[CPEO-MEF] Guidance on Long-Term Monitoring of OE Response

[Lenny Siegel <lsiegel@cpeo.org>]

[The Huntsville Division of the Army Corps of Engineers is seeking input
on its guidance, below, on "Long Term Monitoring (LTM) of Ordnance and
Explosives (OE) Response Projects." Please note that the title will
probably be changed to "Recurring Review." To obtain a fully formatted
file or to offer comments, write
<tammie.l.learned@hnd01.usace.army.mil>. - Lenny]



CEMP-RF  (200-1c)
November 1998


MEMORANDUM

SUBJECT:  Long Term Monitoring (LTM) of Ordnance and Explosives (OE)
Response Projects


1.  PURPOSE:  This guidance provides the procedures for developing and
implementing LTM requirements for OE response activities to ensure
public health, safety, and the environment are continuing to be
protected.

2.  APPLICABILITY:  This guidance applies to all Headquarters, U. S.
Army Corps of Engineers (HQUSACE) elements and all USACE Commands having
responsibility for performing ordnance and explosives response
activities. 

3.  REFERENCES: 

     a.  Comprehensive Environmental Response, Compensation and
Liability Act of 1980, (CERCLA), Public Law 96-510, 94 Stat. 2767, 42
USC 9601 and 9621.

     b.  Superfund Amendment and Reauthorization Act of 1986, (SARA),
Public Law 99-499, 100 Stat 1613, amending CERCLA, 42 USC 9601 et seq.,
and other sections.

     c.  Defense Environmental Restoration Program (DERP), 10 USC 2701.

     d.  U. S. Environmental Protection Agency, National Oil and
Hazardous Substance Pollution Contingency Plan, Title 40, Code of
Federal Regulations, Part 300.

     e.  Program Manual, Defense Environmental Restoration Program for
Formerly Used Defense Sites (DERP - FUDS), July 1996.

4.  RESPONSIBILITIES:

It is the responsibility of the USACE district which serves as the
Project Manager (PM) to program funding requirements for LTM, input and
track milestones in the Formerly Used Defense Sites Management
Information System (FUDSMIS), and to develop and implement LTM plans for
OE response activities.   Effective LTM efforts require the commitment
of federal, state, local, and individual resources.  Stakeholder
participation and regulatory considerations are essential in developing
the technical evaluation to support the proposals for LTM.

5.  REQUIREMENTS AND PROCEDURES:

     a.  References 3a and 3b require selected response actions that
result in any contaminants remaining at an OE site be reviewed no less
often than each 5 years.  This review is necessary to ensure that public
health, safety and the environment are being protected by the response
action that was implemented.   Reference 3e specifies that the Defense
Environmental Restoration Account (DERA) will fund LTM activities for
FUDS projects.

     b.  An initial LTM Plan will be included in the Engineering
Evaluation and Cost Analysis (EE/CA) report.  This Plan will be based on
the recommended response alternative(s) for the OE site as documented in
the EE/CA.   Subsequently, the LTM requirements, time frame during which
the monitoring will occur, and the proposed funding will be incorporated
into the Action Memorandum.   The LTM plan will be reviewed for
modification as appropriate during the removal design and post removal
action phases.

     c.  Enclosure 1 is provided to assist in developing and
implementing LTM Plans during the EE/CA phase or its equivalent.  In
addition, LTM Plans should be developed for any OE projects that have
already been executed with no LTM Plans in place.  LTM Plans will
incorporate the elements listed in the enclosure and any other
considerations that are unique to the site.  All LTM Plans will be
developed with the full involvement of the project team and in
coordination with the regulators and stakeholders.  As we gain
experience in conducting LTM, the steps outlined in the enclosure will
be updated and published to reflect the lessons learned.

     d.  The project team, in coordination with the stakeholders and
regulators, will determine the time frame within which a site will be
subjected to LTM.  In accordance with reference 3e, LTM may be necessary
for up to 30 years depending on site conditions; however, the project
team will use sound design criteria to make such determinations. 
Additionally, when LTM efforts indicate further response actions may be
warranted, such actions will be accomplished under the CERCLA process. 
The time frame for LTM efforts will be tracked in the FUDSMIS.

6.  EFFECTIVE DATE: The requirements and procedures set forth in this
guidance become effective upon receipt.  These procedures will remain in
effect indefinitely, unless superseded by other policy or regulation.

7.  POINTS OF CONTACT: If you have any questions, please contact Mr.
Dale Moeller, at telephone number 202-761-4694.


PATRICIA RIVERS
Chief, Environmental Restoration Division
Directorate of Military Programs  


DISTRIBUTION:
(List all USACE elements)



ELEMENTS OF LONG TERM MONITORING 


1.   Establish interdisciplinary project team, determine if required
real estate functions have been completed (e.g., rights of entry have
been obtained), identify Public Affairs Office support requirements
including review of the Community Relations Plan for updating as
appropriate, determine education requirements, if any, for the
stakeholders.

2.  Review Existing Documents (EE/CA or equivalent studies, Explosives
Safety Submissions for any continuing surveillance requirements,
decision documents, removal action reports, etc.).
     
      a.  Determine what actions are proposed or were completed at the
site.
      b.  Determine what the existing conditions are at the site.
      c.  Determine where unexploded ordnance (UXO) items are suspected
or were located and document the rational for this determination.  

3.  Obtain New Data  (Gather readily available data telephonically,
through news articles or releases, public records, local authorities,
etc.).
            
     a.  Record all contacts/interviews
     b.  Review of Changes in Site Conditions
          (1) Construction
          (2) Erosion
          (3) Recreational or other activities 
          (4) Littoral processes
          (5) Storm damage (uprooted trees, etc.)
          (6) Changes in land use
          
      c. UXO incidents
      d. Institutional Controls 
     
4.  Prepare Site Analysis and Work Plans

     a.  Preliminary site analysis  (Based upon existing and new data)

          (1) Prepare preliminary analysis of response effectiveness

          (2) Develop further data gathering requirements

     b.  Develop Field Work Plan (Based upon the preliminary site
analysis)

5.  Perform Field Work for LTM

     a.  Public Information Forums or Media Days
     b.  Interviews (face to face discussions with property owners,
local authorities, etc.)
     c.  Site Visit Evaluation

6.  Prepare Final Report 
 
 (Substantiate that the response action that was implemented is still
protective of human health and the environment or recommend that
additional response actions are warranted)  Include:

     a.  Data gathered or relied upon (from items 2, 3, and 5 above)
     b.  Final Site Analysis
     d.  Conclusions/Recommendations


NOTE:  The basic text of the Final Report should be limited to 5 to 10
pages with liberal use of appendices as required.

-- 


Lenny Siegel
Director, Center for Public Environmental Oversight
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
http://www.cpeo.org


You can find archived listserve messages on the CPEO website at 

http://www.cpeo.org/lists/index.html.

If this email has been forwarded to you and you'd like to subscribe, please send a message to: 

cpeo-military-subscribe@igc.topica.com

_____________________________________________________________
Who will win the Oscars? Spout off on our Entertainment list!
http://www.topica.com/lists/showbiztalk