THE NAVY'S INSTALLATION RESTORATION (IR) PROGRAM

In 1986, Congress passed the Superfund Amendments and Reauthorization Act which brought all federal facilities under the umbrella of Superfund. It created the Envronmental Restoration Program along with funding via Defense Envronmental Restoration Account (DERA) to address past hazardous waste contamination cleanup. The passage of this law required the Navy to follow EPA rules and regulations and to have a program equivalent to the EPA's Superfund Program.

In 1997, in an effort to promote flexibility and to improve performance, Congress divided the DERA among the individual services. The new Navy account is designated Envronmental Restoration, Navy (IR, N). Funds appropriated by Congress and placed in this account pay for the Department of the Navy's Envronmental Restoration Program.

THE SUPERFUND PROCESS

Congress created the Superfund program in 1980 primarily to provide for direct federal response for the cleanup of hazardous waste sites that threaten human health or the environment. The National Contingency Plan is the basic regulatory framework for Superfund and provides an organizational structure and procedures for preparing and responding to discharges and releases of hazardous substances, pollutants and contaminants. Superfund is unique in that it addresses contamination (or threatened contamination) to all media: surface water, soil, air and groundwater.

The Superfund Process is comprised of numerous steps that ultimately lead to the cleanup of contaminated sites. "The Superfund Process" figure depicts the different stages each individual site goes through on its way to eventual cleanup. The ROD indicates when a remedy selection has been made. If at any time the site is determined to pose an immediate threat to human health and the environment, the typical Superfund process is shelved in favor of immediate action.

Site Discovery

Site Discovery identifies areas where hazardous substance contamination or potential for contamination may exist. Many site discoveries result from information and reports from States, communities, local authorities, businesses and citizens.

Site Evaluation

Site Evaluation involves the completion of a Preliminary Assessment/Site Inspection. During this stage a review of any available documents about the site is done. A site visit and sample collection are performed to define and further characterize the comtamination.

NPL Listing

The National Priorities List (NPL) is a listing of all Superfund sites in the United States. The results of the Site Evaluation are used to rank the site using a numerically based scoring system known as the Hazard Ranking System (HRS). The score is based on: 1) the likelihood that a site has released (or has the potential to release) contaminants to the environment, 2) the characteristics of the substance (e.g., toxicity and quantity), and 3) the people or sensitive environments affected by the release. A site may be listed on the National Priorities List in one of three ways: 1) Scoring 28.5 on the Hazard Ranking System, 2) Nomination by the State, or 3) Nomination by the Agency for Toxic Substances and Disease Registry. While the Naval Station (NAVSTA) has many sites that are currently under the Site Evaluation stage, the entire base was originally listed on the NPL because of the contamination at the McAllister point Landfill and Tank Farm 1. After evaluating the contamination in surface water, groundwater and air, the NAVSTA scored 32.25 on the HRS. NAVSTA was formally listed on the NPL on November 21, 1989.

Remedial Investigation

The Remedial Investigation determines the nature and extent of the contamination of the site.

Feasibility Study

A Feasibility Study (FS) is completed which focuses on development of specific remedies to address contamination problems based on general response actions identified in the Remedial Investigation (RI). The FS evaluates a range of alternatives, including the No Action alternative.

Proposed Plan

After a comparison of alternatives in the FS, a remedy is proposed and presented to the public for comment in a Proposed Plan. Typically, there is a 30 day comment period on the Proposed Plan.

Remedy Selection

Remedy Selection phase allows for a Record of Decision (ROD) and Responsiveness Summary (RS) to be completed. A ROD is a decision document indicating that the remedy has been selected. A ROD is developed after the comments on the Proposed Plan are received and evaluated. A Responsiveness Summary (RS) is included in the ROD that responds to comments received on the Proposed Plan.
If EPA and the Department of Defense disagree on the proposed remedy, the ultimate decision on the remedy selection resides with the EPA. The Department of Defense shall make the Administrative Record available to the public for review. The Administrative Record includes all documents and information contributing to the final remedy selection.

Remedial Design

Remedial Design is the preparation of the plans and specifications to perform and complete the remedial action.

Remedial Action

The Remedial Action is the implementation or construction of the remedy itself. Significant on-site activity related to the remedy must begin within 15 months from the date the ROD was signed.

Operation and Maintenance

Once the remedial actions are completed, site operation and maintenance activities are conducted, as needed, to maintain the effectiveness of the remedy and to ensure that no new threat to human health or the environment arises.

NPL Deletion

Once the remedy implemented is operational and functional and meets its designated environmental, technical, legal and institutional requirements, it will be considered a site completion. Site completion at federal facilities can occur for individual operable units, but does not occur for the base until all of the operable units are completed. When planning for a site closeout, EPA must ensure that all waste is properly disposed, that all equipment is decontaminated and demobilized and that response related damages are remedied. In other words, the site is restored.

Removal Actions

Removal Actions can be taken at any time within the process to remove or stabilize an imminent threat to human health or the environment. Removal actions are generally intended to reduce or eliminate imminent threats from contamination and are short-term actions. Environmental problems such as area wide contamination of groundwater are not normally addressed, unless an imminent threat exists. Removal Actions may reduce the cost of longer term cleanup by controlling migration of the hazardous substance or by eliminating the source of the additional contamination.