OFFICE OF INSPECTOR GENERAL 

Catalyst for Improving the Environment 

Public Liaison Report 

Environmental Justice Concerns 

and Communication Problems 

Complicated Cleaning Up 

Ringwood Mines/Landfill Site 

 Report 2007-P-00016 

 April 2, 2007 
Report Contributors: Paul McKechnie 

Dan Cox 

 Tom Reilly 

 Christine Baughman 

Abbreviations 

Borough Borough of Ringwood, New Jersey 

CIC Community Involvement Coordinator 

CRP Community Relations Plan 

EPA U.S. Environmental Protection Agency 

Ford Ford Motor Company 

NJDEP New Jersey Department of Environmental Protection 

NPL Superfund National Priorities List 

OIG Office of Inspector General 

PRP Potentially Responsible Party 

RPM Remedial Project Manager 

Cover photo: Warning signs at one of the sludge removal areas at the site 

(taken by OIG staff in August 2006). 
U.S. Environmental Protection Agency 2007-P-00016

Office of Inspector General April 2, 2007

At a Glance


Catalyst for Improving the Environment 

Why We Did This Review 

Three members of the 

New Jersey congressional 

delegation requested that the

Office of Inspector General 

“conduct an investigation into 

the history and continued 

inadequate characterization 

and remediation of the 

Ringwood Mines/Landfill 

Superfund site.” This report 

addresses whether environmental injustice exists and if 

EPA employed effective 

community relations. Environmental justice is fair treatment and meaningful involvement of all people in implementing environmental laws. 

Background 

About 500 acres around the 

Ringwood mines became a 

Superfund site in 1983 

because of dumped hazardous 

paint sludge. Paint sludge was 

removed several times, and 

the water was being 

monitored, so EPA deleted it 

from the list of such sites in 

1994. Cleanup activities at the 

site resumed after residents 

reported finding more paint 

sludge in 2004. 

For further information, 

contact our Office of 

Congressional and Public 

Liaison at (202) 566-2391. 

To view the full report, 

click on the following link: 

www.epa.gov/oig/reports/2007/ 

20070402-2007-P-00016.pdf 

Environmental Justice Concerns and 

Communication Problems Complicated 

Cleaning Up Ringwood Mines/Landfill Site

 What We Found 

We did not find evidence to indicate that the U.S. Environmental Protection 

Agency’s (EPA’s) actions or decisionmaking to investigate or remediate 

environmental conditions at the Ringwood Mines/Landfill site were affected by 

the area’s racial, cultural, or socioeconomic status. However, residents living near 

the site continue to believe they were unfairly treated because of their racial 

makeup and socioeconomic status. Several residents believe their health was 

adversely affected by exposure to site contamination. Ringwood residents said 

that multiple cleanups at the site beginning in 1987, and a lack of effective 

communication with EPA Region 2, contributed to this perception. Additionally, 

residents believe that EPA is pursuing the current activity because of outside 

pressures. Region 2 plans to address environmental justice concerns by cleaning 

up the site. 

Problems with communications and relationships impeded effective cooperation 

between EPA and residents. Although Region 2 has increased its community 

relations efforts at the site, the new community relations plan being prepared must 

address these impediments.

 What We Recommend 

We recommend that the Regional Administrator, Region 2: 

• Address the Ringwood community’s perception of unfair treatment and 

concerns regarding completely cleaning up the site by ensuring that the new 

Record of Decision includes a detailed comparison of current and prior site 

investigations and cleanups. 

• Prepare and implement a new community involvement plan for the Ringwood 

site. 

• Help the community correct the deficiencies in the Community Advisory 

Group so its meetings are regularly held and productive. 

• Increase communication with the community about Region 2 efforts to ensure 

that the Ford Motor Company properly performs the correct work at the site. 

Region 2 concurred with our recommendations. 
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF 

INSPECTOR GENERAL 

April 2, 2007 

MEMORANDUM 

SUBJECT: Environmental Justice Concerns and Communication Problems 

Complicated Cleaning Up Ringwood Mines/Landfill Site 

 Report No. 2007-P-00016 

FROM: Eileen McMahon 

TO: Alan J. Steinberg 

 Regional Administrator 

 Region 2 

This is our final report on the subject review conducted by the Office of Inspector General (OIG) 

of the U.S. Environmental Protection Agency (EPA). Congressman Frank Pallone, and Senators 

Frank Lautenberg and Robert Menendez of New Jersey requested in March 2006 that we conduct 

the review. This report contains findings that describe the problems the OIG has identified and 

corrective actions the OIG recommends. This report represents the opinion of the OIG and the 

findings contained in this report do not necessarily represent the final EPA position. Final 

determinations on matters in this report will be made by EPA managers in accordance with 

established resolution procedures. 

The findings in this report are not binding in any enforcement proceeding brought by EPA or the 

Department of Justice under the Comprehensive Environmental Response, Compensation, and 

Liability Act to recover costs incurred not inconsistent with the National Contingency Plan. 

The estimated cost of this report – calculated by multiplying the project’s staff days by the 

applicable daily full cost billing rates in effect at the time – is $254,713. 

Action Required 

In accordance with EPA Manual 2750, you are required to provide this office with a 

written response within 90 days of the date of this report. You should include a 

corrective action plan for agreed-upon actions, including milestone dates. We have no 

 Assistant Inspector General for Congressional and Public Liaison 
objections to the further release of this report to the public. This report will be available 

at http://www.epa.gov/oig. 

If you or your staff have any questions, please contact me at 202-566-2391; or Paul McKechnie, 

Product Line Director for Public Liaison, at 617-918-1471 or mckechnie.paul@epa.gov. 
Environmental Justice Concerns and Communication Problems 

Complicated Cleaning Up Ringwood Mines/Landfill Site 

Table of Contents 

Chapters 

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

Purpose .......................................................................................................... 1 

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

 Scope and Methodology................................................................................. 3 

2 Ringwood Residents Have Environmental Justice Concerns ............................ 5 

No Evidence of Discrimination ....................................................................... 5 

Region 2 Actions Contributed to Perception of Unfair Treatment................... 6 

Site Residents Believe Health Was Adversely Affected................................. 7 

Region 2 Plans to Address Concerns by Cleaning Up the Site...................... 8 

 Recommendation ........................................................................................... 9 

Agency Response and OIG Comments ......................................................... 9 

3 Region 2 Must Overcome Impediments to Good Community Relations ............ 11 

Region 2 Did Not Promptly Establish Community Relations .......................... 11 

Community Relations Plan Did Not Change with the Situation ...................... 13 

EPA’s Relationship with Ford Is Perceived As Inappropriate......................... 14 

Other Legal Considerations Complicate Communication............................... 15 

Continued Improvement in Communication Is Needed.................................. 16 

 Recommendations ......................................................................................... 19 

Agency Response and OIG Comments ......................................................... 19 

Status of Recommendations and Potential Monetary Benefits....................................... 21 

Appendices 

A Agency Response to Draft Report ...................................................................... 22 

B Distribution ............................................................................................................ 26 
Chapter 1

Introduction 

Purpose 

We conducted this review in response to a request dated March 3, 2006, from 

three members of the New Jersey congressional delegation: Congressman Pallone, 

Senator Lautenberg, and Senator Menendez. They requested that the Office of 

Inspector General (OIG) review various issues concerning the actions of the U.S. 

