A Trip Down Memory Lane: Federal Facilities Site Assessment Milestones

Transcription

1 2007 National Site Assessment Symposium Denver, Colorado June 19-21, 2007 A Trip Down Memory Lane: Federal Facilities Site Assessment Milestones Presented by Monica Iindeman SA Manager, SA Data Manager, Region 10 Federal Agency Hazardous Waste Compliance Docket Coordinator Environmental Cleanup Office U.S. EPA Region 10

2 1976 Pre-CERCLA Era United States Congress The Resource Conservation and Recovery Act (RCRA) 1976

3 1976 Pre-CERCLA Era continued RCRA of 1976 (42 USC 6901 et seq) ) (40 CFR Parts ) 282) Subtitle C (RCRA ): 3023): Establishes the national hazardous waste management program Replaces Solid Waste Disposal Act and Resource Recovery Subtitle C (42 USC 6937)(RCRA 3016): Inventory of Federal Agency Hazardous Waste Facilities Office of Solid Waste has responsibility for conducting the Inventory

4 1980 CERCLA United States Congress The Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (Superfund) December 11, 1980

5 1980 CERCLA continued CERCLA of 1980 (PL )(42 USC 9601 et seq.), as amended Sec Reportable Quantities Sec Notices, Penalties: Releases Sec Response Authority: Studies & Investigations Sec National Contingency Plan: Methods for discovering & investigating facilities at which hazardous substances have been disposed of or otherwise come to be located Sec Authority to delegate,, issue Regulations Sec Schedules: Assessment, Evaluation & Listing of Facilities on the NPL

6 1986/1988 SARA & The Early Years United States Congress The Superfund Amendments and Reauthorization Act of 1986 December 1986

7 1986/1988 SARA & The Early Years continued SARA of 1986 (PL ), Effective as of 01/01/1987 Section Federal Facilities Section 120(c) - Federal Agency Hazardous Waste Compliance Docket Shall contain all information submitted by Departments, Agencies, or Instrumentalities of the U.S. to EPA under: RCRA 3005, RCRA 3010, RCRA 3016, CERCLA 103 Shall be available for Public inspection; Shall establish program to provide information to Public Section 120(d) - Assessment and Evaluation Executive Order (52 FR 2923) & Delegation of Authory to conduct PAs and SIs to Federal agencies; EPA retains Authority For FF Site Assessment ent Report Reviews, as of 01/23/1987; OSWER/FFEO Federal Agency Haz Was Compliance Docket established as of 01/01/1988; DOD relinquishes FF sites: FUDS as Federal & Non-Federal properties

8 1986/1988 SARA & The Early Years continued FF Sites (examples): Vacation Year-Round in the Virgin Islands? By Invitation of Helen Shannon, Region 2 Region 2 - US DOI Former Fort Segarra,, Water Chemical Warfare Site, Virgin Islands

9 1986/1988 SARA & The Early Years continued Spring Time in the Carolinas? By Invitation of Gena Townsend, Region 4 Region 4 - US Marine Corps Camp Lejeune training NPL site 22 OUs, each with Sites; Groundwater Contamination (TCE, Solvents, and everything else)

10 1986/1988 SARA & The Early Years continued Horseback Riding in North Dakota Cattle Country? By Invitation of Stan Zawistowski,, Region 8 Region 8 Missile Defense Agency - Stanley R. Mickelsen Anti Ballistic Missile Complex, Concrete, ND

11 1986/1988 SARA & The Early Years Backpacking in the Rockies? By Invitation of Jerry Cross, Region 8 continued EPA, BLM, Colorado Div. of Reclamation Mine Safety, and Colorado Dept of Public Health & Environment Golden Wonder Mine, Headwater Drainage of Deadman Gulch

12 1986/1988 SARA & The Early Years continued Going out West? Invitation by Philip Armstrong and Steve Simanonok,, Region 9 Region 9 - USDOE Nevada Test Site, OUs,, Areas too numerous to mention

13 1986/1988 SARA & The Early Years continued Hiking in the Pacific Northwest? By Invitation of Monica Lindeman and Ken Marcy, Region 10 Region 10 US DOE Hanford Nuclear Weapons site, 5 Major Areas, 22 OUs

14 1986/1988 SARA & The Early Years continued Sunbathing in the Arctic? By Invitation of Monica Lindeman and Ken Marcy, Region 10 Region 10 - USAF DEW Line Site Liz-2 2 Point Lay Radar Installation, Kaseguluk Lagoon, Kokolink River, Point Lay, North Slope, AK

15 1986/1988 SARA & The Early Years continued Contaminants on FF Sites (examples): What has seen better days? PCBs, DDT, TCE, Phthalates Fumes to avoid? Travelled to Seveso,, Italy on June 10, 1976? TCDD Agathy Cristie Plots? Arsenic Not for Car Buffs? Mercury For a new high in Lead Fashions? Strontium 90, Uranium, Plutonium Not for now? Chemical Warfare components Not for the Faint of Heart? Munitions/Ordnance Anyone for Dust Control? Mixed Oil Product enhanced by selected above Plus - you name it, it s there

