Child Care Centers and Education Facilities – Site Investigation and Examples

Posted on February 27th, 2017

On February 8, 2017, the NJDEP released its new “Technical Guidance for Investigating Child Care Centers and Educational Facilities.” The document is intended to provide LSRPs and other interested parties with an overview of the environmental requirements for Child Care Centers (CCCs) and education facilities (EFs). For information on required documentation for CCC or EF licensing and completion of Preliminary Assessments (PA), please see the previous blog on this topic, linked here: (link to Blog 1).

In cases where the PA indicates potential Areas of Concern (AOCs), a Site Investigation (SI) will be conducted. The SI will include sampling of AOCs to determine if the areas have been impacted by previous operations or discharges. And, in cases where contamination is identified, remedial action will likely be required in order to obtain a license to operate the CCC or EF. Once all AOCS have been addressed, or if no AOCs have been identified, the RAO can be issued.

Throughout the process, you may encounter circumstances that are unique to the investigation and remediation of future CCCs or EFs. Some examples are listed below:

• If the facility will use an off-site play area that is not on public land, a PA must also be completed for the off-site play area property. In this scenario, the LSRP must also determine if there are AOCs on or adjacent to the play area.
• An indoor air assessment may be necessary if there is a vapor intrusion concern based on known contamination in the area.
• If the CCC or EF is co-located with a dry cleaner or nail salon, then indoor air sampling will be required.
• If the play area is not capped (i.e. concrete patio, asphalt, rubber playground matting, etc.), sampling should be conducted regardless of the presence of AOCs to ensure the play area is protective.
• If there is a cap, but an AOC is present in the play area (documented discharge, past industrial use, etc.) sampling is necessary.
• When historic fill, DAP, or the historic application of pesticides is suspected on the play area, sampling will be conducted.
• Sampling should also be conducted to assess the presence of naturally occurring contaminants within the play area.
• A new RAO will be required in cases where there is an expansion being done to the existing CCC.
• Before an RAO can be issued in cases where there is historic fill, DAP, or historic pesticides, remedial action will be required. This action typically includes a cap, deed notice, and Remedial Action Permit.
• If natural background contamination is identified, remediation or a deed notice will not be required, however a physical protective barrier such as rubber matting will be required.
• A “Child Care Facility” RAO may be issued by an LSRP when a CCC leases a portion of a larger property if the CCC does not own the property, and a PA has been completed for the entire property, including any private off-site play area.
• An “Entire Site” RAO must be issued when the CCC or EF operator also owns the Property.

Through collaboration with the NJDEP and other licensing agencies, JM Sorge, Inc. has helped dozens of CCC and EF owners obtain and maintain their license. JMS is experienced in completing Preliminary Assessments and Site Investigations required for child care licensure, and is also licensed by the NJDOH to conduct Indoor Environmental Health Assessments. Please contact us at 908-218-0066 or for a Child Care Center/Educational Facility environmental evaluation.
Jim Vander Vliet, PE, LSRP
Senior Manager

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