ISRA Remedial Actions forFormer Hyatt Clark Industries Site

The Revitalizing Auto Communities Environmental Response (RACER) Trust has prepared this Project Fact Sheet to update the community about activities currently being performed at the former Hyatt Clark Industries Site, now known as Hyatt Hills, located in the Townships of Clark and Cranford, New Jersey.

As a result of the bankruptcy of General Motors Corporation, the Hyatt Hills property is now owned by the RACER Trust. RACER was created in March 2011 by the U.S. Bankruptcy Court to clean up, and position for redevelopment, this property and others that were owned by the former General Motors Corp. before its 2009 bankruptcy. RACER is continuing to implement approved remedial actions at this Site.

This Fact Sheet discusses progress that has been made under a longstanding agreement (Case #E87769) with the New Jersey Department of Environmental Protection (NJDEP). This agreement requires RACER to conduct Remedial Actions at the Site under the Industrial Site Recovery Act (ISRA), formerly called the Environmental Cleanup Responsibility Act (ECRA). Remedial actions include operation and maintenance (O&M) of an oil recovery system and discharge of treated groundwater under New Jersey Pollution Discharge Elimination System (NJPDES) requirements.

INTRODUCTION

www.racertrust.org

1300 Raritan Road, Union County, NJBlock 1, Lot 143 of the Tax Map of Clark TWP

Block 1, Lot 541 of the Tax Map of Cranford TWPNJ Known Contaminated Site ID. 37799

The Site is the current home of the Hyatt Hills Golf Course. The Site is located at 1300 Raritan Road, in the Townships of Clark and Cranford, New Jersey, on approximately 87 acres. The parcel housed a manufacturing facility in the past. The plant began operating in 1938, originally manufacturing hard rubber products such as steering wheels and door handles for vehicles. For most of the plant’s operating life, it manufactured anti-friction roller bearings for the automotive and railroad industries. In 1981, ownership of the Site passed from General Motors to Hyatt Clark Industries (HCI), Inc., an employee-owned company that operated the plant until 1987. The plant ceased operations in August 1987 when HCI entered into bankruptcy proceedings. In 1989, Motors Liquidation Corporation (MLC) assumed the obligation to complete the plant closure process. As part of the plant demolition and transformation to its current reuse, MLC investigated soil and groundwater to evaluate and to address any unacceptable effects from past operations at the Site.

SITE BACKGROUND

RACER has been performing, and will continue to perform, Remedial Actions at the Site pursuant to the Consent Order with NJDEP. MLC investigated the Site and addressed those areas where conditions posed a potential significant risk to human health and the environment. The scope of the investigation and the required remediation work has been reviewed with NJDEP and has been conducted according to standards that are protective of human health and the environment.

Over the past 20 years, GM and successor owners have completed several steps in the Remedial Action process for the Site. These steps have included environmental investigations and subsequent actions to address areas of affected soil and groundwater at and near the property.

Remedial Actions that have been conducted at the Site include: demolishing/abandoning surface and subsurface facilities; soil and groundwater remediation; constructing a multi-layer cap system to prevent precipitation from infiltrating soil containing contaminant levels above established standards; and constructing a free-product recovery system (FPRS) to remove floating oil from contaminated groundwater. These Remedial Actions were completed in 2000.

More recent Remedial Actions have included excavation of affected soil adjacent to the southeast corner of the Site [Area of Concern 3 (AOC-3)] on the adjacent Conrail Railroad property, that have been affected by polychlorinated biphenyls (PCBs). A total of 200 cubic yards of soil was removed and transported off site for appropriate disposal.

In March 2001, MLC entered into an agreement with the Hyatt Hills Golf Course Commission to construct a golf complex at the Site that included an 18-hole miniature golf course, a multi-station driving range, a 9-hole regulation golf course with auxiliary support buildings, and a full service clubhouse. The agreement allows Hyatt Hills to operate and manage the golf course complex, while ownership of the Site remained with MLC and now RACER Trust.

The ongoing Remedial Action process calls for the following activities: provisions for supplemental groundwater monitoring and certain engineering and institutional controls on the property to control future exposure to constituents left in place; operation, maintenance and monitoring of the FPRS; and annual cap system inspection. The NJDEP has approved a Remedial Action Work Plan (RAW) to implement these activities.

The RAW identifies and provides implementation details regarding the necessary operation, maintenance and environmental service measures and controls to ensure the effectiveness and integrity of the remedy.

