United States 

Environmental Protection 

Agency

EPA505-B-99-001

January 1999

www.epa.gov/swerffrr/

Solid Waste and

Emergency Response

(5101)

4

The Assistant Deputy

Under Secretary of

Defense shares her

views on partnering

priorities.

10

Are institutional controls

more harmful than

helpful?

12

Pilot project finds trees

useful in containing and

removing contaminants.

14

EPA and DoD are

addressing new

measures to deal with

unexploded ordnance

on military ranges.

by Jerry J. Bromenshenk and Garon C. Smith

Honey bees are being used at the U.S. Army's Aberdeen Proving Ground

(APG) in Maryland to monitor environmental conditions before, during, and

after cleanup operations. Recommended as monitors of ecological and health

hazards by EPA and the National Research Council, bees are multimedia

samplers, indicators of chemical bioavailability, and assessors of the effects of

stress such as exposure to chemical emissions.

Honey bees have the ability to pick up chemical residues. As they forage, bees collect

bioavailable contaminants. During good weather, tens of thousands of bees forage daily from each

hive. They bring back pollen and nectar for food, water for drinking and evaporative cooling, and

anything that electrostatically clings to their body hairs. The bees return to their hives each night;

thus hives can be sampled for the presence of environmental contaminants and measured to

determine the effects of these substances on a colony's size, vigor, and activities. 

Given that a colony of bees can easily forage as far as a mile from the hive, bees provide

averaged samples for large areas. From an ecological perspective, anything adversely affecting bee

foraging might also alter the pollination of crops and the native plants that rely on bees and other

insects. From a human health perspective, toxic environmental chemicals readily available to bees

also might pose a hazard to people. In Milltown, Montana, for example, after losses of bees in

nearby commercial apiaries alerted officials of environmental contamination, children were found

to have unacceptable levels of arsenic in their bodies.

The Buzz on Environmental Monitoring

Federal Cleanups That Put Citizens First

<Continued on Page 6>

Volume 2 Issue 1

BreakingNews

By using state-ofthe-art

technologies and

thinking outside the box,

the Base Realignment and

Closure (BRAC) Cleanup

Team (BCT) at Loring Air

Force Base saved millions of

dollars in cleanup costs. The

base, located on approximately 9,000 acres in

Maine near the Canadian border, supported

long-range bomber aircraft for the Strategic Air

Command for more than 50 years. Base activities

included aircraft maintenance and refueling,

munitions storage and maintenance, and flightline operations. 

Over time, these activities contaminated soil,

sediments, groundwater, and surfacewater. By

1990, the base was listed on EPA's National

Priorities List (NPL). In 1994, the base was closed

and a BCT, consisting of representatives from the

U.S. Air Force, EPA Region 1, and the Maine

Department of Environmental Protection,

assumed cleanup tasks. 

Celebrating

Success

<Continued on Page 15>

Loring Cleanup Paves the Way for Economic Growth
2Partners In Progress

Working Together to Build Policy

and Improve Cleanup

by Jim Woolford, Director of FFRRO

Welcome to our second issue of Partners In

Progress. As this newsletter provides a

forum for all parties to be heard, we are

thrilled to include articles by some of our

partners who have taken the opportunity to share information

and discuss innovative approaches for improving cleanup and

reuse. Karla Perri, the new Assistant Deputy Under Secretary

of Defense for Environmental Cleanup at the Department of

Defense (DoD), shares her take on DoD partnering efforts. We

welcome Karla and look forward to working with her on the

myriad issues confronting DoD's cleanup programs. Lenny

Siegel, director of the Center for Public Environmental

Oversight, is a major advocate for improving cleanup and

stakeholder involvement. 

Message from the

Editor

Outreach Activities Vital to Progress

Partners In Progress is just one of FFRRO's many

initiatives to connect with stakeholders and engage

citizens in the cleanup process. Other outreach

activities include producing educational materials,

supporting workshops, giving public presentations, and

participating in conferences.

Through such activities, FFRRO forges new links for

improving cleanup and reuse. We can achieve more by

developing a network of contacts, forming partnerships,

and leveraging resources. In doing so, we often strengthen

efforts of other programs as well.

FFRRO's participation in the Brownfields ’98 Conference

in Los Angeles last November provides a good example of

how we work proactively to establish new links with

stakeholders. Sean Flynn, FFRRO's brownfields coordinator,

and I hosted an exhibit where we spoke with

representatives from consulting firms, the U.S. Department

of Energy (DOE), EPA regional offices, and citizen advisory

boards. 

We also had the opportunity to describe the benefits of

our program with people unfamiliar with FFRRO. During

these discussions, Sean and I explained that federal facilities

and brownfields face similar challenges and must comply

with the same environmental laws. Further, because federal

properties often encompass hundreds of acres and have

large infrastructures, their cleanup and reuse can play a

pivotal role in economic revitalization at nearby

brownfields. For these reasons, partnerships between federal

facility and brownfield stakeholders can be significant.

Sean and I informed participants about how to network,

leverage resources, and share information. We also offered

to help participants identify federal facility contacts in close

proximity to their sites. Outreach efforts such as this are

vital to the progress of our program.

Deborah Leblang is FFRRO’s outreach coordinator and

editor of Partners In Progress.

Deborah Leblang (center) and Sean Flynn (right) talk

about federal facility cleanups with a conference participant.

FromTheDirector

Partners In Progress

Philosophy

Stakeholders involved in federal facility cleanups are

diverse, with differing backgrounds, interests, and

perspectives. All of these stakeholders, however, share a

single, common goal—progress. Partners In Progress

provides an open forum for stakeholders to exchange

information, offer solutions, and share stories about

what works and what doesn't. We encourage you—our

readers—to write to us about your activities that foster

teamwork, promote innovation, and strengthen

community involvement. Only by working together, can

we achieve "federal cleanups that put citizens first."

Articles written by non-EPA authors do not necessarily

reflect the views, positions, or policies of the Agency.

<Continued on Page 3>
3Partners In Progress

Partners In Progress is produced by FFRRO at EPA

Headquarters; however, it reflects the achievements of EPA

regional offices as well. EPA has much to be proud of when it

comes to the accomplishments of regional federal facility and

base realignment and closure (BRAC) cleanup programs.

