As a result of the newly enacted Site Remediation Reform Act (SRRA), the NJDEP has released draft guidance to assist in the mitigation of Immediate Environmental Concern (IEC) conditions.
The IEC guidance was designed to aid remediators, Licensed Site Remediation Professionals (LSRPs), and environmental consultants in addressing the more common types of IEC conditions. IEC case requirements apply directly to the person responsible for conducting the remediation, while consultants and LSRPs will be communicate with the IEC case manager and provided the Department with necessary information to ensure compliance.
Three categories of IEC conditions have been identified within the guidance:
- Potable Water IEC – A condition wherein contamination associated with a discharge of a hazardous substance at levels at or above the Class II Ground Water Remediation Standards exists in potable wells. Additionally, an IEC condition exists when contamination above federal and state drinking water standards (Maximum Contaminant Levels) is found in surface waters used for public water supplies.
- Vapor Intrusion IEC – A condition exists when a hazardous substance discharge results in indoor air contaminant levels above the Department’s Indoor Air Screening Levels. More rarely, vapor intrusion conditions can occur when harmful or toxic subsurface contaminants have migrated into an occupied or confined space. This intrusion can produce an atmosphere that results in unacceptable human health exposure, an oxygen-deficient atmosphere, or cause physical damage to essential underground services such as phone lines carrying 911 communications.
- Direct Contact IEC – A condition wherein soil contamination exists in the upper two feet of the soil column at concentrations above the acute health effect levels; and there is actual (or a potential for) human contact via dermal contact, ingestion or inhalation.
The IEC guidance identifies two critical components to remediating an IEC condition: receptor control and source control. Both components have specific timeframes that must be adhered to regarding notification, remedial action, and reporting. Both components must be completed in order for an IEC case to be closed.