ISRA REMEDIAL ACTIONS

Supplemental Groundwater Monitoring

Pursuant to the RAW and a Groundwater and Summary Work Plan, groundwater monitoring wells located up-gradient and down-gradient of the cap, at the Site’s perimeter, and adjacent off-site wells are sampled on an annual basis to further evaluate the natural attenuation process for the dissolved phase constituents in the overburden and bedrock, and to monitor the extent of the free product (oil). Additionally, groundwater elevation measurements are collected to monitor groundwater flow directions at on- and off-site locations. Reports are submitted to the NJDEP summarizing the groundwater monitoring activities. RACER Trust will continue to cooperate with the NJDEP to ensure that work completed at the Site is conducted according to standards that are protective of human health and the environment.As part of implementing the Groundwater Summary and Work Plan for the Site, RACER and the NJDEP continue to evaluate the need for each monitoring well located on and off site. Wells located in areas no longer needing to be monitored will be properly removed in accordance with NJDEP approval. When wells are located on private property, RACER Trust will coordinate well removal efforts with the property owners.

Operation, Maintenance and Monitoring of FPRS

Since 1997, the free-product recovery system has been in operation at the Site. This system removes free product (oil) from the subsurface. The system includes an equalization tank; oil/water separator and wet well unit; oil skimmer; product tank; bag filters; anthracite clay unit, and two granular activated carbon units. Free product is removed from the groundwater and stored in an on-site storage tank until it is shipped off-site as PCB-contaminated waste to a certified disposal facility in upstate New York.

Pursuant to the site-specific NJPDES permit, quarterly monitoring of the untreated influent groundwater and treated effluent groundwater are performed for permit-specific constituents. If permit-specific effluents limits were to be exceeded, then the NJDEP would be immediately notified, whereupon institutional controls would be immediately implemented in order to maintain standards that are protective of human health and the environment. Semi-annual reports are submitted to the NJDEP summarizing the influent and effluent monitoring activities.

ISRA Remedial Action

Industrial Site Recovery Act (ISRA), formerly Environmental Cleanup Responsibility Act (ECRA) is a New Jersey law (i.e., N.J.A.C. 7:26B) that requires the owner or operator of an industrial establishment to certify that the facility is in an acceptable condition or to clean up any contamination prior to property transfer, termination, or closing. The NJDEP may allow the owner or operator of the industrial facility to enter into a Consent Order (CO) requiring full compliance with ISRA/ECRA.

The New Jersey Department of Environmental Protection (NJDEP) and the prior owner of the site signed a consent order for Remedial Investigation and Remedial Action at the Site.

Remedial Investigation and Remedial Action are processes through which the areas of a facility that may have been affected by the management of solid or hazardous waste, or releases of hazardous constituents, are evaluated and, if necessary, remediated.

New Jersey Pollution Discharge Elimination System (NJPDES) establishes site-specific permit requirements for wastewater discharge monitoring that the owner or operator of the facility must follow to ensure discharges are protective of human health and the environment.

The United States Environmental Protection Agency (U.S. EPA) Region 2, is evaluating the progress of the cleanup of the Former Hyatt Clark Industries Site in accordance with the Resource Conservation and Recovery Act (RCRA).

Clark Township Library, 303 Westfield Avenue, Clark, New Jersey | (732) 388-5999

Write:

Division of Remediation SupportNew Jersey Department of Environmental Protection

401 East State Street, 6th FloorP.O. Box 413

Trenton, NJ 08625-0413

Attn: Office of CommunityRelations

Visit the RACER Trust website at www.racertrust.org

If you would like more information about this project, you may contact the following:

An information repository has been established where final project-related documents are available for public review:

Call or Write:

RACER Trust

Attn: Robert Hare500 Woodward Avenue, Suite 2650

Detroit, Michigan 48226

1-855-RACER-411

rhare@racertrust.org

Call:

New Jersey Dept. ofEnvironmental Protection

Christopher Blake,Case Manager

1-609-292-0494

Annual Cap System Inspection

Maintenance of the soil remedial actions entails routine periodic inspection of the 30-acre cap (a linear low-density polyethylene geomembrane) and review of deed notice requirements to ensure the integrity of engineering and institutional controls. The routine periodic inspections are conducted annually in accordance with New Jersey regulations. Inspection reports are written and submitted to NJDEP, and a logbook is maintained accordingly for NJDEP to review upon request. Items of inspection include checking for differential settlement in the topsoil/barrier protection layer and for failures in the perimeter cap drainage system.

The cap is currently covered by the driving range and parts of the golf course. Although the site is owned by RACER Trust, the Trust has made provisions for the operation and maintenance of the golf course above the cap.