United States 

Environmental Protection 

Agency

EPA505-B-99-002

April 1999

www.epa.gov/swerffrr/

Solid Waste and

Emergency Response

(5101)

6

New technology serves up

a recipe for remediation.

8

Composting takes on 

explosive contaminants at

military bases.

11

EPA is helping to ensure

safety at formerly used

defense sites.

12

Does your underground

storage tank comply with

EPA regulations?

Military facilities that once protected our

nation during the Cold War are now

being used to protect our wildlife. The

U.S. Department of Defense (DoD) is transferring

prime real estate once occupied by the military to other

federal agencies for use as wildlife refuges.

According to the U.S. Fish and Wildlife Service

(FWS), as many as 100,000 acres of military

property could be converted into refuge parks

by the year 2000. 

From coast to coast, communities are reaping the

benefits of these land transfers. According to the FWS,

tourists, educators, researchers, bird watchers, and hikers visit

wildlife refuges in the United States 34 million times a year.

Refuges contribute to local economies by boosting tourism,

and enhance the quality of life for residents by improving a

region’s aesthetic beauty and by offering educational

Going Wild

Bases Find New Life as Refuges 

Volume 2 n Issue 2 Federal Cleanups That Put Citizens First

by John A. Rosenthall

For years, communities have felt 

alienated from Superfund cleanups,

military base closures, and

Brownfields redevelopment projects

because they were not involved in remediation and land use decisions. As a result,

residents were often unable to change

unwanted land use patterns, reduce pollution levels, or maintain economic and

employment opportunities.

A new business venture is changing this

situation, enabling residents to become

both stakeholders and stockholders.

Community members partner with organizations to purchase stock that allows

them to own all or part of a business 

dedicated to environmental cleanup, community redevelopment, or related services.

As stakeholders, community members

gain meaningful participation in decisions

Celebrating

Success

<Continued on Page 10>

Stakeholder to Stockholder

A Tool for Environmental Justice and Public Participation

1EPA

<Continued on Page 9>
2Partners In Progress

Fulfilling A Mission

The Government Performance

and Results Act of 1993

by Renee Wynn

The principal purpose of the Government

Performance and Results Act (GPRA), enacted in

1993, is to hold federal agencies accountable for

achieving results, quality, and customer satisfaction by

requiring them to set goals, measure performance, and

report publicly on their progress. The three major

requirements of the act are:

• Develop and submit a five-year strategic plan to

Congress by September 30, 1997. The plan must

cover EPA’s mission, general goals, and objectives;

explain how these will be met; and discuss any significant factors affecting the achievement of the goals.

• Submit an annual performance plan to the Office of

Management and Budget each year during the budget

development cycle beginning with the fiscal year (FY)

1999 budget. The plan must outline objectives,

resources, and performance measures to meet the goals

and mission of the Agency. 

• Prepare annual program performance reports that outline

the Agency’s successes and failures in meeting the performance measures stated in the corresponding plan. The

report for FY 1999 is due to Congress by March 30, 2000.

Developing the strategic plan was a challenge for the

Agency, given the complexity of environmental statutes and

the number of partners and stakeholders involved (e.g.,

other federal agencies, tribes and tribal governments, state

and local governments, organizations, and citizens). By

working with these partners and stakeholders, however,

EPA can better achieve these goals and more easily develop

future strategic plans, objectives, and performance measures

for protecting human health and the environment. 

Renee Wynn is the associate director of FFRRO.

The first in a series of three, this article introduces

GPRA. Additional articles will outline what the Superfund

Federal Facilities program is doing to comply with the law

and identify ways for stakeholders to participate.

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.

Acronyms Explained

ASTSWMO Association of State and Territorial Solid Waste

Management Officials

BCT BRAC Cleanup Team

BRAC Base Realignment and Closure 

DERTF Defense Environmental Response Task Force

DoD U.S. Department of Defense

DOE U.S. Department of Energy

EPA U.S. Environmental Protection Agency

FFRRO Federal Facilities Restoration and Reuse Office

FUDS Formerly Used Defense Sites

FWS U.S. Fish and Wildlife Service

NPL National Priorities List 

SWMU 91 Solid Waste Management Unit 91

TCE Trichloroethylene

UST Underground Storage Tank

UXO Unexploded Ordnance

What do the terms mean?

