New Law in New Jersey for PFNA Sampling Requirements

New Law in NJ for PFNA Sampling Requirements

New Jersey recently promulgated a law with new PFNA sampling requirements.  Below is a summary of this new law:

NJAC 7:10

 The MCL for the State-regulated perfluorinated compound perfluorononanoic acid (PFNA) shall be 0.013 µg/l.  Monitoring requirements for PFNA shall be those established under the National Regulations at 40 CFR 141.24(f) and at (a)7 below, beginning as set forth at (a)5i below and subject to the condition at (a)5ii below.

i.  All public community water systems using a groundwater source(s) serving a population 10,000 or less and public nontransient noncommunity water systems shall begin monitoring within the first quarter of 2019.  All public community water systems using a surface water source(s) and all public community water systems serving a population greater than 10,000 shall begin monitoring within the first quarter of 2020.

ii.  Notwithstanding the threshold set forth at 40 CFR 141.24(f)(11), the requirement for quarterly monitoring at 40 CFR 141.24(f)(11)(i) shall apply if PFNA is detected at a level exceeding 0.002 µg/l.

 Advanced GeoServices can provide sampling for PFNA and supporting engineering services.  If you require PFNA sampling or other engineering support for PFAS projects, contact:

Rick J. Shoyer, LSRP
Senior Project Consultant
856.354.2273

Veronica E. Foster, P.E.
Senior Project Consultant
856.354.2273

Ground Water Remediation Standards for 3 Constituents Revised in NJ

trenton-capitol-building.png

Effective January 16, 2018, the ground water remediation standards for three constituents were revised based on adopted amendments to Ground Water Quality Standards, N.J.A.C. 7:9C, published in the January 16, 2018 edition of the New Jersey Register (see 50 N.J.R. 334(a)). These amendments, in part, replaced the interim specific ground water quality standards with specific ground water quality standards for 23 constituents, including more stringent standards for three of these constituents.  Additionally, Appendix A of the Discharge of Petroleum and Other Hazardous Substances rule (N.J.A.C. 7:1E) was amended to add Perfluorononanoic acid (PFNA) to the List of Hazardous Substances.

  • Caprolactam: The ground water remediation standard decreases from 5,000 micrograms per liter (ug/L) to 4,000 ug/L.
  • 4,6-Dinitro-o-cresol: The ground water remediation standard decreases from 1 ug/L to 0.7 ug/L.
  • 2-Hexanone:  The ground water remediation standard decreases from 300 ug/L to 40 ug/L.

Caprolactam – Caprolactam (CPL) is an organic compound with the formula (CH2)5C(O)NH. This colourless solid is a lactam (a cyclic amide) of caproic acid. Global demand for this compound is approximately 5 million tons per year, and the vast majority is used to make Nylon 6 filament, fiber, and plastics. Caprolactam is the precursor to Nylon 6, a widely used synthetic polymer. CPL is soluble in water.

Dinitro-ortho-cresol (DNOC) is an organic compound with the structural formula CH3C6H2(NO2)2OH. It is a yellow solid that is only slightly soluble in water with no smell. Dinitrocresols are a class of manufactured chemicals that do not occur naturally in the environment. There are 18 different dinitrocresols. The most commercially important dinitrocresol, 4,6-dinitro-o-cresol (DNOC). It is used primarily for insect control and crop protection (Herbicides). It may be sold under several trade names, including Antinonnin, Detal, and Dinitrol.

2-Hexanone (methyl butyl ketone, MBK or propyl acetone ) is a ketone used as a general solvent and in paints. It is a clear, colorless liquid with a sharp odor. It dissolves very easily in water, and can evaporate easily into the air as a vapor. It dissolves cellulose nitrate, vinyl polymers and copolymers, and natural and synthetic resins. It is recommended as a solvent because it is photochemically inactive; however it has a very low safe threshold limit value. 2-Hexanone is absorbed through the lungs, orally and dermally and its metabolite, 2,5-hexanedione, is neurotoxic.