Environmental Protection Agency (EPA) at the Ringwood Mines/Landfill 

Superfund site in Ringwood, New Jersey. This review addresses the following 

two objectives. 

• Did racial, cultural, or socioeconomic factors at Ringwood have any bearing 

on timely investigating and remediating environmental concerns at the 

Ringwood site? 

• How effective were Region 2's community relations activities at the 

Ringwood site? 

The OIG (Office of Program Evaluation) will issue a separate report on EPA 

oversight of site cleanup efforts, remedy selection, and conditions which resulted 

in relisting the site on the Superfund National Priorities List (NPL). 

Background 

From 1967 into 1971, waste material from the Mahwah, New Jersey, factory of 

the Ford Motor Company (Ford) was deposited in the Borough of Ringwood, 

New Jersey, in and around the shafts of abandoned iron ore mines that had 

operated from the 1700s through the 1930s. The waste materials included car 

parts, solvents, and paint sludge. A subsidiary of Ford had purchased 800 acres of 

this land in 1965, with the intention of developing it. However, the development 

plans were not approved. 

In 1970, Ford donated about 300 acres of the area to the Borough of Ringwood 

(Borough), specifically to the Ringwood Solid Waste Management Authority. On 

part of this land, the Borough started a municipal landfill in 1972. The landfill 

was closed in 1976, at the request of the New Jersey Department of 

Environmental Protection (NJDEP). 

1 
Figure 1. Paint sludge around a tree. 

Source: Photo taken by OIG staff in August 2006. 

Testing by NJDEP in 1982 found 

that groundwater and surface 

water in the area were 

contaminated with volatile 

organic compounds, lead, and 

arsenic. This testing led to EPA 

adding the Ringwood 

Mines/Landfill site (Ringwood 

site or site) to the NPL in 1983. 

The NPL is a list of the most 

serious hazardous waste sites in 

the United States identified for 

possible long-term cleanup. The 

Ringwood site consists of 

approximately 500 acres in a 

block of land about one-half mile 

wide and one and one-half miles 

long. It consists of rugged forest 

areas, open areas overgrown with vegetation, abandoned mine shafts and surface 

pits, an inactive landfill, an industrial refuse disposal area, a municipal recycling 

area, the Ringwood maintenance garage, and about 50 private homes. 

EPA has the legal authority to identify potentially responsible parties (PRPs) 

linked to the site and negotiate settlements with PRPs for site cleanup work or to 

issue administrative orders directing them to do so. In 1984, through EPA 

enforcement actions and the oversight of staff from EPA’s Region 2, Ford started 

investigating the contamination of the Ringwood site as a PRP, and in 1987, 

removed 7,000 cubic yards of surficial paint sludge containing lead and arsenic 

from four areas. In September 1988, the Acting Regional Administrator for 

Region 2 decided, via a Record of Decision, to require long-term monitoring of 

surface water and groundwater at the site, as well as confirmatory soil sampling in 

areas where sludge and soil were removed. Additional paint sludge and other 

debris were removed in 1990. In 1993, Region 2 concluded the requirements had 

been met to delete the site from the NPL. The State of New Jersey concurred 

with the decision to delete the site from the NPL. The Ringwood site was deleted 

from the NPL in 1994. Ford later removed additional paint sludge from the site in 

1995 and 1997, in response to requests from residents and the Borough. 

In 2004, the local community alerted EPA to the presence of additional paint 

sludge at the Ringwood site. Ford and the Borough are re-investigating the site 

under the oversight of an EPA Region 2 Remedial Project Manager (RPM), based 

on EPA enforcement actions dated September 2005. Ford is identified as the 

performing party. Thus, Ford is also removing additional paint sludge from 

several locations at the site. Some of these locations were next to the sites of 

earlier removal actions. As of July 2006, 16,000 tons of paint sludge and soil had 

been removed. In addition, New Jersey agencies are overseeing the possible 

2 
remediation of residential properties or the relocation of residents related to the 

Ringwood site. Effective October 2006, the Ringwood site was again added to 

the NPL. 

Scope and Methodology 

We performed this review in accordance with Government Auditing Standards, 

issued by the Comptroller General of the United States, except that we limited our 

review of management controls and compliance to those directly relating to the 

issues identified in the congressional request. 

We performed our work from June 2006 through November 2006. As part of our 

work, we interviewed EPA employees in the Region 2 Office of Regional 

Administrator, the Public Affairs Division, and the Emergency and Remedial 

Response Division; NJDEP employees of the Environmental Justice Program; 

eight current or former residents who lived on or near the Ringwood site (site 

residents); several consultants for the residents; and officials of the Borough. To 

perform this review in a timely manner and still comply with the requirements of 

the Paperwork Reduction Act, we limited the number of interviews conducted. 

However, to offset this limitation, we held two open meetings in Ringwood 

during October 2006, to obtain more information from the community about 

community relations and environmental justice. Approximately 55 people came 

to these meetings, and 30 people spoke during the sessions. Those who attended 

included site residents, consultants for the site residents, residents living 

elsewhere in the Borough (Borough residents), Borough officials, other elected 

officials, a representative of an environmental organization, and residents of 

nearby communities. 

Besides talking to people, we toured the Ringwood site with staff from Region 2 

and other organizations. We also reviewed documents provided by those who 

spoke to us, documents from Region 2’s site files for the Ringwood site, 

documents in the Ringwood site information repository at the Ringwood Public 

Library, and information obtained through the Internet, particularly the Websites 

of EPA and the Websites specifically for the Ringwood site. In a few cases, we 

relied on information obtained by the other OIG team working on the Ringwood 

congressional request. Finally, we obtained information related to the Ringwood 

site from EPA’s financial management system. 

We issued a draft report to the Regional Administrator of Region 2 on 

February 12, 2007. The Assistant Regional Administrator for Policy and 

Management responded in a memorandum dated March 16, 2007. This 

memorandum is attached as Appendix A. The Region 2 official concurred with 

all of the recommendations, and cited actions the Region has taken to start 

implementing two of the recommendations. The response also provided several 

factual corrections and suggested content revisions. We revised the report as we 

considered appropriate, and discuss some of these items at the end of Chapters 2 

3 
and 3. In addition, the Region’s response requested that we change the title of the 

report so it would be neutral, reflecting the subject of the review. We did not do 

so because it is OIG procedure that the report title should reflect our position on 

the matter under review. 

