DEPARTMENT OF THE ARMY 

ASSISTANT CHIEF OF STAFF FOR INSTAWTION MANAGEMENT 

UM ARMY PENTAGON 

2 2 NOV 2W14 

MEMORANDUM FOR SEE DISTRIBUTION 

SUBJECT: Army Defense Environmental Restoration Program (DERP) Guidance 

Documents for Active and BRAC Installations 

1. References: 

a. Army Defense Environmental Restoration Program Management Guidance for 

Active Installations. November 2004 (Encl 1). 

b. Army Defense Environmental Restoration Program Management Guidance for 

Base Realignment and Closure (BRAC) Installations, November 2004 (Encl 2). 

2. The references provide supplemental guidance to AR 200-1 and DA Pamphlet 200-1 

for management of the Army's environmental restoration programs at active and BRAC 

installations. These documents replace existing guidance last provided in 1999. They 

incorporate changes necessitated by the Transformation of Installation Management 

reorganization, as well as several management initiatives developed in the last few 

years. 

2 Encls 

kistant chief of Staff 

for Installation Management 
 

ASSISTANT CHIEF OF STAFF FOR INSTALLATION MANAGEMENT

 

 

Army Defense Environmental 

Restoration Program: 

 Management Guidance for 

Active Installations

NOVEMBER 2004

Enclosure 1

 

Contents 

Preface 

 Summary of Changes to the Army DERP........................................................i 

 

Chapter 1 .....................................................................................................................

PURPOSE AND APPLICABILITY .............................................................................................. 1-1 

Chapter 2 .....................................................................................................................

BACKGROUND........................................................................................................................ 2-1 

2.1 ARMY DEFENSE ENVIRONMENTAL RESTORATION PROGRAM (DERP)............................. 2-1 

2.2 INSTALLATION RESTORATION PROGRAM (IRP) CATEGORY ............................................. 2-2 

2.3 MILITARY MUNITIONS RESPONSE PROGRAM (MMRP) CATEGORY ................................. 2-3 

2.4 BUILDING DEMOLITION AND DEBRIS REMOVAL PROGRAM (BD/DR) CATEGORY ........... 2-4 

Chapter 3 .....................................................................................................................

ROLES AND RESPONSIBILITIES ............................................................................................. 3-1 

3.1 HEADQUARTERS, DEPARTMENT OF THE ARMY ................................................................ 3-1 

3.2 U.S. ARMY INSTALLATIONS ............................................................................................. 3-2 

3.3 REGULATORY AGENCIES.................................................................................................. 3-2 

3.4 OTHER STAKEHOLDERS.................................................................................................... 3-2 

Chapter 4 ......................................................................................................................

PROGRAM DEVELOPMENT AND MANAGEMENT................................................................... 4-1 

4.1 PROGRAM GOALS AND OBJECTIVES ................................................................................. 4-1 

4.2 PROGRAM IMPLEMENTATION ........................................................................................... 4-1 

4.2.1 INSTALLATION ACTION PLAN (IAP)........................................................................ 4-2 

4.2.2 ARMY ENVIRONMENTAL DATABASE-RESTORATION (AEDB-R)............................. 4-3 

4.2.3 RELATIVE RISK SITE EVALUATIONS (RRSE) .......................................................... 4-5 

4.2.4 RISK ASSESSMENT CODE (RAC)............................................................................. 4-6 
 iv 

4.2.5 COST-TO-COMPLETE (CTC).................................................................................... 4-7 

4.2.5.1 CTC ESTIMATES ............................................................................................ 4-8 

4.2.5.2 REMEDIAL ACTION COST ENGINEERING AND REQUIREMENTS (RACER) ...... 4-10 

4.2.5.3 CTC REVISIONS ........................................................................................... 4-10 

4.2.5.4 CTC AUDITS ................................................................................................ 4-11 

4.2.5.5 CTC TRAINING............................................................................................. 4-12 

4.3 BUDGETING.................................................................................................................... 4-12 

4.4 FUNDING ARMY DERP ACTIVITIES................................................................................ 4-13 

4.4.1 PRIORITY SETTING AND SEQUENCING .................................................................... 4-13 

4.4.2 FUNDING FOR NEW SITES....................................................................................... 4-15 

4.4.3 MILITARY CONSTRUCTION (MILCON) ................................................................. 4-15 

4.4.4 COST RECOVERY AND COST SHARING ................................................................... 4-16 

4.5 EXECUTION STRATEGY ................................................................................................... 4-18 

4.5.1 OBLIGATION GOALS.............................................................................................. 4-18 

4.5.2 DISBURSEMENT GOALS ......................................................................................... 4-18 

4.5.3 DEFENSE GOALS ................................................................................................... 4-18 

4.6 PERFORMANCE MEASURES............................................................................................. 4-18 

4.6.1 MEASURES OF MERIT (MOMS) ............................................................................. 4-19 

4.6.2 ARMY CLEANUP STRATEGIC PLAN GOALS............................................................ 4-19 

4.6.3 DERP ANNUAL REPORT TO CONGRESS................................................................. 4-20 

4.7 PROGRAM TIMELINES..................................................................................................... 4-20 

Chapter 5 .....................................................................................................................

PROGRAM EXECUTION.......................................................................................................... 5-1 

5.1 INSTALLATION.................................................................................................................. 5-1 

5.2 ARMY DERP EXECUTOR.................................................................................................. 5-3 

5.3 U.S. ARMY ENVIRONMENTAL CENTER (USAEC)............................................................ 5-4 

5.4 USAEC ENVIRONMENTAL RESTORATION MANAGER (ERM) .......................................... 5-5 

5.5 U.S. ARMY TECHNICAL CENTER FOR EXPLOSIVE SAFETY (USATCES) .......................... 5-6 

5.6 DEPARTMENT OF DEFENSE EXPLOSIVES SAFETY BOARD (DDESB)................................ 5-6 

5.7 U.S. ARMY CENTER FOR HEALTH POTION AND PREVENTIVE MEDICINE 

(USACHPPM) ........................................................................................................... 5-7 

5.6 BRAC DIVISION AND BRAC FIELD OFFICES ................................................................... 5-7 
Contents 

 v 

Chapter 6 .....................................................................................................................

PROGRAM PROCEDURES ....................................................................................................... 6-1 

6.1 DECISION DOCUMENT (DD)............................................................................................. 6-1 

6.1.1 CERCLA REMEDIAL RECORDS OF DECISION (ROD)/DDS ..................................... 6-1 

6.1.2 REMOVAL ACTION MEMORANDA/DD..................................................................... 6-3 

6.1.3 CORRECTIVE ACTION STATEMENTS OF BASIS (SB)/DD ......................................... 6-4 

6.1.4 DD STAFFING AND APPROVAL PROCEDURES.......................................................... 6-5 

6.2 NON-SIGNIFICANT (OR MINOR) POST-ROD CHANGES: MEMO TO THE SITE FILE. 

ANY NON-SIGNIFICANT OR RECORDS MANAGEMENT................................................. 6-5 

6.2.1 ADMINISTRATIVE RECORD ...................................................................................... 6-5 

6.2.2 MILITARY MUNITIONS RESPONSE PROGRAM (MMRP) DOCUMENTAION................ 6-6 

6.2.3 ENVIRONMENTAL RESTORATION INFORMATION SYSTEM (ERIS)

DOCUMENTATION ................................................................................................. 6-7 

6.3 PUBLIC HEALTH REQUIREMENTS ..................................................................................... 6-7 

6.4 OFF-SITE RESPONSE ACTION ........................................................................................... 6-7 

6.5 TECHNICAL REVIEW AND ASSISSTANCE........................................................................... 6-8 

6.5.1 SITE-SPECIFIC TECHNICAL ASSISSTANCE................................................................ 6-8 

6.5.2 GROUNDWATER EXTRACTION AND TREATMENT EFFECTIVENESS REVIEW 

(GWETER) PROGRAM ......................................................................................... 6-8 

6.5.3 PRINCIPLES OF ENVIRONMENTAL RESTORATION (PER) WORKSHOP....................... 6-9 

6.5.4 PERFORMANCE-BASED CONTRACTING (PBC)....................................................... 6-10 

6.6 INTERAGENCY AGREEMENT (IAG)/FEDERAL FACILITY AGREEMENT (FFA) ................. 6-11 

6.7 REGULATORY PARTICIPATION........................................................................................ 6-12 

6.8 PUBLIC PARTICIPATION AND COMMUNITY INVOLEMENT ............................................... 6-13 

6.8.1 COMMUNITY RELATIONS PLAN (CRP) .................................................................. 6-14 

6.8.2 ENVIRONMENTAL JUSTICE..................................................................................... 6-14 

6.8.3 TECHNICAL REVIEW COMMITTEE (TRC) .............................................................. 6-14 

6.8.4 RESTORATION ADVISORY BOARD (RAB).............................................................. 6-14 

6.8.5 TECHNICAL ASSISTANCE FOR PUBLIC PARTICIPATION (TAPP) ............................. 6-15 

6.9 DEFENSE STATES MEMORANDA OF AGREEMENT (DSMOA) AND COOPERATIVE 

AGREEMENT (CA) PROGRAM ................................................................................... 6-16 

6.10 MONITORED NATURAL ATTENUATION FOR ENVIRONMENTAL RESTORATION.............. 6-16 

6.11 LAND USE CONTROLS (LUCS)..................................................................................... 6-17 

6.11.1 LUCS AT TRANSFERRING PROPERTY .................................................................. 6-18 
 vi 

6.11.2 LUCS AT ACTIVE INSTALLATIONS ...................................................................... 6-19 

6.11.3 DOCUMENTING AND IMPLEMENTING LUCS IN RODS/DDS ................................ 6-19 

6.12 FIVE-YEAR REVIEWS ................................................................................................... 6-20 

6.13 END OF RESTORATION PROGRAM................................................................................. 6-21 

6.13.1 RESPONSE COMPLETE (RC)................................................................................. 6-21 

6.13.2 REOPENED SITES ................................................................................................. 6-21 

6.13.3 POST REMEDIAL DESIGN PROCEDURES ............................................................... 6-22 

6.14 NATURAL RESOURCE INJURIES (NRI) .......................................................................... 6-22 

6.15 ENVIRONMENTAL RESTORATION ISSUES IN PROPERTY TRANSFER............................... 6-23 

6.15.1 DEED COVENANTS .............................................................................................. 6-23 

6.15.2 POST-TRANSFER RESTORATION ACTIVITIES........................................................ 6-24 

Appendix A. Department of the Army Command Structure 

Appendix B. Restoration Concept 

Appendix C. Non-BRAC Excess Properties 

Appendix D. Examples Of Eligible & Ineligible Restoration Activities 

Appendix E. Table of Eligibility 

Appendix F. Definitions for the Military Munitions Response Program 

Appendix G. Policy for Staffing and Approving Decision Documents 

Appendix H Army DERP Cleanup Goals 

Appendix I. Available DERP Guidance 

http://www.dtic.mil/envirodod/Policies/DERPMgt/DERP_MGT_GUIDANCE_0901.pdf

Appendix J. Abbreviations and Acronyms 
 i 

Preface 

This management plan supplements the roles, responsibilities, and procedures contained 

in Army Regulation 200-1 (AR 200-1) and the accompanying Department of the Army 

Pamphlet 200-1 (DA PAM 200-1) and provides guidance to implement the Army’s 

Defense Environmental Restoration Program (DERP) in accordance with the Department 

of Defense (DoD) Management Guidance for theDefense Environmental Restoration 

Program

SUMMARY OF CHANGES TO THE ARMY DERP

Several important changes have occurred in the Army DERP since the March 1999 

version of this guidance was released: 

¡ Installation Restoration Program (IRP) Qualification - The October 1986 

date to qualify for inclusion in the Army’s IRP must be strictly adhered to. 

Installations may perform only those studies necessary to ascertain the 

need for remedial action, identify the preferred remedial alternative, and 

implement the selected remedial action. See Section 2.2 

¡ Military Munitions Response Program (MMRP) - The MMRP is now a 

program category of the DERP. The Army must develop and maintain an 

inventory of sites that have known or suspected (UXO), discarded military 

munitions (DMM), or munitions constituents (MC). Installations must 

submit (1) Explosive Safety Submissions (ESS) Chemical Safety Submissions (CSS) and/or explosive or chemical warfare material (CWM) site 

plans; and (2) the explosives safety provisions (e.g., land use controls or 

explosive safety-related notices) of transfer documents (e.g., leases, deeds, 

findings of suitability for transfer) for property known or suspected to contain MEC or residual explosive hazards through USATCES, to the Department of Defense Explosive Safety Board (DDESB) for munitions 

responses to munitions and explosives of concern (MEC). See Section 

2.3. 

¡ Transformation of Installation Management (TIM) – With the elimination 

of major Army commands in the installation management process, the environmental chain of command and the management of Army restoration 

programs have been significantly altered. See Sections 3.1, and 5; and 

Appendices A and B. 

¡ Army Cleanup Strategy and Strategic Plan - In 2003, the Army identified 

program goals in its Army Cleanup Strategy and corresponding Strategic 

Plan. The primary goals are to identify common objectives for creating 

consistency and accountability across the Army’s cleanup program and to 
 ii 

provide direction to implement a cost efficient program. You may refer to 

Section 4.1 and Appendix H of this guide. 

¡ Army Environmental Database-Restoration (AEDB-R) - The AEDB-R has 

replaced the Defense Site Environmental Restoration Tracking System 

(DSERTS) and the Restoration Cost-to-Complete System (RCTCS), as the 

primary database of installations and their cleanup sites currently under 

the Army DERP, including MMRP category sites. See Section 4.2.2. 

¡ Cost-to-Complete (CTC) – Estimates must be fully auditable; Remedial 

Action Cost Engineering and Requirements (RACER) is the required system to develop CTC estimates while investigations are underway; and installation personnel must complete mandatory RACER training. See 

Section 4.2.5 

¡ Military Construction (MILCON) – Although the DoD Management 

Guidance for the DERP stated that work classification would be strictly 

enforced, the FY03 Defense Authorization Act (Section 313) reversed that 

directive. MILCON funds will not be used for environmental restoration 

projects. See Section 4.4.3. 

¡ Non-Base Realignment and Closure (BRAC) Excess Properties - Although 

the Army funds DERP for these designated properties with Environmental 

Restoration, Army, (ER,A), the ACSIM BRAC Division has responsibilities in managing the restoration and disposal of these properties. See Sections 3.1, 5.8 and Appendix C. 

¡ Record of Decision (ROD)/Decision Document (DD) Approval - Garrison Commanders will approve installation RODs/DDs of $2 million or 

less. The National Guard Bureau (NGB) will approve their facilities’ 

RODs/DDs of $10 million or less. The BRAC Field Offices (BRAC FO) 

will approve, for all non-BRAC excess properties, all RODs/DDs of $10 

million or less. The US Army Environmental Center (USAEC) will approve all non-NGB active installation RODs/DDs between $2 million and 

$10 million. All RODs/DDs over $10 million will be submitted by the installation through the USAEC to Office of the Director Environmental 

Programs (ODEP) in the Office, Assistant Chief of Staff for Installation 

Management (ASCIM) for approval. See Section 6.1.4 and Appendix G. 

¡ Environmental Restoration Information System (ERIS) Documentation - 

The ACSIM has established an Army policy that requires the storage of 

environmental restoration data in a centralized database. The ERIS was 

developed for this purpose and has replaced the outdated Installation Restoration Data Management Information System. All installations that have 

received ER,A funds to collect environmental restoration data must enter 

that data into the ERIS and must modify existing laboratory contracts to 

meet this requirement. See Section 6.2.3. 
Preface 

 iii 

¡ Performance-Based Contracting (PBC) - The Army staff and USAEC are 

playing a key role in establishing a formalized PBC approach to cleanup at 

active Army installations. Focusing on results instead of the cleanup 

process, PBC allows the Army to buy environmental cleanups for a fixed 

price and at a set schedule and will allow the Army to reduce out-year 

long-term management (LTM) and O&M costs. Private remediation firms 

have the flexibility to conduct environmental cleanups in a manner that is 

cost effective for their company while ensuring that legal requirements are 

met and required milestones are achieved. The Army maintains oversight 

of the cleanup and determines, in consultation with the regulators, the desired outcome. . See Section 6.5.4 

¡ Land Use Controls (LUCs) – LUCs will be documented in RODs/DDs, 

stating only broad objectives, not specific installation implementation actions. Installations will state the LUC, its remedial action objective(s), and 

any critical LUC commitments. Implementation details will be documented in the Remedial Design (RD) Phase. LUCs will be a component 

of the remedy for munitions responses at MRS MMRP category sites. See 

Section 6.11. 

¡ Five-Year Reviews – The USAEC will set the installations’ five-year review schedule for the next FY. The US Army Corps of Engineers 

(USACE) Hazardous, Toxic and Radiological Waste (HTRW) Center of 

Expertise will execute all Comprehensive Environmental Response Compensation and Liability Act (CERCLA) five-year reviews at National Priorities List (NPL) and non-NPL installations being funded by ER,A; the 

only exception will be at those installations that have instituted a performance-based contract. For any residual explosive or environmental hazards 

that do not allow for unrestricted use, the Garrison Commander must ensure that the response remains protective of human health and the environment. Installation must obtain USAEC concurrence prior to submitting 

reviews to regulators. See Section 6.12.

 1-1 

Chapter 1 

Purpose and Applicability 

This Army DERP Management Guidance for active installations provides guidance on the management and execution of the Army IRP, the MMRP, and the 

Building Demolition and Debris Removal (BD/DR) Program categories as related 

to environmental cleanup for active installations and non-BRAC excess properties. Supplementing the roles, responsibilities, and procedures contained in Army 

Regulation 200-1 (AR 200-1) and the accompanying Department of the Army 

Pamphlet 200-1 (DA PAM 200-1), guidance is provided to implement the Army’s 

DERP in accordance with the DoD Management Guidance for the Defense Environmental Restoration Program. The Army DERP at active installations applies 

to environmental restoration activities conducted on installations owned by, 

leased by, or otherwise “possessed by the Army” that are located in the United 

States, its territories and possessions, and the District of Columbia including 

Army National Guard and Army Reserve installations. 

This guidance is not applicable to Army restoration activities overseas, the BRAC 

Environmental Restoration Program (ERP), the Compliance-Related Cleanup 

Program or the Formerly Used Defense Sites (FUDS) Restoration Program but is 

applicable to those installations that will be cleaned up by the ACSIM BRAC Division under the Excess Property Disposal Program using ER,A funds. 

 2-1 

Chapter 2 

Background 

The DERP was formally established by Congress in 1984, and is codified at Title 

10 United States Code (USC) §§2701 – 2707 and §2810. The program provides 

for the cleanup of DoD hazardous waste sites consistent with the provisions of the 

Comprehensive Environmental Response, Compensation and Liability Act of 

1980 (CERCLA) as amended by the Superfund Amendments and Reauthorization 

Act of 1986 (SARA); the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) (40 CFR §300); and Executive Order (EO) 12580, Superfund Implementation. 

SARA §211 authorizes the Secretary of Defense to carry out the DERP. The 

Army, Navy, Air Force, and Defense Agencies program, budget and manage individual transfer accounts. The Office of the Deputy Under Secretary of Defense 

for Installations and Environment (ODUSD (I&E)) establishes program goals and 

provides program management oversight. The Army transfer account is known as 

Environmental Restoration, Army (ER,A). The ODUSD(I&E) establishes the 

DERP goals for the Army DERP in the Financial Management Regulation (FMR) 

(previously the Defense Planning Guidance (DPG) goals). Implementation guidance and procedures to achieve the FMR goals are provided in the DoD Management Guidance for the DERP. See Section 4.5.2. 

The National Defense Authorization Act (NDAA) for FY02 (Public Law 107-

107) amended the DERP by establishing a new program element for the cleanup 

of property known or suspected to contain UXO, DMM or MC. It requires the 

Army to develop and maintain an inventory of Defense Sites (referred to as munitions response sites or MRS) that are known or suspected UXO, DMM or MC at 

other than on operational ranges, operating manufacturing or storage facilities, 

and permitted demilitarization facilities). 

2.1 ARMY DEFENSE ENVIRONMENTAL 

RESTORATION PROGRAM (DERP) 

The DoD Management Guidance for the Defense Environmental Restoration 

Program addresses three umbrella environmental restoration areas: 

¡ Active installations. 

¡ BRAC. 
2-2 

¡ FUDS, which are defined as real property that was under the jurisdiction 

of the Secretary and owned by, leased by, or otherwise possessed by the 

United States (including governmental entities that are the legal predecessors of DoD or its Components) and those real properties where accountability rested with DoD but where the activities at the property were 

conducted by contractors (i.e. government-owned, contractor-operated 

[GOCO] properties) that were transferred from DoD control prior to 17 

October 1986. The Army is DoD’s Executive Agent for this program. 

USACE executes this program is executed for the Army.

This guidance only applies to the active installations of the Army, including the 

non-BRAC excess installations. 

Each of these restoration programs has three program categories. These program 

categories are: 

¡ IRP. The IRP category refers to environmental responses (e.g, investigation, cleanup) to hazardous substances, pollutants, contaminants, and POL. 

See Section 2.2. 

¡ MMRP. The MMRP category refers to refers to munitions responses to 

UXO, DMM or MC. The MMRP integrates, to the extent practical, explosives safety and environmental requirements to protect public safety, human health, and the environment. See Section 2.3. 

¡ BD/DR. The BD/DR program category refers to the demolition and removal of unsafe buildings and structures at facilities or sites. See Section 

2.4. 

Because the Army had previously conducted responses on sites known or suspected to contain UXO, DMM or MC, munitions response actions can occur under the IRP category or MMRP category. 

2.2 INSTALLATION RESTORATION PROGRAM 

(IRP) CATEGORY 

Within the Army DERP, IRP category responses focus on identifying, investigating, and cleaning up Army lands contaminated before October 17, 1986 to eliminate unacceptable risks to human health and the environment. The 1986 date to 

qualify as an IRP response is a new requirement for Army installations, in accordance with the DoD Management Guidance for the Defense Environmental Restoration Program, and must be strictly adhered to throughout the Program. 

Installations may perform only those studies necessary to ascertain the need for 
Background 

 2-3 

remedial action, identify the preferred remedial alternative, and implement the 

selected remedial action. 

IRP category responses are conducted consistent with CERCLA, as amended by 

the SARA, using the process described in the NCP, 40 CFR Part 300, and, if applicable, consistent with the substantive requirements of the Resource Conservation and Recovery Act (RCRA) corrective action process. Identification, 

investigation, and cleanup of Solid Waste Management Units (SWMUs) under the 

RCRA corrective action process may be eligible for environmental restoration 

program funds if contamination at the SWMU occurred prior to 1986 and the 

SWMU was inactive or closed prior to being subjected to RCRA requirements. 

The IRP also complies with state, regional, and local requirements that have been 

identified as Applicable or Relevant and Appropriate Requirements (ARARs) in 

the CERCLA ROD or DD. 

The IRP addresses releases to the environment that occurred prior to October 17, 

1986 of the following: 

¡ Hazardous substances or pollutants and contaminants as defined in 

CERCLA. 

¡ Petroleum, oil, or lubricants (POL), as required by law. 

¡ DoD-unique materials. 

¡ Hazardous wastes or hazardous waste constituents. 

¡ Low-level radioactive materials or low-level radioactive wastes. 

At IRP category sites where the release to the environment did not occur prior to 

October 1986, work may continue on those sites already in the AEDB-R. 

Under the IRP category, the Army may conduct munitions responses when: 

¡ The release occurred prior to 30 September 2000, and 

¡ The release is at a site that is not an operational range, an active munitions 

demilitarization facility, an active waste military munitions (WMM) 

treatment or disposal unit or a FUDS, and 

¡ The site’s costs for UXO, DMM or MC were identified and included in 

the DSERTS (now AEDB-R) prior to 30 September 2002, and was not 

classified as “Response Complete (RC)” in the DSERTS.
2-4 

2.3 MILITARY MUNITIONS RESPONSE PROGRAM 

(MMRP) CATEGORY

The MMRP category includes munitions responses to address UXO, DMM and/or 

MC at sites other than on operational ranges. 

See Appendix F for a more detailed listing of MMRP terms.

 Under the MMRP category, the Army may conduct munitions response activities 

when: 

¡ The release occurred prior to 30 September 2002; and 

¡ The release is at a site that is not a FUDS, an operational range, an active 

munitions demilitarization facility, or an active WMM treatment or disposal unit that operated after 30 September 2002; and 

¡ The site’s MMRP costs were not identified or included in AEDB-R prior 

to 30 September 2000.

Funds appropriated for activities to address UXO, DMM, or MC cannot be used 

for: 

 Locations outside of the United States. 

 The presence of military munitions resulting from combat operations. 

 Operational ranges (previously defined as active or inactive ranges). 

 A facility that is used for or was permitted for the treatment or disposal of 

military munitions.

The Army was required to initiate an inventory of defense sites (referred to as 

MRS) with UXO, DMM or MC by 31 May 2003, and update the inventory annually until complete. The data collected during this inventory on defense sites provides the MRS that will be addressed as MMRP category sites. Specific 

requirements for munitions response actions and site-level CTC will be developed 

in AEDB-R. The USAEC is responsible for the initial input of MMRP category 

sites into AEDB-R. 
Background 

 2-5 

2.4 BUILDING DEMOLITION AND DEBRIS 

REMOVAL PROGRAM (BD/DR) CATEGORY

The BD/DR program category is defined as “the demolition and removal of unsafe buildings and structures at facilities or sites that are or were owned by, leased 

to, or otherwise possessed by the United States and under the jurisdiction of the 

Secretary of Defense. The Army does not provide funding for BD/DR under the 

DERP unless the unsafe building or structure has remained unused since October 

17, 1986 and is an integral part of activities during IRP or MMRP category responses. Use of ER,A funding for BD/DR requires extensive preliminary coordination and must be authorized by the Deputy Under Secretary of Defense, 

Installations and Environment (DUSD (I&E)). (Note: Buildings used in the production, demilitarization and/or other munitions-related operations may be contaminated with concentrations of MC that present a potential explosive hazard. 

The demolition of such buildings requires assessment of the risks and review by 

the explosive safety community.) 

See Appendix D for examples of restoration activities eligible for funds under the 

Army DERP, and Appendix E for details on general eligibility under the Army 

DERP 

 3-1 

Chapter 3 

Roles and Responsibilities 

AR 200-1 describes roles and responsibilities for the Army DERP of various organizations within the chain-of-command. The following activities have roles 

that are different from those described in AR 200-1, primarily necessitated by the 

Transformation of Installation Management (TIM) reorganization. 

