Community Relations 

Plan Wins Praise 

Are you aware of the cleanup effort underway at Fort Pickett? What would

be the best way to keep the community informed? These are just two of

the questions posed to community members as part of the development

of the Community Relations Plan (CRP) for the cleanup efforts recently initiated

at Fort Pickett in Blackstone, Virginia. By soliciting input early in the cleanup

effort, the plan’s creators directly addressed the community’s needs and helped

establish a positive relationship between cleanup officials and the local community. U.S. Environmental Protection Agency (EPA) Region 3 staff believe the Fort

Pickett CRP is “one of the most comprehensive and thorough” they’ve seen, and

they plan to use it as a model for other federal facility cleanup projects. 

Designed to facilitate communication among the Army, public officials, residents, the media,

and other interested parties, the Fort Pickett CRP was based on input obtained during interviews

with local residents and community leaders. Twenty-eight local residents were interviewed by phone

and in person in August 1998, including representatives of city government, businesses, environmental groups, and community leaders. Most of these individuals live within two miles of the base.

Interview respondents answered questions in three categories, including general community-related

questions, questions specific to Fort Pickett, and questions about community relations. Information

In Progress

EPA Update on Federal Facility Cleanup and Reuse

Agency

www.epa.gov/swerffrr/

(5106)

2

FFRROs Director takes a

look at a decade of

progress.

6

Need to know how to

conduct a 5-Year Review?

A new guidance document on the subject is

scheduled to be released

in April 2000.

9

FFRRO and

the Department fo

Defense

have joined

forces to

control

lead-based

paint hazards at federal

facility cleanup sites.

Issue 4 Federal Cleanups That Put Citizens First

Celebrating

Success

1EPA

New Guidance Will Help Bring Closure

When the Air Force Base Conversion Agency (AFBCA) was nearing

completion of the remediation phase for some of its Superfund

national priority list (NPL) sites and Base Realignment and Closure

(BRAC) installations, it wanted to ensure correct and legal procedures for final site

closeout. While remediation plans were well underway at several bases, none had

reached the point of closeout yet. The cleanup teams for these sites began looking

for guidance on how to proceed. While they discovered various closeout instructions, there was no single source of information on closing out an environmental

remediation site at federal facilities. 

This discovery planted the seed for the development of the Environmental Site Closeout

Procedures for National Priorities List Sites and BRAC Installations, a comprehensive source of

requirements for closeout of environmental restoration sites at military facilities. This guidance

document was designed by a working group comprised of representatives from each military

branch, the Office of the Secretary of Defense, the U.S. Department of Defense’s (DoD’s) environmental office, EPA, and the California and Illinois environmental protection agencies. The group

BreakingNews

<continued on page 10>

<continued on page 5>
2Partners In Progress

Acronyms Explained

AFBCA Air Force Base Conversion Agency

BCT BRAC Cleanup Team

BRAC Base Realignment and Closure 

CERCLA Comprehensive Environmental Response,

Compensation, and Liability Act 

CRP Community Relations Plan

DoD U.S. Department of Defense

DOE U.S. Department of Energy

DU Depleted Uranium

EPA U.S. Environmental Protection Agency

ETV Environmental Technology Verification

FFRRO Federal Facilities Restoration and Reuse Office

GPRA Government Performance and Results Act

HUD U.S. Department of Housing and Urban Development

IAP2 International Association for Public Participation

NPL National Priorities List 

POC/DC People of Color/Disenfranchised Community

RAB Restoration Advisory Board

RCRA Resource Conservation and Recovery Act

SSAB Site-Specific Advisory Board

TSCA Toxic Substance Control Act

UXO Unexploded Ordnance

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 (PIP) 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.

I

n early December 1999, I had the fortune of

attending a meeting of the People of

Color/Disenfranchised Community

(POC/DC) Environmental Health Network. As

we mulled over the federal responses to 16

POC/DC requests for environmental assistance,

I was struck by the thought that ten years ago

we could not have had such a meeting and as

little as five years ago, if we would have had

such a meeting, it would have been fairly contentious. Now

I was sitting in a crowded EPA conference room in Crystal

City, Virginia, with federal officials, environmental justice

advocates, ministers, tribal representatives, and other

activists, cooperatively working toward finding common

solutions to environmental and health problems in affected

communities. What’s more, there was a general recognition

that we needed to enlarge the circle to bring in more people

and resources to provide more and better solutions. This

meeting and all that came before it are evidence of the

progress we have made.

The 1990s witnessed considerable progress in federal

facility cleanup. Just before the decade started, we witnessed

what might have been one of the lowest points in federal

environmental stewardship with the Federal Bureau of

Investigation raid on the U.S. Department of Energy

(DOE) Rocky Flats facility. More than any other, I think

that event provides us with a reference point to assess how

far we’ve come.

