& PARRE1 10 ASSOCIATES, P.A., CONSULTING ENGINEERS

REMEDIAL INVESTIGATION REPORT1 REMEDIAL ACTION WORKPLAN Monmouth County Park System

Block 19, Lot 47 Township of Holmdel, Monmouth County, New Jersey

N JDEP Case No. 98-12-30-1435-14-23 NJDEP Case No. 09-09-11 -11 37-19

Submitted to:

MONMOU'TH COUNTY PARK SYSTEM 805 Newman Springs R Lincroft, New Jersey 07

December 31,2009

HEADQUARTERS .oad '738

TABLE OF CONTENTS

I .O EXECUTIVE S:UM;MARY ...................................................................................... I 1.1 Background ........................................................................................................................ 1 1.2 Quality Assurance Project Plan ........................................................................................... 1

2.0 REMEDIAL INVESTIGATION .............................................................................. 2 . . 2.1 Surface Water Investigation ................................................................................................. 2 2.2 September 2009 Groundwater Investigation ....................................................................... 3

3.0 REMEDIAL ACTION WORKPLAN ...................................................................... 3 3.1 Ground Penetrating Radar Event ......................................................................................... 4 3.2 Enhanced Fluid Recovery Event .......................................................................................... 4 . . 3.3 Groundwater Investigation. ................................................................................................. -4 3.4 Project Schedule.. ................................................................................................................ .5 3.5 Remedial Action Cost Summary ......................................................................................... 5 3.6 Reporting. ........................................................................................................................... -5

4.0 CLOSING AND LIMITATIONS ............................................................................. 6

LlST OF DRAWINGS

Drawing No. 1 - USGS Topographic Map Drawing No. 2 - Tax Map Drawing No. 3 - Subject Property Layout

LlST OF TABLES

Table No. 1 - Surface Water Sampling Field Data Table No. 2 - Summary of Surface Water Sample Analytical Results

LlST OF APPENDICES

Appendix A - Surface Water Sample NJDEP Reduced Data Deliverable Package and EDD CD

Appendix B - Updated Project Implementation Schedule

1.0 EXECUTIVE SUMMARY

French & Parrello Associates, PA (FPA) performed a Remedial Investigation (RT) on the site

identified as Moiunouth County Park System - Holmdel Park, Shelter Site, Block 19, Lot 47,

Township of Holmdel, Monmouth County, New Jersey (project site). (Refer to Drawing No. 1

and Drawing No. 2 for the project site location). The RI documented in this report included a

moilitoring well gauging event and a surface water sampling event. The following Remedial

Investigation RepodRemedial Action workpi& (RIR/RAW) outlines the RI activities

completed during this phase as well as the proposed remedial activities.

I Background

The project site is a poition of the Monmouth County Park Systems - Holmdel Park. Previously, a

fuel oil Underground Storage Tank (UST) was removed from the project site; that of which, several

remedial investigations and activities have been performed by various environmental consulting

firms. Excluding the recent discovery of free phase product (FPP) in monitoring well MW-1, site

conditions remain similar to the conditions reported in the RAW dated August 6,2009.

1.2 Quality Assurance Project Plan

The intention of this Quality Assurance Project Plan (QAPP) is to provide sufficient detail

regarding the classification of a surface water sample collected near t hc project site. The

investigation was perfolnled in accordance with the requirements of the New Jersey Department

of Enviromnental Protection's (NJDEP's) Technical Requirementsfor Site Remediation (TRSR).

All fieldwork was conducted in accordance with the guidelines set forth in the NJDEP's August

2005 Field Sar?zpling Procedures iWa17ual. All laboratory analytical data is presented in NJDEP

reduced deliverable format with corresponding electronic data deliverables (EbDs).

'fie pi-imary objective of field sampling and laboratory analytical testing was to confinn the

Holnldel Park Pond was not impacted by the documented release within the project site. The

Remedial Investigation ReportlRemedial Action Workplan December 3 1,2009 Monnlouth County Park System - Holindel Park, Shelter Site Page 1

surface water sample was obtained utilizing dedicated sampling equipment in accordance with

the TRSR, and as further outlined in subsequent sections of this RIRRAW. Alpha Analytical,

Inc. (Alpha), a New Jersey state certified laboratory, certification number MA01 5, performed all

Quality Assurance/Quality Control (QNQC) procedures specified in the analytical methods.

FPA reviewed the QAIQC procedures performed by Alpha, and deemed them in compliance

with NJDEP requirements; therefore, the data presented within this report can be assumed

accurate.

2.0 REMEDIAL INVESTIGATION

The following sections outlii~e the tasks performed pursuant to the RAW dated August 6,2009.

Prior to the commencement of onsite activities, FPA conducted a Health and Safety meeting with

all onsite individuals; a copy of the site-specific Health and Safety Plan remains on file at the

FPA office.

2.1 Surface Water Investigation ---.

In order to evaluate surface water quality, on September 9,2009, FPA collected a surface water

.- sample from the Holmdel Park pond located near the project site. No evidence of impact was

observed in the subject pond; therefore, FPA collected the surface water sample, identified as

PW-1, biased toward the nearest preferential migration pathway for coiltarnination, which is a

subsurface drainpipe that discharges into the pond. .-.-

The surface water sample was transferred directly into laboratory-supplied glassware, and - - preserved in a temperature-controlled environment (4" Celsius) until it was transported to Alpha

for analysis. PJV-1 was transported to Alpha wifhin 48 hours of collection and iu~der full chain- , of-custody documentation. The sample was in the possession of FPA personnel until it was

relinquisl~ed to the laboratoiy. Pursuailt to the NJDEP TRSR, PW-1 was analyzed for base -.. neutrals plus a 15 coinpound library search (BN-tlS) and volatile organics plus a 10 compound

- Remedial Investigation Report/Remedial Action Workplan December 3 1,2009 Momout11 County Park System - Holmdel Park, Shelter Site Page 2

library search (V0+10). (Refer to Table No. 1 for field sampling data; refer to Drawing No. 3

for the surface water sample location.)

According to analytical results, targeted compounds were not detected. FPA recommends no

firther action for this area of concern and requests "No Further Action" designation. (Refer to

Table No. 2 for a summary of the surface water sample analytical results; refer to Appendix A

for the NJDEP reduced deliverable package and a CD containing the EDD files).

