The voluntary remediation program
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The Voluntary Remediation Program. Progress In An Evolving Program September 2012. Keith Bentley Chief, Land Protection Branch Georgia EPD. Legislation effective June 1, 2009 Objective is to privatize and expedite cleanup End points the same as HSRA

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The voluntary remediation program

The Voluntary Remediation Program

Progress In An Evolving Program

September 2012

Keith Bentley

Chief, Land Protection Branch

Georgia EPD

Brief history of vrp

  • Legislation effective June 1, 2009

    • Objective is to privatize and expedite cleanup

    • End points the same as HSRA

    • Investigation and remediation supervised by PE/PG and paid by VRP applicant

  • No funding to establish program initially

  • VIRP Application and checklist developed in April 2010

  • Applications started to flow in 2010

  • No rules were promulgated

Brief History of VRP

Vrp vs hsra approach
VRP vs HSRA Approach

Prescriptive Approach

Flexible Approach

Vrp is n ot f or every site

  • VRP works when:

    • Groundwater contamination contained on “controlled” property

    • Receptor farther away from source

    • Participant is in compliance with rules, orders, etc.

  • VRP does not work when:

    • Site is on NPL list

    • Site is subject to EPA remediation order

    • Site has RCRA permit

    • Groundwater contamination is technically difficult to contain/remediate

    • Surface water or off site wells are impacted

VRP Is Not For Every Site

Criticisms of the vrp program

Criticisms of the VRP Program

Improvements to vrp program

  • Developing guidelines and examples for acceptable applications

  • Updates to FAQ on web site

  • Developing more consistent response to applications

  • Developing model consent order for converting HWMA orders to VRP

  • Improving response time- need complete application to approve quickly

Improvements to VRP Program

Challenges and evolving issues

  • Site vs. property questions applications

  • What happens if site leaves VRP before remediation complete?

  • What happens if remediation plan not successful?

  • Expanded use of environmental covenants

  • Financial Assurance issues

  • Evolving technical issues

    • Vapor intrusion assessment

    • Area averaging

    • Groundwater modeling

    • Surface water issues

  • What is the proper level of EPD review up front?

Challenges and Evolving Issues

Potential vrp pitfalls

  • VRP could be used as excuse to delay applications

  • Responsible party could “engineer shop” for the answer they want

  • VRP may not be a permanent solution if controls become inadequate

  • Less involvement of EPD upfront, may result in more uncertainty around acceptable end points- do not want surprises at the end

Potential VRP Pitfalls