CERCLA and Superfund

CERCLA AND SUPERFUND

CERCLA and Superfund: The Cinnaminson Groundwater Contamination Gregory Bolaos The Richard Stockton College of New Jersey

CERCLA and Superfund

Abstract Since its inception in 1980, CERCLA or superfund has been the EPAs program for dealing with the most dangerous toxic waste sites across the United States. One such site is the Cinnaminson Groundwater Contamination, which has been a superfund site since its discovery in 1984 and is still undergoing the remediation process. This site provides a typical example of how the EPA addresses superfund sites. Responsible parties were identified and managed to cooperate with the EPA in funding and designing the remedial action. Despite the changes made to superfund throughout the years, the program still manages to maintain progress towards its goal. However, it is a slow process that takes years to accomplish, any future reforms may have to look into improving efficiency.

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In 1978, the Love Canal tragedy brought national attention to a serious environmental issue. An entire neighborhood consisting of about 800 single-family homes, 240 apartments, and a school, found itself exposed to toxic chemicals that were buried underground since 1953. (Gibbs, 2002) These chemicals came from a toxic waste dump that the neighborhood was built over; the inhabitants were never given any warning that the chemical waste dump was there. (Gibbs, 2002) Those that did know of the chemicals did not believe the toxins would be able to invade their homes. (Beck, 1979) The waste dump was originally a project by a man named William T. Love, which is where the name Love Canal comes from. In 1892, Love intended to have a canal built between the upper and lower Niagara River to generate cheap power to fuel industry and homes of a future city that he dreamed of building. By 1910, the project was abandoned due to the economic depression; only a section of the canal was dug. The property was sold in 1920 to the Hooker Chemical Corporation who turned the site into a municipal and industrial waste dump. (Gibbs, 2002) Years later, in 1953, the canal and all the chemicals were buried and the land was sold to the city for one dollar. (Beck, 1979) As a part of the deal, Hooker was absolved of any liability concerning the buried wastes. (Gibbs, 2002) For years, through the late 1950s and 1970s, the city had been getting complaints of odors and strange substances in peoples yards and playgrounds. (Gibbs, 2002) After years of complaints, the city hired a consultant to investigate; the results found toxic residues in the air and sump pumps of homes, chemical drums close to the surface, and high levels of PCBs in the storm sewer systems. (Gibbs, 2002) In March 1978, the New York State Department of Health began testing the air and soil in basements, and conducted a health study of the families living near the canal. They found high levels of contaminants in the soil and air, and an increased rate

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in reproductive problems in women. (Gibbs, 2002) There was a high rate of miscarriages and birth defects as well as signs of leukemia. (Beck, 1979) The results of these studies and outrage from the community led to a call from the state government to close down the 99th street School and evacuate the affected area. The President of the United States declared a state-of-emergency, and approved funds to be used to help relocate the affected families. (Gibbs, 2002) It was the first time that federal emergency funds were approved for something other than a natural disaster, (Beck, 1979) and revealed the need for federal funds in dealing with future environmental disasters. As bad as the Love Canal Tragedy was, it was only one of many toxic waste dumps across the entire country that could potentially cause an equal or greater threat. To ensure that the federal government would have the necessary funds to provide proper remedial treatment to other potentially hazardous sites, congress signed the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) in 1980. The purpose of CERCLA was to establish a federal trust fund to clean up the most toxic areas of the United States when no responsible party can be identified. (EPA, 2012) The money for this Superfund came from a $1.6 billion petrochemical tax. CERCLA was not only developed to provide funds for cleanup practices, but to also enforce liability towards responsible parties. (EPA, 2012) This is important as ownership of hazardous waste sites tends to shift over time; this makes it difficult to determine who is liable when an accident occurs. (Beck 1979) Superfund allows the EPA to compel responsible parties to perform cleanup or to reimburse the government for EPA-led cleanups. (EPA, 2012)

