ESOH Resource Transformation

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ESOHResourceTransformation
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Environment History

• Common Law Property Rights
• Property owned from Heavens to Hell
• Restraints on use couched in nuisance
• Development of Legislative and Administrative Law
• Zoning
• Sanitation
• Conservation
• Environmental Protection
• Why? Because Values Change

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Traditional E

• Air Quality
• Water Supply and Quality
• Hazardous Waste
• Pollution Prevention
• Natural Resource (Endangered Species, Marine
  Mammals)
• Cultural Resources (Historic Properties, Native
  American consultations)
• NEPA (National Environmental Policy Act)
• Noise Pollution

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Environmental Economics

• Environmental Laws Redefined Internalization of
  Cost
• Rationed Resource Supply (Conservation, Permits,
  Emission Limits)
• Created New Cost (Penalties)

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Excellence Achieved in the Department of Defense

• Managed Risk of Non-Compliance
• 4,196 Hazardous Waste Cleanup Sites Completed
• Enforcement Actions down 91 since 1993
• Managed Hazmat Processes
• DoD accounts for
• DoD accounts for
• Individual private sector sites have TRI releases
  levels exceeding DOD cumulative levels
• Solid Waste Diversion ahead of 2005 goals
• More TE species/acre than any other Federal Land
  Manager

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Challenge Remaining

• Underestimated Risk to Resource Supply and
  Capability
• Loss of access to necessary resources
• Increased operational costs
• Work-arounds
• Result
• Encroachment
• Lost productivity
• Sustainment Paradigm needed for natural
  infrastructure

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The Resource Base

• Components of Natural
  Infrastructure
• Airspace
• Air Shed Emissions Availability
• AICUZ (Noise Bands)
• Groundwater Access
• Groundwater Discharge Availability
• Surface Land Access
• Surface Water Access Discharge
  Availability
• Subsurface Land Access
• Spectrum
• Work Force

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Encroachment Risk
Competing Needs
Zoning Action
New Contaminants
Permit Limit
RESOURCE BASE
RISK
RISK
FINANCIAL
OPERATIONS
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ESOH Transformation

• GOAL Sustain Resource Supply to Operational
  Capability
• Health Protection and Regulatory Compliance
  Inherent in Operability
• PRINCIPLES
• Identify operational and financial risks to
  resource requirements in an objective, quantified
  manner
• Inform risk management decisions through total
  cost visibility for ESOH resource sustainment
• Leverage equity value of the ESOH resource
  portfolio
• Manage risk through investment that supports
  operational and regulatory requirements

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1. Identify and Manage Operational and Financial
Risks to Resources

• Formal modeling developed to quantify resource
  capability needed and available to support
  operational needs
• Take proactive stance on proposed resource
  constraints (e.g., perchlorate, critical habitat
  designations)
• Manage total resource base in Base General Plan
• Operational metrics for ESOH-MS implementation
• Permitted tons of air emissions
• Restored land for operational use
• Workforce availability (under development)

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2. Total Cost Visibility

• Resource sustainment carried through numerous
  funding lines
• MILCON, Acquisition, OM
• Limits opportunities for operational savings or
  cost avoidance
• Total Costs and Liabilities must be identified to
  inform future resource investment decisions
• DOD actions
• Global regulatory actions

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3. Leveraging Value

• DoD managed environmental resources are now a
  commodity with an equity value
• Tools exist to inventory and appraise public and
  private resource value
• NRLAM (Natural Resource Liability Asset
  Management)
• Environmental Appraising
• Resource value intrinsic to managing risk more
  effectively and efficiently
• Enables negotiation from positive position

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4. Tie Programming Goals/Budget to Resource
Requirements

• Current Environmental Program
• DPG tied to regulatory requirements
• Goal No open enforcement actions
• Goal Federal Facility Agreement milestones
• Budget tied to regulatory requirements
• Level 0, 1 prioritization, FFA requirements
• Investment to sustain operations (P2,
  conservation, permit enhancement) not always
  eligible
• Transform to investment strategy that manages
  operational and financial risk across the ESOH
  spectrum

