Lincoln Equities Group, LLC

Environmental Remedy Review - Hamilton Township, NJ

The American Standard facility in Hamilton was founded in 1918. The facility manufactured vitreous china bathroom fixtures until 2001. The process involved molding raw clay, which was then fired and glazed to produce the finished products. After closure, the property was split for re-development into a 65 acre commercial office park with the balance of the undeveloped property (approximately 60 acres) slated for residential development. The residential development was completed by the Morris Companies and the commercial facility was renovated by Princeton Avenue Associates and later sold to Lincoln Equities Group, LLC.

Off-specification product and waste was discarded over the entire undeveloped portion of the site while manufacturing operations were still active. The initial remedial action workplan (RAW) approved by the NJDEP allowed for the relocation of waste pottery from the residential property to the commercial parcel. The selected waste was to be placed under the approved engineering control, which included a geotextile liner and soil or asphalt cap. The relocation and capping of waste pottery was poorly managed with little or no oversight or control. Subsequently, after repeated attempts to control the situation, NJDEP and the municipality issued stop work orders to prevent further co-mingling of clean and contaminated soils. JMS was retained by the commercial developer to re-assess the environmental condition of the property, negotiate a remedial action resolution with NJDEP, and ensure that the approved RAW was properly implemented. During our investigation, it was discovered that the adjacent residential developer had imported PCB-contaminated recycled concrete to construct the roadway between the two parcels. This resulted in further tension between the municipality, NJDEP, and the developer. JMS was retained to monitor the removal of impacted concrete materials and the importing of clean material to re-construct the roadway.

Following our review of site construction records and meetings with NJDEP and the municipality, JMS developed a plan to evaluate the current site conditions using a series of test pits, soil borings, and excavations to verify whether the liner and cap were properly installed. The JMS plan as approved by NJDEP. The investigation confirmed that the engineering control was not present over approximately half of the site, most of which had been landscaped. Other areas of waste placement had been grossly expanded in some cases, impacting associated wetland buffer areas. Following our investigation, JMS prepared a plan to properly install the engineering control, relocate waste out of sensitive areas, and import clean soil, where necessary, to complete the RAW. NJDEP approved the revised remedial action workplan on the site and both the state and municipal stop work orders were lifted. Upon approval of the revised remedial plan, the project was sold to Lincoln Equities, LLC who is the current owner of the property. Lincoln Equities, LLC retained JMS to complete the implementation of the revised remedial action workplan at the site.

JMS provided over sight to ensure the revised RAW was properly implemented and prepared the final Remedial Action Report and associated Deed Notice for the site. The Deed Notice was subsequently approved by NJDEP and filed. The site received a final NFA.