, 
, 
, 
ADI Acceptable Daily Intake
AEC Army Environmental Centre
AFB Air Force Base
AST Aboveground Storage Tank
ARAR Applicable or Relevant and Appropriate Requirement
ARSDR Agency of Toxic Substances and Desease Registry
ATTIC Alternative Treatment Technology Information Centre
BBS Bulletin Board System
Bldg. Building
BRAC Base Realignment and Closure
CAP Corrective Action Plan
CCS Contaminated Civil Site
CDI Chronic Daily Intake
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CES Cost Estimating System
CFR Code of Federal Regulations
CHF Contaminant Hazard Factor
CLEAN Comprehensive Long-Term Environmental Action Navy
CMI Corrective Measures Implementation
CMS Contaminated Military Site
CMSt Corrective Measures Study (Note: the common acronym for this term is
"CMS"; however, CMSt is used in this document)
COPC Contaminants of Potential Concern
CS Confirmation Study
DERA Defence Environmental Restoration Account
DERP Defence Environmental Restoration Programme
DLA Defence Logistics Agency
DOD Department of Defence
DOE Department of Energy
DOI Department of Interior
DPM Defence Priority Model
DSMOA Defence and State Memorandum of Agreement
EA Environmental Assessment
EBS Environmental Baseline Survey
EE/CA Engineering Evaluation and Cost Analysis
EPA Environmental Protection Agency
EPC Exposure Point Concentration
EPCRA Emergency Planning and Community Right-to-Know
ERA Ecological Risk Assessment
ERPS Environmental Restoration Priority System
FDA Food and Drug Administration
FR Federal Register
FS Feasibility Study
FUDS Formerly Used Defence Site
FY Fiscal Year
GAO General Accounting Office
HEAST Health Effects Assessment Summary Tables
HI Hazard Index
HHBRA Human Health Baseline Risk Assessment
HQ Hazard Quotient
HRS Hazard Ranking System
HSWA Hazardous and Solid Waste Amendments
IAS Initial Assessment Study
IRA Interim Remedial Action
IRIS Integrated Risk Information System
IRP Installation Restoration Programme
LOAEL Lowest Observed Adverse Effects Level
LTM Long-Term Monitoring
MCACES Microcomputer Aided Cost Estimating System
MCL Maximum Concentration Level
MF Modifying Factor
MILCON Military Construction
NAVFAC Naval Facilities
NCP National Contingency Plan
NECA Navy Environmental Compliance Act
NEPA National Environmental Policy Act
NIOSH National Institute of Safety and Health
NOAEL No Observed Adverse Effects Level
NPDES National Pollutant Discharge Elimination System
NPL National Priorities List
O&M Operation and Maintenance
OMB Office of Management and Budget
OSHA Federal Occupational Safety and Health Administration
PA Preliminary Assessment
PCB Polychlorinated Biphenyl
POL Petroleum, Oil, and Lubricants
POTW Publicly Owned Treatment Works
PRG Preliminary Remediation Goal
PRP Primary Responsible Party
RA Remedial Action
RAB Restoration Advisory Board
RAC Remediation Action Contract
RAGS Risk Assessment Guidance for Superfund
RBC Risk-Based Concentration
RCRA Resource Conservation and Recovery Act
R&D Research & Development
RD Remedial Design
REAMS Risk Exposure and Analysis Modelling System
RfC Reference Concentration
RfD Reference dose
RFA RCRA Facility Assessment
RFI RCRA Facility Investigation
RFI/CMSt RCRA Facility Investigation/Corrective Measures Study
RI Remedial Investigation
RI/FS Remedial Investigation and Feasibility Study
ROD Record of Decision
SARA Superfund Amendments and Reauthorization Act of 1986
SCS Suspected Contaminated Site
SDWA Safe Drinking Water Act
SF Slope Factor
SI Site Inspection
SOFA Status of Forces Agreements
SMCL Secondary Maximum Contaminant Level
SWMU Solid Waste Management Unit
TRC Technical Review Committee
UCL Upper Confidence Limit
UF Uncertainty Factor
UR Unit Risk
US United States
USCG US Coast Guard
UST Underground Storage Tank
UXO Unexploded Ordnance
WWTP Wastewater Treatment Plant
The United States of America consists of 50 states and one district (District
of Columbia) which occupy approximately 9,372,610 square kilometres. The US
population exceeds 260 million people with approximately 75 percent of the
population living in urban areas. The US covers a large range of terrain
consisting of the vast central plain, mountains in the west, hills and low
mountains in the east, rugged mountains in Alaska and rugged volcanic
topography in Hawaii.
The US Department of Defence (DOD) directs the operations of the US military
consisting of the Department of Army (Army), the Department of Navy (Navy), and
Department of Air Force. The Marine Corps is included in the Department of
Navy. DOD is headed by the Secretary of Defence. The DOD was organized in 1949
as an outgrowth of the National Security Act of 1947. The DOD replaced the
separate War and Navy departments with a unified military establishment. DOD is
by far the largest of the federal departments.
For decades, the United States (US) Federal activities and industrial
facilities generated, stored, recycled, and disposed of hazardous waste, which
often contaminated nearby soil and groundwater. In many instances, these
problems predate existing environmental regulations and laws. The DOD and the
Department of Energy (DOE) own and operate thousands of installations, ranging
from training bases to industrial production facilities. Many of these defence
facilities have been operating for over a century. During this time, the
agencies, like much of American society, operated them without full respect for
the environment. As a result, the defence agencies now have more than 17,000
sites that require environmental clean-up.
The United States government has established various programmes, regulations,
and funds for the purpose of investigating and remediating contaminated sites
throughout the United States for military, civil, and other government
facilities.
Suspected Contaminated Site (SCS)
A suspected contaminated site is a site that, due to the nature of historical
or current operations and/or disposal practices, is considered to have the
potential to be classified as a contaminated site, but there is no data or only
limited data available to suggest that the site is contaminated. Identification
of suspected contaminated sites is essential in establishing where preliminary
site assessments and investigations will be required.
Contaminated Site
In general, a site is considered to be a contaminated site when the
concentration of one or more substances in the soil, groundwater, surface water
or other media degrade the natural quality of the environment; impair the
usefulness of natural resources; offend the senses of sight, taste or smell; or
cause a health hazard. In order to identify a site as contaminated, the United
States (US) Environmental Protection Agency (EPA), the Federal environmental
regulating agency in the US, has established regulatory threshold levels for
different contaminants (e.g., maximum contaminant levels (MCLs), action levels,
clean-up levels, etc.).
Once these regulatory threshold levels are exceeded, the site is considered to
be contaminated. These threshold levels are identified in different US EPA
regulations, depending on the type of contaminant, source of contamination and
the media contaminated. EPA regulatory threshold levels have been established
for contaminants in groundwater and surface water; however, in most cases,
regulatory levels for soil and sediment contaminants do not exist. The US EPA
has developed health-based and risk-based concentrations (RBCs) to be used as
guidelines for evaluating site investigation data and preliminary remediation
goals.
Although EPA has established regulatory threshold levels, State and local
agencies can develop and enforce stricter regulatory levels for contaminated
sites located within their region.
For the purpose of this document, contaminated sites have been divided into
three categories (and defined below in this Section): (1) contaminated military
sites (CMSs), (2) contaminated civil sites (CCSs), and (3) other contaminated
government sites.
Contaminated Military Site
A contaminated military site (CMS) is a contaminated site (as defined above)
that is owned or operated by the United States Department of Defence (DOD) or
was formerly owned or operated by the DOD. The DOD components includes the
Army, Navy, Air Force, Defence Logistics Agency (DLA), and Formerly Used
Defence Sites (FUDSs). Examples of types of CMSs include the following
DOD-owned or operated facilities/installations: research and development
facilities; production sites for military goods (weapons, chemicals, etc.);
test areas; disposal sites; training areas; barracks or other housing areas;
storage areas; airfields; hangars; and other DOD-owned or operated facilities
or areas.
These CMSs can be located within the US or can be located overseas. One
military installation or base may have a number of CMSs within its boundaries;
therefore, the number of CMSs reported throughout this report does not reflect
the number of military bases that are contaminated.
CMSs do not include privately or commercially owned facilities which may
support DOD in such operations as production of military goods, waste disposal,
and other non-military operated or owned operations. Although not considered a
CMS, DOD can share the financial responsibilities associated with the
investigation and remediation of CCSss if DOD is identified as a partially or
potentially responsible party. These sites are typically commercially operated
waste disposal facilities at which waste generated by DOD was disposed. DOD can
also share financial responsibility with private parties on DOD-owned property
where DOD contractors are responsible for the contamination; these sites are
referenced as CMSs because the property is owned by DOD.
CMS Categories
The DOD has established nine different categories of CMSs which are further
divided into forty-four site types. The number of site types was expanded from
25 to 44 in fiscal year 1994 in order to better characterize and account for
the types of sites and progress at these sites with regards to investigation
and clean-up. The CMS categories and site types are identified in Appendix
20-2 and further described in Section 20.-5.0.
Legislative Framework/Administrative System
* Historical DOD Legislation/DERP
Federal agencies such as DOD, Department of Energy (DOE), Department of
Interior (DOI) and others must comply with the fundamental requirements
established by EPA, state and local regulatory agencies. Each of the Federal
agencies have developed their own protocols for the purpose of achieving and
maintaining compliance with applicable regulations. Additionally, DOD
components (e.g., Army, Navy, etc.) have developed parallel and similar
environmental programmes for establishing and maintaining compliance. DOD
established the Installation Restoration Programme (IRP) in 1975 to study and
remediate contaminated DOD sites. In 1984, this programme was made a part of
the Defence Environmental Restoration Programme (DERP) (see Sections 20.-6.0
and 20.-7.0).
* Public (Civil) Legislation
CERCLA and the Resource Conservation and Recovery Act (RCRA) are the primary
Federal laws established by EPA that govern the investigations and clean-up
activities of contaminated sites. A DOD installation typically consists of
multiple contaminated sites regulated by either CERCLA or RCRA or by both.
State and local environmental laws and regulations can also apply to
investigations and remedial activities performed at DOD installations. In many
instances, both Federal (EPA) and state regulations apply to the same site and
application of these regulations are in conflict. Simultaneous negotiations
with multiple agencies is then necessary to develop a mutually acceptable plan
of action.
CERCLA/SARA. The Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA or Superfund) provides EPA with the authority to respond
to releases of hazardous wastes (as defined by the Clean Water Act, Clean Air
Act, Toxic Substances Control Act, Solid Waste Disposal Act, and the EPA
Administrator) from "inactive" hazardous waste sites which endanger public
health and the environment. It also establishes a Federal "Superfund" to
finance response actions, establishes regulations controlling inactive
hazardous waste sites, and establishes liability to recover clean-up costs.
These funds, however, are not available for federally owned or operated sites.
Federal agencies including DOD are responsible for funding the investigation
and remedial actions at DOD active and inactive sites. Superfund Amendments
and Reauthorization Act (SARA) (1986) revises and extends CERCLA to continue
Superfund activities. Title III of SARA, Emergency Planning and Community
Right-to-Know Act (EPCRA) of 1986, provides for "emergency planning and
preparedness, community right-to-know reporting and toxic chemical release
reporting." Under this law, facility owners and operators are required to
provide certain information relating to regulated substances within their
facilities to the appropriate state and local authorities so that they may be
better prepared for environmental emergencies. This law also establishes a
comprehensive framework of procedures to be followed by facility owners or
operators to identify, investigate, and clean-up releases of hazardous
substances to the environment. Through Executive Order 12580 (January 1987),
the President of the United States directs the Secretary of Defence to
implement investigation and clean-up measures in consultation with EPA for
hazardous substances releases from DOD installations. EPA's response policy
and key response steps for implementing CERCLA are established by the National
Oil and Hazardous Substances Pollution Contingency Plan (NCP).
