Highlights of NJDEP CVP and SRAG Meetings

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Highlights of NJDEP CVP and SRAG Meetings

  •  All sites with case numbers older than 10 years as of May 7, 2009 must have Remedial Investigations (RI) completed by May 7, 2014 – no exceptions and no extensions.  Once you deem the RI complete, make sure to state this information on the form and in the report.
  • NJDEP is not stating they will consider a waiver or variance for the 10x rule on volatile contaminants, but they did say a permit should be filed if you think there is a downward trend of concentrations over the past 10 or 20 years, a stable plume, and no potential impact for receptors.  If the permit is received, a Response Action Outcome (RAO) can be completed for the site.  Monitoring will need to be conducted under the permit, but the case is technically closed.
  • If an Underground Storage Tank (UST) investigation is being conducted and chlorinated solvents are present onsite that are not your client’s responsibility, a second case number for the chlorinated solvents as an “Unknown” source should be established, unless it is known.  When completing the RAO for the site, state in the text that the “chlorinated case number remains”.
  • After May 2012, when Classification Exception Areas (CEA) are due for Biennial Certifications, permits will be issued.
  • If NJDEP has a copy of the files, you do not need to submit three electronic copies of those items, just the new information.
  • If a spill less than 100 gallons occurs onsite or a case number is called in for a “suspected release” and within 7 days no release was found, the case is not being handled by enforcement or the county, and the case number needs to be closed, send a letter and all supporting documentation to Kirsten Hahn at Initial Case Assignment.  No letter will come back, but it can be tracked on Dataminer.
  • RPS (Remedial Priority System) ranking and categories will be coming out in November; the client will have 60 days to submit data if they believe their ranking is too high.  This number will only come into play if a Responsible Party becomes recalcitrant.

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