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mr. test field I'm with the with the.training committee in site remediation.and I want to welcome everybody to the.commingled plume technical guidance.training that we have today there are.let's see we have a room full of people.this is awesome.usually we talk to a half-empty crab but.this is very good and we have between.two and three hundred people on the.webinar so we're happy about that too.okay this an application has been made.to the board for credits for this.training it happens to be for to.regulatory credits and one technical.credit and both everybody in all the.people who want credit for it if you're.in the room you know you have to sign in.which I believe you did and you have to.remember to sign out and then on the.webinar you folks will have to do a.little bit more you'll have to answer.the quiz questions as we go along and.you cannot miss miss much in the way of.time okay in your packets you'll have.packets on your chairs and I think.emailed to the webinar folks are the.slides we also have an agenda and we.have a lovely green piece of paper which.is the course evaluation myself and.Sanne will tackle you.if you don't hand this in filled out and.to the best of your ability now because.we read them and we pay attention and we.do things with the information okay.one thing I this is not pertaining to.this class but I wanted to make a.statement about what's going on with the.fake case study training we do at.Rutgers it's the prerequisite training.for LSR piece to take the exam we have.been doing it.twice a year for I think six seven years.I don't know a long time and I believe.this is the last time we're doing it.twice a year so we'll be doing it in.early October.and then from then on we're going to do.it no more than once a year and probably.the beginning of June but that.information will go out there so we.don't Jeannine MacGregor doesn't one.here I didn't know I had to take the.class when you submit your application.so you've been warned.okay the way we get credits for you.online and an in-person or the webinar.folks we will email a list of people who.meet the requirements we know if you.love often and go shopping you know or.take a nap so at the end we are the.people that earn the credits we send to.the LSR PA they send you a link you send.them money they send you a certificate.and everybody is happy okay this is a.different looking quiz slide test your.knowledge in order to the for the.webinar folks to get credits they have.to answer at least three out of the four.questions and they're really the.questions and the answers are somewhat.related to each other and they're not.difficult so when you get there when we.get there the the webinar folks we have.to give them a minute to answer and I'll.quiz the audience in the room and then.we'll ask rob blocks what his vacation.plans are for the summer okay this is a.reminder everybody mute your phones.nobody's reaching for the phones are so.good IRA if your phone goes off you're.in trouble.of course you're going to take any calls.outside the room when we get to the.question and answer period they are.listed on the agenda.we will have microphones to come to you.and so that you can ask your question.loud enough for everyone in the room and.everyone on the webinar to hear we will.also take webinar questions as they come.up I said this okay and this is for the.people that forget to sign out because I.had a couple of those last time Oh.now we get to hear all the cool things.that the LSO PA is doing from Mark.Fisher let's give them a round of.applause good afternoon everybody.how did you take my clicker okay as.testy messages on Mark Fisher Biskit.acity I'm here representing the LSR PA.the LSR PA typically will partner with.the Department when they do these.training sessions oops wrong way not.only to assist in the credits but still.take with the refreshments etc so enjoy.coffee on the LSR PA your dues at work.the LSR PA is also assisted greatly by.our sponsors there's different levels of.sponsors you can find them all on our.website there's a whole host of them.here as Kathy mentioned this course.today is being applied for CDC's there.are continuing education requirements.for those of you who are LS are PS you.probably all know that in during your.renewal period that three-year renewal.period you have minimum CEC requirements.those are listed here and the ethics.course is starred because there seems to.be a lot of controversy with the LS or.PS about but timing and the availability.of ethics course so just so everyone is.aware the LS are PA does offer their.ethics course.it's a three credit course to meet the.minimum requirements we do that six.times during a three year license period.typically we do it twice a year in the.in the spring and in the fall and it's.held throughout the the various parts of.the state our next ethics course is in.September in Somerset and then there's.another one scheduled in January of 2018.if you are in Alice RP you want to.register by all means please go to our.website LS our PA or to do that one of.the things to keep in mind about the.ethics course is that in the past.apparently there's been some issues with.license renewals and the timing of folks.forgetting possibly to complete their.ethics course and so again this is more.of a reminder for everybody to make sure.you pay attention to that make sure that.you are registering in time and I'll.talk a little bit about the timing of.things as well so everybody's clear on.that with regard to continuing ed just.so again LSR pizarra where there's.essentially two categories where you can.gain continuing education credits one is.basically by attending courses or.instructional seminars where you get one.fee fee for each our participation in.that class if you are a teaching a.course or you're doing a presentation or.you're doing a paper at a conference you.also as an individual doing that are.eligible for continuing education.credits in the activities category so.don't forget if you're very active if.you're out doing things you're talking.you can you might be may be eligible for.CCS you just have to make an application.to the board to be able to do that we.were asked to do a public service.announcement from the licensing board.and this has to do with tracking your.continuing education credits for each of.your renewal cycle.as I mentioned the most common issue.seems to be on the timing so bear in.mind that your renewal application is.due to the licensing board 90 days.before your expiration date and at that.time of application you have tab all.your CEC is completed so it's not.advisable for you to come in and say you.know here's my application I still have.15 credits to take I'm going to do those.in the next six weeks and all likelihood.your application is going to be rejected.so please by all means make your life.easier by making sure you have all your.CDC's in place and documented by the.time you make your application speaking.of courses if you go to the LS RPAs.website there's a number of courses that.we have scheduled throughout the balance.of the year um those are all listed here.in your handouts or listed on the.website so please visit that in.particular there is a full day commingle.bloom training course for those of you.can't get enough of this topic on.January 25th well we'll go and we'll.dive a little bit deeper into some of.the technical issues and some of the.resolution issues that we won't be able.to do today a few other LSR PA.initiatives I don't know if we're.calling it this but the big conference.we're doing a two-day conference in the.beginning of the year where we'll have.multi multi courses being offered we're.going to tie that in with our annual.meeting so look for information with.regard to that coming soon a couple.other more recent things we just did a.white paper on historic Phil which is.very interesting those of you who deal.with the Stork Phil I urge you to take a.look at that we have a course listing on.our website of all the available CCC.courses that are out there we have a.tracking tool to track your CEC is you.can keep track of all your requirements.and completed courses during the three.year cycle we have a list of ls our.piece who are willing to participate in.dispute resolution those we're not.endorsing any of those people those are.all strictly volunteers.um for if you're if you have a situation.where you're looking for someone to to.mediate or try to help resolve a dispute.between Alice rps or adversarial parties.these individuals have volunteered to.make their services available so contact.them directly and we also have a.sounding board the sounding board is for.LS RPS we started this in response to.some of the smaller shops where LS RPS.are sole practitioners or are small.firms where they don't have the.opportunity to engage in as much.dialogue as some of us that have.multiple LRS RPS and affirm and you can.write in and ask a question and then.there's a team of ellasar PS that will.sort of skull over your question and.then provide a response back to you a.verbal response it's obviously a.non-binding and a full legal disclaimers.on our website but it's a way to help.probably provide some feedback or else.our piece you don't necessarily have.that or or any other sarpy that may have.a difficult question where they're.looking for some additional input on oh.the else RP also has a bunch of social.media we have a LinkedIn page Facebook.page apparently we are tweeting now so.it's very exciting on our LinkedIn page.we actually do have some discussion.topics that come up anybody can join.that if you're a LinkedIn member you can.join that LinkedIn Ellis RP LinkedIn.page and we do announcements in there.and there's also some discussion topics.that happen as the MSRP is LS RP a is.always encouraging people to get.involved so those of you who are LS are.peas and say even non LS RP if you want.to be a part of the various committees.that the LS RP a is involved when we do.things like work on these guidance.documents we have periodic meetings with.different management groups within the.department and try to provide feedback.to our membership but by all means if.you see something that you'd like to get.involved with just reach out you can.email the general mailbox on the LS RP a.website and that will get you involved.so that's it on the LS RPA and with that.I think we're going to get started with.the actual course and I'd like to.introduce Marianne Kooser we'll kick.things off.one other thing too I forgot to put this.in your package but the LS RPA did a.fact sheet on the MSRP a pro-am yellow.star P program and what the LS are PA is.all about I left a bunch of them at the.table you can get them from our website.it's sort of just general information.about what an ALICE RP is what the.program is about and what the.Association does so if you want to pick.those up there upfront debt thanks.okay connector noon everybody no no no.okay we don't change switch which Jessie.helpless that's right that's when I.pushed first okay all right uh for those.who don't know me a Mary Ann Q circ.bureau chief as a viewer of groundwater.pollution abatement and also the lucky.chair for this committee so I'm just.going over pretty much a document.overview and an introduction to the.process first of all I'd like to thank.everybody that was on the committee.here's a list of the DEP folk as well as.some of the external stakeholders be.working on this document.it's got to be three years or so if.there was oh there's a lot of a lot of.technical difficulties and a lot of.administrative changes and tweaks and.idiosyncrasies and nuances to the.process so I think most of us are here.today John's home with the flu let me.see Lisa hurt her foot so you're going.to be listening to me again twice.instead just one other time so anyway.most of us are here today yes yes George.Nicholas George Nicholas recently and.mr. George Bligh Sheehan is that also.retired a while ago but they put them on.okay all right.just an overview of this technical this.technical guidance document there are.certain things that had done it defines.what a commingled plume condition is it.discusses several common commingled.plume scenarios store in our discussions.there were certain scenarios that we see.a lot so we that tell the guidance.documents broken up a little bit.describe some processes of investigating.the contamination and tools to come up.with your technical lines of evidence to.reach your remedial decisions identify.technical tools and techniques to.establish those multiple lines of.evidence we also have a list of possible.resolution mechanisms that vary from one.of them is the L SRP mediation process.versus if you can't come up go to court.or ideally work together it also.outlines some administrative procedures.issuing an REO and remedial action.permit compliance Mike in fanger we'll.be going through that in detail we can.to come up with a slightly different.process for that so in different notices.and things that you need to include in.your REO also at the end we have some.case studies for some work common or.commingling scenarios that we see fairly.often first of all the definition of.commingle plume your commingle clean.condition Komeito clean condition exists.when groundwater plumes originally.originating from two or more temporally.or spatially discrete contaminant.discharged as mixed or encroached upon.one another to the extent that the.remediation performed on one plume will.affect the remediation of