FAQ

Besides constructing sustainable engineering controls for the 2 million tons of sludge that was deposited along the Rahway River in the last century, and stopping the annual seepage of tons of cyanide into the river that has been going on since then, there are other benefits to capping the site. Work calls for the preservation of all 40 plus acres of wetlands, the creation of 50 to 60 acres of new natural upland habitat where the sludge lies exposed today, and funding millions of dollars in other recreational and environmental improvements in the Borough.

Class B facilities get paid to receive recyclable materials which they recycle into useful products. The five-year remediation and the host community benefits will be funded by revenues derived from recycling the soils used to cap the site, not taxpayer money.

There are dozens of Class B Facilities across the state. They receive and recycle a variety of recyclable materials to prevent them from being landfilled. In some cases, the recyclable materials are processed into products at the Class B facility to ensure they meet the market specifications for their intended use. Most of these Class B Facilities in New Jersey are permanent fixtures. They recycle incoming material and then ship the recycled product back out to be reused in the commercial market. In the case of soil, these other Class B Facilities will recycle the slightly contaminated soil and then ship the end product out to be used as fill at a multitude of locations across the state.

For this project, however, the Class B Facility is only temporary and is designed and permitted to manufacture the soil product exclusively for the site remediation effort. Constructed of brand new electric-driven equipment, the Class B Facility for this project will recycle and manufacture a soil product that can only be used at the site to construct the cap over the impoundments. The manufactured soil product will meet the regulatory defined clean fill specifications set forth in the permits, and provide the geotechnical properties critical to the construction and performance of the cap for the remediation project. Unlike the other Class B Facilities in the state, this will be a temporary facility to only manufacture the materials needed for the project, and no recycled product is permitted to be shipped offsite to be used at other locations all over the state.

This particular FAQ has been posted because of the incredible amount of misinformation incorrectly identified by project detractors that has been parroted in the press. The cap will not be 29’ thick.

The cap will range between 5 and 15 feet thick. The average thickness is 8 feet.

A cap is the most effective means of remediating the site and will have the least impact on the surrounding wetlands. The remediation calls for a minimum thickness of 5 feet of engineered fill to meet the requirements of structure and low permeability. The thickest parts of the cap will be in the middle of this very wide site to allow for drainage from the middle towards the perimeter at a slope of 2 to 3 degrees, i.e. a very flat gradually sloping profile designed to keep water from ponding on ground above the sludge.

The federal government (USEPA) created minimum requirements for capping waste, and New Jersey has adopted these minimum requirements, in many cases strengthening them. In most cases, a cap design calls for more stringent criteria.

The cap design for these sludge impoundments is no exception. Site-specific requirements were determined and addressed by the engineers responsible for the design. They considered a variety of factors, made their calculations, and vetted the design and governing criteria with the host of regulating authorities (state, county and local) before approving and stamping the plans. For this remediation, structure and infiltration were primary concerns and they were thoroughly investigated, addressed and vetted before the plans were approved.

Specifically, the approved remedial action workplan calls for capping the 85 acres of upland impoundments with stabilized, low-permeability, cement modified soils that have been engineered, produced, placed and roller compacted on site at a slight grade to eliminate direct contact with the sludge and prevent water from landing on and percolating into the sludge.

A thick vegetative layer, meeting residential standards for all constituents, is then be spread on top of the compacted sub-base material.

 
This is hydro-seeded and planted with native species to support vibrant new wildlife habitat.

Detractors claimed that no modelling was performed. In fact, many kinds of environmental and geotechnical modelling were performed as part of the investigation for the Carteret remediation.

Mass Balance Water Modelling was performed and reviewed in detail with DEP to determine the effectiveness of the cap design. The results were extremely positive.

The consolidated sludge and low-permeability cap virtually eliminates percolation. The model shows more than 99.7% of the precipitation is eliminated.  This reduces the amount of cyanide being leached from 18 tons per year to maybe a few ounces per day from the entire 85 acre upland site.  In addition, the potential for wash out and percolation caused by erosion and tidal storms is also eliminated.

There are no residences within half a mile of the site and there are huge tanks shielding the facility from view. Still, the contractors performed air modelling and reviewed both the parameters and final modelling results with DEP. The parties agreed that no adverse impacts were found.

Geotechnical modelling was extremely thorough, performed by an internationally recognized geotechnical firm.



The consultant's findings determined that the project loading was safe and effective, and provided recommendations that again were thoroughly reviewed with DEP. The bottom line: the underlying sludge will consolidate safely under gradual loading to form a sturdy base for the cap.

Both the settlement and the stability analysis indicate that the proposed grading plan can be safely achieved as long as construction is performed in stages with waiting periods between stages. It is further understood that the completion of the fill will take approximately 5 years; therefore this should not be an issue. Based on the current available data, 90% consolidation of the cohesive soil underneath the sludge will take two to three years after the placement of fill. For a sludge layer 13 feet thick, the estimated time required to reach 90% of consolidation is approximately 48 days.

