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JMS To the Rescue! – Assistance with Remedial Action Permit Compliance

Posted on August 21st, 2020

Remedial Action Permit Compliance - Photo of Site with Engineered Cap in Foreground

After completing a Site and Remedial Investigation it is determined that the property has soil and groundwater contamination—now what? Sites do not necessarily have to be remediated below NJDEP’s standards to receive a Response Action Outcome (RAO) if the remedial action undertaken is protective of public health, safety, and the environment. Under certain conditions, it is possible to receive a Limited Restricted Use RAO or a Restricted Use RAO with the issuance of a Remedial Action Permit and the implementation of institutional controls (Deed Notice or Classification Exception Area) and/or engineering controls (sub-slab depressurization system, vapor barrier, site cap, injection wells, etc.).

JM Sorge, Inc (JMS) is experienced in handling both soil and groundwater Remedial Action Permit compliance for sites with these institutional and engineering controls. What does that entail? The NJDEP’s Technical Requirement for Site Remediation requires: (1) maintenance of the controls, (2) periodic monitoring for compliance, and (3) the submittal of biennial certifications to the Department stating that the engineering and institutional controls are being properly maintained and continue to be protective of public health and safety and of the environment.

Soil biennial certification compliance typically involves annual or semi-annual inspection of the protective cap, as dictated by the Remedial Action Permit in place for the site. The cap can be a small area or the entire site, and it usually consists of a specified thickness of clean topsoil, asphalt, or concrete that keeps the contaminated soil from being exposed. JMS can perform the inspections or train on-site personnel or a property manager to conduct the cap inspections themselves based on our client’s needs and budgetary concerns. Every two years JMS will submit a soil biennial certification on behalf of the client which encompasses completing the necessary documentation, reviewing local land use and zoning changes, reviewing changes to NJDEP’s remediation standards and emerging contaminants of concern, documenting any cap breeches, and submitting the biennial certification to the appropriate municipal, county, and state entities.

Groundwater biennial certification compliance typically involves annual, semi-annual, or quarterly groundwater sampling events, as dictated by the Remedial Action Permit in place for the site. JMS personnel are highly skilled in groundwater sampling methods in accordance with NJDEP’s Field Sampling Procedures Manual.  JMS will keep our client informed of the groundwater data trends to help determine if the CEA can be terminated early, if the CEA duration is accurate, or if a Remedial Action Permit Modification is necessary to extend the CEA duration. Every two years JMS will submit a groundwater biennial certification on behalf of the client which encompasses completing the necessary documentation, reviewing local land use, water allocation and zoning changes, reviewing changes to NJDEP’s remediation standards and emerging contaminants of concern, conducting a well search, and submitting the biennial certification to the appropriate municipal, county, and state entities.

If you would like assistance with your Remedial Action Permit compliance JM Sorge is excited to partner with you. For more information please contact us at 908-218-0066 or consult@jmsorge.com.

 

Cassandra Ward

Environmental Scientist


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