the other.contaminant.so basically there are some examples.that plumes are once all quite ones on.we have certain examples in a scenario.where there's two on the same site but.time is passed so there's two different.owners that are responsible for each.part and we'll go through that in more.detail these are out of water there we.go.these are a little bit out order some of.the commingled home scenarios that we.came up with I want to stress that these.are based on technical differences and.more commonly administrative differences.if you have these different scenarios.how to get in.out of the process is slightly different.so that's why they're broken up this way.we either have off light sources.different or similar constituents or.on-site sources with obviously different.or similar constituents and the similar.constituents we sometimes refer to that.as the overprinting scenario this is a.in particular some of the service.station folks were concerned about that.there's a spill from a tank system and.then that person leaves the site and.then 5 6 7 8 10 years later there's.another release at the site and how to.differentiate who's responsible for what.this does not address all flight sources.that come on your site that have not.co-mingle you want to stress that the.off-site and we reference that several.times in the presentation the off-site.ground water source investigation.technical guidance document is what.you'll use and like I said we reference.that on some occasions go back for a.second ok.no I think they got put out of order so.I'm just done so it's like that back.what oh no oh no I know it's whatever I.got it I'm trying to close this oh oh.that's ok that's what that's not me some.of the other terms that are specific to.this document are lines of evidence.there were first information to help.support a conclusion the document.focuses on establishing and developing.multiple lines of evidence then when you.are assessed community cumulatively they.can reduce uncertainty and provide.support for the remedial decisions the.next term is off that I kind of.discussed is overprinting and that's a.condition when results that are.temporarily discrete discharges are :.co-located on the same site ok here's.the quiz.all right all right we have a clue so.the guys are going to open it up okay so.the question and I want you guys all to.pay attention in the room and you're not.going to yell out the answer you're.going to raise your hand okay for.off-site sources if the plume is not.commingled which DEP technical guidance.document can be used to conduct.additional investigation click I am I'm.clicking.you're clicking unclick right I guess.it's it appears to be very low this is.very odd okay don't worry about it okay.I'm cloud remember a dr. Seuss is the.Lorax.nobody anybody know okay Zoe or B it.would be the green of sustainable.remediation no nobody looks interested.how about the off-site source.groundwater investigation technical.guidance did I say don't yell out I said.raise your hands when you're supposed to.come up okay yes huh.they can't shave but they could hear you.go over a room a room we have a question.you want did you want to say Lorax no.okay so we need to give the guys on our.webinar folks one whole minute so Rob.are you doing for vacation this year.same way from you she's staying away.from me that is mean and look how ready.got that's alright it's worth every.minute all right how we doing as far as.time good okay very good all right we're.going to move on okay yeah so here we go.now it's working all right.there you yes that's a correct answer.okay.okay so what are some pieces of.information or data that you've gathered.that can show that you possibly may have.a commingled plume you know once when.you have some of these conditions that.may behoove you to evaluate if you have.a combing emplous or not the presence of.contamination different than those under.investigations the obvious easier.easiest scenario is you're dealing with.the underground storage tank you have.your sampling for your v-tex doing your.volatile skin then all of a sudden teeth.or PCE shows up and your well that's.probably not from you if you see changes.in the race ratios of contaminants.detected obviously you have to take into.account degradation especially for.chlorinated but that's one indication.changes in some of the geochemical.conditions at the site if you have.unexplained sustained increases in.contaminant concentrations one of the.scenarios we go through uses that as an.example and also if you've modeled your.plume and that twin length or the.configuration is different than what.your predicted with the models and you.know basically stuff doesn't make sense.that may be something to take a look at.sure well we have questions I think.there's questions after me aren't there.yeah after mark okay you know obviously.these are just you know things you may.want to take a you know what this is.have this condition you may want to take.a look at possible commingle plume.there's a few general rules but that.kind of our overarching throughout the.document that you'll see one in one.thing we try to stress when we use.similar contaminants versus different.constituents and different contaminants.is justifying coaming uplands with.different contaminant signatures.sometimes is a little more.straightforward and not quite as.complicated if you've got two discharges.of TCE from two different places it.makes it a little more complicated and.you.likely are going to have to develop.Moulton more complex multiple lines of.evidence to make that determination also.one of the things that we also want to.stress is during our comment period we.received a lot of comments about.especially in but with our with our are.not the technical aspects or some of the.administrative processes but with a lot.of the variant or resolution mechanisms.and such there was concern that if you.didn't use one of those you'd have to go.in and justify why you did that's not.what we are they're in there as.suggestions and things you may want to.look at so you don't need to come in.with a variance or justify why you.didn't follow all of those resolution.mechanisms the technical tools is the.same thing they're out there they are uh.appropriate for everything there's also.more technical tools that we didn't go.out or aren't in the guidance document.that may help you with your cause so you.don't necessarily need to satisfy that.regulatory obligation by trying to.justify some things that's pretty much.all I had the magenta clover group okay.and yes mr. Fischer will be back he's.going to briefly describe some of.technical tools and such that are in the.dark I was for her sorry thanks for.clarifying that Jessie appreciate it.yeah Mary Ann mentioned that the.guidance document talks quite a bit.about using multiple lines of evidence.to investigate in to address commingle.plumes so the document spends a good bit.of time Wow talking about uh what are.lines of evidence and how are they.defined and basically is defined in the.guidance documents information that.helps support a conclusion typically a.single line of evidence isn't going to.get.you over the bar and the terminology.multiple lines of evidence I mean there.may be situations where a single line of.evidence will work but more often than.not it's better to have more than one to.establish your technical position with.regard to commingled blooms and also.with with most things your investigation.can by using multiple lines of evidence.can reduce some of your uncertainty and.provide support for your remedial.decisions so the guidance document talks.about various lines of evidence that can.be used and as Marianne mentioned and.this is you know really important to.note on the bottom that there are more.lines of evidence that exists than are.outlined in the guidance document one of.the things we tried to do is you know.pull information from the folks that.were on the guidance committee getting.also reaching out to the various.stakeholder groups that had.representation on the guidance documents.committee to come up with what are the.most common lines of evidence that.people are utilizing when they're.dealing with commingled plumes however.that is not to say that there aren't.other options and again I think that.that's one of the things we've got a lot.of comments on that ah not only the the.point that Marianne mentioned before.about I don't have to justify why I'm.not using you don't approve the negative.on why you didn't use six of these lines.of evidence you just have to justify why.it's appropriate in whatever lines of.evidence you have picked for your your.site so then the document goes into you.know what are these lines of evidence.that we're talking about um the first.one is the department's database so all.those CDs that we have been submitting.for the last 20 years.supposedly are all residing in a.database that exists that the department.has access to some folks have it reached.out to Henry kinder badr I think he is.benda keeper for most of this in the.past we don't want to necessarily tie.this to him so in Appendix C we talked.about you know how do you access that.information there there are different.ways to get it different ways that it.can be delivered to you a lot of it has.to do with how you ask the question so.we would encourage you to if you're.looking for sources sometimes or you're.looking for information about a site.that may already exist that you know.about but you're having difficulty.gaining access to the data either.through a file review or whatever means.you can reach out the department and.they can export to you this data so.don't ignore that as a possibility and.they can do you know a reasonably decent.search around your site for those types.of type of information.the USGS also has something called a.groundwater watch and that is a database.that they maintain and within that.database of its information from state.and federal studies supposedly over the.past hundred years so there's a lot of.information in there more often than not.that doesn't have anything to do with.contaminated sites has to do with water.use flow related information within.various aquifers influences that pumping.regimes might have on groundwater usage.in the different aquifers but again it's.important to know if something looking a.little wonky with regard to groundwater.freight transport a groundwater flow on.your site some other multiple lines of.evidence areas to look into is the New.Jersey geoweb so how many people have.ever access to geoweb a lot of hands.very good there's a lot of information.in geoweb more than just what you might.think with regard to you know plot and.SRP site or looking at a CEA there's.quite a bit of information in there and.I think that there actually is a giant.course that's offered period.I believe that the departments involved.will go through what's available in.geoweb there's quite a bit of.information that's in there it's not.just like I said it's not just SRP.information it's all information that.can be really helpful with regard to.identifying what might be a possible.source to a commingled situation of.course there's Data Miner Data Miner for.those of you who don't know is a list of.all the SRP sites and other regulated.activities that the SRP is involved with.more often than not people use it to.look up statuses of Jesus sites what.information might be available in terms.of reports etc again all that.information can be helpful if you're.trying to gain information on informing.your communal bloom situation we discuss.other commonly available sources as well.in terms of establishing your multiple.lines of evidence those commercial.commercially available packages that.typically lose Sanborn maps historic.aerials.historic topos a lot of times some good.information can be found at the.municipal level if you do a folio.request so all those are good places to.look for as you're gathering your.information putting together your.multiple lines of evidence one of the.things we talked about quite a bit in.the guidance document and it's discussed.in a lot of our case studies is using.actual groundwater data from your site.and typically when you're doing your.investigation and you encounter a.commingled bloom scenario you're going.to want to collect some data that might.be beyond what you normally might want.might need to collect to satisfy your.basic RI obligations those are all.things that you should be thinking about.as you're developing your lines of.evidence sometimes those pieces of.information are easy to obtain sometimes.it's not so easy to obtain particular.when you're dealing with access issues.but keep in mind that as you're putting.together your investigation those are.all things you should be thinking about.in terms of your data collection.port Oh what the condition is or what.your potential conclusion is with regard.to how a combing film is behaving other.things to think about in terms of.multiple lines of evidence our.preferential pathways these are things.such as specific geologic conditions.there could be very stream channels or.other types of fracture embedding.playing scenarios that could be.influencing what's going on with flow.and contaminate vein transport you need.to make sure you're looking at those.things carefully that can influence what.the behavior of a cobia loom or any tool.might be doing I'll also look at your.man-made ute conditions such as.utilities foundations piles things that.again can influence what's going on with.the shape and behavior