EPA’s Strategic Plan:

A blueprint for achieving human health and environmental protection over the next five years. 

Goals:

Long-term guideposts or building blocks used

together to achieve the strategic plan.

Objectives:

Short-term measures for each goal that describe in

greater detail the specific, tangible results that EPA

plans to achieve in five years.

Performance Measures:

Results or activities to determine whether the Agency

is making progress towards its objectives.
3Partners In Progress

Overview of

Early Transfer

Guidance

U.S. EPA, Solid Waste and

Emergency Response

EPA505-98-007

January 1999

By allowing the transfer of property that poses

no unacceptable risks

before cleanup is completed, EPA helps

communities benefit from

faster reuse and redevelopment of federal

facilities. FFRRO developed this fact sheet to

inform communities and

federal facility cleanup

teams of this opportunity

while ensuring that proposed transfer and land

use decisions protect

human health and the

environment. The publication answers pertinent

questions such as who

benefits from early transfer; when the early

transfer guidance applies;

how the early transfer

process works; how a

property gets considered

for early transfer; and

when early transfer

occurs.

Federal Facilities

Restoration and

Reuse Office

Introductory

Brochure

U.S. EPA, Solid Waste and

Emergency Response 

EPA505-B-98-003

November 1998

Since its establishment

in 1994, EPA’s FFRRO

has worked with DoD,

the U.S. Department of

Energy (DOE), and other

federal agencies to develop creative, cost-effective

solutions to environmental problems at federal

facilities. This brochure

combines facts and figures

with individual case studies to demonstrate how

FFRRO is helping to

restore environmental 

and economic well-being

to affected communities

through partnerships,

innovative technologies,

and community involvement.

Strengthening

Brownfields

Redevelopment

U.S. EPA, Solid Waste and

Emergency Response

November 1998

FFRRO’s new fact sheet,

Strengthening Brownfields

Redevelopment, describes

how various groups and

federal agencies have

teamed up to develop new

outreach strategies to clean

up Brownfields.

Brownfields are abandoned, idled, or underused industrial and 

commercial facilities where

expansion or redevelopment is complicated by

environmental contamination. Because Brownfields

properties and contaminated federal facilities face

similar challenges and must

comply with the same

environmental laws, it is

important that EPA offices

and federal agencies work

together to help rebuild

these properties into environmentally safe and

economically productive

communities. This fact

sheet explains what

FFRRO is doing to help

achieve that goal.

BRAC Talk

Environmental Base

Realignment and Closure

News

Published by the Naval

Facilities Engineering

Service Center, this

quarterly newsletter

focuses on environmental

cleanup at Navy BRAC

installations. BRAC Talk

has reported on such

issues as covenants and

indemnification in

property transactions,

overlapping environmental regulations, and

specific actions taken at

various naval facilities.

Also included in the

newsletter is a list of Web

sites and a Navy BRAC

contacts list (provided in

every other issue). 

To receive a copy of

the latest BRAC Talk,

contact Ernestine

Rodriguez at 805 982-

4876 or <rodrigueze@

nfesc.navy. mil>. The

newsletter also can be

viewed in PDF format on

the Internet at

<www.navy.mil/

homepages/navfac/env/

newslet.html>. 

Hot Off the Presses

To receive a free copy of any of the following three

FFRRO documents, contact Leo Pineda at 703 841-0893

or <lpineda@erg.com>. The documents are also available on

FFRRO’s Web site at <www.epa.gov/swerffrr/>.
by Marsha Minter

The January issue of PIP shared highlights from EPA’s 1998

National Community Involvement Conference. This is the 

second article of a two-part series.

At EPA’s 1998 National

Community Involvement

Conference, several workshops

provided techniques and guidelines for

working effectively with communities.