Without their extraordinary efforts, FFRRO could not have

pushed cleanups forward, identified ways to save time and

money, and created the impetus to involve stakeholders in the

cleanup process.

Not only do we look to EPA regional offices to implement

cleanup programs, we rely on them to help craft policies and

inform our judgements. The principal groups we work with

are the Federal Facility Leadership Council (FFLC) and the

Federal Facilities Forum, or "Fed Forum." The FFLC is

comprised of regional federal facility program managers and

legal counsels and EPA Headquarter's two main federal facility

offices—FFRRO and the Federal Facilities Enforcement Office

(FFEO). The FFLC is chaired by myself, Craig Hooks (director

of FFEO), and Mary Sanderson and Joan Miles of EPA Region 1.

Productive regional involvement allows us to use the FFLC as

the major internal "sounding board" in policy deliberations. 

The Fed Forum also provides substantial direction to our

policy making. It is comprised of Federal Facility/BRAC

Remedial Project Managers (RPMs) who work day-to-day at

cleanup sites. They serve as our eyes and ears on issues such

as monitored natural attenuation and UXO. Both the FFLC and

the Fed Forum have been invaluable to our program.

FFRRO currently is calculating the annual performance of

the federal facility and BRAC programs. A preliminary

evaluation indicates that more than 90 Records of Decision

were signed; 17 facilities reached the "all remedies

constructed" phase of site cleanup; and 9 facilities were

removed from the NPL.

While much work still remains, these accomplishments

represent tremendous progress in cleaning up federal

Superfund sites. I commend both the EPA regions and our

federal partners in realizing these achievements.

Hanford: A Cleaner Future

U.S. EPA, Solid Waste and Emergency Response

EPA505-F-98-006, July 1998

As many people know, the Manhattan Project

involved the building of the world's first atomic

weapon. Now, you can learn how various groups have been

working during the past 10 years to clean up the site that first

produced plutonium for the top secret project. A new fact

sheet, Hanford: A Cleaner Future, describes the achievements

and challenges of the world's largest environmental cleanup

project and probably the most long-term effort of its kind. The

fact sheet tells how representatives of EPA, DOE, the

Washington State Department of Ecology, Native American

tribes, and citizens' groups are searching for ways to achieve an

accelerated and cost-effective environmental cleanup. 

To obtain a copy of Hanford: A Cleaner Future contact

Deborah Leblang of EPA's FFRRO office by e-mail at

<leblang.deborah@epa.gov> or by calling 202 260-8302. The

fact sheet also can be viewed at <www.epa.gov/swerffrr/

success/hanford.htm>.

Accelerating Cleanup:

Paths to Closure

U.S. DOE, Office of Environmental Management

DOE/EM-0362, June 1998 

Compiled by DOE's Environmental Management (EM)

Program, this report describes progress in the cleanup of 353

projects at 53 separate DOE sites located in 22 states across

the country. Most of these sites were established during the

early days of the Cold War for research, development, testing,

and production of nuclear weapons and a variety of nuclearrelated research projects. 

In addition to remediation activities at specific sites, the

report details the background and mission of the EM program;

the six phases of the decision-making process; cost projections;

and stakeholder, regulator, and tribal nation involvement.

A copy of the book can be obtained by calling 

800 736-3282 and requesting document number 

DOE/EM-0362. This document also is available on the Internet

at <www.em.doe.gov/closure/>.

An Analysis of Composting 

as an Environmental Remediation

Technology

U.S. EPA, Solid Waste and

Emergency Response

EPA530-R-98-008, April 1998

Composting is viewed primarily as a waste management

technique that has the added benefit of enriching soil.

Composting also has proven effective in helping to efficiently

and inexpensively manage hazardous waste contamination.

This report details the benefits and processes of innovative

applications of composting in remediation efforts. Chapters

include data on the use of compost in hazardous waste

management; degradation of toxic organic soil compounds;

application techniques; biofilter use; brownfields reclamation;

and phytoremediation. These innovative composting

applications and their results are gaining attention for the

effective cleanup of federal facilities.

To receive a free copy of the report, call 800 490-9198 and

request document number EPA530-B-98-008. This report also

is available on the Internet at: <www.epa.gov/ epaoswer/nonhw/compost/index.htm#analysis>.

Hot Off the Presses

From the Director <continued from page 2>
Partnering: A Priority in the New Year

by Karla Perri, Assistant Deputy Under Secretary of Defense (Environmental Cleanup)

4Partners In Progress

Since joining DoD, I have taken on the challenge

of partnering. One of my main priorities for

1999 will be expanding and improving the

quality of DoD's partnering activities. DoD's

partnerships with environmental regulatory agencies,

communities, Native Americans, and industry are

essential to ensuring the success of our

environmental restoration activities. DoD has been in

the business of environmental restoration for well

over a decade now, and partnering has been

instrumental to our efforts.

The passage of the Superfund Amendments and

Reauthorization Act (SARA) by Congress in 1986

formalized the preexisting Defense Environmental

Restoration Program and established the Defense

Environmental Restoration Account to fund DoD's

cleanup efforts at operational installations and

Formerly Used Defense Sites (FUDS). Later, BRAC

laws created the BRAC account to pay for

environmental restoration work at BRAC installations.

While SARA granted authority and provided funding

for DoD's environmental restoration program, it also

brought additional changes and uncertainty, especially

regarding listing on the NPL, Interagency Agreements,

and the relationships among DoD, EPA, and the

states. With thousands of sites in need of remediation,

and millions of dollars in the balance, DoD soon

realized productive working relationships had to be

established and nurtured. The department, therefore,

created several partnership arrangements to foster

innovation and build teamwork and consensus among

our stakeholders. 

Our oldest and most successful partnering activity

is the Defense and State Memorandum of Agreement/

Cooperative Agreement (DSMOA/CA) program. This

program, established in 1989, facilitates active state

and territory regulatory agency participation in DoD's

environmental cleanup program, with the expectation

of expediting cleanup at our operational and BRAC

installations and FUDS. States and territories are

reimbursed for technical services provided in support

of DoD environmental restoration activities. The end

result has been improved relations among the states

and territories, military services, and defense

agencies. To date, 48 states and territories have

entered into DSMOAs with DoD. Between 1990 and

1998, more than $2 billion in cost avoidances have

been documented.

