Environmental Cleanup: Supplemental Case Studies of High Priority DOD
Installations (Letter Report, 11/18/94, GAO/NSIAD-95-8).
In an April 1994 report (GAO/NSIAD-94-133), GAO said that despite
spending a reported $3.76 billion, the Defense Department's
environmental cleanup program for high priority military installations
has proceeded slowly during the past decade, with relatively few
hazardous waste sites actually being cleaned up. Most of the time and
money had been spent studying the problem. This supplement focuses on
six case studies--Aberdeen Proving Grounds, Fort Wainwright, McChord Air
Force Base, McClellan Air Force Base, Pearl Harbor Naval Complex, and
Schofield Barracks. GAO discusses the status of the restoration program,
the cost of cleanup to date and projected costs, the cleanup options
considered, the options selected, expected completion, and the
applicable cleanup standards. GAO also discusses the reasons a military
installation was listed on the National Priorities List, the regulatory
process, cooperation between the installation and the regulatory
agencies, staffing at the installations and the regulatory agencies, and
the process for funding the cleanup.
--------------------------- Indexing Terms -----------------------------
REPORTNUM: NSIAD-95-8
TITLE: Environmental Cleanup: Supplemental Case Studies of High
Priority DOD Installations
DATE: 11/18/94
SUBJECT: Environmental monitoring
Hazardous substances
Waste disposal
Defense operations
Military facilities
Interagency relations
Safety standards
Defense budgets
Environmental law
Human resources utilization
IDENTIFIER: EPA National Priorities List
EPA Hazard Ranking System
DOD Installation Restoration Program
DOD Environmental Restoration Program
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Cover
================================================================ COVER
Report to the Chairman, Committee on Governmental Affairs, U.S.
Senate
November 1994
ENVIRONMENTAL CLEANUP - CASE
STUDIES OF SIX HIGH PRIORITY DOD
INSTALLATIONS
GAO/NSIAD-95-8
Environmental Cleanup
Abbreviations
=============================================================== ABBREV
CERCLA - Comprehensive Environmental Response, Compensation and
Liability Act
DERA - Defense Environmental Restoration Account
DOD - Department of Defense
EPA - Environmental Protection Agency
IRP - Installation Restoration Program
NPL - National Priorities List
PCB - polychlorinated biphenyls
ppb - parts per billion
TCE - Trichloroethylene
Letter
=============================================================== LETTER
B-256676.2
November 18, 1994
The Honorable John Glenn
Chairman, Committee on
Governmental Affairs
United States Senate
Dear Mr. Chairman:
This is a supplement to our report entitled Environmental Cleanup:
Too Many High Priority Sites Impede DOD's Program (GAO/NSIAD-94-133,
Apr. 21, 1994). It provides six installation case studies
addressing issues outlined in your request and discussed in our
report. These issues include the status of the restoration program,
the cost of cleanup to date and projected costs, the cleanup options
considered, the option selected, expected completion, and the
applicable cleanup standards. The case studies also provide
installation specific information on reasons an installation was
listed on the National Priorities List (NPL), the regulatory process,
cooperation between the installation and the regulatory agencies,
staffing at the installations and the regulatory agencies, and the
process for funding the cleanup. (See apps. I through VI.)
In our April 1994 report, we stated that despite spending a reported
$3.76 billion as of September 1993, the Department of Defense's (DOD)
environmental cleanup program for high priority installations has
proceeded slowly over the past 10 years, with relatively few
hazardous waste sites being cleaned up. Most of the time and money
have been spent studying the problem. The cost estimate for cleaning
up high priority installations is $18.2 billion.\1 However, this cost
estimate is based on preliminary information and is likely to
increase.
The Environmental Protection Agency's (EPA) system for identifying
high priority sites has led to a large number of individual sites on
installations with that designation. In addition, some sites not
designated as high priority are more contaminated than high priority
sites and pose a greater risk to human health and the environment
than those on the NPL, according to DOD officials. EPA usually
scores only the four to six worst sites on an installation in
determining whether an installation, which may have hundreds of
sites, should be placed on the NPL. Many of these sites may have
only minor contamination, but DOD program managers must apply the
entire Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA) process (see app. VII) to all the sites on an
NPL installation, including those with only minor contamination.
DOD will not be able to efficiently institute cleanup efforts until
it and EPA evaluate the large number of sites currently on the NPL or
the closure list and determine which should be designated as high
priority. Even a relatively few high priority sites could strain
resources and force difficult choices. The Deputy Under Secretary of
Defense (Environmental Security) has proposed a new approach to
solving cleanup problems, which includes developing cooperative
rather than adversarial relationships with regulatory agencies,
setting priorities based on risk, and trying to accelerate cleanups.
We also identified other key factors that have affected DOD's cleanup
of high priority installations in a timely and cost-effective manner.
The complex and time-consuming CERCLA study and cleanup process.
Prolonged study of hazardous waste sites rather than cleanup.
Disagreements with regulatory agencies over the extent of cleanup
required.
Addressing issues during the CERCLA process, such as liability, that
generally do not pertain to governmental installations.
Scarce resources including limited technology and expertise.
Appendix VIII discusses our methodology and scope, including a list
of the installations and organizations visited. We conducted our
review from September 1992 to October 1994 in accordance with
generally accepted government auditing standards. As requested, we
did not obtain formal agency comments on a draft of this report.
However, we provided officials at each of the six installations an
opportunity to provide comments and have included their comments
where appropriate. We also discussed our April 1994 overall report
(NSIAD-94-133) with DOD representatives and included their comments
where appropriate.
--------------------
\1 The estimated cost to clean up DOD installations is based on data
provided by the installations, commands, and services as of September
30, 1993.
---------------------------------------------------------- Letter :0.1
Unless you publicly announce its contents earlier, we plan no further
distribution of this report until 30 days after its issue date. At
that time, we will send copies to congressional committees; the
Secretaries of Defense, the Army, the Navy, and the Air Force; the
Administrator, Environmental Protection Agency; and the Director,
Office of Management and Budget. We will also make copies available
to others upon request.
If you or your staff have any questions concerning this report,
please call me on (202) 512-8412. Major contributors to this
supplement are listed in appendix IX.
Sincerely yours,
Donna Heivilin
Director, Defense Management
and NASA Issues
ABERDEEN PROVING GROUNDS CASE
STUDY
=========================================================== Appendix I
Aberdeen Proving Grounds, Maryland, is an Army Test and Evaluation
Command installation within the Army Materiel Command. The
installation, situated on 79,000 acres, over half of which is covered
by water, is split between Aberdeen (north end) and Edgewood (south
end) areas, separated by a river with both areas consisting primarily
of peninsulas and islands in the upper Chesapeake Bay in Harford and
Baltimore counties.
Aberdeen Proving Ground's mission includes development and testing of
equipment such as weapon systems, rockets and missile systems,
munitions, and components. The Army's Chemical Biological and
Defense Command, a tenant at the installation, is involved in
research of materials such as blister agents, tear gas, and nerve
agents. About 85 percent of the installation's area is used for
vehicular testing, ballistic testing, and artillery and other weapon
testing impact areas.
Throughout its history, the Edgewood area has been the primary U.S.
chemical warfare research and development center. During World Wars
I and II, the Edgewood area manufactured chemical agents. Past
mission activities and disposal practices have resulted in
contamination, including volatile organic compounds, arsenic,
phosphates, napalm, unexploded ordnance, nitrates, chemical agents,
and other contaminants typically found on military installations.
LISTING ON NATIONAL PRIORITIES
LIST
--------------------------------------------------------- Appendix I:1
The two National Priorities List (NPL) sites on the installation are
the entire Edgewood area, which includes 78 individual sites,\1
and the Michaelsville Landfill site in the Aberdeen area. Because
all of the preliminary assessment studies had not been completed,
only one site on the Aberdeen area was listed as an NPL site.
The Edgewood area was placed on the NPL on February 1, 1990. The
site has a composite Environmental Protection Agency's (EPA) Hazard
Ranking System score of 53.57 based on severe contamination from
numerous sites. Installation officials agree that the area should be
on the NPL because of the contamination. Groundwater is not used for
drinking on the Edgewood Peninsula; however, there may be some
private citizens near the Edgewood area boundary that may have
private wells that may be affected. There also is concern that the
contamination may affect the surface waters near the installation,
including the Chesapeake Bay, which could, in turn, affect the fish
and wildlife in the area.
The Michaelsville Landfill covers about 20 acres, and it was placed
on the NPL on October 1, 1989. EPA assigned it a Hazard Ranking
System score of 31.45 largely because of the potential for
groundwater contamination caused by leacheate from the landfill.
Groundwater in and around the Aberdeen area is used as a backup
drinking water supply for the installation. Installation officials
do not agree with EPA that the landfill contamination detected so far
warrants NPL listing.
Even though the fire fighting training site located in the Aberdeen
area was not listed on the NPL, subsequent information indicates it
may be the worst site in the Aberdeen area because of the potential
adverse effect on the environment. Tests indicate that the site is
contaminating the groundwater, which supplies drinking water to the
communities around the installation. Groundwater in and around the
Aberdeen area is used extensively for drinking in Harford County
(50,000 to 60,000 people) and in the town of Aberdeen (14,000
people). A major concern is that the continued pumping of the wells
will establish a low spot in the groundwater table that could further
draw contaminated groundwater from the site.
Installation officials have not tested any of the off-base drinking
water wells to determine if there is any contamination, but the
county and the state have found low levels of volatile organic
compounds and Trichloroethylene (TCE) in their testing of some of the
county wells. In 1992, one of the county wells was shut down because
of the TCE contamination. In June 1993, the Army completed
construction of a water treatment system, at a cost of about $1.3
million, to remove TCE from the water used. The well was also put
back in operation in June 1993.
--------------------
\1 An NPL site can be made up of numerous potentially contaminated
locations on an installation. These locations are referred to as
individual sites when discussing the contaminated locations.
STATUS OF THE INSTALLATION
RESTORATION PROGRAM
--------------------------------------------------------- Appendix I:2
Under the Department of Defense's (DOD) installation restoration
program (IRP), the installation has completed most of the preliminary
assessment/site inspection phase and is in the remedial
investigation/feasibility study phase of the Comprehensive
Environmental Response, Compensation and Liability Act (CERCLA)
cleanup process. The remedial investigation/feasibility study has
been severely restricted by the presence of explosives and chemical
agents at some of the 79 sites.\2 These 79 sites have been divided
into 13 study areas, with each study area to have a Record of
Decision.\3
Nine study areas make up the Edgewood NPL site and four study areas
make up the Aberdeen portion. Table I.1 shows the status of sites on
the installation.
Table I.1
Status of Sites at Aberdeen Proving
Grounds
No. of sites
that reached
or
will reach
CERCLA process phase phase
-------------------------------------------- --------------
Study 79
Interim remedial action-underway 10
Interim remedial action-complete 17
Remedial action 67
Remedial action in place and operating 0
Remedial action complete 0
Closed out-no further action 2
------------------------------------------------------------
Installation officials do not think they have found all of the sites
because they are still finding new sites on a regular basis. The
state and EPA have said the installation does not have to do any more
preliminary assessment/site inspection work to find new sites.
However, if a new site is found, the applicable parts of the
preliminary assessment/site inspection must be done.
--------------------
\2 The 79 sites consists of 319 solid waste management units. Each
unit could be a place where hazardous waste was disposed of or was
spilled or is an operating facility.
\3 A record of what the installation and the regulatory agencies
agree is needed to clean up a site.
COST
--------------------------------------------------------- Appendix I:3
The Army has spent $129.1 million through September 1993, even though
the installation has not entered into the remedial action phase. The
estimated projected total cost to complete the work required by the
Interagency Agreement,\4 as included in the Annual Report to
Congress, is $1.3 billion.
Installation officials believe costs must be controlled and they have
instituted cost control reporting for the work being done and
scheduled to be done. Each project manager has to maintain records
on the work done, perform an analysis of what has been done and how
much the contractor should be paid, and record the amount of
payments. These statistics are reported to the Chief of the
Environmental Conservation and Restoration Division monthly,
quarterly, and annually. These reports are forwarded to higher
command for their review, analysis, and approval.
