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Deconstruction of a MTCA Project WPPA Environmental Meeting

September 25, 2015


Site Cleanup in 9 Easy Steps Site Discovery

Initial Investigation

Site Hazard Assessment

Cleanup Action Plan

RI/FS

Hazard Ranking

Engineering and Design

Construction

O&M

http://www.ecy.wa.gov/programs/tcp/cu_support/cu_process__steps_defns.htm


Can We Insert Some Reality to the Situation?

When I say “We” I mean YOU….

Technical Staff Consultants Finance Executive Staff Regulatory Agencies Attorneys Real Estate/Planning Port Commissioners Communications WPPA Others?


Site “Discovery” MTCA Reality

• • • • • •

Port Examples: Building Project-Dug Something Up

Purchased PropertyKnowingly Contaminated Pursuing historic insurance Tenant Operations Other?


Site Hazard Assessment & Ranking MTCA Reality Health Departments? Who uses the WARM Ranking anyway? https://fortress.wa.gov/ecy/publications/publications/ftc91107.pdf

Is now the time to engage with Ecology?

• • • • • •

VCP vs. Formal Cleanup Program Agreed Order Negotiations Grant Funding Public Outreach Independent Action? Other Experiences?


Internal Process MTCA Reality

• • • • •

Engage with PLPs Agency Negotiations Cost Modeling Defining Roles Other?

PLP Considerations: DNR Big Oil Tenants-Insurance Cities/Counties

Port Commission Consultant Support Legal Political-State & Local Partnerships vs. Adversaries Public Perception Other?


RI/FS…Why does it take so long? MTCA Reality Remedial Investigation

• • • • • •

Scoping Work Plan

Focus Areas Data Gaps Upland vs. Sediment

Other? Most critical step in process? Need agency buy-in…

Considerations:

Multiple rounds of sampling How much data is enough? Informs Remedy Selection Are there other objectives (Brownfields etc.)


RI/FS…Why does it take so long? MTCA Reality Feasibility Study

• • • • • •

Evaluation of Alternatives Integration of Port Plans“Land use Informs Cleanup” Long- and Short-Term Goals Refines Cost

Public Engagement PLP Settlement Opportunities

Other?

Do you know what you want to do with the Site?


Consent Decree? Is funding in place?

MTCA Reality

Consent Decree vs. Agreed Order Interim Actions? Experiences? New realities under Remedial Action Grant Situation? RI/FS

dCAP

EDR

Permit

Conducted Under A.O.?

CD

Construction


Cleanup Construction MTCA Reality

Scope and Scale Coordination with Permitting Agencies Project Partners Tenant Coordination Cash Flow Contractor-Low Bid-Supplemental Criteria Construction Management Experiences: In House Management Turn Key Consultant Support


Public Involvement MTCA Reality

Outreach/Education

Required Process:

Tell a story

30 Comment Periods

Tours?

Public Meetings

Get Burned?

Significant Prep. Time

Vocal Minority

Adequate Review Time? Not a “vote”

Success Stories?

Coordination with Agencies/Partners Outside Support?


MTCA Lean Outcomes and Status Timing and Scheduling: • Two years to complete RI/FS • One Iteration of all significant documents • Significant Documents are reviewed and commented on within 45 days • Three years to complete cleanup construction

Total of 5 years for Start to Finish

Training and Targets: • Develop tool kit and guidance manual for training • Targets for continuous improvement • Develop tool to track progress and provide feedback

WPPA 2015 Env Seminar - Deconstruction of a MTCA Project, Gouran  
WPPA 2015 Env Seminar - Deconstruction of a MTCA Project, Gouran  
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