Issues stemming from our DSMOA program have

encouraged our partnership with the Association of

State and Territorial Solid Waste Management

Officials. We meet frequently, usually quarterly, to

discuss a variety of issues of mutual interest. Some

issues are general, such as improving the cleanup

process and assessing the scope of UXO clearance.

Other issues are more specific, such as the

association's participation in our 1997 effort to

"reinvent" the Defense and State Cooperative

Agreement process.

Another example of our partnerships with state

regulatory agencies is our association with the

Environmental Council of States. In 1996, we created

a permanent forum with the council to share

information and address specific issues of mutual

concern. Through this alliance, the senior leadership

of DoD and the states have the opportunity to

exchange ideas, views, and experiences, which serves

to foster cooperation and coordination in

environmental policy development and management.

With the advent of BRAC in 1988, it was evident

that quick, efficient cleanups would be essential to

community economic development and revitalization

and to property transfers in communities. To

accomplish these cleanup goals, BCTs were

established at our BRAC installations where property

would be made available to the community. The

intent of the BCT concept is to foster partnerships at

the installation level so decisions are made on a

collaborative basis to speed cleanups. We also have

been supporting EPA participation in BCTs by

providing staff and funding resources.
5Partners In Progress

On the community level, Restoration Advisory

Boards (RABs) are a means to promote individual

citizen input into our decision-making processes.

There are 332 installations participating in the

advisory board process across the United States and

its territories, which creates a forum for members of

nearby communities to provide input to DoD's

environmental restoration program. Sharing

information and providing tools is another facet of

partnering we take very seriously.

Partnering with tribal nations in government-togovernment relationships is another important part of

DoD's partnering efforts. Over the past two years, we

have been working in close consultation with

federally recognized tribes to develop a DoD Native

American Environmental Policy. Our efforts have been

very successful, and we expect to have a final policy

in place by spring 1999. Another example of our

government-to-government relationship with tribes is

the cooperative agreement initiative to provide a

robust role in environmental mitigation activities on

their lands. Under this initiative, a cooperative

agreement mechanism provides funding for the

specific technical services to be performed that are

agreed to by DoD and the tribe. We currently have six

such agreements in place.

Some of our partnership efforts are more narrowly

focused. For instance, we have been funding and

participating in the development of the Interstate

Technology and Regulatory Cooperation (ITRC)

Workgroup. In simple terms, the ITRC is a state-led

national coalition with the mission of creating tools

and strategies to reduce interstate barriers to the

deployment of innovative hazardous waste

management and remediation technologies. Developed

in 1995 from a previous initiative by the Western

Governors' Association, ITRC has expanded to include

more than 25 states, three federal partners, public

and industry stakeholders, and two state

associations—the Western Governors' Association and

the Southern States Energy Board. To date, ITRC has

developed 22 guidance documents intended to help

regulatory staff and technology vendors in the

deployment of innovative technologies. We work

closely with ITRC to ensure our technology priorities

are compatible with that of ITRC and integrated into

the ITRC work plan. We provide funding and offer

our sites as demonstration projects for the many

innovative technologies under study.

Partnering continues to be one of DoD's most

successful initiatives and has resulted in millions of

dollars in avoided costs, the acceleration of many

cleanup projects, and enhanced teamwork with our

stakeholders. As an example, the cooperative efforts

of the BCTs and RABs eliminated 59 years of project

work and avoided $60 million in costs. If done

correctly, partnering helps all parties with a stake in

environmental restoration to better understand each

other, leading to cleanups that satisfy the majority of

stakeholder concerns and resulting in faster, cheaper

cleanups that protect human health and the

environment. 

During my tenure, I will continue to enhance

existing relationships between DoD and our partners,

and seek out new ways in which we can team with

other stakeholders in carrying out DoD's

environmental restoration obligations. To learn more

about DoD's cleanup efforts and our initiatives, such

as RABs, I invite you to visit the DoD Environmental

Cleanup Home Page at <www.dtic.mil/

envirodod/>.

Partnering continues to be one of DoD's most successful initiatives

and has resulted in millions of dollars in avoided costs, the 

acceleration of many cleanup projects, and enhanced teamwork 

with our stakeholders.
Honey Bee Monitoring of Chemical 

Releases at APG

A team of scientists from the University of Montana, the

U.S. Army's Center for Environmental Health Research, and

APG's Installation Restoration Program, continually monitor

bees at APG to study the impact of the Army's past and

current activities on the site's air quality and terrestrial

environment. 

Twenty-one electronic hives, outfitted with infrared

counters, were installed at APG. They track bee flight

activity, counting bees as they leave and enter the hive.

Temperature probes inside each hive follow the ability of

the bees to maintain a constant temperature to incubate

their young. These electronics and other features, such as

pumps for chemical sampling, gather and transmit data to a

central processing system that, within minutes, delivers the

data to any place around the globe via the Internet. The

system detects and immediately reports anomalies in bee

behavior that might signal exposure to toxic contaminants.

This real-time monitoring provides an early warning of

changing environmental conditions so that appropriate

action can be taken. It also supplies a means of monitoring

and determining the success of a site cleanup or

remediation action such as the capping of a toxic dump. 

In the past, chemical warfare agents, munitions, UXO,

and wastes from industrial and research plants were

landfilled in many areas at APG. The Army now is removing

these materials, where possible, and capping larger landfills.

Continuous monitoring of bees has been used to identify

possible chemical releases during removal activities at APG's

West Branch Canal Creek (WBCC), 

J-Field, and Carroll Island sites. Bees also have been

released at the Old O-Field and J-Field to profile conditions

before, during, and following landfill capping. 

At WBCC, for example, where a chemical weapons plant

had been removed, bee flight activity was high, colony

condition good, and only trace levels of solvents, such as

perchloroethylene (PCE), occurred in the hives. For three

summers, the colonies at WBCC were indistinguishable

from those at a reference site in rural Churchville,

Maryland, indicating the effectiveness of the cleanup

actions. During landfill capping efforts at Old 

O-Field, in 1996, bee flight activity was low, queens

disappeared, and hive temperatures began fluctuating in

more than half of the colonies. These behavioral anomalies

coincided with very high levels of PCE in the affected hives.

