Petrogram - Spring 2010 - (Page 17)
FEATURE FPMA Efforts to Improve the Cleanup Program Steve Hilfiker PMA is working hard in an attempt to address a few areas where improvements could be made in the Petroleum Cleanup program. The efforts include, among others: • Providing a funded method for obtaining ‘No Further Action’ status for low scored sites through risk-based corrective action • Improvements to the institutional controls process to make risk-based closures easier • Increasing the use of natural attenuation, which would provide funding to more sites faster The emphasis behind most of these eﬀorts is to address the backlog of sites where little to no remedial activity has occurred in years. The statistics vary depending on the FDEP database referenced, but over 5,000 eligible sites are scored 29 or less and have not been in range for funding due to the site score since 1995. As most readers know, the site score that dictates which sites are funded is determined using a hazard ranking system based primarily on risk of impacts to drinking water supplies. Theoretically, low scored sites do not pose a risk to human health or the environment (provided the investigation that determined the score was accurate). Most of these low-scored sites will attenuate naturally over time, and a signiﬁcant percentage of those that have not been assessed in 15 years probably have done so by now. Assessment activity on these sites should promptly lead to unconditional closure through a Site Rehabilitation Completion Order (SRCO), which represents ﬁnal agency action on the applicable discharge(s). The economic beneﬁts are clear. We call this the ‘low hanging fruit’ strategy to reduce the backlog. For low-scored sites that have not attenuated to target levels, we hope to trigger funding for risk-based corrective action (RBCA), which allows for site closure through the use of institutional and/or engineering controls. The most common type of engineering control is to maintain an impervious cover (e.g., concrete) over the site. Institutional controls typically are in the form of recorded deed restrictions on water use. Most sites utilize municipal water, so this is often an insigniﬁcant restriction to the site. The recording process as it currently stands is laborious and we hope to simplify it with our eﬀorts. By increasing the use of natural attenuation, some of the current funding of active remedial systems can be used to thaw frozen sites. More money will be available and the result will be a reduction in the funding score. Once these sites are revived, an emphasis on attenuation and RBCA, as is done in many other states, should continue the trend toward backlog reduction. ❍ Steve Hilfiker is the president of Environmental Risk Management Inc. (www.ermi.net) and can be reached at 1-888-368-6468 or email@example.com. Petrogram Petrogram Petrogram Petrogram e o a | Spring 2010 Spring 201 pri pring 2010 r 01 | 17 17
Table of Contents for the Digital Edition of Petrogram - Spring 2010
Petrogram - Spring 2010
A Celebration of the Petrogram’s 50th Anniversary
How to Stage a Great Grand Opening
FPMA Efforts to Improve the Cleanup Program
Out & About the Industry
E-10 and Single-Wall Fiberglass Tanks
Are You Ready for PCI Compliance?
Crind and Bear It
Index of Advertisers/Advertiser.com
Petrogram - Spring 2010
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