The Solution:

Hudson was retained to complete the site investigation in a phased approach under the MOA. Hudson was also retained to mitigate groundwater, soil and/or sediments contamination and to secure the No Further Action (NFA) letter from the NJDEP without the need for a CEA or a DN. Upon an initial groundwater and soils investigation, Hudson determined that lagoon sludge and vadose zone soils were likely contributing to groundwater contamination. Hudson recommended that soils be addressed first, followed by groundwater and sediments.

Remedial Alternatives Analysis:

To effect site cleanup, Hudson evaluated traditional remedies such as groundwater pump and treat systems. However, the need for groundwater cleanup was dependent upon results of soil source area cleanup. All remedial alternatives considered the impact to the active operations at the facility, which must be maintained.

Remedial Action:

Initial phase of site cleanup consisted of removal and off-site disposal of the lagoon sludge as a non-hazardous industrial waste. To define the extent of soil contamination, Hudson will delineate soils adjacent to the lagoon. Hudson recommended and NJDEP has accepted a focused delineation program which will sample and analyze only for constituents previously found in the lagoon above the most restrictive soil cleanup criteria.

Photo of the Lagoon: