environmental risks (fwd)

Career/Pro ( cpro@igc.apc.org )
Mon, 27 Oct 1997 09:35:47 -0800 (PST)

From: Career/Pro <cpro@igc.apc.org>

Hello Everyone,

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Tony Chenhansa

From: ledereic@cnct.com
To: chx1@cdc.gov
Subject: environmental risks
Date: Monday, October 27, 1997 2:20AM

Dear Colleagues,

My children's school plans to purchase land that had previously been
used for industry. This land had been known to be contaminated with
pollutants. The school got a quote from a waste management company that
says it could clean up the contamination.

MY QUESTIONS, if you can help:

1) The waste management company says it could clean up the land, and
asked a large feel for cleaning up the property. I would like to find
out about getting a second opinion to watch over the waste management

A) Is it better to get a second opinion before the cleanup, after the
cleanup or as the cleanup goes on?

B) Can you recommend a waste management company to do the second

C) The pollutants are listed below in the letter. What are the problems
with these pollutants?

D) How good is the New Jersey Department of Environmental Protection for
their monitoring?

E) Allowable levels of pollutants are usually given for adult males.
Any known effect for children? Are there lower levels allowed for these
pollutants for children?

F) Would it be safe for children after proposed cleanup and capping?

2) The original samples were taken from the front 2.5 acres. Most
of the samples were taken around only 2 areas known to be contaminated.
Few samples were taken from areas not known to be contaminated. Is this
proper sampling techniques, or should more samples be taken from the
untested areas?

A) How problematic might the contaminated water table below be once the
area is capped?

3) The school plans to build while children (preschool age) would be on
the property. How safe or unsafe would that be after proposed cleanup?

4) Is there any other factor that I did not address that I may need to
address as well.

My goals are to make sure the property is safe for my children, and even
more importantly, make sure the property is completely safe for all the
other little children in the Yeshiva, and to avoid a potential tragedy
(Eg in 20 years finding out that something went terribly wrong).

Thank you for your help with this.
P. Ledereich


The property is 9 acres. The proposed purchase of the school property
is only the front 2.5 acres.

LETTER from the waste management company:

Real names have been replaced by the following key.

[WASTE MANAGEMENT] is the waster management company writing this letter
and retained to do the cleanup.

[SCHOOL] is my childrens school that is proposing to purchase the land

[INDUSTRY] is the current owner of the contaminated property.
....... Waste Management ..., .... Was retained by [School] to
investigate the feasibility of building a school at the above referenced
property which is currently owned by .... [industry]. [School] is
planning to purchase a 2.5 acre portion of the former [Industry]
facility (consisting primarily of the former administration building,
steel annex #2 and parking areas) which total s approximately 8.8 acres
in size and is currently being investigated pursuant to New Jersey's
Industrial Site Recovery Act (ISRA).

Although the ISRA investigation identified many area of concern with
regard to the back portion of the property, [WASTE MANAGEMENT COMPANY]
performed numerous tests on the 2.5 acres of the facility which [school]
wishes to develop and has concluded that there are only two areas on
concern specific to the 2.5 acre portion, the former steel, and coal bin
storage areas. Previous soil sampling conducted by [INDUSTRY] in these
two areas of concern revealed polynuclear aromatic hydrocarbons (PAHs)
and priority pollutant metals (PPMs) above the New Jersey Department of
Environmental Protection (NJDEP) Unrestricted Use Soil Cleanup Criteria
(UUSCC) in the soils underlying the property. PAHs which exceed the
UUSCC include benzo[a]anthracene, benzo[b]fluoranthene,
benzo[k]fluoranthene, benzo[a]pyrene, and indeno[1, 2,3-cd]pyrene, and
dibenz[a,h]anthradcene. PPMs which exceed the UUSCC include lead,
cadmium, beryllium, and nickel.

The PAHs and PPMs detected on the property are generally immobile in the
subsurface since they tend to bind to soil particles and dissolve only
slowly into ground water. They will not become airborne unless
disturbed and pose a risk only if ingested in large quantities. The
NJDEP would likely accept an impermeable asphalt cap over the
contaminated soil as a completely effective method of remediation, the
logic being that if you cannot get to the soil in order to eat it, there
is no potential for any human health concerns. This is what [INDUSTRY]
has propsed to do for the entire back portion of the property. Since the
type of contamination is generally immobile, this cap would effectively
stop the contamination from spreading. {Industry{ would receive a
Declaration of Environmental Restriction {DER} for the back portion of
the property, which means that they will always be subject to NJDEP
review to ensure that the cap remains in place and intact.

Although no risk is posed to any children with a cap in place, {SCHOOL]
has indicated to {WASTE MANAGEMENT] that they wish to go one step
further with respect to the proposed 2.5 acre tract. They do not want the
contaminated soil there at all and propose to remove it completely. The
borings [WASTE MANAGEMENT] installed indicated that the depths of the
contaminants are relatively superficial and it would be a simple
procedure to excavate all contaminated soils and resample the affected
areas to confirm that they are clean. New, certified clean soil would
then be used to fill those areas. Once the samples are confirmed clean,
no contamination above UUSCC would remain in the former steel and coal
bin storage areas and no cap would be required on the [SCHOOL] 2.5 acre

All samples collected to date and all samples collected in the future
will be sent to an NJDEP certified lab for anaylsis. Further,
throughout all investigations and subsequent remediation of the site, the
NJDEP will review all actions performed by [WASTE MANAGEMENT] and
determine if all of the remedial procedures followed were in accordance
with applicable state and federal regulations used to determine if a site
is clean. Once [WASTE MANAGEMENT] has performed the remedial work and the
NJDEP has reviewed it, the soil at the property will be deemed completely
clean and safe for any use, with no restrictions whatsoever.

Groundwater which flows underneath the property has also been
investigated by [INDUSTRY] in the form of installing monitoring wells
throughout the entire property. [INDUSTRY] files currently indicate
that there are 4 monitoring wells on the front 2.5 acres which [SCHOOL]
wishes to develop. These wells indicate contamination above New Jersey's
primary drinking water standards for chloroform, trichlorethene (TCE)
and tetrachloroethen (PCE). [INDUSTRY] is in the process of determining if
they, along witih properties upgradient of their property have
contributed to this contamination. They have however, determined that
this contamination did not originate from the 2 areas of concern on the
front 2.5 acres of the property.

The town of {....} uses city water and the groundwater on the property
ranges from 13 to 20 feet below the property, therefore, indicating that
the groundwater under the property will never be used. For these
reasons [INDUSTRY] has determined that they will place a Classification
Exception Area (CEA) over the whole property until the contamination
naturally degrades. This method, as determined by the NJDEP, is safe
for the public and is an acceptable way of monitoring the contamination in
groundwater which will not be utilized under these circumstances. The
only situation in which groundwater becomes problematic is when the
owner chooses to install a shallow private well which will not be installed
here, or in any other urban school location.