The loading plan was calculated with significant safety factors at each step, and these factors will be monitored throughout the construction of the cap to ensure proper consolidation.

Traffic studies, noise evaluations, and many other potential environmental considerations were considered, evaluated, presented for review and discussed with experts and in the five public hearings conducted prior to issuance of the permits.

The Remediation Contractor is Soil Safe, who has operated recycling facilities in New Jersey for over 18 years. An existing facility in Southern New Jersey operates under 14 separate permits and has processed and recycled over 6 million tons of soil in New Jersey alone. Soil Safe is inspected by the DEP Enforcement at least once a month and by four other agencies one or more times a year. Soil Safe has an impeccable soil recycling industry compliance record – hands down the best in the state. Soil Safe is uniquely qualified and experienced to deal with the environmental and geotechnical challenges this Site presents

Yes. Several times, but the attempts always failed. Other than maintenance on some failing berms and application of composted sewage to promote vegetation, little has been done to the site since the early 1970's. Although there was an attempt to control access to the site with fencing and signage, local citizens advised how they used to play on the site as kids and evidence of that remains today. Under the new plan, the sludge will be capped with a structural fill material which will eliminate all direct contact with the contamination.

Today, rainwater that lands in the "bathtub-like" impoundments percolates through the sludge into the groundwater, or "breaks out" somewhere on the exposed berm face to ultimately make its way to the River. This percolated breakout water (leachate) contains contaminants dissolved from the sludge. The engineered cap will virtually eliminate this percolation.

In 2002, the site was issued a "No Further Action" letter by the DEP permitting the lagoons to be left as is, based on strict maintenance of the engineering controls, deed restrictions, inspections and reporting procedures. Provisions were made to address deficiencies should they occur. The NFA provided no long term plans for using the site and was, by design, a temporary solution.

Of note:

• In the 1980s, six inches of composted sewage sludge was placed on the top of some of the pits to promote vegetation and avoid sludge dust from continuing to blow on the New Jersey Turnpike (the highway had to be closed several times because of dusting issues).
• Not surprisingly, most of the composted sewage washed off over time. Large areas of the sludge are now exposed; it is nearly impossible for vegetation to grow in this cyanide-infused material, leaving acres of the quicksand-like sludge exposed to animals and humans who make their way onto the site.
• For each of the last 40 or so years since the site stopped receiving material, up to 28 million gallons of rainwater have seeped through the sludge every year into the Rahway River. Data from the 1980s suggested as much as 100 pounds of cyanide being released into the river every day. Recent studies suggest similar amounts being released still today. Nothing has changed to stop this.

The site certainly is not clean, but it is not the most toxic site in the State, not even in the regional area. It is a problem site, unusable, unstable and presents a danger to the community, migratory and wandering wildlife, and the River. These deficiencies have been investigated, documented and are – finally - being addressed in a comprehensive manner.

The deficiencies include: leaching of cyanide and other contaminants into the groundwater and River, overtopping of berms by flood waters in low lying areas of the site, deterioration of the berms holding back the sludge, and direct exposure of sludge to animals and trespassing humans. In addition to the sludge, the investigations also determined that thousands of tons of undocumented fill have been placed on site over the years.

American Cyanamid Company (now Cytec Incorporated) used the Impoundments from the mid-1930s through 1974 to dispose of a mixture of acidic sludge from an alum manufacturing process and alkaline sludge from a yellow prussiate of soda (YPS) manufacturing process. American Cyanamid Company owned and operated a chemical manufacturing plant, known as the Warner Plant, located in Tremley Point across the River from the site. The Warner Plant operated from 1917 through 1998. In addition to the alum and YPS, the plant produced a number of organic and inorganic products.

Waste alum and YPS sludges from the Warner Plant were slurried and pumped across the Rahway River to the project site. Surface water from the Arthur Kill was used to liquefy the slurry for pumping. River water was also pumped to the site between discharges to prevent sludges from settling in the pipeline. YPS sludge disposal at the site ended in 1970. Alum sludge disposal ended in 1974. Demolition debris from work performed at the Warner Plant were used on the project site for road and berm reconstruction.

Evidence indicates that undocumented fill material has been imported and used on the site over the years to maintain the dikes and to stabilize the surface in several of the impoundments. This fill material was imported from various sites over the years for operations and maintenance of the disposal areas. Because it was imported to the site for the operations of the impoundments, the fill may not be considered historic fill, as defined by the Tech Rule. However, the fill has the physical and chemical characteristics of historic fill.

The sludge is saturated and soft, but exposed surfaces can dry out in extreme weather and create wind-blown dust. As long as it remains saturated, it remains viscous and will not support weight. When it is consolidated, the material strengthens.

