We stuck a stick in the hornets nest with our post on New Jersey’s contaminated site-cleanup program (NJ headline: ‘Polluters rewriting rules for site cleanup’).

The piece prompted 15 comments from readers, resulting in an interesting discussion of New Jersey’s Licensed Site Remediation Professionals (LSRP) program, and other issues.

Today, we continue the conversation with the post below from Nick DeRose who is president of the
NJ Licensed Site Remediation Professionals  Association. He also is a senior principal at  Langan Engineering and Environmental Services, Inc.

Nick DeRose

Nick writes:

I would just like to comment that the full story of the NJ Site Remediation Reform Act (SRRA) is rarely explained.

In addition to establishing the LSRP program – SRRA established ‘an affirmative obligation for responsible parties to remediate with or without input from NJDEP.  Consequently – when the new regulations were adopted, NJDEP established a series of time frames that Responsible Parties (RPs) must meet or face fines or having NJDEP take over their sites.

These included new timelines requiring a prioritized focus on ensuring that actual risks to receptors (potable wells and indoor air) were evaluated for all sites.  This resulted in a significant increase in the pace of work on these sites which, in turn, has resulted in an increased protection to the public.

It also put an end to New Jersey’s voluntary cleanup program which is contrary to what has prevailed in other states across the US. This has to be viewed as a major pro environmental major piece of legislation.

Regarding the concern that LSRPs are the ‘fox in the hen house,’ I can only say that the prevailing sentiment I experience with my clients is a concern that LSRPs will be overly conservative.  And the fact that less than 5% of sites have ‘opted into’ the LSRP program in the first 2 years of the program does not suggest that folks are anxious to run into the arms of LSRPs. 

Regarding all of the NJDEP committee meetings.  I would advise pro environmental advocates to prioritize those committees that you want to get involved with.  NJDEP will be proposing revisions to the Technical Requirements for Site Remediation in July.  This is where I would focus my efforts including understanding why the revisions are being made and educating your constituents in order to provide credible and meaningful input.

As always, we encourage you to share your opinion. Use the comment box below. If one is not visible, click on the tiny ‘comments’ line. We appreciate signed comments but also accept communications from you shy, ‘anonymous’ types. P.S. If you encounter a problem in posting your comment, please let us know.

Related:
NJ headline: ‘Polluters rewriting rules for site cleanup’
What do you want from NJ’s LSRP program?
LSRP Program a “New World Order” for Site Remediation in NJ