SRP Preferred ID GIS Layer Released by NJDEP-SRWP

On February 15, 2022, the NJDEP released of its new “SRP Preferred ID GIS layer.” A Geographical Information System (GIS) layer that “displays all active, closed, and pending Site Remediation remedial cases with known or suspected contamination.”   Active GIS users now have another resource when adding data using ArcGIS online, along with those that frequently use NJDEP Geoweb.  The level of information now available is quite deep and includes such things as NJDEP case status & type, remediation fees, and institutional controls associated with the case, to name a few.  Cardinal routinely uses many of the various GIS resources available to environmental consultants and looks forward to having another tool in the shed. 

For additional information on these new GIS resources & how they may support your project, please contact tfrancis@cardinalLSRP.com or www.cardinalLSRP.com.

Specific details are available on the NJDEP’s site: https://www.nj.gov/dep/srp/srra/listserv_archives/2022/20220215_srra.html

At Cardinal Environmental, we have the experience to get you through your remedial situation and provide realistic costs up-front, regardless of the size, or scope.  Additionally, with over two decades in the industry, we have established relationships in the environmental community to get your project on a cost-effective remedial course that meets your long-term goals.

May 17, 2021 - NJDEP Adopts New Remediation Standards

On May 17, 2021, the NJDEP adopted amended rules at N.J.A.C. 7:26D. Included in the amended rules are soil and soil leachate remediation standards for the migration to ground water exposure pathway and indoor air remediation standards for the vapor intrusion exposure pathway. Numerous changes in the remediation standards are certain to impact current, future, and closed remediation sites. The phase-in period for the updated rules is six months from May 17, 2021, with certain exceptions (e.g., previously approved Remedial Action Workplan, etc.). Several of the key changes include:

• Replacement of "Direct Contact” Soil Remediation Standards with “Ingestion-Dermal” and “Inhalation” exposure pathways.

• Default “Impact to Groundwater Soil Screening Levels” have been replaced with soil and leachate remediation standards for the new “Migration to Groundwater” exposure pathway.

• Replacement of “Indoor Air Screening Levels” with “Indoor Air” Remediation Standards.

For additional information on these remediation standard changes & how they may impact your project, please contact tfrancis@cardinalLSRP.com or www.cardinalLSRP.com.

Specific details are available on the NJDEP’s site:[EXTERNAL]: Adoption of Remediation Standards and Updates to Alternative Remediation Standards Technical Guidance (nj.gov)

At Cardinal Environmental, we have the experience to get you through your remedial situation and provide realistic costs up-front, regardless of the size, or scope.  Additionally, with over two decades in the industry, we have established relationships in the environmental community to get your project on a cost-effective remedial course that meets your long-term goals.

NJDEP Provides Temporary Rule Suspension-Remediation Fee Calculation

On June 17, 2020 the NJDEP adopted an emergency adoption of a temporary rule to suspend the requirement to calculate Site Remediation Reform Act (SRRA) and Remedial Action Permitting fees for fiscal year (FY) 2021, due to financial & budgetary uncertainties cause by COVID-19 pandemic and outlined in Governor Murphy’s Executive Order No. 103 (EO 103).  The FY 2021 fees would remain in effect until FY 2022.

Additional links are below:

• https://www.nj.gov/dep/covid19regulatorycompliance/?utm_medium=email&utm_source=govdelivery

• https://www.nj.gov/dep/covid19regulatorycompliance/docs/srp-contaminated-site-fee-20200617.pdf

• https://www.nj.gov/dep/srp/guidance/srra/fee_guidance_document.pdf

For additional information on Remediation Fees affected by COVID-19 please contact tfrancis@cardinalLSRP.com or www.cardinalLSRP.com.

At Cardinal Environmental, we have the experience to get you through your remedial situation and provide realistic costs up-front, regardless of the size, or scope.  Additionally, with over two decades in the industry, we have established relationships in the environmental community to get your project on a cost-effective remedial course that meets your long-term goals.

NJDEP Clarifies Remediation Timeframe Extensions Due to COVID-19

The NJDEP has provided further clarification on their April 24, 2020 “Notice of Rule Waiver/Modification/Suspension due to the COVID-19 pandemic and outlined in Governor Murphy’s Executive Order No. 103 (EO 103).  The key detail was how remedial timeframes could have been negatively affected and whether extensions were necessary for responsible parties to maintain compliance.  As presented by the NJDEP, “ …some remediation timeframes identified in N.J.A.C. 7:26C and N.J.A.C. 7:26E, as well as timeframes set forth in an administrative consent order, that have been and will be reached during the period in which EO 103 is in effect will be extended for 90 days.”