EPA, in pursuant to CERCLA Section 105, compiled a list of uncontrolled
hazardous substance releases in the US that are identified as priorities for
long term remedial evaluation and response. This list is referred to as the
National Priorities List (NPL). The mechanism for identifying NPL sites is
further described in Section 20.-7.0 and 20.-7.1.
RCRA. The Resource Conservation and Recovery Act (RCRA) of 1976
addresses solid waste issues, and provides EPA with the authority to regulate
the disposal of hazardous waste. RCRA also encourages the development of solid
waste management plans and nonhazardous waste regulatory programmes by the
states; prohibits open dumping of waste; regulates underground storage tanks
(USTs); and provides for a national research, development, and demonstration
programme for improved solid waste management and resource conservation
techniques. RCRA provides EPA with "cradle-to-grave" control, from generation,
transportation, treatment, storage, and disposal, of hazardous waste. RCRA
also provides a framework for dealing with non-hazardous wastes.
RCRA was amended in 1984 to include the Hazardous and Solid Waste Amendments
(HSWA). HSWA required the phase-out of land disposal of hazardous waste;
increased enforcement authority for EPA; developed more stringent hazardous
waste management standards; and provided provisions to deal with USTs. HSWA
provides authority for the investigation and clean-up of past waste sites,
which create a corrective action programme substantially equivalent to
programmes under CERCLA. For those DOD installations that require a RCRA
permit to manage hazardous wastes, EPA or authorized states may impose
corrective action requirements for any known or suspected releases of hazardous
wastes or hazardous substances from Solid Waste Management Units (SWMUs) or
other identified SCSs at the DOD installation.
The UST programme was created by HSWA in 1986 to regulate both petroleum
products and hazardous substances. RCRA Subtitle I establishes requirements
concerning the management of USTs that contain petroleum products and any
substance defined as hazardous under CERCLA; however, USTs containing RCRA
hazardous waste are not regulated by Subtitle I. Responses to petroleum
product releases at CMSs and CCSs are conducted in accordance with UST
regulations under RCRA Subtitle I or state laws, if existing. States, counties
or other local agencies can develop their own UST regulations with requirements
that are equivalent to or stricter than EPA's UST regulations.
Clean-up of CMSs may be governed by both CERCLA and RCRA statutory and
regulatory authorities. Circumstances are dependent on many factors such as
the source and cause of the contamination, status of the installation as either
an NPL or non-NPL site, and whether the installation is seeking a RCRA permit
to manage hazardous waste.
Conflicts between RCRA and CERCLA are not uncommon as the different regulatory
agencies exercise their respective authorities. Partnering efforts are
assisting DOD, EPA and the states with cooperating through regulatory overlaps
and inconsistencies to allow for the most effective and timely clean-up of
CMSs.
* Federal Compliance Requirements
In most instances, Federal facilities are required to comply with environmental
statutes such as RCRA and CERCLA to the same extent as non-Federal (or civil)
facilities. Methods of enforcing compliance at Federal facilities, funding the
investigations and remedial activities, and public involvement in clean-up
activities at Federal installations are the major differences. For both CMSs
and CCSs, if a site is determined to pose an immediate risk to human health,
interim measures are to be taken to eliminate or reduce the human health risk
as soon as possible.
* Overseas Requirements
The policies of the US DOD that apply to remediation of environmental
contamination on DOD installations or facilities located overseas or caused by
DOD operations that occur within the territory of a nation other than the US
are discussed in the following documents:
· Country-Specific Final Governing Standards
· Overseas Environmental Baseline Guidance Document, Department of
Defence, October 1992.
· Memorandum for Secretaries of the Military Departments Under Secretary
of Defence: Environmental Remediation Policy for DOD Activities Overseas
(October 1995).
The overseas Commanders have the responsibility to provide implementing
directives, although this has not yet occurred at all overseas bases. The
Status of Forces Agreements (SOFA) for troops stationed in foreign NATO
countries does also cover liabilities associated with the use of land.
In general, it is the policy of the US to take prompt action to remediate known
imminent and substantial endangerments to human health that are caused by
environmental contamination caused by DOD operations on overseas active DOD
installations and on overseas DOD installations that have been designated for
return to the host nation. The 1995 Memorandum allows commanders to remediate
beyond requirements in case of imminent and substantial endangerments to health
and safety, which otherwise would result in shutting down operations. Other
additional remediation must be approved by appropriate parties.
International agreements may require US to fund environmental remediation; such
required measures may be more extensive than that necessary to remediate known
imminent and substantial endangerments to human health and safety. Remediation
may be completed after return of the property as long as only environmental
contamination caused by DOD operations are addressed and remediation activities
do not exceed those approved prior to the return of the property.
Prior to the return of DOD installations to the host nation, DOD and the host
nation must agree on sites to be remediated and acceptable contaminant levels
and/or measures to be implemented. After return of an installation, DOD will
not fund any environmental remediation beyond that required by binding
international agreement or previously approved remediation measures. Host
nations using their funds may remediate installations to a greater extent
during the US occupancy of the installation with the cooperation of the US.
The decision of whether or not a CMS poses a known imminent and substantial
endangerment shall be made by the appropriate DOD personnel. Remediation may
range from institutional responses, such as restricting access, to permanent
remedies.
Responsibilities
CERCLA, RCRA, UST and other regulations have reporting requirements when a
spill, leak or other contamination to a site has occurred. Threshold levels
for various contaminants are identified by different regulations. When a
threshold level for a contaminant is exceeded, a facility is required to report
the contamination to the appropriate Federal, state or local regulatory agency.
EPA uses the Hazard Ranking System (HRS) to determine if a site is to be listed
on the NPL, a list of the nation's worst sites. The HRS is further described
in Section 20.-7.1. Various databases are maintained that consist of a
compilation of reported environmental incidents. Examples of existing Federal
or state databases include state leaking UST databases, NPL list, State NPL
list (depending on the state), RCRA violators, CERCLIS database and others.
Federal facilities are required to report to the applicable Federal, state
and/or local regulatory agencies and the reported CMSs are included in the
Federal, state and local database.
It is the responsibility of the owner or operator of a facility to register,
assess and remediate a contaminated site. This applies to civil, military and
other government sites. The Commander or head of the military base or
installation is typically considered the "owner" or "operator" and is,
therefore, responsible for registering, assessing and remediating their base or
installation. Typically, an environmental officer or coordinator at the
military installation or facility is delegated these responsibilities.
DOD prioritizes the different military sites in order to distribute funding for
investigation and remediation activities. Contaminated sites are initially
prioritized using limited data that may be available. Once further
investigation is completed that better defines the extent of contamination, the
priority of the site is reevaluated in order to identify high priority sites
for clean-up. The methods for prioritizing the different military sites are
further discussed in Sections 20.-5.0 and 20.-10.0. Sites may be prioritized
both by EPA and by DOD.
Public Involvement
SARA requires DOD to establish technical review committees (TRC) at
installations with environmental restoration programmes. TRCs review technical
documents and discuss progress in implementing and completing environmental
restoration activities. By the end of FY 1994, TRCs had been formed at most
installations with environmental restoration programmes, and at nearly all
installations listed on EPA´s NPL.
DOD policy also requires that community involvement is further strengthened by
the establishment of Restoration Advisory Boards (RABs) installations where
there is sufficient, sustained community interest in the environmental
restoration programme. One of the following criteria must be met to determine
that community interest is sufficient and sustained:
· Closure of the installation involves transfer of property to the
community;
· at least 50 citizens petition for an advisory board;
· the Federal, state, or local government requests formation of an
advisory board;
· the installation determines the need for an advisory board.
RABs were first established in September 1993. Consequently, at many
installations TRCs are being converted to RABs to include more local citizens.
At the end of FY 1995, RABs had been formed at more than 250 operational and
closing installations.
DOD perceives that RABs have become a significant forum through which members
of affected communities can provide input to an installation´s ongoing
environmental restoration programme. Addressing community concerns early in the
clean-up process enhances efforts under, and increases the credibility of, the
environmental restoration programme.
Sources of Funds for Investigation and Remediation/Clean-Up
DOD has organized the environmental restoration programme into five
elements:
· clean-up,
· compliance,
· conservation,
· pollution prevention, and
· technology.
The Secretary of Defence has delegated clean-up responsibility to the Air
Force, Army, Navy and DLA and private firms, which are monitored by the
services.
Funding for the DOD's five environmental programme elements is divided into
three broad categories consisting of
(1) environmental compliance,
(2) environmental restoration, and
(3) BRAC clean-up costs.
Congress provides clean-up funds for work at active DOD facilities and formerly
used defence sites in the Defence Environmental Restoration Account (DERA),
which is considered DOD's equivalent of Superfund. DERA is centrally managed.
The majority of the DERA funds are allocated to DOD NPL sites. Congress
provides funds through the Base Realignment and Closure (BRAC) account for
investigation and clean-up of closing installations. BRAC environmental
funding also includes closure related environmental compliance and
environmental planning. Compliance efforts may include, but are not
necessarily limited to, such actions as
· UST removals;
· closure of hazardous waste treatment, storage, and disposal
facilities;
· radon surveys; and
· asbestos abatement.
Environmental planning involves environmental analyses required under the
National Environmental Policy Act (NEPA) to assist decisions related to
property reuse and redevelopment. Actions to achieve or maintain compliance at
DOD installations are funded through accounts set up within each DOD component,
such as the Navy Environmental Compliance Act (NECA).
States and US territories can be reimbursed for technical services in support
of investigation and clean-up efforts at DOD installations within their
boundaries under the Defence and State Memorandum of Agreement (DSMOA).
Responsible Party Identification
One of EPA's responsibilities with NPL sites is to attempt to identify
responsible parties that potentially contributed to the contamination.
Responsible parties that are identified must share the financial
responsibilities associated with the investigation and remediation of that
contaminated site. However, in cases, the responsible party identified may no
longer exist or may not be capable of financially contributing to the
remediation of the site.
There may be responsible parties for some CMSs other than DOD. Examples of
such CMSs are sites that are owned by DOD but were operated by contractors who
were responsible for contaminating the site. If the contractor still exists
and is financially capable of contributing to the investigation and remediation
of the CMS, then they are held responsible for sharing the burden with DOD.
DOD has also been identified as a potentially responsible party at CCSs. These
sites are typically commercially operated waste disposal facilities at which
DOD generated waste was disposed.
DOD Environmental Restoration Streamlining
The overall downward pressure on the defence budget has affected DOD's
environmental programmes. DOD is being forced to do more with lower budgets.
The decreased budgets and increased public pressure to remediate CMSs have
caused DOD to work closely with regulatory agencies and stakeholders to
streamline and increase efficiencies in the restoration process. Because of
legal mandates, the majority of DOD's past efforts in environmental restoration
were devoted to investigating the environmental impacts. The shift to focusing
on actual clean-up and reducing real environmental risks did not truly begin
until fiscal year 1993. This shift includes
· using more interim actions to remove sources of contamination and to
reduce immediate threats;
· more appropriately prioritizing site clean-up efforts;
· balancing clean-up levels against expected future land use and life
cycle costs;
· promoting technologies to target the most immediate needs;
· identifying better management and contracting approaches; and
· overcoming regulatory or statutory impediments to successful execution
of the restoration programme.
The DOD has developed the "Fast-Track Clean-up Programme" which represents a
new approach to environmental restoration. This programme acknowledges that
environmental policies must consider economic realities and real-world risk,
rather than solely regulations. DOD is fundamentally shifting environmental
policy by encouraging more flexibility in the regulatory process and focusing
on achieving measurable and practical performance-based goals. The new
approach incorporates risk-based assessment when prioritizing sites as well as
allows for evaluation of different sites on an installation separately so not
to require spending of environmental restoration funds on the clean-up of low
priority sites at an installation that has an overall classification as a high
priority installation.
Contracting
Changes to DOD contracting mechanisms have assisted in the improved efficiency
of completing investigations and clean-up activities at CMSs. Under prior
contracting methods, it was more difficult for DOD to retain the same
contractor to complete the different stages of investigation or remediation at
the same site; this caused a loss in experience and familiarity with a site
when a new contractor was selected to complete work that was initiated by a
different contractor. More recently, procurements have been for multiple years
and increased dollars that allow increased continuity. Another improvement in
the contracting strategies is that larger open-end contracts are being awarded
where individual tasks are negotiated; this prevents the need to undergo the
lengthy contracting procedures for every task to be completed.
