GPRA One State’s Perspective

GPRAOne State’s Perspective Arthur Shrader UST Program South Carolina DHEC

Guys in DC Pushing for Release Absolution To leak is human ….To Stop the Leak and Attain Cleanup Complete is Divine

South Carolina Tools that “Get the Job Done”: • Goals that are Attainable • Proactive Assessment Strategies • Risk-Based Corrective Action (RBCA) • Aggressive Cleanup Methods

RBCARisk-Based Corrective Action • Define the Risk • Assessment to Define the Chemicals • Find and Document All Receptors • Definition of the Risk Allows • Establishment of Appropriate Actions to Protect Receptors • Prioritization of Limited Resources

RBCARisk-Based Corrective Action • Define Closure Goals • Soil Action Levels • Vapor Action Levels • Action Levels for Other Chemicals (MtBE, Naphthalene) • Site Specific Cleanup Goals

RBCARisk-Based Corrective Action • Cleanup Goals > MCL • Monitored Natural Attenuation • Faster Active Cleanups • Quickly Close Low Priority Cases • Close 29% of All New Cases

RBCA Accelerated Closures State Cumulative Cases Closed

South Carolina Assessments

Assessments • Initial Assessment Defines Risk • Streamline the Assessment Process • No Plan Required for Initial Work • Select Best Assessment for Situation • Final Assessment Defines it All • Standard Format Reduces Work Preparation & Review Time

Assessments Cleanup Initiated as a Percent of Open Cases

Time and MaterialsWhat We Had • People Worked, but • Nothing Was Completed • Constant Cost Changes • - More Soda • - Sharpen Shears • The Fund Owned: • - Broken Chair • - Dull Shears • Invoices were a Novel • Fights over $2.37

Focus Everyone on Cleanup Results ….. Not on Payments What We Wanted • The Job Completed • or Substantial Progress • Minimal Cost Increases • or Change Orders • The Fund did Not: • Own Broke Equipment • Warehouse Equipment • Simplified Invoices

Cleanup Technologies Best Technology is Used Percent

Work Is Successfully Completed • Guarantee Required for the Bid Amount - Performance Bond - Irrevocable Letter of Credit • QA/QC - Oversight of System Installation - Split Samples Verify Goals Are Met - Verification Monitoring Wells

CleanupProgress

Cost • Plume Size Is The Key Cost Factor - $27,000 for 45’ x 90’ - $80,000 for 120’ x 200’ - $120,000 for 180’ x 225’ • No Significant Cost Increases • BTEX and MtBE • MCLs or Higher Target e.g. 800 ppb (SC Action Level for MtBE is 40 ppb)

Rehabilitation System • System Belongs to the Contractor- No Additional Cost for Repairs • Acts of Nature (Lightning, Hurricane) • Theft or Vandalism • Routine Wear and Tear - Removed by Contractor • Fund Does Not Salvage Used Equipment

Procedures Payment Based on Performance : • As Goals are Met Payment is Authorized • Single Page Invoice Validated by Last Report • Invoice Processing is Less Than Two Days • Reduction in Size of Financial Files • Regulators are Not Pushing for Results… ....Contractor’s Efforts Result in Payment • Engineers and Geologists are Engineers and Geologists NOT Accountants

Procedures • Everyone Focuses on Results • The Entire Plume Is Remediated • Better System Components Are Used • The Best Technology or Method(s) Are Used • Bid/Fixed Cleanup Cost • Allow Best Use of Funding • Allow Budget Projections • Avoid Change Orders (Unfair to Second Lowest Bidder)

GPRAConclusions • RBCA is the Road Map • 25% are “1 Year Closures” = Minimum Work • 33% are “2+ Years Closures” = Assessment and Resampling e.g. MNA • 41% are “3 to 5+ Year Closures” = Cleanup • Easy Closures are Going, Going, Gone • Each State’s Situation and Resources will Accelerate or Delay Closures

Great Performance Requires Action

GPRA One State’s Perspective