For example, if a remedial timeframe were May 1, 2020 it would be extended 90-days to July 30, 2020. The submission of Remedial Timeframe Notification forms are also not required for applicable cases.

Additional links are below:

• https://www.nj.gov/dep/srp/srra/listserv_archives/2020/202006_01_srra.html

• https://www.nj.gov/dep/covid19regulatorycompliance/docs/srp-remedial-timeframes20200424.pdf

• https://www.nj.gov/dep/covid19regulatorycompliance/docs/ao2020-06.pdf

For additional information on Remediation Timeframes affected by COVID-19 please contact tfrancis@cardinalLSRP.com or www.cardinalLSRP.com.

At Cardinal Environmental, we have the experience to get you through your remedial situation and provide realistic costs up-front, regardless of the size, or scope.  Additionally, with over two decades in the industry, we have established relationships in the environmental community to get your project on a cost-effective remedial course that meets your long-term goals.

Interstate Technology & Regulatory Council (ITRC) Issues New PFAS Technical & Regulatory Guidance Document

Contaminants of emerging concern are a group of chemicals that have historically been used in numerous household products, on farms, businesses, and military installations. After decades of production by major chemical manufacturers throughout the world, the byproducts & chemical compounds of the various processes are now being brought to the forefront. These are commonly referred to as “Per and Polyfluoroalkyl Substances” or “PFAs,”  all of which have been demonstrated to be highly mobile and persistent in the environment.

To provide support for investigators, regulators, industry, stakeholders, and government agencies, the Interstate Technology Regulatory Council (ITRC) has issued new online documents including:

• PFAS Technical and Regulatory Guidance Document (https://pfas-1.itrcweb.org/),

• Revised PFAS Fact Sheets and Explainer Videos (https://pfas-1.itrcweb.org/fact-sheets/),

• Training Module Videos (Sampling & Analysis, Fate & Transport, Human & Ecological Effects, etc.)

For additional information on PFAs please contact tfrancis@cardinalLSRP.com or www.cardinalLSRP.com.

At Cardinal Environmental, we have the experience to get you through your remedial situation and provide realistic costs up-front, regardless of the size, or scope.  Additionally, with over two decades in the industry, we have established relationships in the environmental community to get your project on a cost-effective remedial course that meets your long-term goals.

NJDEP Compliance & Enforcement: COVID-19 Compliance Alert

On April 21, 2020 The NJDEP issued Compliance Alert #2020-08 to provide further COVID-19 guidance for environmental practitioners and responsible parties in New Jersey. The update provides information for those that may be faced with missing a regulatory or mandatory timeframe for their remedial project.

• It is strongly recommended that the NJDEP be contacted if your project has the potential to miss remedial deadlines as a result of this unprecedented situation.

Cardinal Environmental is considered an essential operation in the state of New Jersey and remains available to assist you with this matter further. While our highest priority is the health, safety and well-being of our families, colleagues, clients, vendors and those we may come in contact with, we remain committed to providing you with the highest level of service.  For additional information please contact tfrancis@cardinalLSRP.com or www.cardinalLSRP.com.

Please stay safe during these extraordinary times.

Sincerely yours, 

Tom Francis, LSRP

President

NJDEP "Guard Your Backyard" Initiative

The New Jersey Department of Environmental Protection (NJDEP) launched the “Guard Your Backyard” initiative in October 2019 to assist municipalities with the importation of “fill” materials on residential properties.  Like most homeowners, understanding the potential issues with soil-fill materials used for backfilling, new construction, and/or landscaping are usually outside their purview.  As a result, some homeowners may fall prey to less scrupulous contractors willing to offer “free” fill or make the claim that “I know a guy, who knows where we can get some cheap fill.”  Of course, being conscientious of costs doesn’t mean that residents need to make unnecessary concessions and accept questionable fill materials offered by their contractor. 

 Fortunately, the NJDEP is promoting the “Guard Your Backyard” effort where local communities can establish regulations to ensure that “dirty” dirt isn’t freely deposited without oversight from, or notice being provided to the town, city, or municipality.  The NJDEP is also providing model ordinances that local governments may use when developing their own regulation(s).  To date, several NJ townships have adopted ordinances to address the matter, including Wantage, Frankford, and Lafayette.

 Currently, the NJDEP Site Remediation Program (SRP), requires that clean fill be used for remediation sites (see N.J.A.C. 7:26C and 7:26E), where Licensed Site Remediation Professionals (LSRPs) may have oversight.  Now with the Guard Your Backyard initiative, the hope is that those outside of the SRP can educate themselves and take action to protect their properties, and communities from being affected by contaminated soil.  

