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

2. 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.

3. ...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

4. 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.

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

6. 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.

7. 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.

8. 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

9. 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.

10. 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.

11. 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.