2.2 September 2009 Groundwater Investigation

Pursuant to the RAW dated August 6, 2009, FPA conducted a groundwater gauging event of

MW-1 on September 9, 2009. The gauging event included the measuring and logging of the

depth-to-water, depth-to-bottom, and the screening for evidence of FPP or signs of impact in

each well. Duling tlle gauging of MW-1, approximately four inches of FPP was observed to be

floating on the surface of the water. The presence of FPP was not anticipated based upon prior

investigations. Groundwater sampling was not conducted. Due to the presence of FPP, an FPA

-. representative called the NJDEP Hotline and the release was assigned the NJDEP Case Number:

09-09-1 1-1 137-19.

3.0 REMEDIAL ACTION WORKPLAN

'--

PPA proposes to conduct an interim Remedial Investigation/Remedial Action (RIIRA). The

interim RIIKA will include a Ground Penetrating Radar (GPR) survey and an Enhanced Fluid

Recoveiy PFR) event, which will be followed by additional gauging events. Prior to the

.- coinmencement of onsite activities, FPA will conduct a Health and Safety meeting with all onsite

individuals; a copy .of t l~e site-specific Health and Safety Plan is on fde at the FPA office. The

following sections outline the proposed tasks.

Remedial Investigation Repoi-t/Remedial Action Workplan December 3 1,2009 Moninouth County Park System - Wolindel Park, Shelter Site Page 3

, i 3.1 Ground Penetrating Radar Event

According to historical research, the only known source of contamination, a fuel oil UST, was

removed circa 1998, and subsequent soil remediation was completed. During early groundwater

investigations, FPP was not observed in the onsite monitoring wells, nor was it observed during

soil borings advanced circa 2008. Due to the new presence of FPP, FPA proposes to conduct a

GPR survey of the project site with intentions of determining the source of the new FPP (i.e. a

second UST). Additionally, due to the quantity of subsurface utilities within the impact area,

FPA anticipates locating and marking the subsurface utilities during the GPR event.

3.2 Enhanced Fluid Recovery Event

Simultaneous to the GPR survey, FPA proposes to conduct an EFR event. The primary purpose

of this EFR event is to remove the existing FPP from MW-1 and surrounding areas.

Additionally, once FPP is removed, pending supplemental gauging results, FPA will potentially

be able to rule out an incidental or acute release. Utilizing a vacuum truck, the contents of MW-

1 will be purged until evidence of FPP no longer exists. The purged oillwater mixture will be

transported off-site for proper disposal. (Refer to Drawing No. 3 for MW-1 location).

3.3 Groundwater Investigation

Upon the completion of the EFR event, subsequent to a two-week stabilization period, FPA

proposes to conduct a monitoring well gauging event. Monitoring well gauging will include the

measuring and logging of depth-to-water, depth-to-bottom, and the screening for FPP utilizing an

oil-water interface probe in the three onsite monitoring wells. If, after the two-week stabilization

period evidence of FPP no longer exists, subsequent to a second two-week stabilization period,

FPA will conduct a second gauging event. If after-the second gauging event, FPP is still no

longer present, FPA will propose additional groundwater gauging and sampling events. If, after

the initial two-week stabilization period, FPP still exists, FPA will evaluate remedial action

alternatives with the client. (Refer to Drawing No. 3 for monitoring well locations).

Remedial Investigation Report/Remedial Action Workplan December 3 1,2009 Monmouth County Park System - Holmdel Park, Shelter Site Page 4

3.4 Project Schedule

An updated Project Implementation Schedule is included as Appendix B. The schedule is

dependent upon review and approval from the NJDEP Case Manager.

3.5 Remedial Action Cost Summary

The costs associated with the supplemental remedial action outlined in this RIRIRAW, totals

approximately $4,300.00.

3.6 Reporting

Upon the completion of the above outlined tasks, pending the results, FPA will prepare either a

Remedial Action ReportRemedial Action Workplan (RARIRAW) or a Remedial Action

ReportJRemedial Investigation Workplan (RAR/RIW). The RARIRAW or RARRIW will

include the completed tasks as well as the proposed activities.

Remedial Investigation ReportRemedial Action Workplan December 3 1,2009 Monmouth County Park System - Holmdel Park, Shelter Site Page 5

4.0 CLOSING AND LIMITATIONS

FPAYs completed tasks and proposed tasks have been, and will continue to be, performed in

accordance with the scope of services authorized by the Monmouth County Park System and

NJDEP approvals. Services performed by FPA during this project have been, and will continue

to be, conducted in a manner consistent with the level of care and skill ordinarily exercised by

members of the profession currently practicing in the same locality under similar conditions.

Respectfully submitted,

FRENCH & PARRELLO ASSOCL4 TES, P.A.

C. Dudley ~ a h e r , I11 Senior Project Manager

Remedial Investigation ReportJRemedial Action Workplan December 3 1,2009 Monmouth County Park System - Holmdel Park, Shelter Site Page 6

MCPS - HOLMDEL PARK, S H E L T E R SITE ROBERTS ROAD, TOWNSHIP OF HOLMDEL

MONMOUTH COUNTY, NEW JERSEY

FRENCH & PARRELLO 7.5-MINUTE USGS TOPOGRAPHIC MAP

ASSOCIATES, P.A., CONSULTING ENGINEERS KEYPORT QUADRANT

I SCALE, I CONTOUR INTERVAL, ( PHOTO REVISEDn I FIGURE #

300 Route 34, Suite 101 Wall, NJ 07719 732 312-9800 1" = 2.000' 1 lo' 2007 DATG I DRAWN BY0 I PROJECT NUMBER* 1

g - w

FRENCH & PARRELLO ASSOCIATES, P.A., CONSULTING ENGINEERS

1800 Route 34, Suite 101 Wall, NJ 0771 9 732 312-9800

MCPS - HOLMDEL PARK, SHELTER SITE ROBERTS ROAD, TOWNSHIP OF HOLMDEL

MONMOUTH COUNTY, NEW JERSEY

TAX MAP I SCALE, I BLOCK, I LOT* I FIGURE rY

1" = 250' 19 47

DATE. DRAWN BY. PROJECT NUMBER*

11 /20/2009 B JH 08EOOl A

SHELTER BUILMNO 226

ELECTRIC UTlUTY

8URAOE WATER SAMPlE W T l O n

@-....1.......TlOn

MCPS - HOLMDEL PARK, SH'ELTER SITE ROBERTS ROAD, TOWNSHIP OF HOLMDEL

MONMOUTH COUNTY, NEW JERSEY , ,

: - FRENCH & PARRELLO ASSOCIATES, P.A., CONSULTING ENGINEERS

SUBJECT PROPERTY LAYOUT

SCALE* BLOCK. LOT, FIGURE #

NJ 07719 732 312-9800 1' = 40' 19 47

DATE, DRAWN BY. PROJECT N U 3 11 /20/2009 BJH 08E001A

TABLE NO. 1 SURFACE WATER SAMPLING FIELD DATA

MONMOUTH COUNTY PARK SYSTEM - HOLMDEL PARK, SHELTER SITE

Visual = Visual evidence of environmental impact Odar = Odar associated with an environmental release VO+7 0 = Volatile Organic plus a library search of 7 0 compounds B/N+75 = Base Neutrals plus a library search of 75 compounds