DOD contracting strategies differ depending on the issues, agency, and
programme needs. The Navy, Army and Air Force have differences in contracting
strategies. In general, the Navy primarily uses a combination of two major
remediation contracts:
· the Comprehensive Long-Term Environmental Action Navy (CLEAN) contract
during the investigation and design phase and
· the Remedial Action Contract (RAC) during the remedial action phase.
The Air Force advocates a "one base-one contractor" approach to manage their
remediation. The Army's approach incorporates central programme management by
the Army Environmental Centre (AEC) for investigation studies, with design and
remediation handled by the Corps of Engineers.
Potential Cost Savings from Research & Development (R&D)
Many research projects now in the laboratories or being tested in the field are
providing results that foreshadow lower costs (see also Sections 20.-12.0 and
20.-13.0). According to DOD´s estimates in 1994, for example, new
technologies for cleaning-up metals in contaminated groundwater could reduce
costs from as high as $40 to as low as 10 cents per thousand gallons; and for
metals in contaminated soils, from as high as $250 to as low as $20 per ton.
DOD estimated in January 1995 that it might be able to cut cost of remediating
buried ordnance by 33 percent using technology that is being developed.
New technologies for studying contaminated sites could also achieve significant
savings. For example, new penetrometer technologies could reduce the cost of
surveying property containing buried ordnance from $5,000 to as low as $600 per
acre (1 acre = 4046.8 m²). New well-drilling techniques could reduce
sampling costs from $280 to as low as $10 per well-foot (1 foot = 30.48 cm).
Of course, those estimates are preliminary and require additional testing and
application to confirm their validity.
Overseas Bases
Funding for remediation projects comes from commander's operations and
maintenance (O&M) budget. There are no specific or "fenced" funds for
overseas remediation requirements.
Contamination at Different Site Types
In order to better characterize and account for the types of sites and progress
of the investigations and remedial activities at the various DOD site types,
the DOD developed site categories and site types for CMSs. Descriptions of the
different site types of CMSs are provided in Appendix 20-3. The primary
contaminants typically found at each type of CMS are also summarized in
Appendix 20-3.
The number of CMSs for each site category in fiscal year (FY) 1994 is provided
in Appendix 20-4. The number of sites presented in Appendix 20-4 includes sites
where investigations and/or remedial activities are in progress as well as
sites where investigations and/or remedial activities have been completed.
The majority of these sites are associated with past practices involving the
use of petroleum, oil and lubricants for operations and maintenance (O&M)
activities at military installations. In addition, other common contamination
refers to solvents, heavy metals, paints, and other hazardous materials
including acids, asbestos, and pesticides. The 10 most common types of
contaminants found at DOD sites are listed in Table 20-1.
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Source: Congressional Budget Office: Cleaning up Defense Installations: Issues
and Options, January 1995
Leaks or spills occurring as a result of O&M activities may have
potentially affected the immediate surface or subsurface areas surrounding the
source or site. At some CMSs, contaminants may have been transported to other
areas via surface or subsurface migration pathways such as groundwater movement
or surface water runoff. Some site types are relatively unique to CMSs and not
commonly found on CCSs. These site types include: ordnance disposal areas
where munitions have been used; fire fighting training areas where fuels and
other flammable substances have been burned; and low-level radioactive waste
areas where slightly radioactive instruments (e.g., aircraft dials) have been
disposed.
In general, the complexity of the contamination at CMSs is greater than that
found at CCSs. This is primarily due to the large variety of historic and
current operations at individual installations and the uniqueness of some
contaminants such as explosives, radioactive waste, and other DOD specialty
wastes.
Evaluation of Sizes of Contaminated Areas
There are limited data available indicating the size of the areas that have
been found contaminated compared to the size of the sites that were
investigated. This information could be determined for specific installations
where investigations have been completed that define the extent of
contamination, but a comprehensive comparison is not available.
In the DERP Annual Report to Congress for the fiscal year 1994, data were
provided on the size of the installation versus the size of the environmentally
suitable acreage for DOD installations on the list for Base Closure and
Realignment. These data are provided in Table 20-2. Based on these data,
approximately 57 percent of the total installation land area has been
identified as contaminated and not suitable for other uses until remediated or
otherwise proven to be environmentally suitable. However, the entire
installation at each location has not necessarily been investigated but could
have been considered "environmentally suitable" based on land use.
Alternatively, land identified as "environmentally suitable" could have been
investigated but analytical results may have proved certain areas to be
classified as "environmentally suitable".
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Source: DERP FY 1994 Annual Report
Reasons to Investigate CMSs
There are many different mechanisms which can initiate the investigation
processes of suspected contaminated sites. A preliminary site assessment can
be ordered by a regulatory agency with authority under RCRA, UST regulations
(state or Federal), CERCLA, Clean Water Act, or other laws or regulations. A
regulatory agency can order an investigation if there is any reason or cause to
suspect contamination may have occurred to the site. Suspect contamination may
be identified by community or individual complaints; contamination detected on
property located down gradient of the site; SCSs identified during NPDES, RCRA,
or other regulatory inspections; improper closure of hazardous waste areas; or
other such sources.
An investigation may also be triggered if contamination from a known or an
unknown source is detected during routine monitoring. Routine monitoring
requirements include leak detection monitoring of USTs, landfill groundwater
monitoring, groundwater monitoring required for facilities with large petroleum
aboveground storage capacities, RCRA closure plan monitoring requirements and
other regulatory O&M monitoring requirements. Initial investigations can
be triggered if a spill or release of a hazardous substance occurs. UST
regulations require tanks to be upgraded or replaced to include leak detection
by 1998 and to be tightness tested until upgraded or replaced. These UST
regulations have lead to the identification of numerous leaking UST sites
requiring investigations; many of these USTs have been leaking for years and
investigations have not been required until the UST regulations took effect.
A site assessment can also be initiated during property transactions or
refinancing in order to evaluate potential liabilities associated with
potential environmental impacts. Constructions activities, where soil
staining, chemical odours, buried chemical or waste containers, sudden employee
sicknesses or other hazards are identified, can trigger the need for
environmental investigations. Preliminary assessments of DOD-owned parcels are
required prior to the transfer of ownership.
DOD´s Environmental Clean-up Programme
DOD established the Installation Restoration Programme (IRP) in 1975 (See
Section 20.-3.0) to study and remediate contaminated DOD sites. The IRP is
DOD's programme to implement its remedial responsibilities under the
Comprehensive Environmental Response, Compensation and Liability Act (CERCLA)
as amended by the Superfund Amendments and Reauthorisation Act of 1986 (SARA)
and for cleaning up environmentally contaminated sites that are regulated under
other statutes. The IRP is a four-phase programme (see Section 20.-7.0).
In 1984, this programme was made a part of the Defence Environmental
Restoration Programme (DERP), and Congress provided funding through the Defence
Environmental Restoration Account (DERA). In 1990, separate clean-up funding
was provided by Congress for closing and realigning installations under the
Base Realignment and Closure (BRAC) account. In May 1993, DOD created the
Under Secretary of Defence (Environmental Security) position to oversee
clean-up and other environmental efforts.
Progression of CMSs
DOD has devoted most of its efforts during the past two decades to locating and
studying the characteristics of contaminated military sites. Having essentially
completed the initial investigatory phase at most sites, it is now devoting
most of its current efforts to characterizing contaminated sites and developing
technical plans and schedules for cleaning them up. Although DOD has completed
more then thousand interim clean-up measures (see Section 20.-9.0), it has
completed relatively few permanent clean-up actions.
One measure of evaluating the progress of DOD's environmental restoration
programme is to compare the number of sites in progress to previous fiscal
years. However, when comparing the number of CMSs in progress at the end of
fiscal year 1994 (11,785 sites) to fiscal years 1993 (10,439 sites) and 1992
(10,158 sites), the number of sites undergoing investigations and remedial
activities at the end of each fiscal year appears to be increasing.
As identified in Appendix 20-5, the number of sites requiring investigations
and/or remediation continues to fluctuate as existing sites are determined to
require no further action and new sites are identified.
New sites are identified predominantly as a result of newly discovered historic
contamination and not typically as a result of current deficiencies in
environmental compliance. These new sites can be identified as a result of
conducting RCRA Facility Assessments, Environmental Baseline Surveys required
for BRAC installations and other newly discovered CERCLA and UST sites. For
instance, many new contaminated sites have been discovered as a result of
achieving compliance with UST regulations that require USTs to be upgraded or
replaced by 1998.
The number of sites in progress also increases as a result of sites previously
determined as no further action sites or closed sites are reopened when a
regulatory agency does not agree with DOD's determination that clean-up is not
required or is complete. Similar fluctuations occur with the number of FUDS
sites in progress. The breakdown of the number of sites in the different
stages of investigation and remediation is provided in Section 20.-7.0.
According to the FY 1994 DERP Annual Report, a total of 21,425 CMSs on 1,764
military installations have been identified; remedial response has been
completed at approximately 45 percent of these CMSs. The number of CMSs
reported to be in progress in FY 1994 (11,785 CMSs) are located on 760 military
installations.
Registration of Overseas Bases
In terms of registration for overseas bases there are no requirements to
register CMS with DOD. Commands keep data bases to manage their contaminated
sites and prioritize and develop projects, but no formal registration of
overseas CMS is required.
DOD´s Environmental Clean-up Programme
Implemented in 1975, the IRP was DOD's programme to implement its remedial
responsibilities under the Comprehensive Environmental Response, Compensation
and Liability Act (CERCLA) as amended by the Superfund Amendments and
Reauthorisation Act of 1986 (SARA) and for cleaning up environmentally
contaminated sites that are regulated under other statutes. The IRP is a
four-phase programme consisting of:
· Phase I - record search to identify requirements for physical
examination of sites. (Preliminary Assessment PA)
· Phase II - field study to confirm and qualify the presence or
absence of a contamination problem requiring remedial action (Site Inspection
SI)
· Phase III - technology development for CMSs. (Remedial
Investigation/Feasibility Study)
· Phase IV - corrective action: physical clean-up activity
(Remedial Design/Remedial Action)
Phase IV may require several years given the complexity of problems at some
locations. Some actions may require indefinite operations of containment or
purification systems; however, in these cases, Phase IV is considered complete
when the construction activity is complete.
The breakdown of number of sites in the different stages of investigation and
remediation is provided in Table 20-3.
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Source: DERP Annual Report FY 1994
Preliminary Assessment
The initial step in investigating a CERCLA site is to complete a preliminary
assessment (PA) which is designed to distinguish between sites that pose little
or no threat to human health and the environment and those sites which require
further investigation. The PA is based on site information obtained in
installation records searches, visual site inspections, interviews of site
personnel, deed records of ownership, maps, aerial photographs, and other
applicable information sources. The PA is completed typically by a DOD
contractor. Information to be documented as part of a PA includes general site
description; previous ownership; historical usage of properties; hazardous
chemicals and wastes stored, generated or disposed on the property; and results
of visual inspection such as potential impacts to flora, fauna, food chain and
other areas to the property being assessed and surrounding properties.
Pas have been completed at the majority of the CMSs identified to date. The
Corrective Action investigation programme under RCRA consists of a RCRA
Facility Assessment (RFA), a RCRA Facility Investigation (RFI) and a Corrective
Measures Study (CMSt). A RFA, which is the initial step in the RCRA corrective
action process, acts as a screen for first identifying and then eliminating
Solid Waste Management Units (SWMUs), environmental media, or entire
installations from further consideration for corrective action. RFAs are
performed as part of the RCRA permitting process.