Project leaders engaged a world class geotechnical firm to investigate and develop a plan to progressively load and monitor the underlying sludge slowly, allowing the sludge to consolidate under load over time before adding more weight and achieving more consolidation. This method of soil consolidation and progressive strengthening is commonly used and well understood. The plan was reviewed in detail by several geotechnical experts and by DEP, and was found to be extremely well documented and developed.

While there is universal agreement that the berms, without stabilization, will fail, loading of the cap is designed to not push outwards against the berms but downwards against the sludge to promote consolidation. The loading will be monitored so that the consolidation process of the impoundments occurs safely at its desired pace. In time, the impoundments will become much harder that the berms themselves and eliminate the risk of failure.

Except to investigate them and perform a small approved installation (totaling only 1500 square feet), no wetlands were or will be disturbed in this project. In fact, the project will help preserve all of the 40 to 45 acres of existing wetlands, as well as the local ecology. Freshwater wetland permits were secured because much of the sludge was deposited directly into the transition areas that are supposed to be protecting the adjacent wetlands. These contaminated transition areas cannot support the ecological value of the wetlands.

As part of the project, all the destroyed transition areas that were filled with the sludge will be capped and vegetated according to a DEP approved restoration plan to protect humans and wildlife from the cyanide and other contaminants. This revitalized habitat will function as true wetland transition areas.

Several times in the past, the previous landowners and potential developers suggested alternative proposals to remediate the site. All past efforts involved capping the site, usually with processed dredge spoils. All these schemes failed to materialize. The reason was either that: it cost too much; the ground was too unstable and no one wanted to spend the money to figure out how to stabilize it; or, there wasn't enough reliably available and acceptable capping material. This was incredibly frustrating to local officials, the citizens of Carteret and the environmental community who wanted the pollution to stop.

Not one realistic or viable alternative was ever outlined and vetted beyond the concept stage. In the meantime, it's been crystal clear to both public and private parties involved that the sludge continues to leach, and the site continues to deteriorate. Wishful thinking won't stop that; engineering, capital and responsible action will.

The new landowners looked at the past trials and errors and engaged an LSRP to evaluate, using federal criteria, seven alternatives to remediating the property. Two alternatives met the criteria, including the dredge alternative, but this was found to be unreliable – the material was not readily or reliably available. The remaining alternative – capping with recycled soil - was the only effective and feasible method.

"All the other alternatives for site remediation were determined to be ineffective in remediating the site and/or were not feasible." - NJDEP Land Use Permit

No it won't, according to the DEP's top experts.

This site can be impacted by tidal flooding or ocean surge, which is exactly what happened at Rahway Arch during Superstorm Sandy. Flooding concerns have been raised by some who have confused "tidal flooding" from the ocean with "inland flooding" from stormwater runoff upstream.

Vince Mazzei, a supervising DEP environmental engineer said that neither type of flooding will be impacted by Rahway Arch. Mr. Mazzei should know. He is the author of the Flood Hazard Area Control Act rules and its recent amendments in the wake of Superstorm Sandy.

"The flood elevation of the property is 12 feet above sea level," Mazzei said. "The material placed on top is going to be above that elevation. If the water was trying to get from inland sources to the ocean, and you put something in the way, it would push the water onto someone else's property. But in a tidal flood plain, the water is coming from the ocean, irrespective of houses or a landfill. If you look at the tidal flood map, the surge goes on for miles, past the Turnpike. No matter what you fill in or don't fill in, it's not going to change the tidal flood conditions in the area."

More information about flooding includes:

• The site is not in the floodway, and nothing in that adjacent floodway will be changed by this project – in fact it will be preserved.
• Likewise, no wetlands will be disturbed by the project – none – and they will still be subject to flooding.
• The site is already filled with sludge and undocumented fill. And it is very important to understand that these lagoons were filled up long ago to elevations that exceeded the base river (non-tidal) flood. It already has 12-foot-high berms along most of the riverbank; you can't even see the site from the Rahway River.
• The site is tidal - severe flooding in this area is caused by storm surge coming from the ocean, not water flowing down the river. (Note: Superstorm Sandy damaged two of the berms, and every day the project is delayed, the damage worsens).
• Tidal surges wash away exposed sludge. The design will cap the sludge, preventing it from being washed away by storm surges from the Arthur Kill. The cap will maintain the floodway and the potential overflow connections around the site that already exist.
• The problems generally associated with upstream River flooding are caused by constrictions existing upstream from this location which restrict the normal flow of water during storms. There is nothing project engineers can do to change or affect those constrictions – they are all primarily caused by the NJ Turnpike which acts like a seawall for floods from the ocean, and tide gates for floods from inland sources.

