Regulatory Reminder: Important May 2017 & 2019 NJDEP Remediation Deadlines
Two important New Jersey site remediation deadlines are looming in May 2017 and 2019 which could be applicable to your New Jersey Department of Environmental Protection (NJDEP) case. Although these deadlines are years away, site remediation can take years to complete. It is important to get started now to ensure the deadlines are met and you do not incur unnecessary stress and costs as the deadlines draw near.
EWMA can help you with a review your NJDEP case to determine if your site is applicable to either of these deadlines. Remediation requires ample time to complete, so it is important to start working towards meeting these deadlines as soon as possible.
Per New Jersey’s Site Remediation Reform Act (SRRA), the NJDEP may undertake direct oversight of any cases that have not complied with the remediation deadlines in May 2017 and 2019 (N.J.A.C. 58:10C-27.a). Direct oversight means, among other things, that the NJDEP will be empowered to select the remedy for the contamination and require the responsible party to establish a trust in an amount equal to the full estimated cost of the remediation, from which the project will be funded. NJDEP direct oversight means you lose control over your remedial options and timeline.
EWMA will help you evaluate if either of the remediation deadlines are applicable to your site at no cost. If applicable, we can work with you to develop a cost-effective cleanup scope with Licensed Site Remediation Professional (LSRP) oversight to meet the deadlines.
If you are unsure if you are affected by this deadline, or if you have any questions, please contact Michael Sylvester at Michael.Sylvester@ewma.com or (973) 560-1400 x187 or John Coviello at John.Coviello@ewma.com or (973) 560-1400 x184.