Georgia Environmental Protection Division Chris Hurst, Environmental Engineer DOD Remediation Unit

Environmental Stewardship The mission of the Georgia Environmental Protection Division is to help provide Georgia's citizens with clean air, clean water, healthy lives, and productive land by assuring compliance with environmental laws and assisting others to do their part for a better environment. www.dnr.state.ga.us/dnr/environ

...and Military Presence Dobbins Air Force Base Lockheed Martin Air Force Plant No. 6 Fort Gillem & Fort McPherson Fort Gordon Robins Air Force Base Fort Benning Hunter Army Airfield Fort Stewart Marine Corps Logistics Base Moody Air Force Base Naval Submarine Base- Kings Bay Major Department of Defense Installations in Georgia

Department of Defense and State Memorandum of Agreement / Cooperative Agreement (DSMOA/CA) Program GA EPD began participating in the Cooperative Agreement process in CY2001 and July – September 2001 was the first quarter for which we received funding.

Reorganization of GA EPD’s Hazardous Waste Management Branch as a result of our new DSMOA/CA Funding.

DoD Remediation Unit The DoD Remediation Unit is responsible for managing the corrective action programs at federal DoD installations in the state of Georgia, including those sites listed on the Hazardous Site Inventory (HSI). Duties include: review and approval of all work plans and reports which are part of the corrective action processes, conducting Corrective Action Oversight (CAO) Evaluations, modifying Environmental Indicators, and managing workloads & reporting requirements in order to ensure compliance with the DoD and State Memorandum of Agreement (DSMOA) and Cooperative Agreement (CA). Note that underground storage tanks (USTs) at DoD installations will continue to be managed by the UST Program within GA EPD’s Land Protection Branch.

PBC Programs Currently in Georgia Fort Gillem Fort Gordon Robins Air Force Base Horse Pasture Site Hunter Army Airfield MCA Barracks Site Fort Gordon was the first installation in which GFPR was awarded.

Initial Obstacles Associated with Fort Gordon PBC GA EPD Project Manager recently hired into Hazardous Waste Management Branch Complete understanding of state agencies capabilities not understood by contractor or installation Overcoming the learning curve pertaining to GA EPD corrective action guidance/policy Turnover in GA EPD personnel Turnover in contractor personnel

Georgia’s Lessons Learned So Far – Positive Experiences Single contractor PBC contractor is very responsive and highly motivated Ability to diminish learning curve associated with new relationships PBC appears to be better suited for larger scale projects where there is flexibility for the contractor to work with multiple sites or corrective action units The presence of a single contractor simplifies the process, especially if multiple or all of the remedial sites at the installation are under the contract. A single POC with a contractor alleviates the need to communicate with multiple parties. A PBC contractor will be highly motivated to provide quick responses to state comments and will generally achieve results at a faster pace. This is due to the increased profit margin that they will realize based on quick site remediation and closure. A PBC will be more effective if includes a larger array of remedial sites at an installation. The contractor will be more efficiently utilized if they are able to work on multiple tasks during the course of the states review of the required remedial documents.

Georgia’s Lessons Learned So Far – Not So Positive Experiences Difficulty for state in providing same rapid response as contractor (unable to “ramp-up”) Project managers with state agency burdened with increased expectations for a PBC site on top of other duties Contractor has expectations that corrective action review process can be expedited beyond capabilities and or desires of state agency PBC has not included all corrective action activities at the installation There appears to have been expectations that the state project managers and resources could be focused to a PBC project which is not possible, at least in GA. State personnel are assigned many tasks and often have multiple facilities which they oversee corrective action activities. GA has a defined corrective action process which is reflected in most military installations hazardous waste operating permits. GA prefers to maintain the integrity of this process and is very aware of the need to provide written documentation throughout the process so the it is entirely transparent. GA is willing and interested in finding methods to optimize the corrective action process but not at the cost of compromising the permits and state regulations.

Suggestions for Improvements Communicate early on and as often as possible during remedial process. Develop clear understanding of expectations and capabilities of the state agency, the contractor, and the installation. Consider possibility of contractor shifting resources to other projects during course of PBC. Although GA is not able to ramp-up or shift resources as quickly as a private contractor. It appears that the PBC contractor , by nature of their business, can shift resources. If they are unable to stay 100% utilized on a PBC due to state limitations then the contractor should consider assigning other task to their own PBC personnel. GA personnel were not directly involved in the initial PBC development at Fort Gordon and the extent of GA’s capabilities were not clearly understood to all parties. Additionally, the state expectations for the completion of the remedial investigations at the installation were not thoroughly understood or shared. A honest and open line of communication between the installation, contractor, and regulatory agency is critical. Decisions made between these parties during meetings/conference calls should be documented in writing and integrated into the corrective action documents.