. . . "

Sample .ID

PW-I

French and Parrello Associates, P.A. December 31,2009

, . _ , . ~:.. . . . . . . . .-" . . .

. D:ate

9/9/2009

.. . . . " .a".".".'..'- , - " .

. . . . Tim& . . . . . . :

10:30

.. -.-,. ':' ; . . , . . . . . .

Depib:', . . ....

Surface

..... "'~.'"'..," ..:':! ., . , .: " , . . . :?. 'Visual::. .

. . . . . . . . . . . .

N o

............ . . : . . . ' -..,.- ',"' ;.. . . .

. ' . : .~dbc:.. :: .:, : ? , , .

N o

.-..... ......... ................ . . . . . . . . . . . . . . . ';:"."'. ." . . . . . . . .c' .; ;:r",,i ...,;. - . . . . . . . . . . . . . . . . , . ._ . . . . . . . . . .... ..... :,. 2,: . . I . " .......... , ... ' 1' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ' . . . . . . . . , . . . . . .

2..

VO+lO & B/N+I 5

TABLE NO. 2 SUMMARY OF SURFACE WATER SAMPLE ANALYTICAL RESULTS

MONMOUTH COLINTY PARK SYSTEM - HOLMDEL PARK, SHELTER SITE

NOTES: All results are reported in micrograms per liter ( pg/L) (ppb) SWQC = Surface Water Quality Criterion Aq. Acute = Aquatic Acute Exposure Criteria Aq. Chronic = Aquatic Chronic Exposure Criteria HH = Human Health Criteria

French and Parrello Associates, P.A. December 31,2009

Christine Todd Whitman Governor

Department of Environmental Protection

Bureau of Field Operations Underground Storage Tanks Unit

PO Box 435 401 East State Street

Trenton, NJ 08625-0435

James J. Tmcer Monmouth County Board of Recreation Commissioners 805 Newman Springs Road Lincroft, NJ 07738-1695

Robert C. Shinn, Jr. Commissioner

e iioimdei Park 845 Holmdel Road, Holmdel, Monmouth County Block: ? Lot: ? Case # 98- 12-30- 1622-03 Closure # N98-1841 UST # 0224688

Dear Mr, Tmcer:

On 30 Dec 1998, the New Jersey Department of Environmental Protection (Department) received notification of a discharge of hazardous substances fiom the above referenced facility which islare regulated under the Underground Storage of Hazardous Substance Act (N.J.S.A. 58:lOA-21 et seq). On 13 Mar 2000, the Department received a Remedial Investigation Report (RR) from Brinkerhoff Environmental Services, Inc. on behalf of the Monmouth County Board of Recreation Commissioners indicating actions were taken in compliance with the Regulations Implementing the Underground Storage of Hazardous Substances Act (N.J.A.C. 7:14B sea.)

This closure consisted of the removal of one 1,000 gallon #2 he1 oil underground storage tank (UST), one 2,000 gallon #2 he1 oil UST, and all associated piping.

Based upon a review of the remedial investigation completed to date, the following deficiencies shall be addressed as required below.

A. Remedial Investigation

1. General

Please submit the block and lot information for this facility.

2. Soil

Please submit the chromatogram for sample PE-5 (lab ID 9908394, file ID Dl033 fiom 20 Aug 1999, at 0214). . ~

The Monmouth County Board of Recreation Commissioners shall determine the depth to ground water and the percent silt and clay of the soil between the contaminant and the saturated zone. The percent siltlclay shall be determined via sieve analysis. If the soil between the contaminant and the saturated zone is comprised of less than fifteen percent silt and clay or if ground water is encountered within two feet of the contaminant, a Ground Water Remeha1 Investigation is required and shall be

NewJersey is an Equal Opportunity Employer Recycled Paper

conducted pursuant to N.J.A.C. 7:26E-4.4. In addition, a ground water investigation may be required if any of the areas of concern at which soil contamination was detected is located within 2,000 feet of a public supply well, as determined from a map of public supply wells which is available f?om the Department Bureau of Revenue, Maps and Publications (609)-777-1038) or through the Department's Internet home page (http://www.state.nj.us/de~/n&gi, then select 'WJGS Geodata").

3. Ecological Evaluation

A baseline ecological evaluation shall be completed for each contaminated site or area of concern in accordance with N.J.A.C. 7:26E-3.11. This baseline evaluation shall be qualitative in nature and based on site investigation sample results and a site inspection by a person experienced in the use of techniques and methodologies for conducting ecological risk assessment in accordance with EPA guidance. This evaluation shall be used to determine when further sampling and evaluation is required, pursuant to N.J.A.C. 7:26E-4.7.

II. - Other

A. Certification Requirements

Effective April 25, 1992, all persons performing tank services must be certified per N.J.S.A. 58: 10A-24.1-8. AU work related to any tank service shall now be conducted by, or under the immediate on site supervision of an individual certified in the activity being conducted. documents (tank closure and permit applications, reports, proposal(s) submitted to the Department shall be prepared and signed by a certified individual.

B. Costs

After remediation of the soil and ground water has been completed the responsible party is requested to submit the total capital costs involved in performing and confirming a cleanup as well as the costs associated with the proper disposal of all wastes generated during the cleanup. Costs to be reported include monitoring systems, equipment and mobilization costs; operational and maintenance costs, including all labor, utilities and repairs; consulting and labor costs, and sample costs; all disposal costs, including transport, waste transfer and facility tipping fees as well as regulatory review fees.

