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RBCA TALK Vol. 2., no. 1 May 1996

FEATURE ARTICLE

Partners In RBCA Implementation (PIRI) Memorandum Of Understanding Signed

On March 14, 1996, EPA held a press briefing to announce the signing of a Memorandum Of Understanding (MOU)--a document that sets forth the objectives of PIRI (Partnership In RBCA Implementation) and the responsibilities of the participating members (the Partners). (In the MOU, "partners" and "partnership" do not mean a legal entity; rather, they refer to the cooperative relationship of the participating parties.) The four groups in the partnership are:

Industry representatives who signed the MOU are:

The purpose of PIRI is to make sure that any interested state UST program receives RBCA training and assistance in the design and implementation of a RBCA process.

Funding

Two distinct funds support PIRI--a Cooperative Agreement and a Private Sector Account. EPA established a Cooperative Agreement with ASTM to provide RBCA training to state and tribal UST programs. The industry--Amoco, BP, Chevron, Exxon, Mobil, and Shell--created the Private Sector Account to provide funds to ASTM. EPA and the six industry Partners each contributed at least $100,000. Other parties that contributed funding, technical assistance, or other support include Unocal, the American Petroleum Institute (API), and the Petroleum Marketers Association of America (PMAA). Other members of the private sector (e.g., insurance companies, real estate associations, the environmental banking association) are also eligible to participate and/or add funds to the ASTM Private Sector Account.

Structure

Each of the four groups of members has distinct responsibilities. ASTM develops training materials and provides certified trainers to regulators to help them understand the RBCA processes. EPA coordinates with state agencies, manages the Cooperative Agreement, serves as a communications focal point, and provides EPA employees to conduct some of the training. The Industry Partners provide technical expertise/perspective (e.g., demonstration sites and peer reviews of implementation documents). State regulatory Partners provide local regulatory perspective and enhance communications with other state regulators. PIRI will have an organizational life of at least 3 years, the current time frame of the EPA Cooperative Agreement.

 

Strategy Of The Partnership

In order to reach its goals, PIRI will:

Partners' Responsibilities

All Partners must have contributed $100,000 and signed the MOU. In addition, an Industry Partner must agree to support the implementation effort of at least one state in which it has no or minimal assets. Only Partners are eligible for the key stakeholder role. Those among the initial group of Partners are recognized as "Founding Partners." Partners vote on key stakeholder assignments, inclusion of future Partners to PIRI, and other issues re-quiring a decision or joint action of the Partnership. All decisions of the Partnership must be unanimous, and states must agree to key stakeholder decisions.

Technical assistance contracted for a state under the PIRI umbrella must be provided in accordance with the Partnership's technical support request process. Any Partners' efforts under the PIRI umbrella must be focussed on the UST program. Partners wishing to provide support to other waste programs must do so outside of the PIRI framework; any coordinated effort credited to PIRI (using PIRI funds) must be on behalf of an UST program.

ASTM's Role

ASTM (the American Society for Testing and Materials) is a not-for-profit professional society founded in 1989. It is the largest organization in the world devoted to developing and publishing voluntary, full-consensus standards. With participation from EPA, states, and industry, the ASTM Subcommittee on Storage Tanks E50.01 developed a standard entitled Guide for Risk-Based Corrective Action Applied at Petroleum Release Sites [E-1739-95]. ASTM and the subcommittee members, including EPA, have also developed tools and a training program to help UST implementing agencies both understand the concepts of risk-based decision making and the ASTM standard and use them to implement their own RBCA processes.

Key Stakeholder And (Other) Stakeholder Roles

As defined by PIRI, the roles of key stakeholders and stakeholders are somewhat different. Key Stakeholders are PIRI Partners who coordinate the effort to provide requested support to a state; they are not ASTM or State Regulator Partners. Stakeholders can be any party (e.g., major oil company, owner/operator, consulting firm, environmental group) interested in participating in and supporting any state's RBCA training and implementation effort. Stakeholders may, but are not required to, contribute funds to the effort and are not considered to be official Partners or voting members of the Partnership. A copy of the list of key stakeholders and their assigned states that was distributed at the National Conference in Chicago is in Exhibit 1.

