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Introduction According to the U.S. Department of Defense, more than 700 military installations in the U.S. and its territories have contaminated sites that require investigation and/or cleanup. Because of historical manufacturing, industrial and/or maintenance operations, some military installations may pose a known or potential environmental threat from contaminated soils, groundwater, or surface water. Air Force wastes may also be present in off-base disposal facilities requiring investigation and cleanup. The Air Force identified over 4,400 sites that required some level of investigation/cleanup. Through their aggressive efforts to promptly complete cleanup activities, the Air Force has completed 63 percent of these sites with less than 1700 sites requiring further review or cleanup. Under the Installation Restoration Program, the Air Force is committed to meeting its lawful obligations to eliminate threats to public health and restore natural resources for future use. The purpose of this Fact Sheet is to inform Air Force personnel about the IRP process including federal and DoD requirements, Air Force policy and guidance, sources of technical support, funding, typical Air Force IRP projects, remediation technologies, and community involvement. The Defense Environmental Restoration Program (DERP) The Defense Environmental Restoration Program (DERP) was established by Section 211 of the Superfund Amendments and Reauthorization Act of 1986 (SARA) and is codified in Sections 2701-2707 of Title 10 of the United States Code. It is a single program, funded by several accounts, that provides for the cleanup of hazardous substances associated with past DoD activities and is consistent with the provisions of the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), as amended. Under DERP, the Defense Environmental Restoration Account (DERA) funds the cleanup program at operating installations, as well as at Formerly Used Defense Sites (FUDS). IRP DERA funds can only be used to clean up contamination that occurred prior to 1984. At installations designated for closure under the Base Realignment and Closure (BRAC) process, restoration activities are funded by a BRAC account rather than by DERA. Three program categories have been established under DERP: Installation Restoration Program (IRP), Other Hazardous Waste (OHW), and Building Demolition/Debris Removal (BD/DR). The IRP category includes cleanup activities associated primarily with CERCLA-defined hazardous substances, pollutants, and contaminants; DoD-unique materials; and petroleum, oil, and lubricant (POL) contamination. The OHW category includes the cleanup of ordnance and explosives wastes (OEW) at a FUDS property that poses an imminent danger to the public or the environment. The BD/DR category includes demolition and removal of unsafe buildings at FUDS transferred to governmental units. Applicable Policy and Guidance Department of Defense Instruction (DoDI) 4715.7, Environmental Restoration Program, 22 April 1996. This DoDI assigns responsibilities and establishes policies and procedures for the Defense Environmental Restoration Program (DERP). A companion document that provides additional guidance on program implementation is Management Guidance for the Defense Environmental Restoration Program, Office of the Deputy Under Secretary of Defense (Environmental Security), March 1998. Air Force Instruction (AFI) 32-7001, Environmental Budgeting, 9 May 1994. Chapter 2, "Elements of the Air Force Cleanup Program Budget," describes the Air Force Cleanup Program, funding system, and Installation Restoration Program priorities. AFI 32-7020, Environmental Restoration Program, 19 May 1994. This AFI provides guidance and procedures for executing the Air Force Installation Restoration Program (IRP), also referred to as the Air Force Cleanup Program. The Air Force Installation Restoration Program (IRP) The Air Force Installation Restoration Program (IRP) is designed to identify, investigate, and cleanup contamination associated with past Air Force activities at active AF installations; government-owned, contractor-operated facilities; off-site locations where contamination may have migrated; third party sites; and sites that the AF formerly owned or used. Funding support is provided by the Defense Environmental Restoration Account established under DERP. AFI 32-7001, Environmental Budgeting, 9 May 1994, provides additional information on budgeting and programming related to IRP projects. Air Force Major Commands (MAJCOMs) provide execution guidance and oversee implementation of the cleanup program and related activities at facilities under their jurisdiction. IRP activities are conducted in accordance with the requirements of either the Federal Superfund Cleanup Process or the Resource Conservation and Recovery Act (RCRA) corrective action process, as appropriate. AFI 32-7020 emphasizes that on-site or in-situ corrective actions are preferred over cleanup options that require off-site disposal of contaminants. The primary sources of guidance for restoration projects at the installation level are:
