United States General Accounting Office

GAO Report to the Chairman, Committee on

Governmental Affairs, U.S. Senate

November 1994 ENVIRONMENTAL

CLEANUP

Case Studies of Six

High Priority DOD

Installations

GAO/NSIAD-95-8

GAO United States

General Accounting Office

Washington, D.C. 20548

National Security and

International Affairs Division

B-256676.2 

November 18, 1994

The Honorable John Glenn

Chairman, Committee on

 Governmental Affairs

United States Senate

Dear Mr. Chairman:

This is a supplement to our report entitled Environmental Cleanup: Too

Many High Priority Sites Impede DOD’s Program (GAO/NSIAD-94-133, Apr. 21,

1994). It provides six installation case studies addressing issues outlined in

your request and discussed in our report. These issues include the status

of the restoration program, the cost of cleanup to date and projected costs,

the cleanup options considered, the option selected, expected completion,

and the applicable cleanup standards. The case studies also provide

installation specific information on reasons an installation was listed on

the National Priorities List (NPL), the regulatory process, cooperation

between the installation and the regulatory agencies, staffing at the

installations and the regulatory agencies, and the process for funding the

cleanup. (See apps. I through VI.)

In our April 1994 report, we stated that despite spending a reported

$3.76 billion as of September 1993, the Department of Defense’s (DOD)

environmental cleanup program for high priority installations has

proceeded slowly over the past 10 years, with relatively few hazardous

waste sites being cleaned up. Most of the time and money have been spent

studying the problem. The cost estimate for cleaning up high priority

installations is $18.2 billion.1

 However, this cost estimate is based on

preliminary information and is likely to increase.

The Environmental Protection Agency’s (EPA) system for identifying high

priority sites has led to a large number of individual sites on installations

with that designation. In addition, some sites not designated as high

priority are more contaminated than high priority sites and pose a greater

risk to human health and the environment than those on the NPL, according

to DOD officials. EPA usually scores only the four to six worst sites on an

installation in determining whether an installation, which may have

hundreds of sites, should be placed on the NPL. Many of these sites may

have only minor contamination, but DOD program managers must apply the

1

The estimated cost to clean up DOD installations is based on data provided by the installations,

commands, and services as of September 30, 1993.

Page 1 GAO/NSIAD-95-8 Environmental Cleanup
B-256676.2 

entire Comprehensive Environmental Response, Compensation and

Liability Act (CERCLA) process (see app. VII) to all the sites on an NPL

installation, including those with only minor contamination.

DOD will not be able to efficiently institute cleanup efforts until it and EPA

evaluate the large number of sites currently on the NPL or the closure list

and determine which should be designated as high priority. Even a

relatively few high priority sites could strain resources and force difficult

choices. The Deputy Under Secretary of Defense (Environmental Security)

has proposed a new approach to solving cleanup problems, which includes

developing cooperative rather than adversarial relationships with

regulatory agencies, setting priorities based on risk, and trying to

accelerate cleanups.

We also identified other key factors that have affected DOD’s cleanup of

high priority installations in a timely and cost-effective manner.

• The complex and time-consuming CERCLA study and cleanup process.

• Prolonged study of hazardous waste sites rather than cleanup.

• Disagreements with regulatory agencies over the extent of cleanup

required.

• Addressing issues during the CERCLA process, such as liability, that

generally do not pertain to governmental installations.

• Scarce resources including limited technology and expertise.

Appendix VIII discusses our methodology and scope, including a list of the

installations and organizations visited. We conducted our review from

September 1992 to October 1994 in accordance with generally accepted

government auditing standards. As requested, we did not obtain formal

agency comments on a draft of this report. However, we provided officials

at each of the six installations an opportunity to provide comments and

have included their comments where appropriate. We also discussed our

April 1994 overall report (NSIAD-94-133) with DOD representatives and

included their comments where appropriate.

Unless you publicly announce its contents earlier, we plan no further

distribution of this report until 30 days after its issue date. At that time, we

will send copies to congressional committees; the Secretaries of Defense,

the Army, the Navy, and the Air Force; the Administrator, Environmental

Protection Agency; and the Director, Office of Management and Budget.

We will also make copies available to others upon request.

Page 2 GAO/NSIAD-95-8 Environmental Cleanup
B-256676.2 

If you or your staff have any questions concerning this report, please call

me on (202) 512-8412. Major contributors to this supplement are listed in

appendix IX.

Sincerely yours,

Donna Heivilin

Director, Defense Management

 and NASA Issues

Page 3 GAO/NSIAD-95-8 Environmental Cleanup
Contents

Letter 1

Appendix I 

Aberdeen Proving

Grounds Case Study

8

Listing on National Priorities List 8

Status of the Installation Restoration Program 9

Cost 10

Options Considered 11

Options Selected 12

Expected Completion 13

Regulatory Process 13

DOD/Regulatory Agency Cooperation 14

Cleanup Standards 14

Staffing 14

Regulatory Agency Staffing 14

Funding 15

Appendix II 

Fort Wainwright Case

Study

17

Listing on the NPL 17

Status of the IRP 17

Cost 19

Options Considered 20

Option Selected 20

Expected Completion 21

Regulatory Process 21

DOD/Regulatory Agency Cooperation 21

Cleanup Standards 23

Staffing 23

Regulatory Agency Staffing 24

Funding 25

Appendix III 

McChord Air Force

Base Case Study

26

Listing on the NPL 26

Status of the IRP 27

Cost 28

Options Considered 28

Option Selected 29

Expected Completion 29

Regulatory Process 29

DOD/Regulatory Agency Cooperation 31

Cleanup Standards 31

Page 4 GAO/NSIAD-95-8 Environmental Cleanup
Contents

Staffing 32

Regulatory Agency Staffing 32

Funding 32

Appendix IV 

McClellan Air Force

Base Case Study

33

Listing on the NPL 33

Status of the IRP 33

Cost 35

Options Considered 36

Option Selected 36

Expected Completion 36

Regulatory Process 36

DOD/Regulatory Agency Cooperation 37

Cleanup Standards 37

Staffing 38

Regulatory Agency Staffing 38

Funding 39

Appendix V 

Pearl Harbor Naval

Complex Case Study

40

Listing on the NPL 40

Status of the IRP 40

Cost 41

Options Considered 42

Option Selected 42

Expected Completion 42

Regulatory Process 42

DOD/Regulatory Agency Cooperation 42

Cleanup Standards 43

Staffing 43

Regulatory Agency Staffing 44

Funding 44

Appendix VI 

Schofield Barracks

Case Study

46

Listing on the NPL 46

Status of the IRP 46

Cost 47

Options Considered 48

Option Selected 49

Expected Completion 50

Regulatory Process 50

Page 5 GAO/NSIAD-95-8 Environmental Cleanup
Contents

DOD/Regulatory Agency Cooperation 51

Cleanup Standards 51

Staffing 52

Regulatory Agency Staffing 53

Funding 53

Appendix VII 

CERCLA Process

56

Preliminary Assessment 56

Site Inspection 56

Remedial Investigation 56

Feasibility Study 56

Remedial Design 56

Remedial Action 56

Interim Remedial Action 56

Remedy in Place and Functioning as Intended 56

Appendix VIII 

Scope and

Methodology

57

Appendix IX 

Major Contributors to

This Report

59

Tables Table I.1: Status of Sites at Aberdeen Proving Grounds 10

Table I.2: Options Considered for the Old “O” Field Site Cleanup 11

Table I.3: Options Considered for the Michaelsville Landfill

Cleanup

12

Table II.1: Status of Sites at Fort Wainwright 18

Table III.1: Status of Sites at McChord Air Force Base 27

Table IV.1: Status of Sites at McClellan Air Force Base 34

Table V.1: Status of Sites at Pearl Harbor Naval Complex 41

Table VI.1: Status of Sites at Schofield Barracks 47

Table VI.2: Grade Structure for Environmental Office Managers 53

Table VI.3: Requested, Received, and Planned DERA Funding for

Schofield Barracks

54

Page 6 GAO/NSIAD-95-8 Environmental Cleanup
Contents

Abbreviations

CERCLA Comprehensive Environmental Response, Compensation

and Liability Act

DERA Defense Environmental Restoration Account

DOD Department of Defense

EPA Environmental Protection Agency

IRP Installation Restoration Program

NPL National Priorities List

PCB polychlorinated biphenyls

ppb parts per billion

TCE Trichloroethylene

Page 7 GAO/NSIAD-95-8 Environmental Cleanup
Appendix I 

Aberdeen Proving Grounds Case Study

Aberdeen Proving Grounds, Maryland, is an Army Test and Evaluation

Command installation within the Army Materiel Command. The

installation, situated on 79,000 acres, over half of which is covered by

water, is split between Aberdeen (north end) and Edgewood (south end)

areas, separated by a river with both areas consisting primarily of

peninsulas and islands in the upper Chesapeake Bay in Harford and

Baltimore counties.

Aberdeen Proving Ground’s mission includes development and testing of

equipment such as weapon systems, rockets and missile systems,

munitions, and components. The Army’s Chemical Biological and Defense

Command, a tenant at the installation, is involved in research of materials

such as blister agents, tear gas, and nerve agents. About 85 percent of the

installation’s area is used for vehicular testing, ballistic testing, and

artillery and other weapon testing impact areas.

Throughout its history, the Edgewood area has been the primary U.S.

chemical warfare research and development center. During World Wars I

and II, the Edgewood area manufactured chemical agents. Past mission

activities and disposal practices have resulted in contamination, including

volatile organic compounds, arsenic, phosphates, napalm, unexploded

ordnance, nitrates, chemical agents, and other contaminants typically

found on military installations.

Listing on National

Priorities List

The two National Priorities List (NPL) sites on the installation are the entire

Edgewood area, which includes 78 individual sites,1

 and the Michaelsville

Landfill site in the Aberdeen area. Because all of the preliminary

assessment studies had not been completed, only one site on the Aberdeen

area was listed as an NPL site.

The Edgewood area was placed on the NPL on February 1, 1990. The site

has a composite Environmental Protection Agency’s (EPA) Hazard Ranking

System score of 53.57 based on severe contamination from numerous

sites. Installation officials agree that the area should be on the NPL because

of the contamination. Groundwater is not used for drinking on the

Edgewood Peninsula; however, there may be some private citizens near

the Edgewood area boundary that may have private wells that may be

affected. There also is concern that the contamination may affect the

1

An NPL site can be made up of numerous potentially contaminated locations on an installation. These

locations are referred to as individual sites when discussing the contaminated locations.

Page 8 GAO/NSIAD-95-8 Environmental Cleanup
Appendix I 

Aberdeen Proving Grounds Case Study

surface waters near the installation, including the Chesapeake Bay, which

could, in turn, affect the fish and wildlife in the area.

The Michaelsville Landfill covers about 20 acres, and it was placed on the

NPL on October 1, 1989. EPA assigned it a Hazard Ranking System score of

31.45 largely because of the potential for groundwater contamination

caused by leacheate from the landfill. Groundwater in and around the

Aberdeen area is used as a backup drinking water supply for the

installation. Installation officials do not agree with EPA that the landfill

contamination detected so far warrants NPL listing.

Even though the fire fighting training site located in the Aberdeen area

was not listed on the NPL, subsequent information indicates it may be the

worst site in the Aberdeen area because of the potential adverse effect on

the environment. Tests indicate that the site is contaminating the

groundwater, which supplies drinking water to the communities around

the installation. Groundwater in and around the Aberdeen area is used

extensively for drinking in Harford County (50,000 to 60,000 people) and in

the town of Aberdeen (14,000 people). A major concern is that the

continued pumping of the wells will establish a low spot in the

groundwater table that could further draw contaminated groundwater

from the site.

Installation officials have not tested any of the off-base drinking water

wells to determine if there is any contamination, but the county and the

state have found low levels of volatile organic compounds and

Trichloroethylene (TCE) in their testing of some of the county wells. In

1992, one of the county wells was shut down because of the TCE

contamination. In June 1993, the Army completed construction of a water

treatment system, at a cost of about $1.3 million, to remove TCE from the

water used. The well was also put back in operation in June 1993.

