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SRRA Training & ToolsFrequently Asked Questions (FAQs)Receptor Evaluation

 

Site Remediation Reform Act (SRRA)
Receptor Evaluation FAQs

General and Reporting Requirements

Is the submission of a receptor evaluation form required for all cases?

No. A remediating party is not required to submit a Receptor Evaluation form when: A site is not contaminated and a PA/SI report is submitted documenting that fact 1 year after initiating remediation, or an unrestricted remedial action is implemented at the site and a RAO is filed, or NFA is issued, within 1 year after initiating the remediation.

Is the submission of a receptor evaluation form required for my existing case (initiated remediation before November 4, 2009) even though all receptor concerns have already been evaluated?

Yes. Except as noted above, a remediating party of an existing case must submit an initial Receptor Evaluation form pursuant to N.J.A.C. 7:26E-1.15. If all receptor concerns have been addressed at the site and documentation for that work already exists in the reports that have been submitted to the Department, the remediating party must submit the Receptor Evaluation form and reference the previously submitted documentation. The Department recommends that well searches be updated unless one was recently conducted. Updated well searches may be conducted using the online search referenced at: http://www.nj.gov/dep/srp/guidance/ceacompliance/.

How do I fill out the Receptor Evaluation form if my site is very complex or the form does not seem to fit my site?

When the Receptor Evaluation form does not address your site-specific circumstances, you may include a short, concise narrative with the form that clearly explains the circumstances and describes how receptors are being protected. If you need assistance contact your case manager, if one is assigned or a Site Remediation Program contact at http://www.nj.gov/dep/srp/srra/srra_contacts.htm.

Should a receptor evaluation be conducted for cases where there is a conditional No Further Action or Response Action Outcome subject to a Classification Exception Area (CEA)?

For cases that have already received an NFA or RAO subject to a CEA, a receptor evaluation as described in N.J.A.C. 7:26E-1.15 is not required at this time.  It should be noted that the biennial certification process for ground water CEAs includes an updated evaluation of potential receptors for vapor intrusion and ground water use.  Refer to N.J.A.C. 7:26E-8.6(b)6 and 7:26E-8.3(b)iii for more specific details of the receptor evaluation associated with the biennial certification process.

I am implementing a Remedial Action Work Plan (RAWP) that will involve a Classification Exception Area (CEA), but do not have a No Further Action (NFA) or Response Action Outcome (RAO) at this time.  Do I need to complete an updated Receptor Evaluation form?

If the case has yet to obtain an NFA or RAO and is in the Remedial Action phase, a Receptor Evaluation form is required.  In this instance, the Receptor Evaluation form is required even if the only remaining work is monitoring for natural attenuation.

Land Use

I have a very large site and only one small area of concern, do I still have to evaluate land use within 200 feet of the entire property boundary?

The decision to limit the evaluation of land use must be based on existing site data and conditions and on your best professional judgment. The area around the site that must be evaluated can be reduced only in cases where the extent of contamination in soil and ground water, the direction of ground water flow, and the distance to potential receptors is known. Variations of technical requirements must be documented pursuant to N.J.A.C. 7:26E-1.7.

In evaluating future site uses for Section B, Question 3, what degree of certainty should be applied when identifying proposed changes in off site usage?

It is expected that a site visit will be completed as part of the receptor evaluation.  All readily apparent changes in land use should be considered, such as a residential development under construction.

For off site properties within 200 feet of the property boundary, identify those use changes that have been approved by the municipal government.  This change can be through a Planning Board or Zoning Board approval, for example.  Changes in the allowable use of a property through a modification in the municipal Master Plan need not be considered until such time as there is a municipally-approved land use application for the property.

Signs advertising a potential future use are not, of themselves, sufficient evidence to establish a proposed future use but should be confirmed with the appropriate municipal official.

Ground Water

Is a Potable Well/Vapor Intrusion Sampling Notification Form required to be submitted for ongoing sampling of the same potable wells or can the form be submitted on a one-time basis?

If the same wells are being sampled on a routine basis, then the form only needs to be submitted 7 days prior to the first sampling event. An updated Potable Well/Vapor Intrusion Sampling Notification Form is only required to be submitted when a well or a structure is going to be sampled for the first time.

When is a well search required?

An initial well search is required when ground water contamination that has resulted from a discharge is detected above the ground water remediation standards at a site. The regulatory timeframe for the completion of a well search is 90 days after confirming ground water contamination.

If low level ground water contamination is detected in a first sample, the remediating party may confirm the sample results by collecting two additional samples within 30 days (see N.J.A.C. 7:26E- 3.7(e)). The 90 day timeframe to perform the well search does not begin until the results of confirmation sampling are obtained.