The corrective action investigation process for release of a substance not
regulated as a RCRA hazardous waste from USTs vary from the RCRA Corrective
Action Investigation process. The first step, the Initial Site
Characterization, requires an installation to submit information regarding
local communities, subsurface soil conditions, climate and land use to the
appropriate state or Federal regulatory agency. Data may be compiled from
readily available sources or generated by site investigations. Specific
requirements commonly vary depending on the state in which the site is present,
if the state is the appropriate regulatory agency.
Hazard Ranking System
The HRS was developed by the USEPA to evaluate the relative potential of
uncontrolled hazardous substance facilities to cause health or safety problems
or ecological or environmental damage. The HRS is the principal mechanism that
the USEPA uses to determine if a site should be registered on the NPL. The HRS
provides a measure of relative risks, not absolute risks. EPA also uses the
HRS scores to identify military sites that are to be listed on the NPL. If a
site is listed on the NPL, the DOD then gives that CMS a high priority for
completing necessary investigations and remediation. For DOD, NPL status
generally refers to the entire installation, not an individual site on the
installation. A HRS is determined using data and information collected in PAs
and site inspections (SIs) and can be reevaluated once additional data are
collected. The details of the HRS are provided in Appendix A of the CERCLA
Pollution Contingency Plan (40 CFR 300) and are summarized below.
The HRS site score is a result of the evaluation of four pathways:
(1) groundwater migration,
(2) surface water migration,
(3) soil exposure, and
(4) air migration.
An individual score for each pathway is first identified, then used to
calculate the HRS site score. Evaluations common to each of the individual
pathway scores include:
· Likelihood of release (observed release or potential for release).
· Characterization of contaminant sources (identify sources, hazardous
substances associated with each source, and hazardous substances available to a
pathway).
· Nature of materials that may be released (evaluation of contaminant
characteristics such as toxicity, mobility, persistence, bioaccumulation
potential, and quantities present or potentially present).
· Potential targets (such as humans through ingestion, inhalation, or
other pathways; resources affected or potentially affected; and other targets
dependent on the pathway.
The groundwater and air migration pathways use single threat evaluations,
whereas surface water migration and soil exposure pathways are multiple threat
evaluations. Three threats, drinking water, human food chain and
environmental, are evaluated for surface water migration pathways and two
threats, residential populations and nearby populations, are evaluated for soil
exposure. The HRS does not address the feasibility, desirability, timing, or
degree of clean-up required.
RI/FS Process (CERCLA)
If the results of the PA indicate the need for further investigation, a Site
Inspection (SI) is performed. SI investigations commonly include the
collection of limited waste and environmental samples to confirm whether or not
hazardous substances are present at a site. These data are used to perform the
HRS Scoring. If determined to be necessary, additional samples can be
collected to further refine or support the HRS. As mentioned earlier, the HRS
is used to determine whether or not the site is considered to be an NPL site.
Next, a Remedial Investigation (RI), which is more extensive than an SI, is
performed in order to characterize the nature and extent of contamination at a
site.
The risks posed by on-site contamination to human health and the environment
are also evaluated as part of the RI. Data collected in the RI are used to
develop options for final clean-up actions as part of the Feasibility Study
(FS). A detailed analysis of feasible remedial alternatives includes
cost-effectiveness, short and long-term effectiveness and overall human health
and environmental protection. The FS can be conducted separately or, more
commonly, immediately following the RI to provide one consolidated report. EPA
has published a guidance document outlining requirements and recommendations
for conducting RI/FS studies under CERCLA. The publication is titled:
Guidance for Conducting Remedial Investigations and Feasibility Studies
Under CERCLA (1988). An engineering evaluation/cost analysis (EE/CA)
documents the selection of a remedial action where time is not critical (i.e.,
when there are no immediate risks to human health).
RFI/CMSt Process (RCRA)
The step following the RFI in the RCRA corrective action process is an RFI
which characterizes the nature, extent and migration of releases of hazardous
substances into the environment and the risk posed by the degree of
contamination. The CMSt identifies and evaluates potential remedial measures
for the releases identified and investigated in the RFI.
Leaking UST Investigations/CAP
If the Initial Site Characterization identifies evidence of a release, an
Investigation for Soil and Groundwater Clean-up is conducted. This
investigation is performed to determine the extent of soil and groundwater
contamination at a UST site. If the soil and groundwater data prove necessary,
a site-specific Corrective Action Plan (CAP) is conducted to address releases
from UST(s). If the extent of contamination does not justify active
remediation or removal activities or if it is determined to be technologically
not feasible to actively remediate, the CAP may include requirements for
long-term monitoring, continued control of the groundwater flow at the site,
and placement of a notice of continuing hazard in the property deed. CAPs may
involve more detailed studies that establish the design and implementation of a
clean-up.
Defining Site-Specific Investigation Requirements
The method of sampling, number of samples to collect, analytes to test for, and
degree of complexity of the investigations is highly dependent on the extent
and type of contamination and the degree of uncertainty. If records,
interviews or other documentation are available to identify the specific
suspected contaminated sites, potential contaminants of concern, potential
magnitude of contamination (e.g., known quantity of spills, known quantities
used in area, etc.), site-specific geology and hydrogeology, and other
pertinent information, then the investigation efforts necessary to define the
contamination for remediation is greatly reduced. Because of the complexity of
defining necessary procedures for investigations, DOD sites are largely
dependent on contractors which specialize in the appropriate fields.
General guideline documents for assisting the development of the scope of
different investigations are available; however, because investigations at
different suspected contaminated sites (SCSs) within one installation are
largely dependent on site-specific characteristics, the documents are very
general and professional opinions are required in order to adequately identify
investigation needs.
Introduction
The USEPA and similar agencies at the state and local levels within the United
States are embracing Risk Assessment as the cornerstone of the decision-making
process concerning formulation of clean-up requirements for CCS/CMS. Such
agencies, and the general public, are becoming aware of the staggering site
clean-up costs faced by the nation if it is continued to rely on clean-up
requirements such as "cleaning to background" or "removing all detectable
contamination". If unnecessarily funds are overspent during management of
CCS/CMS, the risks to public health can increase by pulling funding away from
other programmes where greater risk reduction per dollar spent can be
obtained.
A vast number of guidance documents has been issued on Risk Assessment and
related issues, as is detailed further below in this report. As there is not
one single approach to conducting risk assessments, in practice some
heterogenicity exists concerning the evaluation of contaminated sites. Such
heterogenicity may be observed between individual EPA documents and between
individual EPA regions as well (Note: the US is divided into 10 EPA regions).
The evaluation of former military installations and production sites also
follows different procedures.
In the USA all important, decommissioned production sites for explosives dating
back to World War II had been evaluated by a risk assessment performed by
the Agency of Toxic Substances and Disease Registry (ATSDR). However,
this type of risk assessment mainly represents a description of the site
status. Opposed to that approach the evaluation performed for the Alabama
Army Ammunition Plant (which was guided by the US Army) follows strongly
the requests of the US EPA and the Superfund program, respectively. Based on
use-specific scenarios exposure is estimated and finally, acceptable limits for
soil contamination are established.
The idea of quantitative risk assessment has also been applied to other
studies, for instance, by Tom McKone from the Lawrence Livermore
Institute. In particular it may be referred to his modeling work on the
environmental risk assessment for demilitarization of conventional weapons (see
References).
What follows is a brief overview of the expansion of the role of risk
assessment within the United States, followed by a summary of some of the
details concerning application of risk assessment to CCS/CMS, including
references to computer programmes, lists, index values, etc.
The basis for estimating safe levels of exposure form experimental studies with
animals that result in the development of "dose-response" curves (the animals
were dosed with chemicals and then monitored to see the response of the animals
to the chemical). Such experimentation resulted in determination of "acceptable
daily intakes" (ADI), the intake level below which no adverse health effects
would result. USEPA has introduced the term "reference dose (RfD) " in lieu of
ADI. For chemicals that exhibit carcinogenic potential, similarities were drawn
to radiation exposure, and it was argued by some that any exposure, regardless
of dose, was interpreted by some as having the potential to initiate cancer.
The USEPA's application of risk assessment to hazardous waste sites utilizes
the interpretation of what is considered negligible risk to the effect: "site
risks should not exceed the acceptable risk range of one chance in a million to
one chance in ten thousand (1 x 10-6 to 1 x 10-4)". This
muddies the situation by encouraging inconsistency across the US concerning
what risk level activates remedial requirements or, alternatively, to what risk
level site risks must be reduced during remediation. Generally, however, in the
context of hazardous waste site investigations, a criteria risk level of 1 x
10-4 is more frequently being embraced by the USEPA and the States.
To date, however, most Records of Decisions (RODs) that document site decisions
cite the more conservative end of the risk range (1 x 10-6).
The USEPA has also expanded the risk assessment process to address
environmental (ecological) risks posed by CCS/CMS, in addition to human health
risks. This was motivated by the National Contingency Plan (NCP) which requires
management procedures to protect human health and the environment.
Below in this Section the human health risk assessment process, and the
environmental risk assessment process are addressed.
Human Health Risk Assessment Technical Instruments/Process
The USEPA has developed human health baseline risk assessment (HHBRA) guidance
that is in accordance with the NCP. The USEPA's methodology is for the most
part presented in the following EPA guidance documents:
· Risk Assessment Guidance for Superfund, Volume I, Human Health
Evaluation Manual (Part A) (referred to herein as RAGS; USEPA, 1989);
· Risk Assessment Guidance for Superfund, Volume I, Human Health
Evaluation Manual (Part B, Development of Risk-based Preliminary Goals)
(USEPA, 1991);
· Risk Assessment Guidance for Superfund, Supplemental Guidance,
Standard Exposure Factors (USEPA, 1991);
· Exposure Factors Handbook (USEPA, 1990);
· Dermal Exposure Assessment: Principles and Applications (USEPA,
1992);
· Human Health Evaluation Manual, Supplemental Guidance: Interim
Dermal Risk Assessment Guidance (Draft) (USEPA, 1992);
· Selecting Exposure Routes and Contaminants of Concern by Risk-Based
Screening (USEPA, 1993);
· Risk-Based Concentration Table, January-June 1995 (USEPA,
1995);
· Guidance for Data Useability in Risk Assessment (USEPA, 1992);
· Chemical Concentration Data Near the Detection Limit (USEPA,
1991);
· Guidance for Conducting Remedial Investigations and Feasibility
Studies Under CERCLA (USEPA, 1988);
· Supplemental Guidance to RAGS: Calculating the Concentration
Term (USEPA, 1992);
· Soil Screening Guidance (USEPA, 1994);
According to RAGS, the key guidance document for Superfund-type HHBRAs, a HHBRA
should include:
· Data evaluation and identification of contaminants of potential concern
(COPCs);
· Exposure assessment;
· Toxicity assessment; and
· Risk characterization and evaluation of uncertainties.
The following is to expnad on these issues:
* Data Evaluation and Identification of COPCs
RAGS specifies four steps for identifying COPCs:
(1) Assess the validity of data.
(2) Identify site-related contaminants by comparison with background levels.
(3) Eliminate, as possible, site-related contaminants unlikely to pose a human
health risk (i.e., analytes that are human dietary nutrients present in safe
concentrations).
(4) Retain the remaining site-related contaminants as HHBRA COPCs and quantify
their associated risks.
In 1993, EPA Region III issued guidance intended to streamline steps two and
three above. The guidance recommends selecting COPCs primarily by screening
against risk-based concentrations (RBCs). This eliminates the need to carry
large numbers of site-related contaminants through the analysis that do not
pose significant health risks. This often results when COPCs are selected
primarily by screening against background, which identifies site-related
contaminants but does not consider whether they are in concentrations of
concern as regards human health. The EPA Region III guidance recommends
computing HHBRA screening RBCs by assuming exposure levels appropriate to the
site, a target carcinogenic risk of 1E-06 (1 x 10-6), and a target
noncarcinogenic hazard of 0.1. The 1993 guidance document includes a list of
nearly 600 such HHBRA screening RBCs. It was computed using October 1992
toxicity criteria, now out of date.