Status of the

Installation

Restoration Program

Under the Department of Defense’s (DOD) installation restoration program

(IRP), the installation has completed most of the preliminary

assessment/site inspection phase and is in the remedial

investigation/feasibility study phase of the Comprehensive Environmental

Response, Compensation and Liability Act (CERCLA) cleanup process. The

remedial investigation/feasibility study has been severely restricted by the

presence of explosives and chemical agents at some of the 79 sites.2

 These

2

The 79 sites consists of 319 solid waste management units. Each unit could be a place where

hazardous waste was disposed of or was spilled or is an operating facility.

Page 9 GAO/NSIAD-95-8 Environmental Cleanup
Appendix I 

Aberdeen Proving Grounds Case Study

79 sites have been divided into 13 study areas, with each study area to

have a Record of Decision.3

 Nine study areas make up the Edgewood NPL

site and four study areas make up the Aberdeen portion. Table I.1 shows

the status of sites on the installation.

Table I.1: Status of Sites at Aberdeen

Proving Grounds

CERCLA process phase

No. of sites

that reached or

will reach phase

Study 79

Interim remedial action-underway 10

Interim remedial action-complete 17

Remedial action 67

Remedial action in place and operating 0

Remedial action complete 0

Closed out-no further action 2

Installation officials do not think they have found all of the sites because

they are still finding new sites on a regular basis. The state and EPA have

said the installation does not have to do any more preliminary

assessment/site inspection work to find new sites. However, if a new site

is found, the applicable parts of the preliminary assessment/site inspection

must be done.

Cost The Army has spent $129.1 million through September 1993, even though

the installation has not entered into the remedial action phase. The

estimated projected total cost to complete the work required by the

Interagency Agreement,4

 as included in the Annual Report to Congress, is

$1.3 billion.

Installation officials believe costs must be controlled and they have

instituted cost control reporting for the work being done and scheduled to

be done. Each project manager has to maintain records on the work done,

perform an analysis of what has been done and how much the contractor

should be paid, and record the amount of payments. These statistics are

reported to the Chief of the Environmental Conservation and Restoration

Division monthly, quarterly, and annually. These reports are forwarded to

higher command for their review, analysis, and approval.

3

A record of what the installation and the regulatory agencies agree is needed to clean up a site.

4

An agreement among the installation, EPA, and the state regulatory agencies outlining what the

installation agrees to do to remediate the site. At some installations, a Federal Facilities Agreement has

been signed, but in this report we will call all agreements Interagency Agreements.

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Appendix I 

Aberdeen Proving Grounds Case Study

Another cost control measure is that all participants in the IRP meet

annually to review the entire program. During the meetings, they discuss

program status, share information, break down all aspects of the work,

discuss options, identify and try to avoid duplication, and identify

procedures or processes to reduce the cost. For example, in reviewing a

contract proposal from a U.S. Army Corps of Engineers’ contractor to

remove some hazardous waste from a Carroll Island site, installation

officials noted that the $1-million cost appeared to be inflated. Upon

further review, the removal action was completed with installation

personnel and contractors for about $258,000.

Options Considered Options were considered for only 2 of the 13 study areas—the Old “O”

Field site and the Michaelsville Landfill. Study work is continuing at the

remaining areas.

As shown in table I.2, a number of options and cost estimates were

considered for the Old “O” Field site.

Table I.2: Options Considered for the

Old “O” Field Site Cleanup Dollars in millions

Option Cost estimate

Down-gradient extraction with discharge to surface water $1.8

Extraction with capping and discharge to surface water 4.1

Extraction with spray irrigation/source flushing 3.0

Extraction with down-gradient reinjection 3.0

Air stripping/carbon adsorption (liquid phase) 9.4

Chemical precipitation/ultraviolet-oxidation 7.4

Chemical precipitation/activated sludge biological treatment/carbon

adsorption 6.4

Chemical precipitation/powdered activated carbon treatment 5.6

No action 0.0

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Appendix I 

Aberdeen Proving Grounds Case Study

As shown in table I.3, a number of options and cost estimates were also

considered for the Michaelsville Landfill.

Table I.3: Options Considered for the

Michaelsville Landfill Cleanup Dollars in millions

Option Cost estimate

Redressing the landfill cap $ 7.0

Installing a new cap in accordance with Maryland’s requirements

using off-post clay 9.2

Installing a new cap in accordance with the Resource Conservation

and Recovery Act requirements for hazardous waste landfill closure 9.6

Installing a new cap in accordance with Maryland’s requirements

using a geosynthetic (plastic) membrane 8.8

Excavating and hauling the waste off-site 135.5

Excavating and incinerating the waste 182.8

Excavating the waste, lining the cavity, replacing the waste, and

capping the landfill 21.1

No action 0.0

Options Selected Records of Decision concerning remedial actions or cleanup have been

signed for the Old “O” Field site and the Michaelsville Landfill. In addition

to these two study areas where options were considered, a Record of

Decision for no action was also signed for the White Phosphorous site

study area. EPA Region III officials told us that the options considered and

selected and the no action decision for the White Phosphorous site met

with their approval.

For the Old “O” Field site, a pump and treat system was selected. The

treatment consisted of chemical precipitation and ultraviolet-oxidation.

The effluent from the treatment plant is discharged into the adjoining

river. After the system was installed, installation officials decided to afford

more protection against the danger of explosion. To do this, they decided

to also install a sand cap over the site that would absorb some of the

effects of an explosion. The cap would also permit rain to wash through

the site, flushing out some of the waste that would be captured and treated

in the new pump and treat system.

For the Michaelsville Landfill site, the Army chose to install a new cap in

accordance with Maryland’s requirements using a special plastic liner.

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Appendix I 

Aberdeen Proving Grounds Case Study

Expected Completion Installation officials said no date has been projected for when all the

cleanup work will be completed. The installation is contemplating funding

for cleanup until the year 2010. As at other installations that use pump and

treat systems, it can take decades for the groundwater to be cleaned. In

most cases, the study work has not progressed far enough to know what

cleanup actions are required. Even with the landfill cap, continuous

monitoring is required, and if the cap fails, cleanup work may be required.

For a number of Aberdeen Proving Ground’s sites, installation officials do

not believe there is adequate technology available to do the cleanup work.

Regulatory Process Installation officials stated that the CERCLA process is time-consuming and

costly and takes a large number of people to implement. However, they

stated that there are some advantages to being placed on the NPL, including

(1) a higher funding priority; (2) a single point of contact for the state

regulatory agency; (3) better incorporation of the applicable, relevant, and

appropriate requirements; and (4) more and better attention from EPA.

They also said there are some disadvantages to being placed on the NPL;

for example, the required paperwork is difficult to manage and get

processed, reviewed, and approved.

Installation officials believe all installation sites should be included in the

Interagency Agreement because it provides for orderly and consistent

management. All of the installation’s sites are included in the agreement.

Because the installation cannot fund and implement all of the projects at

once, installation officials review and prioritize all of the projects and

determine which ones can be put under contract using existing

technology. This approach permits the movement of money to higher

priority projects. As a result, there are some quick response actions, and

some cleanup projects that are accelerated while others have limited

actions taken.

Officials have also tried to accelerate projects by condensing the study

plans to enable faster achievement of a Record of Decision and clean up

some of the worst sites quicker. To shorten the amount of time to clean up

a site, the installation has begun early removal actions or interim remedial

actions while the work to come up with a Record of Decision is being

completed.

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Appendix I 

Aberdeen Proving Grounds Case Study

DOD/Regulatory

Agency Cooperation

So far, the installation has not had any problems with the oversight

provided by the regulatory agencies—EPA and the Maryland Department of

Environment-CERCLA Section. According to installation, EPA, and state

officials, the working relationship has been great. They told us that they

have informally agreed to proceed with the job and to work together.

Installation officials told us that EPA keeps them busy trying to comply

with CERCLA requirements.

Cleanup Standards Installation officials like the idea of one cleanup standard versus the

cleanup being based on a risk assessment. However, they believe the

standard should have provisions for adjustments to accommodate local

conditions and a significant threat if there is one. They said for the

Aberdeen area, a risk assessment is crucial because of the potential threat

to drinking water supplies.

Staffing Installation officials told us that, as of August 1994, the installation was

authorized 14 restoration positions and they had no problem hiring the 

11 people they currently have. For a number of years it was difficult

replacing any that left because the Army had a staffing freeze. They stated

that the freeze had not caused any major problems. The freeze has been

lifted, but it still could affect the remedial action phase because not

enough staff are available to oversee the increased number of contractors

working on the IRP. One reason it has not been a major problem yet is that

Aberdeen was permitted to replace those staff members who left with the

three current staff employees that had lost their jobs because of a

reduction-in-force action at the installation. However, these people do not

have the technical or managerial expertise needed for the IRP. Installation

officials state that without the full number of trained staff authorized, it

will be hard to oversee the contractors’ work. To overcome the shortage of

staff, Aberdeen has signed a contract with the Department of Energy’s

contractor, HAZWRAP, to oversee and monitor the work of the

contractors.

Regulatory Agency

Staffing

EPA officials told us that because of the large number of NPL sites in Region

III and the staffing restrictions, they have been assigning most of their staff

to cover private sector NPL sites. They have a small number of staff

dedicated to federal facilities, which they believe is not enough to cover

the number of sites. Consequently, the region has used contractors to

assist it in reviewing documents.

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Appendix I 

Aberdeen Proving Grounds Case Study

Installation officials told us that the documents they submit to EPA Region

III are reviewed either by regional staff or contractors. According to these

officials, the contractors’ reviews often result in lengthy comments that

are hard to deal with and take considerable time whereas EPA’s reviews

result in comments that can be dealt with and that do not require

excessive work, such as more long-term studies to obtain additional

details on the sites. They told us the contractors’ reviews have caused

them delays in proceeding to the next phase.

Funding Army officials at the installation, the Army’s Environmental Center,5

 and

the headquarters level in Washington, D.C., told us that the Army, through

the Environmental Center, sets funding priorities based on the following

criteria:

• Sites on the NPL with an Interagency Agreement.

• Sites on the NPL without an agreement.

• Sites with notices of violation or consent decrees.

• Sites not on the NPL.

• Removal actions on the NPL.

• Sites with an agreement but not on the NPL.

• Removal actions not on the NPL.

The top two priorities are being fully funded by the Army, and the

installation has received all of the Defense Environmental Restoration

Account (DERA) funding requested. According to installation officials, two

of the worst sites, the fire training area and the Phillips Landfill, have not

received adequate funding (non-DERA) because they are not listed on the

NPL, even though they are included in the agreement. For example, the

installation requested $1 million in fiscal year 1993 to do some of the site

investigation work at the fire training site, but the Army only allotted

$200,000 for some preliminary study work.

According to installation officials, the fire training area was not adequately

funded for a number of years because of the Army’s funding priority

system. However, during the last 2 years, the funding priority has

increased to near the highest priority because installation and regulatory

agency officials consider it to be one of the highest risk sites on the

installation due to the fact that the site is contaminating local drinking

water supplies. In addition, the installation is receiving a larger share of

the funds because installation officials have begun to identify a number of

5

The Environmental Center manages the IRP, including funding and other resources.

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Appendix I 

Aberdeen Proving Grounds Case Study

projects each year that could be done if additional funds become available.

The installation has received a significant amount of year end funds when

other installations could not get their projects under contract.

Also, according to installation officials, some removal projects in the past

had not received the required funding because removals were given a low

priority under the Army’s funding system. These removal projects were

not given a high priority because the installation could not prove a direct

health or environmental risk. To prove a risk, installation officials would

have to do all of the study work, which would take time. As a result,

installation officials said that several removal projects had not been

implemented and the installation had run the risk of contaminating the

groundwater and causing a more costly cleanup problem. They also stated

that during the last 2 years, a number of these projects have been funded

because year end money became available.

At least once a year, installation officials meet with EPA to determine

which sites EPA thinks should have the highest funding priority because of

the environmental risk observed by the regulatory agencies. At these

meetings, installation and EPA officials have stated that they do not believe

the Army has assigned the proper funding priority to some of the sites,

including the fire training area. This site has not received funding because

the study phase was not complete when the Hazard Ranking System

scoring was done for the installation, and as a result, the site was not listed

as an NPL site. Even though it is a high risk site, according to EPA and the

state, it is not on the NPL, and because it is not on the NPL, the Army has not

assigned it a high funding priority.