Below are the five “tools of the trade”

summarized from the workshops. I

hope they can assist with strengthening your community connections.

Encourage active community 

participation:

• Pick a convenient location within the community rather

than at the federal facility.

• Arrange seating in a circle to facilitate interactive dialogue.

• Introduce those in attendance.

• Establish a meeting process and set ground rules at the

beginning.

• Provide various ways to participate (verbal or written

and public or private).

• Take outside concerns such as meeting time, accessibility, and child care into consideration when planning the

meeting.

Validate public participation:

• Show that public input was used and in what way.

• Initiate procedures to track correspondence and 

responses.

• Interview stakeholders and tailor the participation

process accordingly.

Recognize community knowledge:

• Listen carefully to what is being said and build upon

what is offered.

• Work with community leaders.

Use the appropriate cultural approach:

• Provide translators or translated materials when necessary.

• Create a new participation process to reflect the community’s culture(s).

• Encourage participation through appropriate media

(e.g., newspapers, public notices, flyers, letters, and

radio and television ads). 

Maintain honesty and integrity: 

• Articulate goals, experiences, and limitations.

• Show a willingness to discuss tough topics.

• Enhance attendance through personal contact and

sincerity.

When properly applied, these tools can create a successful community involvement program in which citizens and

Community Dynamics Explored at Recent Conference

4Partners In Progress

Community Connection Reflection:

“The American city should be a collection of communities where every member has a right to belong. It should

be a place where every man feels safe on his streets and

in the house of his friends. It should be a place where

each individual’s dignity and self-respect is strengthened

by the respect and affection of his neighbors. It should be

a place where each of us can find the satisfaction and

warmth which comes from being a member of the community of man. This is what man sought at the dawn of

civilization. It is what we seek today.”

—— President Lyndon B. Johnson

TheCommunity

Connection

At the International Association for Public Participation

Conference in Arizona (October, 1998), Minter met up

with fellow community involvement directors, Jennifer

Roberts (left) and Grechen Schmidt (right) from Alaska.
agencies are seen as

equal partners in

the dialogue on

cleanup issues. As a

result, those most

affected by federal

cleanups have the

opportunity to be

fully informed and

to work together

with federal officials to develop

cleanup solutions.

Collectively, community members

can reach reasonable solutions that improve our communities and protect our environment. 

Marsha Minter is FFRRO's Community Involvement

National Program Manager.

5Partners In Progress

In response to the Community Connection column

in the January issue, public participation leaders from

across the country have been in touch with the FFRRO

office. Representatives from New York to California, and

even Hawaii, want to build successful community

involvement programs in their own areas and are looking

for more information. These and other representatives

will be happy to know an abundance of information on

public involvement techniques is available. For a partial

listing of these guides and manuals, please visit the EPA

home page at <www.epa.gov/epahome/partners.htm>. I

hope they will be useful in your endeavors. As always,

questions or comments concerning this article or other

community issues can be directed to me at 202 260-

6626 or <minter.marsha@epa.gov>. Thanks for your

response and keep reading.

<www.epa.gov/opptintr/lead/>

In an effort to make residential and federal buildings

environmentally safer for everyone, the Office of Pollution

Prevention and Toxics’ lead Web site offers a comprehensive list of educational and preventive lead poisoning

programs and lead hazard standards. Lead-based paints

were used widely at federal facilities, presenting a potential

health risk to children and adults. Included on this site are

numerous general education documents providing information on the health

hazards of lead-based

paint and lead dust

and debris, as well as

links to non-EPA

resources for lead

poisoning prevention.

<www.dtic.mil/envirodod/brac>

The DoD

BRAC Environmental Cleanup

site provides the

latest news on

emerging policies

and initiatives,

publications,

points of contact

for each branch of

the military, and

links to related

sites. A key section

housed within the site is the Defense Environmental

Response Task Force (DERTF) home page, which contains findings and recommendations related to

environmental response actions at military installations

that are being closed or realigned under BRAC legislation.

DERTF annual reports to Congress and meeting minutes

also are available.

