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DEPARTMENT OF ENVJRONMENTALPROTECTION OFFICE OFTHE COMMISSIONER Mail Code 401-07 CHRIS CHRISTIE P.O.Box402 BOBMARTIN Governor Trenton, NJ 08625-0402 Commissioner TEL (609) 292-2885 KIM GUADAGNO FAX (609) 292-7695 Lt. Governor



### Judith Enck, Administrator U.S. Environmental Protection Agency Region II 290 Broadway New York, NY 10007-1866
Re: Nomination for Removal Action and National Priorities List ofSuperfund Sites Matlack Inc. Swedesboro Tem1inal Site Woolwich Township, Gloucester County

DearMs. Enck:
The New JerseyDepartment ofEnvironmental Protection (DEP) submits the Matlack Inc. Swedesboro Terminal site in Woolwich Township, Gloucester County for removal action consideration under the federal Comprehensive Environmental Response and Cleanup Liability Act (CERCLA) and nominates the site for inclusion on the National Primities List (NPL) of Superfund sites.
The 31-acre Matlack site poses an ecological risk to bald eagles and other fauna from a contaminated surface water seep to a local creek that warrants removal action considerationby the U.S. Enviromnental Protection Agency (EPA) Region II's Emergency and Remedial Response Division. Furthermore, due to apervasive groundwater contamination problem, including aprobable non-aqueous phase liquid (NAPL) source, and near depletion ofavailable responsible partyfunding, DEP also requests EPA again considerthis former Resource Conservation and Recovery (RCRA) site for NPL listing to adequately complete necessary remedial measures. This site was first scored and found eligible for NPL listing in 1984, but received a RCRA deferral. Since Matlack is no longer a viable company the RCRA deferral is no longervalid.
Because a DEP contractorrecentlyprepared a Remedial Alternatives Analysis at the Matlack site that outlines specific cleanup options, it is recommended EPA incorporate therecentlyproposed national Superfund Integrated Cleanup Initiative (ICI) for accelerating aremedial action project. Theproject size and complexityincluded in the DEP report is within the pilot criteria under ICI's ActionNo.l7. DEP is prepared to help expedite the signing ofa Record ofDecision after this site is placed on the NPL.

NewJersey is an Equal Opportunity**Employer~** Printed on RecycledPaper andRecyclableDEP specificallyrequests that EPA Region II's Removal Action Branch evaluate stopping the discharge ofchlorinated solvents into Grande Sprute Run via seeps located on its banks, Sediment and water samples collected from six locations indicate the presence of tetrachloroethylene (PCE) and othervolatile organic compounds discharging into the tributary, which in turn flows into Raccoon Creek. Grande Sprute Run contains athriving ecological communitythat would beimpactedbycontaminants as measured. Notably, sediment samples from within the flowing seeps contained PCE.
As ofJanuary 2011, DEP maintains control ofapproximately $375,000 in a financial assurance account from the bankruptresponsible pmty for remedial activities at the site. An interim groundwater extraction and treatment system remains active at the site.

Dueto the findings in the Remedial Alternatives Analysis report, lack ofa viable responsible party and scope ofremedial work anticipated to investigate and clean up the volatile organic contamination to protect ecological health in the area, itis appropriate that the Matlack sitebe proposed for the NPL.

DEP specificallyrecommends that two alternatives betaken to preconstruction stage under an ICI pilotto provide more reliable datato make a final decision: excavation ofsource area and insitu chemical oxidation. The extra cost to conduct a treatment test for in-situ chemical oxidation would bepartlyoff-setbyreducing the volume ofsoil to be excavated should the excavation of
source areabe implemented.
The facility began operating in 1962 as a truck terminal and tank-trailer cleaning facility. The site operations, which were closed in 1998, included maintenance areas, parking areas, and truck cleaning racks for purging various tank trailers. Matlack wentbankrupt and DEP took over the financial assurance to remediate the site and has been working withEPA's RCRA program. Currently, a po1tion ofthe prope1ty is used by Liberty Kenworth as a medium and heavy duty l!uck sales and service center.
DEP appreciates the opportunityto participatein the decision-making process to nominate this site for removal consideration and NPL status and is looking forward to future cooperation with EPA during remedial work at the site. Ifyou have any questions, please call me at 609-292-1250.

Si relv

Commissioner

c: George Pavlou, DeputyAdministrator, EPA Region II Walter Mugdan, Director, EPA Emergency and Remedial Response Division Irene Kropp, DeputyCommissioner, DEP Dave Sweeney, Assistant Commissioner, DEP Site Remediation Program