III. Reporting Requirements

A. Written Report Requirements

A written report (RI Addendum Report) shali be submtted to the Case Manager referenced beiow in the Bureau of Field Operations within 45 days of receipt of this letter. This report shall detail the results and conclusions for all activities conducted in compliance with the requirements listed in this letter. TO facilitate processing, please reference the Case Number, Tank Closure Approval Nurnber(s) and UST Registration Number in the report. In addition, if soil or ground water contamination is present, a Remedial Action

t Workplan shall b,e submitted with RI Addendum Report. If no fiuther remediation is required for the site, a proposal for no further action shall be submitted.

B. Block and Lot Requirements

Please be advised that block and lot numbers are required to be included in the Remedial Investigation Report (RlR) pursuant to N.J.A.C. 7:26E. If the block and lot numbers were not submitted with the RE, please include them in the RI Addendum Report.

IV. Compliance

Failure to submit the information requested by the deadline set forth above, will result in this case being referred to the Bureau of Field Operation's Case Assignment section to prioritize the site on the Comprehensive Site List. Please note, pursuant to N.J.S.A. 58:lOA-21 etseq. and N.J.A.C. 7: 14B gt seq., the owner and

operator of the regulated underground storage tanks are strictly liable for compliance with these requirements. In addition, all state regulated USTs, except for heating oil USTs for on-site consumption, are regulated under 40 CFR Part 280. Non-compliance with these federal and state regulations exposes the tank owner and operator to the penalty and liability specified in 40 CFR Part 280, N.J.S.A. 58:lOA-21 et seq. and N.J.A.C. 7:14B @

The Department reserves the right to implement 111 enforcement measures, including the right to assess penalties fiom the original due date and to revoke tank operating registrations.

If you should have any questions regarding h s matter, please contact me at (609) 777-191 1.

Sincerely,

/dd~fy Robert P. Posey, Case anager Bureau of Field Operations

Richard J. Codey Acting Governor

Department of Environmental Protection

Bureau of Southern Case Management 401 East State Street

P.O. Box 433 Trenton, NJ 08625 Fax: (609) 777-4285

Mr. James Mowczan Assistant Engineer Monmouth County Board of Recreation Commissioners 805 Newman Springs Road Lincroft, NJ 07738-1695

Bradley M. Campbell Commissioner

Re: Monmouth Cotr;ty Pit& Systenl-- Ho!:~:del Pr?.rk 545 Holmdel Road Holmdel, Monmouth County Closure # N98-184 1 Case # 98-12-30-1622-03 UST # 0224688 Remedial Investigation Report Dated: July 3 1,200 1 SEC # 9

Dear Mr. Mowczan:

The New Jersey Department of Environmental Protection (Department) reviews Remedial Investigations (RI) and Remedial Action (RA) reports at the site for compliance with the Underground Storage of Hazardous Substances Act, N.J.S.A. 58:lOA-21 et seq. (UST Law) and the "Technical Requirements for Site Remediation," N.J.A.C. 7:26E (Technical Regulations). The - Department has recently undertaken such a review for the above referenced site. This correspondence contains a summary of the latest site conditions and work completed to date as included in the above referenced report and details remaining remedial requirements to ensure compliance with the UST Law and the Technical Regulations. Compliance with these requirelnenls should allow the site to proceed to the completion of corrective action and eventual case closure.

Based upon a review of the remedial investigation completed to date, the following requirements shall be addressed as listed in Sections I, 11 and IU below. The results of tbse r~med;~.l requirements shall be submitted as part of a Remedial Action Workplan (RAW).

I. emedia l Investigation

Area of Concern (AOC) 1 is identified as a former 1,000-gallon fuel oil underground storage tank (UST) at building H225. T h s UST held #2 fuel oil, it's construction and date of installation are unknown. The UST at this AOC was removed on December 30, 1998. Photoionization detector @ID) readings during excavation were greater than 100 units above ambient background. Upon excavation, one %-inch corrosion hole was identified.

On January 4, 1999, five post-excavation soil samples (SS-1 through SS-5) were collected at 9.5 feet below grade (fbg). Samples were analyzed for total petroleum hydrocarbon (TPH). Analytical results inhcated no samples exceeded the Department's Impact to Ground Water Soil Cleanup Criteria (IGWSCC), therefore volatile organic (VO) analysis was not performed.

AOC2 is identified as a former 2,000-gallon fuel oil UST at building #226. This UST held #2 fuel oil, it's construction and date of installation are unknown. The UST at this AOC was removed on December 30, 1998. PID readings during excavation were greater than 100 units above ambient background. Upon excavation, several %-inch corrosion holes were identified.

New Jersey is an Equal Opportunity Employer Recycled Paper

On December 30, 1998, three post-excavation soil samples (SS-1 through SS-3) were collected at 7 to 9 fbg. Samples were analyzed for TPH. Analytical results indicated soil sample SS-3 contained TPH at 33,100 parts per million (ppm). Since it was determined that soil excavation would be conducted, no VO analysis was performed.

On August 10, 1999, soil excavation was conducted at this AOC. Maximum depth of the excavation was 11 fbg. Approximately 70 tons of soil were excavated and stockpiled on-site for disposal. Five post-excavation soil samples (PE-1 through PE-5) were collected at the base and sidewalls of the excavation. Samples were analyzed for TPH. Analytical results indicated PE-5 contained TPH at 1,590 ppm. VO analysis was performed on PE-5 only. Analytical results indicated all compounds detected were below the Department's IGWSCC.

On August 25-26, 1999, 85.7 tons of stockpiled contaminated soil was removed fiom the site. This soil was fiom excavations at AOCl and AOC2.

In a September 12,2000, Department correspondence, Monmouth County Park System (MCPS) was required to complete the following:

Provide Lot and Block information Submit chromatogram for sample PE-5 Determine depth to groundwater and percent (%) silt and clay between the contaminant and the saturated zone. If greater than 15% silt and clay or contamination is within 2 feet of groundwater, conduct a groundwater investigation. Complete a Baseline Ecological Evaluation. All requirements were due in 45 days

In a November 30,2000 Department correspondence, MCPS was issued a Deficiency letter due to the above requirements not being met.

Requirements Due to the groundwater investigation being conducted at the site, MCPS is not required to determine depth to groundwater and percent (%) silt and clay between the contaminant and the saturated zone. The Department's requirements for a Baseline Ecological Evaluation are addressed below.

