EWMA header image
The Environmental Insider

 

Fast Approaching NJDEP Mandatory Compliance

Deadlines...Are You Prepared for March 1st?

 

 

The new NJDEP site remediation reforms impose several mandatory compliance deadlines.  The mandatory deadline for the following regulatory submittals is March 1, 2012, if remediation was initiated prior to March 10, 2010:

 

Preliminary Assessment/Site Investigation (PA/SI): the PA/SI is the initial site assessment of potential areas of concern (AOCs) and the subsequent investigation of these AOCs.  A PA/SI report must be reviewed by a LSRP and submitted to NJDEP by the deadline where required under the Industrial Site Recovery Action (ISRA) or Underground Storage Tank (UST) rules;

 

Initial Receptor Evaluation Form: This form identifies on-site or nearby receptors (potable wells, ecological receptors, vapor risks to building occupants) that could potentially be impacted by contamination identified at your site.  If remediation, which includes sampling, was initiated prior to March 1, 2010, then the Initial Receptor Evaluation Form must be reviewed by a LSRP and submitted to NJDEP by the deadline;

 

IEC Contaminant Source Control Report: an Immediate Environmental Concern (IEC) is determined to be present at your site when a contaminant is detected in one or more scenarios:  (a) above the applicable NJDEP standards, (b) a completed vapor migration pathway is present, and/or (c) there is a sensitive receptor, i.e. potable (drinking water) wells.  NJDEP requires that source control measures be initiated and an IEC Contaminant Source Control Report be reviewed by a LSRP and submitted to NJDEP by the deadline to document how the IEC is being addressed;

 

LNAPL Interim Remedial Measures Report:  if Light Non-Aqueous Phase Liquid (LNAPL) or free product has been identified at your site, interim remedial measures (free product removal) must be implemented and a report reviewed by a LSRP and submitted to NJDEP by the deadline.

 

For projects where remediation began after March 1, 2010, you are required to complete the above tasks within two years of initiating remediation.

 

If submittal of these documents is not completed by the March 1, 2012 deadline, the NJDEP may assess penalties and fines to the remediating party.  The NJDEP may also exercise their right to assume direct oversight of projects, including the posting of a funding source, in addition to potential fines and penalties.

 

If you need further information on these mandatory timeframes or would like to discuss your site further, please contact Sharon McSwieney, EWMA LSRP, at Sharon.McSwieney@ewma.com or (609) 799-7300, ext. 196 or Al Moffit, EWMA LSRP, at  Al.Moffit@ewma.com or (973) 560-1400, ext. 144.

Complimentary LSRP Screening

The first Mandatory Time Frame guideline is March 1; just 5 weeks away!  Speak to our LSRPs to determine if you are responsible for any documents due by this deadline at NO CHARGE.  Call Sharon McSwieney, LSRP (609) 799-7300 x196 or Al Moffit, CPG, LSRP (973) 560-1400 x144.

About EWMA

EWMA is a full-service environmental consulting and remediation firm.
 

EWMA's regional offices in New York City and New Jersey ensures our clients have prompt access to staff and other resources needed to meet their environmental needs.
 

Please visit www.ewma.com or call (973) 560-1400 for more information.

Quick Links

Author

Sharon McSwieney
Sharon McSwieney, LSRP
Assistant Vice President
Join Our Mailing List
EWMA footer image