Cyber News

Minter speaks about community

involvement at an environmental

justice symposium.

Mark your calender for : 

EPA’s 1999 National Community

Involvement Conference

May 24-27, 1999

Crowne Plaza

Kansas City, Missouri
LasagnaTM Is

Served!

To learn about the innovative

LasagnaTM Technology used to

remove trichloroethylene (TCE)

from clayey soil at the Paducah

Gaseous Diffusion Plant in Paducah,

Kentucky, Partners In Progress

interviewed Carl R. Froede Jr., of

EPA Region 4.

Q: What are your responsibilities at the

Paducah facility?

A: The Paducah Gaseous Diffusion Plant can be viewed

as two separate facilities: the active uranium enrichment

plant, now operated by the United States Enrichment

Corporation, which provides fuel for commercial reactors; and the legacy waste site, currently undergoing

remediation by DOE. Recently, I had the opportunity to

work with the Commonwealth of Kentucky and DOE

on a tough cleanup project involving TCE contaminated

soil at part of the legacy waste site we identified as Solid

Waste Management Unit 91 (SWMU 91). DOE used

the site to test the structural integrity of steel drums used

to transport uranium ore. This testing resulted in the

release of large volumes of TCE into the surrounding

soils. 

Q: What is TCE and how did the soil and

groundwater around Paducah become contaminated?

A: Before it was known how dangerous it could be to

human health and the environment, the chemical solution TCE was used at many industrial complexes as a

solvent to clean mechanical parts and components.

Although its hazardous nature now precludes its use as a

solvent, years of use and poor housekeeping practices

resulted in widespread contamination across the Paducah

facility. At the Paducah SWMU 91 site, TCE contamination of the soils and underlying groundwater is a

result of leakage from a concrete cooling tank and

splashing associated with drop-testing steel containers. 

Q: What is the goal for remediation at

Paducah?

A: Our goal from the start was to find an effective and

efficient solution for removing TCE contamination from

the soil while restoring a safe drinking water supply to

the neighboring community. Removing TCE from the

soil, the source of the contamination, is our first priority

because doing so will alleviate further contamination of

groundwater. Cleanup options were limited, though,

involving digging up the soil and either burning it to

eliminate the TCE or hauling the soil to a remote

6Partners In Progress

FromTheField
location. Neither option is ideal. DOE, EPA, and the

Kentucky Department for Environmental Protection

sought an innovative solution that would address contamination in ways that reduced toxicity, mobility, and the

volume of waste. That’s where LasagnaTM comes in. 

Q: How does LasagnaTM help you achieve

your cleanup goals?

A: LasagnaTM is an innovative technology that remediates

TCE-contaminated soil. Named for the layering of

sands, silts, and clays beneath ground level, LasagnaTM

generates an electric field in the soil that drives water

with dissolved contaminants through destruction zones

made of kaolin (a fine white clay) and iron reactive

walls. As the water comes into contact with the iron

filings, the TCE is destroyed by chemical means.

LasagnaTM performed well in two rounds of testing. In

fact, the technology showed such promise as a way to

flush contaminants out of the tight, clayey soil found at

Paducah, we signed a Record of Decision on August 10,

1998, to use LasagnaTM to remediate the SWMU 91 site.

As a result, two years of full-scale testing to verify the

efficacy of the technology at SWMU 91 has begun and

can be extended for another 18 months. 

Q: What results do you anticipate?

A: When LasagnaTM is fully operational, DOE anticipates

complete destruction of the TCE within two to four

years, as opposed to potentially hundreds of years with

conventional treatments. That’s why we’re excited. We’re

not transferring contamination to another media; we’re

eliminating it altogether.

Q: Why is LasagnaTM

called an “innovative

technology?”

A: An innovative technology is

something that has never been

done before. LasagnaTM is considered an innovative

technology because although it

involves an existing technology,

its application is entirely new.

Electro-osmosis—the process of

generating an electric current

between a positive and negative

pole in the ground—has been

used in industry for so long

that it gets big yawns from

engineers now. But adding

iron-filing reactive walls to

destroy contamination within the

subsurface and driving contaminated water through those walls, that’s where the

technology becomes innovative. 