 Here are a few tips when looking to obtain “clean fill” for your home project:

• Ask for “certified” clean fill (know where it came from, and ask for supporting documentation)

• Ask if your local municipality requires a permit for importing / exporting soil-fill.

• Ask for additional cost estimates.

• Be wary of using fill from agricultural areas where pesticides or herbicides may have been historically used (*this includes topsoil).

• Be wary of using fill from commercial / industrial sites.

• Be wary of using fill with solid wastes / debris / or asphalt millings.

For additional information on the Guard Your Backyard initiative or on the site remediation process in NJ, please contact tfrancis@cardinalLSRP.com or www.cardinalLSRP.com.

At Cardinal Environmental, we have the experience to get you through your remedial situation and provide realistic costs up-front, regardless of the size, or scope.  Additionally, with over two decades in the industry, we have established relationships in the environmental community to get your project on a cost-effective remedial course that meets your long-term goals.

NJ Site Remediation Conference-New Brunswick, NJ February 4 and 5, 2020

The NJ Licensed Site Remediation Professional Association (LSRPA) has announced the return of the popular Site Remediation Conference to the Hyatt Regency Hotel in New Brunswick, NJ on February 4th and 5th, 2020.  This is the 3rd annual SRC which has been widely attended by industry professionals and regulators, with networking opportunities, sponsorships, and continuing professional education courses.  The key goals / objectives for the SRC is the sharing of  technical/regulatory knowledge, professional experiences, and ultimately to continue to advance sound practices by environmental professionals and their impact on New Jersey, and our individual neighborhoods.  Cardinal Environmental will be there!

Registration to NJ Site Remediation Conference can be located on the LSRPA website: https://www.lsrpa.org/nj-src

For additional information on NJ SRC or on the  site remediation process in NJ, please contact tfrancis@cardinalLSRP.com or www.cardinalLSRP.com.

At Cardinal Environmental, we have the experience to get you through your remedial situation and provide realistic costs up-front, regardless of the size, or scope.  Additionally, with over two decades in the industry, we have established relationships in the environmental community to get your project on a cost-effective remedial course that meets your long-term goals. Banner photo courtesy of the NJ LSRPA.

NJDEP Establishes New Interim Specific Groundwater Quality Standards for PFOAs & PFOs

The NJDEP Site Remediation & Waste Management Program (SRWMP) have established new Interim Specific Groundwater Quality Standards for Perfluorooctanoic acid (PFOA) and Perfluorooctanesulfonic acid (PFOS) at 0.01 micrograms per liter (ug/L) (or 10 parts per trillion-ppt).  If your Site in New Jersey has, or had the potential to store, use, manufacture, dispose, or discharge these contaminants, further evaluation is recommended.  This starts with a Preliminary Assessment (for “Entire Site” Remediation Cases) and potentially a Site Investigation and/or Remediation.  For Licensed Site Remediation Professionals (LSRPs) in NJ, and other environmental consultants, look to have plenty of back-up data or information to justify the use of professional judgment…and the reasons why further evaluation/ assessment was not warranted. 

Further information on this NJDEP update are provided here SRWMP_ implementation of March 13, 2019 Interim Specific GWQS.  Additional resources can be found at the Interstate Technology Regulatory Council (ITRC).   

At Cardinal Environmental, we have the experience to get you through your remedial situation and provide realistic costs up-front, regardless of the size, or scope.  Additionally, with over two decades in the industry, we have established relationships in the environmental community to get your project on a cost-effective remedial course that meets your long-term goals. For further information on how we can assist you with your remedial solutions and/or LSRP services, please don’t hesitate to contact us at tfrancis@cardinalLSRP.com or www.cardinalLSRP.com.

Updated NJDEP Public Notification Requirements

Environmental practitioners and responsible parties in New Jersey take notice as the NJDEP public notification requirements were updated. From the SRP-Site Remediation Reform Act (SRRA) Listserv:

Updated Public Notification Requirements

On August 6, 2018, amendments to the Administrative Requirements for the Remediation of Contaminated Sites (ARRCS) were published in the New Jersey Register. The amendments include changes related to Notification and Public Outreach at N.J.A.C. 7:26C-1.7.

The major change requires public notification within 14 days prior to commencing initial field activities associated with the remedial investigation (previously remedial action). For cases that initiated the remedial investigation prior to August 6, 2018 but have not yet satisfied the public notification requirements, the 14-day public notification is now due. However, for these cases, the Department is allowing the person responsible for conducting the remediation to comply with the public notification rule requirements by June 30, 2019.

