United States
Environmental Protection
Agency
Solid Waste and
Emergency Response
(5106)
EPA505-B-00-001
March 2000
www.epa.gov/swerffrr/
F3ft In Progre.
EPA Update on Federal Facility Cleanup and Reuse
Community Relations
Plan Wins Praise
Celebrating
Success
A
Lre you aware of the cleanup effort underway at Fort Pickett? What would
be the best way to keep the community informed? These are just two of
Ithe questions posed to community members as part of the development
of the Community Relations Plan (CRP) for the cleanup efforts recently initiated
at Fort Pickett in Blackstone, Virginia. By soliciting input early in the cleanup
effort, the plan's creators directly addressed the community's needs and helped
establish a positive relationship between cleanup officials and the local communi-
ty. U.S. Environmental Protection Agency (EPA) Region 3 staff believe the Fort
Pickett CRP is "one of the most comprehensive and thorough" they've seen, and
they plan to use it as a model for other federal facility cleanup projects.
Designed to facilitate communication among the Army, public officials, residents, the media,
and other interested parties, the Fort Pickett CRP was based on input obtained during interviews
with local residents and community leaders. Twenty-eight local residents were interviewed by phone
and in person in August 1998, including representatives of city government, businesses, environ-
mental groups, and community leaders. Most of these individuals live within two miles of the base.
Interview respondents answered questions in three categories, including general community-related
questions, questions specific to Fort Pickett, and questions about community relations. Information
New Guidance Will Help Bring Closure
BreakingNews
w;
hen the Air Force Base Conversion Agency (AFBCA) was nearing
completion of the remediation phase for some of its Superfund
national priority list (NPL) sites and Base Realignment and Closure
(BRAC) installations, it wanted to ensure correct and legal procedures for final site
closeout. While remediation plans were well underway at several bases, none had
reached the point of closeout yet. The cleanup teams for these sites began looking
for guidance on how to proceed. While they discovered various closeout instruc-
tions, there was no single source of information on closing out an environmental
remediation site at federal facilities.
This discovery planted the seed for the development of the Environmental Site Closeout
Procedures for National Priorities List Sites and BRAC Installations, a comprehensive source of
requirements for closeout of environmental restoration sites at military facilities. This guidance
document was designed by a working group comprised of representatives from each military
branch, the Office of the Secretary of Defense, the U.S. Department of Defense's (DoD's) environ-
mental office, EPA, and the California and Illinois environmental protection agencies. The group
Federal Cleanups That Put Citizens First
-------
A Decade of Progress in Cleanup
Of Federal Facilities
n eafly December 1999, I had the fortune of
I attending a meeting of the People of
I Color/Disenfranchised Community
(POC/DC) Environmental Health Network. As
we mulled over the federal responses to 16
POC/DC requests for environmental assistance,
I was struck by the thought that ten years ago
we could not have had such a meeting and as
little as five years ago, if we would have had
such a meeting, it would have been fairly contentious. Now
I was sitting in a crowded EPA conference room in Crystal
City, Virginia, with federal officials, environmental justice
advocates, ministers, tribal representatives, and other
activists, cooperatively working toward finding common
solutions to environmental and health problems in affected
communities. What's more, there was a general recognition
that we needed to enlarge the circle to bring in more people
and resources to provide more and better solutions. This
meeting and all that came before it are evidence of the
progress we have made.
The 1990s witnessed considerable progress in federal
facility cleanup. Just before the decade started, we witnessed
what might have been one of the lowest points in federal
environmental stewardship with the Federal Bureau of
Investigation raid on the U.S. Department of Energy
(DOE) Rocky Flats facility. More than any other, I think
that event provides us with a reference point to assess how
far we've come.
The decade started with the phrase "decide, announce,
and defend" when it came to federal facility cleanups. As it
ends, words like "partnering" and "collaboration" describe
the general cleanup approach. Cleanup methods and federal
agencies' relationships with states, local governments, tribes,
and various affected communities are improved overall. Of
course, not all facilities or programs have made the same
progress. We see problems from time to time but compared
to a decade ago, the difference is considerable. Our collective
task, however, is still very much a "work in progress" and we
must continue to build on and learn from our successes and
failures.
