Abstract/Why Reich Farm?

The Reich Farm Superfund site was listed on the National Priorities List in 1983 after drums and trenches filled with organic chemicals were found on a portion of the site leased to an independent waste hauler that specialized in transporting chemical wastes.  It was determined the chemicals had been dumped illegally for over five months in 1971, and could be traced back to an independent waste hauler and Union Carbide Corporation (UCC).  Treatment for the contamination lasted fifteen years after the initial NPL listing. 

On a personal level, the Reich Farm site is located about a mile from my childhood home and my mother and brother still live there today.  I wanted to get a beter understanding of what had happened there and of the so-called "cancer clusters" that I had heard so much about growing up.

Interviews

Rosalie McLaughlin, Resident of Toms River:

In March I interviewed my mother about the site, because she had mentioned it by name when I told her about Superfund and the class project we were involved in.  Also she currently lives about a mile from the site and has lived there the past 30 years.  She talked about the impact the news had in the community and about constantly reading about it in the local papers, and her concerns for the safety of my brother and myself because we were both in grade school around the time "cancer clusters" were making news.  Our family switched to bottled water once these clusters made news and rumblings began that they were linked to the drinking water supply



Jon Gorin, EPA employee and the Remediation Site Coordinator for Reich Farm:

I was able to reach Mr. Gorin by email and he explained to me the history of the Reich Farm site and the history of his involvement there.  I asked him about the hurdles associated with the Superfund process and he gave some examples as they related to the Reich Farm property.


Natalie Loney, EPA Community Involvement Coordinator for Reich Farm:

Ms. Loney is extremely busy apparently, as she is the CIC for several Superfund sites, but she was able to get back to me and explain a bit about her role in the Superfund process and what she recalled specifically about the Reich Farm case.  I appreciated her taking the time to get back to me and give my any information she could recall, because she works on numerous sites and has been doing so for a while it seems.

Location/Ownership

Reich Farm

Reich Farm is located in Toms River, New Jersey and is bordered by several businesses located along Route 9.  In 2003 the EPA reported the population within a 3-mile radius of the site was approximately 33,500 and the nearest residence was located about 500 feet southwest of the site (EPA 2003).  The site is also roughly a mile from the Garden State Parkway.  The site is still owned by Mr. and Mrs. Reich, who owned the property at the time of contamination.

Site Discovery/Preliminary Assessment

Contamination at Reich Farm occurred back in August of 1971 when Mr. and Mrs. Reich leased a portion of their property to a man named Nicholas Fernicola, who was an independent waste hauler at the time (EPA 1988).  Mr. Fernicola intended to use the land for the temporary storage of used 55-gallon drums, as he specialized in the transportation and disposal of chemical wastes (EPA 1988).  Around five or six months after leasing their property to Mr. Fernicola, the Reichs began to notice thousands of drums of waste were being stored on the property (UCC 2003).  Upon further investigation they discovered approximately 4,500 drums of waste on the property with an additional 450 empty drums, with labels on the drums such as “tar pitch,” “lab waste solvent,” “solvent wash of process stream,” and “blend of resin oil” (EPA 1988).  Most alarming, there were trenches dug on the property leased to Mr. Fernicola that seemed to indicate these were locations where wastes may have been dumped (EPA 1988).  Most of the drums on site had markings that indicated they were the property of Union Carbide Corporation (UCC), a subsidiary of The Dow Chemical Company that is still in business today and “specializes in the production and purchase of ethylene” (UCC 2011).

Upon making this discovery, the Reichs immediately joined forces with Dover Township and filed complaints against Mr. Fernicola and Union Carbide Corporation; this resulted in the New Jersey superior court ordering that the dumping of chemicals cease on the Reich Farm property and that all wastes and drums were to be removed (EPA 1988).  Union Carbide Corporation was responsible for drum removal and according to reports completed the removal in March of 1972, although an additional 51 drums were removed in June of 1974 (EPA 1988).

A preliminary assessment and site investigation was undertaken in early 1974 after local residents began to complain of an unusual taste and odor to their well water supply (EPA 1988). Preliminary investigations undertaken by the NJDEP in focused on the sampling of water from these well systems and concluded that petrochemical elements were present in the water supply, including toluene and phenol (EPA 1988).  After more extensive sampling was done the Dover Township Board of Health used the results of these sampling activities to that 148 private wells be closed by the end of August (1974), in addition to establishing a zoning ordinance that restricted ground water use in the area around Reich Farm (EPA 1988).

