Amy Jo Petersen

For decades, activities within the military have created a substantial amount of hazardous material, from explosive chemicals to abandoned drums of toxic waste. Moreover, many officials on defense sites were disposing of such hazardous waste without proper containment. As a result, many military bases have significant soil and groundwater contamination that warrants remediation. Recent attention to these kinds of threats to our environment and public health have sparked recognition under federal law regarding cleanup of these sites. The Department of Defense has established a nation- wide program called the Defense Environmental Restoration Program (DERP) to restore contaminated sites to their native condition.

DERP was officially established by Congress in 1986 under the Superfund Amendments and Reauthorization Act (SARA). This reauthorization was implemented to deem the government accountable for remediation of contaminated sites owned by the DoD. SARA was a spin-off of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) which was originally created to force major petroleum companies to clean-up contaminated sites (DoD, 1996). Not only does the amendment designate responsibility, but SARA allows funding to be allocated for the DERP (DoD, 1996). SARA provides a framework for the remedial clean up of hazardous substances associated with past DoD activities (DoD, 1996).

The primary goal of DERP is to identify and remove any hazardous materials and contaminants that pose a threat to humans and/or their environment on military sites. (DoD, 1996). A major component of DERP is the Installation Restoration Program (IRP) which designates restorations on active military sites. The IRP puts emphasis on the remedial action of contamination on a time-critical basis. For example, if a site is determined to be time-critical, it must implement removal action within six months (Guam EPA, 1996). Otherwise, it is considered non-time critical and imposed action will be subject for restoration at a later date. DERP incorporates the removal and remedial clean-up at Formerly Used Defense Sites (FUDS) as well (DoD, 1996). Both the IRP and the FUDS fall under the same protocol in terms of evaluating the level of contamination under the DoD restoration program (DoD, 1996).

Who administers the program?

The office of the Secretary of Defense makes the major policy decisions for the program and renders oversight of the legal aspects. The DoD is the liable party for remediation and removal of hazardous chemicals on defense sites that are still owned by the DoD (DoD, 1996). Under guidance of the Environmental Protection Agency, staff of the DoD performs the actual removal of contaminants, along with many public and private sector contractors to help complete restorations (Guam EPA, 1996). This can be problematic because of the lack of continuity among the different stakeholders involved in the restoration process (Clean Sites, 1997). Although the DoD has established restoration protocols for assessment, techniques used to remove pollutants, and monitoring procedures, it remains difficult to achieve consistency in these protocols between the various defense sites across the US. Shortly after SARA was enacted in 1986, there was a devolvement of funds for DERP, thereby allocating funding for each division of the defense for the installment of restoration for their military bases (Petersen, 1998).

The restoration protocol is composed of a preliminary assessment, a remedial investigation, an engineering evaluation and cost analysis, remedial action plan, and remediation and removal is the last step (DoD, 1996). The initial assessment involves investigation of the soil and groundwater to determine the level of contamination. Samples are taken from the site and tested to evaluate what the constituents are and the amount of danger that they pose.

The next step of the remedial investigation is to determine the long-term risks of the contamination on a specific site. For example, based on the level of constituents within contaminated soil and groundwater, the samples are ranked under a hazard ranking system. If the ranking is relatively high, the site will be put on the National Priority List which provides a means for uniform judgement for immediate action (Petersen, 1998). If the ranking is below the federal standards it may still warrant remediation, but immediate action is not necessary.

The third step involves an engineering evaluation and cost analysis to look at different alternatives for remedial action and to give direction for a specific type of removal. For example, the DoD encourages on-site removal of landfill contamination because it is less costly then having to send out the hazardous waste for someone else to remediate (Petersen, 1998). The main goal is to use current technology in a cost-efficient fashion (DoD,1996). After evaluating what types of equipment are needed and the cost analysis is determined, a remedial action plan is designed. Remedial action plans may include procedures such as landfill capping, thermal desorption, bioremediation, and solidification of heavy metals depending upon the ecosystem in need of restoration.

DERP was designed to restore various ecosystems that lie within the military bases, especially soil and groundwater systems. For example, the DoD is responsible for restoration at sites where leaky underground storage tanks are found. The leaky tanks are pulled out of the ground and replaced with double-walled plastic or steel structures. The soil surrounding the tank is tested and the gross contaminated soil goes through a thermal desorption process (Guam EPA, 1996). This type of removal consists of placing the contaminated soil in a large autoclave to thoroughly heat the material. This breaks down the adsorbed organic materials into less harmful material that can be released into the air (Guam EPA, 1996).