Like the CERCLA cleanup program, the IRP seeks to minimize public health and environmental hazards associated with contaminated sites. As stated in Section 120 of CERCLA, federal facilities, including Air Force installations, are subject to applicable federal and state cleanup laws in the same manner and to the same extent as any non-federal entity. The IRP prescribes investigation and restoration activities conducted through a phased approach. Each phase systematically studies the effects of past environmental activities. At any point in the process, the governing agencies may determine that no further action is required and screen the site out of the process. Alternatively, a site posing an immediate threat to human health or the environment may require the federal government to undertake emergency response actions. The primary phases of the CERCLA remedial action process, which generally apply to installation restoration projects, are: Site Discovery - occurs through various means, including reports of releases to the Environmental Protection Agency (EPA), investigations by government authorities, property assessments/surveys, or incidental discoveries. Site Assessment - this phase consists of several steps: 1) a preliminary assessment is a "desktop" review of available information; 2) the site inspection is a more detailed investigation, usually involving sampling and analysis of environmental media; 3) scoring the site involves applying the EPA hazard ranking model to assess the site's relative risk. The site may require listing on the EPA National Priority List (NPL), depending on the score; and 4) removal actions may be conducted at any time during the remedial action process to mitigate immediate environmental threats. Remedial Investigation/Feasibility Study (RI/FS) - this phase fully characterizes the nature and extent of contamination at the site in sufficient detail to make informed risk management decisions, select the appropriate remedial option, develop a proposed remedial plan, and execute the Record of Decision (ROD). Remedial Design/Remedial Action (RD/RA) - the site remedy is designed, pilot tested, constructed, and implemented during this phase. Long term operation, maintenance, and monitoring of the remedial action are included in this phase. Some Air Force sites of contamination are subject to the RCRA corrective action process rather than CERCLA. The types of sites requiring RCRA corrective actions are primarily hazardous waste treatment, storage, or disposal (TSD) facilities permitted under RCRA. Part of the RCRA permit conditions require corrective actions when a release of a hazardous waste occurs from a RCRA permitted TSD facility or when the TSD facility is being closed. The regulations specifying that corrective actions must be taken at these types of sites are found at Title 40 CFR Subpart S - Corrective Action for Solid Waste Management Units. The actual cleanup process at these types of sites, however, will be in accordance with the CERCLA cleanup process discussed above. Air Force IRP Support Installations do not tackle the IRP process alone. Headquarters Air Force Center for Environmental Excellence's Environmental Restoration Directorate (HQ AFCEE/ER) provides a full range of environmental remediation capabilities to support installation restoration manager requirements. These capabilities include study, design, and remedial action contracts; world class remediation technology and the support needed to implement it; and technical oversight for environmental cleanup/restoration activities on Air Force installations. The Environmental Restoration Directorate is divided into four divisions: Environmental Restoration (ERD), Base Closure Restoration (ERB), Restoration Consultant Operations (ERC), and Technology Transfer (ERT). General information about these divisions can be found by visiting the Environmental Restoration Directorate's WWW site at http://www.afcee.brooks.af.mil/ER/erhome.asp. A list of downloadable ER Technical Products is available at http://www.afcee.brooks.af.mil/ER/erproducts.htm. ERD conducts restoration activities on currently operating Air Force installations worldwide. The Division is subdivided into four customer support groups. One group serves installations belonging to Space Command (AFSPC), Air Force Reserve Command (AFRC), Air Force Materiel Command (AFMC), and Air Education and Training Command (AETC). Another group serves installations belonging to Air Mobility Command (AMC), Air Combat Command (ACC), Air National Guard (ANG), and third party sites. A third group serves installations belonging to Pacific Air Forces (PACAF) and U.S. Air Forces Europe (USAFE). The fourth group manages AFCEE-owned programs at the Massachusetts Military Reservation and the Naval Air Station-Ft. Worth Joint Reserve Base. For more information on ERD and its capabilities, contact Mr. Gerald Saulnier, HQ AFCEE/ERD, DSN 240-5201, gerald.saulnier@hqafcee.brooks.af.mil. Funding the IRP The Defense Environmental Restoration Program (DERP) is funded by the Defense Environmental Restoration Account (DERA), established by 10 U.S.C. 2703 as part of the Superfund Amendments and Reauthorization Act of 1986. The fund is no longer centrally managed and military components are now funded directly. Funding for the Air Force depends on the priority of programmed requirements, site cleanup procedural complexities, and success/failure