The CTDEEP Release Based Cleanup Regulations (RBCRs) going live March 1, 2026 bring about several changes to how spill response and remediation must be handled, including the creation of the Permitted Environmental Professional (PEP) program. A PEP must be on-site for the entire duration of a cleanup in cases where an LEP is not involved. Additionally, a PEP is responsible for coordinating initial cleanup actions and may certify closure of certain releases.
All PEPs must take and pass a CTDEEP approved course and examination with 4-hour refreshers required every three years in addition to other training and experience requirements. Additionally, PEPs must possess a current 40-hour OSHA HAZWOPER, OSHA 30 hour, and ICS (incident command system) 100, 200, and 700 training. Lastly, a PEP must have a total of 10 years of experience in responding to, mitigating, and remediating hazardous materials incidents, releases from underground storage tanks, experience in planning remedial activities, knowledge of chemical fate and transport, knowledge of soil classification, competency in spill response equipment, competency in emergency equipment and procedures, and mitigation, containment, and removal techniques.
As the only 22a-454 permitted spill cleanup contractor approved by CTDEEP to administer this course, KEC brings a large pool of experience and awareness of these regulations and their broader industry implications alongside our knowledge as an environmental consulting firm. Our goal is to ensure every individual in this course walks away with the experience they need to remain in compliance and to successfully oversee cleanup, tank removals, and tank abandonments from job commencement to closure certification.
The following is the general course outline:
- Release based cleanup regulations (RBCR)
- Emergent reportable releases
- Oil and petroleum
- Other releases
- Imminent releases
- Releases exempt from reporting
- Release discovery
- Significant existing releases
- Characterization of discovered releases
- The tiering system
- Immediate actions
- PEP vs LEP roles
- PEP certification vs LEP verification
- Soil cleanup standards
- Groundwater cleanup standards
- The home heating oil special path
- Home heating oil releases with third party as responsible party
- Release remediation closure reporting
- Administrative procedures
- Auditing
- 22a-454 permit overview
- REACT system
- How these regulations differ from the old “regime”
- UST 22a-449(d)-106-107
- UST corrective action
- UST closure
- Remediation Standard Regulations (RSRs)
- GA/GB PMC
- RDEC & I/CDEC
- Soil types and permeability
- Chemical fate and transport
- Release planning and characterization
- Conceptual site model
- Data quality objectives
- Surface water and solubility
- Field screening
- Risk assessment in soil contamination
- PCBs
- Pesticides
- Petroleum hydrocarbons
- Heavy metals
- Brief RCRA overview
- Proper sampling techniques
- Soil sampling methods
- Groundwater sampling methods
- CTDEEP approved analysis for petroleum releases and UST petroleum closure
- Sample handling and chains of custody
- PPE and safety procedures