
I have to believe that in all
science there's variation on the
borders -- that the attendees of
that school who are also in the
neighborhood have to be monitored
for some health effects over the

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entire period.

And if it goes for thirty-
years, I think there has to be
humungous attempts to keep track
of the students who are making
their way through that
neighborhood then through that
school in an area that -- whoever
put the announcement on Wall Patch
used a headline which I thought
was absolutely frightening, and I
think if you take a look...

It goes to all the people
who are thinking about moving into
Wall or Sea Girt. The EPA -- it
says, the EPA's headline:

Astonishing toxic legacy at former
Wall dry cleaner site.

Now, if I hear that, I got
to tell you, I'm rethinking my
willingness to go to that area to
engage in any kind of transaction,
let alone a real estate
transaction.

So, whoever concocted that

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headline to maybe induce more
people to come to the meeting, I
don't think you needed to.

Obviously, you have a pretty nice
attendance.

"Astonishing toxic legacy"
to me carries a long period of
time. And I think the argument
for not making it a legacy but
making a transaction, that maybe
if the Bank of America could pop a
little more than they're willing
to pop for that extra $8 million,
maybe more aggressive negotiating
on your part will convince them
that a year is one heck of a lot
better than thirty years.

MR. WESTGATE: I understand.

Just as a note, we did
sample the indoor air in Old Mill
School early on in our process.

MR. GRYGIEL: How early?

MR. WESTGATE: Probably
around 2000.

MR. GRYGIEL: And we're now

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in 2013.

MR- WESTGATE: Yes.

I began my indoor air
sampling based on where the
contamination is. So, you're side
gradient, you're north of our
plume.

See the groundwater flow
arrows there?

So, you're not being
exposed. The groundwater flow
arrows are the blue ones.

Yes, you're right the
boundary of the plume will change
over time, and I will watch that.

MR. GRYGIEL: Will you
notify all of us, especially the
building principal and the Board
of Ed?

MR. WESTGATE: Just to be
clear, I briefed Wall Township
officials, Sea Girt officials, and
Manasquan. I did not go through
all the different school districts
and brief them. I assumed that

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some of that might flow down.

Maybe Cecilia and I need to
incorporate more of an outreach
program to the schools in the
future.

MR. GRYGIEL: Because that's
our future.

MR. WESTGATE: I have three
kids, I know.

MR. GRYGIEL: Talking to
them directly -- if you understand
some of the local politics, it's
much more effective to talk to the
schools directly rather than
relying on the Township to talk to
the school, not that it doesn't
happen.

MR. WESTGATE: Okay.

We hit all the schools --

MR. GRYGIEL: Sea Girt
School, all the private schools,
Brookside?

MR. WESTGATE: If they're in
the area where I was working my
way across.

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We hit the public schools
first early on. And if the
private schools were in the
contaminated zone, as I worked my
way from west to east we would
contact them and do sampling.

MR. GRYGIEL: Sea Girt
Schools also?

MR. WESTGATE: Yes.

MR. GRYGIEL: Is there a way
to get a list of all the schools
that were sampled for either
air -- Old Mill has a creek that
runs right along it, and for the
life of me I have no idea where it
comes from.

MR. WESTGATE: Steve calls
it the unnamed tributary that
feeds into Hannabrand Brook.

We sampled the water and we
sampled the sediments.

MR. GRYGIEL: Old Mill Creek
maybe we can call it, so we know
which one it is?

That creek floods a lot.

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There's a broken dam up at -- I
forgot

UNKNOWN: Allaire State

Park.

MR. GRYGIEL: And we had
floods down there and the streets
were flooded, et cetera.

So, again, the water there
also constitutes an unknown, at
least for someone who has
grandchildren in school.

What are the risk factors?

Does that creek present any
additional incremental risk
factor?

MR. WESTGATE: If you
contact me, I can give you the
list of the schools that have been
sampled and when they were
sampled.

I don't think I'm allowed to
give you the results. I can check
with our attorneys and see.

Generally -- well, it's public
information, so you'd probably end

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up with them anyway.

MR. GRYGIEL: But, again,
the nine criteria, I think number
nine was community acceptance.

MR. WESTGATE: Yes.

MR. GRYGIEL: I have a
message which I'm sure you've read
already: Thirty years is not
acceptable.

MR. WESTGATE: Okay.

(Applause)

MS. ECHOLS: Sir, in the

back?

MR. SULLIVAN: John
Sullivan. I live in Wall. My
mother is here. I consider myself
a lifelong resident.

I read the report last
night. You mention cancer risk
goes back forty plus years 1960,
fifty plus years.

Can you identify some of the
cancers that are associated with
these cancer risks?

Let me say this: I was

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reading my mother's report at the
dinner table tonight eating
dinner. The basement was twelve
parts per billion. The dinner
table, which was five foot away
from where canister was placed,
for thirtysome odd years, how many
people have been eating dinner
right there?

What are some of the cancers
associated with these high risks?

MS. METZ: Well, the
chemicals we're talking about, PCE
and TCE, include cancers of the
liver and kidneys. So, you know,
those are potential outcomes of
being exposed to PCE at various
levels.

Everyone reacts differently
to exposure. The levels that we
use to evaluate the indoor air
that we've collected in your
mother's home are based on what we
call the ten to the minus six
cancer risk. So, that is one

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excess cancer in a population of
one million with exposure to that
level of that chemical.

I know this gets very
complicated, but in terms of what
the individual health impact on
your mother may be or on you or
your family, I cannot speak to
that. All I can say is that what
we do is we look at what levels
are in the homes, what risks those
may pose, and what we need to do
in terms of remediation to
eliminate that exposure.

MR. SULLIVAN: Is there a
government program that comes into
play for years back?

I have friends that I grew
up with. I live on Wall Drive,

250 yards away from White Swan.

Plenty of people my age have moved
away. They don't know. They
could be my age, older. We don't
know what cancers we might be
suffering years down the road.

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MS. METZ: I think one
important point to make is we
sampled over 450 homes in the area
and only a little more than 35
have actually required a
mitigation system. So, we're not
talking about a widespread vapor
intrusion problem throughout the
area. It's fairly limited to
certain areas.

And, you know -- but, again,
in terms of a government program,
in terms of finding out what, you
know, health impact you may have
experienced from any kind of
exposure that you may have had in
the past, that's not something we
can answer for you here tonight.

I know that doesn't --

MR. SULLIVAN: Will that be
included in future studies?

Possibility?

MS. METZ: The EPA doesn't
do those kind of assessments.
That's the Department of Health

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and New Jersey Department of
Health does that. Our Agency for
Toxic Substances and Disease
Registry, ATSDR, did the lawn
watering scenarios. We can put
you in contact with people from
those organizations if you have
specific questions.

There are doctors within --
UMDNJ has a whole cadre of doctors
that specialize in environmental
exposure, that know what kind of
tests you can do to evaluate, you
know, what effects exposures can
have on your body.

And we can definitely talk
afterwards and provide you with
some additional resources.

MR. SULLIVAN: I appreciate

it.

MR. WESTGATE: With regard
to the sampling, when we did the
sampling in July, just a few days
ago I got the results back, so
I'll be sending you a letter

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talking about your particular

house and our opinion on health

risk associated with that.

MR. SULLIVAN: We have a lot

of long-term residents here

that -- probably has a big impact

on this whole area.

MR. WESTGATE: The risk that

we're talking about is so low,

we're talking about a seventy-year

lifetime risk that you'd have to

spend in that space breathing that

air over a whole lifetime to

increase that cancer chance.

MR. SULLIVAN: My neighbor

two doors down who lives in the

basement. Thirty years ago, we

lived in the basement. We didn't

know what was going on. We played

in the woods right behind White

Swan.

MR. WESTGATE: There's no

risk associated with playing in

the woods.

MR. SULLIVAN: I appreciate

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your time.

MS. ECHOLS: Thank you.

Ma 1 am?

MS. KARITSKY: Good evening.

Pilar Karitsky, 2166 Gregory
Place.

I'm just curious, this map,
when was it done?

MR. POSTEN: The data on the
map was collected in 2010.

MS. KARITSKY: And what was
the one previous to that?

MR. WESTGATE: Those are
just different maps from the same
report.

The sampling finished up in

2010 .

MS. KARITSKY: So, it took
ten years to make the map?

MR. WESTGATE: No.

The Remedial Investigation
was conducted over three or four
years, starting 2007 through 2010.

Then they submitted a series of
draft reports, which we had to

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finalize. And the report is now
finalized and available to the
public.

MS. KARITSKY: I understand.

So, the lady who spoke
before who had her can in her home
was in 2000.

Correct?

MR. WESTGATE: Yes.

MS. KARITSKY: And that was
the beginning of the
investigation?

MR. WESTGATE: No.

That was the indoor air part
of the investigation. This
comprehensive thing that was
conducted by AMEC was started in
2007 .

There have been a number of
different government
organizations, like the Monmouth
County Health Department, then
State of New Jersey, then Bank of
America hired their own
contractors. So, there's been a

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series of investigations, but this
is the —

MS. KARITSKY: Culmination.

MR. WESTGATE: — final,
big, comprehensive, very-
thorough --

MS. KARITSKY: Very
thorough.

And how long do you intend
to maintain this picture for us or
will there be another one, another
evaluation?

MR. WESTGATE: There will be
ongoing --

MS. KARITSKY: Five years?

Two years?

MR. WESTGATE: After we make
the decision about which
technologies to use for the soils
and which to use for the
groundwater, we go into the design
phase. When we hire designers,
the first thing they do: Your
data is too old. We want another
round.

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MS. KARITSKY: Yes.

MR. WESTGATE: So, I expect
in the next year or two we111 be
out there sampling those wells
again that we put in --

MS. KARITSKY: And that will
take two years?

MR. WESTGATE: No, a lot
quicker.

MS. KARITSKY: Like a year?

So, a year and a year,
trying to calculate...

Where I live at 216 6 Gregory
Place is right by St. Catherine's,
behind Barlow's.

MR. WESTGATE: St.

Catherine's is up here and
Barlow's is here.

MS. KARITSKY: I'm between.

That's where I live, right around
there.

So, that's, like, a pretty
intense zone.

MR. WESTGATE: Yes.

MS. KARITSKY: I don't know

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if Barlow's using well water for
their irrigation and to feed all
those plants, does that perpetuate
the problem?

MR. WESTGATE: No.

Actually, what Barlow's is
doing is pumping that shallow
aquifer, bringing the
contamination into the area, and
when they spray it around in their
greenhouses and all that, they're
doing air stripping.

MS. KARITSKY: So, that is
beneficial.

MR. WESTGATE: Correct.

But I've sampled the indoor
air in Barlow's to make sure that
none of those workers or the
customers or the owners of the
property are having health issues
related to that process.

And when we go ahead and do
our pump and treat system, that's
going to stop. We're going to
find an alternative way to have

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Barlow's water their inventory
without using any contaminated
water because I have to clean that
up.

MS. KARITSKY: Yes. Now I
understand.

So, therefore, when I
built -- I just had a well done
actually.

MR. WESTGATE: How deep?

MS. KARITSKY: I don't know.

Honey, how deep?

Forty, is that a problem?

MR. WESTGATE: I'd have to
sample the well.

MS. KARITSKY: Shouldn't the
Town have told me if there's a
problem?

MR. WESTGATE: I don't
control the well permit process.

But, also, think back to the
ATSDR evaluation, where we looked
at the highest levels of
contamination --

UNKNOWN: DEP handles wells.

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MR. WESTGATE: Our ATSDR
process looked at the highest
level -- if you had a well right
in our highest contamination —

MS. KARITSKY: That's here.

MR. WESTGATE: No, you're
about 900 parts per billion.

There's 75,000 parts per
billion over near the source
areas.

MS. KARITSKY: All right.

MR. WESTGATE: ATSDR did
that evaluation and looked at the
highest concentration and the
specific uses -- water vegetable
gardens, water lawns, filling
swimming pools -- and they didn't
see a risk that was of concern for
those using that water.

MS. KARITSKY: So, they
would have pretty much known, the
Town.

MR. WESTGATE: Part of my
job -- I'm a geologist --

MS. KARITSKY: Yes.

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MR. WESTGATE: So, I study
the subsurface problem. And then
with my boss Kim, we figure out
the best way to deal with it.

But while we're doing all
that, while we're going through
all the legal machinations and all
the design folks and all that, I
am not allowed to let anybody be
exposed to that above a certain
health-based level, whether it's
breathing, drinking, whatever.

So, that's part of my job
responsibility, to make sure those
exposures are not happening. If
they are, I do something about it
right away.

MS. KARITSKY: So,
therefore, your responsibility is
to allow us to tell, for example,
the Town: Look, they can't
build -- they can't do a well on
this property.

MR. WESTGATE: Again,
federal government does not do

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well permits.

MS. KARITSKY: No. I know

that.

But you are responsible to
tell the person like me, I'm right
here, you tell me, that's it?

Is that what you're saying?

MR. WESTGATE: If the ATSDR
in our studies of our
contamination and our proposed
uses, if ATSDR said to me that
certain areas of this plume you
cannot let people use for
irrigation purposes, I would have
talked to DEP, they would have
established a well restriction
zone, and you would not have been
able to put a well in.

MS. KARITSKY: Okay. Good.

Thank you very much, and I
wish you well. "Well".

(Laughter)

MR. KILGALLEN: Kevin
Kilgallen. I live on Lincris
Lane, which is on the southern

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border of the zone.

Just specifically, were
there any surveys made of the
number of irrigation wells in the
zone or not?

MR. WESTGATE: I think early
on -- I think Monmouth County,
when they first got involved in
1999, they sampled all of the
irrigation wells. Obviously,
there have been more installed
since then.

As part of our Remedial
Investigation, Steve and his
company, AMEC, sampled a number of
them.

MR. KILGALLEN: Just
specifically, is there a report
that indicates how many are in the
zone?

MR. WESTGATE: I don't
have -- the State of New Jersey
governs the permit process for
irrigation wells. Their count is
probably what you're looking for.

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The number of irrigation

wells

MR. KILGALLEN: So, you
never did a survey.

MR. WESTGATE: I never
conducted a survey of all the
irrigation wells, legal and
illegal, in Wall Township, Sea
Girt, and Manasquan, that's
correct.

MR. KILGALLEN: Okay.

So, I don't see how -- it
seems to me that would be the
first step in analyzing, you know,
the number of uses of irrigation
water, see how many residents
might be exposed to irrigation
well water.

MR. WESTGATE: Well, the
modeling that ATSDR did was
specific to the actual process.

So, they made assumptions.

Let's say a guy is retired,
he spends two hours a day watering
his lawn. Instead of a sprinkler

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system, he's using a handheld
hose. If he spends two hours a
day five days a week — I'm not
sure exactly what parameters they
used, but they go through this
whole process where they model
these various exposure pathways
and then come up with a number
which indicates if it's a health
risk or not.

MR. KILGALLEN: So, that
model does not depend on the
actual number of irrigation wells
in the zone.

Is that what you're saying?

MR. WESTGATE: I don't work
for ATSDR. I don't know if they
inquired into the number of wells,
irrigation wells, present in Wall
Township, Sea Girt, and Manasquan.
I don't know.

If you want that number, I'm
sure we can dig it up.

MR. KILGALLEN: Okay. Thank

you.

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MS. ECHOLS: Sir?

MR. WERNER: Joe Werner,

Briarwood. I know Matt.

That map, can that be sent
out to everybody who signed up
tonight so that they can look and
see where their house is and what
the density of the contaminated
plume is and so on?

MR. WESTGATE: That specific
figure is included in this
Remedial Investigation report,
which is available in the Wall
Township Library, hard copies that
I delivered and electronic files.

So, if you have a computer,
you can borrow the disk, copy the
files, copy those specific
figures, onto your computer.

Also, my office in New York,
which probably doesn't help much,
has a record room where those
documents are available either to
view the hard copies or to get the
electronic files.

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On the website, the site
that Cecilia rattled off, that
long URL address, there's a link
to the Proposed Plan which has one
of the figures attached to the
back of it.

MR. WERNER: So, it's going
to be complicated.

MR. WESTGATE: Proposed
Plans are on the table outside.

MS. ECHOLS: They're all

gone.

UNKNOWN: They're illegible.

MS. ECHOLS: If you go to
the website, the Proposed Plan is
on the website, along with the
Powerpoint presentation, and you
can get both documents there and
you'll be able to see everything
legibly.

MR. WESTGATE: I'm also
looking at having the Remedial
Investigation report and the
Feasibility Study posted on the
EPA website so that you can go

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into our website and download that
document.

UNIDENTIFIED: It is on your
website. I downloaded and printed
it.

MR. WESTGATE: Okay.

UNIDENTIFIED: This is the
Remedial Investigation report,

June 28, 2 013. That's
downloadable and printable.

MS. ECHOLS: In addition, if
you call our records center at the
EPA office in New York, you can
also receive a copy of the
administrative record on a disk.

MS. MAYER: Out of the 450
homes, is there any map that shows
where the 3 5 are?

MR. WESTGATE: Most of the
homes that ended up getting
systems are close to the source
area, so Willow Road, Sea Girt
Avenue, in that area.

I have to be careful because
some of this information about

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specific sample results from
specific houses that would trigger
a system is private like your
health records. So, I can't tell
you what her cholesterol number
is, same kind of deal.

I have a database of all the
houses that I've sampled, even the
ones that have refused sampling.

And a number of people have
slammed the door in my face and
said they don't want it.

So, I could put that out
generically but without specific
addresses or specific information
that would say this house has a
system, that house doesn't.

I don't know if that helps
you answer whatever question
you're asking. But generally,
most of those 34 systems are close
to the source area where there's
high levels of contamination.

Some of those 34 systems
were houses where I gave the

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person the sample results and
although it wasn't above our
threshold, they were too worried
about it, and, you know, trying to
sleep at night, and they put a
system in themselves.

So, again, I'm not sure
where you want to go with that.

MS. ECHOLS: Sir?

MR. CLARK: My name is
Michael Clark. I live on Sea Girt
Avenue.

Matt, I've spoken to you in
the past. My wife and I moved in
five years ago, and you had
mentioned that there was a test
done.

But now we have a two year
old and a one year old. And you
had mentioned that if they're not
playing in the basement often,
it's really not a problem.

But in the area, there are
mostly cape style or ranch style
homes. So, you know, I'm

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concerned with the children not
playing in the basement but living
in a one-story building.

MR. WESTGATE: Well, if I do
a house without a basement, the
first thing we do in our indoor
air sampling --

MR. CLARK: We do have a
basement.

I'm just saying you had
mentioned that it's more --
there's higher levels in the
basement.

MR. WESTGATE: Right,
because that's the entry point.

That1s where the PCE vapors would
get in.

If I had sampled the house
previous to you owning it and if
there was a high enough level, I
would have put a system in. If
you don't have a system, it was
safe; either it was nondetect or
below our threshold level.

We had problems in the past

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where we would go in and sample
someone's house starting with the
indoor air and find out that this
guy who lives in the house has a
can of spot remover in the
basement, which is like pure
tetrachloroethylene in a can. In
the old days, they used that.

So, it would drive our lab
nuts. They'd find all these false
positives and think we've got to
move that person out right away
when in reality it was just an
anomalous situation.

So, now we have a process
where we start by sampling the
vapors underneath the basement
floor. Or if you have a house
without a basement, we sample
underneath the floor in the middle
of the house to see what kind of
vapors are piling up under there.

They have to pile up
underneath at a high enough level
to get into the house and cause a

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health issue; and, therefore,
until we see a certain number, we
won't come back and sample inside.
If it's very low underneath, it
will never get inside at a level
that would be any kind of health
risk.

So, it's kind of a two-stage
process. We're pretty thorough
about that aspect of it.

Again, if you have a concern
about your kids, you, as a new
owner, if you haven't seen any
samples and you didn't get it from
the previous owner, call the
number, my number, and I'll put
you on the list. The next time
our sampling team is available,
we'll include your house.

MS. ECHOLS: Ma'am?

MS. HOWE: Hi. Nicki Howe,
2106 Briarwood Avenue.

How do you test a slab

house?

MR. WESTGATE: We drill a

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hole through the floor by a closet
or someplace -- you know, some
people don't like that.

Let me finish.

We drill a hole through the
floor about the diameter of my
finger and we put a cooper tube in
there with a fitting and an Allen
screw that seals it up.

MS. HOWE: Obviously, you
could do that in my Yankee
basement.

MR. WESTGATE: I don't know
what a Yankee basement is.

MS. HOWE: A Yankee basement
is no bigger than the front, right
up to here, where my furnace is
down here.

MR. WESTGATE: If you have a
cement floor, then we have to put
a hole through the floor and
install the sampling port which we
cement in and seal up with a cap.
So, therefore, we're not opening a
hole for these vapors to come in,

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we're putting a sampling port,
installing it in your floor, and
sealing the cap.

Then we come back with the
canister, which has the vacuum,
and we attach that to the sampling
port, we open the valve, and we
let it draw air for 24 hours.

Some houses in the
neighborhood don't have basement
floors, they have dirt floors, and
we have to handle that
differently.

MS. HOWE: No.

MR. WESTGATE: But if you
want a sample of your house if it
hasn't been sampled before, call
me up and —

MS. HOWE: I've been there
44 years.

MR. WESTGATE: Whereabouts

is it?

MS. HOWE: Briarwood Avenue.

MS. ECHOLS: Sir?

MR. GRYGIEL: Just a

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hypothetical question.

MS. ECHOLS: Your name

again?

MR. GRYGIEL: Fred.

In the four alternatives,
has anybody taken a look at what
the disclosure statement would
look like that a seller of
property would have to disclose to
a potential buyer under each of
those scenarios?

In thirty years, I mean, in
that whole area there's going to
be, I'd say, probably thousands of
transactions. And the first
question as long as this issue is
open is going to be what do I have
to disclose to somebody from
California about what's going on
in the plume?

And that language is going
to be fairly critical to a
decision to move to Wall or avoid
Wall, Manasquan, or Sea Girt.

MR. WESTGATE: I'm sorry I

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didn't address this with you
before, and let me say it now --
let me answer your question first.

I don't have any control
over what you, as the seller of a
house, discloses to potential
buyers. Believe me, over twelve
years I've got hundreds of phone
calls about this very issues,
buyers, sellers, that kind of
thing. So, it's kind of a tricky
subject.

I think of this indoor air
vapor intrusion issue just like I
think of radon gas. One-third of
all houses that change hands every
year in the State of New Jersey
have radon gas problems where they
had to put a ventilation system
in.

People are comfortable with
that. They know what radon gas is
more or less, they know they get
the sample; if it's above a
certain number, they put the

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ventilation system in and it takes
care of the problem.

This is very similar to that
scenario. And the exception is
this is a temporary problem.

We're working on an aggressive
remedy to clean up the
groundwater. So, this is not
radon gas that's coming out of
rock formation for millions of
years and will continue for
millions more. This is something
that we've dealt with in ten,
twenty years, whatever it takes
for certain parts of this
neighborhood to clean themselves
up.

There's a lot of people who
because they hear "dry cleaning
solvents in the groundwater," they
get nervous about it, they don't
understand, they're not up to
speed like they are up to speed
about radon.

But believe me, the sampling

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for this is really-
straightforward, the threshold
numbers are really
straightforward, and $1,800
ventilation system takes care of
the problem.

Joe Warner, who was here
before, opted to put a ventilation
system in his house. I mean, this
is not -- some people get really
worked up about this, but it's not
that alarming.

I'm not sure, what was the
second part of your question?

MR. GRYGIEL: To the extent
that the alternatives -- the
alternative strategies lead to
disclosure statements, if, for
example, you considered
alternative four to be optimal,
what would that disclosure
statement looked, like which
included the thirty-year prospect
of that ongoing remediation?

That's the point I'm trying

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to make.

MR. WESTGATE: I don't have
any control over what you disclose
to a potential buyer of your
house.

MR. GRYGIEL: I understand.

MR. WESTGATE: What often
happens is I get a call from you
and you ask me -- you have sample
results, you send me a letter. I
said you're okay, you didn't need
a systiem. Sometimes you ask for a
copy of the letter and I send
that.

Then I get a call from the
buyer because their home inspector
picked up on the fact that this is
near a Superfund site. So,
therefore, doing their diligence,
they follow through and they will
ask the question, you know, have
you had any samples collected? If
so, what was the results?

And just like radon, just
like if the home inspector was

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looking at my neighborhood in

Hillsboro with radon -- I have

radon in my basement, but it's not

at that threshold level so I never

put a system in. I've been there

25 years, I've raised three kids.

I've got it covered.

MS. MAYER: Relative to

that, do you think, then, if

somebody was purchasing a house

that the right question is: Have

you had any samplings done?

And if they haven't, would

it be something, I suppose, that

we could negotiate to say: Before

I buy this house, I would like to

get some samplings.

Right?

MR. WESTGATE: I can't get

involved in the real estate

transaction, but certainly if

somebody wanted to get a house

sampled and they called me up I

could put them on the list. And

when my contractor is ready to

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come and do fifty more houses, I
could certainly do that one also.

Or in some cases, people
didn't want to wait for the
federal government, who takes
forever, and they got a private
contractor to catch a PCE vapor
sample in their indoor air and
then they sent those results to me
to talk about whether that's a
health risk or not.

And I'll be happy to do
that. I'm happy to provide
letters to people saying based on
this sample collected, we think it
is or is not a health risk.

MS. ECHOLS: Sir?

MR. GRIFFIN: Edwin Griffin,
706 Philadelphia Boulevard in Sea
Girt, just east of Eighth Avenue.

MR. WESTGATE: You're next.
I'm working your way.

MR. GRIFFIN: Come on down.

I'm confused with some of
your standards and your readings

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that you take. Page 2, for
instance, on your report. On the
right-hand column, 2001 New Jersey
DEP collected soil samples, blah,
blah, blah, showed levels 1,900
parts per million. Next sentence,
groundwater samples 13,50 0 parts
per billion.

That's a big difference, per
million or per billion. I don't
understand why the difference.

MR. WESTGATE: Soil uses
parts per million or sediment uses
part per million. Water uses
parts per billion.

MR. GRIFFIN: Okay. Thank

you.

MS. ECHOLS: Ma'am?

MS. BEAM: I'm Tricia Beam.
I'm a Wall Township resident. I
don't live in the area, but I'm
concerned.

You mentioned that the Bank
of America had contributed.

How about the people that

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owned Sun?

MR. WESTGATE: It was a mom-
and-pop organization and the
people are deceased and have no
assets. So, there was no one.

MS. BEAM: Who owns the
property, then?

MR. WESTGATE: It was bought

by —

MS. BEAM: Danino?

MR. WESTGATE: At this
point, we didn't see that she was
in any way linked to that. I
don't want to go into legal
aspects of how she acquired the
property, but, yes, as part of
Royal Majestic Builders Limited
Partnership or something, she
holds the title to that property.

MS. BEAM: Wouldn't she be
liable, then?

MR. WESTGATE: Well, if
someone is liable and they don't
have the assets to contribute,
then we don't pursue them.

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MS. BEAM: So, they still
get to keep the property and own
it?

MR. WESTGATE: We wouldn't
have any reason to seize the
property, but we will clean up the
property.

MS. BEAM: And you wouldn't
put a lien on it?

(Pause in proceedings)

MS. O'CONNELL: As an
option, after the remedy is
selected, you know, there will be
enforcement negotiation. And we
don't have any -- we have a lot of
attorneys but not any here tonight
because we're really here to
present the technical portion of
the remedy, but there will be
enforcement negotiations with any
PRPs that are identified to
discuss performance of the
selected remedy after it's
selected.

MS. BEAM: And my other

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question, will any of the towns
have to bear any of the costs
associated with the cleanup?

MS. O'CONNELL: None of the
towns are potentially responsible
parties. They haven't been
identified as potentially
responsible parties, so that's not
foreseen.

MS. BEAM: So, there would
be no cost to taxpayers other than
what you take federally.

MR. WESTGATE: There is a
tax that -- it doesn't exist
anymore. Superfund used to have a
tax not on private citizens, they
used to have a tax on chemical
companies and all these outfits
that manufactured these hazardous
chemicals that ended up getting
spilled here and there. The
process has changed now.

We get our Superfund money
out of the general federal budget,
which is taxpayer dollars.

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MS. O'CONNELL: Right.

But we do attempt -- we have
an enforcement first policy, and
we attempt to use our enforcement
authority to try to get private
dollars, private parties, to do
cleanup to the extent possible.

MS. BEAM: I would hope that
you would take back this property
and not let them keep it.

MS. ECHOLS: Sir?

MR. KILGALLEN: Kevin
Kilgallen again.

For Mr. Westgate, have you
ruled out the disposal of treated
groundwater into the surface water
of Judas Creek?

MR. WESTGATE: Not
completely, no.

MR. KILGALLEN: What
criteria would you follow there?

MR. WESTGATE: Well, in
terms of the contamination, the
PCE level would be below the
drinking water standard, which is

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one part per billion. So,
essentially, it would be clean.

It would have to do with the
hydraulic load on Judas Creek and
if that would cause flooding. If
we can get permission from the
State of New Jersey to discharge
into that stream, that's something
that we'd have to talk about too.

It's not ruled out at this
point, it's not selected.

MR. KILGALLEN: So, that
decision would effect the ultimate
cost of that option?

In other words, if that
option were ruled out, then you
would have to either pursue an
underground piping of that
water --

MR. WESTGATE: The
alternatives we have for dealing
with -- to get the site clean
water effluent, the three
alternatives were discharge to
Judas Creek, reinjection into the

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aquifer at a place where it
wouldn't cause flooding, or
actually piping that water and
paying a fee to the publically-
owned treatment -- the sewer
authority, local sewer authority.

MR. KILGALLEN: South
Monmouth Regional Sewage
Authority.

MR. POSTEN: I believe
that's it, yes.

MR. WESTGATE: We initially
approached them. They don't seem
that enthusiastic about it.

But once we get into design
phase, we'll approach them again
where we get to the point we have
to have some kind of place to put
our treated water.

MR. KILGALLEN: You'll
consult with DEP about the
ecological issues?

MR. WESTGATE: We have to.

We cannot discharge into
Judas Creek without their

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permission.

MR. KILGALLEN: Will you
publish a proposed report when
those findings are made, whether
you get the go-ahead from them or
not?

MS. O'CONNELL: These are
design decisions. So, when the
design is completed, that report
would become public.

We don11 always have a
public meeting at that point, but
we could make that -- we would
make the design report public.

MR. KILGALLEN: But then it
will be a fait accompli at that
stage?

In other words, you won 11
take input on that issue?

MR. WESTGATE: What other
idea would you have to dispose —

MR. KILGALLEN: It would
depend on the hydrological
reports.

There is a flooding issue

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there.

MR. WESTGATE: I don't want
to exacerbate anybody's flooding.

Touchy subject around here.

MR. KILGALLEN: The flood
boundaries have been expanded in
that zone, if you're aware of
that.

MR. WESTGATE: Yes.

When we do a design, the
designers are tasked with
evaluating all that impact and the
local regulation, Coastal Zone
Management Act. Whatever they
have to comply with in terms of
discharging of that water, they
build that into their drawings.

And then they approach us
with a 3 5 percent design which
kind of lays out what they want to
do, and then we go through the
process with the State to make
sure we can get the appropriate
permits to do what we're planning.

MR. KILGALLEN: Would the

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federal government permit the
further expansion of that flood
zone as a result of your --

MR. WESTGATE: I'm not Corps
of Engineers.

MR. KILGALLEN: — as a
result of your disposal of that?

MR. WESTGATE: Army Corps of
Engineers deals with flood zones.

I can't imagine them modifying
just based on the fact that...

MS. O'CONNELL: We are
sensitive while we're cleaning up
an environmental problem to not
create another one. That would be
irresponsible.

So, we hear what you're
saying. We're not ruling out
discharge to Judas Creek. It may
or may not be feasible. But the
State regulates the surface waters
in the State of New Jersey, and we
do comply with the flood plains
and all the flooding maps, and we
would comply with all the DEP and

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all the state and federal
requirements for that.

That1s an option that we are
going to look at. Whether it's
going to be feasible, we don't
know, but we certainly need to be
sensitive to the flooding issues.

MR. KILGALLEN: So I
understand, being sensitive to
that issue would mean that you
would not permit an expansion of
the flood boundary in that zone?

MS. O'CONNELL: We're not in
charge. The Superfund program
doesn't regulate that, we comply
with what exists.

MR. KILGALLEN: But impact
on that zone, you're increasing --

I assume this effluent would
be discharged over an extended
period of time?

MS. 0'CONNELL: Yes.

MR. KILGALLEN: How long?

MR. WESTGATE: Thirty years.

MR. KILGALLEN: So, for

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thirty years effluent will flow
through surface water.

MR. WESTGATE: First of all,
you're talking about a
hypothetical scenario that we
can't address at this point.

Secondly, Judas Creek is dry
most of the time.

MR. KILGALLEN: That's not
accurate. I'm a resident of that
area.

MR. WESTGATE: Based on our
four-year long investigation --

MR. KILGALLEN: Not
accurate.

MR. WESTGATE: Fine.

We're not going to cause
flooding in there by our
discharge. Like Kim said, we
don't want to cause more problems
trying to solve problems that we
already have.

So, I'm not sure what you're
getting at in terms of --

MR. KILGALLEN: I don't want

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that zone effected. I don't want
additional effluent through that
zone.

MR. WESTGATE: It's as clean
as the water. —

MR. KILGALLEN: The
cleanliness of the water doesn't
matter. You're increasing the
groundwater levels.

MR. WESTGATE: The pump and
treat system would decrease
groundwater levels.

MR. KILGALLEN: Not through
that zone.

MR. WESTGATE: If we pump
into the publically-owned
treatment works, we would increase
the flow into their treatment
plant and lower the groundwater
levels in the vicinity of our
recovery.

MR. KILGALLEN: That's
assuming you don't discharge into
the surface water.

Correct?

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MR. WESTGATE: That would
assume that we discharge into the
publically-owned treatment plant.
It's not yet been decided.

Flooding or causing damage
from flooding is something we
consider when we design our
treatment plant and where to put
the effluent.

I've been through this
before. Its something that will
change the direction of our
discharge if need be if that's
going to happen.

MR. KILGALLEN: So, you're
going to consult with the state
hydrological experts there or not?

What is the role of DEP?

MS. O'CONNELL: We would
need to get a discharge to surface
water permit or permit
equivalency. That's what happens.

So, it would be as if we're
requesting the permit and we're
going to have to meet all the

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requirements that any party --

industrial, commercial -- would

meet in discharging water to that

surface water body.

MR. KILGALLEN: You would

have to file an application with

State DEP?

MS. O'CONNELL: Yes.

MR. KILGALLEN: And that

application would set forth the

parameters of the quantity of the

effluent?

MR. WESTGATE: I'm not sure

exactly what a discharge permit

looks like, but there's modeling

of surface water elevations over

four seasons.

Steve, would you know if

it's two years or ten years?

MR. POSTEN: I think there

is public -- if you file for any

kind of discharge permit, there's

a public notification of the

permit that I believe the DEP is

required to post for public

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comment.

MR. KILGALLEN: Just to
focus now on the cost numbers,
your cost numbers assume that this
would be a surface discharge?

Current cost number on the
option?

MS. O'CONNELL: I'm not
recalling.

MR. POSTEN: Yeah, the
pricing for that alternative
includes the construction of a
treatment plant with discharge to
Judas Creek.

MR. WESTGATE: So, the cost
would go up

MR. KILGALLEN: Significantly-
larger .

MR. WESTGATE: I wouldn't
use the word "significantly".

If we had to discharge to
the publically-owned treatment
works instead of the stream --
these costs that we have in the
Proposed Plan are very rough

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estimate. We don't start to firm
up the costs for all these
different technologies until the
design gets finalized, and then we
cost it out in terms of the actual
dollar amount.

So, let's say we're planning
on seven ground recovery wells and
we go to ten or twelve because
that's what we need to collect in
this hot zone tl)at we' re talking
about. That obviously will change
the cost.

So, you have to take the
numbers in here as a very
preliminary planning estimate
rather than a final number.

MR. KILGALLEN: So, could
you estimate a range of cost?

MR. WESTGATE: No.

MR. KILGALLEN: In other
words, plus one hundred percent,
plus two hundred percent?

MR. WESTGATE: I can't.

I'm not a designer, I'm not

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a cost estimator. I have no
expertise.

MR. KILGALLEN: When would
figures be available, after a
decision on permit was made by the
State?

It seems to me this would
effect the cost-benefit ratio.

MS. O'CONNELL: It may. We
make a number of assumptions for
cost purposes. The costs
presented in the Proposed Plan are
preliminary-type estimates based
on a conceptual design, not a
detailed design.

And they're used to kind of
compare, compare different
alternatives. They're not used to
say this is what the cost is going
to actually be. We do make
assumptions.

So, we made it clear in our
Proposed Plan that we haven't made
a final determination on the
disposition of the treated water

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from the groundwater pump and
treat plant in our three options
as Matt outlined. We did take one
for cost purposes, but that does
not -- we need to make a lot of
assumptions for the cost estimate.

Some of those assumptions might
get changed.

A lot of things might get
changed as we collect more data
and we find and do a detailed
engineering design of the remedy
that we selected. So, these costs
are for our remedy selection
purposes and to compare the
alternatives.

So, if Steve says that's
what we use, the discharge to the
stream, we had to pick one of
those alternatives for the purpose
of cost estimates.

So, that may change if we
change where we're going to
dispose of the treated
groundwater.

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MR. KILGALLEN: Just a quick
follow-up.

Did you pick that option
because it's the least cost?

MS. O'CONNELL: I don't
know --

MR. KILGALLEN: What was the
criteria used?

MR. POSTEN: I mean, there's
three alternatives for injection
to groundwater, and the three
alternatives really were based on
how many extraction wells would be
installed.

And if I recall, the lowest
extraction level, which was
actually the plan that we
currently have, was the only
injection to groundwater option
that was feasible.

But we didn't look at the
costs for that option because the
discharge to surface water is just
conceptually a simpler approach to
make at this conceptual level of

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design than having to design a
distribution field for the
injection of water, into the
groundwater.

MR. KILGALLEN: The criteria
was it's technically easier to
dispose of it in the surface
water.

Is that correct?

MR. POSTEN: Right.

And, again, I think it's —
for this level of analysis, the
way the costs are assumed to be
representative, it's plus fifty
percent and minus thirty percent.

Those are kind of the
guidelines that Superfund, you
know, establishes for this level
of estimate. So, there is a lot
of variability in what the actual
cost can be.

MR. KILGALLEN: What would
the timeline be from -- assuming
that an application was made for
surface discharge, how long would

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that take from application to
decision?

MR. WESTGATE: I don't know.

MR. LOWRY: The applications
submitted to the department, we
basically make three decisions.

It would be sent back for
additional information and
modifications or it would be
denied. It generally depends on
the type of permit. I don't work
in the NJDPES program, but there's
a general performance standard
where that permit would be -- a
decision would be rendered
probably within ninety days or
less.

MR. KILGALLEN: That's from
the time of submission of the
application?

MR. LOWRY: Correct -- or at
the time the permit -- the
application is deemed complete.

Sometimes they come back
because it may be incomplete. So,

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it would be from the time the
permit is determined to be
administratively complete and then
undergo the appropriate technical
evaluation.

MR. KILGALLEN: Will that
application be available by
request?

Would a copy of the
application to the public be
available by request or through
the Freedom of Information Act?

MR. LOWRY: As Steve
mentioned before, the Department
maintains a listing of all permit
applications, applicant name, the
type of permit, proposed
discharge, and things of that
nature.

So, we would make those
available, and then there's a way
for -- you would then be able to
contact us to get more specific
information; basically, a copy of
the permit as submitted.

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MR. KILGALLEN: It would be
considered public information from
the time it's made or is filed?

MR. LOWRY: You would be
noticed that the application had
been made. I'd have to check and
make sure whether the actual
permit application is public
information at the time of -- in
other words, prior to an agency
making a decision.

MR. KILGALLEN: I'm sorry, I
don't know your name.

MR. LOWRY: Biff Lowry.

I'm with the Department of
Environmental Protection, Site
Remediation.

MR. KILGALLEN: Thank you.

MS. ECHOLS: We're going to
have to take a little break
because the stenographer is a
little tired right now. So, we
can take a five-minute break and
then we'll get back.

(Recess taken)

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MS. ECHOLS: We have a
statement from your mayor.

MAYOR LUTTMAN: First of
all, I'd like to thank everyone
that came out tonight from Wall
Township and our neighboring
towns.

This meeting was brought to
our attention about a week ago,
that we were going to have this
meeting. We had a conference call
with some of the parties here
today, and we appreciate that.

I hope that they take to
heart some of the comments that
are made here tonight, especially
those for communication with us
and our school districts for all
the neighboring towns.

In addition, it seems to be
clear to me that a lot of
residents would like to see a
speedy cleanup or remediation of
this in the shortest period of
time possible, and I'd like you to

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take that into consideration.

Also, especially pertaining
to the school districts, I'd like
to see if you could put on the
agenda to make sure that there's
testing done on those facilities,
whether Wall Township schools or
the neighboring towns, because I
feel that that is extremely
important.

We took twelve years to get
to this point, and I'd like to
really see us start the process
and its cleaning up. Again,
twelve years is a long time.

Some of this came as a
surprise to us. We thought it was
in the process of cleanup and it's
just still under the investigation
stage. So, we will look forward
to you coming up with your plan to
remediate this problem.

Thank you.

MS. ECHOLS: Thank you.

MS. SAFKA: Ellen Safka. I

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live on Jefferson Avenue, right
behind Judas Creek.

There is another dry cleaner
that runs along in Foodtown, backs
up to Judas Creek. It's been
there almost thirty years.

Anybody ever tested that?

MR. POSTEN: Part of the
very early work that we did
involved the vapor survey that
Matt talked about. So, we did go
to all of the other potential
areas that could have contributed
to this problem.

We looked at that area
specifically, and, actually, the
NJ DEP had looked at that area
prior to us, and we didn't find a
contribution of those same
chemicals from that specific
facility that impacted these other
areas that we were looking at.

So, we did look at that one
in particular.

MS. ECHOLS: Would you point

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to it again one more time, the
area?

MR. POSTEN: It's right in
that area here, in with the
Foodtown.

MS. SAFKA: With Foodtown
and, also, the laundromat that's
been there about fifty years.

MR. POSTEN: We probably
took something like fifty samples
specifically in that area and we
were able to document that there
wasn't a discharge from there.

MS. SAFKA: The other
question I have is I have two
piezometers in front of my house.

Matthew and I have talked about
them many, many times.

MR. WESTGATE: We need them.

MS. SAFKA: You tell me I
can drink the water.

MR. WESTGATE: The design
investigation, those designers, as
they see this plume, they're going
to say: Oh, my God, we need all

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the information you've got. We're
going to have to go back and
sample it.

And then along with the
natural attenuation, they have to
put together a sampling plan in
order to get the monitored natural
attenuation part of this remedy
through.

So, we need them. I'm
sorry, we need them.

MS. SAFKA: They paved the
road. I know they did it right,
everybody did it right, but then
they dug up all around there again
just two weeks ago, the gas
company.

So, are these shifting?

MR. WESTGATE: No.

MS. SAFKA: Are they going
to be effected?

MR. WESTGATE: If we have to
pull the wells or repair them,
we'll repair the surface of the
road so it's like it was before

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when we put the wells in.

But I would have to inspect
them again to see if when the gas
company did the excavation --
because sometimes they're a little
sloppy -- to see if the wells were
impacted.

When we have to do these
design investigation samples, we
don't inspect every single wells
that we have.

MS. SAFKA: They've been
there over ten years.

MR. WESTGATE: I know. We
just need those wells.

MS. SAFKA: I understand
that, but will we ever know
they're okay?

I mean, if I go to sell my

house

MR. WESTGATE: I could give
you the specific sample results
from that well right in front of
your house, but if you're
concerned about exposure

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pathways -- that's an indoor air
test, not a groundwater well test.

There might be contamination under
the ground, but the vapors aren't
getting into the house, so you
don't have a health issue.

MS. SAFKA: I just have a
resale issue.

MR. WESTGATE: Like I said
before —

MS. SAFKA: How many of
those are there around?

MR. WESTGATE: How many
piezometers?

MR. POSTEN: Piezometers,
it's the same as the monitoring
well, just that we sample water
levels in it mostly instead of
taking quality samples. It's
really no different than a well.

There's something like
seventy of those wells all around
this whole site.

MS. SAFKA: How often are
they tested?

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MR. POSTEN: We tested them
three times during our
investigation, which was 2009 into
2010. We haven't sampled them
since, but --

MS. SAFKA: Somebody just
did mine a couple months ago.

Took photos, wrote down the time
and day and everything.

MR. POSTEN: After the
hurricane, we had our people go
out to every single location to
make sure that the wells hadn't
been damaged. So, we would have
had somebody go out, photograph
every single location.

Some locations we had to
replace the locks or fix because
they had been flooded.

But for example, in that
location, I don't know if there
was flooding or not.

MS. SAFKA: No, we're on
higher ground.

MR. PO.STEN: Right.

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But we still had the people
go out just to make a record of
all of those wells and make sure
they were still okay.

In the next step, when Matt
gets into the design and these
remedies go in place, there will
be a schedule that all of these
wells will be sampled that's going
to go on for twenty or thirty
years or however long this process
takes.

MS. SAFKA: So, when they're
out there, they're actually taking
the samples?

I've seen them take whatever
it is out of the ground.

MR. POSTEN: They'll do one
of two things. There's what's
called a water level meter, and
they'll have something on a reel
that they'll drop down into the
hole that beeps that tells them
what the level of the water is.

And they take that measurement and

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that allows us to make these maps
with the blue lines so we can
figure out which way the water is
moving.

Another thing is they
actually have pumps and hose that
go in and they suck water out for
a period of a couple of hours.

They have all kind of instruments
that are measuring the chemistry,
and then they actually take
samples and send them to the
laboratory.

So, your piezometers,
primarily they would just measure
the water level and not have taken
samples. I think they might have
taken samples once.

But in the future, as these
plans get implemented, they will
be on a schedule, whether it's
twice a year or once a year, all
seventy of these wells to be
sampled.

MR. SAFKA: I have a

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question. Paul Safka, Jefferson
Avenue in Wall.

Further to that point, you
said these are used for water
level.

What do we actually use to
measure PCE levels in that area?

Are there other wells?

MR. POSTEN: Yes.

MR. SAFKA: Are those
results in this final report?

MR. WESTGATE: Yes.

MS. O'CONNELL: Are there
sixty monitoring wells?

There's about sixty
monitoring wells throughout the
entire plume —

MR. SAFKA: This is outside
the plume.

MR. POSTEN: The work that
was done that went on for this
period of several years, the first
level of testing was to determine
what is contaminated and what's
not. And I think the boundary

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between what's contaminated and
what's not runs somewhere along
the area of Jefferson Avenue.

In order to make these water
level maps and make them accurate,
you needed some measuring points
that were actually outside of the
contaminated area or very close to
the boundary, and that's why those
specific wells were installed, or
the piezometers.

We do have the original
temporary data that Matt I think
referred to as a hypodermic
needle, where you go in and suck
out a water sample. Very many of
those were done, hundreds of
those, to determine which areas
were clean and which were
contaminated.

And then the wells were put
in kind of strategic locations
within those areas that were
contaminated.

MR. SAFKA: So, you're

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saying somewhere in the region of
Jefferson Avenue -- I mean,
there's Judas Creek, there's
Briarwood, and there's Jefferson.
It looks like these plume maps
that we've seen are somewhere —
maybe we don't have the resolution
to really pick out Jefferson all
that well, but it sounds like
there aren't a lot of monitoring
wells out there, just a couple
piezometers to look at the water
that's been tested once just kind
of for good measure.

Is there active water
monitoring in the Jefferson area?

MR. WESTGATE: In the area,
to the north of it, yes.

I think this -- I see a PZ
number over here, so I think this
is the one you're talking about.

MR. SAFKA: That's
Jefferson, yeah.

MR. WESTGATE: So, we need
that well just for water table

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elevations. If we start putting a
pump and treat system or recovery
wells, we have to see if the plume
sides expand or not.

For the time being, we need
the piezometer. It's useful for
us. It's contributing to the
cause of cleaning up this
groundwater. I'm sorry if it
offends you, but we have to do it.

MS. SAFKA: It's not
offending, it's just what are
they?

Why are they there?

What's going on?

Some kind of update.

MR. POSTEN: To answer the
question of how often are they
being sampled, they were sampled
two or three times just to
establish the picture. They're in
kind of a hiatus now until this
design work gets down, but then
they will be on the schedule of
being sampled, like I said, twice

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a year, once a year, for the
duration of this project work.

MR. SAFKA: If I may
continue, I have a number of
questions. I don't know if I'll
belabor the whole session tonight,
but I'll submit them in writing.

One thing under the
evaluation of remedial
alternatives, the nine criteria,
particularly focusing on eight and
nine, state agency and community
acceptance.

As far as State of New
Jersey agreed with the preferred
alternatives of this plan, is
there documentation available of
this concurrence that we could
see?

MR. WESTGATE: Not yet.

They just gave us a verbal
at this point.

MR. SAFKA: So, it's verbal.

And when could we expect or
how could we expect...

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MS. O'CONNELL: Before a
remedy is selected, a remedy is
selected at a different stage of
state input, community input, and
that's documented in the Record of
Decision.

And the State of New Jersey
will have an opportunity to accept
with a written concurrence on
that.

MR. SAFKA: Will the State
be open for public comments on
this?

MS. O'CONNELL: This is the
public comment period. The EPA is
the lead agency on this, the State
is our support agency. So, they
will review and hopefully concur
on the remedy in writing at the
time of the ROD.

But we have the lead, and
this is the public comment period.
It goes 'til September 19 and
we're accepting written, verbal
comments, all the comments are

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documented tonight, anything you
want to send by e-mail,
handwritten, all those comments
will be addressed before the
remedy is selected.

MR. SAFKA: So, once the
State agrees, we don't have an
appeal period on that decision.
Basically, EPA takes the lead.

MS. O'CONNELL: Your comment
period is now to EPA. We have the
lead now because it's an EPA-lead
site.

MR. SAFKA: Another part of
the question, there are
notifications to the local
community. I'm particularly
interested in the town
governments, being Wall Township
Sea Girt, and Manasquan.

What was the notification;
how was that effected; and what
were the responses, the feedback?

I see we have the Mayor here
tonight. That's a positive note.

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MR. WESTGATE: I personally
briefed all three municipalities,
various representatives in the
municipalities. I also contacted
Monmouth County Health Department.

I was contacted by
Congressman Smith's office, and I
briefed a bunch of people in that
office.

We put ads in a major
regional paper, Asbury Park Press;
another one, Coast Star, which is
more focused on this particular
area; there's the mailing that
Cecilia did.

Some of those townships that
I briefed personally put our
notification on their websites.

I understand that everybody
wants us to brief the school
districts also, and we'll build
that into the process.

MR. STRAUB: Can I
interrupt, get a question in?

MR. SAFKA: Sure.

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200

MS. ECHOLS: Your name,
please?

MR. STRAUB: Carl Straub,
Manasquan.

We were talking about taking
water from the new treatment plant
that you will design and build
near that area and perhaps run
that water down through Judas
Creek.

Do you know now or when will
you know what the volume of water
would be, how many gallons per
day?

MR. WESTGATE: The estimate
we have now before the design
modelers get involved is between
seventy and two hundred gallons
per minute.

MR. STRAUB: Holy mackerel,
I better put my house on stilts.

MR. WESTGATE: We're not
going to flood neighborhoods.

MR. STRAUB: I mean, there's
a pond there, Mac Pond. And then

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201

from there it flows underneath the
ground and aboveground and then
underneath the ground again past
the schools in Manasquan before it
finally ends up in Stockton Lake.

That's a lot of water.

MR. WESTGATE: Like I was
just explaining to one of the
other residents here who had that
issue, Mac Pond has its own little
groundwater well that I guess
Manasquan pumps constantly to
replenish Mac Pond. So, I
understand there's some flooding
issues. I'm not sure how that
impacts it.

Certainly we're not going to
put a discharge into Judas Creek
that's going to cause additional
flooding, damage people's
property. That's all I can say at
this point.

MR. DONOVAN: That's not an
accurate comment.

MS. ECHOLS: I'm sorry, your

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name?

MR. DONOVAN: My name i s Ed
Donovan. I'm a councilman in the
Borough of Manasquan.

We operate the well at Mac
Pond periodically.

MR. WESTGATE: Oh,
periodically.

MR. DONOVAN: Very low
conversion permit for that well.

It's not constant.

MR. WESTGATE: I stand
corrected.

MR. DONOVAN: We have to
constantly adjust the level of
Mac's well because of the water
that's running down the creek past
Carl's house and coming into Mac
Pond.

MR. WESTGATE: Okay. I
didn't know that. I thought it
was constant.

MR. DONOVAN: No.

MS. SAFKA: I just have a
comment on the wells in front of

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my house.

The last date that they were
tested was February 7, somebody
was out there.

MR. POSTEN: Of this year.

MS. SAFKA: Yes.

MR. POSTEN: I think that's
when we did the follow-up from
Sandy, where we went around to
check the condition of all the
wells. That wasn't really a
formal sampling event, it was just
to make sure the wells were okay.

MR. SAFKA: Can I have the
floor again?

The EPA RCRA section one,
background, it says approximately
a hundred shallow private
irrigation wells within three
municipalities are contaminated.

What are EPA's plans to
inspect, monitor, upgrade, or
close these wells to prevent
further cross-contamination prior
to and during the remediation

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activities?

MR. WESTGATE: Well, part of
our remedy that we're proposing is
establishment or using
institutional controls to help us
with the remedy.

If these wells' existence
impact our trying to collect
groundwater such that maybe
closing them would allow us to
more efficiently do what we want
to do to clean up this aquifer,
then we would talk to the State
about this classification
exception area.

I think that only looks
forward in terms of approving
additional programs, but, again,
we have to have look at the design
stage.

I know Barlow's shallow
irrigation wells are a problem.

We're going to deal with those as
part of our design.

I don't have a full answer.

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MR. SAFKA: I would
anticipate that a lot of these
wells are probably a number of
years old and may not have fully
grouted casings and they could be
basically taking surface water
down to the aquifers, and that's a
whole other issue.

If they're combined with PCE
and other elements in there,
that's a concern for me. To just
say they're there, we'll monitor,
it's a bit of concern.

I think they should be
verified and logged or ruled out
as potential of something that's
working against us on this
remediation.

MR. WESTGATE: We don't want
to come up with a design that on
paper works wonderfully but then
when you actually start pumping we
find all these horror stories
because irrigation wells have an
impact or distorting the plume or

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sidetracking the plume so that we
can't get -- certainly, we'll
build that in --

MR. SAFKA: It could change
the hydrology. I mean, if it's
the perfect conduit to a clay lens
or something, it could be a real
issue that we haven't even
addressed here.

MR. WESTGATE: The one thing
I'm pretty certain of is that most
of the irrigation wells are fifty
feet or shallower. Most people
historically hand dug wells 20,
30, 35 feet the most.

The bottom of our
contaminated zone is about 75 feet
beneath the surface, so there's no
issue of these irrigation wells
having a hole through our low
permeability zone and allowing
contamination to flow between
upper and lower

MR. SAFKA: I have another
part to this.

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Is there a moratorium on
future shallow groundwater wells
in the plume area?

MS. O'CONNELL: Part of the
remedy is going to call for a
classification scenario which we
apply to the State for. They can
create an area where they can
require additional restrictions on
future monitoring wells. It
doesn't mean no monitoring wells
could be installed, but they could
go through additional scrutiny.

The current wells are not
posing the kind -- the only way
for us to require current wells to
be closed -- personally, it would
be nice to have them closed
because then you could control
your plume better. That's just
common sense.

But the wells are not
contaminated and posing the kind
of risk that would allow us to
condemn or the State to condemn

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them and take them. These are
private property. So, without the
risk there...

I think some of the points
you're making are very good points
that we could try to see if
there's a technical problem. Many
of these wells are located in an
area that's going to be addressed
in monitored natural attenuation,
so we will be monitoring that
area, the large more dilute area
of the plume, the Far Field, what
we're referring to in the document
as the Far Field portion of the
plume.

We'll be monitoring that,
and it makes sense for us to look
to see if there's a localized
problem within that large area, to
maybe take a look at that.

But the wells, you know,
they're not posing any
unacceptable risk level and
they're not going to be condemned.

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And you raise a good point, it
makes us lose some control over
portions of it because we don't
have control over who and how uses
that water.

MR. SAFKA: Then given the
potential of fifty to seventy
years to fully attenuate the Far
Field area, is consideration given
to actively remediating these
areas?

I think you were talking
about a pumping station.

Is that correct?

MR. WESTGATE: We did
consider active or aggressive
treatment in the whole plume, not
just our highly contaminated part
of it, and it was ruled out in our
Feasibility Study for a bunch of
reasons; impact on the community,
the cost is exorbitant, and it
didn't shorten the remediation
time that much.

MR. SAFKA: Another

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question.

Was alternative in-situ
technology, including six-phase
heating, considered, and why were
they ruled out?

Based on successful
remediation of PCE contamination
at similar commercial sites and
government facilities, including
NASA, that required only months
rather than years to remediate to
background levels.

MR. WESTGATE: Well, we
largely selected technologies that
would be appropriate for our type
of contamination in our type of
aquifer with our flow patterns and
all that.

I haven't heard of six-phase
heating.

MR. POSTEN: The Feasibility
Study consisted of three separate
reports, and I think the first two
reports are in an appendix to the
current Feasibility Study. So,

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you can go through and follow the
whole train of what was the entire
universe of alternatives that were
looked at and then what were some
of the reasons that some of these
may have been screened out as you
went through the process.

And I know that the
resistive heating is very
effective but it's very expensive.
And there are alternatives, for
example, just excavation, which is
one of the selected options, or
this vapor extraction, will
achieve the same goal but are, you
know, something like five to ten
times less costly than the
resistive heating.

So, if the analysis showed
that you could achieve the same
results as, you know, going
through this screening process, if
you could achieve the same results
for one-tenth or one-fifth of the
cost, then those alternatives

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. 212

would be screened out, and I think
that may have been the case in
terms of the resistent heating.

MR. SAFKA: If I understand,
better technologies may exist but
they were strictly ruled out on
the basis of cost even though the
total life cycle cost may be
somewhat more attractive.

MR. POSTEN: Well, no.

I mean, typically, we are
always looking at the life cycle
cost. But the point is if the
capital cost is something like ten
times more than the combined
capital and O&M cost of an
alternative technology and you'll
achieve the same objective, then
that kind of analysis would be a
rationale for screening out some
of these alternatives as you go
through the process.

MR. WESTGATE: If you look
in the Feasibility Study, there's
a lots of details in there, as

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Steve said, the universe of
technologies that we started with
and how we ruled them out.

MR. SAFKA: Another
question.

In the final investigation
report, Section 1.2.2, referring
to the Sun property, it's
mentioned that underground storage
tank was reportedly located on
site but was not encountered.

Question, considering the
plan is to leave soil in place,
what assurances do we have that
there are not any underground
tanks that contain waste and other
elements?

Was the site fully
investigated for underground
structures either by total
excavation or ground penetrating
radar?

If not, why?

MR. WESTGATE: Yes.

I had AMEC dig up the Sun

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Cleaners property with a backhoe,
and I stood there while we went
through layers down to the water
table. We have documentation of
that.

And there are no -- although
there were rumors that there was
some kind of underground equipment
there, we didn't find it.

MR. SAFKA: So, we, as the
public, can take comfort that
there are no drums or tanks that
somebody may have —

MR. WESTGATE: Yes.

MR. POSTEN: A geophysical
survey, a very detailed one, was
done on that property as well as
the White Swan property. And the
results of that survey are
contained as an appendix to the
report.

And the trenching that Matt
is discussing is that every
location that the geophysical
survey identified what they call

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an anomaly, which could be a tank
or some other kind of metal
contacts, was excavated to
determine if a tank was present at
that location.

And in every case, we had
found, you know, basically debris
and garbage and other kinds of
things, but there was no tank that
was identified.

MR. WESTGATE: Having said
that, during our remedial process
when we're putting in wells for
this SVE system, if we encounter
something that we missed, we deal
with it, not just leave it.

MR. SAFKA: It sounds like
the Sun site is going to be just
essentially leave it in place and
treat with air stripping and
pumping.

MR. WESTGATE: Well, we have
to put in the air sparging wells.

So, we feel pretty
comfortable that we thoroughly

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investigated that particular
location. And we think that if we
install that air sparging and soil
vapor extraction that it would
work and remove the PCE from the
soils without any surprises.

But if we do find something,
it's not against the law to take
care of it. That happens from
time to time on Superfund sites.

MR. SAFKA: On Page 10 of
the plan, it states, "Significant
mass removal by ISVE/AS could be
expected at the Sun Cleaner source
over a period of roughly 10 years,
and systems would be operated
periodically until soil is
remediated.n

Describe what is
"periodically".

MR. POSTEN: I mean, my
understanding of how the systems
work is they run continuously.

The point is you'll remove
very much of the mass during the

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initial portion of the operation
of these systems, and then the
removal rate kind of, you know,
reaches an asymptotic curve. So,
you pull out most of the mass in
the beginning and you pull out
less and less as time goes on.

And what you may do as part
of the operation of those systems
is periodically you turn them off
so you let the ground and the
vapors reach a new equilibrium and
you turn them back on again.

That, from what I
understand, is just part of the
way that you operate those types
of systems. By turning them off,
you let the soil vapors re-
equilibrate in the ground and you
turn them on and you actually
start pulling out more vapors
again.

So, there is some kind of
post operation as to the way those
symptoms work, and I believe the

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concept is there in terms of this
periodic operation. You're only
doing it to improve the
effectiveness of the system.

MR. SAFKA: Another
question.

On Page 12 of the plan it
says that, "The groundwater
extraction treatment system would
be constructed and operated for
approximately 3 0 years."

The first part is what are
the expected operating cycles,
continuously 24/7 or less
frequently?

MR. WESTGATE: At this
point, without talking to any
designers, I would say 24/7.

MR. SAFKA: Describe the
expected sound levels day and
night.

MR. WESTGATE: I don't have
any decibel ratings for you.

Certainly if the community
was -- first of all, we don't even

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know where the plant is going to
go. But if it was in an area
where noise would be an issue,
then we would put insulation of
some kind of a barrier around the
walls of the plant to make it
quiet.

We, EPA, controls what the
designers do in terms of what it
looks like and how much noise it
makes, things like that. So, we
would try to minimize the impact
on the community.

MR. SAFKA: Just to state
this, DEP does have sound criteria
for day and night.

MR. WESTGATE: Our designers
are not going to design a
treatment plant that's not going
to get all the approvals needed
for construction. We follow the
same rules that you would if you
were building a treatment plant in
your backyard.

MR. SAFKA: The third part

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to that question is describe the
esthetics of these system.

Are they structures?

Are they going to be fenced
and landscaped?

Is it going to be
unobtrusive?

MR. WESTGATE: I've done all
of that on my plant down in
Vineland; fencing, landscaping,
put in trees.

I mean, we do that
automatically.

MR. SAFKA: It was expressed
by a number of folks that
testified that it's a concern on
property values to have
potentially what would appear to
be a chemical plant or a refinery
sitting in our community.

MR. WESTGATE: No, it's just
going to look like a commercial
building, and it's not going to be
identified as any kind of chemical
hazardous treatment center or

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anything like that.

It's just a commercial
building that we would buy. You
know, a commercial market, make it
look to fit in as best we can.

MR. SAFKA: Another
question --

MR. WESTGATE: One more. We
have to

MR. SAFKA: It's a very
comprehensive plan.

Has this undergone third-
party peer review?

I know AMEC has done a great
deal of work on it.

Has there been any oversight
within EPA or potentially outside
EPA on qualifying some of these
recommendations?

MS. O'CONNELL: Yes.

EPA has its own independent
contractor doing oversight and
review of all submittals. We have
a number of internal technical
folks, hydrogeologists that review

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all the submittals. The State of
New Jersey has a team of technical
reviewers who have reviewed all
submittals, large and small. In
addition, the Army Corps of
Engineers has reviewed the
Feasibility Study when it was in
draft.

So there's a lot of levels
of review that the documents have
gone through so far. In fact, the
community review is really our
last review. So, you're our last
word.

MR. SAFKA: Just one more
question.

You know, it's a hot button
for a lot of folks. The Sun
Cleaner site, potentially leave it
alone, it's not so bad, and the
comment was made about traffic and
impact on highway. I think that
was questioned.

I'd just like to go on the
record, have traffic impact

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studies been performed at both
White Swan and Sun by traffic
experts, and were alternatives
explored, such as temporary roads
as in an existing composting field
in there?

MS. O'CONNELL: We've looked
at two pretty much -- we've
narrowed down to two technologies
to treat the soil at White Swan
and Sun, and that was SVE and
excavation. The ones we're
proposing is excavation at White
Swan and in-situ vapor extraction
for Sun.

That's not leaving it there
but it is treating it in place
versus digging it up and hauling
it off for disposal. So, that is
the difference.

The soil contamination at
both properties would be addressed
to meet the same cleanup level.
The cleanup standard we developed
for soil is one part per million.

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Our evaluations have shown us that
that will be protective of
groundwater.

So, it's low a cleanup
standard, and if we clean up both
those properties to one part per
billion, they will no longer be
contributing to groundwater
contamination.

So, they will meet the same
cleanup goal. The different
technologies are really based on
the situation, the logistics, the
physical characteristics, that are
different on these two property
that are located a quarter mile
from each other. One is flat, one
has a very steep slope. One is
located on, you know, a somewhat
bet busy street, but one is
located on a very busy traffic
circle. That's not the only
driver, but that's just one
consideration.

White Swan has significantly

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higher contamination in a very
small area, making it a very good
candidate for excavation.

Excavation is generally -- it's
definitely more expensive than
treating it in place through soil
vapor extraction, so it has pluses
and minuses.

But the concentration of
PCE, the high level in the near
zone, right at the water table and
water throughout White Swan are
extremely high, so we can get a
very effective, high amount of
mass out in that the excavation.

The situation at Sun,
there's much less concentrated PCE
contamination in the soil compared
to the mass. So, you'd be
removing maybe more mass, I think,
but a lot less -- you'd be moving
more soil but you'd be moving a
lot less mass of PCE.

So, these are all the
considerations that we took into

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account in proposing what we're
proposing. We've heard some of
the comments here about some folks
having a preference for excavation
on both sides because it would be
quicker because excavation is
expected to take about a year from
when you start construction to
when you complete it.

The SVE would take longer
but would be going on concurrent
with the pump and treat of the
groundwater.

MR. SAFKA: On my list,

Matt, I beg your indulgence, the
Wall Environmental Summit, we have
senators and assemblymen that are
going to open to the public
September 26. Unfortunately, this
is after the cutoff date of public
comments from EPA on this White
Swan/Sun Cleaners.

I would like to respectfully
request an extension be given,
please, beyond the September 26

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date to afford the opportunity to
get with our legislative
representatives.

MR. WESTGATE: I did
volunteer to attend that meeting
if White Swan issues came up, so
I'd be happy to address any
questions.

(Pause in proceedings)

UNIDENTIFIED: I was just
addressing the issue of
Environmental Summit, the date,
and that Matt and the group was
kind enough to allow us to put
that on the table because it is an
environmental summit with our
legislators that's occurring on
September 26.

And Paul is right when he
requests an extension because it
is after the cutoff date.

MS. O'CONNELL: I'm not
certain what that is or if we're
invited or how we fit into that
process because this is our

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meeting to take --

UNIDENTIFIED: Correct.

MS. 0'CONNELL: I'm not
sure -- it sounds like it's
something a little different.

UNIDENTIFIED: It is
something different. This is our
ninth year as an environmental
committee. Any environmental
question, there's nothing off the
table, any resident can come and
ask any questions.

So, if the residents come,
they ask specifically about this,
that's fine too. It doesn't
necessarily mean that this will be
addressed if someone doesn't bring
the issue up, because it's open to
all environmental questions and it
doesn't necessarily just cover
this.

I don't know what else I can
say about that.

MS. 0'CONNELL: If we're not
part of that meeting and it has to

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do with a lot of local issues,
this -- you know, if you have
other questions or you want to
contact us, you can contact Matt
during the public comment period,
you know, we're trying to address
your comments.