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The ESOH Management System
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Transformation Spheres of Influence
Operationally-Driven ESOHMS
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Environmental TransformationMcGuire AFB

• Replacing C-141s with C-17s
• Ozone Non-attainment Area
• Near Limit on NOx Budget
• P2 Efforts Created Head Room in VOC Budget
• Traded VOC Head Room for NOx in SIP
• Increased Resource Availability Doubled
  Mission Capacity

Traded 200 tons/yr
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Past PerformanceStreamlines Responses
Cohort A Small ArmsRanges
Streamlined Site Investigation
Presumptive Remedy
Set Future Use/DQOs
Focused Site Evaluation
Cohort B Boresight Ranges
Set Future Use/DQOs
EE/CA
RemovalAction
Focused Site Evaluation
Cohort C EOD Ranges OB/OD Sites
Set Future Use/DQOs
Streamlined Remedial Investigation
Focused Feasibility Study
RemedialAction
Site Evaluation
Cohort D CWM Sites
Safe to Reuse
Set Future Use/DQOs
Remedial Investigation
Focused Feasibility Study
Remedial Action
Site Evaluation
209 Munitions Response Sites
Cohort E Pyro/Prac Sites
Remedial Investigation
Focused Feasibility Study
Remedial Action
Set Future Use/DQOs
Site Evaluation
Cohort F All Other Sites
Set Future Use/DQOs
Remedial Investigation
Feasibility Study
Remedial Action
Site Evaluation
Cohort G MunitionsConstituents
Set Future Use/DQOs
Remedial Investigation
Feasibility Study
Remedial Action
Remedy Operation
Site Evaluation
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Current and Future Actions

• New Policy Guidance
• Jun 02 SAF/IEE ESOH Management Information System
  Memo (ESOHMIS)
• AFPD 90-8, Environment, Safety and Occupational
  Health
• AFI 90-801, ESOH Management System Implementation
• SPG/APPG inputs
• Resource Capability Model fielded
• Pilot tests, ACC bases, MMR, ANG pilot
• Environmental Appraisals underway
• Natural Infrastructure considerations in force
  shaping

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Back ups only
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Performance-based Cleanup Transformation
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Environmental Transformation Cleanup

• 1987 (then)
• Cost to Complete (CTC) estimate 14B
• Time to Complete estimate CY2000
• Lack of Knowledge / Technology / Credibility
• High Decision Uncertainty
• Intense Legal and Regulatory Scrutiny
• RESULT
• Program Managed to Process Requirements
• Goals, Objectives based on Process Milestones
• PPB Process tied to Process Milestones
• Massive oversight bureaucracy created

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Need for Transformation

• 2003 (and now)
• Program Cost to Complete (CTC) estimate 50B
• Time to Complete estimate
  CY2014
• 20 years, 12,000 sites of Knowledge / Tech. /
  Cred.
• High Decision Uncertainty
• Intense Legal and Regulatory Scrutiny
• RESULT
• Program Managed to Process Requirements
• Goals, Objectives based on Process Milestones
• PPB Process tied to Process Milestones
• Massive oversight bureaucracy still exists!

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Need for Transformation

• New Mission Requirements
• Emerging Contaminants military-necessary
  constituents targeted by environmental regulatory
  action
• New contaminants (e.g. perchlorate, RDX,
  1,4-Dioxane)
• Lower standards for existing contaminants (e.g.
  TCE, PCE)
• Ranges sustainment, off-base migration, UXOs
• Munitions Response Program
• Radioactive Waste Sites

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Need for Transformation

• Avg Time to Record of Decision 12 years
• Avg Site Investigation Time 6 years
• Decision Documents w/o clear performance
  objectives
• NPL/FFA construct has not provided assumed
  benefits
• Lack of on-the-ground RCRA/CERCLA integration
• Time structure outrun by technology
• Added documents but not faster/better/cheaper
• Efficacy of fence to fence designation

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Air Force Performance- Based Approach to
RODs

• Developed in course of negotiation with EPA
  Region III over Langley RODs
• Key principles
• Actual performance is critical (performance over
  process)
• Notification (keep regulators and public
  informed)
• Access by regulators to site work and documents
  to verify protective remedies
• Accountability for on-the-ground results
• Examples Travis, Langley, Hanscom