3.1 HEADQUARTERS, DEPARTMENT OF THE 

ARMY

The Installation Management Agency (IMA), as a Field Operating Agency (FOA) 

under the ACSIM, oversees all US Army-wide installation management. The HQ 

IMA monitors installation cleanup programs. The IMA Regions monitor the installation cleanup program within the region and coordinate with installations and 

ACSIM on issues of regional, regulatory, and public concern. 

The Major Army Commands (MACOMs) with special installations monitor their 

installation restoration program. These MACOMs coordinate with installations 

and ACSIM on issues of regulatory and public concern. 

The BRAC Division and its Field Offices (FOs) support the ACSIM in managing 

non-BRAC excess properties. Although the DERP for these properties is funded 

by ER,A, the BRAC Division manages the restoration and disposal of these properties. 

The USAEC is a FOA supporting the ODEP and the BRAC Division in managing 

Army environmental programs. The USAEC is the program manager for the 

Army DERP for active installations and non-BRAC excess properties. The 

USAEC develops the active installation DERP budget, compiles obligation plans 

and tracks obligation of funds, reports on progress through ODEP and ACSIM to 

the Deputy Assistant Secretary of the Army for Environment, Safety and Occupational Health (DASA (ESOH) for input to the ODUSD (I&E) In-Progress Reviews (IPRs), develops Army-wide guidance, and coordinates program activities 

and requirements with IMA. The USAEC also oversees the execution of the 

DERP at active installations. The USAEC has assigned individuals as Environmental Restoration Managers (ERMs) who serve as the technical environmental 

link between installation or garrison environmental offices and HQDA. The 

ERMs are responsible for direction and management of the Army DERP for assigned installations. The ERM assists the installation with the prioritization of 

Army DERP requirements, monitors project execution for obligation and reporting, and provides technical and financial guidance to assigned installations. The 
 3-2 

USAEC has assigned Program Coordinators (PCs) to work with the installations 

and ERMs on reporting requirements such as AEDB-R, obligation plans, and 

quarterly progress reports. 

The United States Army Technical Center for Explosives Safety (USATCES), 

acting for the Army Safety Office, develops Army policies, procedures, and regulations to ensure compliance with the DoD Explosives Safety Standards (DoDD 

6055.9-STD). USATCES recommends explosives safety policy for the management and cleanup of real property known or suspected to contain MEC; provides 

technical assistance and advise on matters related to munition responses and explosives safety to Garrison Commanders and others; reviews and provides Army 

approval for explosive safety submissions, chemical safety submissions, and/or 

explosive or chemical warfare material site plans submitted to the Department of 

Defense Explosives Safety Board for approval. USATCES also reviews the explosives safety provisions (e.g., land use controls or explosive safety-related notices) of transfer documents (e.g., leases, deeds, findings of suitability for transfer) 

for property known or suspected to contain MEC or residual explosive hazards 

that, per DoDD 6055.9-STD, must be submitted to the DDESB for review and 

approval prior to the transfer. 

3.2 U.S. ARMY INSTALLATIONS

The Garrison Commander, or other designated authority when there is no Garrison Commander, is responsible for executing the installation’s environmental 

programs. The Garrison Commander is responsible for tasking the installation’s 

DERP Executors, reporting to their USAEC ERM, coordinating regulatory and 

community involvement, and for ensuring compliance with DoD policies, to include explosive safety policies, and applicable federal and sates laws and regulations. 

The Remedial Project Manager (RPM) is the installation coordinator of the numerous restoration activities among the Army, the U.S.Environmental Protection 

Agency (USEPA), state agencies, and the local community. The RPM position is 

assigned by the Garrison Commander and has overall responsibility for the DERP 

at the installation. 

The DERP Executor conducts remedial responses (identification, investigation, 

and cleanup of contamination) at active installations at the direction of the RPM. 

Army installations may execute projects and the USACE and the US Army Center 

for Health Promotion and Preventive Medicine (USACHPPM) may execute specific projects for the DERP. 

3.3 REGULATORY AGENCIES

State regulatory agencies are involved in the DERP at Army installations. Points 

of contact at state regulatory agencies are established for each installation. 
Background 

 3-3 

CERCLA requires that cleanup documents be coordinated with State regulators 

and appropriate federal agencies, such as those entities serving as Natural Resource Trustees. Installations provide state regulatory agencies access to program 

information (with due consideration of issues related to accuracy, national security, and other established forms of confidentiality or privilege), including draft 

data and documents approved by the USAEC ERM. 

In addition to state regulators, the USEPA is involved in the Army DERP at installations on the USEPA’s National Priorities List (NPL). The Army, the EPA, 

and the state regulators work together to develop cleanup schedules, sampling and 

analysis plans, and the appropriate decision documents for both removal actions 

and remedial actions at NPL sites. Cleanup terms, document delivery and cleanup 

schedules are memorialized in Federal Facility Agreements (FFAs). See Section 

6.7 for additional information concerning regulatory agencies. 

3.4 OTHER STAKEHOLDERS

Other stakeholders, such as members of the local communities or Native American tribes or governing bodies also provide input to the Army DERP. In addition, federally recognized tribes may serve as Natural Resource Trustees. See 

Section 6.8. 

 4-1 

Chapter 4 

Program Development and Management 

The Army plans, programs, and budgets to implement remedial response actions 

at installations that remediate contamination in accordance with the goals set forth 

in the DoD FMR, the procedures in the OSD Management Guidance for the 

DERP, the policies in AR 200-1, and guidance in DA Pam 200-1. 

4.1 PROGRAM GOALS AND OBJECTIVES

The DoD developed cleanup goals and objectives for the IRP category at active 

installations and presented the goals and objectives in the FMR. Program goals 

are being developed for the MMRP category so as not to impact existing Defense 

goals for the IRP. The DoD evaluates the Army environmental program based on 

compliance and consistency with FMR guidance at semi-annual IPRs. 

The FMR directs that the Army reduce risk to protect human health and the environment and comply with legally enforceable agreements, orders, and laws 

through implementation of cost-effective response actions. The current FMR establishes the following environmental restoration goals for installations: 

¡ As installations enter into new (or adjust existing) regulatory agreements, 

the concept of flexible schedules and flexible sequencing of work should 

be included (i.e., avoid milestones based on specific dates). 

¡ Sequencing of work should reflect the results of Relative Risk Site 

Evaluations (RRSEs). 

¡ Restoration activities should support associated requirements of the 

Agency for Toxic Substances and Disease Registry (ATSDR) and Defense 

State Memoranda of Agreements (DSMOA).

In addition, the Army has identified program goals in its Army Cleanup Strategy 

and corresponding Strategic Plan. These additional goals and metrics (see Appendix H) provide direction to implement a cost efficient program. 

4.2 PROGRAM IMPLEMENTATION

To ensure consistency in the manner in which the Army’s DERP is implemented 

to meet the Defense goals, several databases, documents, and reports play key 

roles in the process. The Installation Action Plan (IAP), the AEDB-R, the RRSE 

(Risk Assessment Code (RAC) for MMRP), and the CTC are all inter-related; require input from one another; and, in turn, provide output to each other. Each 
 4-2 

must be internally coordinated to ensure overall consistency within the Army’s 

DERP. 

4.2.1 Installation Action Plan (IAP) 

The key document in the management and execution of the DERP is the IAP. 

The IAP outlines the total multi-year integrated, coordinated approach to achieving an installation's DERP goals. The plan is used by the USAEC, NGB, major 

Army command (MACOM), IMA and installations to monitor requirements, 

schedules, and budgets. For each site within the AEDB-R, the IAP documents 

DERP requirements, the rationale for the technical approach, and corresponding 

financial requirements. Prior year funding and cost estimates through the entire 

remedial processes are included. Estimates of cost must be fully supportable, either using the RACER estimating model or an engineer estimate generated by an 

industry-wide accepted model. (See Section 4.2.5) The IAP contains the DERP 

history, current AEDB-R status, contaminants of concern, response actions taken, 

past milestones, and any possible future response actions. 

Each installation receiving ER,A funds is required to prepare an IAP annually. In 

the case of the NGB, the NGB acts as the installation and is responsible for preparing the IAP. Installations update and submit their IAPs annually to the 

USAEC. For those installations where USAEC conducts an IAP workshop, the 

installation will submit the completed and signed IAP to USAEC within 90 days 

after completion of the workshop. For those installations having no IAP workshop, the IAP will be updated and submitted to USAEC by 30 May of each fiscal 

year. Signatures are only required for the purpose of approving and transmitting 

the official annual IAP that resulted from the IAP workshop or annual update by 

the installation. Even though an installation is required to officially submit an approved IAP annually, the installation should update the plan whenever a change to 

the program occurs. 

Installations should involve federal, state, local regulators, tribal governments, 

and community members of an installation’s Restoration Advisory Board (RAB) 

when developing and updating the IAP so they may participate in the planning 

process. 

The DoD recommends that environmental management plans for DERP, such as 

IAPs, be made available to environmental regulators and the public. The Army 

also encourages using the IAP to brief the planned restoration activities for the 

installation at RAB and TRC meetings, and public meetings. However, all IAPs 

must have the constrained and unconstrained site-level CTC removed prior to distribution to the public or regulators or placement in the Administrative Record or 

information repository. Additionally, public affairs and security reviews of the 

public version IAP must be conducted prior to distribution. 

The Army’s MRS have been identified in its inventory of former ranges, “Closed, 

Transferred, and Transferring Range/Site Inventory Program.” Installations must 
Program Development and Management 

 4-3 

share their Phase 3 Range & Site Inventory Reports with regulators and, as appropriate, with stakeholders. Installations should incorporate MRS information into 

their IAPs as their inventories are completed and final inventory reports are issued. Planning is documented through the IAP process, beginning with the IAP 

workshop where all interested parties are gathered together to discuss the installation cleanup program. Attendees at the workshop review each site and determine 

the best course of action to complete the cleanup. 

The USAEC will conduct annual IAP workshops for installations with significant 

cleanup programs. The IAP workshops assist in IAP preparation and ensure consistency with Army program guidance. The IAP reviews the program’s efforts to 

achieve cost-effective and expeditious completion of the cleanup effort. The 

workshops also serve as a forum to obtain significant stakeholder input in the 

planning process. In addition, the resulting IAP can be the basis for state support 

under the DSMOA program. The workshops are typically one to three days in 

duration. 

The USAEC will examine descriptions and plans of action for each AEDB-R site 

requiring ER,A funding for technical soundness and internal consistency. The 

associated cost estimates, broken out both by year and by program phase will also 

be reviewed representing a key step in the process of building a coherent and prioritized program from a compilation of individual projects. In general, IAP 

Workshops serve as an important tool to assist in information exchange throughout the Army DERP. Furthermore, IAP Workshops provide a useful opportunity 

for installation teams to consider their cleanup programs on an integrated level. 

The USAEC will provide a meeting facilitator, and the necessary administrative 

support to produce a draft IAP at the meeting. Installations should be able to explain their technical requirements (as well as the basis for estimated costs), and 

take the necessary steps to ensure attendance by other stakeholders. 

Additional IAP guidance is available on the Internet at: 

http://www.denix.osd.mil/denix/Public/Policy/Army/IRP/iap99f.html

4.2.2 Army Environmental Database-Restoration (AEDB-R) 

 The AEDB-R, formerly known as the DSERTS and the RCTCS, is a database 

of installations and cleanup sites, to include MRS, for which the installation is 

responsible that are currently in the Army DERP. The AEDB-R provides an 

automated Internet-based application to manage, track, and query data on activities conducted under the Army DERP. The AEDB-R data are used to meet upward reporting requirements and are a source of information for the following: 

¡ The DERP Annual Report to Congress. 
 4-4 

¡ Army’s Environmental Restoration Financial Liability Statement. 

¡ Program Objective Memorandum (POM). 

¡ President’s Budget. 

¡ Site-level CTC. 

¡ Relative Risk Site Evaluations (RRSEs) or Risk Assessment Codes 

(RACs). 

¡ DERP Obligation Plans. 

¡ DoD In-Progress Reviews (IPRs/Measures-of-Merit (MOMs)). 

¡ ACSIM DERP Reviews. 

¡ IAPs.

Installation personnel must maintain a current list of all sites at the installation in 

AEDB-R that have “Completed," “Underway," or “Future” restoration activities. 

Site-level data must include Site Name/Description, Site Type, Regulatory Statute, and Phase/Cleanup Action status. 

Installations must report key program status elements in AEDB-R, such as information on RODs/DDs, Federal Facilities Agreements (FFAs), RRSE/RAC 

evaluations, and Restoration Advisory Boards (RABs). Installations will also report on Five-Year Reviews and LUCs through AEDB-R. Installations must ensure data for each site is current and must correct any identified data gaps and 

inconsistencies. 

Installations will submit AEDB-R input to the USAEC in accordance with the 

semi-annual AEDB-R data call memorandum published by USAEC. The 

USAEC ERMs (and NGB for NGB installations) will provide quality assurance 

on the AEDB-R data submitted by installations. Non-BRAC excess properties 

must coordinate their data with the appropriate BRAC FO prior to submission to 

USAEC. 

The USAEC provides AEDB-R access, user manuals, Army guidance, and training to installation, BRAC FO, BRAC D, ODEP and other personnel as required 

by new versions and policy/guidance updates. The USAEC also provides on-site 

assistance as requested by the installations. 

The USAEC reviews all data submissions for completeness and consistency with 

the AEDB-R data call memorandum. Any necessary revisions are coordinated 

with the installation. The USAEC consolidates data files into an Army file for 

submittal to ODUSD (I&E). 
Program Development and Management 

 4-5 

For MMRP data, the USAEC ensured the transition of MRS data from the Army 

Range Inventory Database (ARID) to AEDB-R. MMRP category sites require the 

same biannual updating as IRP category sites. If MMRP eligible MRS are found 

after the inventory is complete, they will be entered into AEDB-R during the 

semi-annual updates. The MRS identified during the inventory were assigned a 

RAC score, which satisfied criteria to be entered into AEDB-R. Until the MMRP 

is more mature, the USAEC will continue to centrally update AEDB-R on the 

web and coordinate the data with the installations and the assigned USAEC ERM.

For additional information on the AEDB-R, visit the USAEC website at: 

http://aec.army.mil/

The AEDB-R may be accessed at https://aerp.apgea.army.mil/ Contact the 

USAEC Help Desk for user account requests 

The Help Desk can be reached at 410-436-1244 or DSN 584-1244 or by e-mail at 

usaechelpdesk@aec.apgea.army.mil

4.2.3 Relative Risk Site Evaluation (RRSE) 

The DoD has established risk reduction as a major program goal for the DERP 

and has implemented a strategy to ensure that high-risk sites receive priority for 

cleanup. The RRSE is the foundation of that strategy for IRP category sites. The 

AEDB-R sites are categorized into relative risk groups based on an evaluation of 

contaminant concentrations, migration pathways, and human and ecological receptors in groundwater, surface water, sediment, and surface soils. Evaluations of 

these factors at a site are combined to place the site in an overall category of 

"high,” "medium,” or "low" relative risk. The RRSE should not be used to: 

¡ Select a remedy. 

¡ Determine whether or not response actions should be taken. 

¡ Substitute for a baseline risk assessment or health assessment, which identifies risks, or the health assessment, which identifies the potential health 

effects on the community, associated with the site. 

¡ Determine whether a site should be classified as Response Complete (RC) 

or No Further Action (NFA). 

¡ Avoid meeting legal requirements.

A RRSE is required for all AEDB-R IRP category sites with ongoing cleanup activities and should be performed with available site data. Using the RRSE module 

in AEDB-R, installations must evaluate available data for each AEDB-R cleanup 
 4-6 

site. Although previously calculated RRSE data is maintained, a new RRSE calculation is not required and should not be performed at sites: 

¡ Classified as having all (Remedy-In-Place) RIP, even though the sites may 

be in Remedial Actions (Operations) RA(O) or LTM. 

¡ Classified as RC. 

¡ Having only BD/DR requirements.

Installations can add sites to the AEDB-R without information to conduct a RRSE 

as pending sites, but they cannot be approved until the RRSE is completed and 

reviewed. Sites with chemical agent contamination that cannot be safely sampled 

can be added to AEDB-R as “Not Evaluated." An installation must use Operations and Maintenance (O&M) funds to obtain the data to develop the initial 

RRSEs. 

Installations must solicit stakeholder involvement throughout the RRSE process. 

The IAPs, together with the RRSE, can serve as the basis for dialogue with regulators and, when appropriate tribal governmental representatives) and stakeholders (e.g., community members of an installation's Restoration Advisory 

Board (RAB) on sequencing work at sites. 

Installations will review and update their RRSE data semi-annually during the 

Spring and Fall AEDB-R data calls. The RRSE data are provided to the ODUSD 

(I&E) at mid-year and at the end of the FY. The DoD uses relative risk data to 

measure progress, show risk reduction and potentially adjust program goals at the 

semi-annual DoDIn-Progress Reviews (IPRs). The DoD Relative Risk Working 

Group developed a quality assurance program for RRSE data. After AEDB-R 

data are provided to the ODUSD (I&E), the DoD returns questionable RRSE data 

for explanation or possible corrective action. Installations must reevaluate the 

relative risk of sites for each AEDB-R data call, particularly for those sites where 

new data is available or where data is questionable. 

For detailed guidance on the RRSE, see the 1997 DoD Relative Risk Site Evaluation Primer, available on the Internet at: 

http://www.dtic.mil/envirodod

4.2.4 Risk Assessment Code (RAC) 

Pending implementation of the Munitions Response Site Protocol (MRSP), the 

RAC has been adopted as an interim DoD-wide approach for providing a single, 

consistent tool for assigning to an MRS known or suspected to contain MEC a 

relative priority. The Army will offer regulators and public stakeholders opportu-
Program Development and Management 

 4-7 

nities to participate in the RAC development process. Each MRS known or suspected to contain MEC, to include MRS where a response has been completed, 

shall be assigned a RAC score, as soon as possible. Until the RAC is assigned, 

MRS known or suspected to contain MEC will be classified as “not yet evaluated.” The installation assign a RAC to a newly identified MRS that are known or 

suspected to contain MEC within 12 months of its identification. 

Due to the inherent differences between long-term environmental risks and the 

immediate risks posed by explosives, the RAC is the framework for prioritizing 

the explosive safety hazards. It identifies the potential explosives safety hazards 

identified at a site by assessing the risk at sites known or suspected to contain 

MEC. Certain sites may have a RAC score to address potential explosive hazards 

and a RRSE addressing the relative risk posed by environmental contamination at 

the site. 

Installations must review and update RAC data semi-annually during the Spring 

and Fall AEDB-R data calls. The RAC data are provided to the ODUSD (I&E) at 

mid-year and at the end of each FY. A RAC is required for all MMRP AEDB-R 

sites known or suspected to contain MEC and should be performed with available 

site data. Each MRS (including MRS where a munitions response has already 

been implemented) were assigned a RAC during the MMRP Preliminary Assessment phase (Army Range Inventory). Newly identified sites shall be evaluated 

and a RAC assigned within 12 months of identification. Until the RAC is assigned, the MRS will be classified as “not yet evaluated." The RAC should not be 

used to: 

¡ Select a remedy. 

¡ Determine whether or not response actions should be taken. 

¡ Substitute for a baseline risk assessment, which identifies the risks, or the 

health assessment associated with the site health assessment, which identifies the potential health effects on the community, associated with the site. 

¡ Determine whether a MRS should be classified as RC or NFA. 

¡ Avoid meeting legal requirements.

Regulators and public stakeholders will be offered opportunities to participate in 

the RAC development process. The IAPs, together with the RAC, can serve as 

the basis for dialogue with stakeholders (local community, RABs, and regulator 

representatives) on sequencing work at sites. 

4.2.5 Cost-to-Complete (CTC) 

The CTC estimate for environmental restoration projects is an important planning 

tool in the budget process. The HQDA uses the CTC estimates to support the fi-
 4-8 

nancial liability statement, to support POM submissions, develop the annual 

President's budget, and to track cost avoidance measures implemented by Army 

installations. 

Since 1990, several federal financial acts added new requirements for DoD to accurately report environmental liabilities. The purpose of these acts was to improve general and financial management practices in the federal government. 

Agencies are required to develop multi-year strategic plans, annual performance 

plans, and annual performance reports. In addition, federal agencies are required 

to produce annual auditable financial statements and accurate cost and performance information, as well as to integrate budget, accounting, and program data. In 

summary, these statutes require the DoD and the Army to develop auditable financial statements that report both assets and liabilities. A liability is defined as a 

probable and estimable future outflow of resources due to a past government 

transaction or event. 

Liability disclosure includes having complete, formal, and auditable documentation of all data, models, and other information used to develop the estimate of the 

environmental restoration liability. The CTC estimates and the funding levels in 

the annual financial statements for environmental restoration must be consistent 

with each other. Further, these funding levels must be consistent in any reports 

provided to outside entities, such as in the DERP Annual Report to Congress. 

The CTC estimates form the basis of the environmental liabilities reported in the 

Army’s Annual Financial Statement in compliance with the Chief Financial Officers Act of 1990. In addition, CTC estimates must comply with DoD Financial 

Management Regulation (FMR) 7000.14-R, Volume 4, Chapter 14, Accrued Environmental Restoration (Cleanup) Liabilities (October 1999). This regulation 

requires documentation of data sources, methods of estimation and documentation 

of management review of CTC estimates. FMR 7000.14-R, Section 140105, 

stipulates that CTC estimates are subject to audit. Therefore, information used to 

develop CTC estimates for the environmental restoration programs is subject to 

audit by the US Army Audit Agency and the DoD Inspector General. 

4.2.5.1 CTC Estimates 

Installations shall prepare annual CTC estimates for each IRP category site in the 

AEDB-R with a status of “underway” or “future” and USAEC shall prepare the 

CTC estimates for each MMRP site in the AEDB-R. These estimates shall reflect 

the environmental restoration strategy and sequence as presented in the IAP for 

the site and any changes that occurred since the last CTC update. 

Installations shall prepare a CTC estimate only when there is sufficient sitespecific data to make a “probable” estimate without making unsubstantiated assumptions. If a site-specific CTC estimate is not prepared, installations shall 

document the rationale for not doing so, describe their plan of action and milestones for gathering sufficient site-specific information to develop an estimate, 
Program Development and Management 

 4-9 

and forward that information with the rest of the installation's CTC data. Installations shall ensure the reliability and completeness of the data used to calculate 

their CTC estimates. Installations are required to ensure that these data sets are 

complete, up-to-date, and documented in a manner that will withstand an audit. 

The CTC estimates shall include, on a current cost basis (not adjusted for inflation), all anticipated costs required to effectively restore the site, as well as the 

costs of complying with applicable legal and regulatory requirements. This requires that CTC estimates: 

¡ Be site-specific. 

¡ Consider the reasonably anticipated future land use of the site. 

¡ Be based on technologies that are currently available. 

¡ Include the cost of completing all remaining studies, restoration, removal, 

or remedial action (including long-term operating of remedial systems). 

¡ Include costs in the LTM phase, to include all five-year review costs, costs 

for management and monitoring of LUCs applied to sites where cleanup to 

an unrestricted use can not be attained, costs of decommissioning treatment systems and abandoning monitoring and extraction wells. Prior to 

completion of Remedial Action (RA) requirements, long-term CTC estimates shall be adjusted annually, through indexing, to maintain them on a 

current cost basis. 

¡ Include costs associated with deletion from the NPL, where appropriate.

The CTC estimates shall document environmental restoration cost information, to 

include identifying: 

¡ The source of requirements (e.g., applicable laws and regulations). 

¡ Methods for assigning estimated total environmental restoration costs to 

current operating periods. 

¡ Material changes in the total estimated costs of environmental restoration 

activities (e.g., due to changes in laws, technology, plans) and the portion 

of the change in estimate that relates to prior period operations. A material change is defined as evidence that a change of more than 10 percent of 

the prior year ending balance (up or down) will occur. 

¡ The nature of estimates and the disclosure of information regarding possible changes due to inflation, deflation, technology, or applicable laws and 

regulations.
 4-10 

The CTC estimates should include all anticipated future costs, including LTM 

where necessary. In the event the number of years required for LTM is undetermined, as may be the case for certain classes of sites, such as landfills, the years 

should be based on past similar sites. CTC estimates should not exceed 30 years. 

In addition, CTC estimates should include all project management (e.g., USACE 

costs, owner costs) and contingency costs (e.g., risk) associated with the environmental restoration of the site. Legal, regulatory, and administrative costs associated with site closeout should also be included in CTC estimates. 

The CTC estimates shall not include the costs of environmental compliance, pollution prevention, conservation activities, contamination or spills associated with 

current operations, or treaty obligations. The Army accounts for those as part of 

ongoing operations. Similarly, expenses associated with the operation, management, or sustaining operational ranges are not included as environmental restoration liabilities. 

4.2.5.2 REMDIAL ACTION COST ENGINEERING AND 

REQUIREMENTS (RACER) 

In FY02, the Army began using the RACER model to develop CTC estimates for 

sites without a Feasibility Study (FS). The RACER is a cost-estimating tool that 

estimates costs for all phases of remediation: Interim Actions/Interim Measures, 

studies (Preliminary Assessment/Site Investigation PA/SI, Remedial Investigations/Feasibility Studies (RI/FS), RCRA Facility Investigations/Corrective Measures Studies (RFI/CMS)), Remedial Design, RA (including operation and 

maintenance), and site work and utilities. The engineering solutions within 

RACER are based on data from government and industry, construction management agencies, technology contractors and vendors, and historical project information. 

During the development of a ROD/DD, other auditable cost estimating models 

may be used based on site-specific data. If installations use another computerized 

model to calculate CTC estimates, they shall ensure that the computer model used 

for this purpose is verified, validated, and accredited per DoD Instruction (DoDI) 

5000.61 - DoD Modeling and Simulation Verification, Validation, and Accreditation (VV&A). Some estimates cannot be developed using a computer model because some environmental restoration actions are truly site-specific and unique to 

a particular set of contaminants for which no computer model may exist. In these 

instances, estimates must, by necessity, be developed based on engineering studies or estimates. Estimates developed based on engineering studies or estimates, 

other methods, or computer models not validated per DoDI 5000.61 shall be fully 

documented. The information submitted to the USAEC for inclusion in the annual financial statement shall be annotated accordingly. 
Program Development and Management 

 4-11 

4.2.5.3 CTC Revisions 

Installations shall update their IRP category site CTC data 30 days prior to their 

individual IAP workshops. If an installation does not have an IAP workshop 

scheduled within the FY, CTC updates must be completed by June of each year. 

The USAEC shall update an installation’s MMRP site CTC data following the 

IAP workshop or by June of each year if there is no workshop. 

The CTC estimates for a site shall be revised when there a “material change” occurs. Such a change must be fully documented by a signed memorandum maintained at the installation, and the IAP for the site must be revised to reflect this 

change. The revised estimate shall be forwarded to the USAEC, or the NGB for 

NGB installations, for incorporation into the Army-wide annual financial statements. In the event of a material change in the liability from year to year, the nature of the change must be disclosed. Reasons for such a change may include 

level-of-effort, inflation, delays in implementation, and new regulatory requirements. 