Several times a year EPA Region III publishes an "RBC Table" of more generic
RBCs for several hundred chemicals (USEPA, 1995). These RBCs are not
specifically intended for selecting HHBRA COPCs, but are for general-purpose
rapid assessment of contamination levels.
The RBC Table presents RBCs for tap water (i.e., drinking water), ambient air,
fish, soil assuming commercial/industrial worker exposure, and soil assuming
residential exposure. They are computed using current toxicity criteria, a
target carcinogenic risk of 1E-06 and a target noncarcinogenic hazard of 1.0.
As a practical matter, the RBCs appearing in EPA Region III's RBC Table differ
only from the risk assessment COPC-selection "screening RBCs" by the assumed
target noncarcinogenic hazard and the RBC Table's use of more current toxicity
criteria. By adjusting the target noncarcinogenic hazard from 1.0 to 0.1, the
RBC Table RBCs become COPC-selection RBCs. When an RBC is not available or is
actually less than background, the original RAGS methodology is followed which
is to select COPCs by comparison with background.
* Exposure Assessment
Exposure assessment consists of identifying populations that may be exposed to
site-related contamination, determining how exposure may occur, and quantifying
intake for realistic exposures. Potentially exposed populations are identified
by developing a conceptual site model that represents the release and transport
of contaminants, and by examining current and probable future land uses. These
land uses are represented by broad land use scenarios. Potentially exposed
current and future populations, and the pathways by which they are exposed are
then identified.
Of the identified populations, those retained for exposure quantification must
satisfy two criteria: (1) there exists at least one complete exposure pathway
from contaminated media to that population, and (2) meaningful exposure is
likely. Exposure frequency and duration are the main criteria for deciding
whether an exposure is "meaningful" and the pathway merits quantification. A
complete exposure pathway typically has four elements:
· a source and mechanism of chemical release
· a retention or transport medium (or media)
· a point of human contact (an "exposure point")
· an exposure route (primarily ingestion, inhalation, or dermal
absorption).
Once potentially exposed populations and exposure routes have been identified,
exposure is quantified by calculating the intake of each COPC. Intake
equations are used to estimate the amount of chemical crossing an individual's
"exchange boundary." They take as their independent variable a COPC's exposure
point concentration (EPC). Aside from the dermal pathway, intake equates in
toxicological terms to the "administered" dose, rather than the dose actually
absorbed into the bloodstream. For the dermal pathway, it is the absorbed
amount. Intake equations are pathway specific, and include both site-specific
and EPA-standardized parameters. The EPC is calculated using site monitoring
data.
For many, if not most, Superfund-type HHBRAs, current risks are much lower than
those calculated for the future, because future exposure assumptions are
generally very conservative. Two key future scenario issues are selecting the
most probable future land use (residential is the most conservative choice),
and whether exposure to groundwater may occur. Shallow groundwater typically
has the highest levels of chemical contamination, but shallow groundwater is
often not potable due to other factors such as bacterial contamination, high
mineral levels or salt water intrusion. Drinking water wells are typically
installed in deeper strata.
The most important component of an HHBRA is the somewhat subjective process of
estimating future land uses and the associated exposure assumptions that go
along with that land use. Adherence to standard default USEPA exposure
assumptions undermines the site-specific aspect of a risk assessment and
frequently results in risk estimates that do not reflect reality. The best
course of action during this stage of the risk assessment is to engage the
regulatory agencies and interested members of the public in dialogue so that
they may be part of this subjective decision-making process and also be made to
understand that site-specific future exposure assumptions are the objective,
rather than arbitrary default assumptions.
After potential land use(s) has been identified, and before chemical exposure
(dose) is estimated, the concentration of the chemicals to which exposure will
occur must be estimated. A COPC's exposure point concentration is the
concentration with which receptors are assumed to make contact. (For details on
how to estimate contaminant intake see Appendix 20-1.)
* Toxicity Assessment
Toxicity data for chemicals detected at CCS/CMS are primarily available from
EPA's two principle repositories of current toxicity information on chemicals
of human health concern:
· the Integrated Risk Information System (IRIS; and
· the Health Effects Assessment Summary Tables (HEAST).
IRIS is EPA's official repository of consensus, or "work group verified," human
health risk information; HEAST contains provisional toxicity values. The RfD is
used to quantify a chemical's noncarcinogenic effects. It represents the
maximum acceptable human uptake of a chemical with noncarcinogenic toxicity,
expressed as a dose - usually administered, rather than absorbed - in
milligrams per kilogram per day (mg/kg-day) (see also Appendix 20-1).
For carcinogens, the slope factor (SF) is used to assess a chemical's potential
human carcinogenic effects. It is an estimate of the increased probability of
an exposed individual developing cancer in his or her lifetime. The SF is
expressed as lifetime cancer risk per (mg/kg-day)-1. The RfD/SF
concept initially was developed for longer term, or "chronic," exposure.
Chronic exposure is considered lifetime or near-lifetime in duration.
The RfD/SF methodology was developed in the 1980s. In 1991, EPA changed the
method from a dose basis (i.e., RfDi and SFi) to an air
concentration basis. For noncarcinogenic effects, the new parameter is the
reference concentration (RfC), which represents the maximum acceptable air
concentration of the chemical (expressed in milligrams per cubic metre
(mg/m3)). The corresponding parameter for carcinogenic effects is
the unit risk (UR), expressed as risk per microgram per cubic metre
(mg/m3)-1 of chemical in the air. Because the RAGS
methodology for quantifying carcinogenic risk and noncarcinogenic hazard was
drafted before 1990, it works best with toxicity values expressed in dose
(USEPA, 1989b). Therefore, HHBRA's typically convert the currently available
RfCs and URs to RfDis and SFis using an assumed human
inhalation rate of 20 cubic metres per day (m3/day) and a body
weight of 70 kg.
* Risk and Hazard Characterization and Evaluation of Uncertainties
In Superfund-type HHBRAs, hazard and risk are quantified through the use of
RfDs and SFs. The excess carcinogenic risk associated with a carcinogen
represents cumulative lifetime effects for a large population of receptors. In
accordance with the NCP, EPA uses 10-4 to 10-6 summed
total risk as a "target risk range" in managing Superfund sites (40 CFR, Part
300.430). For noncarcinogenic effects, the human health toxicity hazard from
exposure to a single chemical is calculated according to Appendix 20-1. As with
carcinogenic risk, individual contaminant HQs are summed by and across pathways
for exposed populations at the given exposure points. The resulting overall
sum is called the hazard index (HI).
Uncertainties associated with the following issues typically are addressed by
HHBRA's:
· sampling and chemical analysis;
· land use;
· pathways selection;
· exposure parameter values for intake calculation;
· toxicity criteria.
A discussion of methods for calculating uncertainties from the above would be
beyond the scope of this study.
Environmental Risk Assessment Process
Environmental Risk Assessments are also referred to as Ecologic Risk
Assessments (ERAs) or Ecotoxicological Risk Assessments. In the year 1994 the
EPA stated that ecotoxicological risk assessments have to form a key part of
every assessment of a Superfund-site (OSWER Directive No. 9285.7-17). The
concepts of ecological or ecotoxicological risk assessment are applicable to
former military installations and production sites. Until present, usually on
overseas bases no risk assessment approach has been used to provide a common
sense approach to remediation goals. This is mainly due to the lack of
acceptance of the models by host nation authorities.
The procedures for conducting ERAs are not as well established as compared to
HHBRAs. This is due to e.g. the requirement to conduct ERAs is relatively new,
toxicity data describing the effects of particular chemicals on specific
biologic receptors are very scarce. Also, the uncertainties are much larger
with ERAs than with HHBRAs.
In spite of the fact that guidance on this topic by the US EPA was available
since the end of the eighties, in December 1993 it was the first time that an
approach was introduced that is similar to the human toxicological risk
assessment procedure. The Wildlife Exposure Factors Handbook provides
corresponding exposure algorithms and parameters for a limited number of
species which allow a quantitative exposure estimation.
Also, computer programmes have become more available to assist practitioners in
the assessment of site risks, e.g. the State of Virginia's "Risk Exposure and
Analysis Modelling System (REAMS) or programmes such as Crystal Ball and At
Risk. Lists are available in the form of: (1) toxicity data for chemicals, and
(2) risk based action levels for chemicals. In this context, data bases such as
IRIS and HEAST (described in the above text) should be mentioned.
EPA and State Clean-Up Attainment Goals
* Maximum Contaminant Level
EPA established Maximum Contaminant Levels (MCLs) for inorganic and organic
chemicals, turbidity, coliform bacteria, and radiological constituents that
pose a human health risk if consumed in drinking water. MCLS are used as
guidelines for assessing the suitability of a surface water or groundwater for
use as a public water supply. MCLs are updated as identified to be necessary
and delineated in Title 40, Parts 141 and 143 of the Safe Drinking Water Act
(SDWA).
States can adopt EPA's MCLs or they can develop more stringent requirements.
Contaminants in groundwater and surface water are compared to MCLs in order to
determine if the media is considered contaminated.
* Water Quality Standards/Groundwater Standards
EPA and state agencies have established and adopted water quality standards for
the purpose of meeting and maintaining reasonable and beneficial uses of water
sources and propagation and growth of aquatic life. Water quality standards for
protecting human health have also been established for water sources used as
public water supplies as well as for other surface waters.
Similarly, various states have established groundwater standards which often
are dependent on the local groundwater situation and may therefore vary
considerably between states. Surface water or groundwater quality standards may
reference MCLs.
* Risk-Based Concentrations (RBCs)
Generally, human health risk assessment involves effort-intensive steps.
Therefore, in order to maximize effciency of risk asessments, RBCs are used
(See also detailed description of the term RBC in Section 20-7.3). RBCs for
soil are commonly used during preliminary evaluation of a suspected
contaminated site because, in most cases, Federal or state standards for soil
and sediment have not been established.
ARARs
At sites which are required to comply with CERCLA, remedial actions must comply
with applicable or relevant and appropriate requirements (ARARs) for the site
conditions. ARARs are requirements, criteria, limitations, or guidelines
developed by Federal, state, or local agencies. ARARs include, but are not
limited to, historical and cultural land use; effects on endangered species;
presence of wetlands; availability of treatment technologies; and cost of
treatment.
A requirement may be either "applicable" or "relevant and appropriate" to a
remedial action. The following example is provided in order to differentiate
between "applicable" and "relevant and appropriate" requirements. EPA
established MCLs (discussed above in this Section) as standards that are
applicable to certain public water systems. When establishing site-specific
ARARs for a military base, MCLs are not legally applicable to clean-up
of groundwater or surface water; however, MCLs may be considered relevant
and appropriate in situations where people use private drinking water wells
in the area.
ARARs can have two detrimental effects on remedial activities: (1) they can
increase the cost of a remediation and (2) they can delay the schedule of
remediation. These effects can be caused by expanded activities onsite to meet
the regulatory requirements, and additional regulatory parties brought in to
review and approve matters within their areas of regulatory expertise. For
example, if the contaminated site is located in a designated historic zone or
below a historic building, the National Historical Association or other
appropriate agency will become involved in determining the method of
remediation.
Interim Remedial Action
One of DOD's priorities for accelerating clean-up and reducing or eliminating
risk to human health and the environment is to focus more effort on interim
measures:
· removal actions (source/waste removal, e.g., contaminated soil
excavation, drum or container removal, etc.);
· interim remedial actions (capping, installing drainage controls, soil
vapour treatment and pumping-and-treating groundwater serve to stabilize sites
by controlling or eliminating migration of contaminants);
· installing fences or other site access control measures;
· providing alternate drinking water supplies to reduce risks by
eliminating exposure to contaminants.
Many actions such as waste removal and treatment that are initiated as interim
measures, are proving to fulfill final clean-up requirements. Interim actions
are typically initiated during the investigation stage at a contaminated site
and are constantly evaluated during the investigation phase. The number of
interim actions completed and the number of interim actions underway have
increased over the past several years and are considered key measures of
clean-up progress. DOD had completed 681 interim actions at 568 sites in FY
1992, 1,015 interim action at 865 sites in FY 1993, and 1,387 interim actions
at 1,173 sites in FY 1994. The cumulative number of interim actions completed
by the end of FY 1994 represents an increase of slightly more than 100 percent
over the cumulative number of interim actions completed as of the end of FY
1992.