People began to recognize the potentially tremendous
cleanup workload at federal facilities in the late 1980s and
early 1990s. Few had a good sense of the magnitude of the
challenge, but most intuitively understood it to be over-
whelming. At that time, EPA was in the process of adding
more than 100 federal facilities to its Superfund National
Acronyms Explained
AFBCA Air Force Base Conversion Agency
BCT BRAC Cleanup Team
BRAC Base Realignment and Closure
CERCLA Comprehensive Environmental Response,
Compensation, and Liability Act
CRP Community Relations Plan
DoD U.S. Department of Defense
DOE U.S. Department of Energy
DU Depleted Uranium
EPA U.S. Environmental Protection Agency
ETV Environmental Technology Verification
FFRRO Federal Facilities Restoration and Reuse Office
GPRA Government Performance and Results Act
HUD U.S. Department of Housing and Urban Development
IAP2 International Association for Public Participation
NPL National Priorities List
POC/DC People of Color/Disenfranchised Community
RAB Restoration Advisory Board
RCRA Resource Conservation and Recovery Act
SSAB Site-Specific Advisory Board
TSCA Toxic Substance Control Act
UXO Unexploded Ordnance
Partners In Progress
Philosophy
Stakeholders involved in federal facility cleanups
are diverse, with differing backgrounds, interests,
and perspectives. All of these stakeholders, how-
ever, share a single common goal—progress.
Partners In Progress (PIP) provides an open
forum for stakeholders to exchange information,
offer solutions, and share stories about what
works and what doesn't. We encourage you—our
readers—to write to us about your activities that
foster teamwork, promote innovation, and
strengthen community involvement. Only by
working together can we achieve "federal
cleanups that put citizens first."
positions, or po
licies of the As
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Priorities List (NPL). Few will recall the first EPA federal
facilities office in existence at that time, the Federal Facilities
Hazardous Waste Task Force in the Office of Waste
Programs Enforcement. The 1994 reorganization of EPA
lead to the creation of the two current offices focusing on
federal facilities, (FFRRO and the Federal Facilities
Enforcement Office [FFEO]). Over the same time
frame, many EPA regional offices created their own
individual units, sections, or branches to focus on
the cleanup of federal facilities.
The last decade has experienced many signifi-
cant events and achievements. From my perspec-
tive, the 1993 Interim Report and later 1996 Final
Report of the Federal Facilities Environmental
Restoration Dialogue Committee (also known as the
"FFERDC Report") was the most significant. The
significance is not only in the report's "Principles
and Recommendations" for improving federal facil-
ity cleanup, which are now being implemented,
but also in the dialogue process itself which
brought together individuals with a diversity of perspectives
and experiences. It forged a foundation for building cooper-
ation and trust. The relationships and friendships developed
during the FFERDC process have helped us find solutions
to issues that have arisen since the reports publication. It has
proven to be a document we can return to for guidance
when facing tough issues and it has really changed for the
better the way the federal government works.
Also noteworthy is the 1995 Report of the Federal
Facilities Policy Group on Improving Federal Facilities
Ckanup. This report was the Executive Branch's first system-
atic recognition of the environmental cleanup challenge on
federal lands. The report recognized the legacy of the cold
war and past failures of federal facilities to protect the envi-
ronment. It remains the only report to include an estimated
funding requirement for complete cleanup of federal govern-
ment sites. Though many were initially shocked at the $234
to $389 billion estimate, that figure may have been an
under-estimate as it did not account for cleanups that may
be required for closed, transferring, and transferred military
ranges, formerly-owned contaminated federal properties,
and natural resource damages.
A third major achievement was the passage of the
Federal Facilities Compliance Act in 1992, which amended
the Resource Conservation and Recovery Act (RCRA) and
waived sovereign immunity for violations of the hazardous
waste statute. It also addressed mixed waste issues and
required the promulgation of regulations on unexploded
ordnance.
From the perspective of Superfund cleanup, we have
made tremendous progress. A decade ago, toxic waste sites
on federal facilities were still being discovered and character-
ized. Compared to work at private sites, federal facilities
lagged behind in remediation. That changed in the 1990s
with a rapid evolution in cleanup programs. Many federal
facilities are now in the design and construction phases of
cleanup. The profile of work at the NPL sites dramatically
underscores this progress.
1990
Projects (end of year)
Proposed/Final NPL Sites
Ongoing Remedial Investigation/
Feasibility Study projects
Ongoing Remedial Design projects
Ongoing Remedial Action projects
All Remedial Action Projects Completed
NPL Deletions
121
275
17
13
0
0
1999
(end of year)
165
477
76
204
23
9
But where do we go from here? As the FFERDC report
notes, the relationships among regulated agencies, the regu-
lators, and affected communities are tenuous and fragile. As
in most relationships, when money gets tight, tension tends
to increase. Federal fiscal constraints pose a tremendous
challenge to maintaining our current pace of progress
toward completing site cleanup. New contaminated sites are
being discovered and new challenges are emerging. To con-
tinue the core cleanup work at federal facilities, the federal
government must find solutions to the new challenges on
the horizon. The principal challenges that I see are:
• Addressing closed, transferring, and transferred
military ranges.
• Continuing to improve community involvement in
all phases of cleanup and reuse efforts with a focus on
environmental justice communities.
• Building a viable program across all federal agencies
for "long-term stewardship" of the cleaned up sites to
ensure continued protection of human health and the
environment.
