The majority of the sites were remediated to NJDEP unrestricted use standards in effect at the time and were awaiting No Further Action approvals by NJDEP; the sites were considered to be a “low priority” to NJDEP case managers.
The New Jersey Site Remediation Reform Act or SRRA (N.J.S.A. 58:10C-1 et seq.) became effective on May 7, 2012 and established the affirmative obligation for responsible parties to remediate contaminated sites with the oversight of an New Jersey LSRP.
The Utility retained the LSRPs at ESI to review the historical remediation work performed at 26 sites and issue Response Action Outcomes or RAOs to close the case for each site. ESI’s LSRPs reviewed the remedial investigation and remedial action reports for each site to determine compliance and either issued RAOs or recommended further work to confirm the historical findings. NJDEP had revised its Soil Remediation Standards in 2008, which added to the complexity of the review.
Additional soil investigation and remediation (through excavation and removal) was performed at several sites. Within four years, RAOs were issued for 25 of the 26 sites. Remedial activities at the remaining site are on-going due to property owner access issues.