4 
Chapter 2

Ringwood Residents Have 

Environmental Justice Concerns 

Contrary to the strong opinions expressed by Ringwood site residents, we found 

no evidence that EPA’s actions or decisionmaking were affected by the area’s 

racial, cultural, or socioeconomic status. We did find that in 1984, EPA Region 2 

did not take the actions needed to foster a feeling among the residents that EPA 

was committed to protecting their health and the environment. Additionally, the 

residents believe that outside pressures have caused the latest cleanup initiative. 

Region 2’s past interactions with Ringwood residents, together with the fact that 

EPA is back for the fifth time in 20 years to clean up the site, have contributed to 

the residents’ feelings of mistrust. 

No Evidence of Discrimination 

Based on our extensive review of site files and interviews, we did not find 

evidence that Region 2 discriminated against Ringwood site residents. 

Of the seven people we interviewed who currently live on the site, six indicated 

their heritage included American Indian (i.e., the Ramapough Mountain Indians), 

African American, or both. These are considered minority populations. Six 

indicated their household income could be categorized as lower income. 

Information provided by the Borough Manager supported the characterization of 

the neighborhood as lower income. He indicated that 560 people are living in 44 

homes there, or an average of 12 people per home. Also, the assessed values of 

homes in the neighborhood of the site are lower than for the Borough as a whole: 

an average of $68,000 versus $180,000. 

Racial and socioeconomic factors did not appear to have any bearing on EPA 

efforts to clean up the Ringwood site. One Region 2 supervisor involved with the 

earlier cleanup efforts at the site said that he was aware some of those living at the 

site were members of the Ramapough Mountain Indian community. He said the 

fact that they were members of a minority community had no effect on the work 

that EPA needed to do at the site. He added that Agency staff did not treat them 

differently. He explained that it was EPA’s job to clean up the site regardless of 

who lived there, and even if no one lived there. 

5
Region 2 Actions Contributed to Perception of Unfair Treatment 

Environmental justice is the fair treatment and meaningful involvement of all 

people regardless of race, color, national origin, or income with respect to 

developing, implementing, and enforcing environmental laws, regulations, and 

policies. Seven individuals, though, who spoke at our public availability session 

and included two residents we had previously interviewed, felt that the Ringwood 

site would have been cleaned up more timely and effectively if the site had been 

located in a nonminority, more affluent neighborhood. Of the current residents 

we interviewed or who provided comments at our public availability sessions, 

most felt they had not been treated fairly by EPA for varying reasons. First, EPA 

performed previous cleanups of the site, but it is still contaminated. Second, 

during earlier cleanups of the site, EPA did not communicate formally with the 

residents. Third, residents believe outside pressure is forcing Region 2’s current 

actions. 

Five Cleanup Actions Required 

EPA is conducting a fifth cleanup action at the Ringwood site, because all 

contamination was not identified and removed during the previous four cleanups. 

A brief summary of the prior four cleanup actions follows: 

• Beginning in October 1987, Ford excavated and removed 7,000 cubic yards of 

paint sludge containing lead and arsenic from the surface of four areas of the 

site. 

• Additional paint sludge was discovered at the O’Connor Disposal Area of the 

site in October 1989, and in January 1990, drums of waste material were 

discovered there. As a result, 51 drum remnants and 727 tons of additional 

paint sludge were 

removed. In 1992 and 

1993, geophysical 

surveys and test pit work 

were conducted in the 

area, but no additional 

barrels or hazardous 

substances were 

discovered. 

• In 1995, residents 

notified Borough officials 

that more paint sludge 

was at the site. Ford 

removed five cubic yards 

of paint sludge from a 

residential property. 

Figure 2. Removal activity at SR-3 (sludge removal 

area 3), just north of the O’Connor Disposal Area. 

Source: Photo taken by OIG staff in August 2006. 

6
• In December 1997 and January 1998, an additional 30 cubic yards of paint 

sludge and soil were removed from the hillside adjacent to the O’Connor 

Disposal Area. 

Lack of Communication During Original Cleanup 

While the Superfund program was relatively new at the time, Region 2 staff were 

required to establish an effective dialog with the community during the original 

cleanup of the Ringwood site. When the Region did not effectively communicate 

with the community, the residents began to mistrust EPA and believed they were 

not being treated fairly. We discuss problems regarding EPA communications 

and community relations at the Ringwood site further in Chapter 3. 

Many Believe Outside Pressure Was Needed for Current EPA Actions 

According to many individuals whom we interviewed or who spoke at our public 

availability session, not only has EPA not cleaned up the site, but also it is not 

voluntarily doing so now. These individuals believed that EPA would not have 

taken the current actions without outside pressure. They believed EPA responded 

to various sources of pressure, including pressures from elected officials, 

residents’ lawyers, environmental 

groups, and the media. 

Ringwood site residents are sensitive to 

the manner in which they are 

treated. The Borough covers an area of 

more than 25 square miles. Yet several 

facilities are concentrated in the same 

area around the Ringwood mines. This 

includes a landfill (now closed), a 

recycling center, the Borough 

maintenance garage, and radio and 

power line towers. In the 1990s, the 

area was a proposed site for a power 

plant and a chemical company. 

Site Residents Believe Health Was 

Adversely Affected 

Several residents believe their health, or 

the health of family members or 

neighbors, was adversely affected by 

exposure to contamination at the site. 

For the adults, this exposure has now 

Figure 3. Map of Ringwood showing 

(in yellow) the approximate size and 

location of the Superfund site. 

Source: OIG staff. 

7
lasted 40 years, that is, since 1967. Four people gave us examples of such health 

problems. 

In May 2006, the New Jersey Department of Health and Senior Services 

completed a public health assessment and concluded that the Ringwood site posed 

a public health hazard because exposure to paint sludge and soil may continue to 

occur at levels of health concern. The report also noted a higher proportion of 

children with elevated blood lead levels compared to the rest of the Borough. 

However, the overall incidence of cancer was not elevated. The report 

recommended that an exposure investigation be conducted because of the 

potential for exposure to metals from paint sludge and contaminated soils at the 

site. However, in a June 2006 letter, attorneys representing some Ringwood 

residents indicated that they had advised their clients not to participate in 

interviews or physical exams requested by the Agency for Toxic Substances and 

Diseases Registry, due to ongoing litigation regarding the Ringwood site. The 

lawyers proposed an alternative method to provide information on their clients’ 

past and current medical condition. 

