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NJDEP Draft Technical Guidance for Child Care Centers – Area of Concern and Response Action Outcome

Posted on August 25th, 2015

NJDEP recently released a new Draft Technical Guidance Document for Investigating Child Care Centers (CCC) and Educational Facilities (EF). The draft guidance outlines the process for identifying specific areas of concern (AOCs) at CCCs/EFs. The environmental investigator should, at a minimum, consider the following to evaluate for AOCs: exposed play areas such as grass or soil cover; capped play areas; potential underground storage tanks; nearby transformers; former agricultural use; and historic fill. If the complete site history of the CCC/EF cannot be determined, soil sampling of the play areas must be conducted. Remediating a play area with a barrier instead of completing a Remedial Investigation/Remedial Action (RI/RA) is not acceptable.

Since May 2012, new and relocating Child Care Centers (CCCs) have been required to retain a Licensed Site Remediation Professional (LSRP) for their issuance of a Response Action Outcome (RAO), prior to the issuance of a child care license from the New Jersey Department of Children and Families. The LSRP must issue either an Entire Site RAO or Child Care Leasehold RAO. An Entire Site RAO can only be issued if a Preliminary Assessment (PA) has been completed for the entire property, and all Areas of Concern (AOCs) have been addressed. The Child Care Leasehold RAO may be issued for a portion of any property lot on which a CCC is proposed to occupy. The exact area of the proposed CCC must be shown on a detailed map along with the RAO document.

In situations where the CCC owner is not the property owner, the following conditions apply:

  1. the LSRP may issue a Child Care Leasehold RAO if areas of concern (AOCs) or contamination identified on other portions of the property are not a threat to the CCC; however, a PA report must still be prepared for the entire site.
  2. If the CCC and play area were constructed prior to issuing an RAO, the Entire Site RAO may be issued to the CCC owner.
  3. If the CCC building and play area were not constructed prior to issuing an RAO, an Entire Site RAO (non-child care) can only be issued to the property owner.
  4. When the CCC building and play area are constructed, a Child Care Facility RAO or Child Care Leasehold RAO is still required for the CCC owner before a license may be issued.

Draft guidance link: https://www.lsrpa.org/njdep-seeks-comments-from-lsrpa-members-on-new-draft-technical-guidance-document-for-investigating-child-care-centers-and-educational-facilities

JM Sorge, Inc. is highly experienced in completing Preliminary Assessments and Site Investigations for Child Care Centers and Educational Facilities, and also has four Licensed Site Remediation Professionals (LSRPs) on staff. Please contact JM Sorge, Inc. at 908-218-0066 or consult@jmsorge.com for a Child Care Center/Educational Facility environmental evaluation.

Kelly Jackson, Environmental Scientist


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