The decade started with the phrase “decide, announce,

and defend” when it came to federal facility cleanups. As it

ends, words like “partnering” and “collaboration” describe

the general cleanup approach. Cleanup methods and federal

agencies’ relationships with states, local governments, tribes,

and various affected communities are improved overall. Of

course, not all facilities or programs have made the same

progress. We see problems from time to time but compared

to a decade ago, the difference is considerable. Our collective

task, however, is still very much a “work in progress” and we

must continue to build on and learn from our successes and

failures.

People began to recognize the potentially tremendous

cleanup workload at federal facilities in the late 1980s and

early 1990s. Few had a good sense of the magnitude of the

challenge, but most intuitively understood it to be overwhelming. At that time, EPA was in the process of adding

more than 100 federal facilities to its Superfund National

A Decade of Progress in Cleanup 

Of Federal Facilities

FromTheDirector
Priorities List (NPL). Few will recall the first EPA federal

facilities office in existence at that time, the Federal Facilities

Hazardous Waste Task Force in the Office of Waste

Programs Enforcement. The 1994 reorganization of EPA

lead to the creation of the two current offices focusing on

federal facilities, (FFRRO and the Federal Facilities

Enforcement Office [FFEO]). Over the same time

frame, many EPA regional offices created their own

individual units, sections, or branches to focus on

the cleanup of federal facilities. 

The last decade has experienced many significant events and achievements. From my perspective, the 1993 Interim Report and later 1996 Final

Report of the Federal Facilities Environmental

Restoration Dialogue Committee (also known as the

“FFERDC Report”) was the most significant. The

significance is not only in the report’s “Principles

and Recommendations” for improving federal facility cleanup, which are now being implemented,

but also in the dialogue process itself which

brought together individuals with a diversity of perspectives

and experiences. It forged a foundation for building cooperation and trust. The relationships and friendships developed

during the FFERDC process have helped us find solutions

to issues that have arisen since the report’s publication. It has

proven to be a document we can return to for guidance

when facing tough issues and it has really changed for the

better the way the federal government works.

Also noteworthy is the 1995 Report of the Federal

Facilities Policy Group on Improving Federal Facilities

Cleanup. This report was the Executive Branch’s first systematic recognition of the environmental cleanup challenge on

federal lands. The report recognized the legacy of the cold

war and past failures of federal facilities to protect the environment. It remains the only report to include an estimated

funding requirement for complete cleanup of federal government sites. Though many were initially shocked at the $234

to $389 billion estimate, that figure may have been an

under-estimate as it did not account for cleanups that may

be required for closed, transferring, and transferred military

ranges, formerly-owned contaminated federal properties,

and natural resource damages.

A third major achievement was the passage of the

Federal Facilities Compliance Act in 1992, which amended

the Resource Conservation and Recovery Act (RCRA) and

waived sovereign immunity for violations of the hazardous

waste statute. It also addressed mixed waste issues and

required the promulgation of regulations on unexploded

ordnance. 

From the perspective of Superfund cleanup, we have

made tremendous progress. A decade ago, toxic waste sites

on federal facilities were still being discovered and characterized. Compared to work at private sites, federal facilities

lagged behind in remediation. That changed in the 1990s

with a rapid evolution in cleanup programs. Many federal

facilities are now in the design and construction phases of

cleanup. The profile of work at the NPL sites dramatically

underscores this progress.

But where do we go from here? As the FFERDC report

notes, the relationships among regulated agencies, the regulators, and affected communities are tenuous and fragile. As

in most relationships, when money gets tight, tension tends

to increase. Federal fiscal constraints pose a tremendous

challenge to maintaining our current pace of progress

toward completing site cleanup. New contaminated sites are

being discovered and new challenges are emerging. To continue the core cleanup work at federal facilities, the federal

government must find solutions to the new challenges on

the horizon. The principal challenges that I see are:

■ Addressing closed, transferring, and transferred 

military ranges. 

■ Continuing to improve community involvement in

all phases of cleanup and reuse efforts with a focus on

environmental justice communities.

■ Building a viable program across all federal agencies

for “long-term stewardship” of the cleaned up sites to

ensure continued protection of human health and the

environment. 

■ Addressing contaminated formerly-owned federal

properties.

■ Putting contaminated federal properties to 

productive reuse.

■ Addressing contamination at the non-DoD, nonDOE federal facilities.

I am looking forward to building on the foundation we

have put together and working with all the parties that share

an interest in solving these and other, yet to be discovered

challenges. It will take our collective talents to come up with

workable solutions.

