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THIRD FIVE-YEAR REVIEW REPORT ELLIS PROPERTY SUPERFUND SITE

BURLINGTON COUNTY, NEW JERSEY

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Prepared by

U.S. Environmental Protection Agency Region 2

New York, New York

Date:

Walter E. Mugdan, Director Emergency and Remedial Response Division

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Table of Contents

Five-Year Review Summary Form ............................................................................................ iii

Introduction ................................................................................................................................... 1

Background ................................................................................................................................... 1

Physical Characteristics ............................................................................................................. 1

Site Geology/Hydrogeology ........................................................................................................ 1

Land and Resource Use .............................................................................................................. 2

History of Contamination ........................................................................................................... 2

Initial Response ........................................................................................................................... 2

Basis for Taking Action ............................................................................................................... 3

Remedial Actions .......................................................................................................................... 3

Remedy Selection ........................................................................................................................ 3

Remedy Implementation .............................................................................................................. 5

System Operations/Operation and Maintenance ........................................................................ 6

Progress Since Last Five-Year Review ....................................................................................... 7

Five-Year Review Process ............................................................................................................ 8

Administrative Components ........................................................................................................ 8

Community Involvement .............................................................................................................. 8

Document Review ........................................................................................................................ 8

Data Review ................................................................................................................................ 8

Site Inspection ............................................................................................................................. 9

Interviews .................................................................................................................................... 9

Institutional Controls Verification ............................................................................................ 10

Technical Assessment ................................................................................................................. 10

Question A: Is the remedy functioning as intended by the decision documents? ..................... 10

Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives used at the time of the remedy still valid?................................................................ 10

Question C: Has any other information come to light that could call into question the protectiveness of the remedy? ................................................................................................... 12

Technical Assessment Summary ............................................................................................... 12

Issues, Recommendations and Follow-Up Actions .................................................................. 13

Protectiveness Statement ............................................................................................................ 13

Next Review ................................................................................................................................. 13

Attachments

Attachment 1: Figure .................................................................................................................. 0

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Executive Summary

This is the third five-year review for the Ellis Property Superfund site located in Evesham and Medford Townships, Burlington County, New Jersey. The purpose of this five-year review is to review information to determine if the remedy is and will continue to be protective of human health and the environment. The triggering action for this policy five-year review is the completion date of the previous five-year review. This five-year review assessment found that the remedial actions implemented at the Ellis Property Superfund site currently protect human health and the environment. However, in order to be protective in the long-term, additional excavation and in-situ source remediation activities selected in the 2013 ROD Amendment need to be implemented, and the operation, maintenance, and groundwater monitoring activities need to be conducted in accordance with the groundwater pump and treat system operation and maintenance plan.

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Five-Year Review Summary Form

SITE IDENTIFICATION

Site Name: Ellis Property

EPA ID: NJD980529085

Region: 2 State: NJ City/County: Evesham and Medford Tonwships/ Burlington County

SITE STATUS

NPL Status: Final

Multiple OUs? Yes

Has the site achieved construction completion? Yes

REVIEW STATUS

Lead agency: EPA

Author name (Federal or State Project Manager): Richard Ho

Author affiliation: EPA

Review period: 9/29/2010 - 9/29/2015

Date of site inspection: 5/20/2014

Type of review: Policy

Review number: 3

Triggering action date: 9/29/2010

Due date (five years after triggering action date): 9/29/2015

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Issues/Recommendations

Issues and Recommendations Identified in the Five-Year Review:

OU(s): 2 Issue Category: Changed Site Conditions

Issue: Residual source material present in the subsurface.

Recommendation: Implement 2013 ROD Amendment source actions.

Affect Current Protectiveness

Affect Future Protectiveness

Party Responsible

Oversight Party

Milestone Date

No Yes EPA State 9/29/2020

OU(s): 2 Issue Category: Monitoring

Issue: Sediment and surface water samples indicate elevated inorganics.

Recommendation: Sample sediment and surface water for organics and inorganics annually.



Party Responsible

Oversight Party

Milestone Date

No Yes State EPA 9/29/2016


Issue: Limited groundwater data and analysis conducted to support this five-year review.

Recommendation: Ensure the state collects and analyzes groundwater data annually in accordance with the O&M Plan.



Party Responsible

Oversight Party

Milestone Date


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Issue: Chromium was never speciated.

