Status of Site Remediation Program in NJ

Report
Site Remediation and the
Licensed Site Remediation
Professional Program
NJDEP/Air & Waste Management Association
Regulatory Update Conference
October 12, 2012
Ken Kloo, Director
Site Remediation Program
SITE REMEDIATION
PROGRAM
Assistant
Commissioner
Division of
Enforcement,
Technical, and
Financial Support
Division of
Remediation
Management
Remediation Review
Remediation Oversight
Enforcement and
Information Support
Hazardous Site
Science
Financial Services
Inspection and Review
Case Management
Site Management
Case
Assignment and Initial
Notice
Ground Water
Pollution Abatement
Fiscal Support and
Contract
Administration
Field Operations North
Remedial Action
Permitting
Environmental
Measurements and
Site Assessment
Enforcement and
Investigations
Environmental
Evaluation and Risk
Assessment
Fund Management
Field Operations South
Brownfield Reuse
Information Systems
Data Quality
Direct Billing and
Cost Recovery
UHOT
1
Publicly Funded
Response
Dredging and
Sediment Technology
Community
Relations
Site Remediation Reform Act
• May 7, 2012
• Full implementation of LSRP program
• Final rules adopted
2
Final Rules
 Reflect complete conversion to LSRP program
 “Final” rule included:
•
Amendments to ARRCS, ISRA, UST rules to make
consistent with LSRP process
•
Complete overhaul of Technical Requirements
 Completed with upfront stakeholder input
 Coincides with conversion of all cases within
SRP to LSRP process
3
Technical Guidance: Round 1

Technical Guidance topics
•
Attainment (Compliance)
•
Monitored Natural Attenuation
•
Clean Fill/Alternative Fill
•
PA/SI/RI Groundwater
•
Conceptual Site Model
•
PA/SI/RI Soils
•
Ecological Investigation
•
Presumptive Remedies
•
Historic Fill
•
Receptor Evaluation
•
Immediate Environmental
Concern
•
Vapor Intrusion
•
Analytical Methods *
•
Technical Impracticability *
•
Linear Construction
•
LNAPL
* = Not completed
4
Technical Guidance: Round 2



5
Kick-off meeting held September 19
Six (6) topics chosen through stakeholder process for
document development
Committee members chosen
•
Offsite source investigation
•
Co-mingled ground water plumes
•
Historic pesticide use
•
Capping
•
Performance monitoring of in-situ ground water remedial
actions
•
Evaluation of contaminated ground water discharge to surface
water
UHOT Rules
 Unregulated Heating Oil Tanks
 Aiming to propose Fall 2012
 LSRP not required
 DEP issues NFA, LSRP does not issue RAO
 Significant changes:
6
•
Do not need to analyze for TICs
•
De minimis volume can remain without need for
Deed Notice in limited circumstances
•
Deed notice “lite”
Stakeholder Input
 DEP recognizes the importance of
continued stakeholder input to help
ensure the success of the LSRP program
• Regulations
• Technical Guidances
• Training
7
Compliance Assistance
 Current emphasis on compliance assistance
 Identify responsible entity(ies)
•
Someone needs to step up
•
No one steps up, all go to Enforcement
 Someone steps up: discuss issues - attempt to
bring into compliance
 Not permanent – offered during transition to
LSRP program
8
Enforcement
 Will pursue enforcement actions against
responsible entity(ies) for failure to:
•
Retain LSRP
•
Meet regulatory/mandatory time frames
•
Meet requirements imposed by Direct Oversight
 AONOCAPAs already sent to responsible
entity(ies)
 LSRPs may be referred to SRPL Board for
disciplinary proceedings
9
LSRP Statistics: (as of October 1, 2012)
10

Total number SRP cases
= 14,365

Total number active LSRP cases
=
9,491

Total number closed LSRP cases
=
1,174

Total number cases that still need
to hire LSRP
=
2,344

Total number active UHOT cases
=
2,116

Total number closed UHOT cases
=
33,074

Total number active “other” SRP cases
=
2,758
LSRP Statistics: (as of October 1, 2012)
 Number RAOs filed
 Number RAOs inspection/review
completed
 Number RAOs invalidated
= 1,812
= 1,464
=
0
 Average total days DEP processing time= 45.20
11
LSRP Licensing Examinations
 1st exam = May 14, 2012
•
278 took exam
•
218 passed (78 percent)
•
List of permanent/temporary available through DEP
and SRPL websites
▪
▪
(datamine2.state.nj.us/DEP_OPRA/OpraMain/categori
es?category=SRRA/)
(www.nj.gov/lsrpboard/)
 2nd exam = September 24, 2012
• 235 took exam
• Results available soon
12
LSRP Licensing Examinations
 Two more exams scheduled
•
•
November 15, 2012
January 17, 2013 (tentative)
 November Exam
•
•
•
13
Full Credential Review applicants must submit
applications by October 12, 2012
Limited Credential Review applicants must submit
applications by October 19, 2012
Limited Credential Reviews are available only for
individuals who possess a temporary LSRP license
and/or individuals who are repeating the exam
LSRP Licensing Examinations
 January 2013 Exam
•
Tentatively scheduled for January 17, 2013
• Application schedule for January 2013 exam will
be announced when January examination date
finalized
 SRPL Board anticipates additional examinations will
be given May and November 2013
 ALL TEMPORARY LICENSES EXPIRE ON
FEBRUARY 28, 2013
14
Brownfield Issues
 HDSRF
• Current balance = approximately $30M
• A2395/S1246 revised HDSRF priorities
• Conditionally vetoed by Governor
15

Accepts revised priorities

Reduces awards to municipalities

Eliminates grants for innovative technology and
unrestricted/limited restricted remedies

Funds remedial action workplan (RAW)
preparation at 100%
Brownfield Issues
 Brownfield Development Areas
• No plans to designate new BDAs due to
limited HDSRF funding
16
Publicly Funded Remediations
 Department has amended all contracts to allow use
of LSRPs on publicly funded remediations
• Implementation ongoing
 Immediate Environmental Concerns
• Case manager assigned for all IEC cases
17
Contact Information
 Names and phone numbers of SRP staff
by topic area are available at
http://www.state.nj.us/dep/srp/srra/srra_contacts.htm
18
Questions?
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