Title: Introduction Text: The goal of the Department of Navy (DON) Environmental Restoration (ER) Program is to restore contaminated sites to conditions that protect human health and the environment and support the defense mission. This program, comprised of the Installation Restoration Program (IRP) and Munitions Response Program (MRP), has progressed significantly in implementing remedies at contaminated sites. A growing number of these sites are approaching the Site Closeout (SC) milestone and achieving this milestone in an efficient manner is important to the DON. The ER Optimization Workgroup has developed guidance to assist Navy Remedial Project Mangers (RPMs) in achieving efficient, protective, and cost-effective Site Closeout. The document is titled Guidance to Documenting Milestones Throughout the Site Closeout Process. In summarizing the Guidance, this Web Tool outlines the recommended approach to site closeout and identifies the documents that must be prepared at appropriate stages of the site closeout process to record agreements and concurrence of regulators.

Title: Site Closeout Text: Site Closeout (SC) is a milestone that signifies the DON has completed active management and monitoring at a remediation site, the remedy is protective of human health and the environment, no restrictions on future land use are needed for this site, and no additional funds are expected to be expended at the site.

Title: Purpose of SC Guidance Text: The purpose of DON SC guidance is to outline a consistent approach for DON RPMs to follow in recognizing and documenting specific milestones for achieving SC. Preparing consistent, identifiable, and defensible documents helps to ensure that decisions and milestones in the SC process are adhered to even when DON RPMs, regulators, and other stakeholders change with a project over time. Following the right process and developing proper documentation will also help to avoid re-opening ER sites after they have been closed.

Title: ER Process Milestones Text: The DON ER process, also referred to as the Site Closeout process, starts with identification and investigation of contaminated sites and continues through the selection, design, and implementation of remedial actions to achieve cleanup goals. This process is designed in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) requirements. Key phases and milestones are as follows: Preliminary Assessment/Site Inspection (PA/SI) Remedial Investigation/Feasibility Study (RI/FS) Removal Action (RA) Interim Remedial Action (IRA) Record of Decision (ROD) Remedial Design (RD) Remedial Action Construction (RA-C) Remedy in Place (RIP) Remedial Action Operation (RA-O) Response Complete (RC) Long-Term Management (LTMgt) Site Closeout (SC) The major phases and milestones are presented in the following pages of this tool, followed by a discussion of required SC documentation.

Title: Preliminary Assessment/Site Inspection (PA/SI) Text: The PA identifies contaminated sites based primarily on a review of existing information about hazardous substance use or disposal practices at an installation. During the SI, a limited amount of field data may be collected to determine the nature of any releases and potential threat to any receptors. Sites that do not pose an unacceptable risk to human health and the environment are designated as “no further action” (NFA) sites. The NFA designation can also be referred to as “no further remedial action planned” (NFRAP). If a site is identified as a potential risk to human health and/or the environment, the nature and extent of contamination should be further delineated, via the RI/FS.

Title: Remedial Investigation/Feasibility Study (RI/FS) Text: The RI phase includes a sampling and analysis program to determine the nature and extent of contamination and to perform human health and ecological risk assessments. The FS phase includes an initial screening and then detailed evaluation of remediation alternatives. The RI/FS may determine that NFA is required at the site. Following completion of a FS report, the preferred alternative is documented in a Proposed Plan for public comment. A removal action can take place during any phase of the cleanup process, but is more common during the PA/SI or RI/FS phases. If a removal action occurs from the RI phase, a ROD or other Decision Document (DD) must be prepared prior to SC.

Title: Removal Action (RA) Text: The RA process is used to address the release of a pollutant, which may present an imminent threat to human health and the environment. While completion of a removal action may meet the remedial action objectives for a site, the final site closeout documentation must be from the appropriate remedial action phase.

Title: Record of Decision (ROD) Text: All required remedial actions selected for a site or operable unit (OU) are documented in a ROD. An OU may address a single site at an installation, several sites at the same installation, or contaminated media (e.g., groundwater, soil, or sediments). The ROD includes a summary of site conditions, cleanup goals, and the rationale for selecting the remedy. For non-National Priorities List (NPL) sites, a Decision Document (DD) may be prepared instead of a ROD, but with similar scope. A summary of any interim remedial actions (IRAs) also should be included in the final ROD or DD.

Title: Interim Remedial Action (IRA) Text: An IRA is a remedial action undertaken as a component of a larger remedy prior to the selection of a final remedy. The IRA decisions are documented in an Interim Record of Decision (IROD) and are treated as a partial solution to a complex, multi-media contaminant problem or as a remedial action at one site included within a multi-site OU. Because of the interim status, implementing an IRA does not meet the RIP or RC milestones. However, if an interim action becomes the final action through a final ROD, then the remedy can achieve RIP or RC status.

