The Air Force Installation Restoration Program (IRP)

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The Air Force Installation Restoration Program (IRP) is designed to identify, investigate, and cleanup contamination associated with past Air Force activities at active AF installations; government-owned, contractor-operated facilities; off-site locations where contamination may have migrated; third party sites; and sites that the AF formerly owned or used. Funding support is provided by the Defense Environmental Restoration Account established under DERP. AFI 32-7001, Environmental Budgeting, 9 May 1994, provides additional information on budgeting and programming related to IRP projects. Air Force Major Commands (MAJCOMs) provide execution guidance and oversee implementation of the cleanup program and related activities at facilities under their jurisdiction.
IRP activities are conducted in accordance with the requirements of either the Federal Superfund Cleanup Process or the Resource Conservation and Recovery Act (RCRA) corrective action process, as appropriate. AFI 32-7020 emphasizes that on-site or in-situ corrective actions are preferred over cleanup options that require off-site disposal of contaminants. The primary sources of guidance for restoration projects at the installation level are:
·1996/97 Air Force Environmental Restoration Program Management Guidance, July 1995, published by Headquarters United States Air Force, (HQ USAF/CEVR). This document has been under continuous revision and has appeared in several "interim" versions since July 1995. Copies of the original document may be obtained from PRO-ACT.
·Air Force Remedial Project Manager's Handbook (The "Green Book"), published by HQ USAF/ILE. This document is under revision and scheduled for Air Force distribution in 2000. Point of Contact: Mr. Shane Hirschi, DSN: 607-0228
·Management Guidance for the Defense Environmental Restoration Program, March 1998, Office of the Deputy Under Secretary of Defense (Environmental Security) (DUSD/ES). The DUSD/ES document can be obtained from PRO-ACT or from the Defense Environmental Network Information Exchange (DENIX) World Wide Web (WWW) site at Http://www.denix.osd.mil/denix/Public/ES-Programs/Cleanup/DERP/guide.html.
The IRP cleanup process closely follows the requirements of the National Contingency Plan (NCP) as promulgated under the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA), 42 USC 9601 et seq. Originally published pursuant to Section 311 of the Federal Water Pollution Control Act (Clean Water Act), the NCP was revised and republished pursuant to section 105 of CERCLA at Title 40 Code of Federal Regulations (CFR) Part 300, "National Oil and Hazardous Substances Pollution Contingency Plan." The purpose of the NCP is to provide the organizational structure and procedures for preparing for and responding to discharges of oil and releases of hazardous substances, pollutants, and contaminants. The NCP is applicable to response actions taken pursuant to the authorities under CERCLA and Section 311 of the Clean Water Act, as amended.
Like the CERCLA cleanup program, the IRP seeks to minimize public health and environmental hazards associated with contaminated sites. As stated in Section 120 of CERCLA, federal facilities, including Air Force installations, are subject to applicable federal and state cleanup laws in the same manner and to the same extent as any non-federal entity. The IRP prescribes investigation and restoration activities conducted through a phased approach. Each phase systematically studies the effects of past environmental activities. At any point in the process, the governing agencies may determine that no further action is required and screen the site out of the process. Alternatively, a site posing an immediate threat to human health or the environment may require the federal government to undertake emergency response actions.

The primary phases of the CERCLA remedial action process, which generally apply to installation restoration projects, are:

Site Discovery - occurs through various means, including reports of releases to the Environmental Protection Agency (EPA), investigations by government authorities, property assessments/surveys, or incidental discoveries.

Site Assessment - this phase consists of several steps: 1) a preliminary assessment is a "desktop" review of available information; 2) the site inspection is a more detailed investigation, usually involving sampling and analysis of environmental media; 3) scoring the site involves applying the EPA hazard ranking model to assess the site's relative risk. The site may require listing on the EPA National Priority List (NPL), depending on the score; and 4) removal actions may be conducted at any time during the remedial action process to mitigate immediate environmental threats.

Remedial Investigation/Feasibility Study (RI/FS) - this phase fully characterizes the nature and extent of contamination at the site in sufficient detail to make informed risk management decisions, select the appropriate remedial option, develop a proposed remedial plan, and execute the Record of Decision (ROD).

Remedial Design/Remedial Action (RD/RA) - the site remedy is designed, pilot tested, constructed, and implemented during this phase. Long term operation, maintenance, and monitoring of the remedial action are included in this phase.

Some Air Force sites of contamination are subject to the RCRA corrective action process rather than CERCLA. The types of sites requiring RCRA corrective actions are primarily hazardous waste treatment, storage, or disposal (TSD) facilities permitted under RCRA. Part of the RCRA permit conditions require corrective actions when a release of a hazardous waste occurs from a RCRA permitted TSD facility or when the TSD facility is being closed. The regulations specifying that corrective actions must be taken at these types of sites are found at Title 40 CFR Subpart S - Corrective Action for Solid Waste Management Units. The actual cleanup process at these types of sites, however, will be in accordance with the CERCLA cleanup process discussed above.

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