Wednesday, April 9, 2014
Torne Valley Paint Sludge Cleanup Plan Presented to Public
By Colin English, Kristen Andrada, Alexa Marques and Rudolf Reda
On March 12, at the Suffern, New York, public library, the New York State Department of Environmental Conservation (NYSDEC) held a meeting to invite public commentary about a proposed remedy to paint sludge contamination in the Town of Ramapo, Rockland County, NY. Ford Motor Company operated an automobile manufacturing plant in Mahwah, New Jersey from 1955-1980 and disposed of toxic materials in New Jersey and New York along the banks of rivers, in wooded areas around the local suburban towns, and along roadways accessible by trucks.
Since the New Jersey and New York state border cuts through the areas of contamination, this separation subjects them to different local populations, municipalities, and state regulations, which has created a difference in how sites on each side of the border have been cleaned.
The remediation plan being considered by the NYSDEC addresses three sites in Rockland County, NY: Operable Unit-1 (OU-1), North of the Ramapo Well Field; OU-2, the Torne Valley Road Area; and OU-3, the Camp Hill Road area. OU-1 and OU-2 are located in an undeveloped area of Hillburn approximately two miles north of the Village of Suffern. OU-3 is next to a county park in a suburban area approximately one mile southwest of the intersection of Palisades Parkway and Route 202.
Each site represents a portion of a remediation plan that Ford, as the responsible party for the dumped sludge, and the NYSDEC collectively undertake through the national Superfund Program, Comprehensive Environmental Response, Compensation and Liability Act (CERCLA). Specifically, this meeting addressed proposed remedial action for the Torne Valley Road Area (OU-2).
This meeting held by the state environmental agency represents the first public meeting on a cleanup plan in the history of this site. The Rockland County Public Health Department first raised concern about the presence of paint sludge at these sites as early as 1980. Yet, remedial action was not taken for approximately 25 years after this call for alarm. The beginning of the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), established in 1980, coincided with the public concern over the contamination.
This is the first detailed report of how Ford intends to clean up this site presented to the public since “Toxic Legacy,” the multi-media report in 2005 by the Bergen Record, uncovered lack of action regarding paint sludge dumped in Ringwood, NJ, and across the border in New York.
Ramapo Well Field Site Clean Up Work
The North of Ramapo Well Field site, which encompasses United Water Company wells serving a large portion of Rockland County, was remediated over time, with much of the work done last year. It is currently in the process of continual management and restoration measures. The site has been extensively cleaned, and the result has satisfied the NYSDEC, town officials, and the public.
OU-3, the Camp Hill Road Area, is in an early design stage that determines the method of how it will be cleaned. OU-2, the Torne Valley Road area, is highly contaminated but the extent of the depth of toxic materials in the soil is not known.
The NYSDEC presented a detailed remedial plan for OU-2. NYSDEC Project Manager William Bennett described the site’s history, the current state of the site, and proposed remedial alternatives. OU-2 was previously owned by the Ramapo Land Company in which it was used as heavy equipment storage and occasionally as a waste transfer station by the Town of Ramapo. In 1983, the Ramapo Highway Department found paint sludge on the property and adjusted site borders that accounted for all possible areas of contamination.
Following the state remedial investigation procedure, a variety of testing and visual reconnaissance occurred to identify the extent of the contamination. The sludge at this site ranges in size and protrudes out of embankments from where it was buried several feet under the soil near Torne Brook. According to the NYSDEC standards the sludge exceeds their maximum concentration levels for Benzene, Tulane, Ethyl Benzene, Xylene, Naphthalene, Inorganic Barium, Cadmium, Copper, Lead, Mercury and Nickel. Throughout their initial survey of the Torne Brook site, the crews filled two 55 gallon drums by hand with hardened paint sludge and particulate matter.
Alternative Clean Up Proposals
The primary objective of the proposed remedial action plan is to remove all visible paint sludge, restrict residential use, protect groundwater, and prevent ingestion and exposure to contaminants. The NYSDEC project manager outlined five alternatives for cleanup that vary in cost, extent of remediation, and feasibility. The agency proposes to approve alternative 4: at a cost of $7.5 million; it consists of removal of sludge up to 8 ft, and excavation into the embankments up to 10 ft vertically and 10 ft horizontally. Following the process of deep removal, they would then backfill the excavation with clean, uncontaminated soil. In addition to the excavation, a series of institutional controls would be established while also restoring and revegetation of the landscape. Post-remediation, if any more sludge is to be found, it would be Ford’s responsibility to provide additional clean up.