For more information about these changes, contact:

Rick Shoyer, LSRP
Senior Project Consultant
856.354.2273

New Solar Act subsection t application available through New Jersey Board of Public Utilities

New Solar Act subsection t application available through New Jersey Board of Public Utilities

According to a listserv sent from NJDEP on December 19, 2017, “Subsection (t) of the Solar Act provides that "No more than 180 days after [July 23, 2012], the Board of Public Utilities shall, in consultation with the Department of Environmental Protection and the New Jersey Economic Development Authority, and, after notice and opportunity for public comment and public hearing, complete a proceeding to establish a program to provide [Solar Renewable Energy Certificates] to owners of solar electric power generation facility projects located on a brownfield, on an area of historic fill or on a properly closed sanitary landfill facility.”

New Subsection t application

If you have questions regarding the New Solar Act, please contact:

Rick Shoyer, LSRP
Senior Project Professional
856.354.2273

NJDEP Revamps Heating-Oil Tank Systems in proposed rules

heating-oil tank system

On July 17, 2017, the New Jersey Department of Environmental Protection (NJDEP) published proposed rules that included the long-awaited Heating Oil Tank System (HOTS) Remediation Rules (N.J.A.C. 7:26F).  This rule has been rumored to be “right around the corner” for many years.  It was delayed in legal review and overshadowed by the sweeping changes instituted in 2009 with the introduction of the Site Remediation Reform Act and the creation of the Licensed Site Remediation Professional (LSRP) certification.  The HOTS Rules (managed by the NJDEP’s Unregulated Heating Oil Tank, or UHOT, program) pertain to a specific subset of environmental cases in New Jersey.  These include both residential and small (2,000 gallons or less), non-residential heating-oil tank systems, which are unregulated tanks.

The stated objectives of the program are to:

  • Allow pre-qualified professionals to investigate low-risk environmental cases
  • Accelerate the NJDEP review process and reduce the time to closure, especially in cases of residential real estate transactions
  • Re-direct NJDEP resources toward oversight and enforcement of high-risk cases

The “pre-qualified professional” mentioned above can either be an LSRP, or a Subsurface Evaluator (SSE).  The SSE license has been around for a decade.  There are several distinctions between how an LSRP and an SSE can operate on a UHOT/HOTS case:

  • An SSE must obtain NJDEP approval and obtain a No Further Action letter.  An LSRP may “close” a HOTS case without NJDEP approval (but only in cases where the HOTS is part of a larger remediation effort).
  • An SSE needs to be on-site to physically oversee the HOTS investigation and remediation.  An LSRP has the ability to rely on, and certify, work performed by others.
  • An SSE cannot perform an ecological risk assessment.  This is considered a highly specialized task.  If this is required to complete the remediation, an LSRP must be consulted.
  • An SSE cannot institute a traditional Deed Notice.
  • An SSE must be employed by a firm that also has an SSE certification.

Because HOTS cases are considered low-risk, the timeframes that force other cases along in a timely progression do not apply.  Many residential underground tank cases await NJDEP funding, which may take 5 to 7 years to obtain.  The one exception is a timeframe to remove free product; this removes the source material and limits contaminant migration while the property owner waits for funding to be approved.

Other notable changes in the proposed rule include:

  • Under specific conditions, an SSE or LSRP can leave contamination in place by implementing a “HOTS Deed Notice” without NJDEP permit approval, NJDEP fees, or biennial certifications.  However, filing a Deed Notice could still affect the value of the property and the cost of homeowner’s insurance.
  • If the residual contamination under a residential building is estimated to be less than 15 cubic yards, an SSE or LSRP can leave contamination in place by implementing a Small Quantity Exception.  This option does not require a Deed Notice.
  • Removal of the requirement to analyze groundwater for Tentatively Identified Compounds.  This applies to any Site contaminated by No. 2 fuel-oil only, not just HOTS cases.

There are other distinctions between HOTS cases and others that have already been in place, including lighter requirements for Public Notification, Ecological Evaluation, and potable well searches.  All of these aim to give residential property owners more leeway for how they remediate their Sites, and to give them the tools they need once the house is on the market and they’re under a time crunch to get to closing.  The typical time for NJDEP review of a HOTS Remedial Action Report is has been reduced to a matter of weeks by some of the changes implemented by NJDEP over the years.