Q: Who developed LasagnaTM?

A: DOE solicited major industries to test innovative

technologies at its facilities. The LasagnaTM group, made

up of Monsanto, Dupont, and General Electric corporations, approached DOE with this technology that

eliminates TCE. DOE selected Paducah as the most

appropriate site to demonstrate that technology and

solicited EPA’s involvement. We all worked together to

test the LasagnaTM technology.

Q: What does this mean for future

cleanups?

A: LasagnaTM gives us technology that results

in effective TCE destruction at a reasonable

cost. The cost of cleaning 1 cubic yard of soil

in this way is estimated to be $190, considerably less than alternatives that require removal

and possible transportation of contaminated

soil. This project also shows that the regulating community can work with federal

facilities and with partners in industry to

demonstrate and successfully implement

innovative technologies across the nation.

To learn more about the use of LasagnaTM at

the Paducah Gaseous Diffusion Plant, look for

FFRRO’s newest fact sheet, Cooking Up

Solutions: Cleaning Up With LasagnaTM, due

to be published in May 1999. 

7Partners In Progress

LasagnaTM in operation at

Paducah.

Photos are courtesy of DOE
At a growing number of military bases, an innovative

remediation technology proves

that it is possible to completely eliminate munitions-derived contaminants

found in soil for less money and time

than traditional treatments. Performed

on-site, composting cleans up facilities

using naturally occurring microorganisms in the soil, which

digest and break down chemical compounds in explosives

into harmless fragments that are incorporated into the

humus of the soil, creating a potting-soil quality material. 

At both Umatilla Chemical Depot in Hermiston,

Oregon, and Hawthorne Army Depot in Hawthorne,

Nevada, unlined evaporation lagoons held wastewater produced from cleaning Trinitrotoluene, Royal Demolition

Explosives, and other explosives out of decommissioned

bombs. After the water evaporated, workers excavated and

burned the residual solids. Over the years, however, the

contaminants in the wastewater seeped into the underlying

soil and groundwater, placing both facilities on the

National Priorities List (NPL) for hazardous waste cleanup. 

Testing Composting Efficiency

In an effort to save time and money, the BRAC

Cleanup Team (BCT) considered a number of innovative treatment methods to address the contamination

problem. The BCT, made up of representatives from the

Umatilla Chemical Depot, EPA Region 10, and the

Oregon Department of Environmental Quality, ultimately chose composting. Workers at Umatilla mixed

the contaminated soil with nutrients in the form of hay,

cow manure, sawdust, and potato scraps to aid in the

composting process. 

Umatilla’s use of composting represented the first time

this method was employed to remediate explosives at an

NPL site. The cleanup effort was a success. A total of

14,800 tons of soil were completely decontaminated of

hazardous substances, and the composting method saved

the base an estimated $3.8 million—approximately onehalf the cost of incineration, the treatment method usually employed. In addition, the combination of composting

and other innovative site assessment and remedial technologies reduced the cleanup time by three years. 

Repeated Success

Based on the positive results demonstrated at Umatilla,

cleanup officials at Hawthorne Army Depot and the Nevada

Division of Environmental Protection decided that composting should be used to treat contaminated soils there.

They estimated that composting could potentially save the

base $3.6 million in treatment costs. A pilot project focusing

on 2,800 cubic yards of soil was conducted in 1997. 

Workers excavated targeted soils and mixed them with

clean soil. This step was necessary because contamination levels were as high as 10,000 parts per million,

exceeding allowable levels for soil excavation. The mixed

soil was then combined with wood chips, cow manure,

hay, and potato scraps to provide the ingredients needed

for successful composting to occur. 

