CT DEP'S PERSPECTIVE ON SITE CHARACTERIZATION June 6, 2002

1. CT DEP'S PERSPECTIVE ON SITE CHARACTERIZATIONJune 6, 2002 Presented by: Christine Lacas, Supervising Environmental Analyst Permitting, Enforcement & Remediation Division Bureau of Water Management Connecticut Department of Environmental Protection 79 Elm Street, Hartford, CT 06106-5127 (860) 424-3766 christine.lacas@po.state.ct.us

2. CT DEP'S PERSPECTIVE ON SITE CHARACTERIZATION • In CT, Licensed Environmental Professionals are authorized by statute to provide verifications for specific types of sites. • Pursuant to CGS §22a-134(19), "Verification" means the rendering of a written opinion by a licensed environmental professional that an investigation has been performed in accordance with prevailing standards and guidelines and that the parcel has been remediated in accordance with the remediation standards.

3. CT DEP'S PROGRAM FOR AUDITING LICENSED ENVIRONMENTAL PROFESSIONAL (LEP) VERIFICATIONS (THE AUDIT PROGRAM) HAS TWO PRIMARY PURPOSES: • to identify LEP verifications that may represent violations of the LEP or Remediation Standard Regulations, and • to identify topics and areas for which further training and guidance is needed. • Site Characterization was identified as one of the areas in which additional training and guidance is needed.

4. THE MOST COMMON SITE CHARACTERIZATION DEFICIENCIES IDENTIFIED THROUGH THE AUDIT PROGRAM ARE: • Failure to identify all potential release areas • Failure to identify all contaminants of concern • Failure to fully understand or document the distribution of contaminants for a specific release area (without regard for regulatory criteria) before reaching a conclusion on the need for remediation • Failure to document the rationale for conclusions reached on the need for no additional investigation and/or remediation for a specific release area or area of concern.

5. INITIATIVES FOR CHANGE • A Draft Site Characterization Guidance Document was issued by DEP (June 2000).This document advocates the use of phased investigations and a Conceptual Site Model approach, and is available from the Environmental Professionals of Connecticut website at www.epoc.org • Conceptual Site Modeling Training workshops have been given several times since the Draft Guidance was issued. • An Expedited Site Characterization CD has been developed for UST sites • DEP encourages the use of field characterization methods (with appropriate documentation) whenever possible.

6. INITIATIVES FOR CHANGE, continued • Since the release of the Draft Site Characterization Guidance Document and the associated Conceptual Site Modeling Workshops, there has been an improvement in the quality of the site characterization work submitted to DEP. We are seeing more reports that describe the conceptual site model as well as the rationale for investigation and remediation decisions that are made.

7. CHALLENGES REMAINING • Comments received by DEP on the June 2000 Draft Site Characterization Guidance document are being reviewed, and the Guidance is scheduled to be finalized this summer. • DEP staff and the EPOC Education Subcommittee continue to work together to develop and present training. A comprehensive course on Site Characterization is being developed and will likely be offered by EPOC late this year (December).

8. CHALLENGES REMAINING, continued • Despite the guidance and training efforts described above, we continue to see some site investigations that do not identify or adequately address all release areas, do not identify or address all constituents of concern, or do not adequately define the extent of contamination in all media.

9. SUGGESTIONS FOR IMPROVEMENT: • Better documentation of the rationale for site characterization decisions. • Improved documentation that environmental improvements (documented by sampling results after remedial actions have been undertaken and completed) are consistent with the Conceptual Site Model developed for the site.