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Appendix II 

Fort Wainwright Case Study

The primary mission of Fort Wainwright, Alaska, which covers over

900,000 acres, is to train soldiers in the arctic environment, prepare troops

to defend the state, and deploy worldwide. Industrial operations include

the maintenance of fixed-wing aircraft, helicopters, and support vehicles.

The waste generated and the contamination Fort Wainwright has to

address include petroleum products, chemicals, pesticides, volatile

organic compounds, heavy metals, batteries, solvents, paints, and

radiologically contaminated wastes. The U.S. Army, Alaska, Public Works

at Fort Richardson, manages and provides oversight of the environmental

programs at the fort. Fort Wainwright’s environmental staff provides

limited on-site assistance in the cleanup program.

Listing on the NPL Fort Wainwright was placed on the NPL with a Hazard Ranking System

score of 42.4 in August 1990 because of possible groundwater

contamination from a landfill, and the North Post sites, and six sites

contaminated with heavy metals. The score was a composite score of a

number of sites on the installation.

EPA officials, based on the preliminary studies, believed a North Post site

was leaking benzene into the groundwater; however, a subsequent review

of the data indicates this may not be true. A removal action removed all

contaminated dirt, and a groundwater investigation will be done to

confirm whether there is benzene contamination of the groundwater

according to Army officials.

The Army has records indicating mustard gas canisters were disposed of

on the fort, and an effort was made to locate the sites. One was found and

a partial cleanup was done in the 1960s. Another removal action is

planned. An EPA official believes the site still contains contaminants and

the site by itself could qualify the installation for the NPL.

Status of the IRP Several studies, including the preliminary assessment, have been

completed. The preliminary assessment, done in 1987, evaluated the

landfill, the North Post sites, and other petroleum, oil, and lubricant sites

scattered throughout the installation. In 1992, EPA, the state, and the Army

recommended that some sites be closed out, with no further action, and

that others be studied further, including some testing. During the

follow-up studies, possible chemical disposal sites in the Birch Hill area

and other sites that may require additional work were identified. Work on

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Appendix II 

Fort Wainwright Case Study

the remedial investigation/feasibility study was begun in fiscal year 1993.

Table II.1 shows the status of CERCLA work at Fort Wainwright.

Table II.1: Status of Sites at Fort

Wainwright

CERCLA process phase

No. of sites

that reached or

will reach phase

Study 61

Interim remedial action-underway 2

Interim remedial action-complete 19

Remedial action 15

Remedial action in place and operating 0

Remedial action complete 11

Closed out-no further action 34

Some of the North Post sites have been cleaned up and others are under

remediation. So far, the material taken from the North Post sites has had

very low levels of contamination. The installation’s petroleum, oil, and

lubricant pipeline has significant leaking problems. U.S. Army, Alaska,

officials plan to use ground penetrating radar to pinpoint any waste sites,

especially the alleged chemical waste disposal sites.

The Army found that only one of two possible sites had evidence of

possible radiological contamination. The radiation was believed to be

what was left from disposing of the remains of airplane instruments and

dials. An Army official stated that the contamination from this site was

removed in the 1960s, and EPA and the state formally agreed with the

Army’s decision for no further action on this site.

The installation is continually finding new sites, especially buried

petroleum products in drums. During World War II, in anticipation of a

possible Japanese attack on above ground petroleum, oil, and lubricant

storage facilities, the installation buried a very large number of drums with

these products in them. Even though the preliminary assessment identified

a large number of these sites on the installation, U.S. Army, Alaska,

installation, and contractor officials are continually finding others.

Recently, installation, contractor, and U.S. Army, Alaska, officials

identified a site where they thought about 40 to 60 drums were buried.

However, the contractor found over 1,600 drums, many still containing

petroleum products. Army officials told us that as of August 1994 all of the

drums had been removed from the site.

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Fort Wainwright Case Study

EPA and state regulatory agencies’ officials told us that the IRP at Fort

Wainwright is a good one and that they believe the installation is

identifying its sites through the IRP. The installation has been very diligent.

For example, unlike other installations, it closely coordinated the

preliminary assessment with both state and EPA regulators and

incorporated their comments into the assessment plan.

The sites have been divided into five operable units. Operable Unit 5 has

been left open to add new sites when found.

The Army, in studying the groundwater flow, is having difficulty

determining the amount of contamination, the direction of the

contamination plume migration, and the source of the contamination

because of the uncertainty caused by the permafrost. For example, based

on normal geological formations, groundwater would flow in a certain

direction. However, with the permafrost, the direction of the groundwater

flow can change, at times even be reversed. In addition, the effect changes

with the seasons.

U.S. Army, Alaska, officials believe that with the extent of contamination,

the geological formations, the permafrost, and available technology, the

installation cannot clean up the groundwater to drinking water standards.

They stated that attempts to clean up the groundwater would be very

difficult and costly.

Cost The Army had spent $21.4 million through fiscal year 1993, and it expects

to spend a total of about $72.7 million to implement the requirements of

the Interagency Agreement. However, installation officials told us the cost

estimate could increase as further study work is completed and the final

remedial actions are decided.

U.S. Army, Alaska, and the Corps of Engineers are responsible for

ensuring cleanup is being accomplished in the most cost-effective manner.

U.S. Army, Alaska, officials believe that if the following were implemented,

the cost of cleanup could be minimized.

• Clean up some sites while studies are being done at others.

• Remove the contamination from some sites and not do anything else, such

as installing expensive pump and treat systems that often do not clean up

the groundwater.

• Do nothing at all at some of the lesser contaminated sites.

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Fort Wainwright Case Study

Installation officials stated that another way to minimize costs is to

improve environmental contracts so that they are more flexible. An Army

official stated that 5 years ago, a “Blue Ribbon Panel” concluded that the

Corps’ construction contracts were not specific enough to prevent

unnecessary cost growth. In response, the Corps set up rigid procedures

for contracting and contract administration to prevent cost growth during

facility construction.

However, U.S. Army, Alaska, officials believe these rigid procedures

conflict with the need for flexibility in environmental contracts.

Environmental contracts are not like construction contracts because there

is not a definite structure being built. Also, there are many unknowns

concerning hazardous waste cleanup. Thus, it is almost impossible to tell

what will be encountered as the work progresses. As a result, there is a

need to constantly change the scope of work to adjust for the unknowns.

According to U.S. Army, Alaska, officials, the rigid procedures had caused

them to delay the IRP while the contracts are amended to include

additional problems found. These delays can extend the IRP by months and

cause costs to increase because contractors must wait while the contracts

are amended. The total effect is to allow the contamination to continue to

spread, thus necessitating additional cleanup work and possibly more

contract changes.

Army officials stated that Corps officials agreed that the rigid procedures

for construction type contracts have caused problems in environmental

contracting. They state that the Corps is reviewing its procedures to

determine if changes can be implemented to accommodate the need for

more flexibility while at the same time minimizing costs.

Options Considered U.S. Army, Alaska, officials told us that they have not reached the point

where they would consider which options to use in cleaning up the

installation.

Option Selected U.S. Army, Alaska, officials told us that nothing has been decided

concerning final clean up actions at the sites and for the cleanup of

groundwater. However, for selected sites, to prevent further

environmental contamination, the installation has taken interim remedial

actions to remove contaminants. These actions include removing

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Fort Wainwright Case Study

contaminated barrels, digging up contaminated soil and removing it from

the installation, and installing a groundwater treatment facility. Most of

these sites were considered to be “hot spots” that could be cleaned up

relatively easy and with minimal costs. The installation has used various

methods and some technological advances in the cleanup program such as

bioremediation, land farms, and biopiles. The regulatory agencies

concurred with the actions taken to date. However, it has not been

decided if further work will be required at these sites because final

agreement with the regulatory agencies has not been reached.

Expected Completion U.S. Army, Alaska, and installation officials told us that because they are

still in the early stages of the IRP, they do not know when the cleanup work

will be completed, what the extent of contamination is, or what the final

remedies for most sites will be. The officials stated that, if the installation

is allowed to limit work to the interim remedial actions at all of the sites,

then the IRP could be completed within the next 10 years, otherwise it

could take longer.

Regulatory Process Installation and U.S. Army, Alaska, officials told us that as long as the

work is being done under the CERCLA process they have no problems with

the regulatory agencies. However, they believe the CERCLA process as a

whole is time-consuming and costly and slows down the cleanup process.

The Interagency Agreement was signed by the state on December 24, 1991,

by EPA on March 25, 1992, and the Army on March 19, 1992. Installation

officials believe that all of the sites should be included in the agreement

because it enables everyone to concentrate on what needs to be done and

provides a mutually agreed upon basis for managing the work. As

decisions are made on each site, they will be incorporated into the

agreement. Installation officials firmly believe that the CERCLA process

would have been much slower if the procedure outlined in the Interagency

Agreement had not been in place.

DOD/Regulatory

Agency Cooperation

The Alaskan Department of Environmental Protection and EPA located

their program managers near the fort with the authority to act for each

agency. Officials from the involved organizations (U.S. Army, Alaska, EPA,

and state regulatory agencies) told us that having all three project

managers located near each other, and their willingness to work together,

has resulted in a good working relationship. They also told us that almost

all of the decisions these three have made have been right, resulting in

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Fort Wainwright Case Study

little change to actions being taken. The Army, at the DERA conference in

Denver, Colorado, designated Fort Wainwright as an example of how to

implement the program and has included the installation’s IRP in its CERCLA

management training.

The three program managers meet monthly, more if necessary. Actions

planned or being done by one activity are always discussed with the other

two. They deal with the small problems before they become big ones. If

they have a difficult problem, they check with their supervisors to make

sure the right decisions are implemented. They each have technical

experts either in-house or by contractor who provide assistance.

An important feature of the close working relationship of the three project

managers is that they meet often to informally work out some of the

difficult problems. This arrangement leads to a better understanding of the

views of each manager. They believe that not having frequent meetings

and a good working relationship could result in actions that may not be

required or that are wrong. If this happens, a lot of time and money could

be spent correcting the actions.

U.S. Army, Alaska, officials said that EPA and the state have been

extremely helpful to installation officials. They have conducted tests,

made the required analyses, and generally done whatever is necessary to

help get the work done. EPA has provided its technical expertise to either

start or complete the study and remediation work.

One concern, however, is that the state has placed stricter standards on

the installation’s cleanup of petroleum, oil, and lubricant sites than it has

placed on the city. In this instance, the contractor is required to dig up the

contaminated dirt and take it to a storage location where the state requires

it to be placed in plastic-lined storage facilities until it can be burned. (At

the time of our visit, the contractor was testing its proposed burning

operation for the fort on the city’s petroleum-contaminated soil.) However,

unlike the contaminated soil at Fort Wainwright, the city’s contaminated

soil is placed on the ground with no protection to the environment.

Installation officials believe that the city is not being held to the same

standard for treating waste as the installation is. By being held to a stricter

standard, to build the plastic-lined storage facilities, the installation is

incurring higher costs.

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Fort Wainwright Case Study

Cleanup Standards Installation, EPA, and state officials state that in an ideal world one

standard for each chemical would be the optimal solution for cleaning up

hazardous waste. But realistically, that cannot be done. Each site is

different and each chemical reacts differently depending upon the

environmental conditions.

Installation officials said that the cleanup standard for each installation

should be based on a risk assessment that considers what the installation

will be used for in the future. Thus, each assessment would entail different

goals for different installations for the same contaminant. Like California,

Alaska considers petroleum, oil, and lubricant products to be hazardous

waste, and most of the sites on the fort to be cleaned up are contaminated

with these products. As of now, the state standard that Fort Wainwright

has to clean up to is drinking water standards.

