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Voluntary Remediation Program (VRP)

VRP Frequently Asked Questions

Revised On: Nov .14, 2023 - 4:00 p.m.

The following is a list of frequently asked questions and answers about the Voluntary Remediation Program (VRP).

General Questions: 

Submit completed VRP applications by email to the VRP team, along with all supporting documents (i.e., maps, reports, etc.) | Download Application > | Email >

  • Please submit files in the .pdf format.
  • Sending paper hardcopies to ADEQ is not necessary. 
  • If supporting document files are too large to attach to email, please request a link to upload files in the email with the application.

Pay the VRP application fee by company check, cashiers check, certified check or money order made payable to “State of Arizona”, and include the template cover letter found with the application.

Mail the fee and cover letter directly to:

Arizona Department of Environmental Quality
Attn: Voluntary Remediation Program Accounts Receivable
1110 W. Washington Street, 6th Floor
Phoenix, AZ 85007

Yes, an applicant may enter the VRP to clean up a portion of a property, however, the boundaries of the portion of the property brought into the program may expand as additional sampling provides more information about the extent of contamination. The Volunteer will be required to continue to expand the portion of the property until sampling data shows contaminant of concern (COC) levels below target cleanup levels.

Yes, the VRP website provides numerous templates and guidance documents. Templates and documents are found under the “Forms” and “Templates & Resources” tabs on the main VRP page | View >

Yes, a general discussion regarding the conditions of the site and whether it appears to qualify for the VRP has been beneficial for previous applicants.

Yes. If a No Further Action (NFA) is sought, laboratory analytical data must show the characterization of the media investigated regardless of historic property use.

This depends on the current use of the site. If the use of the property has changed since Phase II was conducted, additional characterization may be required. In addition, a Phase II generally includes limited sampling and is conducted to gather additional information and determine if environmental problems exist at the site. Generally, a Phase II is not conducted with adequate spatial characterization to vertically and laterally characterize a site.

This is dependent on the site-specific conditions, which may include, but are not limited to, the contaminant(s) of concern, type/nature of release, depth to groundwater and lithology, etc.

Yes, a Volunteer can develop site-specific soil remediation levels.  If approved, these levels can be used to support an NFA determination.

Yes, a person may remediate soils to a residential or a non-residential site-specific remediation level derived from a site-specific human health risk assessment.

Yes, depending on site-specific conditions, characterization and remedial activities may be combined.

To qualify for an NFA, the VRP evaluates only contaminants for which a published Arizona regulatory standard exists. However, the VRP, on a case-by-case basis, may allow an applicant to bring in a site for evaluation of an emerging contaminant to be compared to another state or federal regulatory level, but the closure process will differ from that of an NFA determination.

ADEQ is not able to make recommendations regarding which contractors to use. Upon request, the VRP can provide a list of contractors used by the State of Arizona through the Arizona Superfund Response Action Contract, the Arizona Pollutants Contract, and the Arizona Tanks Contracts.  However, there are many contractors outside of these contracts who may also be well-qualified and should be assessed by the applicant/Volunteer.

On a case-by-case, site-specific basis. The VRP does not issue an NFA for vapor intrusion/indoor air characterization. However, the VRP will require an evaluation of the potential for a vapor intrusion issue as a secondary evaluation to the primary media listed in the statute (groundwater, surface water, soil).

The prospective Volunteer should determine if the PCB release is subject to the US EPA Toxic Substances Control Act (TSCA) and therefore subject to federal regulation. The VRP will require written documentation from the Volunteer confirming the PCB release is not subject to TSCA. If the PCB release is regulated under TSCA, the VRP does not have the authority to provide oversight of the PCB remediation. If the VRP is able to provide oversight of the PCB remediation, detailed information on required soil sampling and laboratory analytics will be discussed during the site kickoff meeting upon acceptance into the program.

Yes, the site could be accepted into the VRP. The Volunteer and the VRP can work with the US EPA jointly on the PCB release/remediation. The Volunteer would address the other COCs under the VRP.

The VRP has the authority to require a Volunteer to conduct an ecological risk assessment based upon known site-specific information, including the existence of ecological receptors and complete exposure pathways. When remediating a site, the Volunteer must remediate soil so that any concentration of contaminants remaining in the soil after remediation does not cause or threaten to cause an adverse impact to ecological receptors. If the ecological risk assessment indicates any such impact, the Volunteer must remediate soil to an alternative soil remediation level, derived from the ecological risk assessment, that is protective of ecological receptors.


