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Updates to Historic Fill Material and Diffuse Anthropogenic Pollutants Technical Guidance

Posted on June 27th, 2013

On April 30, 2013 New Jersey Department of Environmental Protection (NJDEP) officially released an update to the previously issued “Historic Fill Material and Diffuse Anthropogenic Pollutants Technical Guidance.” This document has now been renamed “Historic Fill Technical Guidance” and the section on Diffuse Anthropogenic Pollutants (DAP) has been removed. According to NDJEP, the technical guidance for DAP will now be addressed in the “Offsite Source Investigation/Documentation Technical Guidance,” which is still being developed by the NJDEP’s Site Remediation Program Stakeholder Committee. However, NJDEP did release an administrative guidance document entitled “Diffuse Anthropogenic Pollution Administrative Guidance.”

On April 30, 2013 New Jersey Department of Environmental Protection (NJDEP) officially released an update to the previously issued “Historic Fill Material and Diffuse Anthropogenic Pollutants Technical Guidance.” This document has now been renamed “Historic Fill Technical Guidance” and the section on Diffuse Anthropogenic Pollutants (DAP) has been removed. According to NDJEP, the technical guidance for DAP will now be addressed in the “Offsite Source Investigation/Documentation Technical Guidance,” which is still being developed by the NJDEP’s Site Remediation Program Stakeholder Committee. However, NJDEP did release an administrative guidance document entitled “Diffuse Anthropogenic Pollution Administrative Guidance.” These new guidance documents are available at the NJDEP’s Site Remediation Guidance Library:

https://www.nj.gov/dep/srp/guidance

The new DAP Administrative Guidance defines DAP as follows:

“Diffuse anthropogenic pollution” or “DAP” means contamination from broadly distributed contaminants, often arising from multiple sources. DAP generally arises from atmospheric deposition, but may also contain contributions from random, non-attributable, non-point sources.

The guidance indicates that DAP is considered to be contamination from an offsite source, and therefore does not have to be remediated. However, once identified, the presence of DAP must be documented in a notice on the Response Action Outcome (RAO) for the site. As mentioned above, the technical guidance on how to determine DAP is still under development, so it will be interesting to see how extensively this impacts the remediation of contaminated sites once the technical guidance is finalized.

The new Historic Fill Material Technical Guidance details methods that investigators may use to confirm the presence of historic fill material and provides procedures to delineate and remediate any associated soil or ground water contamination. Consistent with previous NJDEP policy, this updated guidance indicates that investigators may either remediate historic fill material under the assumption that it is contaminated or they may establish, via sampling, that the historic fill material is not contaminated. However, the updated guidance provides additional clarity on sampling and reporting requirements, and also contains a draft Confirmed Discharge Notification reporting form, indicating how to properly report contaminated historic fill material to NJDEP.

Thomas Burke

Project Manager, JM Sorge, Inc.


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