Connecticuts Remediation Standard Regulations

1
Connecticuts Remediation Standard Regulations

• Brownfields and Beyond
• Hot Topics in Environmental Health Conference
• March 29, 2007

2
To clean up or not to clean up.that is the
question. (apologies to Shakespeare)
Is this a problem?
What should be done?
Where can I get help?
Is this clean?
3
CT Remediation Standard Regulations Tools for
Success

• Detailed guidance, requirements and standards
  that can be used at any site
• Determine Need for Remediation
• Protect Human Health and the Environment

4
Environmental Protection within the RSRs
5
Risk Based Goals
Exposure Potential for
Effect
Risk
6
RSR Approach to Remediation

• Media based approach
• Remediation Goals and Requirements
• Background
• Risk-based
• Technical Considerations
• Site Specific Adjustments

7
Exposure

• Current RSRs
• Residential
• Industrial-Commercial
• Under Consideration
• Recreational Exposure Scenario
• Update Approach for Children
• Fish Consumption Exposures

8
Potential for Effects

• Toxicity Values
• Cancer and Noncancer Endpoints
• Under Consideration
• Update Toxicity Values
• Update Approach for Children

9
Considering Children.

• Greater exposure per body weight compared to
  adults
• Sensitive to mutagenic chemicals
• Biological response to other chemicals different
  than adults
• Propose changes to risk-based criteria to address
  child-specific issues

10
Soil

• Direct Contact
• Incidental ingestion of soil
• Exposure Scenarios
• Residential
• Industrial Commercial
• Recreational - Under Consideration

11
Soil

• Pollutant Mobility Criteria
• Will contaminants move from soil to Ground water?
• Exposure Scenario
• Drinking Water
• Under Consideration
• Future Drinking Water Resources
• Consideration of Volatilization and Surface Water
  Exposures

12
Ground Water

• Ground Water Protection Criteria
• Drinking Water Protection
• Basis
• Federal MCL
• State Action Level
• Risk-based Criteria

13
Ground Water

• Volatilization Criteria
• Will chemicals move from ground water or soil
  into the air space within a building?
• Applies to Volatile Chemicals
• Updated environmental model for chemical transport

14
Sediment

• Existing RSRs
• Case by Case
• Under Consideration
• Explicit Inclusion of Sediment as an Exposure
  Media
• Risk-based Criteria for Direct Contact and for
  Bioaccumulation of Contaminants through the Food
  Chain

15
Remediation

• Practical Considerations

16
Who do the RSRs apply to?

• Facilities that generate or handle hazardous
  materials when
• the property is being transferred
• is under order to remediate
• voluntarily enters remediation program
• Common Examples
• Industrial Facilities
• Gas Stations/Vehicle Repair Stations
• Dry Cleaners

17
Who dont the RSRs apply to?

• Facilities that generate or handle hazardous
  materials when the property is not being
  transferred, under order or voluntarily entered
  into a remediation program
• Facilities/locations at which pollution may
  exist, but the site does not meet the regulatory
  requirements for generating or receiving
  hazardous materials or type of facility and an
  order to remediate has not been issued

18
Brownfields

• Property where the expansion, redevelopment or
  reuse may be complicated by the presence or
  potential presence of a hazardous substance,
  pollutant, or contaminant
• Typically subject to the RSRs

19
Pfizer Global Development Facility
20
School Construction Site

• Construction of a new school
• Site not subject to RSRs
• Material brought on site during construction
• Reclaimed miscellaneous aggregate meeting DOT
  specifications for sub-base material

21
School Construction Site

• Problem?

Yes ! !

• DEP Response Restrict use of Material based on
  exceedance of DEC criteria for PAHs

22
Use of Fill Materials

• Not regulated under RSRs if site is not involved
  in an RSR remediation
• On the local level
• Ask questions!!!
• Know the source of the material
• Did anyone analyze for pollutants?
• Use RSR criteria to determine if chemical quality
  is suitable for site
• Re-use of polluted soil sediments is addressed
  under DEP solid waste regulations. DEP is
  developing General Permit to address this issue.

