  |
|||||
|
|
NASB Clean-Up Program Overview Restoration Advisory Board (RAB) Meetings Recent and Upcoming Field Activities NAS Brunswick Team Organizations Historical Radiological Assessment Links
|
Comprehensive Environmental Response Compensation and Liability Act (CERCLA) Program In 1975, the Department of Defense (DoD) began a pilot program to investigate past hazardous waste disposal at DoD facilities. The primary regulatory and administrative program that drives environmental cleanup at NAS Brunswick is CERCLA. Congress passed CERCLA in 1980 to protect human health and the environment by establishing a comprehensive regulatory framework for investigating and remediating uncontrolled releases of hazardous substances. CERCLA addresses uncontrolled releases of hazardous substances where contamination resulted from past practices (often from facilities no longer in operation). CERCLA set up the original “Superfund” for cleanups of hazardous waste sites. Sites eligible for cleanup using Superfund are listed on the National Priorities List (NPL). The Superfund Amendments and Reauthorization Act (SARA) was passed by Congress in 1986. An important provision of SARA included federal facilities in the Superfund process, although federal facilities such as NAS Brunswick are not eligible for Superfund cleanup funds. As a result of SARA, DoD established the Defense Environmental Restoration Account (DERA) to fund studies and cleanups at military installations. The Federal Agency Hazardous Waste Compliance Docket (FAHWCD) is used to identify federal facilities that must be evaluated. The purpose of the FAHWCD is to determine if a facility poses a risk to human health and the environment under CERCLA and to provide a mechanism to make this information available to the public. For each listed site, the responsible facility must complete a Preliminary Assessment (PA) and, if needed, a Site Inspection (SI) to determine of CERCLA response actions are required. Preliminary Assessment/Site Inspection (PA/SI) During the PA/SI, a facility is surveyed to determine whether past activities may have generated hazardous wastes, what those wastes were, and what was done with the wastes. This survey includes reviews of old records, interviews with current and former employees, and an inspection of the facility. Preliminary soil and water samples may be collected at specific sites identified during the PA/SI and a determination is made on whether additional investigation is warranted. After reviewing the data collected from a federal facility, EPA may list the facility on the NPL. NPL Listing EPA uses the Hazard Ranking system (HRS) as a scoring system to evaluate relative threats to public health and the environment posed by uncontrolled releases or threatened releases of hazardous substances. The HRS uses information obtained from the PA/SI to assign each site a score based on the likelihood that contaminants have been or will be released from the site. Sites scoring above a minimum score are eligible for placement on the NPL, which designates those sites representing the highest priority for further investigation and possible action under CERCLA. Most federal facilities listed on the NPL have been listed in their entirety, rather than by individual sites within a facility, so that interrelationships and interactions among multiple releases and the contamination of various environmental media can be addressed comprehensively. Remedial Investigation (RI) The purpose of the RI is to collect the data necessary to assess risks to human health and the environment and to support the development, evaluation, and selection of remedial alternatives. During the RI, soil and water samples are collected and analyzed, and risks to human health and the environment are determined via risk assessments. RIs determine what wastes are present, where the wastes are, if the wastes are moving to other media (groundwater, etc.) and if there is a risk to human health and the environment. Sites that pose an imminent threat to human health are cleaned up immediately with removal actions. Feasibility Study (FS) The objective of an FS is to develop and evaluate alternatives for remedial action. The FS will employ data presented in the RI report and data collected in previous investigations. The FS shall develop remedial response objectives and general response actions, identify applicable technologies, combine alternatives into remedial alternatives, screen and evaluate remedial technologies/alternatives, and analyze alternatives in detail. Ultimately, the FS determines the best technology for cleaning up a site. Proposed Remedial Action Plan (PRAP) After the FS is completed, a PRAP is prepared. The PRAP identifies and explains the rationale for the preferred remedial alternative and addresses the threats to human health and the environment at the site or operable unit. It describes all remedial alternatives that were evaluated, explains the nine criteria used to conduct the evaluation and comparison of the alternatives, and solicits public