The Virginia Department of Environmental Quality (“DEQ”) has clarified its approach to issuing “no further action” letters (“NFAs”) for sites with both petroleum and non-petroleum contamination. This clarified approach will ensure that non-petroleum contaminated sites are reviewed only through the Virginia Voluntary Remediation Program (“VRP”) screening process. In addition, DEQ has launched its updated technical approach to risk assessments, the Virginia Unified Risk Assessment Model (“VURAM”). The combined effect of these developments is a more universal and definitive process for determining whether cleanup obligations exist for non-petroleum contaminated sites and, if so, the applicable risk-based cleanup levels.
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