Formatted Title
Case Study of a Successful Brownfields Remediation Project at a Former Manufacturing Facility
Background/Objectives
The General Engines Company (General Engines) operated a manufacturing facility in West Deptford, New Jersey. The manufacturing operation consisted of assembly of trailers for transport of construction equipment. General Engines purchased the adjacent property Lot 6 (Neely Property) in 1985 in anticipation of expanding the existing operations; however, a decision was made to cease operations at this location and the Neely property was never used as part of the active operation. The cessation of operations triggered the Environmental Cleanup Responsibility Act (ECRA) was triggered and under the Industrial Site Recovery Act (ISRA) a Preliminary Assessment/Site Investigation (PA/SI) was completed for both Lots 6 and 7 as required by the New Jersey Department of Environmental Protection (NJDEP). Based upon the results of the PA/SI, 22 areas of environmental concern (AOCs) were identified across the property. The AOCs identified included the Neely Property at Lot 6. During the PA/SI, the former Neely property was identified as a former drum reconditioning facility that handled wastes not associated with the General Engines operation. In addition, buried drums from the reconditioning operation were discovered on the property and were remediated. The primary constituent of concern associated with the Neely property was the chlorinated solvent trichloroethene (TCE). In addition, a portion of the Lot 7 property was leased to GAF. GAF disposed of waste materials on the southwestern portion of the property. GAF disposed of solid waste as well as fibrous asbestos in this area. The objective of this project was to remediate the AOCs effectively to facilitate sale of the property and development as a Brownfields property. The site was located adjacent to a major New Jersey interstate exit which provided optimum access for commercial/industrial logistics operations.
Approach/Activities
Various phases of remedial activities were conducted on the Neely property including excavation and disposal of drums and contaminated soils. The 22 AOCs at the property were successfully remediated under a Memorandum of Agreement (MOA) with NJDEP. Three AOCs were addressed through institutional controls of a deed notice including a clean soil cap to address surface soil impacts. The onsite solid waste landfill was closed in accordance with NJDEP Solid Waste regulations. Groundwater at the General Engines site has been impacted only by TCE associated with the former Neely property operations. The reductive dechlorination natural remediation process, by which indigenous bacteria degrade chlorinated solvents under anaerobic conditions, is ongoing and active throughout the dissolved plume. An extensive groundwater monitoring program has been conducted as part of the approved natural attenuation remedy for the past 25 years. Based upon the results of the groundwater monitoring program, due to natural attenuation and source removal, the extent of the contaminant plume as well as the magnitude of concentrations in the former source area have decreased significantly. General Engines, in a proactive move to attempt to enhance the ongoing natural attenuation process, retained AECOM to implement a 3-D Microemulsion™ (3DMe) grid injection program. The injection resulted in reduced concentrations in the area by an order of magnitude and overall decreasing concentration trends continue to be evident. NJDEP pursued natural resources damages for the site that were settled by the responsible party. In 2018, NJDEP issued a groundwater natural attenuation remedial action permit (RAP) and a soil RAP for the three AOCs addressed by institutional controls (deed notice) with monitoring and maintenance requirements. The issuance of these RAPs resulted in a Restricted Use Response Action Outcome (RAO) being issued for the entire site. The RAO is essentially an equivalent to a conditional no further action from the NJDEP under New Jersey’s Licensed Site Remediation Professional Program.
Results/Lessons Learned
The issuance of the entire site RAO facilitated sale of the property to a Brownfields developer that has successfully developed the site into a warehouse logistics facility. The RAPs are being maintained jointly by the new property owner and the responsible party. This case study demonstrates how properties with significant soil and groundwater impacts can be effectively remediated to result in productive/profitable Brownfields development.