In May 2006, EPA Region 2 issued a draft environmental justice assessment 

which concluded that Ringwood was an adversely impacted area based on a report 

issued by the Agency for Toxic Substances and Diseases Registry in 1989. The 

report concluded that the Ringwood site posed a potential health concern because 

of the risk to human health that could result from possible exposure to hazardous 

substances at levels that may result in long term adverse health effects. However, 

the Region indicated that because of the current limitation of localized health 

information about the community resident population, it could not satisfactorily 

distinguish the area from other communities to perform a comparative assessment 

to determine if environmental injustice occurred or exists. The Region indicated 

that to make such a determination it needed to conduct a refined environmental 

justice assessment, including cumulative and risk assessments, when localized 

health data on the residents have been collected by the State of New Jersey and a 

comparable “reference” community is identified. 

Region 2 Plans to Address Concerns by Cleaning Up the Site 

Region 2 believes that cleaning up the Ringwood site will be the most effective 

way to address any concerns or perceptions regarding environmental injustice. 

Regional staff informed Ringwood site residents that they plan to effectively 

clean up the site this time. This intention appears to be supported by the 

Agency’s relisting of the site on the NPL. However, residents doubt the Agency’s 

abilities to do so, considering EPA’s past cleanup efforts at Ringwood. Residents 

cited concerns that all sludge and debris may not have been identified; limited 

monitoring of streams flowing into the Wanaque Reservoir was occurring; and 

there was a lack of testing of local wildlife and plants, some of which are 

consumed by site residents. 

8
Region 2’s RPM for the Ringwood site said that testing for waste disposal areas 

has been extended to areas not previously surveyed, additional monitoring wells 

are being installed, and testing wildlife and plants began in October 2006. On 

January 30, 2007, EPA, together with Federal and State health agencies, held a 

public information session to discuss results of the EPA’s biota study at the 

Ringwood site; about 50 people attended the session. On March 9, EPA released 

the initial results of its study of deer from the Ringwood site. Recently collected 

deer from off the site are being analyzed. According to a Region 2 official, 

additional wildlife, including wild turkeys, rabbits, and squirrels, will be collected 

and analyzed; they plan to present these findings to the public later this spring. 

While the Region plans to address environmental justice concerns by cleaning up 

the site, we believe the Region can take additional action to alleviate these 

concerns. When the current investigation of the site is completed, Region 2 will 

consider options for cleaning up the site. The remedy the Region selects will be 

documented in a Record of Decision. According to a Region 2 official, a Record 

of Decision routinely includes a summary of prior investigation and cleanup 

actions. And any future Record of Decision issued for the Ringwood site will 

discuss all prior investigation and cleanup actions implemented at the site and 

demonstrate why the selected cleanup action, once implemented, will protect 

human health and the environment. We believe the new Record of Decision 

should not just summarize the prior actions, but provide a detailed comparison of 

the current and prior investigations and cleanup actions. We believe such a 

detailed comparison will better address residents’ concerns about the scope of the 

current cleanup. 

Recommendation 

We recommend that the Regional Administrator, Region 2: 

2-1 Address the Ringwood community’s perception of unfair treatment and 

concerns regarding completely cleaning up the site by directing his staff to 

ensure that the new Record of Decision includes a detailed comparison of 

current and prior site investigations and cleanups. 

Agency Response and OIG Comments 

In the response to the OIG draft report, the Assistant Regional Administrator for 

Policy and Management concurred with the above recommendation, and 

suggested replacing the description of the recommendation in the “At a Glance” 

section of our report with the actual recommendation. We concurred and revised 

the final report accordingly. 

The Region’s response also indicated that although New Jersey health officials 

noted that children living near the Ringwood site had higher levels of lead in their 

9
blood than children in other parts of the borough, only one child in the study had 

an elevated level in his/her blood that was possibly related to paint sludge from 

the Ringwood site. 

According to the New Jersey Public Health Assessment, 909 Ringwood children 

were tested for blood lead between July 1999 and October 2005. Of these 

children, 45 lived in the Ringwood Mines area (“Focus Area”); 861 lived in other 

areas of Ringwood (“non-Focus Area”); and 3 lacked sufficient address 

information to determine residential location. 

The study noted that although most children had a blood lead level below 10 

μg/dL, there appeared to be slightly higher levels in the distribution of blood lead 

levels in the Focus Area children, which could have resulted from the relatively 

small sample size or could indicate that the children had slightly more exposure to 

lead in the environment than non-Focus Area children. 

The Ringwood Health Department followed up on two Focus Area children 

whose blood lead levels exceeded 10 μg/dL and determined that the elevated level 

for one child was attributed to potential exposure to lead in paint sludge, while for 

the other child the likely cause was lead paint during home renovation. However, 

the New Jersey Public Health Assessment also noted that if 1,000 children had 

been tested, the rate of elevated blood level for non-Focus Area children was 8 

children per 1,000, while the rate for Focus Area children was 44 children per 

1,000. 

The Region’s response also indicated that Upper Ringwood was an adversely 

impacted area solely as a result of it being part of a Superfund site. However, as 

noted on pages 8 and 9 of this report, the Region’s environmental justice 

assessment concluded that the site exhibited an adverse health effect on the 

Ringwood Mines community based on a report issued by the Agency for Toxic 

Substances and Diseases Registry in 1989. This report concluded that the 

Ringwood site posed a potential health concern because of the risk to human 

health that could result from possible exposure to hazardous substances at levels 

that may result in long term adverse health effects. 

10
Chapter 3

Region 2 Must Overcome Impediments 

to Good Community Relations 

At most sites, the success of community 

involvement has a direct impact on the 

success of the overall cleanup. 

Source: April 2002 Superfund 

Community Involvement Handbook 

Despite recent efforts by Region 2 staff to increase communications with 

residents, three factors impede good relations. First, during earlier cleanups of the 

Ringwood site, Region 2 staff missed opportunities to establish a good 

relationship with the community by not promptly developing a community 

relations plan in 1984, and then not updating it in the early 1990s to reflect 

changes in the situation. Second, there 

are concerns about EPA’s relationship 

with Ford, the performing potentially 

responsible party (PRP) for the site. 

Third, other legal concerns are also 

impacting communications. 

Specifically, the site residents’ lawyers 

want communications with some site residents to go through them, and the 

Borough’s status as a PRP complicates communications with Borough officials. 

For an effective working relationship with the community, the new community 

relations plan for the Ringwood site must address the current impediments. 

Region 2 Did Not Promptly Establish Community Relations 

Despite requirements to the contrary, the Region 2 community relations staff did 

not become involved in site activities until 1988 - 5 years after the site was listed 

on the NPL and shortly before the remedy was selected for the site. Earlier dialog 

with community members might have laid a foundation for good relations, 

perhaps leading to locating and removing more contamination during the original 

site cleanup; according to one of the site residents, they have pointed out half of 

the areas that are now being cleaned up. 

In September 1983, EPA added the Ringwood site to the NPL. According to 

EPA’s May 1983 Superfund Community Relations Policy, the objectives of the 

Superfund community relations program are to: 

• gather information about the community in which a site or incident is located, 

• inform the public of planned and ongoing actions, 

• give the public the opportunity to be involved in decisionmaking, and 

• focus and resolve controversy. 