CERCLA and Superfund

In 1986, CERCLA was amended by the Superfund Amendments and Restoration Act (SARA), reflecting the EPAs experience in administering the Superfund program and made several important changes and additions. (EPA, 2012) It stressed the importance of using innovative technologies in cleaning up superfund sites. SARA also increased state involvement in every phase of the Superfund Program and encouraged community involvement in making decisions on how sites should be cleaned up. (EPA, 2012) Most importantly, the Act also injected more money into the trust fund, increasing it to $8.5 billion. (EPA, 2012) In the mid-1990s, a series of reforms were passed for Superfund. These reforms were passed in a series of 3 rounds. The first round expanded public involvement and aimed to improve the cost, pace, and fairness of the program. (EPA, 2012) In February 1995 the second round of reforms was passed, these reforms strengthened and improved the program through initiatives in enforcement, economic redevelopment, public involvement and environmental justice, innovative technology, and State and Tribal empowerment. (EPA, 2012) The last round of reforms were passed in October 1995, some of the reforms focused on promoting clean up decisions that were both cost-effective and safe for human health and the environment; others were to reduce litigation and transaction costs, and keep States and communities informed and involved in clean up decisions. (EPA, 2012) One major change occurred at the end of 1995, the tax authorization for Superfund was allowed to expire without renewal. Money going into superfund at this point came from fines, penalties, and interest on the funds investments. (Superfund reform, 1998) Recently, with the passing of the American Recovery and Reinvestment Act (ARRA) superfund was given an additional $600 million in stimulus funds to help accelerate cleanup activities or start new construction projects. (EPA, 2012)

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Sites that are designated as a threat to public health and require money from superfund are placed on the National Priority List (NPL). This list is viewable on the EPAs website and contains every superfund site in the United States. One such site is located in Cinnaminson Township, New Jersey referred to as simply the Cinnaminson Groundwater Contamination or CGC. The site covers about 400 acres within the townships of Cinnaminson and Delran in Burlington County; it consists of a landfill, residential, and both light and heavy industrial properties. (EPA, 2011) Some of the industrial properties have underground petroleum storage tanks and one has an unlined slurry pit and cooling ponds. (ATSDR, 2000) The landfill portions of the site were originally mining pits for sand and gravel. Starting from the late 1950s the completed parts of the mining pits were used to store municipal solid waste. Large portions of waste, including municipal, food, and industrial waste, continued to be added to the landfill even after the mining operations were shut down in the 1960s. (EPA, 2011) In the 1970s the site was owned by Sanitary Landfills Inc. (SLI); their landfill accepted industrial and hazardous waste materials. Throughout the 1970s the New Jersey Department of Environmental Protection (NJDEP) cited SLI several times for violating landfill regulations. (ATSDR, 2000) In 1979, an analysis of the on-site groundwater discovered that there was contamination from the landfill. As a result of this discovery, the NJDEP ruled that the landfill was to be shut down and all operations would cease. As part of the closure plan, SLI had the landfill covered with an 18 inch clay cap, installed a gas collection and venting system, and started a groundwater monitoring program. (ATSDR, 2000) Continuing groundwater studies conducted by the EPA and SLI discovered on-site groundwater contamination in the landfill area. (EPA, 2011)

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The preliminary assessment was completed on April 4, 1985. (EPA, 2011) Several sources of contamination were discovered; the SLI landfill was the major source but there were also potential sources from nearby industries. Del Val Ink and Color and L & L RediMix are two nearby companies with underground petroleum storage tanks, and the Hoeganaes Corporation, a steel plant, used unlined slurry pits which could also be a source of contamination. (EPA, 1990) Chemicals from the SLI landfill were found to have made their way into the underlying aquifer. Among the various chemicals found were heavy metals, including arsenic, cyanide, chromium, and manganese. The main chemicals of concern were volatile organic chemicals (VOCs) including chloroform, benzene, tetrachloroethylene, vinyl chloride and much more. (EPA, 2010) The aquifer supplies drinking water to about 52,000 people that live in close proximity to the site. (EPA, 2011) These chemicals are known carcinogens and would be a serious health risk if ingested. Risk of exposure to the chemicals from the landfill can come from ingesting contaminated drinking water from the perched water zones and the regional aquifer. None of the wells in the perched water zone are used for drinking water, however if the chemicals are allowed to flow into the regional aquifer there is a risk of ingestion. (EPA, 1990) The second potential risk of exposure is the inhalation of VOCs from the landfill. VOCs can vaporize from the contaminated groundwater and end up intruding into buildings. However, the risk/health assessment determined that no adverse health effects could occur on or around the site. (EPA, 1990) Potential impacts on the environment were also assessed. There are no endangered species or critical habitats nearby therefore, it was determined that the pollutants are only a human health risk. (EPA, 1990)

