New Historic Fill Material and Diffuse Anthropogenic Pollutants (DAP) Guidance Document
On October 20, 2011 New Jersey Department of Environmental Protection (NJDEP) released a new Technical Guidance document about how to address Historic Fill Material and Diffuse Anthropogenic Pollutants (DAP). A copy of the guidance document is available from NJDEP’s website here:
Historic fill material is prevalent throughout much of New Jersey’s commercial and industrialized areas, and this material is often contaminated with Polycyclic Aromatic Hydrocarbons (PAHs), and Metals above NJDEP’s regulatory standards. This is well known, and the NJDEP has long since established methods for addressing this issue. This new guidance document contains much of the same information in the current Technical Requirements for Site Remediation (TRSR) for historic fill material, however there is additional prescriptive guidance on issues such as site investigation sampling and characterization, remedial and groundwater investigation requirements, and acceptable remedial actions. The document also indicates the Site Remediation Reform Act exempts a Licensed Site Remediation Professional (LSRP) from the requirement to notify NJDEP’s Hotline when historic fill material is encountered. However if historic fill material is identified, it is still required to be addressed under the LSRP program, in accordance with the TRSR.
This new document also provides guidance on Diffuse Anthropogenic Pollution (DAP), which the NJDEP does not currently have any TRSR requirements for. According to the guidance document, DAP is defined as broadly distributed contaminants, often arising from multiple sources, which have been historically generated by human activities. DAP generally arises from atmospheric deposition, but may also contain contributions from other non-point sources, not attributed to a discharge. DAP typically includes PAHs and metals and is generally limited to contamination within surficial soils. The investigation and remediation guidance for DAP in this document is fairly limited and generic, however it will be interesting to see how regulations regarding this relatively new classification of contamination develop. So as always stay tuned to the NJDEP’s website, and www.jmsorge.com for the most up to date information.
Project Manager, JM Sorge, Inc.