Long Term Stewardship Efforts and Opportunities: Virginia - - PowerPoint PPT Presentation

Long Term Stewardship Efforts and Opportunities:

Virginia Department of Environmental Quality

Chris Evans, Director Tara Mason, Team Lead Office of Remediation Programs RCRA Corrective Action Program November 6, 2019

ORP Program Areas Office of Remediation Programs

• Federal Facilities
• DOD installations and NASA
• BRAC
• FUDS
• Superfund
• state lead, private, O&M
• RCRA CA
• Risk Assessment
• Site Assessment (PASI)
• ARARs
• UECAs
• Voluntary Remediation

Program (VRP)

• Brownfields
• Remedy Consent Orders

(RCO’s)

• Grants Management

(DSMOA, CORE, PPG, CA’s, RCO’s)

• Regulatory Analytics

RCRA Corrective Action Program - DEQ

• The RCRA Corrective Action Program ensures investigation and

cleanup of hazardous releases that pose an unacceptable risk at RCRA hazardous waste facilities and implemented in accordance with the Hazardous and Solid Waste Amendments of 1984 (HSWA) and accompany regulations.

• The Commonwealth of Virginia was authorized to administer

RCRA Corrective Action, effective September 29, 2000, and works in partnership with the U.S. Environmental Protection Agency (EPA.)

• DEQ and EPA have an excellent working relationship
• DEQ looks forward through the corrective action stage and

considers reuse and redevelopment

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RCRA Corrective Action Remedy Selection Process

Step 1 Step 2 Step 3

• Agree on Corrective Action Objectives
• Complete Corrective Measures Study (if needed)

Prepare Statement of Basis and Administrative Record Conduct Public Notice Issue Final Remedy Decision Corrective Measures Implementation Construct Final Remedy [Active Remediation or Institutional and/or Engineering Controls (ICs/ECs)

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LTS Introduction in Virginia

• Beginning with a FY14 pilot, Virginia has worked with EPA

Region 3 with the mutual goal of ensuring long term effectiveness of completed remedies

• Utilize field inspections and records review to evaluate

engineered controls (EC) and institutional controls (ICs) at RCRA Corrective Action sites

• Ensure controls are in place, maintained and operated as
• riginally designed, and local communities are aware of the

remedy in place

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Institutional Controls

• Environmental

covenants (UECA’s)

• Signage
• Leveraging local
• rdinances (gw use

restrictions)

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Engineering Controls

• Landfill cap
• Parking lots
• SSDS
• Vapor barriers
• Hydraulic control

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Implementation Strategy

• Target facilities were those with remedies older than 10 years
• There are more than 200 facilities in Region 3 with complete

remedies that include EC’s and/or IC’s

• Targets for LTS evaluation evaluated once every five years
• Similar to the frequency of the Five Year Review under CERCLA

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EPA and DEQ Collaboration

• Virginia began LTS evaluation program in 2014 with direction

and assistance from EPA Region 3

• As part of annual CA workshare agreement, DEQ and EPA

coordinate to determine specific sites to be evaluated

• Sites with oldest remedies are given first priority
• EPA Region 3 and DEQ both conduct LTS evaluations in

Virginia

• 5 to 10 LTS Evaluations conducted per year.
• In Virginia - 121 in the 2020 Universe; 63 sites included in LTS

evaluations

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LTS Goals

• Evaluate whether the ICs/ECs are functional and maintained,

and components of final remedy, including active systems, are effective and/or achieving goals

• Ensure that the protective controls selected and implemented

are:

• Maintained and operated in accordance with the selected remedy
• Remain effective
• Intact and undamaged

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LTS Goals - Continued

• Verify that the use of the property has conformed to any

applicable use restrictions

• Verify active remediation systems are functioning as designed

and properly maintained

• Determine whether any potential deficiencies exist and address

in a timely manner

• Ensure that the local community remains aware of the current

remedy status where necessary

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Summary of LTS Process in Virginia

• Conduct file/document

review

• Develop site-specific

inspection checklist based on remedy components (comprehensive list of IC’s/EC’s and final remedy requirements)

Summary of LTS Process in Virginia Continued

• Contact Facility, consultant (if

applicable), VDEQ regional office, and EPA to provide inspection notice and schedule

• Conduct site inspection (using

checklist) and review information with facility. Note any deficiencies

• Prepare LTS evaluation, report

documenting findings

• Follow up with facility to correct

noted deficiencies and incompatible uses.

