Perimeter Air Monitoring Guidance Document
The New Jersey Department of Environmental Protection (NJDEP) is scheduled to release their long-awaited Perimeter Air Monitoring (PAM) Guidance Document in December 2021.
With the new Environmental Justice (EJ) regulations from the NJDEP that speak to reducing impacts to overburdened communities from neighboring stressors, its no surprise that the NJDEP is focusing their energy on perimeter air monitoring. That being said, its primarily in the Site Remediation Program (SRP) where this document will reside, be utilized, and see most of the action.
This guidance document has the potential to do to the regulated community and the SRP what the NJDEP’s 2013 Vapor Intrusion Guidance (VIG) document did – that is to unleash a great deal of new requirements (in great specificity) to an area of the site remediation practice that is not that robust. Although the NJDEP Tech Regs have always contained a PAM “requirement” (there is one line in 7:26E-5.5(b)7)), it is lacking specificity and routinely ignored or loosely considered by the regulated community.
The level of prescription in NJDEP’s guidance documents SRP is typically very high. We expect to see specific and well-defined triggers for inducing responsible parties to evaluate their receptors and introduce PAM, if warranted.
The Basics of a PAM Include:
Definition of the Constituents of Concern (COCs)
Equipment Requirements to Meet the COCs and Objectives
Monitoring Locations, Frequency, and Operations & Maintenance (O&M)
Background Sampling & Action Levels
Data Collection, Data Management, and Reporting Requirements
The exact release date of the document is not yet known, but the NJDEP has been promising the document “by the end of the year.”