IPTD-71
NJDEP SRRA Implementation - Remedial Action Permit Application Service (Allowing establishment of institutional/engineering controls via RSP)
Description
SRP Reform- Modify NJEMS and RSP to allow LSRPs to submit Remedial Action Permit applications and other Institutional/engineering controls (including Classification Exception Areas [CEAs] and Deed Notices).
Project Justification
Remedial Action Permits are the final piece of the LSRP Remedial Process which has not been migrated into an RSP Service
LSRPs are required to submit RAP applications, however, many Remedial Applications are incomplete, delaying processing for many cases. . For LSRPs this service falls between the existing RAR and RAO services. Many RAOs can not be issued until the Remedial Action Permit is issued, so the service will help insure that the process is improved and review times shortened. As well as allowing LSRPs to have the final step for the remedial process as an online submission.
LSRPs are required to submit RAP applications, however, many Remedial Applications are incomplete, delaying processing for many cases. . For LSRPs this service falls between the existing RAR and RAO services. Many RAOs can not be issued until the Remedial Action Permit is issued, so the service will help insure that the process is improved and review times shortened. As well as allowing LSRPs to have the final step for the remedial process as an online submission.
Linked work items
Activity
Show:
May 13, 2025 - Mtg with Jim Bridgewater, Michele Zola, Joe Eaker, Ian Fisher, Mike Gaudio.
Jim is signing the change order for the minimum requirements for RAP rule to issue permits on day 1. chedule includes Final JAD Design by 6/30/25. We may bifurcate at that point.
JAS/Design Work Plan #195 signed 3/18/2025, with JADs scheduled for 4/1/2025-4/3/2025. Note, this work plan covers both
11/26/24 New RAP rules & process Agenda:
Need now:
revised forms (all) & permit template for IANA
Prerequisites for combining permits
Start process of prepping new Profiles & requirement
Establish general schedule
Confirm rule effective date is 10/21/25, and that this date will not change
How do changes to PEGA schedule affect this project
When can BRAP complete the above "need now" items
Set up ongoing update meetings (and determine who needs to be involved in each meeting)
Set general update meeting dates
Set up ongoing meetings to flesh out permit templates (and forms, once samples provide)
Set up ongoing meetings to re-write requirements & profiles
Minimum viable Product (what do we need day 1- 10/21/25)
Ability to create new subject item - permit types
Ability to merge permits subject items into single activity (in both NJEMS & PEGA)
Ability to capture all necessary data (pay specific attention to new indoor air notification)
Modifications to billing proc to handle new types of permits & data structure
Ability to generate permit document
Profiles & requirements will need to be completely rewritten!
How are profiles going to work?
Items that require CGI involvement, but could be built Now (will be needed regardless of final rule proposal)
Service to submit a CEA at during RI or RA submission
Get subject item functionality (will be needed for combining RAPS)
increase size limit of MTB_PARAM_GOAL_TYPE_GOAL_XREF.CLEANUP_GOAL_NUMBER and/or make varchar to allow for no numeric standards.
10/3/2024 Pre-Meeting Notes. Ian Fisher, Scott Tyrrell, Joe Eaker
What will need to be built-
Online services For RAP
Submit a CEA
Submit a new Remedial action Permit
Mod/transfer an existing remedial action Permit
Terminate a Remedial action permit
Submit a biennial certification
DEED notice & CEA lift service
Changes needed to NJEMS to improve RAP processing/data quality
-need anchor date to memorialize start date of permit as it moves through multiple activities (will allow multiple and bundled permits to maintain the same billing & submittal cycle, independent of when permit issued)
-need 'get subject item' functionality so SRPPMT document can be created as soon as application comes in (will alleviate status issues caused by having multiple control docs)
-ongoing clock issues - need more status to be recognized by the clock.
May need CGI assistance created letterbuilder doc that can handle "bundled' permit scenario. (NOTE: prior discussions appear to indicate we can do this using requirements)
We still need a firm idea of what new permit types (combined, VI-IA & type 1 througb 5) will look like.
Example of possibly problematic 'weeds' issue - sites get subdivided- in these case one permit at one site /pi often gets broken up into many permits across multiple sites/pis
Other issues/complicating factors:
Proposed rule changes shift & re-number certain requirements - this will necessitate a full reload of the requirements library
Discussions will be needed on fee structure……………….
Which components can change each year (and therefore need to be unique assessments
Rule Proposal will be in the October 21, 2024 Register. Schedule meeting with CSRR and DOIT.
Combined permits 1-9-23 meeting
1 - permit Doc with logic that brings in requirements for each permit type and "nests them together" - complicated
2- one permit Doc where each permit type is separate section (may be slightly less complicated)
2- 3 individual permit docs and combine in PDF bundler with common cover letter (easiest).
4- can we handle from requirements side where user picks profile for soil; GW; IA,
; SW & GW; soil & IA; GW & IA; S,GW & IA.
BIS to schedule internal JADs in August/September. BIS, BRAP, BCAIN, BGWPA
DOIT and program meeting 7/6/23 - discussion of rule with proposal expected to be final Jan-Feb '24 (end of comment period) and effective date at end of '24. Program was asked to do analysis of the draft/proposed rule for system changes, which can be done in-house (new Activities, billing, etc.) and which changes require a build. If that is ready at time of rule clarity, we should have time (about 9 months) to design and build what is needed. Jim proposes to engage CGI in Nov '23 roughly when proposal is expected. Mike McCormack to lead for DOIT. More bandwidth expected in the fall. Program lead on pre-JAD efforts is not yet named, but Scott T. and/or Joe E. will be needed, perhaps with new staff to learn as they go. Vicki is a potential as return hourly.
RAP Permit Processing--Implementation Plans.xlsx
The results from the Lean Sigm Six Project from Jessica Sponaugle is resulting in changes to the current RAP process and recommends development of an on-line service to accept the permit applications and ingest that data into NJEMS/PEGA
There is a Lean Sigma Six Project looking at streamlining RAP processing. Jessica Sponaugle is spearheading this project. Results of the Lean Sigma Six Project will be added upon completion.