Your elected officials, some
are here, some are not here, they
can all submit comments during the
public comment period. Everybody
is encouraged.

Really, this is our forum
and that isn't, and I'm not sure
if that's going to be beneficial.

MR. WESTGATE: There's over
three weeks left of the comment
period, so give us what you've
got.

MR. SAFKA: This is probably
internal within Wall, but we have
to get these comments or any
concerns raised with our
legislators before that.

MS. SAFKA: I invited both

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of them, Sean Kean and Dave Rible,
but I never heard anything back.

Chris Smith, as suggested, I
signed all the paperwork for him
to be our public advocate,
whatever. Didn't get a call on
that. He did send a
representative, but the other
people, never got a return e-mail
from as to whether they were
coming.

MS. ECHOLS: If there aren't
any more questions, we're going to
end the meeting. We have a long
way to go back.

MS. MORRISSEY: Can I just
ask one briefly?

Wilma Morrissey, East Eighth
Street.

The residents that brought
up the one-year thing, I
understand they want to get it
over with as quickly as possible.

And I'm trying to weigh that with
alternative four. Kim did a good

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job in addressing it.

And I just wondered if you
could reiterate those points
again, because you mentioned the
steep slope, you mentioned the
traffic, and I'm not comfortable
with -- I'm not convinced about
alternative four and I just wanted
to be.

MS. O'CONNELL: Alternative
four is a combination. It calls
for excavation at White Swan,
which appears that most people
here would agree with.

And it calls for soil vapor
extraction, which is treating the
soil in place at the Sun Cleaners
property, which it sounds like
some people are opposed to because
it will take longer to reach the
remediation goal.

That sounds like what we've
been hearing tonight from a few of
the commenters.

We looked at excavation at

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both sites and at soil vapor
treatment at both sites. They
would both work, but we are
looking at a number of factors in
trying to decide what's the best
action for each property,
including long-term impact, short-
term impact, cost, disruption to
the community, effectiveness,
overall protection.

And in doing that, the
reason that we are proposing soil
vapor extraction in-situ
treatment, although it would take
longer to meet the goal, the goal
would be met -- our rough estimate
is sometime within about ten
years -- however, we would get a
fast reduction of levels and then
we would be pulsing and treating
on and off in order to make that
very low standard we developed,
which is one part per million for
PCE in soil.

We would get there

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eventually, but it would take
longer. It would be less
expensive, but that's not the only
driver. They're still in the same
order of magnitude.

The reason we like the SVE
treatment at Sun versus White Swan
is we have a small area of very
highly contaminated soil at White
Swan which is very amenable to
excavation because the area is
flat, it's located on a street
where it would be easier to get
trucks in and out.

There's a lot of logistics
with soil excavation. There's a
lot of traffic on the street,
there's health and safety issues.

While we could do the
excavation on Sun, it is a
feasible alternative, the soil
vapor extraction was more
preferrable to us. There's an
extremely steep slope behind it.

It would be very difficult --

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possible, but much more difficult
to physically -- the topography
makes it more difficult to
excavate, the location makes it
more difficult to excavate.

And in addition, there's a
much less concentrated mass of
PCE. It is contaminated, but it's
much less mass of PCE per, you
know, volume of soil.

So, the excavation I believe
was estimated at $4.5 million, but
you'd be moving much less mass and
you'd be dealing with these other
logistical problems which, again,
could be dealt with, but we're
trying to consider the whole
remedy together.

Also, the pump and treat
would be happening in the
downgradient area of those two --
in the Near Field area, the area
of the most groundwater
contamination, that's a long-term
cleanup. That will be going on

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for approximately thirty years.

So, the ten years of treatment of
the lesser -- the contaminated
soils on Sun would be happening
concurrent with the groundwater
cleanup.

The White Swan would be the
first thing to be done because of
the conditions there.

That's our rationale in why
we're proposing two different soil
alternatives on those two
different properties.

MS. ECHOLS: We just want to
thank everyone for coming out
tonight. The public comment
period ends on September 19, and a
Record of Decision will be
prepared thereafter which will
encompass all of the comments that
were made tonight and those that
are written and sent in to Matt.

Thank you.

(Time noted: 10:29 p.m.)

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CERTIFICATE
STATE OF NEW JERSEY)

) ss.

COUNTY OF HUDSON )

I, LINDA A. MARINO, RPR,
CCR, a Shorthand (Stenotype)

Reporter and Notary Public of the
State of New Jersey, do hereby
certify that the foregoing
transcription of the public meeting
held at the time and place aforesaid
is a true and correct transcription
of my shorthand notes.

I further certify that I am
neither counsel for nor related to
any party to said action, nor in any
way interested in the result or
outcome thereof.

IN WITNESS WHEREOF, I have
hereunto set my hand this 3rd day of
September, 2013.

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APPENDIX III
Attachment D

Comments on Proposed Plan

-------
CHRISTOPHER H. SMITH

4th Djstwict, Mew Jersey

CONSTITUENT SERVICE CENTERS
112 Vitlam Center Orl«e
Freehold. Nj 07728-2510
(732)780-3035

4573 South Bmart Strset
Hamilton, NJ 08620-2215
(6091 685-7878

108 Lacey Road, SdRe 3BA
Whiting, NJ 08759-1331
(732)350-2300

2373 Raybum House Office Hwilrtmg
Washington. DC 20&1S-30CW
i202! ?25-3765

hup://chrtssrni!h,house.gov

Congress of tfje Uniteti States

l^ousc of 3Xcpre6cntatibrs

SENIOR MEMBER. FOREIGN AFFAIRS

COMMITTEE

CHAIRMAN, AFTRICA, GLOBAL HEALTH
GLOBAL HUMAN RIGHTS, AND
INTERNATIONAL ORGANIZATIONS

SUBCOMMITTEE

WESTERN HEMISPHERE

SUBCOMMITTEE

CO-CHAIRMAN, COMMISSION ON SECURITY
AND COOPERATION IN EUROPE

CO CHAIRMAN CONGRESSIONAL-EXECUTIVE
COMMISSION ON CHINA

DEAN, NEW JERSEY DELEGATION

September 24, 2013

Matthew Westgate

Geologist/Remedial Project Manager
Environmental Protection Agency - Region 2
290 Broadway, Floor 19
New York, New York 10007-1823

Dear Mr. Westgate,

On behalf oi'lhe residents of Monmouth County, 1 would like to thank you and your team for your
efforts on the White Swan/Sun Cleaners Remediation project. 1 know that we both believe that the health
and safety of the residents in the affected area are of utmost importance.

! have been contacted by Mr. John Papandrea of 29 Willow Way, Manasquan. regarding a request
for soil testing. Mr. Papandrea has expressed his concern about potential contamination of the soil in and
around the Manasquan High School athletic fields which will soon be under construction. He therefore
requests that soil samples be taken in the butter zone that abounds Judas Creek between the athletic fields
and the homes on Willow Way. Since construction may begin soon, Mr, Papandrea has asked that this
project be given a high priority so it may be completed before any construction begins.

Additionally, Mr. Papandrea has requested air sampling be done at liis home. As you know, toxins
were previously found in Judas Creek which runs along his property, but no air testing has been done at his
residence thus far. Mr. Papandrea has indicated that he has already reached out to you on these matters
and expressed that you were very helpful. The purpose of my correspondence is to respectfully ask you to
expedite the consideration of his request

Thank you v ery much for your prompt attention to this matter. 1 know Mr. Papandrea's concern*
will be carefully and objectively reviewed. 1 would appreciate you contacting Jo Schloeder, Director of
Public Policy in my Freehold office, regarding your plans in this matter so we may keep the constituent
apprised. As always, I am grateful for your assistance.

CHS:jss

Sincerely,

fame'

CHRISTOPHER H. SMITH
Member of Congress

Cu-Chairman of 'he following coalltreins: Task Force on Atttwtmer's Disease * Bi-P»ra»»fi Coalition tof Comftatllfl Antt-Seminwn • Lyme Disease Caucus
Coalition ten Autism Research ana E/Jucalion » Global Internet Freeoom Caucus • Bi-Partisan Congressional Pfo-Life Caucus * Bosnia Caucus
Ad Hoc Congressional Cominltlet (or Irish Affairs * Congressional Caucus on Human Trafficking * Vietnam Cau«.us * Poland Caucus

©

PRM fjrft Htrn'.ii R3 fApeP

-------
U.S. HOUSE OF REPRESENTATIVES

WASHINGTON, DC 2051 *-3004
PUBLIC OOCUMENT

OFFICIAL BUSINESS	*	•

Matthew Westgate
Geologist/Remedial Project Manager
Environmental Protection Agency"
Region 2

290 Broad way. Floor 19
New York, New York 10007

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Westgate, Matthew

From:

Sent:

To:

Subject:

John Frisco [jsfrisco@gmail.com]

Thursday, September 19, 2013 7:45 PM
Westgate, Matthew; Echols, Cecilia; Mugdan, Walter
Supplemental White Swan Proposed Plan Comments

This is to supplement the comments previously provided on the above proposed plan. My earlier comments
raised some question about the adequacy of the proposed groundwater remedy and whether there may be
benefits to a more aggressive or comprehensive action. I wanted to further discuss or clarify the benefits issue
to ensure that my comments are fully understood and properly addressed.

To begin with, this is is not the typical groundwater contamination problem where the quality of drinking water
is the primary concern. At this site, PCE and TCE in the groundwater can enter homes via the vapor intrusion
route. Subslab ventilation systems are being utilized in the near-term to protect the health of impacted
residents. These systems, considered temporary, are effective as long as they are properly maintained. The
long-term or permanent solution to the problem is to reduce groundwater contaminant levels to a point where
the in-house temporary systems are no longer needed.

Evaluation of the effectiveness of groundwater actions should not only consider the time necessary to meet
drinking water standards in the aquifer but also include the time to reduce contaminant levels such that the
ventilation systems can be removed. In addition, the evaluation should determine whether more aggressive
remedial action can reduce the footprint or number of homes requiring ventilation systems. The ultimate goal
of the remedy should be to clean up the groundwater in a reasonable time frame while also reducing the reliance
on the temporary ventilation systems. My guess is that residents may prefer to not have to rely on the systems
longer than absolutely necessary. Evaluation of the benefits of more aggressive remedial action should be
performed in this context. Modifications to the proposed remedy may be considered depending on the results of
this evaluation.

Thank you for the opportunity to comment on the proposed remedy during the public comment period. I look
forward to your response.

l

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Westgate, Matthew

From:

Sent:

To:

Subject:
Attachments:

Gamberg, Kate [KGamberg@njleg.org]

Thursday, September 19, 2013 4:53 PM
Westgate, Matthew

Public Comment on the White Swan/Sun Cleaners Superfund Site
White Swan Public Comment.pdf

Dear Mr. Westgate:	f

Please find attached a public comment from Senator Bob Singer, Assemblyman Sean Kean and Assemblyman Dave
Rible on the White Swan/Sun Cleaners Superfund Site.

Thank you for your attention to this correspondence.

Sincerely,

Kate Gamberg

Kate Gamberg

Chief of Staff

Office of Assemblyman Sean Kean
1955 Highway 34, Building 2A
Wall, NJ 07719
(732) 974-0400

l

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ASSEMBLYMAN SEAIM KEAN

1955 Highway 34, Bldg. 2A, • Wall, NJ 07719 'Phone: (732) 974-0400 • Fax: (732) 974-2564

September 19,2013	Assemblyman Sean Kean

Contact: Kate Gamberg	(732) 974-0400

DISTRICT 30 LEGISLATORS COMMENT ON
WHITE SWAN/SUN CLEANERS SUPERFUND SITE

CLEAN UP PLAN

Senator Robert W. Singer, Assemblyman Sean T. Kean and Assemblyman David P.
Rible (R-Monmouth, Ocean) issued the following public comment on the Environmental
Protection Agency's (EPA) Proposed Plan for the White Swan Cleaners/Sun Cleaners
Area Groundwater Superfund Site:

"As state representatives for the impacted communities and residents directly affected by
this Superfimd Site, we have contacted the Environmental Protection Agency (EPA) and
are coordinating efforts with Congressman Chris Smith. We urge the EPA to select the
most health conscious and expeditious option to address soil and groundwater
contamination."

it tt n n
. Tttltfit

)

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WestgateJVlatthew

Sent:

To:

Cc:

Subject:

From:

Echols, Cecilia

Thursday, September 19, 2013 4:25 PM
Westgate, Matthew
stevemazzal @yahoo.com
White Swan Cleaners

Received a call from a homeowner. He would like his home tested.

Steven & Jennifer Mazza
1325 Willow Drive
SeaGirt, NJ 08750

732-449-1781

1

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Westgate, Matthew

From:

Sent:

To:

Subject:
Attachments:

Gamberg, Kate [KGamberg@njleg.org]
Thursday, September 19, 2013 4:44 PM
Westgate, Matthew
Meeting Request
Letter to the EPA.pdf

Dear Mr. Westgate:

Please find attached a letter requesting a meeting with the EPA to discuss the White Swan/Sun Cleaners Superfund Site.
This letter was mailed today. Thank you for your attention to this correspondence.

Sincerely,

Kate Gamberg

Kate Gamberg

Chief of Staff

Office of Assemblyman Sean Kean
1955 Highway 34, Building 2A
Wall, NJ 07719
(732) 974-0400

l

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NEW JERSEY STATE LEGISLATURE

Legislative district Office
30th District

Robert w. Singer

Senator
SenSinger@njleg.org

Assemblyman

AflmSKeam@njleg.org

SEAN T. KEAN

September 19,2013

David P. Rible
Assemblyman

AsmRible@njleg.org

Mr. Matthew Westgate

Remedial Project Manager

United States Environmental Protection Agency

290 Broadway, 19th Floor

NY, NY 10007-1866

Dear Mr. Westgate:

We represent the 30th Legislative District in New Jersey which includes Manasquan, Sea Girt and
Wall Township. As the state representatives of these communities, we are very concerned about
the White Swan/Sun Cleaners Superfund Site and the proposals to clean up the groundwater and
soil contamination.

As such, we would greatly appreciate the opportunity to meet with you and be briefed on the
proposals and the U.S. Environmental Protection Agency's (EPA) preferred alternative to address
soil and groundwater contamination. In addition, we would like to invite Congressman
Christopher Smith and the governing bodies of Manasquan, Sea Girt and Wall Township to join
us at this meeting. This briefing would provide municipal, state, and federal elected officials with
the opportunity to speak directly to the EPA about the project and be informed on the EPA's
preferred alternative proposal.

Thank you for your consideration of this meeting request. Please feel free to contact our offices to
discuss this request.

cc: Congressman Christopher Smith; Mayor George Dempsey, Manasquan; Mayor Ken Farrell,
Sea Girt; Mayor Todd Luttman, Wall Township

RS/SK/DR/kg

Ocean county office

1771 MADISON AVENUE • SUITE 2
LAKEWOOD, NJ 08701
Phonk: 732-901-0702
fax: 732-901-0587

Monmouth County office
1955 HIGHWAY 34- BLDG. 2A
WALL, NJ 07719
Phone: 732-974-0400
Pax: 732-974-2664

Printed on Recycled Paper

-------
Westgate, Matthew

From:

Sent:

To:

Subject:

Carafe, Lorraine [lcarafa@seagirtboro.com]

Thursday, September 19, 2013 4:30 PM
Westgate, Matthew

Re: Borough of Sea Girt, White Swan Remediation Comments

Good afternoon, Matthew,

The information that was given to me is that home testing had not started in Sea Girt as of this date. If this
information is not correct, please advise where I may find it.

Also, one of the concerns expressed with the plan is the outlier date of almost 30 years for completion of this
project - far too long, considering that this has been going on for at least 10 years already. Are there plans to
move more quickly to remove the contaminated groundwater?

Thank you.

Lorraine P. Carafa, RMC, CFO
Borough of Sea Girt
321 Baltimore Blvd.

Sea Girt, NJ 08750
Tel: 732.449.9433, xl 16
Fax: 732.974.8296

On Thu, Sep 19,2013 at 4:24 PM, Westgate, Matthew  wrote:

EPA tested the groundwater in Sea Girt during our Remedial Investigation and a number of homes have had indoor air
sampling done since 2001.

Any comments on our Proposed Plan?

Thanks,

Matthew Westgate, Project Manager/Geologist

U.S. EPA Region 2

New Jersey Remediation Branch

Southern New Jersey Remediation Section

290 Broadway, 19th floor

Lorraine,

1

-------
New York, N.Y. 10007-1866
(212)637-4422
Westgate.matthew@,epa. gov

From: Carafe, Lorraine [mailto:lcarafa@seaairtboro.coml
Sent: Thursday, September 19, 2013 4:06 PM
To: Westgate, Matthew

Subject: Borough of Sea Girt, White Swan Remediation Comments

Mr. Westgate,

For your information and files.

Thank you.

Lorraine P. Carafa, RMC, CFO
Borough of Sea Girt
321 Baltimore Blvd.

Sea Girt, NJ 08750
Tel: 732.449.9433. xl 16
Fax: 732.974.8296

2

-------

Westgate, Matthew

From:	Carafa, Lorraine [lcarafa@seagirtboro.com]

Sent:	Thursday, September 19, 2013 4:06 PM

To:	Westgate, Matthew

Subject:	Borough of Sea Girt, White Swan Remediation Comments

Attachments:	White Swan to Congressman Smith 9.12.2013.docx

Mr. Westgate,

For your information and files.
Thank you.

Lorraine P. Carafa, RMC, CFO
Borough of Sea Girt
321 Baltimore Blvd.

Sea Girt, NJ 08750
Tel: 732.449.9433, xl 16
Fax: 732.974.8296

l

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September 12,2013

The Honorable Christopher H. Smith
NJ District 4

112 Village Center Drive, 2nd Floor
Freehold, NJ 08827

Re: White Swan Groundwater Contamination
Dear Congressman Smith:

Thank you, on behalf of the governing body of Sea Girt, for your assistance in this matter. The
testing of homes in Sea Girt to determine if any are adversely affected by this groundwater contamination
and/or air quality issues has been discussed with the EPA for at least three years, and to date, no homes in
Sea Girt have been tested. Our residents are entitled to know what, if any, negative impact the
contamination may be causing in our community. We request that the testing of homes within Sea Girt be
expedited, problems identified and remediation begin immediately thereafter.

The Borough of Sea Girt was also compelled to install an air stripper at our Water Treatment
Plant when groundwater contamination was discovered within the DPW complex at the initial cost in
excess of $50,000, when testing and DEP fees are included. Additional costs were incurred when the
plant was rehabilitated in 2011-12, at an additional cost in excess of $25,000 for these costs. The Borough
is seeking reimbursement of the expenses incurred due to the contamination that spread into our facility.

Please do not hesitate to contact me at 732.449.9433, xl 16, if you have any questions.

Very truly yours,

Lorraine P. Carafa, RMC
Clerk-Acting Administrator

LPC/jmh

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Westgate, Matthew

Subject:
Attachments:

Sent:

To:

Cc:

From:

Richman-La Londe, Alexa [ALALONDE@RIKER.com]

Thursday, September 19, 2013 12:09 PM
Westgate, Matthew

Urdaz, Damans; Moulthrop, Samuel; Dalleinne, Christopher P; Swenson, Ken -Legal
White Swan/Sun Cleaners Ground Water Contamination Site - Proposed Plan
Comments on Proposed Plan.pdf

Dear Matt,

Please see the attached letter providing the Bank's comments on the Proposed Plan. Thank you.

Alexa

a

Alexa Richman-La Londe | Counsel
Riker Danzig Scherer Hyland & Perretti LLP

Headquarters Plaza | One Speedwell Avenue | Morristown, NJ 07962-1981
f 973.451.8495 | f: 973.451.8718 | alalonde@riker.com | www.riker.com

IRS Circular 230 Disclosure:To ensure compliance with requirements imposed by the IRS, we inform you that
any U.S. federal tax advice contained in this communication (including any attachments) is not intended or
written to be used, and cannot be used, for the purpose of (I) avoiding penalties under the Internal Revenue
Code or (II) promoting, marketing or recommending to another party any transaction or matter addressed
herein.

Confidentiality Notice; This e-mail contains information that is privileged and confidential and subject to legal
restrictions and penalties regarding its unauthorized disclosure or other use. You are prohibited from copying,
distributing or otherwise using this information if you are not the intended recipient. If you have received this e-
mail in error, please notify us immediately by return e-mail and delete this e-mail and all attachments from your
system. Thank You.

i

-------
RIKER
DANZIG
SCHERER
HYLAND

Samuel P. Moulthrop

Partner

Direct:
t: 973.451.8471
f: 973.451.8695

PERRETTIup

smoulthrop@riker.com
Reply to: Morristown

ATTORNEYS AT LAW

September 19, 2013

VIA E-MAIL and HAND DELIVERY

Matthew Westgate, Remedial Project Manager
New Jersey Remediation Branch
Emergency and Remedial Response Division
U.S. Environmental Protection Agency
Region II

290 Broadway, 19th Floor
New York, NY 1007-1866

Re: White Swan/Sun Cleaners Ground Water Contamination Area Superfund Site
Comments on Proposed Plan

Dear Mr. Westgate:

provides the Bank's comments on the United States Environmental Protection
Agency's ("EPA") Proposed Plan for the White Swan Cleaners/Sun Cleaners Area
Groundwater Contamination Superfund Site (the "Site"), dated August 2013.

Pursuant to the 2006 Administrative Settlement Agreement and Order on
Consent for Remedial Investigation and Feasibility Study ("RI/FS") with EPA, the Bank,
through its consultant AMEC Environment & Infrastructure ("AMEC"), conducted the
RI/FS, upon which the Proposed Plan is based. The objective of the RI/FS process is to
gather information sufficient to support a decision as to which remedy is the most
appropriate for a given site. The Bank devoted substantial resources to perform and

Headquarters Plaza, One Speedwell Avenue, Morristown, NJ 07962-1981 • 1973.538.0800 f: 973.538.1984
50 West State Street. Suite 1010.Trenton, NJ 08608-1220 • t 609.396.2121 f: 609.396.4578
500 Fifth Avenue, New York, NY 101 10 • t: 212.302.6574 f: 212.302.6628 "

London Affiliate: 33 Cornhill, London EC3V 3ND, England • t: +44 (0) 20.7877.3270 f: +44 (0) 20.7877.3271

This firm represents Bank of America, N.A. (the "Bank"). This letter

www.riker.com

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Matthew Westgate, RPM
September 19, 2013
Page 2

prepare a comprehensive and thorough RI/FS. The Bank supports EPA's selection of
the Preferred Alternative as the remedial approach to be implemented for the Site.

Notwithstanding the Bank's support for the selection of the Preferred
Alternative, the Bank disagrees with certain statements and conclusions in EPA's
Proposed Plan that EPA inferred or deduced from the data in the RI/FS. Our
disagreement does not affect the selection of the Preferred Alternative but addresses
certain EPA statements and conclusions that are not material to the remedy selection,
but are important to providing accurate conclusions regarding the meaning of the data
in the RI/FS. As you know, the Bank and EPA have disagreed on several conclusions to
be drawn from the Rl data. To put it colloquially, we have "agreed to disagree" as the
RI/FS was prepared. The primary disagreement involves the EPA conclusion inferred
from the data regarding the extent of mixing between the contaminant plumes from
the two separate source areas. The initial draft of the Rl Report included detailed
discussion regarding this topic. The detailed conclusions made by AMEC in the draft
Report were removed at EPA's insistence because it avoided an impasse with EPA
regarding these conclusions, however, the underlying Rl data support AMEC's
conclusions. There is no dispute between EPA and AMEC that the data from the Rl
are technically sound and complete (in terms of quality and quantity) and, as EPA
agrees, are sufficient upon which to base a remedial decision. The Rl data support
AMEC's conclusions as set forth below, and these comments were provided in much

4409027v2

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Matthew Westgate, RPM
September 19, 2013
Page 3

greater detail by AMEC to EPA in response to EPA's comments on draft reports
(which are part of the administrative record).

Specifically, the Bank disagrees with EPA's statements and conclusions in the
Proposed Plan that there is one groundwater contaminant plume associated with the
Site. These conclusions and statements are made throughout the Proposed Plan.
Specific examples include, but are not limited to, in the Site Description on page 2:
"The groundwater contaminant plume extends from these two sources areas to the
east and is approximately one mile wide and two miles long." In the Groundwater
portion of the Site Characteristics section on page 4 of the Proposed Plan EPA states
"The Site's groundwater plume is contaminated with PCE at levels ranging from I ppb
to 75,000 ppb, and continues to migrate from the two source areas located near Route
35 eastward to the Atlantic Ocean, approximately 2 miles away." In addition, on page
4, EPA states "There are two areas of the plume, in close proximity and downgradient
of the two source areas which generally contain the highest levels of groundwater
contamination."

Contrary to EPA's characterization as to one plume, the Rl data clearly establish
that there are two largely distinct and separate ground water plumes at the Site, and
that the edges of these plumes overlap in a limited area (primarily Laurel and Magnolia
Avenues, east of Old Mill Road). A contaminant plume is defined by a longitudinal
center of mass aligned along an orientation controlled by the hydraulic gradient.
Separate and distinct plumes emanating from the White Swan property and the Sun

4409027*2

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Matthew Westgate, RPM
September 19, 2013
Page 4

property have been fully and accurately characterized. As each plume emanates from
its respective source area, the plumes do not overlap or mix at all for a distance of
roughly 1,500 and 2,500 ft from the White Swan and Sun source areas, respectively.
Even after the two plumes have traveled this distance to the area east of Old Mill Road
in the vicinity of Laurel and Magnolia Avenues, only the low-concentration peripheral
edges of the two plumes appear to overlap, but they retain their separate plume
characteristics. The data do not support the conclusion that there is one plume
associated with the Site or that there is substantial mixing and communication between
the plume emanating from White Swan property and the plume emanating from the
Sun property. Rather, the data indicate that the edges of the plumes within a portion
of the Site where the plumes are in close proximity (i.e., the region between MW-R-20
and MW-R-8 and south of MW-R-7) appear to overlap.

Extensive additional data support the separation of the centers of mass between
the two plumes. Specifically, the continuity of the highly concentrated contaminant
plume from the Sun property to Waterbrook Florist, Christie Lane and the Barlow
Flower Farm is mapped and confirmed consistently by every analytical technique
applied during the Rl. The two plumes also exhibit distinct characteristics relative to
chlorinated solvent daughter product ratios. In addition, prior investigations by NJDEP
also support the conclusion that there are two separate plumes with only a limited
area of mixing at the edges.

4409027v2

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Matthew Westgate, RPM
September 19, 2013
Page 5

The Bank's position, which includes the references to the technical data that
supports these conclusions, is clearly established in the administrative record (through
letters and e-mails provided to EPA during the development of the RI/FS) and
specifically in the following exhibits, among others, attached hereto:

Exhibit A. 9/23/11 Response to EPA Comments on Draft Remedial
Investigation Report;

Exhibit B. 12/2/II Response to EA Comments on Final Draft (Revised)
Remedial Investigation Report dated September 13, 2011;

The Bank and EPA have additional disagreement on other conclusions to be
drawn from the data, however, the Bank believes these comments are part of the
administrative record as set forth in the exchange of draft reports, EPA comments and
the Bank's response to those comments. None of those disagreements impact the
selection of the Preferred Alternative. The Bank does not waive any argument,
defense, or other issue not raised in these comments and specifically reserves the right
to raise these issues when appropriate, as well as the right to challenge any EPA
conclusions derived from its one plume theory.

Samuel P. Moulthrop

4409027*2

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EXHIBIT A

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ame
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Mr. Matthew Westgate
September23, 2011
Page 2

amecP

must be presented separately from the monitoring well results obtained from wells
Installed and sampled as part of this Remedial Investigation. Screening data, collected
through Hydropunch and MIP sampling, Is not subject to the same QA/QC procedures as
samples collected from monitoring wells. Therefore, while screening data may be
considered by EPA, EPA will rely on monitoring well data when making decisions about
risk and remedial alternatives. Separate Maps, Tables and cross-sections containing only
qualified Rl monitoring well sample data should be submitted In the Rl report

Additional Comment 4 (3/9/11): Screening data Includes temporary Hydropunch
groundwater and soil samples, soil gas surveys using Gore-Sorbers, ECD and MIP tool
responses, etc. This data should be included In the Rl report and may be referenced;
however, these data alone are not to be used to draw substantial conclusions regarding
risk or selection of remedial alternatives. Screening data can be discussed in
conjunction with reproducible samples collected from permanent monitoring wells.
Therefore, you should discuss or qualify the distinction between screening and
monitoring well data where appropriate throughout the body oftheRI Report

Response: As EPA has recognized, separate data presentations containing the results of
monitoring well data alone were incorporated in the initial Draft RIR and remain in the Final RIR
(Tables 15,26,33, and Figures 14A, 16A, 18A, 20A, 22A, 26A, 28A, 46A, 47A).

As noted in the RIR, screening-level technologies typically provide indicators of the presence,
absence, and/or magnitude of contamination, rather than directly quantifying contaminant
concentrations. The screening-level surfidal investigations performed at the Site included
geophysical surveys at the source area properties (to identify subsurface structures/anomalies),
and a passive soil vapor survey (PSV), to map the distribution of contaminant mass in the
vadose zone within and down-gradient of the source area properties. Subsurface screening-
level investigations consisted primarily of membrane interface probe (MIP) test penetrations, to
map the lateral and vertical distribution of contaminant mass through Electron Capture Device
(ECD) response, and Soil Color Optical Screening Tool (SCOST™) penetrations, to rapidly
characterize subsurface lithology (between control borings) in advance of MIP testing. It should
be noted that the passive soil vapor survey method employed in the Rl achieved a higher
resolution of VOC constituents than the EPA reference method (as documented in the EPA
Technology Verification Report EPA/600-R-97/150), and the ability of the MIP to provide a very
high correlation (r2 -0.90) with saturated soil VOC concentrations measured with EPA Method
8260 has been successfully implemented and documented by USACE (ERDC/EL TR-02-16).

These screening level techniques need to be differentiated from confirmatory ground water
quality sampling performed with hydropunch ground water sampling techniques using
Geoprobe® direct push technology (DPT). The hydropunch samples were obtained using
techniques and equipment verified by the EPA Environmental Technology Verification Program
(EPA/600/R-03-086), analyzed by certified laboratories, and validated using EPA Region 2
protocols. While we understand that these data may not be considered definitive relative to
human health risk assessment analysis, they are appropriate and useful to identify and
delineate patterns in the lateral and vertical distribution of contaminants within the context of
conceptual site model (CSM) development, estimate the distribution of contaminant mass, and
where corroborated by the results of monitoring well sampling, define the limits and boundaries
of the contaminant plumes. In all cases, the results of hydropunch ground water sampling were
highly correlated with the results of co-located monitoring wells (RIR Figure 41).

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¦ Mr. Matthew Westgate
September23,2011
Page3

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Mr. Matthew Westgate
September 23,2011
Page 4

amecP

should be noted In the RJ report that the IACU Is not continuous across the entire site. It
Is absent In the north central part of the she In the vicinity ofHannabrand Brook.

Additional Comment 113/9/11): Regarding the Intra Aquifer Confining Unit (IACU) and the
change of Its name to the Intra Aquifer Low Permeability Unit (IALPU) throughout the Rl
Report, EPA agrees to the name change.

Additional Comment 2 (3/8/11): Relative to the lateral extent of the IALPU, you Indicated
that we are In agreement, that the IALPU acts to segregate shallow contamination from
the deeper aquifer. As discussed, we agree that contamination was not detected beneath
the IALPU In any of the deep monitoring wells, however, then Is a component of
downward groundwater flow across the unit (see Figures 15, 17, 19, 21, 2% 25, 27, 29)
and PCE contamination was detected In wells that were screened approximately 9 feet
Into the top of the unit (MW-R5-I; MW-R12-I). The unit acts to Impede the flow If
contaminated groundwater, but It Is not an Impermeable confining unit Please clarify
this throughout the Report

EPA does not agree that the IALPU Is laterally continuous access the entire site. It Is
clear that the IALPU Is not present In the vicinity of Hannabrand Brook, as seen In the
LHhologlc Borings. EPA agrees that the IALPU Is present throughout most of the Site.
Please clarify this throughout the Report

Response: The Draft RIR had referred to an "inter-aquifer confining unif (IACU). Our use of
this phrase to characterize the unit was intended to follow the convention applied by Jablonski
(1968) and others (e.g., RIR Table 22), recognizing that local confining beds" of low
permeability deposits occur throughout the Kirkwood Formation. EPA had concerns with
characterization of the unit as "confining." Recognizing that designation of the unit as confining
or semi-confining is related to unit hydraulic properties that cannot be fully determined through
the level analysis performed in the Rl (which focused primarily on the characteristics of
permeable deposits), consensus was reached between EPA and the Bank regarding the low
permeability characteristics of the IACU and the fact that monitoring data do not indicate
penetration of the unit by contamination into the lower confined aquifer. As such, the
description of the unit was changed from IACU to "intra aquifer low permeability unif (IALPU)
throughout the Final RIR.

Regarding the issue of vertical ground water flow, it is important to make a distinction between
hydraulic potential and ground water flow;. The three dimensional ground water flow vector at
any point is a function of the hydraulic head potential (difference in measured ground water
elevations) and the hydraulic conductivity. As noted in the RIR, the geometric mean vertical
hydraulic conductivity (K) estimated for the IALPU is about 0.003 ft/day (1.1 x 10-6 cm/sec),
compared to a geometric mean lateral hydraulic conductivity in the overburden aquifer of about
8 ft/day (although calibrated about an order of magnitude higher in the numerical ground water
flow model). Given a difference of about only one order of magnitude between the lateral and
vertical head potential, but a difference of 4-5 orders of magnitude in lateral K versus vertical K,
ground water flow within the Site will be predominantly horizontal. The hydraulic cross-sections
illustrated in the initial Draft RIR were prepared prior to calibrated numerical flow model profiles
and have been revised slightly in the Final RIR to better reflect estimated hydraulic head
potential across the IALPU.

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Similarly, contamination of the surface of a low permeability unit underlying a contaminated
aquifer through the process of diffusion is a common and well-known phenomenon, and in feet
is referenced extensively in the RIR (e.g.. Chapman and Parker, 2005; Sale et al., 2008). The
presence of such contamination has no bearing on whether the IALPU as a whole is considered
a confining or semi confining unit

The Bank believes the following available data supports a finding that the IALPU is present
across the Site: (1) during literature review performed as part of Work Plan preparation for the
Rl, the presence of the IALPU was suggested in geophysical logs from across the region
(Sugarman and Owens, 1994), and regional production well logs (e.g., Sea Girt Borough
municipal well logs #3 and #7, and Ihe Waterbrook Florist well log); (2) the characteristic surface
of the unit was identified at over 100 control boring and SCOST (soil color probe) locations
across the entirety of the Site (including throughout the north central portion of the Site where
no deep borings were installed); (3) at every location within the Site where the surface of the
unit was identified and deep borings were advanced to install monitoring wells in the confined
aquifer, the unit was observed and fogged; i.e., 11 locations across the central and southern
portions of the Site (30-50 ft thick); (4) two boring logs for production wells installed at St
Catherine's Cemetery (Draft RIR Appendix R), located just south of Hannabrand Brook that
indicate the presence of the IALPU1 (these borings were located in the "north-central" portion of
the Site); (5) the results of Shelby Tube samples obtained from the surface of the IALPU at
monitoring well locations MW-R-9, MW-R-14 and MW-R-21 (within the "north-central" portion of
the Site) exhibited vertical hydraulic conductivities ranging from 4.4 x 10"6 cm/sec, 9.9 x 10"*
cm/sec, and 4.3 x 10~7, all characteristic of the low permeability unit; and (6) the only location
where the IALPU was not observed was in one exploratory boring located north of the Site in
the erosional corridor (floodplain) of Hannabrand Brook; it was again encountered about 150 ft
north of that location at MW-R-6D.

To accommodate EPA's concern given the one location where the IALPU was not observed, it
was agreed that the language of the RIR describing the presence of the IALPU would be
changed to say present across "most" of the Site, with specific identification of the only area
where it was not encountered (north of the Site in the erosional channel of Hannabrand Brook).

General Comment 3 (12/21/1 Oi: Based on the information contained In this Remedial
Investigation Report, there Is Insufficient evidence to conclude that the two identified
source areas generate distinct, separate plumes that maintain their separate identities
across the entire site to Hannabrand Brook ami die Atlantic Ocean. Although much of the
contamination from the White Swan source area migrates in an east-north-easterly
direction, there Is a distinct mixing zone where contaminant mass blends together from
both source anas. This mixing zone is approximately from Laurel Ave, (MW-R-20)
northeast to Terrace Place, (MW-R-21). All references in the document that describe the
"Sun Cleaners plume" should be removed from the document References to the "White
Swan plume" should be referred to, where appropriate, as the "north-central part" o/ the
plume.

1 These logs indicate the presence of characteristic low permeability soils at a depth and thickness that is
generally consistent with the mapping of the IALPU provided in the RIR (e.g., Well Permit No. 29-23028:
"brown silty day", 38-56 ft bg; Well Permit No. P200906156: "gray silty sand": 10-20 ft bgs, "fine gray
sand with clay": 20-67 ft bgs)

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example, In Figure 37, It would be helpful to label the Sea Girt municipal Well Field
(referenced on page 31, & paragraph).

Response: In the preparation the Draft RIR Figures, it was determined that inclusion of all of
the reference information on all of the maps would interfere with the data presentations in many
cases, especially on smaller sized figures. Figure 2 of the RIR is a "Pertinent Site Features"
map that was specifically prepared to locate a range of streets, water bodies and geographic
features that are referenced throughout the text of the RIR. Draft RIR Figures 8 and 9 (location
maps for ail of the subsurface investigations and monitoring well installations) also provide
detailed street information. The location of the Sea Girt municipal well field was added to Figure
37 in the Final RIR, and to the extent that it did not interfere with the clarity of mapped
information, additional location information was added to many of the other Final RIR figures.

General Comment 5 (12/21/10): If degradation of the contaminants Is discussed,
geochemlcal parameters of the particular section of the aquifer referenced should be
presented In a meaningful context to support the theories presented (see page 67, 2nd
paragraph). If the data In Tables 33 and 33a supports the "different source area
fingerprint9 conclusion, further discussion to support tills should be Included. The
language In the Report should be adjusted to reflect that In the vicinity of the Sun
Cleaners property, a slightly enhanced environment for In-sltu blodegradation may be
present The fingerprint of the contaminants alone does not support conclusions about
the environment itself, it Is but one of the lines of evidence which may be used. The same
goes for page 75, paragraph 3. The discussion presented Is useful, but should be
augmented to include measured parameters to support the statements made.

Response: Specifically, mean total organic carbon is higher (3.2 vs. 2.1 mg/L) and dissolved
oxygen and oxidation reduction potential are lower (0.75 vs. 5.12 mg/L and 193 vs. 218 mv,
respectively) in monitoring well ground water samples obtained from the Sun property relative to
those obtained from the White Swan property (Table 33A). Of importance in review of the
daughter product ratio data is that differences in plume characteristics between the two source
areas can be observed, and that these differences correlate to areas of the plumes that would
be expected to be distinct based on mapped concentration distributions and flow paths.

Additional Comment 5 (3/3/11): The groundwater flow model is a mathematical
simulation of the regional flow patterns based on estimated boundary conditions,
averaged or estimated hydraulic properties of the aquifer, estimated recharge rates etc.
The model Illustrations and figures do not serve as evidence that the plume Is divided
into two separata and distinct cores that maintain their Integrity across the entire site.
This must be clarified In the revised report

Response: Details regarding the design and calibration of the numerical flow model prepared
for the Site are contained in Appendix W. The model was developed using model code,
practices and procedures widely and routinely accepted in the practice, and achieved a very
high correlation (low RMS error) with measured field conditions (hydraulic head distribution). To
the north, west and south, boundary conditions were established well beyond the Site physical
boundaries to minimize their effect on the simulations. The calibrated steady state model was
run under a wide range of recharge and pumping conditions, to allow for evaluation of these
significant hydraulic influences on ground water flow paths and discharge. The results of these
analyses indicated distinct flow paths from the White Swan and Sun source areas (as simulated

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County (NJDEP, 2002), and the Site Summary section of the Hazard Ranking System
Documentation Package (Weston, 2003). The source of this information is contained in
Attachment I of the Site Investigation, White Swan Laundry and Cleaners, Wall Township,
Monmouth County (NJDEP, 2001b), which is a "Magnolia Lane Fact Sheet" prepared by the
Monmouth County Board of Health, dated March 31, 1999. A footnote has been added to the
Final RIR to note that there is no explanation in the record to explain the seven year delay in
reporting.

Comment 12: Page 6, section 1.3.3, 2nd paragraph -see comments 3 and 6 regarding
"nd1" and "nd2".

Response: In the Final RIR, the Site Investigation, Sun Cleaners, Wall Township, Monmouth
County is referred to as "NJDEP, 2001a" instead of and1", the Site Investigation, White Swan
Laundry and Cleaners, Wall Township, Monmouth County is referred to as "NJDEP, 2001b"
instead of "nd2", and the Site Investigation, Gulf Service Station, Wall Township, Monmouth
County is referred to as "NJDEP, 2001c* instead ofndS".

Comment 13: Page 6, section 1.3.3, 5® paragraph, 3rd sentence -Insert"Appendix A"
after Table A-1.

Response: "Appendix A" will be inserted after Table A-1.

Comment 14: Page 6, section 13.3.1, 2nd paragraph, 1 sentence - Insert "Appendix A"
after Table A-1.

Response: "Appendix A" has been inserted after Table A-1.

Comment 15: Page 8, section 1.3.3.2, 20rf paragraph, title -Provide date and specify "Gulf
Service Station Site Investigation" Instead of ndX.

Response: The citation has been revised to show the title and date of the report Site
Investigation, Gulf Sen/ice Station, Wall Township, Monmouth County (NJDEP, 2001c).

Comment 16: Page 12, section 1.3.4, paragraph 2 -remove references to "at or above 60
ug/m3 and below 6 ug/m3". Please Indicate that EPA Installed systems In 6 residential
buildings ami 2 commercial buildings and NJDEP Installed 19 systems.

Response: The references to "at or above 60 ug/m3 and below 6 ug/m3" have been
removed and the tBXt has been revised to read: "Based on the analytical results, EPA installed
ventilation systems in 6 residences and 2 commercial establishments.....NJDEP additionally
installed ventilation systems in 19 buildings."

Comment 17: Page 14, section 1.3.5.3, 3rd paragraph, last sentence - Remove the
sentence "It is believed....in Section 4.2.1." The Rl report just provides the characteristics
of the aquifer and contamination plume.

Response:

The sentence has been removed.

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Comment 18: Page 39, Section 3A Soils, Last sentence. Include In this report the detailed
Inhumation about site soils that you Indicate are contained In tin SLERA (AMEC, 2010c).

Response: Section "3.Z4 Soils? of the SLERA has been inserted into Section 3.4 of the
Final RIR, and "Figure 5: Monmouth County Soli Survey Map' from the SLERA has been
added as Figure 74.

Comment 19: Page 44, section 3.7, 1st paragraph, last sentence -Table 18 Is not a
IHhologlc section but a table of slug test results. Insert Lfthologlc reference tables.

Response: The Table 18 reference has been revised to Table 22 (Geologic Formations and
Their Water Bearing Properties in Monmouth County, New Jersey) in the Final RIR.

Comment 20: Page 44, section 3.7,4" paragraph, T* sentence -Remove the sentence that
reads "A significant finding of the Rl Is that this IACU does appear to exist across the

entire area of the site,	" This Is not accurate and should be removed. Also see general

comments.

Response: Refer to response to General Comment 2 (12/21/10) and Additional Comments 1
and 2 (3/9/11).

Comment 21: Page 45, section 3.7,1st paragraph, 1* sentence -Remove the sentence "As

such, It has been Identified as a distinct hydrostratigraphlc unit	within the site". EPA

disagrees based on the available facts gathered during the Rl. Uthology varies laterally
and Is not consistently Impermeable across entire site. A permeable barrier Is not
present in north central part of she.

Response: Refer to response to General Comment 2 (12/21/10) and Additional Comments 1
and 2 (3/9/11).

Comment 22: Page 45, section 3.7, T* paragraph, last sentence -If the IACU was not
found In a boring north ofHannabrand Brook, then Its thickness Is zero, not 12 to 15 feet
as indicated by Figure 11.

Response: Figure 11 plots only data from deep monitoring well borings, and estimates a
decreasing IACU (IALPU) thickness gradient across the northern portion of the Site, based on
the gradient observed across the central and southern portions of the Site and the lithology
observed at MW-R-6D in Spring Lake Heights. Isopach contours were specifically not mapped
across Hannabrand Brook because the characteristic IALPU lithology was not observed in a
single exploratory boring that was advanced in the flood plain of Hannabrand Brook north of the
Site (-150 ft south of MW-R-6D). Please refer to the response to General Comment 2
(12/21/10) and Additional Comments 1 and 2 (3/9/11), which provides more information
regarding the basis for the mapped distribution of the IALPU, including the availability of
production well logs from the area south of Hannabrand Brook (St Catherine's Cemetery) and
Shelby Tube samples from monitoring well clusters installed south of the Brook, that document
the presence of the low permeability unit in the "north central" area of the Site. In the Final RIR,
the isopach contour Interval closest to Hannabrand Brook has been dashed.

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Comment 23: Page 46, section B-B' 1st paragraph -In Figure 16 you show 1,200 ug/l PCE
located 5 to 7 feet below the top surface of the Inter Aquifer "Confining Unit". This IACU
Is not confining, as demonstrated by contamination detected within or below the surface
of the unit

Response: Contamination of the surface of a low permeability unit underlying a
contaminated aquifer through the process of diffusion is a common and well-known
phenomenon, and in fact is referenced extensively in the RIR (e.g., Chapman and Parker, 2005;
Sale et al., 2008). The presence of such contamination has no bearing on whether the IACU
(IALPU) is considered a confining or semi confining unit

Comment 24: Page 48, section 3.8.1,1" paragraph, 2" sentence - It Is stated here Within
the western third of the site, unconflned aquifer flow Is oriented to the northeast, towards
Hannabrand Brook..." This Interpretation Is based on Figures 42 to 44 and the
subsequent figures. However groundwater flow lines are based on points where
Groundwater Elevations dates are not indicated except for "spring". Please indicate in
the legend which specific dates apply to the elevations represented in the flow lines.

Response: As indicated in the Legends on the Figures, the mapped hydraulic gradients are
based on ground water level elevation data obtained from monitoring weds on May 4, 2009
(Figures 42-44), June 1,2009.(Figure 45), and October 5,2009 (Figures 46-49). Appendix T of
the Draft RIR contains maps of hydraulic gradient by monitoring zone for each month across the
period March 2009 - March 2010; there is little observed change in ground water flow patterns.

Comment 25: Page 55, section 4.2.2.1, paragraph 1, Indicate which of the soli samples
contained In Figure 32 are from monitoring wells Installed as part of tills Remedial
Investigation and generate a Figure which shows only that date.

Response: No vadose zone soil samples were collected from monitoring well borings as part
of the Remedial Investigation. In accordance with the Work Plan (AMEC, 2007) vadose zone
soil samples were obtained at depths of 0-2 ft. 2-10 ft (and/or the location of the highest
recorded PID/MP reading), and at the water table interface. At 5 borings on each of the White
Swan and Sun properties, these samples were analyzed for TCL VOCs, TCL SVOCs and TAL
metals. At 9 additional boring locations on the Sun property and 18 additional locations on the
White Swan property, supplemental, targeted TCL VOC samples were obtained in the vadose
zone. Figures 32 and 35 map the PCE concentration distribution obtained from all of these
samples.

Comment 26: Page 58, section 4.2.2, paragraph 2, In Figure 35, the soil mass and
contamination levels are portrayed as In the White Swan example. Please Indicate which
soil values are from the permanent monitoring wells Installed as part of tills remedial
investigation. Please duplicate the figure using only that data.

Response: See response to Specific Comment 25, above.

Comment 27; Page 61, section 4.3, paragraph 4, Remove the sentence "Figure 37 does
provide an accurate depiction of the lateral extent of contaminant plumes... "through (2)
on page 62. The MIP Is only a screening tool and the ECO response patterns do not
directly Indicate concentrations of PCE In groundwater. The statement that the MIP ECD

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patterns define the lateral extent and separation of the plumes Is not accurate and must
be removed. The MIP tool can be an Indicator that concentrations may be higher In
certain areas like Magnolia Ave or Barlow's Flower Farm, but the groundwater samples
from the monitoring wells define exactly how high the levels are.

Response: Please refer to the conclusions cited by Dena Crumbling of EPA's Technology
Innovation Office in response to General Comment 1 (12/21/10) and Additional Comment 4
(3/9/11) relative to the utility and applicability of "screening level" data to the site investigation
process. Also, note that available, published validation data for the use of the MIP to
characterize subsurface solvent contamination indicate a correlation coefficient (r2) of 0.90
between saturated soil concentration and MIP response2. Notwithstanding the above, the Bank
has revised the text of this section to indicate that the MIP was used to provide a detailed
means of understanding the relative distribution of solvent contamination in the subsurface.
These data were essential in the dynamic execution of the Work Plan, to target horizontal and
vertical sampling zones for more comprehensive confirmatory analysis with hydropunch ground
water sampling and ultimately well installation and sampling. It is important to note that the
simplified presentation on Figure 37 maps only the highest MIP response from over 1,200
vertical readings obtained across 50-60 feist of penetration at each test location. Consequently,
while the Figure provides useful estimates of the limits of the contaminant plumes and regions
of elevated concentration associated with plume cores, jt obviously cannot depict features
associated with the three-dimensional distribution of mass; these are depicted in RIR Figures
14-29 and 38-40.

Comment 28: Page 62, section 4.3.1, paragraph 1, Remove Hem (3) mthe segregation of
the centers of contamination mass between plumes emanating from tin White Swan
Property and the Sun Property." There are many hydropunch samples that show
continuous, connecting areas of contamination between the north-central lobe and the
main plume on all three levels In the unconflned aquifer. See hydropunch locations lrlp-0
1 (160 ug/l) on the shallow map, Irl-s 15 (120 ug/l), mgnl-14 (12 ug/l) and grgy-05 (3.2 ug/l)
on the lntermedlate-1 map, M~S09 (79 ug/l) and hmlk-18 (17 ug/l) on the Intehnediate
map. Clearly, there Is considerable mixing and communication between the north central
lobe and the rest of the plume.

Response: The Bank does not believe that these statements accurately represent the data
collected during the Remedial Investigation. Please refer to response to General Comment 3
(12/21/10) and Additional Comment 3 (3/9/11).

Comment 29: Page 62, section 4.3.1, paragraph 2, 3* sentence -Remove the sentence
"About 12% of the total mass Is associated with the contaminant plume emanating from

the White Swan Property.	and 47A". Since there is mixing and communication In the

various plume lobes laterally and vertically. It is unreasonable to calculate mass in
separate volumes and attribute than to different sources.

Response: As discussed more fully in response to General Comment 3 (12/21/10) and

2 Karen F. Myers, William M. Davis, and Jed Costanza. 2002. Tri-Service Site Characterization and
Analysis'Penetrometer System Validation of the Membrane Interface Probe. U.S. Army Corps of
Engineers, Engineer Research and Development Center. ERDC/EL TR-02-16. July 2002.

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Additional Comment 3 (3/9/11), the Final RIR removes specific language assigning percentage
mass to areas of contamination within the Site.

The mass estimate in the Draft RIR was calculated by multiplying the mapped concentration
distribution for each monitoring zone illustrated on RIR Figures 38, 39, and 40 by an estimated
saturated thickness and porosity (this method is described in Ricker, 20083). Consequently, the
vertical distribution of mass was captured by each monitoring zone calculation and then
summed to derive a total concentration. The lateral distribution of mass between the plume
emanating from the White Swan Property and the plume emanating from the Sun Property was
estimated by a dividing line that was plaoad between MW-R-18, MW-R-19, MW-R- 20, MW-R-8,
and MW-R-21. This line traverses areas that either lie between the most highly concentrated
zones of each plume, or areas between the plumes where no contamination was detected.

The orientation of contaminant migration is controlled by the regional hydraulic gradient, and the
correlation of these factors is clearly mapped on figures 42-44 and 46-48. Given the constraints
on contaminant migration imposed by the hydraulic gradient, the only area where any degree of
lateral plume mixing would be possible lies within a small region between MW-R-20 and MW-R-
8 and south of MW-R-7 (and possibly portions of the areas between MW-R-8 and MW-R-21).
As the concentrations in the area are low compared to the more heavily concentrated plume
cores to the north and east variations in plume cross-sectional area in this region would result
in very small changes to the mass calculations (£1 %). Consequently, given the simplifying
assumptions necessary for this type of analysis, the calculations presented in the Draft RIR
represent a reasonable, relative estimate of the distribution of mass between the plume areas
mapped within the Site.

Comment 30: Page 66, section 4.3.1,1st paragraph, After the sentence "Figures 46A and
47A are maps of PCE distribution based solely on monitoring well ground water data.",
add the following sentence Mixing and continuous contamination are present In the
shallow monitoring well MW-R-8S (7.7 ug/l PCE) and In the Intermediate wells MW-R-81 -
(13 ug/l PCE) and MW-R-211- 1-(5.2 ug/l PCE) which demonstrates that the north central
plume lobe Is not separate from the remainder of the plume."

Response: The Bank does not believe that these statements accurately represent the data
collected during the Remedial Investigation. The very low concentrations of PCE detected in
MW-8S, MW-R-8I, and MW-21M relative to plume core concentrations in the hundreds or
thousands of ppb, coupled with the lack of PCE detection at MW-R-21 S, MW-R-211, MW-R-
18S, MW-R-181-1, MW-R-181, MW-R-19S, MW-R-19M, MW-R-191, MW-R-20S, MW-R-201-1,
and MW-R-201, clearly indicate the presence of two discrete plumes within the Site. The
dimensions and concentration gradients associated with these plumes are more accurately
defined in Figures 42-44 and 46-48 (based on an additional 500 data points), and the plume
distribution mapped in those figures correlates well with the measured ground water hydraulic
gradient and the results of numerical ground water flow modeling (Figure 72). Limiting the
evaluation of contaminant distribution to only those data obtained from monitoring wells,

3 Ricker, Joseph A. 2008. "A Practical Method to Evaluate Ground Water Contaminant Plume Stability".
Ground Water Monitoring & Remediation. Fall 2008. Vol. 28, No. 4; pp 85-94.

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ignoring hydropunch sample data, and discounting the constraints that the hydraulic gradient
imposes on flow paths, does not allow for a fully representative assessment of Site conditions.
In fact, EPA itself specifically argues against reliance on such a limited analysis (refer to
comments cited by Crumbling (2001) in the response to General Comment 3 (12/21/10) and
Additional Comment 3 (3/9/11).

Comment 31: Pago 67, section 4.3.2, paragraph 2, Include the following sentence In this
paragraph mVarying concentrations of TCE and DCE from the two different source areas
Indicates that one source Is older titan the other and the PCE horn the older site has had
more time to break down Into TCE and DCE downgradlent

Response: It is unclear whether this is the case, since available historic information
regarding the period of time over which dry cleaning operations were performed at the Sun
property and the White Swan property indicate that such operations were largely
contemporaneous. What does appear to be the case is that geochemical conditions at the Sun
property are generally more conducive to chlorinated hydrocarbon biodegradation that those at
the White Swan property. For example, as noted in the response to General Comment 5, mean
total organic carbon is higher and dissolved oxygen and oxidation reduction potential are lower
in samples obtained from the Sun property relative to those obtained from the WhitB Swan
property (Table 33A). Of importance in review of the daughter product ratio data is that
differences in plume characteristics between the two source areas can be observed, and that
these differences correlate to areas of the plumes that would be expected to be distinct based
, on PCE concentration distribution and flow paths.

Comment 32: Page 80, Section 5.2.1.1, the precipitation reference should be included.

Response: Precipitation data were derived from 45 year monthly average data from the
Lakehurst NAS weather station (www.weatherbase.coml.

Comment 33: Page 80-81, Section 5.2.1.1, It would be helpful to reference Figure 45 and
label the wafer bodies represented on that figure.

Response: Figure 2 of the RIR is a "Pertinent Site Features" map that was specifically
prepared to locate a range of streets, water bodies and geographic features that are referenced
throughout the text of the Draft RIR. Water bodies have been identified on Figures 42-49 in the
Final RIR.

Comment 34: Page 92, section 6.0 Summary and Conclusions: 1" paragraph. The Intra
Aquifer Confining Unit (74 CI/) Is not completely confining and therefore should be
referred to as a semi-confining unit The report demonstrates that there is downward flow
from the shallow uncorrfined part of the aquifer Into the deep zone below the LACU
therefore all references to "confining" unit should be modified to "seml-confinlng" In
addition, the IACU Is not continuous across the entire site. It Is absent In the north
central part of the site under Hannabrand Brook. Remove the statement "it appears to
exist across the entire area of the site, separating a shallow unconfined aquifer from a
deep confined aquifer...

Response: Please refer to the response to General Comment 2 (12/21/10) and Additional
Comments 1 and 2 (3/8/11).

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Comment 35: Page 92, section 6.0 Summary and Conclusions, 3rd paragraph. Bullet (3)
should be modified to Indicate that although much of the contamination from the White
Swan source area heads east-north-east there Is a distinct mixing zone where
contaminant mass blends together from both source anas. This mixing area Is from
Laurel Ave, MW-R-20 northeast to Terrace Place, MW-R-21.

Response: The Bank's position regarding the nature and extant of contamination is
described in response to General Comment 3 (12/21/10) and Additional Comment 3 (3/9/11). In
the Final RIR, this tBXt has been revised to read: "a mixing area of contamination down gradient
from the two source areas to the east of Old Mill Road in the vicinity of Laurel and Magnolia
Avenues;"

Comment 36: Page 9% section 6.0 Summary and Conclusions, 2nd paragraph, 1"
sentence-remove the part of the sentence that says "with about 12% of the total mass
associated with the contaminant plume emanating from the White Swan Property, ancf
88% with plume emanating from the Sun Property". Since there Is a definite zone
between MW-R-20 ami MW-R-21 that has not been fully characterized, a quantitative
estimate of contaminant mass distribution cannot be calculated.

Response: Please refer to response to Comment 29. In the Final RIR, the first sentence of
this paragraph has been replaced with the following: "The mass of dissolved PCE in the
unconfined aquifer was estimated to be approximately 4,220 lb (1,915 kg)."

Comment 37: Figure 34, Hydropunch Interval Maps for 26 to 32 feet and 32 to 38 feet -You
must remove the blue contaminated zone to tin west of ws-06 through ws-16 because
there are no data points to show 10 to 25 ug/L PCE in that area. Hydropunch Interval
Maps for 45 to 57 feet and 57 to 65 feet-You must remove the blue contaminated zone to
the west of ws-06 through ws-16 because there are no data points to show 10 to 50 ug/L
PCE In that area.

Response: These maps have been revised in the Final RIR so that the contaminant
distribution in external areas will be constrained by the limits of the available data.

Comment 38: Figure 73, it appears that only one data point Is available far Layer 2 ad
Layer 4. Please provide additional information on this.

Response: Three model layers were created to generally correspond to the three monitoring
zones within the unconfined aquifer. This was done primarily to allow for (1) vertical variation in
aquifer parameter estimates (if observed), and (2) potential future evaluation of remedial options
entailing establishment of vertical recirculation cells within the unconfined aquifer. Model Layer
2 corresponds to the 1-1 monitoring zone. The 1-1 monitoring zone was established subsequent
to the initiation of the Rl to characterize contaminant migration from the Sun property, primarily
in the western portion of the Site. As a result only a limited number of well screens (and
consequently, very little monitoring data) exists for this zone. There is only a very small variation
observed in hydraulic head between the 1-1 zone and the I zone (typically several hundredths of
a foot), and therefore essentially no consequence to the lack of available data for model
calibration within this zone. Layer 4 represents the IACU (IALPU), and no monitoring wells or
piezometers are completed in that unit.

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(3) Specific Comments on the Revised Rl Report dated April 29. 2011 (from EPAs Letter
dated August 3.2011)

Comment 1: Page xl, List of Acronyms: Change IACU Intra-aqulfer confining unit to
IALPU Intra aquifer low permeability unit

Response: This term has been revised to "IALPU: intra aquifer low permeability unit" in the
Final RIR text

Comment 2: Page 1, Introduction, Section 1.2 Site and Source Ana Characteristics,
Sentence 3 - On-site dry cleaning operations at the White Swan dry cleaners continued
after the bank purchased the property so take out the sentence 'when on-site dry
cleaning ceased and the bank's predecessor purchased the property". Ocean County
National Bank bought the property on 9/8/83 and Charles Mahoney ceased White Swan
dry cleaner operations In 1986. Reference to be Included -(Wall Township Application for
Site Plan Approval dated 7-24-84 "requests use of temporary trailer on she to house
White Swan Laundry during construction of new building, which will contain bank and
White Swan Laundry.").

Response: See response to Specific Comment 4 from EPA's December 21,21010 letter.

Comment 3: Page 3, first paragraph, After the seventh sentence add the following "From
1984 to 1986 White Swan dry cleaners and the bank operated from this same property."

Response: See response to Specific Comment 4 from EPA's December 21,21010 letter.

Comment 4: Page 4, paragraph 3, First sentence - explain 7 year gap between when
sample was collected (1990) and when It was reported (1997).

Response: The precise language provided in the Draft RIR is contained in several documents,
including the Unknown Source Investigation, Magnolia Avenue Groundwater Contaminatbn.
Wall Township, Monmouth County (NJDEP, 2002), and the Site Summary section of the Hazard
Ranking System Documentation Package (Weston, 2003). The primary source of this
information is contained in Attachment I of the Site Investigation, White Swan Laundry and
Cleaners, Wall Township, Monmouth County (NJDEP, 2001b), which is a "Magnolia Lane Fact
Sheet" prepared by the Monmouth County Board of Health, dated March 31,1999. The reason
for the seven year gap is unknown. A footnote has been added to the Final RIR text indicating
that the reason for the discrepancy is unknown.

Comment 5: Page 8, fourth paragraph - What was sampled In the 1999 NJDEP
Investigation? Was It the waste oil product, soil or water?

Response: Waste oil/sludge.. According to the Site Investigation, Gulf Service Station, Wall
Township, Monmouth County (NJDEP, 2001c), "NJDEP personnel collected a sample from the
waste tank"; analytical results were reported in a table entitled: "Underground Waste Tank
Results".

Comment 6: Page 9, last paragraph, Use "ppm" for soil and sediments and "ppb" for
water here and throughout entire document

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. Mr. Matthew Westgate
September 23,2011
Page 19

ame(P

Response: Units of ppm for soil and ppb for water have been incorporated in the Final RIR text
in lieu of mg/kg and ug/L.

Comment 7: Page 11, last paragraph, 3rd bullet, AOC 3, change the direction from
"northeastto "east-northeast" when describing the VOC plume migration from White
Swan.

Response: These bulleted items paraphrase direct language from the source document
(NJDEP, 2003). The Bank has incorporated into the RIR the eixact language from the
document, as follows:

"AOC 1. A Volatile Organic Compound ground-water (water table) plume
emanating from the former Sun Cleaners facility, migrating east-Northeasterly
beneath and also discharging into the intermittent stream Judas Creek, and also
migrating east-northeasterly into and through the Borough of Sea Got, eventually
discharging into the Atlantic Ocean, about 2- miles from the source area;

AOC 2. Surface-water Volatile Organic Compound contamination of Judas
Creek, starting up-gradient around the vicinity of Newark AveJNursery and Judas
Creek, and extending an unknown distance downstream;

AOC 3. A Volatile Organic Compound ground-water (water table) plume
emanating from the former White Swan Cleaners facility, migrating northeasterly,
and discharging into a tributary to Hannabrand Brook about 3000 - feet away
from the source area;

AOC 4. Potential soils VOC contamination at the former Sun Cleaners location;

AOC 5. Potential surface water VOC contamination of Hannabrand Brook and its
unnamed tributary."

A footnote has been added to the Final RIR text to note that, relative to AOC 3, the orientation
of the hydraulic gradient (and contaminant migration) in the immediate vicinity of the White
Swan property is to the east-northeast

Comment 8: Page 12, sixth paragraph, Last sentence. Indicate that the Investigation
program Is currently ongoing In 2011, not 2010.

Response: This change has been made in the Final RIR text.

Comment 9: Page 14, last paragraph, use micrograms per liter not milligrams per liter for
Indoor air or sub-slab vapor sample results.

Response: Revision to units has been made in the Final RIR text.

Comment 10: Page 19, Section 2.3.1 HHP Test Penetrations, second sentence change
Intra-aquifer confining unit IACU " to Intra-aquifer low permeability unit IALPU" here and
throughout the entire document

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Mr. Matthew IVesfgate
September 23,2011
Page 20

amecP

Response: This term has been revised to "intra aquifer low permeability unit" or "IALPU" in the
Final RIR text

Comment 11: Page 23, second, third and fourth paragraphs, please explain that there Is
some potential far cross contamination when a temporary rod Is advanced through
contaminated sediments to collect groundwater samples because It Is not completely
decontaminated at each interval.

Response: Due to the notBd continuing problems with the presence of sediment fines in
recovered ground water samples, and the heaving of sediments, acquisition of multiple ground
water hydropunch samples from the same direct push penetration was limited primarily to a
number of test locations within the source area properties (where samples at 5 ft intervals
across the saturated zone were required). Down-gradient of the source areas (where shallow
contaminated sediments are not present in any event), nearly all of the ground water
hydropunch samples were obtained from separate test penetrations: the water table samples
were obtained with the Temporary PVC Weir method, and the "1-1 zone" and "l-zone" samples
were obtained using "SP-15" expendable ("sacrificial") well screens. Consequently, the Bank
does not believe that the condition identified by EPA occurred at the Site (nor is it suggested by
the results of comparative water quality sampling and analysis; RIR Figure 41). A footnote has
been added to the Final RIR that states the following:

"It should be noted that with the use of hydropunch-type sampling devices, there
is the potential for contamination associated with shallow sediments to be
"dragged" to lower sampling intervals, thereby biasing these lower samples.
Improvements in sampling equipment and sampling protocols over the past 20
years have largely minimized the occurrence of such biases, and none were
observed in the test results from this Remedial Investigation'

Comment 12: Page 25, Section 2.4.1 MIP/SCOST Investigation, please explain that the
SCOST only observes the color of the penetrated beds and does not return a sediment
sample to the surface to allow a Geologist to physically evaluate the grain size and clay
content

Response: The intent of the SCOST was not to provide geotechnical information regarding
sediments, but as noted in the text of the RIR, to interpolate the surface elevation of the IALPU
between lithologic control borings, in order to provide a target depth for MIP penetration and
ground water hydropunch sampling. Consequently, data derived from the SCOST were not
applied in a vacuum, and in cases where results were equivocal, conventional boring and
sampling was performed (over 65 borings were advanced for the purpose of documenting the
surface of the IALPU, as noted in RIR Tables 11 and 14). EPA is aware that in many locations
the characteristics of the IALPU (including dark color) is very distinctive from overlying, lighter
colored colluvial, beach and estuarine deposits, and consequently, use of the SCOST was
appropriate for this application.

Comment 13: Page 27, Third paragraph, 3" sentence change "plumes'' to "plume".

Response: The Bank's position regarding the nature and extent of contamination is described
in response to General Comment 3 (12/21/10) and Additional Comment 3 (3/9/11). The section
of the RIR that is the subject of this comment discusses the location and placement of

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. Mr. Matthew Westgate
September 23,2011
Page 21

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Mr. Matthew Westgate
September 23,2011
Page 22

amecP

Additionally, in the third paragraph on Page 29, the second sentence has been revised
to read: "Well cluster MW-R-8 and piezometer cluster PZ-R-1 were located between the
highly contaminated areas in the central and western portions of the Site, cluster MW-R-
15 was located...".

Comment 17: Page 30, First paragraph, last sentence - Table 14 contains Geotechnkal
Lab Data, not well sampling data.