Contamination

Preliminary and remedial investigations at the Reich Farm site in 1977 found a wide variety of organic and inorganic contaminants in both the soil and the aquifer below, although not all of them can be attributed to the dumping of chemicals there.  Metals such as cadmium, nickel, lead, chromium, iron, and manganese were detected in groundwater during preliminary remedial investigations; however, knowledge of the wastes and labels on the UCC drums, coupled with the random nature of the detections, seems to indicate that Reich Farm is not the source of these metal contaminants (EPA 1988).  Nevertheless major contaminants that can be traced back to Union Carbide Corporation were discovered in the groundwater (chlorobenzene, tetrachloroethene, trichloroethene, 1,1 and 1,2 dichloroethene), soil (xylenes, styrene), or both (ethylbenzene, toluene, acetone) (EPA, 1988).  The EPA’s Record of Decision from 1988 has an extensive list of both organic and inorganic chemicals found in soil and groundwater at the Reich Farm Superfund site, and differentiates between those that can be assumed to be related to the organic chemical wastes that were dumped there and those that are likely unrelated to dumping events.

The difficulty with many of these pollutants is that they have the ability to travel and the tendency to concentrate themselves in the lower levels of the soil, anywhere from fifteen feet down to thirty five feet down (EPA 1988).  This made it easy for the contamination to eventually impact the aquifer below the Reich Farm site, which fed into the drinking water supply for local residents.  Further compounding the issue was the fact that sampling for the remedial investigation took place in 1987, over fifteen years after the suspected contamination.  This lead to a public health evaluation (PHE) which identified thirteen indicator chemicals that existed in higher than normal concentrations within the soil and water at the site but still declared that the site would not be a public health risk and that there was no indication of Reich Farm contaminating private drinking wells or the aquifer below the Superfund site (EPA 1988).  This was an incorrect diagnosis of the potential human health impacts, as cancer clusters have developed in affected areas (UCC 2003).  This would seem to indicate that pollutants migrated away from the Reich Farm boundaries by the time sampling was done, or sampling wasn’t thorough enough in attempting to determine health risks, or a combination thereof.    No environmental assessments were ever done on the property but the 1988 Record of Decision (ROD) states that “it does not appear to pose a significant risk to the local flora or fauna” and that groundwater contamination did not present a toxic potential or the potential to bioaccumulate in any stream ecosystems (EPA 1988).

NPL Listing/Potentially Responsible Parties (PRPs)

Based off of preliminary investigations done in 1977, Reich Farm was one of 418 sites placed on the EPA’s proposed NPL that was published in December of 1982 (EPA 1988).  Final approval for inclusion on the NPL was given in September of 1983 and the site was officially listed on the National Priorities List (1983), based on the use of the EPA’s Hazard Ranking System (EPA 1988).  Three responsible parties were identified for the contamination of the Reich Farm site:  The Reichs, Union Carbide Corporation, and Mr. Fernicola (the waste hauler) (UCC 2003).  Union Carbide Corporation has paid for the majority of cleanup costs whereas the Reichs responsibilities are mostly limited to allowing cleanup companies access to their property, although they were ordered to pay for the construction of a fence around the contaminated area.  Mr. Fernicola eventually had all charges against him dropped by the New Jersey Department of Environmental Protection in exchange for his agreement to stop transporting and disposing of chemical wastes (EPA 1988).

Remediation Investigations/Feasibility Study and Record of Decision

Groundwater Contamination at Reich Farm

Remediation investigations and feasibility studies were undertaken in 1986 and 1987.  The investigations were done by the Environmental Protection Agency, beginning in May and June of 1986 and completing in April of 1988 (EPA 1988).  Migratory pathways were identified that suggested contaminants could move from the soil to the air and from the soil to the water, although soil to air pathways were found in the PHE to be of no risk to human health due to low levels of volatile organics in surface soils (EPA 1988).  Soil contaminants were deemed unlikely to migrate to surface water but the PHE indicated that it could potentially migrate to groundwater, although a thorough analysis wasn’t done because the semi-volatile showing the highest levels in soil samples was already present in the groundwater in the area

(This lack of analysis would eventually lead to the groundwater being declared safe when it in fact wasn’t.)

Based off the RI/FS, six remedial alternatives were considered for treatment of the soil and four were considered for the groundwater (EPA 1988).  “No remedial action” was suggested for both the contaminated medias but was dismissed as a viable solution, despite the low costs when compared with other remedial actions.  For the soil, placement of a cap upon the soil was considered as well as an idea of transporting the contaminated soils to incinerators at off-site locations (EPA 1988).  Ultimately the EPA determined that “enhanced volatilization” would be the best method for this site, which is a process in which soil is placed in a thermal dryer and then injected with hot air (EPA 1988) (UCC 2003).  The hot air forces organic compounds to volatize, after which they can be combusted (EPA 1988).  Groundwater alternatives included processes such as air stripping, carbon absorption, and granular activated carbon absorptions (EPA 1988).  Air stripping, like the enhanced volatilization used for treating soils, utilizes hot air injections to create “off gases” of volatiles that can be removed from the groundwater by pumping (EPA 1988).

