PDS PROFESSIONAL DESIGN SERVICES, L.L.C. 1245 AIRPORT ROADe SUITE | # LAKEWOOD NEW JERSEY 087014 732-363-0060 « FAX 732-363-0073, ENGINEERING@PDS-NJLCOM_ WWW.PDS-NJ.COM Wut a STEVENS, PEP (GRAHAM. MACFARLANE, PE ‘Vice RestoeNT JNM, BORDEN, PP. ACR ‘assbeare SEAN. COUGHLAN reeset {AES 1. RUIN PLS, sssocinre {ASSOCIATE November 25, 2019 Kimberly Skibo, Vice Chairwoman Jackson Township Environmental Commission 95 West Veterans Highway Jackson, NI 08527 Re: Jackson Trails Block: 23001 - Lots: 22 thru 29 South Hope Chapel Road Jackson Township, Ocean County PDS No. 17286 Dear Ms, Skibo and The Environmental Commission, Our office is receipt of your review letter dated November 19, 2019 regarding the above referenced project. Please accept the following responses to each of the review comments: ‘The Environmental Commission requested one set of full-sized plans. Mr. Borden committed to attend the August 2019 meeting with the Environmental Impact Statement, and printed full size drawings. However, those plans have not been produced. Full size plans were submitted to the Commission at the time the Planning Board submittal was made on August 10, 2018, Attached please find one (1) additional set of full-sized plans. During testimony at the Jackson Township Planning Board Hearing, The Applicant for Jackson Trails, Jan Borden and Sal Alfieri both committed to the Jackson Township Planning Board that they would appear at the October 2019 Environmental Commission meeting to discuss the Environmental concerns on the application; however, no entity representing Jackson Trails appeared at this meeting. The undersigned did attend the July Commission meeting to describe the project. A letter was issued by the Commission dated July 19, 2019 and a comprehensive response was provided by letter dated August 10, 2019. Additionally, supplemental information was submitted to the Commission by letter dated September 24 addressing the CEA located on the adjoining site. It was at the October Planning Board meeting the Commission Chairman recused himself from all review relating to this project. Additionally a member of the Commission, Stephan DeMarzo, spoke in objection to the project at the October Planning Board Meeting thereby disqualifying himself from any consideration of this project by the Commission. As a result, there is an insufficient quorum of Commission members available to discuss the project since only three (3) other Commission members remain. These facts were explained to Chairman Riker by the project attorney, Sal Alfier prior to the meeting. ‘The Walter Earle Corp. site, abutting the Jackson Trails property, is a contaminated property under the NIDEP's Site Remediation Program (SRP) (Program Interest No. 004009).Jackson Township Environmental Commission Jackson Trails Block 23001 Lots 22-29 Jackson Town PDS 17286 ‘Ocean County November 25, 2019 Page2 of 7 ‘The current regulatory status of the Walter Earle Corp. site includes a Classification Exception Area (CEA) for groundwater established on April 9, 2014, with an estimated self-attenuating duration of 2036. Based on a brief review of the NJDEP's website the CEA was established for a chlorinated solvent known as trichloroiethylene (TEC), historically utilized, for example, as a metals degreaser, and dry-cleaning solvent. A few concems with the presence of this TCE: No regulatory report(s) was provided that summarized the nature and extent of the CEA, nor ‘was groundwater analytical data provided to allow the Environmental Commission to make a proper assessment of the CEA. These are considered significant data gaps, and would require further investigation by any commonly accepted industry standard practice. ‘Vapor Intrusion to the proposed Residential Housing: The NIDEP's website documents a TCE plume with a concentration of 308 milligrams per kilograms (mg/kg); however, since the NJDEP work in micrograms per liter (ng/L) when assessing ground water impacts, the commission requests clarification, and also assumes that the concentration of TCE is 308 g/L. The NIDEP Groundwater Quality Standard (GWQS) for TCE is Ing/L, but even more importantly for the Jackson Trails Site, is the NIDEP's Vapor Intrusion (VI) Groundwater ‘Screening Level of 2ug/L. The TCE impacts within this plume are very high, especially in ‘comparison to the VI screening levels. Therefore, there is a high concern that there is a serious ‘Vapor Intrusion risk tothe proposed Residential Housing. Fate and Transport information (required for establishing a CEA) for the TCE plume was not provided. This would assist in understanding how reliable the “duration” established for the CEA actually is, as the duration is generally a statistically derived value based on site-specific data and/or literature, The CEA can only be terminated when actual groundwater analytical data that shows the