EPA DoD Cleanup Program Measures Harmonization Project. States Perspective

Transcription

1 EPA DoD Cleanup Program Measures Harmonization Project States Perspective Marilyn K. Null Colorado Department of Public Health and Environment ASTSWMO Community Involvement Focus Group Denver, Colorado 14 June 2010

2 Presentation Outline Snapshot of Key Federal Facilities Cleanup Partnership Elements Current Measures Reporting Challenges/Confusion Factors Harmonization Project Directives Harmonization Dialogue Findings A More Comprehensive Vision Recommendations

3 Federal Facilities Cleanup Partnership Key Elements The Partners OSD EPA DOI/DOE/Ag/BLM States Tribes The Public The Working Universe 173 Federal Facilities on NPL (final & deleted EPA FFRRO, 10/09) The Regulatory Drivers CERCLA RCRA OPA (under CWA) State Laws The Goals Protective Cleanups Accountability Consistency/Transparency

4 Confusion Factor #1: Numbers EPA 2238 Federal Facilities Sites (173 NPL) 164 Federal Facilities with Interagency Agreements 67 Construction Completes 50% Construction Completes in 3-4 years DoD 4517 Installations (141 NPL, 4,376 non-npl) 136 Installations with signed Federal Facilities Agreements 26,293 Sites at Remedy in Place/Response Complete All Sites at Remedy in Place/Response Complete by 2014

5 Confusion Factor #2: Terminology Site EPA Operable Unit Construction Complete Site Completion/Final Closeout Report Operations & Maintenance DoD Installation Site Remedy in Place Response Complete Long-Term Monitoring

6 Confusion Factor #3: Measures of Success Construction Complete EPA DoD States Remedy in Place/Response Complete SC: Remedy selection/construction Complete TN: Waste properly treated and disposed Acres ready for re-use N/A IL: Acres remediated/available for reuse CA: DTSC Perf Mgt Matrix (land is ready for reuse) Site Completion/Final Closeout Report Response Complete MA: Site closeouts/year in compliance with State standards RI: Closeout or NFA letter TX: Full facility cleanups completed, including NDAI concurrence

7 Current Measures Reporting Challenges Incompatible terminology, scope and endpoints (DoD vs EPA vs State) Different reporting intents / audiences OMB vs Congress vs General Public Incompatible measures databases EPA s CERCLIS (real time data) vs DOD s KBCRS (reporting system) Communicating cleanup endpoint progress & completion timelines OMB, elected officials & general public Limited accountability/transparency

8 Harmonization Project Memos Office of the Under Secretary of Defense. Aligning DoD s Defense Environmental Restoration Program (DERP) Goals and Performance Metrics with the Environmental Protection Agency s Government Performance Results Act (GPRA) Goals. Oct 7, 2009 Memo. Office of the Under Secretary of Defense. Conduct a Crosswalk between DoD Sites and Environmental Protection Agency (EPA) Operable Units (OUs) at National Priorities List (NPL) Installations. May 19, 2010 Memo.

9 Harmonization Dialogue OSD Memos (Oct 2009 and May 2010) EPA-DoD Metrics Workgroup Established EPA / OSD POCs identified Workgroup meetings over last nine months Agency-specific Measures Terminology, Inherent Scope, Purpose Examined e.g., EPA GPRA measures for NPL installations vs DoD cleanup program goals Measures Commonalities /Disconnects Identified Lack of one-to-one relationship between OU (EPA Database) and Sites (DoD database) Crosswalk Development Tasking Underway EPA / DoD RPMs tasked with effort (per May 2010 Memo) State RPM involvement not requested

10 Harmonization Dialogue Findings DoD Vision Crosswalk designed to Validate site-level NPL flags in Knowledge- Based Corporate Reporting System (KBCRS) database DoD information application providing environmental program data to OSD Corresponds to major environmental programs (e.g., MMRP, DERP and Solid Waste) EPA Vision Better align EPA s reporting metrics and measures (GPRA s) with those of the DoD Environmental Programs Develop a target-setting process Harmonize DoD / EPA reporting endpoints Improve EPA s external metric communication and report processes

11 A More Comprehensive Vision. General Public Input State Measures as Reported in Annual State Environmental Agencies. Compliance & Enforcement Annual Reports DoD CROSSWALK State EPA Tribal Requirements DoD Measures as Reported in KBCRS Database (uploaded with data twice / year; no realtime data entered) Elected Official Input EPA Measures As Required by GRPA of 1993 and identified in CERCLIS database (realtime data system)

12 Recommendations Share current workgroup findings with state regulator stakeholders on regular basis e.g., ECOS, ASTSWMO, NGA, NAAG Invite state representatives to the Workgroup Capture state Measures of Success in Crosswalk States Results-Driven versus current Output-Driven reporting Employ National Environmental Performance Partnership Agreement as a tool in Crosswalk Dialogue with DoD, states and other stakeholders Engage General public and other stakeholders in evaluating challenges with current Measure of Success reporting approach & tools

13 Questions & Answers Contacts: Ms. Millie Garcia-Serrano State of Massachusetts DEP Deputy Regional Director, Bureau of Waste Site Cleanup ASTSWMO Fed Facilities Subcommittee Chair Ms. Marilyn K. Null Colorado Dept of Public Health and Environment Community Involvement Specialist ASTSWMO Community Involvement FG