The strategic plan summarizes remediation alternatives for the JIS Landfill site in South Brunswick, New Jersey. The three main alternatives discussed are: 1) passive containment and monitoring, 2) targeting the napl source zone through excavation or treatment followed by natural attenuation, and 3) fully remediating the groundwater to meet drinking water standards. Key factors like soil and groundwater remediation approaches, land use restrictions, and regulatory requirements are compared for each alternative. The document aims to evaluate the options and establish an end state vision to guide future remedial actions at the site.

1. CONFIDENTIAL
Site Strategic Plan (EXAMPLE)
JIS Landfill
South Brunswick, New Jersey
Contact:
John Rosengard
(415) 982-3100
www.erci.com
© 2012 Environmental Risk Communications, Inc.

2. Project Scope
“In S
“I Scope” Issues and Al
”I d Alternatives
i “Out of Scope” I
“O fS ” Issues and Alternatives
d Al i
o End state vision / risk and land ownership o Asset operation strategy
o Properties covered by this document o Statewide policy issues
o Pace to closure o Litigation strategy
o Revenue and cost recovery opportunities o Staffing, contractor selection
o NRDA o Accounting treatment of remedial costs
o Effect on nearby operations (reserves, CapEx, etc.)
o Unit costs
o Remedy selection / endpoints
Key Assumptions
1 Property zoning remains Industrial
2 CERCLA site; no duplicative RCRA closure process
© 2012 Environmental Risk Communications, Inc. 2

3. Current Regulatory / Counterparty Status
 New Jersey Department of Environmental Protection
Lead Agency
(NJDEP)
 RFI complete (per DEQ expectations)
Current Regulatory  Final Remedy Selected – 09/2009
 Construction complete – 09/2009
Status  Risk assessments, CMS, and CMI to be done as conditions
of AOC (1988) and in accordance with VRP guidance
Principal Regulatory  DEQ: Non-degradation of river / waters of the state
 Potential Region 2 RCRA re-opener and/or additional
Risk Drivers requirements
Land Ownership  Site wholly owned by Jones Industrial Services (JIS)
 High risk property owner (bankruptcy filing possible in 2
years)
 Insurer are Travelers and Liberty Mutual
Counterparty Status
C t t St t
 PRP Group allocation is in place; currently 5th by volume at
8%; largest is privately-held metals processor, 3rd largest is
oil refiner owned by hedge fund
© 2012 Environmental Risk Communications, Inc. 3

4. Stakeholder Analysis
Level of Level of
Stakeholder Influence Support Key Drivers Management Strategy
(0 – 5) (0 – 5)
Protection of wild and  Free product recovery system
NJDEP 4 4 scenic river, protection of  Assessment of historic
drinking water aquifer
d i ki if releases, possible d
l ibl data gaps
Protection of human health
EPA 3 0 Comply with EPA requirements
and the environment
 Resolve all outstanding
property management issues
and position ourselves to
leverage property transfers to
Adjacent Potential impact on
1 0 reduce remedial requirements
Landowners development potential
/ costs
 Maximize the sale and
alternate use of other surplus
property
Potential sheen on river,
Town Residents 1 0 GW system
trespass risk
NGOs
NGO N/A N/A None id tifi d
N identified
NRDA impacts and Leverage settlement through
NRDA Team 3 4
credibility property sale to state
Jones Industrial
5 5 -- --
Services
Routine monitoring and
PRP Group 5 5 Allocation
prepayment into escrow account
© 2012 Environmental Risk Communications, Inc. 4

5. Physical Setting – Site Location
JIS Landfill
JIS Landfill
© 2012 Environmental Risk Communications, Inc. 5

6. Site Specifics – Ownership Information
Vulture City
Wakefern Food
Furniture Cannon
Corporation
Sunoco
S
Cary
Compounds
Residential
JIS L dfill
Landfill
Plume Area
Residential
Monroe
Collision
Drive Medical Center
New Jersey Turnpike
I-95
© 2012 Environmental Risk Communications, Inc. 6

