Randolph Allowing Restricted Chemicals on Land Beside the Black River

by Brian T. Lynch, MSW

There is an environmental question facing the residents of Randolph Township, It should be a matter of concern to everyone who draws their water from the valley where the Black River flows. The question arises because Randolph officials granted permission for a chemical manufacturing company to open its new plant in the township’s most environmentally sensitive location.

The question: Is it wise to manufacture thousands of tons of chemical cleaning products at a facility located 460 yards from Black River and less than a mile from commercial wells where thousands get their drink water?

This glacier valley runs from Kenvil to Hunterdon County and is a main artery for fresh water, open space, and aquatic habitat. Between wells and reservoirs along the way, it serves farmlands and over two million New Jersey residents. In addition to the Lamington River (Black River), billions of gallons of groundwater travels under the valley in an underground river.

A California based chemical company, ECOS, wants to expand its production of environmentally friendly cleaning products. It hopes to lease a 165,000 square foot building with 60 docking bays in the Morris Business Park located at 1578 Sussex Turnpike (Block 5, lot 8). Schindler Elevator is among the tenants in this industrial complex. The complex shares its southern boundary with Morris County’s Alamatong Wellfielde. To the East is a steep, mostly wooded climb up a steep ridge. This area is recognized as a groundwater recharge area. There are pockets of wetlands  surrounding the property including two small Lamington tributaries that carry water to the river. The western edge of the property is on the edge of the river’s flood plain.

The property owner and landlord is the Silverman Group, a national, privately owned and operated private equity and real estate development organization based in Basking Ridge, New Jersey. It oversees Morris Business Park, one of many commercial and industrial properties it owns in 21 states.

Because of its environmentally sensitive location, this Silverman industrial property has strict zoning restriction that lists nine permitted uses. None of the permitted zoning uses expressly allows chemical manufacturing on this site. Additionally, within the wording of Ordinance §15-33.2(A)(4), is language that prohibits the warehousing, or storage, of goods or products that carry any NFPA rating higher than (1). 

What does that mean? It means any chemicals that carries a moderate to high exposure risk to human health or safety is not permitted to be stored on this site. (see sidebar)

The ECOS operation, if permitted, would involve shipping in, storing, and “blending” very large quantities of various chemicals.

Based on my own review of just six of over 120 products made by ECOS, at least 38 different chemicals are needed. Most of these ingredients have language in their respective “Safety Data Sheets” (SDS) that warn against release of the chemical into the environment. Two of the chemical are listed as harmful to aquatic life or the environment if accidentally leaked into storm drains groundwater or water features. [See Appendix A]

But, do any of these chemicals carry a NFPA warning of moderate health risks of (2) or higher?

 
Yes. It appears that 23 of the 38 chemicals used in the six ECOS cleaning products surveyed have a NFPA rating of (2) or above. This means that without a zoning variance or a waver of some type, ECOS should not be allowed to manufacture cleaning products within this industrial complex. The Silverman Group filed with the Randolph Township Board of Adjustment (RTBA) for zoning variances and an interpretation of the municipal ordinances that apply to the site.

ZONING VARIANCE STATUS: GRANTED!

The initial RTBA public hearing on the Silverman Group’s request for variances was held on September 11, 2025. It was clarified that this hearing by the RTBA was for an interpretation of the applicable zoning ordinances. The Board determined that the proposed use is not permitted by municipal zoning statutes, so the application was scheduled for a variance hearing to be heard on September 25th.

On September 25th, RTBA held a public hearing, This time, “The application [was] for a use variance for environmentally friendly cleaning products,” according to the minutes. Ms. Jena Arkin, a chemist with ECOS, explained how “the detergent is made from food-grade ingredient.” 

Charles Heydt, PP, was recognized as an expert and testified. He noted that, “the site is particularly suitable for this industrial zone… that the company's closed system operates effectively, making it a good fit for the site… and there will be no discharge of any manufacturing by-products, with no impacts to the stormwater.” The only chemical ingredient discussed by the board was Ethenol. A discription by Ms. Arkin as to how this flammable chemical would be handled withing the facility was satisfactory to the Board.  