Staffing U.S. Army, Alaska, including Forts Greely, Wainwright, and Richardson,

has 26 authorized positions to do all environmental work, including

installation restoration or CERCLA work. The U.S. Army Force Integration

Support Agency made a study of the U.S. Army, Alaska’s, environmental

staffing in December 1993 and determined that to adequately do all of the

required environmental work, U.S. Army, Alaska, would need 54 staff

members. U.S. Army, Alaska, officials stated that it is unlikely they will get

any additional staff until the Army lifts its hiring freeze. They also stated

that one of the primary reasons Army installations were assessed over

$5 million in punitive and stipulated fines since January 1993 was the

shortage of environmental staff to do the required work.

These officials stated that by not having the number of people required

there has been adverse effects on the total environmental program. The

primary one is that they have not been able to adequately oversee the

work being done by the environmental contractors on the installations.

One staff member, the program manager (GS-12), oversees the IRP at U.S.

Army, Alaska, headquarters at Fort Richardson. Fort Wainwright has four

people working full time in the environmental area and a number of

“borrowed” military people assisting them. U.S. Army, Alaska, and

installation officials depend heavily on the Corps for the contracting

portion of the work, including the awarding, administering, and

monitoring of the contracts.

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Fort Wainwright Case Study

U.S. Army, Alaska, officials stated that keeping environmental staff is

difficult for the Army because it does not assign as high a grade structure

(top grade is a GS-13 at U.S. Army, Alaska, and GS-11 at the fort) to its

environmental programs at the installations as does the Air Force (GS-13

at each Alaskan installation), the Navy (GS-13), and the Bureau of Land

Management Office in Anchorage (GS-13). The officials have characterized

the Army’s program as the training ground for all of the other federal

agencies in Alaska. The training that the Army provides is outstanding and

recognized by all other federal agencies in the state. However, to get more

money and a promotion, the Army staff have to go somewhere else, often

doing the same job or at times a lesser job.

U.S. Army, Alaska, and installation officials told us that the staffing for the

IRP work is not enough to oversee contractor work, a responsibility of U.S.

Army, Alaska. Because of its staffing shortage, they have to rely too much

on contractors. The contractors are put in a position of getting the CERCLA

work done, even though they do not have the authority to act for the

government in dealings with the regulatory agencies.

Army officials told us staffing is not adequate to properly spend the money

now available, much less any more that might be provided them. If the

budget continues to grow and the Army continues to have its current

staffing problems, some funds could be inappropriately used. For

example, contractors may take actions not required (drill unnecessary

monitoring or test wells), will do things wrong (not properly preserving

test samples), or will not comply with requirements (not using

EPA-approved laboratories to perform the tests), which could lead to

additional costs in the future.

Regulatory Agency

Staffing

Fort Wainwright and U.S. Army, Alaska, officials told us they have not

experienced any problems with the Alaskan Department of Environmental

Control because of any staffing shortages. State officials, however, told us

that they are beginning to experience some serious funding and personnel

problems and that these problems could affect the adequacy of their work

in the future.

U.S. Army, Alaska, officials told us that they have experienced some

problems in getting documents reviewed by EPA Region X officials within

the time frames set forth in the Interagency Agreement. A Region X official

told us that they have experienced some problems reviewing documents

timely because they do not have enough staff and thus, the region has used

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Fort Wainwright Case Study

contractors to review and analyze the installation’s submissions. U.S.

Army, Alaska, officials state that this approach has complicated the CERCLA

process because a contractor generally recommends to EPA that more

work be done for each site. By having the installation do more at each step

of the process, the contractor is able to continue working. As a result, the

program is delayed and costs increase significantly. A Region X official

told us they minimize the chances of this happening by requiring all

contractor work to be reviewed and approved by EPA staff.

Funding Being on the NPL forces installation and U.S. Army, Alaska, officials to

focus on the problem, work out solutions, and deal with the issues. It also

enables them to get DERA funding easier. They believe that the only way to

get adequate cleanup money is to be listed on the NPL.

The amount of funds received has been adequate. Additional money could

not have been used because Fort Wainwright and U.S. Army, Alaska, do

not have enough people to adequately oversee any more contracting work.

All of the sites identified on the installation have been given equal priority

for DERA funding.

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Appendix III 

McChord Air Force Base Case Study

McChord Air Force Base, Washington, was formally dedicated in May 1938

on land deeded from Pierce County and occupies about 4,600 acres near

the city of Tacoma. As an Air Mobility Command facility, McChord’s

current mission is to provide rapid airlift capability of personnel and

equipment to anywhere in the world. Significant quantities of solvents,

protective coatings, industrial products, petroleum, oils, and lubricants

have been used in maintenance and operational activities in support of this

mission and past missions. As a result, McChord has some contaminated

sites, which are similar to those found on many other Air Force and Navy

aviation installations.

Listing on the NPL Unlike the current practice of DOD and EPA to place an entire installation

from fence to fence on the NPL, only two sites on the installation were

placed on the NPL. These two sites were (1) the off-base American Lake

Garden Tract with a Hazard Ranking System score of 31.94 and the

adjoining contiguous Area D, which has seven individual sites, including

the Whispering Firs Golf Course (site 5 landfill) and (2) the Washrack

Treatment Area, including sites 54 and 60 with a score of 42.24. The

American Lake Garden Tract and the Washrack Treatment Area were

placed on the NPL in September 1984 and July 1987, respectively.

Two landfills may be leaching contaminants into the groundwater and a

contamination plume was documented to be spreading under the

American Lake Garden Tract from Area D and the site 5 landfill. The

groundwater, at the 140- to 500-foot level, is used for drinking water, and it

is contaminated with TCE and other wastes from both NPL sites. TCE has

shown up in two of McChord’s wells; however, most of the sample test

readings were below the 5 parts per billion (ppb) Maximum Contaminant

Level set by EPA. The readings for the highest test well ranged from 0.08 to

120 ppb. The Washrack Treatment Area has a stationary layer of fuel and

oil floating on the water table.

Even though there is some groundwater contamination, McChord officials

do not believe any installation sites should be on the NPL. The

contamination is not very bad, and the installation has paid to have the

American Lake Garden Tract area hooked up to the regional water system.

They believe the decision to put McChord’s sites on the NPL was a “political

decision,” not one based on significant evidence. In other words, during

the early stages of the Superfund program, EPA was under pressure to get

sites on the NPL, and McChord’s sites were two possibilities where the

listing could be done rather quickly and easily.

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McChord Air Force Base Case Study

EPA officials stated that in the early stages of the NPL effort, there were very

few sites with enough data to determine if they should be listed. In the

case of McChord, they knew the installation had some groundwater

contamination and they decided to list it.

Status of the IRP McChord officials believe the IRP Phase I study and the follow-on CERCLA

preliminary assessment and other investigative work have identified all

sites on which McChord has any data. However, there is the possibility

that unknown sites may be found.

The Phase I study identified 62 sites. Subsequent study work confirmed

most of these sites and identified 2 additional sites, for a total of 

64 hazardous waste sites. In addition, 22 DERA eligible underground storage

tanks with contamination problems were designated as site 65. These 

22 tanks were later removed from the DERA-funded effort to an

environmental compliance-funded project, which is complete. Table III.1

depicts the status of CERCLA work at McChord.

Table III.1: Status of Sites at McChord

Air Force Base

CERCLA process phase

No. of sites

that reached or

will reach phase

Study 65

Interim remedial action-underway 0

Interim remedial action-complete 1

Remedial action 6

Remedial action in place and operating 1

Remedial action complete 0

Closed out-no further action 58

Of the original 62 sites, a large number of them were included in the Phase

I study because someone believed some waste may have been disposed of

at the site, but there was no evidence or documentation supporting this

belief. McChord officials said that 52 sites should not have been included

and would not have been if they had been in the private sector. McChord

submitted to EPA a No Further Response Actions Planned document on

August 15, 1994, for 58 sites. Installation officials consider these sites to be

finished. EPA and the state have agreed to the no further action decisions

on 24 of the 58 sites.

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McChord Air Force Base Case Study

Cost Through 1993, McChord had spent $12.5 million, and it expects to spend,

based on its understanding of the Interagency Agreement requirements, a

total of $20.1 million through 2005. The total cost does not include any

changes that may be made to the IRP or any additional requirements

resulting from changes in the laws or regulations.

McChord is using a task order contract, which officials believe permits the

installation to get the work done in a timely manner and at the lowest

costs possible. The preliminary assessment cost about $50,000. The

remedial investigation/feasibility study for the American Lake Garden

Tract cost $3.1 million and took over 37 months to complete. However,

McChord officials believe that the annual costs will start to decrease

because future costs will be for long-term monitoring and the operation

and maintenance of the pump and treat system, which was built at a cost

of $1.5 million.

Options Considered The options considered for the American Lake Garden Tract were

• no action, with monitoring only;

• one groundwater extraction system, one carbon adsorption treatment

facility, and irrigation/recharge of treated groundwater;

• three groundwater extraction systems, two carbon adsorption treatment

facilities, and irrigation/recharge of treated groundwater; and

• three groundwater extraction systems, two carbon adsorption treatment

facilities with addition of bioremediation, and irrigation/recharge of

treated groundwater.

The options considered for the Washrack Treatment Area were

• no action except monitoring of the groundwater;

• institutional controls to prevent access to the site;

• containment of the floating layer of oil by installing a cap and institutional

controls;

• installation of a groundwater/fuel extraction system, a treatment system to

remove the fuel from the groundwater, and off-site recycling of the

recovered fuel;

• an excavated trench, passive fuel removal, off-site recycling of recovered

fuel, and bioremediation of the soil excavated from the trench at a

contractor’s site off the installation; and

• bioremediation of the fuel and fuel contaminated soil in place at the site.

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McChord Air Force Base Case Study

Option Selected For the American Lake Garden Tract, the Record of Decision calls for

installing a pump and treat system with long-term monitoring. At first,

McChord officials believed it was a “bad decision” to try and clean up the

aquifer. But now McChord, EPA, and Washington Department of Ecology

officials agree that the aquifer will not be cleaned up in the near future,

maybe decades, if ever. However, they agreed that the pump and treat

system will be used to contain and/or manage the contamination plume so

that contamination will not spread further. McChord will provide

institutional control to prevent any disturbances of the contamination.

The Record of Decision for the Washrack Treatment Area calls for

installing a fuel extraction trench and collection system for passive fuel

removal. The collected oil will be sent to a recycling treatment facility.

Long-term monitoring of the groundwater will determine if the

contamination leaves the installation, and institutional controls to prevent

disturbance of the contamination will be implemented.

However, a pilot study, conducted as part of the remedial design phase,

showed that the amount of fuel at the site was over estimated in the

remedial investigation/feasibility study. Consequently, it was determined

that the selected remedial action was not feasible. Therefore, McChord, in

agreement with the state and federal regulators, developed an Explanation

of Significant Difference document that recommended that no remedial

action be taken, but that long-term monitoring should be done. As agreed

upon, the long-term monitoring program should begin in fiscal year 1995.

Expected Completion According to the October 1993 Management Action Plan, remedial actions

at McChord will not be completed until 2005. McChord officials state that

even then long-term monitoring will probably continue for an unknown

length of time, maybe decades.

Regulatory Process McChord officials believe all sites on the installation should have been

included in the Interagency Agreement. However, a three-party agreement

(EPA, state, and McChord) was signed to include only the two NPL sites. A

Consent Decree, or two-party agreement, with the Washington Department

of Ecology was signed for 29 additional sites covered by the state’s Model

Toxic Control Act. The act allows the installation to have more latitude on

what is to be done, to focus its study efforts, and to set time frames or

deadlines for those sites not on the NPL.

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McChord Air Force Base Case Study

McChord officials believe that the CERCLA process has delayed the remedial

investigation/feasibility study phase. EPA has issued a number of guidance

documents for this phase that requires an installation to conduct studies,

prepare reports, submit draft reports to EPA for review, and incorporate

EPA’s comments in the reports and plans. This is a problem because EPA

wants the installation to do the study and analysis work to come up with

an iron-clad case that will stand up to public scrutiny. McChord officials

said that EPA officials have told them that for the remedial decision to

stand up to public scrutiny, the installation must prepare the same

documents that would be needed to make the case stand up in the courts.