7. General Site Information
JIS Landfill
EPA REGION 2
901-999 Cranbury South River Road
Middlesex, South Brunswick, New Jersey
EPA ID#: NJD097400998
 Located in South Brunswick Township, near the border of
Monroe Township
 Approximately 24 acres, includes a 7.8 acre landfill and a
waste transfer operation
 Approximately 50,000 cubic yards of waste were disposed
50 000
of annually until landfilling operations ceased in 1980
 Ground water is contaminated with metals and volatile
organic compounds (VOCs), including vinyl chloride,
JIS Landfill
methylene chloride, acetone, tetrachloroethene,
trichloroethane, chlorobenzene, benzene and Aldrin, a
pesticide
 Concentrations of contaminants are above Federal and
State drinking water standards
Plume Area
 Contaminants have been detected in the groundwater
from the site to Manalapan Brook, 1.5 miles downgradient
of the site; contamination is present from the water table
to the base of the aquifer, a thickness of roughly 60 feet
© 2012 Environmental Risk Communications, Inc. 7

8. Historical Images
1995 2002
2006 2007
© 2012 Environmental Risk Communications, Inc. 8

9. Operating & Remediation Timeline
Operating History
1960-1970s
The landfill accepted chemical, 1983
municipal, and industrial wastes JIS placed a
1959:
including broken battery casings, cap over the
• Landfilling Operations northern half
began within a former paint sludges, solvents, and
of the landfill
borrow pit pesticides
• Excavated material from
the borrow pit provided fill 1980 1985
needed for the construction Operations ceased, JIS placed a cap over the
approximately 50,00 cubic southern half of the
of the New Jersey Turnpike
yards had been disposed of landfill
annually
‘59 -- ‘60 ‘-- ‘77 ‘80 ‘83 ‘86 ‘89 ‘92 ‘95 ‘98 ‘01 ‘04 ‘07 ‘10
1994-1995
2005 2007-2009
Notice letters issued
1982 • Five Year Remedial
RI / FS combined
• Remedial Action
da o Review Report investigation of
Plan submitted completed
l d the Secondary
h d
1990-1992 • Full Scale In- plume
• Proposed to NPL Removal 1997-1998
situ biosparge conducted in
assessment GW monitoring of pilot study 2007,
1989 three wells indicates implemented Completed in
NJDEP requested 1993 - 1994 chemicals of 2008,
1983
that EPA conduct an concern are below addendum
Final listing on NPL
g NJDEP collected
assessment of agency action levels submitted i
b itt d in
data on drinking 2004
groundwater water wells to 2009
• RI / FS
contamination supplement the RI / Negotiations
FS
Remediation History
© 2012 Environmental Risk Communications, Inc. 9

10. Site Conceptual Model (EXAMPLE)
Human Risk: Low 3rd-party Liability Risk: Low
Ecological Risk: Low o ACME Ranch immediately offsite in direction of
o Nothing off-site groundwater flow, but trench intercepts bulk and
o River sediment: Suspect low probability of NRDA stream acts as natural barrier
claim o Aquifer unproductive for residential use
o USFWS (NRDA trustee) studied 7 site: Minimal o No current or pending class action or corrective
d l
contamination found, some control area results action-related litigation or property claims
higher than industrial / municipal reach of river; o No environmental justice issues
no T&E species on South Property
o Prelim. risk assessment indicates no eco risk o Possible legal issues with leased property and/or
drivers on South Property SE NAPL plume
o Ponds: Suspect low probability of NRDA claim
o USFWS collected plant / sediment / tissue
samples: No definitive
© 2012 Environmental Risk Communications, Inc. 10

