Regulated Materials Review (RMR) is the practice of assessing, investigating and mitigating, if necessary, contaminated properties in a transportation project area. In most instances, ODOT tries to avoid these areas, but when avoidance of a contaminated property is not an option, we have a plan in place to mitigate the situation.
NEPA Transportation Projects
During the NEPA process, environmental site assessment investigations are conducted using ODOT’s Regulated Materials Review Guidance (RMR). This guidance has been specifically designed to address issues of acquisition liability and materials management which may affect transportation projects. Each Regulated Materials Review must address the potential liability of acquiring portions or all of a property under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) and the Superfund Amendment and Reauthorization Act (SARA). If properties are shown to be contaminated, then those materials must be removed from the site during construction and must be properly identified and managed under the Resources Conservations and Recovery Act (RCRA) and the Hazardous and Solid Waste Amendments (HSWA). For sites requiring remediation, in an enforcement action or regulatory oversight, the RMR Unit conducts the necessary coordination with the U.S. Environmental Protection Agency (USEPA), Ohio EPA and/or the Bureau of Underground Storage Tank Regulations (BUSTR) for the project.
Product & Waste Management
The RMR Unit helps Districts keep in regulatory compliance by providing guidance on the storage of products, management of wastes, remediation of facilities and the preparation of guidance documents for product and waste management. The RMR Unit addresses ODOT regulatory issues and is a point of contact for regulatory agencies. In order to accomplish this mission, the RMR Unit works with the Districts’ Facility Management and Highway Maintenance personnel, the Office of Maintenance Administration and the Office of Facilities Management.
Product management at ODOT’s facilities includes a variety of items from regulated materials such as parts washers and automotive fluids to unregulated materials such as salt and pressure treated lumber. The goal is to properly manage and store these products while conserving products, promoting recycling and recommending new products to replace products containing hazardous constituents.
The RMR Unit also provides guidance and technical assistance for ODOT facilities that have been impacted by past practices and other environmental concerns. The tasks involved include site investigations, negotiating and interacting with USEPA and Ohio EPA, providing technical assistance in selecting remedial alternatives and providing guidance during their implementation.
Tank Management Program
The RMR Unit assists the Districts’ Facility Management and Highway Maintenance personnel with the operation and maintenance of their above ground and underground storage tanks containing petroleum products. In addition, the RMR Unit addresses regulatory issues related to the tanks, acts as a point of contact for the Bureau of Underground Storage Tank Regulations (BUSTR) and the State Fire Marshal, and provides assistance in writing and updating the Spill Prevention, Control and Countermeasure (SPCC) plans for ODOT facilities.
The RMR Unit assures ODOT’s petroleum tanks are properly registered with BUSTR. As part of these duties, the RMR Unit manages ODOT’s regulatory compliance for all ODOT USTs and ASTs.