Achieving Compliance at Contaminated New Jersey Site

Our client’s manufacturing facility is located on a contaminated site in New Jersey that has numerous legacy contamination issues, having been utilized for industrial purposes since the early 20th century and later being sold to a manufacturer in the 1990’s. Various contaminated areas of concern were discovered at the property and remediated to the satisfaction of the NJDEP in accordance with the provisions of the New Jersey Industrial Site Recovery Act (ISRA). When a subsequent business transaction again triggered the provisions of the ISRA, our Licensed Site Remediation Professionals (LSRPs) were hired to perform site assessments, develop a work plan for additional contaminated areas of concern, and carry out the required remedial measures.

Though the previous owner of the property had been responsible for the vast majority of remediation activities on site, our client was responsible for making sure the site maintained compliance on an ongoing basis. As we’ve continued to work with them over the years, there have been occasions that necessitated further remediation. One of these was a release of lubricating oil from a compressor vent after which polynuclear aromatic hydrocarbons (PAHs) were detected in the soil in excess of NJDEP standards. This was cause for a new site investigation to identify levels of known contaminants as well as identify any others, including petroleum hydrocarbons, polychlorinated biphenyls (PCBs), and additional metals.


In addition to fulfilling the client’s public notification and outreach requirement around this event, we worked with a subcontractor to complete all the necessary field remediation activities, which included excavating contaminated soil and disposing it offsite, as well as constructing engineering controls for inaccessible contaminated soils, which would remain in place. We also prepared the required remedial action report documenting all remediation activities and a remedial action permit application for soils for submittal to NJDEP. After the remedial action permit was approved, Woodard & Curran’s LSRP issued an entire site restricted use Response Action Outcome document. Since our initial involvement with this site, one of our LSRPs has provided consulting services for a subsequent discharge to assure remediation is completed in accordance with state regulatory standards by conducting an independent site investigation and assisting with all phases of project management. Having continued to work with this client for several years, we have been additionally responsible for preparing necessary biennial certifications, ensuring the remedial actions continue to be protective of the public and the health and safety of the environment.


New Jersey





Paul Norian, Mark Pietrucha

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