The Remediation Process: Publicly Funded Cases
February 22, 2005 (Minor update 18 June 2007)
The Remediation Process: Publicly Funded Cases
(Superfund and Non-Superfund)
Within the New Jersey Department of Environmental Protection (NJDEP),
the Site Remediation and Waste Management Program (SRP) oversees the remediation
of contaminated properties in accordance with our mandate to protect public
health and the environment. The type of cases overseen by SRP range from
the replacement of household fuel tanks to large abandoned industrial
facilities in the center of some of our largest cities. There are also
many rural sites where ground water contamination has raised public health
concerns. These concerns dictate that wells be tested and municipal waterlines
extended to homes if contamination is found.
Overall, sites are either remediated by the party responsible for the contamination, or, in instances where there is no responsible
party, by the state of New Jersey. The remediation process is
slightly different in the two situations. This guidance document describes
cases where there is no responsible party.
The Public Funded Remedial Process
It is important to understand the sequence of events that make up the
remedial process when evaluating the cleanup progress at publicly funded
Superfund and non-Superfund sites. A site consists of one or more subsites
(sometimes referred to as Operable Units at Superfund sites) that represent
individual areas of environmental concern. While a subsite can focus on
any environmental hazard, typical examples include contaminated ground
water, contaminated soil, leaking underground storage tanks, buried drums,
abandoned containers of chemical wastes, off-site potable wells or an
Immediate Environmental Concern (IEC) condition. A subsite may be identified
at the beginning of a site investigation or at any time during the course
of the remedial process additional environmental problems are discovered.
Once a site or subsite has been identified, it undergoes one or more
of the following steps to characterize the extent of the contamination
and/or remediate the environmental or health hazards. The phase of the
remedial process that is underway determines the current status of the
site or subsite. The site or subsite is assigned a Completed status when
all remedial work is finished and the environmental and health hazards
are fully addressed.
A Remedial Investigation and Feasibility Study (RI/FS) is a study conducted
at Superfund sites to determine the nature and extent of the contamination
and evaluate cleanup alternatives. The environmental problems at a site
or subsite are characterized during the Remedial Investigation. The effectiveness,
implementability, timeliness, cost and community concerns associated with
each cleanup alternative are considered during the Feasibility Study.
A Remedial Investigation is also implemented at non- Superfund sites to
determine the nature and extent of the contamination, but a Remedial Action
Selection (RAS) is conducted instead of a Feasibility Study. All publicly
funded actions require an RAS prior to selecting and implementing a cleanup
plan. After selecting a preferred remedial alternative for a publicly
funded Superfund or non-Superfund site based on how well it meets the
stipulated evaluation criteria, NJDEP (or in the case of federal-lead
Superfund sites, USEPA) will hold a public comment period on the proposed
cleanup plan.
A Remedial Design is the development of engineering plans and specifications
to implement the remedy selected in the Feasibility Study or Remedial
Action Selection, such as sizing a ground water treatment plant or developing
an accurate measurement of contaminated soil that must be removed for
off site disposal. Further data collection and analysis may be required
to finalize design specifications.
A Remedial Action (sometimes referred to as a Construction project)
is the implementation of a selected remedy. A Remedial Action may be implemented
immediately after a site is identified, such as removal action at an Immediate
Environmental Concern (IEC) site, as an interim remedial measure while
a site is being investigated, or as a final cleanup measure after a formal
Remedial Design has been completed. A Remedial Action may include, but
is not limited to, the following activities:
- Installation of a ground water treatment system
- Installation of a soil treatment system (i.e., soil flushing or soil
vapor extraction)
- Removal of contaminated soil or drums
- Installation of a landfill cap or slurry wall
- Removal of leaking underground tanks
- Installation of a permanent cover over contaminated soil
- Installation of a ventilation system in a building or other structure
where hazardous vapors are present
- Installation of Point-of-Entry Treatment (POET) systems on private
potable wells
- Demolition of buildings or other structures when needed to facilitate
remediation of the site
- Fencing of a site to prevent access
In addition, extension of water lines to a ground water contamination
area or installation of a treatment system on a contaminated municipal
supply well by a municipality or local water purveyor with funds provided
by NJDEP are also considered Remedial Actions.
NJDEP soil cleanup criteria have been established for many contaminants
to guide unrestricted, limited use and restricted Remedial Actions for
soil. This allows cleanup and reuse of some sites, such as former industrial
complexes, at lower costs, while still protecting human health and the
environment. A Deed Notice (formerly called a Declaration of Environmental
Restriction) is imposed for sites that only comply with the restricted
soil criteria (a limited restricted Remedial Action). It is also imposed
when engineering controls at sites with soil contamination levels that
exceed the restricted criteria adequately protect public health and the
environment (a restricted Remedial Action). This notice ensures the disclosure
of site conditions to future owners and the maintenance of required engineering
controls.
Certain exceptions for contaminated ground water can also be obtained
depending on its use. A Classification Exception Area (CEA) is established
at sites when ground water contaminant levels exceed state ground water
quality criteria, but there is an expectation that over time such standards
will be met.
The state funds 10% of the Remedial Action costs at Superfund sites,
with USEPA providing the rest. NJDEP funds 100% of the Remedial Action
costs at non-Superfund sites. When responsible parties for these sites
are identified, NJDEP brings legal action to recover the expended funds.
Operation and Maintenance (O&M) are performed at sites where long-term
cleanup actions are underway or environmental controls have been installed.
O&M covers a wide range of activities, from overseeing the proper
functioning of a ground water treatment system to cutting the grass on
a landfill cap. O&M may also include the environmental monitoring
conducted to evaluate the effectiveness of a remedial action. One example
of this is the periodic sampling of ground water that is conducted after
a leaking underground storage tank or other source of contamination has
been excavated, or after a plume of contaminated ground water has been
remedied through active treatment. At sites where restricted cleanups
are conducted, O&M may continue indefinitely. The state funds 100%
of O&M costs at Superfund and non-Superfund sites.
Long-Term Remedial Action (LTRA) denotes O&M activities performed
on large scale ground water extraction and treatment plants at Superfund
sites. These treatment plants are projected to run for several years until
ground water cleanup criteria are achieved. For the first 10 years, USEPA
funds 90 percent of LTRA costs and the state provides the remaining 10
percent. After ten years the site is considered in O&M and the state
funds 100 percent of these costs.
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upon in lieu of officially promulgated NJDEP rules and definitions
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