What information or data is required to be evaluated in a well search?

The minimum requirement of the initial well search pursuant to N.J.A.C. 7:26E-1.17 is to identify and map 1) all wells within ½ mile from ground water contamination and 2) all public supply, irrigation, industrial and any other wells with a water allocation permit within 1 mile from ground water contamination. Monitoring well information from adjacent contaminated sites is not required to be mapped or submitted for the receptor evaluation. However, this information should be maintained because it may be important later during the remedial investigation.

The purpose of collecting and analyzing this information is to ensure that potable wells are identified early in the ground water investigation and sampled when required. In addition, the location, well logs, and construction of production wells identified in the well search are used to understand the local hydrogeology, and develop a hydrogeologic framework for the surrounding area and help define the scope of the remedial investigation of ground water. "Guidance on Vertical Delineation of Ground Water Plumes" Site Remediation News, May 2001 p. 6 can be found at: http://www.nj.gov/dep/srp/news/2001/srn200105.pdf.

The first step is to identify community and non-community public supply wells, Well Head Protection areas, and service areas for the water purveyors. This information is available on the NJDEP's GIS data coverages. These coverages can be accessed at http://www.nj.gov/dep/gis/geowebsplash.htm. This electronic search should not be used to substitute for the initial search of NJDEP paper well records.

A search of NJDEP well records must be conducted. In addition, it is critical to check with the county and local health and environmental officials because they may have local well records and information that is not in the NJDEP's well records or databases.

The NJDEP has significant information on permitted wells that can be obtained by conducting an electronic radial well search at http://www.nj.gov/dep/watersupply/well/well_search.htm.

When conducting a well search to determine ground water use in a particular area, it is important to know that there is no one comprehensive source of information that can be relied on to determine whether wells are present. The use of private ground water wells can vary from community to community and sometimes from house to house. For instance in many highly urbanized areas of the State ground water has not been used for potable purposes for decades and local ordinances prohibit the installation of new wells. In other communities, waterlines may exist but not all residents are connected. You cannot assume that private wells do not exist just because an area is serviced by public water lines. Therefore, multiple sources of information should be used to effectively evaluate water use in a particular area including NJDEP records of well permits, purveyor service area and detailed waterline information, NJDEP GIS resources, and municipal and county environmental records.

Mapping waterline and hookup information from the local purveyor or local government can also be an efficient way to determine areas or homes that are not supplied with public water. As noted above the availability of public water does not necessarily mean that homes do not have wells in use.

What information needs to be submitted for a well search?

The well search must include the following:

  • A map of all wells (except monitoring wells) identified in the ½ mile and one mile radius searches.
  • A spreadsheet of all wells identified and all the sources of records used to construct the search, including local or county health departments. The template spreadsheet can be downloaded at http://www.nj.gov/dep/srra/forms.
  • A hard copy of the well search should be submitted with the next remedial phase report (SI, RI or RA reports) submitted to the Department.

When is a door-to-door survey required?

A door-to-door survey is required when potable wells are identified in a well search based on the ½ mile paper well search or there is any doubt if ground water is being used by nearby residents in a known contaminated ground water area. For example, a door-to-door survey would be required when, in an area with waterlines, after checking with the water purveyor, it is determined that not everyone is receiving a water bill. Multiple sources must be used to eliminate the need for a door-to-door survey in an area with contaminated ground water. It is important to note that active private wells are often found in areas currently serviced by purveyors unless there was a specific local ordinance that requires people to close their wells before they are allowed to hookup to waterlines.

The scope of the door-to-door survey may be reduced to 250 feet upgradient and 500 feet sidegradient of the known extent of ground water contamination once ground water flow direction is known. Likewise the survey may be limited once plume delineation is complete.

Based on the well search, which wells must be sampled and when should they be sampled?

Pursuant to N.J.A.C.7:26E-1.17(a), the initial potable well sampling must include all potable wells within 1000 feet unless the ground water flow direction is known and the sampling may then be limited to 250 feet upgradient, 500 feet side gradient and 1000 feet downgradient of the ground water contamination. This sampling is required to be conducted within 120 days after ground water contamination is confirmed. If contamination above the ground water remediation standard is found in a potable well, it is an IEC condition and the remediating party shall comply with the Department's IEC requirements at N.J.A.C. 7:26E1.14 and the Department's IEC guidance provided at http://www.nj.gov/dep/srp/guidance/srra/draft_iec_guidance.pdf. The remediating party must continue to “step out” and sample additional potable wells until clean potable wells are found.

Irrigation wells should be sampled when there are concerns about exposure, for example, used to water food crops or for recreational purposes. Irrigation wells should also be sampled when additional information about the plume characteristics is needed.

