The New Jersey Department of Environmental Protection’s (NJDEP) Technical Requirements for Site Remediation is a key piece of legislation for all site remediators, but particularly those operating on the East Coast. Last amended in 2018, these Technical Requirements contain a provision where, under certain conditions, site remediators must action a Perimeter Air Monitoring Plan (PAMP). However, until recently, the language around perimeter air monitoring has lacked specificity, leaving many air quality professionals at times unsure of how to most effectively meet these conditions.

To help provide clarity around these often complex requirements, the NJDEP, via their Contaminated Site Remediation and Redevelopment (CSRR) program, released their long-anticipated Perimeter Air Monitoring (PAM) Technical Guidance document in December of 2023.

Coming into full effect in 2024, the PAM Technical Guidance document describes in detail how, where, and when a PAMP is required over the course of a remediation project. As part of maintaining compliance, the NJDEP lays out seven steps for the development and execution of a PAMP, which we’ll briefly cover here, along with a broad look at who this document is for and when it applies.

By spelling out, step-by-step, every element required for a successful PAMP, this guidance document is set to transform how consultants and environmental health and safety professionals approach air monitoring on remediation projects.

A perimeter air monitoring plan combines monitoring tools, mitigation processes, and action limits, towards the goal of reducing off-site emissions and minimizing the impact of remediation on surrounding communities. Along with protecting sensitive receptors, the PAM Technical Guidance document outlines additional reasons why a PAMP may be needed. These include keeping stakeholders and community leaders informed, demonstrating the effectiveness of controls, and documenting steps taken to reduce emissions for compliance purposes.

Regarding the “how”, the NJDEP puts forward requirements for both real-time monitoring and laboratory analysis. Uses for the latter include identifying contaminants of concern, confirming the accuracy of real-time results, and evaluating exposure levels where real-time tools provide insufficient cover. The document goes on to outline that guidance is restricted to remedial actions and is intended to apply only to sites that meet certain criteria.

While worker health and safety are, of course, of critical importance on any project, the NJDEP points out that PAM guidance is aimed at protecting off-site receptors. However, it’s worth noting that data used to evaluate community impact will likely have applications within a separate worker health and safety plan. Because of the detailed work required to meet all requirements, the NJDEP recommends that a “full-time perimeter air monitoring technician be designated to carry out all aspects of the PAM plan at the site.”

Within the guidance document is a handy flow chart outlining the seven steps of a successful PAMP. These steps broadly fall into three stages:

Here’s a quick primer on each of the seven steps:

Step 1: Identify Contaminants of Concern (COCs)
A PAMP is defined in the guidance document as being “designed to monitor and control off-site excursion of dust, vapor, and odors”. This may include volatile organic compounds (VOCs), particulates, or “compounds which don’t fit in these classifications (e.g., mercury vapor, metal fumes)”. Where additional characterization data is needed, lab analysis should be used to determine COCs.

Step 2: Identify Potential Airborne Exposures
Here, the NJDEP requires the development of a Conceptual Site Model (CSM), predicting how COCs may impact nearby receptors throughout the remediation process. A CSM will consider factors such as the nature of emission-generating activities, potential exposure routes, and existing background pollution near the site. Technical guidance on CSM development can be found here.

Step 3: Establish Health-Based Threshold Values and Response Levels
To help determine Health-Based Threshold Values (HBTVs), a Perimeter Air Monitoring Technical Guidance Calculator is included alongside the PAM guidance document, along with step-by-step instructions. Where multiple COCs exist on-site (as in most cases), it is best practice to target the most stringent of HBTVs, maximizing protection for off-site receptors. When calculating a response level, factors such as contaminant concentration in soil and frequency of exposure should also be considered alongside HBTVs.

Step 4: Identify Monitoring Methods and Technologies
The NJDEP defines monitoring strategy as “the selection of the type, quantity, and quality of measurements to be made”, to be determined by site-specific requirements. As outlined earlier, this typically involves both real-time monitoring and laboratory-based analysis. Selecting the correct equipment is crucial to meeting data quality objectives (DQOs) and should involve expert input wherever possible.

Step 5: Identify Sampling and Monitoring Locations and Schedule
Once you’ve selected the type of equipment, the next step involves deciding on factors such as the number of stations required, where to place monitoring devices for maximum coverage, frequency of sampling, and the distribution of fixed vs mobile monitoring devices.

Step 6: Select Actions to Address Exceedances of the Response Levels and HBTVs
Response levels should be clearly stated within the PAMP, forming an escalating sequence of actions based on the severity of the exceedance. For example, one response threshold may trigger a brief pause in activity so exposed soil can be sprayed with water, while a higher response level will necessitate a full site shut down.

Step 7: PAM Plan Review, Modifications, and Documentation
An effective PAMP should be viewed as a “living document”, one that can, and should, be modified as conditions change or new information becomes available. Reasons for altering a PAMP might include changes in the nature or duration of remediation activities, third-party emissions, or a substantial shift in contamination levels according to monitoring data. Thorough documentation is an important part of maintaining community trust and compliance.

We’ll be publishing more educational pieces like this throughout the year, highlighting the most critical factors in meeting these, and other, remediation monitoring requirements.

As an established provider of perimeter air monitoring solutions globally, with a detailed understanding of the North American market, we’ll also be providing training on understanding PAM Technical Requirements and selecting the best available technology for the job. Aeroqual's all-inclusive PAM equipment and software packages make NJDEP PAM compliance easy. Find out more about Aeroqual PAM rental packages.

Look out for more information on these PAM training programs soon, and in the meantime don’t hesitate to reach out if you have any questions!