1990 1999 

(end of year) (end of year)

Proposed/Final NPL Sites 121 165

Ongoing Remedial Investigation/

Feasibility Study projects 275 477

Ongoing Remedial Design projects 17 76

Ongoing Remedial Action projects 13 204

All Remedial Action Projects Completed 0 23

NPL Deletions 0 9

Projects
Improving the Practice of Public Participation

By Martha A. Rozelle

The International Association for Public Participation

(IAP2), a nonprofit corporation, is committed to

improving decision-making processes by promoting

public participation and making it more professional.

Established in 1990, IAP2 takes a leadership role in establishing high standards for public processes by developing

and sharing personal values, and it is the most comprehensive source of information, tools, and training needed to

improve decisions that affect the public. 

IAP2 has more than 1,000 members from 25 countries

and all levels of government and industry, including electric

utilities, industry, engineering and environmental consulting

firms, law enforcement, health care, and public participation

practitioners. Last year, IAP2 entered a partnership with

EPA’s Federal Facilities Restoration and Reuse Office

(FFRRO) to help foster improved public participation in

federal facility cleanups. Marsha Minter, FFRRO’s

Community Involvement National Program Manager, was a

member of IAP2’s Board of Directors for 1999. 

In its leadership role, IAP2 has defined a set of core values that its members use to guide the development and

implementation of public participation processes. These core

values were developed over a two-year period with broad

international input and have been adopted by other entities,

such as the National Environmental Justice Advisory

Council. These core values ensure that the interests and concerns of potentially affected people and entities are reflected

in decisions. The core values are: 

1. The public should have a say in decisions about actions

that affect their lives.

2. Public participation includes the promise that the 

public’s contribution will influence the decision.

3. The public participation process communicates the

interests and meets the process needs of all participants.

4. The public participation process actively seeks out and

facilitates the involvement of those potentially affected.

5. The public participation process involves participants in

defining how they participate.

6. The public participation process provides participants

with the information they need to participate in a 

meaningful way.

7. The public participation process communicates to 

participants how their input affected the decision.

Decision-makers, public officials, and the public can

achieve mutual expectations by treating each other with

respect and by recognizing the IAP2 core values in the

design of public participation processes. FFRRO intends to

incorporate these values into its own participation planning.

By showing stakeholders that they do have a voice in matters

that concern them and that their concerns will be taken into

consideration in decision-making will improve trust and

communication—vital ingredients to successful public 

participation. 

Martha A. Rozelle, Ph.D., is the president of IAP2. She is

also the president of a participatory decision-making consulting firm, The Rozelle Group, Ltd., in Phoenix, Arizona. For

more information about IAP2 or to learn how to become a

member, visit the program’s Web site at <www.iap2.org>.

4Partners In Progress

Over the past four years, FFRRO has been involved in

the development of the U.S. Department of Defense

(DoD) Range Rule and related supporting activities.

Critical to the success of the Range Rule (and EPA’s concurrence) are the ongoing efforts to develop a risk assessment or

risk management approach. This effort, now in its third year,

will yield a much different approach for addressing military

munition and unexploded ordnance (UXO) risks at closed,

transferred, or transferring ranges than is currently in use.

Initially, DoD developed an approach that was very

quantitatively driven. Given the wide application the

methodology would have, EPA urged DoD to create a partnering team comprised of representatives from EPA, states,

tribes, and other federal agencies and stakeholders. Originally

formed in 1997, the partnering team today involves approximately 40 individuals and combines insights from both DoD

and non-DoD parties. The overall approach has evolved

toward more qualitative risk management, recognizing the

uncertainty involved in the detection and clearance of UXO.

The Range Rule Risk Methodology will be the subject of a

comprehensive article to appear in a future issue of 

Partners In Progress.

A Risk Management Approach for UXO 
obtained from the interviews included the community’s current awareness level about the cleanup, primary sources of

information on community news, and specific types of

information they would like to receive about the cleanup

activities. 

The Fort Pickett CRP outlines specific community relations activities and a time line for implementing these activities. Several of the activities relate directly to the interview

responses. The plan, for example, calls for the BRAC

cleanup team (BCT) to make presentations to local civic

organizations highlighted by respondents. To make the CRP

more useful to the community, it includes contact information for all the BCT and Restoration Advisory Board (RAB)

members as well as other project contacts, including local

media, Fort Pickett contacts,

elected officials, and area clubs

and organizations. 

The BCT for Fort Pickett

initiated the CRP in July

1998, and it was completed by

September 1998. The BCT is

comprised of representatives

from the Army Corps of

Engineers, EPA Region 3, and

the Virginia Department of

Environmental Quality. The

BCT members expressed their

desire for a thorough CRP to

the contractor who prepared

the plan. They conveyed the

specific components they

wished to see in the plan, one

of which was the need to solicit the community’s input prior

to the plan’s development. In

addition, the BCT provided

feedback on the interview

questions when they were in

the draft stage. As a member

of both the BCT and the

RAB, EPA was instrumental in

creating an exemplary plan.

