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ESOH Resource Transformation

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Title: ESOH Resource Transformation


1
ESOHResourceTransformation
2
Environment History
  • Common Law Property Rights
  • Property owned from Heavens to Hell
  • Restraints on use couched in nuisance
  • Development of Legislative and Administrative Law
  • Zoning
  • Sanitation
  • Conservation
  • Environmental Protection
  • Why? Because Values Change

3
Traditional E
  • Air Quality
  • Water Supply and Quality
  • Hazardous Waste
  • Pollution Prevention
  • Natural Resource (Endangered Species, Marine
    Mammals)
  • Cultural Resources (Historic Properties, Native
    American consultations)
  • NEPA (National Environmental Policy Act)
  • Noise Pollution

4
Environmental Economics
  • Environmental Laws Redefined Internalization of
    Cost
  • Rationed Resource Supply (Conservation, Permits,
    Emission Limits)
  • Created New Cost (Penalties)

5
Excellence Achieved in the Department of Defense
  • Managed Risk of Non-Compliance
  • 4,196 Hazardous Waste Cleanup Sites Completed
  • Enforcement Actions down 91 since 1993
  • Managed Hazmat Processes
  • DoD accounts for lt 0.1 of US TRI Releases
  • DoD accounts for lt 10 of US FedGov TRI Releases
  • Individual private sector sites have TRI releases
    levels exceeding DOD cumulative levels
  • Solid Waste Diversion ahead of 2005 goals
  • More TE species/acre than any other Federal Land
    Manager

6
Challenge Remaining
  • Underestimated Risk to Resource Supply and
    Capability
  • Loss of access to necessary resources
  • Increased operational costs
  • Work-arounds
  • Result
  • Encroachment
  • Lost productivity
  • Sustainment Paradigm needed for natural
    infrastructure

7
The Resource Base
  • Components of Natural
    Infrastructure
  • Airspace
  • Air Shed Emissions Availability
  • AICUZ (Noise Bands)
  • Groundwater Access
  • Groundwater Discharge Availability
  • Surface Land Access
  • Surface Water Access Discharge
    Availability
  • Subsurface Land Access
  • Spectrum
  • Work Force

8
Encroachment Risk
Competing Needs
Zoning Action
New Contaminants
Permit Limit
RESOURCE BASE
RISK
RISK
FINANCIAL
OPERATIONS
9
ESOH Transformation
  • GOAL Sustain Resource Supply to Operational
    Capability
  • Health Protection and Regulatory Compliance
    Inherent in Operability
  • PRINCIPLES
  • Identify operational and financial risks to
    resource requirements in an objective, quantified
    manner
  • Inform risk management decisions through total
    cost visibility for ESOH resource sustainment
  • Leverage equity value of the ESOH resource
    portfolio
  • Manage risk through investment that supports
    operational and regulatory requirements

10
1. Identify and Manage Operational and Financial
Risks to Resources
  • Formal modeling developed to quantify resource
    capability needed and available to support
    operational needs
  • Take proactive stance on proposed resource
    constraints (e.g., perchlorate, critical habitat
    designations)
  • Manage total resource base in Base General Plan
  • Operational metrics for ESOH-MS implementation
  • Permitted tons of air emissions
  • Restored land for operational use
  • Workforce availability (under development)

11
2. Total Cost Visibility
  • Resource sustainment carried through numerous
    funding lines
  • MILCON, Acquisition, OM
  • Limits opportunities for operational savings or
    cost avoidance
  • Total Costs and Liabilities must be identified to
    inform future resource investment decisions
  • DOD actions
  • Global regulatory actions

12
3. Leveraging Value
  • DoD managed environmental resources are now a
    commodity with an equity value
  • Tools exist to inventory and appraise public and
    private resource value
  • NRLAM (Natural Resource Liability Asset
    Management)
  • Environmental Appraising
  • Resource value intrinsic to managing risk more
    effectively and efficiently
  • Enables negotiation from positive position