Clean-Up Technologies
* CERCLA Presumptive Remedies
Past CERCLA remedial and removal programmes have identified that similar
environmental contamination characteristics are found at certain categories of
sites. As a result of compiling evaluation and clean-up data at these sites,
Superfund developed presumptive remedies to accelerate future clean-up of
contaminated sites. The primary objective of the presumptive remedies
initiative is to use past experience to streamline site investigations,
accelerate selection of clean-up actions and decrease clean-up costs.
Presumptive remedies are preferred technologies for similar types of sites that
have been identified based on historical patterns of remedy selection and EPA's
scientific and engineering evaluation of performance data on implementation of
technology. The use of presumptive methods assists by focusing data collection
efforts during site investigations (i.e., RIs, remedial site evaluation) and
significantly reducing the evaluation of technologies phase (FS or EE/CA). The
Presumptive Remedies identified in EPA's "Presumptive Remedies: Policy and
Procedures" document are provided in Appendix 20-7, Table A. The effect of the
presumptive remedies on the clean-up process is summarized in Appendix 20-7,
Table B.
* Alternative and Innovative Clean-Up Technologies
Because all contaminated sites differ to some extent, especially in their
relation to surrounding communities and sensitive ecosystems, a determination
must still be made on a site-specific basis as to how a given remedial design
is expected to achieve protectiveness during remedial construction as well as
during and following remedial action. Protection of human health and the
environment is one of two threshold considerations (the other being compliance
with ARARs) that must be met in order for an alternative to be eligible for
selection as the remedy for any given contaminated site. EPA encourages review
of the latest Innovative Technologies Semi-Annual Reports, Engineering
Bulletins or other sources for the up-to-date information on the potential
effectiveness and applicability of various innovative technologies. It is
essential to evaluate whether unusual circumstances exist at a site that create
the need to consider non-presumptive remedies based on site-specific conditions
and/or community, state, and primary responsible party (PRP) concerns, or the
availability of a potentially promising innovative technology.
Alternative treatment technologies are alternatives to land disposal. The most
commonly used alternative technologies are solidification/stabilization and
incineration. Innovative technologies are alternative remediation technologies
that lack performance and cost data in Superfund-type applications.
* Summary of Existing Clean-Up Technologies
There have been many different conventional and innovative remediation
technologies implemented at various sites throughout the United States. Some
innovative technologies may have only been implemented thus far as pilot-scale
studies. Many important site-specific characteristics must be evaluated prior
to selecting the most appropriate clean-up technology for a given site. A
summary of remediation technologies for soil, sediment and sludges;
groundwater; and air are provided in Appendix 20-8, Tables A to C,
respectively. These tables provide an overview of types of remedial
technologies available, status of the technology, overall cost, targeted
contaminants to be treated, time to complete, and brief comments concerning
effectiveness or inhibitions. The table also provides information on whether
or not each technology is operation and maintenance and/or capital intensive.
The list of contaminant groups is intended as a general reference only. A
given technology may only treat selected compounds within the constituent
groups listed. Secondary contaminant groups identify contaminants that a
technology can treat, but is less effective than treating the target
constituents or further investigation is required.
* Special Problems posed by UXO and Contaminated Groundwater
Cleaning-up UXO and chemical warfare materials is among the most difficult,
dangerous and time consuming and thus expensive tasks DOD is facing. One of the
reasons is that some ordnance sites, such as the former naval artillery
practice Kahoolawe, Hawaii, are located in remote areas with extremely
difficult terrain. Other sites are wooded and difficult to survey.
Until 1994, the US Army Corps of Engineers had identified almost 1,700 sites on
which buried ordnance were reported. Current technology to remediate buried
ordnance typically involves a survey by operators on foot using hand-held metal
detecting equipment. Bulldozers and specially protected heavy equipment are
used to dig up buried ordnance and transport it to facilities where it will be
de-armed or exploded. The costs are about $65,00 per acre to survey and
remediate. Ordnance sites that have been remediated to a specified depth.
Experts have testified that buried ordnance sometimes migrates toward the
surface with time, so that remediation may be effective only temporarily before
an area must be cleaned again. Thus such sites may require periodic
monitoring.
Remediation of groundwater remains one of the most vexing problems. Groundwater
at many DOD facilities is contaminated by Trichloroethene. In general, current
clean-up technology is slow and costly. Determining the location and extent of
contamination requires expensive wells for sampling and monitoring. Current
systems that pump water from the ground and treat it with scrubbing devices can
take years, even decades, to achieve clean-up standards.
* Clean-Up Technology Databases
EPA published a document which lists and describes 25 available Federal
databases containing information on contaminated site clean-up technologies;
this document is titled "Accessing Federal Data Bases for Contaminated Site
Clean-Up Technologies" (EPA, 1992). These databases are periodically updated
and provide information such as: clean-up technology descriptions, performance
data on existing technology, cost data associated with implementation and
operation of various clean-up technologies, and case studies. Some of these
databases have user fees. The majority of the Federal databases listed are
accessible to the public and many have online capabilities. This document also
provides the hardware/software required in order to operate each database.
* Several examples of these data bases include:
· Alternative Treatment Technology Information Centre (ATTIC): contains
more than 2,000 abstracts of technical references on alternative treatment
methods for remediating hazardous waste.
· CLU-IN Bulletin Board System (BBS): offers messages, bulletins,
computer files, and databases that assist in obtaining current information
about innovative clean-up technology.
· Defence RDT & E Online System: provides information on DOD's ongoing
research and technology efforts.
Post Closure Care (Technologies for Securing)
If upon completion of the closure of a hazardous waste site or completion of
the remediation of a contaminated site, it is determined necessary to implement
measures to further protect human health and/or the environment, post-closure
care measures are identified and implemented. At a minimum, post-closure
activities consist of monitoring, reporting, and maintenance activities.
Contaminated sites that typically are subject to post-closure activities
include former hazardous waste surface impoundments, waste piles, land
treatment units and landfills.
Post-closure requirements are implemented if a regulated hazardous waste unit
fails to satisfy the regulatory requirements of closure by removal or
decontamination. Whenever contaminated soils, subsoils, liners or other
substances have been left in place, post-closure activities typically include
inspection and maintenance of the final cover and groundwater monitoring wells,
as well as the implementation of the applicable groundwater monitoring
programme. If all contaminated soils, subsoils, liners and other substances
have been removed but the groundwater contamination remains, post-closure
activities will include maintenance of the groundwater wells and implementation
of the applicable groundwater monitoring programme. For RCRA hazardous waste
management units, the list of constituents to sample and analyse for and the
analysis methods to be used are identified in the Groundwater Monitoring List
in the RCRA regulations. If constituents on the Groundwater Monitoring List
were not used or disposed at the hazardous waste management unit in question,
analysis of those constituents is not required. Post-closure care is continued
for approximately 30 years or a time period defined by the regulating agency,
either state or Federal.
Prioritizing sites is necessary because funds are not available to clean-up all
contaminated sites at one time; therefore, ranking sites for the purpose of
allocating clean-up funds has become an important process in remediating
high-risk sites. As discussed earlier in this report, the HRS, developed by
EPA, is primarily used to determine if a site should be registered on the NPL.
The HRS scoring is conducted with limited data and is not used by EPA to
prioritize clean-up at the various sites. Various states have developed
prioritizing systems similar to the HRS to evaluate which contaminated sites
should be cleaned-up first. This section discusses the mechanisms used by EPA,
DOD and DOE for prioritizing contaminated sites for clean-up. Although there
are existing prioritizing methods, deficiencies have been identified in each of
the systems and a new method that has been developed recently is discussed this
Section.
EPA Prioritization
* RI/FS Priority Setting Process
As a result of the unexpected large number of sites on the NPL, EPA has been
unable to efficiently complete detailed site studies and remedial action plans.
To assist in identifying the more critical sites, EPA developed an informal
regional RI/FS priority-setting process which is a systematic procedure that
EPA regions must establish to determine priorities for RI/FS projects. This
process is applicable to individual sites and is based on a "worst-first"
principle. This method is only applicable to sites where the RI/FS could be
covered by the Superfund budget which, therefore, excludes CMSs on the NPL
list.
* RA Priority-Setting Process
Due to the backlog of unremediated NPL sites, EPA developed an RA
priority-setting process in order to determine which sites are to be remediated
first. This process incorporates aggregate and subjective evaluations, but is
simple so that the reasons for a particular NPL site receiving a given score
are clear. Because CMSs are not funded by EPA with the Superfund budget, this
process is not applied to DOD sites.
DOD Site Prioritization Processes
In the past, DOD (and DOE) were not under the great external pressure as they
currently are to remediate hazardous waste sites. Many DOD sites are located
in relatively remote or inaccessible areas as well as national security
restricts the public from gaining access to and obtaining information
concerning DOD installations. These issues have inhibited public scrutiny of
CMSs. The source of funds for DOD clean-ups is the agencies' operating funds,
not Superfund; therefore, DOD found it necessary to develop their own priority
setting methods: the Defence Priority Model (DMP), to assist in ranking sites
for remedial action. Because DOD previously was under less pressure than EPA
to make a quick decision of whether a site is contaminated or not, DOD was able
to collect more field data for use in the model. The historical practices of
DOD for prioritizing which sites to clean-up first are further discussed
below.
* General DOD Prioritization
Because CERCLA of 1980 and base closure laws require that all Federal property
be cleaned up before it is transferred to non-Federal owners for reuse, DOD,
therefore, gives a high priority for clean-up to installations scheduled to
close and realign in order to accelerate property transfer to local communities
for economic revitalization. DOD also gives high clean-up priority to sites on
the EPA's NPL, a register of the nation's worst contaminated sites. Most
closing and realigning bases are not on the NPL; therefore, the need for
clean-up funding has been accelerated for many installations that would not
have been eligible if they were not being closed or realigned. A 1994 GAO
report indicated that DOD had too many high priority sites that distracted from
remediating the worst sites first.
The Community Environmental Response Facilitation Act (1992) amended CERCLA to
expedite the transfer of closed or realigned DOD bases to non-Federal ownership
by considering that clean-up actions "have taken place" if they are in place
and operating properly and successfully. However, because many of the closed
bases are in the early stages of the clean-up process, little of the property
has actually been transferred to non-Federal owners. In order to further
facilitate non-Federal reuse of the closed bases, Congress in the National
Defence Authorization Act (1994) permitted long-term leases of closed base
property to non-Federal users; however, few leases have been signed. Issues
affecting leases include: (1) government potential liability for hazardous
waste generated by tenants; (2) time and effort required to complete documents
and processes required by Federal, state, and local laws and DOD policies
before property can be leased; and (3) obligation of environmental services to
monitor and manage property.
* Defence Priority Model
In November 1987, the Office of Deputy Assistant Secretary of Defence
(Environment) of DOD, proposed to establish a prioritization method, the
Defence Priority Model (DPM), for relative ranking of IRP sites requiring
remedial action. This DPM was not to replace using EPA's HRS, but was to be
applied to a site after a RI/FS has been completed as opposed to the HRS which
is applied to sites where relatively little information is known (i.e., only PA
or SI conducted).
The DPM was used to identify those sites with the highest environmental and
health significance so that DERA funding for remedial action was made available
to those sites. The DPM scores CMSs based on the following three (3)
factors:
· the potential for contaminant transport (pathway subscore);
· characteristics and concentration of each contaminant (hazard subscore);
and
· the presence of potential receptors (receptor subscore).
This DPM score, along with other pertinent information such as regulatory
requirements and programme efficiencies, is used to determine the relative
priority of a remedial action project. The DPM is not intended for use in
ranking all CMSs at DOD facilities. Sites posing imminent threats from
contamination receive top priority for clean-up and do not become part of the
DPM evaluation. In addition, higher priority is assigned to bases undergoing
closure - which is not incorporated into the DPM.
