Posted on September 15th, 2014
On September 10, 2014 the New Jersey Department of Environmental Protections (NJDEP) released an email stating they will be changing their review process of LSRP documents, in order to streamline the process. NJDEP is required by statute to inspect all documents submitted by LSRPs. However, NJDEP has indicated that reviews of non-Response Action Outcome (RAO) phase submissions are not always necessary or an efficient use of NJDEP personnel. Therefore, with some exceptions, NJDEP reviews of non-RAO documents will be deferred until an RAO is submitted and all documents can be reviewed together.
The most important exception to the deferral of reviews is regarding receptors. NJDEP has indicated that they will still review receptor issues for each submission to confirm that sensitive populations are protected. Additionally, items that require pre-approval and permit applications will continue to be processed and reviewed when they are received.
NJDEP indicates this method will be more efficient, and by reviewing all documents together, it will eliminate many items that may have triggered a review early in the remediation but are resolved once the remediation is complete. Alternatively, any issues not addressed by an LSRP will not be reviewed until after the remediation is complete, which could also delay the cleanup process. Therefore, it is important as always to have a qualified LSRP to ensure compliance the NJDEP regulations throughout the entire cleanup process.