For detailed guidance on CTC procedures see “Developing Cost-to-Complete 

Estimates & Financial Reporting of Environmental Restoration Liabilities for the 

US Army Environmental Restoration Program," January 2002. 

4.2.5.4 CTC Audits 

Environmental restoration estimates for both the CTC and environmental liability 

reporting in an annual financial statement are subject to audit. The financial management regulations emphasize that financial records, to include CTC estimates, 

must have audit trails to allow transactions to be traced from the point of initiation 

to the final report. A fundamental requirement of a good audit trail is that all 

transactions must be adequately supported with pertinent documents and source 

records. The source document shall include a narrative providing sufficient explanation for the basis of the estimate, the date prepared, the preparer's name, and 

supervisor’s signature. Original estimates and changes in those estimates shall be 

documented and available for review. Documentation must exist at the time of an 

audit. 

These requirements should be identified in the contract Statement (or Scope) of 

Work if the design or FS contractor must develop a cost estimate for the removal 

or remedial action. The contractor’s cost estimation may be subject to audits, thus 

the contractor must be able to justify the process. 

Installations shall include an evaluation of environmental liability disclosure practices as a part of any installation-specific environmental self-auditing programs, 

such as the Army's Environmental Performance Assessment System (EPAS) formerly known as Environmental Compliance Assessment System (ECAS). 
 4-12 

The ACSIM has directed that the USAEC will institute field audits to verify supporting documentation to the requirements identified for CTC. The USAEC will 

conduct CTC reviews at selected Army DERP sites. The following protocol will 

be used to determine sites selected for review: 

¡ Sites with deficiencies identified during previous audits. 

¡ Sites with remedial action costs greater than $5 million scheduled for execution in the current or next FY. 

¡ Sites where cleanup versus study phase estimates are disproportionate 

(e.g., large study cost with small cleanup costs, design costs with no associated cleanup costs, design costs greater that 40 percent of the associated 

cleanup costs). 

¡ Sites where there is a material change in the financial liability. 

4.2.5.5 CTC Training 

The Army has developed a formal training program to certify installation staff in 

the preparation of CTC estimates, to include estimates for munitions responses. 

Installations must schedule formal training programs (e.g., introductory training, 

recurring “refresher” training) for staff personnel engaged in the development of 

CTC estimates or preparation of environmental restoration liability reports. 

Documentation that staff received this training shall be maintained as a part of the 

audit trail for the annual financial statement. 

4.3 BUDGETING

Budgets are determined based on several factors. The Defense goals and the following are taken into consideration: 

¡ Program initiatives. 

¡ Statutory and legal requirements, including agreements with regulatory 

agencies. 

¡ The ability to execute cleanup projects in a given year and the feasibility 

of carrying out the activity in relation to other activities at the installation. 

¡ Cultural, social, and economic factors, including environmental justice 

considerations. 

¡ Short-term and long-term ecological effects and environmental impacts in 

general, including injury to natural resources and lost use. 
Program Development and Management 

 4-13 

¡ Acceptability of the action to regulators, Native American tribes, and public stakeholders. 

¡ Availability of new and innovative technologies that are appropriate for 

use given site conditions. 

¡ Actual and anticipated funding availability. 

Budgets are determined by USAEC and provided to the installations for use during the IAP Workshop and subsequent AEDB-R data entry. 

The USAEC consolidates the programmed requirements and utilizes this information for financial reporting such as the Financial Liabilities Statement, the President’s Budget, the DERP Annual Report to Congress, the Program Objective 

Memorandum (POM) and the Budget Estimate Submission (BES). 

The USAEC develops the Army DERP budget by consolidating installation requirements as programmed in the AEDB-R database, Fall submission. As DERP 

activities progress to meet program goals, the budgets are adjusted based on the 

updated CTC database. 

4.4 FUNDING ARMY DERP ACTIVITIES

Early in the FY, installations will enter their funding requests into the ER,A Funding Request system. This system was developed as a means to provide an automated process for preparing, submitting and approving funding requests by those 

users who can access the World Wide Web (www). Specifically, the system enhances the data collection, analysis, reporting and information sharing of Army 

environmental data. 

The ER,A Funding Request System includes three users roles: the installation 

role, the oversight role (USAEC program coordinators), and the executive role 

(USAEC). The installation role provides the data entry and routes the request up 

to the oversight for approval. The oversight role reviews the funding request and 

either routes the approval up to the executive or routes the rejection back down to 

the Installation. The executive role reviews the funding request and either routes 

the approval up or routes the rejection back down to the oversight level. 

Access to the ER,A Funding Request system is restricted. Users will only see the 

funding requests that they have either created, been granted access to, or that have 

been routed to them. 

The ER,A Funding request system may be accessed at 

https://aerp.apgea.army.mil/ Contact the USAEC Help Desk for user account requests 
 4-14 

The Help Desk can be reached at 410-436-1244 or DSN 584-1244 or by e-mail at 

usaechelpdesk@aec.apgea.army.mil

4.4.1 Priority Setting and Sequencing 

The Army employs a risk management approach in the DERP that protects human 

health and the environment through focusing on actions to reduce risks in the 

short-term and then focusing on longer-term risk management actions. Installations must effectively communicate to stakeholders the Army’s use of risk management in the sequencing, planning, and implementation of environmental 

restoration activities. 

Prioritization and sequencing of environmental restoration activities will be accomplished using the frameworks described in the DoD RRSE Primer and the 

RAC as described in Appendix H, other risk information, and other management 

factors. In prioritizing and sequencing environmental restoration activities for 

funding, some considerations that may have an impact include: 

¡ The relative-risk posed among sites. Generally sites that present a greater 

relative-risk to human health, safety, or the environment will be addressed 

before sites that present a lesser risk. 

¡ The findings of health, safety, or ecological risk assessments or evaluations based on site-specific data. 

¡ The reasonably anticipated future land use, especially when planning response actions, conducting evaluations of response alternatives, or establishing specific response action objectives. 

¡ Implementation and execution considerations (e.g., the availability of the 

necessary systems to implement a particular action; examination of alternatives to responses that entail significant capital investments, a lengthy 

period of operation, or costly maintenance; considering alternatives to removal or treatment of contamination when existing technology cannot 

achieve established standards (Maximum Contaminant Levels, etc). 

¡ For munitions responses, the limitations and capabilities of available technology. 

¡ Economic considerations, including economies of scale, evaluation of total 

life cycle costs, and estimated valuations of long-term liabilities. 

¡ Implementing standing commitments including those in formal agreements with regulatory agencies, requirements for continuation of remedial 

action operations until response objectives are met, other long-term management activities, and program administration. 
Program Development and Management 

 4-15 

¡ Established program goals and initiatives. 

¡ Concerns expressed by regulators and public stakeholders. 

¡ Cultural, social and economic factors, including environmental justice 

considerations. 

¡ Short-term and long-term ecological effects and environmental impacts in 

general, including injuries to natural resources. 

¡ Opportunities to buy out entire installations/states.

For additional guidance on prioritization and sequencing of environmental 

restoration activities, see the DoD Relative Risk Site Evaluation Primer, on 

the Internet at http://www.dtic.mil/envirodod

4.4.2 Funding for New Sites 

ER,A funds may only be used for sites in AEDB-R. A site may be added to 

AEDB-R once the ER,A eligibility is determined, the PA/SI is completed and the 

RRSE category or RAC has been determined. 

4.4.3 MILITARY CONSTRUCTION (MILCON) 

The FY03 Defense Authorization Act revised 10 USC 2707 to specify that environmental restoration projects are not military construction and that such projects 

should be funded from appropriations for environmental restoration (ER,A for 

Army). This rescinds the current DoD Management Guidance for the DERP that 

requires the use of MILCON funding for environmental restoration response activities resulting in the construction of a real property facility. 

4.4.4 Cost Recovery and Cost Sharing 

As a matter of policy, the Army will pursue recovery of response costs of $50,000 

or more from either contractors or other entities that are responsible or partly responsible for environmental damage on Army installations. The terms, “cost recovery” and “cost sharing” are defined as: 

¡ Cost recovery involves money received from private parties to compensate 

the Army for installation costs in completed environmental restoration activities for which the private party bears some responsibility. Cost recovery amounts involving completed environmental restoration activities are 

available for redeposit to the ER,A account for use on other Army DERP 

projects. 
 4-16 

¡ Cost sharing involves amounts contributed by a private party to the Army 

to compensate the Army for environmental restoration activities being 

planned or currently being conducted by the installation for which the private party bears responsibility. Cost sharing amounts are available for 

Army use in its performance of environmental restoration activities at the 

installation.

The Army is authorized to credit its ER,A account with funding recovered pursuant to CERCLA for response costs at Army DERP sites attributable to other nonDoD potentially responsible parties (PRPs) or to the negligence of DoD contractors. The Army may also credit any other funds recovered from a contractor, insurer, surety, or other person to reimburse DoD or the Army for any expenditure 

for DERP activities. 

The Army is establishing processes to identify CERCLA PRPs and to pursue 

them to either take responsibility for environmental restoration or to contribute to 

the cost of response actions, on a total cost recovery or contribution basis, as appropriate. The identification of potential PRPs should occur as early as possible 

in the environmental restoration process. The Environmental Law Division 

(ELD), Office of the Judge Advocate General (OTJAG), is responsible for coordinating with the Department of Justice (DOJ) to pursue claims against such parties. ELD Litigation Branch typically requests the local counsel to prepare a 

litigation report regarding the proposed claims. When cost recovery or contribution claims appear to be possible, the Army will, in coordination with DOJ, retain 

records, documents, and maintain all costs and project documentation necessary 

to support cost recovery claims against the PRPs. 

Seeking to have a PRP, either take responsibility for environmental restoration or 

contribute to the cost of response actions, on a total cost recovery or contribution 

basis, is preferred over expending ER,A funds to pay for response costs that are 

the liability and responsibility of other PRPs. 

In coordination with the garrison legal staff and through the Office of the Judge 

Advocate General (OTJAG), installations shall pursue recovery of response costs 

of $50,000 or more whenever an IRP action on Army property is required because 

of legal requirements or an imminent and substantial threat to human health or the 

environment, and the cooperation of the other PRP could not be negotiated in advance of the work performance. Installations will report to the USAEC, who will 

inform ODUSD (I&E) of all attempts to recover response costs. Installations will 

report the following information, which will be included in the DERP Annual Report to Congress: 

¡ Installation name. 

¡ City (or county if appropriate) and state where the installation is located. 
Program Development and Management 

 4-17 

¡ Status of cost recovery actions (i.e., “Underway," “Complete," “Not Feasible," “No Cost to be Recovered”). Actions that are inactive in a given 

FY but are continuing shall be categorized as “Underway." 

¡ Investigate status of recovery actions deemed sufficient to pursue (i.e., an 

action that will not benefit the government would be considered insufficient to pursue”). 

¡ Cost recovery reported in a previous annual report that has since been determined not to benefit the government. The installation shall report the 

status as “Not Feasible” or “No Cost to be Recovered” and provide a brief 

but complete explanation for the decision. 

¡ Total amount recovered or shared with another PRP or amount recovered 

from a negligent DoD contractor, as of the end of the reported FY. 

¡ Where recovery actions are under way and some costs have been recovered, the total amount recovered as of the end of the reported FY. (If recovery actions are underway and no costs have been recovered as of the 

end of the reported FY, installations shall report that the amount is $0. Installations shall not report estimated future costs). 

¡ Total costs spent in legal and management costs to pursue recovery, as of 

the end of the reported FY. 

¡ Where recovery actions are underway or complete, the cost to pursue the 

action as of the end of the reported FY. 

¡ Where the cost to pursue the action has not been determined but will be 

determined later, “TBD." 

¡ Where the cost to pursue is unknown and is not determinable, “Amount 

Unknown."

If, after coordination with and the concurrence of the USAEC and ELD, an installation decides that it is not in the best interest of the government to pursue such a 

recovery, the installation will inform the USAEC and ODUSD (I&E) of its rationale. 

4.5 EXECUTION STRATEGY

The DoD and the Army have established obligation, disbursement, and defense 

goals for the Army DERP that must be met during program execution. 
 4-18 

4.5.1 Obligation Goals 

The DoD goal for obligation of funds is 28 percent by first quarter, 55 percent by 

second quarter, 80 percent by third quarter, and 100 percent by fourth quarter of 

each FY. 

4.5.2 Disbursement Goals 

To ensure that all ER,A funds are disbursed in a timely fashion, the following 

goals have been established by DoD for ER,A funds:

YEAR OF OBLIGATION CUMULATIVE DISBURSEMENT OF FUNDS 

Initial year 22% 22% 

Second Year 45% 67% 

Third year 22% 89% 

Fourth year 6% 95% 

Fifth year 5% 100% 

4.5.3 Defense Goals 

The Army must meet the goals of the FMR. The FMR requires that IRP restoration activities have remedial systems in place to: 

¡ Reduce relative risk at 100 percent of the identified high relative risk sites 

by the end of FY07 (or within three years for any newly identified high 

relative risk sites). 

¡ Reduce relative risk at 100 percent of the identified medium relative risk 

sites by the end of FY11. 

¡ Reduce relative risk at 100 percent of the identified low relative risk sites 

by the end of FY14.

The DoD has established metrics for the MMRP to complete Preliminary Assessments by 

FY2007 and complete Site Inspections by FY2010. The Army considers the final 

inventory report to be equivalent to the PA, so the Army successfully met the PA metric 

in FY2004 

The most recent information on Defense Goals is available in the Internet at:

http://www.dod.mil/comptroller/fmr/02b/Chapter13.pdf
Program Development and Management 

 4-19 

4.6 PERFORMANCE MEASURES

DoD and the Army establish various Performance Measures for the DERP that 

must be met during program execution. 

4.6.1 Measures of Merit (MOMs) 

The MOMs are the tools used by the Army and ODUSD (I&E) to measure the 

Army’s progress toward goals set forth in the FMR. The Army currently reports 

three MOMs for the IRP to ODUSD (I&E) semi-annually at the IPR: 

¡ Relative Risk Reduction - Tracks both site counts and funding for each 

relative risk category. Status of sites in each relative risk category for 

each FY is used to indicate progress toward the FMR goals of relative risk 

reduction. The main goal is to lower the number of sites in the “High” 

relative risk category. 

¡ Phase Progress - Tracks the number of sites and funds in study, cleanup, 

and RC/NFA categories. Progress is indicated as sites go from the investigation phase and cleanup phase to the RC or NFA categories. The main 

goal is to increase the number of sites remediated and closed out. 

¡ Installations Achieving Final RIP/RC - Tracks the number of installations 

that have all sites in the RIP or RC categories. The main goal is to increase the number of sites in the RIP and RC categories. 

The Army will track the performance of MMRP category sites separately from 

IRP category sites. 

4.6.2 Army Cleanup Strategic Plan Goals

In 2003, the Army implemented a new Cleanup Strategy and identified program 

goals in its corresponding Cleanup Strategic Plan. The primary goals are to identify common objectives for creating consistency and accountability across the 

Army’s cleanup program and to provide direction to implement a cost effective 

program. 

See Appendix H for a detailed explanation of Army Cleanup Strategic Plan Goals 

4.6.3 THE DERP Annual Report to Congress 

The Congress requires DoD to submit an annual Report to Congress that describes 

the DERP accomplishments during the previous FY. Requirements are outlined 
 4-20 

in §120(e)(5) of CERCLA and §211 of SARA, as amended on 10 November 

1993. The report details progress made in carrying out environmental restoration 

activities at military installations, including success stories highlighting significant DERP activities and initiatives; narrative summaries for NPL installations, 

proposed NPL installations, and major BRAC installations; and the status of the 

cleanup. At the end of each FY, the USAEC requests that installations submit 

success story candidates and provide information for narrative summaries. 

The AEDB-R Fall Data submission is a critical source of information for the Report to Congress. Therefore, installations should ensure that the AEDB-R data is 

updated and submitted as required. The USAEC then compiles and submits the 

Army’s input to DoD. The DoD must then submit the report to Congress by 31 

March of each year. 

The DERP Annual Report to Congress is available on the Internet: 

http://www.dtic.mil/DERP/DERP.htm

4.7 PROGRAM TIMELINES

¡ Oct Report to Congress Draft Narratives 

¡ Oct Closeout Obligation Plan for prior FY due 

¡ Nov Fall AEDB-R forwarded to DoD 

¡ Dec Report to Congress Success Stories and Narratives submitted 

¡ Dec DoD Semi-annual IPR 

¡ Jan President’s Budget submitted 

¡ Jan Begin update of CTC requirements 

¡ Feb AEDB-R spring data call begins 

¡ Mar Annual DERP Report to Congress submitted by DoD 

¡ Apr AEDB-R spring data submission due 

¡ May Spring AEDB-R forwarded to DoD 

¡ Jun DoD Semi-annual IPR 

¡ Jun AEDB-R fall data call begins

¡ Jul CTC requirements due to USAEC 
Program Development and Management 

 4-21 

¡ Jul AEDB-R fall data submission 

¡ Sep Upcoming FY Obligation Plan due 

¡ Oct Financial Liabilities Report Due 

 5-1 

Chapter 5 

Program Execution

The Army DERP is executed at the installation level. The installation RPM, the 

designated Army DERP Executor, and USAEC all play a role in the execution of 

the Army DERP. 

5.1 INSTALLATION

The Garrison Commander is responsible for execution of the installation’s 

Army DERP. Where there is no Garrison Commander, the ODEP or appropriate NGB or US Army Reserve Command will designate an alternative authority. The Garrison Commander or other designated authority will assign a 

RPM to ensure all work is accomplished in accordance with regulatory, DoD, 

and Army policy. The Garrison Commander or a designee will also approve 

all required ESS, CSS and/or explosive or CWM site plans being submitted, 

through USATCES, to the DDESB for approval for properties under the installation control. The Garrison Commander executes the Army DERP 

Community Relations Program and determines interest and, if appropriate, 

creates a RAB or Technical Review Committee (TRC). The RPM’s duties include: 

¡ Serve as the primary point of contact between the installation, the 

ATSDR, the USACHPPM, the USAEC, the DERP Executor, regulators, 

and the public, although the Garrison Commander remains the ultimate 

decision authority for the installation 

¡ Coordinate and consult with installation legal counsel on all environmental agreements; coordinate with USAEC on all agreements affecting 

the DERP. Installation counsel should involve Environmental Law Division (ELD), OTJAG when agreements might be inconsistent with 

Army/DoD policy. 

¡ Work with State DSMOA representatives to develop joint execution plans, 

monitor state technical support and review state reimbursement requests as 

necessary. 

¡ Communicate and negotiate with regulators as the primary Army DERP 

representative for the installation. 

¡ Establish and maintain the public repository and administrative record. 
 5-2 

¡ Prepare and submit the IAP, DERP Obligation Plan input, DERP Annual 

Report to Congress input, and related changes through the USAEC PC and 

the USAEC ERM. 

¡ Incorporate ATSDR recommendations from the Public Health Assessment 

into the IAP. 

¡ Implement projects; identify and report funding requirements; and program the necessary ER,A funds through the installation obligation plans, 

CTC, and AEDB-R with estimates of cost and time requirements for performance of specific tasks. 

¡ Assign tasks to the Army DERP Executor; describe the general scope of 

activities; provide project criteria, goals, and general milestones for restoration work; ensure maximum competition when selecting project management services. 

¡ Provide appropriate funds, in coordination with the USAEC, to the Army 

DERP Executor for all work required and ensure that funds are allocated 

only to eligible projects. 

¡ Approve proposed schedules and deadlines for all tasks and deliverables, 

and provide timely comments and approvals to the Army DERP Executor 

on items such as scopes of work and project documents. 

¡ Provide guidance to the Army DERP Executor concerning all interpretations of statutes and regulations that may effect performance of a task; obtain concurrence from the USAEC on any deviations from DoD or Army 

policy and guidance; and document deviations from policy. 

¡ Coordinate with the Army DERP Executor to resolve any impediment to 

task completion on or before the stated deadline and at or below the stated 

costs. Notify the USAEC of any penalty and associated costs incurred by 

the Army DERP Executor’s failure to meet a deadline. 

¡ Provide copies of project documents for review and comment through the 

USAEC ERM to appropriate Army DERP proponents such as the 

USACHPPM and ATSDR (when appropriate). 

¡ Provide copies of all RODs/DDs for review and concurrence to the 

USAEC and the USACHPPM and obtain appropriate Army approval signatures before release of funds for removal/interim/remedial action contracts. 

¡ Evaluate the DERP executor's ability to meet schedules, communicate 

with the installation staff, provide quality reports, and effectively use 

available funding resources. If the DERP executor's performance is unsatisfactory, notify the Garrison Commander or other designated authority 
Program Execution 

 5-3 

who will contact the commander of the executing agency and attempt to 

resolve the issues. Ensure procurement processes to document performance are followed. If the quality of performance by the DERP executor 

continues to be unsatisfactory, the Garrison Commander or other designated authority, in concurrence with the USAEC, may transfer execution 

to another performer. Appropriate notifications shall be made to the 

DERP executor and the USAEC so that funds can be recovered and redirected to the new performer.

5.2 ARMY DERP EXECUTOR

With the Army-wide implementation of PBC, execution strategies may vary 

greatly from those historically used in the Army DERP. 

The USACE has established Hazardous, Toxic and Radiological Waste (HTRW) 

Design Districts for executing environmental cleanup activities and Military Munitions Center of Expertise (MM CX) for executing MMRP category responses. 

The USACE District Project Manager coordinates the support of the Design Districts and Centers and oversees contracts to private industry. Each Design District 

and Center works within specific geographic boundaries. The Director of Military Programs at HQ USACE may grant approval for an installation to use a 

USACE District outside of its assigned geographic area. 

Installations may also execute Army DERP projects themselves or contract directly with private industry to have the projects executed. The USACHPPM is 

available to execute specific projects under the Army DERP such as specialized 

risk assessment and initial site assessment projects--particularly PAs, SIs, and 

RRSE assessments. 

Use of government agencies outside of the Army to execute the Army DERP is 

discouraged except under unusual circumstances. Economy Act procedures must 

be followed in those cases. Installations should contact their resource management and legal offices concerning Economy Act procedures. 

Through a Memorandum of Understanding (MOU) with the DoD, the ATSDR, a 

non-DoD federal agency, performs public health assessments for installations on 

or proposed for the NPL and is authorized to perform Public Health Consultations 

as requested by any installation. Procedures to request ATSDR assistance can be 

found in Section 6.3. 

 

The Army DERP Executor duties are as follows: 

¡ Assign a primary point of contact(e.g., USACE District project manager) 

for the installation RPM. The primary point of contact coordinates execut-
 5-4 

ing organization support to installation requests for contracting services 

for specific tasks or projects. 

¡ Provide estimates of costs and time requirements for performance of specific tasks forwarded by the installation RPM, including in-house costs, 

specific contract and pricing data, and costs charged for contract administrative services applicable to each FY for the contract administration; 

compare historical cost data from analytical laboratories to ensure the 

DERP Executor can negotiate the lowest available price; and plan laboratory analyses to minimize higher cost turnaround time requirements. 

¡ Propose schedules for all deliverables and accomplishes all tasks within 

time deadlines set forth by the installation RPM. (Tasks will not be considered complete until reviews are prepared for all work performed and 

accepted by the installation RPM.) 

¡ Recognize the installation RPM as the sole contact with all environmental 

regulators; report any contacts by regulators to the installation RPM; and 

attend all meetings as requested by the installation RPM. 

¡ Request specific approval from the installation RPM before release for 

publication of any information gathered. Withhold any IRP information 

not approved for release by the installation RPM. 

¡ Use existing contracts before initiating new contracts for environmental 

work.

5.3 U.S. ARMY ENVIRONMENTAL CENTER 

(USAEC) 

The USAEC is a FOA to the ASCIM under the direction of the Director of Environmental Programs (DEP). As the program manager for the Army DERP, the 

USAEC provides a broad range of program management and oversight services in 

support of the DEP and installations. 

The USAEC conducts the HQDA-initiated independent technical review (ITR) 

and assistance programs (see Section 6.5). The USAEC compiles teams of independent technical experts that review specific remediation projects for installations and provide recommendations concerning the technical feasibility of 

restoration projects. 

The USAEC also oversees all restoration activities at Army installations. The 

USAEC provides technical assistance with AEDB-R updates for IRP category 

sites, revisions to the IAPs, CTC updates for IRP category sites, guidance in the 

overall Army DERP process and performs the CTC and AEDB-R updates for 
Program Execution 

 5-5 

MMRP category sites. The IAPs, in conjunction with the installation Army 

DERP Obligation Plan, are used by USAEC to track the progress of the Army 

DERP at each installation. The USAEC supports business initiatives of HQDA 

with site review, technical evaluation, and PBC initiatives. 

The USAEC ERMs coordinate with installations before any site visits and notify 

the installation of any issues that arise from the site visit. As necessary, Army 

DERP project documents should be provided to the USAEC ERM. The USAEC 

will submit copies of completed documents to the Army’s Technical Information 

Center, the centralized library of all Army environmental documents, located at 

the USAEC at Aberdeen Proving Ground, Maryland. 

To obtain USAEC ERM POC information for a specific installation, contact 

USAEC’s Cleanup Division at DSN 584-3461 or commercial (410) 436-3461 

5.4 USAEC ENVIRONMENTAL RESTORATION 

MANAGER (ERM) 

The USAEC ERMs are responsible for the technical direction and oversight of the 

Army DERP for installations assigned to them. The USAEC ERMs provide quality assurance on the data provided by installations for use in reporting Army requirements. All requirements must meet Army criteria for eligibility and must 

have RRSEs/RACs completed in accordance with current Army guidance. Administrative requirements are directed through the USAEC Program Coordinator 

to the installation. 

In the case of the NGB, the NGB may act as the installation and becomes responsible for all environmental reporting. 

USAEC ERM duties include: 

¡ Work as closely as possible with installation team but maintain Army perspective and objectivity. 

¡ Assess program viability; ensure schedules, cost and approach are consistent and reasonable; ensure program planning includes closeout focus and 

strategy. 

¡ Identify possible roadblocks to progress and work with the installation to 

overcome those roadblocks. Enlist the resources necessary to get programs on track. 

 Review Technical Documents (RI/FS & RFI/CMS documents): 
 5-6 

h Coordinate reviews, including Groundwater Extraction and Treatment 

Effectiveness Review (GWETER), with USACHPPM/USAEC technical support. 

h Ensure Data Quality Objectives are identified, i.e., make sure studies 

have a purpose. 

h Ensure plans detail an acceptable technical approach. 

h Ensure plans support decision points. 