contamination has attunated to a concentration not exceeding the NIDEP's GWQS, for at least two consecutive rounds. It is highly improbable that TCE, at a concentration of 308yg/L, will naturally attenuate by 2036. However, no information was provided documenting the Remedial Action at the Site (i.., active or passive remediation). It is unclear what the depth to groundwater at the Site is ifthe new structures are near this CEA will have basements, this would result in even higher Vapor Intrusion concerns. ‘The "Critical Area Map of Groundwater Contamination” plan dated August 19, 2019 prepared by Professional Design Services, LLC (PDS) of Lakewood, New Jersey depict a dashed area called "Groundwater CEA Area.” Utilization of a “dashed! line showing the extent of the CEA boundary is known in the industry to be an “inferred boundary extent.” An inferred boundary ‘extent is not a reliable source to draw the "100' critical area buffer", as it indicates the CEA ‘could be much larger than currently drawn,Jackson Township Environmental Commission Jackson Trails Block 23001 Lots 22-29 Jackson Township, Ocean County PDS 17286 November 25,2019 Page 3 of 7 ‘©. The placement of the monitoring wells (MWs) shown on the PDS plan do not corroborate with the CEA boundary. For the CEA boundary to be accurate and reliable, actual groundwater analytical data is required; however, as you can see MWs are missing along northem and ‘western boundary extents. If MWs and/or data exists, it was not provided. Further, with a concentration of 308 g/L and understanding the nature of TCE, the footprint of the CEA plume seems very small. Even at low levels, TCE is known to be able to contaminate a large quantity of groundwater. (© Historically, TCE was known to be very unstable within the metal containers that it was stored in (would corrode through), therefore, chemical stabilizers were required to be added to the ‘TCE, such as 1,4-Diozane and Methyl Ethyl Keytone (MEK). On January 16, 2018 NIDEP adopted amendments to the Ground Water Quality Standards (N.J.A.C.7:9C), which included revisions and replacements to the NIDEP's GWQS. Specifically, for 1,4-diozane the amendments included the replacement of the interim specific ground water quality standard (0.4 micrograms per liter (ug/L]) with a specific class IIA Groundwater Quality Criteria, establishing a NIDEP GWQS fir 1,4-diozane at 0.4u9/L. Therefore, due to the date of the Remedial Action Permit (2014) vs. the adoption of the 1,4 Diozane GWQS (2018), and the fact that in order to “see” 1,4-dioxane as low as 0.4yg/L a modified (and more expensive) analytical methodology is required (which was not commonly performed in 2014); therefore, it is unlikely that the presence of 1,4-Diozane at the Walter Earle Corp. site was assessed. Along with TCE, the EPA considered 1,4-Dioxane and MEK volatile organic compounds (VOC). © Itis unknown if passive sub-slab mitigation systems and/or vapor barriers are being proposed at the balance of the residential structures. A very specific vapor barrier material would be required, as typical moisture barriers do not prevent the migration of chlorinates solvents into ial and thickness of a vapor barrier must be specific to the contami under the building, otherwise, an undue exposure risk may be present to the occupants, Further, any buildings within 100' of the actual TCE boundary would require post construction VI testing and monitoring, which would be very disruptive to residential use, and in the case access is denied for sampling, would leave an unassessed VI concern. (© According to the Walter Earle Corp. site, there is currently no Licensed Site Remediation Professional (LSRP) assigned, which is highly concerning, as any Responsible Party is required to retain an LSRP for any site in the NIDEP's SRP. Therefore, this contamination is currently unsupervised. The CEA does not arise from any activities at the subject property, is not located on the site and is solely the responsibility of the adjoining property owner, Earle. The Applicant, Jackson Trails LLC bears no responsibility for the CEA. A CEA serves as a well restriction and public notification of groundwater contamination that is attenuating naturally. The letterJackson Township Environmental Commis Jackson Trails Block 23001 Lots 22-29 Jackson Township, Ocean County PDS 17286 November 25, 2019 Page 4 0f7 ‘and plan dated September 24, 2019 prepared by this office and addressed to the Commission addresses all of the relevant facts relating to the CEA and nothing more is required from Jackson Trails. to address this concern. Another copy is enclosed and the plan that ‘accompanied the letter is shown as well. { EARLE t ASPHALT |. CORPORATION exsTING SOFT. ‘OUFFER Based on the nature of these comments it appears these documents were not reviewed prior to writing these comments or the