Another cost control measure is that all participants in the IRP meet
annually to review the entire program. During the meetings, they
discuss program status, share information, break down all aspects of
the work, discuss options, identify and try to avoid duplication, and
identify procedures or processes to reduce the cost. For example, in
reviewing a contract proposal from a U.S. Army Corps of Engineers'
contractor to remove some hazardous waste from a Carroll Island site,
installation officials noted that the $1-million cost appeared to be
inflated. Upon further review, the removal action was completed with
installation personnel and contractors for about $258,000.
--------------------
\4 An agreement among the installation, EPA, and the state regulatory
agencies outlining what the installation agrees to do to remediate
the site. At some installations, a Federal Facilities Agreement has
been signed, but in this report we will call all agreements
Interagency Agreements.
OPTIONS CONSIDERED
--------------------------------------------------------- Appendix I:4
Options were considered for only 2 of the 13 study areas--the Old "O"
Field site and the Michaelsville Landfill. Study work is continuing
at the remaining areas.
As shown in table I.2, a number of options and cost estimates were
considered for the Old "O" Field site.
Table I.2
Options Considered for the Old "O" Field
Site Cleanup
(Dollars in millions)
Cost
Option estimate
----------------------------------------------- -----------
Down-gradient extraction with discharge to $1.8
surface water
Extraction with capping and discharge to 4.1
surface water
Extraction with spray irrigation/source 3.0
flushing
Extraction with down-gradient reinjection 3.0
Air stripping/carbon adsorption (liquid phase) 9.4
Chemical precipitation/ultraviolet-oxidation 7.4
Chemical precipitation/activated sludge 6.4
biological treatment/carbon adsorption
Chemical precipitation/powdered activated 5.6
carbon treatment
No action 0.0
------------------------------------------------------------
As shown in table I.3, a number of options and cost estimates were
also considered for the Michaelsville Landfill.
Table I.3
Options Considered for the Michaelsville
Landfill Cleanup
(Dollars in millions)
Cost
Option estimate
----------------------------------------------- -----------
Redressing the landfill cap $ 7.0
Installing a new cap in accordance with 9.2
Maryland's requirements using off-post clay
Installing a new cap in accordance with the 9.6
Resource Conservation and Recovery Act
requirements for hazardous waste landfill
closure
Installing a new cap in accordance with 8.8
Maryland's requirements using a geosynthetic
(plastic) membrane
Excavating and hauling the waste off-site 135.5
Excavating and incinerating the waste 182.8
Excavating the waste, lining the cavity, 21.1
replacing the waste, and capping the landfill
No action 0.0
------------------------------------------------------------
OPTIONS SELECTED
--------------------------------------------------------- Appendix I:5
Records of Decision concerning remedial actions or cleanup have been
signed for the Old "O" Field site and the Michaelsville Landfill. In
addition to these two study areas where options were considered, a
Record of Decision for no action was also signed for the White
Phosphorous site study area. EPA Region III officials told us that
the options considered and selected and the no action decision for
the White Phosphorous site met with their approval.
For the Old "O" Field site, a pump and treat system was selected.
The treatment consisted of chemical precipitation and ultraviolet-
oxidation. The effluent from the treatment plant is discharged into
the adjoining river. After the system was installed, installation
officials decided to afford more protection against the danger of
explosion. To do this, they decided to also install a sand cap over
the site that would absorb some of the effects of an explosion. The
cap would also permit rain to wash through the site, flushing out
some of the waste that would be captured and treated in the new pump
and treat system.
For the Michaelsville Landfill site, the Army chose to install a new
cap in accordance with Maryland's requirements using a special
plastic liner.
EXPECTED COMPLETION
--------------------------------------------------------- Appendix I:6
Installation officials said no date has been projected for when all
the cleanup work will be completed. The installation is
contemplating funding for cleanup until the year 2010. As at other
installations that use pump and treat systems, it can take decades
for the groundwater to be cleaned. In most cases, the study work has
not progressed far enough to know what cleanup actions are required.
Even with the landfill cap, continuous monitoring is required, and if
the cap fails, cleanup work may be required. For a number of
Aberdeen Proving Ground's sites, installation officials do not
believe there is adequate technology available to do the cleanup
work.
REGULATORY PROCESS
--------------------------------------------------------- Appendix I:7
Installation officials stated that the CERCLA process is
time-consuming and costly and takes a large number of people to
implement. However, they stated that there are some advantages to
being placed on the NPL, including (1) a higher funding priority; (2)
a single point of contact for the state regulatory agency; (3) better
incorporation of the applicable, relevant, and appropriate
requirements; and (4) more and better attention from EPA. They also
said there are some disadvantages to being placed on the NPL; for
example, the required paperwork is difficult to manage and get
processed, reviewed, and approved.
Installation officials believe all installation sites should be
included in the Interagency Agreement because it provides for orderly
and consistent management. All of the installation's sites are
included in the agreement.
Because the installation cannot fund and implement all of the
projects at once, installation officials review and prioritize all of
the projects and determine which ones can be put under contract using
existing technology. This approach permits the movement of money to
higher priority projects. As a result, there are some quick response
actions, and some cleanup projects that are accelerated while others
have limited actions taken.
Officials have also tried to accelerate projects by condensing the
study plans to enable faster achievement of a Record of Decision and
clean up some of the worst sites quicker. To shorten the amount of
time to clean up a site, the installation has begun early removal
actions or interim remedial actions while the work to come up with a
Record of Decision is being completed.
DOD/REGULATORY AGENCY
COOPERATION
--------------------------------------------------------- Appendix I:8
So far, the installation has not had any problems with the oversight
provided by the regulatory agencies--EPA and the Maryland Department
of Environment-CERCLA Section. According to installation, EPA, and
state officials, the working relationship has been great. They told
us that they have informally agreed to proceed with the job and to
work together. Installation officials told us that EPA keeps them
busy trying to comply with CERCLA requirements.
CLEANUP STANDARDS
--------------------------------------------------------- Appendix I:9
Installation officials like the idea of one cleanup standard versus
the cleanup being based on a risk assessment. However, they believe
the standard should have provisions for adjustments to accommodate
local conditions and a significant threat if there is one. They said
for the Aberdeen area, a risk assessment is crucial because of the
potential threat to drinking water supplies.
STAFFING
-------------------------------------------------------- Appendix I:10
Installation officials told us that, as of August 1994, the
installation was authorized 14 restoration positions and they had no
problem hiring the
11 people they currently have. For a number of years it was
difficult replacing any that left because the Army had a staffing
freeze. They stated that the freeze had not caused any major
problems. The freeze has been lifted, but it still could affect the
remedial action phase because not enough staff are available to
oversee the increased number of contractors working on the IRP. One
reason it has not been a major problem yet is that Aberdeen was
permitted to replace those staff members who left with the three
current staff employees that had lost their jobs because of a
reduction-in-force action at the installation. However, these people
do not have the technical or managerial expertise needed for the IRP.
Installation officials state that without the full number of trained
staff authorized, it will be hard to oversee the contractors' work.
To overcome the shortage of staff, Aberdeen has signed a contract
with the Department of Energy's contractor, HAZWRAP, to oversee and
monitor the work of the contractors.
REGULATORY AGENCY STAFFING
-------------------------------------------------------- Appendix I:11
EPA officials told us that because of the large number of NPL sites
in Region III and the staffing restrictions, they have been assigning
most of their staff to cover private sector NPL sites. They have a
small number of staff dedicated to federal facilities, which they
believe is not enough to cover the number of sites. Consequently,
the region has used contractors to assist it in reviewing documents.
Installation officials told us that the documents they submit to EPA
Region III are reviewed either by regional staff or contractors.
According to these officials, the contractors' reviews often result
in lengthy comments that are hard to deal with and take considerable
time whereas EPA's reviews result in comments that can be dealt with
and that do not require excessive work, such as more long-term
studies to obtain additional details on the sites. They told us the
contractors' reviews have caused them delays in proceeding to the
next phase.
FUNDING
-------------------------------------------------------- Appendix I:12
Army officials at the installation, the Army's Environmental
Center,\5 and the headquarters level in Washington, D.C., told us
that the Army, through the Environmental Center, sets funding
priorities based on the following criteria:
Sites on the NPL with an Interagency Agreement.
Sites on the NPL without an agreement.
Sites with notices of violation or consent decrees.
Sites not on the NPL.
Removal actions on the NPL.
Sites with an agreement but not on the NPL.
Removal actions not on the NPL.
The top two priorities are being fully funded by the Army, and the
installation has received all of the Defense Environmental
Restoration Account (DERA) funding requested. According to
installation officials, two of the worst sites, the fire training
area and the Phillips Landfill, have not received adequate funding
(non-DERA) because they are not listed on the NPL, even though they
are included in the agreement. For example, the installation
requested $1 million in fiscal year 1993 to do some of the site
investigation work at the fire training site, but the Army only
allotted $200,000 for some preliminary study work.
According to installation officials, the fire training area was not
adequately funded for a number of years because of the Army's funding
priority system. However, during the last 2 years, the funding
priority has increased to near the highest priority because
installation and regulatory agency officials consider it to be one of
the highest risk sites on the installation due to the fact that the
site is contaminating local drinking water supplies. In addition,
the installation is receiving a larger share of the funds because
installation officials have begun to identify a number of projects
each year that could be done if additional funds become available.
The installation has received a significant amount of year end funds
when other installations could not get their projects under contract.
Also, according to installation officials, some removal projects in
the past had not received the required funding because removals were
given a low priority under the Army's funding system. These removal
projects were not given a high priority because the installation
could not prove a direct health or environmental risk. To prove a
risk, installation officials would have to do all of the study work,
which would take time. As a result, installation officials said that
several removal projects had not been implemented and the
installation had run the risk of contaminating the groundwater and
causing a more costly cleanup problem. They also stated that during
the last 2 years, a number of these projects have been funded because
year end money became available.
At least once a year, installation officials meet with EPA to
determine which sites EPA thinks should have the highest funding
priority because of the environmental risk observed by the regulatory
agencies. At these meetings, installation and EPA officials have
stated that they do not believe the Army has assigned the proper
funding priority to some of the sites, including the fire training
area. This site has not received funding because the study phase was
not complete when the Hazard Ranking System scoring was done for the
installation, and as a result, the site was not listed as an NPL
site. Even though it is a high risk site, according to EPA and the
state, it is not on the NPL, and because it is not on the NPL, the
Army has not assigned it a high funding priority.
--------------------
\5 The Environmental Center manages the IRP, including funding and
other resources.
FORT WAINWRIGHT CASE STUDY
========================================================== Appendix II
The primary mission of Fort Wainwright, Alaska, which covers over
900,000 acres, is to train soldiers in the arctic environment,
prepare troops to defend the state, and deploy worldwide. Industrial
operations include the maintenance of fixed-wing aircraft,
helicopters, and support vehicles. The waste generated and the
contamination Fort Wainwright has to address include petroleum
products, chemicals, pesticides, volatile organic compounds, heavy
metals, batteries, solvents, paints, and radiologically contaminated
wastes. The U.S. Army, Alaska, Public Works at Fort Richardson,
manages and provides oversight of the environmental programs at the
fort. Fort Wainwright's environmental staff provides limited on-site
assistance in the cleanup program.
LISTING ON THE NPL
-------------------------------------------------------- Appendix II:1
Fort Wainwright was placed on the NPL with a Hazard Ranking System
score of 42.4 in August 1990 because of possible groundwater
contamination from a landfill, and the North Post sites, and six
sites contaminated with heavy metals. The score was a composite
score of a number of sites on the installation.
EPA officials, based on the preliminary studies, believed a North
Post site was leaking benzene into the groundwater; however, a
subsequent review of the data indicates this may not be true. A
removal action removed all contaminated dirt, and a groundwater
investigation will be done to confirm whether there is benzene
contamination of the groundwater according to Army officials.
The Army has records indicating mustard gas canisters were disposed
of on the fort, and an effort was made to locate the sites. One was
found and a partial cleanup was done in the 1960s. Another removal
action is planned. An EPA official believes the site still contains
contaminants and the site by itself could qualify the installation
for the NPL.