11
The RPM is the overall project manager with 

responsibility for everything that occurs at the site. The 

Community Involvement Coordinator is responsible for 

advising the project manager on required community 

involvement activities and recommending activities that 

will ensure the community has every opportunity to be 

involved. Involvement by all members of the Site Team 

in community involvement planning and implementation 

activities ensures integration of community involvement 

in the cleanup process and furthers public participation. 

Source: April 2002 Superfund Community Involvement 

Handbook 

For all Superfund-financed cleanup actions, the policy stated EPA regional offices 

must develop a community relations plan (CRP). The CRP is a management and 

planning tool which outlines the specific 

communications activities to be used 

during a Superfund response and the 

integration of these activities with the 

technical work at a site. The Remedial 

Action Master Plan for a site must include 

a community relations assessment with 

steps needed to prepare the CRP. 

EPA drafted a Remedial Action Master 

Plan for the Ringwood site in August

1983. It included the required community

relations assessment. The first item in the 

assessment was to identify community concerns by interviewing local officials 

and community members. It did not include the required schedule for completing 

the community relations plan. 

Seven months after the Remedial Action Master Plan was prepared, Ford became 

responsible for cleaning up the site. Since the cleanup was led by the PRP, it was 

no longer a Superfund-financed action. Consequently, EPA’s 1983 policy did not 

apply, so the Region 2 staff may have considered a CRP unnecessary. Effective 

February 1986, the requirements changed; for cleanup actions at NPL sites, 

including enforcement actions, a CRP must be implemented before field activities 

start. However, the Region 2 staff did not immediately start preparing the CRP 

for the Ringwood site. 

The interviews needed to prepare the CRP were performed in early 1988. They 

were conducted by a member of the Region 2 Office of External Affairs and an 

EPA contractor. In Region 2, the community relations staff are not part of the 

Superfund program division. The CRP for the Ringwood site was issued in July 

1988. The delay from 1983 to 1988 in preparing the CRP was not explained in 

the site files, although we found documents dated 1985 and 1986, informing 

Region 2 staff of potential community relations problems at the site and urging 

them to prepare a CRP. These documents came from staff in the New Jersey 

Department of Environmental Protection. 

Although community relations staff were not involved until 1988, Region 2 

technical staff were involved. There was little evidence that the Region 2 

technical staff informed the community about site activities. We found two 

handouts about site activities dated before the July 1988 CRP: February 1984 and 

October 1987. The latter announced the start of excavating and removing paint 

sludge. It was mailed to residents by local officials. The first public meeting with 

residents during that period was in August 1988, to discuss the options for 

12
cleaning up the site. There was no evidence in Region 2’s site files of any other 

meetings with residents. 

The lack of evidence concerning communication with the community during the 

original cleanup was consistent with what community members told us. We 

interviewed eight people who were adults living in Ringwood at that time. Six of 

these individuals lived on or very near the site. None of the eight people recalled 

efforts by EPA to inform them about what was going on at the site. Three said 

they were unaware of the original cleanup activity. Five site residents said they 

did not know about the original cleanup until they saw trucks or workers at the 

site. 

Community Relations Plan Did Not Change with the Situation 

Region 2 staff did not re-evaluate community relations activity in 1992 and 1995 

when community members brought additional concerns to their attention. The 

community issues and concerns identified in the 1988 Ringwood CRP were 

limited. Two local organizations, the Families of the Ringwood Mines and the 

Ringwood Neighborhood Action Association, expressed additional concerns 

about the site in 1992 and 1995, respectively. Although EPA’s 1988 Community 

Relations Handbook indicates that a community relations plan should be revised 

if community attitudes change, the Region 2 staff have never changed the 

Ringwood CRP. 

In a letter dated April 1992, a representative of the Families of the Ringwood 

Mines told the Region 2 project manager that the citizens living near the 

Ringwood mines were concerned about the possible health effects of the 

substances dumped at the mines. The letter noted the presence of noxious odors 

and vapors. This group apparently started collecting health information from 

community members. Because he was concerned about the issue, in June 1992 

the Region 2 project manager requested that a fact sheet be prepared. A fact sheet 

dated July 1992 was prepared. It summarized the results of monitoring activities 

at the site. There was no evidence of other community relations activity 

concerning the matter. 

In late February 1995, the president of the Ringwood Neighborhood Action 

Association informed the Borough Council that paint sludge remained at the 

Ringwood site despite two previous removal actions. After visiting the site, the 

health officer from the Borough contacted EPA about the sludge. The Region 2 

project manager visited the site in April 1995, and promised to investigate further. 

There was no evidence of other community relations activity concerning the 

matter. These events in 1995 were similar to how the current cleanup actions at 

the site started. 

13
EPA’s Relationship with Ford Is Perceived As Inappropriate 

Some Borough residents and officials, and others, perceive EPA’s relationship 

with Ford to be inappropriate. According to them, Ford appears to be making the 

decisions about cleaning up the site, not EPA. 

Several people, including site residents, their consultants, and Borough officials, 

expressed concern about the relationship between EPA and Ford (including 

Ford’s technical consultant). They characterized the relationship between EPA 

and Ford in several ways, or combinations of ways, including that EPA: 

• Protected or defended Ford, or let Ford off the hook. 

• Let Ford make the decisions. 

• Was lax, or not forceful enough, with Ford. 

• Did not ensure that Ford’s technical consultant performed adequately. 

Some of these individuals also expressed concern about funding the cleanup if 

Ford backs out or goes bankrupt; this concern was cited as a possible reason for 

EPA being lax with Ford. 

According to several people, the actions of the current Region 2 RPM contributed 

to their perception of an inappropriate relationship. Under the current settlement 

agreement between EPA and Ford, EPA (i.e., the RPM designated in the 

agreement) must approve the plans prepared by Ford, as well as the work 

performed. Thus, the RPM must work closely with Ford. At the same time, we 

believe the Region 2 staff must demonstrate to the community that they are 

directing this work, not Ford or its technical consultant. Some ways they may do 

this are as follows: 

• When meeting with Borough residents, fully answer questions about work at 

the site in an open and direct manner, without referring to representatives of 

Ford or its consultant. According to a Region 2 official, their representatives 

answer the vast majority of questions, and refer questions to Ford or its 

consultant on the rare occasions EPA staff are unable to answer a specific 

comment. Despite these efforts, several Borough residents and officials 

believe the RPM does not fully answer some of the questions he addresses. 

• Promptly convey testing results to the community, and explain the 

implications of these results to them. According to a Region 2 official, 

Region 2 releases data after the quality is verified, so it usually takes 21 days 

to process a sample. At the public meeting on July 25, 2006, Region 2 staff 

explained to the community why it takes longer for EPA to release results 

than it takes the site residents’ consultant. Once Region 2 has the results, 

14
though, the community wants them as soon as possible, along with what they 

mean. 