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After the preliminary assessment was completed, the CGC site was moved from the proposed NPL to the final NPL on June 10, 1986. There are three methods used to get polluted sites placed on the NPL. One way is that States and territories are allowed to designate a single top-priority site regardless of how the EPA grades it. Another way for sites to get on the NPL is for it to meet three requirements; first, the Agency for Toxic Substances and Disease Registry (ATSDR) of the U.S. Public Health Service must issue a health advisory that recommends removing people from the site. Then, the EPA determines that the site is a significant threat to public health. Finally, the EPA must decide if using its remedial authority for NPL sites is more cost-effective than its emergency removal authority. The usual method for placing sites on the NPL is through the EPAs Hazard Ranking System (HRS). (EPA, 2012) The HRS is a numerical scoring system that uses information from the preliminary assessment and site investigation to determine the level of risk towards human health and environmental damage. To analyze a potential site, numerical values are assigned to three categories of factors. There is the likelihood that a site has released or has the potential to release hazardous chemicals into the environment, the characteristics of the waste such as quantity or toxicity, and the amount of people that could be affected. Pathways of contamination are also scored under the HRS, which include groundwater migration, surface water migration, soil exposure, and air migration. Scores are calculated for each of these pathways, the score can be high even if only one of the pathways has an extremely high score. This is important because even the most dangerous sites can have only one pathway. (EPA, 2012) The CGC site scored sufficiently high enough on the HRS due to the impact it had on groundwater, and the variety of land use in the area. (Katz, Ira-Perry, personal communication, November 23, 2012)

CERCLA and Superfund

The site was originally proposed to be placed on the NPL in 1984; the preliminary assessment was finished on April 3, 1985. After this assessment, the site required an aerial survey which was completed on April 1, 1986; it wasnt until June 10, 1986 that the site was listed on the NPL. In order to reduce human exposure to chemicals at the site, institutional and engineering controls were put in place. (EPA, 1990) After the landfill was ordered to be shutdown, a clay cap was built on top of the landfill area to minimize the amount of chemicals from leaching into the groundwater supply as a result of rainfall. A gas collection and venting system was installed to prevent the buildup of noxious gasses underground. The groundwater was closely monitored to observe the movements of pollutants. To keep people from entering the area, a fence was installed to keep people out of the landfill area. The other portions of the site are on private property and already had fences up. Signs are posted on the fence telling people to keep out of the area and notifying them of the superfund investigations and cleanup going on in the area. (EPA, 1990) Despite the presence of these engineering and institutional controls, they seem to have not made any impact on economic activities in the area. The fenced out portion of the site is only in the landfill area, and any nearby businesses are still active to this day. It would only take a single drive down to the site to see that not only are businesses still active, but residential houses are still being lived in; there is even a small farm and market across the street. It would seem that despite the potential for toxic exposure, there was no need to move people away from the site. Either the contaminants are not a big enough threat to the nearby population or the remedial activity has them under control.