13
4. Tie Programming Goals/Budget to Resource
Requirements
  • Current Environmental Program
  • DPG tied to regulatory requirements
  • Goal No open enforcement actions
  • Goal Federal Facility Agreement milestones
  • Budget tied to regulatory requirements
  • Level 0, 1 prioritization, FFA requirements
  • Investment to sustain operations (P2,
    conservation, permit enhancement) not always
    eligible
  • Transform to investment strategy that manages
    operational and financial risk across the ESOH
    spectrum

14
The ESOH Management System
15
Transformation Spheres of Influence
Operationally-Driven ESOHMS
16
Environmental TransformationMcGuire AFB
  • Replacing C-141s with C-17s
  • Ozone Non-attainment Area
  • Near Limit on NOx Budget
  • P2 Efforts Created Head Room in VOC Budget
  • Traded VOC Head Room for NOx in SIP
  • Increased Resource Availability Doubled
    Mission Capacity

Traded 200 tons/yr
17
Past PerformanceStreamlines Responses
Cohort A Small ArmsRanges
Streamlined Site Investigation
Presumptive Remedy
Set Future Use/DQOs
Focused Site Evaluation
Cohort B Boresight Ranges
Set Future Use/DQOs
EE/CA
RemovalAction
Focused Site Evaluation
Cohort C EOD Ranges OB/OD Sites
Set Future Use/DQOs
Streamlined Remedial Investigation
Focused Feasibility Study
RemedialAction
Site Evaluation
Cohort D CWM Sites
Safe to Reuse
Set Future Use/DQOs
Remedial Investigation
Focused Feasibility Study
Remedial Action
Site Evaluation
209 Munitions Response Sites
Cohort E Pyro/Prac Sites
Remedial Investigation
Focused Feasibility Study
Remedial Action
Set Future Use/DQOs
Site Evaluation
Cohort F All Other Sites
Set Future Use/DQOs
Remedial Investigation
Feasibility Study
Remedial Action
Site Evaluation
Cohort G MunitionsConstituents
Set Future Use/DQOs
Remedial Investigation
Feasibility Study
Remedial Action
Remedy Operation
Site Evaluation
18
Current and Future Actions
  • New Policy Guidance
  • Jun 02 SAF/IEE ESOH Management Information System
    Memo (ESOHMIS)
  • AFPD 90-8, Environment, Safety and Occupational
    Health
  • AFI 90-801, ESOH Management System Implementation
  • SPG/APPG inputs
  • Resource Capability Model fielded
  • Pilot tests, ACC bases, MMR, ANG pilot
  • Environmental Appraisals underway
  • Natural Infrastructure considerations in force
    shaping

19
Back ups only
20
Performance-based Cleanup Transformation
21
Environmental Transformation Cleanup
  • 1987 (then)
  • Cost to Complete (CTC) estimate 14B
  • Time to Complete estimate CY2000
  • Lack of Knowledge / Technology / Credibility
  • High Decision Uncertainty
  • Intense Legal and Regulatory Scrutiny
  • RESULT
  • Program Managed to Process Requirements
  • Goals, Objectives based on Process Milestones
  • PPB Process tied to Process Milestones
  • Massive oversight bureaucracy created

22
Need for Transformation
  • 2003 (and now)
  • Program Cost to Complete (CTC) estimate 50B
  • Time to Complete estimate
    CY2014
  • 20 years, 12,000 sites of Knowledge / Tech. /
    Cred.
  • High Decision Uncertainty
  • Intense Legal and Regulatory Scrutiny
  • RESULT
  • Program Managed to Process Requirements
  • Goals, Objectives based on Process Milestones
  • PPB Process tied to Process Milestones
  • Massive oversight bureaucracy still exists!