Recommendation: Ensure that sampling and analysis includes hexavalent chromium.



Party Responsible

Oversight Party

Milestone Date



Issue: 1,4 Dioxane was not sampled.

Recommendation: Ensure that sampling and analysis includes 1,4 Dioxane, which was detected during the remedial investigation.



Party Responsible

Oversight Party

Milestone Date


Protectiveness Statement(s)

Operable Unit: 2

Protectiveness Determination: Short-Term Protective

Addendum Due Date (if applicable): Click here to enter a date.

Protectiveness Statement: The remedy currently protects human health and the environment because there is no human or ecological receptor exposure to contaminated groundwater or subsurface soils and the site is not in use. However, in order for the remedy to be protective in the long-term, the following actions need to be taken to ensure protectiveness: implement remedial actions selected in the 2013 ROD Amendment: collect and analyze additional sediment and surface water samples for metals; ensure state collects and analyzes groundwater samples in accordance with the operation and maintenance plan; and determine if hexavalent chromium is present above risk-based levels in groundwater.

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Sitewide Protectiveness Statement

Protectiveness Determination: Short-term Protective

Protectiveness Statement: The remedy currently protects human health and the environment because there is no human or ecological receptor exposure to contaminated groundwater or subsurface soils and the site is not in use. However, in order for the remedy to be protective in the long-term, the following actions need to be taken to ensure protectiveness: implement remedial actions selected in the 2013 ROD Amendment; collect and analyze additional sediment and surface water samples for metals; ensure state collects and analyzes groundwater samples in accordance with the operation and maintenance plan; and determine if hexavalent chromium is present above risk-based levels in groundwater.

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Introduction The purpose of a five-year review is to evaluate the implementation and performance of a remedy in order to determine if the remedy is and will continue to be protective of human health and the environment and is functioning as intended by the decision documents. The methods, findings, and conclusions of reviews are documented in the five-year review. In addition, five-year review reports identify issues found during the review, if any, and document recommendations to address them. This is the third five-year review for the Ellis Property site, located in Evesham and Medford Townships, Burlington County, New Jersey. This five-year review was conducted by the Environmental Protection Agency (EPA) Remedial Project Manager (RPM), Richard Ho. The review was conducted pursuant to Section 121(c) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), as amended, 42 U.S.C. Section 9601, et seq., and 40 C.F.R. 300.430(f)(4)(ii) and in accordance with the Comprehensive Five-Year Review Guidance, OSWER Directive 9355.7-03B-P (June 2001). This report will become part of the site file. The triggering action for this policy review is the completion date of the previous five-year review. A five-year review is required at this site due to the fact that the remedial action will not leave hazardous substances, pollutants or contaminants on site above levels that allow for unlimited use and unrestricted exposure, but requires five or more years to complete. For purposes of site management, the Ellis Property site was divided into two operable units: OU1 addresses the contaminated soils and OU2 addresses the contaminated groundwater. The OU1 remedy has been amended in 2013 Record of Decision (ROD) Amendment. The OU2 remedy is currently operating to restore the contaminated groundwater. This five-year review evaluates the operating OU2 groundwater remedy. Background

Physical Characteristics The land at the site is vacant, undeveloped, and overgrown with weeds. Land in the area immediately surrounding the site is primarily agricultural, though it is transitioning to residential. Cultivated fields bound the site to the north and south. Another field is found to the west, across Sharp Road. To the east of the site lies a wetland area. Although the wetlands receive surface water runoff from the site, inundation and saturation of the wetland area is probably caused by discharge from the shallow groundwater table. Consequently, periodic drying of the wetlands occurs when the elevation of the groundwater table is reduced. The nearest free-flowing surface water is Sharps Run, approximately one-quarter mile north of the site. Drainage from the wetlands eventually leads to Sharps Run.

Site Geology/Hydrogeology The Ellis Property site is situated in the central portion of the Atlantic Coastal Plain, which extends from the fall line located west of the Delaware River to the Atlantic Ocean. The Coastal

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Plain regionally slopes gently to the southeast. Site topography is generally flat. The site is underlain by a shallow unconfined aquifer called the Hornerstown Sand, which is comprised of silty sand and clay lenses. The water table is, on average, five feet below ground surface (bgs), and the Hornerstown formation is typically no deeper than 30 feet bgs. Underlying this shallow aquifer is the Navesink Sand, which is comprised of interbedded layers of glauconitic clay and sand, and is generally about 30 feet thick. Thus, the combined formations extend, on average, about 50 to 70 feet bgs.