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After superfund sites are listed on the NPL, the next step is to perform a remedial investigation (RI) and a feasibility study (FS). The purpose of the RI is to collect data to characterize site conditions, determine the nature of the waste, assess the risk to human health and the environment, and finally to conduct treatability testing to evaluate the performance and cost of treatment technologies. The FS is how alternative remedial actions are developed, screened, and evaluated. (EPA, 2012) For the CGC site, the RI involved the installation of monitoring wells and groundwater sampling in order to characterize the site. (ATSDR, 2000) The EPA installed 12 wells to investigate the groundwater conditions on the property of the Hoeganaes Corporation. SLI installed 26 wells on the landfill site to monitor leachate. As a part of the RI, the EPA added an additional 49 monitoring wells in the study area, giving a total of 87 monitoring wells to help characterize the site. (EPA, 1990) The completion of the RI in 1989 discovered that the hydrogeology of the site is complicated by layers of clay. These clay lenses divide the underlying aquifer into two sections, a shallow aquifer and a deep aquifer. Both of these were found to be contaminated. (ATSDR, 2000) The shallow aquifer, (also referred to as perched water zones) flows into the deep (regional) aquifer, which then flows in a south-southeasterly direction. (EPA, 1990) The FS was completed in 1990. Any remedial actions taken were to achieve several objectives; to satisfy local, state, and federal requirements, to reduce continued degradation of the groundwater, and to prevent contaminants from migrating into municipal drinking water wells. (EPA, 1990) Two types of actions were determined to address the groundwater issue, source control methods to prevent the further leaching from the landfill, and groundwater management to address the contamination already present within the groundwater. (EPA, 1990)

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As a part of the FS, potential remedial technologies are reviewed for effectiveness, implementation, and cost. In determining source control, several alternatives were taken into consideration. The alternatives include, taking no further action, installing monitoring and administrative controls, or installing a full RCRA (Resource Conservation and Recovery Act) cap. As stated before, SLI installed an 18 inch clay cap in 1985 after the landfill was shut down. At the time of the FS, the cap was found to be effective in preventing rainwater from entering the landfill, reducing the migration rate of the contaminants. It was decided that with continued maintenance and monitoring the long term effectiveness of the cap, no final decisions will be made until the migration management system is completed. (EPA, 1990) In developing the management of groundwater, five alternatives, (referred to as MM1-5) were developed along with several different options for treating the groundwater. MM-1, no further action, would only involve SLI following the requirements listed in the landfill closure plan. Which includes groundwater monitoring, maintenance of the fencing and cap, controlling access to the site as well as a review of the site conditions every five years; this would cost $15,000 in operation and maintenance. Alternative MM-2 involves implementing administrative and monitoring controls to reduce the chance of exposure. This would include the requirements in the landfill closure plan, implementing a long term monitoring program, and controlling access to the site. State and local governments would also need to place health warnings on any new well installation permits. This alternative would cost $369,000 and $84,000 in operation and maintenance. (EPA, 1990) The other three alternatives involve treatment of the contaminated ground water. MM-3 includes the aspects of MM-2 as well as a groundwater extraction and treatment system for the shallow aquifer. Extraction wells would remove contaminated groundwater, be treated to meet

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drinking water standards, and injected into the regional aquifer. The injection wells would be placed downgradient of the plume to create a hydraulic barrier between the contaminated and treated groundwater; preventing further migration of the contaminants. This process was estimated to require 5 years of treatment. (EPA, 1990) Alternative MM-4 is similar to the previous one except this alternative focuses on removing contaminants from the deep, regional aquifer. Treatment of the regional aquifer was estimated to take at least 30 years. The final alternative MM-5 involves treating the groundwater from both the shallow aquifer and the regional aquifer, which would also require 30 years of treatment. (EPA, 1990) The cost of remediation activity depends on type of treatment method; there were three options available for treating groundwater. Option A would have the water pumped into a treatment plant, chemical precipitation would remove any inorganic pollutants, and air stripping would remove VOCs. For option B, the water is treated on-site, after chemical precipitation the groundwater would be mixed with an oxidant and then exposed to UV light. This causes the organic components to oxidize into carbon dioxide, water, and non-hazardous salts. The option C method involves the volatile organics being removed through a biological activated carbon treatment after chemical precipitation. (EPA, 1990) Of the three options, A is the least expensive treatment method, while option C is the most expensive. Out of the 5 alternatives MM-5 was selected, and of the three treatment options, option C was selected. The estimated cost for the implementation of MM-5 with option C was $20,500,000 with an annual cost of $751,000 for operation and maintenance for a period of 30 years. Option C was determined to be the most cost effective because it provides the highest overall effectiveness proportional to its cost. The selected remedy was accepted by both the state of New Jersey and the general public. (EPA, 1990)