11. Current Risks (EXAMPLE)
Description Risk Actualization
Potential Likeli-
Source Qualitative Volume / Magnitude Threat Impact
Drivers hood
NAPL Plumes affect ~ 3 million gallons NAPL intrusion into 3rd-party Low Medium, potential
majority of south already pumped; ~ 1 South Brunswick lawsuit property purchases
property; mostly – 8 million gallons and/or more aggressive
contained on site; left; probable that GW treatment
some has been large percentage is
pumped; intra- <= residual Regulatory Low High, aggressive
plume mobility saturation and not driven investigation and
exists in some easily removed with work treatment of GW or
areas; conventional maximize CAMU to
technologies remove smear zones
Ultimate regulatory Long-term Med High, escalation of
clean-up is “non- O&M remedial cost
degradation”
SWMUs & Multiple on Currently 380 million Additional cleanup Regulatory Med High, escalation of
soils property; in process yds3 excavated and required of North & driven remedial cost
of removing and 0-200 million yds3 South properties work
putting in CAMU planned for
excavation; could Dermal contact to Worker / Low Low, full security
range as high as workers and trespasser controls trespass, all
1,300,000 yds3 trespassers; vapors
p ; p exposure
p dust actively controlled
y
during construction
Sediments River and North Estimated volume of Environmental NRDA Low Medium, dredging may
property ponds 200,000 yds3; damage claim be required
USFWS found no
environmental Regulatory Med Medium, reverse
damage at ponds dredging or dredging
may be required
Trespass (river only) 3rd-party Very Medium, damages and
lawsuits low dredging
© 2012 Environmental Risk Communications, Inc. 11

12. Other Significant Risks (EXAMPLE)
Likelihood Cost Expected Range
(%) ($ millions) ($ millions)
Technical Risks
Existing containment requires re-building within 10yrs 5% $5 $0.25
Passive system fails to protect off-site areas 50% $6 $3
River
Ri e sediment clean p requirements
clean-up eq i ements 10-50%
10 50% $0-2.5
$0 2 5 $0-$1.25
$0 $1 25
Non-Technical Risks
SE NAPL Plume liability 0-50% $0-6 $0-3
NRDA d
damages 10% $0-0.3
$ $0-0.03
$
South Brunswick, New Jersey citizen / 3rd party lawsuit 0-10% $0-10 $0-1
© 2012 Environmental Risk Communications, Inc. 12

13. End State Vision (EXAMPLE)
Site in 1960s and 70s
Remediation ESV
 Residential – No potential for future homeowners
to see or smell residual hydrocarbons during
normal homeowner activities (including installing
swimming pools, f fence posts, foundations,
f
piping, landscaping)
 Recreational / Public Open Space and common
areas with administrative and engineering
controls to prevent users and workers from
exposure above acceptable health risk-based
levels during normal use, construction, and
maintenance activities
End State Vision
How do We Get there?
 Generate redevelopment plan by 2015
 Complete environmental compliance activities by
2017
 Market property by 2018
© 2012 Environmental Risk Communications, Inc. 13

14. Evolution of Spending Forecasts –
Graphed with Cumulative Actuals (EXAMPLE)
$120
$110 2011
$100
$90
2010
2009
$80
2008
$
$70
($ MM)
$60 2006
2007
$50
$40 Cumulative
$30
Spending
$20
$10
$0
Cumulative Spend Budget Remaining 2006 2007 2008 2009 2010 2011
© 2012 Environmental Risk Communications, Inc. 14

15. Alternative Strategy Analysis (EXAMPLE)
Regulatory Degree Of Source Regulatory Re- Recovery Of
Disposal Option End-State Vision
Framework Removal opener Costs
Complete
Current Unrestricted
Onsite (RBCA State Only Cash Out
Consent Order Use,
Use Sell
Residual)
Mixed or Non-
Amend Consent + County for
Trucks Pits & Lagoons Residential Co-Pay
Order Groundwater
Use, Sell
Recreational
Consent Decree Truck & Rail RBCA Optimal + EPA Use, Sell /
Donate
Enforcement
Pits Removed,
After Exiting Slurry Line to Eminent
Stabilize the No Sale
State Barge Domain
Rest
Superfund
Aggressive Remediation Strategy
Low Risk Remediation Strategy
EPA led Remediation Strategy
PRP Committee Led Strategy
© 2012 Environmental Risk Communications, Inc. 15