Land and Resource Use There are no current uses of the Ellis Property except for the ongoing remedial activities, and there are no known plans for land re-use at this time. The land is currently zoned as industrial, although this zoning may change in the future. The risk assessment prepared in the 1992 ROD and 2013 ROD Amendment considered unrestricted future land use for the site property.

History of Contamination This property was originally a dairy farm, until acquired by Irving Ellis in 1968. Approximately four of the 36 acres were used in drum reconditioning operations—drums were rinsed and resold. Surficial spills and discharges associated with drum reconditioning, and chemical storage are believed to have contributed to contamination of soil and groundwater at the site. Operations ceased in the late 1970s following a fire.

Initial Response In September and December of 1982, the Evesham Municipal Authority and the New Jersey Department of Environmental Protection (NJDEP) filed civil action complaints against Irving and Reba Ellis for illegal storage of drums and failure to comply with a Directive Letter. These two suits were consolidated in August 1983, and the courts issued an Order for Partial Summary Judgment ordering Mr. Ellis to pay approximately $100,000 and forbidding him to store, discharge, or spill hazardous substances on the site. The site was included on the National Priorities List on September 1, 1983. On October 19, 1984, EPA issued a General Notice Letter to Mr. Ellis, informing him of his potential liability under the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA), with respect to the contamination at the site. Removal Actions In March 1983, utilizing the New Jersey Spill Compensation Fund, NJDEP removed approximately one hundred drums containing acids and disposed of them at an approved off-site facility. Containerized solids and flammable liquids were also removed and disposed of, along with contaminated soil and sludge. In an acid spill area, the highly acidic surface soils were removed, and lime was tilled into the soil to neutralize the acid. Soils in the vicinity of a polychlorinated biphenyl (PCB) disposal area were removed to a depth of approximately two feet and disposed at an approved off-site facility. The large building and sheds were demolished

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at that time because they were structurally unsafe. Local private wells were sampled again and showed no contamination. On February 22, 1989, NJDEP requested that EPA conduct a drum removal action at the site. After a preliminary assessment, EPA, through its removal authority, began site preparation, waste sampling, and stabilization. EPA segregated, staged and labeled a total of 218 drums containing hazardous waste material for off-site disposal. In addition, approximately 400 empty drums were crushed for off-site disposal. Removal of the drums was completed on April 17, 1990.

Basis for Taking Action In 1985, EPA began a remedial investigation to determine the nature and extent of contamination is soils, groundwater, surface water, and sediment. RI results indicated groundwater and soils were contaminated with volatile organic compounds (VOCs) and metals. In 1992, a risk assessment was conducted and concluded that, under future residential land-use scenarios, risks to the future resident included ingestion of home-grown produce, ingestion of chemicals in the ground water, and non-ingestion uses of groundwater (i.e., bathing). Surface water and sediment did not pose an unacceptable risk to human health. An ecological risk assessment was also conducted and concluded that contaminated soils presented an unacceptable risk to ecological receptors. As part of the 2013 ROD Amendment, the Human Health Risk Assessment and Ecological Risk Assessment from the 1992 ROD were re-evaluated. EPA concluded that the current and future land use assumptions for the site are still valid and that the basis for taking an action at the site derived, primarily, from direct contact or groundwater exposure to a future resident is still valid. The ROD Amendment also concluded that while there have been changes in how ecological risk is calculated, the remediation goals used for the upland portion of the site appear to be protective of terrestrial receptors and that concentrations of trichloroethylene (TCE), a primary groundwater contaminant at the site, in the surface water are below chronic aquatic values. Remedial Actions

Remedy Selection In September 1992, EPA signed a Record of Decision (ROD) for the site. The ROD identified the following media-specific remedial action objectives (RAOs): Soil

Prevent contact with contaminated soil, which represents an unacceptable risk, or reduce contaminant concentrations in the soil below risk-based levels.

Prevent further migration of soil contaminants into the groundwater. Prevent migration of contaminated soils off site.

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Groundwater Prevent the migration of contaminated groundwater off site. Prevent the migration of contaminated groundwater into the underlying aquifers. Return the aquifer to its designated use as a source of drinking water by reducing

contaminant concentrations in the shallow groundwater to drinking water quality.

