About Jenny Cutright

“Be the change you wish to see in the world” Mahatma Ghandi
Jen holds a BS in Chemistry from the University of Minnesota and an MS in Environmental Policy from Drexel University. She has been with REPSG since April 2006. In evaluation of environmental conditions, she has designed environmental monitoring and remediation strategies appropriate to the level of identified environmental risk and has participated in Phase I and Phase II Environmental Site Assessments, Regulatory Site/Remedial Investigations in Pennsylvania, New Jersey, Maryland and Delaware and Brownfields redevelopment projects in New Jersey and Delaware. She also develops advanced data acquisition, management and mapping techniques used for environmental analysis. Jen likes to run and bake. The more she runs the more she can bake.

Stop Chasing Contamination: DEP Implements Compliance Averaging Guidance

NJDEP SRP LogoOn September 24, 2012 the NJDEP finalized the Technical Guidance for the Attainment of Remediation Standards and Site-Specific Criteria. The new Guidance provides helpful information for applying appropriate remediation criteria and determining compliance. However, the standout piece of information is that compliance averaging, like the use of 95 percent upper confidence limit of the mean (95 UCL) and 75%/10x, can now apply to Sites in New Jersey. These compliance options have been accepted by the PADEP for years, and REPSG has applied these statistical strategies at many Sites in Pennsylvania.

HOW DOES THIS IMPACT YOUR NEW JERSEY REMEDIATION?

75%/10x is a useful statistical analysis strategy for remediation involving point-source impacts, like underground storage tanks or small spills. As long as the specified number of samples is collected and the analytical results of 75% of those samples are compliant with the remediation standard, the soils under investigation are in compliance. This approach can eliminate the need to chase low-level contamination that can sometimes persist after the removal of a heating oil tank; for example, in the case of benzo(a)pyrene and number 4 fuel oil.

95 UCL is another helpful statistical analysis strategy that can now be utilized at Sites in NJ. This method identifies uniform contamination and estimates the average concentration at the 95 UCL. If the average concentration is below the remediation standard, the associated soils are compliant; even some samples within the dataset have concentrations above the remediation standard.

Do you think that compliance averaging could help speed up remediation at your Site? REPSG can apply our statistical experience to your New Jersey projects. Leave a comment below or please feel free to contact me at jcutright@repsg.com.

An Introduction to Vapor Intrusion Investigations in New Jersey

 For the New Jersey Department of Environmental Protection (NJDEP), 2012 has been a banner year. Here at REPSG, we have really had to stay on our toes to ensure that allNew Jerseysites are adhering to current regulatory guidance, form submittal requirements, and rules.

In January 2012, the new Vapor Intrusion Technical Guidance was finalized, providing lots of new details for the investigation of vapor intrusion into indoor air. Additionally, the Technical Requirements for Site Remediation (7:26E) was finalized in May 2012, providing the last word in receptor evaluation of populations being potentially impacted by harmful vapors. Now that all of the changes have been finalized, Suzanne Shourds and I plan to tackle the topic of vapor intrusion in an upcoming series of blog articles. We will be discussing the ins and outs of vapor intrusion as well as our own experiences with sites in New Jersey that have addressed potential vapor intrusion. These posts will cover vapor intrusion screening levels, receptor evaluations, the stages of a vapor intrusion investigation (groundwater, soil gas, and indoor air), mitigation, and the special requirements associated with Immediate Environmental Concerns and Vapor Concerns.ew Jersey Department of Environmental Protection (NJDEP), 2012 has been a banner year. Here at REPSG, we have really had to stay on our toes to ensure that all New Jersey sites are adhering to current regulatory guidance, form submittal requirements, and rules.

To get things started, let’s take a look at Vapor Intrusion Investigation Triggers, Screening Levels, and Receptor Evaluation (Stage 1).

When conducting a Site Investigation, the first step to take to address potential vapor intrusion is to identify a source, as well as a potential pathway (typically impacted groundwater) and possible receptors. Identification of all these components triggers the need for a Vapor Intrusion Investigation (Stage 2), addressed in the next blog post on this topic).

