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Home > Programs > Ombudsman > Permit Streamlining > Waste Task Force > Regulatory and Administrative Working Group


Waste Permit Streamlining Task Force-
Regulatory and Administrative Working Group

Agendas Minutes
Agenda, 5/31/01 Draft Notes, 4/10/01
Draft Notes, 5/17/01

Regulatory Issues



1 R

Regulations need to be updated and better coordinated, especially the Oil Pollution Control and UST regulations.

2 R

The Site Investigation Report and the Remediation Plan should be combined into one process.

3 R

Review and clarify the site characterization and testing protocols to determine if the requirements are appropriate.

4 R

Modify the regulations (if necessary) after the policy issues concerning arsenic have been resolved.

5 R

The Site Remediation Rules are cumbersome and should be made more flexible.

6 R

Environmental Equity - Review the Site Remediation Regulations to ensure environmental equity issues are appropriately addressed.

7 P

Develop a policy / change regulations that encourages an expedited remediation process for "simpler sites".

8 P

Evaluate a limited LSP process for the "simpler sites. Look at the possibility of allowing third party certification of site conditions and an expedited review of Settlement Agreements and Remedial Action Plans.

9 P

Encourage the development of a public / private consortium that will help to get "simpler sites" remediated. Have this organization be responsible for developing a certification program that includes an independent audit function.

10 P

DEM should develop a model Settlement Agreement.

11 P

Site Remediation, LUST and UST regulations should have consistent remedial objectives.

13 D

To better fund and support the program, fees should better reflect the actual review time required for complex proposed remedies (i.e.: risk assessment reviews).

14 D

Options should be considered (including fees and funding sources) to allow the program to hire outside technical support as needed.

15 D

To encourage more use of innovative technology, and more permanent clean ups, the State should consider a fee structure for the use of ELUR's to discourage their overuse.

Administrative Areas of Concern


Staffing issues

1 A

There is insufficient staff to run the program.

2 A

Staff takes too long to review complex projects that are out of the ordinary.

3 A

DEM staff is not generally equipped to review complex risk assessments.

4 A

There is not a comfort level between staff and the regulated community and trust needs to be developed between these two groups.

5 A

There are many new employees in the program and as a result of their experience level, are being too conservative in their reviews.

6 A

Performance tracking is a good management tool, but there is concern that the goals may push DEM staff to issue deficiency letters to meet time goals, rather than working to make decisions on the submitted material.


Application Quality/Training

7 A

In order to improve application quality, DEM should sponsor consultant-training courses, possibly using URI as a resource.

8 A

Stakeholders should support a training institute and push for training in this area.

9 A

DEM should conduct consultant training / workshops on DEM's expectations for site remediation submissions.

10 A

DEM should develop, publish and distribute guidance material and policy directives about the regulations using the DEM homepage and traditional outreach mechanisms.

11 A

DEM should develop an administrative completeness checklist that could be used as a guide by an applicant for site remediation submissions.

12 D

To ensure application completeness and standardize review, submissions need to address all requirements of section 7 (Site Investigation). If required, submissions should state if a particular specific rule is not applicable to a site.

13 D

Submissions should address section 7.04 (re: development of 3 proposed remedial alternatives) addressed specifically relative to cases involving proposed residential reuse of historic industrial properties.

14 D

Submittals need to better address ecological risk pathways (i.e.: sediments, surface water, etc.).

15 D

If a site investigation and remedial action work plan are submitted concurrently, the site investigation is complete.

16 D

Presumptive remedy options should be evaluated.

P=policy; A=administrative; R=regulatory; D=DEM generated

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rev. 1/31/14