EPA Region 3 staff assisted in

conducting interviews. In

addition, staff took the initiative and asked RAB members

for their recommendations for

respondents. This resulted in a

well-balanced pool of community members. 

Before the CRP was developed, community involvement

in the Fort Pickett cleanup consisted primarily of participation in the RAB meetings. Public notices were placed in area

newspapers before each meeting, and meeting minutes and

agendas were mailed to

approximately 60 interested

parties before each meeting.

The CRP interview responses

indicated a particular newspaper in which to put meeting

notices and expanded the

mailing list to 125 persons.

Also, it proved to be an excellent way to raise awareness

about the cleanup efforts

since participants were briefed

on the project in conjunction

with the interview.

EPA staff believe that

because the CRP was developed in the early stages of the

cleanup effort, the BCT can

address any concerns that may

arise more effectively. Indeed,

few concerns are anticipated

precisely for this very reason.

Due to its comprehensiveness,

simplicity, and incorporation

of community opinion, EPA

Region 3 plans to use the Fort

Pickett CRP as a model for

other cleanup projects. 

To learn more about the

Fort Pickett Community

Relations Plan, contact Don

McLaughlin of EPA Region 3

at 215 814-5323.

Community Relations Plan

<continued from page 1> Fort Pickett, located in a rural area of southern Virginia, operat

mainly as a combat training facility from its creation until it wa

designated for realignment in 1995. Restoration efforts began i

1996. Current cleanup efforts are focused on a 3,500-acre area o

the base that is being readied for transfer to the Local

Redevelopment Authority. Approximately 95 percent of these

3,500 acres were found to be free of environmental concerns an

suitable for transfer and/or lease. Cleanup activities for the

remainder of the affected area are currently in the remedial

investigation phase.

Shell casings like those pictured above were

recently cleaned up from an area under investigation at Fort Pickett. More than 8,000 shell casings were found. According to the Army Corps of

Engineers Huntsville District, some of the shells

showed evidence of residual contamination and

need to be detonated and rendered residue free

prior to disposal at a recycling facility.

Two 55-gallon drums containing unidentified

substances. These drums were sampled, properly

characterized, and disposed of.
6Partners In Progress

People often think that once a cleanup action is in

place at a contaminated site, the work is done. But

remedy selection is only the first step in making a

closed, transferred, or transferring federal facility safe for

human exposure. In order to ensure that a cleanup remedy

eliminated the contamination or is still working to protect

human health and the environment, the participants must

conduct a five-year review. A review is an on-site inspection

of remediation activities that includes testing contamination

levels. While it sounds like an easy process, it can be difficult to determine who conducts the review, when the review

should take place, and what actions should be taken as a

result. New guidance developed by EPA and slated for

release in April 2000 helps clear up that confusion. 

EPA has defined two types of five-year reviews at all

National Priority List (NPL) sites: statutory, meaning it is a

mandatory action required by the Comprehensive

Environmental Response, Compensation, and Liability Act

(CERCLA), or policy, meaning that it is required by EPA

policy. Both, however, may be conducted at any federal

facility site where ‘the President’ (i.e., EPA or delegated federal agencies acting on the President’s authority) has selected

CERCLA remedial actions that leave waste in place at levels

that do not allow for unrestricted use, to ensure that cleanup

actions are working as planned (i.e., remain protective of

human health and the environment). But how does a project manager know what type of review is needed and when

it should be given? 

“It sounds like it should be routine, but it’s not something that can be summarized in one sentence,” explained

Mark Stephens of EPA Region 3. “There are some complexities to the who, what, when, and why.” Answers to these

issues, however, can be found in a new Five-Year Review

Guidance. Stephens was one of the collaborators on the

effort, working primarily on a chapter defining roles and

responsibilities of the various parties involved in a CERCLA

cleanup. 

Carol Bass of the Office of Emergency and Remedial

Response, headed the five-year review team. Not only did

the team collect and compile previous guidance, but they

also worked to eliminate contradictions in earlier documents, defined terms, and clarified ambiguous or confusing

information. 

“It really was a multioffice effort,” said Bass. “We needed

expertise from several EPA offices.” After many months of

refining the text, the document is currently under review by

federal agencies, including the Department of Defense

(DoD), the Department of Energy (DOE), the Department

of Justice, the Agency for Toxic Substances and Disease

Registry, as well as states and tribes.

Guidance Features

The purpose of five-year reviews is to determine whether

a remedy is or is expected to be protective, to document any

deficiencies identified during the review, and to recommend

specific actions to ensure that a remedy will be or will continue to be protective. 