The DPM is (absolute) risk-based, includes both human health and ecological
impacts (with a significantly greater weight on human health), can be used to
rank sites, is not amenable to cost-benefit interpretation, and deliberately
omits social and economic impacts from the formal calculations. The model was
not developed as a tool for dynamic tracking. It has only been recently that
site clean-up has been restricted by lack of funds. With an increasing number
of sites with detailed characterization completed, stiffer competition for
funds is expected to become evident in the near future. Thus, a need for a
prioritizing system that incorporates a larger number of factors is needed.
Based on the analyses of the existing prioritizing methods published in
"Ranking Hazardous Waste Sites for Remedial Action" (National Research Council,
1994), DOD decided to discontinue use of their modelling approach referred to
as the DPM. DOD has developed a new method, Relative Risk Site Evaluation, that
is discussed below.
* DOD Relative Risk Site Evaluation
The DOD has developed a Relative Risk Site Evaluation framework as a method of
categorizing and prioritizing sites in the DERP into high, medium and low
relative risk groups. This categorization of sites is based on the evaluation
of contaminants (contaminant hazard factor), contaminant migration pathways
(migration pathway factor), and human and ecological receptors of contaminant
exposure (receptive factor) in groundwater, surface water, sediment and surface
soils. The air media is not currently considered by the relative risk
evaluation framework because the risk via the air pathway from DOD sites
without soil contamination is currently minimal and the preliminary remediation
goals (PRGs) for contaminated soils and water include consideration of
inhalation of volatiles and/or contaminated particulates (for soil only). The
different sites located at each DOD installation are evaluated separately and
each assigned a high, medium or low priority ranking. The evaluation framework
assists DOD in ensuring that the DERP funds are directed at those sites and
SCSs that pose the highest risk to human health and the environment to the
maximum extent feasible. The results of the Relative Risk Site Evaluations
will be combined with the assessment of other risk management concerns
pertaining to the site, such as regulatory enforcement status of sites and
technology availability, prior to the allocation of DERP funds to a particular
site.
This rating procedure uses site information gathered from investigations
conducted to date and from interviews with site personnel or knowledgeable
members of the public and regulatory community. The rating for a site can
change by reevaluating that site as additional information becomes available.
Sites and SCSs that lack reliable data of contaminant concentrations are not
rated using this method but are designated "Not Evaluated" and are deferred,
programmed for additional data collection, a removal action if warranted, or
other appropriate response action before they are evaluated.
The rating for the contaminant hazard factor (CHF) is determined based on the
ratio of the maximum concentration of a contaminant in the media to a
risk-based concentration standard for that contaminant. For human health, the
risk-based concentration standard for carcinogens is the concentration that
presents a 1 in 10,000 risk of increased cancer incidence, which is the
remedial action threshold for carcinogens defined by EPA (OSWER Directive
9355.0-30). The original Region IX EPA RBCs, which are based on a one-in-one
million risk of increased cancer incidence, were multiplied by 100 to be used
in the CHF factor. Region IX EPA updates the RBCs/PRGs on a semiannual basis;
therefore, PRGs used in calculating the CHF would also require updating.
The concentration standard for non-carcinogens is the concentration that
provides an exposed individual with the daily referenced dose (RfD). The RfD
is the estimated daily exposure level of a contaminant to a human population
below which adverse non-cancer health effects are not anticipated (see also
Section 20.-7.3 and Appendix 20-1). Residential concentrations were used for
the soil PRGs provided in Appendix B of the DOD Relative Risk Site Evaluation.
Conducting risk assessments and identifying remedial clean-up goals based on
the current and future usage of the property in question is currently an
important issue being discussed by the Federal government regulators.
Considering potential future land use when identifying clean-up goals would
increase PRG contaminant concentrations, decrease clean-up cost, and decrease
remedial activity time frames.
The development of this Relative Risk Site Evaluation process is relatively new
and results of implementation of this evaluation method for prioritizing
remedial action at sites are not available.
DOE's ERPS
The DOE developed their own priority setting model called the Environmental
Restoration Priority System (ERPS). A brief summary of the technical features
of ERPS is described below because it offers another choice in priority setting
models; however, because the focus of this report is not on DOE practices, the
discussion is brief. ERPS is a comprehensive model that addresses both
radioactive and nonradioactive hazardous wastes and is applicable to all DOE
sites. Dynamic tracking is an important feature of ERPS that is not offered by
DPM. This involves updating the model on an annual basis to be considered in
each year's funding allocations and tracks the reductions of risks achieved by
ongoing remediations. Similar to DPM, ERPS is used to address longer-term
problems; immediate risks were to be addressed separately from ERPS. ERPS
includes cost estimation for remediation and associated risk reduction
achievements. ERPS allows input of subjective judgement in the scoring process
if adequate scientific data are not available for the site in question. This
allows for "user friendliness" but can also lead to poor decision-making if
abused or used by unqualified personnel.
Historical incidents created concerns for the safety and health of communities
in the vicinity of contaminated sites. In addition, historical accidents and
contaminant exposure incidents caused concern for employees exposed from
working in the areas of contamination, those handling hazardous waste and those
involved with the investigation and clean-up of hazardous waste.
In 1985, a consortium of federal agencies consisting of NIOSH, OSHA, USCG, and
the EPA, published the "Occupational Safety and Health Guidance Manual for
Hazardous Waste Site Activities". This guidance document, not regulation, was
produced due to the need for direction for workers that had been employed to
carry out the work detailed in CERCLA. In 1986, Section 126 of SARA mandated
OSHA to promulgate a rule that would protect both emergency response and
hazardous waste workers from the effects of hazardous materials exposure during
their work. In December 1986, OSHA established the Interim Final Rule 29 CFR
1910.120, Hazardous Waste Operations and Emergency Response, which was
basically a rewrite of the 1985 guidance document. The final rule passed in
March 1989 and became effective March 6, 1990.
OSHA's 29 CFR 1910.120 addresses health and safety programmes including site
work plans and site-specific health and safety plans; site characterization and
analysis such as required personal protective equipment, monitoring equipment
required, risk identification and other essential factors; site control;
training requirements; medical surveillance programme requirements; drum and
container handling requirements; decontamination; emergency response measures;
and other health and safety factors.
Various DOD components, such as the US Army Corps of Engineers (USACE) and the
Air Force have their own health and safety manuals which are prepared based on
29 CFR 1910.120 health and safety requirement. Other DOD components follow
OSHA health and safety requirements.
In the period 1984 to 1995, DOD had devoted more than 10 years and $11 billion
to identifying, studying and cleaning-up contamination on thousands of military
installations across the nation. Defence agencies have identified more than
27,000 suspected contaminated sites on more than 9,700 military installations
and former defence properties in all 50 states. About 17,000 sites are expected
to require environmental clean-up. Using today´s technology, the cost to
remediate DOD sites alone is estimated at $30 to 35 billion, and the total cost
of clean-up at current and former defence sites including DOE sites is
projected to exceed $200 billion. How carefully such estimates have to be
viewed at, is shown by the development of cost estimates over the last years:
in 1989 DOD estimated that completing the clean-up programme would cost between
$6.9 and $13.7 billion (1995 dollars). Now, it is considered that the programme
costs may exceed $30 billion. The Inspector General of DOD found that average
clean-up costs for defence facilities scheduled to be closed were typically
about 60 percent higher than initial estimates.
During the last decade, DOD´s spending for environmental clean-up in
average has increased 23% each year. In 1984, DOD spent about $200 million for
clean-up; in 1995, the Congress authorized DOD to spend about $2.5 billion on
environmental clean-up programmes. A similar amount will be required in 1996.
DOD, however, expects significant reductions in spending for environmental
clean-up in the next years, when many projects will begin the transition from
study and analysis to remediation. Until 1994, most of the clean-up budget was
allocated for studies; clean-up costs first exceeded 50 percent in 1994 when
relatively few sites were actually in the final phase of clean-up. Emerging
technologies now being developed or field tested also suggest a significant
potential for cost savings (see Sections 20.-4.0 and 20.-13.0).
There is much uncertainty about future costs. For example, each year the
department identifies new contaminants on existing sites as well as additional
polluted sites. Furthermore, most sites are still in the study phase and the
price development at the clean-up market in the time needed to complete
studies, analyses and remediation is difficult to project. Recent court rulings
could also drive costs by leading to stricter clean-up standards than those DOD
originally has planned to meet.
The different DOD components utilize various cost estimating systems for
developing detailed cost estimates and cost engineering analyses of projects
that need to be implemented. Costs developed are used to assist DOD in budget
planning for the various types of environmental projects (site investigations,
remedial/removal activities, O&M activities, and projects necessary to
maintain or achieve regulatory compliance). The Navy utilizes the Naval
Facilities (NAVFAC) Cost Engineering System (CES) software and the Army and Air
Force utilize the Microcomputer Aided Cost Estimating System (MCACES) software
for developing detailed cost estimates and cost engineering analyses. Cost
estimates using both of these cost estimating systems can be prepared using the
standard building system structure as well as the new DOD Work Breakdown
Structure. If cost estimates for certain products, labour or other tasks are
not available in the NAVFAC CES or MCACES databases, Means Cost Data Books
and/or ECHOS Environmental Restoration: Assemblies Cost Book are used as
sources for obtaining cost estimates. Both sources update cost estimates on a
regular basis.
Cost estimates are typically generated by contractors at the same time the
remediation designs are prepared. Once the design(s) accompanied by the
associated cost estimate(s) is submitted for a CMS and funds have been
allocated, the design project is advertised for contractors to submit bids for
completing the remediation.
The development of innovative technology is essential to increasing efficiency
and effectiveness of fulfilling environmental restoration demands facing DOD.
Innovative technologies are likely to provide significant potential for cost
savings both during site characterisation and during clean-up (see Section
20.-4.0). DOD thus has developed and implemented a strategy that is designed to
foster technologies that address DOD environmental needs, identify
cost-effective technologies, overcome barriers to the application of
technologies, expedite commercialization of technologies, and enhance US
competitiveness in the global market.
The methodology for technology development is supported by the integrated
efforts of the DOD components and is coordinated through the Office of the
Secretary of Defence. In order to support research and development (R&D)
technologies for remediation, sampling and analysis, and other such actions,
DOD is using programmes outside of DERA and BRAC, such as the Strategic
Environmental Research and Development Programme (SERDP), the services'
Research, Development, Testing and Evaluation (RDT&E) programmes, and the
DOD National Environmental Technology Demonstration Programme (DOD/NETDP).
A list of clean-up projects funded through SERDP in the financial years 1995
and 1996 is contained in Appendix 20-9. It exhibits that the clean-up programme
of SERDP focuses on conducting research and development on the issues
remediation technologies, monitoring and characterization methods and
technologies, and assessment methods. In 1996, there is evidence of a certain
shift of focus as new projects - among others - serve to better understand the
fate of contaminants under natural conditions. The relevant projects involve
research on the natural attenuation of contaminants and subsurface
bioremediation process monitoring indicators.
DOD components and EPA are selecting characterized CMSs with appropriate
contaminants to serve as test locations, developing common Quality Assurance
and Quality Control procedures, and developing coordinated dissemination
mechanisms for reporting results of technology demonstrations and evaluations.
The components and EPA will establish partnerships with government and private
interests to carry out technology demonstrations at selected sites and will
provide researchers and developers with technical and field support. The
following sites in DOD/NETDP already have been identified:
· Port Hueneme Naval Construction Battalion Centre sites for technologies
for fuel hydrocarbon remediation
· Volunteer Army Ammunition Plant sites for demonstration involving
technologies for the remediation of energetics and heavy metals
contamination
· Wurtsmith Air Force Base for development and testing of integrated
biological/Physicochemical remediation processes and evaluation of innovative
monitoring and measurement technologies
· McClellan Air Force Base sites for demonstrating technologies for
solvent remediation
· Dover Air Force Base to house the Groundwater Remediation Field
Laboratory.
