Environmental Progress
1980's
BP took over operations at Paulsboro Terminal beginning in 1969, but there were releases of petroleum products and chemicals dating from the 1920's, well before BP acquired the property. In 1981, components of petroleum products were discovered in the groundwater and corrective measures and extensive remedial investigations began almost immediately. The New Jersey Department of Environmental Protection (NJDEP) began regulatory oversight of environmental investigations in 1982. One of the first steps taken was to enter into an agreement with BP to recover light non-aqueous phase liquids (LNAPL), or the component of petroleum product that floats on the water table. BP installed several recovery wells throughout the Terminal property. The arrangement was formalized in 1989, when BP signed an Administrative Consent Order (ACO) requiring LNAPL recovery. Efforts were expanded to include recovery of ethyl acetate, kerosene, and No. 6 oil shortly after LNAPL recovery began.
1990's
The 1990's were an active period at the Terminal in terms of remediation efforts. In 1991, a groundwater recovery and treatment system was built and activated to extract and treat groundwater containing chemical constituents and dissolved-phase petroleum, and achieve hydraulic control of the aquifer beneath the site in an effort to contain the migration of impacted groundwater.
In 1994, BP signed a Memorandum of Agreement (MOA) with the NJDEP, agreeing to investigate and clean up 14 potential Areas of Concern (AOCs) on the Terminal property. Several phases of soil and groundwater investigations began, which continue today.
Around the same time, petroleum vapors were detected in the basements of residents to the west of the Terminal. BP purchased five residential properties and instituted a Value Protection Plan (VPP) to maintain property values in a two-block area of the affected neighborhood. In 1996, BP conducted an indoor air study that encompassed homes both within and outside the impacted area. The study, conducted with the NJDEP and the NJ Department of Health, was overseen by Dr. Bernard Goldstein of the Environmental and Occupational Health Sciences Institute, NJ University of Medicine and Dentistry. It concluded that benzene concentrations in homes did not pose a health risk and were generally below national averages. In addition, there was no difference in benzene levels found in homes within the impacted area compared with homes located outside it.
In May 1996, Terminal operations ceased. This triggered compliance with the NJ Industrial Site Recovery Act (ISRA), which imposes certain rules on the sale, transfer or closure of industrial sites where hazardous chemicals are or were handled. A Remediation Agreement was also signed, allowing for the sale or reuse of the property while environmental assessment continues, and a comprehensive groundwater monitoring program was initiated.
In order to remove hydrocarbon vapors that had accumulated in subsurface soils due to migration of LNAPL and impacted groundwater, a soil vapor extraction and treatment system (SVE) was installed in the residential neighborhood next to the northwest portion of the Terminal in 1997. This off-site SVE system, utilizing a network of 15 extraction wells, was expanded in 1999 and upgraded in 2001 and 2002 to include several on-site areas.
In 1998, more than 30 above-ground storage tanks were emptied, cleaned out and demolished. Approximately 24 miles (greater than 90%) of underground pipes at the Terminal were also cleaned and removed.
The groundwater recovery system was upgraded in 1999 in order to more effectively extract impacted groundwater and now operates at nearly 500,000 gallons per day. The aquifer system beneath Paulsboro is divided into three distinct aquifers' Upper, Middle, and Lower, separated by clay layers. The groundwater recovery system has now ensured that contaminated groundwater is not leaving the property boundary of the Terminal via the Upper aquifer. This is known as horizontal containment.
Several different avenues of communication with residents were established as an important part of the remediation project. A newsletter was published in 1998 and is now produced quarterly and mailed to over 2000 residents to update them (in plain English) on the progress made at the site. A public forum was held in 1999 where residents could ask one-on-one questions of BP staff, contractors, and local and state health and environmental agencies. The website, the newest information channel, keeps people abreast of the schedule of events, maps, and redevelopment news, and provides access to an electronic copy of the newsletter.
2000 and Beyond
An air sparging system was designed and approved for used by NJDEP to address soil impacts in the saturated zone below the water table. This augments the SVE system, which deals with soil impacts above the water table. Air sparge wells began operating in October 2004.
A Preliminary Action Report (PAR), which identified all potential AOCs at the site, and prioritized them for investigation and eventual remediation was completed in 2001 and submitted to the NJDEP in early 2002. The PAR identified approximately 160 areas of investigation consisting of 321 potential AOCs on Terminal property and two additional parcels purchased by BP in the 1970's.
In 2002, deep groundwater monitoring wells were installed to determine the extent of impacted groundwater in terms of depth (vertical impact). Initial sampling of the wells showed the presence of some volatile organic compounds (VOC) in the Middle aquifer. Additional deep groundwater wells were installed in 2003, both on and off site. Follow-on tests at the municipal wells were completed and some VOC were detected; however, all levels are below drinking water standards. Sampling of the municipal wells continues on a semi-annual basis.
A Site Investigation (SI), which is a follow-up of the PAR, was completed in 2002 and a report was submitted to the NJDEP in May 2003. The SI involved extensive sampling of soil, sediment, and surface water of the AOCs identified in the PAR and included recommendations for the next phase of work to be conducted, the Remedial Investigation (RI).
The RI work began in August 2004. The RI work also involved extensive sampling of soil, sediments, surface water and groundwater to determine the extent of impacts identified in the SI both horizontally (how far) and vertically (how deep). Findings were reported in a series of Remedial Investigation Reports (RIR) from 2005 through 2007. The Final RIR was submitted in August 2007 and was approved by NJDEP, followed by submittal of the Remedial Action Selection Report, which was approved by NJDEP in April 2008. The RASR and RASR Addendum further divided the Site into 16 areas, called Remedial Management Units (RMU), for which Remedial Action Workplans (RAW) have been submitted detailing the selected cleanup methods. Most of these RAWs have been approved by NJDEP (click here for a list of submitted and approved reports since 2007). Several of the remedial actions detailed in these RAWs will be implemented in 2010.
The groundwater and soil remediation systems installed in the 1990s and in the first decade of 2000 have continued to operate at the Site during the on-going investigation and report submittal activities. Based on the approved RAWs, these systems will be improved and additional systems will be installed, operated, and monitored during Port redevelopment and beyond. Cleanup progress will continue to be monitored and reported in Remedial Action Progress Reports submitted to the NJDEP.
