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

2. 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

3. 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

4. ODOT
PROCEDURES

5. 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

6. 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

7. Regulated Materials Review – Step 2
PERFORM ODOT GIS SEARCH
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

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

9. 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

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

11. 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

12. 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

13. 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

14. 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

15. 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

16. 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

17. CE
Document

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

19. 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

20. 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

21. Contacts Matt Perlik - Assistant Environmental Adminstrator
Matt Perlik - Assistant Environmental Adminstrator or
Larry Hoffman - Major Project Coordinator or
Julie Denniss - ESA Specialist 3 or
Ross Irvine - Attorney or
[21] Categorical Exclusion Training Class – Presented by the Office of Environmental Services