history in obligating and disbursing previously distributed funds. Headquarters United States Air Force, Installations and Logistics, Civil Engineer Directorate (HQ USAF/ILE), determines the distribution of DERA funds to MAJCOMs based on the relative priority of the total requirements. Also considered in making DERA allocation decisions is the demonstrated ability of the organization to both obligate and expend the funds in a timely manner. DERA funds are intended for all work directly related to the IRP effort at an installation. The funds can also be used for remedial technology demonstrations and development, the first 10 years of operations and maintenance following construction of a remedial project, corrective actions at RCRA-permitted units or underground storage tanks, and immediate removal actions. Again, DERA funds can only be used to address contamination that occurred prior to 1984. DERA funds cannot be used to maintain RCRA-permitted units or conduct RCRA Facility Assessments (RFAs). They cannot be used to support an ongoing military construction (MILCON) project when contamination is found during construction since this situation is considered part of the MILCON project cost. DERA funds should also not be used to pay a judgement in a Third Party Site (TPS) matter where the Air Force is represented by the Department of Justice (DOJ). Other prohibited uses include: fines and penalties, managing or replacing PCB transformers, underground storage tank testing or repair, spills covered by Spill Prevention Control and Countermeasures (SPCC) plans, asbestos surveys, overseas restoration, and various other items. DERA can be used to fund U.S. Air Force government civilian employees, who typically work at the base, command, agency, center and/or Air Staff level. Positions may be full-time or partially funded on a reimbursable basis if the position supports DERP activities. Contractor support must be identified in the management line item. DERA funding may also be used for: funding benefit packages, awards, relocation allowances, moving expenses and real estate fees (all of these items must be identified separately as backup justification to the manpower request), and backfilling of military positions assigned DERP related activities with civilian personnel. The dynamic nature of the DERP may result in significant changes in costs and requirements throughout the fiscal year, and the status of DERA funded projects should be communicated in the DERA Status Report (DSR). Each organization receiving DERA funding should complete a DSR monthly. More details on DERA funding and management are found in AFI 32-7001, "Environmental Budgeting." Typical Air Force IRP Projects Although the Air Force IRP addresses many types of sites where contaminants have been released to the environment, three major types of sites are most common at Air Force installations. Between 50% and 60% of all contaminated sites addressed by the Air Force IRP are affected by releases of petroleum products (e.g., fuels, oils, gasoline, etc.) The remaining sites are affected largely by releases of industrial chemicals from a facility and by landfill releases. Petroleum products are typically released to the environment when storage tanks and/or pipelines leak. Fuels are typically stored near aircraft hangars and maintenance areas. Petroleum products may also form a significant portion of runoff waters from flightlines, runways, and other paved areas. The contaminants of concern in fuels are a wide range of hydrocarbons, which are potentially harmful to the environment and exposed populations. Of particular concern are the aromatic hydrocarbons such as naphthalene, benzene, toluene, ethylbenzene, and xylene isomers. Fuel releases may occur in sudden large spills; however, they more commonly involve slow leakage over a period of years. Since fuel spills are so common, the Air Force has placed significant emphasis on the development of efficient and cost-effective technologies for remediating these sites. Additional information about fuels and their effect on the environment can be found in the upcoming PRO-ACT Fact Sheet "Petroleum Fuels: Basic Composition and Properties," to be published in early 1999. Industrial solvents and degreasers, particularly chlorinated volatile organic compounds (VOCs), are extremely common environmental contaminants both at Air Force installations and in civilian industrial and commercial areas. Common examples of these chemicals are trichloroethylene (TCE), 1,1,1-trichloroethane (TCA), perchloroethylene (PCE), and methylene chloride. All of these substances have potentially serious health effects at low concentrations. Although pollution prevention initiatives have greatly curtailed the use of these chemicals by Air Force activities, they have been widely used in the past. Leakage from storage systems/areas, disposal of spent solvents, and releases through pipelines and sewers are all common means by which these substances have entered the environment. Once released, the density and poor solubility of these substances make them particularly difficult to intercept and remove from the environment. Air Force installation landfills, like commercial landfills that accepted Air Force wastes, typically incorporated standard containment