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When addressing contamination at a superfund site, different sections are addressed; these are referred to as OUs (operable units). The CGC has four operable units, OU1 is the groundwater remediation as it relates to the landfill, OU2 is the landfill cap, OU3 refers to the industrial area, and OU4 is the larger groundwater investigation that makes up the 400 acre site. (Katz, Ira-Perry, personal communication, November 23, 2012) The sites record of decision (ROD) is based only on OU1, the other OUs are either still in the investigation phase, or have not required any immediate action. An ROD outlines the decisions made during the remediation process, and is written after the RI and FS are complete. The ROD for the CGC site begins with the results of the RI and how it was performed. It states where contaminants were found, which portion of the site was tested, and how they were tested. Testing was performed through monitoring wells to test groundwater, surface water and sediment samples were taken, and potable wells were tested for contaminants. In the results, it states that the contaminants are found primarily in the groundwater making it the area of greatest concern. (EPA, 1990) The next section of the ROD summarizes the potential risks to human health as a result of exposure to the contaminants. It goes over what approach to risk assessment is used for noncarcinogenic and carcinogenic risk; hazard index for the former and cancer potency factors for the latter. It was concluded that if the contamination is not addressed, they could pose a danger to public health. After this section, the ROD goes over the different alternatives, stating what each one does and how much it will cost. Next is a summary of the comparative analysis of each alternative, detailing which would be the most effective in proportion to its cost. After this, the ROD overviews the selected remedy and which goals the EPA has in mind for the site. With the

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selected remedy, the EPA seeks to return the contaminated aquifer to a safe source of potable water. (EPA, 1990) Statutory Determinations is a short section of the ROD that states how the remedial action will comply with applicable or relevant and appropriate requirements (ARARs) and any other federal and state regulations. The last section, the Response Summary Overview has several sub-sections; each contains questions and comments expressed by the public during the public comment period and the EPAs written responses. Residents and local officials had several major concerns; there was limited availability of public information regarding the EPAs activities and requested they be kept informed, they wanted to know if the water they were currently using was safe, they requested more information regarding the SLI landfill closure plan, and if the superfund re-authorization of 1986 would delay funding. The EPA assured that the public water supply is still safe and that funding should not be slowed especially if the potentially responsible parties decide to fund the clean-up, and that further information could be found at established information repositories such as the Cinnaminson Public Library and Municipal Building. (EPA, 1990) SLI and the other potentially responsible parties were obligated to take responsibility in managing and funding the remedial design and remedial action. Field work for the remedial design was initiated in June 1993. (EPA, 2010) It was also required of SLI to conduct groundwater monitoring and hydrogeological investigations; SLI started their monitoring program in February 1994. (ATSDR, 2000) The design for the remediation system was completed in 1996, but SLI decided that modifications were required to increase efficiency. The final design was completed in January 1999; construction was completed one year later. (EPA, 2010)