• Addressing contaminated formerly-owned federal
properties.
• Putting contaminated federal properties to
productive reuse.
• Addressing contamination at the non-DoD, non-
DOE federal facilities.
I am looking forward to building on the foundation we
have put together and working with all the parties that share
an interest in solving these and other, yet to be discovered
challenges. It will take our collective talents to come up with
workable solutions. EI3
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Improving the Practice of Public Participation
By Martha A. Rozelle
The International Association for Public Participation
(IAP2), a nonprofit corporation, is committed to
improving decision-making processes by promoting
public participation and making it more professional.
Established in 1990, IAP2 takes a leadership role in estab-
lishing high standards for public processes by developing
and sharing personal values, and it is the most comprehen-
sive source of information, tools, and training needed to
improve decisions that affect the public.
IAP2 has more than 1,000 members from 25 countries
and all levels of government and industry, including electric
utilities, industry, engineering and environmental consulting
firms, law enforcement, health care, and public participation
practitioners. Last year, IAP2 entered a partnership with
EPAs Federal Facilities Restoration and Reuse Office
(FFRRO) to help foster improved public participation in
federal facility cleanups. Marsha Minter, FFRRO's
Community Involvement National Program Manager, was a
member of IAP2's Board of Directors for 1999.
In its leadership role, IAP2 has defined a set of core val-
ues that its members use to guide the development and
implementation of public participation processes. These core
values were developed over a two-year period with broad
international input and have been adopted by other entities,
such as the National Environmental Justice Advisory
Council. These core values ensure that the interests and con-
cerns of potentially affected people and entities are reflected
in decisions. The core values are:
1. The public should have a say in decisions about actions
that affect their lives.
2. Public participation includes the promise that the
public's contribution will influence the decision.
3. The public participation process communicates the
interests and meets the process needs of all participants.
4. The public participation process actively seeks out and
facilitates the involvement of those potentially affected.
5. The public participation process involves participants in
defining how they participate.
6. The public participation process provides participants
with the information they need to participate in a
meaningful way.
7- The public participation process communicates to
participants how their input affected the decision.
Decision-makers, public officials, and the public can
achieve mutual expectations by treating each other with
respect and by recognizing the IAP2 core values in the
design of public participation processes. FFRRO intends to
incorporate these values into its own participation planning.
By showing stakeholders that they do have a voice in matters
that concern them and that their concerns will be taken into
consideration in decision-making will improve trust and
communication—vital ingredients to successful public
participation. IJIJ
Martha A. Rozelle, Ph.D., is the president ofIAP2. She is
also the president of a participatory decision-making consult-
ing firm, The Rozelle Group, Ltd., in Phoenix, Arizona. For
more information about IAP2 or to karn how to become a
member, visit the program's Web site at .
A Risk Management Approach for UXO
Over the past four years, FFRRO has been involved in
the development of the U.S. Department of Defense
(DoD) Range Rule and related supporting activities.
Critical to the success of the Range Rule (and EPAs concur-
rence) are the ongoing efforts to develop a risk assessment or
risk management approach. This effort, now in its third year,
will yield a much different approach for addressing military
munition and unexploded ordnance (UXO) risks at closed,
transferred, or transferring ranges than is currently in use.
Initially, DoD developed an approach that was very
quantitatively driven. Given the wide application the
methodology would have, EPA urged DoD to create a part-
nering team comprised of representatives from EPA, states,
tribes, and other federal agencies and stakeholders. Originally
formed in 1997, the partnering team today involves approxi-
mately 40 individuals and combines insights from both DoD
and non-DoD parties. The overall approach has evolved
toward more qualitative risk management, recognizing the
uncertainty involved in the detection and clearance of UXO.
The Range Rule Risk Methodology will be the subject of a
comprehensive article to appear in a future issue of
Partners In Progress. QH
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Community Relations Plan
obtained from the interviews included the community's cur-
rent awareness level about the cleanup, primary sources of
information on community news, and specific types of
information they would like to receive about the cleanup
.activities.
The Fort Pickett CRP outlines specific community rela-
tions activities and a time line for implementing these activi-
ties. Several of the activities relate directly to the interview
responses. The plan, for example, calls for the BRAC
cleanup team (BCT) to make presentations to local civic
organizations highlighted by respondents. To make the CRP
more useful to the community, it includes contact informa-
tion for all the BCT and Restoration Advisory Board (RAB)
members as well as other pro-
ject contacts, including local
media, Fort Pickett contacts,
elected officials, and area clubs
and organizations.
The BCT for Fort Pickett
initiated the CRP in July
1998, and it was completed by
September 1998. The BCT is
comprised of representatives
from the Army Corps of
Engineers, EPA Region 3, and
the Virginia Department of
Environmental Quality. The
BCT members expressed their
desire for a thorough CRP to
the contractor who prepared
the plan. They conveyed the
specific components they
wished to see in the plan, one
of which was the need to solic-
it the community's input prior
to the plan's development. In
addition, the BCT provided
feedback on the interview
questions when they were in
the draft stage. As a member
of both the BCT and the
RAB, EPA was instrumental in
creating an exemplary plan.
