Measuring Results In Pay For Performance Cleanups Brian Dougherty Florida Department of Environmental Protection

Monitoring Cleanup § PFP Milestones l Pre-determined events when payments are made l Usually based on a subset of the data § Cleanup Target Levels l Satisfy state requirements for all contaminants and all media

PFP Milestones § Typical Breakdown l 45% System Startup l 10% Contaminants reduced by 50% l 10% Contaminants reduced by 75% l 10% Contaminants reduced by 90% l 10% Reach CTLs (all media and contaminants) l 15% Hold CTLs and Close Site

3333W??3 Components of Monitoring PFP Cleanup Progress ¬ Establish the baseline. ­ Determine the endpoint. ® Select key monitoring wells. ¯ Specify perimeter wells. ° Calculate milestones. ± Provide for split sampling. ² Provide for verification wells and borings. ³ Maintain cleanup levels.

¬ Establish The Baseline § This is point from which all progress will be measured. l Should be very recent data or first task in PFP agreement, not based on previous data. § Sample several wells to get good snapshot of the site. l Specify analyses and analytes of interest.

­ Determine the Endpoint § Strict Resource Protection. l High cost, long duration but clean site. § Site Specific Target Levels. l Lower cost, shorter duration. l Monitoring period may extend cleanup.

Endpoint Options §Strict resource protection. l High Cost, Clean Site. §Site Specific Levels with monitoring. l Long term monitoring leads to delayed payment. Payment delay causes cost to increase. Natural attenuation not a performance issue. §Site Specific levels with no monitoring. l Low cost, short duration. l No assurance if site rebounds

® Key Monitoring Wells §Milestone measurement points. §Carefully choose a small, representative number of wells. l Consider how you will measure progress. §Clean wells don’t add to information. §Allow for changes if site conditions change.

Corner Gas Station Key Monitoring Wells

¯ Perimeter Wells §Important to make sure plume doesn’t move away. §Keep to a minimum. l More wells may provide more comfort, but at a higher price.

Corner Gas Station Perimeter Wells

° Milestone Measurement §Average of Key Monitoring Wells. l Sensitive to large change in single well. l Less indicative if key wells differ widely in contaminant levels. §CoC Reduction in each well. l Precise measure of progress. l Harder to make progress in well with low contaminant levels. §Mass Reduction.

Milestone Measurement

± Split Sampling §Important for verifying progress and payments. §Require prior notice of any milestone sampling event. §Tie payment terms to agreement between split samples.

² Verification Wells & Borings §Important to confirm site is clean and not just that certain wells are clean. §Withhold final payment pending results. §Allow contractor to split samples.

³ Maintaining Cleanup Levels §Minimum time period (State Requirement.) l Typically 6 to 12 months §Provision for spikes and rebounds. l Resample to confirm? l Require corrective action? l Does monitoring period reset?

Pay For Performance Monitoring §Goal: Pay for Environmental Results. l Measure real reductions in contaminant levels. l Monitor cleanup progress. l Confirm results. §Provide Defined Goals for: l PFP Payments. l Meeting State Standards.