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• Completion of an ISRA project in one year even with contamination exceeding 10,000 mg/kg of TPH • Innovative excavation and boring techniques allowed for remediation below supporting foundations resulting in an unrestricted use no further action letter. Facility: Regulatory Involvement/Program: New Jersey Department of Environmental Protection (NJDEP)/ Division of Responsible Party Site Remediation. Knowing the facility was going to be sold in about one year triggering ISRA, we initiated site remediation under the voluntary MOA program to gain a one year head start on the cleanup which was required by the purchaser to be completed for the sale to proceed. The Problem: A thorough preliminary assessment (PA) and site investigation identified seven (7) areas of concern (AOC). Based on the PA, four of the AOCs would require remediation prior to any sale AOC-1 and AOC-2: two previously unknown Underground Storage Tanks (USTs) were identified, one in the building under the floor slab and the other partially under the foundation to a new addition. AOC-3: A drum storage rack was staged over a catch basin thought to drain to the facility's floor drain system. In actuality, the catch basin was a former window well with a soil base. AOC-4: an outside dumpster was used to store metal shavings from tool production. The shavings were coated with cutting oil, which discharged onto the pavement and were released to the environment.
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The Solution: Recognizing the need for site cleanup as a prerequisite for the sale of the facility, Hudson was retained to develop and implement the voluntary cleanup program under an MOA. The goal was to conduct the cleanup in advance of the ISRA triggering action and allow the sale to proceed as scheduled. Remedial Alternatives Analysis: All four AOCs were contaminated with petroleum hydrocarbons in excess of 10,000 mg/kg. Soil excavation and off–site disposal was determined to be the cost effective method. Engineering Design: The excavation at AOC-4 would be straight forward and easily completed. However, AOC-1 and AOC-3 were completely inside the building and AOC-2 was a UST inside the building which extended through the foundation to the exterior public sidewalk. Hudson determined that shoring was needed to allow removal of tanks and soil from below supporting foundation walls. Remedial Action: Holes were saw cut in the floor to allow easy entry by workers into the confined space. The two USTs were opened and cleaned in place. They were then cut into small sections, which were manually lifted through the hole in the floor. The area of the UST below a supporting wall was left in place and shored using steel beams and plates. Contaminated soil was manually excavated. Following the soil cleanup, the excavation areas were filled with concrete slurry to maintain structural support. |
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