The May 2014 requirement for completion of the Remedial Investigation and submittal of Remedial Investigation Report, imposed on certain contaminated sites in New Jersey by the Site Remediation Reform Act, is quickly approaching.  Those who are required to but fail to submit a Remedial Investigation Report before the May 7, 2014 deadline are expected to fall into direct oversight, thus allowing NJDEP to define the remediation path for those sites going forward.  There have been rumors that certain industry groups plan on proposing legislation requesting an amendment to the Administrative Requirements for Remediating Contaminated Sites regarding the definition of when “remedial investigation” is considered complete.  There is a discrepancy between the Site Remediation Reform Act’s definition and the Administrative Requirements for Remediating Contaminated Sites definition.  The Department of Environmental Protection has stated that it will be establishing a policy with regard to the definition of “remedial investigation” that will be consistent with the Site Remediation Reform Act’s definition, which is more flexible than the definition in the Administrative Requirements for Remediating Contaminated Sites definition.  To be continued.

Topics:  Contaminated Properties, Department of Environmental Protection, Remediation, Site Remediation Reform Act

Published In: Environmental Updates, Commercial Real Estate Updates, Residential Real Estate Updates

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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