During the two years following the installation of the cover,

bee behaviors reflected a more normal state and the levels

of PCE dropped. The bees enhanced hazard evaluation by

signaling an initial release and then verifying a reduction in

bioavailable PCE following the capping. Bees still are on the

job at the J-Field landfill where digging and capping actions

are ongoing.

Honey bees in small, nonelectronic, minihives also are

being used to survey a large number of sites at APG not

previously evaluated for chemicals in the air or terrestrial

environment. Additionally, bees are being used to survey

boundary areas including 12 sites in the residential

communities surrounding the APG Edgewood area. For this

form of monitoring, the bees, pollen, air inside the hive,

and ambient air are periodically sampled. Colonies are

inspected to assess overall condition. 

Real-time monitoring of bee

colony activities and

conditions can be an integral

part of early identification of

environmental threats.

Breaking News

<Continued From Page 1>

6Partners In Progress
In addition to APG, trace levels of solvents have appeared

in beehives in three nearby Maryland counties. Although

these same solvents do not appear in comparable hives in

Montana, automobile repair shops, other local industries,

and agricultural applications, not APG, appear to be the

primary source of many of the hazardous chemicals. Low

levels of chemicals derived from tear gas and explosives are

found only in some of the hives on the grounds. Finally,

although the levels of toxic metals are slightly elevated in

bees and pollen at some APG locations, none of these hives

displayed the toxic levels of metals often found in bees in

comparable hives in ore mining and smelting regions of

Montana. 

To date, the chemical monitoring of hives has

demonstrated a high degree of correlation to standard

chemical monitoring. Large areas can be screened quickly

and relatively inexpensively, indicating where to focus more

stringent remediation techniques. Real-time monitoring of

honey bee colony activities and conditions can be an

integral part of the effort toward the early identification of

environmental threats so corrective action can take place.

For more information on honey bee monitoring,

including the development of microchips for tracking of

individual bees, contact Dr. Jerry Bromenshenk (University

of Montana) at 406 243-5648; e-mail <jjbmail

@selway.umt.edu> or visit the Web site at <www.umt.edu/

biology/bees>.

Jerry J. Bromenshenk, Ph.D, is adjunct professor with the

Division of Biological Sciences at the University of

Montana-Missoula. Garon C. Smith, Ph.D., is associate

professor of chemistry at the University of Montana.

<www.clu-in.org>

A wealth of information

about innovative remediation

technologies is now available

at your fingertips. The

Hazardous Waste Cleanup

Information Web site,

developed and maintained by EPA's Technology

Innovation Office, describes remediation

programs, organizations, publications, and

other tools. The site is geared toward federal

and state personnel, consulting engineers,

technology developers and vendors,

remediation contractors, researchers,

community groups, and citizens. Featured on

the site are "Citizen's Guides" to various

innovative technology remedies. These guides

are written in plain English and provide

information and illustrations of technologies

being used across the country to clean up

federal and private facilities.

<www.epa.gov/year2000>

The countdown to the new millennium is

well underway. In the midst of the excitement is

the fear that computer systems will crash at the

stroke of midnight, unable to interpret the twodigit 00 year code. On this special Web site, you

can learn how EPA is safeguarding its operations

by implementing a Year 2000 (Y2K) strategy. In

addition to an outline of the strategy, the site

offers information on EPA's date standard, Y2K

assistance and guidance, compliance status of

EPA's mission critical systems, Y2K

environmental sector action plans, and much

more. The days to the new millennium

continually click down in the upper right corner

of the home page, so check it out today.

<www.cpeo.org>

Visit The Center for Public Environmental

Oversight's Web site and you'll find the

Technology Tree, an original "front end" for

researching environmental remediation

technologies. Also available on this new home

page is the organization's newsletter, Citizens'

Report on the Military and the Environment.

Visitors also can access other publications,

information on current stakeholder issues, and

a list of upcoming events. 

Cyber News

7Partners In Progress
Laura Ripley, from EPA Region

5, explains how she is

participating in the cleanup and

reuse of Rickenbacker Air National

Guard Base in central Ohio.

Q: You're currently managing the base closure and

realignment of Rickenbacker Air National Guard Base.

What's the history of this base?

A: Rickenbacker provided airfield support for the Air

Force, Ohio Air National Guard, and Army National

Guard. Installation activities included operation,

maintenance, and repair of aircraft, vehicles, and

equipment. It also was used as a training center for

pilots and carried out some pesticide spraying

missions at other bases.

Q: What contaminants are on the site as a result of these

activities and what remedies will you use to clean them

up?

A: There is a blend of contaminants that includes fuel

components, chlorinated solvents, and some inorganic

metals. They're evident in both the soil and

groundwater at certain sites on the base. Recently,

we've reviewed the draft feasibility study, a document

compiled by the Air Force, which provides a number

of alternatives to be considered for cleanup. Remedial

actions will likely include a combination of hot spot

[soil] removal and monitored natural attenuation as

well as a permeable reactive wall in one area to keep

pollutants contained. Until these remedial actions are

put in place and operating successfully, the site cannot

be considered suitable for transfer. Unless the Air

Force opts for early transfer, the base probably won't

be completely transferred until 2002.

Q: Is Rickenbacker a typical base cleanup?

A: For the most part, Rickenbacker is the norm for

environmental investigations and cleanup. The base is

somewhat unusual, however, in that it involves both a

closure and a realignment. The Ohio Air National

Guard and Army National Guard will retain 300 acres

while the remaining 1,700 acres will be handed over

to the Rickenbacker Port Authority (RPA) through a

public benefit transfer. RPA plans to use this property,

including the airfield, for a commercial industrial

airport. RPA also is trying to get related industries to

take over some of the other areas. Currently, RPA has

leased the property from the Air Force.

Q: When you transfer a base to a business that conducts

similar operations, in this case an airport, how do you

ensure the same contamination issues do not recur? 

A: Regulations for underground storage tanks have

been strengthened, requiring fuel tanks and associated

piping to be properly designed and constructed to

include spill and overfill prevention equipment. Any

underground portion of a tank that routinely contains

fuel products must be protected from corrosion.