Costs For ROD Recommendations

The enhanced volatilization of the soil was estimated to cost $1,916,000 over a nine month period, but without construction or maintenance costs thereafter (EPA 1988). 

The combination method suggested for groundwater treatment would cost $3,916,000 in total with an eleven year implementation period, and would include a $905,000 construction cost and $390,000 in annual maintenance (EPA 1988).

Remedial Design/Remedial Action

Reich Farm Groundwater Plume

Union Carbide Corporation was responsible for the Remedial Design/Remedial Action after the proper remediation techniques were recommended, and funded the cleanup efforts almost entirely (EPA 1988).  Following its pre-design activities UCC also agreed to evaluate the results of its remedial actions and to improve the system if evaluations deemed it necessary (UCC 2003). An initial phase of groundwater and soil sampling took place in 1991 and was followed by a study to determine remediation costs and whether or not a thermal desorption treatment would be viable (UCC 2003).  The results of this study lead to changes in the remediation plans which determined a Parkway well field would be used for groundwater treatment, rather than relying on a process where groundwater would be treated directly beneath the Reich Farm site and then transported up gradient from the site (UCC 2003).  This change was the result of the EPA’s conclusion that groundwater contamination extended to a Parkway well field located one mile south of the Reich Farm Superfund site (UCC 2003).  Another change to the plan was the decision to ultimately use the treated water from this Parkway well field as a municipal water supply, rather than transporting it back into the ground water supply up gradient (UCC 2003).   

1995 ESD/Construction Completion/Cleanup Completion

In 1995 an Explanation of Significant Differences was created to allow for public commentary on the changes to the RD/RA (EPA 1998).  The ESD indicated that the new plan would save the project $2 million by negating the need to create a well for treatment and by utilizing the treated water for municipal uses rather than re-injecting the water back into the groundwater supply (EPA 1998).  No changes were ever suggested for the treatment of the contaminated soils at Reich Farm and soil remediation was completed by May of 1995, although the volume of contaminated soils was more than seven times larger than originally estimated (EPA 1998). 

The groundwater treatment system completed construction in 1997 and by 1998 a Preliminary Close-Out Report had already been submitted (EPA 1998).  Four activated carbon units were added to the treatment system in 1997 as a measure to remove compounds that had been more recently identified (EPA 2003).  In June of 1999 an additional containment well was constructed in order to further protect unimpacted wells in the Parkway well field (EPA 2003).  This was because one year earlier in 1998, another Explanation of Significant Differences was released that indicated that two of six wells within the Parkway well field that had been being used for groundwater treatment were determined to still have low levels of contamination (EPA 1998).  The ESD included a recommendation from the NJDEP that these two wells be excluded from use as public water supply unless it became absolutely necessary down the road (EPA 1998).  These same contaminants have later been linked to a high incidence of childhood cancer among residents whom received drinking water from the Parkway well fields (UCC 2003).

Reich Farm Future Site Use

SAN Trimer

At this point it would appear that the site is best being left alone at this point as it is subject to monitoring activities sponsored by Union Carbide Corporation and the EPA, and studies are still ongoing about the contamination that occurred there and possible links to cancer clusters that sprouted up in the area.  There are no records to indicate that the site has been officially deleted from the National Priorities List despite their being no further cleanup activities taking place at the site. 

The EPA issued the last five year review in 2008 and did not recommend any further cleanup procedures, but established continued sampling requirements for the site due to concerns over a new breed of semi-volatiles known as “SAN Trimer” that had developed due to reactions within the treatment wells (EPA 2008).  The EPA continues to perform studies that are testing the relative toxicity of SAN Trimer and attempting to determine its potential as a carcinogen (EPA 2008).

Conclusions About Superfund

The Superfund process ultimately works because it can help answer the question of “who is going to pay for the cleanup?” and this is often the most important question when dealing with contaminated sites.  The biggest problem under the current system, in my opinion, is the lack of funding given to it by the government and that would be my main tweak.  The Environmental Protection Agency currently relies on the finding of PRPs (potentially responsible parties) in order to charge them with the cleanup because the “Superfund” has essentially been empty for years now. 

Often times it becomes difficult to find PRPs at a site or things get tied up in litigation, meanwhile sites continue to degrade and pollution and contaminants continue to remain in an environment longer than they should have to.  If the Superfund was restored to where it had been previously the EPA would be able to begin cleanup at sites such as this and then go after potentially responsible parties to seek reimbursement, rather than to seek initial funding of cleanup.  This would help make the process more successful in the future when dealing with Superfund contamination sites.