Response: This reference has been revised to Table 13 in the Final RIR text

Comment 18: Page 45, 3rd paragraph, Absence of clay layer below Hannabrand Brook
should be referenced to SCOST location "cemetery 01" and llthology log from "cemetery
04" where It shows It does not exist

Response: This statement is unclear. Both of the referenced logs indicate the presence of the
IALPU at a depth of approximately 33 ft bgs. Specifically, the lithoiogic log references 12 ft of
"clayey silt, sand and silt and sandy silt" before terminating at 45 ft bgs. As discussed
previously with EPA, well installation logs from the cemetery (RIR Appendix R) also provide
similar information. The Bank believes this description is consistent with the language used in
the RIR to generally describe the characteristics of the IALPU: 'Unit lithology and texture vary
from thick sequences of sBt and/or day, to interbedded zones of silty sand and fine sand, or silt
and day with IMe fine sand..."

Comment 19: Page 46, First paragraph, last sentence - Figure 11 shows the thickness of
the IALPU Is 12 feet near Hannabrand Brook. Since It Is absent near Hannabrand Brook,
the thickness should bo zero. Correct figure 11 and revise the text

Response: Review of information provided above in the response to Comment 18, including
well construction logs from the cemetery, suggests that the IALPU is present at a thickness of at
least 12 ft south of Hannabrand Brook. The only location where it was not encountered was in a
boring advanced immediately to the north and within the floodplain of Hannabrand Brook. It was
again encountered further north of the Brook at MW-R-6. The RIR text states this information
accurately. Figure 11 was previously modified to eliminate contour mapping within or north of
Hannabrand Brook. In the Final RIR, the 12 ft isopach contour line on Figure 11 has been
dashed, to more clearly indicate that the IALPU thickness is inferred in this area.

Comment 20: Page 49, first paragraph, second sentence, change the sentence to read "
Within the western third of the site, unconfined aquifer flow is oriented to the EAST-
northeast.". See Figure A-5, Appendix A.

Response: This change has been made in the Final RIR text.

Comment 21: Page 49,4th paragraph, first sentence, change the sentence to read "Within
the western half of the site, the hydraulic gradient In the unconfined Shallow and
Intermediate monitoring zones Is oriented to the east-northeast towards discharge Into
the perennial Hannabrand Brook stream channel network and east towards the ocean."

Response: See response to Comment 22, below.

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. Mr. Matthew Westgate
September 23,2011
Page 23

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Mr. Matthew Westgate
September 23,2011
Page 24

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Mr. Matthew Westgato
September23,2011
Page 26

Response: While AMEC wetlands scientists and ecologists believed that the fall survey in
^November 2006 was appropriate for the evaluation of habitat, an additional survey was
performed in April 2011, following consultation with EPA. The results of the supplemental survey
were documented in a technical memorandum submitted to EPA on April 29, 2011, and in the
text of the pending Final Screening Level Ecological Risk Assessment (SLERA). The findings of
the April 2011 survey did not differ from those of the November 2006 survey.

As always, if you have any questions regarding the information provided in this comment-
response document please feel free to contact me or Chris D'Alleinne of Bank of America.

Sincerely,

AMEC

Stephen E. Posten
Project Coordinator/Principal

3-7726-0004

c: C. Petersen, EPA
K. O'Connell, EPA
S. Moulthrop, Riker Danzig
A. Anastas, Bank of America
C. D'Alleinne, Bank of America
J. Wamicke, AMEC

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EXHIBIT B

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ame

December 2, 2011

Mr. Matthew Westgate, Remedial Project Manager

New Jersey Remediation Branch

Emergency and Remedial Response Division

U.S. Environmental Protection Agency

Region II

290 Broadway

19th Floor

New York, NY 10007-1866

Re: Response to EPA Comments on Final Draft (Revised) Remedial Investigation
Report (RIR) dated September 13, 2011

White Swan Cleaners/Sun Cleaners Area Ground Water Contamination Superfund
Site ("Site")

Dear Mr. Westgate:

On behalf of Bank of America ("Bank"), AMEC is submitting this response to EPA's comments
on the Final Draft (revised) RIR text dated September 13, 2011. EPA's October 13, 2011,
comments were received by the Bank on October 17, 2011 and a meeting was held with EPA
on November 1, 2001, after which some additional revisions were submitted for EPA's review.
EPA provided additional comments by e-mail dated November 10th. There have been
subsequent discussions and e-mails seeking to resolve EPA's comments. Changes to the text
of the Rl, as agreed during our meeting and in subsequent discussions, are provided below
along with additional technical discussion, where warranted.

Comments on the text of the Revised Rl report dated September 13,2011

Comment 1: Page 14, first paragraph, 7.27 ppm is 7,270 ppb not 7,200 ppb.

Response: The correct value from Figure A-5 (Appendix A) is 7,190 ppb (previously, 7.19 ppm
had been rounded to 7.2 ppm). This change has been made in the text.

Comment 2: Page 14, Section 1.3.5.4,4th sentence - Change milligrams to micrograms.

Response: This change was previously made in the final draft of the document.

Comment 3: Page 22 Section 2.3.4, footnote 11, last sentence - remove the words: " and
none were observed in the test results from this Remedial Investigation.'' In this study
there was no specific investigation comparing sample results from the hydropunch vs.
monitoring wells at the same locations in order to demonstrate that the hydropunch
samples were free of cross contamination from contaminated sediments above the
sampled interval.

AMEC Earth & Environmental, Inc.

285 Davidson Avenue, Suite 405
Somerset, New Jersey 08873
Tel (732) 302-9500

Fax (732) 302-9504	www.amec.com

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Mr. Matthew Westgate
December 2, 2011
Page 2

Response: Figure 41 of the Rl, and the corresponding table contained on Page 61 of the Draft
Report ("Samples Used in the Preparation of Figure 41 Correlation Charts"), performs the
specific investigation noted in EPA's comment, and indicates that there is no apparent bias in
the data from the co-located hydropunch and monitoring well samples. The Table following
Figure 41 was included to indicate the depth intervals from which hydropunch samples were
obtained, for direct comparison with monitoring well screen installation depth (contained in
Table 12 of the Rl). To provide more clarity in this regard, the footnote has been revised to
read:

"It should be noted that with the use of hydropunch-type sampling devices, there
is the potential for contamination associated with shallow sediments to be
"dragged" to lower sampling intervals, thereby biasing these lower samples.
Improvements in sampling equipment and sampling protocols over the past 20
years have largely minimized the occurrence of such biases, and hone worn
observed in the test results from this Remedial investigation. As indicated
on the graphs comprising Figure 41, good correlation was observed
between co-located hydropunch and monitoring well sample data collected
during this Remedial Investigation."

Comment 4: Page 28, 3rd paragraph, second sentence - Remove "MW-R-8 and" from the
sentence "MW-R-8 and piezometer cluster PZ-R-1 were located between the apparent
side gradient limits of the White Swan and Sun plumes". MW-R-8 had 7.5 ppb of PCE and
Is therefore within the mixing area of the plume. PZ-R-1 is in between the two separate
contamination streams emanating from the two source areas, but MW-R-8 is within the
mixing area. The mixing area is defined by a line beginning sit MW-R-20 (on the west)
going east through MW-R-8 and northeast to MW-R-21 where contamination from the
White Swan and Sun Cleaners Source areas blend together.

In the Shallow part of the aquifer, the following PCE levels were observed from west
(MW-R-20) to east (MW-R-21):

LRL-S 15 - (15-20 ft) - 6.5 ppb
LRL-S03 - (15-20 ft) - 46.0 ppb
LRLP-01 - (20-25 ft) -160 ppb
AZLA-06 - (19-24 ft) -100 ppb
MGNL-14 - (15-20 ft)-41J ppb
MGNL-15 - (15-20 ft) - 5.3 ppb
HMLK-18 - (17-22 ft) - 2.6 ppb

In the Intermediate (I-1) part of the aquifer, the following PCE levels were observed from
west (MW-R-20) to east (MW-R-21):

LRL-S 15-(32-34 ft)-120 ppb
LRL-S03 - (32-34 ft) - 56 ppb
LRLP-01 - (36-38 ft) - 120 ppb
AZLA-06 - (30-32 ft) - 685 ppb
MGNL-14 - (31-33 ft) -12 ppb
MGNL-15 - (31-33 ft) -14 ppb

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Mr. Matthew Westgate
December 2, 2011
Page 3

HMLK- 18 - (30-32 ft) -1 6 ppb
GRGY-05 - (21-23 ft) - 3.2 ppb

In the Intermediate (I) part of the aquifer, the following PCE levels were observed from
west (MW-R-20) to east (MW-R-21):

LRLS03 - (48-52 ft) - 5.5 ppb
LRLP-01 - (49-53 ft)-23 and 28 ppb
AZLA-06 - (45-49 ft) - 99 ppb
MGNL-14 - (43-47 ft) -44 ppb
MGNL-15 - (42-46 ft) -22 ppb
HMLK-18 - (45-49 ft) - 17 ppb
GRGY-07 - (40-44 ft)-67 ppb
GRGY-05 - (37-41 fl)-58ppb

Clearly, If there was complete contamination separation to the north and south of this
line, PCE levels would be zero or less than 1 in all of these samples. There were 24 out of
26 samples with PCE above 1 ppb and as high as 160 ppb which indicates the White
Swan and Sun Cleaners contamination plumes are co-mingling before they continue
down gradient to the northeast, east and southeast

Response: The noted sentence was previously revised in the final draft of the document to read
as follows: "Well cluster MW-R-8 and piezometer cluster PZ-R-1 were located between the
highly contaminated areas in the central and western portions of the She..." This language
is consistent with that provided in preceding and subsequent paragraphs (as previously agreed
with EPA), and accurately describes the rationale for well placement during the active phase of
the Rl.

Note that the Bank's position regarding the nature and extent of contamination is set forth in the
response to General Comment 3 (12/21/10) and Additional Comment 3 (3/9/11) in the
September 23, 2011 response to comment letter. Further, the detailed delineation of PCE
levels from hydropunch samples described in the comment defines what the Bank believes to
represent the edges or boundaries between the more highly contaminated cores of the plumes
emanating from the White Swan Property and the Sun Property. The particular data referenced
in EPA's comment does not reflect the many non-detect ("IT qualified") or low concentration
(<10 ppb) sample points also located within this boundary area between the plumes that more
clearly suggest differentiation, including in the Shallow (S) zone: LRL-S11 (4.5 ppb), AZLA-04
(6.9 ppb), MGNLP-02 (9.6 ppb), MGNLP-01 (6.4 ppb), MGNL-16 (0.8 ppb), MGNL-17 (0.6 ppb),
HMLK-12 (0.4U ppb), and EVRGN-07 (2.9 ppb); in the Intermediate (1-1) zone: LRL-S12 (2
ppb), GRGY-07 (0.4U ppb), TERCE-06 (0.8J ppb), and CHGO-25 (0.73J ppb); and in the
Intermediate (I) zone: MGNLP-01 (0.4U ppb), MGNLP-02 (0.4U ppb), MGNL-18 (0.2U ppb).
MGNL-17 (1 ppb). Further, in some cases, the characterization of the delineation in EPA's
comment attempts to connect contaminated sample points across areas with essentially no
contamination (PCE < 1 ppb); for example, within the intermediate (I) zone, three sample points
with PCE concentrations < 1 ppb (MGNLP-01, MGNL-16, and MGNL-17) lie between the cited
sample points MGNL-15 (5.3 ppb) and HMLK-18 (2.6 ppb); correlation across this area is clearly
not valid.

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Mr. Matthew WestgatB
December 2, 2011
Page 4

Comment 5: Page 62, first paragraph, second sentence - change to read "(1) a
preferential east-northeast trend to the orientation of part of the contaminant migration
from the White Swan Property (toward Hannabrand Brook and its unnamed tributary
stream)". The conceptual Site Model was modified because the vapor survey showed
another lobe of the contamination from the White Swan source area splitting and heading
north east towards Hannabrand Brook but it does not show this new lobe is separate
from the White Swan contamination in the main part of the plume.

Response: The Bank's position regarding the nature and extent of contamination is set forth in
the response to General Comment 3 (12/21/10) and Additional Comment 3 (3/9/11) in the
September 23, 2011 response to comment letter. The section of the Rl addressed in EPA's
comment above describes the results of the passive soil vapor survey, as illustrated on Rl
Figure 3. The extent of the vapor survey was limited to the areas of the Site where it was
expected that the highest concentrations of PCE would be observed in the shallow aquifer,
since the vapor probes are most effective in such areas. As indicated on Rl Figure 3, these
areas consist of the source area properties and areas immediately down-gradient of the source
areas, extending only to the vicinity of Old Mill Road. Within the area of the vapor survey,
findings regarding the orientation of the contaminant plumes, reduced contaminant flux from the
White Swan Property (due presumably to prior removal actions), and the lack of contamination
between the plumes west of Old Mill Road, were corroborated by all subsequent analyses.

The text in this section was revised as follows: ".. (1) a preferential east-northeast trend to
the orientation of contaminant migration from the White Swan Property (toward
Hannabrand Brook and its unnamed tributary

Comment 6: Page 62, last paragraph that begins with "Figure 37..", last sentence - add
the words "combines with" between item (1) and (2) such that the sentence will read as
follows: (1) an east-northeast trending component of high MIP-ECD response in the
northwestern portion of the site associated with the White Swan property and extending
into the area of Old Mill Road and western Magnolia Avenue and then towards St
Catharine's Cemetery and Hannabrand Brook and combines with (2) an eastern trending
component associated with the Sun Property extending from Route 35 to Waterbrook
Florist and then to the central area of the Site.

Figure 37 clearly shows a mixing area of MIP-ECD response (herein reported to represent
PCE contamination) from Christie Lane east to Gregory Place. No conclusion is indicated
in Figure 37 that the two contamination masses are separate and heading in different
directions.

Additional November 10th E-Mail comment: When you say "an east-northeast trending
component" of the MIP response (aka - contamination) associated with the White Swan
Property is extending to Old Mill Road, western Magnolia Ave and then towards St
Catherine's Cemetery and Hannabrand Brook" you are intentionally ignoring the
component of that contamination from White Swan which is mixing with the Sun
contamination and heading east That sentence known as item (1) is not completely
accurate until you specify that not all of the White Swan contamination ends up in
Hannabrand Brook.

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Mr. Matthew Westgate
December 2, 2011
PageS

Response: As noted in the third paragraph on Page 62, the MIP response mapped on Figure
37 at each point represents the maximum ECD sensor value recorded from over 1,000 readings
obtained between ground surface and the surface of the intra aquifer low permeability unit (i.e.,
extending across the vadose zone as well as the saturated zone). Consequently, while patterns
in the distribution of contamination and the extent of contamination are evident from these data
(as noted in the text of the Rl), this map should not be used to draw conclusions regarding the
three dimensional migration of contamination in the saturated zone from the source areas.
Such conclusions must be drawn from actual water quality measurements and the orientation of
ground water flow (for example, as indicated on Figures 42-48). The maximum ECD value map
was used during performance of the Rl primarily to locate transects within which hydropunch
ground water samples (and ultimately monitoring well samples) would be obtained.

EPA's comments imply that no distinction can be made relative to the separate masses of
contamination. On review, however, it is noted that two large masses of maximum ECD
response exist (1) in the area of Laurel and Magnolia Avenues (east of Old Mill Road), and (2)
in the area extending between Christie Lane, Gregory Place and Bell Place. These masses
indicate an ECD response that is 0.5-1.5 orders of magnitude greater than those in adjacent
areas; such a variation in response is considered to represent a marked difference in field
conditions.

It is important to stress, again, that the map of maximum ECD data present only a limited view
of the MIP data. As indicated (for example) in Rl Figures 14 and 16, direct paths of contaminant
migration can be tracked across the Site in cross-section using the full extent of the MIP log
data. These cross-sections support the predominant migration pathways of contamination
illustrated on Figures 38-40 and Figures 42-48.

In closing, Figure 37 does not indicate that "...an east-northeast trending component of high
MIP-ECD response in the northwestern portion of the site ..." combines with "...an eastern
trending component associated with the Sun Property extending from Route 35 to Waterbrook
Florist." Figure 37 indicates that there are two predominant masses of contamination within the
Site, and provides secondary information about the extent of contamination.

In order to avoid impasse on language that would be acceptable to both the Bank and EPA, we
have decided to remove this paragraph. A description of the distribution of contamination that is
acceptable to both parties is contained in the following Section 4.3.1 of the Rl.

Comment 7: Page 66, second paragraph, first sentence - Change the sentence to read as
follows: PCE concentrations in monitoring wells down-gradient of the White Swan
Property are highest in the Magnolia Ave area (260 ppb - 460 ppb in the S and I
monitoring zones at well cluster MW-R-7), decrease to 5 ppb - 19 ppb south of
Hannabrand Brook (MW-R9S,I) and 11 ppb to the east in MW-R-12S, and are not detected
north of Hannabrand Brook (MW-R6S,D).

Additional November 10th E-mail Comment I had added the phrase and 11 ppb to the
east in MW-R-12S, to specify that PCE concentrations down gradient of the White Swan
Property also extended to MW-R-12. By changing the descriptive term associated with
the White Swan property PCE concentration, from "in the monitoring wells" to "within the
core of the contaminant plume" you did not change your main point of the sentence,
which is that White Swan PCE contamination is only found at Magnolia Ave, MW-R-7 and

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Mr. Matthew Westgate
December 2,2011
Page 6

Hannabrand Brook. Your statement is incorrect because it is not supported by the data
in the report Since there is mixing in the previously defined "Mixing Zone" (see my
comment #4), some White Swan contamination is present in MW-R-12S. My addition as
specified "and 11 ppb to the east in MW-R-12S, "must be included in your sentence or
strike the sentence entirely.

Response: As discussed previously with and acknowledged by EPA, the contamination that
extends northeast of Old Mill Road to Hannabrand Brook is predominantly associated with the
White Swan Property, and that the contamination that migrates past Christie Lane and the
Barlow Flower Farm towards Sea Girt is predominantly associated with the Sun Property.
Revision of the specified text to indicate that contamination detected in MW-R-12 is directly
associated with the White Swan Property is not consistent with these concepts. The Rl text in
the specified section has been revised as follows:

"PCE concentrations in monitoring wells within the core of the contaminant
plume down-gradient of the White Swan Property are highest in the Magnolia
Avenue area (260 ppb - 480 ppb in the S and I monitoring zones at well cluster
MW-R-7)., decrease to 5 ppb—19 ppb south of Hannabrand Brook (MW-R-
9S, I}, and are not detected north of the Brook (MW R-6S.D). PCE
concentrations in monitoring wells within the core of the contaminant plume
down-gradient of the Sun Property are highest elevated south of the Sea Girt
Mall (2,300 ppb - 13,000 ppb; MW-R-5S,I-1), at the Waterbrook Florist (210 ppb
- 1,100 ppb; MW-R-16S, 1-1), at the Barlow Flower Farm (78 ppb - 910 ppb;
MW-R-10S, I), and in the vicinity of the Sea Girt Borough municipal well field (11
ppb-410 ppb)."

The first sentence now describes where the highest concentrations were detected down-
gradient of the White Swan source. The beginning of second (Sun-related) sentence was then
edited in the same way, so both sentences now describe where the highest concentrations ("hot
spots") were observed. This is useful information in and of itself, and sets the stage for the
targeting of hot spots with active treatment in the FS.

Comment 8. Figure 10 - Change "Confining Unit" to "Low Permeability Unit" in Legend
label

Response: This change was previously made in the final draft of the document

As always, if you have any questions regarding the information provided in this comment-
response document, please feel free to contact me or Chris D'Alleinne of Bank of America.

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Mr. Matthew Westgate
December 2, 2011
Page 7

Sincerely,
AMEC

Stephen E. Posten
Project Coordinator/Principal

3-7726-0004

c: C. Petersen, EPA
K. O'Connell, EPA
S. Moulthrop, Riker Danzig
A. Anastas, Bank of America
C. D'Alleinne, Bank of America
J. Wamicke, AMEC

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MUNICIPAL, CLERK'S OFFICE
782-223-0544 EXT. 238
CONFIDENTIAL

FAX

TO: Mr. Matthew Westgate FAX: 212-637-4429
FROM: Edward Donovan, Council President
SUBJECT: White Swan Contaminated Site
Number of Pages including cover sheet: 2
Return fax: 732-223-1300	Date: September 19, 2013

MESSAGE: Attached please find White Swan/Sun Superfund Clean-
up Comments. Please do not hesitate to contact me with any
questions.

Thank you.

MrtAMfWMff, It. JL

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BOROUGH HALL, M)t EAST MAIN STREET

Incorporated December 30,1B87

732-223-0544
Fa* 732-223-1300

GEORGE R. DEMPSEY, JR,
Mayor

BARBARA ILAfllA
Municipal Clerk

September 18, 2013

BOROUGH. OJ=,m«lSlASQUAN

coui&TV! qfc
-------
Westgate, Matthew

Subject:
Attachments:

Sent:

To:

Cc:

From:

Maria, Barbara [bilaria@manasquan-nj.com]

Thursday, September 19, 2013 11:16 AM
Westgate, Matthew

Schloeder, Jo; Ed Donovan; Joe Delorio; George Dempsey

White Swan/Sun Superfund Clean up Plan Comments

White Swan Letter Comments.pdf; White Swan Letter Comments.pdf

Mr. Westgate,

Attached please find the Borough of Manasquan's comments on the White Swan/Sun Superfund Clean Up.

If you have any questions or need additional information please do not hesitate to contact Council Member
Edward Donovan or Borough Administrator, Joseph Delorio.

Thank you.

Sicvdkvia J. Jlaitia, StMC, (LMJR

Municipal Clerk
Borough of Manasquan
201 East Main Street
Manasquan, NJ 08736
P 732-223-0544
F 732-223-1300

E-mail: bilaria@manasauan-ni.com
"Like" Manasquan on Facebook Today!

WARNING: Email received by or sent to Borough Officials are subject to the Open Public Records Act
[OPRAJ.This message is intended only for the use of the addressees. It may contain privileged and/or
confidential information that should not be disclosed under applicable law. If you are not an addressee, or the
employee or agent responsible to deliver this message to an addressee, you are notified that any use or
dissemination of this message is prohibited, and that you should destroy/delete it immediately and advise the
sender. Thank you for your cooperation.

l

-------
BOROUGH HALL, 201 EAST MAIN STREET

Incorporated December 30,1887

732-223-0544
Fax 732-223-1300

GEORGE R. DEMPSEY, JR.
Mayor

BARBARA ILARIA
Municipal Clerk

BOROUGI^,OF:l^i4gslASaUAN

COUNTY Ogl^QNP^lbuTH

JOSEPH R. DeIORIO
Municipal Administrator/
Chief Financial Officer

September 18, 2013

Mr. Matthew Westgate
US EPA

290 Broadway. 19th Floor
New York, NY 10007-1866

Re: White Swan/Sun Superfund Clean-Up Comment

Dear Mr. Westgate:

On September 3,2013, the Manasquan governing body authorized a resolution concerning proposed
solutions by the EPA to remedy the White Swan contamination site. Although we support remediation,
the governing body specifically objects to EPA's Alternative #4 for Ground Water Remediation:

°lt is estimated that two extraction wells would be required for each source area and an additional three
may be needed to address downgradient hot spot areas pending further evaluation in the RD. A
groundwater extraction and treatment system would be constructed and operated for approximately 30
years."

."Treatment of groundwater in the plant would be achieved by several methods including air stripping and
GAC adsorption units, and the treated water would likely be discharged to a surface water body
such as Judas Creek, the sanitary sewer system, or re-injected into the aquifer."

In Manasquan, Judas Creek floods residential properties in the Willow Way area during significant rain
events. Water from the creek sometimes extends 80 feet into backyards bordering the creek at those
times. Judas Creek also passes very dose to Manasquan High School and through Manasquan
Elementary School before emptying into Stockton Lake. The borough believes the flooding problem would
be exacerbated if as much as 200 gallons per minute, 24 hours a day, 7 days a week were discharged
into the creek. Manasquan would suggest the EPA consider a plan where the treated water would be re-
injected into the aquifer.

Therefore, the Borough of Manasquan objects to remediation Alternative #4 for Ground Water
Remediation.

On behalf of Mayor George Dempsey and Borough Council,

SENT VIA FAX AND EMAIL
Fax: (212) 637-4429E-mail: westaate.matthew(S>eDa.aov

Ed Donovan
Council President
Borough of Manasquan

www.manasquan-nj.com

-------
BOROUGH HALL, 201 EAST MAIN STREET

Incorporated December 30,1887

732-223-0544
Fax 732-223-1300

GEORGE R. DEMPSEY, JR.
Mayor

BARBARA ILARIA
Municipal Clerk.

BOROUGH. OF MAN AS QU AN

COUNTY OFM'QN^OUTH

JOSEPH R. DeIORIO
Municipal Administrator/
Chief Financial Officer

September 18, 2013

Mr. Matthew Westgate
US EPA

290 Broadway. 19th Floor
New York, NY 10007-1866

Re: White Swan/Sun Superfund Clean-Up Comment

Dear Mr. Westgate:

On September 3,2013, the Manasquan governing body authorized a resolution concerning proposed
solutions by the EPA to remedy the White Swan contamination site. Although we support remediation,
the governing body specifically objects to EPA's Alternative #4 for Ground Water Remediation:

'ft is estimated that two extraction wells would be required for each source area and an additional three
may be needed to address downgradient hot spot areas pending further evaluation in the RD. A
groundwater extraction and treatment system would be constructed and operated for approximately 30
years."

°Treatment of groundwater in the plant would be achieved by several methods including air stripping and
GAC adsorption units, and the treated water would likely be discharged to a surface water body
such as Judas Creek, the sanitary sewer system, or re-injected into the aquifer °

fn Manasquan, Judas Creek floods residential properties in the Willow Way area during significant rain
events. Water from the creek sometimes extends 80 feet into backyards bordering the creek at those
times. Judas Creek also passes very dose to Manasquan High School and through Manasquan
Elementary School before emptying into Stockton Lake. The borough believes the flooding problem would
be exacerbated if as much as 200 gallons per minute, 24 hours a day, 7 days a week were discharged
into the creek. Manasquan would suggest the EPA consider a plan where the treated water would be re-
injected into the aquifer.

Therefore, the Borough of Manasquan objects to remediation Alternative #4 for Ground Water
Remediation.

On behalf of Mayor George Dempsey and Borough Council,

SENT VIA FAX AND EMAIL
Fax: (212) 637-4429E-mail: westaata.matthewt3)8Da.aov

Ed Donovan
Council President
Borough of Manasquan

www.manasquan-nj.com

-------
Westgate, Matthew

From:	Ellen Safka [wallmoml 1 @gmail.com]

Sent:	Wednesday, September 18, 2013 6:14 PM

To:.	Westgate, Matthew; Echols, Cecilia

Subject:	Thanks

I want to take the time to thank you both for your help. It is a pleasure to work with you and you are very
helpful.	-	.'

Please, remember we are your friends, not your enemies!

Ellen Safka

\

-------
)

Westgate, Matthew

Lake, Lauren [llake@townshipofwall.com]

Wednesday, September 18, 2013 4:41 PM
Westgate, Matthew

White Swan/ Sun Cleaners Letters to EPA- Township of Wall
EPA Lettter-Westgate 9.17.13.pdf; McMoran EPA Response 9.13.13.pdf

Mr. Westgate please see attached letter from Jeff Bertrand, Township Administrator and additional attachments (resident

correspondence received by our office).

Hard copies have been sent to you via regular mail as well.

Thanks very much. Lauren

Lauren Lake

Assistant to the Township Administrator
732-449-8444 est 216
llake@townshipofwall.com
www.wallni.com

From:

Sent:

To:

Subject:
Attachments:

l

-------
TOWNSHIP OF WALL

2700 Allaire Road
P.O. Box 1168
Wall, New Jersey 07719-1168

Todd W. Luttman, Mayor

Clinton C. Hoffman, Deputy Mayor

Ann Marie Conte

Jeffrey W. Foster

George K. Newberry

>- JeflEry L. Bertrand
Township Administrator

(732) 449-8444 Ext. 216
FAX (732) 449-8996

September 17, 2013

Mr, Matt Westgate
U.S. EPA

290 Broadway, 19th floor
New York, NY 10007

Dear Mr. Westgate:

The Wall Township Committee had the privilege .of attending the informational session conducted
by the U.S. Environmental Protection Agency (EPA) regarding the contamination of a portion of
Wall Township, Manasquan, and Sea Girt from White Swan Cleaners and Sun Cleaners. In
response, the Wall Township Committee encourages all Wall Township residents to send in their
opinions about the proposed clean up alternatives for the two sites, and the affected area ground
water to the EPA before the end of the public comment period on September 19, 2013.

The Township Committee supports the residents fully, especially those in the affected area, and are
in favor of the most palatable, effective and efficient solution available to clean up these
contaminants in the soil at the two sites and in the ground water.

The Township has great concern regarding the time that has elapsed since the initial discovery of
this situation. We will not accept any unreasonable or artificial delays in the implementation of the
project. Any solutions must take into account both the long term and short term needs and
concerns of our residents as well as those of the other effected communities to our east.

We look forward to seeing more detailed remediation plans for this project that should include
information on any potential construction and permanent facility noise, disruption of traffic patterns
especially those affecting school bus routes and our commuting residents as well as any potential
interruption of services. It should also be noted that one portion of the affected area (Laurel
Avenue) may be adversely affected by storm water runoff. Therefore it would be appropriate and
possibly necessary to include this in your studies and potential remedies.

In addition, we have been contacted by several residents that have requested additional regularly
scheduled air quality testing to take place in the area elementary school - Old Mill School. While the
school is not shown to be located in the impacted area, it is adjacent to the "far field area" oh Old.

-------
Mill Road as listed on the EPA promulgated map. Such testing should be initiated independendy of
the development of additional studies or plans arid certainly before any hard site work begins at the
site of the former cleaners.

In closing, wie would like to express our appreciation to Mr. Matt Westgate from the U.S.
Environmental Protection Agency (EPA) for his diligence, patience, arid forthright and
knowledgeable answers to the residents and our collective questions and concerns. It is our
understanding that Mr. Westgate has been working on this project for some time and has been
instrumental in addressing our residents' concerns through the implementation of air quality testing
in homes throughout the affected area.

We have also attached all correspondence the Township has received from residents regarding this
matter to date.

Sincerely,

On Behalf of the Township Committee
JLB/I1

cc: Township Committee

-------
McMORAN, O'CONNOR & BRAMLEY

A PROFESSIONAL CORPORATION
COUNSELLORS AT LAW

NEW 1ERSEY OFFICE

RAMSHORN EXECUTIVE CENTRE
BLDG.D, SUITE D-l
2399 HIGHWAY 34
WALL TOWNSHIP, NEW JERSEY 08736

(732) 223-7711 FAX: (732) 223-7750

REPLY TO:

NEW JERSEY OFFICE

NEW YORK OFFICE

75 ROCKEFELLER PLAZA
16™ FLOOR
NEW YORK, NEW YORK 10019
(800) 292-6640

WEB: www.mcmoranlaw.conl

BRUCE P. McMORAN

MEMBIUl OFNJ. NY, Fl. AND DC BAKS

bmcniorah@memoninraw.com

September 13, 2013

VIA EMAIL: lkubacz@township6fwall.com

Todd W. Luttman, Mayor
Township of Wall
2700 Allaire Road
Wall, NJ 07719

RE: White Swan Cleaners/Sun Cleaners Area Groundwater
Contamination Superfund Site

Dear Mayor Luttman:

I am 9 resident of 1210 Hemlock Avenue, Wall Township, NJ.

For approximately 20 years, the New Jersey Department of Environmental
Protection (NJDEP), and subsequently the United States Environmental Protection
Agency (EPA) have been aware of a Superfund Site in southern Monmouth County that,
affects thousands of your constituents.

In essence, the former owners of White Swan Cleaners on Sea Girt Avenue in
Wall Township and Sun Cleaners on the Manasquan circle in Wall Township, dumped
almost 5,000 pounds of toxic dry cleaning solvents into the ground over a 30-year period
from 1960 to 1991.

The toxic substance (PCE) naturally migrated through rainfall into the
groundwater system, forming a toxic plume of contaminants, which flow from those prior
locations through the groundwater of Wall Township, Manasquan, and Sea Girt. The
toxic plume affects not only the groundwater but the air quality in the area.

-------
Todd W. Luttman, Mayor
Township of Wall
September 13,2013
Page 2

After six years of involvement, in August 2013, the EPA finally proposed
alternative plans to deal with the toxic material which, as long as it remains on-site,
continues to further contaminate the groundwater and the air in the area. The EPA
proposed four alternatives to deal with the soil contamination, which were contained in a
Superfund Proposed Plan dated August of 2013, which was distributed to residents of
Wall Township in a meeting in the municipal building on August 27, 2013. In essence,
the four alternatives for dealing with the soil contamination are found at pages 9-10 of the
proposed plan.

The EPA proposed alternatives for dealing with the soil contaminations are as
follows:

•	Alternative 1 - No Action - Under this alternative, the EPA would take no
action, allowing the soil to remain on-site and continue the contamination for
current residents and generations to come. Clearly, this alternative (or non-
alternative) is unacceptable.

•	Alternative 2 - In-Situ Soil Vapor Extraction/Air Sparching for Sun
Cleaners and White Swan Source Area Soils. Under this alternative, the
EPA would take 10 years and spent $3.6 million to dig extraction wells and
perform other actions to remove the contaminants in the soil. During the 10-
year period, the contaminants would continue to leech into the soil and
groundwater.

•	Alternative 3 - Evacuation & Disposal of Soils at the Sun Cleaners &
White Swan Cleaners Source Areas. Under this alternative, the
contaminated soil from these two areas would be removed in one-year. This
alternative ends the problem with which the NJDEP, the EPA and the
residents have been dealing with for more than 20 years in a one-year period
at a cost of $8 million.

•	Alternative 4 - In-Situ Soil Vapor Extraction/Air Sparching at the Sun
Cleaners Source Area & Evacuation & Disposal of Soils at the White
Swan Source Area. This alternative is essentially a combination of
alternatives 2 and 3, which would remove and dispose of the White Swan soil
in one year. It would not remove the Sun Cleaners soil but instead have it
treated under Alternative 2 for a 10-year timeframe. The cost of this project is
estimated at $5.4 million.

Further on, at page 13 of the proposed plan, is a section entitled, "Long-Term
Effectiveness and Permanence." The first sentence under this analysis states, "The
highest degree of permanence and long-term effectiveness is achieved for those
alternatives that result in the greatest removed of contaminants from the site."

McMORAN, O'CONNOR & BRAMLEY

A PROFESSIONAL CORPORATION

-------
Todd W. Luttman, Mayor
Township of Wall
September 13,2013
Page 3

It should be obvious to anyone reading proposed alternative 3 and proposed
alternative 4, that alternative 3 results in the removal of all the contaminants in one-year.
Thus, any continuation of the problem in the future is limited to clearing up the
groundwater. There would be no further pollution. Despite the fact that this alternative
meets the goal of long-term effectiveness and permanence, stated on page 13 of the
analysis, the EPA does not recommend it. Instead, it recommends alternative 4, which
allows the groundwater contamination to continue for the residents for 10 years.

The difference in cost in these two proposals, according to the EPA, is $2.6
million; a minor number considering the potential negative health effects on the residents,
and on property values for home and business owners.

The only defense that the EPA gave to its selection of Alternative 4 over
Alternative 3 was that it could result in disruption of traffic in the area of the Manasquan
circle during the one-year process involving removal of the soil. That interference is not
enough of an. inconvenience to not clear up the problem in one year. Indeed, the safety
and health of the population should be put ahead of any potential short-term traffic
dislocations.

We would encourage you to contact the EPA and advise them that the residents of
this area would be better served by Alternative 3, providing for the removal of all
contaminated soils in a one-year timeframe.

Thank you very much for your assistance in this matter.

BPM/pl

Encs.

McMORAN, O'CONNOR & BRAMLEY

A PROFESSIONAL CORPORATION

-------
McMORAN, O'CONNOR & BRAMLEY

A PROFESSIONAL CORPORATION
COUNSELLORS AT LAW

NEW IERSEY OFFICE

RAMSHORN EXECUTIVE CENTRE
BLDG.D, SUITE D-l
2399 HIGHWAY 34
WALL TOWNSHIP, NEW JERSEY 08736

(732) 223-7711 FAX: (732) 223-7750

REPLY TO-.

NEW JERSEY OFFICE

September 13,2013
VIA EMAIL: westgate.matthew@epa.gov

NEW YORK OFFICE

75 ROCKEFELLER PLAZA
16" FLOOR
NEW YORK, NEW YORK 10019
(800) 292-6640

WEB: www.mcmoranIaw.com

BRUCE P. McMORAN

MHMnKR OFNJ, NY. 1L AND DCIIAHS

bmcmoran@mcmornnlaw.com

Matthew Westgate, Project Manager
U.S. Environmental Protection Agency
290 Broadway, 19fh Floor
New York, NY 10007-1866

RE: White Swan Cleaners/Sun Cleaners Area Groundwater
Contamination Superfund Site

Dear Mr. Westgate:

Please accept this letter as my written comments to the EPA's proposed plan
dated August 2013 for the above Superfund Site.

My wife and 1 reside at 1210 Hemlock Avenue, Sea Girt, NJ 08750. We
purchased the property on February 15, 2007. Despite prior correspondence with your
office in 2007 (see copy attached), the EPA continues to send notifications regarding this
property to the prior owner. See attached copy of post card addressed to Frank Cristeli,
which was sent in August 2013 advising us of the public meeting scheduled on August
27, 2013. Please correct your files and procedures to ensure that current residents receive
appropriate notification regarding this important subject.

My wife and I, along with a number of other people, attended the EPA meeting on
August 27,2013 at the Wall Township Municipal Center.

As we entered the meeting, we were given a 16-page single spaced handout
regarding the EPA's proposed plan. It would have been very helpful had this been sent to

-------
Matthew Westgate, Project Manager
September 13,2013
Page 2

everyone in advance of the meeting rather than trying to have to read it and digest it
during the time of the meeting.

The August 27, 2013 meeting was essentially an oral presentation of the same
materials contained in the proposed written plan. As far as I or other attendees could tell,
there was no additional information provided at the meeting.

Essentially, the pollution emanated from two drycleaners who operated from
approximately 1960 through 1991. It appears that these two drycleaners, Sun Cleaners,
located in the area of the Route 35/Manasquan traffic circle, and White Swan Cleaners,
located on the north side of Sea Girt Avenue, just east of Route 35, contaminated the soil
through dumping of dry cleaning solvents on or about their properties. This has resulted
in substantial PCE contamination (4,700 lbs) of the soil surrounding the drycleaners and
the groundwater flowing under those properties, and continuing east through Manasquan,
Wa]l Township and Sea Girt to the ocean. The White Swan contamination continues to a
depth of 25 feet, which is 10 feet below the water table.

The contamination was originally discovered in the early 1990's by a resident of
Magnolia Avenue in Wall Township. Subsequent sampling identified PCE at levels of up
to 1,500 parts per billion (ppb). T note that the EPA advises that anything exceeding 1
ppb is excessive.

The New Jersey Department of Environmental Protection (NJDEP) requested
EPA's involvement in December of 2001. Since then, the EPA has engaged in sampling
of soil water and air in the area, and has participated in a remedial investigation with
Bank of America, the subsequent owner of the White Swan Cleaners. That investigation
began in August of 2007. By that point, almost 17 years had passed since the first
identification of the problem. The EPA's investigation continues through 2013, or more
than 20 years after the first investigation.

The affected area is an affluent southern Monmouth County suburb, densely
populated with one-family homes. Thus, the adult residents and their children have
remained exposed to this hazard for more than 20 years while the NJDEP and EPA have
been investigating it.

Until the contaminated soil is removed from the White Swan and Sun Cleaners
site, it will continue to leech into the groundwater supply in the area, thus, perpetuating
the problem.

It appears that the purpose of the August 27, 2013 meeting was to sell the local
residents on the choice of alternatives that the EPA evaluated and is recommending.

Contained within that 16-page single spaced document that was handed out on
August 27, 2013 is an analysis of the "Long-Term Effectiveness and Permanence of

McMORAN, O'CONNOR & BRAMLEY

A PROFESSIONAL CORPORATION

-------
Matthew Westgate, Project Manager
September 13,2013
Page 3

the Remedial Alternatives Proposed." lift the first sentence, it states, "The highest
degree of permanence and long-term effectiveness is achieved for those alternatives
that result in (a) the greatest removal of contaminants from the site."

The EPA proposed alternatives for dealing with the soil contaminations are as
follows:

•	Alternative 1 - No Action - Under this, alternative, the EPA would take no
action, allowing the soil to remain on-site and continue the contamination for
current residents and generations to come. Clearly, this alternative (or non-
alternative) is unacceptable.

•	Alternative 2 - In-Situ Soil Vapor Extraction/Air Sparching for Sun
Cleaners and White Swan Source Area Soils. Under this alternative, the
EPA would take 10 years and spent $3.6 million to dig extraction wells and
perform other actions to remove the contaminants in the soil. During the 10-
year period, the contaminants would continue to leech into the soil and
groundwater.

•	Alternative 3 - Evacuation & Disposal of Soils at the Sun Cleaners &
White Swan Cleaners Source Areas. Under this alternative, the
contaminated soil from these two areas would be removed in one-year. This
alternative ends the problem with which the NJDEP, the EPA and the
residents have been dealing with for more than 20 years in a one-year period
at a cost of $8 million.

•	Alternative 4 - In-Situ Soil Vapor Extraction/Air Sparching at the Sun
Cleaners Source Area & Evacuation & Disposal of Soils at the White
Swan Source Area. This alternative is essentially a combination of
alternatives 2 and 3, which would remove and dispose of the White Swan soil
in one year. It would not remove the Sun Cleaners soil but instead have it
treated under Alternative 2 for a 10-year timeframe. The cost of this project is
estimated at $5.4 million.

As holed above, at page 13 of the proposed plan, is a section entitled, "Long-
Term Effectiveness and Permanence." The first sentence under this analysis states,
"The highest degree of permanence and long-term.effectiveness is achieved for those
alternatives that result in the greatest removed of contaminants from the site."

It should be obvious to anyone reading proposed alternative 3 and proposed
alternative 4, that alternative 3 results in the removal of all the contaminants in one-year.
Thus, any continuation of the problem in the future is limited to clearing up the
groundwater. There would be no further pollution. Despite the fact that this alternative
meets the goal of long-term effectiveness and permanence, stated on page 13 of the

McMORAN, O'CONNOR & BRAMLEY

A PROFESSIONAL CORPORATION

-------
Matthew Westgate, Project Manager
September 13,2013
Page 4

analysis, the EPA does not recommend it. Instead, it recommends alternative 4, which
allows the groundwater contamination lo continue for the residents for 10 years.

The difference in cost in these two proposals, according to the EPA, is $2r6
million; a minor number considering the potential negative health effects on the residents,
and on property values for home and business owners.

The only defense that the EPA gave to its selection of Alternative 4 over
Alternative 3 was that it could result in disruption of traffic in the area of the Manasquan
circle during the one-year process involving removal of the soil. That interference is not
enough of an inconvenience to not clear up the problem in one year. Indeed, the safety
and health of the population should be put ahead of any potential short-term traffic
dislocations.

Thank you for your attention.	/

Very,truly y
-------
McMORAN, O'CONNOR & BRAMLEY

A PROFESSIONAL CORPORATION
COUNSELLORS AT LAW

NEW IERSEY OFFICE

NEW YORK OFFICE

RAMSHORN EXECUTIVE CENTRE
BLDG. D, SUITE D-l
2399 HIGHWAY 34
WALL TOWNSHIP, NEW JERSEY 08736

75 ROCKEFELLER PLAZA
16*" FLOOR,
NEW YORK. NEW YORK 10019
(800) 292-6640

(732) 223-7711 FAX: (732) 223-7750

WEB: www.mcmoranlaw.com

REPLY TO:

NEW JERSEY OFFICE

BRUCE P. McMORAN

MEMBER OP NJ. NY, FI. AND DC I1AIIS
bmcmoran@mcmoianlaw.com

September 13,2013

VIA EMAIL & REGULAR MAIL

Edward C. Gurskis, Senior Vice President

David O Johnson, Vice President

Valley National Bank

140 Markham Place

Little Silver, New Jersey 07739

Gentlemen:

I enclose the signed commitment, letter to the Bank regarding our line of credit.

We have greatly enjoyed our relationship with Valley National Bank and look
forward to continuing that relationship.

Thanks for all your help over the past several years and the renewal of our line of

credit.

Very truly yours,

BPM/pl
Enc.

BRUCE P. McMORAN

-------
Lynette

MFO

DSB

-------
U.S. Environmental Protection Agency
290 Broadway, 26lh Floor
New York, NY 10007-1866

FIRST-CLASS MAIl
Postage & Fees

PAID

£RA Permit
No-. G-35	

Frank Cristell

1210 Hemlock Avenue

Sea Girt, New Jersey 08750

EPA INVITES YOU TO THE
White Swan Cleaners/Sun Cleaners Area Groundwater
Contamination Superfund Site
Public Meeting

The U.S. Environmental Protection Agency invites you to attend a public meeting to
discuss its Proposed Plan to address contamination at the White Swan Cleaners/Sun
Cleaners Area Groundwater Contamination Superfund Site within Wall Township,
Manasquan, and Sea Girt, New Jersey. The meeting will be held on: August 27, 2013 at
7:00pm At the Wall Township Municipal Center, Main Meeting Room, 2700 Allaire Road,
Wall, New Jersey 07719.

Representatives from EPA will present ihe Proposed Plan to address contamination at the
Site and will also receive formal comments. The comment period for the Site closes on
September 19, 2013. All written comments should be sent to Matthew Westgate, Project
Manager, U.S. EPA, Region 2. 290 Broadway, 19lh Floor, New York, NY 10007 or via
email to Westgate.Matthew@epa.gov

Copies of the Proposed Plan and the Administrative Record for the Site are available at
the Wall Township Public Library Reference Section located at 2700 Allaire Road, Wall
NJ 07719 (732)449-8444.

For further information, please contact Cecilia Echols, Community Involvement
Coordinator at 212-637-3678 or toll free at 1 -800-346-5009 or visit our website @
http://www.epa.gov/region2/superfund/npl/whiteswan *

-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 2
290 BROADWAY
NEW YORK, NEW YORK 10007

January 10, 2007

Mr. Bruce McMoran
McMoran, O'Connor & Bramley
Ramshorn Office Center
Bldg D, Suite D-l
2399 Highway 43
Manasquan, NJ 08736

He: Indoor Air Sample Results for 1210 Hemlock Ave
Dear Mr. McMoran:

The U.S. Environmental Protection Agency (EPA) collected indoor air samples from the
house at 1210 Hemlock Ave on July 24, 2006. The analytical results are reported below in
micrograms per cubic meter (ug/m3) as follows:

Tetrachloroethylene (PCE): 18.99 ug/m3 for indoor air, 210.25 ug/m3for sub-slab air

Trichloroethylene (TCE): 0.19 ug/m3 for indoor air, 1.07 (non-detect) ug/m3 for sub-slab
air.

The results are well below, but approaching the health based level of concern for PCE in
indoor air. The health-based level is 100 ug/m3 or above for PCE in indoor air and 1,000
ug/m3 or above in the sub-slab soil gas. At that level EPA would install an Indoor Air
Ventilation System to reduce the level of PCE in the house. This health based number has
been modified to also take into consideration the concentration of PCE in the soils beneath
the house. In your clients' case, our decision to continue to monitor the indoor air is based
on the fact that site contamination exists under the sub-slab. I do not have any previous
sample data from 1210 Hemlock Ave, so I cannot determine if the indoor air PCE levels
have increased or decreased in the past few years. As I indicated in the letter to Mr.
Cristell, EPA would like to continue to sample the indoor air in the near future. If you
have any questions concerning this matter, please contact me at (212) 637-4422.

Sincerely,

Matthew Westgate
Project Manager

U.S. Environmental Protection Agency
290 Broadway - 19th floor
New York, N. Y. 10007-1866
e-mail: Westgate.Matthew@epa.gov

-------
Superfund Program
Proposed Plan

U.S. Environmental Protection Agency,
Region 2

White Swan Cleaners/Sun Cleaners Area Groundwater
Contamination Superfund Site
August 2013

-z.

O

. " I " c

-A-

-ZL.

EPA ANNOUNCES PROPOSED PLAN
This Proposed Plan identifies the Preferred Alternative
to address soil and groundwater contamination at the
White Swan/Sun Cleaners Area Groundwater Superfund
Site (Site) located in Wall Township, Sea Gin and
iVIatuisquan, Monmouth County, New Jersey,.and
provides the rationale for this preference. Alternatives
have been developed to address soil and groundwater
contaminated primarily with the dry cleaning chemicals
perchloroelhylene (PCE). and its breakdown products
irichloroethcne( TCE) and cis-l, 2 dicliloruethene (eis-
1.1 DL'li).

("he U.S. Environmental Protection Agency's (EPA's)
preferred alternative to address soil and groundwater
contamination is .Alternative 4 lor soils and Alternative 4
for groundwater. The major elements of the preferred
alternative include:

•	e.ieaviirion and off-Site disposal of soils at the
White Swan Cleaners properly source area;

•	in-situ soil vapor extract ion/air sparging of soils
iihI shallow groundwater at the Sun Cleaners
properiy source area;

•	construction of a groundwater extraction and
ircaiincnr system to capture and treat the most
Jiiuhly contaminated groundwater at the Site;

•	monitored natural attenuation for lesser
contaminated groundwater;

•	I'siublishrneni of a Classification Ki.Nemption
Area to prevent exposure to groundwater during
:he remediation; and

•	indoor uir monitoring of buildings in close
	• • - proxirnity"'tbThe groundwiirepeontahiination"

plume, and installation of vapor mitigation
sy.iiems. as necessary.

This Proposed Plan includes summaries of the cleanup
alternatives evaluated for Site soils and groundwater.
This document is issued by EPA, the lead agency for
Site activities, and the New Jersey Department of
Environmental Protection (NJDEP'l, the support agency.
EPA. in consultation with NJDEP. will select the final
remedy for the soils and groundwater after reviewing
and considering all rnfonnation submitted during a 30-
day public comment period. EPA, in consultation with
NJDEP. may modify the preferred alternative or select

anotner response-action presented in (his Proposed Plan
based on new information or public comments.

Therefore, the public is encouraged to review and
comment on all the alternatives' presented in this
document

$TjA is/issuing this Proposed /Ian as (/art of fts community
relations program under Section 117(a) of the
Comprehensive Environmental Response, Compensation,
and Liability Act (CERCLA, commonly known as
Superfund) and Sections 300.430(0 ;|(1d 300.435(c) of i.hc
National Oil and Hazardous Substances Pollution.
Contingency Plan t'NCP). This Proposed Plan summarizes
information that can be found in greater detail in the
Remedial Investigation (Rl), Baseline Human Health Risk
Assessment, feasibility Study (PS) He-ports and other
documents contained in the Administrative Record for the
Site.

MARK your calendar

PUBLIC COMMENT PERIOD:

August 20, 2013 - September 19, 2013

EPA will accept written comments on the Proposed Plan
during the public comment period.

PUBLIC MEETING: August 27, 2013

EPA will hold a public meeting to explain Ihe Proposed
Plan and all of the alternatives presented in the Feasibility
Study. Oral and written comments will also be accepted at
the meeting. The meeting will be held in the Wall
Township Municipal Center, Main Meeting room. 2700
Allaire Road, Wall. NJ at 7.00 Plyi.

For more information, see the Administrative Record
at the following locations:

U.S. EPA Records Center. Region 2
290 Broadway. 18m Floor.

New York, New York 10007-1866
(212)637-4300

Hours: Monday-Friday - 9 am to 5 p.m., by appointment.

Wall Township Public Library.

Reference Section
2700 Allaire Road
Wall, NJ 07719

Hours: Mon -.10am-9pm, Tues-Thurs - 9 am -9 pm,
Fri -1pm-5pm. Sat - 9am - 5 pm

l

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SITE DESCRIPTION

The White Swan Cleaners/Sun Cleaners Area ¦
Groundwater Contamination. Site is an area of soil and
groundwater contaminated with dry cleaning chemicals
and/or their breakdown products in portions of three
municipalities: Wall Township. Manasquan Borough
and Sea Ciirt Borough, New Jersey. The shallow,
uncoil lined Cohnnsey and Kivkwood aquifer was
contaminated by chemicals released at two former dry
cleaning facilities located approximately 0.2 miles apart
along Route 35. The two dry cleaners released the same
volatile organic contaminant, PCE, onto the soil and in
to the shallow permeable sandy aquifer. The White
Swan source area is located at 1322 Sea Girt Avenue and
the Sun Cleaners source area is located at 2213 Route
35, (aka 21)1 Manasquan Circle) in Wall Township. The
groundwater contaminant plume extends from these two
source areas to the east and is approximately one mile
wide and two miles long. That plume is bordered by
Route 35 on the west: Hannabrand Brook and Wreck
Pond on the north, Judas Creek and Stockton Lake on
the south and the Atlantic Ocean on the east (see Figure
I). The Conner Sun Cleaners building on the west side
of Manasquan Circle was demolished. Che properly is
currently a vacant lot. The Conner White Swan building
was used as a branch office for a local bank and is
currently vacant. After the White Swan cleaning
operation ceased, the White Swan property was used as a
branch office by a national bank, but the property is now
vacant.

SI TE HISTORY

1 he two dry cleaners operated from approximately I960
through I99I. In ihc early I 99(Js. a resident of Magnolia
Avenue notified the Monmouth County Health
Department (MCTID1 that their private irrigation well
contained PCE. Subsequent sampling identified three
irrigation wells containing PCE at levels up to 1,500
parts per billion (ppb). From I*JQ7 to 199N, MC11D
sampled an additional 29 irrigation wells located east of
Route 35. and found extensive PCE contamination up io'
I ..10.0 ppb. Subsequently, approximately 100 irrigation
•.veils were sampled by MCI ID and the NJDEP and
showed up to 1.648 ppb of PCE.

In IW), VICI-ID sampled Hannabrand Brook and Wreck
Pond and found PCE levels ranging from 0.S ppb to 16
ppb, in excess of the NJDEP Surface Water Quality
Standard of 0.34 ppb for PCE in fresh water. PCE was
not detected in surface water to the south in Mac Pond
• and Stockton Lake. In 2002, PCE was detected at 5 ppb
in the surface water of Judas Creek near Route 71.
Subsequent surface water sampling in 2003 showed PCE
at levels up to 99ft ppb in Judas Creek east of Sea Girt
Mall.

PCE was not detected in the Sea Girt Municipal Wells
initially. However, in late 1999, PCE was detected below
the NJ groundwater quality criteria of I ppb at 0.63 ppb in
one of the municipal wells. Sea Girt installed an air
stripper treatment system to remove Volatile Organic
Compounds (VOCs) from the water prior to distribution.

In January 2000, soil samples were collected by NJDEP at
the White Swan property at depths ranging from 3.5 to 6.5
feet below ground surface (bgs). PCE was detected in
samples up to 0.340 parts per million (ppm). Groundwater
samples collected at the time indicated PCE at levels up to
670 ppb, TCE at levels up to 97 ppb and DCE at levels up
to 25 ppb. NJDEP concluded the White Swan property
was a source of groundwater contamination.

In 2001, NJDEP collected soil samples from the Sun
Cleaners property which revealed the presence of PCE at
levels up to 1,900 ppm. Groundwater sampling on the
property showed PCE at levels up to 15.500 ppb. These
data confirmed the Sun Cleaners property as a source of
groundwater contamination.

NJDEP determined that VOCs in the shallow groundwater
might be volatilizing and entering the unsaturated zone
soils. These vapors could also be impacting the indoor air
quality of buildings in the vicinity of soil and groundwater
contamination. NJDEP collected indoor air samples from
approximately 30 locations and found PCE present in
-------
Remedial Investigation

On Septetnber.21, 2006, EPA issued Bank of America
(BOA). a potentially responsible party (PRP) for the
Site, an administrative order on consent which required
BOA to conduct a remedial investigation and feasibility
study. Following review and approval of the planning
documents, the remedial investigation field activities
began in August 2007. The purpose of the investigation
was to determine the nature and extent of contamination
at die Site. After extensive preliminary field screening
investigations, BOA installed over 60 monitoring wells
and piezometers (groundwater sampling sites). They
collected over 500 groundwater samples- using
temporary borings. Soil'and groundwater samples were
collected and analyzed through 2008, 2009 and 2010.
Most of the R1 field work was completed in 2010.
Subsequent to the field operations, the remedial
investigation report, risk assessment, and feasibility
study were drafted. Concurrent with this work. EPA
performed extensive vapor investigations in and under
structures in proximity to the groundwater contaminant
plume.

SITK CHARACTERISTICS

I'he Silt: is located within the New Jersey Coastal Plain.
In general, the topography of the area is fiat. The
majority of the Site contains mixed residential housing
and smaJI commercial buildings. There-are farms and
woodlands to the west and the Atlantic Ocean coast on
ihe east.

I'he Site area is underlain by the Cuhanscy and
K'irkwnod Formations which consist of unconsolidated,
ittierhedded sand, silt and clay layers gently dipping
towards the east. The ground surface is mostly medium
grained sand which allows surface water to percolate
down and ilow to the east. Approximately 75 feet bgs is
a luw permeability layer which keeps the groundwater
contamination from going deeper. The top of the water
table, or saturated <:one. is about 12 to 15 feet bgs. The
regional groundwater. Ilow. across.the..Site-is-generally
east towards the ocean, but some of the shallow
contaminated groundwater flows northeast into
Hannabrand Brook and Wreck Pond. Tothesourh,

-utile shallow contaminated groundwater (lows southeast
into Judas Creek and Stockton Lake.

I'he White Swan facility is located 44 to 47 feet above
mean sea level (tnsl) and the ground surface slopes to the
east. Hannabrand Brook is located approximately 1.500
feet northeast of the White Swan source, area and flows
eastward into Wreck Pond and the Atlantic Ocean. The
Sun Cleaners property is located approximately 1,200
feet to the .southwest of the White Swan property at an
elevation of 46 to 51 feet above msl. Surface water

from the west of the Sun Cleaners property flows east into
an intermittent stream called Judas Creek, then into Mac-
Pond and eventually to Stockton Lake and finally, the
ocean.

"flie contaminants of concern (CoCs) at the Site include
PCE and its associated breakdown products. TCE and eis-
1.2-DCE. PCE, ICE and DCE contamination from both
source areas is dissolved in groundwater. The
contaminated groundwater from the separate sources
flows east and meets near Old Mill Road between
Magnolia Ave and Sea Girt Ave. The combined
groundwater contamination-continues to migrate east,
northeast and southeast towards the Atlantic Ocean. The
northern boundary of the contaminant plume is
Hannabrand Brook and Wreck Pond, file southern
boundary is Judas Creek. Mac Pond and Stockton Lake.
Hie extent of the contaminant plume is approximately one
mile wide (north to south) and two miles long (west- to
cast) (see Figure l).-

The groundwater contaminant plume is underlying an area
of dense residential and commercial development, I'he
towns impacted by the Site's groundwater plume provide
residents with u public water supply system. Pre-existing
wells within the area of the Site's groundwater
contaminant plume are used for non-potable purposes,
mainly irrigation.

The nearest municipal wells to the source areas are
operated by Sea Girt, and are located about ft.000 feet east
tdowngradient) of the Site's source areas. The wells draw
water from depths of 123 feet, 120 feel and 715 l'cet below
the ground surface. I'he Ikirough of Sea liirt installed an
air stripper after detecting I'C'fi ;n 0.63 pph t below the NJ
(.iroundwarerOualitv Standard) in I'W. frequent
sampling is performed to assure that all drinking water
standards are met.

White Swan Soils

In 2001. the PRP excavated the septic tank, associated
piping and associated contaminated soil from the White
.. Swan property parking lot. Approximately 20 tons nf soil
wore excavated and transported olT-Site to a licensed
facility for disposal. However; significant soil
contamination remains arthe property, to a depth of 25
feet bgs, which is 10 feet below tlie water table. During
the R.I, in 2008, a total of 52 samples were collected from
1.3 borings. In 2009. 16 additional subsurface soil samples
were collected from 10 additional borings. Soil samples
from the unsaturated zone below the asphalt pavement at
the White Swan property showed PCE contamination at
levels ranging from I ppm to a maximum of 160 ppm at u
depth of 0-7 feet bgs, aiid up to a maximum of 2K.000
ppm at 17 -25 feet bgs Ibelow the water table). PCT: mass
in the soil at the White Swan property is estimated to be
approximately 4.360 pounds. Maximum fCE and cis-l.

-------
2, DCE levels on the property are 32 ppm and 37 ppm
respectively.

Sun Cleaners Soils

At the Sun Cleaners property, a total of 48 subsurface
soil samples from 13 soil borings were collected in 2008.
I'CE contamination in the unsaturated zone soils at the
Sun Cleaners property was found to be as high as 51
ppm (at a depth of 6 to 13 feet bgs) with a total PCE soil
mass of approximately 140 pounds. 1'he maximum ICE
level was 3.8 ppm and the maximum cis-1,2, DCE level
was 31 ppm.

Surface Water and Sediments
NJDEP surface water samples from 2003 showed levels
of PCE at y% ppb in Judas Creek east of the Foodtown
Mall near Sea Girt Ave. These levels were above the NJ'
surface water quality standard of 0.34 ppb in fresh water.
In 2008, RI surface water samples collected 500 feet
downgradient showed significantly lower levels of PCE
at 31 ppb, 13 ppb. A.3 ppb. 4.1 ppb, 12 ppb and 13 ppb
between Mac Pond and Stockton Luke.

Judas Creek sediment samples showed PCE.at 4.4 ppm.
near Manasquan I ligh School and 0.7l> ppm and 0.81
ppm near Route 71. These are above the site specific
NJDHP ecological screening criteria of .45 ppm lor
sediments.

In 2000. in I lannabrand Brook, NJDEP found PCE at 1
ppb in surface water near St. Catharine's Cemetery and 2
ppb in Wreck Pond. During the HI., PCE was found at
I. I ppb in ihe unnamed tributary surface water that feeds
into Mannabrand Brook and up to 5» ppb in the surface
water of Hannabrand Brook itself. Wreck Pond surface
water showed PCE levels up to 0.25 ppb (estimated) at
the Route 71 I3ridge.

PCE was found at 0.21 ppm in the Hannabrand Brook
>v.-diments near St. Catharine's Cemetery. Sediments in
the unnamed tributary had PCE levels as high as 1.8
pptn and 4.1 ppm (estimated) in Hannabrand Brook.

(i round water

I'he Site's groundwater plume is contaminated with PCE
at levels ranging from 1 ppb to 75.000 ppb, and
continues to migrate from the two source areas located
near Route 35 eastward to the Atlantic Ocean,
approximately 2 miles away. The plume extends from
the water table at the source areas to a depth of
approximately 70 feet bgs, where a low permeability
layer extends across much of the site. The
contamination does not extend to the north of
Hannabrand Brook or Wreck Pond, and generally not
south of Judas Creek and Stockton Lake.

at the White Swan properry and 61,000 ppb at the Sun
Cleaners property.

There are two areas of the plume, in close proximity and
downgradient of the two source areas which generally
contain the highest levels of groundwater contamination.
These two areas are referred to as the Near Field areas and
generally contain concentrations of PCE over 1,000 ppb.
The Near Field areas include groundwater underlying the
Sun Cleaners property and extending over 1,000 feet
downgradient, and groundwater underlying the White
Swan property and extending approximately 700 feet
downgradient. The remainder of the groundwater plume is
referred to as the Far Field. The Far Field area of
groundwater contamination generally includes areas
where PCE has been detected between the levels of I ppb
and 1,000 ppb. However, within the large Far Field area,
there are a number of "hot spots," which are smaller
localized areas of PCE contamination thai range from 500
ppb up to 3.100 ppb. The PCE contamination within the
youndwater.generally sinks deeper as it proceeds to the
cast, but was not found below the low permeability zone
around 75 feet bgs.

Indoor Air

In the vicinity of the shallow groundwater contamination,
VOCs may escape or volatilize from the groundwater and.
permeate the unsaturated zone soils. This vapor can
penetrate basement walls and lloors in occupied
dwellings. EPA has sampled the sub-slab air and/or
indoornir of over 400 residences and commercial
buildings in order to evaluate this exposure pathway and
will continue to sample buildings in the vicinity of the
contamination to assess the potential risk io occupants.
The highest level of PCE vapor in sub-slab air was found
to he yjOO ug/inJ below a residence near Christie Lane
and Sea Girt Ave. To date, thirty-four indoor air
ventilation systems have been installed by EPA in
buildings where indoor air PCE levels exceeded health
based levels. The systems are designed to vent vapors
from beneath the foundation, thereby preventing vapors
from entering the building. These systems are monitored
!0 ensure-thev are performing properly-.- Sampling of
residences and buildings overlying ihe groundwater plume
will continue. Additional indoor air ventilation systems
will be installed, as needed, to prevent unacceptable risks
to occupants of buildings.

During the Rl. PCE was found as high as 75.000 ppb

4

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WHAT IS A "PRINCIPAL THREAT"?

The NCP establishes an expectation that EPA will use
treatment to address the principal threats posed by a site
wherever practicable (NCP Section 300.430(a) (I) (iii)
(A)). Hie "principal threat" concept is applied to the
characterization of "source materials" at a Superfund
site. A source material is material that includes or
contains hazardous substances, pollutants or
contaminants that act as a reservoir for migration of
contamination to ground water, surface water or air. or
acts as a source for direct exposure. Contaminated
ground water generally is not considered to be a source
material; however, Non-Aqueous Phase Liquids
(NAPl.s) in ground water may be viewed as source
material. Principal threai wastes are those source
materials considered to be highly toxic or highly mobile
that generally cannot be reliably contained, or would
priisent a significant risk to human health or the
environment should exposure occur. The decision to
treat these wastes is made on a site-specific basis
through a detailed analysis of the alternatives using (he
nine remedy selection criteria This analysis provides a
basis for making a statutory finding that the remedy
employs treatment as a principal element.

PRINCIPAL THREATS

litis Proposed Plan addresses .soil contamination at both
PCR source areas ideniilied at the Site. These soils are
considered principal threat wastes. Addressing these
contaminated soils will have a positive impact on the
planned groundwater remediation, as Ihev are an
(ingoing source of groundwater Contamination at the
Silo.

SCOPE AND HOLE OK THE ACTION

l:PA is addressing the cleanup of this Site through one
phase, or operable unit, of long-term cleanup, addressing
•lie source area soils, sediment, groundwater
..contamination,.and indoor air cotuaminaiion_

RISK SUMMARY

I'he purpose of the risk assessment is to identify
potential cancer risks and noncancer health hazards at
the site assuming that no further remedial action is taken.
A baseline human health risk assessment was performed
to evaluate current and future cancer risks and noncancer
health hazards based on the results of the remedial
investigation.

A screening-level ecological risk assessment was also
conducted to assess the risk, posed to ecological
receptors due to site-related contamination.

Human Health Risk Assessment

As part of the R.I/FS. a baseline human health risk
assessment was conducted ro estimate the risks and
hazards associated with the current and future effects of
contaminants on human health and the environment. A
baseline human health risk assessment is an analysis of the
potential adverse human health effects caused by
hazardous-substance exposure in the absence of any
actions to control or mitigate these under current and
future land uses.

A four-step human health risk assessment process was
used for assessing site-related cancer risks and noncancer
health hazards. 'I'he four-step process is comprised of:
Hazard Identification of Chemicals of Potential Concern
(COI'C's), Exposure Assessment. Toxicity Assessment,
and Risk Characterization (see adjoining box "What is
Risk and How is it Calculated").