The changes proposed in the HOTS Rules have knock-on effects that trigger modifications to the Discharges of Petroleum and Other Hazardous Substances rules (N.J.A.C. 7:1E), the New Jersey Pollutant Discharge Elimination System rules (N.J.A.C. 7:14A), the Underground Storage Tank rules (N.J.A.C. 7:14B), the Industrial Site Recovery Act Rules (N.J.A.C. 7:26B), the Administrative Requirements for the Remediation of Contaminated Sites (N.J.A.C. 7:26C), and the Technical Requirements for Site Remediation (N.J.A.C. 7:26E).  To allow for extra opportunity to comment on all of these changes, the NJDEP extended the public comment period until September 29, 2017.  The NJDEP has provided a courtesy copy of the full rule proposal at: http://www.nj.gov/dep/rules/proposals/20170717b.pdf.

For more information on this topic, contact:

Chris Valligny, SSE, LSRP
Project Professional
610-840-9195

Rick Shoyer, LSRP
Senior Project Consultant
856.354.2273

4-Log Virus Inactivation Treatment for Drinking Water Systems

GPM Associates an Advanced GeoServices company

GPM Associates, an Advanced GeoServices company, has successfully designed systems to treat bacteria in drinking water systems, such as E-Coli and Total Coliform.  

GPM Associates recently completed the design and environmental permitting for new 4-Log virus inactivation treatment systems for several Public Community (PC) and Public Non-Community (PNC) water supply systems with groundwater supply wells, using a new chlorination feed system or multi-barrier, validated, ultra-violet (UV) light disinfection system.

virus inactivation treatment for bacteria in water systems

One project example includes the following: At a campground located in northern New Jersey that has its own PNC water supply system, Total Coliform bacteria and E-Coli bacteria were detected in the exisiting groundwater supply wells.  GPM Associates provided professional services to assist the campground with several items, including responding to the New Jersey Department of Environmental Protection’s (NJDEP) Corrective Action Plan to resolve non-compliance issues including E-Coli bacteria contamination, environmental permitting, and full design of new 4-log virus inactivation treatment systems for several wells.  Services also included submitting a Groundwater Protection Plan to the NJDEP and working with the NJDEP, the local county health department, and the client to see the project through to its successful completion.  The system design included using sodium hypochlorite solution feed systems with plug flow contact piping for the groundwater supply wells.  As part of the Corrective Action Plan’s requirements, GPM also assisted the campground with updating water distribution plans, GIS mapping, and completing water and wastewater distribution system evaluations.  Since the camping season was approaching, this project had a tight schedule and GPM was able to provide its professional services to assist the client in getting the new treatment systems online, resolving the bacteria issues, and bring the system back into safe drinking water compliance with NJDEP, prior to the start of the camping season.

To learn more about 4-log virus inactivation treatment systems, please contact:

Rick Shoyer
856.354.2273

NJ Issues Mandatory Cessation of Dry Cleaning Equipment in Residential Buildings

Dry Cleaners to Cease Operations in Residential Buildings

Recently NJDEP issued new regulations regarding perchloro-ethylene ("PERC") and dry cleaners.  The regulatory agency mandated that all dry cleaning equipment located at co-located residential locations to cease operations by December 21, 2020. See 40 CFR Part 63.322(o)(5):

  • After December 21, 2020, the owner or operator shall eliminate any emission of PCE from any dry cleaning system that is located in a building with a residence. In order to comply with these regulations, dry cleaning equipment owners/operators must:

  • Conduct monthly inspections for vapor leaks according to EPA Method 21 if the dry cleaning equipment was installed after December 21, 2005.

  • Eliminate any emission of PCE during the transfer of articles between the washer and the dryer(s) or reclaimer(s).

  • Eliminate any emission of PCE from any dry cleaning system that is installed (including relocation of a used machine) after December 21, 2005, and that is located in a building with a residence.

  • After December 21, 2020, the owner or operator shall eliminate any emission of PCE from any dry cleaning system that is located in a building with a residence.

  • Sources demonstrating compliance under Section 63.320(b)(2)(ii) shall operate the dry cleaning system inside a vapor barrier enclosure and conduct a weekly inspection of the machine components for vapor leaks.