Another type of soil restoration method that occurs under the DERP is bioremediation of gross contaminated soils (Guam EPA, 1996). Bioremediation incorporates the utilization of natural components such as air, water, and solar radiation to break down the organic materials that are found in the soil. If the soil has been found to be of high toxicity, the soil is removed from landscape and placed on a concrete surface to be exposed to air, water, and heat until the toxins are eliminated. This practice is encouraged for on-site restoration and more suitable in terms of cost-efficiency, and minimizing energy use.

The solidification of heavy metals found in the soil on-site has been implemented to reduce infiltration into soil and groundwater ecosystems is a common way that the DoD completes a restoration of this type (Petersen, 1998). To remediate the soils contaminated with heavy metals such as lead and mercury, concrete is mixed with the soil to eliminate further leachate into the groundwater and surrounding landscape (Petersen, 1998).

To further demonstrate how the DoD meets the criteria under DERP, a restoration at the Construction Battalion landfill at South Finegayan US Navy Center in Guam is described. This landfill has been used to dispose of vehicle parts, domestic wastes, and construction debris (Guam EPA, 1996). The Navy had been burning the waste on this site and undoubtedly contaminated the soil for many years (Guam EPA, 1996). As a result, the soil underneath the landfill were not within federal standards, which poses a threat to the plant and wildlife community, and to humans as well. This landfill actually lies directly above Guam’s main aquifer, which was one of the DoD’s main intentions to perform remedial action. However, the concentrations of contamination leaching into the aquifer a within federal standards and not posing a threat at the current time (Guam EPA, 1996).

A remedial action plan was developed to clean-up the surface soil to bring back the natural community at this site. The plan was designed to reduce infiltration of contaminants into the soil from rainfall, to ensure that the groundwater receives little or no impact from the landfill (Guam EPA, 1996). In order to accomplish this goal, the DoD has implemented a remedial structure consisting of a impermeable capping system to reduce penetration into the soil and groundwater (Petersen, 1998). Furthermore, this remedial action involved a soil buffer system, placing clean topsoil to support vegetation over the membrane liner. It is important to not only complete the initial remediation but to restore the landscape to a more natural condition to stimulate a biotic community. This remedial structure has been effective thus far, with no reports of further contamination in the soil community (Guam EPA 1996).

All of the methods that have been discussed are highly encouraged and are implemented in a very systematic approach. The DoD encourages the utilization of on-site restorations for cost- efficient approaches (DoD, 1996). On the other hand, off-site restorations are highly discouraged, because of the expense of contracting it out and sending it off-site.

Public outreach is strongly encouraged and is a fundamental part of this program. This is achieved by initiating public reinvestment programs, to secure continual support of public involvement and economic progress for the restored landscape. For example, after a site is closed and contaminants are removed, community reinvestment is essential for redevelopment of the area (DoD, 1996). This demonstrates that these restorations are not an attempt to put a band-aid on the contamination, but to restore this habitat to a more natural environment. Community involvement needs to be improved by creating initiatives to invest in the restored sites that have been closed (DoD, 1996).

The DoD determines the amount of success in their restoration efforts in many ways. First of all, the DoD uses monitoring wells to evaluate the amount of contamination running through the soils and groundwater systems (Petersen, 1998). The main purpose is to ensure that contaminants are no longer percolating underground. The DoD has contracted a Clean Sites organization to review the effectiveness of DERP, including a comprehensive analysis of administrative techniques, remedial action plans, cost-efficiency, and long-term effects on the ecosystems (Clean Sites, 1997). Restoration Advisory Boards (RAB) are essential to assess effectiveness as well. RAB’s play an important role for revisions of the remedial action and/ or removal.

Overall, DERP is committed to restoring contaminated sites for future land use by the community, and attempts to control pollution that has occurred on past military sites through protocol created by Congress.

Clean Sites Organization. Clean Sites <http://www.cleansites.org/dod.htm.> <August, 1997> <May 4, 1998>

Department of Defense. Department of Defense Environmental Restoration Program. <http://www.dtic.mil/envirodod/> <April 22,1996> <April 26,1998>

Guam EPA. CleanUp at the South Finegayan Construction Battalion Landfill US Navy Public Works Center, Guam. Fact Sheet No. 4. 1996.

Petersen, Mark. Site-Manager for EPA. Telephone Interview. May 15,1998.

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