Eventually, the requirement to hire an Licensed Site Remediation Professional (LSRP) pursuant to the Site Remediation Reform Act (SRRA) will apply to virtually everyone conducting a remediation. Moreover, an LSRP cannot be a salaried employee of the person responsible for conducting remediation, so the LSRP must be someone outside the company. The time for hiring an LSRP depends on your circumstances:
- Do you have a “new” case where remediation was initiated after May 7, 2009?
- Do you have an existing case where there has been NO remedial activity in more than two years?
- Have you received a final order from NJDEP after May 7, 2009, for penalties concerning remediation or a demand for stipulated penalties under an exiting oversight document?
- Do you have an existing case where remedial activity has been ongoing?
So that you may determine your own site remediation strategy, it is important to understand how NJDEP will approach these different circumstances and how it plans to proceed with implementation of its new remediation paradigm. » Read the rest of this entry «
The investigation and clean up of contaminated sites in New Jersey will never be the same. Gov. Jon S. Corzine’s May 7, 2009, adoption of the Site Remediation Reform Act (SRRA) started a new chapter in the state’s environmental regulatory history. Under SRRA, the New Jersey Department of Environmental Protection (NJDEP) takes on a significantly reduced level of direct oversight with respect to the vast majority of cleanups. In such cases, the NJDEP will no longer be issuing No Further Action letters, or (NFAs). Rather, qualified private consultants will be authorized as Licensed Site Remediation Professionals (LSRPs), and these professionals will conduct and approve the cleanup of the contaminated sites. LSRPs will issue Response Action Outcomes, or (RAOs), to certify completion of the investigation and cleanup of a contaminated site in accordance with state standards. Each LSRP’s work product and approved RAOs may be subject to an audit by the NJDEP and a newly formed Licensed Site Remediation Professional Board and its NJDEP staff.