review and comment on all alternatives presented. It is written expressly for public review. Record of Decision (ROD) Once the final remedy is selected (after public review of the PRAP), a record of decision (ROD) is prepared. The ROD, which explains the remedy selection process and identifies the selected remedy, is based on information and technical analysis presented in the Remedial Investigation Report and Feasibility Study. The ROD documents the final response action decision at a site and certifies that the final remedy was selected in accordance with the requirements of CERCLA and the National Contingency Plan (NCP). Remedial Design/Action (RD/RA) The Remedial Design is a series of engineering reports, documents, specifications, and drawings that detail the steps to be taken during the Remedial Action to meet the goals established in the ROD and remove the site from the NPL. The Remedial Action is the process by which the remedy, as selected in the ROD and defined by the Remedial Design, is implemented. Interim Remedial Action (IRA) During the CERCLA process constructing a short term or simple remedy may be completed at a site at any time. Engineering Evaluation/Cost Analysis (EE/CA) An EE/CA must be completed for all non-time critical removal actions (IRAs) as required by NCP. The goals of the EE/CA are to identify the objectives of the removal action and to analyze the various alternatives that may be used to satisfy these objectives for effectiveness, implementability, and cost. While an EE/CA is similar to the FS conducted for remedial actions, it is less comprehensive compared to the FS. Action Memorandum After an EE/CA is completed, an Action Memorandum is prepared. An Action Memorandum provides a concise, written record of the decision to select an appropriate removal action. As the primary decision document, it substantiates the need for a removal action, identifies the proposed action, and explains the rationale for the removal action selection. In this respect, the Action Memorandum for removal actions parallels the function of the ROD; however, the Action Memorandum is not as elaborate as the ROD. Operation and Maintenance (O&M) Monitoring Ongoing monitoring requirements for the post-remediation phase are determined based on the effectiveness of the remedial action. Sampling and analysis may be required to confirm that the site contaminants are no longer present above acceptable action levels and to initiate site closure activities. O&M requirements are established in a Long-Term Monitoring Plan (LTMP). Five-year reviews are required if hazardous substances remain on site above risk-based levels based on unlimited use and restricted exposure or regulatory standards. Military Munitions Response Program (MMRP) The Department of Defense (DoD) has established the MMRP under the Defense Environmental Restoration Program to address munitions and explosives of concern (MEC) (including unexplooded ordnance and discarded military munitions) and munitions constituents (MC) at other than operational military ranges and other sites. Closed, transferred, and transferring military ranges and sites not located on an operations range are considered other than operational. Land Use Controls (LUCs) Land Use Controls (LUCs) consist of both Engineering Controls (ECs), such as fencing and signage, and Institutional Controls (ICs), such as deed restrictions, that are implemented to preclude unacceptable future human health and/or ecological risks from exposure(s) to chemicals of concern (COCs) at a given site. The Land Use Controls will be maintained until the concentration of hazardous substances in the soil and groundwater are at such levels to allow for unrestricted use and unlimited exposure. Typical performance objectives are to prohibit unauthorized excavation, construction or intrusive activities, to prohibit residential development of the site, and to prohibit the extraction or any use of the groundwater beneath the site. Five Year Review If a remedial action is selected that results in hazardous substances, pollutants, or contaminants remaining at the site above levels that allow for unlimited use and unrestricted exposure, the lead agency will review such action no less often than every five years after the initiation of the selected remedial action (i.e., CERCLA Five Year Review) to ensure that the remedy is, or will be, protective of human health and the environment. Five Year Reviews are prepared consistent with EPA's Comprehensive Five Year Review Guidance and the Chief of Naval Operation’s Policy for Conducting Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Statutory Five-Year Reviews. Deletion from the NPL A site may be deleted from the NPL when the final ROD requirements are attained (i.e., the remedial objectives have been met) and the site is operational and functional. No site may be deleted from the NPL without an approved Close Out Report (COR). The COR provides a brief technical demonstration of how the implemented remedy at the site satisfies the completion requirement.
|