STATUS OF THE IRP
-------------------------------------------------------- Appendix II:2
Several studies, including the preliminary assessment, have been
completed. The preliminary assessment, done in 1987, evaluated the
landfill, the North Post sites, and other petroleum, oil, and
lubricant sites scattered throughout the installation. In 1992, EPA,
the state, and the Army recommended that some sites be closed out,
with no further action, and that others be studied further, including
some testing. During the follow-up studies, possible chemical
disposal sites in the Birch Hill area and other sites that may
require additional work were identified. Work on the remedial
investigation/feasibility study was begun in fiscal year 1993. Table
II.1 shows the status of CERCLA work at Fort Wainwright.
Table II.1
Status of Sites at Fort Wainwright
No. of sites
that reached
or
will reach
CERCLA process phase phase
-------------------------------------------- --------------
Study 61
Interim remedial action-underway 2
Interim remedial action-complete 19
Remedial action 15
Remedial action in place and operating 0
Remedial action complete 11
Closed out-no further action 34
------------------------------------------------------------
Some of the North Post sites have been cleaned up and others are
under remediation. So far, the material taken from the North Post
sites has had very low levels of contamination. The installation's
petroleum, oil, and lubricant pipeline has significant leaking
problems. U.S. Army, Alaska, officials plan to use ground
penetrating radar to pinpoint any waste sites, especially the alleged
chemical waste disposal sites.
The Army found that only one of two possible sites had evidence of
possible radiological contamination. The radiation was believed to
be what was left from disposing of the remains of airplane
instruments and dials. An Army official stated that the
contamination from this site was removed in the 1960s, and EPA and
the state formally agreed with the Army's decision for no further
action on this site.
The installation is continually finding new sites, especially buried
petroleum products in drums. During World War II, in anticipation of
a possible Japanese attack on above ground petroleum, oil, and
lubricant storage facilities, the installation buried a very large
number of drums with these products in them. Even though the
preliminary assessment identified a large number of these sites on
the installation, U.S. Army, Alaska, installation, and contractor
officials are continually finding others. Recently, installation,
contractor, and U.S. Army, Alaska, officials identified a site where
they thought about 40 to 60 drums were buried. However, the
contractor found over 1,600 drums, many still containing petroleum
products. Army officials told us that as of August 1994 all of the
drums had been removed from the site.
EPA and state regulatory agencies' officials told us that the IRP at
Fort Wainwright is a good one and that they believe the installation
is identifying its sites through the IRP. The installation has been
very diligent. For example, unlike other installations, it closely
coordinated the preliminary assessment with both state and EPA
regulators and incorporated their comments into the assessment plan.
The sites have been divided into five operable units. Operable Unit
5 has been left open to add new sites when found.
The Army, in studying the groundwater flow, is having difficulty
determining the amount of contamination, the direction of the
contamination plume migration, and the source of the contamination
because of the uncertainty caused by the permafrost. For example,
based on normal geological formations, groundwater would flow in a
certain direction. However, with the permafrost, the direction of
the groundwater flow can change, at times even be reversed. In
addition, the effect changes with the seasons.
U.S. Army, Alaska, officials believe that with the extent of
contamination, the geological formations, the permafrost, and
available technology, the installation cannot clean up the
groundwater to drinking water standards. They stated that attempts
to clean up the groundwater would be very difficult and costly.
COST
-------------------------------------------------------- Appendix II:3
The Army had spent $21.4 million through fiscal year 1993, and it
expects to spend a total of about $72.7 million to implement the
requirements of the Interagency Agreement. However, installation
officials told us the cost estimate could increase as further study
work is completed and the final remedial actions are decided.
U.S. Army, Alaska, and the Corps of Engineers are responsible for
ensuring cleanup is being accomplished in the most cost-effective
manner. U.S. Army, Alaska, officials believe that if the following
were implemented, the cost of cleanup could be minimized.
Clean up some sites while studies are being done at others.
Remove the contamination from some sites and not do anything else,
such as installing expensive pump and treat systems that often do not
clean up the groundwater.
Do nothing at all at some of the lesser contaminated sites.
Installation officials stated that another way to minimize costs is
to improve environmental contracts so that they are more flexible.
An Army official stated that 5 years ago, a "Blue Ribbon Panel"
concluded that the Corps' construction contracts were not specific
enough to prevent unnecessary cost growth. In response, the Corps
set up rigid procedures for contracting and contract administration
to prevent cost growth during facility construction.
However, U.S. Army, Alaska, officials believe these rigid procedures
conflict with the need for flexibility in environmental contracts.
Environmental contracts are not like construction contracts because
there is not a definite structure being built. Also, there are many
unknowns concerning hazardous waste cleanup. Thus, it is almost
impossible to tell what will be encountered as the work progresses.
As a result, there is a need to constantly change the scope of work
to adjust for the unknowns.
According to U.S. Army, Alaska, officials, the rigid procedures had
caused them to delay the IRP while the contracts are amended to
include additional problems found. These delays can extend the IRP
by months and cause costs to increase because contractors must wait
while the contracts are amended. The total effect is to allow the
contamination to continue to spread, thus necessitating additional
cleanup work and possibly more contract changes.
Army officials stated that Corps officials agreed that the rigid
procedures for construction type contracts have caused problems in
environmental contracting. They state that the Corps is reviewing
its procedures to determine if changes can be implemented to
accommodate the need for more flexibility while at the same time
minimizing costs.
OPTIONS CONSIDERED
-------------------------------------------------------- Appendix II:4
U.S. Army, Alaska, officials told us that they have not reached the
point where they would consider which options to use in cleaning up
the installation.
OPTION SELECTED
-------------------------------------------------------- Appendix II:5
U.S. Army, Alaska, officials told us that nothing has been decided
concerning final clean up actions at the sites and for the cleanup of
groundwater. However, for selected sites, to prevent further
environmental contamination, the installation has taken interim
remedial actions to remove contaminants. These actions include
removing contaminated barrels, digging up contaminated soil and
removing it from the installation, and installing a groundwater
treatment facility. Most of these sites were considered to be "hot
spots" that could be cleaned up relatively easy and with minimal
costs. The installation has used various methods and some
technological advances in the cleanup program such as bioremediation,
land farms, and biopiles. The regulatory agencies concurred with the
actions taken to date. However, it has not been decided if further
work will be required at these sites because final agreement with the
regulatory agencies has not been reached.
EXPECTED COMPLETION
-------------------------------------------------------- Appendix II:6
U.S. Army, Alaska, and installation officials told us that because
they are still in the early stages of the IRP, they do not know when
the cleanup work will be completed, what the extent of contamination
is, or what the final remedies for most sites will be. The officials
stated that, if the installation is allowed to limit work to the
interim remedial actions at all of the sites, then the IRP could be
completed within the next 10 years, otherwise it could take longer.
REGULATORY PROCESS
-------------------------------------------------------- Appendix II:7
Installation and U.S. Army, Alaska, officials told us that as long
as the work is being done under the CERCLA process they have no
problems with the regulatory agencies. However, they believe the
CERCLA process as a whole is time-consuming and costly and slows down
the cleanup process. The Interagency Agreement was signed by the
state on December 24, 1991, by EPA on March 25, 1992, and the Army on
March 19, 1992. Installation officials believe that all of the sites
should be included in the agreement because it enables everyone to
concentrate on what needs to be done and provides a mutually agreed
upon basis for managing the work. As decisions are made on each
site, they will be incorporated into the agreement. Installation
officials firmly believe that the CERCLA process would have been much
slower if the procedure outlined in the Interagency Agreement had not
been in place.
DOD/REGULATORY AGENCY
COOPERATION
-------------------------------------------------------- Appendix II:8
The Alaskan Department of Environmental Protection and EPA located
their program managers near the fort with the authority to act for
each agency. Officials from the involved organizations (U.S. Army,
Alaska, EPA, and state regulatory agencies) told us that having all
three project managers located near each other, and their willingness
to work together, has resulted in a good working relationship. They
also told us that almost all of the decisions these three have made
have been right, resulting in little change to actions being taken.
The Army, at the DERA conference in Denver, Colorado, designated Fort
Wainwright as an example of how to implement the program and has
included the installation's IRP in its CERCLA management training.
The three program managers meet monthly, more if necessary. Actions
planned or being done by one activity are always discussed with the
other two. They deal with the small problems before they become big
ones. If they have a difficult problem, they check with their
supervisors to make sure the right decisions are implemented. They
each have technical experts either in-house or by contractor who
provide assistance.
An important feature of the close working relationship of the three
project managers is that they meet often to informally work out some
of the difficult problems. This arrangement leads to a better
understanding of the views of each manager. They believe that not
having frequent meetings and a good working relationship could result
in actions that may not be required or that are wrong. If this
happens, a lot of time and money could be spent correcting the
actions.
U.S. Army, Alaska, officials said that EPA and the state have been
extremely helpful to installation officials. They have conducted
tests, made the required analyses, and generally done whatever is
necessary to help get the work done. EPA has provided its technical
expertise to either start or complete the study and remediation work.
One concern, however, is that the state has placed stricter standards
on the installation's cleanup of petroleum, oil, and lubricant sites
than it has placed on the city. In this instance, the contractor is
required to dig up the contaminated dirt and take it to a storage
location where the state requires it to be placed in plastic-lined
storage facilities until it can be burned. (At the time of our
visit, the contractor was testing its proposed burning operation for
the fort on the city's petroleum-contaminated soil.) However, unlike
the contaminated soil at Fort Wainwright, the city's contaminated
soil is placed on the ground with no protection to the environment.
Installation officials believe that the city is not being held to the
same standard for treating waste as the installation is. By being
held to a stricter standard, to build the plastic-lined storage
facilities, the installation is incurring higher costs.
CLEANUP STANDARDS
-------------------------------------------------------- Appendix II:9
Installation, EPA, and state officials state that in an ideal world
one standard for each chemical would be the optimal solution for
cleaning up hazardous waste. But realistically, that cannot be done.
Each site is different and each chemical reacts differently depending
upon the environmental conditions.
Installation officials said that the cleanup standard for each
installation should be based on a risk assessment that considers what
the installation will be used for in the future. Thus, each
assessment would entail different goals for different installations
for the same contaminant. Like California, Alaska considers
petroleum, oil, and lubricant products to be hazardous waste, and
most of the sites on the fort to be cleaned up are contaminated with
these products. As of now, the state standard that Fort Wainwright
has to clean up to is drinking water standards.
STAFFING
------------------------------------------------------- Appendix II:10
U.S. Army, Alaska, including Forts Greely, Wainwright, and
Richardson, has 26 authorized positions to do all environmental work,
including installation restoration or CERCLA work. The U.S. Army
Force Integration Support Agency made a study of the U.S. Army,
Alaska's, environmental staffing in December 1993 and determined that
to adequately do all of the required environmental work, U.S. Army,
Alaska, would need 54 staff members. U.S. Army, Alaska, officials
stated that it is unlikely they will get any additional staff until
the Army lifts its hiring freeze. They also stated that one of the
primary reasons Army installations were assessed over $5 million in
punitive and stipulated fines since January 1993 was the shortage of
environmental staff to do the required work.
These officials stated that by not having the number of people
required there has been adverse effects on the total environmental
program. The primary one is that they have not been able to
adequately oversee the work being done by the environmental
contractors on the installations.
One staff member, the program manager (GS-12), oversees the IRP at
U.S. Army, Alaska, headquarters at Fort Richardson. Fort Wainwright
has four people working full time in the environmental area and a
number of "borrowed" military people assisting them. U.S. Army,
Alaska, and installation officials depend heavily on the Corps for
the contracting portion of the work, including the awarding,
administering, and monitoring of the contracts.
U.S. Army, Alaska, officials stated that keeping environmental staff
is difficult for the Army because it does not assign as high a grade
structure (top grade is a GS-13 at U.S. Army, Alaska, and GS-11 at
the fort) to its environmental programs at the installations as does
the Air Force (GS-13 at each Alaskan installation), the Navy (GS-13),
and the Bureau of Land Management Office in Anchorage (GS-13). The
officials have characterized the Army's program as the training
ground for all of the other federal agencies in Alaska. The training
that the Army provides is outstanding and recognized by all other
federal agencies in the state. However, to get more money and a
promotion, the Army staff have to go somewhere else, often doing the
same job or at times a lesser job.