MCPS shall complete the horizontal and vertical extent of contamination previously detected in soil boring SS-3 (TPH). Sampling shall begin at the location where contamination was previously detected and continue out in all directions, including vertically, until the complete horizontal and vertical extent of contamination to the applicable unrestricted use remediation standard is defined. Additional information on requirements for contaminant delineation may be found in N.J.A.C. 7:26E-4.1 (b).

It is the Department's position that the results of a saturated zone soil sample will be wholly attributed to the soil matrix, even though some portion of the contaminants are fiom the ground water portion of the sample. Contaminants in the unsaturated and saturated zones shall be vertically and horizontally delineated to the RDCSCC. Contaminated materials exceeding the RDCSCC can be (a) removed for ex-situ remediation or disposal, (b) remain in-place with the necessary institutional and/or engineering controls (except if acting as a ground water contaminant source), or remain in-place pending in-situ 9eatment (including natural remediation). Whichever treatment is proposed and approved, post-remedial soil sampling will be required at all soil sampling locations where the results exceeded the Department's RDCSCC.

Field screening may be utilized to bias sample locations to areas of greatest suspected contamination, but pursuant to N.J.A.C. 7:26E-2.l(b), may not be utilized to verify clean zones. The Department's most recent general guidance on soil contaminant cleanup criteria (May 12, 1999 version) may.also be utilized to evaluate when delineation is complete. If contamination is to be remediated during this phase of the investigation, MCPS shall conduct the appropriate post-remedial sampling to confirm the effectiveness of the remedial effort, pursuant to N.J.A.C. 7:26E-6.4.

MCPS shall submit an implementation schedule, for Department approval, within 60 days of the date of this letter. The implementation schedule shall be inclusive of the completion of all of the other outstanding requirements above.

B. Ground Water

On May 7,2001, one temporary well point was installed at AOC2. On May 9,2001, a groundwater sample was collected from the temporary well point. Depth to water was 15 fbg. Liquid phase hydrocarbon (LPH) was not present, however a LPH sheen was detected on groundwater. The sample was analyzed for volatile organic plus ten additional compounds W 1 0 ) and base neutral plus 15 additional compounds (B/N+15). Analytical results indicated the following compounds exceeded the Department's Ground Water Quality Standards (GWQS):

Benzene [5 1 parts per billion (ppb)] Methyl tertiary-butyl ether (MTE3E; 585 ppb) 2-methylnaphthalene (1,050 ppb; GWQS for individual TICs was applied = 100 ppb) phenanthrene (3 12 ppb GWQS for individual TICs was applied = 100 ppb) B/N tentatively identified compounds (TICs; 6,321 ppb)

The above referenced report proposed two monitoring wells to be installed on-site. One of the proposed monitoring wells was to be located at the temporary monitoring point location. Groundwater samples would be analyzed for VW10 and BIN+ 15.

Requirements Since a discharge occurred from the UST, a Ground Water Investigation shall be conducted in accordance with N.J.A.C. 7:26E-3.7 and/or 4.4. One ground water monitoring well shall be installed at the location of the UST or within ten feet downgradient of the UST. The Department approves installation of a permanent monitoring well at the temporary well point for this purpose. Ground water samples shall be collected pursuant to the "Field Sampling Procedures Manual" and analyzed for VOt- 10 and B/N+ 15.

Please note that in accordance with N.J.A.C. 7:26E-3.7(e)iv, groundwater flow direction shall be determined. Therefore, MCPS shall install a minimum of three monitoring wells to meet this requirement.

C. Receptor Evaluation Since ground water contamination was identified in excess of the GWQS, N.J.A.C. 7:9-6, MCPS shall perform the requirements found in N.J.A.C. 7:26E-4.4(h)3i through ix, as discussed below.

Well Search Requirements MCPS shall conduct a well search that identifies all irrigation, monitoring and domestic wells located within a one-half mile radius of the site (including any such wells located on-site) and all industrial, public supply wells and wells with water allocation permits located within a one mile radius of the site in accordance with N.J.A.C. 7:26E-3.7(e)3i through v within the time fiames specified therein..

MCPS shall accurately plot the results of the well search on a scaled map (scale shall be greater than or equal to 1:24,000) in relation to the facility. MCPS shall submit the map, a listing of all wells identified cross-referenced to the scaled map, and any specific information available on the wells to the Department. This information shall include: the type of well, the status of the well (active, inactive, properly abandoned pursuant to N.J.A.C. 7:9-9 et seq.), total depth, casing length, open bore hole or screened interval, copies of well records and or well logs on file with the Department's Bureau of Water Allocation, and any additional records available in county or municipal records. MCPS shall submit a listing of all sources referenced in performing the well search. If a referenced agency is &able to provide the information requested, written documentation that the source was contacted and that the request for information was either denied or that the information was unavailable shall be provided.

If MCPS fails to conduct the well search as required, the Department may initiate enforcement action including issuance of a Notice of Violation andlor monetary penalties as allowed by law.

Well Canvassing. Requirements As ground water contamination has been identified and ground water is used for potable, irrigation, commercial andlor industrial purposes in the vicinity of this site, MCPS is required to canvass the neighborhood to locate all nearby permitted and unpermitted wells. Canvassing shall be conducted within 14 days of the date of this letter, both within the estimated plume of contamination and within 1,000 feet of the known down gradient edge of contamination. MCPS shall plot the locations of all wells identified in the well search and canvassing on a reduction of a topographic or geoquadrangle map.

MCPS shall also sample the nearest down gradient well@) which are within 1,000 feet of the known down gradient edge of the potential path(s) of the contamination and analyze the samples for volatile organics using EPA Method 524.2 Version 4.1 with forward library search (include targeted analysis for TBA using EPA Method 524.2 Version 4.1 with the proper detector)

Samples should be collected as close to the pumping well as possible. The sampling location should also be prior to any storage tanks or treatment systems, if possible (i.e.: an outdoor spigot). If a sample must be collected following passage through a.treatment system, then the sample should be collected from a cold water, non-aerated spigot and the type, size and purpose of the treatment unit should be identified on sample sheets and in the field logbook.

A Well Information Form, included as an enclosure, shall be completed for each well sampled and the BSCM case manager shall be notified a minimum of 14 calendar days prior to the sampling event. Be sure to include the property owner and resident (if applicable) name and address for each well sampled, along with the Block and Lot for the property on which the well is located.