Each section of the process usually has several versions of any reports or

plans. For example, a preliminary draft is prepared and submitted to EPA

for review and comment. EPA provides its comments, which are prepared

by its contractors, to McChord, which then has its contractor review EPA’s

comments and incorporate the changes and resubmit the draft to EPA as a

final draft. EPA reviews and submits its comments on the final draft to

McChord, which incorporates the comments into the final report.

For the period July 1988 through September 1991, McChord officials

analyzed the time spent preparing and revising documents submitted to

EPA. During that time, 25 documents were prepared, often including

multiple versions that incorporated EPA’s and the state’s comments.

Review of each version of each plan or report usually costs $20,000 to

$30,000.

EPA and the state required McChord to make a risk assessment for the two

NPL sites. Even though the Washrack Treatment Area is in an area where

industrial activity continues, EPA required McChord to use residential

standards. EPA said that McChord should assume in its risk assessment

that condos will be built on the site and children will be playing in the area

and all people living in the condos will get their drinking water from the

shallow aquifer.

The installation has faced difficulties in resolving differences between the

regulatory agencies. If they require different actions or set different

standards, McChord resolves the differences and determines what is to be

done, which takes time and causes IRP delays. EPA officials told us that they

are trying to minimize their differences with state officials so the IRP can

proceed.

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McChord Air Force Base Case Study

DOD/Regulatory

Agency Cooperation

Generally, during the last couple of years, McChord has had a very good

working relationship with the regulatory agencies. There are no problems

with the way things are being done at the present time. This increased

cooperativeness has come about partially because of the changes

instituted by the Air Force and EPA due to the good working experiences

EPA has had with Fort Wainwright.

The Washington Department of Ecology is the state regulatory agency

responsible for oversight. McChord officials state the working relationship

with Ecology has been outstanding because it is willing to work with the

installation to accomplish the cleanup.

McChord officials state they had trouble getting EPA to review their

documents in a timely manner, which has caused delays in getting work

done. EPA uses contractors to review the documents and reports submitted

by McChord because EPA does not have the staff to do it. EPA officials state

that any products prepared by their contractors must be reviewed by EPA

staff before being released to McChord. At times, this review by EPA staff

has been less than desired because of the workload. McChord officials do

not believe this has caused any insurmountable problems.

McChord officials told us that the biggest problem encountered with

contractors, not just McChord’s, is that they are involved in the

decision-making process for the program. They believe that a cleanup

program should not be controlled by a contractor. DOD needs to insure that

adequate numbers of people with the required technical expertise are

available (1) to oversee the contractors and (2) to use the

contractor-prepared data in deciding what has to be done.

Cleanup Standards According to McChord officials, there should be only one set of standards.

However, since sites are so different, it may be necessary to establish a

cleanup goal for large badly contaminated sites. The hydrology is very site

specific, and often cleanup standards cannot be technically achieved or

are not economically feasible. Any applicable state standard that is more

stringent than the comparable federal standard and is legally applicable or

relevant and appropriate under the circumstances will apply. McChord

officials believe the state of Washington may have gone too far because

some standards are not measurable with today’s equipment.

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McChord Air Force Base Case Study

Staffing Generally, McChord was able to hire, train, and retain staff. It currently

has seven people, which is enough to manage the work done at the current

funding level, and it does not expect to receive additional funds. McChord

officials stated that they need to maintain high grades to attract high

quality, fully trained staff with experience. Recently the Air Force

mandated reductions in DERA-funded staff. Consequently, McChord will

lose some of its DERA-funded staff in fiscal year 1996.

Regulatory Agency

Staffing

McChord officials are not aware of any insurmountable problems caused

by the number and quality of staff at the regulatory agencies other than the

time it takes to have documents reviewed.

Funding Under current Air Force procedures, the NPL sites with signed Interagency

Agreements get the highest funding priority. The next priority is for

non-NPL sites that have compliance deadlines. Since all of McChord’s sites

are subject to regulatory deadlines, there have been no problems in

obtaining the required funds. However, McChord officials believe that in

the future, DERA funds may not be enough to get the work done at all

installations. As a result, there is a need for some type of priority setting

system to determine which installations and which sites on each

installation will receive money. Consequently, according to these officials,

DOD may have to tell the regulators it cannot clean up all of the sites. Air

Force headquarters has informed McChord officials that the Air Force

funding priorities are scheduled to change in fiscal year 1997. A risk

assessment approach will replace the current priority scenario.

Two ways to reduce costs are

• clean up only the bad sites and delay or not do the clean up for sites that

do not pose a risk to the environment and

• modify the amount of study required for some of the lesser sites so that

quick removal actions can be undertaken.

Page 32 GAO/NSIAD-95-8 Environmental Cleanup
Appendix IV 

McClellan Air Force Base Case Study

The Sacramento Air Logistics Center, California, is a large industrial

complex located on McClellan Air Force Base. The Center’s primary

mission is aircraft maintenance. In performing its mission, the Center

generates more than 470 different hazardous waste streams, including

solvents, caustic cleaners, low level radioactive waste, polychlorinated

biphenyls (PCB), heavy metals, and a variety of fuel oils and lubricants. The

previous disposal practices for wastes from these industrial type

operations have resulted in significant environmental contamination.

Listing on the NPL EPA scored McClellan using the Hazard Ranking System in 1984 and placed

the entire installation on the NPL in July 1987. McClellan’s score of 57.93 is

the highest of any Air Force base. However, McClellan officials state the

contamination is actually much worse than what was known in 1984 and

what the score indicates. Over the years waste products from industrial

activities have been dumped into disposal ponds located throughout the

installation. These hazardous wastes have percolated into the soil and

groundwater, and the contamination is migrating off the installation. There

are three huge plumes of contaminated groundwater containing more than

11 billion gallons and reaching depths of 400 feet beneath the installation.

The worst contaminated groundwater is near the installation’s western

boundaries and drinking water wells have been closed, the drilling of new

water wells banned, water purification systems installed, and 540 off-base

citizens connected to public water supplies. More than 400 acres of soil

have been contaminated to depths exceeding 300 feet for an estimated

total of 1.5 billion cubic feet of contaminated soil and more than 11 billion

gallons of contaminated groundwater.

TCE has been detected in the shallow, middle, and deep water-bearing

zones of the aquifer with 45,000 ppb as the highest level detected. Other

contaminants detected and the amounts are 1, 2 Dichloroethylene (600

ppb), Tetrachloroethylene (1,400 ppb), Vinyl Chloride (2,700 ppb), and

Carbon Tetrachloride (500 ppb).

Status of the IRP An Interagency Agreement was signed with EPA and the California EPA in

July 1989. The preliminary assessment/site inspection phase is complete,

and 258 potentially contaminated sites have been identified. Most of these

sites are now in the remedial investigation/feasibility study phase. Table

IV.1 depicts the status of sites at McClellan.

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McClellan Air Force Base Case Study

Table IV.1: Status of Sites at McClellan

Air Force Base

CERCLA process phase

No. of sites

that reached or

will reach phase

Study 258

Interim remedial action-underway 15

Interim remedial action-complete 134

Remedial action 255

Remedial action in place and operating 0

Remedial action complete 3

Closed out-no further action 36

The sites are divided into 11 operable units. The following are three

examples of an operable unit’s location, number of sites, type of

contaminant, and actions being taken.

• Operable Unit A, in the southeastern portion of the installation, is the

oldest and most densely built-up area and contains 121 sites.

Contaminated sites include repair shops, photo and other laboratories, PCB

and asbestos storage areas, motor pools, wash racks, gas stations, oil

water separators, sewer drains and sumps, industrial waste treatment

plants, acid and cyanide disposal pits, and landfills. Regulatory agencies

have preliminarily concurred with the Air Force’s suggestion of no further

investigation at three sites. The Interagency Agreement calls for the

remedial investigation/feasibility study to be conducted based on a site

prioritization model, with high priority sites proceeding with remediation

first. Site prioritization is currently underway.

• Operable Units B and C, in the western and southwestern portions of the

installation, contain about 1,350 million cubic feet of contaminated soil

and 2 plumes of groundwater contamination that join to create a single

10-billion gallon plume contaminated by several contaminants, including

TCE, which reaches depths of 400 feet. Operable Unit B contained 48 sites

and Operable Unit C contained 43. Both included waste disposal pits and

trenches, landfills, sewer lines, underground storage tanks, and an

industrial waste treatment plant with surface impoundments. Most of the

underground storage tanks have been removed and/or replaced with above

ground storage tanks or state of the art underground storage tanks. The

underground storage tank program to remove or replace single walled

tanks is scheduled to be completed in 1996, ahead of the 1998 compliance

deadline. The surface impoundments were shut off in 1988 and were

surface sealed in 1989.

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McClellan Air Force Base Case Study

One of the installation’s drinking water wells, number 18, was shut down

in 1981, after volatile organic compounds were detected in quantities

above the action level. An activated carbon filtration system was installed

in 1985 for the well. This system is still in operation, and bimonthly

filtration system and effluent sampling and analysis has shown no volatile

organic contaminants above the action level.

In December 1986, the Air Force completed construction of the

groundwater treatment plant at a cost of $4.8 million. This plant treats

contaminated groundwater pumped from 15 extraction wells—6 wells in

Operable Unit D ($1 million), 7 wells in Operable Unit C ($1.5 million), and

2 wells in Operable Unit B ($700,000). At the time of our visit, the plant

was treating 250 gallons per minute, but it was designed to handle up to

1,000 gallons per minute. The plant is effective in controlling the flow of

groundwater in shallow, middle, and deep water-bearing zones.

Cost The Air Force has spent more than $155 million on cleanup at McClellan

through fiscal year 1994. Air Force officials recently reduced the cost

estimate made in 1992 by $300 million, to $1.3 billion. However, this

revised estimate relies on assumptions that new emerging technology can

be used, the completion date can be extended to the year 2010, and new

initiatives will be successful.

McClellan officials state the science and technology needed to

economically clean up massive amounts of contaminated soil and

groundwater, like those under McClellan, are not currently available. They

state it would cost a prohibitive $10 billion to clean up the installation

using existing or current technology by the Air Force’s completion goal of

the year 2000.

Delaying the cleanup of contaminated sites can increase the cost if the

contamination is allowed to migrate and enter the groundwater. However,

installation officials state that taking extra time can also be a vehicle to

reduce cleanup costs. They note it may be better to contain and manage

contaminated sites until emerging technology, now being studied and

tested, becomes available and natural remediation is also occurring with

the passage of time. They state that if an installation rushes in and installs

treatment systems that are not proven, the cost for cleaning up the site

may be increased, first by the system installed if it does not work and

second by having to install a new system later.

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McClellan Air Force Base Case Study

Options Considered McClellan, in cooperation with EPA, is testing a number of new

technologies for remediating massive amounts of both contaminated soil

and groundwater economically. These emerging technologies include a

two-phased extraction and soil vapor extraction. McClellan officials hope

to assess the feasibility of dislodging contaminants trapped in the soil by

lowering the localized groundwater table and then extracting the

contaminants with vacuum pressure. McClellan officials also hope to

assess the feasibility of lowering the localized groundwater table and

extracting contaminants associated with vapors, instead of water, using

vacuum pumps.

Option Selected The final options have not been selected, but McClellan officials state that

the installation’s huge amount of contaminated soil and groundwater are

too massive to economically clean up with current technology. Instead,

McClellan officials have implemented various actions to limit human

exposure to contaminated groundwater and soil as natural remediation

occurs and new and better technologies are developed. These actions

include installing pump and treat systems and the removal of hot spots or

high concentrations of contaminated soil. In addition, they are cooperating

with EPA to develop and test various new methods of remediating the soil

that may be more economical.

Expected Completion Installation officials state the Air Force’s goal of completing the cleanup

by the year 2000 is not realistic. They believe that by stretching the

installation’s IRP out to 2010 they can use emerging technology and let

natural remediation occur. In the interim, they will protect the public by

limiting exposure.

Regulatory Process McClellan officials state the CERCLA process was primarily designed to

identify and correct only a few contamination problems at the installation.

However, McClellan’s contaminated sites have massive amounts of

contaminated soil and groundwater and have a variety of problems.