Workers formed the soil mixture into piles, or

windrows, adjacent to the contaminated area. They facilitated the composting process by watering and turning

the windrows daily to provide essential oxygen and water

that the bacteria need to thrive. Also, project managers

monitored moisture and temperature levels regularly to

ensure the proper conditions were maintained throughout the process. After only 20 days, composting was

completed. Sampling showed that no detectable levels of

explosives remained in the soil. The remediated soil was

used to backfill the excavated lagoons. The area was then

seeded with desert plants. Because composting produces

a nutrient-rich product comparable to an enriched top

soil, plant growth occurred easily. Due to the success of

the pilot project, composting of the remaining 41,000

cubic yards of contaminated soil began in late 1998.

Additional Opportunities for Savings

Promising results at these and other facilities demonstrate that composting is an effective and practical way

to remediate explosive-contaminated soils. The U.S.

Army Corps of Engineers estimates that $200 million

could be saved if composting were used to clean up the

remaining U.S. munitions sites. This innovative and natural decontamination approach also fulfills FFRRO’s

goal to ensure faster, more effective, and less costly

cleanups. 

To read more about composting explosives and some 

successful cleanup projects, visit these Internet sites: The

Composting Alternative to Incineration of Explosives

Contaminated Soils, <www.clu-in.org/products/newsltrs/

ttrend/ttcmpost.htm>; Innovative Uses of Compost:

Composting of Soils Contaminated by Explosives, <www.

epa.gov/epaoswer/non-hw/compost/explos.pdf>. 

8Partners In Progress

Composting

Saves Millions

Naturally

BreakingNews
and recreational opportunities.

Hunting, fishing, and hiking are just a few of the activities the citizens of Laurel, Maryland, now enjoy at

Patuxent Research Refuge, formerly Fort Meade. DoD

turned over more than 8,000 acres of the former Army

munitions testing ground to the refuge in 1991. The facility now provides a haven for hundreds of species of

migratory birds and wildlife, including bald eagles, deer,

and foxes.

EPA Remedial Project Manager at Fort

Meade, Nicholas Dinardo, recalled that

citizens did not want the facility developed

into an industrial or commercial area.

“Because of the community’s input, Fort

Meade is now a wildlife refuge.” “The

community was very supportive of the

transfer,” added Nell Baldacchino,

Education Team Leader of the Patuxent

Research Refuge. 

In the neighboring state of Virginia, the former

Woodbridge Research Facility is enjoying similar success.

Used by the Army as a radio transmission and electromagnetic research facility for 48 years, it was officially

transferred to FWS in June 1998. Today, the 580 acres of

wetlands, forests, and meadows are part of the Occoquan

Bay National Wildlife Refuge. More than 214 bird species

have already been documented on the refuge, making the

facility one of the richest concentrations of bird life in

Virginia. The tall bluffs of the refuge also provide havens

for eagles and great blue herons.

Great blue herons are also finding a home at the Fort

Devens Sudbury Training Annex in

Massachusetts, which is currently

being transferred to FWS. The

acility will primarily be used

for habitat restoration

efforts and as a migratory

bird refuge where rare species like red-tailed hawks and

osprey already have taken up residence. A variety of

other wildlife such as deer, beavers, owls, foxes, hawks,

and song birds also call the annex home. According to

Bud Oliveira, Refuge Manager at the Great Meadows

National Wildlife Refuge, FWS is working to acquire a

total of 2,205 acres of the site by the end of 1999.

On America’s west coast, Mare Island Navy Base, a

major ship construction and repair facility in California,

has undergone a successful transformation of its own. In

January 1998, FWS and the California State Lands

Commission negotiated a lease that added 2,370 acres of

the former Navy base to the San Pablo Bay National

Wildlife Refuge. This land, comprised of wetlands,

ponds, and open water, will be used primarily as a habitat

for migratory birds, waterfowl, and the endangered

California clapper rail and saltmarsh harvest mouse.

In addition to the wildlife protected by these refuges,

dwindling plant life also is reaping the benefits of base

transitions. Formerly the world’s largest TNT factory, the

Joliet Arsenal in Illinois was cleaned up and transferred by

the Army in 1997 to the U.S. Department of Agriculture

Forest Service to create the Midewin National Tallgrass

Prairie. The nation’s first federally designated tallgrass

prairie spreads across 19,000 acres, providing the nearby

community with recreational opportunities and conserving

habitats for plants and wildlife.