of a filming of.plume one of the things that is sort of.a I guess I would consider sort of a.science so to speak is the whole concept.of fate and transport modeling we talked.again in the guidance document quite a.bit about how to use fate and transport.modeling and those types of models can.range anywhere from very basic.analytical models that can predict a.concentration behavior there are reverse.particle tracking models where you can.sort of back calculate and try to figure.out what a condition used to be B flaw.that resulted in a commingled plume.condition there are other models that.can be used to evaluate what the.potential resolution options might be.and we'll talk a little bit about that.later in the presentations about how you.can do that to use these models to help.facilitate a resolution there are quite.a few models that are in the public.domain we try to include those a list of.all those in appendix F of the guidance.document and by all means those are not.the only ones that exist there are a.whole host of very expensive and.sophisticated models again.tailored to your site whatever you think.might be appropriate to justify the.condition there's a whole section in the.guidance document that talks about.statistical analysis and how statistical.analysis can be used when dealing with a.commingled bloom situation there are.obviously statistical techniques you.don't necessarily have to be a.statistician to do these some of them.you might want to have some background.in statistics because they can get.pretty complicated most commonly those.statistical models help address the.uncertainty component with trying to.predict what's going to happen.particularly in a communal bloom.scenario they can help to predict trends.they can help evaluate different sources.etc there are geo statistical methods.that can be used those are typically.spatial distribution models again that.can help evaluate and look for patterns.that may not be readily apparent when.you're just looking you know how to date.a data table or a data figure so.Catholic analysis those are basically.probability analysis where they try to.predict uncertainty and in certain.scenarios again things get very.complicated and you're trying to use.models to predict that you can use this.type of analysis to basically say well I.think 95 percent of the time this is.what I expect the outcome to be or.greater than 50 percent of the time I.expect this at the outcome Appendix B in.the guidance document talks about of all.the examples of statistical analysis.that we could come up with again we try.to tap into the ones that are the most.commonly used that people have.experience with this by no means is a.list of all the statistical models that.are available out there again.use whatever resource you think is.appropriate to establish your multiple.lines of evidence.another good guidance document to tap.into is the monitored natural.attenuation guidance document that.document lists a whole host of.statistical methods that can be used as.part of your M&A strategy a lot of those.over.or very similar when you're dealing to.co-mingle plume scenario.similarly in the groundwater s iri are a.technical guide in stock into their.others there's additional discussion.about statistical analysis another sort.of science that exists out there with.regard to dealing with the investigation.of filming with plumes that can be very.helpful or environmental forensics this.again is sort of a an area of study that.there's actually firms that specialize.that that's all they do or these types.of things and again they range in from.very basic laboratory analysis very.complicated and very complex data.analysis that can be done and those.again they can look at the historical.chemical behavior help to predict what.the past or the future of this.commingled plume scenario might be it's.typically used a lot most commonly is.probably doing with age dating again.it's any of those of you that have been.involved in a litigation that involved.trying to evaluate what happened back in.the day trying to date a plume that's.environmental forensic techniques are.pretty common in that in that area it is.an evolving science and there's actually.new things that come out all the time we.spend in fact one of the case studies.talks of quite a bit about one of those.specific techniques that we'll get into.later than the day in Appendix II of the.guidance document we talked about again.the most common we identified or.utilized forensic techniques some of.those are specific to petroleum.hydrocarbon the fingerprinting and the.piano analysis there's degradation.compound analysis that you can do beyond.you know strictly looking at the data.that you generate from sort of a.straight volvió see analysis there's.trace compound additives.uh there's a compound specific stable.isotope analysis that's one of the ones.we talked about in the case study where.you basically look at the molecular.level with some of these compounds to.help identify who's who.again it's it can be pretty complicated.and pretty expensive approach to take.but oftentimes it's it can be a.necessary line of evidence that you need.to to make your case similarly there's.biomarkers and weathering analysis those.are most commonly used with petroleum.forensics another model that we talked.about is using the CSM there's actually.an existing guidance document that.exists from the department about.conceptual site models and that.essentially can be a written or an.illustrative depiction of the physical.chemical biological procedures that.influence the transport migration and.potential impacts to receptors again.trying to help explain a complex.condition is oftentimes very helpful to.use a CSM to do that so take a look at.the department's of guidance document on.that I think we have it a test question.yes we do very exciting okay open it up.or our oh I don't do anything oh that's.good right yeah don't touch our so good.so far so good.okay so we're open yep put the clickers.down okay um all right so the question.if you are awake the last 30 seconds you.will know the answer to this question.okay a conceptual site model is a.written or illustrative description of.the physical chemical biological.processes that control the transport.migration and potential impact of.contaminants to receptor is this true or.false.is it true or false they are awake.that's wonderful and we I know I was.totally leading so I'm afraid to talk to.rob we have no 30 seconds we're going to.talk to all round mr. nice-guy.mr. puttan can you tell me do you have.any plans for summer oh yes I'm going to.Delaware all vacation.I'll have to talk later that's sad all.right do we have a everybody's are going.to want to volunteer made fun of a.different fun of your vacation is here.all right how we doing we've done with a.minute and more stackin see I shoulda.asked that question slower more slowly.we're just about there.and they're going to close up and we're.going to have questions very soon and so.get ready I just click there's true yes.all those smiling faces said it was true.oh yeah that's nice okay all right I.guess come on already.all right so a couple final lines of.evidence that we talked about in the.guidance document something known as.high resolution site characterization.there's actually a guidance document.that exists on this typically those.things are somewhat dynamic types of.field investigative strategies where.you're doing focused data collection to.refine your understanding either of.ethology or contaminate distribution.often in three dimensions those things.can be done with direct push tools using.a membrane interface probe there's some.borehole geophysics that can be done.there's saw gas sampling techniques you.can use those in any combination of.those various tools again the idea is to.gather additional information on your.site characteristics to justify your.condition with regard to a commingled.plume condition that help predict.whether they're happening in the past or.what's going to happen in the future.like I mentioned typically those are.real-time data evaluation tools and that.way you can make adjustments in the.field as you're collecting additional.data to help hopefully inform your.decision-making.so in the guidance document there is a.table and it is a potential lines of.evidence checklist and the idea it's a.very busy table um if you look through.the guidance documents it's multiple.pages again the idea is to use this as a.tool to help you keep track of various.multiple lines of evidence that you're.collecting to help formulate your.opinion to make sure you're not.overlooking anything again this is not.designed to prove the negative and.explain why you didn't use a particular.line of evidence it's really again a.checklist it's not a requirement it is.just a tool to assist LSR pieces.actually I don't know if we had it in.the original guidance document or it was.one of the things that people ask for.but people like checklist so we included.a checklist so in summary there are many.options for developing multiple lines of.evidence when you're dealing with.contaminated co-mingled plume multiple.lines of evidence are useful in.investigating and valuating and.justifying your remedial strategies and.your resolution mechanisms as we'll hear.about in a little bit again not to.stress this enough the multiple lines of.evidence of the guidance document are.just examples use some of these or none.of these it's really up to you the idea.at the end of the day is that you've.established as the L SRP sufficient.evidence to support your conclusions if.you fail to do that then when you make.your submission whatever it is in the.course of your key document submission.or your permit application you will.probably get questions from the.department so the better you do with.documenting your multiple lines of.evidence the better off you will be in.these conditions and it really is about.utilizing professional judgment we got a.lot of comments about that with the.comments that we wanted people wanted to.make sure that we are reiterating the.importance of professional judgment by.Alice RPS when you're going through your.lines of evidence and identifying what.line.evidence to use how many to use how to.justify explain so that is the multiple.lines of evidence section of the.document don't go far because we have.quite a question we're open for.questions webinar and this gentleman has.been holding on to that question for a.while.Thank You Tess first of all I want to.thank you for sticking it out and.getting this guidance document completed.there are a number of us that we're.waiting a very long time and prompting.every six months where is it where is it.I'm glad you got it done and I think.overall it's it's going to be very.helpful for practitioners the one thing.in my read of this document was that.struck me was that establishing physical.flow relationships you know among these.plumes these commingle plumes really.wasn't it didn't seem to me to be.addressed appropriately in the guidance.it's mentioned as background data that.you could collect it's not really you.know there's no specific requirement or.no hierarchy of requirements of multiple.lines of evidence most of the guidance.document seems to be focused on forensic.chemistry and things of that nature.which is appropriate but if you don't.have the physical groundwater flow the.geologic setting and the groundwater.flow.defined sufficiently then there's no.point in doing any of the other stuff so.it seemed to me that that that one.factor might have been up sort of you.have to have that before you do anything.else and I just like to get a sense of.what your thoughts were as you were.developing this guidance along those.lines when we were coming up this I.think our maybe we didn't reiterate it.as best we should have but the whole.idea was this is stuff in addition to.the regular what you need for every case.that you're evaluating commingled Plumer.not this was stuff in addition to the.basics which ground water flow obviously.is a critical piece so I mean we didn't.stress that.enough but these are kind of I think.there's a section on if you do in.quote-unquote the usual investigation.that you need to do that in this stuff.in addition to they might need to do.extra to help you make that.determination yeah and I think your.point is well-taken I mean it is.something that is more important.probably than as your fundamental.information that you need to be.collecting that's really going to.influence all the decisions you.ultimately make so good point two.comments picking up on what you just.said we trying to find out if his.gaining streams and losing streams.unless we talked to you nobody else.seems to get into it that much just.because the geology like when you go to.Pennsylvania in New York it's a much.bigger deal but when we talk about it.it's like like I said most we're talking.to you I think you should go further.with what he said that's my only comment.because we don't seem to have the same.level of training in the state like.other states with a lot of rockets on.like that so that's my comment but to me.the gaining and losing stream is a big.receptor thing a lot of the time so.that's just a general comment something.mark didn't mention I'll be very clear.about this somehow we have a break with.EPA sites that our surrounding states.don't have they don't go into the Data.Miner nobody seems to read the EPA.reports when they come out CAS are not.placed their stuff pumps we find in.residential