U.S. Army, Alaska, and installation officials told us that the
staffing for the IRP work is not enough to oversee contractor work, a
responsibility of U.S. Army, Alaska. Because of its staffing
shortage, they have to rely too much on contractors. The contractors
are put in a position of getting the CERCLA work done, even though
they do not have the authority to act for the government in dealings
with the regulatory agencies.
Army officials told us staffing is not adequate to properly spend the
money now available, much less any more that might be provided them.
If the budget continues to grow and the Army continues to have its
current staffing problems, some funds could be inappropriately used.
For example, contractors may take actions not required (drill
unnecessary monitoring or test wells), will do things wrong (not
properly preserving test samples), or will not comply with
requirements (not using EPA-approved laboratories to perform the
tests), which could lead to additional costs in the future.
REGULATORY AGENCY STAFFING
------------------------------------------------------- Appendix II:11
Fort Wainwright and U.S. Army, Alaska, officials told us they have
not experienced any problems with the Alaskan Department of
Environmental Control because of any staffing shortages. State
officials, however, told us that they are beginning to experience
some serious funding and personnel problems and that these problems
could affect the adequacy of their work in the future.
U.S. Army, Alaska, officials told us that they have experienced some
problems in getting documents reviewed by EPA Region X officials
within the time frames set forth in the Interagency Agreement. A
Region X official told us that they have experienced some problems
reviewing documents timely because they do not have enough staff and
thus, the region has used contractors to review and analyze the
installation's submissions. U.S. Army, Alaska, officials state that
this approach has complicated the CERCLA process because a contractor
generally recommends to EPA that more work be done for each site. By
having the installation do more at each step of the process, the
contractor is able to continue working. As a result, the program is
delayed and costs increase significantly. A Region X official told
us they minimize the chances of this happening by requiring all
contractor work to be reviewed and approved by EPA staff.
FUNDING
------------------------------------------------------- Appendix II:12
Being on the NPL forces installation and U.S. Army, Alaska,
officials to focus on the problem, work out solutions, and deal with
the issues. It also enables them to get DERA funding easier. They
believe that the only way to get adequate cleanup money is to be
listed on the NPL.
The amount of funds received has been adequate. Additional money
could not have been used because Fort Wainwright and U.S. Army,
Alaska, do not have enough people to adequately oversee any more
contracting work. All of the sites identified on the installation
have been given equal priority for DERA funding.
MCCHORD AIR FORCE BASE CASE STUDY
========================================================= Appendix III
McChord Air Force Base, Washington, was formally dedicated in May
1938 on land deeded from Pierce County and occupies about 4,600 acres
near the city of Tacoma. As an Air Mobility Command facility,
McChord's current mission is to provide rapid airlift capability of
personnel and equipment to anywhere in the world. Significant
quantities of solvents, protective coatings, industrial products,
petroleum, oils, and lubricants have been used in maintenance and
operational activities in support of this mission and past missions.
As a result, McChord has some contaminated sites, which are similar
to those found on many other Air Force and Navy aviation
installations.
LISTING ON THE NPL
------------------------------------------------------- Appendix III:1
Unlike the current practice of DOD and EPA to place an entire
installation from fence to fence on the NPL, only two sites on the
installation were placed on the NPL. These two sites were (1) the
off-base American Lake Garden Tract with a Hazard Ranking System
score of 31.94 and the adjoining contiguous Area D, which has seven
individual sites, including the Whispering Firs Golf Course (site 5
landfill) and (2) the Washrack Treatment Area, including sites 54 and
60 with a score of 42.24. The American Lake Garden Tract and the
Washrack Treatment Area were placed on the NPL in September 1984 and
July 1987, respectively.
Two landfills may be leaching contaminants into the groundwater and a
contamination plume was documented to be spreading under the American
Lake Garden Tract from Area D and the site 5 landfill. The
groundwater, at the 140- to 500-foot level, is used for drinking
water, and it is contaminated with TCE and other wastes from both NPL
sites. TCE has shown up in two of McChord's wells; however, most of
the sample test readings were below the 5 parts per billion (ppb)
Maximum Contaminant Level set by EPA. The readings for the highest
test well ranged from 0.08 to 120 ppb. The Washrack Treatment Area
has a stationary layer of fuel and oil floating on the water table.
Even though there is some groundwater contamination, McChord
officials do not believe any installation sites should be on the NPL.
The contamination is not very bad, and the installation has paid to
have the American Lake Garden Tract area hooked up to the regional
water system. They believe the decision to put McChord's sites on
the NPL was a "political decision," not one based on significant
evidence. In other words, during the early stages of the Superfund
program, EPA was under pressure to get sites on the NPL, and
McChord's sites were two possibilities where the listing could be
done rather quickly and easily.
EPA officials stated that in the early stages of the NPL effort,
there were very few sites with enough data to determine if they
should be listed. In the case of McChord, they knew the installation
had some groundwater contamination and they decided to list it.
STATUS OF THE IRP
------------------------------------------------------- Appendix III:2
McChord officials believe the IRP Phase I study and the follow-on
CERCLA preliminary assessment and other investigative work have
identified all sites on which McChord has any data. However, there
is the possibility that unknown sites may be found.
The Phase I study identified 62 sites. Subsequent study work
confirmed most of these sites and identified 2 additional sites, for
a total of
64 hazardous waste sites. In addition, 22 DERA eligible underground
storage tanks with contamination problems were designated as site 65.
These
22 tanks were later removed from the DERA-funded effort to an
environmental compliance-funded project, which is complete. Table
III.1 depicts the status of CERCLA work at McChord.
Table III.1
Status of Sites at McChord Air Force
Base
No. of sites
that reached
or
will reach
CERCLA process phase phase
-------------------------------------------- --------------
Study 65
Interim remedial action-underway 0
Interim remedial action-complete 1
Remedial action 6
Remedial action in place and operating 1
Remedial action complete 0
Closed out-no further action 58
------------------------------------------------------------
Of the original 62 sites, a large number of them were included in the
Phase I study because someone believed some waste may have been
disposed of at the site, but there was no evidence or documentation
supporting this belief. McChord officials said that 52 sites should
not have been included and would not have been if they had been in
the private sector. McChord submitted to EPA a No Further Response
Actions Planned document on August 15, 1994, for 58 sites.
Installation officials consider these sites to be finished. EPA and
the state have agreed to the no further action decisions on 24 of the
58 sites.
COST
------------------------------------------------------- Appendix III:3
Through 1993, McChord had spent $12.5 million, and it expects to
spend, based on its understanding of the Interagency Agreement
requirements, a total of $20.1 million through 2005. The total cost
does not include any changes that may be made to the IRP or any
additional requirements resulting from changes in the laws or
regulations.
McChord is using a task order contract, which officials believe
permits the installation to get the work done in a timely manner and
at the lowest costs possible. The preliminary assessment cost about
$50,000. The remedial investigation/feasibility study for the
American Lake Garden Tract cost $3.1 million and took over 37 months
to complete. However, McChord officials believe that the annual
costs will start to decrease because future costs will be for
long-term monitoring and the operation and maintenance of the pump
and treat system, which was built at a cost of $1.5 million.
OPTIONS CONSIDERED
------------------------------------------------------- Appendix III:4
The options considered for the American Lake Garden Tract were
no action, with monitoring only;
one groundwater extraction system, one carbon adsorption treatment
facility, and irrigation/recharge of treated groundwater;
three groundwater extraction systems, two carbon adsorption treatment
facilities, and irrigation/recharge of treated groundwater; and
three groundwater extraction systems, two carbon adsorption treatment
facilities with addition of bioremediation, and irrigation/recharge
of treated groundwater.
The options considered for the Washrack Treatment Area were
no action except monitoring of the groundwater;
institutional controls to prevent access to the site;
containment of the floating layer of oil by installing a cap and
institutional controls;
installation of a groundwater/fuel extraction system, a treatment
system to remove the fuel from the groundwater, and off-site
recycling of the recovered fuel;
an excavated trench, passive fuel removal, off-site recycling of
recovered fuel, and bioremediation of the soil excavated from the
trench at a contractor's site off the installation; and
bioremediation of the fuel and fuel contaminated soil in place at the
site.
OPTION SELECTED
------------------------------------------------------- Appendix III:5
For the American Lake Garden Tract, the Record of Decision calls for
installing a pump and treat system with long-term monitoring. At
first, McChord officials believed it was a "bad decision" to try and
clean up the aquifer. But now McChord, EPA, and Washington
Department of Ecology officials agree that the aquifer will not be
cleaned up in the near future, maybe decades, if ever. However, they
agreed that the pump and treat system will be used to contain and/or
manage the contamination plume so that contamination will not spread
further. McChord will provide institutional control to prevent any
disturbances of the contamination.
The Record of Decision for the Washrack Treatment Area calls for
installing a fuel extraction trench and collection system for passive
fuel removal. The collected oil will be sent to a recycling
treatment facility. Long-term monitoring of the groundwater will
determine if the contamination leaves the installation, and
institutional controls to prevent disturbance of the contamination
will be implemented.
However, a pilot study, conducted as part of the remedial design
phase, showed that the amount of fuel at the site was over estimated
in the remedial investigation/feasibility study. Consequently, it
was determined that the selected remedial action was not feasible.
Therefore, McChord, in agreement with the state and federal
regulators, developed an Explanation of Significant Difference
document that recommended that no remedial action be taken, but that
long-term monitoring should be done. As agreed upon, the long-term
monitoring program should begin in fiscal year 1995.
EXPECTED COMPLETION
------------------------------------------------------- Appendix III:6
According to the October 1993 Management Action Plan, remedial
actions at McChord will not be completed until 2005. McChord
officials state that even then long-term monitoring will probably
continue for an unknown length of time, maybe decades.
REGULATORY PROCESS
------------------------------------------------------- Appendix III:7
McChord officials believe all sites on the installation should have
been included in the Interagency Agreement. However, a three-party
agreement (EPA, state, and McChord) was signed to include only the
two NPL sites. A Consent Decree, or two-party agreement, with the
Washington Department of Ecology was signed for 29 additional sites
covered by the state's Model Toxic Control Act. The act allows the
installation to have more latitude on what is to be done, to focus
its study efforts, and to set time frames or deadlines for those
sites not on the NPL.
McChord officials believe that the CERCLA process has delayed the
remedial investigation/feasibility study phase. EPA has issued a
number of guidance documents for this phase that requires an
installation to conduct studies, prepare reports, submit draft
reports to EPA for review, and incorporate EPA's comments in the
reports and plans. This is a problem because EPA wants the
installation to do the study and analysis work to come up with an
iron-clad case that will stand up to public scrutiny. McChord
officials said that EPA officials have told them that for the
remedial decision to stand up to public scrutiny, the installation
must prepare the same documents that would be needed to make the case
stand up in the courts.
Each section of the process usually has several versions of any
reports or plans. For example, a preliminary draft is prepared and
submitted to EPA for review and comment. EPA provides its comments,
which are prepared by its contractors, to McChord, which then has its
contractor review EPA's comments and incorporate the changes and
resubmit the draft to EPA as a final draft. EPA reviews and submits
its comments on the final draft to McChord, which incorporates the
comments into the final report.
For the period July 1988 through September 1991, McChord officials
analyzed the time spent preparing and revising documents submitted to
EPA. During that time, 25 documents were prepared, often including
multiple versions that incorporated EPA's and the state's comments.
Review of each version of each plan or report usually costs $20,000
to $30,000.
EPA and the state required McChord to make a risk assessment for the
two NPL sites. Even though the Washrack Treatment Area is in an area
where industrial activity continues, EPA required McChord to use
residential standards. EPA said that McChord should assume in its
risk assessment that condos will be built on the site and children
will be playing in the area and all people living in the condos will
get their drinking water from the shallow aquifer.
The installation has faced difficulties in resolving differences
between the regulatory agencies. If they require different actions
or set different standards, McChord resolves the differences and
determines what is to be done, which takes time and causes IRP
delays. EPA officials told us that they are trying to minimize their
differences with state officials so the IRP can proceed.
DOD/REGULATORY AGENCY
COOPERATION
------------------------------------------------------- Appendix III:8
Generally, during the last couple of years, McChord has had a very
good working relationship with the regulatory agencies. There are no
problems with the way things are being done at the present time.
This increased cooperativeness has come about partially because of
the changes instituted by the Air Force and EPA due to the good
working experiences EPA has had with Fort Wainwright.
