Hull was retained to investigate and close out a RCRA (Resource Conservation and Recovery Act) release area associated with a release of ferrous chloride solution from the facility’s picking line and obtain a Covenant not to sue through the Ohio Voluntary Action Program (VAP).
In executing this project, Hull undertook the preparation of Phase I Property Assessment Report, entry into the Ohio Voluntary Action Program (VAP), and implementing the Memorandum of Agreement (MOA) Track. Hull also secured the Clean Ohio Assistance Fund grant for Phase II Assessment activities through Jefferson County Regional Planning Commission. Hull conducted Phase II Assessment Activities to characterize the property in accordance with the Ohio VAP and the preparation of Phase II Assessment Report and Property Specific Risk Assessment.
The Property was eligible under the VAP with the exception of the RCRA closure area. The RCRA unit needed to be closed pursuant to RCRA regulations prior to the entire property being eligible for the Ohio VAP. During the RCRA closure process, Hull negotiated that any groundwater issue associated with the RCRA release could be addressed under the VAP. This negotiation saved the owner thousands of dollars in additional groundwater sampling that would have been necessary under RCRA.
Steve Gross, CP, CPG