Partners In Progress Issue 4 - October 2000

Contents:

Partners In Progress Philosophy
Celebrating Success: Community Relations Plan Wins Praise
Breaking News: New Guidance Will Help Bring Closure
From The Director: A Decade of Progress in Cleanup Of Federal Facilities
Improving the Practice of Public Participation
A Risk Management Approach for UXO
Five-Year Review Guidance
Cyber News: www.epa.gov/etv/
Community Involvement On the Web
Air Force Base Conversion Agency (AFBCA)
EPA and DoD Approve Field Guide On Lead-Based Paint
Setting and Achieving Goals With GPRA
The Community Connection: FFRRO Leads the Way in Promoting Citizen Interests
Write To Us
Acronyms Explained

Partners In Progress Philosophy

Stakeholders involved in federal facility cleanups are diverse, with differing backgrounds, interests, and perspectives. All of these stakeholders, however, 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.”

Celebrating Success: Community Relations Plan Wins Praise

Are 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 the 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 community. 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, environmental 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 obtained from the interviews included the community’s current 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.

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 a 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 investigation at Fort Pickett. More than 8,000 shell casings 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.

Two 55-gallon drums containing unidentified substances. These drums were sampled, properly characterized, and disposed of.

The Fort Pickett CRP outlines specific community relation activities and a time line for implementing these activities. 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 information for all the BCT and Restoration Advisory Board (RAB) members as well as other project 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 solicit 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 initiative and asked RAB members for their recommendations for respondents. This resulted in a well-balanced pool of community members.

Before the CRP was developed, community involvement in the Fort Pickett cleanup consisted primarily of participation in the RAB meetings. Public notices were placed in area newspapers before each meeting, and meeting minutes and agendas were mailed to approximately 60 interested parties before each meeting. The CRP interview responses indicated a particular newspaper in which to put meeting notices and expanded the mailing list to 125 persons. Also, it proved to be an excellent way to raise awareness about the cleanup efforts since participants were briefed on the project in conjunction with the interview.

EPA staff believe that because the CRP was developed 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.

Breaking News: New Guidance Will Help Bring Closure

When 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 instructions, 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) environmental office, EPA, and the California and Illinois environmental protection agencies. The group met monthly for one and a half years, identifying and compiling 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, contributed by EPA regional members of the workgroup, round out this section of the guidance.

According to Mario Ierardi 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, Ierardi explained, it needs to start looking at closeout procedures, even if remediation is 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 completely closed out because it will always require some kind of monitoring.

In January 1999, an interim guidance document encompassing 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 facilities, 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 information contained in the guidance,” Ierardi 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.

From The Director: A Decade of Progress in Cleanup Of Federal Facilities

In early December 1999, I had the fortune of attending a meeting of the People of 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 overwhelming. At that time, EPA was in the process of adding more than 100 federal facilities to its Superfund National 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 significant events and achievements. From my perspective, 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 facility 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 cooperation and trust. The relationships and friendships developed during the FFERDC process have helped us find solutions to issues that have arisen since the report’s 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 Cleanup. This report was the Executive Branch’s first systematic 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 environment. It remains the only report to include an estimated funding requirement for complete cleanup of federal government sites. Though many were initially shocked at the $234 to $389 billion estimate, that figure may have been an underestimate 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 characterized. 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.

But where do we go from here? As the FFERDC report notes, the relationships among regulated agencies, the regulators, 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 continue 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.

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 establishing high standards for public processes by developing and sharing personal values, and it is the most comprehensive 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 EPA’s 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 values 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 concerns 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.

Martha A. Rozelle, Ph.D., is the president of IAP2. She is also the president of a participatory decision-making consulting firm, The Rozelle Group, Ltd., in Phoenix, Arizona. For more information about IAP2 or to learn how to become a member, visit the program’s Web site at www.iap2.org

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 EPA’s concurrence) 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 partnering team comprised of representatives from EPA, states, tribes, and other federal agencies and stakeholders. Originally formed in 1997, the partnering team today involves approximately 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.

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 difficult 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 federal 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 project 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 something that can be summarized in one sentence,” explained Mark Stephens of EPA Region 3. “There are some complexities 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 documents, 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 continue 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 completion date of the remedy. The guidance also addresses 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 decision 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 agencies’ 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 bass.carol@epa.gov.

Cyber News: 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, which lays out the criteria for and responsibilities of all of the governmental 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.

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 coordinator. 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 members, 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 www.epa.gov/fedfac/comminvolve/index.htm and send their comments by e-mail to stinson.jeffrey@epa.gov.

Air Force Base Conversion Agency (AFBCA)

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 visitors 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 responsibilities to federal, state, and local conversion planning agencies and those in affected communities. Base Realignment and Closure (BRAC) contact information 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 of the U.S. Department of Defense’s (DoD’s) BRAC sites.

EPA and DoD Approve Field Guide On Lead-Based Paint
by Monica L. McEaddy and Sandra Cotter

The 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 breakthrough 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 requirements. The focus of Title X and the Field Guide is on protecting the health of children at residential properties. Title X requires that hazards from LBP be abated in housing constructed prior to 1960. While a federal agency may transfer the implementation of abatement to the transferee, the federal agency must perform an inspection and risk assessment of all target housing prior to transfer. In addition, as a matter of policy, DoD has included a number of requirements that exceed Title X to ensure that actions taken are protective of children. The Field Guide policy requirements include:

• Soil surrounding housing constructed between 1960 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 1960 and 1978 that contains potential lead hazards (concentration 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 determine whether no action, interim controls, or abatement 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 (deteriorated 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 redeveloped 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 purpose 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 regulations 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 incorporated 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 FOST (finding of suitability to transfer).

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.

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 EPA’s leaders today and in the future, the Agency has developed a series of 10 strategic, long-term goals. These goals supported by EPA’s objectives and performance measures have become the framework for the Agency’s planning, budgeting, and accountability process.

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
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

FFRRO concentrates its efforts on Goal 5, “Better Waste Management and Restoration of Contaminated Waste Sites,” including the oversight of Superfund cleanup activities 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 technical assistance to other federal agencies for their uncontrolled 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 distribution stations and contain environmental contamination from hazardous wastes, unexploded ordnance, radioactive wastes, or other toxic substances.

Goal 5 has several objectives and underlying components. 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 contaminated Superfund, RCRA, US, and brownfield sites.

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) determining 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 statutory deadlines for federal facility activities. EPA will collaborate with states and tribes to enhance the federal, state, and tribal Superfund programs, reduce overlap among the programs, 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 construction 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 Boards/Site-Specific Advisory Boards at federal facilities 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 regulations and policies to the budget and hold EPA accountable to the public.

Renee Wynn is the associate director of FFRRO.

The Community Connection: FFRRO Leads the Way in Promoting Citizen Interests

Participating 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 advisory boards (RABs), EPA tackled several issues including lead-based paint, depleted uranium (DU) contamination, and the strength and effectiveness 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 residential buildings, they are allowed to deteriorate, contaminating 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 dissolution 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 existing community forums and tribal sessions. Community representatives 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.

Write To Us

We encourage your questions, comments, and contributions. Please send your input to Dianna Young by mail at U.S. EPA/FFRRO, Mailcode: 5106, 1200 Pennsylvania Avenue, NW., Washington, DC 20460; e-mail at young.dianna@epa.gov; or fax at 202 260-5646.

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

Articles written by non-EPA authors do not necessarily reflect the views, positions, or policies of the Agency.