The Washington Department of Ecology is the state regulatory agency
responsible for oversight. McChord officials state the working
relationship with Ecology has been outstanding because it is willing
to work with the installation to accomplish the cleanup.
McChord officials state they had trouble getting EPA to review their
documents in a timely manner, which has caused delays in getting work
done. EPA uses contractors to review the documents and reports
submitted by McChord because EPA does not have the staff to do it.
EPA officials state that any products prepared by their contractors
must be reviewed by EPA staff before being released to McChord. At
times, this review by EPA staff has been less than desired because of
the workload. McChord officials do not believe this has caused any
insurmountable problems.
McChord officials told us that the biggest problem encountered with
contractors, not just McChord's, is that they are involved in the
decision-making process for the program. They believe that a cleanup
program should not be controlled by a contractor. DOD needs to
insure that adequate numbers of people with the required technical
expertise are available (1) to oversee the contractors and (2) to use
the contractor-prepared data in deciding what has to be done.
CLEANUP STANDARDS
------------------------------------------------------- Appendix III:9
According to McChord officials, there should be only one set of
standards. However, since sites are so different, it may be
necessary to establish a cleanup goal for large badly contaminated
sites. The hydrology is very site specific, and often cleanup
standards cannot be technically achieved or are not economically
feasible. Any applicable state standard that is more stringent than
the comparable federal standard and is legally applicable or relevant
and appropriate under the circumstances will apply. McChord
officials believe the state of Washington may have gone too far
because some standards are not measurable with today's equipment.
STAFFING
------------------------------------------------------ Appendix III:10
Generally, McChord was able to hire, train, and retain staff. It
currently has seven people, which is enough to manage the work done
at the current funding level, and it does not expect to receive
additional funds. McChord officials stated that they need to
maintain high grades to attract high quality, fully trained staff
with experience. Recently the Air Force mandated reductions in
DERA-funded staff. Consequently, McChord will lose some of its
DERA-funded staff in fiscal year 1996.
REGULATORY AGENCY STAFFING
------------------------------------------------------ Appendix III:11
McChord officials are not aware of any insurmountable problems caused
by the number and quality of staff at the regulatory agencies other
than the time it takes to have documents reviewed.
FUNDING
------------------------------------------------------ Appendix III:12
Under current Air Force procedures, the NPL sites with signed
Interagency Agreements get the highest funding priority. The next
priority is for non-NPL sites that have compliance deadlines. Since
all of McChord's sites are subject to regulatory deadlines, there
have been no problems in obtaining the required funds. However,
McChord officials believe that in the future, DERA funds may not be
enough to get the work done at all installations. As a result, there
is a need for some type of priority setting system to determine which
installations and which sites on each installation will receive
money. Consequently, according to these officials, DOD may have to
tell the regulators it cannot clean up all of the sites. Air Force
headquarters has informed McChord officials that the Air Force
funding priorities are scheduled to change in fiscal year 1997. A
risk assessment approach will replace the current priority scenario.
Two ways to reduce costs are
clean up only the bad sites and delay or not do the clean up for
sites that do not pose a risk to the environment and
modify the amount of study required for some of the lesser sites so
that quick removal actions can be undertaken.
MCCLELLAN AIR FORCE BASE CASE
STUDY
========================================================== Appendix IV
The Sacramento Air Logistics Center, California, is a large
industrial complex located on McClellan Air Force Base. The Center's
primary mission is aircraft maintenance. In performing its mission,
the Center generates more than 470 different hazardous waste streams,
including solvents, caustic cleaners, low level radioactive waste,
polychlorinated biphenyls (PCB), heavy metals, and a variety of fuel
oils and lubricants. The previous disposal practices for wastes from
these industrial type operations have resulted in significant
environmental contamination.
LISTING ON THE NPL
-------------------------------------------------------- Appendix IV:1
EPA scored McClellan using the Hazard Ranking System in 1984 and
placed the entire installation on the NPL in July 1987. McClellan's
score of 57.93 is the highest of any Air Force base. However,
McClellan officials state the contamination is actually much worse
than what was known in 1984 and what the score indicates. Over the
years waste products from industrial activities have been dumped into
disposal ponds located throughout the installation. These hazardous
wastes have percolated into the soil and groundwater, and the
contamination is migrating off the installation. There are three
huge plumes of contaminated groundwater containing more than 11
billion gallons and reaching depths of 400 feet beneath the
installation.
The worst contaminated groundwater is near the installation's western
boundaries and drinking water wells have been closed, the drilling of
new water wells banned, water purification systems installed, and 540
off-base citizens connected to public water supplies. More than 400
acres of soil have been contaminated to depths exceeding 300 feet for
an estimated total of 1.5 billion cubic feet of contaminated soil and
more than 11 billion gallons of contaminated groundwater.
TCE has been detected in the shallow, middle, and deep water-bearing
zones of the aquifer with 45,000 ppb as the highest level detected.
Other contaminants detected and the amounts are 1, 2 Dichloroethylene
(600 ppb), Tetrachloroethylene (1,400 ppb), Vinyl Chloride (2,700
ppb), and Carbon Tetrachloride (500 ppb).
STATUS OF THE IRP
-------------------------------------------------------- Appendix IV:2
An Interagency Agreement was signed with EPA and the California EPA
in July 1989. The preliminary assessment/site inspection phase is
complete, and 258 potentially contaminated sites have been
identified. Most of these sites are now in the remedial
investigation/feasibility study phase. Table IV.1 depicts the status
of sites at McClellan.
Table IV.1
Status of Sites at McClellan Air Force
Base
No. of sites
that reached
or
will reach
CERCLA process phase phase
-------------------------------------------- --------------
Study 258
Interim remedial action-underway 15
Interim remedial action-complete 134
Remedial action 255
Remedial action in place and operating 0
Remedial action complete 3
Closed out-no further action 36
------------------------------------------------------------
The sites are divided into 11 operable units. The following are
three examples of an operable unit's location, number of sites, type
of contaminant, and actions being taken.
Operable Unit A, in the southeastern portion of the installation, is
the oldest and most densely built-up area and contains 121 sites.
Contaminated sites include repair shops, photo and other
laboratories, PCB and asbestos storage areas, motor pools, wash
racks, gas stations, oil water separators, sewer drains and sumps,
industrial waste treatment plants, acid and cyanide disposal pits,
and landfills. Regulatory agencies have preliminarily concurred with
the Air Force's suggestion of no further investigation at three
sites. The Interagency Agreement calls for the remedial
investigation/feasibility study to be conducted based on a site
prioritization model, with high priority sites proceeding with
remediation first. Site prioritization is currently underway.
Operable Units B and C, in the western and southwestern portions of
the installation, contain about 1,350 million cubic feet of
contaminated soil and 2 plumes of groundwater contamination that join
to create a single 10-billion gallon plume contaminated by several
contaminants, including TCE, which reaches depths of 400 feet.
Operable Unit B contained 48 sites and Operable Unit C contained 43.
Both included waste disposal pits and trenches, landfills, sewer
lines, underground storage tanks, and an industrial waste treatment
plant with surface impoundments. Most of the underground storage
tanks have been removed and/or replaced with above ground storage
tanks or state of the art underground storage tanks. The underground
storage tank program to remove or replace single walled tanks is
scheduled to be completed in 1996, ahead of the 1998 compliance
deadline. The surface impoundments were shut off in 1988 and were
surface sealed in 1989.
One of the installation's drinking water wells, number 18, was shut
down in 1981, after volatile organic compounds were detected in
quantities above the action level. An activated carbon filtration
system was installed in 1985 for the well. This system is still in
operation, and bimonthly filtration system and effluent sampling and
analysis has shown no volatile organic contaminants above the action
level.
In December 1986, the Air Force completed construction of the
groundwater treatment plant at a cost of $4.8 million. This plant
treats contaminated groundwater pumped from 15 extraction wells--6
wells in Operable Unit D ($1 million), 7 wells in Operable Unit C
($1.5 million), and 2 wells in Operable Unit B ($700,000). At the
time of our visit, the plant was treating 250 gallons per minute, but
it was designed to handle up to 1,000 gallons per minute. The plant
is effective in controlling the flow of groundwater in shallow,
middle, and deep water-bearing zones.
COST
-------------------------------------------------------- Appendix IV:3
The Air Force has spent more than $155 million on cleanup at
McClellan through fiscal year 1994. Air Force officials recently
reduced the cost estimate made in 1992 by $300 million, to $1.3
billion. However, this revised estimate relies on assumptions that
new emerging technology can be used, the completion date can be
extended to the year 2010, and new initiatives will be successful.
McClellan officials state the science and technology needed to
economically clean up massive amounts of contaminated soil and
groundwater, like those under McClellan, are not currently available.
They state it would cost a prohibitive $10 billion to clean up the
installation using existing or current technology by the Air Force's
completion goal of the year 2000.
Delaying the cleanup of contaminated sites can increase the cost if
the contamination is allowed to migrate and enter the groundwater.
However, installation officials state that taking extra time can also
be a vehicle to reduce cleanup costs. They note it may be better to
contain and manage contaminated sites until emerging technology, now
being studied and tested, becomes available and natural remediation
is also occurring with the passage of time. They state that if an
installation rushes in and installs treatment systems that are not
proven, the cost for cleaning up the site may be increased, first by
the system installed if it does not work and second by having to
install a new system later.
OPTIONS CONSIDERED
-------------------------------------------------------- Appendix IV:4
McClellan, in cooperation with EPA, is testing a number of new
technologies for remediating massive amounts of both contaminated
soil and groundwater economically. These emerging technologies
include a two-phased extraction and soil vapor extraction. McClellan
officials hope to assess the feasibility of dislodging contaminants
trapped in the soil by lowering the localized groundwater table and
then extracting the contaminants with vacuum pressure. McClellan
officials also hope to assess the feasibility of lowering the
localized groundwater table and extracting contaminants associated
with vapors, instead of water, using vacuum pumps.
OPTION SELECTED
-------------------------------------------------------- Appendix IV:5
The final options have not been selected, but McClellan officials
state that the installation's huge amount of contaminated soil and
groundwater are too massive to economically clean up with current
technology. Instead, McClellan officials have implemented various
actions to limit human exposure to contaminated groundwater and soil
as natural remediation occurs and new and better technologies are
developed. These actions include installing pump and treat systems
and the removal of hot spots or high concentrations of contaminated
soil. In addition, they are cooperating with EPA to develop and test
various new methods of remediating the soil that may be more
economical.
EXPECTED COMPLETION
-------------------------------------------------------- Appendix IV:6
Installation officials state the Air Force's goal of completing the
cleanup by the year 2000 is not realistic. They believe that by
stretching the installation's IRP out to 2010 they can use emerging
technology and let natural remediation occur. In the interim, they
will protect the public by limiting exposure.
REGULATORY PROCESS
-------------------------------------------------------- Appendix IV:7
McClellan officials state the CERCLA process was primarily designed
to identify and correct only a few contamination problems at the
installation. However, McClellan's contaminated sites have massive
amounts of contaminated soil and groundwater and have a variety of
problems. According to the officials, the proper evaluation of the
problems and their solutions requires that the process be tailored to
the conditions on the installation.
McClellan has conducted several removal and interim actions, using
the Superfund Accelerated Cleanup Model version of the CERCLA
process. Some were implemented prior to the remedial
investigation/feasibility study and/or remedial design phases being
completed. These actions were designed to stabilize a site, prevent
further degradation, or achieve risk reduction in terms of the threat
posed to the public or to the environment.
During our visit, McClellan officials complained about the regulatory
process being slow. They stated that EPA had trouble providing
timely review of and comment on documents. Also, they stated it was
virtually impossible to get regulatory agencies to agree that nothing
more needed to be done at sites that have been cleaned up.
However, McClellan and the regulatory agencies created the
Environmental Process Improvement Center, a cooperative grouping of
the parties to the Interagency Agreement, including McClellan, EPA,
and the California EPA. The goals of the Center include accelerating
site cleanup, preventing pollution, applying new cleanup
technologies, and sharing compliance strategies. Since the creation
of the Center, the IRP activities have progressed at a faster rate.
