From: | Lenny Siegel <lsiegel@igc.org> |
Date: | Thu, 17 Oct 1996 10:49:14 -0700 (PDT) |
Reply: | cpeo-military |
Subject: | EPA ON PERFORMANCE |
From: Lenny Siegel <lsiegel@igc.org> I received the following comments about Peformance-Based cleanup from some people at EPA. The cover note said, "Please excuse the EPA Speak." Lenny __________________________________________ Comment 1: I believe that if we want to do them, performance based systems are doable under the present rules. For example, agreements could reflect investigation complete and construction complete, instead of RIFS report completion or Shakeout Report. RODs can contain contingencies to allow for changes in technology. Finally, most of our ARCs contracts are cost plus award fee. So don't let the buzzwords confuse matters. Take the concepts you like and we can make them work! __________________________________________ Comment 2: I sort of disagree with a few of Lenny's premises, although my position may reflect my being still a bit new to the federal facilities side of things. 1) I believe our agreements already include a balance of both document tracking and performance basis. Very few of us are in pursuit of a "perfect" RI or FS, but rather, look for a "good enough" document as part of the means for getting to the clean up. Of course, there has to be some balance, as the reports provide the analysis to justify why we are doing what we are doing in the way we are doing it. Certainly our national tracking focus has moved much more toward cleanup performance and completion. 2) While I think there is some leeway in going to performance-based RODs, I would really proceed with caution on this. I would argue that the issue here is largely about our attitude about changing RODs. If we have clear and strong justification for changing a ROD, we should be able to do so in about three months without much problem (faster for just an ESD). If it takes longer than this, I would suggest it is because there is something about the change that some interested party considers a bona fide issue, in which case the performance-based ROD clearly would have been even LESS palatable. (If we have assurance that all stakeholders at a site have bought into the performance-based approach, I would be more comfortable, but I think there's still a diversity of positions on this....) There is a matter of degree here, and better use of contingency RODs with well-defined triggers may present some opportunity for compromise. | |
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