After satisfying the Board on the company’s plans for safe handling of ethanol used in its hand sanitizer, assuring the Board that its safe, “closed systems” of production allows no chemical waste products or wastewater to exit the building, and the RTBA deciding that ECOS is not a warehousing operation that stores chemicals, the use variance was approved. No discussions of any other chemicals were discussed according to the minutes.

During Ms. Arkin testimony, she said the chemical shipments to the plant would be about five deliveries per shift with two shifts per day. That equals ten deliveries per day to a building with 60 docking bays, as is called for in the plans. Each tractor-trailer holds between 10 and 15 tons of cargo. A conservative estimate, based on a five day per week operation and 10 tons per delivery, is that the Randolph Townships Board of Adjustment is waving in 500 tons of unidentified chemicals per week to this environmentally sensitive location for a manufacturing operation that is not specifically allowed under the current zoning. 

The decision of the Board is based on a point in time picture of ECOS manufacturing. No one can predict what changes in products, chemicals, procedures, natural disasters, or ownership changes there may be over the next 50 years. 

Fifty years is a blink of an eye in geologic time. It is even brief in human terms. If you have or know any young adults in college, based on present expected operations, 1.3 million tons of potentially harmful chemicals will be shipped in and out of the ECOS plant in their lifetime. This is more than enough time for a "black swan" event to happen. 

Pictured on the left are the cargo ports on one side of the building where ECOS hopes to house its manufacturing plant. Half of the paved surface slopes towards the building and the drainage grates seen here. Stormwater from the roof also flows into this drainage channel. The water collected here empties into the field and treeline in the background, then into the Black River.

Is this variance consistent with the values and expectations of Randolph residents and their representatives?  If not, consider contacting the Randolph NJ Clear Water Coalition, a recently formed organization and Facebook Page dedicated to the reconsideration of this Board of Adjustment decision. The time to voice your opinion is running short.

                        A SACRED VALLEY – (My opinion)

This is a picture I took of the vicinity near the commercial wells of the Alamatong Wellfield where water is drawn every day for residents of Randolph and Mine Hill. It is a spot upstream from the Ironia Bridge and Lake Lillian. It is a place of breathtaking beauty and peaceful solace. It is not a place that most people who drink this water will ever experience. That is too bad. It is very hard to appreciate what we cannot see, hear, or touch. But if you spend any time at this spot, your inner biological senses will tell you that this is a sacred place.

We all have our daily rituals. This time of year, mine usually begins by nudging up the thermostat and drawing water from the kitchen sink for morning coffee. It’s a familiar and important routine that start my day. In fact, it is a ritual carried over from my ancestors who started their day by rekindling the fire with wood they split from a tree they cut down, and lowering a wooden bucket into a hand-dug well for water. The difference between their daily rituals and mine is that they touched the earth directly for warmth and water. We do not. Most of us rarely consider from where our water is drawn.

My water source in Mine Hill is also the Alamatong Wellfield. Having visited it in person,

 and the idea of what is being planned doesn't sit well with me. Any feature of nature capable of supporting habitats teaming with life as well as two-million people is worthy of veneration and respect. I can only hope the residents and officials of Randolph feel the same way.  It's not worth the risk.

Appendex A

After reviewing all the chemicals that go into make 6 of 120 products manufactured by ECOS, the following table lists all the chemical ingredients with an NFPA rating of (2) or higher. These are a;; chemicals specifically prohibited from being stored on the Morris Business Park property by a zoning ordinance. The Randolph Township Board of Adjustment’s variance allows these, and other potentially harmful chemicals, to be shipped and stored for use in the proposed ECOS manufacturing plant. The six products reviewed are:

Laundry Detergent Sheets – Free & Clear, Laundry Detergent Sheets – Lavender Vanilla, ECOS Dishwasher Detergent Packs, Foaming Dish Soap – Free & Clear, Pet Stain & Odor Remover, and Bathroom Cleaner – Tea Tree.