PERC dry cleaning operations have routinely been the source of contamination to soil, groundwater and indoor air at properties located across the country. PERC is a known carcinogen and therefore a highly regulated chemical.  PERC vapors can easily migrate through the ground into the air and affect the air quality of indoor buildings.

Please contact one of our New Jersey offices to discuss your compliance options:

Rick Shoyer, LSRP
856.354.2273

Historic Fill to be Remediated in New Jersey

New Jersey Historic Fill Remediation

There has been many questions regarding how to handle historic fill at remediation sites in New Jersey.  The New Jersey Department of Environmental Protection (NJDEP) has clarified their requirements according to the NJDEP's Site Remediation Program Site Remediation Reform Act (SRRA):

"As currently defined in statute, historic fill meets the definition of a discharge within the Spill Compensation and Control Act (N.J.S.A. 58:10-23.11) and therefore requires remediation. The Brownfield and Contaminated Sites Act (N.J.S.A. 58:10B-1 et seq.) provides a rebuttable presumption that the Department shall not require any person to remove or treat historic fill in order to comply with applicable health risk or environmental standards in 58:10B-12h but it does not alter the requirement to remediate. In these areas engineering and institutional controls are designed to prevent exposure to humans. The Site Remediation Reform Act (N.J.S.A. 58:10C-1 et seq.) exempts reporting historic fill to the Department's Hotline at N.J.S.A. 58:10C-16k but it also does not alter the requirement to remediate." 

"Remediation" can be achieved through institutional (e.g., deed notice) and engineering controls (e.g., asphalt paving).

The NJDEP’s GeoWeb map provides areas where NJDEP has identified as “fill areas”.  This does not automatically mean that these areas have “historic fill” above regulatory standards. 

If you require further clarification on how to handle historic fill at your remediation site, please contact one of our New Jersey offices:

Rick Shoyer, LSRP
856.354.2273

Proposed Rule for Sanitary Landfills

The New Jersey Department of Environmental Protection (NJDEP) recently published a proposed rule pertaining to sanitary landfills in the New Jersey Register.  A summary of NJDEP's proposal is below, courtesy of the Chemistry Council of New Jersey:

Legacy Landfill Law (Law)

sanitary landfill
  • The proposed Legacy Landfill Law establishes requirements and controls applicable to legacy landfills and closed sanitary landfill facilities that accept new materials after closure in order to, for example, prepare the landfill surface for redevelopment.  A legacy landfill is a landfill that ceased operations prior to January 1, 1982, and received for disposal solid waste or waste material that was received for disposal prior to October 21, 1976 that is included within the definition of RCRA hazardous waste.  Part of the jurisdiction of this law is the integration of the Law’s requirements into the existing Solid Waste Rules to address closure/post-closure care and disruption of all sanitary landfills; and
     
  • Extending some requirements of the Law to all sanitary landfills.

Other new technical requirements include the following:

Air Pollution Control

  • Amend these rules to address the hydrogen sulfide emission standard included in the Law

Solid Waste Rules

  1. Clarify the definitions of “contaminated soil”, “clean fill”, and “solid waste” in the Solid Waste and Recycling Rules; DEP is not proposing to change how a generator manages/handles contaminated soil or clean fill
     
  2. NEW definition: Contaminated Soil – “soil, soil-like material, or mixtures of soil with other material containing concentrations of one or more contaminants that exceed the residential direct contact soil remediation standards or non-residential direct contact soil remediation standards, whichever is more stringent, as set forth in N.J.A.C. 7:26D, Remediation Standards”
     
  3. DELETED definition: Clean Fill (in order to avoid the possibility of the same material meeting both the definition of “clean fill” and the new proposed definition of “contaminated soil”); DEP is not proposing to change the definition of “clean fill” under the SRWMP Rules.
     
