Overview of the
Installation Restoration Program
The Installation Restoration Program (IRP) is a
Department of the Navy (DoN) initiative to identify, investigate and clean up former waste disposal sites. In general, chemical waste at MCAS Cherry Point originated from various activities, including: industrial operations (e.g. electroplating, stripping, etching, cleaning, etc.) conducted by NADEP (formerly NARF); aircraft and ground support equipment (GSE) painting operations conducted by NADEP and 2nd MAW; and MCAS Cherry Point power generation, to name a few. At the time, the DoD
followed industry-wide standard methods to dispose of these wastes
(e.g. solvents, waste oil, batteries, coal ash, wastewater sludge,
etc.). For example, solid wastes were typically deposited in
low-lying areas and covered with soil. Over time, however, new
regulations and approaches were developed for waste disposal.
Resource Conservation and Recovery Act of 1978 (RCRA) was enacted in 1976 to deal with wastes at sites that are still operational, while
Comprehensive Environmental response, Compensation and Liability Act
(CERCLA) was enacted in 1980 to investigate and clean up abandoned hazardous waste sites.
To address waste sites on military property, the Department of
Defense (DoD) established the IR program in 1975. Depending upon the
circumstances, military IR sites are identified, investigated, and
cleaned up in accordance with RCRA or CERCLA or in accordance with
an integrated approach based on both laws. As environmental awareness and knowledge progressed alongside the enactment of environmental legislature, the DoD altered their disposal practices to protect the environment and to conform to the environmental regulations.
Three primary governmental entities are involved in the cleanup of
past contamination at Department of the Navy (DoN) installations:
the United States Environmental protection Agency (USEPA), the DoN,
and the State of North Carolina Department of Environmental and
Natural Resources (NCDENR).
The Navy’s IRP was initiated in 1986, following the enactment of the SARA legislation, and replaced the
Navy Assessment and Control of
Installation Pollutants (NACIP) program. The purpose of the DoN IRP is to reduce the risk to human health and the environment from past waste disposal operations and hazardous material spills at DoN activities in a cost-effective manner consistent with Defense Environmental Restoration Program (DERP) requirements.
The mission of the USEPA is to protect human health and safeguard the environment. The USEPA is the federal agency responsible for providing guidance on hazardous waste site operation issues and USEPA Superfund site cleanup activities. USEPA Region 4, based in Atlanta, Georgia , is responsible for oversight of MCAS Cherry Point IRP.
NCDENR is the lead stewardship agency for the preservation and protection of North Carolina ’s environment and natural resources. Based in Raleigh, North Carolina , NCDENR Division of Waste Management, Superfund Section evaluates uncontrolled hazardous waste sites within the state and partners with DoD and USEPA to address cleanup goals, maximize stakeholder involvement, and improve the decision-making process to accomplish environmental restoration at DoD installations.
Within DoN, the Naval Facilities Engineering Command (NAVFAC) is responsible for the IRP and coordinates all IRP actions. The Engineering Field Divisions (EFDs) and Engineering Field Activities (EFAs) are subordinate commands under NAVFAC and provide environmental engineering, technical, legal, and contracting assistance to installations within their respective geographic areas of responsibility. NAVFAC Mid-Atlantic Division (NAVFAC Midlant), based in Norfolk, Virginia, executes the IRP for MCAS Cherry Point at the field level through the Remedial Project Manager (RPM) who is responsible for the management of the IRP at the installation level. The RPM’s responsibilities include identifying resources needed to effectively implement the remedial action process including CERCLA response actions and ER,N eligible RCRA Corrective Actions. The RPM coordinates the work of Navy technical support agencies and contractors to accomplish IRP goals and policies. The RPM is involved in all aspects of the project including interagency relationships, funding, scheduling, design, and remedial action.
As the IRP may affect the mission of an installation, the health and welfare of the people who work and live on or near the installation, and the public’s attitude in neighboring communities toward an installation, the Commanding Officer/Commanding General (CO/CG) of an installation must be consulted and kept fully informed about IRP decisions and actions affecting their installation. MCAS Cherry Point coordinates with the NAVFAC Midlant RPM concerning all IRP cleanup matters through the EAD at MCAS Cherry Point.
Click here to view
History of IRP
The CERCLA Process
The IRP begins site studies with a Preliminary
Assessment/Site Investigation (PA/SI) to distinguish between sites that
pose little or no threat to human health or the environment and sites that may
pose a threat and require further investigation. This stage involves a review of
historical documents and a visual site inspection. If the PA results in a
recommendation for further investigation,
 a
Site Investigation (SI) is performed. During the SI media samples (such as water and soil) are collected to confirm or deny the presence of potentially hazardous substances.
Based on the results of the PA/SI, a Remedial
Investigation (RI) may be needed at a site. An RI is designed to learn more about the site contamination and determine if any known contamination is leaving (i.e., migrating from) the site. During this phase, samples are usually collected from the soil, groundwater, surface water (such as creeks or lakes), soils and sediments. The resulting data provides information about the extent of possible contamination and rate of migration, if applicable.
A Feasibility Study (FS) may be conducted concurrently with the RI. The data collected in the RI influence the development of remedial (i.e. cleanup) alternatives able to meet the environmental standards, considering factors such as the degree of contamination and potential human health and environmental risks. A variety of remedial methods are considered, including the “No Action” alternative. Next, a Proposed Remedial Action Plan (PRAP) is presented, outlining several feasible or likely alternatives and recommending the preferred remedial method.
The public has an opportunity to comment on the PRAP during an announced
formal public comment period. Site information is compiled and placed in the
general IRP Information Repositories established at local libraries for public
review. The public comments are reviewed and the responses are recorded in a
document called a Responsiveness Summary. At the end of the public comment
period an appropriate remedial alternative is chosen to protect human health and
the environment. The
Record of Decision (ROD) document is issued that explains the selected remedial action and includes the Responsiveness Summary.
The final stage in the process is the Remedial
Decision/Remedial Action (RD/RA). The RD phase is where the technical specifications for cleanup remedies and technologies are designed. The RA is the actual construction or implementation phase of the cleanup process.
|