The public notification webpage (www.nj.gov/dep/srp/guidance/public_notification/) is being updated to reflect the new requirements. In addition, the Department will add language highlighting the revised public notification requirements to the acknowledgement letter that is issued in response to online submittals of site investigation reports and remedial investigation reports. SRP Site Remediation Reform Act (SRRA) Web site: www.nj.gov/dep/srp/

At Cardinal Environmental, we have the experience to get you through your remedial situation and provide realistic costs up-front, regardless of the size, or scope.  Additionally, with over two decades in the industry, we have established relationships in the environmental community to get your project on a cost-effective remedial course that meets your long-term goals. For further information on how we can assist you with your remedial solutions and/or LSRP services, please don’t hesitate to contact us at tfrancis@cardinalLSRP.com or www.cardinalLSRP.com. 

New Jersey-Hazardous Discharge Site Remediation Fund (HDSRF) Update-July 2016

Remedial cases in New Jersey in New Jersey often stall out due to the lack of available funds.  This is no secret, as the costs to investigate and/or remediate cases thought to be relatively benign can sometimes sky-rocket 10x, and no responsible party (or homeowner) wants to get that news.  In similar fashion, when looking for some form of assistance or relief from the state, there was the similar doom & gloom scenario where no money was available, or the funds were all dried up.  However, recent inquiries by Cardinal Environmental Consulting to the NJDEP have produced a shimmer of hope with the Hazardous Discharge Site Remediation Fund (HDSRF)…and ultimately a few of our clients.

The HDSRF fund is doing quite well with about $12 million remaining through June 2016, with another $11 million coming in July.  Review times are averaging about 30 days; however, there is still a lengthy backlog so the number one tip that we give all our clients is:

 1.      Assess whether they qualify and if so, get an application in as quickly as possible. 

Applications may take some time to complete, as a number of things are required (e.g. remedial cost estimates, funding type, demonstrated need, etc.) but be sure to take full advantage of the HDSRF County Coordinators.  They are always available to assist with the applications, and are excellent resources.  Allocating valuable time and a relatively small monetary investment to get through the process could save you thousands of dollars later on, so don’t delay!

At Cardinal Environmental, we have the experience to get you through your remedial situation and provide realistic costs up-front, regardless of the size, or scope.  Additionally, with over two decades in the industry, we have established relationships in the environmental community to get your project on a cost-effective remedial course that meets your long-term goals. For further information on how we can assist you with remedial funding solutions and/or LSRP services, please don’t hesitate to contact us at tfrancis@cardinalLSRP.com or www.cardinalLSRP.com. 

Photo of Lake Pemberton, NJ /  Courtesy of Kimberly Green Kaeser

New Jersey Residential Underground Storage Tanks: Contractor Tips Volume 1: “Contracts”

Last month, Cardinal Environmental Consulting discussed the topic of Unregulated Heating Oil Tanks (UHOT) in New Jersey, and the forthcoming legislation that will allow for small amounts of contamination to be left behind (see New Jersey Unregulated Heating Oil Tanks & The Deed Notice “Light”), but for this post, we decided it was important to list some key points for homeowners to consider when having an Underground Storage Tank (UST) removed and some tips to be aware of when hiring a contractor:                                                                            

• Ensure that the UST contractor you’re hiring is certified & insured…and ask for copies.
• Ensure that the UST contractor calls for a utility mark-out (and get a copy of the mark-out ticket). It’s the law in New Jersey.
• Let your contractor know where all of the “private” utilities are on your property beforehand, including irrigation and electric lines if you know where they are.  Contractors are not (and shouldn’t be) responsible for unknown utilities…but they are very skilled and avoiding them if they are told ahead of time.
• Read the fine print at the end of the contract.  Often times a residential UST contractor will provide a price to coordinate, remove, and dispose of the UST only.  If contaminated soils are identified, it will be an added cost to remediate.  For example: If the contract price you received says $5,000…that doesn’t usually include the excavation, transportation, and disposal of contaminated soils.  However, ask what will happen if contaminated soils are discovered, and discuss the price per ton if soils need to be excavated.  This generally ranges between $75 and $95 per ton. 
• Analysis costs for soil samples are often not included. Waste classification (WC) samples are sometimes collected, but the actual analysis may be an added cost. Discuss sampling and analysis prior to selecting your contractor. Note: the WC samples are used to let a disposal facility know what they are “accepting.” 

And last, but not least:

• Have the contractor include the cost to include mats or other means of protecting your lawn when the work is being performed. This includes keeping the removed UST on heavy plastic after it’s pulled.  It’s understandable that there may be some minor disturbances to the grass and/or ground surface, but there’s no reason for two (2) foot deep ruts!