In addition, we're taking out some of the fuel lines,

oil/water separators, and storage tanks. Fuel capacities

are being reduced, and the hazardous waste storage

areas are being cleaned up and closed down. Also, RPA

is considering upgrading the stormwater drainage

system as well. Thus, with minor changes and

alterations before reuse, new contaminants should not

be reintroduced into the environment.

FromTheField

8Partners In Progress

Team Effort Keeps Rickenbacker on Track
Q: How has partnering played a role in the cleanup at

Rickenbacker?

A: Partnering brought together the key players from

each organization involved as well as their technical

support staffs. Working together as a team has helped

prevent disagreements and thwart potential problems.

Additionally, representatives from the Air Force, state,

and EPA have not changed. Continuity of key

individuals has allowed us to develop a strong rapport

and the ability to move things forward without having

to wait for new team members to familiarize

themselves with the facility. 

Q: How has the community been involved?

A: The community has been informed of the issues

concerning Rickenbacker since 1991. Members of the

community have toured the site and are aware of the

contaminants found there. They've given some input

on cleanup and reuse but have not been heavily

involved. At this point, the RPA has been the only

nongovernment agency actively participating in the

process, attending the working team meetings, and

commenting on work plans and reports. The proposed

work plan, which is a public document on the cleanup

alternatives for the base, was published in December

1998. Following its release, the community was

informed of the actions chosen for base cleanup and

was invited to comment and offer suggestions. 

Q: What have been the challenges of cleaning up and

transferring Rickenbacker?

A: The main challenge of cleaning up and transferring

Rickenbacker has been to utilize available resources in

an expeditious and cost-effective manner. RPA wants to

redevelop the land; therefore, the project schedule has

been expedited. To accommodate this condensed

schedule, the coordination and cooperation of all

parties involved has been crucial. These strong,

cooperative partnerships have allowed the

Rickenbacker cleanup plan to proceed quickly and

efficiently.

9Partners In Progress

On Being an EPA

Remedial Project

Manager

Q: What challenges does an EPA Remedial

Project Manager (RPM) face?

A: The primary challenge of the position is

working with industry, federal facilities, and/or

the state in implementing environmental

cleanup programs. Because each entity can have

different goals and objectives, the EPA RPM

assumes the role of negotiator. RPMs try to

ensure all partners have sufficient information

on which to base their decisions when selecting

the best cleanup method. They need to select

methods that protect public health and the

environment in a reasonable time frame. 

Q: What is the learning curve for an EPA RPM

once assigned to a base closing?

A: An effective RPM must learn the ins and outs

of the base as well as its past activities and how

those activities have affected the environment.

This learning comes from extensive document

review and site visits. We learn a great deal in

the field by participating in work plan

discussions and development, environmental

investigations, field modifications, sample

location determination, and data evaluation.

Q: How many EPA staff members work on a

site?

A: In order to make informed and practical

decisions, I work with an EPA in-house technical

support staff. This group includes a chemist,

geologist, risk assessor, toxicologist, and

ecologist. An engineer also is involved during

the remedial action stage to review the design,

construction, and operation of the remedy as it

takes place.

Like the RPM, technical support members learn

about a site through document review and site

visits, as necessary. I think it's extremely

beneficial to have these experts with me at

meetings when we need to discuss issues and

come to some conclusions regarding those

issues. Tapping into that technical expertise on

the spot is invaluable. 
Institutional Controls:

The Emperor's New

Clothes?

by Lenny Siegel

Two hikers wander past a "no trespassing" sign into a

contaminated area. A public facility is built on top of

a forgotten capped landfill. These are just two

scenarios that demonstrate the potential ineffectiveness of

institutional controls. Institutional controls are restrictions

on the use of land or water, imposed by environmental

regulators and state and federal agencies, that complement

or substitute for removing or treating contamination. 

All too often, regulators choose these restrictions with

minimal stakeholder involvement and to save on short-term

expenses. In addition, they are being used more and more

on sites with contamination or UXO, which could pose

significant threats for decades. Once in place, institutional

controls are often inefficiently monitored or enforced. Like

the fabled emperor's new clothes, merely saying that

institutional controls are in place does not guarantee their

effectiveness or long-term stability. 

Sometimes, institutional controls are necessary and

unavoidable. For example, they are useful in limiting

exposure while cleanup remedies are being put in place

and before these remedies are operating effectively. In

addition, where complete cleanup is technically infeasible,

prohibitively expensive, or likely to cause irreparable

environmental damage, institutional controls might be the

only option. Beyond these situations, institutional controls

should only be used when they are reinforced by

geographic or physical reality. In an area likely to remain a

wildlife refuge indefinitely, for example, restricting

construction on a capped landfill is suitable. (Of course, the

land management agency should keep track of that landfill

if it decides to build a visitors' center or install a pipeline.)

When institutional controls are adopted, all parties

should consider ways to enforce these restrictions. Local

governments, for example, could restrict land use through

zoning and other measures that restrict specific activities

such as excavation. For property remaining in federal

hands, facility management plans should specify the

controls.

No matter what strategy is used, however, regulators

should be aware of potential loopholes. In most states, for

example, deed restriction language written into transfer

documents cannot easily be enforced against subsequent

owners. Zoning can be vetoed or changed by a city council

vote and there is no long-term enforcement mechanism.

The following simple steps can help solve these

problems:

• Memorialize institutional controls in legal

documents. For instance, restrictions can be written into

decision documents (such as records of decision and

action plans) and property transfer documents.

Properties should be subjected to overlapping

restrictions in which cleanup decision documents,

property documents (for nonfederal property), and

official plans (whether drawn up by local governments or

federal property owners) should all simultaneously

memorialize the same institutional controls.

• Establish a single registry. Many different agencies

regulate cleanup for each geographic area; therefore,

data on controls are currently fragmented and, in some

areas, simply anecdotal. Regulatory agencies can establish

a single, unified list or registry of institutional controls

imposed to limit exposure to toxic waste, radioactive

substances, and explosives. A registry would make it possible

to quantify and analyze the use of institutional controls.

• Provide easy public access to the registry. The people

who are at risk—or who care about the species at risk—

have a long-term stake in the effectiveness of controls.

Just as information on toxic releases has allowed the

public to press for increased compliance and pollution

prevention, an institutional control registry would give

public stakeholders the information they need to

monitor limitations on use and pathways.

