IEC Technical Guidance Training

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IEC Specialized Direction Preparing. Andrew Locales, Mark Fisher, John Boyer September 2011. What are we going to cover?. Diagram of IEC Idea IEC Administrative Procedure IEC Assets Vapor Interruption Review Contextual analyses IEC Program Status. 2. IEC Idea Review. Andrew Destinations, NJDEP.

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IEC Technical Guidance Training Andrew Sites, Mark Fisher, John Boyer September 2011

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What are we going to cover? Review of IEC Concept IEC Regulatory Process IEC Resources Vapor Intrusion Overview Case Studies IEC Program Status 2

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IEC Concept Overview Andrew Sites, NJDEP

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IEC Guidance Committee Members Christopher Dailey, GEI Consultants Jeffrey Farrell, PS&S Mark Fisher, The ELM Group, Inc., LSRPA Bob Gallagher, DEP Martin Hilfinger, Cumberland Gulf Kathleen Murray, TERMS Environmental Rocky Richards, DEP Dan Stecchini, Groundwater & Environmental Services Andrew Sites, DEP – Co-executive Bruce Venner, DEP – Co-administrator 4

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What is an IEC? Contaminant source in the earth Contaminant relocation pathway Impacted receptor 5

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Three sorts of IECs Potable wells Vapor interruption Direct contact 6

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IEC Trigger Levels Potable Water > Groundwater Remediation Standards Vapor Intrusion > Rapid Action Levels Direct Contact > Acute Health Effect Levels 7

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Basic IEC Concept Delineate IEC issue Remediate IEC issue Remove source creating IEC issue 8

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What is the IEC Process? Each IEC gets a Case Manager Expedited time spans for fast reaction New cases go to IEC gather Case Managers on existing cases will deal with IECs LSRP/expert must work with Case Manager Most work in light of verbal endorsements with email affirmation 9

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IEC Guidance Written for essential sorts of IEC conditions and delicate receptors Includes both administer and direction: might & ought to Frequent correspondences and data imparting to caseworker is key Time expansions can be asked for 10

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Rules and Guidance Technical Rules (should) Must agree to necessities of the guidelines Guidance (ought to) Follow direction yet can utilize proficient judgment with satisfactory defense 11

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All administrative time allotments in Technical Rules N.J.A.C 7:26E-1.14 Start date for administrative time allotments was 11/2009 for existing IECs and date of revelation for new IECs All required time periods are in the ARRCS lead N.J.A.C. 7:26C-3.3 The begin date for obligatory time allotment arrangements was March 1, 2010 (existing locales) All compulsory time allotments are 2 years from the date of revelation of the IEC Time outline expansion can be asked for Regulatory and Mandatory Time Frames 12

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How to get an augmentation of administrative time period? Present a Remediation Time Frame Extension Request shape to the Case Manager or Bureau of Initial Notice 30 days before due date Provide judicious for expansion and new timetable If endorsed - You won't get a reaction If objected - A dismissal letter will be sent Note: An augmentation of an administrative time allotment must not bring about exceedance of an obligatory time span 13

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How to get an expansion of required time period? Present a Remediation Time Frame Extension Request shape to the caseworker or Bureau of Initial Notice 60 days before due date Provide sound for expansion New calendar to finish work Department will give a composed reaction 14

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Role of LSRP/RP & IEC Case Manager LSRP/RP Address IEC by taking after guidelines and direction IEC Case Manager Oversight: Direct Billing to RP Answer questions Evaluate time augmentation demands Evaluate deviation from direction Document advance or absence of advance Initiate authorization Noncompliance: utilize open assets 15

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Non-Compliance with Rules Case will be alluded for implementation DEP will utilize open assets for tending to receptors and leading receptor outline Refer LSRP to Licensing Board Enforcement against the dependable party $20,000 base punishment per infringement 16

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Significant Changes Current Technical Rules: February 2011 IEC Information Submittal 5 days stretched out to 14 days Regulatory: Source Control & Report 270 days reached out to 1 year Mandatory: Source Control & Report 1 year stretched out to 2 years 17

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Significant Vapor Intrusion Rule Changes Interim Response Action (VI ONLY) 5 days reached out to 14 days Trigger for VI IEC Indoor air screening levels (IASL) changed to surpassing the Rapid Action Levels (RAL) Vapor Concern (VC) Case classification made trigger level > IASL and < RAL 18

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IEC Regulatory Process Mark Fisher, The ELM Group, Inc.