  4. AMENDED definition: Solid Waste – “any garbage, refuse, sludge, processed or unprocessed mixed construction and demolition debris, including, but not limited to, wallboard, plastic, wood, or metal, or any other waste material, except it shall not include the following…”
     
  5. Solid Waste excludes materials which are defined as “non-water-soluble, non-decomposable, inert solids, such as rock, soil, gravel, concrete, glass, and/or clay or ceramic products that do not contain concentrations of one or more contaminants that exceed the residential direct contact soil remediation standards or non-residential direct contact soil remediation standards, whichever is more stringent, as set forth in N.J.A.C. 7:26D, Remediation Standards”.
     
  6. Currently, a Beneficial Use Determination is required prior to transporting soil that does not exceed SRS off-site for reuse. However, under the proposed rule, if soil has been determined to not exceed the concentration criteria of (new) N.J.A.C. 7:26-1.6(a)6 and is not considered a solid waste, this soil would also be exempt from the requirements of N.J.A.C. 7:26-1.1(a)1ii (Scope of Rules) and N.J.A.C. 7.26-1.7(g)4iv (Exemption from Solid Waste Facility Permitting). In other words, the generator of this soil would not be required to obtain a Beneficial Use approval from DEP.

There is some industry concern that the new definition of “soil” may adversely impact the option of beneficially re-using soils with contaminant concentrations below the threshold outlined in NJAC 7:26-1.6(a)6.   

A public hearing concerning the proposal occurred on Friday, September 23, 2016 at 10:00 A.M.  Written comments are due to NJDEP by October 14, 2016.  

If you would like to learn more about regulatory changes to sanitary landfills or would like to discuss your landfill site, please contact:

Veronica Foster, P.E.
Senior Project Consultant
856.354.2273

NJDEP Recommends New PFOA Limit

NJDEP publishes new recommended PFOA limit

The New Jersey Department of Environmental Protection (NJDEP) has recommended a new maximum level for the chemical PFOA, amid protests from environmentalists and legislators.  This is only a recommendation - there will be a public comment period through the The New Jersey Drinking Water Quality Institute, which recommended the new limit to NJDEP.  

Although NJDEP may alter this recommendation when it publishes its final rule, the new recommended level is 14 parts per trillion (ppt), which is significantly lower than the U.S. Environmental Protection Agency's 70 parts per trillion level and lower than the state's strict level of 40 ppt.

PFOA has long history of being used in such products as stain-resistant clothing, non-stick cookware, and some fire-fighting foams.  PFOA's strong chemical bond makes it desirable for industrial uses but is difficult to metabolize in humans. Long-term exposure can lead to many diseases.  In addition, it's strong chemical bond makes it difficult to break down in the environment.  

Once the public comment period is over, the Water Quality Institute will make a final recommendation to NJDEP, which will in turn set the final level.

For more information on PFOA and water quality standards, please contact:

Rick Shoyer, LSRP
Senior Project Consultant
856.354.2273

How to Remove PFOA and PFOS

How to Remove PFOA and PFOS

The Water Research Foundation (WRF) found that aeration, chlorine dioxide, dissolved air flotation, coagulation, flocculation, sedimentation, granular filtration, and microfiltration were all ineffective for removing PFASs (poly- and perfluoroalkyl substances), including PFOA (perfluorooctanoic acid) and PFOS (perfluorooctanesulfonic acid). Anion exchange was moderately effective in treating PFOA, highly effective for PFOS, and failed to remove several other PFASs. Nanofiltration and reverse osmosis proved to be the most effective methods of removing even the smallest PFASs. Granular activated carbon (GAC) was shown to be adept at removing most PFASs and it may be the average utility’s best bet for PFOA and PFOS contamination.

According to the WRF, PFOA and/or PFOS occurrence has been discovered in 30 states. The WRF advised that any water treatment plant that’s near a chemical manufacturing operation or military base should be on alert for PFASs contamination.