• Require registry consultation when considering

property transfer. For properties transferred from

federal ownership, local governments should be required

to consult the registry when considering zoning changes,

building permits, and other actions that could

compromise controls. This sounds simple, but it might

be difficult for local governments to limit owners' use of

their land without compensation, particularly if the

controls were imposed by other agencies such as state or

federal environmental regulators.

10Partners In Progress
• Ensure long-term auditing and enforcement. The

federal government and/or states should establish an

agency to audit and enforce institutional controls at

affected properties. This monitoring should go beyond

the typical five-year review mandated by the Superfund

law.

• Ensure long-term protection. Property law must be

revised to ensure that institutional controls "run with the

land" forever. Sites also should not be "closed out" until

there is no longer a need for institutional controls. As

long as the protection of public health and natural

ecosystems requires limits on the use of land and other

resources, those sites and their associated restrictions

should remain on the environmental and legal "radar

screen."

Even if all the above steps are applied evenly across all

relevant jurisdictions and are backed with the necessary

long-term funding, institutional controls should still be

considered unreliable. Understandably, those responsible

for cleanups want to save money and assume restrictions

will be effective. Arbitrarily implementing institutional

controls, however, does not ensure the most effective

means of remediation. Property owners have too much

incentive to use their land to the fullest extent possible.

Others often have good reason to enter restricted property.

As time passes, there is a likelihood that even the best laid

controls will be breached.

Lenny Siegel is the Director of the Center for Public

Environmental Oversight, a program of the San Francisco

Urban Institute, San Francisco State University.

A Closer Look at Institutional Controls

Typical institutional controls used for environmental

cleanup projects include deed restrictions and zoning

ordinances. When implemented and enforced properly,

these controls protect human health and the environment

by interrupting the pathway of contamination (e.g., soil,

groundwater, surfacewater) from receptors—people, fish,

and animals. For example, if groundwater is contaminated,

an institutional control would prohibit drilling a well for

drinking water in that area. Institutional controls should

remain in place as long as the pathway continues to pose a

risk. If remediation renders the pathway safe for exposure,

however, the control can be lifted. 

11Partners In Progress

National Defense

Industrial

Association (NDIA)

25th

Environmental

Symposium and

Exhibition

March 29 through April 1, 1999

Denver, Colorado

The theme for this year's symposium is

Privatization and Outsourcing of DoD

Environmental Operations. For more information

on session topics and how to register, call NDIA

at 703 522-1820 or visit

<www.ndia.org/events/brochure/944/944.htm>

on the Internet.

The National Town Meeting 

for a Sustainable America

May 2 through 5, 1999

Detroit, Michigan

The President's Council for Sustainable

Development will host this "town meeting" to

recognize and encourage sustainable

development activities across the United States.

For more information, visit the National Town

Meeting's Web site at

<www.sustainableamerica.org>. 

UXO Forum ’99 — Strategies for

Tomorrow, Tactics for Today

May 25 through 28, 1999 

Atlanta, Georgia

Session topics for this global conference include

UXO detection, policy and regulations, case

studies, UXO clearance, risk assessment,

partnering and transitions, and more. Worldwide

UXO experts will be in attendance. For more

information, call 888 808-5303 or visit

<http://www.denix.osd.mil/denix/Public/News/UX

OCOE/Conference/Atlanta/atlanta.html>.

OnTheAgenda
by John Wrobel, Steve Hirsh, and Harry Compton

Poplar trees are turning out to be a natural choice for

cleaning up a U.S. Army site in Maryland. A stand of

184 hybrid poplars, planted in 1996, are helping to

contain toxic substances in the soil and groundwater,

through a process called phytoremediation, on the J-Field at

Aberdeen Proving Ground (APG). No ordinary field of trees,

the poplars are the subject of a five-year project conducted

by a team of representatives from EPA Region 3, EPA's

Environmental Response Team, the U.S. Army, and the

Maryland Department of the Environment, to investigate

pilot-scale applications of innovative technologies.

The J-Field site was once a pit burning location for

munitions and chemical agents. During the burning

process, large volumes of chlorinated solvents, used as

decontaminating agents, were discharged onto the ground.

As a result, a plume of chlorinated solvents, predominantly 

1,1,2,2-tetrachloroethane and trichloroethene, contaminated the groundwater in and around the burning pits in

concentrations exceeding 500 parts per million in some

areas. 

The project involved several initial steps. First, the team

collected and analyzed soil samples for levels of chlorinated

organic compounds, metals, and chloride. The soil was then

prepared by digging holes; adding fertilizers and nutrients,

such as nitrogen and phosphorous, to aid tree growth; and

mixing the soil. Next, the team planted the trees to depths

allowing coverage and data collection from the root

capillary zone during groundwater seasonal highs and lows.

Located on 1 acre southeast of the toxic pit, the trees soak

up the groundwater flowing from the contaminated area.

The team continually monitors the groundwater quality and

level using wells and lysimeters installed nearby.

Each season, the team conducts various monitoring tests.

The tests include measuring the effects of weather,

including precipitation, solar radiation, temperature,

humidity, and wind speed; tree growth measurements; soil

vapor and air quality samples; levels of metals, chlorinated

organic solvents, and degradation products in plant tissues;

sap flow; transpirational gas and condensate water; and soil

content and characteristics. The data collected help the

team determine how the trees are responding to and

influencing their surroundings.

With each sampling event, the team has observed

noteworthy results. In an ongoing test of condensate water

samples, the team recently noted a correlation between

concentrations of chlorinated organic compounds found in

condensate water and transpirational gas given off by the

trees. Further studies of this relationship will help the team

determine the trees' ability to contain and remove

contaminants. Another important test of the remediation

capability of the trees, is a study of the soil community. In a

recent sample, the team noted increased numbers and

diversity of nematode populations inhabiting the area.

These findings suggest the trees are having a positive affect

in the area. 

The team has measured the trees' groundwater intake at

rates of 2 gallons/day/tree,

with peak flows of 10

gallons/day/tree. Higher flows

are anticipated as the trees

mature. Increasing

concentrations of chemical

compounds and byproducts

in plant tissue samples during

the growing season indicate

that the trees are able to

remove more and more

toxins during this time. 

