Regulatory Drivers
In 1975, the Department of Defense (DoD) began a pilot program to investigate
past hazardous waste disposal at DoD facilities.
Click on the regulatory and administrative
programs below to learn more about what drives environmental cleanup at ABL :
In 1980, the pilot program was
re-issued by Congress as the Comprehensive Environmental Response
Compensation and Liability Act (CERCLA). Under CERCLA,
additional responsibilities and authorities were delegated to the
Department of Defense. CERCLA set up the original "Superfund" for
cleanups of hazardous waste sites. Sites eligible for cleanup
using Superfund are listed by EPA on the National Priorities List (NPL)
(federal facilities are not eligible for Superfund cleanup funds).
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Step
1 |
Discovery |
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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 whether the
facilities pose a risk to public health and the environment
under CERCLA and to provide a mechanism to make this
information available to the public. For each listed
facility, the responsible facility must complete a
Preliminary Assessment (PA), and, if warranted, a Site
Inspection (SI) to determine whether CERCLA response actions
are necessary. |
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Step 2 |
Preliminary Assessment / Site Inspection (PA/SI) |
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During the
PA/SI, an installation is surveyed to determine which
activities may have generated hazardous wastes, what those
wastes were, and what was done with them. This
includes reviews of old records, interviews with current and
former employees, and an inspection of the installation.
During the PA/SI, specific sites are
identified, preliminary soil and water samples are taken,
and a determination is made on whether further investigation
is warranted. The EPA may, after reviewing the data
collected from a federal facility, list the facility on a
National Priorities List (NPL). The Defense
Environmental Restoration Account funds the cleanup for
federal facilities on the NPL. |
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Step
3 |
NPL
Listing |
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The
Hazardous Ranking System (HRS) is a scoring system used by
EPA 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 by the inital limited investigations
(PA and SI) conducted at a site. EPA uses the HRS to
assign each site a score ranging from 0 to 100 based on the
likelihood that contaminants have been or will be released
from the site. Sites scoring at least a 28.5 are
eligible for placement on the NPL, which designates those
sites representing the highest priority for further
investigation and possible investigation under CERCLA.
Sites that receive an HRS score below 28.5 are not proposed
for the NPL, and no further action is required under CERCLA.
EPA gives the site a "No Further Response Action Planned"
(NFRAP) designation on the docket. However, North
Carolina and/or other authorities might require further
action (RCRA corrective action). |
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Step
4 |
Remedial Investigation (RI) |
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During the
Remedial Investigation, soil and water samples are taken and
a health and ecological risk assessment is performed.
The studies determine which wastes are present, where they
are, whether they are moving into the groundwater, and
whether there is a risk to public health and the
environment. Sites that pose an imminent threat to
public health are cleaned up immediately with removal
actions. |
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Step 5 |
Feasibility Study (FS) |
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The Feasibility Study determines
the best technology for cleaning up a site. |
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Step 6 |
Proposed Plan |
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The
Proposed Remedial Action Plan (PRAP) identifies and explains
the rationale for the preferred remedial alternative and
addresses the threats to human health and the environment at
the site 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. |
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Step 7 |
Remedy
Selection |
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The
purpose of the Record of Decision (ROD) is to document the
selected remedy. The ROD provides a plan for site design and
remediation, and documents the extent of human health or
environmental risks posed by the site. It also serves
as legal certification that the remedy was selected in
accordance with the requirements of CERCLA and the National
Contingency Plan (NCP). |
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Step 8 |
Remedy
Design / Action (RD/RA) |
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The
Remedial Design / Action includes development of the
specific design for the selected remedy to approved
environmental standards and implementation of the remedy
through construction. |
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Step 9 |
Operation and Maintenance Monitoring |
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Ongoing
monitoring requirements for the post-remediation phase are
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 begin site closure activities. |
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Step
10 |
Deletion from the NPL |
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A site may
be deleted from the NPL when the final ROD requirements are
attained (the remedial objectives) 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. |
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