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The goals apply to all sites at active installations, but only to Installation Restoration Program (IRP) sites - that is, not to Military Munitions Response Program (MMRP) sites - at Formerly Used Defense Sites (FUDS). There is no mention of Base Realignment and Closure sites. Before this memo, DERP goals were based upon EITHER the achievement of "remedy in place" or "response complete" (RC). The Defense components are approaching those existing goals, sometimes by installing extractive systems that are expected to operate for many years. A majority of existing response complete sites, however, were relatively minor sites that leap-frogged directly to response complete without the selection and implementation of a remedy. Remember, under the DERP accounting system, there are generally many "sites" on a single active installation. The two new goals are: "90% of IRP and MMRP sites at active installations, and IRP sites at FUDS properties will achieve RC by the end of Fiscal Year (FY) 2018." "95% of IRP and MMRP sites at active installations, and IRP sites at FUDS properties will achieve RC by the end of FY2021." The memo includes a definition of response complete: "The RC milestone signifies that the Department of Defense (DoD) has met the remedial action objectives for a site, documented the determination, and sought regulatory agreement. RC signifies that DoD has 1) determined at the end of the Preliminary Assessment/Site Inspection, or Remedial Investigation that no additional response action is required, 2) achieved Remedy-in-Place (RIP) and the required Remedial Action Operations (RA-O) has achieved the remedial action objectives, or 3) where there is no RA-O phase, then the Remedial Action Construction (RA-C) has achieved the remedial action objectives. Long-term management may occur after RC is achieved." It continues: "DoD achieves RC when no contaminants pose a threat to human health and the environment for the current land use. DoD may establish land use restrictions and conduct long-term periodic reviews, monitoring, and maintenance at a site once it has achieved RC. These activities may last either for a specified period or indefinitely to ensure protection of human health and the environment."
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Lenny Siegel Executive Director, Center for Public Environmental Oversight a project of the Pacific Studies Center 278-A Hope St., Mountain View, CA 94041 Voice: 650/961-8918 or 650/969-1545 Fax: 650/961-8918
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