Successful transformation of these military facilities

benefits communities. EPA, in cooperation with DoD,

the U.S. Department of Interior, and local residents, is

working to make cleanup efforts more efficient while

providing a safe environment for both wildlife and the

public. With continued support from EPA more of

America’s closing military sites will now defend the

nation’s wildlife. 

9Partners In Progress

Going Wild

<Continued From Page 1>

“Because of the community’s input,

Fort Meade is now a wildlife refuge.”

—Nicholas Dinardo, EPA Regional Project Manager at Fort Meade, MD
that impact their lives. As stockholders, residents have

greater access to timely and correct information.

The general principle behind the Stakeholder to

Stockholder idea is to maintain the proper balance of

professional managers and community members to

ensure sound and profitable practices are carried out in

the best interest of the community. The Stakeholder to

Stockholder strategy enables residents, who might lack

the business skills or capital necessary to develop and

manage a profitable business, to own all or part of this

new business. Residents can buy stocks at a price as low

as $1 per share while professional business managers

and others with sufficient capital own the remaining

shares of stock. Cleanup and redevelopment decisions

and the resulting profits are therefore shared among all

stockholders.

The four goals of Stakeholder to Stockholder are:

• Empower community residents to meaningfully participate in environmental and economic

development: Residents who own all or part of a forprofit business will gain a larger voice in their

community’s cleanup, redevelopment, and sustainability. A business owned in whole or in part by the

community is in a unique position to help shape the

commercial development of the neighborhood. 

• Empower community residents to meaningfully

participate in environmental decisionmaking:

Community residents with a present or future equity

interest will demand more information about the

remediation component of a redevelopment project,

and have a greater influence in how the cleanup and

redevelopment proceeds.

• Improve communication between business and the

community: Traditionally, businesses that operate in

low-income or minority areas do not keep local residents informed about company activities. A business

partially owned by the community provides a model

for how businesses can interact more positively with

the surrounding community.

• Create wealth in the community by developing a

profitable business: Since Stakeholder to Stockholder

will create a for-profit business, residents should expect

the enterprise to turn a profit, of which they will

receive their fair share. In addition, the enterprise will

create other kinds of wealth such as new job skills,

opportunities for spin-off businesses, and social connections that come from broad-based community work.

Stakeholder to Stockholder businesses may be created

on publicly or privately owned Brownfields or military

bases that are being disposed of as part of the base realignment and closure BRAC process. The individual steps for

business formation are identical, but the order of those

steps might differ slightly depending on a variety of factors. The desired outcome, however, will be the same—a

profitable business owned in whole or part by impacted

community residents and operated in the best interest of

the community.

John A. Rosenthall is Director of the Howard University

Urban Environment Institute in Washington, DC.

Stakeholder to Stockholder, a project of Howard University

Continuing Education and Arthur Andersen, LLP, was developed through a cooperative agreement between Howard

University Continuing Education and EPA’s Federal

Facilities Restoration & Reuse Office (FFRRO). Stakeholder

to Stockholder pilot projects are currently in progress at

Brownfields and BRAC sites. For additional information

about Stakeholder to Stockholder contact John Rosenthall at

301-585-2295 or <jrosenthall@con-ed.howard.edu>.

Stakeholder to Stockholder

<Continued From Page 1>

An Added Benefit

Increased participation by residents speeds up

the pace of Brownfields and BRAC projects. With

broad-based community support, projects tend to

have less opposition and move more quickly

through the approval process. Waivers and exceptions, for example, tend to be easier to grant when

there is a cross-section of community support for

the request.

10Partners In Progress
Working Toward the

Safe Reuse of FUDS

by Douglas A. Bell and Sean M. Flynn

Recipients of former DoD property could unknowingly be sitting on a former military range. Most

of the more than 9,000 formerly used defense

sites (FUDS) scattered across the country are now resting in the hands of private parties. Many of these

properties are former U.S. military ranges, which were

used for everything from testing conventional, chemical,

and biological weapons to training troops. It is not yet

known how many FUDs are former ranges; however, the

military currently estimates that approximately 2,700 of

these sites contain unexploded ordnance (UXO).

