RMS developed a sampling strategy in cooperation with the NJDEP that allowed our client to forgo the Administrative Consent Order (ACO) process. The client’s site was in Direct Oversight for failure to address contamination identified over 25 years ago during the closure of a gasoline and waste oil underground storage tank (UST). RMS performed an Order of Magnitude Evaluation (OME) to determine which COC present in July 1995 remained above the current NJDEP Soil Remediation Standards (SRS) and default Impact to Groundwater Soil Screening Levels (IGWSSLs). The OME identified historical contamination from volatile organic compounds (VOCs) and polycyclic aromatic hydrocarbons (PAHs) above current remediation standards. RMS used degradation calculations to provide evidence that COC contamination was no longer present at concentrations above the current NJDEP SRS. Results of the degradation evaluation was supported with analysis soil samples collected at specific locations where historic contamination was identified in July 1995. Since the half life of metals is very long, a site-specific IGW SRS was developed for metals whose concentrations exceeded current NJDEP default IGWSSL’s.
- Was able to forgo the ACO process even though site was in Direct Oversight from July 1995.
- Provided evidence that contamination from July 1995 was no longer present on-site
- Was able to issue an AOC specific unrestricted Response Action Outcome (RAO)
- Worked with the NJDEP to reduce penalties
- Soil sampling and analysis
- Order of Magnitude evaluation on historic contamination from July 1995.
- Performed degradation calculations to provide evidence that contamination was no longer present