The selected remedy included:

Excavation of contaminated soil and treatment/disposal at an approved off-site facility; Extraction and treatment of contaminated groundwater from the shallow aquifer

underlying the site with the treatment of groundwater in an on-site facility; Disposal of the treated groundwater on the site by reinjection; and Implementation of an environmental monitoring program to ensure effectiveness of the

remedy. A Record of Decision Amendment was signed for the site on September 30, 2013, to address the residual soil contamination identified since the 1992 selected remedy had been implemented. The RAOs from the 1992 ROD were modified as follows: Soil

Prevent contact with contaminated soil, which represents an unacceptable risk, or reduce contaminant concentrations in the soil below risk-based levels;

Prevent further migration of soil contaminants into the groundwater; and Prevent migration of contaminated soils off site.

Groundwater

Prevent the migration of contaminated groundwater off site; Prevent the migration of contaminated groundwater into the underlying aquifers; Prevent potential exposure by inhalation/vapor intrusion that presents unacceptable risk

under a future land use scenario; and Return the aquifer to its designated use as a source of drinking water by reducing

contaminant concentrations in the shallow groundwater to drinking water quality. The major components of the Amended Remedy include the following:

Excavation and off-site disposal of TCE contamination in the residual source area, and contaminated soil in the plume area;

Implementation of in-situ treatment, where appropriate, to complement excavation; Continued operation of the existing collection and treatment system for a period of time

(estimated to be one year) to evaluate the effectiveness of the system to reduce residual groundwater contamination;

Monitoring of groundwater; and

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Continuation of institutional controls to prevent exposure to contaminated groundwater

until remediation goals are achieved.

The modified remedy components have not been implemented at the time of this five-year review. Therefore, the document will focus on groundwater remedy (defined as OU2).

Remedy Implementation The remedy selected in the 1992 ROD was implemented using federal funds because a viable Potentially Responsible Party (PRP) could not be found. In August 1994, NJDEP contracted with an environmental consulting firm to prepare design plans and specifications for the remedy. Additional monitoring wells were installed in July 1995 to further delineate the groundwater contamination plume. The remediation of contaminated soil was performed in 1998 by excavating soils that exceeded cleanup levels established in the ROD and transporting contaminated soil off-site for disposal. NJDEP conducted quality assurance testing on post-excavation samples. Several rounds of post-excavation sampling and an additional excavation were performed before the soil remediation was deemed complete. A total of 1,400 cubic yards of excavated soils were disposed of at an approved off-site facility. Excavations were filled with clean fill that was tested prior to being brought on site. In 1999, NJDEP contracted with Barbella Environmental Technologies, Inc., for the construction of the groundwater remediation system. In preparation for groundwater remediation, site-clearing and non-intrusive construction began in November 1999. Groundwater reception and recharge trenches were installed on the site. A treatment building was constructed, along with the necessary access roads. Four monitoring wells were installed in the wetland area to monitor the impact of the treatment system on the wetland area. A dense nonaqueous phase liquid (DNAPL) source of PCE was found in the soil during construction and was excavated and disposed off site. An evaluation of wetlands was performed in 2000 and 2001, and concluded that the wetlands were not adversely affected by the groundwater treatment system. As part of the evaluation, a baseline vegetative community survey was conducted to provide an initial assessment of the vegetative communities prior to initiating groundwater remediation activities. All of the characterized species at the site during the baseline evaluation were planted stock. Ten quadrants and 6 data points were established during the baseline survey. Overall the vegetation appeared vigorous and healthy. Subsequent monitoring over the next couple of years indicated that colonization of plant species native to the area had occurred. The overall heights and stem densities documented suggests that the community is healthy and experiencing vigorous growth patterns. Change other than successive growth has not occurred. Minor wildlife browsing was noted in some areas. Construction of the groundwater treatment system was completed on June 5, 2000. The Capture and Treat (C&T) system started up on June 16, 2000 and was determined to be operational and functional on August 31, 2000. Long-term remedial action began on August 31, 2001.