EPA Region 3 staff assisted in
conducting interviews. In
addition, staff took the initia-
tive and asked RAB members
for their recommendations for
respondents. This resulted in a
well-balanced pool of commu-
nity members.
Fort Pickett, located in a rural area of southern Virginia, operated
mainly as a combat training facility from its creation until it was
designated for realignment in 1995. Restoration efforts began in
1996. Current cleanup efforts are focused on a 3,500-acre area of
the base that is being readied for transfer to the Local
Redevelopment Authority. Approximately 95 percent of these
3,500 acres were found to be free of environmental concerns and
suitable for transfer and/or lease. Cleanup activities for the
remainder of the affected area are currently in the remedial
investigation phase.
Shell casings like those pictured above were
recently cleaned up from an area under investi-
gation at Fort Pickett. More than 8,000 shell cas-
ings were found. According to the Army Corps of
Engineers Huntsville District, some of the shells
showed evidence of residual contamination and
need to be detonated and rendered residue free
prior to disposal at a recycling facility.
Before the CRP was developed, community involvement
in the Fort Pickett cleanup consisted primarily of participa-
tion in the RAB meetings. Public notices were placed in area
newspapers before each meet-
ing, and meeting minutes and
agendas were mailed to
approximately 60 interested
parties before each meeting.
The CRP interview responses
indicated a particular newspa-
per in which to put meeting
notices and expanded the
mailing list to 125 persons.
Also, it proved to be an excel-
lent way to raise awareness
about the cleanup efforts
since participants were briefed
on the project in conjunction
with the interview.
Two 55-gallon drums containing unidentified
substances. These drums were sampled, properly
characterized, and disposed of.
EPA staff believe that
because the CRP was devel-
oped in the early stages of the
cleanup effort, the BCT can
address any concerns that may
arise more effectively. Indeed,
few concerns are anticipated
precisely for this very reason.
Due to its comprehensiveness,
simplicity, and incorporation
of community opinion, EPA
Region 3 plans to use the Fort
Pickett CRP as a model for
other cleanup projects.
To learn more about the
Fort Pickett Community
Relations Plan, contact Don
Mclaughlin of EPA Region 3
at 215 814-5323. EH
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Five-Year Review Guidance
People often think that once a cleanup action is in
place at a contaminated site, the work is done. But
remedy selection is only the first step in making a
closed, transferred, or transferring federal facility safe for
human exposure. In order to ensure that a cleanup remedy
eliminated the contamination or is still working to protect
human health and the environment, the participants must
conduct a five-year review. A review is an on-site inspection
of remediation activities that includes testing contamination
levels. While it sounds like an easy process, it can be diffi-
cult to determine who conducts the review, when the review
should take place, and what actions should be taken as a
result. New guidance developed by EPA and slated for
release in April 2000 helps clear up that confusion.
EPA has defined two types of five-year reviews at all
National Priority List (NPL) sites: statutory, meaning it is a
mandatory action required by the Comprehensive
Environmental Response, Compensation, and Liability Act
(CERCLA), or policy, meaning that it is required by EPA
policy. Both, however, may be conducted at any federal
facility site where 'the President' (i.e., EPA or delegated fed-
eral agencies acting on the President's authority) has selected
CERCLA remedial actions that leave waste in place at levels
that do not allow for unrestricted use, to ensure that cleanup
actions are working as planned (i.e., remain protective of
human health and the environment). But how does a pro-
ject manager know what type of review is needed and when
it should be given?
"It sounds like it should be routine, but it's not some-
thing that can be summarized in one sentence," explained
Mark Stephens of EPA Region 3. "There are some complex-
ities to the who, what, when, and why." Answers to these
issues, however, can be found in a new Five- Year Review
Guidance. Stephens was one of the collaborators on the
effort, working primarily on a chapter defining roles and
responsibilities of the various parties involved in a CERCLA
cleanup.
Carol Bass of the Office of Emergency and Remedial
Response, headed the five-year review team. Not only did
the team collect and compile previous guidance, but they
also worked to eliminate contradictions in earlier docu-
ments, defined terms, and clarified ambiguous or confusing
information.
"It really was a multioffice effort," said Bass. "We needed
expertise from several EPA offices." After many months of
refining the text, the document is currently under review by
federal agencies, including the Department of Defense
(DoD), the Department of Energy (DOE), the Department
of Justice, the Agency for Toxic Substances and Disease
Registry, as well as states and tribes.
