[SRRA]: New Soil and Ground Water Remedial Action Permit (RAP) Initial, Modification, and Termination Applications and Deed Notice Termination Form and Instructions available

The New Jersey Department of Environmental Protection (NJDEP) has created new Remedial Action Permit (RAP) applications/forms. They are: RAP Initial, RAP Modification, and RAP Termination Applications for both soil and ground water, as well as a new Deed Notice Termination Form.

Based on numerous RAP Stakeholder meetings, it was determined to separate the current Soil and Ground Water RAP Applications into initial, modification, and termination applications to be more user friendly and to make the current RAP Application process more efficient. The forms more clearly indicate what is expected to be submitted and when a submittal is needed. Insufficient information, information missing from the report that was submitted, and missed submittals are the most common deficiencies with RAP applications. These new applications/forms and instructions should better streamline RAP-related submittals to the NJDEP and reduce the total processing time for the applications.

In addition, the new Deed Notice Termination Form was created to make the current Deed Notice termination process more transparent, as this current process was not well known and difficult to understand.

The new remedial action permit applications/forms and instructions are available on the NJDEP's website. All the permit forms can be found in a new section on the Forms page (http://www.nj.gov/dep/srp/srra/forms/#rap_forms)to make finding the new forms easier. Some important changes/additions for the Soil and Ground Water RAP Initial, Modification, and Termination Applications include the following:

• Clearer Options for Section B on all applications – Reason(s) for the RAP Application are listed.
• Attached Documents Section – An administrative checklist of what is required to be submitted with the application and asks the user to indicate where this information can be located in the Remedial Action Report. Electronic copies required for most attached documents.
• Other Information Provided Section – Encourages the user to list any/all other pertinent information to support the RAP Application (i.e., professional judgement justification, compliance averaging, variances from rules/guidance, etc.).
• New questions on the applications to be consistent with current guidance include the following important topics: Indeterminate Vapor Intrusion Pathway status; Vapor Intrusion Long Term Monitoring Plan; capping of the impact to ground water pathway for volatile organic compounds; Polychlorinated Biphenyls (PCBs) – compliance/approval with the federal Toxic Substances Control Act (TSCA) program; delineation of soil/ground water contamination; compliance averaging; off-site and background ground water contamination; and chromate chemical production waste.
• Clearer instructions for the use of a Remediation Funding Source as Financial Assurance.
• Website links for the tax databases that the NJDEP uses to verify the site address and block/lot, and current owner of the site.
• Municipal Subdivisions of a site; instructions to contact the Bureau of Case Assignment and Initial Notice (BCAIN) to see if new Program Interest (PI) #s are necessary.
• Notice that a RAP application(s) will not be processed until all past RAP annual fees have been paid in full and all previously required RAP Applications have been submitted.
• Licensed Site Remediation Professional (LSRP) Retention/Dismissal Note in the instructions of all the RAP Applications.
• A RAP Modification Application is no longer needed for a change in Financial Assurance.

Training on these new applications/forms and instructions will be announced in a subsequent email.

SRP Site Remediation Reform Act (SRRA) Web site: www.nj.gov/dep/srp/

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