Thus far, the team has

collected increasing evidence

that supports the use of trees

for soil and groundwater

remedia-tion. The inherent

benefits of phytoremediation

at the J-Field site include low

cost, low maintenance, and

low impact, compared to

more traditional remedies

such as a pump-and-treat

system. Though additional data

and interpretations are needed

to conclusively prove its

effectiveness, preliminary

conclusions have

demonstrated that

phytoremediation is a natural

cleanup choice.

New Trees

The phytoremediation team at APG planted

new trees in November 1998. Native species,

such as silver maples and tulip poplars, were

planted to gauge their effectiveness in

containing the J-Field contaminants. Based on

lessons learned in the first two years of the

project, these trees were planted with more

sand around the roots to encourage growth

and to attract groundwater. Additional trees

also were planted in an uncontaminated site in

order to compare test data. 

Treeting Contamination:

A Natural Cleanup Alternative

John Wrobel of the U.S. Army at

Aberdeen Proving Ground

Directorate of Safety, Health, and

Environment; Steve Hirsh of EPA

Region 3; and Harry Compton of

EPA's National Risk Management

Research Laboratory; shown above

at J-Field, are members of the

phytoremediation project team.

12Partners In Progress
by Marsha Minter, FFRRO Community

Involvement National Program Manager

This column's icon—people linked

arm-in-arm—illustrates EPA's goal of

helping all parties become involved in

environmental decision-making at

federal facilities. This two-part article

shares highlights from EPA's National

Community Involvement Conference,

an event that provided inspiration and insight on how we

can work together to achieve this goal. 

Held in Boston in August 1998, the conference focused

on EPA's commitment to help communities find solutions to

environmental concerns. The conference brought together

community involvement directors, Restoration Advisory

Board (RAB) members, public affairs specialists, military

officials, site supervisors, and representatives from

government and academia.

Through workshops and dialogue, the participants

learned innovative techniques and approaches for fostering

community involvement. In her keynote address, Susan

Seacrest, president of the Groundwater Foundation, shared

her inspiring vision for community involvement. As the

founder of the Groundwater Guardian Program—a national

program that promotes community involvement 

in groundwater protection—Ms. Seacrest has found that

even the smallest step toward community involvement is a

step in the right direction. Said Ms. Seacrest, "a journey of a

thousand miles begins with a single step." 

Ms. Seacrest emphasized that, to succeed in effective

community involvement, we must have the following:

• Promise: According to Ms. Seacrest's "spark plug" theory,

a single, inspirational moment is all that is needed to

spark the journey of a thousand miles.

• Process: After the spark has fired, the journey must be

encouraged and nurtured. Sound science, reliable

information, and accurate data are essential.

• Partnerships: Information and data without human

relationships will not achieve success. People power is

needed to make the process work. Partnerships must be

forged at all levels and reach beyond city or county limits.

• Products: The end results—the products—should be

sustainable, results-oriented solutions to problems.

Ms. Seacrest reflected that by following the above "Ps," as

she calls them, people learn to value the differences among

themselves and eventually master the fifth "P"—patience.

EPA is committed to increasing community involvement,

supporting RABs and SSABs, and fostering partnerships with

other stakeholders. Together we can ensure the success of

our nation's cleanup programs. Arm-in-arm, the journey will

become easier each step of the way.

Portions of this column were reprinted from the U.S. EPA

National Community Involvement Conference Proceedings

Supplement, with permission from the Groundwater

Foundation. This article will be continued in the spring

issue of Partners In Progress. Questions or comments on this

article or other community issues can be directed to

Marsha Minter at 202 260-6626; or e-mail:

<minter.marsha@epa.gov>.

Inspiration Sparked at 

Community Involvement Conference

TheCommunity

Connection

Community Connection Reflection:

“Never doubt that a small group of

thoughtful, committed citizens can change

the world. Indeed, it is the only thing that

ever has.”

—Margaret Mead

13Partners In Progress
The Military Range

Cleanup Debate

by Douglas A. Bell

T

o ensure military readiness, DoD has operated more

than 10,000 sites for troop training or testing of

munitions and other weapons. Many of these sites are

defined by DoD as military ranges. Due to tremendous site

assessment and cleanup costs, most of the ranges have not

been thoroughly investigated and still contain unknown

amounts of munitions including UXO. Since the 1950s,

many contaminated ranges have been transferred and are

no longer under DoD control. These properties are now in

the hands of private citizens, industry, States, and tribal

nations, who, in some situations, might not be aware that

UXO or hazardous chemical contamination is present.

EPA, DoD, states, and military range stakeholders are

working to develop policies for addressing military

munitions and UXO. In February 1997, EPA finalized the

Military Munitions Rule, a federal regulation that provides

requirements for storage, transport, and disposal of military

munitions. Initially, military ranges were to be included

within the broad authorities of the Military Munitions Rule.

In 1995, however, DoD began developing its own

regulation specifically for closed, transferred, and

transferring military ranges. DoD proposed this rule in

September 1997. While this rule is under development,

when finalized, it will set forth a process for investigation

and cleanup actions at these types of military ranges.

Various parties have expressed different perspectives on

DoD's proposed rule and the risks associated with military

ranges. DoD stated in the draft Range Rule Risk

Methodology that "risk is defined as the product of the

probability of detonation and the consequences of

detonation" [of UXO]. This DoD position indicates that

UXO are only dangerous if enough force is applied to cause

detonation. Some regulators, stakeholders, and tribal

parties disagree with DoD's stated position. These parties

also feel the proposed regulation does not adequately

address assessment and remediation, citing the tremendous

risks involved with any exposure to munitions, particularly

UXO. This is only one example of the difficult issues that

face DoD and all involved.

Evaluating the risks posed by military munitions is a

complex and difficult task. Risk, danger, and exposure to

UXO, for example, cannot be easily measured with

traditional risk assessment methods. Lifetime exposure to

UXO, as compared to hazardous chemicals, has no meaning

since just one detonation is all that's needed to cause a

fatality. 

In addition to determining risk, DoD must collect rangespecific information. Some of the affected properties are

extremely large, spanning more than 100 square miles.

Making matters even more complex is that many of the

activities performed on ranges during their lifetime are still

unknown. General records might serve as a guide, but they

often lack sufficient detail about how much ordnance was

used or where it was used and disposed of following

training activities. Without this crucial information, the DoD

task of cleaning up and stabilizing the ranges is much more

difficult. 