Title: Remedial Design (RD) Text: This phase involves preparing the detailed design of the remedial action selected in the ROD.

Title: Remedial Action Construction (RA-C) Text: The designed remedial system is constructed on the site during this phase. Any construction required for the implementation of land use controls (LUCs) also may occur during this phase.

Title: Remedy In Place (RIP) Text: This milestone is achieved when the construction of a long-term remedy is complete and the remedy is operating as planned to meet project remedial action objectives in the future, or a short-term remedy has been successfully implemented and the final documentation is being prepared. Determination of achieving the RIP milestone is a Navy decision and regulatory concurrence for this milestone is not needed.

Title: Remedial Action Operation (RA-O) Text: This phase involves operation, maintenance, and monitoring actions for the remediation system and site. It may include conducting 5-year reviews prior to achieving RC. The RA-O phase also may include implementation, management, and maintenance of LUCs if these were part of the selected remedial action in the ROD. Periodic monitoring reports are routinely prepared during this phase to document performance of remediation systems. The RA-O phase continues until a remediation system achieves cleanup goals.

Title: Response Complete (RC) Text: This milestone signifies that the remedial action objectives have been met and the RA-O phase has achieved cleanup goals specified in the ROD or DD. Formal documentation for the RC milestone is essential to ensure recognition of completion of cleanup goals at the site. Details about documenting completion of the remedial action are provided in the "Documentation" section of this Web Tool. Prior to claiming completion of the RC milestone, regulatory concurrence with this documentation is required.

Title: Long Term Management (LTMgt) Text: Following the RC milestone, LTMgt may be required to monitor long-term protectiveness of the remedy when the cleanup goals do not allow unrestricted use of the site. Actions during this phase may involve groundwater monitoring, implementation and management of LUCs, and conducting 5-year reviews. Operation of an active or passive remedy is part of the RA-O phase and therefore is not included in the LTMgt phase. All such operations should be complete prior claiming the RC milestone and starting the LTMgt phase.

Title: Site Closeout (SC) Text: SC signifies that the DON has completed active management and monitoring at a site, the remedy is protective of human health and the environment, no restrictions on future land use are needed for this site, and no additional funds are expected to be expended at the site. SC is an important milestone. However, unlike RIP or RC, it is not a Department of Defense (DoD) metric for measuring progress of the ER Program.

Title: Comparing RCRA/CERCLA (1 of 2) Text: Several DON installations have remediation projects which require adherence to the Resource Conservation and Recovery Act (RCRA). The RCRA Corrective Action (CA) process is similar to the CERCLA process, but the terminologies for each phase/milestone of the cleanup process are different as shown here. The U.S. Environmental Protection Agency (U.S. EPA) has issued two references that provide further information on concurrent compliance with both RCRA and CERCLA (1996 and 2005). For many installations, the RCRA/CERCLA integration process has been outlined in a Federal Facility Agreement (FFA) or Federal Facility Site Remediation Agreement (FFSRA). Check these documents to determine how RCRA and CERCLA documentation requirements are to be addressed.

Title: RCRA Corrective Action Completion (2 of 2) Text: These are two types of RCRA Corrective Actions as follows: Corrective Action Complete without Controls Corrective Action Complete with Controls More information can be found in the Final Guidance on Completion of Corrective Action Activities at RCRA Facilities (U.S. EPA, 2003). Although, the terminology in this guidance is different from the DON terminology for SC, there are similarities in the basic approach.

Title: Corrective Action Complete without Controls Text: The U.S. EPA recommends this option to indicate: (a) No Corrective Action was needed or (b) Corrective Action was successfully implemented to achieve corrective action goals and no further action or controls are necessary to protect human health and the environment. Comparing this option to the DON ER process terminology, item (a) is similar to designating a site as NFA during the PA/SI or RI/FS phases, and item (b) is similar to achieving RC and SC milestones at a site where no LTMgt phase is required.

Title: Corrective Action Complete with Controls Text: This option will be used generally when the remedy has achieved site-specific cleanup objectives, but continued operation, maintenance, and/or monitoring is needed to protect human health and the environment. This includes maintenance of any needed LUCs. Comparing this option to the DON ER process terminology, it is similar to achieving the RC milestone and conducting further activities in the LTMgt phase to ensure protectiveness of the remedy.

Title: Site Closeout Documentation Text: The six core documents which are necessary to acknowledge the achievement of the SC milestones are shown here. An overview of the core documents required for the CERCLA and RCRA regulatory frameworks is provided in the following pages of this Web Tool and discussed in detail in the DON SC guidance.

