Findings
& Recommendations for the Remediation of Historic Pesticide Contamination
- Final Report March 1999
Table
of Contents
Executive
Summary
The increasing development pressures
on New Jersey’s remaining farmland have triggered a number of major public
policy issues for the state. The Whitman administration is attempting
to strike an appropriate balance between new development and the management
of the State’s natural resources.
Recently, one specific issue that
needs to be dealt within this larger context was brought to the attention
of the New Jersey Department of Environmental Protection (the Department)
by the development community. The historical use of agricultural pesticides
in New Jersey has resulted in pesticide residues of certain persistent
pesticides in soil at concentrations that exceed the Department’s residential
soil cleanup criteria and may pose a human health risk. The primary concern
with historical pesticide residues is human health risk from inadvertent
ingestion of contaminated soil, particularly by children. The presence
of moderately elevated pesticide residuals in soil present potential health
and marketplace concerns. While there is currently no requirement that
agricultural soil be tested prior to development, many developers and
lenders are requiring that sites proposed for development undergo an evaluation
of environment conditions. In fact, it was such a requirement that triggered
the investigation into potential impacts of pesticide residues and soil.
The Department estimates that up
to 5 percent of the state’s acreage may be impacted by the historical
use of arsenical pesticides alone. The presence of pesticide residues
may be a concern in currently operating farms and orchards as well as
properties that have already been developed. Research conducted by the
Department indicates similar problems exist in other states and countries.
The challenge is how to modify the
cleanup process currently used in New Jersey to remediate industrial discharges
to address the risks presented by historical pesticide contamination.
Department Commissioner Robert Shinn
formed the Historic Pesticide Contamination Task Force to help the Department
identify technically and economically viable alternative strategies that
will be protective of human health and the environment for sites with
contamination due to historical use of pesticides. The Task Force met
under the direction of Richard J. Gimello, Assistant Commissioner for
the Department’s Site Remediation Program. During their deliberations
Task Force members focused on how the Department determines risk and sets
cleanup criteria. This report is a product of true compromise by parties
with significant interests. While supporting the overall report, the Task
Force members, individually, would place different emphasis on the various
conclusions, findings and recommendations. Many members continue to have
questions about various elements of the report. The Task Force believes
that implementation of the remedial options identified in the report are
protective of human health and the environment. The Task Force agreed
to offer the following recommendations while the Department continues
to evaluate relevant environmental data, conduct needed research, monitor
economic impacts of these policies and revisit these recommendations as
needed.
The Task Force focused its efforts
on several pesticides of concern based upon their extensive agricultural
use over a number of years in New Jersey, their persistence in the environment
after application, and their presence in sites across the state in concentrations
which exceed the Department’s residential soil cleanup criteria. The pesticides
of concern, which have not been widely used in many years, are arsenic,
lead, DDT (and its metabolites, DDE and DDD), dieldrin and aldrin.
Over the last 100 years the agricultural
community has routinely and consistently applied pesticides to control
pests in order to increase crop yield. Application rates, duration of
use and persistence in soil are the major factors that contribute to the
likelihood that residual pesticides will be present in soil at concentrations
above the Department’s residential soil cleanup criteria.
Once the areas of likely application
are identified, it is then important to determine the behavior or fate
of the pesticides in the environment to obtain a better idea of where
and in what form pesticide residuals are expected to occur. Other environmental
factors, which influence a pesticide’s environmental fate, include its
ability to become bound to the soil and its solubility. There are also
human factors that influence where these residuals are likely to be found,
such as site use and soil management. One of the inherent problems with
the presence of arsenic and lead, in contrast to the organochlorine pesticides,
is that these are two naturally occurring metals and that it is often
difficult to distinguish between concentrations from the application of
pesticides and those that occur naturally.
The Department has only collected
limited soil sampling data concerning soil pesticide residuals at agricultural
properties. While the data are included in the report, the reader is cautioned
against attempting to draw conclusions and applying them to specific areas
or to the entire state.
The Historic Pesticide Contamination
Task Force applied the Department’s paradigm for determining risk to human
health from the environmental exposure to these chemicals. Primarily this
includes following the Legislative guidelines in the Brownfield and Contaminated
Site Remediation Act, N.J.S.A. 58:10B-1 et seq., for the acceptable risk
level of one additional cancer case in one million people exposed and
the application of this risk management decision through human health
risk assessments following the applicable federal guidelines.
The Task Force was unable to determine
the potential economic impacts which may result from the their recommendations
because New Jersey is first in the nation to take actions to control exposure
from historical pesticide contamination. However, both the Task Force
and Department believe that it was very important to proceed with this
evaluation and develop recommendations to educate the public and to make
recommendations to mitigate risk from historical pesticide contamination
in a timely manner.
The Historic Pesticide Contamination
Task Force makes the following recommendations to assist those involved
in the remediation of agricultural properties that have been developed
and that will be developed in the future.
- Sampling of former agricultural areas, and any necessary remediation,
should be conducted prior to site development.
- Sampling of former agricultural areas, and any necessary remediation,
should be conducted for areas with exposed soil that are intensively
used by children, such as schools, daycare centers and playgrounds.
- Sampling and remediation at sites that have already been developed,
except as noted above, should be conducted whenever the current or potential
future occupant desires. The Department should provide guidance concerning
sampling methods and exposure control alternatives to any person concerned
with historic pesticide contamination.
- The Department should provide an appropriate sampling methodology
specifically designed for the investigation of pesticide residues in
soil at agricultural properties (Addendum
5);
- The Department should authorize a remedial alternative involving soil
blending for pesticide residues in soil in former agricultural areas
when it is protective of human health. The Task Force recognizes that
soil blending represents a substantial departure from current State
policy. Therefore, the Task Force recommends that soil blending apply
only to historical pesticide contamination sites.
Recommendations also include remedial
options for new and existing development sites such as the consolidation
and covering of contaminated soil on-site under roads and structures or
capping contamination with clean soil. The Task Force recommends that
the Department allow contaminated soil to be blended with clean soil from
on or off-site sources to achieve concentrations at or below the Department’s
residential soil cleanup criteria.
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