16. Summary of Alternatives (EXAMPLE)
NAPL Endpoint & Attenuation GW Non-Degradation
Non Degradation
Passive Contain and Monitor (1)
Zone (2) Driven Clean-up (3)
Soils Excavate and remove RA identified soils; Same Strategy Same Strategy
place in CAMU
North Property Leachate collection MNA or air sparging,
collection, sparging Same Strategy Same strategy
Remediation
Groundwater and passive soil venting under CAMU
(through 2021); no NAPL issues
South Property Extend wall if needed; switch off trench Switch off trench system; remediate Remediate complete
Groundwater system; demonstrate immobility of NAPL to interim or TI determined endpoint smear zone to endpoint
p
plume; F&T modeling-pilot if needed
; g p using excavation and establish
g such that GW returned to
R
attenuation zone to allow transition MCLs within 50 years
to passive / MNA using NMA
Sediments Ecological risk assessment only Same Strategy Same Strategy
(River / Pond)
Land Use Maintain current zoning (Commercial / Same Strategy Same Strategy
End Use
Industrial); explore potential uses
Risk and Land Sale or lease of property to 3rd party for Sale or lease of property to 3rd party Sale or lease of property
Ownership alternate uses for alternate uses to 3rd party for alternate
uses
Regulatory
Reg lato Obtain VRP remedy decision and
emed Same Reg lato Strategy
Regulatory St ateg Same Reg lato Strategy
Regulatory St ateg
Strategy agreement by 2005
Advocacy
Use current voluntary efforts (i.e., CAMU)
to obtain favorable regulatory outcomes
Community Notify adjacent landowners of Same Strategy Same Strategy
A
Strategy
St t remediation activities
di ti ti iti
Counterparty Monitor fellow PRPs for long term Use escrow accounts to accelerate Monitor fellow PRPs for
Strategy cash call collection and avoid long term
financial monitoring
© 2012 Environmental Risk Communications, Inc. 16

17. Summary of Financial Results: Simplified (EXAMPLE)
FINANCIAL SUMMARY
Case Case Case Case
R 1 2 3
GW Non-
Passive Contain and NAPL Endpoint &
Strategy Description Reserve Case Degradation Driven Notes
Monitor Attenuation Zone
Clean-up
Budgeted costs, inflated,
FUTURE VALUE 5-YR (2011-2015) ($10,373,851)
($10 373 851) ($534,745)
($534 745) ($16,152,056)
($16 152 056) ($10,940,989)
($10 940 989)
undiscounted - 5 years
Budgeted costs, inflated,
FUTURE VALUE 10-YR (2011-2020) ($17,754,275) ($15,048,505) ($24,062,848) ($20,096,002)
undiscounted - 10 years
Budgeted costs, inflated,
FUTURE VALUE 30-YR (2011-2040) ($27,957,759) ($31,923,532) ($34,266,332) ($28,998,297)
undiscounted - 30 years
Budgeted costs, inflated,
PRESENT VALUE 30-YR (2011-2040) ($21,688,188) ($23,188,252) ($27,599,029) ($23,131,890)
discounted - 30 years
Recoveries from all sources,
COST RECOVERIES $6,808,649 $7,800,092 $11,740,109 $7,233,993
inflated, undiscounted
Increases or decreases in
OPERATING BUSINESS IMPACTS $0 $0 $0 $0 operating company profit,
inflated, undiscounted
Net total of budget, recoveries
PROJECT CASH FLOWS NPV ($16,348,461) ($17,473,509) ($18,054,616) ($17,356,012) and operating company impacts;
inflated, discounted
Financial Assumptions: 3.20% In flat io n
2.75% Disc o u n t rat e All values shown are USD
© 2012 Environmental Risk Communications, Inc. 17

18. Scenario Comparison – NPV ($ millions) (EXAMPLE)
Four Campus Alternatives - (Excludes 120 Off-campus Acreage)
Best
tive Probability
Cum
Alt 5c
mulative Fre
EV = $(16.9) MM
Alt 5d
EV = $(20.9) MM
equency
Cumulat
Alt 5a
EV = $(28.9) MM Follow Dashed
Lines to x-Axis
Alt 5b for P50 Values
EV = $(27.3) MM (values shown
on Tornado
diagrams)
© 2012 Environmental Risk Communications, Inc. 18