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The plant began operation in April 2000 and will continue to remove contaminants for about 30 years. (EPA, 2010) After the process is finished, the site could potentially be open to development, though some restrictions could be placed on the site. Because this is a groundwater contamination, there could be a restriction preventing private wells from being built. (Katz, Ira-Perry, personal communication, November 23, 2012) The landfill area covers a large section of property, if this area were open to development any interested businesses could use it. Being unable to build private wells could be an obstacle, but if they use public water it may not be a problem. Based on how the CGC site was handled, it would seem that CERCLA is most certainly a functional system that is effective in handling toxic waste clean-ups. There were no major problems or issues in the remediation or investigation processes. The public seemed to support the EPAs actions and remediation decision; potentially responsible parties were cooperative in working with the EPA, despite some comments made that questioned the results of the RI and FS. (EPA, 1990) Without a program like superfund, it is likely that the contaminants may not have been addressed and could have made their way into the public water supply. Looking at the ROD and the timeline of activities the whole process seems cut-and-dry and by-the-numbers. Any person looking to use this site as an example of CERCLA being ineffective would not find much to work with. However, one problem that can be taken from the EPAs handling of the CGC site is that the entire process simply takes too long. The first stage of the Superfund Cleanup Process for this site started in 1984, and contaminants werent removed from the ground until almost 20 years later. Now this seems mostly due to the five years it took to perform the RI and FS, which was an EPA funded assignment and because it took the potentially responsible party eight years to finish the remedial design. (EPA, 2012) Either way, there is little evidence

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related to the CGC site that reveals CERCLA as ineffective, after all it managed to accomplish what it set out to do.

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Works Cited: (1998). Superfund reform. Congressional Digest, 77(3), 68. Retrieved from http://search.ebscohost.com/login.aspx?direct=true&db=pwh&AN=373320&site=povlive Agency for Toxic Substances and Disease Registry. (2000, December 26). Public health assessment: Cinnaminson ground water contamination. Retrieved from http://www.atsdr.cdc.gov/hac/pha/pha.asp?docid=391&pg=0 Beck, E. C. (1979). The Love Canal Tragedy. Environmental Protection Agency, EPA Journal. Retrieved from http://www.epa.gov/history/topics/lovecanal/01.html EPA. Environmental Protection Agency, (1990). Record of decision: Cinnaminson groundwater contamination (NJD980785638). Retrieved from website: http://www.epa.gov/superfund/sites/rods/fulltext/r0290127.pdf EPA. Environmental Protection Agency, (2010). National priority site fact sheet: Cinnaminson groundwater contamination (NJD980785638). Retrieved from website: http://www.epa.gov/Region2/superfund/npl/0200995c.pdf Environmental Protection Agency. (2011, April 14). Cinnaminson groundwater contamination. Retrieved from http://www.epa.gov/region2/superfund/npl/cinnaminson/ Environmental Protection Agency. (2012, May 14). Retrieved from http://www.epa.gov/region02/superfund/ Gibbs, L. M. (2002). Love canal: the start of a movement. Retrieved from http://www.bu.edu/lovecanal/canal/index.html

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Appendix:

Section I: Interview with Remedial Project Manager

Section II: Maps and Photographs of CGC site

Section III: Articles from the Press

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The Cinnaminson Groundwater Contamination site only had one site contact, Remedial Project Manager, Ira-Perry Katz, listed on the EPAs superfund website. When I contacted him through phone call, he suggested I send him questions via e-mail. Below, are listed the questions he was able to answer: How did the site end up on the NPL? Which of the three mechanisms was used to place it on the NPL? The site was initially identified based on environmental contamination from the Sanitary LF, Inc. It became known as an "area-wide" groundwater contamination site based on impacts to the surrounding area. It was placed on the NPL because it scored sufficiently high enough using EPA's Hazard Ranking System due to its impacts on groundwater. Because the site is an "areawide" groundwater contamination site, it encompasses a large area (400-acres in this case) and includes a variety of land uses (residential, commercial, industrial). What led to the initial investigation? Who did the investigation and how were the pollutants discovered to begin with? These detail pre-date me, but you should be able to find this info in the ROD or other publically available documents on EPA's website for Cinnaminson Groundwater Contamination Site. Why did it require money from superfund? Funding for the environmental investigation and clean-up activities are from private parties considered liable under Superfund law. Monies expended by EPA are recovered from those private parties considered liable under Superfund.

