Location: Middlesex, New Jersey

Regulatory Program: RCRA Corrective Action

Duration: September 2001 to Present

Summary: Streamlined Corrective Action project and Environmental Indicators assessment, making full use of existing data from adjacent site investigations.

Princeton Geoscience was hired to implement RCRA Corrective Action requirements at this active chemical recycling facility, pursuant to a RCRA Hazardous and Solid Waste Amendments (HSWA) permit issued by USEPA.  The facility occupies four acres in a highly industrialized area.  Site operations began in 1968, and have focused primarily on solvent recycling and blending of fuels for use in cement kilns.  Additional activities performed during recent years include sale of virgin solvents and the repackaging and recycling of lab pack wastes.  The facility handles much of the industrial hazardous waste produced in the northeast, and is New Jersey’s largest Large Quantity Generator under the RCRA program.  Based upon several short site inspections and limited sampling conducted previously at the site, USEPA identified six Solid Waste Management Units and three Areas of Concern (AOCs).  The HSWA permit required the client to conduct multiple phases of field investigation and remedial assessment, including a Release Assessment (RA), a multi-phased RCRA Facility Investigation (RFI) and a Corrective Measures Study.  For each of these work phases, the permit required submittal of draft and final copies of detailed work plans and reports.

As an initial activity, Princeton Geoscience compiled an extended project schedule which incorporated timelines for all project activities required under the permit, including work plan development, coordination with subcontractors, field activities, laboratory analyses, report preparation and regulatory review.  Based on the schedule, it became evident that over two years would elapse before the extent of contamination in the shallow “perched zone” aquifer would be determined.  This protraction of the schedule was associated mainly with the requirement to submit and revise cumbersome workplans before completing any work onsite, but the structuring of the work into artificially distinct phases and work areas also would have caused delay.  In addition, the delay would have been inconsistent with the RCRA Cleanup Reforms of 1999 and 2001, which are intended to speed the achievement of project goals by focusing on results rather than procedures, and by eliminating barriers to application of innovative and common sense solutions.  Therefore, Princeton Geoscience proposed an alternate, streamlined approach to expedite the site characterization, which was accepted by USEPA and NJDEP.

Under the revised approach for the site characterization, the RA and RFI for soil and perched zone groundwater have been combined into a single phase of work (RFI Phase 1) and the investigation is taking place in a site-wide, rather than area- by- area, basis.  In addition, Princeton Geoscience prepared and submitted an abbreviated workplan to USEPA and NJDEP and no revisions to the document have been required.  An informal and efficient practice of regularly communicating project findings and obtaining input from the USEPA and NJDEP case management teams has been established, greatly expediting the process and reducing costs.

Within two months of submitting the abbreviated workplan, a detailed chemical and stratigraphic characterization of soil and perched zone groundwater was completed onsite.  This included collection of a total of 70 soil samples and 30 groundwater samples from a total of 33 direct-push (i.e., Geoprobe®) borings onsite.  This investigation identified extensive chlorinated and non-chlorinated volatile organic compound (VOC) contamination in soil and groundwater beneath the concrete surface containment, consistent with historical use of the site as a solvent recycling facility since the 1960s.  Within three months of receiving analytical results for the onsite work, a supplemental offsite investigation was completed which accomplished horizontal delineation of site-related VOC contamination in the perched zone aquifer and provided the basis for the selection of appropriate locations for the installation of  permanent monitoring wells onsite and at selected locations offsite. 

Another factor that has significantly benefited the project is the site’s location in a heavily industrialized area and the proximity of numerous sites undergoing environmental investigation and/or remediation.  Princeton Geoscience performed NJDEP file reviews for 14 nearby sites listed on NJDEP’s Known Contaminated Sites List, obtaining a great deal of directly relevant information which is being used to satisfy Corrective Action requirements.  Examples of information obtained during the file reviews include:

·   Identification of an existing network of offsite monitoring wells in the perched zone and bedrock aquifers, which will be used during the RFI and subsequent monitoring

·   Voluminous hydrogeologic characterization data (e.g., records of pumping tests, rock coring, geophysical logging, soil coring, hydraulic monitoring, capture zone analyses, etc.) which support the need for limited, if any, additional such work onsite

·   Results of numerous well searches, water supply evaluations, ecological assessments

In addition, Princeton Geoscience identified details of a proposed remedy for pesticide groundwater contamination originating on the property immediately upgradient of the site during the file searches.  This information has relevance to future remedies that may be implemented onsite.  Specifically, contaminant plumes originating on the upgradient property and on the site are co-mingled and combined efforts for remediation may be appropriate.  The upgradient property owner has determined that the current operation of a production well by the client achieves hydraulic control of pesticide-impacted groundwater originating upgradient of the site, and has proposed that our client’s continued operation of the well should serve as a remedy for groundwater contamination in the bedrock aquifer.  The same property owner has proposed to install a remedial system downgradient of the site, to treat pesticide-contaminated groundwater in the perched zone.  The processes envisioned for the perched zone and bedrock aquifers would very likely also be effective in treating volatile organic compound (VOC) contamination emanating from the site.

Other activities completed to date under the RFI Phase 1 have included packer testing and geophysical logging of the site production well during a shutdown period when the well pump was replaced, a well search and water supply survey (receptor evaluation), preliminary work for an evaluation of indoor air quality, and the assessment of the extent of onsite impacts resulting from past pesticide manufacturing on the adjacent property.  Tasks remaining to be completed during RFI Phase 1 include installation of perched zone monitoring wells at nine locations onsite and at two offsite locations, sampling groundwater and monitoring groundwater elevations in the expanded monitoring well network and monitoring surface water elevations at six existing staff gage locations.  Current plans call for preparation of an RFI Phase 1 Report detailing findings of the perched zone groundwater investigations.  Based on the working relationship developed with the regulatory case management teams, it may be possible to combine reporting of RFI Phase 1 results with those for RFI Phase 2, which will evaluate conditions in the bedrock aquifer.  Combined reporting for the two investigative phases would significantly reduce both the duration and cost of the project.

Following such an approach will also facilitate the client’s plan to demonstrate achievement of goals for Environmental Indicators (EIs) by 2005.  EIs are measures developed by USEPA pursuant to the Government Performance and Results Act of 1993, to gauge the progress being made to control contamination at corrective action sites.  Two EIs have been developed to date.  The Human Exposure EI determines whether contamination has been controlled so that it does not pose a danger to people, and the Groundwater EI determines whether contaminant migration in groundwater has been controlled.  One of  USEPA’s goals is that by 2005, 95% of the 1,714 high-priority RCRA cleanups being undertaken now (of which this site is one) will have human exposures under control, and that 70% of them will have contaminated groundwater under control.  Substantial progress toward demonstrating achievement of the Human Exposure EI has been made through completion of the well search and water supply survey, which indicated no evidence of potable groundwater use in the area of the site.  Significant additional work will be required to confirm other potential exposure pathways are not complete (i.e., indoor air evaluation) and to complete the assessment for the Groundwater EI.  Therefore, elimination of non-essential administrative steps in the remedial process will be crucial as the project moves forward.