LTS Mapping

• Verify or obtain mapping of the extents of ICs and ECs selected

as part of final CA remedy

• Ask facilities to provide geographic coordinates for IC/EC areas
• Use best efforts to acquire GIS/CAD from existing/prior owners

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LTS Mapping Continued

• Provide facility maps and

information to EPA Region 3 for their RCRA CA webpage

• Joel Hennessy @ EPA Region 3

manages this task.

LTS Evaluation Report

• Provide:
• Results of Evaluation to Facility, State Regional Offices, EPA
• Associated Mapping (if applicable)
• Completed Checklist

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LTS Evaluation Report

• When there is community

interest

• Work with facility to provide notice
• f LTS evaluation and update

community on site status and progress towards meeting program goals and performance standards

• Update EPA webpage

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LTS Evaluation Report

RCRAInfo database update:

• mapping information

for IC’s/EC’s

• RCRAInfo tracking

codes (Region 3 defined)

• CAS88P(X) – Pass
• CAS88N(X) – Need

Minor Maintenance

• CA88F(X) – Further

Evaluation Needed

• (X) – Evaluation Number

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Program Highlights

• Collaborative approach between EPA Region 3 and VDEQ
• LTS program is not considered a burden
• Strong customer service and helpfulness
• Flexibility of program used to achieve results and improvements
• Redevelopment of sites encouraged to benefit communities
• Improved coordination with compliance inspectors (avoid
• verlap) and other DEQ programs

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LTS Success Story: Virginia Emergency Fuel Storage

• Bulk fuel storage from 1973–1982

during energy crisis

• Owned and operated by VDEM
• 460 acres and 23, 2M gal tanks,

sludge pit, cosmoline dump

• Remedy selection 1997 – Removal

actions, IC’s/EC’s and MNA

• LTS Evaluation 2015 – EPA and

DEQ joint effort

• Yorktown EDA redevelopment

interest

• Legislation Action 2019-Budget

Amendment

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LTS Success Story: Virginia Emergency Fuel Storage

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Remedy Requirements

• Remove sludge pit and

cosmoline dump

• Implement MNA groundwater

monitoring

• Maintain security fence
• Post and maintain warning

signs

• Secure tanks/vaults
• Repair and maintain dam
• utlet structure
• Implement LUCs, deed

notification

LTS Results

• Sludge pit/cosmoline dump

closed to residential standards

• MNA GW monitoring

implemented, wells in disrepair

• Security fence in disrepair
• Posted warning signs worn and

faded

• Tanks/vaults cleaned and

secured

• Dam repaired and in good

condition

• LUCs/deed notification not

completed

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Path Forward - Importance and Timing

• Develop plan with stakeholders –

VDEM, DGS, Yorktown EDA

• Yorktown EDA – Strong interest

in redevelopment – Unmanned systems testing and solar farm

• GO Virginia – Funding for

acceptable redevelopment proposals

• Budget Amendment HB1700 –

Property transaction

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Budget Amendment HB1700

• Transfer 150 acres to VA Regional

Industrial Facility Authority (VRIFA)

• VRIFA - convey 150 acres to
• perator of 20 megawatt solar

facility

• Make available remaining acreage

to VRIFA - unmanned systems companies or companies locating to area

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LTS Evaluation - Highlights and Successes

• Identified missing elements of the remedy
• ICs/ECs established and plan for execution

developed

• Property suitable for transfer
• Results support economic redevelopment
• Able to meet required timeframe of HB 1700

budget amendment

• Achieved EPA’s national metric – Ready for

Anticipated Reuse

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Questions?

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