Yes, if modification or removal of the DEUR requires site characterization and/or remediation, the property owner is required to have agency oversight for approval of the completeness of the activities | Learn More & View Contact >

A Volunteer may withdraw from the VRP at any time. However, the resulting withdrawal will void any suspension of actions established under the statute.  In addition, the VRP may refer the site information to another ADEQ program under Title 49 if the VRP has been made aware of contamination that causes or may threaten to cause an impact on public health and the environment.

No Further Action (NFA) Questions:

The VRP’s authority to issue closure of a site or portion of a site is referred to as a No Further Action (NFA) Determination or a Conditional NFA (CNFA) Determination.1 The VRP’s NFA may grant closure for soil, sediment, groundwater, and surface water if residential soil remediation levels (SRLs) are met. A CNFA may grant closure for soil if non-residential SRLs are met and a Declaration of Environmental Use Restriction (DEUR) is recorded | Learn About DEURs >

The two other types of closure, a Letter of Completion and a Notice of Site Closure are issued for rare and specific circumstances and can be discussed with VRP during a new site kickoff meeting.

"Area-specific" refers to the lateral and vertical extent of the media characterized to below regulatory levels for an NFA. COCs are contaminants of concern, of which a specific target list may be presented by an applicant in pursuit of an NFA. The VRP may require the list to be expanded once the source(s) is/are clearly identified.

Yes, the NFA can include specific language to accommodate site-specific conditions. For example, if a site's soil is remediated to the 1x10-6 residential Soil Remediation Level, it would be specified in the NFA determination letter.

Yes, an NFA determination can be issued after long-term monitoring is completed and the media's valid laboratory analytical data indicates contaminants of concern are below applicable standards.

Any contaminant having been properly investigated and having valid laboratory analytical data indicating it is below an applicable standard may be included in an NFA determination letter.

Any media (e.g., soil, groundwater, etc.), having been properly investigated and having valid laboratory analytical data indicating contaminants of concern are below applicable standards, may be included in an NFA determination letter.

Yes, if the PCB release is not subject to TSCA. If not subject to TSCA, the Volunteer must compare the total Aroclors to the high-risk PCB SRLs. To utilize the low-risk PCB SRLs, congener analysis is required. The Volunteer should work with their VRP PM for further details.

Yes, an NFA/CNFA can be rescinded or amended.2 Circumstances for rescinding or amending an NFA/CNFA could include any of the following:

  • if new information is discovered that would result in the denial of an NFA,
  • if the information submitted was inaccurate, misleading, or incomplete, and/or
  • if remedial action is necessary to respond to a release or threat of a release that may present an imminent and substantial danger to public health or welfare or the environment.


Timing Questions:

An application must be accepted within 60 days of receipt unless the VRP notifies the applicant that the application is incomplete or has been denied.

After an application is approved, the VRP will schedule a kickoff meeting with the Volunteer and the Volunteer shall submit a work plan to complete characterization, a work plan to complete remediation, or a request for NFA/CNFA.3 The VRP will help determine the appropriate path during the kickoff meeting.


The VRP understands external pressures/deadlines often influence applicant’s timelines, however, the VRP cannot guarantee expedited review of complete and accurate applications or other documents submitted to the program. The VRP strives to achieve document review in as short a time frame as possible.

The VRP prefers no less than quarterly communication on any site. Site-specific factors will be used to determine an appropriate time frame for inactivity. The VRP understands events outside the control of the Volunteer may occur. If this should happen, the Volunteer should work with the VRP to establish an appropriate schedule. If established communication requirements are not met, the VRP holds the authority to terminate the site.

Time to closure is site-specific and varies depending on the complexity of the site and the active engagement of the Volunteer. Volunteers enter the VRP at different stages/phases of the project. The time between acceptance into the VRP and determination of NFA depends on the thoroughness and accuracy of the data submitted, the nature and extent of contamination, and the length of time participants take to respond to VRP inquiries, requirements and comments.

