Why Montgomery is wary of 3M site cleanup

The background, with text of letter to DEP

By Katie Wagner Staff Writer
MONTGOMERY — The township’s dissatisfaction with the 3M Belle Mead plant, which produces roofing granules, dates back approximately four years to when 3M failed to provide explanations on how its operations were affecting air quality to the Planning Board, according to township officials.
Montgomery Township Deputy Mayor Louise Wilson, who had been mayor and a member of the Planning Board at the time, said a series of “testy exchanges” between township and 3M officials followed the Planning Board meeting and that ultimately the plant’s manager was sent to another of the corporation’s sites.
Montgomery officials’ early August discovery of the existence of potentially toxic metals stored on the Sourland Mountain site has them even more concerned about the site.
”We have been told all along that the biggest concern of the site was the fines piles and the environmental concerns it was causing in our waterways,” said Montgomery Township Mayor Cecilia Xie Birge. “Those problems were more aesthetic than anything else, but this recent report demonstrates potential for health risks.”
Prior to the arrival of Keith Jacobs, the plant’s current manager, “3M was not forthcoming with information about conditions at the plant and resisted the township’s efforts to protect nearby neighborhoods and the streams,” Ms. Wilson said.
According to township officials, Mr. Jacobs has been open and honest with the township and has overseen design and installation technologies that have brought substantial improvements in air quality.
”Keith’s arrival at 3M coincided with a dramatic change in the company’s attention, and investment in, addressing severe deficiencies in equipment and operating procedures that were causing serious air quality and water quality problems in the area,” Ms. Wilson said.
She added, “Under his leadership they have initiated improvements that prior to his arrival they had not done, either because they had been unaware of their need to do them or because they chose not to do them.”One thing township officials said hasn’t improved since Mr. Watson’s arrival is the water quality of various brooks with tributaries on the 3M property — a concern the township raised in an Aug. 6 letter to the state Department of Environmental Protection. (See full text of the letter, below). Also included in the letter are questions on what will happen to the plant’s waste pile of mineral fines and who will be responsible for ongoing environmental compliance on that site, after the plant closes, which 3M recently announced it intended to do.
According to the letter, for every ton of roofing granules produced by the plant, a ton of waste product in the form of mineral fines (powdery rock dust) is produced. The letter claims that the millions of dollars 3M has invested in controlling dust from its pile of mineral fines has resulted in improved air quality, but not water quality. Also referenced in the letter is that 3M has implied the water quality problem is too expensive for the company to fix.
According to DEP spokesman Larry Hajna, the DEP mailed its response to the township’s letter Thursday.
Mr. Hajna declined to disclose the details of the response.
Describing the fines pile, Ms. Wilson said: “It’s massively big. It’s an industrial waste product that’s extraordinarily difficult to control. The prospect of having it be this gigantic abandoned pile of rock dust is a very unpleasant scenario.
”We know that DEP is really the oversight authority here and we feel very strongly about doing everything we can to make sure DEP is paying careful attention to this,” she added. “Our big concern is what happens when 3M is gone if somebody that doesn’t have the skills and integrity of somebody like Keith Jacobs is running the site. We’re looking 10 years, 50 years, 100 years in the future and we want to make sure DEP and 3M are looking ahead, too.”
Among the township’s other requests contained in the letter are, receiving a list of all permits held by the plant, being notified when DEP receives 3M’s closure plan and that a single point person from DEP is selected to be responsible for the plant’s closure.
”I’m concerned about the future,” said Mayor Birge, in an interview Thursday. “The township wants to make sure the closures are properly done and that there will not be any future closure problems, and wants the company to be responsible for completing remediation.”
Here is the full text of the Aug. 8 letter, sent to Lisa Jackson, Commissioner, NJ Department of Environmental Protection by the Montgomery Township Committee:
Dear Commissioner Jackson:
In late June, 3M Corp. announced it will phase out operations at its Belle Mead facility, which includes property in Montgomery Township and Hillsborough Township, Somerset County.
This 3M facility, part of the company’s Industrial Mineral Products Division, is located in the Sourland Mountain region of central Jersey — a unique environmental resource of deep woods habitat, vernal pools and boulder fields covering more than 90-square-miles. The facility quarries diabase rock and crushes the rock to small granules, then processes and colors the granules for use by the asphalt roofing industry.
A byproduct of the mining and crushing operation is mineral fines. For every ton of roofing granules produced, a ton of waste product in the form of mineral fines (powdery rock dust) also is produced. These mineral fines have been stockpiled on the mountain for decades. The fines pile now covers approximately 60 acres and is 80 to 100 feet high. It rises well above the tree line and is clearly visible for miles.
