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 • UECAs • DOD installations and NASA • Voluntary Remediation Program (VRP) • BRAC • Brownfields • FUDS • Superfund • Remedy Consent Orders (RCO’s) • state lead, private, O&M • Grants Management • RCRA CA (DSMOA, CORE, PPG, • Risk Assessment CA’s, RCO’s) • Site Assessment (PASI) • Regulatory Analytics • ARARs

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 4

RCRA Corrective Action Remedy Selection Process • Agree on Corrective Action Objectives • Complete Corrective Measures Study (if needed) Step 1 Prepare Statement of Basis and Administrative Record Conduct Public Notice Step 2 Issue Final Remedy Decision Corrective Measures Implementation Construct Final Remedy [Active Remediation or Step 3 Institutional and/or Engineering Controls (ICs/ECs) 5

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 originally designed, and local communities are aware of the remedy in place 6

Institutional Controls • Environmental covenants (UECA’s) • Signage • Leveraging local ordinances (gw use restrictions) 7

Engineering Controls • Landfill cap • Parking lots • SSDS • Vapor barriers • Hydraulic control 8

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 9

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 10

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 11

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 12

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 15

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 17

LTS Evaluation Report • When there is community interest • Work with facility to provide notice of LTS evaluation and update community on site status and progress towards meeting program goals and performance standards • Update EPA webpage 18

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 19

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 overlap) and other DEQ programs 20

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 21

LTS Success Story: Virginia Emergency Fuel Storage 22

Remedy Requirements LTS Results • Sludge pit/cosmoline dump • Remove sludge pit and closed to residential standards cosmoline dump • MNA GW monitoring • Implement MNA groundwater implemented, wells in disrepair monitoring • Security fence in disrepair • Maintain security fence • Posted warning signs worn and • Post and maintain warning faded signs • Tanks/vaults cleaned and • Secure tanks/vaults secured • Repair and maintain dam • Dam repaired and in good outlet structure condition • Implement LUCs, deed • LUCs/deed notification not notification completed 23

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 24

Budget Amendment HB1700 • Transfer 150 acres to VA Regional Industrial Facility Authority (VRIFA) • VRIFA - convey 150 acres to operator of 20 megawatt solar facility • Make available remaining acreage to VRIFA - unmanned systems companies or companies locating to area 25

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 26

Questions? 27