Many FUDS were transferred by DoD in the 1950s

or 1960s, prior to the introduction of extensive investigation and site characterization requirements by

environmental regulators. In addition, a significant

number of these sites were located in remote areas and

generally thought to be forever out of reach by the public. As cities have expanded outward over time, some of

the more remote FUDS have become prime targets for

development or redevelopment.

Such increased public access to these sites concerns

EPA, states, citizens, and other stakeholders, given the

suspected widespread UXO contamination at FUDS 

and the uncertainties regarding exposure risks. Former

military ranges represent possibly the greatest cause for

concern because they have been relinquished from 

DoD control, in many cases without adequate site

characterization or risk assessment. Since these sites

often are being used for recreational, residential, or retail

purposes, the public might be at risk from exposure to

UXO and other military waste and not even know it.

Meaningful EPA and state involvement is essential to

ensure the protection of public health and the environment at these sites. Presently, EPA is working with DoD,

military components, and the U.S. Army Corps of

Engineers (Corps), which administers DoD’s FUDS program, to better address UXO contamination nationwide,

especially at former military ranges where UXO is

known or suspected to be present.

In addition, an internal EPA workgroup continues to

assess the challenges EPA regional offices face when

working with the Corps to oversee identification and

cleanup of FUDS. The Association of State and

Territorial Solid Waste Management Officials

(ASTSWMO) Current Issues Task Force is performing

similar work, recently conducting a survey concerning

the validity of the Corps’ cleanup assessments at FUDS.

In the spirit of partnering, EPA and the ASTSWMO

Current Issues Task Force are meeting jointly with the

Corps to discuss key issues and to mutually explore

mechanisms for working together to improve the FUDS

program through enhanced regulatory participation. 

These and other partnering efforts will result in

greater assurances that former military ranges and other

FUDS are cleaned up well enough to support safe reuse

of the property. 

Douglas A. Bell is an environmental scientist at FFRRO

where he manages military range issues nationwide. Sean

M. Flynn is a program analyst for FFRRO. 

11Partners 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:__________________________________________
Are Your Tanks In

Compliance?

by Deborah Leblang

The deadline for complying with EPA’s Underground

Storage Tank (UST) regulations has passed. If you still

have a substandard UST installed before December

22, 1988 on your federal facility, it is time for action. 

All USTs should now be protected against corrosion,

spills, and overfills. Compliance can be achieved by implementing one of the following remedies:

• Upgrade the UST by adding spill, overfill, and corrosion protection.

• Replace the UST with a new tank that has spill, overfill, and corrosion protection.

• Permanently close the UST or temporarily close the

tank until it can be upgraded or replaced.

These UST regulations are vital in preventing yet

another generation of substandard tanks from contaminating soil, groundwater, and drinking water. More than

370,000 UST releases have been reported—about half of

which have contaminated groundwater. Such leaks have

caused fires and explosions or released toxic

fumes into schools,

homes, and other buildings. Not only can

leaking USTs harm people and the environment,

but they produce costly

cleanup bills. The average cost of a UST cleanup is $125,000; groundwater

cleanups often exceed $1 million. 

Failure to meet the above requirements can result in

penalties of up to $11,000 per day, per tank, for each violation. EPA is focusing inspection resources in areas that

will produce the greatest benefits to the environment and

human health. In particular, EPA is concentrating on federal facilities, owners and operators of multiple facilities or

large facilities with multiple USTs, and facilities endangering sensitive ecosystems or drinking water.

To learn more about UST policies, visit the home page

for the Office of Underground Storage Tanks at

<www.epa.gov/oust/>. You also can order a free 16-page

booklet entitled Don’t Wait Until 1998: Spill, Overfill,

and Corrosion Protection for USTs by calling EPA’s

RCRA Hotline at 800 424-9346. 

Open manway showing catch basin

and pressurized piping (without the

line leak detector yet installed).