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How did the local community and businesses respond to the news? Were there any major concerns, outrage, involvement, or lawsuits? I was not involved in the project during the early days of this. However, the ROD usually has a section toward the end of it that is a "Responsiveness Summary" which incorporates public comment on the ROD. That may give you some insight into public sentiment at the time. Was a responsible party identified? Yes, there are several and they are implementing environmental investigation and clean-up activities in furtherance of remediation of the site. In the ROD, it was mentioned that there were several remediation alternatives, of these why was MM-5 and Option C chosen over the others? Again, the development of the ROD pre-dates me. However, in the ROD there is always a section which compares the alternatives and presents the pros and cons as well as evaluates the alternatives against EPA's 9 evaluation criteria (protectiveness, reduction of toxicity, mobility and volume of contaminants, compliance with requirements, short-term effectiveness, cost, etc.) In the fact sheet, it was stated that the clay cap and the nearby industrial area were listed as operational units (OU), were there any investigations made? Did they find anything? There are four operable units (OUs). An OU is an EPA term of art that designates a discrete phase of work. At Cinnaminson, OU1 is the groundwater remediation related to the landfill; OU2 is the landfill cap that was placed on the landfill that was one of sources of groundwater contamination; OU3 is the work (currently in the environmental investigation phase) at an

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industrial property that is considered part of the site and OU4 is a larger groundwater investigation that encompasses the 400-acres that makes up the site. Were there any major problems or issues that occurred during remediation? I am not aware of any major problems or issues....again, this pre-dates me. At what point will the site be considered safe? What will happen to the site after remediation is completed? EPA does not consider the "site" an "imminent and substantial endangerment", which is EPA's threshold for taking "emergency" actions. So, there is no immediate threat to public health. We remediate sites that would require an emergency action because of the imminent and substantial endangerment. However, although contaminated sites do not always present an immediate threat to public health or the environment, there can be a potential current or future risk. For example, at this site; impacted groundwater has the potential to impact a public water supply well field so, we determine a remedial action(s) to mitigate a risk to that public water supply. Site that are remediated generally become available for use consistent with local land use regulations. However, in some instances; restrictions can be put on that may limit its use. For example, when remediation of contaminated groundwater takes years (e.g. 30 or more years in some cases), there may be a restriction on putting a private well on the property although that does not necessarily preclude development of the property. Finally, is there any other information you can send to me? Maps, documents, etc? You should be able to download what you need from EPA's website.

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Section II: Maps and Photographs of the Site

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Section III: Articles from the Press

Pompper, Donnalyn. (1986, April 15). EPA PLANS TO INVESTIGATE TOXINS AT CINNAMINSON SITE. Philadelphia Inquirer. Retrieved from http://articles.philly.com/1986-04-15/news/26078992_1_contamination-source-andextent-superfund

Denise-Marie Balona. (1998, ). E. RIVERTON GETS WATER WARNINGS OFFICIALS TOLD RESIDENTS NOT TO DRINK WELL WATER. A SURVEY STARTS TODAY TO HELP DETERMINE ITS SAFETY. Philadelphia Inquirer, pp. B.9.

Rob Laymon. (1998, ). A TOXIC TOWNSHIP? CINNAMINSON RESIDENTS: CANCER CLUSTER PLAGUES US. Philadelphia Daily News, pp. 15.

Carrie Budoff. (1999, ). E. RIVERTON WANTS ANSWERS ABOUT CANCER RATE THE CINNAMINSON NEIGHBORHOOD MAY GET SOME FROM A SURVEY BEING CONDUCTED. SOME FEAR THE NUMBERS ARE ABORMALLY HIGH. Philadelphia Inquirer, pp. B.1.

Carrie Budoff. (1999, ). E. RIVERTON STUDY FINDS NORMAL CANCER RATES. Philadelphia Inquirer, pp. B.4.

Carrie Budoff. (1999, ). LOCALITY COMPLETES SURVEYS ON CANCER THE EFFORT TOOK MONTHS. THE STATE WILL STUDY WHETHER E. RIVERTON HAS AN ABNORMALLY HIGH RATE. Philadelphia Inquirer, pp. B.2.