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NJDEP Compliance Assistance Alert

Posted on August 15th, 2012

 UST Registration Certificates and Release Response Plans

Underground storage tank (UST) systems owners and operators received letters from the NJDEP in July 2012 titled “Compliance Assistance Alert – Underground Storage Tank Registration Certificates.” The letters cite the State’s Site Remediation Reform Act (SRRA), which stipulates that remediation of past and future discharges is the responsibility of UST owners and operators, and that a Licensed Site Remediation Professional (LSRP) must be hired to oversee remediation at all regulated UST sites (including those for which tank closure reports are outstanding). JMS currently has three LSRPs on staff to assist with these services. The letters also include a reminder that Registration Certificates must be kept and renewed in order to continue receiving product deliveries and operate the UST system(s). UST Registration is required to be renewed every three years, using the NJDEP’s UST Facility Certification Questionnaire (Form UST-021) located at:

https://www.nj.gov/dep/srp/forms/ust/ust021b.pdf

Updated versions of the form must also be submitted whenever contact or facility information has changed or whenever updated insurance information must be provided. 

A footnote at the bottom of the letter cites New Jersey’s “UST Rules,” which require the owner or operator to have a Release Response Plan that identifies an LSRP as a contact, among other responders, should a future release occur. The letter also notes that the release response plan must be made available for onsite inspection (i.e., to NJDEP and/or local health department officials).

JMS has prepared Release Response Plans for sites across New Jersey to assist UST owners and operators in maintaining compliance with these rules. In addition to listing these contacts, the Release Response Plan must include “the procedures to be followed in the event of a leak or discharge of a hazardous substance, pursuant to N.J.A.C. 7:14B-7.3 and 8” (sections of the UST Rules concerning confirmed discharges and remediation, respectively). For UST systems that are to be removed/closed, the release response plan must be prepared in accordance with Chapter 9 of the UST Rules, as well as the Administrative Requirements for the Remediation of Contaminated Sites (N.J.A.C. 7:26C).

Click here for an example Compliance Assistant Alert letter received from NJDEP

 

Tim Dempsey

Project Manager


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