 Review Proposed Plans, DDs, and RODs: 

h Work with installation on Army position at the RI/FS stage 

h Ensure proposed plans and DDs reflect Army position.

h Coordinate USACHPPM and Legal input and review.

¡ Perform quality assurance checks on program management data and coordinate corrections with the installations. 

¡ Identify opportunities where use of PBC will enable more efficient use of 

funds and/or site closeout. 

¡ Monitor obligation performance against installation obligation plans and 

work with the installations to expedite actions.

5.5 U.S. ARMY TECHNICAL CENTER FOR 

EXPLOSIVE SAFETY (USATCES) 

The USATCES reviews and approves all Explosive Safety Submissions (ESS), 

Chemical Safety Submissions and/or explosive or CWM site plans for consistency 

with DoD Explosives Safety Standards (DoDD 6055.9-STD) and with DoD and 

Army explosives safety policies. USATCES also reviews the explosives safety 

provisions (e.g., land use controls or explosive safety-related notices) of transfer 

documents (e.g., leases, deeds, findings of suitability for transfer) for property 

known or suspected to contain MEC or residual explosive hazards that, per DoDD 

6055.9-STD, must be submitted to the DDESB for review and approval prior to 

the transfer. 

The ESS and explosive site plan are critical documents for munitions responses to 

MEC. A DDESB-approved approved ESS is required prior to implementation of 
Program Execution 

 5-7 

the agreed upon munitions response to MEC. The purpose of the ESS is to ensure 

that all applicable DoD and DA explosive safety standards are applied during a 

munitions response. 

5.6 U.S. ARMY CENTER FOR HEALTH 

PROMOTION AND PREVENTIVE MEDICINE 

(USACHPPM) 

The USACHPPM will provide medical and health-related oversight of restoration 

activities. These activities include the preparation of Public Health Assessments, 

health consultations, health studies, responses to citizens’ petitions and health 

education activities. The Center reviews and concurs on human health risk assessments and RODs/DDs for the Army Surgeon General and reviews ecological 

risk assessments. 

5.7 BRAC Division and BRAC Field Offices 

The BRAC Division and its designated F have responsibility for managing DERP 

cleanups at non-BRAC excess installations. They work closely with USAEC to 

identify and prioritize Army DERP activities and to facilitate property transfer. 

6-1 

Chapter 6 

Program Procedures 

The Army DERP was implemented to address the Army’s cleanup responsibilities 

consistent with CERCLA/SARA, the NCP and as applicable, RCRA corrective 

action requirements. This section provides additional details on several program 

procedures required under the Army DERP. 

6.1 DECISION DOCUMENTS (DD) 

The term “Decision Document” encompasses Records of Decision and Action 

Memoranda remedies and removals, and Statements of Basis for RCRA corrective actions. Installations will maintain all DDs in the installation Administrative 

Record and their permanent environmental files and provide copies to USAEC. 

6.1.1 CERCLA Remedial Records of Decision (ROD)/DDs 

Under the CERCLA/NCP Remedial Action process at both NPL and non-NPL 

sites, a remedy must be selected and documented in a ROD or DD following receipt of the Proposed Plan, public comments, and consultation with the regulators. 

The ROD or DD serves as certification that the Army selected the remedy pursuant to CERCLA Section 104 and following the process in CERCLA Section 120 

and the NCP Section 300.430. All RODs must explain how the NCP’s nine 

evaluation criteria1 were used to select a remedy.2 All facts, analyses of facts, and 

site-specific policy determinations considered in implementing a remedy should 

be documented in a ROD in an appropriate level of detail.3 A ROD describes the 

site and types of contamination at issue, outlining the risks being addressed. The 

Feasibility Study alternatives are summarized with a discussion of why the selected alternative was chosen. A ROD explains why the remedy is protective of 

human health and the environment and how it attains the applicable or relevant 

and appropriate requirements (ARARs) of other selected federal and state laws.4 

There should also be a description of how the technical aspects of the remedy will 

 1

 The nine NCP criteria are: overall protection of human health and the environment; compliance with applicable or relevant and appropriate requirements; long-term effectiveness and permanence; reduction of toxicity, mobility, or volume through treatment; short-term effectiveness; 

implementability; cost; state acceptance; and community acceptance. These criteria and a brief 

explanation of their scope can be found in 40 Code of Federal Regulations 300.430(e)(9) and 

(f)(1). These criteria are based on the requirements in CERCLA section 121 (42 U.S.C. 9621). 

For a further explanation of the 9 NCP criteria, see 55 Federal Register at 8719 (March 8,1990). 2

 40 CFR 300.430(f)(5)(i). 

3

 40 CFR 300.430(f)(5)(i). See also 55 FR at 8731 (March 8,1990), for a general description 

concerning decision documentation. 4

 40 CFR 300.430(f)(ii)(A) and (B). 
6-2 

address the specific site contaminants and whether five-year reviews are needed.5

 

A ROD should also show how the remedy is cost-effective proportional to its protectiveness.6

 

A ROD should contain the following nine parts: 

1. Site Conditions and Background 

2. Current and Potential Future Land/Water Use 

3. Site Risks 

4. Remedial Action Objectives7 

5. Description and Comparative Analysis of Alternatives8

6. Description, Cost and Outcome of Selected Remedy 

7. Statutory Determinations (ARARs & Periodic Review)9

8. Responsiveness Summary (i.e., summary of responses/significant comments)10

9. Declaration of Remedy & Signature 

Pursuant to NCP §300.430 (f)(6), after the Army signs the ROD, the Army must: 

¡ Publish a notice of the availability of the ROD in a major local newspaper 

of general circulation (the USEPA) will publish the notice in the Federal 

Register). 

¡ Make the ROD available for public inspection and copying at the information repositories located on or near the facility before the commencement 

of any remedial action.

Per CERCLA §120 (e)(2), the remedial action must commence within 15 months 

of signing the ROD. 

A signed ROD may be re-evaluated, if appropriate, at any point during the remedial action process (i.e., during remedial design, before or after operations are in 

place, when the selected remedy is found to be ineffective, more stringent cleanup 

standards are promulgated, or if recently developed technology may better meet 

cleanup goals). If, after re-evaluation, the selected remedy significantly changes, 

the Army will prepare an explanation of significant differences (ESD).11 The 5

 40 CFR 300.430(f)(5)(ii)(E) and 300.430(f)(iii)(C). 

6

 40 CFR 300.430(f)(5)(ii)(D). 

7

 40 CFR 300.430(f)(5)(iii)(A). 8

 40 CFR 300.430(f)(5)(ii). 

9

 40 CFR 300.430(f)(5)(ii) identifies the statutory requirements of CERCLA section 121 (42 

U.S.C. 9621). 10 40 CFR 300.430(f)(5)(iii)(B). See also U.S. EPA, Solid Waste and Emergency Response, 

Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection 

Decision Documents, EPA540-R-98-031 (July 1999). 11 40 C.F.R. § 300.435(c)(2)(i). 
Program Procedures 

6-3 

ESD would be coordinated with the appropriate regulators and provided to the 

public for review.12 For fundamental remedy changes, the Army will have to 

modify or amend the ROD before the changes can be implemented (see Section 

6.1.4). 

6.1.2 Removal Action Memoranda/DD 

An Action Memorandum serves as the primary decision document substantiating 

the need for a removal response, identifying the proposed action, and explaining 

the rationale for the removal.13 There are, however, three types of removal actions: emergency, time-critical, and non-time critical. While the NCP does not 

explicitly categorize Removal Actions into these categories, USEPA uses these 

terms in implementation guidance.14 In emergency or time-critical situations, it 

may be necessary to initiate action prior to the preparation of an Action Memorandum.15 Thus, documentation consistent with this guidance to the extent practicable may occur after the removal action for emergency or time critical removals. 

For non-time critical removals, or where time permits prior to time-critical removals, the Action Memorandum should contain the following six parts: 

1. Purpose 

2. Site Conditions and Background 

3. Threats to Public Health or Welfare or the Environment 

4. Proposed Action(s) and Estimated Cost (including identified ARARs) 

5. Recommendation 

6. Signature 

The Site Conditions and Background should include a site description and other 

actions to date. The NCP at 40 CFR 300.415(b) requires a determination that 

there is a threat to public health or welfare or the environment based on eight factors.16 Thus, the Action Memorandum documents why removal (as opposed to 

 12 40 C.F.R. §§ 300.435(c)(2)(i)(A), (B)(ii). 

13 See OSWER Dir. 9360.3-01, Superfund Removal Procedures Action Memorandum Guidance (Dec. 1990). 14 For example, EPA Publication 9360.0-32, Guidance on Conducting Non-Time-Critical Remedial Actions Under CERCLA, 1993, states that: EPA has categorized removal actions in three 

ways: emergency, time-critical, and non-time critical, based on the type of situation, the urgency 

and threat of the release or potential release, and the subsequent time frame in which the action 

must be initiated. Emergency and time-critical removal actions respond to releases requiring action within 6 months. Non-time-critical removal actions respond to releases requiring action that 

can start later than 6 months after the determination that a response is necessary. 15 See OSWER Dir. 9360.3-01, Superfund Removal Procedures Action Memorandum Guidance, at page 5 (Dec 1990). 

16 The eight factors are: 

(i) Actual or potential exposure to nearby human populations, animals, or the food chain from 

hazardous substances or pollutants or contaminants 

(ii) Actual or potential contamination of drinking water supplies or sensitive ecosystems; 
6-4 

remedial) action is appropriate.17 The Action Memorandum also describes the 

proposed action and estimated costs, including how the removal action, to the extent practicable, contributes to the efficient performance of any anticipated longterm remedial action (NCP at 40 CFR 300.415(c)). This section also discusses 

ARARs, which are to be attained to the extent practicable considering the exigencies of the situation. Non-time critical removals should also refer to the Engineering Evaluation/Cost Analysis (EE/CA) and discuss the alternative actions 

considered. 

6.1.3 Corrective Action Statements of Basis (SB)/DD 

A Statement of Basis or similar state designated document serves as the primary 

DD substantiating the need for a RCRA corrective remedial action with evaluation of the proposed remedy and other alternatives based on risk-based selection 

criteria. The regulator should prepare a SB when corrective action is implemented 

through either a permit or an enforcement order18. A SB is a remedial selection 

document similar in purpose to a CERCLA ROD. Because the SB is issued by a 

regulator, a Corrective Measures Study can serve as the DD for Army staffing 

purposes. 19

Although state specific requirements may vary somewhat, a DD/SB should contain the following seven parts: 

 1. Purpose 

2. Site Risk and Background 

 

(iii) Hazardous substances or pollutants or contaminants in drums, barrels, tanks, or other 

bulk storage containers, that may pose a threat of release; 

(iv) High levels of hazardous substances or pollutants or contaminants in soils largely at or 

near the surface, that may migrate; 

(v) Weather conditions that may cause hazardous substances or pollutants or contaminants to 

migrate or be released 

(vi) Threat of fire or explosion; 

(vii) The availability of other appropriate federal or state response mechanisms to respond to 

the release, and 

(viii) Other situations or factors that may pose threats to public health or welfare or the environment. 17 See U.S. EPA, Office of Enforcement and Compliance Assurance, Use of Non-TimeCritical Removal Authority in Superfund Response Action, February 14, 2000. 18 See OSWER Dir 9902.6, Guidance of RCRA Corrective Action Decision Documents: The 

Statement of Basis Final Decision and Response to Comments, (Feb 1991). Note that remedy 

selection and/or site closeout status should eventually be identified in the permit provisions concerning RCRA corrective action or if a corrective action order is updated. 

19 If a Corrective Measures Study(CMS) is used as the Decision Document for Army staffing 

purposes, the SB does not need to be restaffed unless there are significant differences between the 

CMS and the SB. 
Program Procedures 

6-5 

 3. Proposed Remedy and Scope of Corrective Action 

 4. Summary of Alternatives 

 5. Evaluation of the Proposed Remedy and Alternatives 

 6. Public Participation if a RAB exists or permit conditions require 

 7. Declaration and Signature 

The Site Risk and Background should include a site description of the contaminated media, the contaminants of concern, exposure pathways, the potential exposed population, and the level of risk to human health and the environment. The 

EPA’s guidance on corrective action established a two-phased evaluation for remedy selection sufficient to meet first threshold then balancing criteria in order to 

identify the remedy that provides the best relative combination of attributes. A 

DD/SB should also describe how the scope of the proposed remedy fits into the 

overall IRP strategy and effectively balances treatment with exposure control for 

reasonably anticipated reuse.20

6.1.4 DD STAFFING AND APPROVAL PROCEDURES 

The review and approval procedures for DDs are contained in the DASA(ESOH) 

Memorandum, 7 Aug 2003, subject: Policies for Staffing and Approving Decision 

Documents (Appendix G). 

6.2 NON-SIGNIFICANT (OR MINOR) POST-ROD CHANGES:

MEMO TO THE SITE FILE. ANY NON-SIGNIFICANT OR 

RECORDS MANAGEMENT

Installations must collect and retain environmental restoration records in accordance with all applicable statutes and regulations, and the record must meet 

USEPA guidelines. Environmental restoration records will be collected as they 

are generated or received in the course of the decision-making process. 

6.2.1 Administrative Record 

 20 See for use as guidance U.S. EPA Proposed Rule for Corrective Action for Releases from 

Solid Waste Management Units at Hazardous Waste Management Facilities, 61 Federal Register 

19431. (May 1, 1996). Threshold criteria: Remedies must (1) be protective of human health and 

the environment; (2) attain media cleanup standards; (3) control the source(s) of releases so as to 

reduce or eliminate, to the extent practicable, further releases of hazardous waste that might pose 

threats to human health and the environment ; and (4) comply with applicable standards for waste 

management. Balancing criteria: For choosing among alternatives that meet the threshold criteria: 

(1) long-term reliability and effectiveness; (2) reduction of toxicity, mobility, or volume of wastes; 

(3) short-term effectiveness, (4) implementability, and (5) cost. 
6-6 

Installations shall establish an Administrative Record that contains the documents 

that form the basis for the selection of IRP and MMRP response actions. The installation shall compile and maintain the Administrative Record in accordance 

with CERCLA and 40 CFR §300, Subpart I and USEPA guidance. 

The Administrative Record serves two purposes. First, the Administrative Record 

acts as a vehicle for public participation in selecting a response action. Second, 

judicial review of any issue concerning the adequacy of any response action is 

limited to the contents of the Administrative Record. Under this provision of 

CERCLA, the Administrative Record is the sole source of documentation that can 

be used by a party challenging a response action. It is also the sole source of 

documents available for the defense of a response action by an installation. It is 

critical that the installation take care in compiling the Administrative Record. If 

the installation fails to compile a complete and accurate Administrative Record, it 

may significantly impact DoD’s ability to defend, and the court’s ability to review, a challenged decision. A permanent record of the data gathered to characterize a site and a clear audit trail of pertinent data analysis and resulting decisions 

and actions are required. 

The Administrative Record shall include, but is not limited to including: 

¡ Documents and materials containing information that may form a basis for 

the Army’s selection of a response action. 

¡ Documents and materials available to the installation at the time the decision was made. 

¡ Documents and materials that were considered by or relied upon by the installation for decision making. 

¡ Documents and materials that were available to the installation at the time 

of a decision, even if the decision maker did not specifically consider 

those documents. 

¡ Privileged and non-privileged confidential documents and materials. 

¡ Documents received, published, or made available to the public as required by CERCLA for removal or remedial site assessments or actions.

6.2.2 Military Munitions Response Program (MMRP) Documentation 

For MMRP category responses, installations shall have a permanent record of the 

data gathered to characterize a site and a clear audit trail of pertinent data analysis 

and resulting decisions and actions. To the maximum extent practicable, the permanent record shall include sensor data that is digitally recorded and georeferenced. The ACSIM shall approve exceptions where digitally recording and 
Program Procedures 

6-7 

geo-referencing are impractical. These data shall be included in the Administrative Record.

6.2.3 Environmental Restoration Information System (ERIS) 

Documentation 

The ACSIM has established an Army policy that requires the storage of environmental restoration data in a centralized database. The ERIS was developed for 

this purpose and has replaced the outdated Installation Restoration Data Management Information System. All installations that have received ER,A funds to collect environmental restoration data must enter that data into ERIS and must 

modify existing laboratory contracts to meet this requirement. 

See the 17 February 1999 memorandum from the ACSIM, subject: Policy on Electronic 

Storage of Environmental Restoration Data. See the 12 November 2003 memorandum from 

the ACSIM, subject: Implementation Guidance for the Use of the ERIS.

6.3 PUBLIC HEALTH REQUIREMENTS 

A Public Health Assessment (conducted by ATSDR) is required when an installation is proposed for the NPL or is the subject of a citizen’s petition. Upon proposal for the NPL, the installation is contacted by the USACHPPM. The Center 

instructs the installation on the requirements for a Public Health Assessment, the 

role of the ATSDR, and negotiates a schedule for an initial ATSDR site visit 

within 18 months of proposal to the NPL. The USACHPPM provides installations with a schedule for site visits and documents delivery by quarter. 

6.4 OFF-SITE RESPONSE ACTION 

To fulfill its CERCLA responsibilities per EO 12580, the Army has the authority 

to conduct response actions outside of the installation boundaries, where the installation is reasonably considered to be the sole or the major source of the 

CERCLA release. Off-site actions can be complex and often require extensive 

coordination because of the lack of Army control over the off-site property and 

the necessity for increased interaction with the public. 

For DOD, only, Explosive Ordnance Disposal (EOD) have execution authority for 

explosives or munitions emergency response actions to control, mitigate, or 

eliminate the actual or potential threat encountered during an explosives or munitions emergency. 

AR 200-1 states that the DASA (ESOH) will approve all off-site response actions. 

However, since the February 1997 publication of AR 200-1, the DASA (ESOH) 

has designated authority to the Garrison Commander to approve off-site data collection to determine contamination migration and any off-post monitoring to en-
6-8 

sure that contamination has not migrated off-site. If there is an actual or high potential threat to human health or safety on or off the installation, the DASA 

(ESOH) will be immediately notified by the Garrison Commander through 

USAEC and ODEP. The DASA (ESOH) approves off-post response actions to 

include either starting or stopping the provision of bottled water, alternative water 

supplies, wellhead treatment devices, or connection to a municipal water system. 

The installation must provide a response plan through the command chain (with 

information directly to USAEC) to the DASA (ESOH) for any off-site response 

actions. In emergencies, this plan may be after the fact of receiving verbal or 

electronic approval from the DASA(ESOH) to respond. 

Requirements for notification procedures and the response plan can be obtained from DA 

PAM 200, Section 11-14. Available on the Internet at http://usapa.army.mil/gils

6.5 TECHNICAL REVIEW AND ASSISTANCE

As a function of program management, the USAEC is responsible for ensuring 

that the cleanup program is conducted as effectively and efficiently as possible. 

To that end, the USAEC has established within its Cleanup Division a Technical 

Review and Assistance Branch to provide both technical review of installation 

actions and technical assistance in developing sound technical approaches to 

cleanup problems. The Independent Technical Review (ITR) was the initial project-level technical and legal review and assistance mechanism. This mechanism 

has been replaced by several initiatives that support the cleanup program. 

6.5.1 Site-Specific Technical Assistance 

Site-Specific Technical Assistance is useful in the development of investigative 

and cleanup plans. The overall objective of Site-Specific Technical Assistance is 

to meet the Army’s obligation to protect human health and the environment while 

ensuring that planned response actions are cost-effective. The Site-Specific 

Technical Assistance process provides access to top environmental experts from a 

variety of environmental disciplines. The assistance group reviews specific projects to determine whether the investigative approach, proposed actions, proposed 

monitoring plans, and exit strategies are technically and legally sound. The assistance is intended to improve decision-making and to support technically and legally sound initiatives. Site-specific technical assistance is adaptive and flexible 

to meet the needs of the Army. 

6.5.2 Groundwater Extraction and Treatment Effectiveness Review 

(GWETER) Program 

The GWETER program focuses specifically on assessing the effectiveness of existing groundwater treatment systems. The primary purpose of these reviews is to 

determine whether there are more cost-effective alternatives to pump and treat 
Program Procedures 

6-9 

that were not considered during initial remedy selection. These reviews use technical experts from the government and regulatory agencies to ensure that existing 

systems have performance goals that define when cleanup is completed and systems can be shut down. In addition, these goals are to be used to ensure that the 

systems are capable of meeting these goals in a reasonable period and that there 

are not new technologies that can meet these goals in a more cost effective manner. For example, protocols for determining the effectiveness of natural attenuation have matured and the use of natural attenuation in conjunction with a pump 

and treat system can be very cost effective. The GWETER examines the basis for 

risk management decisions and cost effective cleanup by analyzing all aspects of 

the groundwater exposure pathway. Secondarily, GWETER looks at pump and 

treat systems still in the proposed stage to ensure that all alternatives to pump and 

treat are being considered. 

6.5.3 Principles of Environmental Restoration (PER) Workshop 

A number of general ITR recommendations have been quite common among a 

large percentage of installation projects reviewed. To address these recurring recommendations and lessons learned, an additional mechanism was developed to 

provide environmental restoration assistance to the Army: The Principles of Environmental Restoration (PER) workshop. The USAEC adopted the PER to provide more streamlined and direct assistance to Army installations on specific 

issues, especially decision-based planning. This initiative is the result of an effort 

to capitalize on a training program developed jointly by the Department of Energy 

(DOE) and the USEPA to improve the DOE cleanup program. 

The purpose of the PER workshop is to provide tools and approaches that will 

help decision-makers collect appropriate investigative information and proceed 

more quickly to acceptable site closeout. The workshop stresses the need for 

early planning and development of data quality objectives and early development 

of exit criteria to ensure investigations and cleanups stay on track. The workshop 

is intended to: 

¡ Provide sufficient understanding of environmental restoration principles to 

ensure that proposed investigative and cleanup requirements are needed to 

support risk-based decisions and actions. 

¡ Improve the process within which the installation project teams operate to 

better focus on the end objectives of the restoration program. 

Central to the PER workshop are four key principles of environmental restoration. 

These principles are: 

¡ Building an effective project management team. 

¡ Clear, concise, and accurate problem identification. 
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¡ Early identification of possible response actions. 

¡ Uncertainties are inherent and will always need to be managed. 

The workshop addresses the applicability of these principles across the spectrum of restoration efforts – from site investigation planning through site 

closeout – and how they can be used to improve the decision-making process 

at most sites. 

6.5.4 Performance-Based Contracting (PBC) 

The PBC is a concept based on reforms mandated to all federal agencies by the 

President’s Management Agenda, the Government Performance and Results Act 

of 1993, and the Federal Acquisition Streamlining Act of 1994. These reforms 

emphasized the need to maximize the focus on results instead of focusing on the 

process. Using this approach, the government no longer develops a prescriptive 

statement of work dictating how the contractor will achieve project milestones. 

Instead, a performance-based approach to environmental cleanup emphasizes the 

outputs the contractor will produce (e.g., RC, RIP) but does not specify how to 

produce those outputs. This approach allows private remediation firms the flexibility to conduct environmental cleanups in a manner that is cost effective for 

their company while ensuring that legal requirements are met and required milestones are achieved. 

The PBC approach allows the Army to buy environmental cleanups for a fixed 

price and at a set schedule. Regulatory agencies should have the same level of 

involvement as they do under traditional cleanup contracting approaches. The 

Army maintains oversight of the cleanup and determines upfront (in consultation 

with the regulators) the desired outcome (typically regulatory closure) that will be 

achieved. In guaranteed fixed price remediation contracts, the use of environmental insurance offers the Army protection from environmental liabilities. 

For the Army’s active installations, the USAEC is playing a key role in establishing a formalized PBC program and identifying PBC candidates. 

The PBC process involves three phases: 

¡ Technical evaluation and selection of candidate sites, including final determination of appropriateness of pursuing a PBC. 

¡ Initiation of the procurement process: 

- Preparation of a Performance Work Statement. 

- Development of the Independent Government Cost Estimate 

(IGCE). 
Program Procedures 

6-11 

- Development of the Request for Proposal by the contracting organization. 

- Scoping/Bidders Meeting at the installation to initiate the proposal 

process. 

- Evaluation of the proposals, negotiation, and award/non-award decision. 

¡ Contract oversight and deliverables. 

Not all remediation efforts are candidates for PBC. Restoration efforts where 

characterization data are not validated or incomplete or where regulatory closure 

is not easily defined are not good candidates for this approach because of the high 

risk due to uncertainty. As the level of uncertainty increases, so does the possibility that high-risk projects may not be good candidates for the necessary environmental insurance. However, bidders that are willing to take on more risk at a 

lower cost are more likely to win PBCs. 

Monetary incentives may be included in a PBC in an effort to encourage a contractor to achieve regulatory closure on a particular site in an expedited manner. 

This approach can assist the Army in reducing out-year LTM and O&M costs. 

Award of a PBC is not automatic, nor is the award guaranteed to incumbent contractors at the installation. Candidate bidders must have completed elements of 

their current work that impinge on the scope of the RFP. During scope development, the Army team attempts to reduce the amount of uncertainty present in order to ensure a sufficient pool of qualified bidders. 

Prior to entering into final negotiations with the bidders, the Army develops a negotiation strategy to identify a “walk away” point, which is essentially the agreedupon point at which the PBC will not be awarded should bids exceed the IGCE 

and negotiations fail to close the gap to the Army’s satisfaction. 

For detailed information on PBC, visit the USAEC website at aec.army.mil. For other Technical 

Review and Assistance information, contact USAEC’s Cleanup Division at 410-436-5793/1522 or 

DSN 584-5793/1522. 

6.6 INTERAGENCY AGREEMENT (IAG)/FEDERAL 

FACILITY AGREEMENT (FFA) 

Upon an installation’s nomination to the NPL, the installation, the USEPA, and , 

if the State requests, appropriate state regulatory agencies enter into an IAG/FFA 

to complete of all necessary remedial actions at the installation. The Garrison 

Commander and the DASA (ESOH) will both sign the IAG/FFA for the Army. 
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In order to maintain consistency throughout DoD, DoD and USEPA developed 

the 1988 USEPA-DoD FFA model language, with edits for state participation 

dated 17 March 1989, and the most recent revision of 10 February 1999. This 

model language forms the basis for all FFA negotiations. The FFA model language was not intended to cover all issues that would be included in an FFA, and 

installations may negotiate additional, necessary provisions on a site-by-site basis 

that do not conflict with the FFA model language. Such additional provisions do 

not become part of the model language, nor are they binding precedent for other 

FFAs for that or any other DoD installation.

The ODUSD must approve deviations to the model language. The concepts of 

“flexible” schedules, funding constraints, and relative risk must be incorporated 

into IAGs/FFAs. DoD and Army strongly support the approach of incorporating 

more flexible schedules into supporting agreements among FFA parties. 

