One of the issues that can complicate a clean up is if multiple environmental regulatory programs apply to the site. Even the same type of contamination may be required to be addressed under different programs and different processes.
A prime example of this issue in Ohio is the disconnect between Ohio’s Voluntary Action Program (VAP)

The Northeast Ohio Regional Sewer District (NEORSD) has entered into a settlement with U.S. EPA to fix its combined sewer overflow issues (CSOs). Included in the settlement is a provision which requires NEORSD to spend $42 million in eight years to eliminate 44 million gallons of storm water from entering its sewer system.
In working on brownfield redevelopment projects, I find that addressing old underground storage tanks (USTs) or hazardous waste (RCRA) units can be one of the trickiest issues to address.
For over three years, U.S. EPA had been moving toward a seismic shift in how it regulated stormwater run-off from construction sites. For the first time, U.S. EPA tried to impose a numeric permit limit on the turbidity of water (sediment mixed with water) that leaves construction sites following rain events. EPA ‘s efforts are