DOD's Environmental Security Technology Certification Programme (ESTCP) is
designed to move promising new technologies that address DOD specific
environmental problems from DOD laboratories to CMSs for demonstration and
validation. DOD's innovative technologies are shared with other federal
agencies and are introduced to the commercial market in order to expedite
restoration of CMSs and to receive economic benefits for DOD's R&D
investments. DOD has reviewed innovative technologies and is currently
selecting technologies that appear promising to fund for demonstration. DOD
expects to fund up to 40 technology demonstrations, the majority of which will
feature clean-up technologies. More detailed information on what types of
technologies are likely to be tested were not yet available.
The Federal Remediation Technologies Round table (the Round table) was created
to exchange information on hazardous waste site remediation technologies, to
consider cooperative efforts of mutual interest, and to develop strategies that
could lead to a greater application of innovative technologies. The member
agencies of the Round table consist of the USEPA, DOE, DOI and DOD (includes
Army, Navy and Air Force). The Round table compiles information and data
collected in case studies on remedial technology including bioremediation,
groundwater treatment, soil vapour extraction, thermal desorption, soil
washing, in situ vitrification, and other remedial technologies. As additional
information is gathered on these technologies, documentation is be developed
and supplemented. The Round table also established guidelines to documenting
cost and performance for evaluating remediation projects.
AEHA (U.S. Army Environmental Hygiene Agency): Health Risk Assessment for
Consumption of Deer Muscle and Liver From Joliet Army Ammunition Plant. Joliet,
Illinois, Project No. 75-51-YF23, Aberdeen Proving Ground, Maryland. June
1994
Anslow, W. P., and Houck, C. R.: Systemic Pharmacology and Pathology of Sulfur
and Nitrogen Mustards. Chemical Warfare Agents and Related Chemical Problems,
Chapter 22, Summary of Technical Report of Division 9, NDRC, pp. 440-478 and
731-737. 1946
APG (U.S. Army Aberdeen Proving Ground): Focused Feasibility Study, Operable
Unit A (Draft). Prepared by Dames & Moore for Hazardous Waste Remedial
Actions Program, Oak Ridge, Tennessee, under contract to U.S. Army Aberdeen
Proving Ground Installation Restoration Program. January 1995
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Burmaster, D. E. and Lehr, J.H.: It's Time to Make Risk Assessment a Science.
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Chemical Stockpile Disposal Program: Final Programmatic Environmental Impact
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Daley, P.: Military Marches Toward New Horizons in Pollution Control. Pollution
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Waste Management. 1987
Gilbert, R.O.: Statistical Methods for Environmental Pollution Monitoring, Van
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Houghton, A. and Siegel, L.: An Excerpt from the Military Contamination and
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ICF-Clement Associates, Inc.: Comparative Potency Approach for Estimating the
Cancer Risk Associated With Exposure to Mixtures of Polycyclic Aromatic
Hydrocarbons. Interim Final Report. Contract No. 68-02-4403, USEPA. 1988
Kingery, A.F., and Allen, H.E.: Environmental Fate of Alkyl Methylphosphonates
Arising from Chemical Surety Material (CSM) and Potential Non-CSM Sources in
Soil and Aqueous Media, Final Report, U.S. Army Environmental Center, Technical
Support Division, Aberdeen Proving Ground, Maryland. March 1994
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Effects Data Base Assessment. Methods for Estimating Multi-Pathway Exposures to
Environmental Contaminants. Final Report, Phase II. UCRL-21064. Lawrence
Livermore National Laboratory. June 1988
Mecler, F.J.: Mammalian Toxicological Evaluation of DIMP and DCPD (Phase
3-IMPA), U.S. Army Medical Research and Development Command, Environmental
Protection Research Division, Fort Detrick, Maryland. 1981
Munch, D.: Soil Contamination Beneath Asphalt Roads by Polynuclear Aromatic
Hydrocarbons, Zinc, Lead and Cadmium. The Science of the Total Environment,
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Norback, D.H., and Weltman, R.H.: Polychlorinated Biphenyl Induction of
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Reynolds, M. L., et al.: Relationship Between the Biodisposition of (3H)soman
and its Pharmacological Effects in Mice. Toxicol. Appl. Pharmacol. Vol.
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Roach, M.C., et al.: Fluorescence Detection of Alkylphosphonic Acids Using
p-(9-anthroyloxy) Phenacyl Bromide. Army Research Office, Research Triangle
Park, NC, Government Reports Announcements and Index, Issue 18 (NTIS/AD-A180
870/9). 1987
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in Workers Exposed to Manganese Dioxide Dust. British Journal of Industrial
Medicine, Vol. 49, pp. 25-34. 1992
Rosenblatt, D., et al.: Problem Definitions on Potential Environmental
Pollutants II, Physical, Chemical, Toxicological, and Biological Properties of
16 Substances. U.S. Medical Research and Development Laboratory, Frederick,
Maryland. 1975
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Aquatic Species of Plants. Edgewood Arsenal Technical Memorandum, EB-TM-73011,
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Seventh Edition, Van Nostrand Reinhold Publishers, New York, pp. 756. 1989
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aluminum, Barium, Beryllium, and Tungsten. J. Nutrition, Vol. 105, pp. 421-427.
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Other surficial Materials of the Conterminous United States. U.S. Geological
Survey Professional Paper 1270. 1984
Takada, H., Onda, T., Ogura, N.: Determination of Polycyclic Aromatic
Hydrocarbons in Urban Street Dusts and Their Source Materials by Capillary Gas
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1990
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USAEC (U.S. Army Environment Center): Reference Sampling and Analysis Program:
Soil Sediment, and Surface Water Reference Data Report. Draft Final, Aberdeen
Proving Ground, Edgewood, Maryland. March 1995
U.S. Army: Policy and Guidance for Identifying U.S. Army Environmental Program
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RCS DD-P&L (SA) 1383 (OMB A-106 Report), Vol. II, Edition III. July 1993
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1992
U.S. Army Corps of Engineers (USACE), latest revision. Safety and Health
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Remedial Response, Washington DC. December 1994
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Illinois. 13 June 1994
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Washington DC. September 1992
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Attachment 1, Risk Assessment Paper for Systemic Toxicity and Carcinogenicity
of Aluminum (CASRN 7429-90-5). memorandum from the Office of Emergency and
Remedial Response, Washington DC, to Pat VanLeeuwan, EPA Region V, Chicago,
Illinois. 4 May 1992
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Exposure Factors (Interim Final), Office of Emergency and Remedial Response,
Washington, DC. 1991
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Goals) (Interim). Office of Emergency and Remedial Response, Washington DC,
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Hazardous Waste Management Division, Philadelphia, Pennsylvania. 1991
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Environmental Assessment, Washington DC. 1990
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Evaluation Manual (Part A) (Interim Final), Office of Emergency and Remedial
Response, Washington DC, EPA/540/1-89/002. 1989
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Response. Washington, DC. 1988
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in Relation to Air Levels Among Roofers. Archives of Environmental Health, Vol.
44, No. 3, pp. 157-163. 1989
Details on Calculating Risk Assessment Parameters
Estimating Contaminant Intake
The generic equation for estimating contaminant intake is:
CMS Categories and Site Types
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Notes:
1 The site descriptions provided in this table are not intended to
be all-encompassing or exact regulatory definitions.
They provide only general descriptions of the different categories of DOD
sites.
AST Aboveground storage tanks
bldg. building
PCB Polychlorinated biphenyl
POL Petroleum, oil and lubricants
UST Underground storage tank
UXO Unexploded ordnance
WWTP Wastewater Treatment Plant
Total Number of Contaminated Sites by Category1 DOD and its Components
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Appendix 20-4: (continued)
Source: DERP FY 1994 Annual Report
1 The number of sites presented in this table includes sites with
investigations or remediation
in progress and sites where investigation and/or remedial activities have been
completed.
2 DOD total, including FUDs.
Progression of Active CMSs 1
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1 These numbers do not include FUDS.
2 The number of sites identified in this table are the number of sites
undergoing site investigation, interim action, remedial design and/or clean-up.
The numbers do not include the number of sites with response completed to date.
As of September 30, 1994, it is reported that 9,640 sites with response
complete exist. Each DOD installation can have more than one site.
NR = Not reported
Source: DERP Annual Report for Fiscal Year 1994
CERCLA, RCRA, and UST Investigations and Clean-Up Processes
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A: Current Presumptive Remedies 1
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PCB = Polychlorinated Biphenyls
TBD = To be determined
NA = Not applicable
1 Source: Presumptive Remedies: Policy and Procedures, EPA,
1993.
2 Source: Moving Sites Faster Through Streamlined Oversight,
Versar, 1995.
B: Effect of Presumptive Remedies on Clean-up Process
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1 Streamlined for municipal landfills
A: Remediation Technologies for Soils, Sediments and Sludges
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Source: EPA and Air Force, July 1993
1 Listing of contaminant groups is intended as a general reference
only. A technology may treat only selected compounds within the contaminant
groups listed.
Further investigation is necessary to determine applicability to specific
contaminants.
2 Costs are provided in 1993 U.S. currency per 1,000 liters of
groundwater treated unless otherwise indicated.
3 Time required to clean-up a "standard" site using the specified
technology. The "standard" site is 18,200 metric tons for soils (0.41 hectare,
3.04 meters deep).
FH = fuel hydrocarbons
H = halogenated
nonH = non-halogenated
SVOCs = semi-volatile organic compounds
VOCs = volatile organic compounds
O&M = Operations & Maintenance
B: Groundwater Remediation Technologies
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Source: EPA and Air Force, July 1993
1 Listing of contaminant groups is intended as a general reference
only. A technology may treat only selected compounds within the contaminant
groups listed.
Further investigation is necessary to determine applicability to specific
contaminants. Technology can be used for treatment of "secondary"
contaminants; however, results are typically less effective or else the
technology is in the developmental stages for these contaminants.
2 Costs are provided in U.S. currency per 1,000 liters of
groundwater treated.
3 Time required to clean-up a "standard" site using specific
technology. The "standard" site is a normalized site of 0.41 hectare, 3.04
meters deep with an average porosity of 30% and a shallow aquifer. Site volume
is 3,785,000 liters.
4 Time to complete is not applicable (NA) because these treatment
technologies are either support technology and clean-up time is dependent upon
primary treatment, or the clean-up time is highly dependent upon contaminant
concentrations and/or types and clean-up time cannot be predicted without such
site-specific knowledge.
FH = fuel hydrocarbons SVOCs = semi-volatile organic compounds
H = halogenated VOCs = volatile organic compounds
nonH = non-halogenated O&M = Operation and Maintenance
C: Air Emissions/Off-Gas Treatment Processes
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Source: USEPA and Air Force, 1993
1 Listing of contaminant groups is intended as a general reference
only. A technology may treat only selected compounds within the contaminant
groups listed.
Further investigation is necessary to determine applicability to specific
contaminants.
2 Costs are provided in 1993 U.S. dollars.
3 Time to complete is not applicable (NA) because these treatment
technologies are support technologies used to treat off-gases produced by
another remediation
technology; therefore, the site clean-up is wholly dependent upon the clean-up
time associated with the primary treatment.
FH = fuel hydrocarbons
H = halogenated
nonH = non-halogenated
SVOCs = semi-volatile organic compounds
VOCs = volatile organic compounds
kg = kilogram
O&M = Operation and Maintenance
Financial Year 1995 and 1996 SERDP Clean-up Projects
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A Army
AF Air Force
DoD Department of Defence
DOE Department of Energy
EPA Environment Protection Agency
FTS Fourier Transform Spectrometer
FY Financial Year
MUDSS Mobile Underwater Debris Survey System
N Navy
NMR Nuclear Magnetic Resonance
PAH Polyaromatic Hydrocarbons
PNL Pacific Northwest Laboratory
SCAPS Site Characterisation and Analysis Penetrometer System
USGS United States Geological Survey
UXO Unexploded Ordnances
VOC Volatile Organic Carbons
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