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System Operations/Operation and Maintenance Operation and maintenance (O&M) of the original OU2 remedy is being performed by NJDEP and includes the operation and maintenance of the treatment facility, sampling and analysis of the monitoring wells, groundwater level measurements, and wetland monitoring. The O&M plan requires that groundwater samples are collected from 38 monitoring wells on an annual basis and analyzed for site-related VOCs. Remediation System Evaluation and C&T system modifications In 2006, EPA performed a Remediation System Evaluation (RSE) of site operations. The September 2006 RSE report identified several enhancements to improve the performance of the selected response action and suggested that additional site investigation activities be conducted to determine if DNAPLs were present at the site. In particular, the RSE identified several issues likely to affect overall C&T system performance, including the location of extraction wells in low-permeability soil formations and the presence of the sand channel on the northern part of the site. The sand channel was believed to limit the effectiveness of the northern portion of the collection trench in adequately intercepting contamination. A cutoff wall was installed in 2012 to isolate the contaminated groundwater from the sand channel and direct it, instead, to the collection trench. This wall was also designed to be used as a shoring protection for excavation in the vicinity of the plume area Additional Source Investigation Activities While the removal and remedial response actions taken to date have eliminated drums and large areas of contaminated soil, residual TCE in localized areas of the site along the interface of the Hornerstown Formation and Navesink Formation have been consistently identified in site monitoring wells during groundwater monitoring conducted since 2001. TCE and other VOCs found in groundwater at present were not identified as soil contaminants at the time of the ROD because they were not detected at significant levels. In response to persistent TCE contamination, NJDEP conducted a Pre-Design Investigation (PDI) to further delineate the residual source(s) and extent of contamination in soil and groundwater, to evaluate the presence of DNAPLs, and assess the potential need for changes to the groundwater remedy. The PDI investigation identified TCE, found predominantly between 10 and 24 feet below ground surface, with more elevated concentrations identified during the PDI than historical groundwater results. The significant levels of TCE in the groundwater indicate the existence of a DNAPL source, but such a source has not yet been found (see figure in Attachment 1). The DNAPL source material constitutes a principal threat waste at the site. The influence of pumping wells PW-1 and PW-2 in extracting subsurface contamination bound in the tight soil matrix is limited. Note that these two pumping wells are well placed relative to the TCE source areas and pumping has been ongoing for more than 10 years, yet they appear to have made little progress toward addressing these sources. The primary cause of persistent elevated levels of groundwater

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contamination in portions of the site appears to be residual deep soil contamination below the water table. These contaminants, bound tightly in the soils, leach slowly out of the soils, serving as a continuing source of groundwater contamination that is not easily addressed by the existing system. Based on a review of the groundwater monitoring results from November 1999 to October 2010, multiple residual source areas of TCE contamination appear likely at the site. The primary potential source area in the shallow zone is in the vicinity of monitoring wells MW-2 and MW-6, continuing downgradient to the extraction trench, where relatively high TCE concentrations persist. Another potential source area, based on previous investigations, is in the vicinity of extraction well PW-1, which has had elevated concentrations of TCE in the influent to the treatment plant in 2009 and 2010, as high as 31,286 micrograms per liter (µg/l ) in 2013. The site remedy was modified in 2013 to address the residual TCE source area(s). Progress Since Last Five-Year Review Protectiveness statement(s) from previous five-year review

The remedy is protective of human health and the environment and is expected to remain protective in the short term. There is no human exposure to contaminated groundwater or subsurface soils because the site is not in use, and there are no anticipated ecological concerns associated with exposure to site contaminants.. Recommendations identified in previous five-year review There were no formal recommendations in the last five-year review. As part of regular O&M, surface water and sediment data will continue to be collected. The data from the surface water and sediment sampling will be analyzed for increasing trends, and the results will be evaluated to determine if a screening level risk assessment will be necessary. Wetland monitoring will also continue. In addition, EPA will recommend to NJDEP that future groundwater samples include an analysis for hexavalent chromium, since this compound is highly soluble. Progress on recommendations Groundwater Monitoring The O&M plan requires annual sampling and analysis of groundwater. Over the last five years, only three rounds of groundwater sampling was conducted. As is discussed in the data review section, the three sampling events were only analyzed for VOCs. Metals, including hexavalent chromium, were not analyzed.

