Regulated Materials Review Regulated Materials Review Categorical Exclusion Training Class – Presented by the Office of Environmental Services

What’s the Purpose? Identifying properties that pose a liability risk from an ownership perspective when acquiring new ROW (Due Diligence) Identifying properties that pose a materials management concern during construction (Due Care) Based on Rachel Carson’s book Silent Spring and three major environmental disasters – Cuyahoga River on fire, Times Beach and Love Canal [2] Categorical Exclusion Training Class – Presented by the Office of Environmental Services

Federal Laws CERCLA Comprehensive Environmental Response, Compensation, and Liability Act of 1980 SARA Superfund Amendments and Reauthorization Act RCRA Resource Conservation and Recovery Act Hazardous and Solid Waste Amendments of 1984 Amended RCRA to establish land bans and regulate Underground Storage Tanks (USTs) [3] Categorical Exclusion Training Class – Presented by the Office of Environmental Services

ODOT PROCEDURES

Regulated Materials Review Documents ODOT Regulated Materials Review Manual RMR Screening/PILUT Form RMR Flowchart (Page 68 of RMR Manual) RMR Assessment Form RMR Investigation Form RMR Decision Summary/Cost Form [5] Categorical Exclusion Training Class – Presented by the Office of Environmental Services

Regulated Materials Review – Step 1 RMR Screening Prerequisites: Known, or generally known project limits Known, if any, ROW acquisitions Known, if any, Deep Excavations (Greater than six feet below surface grade) FIRST OFF RAMP If Project does not involve permanent ROW acquisitions or deep excavations, the User completes the General Information and Section 1 of the RMR Screening/PILUT Form, uploads the completed form to ODOT’s EnviroNet as the RMR submittal documentation, and informs the DEC of the findings [6] Categorical Exclusion Training Class – Presented by the Office of Environmental Services

Regulated Materials Review – Step 2 PERFORM ODOT GIS SEARCH http://gis3.dot.state.oh.us/rmr/ Generally similar to the commercial searches (EDR, etc.) Will show CERCLA, RCRA, Landfill, BUSTR, all known databases we could get our hands on [7] Categorical Exclusion Training Class – Presented by the Office of Environmental Services

Regulated Materials Review – Step 2 [8] Categorical Exclusion Training Class – Presented by the Office of Environmental Services

Regulated Materials Review – Step 3 PILUT FORM *NOTE* This section is currently being reworked based on comments Form is used to document properties that contain RM based on the GIS viewer and high risk properties Gas stations, Dry Cleaners, Industrial sites, etc. All C2 or higher projects must have VPR (Visual Property Reconnaissance) ODOT users may do this during site visits Consultants may be tasked with taking photos Historic Aerial photos also required [9] Categorical Exclusion Training Class – Presented by the Office of Environmental Services

Regulated Materials Review – Step 3 [10] Categorical Exclusion Training Class – Presented by the Office of Environmental Services

Regulated Materials Review – Step 3.5 PILUT FORM (Continued) Remote Properties ODOT is concerned about nearby properties that have the potential for contaminant migration. High/Low Risk Properties More likely to find potential concerns. Use the flowchart to determine if additional studies are warranted. [11] Categorical Exclusion Training Class – Presented by the Office of Environmental Services

Regulated Materials Review – Step 4 RMR Screening Form Use the information from the PILUT to complete the form [12] Categorical Exclusion Training Class – Presented by the Office of Environmental Services

Regulated Materials Review – Next Steps RMR Assessment = ATSM Phase I RMR Investigation = ASTM Phase II Consult RMR Guidance for more details [13] Categorical Exclusion Training Class – Presented by the Office of Environmental Services

Regulated Materials Review – DSCF Summary form used to document potential costs Formulas are in Section 7.7 of RMR Guidance Ex. Average costs associated with hauling solid wastes to a landfill Used by ODOT project managers (potentially non- environmental people) to determine project costs/impacts [14] Categorical Exclusion Training Class – Presented by the Office of Environmental Services

Regulated Materials Review – Plan Notes Very important outcome Instructions for contractors on how to deal with regulated materials Site specific health and safety plans (SSHPs) Transport vehicles Sampling Handling & Disposal [15] Categorical Exclusion Training Class – Presented by the Office of Environmental Services

Non-NEPA Issues Non-NEPA items not addressed in the environmental document Asbestos on bridges or in buildings Heavy metals in bridge or building paint [16] Categorical Exclusion Training Class – Presented by the Office of Environmental Services

CE Document

ESA Tab - EnviroNet [18] Categorical Exclusion Training Class – Presented by the Office of Environmental Services

Remarks Will be updated with the next EnviroNet update Will be updated with the next EnviroNet update For now, use best judgement when completing [19] Categorical Exclusion Training Class – Presented by the Office of Environmental Services

Points to Remember OES provides recommendations OES provides recommendations Based on results of studies OES is not a coordinating agency Consultant prepared reports are ODOT documents Coordination with OES is part of the collaborative effort between ODOT and the consultant [20] Categorical Exclusion Training Class – Presented by the Office of Environmental Services

Contacts Matt Perlik - Assistant Environmental Adminstrator Matt Perlik - Assistant Environmental Adminstrator 614-466-1937 or Matt.Perlik@dot.ohio.gov Larry Hoffman - Major Project Coordinator 614-466-6439 or Larry.Hoffman@dot.ohio.gov Julie Denniss - ESA Specialist 3 614-466-7942 or Juliet.Denniss@dot.ohio.gov Ross Irvine - Attorney 614-387-0268 or Ross.Irvine@dot.ohio.gov [21] Categorical Exclusion Training Class – Presented by the Office of Environmental Services