In addition, the following information shall be conveyed when the property ownerlresident is initially notified that the well will be sampled:

i. The well sampling is required by the Department;

, ii. The well sampling is associated with a specific underground storage tank case (provide complete name, address and case #);

iii. The Department will provide the sampling results to the property ownerlresident within 90 days of the sampling event; and

iv. If the well owner has any questions concerning the sampling of the well or the associated underground storage tank case, the assigned case manager should be contacted (include both the name and phone number of the case manager).

Sampling shall be conducted within thirty (30) calendar days of the date of this letter. The sampling results and a Well Information Form shall be submitted within forty-five (45) calendar days from the date on which sampling was conducted and shall be accompanied by the Quality AssurancelQuality Control deliverables prepared per the "Full Laboratory Data Deliverables" format. An electronic version of the of the sampling data shall also be submitted since the Technical Requirements for Site Remediation (N.J.A.C. 7:26E) require that all analytical results of environmental samples be submitted electronically [see 3.13(c)3v]. Failure to initiate sampling and/or provide the sampling results within the specified timeframes may result in the issuance of a notice of violation with penalty assessment. If contamination is found, the Department and the local health official shall be notified immediately.

Utilitv Evaluation Reauirements MCPS shall identify the possibility of interconnections between ground water and any subsurface utilities (e-g., storm sewers, sanitary sewers, water lines, etc.) located along on the site. MCPS shall determine the depth of the invert, the diameter of the conduit, and the construction specifications of utility. MCPS shall also determine whether any utilities may be acting as conduits for contaminant migration (i.e., either along the utility's backfill or within the utility itself). This determination shall include, but not be limited to, visual inspection and the use of field screening instruments. If applicable, surface water sampling may also be required pursuant to N.J.A.C. 7:26E-4.5. In addition, MCPS shall determine whether the utility is a barrier to contaminantlground water migration.

Surface Water Evaluation Requirement MCPS shall evaluate where @e closest surface water body is located and whether the of surface water body, has been or will be affected by the discharge. This may be accomplished by using a contaminant fate and transport ground water model. If contamination of the surface water body is suspected, MCPS may be required to conduct surface water and I or sediment sampling required pursuant to N.J.A.C. 7:26E-3.8 and 4.5. The Department will comment following a review of the p r e h m r y surface water evaluation.

Local Area Use Evaluation Recluirements MCPS shall provide a local area map indicating local area usage. This shall include all structures in the vicinity of the site, including if the structure has a basement. The results of the local area use evaluation shall be included on a scaled site map.

D. Ecological Evaluation

A baseline ecological evaluation shall be completed for each contaminated site or area of concern in accordance with N.J.kC. 7:26E-3.11. This baseline evaluation shall be qualitative in nature and based on site investigation sample results and a site inspection by a person experienced in the use of techniques and methodologies for conducting ecological risk assessment in accordance with EPA guidance. This evaluation shall be used to determine when further sampling and evaluation is required, pursuant to N.J.A.C. 7:26E-4.7.

11. Quality Assurance

A. AU data submitted shall conform to N.J.A.C. 7:26B2, except where specifically indicated.

B. In accordance with N.J.A.C. 7:26E-3.13(b) 3, a technical overview is required for any report submission. AS part of that overview, a discussion regarding the reliability of the laboratory analytical data shall be included.

In accordance with N.J.A.C. 7:26E-3.13(~)3~, a table summarizing all sampling results shall be provided with the report required herein. The table shall be organized by area of concern and shall include sample location, media, sample depth, field and laboratory identification numbers, analytical results, and comparison to applicable remediation standards. The data in the summary table shall be presented both as hard copy and an electronic deliverable using the database format outlined in detail in the current HAZSITE application or appropriate spreadsheet format specified in the Department's Electronic Data Interchange Handbook in effect as of the date the report is prepared. The Electronic Data Interchange Handbook and a copy of the current HAZSITE application software may be obtained fiom the Department by calling (609) 633-1476.

III. Administrative Requirements

A. Certification Requirements

Effective April 25, 1992, all persons and firms performing tank services on regulated USTs must be certified per N.J.S.A. 58: 10A-24.1-8. AU work related to any regulated tank service shall be conducted by, or under the immediate on site supervision of an individual certified in the activity being conducted. All documents (tank closure and permit applications, reports, proposals) submitted to the Department shall be prepared and signed by the certified individual responsible for the project.

In accordance with N.J.A.C. 7:14 B-1.7 (a) (Underground Storage of Hazardous Substances Rules) and implementing regulations all submissions to the Department require the appropriate certification and corporate resolution as specified therein. In addition, please be advised that the Department will not initiate case closure if MCPS has not complied with the aforementioned regulations.

B. Field Activity Notification

MCPS shall notify the assigned BSCM Case Manager at least 14 calendar days prior to implementation of field activities. If MCPS fails to initiate sampling within 30 calendar days of the receipt of this letter, any requests for an extension of the required time fiames may be denied.

C. Billing

Effective February 22, 1994, the Department initiated direct billing for the oversight of remedial investigations and remedial actions at regulated UST sites. Documents submitted in accordance with N.J.A.C. 7:26E may help reduce the time necessary for oversight of the above referenced site.

D. Remedial Action Selection

MCPS shall submit a Remedial Action Selection Report in accordance with N.J.A.C. 7:26E-5. This submission may be included as a part of the RAW. Please note that the Remedial Action Selection Report will satisfy the requirement

to submit an Effectiveness Analysis and Certification.

D. Notifications

Pursuant to N.J.A.C. 7:26E-1.4, MCPS shall notify the municipal clerk of each municipality in which the site is located forty-five calendar days prior to the submission of the remedial action selection report to the Department. The notification shall be in writing and shall include all information specified in N.J.A.C. 7:26E-1.4(d)1 through 10.

E. Reporting Requirements

MCPS shall submit the results of the sensitive receptor survey and BEE, sections C and D, respectively within 60 days of the date of this letter. Based on the findings of these investigations, MCPS shall submit an implementation schedule, for Department approval, for completion of the remaining requirements and the submittal of a RAW. The implementation schedule shall also be submitted within 60 days of the date of this letter.

