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Toxicology study concluded dioxin compounds, if encapsulated, would not pose a risk to the environment. Asphalt/Concrete composite cap coupled with a Deed Notice which permitted restricted residential use resulted in No Further Action letters. Facility: Regulatory Involvement/Program: New Jersey Department of Environmental Protection (NJDEP)/ Industrial Site Recovery Act (ISRA) The Problem: The site was severely impacted by dioxins, pesticides, heavy metals, carcinogenic PAHs, volatile organic and base neutral compounds. Contaminated media included soil, groundwater, and interior building surfaces. The Solution: Hudson was retained to address the widespread contamination and secure No Further Action (NFA) letters from the NJDEP. Remedial Alternatives Analysis: Building Interior Four options were evaluated: Demolition, scarification (i.e. removal of a thin layer of concrete), steam/pressure wash, and encapsulation. Hudson determined that steam/pressure wash would remove most contaminants and encapsulation would eliminate the slight future exposure risk. Soil A significant area of soil contamination existed (> 2 acres ). Engineering controls to eliminate exposure to the contaminated soil and a Deed Notice (DN) were the only economically feasible alternatives. Groundwater Although soil was severely impacted, groundwater was only minimally contaminated. Establishment of a groundwater Classification Exception Area (CEA) was determined to be the preferred solution.
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Engineering Design: Interior Surfaces A steam/pressure wash was performed on all surfaces. To access high ceilings, Hudson used a mobile lift and moveable scaffolding. All wash water was collected, containerized, and disposed. Cleaned surfaces were painted to encapsulate any remaining contaminants. Soil Hudson reviewed toxicological data to determine if the dioxin concentrations were a significant risk based on EPA established values. Groundwater Statistical analysis of quarterly sampling data was used to generate a groundwater model. Based on the model, for the minimally impacted groundwater, the NJDEP approved a CEA with an indeterminate duration. Remedial Action: Soil An NFA letter was issued by the NJDEP following construction of a Concrete/Asphalt cap and filing the DN allowing limited residential development. Groundwater An NFA letter was issued by the NJDEP following the establishment of the CEA for groundwater within the property boundaries. |
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