Emerging environmental health contaminants
New scientific information about chemicals released into the environment may prompt regulatory changes that can impact a broad range of Defense Department (DoD) activities. Noblis has provided a broad spectrum of expertise in supporting an “emerging contaminants” effort that scans the horizon to identify these chemicals and manage their impacts on DoD personnel, training ranges, weapons development, and operations. This has enabled a fully informed, risk-based investment decision process that protects human health, the environment, and DoD operational capabilities.
Onsite technical support for Air Force base transition to public lands
Cleaning up and closing DoD bases so they are suitable for other public uses poses tremendous environmental, technical, managerial, and legal challenges. Pressure is often placed upon base closure personnel to accelerate cleanup and transfer property to the public for redevelopment. However, responsible base closure manager access to professional and technical support to carry out the process is often constrained due to staff migrating to more secure, long-term jobs within the federal government. Noblis was asked to provide staff support at bases undergoing closure on a full-time, dedicated basis and provide independent counsel to the government regarding contaminant investigations and cleanup, exit strategies, budgeting, property transfer, demolition, and regulatory facilitation. Noblis’ technical assistance has contributed to keeping the process on track towards redevelopment to the benefit of both the public and the government.
Water infrastructure at an active military installation
The water system at a DoD facility was interrupting mission critical activities by falling short of meeting the facility’s needs. Noblis was asked to mobilize a team on short notice to analyze and address the problem. The work involved conducting site evaluations, engineering reviews, personnel interviews, database analyses, and hydraulic evaluations. Results of the effort included devising solutions to the water system failures without disrupting mission critical activities at the base. Further engineering reviews and evaluations of contractor proposals were recommended when installing upgrades to ensure that water system supplies can meet future demand.
Optimizing environmental restoration at Department of Defense bases
Environmental cleanups at DoD bases involve a host of technical, regulatory, and programmatic elements. The Air Force asked Noblis to evaluate cleanups at a large number of its bases to ensure they are effective and moving towards regulatory approval of site closeout. During intense, week-long site evaluations, Environmental Restoration Program Optimization (ERP-O) teams of Air Force, Noblis, and other experts with diverse specializations verify cleanup goals and strategies, evaluate the performance of current cleanup efforts and recommend innovative technologies to ensure cleanups protect the public. As part of the review, the teams brief base environmental managers, state, and federal regulators on their key findings and conduct follow-up activities to track implementation and communication of their recommendations. Noblis has led ERP-Os at over 40 DoD bases, resulting in increased protectiveness, earlier site completion, and significant long-term cost avoidance.
Restoration recommendation tracking matrix
The durable value of ERP-O reviews is contained in a set of key recommendations for follow-on activities at the base. These recommendations require varying levels of follow-through to be effectively implemented. Without implementation, the value of the recommendations is lost. Accordingly, Noblis was asked to develop a process for tracking the progress of implementing various ERP-O recommendations and to identify the impacts of those recommendations on key program metrics such as risk, cost, and schedule. Maintaining an appropriate level of detail and ensuring follow-through on each recommendation is critical to effective long-term management of DoD environmental legacies. An ERP-O recommendation tracking system specifies:
The recommendations.
The party responsible for implementation of the recommendation.
How the recommendation will affect current risk to human health and the environment.
The impact of the recommendation on the time to cleanup and potential closure.
Estimates and actuals of the costs to implement the recommendation.
Estimates and actuals of cost savings realized through implementation of the recommendation.
A metric system used to follow the recommendation through the various phases of implementation including:
regulatory buy-in
award of implementation contract
completion of implementation work plan
actual implementation, and
project close-out.
Status of each recommendation (e.g., pending, canceled, ongoing, postponed, etc.).
Noblis support allows each ERP-O recommendation to be tracked from development through complete implementation. By using this tool, the success of the cleanup program can be ascertained and managed more carefully by the DoD.
Engineering and water resource evaluations
Noblis experts were asked to provide an independent analysis of the operation of a wastewater collection system at an Air Force base. The team reviewed the engineering, legal, and regulatory issues related to the base’s water infrastructure. Noblis enhanced base operations by optimizing the wastewater collection system and by supporting new technical and managerial approaches to water resources and water rights.
Defensible Five-Year Review cleanup at an Air Force facility
At former military installations where environmental restoration has been implemented under the nation’s major cleanup law, Five-Year Reviews are required to evaluate the implementation and protectiveness of cleanup actions that have left contamination at the site. Noblis experts were asked to provide an independent and conflict-free review and analysis of the protectiveness of cleanup remedies at former Air Force bases. The broad technical expertise used in conducting these Five-Year Reviews has resulted in U.S. Environmental Protection Agency (USEPA) and state regulatory acceptance of the public health evaluations.