23
Need for Transformation
  • New Mission Requirements
  • Emerging Contaminants military-necessary
    constituents targeted by environmental regulatory
    action
  • New contaminants (e.g. perchlorate, RDX,
    1,4-Dioxane)
  • Lower standards for existing contaminants (e.g.
    TCE, PCE)
  • Ranges sustainment, off-base migration, UXOs
  • Munitions Response Program
  • Radioactive Waste Sites

24
Need for Transformation
  • Avg Time to Record of Decision 12 years
  • Avg Site Investigation Time 6 years
  • lt 25 of Cleanup Resources in fieldwork
  • Decision Documents w/o clear performance
    objectives
  • NPL/FFA construct has not provided assumed
    benefits
  • Lack of on-the-ground RCRA/CERCLA integration
  • Time structure outrun by technology
  • Added documents but not faster/better/cheaper
  • Efficacy of fence to fence designation

25
(No Transcript)
26
Air Force Performance- Based Approach to
RODs
  • Developed in course of negotiation with EPA
    Region III over Langley RODs
  • Key principles
  • Actual performance is critical (performance over
    process)
  • Notification (keep regulators and public
    informed)
  • Access by regulators to site work and documents
    to verify protective remedies
  • Accountability for on-the-ground results
  • Examples Travis, Langley, Hanscom

27
Benchmarking from EPA Leadership and Successes
  • One Cleanup Program Initiative
  • Triad/Dynamic Site Characterization
  • NPL Delistings/Deletions
  • Follow-on Reuse

28
EPAs One CleanupProgram Initiatives
  • One Cleanup Program Draft Action Plan (August
    2002)
  • Primary goal Use efficient, effective and
    protective management approaches.
  • performance over process the focus should be on
    protective results
  • Results-Based Approaches to RCRA Corrective
    Action (Sep 2003)
  • 1999 and 2002 Cleanup Reforms
  • Land Revitalization Initiative

29
TriadDynamic Site Characterization
  • Comparison of McGuire Triad Benchmark site to
    all Air Force high relative risk groundwater
    sites
  • Averaged RI phase AFRIMS data for all
    groundwater impacted sites with high groundwater
    relative risk
  • ???????

Triad site RI Benchmark Average AF RI Spill Sites (SS)
Cost 650K 898K
Duration 10 months 62 months
30
NPL Delistings
Source EPAs Comprehensive Environmental
Response, Compensation and Liability Information
System (CERCLIS)
31
Follow-on Reuse
  • OShux Golf Course Residential Redevelopment
  • Brownfields Adjacent to a Superfund site in Ohio
  • Plume from a Dry Cleaning Operation
  • Site was Redeveloped for Residential Use
  • Site Specific Groundwater Standards were
    Significantly Higher than MCLs

32
AF Environmental Program Transformation Vision
  • Natural Resources must be Sustained, Restored,
    and Modernized (SRM)
  • Metric Capability of NR to support mission
  • Business-model (Performance v. Process)
  • Cost
  • Schedule
  • Performance
  • Human Eco risk minimization is inherent
  • Regulatory Drivers not sufficient for PPB Process
    must value investment to increase NR capability

33
AF Environmental Program Transformation
Principles
  • Manage to Operational Requirements
  • Performance-Based / Business Model Approach
  • Assess and Exploit Asset Value / Environmental
    Equity
  • Invest to Buy Down Liabilities
  • Drive Down Program Costs
  • Improve Information and Knowledge Management

34
Cleanup ProgramTransformation
  • Diagnostic Tools
  • AF Management Review
  • AF Audits
  • OSD Feedback
  • Environmental Restoration Tiger Team
  • AFRIMS / MIS / RMIS
  • Way Forward
  • Apply AF Environmental Transformation Principles
  • More Effective Central Oversight
  • Greater Accountability Tools and Controls

35
Managing to Operational Requirements
  • Resource Capacity Model (RCM) quantifies
    encroachment due to resource degradation
  • Expanding SDWA Executive Agency to work
    proactively on emerging contaminants
  • Increased program visibility at Wing CC Level