According to the officials, the proper evaluation of the problems and their

solutions requires that the process be tailored to the conditions on the

installation.

McClellan has conducted several removal and interim actions, using the

Superfund Accelerated Cleanup Model version of the CERCLA process.

Some were implemented prior to the remedial investigation/feasibility

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McClellan Air Force Base Case Study

study and/or remedial design phases being completed. These actions were

designed to stabilize a site, prevent further degradation, or achieve risk

reduction in terms of the threat posed to the public or to the environment.

During our visit, McClellan officials complained about the regulatory

process being slow. They stated that EPA had trouble providing timely

review of and comment on documents. Also, they stated it was virtually

impossible to get regulatory agencies to agree that nothing more needed to

be done at sites that have been cleaned up.

However, McClellan and the regulatory agencies created the

Environmental Process Improvement Center, a cooperative grouping of

the parties to the Interagency Agreement, including McClellan, EPA, and

the California EPA. The goals of the Center include accelerating site

cleanup, preventing pollution, applying new cleanup technologies, and

sharing compliance strategies. Since the creation of the Center, the IRP

activities have progressed at a faster rate. For example, the Air Force has

implemented removal actions as the expedited response to control the

migration of contaminants beneath Operable Unit B before it reached the

installation boundary or well Number 18.

DOD/Regulatory

Agency Cooperation

McClellan officials state that the working relationship between installation

officials and the regulatory agencies has improved since the Center was

created. McClellan officials state that they have found the cooperative

working relationship and the team partnership approach with regulatory

agencies are much better because they eliminate the adversarial

relationship and litigation and promote the cleanup process. McClellan

officials state that team interaction helps them move through most

difficulties, shortens time frames, and reduces costs.

Cleanup Standards McClellan officials believe cleanup standards should be set by EPA, not the

states since EPA’s standards are designed to limit exposure to a substance

that may be unhealthy. The amount of exposure may vary based on age as

the very young and old tend to be more sensitive, but it should not vary by

site. However, they believe that cleanup goals, which are based on the

cleanup standard and the likelihood of exposure and are usually quite site

specific, should be set for each site by EPA, state regulators, and DOD.

McClellan officials state small contaminated sites can be cleaned up to a

cleanup standard less expensively by removing or treating relatively small

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McClellan Air Force Base Case Study

amounts of contaminated soil rather than conducting a risk assessment.

However, it is often not economically feasible, technically possible, or

necessary to achieve the cleanup standard for sites with massive amounts

of contaminated soil. They also note that it is not possible to return

contaminated aquifers to drinking water standards or pristine conditions

for decades with existing technology but that the public can be protected

by treating the groundwater extracted for drinking purposes. EPA does not

fully agree with McClellan’s position, but they are working with the

installation to develop strategies for cleaning up as many sites as possible

and getting out of the CERCLA process.

Staffing McClellan officials told us that they do not have sufficient staff to support

the growth of the IRP. The downsizing of DOD and the federal work force

has made it extremely difficult to attract well qualified candidates. During

the past year, McClellan has had a 30-percent turnover rate in its IRP

resources. When vacancies occurred, it was difficult to hire replacements

due to major personnel constraints from base closure and realignment

actions. The average time to fill vacancies has tripled during the past year

and positions were being filled with personnel with limited or no

environmental experience or training. In addition, they stated that

proposed reduction-in-force actions would eliminate over 20 percent of

their DERA-funded personnel. If this occurs, there will be severe impacts to

McClellan’s ability to maintain the progress that has occurred in IRP

activities over the last decade.

Regulatory Agency

Staffing

McClellan officials noted that EPA and the state regulatory agencies have

good technically qualified people, but neither have enough, and there has

been a significant turnover of EPA’s technical staff. State regulatory

officials stated that they need more people and that turnover is a

significant problem. They also stated it is difficult to hire qualified and

experienced people in many of the specialties needed for this work

because it is a relatively new area of endeavor.

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McClellan Air Force Base Case Study

Funding McClellan officials stated that funding has not been adequate to achieve

the Air Force’s goal of completing cleanup by the year 2000. Anticipated

funding levels also do not support meeting original Interagency Agreement

schedules. However, all agencies recognize that cleaning up all sites,

regardless of the risk it poses, is not a cost-effective approach. As a result,

McClellan is changing from an operable unit cleanup schedule toward a

basewide schedule that is driven by the risk posed. McClellan officials

believe that the risk-based approach will be more cost-effective, providing

current efforts to accelerate the development of innovative and emerging

cleanup technologies.

Page 39 GAO/NSIAD-95-8 Environmental Cleanup
Appendix V 

Pearl Harbor Naval Complex Case Study

The Pearl Harbor Naval Complex,1 the product of more than a hundred

years of peace and wartime development, is located on 6,300 acres along

the southern coast of the Island of Oahu. The installation’s primary

mission since the early 1900s has been ship repair. Shore facilities and

wharfs have been constructed, expanded, and improved to meet changing

needs of the U.S. fleet. Today, the Complex provides facilities, services

(including maintenance), and materials in support of the U.S. Pacific Fleet.

Past inappropriate handling and disposal of hazardous substances,

including waste oils, pesticides, heavy metals, PCBs, solvents, chemical

wastes, and fuels have contaminated the environment. The releases were

often the result of accidents such as leaks, spills, and ruptured containers.

However, in many instances, the releases were due to disposal practices

deemed acceptable at the time.

Listing on the NPL The Complex was listed on the NPL in October 1992. In 1991, EPA scored six

sites under the Hazard Ranking System. While EPA did not include more

than 50 other potentially contaminated sites at these activities in its

evaluation, it reserves the right to designate additional sites under its

aggregation policy of considering all sites in the Complex as a single NPL

site. The Complex’s Hazard Ranking System score of 70.82, the highest of

any DOD installation, is a composite score based on the six sites.

Navy officials agree that the Complex should be on the NPL, but stated it

should not have the highest score of any DOD installation. They are

concerned the high score could cause bad publicity and extra EPA

requirements and oversight, which could delay cleanup efforts. Navy

officials sent a letter to EPA questioning the validity of the score, noting

that each of the activities’ individual scores would have only been in the

low 30s, which would have given the Complex a low NPL ranking.

Status of the IRP The 1983 Navy Assessment and Control Of Installation Pollutants Initial

Assessment Study2

 identified and evaluated 32 potentially contaminated

sites with regard to contamination characteristics, migration pathways,

and pollutant receptors. Of the 32 sites, 3 were recommended for further

1

The Complex consists of seven activities: Shipyard, Naval Station, Public Works Center, Inactive

Ships Center, Submarine Base, Naval Magazine Lualualei (West Lock Branch), and Fleet Industrial

Supply Center.

2

The assessment is equivalent to the CERCLA Preliminary Assessment.

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Pearl Harbor Naval Complex Case Study

study and were listed in order of priority: Pearl City Peninsula Landfill,

Red Hill Oily Waste Disposal Pit, and Transformer Station D4.

EPA disagreed with the Navy’s position taken in its preliminary assessment

study and requested further investigation at 16 additional sites of the 32,

but made no reference to the remaining 13 sites. Subsequently, the Navy

identified another 29 sites for a total of 61. Table V.1 depicts the status of

CERCLA work at the Complex.

Table V.1: Status of Sites at Pearl

Harbor Naval Complex

CERCLA process phase

No. of sites

that reached or

will reach phase

Study 61

Interim remedial action-underway 2

Interim remedial action-complete 4

Remedial action 46

Remedial action in place and operating 0

Remedial action complete 0

Closed out-no further action 18

The six sites scored under the Hazard Ranking System included two

sites—the former gyro repair shop and the former metal pickling waste

disposal site—that the Navy had determined no further action was

required under the CERCLA process. Also, EPA’s request for further

investigation did not include them. According to Navy officials, neither of

these sites affected potable water as the groundwater under them is

brackish (salty) water. The nearest potable water well is several miles

up-grade in the opposite direction of groundwater flow.

As new sites are identified, they are included for investigation on a priority

basis. Site inspections have been completed or are being completed for

most Pearl Harbor sites.

The Navy, EPA Region IX, and the state’s Department of Health entered

into an Interagency Agreement in April 1994. The agreement establishes a

framework to investigate and clean up the Complex.

Cost The Navy has spent about $26 million and estimates it will cost about

$196 million to complete clean up of the contaminated sites. The cost

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Pearl Harbor Naval Complex Case Study

estimate is based on initial job scopes and may increase significantly once

more is known about the sites and the remediation phase begins.

Options Considered Navy officials stated that the IRP has not progressed far enough to

determine which cleanup options will be considered for the Complex.

Progress in the IRP has been slow because the Complex was not designated

a NPL installation until October 1992. Without the NPL designation, funding

was hard to get and the work done was limited. As interim measures, the

Navy is considering bio-remediation and pumping to remove oil floating on

the subsurface groundwater. Currently, an oil-water separator, booms, and

oil skimmers collect oil that seeps through cracks in a storm drain leading

into Pearl Harbor after heavy rains. Another small oil recovery project has

been installed to determine the feasibility of pumping the oil out of the

aquifers.

Option Selected The work has not progressed far enough to select the final cleanup options

yet.

Expected Completion During the Interagency Agreement signing ceremony, officials from the

Hawaii Department of Health and EPA Region IX announced that the

cleanup could take up to 30 years to complete based on the number of

sites, collection requirements, and remedial action required.

Regulatory Process Navy officials believe the elaborate CERCLA process does not need to be

performed on small sites that could easily be remediated without a

large-scale study and those sites covered by previous agreements with EPA.

In addition, the CERCLA process of determining liability is not needed for

sites that are the Navy’s responsibility, so there is no need to prepare

documents in anticipation of litigation to determine who should pay for

remediation.

DOD/Regulatory

Agency Cooperation

The Naval Facilities Engineering Command’s Pacific Division has a good

working relation with EPA and state regulatory officials. The Navy informs

the state and EPA on the progress of its cleanup studies and actions.

Because the Complex was not on the NPL until October 1992, EPA had not

been a problem because it focused on NPL sites. However, since

October 1992, EPA has begun to provide more oversight at the installation.

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Pearl Harbor Naval Complex Case Study

The Complex has not encountered any difficulties with multiple controls

by the regulatory agencies regarding oversight.

Cleanup Standards Pacific Division and Pearl Harbor Complex officials all agreed that

contaminated sites need to be cleaned. However, they question the need to

clean all sites to standards that may exceed naturally occurring conditions

or when such cleanup is not technically or economically feasible. They

advocated programs such as stopping contamination flow into

groundwater and preventing the contamination from spreading.

Navy officials had no opinion as to whether there should be one set of

cleanup standards and who should set them. They noted that the state

relies upon EPA standards but does provide some state guidelines for

specific chemicals. Navy officials state the Navy contractor for

Comprehensive Long-Term Environmental Action researched the current

federal and state cleanup standards for each site but did not note a

specific problem with any standards.

Staffing Unlike mainland installations, Pacific Division and Pearl Harbor Complex

officials told us they are generally able to hire, train, and retain qualified

people. Staffing for the Environmental Division, Pacific Division, has more

than doubled in the last 5 years to 65 persons, of which 18 are designated

for the IRP, because the Navy pays more than the city and county of

Honolulu and the state. In addition, because most of the environmental

work is done through the Pacific Division, which handles most of the naval

installations in the Pacific Ocean area, the Navy is able to provide higher

grades to its workers than the state or other services. The limited number

of staff (four) that have left so far, have gone primarily to private industry.

However, officials noted that they could use more specialized training in

areas such as soil assessment and data validation.

The Navy ensures cleanup is being accomplished in the most cost-effective

manner with four organizations. The Pacific Division, Navy Facilities

Engineering Command, is the focal point for Complex activities, provides

technical expertise to the Restoration Advisory Board, assesses cleanup

options, distributes DERA and Navy environmental funds, and provides

legal advice. The Commander of the Naval Base chairs the Restoration

Advisory Board and is the environmental coordinator who ensures

consistency of policy with state regulators, facilitates policy distribution

and resolution of disputes between field activities, and is in charge of

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Pearl Harbor Naval Complex Case Study

community relations. The individual field activities have primary

responsibility for compliance and own the land. The contractor provides

environmental study/evaluation support.