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Benchmarking from EPA Leadership and Successes

• One Cleanup Program Initiative
• Triad/Dynamic Site Characterization
• NPL Delistings/Deletions
• Follow-on Reuse

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EPAs One CleanupProgram Initiatives

• One Cleanup Program Draft Action Plan (August
  2002)
• Primary goal Use efficient, effective and
  protective management approaches.
• performance over process the focus should be on
  protective results
• Results-Based Approaches to RCRA Corrective
  Action (Sep 2003)
• 1999 and 2002 Cleanup Reforms
• Land Revitalization Initiative

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TriadDynamic Site Characterization

• Comparison of McGuire Triad Benchmark site to
  all Air Force high relative risk groundwater
  sites
• Averaged RI phase AFRIMS data for all
  groundwater impacted sites with high groundwater
  relative risk
• ???????

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NPL Delistings
Source EPAs Comprehensive Environmental
Response, Compensation and Liability Information
System (CERCLIS)
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Follow-on Reuse

• OShux Golf Course Residential Redevelopment
• Brownfields Adjacent to a Superfund site in Ohio
• Plume from a Dry Cleaning Operation
• Site was Redeveloped for Residential Use
• Site Specific Groundwater Standards were
  Significantly Higher than MCLs

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AF Environmental Program Transformation Vision

• Natural Resources must be Sustained, Restored,
  and Modernized (SRM)
• Metric Capability of NR to support mission
• Business-model (Performance v. Process)
• Cost
• Schedule
• Performance
• Human Eco risk minimization is inherent
• Regulatory Drivers not sufficient for PPB Process
  must value investment to increase NR capability

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AF Environmental Program Transformation
Principles

• Manage to Operational Requirements
• Performance-Based / Business Model Approach
• Assess and Exploit Asset Value / Environmental
  Equity
• Invest to Buy Down Liabilities
• Drive Down Program Costs
• Improve Information and Knowledge Management

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Cleanup ProgramTransformation

• Diagnostic Tools
• AF Management Review
• AF Audits
• OSD Feedback
• Environmental Restoration Tiger Team
• AFRIMS / MIS / RMIS
• Way Forward
• Apply AF Environmental Transformation Principles
• More Effective Central Oversight
• Greater Accountability Tools and Controls

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Managing to Operational Requirements

• Resource Capacity Model (RCM) quantifies
  encroachment due to resource degradation
• Expanding SDWA Executive Agency to work
  proactively on emerging contaminants
• Increased program visibility at Wing CC Level

STATUS Proof of Concept Pilot Test successful
working RCM into BRAC Process
STATUS Task Force formed (0-6 level) Briefing
to AF/CVA and AF ESOH Council on 10 Oct 03
implementation to follow
STATUS Quarterly Cleanup Program briefings begin
Q2FY04
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RCM Example Pilot Test Range
Tested Metrics
Airspace Metric 2 Hours
Surface Land Access Metric 2 Developable Acres
Airspace Metric 1 Compatible Volume
Airspace Metric 3 Distance
Airspace Metric 4 Minimum Size Dimensions
Surface Land Access Metric 1 Compatible Acres
Surface Water Discharge Availability
Ground Water Access (Supply)
RR
RO3
RO3
RO2
RO2
RD1
RR
RD3
- Range has some resource opportunity Approximate
ly 1.4 airspace encroachment using Metric 1 at
range There is no validated method in AF to
size airspace for Metric 4. Required airspace
dimensions generated by 20 FW staff for Basic
Surface Attack (pilot test purposes) Approximat
ely 12.1 off-range surface land encroachment
using Metric 1
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Performance-Based / Business Model Approach

• SAF/IE Focus Area
• ESOHMS applied to Cleanup Program
• Decision Document Record of Decision Guidance

STATUS Cleanup Program Protocol being added to
FY04 ESOHCAMP (self audit) emphasizing PB goals,
CFO liabilities
STATUS Oct 03 SAF/IE Policy (AF Principles)
will set framework for performance-focused
cleanup DDs / RODs (Model procedures provided).
AF/ILE and AFRPA implementing guidelines to
follow.
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Performance-Based / Business Model Approach