I'he. baseline human health risk assessment began with
selecting CO PCs in the various media (i.e., soil,
groundwater, surface water, and sediment) that could
potentially cause adverse health effects in exposed
populations. I'he current mtd future land use scenarios
included the following exposure pathways and
populations:

» Construction Worker: current/future ingestion, dermal
contact and inhalation of surface and subsurface soil
and future inhalation of outdoor and indoor vapors for
.id ultS

¦» Utility Workers: current/Tut lire ingestion, dermal
contact and inhalation of surface and subsurface soil
for adults

•	Residents: current/future ingestion and dermal contact
of surface soil.'current ingestion, dermal contact and
inhalation of groundwater from lawn watering and
swimming pools, current inhalation of air from
outdoor and indoor vapors, and future ingestion,
dermal contact and inhalation of groundwater for
adults and children

•	Transient Visitors: current/future ingestion and dermal
contact of surface soil, current/future ingestion,
dermal contact and inhalation of surface water and
sediment from Wreck Pond,, Hannabrand Brook and
Judas Creek, which includes Mac Pond and Stockton
Lake, and current future consumption offish and
crabs from Wreck Pond for adults, teens (age 12-17).
older children (age 7-11) and children (age 0r6)

•	Commercial Customers: current inhalation of air from
outdoor and indoor vapors for adults, adolescents and
children

-------
• Commercial Workers: current inhalation of air from
outdoor and indoor vapors tor adults

In this assessment, exposure point concentrations were
estimated using .either the maximum detected ¦
concentration of a contaminant or the 95% upper-
confidence limit (UCL) of theaverage concentration.
Chronic daily intakes were calculated based on the
reasonable maximum exposure (RME). which is the
highest exposure reasonably anticipated to occur at the
site. The RME is intended to estimate.a conservative
exposure scenario that is still within the range ot'
possible exposures. Central tendency exposure (CTE1
assumptions, which represent typical average exposures,
were also developed. A complete summary of all
exposure scenarios can be found in the baseline human
health risk assessment.

Surface Soil

Risks and hazards were evaluated for current and future
exposure to surface soil at both source areas. The
populations of interest included adult construction and
utility workers. The cancer risks lor both receptor
populations evaluated were within or below the
acceptable EPA risk range of 1 .UE-06 to I .UE-04. The
hazard index for construction svorkers and utility
workers were below the EPA acceptable value of I.
There' were no contaminants of concern (COCs)
identified, for soil (Table I).

Table I. Summary of hazards and risks associated with
surface soil.

ileeepior

1 la/ard
Index

Cancer Risk

i (.uiiMi UL-tion Worker - Adult

(1.17

I F-U6

! 1-'lilitv Worker - Adult

0.17

JI.--D5

! 1 here were no COCs identified in the surface soil.

Subsurface Soil

Risks and hazards were evaluated for the potential
current and future exposure to subsurface soil. The
population of interest included adult construction and
utility workers: The subsurface soil, identified as 2-10
:'cet below ground surface, was evaluated for
construction workers and the cancer risk and non-cancer
hazards were wilhin or below EPA criteria.

Both the cancer risk and hazard indices were below or
within the EPA' acceptable values and ranges. There
were no COCs identified in the subsurface soil (Table 2).

Table 2. Summary of hazards and risks associated with
subsurface soil.

Receptor

Hazard
Index

Cancer Risk

CuiiAtrueiion Worker - Adult

0.16

3F.-05

Receptor

Hazard
Index

Cancer Risk

Utility Worker - Adult

0.16

2E-06

There were no COCs identified in the subsurface soil.

Groundwater

Risks and hazards were evaluated for current and future
exposure to groundwater from irrigation wells and private
wells. The populations of interest included adult and child
residents. Hie cancer risk for the use of the irrigation
wells for both the adult and child residents were within the
acceptable EPA risk range of 1.0E-06 to 1 .OE-04. The
hazard indexes for use of the irrigation wells for both adult
and child resident were below the EPA acceptable value
of 1. The cancer risks and hazard indices for future use of
the groundwater for drinking, exceed the acceptable EPA.
risk ranges and hazard value for both the adult and the
child. The COCs that were identified for groundwater
include four VOCs {Table 3).

Table 3. Summary of hazards and risks associated with
groundwater.

Receptor

Hazard
Index

Cancer Risk

Irrigation Wells - Adult

0.13

1E-U4

Irrigation Wells - Child

0.51

IE-04

Swimming Pools - Adult

0.14

IE-04

Swimming Pools - Child

0.17

3E-()5

Tap Water {Shallow) - Adult

30

4E-02

Tap Water (Shallow) - Child

S7

7E-02

Tap Water 1 Deep) - Adult

7.5

1E-U4

Tap Water (Deep) - Child

18

7F-05

COCs include: icirachloreihylene 1PCIi),
irichlorooihylene (TCE), cis-L2-dich.loro».-ihylene. and
vinvl chloride

Surface Water and Sediment

Risks and hazards were evaluated for current and future
exposure to surface water and sediment from Wreck Pond,
i lannabrand !3ruok. and Judas Creek, which includes Mac
Pond and Stockton Lake. The populations of interest- •
included adult, teen, older child, and child transient
visitors lor Wreck Pond arid teen and older child transient
visitors for Hannabrand Brook and Judas Creek. The
cancer risks and hazard indices for all of the populations
evaluated were below or within the EPA acceptable
values. There were no COCs identified for surface water
or sediment {Table 4). Since there were no COCs
identified for surface water or sediment, the ingestion of
biota from Wreck Pond was considered to be an
incomplete pathway.

Table 4. Summary of hazards and risks associated .with ¦
surface water and sediment.

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Receptor

Hazard Index

Cancer
Risk

Surface 1 (¦'aier - Wreck Pond

Transient Visitor - Adult

0.0024

5E-08

Transient Visitor - Teen

0.01

5E-08

Transient Visitor - Older
Child

0.022

1E-07 j

|

Transient Visitor - Child

0.0050

3E-08

Surface IVuter - Haiimhrund Brook

Transient Visitor-Teen

0.022

2E-07

Transient Visitor - Older
Child

0.040

2F.-07

Surface 1 Voter - Jiuhis Creek

Transient Visitor - Teen

0.018

3E-05

Transient Visitor - Older
Child

0.035

4E-05

Sediment - ll'rcc.k Pond

Transient Visitor - Adult

0.00031

5E-08

i Transient Visitor - Teen

0.0016

<)E-08

Transient Visitor - Older
Child

0.0017

5E-0S

Transient Visitor - Child

11.00072

3E-UX

Sediment - !lunnuhntnd lirook

1 Transient Visitor--'Teen

0.0056

2E-06

Transient Visitor - Older
Child

0.012

i

21-1-06

1 Sediment - Huiinuhraiiit tirunk

Transient Visitor - 'Teen

U.O078

2E-06

Transient Visitor - Older
Child

0.0082

2E-06

j There were no COC's identified in the surface water or
i sediment.

I'll pors

f lie potential Kor vapor intrusion into a building's indoor
air is being addressed through ail onguing EPA sampling
program. I'hc investigation includes collection and
analysis of sub-slab soil gas samples, and indoor air
samples in structures overlying the groundwater
contaminant plume. Levels of contaminants are
compared to health-based standards for each structure.
Where health-based standards are exceeded*- vapor
mitigation systems have been installed. Sampling is
ongoing throughout the area overlying the plume, and
additional indoor air ventilation systems will be
installed, as needed, to prevent unacceptable risk to
occupants of buildings. Ilierefore, a quantitative risk
,ma lysis was not needed.

The evaluation of potential outdoor vapor exposure to
residents, commercial customers, commercial workers
mid construction workers indicated that the pathway was
incomplete. Therefore, a quantitative analysis was not
needed.

It is !'• HA's current judgment that although the risks

associated with soil exposure are within or below CPA's
acceptable values, rhe soil concentrations of PCE and TCE
are above concentrations that are associated with an
adverse impact to groundwater, thus there is a need to
address the soil through a remedial action.

Based on the results of the human health risk assessment,
a remedial action is necessary to protect human health
from actual or threatened releases of hazardous substances
in groundwater.

Ecological Risk Assessment
A screening-level ecological risk assessment \v;ts
conducted to evaluate the potential for ecological risks
from the presence of elevated VOCs in ground water that
discharges to surface water and sediments associated with
the Judas Creek and Hannabrand Brook stream systems.
1'lie SLERA focused on evaluating the potential for
impacts to sensitive ecological receptors to site-related
constituents of concern through exposure to surface water
and sediment from Wreck Pond, Hannabrand Brook, and
Judas Creek.-which includes Mae Pond and Stockton
Lake. Surface water and sediment concentrations were
compared to ecological screening values as an indicator of
the potential for adverse effects to ecological receptors, for
each water body system. A complete summary of all
exposure scenarios can be found in the screening level
ecological risk assessment (St.ERA).

llannuhrund Untok System: There is a potential for
adverse elTecrs to llsh and aquatic invertebrates from
exposure to contaminated groundwater that is discharging
to Hannabrand Hrodk. The sediment screening criteria
Mere exceeded for PCE in three locations, resulting in
hazard indices tills) of 4.1, I .S and 0.7. rwo of which are
above the acceptable value of I. The 1'CII detections in
the sediment are considered to be site-related. The surface
water screening criteria was not exceeded for 1 lannabrand
Brook.

Judas Creek System: There is a potential for adverse
effects to aquatic lish and invertebrates from exposure to
contaminated groundwater thnfmay be discharging to
Judas Creek. The sediment screening criteria were
exceeded for PCE in two locations, resulting in His of 4.4
and 1.8, which are above the acceptable value of I. Hie
PCE detections in the sediment may be associated with
runoff from an industrial area instead of groundwater
discharge. The surface water screening criteria was nor
exceeded for Judas Creek.

Based on the results of the ecological risk assessment, a
remedial action is necessary to protect the environment
from actual or threatened releases of hazardous
substances, which includes the discharge of contaminated
groundwater into surface water bodies at the Site.

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WHAT IS RISK AND HOW IS IT
CALCULATED?

A Superfund baseline human health risk assessment Is an
analysis of the potential adverse health effects caused by
hazardous substance releases from a site in the-absence of
any actions to control or mitigate these under current- and
future-land uses. A four-step process is utilized for assessing
site-related human health risks for reasonable maximum
exposure scenarios.

Hazard Identification: In this step, the contaminants of
concern at the site in various media (i.e., soil, groundwater,
surface water, and air) are identified based on such factors
as toxicity, frequency of occurrence, and fate and transport
of the contaminants in the environment, concentrations of the'
contaminants in specific media, mobility, persistence, and
bioaccumulation.

Exposure Assessment: In this step, the different exposure
pathways through which people might be exposed to (he
contaminants identified in the previous step are evaluated.
Examples of exposure pathways include incidental ingestion
of and dermal contact with contaminated soil. Factors
relating to the exposure assessment include, but are not
limited to, the concentrations that people might be exposed
to and the potential frequency and duration of exposure.
Using these factors, a "reasonable maximum exposure"
scenario, which portrays the highest level of human
exposure that could reasonably be expected to occur, is
calculated.

Toxicity Assessment: In this step, the types of adverse health
effects associated with chemical exposures, and the
relationship between magnitude of exposure (dose) and
severity of adverse effects (response) are determined.
Potential health effects are chemical-specific and may
include the risk of developing cancer over a lifetime or other
non-cancer health effects, such as changes in the normal
functions of organs within the body (e.g., changes in the
•ilfectiveness of the immune system). Some chemicals are
".aoable of causing boih cancer and noncancer health
effects.

Risk Characterization: This step summarizes and combines
exposure information and toxicity assessments to provide a
quantitative assessment of site risks. Exposures are
evaluated based on the potential risk of developing cancer
and the potential for noncancer health hazards. The
likelihood of an individual developing' cancer is expresses! _as_
. a probability. For example, a 10 cancer risk means a
'one-in-ten-thousand excess cancer risk"; or one additional
cancer may be seen in a population of 10.000 people as a
result of exposure to site contaminants under the conditions
explained in the Exposure Assessment. Current Superfund
guidelines for acceptable exposures are an individual lifetime
excess cancer risk in the range of 10"* to 10"8 (corresponding
to a one-m-ten-thousand to a ona-in-a-million excess cancer
risk), for noncancer health effects, a "hazard index" (HI) is
calculated. An HI represents the sum of the individual
exposure levels compared to their corresponding reference
doses. The key concept for a noncancer HI is that a
"threshold level" (measured as an HI of less than 1) exists
below which noncancer health effects are not expected to
occur.

REMEDIAL ACTION OBJECTIVES

Remedial action objectives (RAOs) were developed for
soils and groundwater to address the human health risks
and environmental concerns posed by Site-related
contamination.

RAOs:

•	Prevent or minimize current and liiture human
exposures, including ingestion of groundwater
and/or inhalation of vapors, from Site-related
VOCs in groundwater that present a risk to public
health and the environment;

•	Prevent or minimize migration of Site-related soil
contamination to groundwater;

•	Restoration of the Site groundwater to meet
drinking water standards within a reasonable time
frame; and

•	Prevent or minimize the migration of Site-related
contaminated groundwater to surface water and
sediment that presents a risk to the environment.

To achieve RAOs, cleanup goals for soils at the Site were
developed. Soil cleanup standards that will be protective
of groundwater were developed by using the SESOIL
model. The cleanup goal calculated through the model is
I ppm for PCE in soils. It is believed that remediation of
Site soils to this standard will address all Site-related
contaminants.

The remediation goals selected, for the groundwater are
hased on groundwater applicable or relevant and
-.ippropriate requirements (ARARs) for this Site, which
include the federal and state .VICUs, and NJDF.P
Groundwater Quality Criteria (.GWQC). The Site
groundwater remediation goals are the most conservative
of the above criteria. The remediation goals selected for
. ihe.primary.cuntairunancs.ot'concerns at this-Site- are-1- ppb- ¦
lor PCE and I ppb for TCE. which are the state GWQC.

summary of remedial alternatives

Potential applicable technologies were identified in the FS
prepared for this Site. These technologies were initially
screened based on effectiveness, implementability and
cost as criteria. Those technologies that passed initial
screening were ;hen assembled into four remedial
alternatives for soil and four remedial alternatives for
groundwater.

All of the alternatives, with the exception of the No
Action alternative, would include the ongoing

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investigation and remediation, as appropriate, of indoor
air containing elevnred levels of VOCs in structures
overlying the groundwater contaminant plume.

Sampling ot' indoor and sub-slab air would continue.
Individual vapor mitigation systems would be installed
at ouch structure determined to have elevated levels of
VOCs in indoor air. and systems installed previous to the
remedy selection would be maintained.

In the process of developing groundwater remedial
alternatives for the Site, a number of groundwater
extraction and treatment scenarios that would address
varying portions of groundwater contamination in the
Fur Field area were evaluated, but screened out.
Hx tensive extraction and treatment of groundwater
throughout the Far Field area, was shown through
modeling as not likely to he highly effective. Extraction
of groundwater throughout the Far Field area would be
highly disruptive ,io the community, expensive and
would not significantly decrease the overall cleanup time
1'rame compared to the alternatives that were developed
which rely on active treatment in the Near Field areas
and allow Far Field contamination to attenuate.

All of the groundwater remedial alternatives, with the
exception of the No Action Alternative, would include
ihc establishment of a Classification Exception Area
(C'lriA) in accordance with state regulations to minimize
the potential exposure to contaminated groundwater until
the groundwater meets the remediation goals. However,
consistent with expectations set out in Supertund
regulations, none of ihe alternatives rely exclusively 011
institutional controls to achieve protect)vencss.

All of the groundwater remedial alternatives, with the
exception of the No .Action Alternative, would rely in
part on monitored natural attenuation I.VINA) to restore
the lesser contaminated portions of the groundwater
contaminant plume ro drinking water srandards. With
the performance of an active remediation of the most
viiiiiuminuicd (groundwater in the Near Field, modeling
, has .shown thai Far Field uroundwater-would he-restored
to drinking water standards in a much shorter time frame
than, without remediation I roughly 70 years vs. 400
years). I'he implementation of .VINA requires long-term
monitoring of contaminants as they naturally attenuate
through dilution, dispersion, adsorption, volatilization
and/or biudegradation, until groundwater returns
naturally to concentratiuns below rhe remediation goals.
These processes are expected to be effective at this Site
in ureas of lesser groundwater contamination in
conjunction with active treatment in the areas of higher
contamination. In the Far Field area, due ro the aerobic
nature of the Site aquifer, dispersion and dilution are
likely to be the predominant forms of natural
attenuation. In addition, since 2000. decreasing

contamination concentrations have been observed near the
source areas. EPA believes this dilution trend will
continue, in this Very prolific, unconfined aquifer, in which
groundwater migrates at approximately one foot per day.
Based on preliminary modeling, it is expected that, in
conjunction with active treatment in the Near Field areas,
the estimated natural attenuation time frame in the Far
Field areas is approximately 50 to 70 years. The MNA
portion of each groundwater alternative listed beknv (with
the exception of the No Action alternative), would include
the installation and sampling of an estimated nine clusters
of monitoring wells, in addition to surface water and
sediment samplingin the water bodies bounding the Site's
groundwater plume. The exact sampling frequency and
protocol would be established during the remedial design
(RD) phase of the cleanup.

For ihe groundwater alternatives, tiPA chose 10 actively
address groundwater above 1,000 ppb of PCE bused on
modeling which showed active treatment of areas of lower
concentrations (100, 150, 200 and 250 ppb) would not
appreciably speed up the groundwater cleanup time.

I'he lime frames presented below for construction do not
include the time necessary for pre-design investigations,
remedial design, oreontruet procurements. Each of the
groundwater alternatives will take longer than five years
to achieve remediation goals. Therefore, a five-year
review will be conducted every live years after the
initiation of the remedial action, until remediation goals
are achieved.

Consistent with EPA Region 2's (.'lean and Green policy,
l-.FA will evaluate the use of sustainable technologies and
practices with respect to any remedial alternatives selected
for this Site.

A brief summary of rhe remedial alternatives developed
Ibr ihe Site is provided below. More detailed descriptions
of the remedial alternatives can be found in the FS report.

Alternatives for Soil .Source Areas

Alternative I - No Action

The No Action Alternative was retained, as required by
the National Contingency Plan (NCP), and provides u
baseline for comparison with other alternatives. No
remedial actions would be implemented as part of the No
Action Alternative. Furthermore, this alternative would-
not involve any monitoring of'groundwater or institutional
controls. Contaminants in the soil would continue to
migrate into the groundwater, and VOC contamination
would continue to migrate with groundwater
downgradient. In addition, vapor phase contamination
would continue to migrate into the indoor air of some
.structures overlying the plume.

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Total Capital Cost	SO

Operation and Maintenance	SO

Total Present Net Worth	SO

Timeframe	N/A

Alternative 2 - In-Situ Soil Vapor Extraction/Air
Sparging tor Sun Cleaners and White Swan Source
Area Soils

Alternative 2 includes the in-situ vapor extraction
(ISVEJ and air sparging (AS) of soil and shallow "round
water in the two soil source areas. This alternative
would involve the injection of air into the subsurface
groundwater, enabling a phase transfer of VQCs from a
dissolved state to the vapor phase. The contaminated air
enters the unsaturated, contaminated soils, where a SVE
system creates a negative pressure through a series of
extraction wells. The extraction wells are used to collect
the contaminated air, which is then treated to remove
contaminants through the use of catalytic oxidizers or
granular activated carbon (GAC). 130A has proposed
ihat this alternative include the use of a series of
recirculating groundwater remediation wells (RCRWs),
which would apply the same principals as explained
above, but would provide for both air sparging and ISVE
to be implemented within well casings of a series of
wells. Specific details of the implementation of this
technology would be determined during ihe IID phase.

Active operation of the ISVE/AS system may be
intermittent over the estimated 10 year time frame to
.icnieve goals.

fmal Capital Cost	SI ..S million

i Operation & Maintenance SI .X million
Total Present Net Worth	S3.6 million

l ime frame	10 years

Alternative J -Excavation and Disposal of Soils at the
Sun Cleaners and White Swan Source Areas

— Alternative J would-include excavation-^ removal, and-.
•.)ff-site treatment and/or disposal of all soil containing
more than 1 ppm of PCE from the White Swan and Sun
Cleaners source areas. There are approximately 5.100
cubic yards of soils exceeding the cleanup criteria at the
White Swan property and approximately 9,600 cubic
yards at the Sun Cleaners property. Treatment or
disposal would occur at RCRA-permitied Facilities in
accordance with regulatory requirements for these soils.
Excavation would be accomplished with commonly used
construction equipment, by methods widely used for
impacted soils in cases where the soil contamination is
relatively shallow. less than 25 feet below ground
surface. Sheet piling and de-watering would be required
js excavation would go below the water table to

maximize mass reduction. The contaminated groundwater
generated during soil excavation would be collected and
properly treated. Traffic controls would be required
because of the close proximity to the Manasquan Traffic
Circle and Sea Gin Avenue. This alternative would be
completed in approximately one year. Demolition and
disposal of the White Swan Bank building may be
required to facilitate the excavation.

Total Capital Cost	S8 million

Operation and Maintenance	SO

Total Present Net Worrh	SS million

Time frame	1 year

Alternative 4 - In-Situ Soil Vapor Extraction/Air
Sparging at the Sun Cleaners Source Area and
Excavation and Disposal of Soils at the White Swan
Source Area

Alternative 4 includes ISVE/AS of soil and shallow
groundwater in the Sun Cleaners source area (as described
in Alternative 2) and excavation and off-sile disposal of
contaminated soils at the White Swan source area (as
described in Alternative 3). ISVE/AS would be preferred
at the Sun Cleaners source urea as there is relatively low
estimated l'CE mass as compared to the White Swan
source area. Excavation and off-Site disposal would be-
more appropriate at the White Swan source area because it
contains a much higher mass of l'CE contamination at a
relatively shallow depth (less than 25 lect) compared to
the Sun Cleaners source area. In addition, based on its
topography and location, excavation would be much easier
to implement at the White Swan source area compared to
the Sun Cleaners source area. ISVE/AS is expected to be
a slower process for removal of PCE compared to
excavation due to mass transfer limitations. Significant
mass removal by ISVE/AS could be expected at the Sun
Cleaners source area over a period of roughly 10 years,
and systems would be operated periodically until soil is
remediated. Soil excavation at White Swun would take
less than one year. Demolition and disposal of the White
Swan iiank building may be required to facilitate the
excavation.- -

Total Capital Cost
Operation and Maintenance
Total Present Net Worth
Time frame

54.5 million
S.9. million
S5.4 million
10 years (Sun)

1 year i White Swan)

Alternatives for Groundwater
Alternative I - .No Action

The No Aotion Alternative was retained, as required by
the NCP. and provides a baseline for comparison with
other alternatives. Under this alternative, no remedial

10

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actions would be implemented. Furthermore, this
alternative would not involve any monitoring of
groundwater or institutional'controls. Contaminants in
the groundwater would continue to migrate uncontrolled.

Total Capital Cost	SO

Operation and Maintenance	SO

Total Present Net Worth	SO

Time frame	N/.A

Alternative 2 -In-Situ Vapor Extraction and Air
Sparging/MNA/ICs/Vapor Remediation

This alternative would treat contaminated groundwater
in-situ in the Near Field areas, which generally contain
PCE levels of greater than 1.000 ppb, through the use of
the ISV'E'AS technologies. ISVH/AS in the Near Field
areas ofhighest groundwater contamination would
involve the injection of air into the subsurface
groundwater, enabling a phase transfer of VOCs from a
dissolved state to the vapor phase. 1'he contaminated air
enters.the unsaturated soils, where a SVE system creates
a negative pressure through a series of extraction wells.
The extraction wells are used to collect the contaminated
air. which is then treated to remove contaminants
through the use of catalytic oxidizers or GAC. BOA has
proposed that this alternative be implemented through
the use of a series of RGRAVs. which would apply the
-nine principals as explained above, hut would provide
fur both air sparging and ISVF. to he implemented within
•a ell casings of a series of wells. Specific details of the
implementation of this technology would be determined
• luring the RD phase of the project.

During ihe.RD, an evaluation of individual Far Field
•hot spots" for treatment through the ISVE/AS
technology would be performed to assess the
•jiTecti veness of treatment.

would be installed and maintained. In addition, systems
already insralled at the Site would be maintained until (he
groundwater is remediated.

Total Capital Cost
Operation and Maintenance
Total Present Net Worth
Time frame (ISVE/AS)

Full Groundwater Restoration

S5.4 million
$5.4 million
SI0.8 million
10 years

Approx. 70 years

Alternative 3 - In-Situ Chemical Oxidation
(ISCO)/MNA/ICs/Vapor Remediation

I SCO would involve injecting an oxidant or oxidant
releasing compound into wells located within the most
highly contaminated groundwater, generally containing
l5CE at levels of greater than 1.000 ppb in the Near Field
arcus. The" oxidant would mix with the contaminants, and'
cause thein to decompose. When the-process is complete,.
only water and innocuous breakdown products would be
left in the treated area. Monitoring would be required to
determine the effectiveness of the treatment.

Although final details of the implementation of this
alternative would be developed in the RD phase, for
costing purposes, it was assumed that sodium
permanganate would be the oxidant of choice. Lines of
injection well clusters would be installed perpendicular to
groundwater How. I'iach cluster would be comprised of
three wells installed to different depths- It is estimated
that the implementation of this alternative would require
the installation of approximately 40 injection well clusters
near and downgradient of the Sun Cleaners source area
and 19 injection well clusters near and downgradicnt of
the White Swan source area.

During the RD. an evaluation of individual Far Field "hot
spots" for treat in em through the ISL'O technology would
be performed to assess the effectiveness of treatment.

VINA would be implemented in the Far Field portion of
the groundwater contaminant plume, concurrent with
ISVH/AS in ihe Near Field areas. Attenuation processes
i'or VOCs, in groundwater, would be closely monitored
concurrent, with other aspects of the selected remedy. In
addition, surface water and sediment sampling and
analysis would be included in the long-term monitoring
plan.

MNA would be implemented in the Far Field portion of
the groundwater contaminant plume, concurrent with
I.SCO in the Near Field areas.. Attenuation processes for
VOCs in groundwater would be closely monitored
concurrent with other aspects of the selected remedy. In
addition, surface water and sediment sampling and
analysis would be included in the long-term monitoring
plan.

A CEA would be established to limit the installation of
additional wells in the area of groundwater
contamination until cleanup standards have been met.

I'his alternative would address indoor air contamination
by continuing EPA's current program of sampling sub-
>lub and indoor air associated with structures overlying
the groundwater contaminant plume. Where elevated
VOC levels are detected, vapor mitigation systems

A CF.A would be established to limit the installation of
additional wells in the area of groundwater contamination
until cleanup standards have been met.

This alternative would address indoor air contamination
by continuing EPA's current program of sampling sub-
slab and indoor air associated with structures overlying the
groundwater contaminant plume. Where elevated VOC'

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THE NINE SUPERFUND EVALUATION CRITERIA

1.	Overall Protectiveness or Human Health and the
Environment evaluates whether and how an alternative
eliminates, reduces, or controls threats to public healrh and
the environment through institutional controls,
engineering controls, or treatment.

2.	Compliance with Applicable or Relevant and
Appropriate Requirements (ARARs) evaluates whether
the alternative meets federal and state environmental
statutes, regulations, and other requirements that pertain to
the site, or whether a waiver is justified.

3.	Long-term Effectiveness and Permanence considers
the ability of an alternative to maintain protection of
human health and the environment over time.

4.	Reduction of Toxicity, Mobility, or Volume (TMV)
of Contaminants through Treatment evaluates an
alternative's use of treatment to reduce the harmful effects
of principal contaminants, their ability to move in the
environment, and the amount of contamination present.

5.	Short-term Effectiveness considers the length of time
needed to implement an alternative and the risks the
alternative poses to workers, the- community, and the
environment during implementation.

f>. I in piemen lability considers the technical and
administrative feasibility of implementing ihe alternative,
including factors such as the relative availability of goods
and services.

7. Cost includes estimated capital and annual Operations
and maintenance costs, as well as present worth cost.
Present worth cost is the total cost of an alternative over
time in terms of today's dollar value. Cost estimates are
expected to be accurate within a range of +50 to -30
percent.

H. State/Support Agency Acceptance considers whether
the State ayre.es with the EPA's analyses and
" recommendations, as described in the 10/FSahd Proposed
Plan.

'J. Community Acceptance considers whether the local
community agrees with EPA's analyses and preferred
alternative. Comments received on the Proposed Plan are
an important indicator of community acceptance.

levels are detected, vapor mitigation systems would be
installed and maintained. In addition, systems already
installed at the Site would be maintained until the
•iruundwater is remediated.

Total Capital Cost
Operation and Maintenance
Total Present Net Worth
Time frame (.ISCO)

Full Groundwater Restoration

S7.9 million
5-3.7 million
SI 1.6 million
10 years

Approx. 70 years

Alternative 4 - Extraction and
Treatment/MNA/ICs/Vapor Remediation

Alternative 4 would include construction and operation of
a groundwater treatment plant and an extraction well'
system to collect and treat contaminated groundwater in
the Near Field areas immediately downgradient from both
source areas. This alternative would target the most
highly contaminated groundwater,-generally containing
PCE at levels of greater than 1,000 ppb. It is estimated
that two extraction wells would be required for each
source area and an additional three may be needed to
address downgradient hot spot areas pending further
evaluation in the R.D. A groundwater extraction and
treatment system would be constructed and operated for
approximately 30 years. It would consist of groundwater
extraction wells, the associated underground piping and a
treatment plant, '["he extraction system layouts and How
rates would be designed to maximize capture of
contaminated groundwater from different areas, then
combined and pumped to a treatment plant. .

Treatment of groundwater in the plant would be achieved
by several methods including air stripping and GAC
adsorption units, and the treated water would likely be
discharged to a surface water body such as Judas Creek,
the sanitary sewer system, or re-injected into the aquifer.

During RD, it would be determined if additional
extraction wells would be used to treat hot spots areas
within the Far Field portion of the groundwater plume.

Monitored Natural Attenuation for the Far Field area of
the plume would be the same as discussed above for
Alternatives 2 and 3.

A CFA would be established to limit the installation of
additional wells-in the area of groundwater contamination -
until cleanup standards have been met.

This alternative would address indoor air contamination
by continuing EPA's current program of sampling sub-
slab and indoor air associated with structures overlying the
groundwater contaminant plume. Where elevuted VOC
levels are detected, vapor mitigation systems would be
installed and maintained. In addition, systems already
installed at the Site would be maintained until the
groundwater is remediated.

Total Capital Cost
Operation and Maintenance
Total Present Net Worth

S7.3 million
"Sft.2 million
SI3.5 million

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Time Iriime (Pump & Treat) 30 years
Full. Groundwater Restoration Approx. 70 years

EVALUATION OF REMEDIAL ALTERNATIVES

Nine criteria are used to evaluate the different remedial
alternatives individually and against each other in order
to select the best alternative. This section of the
Proposed Plan profiles the relative performance of each
alternative'against the nine criteria; noting how it
compares 10 the other options under consideration. The
nine evaluation criteria are discussed below. A more
detailed analysis can be found in the FS.

Overall Protection of Human Health and the
Knvirmimcnt

The No Action Alternatives forsuil and groundwater are
not protective of human health and the environment.

While source area soils do not pose a direct risk to
human health, they contribute to groundwater
contamination at the Site, which poses unacceptable
levels of risk to human health. Under the No Action
alternative. VOC contamination in soils would continue
lo migrate to groundwater. Groundwater contamination
would continue to migrate uncontrolled, where it may
continue to iinpuet human health and the environment.

All other soil alternatives provide adequate protection of
human health and ihe environment and are expected to
comply with ARARs.

All groundwater alternatives lother than No Action) are
considered protective, fhey all include treatment of the
Site's most highly contaminated groundwater, and
include MNA. institutional controls, and appropriate
jndoor air mitigation to minimize potential exposure to
contaminated groundwater and vapors emanating from
groundwater until the alternatives ;ire implemented, and
remediation goals have been achieved.

Compliance with Applicable or Relevant and
Appropriate Requirements (AKARs).

I'he three broad categories of ARARs include chemieal-
>peciiie. location-specific and action-specific ARARs.
.ARARs have been established for groundwater at this
Site to restore the aquifer to drinking water standards.

No soil ARARs are required to protect against direct
contact with .Site soils, as this exposure does not pose
unacceptable risks. However, modeling was performed
to develop a soil cleanup standard for PCE. the primary
contaminant of concern that would be protective of
groundwater. I"he soil cleanup standard for PCE is 1
part per million (ppm). All soil remediation alternatives,
except the No Action alternative, would meet this
standard eventually. The No Action alternative would

n

not meet standards in a reasonable time frame. Of the two
active remediation technologies, excavation would
achieve soil ARARs more quickly, in I year, and. ISVE
would take approximately 10 years. The ISVE and
excavation technologies would also comply with location-
and action-specific ARARs such as the Resource
Conservation and Recovery Act.

All of the groundwater alternatives would eventually meet
the groundwater ARARs. The primary contaminant of
concern. PCE, has a NJ GVVQC of I ppb. The No Action
Alternative would not ineet ARARs in a reasonable time
frame^atid would not assure that residential drinking
water standards are met in the short term. "Hie alternatives
which include active treatment I Alternatives 2. 3 and 4)
would assure that potable water met the chemical-specific
ARAll for PCE.in a much shorter time frame compared to
the No Action alternative. All alternatives would comply'
with location- and action-specific ARARs such as the
Freshwater Wetlands Protection Act and the Federal Clean
Water Act.

.VINA is a component of.each alternative, with the
exception of the No Action alternative. .VINA would be
used to address lesser contaminated groundwater in the
I 'ar Field area of the Site. With the performance of an
active remediation of the most contaminated groundwater
in the Near Field, modeling has shown that Far Field
groundwater would be restored to drinking water
standards in a much shorter lime frame than without
remediation (roughly 70 years vs. -100 years).

l-'ach alternative, with the exception of the No Action
alternative, includes ongoing indoor air sampling and
installation of remediation systems within buildings to
prevent exposure lo unacceptable levels of PCI: in indoor
air.

Lung-Term Effectiveness and Permanence

The highest degree of permanence and long term
effectiveness is achieved for those alternatives that result
. in.a. greatest removal.of.contaminants, from the. Site. The
No Action Alternative would nut be effective in the long
term because no actions will be taken to address the
contamination. Some attenuation of contaminants can be
expected over time, but this would not be measured or
monitored under Alternative I.

For soil. Alternative 2, ISVE'AS. would be effective for
removal of soil contamination in the source area. Since it
is expected that the full remediation would take place
within 10 years, it would be both effective in the long term
and permanent. The magnitude of risk remaining after
implementation of 1S VE/AS or excavation for soil
contamination would be similar. ISVE/AS (Alternatives 2
and 4) would achieve contaminant reductions through in-

-------
situ treatment, while excavation (.Alternatives and 3 and
4) would rely on physical removal of the contaminated
material. ISVE/AS is estimated to require active
treatment operations tor up to 10 years, compared to 1
year for excavation. Excavation would have a higher
degree of certainty of reduction of contaminants since all
contaminated material would be physically removed.
ISVE/AS is expected to be effective at reducing
contamination, but since it is an in-situ technology, it
may not achieve 100% removal of VOCs, as would be
achieved by excavation.

For groundwater, active treatment in the Near Field areas
under consideration would include (SVE/AS
(Alternative 2), ISCO (Alternative 3), or extraction and
treatment (Alternative 4). In comparing these
alternatives. Alternatives 2 and 4 would likely have
similarlyhigh degrees of long-term effectiveness.
Alternative 3, ISCO, could be effective in the long term,
hut would be more difficult to implement and manage,
lending to more uncertainty with res,pect to its long-term
effectiveness compared to Alternatives 2 and 4.

Reduction uf Toxicity, Mobility, or Volume Through
Treatment

The No Action Alternatives for both soil and
groundwater would not treat the contaminants and would
not reduce their toxicity, mobility, or volume through
treatment.

For soils. Alternative 2, ISVE/AS would reduce the
volume of the majority of the VOC contaminants in the
•;uils (estimated at WM> removal) through treatment,
thereby greatly reducing the volume of the contaminants.
Alternative 3.- excavation, would remove 11)0% of the
volume of contaminants, but is not likely to include
treatment in that the excavated soils would likely be
disposed at an off-Site, licensed landfill. Alternative 4
would be effective in reducing toxicity, mobility and
\ i>lume through treatment nt the Sun Cleaners property.
As stated, excavated soil from the White Swan Cleaners
property may not require treatment at a.wasie disposal ..
facility.

"For groundwater. Alternative 2 (ISVE/AS). Alternative 3
(ISCO). and Alternative 4 (extraction and treatment)
would all reduce the toxicity, mobility and volume of
groundwater contaminants using different treatment
technologies in the Near Field. ISCO would
permanently destroy contaminants in-.situ. ISVE/AS and
extraction and treatment would remove contaminants in
the groundwater and then treat the contaminants in the
air or groundwater stream generated respectively.

Short-Term Effectiveness

The No Action Alternatives for soil and groundwater
include no construction or monitoring, and would have no
short-term impacts at the Site.

In addressing contaminated soils. Alternatives 2,3, and 4
would all have some short-term impacts on workers and
the local community, as the source areas to be remediated
are located in a highly developed commercial area, near
residential communities. Potential risks would include
physical hazards near areas where heavy equipment is
used and from increased vehicles traffic, and noise, air
emissions, and hazards resulting from managing
contaminated soils. These short-term risks can be
managed through appropriate planning and monitoring
during the construction. Air emissions generated during
the-ISVE/AS operations can be controlled and monitored.
Disruption to the community would be relatively lower for
ISVE/AS (Alternatives 2 and 4) compared to. excavation
i Alternatives 3 and 4), as excavation would require the
transportation of contaminated soils from the source areas
via existing roadways. However, ISVE/AS would require
about 5 months to construct, and 10 years to operate
intermittently, while excavation would fake about I year
to implement.

For the groundwater alternatives, Alternatives 2
(l'SVE/AS), Alternative 3 (ISCO). and Alternative 4
(groundwater extraction and treatment), a number of
short-term risks are possible including, physical hazards,
noise, traffic near areas requiring heavy equipment tbr
construction, emissions and dust. Additional significant
.short-term risks would be presented under Alternative 3
I ISCO). as this alternative would require handling and
storage of a chemical oxidant in a densely populated
residential community. The oxidant would need to be
carefully managed. In addition. Alternative 3 (ISCO)
would also have the potential to increase contaminated
vapors in residential areas. Careful monitoring and
management of vapors would be required to protect public
health. All of the three active groundwater alternatives
would present some disruption of the community;
however. Alternatives would-require ihe-most disruption-
of private property and is the least effective in the short-
term.

Iinplementability

The No Action Alternatives for soil and groundwater
require no implementation.

For soils, each alternative considered would be technically
implementable and uses proven, readily available
technologies. A pilot study would be needed prior to the
design of the remedy under Alternative 2 (ISVE/AS).
Alternative 3 (Excavation) would be significantly more
difficult to implement at the Sun Cleaners source area

-------
compared to the White Swan source urea for a number of
reasons. The topography of the Sun Cleaners property
includes ^substantial steep slope, which may require
specialized equipment to assure a safe exaction, tn
addition, the Sun Cleaners property is located on a
highly congested traffic circle, which would require
significant rerouting of traffic and disruption to the
community. The White Swan property by comparison,
would be easier to excavate as it is relatively level and
located on a less traveled road. In addition, the
excavation alternative would remove significantly more
mass from the White Swan property compared to the
Sun Cleaners property (4.360 pounds of PCE mass at
White Swan vs. 140 pounds of PCE mass ai Sun
Cleaners).

For groundwater, each technology considered is
technically implementable. proven and readily available.
Issues required to implement all alternatives include
acquisition of land, subsurface work within local streets
and private property for installing system components.
Alternative 2 (ISVE/AS) and Alternative 3 (ISCO)
would have the greatest amount of infrastructure
required on private property compared to Alternative 4
I extraction and treatment). For this reason, these
alternatives would be more disruptive to the community
during construction and operation compared with
Alternative 4.

Alternative 2 11SV17AS) would require regular
maintenance to prevent metals fouling in the system.
Alternative 3 (ISCO) would present safety hazards
issociated with the storage and handling of chemical
oxidants in residential areas, further generation of
contaminated vapors could he exacerbated through the
implementation of ISCO and indoor air would need to be
closely monitored.

Cost

I'liere are no costs associated with the No Action
Alternatives for soil and groundwater: however, it would

.provide no protection.to buman.heallh.or.the 	

environment, fhe following chart summaries the costs
for rest of the remedial alternatives.

Ground
water

WS&
Sun

MSVE/
MNA

5.4

5.4

10.X

Ground
water

WS&
Sun

3-lSCO/
MNA

7.y

3.7

11.6

Ground
water

WS&
Sun

4-P&T/
MNA

7.3

6.2

13.5

State/Support Agency Acceptance

"Hie State of New Jersey agrees with the preferred
alternative in this Proposed Plan.

Community Acceptance

The community's opinion of the preferred alternative will
he evaluated after the public comment period ends and
will be described in the Responsiveness Summary of the
Record of Decision. The Record of Decision is the
document that formalizes the .selection of the remedy for a
site.

SUMMARY OF THE'PREFERRED ALTERNATIVE

The preferred alternative for the White Swan
Cleaners/Sun Cleaners Area Groundwater Contamination.
Site is Alternative^ for source soils and Alternative 4 for
groundwater. Alternative 4 for soils would include the
ISVE/AS technology to treat soils and associated
groundwater at the Sun Cleaners source area and
excavation and off-site disposal for soils at the White
Swan source area. Demolition and disposal ol'ihe bank
building may be necessary. Alternative 4 for groundwater
would include: the extraction ;ind treatment of the most
highly contaminated groundwater in-the Near Meld
portion of the groundwater plume: MNA Ibr lesser
contaminated groundwater in the Far Field portion of the
groundwater plume, ongoing sub.-slab and indoor air
investigation and remediation, and ICs.

ISVE/AS would he implemented for soils at lhe Sun
Cleaners source area and excavation would he
implemented for soils at il'ic White Swan source urea.

Soils located above the water.iable..as. weLLaa.soiIs below
the water table would be addressed, as these are principal
threat wastes. A Site-specific soil cleanup tjoal of 1 ppm
for PCE has been developed and would be protective of
groundwater. Addressing soils to meet this cleanup
standard is expected to address all Site contaminants.

After completion of soil remediation activities, both
properties containing contaminated soils would be
restored and could be redeveloped.

The most highly contaminated groundwater at the Site, in
the Near Field-area, would be remediated through
extraction and treatment. Extraction wells would be
located adjacent to and downgradient the source areas to
address the Site's most highly contaminated groundwater.

Media

Source
Area

Alternative

Capital

Cost

SM

O&M
SM

Present

Worth

SM

soil

WS &.
Sun

2-iSVE

1.8

1.8

3.6

soil

WS &.
Sun

3-

Excavation

*.0

•S.0

M>il

WS
and
Sun

4-ISVE for
Sun

Excavation
For WS

4.5

0-9

5.4

-------
The groundwater treatment plant would treat the
groundwater by removing the PCE and ICE using air
strippers and activated carbon. The treated groundwater
would be discharged to either to the local
sewer/treatment, facility, surface water or re-injected into
the aquifer. Areas of elevated groundwater
contamination (hot spots) in the Far Field area of the Site
would be t'unher evaluated and may be addressed
through either the groundwater extraction and treatment
system, ur smaller localized treatment systems.
Determinations regarding whether to address these hot
spots will be made during the RD.

Lesser contaminated groundwater would be addressed
through MNA. Attenuation processes for VOOs in
groundwater would be closely monitored concurrent
wich other aspects of the selected remedy. Sediments
would continue to be monitored to evaluate the impact
of the remedy over time.

Indoor air contamination would be addressed by
continuing EPA's current program of sampling sub-slab
and indoor air associated with structures overlying the
groundwater contaminant plume. Where elevated VOC
levels are detected, vapor mitigation systems would be
installed and maintained. In addition, systems already
installed at the Site would be maintained until the
groundwater is remediated.

The preferred alternative would prevent exposure to Site
contaminants by addressing indoor air contamination as
described above, and through the implementation of ICs,
¦.uch as a CEA, until the aquifer is restored to drinking
water standards. The total cost of the preferred
alicriuuivc to address all Site contamination is estimated
to he SIX.lJ million.

As is EPA's policy, live-year reviews would be
conducted until remediation gpajs have been met.

The preferred alternative was selected over the other
alternatives principally because it is expected to achieve
, substaiuiaLlong-term risk-reduction.through treatment.of
'.he principal threat waste, as well us the most highly
contaminated groundwater contamination.

Based on information currently available. EPA believes
the preferred alternative is protective of human health
and the environment, complies with AilARs and
provides the best balance of tradeoffs among the other
alternatives with respect to the Superftind evaluation
criteria. EPA expects the preferred alternative will
satisfy the statutory requirements of C'ERCLA Section
1212(b).

Consistent with EPA Region 2's Clean and Green
policy, EPA will evaluate the use of sustainable

technologies and practices with respect to any remedial
alternative selected for the Site.

COMMUNITY PARTICIPATION

EPA provided information regarding the cleanup of the
White Swan/Sun Cleaners Supeifund Site to the public
through public meetings, the Administrative Record file
for the Site and announcements published in the Coast
Star newspaper. EPA encourages the public, to gain, a
more comprehensive understanding of the Site and the
Superfund activities that have been conducted there.

For farther information on EPA's preferred alternative for
the White Swan/Sun Cleaners Superfund Site, please
contact:

Matthew Westgate	Cecilia Echols

Remedial Project Manager Community Relations
([2121 637-4422	(212) 637-3678

U.S. EPA

200 Broadway, I9lh Floor
New York, New York I00U7-1866

The dates for the public comment period; the date, the
location and time of the public meeting: and the locations
of the Administrative Record files are provided on the
front page of this Proposed Plan.

N

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ta.ossAiu

AU.Vlis: Applicable vii Relevant and .i>|>i<.>K' Kci|imcuicilis. I lio*.- .ik' federal or Stale ctiv iroiimciltai I'nlc> and t't!y illations
lh;i( iim\ pertain to I lie She or a particular aliernaiivc.

Carcinogenic Itisk: Lancer risks arc cspicssed as ;t number ivllcciin:; ilie increased chance iluil a person will dev«_• hijt cancer if
exposed 10 chemicals or substances. I\>i cvamplc. lU'A's acceptable ri>k r;iiiyo lor Siipcrfuiid hazardous waste silts is I \ IU"* Ui I \
10'". nicuiiiiu; there is I additional chance in Kuiiiu (I x 1U "I lu I additional chance in I million (1 x l(J'r) that a person w ill
dc\clop cancer iI' exposed lo a Sile contaminant that is 1101 icnicdiaicd.

OLIUC'LA: Comprehensive I :n\ iroimiciual Kcsponse. Compensation and I i.ilnlily Act. A federal lavv. commonly re leu e J lo as lite
'¦Siipcrfuiid" l'rn«ram. passed in 19Mi llrul prov iiles lor lesponse actiuiis al sites found lo be eunuimiiuiieil w ill) hazardous
substances, pollutants or contaminants lluu endanger public health and safctj or the environment. -

("OI'C: Chemicals of l'oicntial Concent.

SI.IlRA: Screening l evel Ideological Risk Assessment. \ii evaluation of (lie potential risk po.ied 10 the cii\ ironmenl if remedial
activ ilies arc not perloiiiicd ;il lite Site.

KS: leasibilit) Study. Analysis of Ilie practicability of multiple ieiiieJi.il neiioii options for the Sile.

(.round >t slier: Subsurface water thai occurs in soils and geologic formations that arc fully Saturated.

1I11KA: Human Health Risk Assessment. An evaluation of ilie lisk po.-.ed to human health should remedial activ ities iit.il be
implemented.

Ill: Hazard Index. A number indicative »f noncarcinoucuic healili effects thai i> the raiivi of lite existing level ol exposure to an
acceptable level of exposure. A value ct|iial to or less titan one indicates llial llic human population is not likely lu experience
adverse ef Iccts

HQ: I la/Mid Qouticitt. I lOs arc used lo evaluate noncauino^cnic health effects and ecological risks. A tulue ei|ual lo or less than
oner indicates that lite human tn ecological population are not likely to experience' adverse effects.

IOs: Institutional Controls. Ailiiiiuistr.il i\c methods tu prcxciu human exposure lo contaminants. such as by rcslrictin;.' the use of
groundwater lor drinking vv jtei purposes.

Nino L valuation Criteria: See text box on I'agc 12.

Nuitcarciilu^onic Risk: Noncailcer i la/aids tor risk) .ne c\,nes>cvl .is a t|ui>iieiil that compares the exisiinj> level of cxpusiirv to the
acceptable level of exposure. There is a level of exposure (llic reference dosci below which ii is unlikely for c\cn a sensitive
population lo experience adverse health effects. l!Sl.:l'A's lhiesliol.1 level I'm nuncarciuogcuic risk at Super fund sites is I. meaning
lltui if the exposure exceeds the ihivsholJ: thcic may be a concern for potential noiicancer effects.

Nl'L: National Priorities l.ist. A list developed In I Sl:l'.\ of uttcuiiirollcd ha/ardi'us substance release sites in the L uitcd Stales
that are considered priorities lot long-icrm remedial evaluation and response.

-------
Operable 1'ilil (OU): ;i discrete oction [Iml comprises mi increment.ii slop toward comprehensively addressing iiic
problems. This discrete portion ol'.i ivuictii.il response in.iiKiucs migration. or eliminates or mitigates u release, threat ol
:i release, or pathway ol exposure. The cleanup of a site can be divided into a number of opct'ublc units, depending on
the complexity of the problems associated with die bite.

I'rneticill Quantitation l-cvel (I'tjl ): means the lowest concentration ol'.i constituent thai can be rcliablv achieved among
laboratories within specified limits of precision and accuiacv during routine laboratory operating conditions.

I'resciit-Wurlli Cost: Total cost, in current dollais. of the remedial aciion. The present-worth cost ineludes capital costs required to
implement ilie remedial uetion. as w ell as tile eust ol' long-term operations, maintenance. mid monitoring.

I'ropnscd Plan: A document thai presents the preferred 1v11iLili.1l alternative and requests public input regarding tltc proposed
cleanup alternative.

Public C'uiiiuiviil i't-riml: Hie time allowed lor die member:, ol ;. poiciiti.dl) jfl'ecled Community to express views and concerns
regarding IJSEl'A's preferred remedial alternative.

UAOs: Remedial Action Objectives (Ihjcciives ol'remedial action.-, tli.it are developed bused oil contaminated media, contaminants
of concern, potential recepiors and exposure scenarios, human health and ecological risk assessment. and attainmem of leguluiory
cleanup levels.

Record ol Decision (KUD): A legal document tli.it describe* the cleanup action vir remedy selected lor a site, the basi> lor choosing
llial remedy, and public comments on ihc selected remedy.

Remedial Action: A cleanup to address hazardous siihsi.iitcot at .1 site.

Ut; Keincili.il Invvsiigation. A stud) ol'a I'acilils (hat supports the selection ol'a remedy where hazardous substances have been
disposed or released. The K| identities the nature and cmciiI of contamination at tlic facility and itnal^es risk associated with
C'Ol'Cs.

Saturated Soils: Soils that are found below the Water Iable. I'hese soils stay wet.

1 UCs: "I o-bc-eonsideredh," consists of iioi|-pioiuulgalcd adv i.sories and or guidance that were developed by lil'A, other federal
agencies, or stales that may be useful in developing CIIKCI.A remedies.

Unsaturated Soils: Soils lliat are found above the Water "I able. Rain or surface water passes lluuugli these soils. These soils
remain dry:

I SKI'A: Linited Slates Lnviromnciiial I'nucciion Agcitcx. The ledcr.il agency responsible lor administration and cnlbicemeiit of
(TIU.'L.A land oilier environmental statutes and regulations), and final approval authority for the selected ROD.

VOC: Volatile Organic Compound. 'Ivpe 0l chc111ic.il that readily vaporises, often producing a distinguishable odor.
Water Tubk': The water table is an imaginary line marking the top of the water-saturated area within a rock column.

-------
iv

-------
Westgate, Matthew

From:

Sent:

To:

Subject:

Echols, Cecilia

Wednesday, September 18, 2013 4:17 PM

Westgate, Matthew

FW: Public meeting August 27, 2013

See below. I sent the link to Ellen Safka. Thanks

From: Echols, Cecilia

Sent: Wednesday, September 18, 2013 4:14 PM
To: 'Ellen Safka'

Subject: RE: Public meeting August 27, 2013

Here is a link to the transcript. I hope this will help you.
http://epa.gov/region02/superflind/npl/whiteswaii/additioiialdocs.html

Cecilia

From: Ellen Safka [mailto:safkae@qmail.coml
Sent: Wednesday, September 18, 2013 2:06 PM
To: Echols, Cecilia

Subject: Re: Public meeting August 27, 2013
Thank you!

Ellen Safka

On Wed, Sep 18,2013 at 9:49 AM, Echols, Cecilia  wrote:

Please call Mr. Robert Keating at 212-637-4325. He is in charge of the Records room and he has a copy of the
Administrative Record for the White Swan Cleaners site. The transcript is a part of that document.

Thank you,

Cecilia Echols

Community Involvement Coordinator

Hi Ellen,

l

-------
From: Ellen Safka rmailto:wallmomll@amail.coml
Sent: Wednesday, September 18, 2013 9:21 AM
To: Echols, Cecilia

Cc: Westgate, Matthew; WILMA MORRISSEY
Subject: Public meeting August 27, 2013

I was wondering if we could see the transcripts from the meeting before we attend the Sept 26,2013, meeting
for the Wall Environmental discussion.

Where might they be to review them?

Thank you,

Ellen Safka

2

-------
Westgate, Matthew

From:

Sent:

To:

Patricia and Maureen McCloskey [mpmshore@hotmail.com]
Wednesday, September 18, 2013 12:50 PM
Westgate, Matthew

Dear Mr. Westgate,

My name is Pat McCloskey and I live at 1201 Hemlock Avenue in Wall Township NJ (Sea Girt
Estates). The street behind us is Magnolia. We would like to receive air quality testing at our
house as we are very concerned about the unhealthy environmental problem that exists in our
area. My phone is: 732-449-0571.

Please let us know if you need anything else. We appreciate any help you can give us at this time.

Thank you.

Pat

i

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Westgate, Matthew

From:	Edward Donovan [edonovan@verizon.net]

Sent:	Wednesday, September 18, 2013 11:27 AM

To:	Westgate, Matthew

Cc:	Jo.Schloeder@mail.house.gov; Joseph Delorio; Barbara Maria

Subject:	FW: White Swan/Sun Superfund Clean Up Plan Public Comment

Good Morning Mr. Westgate,	¦

I am forwarding you an email sent to Congressman Chris Smith's office regarding the Borough of Manasquan's public
comment on the proposed White Swan/Sun Cleaners remediation project. The Borough Administrator, Joseph Delorio
will also be forwarding a resolution authorized at the governing body's Sept. 3, 2013 meeting.

Thank you,

Ed Donovan
Council President
Borough of Manasquan

From: Edward Donovan fmailto:edonovan@verizon.netl
Sent: Wednesday, September 18, 2013 11:14 AM
To: 'Schloeder, Jo'; 'edonovan@manasquan-nj.com'

Cc: 'jdeiorio@manasquan-nj.com'

Subject: RE: Superfund Clean Up Plan

Good Morning,

Thank you for contacting me about this matter. At our town council meeting on Sept. 3, 2013, the Manasquan governing
body authorized a resolution regarding solutions proposed by the EPA. Although we support the project as a whole, the
governing body specifically objects to EPA's Alternative #4 for Ground Water Remediation:

"It is estimated that two extraction wells would be required for each source area and an additional three may be needed
to address downgradient hot spot areas pending further evaluation in the RD. A groundwater extraction and treatment
system would be constructed and operated for approximately 30 years."

"Treatment of groundwater in the plant would be achieved by several methods including air stripping and GAC
adsorption units, and the treated water would likely be discharged to a surface water body such as Judas Creek, the
sanitary sewer system, or re-injected into the aquifer."

In Manasquan, Judas Creek floods residential properties in the Willow Way area during significant rain events. Water
from the creek sometimes extends 80 feet into backyards bordering the creek at those times. Judas Creek also passes
very close to Manasquan High School and through Manasquan Elementary School before emptying into Stockton Lake.
The borough believes the flooding problem would be exacerbated if as much as 200 gallons per minute, 24 hours a day,
7 days a week were discharged into the creek. Manasquan would suggest the EPA consider a plan where the treated
water would be re-injected into the aquifer.

I would like to thank you and Congressman Smith again for your interest.

Sincerely,

Ed Donovan
Council President
Borough of Manasquan

l

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From: Schloeder, Jo [mailto:Jo.Schloeder@mail.house.aovl
Sent: Tuesday, September 17, 2013 1:30 PM
To: edonovan@manasquan-ni.com
Cc: ideiorio@manasauan-ni.com
Subject: Superfund Clean Up Plan

Mr. Donovan:

As you know, the EPA's comment period on the proposed plan for the White Sawn/Sun Superfund clean-up closes this
week. The Congressman would very much like to support and assist the Borough in any way during this time. Kindly
advise if Manasquan will be providing comment and any specific requests you will be making so that we may try to work
toward that end.

If you have any questions, please do not hesitate to contact me.

Sincerely
Jo Schloeder

Jo Smith Schloeder, Director of Public Policy
io.schloeder@mail.house.aov

Congressman Christopher H. Smith • NJ Dist. 4

112 Village Center Drive - 2 Fl.

Freehold, NJ 08827

732-780-3035 phone

732-780-3079 fax

2373 Raybum House Office Bdg.

Washington, DC 20515
(202) 225-3765 phone
http://ch rissmith.house.aov/

2

-------
WestgateJ^atthew

Subject:

Sent:

To:

Cc:

From:

ClayConstantinou@aol.com
Wednesday, September 18, 2013 10:24 AM
Westgate, Matthew
jenniferconstantinou@gmail.com
Re: PCE indoor air sampling

Mr. Westgate,

Thank you. My daughter Jennifer and I are grateful for your assistance.

Regards,

Clay

In a message dated 9/17/2013 2:34:57 P.M. Eastern Davliaht Time. WestQate.Matthew@epa.gov writes:
Dr. Constantinou:

Here is the instruction sheet I send out when I am contacting residents to have their house sampled.
If you have any more questions please call me at the number below.

Matthew Westgate, Project Manager/Geologist

U.S. EPA Region 2

New Jersey Remediation Branch

Southern New Jersey Remediation Section

290 Broadway, 19th floor

New York, N.Y. 10007-1866

(212)637-4422

W esteate.matthew@epa. gov

l

-------
Westgate, Matthew

From:	Ellen Safka [wallmom11@gmail.com]

Sent:	Wednesday, September 18, 2013 9:21 AM

To:	Echols, Cecilia

Cc:	Westgate, Matthew; WILMA MORRISSEY

Subject:	Public meeting August 27, 2013

I was wondering if we could see the transcripts from the meeting before we attend the Sept 26,2013 meeting
for the Wall Environmental discussion.

Where might they be to review them?

Thank you,

Ellen Safka

l

-------
WestcjateJVIatthew

Sent:

To:

Cc:

Subject:

From:

Stephen Barlow [sbarlow@barlowflowerfarm.com]
Wednesday, September 18, 2013 7:53 AM
Westgate, Matthew

Ibarlowbytheshor@aol.com; Stephanie Peduto
Barlow Flower Fahn

Good Morning Matt,

I hope you are doing well. I am sure you are very busy with the plumb following the public meeting and all the press
that it has been getting. I had a couple of concerns and wanted to see if you could let me know some information on
them.

As you know, we water all of our plants with well water, that has been in contact with the plume.

1.	What is the likely hood of the toxins being absorbed by the plants?

2.	Are my employees that are in direct contact with the water in harm's way?

3.	Are there clean products out there that can clean the water prior to it coming in contact with the plants?

4.	Is it possible to have our well water tested?

5.	What happens to the chemicals in the water once they come out of the hose?

6.	We are concerned about getting bad press since we are in a hot spot of the plume. Is there any literature

that we could repurpose to our customers assuring them that Barlow's is a safe place to shop and that the
products we produce are safe to handle?

Also, we have just constructed two new homes on village road and wanted to get them tested.

1.	Can you please let me know the steps involved in getting them tested?

2.	What is the time frame on this process?

Thank you in advance for the answers to our questions and all your help with this.

Stephen Barlow

Barlow's

1014 Sea Girt Avenue
Sea Girt, NJ 08750
www.barlowflowerfarm.com

l

-------
>

Westgate, Matthew

From:

Sent:

To:

Subject:
Attachments:

Ellen Safka [safkae@gmail.com]

Tuesday, September 17,2013 6:55 PM
Westgate, Matthew; Echols, Cecilia; WILMA MORRISSEY
WHITE SWAN CLEANERS/SUN CLEANERS
Questions for EPA v1.0-1 .docx

As we have been directed to, here are the additional questions that were unable to be asked due to time
restraints at that time.

I would like to receive the answers to the questions returned to me to clear up some of the issues that we have
concerns over.

Thank you for your continued support.

Ellen & Paul Safka
1204 Jefferson Ave
Manasquan, New Jersey 08736

(7321223-2495

l

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Questions for EPA:

Rev 1.1 September 17, 2013

1. Evaluation of Remedial Alternatives page 15 of Proposed Plan lists nine criteria with
number 8 and 9 as State (or support agency) acceptance and Community acceptance
respectively.

a.	Proposed Plan states "The State of New Jersey agrees with the preferred
alternative in this Proposed Plan." Will documentation of this concurrence be
made available to the public?

b.	Please describe method and status of Notifications and responses from affected
town governments, that being Wall Township, Sea Girt, and Manasquan?

c.	Was Wall Township Board of Health notified of Proposed Plan and what was
their response?

2. Were "treatability studies" performed? [ re: EPA Work Plan Task V Treatability Studies]

a.	Did they include pilot scale equipment and testing to determine effectiveness?

b.	Are these studies available to the public?

3. EPA Work Plan Section 1 Background identified ground water contamination
approximately 2 miles long and 1 mile wide. Approximately 100 shallow private
irrigation wells within three municipalities are contaminated.

a.	What are EPA's plans to inspect, monitor, upgrade or close these wells to
prevent further cross-contamination prior to, and during the remediation
activities?

b.	Is there a moratorium on future shallow ground water wells in this area?

1

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4. Will institutional controls be placed on White Swan and Sun Cleaner sites to prevent any
use or redevelopment at anytime during implementation of this Proposed Plan?

.5. Is the current owner of the Sun Cleaners site named as a-potentially responsible party
(PRP) and what responsibility do they have in this Plan?

.6. EPA's website page updated August 22, 2013 "GPRA Measures" tab states "EPA is
working to determine whether, under current conditions, there are any potential or
actual human exposures to contaminants at this site."

a. Are we to anticipate this is still ongoing and please provide time line for this
effort?

7.	EPA's website page updated August 22, 2013 "GPRA Measures" tab states "At this site,
EPA is still working to determine whether contaminated ground water migration is
under control."

a. Are we to anticipate this is still ongoing and please provide time line for this
effort?

8.	Page 9 of Plan: Given the potential of 50 to 70 years to fully attenuate the Far Field
areas.

a.	Was consideration given to active remediation techniques in these areas?

b.	And what was the decision and basis of decision?

9.	Were alternative in-situ technologies including Six- Phase Heating (SPH) considered and
why were they ruled out? Based on successful remediation of PCE contamination at
similar commercial and government facilities including NASA Cape Canaveral requiring
only months rather than years, this would appear worthy of consideration.

10.	Page 10 of Plan: States that "Significant mass removal by ISVE/AS could be expected at
the Sun Cleaners source area over a period roughly 10 years and systems would be
operated periodically until soil is remediated."

a. Describe what is periodically?

2

-------
b.	Since White Swan site excavation and removal is only anticipated to take less
than one year why is the same approach not being used for the Sun Cleaners
site?

c.	Did Bank of America have input on what methods are employed since their
White Swan site cleanup is in the 1 year time frame and the Sun Cleaners site 10
years?

11. Page 10 of Plan: Reason for not excavating Sun Cleaners site due to topography and
location is questionable. Both sites are in close proximity to the highway and will impact
traffic flows in either case.

a.	Have traffic impact studies been performed for both sites to support the
conclusion?

b.	Were alternatives explored such as temporary haul roads thru adjacent compost
facility to avoid direct truck traffic into the Highway 35 circle?

12. Page 12 of Plan: "A groundwater extraction and treatment system would be constructed
and operated for approximately 30 years."

a.	What are expected operating cycles, continuous 24x7 or less frequently?

b.	Describe expected sound levels day and night?

c.	Describe aesthetics of these systems, including structures, fencing, and
landscaping?

13. Has this Proposed Plan undergone third party peer review both from inside and outside
the EPA?

a. By whom and are the findings published?

14. When will the Jefferson Ave Piezometer(s) be closed and removed and paving repaired?
Based on the map provided in Proposed Plan, it appears these are not in the delineated
area exhibiting PCE in groundwater. Will schedule be made available of testing and will
periodic reports be also accessible?

3

-------
15. What is timeline from today and after Public comment period to begin implementation
and break ground on the remediation activities?

4

-------
Westgate, Matthew

Sent:

To:

Cc:

Subject:

From:

Echols, Cecilia

Tuesday, September 17, 2013 12:37 PM

Martin, JohnJ

Westgate, Matthew

RE: White Swan Community Member

Thanks John.

Matt, here is another inquiry.

From: Martin, JohnJ

Sent: Tuesday, September 17, 2013 9:51 AM
To: Echols, Cecilia

Subject: White Swan Community Member
Hi Cecilia,

We got a call from a member of the Wall Township community asking about local groundwater. It sounds like he's
looking for reassurances that it's ok for his family to continue using the water, but he might have some more questions
about the cleanup.

His name is Chris Campbell. His contact info is 301-312-5250 and christopherfcambell(5>gmail.com.

John Martin
Press Officer

U.S. Environmental Protection Agency
290 Broadway, New York, NY 10007
martin.iohni@epa.gov
Desk: 212-637-3662
Cell: 646-256-6710

EPA's Region 2 Covers N J., N.Y., P.R. and the U.S.V.I.

Visit Us: epa.gov/region2

Twitter: twitter.com/eparegion2

Facebook: facebook.com/eparegion2

Greening the Apple Blog: blog.epa.gov/greeningtheapple

John

l

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Westgate, Matthew

From:

Sent:

To:

Subject:

Echols, Cecilia

Monday, September 16, 2013 2:33 PM
Westgate, Matthew
FW: Sea Girt Estates

Here is another inquiry.

	Original Message	

From: Francesca Wells rmailto:Mellsteatrt3aol.coml
Sent: Tuesday, September 03, 2013 10:02 PM
To: Echols, Cecilia
Subject: Sea Girt Estates

Hello. I lived in Sea Girt Estates in the late 80's and 90's. in 1994 my father was
diagnosed with cancer in his 60's. His cancer was so aggressive that he died before his
primary cancer could be diagnosed. Other neighbors had similar experiences. When I
researched our town I saw that our neighborhood was listed as a superfund site in the early
90's if not earlier. I was shocked! The only thing more shocking is seeing that it took 20
plus years for the EPA to come up with a plan to clean it up. 20 years?! How many of my
high school friends have died from cancer in their 40's while the EPA took 20 years to come
up with a plan?

My question is how do you explain this 20 plus year gap for this clean up? Did you notify
the residents of the danger? If not, why? I would like this question to be a part of your
public records because I will not rest until I have answers for this horrific lack of respect
for human safety.

Thank you,

Francesca Wells

-------
Westgate, Matthew

From:	Michael Tighe [mjtighe@optimum.net]

Sent:	Monday, September 16, 2013 1:25 PM

To:	Westgate, Matthew

Subject:	Re: White Swan Superfund

Thank you for the reassurance.

Sent from my iPad
mjt.

On Sep 16, 2013, at 11:08 AM, "Westgate, Matthew"  wrote:

>	Mr. Tighe;

>	Yes there are some low levels of PCE contamination in the groundwater at that location but
our sister agency ATSDR did a health evaluation to find out if there was any risk associated
with using the water for your swimming pool and found none. The ATSDR documents related to
that evaluation as well as other important site documents are in the Wall township Public
library reference section on 2700 Allaire Road.

>.

>	Matthew Westgate,

>	Project Manager/Geologist U.S.

>	EPA Region 2 New Jersey Remediation Branch, Southern New Jersey

>	Remediation Section

>	290 Broadway, 19th floor

>	New York, N.Y. 10007-1866

>	(212)637-4422

>	Westgate.matthewfilepa.gov

>

	>	Original Message	

>	From: Michael Tighe rmailto:mitighefi)optimum.netl

>	Sent: Saturday, September 14, 2013 11:19 AM

>	To: Westgate, Matthew

>	Subject: FW: White Swan Superfund

>

>

>	Sir,

>

>	I submitted the e-mail question below because I am concerned about potential contamination
of the ground water from the White Swan incident.

