Below is language directly from the NJDEP Bureau of Release Prevention on the latest changes to the Discharge Prevention, Containment and Countermeasure (DPCC) and Discharge Cleanup and Removal (DCR) technical deficiency process for plan submissions, renewals, and amendments. This is applicable to facilities regulated by the Discharges of Petroleum and Other Hazardous Substances rules, N.J.A.C. 7:1E (the DPHS rules):
From: DEP Release_Prevention <firstname.lastname@example.org>
Sent: Thursday, June 18, 2020
Subject: DPCC/DCR Plan - Change in Review Process
The Bureau of Release Prevention has made a change in the review process for DPCC/DCR Plans, Renewals, and Amendments and is providing this notice to enable a smooth transition for DPHS regulated facilities.
In the past, when the Bureau identified deficiencies in the review of a facility’s plan, plan renewal, or plan amendment, multiple technical letters often have been issued to correct those deficiencies. In many cases, facilities have not addressed the deficiencies, addressed them incorrectly, or introduced new deficiencies in the revision of the plan submission. This has caused long delays in the approval of the plan submission. Prior to a site inspection, our engineers send notes concerning plan/amendment deficiencies and discuss and explain the deficiencies during the site inspection. Going forward, the Bureau will issue only one technical letter. If the deficiencies noted are not adequately addressed in the revision of the plan, a Notice of Violation (NOV) may be issued for failure to correct the deficiencies. Your project manager is available to answer questions and provide clarification to assist you in resolving all deficiencies to result in approval of your plan or amendment submittal.
If you have any questions concerning your DPCC/DCR plan, please contact Roy Soong your project manager at 609-575-1129, who is copied on this email.
Thank you and stay safe and healthy.
Paul Komosinsky, Chief
Bureau of Release Prevention Department of Environmental Protection P.O. Box 420, Mail Code 22-03D 401 East State Street Trenton, NJ 08625-0420"