Next, the project manager from the NYS Department of Health, Anthony Perretta, spoke about public health issues. Perretta stated that even though the paint sludge is mostly in solid form now, it is still dangerous to public health, especially when handled. His chief concern is the possible spread of the paint sludge particles in dust that are likely to leave the site during the use of heavy equipment. Perretta insisted on establishing a community air monitoring plan that would limit the amount of dust that leaves the perimeter of the site and use photoionization detectors to alert workers to stop work and examine the particles for contamination. He further suggested to implement institutional controls to maintain and manage the area for additional paint sludge or other environmental damages. Doing it this way would protect the workers as well by determining a certain cleanliness of the work site and the vehicles leaving the site.
After the presentation of the proposed remedy for the OU-2 site, the audience was free to comment and question the Arcadis and Ford representatives on the case. It was encouraged that both the audience and the people who could not make the public meeting should formally submit their comments to William Bennett for project related questions and Anthony Perretta for site-related questions. The comment period ended on March 30, 2014.
Michael Knipfing, the DEC representative from Region 3 (The New York counties of Sullivan, Ulster, Dutchess, Orange, Putnam, Rockland, and Westchester), stated that this proposal was not the final proposal but a draft that would be changed after considering the public comments.
Public Comments Raise Concerns
Rockland County Legislature Chairman Alden Wolfe stated that the long term persistent illnesses in the area correlated with the contamination as information about the dumping surfaced over time. Wolfe suggested that it would be best to include the Town of Ramapo for their approval of the site remedy. Referring to health and safety implications for future site usage, Wolfe stated: “This remediation needs to be executed carefully and effectively for the future and generations to come.”
Vincent Mann, the Chief of the Ramapough-Lenape Nation Turtle Clan of Ringwood, New Jersey, spoke about the effects of the paint sludge on his people. He argued that the state border has created the faulty notion that the NJ and NY contamination sites are separate and not a part of the same problem. Alluding to proposals to cap and fully remove contaminated soil in Ringwood, he said “For Ford to treat my family in Ringwood any different is ludicrous.” After seven unsuccessful clean ups in Ringwood, families there are still suffering, he said. Chief Mann believed that the $94.7 million estimated cost of full remediation for OU-2, the 5th alternative in the feasibility study, would be the cost for a full clean up at the larger Ringwood site.
Despite the cost, Mann argued that all sites should get the 5th alternative to eliminate all paint sludge pollution. Mann also requested a health assessment in the Torne Valley area because of Hillburn’s seemingly high cancer incidences and fatalities. He emphasized that, for comparison, the Ringwood Ramapoughs have first hand experience with the paint sludge contamination, but much of the regional public does not know that the Ringwood area has been listed as a superfund site twice within the last half century.
Geoff Welch from the Ramapo River Committee remarked about the ecological impacts that the clean up crews operating in the Torne Valley need to consider such as the primary aquifer under Torne Valley and the biological diversity within the riparian wetland habitat such as rattlesnakes in the summer mating season. Another concerned resident raised the question of waste material disposal sites and Bennett responded that the location of disposal was not determined but said that the hazardous waste will be carefully tracked. The waste must go through a DEC or EPA disposal facility to see whether or not other facilities can accept the material. He presumed that the waste taken from OU-2 could be mixed with other material, placed in a landfill, or incinerated.
A Suffern resident worried about the brook trout in nearby streams and wanted restoration crews to plant taller trees by the streams and rivers to shade the trout and their young. In response, Chuck Stead, a professor in Ramapo College’s Environmental Studies program, noted that the trout, native to the Ramapo area, are fewer in number than in the past. He said that a continual cut of the tree canopy in the area will reduce shade and fewer trout will reach mature age. He suggested that the remediation must consider how much of the canopy will be disturbed.
Stead noted that on class trips to the contaminated area, his students found paint at three feet into the ground, not two as previous reports stated. He argued that paint sludge can migrate up to 18 inches from where it was dumped, due to erosion from winter weather. This effect has caused the solid form of paint sludge to break down into smaller particles, allowing for easier migration of the contamination.
Finally, Ford Project Manager Mohammed Zakkar described many aspects of the Torne Valley remediation. At OU-1, he said, 42,000 tons of contaminated material was excavated and disposed of or incinerated in the states of Utah, Michigan, and elsewhere. In response to Chief Mann’s question regarding how much of the removed material was toxic sludge versus soil, Zakkar described a ratio of 70 percent soil and 30 percent paint sludge. For OU-2, he predicted that it would cost more than the estimate of $7.5 million due to paint sludge likely to be found deeper than expected.
Public commentary to the NYSDEC on the OU-2 remediation ended on March 30th, 2014, and the NYSDEC did not announce any future meetings. The site remediation plan is expected to begin within the next year.
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