The DERP Process:
The Department follows the cleanup process defined by CERCLA’s National Oil to and Hazardous Substances Pollution Contingency Plan (NCP) to clean up our sites. The DERP Management Guidance provides Military Components with guidance on cleanup in accordance with the NCP.
To most effectively address the different kinds of contaminants on DoD installations and former properties, the Department organized DERP into three program categories:
- Installation Restoration Program (IRP): The IRP addresses releases of hazardous substances, pollutants, or contaminants that may pose a risk to human health and the environment.
- Military Munitions Response Program (MMRP): The MMRP addresses environmental health and safety hazards from unexploded ordnance, discarded military munitions, and munitions constituents.
- Building Demolition/Debris Removal (BD/DR): The BD/DR program addresses demolition and removal of unsafe buildings and structures.
DERP Cleanup Process:
DoD conducts a preliminary assessment (PA) at a site, through document reviews, visual site inspections, and interviews, to determine whether or not a chemical release has occurred at the site, and if further investigation is warranted. If the PA suggests that contamination may be present at the site, the Department conducts a site inspection (SI) and collects and analyzes environmental samples to determine if additional study is required and if response actions may be needed at a site. DoD may determine, when comparing SI site data with preliminary remediation goals, that the site poses no risk and requires no further action.
If the SI indicates the site requires additional investigation, DoD will conduct a remedial investigation (RI). The RI involves collection of more comprehensive data at the site to
assess the nature and extent of contamination and the potential risks posed by the contamination. The results of the RI are used in developing remediation goals and alternatives for cleanup in the feasibility study (FS). The results of the RI/FS are documented in a record of decision (ROD) or equivalent decision document, including the selected cleanup strategy for the site. Sites determined to require no further action at any phase of the investigation process are considered to have reached Response Complete (RC).
The cleanup phase begins with the remedial design (RD) of the selected remedy. Remedial action construction (RA-C) is the implementation of the cleanup, and may include remedial action operation (RA-O) or operation of the remedy until the cleanup objectives required by the ROD for that site have been met. Some sites may require a review of the remedial action at least every five years after the remedial action is initiated. These reviews are performed to ensure that the remedy is functioning as designed and that any necessary operation and maintenance activities are taking place.
Prioritization and Cleanup Goals:
DoD uses the Relative-Risk Site Evaluation (RRSE) framework to prioritize cleanup under the IRP program. Each site is ranked as high, medium, and low risk, based on the nature and extent of a site’s contamination, the likelihood that contaminants will migrate through the environment, and potential impacts of contamination on populations and ecosystems. In addition to the RRSE framework, DoD uses the Munitions Response Site Prioritization Protocol (MRSPP) to prioritize cleanup of MMRP sites. Each site is assigned a score based on the explosive safety hazard and risk posed by the site.
DoD established goals to measure cleanup progress for each program category by risk reduction and completion of cleanup. Progress made towards program goals can be found in the Department of Defense Environmental Programs Annual Report to Congress.