STATUS Proof of Concept Pilot Test successful
working RCM into BRAC Process
STATUS Task Force formed (0-6 level) Briefing
to AF/CVA and AF ESOH Council on 10 Oct 03
implementation to follow
STATUS Quarterly Cleanup Program briefings begin
Q2FY04
36
RCM Example Pilot Test Range
Tested Metrics
Airspace Metric 2 Hours
Surface Land Access Metric 2 Developable Acres
Airspace Metric 1 Compatible Volume
Airspace Metric 3 Distance
Airspace Metric 4 Minimum Size Dimensions
Surface Land Access Metric 1 Compatible Acres
Surface Water Discharge Availability
Ground Water Access (Supply)
RR
RO3
RO3
RO2
RO2
RD1
RR
RD3
- Range has some resource opportunity Approximate
ly 1.4 airspace encroachment using Metric 1 at
range There is no validated method in AF to
size airspace for Metric 4. Required airspace
dimensions generated by 20 FW staff for Basic
Surface Attack (pilot test purposes) Approximat
ely 12.1 off-range surface land encroachment
using Metric 1
37
Performance-Based / Business Model Approach
  • SAF/IE Focus Area
  • ESOHMS applied to Cleanup Program
  • Decision Document Record of Decision Guidance

STATUS Cleanup Program Protocol being added to
FY04 ESOHCAMP (self audit) emphasizing PB goals,
CFO liabilities
STATUS Oct 03 SAF/IE Policy (AF Principles)
will set framework for performance-focused
cleanup DDs / RODs (Model procedures provided).
AF/ILE and AFRPA implementing guidelines to
follow.
38
Performance-Based / Business Model Approach
  • Performance-based Contracting
  • Information Management
  • Report Card / Annual MAJCOM PMRs

STATUS 10 of FY03 contracts are PB goal is 20
by Q3FY04
AFRIMS vs. RMIS Reconciliation
ECD Dec 03 AFRIMS/MIS vs. RMIS
Reconciliation Feb 04 New
Policies (AOCs, Reopeners, etc.) Sep 03 -
Feb 04 Conversion to web-based system with
site-level data Oct 04
STATUS First Round Oct Dec 03 starts 16 Oct
39
Effective Oversight
  • Installation / MAJCOM Report Cards and PMR
  • Special emphasis areas (AOCs, reopeners, etc.)
  • Metrics beyond DPGs (Site closeout, liability,
    CTC, etc.)
  • Briefed annually to Air Staff -- Secretariat by
    exception
  • Progress Report to Wing Commander quarterly
  • Self Audits Adding Cleanup Protocol to ECAMP
  • Significant findings tracked quarterly at
    installation, MAJCOM, and Air Staff headquarters
  • DSMOA Program Training and Improvements

40
Decrease in CTC from FY97 Baseline est.
Expenditures
Remaining CTC Liability
41
Expenditures
Expenditures
CTC Increase
CTC Liability (Baseline from FY98)
Remaining CTC Liability
42
AF Total ERA CTC
POLICY NEEDED
43
Investment
  • Training Program / Crossfeed Review
  • Process Technology Optimization Clearinghouse
  • Standardize / Institutionalize RPO
  • IPO Triad
  • Benchmarking
  • Revitalized Peer Review

STATUS Process / Technology PMR Oct 03 New
policy guidance following PMR and Tiger Team
Report
44
Way Forward
  • Adhere to Transformation Principles
  • Harness ER Tiger Team Recommendations
  • Address High Interest Items (AOCs, CTC,
    Re-openers, CFO Liabilities, Information
    Management)
  • Outreach
  • Congress (ARC Reform)
  • AF RPMs
  • OSD
  • Regulators / Stakeholders
  • OMB Comptroller

45
Next Steps
  • Complete EAGLE LOOK / ERTT Reporting
  • More Detailed Discussions with OSD Cleanup Staff
  • Vetting new AF polices on high interest items
  • Continued work on IM Systems Reconciliation
  • Follow-up Brief to PADUSD(IE) Jan/Feb 03