neighborhoods so when we get.more money somebody should do that but.other states they formally comment on.each thing coming out in EPA go back and.forth and they go in the files we just.don't have that I think we should it's.just a general comment because I come.across commingled things once in a while.rarely by mistake but when EPA is out in.the neighborhood of a town in North.Jersey and people are studying four or.five other cases and you can't find it.that's not a good thing but that's just.a comment and I'm not I'm not saying you.know it is that it should get emphasis.that's why I like white because Ellis or.peas don't pick up those sites if.they're not being redeveloped they just.sort of sit in the black hole that was.my own comment.and I do think I do that I'm not a.hundred percent sure about this I'm not.super fun expert but I know there are.some sites that the department will.require a CA to map and but I don't know.that that happens on every no they're.all going they all should have but your.point is they don't know yes we can can.you guys in the control room can you.highlight the bottom one maybe if you.click okay the rest are not pertinent uh.does know it's like it's like when ii.start yeah stuff like that okay.trust me I'm from the government what.I'm going to take this I am going to.take this one first and then we'll take.you okay it goes the njd the unknown.source site list oh can read it site.evaluation report Oh does a whole wait.as a multiple line of evidence I guess.they're saying the unknown source report.that was looks like with a twenty two.thousand seven does that hold any weight.as a multiple one of the lines of.evidence well I think in general any.information that's available for you to.use it may not be the only line of.evidence you need you need to come in.with but there are you know some reports.for unknown source investigations that.we've done that are a public record I'm.not sure specifically what that recorder.is referring to everything if anything.that's out there in public information.may not stand alone but yeah you can use.it okay clearly we're talking about.coming up lunes we're going to be.talking about at least one gasoline.plume as the committee identified any.commercial laboratories that are willing.to fingerprint gasoline contaminants.actually John Engle is who is uh has a.lot of history with the petroleum.industry both working with the petroleum.clients and in the consulting background.he actually brought a number of things.to the table he didn't come up with any.in order to be necessarily one to.endorse a specific laboratory I think.the department is very careful about not.doing that sort of thing and I think the.petroleum forensics is also something.that it's continuing to evolve there's.actually a UH I think a one or two day.course that I think tours around the.country that makes a stop in New Jersey.and they spent almost the whole day.talking about petroleum forensics and.and what those opportunities are to do.that but it is it is something that's.not perfect at this point it's it.errantly very difficult to do any other.questions before our next speaker we're.going to one more speaker and then a.break of then short break okay.things melt like me no oh yeah okay okay.we're good okay.so you've done all gathered all your.lines of evidence you've made the.determination that there is a commingled.plume condition so now what do you do so.the committee we had a long conversation.with management here as well because.Haleh you know this is a technical.guidance document so we went through all.the tools and I think we made the.determination that really the a lot of.what people answers it a lot of to the.questions that people really want or so.what what do I have to do to move.forward with the process how can I get.out issue my reo so a large portion of.the guidance document it's kind of.evolved to discuss some of these things.okay the objective for actually grab the.loan come on okay some of the objectives.of trying to come up with a resolution.mechanism allow the remedial activities.to move to move forward and ensuring.that some of the mandatory and.regulatory timeframes are not missed.protecting receptors also moving forward.to avoid potential litigation between.parties potentially reduce remediation.costs time or cost if you're working.together and input into planning.remedial actions to address the releases.there's a few overarching that one of.the overarching things that will discuss.through the resolution mechanism is the.whole idea of using the multiple lines.of evidence is to determine which.contamination is yours and trying to.differentiate this is mine this is the.other guys so some of the a lot of these.red all of these resolution mechanisms.are basically you've already made that.determination and this is how you move.forward with the information that you.have.here okay and until you can determine.which molecules whose you are still got.the joint and several liability so.you're on the hook until you can make.that differentiation sometimes you can.do that and that's great and to be.honest with you sometimes there's just.going to be situations where you cannot.make that determination and so you are.responsible for the remediation until.you prove otherwise some things that you.still need to address and I know we have.comments about the time frames and.meeting the required time frames and.sending the information into the.department but certain things need to be.done quickly and regardless of the fact.that there's a commingled klum a lot of.these are related to IC and receptor.conditions obviously you need to still.identify all your potential receptors.you have to evaluate the mitigation or.you have to mitigate any impacted or.imminently threatened receptors that.would be that you know icy conditions.either VI or potable water impacts and.you need to control ongoing sources and.implement I RMS including three products.you know further for the for the free.product elemental guidance document so.you have to do those regardless I we.broke this out in coming up with a.resolution mechanism for your site.basically three you know three ways.either there's tools you can do is when.you're working cooperatively with the.other responsible party or you can put.if they're not giving you the time of.day or there's some circumstances where.you've got a whole lot of contamination.and there's a little bit maybe.commingling and it's a seizure and not.worth the aggravation to just do it.yourself.and also if you're the third type is if.you're dealing with somebody who just.doesn't want to have any parts of the.remediation and just like none of this.is mine it's all yours so that's how we.broke it down the first thing is working.cooperatively throughout the guidance.document I think we referenced that the.department's preference if possible is.to work work as a group you know I know.there are certain circumstances of.having feet.worked on a few like service stations.through the relic program that people.were using back in the day and that.really just it just makes life a whole.lot easier for everybody's coordinating.it together and a lot of times that's.just not optimal maybe at the beginning.but even if you can break down some of.the investigations smaller pieces where.you're working together sometimes that.can that can help as well some of the.benefits you know hopefully you can move.once you've agreed you can move the.remediation through faster you're not.fighting with people anymore um usually.it's more efficient there's one set of.welds going in instead of you know party.a putting in on men party two putting in.trying to get access to either of them.so sometimes that helps also off-site.access you can eliminate some of that if.there are people you know if you need to.get on each other site some of the.challenges with trying to do that are.trying to you know figure out who's.who's paying for what and the cost.allocation completeness of like you.determined that there is a commingle.plume and the completely some.investigation party a is almost done.with their remedial investigation party.B hasn't even started so how do you get.them on to the you know onto the same.page another challenge can sometime be.the goal at the end this person in you.know looking for a residential.development this person over here is.doin unrest and sometimes a conflict.what the objectives and the goals are a.lot of times we see that with active.versus M&A you know active might be.quicker the other parties like and we'll.do M&A it'll take a little longer but.that's what we want to do working.independently depending on the scope of.the situation this may be the easiest.passed path forward as I mentioned.before a large plume in the small bits.of chlorinated or T C or B Texas.encroaching onto your TCE pro kleh if it.may not necessarily be of issue might.just be easier.deal with it by yourself some of the.benefits of this are basically the scope.of the remedy is what you were your.party or they'll sarpy pills appropriate.timing you don't have to wait on anyone.else you can just you know go forward.and on your you know on your merry.little way some of the challenges are.though you're paying for the whole thing.you know so um and if that's not an.issue and timing or moving forwards more.important that may not be a problem also.proceed while you ability this came up.if you're cleaning up somebody's miss.somebody may be thinking oh you're.cleaning it must be yours so that's.something else to take a look at working.with an uncooperative PRC are there are.some tools that are outlined in the.guidance document that will 3 throughout.their mechanisms you can try to use two.one is a neutral party technical.mediation and related to that obviously.its technical arbitrator may be third.party neutral technical arbitration you.can use it outside agencies to do that.the LSR PA as Mark was talking about now.has a you know if you're a member you.can come in and they have a dispute.resolution group you might want to try.that there's all kinds of other.mediation and arbitration groups and.things out there not some of them not.necessarily involving an LS rp2.responsible parties can do that without.else our peace can also seek triple.damages if you have enough information.to show that you've been you've been.damaged or you're paying for a.remediation you want to go after the.cost for the other guy that's outlined.how you do that and get that authority.from us it's outlined in the guidance.document and this and the last thing or.is up here is litigation you know we sue.the guy we're not doing what you want.obviously this is not an exhaustive list.just some things these are more what I.consider more outside things you can do.outside the department there are also.the office of dispute.resolution at the DEP will they they.usually they will only work on disputes.between the EP and a responsible party.but sometimes that may be helpful this.will not address disagreements or issues.between Ellis RPS.but it's out there there are some.facilities in some cases I think that.have gone through this process that's.more to line up what we are requiring.but it is out there and also um.technical consultations the that's where.an LS RP and a responsible party can you.know come in to discus discuss technical.concerns this will not and on since I'm.the one that gets all these I will not.be addressing disagreements between LS.RPS you ask me I will send you to sue.Boyle because that is not our.responsibility and that it's not what we.do okay great it doesn't say that.perhaps that we'll take questions now.but I guess because because anybody has.this is all very much a general yeah.overview of things I have a couple.questions mostly related to liability.under resolution mechanisms you.mentioned identification of all.potential receptors could you talk for a.minute about a lot of this a lot of my.questions I guess all relate to one.thing and that is if I've done for my.client what I believe needs to be done.and I've demonstrated that going further.with off-site contamination is.ultimately someone else's problem if.they're recalcitrant are you suggesting.that we need to continue doing the other.parties work because if that's in fact.the case I can guarantee you that in.many instances lawyers and litigation.are going to put us in a hard stop and I.am trying to write resolve where the.guidance wants to take us with what.reality is out.a lot of what Mike in fair we'll be.talking about is calling the hotline.issuing our AOS for off-site stuff but.there's that's what a lot of his.information it kind of does is you found.this you've made a determination that.it's not yours what do I do next.and he will be going through that I.think administrative wise do something.yeah I just what I had to because that I.can appreciate that comment for sure and.I think when we were looking at the.guidance document the way I would look.at it is sort of where are you in the.process and if you are sort of in the.initial stages of the process and you.don't feel you have sufficient lines of.evidence to make that conclusion that.this part of the plume is not yours I.think you need the department's going to.encourage you to you know do what you.need to do to protect receptors during.that uncertainty period once you're at a.point where you you've made that.determination I mean you may be a.scenario where because if there are.potential receptors that are going to be.impacted or could be impacted you may.want to reach out at the