Site Completion Terminology

[Lenny Siegel <lsiegel@cpeo.org>]

SITE COMPLETION TERMINOLOGY

Apparently led by the Air Force, the Defense Environment Security office
has clarified "terminology for work after remedial design" in its March,
1998 Management Guidance for the Defense Environmental Restoration
Program. I consider this apparently new terminology a major step
forward, but it has apparently not yet filtered down to the project
manager level. Hopefully, discussions with regulatory agencies will lead
to similar, consensus terminology that will be used by all of the
agencies. - Lenny

"'Remedial Action-Construction' (RA-C) is the period during which the
final remedy is being put in place. The end date signifies that the
construction is complete, all testing has been accomplished and that the
remedy will function properly. The phase 'Remedial Action-Operations'
(RA-O) is the period during which the remedy is in place (RIP [not to be
confused with Rest in Peace - LS]) and operating to achieve the cleanup
objective identified in the Record of Decision (ROD) or equivalent
agreement. Any system operation or monitoring requirements during this
time should be termed RA-O. 'Response Complete' (RC) signifies that the
remedy is in place and required RA-O have been completed. If there is no
RA-O phase, then the RA-C end date will also be the RC date.

"Once a site is RC, environmental monitoring is termed 'Long Term
Monitoring' (LTM). This term should be used until 'Site Closeout.' 'Long
Term Monitoring' is reserved for monitoring once a site is RC, and
should not be used to refer to monitoring after 'Remedy in Place,' (this
includes sites for which [the] selected remedy is natural attenuation)."

Lenny Siegel
Director, Center for Public Environmental Oversight (AKA SFSU
CAREER/PRO)
c/o PSC, 222B View St., Mountain View, CA 94041
Voice: 650/961-8918 or 650/969-1545
Fax: 650/968-1126
lsiegel@cpeo.org