1. Navigating the Voluntary Cleanup Program (VCP) Joseph Bell, P.G. Technical Specialist Voluntary Cleanup Program-Corrective Action Section

2. Purpose of Presentation Administrative requirements Technical requirements

3. Administrative Requirements Revised VCP Application form Revised VCP Agreement form Hard copy and electronic copy

4. Revised VCP Application Requests additional administrative details Improved instructions Requires legal description Requires site assessment Incomplete applications rejected PDF form more user-friendly

5. Revised VCP Agreement Requests additional administrative details Instructions now provided Requires billing party signature Includes modification warning PDF form more user-friendly * Picture courtesy of Association of Train Operating Companies

6. Technical Requirements Knowledge of site history Chemicals of concern Source area characterization Environmental media Applicable regulations * Picture courtesy of Neil Greenberg/Freshwater Railway

7. Knowledge of Site Operational History Key controlling factor Inverse proportionality (mostly)

8. Chemicals of Concern (1) Definition Limited by most factors Controls media sampling Why consider it second?

9. Chemicals of Concern (2) Low threshold values for metals Background concentrations Exceedance may not = release Environmental professional’s role

10. Chemicals of Concern (3) Fill material is not = to native soil Some may be treated similarly Solid waste exemption Non-inert fill

11. Chemicals of Concern (4) In-use consumer products Address when “discarded” Determination is site-specific

12. Source Area Characterization Operational history driven scope Chemical of concern analyses Sampling of environmental media Previously closed areas/units

13. Environmental Media Sampling of soil, water, air and other media Chemical fate and transport All Appropriate Inquiry

14. Applicable Regulations Know Chapter 334 exclusions and exemptions Know Chapter 334 definitions Know cleanup rule closure standards and health-protective level development Know Chapter 333 allowances Know Chapter 333 overlays Fulfill cleanup rule requirements for investigation and response

15. Question and Answer Session Email: Joseph.Bell@tceq.texas.gov Phone: 512-239-6753