ISRA Investigation and Remediation at Former Paint Manufacturing Facility in New Jersey

Project Challenges

The seller of an 11-acre former paint manufacturing facility that ceased operations in 1995 engaged TRC for the environmental cleanup. TRC was retained to do a preliminary assessment (PA) per the Industrial Site Recovery Act (ISRA) to investigate 39 environmental Areas of Concern (AOCs) pursuant to the New Jersey Department of Environmental Protection (NJDEP) regulations and technical guidance, and issue a sitewide Restricted-Use Response Action Outcome (RAO-E) under the NJDEP’s Licensed Site Remediation Professional (LSRP) program.

During the NJDEP review period for the ground water Remedial Action Permit (RAP) application, new remediation standards were promulgated for several per- and polyfluoroalkyl substances (PFAS) that were potentially used at this facility.

TRC’s Solutions

TRC researched specific PFAS applications in paint manufacturing, evaluated the former operations at the facility to determine which processes and process areas were potential sources of PFAS, reviewed the previously completed site investigation to determine where there were potential discharges, and implemented a focused PFAS and background investigation to demonstrate these substances were not discharged to the environment at the Site.

The final environmental remediation reports had already been submitted to the regulators at the time that PFAS remediation standards were adopted. TRC documented the PFAS evaluation and investigation via a compliance assessment memorandum rather than by rescinding and re-issuing the final reports and RAP application, which would have caused the remediating party to miss regulatory deadlines. The NJDEP reviewed this memorandum and did not require additional action on the part of the party responsible for the cleanup of this site.

Client Benefits

TRC remediated all environmental issues, including assessment of PFAS during the final remediation approval period, in the NJDEP allotted timeframes, allowing the client and the current property owner to conclude their remediation agreement. This is a completed ISRA investigation and remediation project. The property is now being used for a variety of retail and non-industrial commercial businesses.

Project Location: New Jersey

Completion Date: 2020