This panel addressed two main issues:
- Is the permit process a second bite at the apple? Does it allow the NJDEP to remove decision-making authority from a Licensed Site Remediation Professional?
- What level of review is required to obtain a permit for a site that was previously closed with a conditional No Further Action Letter?
On the 1st topic, Peter put forth his opinion that the NJDEP Ground Water Remedial Action Permit has an important and beneficial role in the remediation process. However, the NJDEP permit approval process must be expedited. Permits should all be reviewed and approved in 60 days. Current metrics from the NJDEP Site Remediation Program indicate there are currently 228 permits pending approval for August of 2015. In addition, Peter recommended that a separate permit process should be established for Vapor Intrusion.
On the 2nd topic, Peter indicated that an LSRP has to review the work that leads up to the issuance of the prior conditional No Further Action Letter. Ultimately, the LSRP must be confident that the remediation is protective of human health and the environment in order to certify a permit application. This is a difficult message for a client to hear when they believe that remediation is complete since they have previously received a No Further Action Letter.
Others panelists and members of the audience put forth opinions that the permit process is onerous, unnecessary and undermines the basis of the Licensed Site Remediation Professional Program.
Ultimately, most of the audience agreed that a quicker review and approval of the initial NJDEP ground water remedial action Permit applications and ground water remedial action permit modification applications is necessary to continue the success of the Licensed Site Remediation Professional program.