• In the cover letter providing the site residents’ representative with the monthly 

progress report, clearly explain in detail when and how upcoming site activity 

will impact the neighborhood. Although Region 2 staff have expanded 

distribution of these progress reports, apparently site residents (and, as 

discussed later, Borough officials) are not satisfied with their content. For 

example, according to the progress report for August 2006, in September 

2006, Ford’s consultant anticipated performing site-wide groundwater 

sampling. In the letter dated September 19, 2006, that conveyed this progress 

report to the community’s representative, the RPM noted that Ford’s 

consultant “will be collecting groundwater samples from all viable monitoring 

wells at the Site, starting on Monday, September 25, 2006.” The RPM 

repeated this information in a letter to the site residents’ representative dated 

September 21. Starting on October 3, and continuing for several days, a crew 

using large equipment that partially blocked a residential street performed 

work in the Ringwood site. Site residents were upset about this activity for 

several reasons, one of which was they believed no one had warned them 

about it in advance. Even with the RPM’s notice, they had not connected this 

activity with the groundwater sampling. 

• Inform the community when EPA approves plans for work at the site, 

highlighting the review EPA performed and any changes to the plan that EPA 

requested. 

Other Legal Considerations Complicate Communication 

EPA’s communications with Borough residents and officials are impacted by two 

other issues, which are of a legal nature. First, lawyers representing past and 

present residents of the Ringwood site want contacts with the site residents 

coordinated through them. This sometimes slows efforts by Region 2 staff to 

meet with site residents. Second, site residents sometimes rely on Borough 

officials to inform them about site activities. These officials do not always know 

about the activities because, since the Borough is also a PRP, Region 2 staff must 

follow legal protocols in communicating with them. 

Shortly after the RPM’s site visit in April 2004, lawyers representing the site 

residents contacted the Region 2 staff. They asked Region 2 to keep them 

apprised concerning EPA's activities as they affect the residents, and to coordinate 

Region 2’s contacts with these residents through them. According to the lawyers, 

the site residents had sought counsel “in large part due to EPA's 22-year record of 

failing to clean the contaminated site on which they reside, failing to protect their 

health, and failing even to speak to them.” In January 2006, the site residents 

filed a lawsuit against Ford. 

15
The Region 2 staff must take the lawyers’ requests into account when dealing 

with site residents. According to a Region 2 official, they try to communicate 

with site residents as directly as possible while accommodating their needs for 

legal representation. However, accommodating the lawyers’ requests sometimes 

delays meetings between the Region 2 staff and site residents. For example, 

according to the Community Involvement Coordinator (CIC) for the Ringwood 

site, she tried to set up a meeting with the site residents (and their lawyers) in 

March 2005. The meeting was not held until May 2005. 

There is a communication network for the PRPs. It includes the Borough because 

in 1990, EPA formally notified the Borough that it was a PRP. A single person 

was identified in the enforcement orders to serve as the official contact for the 

PRPs related to the Ringwood site. The official contact is a Ford official. All 

technical matters must go through this person. Ford, therefore, is responsible for 

keeping the Borough informed about what is going on at the site on a day-to-day 

basis, not EPA. Each month, Ford’s technical consultant prepares a summary on 

site activity. The Borough Manager receives these monthly reports. Thus, the 

Borough is regularly informed about site activity. 

The Borough officials with whom we spoke believed they were not receiving 

enough information about site activities. When unexpected activity occurs at the 

site, some site residents contact Borough officials. The Borough officials do not 

always have information about the activity in question. The Region 2 RPM is 

aware of the concern about communication among the PRPs, and is working with 

Borough officials to resolve it. In addition, according to him, Region 2 sends a 

copy of all correspondence with residents to the Borough. 

Continued Improvement in Communication Is Needed 

The Region 2 community relations staff have increased interaction with site and 

Borough residents. Because of these efforts, some site residents believe 

communication has improved regarding their involvement in site activities. The 

new CRP being prepared for the Ringwood site must further a good relationship 

with site and Borough residents. 

Since April 2004, when the Region 2 employee who later became the RPM for 

the Ringwood site toured the area with site residents, the Region 2 community 

relations staff have spent more time each year on community relations activities 

for the Ringwood site. In fiscal 2004, they spent 83 hours, in 2005 almost 360 

hours, and in 2006 almost 450 hours. Most of the time in 2006 was performed by 

the CIC for the site. Of her time working on various Region 2 Superfund sites 

during 2006, she spent over a quarter on Ringwood. 

16
Figure 4. Time Spent by Region 2 on Community Relations 

Recently Increased 

83.0 

358.5 

446.0 

0.0 

50.0 

100.0 

150.0 

200.0 

250.0 

300.0 

350.0 

400.0 

450.0 

2004 2005 2006 

Fiscal Year 

Hours of Community Relations Activity 

Source: OCFO Reporting and Business Intelligence Tool 

The increased effort on community 

relations activities is reflected by the 

number of contacts with site and 

Borough residents. Besides several 

meetings in 2004 and 2005, with 

just site residents and their lawyers, 

the Region 2 staff: 

• held four larger-scale public 

 information meetings with 

those interested in the site; 

• helped site residents create a 

Ringwood Community 

Advisory Group (CAG), 

which then met four times; 

• arranged for the Regional Administrator for Region 2 to visit Ringwood in 

October 2005 and January 2006; 

• prepared six handouts about activities at the site; and 

• established a Website for the Ringwood site in addition to the EPA Website 

and a Website maintained by Ford. 

Some of the site residents who spoke to us believed EPA is now doing a better job 

keeping them informed and involved. 

Several setbacks have occurred in the recent relations between the EPA staff and 

the residents. For example, although the CAG started off with monthly meetings, 

none were held since March 2006, and the reason they were discontinued is in 

dispute. One resident said the EPA staff no longer wanted them; the EPA staff 

contend a community lawyer requested the CAG meetings stop. Also, several 

people who attended community or CAG meetings told us some of the meetings 

degenerated because of conflicts between participants. Despite the improved 

communications, some site residents told us they believe the EPA staff are not 

always open, frank, or timely in letting them know about site activities. 

Changes Needed to Community Advisory Group 

As noted earlier, the Region 2 staff helped the site residents form a CAG. A CAG 

is intended to be a public forum for community members to present and discuss 

17
their needs and concerns 

related to the Superfund 

decisionmaking process. 

Thus, a CAG seems 

appropriate for the 

Ringwood site. 

However, the CAG 

described in interviews as degenerating or deteriorating, out of control, shouting 

matches between EPA staff and residents, awful dynamics, and the community 

was hostile. This must be reversed if the CAG is to be a successful forum. 

