1. RCRA 2020 Vision… A View from a Facility Owner Lloyd E. Dunlap Atlantic Richfield Company, BP

2. our view US EPA’s “a better way” and the 2020 Vision provides a roadmap for land owners, agencies and communities to help redevelop sites Facility owners can attain the RCRA environmental indicators. We need to work with EPA and States towards practical ways of completing Corrective Action There are many tools available to us now that can assist in attaining the 2020 Vision, however, we need to use them

3. a road map to success Up front: Ensure endpoints fit foreseeable end use  We need to understand the site’s stakeholders and other drivers. Communities want these properties back in use  Once EIs are met, remedies can be at work while sites are redeveloped Extract usefulness, benefits and lessons learned from existing regulatory frameworks  RBCA  Brownfield  State Voluntary

4. a road map to success (cont.) Timeframes to attain corrective action need to be realistic, but the traditional process can be cut by 75%. Opportunities include…  Use an expedited process (e.g. State of Illinois)  Use a performance based approach or streamlined Orders (e.g. USEPA Region 5 )  Use a self-certification process (e.g. State of Massachusetts) The CA process needs to cut out the “paperwork shuffle”. We need to force decisions, actions and -- Completion!  Collaborate vs. Advocate  Build Trust

5. tactics Embrace Brownfield Initiatives  Ensure there is an effective institutional controls program  Support financial incentives for redevelopment  Promote networks to bring together facility owners, developers, banks, agencies, governments, consultants and communities Create an environment for success. Set clear objectives and a timeline for achieving milestones  Reward agency staff for attaining milestones  Create disincentives for “paralysis by analysis”  Reward facility owners for attaining milestones  Ensure fair and consistent enforcement

6. tactics (cont.) Ensure the points of compliance:  are based on risk to receptors (e.g. Sugar Creek, MO), or  apply a groundwater management zone concept (e.g. Wood River, IL) Separate remedies, completion and institutional controls by media  Soils  Groundwater Parceling:  Meets redevelopment needs  Efficient use of resources  Faster cleanup

7. a solution for operating sites Define “complete” from RCRA Corrective Action whenever the environmental indicators for human health and groundwater control are attained Future operations, monitoring and maintenance as well as groundwater cleanup requirements to be folded into a single multi-media (air, water, waste) operating permit for the site, to be renewed every 5-10 years At time of plant closure, the operating permit terminates and a new remedy will have to be negotiated

8. issues & opportunities  How clean is clean?  Institutional Controls  Technical Practicability  “Best” Technology  Operating sites  Parceling (large sites)  Groundwater cleanup  Will legislation be required?  States Authority  EPA Enforcement  Modifications of orders and permits  Costs/Resources

9. parting words The 2020 Vision will not be attained unless the agencies and industry change their current practices There are a number of tools and cutting edge programs available to us now which will allow us to attain our goals Don’t wait. We need to implement the programs and focus our attention now Together we can attain our vision for the benefit of the public and the environment