FREE Hot Topic with Gwen Zervas of NJDEP, Contaminated Site Remediation & Redevelopment, Division of Remediation Management on August 8, 2023.
As Director, her responsibilities include the oversight and management of Remediation Review (Inspection & Review, as well as Remedial Action Permits), Remediation Oversight (Case Management, Field Operations and UHOT) and Publicly Funded Response.
NJDEP’s Gwen Zervas Details How the Division of Remediation Management Is Re-Tooling Permits, Reviews and Communication
August 2023 CPES Hot-Topic Recap
When the New Jersey Department of Environmental Protection (NJDEP) promoted Gwen Zervas, P.E. to Director of the Division of Remediation Management last year, the move signaled that Trenton wanted fundamental change inside its largest site-cleanup bureau.
Speaking to more than 150 environmental professionals in CPES’s August Hot Topic session, Zervas outlined exactly what that change looks like: streamlined permit reviews, clearer lines of communication and a willingness to hand more responsibility—and trust—back to Licensed Site Remediation Professionals (LSRPs).
Who Is Gwen Zervas?
- Three decades at NJDEP. Zervas started at 12 years old, moderator Dr. George Berkowitz joked, but her résumé really does cover 30+ years in programs ranging from enforcement to publicly funded cleanups.
- Chemical engineer & educator. She holds a B.S. in Chemical Engineering (Catholic University) and an M.A. in Secondary Education (Arcadia University)—a combination that serves her well when translating regulatory nuance for practitioners.
- Division chief for 150 staff. Her portfolio spans remediation review, oversight, field operations, unregulated tank programs (UHOT), publicly funded response and Brownfield incentives.
What Does the Division of Remediation Management Do?
Zervas walked attendees through a rarely seen org chart:
| Element | Key Bureaus / Functions |
|---|---|
| Remediation Oversight | Bureau of Case Management (traditional & direct oversight) and Bureau of Field Operations (child-care reviews, UHOT, engineering-control inspections) |
| Publicly Funded Response | Bureau of Site Management (manages ~$20 million in annual state-funded projects) and Bureau of Environmental Measurements & Site Assessment (IEC response, potable-well & VI sampling, unknown-source work) |
| Remediation Review | Bureau of Inspection & Review (document inspections, REO reviews) and Bureau of Remedial Action Permitting (ground-water & soil RAPs, biennial certifications) |
| Office of Brownfield & Community Revitalization | Manages Brownfield Development Areas (new applications open September 2024) and reviews HDSRF grants and landfill-redevelopment projects |
The Pain Points Everyone Knows
Feedback from LSRPs, PRCRs and trade groups was candid:
- Permit backlogs—especially remedial-action permits (RAPs).
- Too many desk reviews, too few inspections.
- Extra work requested on “staff preference,” not rule.
- NOTDs (now “NOIs”) arriving long after submittal.
- Confusing routes for resolving technical disagreements.
The Remediation Process Improvement Initiative (RPII)
Zervas’s team and external stakeholders built a nine-point action plan; highlights include:
| Change | How It Works | Status |
|---|---|---|
| Five “prioritized” RAP types | Presumptive-remedy child-care cases, non-site-wide caps, simple IC renewals, etc. | 175 applications already flagged; expedited issuance underway |
| Notice of Incompleteness (NOI) replaces Technical Deficiency letters | 60-day single response window; supervisor co-signs; reviewers must answer promptly | Active |
| Effective Collaborative Communications Committee (ECCC) | DEP + LSRPs produced new flow charts, FAQs and January 2024 training; aim is “right-first-time” submissions | Materials posted on DEP website |
| Certification-based permits (in development) | For low-risk categories, DEP would rely on enhanced LSRP/PRCR certifications and skip in-depth review | Concept stage, legal review ongoing |
| Technical-Disagreement Panel | DEP considering reviving a three-member panel (with potential LSRP participation) to arbitrate disputes quickly | Workgroup convened August 2023 |
What Practitioners Should Do Now
- Use the new flow charts & FAQs. They spell out exactly what data and maps DEP expects in RAP and RAR packages.
- Expect one 60-day shot to fix NOI issues—and schedule drillers or labs accordingly.
- Contact the supervisor on the NOI immediately if you foresee a timing problem; extensions will be rare.
- Flag eligible projects for the five prioritized RAP categories; DEP is clearing that queue first.
- Watch for Brownfield Development Area (BDA) applications opening in September if your municipality needs targeted support.
Bigger Reforms on the Horizon
- General Permits & Permits-by-Certification. DEP’s land-use model may migrate to remediation, but not until a later rule package.
- Rule Proposal on RAPs. Expect focused permit definitions and streamlined triggers for “additional reviews” when the draft hits the New Jersey Register.
- One-Permit Paradigm. Soil, ground-water and VI components will be combined under a single RAP rather than separate media-specific permits.
Bottom Line
After years of backlog angst, NJDEP is publicly acknowledging its bottlenecks and inviting regulated parties into the fix. If the new NOI process sticks and certification-based permits become real, LSRPs could finally regain the legislative intent of SRRA: professional judgment backed by enforceable accountability, without endless document ping-pong.
Stay engaged—the department is still filling vacancies and shaping those workgroup recommendations. As Dr. Berkowitz reminded the audience: “It’s not going to happen overnight, but the willingness to listen and act is finally on the table.”
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