The Department of the Navy (DON) Environmental Restoration (ER) process starts with identification and investigation of contaminated sites, followed by selection, design, and implementation of remedial actions to achieve remediation goals. This process is designed in accordance with CERCLA requirements.
There are two types of DON ER responses.
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Removal Actions are taken to address releases or threatened releases requiring prompt action.
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Remedial Actions are taken to permanently and significantly reduce the dangers associated with releases or threats of releases of hazardous substances that are serious, but not immediately life threatening. The Remedial Action process specifies the steps to thoroughly evaluate the nature and extent of contamination, and provides a structure to identify and evaluate cleanup alternatives.
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Remedial Action Process
The basic steps are as follows:
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Preliminary Assessment/Site Inspection (PA/SI) evaluates if past waste management practices resulted in release of hazardous substances.
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Remedial Investigation/Feasibility Study (RI/FS) are typically performed together. The RI is a sampling and analysis program to determine the nature and extent of contamination, and to determine what risk is posed by contaminates of concern at the site. The FS is a detailed evaluation of remediation alternatives.
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Proposed Plan (PP) presents the preferred cleanup alternative and explains why the alternative was chosen. This document has a public comment period.
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Record of Decision (ROD) documents the selected cleanup solution.
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Remedial Design (RD)/Remedial Action (RA) prepares a design for the cleanup alternative; and implements the cleanup alternative.
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Remedial Action Operations (RAO) is part of the RA. It is done when the cleanup alternative involves the operations of a cleanup system/technology to achieve a remedial goal.
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Long-Term Management (LTM) occurs at sites where hazardous substances remain after the RA has been completed. This may involve sampling/monitoring/maintenance of the remedial action.
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No Further Action (NFA) takes place when all necessary remedial action activities are complete and the DON and regulatory agencies agree that no further action (NFA) is appropriate at the site.
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Removal Action Process
In some cases, the DON and regulatory agencies may conduct a Removal Action of hazardous substances from a site. These removal actions are carried out in accordance with federal and state requirements.
The DON can conduct a removal action if any one or more of the following criteria are present:
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An imminent threat to human health or the environment exists.
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The source of the contamination can be removed quickly and effectively.
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Access to contamination can be limited.
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A removal action is the fastest way of remediating the site.
The basic steps are as follows: