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Department of Interior

Recommendations and Actions

DOI14: Enhance Environmental Management by Remediating Hazardous Material Sites

BACKGROUND

As the nation's principal conservation agency, the Department of the Interior (DOI) is responsible for most of the U.S.' federal lands and natural resources (over 440 million acres). These lands are geographically dispersed across the country. The DOI mission statement emphasizes preserving the environmental values of these lands and providing for the enjoyment of life through outdoor recreation. Some DOI lands were formerly used as defense sites or for industrial purposes and were contaminated with hazardous waste. The Environmental Protection Agency (EPA) currently lists 432 DOI facilities on the Federal Agency Hazardous Waste Compliance Docket.

The department is continuing its efforts to identify hazardous materials (HAZMAT) sites that result from the effects of human activities on lands under its jurisdiction. Because a large portion of DOI lands are open to public access for activities ranging from hiking and fishing to the operating of mines, additional contamination can still occur. Maintaining an accurate inventory of these HAZMAT sites is therefore an ongoing process. DOI needs to increase its effort to address HAZMAT cleanup on its lands. Because of the high costs of remediation, DOI must make maximum use of existing resources.

Several of the bureaus within DOI, including the Bureau of Land Management, Bureau of Indian Affairs, National Park Service, and Fish and Wildlife Service, have primary responsibility for managing lands where hazardous materials have been identified. These agencies have skills in land and natural resource management, provide training for professional staff in handling hazardous materials, and provide contract oversight for activities on their lands ranging from national park concessionaires to reclamation of polluted lands.

Other bureaus, including the U.S. Geological Survey, Bureau of Mines, and Bureau of Reclamation, have scientific and technical expertise for assessing hazardous materials sites and assisting with site construction and oversight. Decisions related to mitigation of HAZMAT sites cannot be made without reliable data about the sites in question. Above all, coordination of scientific understanding with management issues is crucial when fulfilling responsibilities for the resources and people on these lands.

Therefore, an integration of managerial and scientific expertise should be implemented to yield cooperative approaches to HAZMAT site assessment and remediation. The complementary capabilities of bureaus have the potential of providing high-quality, objective information for planning remediation of hazardous waste sites. A multi-bureau, team approach to planning HAZMAT remediation that draws on DOI's full array of in-house resources should be implemented.

A memorandum of understanding was signed in 1991 by DOI, the Western Governors' Association, and other federal agencies to work on a collaborative approach to the development of technical solutions for environmental restoration. The purpose of the partnership is to test ways to expedite the deployment of innovative technologies for cleanup. Following a departmentwide HAZMAT conference in 1993, the Assistant Secretary for Water and Science recommended that DOI designate pilot projects to develop remediation plans for contaminated lands in the western states. The purpose of the pilots is to test the use of in-house expertise to develop a strategy for cooperative assessment of HAZMAT sites.

Pilot projects are needed to demonstrate new models for state and federal partnerships. Pilots will also provide an opportunity to field-test new technologies for remediation. These model approaches and technologies should lead to achieving cleanup goals more rapidly and at less cost than current methods.

DOI needs to send a strong message that pollution of public lands is unacceptable. Responsible parties should be prosecuted to the full extent of federal law and be held liable for cleanup costs. However, before a remediation program can be fully realized, the department needs to surmount legal and fiscal obstacles.

DOI must pursue enhanced enforcement authority to clean up departmental lands by those parties actually responsible for the pollution. At present, the department has no enforcement authority in this area. A remediation and restoration effort based on the principle that polluters pay will require a financial investment in planning and oversight. Because of the large number of sites, high cost of cleanup, and the length of time it takes to plan for and reclaim HAZMAT sites, DOI must plan for the long term. Resolving the HAZMAT problem will ultimately demand additional legal and fiscal resources.

Establishing a legal strike force will enable bureau environmental staff to work with DOI attorneys toward common departmental remediation, cleanup, and restoration goals. DOI strike force attorneys will also work with other federal agencies, including the EPA, to cooperatively address legal and liability issues that present obstacles to cleanups.

ACTIONS

1. DOI should integrate managerial and scientific expertise in cooperative, cross-bureau approaches to hazardous material site assessment and remediation.

To accomplish this goal, the development of formal cooperative agreements among bureaus for planning and implementing cleanup of specific sites is necessary. Other methods include use of intra-bureau personnel exchanges, electronic bulletin boards, and collective data-base development.