Commission members simply do not understand the basic facts surrounding a CEA. The important facts in this case are the Jackson Trails site does not ‘contain a CEA, the contamination is all located off-site as defined by the CEA, the CEA was properly issued by a LSRP working for Earle and will expire in 2036, no groundwater wells ‘are proposed , the critical distance (100') vapor intrusion mitigation area extends onto the Jackson Trails site affecting three (3) of the proposed homes, vapor mitigation systems are required only for these three (3) homes consistent with NIDEP rules and guidelines. The Vapor Mitigation Systenss will comply with the Vapor Intrusion Pathway Investigative ‘Strategy as contained in the NJ Site Remediation Reform Act (SRRA), As such we are simply complying with the public notification obligations of the CEA, nothing further is required from Jackson Trails. The CEA is currently under the oversight of Potomac Environmental under contract to Earle. The continued monitoring of the CEA is the obligation of Earle andJackson Township Environmental Comr Jackson Trails Block 23001 Lots 22-29 Jackson Township, Ocean County PDS 17286 November 25, 2019 Page § of 7 Jackson Trails has no obligations or responsibilities. If you have continuing questions it is recommended you contact Earle since they are the responsible party. ‘The Environmental Impact Statement is deficient per Township Ordinance #244-189, Further, the EIS is based on a 2008 study, based on information from NIDEP Landscape Habitat Ranking Map the site is ‘mapped with State Threatened Northern Pine Snake, which was observed as recent as 2007. Therefore, the EIS is in need of updating, logs should be provided, a request from the NIDEP Natural Heritage Program databases should be updated, and based on the identification of a State Threatened species on the site, a Threatened and Endangered (T&E) Species Survey atthe Site should be completed. The first statement alleging any deficiency of the EIS per 244-189 does not contain any supportive facts. In fact, the EIS is fully compliant with 244-189 as it strictly follows the project description, site description and inventory and impacts have been addressed consistent to the ordinance. This project is located in the Pinelands and NIDEP has no jurisdiction on threatened and endangered species. Pinelands has reviewed this and other projects proposed on these properties many times over the past 15 years and have consistently found them consistent with their “Fish and Wildlife” standards which includes threatened and endangered species (T&E). Most recently, Pinelands has issued a Certificate of filing on April 5, 2019 which is consistent with regard to their fish and wildlife standards found in ‘the Comprehensive Management Plan, NJAC 7:50- 6.33. The Pinelands Commission contains the regulatory authority and qualified staff to review the T&E issues, consistent with the testimony at the Planning Board Pinelands is required to review any approval granted by the Planning Board and the applicant willbe guided by any requirements imposed by the Pinelands Commission. ‘The Environmental Commission has previously requested dates of the surveys and all field observation notes, logs, photographs for supporting work in developing the EIS submitted, TO date, we have been denied this supporting information. The response above addresses this item. ‘The Environmental Commission understands that there has been ongoing tree clearing and asbestos abatement/removal on the site. No tree clearing has been performed on the site. There has been maintenance work performed on the site to clean up some debris and remove two (2) decrepit former chicken coops. Please be advised the site isa farm-assessed property and the work performed is consistent with those activities. ‘The Commission would like to be provided with the permits and dates for both the tree removal and the asbestos removal. Further, there were numerous solid waste dumpsters for which Origin and Disposal Forms as well as disposal manifests shall be provided. Please also furnish disposal documents for all walking floor trailers utilized on site to date. No trees regulated by the Jackson Township Tree Ordinance have been removed and a Tree Permit was not required. A site visit was performed with the Township Forester on October 14, 2019. The ‘equipment on the site was utilized on the site to dispose of debris collected throughout the site as wellJackson Township Environmental Commission Jackson Trails Block 23001 Lots 22-29 Jackson Township, Ocean County PDS 17286 ‘November 25, 2019 Page 6 of 7 as the two (2) decrepit chicken coops that were removed as authorized by a demolition permit issued by the Township Building Department. It is not required to provide the Environmental Commission with any further information. During a site visit