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Environmental Remediation Rule Update and Implementation Plan

The HSRA rule change reflects updated scientific insights since 1994, aiming to enhance consistency, reduce contamination risks, and adjust cleanup standards. The RuleMaking Team and RRS changes offer flexibility for various site conditions, ensuring effective and comprehensive soil and groundwater protection. The guidance development process, including leaching and area averaging, further streamlines remediation procedures while addressing key challenges. Enroll in the Voluntary Remediation Program for a more adaptable compliance framework and expedited property readiness. Stay informed about upcoming rule changes and emerging environmental concerns, such as PFAS and PFOA.

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Environmental Remediation Rule Update and Implementation Plan

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  1. HSRA Rule Change • Reflect changes in scientific understanding since 1994 • Provide Consistency in Cleanup Standards • Reduce risk from contaminated sites • Correct values in the current lookup tables • Set easily calculated default cleanup standards (Type 1 and 3) • Provide additional flexibility for specific site conditions (Type 2 and 4)

  2. RuleMaking Team • Jeff Cown – Fmr. LPB Chief • Sarah Visser – LPB Assistant Chief • Beth Blalock – Fmr. LPB Asst Chief • Jason Metzger – RRP Manager • Shanna Alexander – Fmr. RAU Mgr. • Amy Potter, David Hayes, David Brownlee, Kevin Collins • Focused Stakeholder Group • Technical Risk Work Group

  3. General Changes • Minor changes and clarifications in: • Rule 391-3-19-.02 “Conventions”new abbreviations. • Rule 391-3-19-.04 “Release Notification” clarify the soil notification requirement exclusion for Brownfield properties. • Rule 391-3-19-.06 “Corrective Action” removal actions under the NCP may comply with Type 5 cleanup standards. • Rule 391-3-19-.08 “Property Notices”consistency with HSRA wording and to recognize continuing obligations.

  4. RRS Changes – Flexibility • Rule 391-3-19-.07 “Risk Reduction Standards” • All RRS provide adequate protection of HH&E • Use of soil area-averaging (site-specific) • Use of soil composite sampling (site-specific) • Provides for default non-residential groundwater standards • Use of covenants for Type 4 (non-residential) groundwater compliance • Consideration of anthropogenic sources and background studies • Accounts for migration risk in determining free-product removal requirements • Redefine default ‘surface’ soil as top one foot

  5. Direct Contact Calculations • Updated RAGS Equations 1, 2, 6, and 7 • Consistent with EPA Regional Screening Level equations • Incorporate age-dependent adjustment factors • Site-specific soil bioavailability in calculations • Allows use of chemical surrogates • Added language regarding toxicity and chemical-specific parameter hierarchy • Updated volatization and PEF equations • Incorporated subsurface exposure for non-resident • Replaced GALM with EPA Adult Lead Model

  6. LeachinG Calculations • Type 1/3 Leaching Calculations - Replaced GW *100 value with default partitioning equation • Appendix III, Table 4 • Type 2/4 - Use of existing groundwater data to show soils are protective

  7. Interim RRS Guidance

  8. Guidance Development • Demonstrating Completion of Soil Removal Actions • Environmental Covenant Guidance / Template • FAQs for Evaluating the Soil-to-Groundwater Pathway • Area Averaging Approach to Soil Compliance • Vapor Intrusion • Georgia Risk Assessment Guidance

  9. Leaching and Area Averaging • Drafts published 10/24/18 • Comment period extended • Comments from GIEC, GBA, Ashland, SCS • Leaching Status • Clarification/discussion meetings April/May • Revised draft late May • Area Averaging Status • Extensive comments • Clarification/discussion meetings May/June • Revised draft and potential stakeholder meeting

  10. VI technical advisory com. • Leverage External Technical Expertise • 2 EPD representatives and 8 external • Kick-off Meeting 1/22/19 • Monthly meetings for 6-month period • Sub-groups • Issue draft guidance document • Engage in public review process

  11. Voluntary Remediation Unit • Purpose: Administer the Voluntary Remediation Program (VRP) in an objective, consistent, and timely manner, in accordance with the VRP Act.

  12. Why enroll in the VRP? • More flexible framework to meet compliance obligations • Update compliance status • Make property “Brownfield Ready” • Make sure cleanup meets all Brownfield requirements (source material, use of controls) • Defer HSI listing (case-by-case basis) • Framework for EPD concurrence with investigation / cleanup that is not otherwise regulated

  13. VRP and the hazardous site inventory VRP Applications: % on HSI HSI Delistings in Last 3 Years

  14. On the Horizon • Finalize Leaching and Area Averaging Guidance • Vapor Intrusion Technical Advisory Committee • Georgia Risk Assessment Guidance • GEOS / LEMIR Enhancements • Notification digitization • Future Rule Changes • PFAS / PFOA?

  15. Jason Metzger • Response and Remediation • Program Manager • jmetzger@gaepd.org • 404-657-8606

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