It should be noted that if MCPS completes the above requirements, and the data indicate that the remedial investigation has not been completed (e.g.., contamination not completely delineated), MCPS shall submit a Remedial Investigation Workplan in accordance with N.J.A.C. 7:26E4.2 within the specified time frame. The RIW shall include a schedule of implementation of the remaining remedial investigation required and the submittal date of the RAW. MCPS also has the option of completing the remaining remedial investigation in accordance with N.J.A.C. 7326E-4, followed by the submission of the RIRiRAW. If the latter option is selected, MCPS shall notify the Case Manager listed below, in writing, within two weeks prior to the specified time fiame referenced above. This notification shall include a generic discussion of activities conducted to date and activities to be conducted, as well as a detailed schedule of implementation, which includes the submission of the R W M W .

Please note, pursuant to N.J.S.A. 58:lOA-21 et seq. and N.J.A.C. 7:14B et seq., the owner and operator of the regulated underground storage tanks are strictly liable for compliance with these requirements. In addition, all state regulated USTs, except for heating oil USTs for on-site consumption, are regulated under 40 CFR Part 280. Non-compliance with these federal and state regulations exposes the tank owner and operator to the penalty and liability specified in 40 CFR Part 280, N.J.S.A. 58: 1OA-21 a a. and N.J.A.C. 7: 14B a=.

Failure by MCPS to comply with the requirements of this letter and previous Department letters to remediate the discharge(s) may increase MCPS's potential liability to the Department in an amount equal to three times the cost of conducting the necessary remedial actions and may cause a lien to be placed upon the property of MCPS, pursuant to the Spill Compensation and Control Act N.J.S.A. 58:lO-23.11 et seq. (Spill Act). In addition, the Department reserves the right to pursue penalties for the discharge and for failure to submit the outstanding information, from the original due date, pursuant to the Spill Act.

If you require copies of Departmental Guidance Documents or applications, many of these'documents are available on the internet at WWW.STATE.NJ.US/DEP/SRP. If you should have any questions regarding this matter, please contact Diane Gard, Case Manager, of the Bureau of Southern Case Management at 609-292-0912.

Sincerely,

Lee Hendricks, S u p e ~ s o r Bureau of Southern Case Management

Enclosure: Well Information Form

\\dep-csshare\share\srpwIpsr\isee\bust\p2-jg\Ih\dmg\98-12-30-1622-03 holmdel park\98-12-30-1622-03 deficiency letter 2005-04.doc

6

Jon S. Corzine Covenlor

Department of Environmental Protection Lisa P. Jackson Commissioner

Bureau of Enforcement and investigations 401 East State Street

P.O. Box 028 Trenton, NJ 08625-0433 Phone # 609-633-1480 Fax # 609-633-1439

CERTIFIED MAIL1RR.R No. 7006 0810 0002 1819 1851

Monmouth County ~ o a r d of Recreation Commissioners 805 Newman Springs Road Lincroft, NJ 07738

NOTICE OF VIOLATION

Name of violator: Monmouth County Board of Recreation commissioners Location: 845 Holmdel Road, Holmdel, Monmouth County, New Jersey 07733 Identifying #: 022468

You are hereby notified that during a compliance review conducted on November 1, 2007, the Department identified the following violations of the New Jersey Spill Compensation and Control Act (N.J.S.A. 58:lO-23 et seq.1, the Water Pollution Control Act (N.J.S.A. 58:lOA-1 et seq.), the New Jersey Underground Storage of Hazardous Substances Act (N.J.S.A. 58: 10A-2 1 et seq) and the regulations promulgated thereunder.

Subiect: Failure to perform remedial investigation Requirement: Pursuant to N.J.A.C. 7:14B-8.2(a)l, the owner or operator of an underground storage tank system which has discharged hazardous substances shall perfom a remedial investigation in accordance with the requirements of N.J.A.C. 7:26E- 4. Description of Noncompliance: Failure to perform a remedial investigation in accordance with N.J.A.C. 7:26E-4.

Subiect: Failure to delineate soil contamination Requirement: Pursuant to N.J.A.C. 7:26E-4.l(b), the delineation of the horizontal and vertical limits of contamination to the applicable unrestricted use remediation standard for all media shall be conducted as part of the Remedial Investigation. Delineation shall be accomplished in accordance with N.J.A.C. 7:26E-4.1 (b) 1-3.

MONMOUTH CNTY BD OF RECREATION COMM PEA070001 - 022468 Page 2

Description of Noncompliance: Failure to delineate the horizontal and vertical limits of contamination to the applicable unrestricted use remediation standard for all media. Specifically, the delineation of contaminants in soils has not been completed as required in the Department's April 1,2005 and May 12,2006 correspondence. *

Subiect: Failure to delineate ground water contamination Requirement: Pursuant to N.J.A.C. 7:26E-4.4(h)3i, the results of initial ground water analyses shall be evaluated as follows: If ground water contamination above the applicable remediation standards has been confirmed, the person responsible for conducting the remediation shall perform the requirements in (h)3i through ix and shall delineate the vertical and horizontal extent of ground water contamination and the sources of ground water contamination, including, but not limited to, the extent of fiee

- andlor residual product as determined pursuant to N.J.A.C. 7:26E-2.l(a) 1 1. Description of Noncompliance: Failure to delineate the vertical and horizontal extent of ground water contamination and the sources of ground water contamination, including fi-ee and residual product, as required by the Department's letters dated April 1,2005, and May 12,2006. *

Subiect: Failure to perform a well search and well canvassing Requirement: Pursuant to N.J.A.C. 7:26E-4.4(h)3v, the results of initial ground water analyses shall be evaluated as follows: If ground water contamination above the applicable remediation standards has been confirmed, the person responsible for conducting the remediation shall perform an updated well search. Description of Noncompliance: Failure to perform a well search and well canvassing as required by the Department's letters of April 1,2005, and May 12,2006.

Subiect: Failure to conduct a baseline ecological evaluation Requirement: Pursuant to N.J.A.C. 7:26E-3.11(a), a baseline ecological evaluation shall be completed for each contaminated site or area of concern, except an area of concern that consists of an underground storage tank stoi-ing heating oil for on-site consumption in a one to fo-ur family residential building. Description of Noncompliance: Failure to conduct a baseline ecological evaluation according to general technical requirements and the Department's letters of April 1, 2005 and May 12,2006. *

Subiect: Failure to evaluate surface water that may be impacted Requirement: Pursuant to N.J.A.C. 7:26E-4.4(h)3vii, the results of initial ground water analyses shall be evaluated as follows: If ground water contamination above the applicable remediation standards has been confirmed, the person responsible for conducting the remediation shall evaluate any surface water body that may be impacted by the contaminated ground water pursuant to N.J.A.C. 7:26B-3.8 and 4.5. Description of Noncompliance: Failure to properly evaluate any surface water body potentially impacted by contaminated ground water as required by the Department's letters of April 1,2005 and May 12,2006.