Guidance Features
The purpose of five-year reviews is to determine whether
a remedy is or is expected to be protective, to document any
deficiencies identified during the review, and to recommend
specific actions to ensure that a remedy will be or will con-
tinue to be protective.
Who?
The guidance goes into great detail as to who should
conduct the review. For federal facilities, this is determined
by the site-specific conditions: such as whether the site is a
NPL site; whether the site is a DoD, DOE, or Coast Guard
site; whether there is a federal facilities agreement (FFA) in
place; and if there is an FFA, what does it say. In many
cases, EPA has some role in the review.
What/When?
Once it is determined who will conduct the review, it is
necessary to identify the kind of review needed. A statutory
review is required for those sites that upon completion will
leave contamination in levels higher than those allowable for
unlimited access or use. These reviews are conducted no less
than every five years based on the start date of a remedial
action. EPA policy reviews are required for a number of
other sites based on the guidance. These reviews take place
no less than every five years based on the construction com-
pletion date of the remedy. The guidance also addresses
CyberNews
www.epa.gov/etv/
Managed by EPA's Office of Research and Development, the
Environmental Technology Verification (ETV) Program was created to
accelerate the introduction of new environmental technologies into the
domestic and international marketplace. The program's Web site explains
the process through which these new technologies are verified, including
pilot projects in development and testing events. This site also contains
the list of technologies verified and the ETV quality management plan,
tal and private sector participants in the ETV program. ETV articles and
press releases, links to partners and related Web sites, state and regional
outreach activities, and a list server are also available.
-------
other situations, including what is required if there are
RCRA actions or deferrals involved; monitoring, monitored
natural attenuation, institutional controls, 'no further action',
or multiple operable units.
How?
Finally in addition to planning the review, forming a
team, and compiling data, a reviewer needs to ask several
questions to determine the protectiveness of the remedial
actions at a site. The three primary questions are:
• Is the remedy functioning as intended by the deci-
sion documents?
• Are the assumptions used at the time of the remedy
selection still valid?
• Has any other information come to light that could
call into question the protectiveness of the remedy?
Depending on the responses to these questions, several
followup questions reviewers should ask also are included in
the guidance document.
The guidance is accompanied by a five-year review report
template, a sample report, and a site inspection checklist.
"The samples allow someone who's never conducted a five-
year review to get a good idea of what information is needed
and what a finished report should look like," Bass said.
Finalizing the Guide
Bass and her team will carefully review the other agen-
cies' comments, responding to each and deciding how to
incorporate them into the guidance. "This is a document
that people really need. They're looking forward to its
release," Bass said. "It's been a lengthy process but it has been
well worth the effort."
The finalized guidance will be released in April 2000.
For more information on the Five-Year Review Guidance,
e-mail Carol Bass at .
Community Involvement
On the Web
In keeping with its commitment to public participation, the
Federal Facilities Restoration and Reuse Office (FFRRO)
unveiled its new Web page dedicated to community
involvement. Located within the office's main site at
, the new page is divided into several
topics containing information on the Federal Facilities
Environmental Restoration Dialogue Committee, Restoration
Advisory Boards and Site-Specific Advisory Boards, public
forums and workshops, tribal nations, environmental justice,
state and local government, environmental restoration issues,
and FFRRO partnerships.
The community involvement site is still being developed
according to Jeff Stinson, FFRRO's acting Internet coordina-
tor. Phase 1, which is currently available on the Internet, went
online in November 1999. Phase 2 will include interactive
components such as community and site-specific forums in
which stakeholders, project managers, advisory board mem-
bers, and others can exchange information and suggestions for
facility cleanup. This portion of the site is expected to go
online in the near future. Stinson encourages readers to view
the site at
and send their comments by e-mail to
.
www.afbca.hq.af.mil
The Air Force Base Conversion Agency (AFBCA) is committed to making sure that closing
and realigning Air Force installations are cleaned up and made available for reuse as quickly
and efficiently as possible. The agency's Web site helps further this mission by providing visi-
tors with progress reports, newsletters, fact sheets, and training materials. The online version
of the Base Conversion Handbook helps personnel understand how their individual efforts
directly contribute to the overall conversion process and helps communicate the AFBCA's
mission, roles,
and those in affected communities. Base Realignment and Closure (BRAC) contact informa-
tion and site-specific data might also be of particular interest to Air Force base stakeholders.
The site also contains general regulations, guidance, and other information applicable to all o
the U.S. Department of Defense's (DoD's) BRAC sites.
--
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EPA and DoD Approve Field Guide
On Lead-Based Paint
by Monica L. McEaddy and Sandra Cotter
^^^™he main objectives of any action implementing a
Defense Base Closure and Realignment Commission
(BRAC) recommendation are to eliminate threats to
human health and the environment that might be present
on the closing installation and to transfer the property to
communities quickly and efficiently. One threat that could
be present on a closing installation is lead-based paint (LBP)
contamination. This threat is easier to evaluate and clean up
thanks to the new interim Field Guide (EPA and DoD
signed off on the Interim Field Guide on December 15,
1999) developed by a team of Environmental Protection
Agency (EPA) and Department of Defense (DoD) staff.