To overcome these challenges, DoD is engaged in a

number of efforts to address military ranges. The enormity

of DoD's tasks makes progress difficult, but DoD has

committed to resolving the issues involved. In conjunction

with DoD, EPA will continue to work with all parties. EPA is

assisting in these efforts to deal with situations at closed,

transferred, and transferring ranges through existing

authorities, like the EPA

Munitions Rule, the

Superfund law, the Resource

Conservation and Recovery

Act, and the Safe Drinking

Water Act. All involved will

continue to work toward

establishing a higher level of

protection for human health

and the environment.

Douglas Bell is an

environmental 

scientist at FFRRO where he

manages military range issues

nationwide.

Photo by Harry Craig, EPA Region 10

UXO found at the Umatilla Army

Depot in Hermiston, Oregon.

14Partners In Progress

DEFINITIONS

Military Munitions: Ammunition products and components

produced or used for national defense and security.

Examples include propellants, explosives, pyrotechnics,

chemical and riot control agents, chemical warfare agents,

rockets, guided and ballistic missiles, bombs, warheads,

mortar rounds, artillery ammunition, grenades, mines, and

torpedoes.

Military Range: A land or water area used to develop, test,

and evaluate military munitions, or to train military

personnel in their use and handling. Ranges include firing

lines and positions, buffer zones, maneuver areas, firing

lanes, test pads, detonation pads, and impact areas.

UXO: Military munitions that have not detonated. These

include damaged, decomposed, and dud-fired munitions. 

Full, legal definitions of these terms can be found in the

proposed DoD Range Rule at <www.acq.osd.mil/ens/

draft/rangrule.doc>.
Excavating Big Savings

First, the BCT tackled the contaminants in Greenlaw

Brook and the Little Madawaska River, which it feeds.

Stormwater drainage and runoff from the base's industrial

and flight-line activities areas contaminated these nearby

surfacewaters. The contamination was so severe that, in

1996, the Maine Department of Human Services issued an

advisory against eating fish from the river. 

To treat the contaminated area, the BCT excavated the

banks of the brook. Once excavation was underway, the

team discovered the contamination was more than twice the

originally projected levels. Undaunted by these findings, the

BCT establishing a state-of-the-art, on-site laboratory for

analyzing water and sediment samples. Daily tests enabled

the BCT to direct the excavation crew quickly and

efficiently. In addition, the BCT expedited the excavation

process by accelerating decision-making procedures and

cutting through red tape wherever possible. 

The BCT excavated an additional two feet of sediment

beyond the treated area to ensure all contamination was

removed. The remaining sediment not only met required

standards but was considered an excellent wetland soil. In

fact, the quality of the remaining soil was so good that

backfilling the area with replacement soil was unnecessary,

saving $2 million in backfill costs. 

Consolidating Waste

The BCT also saved more than $30 million in solid waste

transportation and disposal costs by consolidating waste on

the base. Initially, the team planned to close the landfills in

the southwestern section of the base. A closer evaluation,

however, showed using the landfills to handle contaminated

soil excavated from the base cleanup would be more efficient

and cost-effective than paying a firm to transport and

dispose of the wastes. 

The excavated wastes pose minimal risk on the base since

the landfills utilize a double-layer capped system to prevent

leakage. All the landfills are situated well above the water

table, eliminating the risk of potential groundwater

contamination. Currently, approximately 750,000 cubic yards

of excavated soil have been placed in the landfills from

more than 100 sites. 

A Brighter Future

Today, the base is home to the Loring Commerce Center, a

thriving hub of jobs, services, and recreation. Employment at

the center reached approximately 1,200 by the end of 1998.

With a well-established infrastructure of transportation, utility,

and telecommunications systems in place, the state of

Maine is confident it can fill the commercial, industrial, and

aviation space still available at Loring. These new endeavors

are helping to stimulate economic growth and ensure longterm stability in the area.

15Partners In Progress

Write To Us

We encourage your questions, comments, and contributions. Please send your input to Deborah Leblang by mail at 

U.S. EPA/FFRRO, Mailcode: 5101, 401 M Street, SW., Washington, DC 20460; e-mail at <leblang.deborah@epa.gov>;

or fax at 

202 260-5646.

Join Our Mailing List

If you would like to be on the FFRRO mailing list to

receive future issues of Partners In Progress, please fill

out and return this form to ERG, c/o Leo Pineda, 2200

Wilson Boulevard, Suite 400, Arlington, VA 22201-

3324; or fax to 703 841-1440. Alternately, you can

send your request via 

e-mail to <lpineda@erg.com>.

Name: ________________________________________

Agency/Organization:_____________________________

Street Address: _________________________________

____________________________________________

City: __________________________________________

State: ________ Zip Code: ________________________

Phone Number: _________________________________

E-mail: ________________________________________

Celebrating Success

<Continued From Page 1>
Acronyms Explained

APG Aberdeen Proving Ground

BCT BRAC Cleanup Team

BRAC Base Realignment and Closure 

CERCLA Comprehensive Environmental Response, Compensation, 

and Liability Act 

DoD U.S. Department of Defense

DOE U.S. Department of Energy

DSMOA/CA Defense and State Memorandum of Agreement/Cooperative

Agreement

EPA U.S. Environmental Protection Agency

EM Environmental Management

FFEO Federal Facilities Enforcement Office

FFLC Federal Facilities Leadership Council

FFRRO Federal Facilities Restoration and Reuse Office

FUDS Formerly Used Defense Sites

ITRC Interstate Technology and Regulatory Cooperation

NPL National Priorities List 

RAB Restoration Advisory Board

RPM Remedial Project Manager

SARA Superfund Amendments and Reauthorization Act

SSAB Site Specific Advisory Board

UXO Unexploded Ordnance

Y2K Year 2000

For More

Information

Do you have questions

about federal facility cleanup

and reuse? Do you want to

learn more about FFRRO’s

partnerships and latest

projects? If so, call FFRRO

at 202 260-9924.

Also, look for information on

the Internet at <www.epa.

gov/swerffrr/>. You’ll find

information on innovative

cleanup technologies, current

guidance, links to Web sites

of FFRRO partners, and

more.