Environmental Site Assessment Guidelines - Ohio Department of ...

6.1.6 Regulatory Records Review
The activities involved in this section include further research of a parcel's regulatory history. This
research involves completing a BUSTR file review for each site identified in the regulatory
database search and summarizing relevant information including the potential of encountering
petroleum contaminated soils during construction. Any pertinent registration, closure, corrective
action, engineering controls, institutional controls, covenants, and/or release notification
information should be reviewed, summarized, and documented in the report. This information is
particularly important for sites where the BUSTR report has given the site a No Further Action
(NFA) letter, since many sites are now given an NFA letter based on a site-specific risk-based
assessment. NFAs based on a risk assessment address only liability issues and allow petroleum
contaminated soils to remain onsite and non-remediated. If these contaminated soils are
excavated, they are considered a waste and need special management during construction. To
determine if a PCS note is warranted for a site, compare the soil data in the BUSTR file(s) to the
BUSTR Re-use Action Levels via Table 1 of OAC 1301:7-9-16(D) (see Appendix J).
The raw data from the file review should be included in an appendix. This raw data included with
the file review should include the pertinent portions of the Closure Report and other BUSTR
required reports. Examples of this required raw data includes, but is not limited to: soil and
groundwater analytical data (tables of laboratory results will suffice in place of rather lengthy
laboratory analytical printouts, as long as all the laboratory results from the printouts are in the
tables), maps that depict the location(s) of the UST(s), pump island(s), vent pipes, contamination,
monitoring wells, soil borings, etc. This data should be included even if the site has received an
NFA. Typically, copies of the chain of custodies, lab data already presented in a data table,
QA/QC reports, etc. should not be included.
When sites do not have a BUSTR file but have evidence that they previously managed petroleum
products (i.e. evidence of USTs, pump islands, interviews, etc.), it will be assumed that PCS will be
encountered and a PCS note warranted for any deep excavation on that site. For the BUSTR
contacts see Appendix F.
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