For more information on this topic or to discuss your site needs, contact:

Rick Shoyer, LSRP
856.354.2273

NJDEP Increasing Fees

NJDEP Increasing Fees

Each year the New Jersey Department of Environmental Protection is required to compile its "Annual Site Remediation Reform Act Program Fee Calculation Report," which documents the anticipated fee increases for various items.  As of July 1, 2016 the following fees will increase:

For Annual Remediation Fees, if the invoice sent by the Department is dated:

  • On or before June 30, 2016, the Annual Remediation Fees listed in the June 2015 version of the "Annual Site Remediation Reform Act Program Fee Calculation Report" apply

  • On or after July 1, 2016, the Annual Remediation Fees described in the July 5, 2016 version of the "Annual Site Remediation Reform Act Program Fee Calculation Report" apply

For Remedial Action Permit Annual Fees, if the invoice sent by the Department is dated:

  • On or before June 30, 2016, the Remedial Action Permit Annual Fees listed in the June 2015 version of the "Annual Site Remediation Reform Act Program Fee Calculation Report" apply

  • On or after July 1, 2016, the Remedial Action Permit Annual Fees described in the July 5, 2016 version of the "Annual Site Remediation Reform Act Program Fee Calculation Report" apply

For the Remedial Action Permit Activity Fees, if the permit activity (application, modification, transfer, termination) is administratively complete and is post-marked:

  • On or before June 30, 2016, the Remedial Action Permit Activity Fees listed in the June 2015 version of the "Annual Site Remediation Reform Act Program Fee Calculation Report" apply

  • On or after July 1, 2016, the Remedial Action Permit Activity Fees described in the July 5, 2016 version of the "Annual Site Remediation Reform Act Program Fee Calculation Report" apply

For more information on these fee increases, visit the Annual Site Remediation Reform Act Program Fee Calculation Report webpage.

If you have questions about these fees, please contact:

Rick Shoyer, LSRP
856.354.2273

Chris Valligny, LSRP
610.840.9195
 

Revised Administrative Guidance on Response Action Outcomes

The New Jersey Department of Environmental Protection uses a list serve to communicate to the public with respect to the Site Remediation Reform Act (SRRA).  Below is the latest guidance notification published on the list serve.

The New Jersey Department of Environmental Protection (Department) is announcing the availability of the revised administrative guidance "Issuance of Response Action Outcomes (RAOs)." Since the implementation of the ARRCS rules, the regulated community has provided substantial constructive input regarding the original guidance document, which was posted in May 2011. Some of the updates to the guidance document include:

  • A comprehensive explanation for each section of the document, including the addition of examples and scenarios
  • The application of media-specific situations within the Scope of Remediation section
  • The application of Limited Conveyance 
  • Instructions and use of all Notices
  • Consolidation of Notices regarding Child Care Facilities in one section
  • Addition of a Response Action Outcome Quick Reference Checklist
  • Instructions on amending the language in a Response Action Outcome
  • Instructions on withdrawing a Response Action Outcome

This guidance and a Change Log describing the updates are posted on the Department's website at www.nj.gov/dep/srp/guidance/.

Also as part of this updated guidance, the Department is amending the "Soil Contamination From an Off-Site Source Not Remediated - Diffuse Anthropogenic Pollution" and the "Historically Applied Pesticides Not Addressed" Notices, and making available a new Notice, specific to "Ground Water Contamination due to Regional Historic Fill (Ground Water confirmation sampling has not been conducted)."  These Notices are available on the Department's website at www.nj.gov/dep/srp/regs/arrcs/index.html, under Section E., New Response Action Outcome Notices.

If you have questions regarding the Site Remediation Reform Act or Response Action Outcomes, please contact Rick Shoyer at:

Rick Shoyer, LSRP
rshoyer@advancedgeoservices.com
856.354.2273

Ground Water Quality Standard 1,4-Dioxane; CAS Registry #123-91-1

In accordance with the New Jersey Ground Water Quality Standards rules at N.J.A.C. 7:9C-1.7, the New Jersey Department of Environmental Protection (NJDEP) has developed an interim specific ground water quality criterion of 0.4 μg/L and PQL of 0.1 μg/L for 1,4-Dioxane.  Pursuant to N.J.A.C. 7:9C-1.9 (c), the applicable constituent standard is 0.4 μg/L.  

1,4-Dioxane is used as a solvent, a laboratory reagent and as a trace contaminant in the manufacture of cosmetics.  Its primary use was as a stabilizer of the solvent 1,1,1-Trichloroethane (TCA) (CAS Registry # 71-55-6) and it is often detected in association with TCA.  In the lab, low levels of 1,4-Dioxane is difficult to detect, especially when chlorinated solvents are present.  For the laboratory to obtain the PQL or standard, a separate analytical run is required for low level compounds.