16 1990/ Progress Can we have progress? Yes, we can: National Oil and Hazardous Substances Pollution Contingency Plan,, 40 US Code of Regulations (CFR), Part 300 Final Rule (55 FR 8666, March 8, 1990), Latest revision 1994 Guidelines and procedures for responding to releases or potential l release of hazardous substances, pollutants, or contaminants. Hazard Ranking System (HRS) (40 CFR Part 300, Final Rule, Appendix A, Federal Register, Vol. 55, No.241, December 14, 1990) Method for evaluation of potential threats to human health and the t environment from Hazardous Waste Sites Discovery of Releases (40 CFR Part ) Discovery or notification and outline of what constitutes discovery of a hazardous substance release. Identifies 7 discovery ways, including ing Other sources. No, we can t: Subpart K Federal Facilities [Reserved] (40 CFR 300, Introduction)

17 1990/1995 Mixed Progress Have we complied with the Law? A Wake-Up Call to Federal Facilities? Judicial Order, January 15, 1991,, case entitled Conservation Law Foundation of New England v. EPA, C.A. No Y, D. Mass. EPA was ordered to conduct a preliminary assessment of certain facilities by July 15, 1992, and to complete evaluations of each facility for the National Priorities List by July 15, Are we making FF Site Assessment Progress or not?

18 1990/1995 Mixed Progress No specific FF Remedial Site Assessment/Review Guidance What PAs?? What SIs? Removal Reports, EE/CAs CAs,, Risk Assessments, - and surprise, some PAs, SIs When for Review? 2 years? 5 years? 10 years? Still waiting? FF Docket Move from OSWER/FFRRO to OECA/FFEO EPA s Regional Federal Facility Site Assessment now has 2 HQ Homes? OSWER/OSRTI/STSIB for FF Site Assessment OECA/FFEO for the FF Docket

19 1997/2005 Accomodation and New Challenges 1997 DoD Amendment Change of Submission Date for FF PAs to EPA Change from 18 Months to a reasonable schedule EPA Mixed Ownership Mine/Mill sites Policy & site- by-site basis of determination for exclusion from FF Docket listing as of 06/24/2003 FF Docket move from OECA/FFEO back to OSWER/FFRRO as of 10/18/2005 Welcome Back! EPA s Regional Federal Facility Site Assessment now has 1 HQ Home? OSWER/OSRTI/ARD/STSIB for FF Site Assessment OSWER/FFRRO for the FF Docket

20 1997/2005 Accomodation and New Challenges EPA FF SA Summary Guides, Washington, DC, 2005 OECA/FFEO, OSWER/OSRTI, OSWER/FFRRO OGC, 10 Regional FF Docket Coordinators, and a Cast of Thousands FEDERAL FACILITIES REMEDIAL PRELIMINARY ASSESSMENT SUMMARY GUIDE JULY 21, 2005 FEDERAL FACILITIES REMEDIAL SITE INSPECTION SUMMARY GUIDE July 21, 2005

21 1997/2007 Accomodation and New Challenges MMRP Congress mandated DoD Regulation involves EPA as a Regulatory Agency for FF Docket listing of FF MMRP sites not previously listed; Review of MMRP reports for FF & Non-FF MMRP sites Contaminants on FF sites - Additions (examples): Perchlorate; UXOs; ; Ordinance & Constituents; EPA Docket Reference Manual, Washington, DC, 2007 OSWER/FFRRO OGC, 10 Regional FF Docket Coordinators Docket Reference Manual Federal Agency Hazardous Waste Compliance Docket Interim Final March 9, 2007

22 1997/2007 Accomodation and New Challenges FF MMRP and WWII Battlefield sites (examples): Come Scuba Diving off Puerto Rico s NW Refuge Desecheo Island? By Invitation of Helen Shannon, Region 2 Region 2 MMRP site: USDOI FWS Desecheo National Wildlife Refuge: Desecheo Island Former Navy & Air Force Bombing & Gunnery Range, 13 mi W of Puerto Rico (incl. Upland Bombing Range, Underwater Demolition Bombing Target, lb Bomb, lb GP Bombs found on beaches, etc.)

23 1997/2007 Accomodation and New Challenges Travel to exotic Guam s Beaches? By Invitation of Kathleen Shimmin,, Region 9 Region 9 MMRP & WWII Battlefield site: US DOI NPS War in the Pacific National Historic Park: Asan Beach, Guam (Off-shore, Beaches & Upland Munitions/Ordnance)

24 1997/2007 Accomodation and New Challenges Come Bird Watching in the Aleutians? Skiing the Pacific Ring of Fire? By Invitation of Monica Lindeman,, Ken Marcy and Harry Craig, Region 10 Region 10 MMRP & WWII Battlefield site: USDOI FWS Maritime National Wildlife Refuge: Kiska Island (Underwater, Beaches, Upland Munitions/Ordnance)

25 2007 and Beyond Federal Facilities Site Assessment now and in the Future: DoD sites: MMRP sites Battlefield sites Off-Base Found Munitions/Ordnance/Missiles etc. Federal Facilities Formerly Used Defense (FF FUD) sites Federal Facilities Perchlorate sites Other Federal Facilities sites: Other Federal Land Management sites: Unpatented Abandoned Mine/Mill sites; Mines, Mill, or mine waste disposal areas on FLMA lands under Federal permit or lease

26 No End in Sight