Defense Environmental Restoration Program DERP Planning Meeting

1
Defense Environmental Restoration Program
(DERP)Planning Meeting
November 13, 2003 Office of the
Deputy Assistant Secretary of the Army
(Environment, Safety and Occupational Health)

2
Topics

• Army Environmental Cleanup Strategy
• DASA (ESOH) Top Five
• Current Issues
• Military Munitions Response Program
• Perchlorate Policy
• Land Use Controls

3
Army Environmental Cleanup Strategy

• Directed by ASA(IE)
• Developed by ESOH and OACSIM with participation
  from Program Managers and principals
• Not just DERP
• Includes Overseas, Compliance-Related Cleanup,
  FUDS, and Special (unique funding) installations
• For first time, one Strategy for all program
  areas

4
DASA(ESOH)Top Five

• Top five initiatives identified by each DASA
• Monthly status reporting to the ASA(IE)
• DASA(ESOH)
• Cleanup - Site accomplishment of RIP/RC for FY 04
  05
• Integrated Natural Resource Management Plans
  (INRMP) at 80 of installations by FY 04
• Safety - Reduce accident rates by 50 in two
  years
• Technology - Validate 5 new technologies for
  field testing
• Environmental vulnerability - Achieve Low Risk
  category
• 75 of Army installations by end of 04
• 80 of Army installations by end of 05

5
DASA(ESOH)Top Five (Cont)

• DASA(ESOH) Cleanup Achieve RIP/RC for Active
  and BRAC Programs
• FY 04 207 Active Sites
• 44 BRAC Sites
• FY 05 141 Active Sites
• 27 BRAC Sites
• Installation Status Reporting Requirements
• Semi Annual AEDB-R updates
• Quarterly out of cycle updates for affected
  installations

6
Current Issues

• Military Munitions Response Program
• Perchlorate Policy
• Land Use Controls

7
Current Issues Military Munitions Response Program

• Munitions Response Directive (DoDD 4715.XX)
• Provides response policy for all locations other
  than operational ranges
• Policy guidance expected to be signed by Jan 04
• MMRP Site Prioritization Protocol
• OSD has published in Federal Register
• Public comment period ends November 20, 2003
• OSD working group is developing metrics
• Expect DOD to finalize the metrics for cleanup at
  MMRP sites in FY2004
• Karen Wilson is Army POC

8
Current Issues Perchlorate Policy and Guidance

• ASCIM Guidance of June 27, 2003
• Comply with applicable laws
• Sampling response authorized where
• release is known or suspected
• human exposure pathway exists
• prior approval by HQDA
• requires development of sampling plan

9
Current Issues Perchlorate Policy and Guidance
(Cont)

• OSD PDUSD(IE) Interim Policy of September
  29, 2003 directs sampling and establishment of
  database
• Safe Drinking Water/Unregulated Contaminant
  Monitoring Rule and Clean Water Act
• Environmental Restoration
• Reasonable basis to suspect release
• Human exposure completed pathway is likely
• Reports to DOD by 31 January 2004
• Funding Restoration and Compliance accounts
• Army developing implementing guidance

10
Current Issues Land Use Controls

• Land Use Controls
• DoD has approved Navy/EPA Principles
• Army has endorsed
• Principles
• NPL RODs should be lean LUCs will become part of
  a remedy
• Specific details on LUC management will be placed
  in post-ROD documents
• Remedial Design
• Remedial Action Work Plan

11
Current Issues Land Use Controls (cont)

• Issues Relating to RD Documents
• As primary document, RD should outline LUC
  performance objectives
• Should not list all LUC details
• Augmenting the RD is appropriate
• Compile a comprehensive site-wide LUC management
  plan
• LUC Modification Obtain EPA concurrence
• Existing LUC MOAs and LUCIPs We do not plan to
  revisit
• Field should transition to documentation approach
  outlined above

12
Current Issues Land Use Controls (cont)

• LUC Enforcement
• Prefer cooperative approach to LUC enforcement
• Work with EPA, States and relevant parties to
  prevent LUC violations
• Site Closeout
• May negotiate/finalize Closeout Documents(COD)
• Avoid using the term Remedial Action Closure
  Report (RACR)
• DoD will define Land Use Control
• Will provide to field for incorporation into
  current FFAs without further discussion

13
Current Issues Land Use Controls (cont)

• DoD InterService Review
• No 72-hour review required if follow principles
• Remain silent on issue of whether EPA approves
  5-Year reports
• Installations may outline basic 5-year review
  commitments in their post-ROD documents
• Do not agree to any new post-ROD primary
  documents
• OSD will discuss with EPA in the future

14
Summary

• DASA(ESOH) continues to have keen interest in
  oversight and advocacy for the Armys
  Installation Restoration Program
• Good data and consistent story from year-to-year
  is key to program CREDIBILITY and support for
  continued funding