Regulatory Agency

Staffing

At the time of our visit, officials from the state’s Department of Health, the

primary regulator, stated that the Department was severely understaffed to

perform oversight on both government and privately owned sites and

therefore they had focused on private industry where they felt they could

get more accomplished. Since April 1994, the Department has hired what it

considers to be an adequate number of staff to do the oversight work.

They stated that they do not have a problem with the Navy’s efforts

because of the good working relationship that they have had since they

were able to obtain the needed staff.

Navy officials, however, told us that based on EPA’s lack of timely response

to routine reports from the installation, EPA may have been understaffed.

At the time of our visit in 1993, officials from EPA’s Region IX Office told us

that because of the very large number of NPL sites in its region and the

limited number of staff, they could not accomplish all of the oversight

work required for installations on the NPL. As a result, they were doing

little oversight of non-NPL installations. In subsequent information

provided in October 1994, EPA officials stated that their staffing situation

had improved and they were providing the required oversight for federal

facilities on the NPL.

Funding Navy officials told us that there is a funding shortage for the IRP for all

installations. However, the Complex does not have a funding problem

because it is on the NPL and receives funding priority. According to Navy

officials, there is adequate funds available to investigate and clean up the

Complex. Pacific Division evaluates each site separately to determine

which site will get DERA funding based on the threat to human health and

status of remediation projects. For sites that may require remedial or

removal actions, the Navy uses the Defense Priority Model score to

prioritize funding. The Pacific Division prioritizes sites based on the Chief

of Naval Operations’ funding policy, which is to fully fund only those sites

on the NPL or subject to legal time frames set under federal, state, or local

regulations.

Navy officials stated that an entire installation could be designated an NPL

site and get priority funding, even if only one site on the installation is a

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Pearl Harbor Naval Complex Case Study

“worst” site. Such funding disparities could result in less critical sites

receiving funding when more critical sites at another installation that is

not on the NPL does not. As a result, Pacific Division and Pearl Harbor

officials do not believe all of the sites on the installation should be

included in the NPL designation.

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Appendix VI 

Schofield Barracks Case Study

Schofield Barracks, established in 1908 for the Army’s mobile defense of

Oahu, is the largest and most populated installation in Hawaii. As the

headquarters of the 25th Infantry Division and the 45th Support Group, its

mission is to provide administration, training, and housing facilities for

these two units, as well as depot and repair facilities for helicopters,

trucks, and other support equipment; a medical facility; and community

and housing support. Training includes firing and nonfiring activities.

Schofield also provides administrative support, including environmental,

to several smaller Army activities in Hawaii.

Listing on the NPL TCE contamination was found in Schofield’s drinking water wells in 1985.

These wells extract water from one of the few large groundwater aquifers

on the Island, which discharges into the larger Pearl Harbor Aquifer. The

TCE source is not known, but tests are being conducted. The presence of

TCE at 40 ppb in one of the wells, which was above EPA’s maximum

contaminant level of 5 ppb, was the reason Schofield was placed on the

NPL in September 1990. The Hazard Ranking System score was 28.9, one of

the two lowest scores for any DOD installation on the NPL.

Army officials initially disagreed with EPA’s decision to place the

installation on the NPL because there was no conclusive evidence

indicating Schofield was the source of the TCE contamination. They cited

suspected sources such as a small industrial area off the installation near

the water wells. However, additional study indicates the installation’s

landfill, other sites on the installation, and Wheeler Army Airfield

(formerly Wheeler Air Force Base) could also be sources.

Status of the IRP Schofield has sites in various study and remediation phases, including the

early phases. An August 1990 Army study identified and scored potential

hazardous waste sites on the installation. The study was the basis for the

sites specified in the Interagency Agreement. With this study, installation

officials believe they have identified the potential sites and are developing

work plans for further investigation in coordination with EPA. The

preliminary assessment/site inspection phase began for most sites during

1992. EPA has expanded the number of sites needing further investigation

to 116. Table VI.1 depicts the status of CERCLA work at Schofield Barracks.

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Schofield Barracks Case Study

Table VI.1: Status of Sites at Schofield

Barracks

CERCLA process phase

No. of sites

that reached or

will reach phase

Study 116

Interim remedial action-underway 0

Interim remedial action-complete 1

Remedial action 30

Remedial action in place and operating 1

Remedial action complete 1

Closed out-no further action 49

Although installation officials believe they have identified all of the sites, it

is possible additional sites could be found. To determine whether the

contamination is spreading off the installation, Schofield had a contractor

test private drinking water wells near the installation for contamination.

Results from these tests did not show any TCE contamination at private

wells. However, some of the wells on Field Station Kunia, a small Army

installation adjoining Schofield, have shown low levels of TCE

contamination.

In accordance with the Installation Action Plan, Schofield has established

four operable units and set priorities. DOD and EPA officials state that this

process will ensure the most contaminated sites or those posing the most

imminent danger get funding and cleanup priority. The installation also

plans to have a risk assessment of all hazardous waste sites.

Cost The Army has spent over $17 million to study and solve the contamination

problems at Schofield Barracks. The Army and EPA had different

approaches for cleaning up the installation. EPA’s procedures called for

(1) a more comprehensive study and testing program, (2) more work on

determining if the treatment of the drinking water as it is used will work,

and (3) more testing for contaminants during cleanup actions. It also

wanted the Army to consider testing for the full range of contaminants at

the landfill. The Army believed the current system to treat the drinking

water was adequate and more testing was not needed. There were two

cost estimates—$65.7 million for the Army’s proposal and $142.1 million

using EPA’s procedures.

Subsequent to our visits, Schofield officials told us that EPA Region IX

agreed to the Army’s proposal that the treating of the groundwater as it is

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Schofield Barracks Case Study

pumped for use will provide adequate protection to those using the water.

Further remediation of the groundwater would not be required.

Schofield officials believed EPA was not aware of the high cost of

environmental restoration work in Hawaii. For example, EPA wanted the

installation to drill a grid of at least 120 test wells to determine the TCE

contamination source. According to Schofield officials, the cost for a test

well on the mainland is about $50,000 to $100,000, whereas in Hawaii, the

cost is about $400,000 for each well because the geological formations are

unusual and the groundwater is about 800 feet deep. Thus, the total for the

120 test wells would be $48 million.

Schofield officials said that the cost to determine the extent of the

contamination plume could be significantly higher than the $48 million,

but they did not have an estimate they were willing to provide us. Any

remediation cost for items such as constructing the pump and treat system

and the testing that would be a part of the project would be additional. The

current cost estimate for a planned limited remediation—contaminant

removals from known sites, landfill investigative work and long-term

monitoring, installation of a limited number of test wells, and the study of

drinking water wells surrounding the installation—is $21 million, less than

half the cost of drilling the test wells.

Installation officials state that they follow the feasibility study procedures

outlined in EPA’s guidance. Cost is considered, but it is not an overriding

factor. They are focusing the IRP to target cost-effective cleanups early so

the investigation can be concise and cost-effective. EPA has not agreed

with all of the installation’s focusing initiatives.

Options Considered When TCE was found in the drinking water wells in 1985, the Army chose to

treat the water as it was used, basing its decision on two factors. One, it

would be impractical to remediate an aquifer by the pump and treat

method because it is 800 feet deep, the aquifer discharges to the Pearl

Harbor aquifer at a rate of 115 million gallons per day, and the aquifer is

contained in an unusual geological structure under Schofield. Two, the

cost of providing the database to support such a pump and treat

remediation of the aquifer would be extremely high. The Army stated that

its system to treat the water as it is used, to less than 1 ppb for TCE, has

been in use for 7 years. It cost about $3.7 million in 1985 to build the

treatment plant and costs about $50,000 a year to operate and maintain it.

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Schofield Barracks Case Study

The Army believes the same approach could be used locally or by the city

of Honolulu.

EPA favored the use of a pump and treat system that would remove TCE

from the groundwater and return treated water to the aquifer. EPA did not

believe the Army Environmental Center had done enough testing to prove

that Schofield’s current water treatment system worked and there was no

documents to support the Army’s position. To obtain the needed data, EPA

wanted the installation to investigate all known potential sites to

determine the TCE contamination source, and then to clean up the sites.

The Army’s cost estimate to install and operate the pump and treat system

and perform the required sampling and testing over a lengthy period of

time was several hundreds of millions of dollars.

The installation, the major command, and the Army Environmental Center

resisted this idea. They believed the current water treatment system would

be the most cost-effective way to supply uncontaminated drinking water.

According to Schofield officials, subsequent to our visits, EPA agreed that

the point of use system would be the final remediation required. Currently,

the stripper reduces the amount of TCE in the drinking water from 40 ppb

to less than 1, which is below the maximum contaminant level of 5 ppb.

Option Selected Although final decisions have not been reached, both EPA and Army

officials believe progress is being made. They agree on the following key

issues.

• The highest priority is finding the source of TCE contamination and

cleaning it up.

• The groundwater should be treated at the point of use.

• The procedures that consider a full range of containment and monitoring

options for the largest site, a former landfill, have been streamlined.

• Remediation will focus on the 12 worst sites. An additional 34 sites will

continue in the remedial investigation phase and no further work will be

required at 70 of the 116 sites.

Schofield officials said that the state has not assessed these issues and as a

result, have not taken a position regarding the EPA/Army agreement.

Page 49 GAO/NSIAD-95-8 Environmental Cleanup
Appendix VI 

Schofield Barracks Case Study

Expected Completion Installation officials state that the current schedule calls for remedial

action to be completed by fiscal year 1996. They estimate that long-term

monitoring will continue beyond this date.

Regulatory Process Installation officials believe the CERCLA process has inhibited timely

cleanup at Schofield Barracks. The CERCLA process requires the installation

to conduct studies and submit a draft report to EPA, which has 60 to 90

days to review and comment. The installation has from 15 to 45 days to

review EPA’s comments and respond with a final draft report. EPA then has

30 to 45 days to approve the report. During the process, either party can

request time extensions for further work. This review process, however,

slows down the CERCLA process because it has to be done for every plan

and report prepared under the Interagency Agreement. In addition, each

decision point report could require more than one version of the draft and

this review process would be repeated for each version.

They believe the study phase is prolonged by the requirements agreed to in

the agreement. If the agreement is followed step by step, it ties the

installation’s hands in getting sites cleaned up using contaminant removal

actions. Agreements were once site specific, but now they predominantly

cover the installation from fence to fence. Consequently, all sites,

regardless of size or contaminant, are to be treated the same in the CERCLA

process.

In Schofield’s case, EPA has expanded the investigation beyond locating

and remediating TCE source(s), the basis for the NPL listing. Because most

of the sites do not contain TCE, installation officials questioned why it has

to go through the entire CERCLA process for each site. They stated that if

EPA was not so involved in the study of the smaller, less contaminated

sites, the cleanup could be completed quicker.

Schofield officials told us that EPA is involved with all the sites because it

does not trust DOD installations to do a good job. EPA officials state that if

TCE is found in one well, there is a potential for any site on the installation

to be the source of TCE contamination. Because the installation did do

some maintenance of equipment in the past and may have used TCE, EPA

expects the installation to do all of the CERCLA required work at all of the

sites, even if the site is a minor one and there is no evidence of TCE use at

the site.

Page 50 GAO/NSIAD-95-8 Environmental Cleanup
Appendix VI 

Schofield Barracks Case Study

Schofield officials state the advantages of being on the NPL are (1) the

installation receives a higher funding priority and (2) a mechanism is in

place to facilitate the completion of cleanup.

DOD/Regulatory

Agency Cooperation

Installation personnel spend a lot of time working with the regulatory

agencies to get the work done. They state there was very little

communication and cooperation in the early stages of the IRP, especially

when deciding on what to do to clean up the drinking water. EPA and the

Army Environmental Center officials told us that they believed that this

disagreement caused delays in the cleanup. EPA and the Army

Environmental Center, with assistance from the installation, have initiated

a more cooperative effort to determine what needs to be done to

remediate the contamination from the installation.

