Pennsylvania Act 2
Pennsylvania's Land Recycling and Environmental Remediation Standards Act (commonly referred to as PA Act 2) was passed in 1995 to provide clear, consistent remedial standards within the Commonwealth of Pennsylvania. Act 2 allows for the remediation of sites under one or a combination of the Statewide Health Standard, the Background Standard, and the Site-Specific Standard. The regulations associated with Act 2 are found at 25 PA Code Chapter 250, and contain the published Statewide Health Standards as well as guidelines for establishment of Background and Site-Specific Standards. The Statewide Health Standards are generic standards applicable to all sites in Pennsylvania. The Background Standard is established through the collection of background samples and comparison of those results to site concentrations. The Site Specific Standard is established through the use of risk assessment and site-specific exposure assumptions to establish acceptable cleanup standards. These remediation standards are also applied to Pennsylvania sites regulated under the UST regulations (25 PA Code Chapter 245), and the Hazardous Sites Cleanup Act. Pennsylvania has been granted RCRA authority by the USEPA, and RCRA programs are implemented at the state rather than the Federal level; also using the Act 2 standards as target cleanup criteria.
PA Act 2 Experience
I have extensive consulting experience supporting clients remediating sites under Pennsylvania's Act 2 program. My experience includes characterization of sites in accordance with Act 2 requirements, conducting site-specific risk assessments, preparation of cleanup plans, and preparation of Final Reports. I have led negotiations with Pennsylvania regulators, and provided public communication on behalf of clients remediating sites under Act 2.
In 1997, I managed a team of professionals in the Act 2 closure of six units at a major chemical facility in southwestern Pennsylvania. At the time of the effort, the Act 2 Regulations were not yet promulgated and the draft regulations were continually changing. The client had reserved upwards of $10 million to complete remediation of the site. Through assembly of a realistic risk assessment and the use of various contaminant modeling techniques, we were able to reduce the remediation to a monitoring only remedy. Monitoring was limited to eight quarters per the requirements of Act 2 and all six units were successfully closed.
Through application of site-specific risk assessments, I have closed over 20 sites under Act 2. These sites have ranged from simple pathway elimination projects to highly complicated sites requiring detailed risk assessment. I specialize in moving sites to closure using the technical tools available to scientifically justify limiting remedial action.