Remedial Action Permits for soil, groundwater, & Indoor AIR

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If contaminants will remain in soil, groundwater, or indoor air after remediation is completed, a Remedial Action Permit (RAP) is required prior to issuance of a Response Action Outcome.  The RAP requires that a New Jersey Licensed Site Remediation Professional (LSRP) be retained to oversee the implementation of the permit, conduct periodic inspections, and certify the ongoing protectiveness of the remediation.  Whether you are managing existing land use controls or are anticipating the need to manage a remedial action permit for soil or groundwater, RĒSN can help.

RĒSN's RAP Management and Assessment program is tailored to provide our clients with a cost-effective solution to the management of Deed Notices, Classification Exception Areas, and Indoor Air Notification Areas at sites across New Jersey.

SOIL REMEDIAL ACTION PERMITS FOR DEED NOTICES

RĒSN cost-effectively conducts required inspections and biennial reporting to help you maintain compliance with your Soil Remedial Action Permit by verifying and certifying the ongoing protectiveness of institutional and engineering controls.  Where needed, RĒSN maintains relationships with a variety of contractors and professionals that can assist in conducting maintenance or repair to damaged engineering controls.  Additionally, we continually monitor changes in applicable regulations and can advise you how new rules may affect existing Soil RAP and can help with the required review of contaminants remaining on site in comparison to the changing Soil Remediation Standards. 

GROUNDWATER REMEDIAL ACTION PERMITS FOR CLASSIFICATION EXCEPTION AREAS

RĒSN is well versed in groundwater investigation, remediation, and management of groundwater remediation permits including: 

• Classification exception area (CEA) assessment and modification 

• Groundwater flow and contaminant migration modeling 

• Periodic groundwater sampling 

• Groundwater treatment system operation, management, and maintenance 

• Vapor assessment 

• Vapor mitigation system operation, management, and maintenance 

• Remedial system optimization 

• Biennial reporting 

We are experienced in managing groundwater contamination in systems that range in complexity from the simplest contaminant plumes in shallow unconfined sandy aquifers to complex groundwater issues impacting multiple water-bearing units in both unconsolidated and consolidated formations, including complex cases of DNAPLs within fractured bedrock systems.  RĒSN can successfully conduct work at both inactive and active manufacturing sites, chemical plants, refineries, bulk storage facilities, and commercial sites, while working closely with facility personnel to ensure safety while minimizing potential interruptions to ongoing business operations.  Further, RĒSN is experienced in public communications in the event that off-site impacts result in the need to conduct public notifications or otherwise communicate with the public and municipal agencies.

INDOOR AIR NOTIFICATION AREAS (IANA)

This institutional control newly established by NJDEP is based on the groundwater classification exception area but applies to buildings where vapor intrusion has been confirmed and an engineering control is being implemented to mitigate a Vapor Concern (VC) or Immediate Environmental Condition (IEC).  

For sites with operating vapor mitigation systems, a notification of the IANA is required at the Remedial Investigation Report phase with a permit application submitted at the time the Remedial Action Report submission.  For sites with vapor mitigation systems that are already in post-remediation (i.e., systems operated in conjunction with a groundwater RAP) an IANA permit application is required prior to the next scheduled biennial certification.

MODIFYING AND COMBINING PERMITS

Recent changes to NJDEP regulations allow combining of permits to facilitate streamlining of permit management.  While offsite or contiguous properties with different PI numbers cannot be combined, sites can combine multiple soil permits with groundwater and the new IANA permits such into a single permit with one annual fee and a single biennial certification report.

REMOVAL OF LAND USE CONTROLS

When land use controls are no longer needed, no longer function as intended, or need modification as a result of planned activities or redevelopment within the area.  RĒSN can help determine cost-efficient solutions in removing or modifying engineering and institutional controls and can assist with: 

• Alternate design 

• Cost-benefit analysis 

• Oversight of engineering and institutional control disruptions 

• Groundwater remediation optimization 

• System decommissioning

• Remedial Action Permit Modification or Termination