For example, the Air Force has implemented removal actions as the
expedited response to control the migration of contaminants beneath
Operable Unit B before it reached the installation boundary or well
Number 18.
DOD/REGULATORY AGENCY
COOPERATION
-------------------------------------------------------- Appendix IV:8
McClellan officials state that the working relationship between
installation officials and the regulatory agencies has improved since
the Center was created. McClellan officials state that they have
found the cooperative working relationship and the team partnership
approach with regulatory agencies are much better because they
eliminate the adversarial relationship and litigation and promote the
cleanup process. McClellan officials state that team interaction
helps them move through most difficulties, shortens time frames, and
reduces costs.
CLEANUP STANDARDS
-------------------------------------------------------- Appendix IV:9
McClellan officials believe cleanup standards should be set by EPA,
not the states since EPA's standards are designed to limit exposure
to a substance that may be unhealthy. The amount of exposure may
vary based on age as the very young and old tend to be more
sensitive, but it should not vary by site. However, they believe
that cleanup goals, which are based on the cleanup standard and the
likelihood of exposure and are usually quite site specific, should be
set for each site by EPA, state regulators, and DOD.
McClellan officials state small contaminated sites can be cleaned up
to a cleanup standard less expensively by removing or treating
relatively small amounts of contaminated soil rather than conducting
a risk assessment. However, it is often not economically feasible,
technically possible, or necessary to achieve the cleanup standard
for sites with massive amounts of contaminated soil. They also note
that it is not possible to return contaminated aquifers to drinking
water standards or pristine conditions for decades with existing
technology but that the public can be protected by treating the
groundwater extracted for drinking purposes. EPA does not fully
agree with McClellan's position, but they are working with the
installation to develop strategies for cleaning up as many sites as
possible and getting out of the CERCLA process.
STAFFING
------------------------------------------------------- Appendix IV:10
McClellan officials told us that they do not have sufficient staff to
support the growth of the IRP. The downsizing of DOD and the federal
work force has made it extremely difficult to attract well qualified
candidates. During the past year, McClellan has had a 30- percent
turnover rate in its IRP resources. When vacancies occurred, it was
difficult to hire replacements due to major personnel constraints
from base closure and realignment actions. The average time to fill
vacancies has tripled during the past year and positions were being
filled with personnel with limited or no environmental experience or
training. In addition, they stated that proposed reduction-in-force
actions would eliminate over 20 percent of their DERA-funded
personnel. If this occurs, there will be severe impacts to
McClellan's ability to maintain the progress that has occurred in IRP
activities over the last decade.
REGULATORY AGENCY STAFFING
------------------------------------------------------- Appendix IV:11
McClellan officials noted that EPA and the state regulatory agencies
have good technically qualified people, but neither have enough, and
there has been a significant turnover of EPA's technical staff.
State regulatory officials stated that they need more people and that
turnover is a significant problem. They also stated it is difficult
to hire qualified and experienced people in many of the specialties
needed for this work because it is a relatively new area of endeavor.
FUNDING
------------------------------------------------------- Appendix IV:12
McClellan officials stated that funding has not been adequate to
achieve the Air Force's goal of completing cleanup by the year 2000.
Anticipated funding levels also do not support meeting original
Interagency Agreement schedules. However, all agencies recognize
that cleaning up all sites, regardless of the risk it poses, is not a
cost-effective approach. As a result, McClellan is changing from an
operable unit cleanup schedule toward a basewide schedule that is
driven by the risk posed. McClellan officials believe that the
risk-based approach will be more cost-effective, providing current
efforts to accelerate the development of innovative and emerging
cleanup technologies.
PEARL HARBOR NAVAL COMPLEX CASE
STUDY
=========================================================== Appendix V
The Pearl Harbor Naval Complex,\1 the product of more than a hundred
years of peace and wartime development, is located on 6,300 acres
along the southern coast of the Island of Oahu. The installation's
primary mission since the early 1900s has been ship repair. Shore
facilities and wharfs have been constructed, expanded, and improved
to meet changing needs of the U.S. fleet. Today, the Complex
provides facilities, services (including maintenance), and materials
in support of the U.S. Pacific Fleet.
Past inappropriate handling and disposal of hazardous substances,
including waste oils, pesticides, heavy metals, PCBs, solvents,
chemical wastes, and fuels have contaminated the environment. The
releases were often the result of accidents such as leaks, spills,
and ruptured containers. However, in many instances, the releases
were due to disposal practices deemed acceptable at the time.
--------------------
\1 The Complex consists of seven activities: Shipyard, Naval
Station, Public Works Center, Inactive Ships Center, Submarine Base,
Naval Magazine Lualualei (West Lock Branch), and Fleet Industrial
Supply Center.
LISTING ON THE NPL
--------------------------------------------------------- Appendix V:1
The Complex was listed on the NPL in October 1992. In 1991, EPA
scored six sites under the Hazard Ranking System. While EPA did not
include more than 50 other potentially contaminated sites at these
activities in its evaluation, it reserves the right to designate
additional sites under its aggregation policy of considering all
sites in the Complex as a single NPL site. The Complex's Hazard
Ranking System score of 70.82, the highest of any DOD installation,
is a composite score based on the six sites.
Navy officials agree that the Complex should be on the NPL, but
stated it should not have the highest score of any DOD installation.
They are concerned the high score could cause bad publicity and extra
EPA requirements and oversight, which could delay cleanup efforts.
Navy officials sent a letter to EPA questioning the validity of the
score, noting that each of the activities' individual scores would
have only been in the low 30s, which would have given the Complex a
low NPL ranking.
STATUS OF THE IRP
--------------------------------------------------------- Appendix V:2
The 1983 Navy Assessment and Control Of Installation Pollutants
Initial Assessment Study\2 identified and evaluated 32 potentially
contaminated sites with regard to contamination characteristics,
migration pathways, and pollutant receptors. Of the 32 sites, 3 were
recommended for further study and were listed in order of priority:
Pearl City Peninsula Landfill, Red Hill Oily Waste Disposal Pit, and
Transformer Station D4.
EPA disagreed with the Navy's position taken in its preliminary
assessment study and requested further investigation at 16 additional
sites of the 32, but made no reference to the remaining 13 sites.
Subsequently, the Navy identified another 29 sites for a total of 61.
Table V.1 depicts the status of CERCLA work at the Complex.
Table V.1
Status of Sites at Pearl Harbor Naval
Complex
No. of sites
that reached
or
will reach
CERCLA process phase phase
-------------------------------------------- --------------
Study 61
Interim remedial action-underway 2
Interim remedial action-complete 4
Remedial action 46
Remedial action in place and operating 0
Remedial action complete 0
Closed out-no further action 18
------------------------------------------------------------
The six sites scored under the Hazard Ranking System included two
sites--the former gyro repair shop and the former metal pickling
waste disposal site--that the Navy had determined no further action
was required under the CERCLA process. Also, EPA's request for
further investigation did not include them. According to Navy
officials, neither of these sites affected potable water as the
groundwater under them is brackish (salty) water. The nearest
potable water well is several miles up-grade in the opposite
direction of groundwater flow.
As new sites are identified, they are included for investigation on a
priority basis. Site inspections have been completed or are being
completed for most Pearl Harbor sites.
The Navy, EPA Region IX, and the state's Department of Health entered
into an Interagency Agreement in April 1994. The agreement
establishes a framework to investigate and clean up the Complex.
--------------------
\2 The assessment is equivalent to the CERCLA Preliminary Assessment.
COST
--------------------------------------------------------- Appendix V:3
The Navy has spent about $26 million and estimates it will cost about
$196 million to complete clean up of the contaminated sites. The
cost estimate is based on initial job scopes and may increase
significantly once more is known about the sites and the remediation
phase begins.
OPTIONS CONSIDERED
--------------------------------------------------------- Appendix V:4
Navy officials stated that the IRP has not progressed far enough to
determine which cleanup options will be considered for the Complex.
Progress in the IRP has been slow because the Complex was not
designated a NPL installation until October 1992. Without the NPL
designation, funding was hard to get and the work done was limited.
As interim measures, the Navy is considering bio-remediation and
pumping to remove oil floating on the subsurface groundwater.
Currently, an oil-water separator, booms, and oil skimmers collect
oil that seeps through cracks in a storm drain leading into Pearl
Harbor after heavy rains. Another small oil recovery project has
been installed to determine the feasibility of pumping the oil out of
the aquifers.
OPTION SELECTED
--------------------------------------------------------- Appendix V:5
The work has not progressed far enough to select the final cleanup
options yet.
EXPECTED COMPLETION
--------------------------------------------------------- Appendix V:6
During the Interagency Agreement signing ceremony, officials from the
Hawaii Department of Health and EPA Region IX announced that the
cleanup could take up to 30 years to complete based on the number of
sites, collection requirements, and remedial action required.
REGULATORY PROCESS
--------------------------------------------------------- Appendix V:7
Navy officials believe the elaborate CERCLA process does not need to
be performed on small sites that could easily be remediated without a
large-scale study and those sites covered by previous agreements with
EPA. In addition, the CERCLA process of determining liability is not
needed for sites that are the Navy's responsibility, so there is no
need to prepare documents in anticipation of litigation to determine
who should pay for remediation.
DOD/REGULATORY AGENCY
COOPERATION
--------------------------------------------------------- Appendix V:8
The Naval Facilities Engineering Command's Pacific Division has a
good working relation with EPA and state regulatory officials. The
Navy informs the state and EPA on the progress of its cleanup studies
and actions. Because the Complex was not on the NPL until October
1992, EPA had not been a problem because it focused on NPL sites.
However, since October 1992, EPA has begun to provide more oversight
at the installation. The Complex has not encountered any
difficulties with multiple controls by the regulatory agencies
regarding oversight.
CLEANUP STANDARDS
--------------------------------------------------------- Appendix V:9
Pacific Division and Pearl Harbor Complex officials all agreed that
contaminated sites need to be cleaned. However, they question the
need to clean all sites to standards that may exceed naturally
occurring conditions or when such cleanup is not technically or
economically feasible. They advocated programs such as stopping
contamination flow into groundwater and preventing the contamination
from spreading.
Navy officials had no opinion as to whether there should be one set
of cleanup standards and who should set them. They noted that the
state relies upon EPA standards but does provide some state
guidelines for specific chemicals. Navy officials state the Navy
contractor for Comprehensive Long-Term Environmental Action
researched the current federal and state cleanup standards for each
site but did not note a specific problem with any standards.
STAFFING
-------------------------------------------------------- Appendix V:10
Unlike mainland installations, Pacific Division and Pearl Harbor
Complex officials told us they are generally able to hire, train, and
retain qualified people. Staffing for the Environmental Division,
Pacific Division, has more than doubled in the last 5 years to 65
persons, of which 18 are designated for the IRP, because the Navy
pays more than the city and county of Honolulu and the state. In
addition, because most of the environmental work is done through the
Pacific Division, which handles most of the naval installations in
the Pacific Ocean area, the Navy is able to provide higher grades to
its workers than the state or other services. The limited number of
staff (four) that have left so far, have gone primarily to private
industry. However, officials noted that they could use more
specialized training in areas such as soil assessment and data
validation.
The Navy ensures cleanup is being accomplished in the most
cost-effective manner with four organizations. The Pacific Division,
Navy Facilities Engineering Command, is the focal point for Complex
activities, provides technical expertise to the Restoration Advisory
Board, assesses cleanup options, distributes DERA and Navy
environmental funds, and provides legal advice. The Commander of the
Naval Base chairs the Restoration Advisory Board and is the
environmental coordinator who ensures consistency of policy with
state regulators, facilitates policy distribution and resolution of
disputes between field activities, and is in charge of community
relations. The individual field activities have primary
responsibility for compliance and own the land. The contractor
provides environmental study/evaluation support.
REGULATORY AGENCY STAFFING
-------------------------------------------------------- Appendix V:11
At the time of our visit, officials from the state's Department of
Health, the primary regulator, stated that the Department was
severely understaffed to perform oversight on both government and
privately owned sites and therefore they had focused on private
industry where they felt they could get more accomplished. Since
April 1994, the Department has hired what it considers to be an
adequate number of staff to do the oversight work. They stated that
they do not have a problem with the Navy's efforts because of the
good working relationship that they have had since they were able to
obtain the needed staff.
