Offices of the Delaware Department of Natural Resources and Environmental Control
3-17-17 Press Release Submissions made to Sussex Countian, Dover Post, Delaware Gazette, Delaware Free News, and the High Tide News, State Senators: Simpson, Lopez, Pettyjohn, Richardson, Hocker; State Representatives: Kenton, Bolden, Schwarzkopf, Wison, Short, Dukes, Collins, and Gray; Sussex County Councilmen: Vincent, Wilson, Burton, Cole, and Arlett; City of Georgetown Mayor and City Council; Green Delaware, Delaware Audubon Society, Delaware Center for the Inland Bays, Clean Air Council, White Clay Watershed Association, Sussex County Land Trust, Partnership for the Delaware Estuary, Delaware River Keeper; Science/Environmental Clubs for High Schools: Cape Henlopen, Del Mar Senior, Laurel Senior, Milford, Seaford, and Woodbridge.
State of Delaware Proposes to Approve Sketchy Cleanup Plan for Georgetown Brownfields Site
The State of Delaware Department of Natural Resources and Environmental Control (DNREC) has proposed to approve a sketchy cleanup plan for the J.G. Townsend Site located on Pepper Street in Georgetown.
The J.G. Townsend Site in Georgetown was formerly a service station where high levels of lead in shallow soils were documented. Soil tests showed up to ten times hazardous waste levels and normally that hazardous substance at that concentration should be contained in a landfill. Over the last 10 years the plan was to dig up a few hundred cubic yards of soil for disposal but the plan changed. Now, the DNREC is poised to approve a substandard plan that doesn’t involve excavation.
The problem is that contaminated soil is in contact with shallow groundwater and there is lead in that too. The DNREC proposed to discontinue groundwater monitoring but provided a technically unsound rationale for doing so. Close to the property line they only sampled two (2) wells two (2) times and twelve (12) years apart. The results for filtered samples showed an 100% increase in lead concentrations over 12 years but the levels were still below screening levels. Non-filtered samples were also tested and one (1) showed lead higher than screening levels; however only 2 unfiltered samples were tested but no data was available for comparison 12 years apart. That testing program was unusual and does not meet industry standards for groundwater monitoring programs; it is irresponsible for the DNREC to propose discontinuation of groundwater monitoring based on that data set. One conclusion which may be drawn from the available data is that since lead was detected at that location, it indicates that it is migrating from the source toward the property line. But further information is needed to figure out how much. It is customary to map groundwater contaminant plumes; but they skipped that. They just pulled samples at the property line and there isn’t enough data to plot on a map to show that the remedy approach is appropriate.
Environmental Review, Inc. reviewed the proposed cleanup plan and supporting documents and informed the DNREC that the groundwater data set that they relied upon to make their decision to close the wells at the Site was inadequate. DNREC should recommend placement of additional wells and groundwater monitoring on a quarterly or annual schedule. That way trends in the data could be used to support decision-making before deciding to close the wells. The environmental group also suggested that potential contaminant transport mechanisms in the aquifer matrix should be studied. Aquifer tests are needed to determine how fast the groundwater is moving and find out what volume of groundwater is passing under the site. That way an estimate of contaminant mass that is migrating away from the contaminant source area can be made. Site conditions are favorable for a lot of groundwater flow since it is underlain by medium-grained sand and groundwater slopes 2%. Another consideration is that a contaminant transport mechanism can be facilitated when contaminants latch onto small particles and move with the groundwater. Those small particles may be comprised of minerals or organic matter for example from decaying foliage. These factors combined make it clear that DNREC should require further study, investigation and monitoring at the Site. The simplest thing would be to excavate the contaminated soil and conduct groundwater monitoring until such time that the trends in the data demonstrate that the cleanup program was effective. But if the contaminated soil is left in place then provisions for monitoring should be kept in place.
Tom Price, Executive Director of Environmental Review, Inc. said: “There are a technical deficiencies associated with this cleanup plan but we’re hopeful that improvements will be recommended by the department. Members of the community who would like to learn more about the project should call the Project Manager Mr. Rick Galloway of the Department of Natural Resources and Environmental Control at (302) 395-2614 and request a public meeting. If anyone can influence this project it is the local community.”
View the DNREC Public Notice for the cleanup plan at:
https://onlinedocs.dnrec.delaware.gov/docfinity/servlet/repository?j_username=DNRECAPI&j_password=API@dnrec2012&id=6744d73fd212a86f0iz5km1bd0010000&clearRedaction=false&annotate=true&thumb=false&pdf=true
View the full version of comments by Environmental Review, Inc. comments at: http://www.envreview.org/index.php/delaware/91-delaware-department-of-natural-resources-and-environmental-control-amended-proposed-plan-of-remedial-action-dated-february-10-2017-for-the-j-g-townsend-site-located-at-pepper-street-in-georgetown-site-de-1338-2-25-17
3-16-17 Press Release Submissions were made to Sussex Countian, Dover Post, Delaware Gazette, Delaware Free News, and the High Tide News.
Department of Natural Resources and Environmental Control Receives Public Comments for Cleanup Plan for Georgetown Site
On February 10, the State of Delaware Department of Natural Resources and Environmental Control (DNREC) solicited comments from the public for a proposed cleanup plan at the J.G. Townsend Site, Pepper Street, in Georgetown.
The J.G. Townsend Site in Georgetown was formerly a service station where high levels of lead in shallow soils were documented. The DNREC proposed to approve a cleanup plan which included capping the ground surface and placement of a land use covenant on the property to restrict digging and future usages to commercial or industrial purposes. The cleanup plan proposed to discontinue groundwater monitoring and close groundwater monitoring wells.
Environmental Review, Inc. reviewed the proposed cleanup plan and supporting documents and suggested that a contaminant transport mechanism in the aquifer matrix at the site had been overlooked. DNREC was poised to approve closing of the groundwater issue based on an assumption that lead was bound up in soil and that migration was not expected since only low levels of lead was observed in filtered samples near the property line. However, the environmental group noticed that an unfiltered groundwater sample showed lead above screening levels. The group suggested that site conditions including sandy soils, shallow groundwater, and contaminant concentrations ten times higher than hazardous waste levels may be facilitating contaminant transport in the aquifer matrix.
The environmental group suggested that more active plans should be adopted including further investigation, continued groundwater monitoring, and active cleanup. Tom Price, Executive Director Environmental Review, Inc. said: “It is very encouraging to see that the Department of Natural Resources and Environmental Control made the proposed cleanup plans and supporting documentation available for public viewing on their website. We are hopeful that the department will recommend further investigation and removal of the contaminated soils by excavation.”
View the DNREC Public Notice for the cleanup plan at:
https://onlinedocs.dnrec.delaware.gov/docfinity/servlet/repository?j_username=DNRECAPI&j_password=API@dnrec2012&id=6744d73fd212a86f0iz5km1bd0010000&clearRedaction=false&annotate=true&thumb=false&pdf=true
View the full version of Environmental Review, Inc. comments at: http://www.envreview.org/index.php/delaware/91-delaware-department-of-natural-resources-and-environmental-control-amended-proposed-plan-of-remedial-action-dated-february-10-2017-for-the-j-g-townsend-site-located-at-pepper-street-in-georgetown-site-de-1338-2-25-17