department and.sort of make sure it's clear and maybe.there's some sort of document you may.want to submit I don't know it's going.to be really case specific but once.you're at that point I think Marianne.was saying then you're off the hook.you've demonstrated what you need to.demonstrate it's really during that.uncertainty period where we wanted this.what we want to distress you know you.may have to take care of something that.ultimately may not end up being your.responsibility but in the interest of.protecting receptors during that interim.phase you should be doing that I would.say it's probably you know key documents.submitted that's where you would do.those you know establish that line in.the sand that you're taking that.position you know and that would be in.an REO determination or we're going to.get to that so when we talk about that.you know there's a whole bunch of.scenarios that we sort of came up with.that you may find yourself in and what.do I do to get out that's really about.one more question and then we'll take a.break just a follow on and a related.question in the situation where you have.significant reason to believe that you.have.nation from an off-site source not.related to your site but you're not 100%.there yet you you don't have a slam-dunk.argument there what are the implications.with respect to timelines timeframes.particularly with respect to if you have.a potential impact who receptor in other.words do you have to abide by all the.timeframes in the situation where you.are not certain that the contamination.you're dealing with is your.contamination yes your you are yours to.be held to those timeframes I know with.some of the IEC you need to contact IEC.group if they're sometimes there's a.little wiggle room in that regard but.generally you need to meet the timeframe.that was what I was saying at the.beginning of my talk is I know people.going to say well I you know I only have.45 days to do this how am I going to do.it unfortunately until you show it's not.you you're kind of hook for the time.frame okay we're going to take a break.we're a little ahead of schedule so.let's come back at about ten of three.coming up is a very snappily dressed.Michael and Sanger and he's going to.talk about some administrative.requirements Michael oh yes yes I cannot.give me applause for learning how to use.click oh you're gonna have to just do.with your hands.yeah I can go again I press everything.fun and I wait it says to displace press.press the question mark button mMmmm.that's that okay ray okay that's what I.do at home I'm like oh friend everyone.now I can't make it go forward I have to.warm up can you cook an XYZ the word so.it should be this one okay is I'm.talking about section 5 I like to call.it how to get the cominging plumb.through the system because it sounds.better than administrative requirements.okay we're going to call it talk about.situations when cominging contamination.is found before the remedial action.permit is issued and yeah that's.probably most of the cases we will.consider finding the contamination will.consider scenarios finding contamination.off site versus finding it on site and.we will approach how to establish.classification area in these in these.situations okay we will also talk about.finding the commingling contamination.after remedial action permit and you.perhaps tre owes.already been issued and also there are.new notices for responsive action.outcome via for these situations okay.now each of these scenarios will involve.a call to the hotline so each section.has an enumerated numerator paragraph of.the steps to take and in calling the.hotline the sections in each and each.scenario look the same but they're not.and particularly we want you to note.that there is a an item number for that.has verbatim language we want to tell.the hotline operator you know whether.they want aired or not yeah yes and the.language is different for each scenario.and also should be noted that in one.scenario the call to the hotline is not.immediate okay so yeah the commingled.Plume scenarios were looking at our.overprinting so the separate discharge.is detected on site and the sources on.site also the separate discharge could.be detected on site but the contaminants.are actually coming from off site also.you might be delineating down gradients.and you might find different.contamination different contamination.down site or we could find similar.contamination down gradients.okay scenario one in a section 5.1 and.the guidance is the overprinting.scenario again it will involve a call.the hotline according to the you see the.language in the enumerated section and.you will submit a confirmed just a char.a confirmed discharge notification okay.within 14 days of the hotline call.oh and I have to mention this point.somehow we got a little of processing.error and we called 245 days in the.guidance document but we are trying to.get that fixed ok ok ok the scenario 2.is when we find the contamination of the.cominging contamination on site but the.contaminants are coming from off-site.and presumably we can document that and.so again we make a hotline call we.submit the CDN within 14 days ok this is.section 5.2 ok scenario 33 is when.you're downgrading your mutants perhaps.delineating your downgrading you find.different contamination a different.dissimilar contaminants in your you know.then you're looking for ok again you.will you will make a hotline call and.you will then complete your.investigation ok in this scenario there.will be no confirmed discharge.notification at least you know you will.not be doing that and there will be no.REO notice ok and it should be.emphasized it's important to use the.hotline language we give you because.yeah the last thing you want is for you.to write your RA oh and us to say hey.wait what about that number you you had.over there we want to separate that.number from your case and we decided to.put the downgrading scenarios in one.section so this is five point three.point one ok not to be confused with.five point three point two okay when we.find similar contaminants down gradients.okay.again you will complete your.investigation and you will make a.hotline call ok again there will be no.confirmed discharge.vacation and you will not put this in.your you will not put this number in.your RA oh and this is a case where oh.if they're similar contamination if.there are similar contaminants.you might not know right away that this.is not related to your discharge the.discharge you're investigating so it may.take you a while to compile the multiple.lines of evidence you need to say yes.this is somebody else's hang field or.something you might take you a while to.find that so this is a situation in.which your hotline call is not in me and.not immediate okay work or custom to you.within 15 minutes but call that line but.you don't really know that it's a.different discharge feel until you.compile your your lines of evidence.okay now everyone's familiar with RI.deadlines so you know that eventually.you're going to want to write your note.you're just you're going to want to.establish classification exception area.[Music].okay so we have there are some.considerations for this situations the.contaminated flume situation okay.wherever possible we want you to model.the India we want you to model the.individual contributions to the flume.using your modeling forensics or other.lines of evidence try to say this you.know try to ignore the other ones and.this would be my plume if if everything.had gone right okay now it could be that.that's not possible okay so when the.cominging plumes cannot be.differentiated you will put the entire.plume you'll draw the entire plume you.know even though you know that you your.discharge is not responsible for the.entire plume.you will need to put in your report that.you are you chose these boundaries.because you cannot differentiate the.plumes okay alright here we are again so.we're going to open up the question to.the webinar folks and just to reiterate.we're doing this in order for the.webinar participants to be able to get.credit for these and this is going to be.a very difficult question so hang on.when commingle plumes cannot be.differentiated include the entire plume.when developing a classification.exception area and I want to show of.hands is that true or false.somebody in the back fooling around okay.so it looks like we're we have another.30 seconds who can I bother.IRA how are you what are you going to be.doing this summer going to Maritime.Provinces of Canada that sounds like.more fun than Delaware I think is that.it no we need no no I should have thrown.it out more I'm actually going to.Vancouver and Vancouver Island and.famous Neil River sis doing the same.thing no I don't think so it's like I'm.watch you're going to each other the.restaurants or something on five more.seconds and then mike is going to.continue he's doing a bang-up job don't.you think yep.super all right closer all right and the.answer was true and you are going to.continue right okay.we also want to continue we always want.to consider situations in which you.already have the permits and perhaps the.REO and then you encounter the.commingling.contamination okay now we call these we.identify these situations as a b c and d.mostly to not confuse them with.scenarios one two three four okay okay.there is a table two in the guidance.table one is the the checklist multiple.lines of the heavens checklist table two.is the post remedial action permit.decision tree okay and it looks looks.like this except in the guidance.document it's expanded and much more.detailed and at this juncture I also.have to mention that there's an.imprecise use of words in the in the.table we use the word can we use the.phrase cannot sample okay and you know.be and the context is if you cannot.sample then request a permit abeyance.but you got viously you you can sample.it sound that I guess a lot of people.thought it sounded like we were telling.you you can sample you know but as we'll.see we're actually giving you more.latitude about sampling okay I am where.I think we'll try try to fix that one.too.okay the okay so scenario a is when you.have your permit you encounter the other.contamination but it has minimal impact.on your on your existing one or.mediation okay it could be that your.remediating be techs and also new get.some PCE but if the levels are low maybe.they don't affect your detection levels.or anything so you can just go on your.merry way no permit no remedial action.permit modifications necessary you have.just continue on your on your path okay.now scenario B is when you when you.encounter the contamination.and it does have an impact on your.remediation okay and we're calling it.scenario B when you are able to come up.with a revised monitoring plan and you.can get a permit modification that keeps.the and that will keep the permit in.compliant okay now the next scenarios.involve what we call remedial action.permit aband.okay and we thought we'd better have a.special slide on that before going.further what is an AB and we say they.even put it you know right in the middle.so everybody would see okay.an AB and puts the monitoring plan of.the permit on hold you know you still.have a permit but we're not holding you.to the provisions of the the monitoring.plan your permits are very inflexible.you know they says here the well as you.example these are your parameters you on.this schedule if you're not doing that.you're not doing what's in the permit so.if you're not able to to continue on.that monitoring plan or we call that a.remedial action permit abeyance okay so.when you encounter your content.contamination and you really think you.know my monitoring plans out the window.here with your next biennial.certification you will provide a.justification based on professional.judgment of you know why your monitoring.plan is no longer viable and then you.will propose an appropriate course of.action and it is subject to Department.written approval okay that is you're.going to get a letter and reply we call.an abeyance letter okay so again because.the permits are inflexible you might say.well my source will find.middle wells nice fringe wells are no.good but hey that well over there looks.good but it's not my permit.we're with the bands in effect you have.more latitude to modify your your.investigation and and your your your.monitoring.okay I know scenario says though.scenario C is when you have an the new.discharge affecting your remediation and.you determine sampling will not allow.for the differentiation of the impact.from the new discharge again and in this.scenario we're going to consider the.situation where you do have multiple.lines of evidence to to separate two to.separate out your of your discharge from.the other discharge you may have to take.other factors into account and maybe the.new discharge is effective affecting.your degradation rates or maybe it's Co.solving your and Co solving your.contaminants and increasing the spatial.the distance okay.whatever it is figure it out and you.know proposed to say propose and say I.have been able to figure out how to.extrapolate my remediation okay so in.these cases you would request the.groundwater remedial action permit.abeyance would continue you know your.silver permit you'll still pay your.permit fees submit your bio.certifications and then yes so you.develop the lines of evidence to.extrapolate when your initial plume will.would have met applicable standards okay.and that's your goal you want to