This break-through effort will help the agencies achieve
their goal of faster cleanup and property transfer.
After collaborating for two years on how to address LBP
hazards at DoD sites, the two agencies signed a plan of
action in March 1999, and pursuant to that plan of action
the agencies began developing the Field Guide. The guide
provides a framework for EPA and DoD project managers
to manage and control LBP hazards at BRAC facilities. The
document combines existing regulations such as Title X of
the Housing and Community Development Act of 1992
and its implementing regulations, the EPA Toxic Substance
Control Act (TSCA) Section 403 proposed rule, and the
Department of Housing and Urban Development (HUD)
Section 1013 final rule, with additional DoD policy require-
ments. The focus of Title X and the Field Guide is on pro-
tecting the health of children at residential properties. Title
X requires that hazards from LBP be abated in housing con-
structed prior to I960. While a federal agency may transfer
the implementation of abatement to the transferee, the fed-
eral agency must perform an inspection and risk assessment
of all target housing prior to transfer. In addition, as a mat-
ter of policy, DoD has included a number of requirements
that exceed Title X to ensure that actions taken are protec-
tive of children. The Field Guide policy requirements
include:
• Soil surrounding housing constructed between I960
and 1978 that contain soil lead hazards (concentration
of lead in bare soil equal to or exceeding 2,000 ppm
or 400 ppm in bare soil in children's play area) caused
by the use of LBP must be abated. The purchaser may
be required to perform the abatement activities as part
of the transfer agreement.
• Soil surrounding housing constructed between I960
and 1978 that contains potential lead hazards (con-
centration of lead in bare soil between 400 and 2,000
ppm, except children's play area) caused by the use of
LBP will be evaluated on a site-by-site basis to deter-
mine whether no action, interim controls, or abate-
ment is appropriate based on risk and non-risk
factors.
• Specific areas of the residential parcel or structure
intended to be reused as a child-occupied facility will
be evaluated for LBP hazards. LBP hazards (deterio-
rated painted surfaces, dust lead hazards, and soil lead
hazards) are required to be abated prior to the use as a
child-occupied facility.
• Target housing that will be demolished and redevel-
oped as residential property following transfer will be
evaluated and abated by the transferee for soil lead
hazards after demolition and prior to occupancy of
any newly constructed dwelling units.
What's Covered and What's Not
The interim Field Guide only applies to property that is
or will be reused as residential real property. HUD defines
residential real property as property where people reside or
will reside, such as houses and apartment buildings. As a
matter of policy, DoD includes child-occupied facilities
within the definition of residential real property for the pur-
pose of this guide. Child-occupied facilities are defined as
day-care centers, preschools, and kindergarten classrooms
regularly visited by children under six years of age. This
guide is not applicable to non-residential properties such as
single room occupancy dwellings like Bachelor Housing,
and schools.
The Field Guide does not supersede any state laws or
regulations regarding lead hazards. Therefore, any sampling
and abatement requirements identified in state laws or regu-
lations must be met. This guide is an interim final as it
reflects the proposed TSCA 403 rule and has not yet been
reviewed by states, tribes, and others potentially affected by
this field guide. Once the TSCA 403 rule is finalized and
additional comments are received, evaluated, and incorpo-
rated in the document as appropriate, the guide will be
finalized. EPA and DoD will continue to work together on
other LBP issues, such as developing model language for a
non-residential POST (finding of suitability to transfer). EH
Monica McEaddy is a Chemical Engineer for EPA's Federal
Facilities Restoration and Reuse Office. Sandra Cotter is a Risk
Assessment Program Manager for the Environmental Division,
Headquarters Naval Facilities Engineering Command.
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Setting and Achieving Goals With GPRA
by Renee Wynn
This is the second installment of a three-article series on
FFRRO's efforts to comply with the requirements of the
Government Performance and Results Act (GPRA).
The U.S. Environmental Protection Agency's (EPA's)
mission is to protect human health and to safeguard
the natural environment—air, water, and land—upon
which life depends. To remain focused on this mission and
to establish guideposts for EPAs leaders today and in the
future, the Agency has developed a series of 10 strategic,
long-term goals. These goals supported by EPAs objectives
and performance measures have become the framework for
the Agency's planning, budgeting, and accountability
process.
FFRRO concentrates its efforts on Goal 5, "Better Waste
Management and Restoration of Contaminated Waste
Sites," including the oversight of Superfund cleanup activi-
ties on federally owned and operated properties containing
uncontrolled or abandoned hazardous waste sites. These sites
were created when chemicals and other wastes where
dumped in the open and left to seep into the ground, flow
into rivers and lakes, and contaminate soil and groundwater.
