Anne Hayton NJDEP

Transcription

1 Anne Hayton NJDEP

2 Investigating Impacts from Contaminated Sites to Surface Water Issued by Site Remediation Program on Nov. 25, Background Purpose Key Concepts Remedial Decision Process Available Resources 2

3 Background Publicly-Funded or Agency Lead Projects CERCLA* (Superfund)à Result in Records of Decision (RODs) Privately-Funded Projects Licensed Site Remediation Program àresult in Response Action Outcomes (RAOs) *Comprehensive, Environmental Response and Cleanup Liability Act,

4 Purpose Recognized confusion by regulated community and Licensed Site Remediation Professionals (LSRPs) regarding responsibilities for off-site impacts to Surface Water Identified the need to clarify that NJDEP Technical Requirements for Site Remediation, N.J.A.C. 7:26E, apply to every site even when - industrial/developed environment - delineation will overlap with other projects - surface water is part of CERCLA study 4

5 NJDEP Technical Requirements for Site Remediation, N.J.A.C. 7:26E Subchapter 1.16, Ecological Receptor Evaluation If yes to Eco Receptors AND Site Data > ECS à SI needed If no to both à no further investigation needed Subchapter 3.6, Site Investigation (SI) for Surface Water and Sediment Subchapter 4.8, Remedial Investigation (RI) for Surface Water and Sediments Subchapter 5.1e, Remedial Action Requirements for free and residual product 5

6 The Investigations (N.J.A.C. 7:26E-3.6 and 4.8) Investigation Goals: Determine if site-related contamination has reached surface water and the extent of impact. Complete contaminant delineation in sediment and surface water Characterize background conditions Conduct Ecological Risk Assessment (ERA), if needed, for site-specific remediation goals 6

7 Compare site data to: Decision Process NJDEP Ecological Screening Criteria (ESC) Site-Specific Preliminary Remediation Goals (PRGs) Background and Regional conditions If contaminant concentrations in surface water and/or sediment are greater than ESC or PRGs, and Background conditions: à Remedial Action Alternatives need to be considered 7

8 Complicating Factors Waterbodies in highly developed and industrialized areas Existing Legacy contamination from multiple sources (historical discharge impacts) Tidal conditions Existing CERCLA or RCRA* jurisdiction *Resource Conservation and Recovery Act (1976) 8

9 Recommended Approach Obtain information on surrounding conditions à Review files at NJDEP and USEPA à Seek existing data from other entities performing remedial work, such as Responsible parties, LSRPs and State and Federal representatives. à Seek existing information from academia and other institutions which may have performed relevant studies 9

10 Recommended Approach Evaluate site-specific data in context of other information on surface water of interest à Background and/or regional conditions à Request a Technical Consultation with NJDEP-BEERA à Coordinate with other entities performing remedial investigations/remedial actions nearby 10

11 Overlap with CERCLA Project If site-related discharge overlaps with a CERCLA waterway: à Coordinate closely with USEPA, and NJDEP as support agency, during site evaluation process à Develop remedial approach in concert with the CERCLA project: CERCLA remedy may address issue Or Additional remedial action to supplement the planned CERCLA remedy may be needed. 11

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15 Available Resources NJDEP Ecological Evaluation Technical Guidance, Feb NJDEP Characterization of Contaminated Ground Water Discharge to Surface Water Technical Guidance, Jan Information from other entities involved with nearby remedial activities (e.g., other LRSPs, NJDEP, USEPA, USACE, USFWS) Enlist services of subcontractor specializing in ecological evaluations and risk assessments Technical Consultation with NJDEP-Site Remediation Program Lines of evidence approach and professional judgement 15

16 Available Resources (continued) To locate CERCLA/Superfund Sites in New Jersey To locate remedial work performed by others: NJ GeoWeb: 16

17 Conclusion The delineation of site-related contamination to surface water is an important part of a completed remedial investigation per State Regulations N.J.A.C 7:26E. This requirement applies to situations even when there may be overlap with other sites and overlap with a CERCLA waterway investigation. 17

18 Questions?