Measuring Results In Pay For Performance Cleanups

1. Measuring Results InPay For Performance Cleanups Brian Dougherty Florida Department of Environmental Protection

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

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

4. 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. • Provide for verification wells and borings. • Maintain cleanup levels. 3 3 3 3 W ? ? 3

5. Establish The Baseline • This is point from which all progress will be measured. • 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. • Specify analyses and analytes of interest.

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

7. Endpoint Options • Strict resource protection. • High Cost, Clean Site. • Site Specific Levels with monitoring. • 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. • Low cost, short duration. • No assurance if site rebounds

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

9. Corner Gas Station Key Monitoring Wells

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

11. Corner Gas Station Perimeter Wells

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

13. Milestone Measurement

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

15. 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.

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

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