To the extent that an installation negotiates provisions that deviate from the FFA 

model language in a proposed FFA, that installation will specifically identify each 

such change and its rationale when submitting the proposed FFA for ODUSD review. In addition, the installation will identify and provide rationale to reviewers 

for any other significant provision in the draft FFA that would qualify or limit any 

FFA model provision, as well as novel additions to the model language. 

The installation’s servicing legal office has the lead in IAG/FFA negotiations; 

however, the legal chain of command may designate another lead should the installation request assistance. The USAEC counsel and OTJAG will provide assistance during the negotiation process. When the IAG/FFA is sent to DASA 

(ESOH) through the command chain for signature, the ACSIM requests concurrence from the OTJAG and USAEC. The installation should provide USAEC 

with copies of the draft IAG/FFA for review and concurrence prior to sending the 

IAG/FFA to DASA (ESOH) for signature. 

See 10 May 2000 Memorandum from the DUSD(ES), subject: Federal Facility Agreement – 

Deadlines and Funding Model Language for the latest guidance on FFA model Language. 

See 6 December 2000 Memorandum from the DUSD(ES), subject: Federal Facility Agreement Model Language-Policy on Deviations for the latest policy update at 

http://aec.army.mil/usaec/cleanup/popup/library/index.html. 

6.7 REGULATORY PARTICIPATION

The Army works cooperatively with regulatory agencies so that restoration goals 

can be accomplished cost effectively, in accordance with applicable laws and 

regulations. To accomplish this, Army installations should identify points of contact in regulatory agencies, determine communication channels, and establish cooperative relationships. Installations should provide regulators with ready access 
Program Procedures 

6-13 

to program information, including draft data and documents, and establish procedures for obtaining pertinent information from regulators on a timely basis. 

Installations must involve regulatory agencies in: 

¡ RRSEs and RAC scoring results. 

¡ Project planning, budgeting, and implementation (including IAPs). 

¡ Workplan development and site and project prioritization. 

¡ Development of the Conceptual Site Model and sampling and analysis 

plans and updates. 

¡ RC and Site Closeout determinations. 

¡ RABs and other community involvement initiatives.

The lead regulatory agency is dependent upon the status of the installation. If the 

installation is on the NPL the U.S.EPA is the lead regulator. Otherwise, the state 

is the lead regulator. 

6.8 PUBLIC PARTICIPATION AND COMMUNITY 

INVOLVEMENT

Local communities are interested in the results of environmental studies conducted under the Army DERP because of the potential impact on their health, environment, and economic well-being. The Army fully supports public 

involvement programs that require the Army to solicit and consider the advice 

from the interested individuals, groups, and government bodies before selecting 

response alternatives. 

Installations should consult with stakeholders throughout the planning and execution process. Consultation involves providing information and seeking feedback/input before decisions are made. Although there is public involvement, the 

Army retains final decision authority at non-NPL installations as lead agency. 

Consultation should begin in the program formulation phase, and continue to site 

closeout. Installations should re-initiate consultation if the remedy changes significantly. The extent of consultation may vary over the life of the program and 

should be commensurate with the level of restoration activity and stakeholder/community interest. The RAB, where one exists, comprised of representatives of the installation, regulatory agencies and the local community, shall be the 

primary forum for consultation. Installations that do not have a RAB must ensure 

a viable pathway of communication exists with the local community. 

When changes to the remedial program become necessary, installations will consult with stakeholders, to the extent possible, before final decisions are made. 
6-14 

This could be in the form of activities such as public meetings, public information 

sessions, newsletters, and press releases. 

6.8.1 Community Relations Plan (CRP) 

A CRP is required for all Army installations in the Army DERP. The CRP provides the guidelines and “roadmap” for future community relation activities associated with installation cleanup. 

CRP guidelines and related information are available on the Internet at 

http://www.denix.osd.mil/denix/Public/Library/Planning/html. 

6.8.2 Environmental Justice 

An Executive Order (EO) requires federal agencies to identify and address disproportionately high and adverse human health and environmental effects of federal programs, policies, and activities on minority and low-income populations. 

Army addresses and considers environmental justice concerns and issues in its 

restoration programs. Environmental justice issues within a community will be 

identified while developing an installation’s CRP. The primary source of input 

for environmental justice issues in a specific community should be the RAB, 

where one exists. 

See EO 12898, Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations, the DoD Strategy on Environmental Justice, and 

related information on the Internet at 

http://www.denix.osd.mil/denix/Public/Library/Planning/Justice/note7.html. 

6.8.3 Technical Review Committee (TRC) 

Per 10 USC §2705(c), a TRC is established to review and comment on the 

Army’s actions with respect to releases or threatened releases of hazardous substances at installations. TRC meetings serve as working sessions for exchanging 

information and organizational viewpoints. Members of a TRC include at least 

one representative from the Army; appropriate EPA, state and local authorities; 

and representatives from surrounding communities. The Garrison Commander is 

responsible for establishing and chairing or designating an installation/Army 

chairperson for the TRC. 

6.8.4 Restoration Advisory Board (RAB) 
Program Procedures 

6-15 

To facilitate public involvement, the Army encourages the establishment of 

RABs. The RABs are a forum between governmental decision-makers and the 

affected local community providing the opportunity for meaningful community 

input to the decision-making process including project prioritization. RABs meet 

the requirement for TRCs in 10 USC §2705. Every installation participating in 

the Army DERP, to include MMRP projects, must determine community interest 

in establishing and participating in a RAB. The TRCs should, as appropriate, be 

converted to RABs at installations where at least one of the following criteria are 

met: 

¡ Federal, state, or local government agencies formally request that a RAB 

be formed; 

¡ At least 50 local residents sign a petition requesting that a RAB be 

formed; 

¡ The Garrison Commander determines that a RAB is needed; or 

¡ Installation closure involves transfer of property to the community. 

The installation must keep the TRC/RAB appraised of program funding status and 

possible impact of any cuts prior to and during program execution. The installation should, at a minimum, provide the TRC/RAB with copies of the IAP and if 

appropriate have the TRC/RAB participate in the annual update of the IAP. Project work plans should also be provided to the TRC/RAB to ensure they are 

knowledgeable of the plans, including any changes. 

The TRC/RAB members should be involved by providing input on activities/projects, including scope, timing, schedule, and overall environmental restoration funding at the installation. Installations shall inform TRC/RAB members 

of the existence of fiscal controls, and identify priorities so that, should budget 

reductions or program adjustment become necessary, TRC/RAB members can 

provide informed input. 

Guidance on the role of RABs is contained in the DA Pam 200-1 Environmental 

Quality, Environmental Protection and Enhancement. 17 January 2002 at

http://www.usapa.army.mil/gils. 

6.8.5 Technical Assistance for Public Participation (TAPP) 

There may be times when community RAB/TRC members require a level of independent technical support. Community RAB/TRC members may seek independent technical assistance to contribute to the public’s ability to participate in 
6-16 

the restoration program. To obtain funding, community members of RABs/TRCs 

must apply for TAPP. The installation reviews the application for eligibility and 

approval before developing appropriate TAPP funding requirements. 

Additional RAB guidance and information on TAPP, can be found on the USAEC 

library web site, http://aec.army.mil/usaec/cleanup/popup/library/index.html.

6.9 DEFENSE STATES MEMORANDA OF 

AGREEMENT (DSMOA) AND COOPERATIVE 

AGREEMENT (CA) PROGRAM

The DSMOA/CA program funds state environmental regulatory agencies for 

technical services provided in support of the Army DERP. The goals of the 

DSMOA/CA Program are to expedite the cleanup process, to comply with state 

regulations, and to improve coordination and cooperation between DoD and 

state/territorial regulatory communities. The USACE is the executive agent of the 

DSMOA/CA Program. The Army provides USACE funding for the states that 

have a signed DSMOA/CA. 

The DSMOA describes how a state will provide technical services and the Army 

will provide funds for those services. The CA specifies short-term services to be 

provided and the costs of those services for two years. The CA also includes a 

narrative summary plan of long-term activities with reasonable estimates of cost 

for an additional four years, as necessary. The CAs will be updated to reflect 

MMRP requirements. 

For detailed guidance on the DSMOA/CA program, see USACE handbook 

“Working Together to Achieve Cleanup: A Guide to the Cooperative Agreement 

Process” 

http://www.edod.net/dsmoa/

6.10 MONITORED NATURAL ATTENUATION FOR 

ENVIRONMENTAL RESTORATION

While natural attenuation has no specific regulatory definition, the Army defines 

natural attenuation as the reduction of contaminant concentrations in the environment through biological processes (aerobic and anaerobic biodegradation, plant 

and animal uptake), physical phenomena (advection, dispersion, dilution, diffusion, volatilization, sorption/desorption), and chemical reactions (ion exchange, 

complexation, abiotic transformation). Terms such as intrinsic remediation or 

biotransformation are included within the more general natural attenuation definition. 
Program Procedures 

6-17 

Natural attenuation requires action; therefore, it is substantively different from a 

no action alternative. Natural attenuation typically requires extensive monitoring 

to ensure that the predicted natural processes are taking place. Natural attenuation 

remedies might take longer than engineered remedies to correct the problem. Additionally, there should be a readily available contingent remedy for the site. It 

will take credible scientific data, site characterization data, and predictive modeling to prove that natural processes are sufficient to reduce risk in the time frame 

required. 

Army policy directs that natural attenuation must be considered as a candidate 

remedy for contaminated sites either alone or in combination with active engineered measures. An engineered remedial action will not be approved unless an 

analysis that includes natural attenuation has been completed and natural attenuation has been shown to be inappropriate for a site cleanup. 

Full protocols on the use of natural attenuation for different classes of contaminants commonly found at Army bases are presently under development at 

USAEC. Until these protocols are available, the Air Force Center for Environmental Excellence’s protocol (Technical Protocol for Implementing the Intrinsic 

Remediation (Natural Attenuation) with Long-term Monitoring Option for Dissolved-Phase-Fuel Contamination in Ground Water) for petroleum contaminants 

is recommended. In addition, the USEPA issued the following: EPA Directive 

Number 9200.4-17P, Use of Monitored Natural Attenuation at Superfund, RCRA 

Corrective Action, and Underground Storage Tank Sites, 21 April 1999. 

6.11 LAND USE CONTROLS (LUCS)

The LUCs are physical, legal, and other mechanisms that restrict property use. 

The LUCs are used to mitigate risks associated with exposure to contamination 

either during or residual to cleanup, when it is inappropriate or not feasible to 

eliminate those risks by removing or treating the contaminated media to unrestricted use levels. The LUCs should therefore be used primarily as a component 

of other remedial actions, unless leaving contaminants in place proves to be the 

most favorable risk management decision (e.g., due to technical or economic limitations, concerns regarding worker safety, or to prevent collateral ecological injuries). The primary LUC mechanisms are defined as follows: 

¡ Physical mechanisms encompass a variety of engineered remedies that reduce or eliminate exposure to contaminated media. Such controls are intended to keep trespassers away from a site, warn people of dangers, or 

restrict or contain actual or potential contaminant migration. These 

mechanisms are also known as Physical Controls or Engineering Controls 

(ECs). 

¡ Legal mechanisms used for LUCs may be the same as those used for Institutional Controls (ICs) as discussed in the NCP. These mechanisms are 

primarily imposed to ensure that restrictions on land use, developed as part 
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of a remedy decision, stay in place. Examples of legal mechanisms include restrictive covenants, equitable servitudes, and deed restrictions for 

transfer properties 

The objective of LUCs is to ensure that land use remains compatible with the land 

use that was the basis for the evaluation, selection, and implementation of the response action. As such, LUCs are a common component of any response action 

that does not allow for unrestricted land use following the completion of the response action or when the response action allows for unrestricted use, but there is 

a need to protect the integrity of the remedy. Because current technologies do not 

allow for complete removal of all MEC, LUCs will be a component of all munitions responses at MRS known to contain MEC. Where there is a pre-existing 

restriction, the LUC shall be used to establish the “reasonably anticipated future 

land use.” However, since it is not being instituted as a part of the environmental 

restoration activities, that pre-existing restriction need not be evaluated as a response alternative. Instead, the pre-existing restriction will be discussed in the 

factual section of the ROD or DD. 

At all sites where a use restriction is part of environmental restoration activities, 

the LUC must be clearly defined, established in coordination with affected parties, and enforceable. Implementing LUCs through established real estate and 

land use management mechanisms provides a means to assure that LUCs remain 

effective. Use of a system of mutually reinforcing controls is often a necessary 

component in a LUC strategy. When considering LUCs as part of the response 

alternatives, the unrestricted use alternative must also be considered. 

6.11.1 LUCS AT TRANSFERRING PROPERTY 

For property that is to be transferred with some type of LUC, proprietary mechanisms may be used to restrict land use. Proprietary controls are contractual or real 

estate mechanisms, usually established in a transfer deed or contract for sale in the 

form of covenants or easements. We may supplement such proprietary LUCs 

with existing forms of control imposed by a State or local government that originate from their police power authorities. This may include zoning, permitting, 

and local redevelopment ordinances. However, Army cannot impose or enforce 

these forms of governmental restrictions. Instead, we would work together with 

State or local governments to ensure that zoning and other forms of restrictions 

are maintained. LUCs should be incorporated into appropriate transfer documentation. 

The LUCs should be managed and maintained at the local level whenever possible. In the case of an active installation, this responsibility will fall within the installation command structure until transfer. In the case of properties transferring 

or transferred from federal control, the transferee(s) should undertake practical 

LUC oversight and maintenance responsibilities on property that has left Army 

control. The appropriate transfer documents should specify the responsibility of 

the transferee(s) and subsequent property owners and users to maintain and en-
Program Procedures 

6-19 

force LUCs. In addition, Army may work together with state or local government 

agencies or with other appropriate authorities (e.g., zoning boards) to assist in 

LUC management and enforcement, ensuring compliance with remedial LUCs by 

a transferee. 

At properties transferring from federal control, the Army should use state LUC 

registries where available. The Army may, upon transfer, grant a property interest to the relevant state or local agency that will allow the state or local agency to 

maintain and enforce the LUC. Most LUCs at transfer sites would also be memorialized in the deed as deed restrictions or in other publicly available legal instruments. It is essential that the Army consult state property law and state 

environmental law when drafting the restriction because state law may require the 

use of a particular type of instrument or operative language. 

6.11.2 LUCS AT ACTIVE INSTALLATIONS

In order to ensure that active installation LUCs are observed and maintained, installations will incorporate them into the installation’s Master Plan (part of the 

environmental overlay and an annex with descriptions of both ECs and ICs) (AR 

210-20). In addition, Installations will develop written management procedures 

for maintenance and inspection of ECs and review of proposed actions 

(e.g.,construction projects, excavations, etc.) that may impact the LUCs (see Appendix I for examples). 

Approaches to LUC documentation will differ between active and transfer sites. 

Active installations cannot use restrictive covenants or negative easements to restrict property because these restrictions cannot be created without a conveyance. 

Furthermore, federal real property policy generally does not permit creation of 

restrictive covenants or negative easements by a land holding agency, such as the 

Army. As a practical matter, even if these restrictions could be placed on active 

installation property, restrictive covenants would not be effective for notifying 

installation personnel of the existence of land use controls because they are recorded in the local land records office, and title searches are typically not performed when making land use decisions at active installations. However, State 

law may permit alternative means of recordation, such a LUC notice, so installation representatives should consider State real property law when approaching this 

issue. A LUC notice does not create or convey a property interest. 

6.11.3 DOCUMENTING AND IMPLEMENTING LUCS IN RODS/DDS

 Coordinate with the installation legal office on LUC documentation and implementation to ensure consistency with any recent guidance. The most recent 

HQDA guidance is contained in DASA(ESOH) memorandum, subject: Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) 

Record of Decision (ROD) and Post-ROD Policy, dated 2 March 2004 (Appendix 

I). Only broad LUC objectives, not specific installation implementation actions, 

will be included in the CERCLA ROD/DD. This means that installations will 
6-20 

keep the ROD lean (by stating what the LUC is and what the LUC’s purpose (remedial action objective(s)) is in the ROD). The implementation details are to be 

included in documentation for the RD Phase (this may be a RD Work Plan, RA 

Work Plan, LUC Implementation Plan, Remedial Design, etc., depending on the 

terminology used by the specific installation, state and USEPA region). Once further guidance on land use controls is approved, it will be provided via memorandum and on the USAEC web site. 

http://www.dtic.mil/envirodod/Policies/PDLUCS.htm

6.12 FIVE-YEAR REVIEWS

In accordance with CERCLA and the NCP, if hazardous substances, pollutants, or 

contaminants remain at a site after a response action, at levels that do not allow 

for unlimited use and unrestricted exposure, a CERCLA five-year review is required. However, this is a CERCLA-specific requirement. Where a RCRA Corrective Action has been implemented, a five-year review is not required. The 

CERCLA five-year review will be conducted no less often than every five years 

after a selected remedial action has been initiated, or in accordance with the 

ROD/DD. The first review will be conducted no more than five years after the 

initiation of on-site construction for the first site requiring a five-year review. All 

sites will be included in the first review regardless of their phase of cleanup unless 

they have already been cleaned up for unrestricted use. Five-year reviews will 

continue until contaminants are below levels that allow for unrestricted use for all 

sites, as determined by the Army. 

The USAEC will distribute an annual memorandum notifying affected installations that a five-year review is scheduled in the next FY. The USAEC will set the 

installations’ five-year review schedule for the next FY based on the submitted 

ROD/DD information in AEDB-R. The Garrison Commander will review the 

response action to ensure that human health and the environment are being protected. The review process will also be used to determine whether active treatment remedies and long-term monitoring programs are operating efficiently and 

continue to be cost effective. If a selected remedy is determined to be inoperative 

and/or not protective of human health and the environment, a new remedy will be 

selected that complies with the provisions of CERCLA and the NCP. 

Five-year reviews for ER,A eligible projects will be funded by ER,A. Installations will be responsible for updating the associated CTC and for programming 

for funds in AEDB-R. Installation obligation plans will list USAEC as the executor to allowing funding transfer directly from USAEC to the executor. The 

USACE HTRW Center of Expertise will conduct all CERCLA five-year reviews 

at NPL and non-NPL installations being funded by ER,A . The only exception 

will be at those installations that have instituted a PBC that holds the contractor 

responsible for conducting the five-year review within the contract period of performance. 
Program Procedures 

6-21 

For all active installations except excess installations assigned to the BRAC Division, the Installation Commander is the approval authority. The installation will 

obtain USAEC concurrence prior to submitting copies to regulators for review 

and comment. 

See the Memorandum from ACSIM, subject: Final Guidance for Conducting 

Five-Year Reviews, for the latest guidance on five-year review requirements at 

Army Installations: 

http://www.denix.osd.mil/denix/DOD/Policy/Army/Cerclareviews.pdf

6.13 END OF RESTORATION PROGRAM

Sites remain in the Army DERP until all required response actions have been 

completed. Requirements at these sites will continue to be programmed and 

budgeted in the appropriate environmental restoration account. 

6.13.1 Response Complete (RC) 

Consistent with CERCLA, the DERP, and applicable Executive Orders and regulations, the Army shall consider environmental response activities under the Army 

DERP RC when it achieves and documents all the response objectives identified 

in an appropriately signed ROD/DD. 

If Army DERP activities allow for unrestricted use of the property, RC occurs 

when there is verification of the achievement of the response objectives detailed 

in the ROD/DD. If Army DERP activities do not allow for unrestricted use of the 

property, RC occurs when the following three conditions are met: 

¡ There is verification of the achievement of the response objectives detailed 

in the ROD/DD. 

¡ At least one subsequent review has been conducted to ensure the response 

action has remained effective and continues to be protective of public 

safety, human health and the environment as defined by the response objectives detailed in the ROD/DD. 

¡ At least five years have elapsed since the remedial action objectives were 

first achieved. 

6.13.2 Reopened Sites 

Any site that previously completed all required response actions that is determined, by the results of subsequent long-term management actions, to require additional response actions to achieve the response objectives identified in the 

ROD/DD will be considered a “re-opened environmental restoration site." Addi-
6-22 

tional response action requirements at such sites shall be programmed and budgeted in the ER,A account. 

The second type of reopened site relates to sites where the investigation(s) have 

been completed (PA, SI, RI/FS) and subsequently, an investigative phase is reopened. These sites will also be considered “re-opened environmental restoration 

sites.” Additional environmental study or response action requirements at such 

sites shall be identified during AEDB-R updating. 

Reopening of a site or investigation requires justification. That justification will 

be included in the narrative field of the site general information in AEDB-R. 

6.13.3 Post Remedial Design (RD) Procedures 

The terminology for work in the final stages of remediation was developed to 

more accurately reflect the status of the site. Remedial Action-Construction 

(RA(C)) is the phase during which the final remedy is being put in place. The end 

date signifies that the construction is complete, all testing has been accomplished, 

and that the remedy will function properly. The RA(O) is the phase during which 

the remedy is in place and operating to achieve the cleanup objective identified in 

the ROD/DD. Any system operation or monitoring requirements during this time 

should be termed RA(O). RC signifies that the remedy is in place and the required RA(O) has been completed. If there is no RA(O) phase, then the RA(C) 

end date will also be the RC date. Once a site is RC, environmental monitoring or 

review of site conditions and/or maintenance of the remedial action to ensure the 

remedy is operating as designed is termed LTM. The LTM refers to monitoring 

and other management requirements once a site is RC, and should not be used to 

refer to monitoring after RIP, which is included in RA(O). (This includes sites for 

which the selected remedy is natural attenuation.) 

Installations and USAEC ERMs should review AEDB-R data inputs to ensure 

that data reflect the terminology described herein. 

Remedial Action 

Construction

Remedy in Place

Remedial Action 

Operation

Response Complete*

Long-term 

Management

LTM

Requirements

Complete

Start

Milestone

Complete

*Response Complete could occur after construction if there no operation .

Milestones
Program Procedures 

6-23 

6.14 Natural Resource Injuries (NRI) 

As stated in the ODUSD (I&E) memorandum, Interim Policy on Integration of 

Natural Resource Injury Responsibilities and Environmental Restoration Activities (2 May 2000), the Secretary of Defense has delegated the authority as a 

CERCLA natural resource trustee to the head of each Component, with authority 

to re-delegate a representative as appropriate. Installation Commanders do not 

serve as natural resource trustee representatives. 

At sites where the Army is acting as CERCLA Lead Agent, installations shall 

identify potential NRI attributable to releases of hazardous substances as they perform site characterizations. This evaluation is intended to provide relevant information regarding the current condition of the natural resources. Such data are then 

used to assist the installation in the assessment of the threshold criteria of “overall 

protection of human health and the environment” that is part of the evaluation of 

response alternatives. As part of the evaluation of response alternatives, installations shall assess: 

¡ How each response alternative considered addresses the potential natural 

resource injuries caused by Army activities. 

¡ Whether implementation of that particular response alternative will itself 

cause additional potential natural resource injury. 

The installation shall notify all appropriate Trustees, which may include federal 

agencies, states, and Native American tribes, of potential injury to natural resources and shall coordinate documents and proposed environmental restoration 

activities with these Trustees. This coordination does not, however, grant the 

other Trustees a role in selection of a response. The installation shall also coordinate with Army-wide natural resource professionals to obtain relevant ecosystem 

information. Installations are encouraged, when feasible and cost-effective, to 

select a response that will result in the least amount of potential natural resource 

injury. 

6.15 ENVIRONMENTAL RESTORATION ISSUES IN 

PROPERTY TRANSFER 

Army guidance for studies and documentation to support property transfers into 

and out of Army control are addressed in Section 15-6 of DA Pam 200-1. Since 

the implementation of the TIM, the IMA now is responsible for the activities the 

DA Pam 200-1 ascribes to the Army Major Commands (MACOMs), except for 

those installations belonging to the Army National Guard or are special installations of the MACOMs. Special installations are defined in the following: 

http://www.ima.army.mil/files/Special_Installations_Study1.doc
6-24 

6.15.1 Deed Covenants 

The CERCLA §120(h) has specific requirements for covenants that must be given 

when transferring property by deed outside the federal government. The Installation Legal Office must be consulted to determine when the covenants are required. 

When conveying by deed to a non-federal entity, a property where a CERCLA 

hazardous substance was stored for one year or more, or release to have been 

known, or known to have been disposed on the property, CERCLA §120(h)(3) 

requires two covenants in the deed (unless the property recipient is a PRP for contamination on the property). 

¡ The first covenant, under CERCLA §120(h)(3)(i), states that all necessary 

remedial action with respect to any hazardous substance remaining on the 

property has been taken before the date of transfer. In the case of early 

transfer, this covenant will be withheld upon conveyance, and issued instead upon completion of cleanup. 

¡ The second covenant, under CERCLA §120(h)(3)(ii), warrants that any 

additional remedial action found to be necessary after the date of the transfer would be conducted by the United States. 

¡ In addition, the deed must contain a clause granting to the United States 

access rights to enter the property to conduct any future remedial activities.

When conveying by deed to a non-federal entity, property that has been identified 

as “uncontaminated” (i.e., where no CERCLA hazardous substance, petroleum 

product, or petroleum product derivative was released or disposed) and where no 

remedial action has been necessary, the deed shall contain a covenant required by 

CERCLA §120(h)(4)(D)(i) warranting that any remedial action found to be necessary after the date of the transfer will be conducted by the United States. In addition, the deed must contain a clause granting to the United States access rights to 

enter the property to conduct any future remedial activities. 

For property known or suspected to contain MEC, to include property on which 

there is a potential for residual explosive hazards to remain, a covenant or notice 

is required. At a minimum, the notice should advise of the former use of property 

as a military installation, that there is a possibility that MEC may exist on the 

property, that should MEC be found on the property it should not be moved, disturbed or destroyed, but shall immediately reported to the local police who will 

request DoD support of an explosives or munitions emergency.

6.15.2 Post-Transfer Restoration Activities 
Program Procedures 

6-25 

Installations should disclose all environmental restoration activities that were required at a given property to the communities and the transferee. This shall include the basis for selecting the reasonably anticipated future land use used in 

evaluating the need for a response action, or in formulating remedial alternatives 

for evaluation. Installations should also provide the transferee a copy of the current DoD policy on additional restoration after transfer [currently the Deputy Under Secretary of Defense (Acquisition and Technology) (USD (A&T)) 

memorandum, Responsibility for Additional Environmental Cleanup after Transfer of Real Property (25 July 1997)]. Additional environmental restoration activities necessary to address contamination attributable to DoD activities will be 

performed consistent with the reasonably anticipated future land use assumptions 

used to evaluate the original remedy and CERCLA §120(h). 

Unless otherwise provided for in transfer documentation or by prior notification, 

the installation that disposed of the property will be responsible for additional environmental restoration if: 

¡ Additional contamination discovered after transfer that is attributable to 

Army activities that occurred prior to transfer, and that is inconsistent with 

the established remedy. 