The dust from the fines pile has proven exceptionally difficult for 3M to manage, creating significant air quality problem and a persistent discoloration/ pollution of several streams and headwater tributaries that drain through Montgomery Township into the Millstone River. 3M is currently operating under an Administrative Consent Order under the supervision of NJDEP — Northern Bureau of Water Compliance and Enforcement. 3M has invested millions of dollars in improving air quality and water quality. The company has been largely successful with air quality improvements, but the water quality problems persist and seem to be too expensive for 3M to fix. In announcing that the Belle Mead facility would close, 3M cited “the already high cost of production, combined with the additional investments needed for continued operation.” This was a direct reference to the cost of cleaning the water that runs off the site.
Montgomery Township is very concerned about the future of the 3M facility. Specifically, we feel the enormous pile of mineral fines represents a significant hazard and we need answers to the following questions:
• Will the fines pile remain on top of Sourland Mountain when 3M departs?
• If so, how will the fines pile be managed in perpetuity, by whom, and at whose expense?
• Who will be responsible if there is a catastrophic failure of the fines pile? There have been failures in the past, resulting in “blowout” situations, extreme erosion during and after significant storm events.
• Downhill from the fines pile there are exceptional resource wetlands; these wetlands and other high quality habitat are at risk. How can we ensure that these resources are protected in perpetuity?
• 3M has created a series of basins that hold water, and channels that manage and direct stormwater runoff. The basins require periodic dredging and structural repairs. Who will maintain these basins in the future?
• 3M has not been able to control the problem of suspended solids and dissolved solids in the water exiting their site. The surface waters downstream of the site often are a chalky white color, and can no longer support a healthy diversity of aquatic life. This problem must be addressed. Who will be responsible?
• There has been discussion of possibly transferring the fines pile into the quarry hole. If the mineral fines are moved back into the hole and stabilized, the air and water quality risks, as well as the danger of possible structural failure of the fines pile, would be resolved. However, transferring the fines to the quarry would create a disturbance — possibly a huge disturbance with heavy, unhealthy rock dust — during transfer, and might require construction of retaining walls around the hole to accommodate the very large volume of fines. Who will decide the future of the fines pile, and how will this decision be made?
• There are reports of toxic metals contained in the fines pile. The data from the EPA TRI Explorer Website indicates that just under 150,000 pounds of toxic metals (manganese, chromium, cobalt, zinc and lead) in on-site landfills, presumably the fines pile, from 1999 to 2005 alone. 3M Belle Mead has been in operation for over 40 years. How can we ensure these toxic metals are properly contained and not released to streams or bodies of water? Does 3M have a permit for this activity? Montgomery would greatly appreciate a list of all permits currently held by 3M for this facility.
• 3M has a permit to pump more than 10 million gallons of water-per-month from wells on site. Will these wells be closed? There are also monitoring wells on site. Will these be closed or maintained, and if maintained — by whom?
Montgomery Township will do whatever it takes to ensure that the 3M site does not pose a long-term threat to public health and safety, and the environment. Current conditions are unacceptable, but could become far worse under certain circumstances. Currently there is a safety net in the event of an exacerbation of current conditions, as a Fortune 100 company stands behind the site. Who will be responsible if title to the property transfers?
It is imperative that 3M be held to a high standard that only DEP can set and enforce. We ask that DEP require permanent, comprehensive solutions to the existing and potential problems associated with the mineral fines pile, quarry, basin system, coloring plant and other features of the site.
The 3M closure presents a complex set of issues that must surely extend to several offices or divisions within DEP. In addition to the information we request, Montgomery would greatly appreciate a cross-division coordination of activities within DEP, perhaps with a single point person responsible.
We understand that 3M is preparing a revised closure plan. We assume the closure will be regulated under ISRA and thus will undergo a complete review by NJDEP and ultimately will require a No Further Action approval. 3M has been cooperative with Montgomery in endeavoring to address the environmental problems on site, and their plant manager and staff have worked diligently to address countless problems. We hope and expect 3M will continue to work with the township and will provide us with a copy of their proposed closure plan. Still, we would appreciate knowing when DEP receives the closure plan, and we ask for an opportunity to then meet with the appropriate department staff to discuss the situation, including the remedial action work-plan and a final, permanent remediation plan.
Thank you very much for your department’s attention to these important issues, and for your consideration of our urgent requests.
Cecilia Xie Birge
Montgomery Township 