>	mjt.

>

>		 Begin forwarded message 	

>	Subject: White Swan Superfund

>	Date: 09/14/13 11:08:43 AM

>	From: "Michael Tighe" 

>	To: westgate.matthew(Bepa.gov

>

>	Sir,

>	I am a resident of Sea Girt, New Jersey on New York Blvd., between Third and Fourth Avenues
and have an inground concrete swimming pool in my back yard. I am considering filling the
pool with water from an underground well on our property. My family including my
grandchildren use the pool.

>

l

-------
>	If I fill this swimming pool form the underground well is there any threat to my family. Is
it safe to do this?

>

> mjt.

2

-------
Westgate, Matthew

From:

Sent:

To:

Subject:

Rick Deacon [rdeacon@interspec.com]
Monday, September 16, 2013 10:36 AM
Westgate, Matthew
RE: White Swan

I appreciate it.

—Original Message	

From: Westgate, Matthew rmailto:Westgate.MatthewOepa.gov!

Sent: Monday, September 16, 2013 11:04 AM
To: Rick Deacon
Subject: RE: White Swan

No you are south of the southern edge. The plume is moving west to east.

Its going to pass to the east, north of your location.

	Original Message	

From: Rick Deacon rmailto: rdeacon(S)interspec.com!

Sent: Monday, September 16, 2013 9:55 AM
To: Westgate, Matthew
Subject: RE: White Swan

Thanks for taking the time to respond.Am I in-the path of the plume as it moves downstream?
	Original Message	

From: Westgate, Matthew \mailto:Westgate.MatthewOepa.gov!

Sent: Monday, September 16, 2013 10:22 AM

To: rdeaconOinterspec.com

Cc: Echols, Cecilia

Subject: White Swan

There is no contamination in the groundwater at your location - 34 Forest Ave in
Manasquan,ND.

Therefore no worries regarding indoor air.

Matthew Westgate, Project Manager/Geologist

U.S. EPA Region 2

New Jersey Remediation Branch

Southern New Dersey Remediation Section

290 Broadway, 19th floor

New York, N.Y. 10007-1866

Mr. Deacon

(212)637-4422

1

-------
Westeate. matthewiSepa. gov

-------
V; *¦

Westgate, Matthew

From:

Sent:

To:

Subject:

Jennifer E. Constantinou Oenniferconstantinou@gmail.com]
Monday, September 16, 2013 10:28 AM
Westgate, Matthew

Re: Purchasing home in Sea Girt, NJ - plume inquiry

That sounds great - the closing would not be until January 2, 2014. I've asked my realtor for
the current owners' information. Thank you again. Jennifer

Sent from my iPhone

On Sep 16, 2013, at 10:25 AM, "Westgate, Matthew"  wrote:

>	The Superfund program pays for sampling and/or any air mitigation systems.

>	I can put property owners on the list of houses to be sampled, but cannot guaranty that it
will be done in time for your closing.

>

	>	Original Message	

>	From: Jennifer E. Constantinou fmailto:ienniferconstantinouOemail.com!

>	Sent: Monday, September 16, 2013 10:22 AM

>	To: Westgate, Matthew

>	Subject: Re: Purchasing home in Sea Girt, NJ - plume inquiry

>

>	Thanks so much, Mr. Westgate. I will find the information for the

>	current owner and circle back with you. Is there a fee associated with

>	the sampling? I will be completing the home inspection within the next

>	week. Jennifer

>

>	Sent from my iPhone

>

>	On Sep 16, 2013, at 10:12 AM, "Westgate, Matthew"  wrote:

>

>> Ms. Constantinou;

>> Yes there are low levels of PCE contamination in the plume at that location. If you
provide the name and phone number of the new owner I can sample the house and install a vapor
remediation system if needed. I wouldn't expect to find much in that area, but only sampling
would provide the precise amount, if any. I sampled 7 houses on Brooklyn Blvd, and none
needed systems.

>>

>> Matthew Westgate, Project Manager/Geologist U.S. EPA Region 2 New

>> Jersey Remediation Branch Southern New Jersey Remediation Section

>> 290 Broadway, 19th floor

» New York, N.Y. 10007-1866

>> (212)637-4422

>> Westsate.matthewfilepa.gov

>>

>>

>>

>>	Original Message	

>> From: Jennifer E. Constantinou
>> rmailto:ienniferconstantinoufilgmail.com!

>> Sent: Monday, September 16, 2013 10:03 AM
>> To: Westgate, Matthew

>> Subject: Re: Purchasing home in Sea Girt, NJ - plume inquiry
>>

l

-------
Thank you! It is 509 Brooklyn Blvd, Sea Girt, NJ.

Sent from my iPhone

On Sep 16, 2013, at 10:02 AM, "Westgate, Matthew" cMestgate.MatthewiSepa.gov> wrote:

>	Ms. Constantinou;

>	Could you please provide me with a specific address?

>	Then I can check your location with respect to the plume.

>

>	Matthew Westgate, Project Manager/Geologist U.S. EPA Region 2 New

>	Jersey Remediation Branch Southern New Jersey Remediation Section

>	290 Broadway, 19th floor

>	New York, N.Y. 10007-1866

>	(212)637-4422

>	Westeate. matthewfSepa. gov

>

>

>

	>	Original Message	

>	From: Jennifer E. Constantinou

>	rmailto:ienniferconstantinou@gmail.com!

>	Sent: Monday, September 16, 2013 9:53 AM

>	To: Westgate, Matthew

>	Subject: Purchasing home in Sea Girt, NJ - plume inquiry

>

>	Good morning, Mr. Westgate - I was wondering if you might be

>	available for a few moments to speak with me. I am an attorney

>	purchasing a home in Sea Girt, NJ oh Brooklyn Avenue and recently

>	learned of the plume/ground water contamination in the town. I've

>	confirmed that the house does not have a well, but wanted to do

>	further diligence on whether I should be concerned with the

>	potential for contamination in the area of the town in which my

>	potential new home will be located. I would very much appreciate if

>	you could shed any light on this issue or point me in the right

>	direction. Thank you so much. Jennifer

>

>	Jennifer E. Constantinou

>	Senior Counsel - Litigation

>	Wyndham Hotel Group

>	22 Sylvan Way

>	Parsippany, ND 07054

>	732-642-3469

>	Jennifer.ConstantinouPwvn.com

>	Jenniferconstantinouflgmail.com

>

>

> Sent from my iPhone

2

-------

Westgate, Matthew

From:	Jennifer E. Constantinou [jenniferconstantinou@gmail.com]

Sent:	Monday, September 16, 2013 10:03 AM

To:	Westgate, Matthew

Subject:	Re: Purchasing home in Sea Girt, NJ - plume inquiry

Thank you! It is 509 Brooklyn Blvd, Sea Girt, NJ.

Sent from my iPhone

On Sep 16, 2013, at 10:02 AM, "Westgate, Matthew"  wrote:

>	Ms. Constantinou;

>	Could you please provide me with a specific address?

>	Then I can check your location with respect to the plume.

>

>	Matthew Westgate, Project Manager/Geologist U.S. EPA Region 2 New

>	Jersey Remediation Branch Southern New [Jersey Remediation Section

>	290 Broadway, 19th floor

>	New York, N.Y. 10007-1866

>	(212)637-4422

>	Westgate.matthewlfflepa.gov

>

>

>

	>	Original Message	

>	From: Jennifer E. Constantinou rmailto:ienniferconstantinou(3gmail.coml

>	Sent: Monday, September 16, 2013 9:53 AM

>	To: Westgate, Matthew

>	Subject: Purchasing home in Sea Girt, NJ - plume inquiry

>

>	Good morning, Mr. Westgate - I was wondering if you might be available for a few moments to
speak with me. I am an attorney purchasing a home in Sea Girt, NJ on Brooklyn Avenue and
recently learned of the plume/ground water contamination in the town. I've confirmed that
the house does not have a well, but wanted to do further diligence on whether I should be
concerned with the potential for contamination in the area of the town in which my potential
new home will be located. I would very much appreciate if you could shed any light on this
issue or point me in the right direction. Thank you so much. Jennifer

>

>	Jennifer E. Constantinou

>	Senior Counsel - Litigation

>	Wyndham Hotel Group

>	22 Sylvan Way

>	Parsippany, NJ 07054

>	732-642-3469

>	Jennifer.ConstantinouOwvn.com

>	Jenniferconstantinoufitemail.com

>

>

> Sent from my iPhone

l

-------
Westgate, Matthew

From:

Sent:

To:

Subject:

Michael Tighe [mjtighe@optimum.net]
Saturday, September 14, 2013 11:09 AM
Westgate, Matthew
White Swan Superfund

Sir,

I am a resident of Sea Girt, New Jersey on New York Blvd., between Third and Fourth Avenues
and have an inground concrete swimming pool in my. back yard. I am considering filling the
pool with water from an underground well on our property. My family including my
grandchildren use the pool.

If I fill this swimming pool form the underground well is there any threat to my family. Is
it safe to do this?

mjt.

l

-------
WestgateJVIatthew

From:

Sent:

To:

Subject:

wendidw@yahoo.com
Saturday, September 14, 2013 9:01 AM
Westgate, Matthew
White swan sun fiasco

Dear Matthew,

I sent an email to you a few weeks ago and have not heard back from you in regard to the
questions I have. If you did not get it please let me know ASAP so I can send my letter
again.

Also, after the public comment period I would like to be contacted as to your decision
regarding the clean-up. As I stated in my first letter, I am opposed to stretching out the
clean-up for 30 years. We need to resolve this issue in the most immediate way to get rid of
these lingering toxins and protect property values in a desirable shore area.

Wendi sheridan

Concerned resident of Sea Girt estates

l

-------
Westgate, Matthew

From:

Sent:

To:

Subject:

Chris Fabian [caf462285@msn.com]
Friday, September 13,2013 5:16 PM
Westgate, Matthew
Air testing

Mr. Westgate,

I live at 2190 Terrace Place, Sea Girt (Wall) and would like to request air quality testing.

Thank you,

Chris Fabian
973-809-9224
caf462285@msn.com

-------
Westgate, Matthew

From:

JOHNPAPCPA@aol.cbm
Friday, September 13, 2013 1:41 PM
Westgate, Matthew

asmrible@njleg.org; asmskean@njleg.org; sensinger@njleg.org;

priya.sundaram@dep.state.nj.us; michael.alemzadeh@dep.state.nj.us; mcjkirk@netzero.com;
mcjkirk@netzero.net

Fwd: from John Papandrea re:public comment White Swan/Sun Cleaners Superfund ...
FederalEPAAugust302013letter.doc

Sent:

To:

Cc:

Subject:
Attachments:

To: Mr. Mathew Westgate
Federal EPA
290 Broadway, 19th floor
New York, NY 10007-1866
September 12, 2013

Dear Mr. Westgate:

As of today, I have not received any answers as requested in my letter attached. I insist on answers

to the following questions pertaining to the White Swan Cleaners/Sun Cleaners Area Groundwater Contamination

Superfund Site:

1. Have you or staff taken soil samples within the wetlands and transitions/buffer area along Judas Creek between the
Manasquan High School Athletic Fields and the Willow Way Homeowners? If so, what were the results? If not, do you
intend on taking the soil samples before construction begins in the aforementioned transition areas of subject Judas
Creek? Since the Manasquan Board of Education is planning on building a retaining wall within these wetlands areas,
including driving pilings approximately thirty feet into the ground, should the core soil samples be taken first, and any
construction postponed, before planned construction begins, in order to test this area for contaminants?

I have asked that my home and property be tested, both soil and air, for contaminats, and have not received a response
back from you. Will you, or will you not, do these test? A Yes or No answer will suffice on this question, but if yes, a date
would be appreciated.

Your prompt response is requested and appreciated.

I am copying my Congressman, Chris Smith on this email.

Sincerly,

John Papandrea
29 Willow Way

Manasquan, New Jersey 08736

(732)528-6014

iohnDapcpa@aol.com

From: JOHNPAPCPA@aol.com
To: westaate.matthew@epa.gov

CC: priva.sundaram@dep.state.ni.us. michael.alemzadeh@dep.state.ni.us
Sent: 8/30/2013 12:47:12 P.M. Eastern Daylight Time

Subj: Fwd: from John Papandrea re:public comment White Swan/Sun Cleaners Superfund ...

l

-------
From: JOHNPAPCPA@aol.com
To: westaate.mathew@eDa.aov

CC: priva.sundaram@dep.state.ni.us. michael.alemzadeh@dep.state.ni.us
Sent: 8/30/2013 12:41:32 P.M. Eastern Daylight Time

Subj: from John Papandrea re:public comment White Swan/Sun Cleaners Superfund Sites
Dear Mr. Westgate:

Input pursuant to the public meeting and corresponding comment period attached for your perusal.

Please feel free to contact me at my address, this email address or telephone number provided in the
attached letter. I have made several requests of your offices which require a response, including testing
my air and soil, as well as the wetlands areas between my Willow Way property and the Manasquan
Board of Education High School Athletic Fields which also border the same wetlands area.

I have copied the NJ DEP on this letter.

Thank you.

John Papandrea
Residential Homeowner
29 Willow Way
Manasquan, NJ 08736

2

-------
id:i;£/zx eon	Il^f iO/0 75" 1^2 f?6}" I & (f 2-

Mr. Mathew Westgate
Federal EPA, Region Two
290 Broadway, 19th floor
New York, NY 10007-1866

John Papandrea
29 Willow Way

Manasquan, NJ 08736
(732)528-6014

August 30, 2013

Dear Mr. Westgate:

I am submitting this letter pursuant to the public meeting that was held on August
27, 2013, and the public comment period ending on September 19, 2013, as my
input with regard to the White Swan/Sun Cleaners area groundwater
contamination superfund site. My entire household including myself is in favor of
GROUNDWATER PLAN ALTERNATIVE 3, for both the Sun and White Swan
sites. Ten years is simply much too long to clean up the Sun site, and could have
serious negative economic consequences to the area. The Sun site is located on
the northwest corner of the Manasquan traffic circle, off said circle, with traffic re
routing either around or through the circle quite feasible. Coordination with the NJ
DOT and Monmouth County certainly is attainable. We do not want this process
extended for ten years.

With respect to the GROUNWATER PLAN, we are in favor of ALTERNATIVE 3
for both sites, In-situ chemical oxidation vapor remediation plan for both sites for
reasons that were discussed at the meeting by other effected residential property
owners which we agree with.

We live on "Judas Creek" just east of the MAC POND site, in the
wetlands/stream area which flows between the Manasquan Board of Education
athletic fields and the homeowners on Willow Way, Manasquan. The creek floods
very badly, flooding having increased in scope over the years for various
reasons, so we are opposed to draining processed water back into Judas Creek,
which could exacerbate the flooding. My neighbor brought this issue up during
the meeting, and our property is directly next to his.

Have your offices taken core soil samples from the wetlands and buffer areas
that exist between the Manasquan High School athletic fields and Willow Way?
Since the Manasquan Board of Education is planning on building a retaining wall
within the wetlands and buffer areas, with pilings, we ask that soil samples be
taken first to weigh the environmental impact and risks if the contaminants are
found to be in those soils, appurtenant to the stream. Driving pilings into the
ground and building a concrete retaining wall could certainly have impact on the
effected areas, including the residential property owners on Willow Way.

-------
I request that if you have not already done so, please take and evaluate the soil
samples within subject wetlands areas.

In closing, I did not receive any postcard advising me of the public meeting.
I request that your offices take soil and air samples from my property as well in
order to test for these contaminants. My wife has developed COPD while living
on Willow Way, and is legally disabled from it. I want to make certain that she
and the rest of my household are safe, and if there is a problem with
contaminants, proper steps will be taken to alleviate the problem.

Please advise accordingly.

CC:NJDEP

29 Willow Way
Manasquan, NJ 08736
(732)528-6014
iohnpapcpa@aol.com

-------
WestcjateJVJatthew

From:

Sent:

To:

Subject:
Attachments:

Bruce P McMoran [bmcmoran@mcmoranlaw.com]

Friday, September 13, 2013 9:57 AM
Westgate, Matthew

White Swan Cleaners/Sun Cleaners Area Groundwater Contamination Superfund Site
DOC.pdf

Dear Mr. Westgate:

Please see my attached correspondence and referenced attachments.
Very truly yours,

BRUCE P. McMORAN
McMoran, O'Connor & Bramley
2399 Highway 34
Building D, Suite D-l
Manasquan, N3 08736
Telephone: (732) 223-7711
Fax: (732) 223-7750

Notice: This e-mail and all attachments are CONFIDENTIAL and intended SOLELY for the
recipients as identified in the "To", "cc", and "bcc" lines of this email. It may contain
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IRS CIRCULAR 230 DISCLOSURE: To ensure compliance with requirements imposed by the IRS and
other taxing authorities, we inform you that any tax advice contained in this communication
(including any attachments) is not intended or written to be used, and cannot be used, for
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DOC.pdf

l

-------
McMORAN, O'CONNOR & BRAMLEY

A PROFESSION AL CORPORATION
COUNSELLORS AT LAW

NEW JERSEY OFFICE

NEW YORK OFFICE

RAMSHORN EXECUTIVE CENTRE
BLDG. D, SUITE D-I
2399 HIGHWAY 34
WALL TOWNSHIP, NEW JERSEY 08736

75 ROCKEFELLER PLAZA
16™ FLOOR
NEW YORK, NEW YORK 10019
(800) 292-6640

(732) 223-7711 FAX: (732) 223-7750

WEB: www.mcmoranlaw.com

REPLY TO:

NEW JERSEY OFFICE

September 13,2013

VIA EMAIL; westgate.matthew@epa.gov

Matthew Weslgate, Project Manager
U.S. Environmental Protection Agency
290 Broadway, 19th Floor
New York, NY 10007-1866

RE: White Swan Cleaners/Sun Cleaners Area Groundwater

Dear Mr. Westgate:

Please accept this letter as my written comments to the EPA's proposed plan
dated August 2013 for the above Superfund Site.

My wife and I reside at 1210 Hemlock Avenue, Sea Girt, NJ 08750. We
purchased the property on February 15, 2007. Despite prior correspondence with your
office in 2007 (see copy attached), the EPA continues to send notifications regarding this
property to the prior owner. See attached copy of post card addressed to Frank Cristell,
which was sent in August 2013 advising us of the public meeting scheduled on August
27,2013. Please correct your files and procedures to ensure that current residents receive
appropriate notification regarding this important subject.

My wife and I, along with a number of other people, attended the EPA meeting on
August 27, 2013 at the Wall Township Municipal Center.

Contamination Superfund Site

As we entered the meeting, we were given a 16-page single spaced handout
regarding the EPA's proposed plan. It would have been very helpful had this been sent to

-------
Matthew Westgate, Project Manager
September 13,2013
Page 2

everyone in advance of the meeting rather than trying to have to read it and digest it
during the time of the meeting.

The August 27, 2013 meeting was essentially an oral presentation of the same
materials contained in the proposed written plan. As far as I or other attendees could tell,
there was no additional information provided at the meeting.

Essentially, the pollution emanated from two drycleaners who operated from
approximately 1960 through 1991. It appears that these two drycleaners, Sun Cleaners,
located in the area of the Route 35/Manasquan traffic circle, and White Swan Cleaners,
located on the north side of Sea Girt Avenue, just east of Route 35, contaminated the soil
through dumping of dry cleaning solvents on or about their properties. This has resulted
in substantial PCE contamination (4,700 lbs) of the soil surrounding the drycleaners and
the groundwater flowing under those properties, and continuing east through Manasquan,
Wall Township and Sea Girt to the ocean. The White Swan contamination continues lo a
depth of 25 feet, which is 10 feet below the water table.

The contamination was originally discovered in the early 1990's by a resident of
Magnolia Avenue in Wall Township. Subsequent sampling identified PCE at levels of up
to 1,500 parts per billion (ppb). I note that the EPA advises that anything exceeding 1
ppb is excessive.

The New Jersey Department of Environmental Protection (NJDEP) requested
EPA's involvement in December of 2001. Since then, the EPA has engaged in sampling
of soil water and air in the area, and has participated in a remedial investigation with
Bank of America, the subsequent owner of the White Swan Cleaners. That investigation
began in August of 2007. By that point, almost 17 years had passed since the first
identification of the problem. The EPA's investigation continues through 2013, or more
than 20 years after the first investigation.

The affected area is an affluent southern Monmouth County suburb, densely
populated with one-family homes. Thus, the adult residents and their children have
remained exposed to this hazard for more than 20 years while the NJDEP and EPA have
been investigating it.

Until the contaminated soil is removed from the White Swan and Sun Cleaners
site, it will continue to leech into the groundwater supply in the area, thus, perpetuating
the problem.

It appears that the purpose of the August 27, 2013 meeting was to sell the local
residents on the choice of alternatives that the EPA evaluated and is recommending.

Contained within that 16-page single spaced document that was handed out on
August 27, 2013 is an analysis of the "Long-Term Effectiveness and Permanence of

McMORAN, O'CONNOR & BRAMLEY

A PROFESSIONAL CORPORATION

-------
Matthew Westgate, Project Manager
September 13,2013
Page 3

the Remedial Alternatives Proposed." In the first sentence, it states, "The highest
degree of permanence and long-term effectiveness is'achieved for those alternatives
that result in (a) the greatest removal of contaminants from the site."

The EPA proposed alternatives for dealing with the soil contaminations are as
follows:

•	Alternative 1 - No Action - Under this alternative, the EPA would take no
action, allowing the soil to remain on-site and continue the contamination for
current residents and generations to come. Clearly, this alternative (or non-
alternative) is unacceptable.

•	Alternative 2 - In-Situ Soil Vapor Extraction/Air Sparching for Sun
Cleaners and White Swan Source Area Soils. Under this alternative, the
EPA would take 10 years and spent $3.6 million to dig extraction wells and
perform other actions to remove the contaminants in the soil. During the 10-
year period, the contaminants would continue to leech into the soil and
groundwater.

•	Alternative 3 - Evacuation & Disposal, of Soils at the Sun Cleaners &
White Swan Cleaners Source Areas. Under this alternative, the
contaminated soil from these two areas would be removed in one-year. This
alternative ends the problem with which the NJDEP, the EPA and the
residents have been dealing with for more than 20 years in a one-year period
at a cost of $8 million.

•	Alternative 4 - In-Situ Soil Vapor Extraction/Air Sparching at the Sun
Cleaners Source Area & Evacuation & Disposal of Soils at the White
Swan Source Area. This alternative is essentially a combination of
alternatives 2 and 3, which would remove and dispose of the White Swan soil
in one year. It would not remove the Sun Cleaners soil but instead have it
treated under Alternative 2 for a 10-year timeframe. The cost of this project is
estimated at $5.4 million.

As noted above, at page 13 of the proposed plan, is a section entitled, "Long-
Term Effectiveness and Permanence." The first sentence under this analysis states,
"The highest degree of permanence and long-term effectiveness is achieved for those
alternatives that result in the greatest removed of contaminants from the site."

It should be obvious to anyone reading proposed alternative 3 and proposed
alternative 4, that alternative 3 results in the removal of all the contaminants in one-year.
Thus, any continuation of the problem in the future is limited to clearing up the
groundwater. There would be no further pollution. Despite the fact that this alternative
meets the goal of long-term .effectiveness and permanence, stated on page 13 of the

McMORAN, O'CONNOR & BRAMLEY

A PROFESSIONAL CORPORATION

-------
Matthew Westgate, Project Manager
September 13, 2013 .

Page 4

analysis, the EPA does not recommend it. Instead, it recommends alternative 4, which
allows the groundwater contamination to continue for the residents for 10 years.

The difference in cost in these two proposals, according to the EPA, is $2.6
million; a minor number considering the potential negative health effects on the residents,
and on property values for home and business owners.

The only defense that the EPA gave to its selection of Alternative 4 over
Alternative 3 was that it could result in disruption of traffic in the area of the Manasquan
circle during the one-year process involving removal of the soil. That interference is not
enough of an inconvenience to not clear up the problem in one year. Indeed, the safety
and health of the population should be put ahead of any potential short-term traffic
dislocations.

Thank you for your altertinn

13PM/pI
Encs.

c: Todd W. Luttman, Mayor, Wall Township

Robert W. Singer, Senate, 30th Legislative District

Assemblyman Sean T. Kean

Assemblyman David Rible

Congressman Chris Smith

Jeff Chiesa, U.S. Senator

Robert Menendez, U.S. Senator

Dan Radel, Editor, Asbury Park Press

Jim Manser, Publisher, The Coast Star

McMORAN, O'CONNOR & BRAMLEY

A PROFESSIONAL CORPORATION

-------
U.S. Environmental Protection Agency
290 Broadway, 26th Floor
New York, NY 10007-1866

FIRST-CLASS MAIL
Postage & Fees

PAID

EPA Permit

Klo. Q-35

Frank Cristelf

1210 Hemlock Avenue

Sea Girt, New Jersey 08750

EPA INVITES YOU TO THE
White Swan Cleaners/Sun Cleaners Area Groundwater
Contamination Superfund Site
Public Meeting

The U.S. Environmental Protection Agency invites you to attend a public meeting to
discuss its Proposed Plan to address contamination at the White Swan Cleaners/Sun
Cleaners Area Groundwater Contamination Superfund Site within Wall Township,
Manasquan, and Sea Girt, New Jersey. The meeting will be held on: August 27. 2013 at
7:00pm At the Wall Township Municipal Center, Main Meeting Room, 2700 Allaire Road,
Wall, New Jersey 07719.

Representatives from EPA will present 4he Proposed Plan to address contamination at the
Site and will also receive formal comments. The comment period for the Site closes on
September 19, 2013. Allwritten comments should be sent to Matthew Westgate, Project
Manager, U.S. EPA. Region 2, 290 Broadway, 19lh Floor, New York, NY 10007 or via
email toWeslgate.Matthew@epa.gov

Copies of the Proposed Plan and the Administrative Record for the Site are available at
the Wall Township Public Library Reference Section located at 2700 Allaire Road, Wall,
NJ 07719 (732)449-8444.

For further information, please contact Cecilia Echols, Community Involvement
Coordinator at 212-637-3678 or toll free at 1-800-346-5009 or visit our website @
http://www.epa.gov/region2/superfund/npl/whiteswan

-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 2
290 BROADWAY
NEW YORK, NEW YORK 10007

January 10,2007

Mr. Bruce McMoran
McMoran, O'Connor & Bramley
Ramshorn Office Center
Bldg D, Suite D-l
2399 Highway 43
Manasquan, NJ 08736

Re: Indoor Air Sample Results for 1210 Hemlock Ave
Dear Mr. McMoran:

The U.S. Environmental Protection Agency (EPA) collected indoor air samples from the
house at 1210 Hemlock Ave on July 24, 2006. The analytical results are reported below in
micrograms per cubic meter (ug/m3) as follows:

Tetrachloroethylene (PCE): 18.99 ug/m3 for indoor air, 210.25 ug/m3for sub-slab air

Trichloroethylene (TCE): 0.19 ug/m3 for indoor air, 1.07 (non-detect) ug/m3 for sub-slab
air.

The results are well below, but approaching the health based level of concern for PCE in
indoor air. The health-based level is 100 ug/m3 or above for PCE in indoor air and 1,000
ug/m3 or above in the sub-slab soil gas. At that level EPA would install an Indoor Air
Ventilation System to reduce the level of PCE in the house. This health based number has
been modified to also take into consideration the concentration of PCE in the soils beneath •
the house. In your clients' case, our decision to continue to monitor the indoor air is based
on the fact that site contamination exists under the sub-slab. I do not have any previous
sample data from 1210 Hemlock Ave, so I cannot determine if the indoor air PCE levels
have increased or decreased in the past few years. As I indicated in the letter to Mr.

Cristell, EPA would like to continue to sample the indoor air in the near future. If you
have any questions concerning this matter, please contact me at (212) 637-4422.

Sincerely,

Matthew Westgate
Project Manager

U.S. Environmental Protection Agency
290 Broadway -19lh floor
New York, N.Y. 100.07-1866
e-mail: Westgate.Matthew@epa.gov

-------
Superfund Program
Proposed Plan

U.S. Environmental Protection Agency,
Region 2

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White Swan Cleaners/Sun Cleaners Area Groundwater
Contamination Superfund Site
August 2013

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EPA ANNOUNCES PROPOSED PLAN

This Proposed Plan identifies the Preferred Alternative
lo address soil and groundwater contamination at the
White Swan/Sun CI tuners Area Grouiuhviiier Superfund
Site (Site) located in Wall Township, Sea Girt and
Manasquan. Vlontnouth County, New Jersey ..and
provides the rationale for this preference. Alternatives
have been developed to address soil and groundwater
contaminated primarily with the dry cleaning chemicals
perehloroethylene (PCE). and its breakdown products
iricliloioeihene (TCE) and eis-l, 2 dichloroethene (cis-
I.2DCI-J).

The U.S. Environmental Protection Agency's (EPA's)
preferred alternative to address soil and groundwater
contamination is Alternative 4 for soils and.Alternative 4
for ijrourulwater. The major elements of the preferred
alternative include:

unoriier response action presented in this Proposed Plan
based oil new information or public comments.

Therefore, the public is encouraged to review and
comment on all the alternatives presented in this
documcnr

fPA is/issuing this Proposed |flan as i^art of Frs community
relations program under Section 117{a) of the
Comprehensive Environmental Response, Compensation,
and Liability Act (CERCLA. commonly known as
Superfund) and Sections 300.430(f) and 300.435(e) of the
National Oil and Hazardous Substances Pollution
Contingency Plan ( NCP). This Proposed Plan summarizes
information that can be found in greater detail in the
Remedial Investigation (RO, Baseline Human Health Risk
Assessment, Feasibility Study (FS.) Reports and other
documents contained in the Administrative Record for the
Site.

•	excavation and off-Site disposal of soils at the
White Swan Cleaners property source area;

•	in-situ soil vapor extraction/air sparging of soils
and shallow groundwater at the Sun Cleaners
property source area;

® construction of a groundwater extraction and
ueutment system to capture and neat the most
highly contaminated groundwater at the -Site;

•	monitored natural attenuation for lesser
contaminated groundwater;

•	osiahlishmeni of a Classification Exemption
Area to prevent exposure to groundwater during
;he remediation', and

•	indoor air monitoring of buildings in close
— - ' ornximity'to'fhe'gfouhdwateredritamina'ti'ori

plume, and installation of vapor mitigation
systems, as necessary.

This Proposed Plan includes summaries of the cleanup
alternatives evaluated for Site soils and groundwater.
This document is issued by EPA, the lead agency for
Site activities, and the New Jersey Department of
Environmental Protection (NJDEP), rhe support agency.
EPA. in consultation with NJDEP, will select the hnal
remedy for the soils and groundwater after reviewing
and considering all information submitted during a 30-
day public comment period. EPA, in consultation with
NJDEP. may modify the preferred alternative or select

\IARK YOUR CALENDAR

PUBLIC COMMENT PERIOD:

August 20, 2013 - September 19, 2013

EPA will accept written comments on the Proposed Plan
during the public comment period.

PUBLIC MEETING: August 27, 2013

EPA will hold a public meeting to explain the Proposed
Plan and all of the alternatives presented in the Feasibility
Study. Oral and written comments will also be accepted at
the meeting. The meeting ¦/will be held in the Wall
Township Municipal Center, Main Meeting room, 2700
Allaire Road, Wall. NJ at 7:00 PM.

"For more information, see the Administrative Record
at the following locations:

U.S. EPA Records Center, Region 2
290 Broadway, 18" Floor
New York, New York 10007-1866
(212) 637-4308

Hours: Monday-Friday - 9 am to 5 p.m., by appointment.

Wall Township Public Library,

Reference Section
2700 Allaire Road
Wall. NJ 07719

Hours: Mon - 10am-9pm, Tues-Thurs - 9 am -9 pm,
Fri -1pm-5pm. Sat - 9am - 5 pm

-------
SITE DESCRIPTION

The White Swan Cleaners/Sun Cleaners Area
Groundwater Contamination Site is an area of soil and
groundwater contaminated with dry cleaning chemicals
and/or their breakdown products in portions of three
municipalities: Wall Township, Manasquan Borough
and Sea Girt Borough, New Jersey. The shallow,
uncoatlned Cohatisey and Kirkwood aquifer was
contaminated by chemicals released at two former dry
cleaning facilities located approximately 0.2 miles apart
along Route 35. The two dry cleaners released the same
volatile organic contaminant, PCE, onto the soil and in
to the shallow permeable sandy aquifer. The White
Swan source area is located at 1322 Sea Girt Avenue and
the Sun. Cleaners source area is located at 2213 Route
35, (aku 201 Manasquan Circle) in Wall Township. The
groundwater contaminant plume extends from these two
source areas to the east and is approximately one mile
wide and two miles long. That plume is bordered by
Route 35 on the west; Hannabrand Brook and Wreck
Pond on the north, Judas Creek and Stockton Lake on
the south and the Atlantic Ocean on the east (see Figure
I). The former Sun Cleaners building on rhe west side
of Manasquan Circle was demolished. The property is
currently!! vacant lot. -The former White Swan building
was used as a branch office lor a local bank and is
currently vacant. Alter the White Swan cleaning
operation ceased, the While Swan properly was used as a
brunch office by a national bank, but the property is now
vacant.

SI TE HISTORY

I he rwo dry cleaners operated from approximately I960
through IWI. In the early 1990s, a resident of Magnolia
Avenue notitied the Monmouth County Health
department (MCIID) that their private irrigation well
contained PC'E. Subsequent sampling identified three
irrigation wells containing PCE at levels up to 1.500
parts per billion (ppb). From 1997 to I99X. MC1ID
sampled-an additional 29 irrigation wells located east of
Route 35. and found extensive I'C'E contamination up'to'
1.100 ppb. Subsequently, approximately 100 irrigation
•.veils were sampled by MOID and the NJDEP and
showed up to 1,648 ppb of PCE.

In 1999. MCKD sampled Hannabrand Brook and Wreck
Pond and found PCE levels ranging from 0.8 ppb to 16
ppb, in excess of the NJDEP Surface Water Quality
Standard of 0.34 ppb for PCE in fresh water. PCE was
not detected in surface water to the south in Mac Pond .
and Stockton Lake. In 2002, PC0 was detected at 5 ppb
in the surface water of Judas Creek near Route 71.
Subsequent surface water sampling in 2003 showed PCE
at levels up to 996 ppb in Judas Creek east of Sea Girt
Mall.

PCE was not detected in the Sea Girt Municipal Wells
initially. However, in late 1999, PCE was detected below
the NJ groundwater quality criteria of 1 ppb at 0.63 ppb in
one of the municipal wells. Sea Girt installed an air
stripper treatment system to remove Volatile Organic
Compounds (VOCs) from the water prior to distribution.

In January 2000. soil samples were collected by NJDEP at
the White Swan property at depths ranging from 3.5 to 6.5
feet below ground surface (bgs). PCE was detected in
samples up to 0.340 parts per million (ppm). Groundwater
samples collected at the time indicated PCE at levels up to
670 ppb, TCE at levels up to 97 ppb and DCE at levels up .
to 25 ppb. NJDEP concluded the White Swan property
was a source of groundwater contamination.

In 2001, NJDEP collected soil samples from (he Sun
Cleaners property which revealed the presence of PCE at
levels up to 1,900.ppm. Groundwater sampling on the
property showed PCE at levels up to 15,500 ppb. These
data confirmed the Sun Cleaners property as a source of
groundwater contamination.

NJDEP determined ihul VOCs in the shallow groundwater
might be volatilizing and entering the unsaturated zone
soils. These vapors could also be impacting the indoor air
quality of buildings in the vicinity of soil and groundwater
contamination. NJDEP collected indoor air samples from
approximately 30 locations and found PCE present in
some of samples. As a result. NJDEP requested EPA's
assistance to evaluate the regional PCE contamination in
December 2001.

lil'A began an investigation of indoor air in late 2001
which included approximately 300 samples from 220
locations. The sampling included homes, schools and
businesses!1 As a result, indoor air ventilations systems,
similar to radon ivpe systems, were installed in A
residences and 2 commercial properties. Additionally,
NJDEP continued to sample and install ventilation
systems in structures with PCE above health based levels
in indoor air. Eventually, a total of 29 buildings received
systems during this phase.' fndoor air sampling "continued ¦
while the remedial investigation was being conducted and
is ongoing.

EPA conducted soil sampling at the White Swan and Sun
Cleaners properties in early 2003. At the White Swan
property, the highest PCE soil concentration derected was
57 ppm located 20 feet bgs. At the Sun Cleaners property
¦ the highest PCE concentration detected was 1,200 ppm,
located 14 feet bgs.

The site was included on the National Priorities List
(NPL) on September 23. 2004.

-------
lieineiliul Investigation

On September 21, 2006, EPA issued Bank of America
(HOA). a potentially responsible party (PRP) for the
Site, an administrative order 011 consent which required
BOA to conduct a remedial investigation and feasibility
siudy. Following review and approval of the planning
documents, the remedial investigation field activities
began in August 2007. The purpose of the investigation
was to determine the nature and extent of contamination
at the Site. After extensive preliminary field screening
investigations, BOA installed over fit) monitoring wells
and piezometers (groundwater sampling sites). They
collected over 500 groundwater samples using
temporary borings. Soil and groundwater samples were
collected and analyzed through 2008, 2009 and 2010.
Most of the Rl field work was completed in 2010.
Subsequent to ihe Held operations, the remedial
investigation report, risk :issessincnt, and feasibility
study were drafted. Concurrent with this work. EPA
performed extensive vapor investigations in and under
structures in proximity to the groundwater contaminant
plume.

SITIi CHARACTERISTICS

!'he Siie is located wiihin the New Jersey Coastal Plain.
In general, the topography of the-area is Hat. The
majority ol'lhe Site contains mixed residential housing
.ind small commercial buildings. There are farms and
woodlands 10 the west and the Atlantic Ocean coast on
the cast.

I'he Site area is underlain by the Cohanscy and
K'irkwood l-'ormations, which consist of unconsolidated,
interbedded sand, silt and clay layers gently dipping
towards the cast. I lic ground surface is mostly medium
grained sand which allows surface water to percolate
down and flow to 1 he east. Approximately 75 feet bgs is
,1 low permeability layer which keeps the groundwater
contamination from going deeper. The top of the water
inble, or saturated /.one. is about 12 to 13 feel bgs. The
regional groundwater How across, the She is, generally
cast towards ihe ocean, but some of the shallow
contaminated groundwater llows northeast into
I lannabrand Brook and Wreck Pond. To the souih,
=ume shallow contaminated groundwater llows souiheast
into Judas Creek and Stockton Lake.

The White Swan facility is located 44 to 47 feet above
mean sea level Irnsl) and ihe ground surface slopes to the
east. Hannabrand Brook is located approximately 1.500
feet northeast of ihe White Swan source area and (lows
eastward into Wreck Pond and the Atlantic Ocean. The
Sun Cleaners property is located approximately 1,200
feet to Ihe southwest of the White Swan property at an
elevation of 46 to 51 feel above msl. Surface water

from the west of tlve Sun Cleaners property flows east into
an intermittent stream called Judas Creek, then into Mac
Pond and eventually to Stockton Lake and finally, the
ocean.

The contaminants of concern (CoCs) ai the Site include
PCE and its associated breakdown products. TCI: and eis-
l. 2-DCE. PCE, TCE and DCE contamination from both
source areas is dissolved in groundwater. The
contaminated groundwater from ihe separate sources
llows east and meets near Old Mill Road between
Magnolia Ave and Sea Girt Ave. The combined
groundwater contamination continues to migrate east,
northeast and souiheast towards the Atlantic Ocean. The
northern boundary of the contaminant plume is
Hannabrand Brook and Wreck Pond. The southern
boundary is Judas Creek. Mac Pond and Stockton Lake.
The extent of the contaminant plume is approximately one
mile wide (north to south) and two miles long (west to
east) (see Kigure I).

The groundwater contaminant plume is underlying an area
of dense residential and commercial development. I'he
lowns impacted by ihe Site's groundwater plume provide
residents with a public water supply system. Pre-existing
wells within the area of ilie Site's groundwater
contaminant plume are used for non-potable purposes,
mainly irrigation.

The nearest municipal wells 10 ihe source areas are
operated by Sea Ciirt, and are located about ft.000 leel cast
Idowngradient) of the Site's source areas. The wells draw
water Iroin depths of 123 feet, 129 feet and 715 feel below .
ihe ground surface. I'he Borough of Sea (iirt installed an
air stripper al'ier detecting PCE'at 0.63 ppb 1 below ihe NJ
(.iroundwatfer Quality Standard) in I'W. hvqucnt
sampling is performed to assure iliat all drinking water
>landards are met.

White Swan Soils

In 2001. the PRP excavated the septic tank, associated
piping and associated contaminated soil from the White

	Swan property, parking-lot, Approximately 20 ions of soil •

were excavated and transported off--Site to a licensed
facility for disposal. However, significant soil
contamination remains at the property, to a depth of 25
feet bgs, which is 10 feet below ihe water table. During
the R[, in 200S. a total of 52 samples were collected from
13 borings. In 2009, 16 additional subsurface soil samples
were collected from 10 additional borings. Soil samples
from the unsaturated zone below the asphalt pavement at
the White Swan property showed PCE contamination at
levels ranging from 1 ppin lo a maximum of 160 ppm at a
depth of 0-7 feet bgs. and up to a maximum of 2X.000
ppm at 17 -25 feet bgs (below ihe water table). PCE mass
in the soil al ihe White Swan property is estimated to be
approximately 4.360 pounds. Maximum TCE and cis-l.

-------
2, DCE levels on the property are 32 ppm and 37 ppm
respectively.

Sun Cleaners Soils

At the Sun Cleaners property, a total of 48 subsurface
soil samples lrom 13 soil borings were collected in 2008.
PCE contamination in the unsaturated zone soils at the
Sun Cleaners property was found to be as high as 51
ppm (at a depth of 6 to 13 feet bgs) with a total .PCE soil
mass of approximately 140 pounds. Ihe maximum TCE
level was 3.8 ppm and the maximum cis-1, 2. DCE level
was 31 ppm.

Surface Water and Sediments

NJDEP surface water samples from 2003 showed levels
of PCE at W6 ppb in Judas Creek east of the Foodtown
Mall near Sea Girt Ave. These levels were above the NJ
surface water quality standard of 0.34 ppb in fresh water.
In 2008, R.I surface water samples collected 500 feet
downgradient showed significantly lower levels of PCE
at 31 ppb, 13 ppb, fi.3 ppb, 4.1 ppb, 12 ppb and 13 ppb
between Mac Pond and Stockton Lake.

Judas Creek'sediment samples showed PCE al 4.4 ppm
near Manasquan High School and 0.7() ppm and 0.S 1
ppm near Route 71. These are above the site specific
NJDEP ecological screening criteria of .45 ppm for
sediments.

In 2000. in Hannabrand Brook. NJDEP found PCE at I
ppb in surface water near St. Catharine's Cemetery and 2
ppb in Wreck Pond. During the KI. PCE was found at
I. I ppb in the unnamed tributary surface water that feeds
into Hannabrand Brook and up to 5M ppb in the surface
water of Hannabrand Brook itself. Wreck Pond surface
water showed PCE levels up 10 0.25 ppb i estimated) at
the Route 71 Bridge.

PCE was found at 0.21 ppm in the Hannabrand Brook
sediments near St. Catharine's Cemetery. Sediments in
the unnamed tributary hud PCE levels as high as 1.8
ppm and 4.1 ppm (estimated) in Hannabrand Brook.

< iruundwuter

The Site's groundwater plume is contaminated with PCE
it levels ranging from 1 ppb to 75,000 ppb, and
continues to migrate from the two source areas located1
near Route 35 eastward to the Atlantic Ocean,
approximately 2 miles away. The plume extends from
the water table at the source areas to a depth of
approximately 70 feet bgs, where a low permeability
layer extends across much of the site. The
contamination does not extend to the north of
Hannabrand Brook or Wreck Pond, and generally not
south of Judas Creek and Stockton Lake.

at the White Swan property and 61,000 ppb at the Sun
Cleaners property.

There are two areas of the plume, in close proximity and
downgradient of the two source areas which generally
contain the highest levels of groundwater contamination.
These two areas are referred to as the Near Field areas and
generally contain concentrations of PCE over 1,000 ppb.
The Near Field areas include groundwater underlying the
Sun Cleaners property and extending over 1,000 feet
downgradient, and groundwater underlying the White
Swan property and extending approximately 700 feet
downgradient. The remainder of the groundwater plume is
referred to as the Far Field. The Far Field area of
groundwater contamination generally includes areas
where PCE has been detected between the levels of I ppb
and 1.000 ppb. However, within the large Far Field area,
there are a number of "hot spots." which are smaller
localized areas of PCE contamination that range from 500
ppb up to 3,100 ppb. The PCE contamination within the
groundwater generally sinks deeper as it proceeds to the
east, but was not found below the low permeability zone
around 75 feet bgs.

Indoor Air

In ihe vicinity of the shallow groundwater contamination,
VOCs may escape or volatilize from the groundwater and
permeate the unsaturated zone soils. This vapor can
penetrate basement walls and floors in occupied
dwellings. EPA has sampled ihe sub-slab air and/or
indoor air of over 400 residences and commercial
buildings in order to evaluate ihis exposure pathway and
will continue to sample buildings in the vicinity of the
contamination to assess the potential risk to occupants.
The highest level of PCE vapor in sub-slub air was found
to be 9.500 ug/m' below a residence near Christie Lane
and Sea Girt Ave. To daie. thirty-lour indoor air
ventilation systems have been installed hy EPA in
buildings where indoor air PCE levels exceeded health
based levels. The systems are designed to vent vapors
from beneath the foundation, thereby preventing vapors
from entering the building. These systems are monitored
to ensure they are performing-properly. Sampling of
residences and buildings overlying the groundwater plume
will continue. Additional indoor air ventilation systems
will be installed, as needed, to prevent unacceptable risks
to occupants of buildings.

During ihe RJ. PCE was found as high as 75.000 ppb

4

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WHA'l' IS A "PRINCIPAL THREAT"?

The NCP establishes an expectation that EPA will use
treatment to address the principal threats posed by a site
wherever practicable,(NCP Section 300.430(a) (I) (iii)
(A)). The "principal threat" concept is applied to the
characterization of "source materials" at a Superfund
site. A source material is material that includes or
contains hazardous substances, pollutants or
contaminants that act as.a reservoir for migration of
contamination to ground water, surface water or air. or
acts us a source for direct exposure. Contaminated
ground water generally is not considered to be a source
material;.however. Non-Aqueous Phase Liquids
(NAl'(.s) in ground water may be viewed as source
material. Principal threat wastes are those source
materials considered to be highly toxic or highly mobile
that generally cannot be reliably contained, or would
present a significant risk lo human health or the
environment should exposure occur. The decision to
treat these wastes is made on a site-specific basis
through a detailed analysis of the alternatives using the
nine remedy selection criteria This analysis provides a
basis lor making a statutory finding that the remedy
employs treatment as a principal element.

PRINCIPAL THREATS

flu's Proposed Plan addresses soil contamination at both
PCE source areas identified at the Site. These soils are
considered principal threat wastes. Addressing these
coiiiainiuaied soils will have a positive impact on the
planned groundwater remediation, as lliey are an
untioiiiLr source of "round-water contamination at the

D —	-9

Site.

SCOPE AND ROLE OK TIIE ACTION

I-PA is addressing the cleanup of this Site through one
phase, or operable unit of long-term cleanup, addressing
ijje source area soils, sediment, groundwater
.eoniainination..and indoocait contamination.	

RISK SUMMARY

I'he purpose of the risk assessment is to identify
potential cancer risks and noncancer health hazards at
the site assuming that no further remedial action is taken.
A baseline human health risk assessment was performed
to evaluate current and future cancer risks and noncancer
health hazards based on the results of the remedial
investigation.

A screening-level ecological risk assessment was also
conducted to assess the risk posed lo ecological
receptors due to site-related contamination.

Human Health Risk Assessment

As part of the RI/FS. a baseline human health risk
assessment was conducted to estimate the risks and
hazards associated with the current and future effects of
contaminants on human health and the environment. A
baseline human health risk assessment is an analysis of the
potential adverse human health effects caused by
hazardous-substance exposure in the absence of any
actions to control or mitigate these under current and
future land uses.

A four-step human health risk assessment process was
used for assessing site-related cancer risks and noncancer
health hazards. The four-step process is comprised of".
ILuard Identification of Chemicals of Potential Concern
(COPCs), Exposure Assessment, Toxicity Assessment,
and Risk Characterization (see adjoining box ""What is
Risk and How is it Calculated").

The baseline human health risk assessment began with
selecting COPCs in the various media (i.e., soil,
groundwater, surface water, and scdimentj that could
'potentially cause adverse health effects in exposed
populations. The current and future land use scenarios
included the following exposure pathways mid
populations:

» Construction Worker, current/future ingestion, dermal
contact and inhalation of surface and subsurface soil
and future inhalation of outdoor and indoor vapors lor
adults

•	Utility Workers: current/future ingestion, dermal
contact and inhalation of surface and subsurface soil
lor adults

•	Residents: current/future ingestion and dermal contact.
of surface soil, current ingestion, dermal contact and
inhalation of groundwater from lawn watering and
swimming pools, current inhalation of air from
outdoor and indoor vapors, and future ingestion,
dermal contact and inhalation o.f groundwater for
adults and children

•	Transient Visitors: current/future ingestion and dermal
contact of surface soil, current/future ingestion,
dermal contact and inhalation of surface water and
sediment from Wreck Pond. Hannabrand Brook and
Judas Creek, which includes Mac Pond and Stockton
Lake, and current future consumption of lish and
crabs from Wreck Pond for adults, teens (age 12-17).
older children (age 7-11) and children (age 0-6)

•	Commercial Customers: current inhalation of air from
outdoor and indoor vapors for adults, adolescents and
children

5

-------
• Commercial Workers: current inhalation of air from
outdoor and indoor vapors for adults

In this assessment, exposure point concentrations were
estimated using either the maximum detected
concentration of a contaminant or'the V>5% upper-
confidence limit (UCL) of rhe-average concentration.
Chronic daily intakes were calculated based on the
reasonable maximum exposure (RME), which is the
highest exposure reasonably anticipated to occur at the
site. The RME is intended to estimate a conservative
exposure scenario that is still within the range of
possible exposures. Central tendency exposure (CTE)
assumptions, which represent typical average exposures,
w ere also developed. A complete summary of all
exposure scenarios can be found in the baseline human
health risk assessment.

Surface Soil

Risks und hazards were evaluated for current and future
exposure to surface soil at both source areas. The
populations of interest included adult construction and
utility workers. "Hie cancer risks for both receptor
populations evaluated were within or below the '
acceptable EPA risk range of 1.0F.-06 to I.UE-04. Hie
hazard index for construction workers and utility
workers were below (he EPA acceptable value of 1.
There were no contaminants of concern. (COCs)
identified for soil (Table 1).

Table 1. Summary of hazards and risks associated with
surface soil.

Receptor

Hazard
Index

Cancer Risk

Utility Worker - Adult

0.16

2E-06

There were no COCs identified in the subsurface soil.

Receptor

1 lazard
1 ndcx

Cancer Risk

(. on.slmction Worker -• Adult

0.17

1 E-Oft

I .'tilitv Worker - Adult

0.17

:i.:-t)5

1 here were no COCs identified in the surface soil.

Subsurface Suit

Risks and hazards were evaluated for the potential
current and future exposure to subsurface soil. 'The
population of interest included adult construction and
utilicv workers: The'subsurface soil, identified as 2-10"
feet below ground surface, was evaluated for
construction workers and the cancer risk and non-cancer
hazards were within or below EPA criteria.

Both the cancer risk and hazard indices were below or
within the EPA' acceptable values and ranges. There
were no COCs identified in the subsurface soil (Table 2).

I'uble 2. Summary of hazards and risks associated with
subsurface soil.

Groundwater

Risks and hazards were evaluated for current and liiture
exposure to groundwater from irrigation wells and private
wells. The populations of interest included adult and child
residents. The.cancer risk for the use of the irrigation
wells for both the adult and child residents were within the
acceptable EPA risk range of 1.0E-06 to 1.0E-04. The
hazard indexes for use of the irrigation wells for both adult
and child resident were below the EPA acceptable value
of i. The cancer risks and hazard indices for future use of
the groundwater for drinking exceed the acceptable I-PA.
risk ranges and hazard value for both the adult and the
child. The COCs that were identified for groundwater
include four VOCs (Table 3).

Table 3. Summary of hazards and risks associated with
groundwater.

Receptor

Hazard
Index

Cancer Risk

Irrigation Wells - Adult

0.13

1E-04

Irrigation Wells - Child

0.51

1 E-04

Swimming Pools - Adult

0.14

1 E-04

Swimming Pools - Child.

0.17

.511-05.

Tap Water (Shallow) - Adult

30

-IE-02

Tap Water (Shallow) - Child

87

7E-02

Tap Water (Deep) -- Adult

7.5

1 E-04

I'np Water (Deep) - Child

18

7E-05

COCs include: ictrachlorelhylene (PCfi),
irichlorocthylene (1'CE), ei.s-1.2-dichlorocthylcne, and
vinvl chloride

| Receptor

Hazard
Index

Cancer Risk

! Construction Worker - Adult

0.1 fi

3F--05

Surface Water and Sediment

Risks and hazards were evaluated for current and future
exposure to surface water and sediment from Wreck Pond,
i lannabrand Brook, and Judas Creek, which includes Mac

Pond-and Stockton* Lake-'The populations of interest	

included adult, teen, older child, and child transient
v isitors for Wreck Pond and teen and older child transient
visitors for Hannabrand Brook and Judas Creek. The
cancer risks and hazard indices for all of the populations
evaluated were below or within the EPA acceptable
values. I'here were no COCs identified for surface water
or sediment (Table 4). Since there, were no COCs
identified for surface water or sediment, the ingestion of
biota from Wreck Pond was considered to be an
incomplete pathway.

Table 4. Summary of hazards and risks associated .with
surface water and, sediment.

-------
Receptor

Hazard Index

Cancer
Risk

Snr/itce Water - Wreck Pnnd

Transient Visitor - Adult

0.0024

5E-U8

Transient Visitor - Teen

0.01

5E-08

Transient Visitor - Older
Child

0.022 ¦

i

IE-07 i

Transient Visitor - Child

0.0059

3E-08

Sur/ciCe Water - Huiifiuhruiul Brook

Transient Visitor- feen

0.022

2E-07

Transient Visitor - Older
Child

0.040

2E-07

Surface Water - Judus Creek

Transient Visitor - Teen

D.0IS

3E-05

Transient Visitor - Older
Child

0.035

4E-05

Sediment - Wreck Pond

Transient Visitor - Adult

0.00031

5E-08

Transient Visitor - Teen

0.001 A

fiE-O.X

Transient Visitor - Older
Child

0.0017

5E-08

Transient Visitor - Child

n.00072

3E-0S

Sediment - liumtuhmnd Hmuk

Transient Visitor - Teen

0.0056

:t:-06

i Transient Visitor - Older
j Child

0.012

2R-0A

! Sediment ¦¦¦ Hannuhrund Brook

| Transient Visitor - 'Teen

0.007,S

21'-DA

j Transient Visitor ~ Older
! Child

U.0IJ.X2

2E-06

| lliere were no C.'OCs identified in the surface water or
! im en r.

I'll pots

Hie potential for vaporintrusion into a building's indoor
air is being addressed through an ongoing EPA sampling
program. I he investigation includes collection and
analysis of sub-slab soil gas samples, and indoor air .
¦samples in structures overlying ihe groundwater
contaminant plume. Levels of contaminants are
compared to health-based standards for each structure.
Where hcuhh-bused standards are exceeded, vapor
mitigation systems have been installed. Sampling is
.ingoing throughout the area overlying the plume; and
additional indoor air ventilation systems will be
installed, as needed, to prevent unacceptable risk to
occupants of buildings. Therefore, a quantitative risk
.malysis was not needed.

The evaluation of potential outdoor vapor exposure to
residents, commercial customers, commercial workers
and construction workers indicated that the pathway was
incomplete. Therefore, a quantitative analysis was not
needed.

It is f-.P.Vs current judgment that although the risks

associated with soil exposure are within or below CPA's
acceptable values, the soil concentrations of PCE and TCE
are above concentrations that are associated with an
adverse impact to groundwater, thus there is a need to
address the soil through a remedial action.

Based on the results of the human health risk assessment,
a remedial action is necessary to protect human health
from actual or threatened releases of hazardous substances
in groundwater.

Ecological Risk Assessment
A screening-level ecological risk, assessment was
conducted to evaluate the potential for ecological risks
from the presence of elevated VOCs in ground water that
discharges to surface water and sediments associated with
the Judas Creek and Hitnnabrand Brook stream systems.
The SLERA focused on evaluating the potential for
impacts to sensitive ecological receptors to site-related
constituents of concern through exposure to surface water
and sediment from Wreck Pond, llannabrand Brook, and
Judas Creek, which includes Mae Pond and .Stockton
Lake. Surface water and sediment concentrations were
compared to ecological screening values as an indicator of .
the potential for adverse effects to ecological receptors for
each water body system. A complete summary of all
exposure scenarios can be found in the screening level
ecological risk assessment I SI.ERA).

llannabrand lirtiok System: There is a potential for
adverse effects to fish and aquatic invertebrates from
exposure to contaminated groundwater that is discharging
to I lannabrand Hrook. The sediment screening criteria
were exceeded lor PCE in three locations, resulting in
hazard indices tills) of 4.1. I.K and 0.7, two of which are
above the acceptable value of I- The' l'C.Ti detections in
the sediment are considered to be site-related. The surface
water screening criteria was not exceeded for l lannabrand
13 rook.

¦Indus Creek System: There is a potential for adverse
effects to aquatic lish and invertebrates from exposure to
contaminated groundwater that may be discharging to
Judas Creek. The sediment screening criteria were
exceeded for PCE in two locations, resulting in His of 4.4
and I .8, which are above the acceptable value of 11 The
PCE detections in the sediment may be associated with
runoff from an industrial area instead of groundwater
discharge. The surface water-screening criteria was not
exceeded for Judas Creek.

Based on the results of the ecological risk assessment, a
remedial action is necessary to protect the environment
from actual or threatened releases of hazardous
substances, which includes the discharge ot'contaminated
groundwater into surface water bodies at the Site.

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WHAT IS RISK AND HOW IS IT
CALCULATED?

A Superfund baseline human health risk assessment is an
analysis of the potential adverse health effects caused by
hazardous substance releases from a site in the absence of
any actions to control or mitigate these under current- and
future-land uses. A four-step process is utilized for assessing
site-related human health risks for reasonable maximum
exposure scenarios.

Hazard Identification: In this step, the contaminants of
concern at the site in various media (i.e., soil, groundwater,
surface water, and air) are identified based on such factors
as toxicity, frequency of occurrence, and fate and transport
of the contaminants in the environment, concentrations of the'
contaminants in specific media, mobility, persistence, and
bioaccurnulation.

Exposure Assessment: In this step, the different exposure
pathways through which people might be exposed to the
contaminants identified in the previous step are evaluated.
Examples of exposure pathways include incidental ingestion
of and dermal contact with contaminated soil. Factors
relating to the exposure assessment include, but are not
limited to, the concentrations that people might be exposed
to and the potential frequency and duration of exposure.
Using these factors, a "reasonable - maximum exposure"
scenario, which portrays the highest level of human
exposure that could reasonably be expected to occur, is
calculated.

Toxicity Assessment: In this step, the types of adverse health
effects associated with chemical exposures, and the
relationship between magnitude of exposure (dose) and
severity of adverse effects (response) ara determined.
Potential health effects are chemical-specific and may
include the risk of developing cancer over a lifetime or other
non-cancer health effects, such as changes in Ihe normal
functions of organs within the body (e.g., changes in Ihe
effectiveness of the immune system). Some chemicals are
-apable of causing both cancer and non-cancer health
effects.

Risk Characterization: This step summarizes and combines
exposure information and toxicity assessments to provide a
quantitative assessment of site risks. Exposures are
evaluated based on the potential risk of developing cancer
and the potential for noncancer health hazards. The
likelihood of arv individual, developing'cancer I expressed a?.,
a probability. For example, a 10 cancer risk means a
"bne-in-ten-thousand excess cancer risk"; or one additional
cancer may be seen in a population of 10,000 people as a
result of exposure to site contaminants under the conditions
explained in the Exposure Assessment. Current Superfund
guidelines for acceptable exposures are an individual lifetime
excess cancer risk in the range of 10"1 to 10'6 (corresponding
to a one-in-ten-thousand- to a one-in-a-million excess cancer
risk). For noncancer health effects, a "hazard index" (HI) is
calculated. An HI represents the sum of the individual
exposure levels compared to their corresponding reference
doses. The key concept for a noncancer HI is that a
"threshold level" (measured as an HI of less than 1) exists
below which noncancer health effects are not expected to
occur.

REMEDIAL ACTION OBJECTIVES

Remedial action objectives (RAOs) were developed for
soils and groundwater to address the human health risks
and environmental concerns posed by Site-related
contamination.

RAOs:

•	Prevent or minimize current and future human
exposures, including ingestion of groundwater
and/or inhalation of vapors, from Site-related
VOCs in groundwater that present a risk to public
health and (he environment;

•	Prevent or minimize migration of Site-related soil
contamination to groundwater;

•	Restoration of the Site groundwater to meet
drinking water standards within a reasonable time
frame: and

•	Prevent or minimize the migration of Site-related
contaminated groundwater to surface water and
sediment that presents a risk to the environment.

To achieve RAOs, dcunup goals for soils at ihe Site were
developed. Soil cleanup standards thai will be protective
of groundwater were developed by using the SESOIL
model. The cleanup goal calculated through the model is
1 ppm for PCE in soils. It is believed that remediation of
Site soils to this standard will address all Site-related
contaminants.

file remediation goals selected for the groundwater are
hased on groundwater applicable or relevant and
appropriate requirements (ARARsI lor this Site, which
include the federal and srate MCLs. and NJDEP
Groundwater Quality Criteria (GWQC). The Site
groundwater remediation goals are the most conservative
of the above erireria. The remediation goals selected for
the primary..contamiaanrs.of.concerns auhis-Site-are-1 pp.b~-
lor PCE and 1 ppb for TCE. which are the slate CAVQC.

SUMMARY OF REMEDIAL ALTERNATIVES

Potential applicable technologies were identified in the FS
prepared for this Site. These technologies were initially
screened based on effectiveness, implementability and
cost as criteria. Those technologies that passed initial
screening were then assembled into four remedial
alternatives for soil and four remedial alternatives for
groundwater.

All of the alternatives, wilh the exception of the No
Action alternative, would include the ongoing

-------
s

investigation and remediation, as appropriate, of indoor
air containing elevated levels of VOCs in structures
overlying the groundwater contaminant plume.

Sampling of indoor and sub-slab air would continue.
Individual vapor mitigation systems would be installed
at each structure determined to have elevated levels of
VOCs in indoor air. ami systems installed previous to the
remedy selection would be maintained.

In the process of de veloping groundwater remedial
alternatives for ihe Site, a number of groundwater
extraction ;md treatment scenarios that would address
varying portions of groundwater contamination in the
Far Field area were evaluated, but screened out.
l-xlensive extraction and treatment of groundwater
throughout the l:ar Field area, was shown through
modeling as not likely to he highly effective. Extraction
of groundwater throughout rhe Far Field area would be
highly disruptive 10 the community, expensive and
would not significantly decrease the overall cleanup time
frame compared to the alternatives that were developed
which rely on active treatment in the Near Field areas
:md allow Far Field contamination to attenuate.

All of ihe groundwater remedial alternatives,, with the
exception of ihe No Action Alternative, would include
i he establishment of a Classification Exception Area
iCLiA) in accordance with slate regulations ro minimize
the potential exposure to contaminated groundwater until
the groundwater meets the remediation goals. However,
consistent with expectations set out iri Superfund
regulations, none of the alternatives rely exclusively on
institutional controls to achieve protectiveness.

All ol'the groundwater remedial alternatives, with the
exception of the No Action Alternative, would rely in
part on monitored natural attenuation (V1NA) to restore
the lesser contaminated portions of the groundwater
contaminant plume ro drinking water standards. Willi
the performance of an active remediation of ihe most
contaminated yroundwater in the Near Field, modeling
has shown that Far. Field groundwater would be-restored-
to dnnkinu water standards in a much shorter time frame
:han without remediation (roughly 70 years vs. 400
years). Ihe implementation of VINA requires long-term
monitoring of contaminants as. they naturally attenuate
through dilution, dispersion, adsorption, volatilization
•jiid/or biodegradation, until groundwater returns
naturally to concentrations below the remediation goals.
Fhese processes are expected to be effective at this Site
in areas of lesser groundwater contamination in
conjunction with active treatment in the areas of higher
contaminaiion. In the Far Field area, due to the aerobic
nature of ihe Site aquifer, dispersion and dilution are
likely to be the predominant forms of natural
attenuation. In addition, since 2000. decreasing

contamination concentrations have been observed near the
source areas. EPA believes this dilution trend will
continue in this very prolific, uncontined aquifer, in which
groundwater migrates at approximately one foot per day.
Based on preliminary modeling, ir is expected that, in
conjunction with active treatment in the Near Field areas,
the estimated natural attenuation time frame in the Far
Field areas is approximately 50 to 70 years. The MNA
portion of each groundwater alternative listed below (with
ihe exception of the No Action alternative), would include
the installation and sampling of an estimated nine clusters
of monitoring wells, in addition lo surface water and
sediment sampling in the water bodies bounding the Site's
groundwater plume. The exact sampling frequency and
protocol would be established during the remedial design
(RD) phase of the cleanup.

For the groundwater alternatives, EPA chose to actively
address groundwater above 1,000 ppb of PCE based on
modeling which showed active treatment of areas of lower
concentrations.(100, 150. 200 and 250 ppb) would not
appreciably speed up ihe groundwater cleanup time.

I he time frames presented helow for construction do not
include the lime necessary for pre-design investigations,
remedial .design, ur contract procurements. Each of the
groundwater alternatives will take longer than five years
to achieve remediation goals. Therefore, a five-year
review will be conducted every live years after the
initiation of the remedial action, until remediation goals
are achieved.

Consistent with El'A Region Ts Clean and (ircen policy,
l-.FA will evaluate the use of sustainable technologies and
practices with respect to any remedial alternatives selected
for I his Site.

A brief summary ol'the remedial alternatives developed
for I lie Site is provided below. More detailed descriptions
of the remedial alternatives can be found in the FS report.

Alternatives for Soil Source Areas

Alternative I - .No Action

The N'o Action Alternative was retained, as required by
the National Contingency Plan (NC'Pl, and provides a
baseline for comparison with other alternatives. No
remedial actions would be implemented as part of the No
Action Alternative. Furthermore, this alternative would-
not involve any monitoring of groundwater or institutional
controls. Contaminants in the soil would continue to
migrate into the groundwater, and VOC contaminaiion
would continue to migrate with groundwater
downgradient. In. addition, vapor phase contamination
would continue to migrate into the indoor air of some
structures overlying the plume.

-------
Total Capital Cost	ISO

Operation and Maintenance	SO

Total Present Net Worth	SO

Time frame	N/A

Alternative 2 - In-Situ Soil Vapor Extraction/Air
Sparging for Sun Cleaners and White Swan Source
Area Soils

Alternative 2 includes the in-situ vapor extraction
llSVEl and air sparging (AS) of soil and shallow ground
water in the two soil source areas. This alternative
would involve the injection of air into the subsurface
groundwater, enabling a phase transfer of VOCs froin a
dissolved state to the vapor phase. The contaminated air
enters the unsaturated, contaminated soils, where a SVE
•ivstem creates a negative pressure through a series of
extraction wells. The extraction wells are used to collect
ihe contaminated air, which is then treated to remove
contaminants through the use of catalytic oxidizers or
granular activated carbon (GAC). BOA has proposed
that this alternative include the use of a series of
recirculating groundwater remediation wells (RGRWs),
which would apply the saine principals as explained
•ihove. but would provide for both air sparging and ISVE
lo be implemented within well casings of a .series of
wells. Specific details of the implementation of this
technology would be determined during the RD phase.