When the Ringwood CAG was established, it was not given enough form to 

function effectively. According to EPA guidance, each CAG should develop a 

mission statement describing the CAG's specific purpose, scope, goals, and 

objectives. Each CAG also should develop a set of procedures to guide day-today operations. CAG members may select a chairperson from within their ranks 

and determine an appropriate term of office. The primary functions of the CAG 

chairperson are to conduct CAG meetings in a manner that encourages open and 

constructive participation by all members; to ensure that all pertinent community 

concerns are raised for consideration and discussion; and to attempt, whenever 

possible, to achieve consensus among CAG members. If meeting facilitation is 

needed, it is preferable to use someone from the community with facilitation 

experience or a professional meeting facilitator. A neutral facilitator is 

particularly effective at sites where some controversy is anticipated. 

The Ringwood CAG was missing several of the above attributes. It does not have 

a mission statement or operating procedures. The duties of a chairperson were not 

defined, nor was a chairperson selected. Also, given the poor relationships of 

those involved, a meeting facilitator is needed. These deficiencies should be 

corrected. 

A New Community Relations Plan Is Being Prepared 

According to the CIC for the Ringwood site, Region 2 plans to prepare a new 

CRP for the site. Under EPA’s current guidance, the April 2002 Superfund 

Community Involvement Handbook, such plans are now called community 

involvement plans. One must be prepared after a site is listed on the NPL. The 

community involvement plan should identify the community’s issues, needs, and 

concerns, and identify specific activities, outreach products, or programs EPA 

will use to address the community’s concerns. The Handbook identifies a variety 

of communication strategies and techniques that can be used by the RPM and CIC 

to ensure the community is informed about, and involved in, site activities. For 

example, it states: 

18

meetings, and some of the other Ringwood site meetings, were variously 

A community with a high level of interest and concern 

about remedial activities or significant environmental 

justice concerns related to the site should be a strong 

candidate for a CAG. 

Source: April 2002 Superfund Community Involvement 

Handbook 
Person-to-person interaction is necessary for the community to get 

to know Site Team members and vice versa. Personal interactions, 

either by telephone or in person, contribute more to the 

development of trust and cooperative working relationships than 

any other form of outreach. Availability sessions, public meetings, 

workshops, and TV or radio appearances work well. 

As noted earlier, the Region 2 staff have initiated personal interaction at the 

Ringwood site. Much more such interaction will be needed because many site 

residents believe the Region 2 staff are not open and frank with them about site 

activities. They based this belief on a variety of incidents in which the Region 2 

staff seemed to evade questions, or did not provide information in a timely 

manner. In fact, a few site residents do not acknowledge that communications 

have recently improved. 

The community involvement plan for the Ringwood site should be promptly 

drafted, thoroughly discussed with residents and Borough officials, and quickly 

implemented. We believe it should include multiple avenues of communication, 

especially personal interaction. According to a Region 2 official, they plan to 

address re-establishing the CAG in the new community involvement plan, and 

they have already begun work on this plan. 

Recommendations 

We recommend that the Regional Administrator, Region 2, direct his staff to: 

3-1 Prepare and implement a new community involvement plan for the 

Ringwood site. 

3-2 Help the community correct the deficiencies in the Community Advisory 

Group so its meetings are regularly held and productive. 

3-3 Increase communication with the community about Region 2 efforts to 

ensure that Ford properly performs the correct work at the site. 

Agency Response and OIG Comments 

In the response to the OIG draft report, the Assistant Regional Administrator 

concurred with the above recommendations. Concerning the factual corrections 

and revisions requested, we generally agreed and changed the report accordingly. 

One comment was about a statement in the OIG draft report that the April 1992 

letter from the Family of the Ringwood Mines mentioned that State authorities 

had determined that the residents’ drinking water was contaminated. Although 

the statement was correct, we deleted it because the 1988 Record of Decision 

confirmed that the residents receive water from a municipal water supply. 

19
Regarding EPA’s relationship with the PRP, Region 2 indicated in its response to 

our draft report that regional staff have interacted with Ford and its contractors 

according to all EPA regulations and guidance for dealing with a PRP at a 

Superfund site. The Region added that while there are variations in the Region’s 

relationships with PRPs from site to site, the Region’s relationship with Ford at 

Ringwood is typical for a Superfund site of this complexity. 

Regarding the CAG, the Region’s response noted that the Region had secured the 

services of a professional facilitator for the CAG. 

Regarding the community involvement plan, Region 2 indicated in its response 

that regional staff conducted several interviews for the new plan on March 2 and 

March 13, 2007. 

Regarding the Agency’s oversight of the PRP, Region 2’s response noted that 

since 1983, EPA issued five administrative orders to Ford, requiring Ford to 

perform various investigatory and cleanup actions at the site. 

20
Status of Recommendations and 

Potential Monetary Benefits 

POTENTIAL MONETARY 

RECOMMENDATIONS BENEFITS (in $000s) 

Rec. 

No. 

Page 

No. Subject Status1 Action Official 

Planned 

Completion 

Date 

Claimed 

Amount 

Agreed To 

Amount 

2-1 

3-1 

3-2 

3-3 

9 

19 

19 

19 

Address the Ringwood community’s perception of 

unfair treatment and concerns regarding 

completely cleaning up the site by directing his staff 

to ensure that the new Record of Decision includes 

a detailed comparison of current and prior site 

investigations and cleanups. 

Prepare and implement a new community 

involvement plan for the Ringwood site. 

Help the community correct the deficiencies in the 

Community Advisory Group so its meetings are 

regularly held and productive. 

Increase communication with the community about 

Region 2 efforts to ensure that Ford properly 

performs the correct work at the site. 

O 

O 

O 

O 

Regional Administrator, 

Region 2 

Regional Administrator, 

Region 2 

Regional Administrator, 

Region 2 

Regional Administrator, 

Region 2 

O = recommendation is open with agreed-to corrective actions pending 

C = recommendation is closed with all agreed-to actions completed 

U = recommendation is undecided with resolution efforts in progress 

21

1 
Appendix A 

Agency Response to Draft Report 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION 2 

 DATE: March 16, 2007 

SUBJECT: Region 2 Comments on OIG Draft Report - Ringwood Mines 

FROM: Donna J. Vizian 

Assistant Regional Administrator for Policy and Management 

TO: Paul McKechnie 

Office of Inspector General 

EPA Region 2 welcomes the opportunity to comment on the Office of the Inspector General’s draft 

report on the Ringwood Mines/Landfill Superfund site. 

Region 2’s responses to each recommendation in the draft report are as follows: 

OIG Recommendation #2-1 

"We recommend that the Regional Administrator, Region 2, address the Ringwood community's 

perception of unfair treatment and concerns regarding completely cleaning up the site, by directing 

his staff to ensure that the Record of Decision includes a detailed comparison of current and prior 

site investigations and cleanups to demonstrate how the current investigation and cleanup will differ 

from those conducted in the past." 

