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September 2, 2020 - [EXTERNAL]: Active System Ground Water Remedial Action Permits

From: NJ Department of Environmental Protection NJDEP@public.govdelivery.com
To: NJDEP@public.govdelivery.com
Date & Time: 9/2/2020 6:37:00 PM
Subject [EXTERNAL]: Active System Ground Water Remedial Action Permits

[EXTERNAL]: Active System Ground Water Remedial Action Permits

The New Jersey Department of Environmental Protection (Department) has been receiving questions regarding what is considered an active ground water remediation when applying for an Active System Ground Water Remedial Action Permit (RAP). Previously, Active System Ground Water RAPs were generally only issued for active ground water treatment systems that were remediating contamination from the discharge(s) and continuously and effectively operating and functioning as designed pursuant to the Administrative Requirements for the Remediation of Contaminated Sites [N.JA.C. 7:26C 7:5(d)4]. The Department is now considering other technologies, such as remedial injections and reactive barriers, as an acceptable long-term remedial action where an Active System Ground Water RAP can be issued. As noted above, it must be demonstrated that these technologies are effectively remediating contamination from the discharge(s) and are operating and functioning as designed.

Remedial injections are to be performed at an appropriate frequency to demonstrate that they are effectively remediating contamination for a minimum of one year prior to submitting an application for an Active System Ground Water RAP (weekly, monthly, and quarterly injection events are acceptable). In addition, an appropriate monitoring well network should be installed, including downgradient, sidegradient, and vertical sentinel wells, to monitor for any vertical and horizontal mobilization of contaminants due to the injections pursuant to N.J.A.C. 7:26E-5.6(b)8, the In-Situ Remediation: Design Considerations and Performance Monitoring Technical Guidance (https://www.nj.gov/dep/srp/guidance/#in_situ), and the Ground Water - SI/RI/RA Technical Guidance (https://www.nj.gov/dep/srp/guidance/#pa_si_ri_gw). The Department will not issue an Active System Ground Water RAP if the application includes a short duration injection or any injections that can occur under 180 days. Discharge To Ground Water (DGW) Permit-By-Rule Authorization Requests for short term remedial actions are acceptable and are reviewed and approved by the Bureau of Ground Water Pollution Abatement.

Reactive barriers should be installed for a minimum of one year prior to the submittal of an Active System Ground Water RAP Application. Pursuant to the Ground Water RAP Guidance (https://www.nj.gov/dep/srp/guidance/#rap_gw), a minimum of one year of quarterly ground water sampling should be performed during active remediation to demonstrate that the active system is effectively operating and functioning as designed.

Questions regarding whether it is appropriate to submit an Active System Ground Water Remedial Action Permit should be directed to the Bureau of Remedial Action Permitting at (609) 984-2556.


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