¡ A determination is made that a remedy is no longer protective of human 

health and the environment due to a failure of the remedy or a change 

made in the applicable health or environmental standard that applies. 

DoD will not conduct additional environmental restoration activities to accommodate changes in land use after transfer where the:

¡ Reasonably anticipated future land use assumptions used for remedy selection were based on the Local Reuse Authority (LRA) reuse or other appropriate planning agency input. 

¡ Remedy selection process included local community input. 

¡ The LRA and/or community request additional environmental restoration 

activities solely to facilitate a use prohibited by deed restriction or other 

appropriate LUC. 

In cases where there is a need for any environmental restoration activities such as 

monitoring, operation and maintenance of remedial systems, or five-year reviews, 

to continue after transfer to non-DoD entities, installations will coordinate 

through the USAEC ERM to determine how to fund such activities in the most 

cost-effective manner. Options for conducting these activities may include: 

¡ Transferring specific LUC inspection, oversight, maintenance, reporting 

and enforcement responsibilities to the new owner(s) and user(s). 
6-26 

¡ Reimbursing another DoD entity (e.g., USACE) to conduct the required 

work. 

¡ Performing the required work. This option is not preferred and shall be 

chosen only when it is the most reliable and cost effective way to ensure 

that work will be completed.
 A-1 

Appendix A 

Department of the Army Command Structure 

IMA Regions 

Assistant Secretary of the Army 

(Installations and Environment) 

Deputy Assistant Secretary 

of the Army 

(Environment, Safety & Occupational Health)

Assistant Chief of Staff 

for Installation Management

Director, 

Environmental 

Programs

US Army Center 

for Health Promotion 

and Preventive Medicine 

US Army 

Corps of Engineers 

Chief, 

BRAC 

Division

BRAC Installations 

Command 

Program Management 

Support 

Active Installations1

US Army 

Environmental Center 

Installation Management Agency 

BRAC Field Office 

1

The special mission funded installations of 

the MACOMs have the same relationship 

with their MACOM headquarters as the 

other active installations with IMA. 

 B-1 

Appendix B 

Restoration Concept 

 USAEC 

IRP Program Manager 

Restoration Management 

Funds Approval 

BRAC Support 

Restoration Functional Manager 

Reporting 

Absorb former MACOM 

 oversight role 

Funding Recommendations 

ODEP

 BRACD 

BRAC MDEP Manager 

Funds Approval 

Compliance/Conservation 

Excess Property Disposal 

BRAC FIELD OFFICES 

Coordinate disposal and 

Environmental efforts 

Coordinate Restoration 

Priorities 

NGB & 

RESERVES 

Oversight 

QA/QC 

NGB & 

RESERVES 

Installations 

Coordinate Restoration 

Priorities 

Installation 

Mgt Agency 

Active 

Installations 

Active Army DERP Excess Army DERP

Excess 

 Installations 

IMA 

Regions 

Support to BRACD 

 C-1 

Appendix C 

Non-BRAC Excess Properties 

Badger Army Ammunition Plant (AAP) 

Charles Melvin Price, Support Center (currently no ER,A funding) 

Cornhusker AAP 

Indiana AAP 

Joliet AAP 

Longhorn AAP 

Ravenna AAP 

Rocky Mountain Arsenal 

St Louis AAP (currently no ER,A funding) 

Sunflower AAP 

Tarheel AAP (currently no ER,A funding) 

Twin Cities AAP 

Volunteer AAP 

 D-1 

Appendix D 

Examples of Eligible and Ineligible Restoration 

Activities 

IRP Activities Eligible for ER,A Funding 

Investigations to identify, confirm, and determine the risk to human health and the environment 

resulting from past DoD contamination. This also includes feasibility studies or engineering 

evaluation and cost analysis (EE/CA); remedial action plans and designs; and removal or remedial 

actions. 

Expenses associated with cooperative multi-party cleanup plans and activities including litigation 

expenses. 

Remedial actions to protect or restore (not enhance) natural resources injured by contamination 

from past hazardous waste disposal activities. 

Cleanup of low-level radioactive waste sites which have been identified as restoration sites. 

Management expenses associated with the Army DERP. Management expenses are those overhead costs required for adequate program oversight and management. 

Operation and maintenance costs for remedial and monitoring systems. 

Immediate actions necessary to address health and safety concerns resulting from past Army contamination such as providing funding for alternate water supplies or treatment of contaminated 

drinking water. 

Releases from underground storage tanks that were not in service as of Oct 17, 1986. 

CERCLA response actions and eligible RCRA corrective actions identified in Federal Facility 

Agreements/Interagency Agreements (FFA/IAGs). 

Corrective actions at solid waste management units (SWMUs) needed because of past Army activities unless the SWMU is subject to RCRA closure requirements. 

Support services provided by another agency in accordance with 10 U.S.C §2701(d). 

Activities responding to UXO, DMM or MC where the release occurred prior to 30 September 

2000, and the site was identified and included in DSERTS (now AEDB-R) prior to 30 September 

2002, and was not classified as response complete. 

MMRP Activities Eligible for ER,A Funding 

Activities responding to UXO, DMM or MC where the release occurred prior to 30 September 

2002, and the site were not already fully funded in the installation’s FY01 CTC estimate. 

 Investigations and responses at non-operational ranges and other eligible MMRP category sites. 
 Consolidated MMRP Definitions (cont) 

 D-2 

IRP Activities Not Eligible for ER,A Funding 

Use of funds for RCRA (i.e.. Federal Facility Compliance Act amended RCRA) fine and penalties 

associated with restoration activities. 

Construction of hazardous waste storage, transfer, treatment or disposal facilities, except when 

part of a restoration remedial action. 

Test or repair of active underground tanks; costs to replace leaking underground tanks. 

Costs to store or replace PCB transformers. 

Costs of asbestos and lead based paint surveys, containment, removal or disposal, except when 

incidental to a response action. 

Costs of spill prevention and containment measures for operating equipment and facilities. 

Cleanup costs of spills associated with current operations. 

Costs of operation, maintenance or repair to hazardous waste treatment, storage or disposal facilities that are in use (i.e., regulated or permitted), except when part of a response action. 

Investigations or cleanup activities associated with facilities that received operating permits under 

RCRA. 

Activities responding to UXO, DMM or MC where the release occurred on or after 1 October 

2000. 

Activities responding to UXO, DMM or MC where the site was listed in DSERTS prior to 30 September 2000, and was classified as response complete. 

Investigations and responses at non-operational ranges and other eligible MMRP 

category sites.
Examples of Eligible and Ineligible Restoration Activities

 D-3 

MMRP Activities Not Eligible for ER,A Funding 

Activities responding to UXO, DMM or MC where the release occurred on or after 1 October 

2002. 

Activities responding to UXO, DMM or MC at locations outside the United States. 

Investigations and responses to munitions constituents (explosives) released to the soil, surface 

water, sediments, or groundwater as a result of ammunition or explosives production or manufacturing. 

Response activities for UXO, DMM or MC resulting from combat operations. 

Response activities for UXO, DMM or MC at operational ranges. 

Response activities for UXO, DMM or MC at facilities that are used for or were permitted for the treatment 

or disposal of military munitions. 

 E-1 

Appendix E 

Table of Eligibility 

ACTIVE INSTALLATIONS AND LOCATIONS NOT ELIGIBLE UNDER THE FUDS PROGRAM 

OR TRANSFERRING UNDER THE BRAC PROGRAM

 Component ER Funds 

Activity Installation 

Restoration 

Munitions 

Response 

BD/DR 

Installation Restoration program category activities at sites where the release occurred prior 

to October 17, 1986.1 

E NE NE 

Installation Restoration program category activities at sites where the release occurred between October 17, 1986, and September 30, 2000, and where the site was identified and included in the DSERTS prior to September 30, 2000. E NE NE 

Installation Restoration program category activities where the release occurred after October 

17, 1986, and where the site was not identified and include in the DSERTS prior to September 30, 2000. 

NE NE NE 

Installation Restoration program category activities involving military munitions (i.e., UXO 

or WMM) or the chemical residues of munitions activities where: 

• The release occurred prior to September 30, 2000; and 

• The site release is not at a FUDS, operational range, 

 active munitions demilitarization facility, or active WMM 

 treatment or disposal unit; and 

• The site was identified and included in the RMIS prior to September 30, 2000, and was 

not classified as “response complete.” 

E NE NE 

Military Munitions Response program category activities where: the release occurred prior to 

September 30, 2002; the release is not at a FUDS, operational range, active munitions demilitarization facility, or active WMM treatment or disposal unit that operated after September 

30, 2002, and the site was not identified or included in the DSERTS prior to September 30, 

2000. 

NE E NE 

Military Munitions Response program category activities at operational ranges, active munitions demilitarization facilities, active WMM treatment or disposal units, or at non-range locations where the release occurs after September 30, 2002. NE NE NE 

Building Demolition/Debris Removal program category activities to address unsafe buildings 

or structures unused since October 17, 1986, where the activities are an integral part of actions under the Installation Restoration or Military Munitions Response program categories NE NE E 

Building Demolition/Debris Removal program category activities to address unsafe buildings 

or structures unused since October 17, 1986, where the activities are not an integral part of 

actions under the Installation Restoration or Military Munitions Response program categories. Components must be granted approval by ODUSD(I&E) to before funds may be programmed. 

NE NE E2 

Building Demolition/Debris Removal program category activities to address unsafe buildings 

or structures used since October 17, 1986. 

NE NE NE 

 KEY: E= Eligible NE= Ineligible 

1 17 October 1986, is the effective date of SARA, the law that amended CERCLA and established DERP. 

2 Components must first request from and be granted approval by ODUSD(I&E) to use ER funds for BD/DR at active installations. 

Approval must be obtained before funds may be programmed. Office of the Deputy Under Secretary of Defense (Installations and 

Environment) September 2001 

F-1 

Appendix F Definitions for the Military Munitions Response 

Program1 

Anomaly Avoidance. Techniques employed on property known or suspected to contain MEC, or CWM in OTM 

configurations to avoid contact with potential surface or subsurface explosive or CA hazards, to allow entry to the 

area for the performance of required operations. 

Chain of Custody. The activities and procedures taken throughout the inspection, re-inspection and documentation process to maintain positive control of Material Potentially Presenting an Explosive Hazard (MPPEH) to ensure the veracity of the process used to determine the status of material as to its explosive hazard. This includes all 

such activities from the time of collection through final disposition. 

Chemical Agent (CA). CA means an agent that, through its chemical properties, produces lethal or other damaging effects on human beings, except that such term does not include riot control agents, chemical herbicides, smoke 

and other obscuration materials. 

Chemical Agent (CA) Hazard. A condition where danger exists because CA is present in a concentration high 

enough to present potential unacceptable effects (e.g., death, injury, damage) to people, operational capability, or 

the environment.

Chemical Warfare Material (CWM). Items generally configured as a munition containing a chemical substance 

that is intended to kill, seriously injure, or incapacitate a person through its physiological effects. CWM includes 

V- and G-series nerve agents or H-series (mustard) and L-series (lewisite) blister agents in other-than-munition 

configurations; and certain industrial chemicals (e.g., hydrogen cyanide (AC), cyanogen chloride (CK), or carbonyl 

dichloride (called phosgene or CG)) configured as a military munition. Due to their hazards, prevalence, and military-unique application, chemical agent identification sets (CAIS) are also considered CWM. CWM does not include: riot control devices; chemical herbicides; industrial chemicals (e.g., AC, CK, or CG) not configured as a 

munition; smoke and flame producing items; or soil, water, debris or other media contaminated with low concentrations of chemical warfare agents where no CA hazards exist. 

Chemical Warfare Material (CWM) Response. Munitions responses and other responses to address the chemical safety; explosives safety, when applicable; human health; or environmental risks presented by CWM regardless 

of configuration. (See munitions response.)

Construction Support. Assistance provided by DoD EOD or UXO-qualified personnel and/or by personnel 

trained and qualified for operations involving CWM during intrusive construction activities on property known or 

suspected to contain MEC, or CWM in OTM configurations to ensure the safety of personnel or resources from 

any potential explosive or CA hazards. 

Chemical Agent (CA) Safety. A condition where operational capability and readiness, people, property, and the 

environment are protected from the unacceptable effects or risks of a mishap involving chemical warfare material 

(CWM).
 Consolidated MMRP Definitions (cont)

F-2 

Defense Sites. Locations that are or were owned by, leased to, or otherwise possessed or used by the Department 

of Defense. The term does not include any operational range, operating storage or manufacturing facility, or 

facility that is used for or was permitted for the treatment or disposal of military munitions. (10 U.S.C. 

2710(e)(1))

Discarded Military Munitions (DMM). Military munitions that have been abandoned without proper disposal 

or removed from storage in a military magazine or other storage area for the purpose of disposal. The term does 

not include unexploded ordnance, military munitions that are being held for future use or planned disposal, or 

military munitions that have been properly disposed of consistent with applicable environmental laws and regulations. (10 U.S.C. 2710(e)(2)) 

Disposal. End of life tasks or actions for residual materials resulting from demilitarization or disposition operations. 

Disposition. The process of reusing, recycling, converting, redistributing, transferring, donating, selling, demilitarizing, treating, destroying, or fulfilling other life-cycle guidance, for DoD property. 

Documentation of the Explosives Safety Status of Material. Documentation recording that material: (1) does 

not present an explosive hazard and is consequently safe for unrestricted transfer within or release from DoD 

control or (2) is MPPEH, with the stated known or suspected explosive hazards, and is consequently is only 

transferable or releasable to a qualified receiver. This documentation must be signed by a technically qualified 

individual with direct knowledge of: (1) the results of both the 100 percent inspection and 100 percent reinspection, and (2) the chain-of-custody of the material originally classified as MPPEH. This certification is followed by a verification signed by a technically qualified individual who inspects the material on a sampling basis 

(sampling procedures are determined by DoD entity that is generating the MPPEH).

Environmental Regulators and Safety Officials. Include, but may not be limited to environmental regulators, 

environmental coordinators or hazardous material coordinators, law enforcement officers, and safety personnel of 

the US Environmental Protection Agency (USEPA), American Indians and Alaska Natives, other Federal Land 

Managers, and/or the States. When appropriate, public health officials of various agencies may also be involved. 

Explosive Hazard. A condition where danger exists because explosives are present that may react (e.g., detonate, deflagrate) in a mishap with potential unacceptable effects (e.g., death, injury, damage) to people, property, 

operational capability, or the environment.

Explosive Ordnance Disposal (EOD). The detection, identification, on-site evaluation, rendering safe, recovery, and final disposal of unexploded ordnance and of other munitions that have become hazardous by damage or 

deterioration.

Explosive Ordnance Disposal (EOD) Personnel. Military personnel who have graduated from the Naval 

School, Explosive Ordnance Disposal; are assigned to a military unit with a Service-defined EOD mission; and 

meet Service and assigned unit requirements to perform EOD duties. EOD personnel have received specialized 

training to address explosive and certain CA hazards during both peacetime and wartime. EOD personnel are 

trained and equipped to perform Render Safe Procedures (RSP) on nuclear, biological, chemical, and conventional munitions, and on improvised explosive devices.

Explosive Ordnance Disposal (EOD) Unit. A military organization constituted by proper authority; manned 

with EOD personnel; outfitted with equipment required to perform EOD functions; and assigned an EOD mission.

Explosives or Munitions Emergency Response. All immediate response activities by an explosives and munitions emergency response specialist to control, mitigate, or eliminate the actual or potential threat encountered 

during an explosives or munitions emergency. An explosives or munitions emergency response may include inplace render-safe procedures, treatment or destruction of the explosives or munitions, and/or transporting those 

items to another location to be rendered safe, treated, or destroyed. Any reasonable delay in the completion of an 

explosives or munitions emergency response caused by a necessary, unforeseen, or uncontrollable circumstance 

will not terminate the explosives or munitions emergency. Explosives and munitions emergency responses can 

occur on either public or private lands and are not limited to responses at RCRA facilities. (Military Munitions 
 Consolidated MMRP Definitions (cont)

F-3 

Rule, 40 CFR 260.10) 

Explosives Safety. A condition where operational capability and readiness, people, property, and the environment are protected from the unacceptable effects or risks of potential mishaps involving military munitions.

Interim Holding Facility (IHF). A temporary storage facility designed to hold recovered chemical warfare material (RCWM) pending transportation for off-site treatment or storage, or on-site treatment. 

Land Use Controls (LUC). LUC are physical, legal, or administrative mechanisms that restrict the use of, or 

limit access to, real property to manage risks to human health and the environment. Physical mechanisms encompass a variety of engineered remedies to contain or reduce contamination and/or physical barriers to limit 

access to real property, such as fences or signs. 

Long-term Management (LTM). The period of site management (including maintenance, monitoring, record 

keeping, 5-year reviews, etc.) initiated after response (removal or remedial) objectives have been met (i.e., after 

Response Complete). 

Material Potentially Presenting an Explosive Hazard (MPPEH). Material potentially containing explosives 

or munitions (e.g., munitions containers and packaging material; munitions debris remaining after munitions use, 

demilitarization, or disposal; and range-related debris); or material potentially containing a high enough concentration of explosives such that the material presents an explosive hazard (e.g., equipment, drainage systems, holding tanks, piping, or ventilation ducts that were associated with munitions production, demilitarization 

or disposal operations). Excluded from MPPEH are munitions within DoD's established munitions management 

system and other hazardous items that may present explosion hazards (e.g., gasoline cans, compressed gas cylinders) that are not munitions and are not intended for use as munitions. 

Military Munitions. Military munitions means all ammunition products and components produced for or used 

by the armed forces for national defense and security, including ammunition products or components under the 

control of the Department of Defense, the Coast Guard, the Department of Energy, and the National Guard. 

The term includes confined gaseous, liquid, and solid propellants, explosives, pyrotechnics, chemical and riot 

control agents, smokes, and incendiaries, including bulk explosives, and chemical warfare agents, chemical munitions, rockets, guided and ballistic missiles, bombs, warheads, mortar rounds, artillery ammunition, small arms 

ammunition, grenades, mines, torpedoes, depth charges, cluster munitions and dispensers, demolition charges, 

and devices and components of the above. 

 The term does not include wholly inert items, improvised explosive devices, and nuclear weapons, nuclear 

devices, and nuclear components, other than non-nuclear components of nuclear devices that are managed under 

the nuclear weapons program of the Department of Energy after all required sanitization operations under the 

Atomic Energy Act of 1954 (42 U.S.C. 2011 et seq.) have been completed. (10 U.S.C. 101(e)(4)(A) through (C))

Minimum Separation Distance (MSD). MSD is the distance at which personnel in the open must be from an 

intentional or unintentional detonation.

Mutual Agreement. A meeting of the minds on a specific subject, and a manifestation of intent of the parties to 

do or refrain from doing some specific act or acts. Inherent in any mutual agreement or collaborative process are 

the acknowledgement of each member’s role in the process and their differing views of their authorities. The 

mutual agreement process will provide a means of resolving differences without denying the parties an opportunity to exercise their respective authorities should mutual agreement fail to be achieved. 

Munitions and Explosives of Concern (MEC). This term, which distinguishes specific categories of military 

munitions that may pose unique explosives safety risks means: (A) Unexploded ordnance (UXO), as defined in 

10 U.S.C. 101(e)(5)(A) through (C); (B) Discarded military munitions (DMM), as defined in 10 U.S.C. 

2710(e)(2); or (C) Munitions constituents (e.g., TNT, RDX), as defined in 10 U.S.C. 2710(e)(3), present in high 

enough concentrations to pose an explosive hazard.
 Consolidated MMRP Definitions (cont) 

F-4 

Munitions Constituents (MC). Any materials originating from unexploded ordnance, discarded military munitions, or other military munitions, including explosive and non-explosive materials, and emission, degradation, or 

breakdown elements of such ordnance or munitions. (10 U.S.C. 2710). 

Munitions Debris. Remnants of munitions (e.g., fragments, penetrators, projectiles, shell casings, links, fins) 

remaining after munitions use, demilitarization, or disposal.

Munition with the Greatest Fragmentation Distance (MGFD). The munition with the greatest fragment distance that is reasonably expected (based on research or characterization) to be encountered in any particular area. 

Munitions Response. Response actions, including investigation, removal actions and remedial actions to address 

the explosives safety, human health, or environmental risks presented by unexploded ordnance (UXO), discarded 

military munitions (DMM), or munitions constituents (MC). 

Munitions Response Area (MRA). Any area on a defense site that is known or suspected to contain UXO, 

DMM, or MC. Examples include former ranges and munitions burial areas. A munitions response area is comprised of one or more munitions response sites. 

Munitions Response Site (MRS). A discrete location within an MRA that is known to require a munitions response. 

One Percent Lethality Distance. A distance calculated from a given CA MCE and meteorological conditions 

(temperature, wind speed, Pasquill stability factor) and established as the distance at which dosage from that 

MCE agent release would be 150 mg-min/m 3 for H and HD agents, 75 mg-min/m3 for HT agent, 150 mg-min/m3 

for Lewisite, 10 mg-min/m3 for GB agent, 4.3 mg-min/m3 for VX vapor, and 0.1 mg-min/m3 for inhalation and 

deposition of liquid VX. 

On-call Construction Support. Support provided, on an as needed basis, by DoD EOD or UXO-qualified personnel and/or by personnel trained and qualified for operations involving CWM during intrusive construction 

activities on property known or suspected to contain MEC or CWM in OTM configurations, where the probability of encountering such has been determined to be low. This support can respond from off-site when called, or 

be on-site and available to provide required construction support. 

On-site Construction Support. Dedicated support provided by DoD EOD or UXO-qualified personnel and/or 

by personnel trained and qualified for operations involving CWM during intrusive construction activities on 

property known or suspected to contain MEC, or CWM in OTM configurations, where the probability of encountering such has been determined to be moderate to high. 

On-call UXO Construction Support. Support provided, on an as needed basis, by DoD EOD or UXO-qualified 

personnel during intrusive construction activities on property known or suspected to contain UXO or other munitions that have experienced abnormal environments where the probability of encountering such has been determined to be low. This support can respond from off-site when called, or be on-site and available to provide 

required construction support. 

On-site UXO Construction Support. Dedicated support provided by DoD EOD or UXO-qualified personnel 

during construction activities on property known or suspected to contain UXO or other munitions that have experienced abnormal environments where the probability of encountering such has been determined to be moderate 

to high. 

On-the-Surface. A situation in which UXO, DMM or CWM are: (A) entirely or partially exposed above the 

ground surface (i.e., the top of the soil layer); or (B) entirely or partially exposed above the surface of a water 

body (e.g., as a result of tidal activity).
 Consolidated MMRP Definitions (cont)

F-5 

Open Burn (OB). An open-air combustion process by which excess, unserviceable, or obsolete munitions are 

destroyed to eliminate their inherent explosive hazards. 

Open Detonation (OD). An open-air process used for the treatment of excess, unserviceable or obsolete munitions whereby an explosive donor charge initiates the munitions being treated. 

Operational Range. A range that is under the jurisdiction, custody, or control of the Secretary of Defense and 

that is used for range activities; or although not currently being used for range activities, that is still considered by 

the Secretary to be a range and has not been put to a new use that is incompatible with range activities. (10 U.S.C. 

101(e)(3)(A) and (B)). Also includes “military range,” “active range,” and “inactive range” as those terms are 

defined in 40 CFR §266.201. (See reference (f)).

Primary Explosives. Primary explosives are highly sensitive compounds that are typically used in detonators 

and primers. A reaction is easily triggered by heat, spark, impact or friction. Examples of primary explosives are 

lead azide and mercury fulminate.

Public Access Exclusion Distance (PAED). The PAED is defined as longest distance of the hazardous fragment 

distance, IBD for overpressure, or the One Percent Lethality Distance. For siting purposes, the PAED is analogous to the IBD for explosives; therefore, personnel not directly associated with the chemical operations are not 

to be allowed within the PAED. 

Qualified Receiver. Entities that have personnel who are, or individuals who are, trained and experienced in the 

identification and safe handling of used and unused military munitions, and any known or potential explosive 

hazards that may be associated with the MPPEH they receive; and are licensed and permitted or otherwise qualified to receive, manage, and process MPPEH. 

Range. A designated land or water area that is set aside, managed, and used for range activities of the Department of Defense. The term includes firing lines and positions, maneuver areas, firing lanes, test pads, detonation 

pads, impact areas, electronic scoring sites, buffer zones with restricted access, and exclusionary areas. The term 

also includes airspace areas designated for military use in accordance with regulations and procedures prescribed 

by the Administrator of the Federal Aviation Administration. (10 U.S.C. 101(e)(1)(A) and (B)) 

Range activities. Research, development, testing, and evaluation of military munitions, other ordnance, and 

weapons systems; and the training of members of the armed forces in the use and handling of military munitions, 

other ordnance, and weapons systems. (10 U.S.C. 101(e)(2)(A) and (B))

Range-Related Debris. Debris, other than munitions debris, collected from operational ranges or from former 

ranges (e.g., targets).

Render Safe Procedures (RSP). The portion of EOD procedures that involves the application of special disposal methods or tools to interrupt the functions or separate the essential components of UXO to prevent an unacceptable detonation. 

Secondary Explosives. Secondary explosives are generally less sensitive to initiation than primary explosives 

and are typically used in booster and main charge applications. A severe shock is usually required to trigger a 

reaction. Examples are TNT, cyclo-1,3,5-trimethylene-2,4,6-trinitramine (RDX or cyclonite), HMX, and tetryl. 

Small Arms Ammunition. Ammunition, without projectiles that contain explosives (other than tracers), that is 

.50 caliber or smaller, or for shotguns. 

Team Separation Distance (TSD). The distance that munitions response teams must be separated from each 

other during munitions response activities involving intrusive operations. 

Technical Escort Unit (TEU). A DoD organization manned with specially trained personnel that provide verifi-
 Consolidated MMRP Definitions (cont) 

F-6 

cation, sampling, detection, mitigation, render safe, decontamination, packaging, escort and remediation of 

chemical, biological and industrial devices or hazardous material. 

Technology-aided Surface Removal. A removal of UXO, DMM or CWM on the surface (i.e., the top of the soil 

layer) only, in which the detection process is primarily performed visually, but is augmented by technology aids 

(e.g., hand-held magnetometers or metal detectors) because vegetation, the weathering of UXO, DMM or CWM, 

or other factors make visual detection difficult. 