For more information about flood issues and myths, please visit Project History

The Borough of Carteret and two companies: Rahway Arch Properties, LLC and Soil Safe, Inc.

About Rahway Arch
Rahway Arch Properties LLC (RAP) was formed with the sole purpose of developing a plan to purchase, clean up and stabilize the old American Cyanamid Sludge Impoundments in Carteret.

Together with the Borough of Carteret, an experienced remediation contractor, a Licensed Site Remediation Professional (LSRP), interested environmental organizations, and fully licensed engineers; Rahway Arch has developed, permitted and implemented just such plan.

RAP contacted and interviewed remediation contractors and engineers to investigate alternatives for closing and stabilizing the site. After months of discussions with other firms, RAP contracted with Soil Safe to provide the permitting, closure, and stabilization services to correct the site's deficiencies relying upon Soil Safe and their world class consultants years of experience with similarly challenged properties.

An agreement was reached with the Borough on construction, operational limitations, and host community benefits; and the Borough agreed to include two adjoining Borough-owned contaminated parcels within the impoundments in the clean-up plan. RAP conducted site tours with the NY/NJ Baykeeper, Edison Wetlands Association, Borough staff, NJDEP officials and staff, Rutgers experts, local citizens, County officials, and others to educate, inform and answer questions about the project. Following these tours, everyone could see the conditions at the site needed fixing as soon as possible and supported the project. RAP and Soil Safe filed for permits and attended public hearings and town hall meetings to document, inform and further explain their plans.

Soil Safe, Inc.
Soil Safe has recycled more than 21 million tons of soil from more than 40,000 projects nationwide. Soil Safe's recycled engineered soil product is a National Green Building Standard (NGBS) certified "Green Product". The facts about Soil Safe:

• Soil Safe's Logan Project successfully manages 14 separate local, state and federal permits. Their operations are highly regulated and inspected. The Carteret project will have a similar number of permits.
• Soil Safe's New Jersey projects have been inspected by DEP and other regulating authorities more than 200 times in the past 10 years; equating to a decade long average of one agency inspection every 18 calendar days. Administrative reports are routinely required and monitored by four bureaus within DEP.
• Soil Safe has the best compliance record in the industry. Soil Safe operates under a proprietary state-of-the-art information system, unparalleled by any other recycling firm in the country. The system tracks all soil and corresponding data into and out of the recycling process on a real time basis. The information system allows real time reports of all shipments and operations.
• Soil Safe's management has more than 200 years of combined experience in remediating sites including Superfund sites, Installation Restoration Programs at numerous Dept. of Defense military bases, large Dept. of Energy Environmental Remediation contracts, management and execution of EPA's Emergency and Rapid Response Contracts involving hundreds of clean-ups, environmental remediation programs for the Bureau of Reclamation, public and private sector landfills, dredge processing and recycling, and remediation of hundreds of sites involving both RCRA hazardous and non-hazardous contamination.
• The Salem Landfill project was the first capping project of a publicly owned landfill completed using funding solely from the private industry sector in the State of New Jersey, and was subsequently bestowed the NJ Environmental Engineering Project of the Year award in 2002.

The potential to impact to air quality was evaluated as part of the design process for the Metro12 Class B Recycling Center and remediation. This evaluation was used to:

• Design the facility to minimize air emissions
• Ensure compliance with National Ambient Air Quality Standards (NAAQS) and New Jersey Air Quality Standards
• Classify the facility under New Jersey regulations for Air Pollution Control (NJAC 7:27)
• Develop the conditions for the Air Quality Permit
• Ensure that the facility would not create an adverse health risk to the surrounding community

Best management practices and control technologies were identified to minimize the potential to emit particulates from operations. These controls and practices have been in place for 12 years and have proven to be extremely effective at Soil Safe's other facilities. In addition, all stationary processing equipment will be electric powered. A water truck will be used to proactively reduce potential emissions during operations.

The potential to emit (PTE) particulate matter was calculated using the U.S. EPA emission factors (AP-42) for total suspended particulates (TSP), respirable particulates (PM-10) and fine respirable particulates (PM-2.5). The PTE volatile organic compounds and toxic air pollutants (TAP) was calculated based upon the maximum allowable concentrations in the recycled soil.
The PTEs were below reporting thresholds for all compounds; the levels equated to 10% to 15% of the allowable emissions from a gas station. This is a very small potential to emit.
Based upon these PTE calculations, the future facility was classified as a Minor Source under New Jersey regulations for Air Pollution Control (NJAC 7:27). As a result, the NJDEP Air Quality Permitting Program determined that dispersion modeling of the site was not required.

Nevertheless, Soil Safe setup and ran a dispersion model of the site and simulated the potential impacts to air quality from the facility operations. The modeling confirmed that the Class B facility and the site remediation would have no adverse impact on air quality.