Who?

The guidance goes into great detail as to who should

conduct the review. For federal facilities, this is determined

by the site-specific conditions: such as whether the site is a

NPL site; whether the site is a DoD, DOE, or Coast Guard

site; whether there is a federal facilities agreement (FFA) in

place; and if there is an FFA, what does it say. In many

cases, EPA has some role in the review. 

What/When?

Once it is determined who will conduct the review, it is

necessary to identify the kind of review needed. A statutory

review is required for those sites that upon completion will

leave contamination in levels higher than those allowable for

unlimited access or use. These reviews are conducted no less

than every five years based on the start date of a remedial

action. EPA policy reviews are required for a number of

other sites based on the guidance. These reviews take place

no less than every five years based on the construction completion date of the remedy. The guidance also addresses

www.epa.gov/etv/

Managed by EPA’s Office of Research and Development, the

Environmental Technology Verification (ETV) Program was created to

accelerate the introduction of new environmental technologies into the

domestic and international marketplace. The program’s Web site explains

the process through which these new technologies are verified, including

pilot projects in development and testing events. This site also contains

the list of technologies verified and the ETV quality management plan,

which lays out the criteria for and responsibilities of all of the governmental and private sector participants in the ETV program. ETV articles and

press releases, links to partners and related Web sites, state and regional

outreach activities, and a list server are also available.

Cyber News

Five-Year Review Guidance
I

n keeping with its commitment to public participation, the

Federal Facilities Restoration and Reuse Office (FFRRO)

unveiled its new Web page dedicated to community

involvement. Located within the office's main site at

<www.epa.gov/swerffrr/>, the new page is divided into severa

topics containing information on the Federal Facilities

Environmental Restoration Dialogue Committee, Restoration

Advisory Boards and Site-Specific Advisory Boards, public

forums and workshops, tribal nations, environmental justice,

state and local government, environmental restoration issues,

and FFRRO partnerships. 

The community involvement site is still being developed

according to Jeff Stinson, FFRRO’s acting Internet coordinator. Phase 1, which is currently available on the Internet, wen

online in November 1999. Phase 2 will include interactive

components such as community and site-specific forums in

which stakeholders, project managers, advisory board members, and others can exchange information and suggestions fo

facility cleanup. This portion of the site is expected to go

online in the near future. Stinson encourages readers to view

the site at <www.epa.gov/swerffrr/comminvolve/index.htm>

and send their comments by e-mail to

<stinson.jeffrey@epa.gov>. 

other situations, including what is required if there are

RCRA actions or deferrals involved; monitoring, monitored

natural attenuation, institutional controls, ‘no further action’,

or multiple operable units.

How?

Finally, in addition to planning the review, forming a

team, and compiling data, a reviewer needs to ask several

questions to determine the protectiveness of the remedial

actions at a site. The three primary questions are: 

• Is the remedy functioning as intended by the decision documents?

• Are the assumptions used at the time of the remedy

selection still valid?

• Has any other information come to light that could

call into question the protectiveness of the remedy?

Depending on the responses to these questions, several

followup questions reviewers should ask also are included in

the guidance document.

The guidance is accompanied by a five-year review report

template, a sample report, and a site inspection checklist.

“The samples allow someone who’s never conducted a fiveyear review to get a good idea of what information is needed

and what a finished report should look like,” Bass said.

Finalizing the Guide

Bass and her team will carefully review the other agencies’ comments, responding to each and deciding how to

incorporate them into the guidance. “This is a document

that people really need. They’re looking forward to its

release,” Bass said. “It’s been a lengthy process but it has been

well worth the effort.”

The finalized guidance will be released in April 2000. 

For more information on the Five-Year Review Guidance,

e-mail Carol Bass at <bass.carol@epa.gov>.

www.afbca.hq.af.mil

The Air Force Base Conversion Agency (AFBCA) is committed to making sure that closing

and realigning Air Force installations are cleaned up and made available for reuse as quickly

and efficiently as possible. The agency’s Web site helps further this mission by providing visitors with progress reports, newsletters, fact sheets, and training materials. The online version

of the Base Conversion Handbook helps personnel understand how their individual efforts

directly contribute to the overall conversion process and helps communicate the AFBCA’s

mission, roles, and responsibilities to federal, state, and local conversion planning agencies

and those in affected communities. Base Realignment and Closure (BRAC) contact information and site-specific data might also be of particular interest to Air Force base stakeholders.

The site also contains general regulations, guidance, and other information applicable to all of

the U.S. Department of Defense’s (DoD’s) BRAC sites.

