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SESI Learning Series: The Latest NJDEP Guidance
June 25, 2013
Do you have fill material that you want to import or export? Before making a decision, you should know the most uptodate NJDEP Guidance. The NJDEP has released an Alternative and Clean Fill Guidance document, updated December 29, 2011, that outlines testing frequency for materials intended for use at sites that are in the Site Remediation Program (SRP). The sampling frequencies developed in this guidance document are not binding to nonSRP sites; however, it is the only NJDEP document that outlines a procedure for certification of clean fill. For nonSRP sites, it is the responsibility and liability of the site owner to determine what level of risk they are willing to take in assessing fill that they import or export. If the owner wishes to remain conservative, then the fill can be analyzed in accordance with the NJDEP Clean Fill Guidance; however, since the site is not in the SRP, they may elect a reduced sampling frequency. The reduced sampling frequency may be based on lines of evidence such as a Preliminary Assessment or previous testing of the material. The NJDEP Guidance specifies what qualifies as a reasonable justification for reduced sampling frequencies. If the owner of a nonSRP site wishes to work within the context of the guidelines, it is the owner's responsibility to determine whether the existing evidence for the fill material is acceptable as a justification to reduce the sampling frequency. The owner of a nonSRP site may also choose to ignore the SRP Guidance; however, this is not recommended. Cross-contamination of sites is a very real problem and it can be mitigated by testing your import or export fill before moving it. If you don't assess your fill properly now, it may become your future liability!
SESI can assist you with all of your environmental engineering needs including sampling and analyses of fill. We are well versed in the new NJDEP Site Remediation Program and we have a Licensed Site Remediation Professional (LSRP) on staff.
*Information based on guidelines as of 6/25/2013