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EPA will work with NJDEP to ensure groundwater is sampled annually (consistent with the current O&M plan) and that the O&M plan be modified to include an analysis of all groundwater samples for hexavalent chromium. Surface Water and Sediment Sampling Surface water and sediment in the wetlands was only sampled once in the five-year period since the last five-year review. Consequently, an analysis of increasing contaminant trends could not be made. EPA will work with NJDEP to ensure adequate surface water and sediment samples are collected so that contaminant trends can be assessed. Climate Change Impacts Potential site impacts from climate change have been assessed, and the performance of the remedy is currently not at risk due to the expected effects of climate change in the region and near the site. Five-Year Review Process

Administrative Components The five-year review team included Richard Ho (EPA-RPM), Robert Alvey (EPA-Hydrologist), Urszula Filipowicz (EPA-Human Health Risk Assessor), Mindy Pensak (EPA-Ecological Risk Assessor) and Natalie Loney (EPA-Community Involvement Coordinator). This is a Fund-lead site.

Community Involvement Notice of the commencement of the five-year review was placed on the Evesham Township webpage in January 2015. Once the five-year review is completed, the results will be made available at the local site repository, which is at the Evesham Library, 984 Tuckerton Road, Marlton, New Jersey 08053. In addition, efforts will be made to reach out to local public officials to inform them of the results.

Document Review The document review consisted of reviewing monitoring well sampling data and monthly C&T Systems Operation Reports since the last five-year review.

Data Review Sample collection and analyses has been conducted on a routine basis for VOCs in monitoring wells since 1999. During the last five years, NJDEP has conducted three rounds of sampling from the monitoring well network. However, the sampling did not include an analysis for metals. A discussion of

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VOC-specific results are included below. TCE is one of the contaminants of concern (COC) in groundwater at the site. The results continue to show a downward trend in TCE levels at monitoring well MW-2. Sampling results for TCE during the last five years have been: 4,400 µg/l (October 2010), 3,307 µg/l (April 2013), and 300 µg/l (November 2014). Analytical results for TCE in MW-23, initially sampled in 2009, reveal an increasing trend. This is consistent with the PDI results and provide evident that additional residual TCE source is present in the vicinity of this well. Perchloroethene (PCE), is also a COC at the site. Data review of PCE reveals a much lower overall impact at the site. MW-7, located upgradient of the eastern side of the groundwater collection trench, has demonstrated rapid decline in PCE concentrations since 2000 when the C&T system became operational. Although current levels are much lower than pre-remedial levels (6000 µg/l ), the trend has shown an increase over the last ten years. The November 2014 results (24.5 µg/l) are the highest detected since 2002. In addition to PCE and TCE, minor detections have also been reported for 1,1 Dichloroethene and cis-1,2-dichloroethene (cis-1,2-DCE) in monitoring wells. The exceedences for these contaminants were found in wells where persistent levels of TCE or PCE existed. It is assumed that these contaminants are present due to natural degradation of PCE and TCE in the groundwater. The maximum cis-1,2-DCE detected during 2014 was 172 µg/l at MW-7. Five surface water and sediment historic locations were sampled on November 10, 2014 for VOCs, metals and hardness. Surface water data were compared to NJDEP chronic surface water criteria for aquatic receptors (http://www.nj.gov/dep/srp/guidance/ecoscreening/); no VOCs were detected. Lead was in exceedance of chronic criteria at locations SW-1 – SW-4 and zinc was identified at location SW-3 above chronic and acute criteria, while reporting limits were greater than criteria for both cadmium and nickel. A review of the sediment data indicate exceedances of inorganic (arsenic, cadmium, chromium, copper, lead, nickel, silver and zinc) lowest effect levels of the NJDEP sediment screening guidelines, while only chromium exceeded severe effect levels at all locations. As there was only one sampling event since the last five-year review, observations on contaminant trends may not be made. EPA will work with NJDEP to ensure more frequent sampling of sediment and surface water is conducted. If elevated levels of inorganics persist, EPA will conduct a screening level ecological risk assessment.

Site Inspection The inspection of the site was conducted on May 20, 2014. In attendance were Richard Ho, EPA and Chad Van Sciver of the NJDEP. No significant issues were identified during the inspection. The site is currently not in use, except for the C&T system, and much of the area is overgrown with grasses and weeds.

Interviews During the five-year review process, interviews were conducted with Carlton Bergman and Ted Hayes of the NJDEP. The purpose of the interviews was to document any perceived problems or successes with the remedy that has been implemented to date. Interviews were conducted on

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November 4, 2014. No issues or perceived problems were raised during the interview. There were no interviews with local officials or community representatives.

