NJDEP has been indicating for months that letters to responsible parties would include a priority ranking (one through five). Now NJDEP is reporting that letters to responsible parties are being revised to remove the site score and will be a request for information. This will provide responsible parties with an opportunity to submit data prior to the sites score being calculated. The letters will most likely request information such as the following:
Only an LSRP can respond to the request for information so the letters are not expected to be distributed until after the May 7, 2012 deadline when all sites are required to retain an LSRP. Responsible parties will need to log-in to the NJDEP website and allocate rights to their LSRP so they can submit the data within 60 days of receipt of the letter. However, calculation of scores will not be able to be completed online.
Responsible parties will receive a matrix (or a spreadsheet in the case of a party with multiple sites) that describes the human health and ecological impacts associated with the site. Instead of receiving an actual score for each associated layer, expect to see a “yes” or “no” indication if the site contamination impacts specific receptor. For example, if a site has vapor intrusion that impacts surrounding residential properties, the site’s matrix will simply confirm that there are vapor intrusion impacts to the surrounding residential properties, but will not provide an associated score. This diagram was posted by NJDEP to explain how categories will be calculated.
NJDEP still intends to post the scores alongside the known contaminated site list in September with flags alerting the public to a site’s compliance status and known contamination of certain chemicals, including chromate, polychlorinated biphenyl, mercury, arsenic and dioxin. Sites will receive two categorical determinations, a human health category and an ecological category. NJDEP is still determining how the category will be indicated on the known contaminated site list – the higher of the two scores may be listed, the average of the two or both scores may be independently listed.
The RPS website is now active – http://www.state.nj.us/dep/srp/srra/rps/. The site is being updated and provides additional details about the system.
NJDEP staff acknowledged that only approximately 50 percent of the known sites have data in the NJDEP NJEMS system and this effort will assist NJDEP in collecting data so that more accurate categorical rankings can be calculated.