Active operation of the ISVE/AS system may be
intermittent over the estimated 10 year time frame to
.ichieve goals.

Total Capital Cost	SI..X million

i )perarinn & Maintenance SI.X million
I'mal Present Net Worth S3.A million
Time frame	10 yours

Alternative J -Excavation and Disposal of Soils at the
Sun Cleaners and White Swan Source Areas

« Alternative.J. would- include excavation, removal, and -
otf-site treatment and/or disposal of all soil containing
mure than I ppm of PCE from the White Swan and Sun
Cleaners source areas. There are approximately 5,100
cubic yards of soils exceeding the cleanup criteria at the
White Swan property and approximately 9,600 cubic
yards at the Sun Cleaners property. Treatment or
disposal would occur at RCRA-permitred facilities in
accordance with regulatory requirements for these soils.
Excavation would be accomplished with commonly used
construction equipment, by methods widely used for
impacted soiJs in cases where the soil contamination is
relatively shallow, less than 25 feet below ground
surface. Sheet piling and de-watering would be required
js excavation would 
-------
actions would be implemented. Furthermore, this
alternative would not involve any monitoring of
groundwater or iiisiituttonal'controls. Contaminants in
the groundwater would continue to migrate uncontrolled.

Total Capital Cost	SO

Operation and Maintenance	SO

Total Present Net Worth	SO

Time lVame	N/A

Alternative 2 -In-Situ Vapor Extraction and Air
Spurging/M'NA/ICs/'Vapor tic-mediation

This alternative would treat contaminated groundwater
in-situ in the Near l-'ield areas, which generally contain
I'CE levels of greater than 1,000 ppb, through the use of
the ISVE/AS technologies. ISVE/AS in the Ne-ar Field
.ireas of highest groundwater contamination would
involve the injection of air into the subsurface
groundwater, enabling a phase transfer of VOCs from a
dissolved state to the vapor phase. The contaminated air
enters the unsaturated soils, where a SVE system creates
a negative pressure through a series of extraction wells.
I'he extraction wells are used to collect the contaminated
:ur. which is then treated to remove contaminants
ihrougl) the use of catalytic oxidizers or CJAC. L30A has
proposed that this alternative he implemented through
i he use of a series of RGRWs. which would apply (he
^ime principals as explained above, but would provide
lor hoth air sparging and ISVF to be implemented within
•.veil casings of a series of wells. Speci lie details of the
implementation of this technology would be determined
¦ luring the RD phase of the project.

I hiring the KD. an evaluation of individual Far f ield
•hot spots" for treatment through the ISVE/AS
;ochnology would he performed to assess the
effectiveness of treatment.

MNA would he implemented in the Far Field portion of
ihe groundwater contaminant plume, concurrent with
ISVI:/AS in the Near Field areas. Attenuation processes
lor VOCs in groundwater would be closely monitored
concurrent with other aspects of the selected remedy. In
addition, surface water and sediment sampling and
analysis would be included in the long-term monitoring
plan.

would be installed and maintained. In addition, systems
already installed at the Site would be maintained until the
groundwater is remediated.

Total Capital Cost
Operation and Maintenance
Total Present Net Worth
Time frame (ISVE/AS)

Pull Groundwater Restoration

S5.4 million
$5.4 million
IS 10.8 million
10 years

Appro*. 70 years

Alternative 3 - In-Situ Chemical Oxidation
(ISCO)/MN.VICs/Vapor Remediation

ISCO would involve injecting an oxidant or oxidant
releasing compound into wells located within ihe most
highly contaminated groundwater, generally containing
I'CE at levels of greater than 1.000 ppb in the Near Field
areas. The oxidant would.mix with ihe contaminants, and
cause them to decompose. When ihe process is complete,
only water and innocuous breakdown products would he
left in ihe treated area. Monitoring would be required to
determine the effectiveness of the treatment.

Although final details of the implementation of this
alternative would be developed in the KD phase, for
costing purposes, it was assumed that sodium
permanganate would be the oxidant of choice. Lines of
injection well clusters would he installed perpendicular to.
groundwater How. Each cluster would he comprised of
[hree wells installed to different depths., ft is estimated
that the implementation of this alternative would require
ihe installation of approximately 40 injection well clusters
near and downgradient of the Sun Cleaners source area
and 14 injection well clusters near and downgradient of
ihe White Swan source area.

During the RD. an evaluation of individual Far Field "hot
spots" for treatment through the ISCO technology would
he performed to assess the effectiveness of treatment.

MNA would be implemented in the Far Field portion of-
ihe groundwater contaminant plume, concurrent with
LSCO in the Near Field areas. Attenuation processes lor
VOCs ingruundwiiterwould be closely monitored
concurrent with other aspects of the selected remedy. In
addition, surface water and sediment sampling and
analysis would be included in the long-term monitoring
plan.

A CEA would be established to limit the installation of
additional wells in ihe area of groundwater
contamination until cleanup standards have been met.

I his alternative would address indoor air contamination
by continuing EPA's current program of sampling sub-
slab and indoor air associated with structures overlying
the groundwater contaminant plume. Where elevated
VOC levels are detected, vapor mitigation systems

A CEA. would be established to limit ihe installation of
additional wells in the area of groundwater contamination
until cleanup standards have been met.

This alternative would address indoor air contamination
by continuing EPA's current program of sampling sub-
slab and indoor air associated with structures overlying ihe
groundwater contaminant plume. Where elevated VOC

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THE NINE SUPERFUND EVALUATION CRITERIA

1.	Overall Protectiveness of Human Health and the
Environment evaluates whether and how an alternative
eliminates, reduces, or controls threats to public health and
the environment through institutional controls,
engineering controls, or treatment.

2.	Compliance with Applicable or Relevant and
Appropriate Requirements (ARARs) evaluates whether
the alternative meets federal and state environmental
statutes, regulations, and other requirements that pertain to
the site, or whether a waiver is justified.

3.	Long-term Effectiveness and Permanence considers
the ability of an alternative to maintain protection of
human health and the environment over time.

4.	Reduction of Toxicity, Mobility, nr Volume (TMV)
uf Contaminants through Treatment evaluates an
alternative's use of treatment to reduce the harmful effects
of principal contaminants, their ability to move in the
environment, and the amount of contamination present.

5.	Short-term Effectiveness considers the length of time
needed ro implement an alternative and the risks the
alternative poses to workers, the community, and the
environment during implementation.

b. Implement-ability considers the technical and
administrative feasibility of implementing the alternative,
including factors such as the relative availability of goods
and services.

7. Cost includes estimated capital and annual operations
and maintenance costs, us well as present worth cost.
Present worth cost is the total cost of an alternative over
time in terms of today's dollar value. Cost estimates are
expected to be accurate within a range of +30 to -.30
percent.

S; State/Support Agency Acceptance considers whether
lite State agrees with the EPA's analyses and
" recommendations; as described i'ti' th'e RI/F.Tand Proposed'
Plan.

Community Acceptance considers whether the local
community agrees with EPA's analyses and preferred
alternative. Comments received on the Proposed Plan are
an important indicator of community acceptance. ¦

levels are detected, vapor mitigation systems would be
installed and maintained. In addition, systems alreacly
installed at the Site would be maintained until the
groundwater is remediated.

Total Capital Cost
Operation and Maintenance
Total Present Net Worth
Time frame (ISCO)

Full Groundwater Restoration

$7.9 million
$ 3.7 million
SI 1.6 million
10 yeare

Approx. 70 years

Alternative 4 - Extraction and
Treatment/MNA/ICs/Vapor Remediation

Alternative 4 would include construction and operation of
a groundwater treatment plant and an extraction well
system to collect and treat contaminated groundwater in
the Near Field areas immediately downgradient from both
source areas. Tins alternative would target the most
highly contaminated groundwater, generally containing
I'CE at levels of greater than 1.000 ppb. It is estimated
that two extraction wells would be required for each
source area and an additional three may be needed to
address downgradient hot spot areas pending further
evaluation in the R.D. A groundwater extraction and
treatment system would be constructed and operated for
approximately 30 years. It would consist of groundwater
extraction wells, the associated underground piping and a
treatment plant. The extraction system layouts and flow
rates would be designed "to maximize capture of
contaminated groundwater from different areas, then
combined and pumped to a treatment plant. .

Treatment of groundwater in the plant would be achieved
by several methods including air stripping and GAC
adsorption units, and the treated water would likely be
discharged to a .surface water body such as Judas Creek,
the sanitary sewer system, or re-injected into the aquifer.

During RD, it would be determined if additional
extraction wells would be used to treat hot spots areas
within the Far Field portion of the groundwater plume.

Monitored Natural Attenuation for the Far Field area uf
the plume would be the same as discussed above for
Alternatives 2 and 3.

A CHA would be established to limit the installation of
additionalwells-in the area of groundwater1 contamination-
until cleanup standards have been met.

This alternative would address indoor air contamination
by continuing EPA's current program of sampling sub-
slab and indoor uir associated with structures overlying the
groundwater contaminant plume. Where elevated VOC
levels are detected, vapor mitigation systems would be
installed and maintained. In addition, systems already
installed at the Site would be maintained until the
•groundwater is remediated.

12

Total Capital Cost
Operation and Maintenance
Total Present Net Worth

S7.3 million
$6.2 million
SI3.5 million

-------
Time Triune (Pump &Treat) 30 years
Full Groundwater Restoration Approx. 70 years

EVALUATION OF REMEDIAL ALTERNATIVES

Nine criteria are used to evaluate the different remedial
alternatives individually and against each other in order
to select the best alternative. This section of the
Proposed Plan profiles the relative performance of each
alternative against the nine criteria, noting how it
compares to the other options under consideration. The
nine evaluation criteria are discussed below. A more
detailed analysis can be Ibund in the FS.

Overall Protection of Human Health and Ihe
Environment

'The No Action Alternatives lor soil and groundwater are
not protective of human health and the environment.
While source area soils do not pose a direct risk to
human health, they contribute tu groundwater
contamination at the Site, which poses unacceptable
levels of risk to human health. Under the No Action
.iltemative. VOC contamination in soils would continue
to migrate lo groundwater. Groundwater contamination
woukl continue to migrate uncontrolled, where it may
continue to impact human health and the environment.

All other soil alternatives provide adequate protection of
human health and the environment and are expected to
comply with ARARs.

All groundwater alternatives (other than No Action) are
considered protective. I'hey all include treatment of the
Site's most highly contaminated groundwater, and
include MNA. institutional controls, and appropriate
indoor air mitigation to minimize potential exposure to
contaminated groundwater and vapors emanating from
groundwater until the alternatives are implemented, and
remediation goals have been achieved-.

Compliance with Applicable or Relevant and
\ppnipriute Requirements (ARARsl			

flic three broad categories of ARARs include chemieal-
r.pecific. location-specific and action-specific ARARs.
ARARs have been established for groundwater at this
Site to restore die aquifer to drinking water standards.
No soil ARARs are required to protect against direct
contact with Site soils, as this exposure does not pose
unacceptable risks. However, modeling was performed
to ilevelop a soil cleanup standard for PCE, the primary
contaminant of concern that would be protective of
groundwater. The soil cleanup standard for I'CE is I
part per million (ppm). All soil remediation alternatives,
except the No Action alternative, would meet this
.standard eventually. The No Action alternative would

not meet standards in a reasonable time frame. Of the two
active remediation technologies, excavation would
achieve soil ARARs more quickly, in I year, and ISVE
would take approximately 10 years. The ISVE and
excavation technologies would also comply with locution-
and action-specific ARARs such as the Resource
Conservation and Recovery Act.

All of the groundwater alternatives would eventually meet
the groundwater ARARs. The primary contaminant of
concern. PCE, has a NJ GVVQC of 1 ppb. The No Action
Alternative would not meet ARARs in a reasonable time
frame, and would not assure that residential drinking
water stundards are met in the short term. The alternatives
which include active treatment (Alternatives 2.3 and 4)
would assure tliar potable water met the ehemieal-specitic
ARAR for PCE in a much shorter time frame compared to
the No Action alternative. All alternatives would comply
with location- and action-specific ARARs such as the
Freshwater Wetlands Protection Act and the Federal Clean
Water Act.

MNA is a component of each alternative, with the
exception of the No Action alternative. MNA would be
used to address lesser contaminated groundwater in the
Far Field area of the Site. With die performance of an
active remediation of the most contaminated groundwater
in the Near Field, modeling has shown thai Far Field
groundwater would be restored lo drinking water
standards in a much shorter time frame than without
remediation (roughly 70 years vs. 400 ycxirs).

liach alternative, with the exception of the No Action
alternative, includes ongoing indoor air sampling and
installation of remediation systems within buildings to
prevent exposure lo unacceptable levels of PCI: in indoor
air.

Long-Term Effectiveness and Permanence

The highest degree of permanence and long term
effectiveness is achieved lor those alternatives that result
in a greatest removal.o.fcontaminanls.from die-Site. Thu
No Action Alternative would not be effective in the long
term because no actions will be taken to address the
contamination. Some attenuation of contaminants can be
expected over time, but this would not he measured or
monitored under Alternative I.

For soil. Alternative 2, (SVE/AS. would be effective for
removal of soil contamination in the source area. Since it
is expected that the full remediation would take place
within 10 years, it would be both effective in the long term
and permanent. Hie magnitude of risk remaining after
implementation of ISVE/AS or excavation for soil
contamination would be similar. ISVE/AS (Alternatives 2
und 4) would achieve containinuni reductions through in-

-------
situ treatment, while excavation (.Alternatives and 3 and
4) wquld rely on physical removal of the contaminated
material. ISVE/AS is estimated to require active
treatment operations tor up to 10 years, compared to 1
year for excavation. Excavation would have a higher
degree of certainty of reduction of contaminants since all
contaminated material would be physically removed.
ISVE/'AS is expected to be effective at reducing
contamination, but since it is an in-siiu technology, it
may not achieve 100% removal of VOCs. as would be
achieved by excavation.

For groundwater, active treatment in the Near Field areas
under consideration would include 1SVEMS
(Alternative 2), ISCO (Alternative 3). or extraction and
treatment (Alternative 4). In comparing these
alternatives, Alternatives 2 and 4 would likely have
similarly high degrees ul" long-term effectiveness.
Alternative 3, ISCO, could be effective in the long term,
hut would be more difficult to implement and manage,
leading to more uncertainty with respect to its long-term
effectiveness compared to Alternatives 2 and 4.

[{eduction of Toxicity, Mobility, or Volume Through
Treatment

The No Action Alternatives lor both soil and
groundwater would not treat the contaminants arid would
not reduce their toxicity, mobility, or volume through
treatment.

For soils, Alternative 2, ISVE/AS would reduce the
volume of the majority of the VOC contaminants in the
soils (estimated at <)9% removal) through treatment,
thereby greatly reducing the volume of the contaminants.
Alternative 3, excavation, would remove 100% of the
volume of contaminants, but is not likely to include
treatment in that the excavated soils would likely be
disposed at an olF-Site. licensed landfill. Alternative 4
would be effective in reducing toxicity, mobility and
¦.olume through treatment at the Sun Cleaners property.
As stated, excavated soil from the White Swan Cleaners
property tnay not require treatment at a.waste disposal..
facility.

For groundwater. Alternative 2 (1SVE/AS). Alternative 3
((SCO), and Alternative 4 (extraction and treatment)
would all reduce the toxicity, mobility and volume of
groundwater contaminants using different treatment
technologies in the Near Field. ISCO would
permanently destroy contaminants in-situ. 1SVE/AS and
extraction and treatment would remove contaminants in
the groundwater and then treat the contaminants in the
air or groundwater stream generated respectively.

Short-Term Effectiveness

The No Action Alternatives for soil and groundwater
include no construction or monitoring, and would have no
short-term impacts at the Site.

In addressing contaminated soils. Alternatives 2,3, and 4
would all have some short-term impacts on workers and
the local community, as the source areas to be remediated
are located in a highly developed commercial area, near
residential communities. Potential risks would include
physical hazards near areas where heavy equipment is
used and from increased vehicles traffic, and noise, air
emissions, and hazards resulting from managing
contaminated soils. These short-term risks can be
managed through appropriate planning and monitoring
during the construction. Air emissions generated during
the 1SVE/AS operations can be controlled and monitored.
[Disruption to the community would be relatively lower lor
ISVEVAS ("Alternatives 2 and 4) compared to excavation
t Alternatives 3 and 4), as excavation would require the
transportation of contaminated soils from the source areas
via existing roadways. However, ISVE/AS would require
about 5 months to construct, and 10 years to operate
intermittently, while excavation would take about I year
to implement.

For the groundwater alternatives. Alternatives 2
I I'SVE/AS'), Alternative 3 (ISCO). and Alternative 4
(groundwater extraction and treatment), a number of
•diort-tcrm risks are possible including, physical hazards,
noise, traffic near areas requiring heavy equipment for
construction, emissions and dust. Additional significant
^hort-tenn risks would be presented under Alternative 3
(ISCO). as this alternative would require handling and
storage of a chemical oxidant in a densely populated
residential community. The oxidant would need to be
carcliilly managed. In addition. Alternative 3 (ISCO)
would also have the potential to increase contaminated
vapors in residential areas. Careful monitoring and
management of vapors would be required to protect public
health. All of the three active groundwater alternatives
would present some disruption of the community:
however, Alternative 3 would-require the-ino.st disruption-
of private property and is the least effective in the short-
term.

Iinplementability

The No Action Alternatives for soil and groundwater
require no implementation.

For soils, each alternative considered would be technically
implementable and uses proven, readily available
technologies. A pilot study would.be needed prior to the
design of the remedy under Alternative 2 (ISVH/AS).
Alternative 3 (Excavation) would be significantly more
difficult to implement at the Sun.Cleaners source area

-------
compared to the White Swan source area for a number of
reasons. The topography of the Sun Cleaners property
includes a substantial steep slope, which may require
specialized equipment to assure a safe exaction. In
addition, the Sun Cleaners property is located on a
highly congested traffic circle, which would require
signi ficant rerouting of traffic and disruption to the
community. The White Swan property by comparison,
would be easier to excavate as it is relatively level and
located on a less traveled road. In addition, the
excavation alternative would remove significantly more
mass from the White Swan property compared to the
Sun Cleaners property (4.360 pounds ofl'CE mass at
White Swan vs. 140 pounds ofl'CE mass at Sun
Cleaners).

Fur groundwater, each technology considered is
technically implementuble. proven and readily available.
Issues required lo implement all alternatives include
acquisition of land, subsurface work wiihin local streets
and private property for installing system components.
Alternative 2 (ISVE/AS) and Alternative 3 (ISCO)
would have the greatest amount of infrastructure
required on private property- compared to Alternative 4
(extraction and treatment).. For this reason, iliese
alternatives would be more disruplive to (he community
during construction and operation compared with
Alternative 4.

Alternative 2 (1SV1-7AS) would require regular
maintenance to prevent inctais fouling in ihe system.
Allernaiive 3 (ISCO) would present safety hazards
issociated with the storage and handling of chemical
oxidants in residential areas. Further generation of
contaminated vapors could be exacerbated through (lie
implementation oflSCO and indoor air would need to he
closely monitored.

Cost

I'here are no costs associated with the No Action
Alternatives for soil and groundwater, however, it would

.provide no protection.to h.uman health or.ihe 	

environment. I'lie following chart summaries the costs
lor rest of the remedial alternatives.

Ground
water

ws&

Sun

MSVE/
.VINA

5.4

5,4

10.8

Ground
water

WS&
Sun '

3-lSCO/
MNA

7.9

3.7

1 1.6

Ground
water

WS&
Sun

4-P&T/
MNA

7.3

6.2

13.5

State/Support Agency Acceptance

The State of New Jersey agrees with the preferred
alternative in this Proposed Plan.

Community Acceptance

The community's opinion of Ihe preferred alternative will
be evaluated after the public comment period ends and
will be described in the Responsiveness Summary of the
Record of Decision. The Record of Decision is the
document lhat formalizes the selection of the remedy lor a
sire.

SUMMARY OF THE PREFERRED ALTERNATIVE

The preferred alternative for the White Swan
Cleaners/Sun Cleaners Area Groundwater Contamination
Site is Alternative 4 for source soils and Alternative 4 for
groundwater. Alternaiive-4 lor soils would include the
ISVE/AS technology to treat soils and associated
groundwater at the Sun Cleaners source area and
excavation and off-site disposal for soils at ihe White
Swan source area. Demolition and disposal of the bank
building may be necessary. Alternative 4 lor groundwater
would include: the extraction and treatment of ihe most
highly contaminated groundwater in ihe Near field
portion of ihe groundwater plume: JV1NA for lesser
contaminated groundwater in ihe l'iir I'ield portion of the
groundwater plume, ongoing sub-slab and indoor air
investigation and remediation, and ICs.

ISVE/AS would be implemented fur soils at the .Sun
Cleaners source area and excavation would be
implemented for soils at the While Swan source- area.
SoilsJ.oca.tc.d.abPV.e the water.lable. as. welLas.soils below
ihe water table would be addressed, as these are principal
threat wastes. A Site-speeilic soil cleanup goal of I ppm
for PCI: has been developed and would be protective of
groundwater. Addressing soils to meet this cleanup
standard is expected to address all Site contaminants.

After completion of soil remediation activities, both
properties containing contaminated soils would be
restored and could be redeveloped.

The most highly contaminated groundwater at the Site, in
the Near Field area, would be remediated through
extraction and treatment. Extraction wells would be
located adjacent to and downgradient the source areas to
address the Site's most highly contaminated groundwater.

Media

Source
Area

Alternative

Capital

Cost

S.M

O&M
SM

Present

Worth

¦SVI

soil

WS &
Sun ¦

MSVE

1.8

1.8

3.6

soil

WS Jt
Sun

3-

Excavarion

8.0

.s.o

-.oil

WS
and
Sun

4-ISVE lor
Sun

Excavation
For WS

4.5

0

5.4

-------
The groundwater treatment plant would treat the
groundwater by removing the PCE and TCE using air
strippers and activated carbon. The treated groundwater
would be discharged to either to the local
sewer/treatment facility, surface water or re-injected into
the aquifer. Areas of elevated groundwater
contamination (hot spots) in the Far Field area of the Site
would be further evaluated and may be addressed
through cither the groundwater extraction and treatment
system, or smaller localized treatment systems.
Determinations regarding whether to address these hot
spots will be made during the RD.

Lesser contaminated groundwater would be addressed
through MNA. Attenuation processes for VOCs in
groundwater would be closely monitored concurrent
with other aspects of the selected remedy. Sediments
would continue to be monitored to evaluate the impact
of the remedy over lime.

Indoor air contamination would be addressed by
continuing EPA's current program of sampling sub-slab
and indoor air associated with structures overlying the
groundwater contaminant plume. Where elevated VOC
levels are detected, vapor mitigation systems would be
installed and maintained. In addition, systems already
installed at the Site would he maintained until the
groundwater is remediated.

The preferred alternative would prevent exposure to Site
contaminants by addressing indoor air contamination as
described above, and through the implementation of ICs,
¦;uch as a CEA, until the aquifer is restored to drinking
water siandards. The total cost of the preferred
alternative to address all Site contamination is estimated
to he SI N.9 million.

As is EPA's policy, live-year reviews would be
conducted until remediation goals have been met.

The preferred alternative was selected over the other
alternatives principally because it is expected to achieve
substantial-long-term risk.reduction.through-treatment.of
(he principal threat waste, as well as the most highly
contaminated groundwater contamination.

Based on information currently available. EPA believes
the preferred alternative is protective of human health
and the environment, complies with AllARs and
provides the best balance of tradeoffs among the other
alternatives with respect to the Superfund evaluation
criteria. EPA expects the preferred alternative will
satisfy the statutory requirements of CERCLA Section
1212(b).

Consistent with EPA Region 2's Clean and Green
policy. EPA will evaluate the use of sustainable

technologies and practices with respect to any remedial
alternative selected tor the Site.

COMMUNITY PARTICIPATION

EPA provided information regarding the cleanup of the
White Swan/Sun Cleaners Superfund Site to the public
through public meetings, the Administrative Record file
for the Site and announcements published in the Coast
Star newspaper. EPA entourages the public to gain a
more comprehensi ve understanding of the Site and the
Superfund activities that have been conducted there.

For further information on EPA's preferred alternative for
the White Swan/Sun Cleaners Superfund Site, please
contact:

Matthew Westgaie	Cecilia Echols

Remedial Project Manager Community Relations
1212) 637-4422 ..	(212) 637-3678

U.S. EPA
2l)0 Broadway, 19th Floor
New York, New York 10007-1 JiAA

The dates for the public comment period; the date, the
location and lime of the public meeting; and the locations
of the Administrative Kecord tiles are pro vided on the
front page of this.Proposed Plan.

-------
(.a.ossAitv

A Ha Us: Applicable or Kckv mil and Appiopt iatc lvci|iiiiciticiiis. I Jic.-e .iiv I cdeial or MMc ciiviuiiiiiiciilai rules ;inJ regulations
thai may pertain In the Site hi a particular alternative.

Ciiiviuujiciiic Uisk: lancer risks ..re cxpiesscd us a number ivtkctioj; Hit.' increased chance that  chemicals ur substances. lor example. 11'As acceptable ri>k range lor Siipcrfuud hazardous uustc site.-, is I x IU"1 to I \
IU'". meaning there is I :uktiiioiuil <.h:iiic«.- ill I(i.Ut.Ki 11 x 10"') lo I additional cluiice in I million (I x 10"°) that ;i person will
develop cancer if exposed In a Sile contaminant iluil is iini icmediatcJ.

C'KKOLA: (.\mipiclicusivc l:ii\ iroiuuciilal Response. compensation and I i.ibility Act. A federal lau . coimnuiily rclcncd 10 as the
"Supcrfuiid" I'royam. passed in I'.>80 lli;ii prov ides for 1 cspon.se actions at .Mies founJ u> tic contaminated vv ill) luuarduus
substances, pollutants ur contaminants (hat ciukuiycr public health and safety or llic environment.

t.'OI'C: Chemicals oll'otciilial Concern.

SI. kit A: Screening level l-!c.ilogiic:il Kisk Assc.-miicih. An evaluation .if ilie puteutial iisk posed io the env iammeiit if remedial
activ itie.s are not performed at the Site.

H>: l egibility Study. .Anal)sis of the practical ulitv of multiple remedial actiuit options lor the Site.

(.•'ruiinilHliter: Subsurface viatcr iliai occui» in soil.-* ami eculo-iic l'nmiatious llial are fully saluiated.

IlilKA: Human lleallh Kisk Assessment. An evaluation of the ri»h posed to human health should remedial activities nut be
implemented.

Ill: llaiurd Indc.x. A number indicative uf tioncaiciiiiiecuic health effects that is the ratio of the cxistitn: level of ex|>osiirc to ail
•acceptable level ol exposure. A value ct|iial to or less than one indicate.^ that the human population is not likely to experience
adveisc ellects.

IIQ: lla/nrd (Juuticiit. IIOs are used to evaluate noucaiciuo^enic health cflccts and eculugical risks. A value equal to 01 less llian
one indicates that the human or ecological population are nut likelv 10 experience adverse effects.

It's: Institutional C ontrols Administrative methods in prevent human exposure to contaminants. such as b> restricting the use ul'
groundwater fur drinking water purposes.

Nino Evaluation Criteria: See text box nn J'.ijje I J.

iNuiieanillogi'iiie Kisk: Noncauccr il.i/ards <01 risk j ,11 e c\|iicssed as a ijiuiticni that ..uinpares the existing level of cXpusure tu the
acceptable level of exposure. There is a lev e:l of exposure (the reference dose) below vvhieli it is unlikclv lor even a sensitive
population to experience adverse health el'kyls. I SII'A's threshold level fur nonearciuo^eilic risk at Superlund sites is I. tiieuiiittii
that if the exposure exceeds the threshold: thcic may be a eouecni for potential noncanccr ellects.

Nl'L: National Priorities l ist A list developed In t SLJ'A .if uncontrolled lia/anluus siibsuuice release sites in the L'liitcd Suites
that are considered priorities lor lony-tcrm icinedial evaluation and response.

1

-------
Operable L'nil (Oil): a discrete action that comprises an increment.il step toward comprehend vely addressiiii! siie
pioliletns. This discrete punion ol'.i remedial response m.iitaucs migration, or eliminates or mitigates a release, threat ol
a release, or pathway ol'exposure. Tlie cleanup ol'a site ean be divided iiuo a number of operable units, depending oil
llie complexity of ihe problems associated with (lie site.

Practical Quantitation l.i-wl II'OU1 means the lowest concentration ol'.i constituent that ean be reliably achieved among
laboratories within specified limns of precision and accuracy during routine laboratory operating cotidiiions.

I'reseiu-Wurih Com: Toial cost. in current dollais. ul'ilie remedial action. The present-worth com include capital costs required 10
implement I lie remedial action. as well as I lie cost of long-term operations, inainiL'naiiee, and monitoring.

Proposed Plan: A document tlnii presents the preferred remedial alternative and requests publie input regarding die proposed
cleanup ahernatix c.

I'uhlic Comment Period: Hie liute allowed lor die members of a potentially affected community to express s lews and concerns
regarding USl-.l'A's preferred remedial alternative.

RAOs: Remedial Aetiun Objectives Objectives of remedial actions ilui are developed based un contaminated media. contaminants
of concern, potential receptors and exposure scenarios, human healili and ecological risk assessment, and attainment ol regulatory
cleanup levels.

Record ol' Decision (ROD): A legal document ilial describes die cleanup action or remedy selected for a site, the basis lur chousing
that remedy, and publie comments oil the selected remedy.

Remedial Action: A cleanup lu address hazardous substances ai a site.

Rl: Remedial Investigation. A stud) ol a facility llial supports tlie selection ol'ii remedy where ha^aidous substances lra\c tieeii
disposed or released. The Kl idealities the nature and c.Mcnl of Contamination at tlie facility and analyzes risk associated vviih
COl'Cs.

Saturated Soils: Soils thai aie found bclovt ihc \\ ater I able. I'liese soils stay net.

'I UCs; " I o-be-eonsiderevls," consists oluoM-pionmlyuud ad\ isorics aud~or guidance that were developed by Ul'A, other federal
agencies, or stales lltai may be useful in developing CL'RCl.A remedies.

Unsaturated Soils: Sviils thai arc found abov e tlie Water I able. Kain or surface water passes tliiuugli tlie.se soils. These soils
remain dry:

ISKl'A: United Stales lin\ironmenial Protection Agency. The I citcral agency responsible for administration and enforcement of
C'lfKCLA (and oilier environmental statutes and regulations), and final approv al authority for the selected ROD.

VOC: Volatile Urganic Compound. I\|>e of chemical that readily vaporises, often producing a distinguishable odor.

Water Table: The water table is an imaginary line marking the top of llie vvaier-saiuratcd area wilhin :¦ rock column.

-------
fr

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WestgateJVlatthew

From:

Sent:

To:

Subject:

Catherine Schwier [ceo@smbr.org]
Thursday, September 12, 2013 12:09 PM
Westgate, Matthew

Sea Girt Estate Air Quality Testing Request

Good afternoon Mr. Westgate,

My three children and I reside at 1307 West Chicago Boulevard, Sea Girt, Nj. Our home is located within Sea Girt Estates
in Wall. I would like to request that our home have an air quality test performed. Please let me know what I need to do
to proceed. Thank you in advance for your cooperation.

Warmest regards,

Catherine L. Schwier-Mencer

l

-------
Westgate, Matthew

From:	John Frisco [jsfrisco@gmail.com]

Sent:	Wednesday, September 11, 2013 10:59 AM

To:	Westgate, Matthew

Cc:	Echols, Cecilia; Mugdan, Walter

Subject:	White Swan Proposed Plan Comments

A general observation is that the scope of the proposed remedy appears limited relative to he magnitude of the
contamination problem. The plume here is not unlike those at Bridgeport and Vineland relative to size where
much larger and more aggressive systems are in place. I understand the nature of the contamination is different
but it does raise questions about the adequacy of the groundwater treatment.

.The near-field and far-field groundwater contamination zones are defined by PCE levels above and below 1000
ppb. How was that level determined and would more active treatment of lower levels result in shorter cleanup
time frames?

How would the anticipated treatment of far-field PCE hot spots affect the estimated groundwater treatment
cost?

In general, the proposed remedy appears to include the appropriate remedial action components. However, there
may be environmental benefits to a more aggressive cleanup approach.

l

-------
Westgate, Matthew

Richard Kane [atlanprod@optimum.net]

Tuesday, September 10, 2013 5:18 PM
Westgate, Matthew

super fund site sea girt estates WAIi NJ
Mathew,

With regards to our phone/con today, can you send by return the results of the test for 1314
Willow Drive(2001 &2006) and/or any other pertinent information that I would need to insure
that the house is safe from environmental standpoint. ( I want to decide if I should get
ventilation system).

Any questions, I can be reached by return or by phone at 908-227-4666.

TX

Richard Kane

From:

Sent:

To:

Subject:

-------
Westgate, Matthew

From:

Sent:

To:

Subject:

Echols, Cecilia

Tuesday, September 10, 2013 3:34 PM
Westgate, Matthew
FW: white swan

Here is another request.

From: Rick Deacon rmailto:rdeacon@interspec.com1
Sent: Tuesday, September 10, 2013 2:13 PM
To: Echols, Cecilia
Subject: white swan

Hi,my name is Rick Deacon and I live at 34 Forest Ave in Manasquan,NJ.I am inquiring as to whether my property falls
within the contamination site as Judas Creek runs through my back yard.Many Thanks

l

-------
Westgate, Matthew

From:	Echols, Cecilia

Sent:	Tuesday, September 10, 2013 1:08 PM

To:	Westgate, Matthew

Subject:	Residential Testing

Resident is seeking testing - Marge Gerard, 1309 W. Magnolia Avenue, Sea Girt, NJ 08750
732-610-8092.

1

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Westgate, Matthew

Sent:

To:

Cc:

Subject:

From:

Echols, Cecilia

Tuesday, September 10, 2013 10:14 AM
Westgate, Matthew

Oconnell, Kimberly; Kluesner, Dave; Story, Karen; Rodriguez, Elias
Article in the Asbury Park Press re: White Swan Cleaners site.

Hi Matt,

Several individuals have called this morning and they are alarmed about this article. I have read it and reassured them
that EPA is working expeditiously in cleaning up the site. The article doesn't seem harsh at all.

The communities concern are cancer in the area and Real Estate values. Additionally, the community doesn't like seeing
their community in the newspaper associated with a Superfund site. That is understandable.

I will keep you posted throughout the day.

http://www.app.com/article/20130910/NJNEWS/3091Q0025/Uneasiness-lingers-over-plans-Superfund-site-southern-

Thanks

Monmouth

1

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Westgate, Matthew

From:

Sent:

To:

Subject:

Carl Straub [carlyjst@yahoo.com]

Saturday, September 07, 2013 11:17 AM
Westgate, Matthew

Re: White Swan Superfund comments regarding Judas Creek

Matt,

Thanks.

Your approach to this project is very encouraging

Can we have your personal Email address to keep in touch on a social note?

Carl and Pat

Carl Straub
carlvist@vahoo.com

From: "Westgate, Matthew" 

To: Carl Straub 

Sent: Wednesday, September 4, 2013 10:18 AM

Subject: RE: White Swan Superfund comments regarding Judas Creek

Carl,

EPA will not produce a groundwater treatment system that floods out residents downstream.

I write the "Scope of Work" for the designers when I hire them and I will include a clause that says they will
not flood out residents with the outfall from the plant.

The designers do hydraulic modeling before they sign and stamp the design, so they don't want to create any
liability for themselves either.

Your comment will be included in the responsiveness summary and our response included there.

If you have any further questions please call me at 212 637-4422

	Original Message	

From: Carl Straub mailto :carlvi st@vahoo.coml
Sent: Wednesday, September 04,2013 9:30 AM
To: Westgate, Matthew
Cc: Patricia Straub

Subject: White Swan Superfund comments regarding Judas Creek

Thanks for your multi-year investigation of this Superfund problem. It was a pleasure to attend the lengthy
session with you and the team of EPA professionals on August 27.

My request is to reconsider the proposed added flow of water to the Judas Creek. We bought the 27 Willow

Hello Matt,

l

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- Way property in 1971 for my parents' retirement There was occasional flooding over the years. But lately the
stormwater flooding has been much more frequent and the Creek banks have been noticeably eroding.

The Monmouth County Mosquito Commission is in process of "de-snagging" the Creek by removing bushes
and trees. They've started in the Elementary School area. However the major obstruction to stormwater flow in
the Creek is the 36 inch diameter pipe under the driveway from a parking lot to the high school building. This
is the major cause of flooding in the Willow Way area.

You'll receive an envelope with a few photos of the flooding problem in our yard. Other properties bordering
Judas Creek have the same problem.

We look forward to your next visit to the Manasquan area and hope to meet with you.

Carl

Carl and Pat Straub

27 Willow Way	'	,

Manasquan, NJ 08736
732-223-2788
Cell: 914-646-4441

Sent from my iPad

2

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Westgate, Matthew

From:

Sent:

To:

Subject:

Cutt, Diana

Thursday, September 05, 2013 10:42 AM

Westgate, Matthew

RE: White Swan Sea Girt Planning

Thanks Matt. I'll contact him as the "new" Jon Josephs©

From: Westgate, Matthew

Sent: Tuesday, September 03, 2013 2:23 PM

To: Cutt, Diana

Subject: FW: White Swan Sea Girt Planning
Diana

Could you provide your info to this guy? I assume you replaced Jon Josephs
Thanks	j

From: Santo Auriemma rmailto:santo@heDure.coml
Sent: Tuesday, September 03, 2013 1:35 PM
To: Westgate, Matthew
Subject: White Swan Sea Girt Planning

Dear Matt

It was a pleasure to meet you at the Wall pubic meeting last week. Believe me, I really don't envy your
position at all. As I mentioned in our brief discussion, Hepure visited your offices several times to discuss the
latest developments in Zero Valent Iron usage in the industry. Your EPA associates were very interested in the
technology for treatment in both soil and ground water. In the past, we coordinated these visits with Jon
Josephs who was the technology liaison for the office. You indicated Jon retired last year. Can you provide me
the persons name and contact information so that we can coordinate with them on future technical
presentations?

Have a great day and I hope to hear from you soon.

Regards,

Santo Auriemma
President

Hepure Technologies, Inc.

98 North Ward Street
New Brunswick, NJ 08901
Cell - 908-399-3422

Matt

l

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Westgate, Matthew

From:

Sent:

To:

Subject:

Mimi Baum [mimi@baum.com]
Wednesday, September 04, 2013 1:34 PM
Westgate, Matthew
White swam

Please tell me what areas in sea girt are required to be tested for this contamination.

Thank you
M Baum
315 Brooklyn
Sea girt

Mimi Baum
mimi@Baum.com

l

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Westgate, Matthew

From:

Sent:

To:

Subject:

Echols, Cecilia

Wednesday, September 04, 2013 1:11 PM
Westgate, Matthew
FW: Sea Girt Estates

Here is a letter for the record.

	Original Message	

From: Francesca Wells fmailto:WellsteamOaol.coml
Sent: Tuesday, September 03, 2013 10:02 PM
To: Echols, Cecilia
Subject: Sea Girt Estates

Hello. I lived in Sea Girt Estates in the late 80's and 90"s. in 1994 my father was
diagnosed with cancer in his 60"s. His cancer was so aggressive that he died before his
primary cancer could be diagnosed. Other neighbors had similar experiences. When I
researched our town I saw that our neighborhood was listed as a superfund site in the early
90"s if not earlier. I was shocked! The only thing more shocking is seeing that it took 20
plus years for the EPA to come up with a plan to clean it up. 20 years?! How many of my
high school friends have died from cancer in their 40's while the EPA took 20 years to come
up with a plan?

My question is how do you explain this 20 plus year gap for this clean up? Did you notify
the residents of the danger? If not, why? I would like this question to be a part of your
public records because I will not rest until I have answers for this horrific lack of respect
for human safety.

Thank you,

Francesca Wells

l

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WestgateJMatthew

Sent:

To:

Cc:

Subject:

From:

Carl Straub [cahyjst@yahoo.com]

Wednesday, September 04, 2013 9:30 AM
Westgate, Matthew
Patricia Straub

White Swan Superfund comments regarding Judas Creek

Hello Matt,

Thanks for your multi-year investigation of this Superfund problem. It was a pleasure to
attend the lengthy session with you and the team of EPA professionals on August 27.

My request is to reconsider the proposed added flow of water to the Hudas Creek. We bought
the 27 Willow Way property in 1971 for my parents' retirement. There was occasional flooding
over the years. But lately the stormwater flooding has been much more frequent and the Creek
banks have been noticeably eroding.

The Monmouth County Mosquito Commission is in process of "de-snagging" the Creek by removing
bushes and trees. They've started in the Elementary School area. However the major
obstruction to stormwater flow in the Creek is the 36 inch diameter pipe under the driveway
from a parking lot to the high school building. This is the major cause of flooding in the
Willow Way area.

You'll receive an envelope with a few photos of the flooding problem in our yard. Other
properties bordering Dudas Creek have the same problem.

We look forward to your next visit to the Manasquan area and hope to meet with you.

Carl

Carl and Pat Straub
27 Willow Way
Manasquan, ND 08736
732-223-2788
Cell: 914-646-4441

Sent from my iPad

l

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Westgate, Matthew

From:

Sent:

To:

Subject:

Santo Auriemma [santo@hepure.com]
Tuesday, September 03, 2013 1:35 PM
Westgate, Matthew
White Swan Sea Girt Planning

Dear Matt

It was a pleasure to meet you at the Wall pubic meeting last week. Believe me, I really don't envy your
position at all. As I mentioned in our brief discussion, Hepure visited your offices several times to discuss the
latest developments in Zero Valent Iron usage in the industry. Your EPA associates were very interested in the
technology for treatment in both soil and ground water. In the past, we coordinated these visits with Jon
Josephs who was the technology liaison for the office. You indicated Jon retired last year. Can you provide me
the persons name and contact information so that we can coordinate with them on future technical
presentations?

Have a great day and I hope to hear from you soon.

Regards,

Santo Auriemma
President

Hepure Technologies, Inc.

98 North Ward Street
New Brunswick, NJ 08901
Cell - 908-399-3422

l

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' , ¦
WestgateJMatthew

From:	wendi weber [wendidw@yahoo.com]

Sent:	Friday, August 30, 2013 4:47 PM

To:	Westgate, Matthew

Subject:	WhiteSwan/Sun Remediation

Attachments:	Dear Mr.Westgate.docx

Dear Mr. Matthew Westgate,
Please find letter attached.
Wendi Sheridan

l

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Dear Mr. Mathew Westgate,

First of all I would like to personally thank you for your efforts at the EPA in working diligently to
coordinate and plan for the clean-up/remediation of the White Swan/Sun dry cleaners. I spoke with you
about seven years ago immediately after purchasing my home in the Sea Girt Estates area and listened
to you speak at the public meeting in Wall on Tuesday.

Before purchasing my home, we looked for years. I fell in love with this area! It is still a beautiful area
with plenty of open space that meets the sea. After speaking with you years earlier, we agreed to have
our home tested. We wanted to make sure our home was free of dry cleaning toxins, and if so make
sure that the proper ventilation system was in place to rid them to ensure our health and safety. Luckily,
our home tested below level and needed no remediation. Some area residents refused testing, in fear of
being "marked" as having contaminants.

Prior to one week ago, I thought remediation had already taken place or was in the process of. Seven
years later, I received the white post card in the mail for the public meeting, which blended in with the
ads. Fortunately, I realized it was not junk mail! Had it been in letter form, or a bright color perhaps it
would have STOOD out, but it didn't. I was glad I sought it out!

After attending the meeting and getting up to speed on the situation, I was in a state of shock. My
dream felt shattered. 30 years to clean-up? 70 years to remediate? Of something I ignorantly thought
would take a short period of time to address. Why did I buy this home? My hard-earned nest egg could
be shattered by a major drop in real-estate values. I beg, please choose option #3 (one year clean-up for
remediation of soil) and option 2 or 3 for the water remediation. The only solution I see is to get this
cleaned up in immediate fashion, we've waited too long after first discovering the problem. If at least
the soil can be cleaned up in one year, then that can be a selling point to say well that was done and is
now compliant. If residents are left with a thirty year or more mess, we will deter the real estate market
here to a stand-still, wearing the scarlet letter "T" for Toxic by the sea for years to come! Please let me
know what we can do to get this done in a quicker fashion. If starting a petition is in order than I would
be happy to participate.

In addition to my concerns about the clean-up method/time period, I have some questions that I'd like
addressed below:

1.	When I sell my home what is my responsibility legally to disclose that may home has or hasn't
been tested? You said that is between the buyer and seller, but I need precise info on this.

2.	How safe are the Sea Girt and Spring Lake beaches? There was no mention of this in the
literature, only that the ponds are not safe for the fish.

3.	If someone has a house where the basement has been ventilated, what is the cancer risk? Is a
ventilated contaminated home equal to that of a home that is not contaminated. As someone

-------
who lives a very healthy, organic, chemical-free lifestyle, I need to know the real health
implications for living in this area even if there are low levels detected.

4. I have a cracked/old basement, are there any added problems with this with detected low
levels?

Thank you for your time. I look forward to hearing from you,

Wendi Sheridan
Resident of Sea Girt Estates

-------
Westgate, Matthew

Subject:
Attachments:

Sent:

To:

Cc:

From:

JOHNPAPCPA@aol.com
Friday, August 30, 2013 12:47 PM
Westgate, Matthew

priya.sundaram@dep.state.nj.us; michael.alemzadeh@dep.state.nj.us

Fwd: from John Papandrea re:public comment White Swan/Sun Cleaners Superfund ...

FederalEPAAugust302013letter.doc

From: JOHNPAPCPA@aol.com
To: westaate.mathew@eDa.gov

CC: priva.sundaram@dep.state.ni.us. michael.alemzadeh@dep.state.ni.us
Sent: 8/30/2013 12:41:32 P.M. Eastern Daylight Time

Subj: from John Papandrea republic comment White Swan/Sun Cleaners Superfund Sites
Dear Mr. Westgate:

Input pursuant to the public meeting and corresponding comment period attached for your perusal.

Please feel free to contact me at my address, this email address or telephone number provided in the attached
letter. I have made several requests of your offices which require a response, including testing my air and soil, as
well as the wetlands areas between my Willow Way property and the Manasquan Board of Education High
School Athletic Fields which also border the same wetlands area.

I have copied the NJ DEP on this letter.

Thank you.

John Papandrea
Residential Homeowner
29 Willow Way
Manasquan, NJ 08736

-------
Mr. Mathew Westgate	John Papandrea

Federal EPA, Region Two	29 Willow Way

290 Broadway, 19th floor	Manasquan, NJ 08736

New York, NY 10007-1866	(732)528-6014

August 30, 2013

Dear Mr. Westgate:

I am submitting this letter pursuant to the public meeting that was held on August
27, 2013, and the public comment period ending on September 19, 2013, as my
input with regard to the White Swan/Sun Cleaners area groundwater
contamination superfund site. My entire household including myself is in favor of
GROUNDWATER PLAN ALTERNATIVE 3, for both the Sun and White Swan
sites. Ten years is simply much too long to clean up the Sun site, and could have
serious negative economic consequences to the area. The Sun site is located on
the northwest corner of the Manasquan traffic circle, off said circle, with traffic re
routing either around or through the circle quite feasible. Coordination with the NJ
DOT and Monmouth County certainly is attainable. We do not want this process
extended for ten years.

With respect to the GROUNWATER PLAN, we are in favor of ALTERNATIVE 3
for both sites, In-situ chemical oxidation vapor remediation plan for both sites for
reasons that were discussed at the meeting by other effected residential property
owners which we agree with.

We live on "Judas Creek" just east of the MAC POND site, in the
wetlands/stream area which flows between the Manasquan Board of Education
athletic fields and the homeowners on Willow Way, Manasquan. The creek floods
very badly, flooding having increased in scope over the years for various
reasons, so we are opposed to draining processed water back into Judas Creek,
which could exacerbate the flooding. My neighbor brought this issue up during
the meeting, and our property is directly next to his.

Have your offices taken core soil samples from the wetlands and buffer areas
that exist between the Manasquan High School athletic fields and Willow Way?
Since the Manasquan Board of Education is planning on building a retaining wall
within the wetlands and buffer areas, with pilings, we ask that soil samples be
taken first to weigh the environmental impact and risks if the contaminants are
found to be in those soils, appurtenant to the stream. Driving pilings into the
ground and building a concrete retaining wall could certainly have impact on the
effected areas, including the residential property owners on Willow Way.

-------
I request that if you have not already done so, please take and evaluate the soil
samples within subject wetlands areas.

In closing, I did not receive any postcard advising me of the public meeting.
I request that your offices take soil and air samples from my property as well in
order to test for these contaminants. My wife has developed COPD while living
on Willow Way, and is legally disabled from it. I want to make certain that she
and the rest of my household are safe, and if there is a problem with
contaminants, proper steps will be taken to alleviate the problem.

Please advise accordingly.

John C Papandrea
CC:NJDEP	Residential Homeowner

29 Willow Way
Manasquan, NJ 08736
(732)528-6014
iohnpapcpa@aol.com

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Westgate, Matthew

From:

Sent:

To:

Subject:

Devin Dam [DDam2@russellreid.com]

Friday, August 30,2013 10:55 AM
Westgate, Matthew

Clean Up Chemical Pollution in Wall Township, Manasquan Borough and Sea Girt, New
Jersey

Matt,

My name is Devin Dam with the Russell Reid and Mr. John Company. I'm curious to know if this project is
going to be handled by a private firm for soil and groundwater disposal.

If so are you able to provide me with this information it would be greatly appreciated.

Devin Dam

Account Executive
800-356-4468, ext. 5455
Direct: 732-692-2455
Cell: 908-399-9050
Fax: 732-225-1739
devind@russellreid.com
devind@mriohn.com

Please consider the environment before printing this e-mail

This transmission (including any attachments) may contain confidential information, privileged material (including material
protected by the solicitor-client or other applicable privileges), or constitute non-public information. Any use of this information by
anyone other than the intended recipient is prohibited. If you have received this transmission in error, please immediately reply to
the sender and delete this information from your system. Use, dissemination, distribution, or reproduction of this transmission by
unintended recipients is not authorized and may be unlawful.

This transmission (including any attachments) may contain confidential information, privileged material
(including material protected by the solicitor-client or other applicable privileges), or constitute non-public
information. Any use of this information by anyone other than the intended recipient is prohibited. If you have
received this transmission in error, please immediately reply to the sender and delete this information from your
system. Use, dissemination, distribution, or reproduction of this transmission by unintended recipients is not
authorized and may be unlawful.

Thank you

a

i

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; v "

Westgate, Matthew

From:	Stephen Barlow [sbarlow@barlowfiowerfarm.com]

Sent:	Wednesday, August 28, 2013 12:14 PM

To:	Westgate, Matthew

Cc:	Stephanie Peduto; olshep@verizon.net

Subject:	' RE: From Stephen Barlow

Matt,

Thanks so much for addressing my concern. I guess that people make it seem to be a very large site, but in retrospect
this site is small compared to the others mentioned.

On another note, my sister and I both have just completed construction on new homes on village road. Would it be
possible to have the basements tested?

Thank you again for addressing our concerns.

Stephen Barlow
Barlow's

1014 Sea Girt Avenue
Sea Girt, NJ 08750
www.barlowflowerfarm.com

From: Westgate, Matthew rmailto:Westaate.Matthew@eDa.aovl
Sent: Wednesday, August 28, 2013 11:42 AM
To: Stephen Barlow

Cc: Posten, Stephen E; Dalleinne, Christopher P; Oconnell, Kimberly
Subject: RE: From Stephen Barlow

Mr. Barlow,

I am sorry, you are correct. I will refrain from using the name of your business when identifying the area of high
contamination around your facility. You are also correct that our sampling team fell into the casual use of names like
Barlow's, Waterbrook, etc. to identify these areas and we picked up the name. I will correct the references in any future
documents and presentations.

White Swan/Sun Cleaners although large, is nowhere near the size of the Hudson River cleanup, Passaic River, Gowanis
Canal, Raritan Bay, etc. which are all in EPA's region 2.

Matthew Westgate, Project Manager/Geologist

U.S. EPA Region 2

New Jersey Remediation Branch

Southern New Jersey Remediation Section

290 Broadway, 19th floor

New York, N.Y. 10007-1866

(212)637-4422

Westgate.matthew@epa.gov

From: Stephen Barlow rmailto:sbarlow@barlowflowerfaim.coml
Sent: Wednesday, August 28, 2013 10:12 AM

l

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^ <»

To: Westgate, Matthew
Subject: From Stephen Barlow

Matt,

Thank you very much for the informative meeting last night. During the meeting I noticed that my company, Barlow's
Nursery, was used as a reference point and a noted "hot spot". In the future I would appreciate something other than
the name of my business as a point of reference (i.e. corner of Village road and Sea Girt avenue). With all the concern in
the community about this superfund site, I do not want the public to think that we are associated with it. Over the past
10 years it has been our goal to become environmentally conscious. We use beneficial insect and disease control, honey
bees for pollination, and have recently installed water recirculation systems to minimize our water use. This is our
culture, I was taken back last night in seeing our family name associated with the top superfund site in New Jersey.

I am sure that it was an oversight and that your team was simply looking at Barlow's as an easy point of reference. I
appreciate all that you and all of your colleagues are doing on this project in attempt to keep our community safe and
informed.

Thank you in advance for your consideration.

Sincerely,

Stephen Barlow
Barlow's

1014 Sea Girt Avenue
Sea Girt, NJ 08750
www.barlowflowerfarm.com

2

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r v-

Westgate, Matthew

From:

Sent:

To:

Subject:

Stephen Barlow [sbarlow@barlowflowerfarm.com]
Wednesday, August 28, 2013 10:12 AM
Westgate, Matthew
From Stephen Barlow

Matt,

Thank you very much for the informative meeting last night. During the meeting I noticed that my company, Barlow's
Nursery, was used as a reference point and a noted "hot spot". In the future I would appreciate something other than
the name of my business as a point of reference (i.e. corner of Village road and Sea Girt avenue). With all the concern in
the community about this superfund site, I do not want the public to think that we are associated with it. Over the past
10 years it has been our goal to become environmentally conscious. We use beneficial insect and disease control, honey
bees for pollination, and have recently installed water recirculation systems to minimize our water use. This is our
culture, I was taken back last night in seeing our family name associated with the top superfund site in New Jersey.

I am sure that it was an oversight and that your team was simply looking at Barlow's as an easy point of reference. I
appreciate all that you and all of your colleagues are doing on this project in attempt to keep our community safe and
informed.

Thank you in advance for your consideration.

Sincerely,

Stephen Barlow
Barlow's

1014 Sea Girt Avenue
Sea Girt, NJ 08750
www.barlowflowerfarm.com

l

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Westgate, Matthew

From:

Sent:

To:

Subject:

Russ Molloy [russ.molloy@gmail.com]
Wednesday, August 28, 2013 9:35 AM
Westgate, Matthew

White Swan cleanup discussion last night

Matt: Thanks for taking the time last night to explain the situation. As you may recall, I mentioned to you that I
recently moved to 158 North Main Street in Manasquan (very close to Barlows Flower Nursery). You suggested
I send you a note to see if you have already had my house checked for PCE vapors. I have a deep basement (13
courses) and want to ensure that all is well.

My contact information is: Russ Molloy, 158 North Main Street, Manasquan, NJ 08736. Phone: 732-740-1660.
Email is russ.mollov@gmail.com.

If you have not had the house checked yet, would you kindly put me on your list and advise when you may
think this could be conducted?

Many thanks,

Russ

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Westgate, Matthew

From:

Sent:

To:

Subject:

Jeanne Mackown [mountain.meadows1951@gmail.com]
Tuesday, August 27, 2013 3:46 PM
Westgate, Matthew

White Swan/Sun Contamination SuperFund Site

Hello....I am trying to determine if my father's property at 1113 Sea Girt Avenue, Sea Girt,
NJ is contaminated. It is located in Wall Township and is down the street from the Sea Girt
Mall. Is there a list of homes that show where they are located in conjunction with the
plume of contamination? I am very concerned about this possible contamination and want, to
know who do I contact to come to the house to see if the air in the basement is contaminated
Then if so, then the soil would most likely be contaminated as well as Ihe private well.

Kindly advise me of what steps should be taken and who is responsible for cleaning up
contaminated areas.

Thank you for your response.

Deanne Mackown

l

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WestgateJVJatthew

From:	Delorio, Joseph [jdeiorio@manasquan-nj.com]

Sent:	Thursday, August 22, 2013 1:39 PM

To:	Westgate, Matthew

Cc:	Oconnell, Kimberly

Subject:	Re: White Swan Sun Cleaners Superfund site

Matthew,

this information has been posted on our Facebook and Twitter Accounts. It will also be blasted on via our email
notification system and posted on our website, shortly.

Joe

On Fri, Aug 16,2013 at 3:50 PM, Westgate, Matthew  wrote:

Dear Mr. Delorio;

Attached is the press notice EPA will be publishing next week in the Asbury Park Press and the
Coast Star. I am planning on a trip your area next week to brief local officials about our findings
and plans for the cleanup, so if you are available, I can include you also. Please contact me with
any questions.

U. S. Environmental Protection Agency invites public comment on a proposed plan for cleanup of the White
£ \ Swan Cleaners/Sun Cleaners Area Groundwater Contamination Superfund Site, within Wall Township,
| Manasquan, and Sea Girt, New Jersey

The U.S. Environmental Protection Agency (EPA) announces the opening of a 30-day public comment period on the cleanup proposal
to address on-site soil and groundwater contaminated with Tetrachloroethylene (PCE) at the White Swan Cleaners/Sun Cleaners Area
Groundwater Contamination Superfund Site in Wall Township, Manasquan and Sea Girt, NJ.

Public comment on the preferred cleanup plan, and other cleanup alternatives that were considered, begins on August 20, 2013 and
ends on September 19, 2013. The EPA encourages the public to attend a public meeting on Tuesday , August 27, 2013 at 7 p.m. at
the Wall Township Municipal Center, Main Meeting Room at 2700 Allaire Road, Wall, N.J. 07719.

The Proposed Plan is available at http://www.eDa.Qov/reaion2/suDerfund/nDl/whiteswan/ or by calling Cecilia Echols, EPA's Community
Involvement Coordinator, at (212^ 637-3678 and requesting a copy by mail.

Written comments on the Proposed Plan, postmarked no later than September 19, 2013 may be mailed to Matthew Westgate, EPA
Project Manager, at U.S. EPA, 290 Broadway, 19th Floor, New York, NY 10007-1866.or e-mailed no later than September 19, 2013 to
Westaate.Matthew@eDa.aov

The Administrative Record file, containing the documents used or relied on in developing the alternatives and preferred cleanup plan, is
available for public review at the following information repositories:

1

-------
Wall Township Public Library Reference Section located at 2700 Allaire Road, Wall, NJ 07719

U.S. EPA Region 2, Superfund Records Center, 290 Broadway, 18th Floor, New York, NY 10007-1866 (212) 637-4308. Mon. - Fri.,
9am - 5pm

Matthew Westgate, Project Manager/Geologist

U.S. EPA Region 2

New Dersey Remediation Branch

Southern New Jersey Remediation Section

290 Broadway, 19th floor

New York, N.Y. 10007-1866

(212)637-4422

Westgate.matthew@,epa. gov

Joseph R. Delorio .
Administrator/Chief Financial Officer
Borough of Manasquan
201 East Main Street
Manasquan, New Jersey 08736
732-223-9530
www.manasquan-ni .com

"Like" Manasquan on Facebook Today!
"Follow" us on Twitter!

2

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Westgate, Matthew

Peter Jennings [shoregang@optonline.net]
Thursday, August 22, 2013 8:28 PM
Westgate,. Matthew
Re: White swan/ Sea Girt

I know a bit about air stripping water treatment. I am wondering about my shallow well and
the many in the area. Do you think shallow wells could be an answer or a help?We have wreck
pond,Maxs pond and the blasinburg stream,were water could be sprayed and aerated. Dust a
thought . Im wondering if the ground could be dewatered in spots and sprayed at these
points. Also how long before it works it self to the ocean with no cost or bother to anybody?
I thank you for your response to my questions.

Peter Dennings
732-449-4891 H
973-621-7555 w

On Aug 22, 2013, at 9:15 AM, Westgate, Matthew wrote:

>	Generally, when water containing PCE is sprayed into the atmosphere, the PCE volatilizes
out of the water droplets - this process is used to treat water containing many Volatile
Organic Compounds and is called "air stripping".

>

>	However, if you have a specific process that you are proposing using the contaminated
groundwater from the White Swan site, I would need to evaluate it to assure the safety of
those involved. In addition, if you are proposing pumping of the site contaminated
groundwater it might impact my groundwater remedial action so I would need to know about it
before you begin.

>

>	Finally if you are planning dewatering operations which would pump contaminated site
groundwater there will be some requirements under RCRA that need to be addressed.

>

>	Please contact me directly to discuss.

>

>	Thank you,

>

>	Matthew Westgate

>	212 637-4422

>

	>	Original Message	

>	From: Martin, DohnD

>	Sent: Thursday, August 22, 2013 8:47 AM

>	To: Westgate, Matthew

>	Subject: FW: White swan/ Sea Grt

>

>	Hi Matt,

>

>	Please see below, especially with regard to his first two questions-- will contaminents
from the pumped water become airborne and will this cleanup interfere with expansion of
highway 35.

>

>	Thank you,

>	Dohn

From:

Sent:

To:

Subject:

-------
>	Dohn Martin

>	Press Officer

>	U.S. Environmental Protection Agency

>	290 Broadway, New York, NY 10007

>	martin.iohnifilepa.gov

>	Desk: 212-637-3662

>	Cell: 646-256-6710

>

>	EPA's Region 2 Covers N.3., N.Y., P.R. and the U.S.V.I.

>	Visit Us: epa.gov/region2

>	Twitter: twitter.com/eparegion2

>	Facebook: facebook.com/eparegion2

>	Greening the Apple Blog: blog.epa.gov/greeningtheapple

>

>

	>	Original Message	

>	From: Peter Dennings rmailto:shoregangfitoptonline.net1

>	Sent: Wednesday, August 21, 2013 9:00 PM

>	To: Martin, DohnD

>	Subject: White swan/ Sea Grt

>

>	Dust a few short questions. If the ground water is pumped to the surface, does the
contaminants become airborne and dissipate?

>	Also , does this effect the highway 35 expansion, since it goes over the sites? Why is the
price so high for the clean up?

>

>

> Peter Dennings

2

-------
Westg^teJMatthew

Sent:
To:

Subject:

From:

Martin, JohnJ

Thursday, August 22, 2013 8:47 AM
Westgate, Matthew
FW: White swan/ Sea Grt

Hi Matt

Please see below, especially with regard to his first two questions-- will contaminents from
the pumped water become airborne and will this cleanup interfere with expansion of highway
35.

Thank you,

Dohn

3ohn Martin
Press Officer

U.S. Environmental Protection Agency
290 Broadway, New York, NY 10007
martin.iohni@epa.gov
Desk: 212-637-3662
Cell: 646-256-6710

EPA's Region 2 Covers N.D., N.Y., P.R. and the U.S.V.I.
Visit Us: epa.gov/region2
Twitter: twitter.com/eparegion2
Facebook: facebook.com/eparegion2

Greening the Apple Blog: blog.epa.gov/greeningtheapple

	Original Message	

From: Peter Dennings \mailto:shoreeaneOoptonline.net1
Sent: Wednesday, August 21, 2013 9:00 PM
To: Martin, DohnD
Subject: White swan/ Sea Grt

Dust a few short questions. If the ground water is pumped to the surface, does the
contaminants become airborne and dissipate?

Also , does this effect the highway 35 expansion, since it goes over the sites? Why is the
price so high for the clean up?

Peter Dennings

l

-------
Westgate, Matthew

From:

Sent:

To:

Subject:

Costello, James [jkcostello@gfnet.com]
Wednesday, August 21,2013 1:18 PM
Westgate, Matthew

Acquiring federal remediation contracts

Matt,

Thanks for taking the time to talk with me a few moments ago. I would like to learn from you the process of
acquiring a contract from the Federal government for some remediation work. If you could point me in the right
direction it would be very much appreciated. We have done some work for the DOD here in Pennsylvania.
Thanks again.

Jim Costello

James K. Costello

Marketing Manager

Gannett Fleming Project Development Corp.

207 Senate Avenue

Camp Hill, PA 17011

O - 717-763-7270 ext. 2460

C-717-418-3989

ikcostello@gffaet.com

www.gfpdc.com

l

-------
Westgate, Matthew

From:	JOcon1111@aol.com

Sent:	Wednesday, August 21, 2013 1:32 PM

To:	Westgate, Matthew

Subject:	Re: (no subject)

Thank you very much

In a message dated 8/21/2013 1:15:33 P.M. Eastern Davliaht Time. Westaate.Matthew@epa.gov writes:

If you go to the following web page;
http://www.epa.gov/region2/superfund/npl/whiteswan/

then you choose to open the Proposed Plan, the last page in that document there is a generalized map of our
contamination.

In a day or so we will put the Remedial investigation report on that same web page and that will have more
detailed maps

Matt Westgate

From: 30conllll@aol.com rmailto:JOconllll@aol.coml
Sent: Wednesday, August 21, 2013 12:48 PMo: Westgate, Matthew
Subject: (no subject)

Is there a map showing how far/where the plume has migrated to date in Manasquan?? Thank You

John Connor

l

-------
From:	JOcon1111@aol.com

Sent:	Wednesday, August 21, 2013 12:48 PM

To:	Westgate, Matthew

Subject:	(no subject)

Is there a map showing how far/where the plume has migrated to date in Manasquan?? Thank You
John Connor

l

-------
WestgateJMatthew

From:	Robert.Plum@stb.dot.gov

Sent:	Monday, August 19, 2013 1:42 PM

To:	Westgate, Matthew

Subject:	RE: White Swan and Sun Cleaners/Superfund

Thanks for the	info. I suspect my parents' well is nowhere near the town's depth.

From: "Westgate, Matthew" 
To: "Robert.Plumfilstb.dot.gov" 
Date: 08/19/2013 01:34 PM

Subject: RE: White Swan and Sun Cleaners/Superfund

After tomorrow, copies will be available at the Wall Township public library reference
section.

Two of the municipal wells are around 125 to 135 feet deep and the third is
750 feet deep.

	Original Message	

From: Robert.PluirtSstb.dot.gov rmailto:Robert.Plumifflstb.dot.gov!

Sent: Monday, August 19, 2013 1:31 PM
To: Westgate, Matthew

Subject: RE: White Swan and Sun Cleaners/Superfund
Matthew,

Thanks. That is right by the school and about a 1,000' from my parents house. How do I get
the Remedial Investigation appendices?

Rob

From:	"Westgate, Matthew" 

To:	"Robert.PlumlSstb.dot.gov" 

Date:	08/19/2013 01:17 PM

Subject:	RE: White Swan and Sun Cleaners/Superfund

Bell Place between Philadelphia and Baltimore. I don't know which well it was, but copies of
the well records should be contained in the Remedial Investigation appendices

	Original Message—

From: Robert.Plumfilstb.dot.gov rmailto:Robert.Plumfilstb.dot.gov!

Sent: Monday, August 19, 2013 11:59 AM
To: Westgate, Matthew

Subject: White Swan and Sun Cleaners/Superfund

Matthew,

l

-------
This email is in regard to EPA ID#: N3SFN0204241 and particularly the NPL Listing History
(final date: 9/24/0B). The third paragraph contains the follow two sentences:

The New Dersey Department of Environmental Protection (N3DEP) determined the Sea Girt
municipal wells were at risk and sampled them on a monthly basis beginning in August 1999. In
September 1999 PCE was detected in one of them at a level of
0.54 ppb.

Can you identify the location of the well with the 0.54ppb? I don't need an exact street
address. A block location is good enough for me.

Thank you.