Navy officials, however, told us that based on EPA's lack of timely
response to routine reports from the installation, EPA may have been
understaffed. At the time of our visit in 1993, officials from EPA's
Region IX Office told us that because of the very large number of NPL
sites in its region and the limited number of staff, they could not
accomplish all of the oversight work required for installations on
the NPL. As a result, they were doing little oversight of non-NPL
installations. In subsequent information provided in October 1994,
EPA officials stated that their staffing situation had improved and
they were providing the required oversight for federal facilities on
the NPL.
FUNDING
-------------------------------------------------------- Appendix V:12
Navy officials told us that there is a funding shortage for the IRP
for all installations. However, the Complex does not have a funding
problem because it is on the NPL and receives funding priority.
According to Navy officials, there is adequate funds available to
investigate and clean up the Complex. Pacific Division evaluates
each site separately to determine which site will get DERA funding
based on the threat to human health and status of remediation
projects. For sites that may require remedial or removal actions,
the Navy uses the Defense Priority Model score to prioritize funding.
The Pacific Division prioritizes sites based on the Chief of Naval
Operations' funding policy, which is to fully fund only those sites
on the NPL or subject to legal time frames set under federal, state,
or local regulations.
Navy officials stated that an entire installation could be designated
an NPL site and get priority funding, even if only one site on the
installation is a "worst" site. Such funding disparities could
result in less critical sites receiving funding when more critical
sites at another installation that is not on the NPL does not. As a
result, Pacific Division and Pearl Harbor officials do not believe
all of the sites on the installation should be included in the NPL
designation.
SCHOFIELD BARRACKS CASE STUDY
========================================================== Appendix VI
Schofield Barracks, established in 1908 for the Army's mobile defense
of Oahu, is the largest and most populated installation in Hawaii.
As the headquarters of the 25th Infantry Division and the 45th
Support Group, its mission is to provide administration, training,
and housing facilities for these two units, as well as depot and
repair facilities for helicopters, trucks, and other support
equipment; a medical facility; and community and housing support.
Training includes firing and nonfiring activities. Schofield also
provides administrative support, including environmental, to several
smaller Army activities in Hawaii.
LISTING ON THE NPL
-------------------------------------------------------- Appendix VI:1
TCE contamination was found in Schofield's drinking water wells in
1985. These wells extract water from one of the few large
groundwater aquifers on the Island, which discharges into the larger
Pearl Harbor Aquifer. The TCE source is not known, but tests are
being conducted. The presence of TCE at 40 ppb in one of the wells,
which was above EPA's maximum contaminant level of 5 ppb, was the
reason Schofield was placed on the NPL in September 1990. The Hazard
Ranking System score was 28.9, one of the two lowest scores for any
DOD installation on the NPL.
Army officials initially disagreed with EPA's decision to place the
installation on the NPL because there was no conclusive evidence
indicating Schofield was the source of the TCE contamination. They
cited suspected sources such as a small industrial area off the
installation near the water wells. However, additional study
indicates the installation's landfill, other sites on the
installation, and Wheeler Army Airfield (formerly Wheeler Air Force
Base) could also be sources.
STATUS OF THE IRP
-------------------------------------------------------- Appendix VI:2
Schofield has sites in various study and remediation phases,
including the early phases. An August 1990 Army study identified and
scored potential hazardous waste sites on the installation. The
study was the basis for the sites specified in the Interagency
Agreement. With this study, installation officials believe they have
identified the potential sites and are developing work plans for
further investigation in coordination with EPA. The preliminary
assessment/site inspection phase began for most sites during 1992.
EPA has expanded the number of sites needing further investigation to
116. Table VI.1 depicts the status of CERCLA work at Schofield
Barracks.
Table VI.1
Status of Sites at Schofield Barracks
No. of sites
that reached
or
will reach
CERCLA process phase phase
-------------------------------------------- --------------
Study 116
Interim remedial action-underway 0
Interim remedial action-complete 1
Remedial action 30
Remedial action in place and operating 1
Remedial action complete 1
Closed out-no further action 49
------------------------------------------------------------
Although installation officials believe they have identified all of
the sites, it is possible additional sites could be found. To
determine whether the contamination is spreading off the
installation, Schofield had a contractor test private drinking water
wells near the installation for contamination. Results from these
tests did not show any TCE contamination at private wells. However,
some of the wells on Field Station Kunia, a small Army installation
adjoining Schofield, have shown low levels of TCE contamination.
In accordance with the Installation Action Plan, Schofield has
established four operable units and set priorities. DOD and EPA
officials state that this process will ensure the most contaminated
sites or those posing the most imminent danger get funding and
cleanup priority. The installation also plans to have a risk
assessment of all hazardous waste sites.
COST
-------------------------------------------------------- Appendix VI:3
The Army has spent over $17 million to study and solve the
contamination problems at Schofield Barracks. The Army and EPA had
different approaches for cleaning up the installation. EPA's
procedures called for (1) a more comprehensive study and testing
program, (2) more work on determining if the treatment of the
drinking water as it is used will work, and (3) more testing for
contaminants during cleanup actions. It also wanted the Army to
consider testing for the full range of contaminants at the landfill.
The Army believed the current system to treat the drinking water was
adequate and more testing was not needed. There were two cost
estimates--$65.7 million for the Army's proposal and $142.1 million
using EPA's procedures.
Subsequent to our visits, Schofield officials told us that EPA Region
IX agreed to the Army's proposal that the treating of the groundwater
as it is pumped for use will provide adequate protection to those
using the water. Further remediation of the groundwater would not be
required.
Schofield officials believed EPA was not aware of the high cost of
environmental restoration work in Hawaii. For example, EPA wanted
the installation to drill a grid of at least 120 test wells to
determine the TCE contamination source. According to Schofield
officials, the cost for a test well on the mainland is about $50,000
to $100,000, whereas in Hawaii, the cost is about $400,000 for each
well because the geological formations are unusual and the
groundwater is about 800 feet deep. Thus, the total for the 120 test
wells would be $48 million.
Schofield officials said that the cost to determine the extent of the
contamination plume could be significantly higher than the $48
million, but they did not have an estimate they were willing to
provide us. Any remediation cost for items such as constructing the
pump and treat system and the testing that would be a part of the
project would be additional. The current cost estimate for a planned
limited remediation--contaminant removals from known sites, landfill
investigative work and long-term monitoring, installation of a
limited number of test wells, and the study of drinking water wells
surrounding the installation--is $21 million, less than half the cost
of drilling the test wells.
Installation officials state that they follow the feasibility study
procedures outlined in EPA's guidance. Cost is considered, but it is
not an overriding factor. They are focusing the IRP to target
cost-effective cleanups early so the investigation can be concise and
cost-effective. EPA has not agreed with all of the installation's
focusing initiatives.
OPTIONS CONSIDERED
-------------------------------------------------------- Appendix VI:4
When TCE was found in the drinking water wells in 1985, the Army
chose to treat the water as it was used, basing its decision on two
factors. One, it would be impractical to remediate an aquifer by the
pump and treat method because it is 800 feet deep, the aquifer
discharges to the Pearl Harbor aquifer at a rate of 115 million
gallons per day, and the aquifer is contained in an unusual
geological structure under Schofield. Two, the cost of providing the
database to support such a pump and treat remediation of the aquifer
would be extremely high. The Army stated that its system to treat
the water as it is used, to less than 1 ppb for TCE, has been in use
for 7 years. It cost about $3.7 million in 1985 to build the
treatment plant and costs about $50,000 a year to operate and
maintain it. The Army believes the same approach could be used
locally or by the city of Honolulu.
EPA favored the use of a pump and treat system that would remove TCE
from the groundwater and return treated water to the aquifer. EPA
did not believe the Army Environmental Center had done enough testing
to prove that Schofield's current water treatment system worked and
there was no documents to support the Army's position. To obtain the
needed data, EPA wanted the installation to investigate all known
potential sites to determine the TCE contamination source, and then
to clean up the sites. The Army's cost estimate to install and
operate the pump and treat system and perform the required sampling
and testing over a lengthy period of time was several hundreds of
millions of dollars.
The installation, the major command, and the Army Environmental
Center resisted this idea. They believed the current water treatment
system would be the most cost-effective way to supply uncontaminated
drinking water. According to Schofield officials, subsequent to our
visits, EPA agreed that the point of use system would be the final
remediation required. Currently, the stripper reduces the amount of
TCE in the drinking water from 40 ppb to less than 1, which is below
the maximum contaminant level of 5 ppb.
OPTION SELECTED
-------------------------------------------------------- Appendix VI:5
Although final decisions have not been reached, both EPA and Army
officials believe progress is being made. They agree on the
following key issues.
The highest priority is finding the source of TCE contamination and
cleaning it up.
The groundwater should be treated at the point of use.
The procedures that consider a full range of containment and
monitoring options for the largest site, a former landfill, have been
streamlined.
Remediation will focus on the 12 worst sites. An additional 34 sites
will continue in the remedial investigation phase and no further work
will be required at 70 of the 116 sites.
Schofield officials said that the state has not assessed these issues
and as a result, have not taken a position regarding the EPA/Army
agreement.
EXPECTED COMPLETION
-------------------------------------------------------- Appendix VI:6
Installation officials state that the current schedule calls for
remedial action to be completed by fiscal year 1996. They estimate
that long-term monitoring will continue beyond this date.
REGULATORY PROCESS
-------------------------------------------------------- Appendix VI:7
Installation officials believe the CERCLA process has inhibited
timely cleanup at Schofield Barracks. The CERCLA process requires
the installation to conduct studies and submit a draft report to EPA,
which has 60 to 90 days to review and comment. The installation has
from 15 to 45 days to review EPA's comments and respond with a final
draft report. EPA then has 30 to 45 days to approve the report.
During the process, either party can request time extensions for
further work. This review process, however, slows down the CERCLA
process because it has to be done for every plan and report prepared
under the Interagency Agreement. In addition, each decision point
report could require more than one version of the draft and this
review process would be repeated for each version.
They believe the study phase is prolonged by the requirements agreed
to in the agreement. If the agreement is followed step by step, it
ties the installation's hands in getting sites cleaned up using
contaminant removal actions. Agreements were once site specific, but
now they predominantly cover the installation from fence to fence.
Consequently, all sites, regardless of size or contaminant, are to be
treated the same in the CERCLA process.
In Schofield's case, EPA has expanded the investigation beyond
locating and remediating TCE source(s), the basis for the NPL
listing. Because most of the sites do not contain TCE, installation
officials questioned why it has to go through the entire CERCLA
process for each site. They stated that if EPA was not so involved
in the study of the smaller, less contaminated sites, the cleanup
could be completed quicker.
Schofield officials told us that EPA is involved with all the sites
because it does not trust DOD installations to do a good job. EPA
officials state that if TCE is found in one well, there is a
potential for any site on the installation to be the source of TCE
contamination. Because the installation did do some maintenance of
equipment in the past and may have used TCE, EPA expects the
installation to do all of the CERCLA required work at all of the
sites, even if the site is a minor one and there is no evidence of
TCE use at the site.
Schofield officials state the advantages of being on the NPL are (1)
the installation receives a higher funding priority and (2) a
mechanism is in place to facilitate the completion of cleanup.
DOD/REGULATORY AGENCY
COOPERATION
-------------------------------------------------------- Appendix VI:8
Installation personnel spend a lot of time working with the
regulatory agencies to get the work done. They state there was very
little communication and cooperation in the early stages of the IRP,
especially when deciding on what to do to clean up the drinking
water. EPA and the Army Environmental Center officials told us that
they believed that this disagreement caused delays in the cleanup.
EPA and the Army Environmental Center, with assistance from the
installation, have initiated a more cooperative effort to determine
what needs to be done to remediate the contamination from the
installation.
The Interagency Agreement provides for EPA to set up a "project
manager" to oversee the installation's IRP. According to
installation officials, there have been some disagreements that have
slowed down the work.
CLEANUP STANDARDS
-------------------------------------------------------- Appendix VI:9
Schofield officials said that a single standard for each chemical
would be very helpful and could reduce investigative costs. However,
to protect the most sensitive environments and populations, those
standards could translate to higher remediation costs. This may not
be realistic, but there should be some way for determining what has
to be done at each site using a standard procedure. Having different
procedures for determining standards for the same contaminant is not
practicable.
