Alyssa Sellwood, the Remediation and Redevelopment Program’s vapor intrusion and dry-cleaning team leader, will present our Issues & Trends conference call in September. Alyssa will discuss vapor intrusion sampling, including a discussion of action triggers, mitigation and long-term monitoring.
The RR Program seeks your input on a significantly revised document titled, RR-800, Addressing Vapor Intrusion at Remediation & Redevelopment Sites in Wisconsin. The revisions to RR-800 include: updates from ITRC’s and USPEA’s vapor guidance; additional details on required deliverables; expectations for outreach; clarification on preemptive mitigation; and a significantly expanded discussion on vapor mitigation (design options, performance verifications, long-term operation and maintenance, and continuing obligations).
Alyssa Sellwood, a Hydrogeologist with the Remediation and Redevelopment Program and the leader of the dry cleaning and vapor intrusion teams, will present the next Issues & Trends training event on Wednesday, August 9, at noon. No pre-registration is required.
Sellwood’s presentation will be an overview of forthcoming additions and modifications to the RR Program’s existing guidance on vapor intrusion – RR 800 – Addressing Vapor Intrusion at Remediation and Redevelopment Sites in Wisconsin. We originally published the guidance in 2010, but revisions are necessary as knowledge and understanding of vapor intrusion has grown. The guidance is being readied for public comment and includes such updates as commissioning and inspecting vapor mitigation systems, mitigating vapor risk in new construction, and evaluating and addressing potential vapor risk in large commercial and industrial buildings.
As part of the Remediation and Redevelopment Program’s continuing outreach to its customers, the program wants to remind consultants and responsible parties that:
(1) Wis. Admin. Code § NR 700 rule series (hereafter “NR 700”) specifies the technical reports or documents that must be submitted to the Department of Natural Resources (DNR) regardless of whether the responsible party is requesting a fee review or not; and
(2) Those documents are to be prepared by or under the supervision of a professional engineer, hydrogeologist or scientist as those terms are specifically defined in NR 712.03. This rule chapter requires: (1) appropriate qualifications of the consultant; (2) signatures; and (3) certification language to be included with the appropriate NR 700 submittals.
Semi-annual reporting for the period of January 1, 2017 to June 30, 2017 is due August 8, 2017. Semi-annual reporting is required of responsible parties (RPs) for all “open” sites, including those sites the DNR formerly classified as “conditionally closed,” in the BRRTS online database. Consultants may submit these reports on behalf of the RPs.
An email from the DNR with your unique report identification number will go out on July 7, 2017. If you do not receive an email, you can request a number by submitting the Report ID Request Form. The Report ID number you will receive uniquely identifies the activity for which you wish to report, the reporting period, and verifies the person using the ID is authorized to submit the report. If you have any questions, please contact Tim Zeichert at (608) 266-5788.
This guidance document introduces the modified residual contaminant level (RCL) spreadsheet that allows for an alternative method of calculating non-industrial direct contact RCLs for seven carcinogenic polycyclic aromatic hydrocarbons (cPAHs). The modifications are based on a reassessment of the risk posed by cPAHs by the Wisconsin Department of Health Services.
The modified spreadsheet assesses these cPAHs exclusively on cumulative risk and does not assess their individual compound-specific risk. Use of this spreadsheet complies with the requirements of Wis. Admin. § NR 722.11 for developing alternate standards when meeting the RCLs in Wis. Admin. § NR 720 is not practicable.
The comment period will be open through May 31, 2017. This document can be reviewed on the Department’s public input web page, and comments can be submitted to Paul Grittner.
The RR Program recently added four, new online tools to our vapor intrusion (VI) prevention web page to assist environmental professionals as they prepare VI assessments or plan for outreach on a site impacted by vapor intrusion.
Vapor Intrusion 101 video uses a hand drawn animation technique to introduce the concept of vapor intrusion. It is intended for use in conjunction with factsheets and personal communication when talking with a property owner who is unfamiliar with vapor intrusion.
RR-067: Vapor Intrusion Investigation – Information Sheet for Neighbors can be given to an off-site property owner when access is needed to investigate vapor intrusion on their property. This factsheet provides an introduction to environmental investigations, identifies the parties involved, and clarifies who the property owner can contact with questions.
The fourth new tool is on the same web page, under the “screening levels” tab:
The Remediation and Redevelopment (RR) Program is taking steps toward making site file records available electronically via BRRTS on the Web (BOTW).
To assist with this goal, the program encourages consultants to submit NR 700 milestone documents via email to a regional email address and to the project manager instead of submitting a CD or DVD. The RR Program reminds consultants that both electronic and hard copy submittals are required (as well as the fee, if applicable) before submittals are considered “received” by the department. Documents can either be provided as an email attachment or uploaded to the RR Program’s FTP site (if the files are over 12 megabytes). NR 700.11(3g) allows the department to issue this blanket pre-approval for email submittals.
The RR Program recently finalized four new guidance documents regarding the management of contaminated soil and other waste materials excavated at sites or facilities in locations other than a licensed landfill.
This guidance is the culmination of several years of discussion between the RR Program and external stakeholders, including more than 20 individuals who served on the program’s Contaminated Materials Management Advisory Group and other interested parties who also participated in meetings. The group was formed in May 2015 and met more than a dozen times to provide input on issues related to materials management. The RR Program thanks those who participated for sharing their time and perspective.
These new guidance documents include:
RR-060, Management of Contaminated Soil and Other Solid Wastes Wis. Admin. Code §§ NR 718.12 and NR 718.15, provides a general overview of the exemptions available under NR 718 for managing excavated material, a description of when these exemptions may apply, and a summary of the application process and requirements.
RR-071, NR 718.12 Sample Results Notification, provides a cover page that may be used when submitting laboratory reports to the DNR to satisfy the requirements of NR 718.12(1)(e)(4).
RR-072, Recommended Format for Exemption Request Wis. Admin Code NR 718.12 or NR 718.15, provides a consistent format to demonstrate that the proposed management of solid waste material, as a remedial or interim action, qualifies for a NR 718.12 or NR 718.15 exemption and to request written approval of the exemption from the DNR.
RR-073, Request for Exemption from Location Criteria of NR 718.12(1)(c) for Managing Soil as an Immediate Action, provides a format to request that the DNR allow management of soil, as an immediate action, in an area that will not comply with the location criteria listed in NR 718.12(1)(c).
The Prepared Workbook for Brownfields and Land Revitalization from the Council of Development Finance Agencies (CDFA) is a risk management framework for evaluating various actions that a local government might take to bring about a desired reuse at contaminated properties that it does not currently own.
The workbook is available now from the CDFA and is a good resource for municipal officials who are looking to clean up and redevelop contaminated property.