The Voluntary Remediation Program自愿整治方案.pptVIP

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 * VRP vs HSRA Approach Conventional HSRA Approach VRP Approach EPD issues call for CAP Responsible party (RP) submits investigation plan EPD reviews/comments Investigation plan revised and initiated EPD approves site delineation RP submits remediation plan to meet HSRA clean up standards EPD reviews/comments Remediation plan revised and initiated RP submits Compliance Status Report when remediation complete EPD approves CSR and removes site from HSI RP develops general investigation remediation approach Application for entry into VRP submitted to EPD EPD approves general approach with comments Delineation and clean up criteria generally less stringent RP submits semi-annual progress reports RP submits CSR when remediation complete EPD approves CSR/delists site * Prescriptive Approach Flexible Approach VRP Is Not For 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 * A Look At The Numbers * Current Status of Unapproved Applications * Criticisms of the VRP Program Too long to get in program Too many “conditions” Too much management by EPD of details “ It feels like HSRA.” * Improvements to VRP Program Developing guidelines