Kindest regards,

Rob Plum

2

-------
Westgate, Matthew

From:	Sorensen, David [David. Sorensen@co.monmouth.nj. us]

Sent:	Monday, August 19, 2013 12:48 PM

To:	Westgate, Matthew

Cc:	Fournier, Ann Marie

Subject:	RE: White Swan Sun Cleaners

Thanks, was wondering about low figures. Did not make sense to me .
David A. Sorensen

Monmouth County Health Department
Senior Environmental Health Specialist
732.431.7456

Advisory,Consultative and Deliberative Materials

From: Westgate, Matthew [mailto:Westgate.Matthew@epa.gov]

Sent: Monday, August 19, 2013 12:42 PM

To: Sorensen, David; Simmons, Bill; Meddis, Michael; Sandra Van Sant; Fournier, Ann Marie; Grimm, Joel; Stephens,

Michael; Olsen, Tom

Subject: RE: White Swan Sun Cleaners

Those figures I gave to Mr. Simmons were for PCE mass, not soil weight. You are correct the sooner the source is
removed, the better. Most of the PCE in soils is covered by asphault.

Matt Westgate

From: Sorensen, David I"mailto:David.Sorensen@co.monmouth.ni.usl
Sent: Monday, August 19, 2013 12:36 PM

To: Simmons, Bill; Meddis, Michael; Sandra Van Sant; Fournier, Ann Marie; Grimm, Joel; Stephens, Michael; Olsen, Tom

Cc: Westgate, Matthew

Subject: RE: White Swan Sun Cleaners

Dig and dispose 3 tons of soil? Half a roll off. Should have been done 10 years ago.

David A. Sorensen

Monmouth County Health Department
Senior Environmental Health Specialist
732.431.7456

Advisory,Consultative and Deliberative Materials

From: Simmons, Bill

Sent: Monday, August 19, 2013 11:09 AM

To: Meddis, Michael; Sandra Van Sant; Fournier, Ann Marie; Grimm, Joel; Sorensen, David; Stephens, Michael; Olsen,
Tom

Cc: Westaate. Matthew@epa .gov
Subject: FW: White Swan Sun Cleaners

Advisory, Consultative and Deliberative Materials

-------
Thanks Matt it was nice talking with you. I am copying to other programs here and to Sandy Van
Sant who is the Health Officer of the Monmouth County Regional Health Commission, which is the
Local Health Authority for Wall, Sea Girt and Spring Lake.

The U.S. Environmental Protection Agency (EPA) announces the opening of a 30-day public
comment period on the cleanup proposal to address on-site soil and groundwater contaminated with
Tetrachloroethylene (PCE) at the White Swan Cleaners/Sun Cleaners Area Groundwater
Contamination Superfund Site in Wall Township, Manasquan and Sea Girt, NJ.

Public comment on the preferred cleanup plan, and other cleanup alternatives that were considered,
begins on August 20, 2013 and ends on September 19, 2013. The EPA encourages the public to
attend a public meeting on Tuesday , August 27, 2013 at 7 p.m. at the Wall Township Municipal
Center, Main Meeting Room at 2700 Allaire Road, Wall, N.J. 07719.

Matt also gave this summary:

The plume runs about 2 miles from Rt 35 to the ocean, bordered by Wreck Pond to the north and
Judas Creek/Stockton Lake to the south.

The White Swan site (former bank with septic system) has about 4300 pounds of contaminated soil in
the unsaturated zone that the EPA is proposing to excavate and remove.

The Sun Cleaners site on the Manasquan circle has 140 pounds that they will clean up with soil vapor
extraction.

As you will see from the map the Sun Cleaners is a significant source of the groundwater plume.

They will be installing a pump and treat system for the groundwater between Rt 35 and Barlows
Nursery (by intersection of Sea Girt and Village Av).

34 of the 500 homes that the EPA checked have vapor removal systems installed.

Sincerely,

William Simmons, MCHD

From: Westgate, Matthew rmailto:Westaate.Matthew@eDa.aovl
Sent: Monday, August 19, 2013 9:38 AM
To: Simmons, Bill

Subject: White Swan Sun Cleaners
Bill

Here is the announcement
Call if you have questions

-------

Matthew Westgate, Project Manager/Geologist

U.S. EPA Region 2

New Jersey Remediation Branch

Southern New Jersey Remediation Section

290 Broadway, 19th floor

New York, N.Y. 10007-1866

(212)637-4422

Westgate.matthew@epa.gov

NOTICE OF CONFIDENTIALITY

This message, including any prior messages and attachments, may contain advisory, consultative and/or deliberative material, confidential information or
privileged communications of the County of Monmouth. Access to this message by anyone other than the sender and the intended recipient(s) is unauthorized. If
you are not the intended recipient of this message, any disclosure, copying, distribution or action taken or not taken in reliance on it, without the expressed written
consent of the County, is prohibited. If you have received this message in error, you should not save, scan, transmit, print, use or disseminate this message or any
information contained in this message in any way and you should promptly delete or destroy this message and all copies of it. Please notify the sender by return e-
mail if you have received this message in error.

NOTICE OF CONFIDENTIALITY

This message, including any prior messages and attachments, may contain advisory, consultative and/or deliberative material, confidential information or
privileged communications of the County of Monmouth. Access to this message by anyone other than the sender and the intended recipient(s) is unauthorized. If
you are not the intended recipient of this message, any disclosure, copying, distribution or action taken or not taken in reliance on it, without the expressed written
consent of the County, is prohibited. If you have received this message in error, you should not save, scan, transmit, print, use or disseminate this message or any
information contained in this message in any way and you should promptly delete or destroy this message and all copies of it. Please notify the sender by return e-
mail if you have received this message in error.

NOTICE OF CONFIDENTIALITY

This message, including any prior messages and attachments, may contain advisory, consultative and/or deliberative material, confidential information or
privileged communications of the County of Monmouth. Access to this message by anyone other than the sender and the intended recipient(s) is unauthorized. If
you are not the intended recipient of this message, any disclosure, copying, distribution or action taken or not taken in reliance on it, without the expressed written
consent of the County, is prohibited. If you have received this message in error, you should not save, scan, transmit, print, use or disseminate this message or any
information contained in this message in any way and you should promptly delete or destroy this message and all copies of it. Please notify the sender by return e-
mail if you have received this message in error.

3

-------
APPENDIX IV
ADMINISTRATIVE RECORD INDEX

-------
REGION ID: 02

Site Name: WHITE SWAN LAUNDRY AND CLEANER INC
CERCUS ID: NJSFN0204241
OUID: 01
SSID: 02RX
Action:

DocID:

Doc Date:

Title:

Image
Count:

Doc Type:

Beginning Bates:

Ending Bates:

Volume:

Addressee Name:

Addressee Organization:

Author Name:

Author Organization:

115068

08/19/2013

ADMINISTRATIVE RECORD INDEX FOR
THE WHITE SWAN LAUNDRY AND
CLEANER INCORPORATED SITE

81

[INDEX]

DVD1

[]

[]

[,]

[US ENVIRONMENTAL
PROTECTION AGENCY]

114243

1111-01-01
00:00:00.0

SITE INVESTIGATION REPORT - WHITE
SWAN LAUNDRY AND CLEANERS, WALL
TOWNSHIP, MONMOUTH COUNTY-
VOLUMES 1 AND 2 OF 2 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

724

[REPORT]

R2-0000001

R2-0000724

DVD1

[]

[]

[,]

[NJ DEPARTMENT OF
ENVIRONMENTAL
PROTECTION AND ENERGY]

114244

1111-01-01
00:00:00.0

SITE INVESTIGATION REPORT- SUN
CLEANERS, WALL TOWNSHIP,
MONMOUTH COUNTY - VOLUMES 1 AND
2 OF 2 FOR THE WHITE SWAN LAUNDRY
AND CLEANER INCORPORATED SITE

1000

[REPORT]

R2-0000725

R2-0001724

DVD1

[]

[]

[,]

[NJ DEPARTMENT OF
ENVIRONMENTAL
PROTECTION AND ENERGY]

114242

12/22/2000

SITE INVESTIGATION REPORT FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

868

[CHART /TABLE,
REPORT]

R2-0001725

R2-0002592

DVD1

[,]

[SUMMIT BANK]

[MONTGOMERY, JOHN H]

[GROUNDWATER &
ENVIRONMENTAL
SERVICES, INC.]

114240

08/09/2001

SEPTIC TANK EXCAVATION &
GROUNDWATER SAMPLING REPORT FOR
THE WHITE SWAN LAUNDRY AND
CLEANER INCORPORATED SITE

1232

[CHART /TABLE,
REPORT]

R2-0002593

R2-0003824

DVD1

[,]

[FLEET NATIONAL BANK]

[,]

[GROUNDWATER &
ENVIRONMENTAL
SERVICES, INC.]

114241

04/02/2002

REMEDIAL INVESTIGATION ADDENDUM
REPORT - BOOKS 1 AND 2 OF 2 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

469

[CHART /TABLE,
LETTER, REPORT]

R2-0003825

R2-0004292

DVD1

[BUDROE, THOMAS]

[EPA, REGION 2]

[MONTGOMERY, JOHN H]

[GROUNDWATER &
ENVIRONMENTAL
SERVICES, INC.]

114248

07/31/2002

HEALTH CONSULTATION NO. 1 -
EVALUATION OF INDOOR AIR SAMPLING
AT BROOKSIDE SCHOOL FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

25

[CHART /TABLE,
REPORT]

R2-0004293

R2-0004317

DVD1

[]

[]

[,]

[ATSDR]

114249

07/31/2002

HEALTH CONSULTATION NO. 2 -
EVALUATION OF INDOOR AIR SAMPLING
AT OLD MILL SCHOOL FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

23

[CHART /TABLE,
REPORT]

R2-0004318

R2-0004340

DVD1

[]

[]

[,]

[ATSDR]

114247

09/25/2002

HEALTH CONSULTATION: PUBLIC HEALTH
IMPLICATIONS AND INTERPRETATION OF
EXPOSURE TO BENZENE IN RESIDENTIAL
INDOOR AIR FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

17

[CHART /TABLE,
REPORT]

R2-0004341

R2-0004357

DVD1

[]

[]

[,]

[ATSDR]

Page 1 of 81

-------
REGION ID: 02

Site Name: WHITE SWAN LAUNDRY AND CLEANER INC
CERCUS ID: NJSFN0204241
OUID: 01
SSID: 02RX
Action:

DocID:

Doc Date:

Title:

Image
Count:

Doc Type:

Beginning Bates:

Ending Bates:

Volume:

Addressee Name:

Addressee Organization:

Author Name:

Author Organization:

114246

09/25/2002

HEALTH CONSULTATION: PUBLIC HEALTH
IMPLICATIONS AND INTERPRETATION OF
EXPOSURE TO TETRACHLOROETHYLENE
(PCE) IN RESIDENTIAL INDOOR AIR FOR
THE WHITE SWAN LAUNDRY AND
CLEANER INCORPORATED SITE

23

[CHART /TABLE,
REPORT]

R2-0004358

R2-0004380

DVD1

a

[]

[,]

[ATSDR]

197483

09/05/2003

QUALITY ASSURANCE PROJECT PLAN FOR
THE REMOVAL INVESTIGATION DATED
DECEMBER 14, 2001 AT THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

231

[FORM]

R2-0004381

R2-0004611

DVD1

[,]

[EPA, REGION 2]

[MCGILL, KEN ]

[CH2M HILL]

114245

09/19/2006

ADMINISTRATIVE SETTLEMENT
AGREEMENT AND ORDER ON CONSENT
FOR REMEDIAL INVESTIGATION AND
FEASIBILITY STUDY IN THE MATTER OF
WHITE SWAN CLEANERS / SUN CLEANERS
AREA GROUND WATER
CONTAMINATION SUPERFUND SITE - US
EPA INDEX NO. II-CERCLA-02-2006-2019

76

[CHART /TABLE,
REPORT]

R2-0004612

R2-0004687

DVD1

a

[]

[]

[]

114237

06/14/2007

FINAL REMEDIAL INVESTIGATION /
FEASIBILITY STUDY WORK PLAN, QUALITY
ASSURANCE / QUALITY CONTROL
PROJECT PLAN, FIELD SAMPLING AND
ANALYSIS PLAN, HEALTH AND SAFETY
PLAN-VOLUME 1 OF V FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

304

[CHART /TABLE,
PLAN]

R2-0004688

R2-0004991

DVD1

[,]

[BANK OF AMERICA, NA]

[,]

[AMEC EARTH &
ENVIRONMENTAL, INC.]

164200

06/14/2007

REDACTED FINAL REMEDIAL
INVESTIGATION / FEASIBILITY STUDY
WORK PLAN, OA / QC PROJECT PLAN,
FIELD SAMPLING AND ANALYSIS PLAN,
HEALTH AND SAFETY PLAN - VOLUME II
AND III OF V FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1932

[PLAN]

R2-0004992

R2-0006923

DVD1

[,]

[BANK OF AMERICA, NA]

[,]

[AMEC EARTH &
ENVIRONMENTAL, INC.]

114238

06/14/2007

FINAL REMEDIAL INVESTIGATION /
FEASIBILITY STUDY WORK PLAN, QUALITY
ASSURANCE / QUALITY CONTROL
PROJECT PLAN, FIELD SAMPLING AND
ANALYSIS PLAN, HEALTH AND SAFETY
PLAN - VOLUME IV AND V OF V FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

334

[CHART /TABLE,
PLAN]

R2-0006924

R2-0007257

DVD1

[,]

[BANK OF AMERICA, NA]

[,]

[AMEC EARTH &
ENVIRONMENTAL, INC.]

Page 2 of 81

-------
REGION ID: 02

Site Name: WHITE SWAN LAUNDRY AND CLEANER INC
CERCUS ID: NJSFN0204241
OUID: 01
SSID: 02RX
Action:

DocID:

Doc Date:

Title:

Image
Count:

Doc Type:

Beginning Bates:

Ending Bates:

Volume:

Addressee Name:

Addressee Organization:

Author Name:

Author Organization:

114250

08/17/2007

PUBLIC HEALTH ASSESSMENT FOR WHITE
SWAN CLEANERS / SUN CLEANERS AREA
GROUNDWATER CONTAMINATION FOR
THE WHITE SWAN LAUNDRY AND
CLEANER INCORPORATED SITE

178

[CHART /TABLE,
REPORT]

R2-0007258

R2-0007435

DVD1

a

[]

[,]

[ATSDR]

145142

02/24/2008

GC/MS ANALYTICAL REPORT - WHITE
SWAN / SUN CLEANERS AREA VAPOR
INTRUSION STUDY FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

336

[REPORT]

R2-0007436

R2-0007771

DVD1

[CONNELL, REBECCA]

[EPA/ERT]

[BLAZE, STEPHEN]

[LOCKHEED MARTIN, INC.]

198221

08/01/2009

ANALYTICAL REPORT FOR WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

21

[REPORT]

R2-0007772

R2-0007792

DVD1

[,]

[EPA, REGION 2]

[,]

[LOCKHEED MARTIN, INC.]

200002

02/17/2012

FINAL SCREENING LEVEL ECOLOGICAL
RISK ASSESSMENT FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

371

[REPORT]

R2-0007793

R2-0008163

DVD1

[,]

[US ENVIRONMENTAL
PROTECTION AGENCY]

[,]

[AMEC ENVIRONMENTAL&
INFRASTRUCTURE, INC]

152799

06/01/2012

FINAL BASELINE HUMAN HEALTH RISK
ASSESSMENT FOR WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1413

[REPORT]

R2-0008164

R2-0009576

DVD1

[,]

[EPA, REGION 2]

[,]

[AMEC EARTH &
ENVIRONMENTAL, INC.]

200401

06/28/2013

FINAL REMEDIAL INVESTIGATION
REPORT VOLUME 1 FOR THE WHITE
SWAN CLEANER INCORPORATED SITE

356

[REPORT]

R2-0009577

R2-0009932

DVD1

[,]

[US ENVIRONMENTAL
PROTECTION AGENCY]

[,]

[AMEC ENVIRONMENTAL &
INFRASTRUCTURE, INC,
BANK OF AMERICA, NA]

200402

06/28/2013

FINAL REMEDIAL INVESTIGATION
REPORT VOLUME II APPENDICES A - J
FOR THE WHITE SWAN AND CLEANER
INCORPORATED SITE

5705

[REPORT]

R2-0009933

R2-0015637

DVD1

[,]

[US ENVIRONMENTAL
PROTECTION AGENCY]

[,]

[AMEC ENVIRONMENTAL&
INFRASTRUCTURE, INC,
BANK OF AMERICA, NA]

178264

06/28/2013

FINAL REMEDIAL INVESTIGATION
REPORT VOLUME II APPENDICES K - T
FOR THE WHITE SWAN LAUNDRY AND
CLEANER INCORPORATED SITE

902

[REPORT]

R2-0015638

R2-0016539

DVD1

[,]

[US ENVIRONMENTAL
PROTECTION AGENCY]

[,]

[AMEC ENVIRONMENTAL&
INFRASTRUCTURE, INC,
BANK OF AMERICA, NA]

178265

06/28/2013

FINAL REMEDIAL INVESTIGATION
REPORT VOLUME II APPENDIX U PART 1
and 2 of 10 FOR THE WHITE SWAN
CLEANER INCORPORATED SITE

38085

[REPORT]

R2-0016540

R2-0054624

DVD1

[,]

[US ENVIRONMENTAL
PROTECTION AGENCY]

[,]

[AMEC ENVIRONMENTAL&
INFRASTRUCTURE, INC,
BANK OF AMERICA, NA]

178266

06/28/2013

FINAL REMEDIAL INVESTIGATION
REPORT VOLUME II APPENDIX U PART 3
OF 10 FOR THE WHITE SWAN CLEANER
INCORPORATED SITE

38695

[REPORT]

R2-0054625

R2-0093319

DVD1

[,]

[US ENVIRONMENTAL
PROTECTION AGENCY]

[,]

[AMEC ENVIRONMENTAL&
INFRASTRUCTURE, INC,
BANK OF AMERICA, NA]

178267

06/28/2013

FINAL REMEDIAL INVESTIGATION
REPORT VOLUME II APPENDIX U PART 4
OF 10 FOR THE WHITE SWAN LAUNDRY
AND CLEANER INCORPORATED SITE

14648

[REPORT]

R2-0093320

R2-0107967

DVD1

[]

[]

[,]

[AMEC ENVIRONMENTAL &
INFRASTRUCTURE, INC,
BANK OF AMERICA, NA]

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178268

06/28/2013

FINAL REMEDIAL INVESTIGATION
REPORT VOLUME II APPENDIX U PART 5
AND 6 OF 10 FOR THE WHITE SWAN AND
CLEANER INCORPORATED SITE

27238

[REPORT]

R2-0107968

R2-0135205

DVD1

a

[]

[,]

[AMEC ENVIRONMENTAL &
INFRASTRUCTURE, INC,
BANK OF AMERICA, NA]

178269

06/28/2013

FINAL REMEDIAL INVESTIGATION
REPORT VOLUME II APPENDIX U PART 7 -
10 OF 10 FOR THE WHITE SWAN AND
CLEANER INCORPORATED SITE

3604

[REPORT]

R2-0135206

R2-0138809

DVD1

[,]

[US ENVIRONMENTAL
PROTECTION AGENCY]

u

[AMEC ENVIRONMENTAL&
INFRASTRUCTURE, INC,
BANK OF AMERICA, NA]

178270

06/28/2013

FINAL REMEDIAL INVESTIGATION
REPORT VOLUME II APPENDIX V - W FOR
THE WHITE SWAN AND CLEANER
INCORPORATED SITE

1030

[REPORT]

R2-0138810

R2-0139839

DVD1

[,]

[US ENVIRONMENTAL
PROTECTION AGENCY]

[,]

[AMEC ENVIRONMENTAL&
INFRASTRUCTURE, INC,
BANK OF AMERICA, NA]

206026

07/22/2013

FEASIBILITY STUDY FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

723

[REPORT]

R2-0139840

R2-0140562

DVD1

[,]

[US ENVIRONMENTAL
PROTECTION AGENCY]

[,]

[AMEC ENVIRONMENTAL&
INFRASTRUCTURE, INC]

688902

08/16/2013

PROPOSED PLAN FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

19

[PLAN]

R2-0140563

R2-0140581

DVD1

a

[]

[,]

[US ENVIRONMENTAL
PROTECTION AGENCY]

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SAMPLING RESULTS BY LOCATION

209395

1111-01-01
00:00:00.0

REDACTED ACCESS AGREEMENT FOR
BLOCK 280 LOT 48 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0140582

R2-0140582

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209308

01/04/2001

REDACTED ACCESS AGREEMENT FOR
BLOCK 712 LOT 10 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0140583

R2-0140583

DVD2

a

[]

[]

[]

209289

01/17/2001

REDACTED ACCESS AGREEMENT FOR
BLOCK 707 LOT 10 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0140584

R2-0140584

DVD2

a

[]

[]

[]

209258

12/20/2001

REDACTED ACCESS AGREEMENT FOR
BLOCK 293 LOT 3 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0140585

R2-0140585

DVD2

a

[]

[]

[]

209268

12/20/2001

REDACTED ACCESS AGREEMENT FOR
BLOCK 293 LOT 6 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0140586

R2-0140586

DVD2

a

[]

[]

[]

209296

12/21/2001

REDACTED ACCESS AGREEMENT FOR
BLOCK 293 LOT 13 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0140587

R2-0140587

DVD2

a

[]

[]

[]

209194

12/27/2001

REDACTED ACCESS AGREEMENT FOR
BLOCK 706 LOT 8.01 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0140588

R2-0140588

DVD2

a

[]

[]

[]

209479

12/28/2001

REDACTED ACCESS AGREEMENT FOR
BLOCK 299 LOT 22 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0140589

R2-0140589

DVD2

a

[]

[]

[]

209170

12/28/2001

REDACTED ACCESS AGREEMENT FOR
BLOCK 708 LOT 3 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0140590

R2-0140590

DVD2

a

[]

[]

[]

209496

01/03/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 721 LOT 7 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0140591

R2-0140591

DVD2

a

[]

[]

[]

209477

01/04/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 290 LOT 1 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0140592

R2-0140592

DVD2

a

[]

[]

[]

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209139

01/04/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 708 LOT 9 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0140593

R2-0140593

DVD2

a

[]

[]

[]

209285

01/04/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 711 LOT 8 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0140594

R2-0140594

DVD2

a

[]

[]

[]

209485

01/08/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 295 LOT 3 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0140595

R2-0140595

DVD2

a

[]

[]

[]

209593

01/08/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 708 LOT 10 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0140596

R2-0140596

DVD2

a

[]

[]

[]

209140

01/09/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 708 LOT 9 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0140597

R2-0140597

DVD2

a

[]

[]

[]

209525

01/09/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 709 LOT 15 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0140598

R2-0140598

DVD2

a

[]

[]

[]

209276

01/09/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 709 LOT 19 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0140599

R2-0140599

DVD2

a

[]

[]

[]

209135

01/10/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 707 LOT 6 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0140600

R2-0140600

DVD2

a

[]

[]

[]

205962

01/14/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 101 LOT 11 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0140601

R2-0140601

DVD2

a

[]

[]

[]

209083

01/14/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 715 LOT 4 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0140602

R2-0140602

DVD2

a

[]

[]

[]

205959

01/15/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 100 LOT 4 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0140603

R2-0140603

DVD2

a

[]

[]

[]

205956

01/15/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 88 LOT 7 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0140604

R2-0140604

DVD2

a

[]

[]

[]

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205984

01/16/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 102 LOT 2 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0140605

R2-0140605

DVD2

a

[]

[]

[]

145196

01/16/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 708 LOT 1 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0140606

R2-0140606

DVD2

a

[]

[]

[]

205989

01/17/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 105 LOT 3 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0140607

R2-0140607

DVD2

a

[]

[]

[]

209232

01/17/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 278 LOT 15 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0140608

R2-0140608

DVD2

a

[]

[]

[]

205949

01/17/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 38 LOT 17 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0140609

R2-0140609

DVD2

a

[]

[]

[]

205973

01/17/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 49 LOT 5 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0140610

R2-0140610

DVD2

a

[]

[]

[]

209185

01/19/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 708 LOT 2 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0140611

R2-0140611

DVD2

a

[]

[]

[]

205978

01/21/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 61 LOT 1 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0140612

R2-0140612

DVD2

a

[]

[]

[]

209318

01/21/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 711 LOT 7 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0140613

R2-0140613

DVD2

a

[]

[,]

[EPA, REGION 2]

205953

01/22/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 70 LOT 5 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0140614

R2-0140614

DVD2

a

[]

[]

[]

205981

01/22/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 80 LOT 3 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0140615

R2-0140615

DVD2

a

[]

[]

[]

205951

01/23/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 71 LOT 12 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0140616

R2-0140616

DVD2

a

[]

[]

[]

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205987

01/24/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 56 LOT 3 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0140617

R2-0140617

DVD2

a

[]

[]

[]

205976

01/24/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 60 LOT 16 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0140618

R2-0140618

DVD2

a

[]

[]

[]

209600

01/24/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 706 LOT 8.02 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0140619

R2-0140619

DVD2

a

[]

[]

[]

205947

01/25/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 31 LOT 3 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0140620

R2-0140620

DVD2

a

[]

[]

[]

209487

01/28/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 170 LOT 21 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0140621

R2-0140621

DVD2

a

[]

[]

[]

209520

01/28/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 278 LOT 25 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0140622

R2-0140622

DVD2

a

[]

[]

[]

205965

01/29/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 13 LOT 15 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0140623

R2-0140623

DVD2

a

[]

[]

[]

205967

01/30/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 5 LOT 1 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0140624

R2-0140624

DVD2

a

[]

[]

[]

198169

01/31/2002

ACCESS AGREEMENT FOR TRUST
COMPANY BANK FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0140625

R2-0140625

DVD2

a

[]

[]

[]

209366

01/31/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 706 LOT 4 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0140626

R2-0140626

DVD2

a

[]

[]

[]

209491

02/03/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 307 LOT 19 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0140627

R2-0140627

DVD2

a

[]

[]

[]

209494

02/04/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 305 LOT 16 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0140628

R2-0140628

DVD2

a

[]

[]

[]

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209178

02/07/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 706 LOT 9.01 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0140629

R2-0140629

DVD2

a

[]

[]

[]

209500

02/11/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 286 LOT 4 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0140630

R2-0140630

DVD2

a

[]

[]

[]

209495

02/11/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 301 LOT 1 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0140631

R2-0140631

DVD2

a

[]

[]

[]

205971

02/11/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 45.05 LOT 1 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0140632

R2-0140632

DVD2

a

[]

[]

[]

209358

02/11/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 707 LOT 14 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0140633

R2-0140633

DVD2

a

[]

[,]

[EPA, REGION 2]

205960

03/01/2002

REDACTED INDOOR AIR EVALUATION
UPDATE FOR BLOCK 100 LOT 4 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0140634

R2-0140635

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

205963

03/01/2002

REDACTED INDOOR AIR EVALUATION
UPDATE FOR BLOCK 101 LOT 11 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0140636

R2-0140637

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

205985

03/01/2002

REDACTED INDOOR AIR EVALUATION
UPDATE FOR BLOCK 102 LOT 2 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0140638

R2-0140639

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

205957

03/01/2002

REDACTED INDOOR AIR EVALUATION
UPDATE FOR BLOCK 88 LOT 7 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0140640

R2-0140641

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

205990

03/04/2002

REDACTED INDOOR AIR EVALUATION
UPDATE FOR BLOCK 105 LOT 3 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0140642

R2-0140643

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

205974

03/04/2002

REDACTED INDOOR AIR EVALUATION
UPDATE FOR BLOCK 49 LOT 5 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0140644

R2-0140645

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

205979

03/04/2002

REDACTED INDOOR AIR EVALUATION
UPDATE FOR BLOCK 61 LOT 1 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0140646

R2-0140647

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

Page 9 of 81

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205954

03/04/2002

REDACTED INDOOR AIR EVALUATION
UPDATE FOR BLOCK 70 LOT 5 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0140648

R2-0140649

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

198171

03/06/2002

INDOOR AIR EVALUATION UPDATE FOR
TRUST COMPANY BANK FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0140650

R2-0140651

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

205948

03/06/2002

REDACTED INDOOR AIR EVALUATION
UPDATE FOR BLOCK 31 LOT 3 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0140652

R2-0140653

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

205988

03/06/2002

REDACTED INDOOR AIR EVALUATION
UPDATE FOR BLOCK 56 LOT 3 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0140654

R2-0140655

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

205977

03/06/2002

REDACTED INDOOR AIR EVALUATION
UPDATE FOR BLOCK 60 LOT 16 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0140656

R2-0140657

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

205982

03/06/2002

REDACTED INDOOR AIR EVALUATION
UPDATE FOR BLOCK 80 LOT 3 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0140658

R2-0140659

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

209519

03/06/2002

REDACTED RESULTS OF INDOOR AIR
EVALUATION UPDATE ON SAMPLES
COLLECTED FROM BLOCK 278 LOT 25
FOR THE WHITE SWAN LAUNDRY AND
CLEANER INCORPORATED SITE

2

[LETTER]

R2-0140660

R2-0140661

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

145194

03/06/2002

REDACTED UPDATE ON PROGRESS OF
THE SAMPLING/ANALYSIS CONDUCTED
IN PORTIONS OF WALL TOWNSHIP AND
THE BOROUGHS OF SEA GIRT AND
MANASOUAN FOR BLOCK 708 LOT 1 FOR
THE WHITE SWAN LAUNDRY AND
CLEANER INCORPORATED SITE

2

[LETTER]

R2-0140662

R2-0140663

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

205966

03/14/2002

REDACTED INDOOR AIR EVALUATION
UPDATE FOR BLOCK 13 LOT 15 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0140664

R2-0140665

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

205972

03/14/2002

REDACTED INDOOR AIR EVALUATION
UPDATE FOR BLOCK 45.05 LOT 1 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0140666

R2-0140667

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

205968

03/14/2002

REDACTED INDOOR AIR EVALUATION
UPDATE FOR BLOCK 5 LOT 1 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0140668

R2-0140669

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

Page 10 of 81

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205952

03/14/2002

REDACTED INDOOR AIR EVALUATION
UPDATE FOR BLOCK 71 LOT 12 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0140670

R2-0140671

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

209346

04/04/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 285 LOT 4 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0140672

R2-0140672

DVD2

a

[]

[,]

[EPA, REGION 2]

209179

04/04/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 706 LOT 9.01 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0140673

R2-0140673

DVD2

a

[]

[]

[]

209319

04/07/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 711 LOT 7 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0140674

R2-0140674

DVD2

a

[]

[SCHMITT, WILLIAM ]

[EPA]

209277

04/08/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 709 LOT 19 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0140675

R2-0140675

DVD2

a

[]

[]

[]

209309

04/08/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 712 LOT 10 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0140676

R2-0140676

DVD2

a

[]

[]

[]

145195

04/08/2002

REDACTED RESULTS FOR THE INDOOR
AIR EVALUATION SAMPLES COLLECTED
FROM BLOCK 708 LOT 1 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

14

[LETTER]

R2-0140677

R2-0140690

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

209195

04/08/2002

REDACTED RESULTS OF INDOOR AIR
EVALUATION COLLECTED FROM BLOCK
706 LOT 8.01 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

15

[LETTER]

R2-0140691

R2-0140705

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

209181

04/08/2002

REDACTED RESULTS OF INDOOR AIR
EVALUATION COLLECTED FROM BLOCK
706 LOT 9.01 ON 02/07/2002 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

9

[LETTER]

R2-0140706

R2-0140714

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

209136

04/08/2002

REDACTED RESULTS OF INDOOR AIR
EVALUATION COLLECTED FROM BLOCK
707 LOT 6 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

8

[LETTER]

R2-0140715

R2-0140722

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

209186

04/08/2002

REDACTED RESULTS OF INDOOR AIR
EVALUATION COLLECTED FROM BLOCK
708 LOT 2 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

10

[LETTER]

R2-0140723

R2-0140732

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

Page 11 of 81

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209171

04/08/2002

REDACTED RESULTS OF INDOOR AIR
EVALUATION COLLECTED FROM BLOCK
708 LOT 3 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

15

[LETTER]

R2-0140733

R2-0140747

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

209142

04/08/2002

REDACTED RESULTS OF INDOOR AIR
EVALUATION COLLECTED FROM BLOCK
708 LOT 9 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

8

[LETTER]

R2-0140748

R2-0140755

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

209086

04/08/2002

REDACTED RESULTS OF INDOOR AIR
EVALUATION COLLECTED FROM BLOCK
715 LOT 4 ON 01/14/2002 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

8

[LETTER]

R2-0140756

R2-0140763

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

209478

04/08/2002

REDACTED RESULTS OF INDOOR AIR
EVALUATION SAMPLES COLLECTED
FROM BLOCK 290 LOT 1 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

8

[LETTER]

R2-0140764

R2-0140771

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

209297

04/08/2002

REDACTED RESULTS OF INDOOR AIR
EVALUATION SAMPLES COLLECTED
FROM BLOCK 293 LOT 13 ON 12/27/2001
FOR THE WHITE SWAN LAUNDRY AND
CLEANER INCORPORATED SITE

9

[LETTER]

R2-0140772

R2-0140780

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

209259

04/08/2002

REDACTED RESULTS OF INDOOR AIR
EVALUATION SAMPLES COLLECTED
FROM BLOCK 293 LOT 3 ON 12/27/2001
FOR THE WHITE SWAN LAUNDRY AND
CLEANER INCORPORATED SITE

8

[LETTER]

R2-0140781

R2-0140788

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

209269

04/08/2002

REDACTED RESULTS OF INDOOR AIR
EVALUATION SAMPLES COLLECTED
FROM BLOCK 293 LOT 6 ON 12/27/2001
FOR THE WHITE SWAN LAUNDRY AND
CLEANER INCORPORATED SITE

8

[LETTER]

R2-0140789

R2-0140796

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

209486

04/08/2002

REDACTED RESULTS OF INDOOR AIR
EVALUATION SAMPLES COLLECTED
FROM BLOCK 295 LOT 3 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

8

[LETTER]

R2-0140797

R2-0140804

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

209480

04/08/2002

REDACTED RESULTS OF INDOOR AIR
EVALUATION SAMPLES COLLECTED
FROM BLOCK 299 LOT 22 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

8

[LETTER]

R2-0140805

R2-0140812

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

Page 12 of 81

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209367

04/08/2002

REDACTED RESULTS OF INDOOR AIR
EVALUATION SAMPLES COLLECTED
FROM BLOCK 706 LOT 4 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

9

[LETTER]

R2-0140813

R2-0140821

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

209290

04/08/2002

REDACTED RESULTS OF INDOOR AIR
EVALUATION SAMPLES COLLECTED
FROM BLOCK 707 LOT 10 ON 01/17/2002
FOR THE WHITE SWAN LAUNDRY AND
CLEANER INCORPORATED SITE

8

[LETTER]

R2-0140822

R2-0140829

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

209278

04/08/2002

REDACTED RESULTS OF INDOOR AIR
EVALUATION SAMPLES COLLECTED
FROM BLOCK 709 LOT 19 ON 01/09/2002
FOR THE WHITE SWAN LAUNDRY AND
CLEANER INCORPORATED SITE

8

[LETTER]

R2-0140830

R2-0140837

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

209320

04/08/2002

REDACTED RESULTS OF INDOOR AIR
EVALUATION SAMPLES COLLECTED
FROM BLOCK 711 LOT 7 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

8

[LETTER]

R2-0140838

R2-0140845

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

209286

04/08/2002

REDACTED RESULTS OF INDOOR AIR
EVALUATION SAMPLES COLLECTED
FROM BLOCK 711 LOT 8 ON 01/07/2002
FOR THE WHITE SWAN LAUNDRY AND
CLEANER INCORPORATED SITE

8

[LETTER]

R2-0140846

R2-0140853

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

209310

04/08/2002

REDACTED RESULTS OF INDOOR AIR
EVALUATION SAMPLES COLLECTED
FROM BLOCK 712 LOT 10 ON 01/03/2002
FOR THE WHITE SWAN LAUNDRY AND
CLEANER INCORPORATED SITE

8

[LETTER]

R2-0140854

R2-0140861

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

209497

04/08/2002

REDACTED RESULTS OF INDOOR AIR
EVALUATION SAMPLES COLLECTED
FROM BLOCK 721 LOT 7 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

8

[LETTER]

R2-0140862

R2-0140869

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

209535

04/08/2002

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED AT BLOCK 709 LOT
13 ON 01/16/2002 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

8

[LETTER]

R2-0140870

R2-0140877

DVD2

a

[]

[,]

[US ENVIRONMENTAL
PROTECTION AGENCY
REGION 2]

205961

04/08/2002

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 100
LOT 4 ON 01/15/2002 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

9

[LETTER]

R2-0140878

R2-0140886

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

Page 13 of 81

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Count:

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205964

04/08/2002

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 101
LOT 11 ON 01/14/2002 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

9

[LETTER]

R2-0140887

R2-0140895

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

205986

04/08/2002

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 102
LOT 2 ON 01/15/2002 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

8

[LETTER]

R2-0140896

R2-0140903

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

205991

04/08/2002

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 105
LOT 3 ON 01/17/2002 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

8

[LETTER]

R2-0140904

R2-0140911

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

209233

04/08/2002

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 278
LOT 15 ON 01/17/2002 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

8

[LETTER]

R2-0140912

R2-0140919

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

205950

04/08/2002

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 38
LOT 17 FOR THE WHITE SWAN LAUNDRY
AND CLEANER INCORPORATED SITE

9

[LETTER]

R2-0140920

R2-0140928

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

205975

04/08/2002

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 49
LOT 5 ON 01/17/2002 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

9

[LETTER]

R2-0140929

R2-0140937

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

205980

04/08/2002

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 61
LOT 1 ON 01/21/2002 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

8

[LETTER]

R2-0140938

R2-0140945

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

205955

04/08/2002

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 70
LOT 5 FOR THE WHITE SWAN LAUNDRY
AND CLEANER INCORPORATED SITE

8

[LETTER]

R2-0140946

R2-0140953

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

209599

04/08/2002

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 706
LOT 8.02 FROM 01/24/2002 -
03/13/2002 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

17

[LETTER]

R2-0140954

R2-0140970

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

Page 14 of 81

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205983

04/08/2002

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 80
LOT 3 ON 01/22/2002 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

8

[LETTER]

R2-0140971

R2-0140978

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

205958

04/08/2002

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 88
LOT 7 ON 01/15/2002 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

9

[LETTER]

R2-0140979

R2-0140987

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

209527

04/08/2002

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM FOR BLOCK
709 LOT 15 ON 01/09/2002 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

8

[LETTER]

R2-0140988

R2-0140995

DVD2

[,]

[RESIDENT]

[CONFORTINI, ANDREW L]

[EPA]

209592

04/08/2002

REDACTED RESULTS OF THE INDOOR AIR
EVALUATION SAMPLES COLLECTED
FROM BLOCK 708 LOT 10 ON 01/02/2002
FOR THE WHITE SWAN LAUNDRY AND
CLEANER INCORPORATED SITE

13

[LETTER]

R2-0140996

R2-0141008

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

198172

04/08/2002

RESULTS OF INDOOR AIR EVALUATION
SAMPLES COLLECTED AT THE PROPERTY
OF TRUST COMPANY BANK FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

8

[LETTER]

R2-0141009

R2-0141016

DVD2

a

[]

[CONFORTINI, ANDREW L]

[EPA]

209196

04/09/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 706 LOT 8.01 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141017

R2-0141017

DVD2

a

[]

[]

[]

209082

04/09/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 715 LOT 4 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141018

R2-0141018

DVD2

a

[]

[]

[]

209234

04/11/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 278 LOT 15 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141019

R2-0141019

DVD2

a

[]

[]

[]

209368

04/12/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 706 LOT 4 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141020

R2-0141020

DVD2

a

[]

[POTVIN, PAUL]

[EPA]

209591

04/12/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 708 LOT 10 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141021

R2-0141021

DVD2

a

[]

[]

[]

Page 15 of 81

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Count:

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209598

04/15/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 706 LOT 8.02 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141022

R2-0141022

DVD2

a

[]

[]

[]

145192

04/15/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 708 LOT 1 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141023

R2-0141023

DVD2

a

[]

[]

[]

209492

04/16/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 307 LOT 19 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141024

R2-0141024

DVD2

a

[]

[]

[]

198170

04/19/2002

ACCESS AGREEMENT FOR TRUST
COMPANY BANK FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141025

R2-0141025

DVD2

a

[]

[]

[]

198181

05/02/2002

ACCESS AGREEMENT FOR CUMBERLAND
FARMS, INCORPORATED FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[AGREEMENT]

R2-0141026

R2-0141027

DVD2

a

[]

[]

[]

209311

05/03/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 712 LOT 10 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141028

R2-0141028

DVD2

a

[]

[]

[]

209293

05/20/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 289 LOT 12 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141029

R2-0141029

DVD2

a

[]

[]

[]

209264

05/20/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 293 LOT 4 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141030

R2-0141030

DVD2

a

[]

[]

[]

209483

05/22/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 301 LOT 4 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141031

R2-0141031

DVD2

a

[]

[]

[]

209481

05/22/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 307 LOT 3 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141032

R2-0141032

DVD2

a

[]

[]

[]

209498

05/28/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 721 LOT 3 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141033

R2-0141033

DVD2

a

[]

[]

[]

209341

05/30/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 285 LOT 5 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141034

R2-0141034

DVD2

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[]

[CIPOLLA, ROSARIO ]

[EPA]

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209328

06/04/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 711 LOT 5 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141035

R2-0141035

DVD2

a

[]

[,]

[EPA, REGION 2]

209315

06/05/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 712 LOT 7 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141036

R2-0141036

DVD2

a

[]

[,]

[EPA, REGION 2]

209488

06/16/2002

REDACTED ACCESS AGREEMENT FOR
BLOCK 170 LOT 21 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141037

R2-0141037

DVD2

a

[]

[]

[]

209180

08/15/2002

REDACTED RESULTS OF SOIL GAS
SAMPLES COLLECTED FROM BLOCK 706
LOT 9.01 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

10

[LETTER]

R2-0141038

R2-0141047

DVD2

a

[]

[BUDROE, THOMAS]

[EPA, REGION 2]

209197

08/23/2002

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 706
LOT 8.01 ON 06/25/2002 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141048

R2-0141048

DVD2

a

[]

[BUDROE, THOMAS]

[EPA, REGION 2]

209597

08/23/2002

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 706
LOT 8.02 ON 06/25/2002 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141049

R2-0141051

DVD2

a

[]

[BUDROE, THOMAS]

[EPA, REGION 2]

145191

08/23/2002

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 708
LOT 1 ON 06/25/2002 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141052

R2-0141054

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209590

08/23/2002

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 708
LOT 10 ON 06/25/2002 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141055

R2-0141057

DVD2

a

[]

[BUDROE, THOMAS]

[EPA, REGION 2]

209187

08/23/2002

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 708
LOT 2 ON 06/25/2002 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141058

R2-0141060

DVD2

a

[]

[BUDROE, THOMAS]

[EPA, REGION 2]

209172

08/23/2002

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 708
LOT 3 ON 06/25/2002 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141061

R2-0141063

DVD2

a

[]

[BUDROE, THOMAS]

[EPA, REGION 2]

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209085

09/24/2002

REDACTED RESULTS OF INDOOR AIR AND
SOIL GAS RESULTS COLLECTED FROM
BLOCK 715 LOT 4 ON 04/11/2002 FOR
THE WHITE SWAN LAUNDRY AND
CLEANER INCORPORATED SITE

11

[LETTER]

R2-0141064

R2-0141074

DVD2

a

[]

[BUDROE, THOMAS]

[EPA, REGION 2]

209489

09/24/2002

REDACTED RESULTS OF INDOOR AIR AND
SOIL GAS SAMPLES COLLECTED FROM
BLOCK 170 LOT 21 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

12

[LETTER]

R2-0141075

R2-0141086

DVD2

a

[]

[BUDROE, THOMAS]

[EPA, REGION 2]

209235

09/24/2002

REDACTED RESULTS OF INDOOR AIR AND
SOIL GAS SAMPLES COLLECTED FROM
BLOCK 278 LOT 15 ON 04/12/2002 FOR
THE WHITE SWAN LAUNDRY AND
CLEANER INCORPORATED SITE

11

[LETTER]

R2-0141087

R2-0141097

DVD2

a

[]

[BUDROE, THOMAS]

[EPA, REGION 2]

209484

09/24/2002

REDACTED RESULTS OF INDOOR AIR AND
SOIL GAS SAMPLES COLLECTED FROM
BLOCK 301 LOT 4 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

11

[LETTER]

R2-0141098

R2-0141108

DVD2

a

[]

[BUDROE, THOMAS]

[EPA, REGION 2]

209493

09/24/2002

REDACTED RESULTS OF INDOOR AIR AND
SOIL GAS SAMPLES COLLECTED FROM
BLOCK 307 LOT 19 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

12

[LETTER]

R2-0141109

R2-0141120

DVD2

a

[]

[BUDROE, THOMAS]

[EPA, REGION 2]

209482

09/24/2002

REDACTED RESULTS OF INDOOR AIR AND
SOIL GAS SAMPLES COLLECTED FROM
BLOCK 307 LOT 3 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

11

[LETTER]

R2-0141121

R2-0141131

DVD2

a

[]

[BUDROE, THOMAS]

[EPA, REGION 2]

209499

09/24/2002

REDACTED RESULTS OF INDOOR AIR AND
SOIL GAS SAMPLES COLLECTED FROM
BLOCK 721 LOT 3 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

10

[LETTER]

R2-0141132

R2-0141141

DVD2

a

[]

[BUDROE, THOMAS]

[EPA, REGION 2]

209347

09/24/2002

REDACTED RESULTS OF SOIL GAS AND
INDOOR AIR SAMPLES COLLECTED FROM
BLOCK 285 LOT 4 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

10

[LETTER]

R2-0141142

R2-0141151

DVD2

a

[]

[BUDROE, THOMAS]

[EPA, REGION 2]

209294

09/24/2002

REDACTED RESULTS OF SOIL GAS AND
INDOOR AIR SAMPLES COLLECTED FROM
BLOCK 289 LOT 12 ON 05/21/2012 FOR
THE WHITE SWAN LAUNDRY AND
CLEANER INCORPORATED SITE

11

[LETTER]

R2-0141152

R2-0141162

DVD2

a

[]

[BUDROE, THOMAS]

[EPA, REGION 2]

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209279

09/24/2002

REDACTED RESULTS OF SOIL GAS AND
INDOOR AIR SAMPLES COLLECTED FROM
BLOCK 709 LOT 19 ON 04/09/2002 FOR
THE WHITE SWAN LAUNDRY AND
CLEANER INCORPORATED SITE

11

[LETTER]

R2-0141163

R2-0141173

DVD2

a

[]

[BUDROE, THOMAS]

[EPA, REGION 2]

209329

09/24/2002

REDACTED RESULTS OF SOIL GAS AND
INDOOR AIR SAMPLES COLLECTED FROM
BLOCK 711 LOT 5 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

10

[LETTER]

R2-0141174

R2-0141183

DVD2

a

[]

[BUDROE, THOMAS]

[EPA, REGION 2]

209321

09/24/2002

REDACTED RESULTS OF SOIL GAS AND
INDOOR AIR SAMPLES COLLECTED FROM
BLOCK 711 LOT 7 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

11

[LETTER]

R2-0141184

R2-0141194

DVD2

a

[]

[BUDROE, THOMAS]

[EPA, REGION 2]

209312

09/24/2002

REDACTED RESULTS OF SOIL GAS AND
INDOOR AIR SAMPLES COLLECTED FROM
BLOCK 712 LOT 10 ON 04/09/2002 FOR
THE WHITE SWAN LAUNDRY AND
CLEANER INCORPORATED SITE

11

[LETTER]

R2-0141195

R2-0141205

DVD2

a

[]

[BUDROE, THOMAS]

[EPA, REGION 2]

209316

09/24/2002

REDACTED RESULTS OF SOIL GAS AND
INDOOR AIR SAMPLES COLLECTED FROM
BLOCK 712 LOT 7 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

11

[LETTER]

R2-0141206

R2-0141216

DVD2

a

[]

[BUDROE, THOMAS]

[EPA, REGION 2]

209265

09/24/2002

REDACTED RESULTS OF SOIL GAS
SAMPLES COLLECTED FROM BLOCK 293
LOT 4 ON 05/21/2002 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

11

[LETTER]

R2-0141217

R2-0141227

DVD2

a

[]

[BUDROE, THOMAS]

[EPA, REGION 2]

209369

09/24/2002

REDACTED RESULTS OF SOIL GAS
SAMPLES COLLECTED FROM BLOCK 706
LOT 4 FOR THE WHITE SWAN LAUNDRY
AND CLEANER INCORPORATED SITE

5

[LETTER]

R2-0141228

R2-0141232

DVD2

a

[]

[BUDROE, THOMAS]

[EPA, REGION 2]

209198

09/24/2002

REDACTED RESULTS OF SOIL GAS
SAMPLES COLLECTED FROM BLOCK 706
LOT 8.01 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

7

[LETTER]

R2-0141233

R2-0141239

DVD2

a

[]

[BUDROE, THOMAS]

[EPA, REGION 2]

209596

09/24/2002

REDACTED RESULTS OF SOIL GAS
SAMPLES COLLECTED FROM BLOCK 706
LOT 8.02 ON 04/15/2002 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

6

[LETTER]

R2-0141240

R2-0141245

DVD2

a

[]

[BUDROE, THOMAS]

[EPA, REGION 2]

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145190

09/24/2002

REDACTED RESULTS OF SOIL GAS
SAMPLES COLLECTED FROM BLOCK 708
LOT 1 ON 04/15/2002 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

6

[LETTER]

R2-0141246

R2-0141251

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209589

09/24/2002

REDACTED RESULTS OF SOIL GAS
SAMPLES COLLECTED FROM BLOCK 708
LOT 10 ON 04/25/2002 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

6

[LETTER]

R2-0141252

R2-0141257

DVD2

a

[]

[BUDROE, THOMAS]

[EPA, REGION 2]

198182

09/24/2002

RESULTS OF SOIL GAS SAMPLES
COLLECTED AT THE PROPERTY OF
CUMBERLAND FARMS, INCORPORATED
FOR THE WHITE SWAN LAUNDRY AND
CLEANER INCORPORATED SITE

4

[LETTER]

R2-0141258

R2-0141261

DVD2

[,]

[CUMBERLAND FARMS
INC]

[BUDROE, THOMAS]

[EPA, REGION 2]

209199

10/18/2002

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 706
LOT 8.01 ON 09/10/2002 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141262

R2-0141264

DVD2

a

[]

[BUDROE, THOMAS]

[EPA, REGION 2]

209595

10/18/2002

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 706
LOT 8.02 ON 09/10/2002 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141265

R2-0141265

DVD2

a

[]

[BUDROE, THOMAS]

[EPA, REGION 2]

145189

10/18/2002

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 708
LOT 1 ON 09/10/2002 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141266

R2-0141266

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209588

10/18/2002

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 708
LOT 10 ON 09/10/2002 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141267

R2-0141267

DVD2

a

[]

[BUDROE, THOMAS]

[EPA, REGION 2]

209173

10/18/2002

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 708
LOT 3 ON 09/10/2002 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

4

[LETTER]

R2-0141268

R2-0141271

DVD2

a

[]

[BUDROE, THOMAS]

[EPA, REGION 2]

209200

12/02/2002

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 706
LOT 8.01 ON 11/13/2002 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0141272

R2-0141273

DVD2

a

[]

[BUDROE, THOMAS]

[EPA, REGION 2]

Page 20 of 81

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145188

12/02/2002

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 708
LOT 1 ON 10/18/2002 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0141274

R2-0141275

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209587

12/02/2002

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 708
LOT 10 ON 10/18/2002 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0141276

R2-0141277

DVD2

a

[]

[BUDROE, THOMAS]

[EPA, REGION 2]

209201

01/22/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 706
LOT 8.01 ON 11/13/2002 AND
12/16/2002 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[LETTER]

R2-0141278

R2-0141278

DVD2

a

[]

[BUDROE, THOMAS]

[EPA, REGION 2]

209188

01/22/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 708
LOT 2 ON 12/16/2002 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141279

R2-0141279

DVD2

a

[]

[BUDROE, THOMAS]

[EPA, REGION 2]

209348

01/23/2003

REDACTED ACCESS AGREEMENT FOR
BLOCK 285 LOT 4 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141280

R2-0141280

DVD2

a

[]

[,]

[EPA, REGION 2]

209586

01/29/2003

REDACTED ACCESS AGREEMENT FOR
BLOCK 708 LOT 10 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141281

R2-0141281

DVD2

a

[]

[]

[]

209349

04/14/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 285
LOT 4 ON MARCH 19, 2003 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141282

R2-0141282

DVD2

a

[]

[BUDROE, THOMAS]

[EPA, REGION 2]

209585

04/14/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 708
LOT 10 ON 03/19/2003 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141283

R2-0141283

DVD2

a

[]

[BUDROE, THOMAS]

[EPA, REGION 2]

209189

04/14/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 708
LOT 2 ON 03/19/2003 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141284

R2-0141284

DVD2

a

[]

[BUDROE, THOMAS]

[EPA, REGION 2]

209577

08/12/2003

REDACTED ACCESS AGREEMENT FOR
BLOCK 708 LOT 2 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141285

R2-0141285

DVD2

a

[]

[]

[]

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209504

08/12/2003

REDACTED ACCESS AGREEMENT FOR
BLOCK 718 LOT 2 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141286

R2-0141286

DVD2

a

[]

[]

[]

209578

08/21/2003

REDACTED ACCESS AGREEMENT FOR
BLOCK 708 LOT 6 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141287

R2-0141287

DVD2

a

[]

[]

[]

209576

09/04/2003

REDACTED ACCESS AGREEMENT FOR
BLOCK 280 LOT 24 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[AGREEMENT]

R2-0141288

R2-0141290

DVD2

a

[]

[]

[]

209376

09/11/2003

REDACTED ACCESS AGREEMENT FOR
LEASED PROPERTY AT BLOCK 299 LOT 1
FOR THE WHITE SWAN LAUNDRY AND
CLEANER INCORPORATED SITE

2

[LETTER]

R2-0141291

R2-0141292

DVD2

[WESTGATE, MATTHEW ]

[EPA]

[]

[]

209350

09/24/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 285
LOT 4 ON AUGUST 12, 2003 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141293

R2-0141293

DVD2

[]

[]

[WESTGATE, MATTHEW ]

[EPA]

209089

09/25/2003

REDACTED RESULTS OF INDOOR AIR
EVALUATION COLLECTED FROM BLOCK
280 LOT 24 ON 08/11/2003 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141294

R2-0141294

DVD2

[]

[]

[WESTGATE, MATTHEW ]

[EPA]

209510

09/25/2003

REDACTED RESULTS OF INDOOR AIR
EVALUATION SAMPLES COLLECTED
FROM BLOCK 718 LOT 2 ON 08/12/2003
FOR THE WHITE SWAN LAUNDRY AND
CLEANER INCORPORATED SITE

3

[LETTER]

R2-0141295

R2-0141297

DVD2

[]

[]

[WESTGATE, MATTHEW ]

[EPA]

209512

09/25/2003

REDACTED RESULTS OF INDOOR AIR
EVALUATION SAMPLES COLLECTED
FROM BLOCK 718 LOT 2 ON 08/12/2003
FOR THE WHITE SWAN LAUNDRY AND
CLEANER INCORPORATED SITE

3

[LETTER]

R2-0141298

R2-0141300

DVD2

[]

[]

[WESTGATE, MATTHEW ]

[EPA]

209530

09/25/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED AT BLOCK 708 LOT
10 ON 08/13/2003, FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141301

R2-0141303

DVD2

[]

[]

[WESTGATE, MATTHEW ]

[EPA]

209202

09/25/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 706
LOT 8.01 ON 08/13/2003 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0141304

R2-0141305

DVD2

[]

[]

[WESTGATE, MATTHEW ]

[EPA]

Page 22 of 81

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Count:

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209594

09/25/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 706
LOT 8.02 ON 08/13/2003 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141306

R2-0141308

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209190

09/25/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 708
LOT 2 ON 08/13/2003 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0141309

R2-0141310

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209174

09/25/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 708
LOT 3 ON 08/13/2003 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141311

R2-0141313

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209435

10/02/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 708
LOT 1 ON 08/13/2003 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141314

R2-0141316

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208992

10/17/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 278
LOT 7 ON 09/10/2003 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141317

R2-0141317

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209010

10/21/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 278
LOT 1 ON 09/08/2003 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141318

R2-0141320

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208907

10/21/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 280
LOT 90 ON 08/20/2003 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141321

R2-0141321

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209126

10/21/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 707
LOT 9 ON 08/20/2003 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141322

R2-0141324

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209157

10/21/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 708
LOT 6 ON 08/21/2003 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141325

R2-0141327

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

Page 23 of 81

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208931

10/21/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 719
LOT 15 ON 09/08/2003 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141328

R2-0141330

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209505

10/22/2003

REDACTED RESULTS OF INDOOR AIR
EVALUATION SAMPLES COLLECTED
FROM BLOCK 282 LOT 27 ON 09/08/2003
FOR THE WHITE SWAN LAUNDRY AND
CLEANER INCORPORATED SITE

1

[LETTER]

R2-0141331

R2-0141331

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209507

10/22/2003

REDACTED RESULTS OF INDOOR AIR
EVALUATION SAMPLES COLLECTED
FROM BLOCK 282 LOT 27 ON 09/08/2003
FOR THE WHITE SWAN LAUNDRY AND
CLEANER INCORPORATED SITE

3

[LETTER]

R2-0141332

R2-0141334

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209045

10/22/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 279
LOT 6 ON 09/08/2003 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141335

R2-0141337

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208905

10/22/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 281
LOT 21 ON 09/8/2003 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141338

R2-0141338

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208911

10/22/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 341
LOT 19 ON 09/08/2003 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141339

R2-0141341

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209554

10/22/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 708
LOT 18 ON 01/09/2002 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141342

R2-0141344

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208958

10/23/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FOR BLOCK 297
LOT 2 ON 09/08/2003 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141345

R2-0141347

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209070

10/23/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 276
LOT 8 ON 09/10/2003 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141348

R2-0141350

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

Page 24 of 81

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Count:

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209055

10/23/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 278
LOT 6 ON 09/10/2003 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141351

R2-0141353

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209160

10/23/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 707
LOT 1 ON 09/10/2003 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141354

R2-0141356

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209217

10/23/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 713
LOT 5 ON 09/08/2003 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141357

R2-0141359

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209355

10/30/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 707
LOT 16 ON SEPTEMBER 15, 2003 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141360

R2-0141362

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208988

10/31/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FOR BLOCK 278
LOT 3.01 ON 09/15/2003 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141363

R2-0141365

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208957

10/31/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FOR BLOCK 278
LOT 8 ON 09/15/2003 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141366

R2-0141368

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

145182

10/31/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 280
LOT 28 ON 09/15/2003 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141369

R2-0141369

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209569

10/31/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 280
LOT 28 ON 09/15/2003 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141370

R2-0141372

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208900

10/31/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 281
LOT 21 ON 0915/2003 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141373

R2-0141375

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

Page 25 of 81

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Count:

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209205

10/31/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 285
LOT 12 ON 09/15/2003 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141376

R2-0141378

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209337

10/31/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 285
LOT 26 ON SEPTEMBER 15, 2003 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141379

R2-0141381

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209343

10/31/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 285
LOT 4 ON SEPTEMBER 15, 2003 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141382

R2-0141382

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209568

10/31/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 707
LOT 18 ON 09/15/2003 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141383

R2-0141385

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209208

10/31/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 713
LOT 3 ON 09/15/2003 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141386

R2-0141388

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209244

11/03/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 710
LOT 2 ON 11/03/2003 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[FORM]

R2-0141389

R2-0141390

DVD2

a

[]

[]

[]

209302

11/05/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 284
LOT 7 ON 10/24/2002 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141391

R2-0141391

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209214

11/05/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 285
LOT 14 ON 09/25/2003 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141392

R2-0141394

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208923

11/05/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 719
LOT 13 ON 09/25/2003 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141395

R2-0141397

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

Page 26 of 81

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Image
Count:

Doc Type:

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Ending Bates:

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Author Organization:

145187

12/02/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 708
LOT 1 ON 08/13/2003 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141398

R2-0141400

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208972

12/03/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FOR BLOCK 707
LOT 11 ON SEPTEMBER 29, 2003 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141401

R2-0141403

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209203

12/03/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 706
LOT 8.01 ON 10/02/2003 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141404

R2-0141406

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209106

12/03/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 711
LOT 15 ON 09/29/2003 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141407

R2-0141409

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209211

12/03/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 713
LOT 4 ON 09/29/2003 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141410

R2-0141412

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209223

12/04/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 716
LOT 31 ON 10/02/2003 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141413

R2-0141415

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208956

12/18/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 299
LOT 1 ON 10/16/2003 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141416

R2-0141418

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209469

12/22/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 301
LOT 16 ON 11/03/2003 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141419

R2-0141421

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209300

12/22/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 301
LOT 17 ON 11/03/2003 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

7

[LETTER]

R2-0141422

R2-0141428

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

Page 27 of 81

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Site Name: WHITE SWAN LAUNDRY AND CLEANER INC
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Image
Count:

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Ending Bates:

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Author Organization:

209094

12/23/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 289
LOT 4 ON 11/03/ 2003 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141429

R2-0141431

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

205946

12/23/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 38
LOT 9.01 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

3

[LETTER]

R2-0141432

R2-0141434

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209503

12/23/2003

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 710
LOT 2 ON 11/03/2003 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

4

[LETTER]

R2-0141435

R2-0141438

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209375

01/29/2004

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 279
LOT 7 ON NOVEMBER 17, 2003 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141439

R2-0141441

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

198183

02/04/2004

INDOOR AIR QUALITY BUILDING SURVEY
FOR CUMBERLAND FARMS,
INCORPORATED FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

2

[FORM]

R2-0141442

R2-0141443

DVD2

a

[]

[,]

[EPA, REGION 2]

209049

03/19/2004

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 279
LOT 7 ON 01/24/2004 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

5

[LETTER]

R2-0141444

R2-0141448

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209182

03/19/2004

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 706
LOT 9.01 ON 01/21/2004 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141449

R2-0141451

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209228

03/19/2004

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 716
LOT 32 ON 01/21/2004 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141452

R2-0141454

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209063

03/22/2004

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 278
LOT 7 ON 01/21/2004 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

5

[LETTER]

R2-0141455

R2-0141459

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

Page 28 of 81

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Site Name: WHITE SWAN LAUNDRY AND CLEANER INC
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OUID: 01
SSID: 02RX
Action:

DocID:

Doc Date:

Title:

Image
Count:

Doc Type:

Beginning Bates:

Ending Bates:

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Author Name:

Author Organization:

209058

03/22/2004

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 278
LOT 9 ON 01/21/2004 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141460

R2-0141462

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208975

03/29/2004

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FOR BLOCK 706
LOT 9.02 ON 01/21/2004 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141463

R2-0141465

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209164

03/30/2004

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 708
LOT 5 ON 01/21/2004 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141466

R2-0141468

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209330

03/30/2004

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 711
LOT 5 ON JANUARY 21, 2004 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141469

R2-0141471

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209005

03/31/2004

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 278
LOT 31 ON 01/21/2004 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141472

R2-0141474

DVD2

a

[]

[]

[]

209338

03/31/2004

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 285
LOT 26 ON JANUARY 21, 2004 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

5

[LETTER]

R2-0141475

R2-0141479

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209146

04/02/2004

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 708
LOT 8 ON 01/22/2004 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141480

R2-0141482

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209476

04/02/2004

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 709
LOT 2 ON 01/26/2004 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141483

R2-0141485

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209333

04/02/2004

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 711
LOT 4 ON JANUARY 22, 2004 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141486

R2-0141488

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

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209084

04/02/2004

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 715
LOT 4 ON 01/26/2004 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141489

R2-0141491

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209024

05/24/2004

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 285
LOT 18 ON 02/02/2004 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141492

R2-0141494

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209151

05/24/2004

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 708
LOT 7 ON 02/02/2004 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141495

R2-0141497

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209280

05/24/2004

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 709
LOT 19 ON 02/02/2004 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141498

R2-0141500

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

198184

05/24/2004

RESULTS OF INDOOR AIR SAMPLES
COLLECTED AT THE PROPERTY OF
CUMBERLAND FARMS, INCORPORATED
FOR THE WHITE SWAN LAUNDRY AND
CLEANER INCORPORATED SITE

3

[LETTER]

R2-0141501

R2-0141503

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209220

05/25/2004

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 278
LOT 11 ON 03/02/2004 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

5

[LETTER]

R2-0141504

R2-0141508

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208908

05/25/2004

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 280
LOT 90 ON 02/02/2004 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141509

R2-0141511

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209167

05/25/2004

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 708
LOT 4 ON 02/02/2004 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141512

R2-0141514

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209245

05/25/2004

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 710
LOT 2 ON 03/02/2004 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

5

[LETTER]

R2-0141515

R2-0141519

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

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209322

05/25/2004

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 711
LOT 7 ON FEBRUARY 2, 2004 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141520

R2-0141522

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209057

02/13/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 278 LOT 9 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141523

R2-0141523

DVD2

a

[]

[]

[]

209331

02/13/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 711 LOT 5 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141524

R2-0141524

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209062

02/14/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 278 LOT 7 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141525

R2-0141525

DVD2

a

[]

[]

[]

209529

02/14/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 708 LOT 10 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141526

R2-0141526

DVD2

a

[]

[]

[]

209584

02/14/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 708 LOT 10 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141527

R2-0141527

DVD2

a

[]

[]

[]

208915

02/14/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 709 LOT 2 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141528

R2-0141528

DVD2

a

[]

[]

[]

209538

02/15/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 708 LOT 13 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141529

R2-0141529

DVD2

a

[]

[]

[]

209175

02/15/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 708 LOT 3 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141530

R2-0141530

DVD2

a

[]

[]

[]

209323

02/20/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 711 LOT 7 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141531

R2-0141531

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208974

02/21/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 706 LOT 9.02 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141532

R2-0141532

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209127

02/23/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 707 LOT 9 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141533

R2-0141533

DVD2

a

[]

[]

[]

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209183

02/26/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 706 LOT 9.01 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141534

R2-0141534

DVD2

a

[]

[]

[]

209434

02/27/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 706 LOT 8.02 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141535

R2-0141535

DVD2

a

[]

[]

[]

209003

03/02/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 278 LOT 31 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141536

R2-0141536

DVD2

a

[]

[]

[]

145200

03/04/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 708 LOT 1 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141537

R2-0141537

DVD2

a

[]

[]

[]

209114

03/06/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 710 LOT 11 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141538

R2-0141538

DVD2

a

[]

[]

[]

209165

03/07/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 708 LOT 5 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141539

R2-0141539

DVD2

a

[]

[]

[]

198185

03/08/2006

ACCESS AGREEMENT FOR CUMBERLAND
FARMS, INCORPORATED FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141540

R2-0141540

DVD2

a

[]

[]

[]

208901

03/10/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 281 LOT 21 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141541

R2-0141541

DVD2

a

[]

[]

[]

209281

03/10/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 709 LOT 19 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141542

R2-0141542

DVD2

a

[]

[]

[]

209351

03/11/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 285 LOT 4 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141543

R2-0141543

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

198186

03/13/2006

COMMERCIAL QUESTIONNAIRE OF EPA
INDOOR AIR SAMPLING STUDY FOR
CUMBERLAND FARMS, INCORPORATED
FOR THE WHITE SWAN LAUNDRY AND
CLEANER INCORPORATED SITE

6

[FORM]

R2-0141544

R2-0141549

DVD2

a

[]

[]

[]

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198187

03/13/2006

INDOORAIRSAMPLING LOG (SUMMA
CANISTER) FOR CUMBERLAND FARMS,
INCORPORATED FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

2

[REPORT]

R2-0141550

R2-0141551

DVD2

a

[]

[,]

[CH2M HILL]

209023

03/14/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 285 LOT 18 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141552

R2-0141552

DVD2

a

[]

[]

[]

209147

03/14/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 708 LOT 8 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141553

R2-0141553

DVD2

a

[]

[]

[]

208909

03/15/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 280 LOT 90 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141554