Actions To June 1, 1996

PIRI planning meetings were held in mid-April and mid-May. The May meeting focused on a review of draft "issue papers" developed to provide insight on various approaches employed by states to address policy impediments (e.g., off-site contamination) to RBCA. State regulators are always welcome at PIRI meetings. If you are a state regulator and would like to attend a meeting, please call Bob Greenfield at 703 603-7154.

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State News

The following sections include a mixed bag of details from states' RBCA development efforts.

OKLAHOMA

Proceeding on a Fast Track Toward Implementation: The Oklahoma UST/LUST program distributed the second draft of its RBCA guidance document and is awaiting comments prior to the next Oklahoma Stakeholders Workgroup Meeting scheduled for June 3, 1996 in Oklahoma City. The program anticipates that RBCA will become effective on July 1, 1996 with full implementation being approximately 60 days later to allow adequate time for required training. The program is currently assisting in the development of four separate training courses that will be pre-approved as complying with Oklahoma's training requirements. To date, all courses seeking pre-approval have been associated with Oklahoma State University and the University of Oklahoma. Oklahoma has a certification program that will require a minimum of 24 hours of training in RBCA (8 of which must be hands-on software training) for consultants submitting corrective action reports.

Oklahoma is also finalizing development of its Oklahoma Tier 2 software package. This software, which will be available to the consulting community on disk for about $40, will also contain the RBCA worksheets required to be submitted with reports. Thanks to Oklahoma's key stakeholder, Shell Oil Company, and the EPA cooperative agreement, Dr. Atul Salhotra was able to assist Oklahoma in its development of RBCA rules and guidance. Says Mark Carl, "We wouldn't be where we are today without PIRI and its supporting resources and expertise."

The UST/LUST program worked with PIRI to establish the Oklahoma Stakeholders Workgroup. The state provided Shell Oil Company with names and phone numbers of key individuals and organizations who were going to be either directly or indirectly affected by RBCA implementation (e.g., certified UST consultants, tank owners, insurance companies, realtors, bankers, Oklahoma Water Resources Board, and Oklahoma Department of Environmental Quality). Shell Oil Company then took the lead to contact and assist in the coordination of the first meeting held on March 8, 1996. For more information, contact Mark Carl at 405-522-4639.

IDAHO

Guidance Manual Near Completion: Since March 1995, the Idaho Division of Environmental Quality (IDEQ) has been implementing its RBCA Guidance Manual for Petroleum Releases. Several drafts of the document have been produced. Demonstration projects at seven tank sites, which have been in progress since August 1995, are utilizing the draft manual. In March 1996, IDEQ distributed a draft to over 100 stakeholder individuals and groups for review and comment. Then the program held three statewide workshops to explain the proposed policies and procedures in the guidance along with general background information on risk assessment principles, the ASTM standard, and available tools and training opportunities. Agency staff, an ASTM trainer, and Mark Malander of Mobil Oil Co. (the PIRI key stakeholder for Idaho) all made presentations. After it considers written comments and workshop discussions, IDEQ expects to complete the final guidance manual (including customized software and woksheets) by early this summer. Workshops that will focus on implementation of the guidance using the software and worksheets are also planned for this summer. For more information, call Bruce Wicherski at 208 373-0246.

IOWA

RBCA Software Under Development: Iowa's Department of Natural Resources (IDNR) has contracted with Iowa State University to develop RBCA software for IDNR staff and Iowa's contractors and consultants to use in conducting RBCA analyses at LUST sites. All of the policy decisions were made by a technical advisory committee comprised of key public and private stakeholders. These decisions were made during and subsequent to Iowa's module 3 training; they are being incorporated into the state-specific software which will be made available to all certified groundwater professionals. Iowa expects that the beta-copy of the software should be available by August 1996. For more information, call Patrick Rounds 515 284-1616.

MICHIGAN

Michigan is in the process of customizing a computer software spread sheet to incorporate all Michigan- specific Tier 1 generic exposure assumptions. This will assist Michigan Qualified Consultants in evaluating alternate exposures which would be equally protective in the application of Tier 2 and Tier 3 evaluations. Shell Oil Company has taken the lead in working with Michigan staff with support of Amoco Oil Company and Mobil Oil Company to work with Groundwater Services Inc. to develop the computer spread sheet. Also being developed is an analytical groundwater model to be used as a screening tool to better evaluate groundwater site conditions and future remedial alternatives.