reach.that point where you can say you know.everything went according to my plan so.I can terminate my./ okay he might not be so lucky you.might hate being scenario D and that's.where um the new discharge again it.significantly affects your remediation.but and sampling one different allow for.differentiation the flumes but you don't.have your multiple lines of evidence.you know maybe things weren't going so.well and your permits and your your.levels are bouncing out of bouncing.around so you can't extrapolate when.when the end of your CEA is okay once.again you will request the remedial.action permit abeyance and again you'll.continue pay the fees with the biennial.certification and in many cases you many.cases you'll have to wait till the.remediation of that other discharge is.completed before you can go and say okay.well how's my discharge going okay we.now we also have remedial action outcome.notices a you know for the command.Goldblum situations okay.Oh in one case we're going to use an.existing REO notice for the situation in.which you have dissimilar contaminants.that are coming onto your site and.cominging with your plume you will still.use the contamination remains on sites.due to off-site contamination notice you.know that's another thing that's in the.model document so you're probably.already familiar with that okay but we.also have new roomie we have new notices.for the RAL okay one situation is when.you have similar content constituents.you know on site and it's an off-site.source or you could have different into.constituents again multiple on site.guards so you have different.contaminants but they're coming from.your site or a more complicated.situation which yet similar constituents.also coming from your site these were.these are new notices they are in the.guidance documents they're not yet.available on the you know on the forms.page okay so for the time being if you.want to use the notices you'll have to.cut and paste from the guidance.documents also the REO guidance document.is not due for revision I think that.just came out last year so that won't be.revised in the near future to include.the new notices but I have been told.that there will be a listserv about the.new notices and that should be coming.out and a bottom on okay how about okay.where you can take some questions about.like topic or any topic that has.happened they're starting to start to.settle down.you know lab they're in low okay hold on.we have a question here I don't mean to.be a panic about this but I have a site.this has changed three times who is the.lead it's a permit writer or Mary Ann.three I've been inspected to say three.times what I'm supposed to do to make.the permit match the background to get.its change three times of you guys tell.me what I'm supposed to do who is the.lead person for Deitz I'm serious it's.yeah then you would have yep it's a.permit then you would call the for you.is called the permitting group we have.it's a permit issue yes in fact right if.you have a permit and you're trying to.you know work with someone to get the.monitoring plan it would be your your.permit writer you will or I'll give you.Stryder scenario and then we'll drop the.inspections done I get tagged ran out.too.background which is fine I said I'll do.it then I go through another inspection.and there's a different comment when I.finally come to the permit writer he.says you don't have to do it there has.to be one answer somewhere there had to.do with the different types of these.scenarios you're talking about you guys.don't agree with each other I'm not.trying to be what I'm just saying if the.permit writer makes a final decision I.shouldn't have gone through a process.and the permit writer says you don't.need to do it.but but I get these things sometimes.that's all I'm saying.yeah if I mean you know when you have a.permit so that's when you would contact.Mike's folks if there's you know sue vac.concerns about something that was in the.Bureau of an inspection or in reviews.obviously you need to contact them once.your permits been issued or you've.applied for your permit then you should.be talking to Mike and if there's a if.there's a disconnect I mean this.guidance you know we just pretty much.just finalized it in the last month so.you know if it was awhile ago.that's possible but you know if you have.a specific concern just reach out to the.people that one inspected it or to a.permit names I can I know answer was.wrong.so that says okay would work to that a.new guidance and will work to to fix.that all right because these things up.on the web are so hard to read hold on.one occasion a laptop here I can read.them from a laptop all right a former.SRP assistant commissioner said that if.the person responsible or other person.is not cooperating and the remediation.is not proceeding properly the.department would intercede and bang a.few heads together that's adorable.deficiency it knows when to mend and it.will make things happen.sounds good if there's a commingled.pluma and my client is doing the right.thing but the other party is not.cooperating would the department.intercede Maryanne I think you answered.this already wonderful answer again.resolution mechanisms.I think as far as departmental.intercession I think that would be.distill act directive.where in which K if you apply to us and.say look I got an ironclad case here the.issue is spill actor acted a you know.issued the spill act directed to me and.and that other guy and if he doesn't.cooperate I take him to court for.crippled evidence not you but worse what.party should right okay good next.question is we recently called.in an off-site source to the hotline and.when we gave the operator the prasada.prescribed language in the off-site.source guide yes the operator had no.idea of what we were talking about right.have that hotline opera's been trained.in this specific language for commingle.plume they have okay so people on the.webinar can't hear you if you're not on.the microphone what I was going to say.I'm Christina page um is I was on the.commingled whom I'm sorry I was on this.committee and I was on the outside.source committee as well so for the.off-site source guidance document I know.that the operators at the hotline Center.were trained however I believe they.still need to be trained for the.commingling guidance okay yeah okay so.I'm going to continue one because this.is such a pain in the neck I'm going to.continue on with the web questions and.then we'll come back to the people in.the room the next question is does not.the scenario to guidance conflict with.the off-site source guidance that does.not require a CDN for upgrade of off.upgrade off-site source.yikes does review scenario - does it.conflict with off-site source guidance.is I guess they're saying outside source.guidance does not require a CDN for up.gradient.cite sources hmm is that true okay do I.need to say it again okay yeah all right.we're talking about scenario two here.does it conflict with the off-site.source guidance that doesn't require a.CDN for up gradient off-site sources.it's a little hard to follow okay well.one they're not they're not the same.because they're not so nice to mingling.yes if it's cominging then you use the.the commingled plume guidance yes right.where it in there right there's no.commingling with the off-site source.guide all right and I guess if you.tenías right contact the committee if.you want more detail on that directly.via email okay the next question is hey.what's wrong with Delaware they've got.great beaches okay okay that's true.that's not a question okay I'll I'll.make sure I word my question you know.make my statements more carefully in the.future not to offend any particular.state okay we recently called in an.off-site source to the hotline we did.that one while waiting for NJ DP written.response for ground water rap abeyance.does the ground water sampling frequency.included in the rap need to be.maintained they're asking for in advance.they haven't gotten it yet.do they still have to sample according.with a permit okay well you usually a.permit sampling schedule is on the order.of every year or two you know so if you.haven't heard something in a in a year.then there's something wrong.so the I would say yes probably mean.that it's still you know yes yeah yeah.well right the timing is important for.how when you submit an abeyance request.for in advance okay anybody in the room.okay go back the room so big any big.questions any anymore about Delaware.nothing nothing okay well we've let that.go and we now are going to be moving on.to a couple of fascinating case study.familia.let's give Mike a round of applause did.not get the snappy dresser thing.inherently okay.good afternoon so as you've heard so far.this guidance document offers a lot of.options to deal with commingled blooms.in furtive some new concepts some.resolution strategies technical.administrative tools so next part of.this training is to go through a couple.of case studies I'm going to talk about.one excuse me dying of allergies.Rayanne's going to talk a couple others.and the purpose of the case studies to.try to wrap all this together see how.kind of the pieces all fall in place.least that's the intent so this an.overview of this first case study this.involves an overprinting scenario at a.retail gas station that's one having a.hard time it's a former large corporate.owner we call ABC retail and they had.completed this remediation for a.discharge in 1996.the selected monitor natural attenuation.they got their remedial action permit.they were in a remedial happy place in.2010 they sold to an independent.operator we call XYZ retail so during.routine monitoring by ABC retail they.notice the spike significant spike then.beat X which appeared to be new again.this isn't a sort of an over printing.scenario or the same constituents or.spatially similar but then poorly.different so I'm going to go a little.bit into some more background on this.particular case go over the tools used.to determine that it was a new release.discuss some of the resolution.strategies selected and go through.administrative resolutions which.ultimately were used to close the case.so as I said back in 1996 ABC retail.report is discharged or had a discharge.is associated with piping system the.reported discharge they started with.there s IRI.the complete significant amount of soil.excavation they completed some Elm apple.recovery based on the SRR I they didn't.have any off-site soil investigations.and no other receptors were identified.they install the series of monitoring.wells monitoring well network and now.that's hard to see but groundwater is.dint generally to the northwest they.installed to source wells and be down on.lower right that's associated with the.piping area installed to plume well C.and D that was in the source area I mean.in the plume area down gradient of the.source area and then they installed one.off-site set Noel line well II way in.that direction which is down gradient of.the pool wells.between 1996 and 2010 v-tex in the.source area generally decreases below.ground water quality standards the the.wells in the plume WA and the plume.range from non detected 20000 ppb in.this general timeframe but overall the.concentrations exhibited sort of a.decreasing trend within this network.ellen apple recovery ceased in 2008 this.is all ABC retail the initiate initiated.groundwater quality monitoring the B.techs in consent no well II consistently.was below ground water quality standards.subsequently ABC retail ceased.operations in 2010 so this is just a.graph of one of the wells and the source.area might well be original data the.released in 1996 ABC we tell ceased in.2010 a you can see sort of a nice.decreasing trend I said based on the.previous data ABC selected an M&A.revenue and this received early election.permit for groundwater they issued our.limited restricted use our AO for the.1990s 19 1996 case so at this point.right we're done and done they.subsequently sold the facility to XYZ.retail who began operations late 2010.and even post sale so they sold in 2010.to about 2014 their containers.decreasing trend while doing the rap.monitoring for those four years between.2015 and present mwb one of the original.source wells the beat x concentrations.increase.in order magnitude plumeria well C&D.same thing concentrations increasing or.magnitude one of the source wells a as.well as a sentinel well e-either remain.the same or we're below ground water.quality standards so this was mentioned.before even though ABC retail thought.this was a new discharge they were still.obligated to make sure that no new.receptors were identified there's no.Alan Apple will off state monitoring.wells so until they kind of collected.their their proof they're responsible.for making sure those of other receptors.just get back to the graph 96 original.date of release 2010 ABC's thesis.operations XYZ starts operations and in.2015 the concentrations go through the.roof so I guess that ABC suspected that.this was a new release so some of the.tools that they use to build their case.was to revisit the conceptual site model.clearly reviewed the operational history.and timelines they used statistical.trend analyses to confirm that they had.decreasing trends and they use phaeton.transferred modeling in this case fairly.simple they use fire screen to calculate.their CEA in point so the multiple lines.of use evidence used again to build a.case a was operational history they 16.years of data while they were