Requirements Questions:

A Volunteer may elect to use non-residential SRLs, however the use of the property must be restricted to non-residential use with an institutional control and/or engineering control that is recorded on the property deed with the applicable county. The Volunteer may elect to clean up to residential SRLs if they choose to.4

Yes, any property where there is residential use at the time remediation is completed must meet residential SRLs.5

If the property has residential use at the time remediation is completed must meet residential SRLs.6 If a Volunteer elects to remediate to non-residential SRLs, the property must be restricted to non-residential use with an institutional control and/or engineering control that is recorded on the property deed with the applicable county.7

A Volunteer must meet residential or non-residential SRLs. Therefore, remediation, a risk assessment, and/or an engineering control with a deed restriction is required.

No, the Volunteer is not required to remediate another party’s release. However, the Volunteer must provide the VRP with clear and defensible lines of evidence to illustrate they have not contributed to, nor caused, the impacts.

There are statutory requirements such as, but not limited to, signage for field activities and public notices for certain submittals.

Although some sites with off-site contamination follow the Water Quality Assurance Revolving Fund (WQARF) Rule for remedial action, community advisory boards are not a requirement of the VRP. However, other WQARF community involvement requirements are applicable, such as public meetings, if requested by interested parties and public comment periods | Learn More About WQARF > 

The media to be investigated will be specific to the site conditions and COCs but could include soil, soil gas, groundwater and/or surface water.

A Volunteer who determines they have off-site groundwater contamination is required to follow the WQARF Rule for characterization and remedial action in the VRP.

The VRP requires the collection of soil gas data when evaluating volatile organic compounds (VOCs) at a VRP site. The soil gas data are to be converted to a soil solid concentration using a three-phase partitioning calculation, and the resulting concentration is then compared to the applicable soil regulatory level(s). All other potential non-VOC COCs may be evaluated using a soil solid concentration from soil media collected in the field. Be advised, if soil solid data for VOCs are submitted to the VRP, the data will be included in the overall data evaluation process. 

The applicable regulatory levels are Soil Remediation Levels (SRLs), which ensure remaining concentrations of contaminants do not cause harm when soil comes in contact with skin, is inhaled or ingested. Soil contamination remaining onsite must also be at a level that is protective of groundwater. To look up minimum Groundwater Protection Levels (GPL) or calculate an alternative GPL, use the ADEQ GPL Model | Download GPL Model Spreadsheet > | Download Guidance >

The more conservative number between the SRL and the GPL shall be used as the applicable cleanup level for the contaminant of concern.


The schedule depends on the specifics of the site. Project- and/or task-related schedules are required for work plans, which include both site characterization and remediation (if remediation is necessary).8 Periodic progress reports may also be required. Failure to substantially comply with the approved schedule may result in termination from the VRP.

Cost Questions:

When submitting the VRP application, the applicant is required to pay a $2,000 application fee. This fee is non-refundable and covers the cost for the VRP to review the application and determine eligibility for the Site to enter the program. If the site is accepted into the VRP, a $4,000 deposit request will be sent to the applicant with the acceptance letter. VRP personnel bill at $110 per hour for any work related to the site, and those hours are deducted from the site account. If the account balance falls below $1,000, the VRP Project Manager will send the applicant another $4,000 deposit request. Any funds remaining in the account upon closure of the site will be refunded.

Cost to closure is site-specific and varies depending on the complexity of the site. Very broad estimates can be provided upon request for certain types of sites.

No, the Volunteer should only send in the $2,000 application fee.  Once accepted, the VRP will send a VRP acceptance letter along with a deposit request for the $4,000 "retainer" fee.

In very specific instances, it may be possible to pay for VRP oversight utilizing funds awarded through the state Brownfields Program, however, this is determined on a case-by-case basis | Learn More & View Contact >  

The statutory authority for the VRP is found in Arizona Revised Statutes (ARS) Title 49, Chapter 1, Article 5, which includes ARS §§ 49-171 through 49-188 | View ARS Title 49 >


1ARS § 49-181 | View >
2In accordance with ARS § 49-181(E) | View >
3In accordance with Arizona Revised Statutes 49-174(C)
4R18-7-208 | View >
5R18-7-205(B) | View >
6R18-7-205(B) | View >
R18-7-208 | View >
8In accordance with ARS § 49-175 | View >