March/April 2007
Progress Update Ringwood Mines/ Landfill Site |
Ford Motor Company has been working closely with the United States Environmental Protection Agency (EPA), the U.S. Army Corps of Engineers and the New Jersey Department of Environmental Protection (NJDEP) to follow up on cleanup activities undertaken in the 1980s and 1990s at the Ringwood Mines Landfill Site in Ringwood, New Jersey, where waste materials from Ford's former assembly plant in Mahwah, New Jersey, were disposed from late 1967 through mid-1971. Other parties, including the Borough of Ringwood, used the site for the disposal of waste materials before, during, and after the period when Ford-related wastes were brought to the Site.
Ford is providing this Progress Update to share information about developments in the investigation and cleanup of the Site during the months of March and April 2007.
Status of Removal Activities
Ford has completed removal activities in nine of the twelve sludge removal (SR) areas identified during the reconnaissance survey.
Ford has completed initial restoration activities in SR-1 and SR-2, and submitted a request to backfill and restore the lower portion of SR-9. Pending approval by the EPA and NJDEP, Ford will complete backfilling and planting within SR-9 this spring.Pictures of Restoration Activities
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O'Connor Test Pit Investigation
This past November, Ford received approval from EPA and NJDEP to conduct a detailed investigation of the former O'Connor Disposal Area to characterize fill and waste materials. (The EPA-approved work plan is available on the Web site for review at www.ringwoodsiteupdate.com.) Pursuant to the work plan, Ford and its contractor have installed additional wells, excavated test pits and test trenches, and collected surface soil samples from within the O'Connor Disposal Area. When the investigation has been completed, a report on its findings will be prepared. The final, EPA-approved report will be available on its Web site www.ringwoodsiteupdate.com.
Results from groundwater sampling conducted in this area during Fall 2006 are already available on the Web.
Peters Mine Pit Investigation
In January 2006, the EPA approved Ford's work plan for investigation of the Peters Mine Area of the Ringwood Site. Pursuant to the approved plan, ARCADIS excavated a total of 10 test pits and 2 test trenches to characterize the nature and extent of fill materials surrounding the Peters Mine Pit. As expected, small amounts of buried paint sludge were encountered in some of the test pits. Paint sludge deposits were found in 2 excavated on the southern side of the pit. The bulk of the material observed during the test pit sampling process was cardboard and wood.
In addition to the test pit activities, ARCADIS installed additional groundwater monitoring wells in the vicinity of Peters Mine Pit and collected groundwater and surface water samples in September 2006. At the direction of EPA, Ford also submitted a work plan to lower a camera to the base of the Peters Mine air shaft (click here to see a map of area) and obtain water samples from appropriate depths within the shaft after the review of video footage obtained. In March, Ford's contractor was successful at lowering a camera to the base of the air shaft. EPA is reviewing the footage and will be identifying sampling locations.
Ford is preparing a report on the results of the Peters Mine Investigation and will post it on the Web site once it is approved.
In March, Ford submitted a revised work plan for the investigation of the former Cannon Mine Area, which is located in a portion of the Site that contains several historical mine pits. Based on EPA's comments, submitted to Ford in April, the scope of work for the investigation will include installation of 3 directional borings and excavation of 12 test pits. Also, ARCADIS will install 4 additional groundwater monitoring wells in the area and collect 10 surface soil samples.
In connection with the preparation of this work plan, Ford responded to EPA's request and completed a geophysical investigation of the area to determine the vibration levels emitted during remedial activities. In November 2006, Vibra-Tech Engineers, an independent contractor, submitted its final report based on data obtained in July 2005, April 2006 and October 2006. As discussed in Ford's November 2006 Question and Answer document (click here to view the Question & Answer) regarding sink holes at the Site, the data collected over the yearlong study indicate that vibrations associated with Ford's investigation and cleanup activities were generally lower than 'background' vibration levels near the residential properties, and below the standards that the United States Bureau of Mines has established for residential areas.
Investigation activities will begin following final approval from EPA and NJDEP.
Mine Tailings/Soil Investigation
Ford has received final approval from EPA and NJDEP to investigate and analyze mine ore, tailings, and background soil conditions at the Ringwood Site. The investigation will focus on arsenic, which has been detected in some Site soil samples. Arsenic is a trace metal known to be present in some of the magnetite ore and native rock at the Ringwood Site. The purpose of the proposed investigation is to determine (1) whether ore and mine tailings contribute to the arsenic that has been detected in some soils on the Site; and (2) to identify the 'background' or naturally present level of arsenic in soils at the Site. Sampling will commence this May.
SR-9 Investigation
In connection with the removal of surficial paint sludge from the SR-9 area, Ford's contractor, ARCADIS, identified a nearby area which contained buried drums and drum remnants. Under EPA and U.S. Corps of Engineers oversight, ARCADIS removed approximately 25-30 drums and/or drum remnants. The contents of the drums are being tested. It appears that the drums do not contain Ford-related waste and are not related to Ford. (As noted previously, and as confirmed in the Reconnaissance Survey [available at www.ringwoodsiteupdate.com] the Ringwood Site was used by the Borough of Ringwood and third parties for disposal activities over many decades.) Ford is investigating the origin of these drums and will update EPA and NJDEP on its findings.
SR-8 Investigation
Following approval from EPA to investigate an open cribbed mine shaft within SR-8, Ford has lowered a camera into the shaft to investigate whether any waste materials are in the shaft. Ford, EPA and NJDEP are currently reviewing the footage and will discuss an appropriate location to obtain a water sample from the shaft. Ford will post the results of this investigation once they have been approved by EPA.