operating.and four years of post operational data.you know confirming that there was a.decrease in trend they also documented.the effectiveness which is now back in.eighty of 98 effectiveness is their.source removal so they're confident that.they basically got everything previous.el Napa was soil excavation again the.trainer analysis confirmed emanation to.that monitoring period and another line.of evidence the fact that there's.lady significant increases of e-text so.based on that those lines of evidence.ABC retail concluded that a they had a.new discharge and be that they would.have met the grand water quality.standards seven years from the point of.XYZ.discharge so again original data release.cease operations new release and I think.it's 2022 was the calculated gan so.again the multiple lines of evidence.established that they had an over.printing commingled pollutant condition.ABC as part of the resolution strategy.decides to work cooperatively with X Y.or Z retail as I recall there were other.methods suing going along on your own.they just were cooperative lis XYZ.retail doesn't agree with ABC I know I.was shocked too with ABC retail.conclusions and refuses to work.cooperatively ultimately XYZ retail goes.the funked now what do you do so part of.the administrative resolution sort of.the old paradigm basically ABC retail.would had likely taken on the burden of.the new release I was going to use the.word Sol but you have to spell out the.acronyms I didn't and in do that likely.live out the life of the second release.or probably another 20 years and from.ABC's perspective this site kind of goes.nowhere sort of under the new paradigm.basically ABC after they had completed.multiple lines of evidence to prove that.it was new discharge would have called.well I guess in this case would call the.hotline immediately right in accordance.with section 5.1.again they confirmed with multiple lines.of evidence confirmed that there's no.new receptors submitted a CDN and notify.property owner no X Y Z's out of.business there is a property owner in.this particular case because two out of.our three out of the five wells were.affected they no longer could comply.with their permit so they had to modify.or they would modify their permit to.only include those two unaffected Wells.so then when you get new permit is only.you're only going to be responsible for.those two Wells not those three other.Wells that you got impacted by the new.discharge so assuming after seven years.as calculated CEA assuming after seven.years that.mmwa and either to unaffected Wells you.know ten you waited as predicted or some.other time maybe eight years nine years.but whatever that is for just those two.wells you could terminate your permit.after that period of time.okay and the point here is that ABC.retail based on their modified permit.we're now only responsible meeting.groundwater quality standards and -.instead of the five wells so at this.point then once compliance is achieved.in those two unaffected wells maybe so.you could issue an unrestricted REO to.be issued with the commingled plume.notice similar constituents you know.multiple on-site discharges and this is.Mike went through this is scenario B on.Table two if if similar to this.situation let's just go back for a.second and assume that all the wells.were knocked out by the new discharge.that would be scenarios C so in that.case you would put your permit into a.band right because now you can't monitor.any of the wells you would put your.permit into abeyance and then complete.biennial certifications and then.terminate your permit after your.projected seven years.plant tree that's it okay so we have.another case scenario thank you Michael.let's give him a round of applause go.there very few times when you connect.we're not going to take questions yet.very few times when you go to work and.you actually get a round of applause so.we might as well and do that when we can.all right so you're going to explain why.you are here yes I'm going to I won't.everyone slide and right after this we.will have all the rest of quad questions.for the case scenarios and then and.anything else and then we'll wrap up.okay all right um you guys are lucky.enough to hear me for a third time today.Lisa voice was supposed to be giving.this talk but she had a foot injury and.was not able to make it in so and it's.unfortunate because she has actually.used CFIA.some of CFIA techniques in her casework.so you're um I'm going to do my best.it may not get a whole lot of answers to.your questions but I'm gonna go you know.go through her information for these.case studies the first thing I'm going.to do is go go through a little bit of.what the compound specific isotope.analysis or CSI a does or can do or what.it is because we do reference that a.fair amount because it is a new tool as.Mark said it's an ever expanding you.know science for different things that.are coming out specifically the CSI a is.something that works this technique.works best for chlorinated it's a.geochemistry based technology it.measures the stable isotopes of carbon.and hydrogen and chlorine contaminants.to determine determine chemical or bio.if there's been any chemical or.biochemical reactions or degradation it.analyzes the abundance of stable.isotopes and shifts.in the isotope ratios to help identify.contaminant sources for chlorinated.compounds in particular if you have a.source of PC or TCE that ratio will stay.the same throughout the degradation.process and so you can look at the.shifts in the ratios to determine you.know really what's going on or which.which PCE is from which site it also and.this is an analogy that Lisa came up.with it's not a deep you know DNA you.know in criminal cases and you know a.PCE PCE source a source will have.similar characteristics like a DNA it's.not necessarily one on one match but.that was an example she was using to try.to explain how this start how this works.at the beginning you need mostly need.multiple lines of evidence just not this.chemical in front of chemical specific.information also obviously need to have.idea obviously have the heads on site.characterization if you're using if you.want to use bio remediation is when your.indicators you have to have all those.other indicators to the geochemical.indicators the biologic indicators and.you know what you still have to have all.that stuff and you still have to have.month you still are required to monitor.the effectiveness of your remediation.CSI a is accepted science for both.source identification trying to figure.out where source is coming from and also.if you have enough information you can.apportion okay percent this percentage.is this this percentage belongs to that.and you can figure out who is.responsible for what the ITRC has.several guidance documents under the.environmental initial or diagnostic page.there's all CSI is just one of the.techniques that's listed there I have a.copy of the fact sheet for the CSI a it.gives a real good basic and relative.we quick some quick information so you.get a general idea of what's going on.what we're talking about it and like I.said that has CSI a is just one of a.list of forensic tools they have fact.sheets and information for okay I'm.going to go through some basic case.studies and these are based on their.little simplified for the purposes of.this discussion for the guidance.document but actually these are two.sites that Lisa had used CSI a.techniques to figure out what's going on.the the first cut case study and these.are the ones case study for in the.guidance document it's a commercial area.there were many possible off-site.sources where VOCs were coming from um.this isn't there was a obviously a large.amount of work done in the big.evaluation 74 monitoring wells and also.included 100 screening points I think.they did a lot of myths out there.what made it complicated is the shallow.groundwater is clean so and the deep is.dirty so if they're trying to go out.there to try to figure out where it was.coming from and it was very difficult to.do that because there was many shallow.contamination CFIA was one of the tools.used she said along with a good PA in a.good local history to try to figure out.what's going on just have a pointer on.it remember that the people in the web.yeah I know.Wow okay okay oh okay okay all right.this is just an air photo with some of.the contaminant levels that were found.the way this is the top one is PCE the.middle one is TCE.and then the the bottom level in this.concentration the bottom one is the DCE.I want to apologize for the people on.the web I was going through this.presentation and there was no way.going to be able to describe the issue.is so I added this this morning to the.presentation I think everybody got a.handout here we can make sure the web.folks get it yeah well yeah oh oh I.turned the doggies in the guidance I.mean and I called it out as a document.page 65 in 85 and I just wanted to part.it up here for my explanation purposes.alright so um this they did a lot of.isotope ratio signatures and evaluation.at the site almost Gooden.how'd you how'd you put that on oh this.ah that would make sense it's green okay.um so along the top here are the.different ratios the on the top here.it's carbon 13 and carbon 12.this one is chlorine 37 and the ratio of.37 the chlorine 35 and the one over here.is hydrogen 1 2 hydrogen 2 and the.numbers aren't absolute when you look at.them you have to see how they match or.how they match up I should say so.and what the evaluation with all these.numbers I'm just going to point out some.things that you could see here's the.level of PCE this combination right here.as you notice they're all pretty similar.throughout the area that was evaluated.and a signature like this pretty much.shows that there's only one source of.PCE you know the ratios are fairly.closely there's one that's a little off.but in general this would be an example.of something that's pretty much there's.just one source of the TCE at the site a.few other things to look at if you look.at the TCE contamination I get these.right here in monitoring well in the.shallow you know it's it's very low.simmer what's the difference is between.the shallow and the deep the signatures.are well let me step back a second base.the ratio of the chlorine and the ratio.of the hydrogen in the shallow well are.indicative of like a manufactured TCE.sorcerer's it hasn't been degraded at.this point in time so that those numbers.are indicative of a TCE source in.addition to a PCE source and obviously.when you have PCE source than you have.TCE and BC from that as well and if you.look between 1 & 2 at the TCE look the.ratios here this is in this 31.2 and you.go over to the negative 78 that in the.shallow was a lot higher and now it's a.negative those numbers are indicative.that there is some degradation taking.place from some degradation as a PC so.just shows a lot of different things and.like I said the whole point of this is.you really need to look at the ratios of.what's in your source what's downgrading.your source and take a look at how.they're all weighed there are people.that do this for a living so if you.actually need somebody to do that highly.recommend you hire you know don't talk.to some funny because right now I'm not.the expert and what that ended up.showing is there were multiple.discharges in the area the and it turned.out after you went back tracked the PC.and like this is surprised by the way.that the former the PC he was from a.former uniformed rental service and a.drycleaner kind of go figure there are.other TCE sources that were identified.out there some of it the TC was a.degradation product but a lot of it was.fresh and so that was one thing they.needed to look at go out and figure out.where the sources of TCE were and like I.said before there were some of those.results showed that there was some PCE.tegra Dacian but there was also another.source of fresh TC d ok um once that was.all taken into account what do you do.the site in question was the we go back.to the figure of the site person that.started this investigation was the.Uniform rental rental folks.so they established a CCA for their.identified course and their identified.contamination plume since there was some.commingling from an unknown source.the TCE that was reported to the hotline.using the the off-site groundwater.contamination protocol and off-site.coming onto your site commingled.protocol that we talked bevel for an REO.issue was a was issued for some of the.off-site sources that they weren't.responsible for and went through that.process the lack of and I said before.the lack of the shallow contamination is.very difficult to figure out what the.source of the TCE was so further.investigation for that needed to be.taken needed to take place.administrative considerations this is a.scenario where an on-site discharge.there was a discharge on-site with.contamination why granny on flight from.an offside source so that's how that.needed to be taken care of investigate.to show that examination from off-site.and the subject site was not a.contributor the whole idea is this is.you had to do your off light source.Brown investigation for the ground water.off light source and do your pas I and.all that go through the process to make.your determination there's a few if the.contamination in the investigation shows.that the contamination is from an.off-site source and from an on-site.source.you're obviously required to remediate.your that what's on your site if it and.if it