Title: Core Documents for CERCLA Site Closeout Text: The core documents for CERCLA sites are listed below: Concurrence letters for sites designated NFA from PA/SI ROD text for sites designated NFA from RI/FS or PA/SI Interim Remedial Action Completion Report (I-RACR) Remedial Action Completion Report (RACR) Final RACR RACR Amendment for LTMgt completion

Title: NFA Concurrence Letters for PA/SI Sites Text: Sites are often designated NFA in the PA/SI phase. This designation is based on the conclusion that these sites do not pose an unacceptable risk to human health and the environment. The PA/SI reports discuss these sites and provide a rationale for the NFA conclusion. With this designation, these sites also meet the RC (following regulatory concurrence) and SC milestones. A common approach to formalize SC for NFA sites from the PA/SI phase is a letter of concurrence from the regulatory agency. The letters are not required under CERCLA, but are highly desirable to document NFA concurrence. Some form of written regulatory concurrence is required to achieve the DoD goal of RC. Click below to view examples of concurrence letters from the PA/SI phase. Example 1 PA/SI NFA Letter Example 2 PA/SI NFA Letter

Title: NFA ROD Text for RI/FS or PA/SI Text: The RI/FS phase also may identify NFA sites that do not pose an unacceptable risk to human health and environment. These sites are included in the ROD, which is a consensus document indicating agreement from all the stakeholders of the NFA status for these sites. Sites designated NFA from the PA/SI phase also may be included in a ROD for the relevant OU or in other RODs in the same installation, if acceptable to the stakeholders. For a NFA site, the ROD should contain information about the site, current and future land use, site characteristics, and site risks. With a NFA ROD, a site also achieves the RC and SC milestones. Click here to view sample NFA ROD text. Click here to view an NFA ROD Concurrence Letter. Additional information on NFA RODs can be found in the U.S. EPA Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents.

Title: Interim RACR, RACR, and Final RACR Text: The Remedial Action Completion Report (RACR) formally documents the achievement of cleanup objectives specified in the ROD, at the completion of the RA-O phase. The suggested contents for a RACR are shown here. The RPM is required to obtain concurrence from regulatory agencies for this report to achieve the RC milestone. The concurrence could be in the form of a letter and/or a signature page added to the report. The DON RPM is to prepare an interim RACR (I-RACR) for remedies requiring a prolonged RA-O phase for achieving remedial action objectives. The I-RACR is prepared following remedy construction and evaluation to confirm remedy operation as designed. Generally, remedial actions for groundwater such as monitored natural attenuation (MNA) will require long-term operation during the RA-O phase. The general contents for RACRs and modifications to I-RACRs are shown here. When all cleanup goals are complete at the last OU at an installation, the RACR for the last OU will be designated the Final RACR. In addition to the information specific to the last OU, the Final RACR should contain a brief summary of all previous RACRs and NFA RODs (if any) completed at the installation. The Final RACR will require concurrence from the regulatory agencies.

Title: RACR Amendment for LTMgt Completion Text: This report documents completion of LTMgt actions and achievement of the SC milestone. This report is essentially an amendment of the previously prepared RACR for the OU. There are three general ways that a site under LTMgt can achieve the SC milestone: A regulatory standard for a contaminant of concern (COC) is raised to a level above concentrations remaining on site. Contaminant concentrations are naturally attenuated below the unrestricted use concentration levels. Additional active remediation could be conducted to reduce concentrations below unrestricted levels. The basic contents of a RACR Amendment should be similar to a RACR. However, additional information should be included about actions taken following completion of the RACR. This report should have concurrence from the regulatory agencies.

Title: CERCLA NPL Deletion Process Text: For installations on the NPL, the Final RACR is the supporting document for the full deletion of the entire installation from the NPL. Following completion of the Final RACR by the DON, the U.S. EPA is responsible for conducting the deletion process, including any necessary documentation. The document Closeout Procedures for National Priorities List Sites (U.S. EPA, 2000) contains details about the actions U.S. EPA RPMs take to achieve NPL deletion. However, some of the documents mentioned in this U.S. EPA guidance are not required for DON projects and the terminology may be different. Because of these factors and to avoid duplication in reporting, the DoD/EPA Joint Guidance has greatly streamlined the documentation requirements for NPL delisting. The DON RPMs are to follow this DoD/EPA Joint Guidance to prepare the necessary SC documents for NPL sites. The documents prepared by the DON (I-RACR, RACR, and Final RACR) contain all of the necessary information for U.S. EPA to complete the deletion process.

Title: SC for RCRA Corrective Action Sites Text: The SC documentation needed for RCRA sites is summarized below. No Further Action from RFA and RFI Phases. The initial RCRA phases, RFA and RFI, help to identify NFA sites that do not pose unacceptable risks to human health and the environment. All NFA sites from RFA and RFI phases are listed in the RCRA permit for the facility as areas of concern (AOCs) or solid waste management units (SWMUs) that do not need further action. Inclusion in the permit formalizes the SC milestone for these sites. Corrective Action Complete without Controls. For AOCs/SWMUs without LTMgt, a corrective action completion report is prepared after the Corrective Measures Implementation (CMI) phase is over and cleanup goals have been met. This report will be similar to a RACR and will complete the SC milestone. The AOC/SWMU will be designated as “corrective action complete without controls” following a permit modification. Corrective Action Complete with Controls. For AOCs/SWMUs with LTMgt, a corrective action completion report should be prepared and the permit modified to specify long-term corrective measures activities that may include monitoring, LUCs, and reporting. At the completion of the post-closure period, a completion report similar to the RACR Amendment will need to be prepared.