23
Environmental Land Use Restrictions

• Possible outcome at an RSR remediation site
• ELUR
• Binding agreement between property owner and
  CTDEP
• Recorded on municipal land records
• Restricts use or activities at a property in
  order to limit exposure of people to pollutants
  remaining at a site

24
Environmental Land Use Restrictions

• On the local level
• Check the land use records before issuing any
  permits
• Typical conditions
• Do not dig/disturb an area
• Site use to be restricted to Industrial/Commercial
  Use
• Contact DEP if you have questions about sites
  with ELURs in your town

25
Re-Purposing a Site

• Scenario site is to be developed with a new
  land use.
• Sites subject to RSRs future site use will be
  included in remediation plans
• Sites not subject to RSRs RSRs can provide
  benchmarks to evaluate potential for risks

26
Re-Purposing a Site

• On the local level
• Ask questions!!!
• Understand past and future activities for the
  site
• Did anyone analyze for pollutants?
• Use RSR criteria to determine if chemical quality
  is suitable for site
• Example
• Farmland conversion to Residential Development

27
Volatilization

• Scenario Groundwater plume containing volatile
  compounds travels under a building
• Possible inhalation exposure for people in
  building due to migration of chemicals from
  groundwater or soil beneath the building into the
  air space of the building

28
Volatilization
Groundwater Plume Containing Volatile Chemicals
29
Addressing Volatilization

• Sites subject to RSRs volatilization pathway
  will be addressed. At other sites RSRs can
  provide benchmarks to evaluate potential for
  risks
• Volatilization Criteria for Groundwater or Soil
  Vapor in RSRs
• Residential or Industrial Commercial Exposure
  Scenarios

30
Addressing Volatilization

• Indoor Air Monitoring is not recommended
• Migration pathways into building can change over
  time
• Exposure within the building can change over time
• Data difficult to interpret with respect to other
  indoor air sources
• Possible detection limit issues
• RSR Volatilization Criteria provide a
  conservative but realistic evaluation of risks
  from potential migration of volatile chemicals

31
Drinking Water Resources

• DEP has resources to address chemical
  contamination of potable water wells resulting
  from human activities
• Bacterial contamination associated with septic
  systems, etc. should be addressed on the local
  level

32
Drinking Water Resources

• On the local level
• If you suspect a release that may have polluted a
  well
• Identify potential sources
• Can analyze samples using town account at DPH
  laboratory
• Can contact DEP for assistance or questions

33
Sediment

• Scenario Site related activities have affected
  sediments in nearby waterbody
• Sites subject to RSRs
• Currently addressed on a case by case basis
• Future revisions may include more detail on
  sediment remediation
• Sites not subject to RSRs
• Use Soil DEC values to screen data
• Consider potential fish consumption issues

34
Sediment Site
Facility
Contamination
35
Sediment

• On the local level
• If you suspect a release that may have polluted
  sediments
• Identify potential sources
• Identify potential exposure pathways
• Direct contact
• Fish consumption
• Subsistence fishing populations
• Can contact DEP for assistance or questions

36
RSRs Brownfields Beyond

• RSRs provide risk-based and practical approaches
  to identifying the need for and remediating
  Brownfield sites and many other sites.
• RSRs can inform evaluations and decisions at
  sites that may not be required through the
  regulations to follow the requirements of the RSR

37
DEP Remediation Program
North Central District Jan Czeczotka 860 424-3784
Eastern District Bill Warzecha 860 424-3776
North West District Patricia DeRosa 860 424-3501
Central District David Rinquist 860 424-3573
Southwest District Douglas Zimmerman 860 424-3800
South Central District Tom Riscassi 860 424-3781
38
Brownfield Assistance

• Financial Assistance Programs for Buisnesses,
  municipalities, non-profits and housing
• Office of Brownfield Remediation and
  Development Assistance
• (Department of Ecomonic and Community
  Development)
• 860 270-8095
• www.ctbrownfields.com

39
Contact Information

• Traci Iott
• Supervising Environmental Analyst
• CT DEP
• Bureau of Water Protection Land Reuse
• Planning Standards Division
• 860 424-3082
• traci.iott_at_po.state.ct.us

40
(No Transcript)