MMRP PA/SI Survey Summary EPA National Site Assessment · MMRP PA/SI Survey Oversight Issues •...

U.S. EPA Office of Solid Waste and Emergency Response

MMRP PA/SI Survey Summary EPA National Site Assessment

Conference June 20, 2007

U.S. EPA Federal Facilities Restoration and Reuse Office

U.S. EPA Office of Solid Waste and Emergency Response

MMRP Program Background

• Munitions Response Site Prioritization Protocol (MRSPP)– Required by Congress– Final Rule in Federal Register Oct 5, 2005– National “Rack & Stack” initiative for response

action & funding priorities - Relative priority tool– Will not be complete until after 2011

• 3,316 DoD MMRP sites scheduled to finish Site Inspections by 2010 – use as input data for MRSPP ranking

U.S. EPA Office of Solid Waste and Emergency Response

MMRP Program Background

• MRSPP – Three Modules– Chemical Warfare Materiel– Explosives Hazard Evaluation– Human Health Evaluation

• Other DoD programmatic goals include: – HRS Information to EPA– Removal Action Recommendation– NDAI– RI/FS Recommendation

U.S. EPA Office of Solid Waste and Emergency Response

MMRP PA/SI Survey

• Purpose: to better understand EPA & State level of involvement, as well as to identify key issues, challenges, etc

• Sent to Regions and States in Nov 06• Responses evaluated in Feb/March 07• Summary Report sent out on April 10,

2007 to EPA, States, DoD

U.S. EPA Office of Solid Waste and Emergency Response

MMRP PA/SI Survey Results

• 50 responses received from 9 Regions, 19 States, Puerto Rico, District of Columbia

• Respondents include; RPMs, SAMs, FF Coordinators, Managers

• All respondents indicated some level of understanding of the MRSPP

U.S. EPA Office of Solid Waste and Emergency Response

MMRP PA/SI Survey Results

• DoD Outreach: 68% State and 48% EPA respondents answered YES

• OSD MRSPP and USACE FUDS primary outreach venues

• States indicated a much greater level of involvement in MRSPP than EPA Regions. Likely due to high level of FUDS in the MMRP Inventory

U.S. EPA Office of Solid Waste and Emergency Response

MMRP PA/SI Survey Results

• EPA Regions reported more general coordination meetings than States

• All respondents that indicated generally positive interaction for MRSPP also indicated regular coordination meetings

• Lack of resources, travel restrictions, lack of formal agreements cited as coordination impediments.

U.S. EPA Office of Solid Waste and Emergency Response

MMRP PA/SI Survey Key Issues

• Adequate funding is needed• Adequate planning, DQO agreements,

early involvement are needed• Additional oversight resources needed• More MMRP training needed• PA/SI scope is too limited• Inadequate PA = poor starting point

U.S. EPA Office of Solid Waste and Emergency Response

MMRP PA/SI Survey Key Issues

• Better MMRP Inventory, schedule info• PBC driving the train, affects dialogue• EPA Regions want HQ direction on

expectations, resources• Use of approved analytical methods• Stakeholder involvement• Involve State & EPA as equal partners• Better coordination between HTRW & MMRP

U.S. EPA Office of Solid Waste and Emergency Response

MMRP PA/SI Survey Oversight Issues

• Additional oversight resources needed• More MMRP training needed• Better MMRP Inventory, schedule info• Fast track known MEC site to RI/FS• Look at the out years: Lots of RI/FS in

the pipeline

U.S. EPA Office of Solid Waste and Emergency Response

MMRP PA/SI Survey Oversight Issues

• Consider use of enforcement tools, dispute resolution for inadequate reports

• PA/SI limitations– May not support HRS requirements– May not support NDAI recommendations

U.S. EPA Office of Solid Waste and Emergency Response

MMRP PA/SI Survey Recommendations

• Evaluate support contracts for PA/SI reviews

• Develop better info on MMRP Inventory and schedules– HQ Effort to build national tracking data

base– USACE EKO webpage for MMRP FUDS

U.S. EPA Office of Solid Waste and Emergency Response

MMRP PA/SI Survey Recommendations

• FFRRO to develop MMRP PA/SI guidelines for Regions – When to participate– NPL implications– Data sufficiency to support decisions – Draft discussed with FFLC & Fed Forum, FF

Docket Coordinators

• Resolve disconnects between EPA PA/SI Guidance, and DoD MMRP PA/SI execution

U.S. EPA Office of Solid Waste and Emergency Response

QUESTIONS ??

• Doug Maddox, FFRRO 703-603-0087

• Kevin Oates, FFRRO 334-270-3427