• Performance-based Contracting
• Information Management
• Report Card / Annual MAJCOM PMRs

STATUS 10 of FY03 contracts are PB goal is 20
by Q3FY04
AFRIMS vs. RMIS Reconciliation
ECD Dec 03 AFRIMS/MIS vs. RMIS
Reconciliation Feb 04 New
Policies (AOCs, Reopeners, etc.) Sep 03 -
Feb 04 Conversion to web-based system with
site-level data Oct 04
STATUS First Round Oct Dec 03 starts 16 Oct
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Effective Oversight

• Installation / MAJCOM Report Cards and PMR
• Special emphasis areas (AOCs, reopeners, etc.)
• Metrics beyond DPGs (Site closeout, liability,
  CTC, etc.)
• Briefed annually to Air Staff -- Secretariat by
  exception
• Progress Report to Wing Commander quarterly
• Self Audits Adding Cleanup Protocol to ECAMP
• Significant findings tracked quarterly at
  installation, MAJCOM, and Air Staff headquarters
• DSMOA Program Training and Improvements

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Decrease in CTC from FY97 Baseline est.
Expenditures
Remaining CTC Liability
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Expenditures
Expenditures
CTC Increase
CTC Liability (Baseline from FY98)
Remaining CTC Liability
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AF Total ERA CTC
POLICY NEEDED
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Investment

• Training Program / Crossfeed Review
• Process Technology Optimization Clearinghouse
• Standardize / Institutionalize RPO
• IPO Triad
• Benchmarking
• Revitalized Peer Review

STATUS Process / Technology PMR Oct 03 New
policy guidance following PMR and Tiger Team
Report
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Way Forward

• Adhere to Transformation Principles
• Harness ER Tiger Team Recommendations
• Address High Interest Items (AOCs, CTC,
  Re-openers, CFO Liabilities, Information
  Management)
• Outreach
• Congress (ARC Reform)
• AF RPMs
• OSD
• Regulators / Stakeholders
• OMB Comptroller

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Next Steps

• Complete EAGLE LOOK / ERTT Reporting
• More Detailed Discussions with OSD Cleanup Staff
• Vetting new AF polices on high interest items
• Continued work on IM Systems Reconciliation
• Follow-up Brief to PADUSD(IE) Jan/Feb 03

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Cleanup Program Transformation

• LTC Jeff Cornell
• SAF/IEE
• 1 Oct 03

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NPL Site Totalsby Status and Milestone
National Priorities List
NPL Site Totals by Status and Milestoneas of
November 06, 2003
Source http//www.epa.gov/superfund/sites/query/q
ueryhtm/npltotal.htm
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Superfund Sites Returned to Productive Use
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EPA TriadDynamic Site Characterization

• The keystone concept of the Triad approach is the
  identification and management of those unknowns
  (i.e., uncertainties) that could cause excessive
  or intolerable errors in decision-making. An
  example of such a decision error would be to
  declare a site "clean" for redevelopment to
  proceed because contamination that would have
  been treated or removed prior to redevelopment
  was missed during sampling. The Triad minimizes
  the likelihood of mistakes by cost-effectively
  supporting the development of an accurate
  conceptual site model (CSM). Briefly, a CSM is
  any graphical or written representation (or
  "conceptualization") of site contamination
  concerns how it got there, whether or not it is
  migrating or degrading, how variable
  concentrations are across the site, what
  receptors might be exposed, and what
  risk-reduction strategies are most feasible. An
  accurate CSM is a primary work product of the
  Triad approach that is refined and matured over
  the course of an investigation. To develop an
  accurate CSM, the Triad approach incorporates the
  elements of systematic project planning, dynamic
  work plan strategies, and real-time measurement
  technologies into a decision support matrix
  designed to manage uncertainties associated with
  environmental restoration projects.

Source Using the Triad Approach to Streamline
Brownfields Site Assessment and Cleanup.
(EPA 542-B-03-002 June 2003)
http//www.brownfieldstsc.org/Docs/Triadprimer.pdf