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Regulatory time periods 3 Categories of Regulatory time spans Potable & Direct Contact Vapor Intrusion Vapor Concern 20

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IEC Regulatory Time Frames: Potable and Direct Contact Immediately 5 days 14 days 60 days 120 days 1 year Call the Hotline and caseworker Interim Response Action IEC Information submittal Engineered System Response Receptor Delineation Engineered System Response Action Report Source Control Report * 21 * Also has 2 year obligatory time allotment

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IEC Regulatory Time Frames: Vapor Intrusion Immediately 14 days 60 days 120 days 1 year Call the Hotline and caseworker Conduct Interim Response Action & submit IEC data and shape Engineered System Response Action & Receptor Delineation Engineered System Response Action Report Source Control Report * 22 * Also has 2 year compulsory time span

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Receptor Evaluation Report Timeline with IEC – Potable water May 1 Well Search 90 days March 1, 2011 Initial Receptor Evaluation* June 1 Collect Potable Sample 120 days March 1, 2012 Mandatory time allotment Get investigative information March 1 Receptor Evaluation Timeline Known ground water pollution 1 year source control 2 year Mandatory time span Data > sexually transmitted disease 120 day req. 5 day req. 14 day req. 60 day req. IEC necessities 23

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Differences amongst VI and Potable Water/Direct Contact VI: Both Interim Response Action and IEC Information Submittal due in 14 days Potable Water/Direct Contact: Interim reaction activity due 5 days IEC Information Submittal due 14 days All other time allotments are comparative 24

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Day 1 – Immediate Requirements Notify the HOTLINE Must allude to case as a " IEC Case" 1 (877) WARN DEP Notify caseworker for doled out cases Notify HOTLINE for obscure source IEC 25

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5 Day Requirements for Potable Water and Direct Contact IEC Complete break reaction activity Interim Response Action Examples Bottled water (consumable IEC) Fencing (coordinate contact IEC) Notify property proprietor, Twp., Health Dept 26

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14 Day Requirements - Potable & Direct Contact Only Information Submittal IEC Response Action Form IEC Spreadsheet Map of site and IEC condition All systematic outcomes with full information deliverables Submit paper duplicate & Email to Bureau Initial Notice and Case Assignment IEC Case supervisor allocated 27

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14 Day Requirements - VI Only Complete between time reaction activity Notify property proprietor, Twp., Local Health Dept., & Dept. Wellbeing and Senior Services Vent, seal breaks and sumps IEC Information Submittal IEC Response Action Form IEC Spreadsheet Map of site and IEC condition All scientific outcomes with full lab information deliverables Submit paper duplicate & Email to Bureau of Case Assignment and Initial Notice (BCAIN) IEC Case Manager will be allocated 28

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60 Day Requirements - All IECs Identify extra receptors (consumable wells and structures) Conduct inspecting Comply with warning prerequisites Complete Engineered System Response Action POET or waterline association Sub-section ventilation Verbal correspondence with IEC Case Manager is continuous 29

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120 Day Requirements - All IECs Submit IEC Engineered System Response Action Report: IEC Response Action Form Receptor depiction & receptor control portrayal IEC Spreadsheet with all IEC related information IEC Map GIS perfect guide accommodation 30

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1 Year Requirements - All IECs Complete outline of IEC source Initiate source control Submit IEC Source Control Report IEC Response Action Form IEC Spreadsheet with all information Map of IEC zone GIS good guide accommodation Monitoring & Maintenance Plan 31

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Vapor Concern - Regulatory Time Frames 14 days: Submit VC Response Action shape 60 days: Submit Mitigation Plan 120 days: Implement Mitigation Plan 180 days: Submit Mitigation Response Action Report 32

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Vapor Concern Interim Vapor Concern Technical Guidance New Vapor Intrusion Guidance will supplant VC Tech. Direction VC cases will have a caseworker VC Response Action Form 33

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VC and IEC Differences IEC: Exceeds Rapid Action Levels (RAL) VC: Exceeds IASL and < RAL No call to DEP Hotline No time allotment for Receptor Delineation No time period for Source Control Must present a Mitigation Plan Both IEC & VC have Case Managers 34

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IEC Case Component Completed IEC case finished off in DEP Database – no letter IEC caseworker's association stops Continue checking and upkeep (M&M) Submit future M&M reports to BCAIN not IEC caseworker M&M arrange fused into RAO allow 35

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Questions? (taken after by 10-min Break)

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IEC Resources Andrew Sites, NJDEP

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SRRA Guidance Library SRRA Forms Library Spreadsheet Sample Maps Sample letters to property proprietors Quick Reference Guide Contact List for Questions on LSRP IEC Resources 38

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SRP Guidance Library IEC Technical Guidance Document VC Technical Guidance Document Vapor Intrusion Guidance Document IEC spreadsheets GAC POET Specifications 40

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Site Remediation Reform Act Guidance Library 41

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SRP Forms Library IEC Response Action Form VC Response Action Form Potable Well/Indoor Air Sampling Notification Form Full Laboratory Data Deliverable Form IEC spreadsheets Remediation Time Frame Extension Request 42

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Site Remediation Reform Act (SRRA) Fo