on 11/17/19, there was evidence of deforestation on Block 23001 Lot 26. Tree stumps, disturbed earth, bulldozer tracks, etc. were observed. There have also been photographic accounts indicating construction equipment and dumpsters in the September 2019 timeframe. © New Jersey Pinelands Commission was contacted about approved permits. The site only has valid forestry permits for lots 22/24. There are no approved permits for lot 26. Please explain why work was performed on lots 22 and 24, and furnish permits, if they exist. There is no deforestation evident on the site. No trees regulated by the Jackson Township Tree Ordinance have been removed. The maintenance work performed consisted of removal of fallen, dead trees, mowing of grassy vegetation and cleaning up of debris dumped by trespassers. (©. There is also a construction permit application for the removal of 2 buildings 50 years or older, 372 lot subdivision, the new construction of 457 dwelling units and s 24,500 square foot ional building on the parcel and the installation of 9,300 linear feet of public sanitary sewer min and 10,600 linear feet of public water main within the Ridgeway Road and South Hope Chapel Road rights-of-way. This permit is not valid yet and per Pinelands Commission letters that have not been sent: "NO DEVELOPMENT MAY BE CARRIED OUT ON THE ABOVE-REFERENCED PARCEL UNTIL SUCH TIME AS THE PINELANDS COMMISSION HAS ACTED ON THE PROPOSED DEVELOPMENT.” No development has occurred on this site and none will be performed until all required regulatory approvals have been obtained, included the final review of the Pinelands Commission, consistent with the testimony provided at the Planning Board, ‘The commission requests information on all demolition and construction work that has been conducted ‘on site thus far which shall include reasoning for construction equipment on site prior to Planning Board approval, specifically what work was performed and exact dates for the work, all applicable approved permits for said work, and Origination and Disposal manifests, as well as end point disposal records for the dumpsters. ‘No construction work has been performed on the site. The necessary demolition permits have been obtained from the Building Department for the two (2) decrepit chicken coops. The Environmental Commission has no regulatory authority to request information related to the demolition, that ‘authority rests with the Township Building Department. To summarize, the following information is enclosed:“Jackson Township Environmental Commission Jackson Trails Block 23001 Lots 22-29 Jackson Township, Ocean County PDS 17286 November 25,2019 Page 7 of7 One (1) full-size set of plans ‘One (1) copy of August 10, 2018 submittal to Commission One (1) copy of Commission leter dated July 19, 2019 ‘One (1) copy of August 12, 2019 submittal to Commission One (1) copy of September 24, 2019 submittal to Commission Should you have any questions or require additional information, please do not hesitate to contact this office, Very truly yours, Tan M. Borden, P.P., AICP, President Professional Design Services, LLC IMBios enclosure ec Jackson Trails LLC Sal Alfieri Esq.PROFESSIONAL DESIGN SERVICES, L.L.C. 1245 AIRPORT ROADe SUITE | # LAKEWOOD NEW JERSEY 08701¢ 732-363-0060 FAX 732-363-0073 ENGINEERING@PDS-NI.COM WWW.PDS.NL.COM WILLIAM A. STEVENS, (GRAHAM MACFARLANE, PE, PP_CME, ‘ice mestoent 1ANM BORDEN. PP. AICP associate SEAN. COUGHLAN JAMES RUAN PLS. PRESIDENT ‘ASSOCIATEASSOCTE ‘September 24, 2019 Mr. Jeffrey Riker, Chairman Jackson Township Environmental Commission 95 West Veterans Highway Jackson, New Jersey 08527 Re: Jackson Trails Preliminary and Final Major Subdivision Plan Preliminary and Final Major Site Plan Block: 23001 — Lots: 22 thru 29 Jackson Township, Ocean County PDS No. 17286 Dear Mr. Riker: Please accept this letter providing additional information regarding the Classification Exception Area established by a neighboring property that was raised during public comment at the August Planning Board Hearing. First of all, this issue does not arise from this site but the neighboring property to the east currently owned by Earle and located in the PM-1 Pinelands Manufacturing zone. PDS did not perform any of the ‘environmental investigations on the Earle site and the information provided is taken from the NIDEP files. A sale of the adjoining property occupied by an asphalt plant known as Jackson Asphalt for many years ‘0 Earle more than 15 years ago triggered an ISRA (Industrial Site Recovery Act) compliance investigation which required soil and groundwater sampling. Remedial activities were performed to remove underground oil tanks and contaminated soils starting in 1999 and concluding in 2011. Subsequent groundwater sampling and modeling confirmed the horizontal extent of groundwater contaminated with TCE (Trichloroethylene) would