Statutory Deadline to Complete Remedial Investigation by May 7, 2014

Synergy Environmental, Inc.
David Robinson, LSRP

July 23, 2013

This month, NJDEP sent notice regarding the Statutory Deadline to Complete Remedial Investigation by May 7, 2014. The Department directed letters to ”all persons responsible for conducting the remediation who, according to the Department’s records, are required to meet the May 7, 2014 statutory deadline for completing the remedial investigation set forth in the Site Remediation Reform Act (SRRA; N.J.S.A. 58:10C-1 et seq.” The DEP also set up a website with information regarding the statutory deadline, and created a call center (1-855-629-2014) for inquiries pertaining to the requirement. The call center operates between 9 am and 4 pm.

The SRRA states that, ”The department shall undertake direct oversight of a remediation of a contaminated site under the following conditions: … unless a longer period has been ordered by a court, the person responsible for conducting the remediation has, prior to the date of enactment of N.J.S.A. 58:10C-1 et seq., failed to complete the remedial investigation of the entire contaminated site 10 years after the discovery of a discharge at the site and has failed to complete the remedial investigation of the entire contaminated site within five years after the date of enactment of N.J.S.A. 58:10C-1 et seq.” (NJDEP SRP Website).

A summary of the specifications of the requirement, as published in the DEP’s June 2013 Compliance Alert Statement: Interpretation of SRRA Requirement to Complete the Remedial Investigation by May 2014, is available at the NJDEP SRP website. The Interpretation addresses:

  • “To what the May 7, 2014 deadline applies”
  • “What “entire contaminated site” means”
  • “What “complete the remedial investigation” means”
  • “What “nature and extent of the contamination” means”
  • “The need to attain remediation standards prior to issuance of a Response Action
    Outcome”

A PDF of the Compliance Alert Letter is also available on the NJDEP’s website, as is a list of Frequently Asked Questions.

Print Friendly