As we’ve stressed in the past, there are many good, reputable environmental consulting and contracting firms that do honest work and put in the effort to minimize the stress of removing USTs, however, you should also understand the proposed scope of work and costs, prior to signing any contract.  Understand what you’re paying for and what the expectations are.  Stay tuned for future discussions on this topic as there are plenty of items to cover!

At Cardinal Environmental, we have the experience to get you through your remedial situation and provide realistic costs up-front, regardless of the size, or scope.  Additionally, with over two decades in the industry, we have established relationships in the environmental community to get your project on a cost-effective remedial course that meets your long-term goals. For further information on how we can assist you with Underground Storage Tank solutions and/or LSRP services, please don’t hesitate to contact us at tfrancis@cardinalLSRP.com or www.cardinalLSRP.com. 

Environmental Pricing: Lowest Price & The Race to the Bottom

In the Mid-Atlantic area, there are many good, reputable environmental consulting firms that do honest work and put in the effort to solve the complex situations that we’re often presented with…and given the industrial & manufacturing history here (and geology), they can be challenging, but offering the lowest price is a race to the bottom that often leads to disaster and soured client-consultant relationships.

This is very common in public bidding opportunities (e.g. Request for Proposals), and is not limited to environmental consultants.  The success rate is generally pretty high when going with a lowest price strategy; although many towns, cities, municipalities have the authority to pass on the lowest bid if they deem a respondent to be more qualified or better suited to achieve the desired results…at an acceptable cost.  It also means that they can select the incumbent if the price is right, thus making their selection process that much easier (and truly minimizing the opportunities for other small businesses).  Cardinal Environmental covered this topic in our January blog post “Should Small Businesses Pursue Requests for Proposals?,” but the same principles hold true when local businesses are searching for a reputable environmental consultant to help them through a difficult situation, whether it’s due diligence, an Underground Storage Tank (UST) removal, or Licensed Site Remediation Professional (LSRP) services.

Experienced firms typically understand that communicating a realistic, or probable outcome to a prospective client along with estimated, and realistic projected costs increases the trust-factor, and the perceived value you bring to the table.  Conversely, there are also many firms (experienced and inexperienced) that will provide a low bid or low cost (with too much fine print in their contracts), simply to secure the work.  Unfortunately, a complex Site’s difficulties usually surface over a short time-period leaving the consultant and client scrambling to identify how much more money is needed, how much longer, etc.  This tactic ultimately impacts the public perception of the environmental consulting industry, but does that mean you should always throw out the lowest price?  Probably not.  It means that you should understand the proposed scope of work, prior to signing that contract, which goes back to a familiar theme that we stress at Cardinal Environmental: effective communication.  Understand what you’re paying for and what the expectations are!

At Cardinal Environmental, we have the experience to get you through your remedial situation and provide realistic costs up-front, regardless of the size, or scope.  Additionally, with over two decades in the industry, we have established relationships in the environmental community to get your project on a cost-effective remedial course that meets your long-term goals. For further information on how we can assist you with environmental solutions and/or LSRP services, please don’t hesitate to contact us at tfrancis@cardinalLSRP.com or www.cardinalLSRP.com. 

Compliance with Remedial Timeframes

The May 2016 deadline for many remedial (investigation) cases has recently passed; however, Persons Responsible for Conducting Remediation (PRCRs) should not put the brakes on forward progress.  Ideally, extensions or other methods of communication were taken prior to the specified date to demonstrate to the NJDEP that action is being taken, or that a timeframe was likely to be missed, but wallowing in defeat never served any purpose (on any level). Regulators and consultants alike understand the complexities when investigating and/or remediating a site, but the easiest course of action is simple communication.  Don’t overthink it.  A phone call, an email, snail mail…take some measures to discuss the matter with the folks in Trenton and keep pressing forward. 

The first step in the process is to retain (or continue to work with) an experienced Licensed Site Remediation Professional (LSRP) to direct the remedial efforts, and right the ship.   The ultimate goal is to avoid direct oversight by the NJDEP, maintain control of your site’s remediation, and keep cleanup costs down. 

As the NJDEP likes to stress:

Site Remediation Costs < Site Remediation Costs + Penalties + Legal Fees

At Cardinal Environmental, we have the experience to get you through your remedial situation, regardless of the size, or scope.  Additionally, with over two decades in the industry, we have established relationships in the environmental community (including the NJDEP) to get your project on a cost-effective remedial course that meets your long-term goals. For further information on how we can assist you with LSRP services, and/or environmental solutions, please don’t hesitate to contact us at tfrancis@cardinalLSRP.com or www.cardinalLSRP.com.