MPCA Addresses Brownfield Users' Concerns

This information was recently gathered from a letter from the MPCA

Dear MPCA Brownfield Program User:

As you may know, Minnesota Pollution Control Agency (MPCA) conducted focus groups in 2008 to solicit comments regarding the improvement of the Voluntary Investigation and Cleanup (VIC) Program and the Petroleum Brownfield Program (PBP). The majority of comments received from Brownfields Program stakeholders were related to: Consistency; Communication and Coordination; Fees and Funding; Policy and Program Development; and Leadership Support. MPCA workgroups were formed to address each of these categories of comments. We would like to provide information regarding our progress in affecting change:

Fees and Funding

A team was formed to conduct a survey of other states to find out whether each state Brownfield program recovers its program costs, charges a fee, and the type of fee. The Team also asked whether each state offered reductions or exemptions from the fee. The team selected eight states based on web-based search of the state Brownfield program funding sources, followed by calling those states to ask program staff specific questions about how their program is funded. A spreadsheet summarizing the benchmarking results is available under "What's New" athttp://www.pca.state.mn.us/cleanup/vic.html. We will not be making changes to the program fee structure at this time based on the current state budget situation. Questions or comments regarding the benchmarking effort may be directed to Andrew Nichols at 651-757-2621.

Invoicing

Brownfields stakeholders recommended the MPCA Brownfields Programs provide clients with a detailed monthly invoice. As a step in meeting that goal, the VIC program mailed detailed monthly invoices in early March 2009. The new invoice provides detailed information regarding work completed in January and February 2009, and a summation of past due amounts. Starting in April 2009, detailed invoices will be sent on a monthly basis. Questions regarding the new format of the invoices may be directed to Andrew Nichols, VIC Program, at 651-757-2612. If you believe the invoiced amount is not correct, please contact Jeanne Philipsen at 651-757-2106. Petroleum Brownfield Program invoices are currently being updated. Please contact Chris McLain at 651-757- 2562 if you have questions regarding this effort.

Combined Application Process for Enrollment in VIC and PBP

A combined application form has been developed for the PBP and VIC Programs, and is available for downloading on the web at http://www.pca.state.mn.us/publications/c-vic3-01.doc. The form may be used for enrolling remediation sites in one or both of the Brownfields Programs. Planning is underway that would allow the submission of the combined application form on-line.

In addition to the application, the group has proposed modifications to the Brownfields Web Pages. Both the combined application process and modifications to the web pages are expected to provide significant convenience to program users, better website navigation and increased speed and accuracy of application processing. For additional information or comments on this effort, please contact Stacey Van Patten at 651-757-2425.

Economize, Standardize and Streamline Report Submittals

The objective of this effort is to analyze the various formats in which data and information are submitted to the MPCA for review by the VIC, Superfund and RCRA programs. It is expected that this effort will result in the development of standardized reporting formats for similar phases of project work done under the oversight of these various programs. Having the submittals conform to consistent and standardized formats will facilitate similar streamlining and consistency in the review process and in the results of the MPCA reviews as well. It is expected that a set of consistent outlines will be released for implementation in the summer 2009. For additional information, please contact Doug Wetzstein at 651-757-2819 or Don Milless at 218-316-3861.

Create Standard Formats for Formal Review/Decision Outputs

In order to improve transparency and facilitate communications with stakeholders, the Brownfield Programs and Superfund are working on developing standardized formats for recording the results of MPCA reviews and decisions. Existing templates from the various programs are being reviewed for this purpose and assessed for broader applicability across the programs. It is expected that consistent formats will be developed and implemented by summer 2009. For additional information and comments on this effort, please contact Doug Wetzstein at 651-757-2819

Establish Protocols to Improve Consistency

As a first step to improving consistency in decision making amongst the various programs of the MPCA Superfund Section (Superfund, RCRA, VIC, and Site Assessment), a scheme of regularly recurring site decision review forums has been designed. This is similar to the site decision committee process that is in place for the Petroleum Remediation and Petroleum Brownfield Programs. While the main objective of the site decision committee review process is to evaluate and enhance consistency in the technical aspects of the decisions made, it is expected that aspects such as review timeframes and costs will also be assessed. It is also anticipated that the process will expand in due course to evaluate consistency amongst the Petroleum and Superfund Section Programs. These forums commenced in February 2009 and are proceeding well, with continued refinements in the process to enhance their effectiveness. For additional information and comments on the establishment of the Superfund Programs Site Decision Review process, please contact Doug Wetzstein at 651-757-2819.

Policy and Planning Team

The MPCA Remediation Division has established a Policy and Guidance Team (PGT) to review the proposals for policy and guidance development. The team members are Lynne Grigor from the VIC program, Mark Toso from Emergency Response and Preparedness, John Moeger from the Closed Landfill Program, Adam Sekely from the Petroleum Remediation Program, Susan Johnson from Superfund Program, and Doug Beckwith, Supervisor. A RCRA staff person will be joining the group soon. The Team currently meets monthly to review proposals for reasonableness, program overlap and priority. The Team will prioritize and recommend proposals to the Division leadership. Once approved, a work group will be formed to start development of the policy or guidance.

The PGT will be developing ways for input from outside of the MPCA in the next few months. For additional information and comments on this action item, please contact Doug Beckwith at 218-302-6611.

Create/Release Vapor Guidance

A guidance document for Superfund, RCRA and Voluntary Cleanup Section titled "Risk-Based Guidance for the Vapor Intrusion Pathway" has been completed and posted on the web at http://www.pca.state.mn.us/publications/c-s4-06.pdf. The Petroleum Remediation Program's vapor intrusion guidance, "Vapor Intrusion Assessments Performed During Site Investigations, Guidance Document 4-01a" though not explicitly a component of this improvement project has also been updated, and is available at http://www.pca.state.mn.us/cleanup/pubs/lustpubs.html. Both documents are based on fundamentally the same decision-making framework. A technical support document for the vapor intrusion pathway for the Remediation Division has been drafted and is currently under review by external partners. For additional information, please contact Rick Jolley (Superfund & VIC) at 651-757-2475 or Tom Higgins (Petroleum) at 651-757-2436.

Create/Release Soil Reuse Policy

The soil reuse work group, which consisted of four MPCA staff and four external parties, has completed its brainstorming and discussion of issues surrounding the reuse of impacted soil. A report documenting the work group's efforts has been drafted and is currently under MPCA review. We anticipate posting the final report on the MPCA's website. For additional information and comments on this effort, please contact Amy Hadiaris at 651-757-2402.

Leadership and Morale

In February 2009, a survey designed to measure employee engagement was completed by members of the Remediation Division. Results will be shared with all members of the Division in April, leading to action plans for following up. Milt Thomas, an organizational development consultant with the MPCA, will also be doing interviews with staff.

Michael Kanner, Manager
Superfund, RCRA, & Voluntary Cleanup Section
Remediation Division

Sandeep Burman, Supervisor
Petroleum and Closed Landfill Section
Remediation Division