does show that it's from off-site.source obviously you follow the off.light source guidance document as well.okay and and just that in it if you find.out that it's not coming there it's not.commingling you um foul off light source.guidance and then put the REO notice in.your REO all right okay.the second scenario was a round field.redevelopment site going from an airport.airport to a mall there are several.zones the aquifer zones contaminated.once again there's a deep and a shallow.component to this originally it was.assumed that there were two different.source areas cieth CSI and CFIA and they.did a PA to identify other tools to.identify this contaminated sources and.the RPS on-site and off-site the in this.situation the CSI a shows significant.difference between two TCE signatures at.the site and two Dean Apple hot spots.and when they went all not just a CSI a.but all the multiple lines of evidence.agree that there were two different.distinct sources.I hope you can see this okay this is.also an example that was one of the.scenarios it's in the guidance document.same scenario five there's two things to.look at here you have robust there we go.all right um so this is some of the CSI.a carbon data that was the ratios that.were determined so you have this area.here and this area here these are in the.upper or the shallow zone and you will.notice that there's two significant.differences in the ratios as well as the.concentrations but keeping points it's.ratios don't take into account.necessarily consideration so at this.point they look like there was two.sources so when they went down into the.lower zone where things got a little.more palatable a little more mushed.together you can still see the the from.the uz1 to the LZ one.you know that ratio is very similar as.up and also in the area is uz2.and LZ - those ratios are within the.realm of similar as well so it's still.distinct that there's two sources when.you get out here a little bit more I.think that's when they started to.co-mingle a little bit more and it.wasn't quite so distinctive to figure.out but any long story short that did.find out that there were two sources.contemned commingling into the one clue.okay based on some of the ratios and.stuff that it's not in the scenario in.the in the document it goes into a.little more detail because some of the.information that was used could help.estimate the EI duration because you.could figure out this these are my.molecule these are their molecules and.come up with some trends and they.decided to proceed with the remediation.complete the remediation and establish.CEA for both again for both of the.identified sources if there was another.off-site source.obviously that would got that we would.called that in as an off-site source and.just you know per the peer the.department's procedures it's an unknown.source the triage unit will evaluate it.and it we may get involved if it's you.know potential icy condition the on-site.discharge was reported and remediated.obviously the CDNs to be reported within.14 days call the hotline uh and.obviously the PRC are has to retain the.el SRP and complete the investigation.for their discharges.okay all right this is our last one okay.so we're going to open it up to the.webinar folks and we'll see how many of.you are still awake.you're looking good all right how many.days from the hotline call does the.person response will have to submit a.confirmed discharge notification a one.day.see for getting upset to say it out loud.[Music].b14 days are awake see two thousand.seven hundred and eighty nine days or D.a whole lot of numbers okay there's a.smart guy in the back that keeps giving.the wrong answer okay all right so since.you know were we've talked about.vacation plans how many people like the.brownies versus the the chocolate chip.muffin brownies yeah chocolate the.muffins with the chocolate chip Center.fewer fewer people Oh very like them all.okay very good.so we're ready and I Mary Ann I have to.say you're doing a bang-up job and.you're going to get Lisa and you're.going to put her in a little different.ugly when you see her she's probably on.probably on the one yeah yeah so I think.I think if we get any complicated.questions about this I think they said.they should send them to you and we'll.get a mansion yes yeah how we doing.ready okay okay woohoo there's your.answer.working days okay um yes the way I think.most of these slides are you know.they're put together it's if you know if.you found out it was an off-site source.obviously you go if your forensics.indicated that was an off-site source.you'd go up go through the off-site.ground water source technical guidance.document so I'm just going to kind of.bleed through these and if it doesn't.show it's from another site and it's.yours.obviously you call the hotline and you.know get prompt follow section 5.2 and.the guidance so it's called.but in what to say you know once again.if it is from off site you can issues.are AOA and include the notice that it.rains on site from an author from off.site contamination.okay and obviously it's yours you're.responsible with the entire remediation.but you know I think in any of these.scenarios if you can demonstrate that.it's coming from off site and not.commingling you know obviously put.yourself to the upside ground water.content okay.all right so we do have questions and we.want to thank you for coming and I'm.holding up the green piece of paper that.shows your evaluation and we will.collect those so if there's any.questions Mary Ann if a facility is.operating for 20 years and they change.their supplier of pce and TCE over like.say several times over the 20 years will.that affect the ratios if they have.different suppliers okay you know in a.scenario like that you may not be able.to make the differentiation but um you.know sometimes again it could screw it.up yet what all right other questions in.the room in my vendor Hayden's example.and let's assume that the second.discharge is a lot worse than the first.and there's an off-site migration.component the way that you've described.it is that ABC company basically gets to.walk after the projected number of years.that they would have achieved.groundwater quality standards what does.the state do relative to XYZ company in.their discharge where there's obviously.we recommend that the LS RP and/or.responsible entity for ABC contact XYZ.until what they found that will get.called in and if you can bifurcate it.they are.on the hook you know that there's a.number associated with that site and.they still have to meet all the.mandatory and regulatory timeframes.higher there LS are P submit their CDN.form I mean they are then in the hook on.the hook I guess it push comes to shove.and it makes it a four student priority.and there's you know potential receptors.and stuff and enforcement action may.take place that that person doesn't you.know XYZ doesn't do anything oh boy lots.of questions so this is also from.Michael's example did the simple example.hesitant complicated questions than the.complicated example of simple questions.so ABC is monitoring and all of a sudden.is a spike and they have concluded that.there's been a new discharge okay I may.have been daydreaming while you were.talking about this but did you do.anything or did in this case was.anything done other than to monitor the.groundwater to actually confirm and.determine that there was another.discharge I didn't hear them yeah so.there's probably you know as I said.operational history was one of the.multiple lines of evidence.you know I presume you would look at.spills 2-6 there's a spill reported but.XYZ was not a upstanding citizen so you.know they didn't report anything nothing.was on the record I suppose a good knock.on XYZ store and say can I see her take.reconciliations and stuff like that.Larry would not there be some physical.evidence that in the recent past.something had happened to result in that.additional quantity of beat text to get.into the groundwater if that were the.case they should have seems to me they.should have found it but bottom line is.I I think they're right that there was.another discharge but I wasn't convinced.well yeah and so sort of the point of.that was not to get to the weeds of the.data and all that I mean yes you.probably wouldn't just rely on one data.point either right you probably have a.couple of follow-ups you might see some.Elm Apple and Wells you know that might.be.evidence but so the poison point that.case study was to follow the process.assuming ABC did their due diligence and.could make their case so yes just play.ten other things to do marry end go back.to that question you have ABC versus XYZ.the key here is XYZ went defunct.there's no longer any XYZ now what is.this fate going to do well it'll it'll.go into the pool of met mr. Cortina.mister enforcement he's here he can.answer that question the one off the one.off Ray's lawns of that different.property owner we would certainly look.to the property owner as a responsible.party of the property owner in even the.ABC situation is a statutory permit E so.technically they're on the hook for the.permit and certainly for the new.discharge that occurred under the XYZ.operation in the time frame that you're.talking about certainly our compliance.and enforcement folks from the.underground storage tank program was.pretty much riding herd on UST operators.that they had insurance so that would be.certainly one area to look to if they in.fact were complying with financial.responsibility more questions in the.room because behind it we have a couple.on the web I'm not sure foreigner let's.see.great presentation that was common.that's good thank you.Edie oh it says in the first case who.ultimately paid for the remediation of.XYZ retail you're saying they went in.nobody nobody well we here right now you.don't care but in general okay in the.first case in Scenario XYZ was said to.have dissolved oh he that was basically.answered who who is then responsible for.the new.contamination once the rap groundwater.rap is terminated the new RP okay.who-who should we of the webinar content.a participant contact if we don't.receive a follow-up email related to.processing our CEC certificates this is.a question so the question is if you.earned your CCC certificate you actually.signed out the way you're supposed to.and you were here the correct amount of.time or on the web the correct amount of.time you can contact me to make sure you.are on the list and that's I think I'm T.fields to at DEP backup and Jacob and.and I'll follow up on it and deceit see.what we have as far as records but if.you're on the list we send that to the.LS or PA and they they send the the once.you pay the big bucks that that you get.your certificate and any other questions.for any of our speakers I think they did.a great job but we're going to give them.all a round of applause we're going to.collect your evaluation forms as you.leave thank you.you.

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Njdep Licensing Form FAQs

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Do military members have to pay any fee for leave or fiancee forms?

First off there are no fees for leaves or requests for leave in any branch of the United States military. Second there is no such thing as a fiancée form in the U.S. military. There is however a form for applying for a fiancée visa (K-1 Visa)that is available from the Immigration and Customs Service (Fiancé(e) Visas ) which would be processed by the U.S. State Department at a U.S. Consulate or Embassy overseas. However these fiancée visas are for foreigners wishing to enter the United States for the purpose of marriage and are valid for 90 days. They have nothing to do with the military and are Continue Reading

How can I fill out Google's intern host matching form to optimize my chances of receiving a match?

I was selected for a summer internship 2016. I tried to be very open while filling the preference form: I choose many products as my favorite products and I said I'm open about the team I want to join. I even was very open in the location and start date to get host matching interviews (I negotiated the start date in the interview until both me and my host were happy.) You could ask your recruiter to review your form (there are very cool and could help you a lot since they have a bigger experience). Do a search on the potential team. Before the interviews, try to find smart question that you are Continue Reading

How do I fill out the form of DU CIC? I couldn't find the link to fill out the form.

Just register on the admission portal and during registration you will get an option for the entrance based course. Just register there. There is no separate form for DU CIC.

How do you know if you need to fill out a 1099 form?

It can also be that he used the wrong form and will still be deducting taxes as he should be. Using the wrong form and doing the right thing isnt exactly a federal offense

How can I make it easier for users to fill out a form on mobile apps?

Make it fast. Ask them as few questions as possible (don't collect unnecessary information) and pre-populate as many fields as possible. Don't ask offputting questions where the respondent might have to enter sensitive personal information. If some users see you collecting sensitive information, they might not be ready to share that with you yet based on what you are offering, and they will think twice about completing the form.

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