STREAMLINED OVERSIGHT REPORT

[Lenny Siegel <lsiegel@igc.org>]

STREAMLINED OVERSIGHT STUDY COMPLETED

The Air Combat Command (US Air Force) has released a report designed to 
reduce bureaucratic obstacles to cleanup at Defense facilities. "Moving 
Sites Faster through Streamlined Oversight" (August, 1995), produced by 
Versar Corporation, was prepared with the help of an external review 
group that included state and Federal regulators and 
environmental/community representatives (including me). The report 
analyzed the current CERCLA (Comprehensive Environmental Response, 
Compensation, and Liability Act) process and tested its proposed 
reforms through pilot activities at the Air Combat Command's Langley 
Air Force Base (in Virginia), which is on the "Superfund" National 
Priorities List.

Versar found that the current cleanup process, some of which is 
required by law but much of which is merely part of a routine, requires 
the generation of a long series of "deliverable" documents. The time it 
takes the Air Force (or other responsible parties at other facilities) 
to generate those documents, regulators to review and comment on them, 
and then for official responses, creates significant delays. Not only 
is all the paperwork costly, but regulatory agencies do not have the 
staff or contractors to read and process the quantity of documents 
currently being generated, and as the workload grows they will fall 
much further behind. We community participants agreed that often the 
sheer magnitude of document generation makes it difficult for citizens 
to keep tabs on a cleanup operation.

Versar summarized, "Findings of the report suggest that the current set 
of institutional relationships that form the regulatory oversight 
process accounts for significant time and money spent on the 
investigation and cleanup of Air Force hazardous waste sites. Estimates 
suggest that this process may account for as much as 60 percent of the 
time and 10 percent of the costs of a typical Remedial 
Investigation/Feasibility Study (RI/FS). These costs are not the result 
of individual players (regulators, Air Force, contractors, community) 
in the oversight interaction failing to conduct their jobs properly, 
but rather the existence of a system that is often driven by documents 
and deliverables, as well as definitions of roles and responsibilities 
that may be inherently inefficient."

Streamlined oversight is designed to reduce the document flow to what 
is necessary. It is based upon partnership - that is regular 
communication among decision-makers. Instead of repackaging boilerplate 
information and methodologies in every document, there should be basic 
documents and exception reports. Furthermore, problems should be solved 
by direct, frequent, and often information communication.

A significant portion of the report is dedicated to describing the 
model of "variable oversight" that the Air Force pilot-tested at 
Langley. This is defined as "Application of appropriate levels of 
regulatory oversight, based on site-specific factors, in a systematic, 
planned manner to improve the efficiency of assuring compliance with 
statutes, regulations, and agreements required for facility cleanup."

Variable oversight, the report recommends, works where there is already 
a strong level of trust among the responsible parties, regulators, and 
the affected community. In practice, it means working with the 
community - the Restoration Advisory Board, for example - to evaluate 
the many individual contamination sites that exist at a typical 
military Superfund facility. The Defense Department Risk Evaluation 
Model is used to compare risks, but other factors are considered as 
well. Those sites where cleanup is routine or minor receive less 
oversight. The serious problems may actually receive additional 
scrutiny as resources are freed from the other sites. Since this method 
of oversight depends upon affirmations of trust, the RAB - which 
normally only provides advice - is actually in a position to block it.

The Air Combat Command does not claim to have invented all of the ideas 
put forward in this report. It does not claim that its version of 
streamlined oversight is the only way to improve cleanup. But it 
definitely pulls together good ideas in a useful form.

I believe this report does the entire cleanup business - not just at 
Federal facilities - a great favor by identifying inefficiencies 
institutionalized in the standard cleanup process. Its proposals are a 
welcome alternative to the weakening of cleanup standards or the 
arbitrary capping of studies. By involving public stakeholders early in 
its process - just as RABs are involving community representatives 
early in the local decision-making process - the Air Force has come up 
with ideas that, I anticipate, will be accepted by community groups and 
thus stand a much greater likelihood of being adopted or adapted in a 
wide variety of cleanup situations.

Lenny Siegel