impacts of catastrophic events at NJDEP SRWMP contaminated sites.

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Page 2 of 45 Table of Contents 1.0 Introduction and Background .. .. .. . 4 1.1 Intended Use .. .. .. .. .. 5 1.2 Purpose .. .. .. .. . 5 1.3 Document Overview .. .. .. .. 6 2.0 Factors to Consider .. .. .. .. .. 7 2.1 Types of Catastrophic Events .. .. .. . 7 2.2 Site Conditions .. .. .. .. .. 7 2.3 Receptors .. .. .. .. . 9 2.4 Regulations .. .. .. .. . 9 2.5 Status of Remediation .. .. .. 11 3.0 Preparedness, Response, Recovery, Re -Assessment .. .. 13 3.1 Preparedness .. .. .. .. .. 13 3.1.1 Assessment of Vulnerability and Risk .. .. .. 14 3.1.2 Select and Implement Mitigation .. .. .. 18 3.1.3 Contacts and Communication .. .. .. .. 20 3.1.4 Assess supplies and equipment .. .. .. 21 3.1.5 Training and Exercises .. .. .. .. 22 3.2 Response .. .. .. .. 22 3.2.1 Assess event and Site Conditions .. .. .. 23 3.2.2 Prioritization .. .. .. . 23 3.2.3 Evaluate Resources and Implement Response .. .. . 24 3.3 Recovery .. .. .. .. 24 3.4 Re -assessment .. .. .. .. 25 3.4.1 Post -event reporting .. .. .. . 25 3.4.2 Lessons learned .. .. .. .. 25 3.4.3 Review of new technologies and guidance that might better protect the site .. 26 4.0 References .. .. .. .. 27

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Page 3 of 45 List of Figures Figure 1 Decision Chart ΠAppropriate Level of Planning and Preparation .. 15 Figure 2 -1 Anti -buoyancy mattress installed over pipeline to resist flotation .. . 18 Figure 2 -2 Flooding caused costly damage to mechanical and electrical equipment .. .. 19 Figure 2 -3 Extensive power line damage during Superstorm Sandy .. 19 Figure 2 -4 Loss of soil at bulkhead with exposed tieback rods .. .. 20 List of Tables Table 1 Risk and Probability Assessment Matrix ΠExample .. .. 16 Table 2 Example of Vulnerability Assessment Results and Prioritized Hardening Measures . 17 Appendices Appendix A fiZero -Hourfl Schedule ΠAnticipated Events .. .. .. 30 Appendix B Information Resources to Help Identify Hazards .. .. . 31 Appendix C Contact Information .. .. .. .. 32 Appendix D The National Incident Management System .. .. . 35 Appendix E Case Study (Fabricated) ΠHolicong Manufacturing Site .. .. .. 37 Appen dix F Glossary .. .. .. .. . 41 Appendix G Acronyms .. .. .. .. . 44

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Page 4 of 45 1.0 Introductio n and Background Due to its industrial history and a progressive contaminated site cleanup program, New Jersey has identified many contaminated sites in need of remediation. By the end of 2014 there were approximately 14,000 contaminated sites under the purview of the New Jersey Department of Environmental Protection (NJDEP or Department ). Leading up to , during , and in the aftermath of Superstorm Sandy in October 2012 , the primary concern s of the Site Remediation and Waste Management Program (SR WMP) were securing and asses sing the effects of Sandy on site s within the State . Prior to the storm, SRWMP communicated to the regulated community the need for site preparedness to prevent the release of hazardous materials and the need to address releases in a timely manner . In an attempt to learn from th at catastrophic event , SR WMP staff and managers who were involved in the response efforts participated in a post -storm exercise to review, analyze and learn from the experience . The goal of this exercise was to evaluate lessons learned and identify i mprovements that could enhance remedial system resiliency for any catastrophic event in the future. Through this evaluation , it became clear that L icensed Site Remediation Professionals (L SRPs ), the Person Responsi ble for Conducting the Remediation (PRCR , as defined in N.J.A.C. 7:26C -1.3), and property owners could benefit from guidance to help them prepare for , respond to , and recover from catastrophic events. Th is guidance w ill cover the following : Planning for resilienc y in the design and implementation of site remedies . Retro -fitting vulnerable sites to decrease disruption to existing systems . Establishing communication networks , chain -of-command structures , and procedures to be used during catastrophic event s. Reviewing lessons learned . Re-assessing systems to be better prepared for future catastrophic events . This guidance was prepared with stakeholder input. For more information on Technical Guidance Documents and the stakeholder process, go to . The following people were on the committee who prepared this document: Mike Burlingame, PE, PP, NJDEP Site Remediation and Waste Management Program Bill Hadsell, NJDEP Si te Remediation and Waste Management Program Neil Jiorle, LSRP, French & Parrello Associates Janine MacGregor, NJDEP Site Remediation and Waste Management Program George Nicholas, NJDEP Site Remediation and Waste Management Program Gary Pearson, NJDEP Emergency Management Program Nicholas Santella, Ph.D., Brownfield Science & Technology Inc. fiBSTIfl Beena Sukumaran, Ph.D., Rowan University Robert A. West, R.A. West Associates In addition, efforts were assisted by: Kevin DeLange, HDR Ron Kurtz, Firmenich Tom O™Neill, NJDEP Site Remediation and Waste Management Program Alison G. Stidworthy, NJDEP Site Remediation and Waste Management Program