FFRRO is responsible for providing oversight and tech-
nical assistance to other federal agencies for their uncon-
trolled hazardous waste sites that are listed on the National
Priority List (NPL). These facilities range from nuclear
weapons plants and military bases to landfills and fuel distri-
bution stations and contain environmental contamination
from hazardous wastes, unexploded ordnance, radioactive
wastes, or other toxic substances.
Goal 5 has several objectives and underlying compo-
nents. The following objective states EPA's plan of action,
while the response provides more specific information as to
how FFRRO is going to achieve these long-term goals at
federal facilities.
Objective: Reduce or Control Risks to Human Health:
By 2005, EPA and its partners will reduce or control the risk
to human health and the environment at over 375,000 con-
taminated Superfund, RCRA, UST, and brownfield sites.
The Agency s 10 Goals Are:
1. Clean Air
2. Clean and Safe Water
3. Safe Food
4. Preventing Pollution and Reducing Risk in
Communities, Homes, Workplaces, and
Ecosystems
5. Better Waste Management and Restoration
of Contaminated Waste Sites
6. Reduction of Global and Cross-Border
Environmental Risks
Response: Respond to Superfund Hazardous Waste
Sites: By 2005, EPA and its partners will reduce the risks the
Superfund sites pose to public health and the environment
by: 1) completing construction at a total of 1,200 NPL sites,
2) conducting 2,400 additional removal actions, 3) deter-
mining if Superfund cleanup is needed at 85 percent of the
sites entered into the Superfund site database, 4) maximizing
Potentially Responsible Party participation in
conducting/funding response actions, and, 5) meeting statu-
tory deadlines for federal facility activities. EPA will collabo-
rate with states and tribes to enhance the federal, state, and
tribal Superfund programs, reduce overlap among the pro-
grams, and leverage public and private resources to promote
cost-effective, efficient cleanups at Superfund sites.
These overarching measures are further broken down
into performance measures that are reviewed and updated
on an annual basis to reflect program changes. The 1999
performance measures for federal facilities included:
• EPA and its partners conducted 335 Superfund
removal response actions.
• EPA accelerated the pace of Superfund cleanups by
completing 136 cleanups and will achieve 900 con-
struction completions by the end of the year 2001.
• In recognition of the importance of community
involvement in the cleanup decision-making process,
the Superfund Federal Facilities Program created a
measure for public participation.
• EPA established 100 Restoration Advisory
Boardss/Site-Specific Advisory Boardss at federal facili-
ties on the NPL.
• EPA commented or concurred on 100 base closure
documents.
EPA's efforts to develop a strategic plan, goals, objectives,
and performance measures help link environmental regula-
tions and policies to the budget and hold EPA accountable
to the public. EH
Renee Wynn is the associate director of FFRRO.
7. Expansion of Americans' Right to Know About
Their Environment
8. Sound Science, Improved Understanding of
Environmental Risk, and Greater Innovation to
Address Environmental Problems
9. A Credible Deterrent to Pollution and Greater
Compliance with the Law
10. Effective Management
-------
Closure
met monthly for one and a half years, identifying and com-
piling existing guidance and defining terms.
In addition to providing a single resource for available
closeout information, the document aligns and identifies
both EPA and DoD milestones for the Comprehensive
Environmental Response, Compensation, and Liability Act
(CERCLA) and Resource Conservation and Recovery Act
(RCRA) programs, making it easier for cleanup teams to
stay on track. Further, it breaks new ground by defining the
work to be done after a remedial action decision has been
made, the point at which most cleanup guidance has ended.
Specific steps involved in a variety of cleanup remedies and
advice and examples based on real life situations, con-
tributed by EPA regional members of the workgroup, round
out this section of the guidance.
According to Mario lerardi of the AFBCA, the guidance
is focused on "streamlining cleanup and closeout activities at
federal facilities across the country." As soon as a facility gets
a cleanup remedy in place, lerardi explained, it needs to start
looking at closeout procedures, even if remediation is
10
FFRRO Leads the Way in Promoting Citizen Interests
TheCommunity
Connection
P
Iarticipating in two multi-
agency meetings on public
involvement in summer 1999,
EPA spoke out on several Superfund
site issues that affect surrounding
communities. Working closely with
citizen groups and restoration adviso-
ry boards (RABs), EPA tackled sever-
al issues including lead-based paint,
depleted uranium (DU) contamina-
tion, and the strength and effective-
ness of public involvement in federal cleanups.