remain ‘confined to the boundaries of the Earle property, and would not extend offsite to any adjoining properties. In 2014 Earle established a CEA (Classification Exception Area) for TCE contaminated groundwater beneath their site. A CEA serves as an institutional control by providing notice that there is ground water pollution in a localized area caused by a discharge at a contaminated site. The CEA is scheduled to expire in 2036 and requires sampling of the contaminant plume by Earle every two (2) years. A CEA serves as an institutional control i i ion ina localized area caused by a discharge at a contaminated stance concems for vapor intrusion into structures extending 100°. Any structures proposed on this site within 100” requires vapor mitigation systems such as plastic vapor barriers and passive venting, Enclosed, please find a map illustrating the CEA and 100° vapor intrusion critical distance. To summarize, no groundwater contamination exists beneath the Jackson Trails project site. The CEA does not prevent the residential development on the Jackson Trails site but simply requires vapor mitigation systems for three (3) proposed homes located within the 100” vapor intrusion critical distance area. I will attend the October 15 Commission meeting to answer any questions regarding the project.Jackson Township Environmental Commission Jackson Trails Preliminary and Final Major Subdivision Plan Preliminary and Final Major Site Plan Block: 23001 —Lots: 22 thru 29 Jackson Township, Ocean County PDS No. 17286 ‘September 24,2019 Page2 of 2 Should you have any questions or require additional information, please do not hesitate to contact this office. Very truly yours, . AICP President Professional Design Services, L.L.C. Enclosure ec: Jackson Trails LLC Salvatore Alfieri/pps\ PROFESSIONAL DESIGN SERVICES, L.L.C. 1245 AIRPORT ROADe SUITE | # LAKEWOOD # NEW JERSEY 087016 752-363-0060 © FAX 732-363-0073 ENGINEERING@PDS-NJ.COM. 'WWW.PDS-N.COM WILLIAM A. STEVENS, PE, CORAHAM J. MACFARLANE, PE, PPCM VICE PRESIDENT UNM. BORDEN, PP AlcP ‘ssoctate SEAND. COUGHLAN JAMES KUHN PLS. PRESIDENT August 12, 2019 Mr. Jeffrey Riker, Chairman Jackson Township Environmental Commission 95 West Veterans Highway Jackson, New Jersey 08527 Re: Jackson Trails Preliminary and Final Major Subdivision Plan Preliminary and Final Major Site Plan Block: 23001 - Lots: 22 thru 29 Jackson Township, Ocean County PDS No. 17286 Dear Mr. Riker: This office is in receipt of your letter dated July 19, 2019 and offers the following response to each comment listed in the letter: + Documentation of existing soil boring logs The plans previously submited includes the locations and logs of 33 soil logs performed ‘throughout the site, these can be found on plan sheet # 79 & 80. + Water and sewer layout The Utility Plans previously submitted contain all of the water and sewer layout, please see lan sheet 21 thru 30. To provide water service a water main is being extended along South Hope Chapel Road from Whitesville Road. Sewer service is being provided from a sewer ‘main to be constructed in Manchester Township along Ridgeway Road (Route 571) and ‘South Hope Chapel Road. The Manchester portion of the sewer has been approved by Manchester and Ocean County Utilities Authority, + Test pit data As noted above the test pit data is shown on plan sheets 79 & 80. The locations are shown on sheet 79 and logs are shown on sheet 80. + Complete storm water plan and calculations The plans previously submitted include the stormwater plan on the Storm Drainage Plans, plan sheet 12-20. The Stormwater Management Report indicating the project complies with the Pinelands Commission stormwater management rules has been previously submitied as well. + Complete landscape project PL overlay on GeoWeb Enclosed please find a copy of the PL overlay on a map generated by the NIDEP GeowebbJackson Tells Preliminary and Final Major Subdivision Plan Preliminary and Final Major Site Pan Block: 23001 ~ Lots: 22 thru 29 Jackson Township, Ocean County PDS No. 17286 ‘August 12,2019 Page 2 of 2 program. + National Heritage data base for T & E species. Please be advised T&E species are regulated by the Pinelands Commission pursuant to the Pinelands Comprehensive Management Plan (CMP). This is evidenced by the Certificate of Filing being issued on April 5, 2019 since it is consistent as it relates to NJAC 7:50-6.33 “Protection of threatened or endangered wildlife” based on survey studies previously performed for Barred Owl, Coopers Hawk, Red-Shouldered Hawk, Northern Pine Snake, Timber Rattlesnake and Pine Barrens Treefrog. Should you have any questions or require additional information, please do not hesitate to contact this office. Very truly yours, Ian M. Borden P.P., AICP President Professional Design Services, L.L.C. Enclosure Jackson Trails LLC Salvatore Alfieri