Indiana Bat Survey
This past summer, at the request of the United States Fish & Wildlife Service (USFWS) and the EPA, ARCADIS undertook a survey to determine whether any Indiana Bats, a Federally Endangered Species, are at the Site. [The Bat Survey Work Plan is available on the Web at www.ringwoodsiteupdate.com]. No Indiana Bats were observed during the four days of netting operations. USFWS required Ford to conduct an additional survey to gather further information regarding the possible presence of Indiana Bats. In February 2007, Ford submitted a proposal to the USFWS and EPA to conduct a Winter Hibernacula Survey through its subcontractor, Bat Conservation Management, Inc. (BCM). Under the approved scope of work, BCM inspected mine features/tunnels to determine whether Indiana Bats were hibernating on the property. No Indiana Bats were observed. A preliminary report outlining the results of the winter survey was submitted to the USFWS by BCM. Once approved by EPA, Ford will post the report on its Web site www.ringwoodsiteupdate.com.
Ford's contractor, ARCADIS, is monitoring air quality at the Site on a daily basis to test for the presence of volatile organic compounds (VOCs) and particulate matter. [For more information, view Ford's Q&A Fact Sheet on Air Monitoring located at www.ringwoodsiteupdate.com.] Air monitors are located at the perimeter of the work area, and at an off-site location near the residences.
To date, air monitoring has not detected VOCs or particulates beyond the boundary of the work area at concentrations above Minimal Risk Levels (MRLs) established by the Agency for Toxic Substances and Disease Registry ('ATSDR').
A resident reported odors in the vicinity of Sheehan Drive and Peter's Mine Road in the early evening on April 26th. EPA, the police, and Ford's contractor were notified. (Ford did not receive notice until the following morning.) The Ringwood police, who responded promptly to the report, identified a slight odor but were not able to determine its source. EPA and the police were not able to identify the source of the reported odor. Ford's contractor has confirmed that at the time that the odor was identified, it was not engaged in any removal activities on the Site. Also, wind direction and velocity data that is recorded on a continuous basis on the Site indicates that at the time of the report, the wind was blowing from the residential area toward the work area, suggesting that the odors were not likely related to the work area. In addition, the air monitoring stations did not identify any exceedances during the period when odors were reported.
Although it does not appear that the odors reported at the site were related to work activities conducted by Ford's contractor, Ford understands that the identification of odors at the site can create concerns, and it encourages residents to immediately notify Ford's on-site contractor, ARCADIS at 973-962-6311 if they detect odors of concern while removal activities are being conducted on the site. Jon Holt, Ford Community Relations Representative, also can be contacted at 908-832-0557 in addition, of course, to the Ringwood Police Department (973-962-7017).
Office of Inspector General Report
On April 4, 2007, the EPA Office of Inspector General (OIG) released a report on the Ringwood Site entitled 'Environmental Justice Concerns and Communication Problems Complicated Cleaning Up Ringwood Mines/Landfill Site.' The OIG Report concluded that EPA Region 2 did not discriminate against Ringwood Site residents and that '[r]acial and socioeconomic factors did not appear to have any bearing on EPA efforts to clean up the Ringwood site.' Ford has submitted comments on the report to the Office of Inspector General and has posted them on its Web site www.ringwoodsiteupdate.com.
Ford and its contractor, ARCADIS, also participated in a public meeting on April 11, 2007, sponsored by OIG to discuss the findings of the report.
Ford and the Borough of Ringwood
We would like to clarify some misstatements in the press recently regarding Ford, the Borough of Ringwood and EPA.
Ford has been conducting environmental activities at the Ringwood site pursuant to the Administrative Order on Consent signed by Ford and EPA in September 2005. As the Borough of Ringwood had been involved in substantial non-Ford-related disposal activities at the Ringwood Site (before, during and after Ford's involvement at the Site), in September 2005, the EPA issued an Administrative Order to the Borough of Ringwood pursuant to Section 106(a) of CERCLA or the Comprehensive Environmental Response, Compensation, and Liability Act. [Click here to view a copy of the Administrative Order.] The Administrative Order that EPA issued to the Borough requires the Borough to pay for or perform a portion of the environmental activities being conducted at the Site. Ford has attempted to reach an agreement with the Borough of Ringwood with regard to the Borough's responsibility for investigation and cleanup work at the site. To date, the Borough has not paid or agreed to be responsible for any of the investigation or cleanup work requested by EPA.
The Administrative Order issued by EPA to the Borough states that failure to comply with the Order may subject the Borough to penalties payable to EPA of up to $32,500 per day. Ford has not requested or demanded that penalties be assessed to the Borough, and Ford is not suing the Borough. Any penalty assessment issue is between EPA and the Borough.
Ford believes the Borough should take responsibility for its fair share of environmental activities at the Site, and Ford continues to negotiate such costs with the Borough. It should be noted that the inability to reach an agreement with the Borough has not slowed down or stopped any of Ford's work at the site. Ford remains hopeful that there will be an amicable resolution of this issue with the Borough.
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Ford is committed to addressing remaining environmental issues at the Ringwood Site associated with the disposal of Ford-related wastes. Ford is also committed to keeping the community informed and addressing questions or concerns about Site activities. If you would like a copy of previous issues of the Progress Update, or have any questions regarding activities at the Site, please contact Jon Holt, Ford Community Relations Consultant at (908) 832-0557.