2. DOI should designate several hazardous material sites as pilot projects for cooperative, multi-bureau assessments to develop remediation plans.

The pilots should be designed to model collaborative approaches and demonstrate new and innovative cleanup technologies. Four pilot sites should be identified on DOI lands in western states during 1993. The sites should be selected in consultation with the Western Governor's Association HAZMAT group.

One pilot site should be selected to begin implementation in fiscal year 1994. Site assessment and evaluation and design of a remedial effort should occur during fiscal years 1994 and 1995. At the end of 1995, an evaluation of the effectiveness of the demonstration project should be conducted. If the demonstration project is successful, implementation of the remediation plan should begin in fiscal year 1996, and work should begin at another pilot site. The remaining two pilots should be started, one each year, in fiscal years 1997 and 1998.

3. DOI should establish a legal strike force by the end of 1994 to address barriers to cleanup.

Aggressive enforcement and cost recovery actions are necessary to ensure that the polluter pays. The department must have increased enforcement authority to compel the parties responsible for pollution of a site to pay for the cleanup. DOI must also have the ability to retain and use the monies recovered through cost recovery actions to pay for the actual costs of cleanups on DOI land.

IMPLICATIONS

The phased approach to site identification and remediation planning is important to ensure that resources are used wisely and that time is permitted for resolution of legal issues. After completion, these approaches and technologies can be compared to traditional, contractor-dependent remediation on the basis of cost-effectiveness and reliability. The use of in-house resources in DOI remediation efforts would increase accountability and quality control. Inter-bureau cooperation would also improve DOI's ability to track its dynamic HAZMAT inventory.

FISCAL IMPACT

In fiscal years 1992 and 1993, DOI spent about $70 million on HAZMAT-related activities, with costs reported individually by bureau. These expenditures included site inventory, evaluation, and prioritization; staff training; safety and environmental compliance; pollution prevention; and management of HAZMAT sites. Only a small percentage of these funds represent actual cleanup of contamination. Cooperative, cross-bureau agreements which emphasize resource sharing are needed to ensure that the overall DOI effort is cost-effective and efficient.

DOI proposes cooperative efforts integrating managerial and scientific expertise within current resource levels. However, planning the assessment and remediation of HAZMAT sites requiring cleanup will demand an investment of additional resources. DOI estimates that implementation of a pilot program to demonstrate cooperative HAZMAT assessment and remediation at a single site will cost about $14 million over a five-year period.

Additional expenditures of approximately $550,000 per year would be required for any year after completion of the pilot project and prior to the start of the actual cleanup. These expenditures would be needed to maintain the integrity of the site and to continue low-level data collection for monitoring at the site. DOI also estimates that one additional full-time equivalent (FTE) will be needed to coordinate the pilot project at a total cost of $100,000 per year (salary, benefits, and administrative support) over the five years.

This proposal does not fund the actual cleanup of the contaminated sites. The start of the cleanup would depend on the resolution of legal issues and the availability of funds. EPA estimates actual cleanup of an average Superfund site is about $30 million over several years. Cleanup must then be followed by site operation and maintenance over a 20-year period estimated to cost about another $3.8 million. These estimates indicate an investment for complete cleanup of a single site at nearly $50 million. Many experts believe these figures underestimate total costs, but they are the most accurate to date.

To establish an effective legal strike force, the department estimates an additional seven FTEs would be required. These positions, with associated salaries, benefits, and administrative support, would cost $600,000 per year. The large-scale commitment of resources needed to address the restoration of HAZMAT sites makes these recommendations for cooperative pilot and legal enforcement approaches critical. The remediation process is too costly to risk wasting resources on untested approaches and too lengthy to proceed without enforcement authority and the ability to ensure that polluters pay for cleanup.

	Budget Authority (BA) and Outlays 
	    (Dollars in Millions) 
 
 Fiscal Year
 
		1994  1995  1996  1997  1998  1999   Total
 
 BA*		2.1  	 3.9   	  6.0     4.1     1.3     1.3     18.7
 
 Outlays	2.1  	 3.9   	  6.0     4.1     1.3     1.3     18.7
 
 Change in FTEs 
		7    	 7     	  7          7       7       7         7

*Note: Budget authority reflects the cost of seven new FTEs, one HAZMAT pilot project for years 1994- 1998, and site monitoring costs for 1999.

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