WOODRUFF ENERGY COMPANY - A NEW JERSEY ISRA/BROWNFIELDS SUCCESS STORY

RT Environmental recently completed upgrading of a secondary containment facility under NJDPCC regulations, for the Woodruff Energy Company, Bridgeton, NJ. Unexpected findings during the tank secondary containment upgrading project caused the need for emergency reporting to the New Jersey Department of Environmental Protection, when a long abandoned buried municipal waste water treatment plant was found beneath a former product transfer pumping station being demolished as part of the project. Following the initial finding of floating oil product, and because of concern that the waste water treatment system was still connected to the Cohansey River caused a temporary shutdown in the secondary containment upgrading project.

Woodruff Energy Company is a home heating oil, commercial business, and service station supply distribution facility, serving southwestern New Jersey. Oil storage facilities have been present on the site on Water Street in Bridgeton, even prior to Woodruff's operations, which began at the site in 1959. Historical operations included barge product delivery and railcar product delivery, although, all oil product operations in recent decades have involved product receipt and delivery by tanker truck.

Upon finding that the buried wastewater treatment plant, immediate contacts were made with the City of Bridgeton as well as the Cumberland County Utilities Authority. It was identified that a treatment system had operated on the site from 1883 until 1927, and investigation work began immediately to determine the size and extent of the buried wastewater treatment tanks at the site. DEP expressed concern that product, or dissolved product, might be migrating to the River, through unknown pipes or, the former wastewater discharge system. Drawings showed a long discharge pipe to the middle of the river.

County utility officials were instrumental in completing an immediate record search and RT worked closely with Lynne Mitchell of the New Jersey Department of Environmental Protection Southern Field Office, as well as Tim Maguire, senior DEP hydrogeologist. We began to conduct an immediate multi-phase investigation to:

• Use data logging techniques to determine whether or not the wastewater vaults were hydraulically connected to the aquifer, or river which is tidal, and verify groundwater flow direction.
• Expeditiously determine the extent of impacted soils at the facility, as some areas of product saturated soils were found in the vicinity of the wastewater vaults, and some floating product was found in the vicinity of the oil pumping station.
• Large test trenches were also excavated horizontally parallel to the river to determine and confirm that no pipelines existed which could convey product impacted groundwater to the River.
• Influent and effluent pipes to and from the wastewater treatment vaults, as well as other pipes, including product and old, small diameter terra cotta pipes encountered during the excavation were all drained and properly grouted, so that there is no potential for further migration to the nearby River.

The New Jersey DEP considers the Cohansey River to be in need of environmental protection, because of presence of shell fish beds, in the lower part of the River, in the Delaware estuary.

The entire project was conducted expeditiously, using a team approach. RT and DEP shared investigation approaches and findings on a daily basis, following a DEP visit to the site by senior officials from the Southern Field Office. With winter approaching, the key concerns were:

• Completing the investigation project such that secondary containment lining could still be installed before cold weather arrived (HDPE selected for secondary containment cannot be installed in low temperature conditions).
• As the previous secondary containment earthen berms had to be opened for the entire project, all parties felt it important to proceed with the work expeditiously, so that the secondary containment could be put back in place.
• All expressed a desire to work closely together using a high degree of careful technical focus to reach common understandings on the specific goals and need for each investigation and remedial step, and to work quickly towards a solution.

The Project turned into a model of cooperation, meeting with full intent and spirit of the New Jersey ISRA/Brownfields law. Although many people are under the impression that the Brownfields Law only applies to contaminated, abandoned urban sites, ISRA revisions also in the law actually allow DEP to adopt flexible and appropriate standards, for petroleum release sites using a risk based corrective action process. RT worked closely together with DEP to use appropriate standards as localized areas around the waste water treatment vaults were investigated, taking into account that the area would be capped by the secondary containment liner. Also taken into account were the investigation results, the site setting, and migration potential.

Once it was demonstrated that all potential migration pathways of concern to the river had been located and successfully closed, Class II soil standards were found to be applicable, and remedial needs were focused on two particular "hot spot areas", which were expeditiously remediated by excavation and removal of soil. Soil was shipped to a regional bioremediation facility for treatment. Engineering and investigation findings, as well as lab results, and key technical findings were forwarded to DEP by fax on a daily basis and investigation and remediation of the entire tank farm/wastewater treatment area was completed in a short three weeks.

There are many people who claim that investigation and remediation at petroleum sites can be overly complicated in NJ and that it can take years to get decisions and to reach a final conclusion. The fast-track project at Woodruff Energy showed that:

• New tools available as part of NJ Brownfields initiatives can allow for a rapid, technically complete remediation work, to address areas of concerns efficiently and effectively.
• Experienced regulatory professionals working closely together, can make quick decisions, carefully focused on specific technical areas, working collaboratively to address environmental concerns.

Although some view the Technical Requirements for Site Remediation in New Jersey as unnecessarily complex, environmental professionals who clearly understand them can work closely with the DEP to make fast field decisions, even when not everything is known initially about the history of a site. Unknowns can be quickly addressed using the most appropriate engineering and hydrogeologic investigation techniques to reach proper technical conclusions quickly.

Mr. Robert Woodruff, Sr., President of Woodruff Energy, commented that the level of cooperation was remarkable, in that daily investigation and remediation work could be planned and implemented with DEP oversight so as to be both focused and efficient. The project was a model of cooperation and provides the assurance that Woodruff's main tank farm facility has been through the investigation and remediation process so that areas under the liner system, are no longer of environmental concern. Woodruff Energy is starting 1999 as one of New Jersey's first ISRA/ Brownfields success stories, wherein fresh approaches and a high level of cooperation prove that environmental work can proceed quickly, efficiently, and professionally.

We at RT salute the Southern Field Office of the New Jersey Department of Environmental Protection for its highly professional and time sensitive oversight, of this important project. Without question, many property and facility owners in New Jersey will want to take advantage of new opportunities that exist to deal with site contamination issues under the New Jersey Brownfields Law.

For more information on the New Jersey Brownfields Law and associated ISRA program revision, contact Gary Brown or Tom Brady. Tom Brady can be reached at our New Jersey office (856) 467-2276 or at tbrady@rtenvnj.com.