Title: SC for Underground Storage Tank Sites Text: Corrective actions under the Underground Storage Tank (UST) program are State-lead, and the State may delegate the authority to a local agency. The documentation and community involvement requirements for UST sites are typically simpler than those defined under CERCLA or RCRA. A common practice for leaking UST sites is to prepare and implement a Corrective Action Plan (CAP) for site remediation. This is followed by periodic monitoring reports to evaluate effectiveness of the implemented remedy. Upon completion of cleanup goals established in the CAP, the final monitoring report is generally the supporting document for a NFA concurrence letter from the regulatory agencies. With this concurrence, the site achieves the RC and SC milestones.

Title: SC Scenarios Text: Click on the graphic to view examples of potential site closeout scenarios for environmental restoration sites.

Title: Summary Text: The following recommendations are made to develop defensible and consistent documents for Site Closeout as part of the DON ER Process: Develop concurrence letters in coordination with regulatory agencies for sites designated as NFA during the PA/SI phase. Include in the ROD sites designated as NFA during the PA/SI based on site-specific conditions. NFA sites from RI/FS are to be included in a ROD per CERCLA requirements. Prepare an I-RACR for remedies requiring a prolonged RA-O phase. Prepare a RACR when the remediation system achieves cleanup goals specified in the ROD or DD. Regulatory concurrence or buy-in on this report confirms achievement of the RC milestone. For sites not requiring LTMgt, this document also confirms achievement of the SC milestone. Prepare a Final RACR when the last OU at an installation achieves cleanup goals. In the Final RACR, provide summary/reference for all the previous RACRs and for any NFA ROD(s) or DDs for the installation. Provide Final RACR to the U.S. EPA for purposes of delisting the site from the NPL. U.S. EPA is to prepare all the delisting documents and conduct the process. Prepare a RACR Amendment for the completion of LTMgt for OUs requiring this phase. Regulatory concurrence for this report confirms completion of all monitoring, reporting, and LUCs for the OU, and achieves the SC milestone. However, for containment remedies such as landfill caps and sites with perpetual LUCs, the LTMgt phase may not be complete in the foreseeable future. For RCRA sites, prepare the corrective action completion report (similar to a RACR) with consultation from the lead regulatory agency, for documenting completion of cleanup objectives for the corrective action. For a site not requiring the LTMgt phase, this report will achieve the SC milestone and will be designated “complete without controls” per RCRA terminology. For a site requiring the LTMgt phase, the site will be designated “complete with controls”, per RCRA terminology. Upon completion of the LTMgt phase, prepare an amendment to the completion report. Obtain closeout letters from the regulatory agencies for underground storage tank corrective actions, relying mostly on the periodic monitoring reports as supporting documents for these closeout letters.

Title: References Text: NAVFAC. 2006. Guidance to Documenting Milestones Throughout the Site Closeout Process. March. NAVFAC. 2000. Guide to Optimal Groundwater Monitoring. January. NAVFAC. 2001. Guidance for Optimizing Remedial Action Operation. April. NAVFAC. 2004. Guidance for Optimizing Remedy Evaluation, Selection, and Design. April. U.S. Department of Defense. 2005. DoD/EPA Joint Guidance for Streamlined Site Closeout and NPL Deletion Process for DoD Facilities. December. U.S. DON. 2001. Navy/Marine Corps Policy for Conducting Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Statutory Five-Year Reviews. U.S. EPA. 1996. Coordination between RCRA Corrective Action, Closure, and CERCLA Site Activities. September. U.S. EPA. 1998. Guide to Preparing Superfund Proposed Plans, RODs, and other Remedy Selection Decision Documents. EPA 540-R-98-031 U.S. EPA. 2000. Closeout Procedures for National Priorities List Sites. EPA 540-R-98-016. U.S. EPA. 2001. Comprehensive Five-Year Review Guidance. EPA 540-R-01-007. U.S. EPA. 2003. Final Guidance on Completion of Corrective Actions at RCRA Facilities. Federal Register Vol. 68, No 37. U.S. EPA. 2005. Improving RCRA/CERCLA Coordination at Federal Facilities. December.

Title: Contact Information Text: For more information about site closeout issues, please contact: NFESC POC (805) 982-1656 PRTH_NFESCT2@navy.mil