 

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Other News

CLU-IN

CLU-IN, EPA's electronic bulletin board system, now has over 8,000 registered users, including participants from all 50 States. (See the June 1995 issue of LUSTLine for basic information about CLU-IN, including the procedures for logging in.) OUST maintains a library of RBCA-related documents (including past issues of RBCA talk, PIRI updates, and state guidance documents) on CLU-IN. Many of these files can be viewed while on-line, and all can be downloaded to your hard disk. To access CLU-IN, you need a modem (2400 baud or faster), telecommunications software (e.g., Crosstalk, Procom), and a PC. The dial-in number is 301-589-8366. Communications parameters are 8 data bits, 1 stop bit, and no parity. Once logged in to CLU-IN, "JOIN" Special Interest Group (SIG) #3--UST/LUST. From there, display the files in File Directory #7--Risk.....If you need assistance accessing CLU-IN or locating and downloading files, call Hal White (703-603-7177). For comments or suggestions on available materials, or to arrange to make your documents available on CLU-IN, call Bob Greenfield (703-603-7154). Here is a list of the new arrivals to the directory:

* PIRI MOU document - AGREEMNT.FNL

* Status of national RBCA training initiative - APR11SUM.WPD

* Hawaii's RBCA policy/guidance document (zipped) - HI-RBCA.ZIP

* List of PIRI Key Stakeholder assignments - KEYSTAKE

* OUST leaflet containing background information on RBCA - LEAFLET.WPD

* RBCA Case Study #2 on Michigan's training effort - MICASE.W51

* Notes from 2/6/96 PIRI meeting in Virginia - PIRI0206.TXT

* Notes from 3/14/96 PIRI meeting In Virginia - PIRI0314.TXT

RBCA CASE STUDY

OUST issued its second in a series of RBCA Implementation Case Studies. The case study on Michigan's effort to train the state's consultants and contractors can be obtained by accessing CLU-IN (MICASE.W51) or contacting an EPA RBCA contact. OUST will be working on additional case studies and would welcome information on subjects. Contact: Bob Greenfield (703) 603-7154.

 

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And finally....

OUST could use your help in identifying issues and impediments encountered during your RBCA implementation efforts. If you have items for the next issue of RBCA Talk, or if you have any comments or recommendations, please contact Bob Greenfield, OUST at (703) 603-7154, fax (703) 603-9163, or send a message via the CLU-IN Bulletin Board, UST/LUST Special Interest Group (SIG).

EXHIBIT 1

Tentative List Of Key Stakeholders (Pending Approval By States)

Amoco Colorado Total: 9 States

Florida

Illinois

Iowa

Minnesota

Nebraska

New Jersey

Utah

Wyoming


BP Alaska Total: 8 States

Alabama

Ohio

Georgia

North Carolina

South Carolina

South Dakota

Tennessee


Chevron Arizona Total: 8 States

Hawaii

Kentucky

Nevada

New Mexico

North Dakota

Washington

Oregon


Exxon Louisiana Total: 6 States

Mississippi & PR

Montana

Pennsylvania

Puerto Rico

Washington, D.C.

West Virginia


Mobil Idaho Total: 9 States

Maine

Maryland

Massachusetts

New Hampshire

New York

Vermont

Virginia

Wisconsin


Shell California Total: 8 States

Connecticut

Delaware

Indiana

Missouri

Oklahoma

Rhode Island

Texas


EPA Arkansas Total: 3 States

Kansas

Michigan


PIRI Key Stakeholder Contacts

Amoco Corp. -- Geoffrey Gilman

Shell Oil Co. -- Wayne Hamilton

Chevron Products Co. -- Jeff Hartwig

Mobil Oil Corp. -- Mark Malander

British Petroleum -- Jim Rocco

Lesley Hay Wilson

Exxon -- Len M. Racioppi

Note: Call your EPA Regional RBCA Contact to get in touch with your PIRI Key Stakeholder.

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