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Response and Remediation Program
Hazardous Site Response Act Voluntary Remediation Program Act Georgia Brownfield Act Uniform Environmental Covenant Act CERCLA PA/SI Team
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EPD / LPB / RRP Jason Metzger David Brownlee Kevin Collins David Hayes
Program Manager David Brownlee RDU1 Unit Manager Kevin Collins RDU2 Unit Manager David Hayes RDU3 Unit Manager Shannon Ridley Brownfield Unit Mgr Four Hires and Four Promotions in FY16 Six Vacancies (incl. 2 new BF Positions)
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RRP Initiatives October 2014 HSRA Rule Change
Improved notification and delineation requirements Allowed delisting of Type 5 sites RQSM scoring deferment, Public notice, others Interactive HSI Map – July 2015 RQSM Toxicity Factor Update – April 2016 Digital Copies of Notifications Abandoned / Inactive Site Reviews / Prioritization GEOS / LEMIR / Scanning
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Georgia epd online system
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RRP Workgroups Vapor Intrusion Area Averaging
Fate & Transport Modeling Risk Assessment and Notification Concentration Review Abandoned Site Prioritization Model
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Hazardous Site Inventory
528 total HSI sites 275 active sites or sites needing enforcement 65 orphan sites 130 local gov. solid waste landfills 58 RCRA sites (hazardous waste) 106 Notifications received / 7 Listings (FY2016)
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Brownfield Applications
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Brownfield Application Types
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Brownfield Program Results
6,300 acres undergoing voluntary cleanup 3,800 acres certified in compliance with RRS 743 Applications / 410 final LOLs issued Over 810,000 tons of contaminated soil remediated Millions of private dollars invested in cleanup Reuse of blighted or underutilized properties Flexible – Many Tools in the Toolbox
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Voluntary Remediation Program Act
Became law June 1, 2009 Began accepting applications Jan. 1, 2010 $5000 Application Fee $75/hr EPD Review Rate Qualifying Property / Participant Checklist w/ Inv. and Remediation Plan
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Voluntary, timely, cost-effective
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VRP Applications 111 Applications received 104 Applications approved
4 Applications under review 6 Applications withdrawn / removed (3 subsequent to approval) 21 Properties delisted 60 Sites have Recorded UECs
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VRP Growth
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VRP Emphasis Item 5 of VRP Application Checklist
CSM, remediation plan, delineation standards, contaminants, exposure pathways, schedule. Not just for HSI sites Five-year schedule. Extension via Consent Order. EC required if controls used to certify compliance Free product removal to extent practicable
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VRP Lessons Learned Covenants difficult to obtain off-property
F&T modeling – work with EPD in advance Source material below water table VRP controls – future redevelopment / Brownfield Ecological impacts
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2013 WORKSHOP Feedback Delineate to Type 2 VI Unknowns
IMPLEMENTED CONSTRAINED Delineate to Type 2 Flexibility / Assistance w/ 5-yr schedule Reduce reporting / Focused comment ltrs Reduce FA Burden Unknown of Future EPD Costs VI Unknowns Downgradient Property issues LOL for impacted properties Separate VRP Unit Reduce EC burden
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VRP / Brownfield Success StORY
1995 Non-HSI due to fencing and no wells Some voluntary activity conducted Mid 2013 Enrolled in VRP 2014 7000+ cu yds soil removed Late 2014 EPD approves soil certification Mid 2015 EPD approves Brownfield App Construction begins on new develop. Late 2015 EPD concurs with F&T Model and EC No SW impacts. VI mitigation reqd. Mid 2016 EC Executed CSR submitted in September Late 2016 VRP Complete? Redevelopment Complete?
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FEEDback, Questions, comments
Response and Remediation Program Jason Metzger – Unit Managers David Brownlee - Kevin Collins – David Hayes - Shannon Ridley –
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