Institutional Controls Verification A classification exception area (CEA), established on February 10, 1998, exists at the site as an institutional control, ensuring that potable wells are not installed in the contaminated shallow aquifer, thereby preventing exposure to the contaminants. Technical Assessment

Question A: Is the remedy functioning as intended by the decision documents? The groundwater C&T system is effectively capturing and treating the dissolved phase VOC and inorganic groundwater contamination. However, the presence of DNAPL has impacted the ability for the system to restore groundwater. A 2013 ROD Amendment selected a remedy to address the residual source. Once the source work has been completed, it is anticipated that the C&T system will be able to restore groundwater to beneficial use. Groundwater sampling conducted over the last five-years confirms that residual sources are present in the subsurface. In addition, surface water and sediment sampling show that VOCs are not discharging downgradient so it is concluded that the plume is effectively being contained by the pump and treat system. One round of surface water and sediment samples were collected and analyzed for metals. Only chromium exceeded ecological screening levels but trends could not be derived from a single sampling event. In order to determine if the chromium is persistent in sediment and surface water, it is recommended that surface water, sediment and groundwater be evaluated for chromium. In addition, since groundwater chromium has never been speciated, it is recommended that the groundwater sampling results also be evaluated for hexavalent chromium. The site is currently vacant (except for the pump and treat plant) and the groundwater use is prevented by the CEA.

Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives used at the time of the remedy still valid? The exposure assumptions and the toxicity values that were used to estimate the potential risks and hazards to human health followed the general risk assessment practice at the time of the 1992 ROD. Although the risk assessment process has been updated and specific parameters and toxicity values may have changed, the risk assessment process that was used is still consistent with current practice and the need to implement a remedial action remains valid. One potential exposure pathway that was not evaluated at the time of the remedy selection is vapor intrusion. VOC contamination is present in the groundwater and although there are no buildings on site, this pathway should be considered and is discussed further at the end of this section.

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Human Health Assessment In the 1992 ROD, a baseline human health risk assessment (HHRA) was conducted to evaluate potential risks to human health associated with exposure to site media including groundwater, surface water, soil and sediment. Results of the HHRA indicated that under the future residential land use scenario, unacceptable carcinogenic risk (1.26x 10-2) and noncarcinogenic health effects (Hazard Index of 362) were likely based on exposure to contaminated groundwater and soils at the site. Ecological Risk Assessment The remedy has reduced the exposure to ecological receptors by minimizing the pathways of exposure to contaminated soils, sediment and surface water by excavating soil and treating groundwater. Although no remedial actions were conducted in the wetland and drainageway areas, it was expected that remediating the soil would eliminate the surface runoff pathway and infiltration of contaminants to groundwater, while groundwater treatment would address any groundwater to surface water impacts. Inorganics in sediment and surface water continue to be identified at concentrations greater than NJDEP ecological screening values. In comparison to the 2010 five-year review report, VOCs do not appear to be a concern in either sediment or surface water, while inorganic concentrations remain elevated. Based upon these data, it is recommended that surface water and sediment monitoring be continued. In order to gain a better understanding of the inorganics present in surface water and sediment. Additionally, a background investigation to determine whether inorganic concentrations are being influenced by upgradient contaminant input would be assist in determining the source of metals contamination. Soil Cleanup Levels The soil clean up levels at the time of the 1992 ROD were the lower of the NJDEP Proposed Soil Cleanup Levels for Contaminated sites and the EPA Risk Based Preliminary Remediation Goals. COCs and their corresponding soil action levels were as follows: arsenic 20 mg/kg, lead 500 mg/kg, polychlorinated biphenyls 1 mg/kg, chromium 945 mg/kg and bis(2-ethylhexyl)phthalate 46 mg/kg. Review of the 1999 Soils RA Closeout Report indicate that slightly different action levels were used for lead (400 mg/kg), PCBs (0.49 mg/kg) and bis(2-ethylhexyl)phthalate (49 mg/kg). These levels were compared to current NJDEP’s Residential Direct Contact Soil Remediation Standards; the standard for bis(2-ethylhexyl)phthalate dropped to 35 mg/kg. PCBs to 0.02 mg/kg, and arsenic to 19 mg/kg. Despite these changes, the cleanup level for bis(2-ethylhexyl)phthalate is still within the acceptable risk range and the change does not impact the protectiveness of the remedy. Also, the arsenic cleanup level is based on state-wide natural background and is within EPA’s acceptable risk range. Currently, NJDEP does not have a cleanup level for total chromium, however, an interim guideline value of 20 ppm for hexavalent chromium and 120,000 mg/kg for trivalent chromium have been established. EPA’s risk-based screening level (RSL) for trivalent chromium is 120,000 mg/kg and 0.3 mg/kg for hexavalent