MONMOUTH CNTY BD OF RECREATION COMM PEA070001 - 022468 Page 3

Subiect: Failure to evaluate subsurface utilities Requirement: Pursuant to N.J.A.C. 7:26E-4.4(h)3viii, the results of initial ground water analyses shall be evaluated as follows: If ground water contamination above the applicable remediation standards has been confirmed, tlie person responsible for conducting the remediation shall evaluate any subsurface utilities to determine whether any utilities may be acting as conduits for contamination migration. Description of Noncompliance: Failure to properly evaluate any subsurface utilities to determine whether any utilities may be acting as conduits for contaminant migration as required by the Department's letters of April 1,2005 and May 12,2006.

Subiect: Failure to provide local area map Requirement: Pursuant to N.J.A.C. 7:26E-4.8(d), the Remedial Investigation Report shall include legible maps and diagrams in accordance with N.J.A.C. 7:26E-4.8(d)l-5. Description of Noncompliance: Failure to provide a local area map indicating local area usage as required by the Department's letters of April 1,2005 and May 12,2006. *

The Department will not assess a penalty against you for the violations marked above with an asterisk (*) if you correct them by the deadlines below.

1. Conduct a well search and well canvass in accordance with N.J.A.C. 7:26E- 4.4(h)3v and submit the results to the Department.

2. Conduct a surface water evaluation in accordance with N.J.A.C. 7:26E-4.4(h)3vii and submit the results to the Department.

3. Conduct a subsurface utilities evaluation to determine whether utilities are acting as conduits for contaminant migration in accordance with N.J.A.C. 7:26E- 4.4(h)3viii and submit the results to the Department.

4. Conduct a Remedial Investigation within 90 days after receipt of this notice to fully delineate contaminants in soils and ground water in accordance with N.J.A.C. 7:26E-4.l(b) and N.J.A.C. 7:26E-4.4@)3i, respectively.

5. Conduct a Baseline Ecological Evaluation in accordance with N.J.A.C. 7:26E- 3.1 l(a), within 30 days after receipt of this notice.

6. Prepare a local area usage map in accordance with N.J.A.C. 7:26E-4.8(d) within 30 days after receipt of this notice.

7. Submit a Remedial Investigation Report (RIR) in accordance with N.J.A.C. 7:14B-8.3(a) which includes the results of Nos. 4 through 6 above within 120 days after receipt of this notice. The RIR shall be accompanied by a Remedial Investigation Workplan or Remedial Action Workplan pursuant to N.J.A.C. 7: 14B-8.3(c).

M O N ~ T H CNTY BD OF RECREATION COMM PEA070001 - 022468 Page 4

This Notice of Violation serves as notice that the Department, has determined that violations have occurred. It does not constitute final agency action and may not be appealed or contested. The issuance of this Notice or compliance therewith does not preclude the State of New Jersey or any of its agencies from initiating formal administrative andfor judicial enforcement action (including assessment of penalties), with respect to the violations listed above or for any other violations. You may appeal or contest such formal actions. The above violations are subject to penalties of up to $ 50,000.00 per day per offense.

If you have any questions regarding this matter please contact Sanjay Sinha, Compliance Manager, at (609) 633-3841 prior to the time frames indicated.

Date: ii /q 0 Bureau of Enforcement and Investigations

C: Sanjay Sinha, BE1 Diane Gad, BUST Municipal Clerk, Holmdel Township Monmouth County Health Dept.

JON S. C:OMINE Governor

h b of NQW dorwg DEPARTMENT OF E N V I R O P ~ W BRQ~CTION

Hurmu of Lindcrgtrund Storage 'Iknks 401 East Statc Srrecr P.0. Ros 433

l'rrmton. NJ 08625-0433 l'honc #: 609-292-8761 Pas #: 609-777-4285

LISA P. JACKSON Commissioner

James Mowczan, Senior Engineer - Civil Moillnouth County Board of Recreation Commissioners 805 Newman Springs Road Lincroft, NJ 07738

COMPLIANCE STATUS NOTICE

Re: Remedial Investigation Report Dated: June 20,2008 Holmdei Park Department of Public Works 845 Holmdel Road Holmdel, NJ' 07733 Case # 98-12-30-1 622-03 SRP PI# 022468; EA ID # PEA070001 SEC Rank: 5

Dcar Mr. Mowczan:

This notice is to advise you regarding the compliance status of violations previously identified in a Notice of Violation.

The following violations have been corrected to the Department's satisfaction and compliance has been achieved:

Failure to perfonn a well search and well canvassing (Compliance Achieved) Failure to r.o~~duct a b~sclinc: ccc!ngical eval~~ntion (Ccn.:p!imce Achieved) Failure to evaluate subsurface utilities (Compliance Achieved) Failure to provide local area map (Compliance Achieved)

The following violations have not been corrected to the Department's satisfaction

Failure to delineate the horizontal and vertical limits of the contaminants in soils as required in the Department's April 1,2005 and May 12,2006 correspondence.

FaiIure to deiineate the vertical and horizontal extent of ground water contamination and the sources of ground water contamination, including free and residual product, as required by the Department's letters dated April I , 2005, and May 12,2006.

Failure to properly evaluate any surface water body potentially impacted by contaminated ground water as required by the Department's letters of April 1,2005 and May 12,2006.

Page 1 IVW Jersey 1s An Epal Oppmrniiy Ernplqicrr d f i l e d or! Rec,vcied Paper mld Recyciabfc

This notice does not constitute an approval. It is intended to acknowledge that compliance has been achieved for some but not all violations previously identified. Note that violations that are not corrected will be subject to penalty assessment.

If you have any questions, please contact Diane Gard at (609) 292-0912.

Sincerely,

Donald Cramer, Acting Section Chief

c: Diane Gard, BUST Sanjay Sinha, BE1 C. Dudley Warner Kt, French & Piuello Associates, P.A. Michael Meddis, Monmouth County Health Dept. Municipal Clerk Sidney Johnson, Jr., Mo~mouth Cty Reg Health Commission No. 1