Vapor intrusion handbook for guiding risk assessments
The DoD asked Noblis to develop an assessment handbook for evaluating vapor intrusion—the movement of pollutants from the ground into the indoor air of buildings used by Army, Navy, Air Force, and Marine personnel. The handbook is an informational resource for base remedial project managers and complements vapor intrusion guidance developed by state and federal environmental regulators. It also builds upon guidance previously developed by the Air Force, Navy, USEPA, and the Interstate Technology and Regulatory Council. The handbook addresses site-screening, sampling and analysis, site-specific vapor intrusion assessment, risk assessment, site mitigation and remediation, and risk communication. Following detailed review by Armed Services representatives, a nationwide distribution of the handbook began in the spring of 2008.
Environmental cleanup program integration
Noblis works closely with the Air Force to develop practical, responsible solutions to hazardous waste releases at closed military installations. A team of technical experts with diverse specializations combine scientific information about the physical environment, chemical contamination, and potential ecological and health impacts on the sites. This assessment is integrated with engineering, financial, legal, and policy information to develop innovative, practical solutions that protect human health and the environment. The team’s independence allows it to seek solutions that balance legal, economic, environmental, and social factors in a way that serves public and governmental goals. The team can gather and evaluate its own technical data, independently evaluate technical inputs from regulatory agencies and cleanup contractors, and present unbiased technical analyses and recommendations to the Air Force, regulatory agencies, and the public. This independence also allows for the evaluation of emerging technologies and scientific trends, the incorporation of legal requirements and budgetary guidance, and builds consensus among the Air Force and environmental regulators for innovative, practical responses to hazardous waste.
Long-term monitoring innovation
Contaminated groundwater at a major DoD site was being monitored through water sample collection from hundreds of wells arranged in networks. A Noblis team of experts was asked to optimize the sampling program to eliminate redundancy in data collection for three of these Long-Term Monitoring (LTM) networks.
Current approaches used by environmental scientists to optimize LTM networks use conservative assumptions and rely on complicated mathematical methods that are difficult to interpret. The Noblis team developed a novel and simpler approach to LTM optimization that leverages the professional judgment of scientists who understand the movement of water through various types of underground soil and rock formations to ensure that the results are realistic for the site. The new design squarely focuses on addressing the principal objectives of LTM networks to:
- Evaluate the performance of the cleanup effort and
- Monitor protection of human health and the environment.
In devising this innovation, the team analyzed trends in groundwater samples from the wells to determine if underground contaminants were moving. If not, a new LTM program was then developed for each polluted area based on seven key criteria articulated by the team. If implemented, the proposed LTM approach designed by Noblis would result in an 80 percent reduction in groundwater sample collection. This would lead to considerable cost savings for the DoD, while at the same time offering sufficient monitoring of any potential environmental health threats.
Template for Records of Decision at Air Force cleanups
The Pacific Air Force Command (PACAF) asked Noblis to design a template for a key regulatory and legal instrument that details the scope of planned cleanup efforts for sites with significant environmental contamination. A Record of Decision (ROD) is a durable administrative tool detailing an investigation of site contamination and the technical nature and feasibility of proposed cleanup plans. In conducting reviews of previous RODs, the PACAF determined that there was significant variation in the quality and level of detail of their RODs and sought to ensure greater consistency in developing them in the future. Noblis developed new standards for a ROD template based on USEPA cleanup and decision document guidance using consistent language and specific information to include in site-specific sections. To support dissemination of the template, Noblis conducted two different ROD training sessions for the PACAF that addressed the technical, regulatory, and legal requirements for RODs and how to employ the ROD template.
Remedial action oversight and operation
Ensuring the effective coordination of cleanup activities by multiple contractors at contaminated DoD sites poses significant challenges. Noblis was asked to integrate a variety of data collection and cleanup activities to ensure they met regulatory, managerial, and technical oversight requirements. The tasks involved supporting the cleanup of 13 contaminated groundwater plumes and over 20 soil sources at a DoD base. Noblis tapped experts to collect and integrate data and coordinate soil removal actions at over 300 sites on the base. The team devised path-breaking ways to coordinate responses to complex environmental challenges by combining multiple cleanup tasks into a smaller number of actions. Simultaneous data collection from monitoring wells common to multiple remedial programs has addressed a variety of cleanup efforts at the same time, thereby significantly reducing costs and administrative burdens. The system designs have led to efficiencies that were achieved while strengthening public health protections.
Practical guide for junior Air Force bioenvironmental engineers
Air Force bioenvironmental engineers (BEEs) receive extensive technical training for the functions they perform in their multi-faceted work. However, they receive comparatively little preparation for the practical demands of planning, executing, and reporting on daily activities in a BEE unit. The Air Force asked Noblis to develop a practical guide to working in and administering the technical tasks of a job in a typical BEE unit. The guide presents the jobs that must be done, tools for administration and staffing, methods for scheduling work, preparation for inspections, handling emergencies, guarding the health of workers and families, and many other activities. The guide is designed as a workbook that can be tailored to a junior BEE’s specific activities and duties. The guidebook is contained in a large three-ring binder that allows each airman to customize technical and managerial tools and add and update information as his or her particular job unfolds.