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chromium. Because of the random disposal practices at Ellis Property when it was operating, it is possible that hexavalent chromium was present at the site. However, because of the extensive soil excavation, it is likely that any elevated chromium in the soil was removed from the site. Nonetheless, EPA recommends that future groundwater samples include an analysis for hexavalent chromium, since this compound is highly soluble. Groundwater Cleanup Levels A comparison of the current New Jersey Groundwater Quality Standards (NJGWQS) with those used at the time of the remedy selection indicates several changes. Because several current NJGWQS are more stringent than those established during the 1992 ROD, they will need to be considered when determining completion of the groundwater remedy. The following RAOs were established for the site and remain valid: prevent contact with contaminated soil, which represents an unacceptable risk, or reduce contaminant concentrations in the soil below risk based levels; prevent further migration of soil contaminants into the groundwater; and prevent migration of contaminated soils off site. Additionally, the following groundwater RAOs were established for the site and also remain valid: prevent migration of contaminated groundwater off site; prevent the migration of contaminated groundwater into the underlying aquifers; prevent potential exposure to inhalation/vapor intrusion that presents unacceptable risk under future land use scenario; and return the aquifer to its designated use as a source of drinking water by reducing contaminant concentrations in the shallow groundwater to drinking water quality. Although not yet implemented, the additional remedial actions as outlined in the 2013 ROD Amendment are expected to help meet the soil and groundwater RAOs. The potential for soil vapor intrusion (VI) into indoor air is evaluated when site soils and/or groundwater are known or suspected to contain VOCs. Since the site does not contain any buildings other than the pump and treat facility, the VI pathway is currently incomplete. If in the future buildings were to be constructed on or within 100 feet of the site, they would be subject to a VI study based on elevated levels of VOCs (most notably TCE) in site soils and groundwater.

Question C: Has any other information come to light that could call into question the protectiveness of the remedy? No other information has come to light that could call into question the protectiveness of the remedy.

Technical Assessment Summary

The C&T system is containing the plume on site. Restoration of the groundwater is not occurring as anticipated due the presence of additional source material. A ROD Amendment selected a remedy for these source areas. Once implemented, it is anticipated that restoration of groundwater will occur. In the interim, a CEA prevents the unacceptable use of the groundwater.

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Issues, Recommendations and Follow-Up Actions The following are recommendations that improve data review but do not affect current protectiveness and were identified during the five-year review:

The source remedy needs to be implemented; EPA recommends that annual O&M include groundwater sampling for metals,

particularly hexavalent chromium; EPA also recommends that surface water and sediment data continue to be collected on

an annual basis; and In order to gain a better understanding of the inorganics present in surface water and

sediment, it may make sense to conduct a background investigation to determine whether inorganic concentrations are being influenced by upgradient contaminant input.

Protectiveness Statement

Sitewide Protectiveness Statement

Protectiveness Determination: Short-term Protective

Protectiveness Statement: The remedy currently protects human health and the environment because there is no human or ecological receptor exposure to contaminated groundwater or subsurface soils and the Site is not in use, and there are no anticipated ecological concerns associated with exposure to site contaminants. However, in order for the remedy to be protective in the long-term, the following actions need to be taken to ensure protectiveness: implement remedial actions selected in the 2013 ROD Amendment; collect and analyze additional sediment and surface water samples for metals; ensure state collects and analyzes groundwater samples in accordance with the operation and maintenance plan; and determine if hexavalent chromium is present above risk-based levels in groundwater.

Next Review The next five-year review report for the Ellis Property Superfund site is required five years from the completion date of this review.

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Attachment 1:Figure

THIRD FIVE-YEAR REVIEW REPORT FOR THE ELLIS ...THIRD FIVE-YEAR REVIEW REPORT ELLIS PROPERTY SUPERFUND SITE BURLINGTON COUNTY, NEW JERSEY < \ Sz PRO"^^ UJ C3 Prepared by U.S. Environmental

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