|
|
* Remed-ial action
reports must have certification by a state- registered professional
engineer that the remedy can achieve the cleanup goals—based on the
remedy selection factors of ECL § 375-1.10(c).
* The NY Bond Act
requires plans to be sealed by a professional engineer.
|
* The cleanup
volunteer and his consul-tants choose the appro-priate cleanup standard or
standards, subject to MDE review and approval.
* Karl Kalbach doesn't think LSPs should
replace agency staff because "you need someone with the guts to make
decisions and to make them quickly."
*Increased VCP partici-pation by 33% in 2001
w/o LSPs. |
* A Licen-sed Site
Profess-ional (qual-ified by appropriate education, training and
experience) hired by the project pro-ponent con-ducts an analysis of the
prop-erty’s cond-ition, deter-mines the appropriate approach to cleanup,
oversees and imple-ments the cleanup, and en-sures com-pliance with
environmen-tal laws. (c. 21A, sect. 19).
*Overseen by a
private LSP Board.
*Statute requires
MassDEP to audit 20% of these cleanups.
* Only about 1% of
audited sites are found to require more work.
* Use of LSPs has increased the number of
cleaned up sites by 14-fold. |
* Private Contractors
Pilot Prog-ram —pub-licly funded projects which were managed by private
contractors, but subject to
MDEQ oversight.
*Most MDEQ-lead
projects use private contrac-tors on the state’s LOE contractor list.
*Even where an
environ-mental consultant may carry out resp-onse activi-ties at a facility
for a private party w/o MDEQ in-put, final approvals (with resol-ution
of lia-bility) can only come from MDEQ. |
* Implement-ation of
presumptive remedies (e.g. for historic fill) does not require separate DEP approval,
but requires DEP pre-approval and oversight..
* NJ gives the
volunteer and its consultants a lot of flexibility in selecting cleanup stds. and objectives, subject to NJ DEP oversight.
*All persons who provide services on USTs
must be certified by DEP in one or more particular classification(s).
*All remediation contractors must per-form
the remediation in accordance w/ the Technical Requirements for Site
Remediation. Certain activities require certifi-cation by a NJ
licensed engineer.
*Unrestricted use remedial actions and U-U soil remedial
actions can be con-ducted where appro-priate w/o DEP oversight provided
the duration of the remedy does not exceed 5 yrs. and provided the
Technical Regs. are followed. But all remedial actions involving GW or
SW require DEP approval and oversight. |
* For each of the
three types of cleanup endpoints, “interpretations of geologic and
hydrogeologic data must be prepared by a professional geologist
licensed in this Common-wealth.”
* Demonstra-tion of
attain-ment in the final report, where pathway elimination is part of the
remediation, shall be on the basis of either an engineering or a hydroge-ologic analysis, or both.
* The person
implementing Engineering Controls shall ensure ongo-ing achieve-ment of
the performance stds. in order to maintain attainment.
* The Key Sites
Initiative uses state-funded contractors to conduct environ-mental
site assess-ments and prepare plans to encourage and facilitate the
voluntary cleanup and reuse of abandoned industrial properties in prime
locations having the greatest potential for reuse—as selected by EDAs
and DEP.
*The Environ-mental Guard-ian Trust
pro-gram will oversee (on a fee-for-service basis as a non-profit entity)
long-term steward-ship of ICs and ECs and other post-remed-iation
respon-sibilities (w/o direct DEP involvement). |