New Jersey's Manufactured Gas Plant Program: Implementation of Phase IV LDR Rule and Associated Policies

摘要

The New Jersey Department of Environmental Protection (NJDEP or Department) Site Remediation Program (SRP) is responsible for overseeing the investigation and remediation of the approximately eighty (80) historic manufactured gas plant sites (MGP). The NJDEP has executed both Administrative Consent Orders (ACOs) and Memoranda of Agreement (MOAs) with the five New Jersey utility companies for more than half of the known MGP sites. Furthermore, the utility companies have committed to remediating the remaining MGP sites, utilizing private funds, with formal NJDEP oversight. Remedial actions at these sites are conducted in accordance with NJDEP approved Remedial Action Work Plans. With the above in mind, the Department reviewed with great interest the Phase IV LDR Rule (Phase IV LDR Rules), specifically, those sections which apply to MGP wastes. The NJDEP's review of the Phase IV LDR Rules has resulted in certain conclusions regarding the generation, storage, treatment and disposal requirements that shall now apply to MGP contaminated media undergoing remediation within New Jersey. The following paragraphs summarize the NJDEP's interpretation of salient portions of the Phase IV Rule and how NJDEP intends to implement the rule changes as they apply to remediation projects at MGP sites being addressed with NJDEP oversight (ACO or MOA).