Time Critical Removal Action (TCRA). Removal actions where, based on the site evaluation, a determination 

is made that a removal is appropriate, and that less than 6 months exists before on-site removal activity must begin. (40 CFR 300.5) 

Unexploded Ordnance (UXO). Military munitions that (A) have been primed, fuzed, armed, or otherwise prepared for action; (B) have been fired, dropped, launched, projected, or placed in such a manner as to constitute a 

hazard to operations, installations, personnel, or material; and (C) remain unexploded either by malfunction, design, or any other cause. (10 U.S.C. 101(e)(5)(A) through (C)))

UXO Avoidance. Techniques employed on property known or suspected to contain UXO or other munitions that 

have experienced abnormal environments, to avoid contact with potential explosive or CA hazards, to allow entry 

to the area for the performance of required operations.

UXO Technicians. Personnel who are qualified for and filling Department of Labor, Service Contract Act, Directory of Occupations, contractor positions of UXO Technician I, UXO Technician II, and UXO Technician III.

UXO-Qualified Personnel. Personnel who have performed successfully in military EOD positions, or are qualified to perform in the following Department of Labor, Service Contract Act, Directory of Occupations, contractor 

positions: UXO Technician II, UXO Technician III, UXO Safety Officer, UXO Quality Control Specialist, or 

Senior UXO Supervisor.

Venting. Exposing any internal cavities of MPPEH, to include training or practice munitions 

(e.g., concrete bombs), using DDESB- or DoD Component-approved procedures, to confirm that an explosive 

hazard is not present.

1

 This list expands the list of definitions contained in the 28 Oct 03 memorandum, 

DASA(ESOH), Subject: Definitions Related to Munitions Response Actions. 
 

G-1 

Appendix G 

Policy for Staffing and Approving Decision Documents1

1. References: 

a. DA Pamphlet 200-1, January 2002. 

b. Installation Restoration Program Management Plan, March 1999. 

c. Management Guidance for the Defense Environmental Restoration Program 

(DERP), ODUSD (I&E), 28 September 2001. 

2. This policy applies to decision documents (DD), including Records of Decision 

(ROD), Interim RODs, Action Memoranda, and Statements of Basis for response or corrective actions taken in accordance with the Comprehensive Environmental Response, 

Compensation, and Liability Act (CERCLA); the National Contingency Plan; Executive 

Order 12580; and the Resource Conservation and Recovery Act (RCRA). 

3. Decision documents are required to document response or corrective actions that 

are DERP eligible per reference 1c, including interim remedial actions, remedial actions, 

removals, or implementation of land use controls that Army imposes as part of a remedy 

to address a CERCLA risk or eligible RCRA corrective action. Emergency response actions shall be documented after the fact. All DDs must be included in the Administrative 

Record for the installation. 

4. Policy: Approval thresholds for DDs are described below: 

a. The Garrison Commander is the approval authority for DDs that have a selected remedy with a present worth cost estimate of $2 million or less. 

b. The Commander, U.S. Army Environmental Center (USAEC) is the approval 

authority for DDs that have a selected remedy with a present worth cost estimate of 

more than $2 million but less than or equal to $10 million. 

1 This appendix is extracted from the DASA(ESOH) memorandum, 7 Aug 03, Subject: 

Policies for Staffing and Approving Decision Documents. The words and graphics are 

from Enclosures 1 and 2. The former applies to active installations, the latter to nonBRAC excess installations.
 Staffing and Approving Decision Documents (cont) 

G-2 

c. The Assistant Chief of Staff for Installation Management (ACSIM) is the approval authority for DDs that have a selected remedy with a present worth cost estimate 

of more than $10 million. 

d. For DDs of interest to the Army Secretariat, the Deputy Assistant Secretary of 

the Army (Environmental, Safety and Occupational Health) (DASA(ESOH)) may elect to 

co-sign the DD. 

 

5. Staffing Procedures for active installations (Schematic showing the process for staffing is at TAB A): 

a. Regardless of approval level, before signing or forwarding decision documents for approval, Garrison Commanders shall staff DDs with their environmental, legal, and public affairs offices. They shall also obtain coordination from USAEC, the 

U.S. Army Center for Health Promotion and Preventive Medicine (USACHPPM), and, 

for Military Munitions Response Program (MMRP) category responses with explosive 

hazards, the U.S. Army Technical Center for Explosive Safety (USATCES). 

b. DDs with costs of more than $2 million but less than $10 million: Submit three 

copies of final DDs with an information copy to the appropriate Installation Management 

Agency (IMA) region, to USAEC, SFIM-AEC-CD, 5179 Hoadley Road, Aberdeen Proving Ground, MD 21010-5401 for regular mail or USAEC, SFIM-AEC-CD, E4480 Beal 

Road, Aberdeen Proving Ground, MD 21010-5401 for FedX, with information to the appropriate IMA region. Before signing, the Commander, USAEC will staff the DDs with 

the USAEC legal and public affairs offices and ensure that the document conforms to 

Army and Department of Defense policy and direction. 

c. DDs with costs of more than $10 million: Submit five copies of final DDs, with 

information copies to the appropriate Installation Management Agency (IMA) region and 

USAEC, to Headquarters, Department of the Army, ACSIM, ATTN: DAIM-EDC, 600 

Army Pentagon, Washington, DC 20310-0600. The Office of the Director, Environmental Programs (ODEP) will provide copies to the appropriate Headquarters, Department of the Army (HQDA) Staff elements for staffing. 

d. The staffing matrix at TAB B shall be completed and included when forwarding a DD to USAEC or ACSIM for approval. 

6. The Environmental Law Division (ELD), Office of The Judge Advocate General 

(DAJA-EL), is available to assist the installations and USAEC legal staff. If installations 

or USAEC identify legal concerns, they are encouraged to consult with ELD when staffing draft DDs. 

7. In addition to placing a copy of all signed DDs in the installation’s Administrative Record, installations shall provide one paper and one electronic copy of signed DDs to the 

the USAEC addresses stated in 5.b. In addition, the approving headquarters shall prepare a short executive summary of all signed DDs and send the executive summary via 
 Staffing and Approving Decision Documents (cont)

G-3 

email to the Chief of the Cleanup Division, ODEP; to the Assistant for Restoration, Office of the DASA(ESOH); and to the appropriate IMA Region. The executive summary 

should describe the selected response action and its relationship to other cleanup actions/operable units. It should also contain such information as the degree of risk reduction, present value cost of the remedy and the contribution to the installation cost-tocomplete for all remedies, amounts and fiscal year(s) that funds are required for remedial action design and construction, duration of any remedial action operations, land use 

controls required and means for maintaining them, and other potential remedies considered. 

8. Responsibilities: Installations and USAEC shall ensure that DDs that commit the 

Army to future expenses pass the following checks: 

a. The project must be DERP eligible per reference 1c. 

b. The Installation Action Plan contains funding for the project(s), and the costs 

are accurately described in the installation’s Cost-to-Complete report. USAEC, as program manager, must ensure that adequate funding exists within the President's Budget 

(budget years) and Future Year Defense Plan (program years) to support the project(s). 

c. The project(s) are consistent with priorities for relative risk reduction as set 

forth in program guidance. 

9. Suspense: 

a. Transmittal memoranda should advise the chain of command of any negotiated or imposed deadlines and allow sufficient time for staffing at each level. To assist 

in planning, TAB A provides the time required for staffing at each stage. . Installations 

or USAEC should plan on a minimum of two to four weeks to obtain approval after receipt of a complete DD packet at HQDA. They should also ensure regulators are aware 

of these time constraints during negotiations. 

b. In situations when an Interagency Agreement or Federal Facilities Agreement 

deadline might be missed because of staffing requirements for DDs over $10 million: 

(1) The USAEC restoration manager should convene a conference call 

with the installation, U.S. Army Corps of Engineer district (when appropriate), and 

ODEP representatives. 

(2) The conference call should result in an understanding of any deadlines 

and if and how the process will be expedited. 

(3) The installation should send, via e-mail (PDF file format for smaller 

documents) or overnight or next day commercial delivery, a copy of the final DD to 

ODEP to initiate the HQDA staffing process. 
 Staffing and Approving Decision Documents (cont) 

G-4 

10. Changes: 

a. Garrison Commanders may approve Explanation of Significant Differences 

(ESD) and ROD amendments for RODs that were originally approved by USAEC or 

ACSIM, if the ESD or ROD amendment does not increase the cost of the project by 

more than $2 million. Those ESD and ROD amendments that increase the cost of the 

project by more than $2 million will be forwarded to USAEC (increase of more than $2 

million but less than $10 million) or ACSIM (increase of more than $10 million), as appropriate, for approval in accordance with paragraph 5 above. 

b. The actual cost of the remedy may exceed the authority of the original approval authority (e.g., $1.5 million ROD approved by garrison commander; actual cost 

exceeds $2 million) due to, for example, a change in project scope or remedies cost. In 

that circumstance, the installation shall provide the next higher-level approval authority 

(USAEC or the ACSIM, as appropriate) information regarding the original scope and 

cost of the project and the nature, extent, and costs of any changes thereto. 

11. This guidance supersedes all previous guidance on this subject, including that in 

references 1a and 1b, and will be in effect until these references are revised and incorporate this guidance. 
 Staffing and Approving Decision Documents (cont)

G-5 
 Staffing and Approving Decision Documents (cont) 

G-6 

1. References: 

a. DA Pamphlet 200-1, January 2002. 

b. Base Realignment and Closure Program Management Plan, April 1999. 

c. Installation Restoration Program Management Plan, March 1999. 

d. Management Guidance for the Defense Environmental Restoration Program 

(DERP), ODUSD (I&E), 28 September 2001. 

2. This policy applies to decision documents (DD), including Records of Decision 

(ROD), Interim RODs, Action Memoranda, and Statements of Basis for response or corrective actions taken in accordance with the Comprehensive Environmental Response, 

Compensation, and Liability Act (CERCLA); the National Contingency Plan; Executive 

Order 12580; and the Resource Conservation and Recovery Act (RCRA). 

3. Decision documents are required to document response or corrective actions that 

are DERP eligible per reference 1c, including interim remedial actions, remedial actions, 

removals, or implementation of land use controls that Army imposes as part of a remedy 

to address a CERCLA risk or eligible RCRA corrective action. Emergency response actions shall be documented after the fact. All DDs must be included in the Administrative 

Record for the installation. 

4. Policy: Approval thresholds for DDs are described below: 

a. The Chief, BRAC FO is the approval authority for DDs that have a selected 

remedy with a present worth cost estimate of $2 million or less. 

b. The Chief, Base Realignment and Closure (BRAC) Division (DAIM-BD) is the 

approval authority for DDs that have a selected remedy with a present worth cost estimate of more than $2 million but less than or equal to $10 million. The Chief, BRAC Division may delegate this approval authority for Installation Restoration Program 

category responses to the Chiefs of BRAC Field Offices (FO) with the concurrence of 

the Deputy Assistant Secretary of the Army (Environment, Safety and Occupational 

Health) (DASA(ESOH)). Approval authority for DDs for Military Munitions Response 

Program category responses may not be delegated. 

c. The Assistant Chief of Staff for Installation Management (ACSIM) is the approval authority for DDs that have a selected remedy with a present worth cost estimate 

of more than $10 million. 

d. For DDs of interest to the Army Secretariat, the DASA(ESOH) may elect to 

co-sign the DD. 
 Staffing and Approving Decision Documents (cont)

G-7 

5. Staffing Procedures for BRAC and excess installations (Schematic showing the 

process for staffing is at TAB A): 

a. Regardless of approval level, before signing or forwarding decision documents for approval, the Chief, BRAC FO shall staff DDs with their environmental, legal, 

and public affairs offices. They shall also obtain coordination from USAEC, the U.S. 

Army Center for Health Promotion and Preventive Medicine (USACHPPM), and, for Military Munitions Response Program (MMRP) category responses with explosive hazards, 

the U.S. Army Technical Center for Explosive Safety (USATCES). 

b. DDs with costs of more than $2 million requiring ACSIM or Chief, BRAC Division approval: Submit six copies of final DDs through the appropriate BRAC FO, with 

an information copy to the appropriate Installation Management Agency (IMA) region, to 

Headquarters, Department of the Army, ACSIM, ATTN: DAIM-BD, 600 Army Pentagon, 

Washington, DC 20310-0600. The DAIM-BD will provide copies to the appropriate 

Headquarters, Department of Army (HQDA) Staff elements for staffing. 

c. The staffing matrix at TAB B shall be completed and included when forwarding a DD to the Chief, BRAC Division or ACSIM for approval. 

d. Chief, BRAC FO shall provide information copies of all DDs being staffed to 

the appropriate supporting Garrison Commander. 

6. The Environmental Law Division (ELD), Office of The Judge Advocate General 

(DAJA-EL) is available to assist the installations and BRAC FO's legal staffs. If installations or BRAC FOs identify legal concerns, they are encouraged to consult with ELD 

when staffing draft DDs. 

7. In addition to placing a copy of all signed DDs in the installation’s Administrative Record, installations shall provide one paper and one electronic copy of signed DDs to the 

Commander, USAEC, ATTN: SFIM-AEC-ER, Aberdeen Proving Ground, MD 21010-

5401. In addition, the approving headquarters shall prepare a short executive summary 

of all signed DDs and send the executive summary via email to the Chief of the Cleanup 

Division, Office of the Director of Environmental Programs (ODEP); to the Assistant for 

Restoration, Office of the DASA(ESOH); and to the appropriate supporting garrison and 

IMA Region. The executive summary should describe the selected response action and 

its relationship to other cleanup actions/operable units. It should also contain such information as the degree of risk reduction, present value cost of the remedy and the contribution to the installation cost-to-complete for all remedies, amounts and fiscal year(s) 

that funds are required for remedial action design and construction, duration of any remedial action operations, land use controls required and means for maintaining them, 

and other potential remedies considered. 

8. Responsibilities: BRAC and excess installations and BRAC FOs shall ensure that 

DDs that commit the Army to future expenses pass the following checks: 
 Staffing and Approving Decision Documents (cont) 

G-8 

a. The project must be DERP eligible per reference 1d. 

b. The BRAC Cleanup Plan for BRAC installations or the Installation Action Plan 

for excess installations contains funding for the project(s), and the costs are accurately 

described in the installation’s Cost-to-Complete report. DAIM-BD as program manager 

for BRAC Cleanup Account funds must ensure that adequate funding exists within the 

President's Budget (budget years) and Future Year Defense Plan (program years) to 

support the project(s). 

c. The project(s) are consistent with priorities for relative risk reduction and 

property transfer as set forth in program guidance. 

9. Suspense: 

a. Transmittal memoranda should advise the chain of command of any negotiated or imposed deadlines and allow sufficient time for staffing at each level. To assist 

in planning, TAB A provides the time required for staffing at each stage. BRAC and excess installations and BRAC FO should plan on a minimum of two to four weeks to obtain approval after receipt of a complete DD packet at HQDA. They should also ensure 

regulators are aware of these time constraints during negotiations. 

b. For Fast Track Cleanup or in situations when an Interagency Agreement or 

Federal Facilities Agreement deadline might be missed because of staffing requirements for DDs with costs over $10 million: 

(1) The BRAC FO should convene a conference call with the USAEC restoration manager and installation, U.S. Army Corps of Engineer district (when appropriate), and DAIM-BD representatives. 

(2) The conference call should result in an understanding of any deadlines 

and if and how the process will be expedited. 

(3) The BRAC and excess installation should send, via e-mail (PDF file 

format for smaller documents) or overnight or next day commercial delivery, a copy of 

the final DD to DAIM-BD to initiate the HQDA staffing process. 

10. Changes: 

a. BRAC FO chiefs may approve Explanation of Significant Differences (ESD) 

and ROD amendments for RODs originally approved by HQDA, if the ESD or ROD 

amendment does not increase the cost of the project by more than $2 million. Those 

ESDs or ROD amendments that that increase the cost of the project by more than $2 

million shall be forwarded to DAIM-BD or ACSIM, as appropriate, for approval in accordance with paragraph 5 above. 
 Staffing and Approving Decision Documents (cont)

G-9 

b. The actual cost of the remedy may exceed the authority of the original approval 

authority (e.g., $1.5 million ROD approved by BRAC FO; actual cost exceeds $2 million) due to, for example, a change in project scope or remedy cost. In that circumstance, the BRAC FO shall provide the next higher-level approval authority (DAIMBD or ACSIM, as appropriate) information regarding the original scope and cost estimate of the project and the nature, extent, and costs of any changes thereto. 

11. This guidance supersedes all previous guidance on this subject, including that in 

references 1a, 1b, and 1c and will be in effect until these references are revised and incorporate this guidance. 
 Staffing and Approving Decision Documents (cont) 

G-10 
 Staffing and Approving Decision Documents (cont)

G-11 

 STAFFING MATRIX FOR DECISION DOCUMENTS

DECISION DOCUMENT TITLE: 

ORGANIZATION STAFF ACTIVITY POC NAME

OFFICE 

SYMBOL

PHONE 

NUMBER FAX NUMBER E-MAIL

INSTALLATION ENVIRONMENT

LEGAL 

PUBLIC AFFAIRS

CHPPM

1

For MMRP USAEC

 w/explosives risk

USATCES1

BRAC FO2 ENVIRONMENT

2 For BRAC & excess LEGAL 

 installations

PUBLIC AFFAIRS

USAEC3 ENVIRONMENT

3 For Active (operational) LEGAL 

 installations PUBLIC AFFAIRS

HQDA ODEP DAIM-EDC 703-601-0599 703-602-0857 firstname.lastname@hqda.army.mil

TJAG DAJA-EL 703-696-1230 703-696-2940 firstname.lastname@hqda.army.mil

ARMY PUBLIC 

AFFAIRS SAPA-PD 703-693-5591 703-693- firstname.lastname@hqda.army.mil

OTSG DASG-HS 703-681-3130 703-681-3163 firstname.lastname@otsg.amedd.army.mil

ODASA(ESOH) SAIE-ESOH 703-697-1987 703-604-2344 firstname.lastname@hqda.army.mil

BRACD2 DAIM-BD 703-601-1911 703-614-1568 firstname.lastname@hqda.army.mil

ARMY SAFETY OFF1 SAIE-ESOH 703-697-3123 703-614-5822 firstname.lastname@hqda.army.mil

TAB B to Enclosures 1 and 2

 

H-1 

Appendix H 

Army DERP Cleanup Program Goals 

Army DERP Cleanup Program Goals are ultimately derived from the the Army Environmental Cleanup Strategy (AECS). The AECS identifies overarching objectives to create 

consistency and accountability across the Army’s cleanup programs. A Strategic Plan for 

each program identifies specific objectives, targets, success indicators, reporting mechanisms, and management review processes for each program area identified in AECS. 

Overarching Vision 

for Army 

Environmental 

Cleanup 

The Army will be a national leader in cleaning 

up contaminated land 

to protect human health 

and the environment as 

an integral part of its 

mission.

Army Environmental Cleanup Strategy 

The Army’s environmental cleanup vision statement communicates the Army’s commitment to correct contamination 

of the environment for which the Army is responsible. 

From the vision statement, the Army develops a strategy 

that sets the stage for development of a strategic plan that 

is consistent with the principles of an Environmental Management System (ISO 14001) in the Army’s cleanup programs. 

Army Cleanup Strategic Plan

Key elements of the Strategic Plan are:

Objectives: Specific outcomes that need to be accomplished within each of the cleanup program areas. 

Targets: The desired time or event milestones for achieving the objectives. 

Success Indicators: The specific measures of success in accomplishing the objectives. 

Reporting Mechanisms: Collecting, performing quality control, maintaining, and reporting 

data. 

Management Review: The procedures for ensuring that the objectives are sustained. 
 Army DERP Cleanup Program Goals (cont) 

H-2 

The cleanup program areas addressed in this strategic plan include cleanup efforts that have been 

conducted separately under the defense environmental restoration program (DERP), the base realignment and closure (BRAC) and compliance programs. The figure below depicts the differences and commonalities between the cleanup program areas. 

Defense Environmental 

Restoration Program 

(DERP)

Compliance-Related 

Cleanup

Army Environmental Cleanup Program Areas

Formerly Used

Defense Sites

(ER, FUDS)

Remediation Overseas (OMA)

Base Realignment and Closure (BRAC)

BRAC ’88 BRAC ’91 BRAC ’93 BRAC ’95 Future BRAC

Active Installations

Excess Installations

(ER,A) Special Installations (OMA, Mission, AWCF) 

Military 

Munitions 

Response 

Program 

(MMRP)

(ER,A &

MILCON)

ER,A OMA

(MILCON)

The Army has identified Army DERP cleanup program goals within the Army Cleanup Strategy 

and corresponding Strategic Plan. These additional goals and metrics provide direction for implementing a cost efficient program. The Strategic Plan is updated on a bi-annual basis. The 

current Army DERP cleanup program goals and objectives within the Army Cleanup Strategic 

Plan can be found at the USAEC Website at: http://aec.army.mil/usaec/cleanup/index.html 
 

I-1 

Appendix I 

Available DERP Guidance 

1. Management Guidance for the Defense Environmental Restoration Program, Office of the Deputy Under Secretary of Defense, March 1998. Internet http://www.dtic.mil/envirodod/Policies/PDDERP.htm 

2. AR 200-1, Environmental Quality: Environmental Protection and Enhancement. 21 February 1997. Internet 

http://www.army.mil/usapa/epubs/index.html

3. AR 200-2, Environmental Quality: Environmental Effects of Army Actions, Department of the Army, 1988. 

http://www.army.mil/usapa/epubs/index.html

4. DAPam 200-1, Environmental Quality: Environmental Protection and Enhancement. Department of the Army, 

17 January 2002. Internet http://www.usapa.army.mil/gils.

5. US Army Environmental Restoration Programs Guidance Manual, US Army Environmental Center, April 1998. 

Internet http://www.denix. osd.mil/denix/Public/Policy/Army/ERP/erptoc.html

6. The Final Report of the Federal Facilities Environmental Restoration Dialogue Committee (FFERDC), US Environmental Protection Agency, April 1996. Internet at http:/ www.epa.gov swerffrr/ferdcrpt /toc.htm 

7. Websites:

Defense Environmental Restoration Program (DERP) Report to Congress. Online copy of the 1994 

through 2003 DERP Reports to Congress. http://www.dtic.mil/envirodod/DERP/DERP.htm

DoD Environmental Cleanup Home Page. Up-to-date information on the DoD cleanup program. 

http://www.dtic.mil/envirodod/COffice/CleanupO.htm

U.S. Army Corps of Engineers (USACE) Environmental Division. General information on USACE. 

htpp://hq.environmental.usace.army.mil/ 

Office of the Director of Environmental Programs – Army. General information on ODEP. 

http://www.hqda.army.mil/acsimweb/env/

US Army Environmental Center (USAEC). General information on USAEC. http://aec.army.mil 

Toxic Substances and Disease Registry (ATSDR) 

1. Memorandum, HQDA, DASA(ESOH), 20 Mar 98, subject: Agency for Toxic Substances and Disease Registry 

(ATSDR) Program Management Plan. 
Available DERP Guidance (cont) 

I-2 

2. Guidelines for the Coordination of Comprehensive Environmental Response, Compensation, and Liability Act 

(CERCLA) Activities between the Agency for Toxic Substances and Disease Registry and the Department of Defense, Office of the Deputy Under Secretary of Defense, February 1995. 

 

3. OSWER Directive 9285.4-02, Guidance for Coordinating ATSDR Health Assessment Activities with the Superfund Remedial Process, US Environmental Protection Agency, March 1987. 

Community Involvement 

1. US Army Restoration Advisory Board and Technical Assistance for Public Participation, US Army Environmental Center, April 1998. Internet http://www.denix.osd.mil/denix/ Public/Policy/Army/ 

IRP/rabapr98.html

 

2. Restoration Advisory Board (RAB) Resource Book, Office of the Deputy Under Secretary of Defense September 

1996. Internet http://www.dtic.mil/envirodod/Policies/RAB/rab_res_book.html 

3. Memorandum, ASA(IL&E), 7 May 96, subject: Issuance of Policy – The Role of Restoration Advisory Boards 

(RABs) in Environmental Cleanup. 

4. Restoration Advisory Board (RAB) Implementation Guidelines, Office of the Deputy Under Secretary of Defense, 

and the US Environmental Protection Agency, September 1994. Internet 

http://www.dtic.mil/envirodod/Policies/RAB/rab_finalrab.htm. 

5. OSWER Directive 9230.0-20, Innovative Methods to Increase Public Involvement in Superfund Community Relations, US Environmental Protection Agency, November 1990. 

6. AR 360-1, The Army Public Affairs Program, September 2000

http://www.army.mil/usapa/epubs/pdf/r360_1.pdf.

7. Websites: 

RAB Information Home Page. Provides a list of publications and information about RABs. 

http://www.dtic.mil/envirodod/Stakeholder/WCommunity/SI_WCRAB.htm 

Cost Estimating 

1. “Developing Cost-to-Complete Estimates & Financial Reporting of Environmental Restoration Liabilities 

for the U.S. Army Environmental Restoration Program”, January 2002. 

2. EPA/542/B-95/002, Guide to Documenting Cost and Performance for Remediation Projects, Federal Remediation Technologies’ Roundtable, US Environmental Protection Agency, March 1995. 

Decision Documents/Records of Decision 

1. Interim Guidance on Environmental Restoration Records of Decision, Office of the Under Secretary of Defense, 

4 June 2002. 

2. Memorandum, DASA(ESOH), 7 Aug 03, Subject: Policies for Staffng and Approving Decision Documents. 
Available DERP Guidance (cont) 

I-3 

3. EPA/540/G-89/007, OSWER Directive 9355.3-02, Guidance for Preparing Superfund Decision Documents; The 

Proposed Plan, The Record of Decision, Explanation of Significant Differences, and The Record of Decision 

Amendment (Interim Final), US Environmental Protection Agency, July 1989. 

Defense State Memorandum of Agreement (DSMOA) 

Working Together to Achieve Cleanup: A Guide to the Cooperative Agreement Process, US Army Corps of Engineers, 22 August 1997. Internet http://www.mrd.usace.army.mil/mrded-h/access/DSMOA/ dsmoa.html 

Environmental Justice 

1. Strategy on Environmental Justice, Office of the Under Secretary of Defense, 24 March 1995. Internet at http:/ 

www.denix.osd.mil/denix/Public/Library/Planning/Justice/note7.html

2. Federal Facilities Agreement/Inter-Agency Agreement at NPL Installations

3. Memorandum, Office of the Assistant Secretary of Defense, 18 Apr 88, subject: DoD's Policy on NPL Site 

Agreements. 

Environmental Restoration Information System (ERIS) 

1. Memorandum, ACSIM, 17 Feb 99, Subject: Policy On Electronic Storage Of Environmental Restoration Data. 

2. Memorandum, ACSIM, 12 Nov 03, subject: Implementation Guidance for the Use of the ERIS. 

Five-Year Reviews 

1. Guidance for US Army Compliance with CERCLA Five-Year Review Requirements at Army Installations, US 

Army Environmental Center 17 July 1998. 