Community Involvement 

On the Web
The main objectives of any action implementing a

Defense Base Closure and Realignment Commission

(BRAC) recommendation are to eliminate threats to

human health and the environment that might be present

on the closing installation and to transfer the property to

communities quickly and efficiently. One threat that could

be present on a closing installation is lead-based paint (LBP)

contamination. This threat is easier to evaluate and clean up

thanks to the new interim Field Guide (EPA and DoD

signed off on the Interim Field Guide on December 15,

1999) developed by a team of Environmental Protection

Agency (EPA) and Department of Defense (DoD) staff.

This break-through effort will help the agencies achieve

their goal of faster cleanup and property transfer.

After collaborating for two years on how to address LBP

hazards at DoD sites, the two agencies signed a plan of

action in March 1999, and pursuant to that plan of action

the agencies began developing the Field Guide. The guide

provides a framework for EPA and DoD project managers

to manage and control LBP hazards at BRAC facilities. The

document combines existing regulations such as Title X of

the Housing and Community Development Act of 1992

and its implementing regulations, the EPA Toxic Substance

Control Act (TSCA) Section 403 proposed rule, and the

Department of Housing and Urban Development (HUD)

Section 1013 final rule, with additional DoD policy requirements. The focus of Title X and the Field Guide is on protecting the health of children at residential properties. Title

X requires that hazards from LBP be abated in housing constructed prior to 1960. While a federal agency may transfer

the implementation of abatement to the transferee, the federal agency must perform an inspection and risk assessment

of all target housing prior to transfer. In addition, as a matter of policy, DoD has included a number of requirements

that exceed Title X to ensure that actions taken are protective of children. The Field Guide policy requirements

include:

• Soil surrounding housing constructed between 1960

and 1978 that contain soil lead hazards (concentration

of lead in bare soil equal to or exceeding 2,000 ppm

or 400 ppm in bare soil in children's play area) caused

by the use of LBP must be abated. The purchaser may

be required to perform the abatement activities as part

of the transfer agreement.

• Soil surrounding housing constructed between 1960

and 1978 that contains potential lead hazards (concentration of lead in bare soil between 400 and 2,000

ppm, except children's play area) caused by the use of

LBP will be evaluated on a site-by-site basis to determine whether no action, interim controls, or abatement is appropriate based on risk and non-risk

factors.

• Specific areas of the residential parcel or structure

intended to be reused as a child-occupied facility will

be evaluated for LBP hazards. LBP hazards (deteriorated painted surfaces, dust lead hazards, and soil lead

hazards) are required to be abated prior to the use as a

child-occupied facility. 

• Target housing that will be demolished and redeveloped as residential property following transfer will be

evaluated and abated by the transferee for soil lead

hazards after demolition and prior to occupancy of

any newly constructed dwelling units.

What’s Covered and What’s Not

The interim Field Guide only applies to property that is

or will be reused as residential real property. HUD defines

residential real property as property where people reside or

will reside, such as houses and apartment buildings. As a

matter of policy, DoD includes child-occupied facilities

within the definition of residential real property for the purpose of this guide. Child-occupied facilities are defined as

day-care centers, preschools, and kindergarten classrooms

regularly visited by children under six years of age. This

guide is not applicable to non-residential properties such as

single room occupancy dwellings like Bachelor Housing,

and schools.

The Field Guide does not supersede any state laws or

regulations regarding lead hazards. Therefore, any sampling

and abatement requirements identified in state laws or regulations must be met. This guide is an interim final as it

reflects the proposed TSCA 403 rule and has not yet been

reviewed by states, tribes, and others potentially affected by

this field guide. Once the TSCA 403 rule is finalized and

additional comments are received, evaluated, and incorporated in the document as appropriate, the guide will be

finalized. EPA and DoD will continue to work together on

other LBP issues, such as developing model language for a

non-residential FOST (finding of suitability to transfer). 

Monica McEaddy is a Chemical Engineer for EPA's Federal

Facilities Restoration and Reuse Office. Sandra Cotter is a Risk

Assessment Program Manager for the Environmental Division,

Headquarters Naval Facilities Engineering Command. 

EPA and DoD Approve Field Guide 

On Lead-Based Paint 

by Monica L. McEaddy and Sandra Cotter

8Partners In Progress
This is the second installment of a three-article series on

FFRRO’s efforts to comply with the requirements of the

Government Performance and Results Act (GPRA).

The U.S. Environmental Protection Agency’s (EPA’s)

mission is to protect human health and to safeguard

the natural environment—air, water, and land—upon

which life depends. To remain focused on this mission and

to establish guideposts for EPA’s leaders today and in the

future, the Agency has developed a series of 10 strategic,

long-term goals. These goals supported by EPA’s objectives

and performance measures have become the framework for

the Agency’s planning, budgeting, and accountability

process.

