Letter from Site Administrator

December 2021

I have served as the court-appointed Site Administrator for nearly six years. I accepted the appointment, in part, because, growing up in Jersey City, I became very familiar with the locations and residents near some of the PPG cleanup sites. This gave me an added motivation to make sure the contaminated sites are remediated and restored safely, effectively, and efficiently.

Since my appointment in January 2016, a total of 23 PPG sites have required investigation, remediation and restoration. I am pleased to report that at 18 of the 23 sites the soil remediation and restoration field work has been completed. At all of the sites, groundwater investigation and/or remediation is either complete or in progress.

At the sites where the soil remediation has not been completed, any exposure to occupants of the properties and the public is controlled by interim remedial measures, where required. These measures range from liners and concrete foundations to asphalt roadways and other controls to prevent direct contact with chromium impacts that remain in the soil under buildings or other structures or surfaces.

Source of the Chromium Contamination

The source of the chromium contamination at the PPG sites dates back to a chromium manufacturing plant operated by a PPG predecessor company from 1911 to 1963. The plant was located in Ward F of Jersey City, east of Garfield Avenue and south of Berry Lane Park and the Hudson-Bergen Light Rail line, on the banks of the former Morris Canal.

The chromium processing operations at the PPG plant generated a residue known as chromate chemical production waste or CCPW. The CCPW was used as fill in construction projects in Hudson County, primarily Jersey City and Bayonne. It was also used in roadway construction and to fill portions of the former Morris Canal. CCPW contains hexavalent chromium, which, according to scientific reports, can cause lung cancer in humans. It has also been linked to other health effects, such as respiratory and skin conditions.

The “JCO”

On June 26, 2009, a Partial Consent Judgment Concerning the PPG Sites (the “JCO”) was entered with the Superior Court of New Jersey. The JCO binds PPG, the New Jersey Department of Environmental Protection (“NJDEP”), and the City of Jersey City to work together on a process that enables PPG to remediate and restore chromium sites in Hudson County.

The terms of the JCO require the appointment of an independent Site Administrator to oversee the remediation and restoration of the sites. This responsibility also includes developing a judicially enforceable master schedule, facilitating the parties’ progress in meeting master schedule milestones, hiring an independent technical consultant, maintaining regular communications with community representatives, overseeing remediation in a manner that permits redevelopment and communicating the public’s concerns to the parties.

Once a site is remediated in accordance with NJDEP standards, the site is removed from the JCO. In some cases, the final remedy for a site requires engineering and institutional controls. These are physical barriers or legal restrictions designed to prevent human exposure to any remaining chromium. In these cases, the site is transitioned to the Licensed Site Remediation Professional (“LSRP”) program. This program requires an LSRP to oversee proper maintenance of the engineering and institutional controls under permits issued by NJDEP.

My communications with the community have been accomplished through various means, including periodic public meetings and publication of annual newsletters. PPG, NJDEP, the City of Jersey and I also collaborate on maintaining this website. Posted to the website are copies of cleanup reports, progress reports that I have filed with the court, the master schedules, newsletters and other pertinent information.

How the Remediation of CCPW is Accomplished

Remediation of chromium impacts in soil and groundwater at the Garfield Avenue Group of Sites involves different methodologies. Where CCPW was found in soils under buildings, parking areas and roadways, the remediation is accomplished, to the extent feasible, almost exclusively by excavation of the impacted materials. This requires removing the impacted material using earthmoving equipment, placing it into trucks and transporting it by truck or rail off-site to licensed disposal facilities.

Based upon investigations performed to date, the only PPG site that has required active groundwater remediation is Site 114 and surrounding parcels. This is the location of the former PPG chromium manufacturing plant.

Groundwater at Site 114 has been impacted by the leaching of chromium in soils under buildings and other areas, including in the former Morris Canal, which ran through the site. All of the chromium-impacted soils at Site 114 that required removal have been dug up, hauled away and given final approval by NJDEP. Chromium-impacted groundwater at Site 114 and surrounding parcels, however, is still in the process of being remediated.

Remediation of groundwater has proven to be complex and quite challenging. While the groundwater at Site 114 (or elsewhere in Jersey City) is not used for drinking water, NJDEP is charged with ensuring that the ultimate remedy for Site 114 groundwater is protective of human health and the environment.

After performing numerous pilot studies, it was determined that active remediation of groundwater at Site 114 and surrounding parcels would be accomplished via a combination of technologies, including extraction of the chromium-contaminated groundwater and/or injection of reagents into the groundwater that cause chemical or biological reactions. Extraction involves pumping the impacted groundwater from the site, treating it at a treatment plant on the Garfield Avenue Group of Sites to remove the chromium and then discharging the treated water to the Passaic Valley Sewerage Commission under the terms of a permit issued by PVSC.

Injection involves adding biological reagents (such as molasses) or chemical reagents (calcium polysulfide) into the groundwater to reduce hexavalent chromium to a more benign form. PPG has also proposed the use of reactive zones consisting of long-lasting reagents and an extensive well system to monitor the groundwater plume. (An article on page 3 of the December 2021 newsletter provides more detail on the proposed groundwater remedy for Site 114 and the surrounding parcels.).

Project Delays/Field Work Issues

Environmental remediation is similar to a construction project. As such, it is subject to many unforeseen problems that can affect the schedule. Some obstacles in meeting milestones for completion of the PPG work include: weather, unanticipated below-ground conditions (e.g., buried debris, underground storage tanks), discovery of more contamination than expected, utility clearances and, of course, the COVID pandemic.

Disputes with property owners can also cause delays. The disputes can result from disruption of the business operations of the property owner and disagreements over access as well as the scope of remediation. Disagreements over the type or extent of restoration following remediation can also arise. I have been asked on numerous occasions to facilitate resolution of these disputes. In some cases, cleanup sites are left in a better condition than they were before remediation.

Potential Conflicts Between Development of a Site and the Remediation Activities

The complexities and unforeseen conditions at a remediation site can interfere with a property owner’s intention to develop the remediation site or put it to its highest and best use. Site 114 is a prime example.

Site 114 is part of the Canal Crossing Redevelopment Area. This area is approximately 111 acres in the southeastern section of Jersey City. The City has designated a redeveloper for Site 114 and other portions of Canal Crossing. The redeveloper is hoping to receive site plan approval from the City and to commence redevelopment work at Site 114 in 2022.

Conclusion

I hope this summary provides some insight into my function as Site Administrator for the past nearly six years. I encourage all interested parties to read the December 2021 newsletter and other documents posted to this website for more information about the status of the remediation work at the PPG sites.

The public is encouraged to use the following email address and phone number to reach me with any questions about the PPG sites: Email: Info@chromecleanup.com; Phone: 201-777-2099.

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RONALD J. RICCIO
Site Administrator, PPG Chromium Cleanup Sites