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Page 5 of 45 1.1 Int ended Use This guidance is designed to help LSRPs and PRCRs plan for and respond to a catastrophic event affecting a contaminated site. This guidance is intended to be used for planning purposes and does not require a submittal to the Department . It may be used in concert with, but does not supersede the Departmen t™s rules, regulations, and guidance . This guidance may be used by various people involved in the remediation of a contaminated site including LSRP s, non -LSRP environmental professionals, property owner s, facility manager s at operating companies and the PRCR . This guidance recognizes that contamination at a contaminated site might include the entire parcel, a single area of concern (AOC), multiple AOCs, and/or impacted media and the possibility of multiple PRCRs. The generic term fi Investigator fl will be u sed to refer to any person that uses this guidance to plan for or respond to a catastrophic event at a contaminated site on behalf of a remediating party, including the remediating party itself. Sites that could benefit from the concepts presented in this guidance include operating facilities where contamination is present, contaminated sites undergoing investigation or remediation, or sites that have completed remediation but have engineering or insti tutional controls remain ing on site. Active sites may have an Emergency Response Plan/Contingency Plan/Business Interruption Plan, or alternate, that incorporates how to handle and manage catastrophic events , and those Plans may benefit by considering this Guidance . This guidance document is not intended to apply to formerly contaminated sites where an unrestricted use remedial action ( No Further Action, NFA or Remedial Action Outcome , RAO ) has been completed. Though not based in rule or statute, this guid ance is intended to present best management practices to plan for and respond to catastrophic events. The Department recognizes that professional judgment may result in a range of interpretations on the application of th is guidance to site conditions. 1.2 Purpose Proper planning for catastrophic events can result in less significant impacts, including personal injuries/deaths, property damage, economic -production time losses, and resources dedicated to recovery efforts. Proper planning can also eliminate and/or reduce the unintended release of contaminants and impacts to the environment during these types of events. New Jersey strives to take a proactive approach when remediating contaminated sites o r building/ rebuilding structures with a vision of increa sed resiliency. The purpose of this document is to provide guidance to the Investigator in the preparation for, response to and recovery from the damage caused by catastrophic events at site remediation projects , including the following : Provid ing guidance for Investigators to assess vulnerabilities of contaminated sites. Act ing as a reminder to Investigators that some degree of planning should be considered, whether a simple list of important contacts, a stand -alone Catastrophic Event Plan, or fac ility -wide plans concerning environmental activities/infrastructure required by regulation for operating facilities. Maintaining site conditions or operational continuity during an event by implementing preventative measures . Respond ing effectively during an event by having appropriate tools and planning in place . Resum ing operations or re -secur ing a site more quickly after an event by implementing recovery steps more readily . Learn ing from experiences during a catastrophic event to make adjustments to mitigate impact s from future events.

