September 2018 Newsletter

September 5, 2018

Author: Equity Environmental Engineering

On one of the first days of school this year, a person was filmed driving on the sidewalk and people's front yards to get around a stopped school bus picking up children. Please don't be that guy!

Bob Jackson, Managing Director


Caution When Buying/Selling Industrial Property in New Jersey

Due Diligence is a specific investigation that should be performed prior to purchasing properties to protect an innocent purchaser from liability associated with contamination that potentially exists on a property. Equity has recently encountered several instances of entities purchasing properties without performing any due diligence and acquiring properties that were later found to have environmental liabilities. In some cases, these properties had active New Jersey Department of Environmental Protection (NJDEP) cases that exposed them to liability not only for the cleanup but for enforcement actions by NJDEP including significant fines.

In addition to Due Diligence, properties with operations classified as "industrial" according to specific North American Industrial Classification System (NAICS) codes are subject to New Jersey's Industrial Site Recovery Act (ISRA) when any triggering event, such as a sale or cessation of operations take place. Some clients have ceased operations and attempted to sell their properties only to find that the sale cannot be completed until they comply with the ISRA requirements. Not being aware of ISRA, they have suddenly found themselves not only unable to complete their transaction but also subject to NJDEP enforcement and potential fines due to non-compliance within the statutory timeframes. This also impacts their financial bottom line.

Equity continues to assist clients in addressing these issues by taking a two-pronged approach: 1) Equity has been able to work closely with NJDEP Bureau of Enforcement to obtain agreements to hold off on fines and Direct Oversight actions so long as the case is being diligently addressed, and 2) Equity has been able to provide expedited and cost-efficient compliance services to the client to minimize their expense while at the same time complying with the ISRA requirements.

Chris Langewisch, LSRP
chris.langewisch@equityenvironmental.com


Converting Former Gas Stations With USTs to Electrical Charging Station

E-mobility, the electrification of vehicles, is transforming the automotive industry. As the major automotive manufacturers of the world are focusing on ramping up production of plug-in electric and plug-in hybrid vehicles to meet consumer demand and increasingly higher quotas set by governments, electric vehicle charging infrastructure is expanding at a rapid pace to provide charging stations for drivers. Manufacturers such as TESLA and private charging station companies such as ChargePoint are racing to build a complete charging infrastructure in high demand areas, especially here in the northeast. The search is on for potential charging station sites.

Former gasoline stations that are now classified as brownfields have been targeted by the charging industry for new charging stations because they are in locations that are convenient to vehicles and they may be seeking a new source of income. Communities with former gasoline station sites may need a profitable use of their land. This can be a fortuitous transition if the site is in the right location and has the right attributes. However, their success as a potential charging station is highly dependent on specific criteria. The attached "Guide for Identifying and Converting High-Potential Petroleum Brownfield Sites to Alternative Fuel Stations" analyzes what the criteria are, how to prioritize them, and the process of converting a former gas station to a charging station.

The multi-step process in converting a former gas station with an underground storage tank (USTs) can be complex as these properties may be classified as brownfields. Equity can offer professional assistance with this process. Examples of these some of these services are listed below.

  • Equity can provide the Due Diligence (see the previous article in this newsletter) and Site Investigation and Remediation Services of the existing Underground Storage Tank Investigation (UST).
  • Equity can provide an ASTM Property Condition Assessments (PCA) which would encompass electrical hazards and other safety hazards associated with high voltage electricity at the site to ensure that it is in good working condition, will not present any hazards to customers, and is generally safe for public use as part of the Certificate of Occupancy.
  • Equity can perform ongoing operation and maintenance (O&M) audits of the charging stations and the charging units.
  • Obtaining local, state and federal permits from the pertinent jurisdictions is a complex process, especially when dealing with brownfield sites. Equity's Planning team can provide the required environmental reports and permitting assistance to gain approvals from the relevant agencies.

If you are the owner or represent someone who owns a former gas station with an underground storage tank, and are considering a new use such as an electric vehicle charging station, Equity Environmental Engineering may be able to assist you in the process.

Neal Leitner, Environmental Planner
neil.leitner@equityenvironmental.com


Grey Water

(Part 3 of 3)

This is a continuation of the story of one of Equity's New Jersey projects where we treated groundwater contaminated with chlorinated Volatile Organic Compounds (VOCs) with Plumestop by Regenesis. The material is a liquefied organic carbon which is injected into the groundwater. The material works by providing locations for bacteria to grow and the reduction of the chlorinated compounds to simpler compounds. It's been two years since we treated the source area of the site. Prior to the treatment, the Tetrachloroethylene (PCE) concentrations in source area groundwater ranged from 1.15 to 3.01 parts per billion. We have seen a progressive decline in PCE concentrations in the source area since then, with PCE concentrations now ranging from non-detect to 1.76parts per billion.

The interesting thing about using liquefied carbon is that it is a black solution when first injected, but as the product is used up, the color of the water changes to grey, and then becomes clear when the product is used up. In some of our wells, the water cleared up fairly quickly, while in other wells, the water remained black for over a year, then changed to grey. Now all of the wells in the source area have cleared up.

Since the cleanup standard for PCE in New Jersey is 1 part per billion, we have been able to stop sampling some wells where there is no PCE. Other wells continue to show decreasing values of PCE. The reduction in the groundwater VOC concentrations has allowed us to reduce the size of the contamination plume in our conceptual site model and reduce the number of wells that we have to monitor. The ultimate goal is the reach the groundwater cleanup standard and close out the remediation on the site.

If you have a groundwater contamination issue or question, please contact Peter Jaran at peter.jaran@equityenvironmental.com.

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