R2-0141554

DVD2

a

[]

[]

[]

208971

03/15/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 707 LOT 11 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141555

R2-0141555

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209356

03/15/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 707 LOT 16 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141556

R2-0141556

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209158

03/15/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 708 LOT 6 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141557

R2-0141557

DVD2

a

[]

[]

[]

209168

03/16/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 708 LOT 4 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141558

R2-0141558

DVD2

a

[]

[]

[]

208926

03/16/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 709 LOT 6 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141559

R2-0141559

DVD2

a

[]

[]

[]

209079

03/16/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 715 LOT 2 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141560

R2-0141560

DVD2

a

[]

[]

[]

209537

03/17/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 708 LOT 12 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141561

R2-0141561

DVD2

a

[]

[]

[]

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209191

03/17/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 708 LOT 2 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141562

R2-0141562

DVD2

a

[]

[]

[]

208930

03/17/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 719 LOT 15 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141563

R2-0141563

DVD2

a

[]

[]

[]

209560

03/19/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 276 LOT 4 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141564

R2-0141564

DVD2

a

[]

[]

[]

209041

03/20/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 279 LOT 5 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141565

R2-0141565

DVD2

a

[]

[]

[]

209550

03/20/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 708 LOT 17 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141566

R2-0141566

DVD2

a

[]

[]

[]

209043

03/22/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 279 LOT 6 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141567

R2-0141567

DVD2

a

[]

[]

[]

209068

03/23/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 276 LOT 8 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141568

R2-0141568

DVD2

a

[]

[]

[]

209065

03/27/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 278 LOT 6 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141569

R2-0141569

DVD2

a

[]

[]

[]

209206

03/27/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 285 LOT 12 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141570

R2-0141570

DVD2

a

[]

[]

[]

208904

03/28/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 280 LOT 84 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141571

R2-0141571

DVD2

a

[]

[]

[]

209246

03/28/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 710 LOT 2 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141572

R2-0141572

DVD2

a

[]

[]

[]

208977

03/28/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 93 LOT 1 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141573

R2-0141573

DVD2

a

[]

[]

[]

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208991

03/30/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 718 LOT 5 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141574

R2-0141574

DVD2

a

[]

[]

[]

209054

03/31/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 278 LOT 6 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141575

R2-0141575

DVD2

a

[]

[]

[]

209002

04/03/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 278 LOT 4 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141576

R2-0141576

DVD2

a

[]

[]

[]

145185

04/04/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 280 LOT 28 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141577

R2-0141577

DVD2

a

[]

[]

[]

208903

04/04/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 280 LOT 28 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141578

R2-0141578

DVD2

a

[]

[]

[]

209353

04/06/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 707 LOT 17 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141579

R2-0141579

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209545

04/06/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 708 LOT 15 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141580

R2-0141580

DVD2

a

[]

[]

[]

209133

04/07/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 707 LOT 7 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141581

R2-0141581

DVD2

a

[]

[]

[]

209149

04/08/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 707 LOT 3 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141582

R2-0141582

DVD2

a

[]

[]

[]

209215

04/10/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 285 LOT 14 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141583

R2-0141583

DVD2

a

[]

[]

[]

209557

04/10/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 708 LOT 18 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141584

R2-0141584

DVD2

a

[]

[]

[]

209547

04/11/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 708 LOT 16 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141585

R2-0141585

DVD2

a

[]

[]

[]

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209218

04/12/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 713 LOT 5 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141586

R2-0141586

DVD2

a

[]

[]

[]

209212

04/14/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 713 LOT 4 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141587

R2-0141587

DVD2

a

[]

[]

[]

209093

04/15/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 289 LOT 4 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141588

R2-0141588

DVD2

a

[]

[]

[]

209129

04/15/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 707 LOT 8 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141589

R2-0141589

DVD2

a

[]

[]

[]

209141

04/16/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 708 LOT 9 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141590

R2-0141590

DVD2

a

[]

[]

[]

209511

04/19/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 718 LOT 2 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141591

R2-0141591

DVD2

a

[]

[]

[]

209152

04/20/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 708 LOT 7 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141592

R2-0141592

DVD2

a

[]

[]

[]

209344

04/24/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 285 LOT 4 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141593

R2-0141593

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209260

04/24/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 293 LOT 3 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141594

R2-0141594

DVD2

a

[]

[]

[]

209266

04/24/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 293 LOT 4 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141595

R2-0141595

DVD2

a

[]

[]

[]

209397

04/24/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 293 LOT 4 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141596

R2-0141596

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209262

04/24/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 297 LOT 13 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141597

R2-0141597

DVD2

a

[]

[]

[]

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209161

04/24/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 707 LOT 1 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141598

R2-0141598

DVD2

a

[]

[]

[]

209361

04/26/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 707 LOT 12 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141599

R2-0141599

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209359

04/26/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 707 LOT 14 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141600

R2-0141600

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209081

04/27/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 715 LOT 4 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141601

R2-0141601

DVD2

a

[]

[]

[]

209342

05/01/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 285 LOT 5 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141602

R2-0141602

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209144

05/01/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 707 LOT 4 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141603

R2-0141603

DVD2

a

[]

[]

[]

209299

05/02/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 297 LOT 15 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141604

R2-0141604

DVD2

a

[]

[]

[]

209399

05/02/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 297 LOT 15 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141605

R2-0141605

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209291

05/03/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 707 LOT 10 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141606

R2-0141606

DVD2

a

[]

[]

[]

209270

05/08/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 297 LOT 11 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141607

R2-0141607

DVD2

a

[]

[]

[]

209398

05/08/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 297 LOT 11 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141608

R2-0141608

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208955

05/08/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 299 LOT 1 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141609

R2-0141609

DVD2

a

[]

[]

[]

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209123

05/09/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 709 LOT 21 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141610

R2-0141610

DVD2

a

[]

[]

[]

197621

05/10/2006

ACCESS AGREEMENT FOR THE SEA GIRT
LODGE FOR THE WHITE SWAN LAUNDRY
AND CLEANER INCORPORATED SITE

1

[AGREEMENT]

R2-0141611

R2-0141611

DVD2

a

[]

[]

[]

208942

05/10/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 276 LOT 11 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141612

R2-0141612

DVD2

a

[]

[]

[]

209556

05/10/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 276 LOT 5 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141613

R2-0141613

DVD2

a

[]

[]

[]

209088

05/10/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 280 LOT 24 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141614

R2-0141614

DVD2

a

[]

[]

[]

209131

05/10/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 709 LOT 17 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141615

R2-0141615

DVD2

a

[]

[]

[]

209110

05/10/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 710 LOT 13 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141616

R2-0141616

DVD2

a

[]

[]

[]

209226

05/10/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 716 LOT 32 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141617

R2-0141617

DVD2

a

[]

[]

[]

209526

05/11/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 709 LOT 15 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141618

R2-0141618

DVD2

a

[]

[]

[]

209303

05/13/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 284 LOT 7 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141619

R2-0141619

DVD2

a

[]

[]

[]

209553

05/14/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 276 LOT 6 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141620

R2-0141620

DVD2

a

[]

[]

[]

209248

05/15/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 297 LOT 9 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141621

R2-0141621

DVD2

a

[]

[]

[]

Page 38 of 81

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209249

05/15/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 297 LOT 9 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141622

R2-0141622

DVD2

a

[]

[]

[]

209137

05/15/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 707 LOT 5 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141623

R2-0141623

DVD2

a

[]

[]

[]

208917

05/15/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 709 LOT 3 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141624

R2-0141624

DVD2

a

[]

[]

[]

208921

05/16/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 709 LOT 4 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141625

R2-0141625

DVD2

a

[]

[]

[]

209117

05/16/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 710 LOT 10 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141626

R2-0141626

DVD2

a

[]

[]

[]

208954

05/17/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 299 LOT 1 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141627

R2-0141627

DVD2

a

[]

[]

[]

208924

05/18/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 719 LOT 13 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141628

R2-0141628

DVD2

a

[]

[]

[]

209224

05/22/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 716 LOT 31 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141629

R2-0141629

DVD2

a

[]

[]

[]

209103

05/23/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 710 LOT 17 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141630

R2-0141630

DVD2

a

[]

[]

[]

197624

05/26/2006

ACCESS AGREEMENT FOR THE FRIENDS
MEETING HOUSE FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141631

R2-0141631

DVD2

a

[]

[]

[]

208960

05/26/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 297 LOT 7 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141632

R2-0141632

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209523

05/28/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 709 LOT 16 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141633

R2-0141633

DVD2

a

[]

[]

[]

Page 39 of 81

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209121

05/30/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 710 LOT 9 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141634

R2-0141634

DVD2

a

[]

[]

[]

209162

05/31/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 707
LOT 1 ON 04/26/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

4

[LETTER]

R2-0141635

R2-0141638

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209502

05/31/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 707
LOT 1 ON 04/26/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141639

R2-0141639

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209549

06/05/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 276 LOT 7 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141640

R2-0141640

DVD2

a

[]

[]

[]

209508

06/05/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 282 LOT 27 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141641

R2-0141641

DVD2

a

[]

[]

[]

209255

06/05/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 293 LOT 1 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141642

R2-0141642

DVD2

a

[]

[]

[]

209238

06/06/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 710 LOT 6 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141643

R2-0141643

DVD2

a

[]

[]

[]

209287

06/08/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 711 LOT 8 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141644

R2-0141644

DVD2

a

[]

[]

[]

209283

06/08/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 711 LOT 9 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141645

R2-0141645

DVD2

a

[]

[]

[]

209034

06/10/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 285 LOT 20 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141646

R2-0141646

DVD2

a

[]

[]

[]

209020

06/10/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 285 LOT 23 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141647

R2-0141647

DVD2

a

[]

[]

[]

Page 40 of 81

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208946

06/10/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 288 LOT 3 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141648

R2-0141648

DVD2

a

[]

[]

[]

208951

06/10/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 301 LOT 9 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141649

R2-0141649

DVD2

a

[]

[]

[]

209339

06/11/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 285 LOT 26 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141650

R2-0141650

DVD2

a

[]

[,]

[EPA, REGION 2]

208985

06/11/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 719 LOT 2 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141651

R2-0141651

DVD2

a

[]

[]

[]

208940

06/12/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 276 LOT 10 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141652

R2-0141652

DVD2

a

[]

[]

[]

209253

06/12/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 301 LOT 3 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141653

R2-0141653

DVD2

a

[]

[]

[]

208912

06/12/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 709 LOT 1 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141654

R2-0141654

DVD2

a

[]

[]

[]

209112

06/12/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 710 LOT 12 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141655

R2-0141655

DVD2

a

[]

[]

[]

209242

06/12/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 710 LOT 3 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141656

R2-0141656

DVD2

a

[]

[]

[]

209601

06/12/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 719 LOT 9 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141657

R2-0141657

DVD2

a

[]

[]

[]

208949

06/14/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 287 LOT 6 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141658

R2-0141658

DVD2

a

[]

[]

[]

209155

06/14/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 707 LOT 2 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141659

R2-0141659

DVD2

a

[]

[]

[]

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209209

06/14/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 713 LOT 3 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141660

R2-0141660

DVD2

a

[]

[]

[]

209025

06/15/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 285 LOT 22 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141661

R2-0141661

DVD2

a

[]

[]

[]

208934

06/15/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 719 LOT 16 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141662

R2-0141662

DVD2

a

[]

[]

[]

209019

06/17/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 285 LOT 17 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141663

R2-0141663

DVD2

a

[]

[]

[]

209028

06/19/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 285 LOT 19 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141664

R2-0141664

DVD2

a

[]

[]

[]

209256

06/20/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 293 LOT 1 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141665

R2-0141665

DVD2

a

[]

[]

[]

208979

06/20/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 719 LOT 5 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141666

R2-0141666

DVD2

a

[]

[]

[]

208936

06/21/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 276 LOT 9 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141667

R2-0141667

DVD2

a

[]

[]

[]

208919

06/26/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 719 LOT 11 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141668

R2-0141668

DVD2

a

[]

[]

[]

209032

06/27/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 285 LOT 21 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141669

R2-0141669

DVD2

a

[]

[]

[]

208981

06/27/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 719 LOT 4 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141670

R2-0141670

DVD2

a

[]

[]

[]

209274

06/27/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 719 LOT 8 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141671

R2-0141671

DVD2

a

[]

[]

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208938

06/29/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 719 LOT 17 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141672

R2-0141672

DVD2

a

[]

[]

[]

209066

07/03/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 278 LOT 5 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141673

R2-0141673

DVD2

a

[]

[]

[]

209272

07/05/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 278 LOT 2 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141674

R2-0141674

DVD2

a

[]

[]

[]

209000

07/05/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 278 LOT 5 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141675

R2-0141675

DVD2

a

[]

[]

[]

209052

07/05/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 278.02 LOT 19 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141676

R2-0141676

DVD2

a

[]

[]

[]

209037

07/06/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 236 LOT 23 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141677

R2-0141677

DVD2

a

[]

[]

[]

209009

07/06/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 278 LOT 1 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141678

R2-0141678

DVD2

a

[]

[]

[]

209236

07/06/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 278 LOT 15 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141679

R2-0141679

DVD2

a

[]

[]

[]

209051

07/06/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 278.02 LOT 21 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141680

R2-0141680

DVD2

a

[]

[]

[]

209571

07/06/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 280 LOT 83 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141681

R2-0141681

DVD2

a

[]

[]

[]

209543

07/06/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 709 LOT 10 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141682

R2-0141682

DVD2

a

[]

[]

[]

209109

07/06/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 711 LOT 14 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141683

R2-0141683

DVD2

a

[]

[]

[]

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209105

07/06/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 711 LOT 16 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141684

R2-0141684

DVD2

a

[]

[]

[]

209230

07/09/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 278 LOT 16 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141685

R2-0141685

DVD2

a

[]

[]

[]

209091

07/10/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 291 LOT 10.01 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141686

R2-0141686

DVD2

a

[]

[]

[]

209250

07/10/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 297 LOT 9 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141687

R2-0141687

DVD2

a

[]

[]

[]

208928

07/10/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 709 LOT 7 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141688

R2-0141688

DVD2

a

[]

[]

[]

208962

07/10/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 710 LOT 16 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141689

R2-0141689

DVD2

a

[]

[,]

[EPA, REGION 2]

209115

07/10/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 711 LOT 11 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141690

R2-0141690

DVD2

a

[]

[]

[]

209335

07/10/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 711 LOT 3 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141691

R2-0141691

DVD2

a

[]

[,]

[EPA, REGION 2]

208948

07/12/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 288 LOT 5 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141692

R2-0141692

DVD2

a

[]

[]

[]

208983

07/12/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 719 LOT 3 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141693

R2-0141693

DVD2

a

[]

[]

[]

209240

07/13/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 278 LOT 12 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141694

R2-0141694

DVD2

a

[]

[]

[]

208966

07/18/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 711 LOT 17 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141695

R2-0141695

DVD2

a

[]

[,]

[EPA, REGION 2]

Page 44 of 81

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208987

07/19/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 719 LOT 1 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141696

R2-0141696

DVD2

a

[]

[]

[]

209522

07/20/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 278 LOT 26 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141697

R2-0141697

DVD2

a

[]

[]

[]

209060

07/20/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 278.01 LOT 7 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141698

R2-0141698

DVD2

a

[]

[]

[]

209015

07/20/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 285 LOT 24 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141699

R2-0141699

DVD2

a

[]

[]

[]

209098

07/20/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 712 LOT 2 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141700

R2-0141700

DVD2

a

[]

[]

[]

209007

07/21/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 278 LOT 29 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141701

R2-0141701

DVD2

a

[]

[]

[]

208998

07/21/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 278 LOT 33 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141702

R2-0141702

DVD2

a

[]

[]

[]

209490

07/21/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 278.02 LOT 3 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141703

R2-0141703

DVD2

a

[]

[]

[]

209514

07/24/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 278 LOT 1.01 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141704

R2-0141704

DVD2

a

[]

[]

[]

208952

07/24/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 301 LOT 9 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141705

R2-0141705

DVD2

a

[]

[]

[]

209119

07/24/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 711 LOT 10 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141706

R2-0141706

DVD2

a

[]

[]

[]

209096

07/24/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 712 LOT 4 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141707

R2-0141707

DVD2

a

[]

[]

[]

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209314

07/24/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 712 LOT 8 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141708

R2-0141708

DVD2

a

[]

[,]

[US ENVIRONMENTAL
PROTECTION AGENCY
REGION 2]

209325

07/25/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 711 LOT 6 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141709

R2-0141709

DVD2

a

[]

[,]

[EPA, REGION 2]

209521

07/26/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 278 LOT 25 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[FORM]

R2-0141710

R2-0141710

DVD2

a

[]

[]

[]

209050

07/26/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 278 LOT 9 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141711

R2-0141711

DVD2

a

[]

[]

[]

208944

07/26/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 291 LOT 20 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141712

R2-0141712

DVD2

a

[]

[]

[]

209541

07/26/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 708 LOT 14 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141713

R2-0141713

DVD2

a

[]

[]

[]

209313

07/26/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 712 LOT 10 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141714

R2-0141714

DVD2

a

[]

[]

[]

209097

07/26/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 714 LOT 10 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141715

R2-0141715

DVD2

a

[]

[]

[]

209317

07/30/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 712 LOT 7 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141716

R2-0141716

DVD2

a

[]

[,]

[EPA, REGION 2]

209471

08/05/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 291 LOT 5 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141717

R2-0141717

DVD2

a

[]

[]

[]

209518

08/08/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 278 LOT 21 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141718

R2-0141718

DVD2

a

[]

[]

[]

209229

08/08/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 714 LOT 4 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141719

R2-0141719

DVD2

a

[]

[]

[]

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209039

08/15/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 714 LOT 14 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141720

R2-0141720

DVD2

a

[]

[]

[]

209470

08/17/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 291 LOT 3 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141721

R2-0141721

DVD2

a

[]

[]

[]

209221

08/21/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 714 LOT 6 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141722

R2-0141722

DVD2

a

[]

[]

[]

209101

09/04/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 712 LOT 1 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141723

R2-0141723

DVD2

a

[]

[]

[]

208993

09/07/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 278 LOT 8 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141724

R2-0141724

DVD2

a

[]

[]

[]

208994

09/07/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 278 LOT 8 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

2

[AGREEMENT]

R2-0141725

R2-0141726

DVD2

a

[]

[]

[]

209327

09/25/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 712 LOT 11 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141727

R2-0141727

DVD2

a

[]

[,]

[EPA, REGION 2]

209516

10/03/2006

REDACTED ACCESS AGREEMENT FOR
BLOCK 278 LOT 23 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141728

R2-0141728

DVD2

a

[]

[]

[]

208970

10/05/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FOR BLOCK 707
LOT 11 ON MARCH 29, 2006 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141729

R2-0141729

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209357

10/25/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 707
LOT 16 ON MARCH 29, 2006 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141730

R2-0141730

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209169

11/01/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 708
LOT 4 ON 03/22/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141731

R2-0141731

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

Page 47 of 81

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Title:

Image
Count:

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Author Name:

Author Organization:

209153

11/07/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 707
LOT 8 ON 05/08/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141732

R2-0141732

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209130

11/07/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 707
LOT 8 ON 05/13/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141733

R2-0141733

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209166

11/07/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 708
LOT 5 ON 05/11/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141734

R2-0141734

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209159

11/07/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 708
LOT 6 ON 03/15/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141735

R2-0141735

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209501

11/07/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 709
LOT 10 ON 07/17/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141736

R2-0141736

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209542

11/07/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 709
LOT 10 ON 07/17/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141737

R2-0141737

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209282

11/07/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 709
LOT 19 ON 03/16/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141738

R2-0141738

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209506

11/13/2006

REDACTED RESULTS OF INDOOR AIR
EVALUATION SAMPLES COLLECTED
FROM BLOCK 282 LOT 27 ON 06/05/2006
FOR THE WHITE SWAN LAUNDRY AND
CLEANER INCORPORATED SITE

1

[LETTER]

R2-0141739

R2-0141739

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209531

11/13/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED AT BLOCK 708 LOT
10 ON 03/13/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141740

R2-0141740

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

Page 48 of 81

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209539

11/13/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 708
LOT 13 ON 03/06/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141741

R2-0141741

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209192

11/13/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 708
LOT 2 ON 03/15/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141742

R2-0141742

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209148

11/13/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 708
LOT 8 ON 03/21/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141743

R2-0141743

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209017

11/14/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 285
LOT 24 ON 07/20/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141744

R2-0141744

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

145186

11/14/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 708
LOT 1 ON 06/19/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141745

R2-0141745

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209108

11/14/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 711
LOT 14 ON 07/17/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141746

R2-0141746

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208973

11/15/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FOR BLOCK 706
LOT 9.02 ON MARCH 13, 2006 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141747

R2-0141747

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209237

11/15/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 278
LOT 15 ON 06/28/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141748

R2-0141748

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209004

11/15/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 278
LOT 31 ON 03/13/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141749

R2-0141749

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

Page 49 of 81

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209061

11/15/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 278
LOT 7 ON 03/08/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141750

R2-0141750

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209056

11/15/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 278
LOT 9 ON 03/08/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141751

R2-0141751

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209022

11/15/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 285
LOT 18 ON 03/15/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141752

R2-0141752

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209352

11/15/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 285
LOT 4 ON MARCH 15, 2006 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0141753

R2-0141754

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

145205

11/15/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 706
LOT 8.02 ON 07/18/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141755

R2-0141755

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209184

11/15/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 706
LOT 9.01 ON 03/22/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141756

R2-0141756

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209128

11/15/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 707
LOT 9 ON 03/06/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

3

[LETTER]

R2-0141757

R2-0141759

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208916

11/15/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 709
LOT 2 ON 03/06/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141760

R2-0141760

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209332

11/15/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 711
LOT 5 ON MARCH 8, 2006 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141761

R2-0141761

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

Page 50 of 81

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209324

11/15/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 711
LOT 7 ON MARCH 15, 2006 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141762

R2-0141762

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209080

11/15/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 715
LOT 4 ON 04/26/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141763

R2-0141763

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

198188

11/15/2006

RESULTS OF INDOOR AIR SAMPLES
COLLECTED AT THE PROPERTY OF
CUMBERLAND FARMS, INCORPORATED
FOR THE WHITE SWAN LAUNDRY AND
CLEANER INCORPORATED SITE

1

[LETTER]

R2-0141764

R2-0141764

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209551

11/20/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 708
LOT 17 ON 04/03/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141765

R2-0141765

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209176

11/25/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 708
LOT 3 ON 03/15/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141766

R2-0141766

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209509

11/27/2006

REDACTED RESULTS OF INDOOR AIR
EVALUATION SAMPLES COLLECTED
FROM BLOCK 718 LOT 2 ON 04/19/2006
FOR THE WHITE SWAN LAUNDRY AND
CLEANER INCORPORATED SITE

1

[LETTER]

R2-0141767

R2-0141767

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209536

11/27/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED AT BLOCK 708 LOT
12 ON 04/05/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141768

R2-0141768

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208969

11/27/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FOR BLOCK 707
LOT 11 ON MARCH 29, 2006 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141769

R2-0141769

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209087

11/27/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 280
LOT 24 ON 05/10/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141770

R2-0141770

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

Page 51 of 81

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Count:

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145181

11/27/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 280
LOT 28 ON 04/12/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141771

R2-0141771

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208906

11/27/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 280
LOT 84 ON 05/8/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141772

R2-0141772

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208910

11/27/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 280
LOT 90 ON 03/28/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141773

R2-0141773

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208902

11/27/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 281
LOT 21 ON 04/10/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141774

R2-0141774

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209304

11/27/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 284
LOT 7 ON 05/13/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141775

R2-0141775

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209207

11/27/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 285
LOT 12 ON 04/05/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141776

R2-0141776

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209216

11/27/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 285
LOT 14 ON 04/10/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141777

R2-0141777

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209030

11/27/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 285
LOT 19 ON 07/10/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141778

R2-0141778

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209035

11/27/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 285
LOT 20 ON 07/10/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141779

R2-0141779

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

Page 52 of 81

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Site Name: WHITE SWAN LAUNDRY AND CLEANER INC
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Image
Count:

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209340

11/27/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 285
LOT 26 ON JUNE 12, 2006 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0141780

R2-0141781

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209345

11/27/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 285
LOT 4 ON APRIL 24, 2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141782

R2-0141782

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209092

11/27/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 289
LOT 4 ON 04/24/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141783

R2-0141783

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209090

11/27/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 291
LOT 10.01 ON 07/26/2006 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141784

R2-0141784

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208953

11/27/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 299
LOT 1 ON 05/16/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141785

R2-0141785

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209301

11/27/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 301
LOT 17 ON 04/12/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141786

R2-0141786

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209163

11/27/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 707
LOT 1 ON 04/24/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141787

R2-0141787

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209555

11/27/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 708
LOT 18 ON 05/15/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141788

R2-0141788

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209143

11/27/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 708
LOT 9 ON 04/17/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141789

R2-0141789

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

Page 53 of 81

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Site Name: WHITE SWAN LAUNDRY AND CLEANER INC
CERCUS ID: NJSFN0204241
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Action:

DocID:

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Image
Count:

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Ending Bates:

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Author Name:

Author Organization:

208927

11/27/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 709
LOT 6 ON 05/15/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141790

R2-0141790

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209247

11/27/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 710
LOT 2 ON 03/28/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141791

R2-0141791

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209078

11/27/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 715
LOT 2 ON 03/30/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141792

R2-0141792

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208990

11/27/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 718
LOT 5 ON 04/05/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141793

R2-0141793

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208999

11/30/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 278
LOT 5 ON 07/27/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141794

R2-0141794

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

197623

11/30/2006

RESULTS OF INDOOR AIR SAMPLES
COLLECTED FROM THE FRIENDS
MEETING HOUSE ON 06/07/2006 FOR
THE WHITE SWAN LAUNDRY AND
CLEANER INCORPORATED SITE

1

[LETTER]

R2-0141795

R2-0141795

DVD2

[LEAN, SUSAN ]

[FRIENDS MEETING
HOUSE]

[WESTGATE, MATTHEW ]

[EPA]

208959

12/04/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FOR BLOCK 297
LOT 7 ON 06/05/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141796

R2-0141796

DVD2

[]

[]

[WESTGATE, MATTHEW ]

[EPA]

208941

12/04/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 276
LOT 10 ON 06/12/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141797

R2-0141797

DVD2

[]

[]

[WESTGATE, MATTHEW ]

[EPA]

208943

12/04/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 276
LOT 11 ON 05/24/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141798

R2-0141798

DVD2

[]

[]

[WESTGATE, MATTHEW ]

[EPA]

Page 54 of 81

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Site Name: WHITE SWAN LAUNDRY AND CLEANER INC
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OUID: 01
SSID: 02RX
Action:

DocID:

Doc Date:

Title:

Image
Count:

Doc Type:

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Ending Bates:

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Addressee Name:

Addressee Organization:

Author Name:

Author Organization:

209559

12/04/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 276
LOT 4 ON 04/12/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141799

R2-0141799

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209558

12/04/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 276
LOT 5 ON 05/17/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141800

R2-0141800

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209552

12/04/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 276
LOT 6 ON 05/30/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141801

R2-0141801

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209548

12/04/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 276
LOT 7 ON 06/05/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141802

R2-0141802

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209069

12/04/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 276
LOT 8 ON 04/03/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141803

R2-0141803

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208937

12/04/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 276
LOT 9 ON 06/14/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141804

R2-0141804

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209001

12/04/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 278
LOT 4 ON 04/03/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141805

R2-0141805

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209053

12/04/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 278
LOT 6 ON 04/10/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141806

R2-0141806

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209064

12/04/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 278
LOT 6 ON 04/10/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141807

R2-0141807

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

Page 55 of 81

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209042

12/04/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 279
LOT 5 ON 03/27/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141808

R2-0141808

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209044

12/04/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 279
LOT 6 ON 04/17/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141809

R2-0141809

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209295

12/04/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 289
LOT 12 ON 04/17/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141810

R2-0141810

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209257

12/04/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 293
LOT 1 ON 06/20/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0141811

R2-0141812

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209298

12/04/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 293
LOT 13 ON 05/22/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141813

R2-0141813

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209261

12/04/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 293
LOT 3 ON 05/09/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141814

R2-0141814

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209267

12/04/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 293
LOT 4 ON 05/15/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141815

R2-0141815

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209271

12/04/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 297
LOT 11 ON 05/08/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141816

R2-0141816

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209263

12/04/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 297
LOT 13 ON 05/08/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141817

R2-0141817

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

Page 56 of 81

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Image
Count:

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Author Name:

Author Organization:

209251

12/04/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 297
LOT 9 ON 07/10/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141818

R2-0141818

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209292

12/04/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 707
LOT 10 ON 05/03/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141819

R2-0141819

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209362

12/04/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 707
LOT 12 ON APRIL 26, 2006 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141820

R2-0141820

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209360

12/04/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 707
LOT 14 ON APRIL 26, 2006 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141821

R2-0141821

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209354

12/04/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 707
LOT 17 ON APRIL 17, 2006 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141822

R2-0141822

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209156

12/04/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 707
LOT 2 ON 06/14/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141823

R2-0141823

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209150

12/04/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 707
LOT 3 ON 04/14/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141824

R2-0141824

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209145

12/04/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 707
LOT 4 ON 05/01/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141825

R2-0141825

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209134

12/04/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 707
LOT 7 ON 04/26/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141826

R2-0141826

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

Page 57 of 81

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Site Name: WHITE SWAN LAUNDRY AND CLEANER INC
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SSID: 02RX
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Image
Count:

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Author Organization:

209540

12/04/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 708
LOT 14 ON 07/26/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141827

R2-0141827

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209544

12/04/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 708
LOT 15 ON 04/17/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141828

R2-0141828

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209546

12/04/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 708
LOT 16 ON 05/10/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141829

R2-0141829

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208913

12/04/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 709
LOT 1 ON 06/12/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141830

R2-0141830

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208918

12/04/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 709
LOT 3 ON 07/24/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141831

R2-0141831

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208922

12/04/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 709
LOT 4 ON 05/31/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141832

R2-0141832

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208929

12/04/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 709
LOT 7 ON 05/31/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141833

R2-0141833

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209210

12/04/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 713
LOT 3 ON 06/14/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141834

R2-0141834

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209213

12/04/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 713
LOT 4 ON 04/19/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141835

R2-0141835

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

Page 58 of 81

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Site Name: WHITE SWAN LAUNDRY AND CLEANER INC
CERCUS ID: NJSFN0204241
OUID: 01
SSID: 02RX
Action:

DocID:

Doc Date:

Title:

Image
Count:

Doc Type:

Beginning Bates:

Ending Bates:

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Addressee Name:

Addressee Organization:

Author Name:

Author Organization:

209219

12/04/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 713
LOT 5 ON 04/12/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141836

R2-0141836

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209225

12/04/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 716
LOT 31 ON 05/22/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141837

R2-0141837

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209227

12/04/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 716
LOT 32 ON 05/10/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141838

R2-0141838

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208925

12/04/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 719
LOT 13 ON 05/17/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141839

R2-0141839

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208932

12/04/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 719
LOT 15 ON 05/02/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141840

R2-0141840

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209138

12/04/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 707
LOT 5 ON 05/15/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141841

R2-0141841

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

197620

12/04/2006

RESULTS OF INDOOR AIR SAMPLES
COLLECTED AT THE SEAGIRT LODGE ON
05/17/2006 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[LETTER]

R2-0141842

R2-0141842

DVD2

[THOMPSON, JAMES]

[SEA GIRT LODGE]

[WESTGATE, MATTHEW ]

[EPA]

209533

12/05/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED AT BLOCK 709 LOT
14 ON 04/19/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141843

R2-0141843

DVD2

[]

[]

[WESTGATE, MATTHEW ]

[EPA]

208961

12/05/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FOR BLOCK 710
LOT 16 ON JULY 11, 2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141844

R2-0141844

DVD2

[]

[]

[WESTGATE, MATTHEW ]

[EPA]

Page 59 of 81

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Site Name: WHITE SWAN LAUNDRY AND CLEANER INC
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SSID: 02RX
Action:

DocID:

Doc Date:

Title:

Image
Count:

Doc Type:

Beginning Bates:

Ending Bates:

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Author Name:

Author Organization:

208968

12/05/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FOR BLOCK 84 LOT
6 ON APRIL 19, 2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141845

R2-0141845

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208976

12/05/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FOR BLOCK 93 LOT
1 ON 04/19/2006 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[LETTER]

R2-0141846

R2-0141846

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209254

12/05/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 301
LOT 3 ON 06/21/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141847

R2-0141847

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209132

12/05/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 709
LOT 17 ON 06/07/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141848

R2-0141848

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209124

12/05/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 709
LOT 21 ON 05/16/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141849

R2-0141849

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209118

12/05/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 710
LOT 10 ON 06/12/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141850

R2-0141850

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209113

12/05/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 710
LOT 12 ON 06/12/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141851

R2-0141851

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209111

12/05/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 710
LOT 13 ON 05/24/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141852

R2-0141852

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209102

12/05/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 710
LOT 17 ON 05/22/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141853

R2-0141853

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

Page 60 of 81

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REGION ID: 02

Site Name: WHITE SWAN LAUNDRY AND CLEANER INC
CERCUS ID: NJSFN0204241
OUID: 01
SSID: 02RX
Action:

DocID:

Doc Date:

Title:

Image
Count:

Doc Type:

Beginning Bates:

Ending Bates:

Volume:

Addressee Name:

Addressee Organization:

Author Name:

Author Organization:

209239

12/05/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 710
LOT 6 ON 06/07/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141854

R2-0141854

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209122

12/05/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 710
LOT 9 ON 05/30/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141855

R2-0141855

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209528

12/05/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM FOR BLOCK
709 LOT 15 ON 05/22/2006 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141856

R2-0141856

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209524

12/05/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM FOR BLOCK
709 LOT 16 ON 06/07/2006 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141857

R2-0141857

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

197627

12/05/2006

RESULTS OF INDOOR AIR SAMPLES
COLLECTED FROM THE TWIN OAKS
MOTEL ON 06/21/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141858

R2-0141858

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208965

12/06/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FOR BLOCK 711
LOT 17 ON JULY 19, 2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141859

R2-0141859

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208986

12/06/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FOR BLOCK 719
LOT 1 ON 07/19/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141860

R2-0141860

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208984

12/06/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FOR BLOCK 719
LOT 2 ON 06/19/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141861

R2-0141861

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208982

12/06/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FOR BLOCK 719
LOT 3 ON 07/13/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141862

R2-0141862

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

Page 61 of 81

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208980

12/06/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FOR BLOCK 719
LOT 4 ON 06/28/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141863

R2-0141863

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209018

12/06/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 285
LOT 17 ON 07/10/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141864

R2-0141864

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209031

12/06/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 285
LOT 21 ON 06/26/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141865

R2-0141865

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209026

12/06/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 285
LOT 22 ON 07/10/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141866

R2-0141866

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209021

12/06/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 285
LOT 23 ON 06/21/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141867

R2-0141867

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208947

12/06/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 288
LOT 3 ON 06/19/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141868

R2-0141868

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209120

12/06/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 711
LOT 10 ON 07/24/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141869

R2-0141869

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209116

12/06/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 711
LOT 11 ON 07/10/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141870

R2-0141870

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209107

12/06/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 711
LOT 14 ON 07/17/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141871

R2-0141871

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

Page 62 of 81

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209104

12/06/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 711
LOT 16 ON 07/06/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141872

R2-0141872

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209336

12/06/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 711
LOT 3 ON JULY 10, 2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141873

R2-0141873

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209326

12/06/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 711
LOT 6 ON JULY 25, 2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141874

R2-0141874

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209288

12/06/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 711
LOT 8 ON 06/19/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141875

R2-0141875

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209284

12/06/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 711
LOT 9 ON 06/19/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141876

R2-0141876

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208978

12/07/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FOR BLOCK 719
LOT 5 ON 06/28/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141877

R2-0141877

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209038

12/07/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 236
LOT 23 ON 07/12/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141878

R2-0141878

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209008

12/07/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 278
LOT 1 ON 07/27/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141879

R2-0141879

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209241

12/07/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 278
LOT 12 ON 07/24/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141880

R2-0141880

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

Page 63 of 81

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Count:

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209231

12/07/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 278
LOT 16 ON 07/19/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141881

R2-0141881

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209273

12/07/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 278
LOT 2 ON 12/07/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141882

R2-0141882

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209067

12/07/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 278
LOT 5 ON 07/17/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141883

R2-0141883

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209059

12/07/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK
278.01 LOT 7 ON 07/24/2006 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141884

R2-0141884

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208950

12/07/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 287
LOT 6 ON 06/26/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141885

R2-0141885

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208945

12/07/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 291
LOT 20 ON 07/26/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141886

R2-0141886

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209243

12/07/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 710
LOT 3 ON 04/17/2006 AND 05/31/2006
FOR THE WHITE SWAN LAUNDRY AND
CLEANER INCORPORATED SITE

1

[LETTER]

R2-0141887

R2-0141887

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208920

12/07/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 719
LOT 11 ON 06/26/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141888

R2-0141888

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208935

12/07/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 719
LOT 16 ON 06/28/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141889

R2-0141889

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

Page 64 of 81

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Image
Count:

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208939

12/07/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 719
LOT 17 ON 06/28/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141890

R2-0141890

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209275

12/07/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 719
LOT 8 ON 06/26/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141891

R2-0141891

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208914

12/07/2006

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 719
LOT 9 ON 06/22/2006 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141892

R2-0141892

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209534

07/25/2007

REDACTED TRANSMITTAL OF RESULTS OF
INDOOR AIR SAMPLES COLLECTED AT
BLOCK 709 LOT 13 ON 01/16/2002 FOR
THE WHITE SWAN LAUNDRY AND
CLEANER INCORPORATED SITE

1

[LETTER]

R2-0141893

R2-0141893

DVD2

[WESTGATE, MATTHEW ]

[EPA]

[]

[]

209381

11/28/2007

REDACTED ACCESS AGREEMENT FOR
BLOCK 280 LOT 21 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141894

R2-0141894

DVD2

[]

[]

[WESTGATE, MATTHEW ]

[EPA]

209473

11/29/2007

REDACTED ACCESS AGREEMENT FOR
BLOCK 279 LOT 1 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141895

R2-0141895

DVD2

[]

[]

[]

[]

209385

11/29/2007

REDACTED ACCESS AGREEMENT FOR
BLOCK 280 LOT 47 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141896

R2-0141896

DVD2

[]

[]

[WESTGATE, MATTHEW ]

[EPA]

209154

11/29/2007

REDACTED ACCESS AGREEMENT FOR
BLOCK 708 LOT 7 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141897

R2-0141897

DVD2

[]

[]

[]

[]

209305

12/01/2007

REDACTED ACCESS AGREEMENT FOR
BLOCK 280 LOT 9.01 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141898

R2-0141898

DVD2

[]

[]

[]

[]

209383

12/04/2007

REDACTED ACCESS AGREEMENT FOR
BLOCK 280 LOT 54 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141899

R2-0141899

DVD2

[]

[]

[WESTGATE, MATTHEW ]

[EPA]

209100

12/12/2007

REDACTED ACCESS AGREEMENT FOR
BLOCK 714 LOT 9 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141900

R2-0141900

DVD2

[]

[]

[]

[]

Page 65 of 81

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Count:

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209408

12/18/2007

REDACTED ACCESS AGREEMENT FOR
BLOCK 281 LOT 28 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141901

R2-0141901

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209472

12/18/2007

REDACTED ACCESS AGREEMENT FOR
BLOCK 712 LOT 3 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141902

R2-0141902

DVD2

a

[]

[]

[]

209384

12/31/2007

REDACTED ACCESS AGREEMENT FOR
BLOCK 280 LOT 53 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141903

R2-0141903

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209222

01/07/2008

REDACTED ACCESS AGREEMENT FOR
BLOCK 714 LOT 6 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141904

R2-0141904

DVD2

a

[]

[]

[]

209306

03/14/2008

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 280
LOT 9.01 ON 01/08/2008 AND
01/09/2008 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

2

[LETTER]

R2-0141905

R2-0141906

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208995

03/30/2008

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 283
LOT 46 FROM 01/08/2008 THROUGH
01/10/2008 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

2

[LETTER]

R2-0141907

R2-0141908

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209193

03/31/2008

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 708
LOT 2 ON 01/09/2008 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141909

R2-0141909

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209177

03/31/2008

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 708
LOT 3 ON 01/09/2008 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141910

R2-0141910

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208933

03/31/2008

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 709
LOT 8 ON 01/08/2008 AND 01/09/2008
FOR THE WHITE SWAN LAUNDRY AND
CLEANER INCORPORATED SITE

2

[LETTER]

R2-0141911

R2-0141912

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

Page 66 of 81

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Site Name: WHITE SWAN LAUNDRY AND CLEANER INC
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OUID: 01
SSID: 02RX
Action:

DocID:

Doc Date:

Title:

Image
Count:

Doc Type:

Beginning Bates:

Ending Bates:

Volume:

Addressee Name:

Addressee Organization:

Author Name:

Author Organization:

209513

04/06/2008

REDACTED RESULTS OF INDOOR AIR
EVALUATION SAMPLES COLLECTED
FROM BLOCK 278 LOT 1.01 ON
01/08/2008 AND 01/09/2008 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0141913

R2-0141914

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208997

04/06/2008

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 278
LOT 33 ON 01/08/2008 AND 01/09/2008
FOR THE WHITE SWAN LAUNDRY AND
CLEANER INCORPORATED SITE

2

[LETTER]

R2-0141915

R2-0141916

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

145202

04/07/2008

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 706
LOT 8.02 ON 01/12/2008 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141917

R2-0141917

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209563

04/09/2008

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 285
LOT 27 ON 04/15/2008 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

6

[LETTER]

R2-0141918

R2-0141923

DVD2

a

[]

[HARM, DOUG ]

[BRINKERHOFF
ENVIRONMENTAL
SERVICES, INC.]

209029

04/24/2008

REDACTED RESULTS OF INDOOR AIR AND
SUB-SLAB SOIL VAPOR SAMPLES
COLLECTED FROM BLOCK 285 LOT 19 ON
06/25/2008 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

2

[LETTER]

R2-0141924

R2-0141925

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209414

06/03/2008

REDACTED ACCESS AGREEMENT FOR
BLOCK 278.01 LOT 3 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141926

R2-0141926

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209425

06/12/2008

REDACTED ACCESS AGREEMENT FOR
BLOCK 716 LOT 45 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141927

R2-0141927

DVD2

a

[]

[]

[]

209390

06/19/2008

REDACTED ACCESS AGREEMENT FOR
BLOCK 718 LOT 6 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141928

R2-0141928

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209415

06/21/2008

REDACTED ACCESS AGREEMENT FOR
BLOCK 278.01 LOT 2 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141929

R2-0141929

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209012

06/23/2008

REDACTED ACCESS AGREEMENT FOR
BLOCK 278 LOT 28 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141930

R2-0141930

DVD2

a

[]

[]

[]

Page 67 of 81

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Site Name: WHITE SWAN LAUNDRY AND CLEANER INC
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OUID: 01
SSID: 02RX
Action:

DocID:

Doc Date:

Title:

Image
Count:

Doc Type:

Beginning Bates:

Ending Bates:

Volume:

Addressee Name:

Addressee Organization:

Author Name:

Author Organization:

209457

06/23/2008

REDACTED ACCESS AGREEMENT FOR
BLOCK 279 LOT 11 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141931

R2-0141931

DVD2

a

[]

[]

[]

209459

06/23/2008

REDACTED ACCESS AGREEMENT FOR
BLOCK 279 LOT 14 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141932

R2-0141932

DVD2

a

[]

[]

[]

209461

06/23/2008

REDACTED ACCESS AGREEMENT FOR
BLOCK 279 LOT 16 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141933

R2-0141933

DVD2

a

[]

[]

[]

209404

06/23/2008

REDACTED ACCESS AGREEMENT FOR
BLOCK 279 LOT 3 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141934

R2-0141934

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209027

06/23/2008

REDACTED ACCESS AGREEMENT FOR
BLOCK 285 LOT 19 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141935

R2-0141935

DVD2

a

[]

[]

[]

209561

06/23/2008

REDACTED ACCESS AGREEMENT FOR
BLOCK 285 LOT 27 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141936

R2-0141936

DVD2

a

[]

[]

[]

209564

06/23/2008

REDACTED ACCESS AGREEMENT FOR
BLOCK 285 LOT 30 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141937

R2-0141937

DVD2

a

[]

[]

[]

152840

06/23/2008

REDACTED ACCESS AGREEMENT FOR
BLOCK 711 LOT 4 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141938

R2-0141938

DVD2

a

[]

[]

[]

209438

06/23/2008

REDACTED ACCESS AGREEMENT FOR
BLOCK 716 LOT 29 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141939

R2-0141939

DVD2

a

[]

[]

[]

209443

06/23/2008

REDACTED ACCESS AGREEMENT FOR
BLOCK 716 LOT 35 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141940

R2-0141940

DVD2

a

[]

[]

[]

209401

06/23/2008

REDACTED ACCESS AGREEMENT FOR
BLOCK 716 LOT 39 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141941

R2-0141941

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209422

06/23/2008

REDACTED ACCESS AGREEMENT FOR
BLOCK 716 LOT 41 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141942

R2-0141942

DVD2

a

[]

[]

[]

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209405

06/23/2008

REDACTED ACCESS AGREEMENT FOR
BLOCK 716 LOT 5 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141943

R2-0141943

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209410

06/23/2008

REDACTED ACCESS AGREEMENT FOR
BLOCK 717 LOT 7 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141944

R2-0141944

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209467

06/23/2008

REDACTED ACCESS AGREEMENT FOR
BLOCK 718 LOT 7 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141945

R2-0141945

DVD2

a

[]

[]

[]

209403

06/23/2008

REDACTED ACCESS AGREEMENT FOR
BLOCK 718 LOT 9 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141946

R2-0141946

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209393

06/24/2008

REDACTED ACCESS AGREEMENT FOR
BLOCK 279 LOT 13 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141947

R2-0141947

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209455

06/24/2008

REDACTED ACCESS AGREEMENT FOR
BLOCK 716 LOT 28 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141948

R2-0141948

DVD2

a

[]

[]

[]

209389

06/24/2008

REDACTED ACCESS AGREEMENT FOR
BLOCK 718 LOT 3 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141949

R2-0141949

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209396

06/25/2008

REDACTED ACCESS AGREEMENT FOR
BLOCK 279 LOT 9 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141950

R2-0141950

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209400

06/25/2008

REDACTED ACCESS AGREEMENT FOR
BLOCK 285 LOT 13 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141951

R2-0141951

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209436

06/25/2008

REDACTED ACCESS AGREEMENT FOR
BLOCK 713 LOT 2 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141952

R2-0141952

DVD2

a

[]

[]

[]

209394

06/25/2008

REDACTED ACCESS AGREEMENT FOR
BLOCK 716 LOT 27 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141953

R2-0141953

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209402

06/25/2008

REDACTED ACCESS AGREEMENT FOR
BLOCK 717 LOT 9 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141954

R2-0141954

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

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209392

06/26/2008

REDACTED ACCESS AGREEMENT FOR
BLOCK 279 LOT 12 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141955

R2-0141955

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209388

06/26/2008

REDACTED ACCESS AGREEMENT FOR
BLOCK 285 LOT 31 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141956

R2-0141956

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209532

06/26/2008

REDACTED ACCESS AGREEMENT FOR
BLOCK 709 LOT 14 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141957

R2-0141957

DVD2

a

[]

[]

[]

209445

06/26/2008

REDACTED ACCESS AGREEMENT FOR
BLOCK 716 LOT 36 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141958

R2-0141958

DVD2

a

[]

[]

[]

209448

06/26/2008

REDACTED ACCESS AGREEMENT FOR
BLOCK 716 LOT 37 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141959

R2-0141959

DVD2

a

[]

[]

[]

209011

08/27/2008

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 278
LOT 28 ON 06/25/2008 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141960

R2-0141960

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209583

08/27/2008

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 285
LOT 19 ON 06/25/2008 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141961

R2-0141961

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209565

08/27/2008

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 285
LOT 30 ON 06/25/2008 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141962

R2-0141962

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209442

08/27/2008

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 716
LOT 34 ON 06/23/2008 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141963

R2-0141963

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209416

08/28/2008

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK
278.01 LOT 2 ON 06/25/2008 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141964

R2-0141964

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

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209413

08/28/2008

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK
278.01 LOT 3 ON JUNE 25, 2008 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141965

R2-0141965

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209474

08/28/2008

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 279
LOT 1 ON 06/25/2008 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141966

R2-0141966

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209417

08/28/2008

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 279
LOT 2 ON 06/25/2008 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141967

R2-0141967

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209048

08/28/2008

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 279
LOT 7 ON 06/25/2008 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141968

R2-0141968

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209562

08/28/2008

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 285
LOT 27 ON 06/25/2008 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141969

R2-0141969

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209334

08/28/2008

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 711
LOT 4 ON JUNE 25, 2008 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141970

R2-0141970

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209439

08/28/2008

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 716
LOT 29 ON 06/25/2008 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141971

R2-0141971

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209440

08/28/2008

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 716
LOT 30 ON 06/25/2008 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141972

R2-0141972

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209444

08/28/2008

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 716
LOT 35 ON 06/25/2008 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141973

R2-0141973

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

Page 71 of 81

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209446

08/28/2008

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 716
LOT 36 ON 06/25/2008 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141974

R2-0141974

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209449

08/28/2008

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 716
LOT 37 ON 06/25/2008 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141975

R2-0141975

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209423

08/28/2008

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 716
LOT 41 ON 06/26/2008 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141976

R2-0141976

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209424

08/28/2008

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 716
LOT 43 ON 06/25/2008 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141977

R2-0141977

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209426

08/28/2008

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 716
LOT 45 ON 06/25/2008 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141978

R2-0141978

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209411

08/28/2008

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 717
LOT 7 ON JUNE 25, 2008 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141979

R2-0141979

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209468

08/28/2008

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 718
LOT 7 ON 06/25/2008 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141980

R2-0141980

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209412

09/12/2008

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 722
LOT 2 ON JUNE 25, 2008 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0141981

R2-0141982

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209441

09/12/2008

REDACTED TRANSMITTAL OF RESULTS OF
INDOOR AIR SAMPLES COLLECTED FROM
BLOCK 716 LOT 30 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[FAX]

R2-0141983

R2-0141983

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

Page 72 of 81

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209047

09/23/2008

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 279
LOT 7 ON 06/25/2008 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0141984

R2-0141984

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209567

01/05/2009

REDACTED ACCESS AGREEMENT FOR
BLOCK 280 LOT 64 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141985

R2-0141985

DVD2

a

[]

[]

[]

209380

01/05/2009

REDACTED ACCESS AGREEMENT FOR
BLOCK 281 LOT 1 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141986

R2-0141986

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208967

01/05/2009

REDACTED ACCESS AGREEMENT FOR
BLOCK 718 LOT 5 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

1

[AGREEMENT]

R2-0141987

R2-0141987

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209566

01/06/2009

REDACTED ACCESS AGREEMENT FOR
BLOCK 280 LOT 36 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141988

R2-0141988

DVD2

a

[]

[]

[]

209379

01/08/2009

REDACTED ACCESS AGREEMENT FOR
BLOCK 280 LOT 35 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0141989

R2-0141989

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208989

05/04/2009

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FOR BLOCK 718
LOT 5 ON 01/05/2009 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0141990

R2-0141991

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209475

05/04/2009

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 279
LOT 1 ON 01/05/2009 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0141992

R2-0141993

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209458

05/04/2009

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 279
LOT 11 ON 01/05/2009 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0141994

R2-0141995

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209386

05/04/2009

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 280
LOT 47 ON JANUARY 5, 2009 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0141996

R2-0141997

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

Page 73 of 81

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Count:

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209307

05/04/2009

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 280
LOT 9.01 ON 01/06/2009 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0141998

R2-0141999

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209252

05/04/2009

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 297
LOT 9 ON 01/05/2009 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0142000

R2-0142001

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209387

05/04/2009

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 357
LOT 2 AND LOT 3 ON JANUARY 5, 2009
FOR THE WHITE SWAN LAUNDRY AND
CLEANER INCORPORATED SITE

2

[LETTER]

R2-0142002

R2-0142003

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209204

05/04/2009

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 706
LOT 8.01 ON 01/05/2009 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0142004

R2-0142005

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209437

05/04/2009

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 713
LOT 2 ON 01/05/2009 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0142006

R2-0142007

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

197619

05/04/2009

RESULTS OF INDOOR AIR SAMPLES
COLLECTED AT THE SEA GIRT LODGE ON
01/05/2009 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

2

[LETTER]

R2-0142008

R2-0142009

DVD2

[,]

[SEA GIRT LODGE]

[WESTGATE, MATTHEW ]

[EPA]

209515

05/06/2009

REDACTED RESULTS OF INDOOR AIR
EVALUATION SAMPLES COLLECTED
FROM BLOCK 278 LOT 1.01 ON
01/06/2009 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

2

[LETTER]

R2-0142010

R2-0142011

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209517

05/06/2009

REDACTED RESULTS OF INDOOR AIR
EVALUATION SAMPLES COLLECTED
FROM BLOCK 278 LOT 23 ON 01/06/2009
FOR THE WHITE SWAN LAUNDRY AND
CLEANER INCORPORATED SITE

2

[LETTER]

R2-0142012

R2-0142013

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208963

05/06/2009

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FOR BLOCK 710
LOT 16 ON JANUARY 6, 2009 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0142014

R2-0142015

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

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209006

05/06/2009

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 278
LOT 29 ON 01/06/2009 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0142016

R2-0142017

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

208996

05/06/2009

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 278
LOT 33 ON 01/06/2009 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0142018

R2-0142019

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209460

05/06/2009

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 279
LOT 14 ON 01/06/2009 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0142020

R2-0142021

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209462

05/06/2009

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 279
LOT 16 ON 01/06/2009 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0142022

R2-0142023

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209046

05/06/2009

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 279
LOT 7 ON 01/06/2009 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0142024

R2-0142025

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209382

05/06/2009

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 280
LOT 21 ON JANUARY 6, 2009 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0142026

R2-0142027

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209466

05/06/2009

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 280
LOT 35 ON 01/06/2009 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0142028

R2-0142029

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209409

05/06/2009

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 281
LOT 28 ON JANUARY 6, 2009 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0142030

R2-0142031

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209036

05/06/2009

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 285
LOT 20 ON 01/06/2009 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0142032

R2-0142033

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

Page 75 of 81

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Count:

Doc Type:

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Author Name:

Author Organization:

209033

05/06/2009

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 285
LOT 21 ON 01/06/2009 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0142034

R2-0142035

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209016

05/06/2009

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 285
LOT 24 ON 01/06/2009 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0142036

R2-0142037

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209125

05/06/2009

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 709
LOT 21 ON 01/06/2009 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0142038

R2-0142039

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209095

05/06/2009

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 712
LOT 4 ON 01/06/2009 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0142040

R2-0142041

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209040

05/06/2009

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 714
LOT 14 ON 01/06/2009 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0142042

R2-0142043

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209099

05/06/2009

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 714
LOT 9 ON 01/06/2009 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0142044

R2-0142045

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209456

05/06/2009

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 716
LOT 28 ON 01/06/2009 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0142046

R2-0142047

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209447

05/06/2009

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 716
LOT 36 ON 01/06/2009 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0142048

R2-0142049

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209450

05/06/2009

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 716
LOT 37 ON 01/06/2009 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0142050

R2-0142051

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209014

06/04/2009

REDACTED ACCESS AGREEMENT FOR
BLOCK 285 LOT 24 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0142052

R2-0142052

DVD2

a

[]

[]

[]

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Count:

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152841

06/04/2009

REDACTED ACCESS AGREEMENT FOR
BLOCK 706 LOT 6 AND LOT 7 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0142053

R2-0142053

DVD2

a

[]

[]

[]

209453

07/01/2009

REDACTED ACCESS AGREEMENT FOR
BLOCK 280 LOT 44 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0142054

R2-0142054

DVD2

a

[]

[]

[]

209391

07/02/2009

REDACTED ACCESS AGREEMENT FOR
BLOCK 279 LOT 15 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0142055

R2-0142055

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209406

07/02/2009

REDACTED ACCESS AGREEMENT FOR
BLOCK 280 LOT 79 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0142056

R2-0142056

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

205969

07/02/2009

REDACTED ACCESS AGREEMENT FOR
BLOCK 45.05 LOT 2.02 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0142057

R2-0142057

DVD2

a

[]

[]

[]

209575

07/03/2009

REDACTED ACCESS AGREEMENT FOR
BLOCK 716 LOT 23 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0142058

R2-0142058

DVD2

a

[]

[]

[]

209570

07/06/2009

REDACTED ACCESS AGREEMENT FOR
BLOCK 280 LOT 29 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0142059

R2-0142059

DVD2

a

[]

[]

[]

209451

07/06/2009

REDACTED ACCESS AGREEMENT FOR
BLOCK 716 LOT 24 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0142060

R2-0142060

DVD2

a

[]

[]

[]

209464

07/07/2009

REDACTED ACCESS AGREEMENT FOR
BLOCK 279 LOT 18 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0142061

R2-0142061

DVD2

a

[]

[]

[]

209432

07/07/2009

REDACTED ACCESS AGREEMENT FOR
BLOCK 280 LOT 17 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0142062

R2-0142062

DVD2

a

[]

[]

[]

209430

07/07/2009

REDACTED ACCESS AGREEMENT FOR
BLOCK 280 LOT 18 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0142063

R2-0142063

DVD2

a

[]

[]

[]

209427

07/07/2009

REDACTED ACCESS AGREEMENT FOR
BLOCK 280 LOT 19 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0142064

R2-0142064

DVD2

a

[]

[]

[]

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Title:

Image
Count:

Doc Type:

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Author Name:

Author Organization:

209574

07/07/2009

REDACTED ACCESS AGREEMENT FOR
BLOCK 280 LOT 49 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0142065

R2-0142065

DVD2

a

[]

[]

[]

209418

07/07/2009

REDACTED ACCESS AGREEMENT FOR
BLOCK 280 LOT 77 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0142066

R2-0142066

DVD2

a

[]

[]

[]

209420

07/07/2009

REDACTED ACCESS AGREEMENT FOR
BLOCK 280 LOT 78 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0142067

R2-0142067

DVD2

a

[]

[]

[]

209573

07/07/2009

REDACTED ACCESS AGREEMENT FOR
BLOCK 280 LOT 89 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0142068

R2-0142068

DVD2

a

[]

[]

[]

209572

07/07/2009

REDACTED ACCESS AGREEMENT FOR
BLOCK 280 LOT 91 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0142069

R2-0142069

DVD2

a

[]

[]

[]

209581

07/07/2009

REDACTED ACCESS AGREEMENT FOR
BLOCK 2801 LOT 10 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0142070

R2-0142070

DVD2

a

[]

[]

[]

209579

07/07/2009

REDACTED ACCESS AGREEMENT FOR
BLOCK 2801 LOT 51 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[AGREEMENT]

R2-0142071

R2-0142071

DVD2

a

[]

[]

[]

209463

09/22/2009

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 279
LOT 16 ON 07/07/2009 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0142072

R2-0142073

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

205970

10/01/2009

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 45.05
LOT 2.02 ON 07/07/2009 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0142074

R2-0142075

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209421

10/28/2009

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 280
LOT 78 ON 07/07/2009 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0142076

R2-0142077

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209452

11/03/2009

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 716
LOT 24 ON 07/07/2009 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0142078

R2-0142079

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

Page 78 of 81

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Site Name: WHITE SWAN LAUNDRY AND CLEANER INC
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OUID: 01
SSID: 02RX
Action:

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Title:

Image
Count:

Doc Type:

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Ending Bates:

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Addressee Name:

Addressee Organization:

Author Name:

Author Organization:

209465

11/05/2009

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 279
LOT 18 ON 07/07/2009 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0142080

R2-0142081

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209582

11/05/2009

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 280
LOT 10 ON 07/07/2009 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0142082

R2-0142083

DVD2

a

[]

[]

[]

209433

11/05/2009

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 280
LOT 17 ON 07/07/2009 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0142084

R2-0142085

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209431

11/05/2009

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 280
LOT 18 ON 07/07/2009 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0142086

R2-0142087

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209428

11/05/2009

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 280
LOT 19 ON 07/07/2009 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0142088

R2-0142089

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209454

11/05/2009

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 280
LOT 44 ON 07/07/2009 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0142090

R2-0142091

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209580

11/05/2009

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 280
LOT 51 ON 07/07/2009 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0142092

R2-0142093

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209419

11/05/2009

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 280
LOT 77 ON 07/07/2009 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0142094

R2-0142095

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

209407

11/05/2009

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 280
LOT 79 ON JULY 7, 2009 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0142096

R2-0142097

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

Page 79 of 81

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Site Name: WHITE SWAN LAUNDRY AND CLEANER INC
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OUID: 01
SSID: 02RX
Action:

DocID:

Doc Date:

Title:

Image
Count:

Doc Type:

Beginning Bates:

Ending Bates:

Volume:

Addressee Name:

Addressee Organization:

Author Name:

Author Organization:

209429

11/05/2009

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 281
LOT 23 ON 07/07/2009 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0142098

R2-0142099

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

200332

11/05/2009

RESULTS OF INDOOR AIR SAMPLES
COLLECTED FROM MANASOUAN HIGH
SCHOOL 167 BROAD STREET,
MANASOUAN, NEWJERSEY FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0142100

R2-0142100

DVD2

[HORN, MARGARET ]

[MANASQUAN BOARD OF
EDUCATION]

[WESTGATE, MATTHEW ]

[EPA]

209013

05/12/2010

REDACTED RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 285
LOT 24 ON 03/11/2010 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0142101

R2-0142101

DVD2

[]

[]

[WESTGATE, MATTHEW ]

[EPA]

197618

05/12/2010

RESULTS OF INDOOR AIR SAMPLES
COLLECTED AT THE SEA GIRT LODGE ON
03/11/2010 FOR THE WHITE SWAN
LAUNDRY AND CLEANER INCORPORATED
SITE

2

[LETTER]

R2-0142102

R2-0142103

DVD2

[,]

[SEA GIRT LODGE]

[WESTGATE, MATTHEW ]

[EPA]

145201

08/28/2012

REDACTED DRAFT RESPONSE WITH
HANDWRITTEN NOTESTO BILL FORT'S
REQUEST FOR RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 706
LOT 8.02 ON 01/12/2008 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

1

[LETTER]

R2-0142104

R2-0142104

DVD2

[]

[]

[WESTGATE, MATTHEW ]

[EPA]

145207

08/28/2012

REDACTED DRAFT RESPONSE WITH
HANDWRITTEN NOTESTO BILL FORT'S
REQUEST FOR RESULTS OF INDOOR AIR
SAMPLES COLLECTED FROM BLOCK 706
LOT 8.02 ON 01/12/2008 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

2

[LETTER]

R2-0142105

R2-0142106

DVD2

[]

[]

[WESTGATE, MATTHEW ]

[EPA]

145204

08/28/2012

REDACTED REQUEST FROM BILL FORT
WITH FIRST ALLIANCE MORTGAGE
REGARDING THE RESULTS OF INDOOR
AIR QUALITY SAMPLES COLLECTED FROM
BLOCK 706 LOT 8.02 ON 01/12/2008 FOR
THE WHITE SWAN LAUNDRY AND
CLEANER INCORPORATED SITE

4

[E MAIL MESSAGE]

R2-0142107

R2-0142110

DVD2

[WESTGATE, MATTHEW ]

[EPA]

[]

[]

Page 80 of 81

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Site Name: WHITE SWAN LAUNDRY AND CLEANER INC
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OUID: 01
SSID: 02RX
Action:

DocID:

Doc Date:

Title:

Image
Count:

Doc Type:

Beginning Bates:

Ending Bates:

Volume:

Addressee Name:

Addressee Organization:

Author Name:

Author Organization:

145203

08/29/2012

REDACTED COPY OF THE LETTER
REQUESTED BY BILL FORT WITH FIRST
ALLIANCE MORTGAGE REGARDING THE
RESULTS OF INDOOR AIR QUALITY
SAMPLES COLLECTED FROM BLOCK 706
LOT 8.02 ON 01/12/2008 FOR THE WHITE
SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

4

[LETTER]

R2-0142111

R2-0142114

DVD2

a

[]

[WESTGATE, MATTHEW ]

[EPA]

145206

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REDACTED STATUS REPORT OF US EPA'S
FINDINGS OF INDOOR AIR
CONTAMINATION FOR BLOCK 706 LOT
8.02 AS REQUESTED BY BILL FORT WITH
FIRST ALLIANCE MORTGAGE FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

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02/14/2013

REDACTED TRANSMITTAL OF SAMPLE
RESULTS FOR BLOCK 711 LOT 17 FOR THE
WHITE SWAN LAUNDRY AND CLEANER
INCORPORATED SITE

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APPENDIX V
NEW JERSEY STATE CONCURRENCE LETTER

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Department of Environmental Protection

CHRIS CHRISTIE
Governor

Site Remediation Program
Mail Code 401-06

BOB MARTIN
Commissioner

P. O, Box 420

KIM GUADAGNO
Li. Governor

Trenton. New Jersey (' .625-0420
Tel.#: 609-292-1250
Fax.#: 609-777-1914

September 27, 2013

Mr. Walter Mugdan, Director

Emergency and Remedial Response Division

U.S. Environmental Protection Agency

Region II

290 Broadway

New York, NY 10007-1866

Re: White Swan Cleaners/Sun Cleaners Area Groundwater Contamination Superfund Site
Record of Decision
EPA ID# NJSFN0204241
DEP PI#G000042009

Dear Mr. Mugdan:

The New Jersey Department of Environmental Protection (DEP) completed its review of the
"Record of Decision, White Swan Cleaners/Sun Cleaners Area Groundwater Contamination
Superfund Site, Wall Township, Manasquan Borough. Sea Girt Borough, Monmouth County,
New Jersey" prepared by the U.S. Environmental Protection Agency (EPA) Region II in
September 2013 and concurs with the selected remedy to address contamination in soil and
groundwater in these coastal communities.

DEP supports excavation soil contaminated with tetrachloroethylene (PCE) at the former White
Swan Cleaners and installation of a soil vapor extraction/air sparging system to clean soil and
shallow groundwater at the former Sun Cleaners. Furthermore, construction of a groundwater
treatment system and continued installation and maintenance of vapor intrusion systems in
residential and commercial structures to address PCE contamination is warranted. DEP concurs
with the selected remedy with a cost of $5.4 million for soils and $13.5 million for groundwater.
It is noteworthy that this was New Jersey's first large-scale vapor intrusion site.

The selected remedy was chosen in accordance with the Comprehensive Environmental
Response, Compensation, and Liability Act, as amended, and, to the extent practicable, the
National Oil and Hazardous Substances Pollution Contingency Plan. This decision is based on
the Administrative Record file for this site. The response action selected in this Record of

New Jersey is cm Equal Opportunity Employer t Printed on Recycled Paper and Recyclable

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Decision is necessary to protect public health and the environment from actual releases of
hazardous substances into the environment.

The major components of the selected remedy include:

•	Excavation and off-site disposal of 5,100 cubic yards of PCE-contaminated soils at the
White Swan Cleaners source area;

•	In-situ soil vapor extraction/air sparging of soils and shallow groundwater contaminated
with PCE at the Sun Cleaners source area;

•	Construction of a groundwater extraction and treatment system to capture and treat the
most highly contaminated groundwater expected to handle between 70 and 200 gallons
per minute;

•	Monitored natural attenuation for lesser contaminated groundwater;

•	Establishment of a Classification Exception Area to document the extent of groundwater
in the area ensuring appropriate precautions prior to use; and.

•	Indoor air monitoring of buildings in close proximity to the groundwater contamination,
plume, and installation of vapor mitigation systems, as necessary.

DEP appreciates the opportunity to participate in the decision making process to select an
appropriate remedy and is looking forward to future cooperation with EPA in remedial action at
this site.

If you have any questions, please call me at 609-292-1250.

C: Ken Kloo, Director. Division of Remediation Management, DEP

Ed Putnam, Assistant Director, Publicly Funded Response Element, DEP
Carole Petersen, Chief, New Jersey Remediation Branch, EPA Region II

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