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Page 6 of 45 1.3 Document Overview This guidance document is organized into the following sections: 1.0 Introduction and Background . This section describes the intended use and purpose of this guidance. 2.0 Factors to Consider. This section discusses factors to consider when planning and preparing for the impacts of catastrophic events at NJDEP SRWMP contaminated sites. Examples of the factors to consider include types of catastrophic events, site specific conditions, potential impacts, constraints (i.e., logistical, regulatory, etc.) and the current status of the remediation. 3.0 Preparedness, Response, Recovery, and Re-Assessment . This section is divided into four subsections that represent the key components of preparin g for and responding to catastrophic events at contaminated sites. The subsections include planning, response to events, recovery from events, and a re -assessment process to identify lessons learned and areas for improvement. 4.0 References. This section prov ides a list of documents and websites used in the preparation of the guidance , and additional sources of information that were consulted and could be helpful to the user, but may not have been specifically referenced in the guidance. Hyperlinks are include d in the body of this guidance to enable quick access to the reference materials. Appendices. The appendices include examples or more detailed information of concepts presented in the guidance document, a case stud y, emergency contact information, glossary and acronyms/abbreviations .

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Page 8 of 45 Contaminant s Consideration should be given to the physical, chemical and biological characteristics of the contaminants and processes that control their transport, migration and potential impacts to receptors as pa rt of the catastrophic event planning. The potential impacts from the migration of contaminants due to a catastrophic event are related to the contaminants™ toxicity, concentration s, mobility and persistence in the environment. Physical hazards, such as flammability or explosion, may also need consideration depending on the concentrat ion of chemicals stored or otherwise present on-site. Contaminants with greater adverse health or ecological effects and/or greater mobility and persistence in the environment warrant greater precautions against release. For these, a greater degree of h ardening of the remedial systems, backup systems and/or automatic management or operational responses should be considered . Remedial and/or backup systems might also use chemicals ( e.g. , gasoline -powered motors, chemical reagents, etc.) that could be released during a catastrophic event and will need to be considered during planning or system hardening. Subsurface Conditions The subsurface conditions sh ould be evaluated in the context of the known or suspected contaminants of concern, potential remedial system -related contaminants and their possible behavior as a result of the occur rence of a cat astrophic event. For example, sites underlain by clayey soils w ill be less susceptible to ground water contamination from a surface spill than sites underlain by sandy soils. For sites that have reached the RI, RA or post -RA stage, it is expected that subsurface conditions and contaminants of concern will be well docu mented. Hydrology and Topography In the case of many natural hazards , site hydrology and topography are key factors for assessing site vulnerability . Consideration should be given to nearby surface water bodies and the topography of the site and surrounding area . Heavy rain from significant storm events could cause flooding of the site from rising surface water levels or from stormwater run -off. Fast moving flood waters are extremely damaging and the erosive forces would be a significant concern f or any site with a soil capping remedy . In addition, consideration should be given to protecting exposed critical structures or buoyant tanks that could be damage d by water and waterborne debris . Land Use The Investigator planning for a catastrophic event should consider current and potentially, future land use if appropriate, at the site and adjacent properties , as well as the land -use categories within Site Remediation Reform Act (SRRA) and the Remediation Standards (N.J.A.C. 7:26D). For example, a more protective approach may be appropriate when the site or adjacent property is used for a school or child care , or is located in a regional classification area such as Pinelands or Highlands . Remedial Systems Remedial systems should be designed to maximize resiliency. In some cases they may need to continue functioning during an event, and hardening may be necessary. In other instances , it may be safer, more reliable, or more cost effective to shut them down and secure them in the case of a predictable catastrophic event. Investigators can conduct a Vulnerability Assessment , followed by a Risk and Probability Assessment , as discussed in Section 3. 1, to assess the relative impact due to failure of various remedial system components so that mitigation measures can be prioritized.