Samples from potable and irrigation wells shall be analyzed in accordance with N.J.A.C. 7:26E-2.1(a)6.

When it is obvious that people within 1000 feet of the ground water contamination are using ground water for drinking or irrigation, such as when no waterlines are available in the area, the remediating party should proceed with sampling promptly rather than waiting for well search records.

Pursuant to N.J.A.C. 7:26E-1.4(e), the remediating parties are required to notify the Department 7 days prior to sampling potable wells.  Please use the Potable Well/Indoor Air Sampling Notification form which is available at http://www.nj.gov/dep/srp/srra/forms.

How and when do you update a well search?

Once a thorough radius well search, pursuant to N.J.A.C. 7:26E-1.17, has been completed the well search can be updated quickly and by using the same procedures that are used for CEA biennial certification. The procedures are outlined in the CEA Biennial Certification guidance provided at http://www.nj.gov/dep/srp/guidance/ceacompliance/tech/

All well searches, including those performed for CEAs, are required to be updated for the Biennial Certification every two years and prior to the submission of a technical document (SI, RI or RA reports) for the Department’s review. The exceptions for updates to the well search are if a local ordinance exists to prevent new wells or the plume is fully delineated, monitored and entirely on site. In addition, the investigator should be cautious and reevaluate the well search in the area if there is any new building construction in areas without waterlines or if there has been any unexplained change in ground water flow direction.

What is the start date that triggers a ground water or vapor intrusion receptor evaluation or the identification of an Immediate Environmental Concern (IEC) condition?

The start date for the receptor evaluation of ground water and vapor intrusion contamination or the identification of IEC condition is the day that data is received from the laboratory which have undergone laboratory review and have been deemed acceptable for release to their client (i.e. LSRP) and documents that contamination attributable to the discharge is above the applicable criteria.

Vapor Intrusion

What is the start date that triggers a ground water or vapor intrusion receptor evaluation or the identification of an Immediate Environmental Concern (IEC) condition?

The start date for the receptor evaluation of ground water and vapor intrusion contamination or the identification of IEC condition is the day that data is received from the laboratory which have undergone laboratory review and have been deemed acceptable for release to their client (i.e. LSRP) and documents that contamination attributable to the discharge is above the applicable criteria.

When a vapor intrusion issue is identified as a concern, what is the extent of detail required to identify the subsurface utilities within 200 feet as required in N.J.A.C. 7:26E-1.18(b)?

Consult the Department’s current Vapor Intrusion Guidance to establish the extent of this assessment.  Recognizing that this guidance is currently undergoing revisions, the following approach should be implemented in the interim.

When single family residences, including rowhouses and townhouses, or other small inhabited structures are identified within the receptor evaluation distance criterion of 200 feet as required in N.J.A.C. 7:26E-1.18(b), it is assumed that service lines (e.g., water, gas, sewer, cable, etc.) run to each structure. Therefore, additional work is not necessary to identify the specific location of each service line, determine other information about these services lines, or to show them on a figure or map.  However, all lateral lines servicing large residential buildings or units; commercial, retail, or industrial buildings; or main lines servicing groups of single family residences shall be identified, as well as utility vaults or other underground structures.

These larger lines and the utility corridors for main lines constructed using bedding material and fill are more likely to act as significant preferential pathways for vapors, contaminated ground water, or NAPL migration and may be important in developing an accurate conceptual site model.  Utility vaults and underground structures that can be associated with larger utilities may also be subject to vapor intrusion and in extreme cases can pose a threat of explosion or an oxygen deficient atmosphere.  However, determining construction specifications of subsurface utilities, as required in N.J.A.C. 7:26E-1.18(b)3, can be limited to characteristics with the potential for influencing contaminant migration, such as the type and extent of any bedding or fill materials used.  These larger subsurface utilities, vaults, etc. should be identified and shown on the appropriate maps or figures in subsequent IEC or remedial phase reports.

Ecological

Do I have to redo the BEE when I submit an updated receptor evaluation with the remedial investigation report or the remedial action report?

Because there is limited information at the end of the site investigation when the BEE is initially conducted, the Department believes that it is important that the remediating party re-evaluate potential ecological receptors as more information is collected during the later phases of remediation. Often ecological receptors are identified during the remedial investigation when contamination is delineated. The updated Receptor Evaluation form should reflect this continuing evaluation.

 

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NJDEP Point of Contact for Site Remediation Reform Act (SRRA) Training

Tessie Fields
NJ Department of Environmental Protection
PO Box 413
401 E. State Street
Trenton, NJ 08625
Phone: (609) 984-9305
Email: Tessie.Fields@dep.state.nj.us

For other SRRA/LSRP related issues please refer to the Contact List for LSRP Questions.