technologies in existence at the time they were constructed. As a result, older landfills have often failed to contain the contaminants placed in them. Rainwater infiltrating through landfill wastes dissolves contaminants, creating a potentially hazardous leachate that may affect groundwater or nearby surface water. Landfills commonly contain many types of wastes and contaminants and remedial efforts must be designed to address this variety. Overview of Remediation Technologies In conjunction with other federal agencies and the rest of the regulated community, the Air Force has gained extensive experience in the design, implementation, and evaluation of remedial technologies. A vast array of technical information is available through the Internet and printed sources on the choosing and adapting of remediation technologies to address contamination concerns at a given site. Although new and innovative technologies are still being developed, a generally "standardized" set of effective and affordable technologies is used at sites with common contamination problems. In recognition of this state of affairs, the U.S. EPA is developing a set of presumptive remedies for common contaminants. A presumptive remedy is a technology that EPA believes to generally be the most appropriate remedy for a specific type of site. The principle of presumptive remedies is intended to focus and speed up the Feasibility Study process and lead to an expedited remedy approval. EPA has published (see Document References section below) a number of presumptive remedies for landfills, VOCs in soils, wood treatment sites, and others. It should be noted; however, that presumptive remedies are not required and may actually be inappropriate where special conditions exist. The Air Force has also developed a set of recommendations and guidelines for dealing with the types of sites most commonly encountered at Air Force installations. Current Air Force guidance on preferred remedies and technologies is available through AFCEE's Technology Transfer Division, (HQ AFCEE/ERT). The Technology Transfer Division evaluates, tests, and applies new, emerging, and unique environmental restoration technologies. A number of reference documents are available for downloading or ordering from the "ERT Toolbox" WWW site at http://www.afcee.brooks.af.mil/ER/toolbox.htm. For fuel spill sites, ERT has found that a particular combination of technologies will quickly and cost-effectively remediate the site with an excellent success rate. The technologies generally recommended include bioventing for fuel-contaminated soils, a combination of vacuum-enhanced free product recovery and bioremediation for phase-separated petroleum product, and natural attenuation for petroleum-contaminated groundwater. In each case, ERT has found that using and supplementing natural processes occurring in the environment greatly enhances the success of the remedial effort. Bioventing is a technology that forces air into the soil to accomplish two goals: 1) the flushing of volatilized fuels from the subsurface soil; and 2) the introduction of air to the oxygen-limited (anaerobic) soil, thereby promoting the growth of naturally occurring microorganisms that break down petroleum compounds. Bioremediation is actually a general term for a suite of technologies that use microorganisms to convert organic contaminants into harmless carbon dioxide, water, and other metabolized by-products. In a very few cases nutrients are injected into the environmental media or engineered bacteria are added; however, in nearly all cases, aerobic (oxygen-rich) conditions are needed to achieve satisfactory results. Many of the most intractable sites are contaminated with phase-separated chlorinated solvents, which are sometimes classified as dense, nonaqueous phase liquids (DNAPLs). These dense substances tend to migrate downward through soil, groundwater, and bedrock, thus contaminating aquifers to significant depths. Their low solubility makes them resistant to dilution effects, and difficult to remove from the subsurface. For sites with residual soil contamination, soil vapor extraction is the presumptive remedy and has been the most frequent choice. Traditionally, groundwater contamination has been addressed with pump-and-treat technology. This technology requires a substantial initial investment, has a high operation and maintenance cost, and has often failed to significantly reduce the quantity of DNAPLs present in the subsurface. In recognition of the extreme difficulty of actively remediating DNAPLs in groundwater, natural attenuation is increasingly becoming the remedy of choice. Natural attenuation is the name given to natural subsurface processes such as dilution, volatilization, biodegradation, adsorption, and chemical reactions with subsurface materials that act to reduce the concentrations of contaminants in subsurface soils and groundwater. Declining concentrations of contaminants are commonly observed at sites prior to initiating remedial actions. In some cases, it appears that natural attenuation may be the most cost-effective way to reduce contaminant concentrations below regulatory or risk-based levels. However, selecting a natural attenuation remedy is not the same as a "no action" alternative. Wherever natural attenuation