FFRRO concentrates its efforts on Goal 5, “Better Waste

Management and Restoration of Contaminated Waste

Sites,” including the oversight of Superfund cleanup activities on federally owned and operated properties containing

uncontrolled or abandoned hazardous waste sites. These sites

were created when chemicals and other wastes where

dumped in the open and left to seep into the ground, flow

into rivers and lakes, and contaminate soil and groundwater. 

FFRRO is responsible for providing oversight and technical assistance to other federal agencies for their uncontrolled hazardous waste sites that are listed on the National

Priority List (NPL). These facilities range from nuclear

weapons plants and military bases to landfills and fuel distribution stations and contain environmental contamination

from hazardous wastes, unexploded ordnance, radioactive

wastes, or other toxic substances. 

Goal 5 has several objectives and underlying components. The following objective states EPA’s plan of action,

while the response provides more specific information as to

how FFRRO is going to achieve these long-term goals at

federal facilities.

Objective: Reduce or Control Risks to Human Health:

By 2005, EPA and its partners will reduce or control the risk

to human health and the environment at over 375,000 contaminated Superfund, RCRA, UST, and brownfield sites.

Response: Respond to Superfund Hazardous Waste

Sites: By 2005, EPA and its partners will reduce the risks the

Superfund sites pose to public health and the environment

by: 1) completing construction at a total of 1,200 NPL sites,

2) conducting 2,400 additional removal actions, 3) determining if Superfund cleanup is needed at 85 percent of the

sites entered into the Superfund site database, 4) maximizing

Potentially Responsible Party participation in

conducting/funding response actions, and, 5) meeting statutory deadlines for federal facility activities. EPA will collaborate with states and tribes to enhance the federal, state, and

tribal Superfund programs, reduce overlap among the programs, and leverage public and private resources to promote

cost-effective, efficient cleanups at Superfund sites.

These overarching measures are further broken down

into performance measures that are reviewed and updated

on an annual basis to reflect program changes. The 1999

performance measures for federal facilities included:

• EPA and its partners conducted 335 Superfund

removal response actions. 

• EPA accelerated the pace of Superfund cleanups by

completing 136 cleanups and will achieve 900 construction completions by the end of the year 2001.

• In recognition of the importance of community

involvement in the cleanup decision-making process,

the Superfund Federal Facilities Program created a

measure for public participation.

• EPA established 100 Restoration Advisory

Boardss/Site-Specific Advisory Boardss at federal facilities on the NPL.

• EPA commented or concurred on 100 base closure

documents. 

EPA’s efforts to develop a strategic plan, goals, objectives,

and performance measures help link environmental regulations and policies to the budget and hold EPA accountable

to the public.

Renee Wynn is the associate director of FFRRO.

Setting and Achieving Goals With GPRA

by Renee Wynn

1. Clean Air

2. Clean and Safe Water

3. Safe Food

4. Preventing Pollution and Reducing Risk in

Communities, Homes, Workplaces, and

Ecosystems

5. Better Waste Management and Restoration

of Contaminated Waste Sites

6. Reduction of Global and Cross-Border

Environmental Risks

7. Expansion of Americans’ Right to Know About

Their Environment

8. Sound Science, Improved Understanding of

Environmental Risk, and Greater Innovation to

Address Environmental Problems

9. A Credible Deterrent to Pollution and Greater

Compliance with the Law

10. Effective Management

The Agency s 10 Goals Are:
10Partners In Progress

met monthly for one and a half years, identifying and compiling existing guidance and defining terms. 

In addition to providing a single resource for available

closeout information, the document aligns and identifies

both EPA and DoD milestones for the Comprehensive

Environmental Response, Compensation, and Liability Act

(CERCLA) and Resource Conservation and Recovery Act

(RCRA) programs, making it easier for cleanup teams to

stay on track. Further, it breaks new ground by defining the

work to be done after a remedial action decision has been

made, the point at which most cleanup guidance has ended.

Specific steps involved in a variety of cleanup remedies and

advice and examples based on real life situations, contributed by EPA regional members of the workgroup, round

out this section of the guidance. 

According to Mario Ierardi of the AFBCA, the guidance

is focused on “streamlining cleanup and closeout activities at

federal facilities across the country.” As soon as a facility gets

a cleanup remedy in place, Ierardi explained, it needs to start

looking at closeout procedures, even if remediation is

pg

Participating in two multiagency meetings on public

involvement in summer 1999,

EPA spoke out on several Superfund

site issues that affect surrounding

communities. Working closely with

citizen groups and restoration advisory boards (RABs), EPA tackled several issues including lead-based paint,

depleted uranium (DU) contamination, and the strength and effectiveness of public involvement in federal cleanups.