46
Cleanup Program Transformation
  • LTC Jeff Cornell
  • SAF/IEE
  • 1 Oct 03

47
NPL Site Totalsby Status and Milestone
National Priorities List
NPL Site Totals by Status and Milestoneas of
November 06, 2003
Status Non-Federal (General) Federal Total Sites
Proposed Sites 48 6 54
Final Sites 1084 158 1242
Deleted Sites 263 13 276
Milestone Non-Federal (General) Federal Total Sites
Partial Deletions 26 10 36
Construction Completions 846 40 886
Source http//www.epa.gov/superfund/sites/query/q
ueryhtm/npltotal.htm
48
Superfund Sites Returned to Productive Use
Sites in Productive Use Sites in Productive Use Sites in Productive Use Sites in Productive Use Sites in Productive Use Sites in Productive Use Sites in Productive Use Sites in Productive Use
Category Primary Use1 Primary Use1 Primary Use1 Primary Use1 Primary Use1 Primary Use1
Category Commercial Residential Ecological Recreational Agricultural Governmental Totals
Actual Use 64 3 16 15 3 10 111
Planned Use 15 -- 1 4 -- 2 22
Continued Use 25 2 -- -- 1 2 30
Restored Use 5 1 -- -- -- 1 7
Totals 109 6 17 19 4 15 170
1 Only the primary productive use of a site is counted, although some sites may have more than one type of productive use present (e.g., both ecological and recreational use may be occurring at the same site). 1 Only the primary productive use of a site is counted, although some sites may have more than one type of productive use present (e.g., both ecological and recreational use may be occurring at the same site). 1 Only the primary productive use of a site is counted, although some sites may have more than one type of productive use present (e.g., both ecological and recreational use may be occurring at the same site). 1 Only the primary productive use of a site is counted, although some sites may have more than one type of productive use present (e.g., both ecological and recreational use may be occurring at the same site). 1 Only the primary productive use of a site is counted, although some sites may have more than one type of productive use present (e.g., both ecological and recreational use may be occurring at the same site). 1 Only the primary productive use of a site is counted, although some sites may have more than one type of productive use present (e.g., both ecological and recreational use may be occurring at the same site). 1 Only the primary productive use of a site is counted, although some sites may have more than one type of productive use present (e.g., both ecological and recreational use may be occurring at the same site). 1 Only the primary productive use of a site is counted, although some sites may have more than one type of productive use present (e.g., both ecological and recreational use may be occurring at the same site).
Source http//www.epa.gov/superfund/programs/recycle/success/sites.htm Source http//www.epa.gov/superfund/programs/recycle/success/sites.htm Source http//www.epa.gov/superfund/programs/recycle/success/sites.htm Source http//www.epa.gov/superfund/programs/recycle/success/sites.htm Source http//www.epa.gov/superfund/programs/recycle/success/sites.htm Source http//www.epa.gov/superfund/programs/recycle/success/sites.htm Source http//www.epa.gov/superfund/programs/recycle/success/sites.htm Source http//www.epa.gov/superfund/programs/recycle/success/sites.htm
49
EPA TriadDynamic Site Characterization
  • The keystone concept of the Triad approach is the
    identification and management of those unknowns
    (i.e., uncertainties) that could cause excessive
    or intolerable errors in decision-making. An
    example of such a decision error would be to
    declare a site "clean" for redevelopment to
    proceed because contamination that would have
    been treated or removed prior to redevelopment
    was missed during sampling. The Triad minimizes
    the likelihood of mistakes by cost-effectively
    supporting the development of an accurate
    conceptual site model (CSM). Briefly, a CSM is
    any graphical or written representation (or
    "conceptualization") of site contamination
    concerns how it got there, whether or not it is
    migrating or degrading, how variable
    concentrations are across the site, what
    receptors might be exposed, and what
    risk-reduction strategies are most feasible. An
    accurate CSM is a primary work product of the
    Triad approach that is refined and matured over
    the course of an investigation. To develop an
    accurate CSM, the Triad approach incorporates the
    elements of systematic project planning, dynamic
    work plan strategies, and real-time measurement
    technologies into a decision support matrix
    designed to manage uncertainties associated with
    environmental restoration projects.

Source Using the Triad Approach to Streamline
Brownfields Site Assessment and Cleanup.
(EPA 542-B-03-002 June 2003)
http//www.brownfieldstsc.org/Docs/Triadprimer.pdf
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