1. Regulated Material Review and Environmental Site Assessments
Categorical Exclusion Training Class

2. Categorical Exclusion Training Class
What’s the Purpose?
Identifying properties that pose a liability risk from an ownership perspective when acquiring new ROW. (Due Dilligence)
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
Categorical Exclusion Training Class

3. Categorical Exclusion Training Class
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)
Categorical Exclusion Training Class

4. ODOT
PROCEDURES

5. Regulated Materials Review
Documents
RMR Guidance Document
Appendix A - RMR Flowchart
Appendix B – RMR Review Form
Appendix C – Remote Enviornmental Property Form
Categorical Exclusion Training Class

6. Regulated Materials Review – Step 1
First step in the process.
Prerequisites:
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 ROW acquisitions or deep excavations, no further action required.
Categorical Exclusion Training Class

7. Regulated Materials Review – Step 2
FOR PERMANENT ROW ACQUISITIONS ONLY
Is the entire Property limited to one of the following land uses?
Forested Land or Cemetary
Occupied by a park or other recreational land
Used only for residential purposes
Used only for agricultural purposes
Previously undeveloped
If the project meets one of the above requirements, document this on Appendix A, Question 2. Upload the form to EnviroNet. Project is exempt from further evaluation.
Categorical Exclusion Training Class

8. Regulated Materials Review – Step 1
In addition to uploading the form, justification must be provided for using one of these off ramps.
Acceptable justifications include:
Aerial Photographs
Historic Photographs
Sanborn Maps
Other maps (OEPA, BUSTR, USEPA, etc.)
Categorical Exclusion Training Class

9. Regulated Materials Review – Step 3
Perform an Environmental Database Search (EDS)
ODOT has created a GIS
Commercial Database searches
After running the search, note the tables on page 8 of the RMR Guidance.
If there are no concerns of regulated materials within the search parameters, document this on the RMR Review form, questions 3 and 4, and upload to EnviroNet. No further evaluation required.
Categorical Exclusion Training Class

10. Regulated Materials Review – Step 3
If the EDS reveals a concern that is not contiguous or within the project limits, but is still within the search parameters, Appendix C is required.
This Appendix only applies to NPL, Solid Waste Facilities, CERCLIS/CERLIS NFRAP, RCRA CORRACTS, or RCRA TSD that was not contiguous and is located upgradient from the project.
Categorical Exclusion Training Class

11. Regulated Materials Review – Step 4
Create a Property Inventory. This is a list of all regulated material concerns for the project.
Classify each remaining property as “high-risk” or “low-risk”.
Categorical Exclusion Training Class

12. Regulated Materials Review – Next Steps
Phase I/Phase IIs
Outcome of RMR will determine if Phase I/Phase II is warranted.
Follow the current ODOT ESA Guidance.
Categorical Exclusion Training Class

13. Categorical Exclusion Training Class
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 12
Categorical Exclusion Training Class

14. Categorical Exclusion Training Class
Commitments
Negotiated actions with a regulatory agency
Identifies type of plan notes needed
Establishes waste management issues
Non-NEPA items are not included
Asbestos, heavy metals
Categorical Exclusion Training Class

15. CE
Document

16. Categorical Exclusion Training Class
ESA Tab - ENVIRONET
Categorical Exclusion Training Class

17. Categorical Exclusion Training Class
Remarks
Brief summary of each investigation
Include date studies were submitted to ODOT
Include coordination dates
Reference where documentation can be found
Emphasis is on the last ESA investigation
Single outcome for each ESA investigation which is documented in an IOC from ODOT-OES
OES, Districts, and consultants are same entity
Categorical Exclusion Training Class

18. Remarks DO NOT INCLUDE PLAN NOTES
Discuss any coordination with regulatory agencies and the resulting outcome/commitments
Unless coordination occurs with a regulatory agency, do not use the following words:
Coordination
Consultation
Concurrence
When a plan note is warranted, state the type of plan note and the location it applies to
DO NOT INCLUDE PLAN NOTES
Categorical Exclusion Training Class

19. Categorical Exclusion Training Class
Points to Remember
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
Categorical Exclusion Training Class

20. Categorical Exclusion Training Class
Contacts
Matt Perlik-Assistant Environmental Adminstrator
Larry Hoffman-Major Project Coordinator
Julie Denniss-ESA Specialist 3
Ross Irvine-Attorney
Categorical Exclusion Training Class