At a citizen caucus held in Washington, DC, in July

1999, the Federal Facilities Restoration and Reuse Office

(FFRRO) addressed the issue of lead-based paint at federal

cleanup sites. Because military structures are not covered by

Housing and Urban Development Department laws for residential buildings, they are allowed to deteriorate, contaminating soil and groundwater with lead. Also, access to these

buildings has not been consistently controlled, increasing

risks to individuals who might come in contact with the

paint. For more information on the remediation of leadbased paint hazards at federal facilities, see the article on

page 8.

Another issue presented at the citizen caucus was the

issue of depleted uranium (DU), a radioactive substance.

Used widely at military sites, DU is a contamination risk to

humans and the environment. The caucus urged the U.S.

Department of Defense (DoD) to provide a list of sites

where DU is or has been used and a history of that use. The

caucus also requested samplings of soil and groundwater at

these sites to evaluate the extent of DU contamination. 

At both the citizen caucus and an EPA Region 8 citizen

workshop held in Denver last August, the issue of public

participation was scrutinized in the wake of DoD’s dissolution of the RAB at Fort Ord in California. Citizens called

for the reinstatement of the Restoration Advisory Board,

arguing that communities must be recognized as an equal

participant in cleanup decisions.

The success of these meetings led EPA and DoD to

agree to attend more community meetings, including existing community forums and tribal sessions. Community representatives attending the meetings are hoping that such a

commitment will allow communities a bigger voice in the

decision-making process from start to finish. 

Background information for this article came from Defense

Environment Alert.

TheCommunity

Connection

FFRRO Leads the Way in Promoting Citizen Interests
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expected to go on for several years. 

The guidance outlines several phases in preparing for site

closeout including:

• Operation of Remedy: The BRAC Cleanup Team

(BCT) determines which cleanup remedies to use and

implements them.

• Response Complete: The cleanup objectives have been

or are being met.

• Long-Term Monitoring/Maintenance: Ensures that the

cleanup remedy remains in place as long as necessary and

continues to be effective.

• Site Closeout: This phase signifies that the response

actions at the site were successful; all cleanup levels and

other requirements have been achieved for all pathways

of exposure, and no further Superfund response is

required to protect human health and the environment.

In many instances, however, a site will never be completely closed out because it will always require some

kind of monitoring.

In January 1999, an interim guidance document encompassing all the existing closeout information was released as a

joint EPA/DoD and Military Service Guide. During a sixmonth review and implementation period at military facilities, BCTs had the chance to apply the guidance and

provide comments. These comments helped the working

group make final revisions to the document so it will be

effective in covering all the issues that might arise in a site

closeout situation. 

“We have not received many comments on the information contained in the guidance,” Ierardi said. “We’ve tried to

find out what’s missing and work to fulfill that need.”

A final EPA/DoD and Military Service Guide was to be

issued in spring 2000. 

Additional information concerning site closeout can be

found on the Environmental Site Closeout Web site at

<www.afbca.hq.af.mil/closeout>.

Write To Us

We encourage your questions, comments, and contributions. Please send your input to Dianna Young by mail

at U.S. EPA/FFRRO, Mailcode: 5106, 1200 Pennsylvania Avenue, NW., Washington, DC 20460; e-mail at

<young.dianna@epa.gov>; or fax at 202 260-5646.
EPA

United States 

Environmental Protection Agency

(5106)

Washington, DC 20460

Federal Facilities

Restoration and Reuse Office

Official Business

Penalty for Private Use $300

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March 27 to 30, 2000

26th Environmental

Symposium and Exhibition

Long Beach, California

This year’s conference focuses on the impact of DoD activities on the global environment and how to integrate environmental issues in sustaining DoD readiness. For more

information, visit the conference Web site at

<environment.ndia.org/>.

April 4 to 6, 2000

HAZMAT 2000 Spills Prevention Conference

St. Louis, Missouri

The HAZMAT 2000 Spills Prevention Conference provides an opportunity for communities, industry, states, and

nations to examine existing policies and tools that foster

hazardous material accident prevention, preparedness, and

response activities. For more information or to register electronically, visit the conference Web site at <www.nrt.org/

nrt/hazmat2000/hazmat2000.nsf>.

OnTheAgenda

May 1 to 3, 2000

IAP2 2000

Washington, DC

This International Association for Public Participation conference will explore the use and advancements of public participation in the 1990s and into the new millennium.

Registration information is available on the Web at

<www.iap2.org> or call 703 971-0090.

May 2 to 4, 2000

The UXO/Countermine Forum

Anaheim, California

DoD’s pre-eminent conference will examine the technologies, issues, and policies surrounding the UXO/

Countermine arena, including environmental remediation,

UXO disposal, humanitarian demining, and more. For

more information visit the Web site at <128.174.5.51/

denix/Public/News/UXOCOE/Conference/Forum00/uxo

2000.html#summary>.