NJDEP News Project Deadlines and COVID-19

March 31, 2020

Author: Equity Environmental Engineering

It is our hope that all are doing well as we attempt to deal with the COVID-19 virus. The restrictions on our mobility and ability to do those normal things in life have been compromised in attempts to limit the spread and keep us healthy. Please be careful in whose advice you accept. There are numerous bits of advice and will be more falsehoods spread about how to avoid and/or treat this deadly disease.

Equity is and will remain open for business with staff working primarily from home as necessary to meet our client's needs. Project schedules will be maintained to the extent possible. Field work or in-person meetings is a challenge based on what is now considered essential work. We're using technology to the extent possible to maintain our high level of service.

Tomorrow is April Fools day! Have some fun.


Project Deadlines and COVID-19

Equity had heard concerns from our Clients about the Coronavirus causing delays in remediation and imperiling our Clients’ ability to complete remediation by the regulatory and mandatory deadlines. For example, one of our Clients that is planning to construct a low permeability cover at a property it no longer owns, cannot access the property to construct the cover. Access is restricted because the property owner has streamlined its on-Site personnel due to the Coronavirus. The personnel who remain at the facility are stretched too thin to meet health and safety permitting requirements, which means that our work and work by other subcontractors is postponed until at least early May 2020. The project schedule can likely accommodate this one-month delay, but a delay of more than three to four months is likely to delay the issuance of the RAR and RAO until after the mandatory deadline.

In mid-March, Geoff Clark/LSRP from Equity, reached out to his contacts at NJDEP to inquire about whether the NJDEP has plans to relax the regulatory and/or mandatory deadlines that may not be met due to the effects of the Coronavirus. The following is a summary of the NJDEP’s response:

  • The NJDEP is currently in the process of adjusting to working from home: from determining work-from-home schedules, to ensuring intra-agency communication, to ensuring employee access to NJDEP databases and files, the NJDEP is not actively working on guidance related to Coronavirus and time frame extensions. However, such guidance is possible in April 2020.
  • NJDEP recommends that remediation continue to the extent possible and, when not possible, that the LSRP and PRCR document the reasons that remediation was delayed. In the example above, such documentation could include letters or emails from the property owner that deny access to the property.
  • NJDEP is unlikely to accept requests to extend the mandatory time frame at this time, particularly when the length of Corona virus-related delays are not known and when the regulatory or mandatory deadline is not imminent. They recommend that the notification occurs approximately 3 to 6 months in advance of a regulatory time frame and 6 to 9 months in advance of a mandatory time frame.

Delineation Wells

In its November 25, 2019 Listserve/email blast, NJDEP indicated that vertical delineation wells should be placed within 10 feet downgradient of the AOC or source area. This is not always practical, is not always possible, and is not usually what our Clients have done. Partly to act as a Client advocate (Equity does not want its Clients to install additional wells just to meet this requirement) and partly to clarify the NJDEP position, Geoff Clark contacted representatives from the NJDEP. Based on the discussion, it was understood that the NJDEP issued the requirement because it has received Remedial Action Permit Applications for Groundwater that do not demonstrate vertical delineation and because many LSRPs and PRCRs were installing the vertical delineation wells at a distance beyond the end of the plume. After a brief conversation, Mr. Clark and the NJDEP agreed that, in many instances, the delineation well should not be installed within 10 feet of the AOC/source area. NJDEP is currently reviewing Mr. Clark’s recommended language. We will let you know of any changes to the NJDEP’s vertical delineation policy. If you would like more information about vertical delineation monitoring well placement, please call Geoff at (973) 527-7451 x201. 

In summary, Equity listens to its Clients, acts to find answers to their questions, and once the answer is obtained, shares the information with our clients. Please call us at 973-527-7451 if you have a question you need to be answered.

New Employees

Qianyu (Kira) Xiang, Junior Urban Planner

Headshot of Qianyu Kira Xiang

Ms. Xiang is a Junior Urban Planner with interests in data analytics and built environment, economic development, transportation, environment, housing, and other current planning issues. She is dedicated to utilizing data analysis, GIS, and programming to articulate, illustrate, and address urban problems. 

Currently, she interprets and applies applicable state, county and local codes, ordinances, and regulations for Equity’s planning projects. Meanwhile, she conducts extensive research in various project areas while providing technical support to the planning team for urban design, area mapping, illustrative plans, sections, perspective renderings, and master planning projects.

Kira holds a Bachelor of Engineering in Urban Planning from Sun Yat-sen University in China. She is a 2019 graduate of the Graduate School of Architecture, Planning, and Preservation (GSAPP), Columbia University as a dual-degree master student in Urban Planning and Real Estate Development. Her coursework at Columbia University focused on the built environment and urban analytics and was specialized in zoning, community planning, data analysis, and GIS.

Alex McLean, Urban Planner

Headshot of Alex McLean

Alex is joining Equity Environmental Engineering as an Urban Planner with an interest in environmental reporting both on the state and local level. He possesses a strong interest in affordable housing, economic development, public health, and transportation.

As an Urban Planner, Alex assists the firm in its environmental reporting services which is largely focused on the preparation of EASs (Environmental Assessment Statements) for the project’s being considered through the City of New York’s CEQR (City Environmental Quality Review) process in addition to Environmental Assessments (EAs) through New York SEQR (State’s Environmental Quality Review) process. Having begun his career in planning in New York City, he is passionate about the need for municipalities to closely monitor changes in land use and regularly report such changes to the public in order to lay the foundation for a more honest planning process. In turn, he will be assisting the firm in advancing its master and comprehensive planning services.

Alex holds a Bachelor’s degree from Stony Brook University and completed his Master’s Degree in City and Regional Planning from Rutgers University’s Bloustein School of Planning and Public Policy in 2014. His graduate work was focused on environmental planning and water resource management. Alex has worked as an environmental planner overseeing the review process for three New York City agencies that include the Department of Housing Preservation and Development (HPD), Department of Environmental Protection (DEP), and the Department of City Planning (DCP). His experience has resulted in an understanding of affordable housing, water infrastructure, and land use issues.

Share Article:

©2022 Equity Environmental Engineering