Environmental Cleanup Program – The Cleanup Process at Fort McClellan
The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) is the pre-eminent cleanup law in the country. Passed in 1980 and amended in 1986, CERCLA, commonly known as Superfund, created a special trust funded from tax dollars to impose cleanup and reporting requirements on the private sector. CERCLA’s purpose is to identify, investigate and cleanup hazardous wastes sites that may pose a threat to human health or the environment. The Superfund Amendments and Reauthorization Act of 1986 (SARA) incorporates and details the specific steps involved in cleanup activities.
While CERCLA funds are not used for cleanup of Department of Defense (DoD) or other federal facilities, the law mandates that these facilities follow guidelines and requirements consistent with CERCLA. Accordingly, the DoD has developed and implemented the Defense Environmental Restoration Program (DERP) to meet the requirements of CERCLA. DERP provides for the identification, investigation, and cleanup of contamination associated with past activities at DoD facilities to ensure that potential threats to public health and the environment are eliminated.
Cleanup at Fort McClellan is being conducted under the Base Realignment and Closure (BRAC) Environmental Restoration Program. BRAC covers military facilities that have been or are being closed and addresses closure-related issues, such as property transfer and reuse, in addition to environmental cleanup.
What are we cleaning up?
Our cleanup program has two parts: (1) areas where munitions and explosives of concern (MEC) to include unexploded ordnance (UXO) may be present due to military training activities and (2) sites where contaminants may have been released during Fort McClellan’s normal operations. These operations may include motor pools where petroleum products were used and weapons-cleaning facilities or print shops where solvents were used, for instance. Both parts of the program are long term and will require several more years before all actions are complete. Once response actions at sites are completed, the Army will make the sites immediately available for reuse. This allows the community to gain quick access to those properties that are declared clean.
How long will the cleanup take?
Since the overriding purpose of a CERCLA-driven cleanup is protection of human health and the environment, the overall process can be lengthy. A number of time-consuming activities are required and driven by the desire to “get it right.” For instance, some of the steps required to complete a cleanup include:
Determining where to sample at a site.
Sampling field work
Laboratory analysis and validation of samples
Reports on findings
Interpretation by different agencies of the analyses and results.
Review and approval cycles for multiple documents and decisions.
Evaluating and choosing remedies that will minimize and/or prevent exposure to hazardous substances, pollutants, or contaminants.
In an effort to expedite the process and to achieve the earliest possible reuse for the property, the BRAC Cleanup Team (BCT) is following the DoD Fast-Track Cleanup approach to environmental restoration. Under the Fast-Track Cleanup, the BCT works with the local community and the McClellan Development Authority (MDA) to address cleanup priorities that accommodate local redevelopment needs. Property that is identified as a high priority for redevelopment is cleaned up first and transferred. Based on current programmed funding projections, it is the Army’s plan to complete all remedial actions within the next ten years.
Who’s involved in the cleanup?
As with all environmental cleanups, there are multiple federal, state, and local agencies and community groups involved. At Fort McClellan the BCT includes representatives from the U.S. Environmental Protection Agency, the Alabama Department of Environmental Management and the U.S. Army, with support from the U.S. Army Corps of Engineers and their contractors.
Additionally, the BCT works closely with the MDA, Fort McClellan’s local redevelopment authority, to determine cleanup priorities and to integrate those priorities with property reuse plans for economic redevelopment. The BCT also works with the Fort McClellan Restoration Advisory Board (RAB), whose role is to advise the Army of the community’s desires with respect to the Army’s cleanup program.
Finally, the public is invited to comment on draft documents and to attend public meetings regarding environmental activities. Announcements about comment periods and meetings are printed in local newspapers.
Are there other aspects of the Clean-up?
Yes, as part of a process known as early transfer, the Army has chosen to transfer property and privatize some of the clean-up whereby the MDA assumes the responsibility for the environmental services under an Environmental Services Cooperative Agreement (ESCA) with the Army. The MDA has entered into a Cleanup Agreement with the Alabama Department of Environmental Management that requires they meet state law while conducting these services under the ESCA. The Army, as a responsible agency, will meet its obligations under CERCLA and other applicable laws and regulations by providing the funds required via the ESCA and overseeing the completion of the environmental services necessary for Site Closeout in conjunction with the Cleanup Agreement and ESCA. As part of its responsibilities, the Army shall remain involved, and will provide appropriate program oversight of the cleanup efforts.
How can you get involved?
Communication with local communities, reuse authorities and the public is the cornerstone of any cleanup program. In addition to publishing notices and holding public meetings, the Army may issue periodic fact sheets and other informational materials concerning investigations and cleanup.
Additionally, the Fort McClellan RAB meets on the third Tuesday twice a year (April and October) at 5:00 PM in the Transition Force Conference Room, 681 Castle Avenue, Building 200, Annsiton, AL. The RAB advises the Army on the community’s concerns and priorities regarding cleanup. The public is always welcome at these meetings. Meetings are announced in local newspapers.
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) at a glance.
There are many required steps associated with an environmental cleanup process under CERCLA. Briefly, these steps are:
Preliminary Assessment - A historical record search to determine whether further investigation is warranted.
Site Investigation - Physical inspection of site with biased soil, sediment, surface water and groundwater sampling to determine whether further investigation is warranted.
Remedial Investigation - Investigation into the type and extent of potential contamination through in-depth sampling of air, soils, surface water, groundwater, plants, and animal life.
Feasibility Study - Evaluation of potential cleanup alternatives and selection of a proposed remedy.
Proposed Plan - Documentation of the feasible alternatives that are considered along with the proposed remedy. The public may comment on the proposed plan.
Record of Decision - Documentation of the selected remedy with the Army’s response to any public comments.
Remedial Design - Completion of the engineering design for the selected remedy.
Remedial Action - Commencement and operation of the selected remedy.
Remedy - Remedies could include fences, clay covers, on-site treatment, monitoring, among many other actions that could be taken at locations of releases.