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Periodic updates from JM Sorge will keep you informed about the latest trends, regulations and updates in the field of environmental consulting.
NJDEP Releases New Fill Guidance Document
NJDEP has released the new Fill Guidance (http://www.nj.gov/dep/srp/guidance/srra/fill_protocol.pdf). This document specifies new requirements and changes the game for the use of clean or alternative fill at Site Remediation Program (SRP) sites.
Alternative fill (fill that contains contaminants in excess of the most stringent soil remediation standards) previously required some type of investigation prior to use; a sampling protocol is now strictly defined.
Dense Grade Aggregate (DGA) or fines that are generated during rock crushing activities at a quarry, is the go-to clean fill used on SRP sites. The material has good geophysical characteristics and with proper documentation was accepted without question by the NJDEP as clean fill. However, the new Fill Guidance now requires all clean fill to be investigated and/or sampled prior to use. Below is a review of the new requirements for clean fill on SRP sites.
New Requirements to use Rock, Sand or Soil obtained from an undisturbed geologic formation as Clean Fill on SRP Sites
A preliminary assessment or other site review is required. As long as the Site Review has determined that the donor site has not been impacted by a contaminant sources, only one sample is necessary. Pre-existing data provided by the quarry/mine is acceptable, as long as there is at least one sample for each calendar year the quarry/mine has been in operation and the data appears reliable.
If the donor material exceeds the impact to groundwater standard (IGW); SPLP testing (per the NJDEP’s SPLP guidance for IGW) can be used to confirm that the donor material will not adversely impact the receiving site.
Elevated Natural Background Consideration
- Soils or geologic formations, which are known to contain naturally occurring elements in excess of the NJDEP’s remediation standards or other criteria, can be used; if the donor site and receiving site is geographically and geophysically compatible;
- Naturally occurring asbestos containing material may not be used as clean fill.
Additional information on the guidance documents mentioned above can be found at: http://www.nj.gov/dep/srp/guidance/srra/
Rhea Grundman
Project Manager
