Updates on Washington State Department of Ecology’s VCP- Part II

Ecology has made some big changes in their Voluntary Cleanup Program (VCP). In an effort to balance staff shortages with increasing workloads, Ecology has raised the bar for entry into the VCP and is implementing new policies to streamline reviews. If you have a site in the program or are planning on entering one, be aware that the standards for what and when Ecology will review are becoming more rigorous.

In our previous blog, Updates on Washington State Department of Ecology Voluntary Cleanup Program, MFA’s Alan Hughes discusses the new checklists and templates Ecology developed for VCP reporting. Ecology recently held a meeting to roll out the checklists and other changes they’ll be making in the program.

What you need to know from the VCP meeting:

• No more complex sites – this includes sites with sediment or surface water contamination, sites that pose an imminent threat, or other issues that are not straight-forward to address (e.g., commingling plumes).

• Waitlists – starting this September, existing VCP sites will be given priority and new sites entering the program will be waitlisted and put in a queue based on entry date.

• Checklists – if your reports aren’t complete, per Ecology’s checklist of standard components, they may be rejected, and you may have to wait 90 days to find out!

• Longer review timeframes – opinions may not be issued within the standard 90 day review timeframe and in some cases may take up to six months, especially in their busiest office in Bellevue.

What does this mean for you?

• Communicate with Ecology early in the process to get a sense of their current workload and review timeframes, to determine if your site will be waitlisted, and to get feedback on whether your site meets the standards for entry into the VCP or if it’s better suited for a different cleanup pathway.

• Contact MFA for a recommendation on which cleanup pathway best fits with your site and particular needs.

• Ensure your VCP application and reports are complete before submittal, per Ecology’s checklists. MFA’s Alan Hughes and Justin Clary were involved in the checklist development and can assist you with this process.

• If you’re planning on entering your site into the VCP, contact MFA sooner rather than later. Wait lists are effective in September!

• MFA can work with you and your team to evaluate whether your site needs to go through the VCP or if an independent cleanup action with no Ecology opinion might suit your needs.