When land or groundwater is contaminated, and needs to be cleaned up, the perennial question asked by the remdiator responsible for the site is "how clean is clean?" Does the level of a contaminant have to be cleaned up to the natural background level? To a level that's safe for use as drinking water? To a higher level, based on the understanding that there is no groundwater, and the site will be paved over as a parking lot? Sometimes, the difference in acceptable residual contamination levels that will be left at the site depends on whether one is conducting a clean up of a release from an underground storage tank, or a groundwater remediation under RCRA.
The WV Department of Environmental Protection is working toward development of a "One Clean Up Program" that would coordinate and standardize the remediation requirements for many different environmental programs. It is trying to do this through a Memorandum of Agreement with EPA Region 3, but has run into some resistance. For those interested in the status of the State's One Clean Up Policy initiative, go to the Robinson & McElwee website and click on the link to the One Clean Up MOU . You will find a December 3, 2007 letter from former DEP Secretary Stephanie Timmermeyer to Donald Welsh, Region 3 Adminstrator, raising concerns about EPA's lack of support for West Virginia's attempt to coordinate remediation activities.
Caveat - Rob Lannan believes this letter is the most recent word on the OCUP, but he would be the person to talk to if you need to know anything up to date about the initiative.
Tuesday, January 20, 2009
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