The Interagency Agreement provides for EPA to set up a “project manager”

to oversee the installation’s IRP. According to installation officials, there

have been some disagreements that have slowed down the work.

Cleanup Standards Schofield officials said that a single standard for each chemical would be

very helpful and could reduce investigative costs. However, to protect the

most sensitive environments and populations, those standards could

translate to higher remediation costs. This may not be realistic, but there

should be some way for determining what has to be done at each site

using a standard procedure. Having different procedures for determining

standards for the same contaminant is not practicable.

Army officials stated that EPA would be the most logical source of

standards to provide nationwide coverage; however, its input would have

to be tempered by real-world practicalities of conducting cleanups. Also,

EPA headquarters would have to bring regional offices into line with a

central policy; the 10 regions currently set their own policies, which makes

standardization extremely difficult.

Installation officials stated that Hawaii does not have any standards for

cleanup, but they believe the state’s standards will be more restrictive than

EPA’s standards. The state has not done any active enforcement at federal

facilities yet.

The installation has been working with both regulators to get them to set

standards for cleanup that are economically and technically feasible.

Page 51 GAO/NSIAD-95-8 Environmental Cleanup
Appendix VI 

Schofield Barracks Case Study

Staffing Installation and the U.S. Army Pacific Command officials told us that they

had been unable to hire and retain enough qualified people. The

installation only has one staff member (GS-12) assigned to the IRP,

1

 and he

was the only one funded by DERA. Even this individual was not hired for

the IRP, he was “stolen” from another unit on the installation. In addition to

his DERA work, he is the Safe Drinking Water Program Manager, the Noise

Program Manager, and the Historic Preservation Program Manager.

Installation officials state the IRP staffing will increase to the equivalent of

three staffyears in the near future. Until the IRP work at the sites on the

installation reaches a point where the funding priority is high enough,

staffing will not always be available. In the installation cleanup activities,

Schofield has less staff than the other two sites we visited in

Hawaii—Pearl Harbor Complex and Hickam Air Force Base. Also,

Schofield and Pearl Harbor are NPL installations while Hickam is not. The

Army’s Pacific Command, Schofield’s major command, has one

environmental engineer and his secretary working in the IRP. They are the

only ones funded by DERA.

The U.S. Army Force Integration Support Agency studied the U.S. Army

Pacific’s and the installation’s environmental staffing, including

installation restoration or CERCLA work, in May 1994. The agency found

that to adequately do all of the required environmental work, the U.S.

Army Pacific and the installation would need about 19 staff members of

which 4 to 5 would work in the IRP. At the time of the study, the Army had

eight authorized positions. Army officials told us that with the recent

lifting of the Army’s staffing freeze, and the study recommendation, they

hope to begin to fill some of the positions.

Army officials stated that all of the installations in Hawaii are competing

for each others’ environmental staffs, and these individuals are

transferring to obtain promotions or improve their careers. Under the

current staffing guidance, the Army is constantly losing people to the other

services that have higher grades for their environmental people. Table VI.2

shows that the management grade structure at the commands and the

installations is higher for the other services. Installation officials told us

that because the Navy’s and the Air Force’s management levels are higher,

they are able to have higher grades for the staff.

1

The one environmental engineer left to go to the Pacific Ocean Engineering Office. Schofield is in the

process of replacing him.

Page 52 GAO/NSIAD-95-8 Environmental Cleanup
Appendix VI 

Schofield Barracks Case Study

Table VI.2: Grade Structure for

Environmental Office Managers Activity Grade

Army Pacific Command GS-14

Schofield Barracks GS-12

Pacific Engineering Field Division Captain or

GM-15

Pearl Harbor Complex GS-13

Pacific Air Force Colonel

Hickam Air Force Base GS-13

Army Environmental Center officials told us that they recognized that

there are resource limitations at Schofield and have attempted to alleviate

the staffing shortage by helping to manage the preliminary assessment/site

inspection contract. Schofield officials told us that they do not expect the

Center to continue to supply staffing assistance. The Center’s

representatives visit the installation two or three times a year, but will

come more often if needed. Generally, there is good communication

between the installation and the Center.

Regulatory Agency

Staffing

Hawaii Department of Health officials told us that the state has provided

little oversight or input into the IRP during the early years because of

staffing shortages. According to Army and state officials, since April 1994,

when additional staff were obtained, the state has provided adequate

oversight.

In Hawaii, EPA’s Region IX concentrates its resources on NPL installations,

such as Schofield, and it does not have a staffing problem that affects

Schofield. However, by concentrating its resources on NPL sites, EPA

officials told us that it does not have enough staff to provide adequate

oversight at non-NPL installations in Hawaii, such as Hickam Air Force

Base.

Funding DERA funds are used because the installation is on the NPL. Table VI.3

shows the funds requested, received, and planned for the IRP.

Page 53 GAO/NSIAD-95-8 Environmental Cleanup
Appendix VI 

Schofield Barracks Case Study

Table VI.3: Requested, Received, and

Planned DERA Funding for Schofield

Barracks Fiscal year

Requested/

planned Received

1984 $50,000 $50,000

1991 985,380 1,005,400

1992 5,356,220 956,220

1993 8,300,000 12,330,000a

1994 10,831,000

1995 9,000,000

1996 9,600,000

1997 700,000

aIncludes $4,400,000 not received in fiscal year 1992.

According to U.S. Army Pacific Command and installation officials, the

fiscal year 1991 DERA funds were received early enough to conduct the

program on schedule. The delay in getting $4.4 million of the $5.4 million

requested in fiscal year 1992 caused the major contract award scheduled

for late fourth quarter to be deferred to the next year. The Army

designated the $4.4 million for other environmental projects that they

thought had higher priorities.

Installation officials stated that the Army and DOD headquarters questioned

the level of funding projected to conduct the remedial

investigation/feasibility study and remedial actions because of the low

Hazard Ranking System score and the lack of a direct link between the TCE

contamination and the Schofield sites. The major command and Army

headquarters have also questioned the need to fund all of the CERCLA work

being done at some of the minor sites on the installation.

Installation officials stated that a problem with funding is the untimely

receipt of the funds. It is difficult to execute contracts when the money is

not received until the last quarter of a fiscal year. For example, in fiscal

year 1992, the installation struggled to execute projects to use the funds

allocated during the early part of the year. It became even more difficult to

use the year-end funds because the installation received the money when

it had less than 6 months to get contracts signed. If contracts are not

signed, the installation has to return the money to the Army

Environmental Center and renegotiate the contracts the next year, if the

installation receives the funds.

Page 54 GAO/NSIAD-95-8 Environmental Cleanup
Appendix VI 

Schofield Barracks Case Study

Installation officials stated that year-end money received does not follow

the normal planning, design, and contracting procedures or adhere to

project priorities. The project that is closest to having a contract signed is

the one funded, which sometimes is not the highest priority project. In

addition, the Pacific Ocean Division’s engineers are tied up with other

projects using year-end money. As a result, needed support services may

not be available and thus, the projects may not be fully planned and

engineered. The Army shares the Pacific Ocean Division’s engineers with

the Air Force for technical and engineering.

Installation officials stated that if the installation is allowed only a short

time to execute the contracts to accomplish the projects, the whole

process needs to be streamlined so that the work can be done with proper

planning. They said the installation needs more than 3 months to spend

dollars efficiently and properly execute the contracts and as a result get

work completed earlier. If the system is not streamlined and some of the

study process and testing eliminated, the total remediation project could

cost $100 to $200 million.

The short time to get the contracts signed causes the projects to be spread

out because the installation has to cover more than one window of

opportunity: one for scoping and study, one for negotiating and

contracting, and another for the remedial action.

Page 55 GAO/NSIAD-95-8 Environmental Cleanup
Appendix VII 

CERCLA Process

Preliminary

Assessment

The initial stage of the cleanup program is an installation wide study to

determine if sites are present that pose hazards to public health or the

environment. Available information is collected on the source, nature,

extent, and magnitude of actual and potential hazardous substance

releases at sites on the installation.

Site Inspection The next step consists of sampling and analysis to determine the existence

of actual site contamination. Information gathered is used to evaluate the

site and determine the response action needed. Uncontaminated sites do

not proceed to later stages of the process.

Remedial

Investigation

Remedial investigation may include a variety of site investigative,

sampling, and analytical activities to determine the nature, extent, and

significance of the contamination. The focus of the evaluation is

determining the risk to the general population posed by the contamination.

Feasibility Study Concurrent with the remedial investigations, feasibility studies are

conducted to evaluate remedial action options for the site to determine

which would provide the protection required.

Remedial Design Detailed design plans for the remedial action option chosen are prepared.

Remedial Action The implementation of the chosen remedial option is implemented.

Interim Remedial

Action

Remedial actions can be taken at any time during the cleanup process to

protect public health or to control contaminant releases to the

environment.

Remedy in Place and

Functioning as

Intended

The remedial action is functioning properly and performing as designed.

These include such actions as the operation of pump and treat systems

that will take decades to complete cleanup.

Page 56 GAO/NSIAD-95-8 Environmental Cleanup
Appendix VIII 

Scope and Methodology

The six installations selected for this supplement were chosen because

either your office expressed interest in the installation or they were

representative of the problems, such as groundwater contamination,

encountered at the sites. To develop the information contained in this

supplement, we reviewed applicable procedures and records maintained

by DOD, EPA, and state regulatory agencies. We also interviewed

environmental officials from the DOD agencies, the Army, the Navy, the Air

Force, and the Defense Logistics Agency at the headquarters level in

Washington, D.C.; at major military commands, engineering field divisions,

and service organizations; selected installations; state regulatory agencies;

and EPA headquarters and regional offices. We reviewed applicable files

and documentation at Washington headquarters offices, command level

offices, the installations, state regulatory agencies, and EPA headquarters

and applicable regional offices, including such pertinent documents as

Interagency Agreements.

Data gathered for the primary report on the installations were used for

these case studies. We updated the information when available.

Army Headquarters offices

Army Materiel Command

U.S. Army Pacific, Honolulu, Hawaii

Army Environmental Center, Maryland

Aberdeen Proving Grounds, Maryland

Fort Lewis, Washington

Fort Sill, Oklahoma1

Fort Wainwright, Alaska

Letterkenny Arsenal, Pennsylvania

Rocky Mountain Arsenal, Colorado

Schofield Barracks, Hawaii

Navy Headquarters offices

Naval Facilities Engineering Command

Chesapeake Engineering Field Division

Pacific Engineering Field Division

Southwest Engineering Field Division

Naval Surface Warfare Center, Dhalgren, Virginia

Pearl Harbor Naval Complex, Hawaii

Page 57 GAO/NSIAD-95-8 Environmental Cleanup
Appendix VIII 

Scope and Methodology

North Island, San Diego Naval Complex, California1

Yorktown Naval Weapons Center, Virginia1

Air Force Headquarters offices

Air Force Center for Environmental Excellence, Texas

Air Force Materials Command, Ohio

Hickam Air Force Base, Hawaii1

Kelly Air Force Base, Texas1

Mather Air Force Base, California

McChord Air Force Base, Washington

McClellan Air Force Base, California

Tinker Air Force Base, Oklahoma

Vance Air Force Base, Oklahoma1

Marine Corps El Toro Air Station, California

Tustin Air Station, California

EPA Headquarters offices

Region III, Philadelphia, Pennsylvania

Region VI, Dallas, Texas

Region VIII, Denver, Colorado

Region IX, San Francisco, California

Region X, Seattle, Washington

Environmental Protection Agency Environmental Research Laboratory,

 Oklahoma

State Regulatory Agencies Alaska

California

Pennsylvania

Oklahoma

Texas

Virginia

Washington

1

Although this is neither an NPL nor closure installation, we visited it because of unique contamination

problems, including contamination of groundwater. Data from this site was not included in our cost

and site analyses.

Page 58 GAO/NSIAD-95-8 Environmental Cleanup
Appendix IX 

Major Contributors to This Report

National Security and

International Affairs

Division, Washington,

D.c.

David R. Warren

Uldis Adamsons

Clementine H. Rasberry

Jacob W. Sprouse, Jr.

Robert G. Hammons

Robert Jones

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