is applied, long term monitoring must be conducted to ensure that the process is effective and that cleanup objectives are being met. Natural attenuation is a good remedy where more active cleanup measures will not materially affect the rate of remediation or where no technically practicable methods are available. It is not, however, a good choice when contaminant plumes continue to migrate and approach downgradient receptors. In most cases, contaminated landfill sites are addressed with capping or enhanced capping technology. Landfill caps are constructed of impermeable materials designed to prevent the infiltration of rainwater and the subsequent formation of landfill leachate. Approximately 70 percent of landfill remediation projects include a cap as the presumptive remedy. However, as evidence mounts of the poor performance of many traditional caps, alternative remedies such as evapotranspiration covers are now being considered. Contaminated groundwater migrating from landfills may be addressed by a variety of traditional techniques including pump-and-treat technology or groundwater barriers. Natural attenuation is also increasingly being proposed where appropriate. Community Involvement U.S. EPA has devoted a major effort toward informing and enlisting the participation of the public in the cleanup process. In addition to conducting public meetings and establishing repositories for site-related documents, EPA encourages the creation of Community Action Groups (CAG). A CAG is made up of interested parties from the local community who want to become informed about the extent of contamination at a site and the risks to the community and the environment, and who wish to participate in an informed manner in the decision making process. DoD, and the Air Force in particular, have adopted similar community involvement ideas. Early in the IRP process, the Air Force develops a comprehensive community relations plan for the installation. An information repository is established for public access to site information, investigation results, technical data, and decision documents. In addition, as established by the Federal Facilities Environmental Restoration Dialogue Committee, Restoration Advisory Boards (RAB) are set up. The RAB is funded by DoD and is similar to the CAG in many respects in that it serves as a forum for informed citizen participation in the IRP process. The Air Force is currently a participant in more that 100 RABs nationwide. RABs benefit both the community and the installation. They are a proactive forum for public participation that serves to foster a good relationship between the installation and the public. In contrast to one-sided public meetings, the RAB helps prevent the impression that the installation is making decisions without input from the community, and thus improves installation credibility. The RAB can serve to prevent the spread of false rumors and scare stories concerning the nature of sites in the IRP process. A good working relationship with the RABs enables the installation to address future IRP sites with greater efficiency. Status of AF IRP Sites Over 4,000 sites of environmental contamination have been identified at Air Force facilities in the U.S. and its territories. Of this total, over 1,900 sites have been formally closed or have had all response actions completed in preparation for final closeout. Almost 2,000 additional areas of concern (AOCs) require assessment and, if validated, may require future funding for study/cleanup. The Air Force estimates that 20 percent of AOCs will become validated IRP sites. Air Force cleanup funding is projected to stabilize at approximately $300 million per year through fiscal year 2003. The cost of cleanup actions is expected to continue to account for 90% of yearly funding with special studies and administrative costs accounting for the remaining 10%. For More Information... EPA's Federal Facilities Restoration and Reuse Office (FFRRO) works with DoD, the Department of Energy (DOE), and other federal entities to help them develop creative, cost-effective solutions to their environmental problems. FFRRO's overall mission is to facilitate faster, more effective, and less costly cleanup and reuse of federal facilities. Visit the FFRRO WWW site at http://www.epa.gov/swerffrr. The site offers access to a wide variety of useful technical and guidance documents focused on the restoration of federal facilities. The Defense Environmental Network and Information Exchange (DENIX) provides access to a variety of DoD and component policy, guidance, and technical documents pertinent to installation restoration and environmental cleanup. Visit the DENIX WWW site at http://www.denix.osd.mil/. The Air Force Institute of Technology, Environmental Education Center (AFIT/EEC), is responsible for ensuring that all USAF environmental personnel have an opportunity to attend technical and management courses as appropriate to perform their jobs. AFIT/EEC offers courses related to the IRP, as well as other environmental courses. For information on obtaining EEC support to attend a course, call DSN 785-5654, ext. 3514 or e-mail cev-eec@afit.af.mil. Visit the AFIT WWW site at http://cess.afit.af.mil. Document References
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