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Page 9 of 45 2.3 Receptors Protection of human and ecological receptors is paramount during catastrophic events. Receptors are defined in the Technical Rules ( N.J.A.C. 7:26E ) as fiany human or other ecological component which is or may be affected by a contaminant from a contaminated site.fl Response and mitigation p lanning should identify sensitive human and ecological receptors ( e.g. , schools, special status species habitat) ; assess the potential for these receptors to be impacted ; and outline measures to protect the receptors in a timely and effective manner . This guidance presumes that, for the most part, it will be used at sites that have moved beyond the Preliminary Assessm ent stage , and the requirements set forth in the Administrative Requirements for the Remediation of Contaminated Sites (ARRCS ) at N.J.A.C. 7:26C and the Technical Rules at N.J.A.C. 7:26E (7:26E -1.12 Receptor Evaluation) will apply. As such, the requirement s to complete at least an Initial Receptor Evaluation (IRE) would have been triggered and the IRE would have been completed. Areas of concern and the existence and potentially the extent of contamination in any medium will be known, pathways for potential contaminant migration will be documented , and receptors will have been identified pursuant to regulatory requirements and other NJDEP technical guidance documents. The information contained in the IRE, Receptor Evaluation or Risk Assessment sho uld be revi ewed and catastrophic event plan ning updated based upon current site conditions, site -related information and the consequences of a catastrophic event , should it occur. This is consistent with the iterative process in the CSM approach discussed above. Cons ideration should be given to how a catastrophic event might impact the finding s of the CSM or change the vulnerability of receptors at sites with existing receptor evaluations. It is important to consider the presence of Environmentally Sensitive Natural Resources ( ESNR) and the potential for these to become contaminated from releases at the site during an event. ESNR is an area defined in the Discharges of Petroleum and Other Hazardous Substances Rules at N.J.A.C. 7:1E -1.8(a), or an area or resource prote cted or managed pursuant to the Pinelands Protection Act, N.J.S.A. 13:18A -1 et se q. and the Pinelands Comprehensive Management Plan (N.J.A.C. 7:50). 2. 4 Regulations The Investigator is encouraged to take into account applicable New Jersey statutes and regulations when planning for , during , and after a catastrophic event. Federal and local regulations should also be considered. Although not inclusive, the following NJ State laws and rules are important when preparing for and responding to a catastrophic event . Site Remediation Reform Act ΠN.J.S.A. 58:10C -1, et seq. Brownfields and Contaminated Site Remediation Act ΠN.J.S.A. 58:10B -1, et seq. Industrial Site Recovery Act ΠN.J.S.A. 13:1K -6, et al. Spill Compensation and Control Act ΠN.J.S.A. 58:10 -23.1, et seq. Water Pollution Control Act ΠN.J.S.A. 58:10A -1, et seq. Underground Storage Tank (UST) Rules ΠN.J.A.C. 7:14B Administrative Requirements for the Remediation of Contaminated Sites (ARRCS) ΠN.J.A.C. 7:26C Industrial Site Recovery Act Rules ΠN.J.A.C. 7:26B Discharges of Petroleum and Other Hazardous Substances Rules ΠN.J.A.C. 7:1E Remediation Standards РN.J.A.C. 7:26D Technical Requirements for Site Remediation (Technical Rules) РN.J.A.C. 7:26E Solid Waste Rules ΠN.J.A.C. 7:26 Hazardous Waste Rules ΠN.J.A.C . 7:26G