Once impacted groundwater with concentrations above the NJDEP’s Groundwater Vapor Intrusion Screening Levels is identified and delineated, all buildings (homes, apartments, commercial spaces, warehouses) and structures (garages, utility vaults, sheds) within 30 feet of petroleum-based impacts (including free product) and/or within 100 feet of non-petroleum-based groundwater impacts (including free product) must be considered potential receptors of vapor intrusion impacts and incorporated into the investigation.       A receptor must be present in order for there to be a potential vapor intrusion concern. This includes consideration of future receptors. Once the trigger is identified, the property owner has 150 days to conduct sampling of the identified receptors. Prior to conducting this sampling, all receptors must be characterized to identify building or structure use, size, and details (such as the presence of a basement).

Additional site triggers for a vapor investigation include: soil gas or indoor air data above Vapor Intrusion Screening Levels, a wet basement or sump containing free product or groundwater impacted with volatile compounds, methane-generating conditions, any other situation threatening health and safety that is related to vapor/indoor air.

Have a question about vapor intrusion investigation triggers? Leave a comment below or please feel free to contact me at jcutright@repsg.com. Please check back soon for our follow up article on Stage 2: Vapor Intrusion Investigation.

UPDATE: NJDEP Remedial Priority Scoring

We have another update on our previous post on the NJDEP’s Remedial Priority Scoring System.  The NJDEP has, again, extended the deadline for submission of data on the RPS Feedback Form. The new submission deadline is September 30, 2012. This provides Persons Responsible for Conducting Remediation and associated LSRPs with more time to update Site information that could impact the RPS score.

If you have any questions, feel free to post them in the comments section below or email me at jcutright@repsg.com.

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Original Update: 7/19/12

NJDEP LogoWe have an update on our previous post on the NJDEP’s Remedial Priority Scoring System.  The NJDEP has extended the deadline for submission of data on the RPS Feedback Form to August 31, 2012. This provides more time to update the X and Y Site coordinates, extent areas for soil and groundwater, pathway information, and missing or rejected Electronic Data Deliverables (EDDs).

If you have any questions, feel free to post them in the comments section below or email me at jcutright@repsg.com.

 

NJDEP Remedial Priority Scoring

NJDEP Remedial Priority Scoring System – What You Need to Know.

You might be reading this post because you just received a letter from the New Jersey Department of Environmental Protection (NJDEP) letting you know that you have been identified as the responsible person for conducting a remediation and that the NJDEP will be ranking your project using the Remedial Priority Scoring (RPS) System. This is not a cause for alarm and you are not alone. This system will be used to rankNew Jersey’s approximately 12,000 sites and the scores will be made public via the NJDEP’s website. Buyers, lenders and insurers can be expected to review a property’s score before proceeding with a transaction. As a result, the accuracy of a property’s score is of paramount importance.

What is New Jersey’s new Remedial Priority Scoring (RPS) System?

RPS is a computerized model that is designed to help the NJDEP categorize contaminated sites based on potential risk to public health, safety or the environment. Once the RPS Score is determined it is catalogued for relative ranking with sites with similar scores and placed into Categories 1 through 5. Category 1 represents the lowest score and thus the least potential risk through Category 5 which represents the highest score and thus the greatest potential risk. It should be noted that the information used by NJDEP will be derived solely from electronic databases maintained by NJDEP, based on reviews of already received letters, this creates the potential for erroneous assessments as these databases may not contain the most accurate and current information. Steps should be taken to make sure your site has the correct score.

What Should You Do If You Have Received a Letter from NJDEP on your Remedial Priority Ranking?

If you have received a letter from the NJDEP regarding your ranking it is important that you work quickly with your LSRP to make sure the information is accurate. You have until August 10, 2012 to utilize an online feedback loop in order to have your ranking recalculated.

If you have not already retained an LSRP for your Site or are unfamiliar with the LSRP program, a Licensed Site Remediation Professional (LSRP) is now required to be retained to insure that remediation is being conducted according to NJDEP requirements. An LSRP is licensed by the State ofNew Jerseyand is required to adhere to strict guidelines to insure that remediation is completed with environmental, ecological and human receptors in mind. Once retained, in addition to insuring an adequate and efficient remediation from start to finish, an LSRP can provide detailed reviews of remediation that has already begun before moving it forward to completion. It is in this capacity that an LSRP can be tremendously useful in identifying errors in the RPS score.

Have you received a letter from NJDEP on your Remedial Priority Ranking? What’s been your experience been with the process? I would love to hear from you. If you have further questions about how to handle this process, feel free to post them in the comments section below or email me at jcutright@repsg.com.