Petrogram - Winter 2010 - (Page 15)
Jill Smith, TERRA-COM Environmental
t is best, in economic times like these, to be very thoughtful in the way we do business and to constantly adapt. The best way to survive, and subsequently thrive, is by examining each expenditure and considering every minute spent in a professional capacity in our industry. Whether a marketer, an environmental prime or an environmental subcontractor, there are industry problems that affect us all. One problem that comes to mind is FDEP’s implementation of the Automated Data Processing Tool (ADaPT) program with a target date of July 1, 2011, for the Bureau of Petroleum Storage Systems. Another problem with the cleanup program is the amazing amount of duplication of effort with the regulatory case management, the prime contractors and the regulatory oversight representatives. Duplication of efforts results in a financial loss associated with the tremendous amount of report requirements and oversight versus actual ‘boots on the ground’ environmental work. Like many of you, I have been perplexed about the way the ADaPT program will be implemented by FDEP. The ADaPT program requires Electronic Data Deliverables (EDD) in the form of a lab EDD, a field EDD and an error log. It is a digital submission of laboratory and field work information. In the September 20, 2010, FDEP implementation outline, I can follow the timeline and see many places where the state contractors are being coordinated with, possibly educated about, and included in the pilot testing of the ADaPT program. If this document is current, I see 11 state contractors listed, and right now we have approximately 232 contractors qualified to work in the Bureau of Petroleum Storage Systems, Environmental Cleanup Program. There are 221 qualified contracting companies that have not been considered in the process, or at the very least, will not be considered until April 1, 2011, when the FDEP website will notice contractors ‘globally’ of the startup date of July 1, 2011. I have looked over the implementation document many times, and I have not found where contractors (state or general) will be reimbursed for the infrastructure dollars that ADaPT installation and implementation will cost.
Also, it appears that the ADaPT program is more of a regulatory exercise rather than an exercise in actual environmental cleanup. The cleanup program has an amazing amount of duplication of effort with the regulatory case management, but also between the prime contractors and the regulatory oversight representative. Let’s take for example, a state cleanup site that is managed on a county level, but approved in Tallahassee both technically and financially; information must be relayed several times before the approval process is complete and work can be approved and scheduled. There are always two layers to any decision: technical or financial. It’s true that prime contractors need to follow the state statutes, however some regulatory agencies or individuals are far more concerned with the minutia rather than moving forward with a holistic cleanup plan. We need to minimize the ‘tornado’ of reporting and oversight, and allow for more ‘boots on the ground’ environmental work. With reduced oversight, more IPTF dollars would be available for cleanup activity. And speaking of the IPTF, we must continue the push forward legislatively by meeting with the legislators and working to fund the cleanup program at the highest level possible. Only through securing the IPTF funds can we continue to make progress on the state funded cleanup program sites. Please use the environmental talking points from the fall 2010 Petrogram, and get out and speak to your legislators. There is no time to waste. My advice is that we navigate the program problems effectively, work legislatively, and watch the petroleum cleanup program appropriations closely. Buckle up, we have a long way to go in the adaptation of our industry. ❍ Jill Smith is director of business development of TERRA-COM Environmental Consulting, Inc. She is also the environmental director on the FPMA Board of Directors and chairs the Environmental Committee. You can contact Jill at 904-3963070 or email@example.com.
Table of Contents for the Digital Edition of Petrogram - Winter 2010
Petrogram - Winter 2010
FPMA Salutes Its Patron Members
Cost Savings Is the New Trend
Out & About the Industry: New Year Petro-Financing Prognostications
CITGO Steps Outside the Box
Enviro Corner: Adaptation
Overcoming the Obstacles: Court Finds Cleanup Cost Coverage
A Bad Combination: Drugs & Alcohol in the Workplace
Local Store Marketing for Convenience Stores
Index of Advertisers/Advertiser.com
Petrogram - Winter 2010