The New Jersey Department of Environmental Protection (NJDEP) recently sent out a notice announcing upcoming 2019 regulatory and mandatory time frames for Remedial Investigations, Remedial Actions, and Response Action Outcomes.
What’s the Latest?
March 1, 2019 Mandatory Deadlines for Remedial Investigation
- For UST and ISRA Case sites with a triggering event between May 7, 1999 and March 1, 2010, and an extension of the March 1, 2017 RIR Regulatory Deadline was not requested, March 1, 2019 is the Mandatory Deadline for completion of soil and/or other media Remedial Investigations and submission of the Remedial Investigation Report (RIR).
May 7, 2019 Regulatory and Mandatory Deadlines for Remedial Action
- The Site Remediation Reform Act (SRRA) set an initial statutory deadline of May 7, 2014 for parties to complete the remedial investigation for sites where the discharge was discovered prior to May 7, 1999 (N.J.S.A. 58:10C-27a(3)). SRRA was subsequently amended to allow responsible parties to apply for a two year extension of the initial statutory Remedial Investigation / RIR deadline to May, 2016.
- For a responsible party that did not obtain an extension of the initial statutory RIR deadline, May 7, 2019 is the Mandatory Deadline for completion of soil only Remedial Actions and submission of the Remedial Action Report (RAR) and Response Action Outcome (RAO).
- For a responsible party that did not obtain an extension of the initial statutory RIR deadline, May 7, 2019 is the Regulatory Deadline for completion of soil and other media Remedial Actions and submission of the RAR and RAO.
- For responsible parties that obtained an extension of the May 7, 2014 RIR deadline to May 7, 2016, May 7, 2019 is the Regulatory Deadline for completion of soil only Remedial Actions and submission of the RAR and RAO.
Failure to meet the Remedial Investigation and/or Remedial Action mandatory deadlines can subject the site to Direct Oversight requirements found in N.J.S.A.58:10C-27(a)(2) and N.J.A.C. 7:26C-14.1, et seq.
The regulatory deadlines can be found in the New Jersey’s Technical Requirements for Site Remediation at N.J.A.C. 7:26E-4.10(a) & 5.8(b).
We Can Help
Whitman’s staff currently includes four individuals that are certified as Licensed Site Remediation Professionals (LSRPs) who have significant experience working with the NJDEP. This includes Ira Whitman, PhD, PE, LSRP, who serves on the New Jersey Site Remediation Professional Licensing Board as well as the Site Remediation Advisory Committee.
If you have any questions about these deadlines, please contact Michael Metlitz, LSRP, Senior Vice President, below.
Contact
Michael Metlitz, LSRP
Senior Vice President
mmetlitz@whitmanco.com
(732) 390-5858
Posted on February 12, 2019