At a citizen caucus held in Washington, DC, in July
1999, the Federal Facilities Restoration and Reuse Office
(FFRRO) addressed the issue of lead-based paint at federal
cleanup sites. Because military structures are not covered by
Housing and Urban Development Department laws for resi-
dential buildings, they are allowed to deteriorate, contami-
nating soil and groundwater with lead. Also, access to these
buildings has not been consistently controlled, increasing
risks to individuals who might come in contact with the
paint. For more information on the remediation of lead-
based paint hazards at federal facilities, see the article on
page 8.
Another issue presented at the citizen caucus was the
issue of depleted uranium (DU), a radioactive substance.
Used widely at military sites, DU is a contamination risk to
humans and the environment. The caucus urged the U.S.
Department of Defense (DoD) to provide a list of sites
where DU is or has been used and a history of that use. The
caucus also requested samplings of soil and groundwater at
these sites to evaluate the extent of DU contamination.
At both the citizen caucus and an EPA Region 8 citizen
workshop held in Denver last August, the issue of public
participation was scrutinized in the wake of DoD's dissolu-
tion of the RAB at Fort Ord in California. Citizens called
for the reinstatement of the Restoration Advisory Board,
arguing that communities must be recognized as an equal
participant in cleanup decisions.
The success of these meetings led EPA and DoD to
agree to attend more community meetings, including exist-
ing community forums and tribal sessions. Community rep-
resentatives attending the meetings are hoping that such a
commitment will allow communities a bigger voice in the
decision-making process from start to finish.
Background information for this article came from Defense
Environment Alert.
-------
expected to go on for several years.
The guidance outlines several phases in preparing for site
closeout including:
• Operation of Remedy: The BRAC Cleanup Team
(BCT) determines which cleanup remedies to use and
implements them.
• Response Complete: The cleanup objectives have been
or are being met.
• Long-Term Monitoring/Maintenance: Ensures that the
cleanup remedy remains in place as long as necessary and
continues to be effective.
• Site Closeout: This phase signifies that the response
actions at the site were successful; all cleanup levels and
other requirements have been achieved for all pathways
of exposure, and no further Superfund response is
required to protect human health and the environment.
In many instances, however, a site will never be com-
pletely closed out because it will always require some
kind of monitoring.
In January 1999, an interim guidance document encom-
passing all the existing closeout information was released as a
joint EPA/DoD and Military Service Guide. During a six-
month review and implementation period at military facili-
ties, BCTs had the chance to apply the guidance and
provide comments. These comments helped the working
group make final revisions to the document so it will be
effective in covering all the issues that might arise in a site
closeout situation.
"We have not received many comments on the informa-
tion contained in the guidance," lerardi said. "We've tried to
find out what's missing and work to fulfill that need."
A final EPA/DoD and Military Service Guide was to be
issued in spring 2000. LJU
Additional information concerning site closeout can be
found on the Environmental Site Closeout Web site at
< urww. afbca. hq. af.millcloseout>.
Write To Us
We encourage your questions, comments, and contributions. Please send your input to Dianna Yiung by mail
at U.S. EPA/FFRRO, Mailcode: 5106, 1200 Pennsylvania Avenue, NW, Washington, DC 20460; e-mail at
; or fax at 202 260-5646.
Join Our Mailing List
If you would like to be on the FFRRO mailing list to receive future \ssuesitfidPiaProg sgs
please fill out and return this form to Dianna Yiung at U.S. EPA/FFRRO, Mailcode: 5106, 1200
Pennsylvania Avenue, NW, Washington, DC 20460; e-mail at ; or
fax to 202 260-5646.
~
Name:
Agency/Organization:
Street Address:
State:
Zip Code:
Phone Number:_
E-mail:
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Agenda
March 27 to 30, 2000
[26th Environmental
Symposium and Exhibition
Long Beach, California
This year's conference focuses on the impact of DoD activi-
ties on the global environment and how to integrate envi-
ronmental issues in sustaining DoD readiness. For more
information, visit the conference Web site at
environment, ndia.org/>.
April 4 to 6, 2000
HAZMAT 2000 Spills Prevention Conference
St. Louis, Missouri
The HAZMAT 2000 Spills Prevention Conference pro-
vides an opportunity for communities, industry, states, and
nations to examine existing policies and tools that foster
hazardous material accident prevention, preparedness, and
response activities. For more information or to register elec-
tronically, visit the conference Web site at .
May 1 to 3, 2000
IAP2 2000
Washington, DC
This International Association for Public Participation con-
ference will explore the use and advancements of public par-
ticipation in the 1990s and into the new millennium.
Registration information is available on the Web at
or call 703 971-0090.
May 2 to 4, 2000
The UXO/Countermine Forum
Anaheim, California
DoD's pre-eminent conference will examine the technolo-
gies, issues, and policies surrounding the UXO/
Countermine arena, including environmental remediation,
UXO disposal, humanitarian demining, and more. For
more information visit the Web site at < 128.174.5.51/
denk/Public/News/UXOCOE/Conference/ForumOO/uxo
2000.html#summary>.
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