This new interim 1,4-Dioxane standard is an order of magnitude change (over 10 times the previous standard).  The ramifications of this are that all cases within the Site Remediation Program (SRP) are required to re-evaluate whether this new standard constitutes a new compound of concern requiring further investigation, delineation and remediation.
NJDEP has estimated that there are approximately 155 cases in the SRP that have TCA as a compound of concern.  Of these cases, NJDEP estimates less than half may have 1,4-Dioxane present above the standard.  Of these cases, approximately 24 are subject to the May 7, 2016 remedial investigation deadline.

The LSRP should evaluate the laboratory data to determine whether 1,4-Dioxane is reported as not detected with a reporting limit of 4 µg/l or less.  If this data exists, using the 10x rule, further investigation is not required.  If the data does not exist, further investigation is required.  Unfortunately, scientific analysis of the movement of 1,4-Dioxane in groundwater suggests this compound becomes a leading edge of the contaminant plume, moving further and faster than other compounds.  This may result in the need for additional delineation, receptor evaluation and sentinel wells.  This change could also trigger a new evaluation of previously remediated sites or sites at which a permitted engineering control is in place.

For SRP cases subject to the May 7, 2016 deadline this becomes a new unexpected challenge.  LSRPs and the regulated community are requesting that the NJDEP provide relief for special cases involving 1,4-Dioxane.For more information on the NJDEP’s November 25, 2015 revised Interim Ground Water Quality Standards, including 1,4-Dioxane, see:

http://www.nj.gov/dep/srp/regs/gwqs/srwmp_implementing_11-25-15_interim_gwqs.pdf.

If you have questions regarding this standard, please contact:

Rick Shoyer, LSRP
rshoyer@advancedgeoservices.com
856-905-2218

New Jersey Flood Hazard Area Rules/Coastal Zone Management Rules/Stormwater Management Rules

New  Jersey has issued draft rules for public comment.  Comments are due July 31, 2015 with a public hearing on June 22 at NJDEP.  A copy of the rule proposal can be found here: NJDEP Proposed Rule

NJ Rules for Flood Hazard Area - Coastal Zone Management - Stormwater Management

 PS:  Please note - rule package exceeds 900 pages! 

For more information, contact:

Stephen W. Kirschner
skirschner@advancedgeoservices.com
610.840.9117

LSRP "Professional Judgment" - Call for Opinions

Advanced GeoServices’ Rick Shoyer, LSRP, is the Brownfields Coalition of the Northeast’s (BCONE) representative on the NJDEP Site Remediation Advisory Group (NJDEP SRAG). The next NJDEP SRAG meeting is June 10th, which Rick will be attending. The meeting will focus on “LSRP professional judgment”. The ability for LSRP’s to utilize their “professional judgment” is considered by Advanced GeoServices’ LSRPs to be a critical element in the practice of reasonable, cost-effective, and safe remedial investigations and remediations based on site-specific condition. As your LSRP, we are reaching out to our clients and attorneys for the following topics for discussion in the next NJDEP SRAG meeting:

(1)  topics for discussion related to professional judgment, and

(2)  volunteers to lead the panel discussions. 

LSRP "Professional Judgment" - Call for Opinions

The panels will include LSRPs, industry representatives, and attorneys. Please email Rick Shoyer by Monday, April 27 with ideas for the panels, and whether you are interested in participating as a panelist.

Other topics AGC would like your opinions on that are being discussed in various committees:

  • Key issues to be addressed in SRRA 2.0
  • "Should" LSRPA provide a list of member LSRP’s that are willing to be hired as a third party dispute resolution/Arbitrator/Mediator for when LSRP’s do not agree (example buyer/seller issues).
  • Litigation “Safe Harbor” provision to protect LSRP’s from frivolous law suits
  • Virtual Groundwater CEA’s for regional known contaminant plumes.

Thank you and we look forward to hearing from you.

Rick Shoyer, LSRP
rshoyer@advancedgeoservices.com
856.905.2218