Region 2 Response 

Region 2 concurs. Any future Record of Decision issued for the Ringwood Mines site will discuss 

all prior investigation and cleanup action implemented at the site, and provide a comparison of the 

current and prior investigations and cleanup actions. 

OIG Recommendation #3-1 

"We recommend that the Regional Administrator, Region 2, direct his staff to prepare and 

implement a new community involvement plan for the Ringwood site." 

Region 2 Response 

Region 2 concurs. For additional information, please see the below section entitled “Update on 

Community Involvement Work.” 

22
OIG Recommendation #3-2 

"We recommend that the Regional Administrator, Region 2, direct his staff to help the community 

correct the deficiencies in the Community Advisory Group so its meetings are regularly held and 

productive." 

Region 2 Response 

Region 2 concurs. Again, for additional information, please see the below section entitled “Update 

on Community Involvement Work.” 

OIG Recommendation #3-3 

"We recommend that the Regional Administrator, Region 2, direct his staff to increase 

communication with the community about Region 2 efforts to ensure that Ford properly performs the 

correct work at the site." 

Region 2 Response 

Region 2 concurs. 

Additionally, we are providing several factual corrections and suggested content revisions that we 

would like to see incorporated into the final version of the report. 

Title of report draws an inaccurate conclusion 

The title of the OIG’s draft report, “Environmental Justice Concerns and Communication Problems 

Complicated Cleaning Up Ringwood Mines/Landfill Site,” suggests that EPA’s cleanup work at the 

Ringwood site has been affected by environmental justice or communication issues. The report, 

however, does not present any findings that EPA’s daily cleanup efforts have been impacted by these 

issues. In addition, the title is a statement of a conclusion rather than a statement that conveys the 

subject of the report. We request that 

the OIG consider a new title for the report that more accurately represents its content. For example 

“A Review of Environmental Justice and Communications Efforts at the Ringwood Mines/Landfill 

Site,” would more accurately describe the content of the report. 

Record of Decision (ROD) recommendation 

The OIG’s recommendation for the new ROD in Chapter 2 (currently at the bottom of page 8) 

should replace the description of that recommendation in the “At a Glance” section as the language 

in Chapter 2 is more complete. 

23
EPA’s relationship with Ford 

We agree with the OIG that EPA’s relationship with Ford as a potentially responsible party (PRP) is 

an important issue at the Ringwood site. However, Chapter 3’s presentation of EPA’s relationship 

with Ford, which is based solely on perceptions of interviewees, does not reflect the reality of this 

relationship. Region 2 staff have interacted with Ford and its contractors according to all agency 

regulations and guidance for dealing with a PRP at a Superfund site, and it is imperative that the 

final report reflect this. Although there are variations in our relationship with PRPs from site to site, 

our relationship with Ford at Ringwood is typical for a Superfund site of this complexity. 

It should be noted that since 1983, EPA has issued five administrative orders to Ford, which require 

Ford’s performance of investigatory and cleanup actions at the site. In fact, investigations are 

currently being conducted at the site by Ford’s contractor pursuant to the requirements of a 

September 2005 administrative order. Furthermore, all work plans developed by Ford’s contractor 

are subject to review and approval by EPA. To ensure compliance with the approved work plans, all 

fieldwork is overseen by the U.S. Army Corps of Engineers for EPA. 

Update on community involvement work 

EPA and federal and state health agencies held a public information session on January 30, 2007 to 

discuss results of the agency’s biota study at the Ringwood site, which was attended by about 50 

people. At that meeting, EPA also announced plans to conduct community interviews as part of its 

revised community involvement plan (CIP). Several interviews took place on March 2 and March 

13 (please note, however, that as of today, none of the Upper Ringwood residents has agreed to be 

interviewed for the revised CIP). EPA has secured the services of a professional facilitator for the 

community advisory group. EPA also released the initial results of its deer study at Ringwood site 

on March 9 and is analyzing recently-collected deer from off of the site. Additional wildlife, 

including wild turkeys, rabbits and squirrels, will be continued to be collected and analyzed. We 

will likely present our findings to the public later this spring. 

Factual corrections for the final report 

• In the “At a Glance” section, the first item in the left column should specify that three 

members of the New Jersey congressional delegation asked the OIG to conduct this 

investigation. 

• On page 2 of the draft, the second paragraph should be revised to reflect that in 1987, 7,000 

cubic yards of superficial paint sludge and soil were removed from four areas of the site. 

• On the same page, the OIG notes that Region 2 concluded the requirements had been met to 

delete the site from the NPL in 1993. The report should reflect that the New Jersey 

Department of Environmental Protection concurred with our findings. 

• The photograph on page 5 is from the SR-3 removal area, not the O’Connor Disposal 

Area. 

• The third paragraph on page 7 discusses a 2006 study by New Jersey health officials that 

noted children living near the Ringwood site had higher levels of lead in their blood than in 

other parts of the borough. Please note that only one child in the study had an elevated level 

in their blood that was possibly related to paint sludge from the Ringwood site. 

24
• The last sentence in this paragraph notes that ATSDR recommended an exposure 

investigation be conducted. Please note that attorneys representing some Ringwood residents 

subsequently indicated in a June 2, 2006 letter that they had advised their clients not to 

participate in physical exams being coordinated by ATSDR, due to litigation concerns. 

• The last paragraph on page 7 of the draft should mention that Region 2 concluded that Upper 

Ringwood was an adversely impacted area solely as a result of it being part of a Superfund 

site. 

• The third full paragraph on page 11 mentions a 1992 letter where New Jersey state 

authorities determined Ringwood residents’ drinking water to be contaminated. However, it 

is EPA’s understanding that Upper Ringwood residents were connected to the municipal 

water supply during the 1980s, which was not contaminated. 

• The report should discuss, perhaps in the “Other Legal Considerations Complicate 

Communication” section in Chapter 3, that New Jersey agencies are overseeing the possible 

remediation of residential properties or relocation of residents related to the Ringwood site. 

If you have any questions, please let me know or contact John Svec at (212) 637-3699. 

25
Appendix B 

Distribution 

Office of the Administrator 

Assistant Administrator for Solid Waste and Emergency Response 

Regional Administrator, Region 2 

Audit Followup Coordinator, Region 2 

Director, Public Affairs Division, Region 2 

Director, Emergency and Remedial Response Division, Region 2 

Audit Followup Coordinator, Office of Solid Waste and Emergency Response 

General Counsel 

Agency Followup Official (the CFO) 

Agency Followup Coordinator 

Associate Administrator for Congressional and Intergovernmental Relations 

Associate Administrator for Public Affairs 

Director, Office of Regional Operations 

Acting Inspector General 

26