Curren offers Licensed Site Remediation Professional (“LSRP”) Services. The New Jersey Site Remediation Reform Act (“SRRA”), approved in May 2009, set in place the requirements for environmental professional licensing as Licensed Site Remediation Professional (“LSRPs”). The program has been modeled after a similar program in Massachusetts initiated in 1993. It is reported that the NJDEP currently has over 20,000 cases awaiting remedial activity. The implementation of the LSRP Program would result in a significant increase in the amount of sites restored in a timely manner.
The key idea of the New Jersey SRRA Program is so that the NJDEP can focus their resources on the more important sites and to allow the responsible parties to move the remediation process along without extensive NJDEP review and comments. The LSRP has the educational and experience background to act as the enforcement arm of the NJDEP and is allowed to move remediation projects forward without NJDEP pre-approval. The LSRP ensures that sites are investigated and remediated in accordance with the NJDEP Technical Requirements for Site Remediation.
The LSRPs will issue Response Action Outcomes “RAOs” for sites where the remediation has been completed. The RAOs take the place of the currently issues No Further Action Letters.
LSRPs are overseen by a board of 13 members and approximately 10% of LSRP cases which are closed with an RAO will be reviewed or audited for compliance to the Technical Requirements and to confirm that the site remediation approach is protective of human health and the environment. The NJDEP will still act as the final approval authority through the auditing process.
The LSRP is charged with the responsibility of reporting any issue deemed an Immediate Environmental Concern (“IEC”) on any site the LSRP is involved with including due diligence assessments.
Responsible parties, under the SRRA program, remain responsible for regulatory compliance issues and are held to mandatory time frames. If a Responsible Party misses a deadline, they may be forced into the “Direct Oversight Program” where the NJDEP becomes the primary oversight on the case. This also opens up the Responsible Party to possible enforcement actions. Other issues which will require NJDEP Direct Oversight would include chromate contaminated wastes, environmentally-sensitive areas where natural resource damages have occurred, some contaminated sediment sites and sites which have been ranked as a priority based on exposure of human health and the environment.
May 7, 2012 NJDEP LSRP Deadline
The NJDEP LSRP program requires that all responsible parties (RP) of commercial property are required to hire a licensed site remediation professional (LSRP) by May 7, 2012, and to then proceed with the remediation or investigation without Department pre-approval. To opt-in the responsible party must complete the LSRP Notification of Retention or Dismissal Form. The form is signed by both the LSRP and the RP, Submission of this certification results in automatic Department approval. No other NJDEP approvals are required.