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Page 10 of 45 Remediation Standards for Radioactive Materials Œ N.J.A.C. 7:28 -12.1, et seq. Toxic Catastrophe Prevention Act – N.J.A.C. 7:31 In addition, recovery projects located within floodplains, wetlands or other protected ecological resources will require permit approvals from the NJDEP Land Use Division. Depending on the regulated resource, these permits are issued pursuant to New Jersey rules , including, but not limited to the following : Flood Hazard Area (FHA) Control Act Rules Œ N.J.A.C. 7:13 Freshwater Wetlands Protection Act Rules Œ N.J.A.C. 7:7A Coastal Permit Program Rules Œ N.J.A.C. 7:7 Stormwater Management Rules Œ N.J.A.C. 7:8 Also important are approvals for work within designated special habitat or use areas , such as the Pinelands , Highlands and Meadowlands. For more information see the following: New Jersey Pinelands Commission at , the Pinelands Protection Act – N.J.S.A. 13:18A -1 et seq. and the Pinelands Comprehensive Management Plan – N.J.A.C. 7:50 . New Jersey Sports and Exposition Authority at and enabling legislation N.J.S.A. 13:17 -21 for Master Plan . New Jersey Highlands Council at http://www.highlands.state.nj .us/njhighlands and the Highlands Water Protection and Planning Act – N.J.S.A. 13:20 -1 et seq. Emergency Permits In response to Superstorm Sandy, NJDEP Land Use Division provided updated regulatory guidance on exempt/non -regulated activities and the expedi ted processes to obtain emergency permits. Relevant guidance is now provided on the NJDEP website. However, multiple eligibility and permit duration restrictions apply to emergency permits. To apply for a Flood Hazard Area (FHA ) emergency permit, permittees must demonstrate severity of environmental degra dation and extraordinary risk or impact to public health and property (N.J.A.C. 7:13 -12.1) . In addition, limited work windows are allowed for FHA emergency permits, including sta rting the work within 30 days, and if the work is not complete within 60 days, a complete permit application may be required. For more information see: . For Coastal Emergency Permits involving work within the Coastal Area Facility Review Act ( CAFRA ) (N.J.A.C. 7:7 -2.1), Coastal Wetlands (N.J.A.C. 7:7 -2.2 ) or Waterfront Development (N.J.A.C. 7:7 -2.3), NJDEP may issue an emergency permit authorization if it det ermines that there is an imminent threat to lives or property if regulated construction activities are not immediately started. For example, if a bulkhead was badly damaged due to a catastrophic storm event resulting in significant damage to the adjacent property , the bulkhead should qualify for an emergency permit to allow its replacement . The potential for severe environmental degradation will also constitute a basis for issuing an emergency permit authorization. The NJDEP or the county government may wa ive District Solid Waste Flow Control Requirements to expedite waste removal after a catastrophic event. A summary of waste flow requirements for each New Jersey c ounty can be found at http: // . NJDEP emergency permits for Temporary Debris Management Areas (TDMAs) may be issued in response to an event. The Investigator should evaluate options available for waste or debris disposal outside of the site™s District if TDMAs and landfills located inside the District are not available.

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Page 11 of 45 2. 5 Status of Remediation The Technical Rules define “remedial phase” as a distinct component of the remediation process (see N.J.A.C. 7:26E -1.8 ). Such components include, without limitation, the preliminary assessment (PA), site investigation (SI), remedial investigation (RI) and remedial action (RA). This Guidance was developed for contaminated sites at any remedial phase , however, p lanning for and responding to a catastr ophic event may differ depending on what remedial phase the site is undergoing . Preliminary Assessment The preliminary assessment scope of work typically does not include intrusive activities and, at this phase in the remedial process, it is unlikely that sufficient information would be available to effectively plan for a catastrophic event. An exception to this would be a situation where a third party is acquiring a known contaminated site from a PRCR . During the due diligence period in such a situation, the Investigator should identify whether the PRCR has conducted catastrophic event plan ning. Site Investigation Catastrophic event planning would be warranted at this stage to minimize damage to onsite equipment being used during the SI (e.g. , drill rigs, backhoes, excavators, gasoline -powered generators, etc.) and to prevent further impact from contamination that has been identified . For example, if there is an on -site detention pond with dissolved contamination but the earthen walls of the pond are structurally unsound, it may be prudent to remove the liquid for off -site disposal at the earliest opportunity to minimize impacts from a catastrophic event. Remedial Investigation At this phase of investigation, contamination has been confirmed and intrusive work is likely occurring. The duration of this phase may be extensive and involve multiple areas of concern. Catastrophic event planning is warranted to protect equipment being used, control contaminant migration and prevent damage to any interim remedial measures that are being implemented. Catastrophic planning should always be updated in response to any new inf ormation generated during the RI Phase or any change in site use . Remedial Action A Remedial Action Work Plan (RAWP) will be prepared that describes the RA to be implemented and may include catastrophic event planning. Factors to consider during catastroph ic event planning at the RA phase may include the following : whether the RA is site -wide or AOC specific potential changes in site use the nature and extent of contamination the type and location of remedial equipment the time period over which remediation will occur (e.g., years vs . decades) whether the remediation achieves restricted, limited restricted or unrestrict ed use These factors help determine whether existing catastrophic event plan ning is appropriate or needs to be revised. This guidance assumes that some RAs will use remedial systems such as ground water pump and treat systems or engineering controls such as a cap . An evaluation of the catastrophic event plan ning with respect to the remedial system should be a component of the ongoing operation and maintenance activities. For example, if climate conditions have left the remedial system more vulnerable to a catastrophic event than when originally installed, or

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