19. Costs for Preferred Strategy – NPV ($ millions)
(EXAMPLE)
335 Units @ $150 / 335 U it @ $270
Units
SF / SF; 24 of 30
Acres
Residential /
Commercial Residential /
Standards to 5’; No Commercial
CAMU Standards to 1’
; CAMU
Extreme P&T
Design, Build; Simple P&T
30 yr
30-yr O&M Design, Build; 10-
yr O&M
60% of 12 Units
/ Acre; Pad 160% of 12 Units
Ready for 335 / Acre; Pad Ready
Units for 335 Units; 24
of 30 Acres
No Risk
28.5K CY Assessment
Sediment
Removal @
$200/CY; 50% -$47.00 -$37.00 -$27.00 -$17.00 -$7.00 $3.00
Trigger Chance
Alt 5c – Value of Tax Credit, Properly Sale, Development
Alt 5c – Soils, CAMU
P50 = $(19.2) MM Alt 5c – Groundwater
Alt 5c – Infrastructure Construction
Alt 5c – Upstream Sediment, Wetlands and Bank
Sediment
Alt 5c – Land Entitlement
Alt 5c – Stakeholder management
© 2012 Environmental Risk Communications, Inc. 19

20. SWOT Analysis of Preferred Strategy (EXAMPLE)
Strengths Weaknesses
o Better NPV than alternatives o Uncertainty of buyer acceptance
o Qualified buyer identified; has experience with o Data is subjective, based on team’s best
other contaminated properties and can qualify estimates
for
f RCRA permit modification
it difi ti o Buyer is an LLC
o Compatible development plan has been o Includes some residential reuse
presented o Company will be remediating property owned
o Ability to quantify intangible issues by others; no longer controls the property
Opportunities
pp Threats
o Dispose of an orphan site in NY o Possibility town could use eminent domain to
o A site is redeveloped and our public image is condemn or take the property
enhanced o Unable to fulfill our environmental obligations
o Neighborhood may get a sewer line (not on to the agencies and/or the buyer
sewer now) ) o Buyer unable to fulfill obligations to Company
y g p y
or others
o Unable to negotiate less restrictive clean up
levels with Agencies
Key Takeaways
 Important that sale strategy meshes with the environmental assessment knowledge
 It’s very hard to align a remediation plan with a redeveloper’s schedule
 Demolition is important to resale value and implementation of the end state vision
© 2012 Environmental Risk Communications, Inc. 20

21. Decision Sequence (EXAMPLE)
Year 1 Year 2 Year 3
Critical Tasks Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1
70,000 CY
$50 million
$40 million
(driven by
Implementation
stabilization
90,000
90 000 CY
volume)
$50 million
Remediation 30%
Design:
N 110,000 CY
$60 million
Decide
whether
$40 million
to
stabilize
marsh
Y $90 million
110,000 CY
$60 million
area (driven by
Implementation
stabilization
220,000 CY
volume)
$120 million
Ownership
Strategy
St t Define Explore
Decide timing, risk
decision legal
transfers, etc
roles aspects
Cost Access
Recovery impact of
Strategy optimal Finalize cost
remedy on
d recovery strategy
t t
cost
recovery
Preferred Pathway
© 2012 Environmental Risk Communications, Inc. 21

22. Path Forward (EXAMPLE)
 Reserve:
 Current reserve (end of current year): $3.45 million
 Recommended reserve (end of current year): $3.8 million
 Watch List:
 SVE/AS or similar remediation system fails alternative technology necessary: $2.0
fails, $2 0
million by Year 3
 Further characterization offsite reveals hot spot areas above risk assessment limits:
>$1.0 million by Year 2
 Closure costs, not paid by the site operation, such as site security and utilities: >$1.0
million by closure announcement
 Peer Review:
 Within 1 year, complete technical peer review for remedy selection
 Within 2 years, decide property’s end state vision and pace to closure
© 2012 Environmental Risk Communications, Inc. 22