Army officials stated that EPA would be the most logical source of
standards to provide nationwide coverage; however, its input would
have to be tempered by real-world practicalities of conducting
cleanups. Also, EPA headquarters would have to bring regional
offices into line with a central policy; the 10 regions currently set
their own policies, which makes standardization extremely difficult.
Installation officials stated that Hawaii does not have any standards
for cleanup, but they believe the state's standards will be more
restrictive than EPA's standards. The state has not done any active
enforcement at federal facilities yet.
The installation has been working with both regulators to get them to
set standards for cleanup that are economically and technically
feasible.
STAFFING
------------------------------------------------------- Appendix VI:10
Installation and the U.S. Army Pacific Command officials told us
that they had been unable to hire and retain enough qualified people.
The installation only has one staff member (GS-12) assigned to the
IRP,\1 and he was the only one funded by DERA. Even this individual
was not hired for the IRP, he was "stolen" from another unit on the
installation. In addition to his DERA work, he is the Safe Drinking
Water Program Manager, the Noise Program Manager, and the Historic
Preservation Program Manager. Installation officials state the IRP
staffing will increase to the equivalent of three staffyears in the
near future. Until the IRP work at the sites on the installation
reaches a point where the funding priority is high enough, staffing
will not always be available. In the installation cleanup
activities, Schofield has less staff than the other two sites we
visited in Hawaii--Pearl Harbor Complex and Hickam Air Force Base.
Also, Schofield and Pearl Harbor are NPL installations while Hickam
is not. The Army's Pacific Command, Schofield's major command, has
one environmental engineer and his secretary working in the IRP.
They are the only ones funded by DERA.
The U.S. Army Force Integration Support Agency studied the U.S.
Army Pacific's and the installation's environmental staffing,
including installation restoration or CERCLA work, in May 1994. The
agency found that to adequately do all of the required environmental
work, the U.S. Army Pacific and the installation would need about 19
staff members of which 4 to 5 would work in the IRP. At the time of
the study, the Army had eight authorized positions. Army officials
told us that with the recent lifting of the Army's staffing freeze,
and the study recommendation, they hope to begin to fill some of the
positions.
Army officials stated that all of the installations in Hawaii are
competing for each others' environmental staffs, and these
individuals are transferring to obtain promotions or improve their
careers. Under the current staffing guidance, the Army is constantly
losing people to the other services that have higher grades for their
environmental people. Table VI.2 shows that the management grade
structure at the commands and the installations is higher for the
other services. Installation officials told us that because the
Navy's and the Air Force's management levels are higher, they are
able to have higher grades for the staff.
Table VI.2
Grade Structure for Environmental Office
Managers
Activity Grade
------------------------------------------------ ----------
Army Pacific Command GS-14
Schofield Barracks GS-12
Pacific Engineering Field Division Captain
or
GM-15
Pearl Harbor Complex GS-13
Pacific Air Force Colonel
Hickam Air Force Base GS-13
------------------------------------------------------------
Army Environmental Center officials told us that they recognized that
there are resource limitations at Schofield and have attempted to
alleviate the staffing shortage by helping to manage the preliminary
assessment/site inspection contract. Schofield officials told us
that they do not expect the Center to continue to supply staffing
assistance. The Center's representatives visit the installation two
or three times a year, but will come more often if needed.
Generally, there is good communication between the installation and
the Center.
--------------------
\1 The one environmental engineer left to go to the Pacific Ocean
Engineering Office. Schofield is in the process of replacing him.
REGULATORY AGENCY STAFFING
------------------------------------------------------- Appendix VI:11
Hawaii Department of Health officials told us that the state has
provided little oversight or input into the IRP during the early
years because of staffing shortages. According to Army and state
officials, since April 1994, when additional staff were obtained, the
state has provided adequate oversight.
In Hawaii, EPA's Region IX concentrates its resources on NPL
installations, such as Schofield, and it does not have a staffing
problem that affects Schofield. However, by concentrating its
resources on NPL sites, EPA officials told us that it does not have
enough staff to provide adequate oversight at non-NPL installations
in Hawaii, such as Hickam Air Force Base.
FUNDING
------------------------------------------------------- Appendix VI:12
DERA funds are used because the installation is on the NPL. Table
VI.3 shows the funds requested, received, and planned for the IRP.
Table VI.3
Requested, Received, and Planned DERA
Funding for Schofield Barracks
Requested/
Fiscal year planned Received
-------------------------------- ------------ ------------
1984 $50,000 $50,000
1991 985,380 1,005,400
1992 5,356,220 956,220
1993 8,300,000 12,330,000\a
1994 10,831,000
1995 9,000,000
1996 9,600,000
1997 700,000
------------------------------------------------------------
\a Includes $4,400,000 not received in fiscal year 1992.
According to U.S. Army Pacific Command and installation officials,
the fiscal year 1991 DERA funds were received early enough to conduct
the program on schedule. The delay in getting $4.4 million of the
$5.4 million requested in fiscal year 1992 caused the major contract
award scheduled for late fourth quarter to be deferred to the next
year. The Army designated the $4.4 million for other environmental
projects that they thought had higher priorities.
Installation officials stated that the Army and DOD headquarters
questioned the level of funding projected to conduct the remedial
investigation/feasibility study and remedial actions because of the
low Hazard Ranking System score and the lack of a direct link between
the TCE contamination and the Schofield sites. The major command and
Army headquarters have also questioned the need to fund all of the
CERCLA work being done at some of the minor sites on the
installation.
Installation officials stated that a problem with funding is the
untimely receipt of the funds. It is difficult to execute contracts
when the money is not received until the last quarter of a fiscal
year. For example, in fiscal year 1992, the installation struggled
to execute projects to use the funds allocated during the early part
of the year. It became even more difficult to use the year-end funds
because the installation received the money when it had less than 6
months to get contracts signed. If contracts are not signed, the
installation has to return the money to the Army Environmental Center
and renegotiate the contracts the next year, if the installation
receives the funds.
Installation officials stated that year-end money received does not
follow the normal planning, design, and contracting procedures or
adhere to project priorities. The project that is closest to having
a contract signed is the one funded, which sometimes is not the
highest priority project. In addition, the Pacific Ocean Division's
engineers are tied up with other projects using year-end money. As a
result, needed support services may not be available and thus, the
projects may not be fully planned and engineered. The Army shares
the Pacific Ocean Division's engineers with the Air Force for
technical and engineering.
Installation officials stated that if the installation is allowed
only a short time to execute the contracts to accomplish the
projects, the whole process needs to be streamlined so that the work
can be done with proper planning. They said the installation needs
more than 3 months to spend dollars efficiently and properly execute
the contracts and as a result get work completed earlier. If the
system is not streamlined and some of the study process and testing
eliminated, the total remediation project could cost $100 to $200
million.
The short time to get the contracts signed causes the projects to be
spread out because the installation has to cover more than one window
of opportunity: one for scoping and study, one for negotiating and
contracting, and another for the remedial action.
CERCLA PROCESS
========================================================= Appendix VII
PRELIMINARY ASSESSMENT
------------------------------------------------------- Appendix VII:1
The initial stage of the cleanup program is an installation wide
study to determine if sites are present that pose hazards to public
health or the environment. Available information is collected on the
source, nature, extent, and magnitude of actual and potential
hazardous substance releases at sites on the installation.
SITE INSPECTION
------------------------------------------------------- Appendix VII:2
The next step consists of sampling and analysis to determine the
existence of actual site contamination. Information gathered is used
to evaluate the site and determine the response action needed.
Uncontaminated sites do not proceed to later stages of the process.
REMEDIAL INVESTIGATION
------------------------------------------------------- Appendix VII:3
Remedial investigation may include a variety of site investigative,
sampling, and analytical activities to determine the nature, extent,
and significance of the contamination. The focus of the evaluation
is determining the risk to the general population posed by the
contamination.
FEASIBILITY STUDY
------------------------------------------------------- Appendix VII:4
Concurrent with the remedial investigations, feasibility studies are
conducted to evaluate remedial action options for the site to
determine which would provide the protection required.
REMEDIAL DESIGN
------------------------------------------------------- Appendix VII:5
Detailed design plans for the remedial action option chosen are
prepared.
REMEDIAL ACTION
------------------------------------------------------- Appendix VII:6
The implementation of the chosen remedial option is implemented.
INTERIM REMEDIAL ACTION
------------------------------------------------------- Appendix VII:7
Remedial actions can be taken at any time during the cleanup process
to protect public health or to control contaminant releases to the
environment.
REMEDY IN PLACE AND FUNCTIONING
AS INTENDED
------------------------------------------------------- Appendix VII:8
The remedial action is functioning properly and performing as
designed. These include such actions as the operation of pump and
treat systems that will take decades to complete cleanup.
SCOPE AND METHODOLOGY
======================================================== Appendix VIII
The six installations selected for this supplement were chosen
because either your office expressed interest in the installation or
they were representative of the problems, such as groundwater
contamination, encountered at the sites. To develop the information
contained in this supplement, we reviewed applicable procedures and
records maintained by DOD, EPA, and state regulatory agencies. We
also interviewed environmental officials from the DOD agencies, the
Army, the Navy, the Air Force, and the Defense Logistics Agency at
the headquarters level in Washington, D.C.; at major military
commands, engineering field divisions, and service organizations;
selected installations; state regulatory agencies; and EPA
headquarters and regional offices. We reviewed applicable files and
documentation at Washington headquarters offices, command level
offices, the installations, state regulatory agencies, and EPA
headquarters and applicable regional offices, including such
pertinent documents as Interagency Agreements.
Data gathered for the primary report on the installations were used
for these case studies. We updated the information when available.
ARMY
---------------------------------------------------- Appendix VIII:0.1
Headquarters offices
Army Materiel Command
U.S. Army Pacific, Honolulu, Hawaii
Army Environmental Center, Maryland
Aberdeen Proving Grounds, Maryland
Fort Lewis, Washington
Fort Sill, Oklahoma\1
Fort Wainwright, Alaska
Letterkenny Arsenal, Pennsylvania
Rocky Mountain Arsenal, Colorado
Schofield Barracks, Hawaii
NAVY
---------------------------------------------------- Appendix VIII:0.2
Headquarters offices
Naval Facilities Engineering Command
Chesapeake Engineering Field Division
Pacific Engineering Field Division
Southwest Engineering Field Division
Naval Surface Warfare Center, Dhalgren, Virginia
Pearl Harbor Naval Complex, Hawaii
North Island, San Diego Naval Complex, California\1
Yorktown Naval Weapons Center, Virginia\1
--------------------
\1 Although this is neither an NPL nor closure installation, we
visited it because of unique contamination problems, including
contamination of groundwater. Data from this site was not included
in our cost and site analyses.
AIR FORCE
---------------------------------------------------- Appendix VIII:0.3
Headquarters offices
Air Force Center for Environmental Excellence, Texas
Air Force Materials Command, Ohio
Hickam Air Force Base, Hawaii\1
Kelly Air Force Base, Texas\1
Mather Air Force Base, California
McChord Air Force Base, Washington
McClellan Air Force Base, California
Tinker Air Force Base, Oklahoma
Vance Air Force Base, Oklahoma\1
MARINE CORPS
---------------------------------------------------- Appendix VIII:0.4
El Toro Air Station, California
Tustin Air Station, California
EPA
---------------------------------------------------- Appendix VIII:0.5
Headquarters offices
Region III, Philadelphia, Pennsylvania
Region VI, Dallas, Texas
Region VIII, Denver, Colorado
Region IX, San Francisco, California
Region X, Seattle, Washington
Environmental Protection Agency Environmental Research Laboratory,
Oklahoma
STATE REGULATORY AGENCIES
---------------------------------------------------- Appendix VIII:0.6
Alaska
California
Pennsylvania
Oklahoma
Texas
Virginia
Washington
MAJOR CONTRIBUTORS TO THIS REPORT
========================================================== Appendix IX
NATIONAL SECURITY AND
INTERNATIONAL AFFAIRS DIVISION,
WASHINGTON, D.C.
David R. Warren
Uldis Adamsons
Clementine H. Rasberry
Jacob W. Sprouse, Jr.
Robert G. Hammons
Robert Jones