2. OSWER Directive 9355.7-03A, Second Supplemental Five-Year Review Guidance, US Environmental Protection Agency, 21 December 1995. 

3. OSWER Directive 9355.7-02A, Supplemental Five-Year Review Guidance, US Environmental Protection 

Agency, 26 July 1994. 

4. OSWER Directive 9355.7-02, Structure and Components of Five-Year Reviews, US Environmental Protection 

Agency, 23 May 1991. 

Land Use Controls 

1. Interim Notification Guidance on Documenting and Reviewing Land Use Controls (LUCs) developed under the 

Army Environmental Restoration Program, Assistant Chief of Staff for Installation Management, 25 April 2002.

2. Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) Record of Decision (ROD) 

and Post-ROD Policy, Deputy Assistant Secretary of the Army (Environment, Safety and Occupational Health 

(DASA(ESOH)), 2 March 2004. 

Natural Attenuation 

Memorandum, HQDA(DAIM-ED), 19 Oct 93, subject: Interim Army Policy on Natural Attenuation for Environmental Restoration. 
Available DERP Guidance (cont) 

I-4 

Property Transfer 

1. Memorandum, USEPA, 16 Jun 98, subject: EPA Guidance on the Transfer of Federal Property by Deed Before 

All Necessary Remedial Action Has Been Taken Pursuant to CERCLA Section 120(h)(3). 

2. Memorandum, HQDA(SAAL-ZA), 24 Apr 98, subject: Environmental Review Process to Obtain the Finding of 

Suitability Required for Use of Early Transfer Authority for Property Not on the National Priorities List. 

3. Memorandum, HQDA(SAAL-ZA), 25 Jul 97, subject: Responsibility for Additional Environmental Cleanup 

After Transfer of Real Property. 

4. Memorandum, HQDA(DAIM-BD), 9 Dec 96, subject: Clarification of Meaning of Uncontaminated Property for 

Purposes of Transfer by the United States. 

5. Memorandum, HQDA(DAIM-BD), 31 May 96, subject: Guidance for Leasing of BRAC Properties. 

6. Memorandum, HQDA(DAIM-BD), 23 Apr 96, subject: Army Policy on Consideration of Future Land Use in 

Determining Cleanup Standards for Base Realignment and Closure (BRAC) Property. 

7. Fast Track To FOST, Interim Final, Office of the Deputy Under Secretary of Defense (Environmental Security), 

February 1995. 

8. Memorandum, HQDA(DAIM-ED), 23 Aug 95, subject: Implementing Guidance for Signature Authority and 

Staffing Procedures for Finding of Suitability to Transfer/Lease (FOST/FOSL)

9. Memorandum, HQDA(DAIM-ED), 11 Apr 94, subject: Use of Environmental Baseline Surveys (EBSs)- Transfer 

Policy Memorandum. 

Radiological Surveys 

1. Memorandum, USAMC, 17 Apr 98, subject: Radiological Survey Policy for US Army Materiel Command 

(AMC) Radioactive Commodity Base Realignment and Closure (BRAC) Sites. 

2. NUREG-1575/EPA 402-R-97-016, USEPA, December 1997, Multi-Agency Radiation Survey and Site Investigation Manual. Internet http:www.epa.gov/radiation/marssim 

3. Memorandum, HQDA(DAIM-BD), 25 Mar 94, subject: Radiologic Contamination on Base Realignment and 

Closure (BRAC) Installations. 

4. NUREG/CR-5512, US Nuclear Regulatory Commission, October 1992, subject: Residual Radioactive Contamination From Decommissioning, Technical Basis for Translating Contamination Levels to Annual Effective Dose 

Equivalent. 

5. NUREG/CR-5849, US Nuclear Regulatory Commission, Manual for Conducting Radiological Surveys in Support of License Termination, June 1992. 

6. Risk Assessment Guidance for Superfund, Volume 1: Human Health Evaluation Manual, Chapter 10, US Environmental Protection Agency, September 1989. 

7. AR 385-11, Ionizing Radiation Protection (Licensing, Control, Transport, Disposal, and Radiation Safety), 1 

May 1980. 

Relative Risk 

1. DoD Relative Risk Site Evaluation Quality Assurance Plan, Office of the Deputy Under Secretary of Defense 

(Environmental Security), Summer 1997. Internet http://www.dtic.mil/ envirodod/relrisk/ qapage.html

2. DoD Relative Risk Site Evaluation Primer, Office of the Deputy Under Secretary of Defense (Environmental 

Security), Summer 1997. Internet: http://www.dtic.mil/envirodod/relrisk/relrisk.html
Available DERP Guidance (cont) 

I-5 

Unexploded Ordnance 

1. AR 385-64, US Army Explosives Safety Program. www.usapa.army.mil/pdffiles/r385_64.pdf. 

2. DA PAM 385-64, US Army Explosives Safety Program. 

3. ER 385-1-92, Safety and Occupational Health Requirements for Hazardous, Toxic, and Radioactive Waste 

(HTRW) Activities, US Army Corps of Engineers.

4. EM 200-1-2, Technical Project Planning, US Army Corps of Engineers.

5. EP 385-1-95b, Explosives Safety Submission, US Army Corps of Engineers.

6. Interim Final Management Principles for Implementing Response Actions at Closed, Transferring, and Transferred (CTT) Ranges, DoD and EPA 2000, 7 March 2000. www.dtic.mil/envirodod/Policies/MMR/UXO-MgtPrin.htm. 

7. EPA 505-B-01-001, Handbook on the Management of Ordnance and Explosives at Closed, Transferred, and 

Transferring Ranges, Draft, Interim Final February 2002. 

8. AR 385-10, “The Army Safety Program,” EPA, 29 February 2001. www.usapa.army.mil/pdffiles/r385_10.pdf. 

9. Department of Defense Explosive Safety Board (DDESB) DoD 6055.9-STD, “DoD Ammunition and Explosives Safety Standards” 

 

J-1 

Appendix J 

Abbreviations and Acronyms 

ACSIM Assistant Chief of Staff for Installation Management 

AEDB-R Army Environmental Database-Restoration 

AR Army Regulation 

ARAR Applicable or Relevant and Appropriate Requirement 

ARID Army Range Inventory Database 

ASA(I&E) Assistant Secretary of the Army (Installations and Environment) 

ATSDR Agency for Toxic Substances and Disease Registry 

BD/DR Building Demolition and Debris Removal 

BES Budget Estimate Submission 

BRAC Base Realignment and Closure 

CA Cooperative Agreement 

CERCLA Comprehensive Environmental Response, Compensation and Liability Act 

CFR Code of Federal Regulations 

CMS Corrective Measures Study 

CRP Community Relations Plan 

CTC Cost to Complete 

CWM Chemical Warfare Materiel 

DA Department of the Army 

DASA(ESOH) Deputy Assistant Secretary of the Army for Environment, Safety and Occupational Health 

DD Decision Document 

DDESB Department of Defense Explosives Safety Board 

DEH Directorate of Engineering and Housing 

DEP Director of Environmental Programs 

DERP Defense Environmental Restoration Program

DoD Department of Defense 

DODI Department of Defense Instruction 

DOE Department of Energy 

DOJ Department of Justice 

DPW Directorate of Public Works 

DMM Discarded Military Munitions 

DPG Defense Planning Guidance 
J-2 

DSERTS Defense Site Environmental Restoration Tracking System 

DSMOA Defense and State Memoranda of Agreement 

DUSD(I&E) Deputy Under Secretary of Defense, Installations and Environment 

EBS Environmental Baseline Survey 

EC Engineering Controls 

EPAS Environmental Performance Assessment System 

EE/CA Engineering Evaluation and Cost Analysis 

ELD Environmental Law Division 

EO Executive Order 

EOD Explosive Ordnance Disposal 

 

ER,A Environmental Restoration, Army 

ERIS Environmental Information System 

ERM Environmental Restoration Manager 

ERP Environmental Restoration Program 

ESA Environmental Site Assessment 

ESD Explanation of Significant Differences 

ESS Explosive Safety Submission 

FFA Federal Facility Agreement 

FFERDC Federal Facilities Environmental Restoration Dialogue Committee 

FMR Financial Management Regulation 

FOA Field Operating Agency 

FO Field Offices 

FOST Finding of Suitability to Transfer 

FS Feasibility Study 

FUDS Formerly Used Defense Sites 

FY Fiscal Year 

GWETER Groundwater Extraction and Treatment Effectiveness Review 

HQ Headquarters 

HQDA Headquarters Department of the Army 

HTRW Hazardous, Toxic and Radiological Waste 

IAG Interagency Agreement 

IAP Installation Action Plan 

IC Institutional Controls 

IGCE Independent Government Cost Estimate 

IMA Installation Management Agency 

IPR In-Process Review 
J-3 

IRA Interim Remedial Action 

IRP Installation Restoration Program

ITR Independent Technical Review 

LTM Long-term Management 

LUC Land Use Control 

MACOM Major Army Command 

MC Munitions Constituents 

MEC Munitions and Explosives of Concern 

MGFD Munitions with Greatest Fragmentation Distance 

MILCON Military Construction 

MMRP Military Munitions Response Program 

MOM Measure of Merit 

MOU Memorandum of Understanding 

MPPEH Material Potentially Presenting an Explosive Hazard 

MSD Minimum Separation Distance 

MRA Munitions Response Area 

MRS Munitions Response Site 

NCP National Oil and Hazardous Substances Pollution Contingency Plan 

NFA No Further Action 

NGB National Guard Bureau 

NDAA National Defense Authorization Act 

NPL National Priorities List 

NRI Natural Resource Injury 

O&M Operations and Maintenance 

OB Open Burn 

OD Open Detonation 

 

ODEP Office of the Director of Environmental Programs 

ODUSD(I&E) Office of the Deputy Under Secretary of Defense for Installations and Environment 

OTJAG Office of The Judge Advocate General 

PA/SI Preliminary Assessment/Site Inspection 

PAED Public Access Exclusion Distance 

PAM Pamphlet 

PBC Performance-Based Contract 

PC Program Coordinator 

PER Principles of Environmental Restoration 
J-4 

POM Program Objective Memorandum 

POL Petroleum, oil, and lubricants 

RA Remedial Action 

RAB Restoration Advisory Board 

RA(C) Remedial Action – Construction 

RA(O) Remedial Action (Operations) 

RAC Risk Assessment Code 

RACER Remedial Action Cost Engineering and Requirements 

RC Response Complete 

RCRA Resource Conservation and Recovery Act 

RCTCS Restoration Cost-to-Complete System 

RD Remedial Design 

RI/FS Remedial Investigation/Feasibility Study 

RIP Remedy-In-Place 

RMIS Restoration Management Information System 

ROD Record of Decision 

RPM Remedial Project Manager 

RRSE Relative Risk Site Evaluation 

RSC Regional Support Command 

RSP Render Safe Procedures 

SARA Superfund Amendments and Reauthorization Act of 1986 

SB Statement of Basis 

SWMU Solid Waste Management Unit 

TEU Technical Escort Unit 

TIM Transformation of Installation Management 

TRC Technical Review Committee 

TRCA Time Critical Removal Action 

TSD Team Separation Distances 

USACE US Army Corps of Engineers 

USACHPPM US Army Center for Health Promotion and Preventive Medicine 

USAEC US Army Environmental Center 

USATCES US Army Technical Center for Explosives Safety 

USC United States Code 

USEPA US Environmental Protection Agency 

UXO Unexploded Ordnance 

www World Wide Web 
 

ASSISTANT CHIEF OF STAFF FOR INSTALLATION MANAGEMENT

 

Army Defense Environmental 

Restoration Program: 

Management Guidance for 

Base Realignment and 

Closure (BRAC) 

Installations 

NOVEMBER 2004 

Enclosure 2 

 i 

PREFACE 

Introduction.................................................................................................................i 

Summary Of Recent Changes To The Army BRAC Program.................................. i 

MILITARY MUNITIONS RESPONSE PROGRAM (MMRP) .............................................................. i 

TRANSFORMATION OF INSTALLATION MANAGEMENT (TIM)...................................................... i 

ARMY CLEANUP STRATEGY AND STRATEGIC PLAN.................................................................... i 

ARMY ENVIRONMENTAL DATABASE-RESTORATION (AEDB-R) ................................................ i 

COST-TO-COMPLETE (CTC) ...................................................................................................... ii 

RECORDS OF DECISION (ROD)/DECISION DOCUMENT (DD) APPROVAL ................................... ii 

ERIS AND ELECTRONIC DATA STORAGE .................................................................................. ii 

PERFORMANCE-BASED CONTRACTING (PBC) ........................................................................... ii 

LAND USE CONTROLS (LUCS)................................................................................................... ii 

FIVE-YEAR REVIEWS ................................................................................................................. ii

1.0 PURPOSE AND APPLICABILITY ........................................................... 1-1 

2.0 BACKGROUND ......................................................................................... 2-1 

2.1 DEFENSE ENVIRONMENTAL RESTORATION PROGRAM (DERP) .................................. 2-1 

2.2 BRAC ENVIRONMENTAL RESTORATION PROGRAM (ERP)......................................... 2-3 

2.2.1 BRAC ERP Eligibility ......................................................................................... 2-3 

2.2.2 BRAC Program Coordination.............................................................................. 2-4 

2.2.3 Fast Track Cleanup .............................................................................................. 2-4 

2.2.4 NATIONAL ENVIRONMENTAL POLICY ACT (NEPA) 

Documentation..................................................................................................... 2-5 

2.2.5 Cultural/Natural Resource Considerations .......................................................... 2-6 

2.3 THE ARMY MILITARY MUNITIONS RESPONSE PROGRAM (MMRP) CATEGORY 

WITHIN ARMY DEFENSE ENVIRONMENTAL RESTORATION PROGRAM

(DERP)....................................................................................................................... 2-6 

2.4 BUILDING DEMOLITION AND DEBRIS REMOVAL PROGRAM (BD/DR) ........................ 2-7 

3.0 ROLES AND RESPONSIBILITIES........................................................... 3-1 

3.1 DEPARTMENT OF THE ARMY (DA).............................................................................. 3-1 

3.2 REGULATORY AGENCIES ............................................................................................ 3-3 

3.3 LOCAL COMMUNITY ................................................................................................... 3-3 
 

 ii 

3.4 OTHER STAKEHOLDERS .............................................................................................. 3-4 

4.0 PROGRAM DEVELOPMENT AND MANAGEMENT ........................... 4-1 

4.1 PROGRAM GOALS AND OBJECTIVES............................................................................ 4-1 

4.2 PROGRAM IMPLEMENTATION ...................................................................................... 4-1 

4.2.1 Environmental Baseline Survey (EBS)................................................................ 4-2 

4.2.2 BRAC Cleanup Action Plan (BCP) ..................................................................... 4-3 

4.2.3 Army Environmental Database-Restoration (AEDB-R) .................................... 4-4 

4.2.4 Relative Risk Site Evaluations (RRSE) and Risk Assessment Code 

(RAC)................................................................................................................... 4-6 

4.2.5 Cost-to-Complete (CTC) ..................................................................................... 4-8 

4.2.5.1 CTC ESTIMATES................................................................................... 4-9 

4.2.5.2 COMPUTER MODELS........................................................................... 4-11 

4.2.5.3 CTC REVISIONS ................................................................................. 4-11 

4.2.5.4 CTC AUDITS ...................................................................................... 4-12 

4.2.5.5 CTC TRAINING................................................................................... 4-13 

4.3 BUDGETING .............................................................................................................. 4-13 

4.4 FUNDING BRAC ACTIVITIES .................................................................................... 4-14 

4.4.1 Funding Categories ............................................................................................ 4-15 

4.4.2 BRAC Work Plan .............................................................................................. 4-16 

4.4.2.1 PREPARATION OF THE BRAC WORK PLAN ........................................ 4-17 

4.4.2.2 ADDITIONS TO THE BRAC WORK PLAN............................................. 4-17 

4.4.2.3 BRAC WORK PLAN REVIEWS............................................................ 4-17 

4.4.3 Priority Setting and Sequencing......................................................................... 4-17 

4.4.3.1 PROGRAM PRIORITIES......................................................................... 4-17 

4.4.3.2 SEQUENCING WORK ........................................................................... 4-18 

4.4.4 Funds Distribution ............................................................................................. 4-18 

4.4.5 Tracking and Reporting ..................................................................................... 4-19 

4.4.5.1 OBLIGATION....................................................................................... 4-19 

4.4.5.2 DISBURSEMENT .................................................................................. 4-19 

4.4.6 Reimbursement for Non-Army Activities ......................................................... 4-19 

4.4.7 Cost Recovery and Cost Sharing ....................................................................... 4-20 

4.5 EXECUTION STRATEGY ............................................................................................. 4-21 
Table of Contents 

 iii 

4.5.1 Obligation Goals ................................................................................................ 4-21 

4.5.2 Financial Management Regulation (FMR) Goals.............................................. 4-21 

4.5.3 Army Cleanup Strategy Goals for BRAC.......................................................... 4-21 

4.5.4 Disbursement Goals........................................................................................... 4-22 

4.5.5 Program Management Goals.............................................................................. 4-22 

4.6 PERFORMANCE MEASURES ....................................................................................... 4-22 

4.6.1 Work Plan Review ............................................................................................. 4-22 

4.6.2 Department of Defense (DoD) Management Review........................................ 4-23 

4.6.3 Measures of Merit (MOMs)............................................................................... 4-23 

4.6.4 DEFENSE ENVIRONMENTAL RESTORATION PROGRAM (DERP) 

Annual Report to Congress................................................................................ 4-24 

4.7 PROGRAM TIMELINES ............................................................................................... 4-24 

5.0 PROGRAM EXECUTION.......................................................................... 5-1

5.1 INSTALLATION ............................................................................................................ 5-1 

5.2 BRAC CLEANUP TEAM (BCT) ................................................................................... 5-3 

5.3 BRAC ENVIRONMENTAL RESTORATION PROGRAM (ERP) EXECUTOR ....... 5-4 

5.4 US ARMY ENVIRONMENTAL CENTER (USAEC)......................................................... 5-5 

5.4.1 Technical Review and Assistance........................................................................ 5-5 

5.4.2 Restoration Oversight .......................................................................................... 5-5 

5.4.3 HQDA Support .................................................................................................... 5-5 

5.4.4 Environmental Restoration Managers (ERMs).................................................... 5-5 

5.5 US ARMY CENTER FOR HEALTH PROMOTION AND PREVENTIVE MEDICINE 

(USACHPPM) ........................................................................................................... 5-7 

5.6 BRAC DIVISION AND BRAC FIELD OFFICES (FO)..................................................... 5-7 

5.7 US ARMY TECHNICAL CENTER FOR EXPLOSIVE SAFETY (USATCES) ...................... 5-7 

6.0 PROGRAM PROCEDURES ...................................................................... 6-1 

6.1 DECISION DOCUMENTS (DD) (DDS)........................................................................... 6-1 

6.1.1 COMPREHENSIVE ENVIRONMENTAL RESPONSE 

COMPENSATION AND LIABILITY ACT (CERCLA) Remedial 

Records of Decision (RODs)/DECISION DOCUMENT (DD)s......................... 6-1 

6.1.2 Removal Actional Memoranda/DECISION DOCUMENT (DD)s...................... 6-3 

6.1.3 Corrective Action Statements of Basis (SB)/DECISION DOCUMENT 

(DD)s.................................................................................................................... 6-4 
 

 iv 

6.1.4 DECISION DOCUMENT (DD) Staffing and Approval Procedures .................. 6-5 

6.1.4.1 RESPONSIBILITIES................................................................................. 6-6 

6.2 RECORDS MANAGEMENT............................................................................................ 6-6 

6.2.1 Administrative Record......................................................................................... 6-6 

6.2.2 MILITARY MUNITIONS RESPONSE PROGRAM (MMRP) 

Documentation..................................................................................................... 6-8 

6.2.3 Environmental Restoration Information System (ERIS) and Electronic 

Data Storage Requirements................................................................................. 6-8 

6.3 PUBLIC HEALTH REQUIREMENTS ................................................................................ 6-8 

6.4 OFF-SITE RESPONSE ACTION ...................................................................................... 6-8 

6.5 TECHNICAL REVIEW AND ASSISTANCE ....................................................................... 6-9 

6.5.1 Site-Specific Technical Assistance...................................................................... 6-9 

6.5.2 Groundwater Extraction and Treatment Effectiveness Review (GWETER) .... 6-10 

6.5.3 Principles of Environmental Restoration (PER) Workshop .............................. 6-10 

6.5.4 Performance-Based Contracting (PBC)............................................................. 6-11

6.6 INTERAGENCY AGREEEMENT (IAG)/FEDERAL FACILITY AGREEMENT (FFA) .......... 6-12 

6.7 REGULATORY PARTICIPATION .................................................................................. 6-14 

6.8 PUBLIC PARTICIPATION AND COMMUNITY INVOLVEMENT........................................ 6-14 

6.8.1 Community Relations Plan (CRP)..................................................................... 6-15 

6.8.2 Environmental Justice........................................................................................ 6-15 

6.8.3 Technical Review Committee (TRC) ................................................................ 6-16 

6.8.4 Restoration Advisory Board (RAB)................................................................... 6-16 

6.8.5 Technical Assistance for Public Participation (TAPP)...................................... 6-17 

6.9 DEFENSE STATES MEMORANDA OF AGREEMENT (DSMOA)/COOPERATIVE 

AGREEMENT (CA) PROGRAM ................................................................................... 6-17 

6.10 MONITORED NATURAL ATTENUATION FOR ENVIRONMENTAL RESTORATION .......... 6-17 

6.11 LAND USE CONTROLS (LUCS).................................................................................. 6-18 

6.11.1 Documenting LUCs in Records of Decision (ROD)/Decision Documents 

(DD) ................................................................................................................... 6-18 

6.12 COMPREHENSIVE ENVIRONMENTAL RESPONSE COMPENSATION

AND LIABILITY ACT (CERCLA) FIVE-YEAR REVIEWS ...................................... 6-19 

6.13 END OF RESTORATION PROGRAM ............................................................................. 6-20 

6.13.1 Response Complete (RC)................................................................................... 6-20 

6.13.2 Reopened Sites................................................................................................... 6-20 
Table of Contents 

 v 

6.13.3 Post-remedial Design Procedures ...................................................................... 6-21 

6.14 NATURAL RESOURCE INJURIES (NRI)....................................................................... 6-21 

6.15 BRAC PROPERTY TRANSFER REQUIREMENTS.......................................................... 6-22 

6.15.1 Determination of Operating Properly and Successfully .................................... 6-23 

6.15.2 Authority to Transfer Property before Completing Environmental 

Restoration Actions............................................................................................ 6-24 

6.15.3 Deed Covenants ................................................................................................. 6-25 

6.16 CLEANUP RESPONSIBILITIES AFTER PROPERTY TRANSFER....................................... 6-27 

6.17 CLOSE OUT ............................................................................................................... 6-28 

7.0 AVAILABLE BRAC ENVIRONMENTAL GUIDANCE......................... 7-1 

APPENDIXES 

Appendix A. Army BRAC Installations ........................................................................... A-1 

Appendix B. Transformation of Installation Management Command Structure...............B-1 

Appendix C. Restoration Concept .....................................................................................C-1 

Appendix D. Examples of Restoration Activities Eligibility for BRAC Funding............ D-1 

Appendix E. Table of DERP Eligibility ............................................................................E-1 

Appendix F. Definitions for Military Munitions Response Program (MMRP) ................F-1 

Appendix G. Policy for Staffing and Approving Decision Documents (DD) .................. G-1 

Appendix H. Army BRAC Cleanup Program Goals ........................................................ H-1 

Appendix I. Abbreviations and Acronyms........................................................................I-1 

Appendix J. Available BRAC Environmental Guidance ..................................................J-1

 i 

Preface 

INTRODUCTION

This management guidance supplements the roles, responsibilities, and procedures contained in Army Regulation (AR) 200-1 and the accompanying Department of the Army (DA) Pamphlet (PAM) 200-1 and provides guidance to 

implement the Army’s Defense Environmental Restoration Program (DERP) for 

BRAC Installations in accordance with the Department of Defense’s (DoD’s) 

Management Guidance for the Defense Environmental Restoration Program. 

Specifically, this document implements updates to the above-listed policy documents based on recent program changes. This guidance does not address potential 

changes to how the Army will manage environmental aspects of the FY05 BRAC 

round of closures. Modified or additional guidance will be forthcoming to address new FY05 BRAC requirements. 

SUMMARY OF RECENT CHANGES TO THE ARMY 

BRAC ENVIRONMENTAL RESTORATION 

PROGRAM (ERP) 

¡ Military Munitions Response Program (MMRP)–The MMRP is now a 

program category of the DERP. The Army must develop and maintain an 

inventory of sites that have known or suspected (UXO), discarded military 

munitions (DMM), or munitions constituents (MC). Prior to conducting a 

munitions response involving munitions and explosives of concern 

(MEC), installations must submit (1) Explosive Safety Submissions (ESS) 

Chemical Safety Submissions (CSS) and/or explosive or chemical warfare 

material (CWM) site plans through USATCES, to the Department of Defense Explosive Safety Board (DDESB) for approval. Additionally, when 

an installations intends to transfer property known or suspected to contain 

MEC, to include property with residual explosive hazards, the installation 

must submit the explosives safety provisions (e.g., land use controls or explosive safety-related notices) of transfer documents (e.g., leases, deeds, 

findings of suitability for transfer) through USATCES to the DDESB for 

approval. The MMRP is a program category of the DERP as detailed in 

the September 2001 update of the DoD Management Guidance for the Defense Environmental Restoration Program. See Section 2.3. 

¡ Transformation of Installation Management (TIM)–With the elimination 

of Major Army Commands (MACOMs) in the installation management 
 

 ii 

process, the environmental chain of command has been significantly altered. See Section 3.1 and Appendices B and C. 

¡ Army Cleanup Strategy and Strategic Plan - In 2003, the Army identified 

program goals in its Army Cleanup Strategy and corresponding Strategic 

Plan. The primary goals are to identify common objectives for creating 

consistency and accountability across the Army’s cleanup program and to 

provide direction to implement a cost efficient program. See Section 4.1 

and Appendix H. 

¡ Army Environmental Database-Restoration (AEDB-R) - The AEDB-R has 

replaced the Defense Site Environmental Restoration Tracking System 

(DSERTS) and the Restoration Cost-to-Complete System (RCTCS), as the 

primary database of installations and their cleanup sites currently under 

the Army DERP, including MMRP category sites. See Section 4.2.3. 

¡ Cost-to-Complete (CTC) Auditability – Estimates must be fully auditable; 

Remedial Action Cost Engineering and Requirements (RACER) is the required system to develop CTC estimates while investigations are underway; and installation personnel must complete mandatory RACER 

training. See Section 4.2.5. 

¡ Records of Decision (ROD)/Decision Document (DD) Approval – The 

Chief, BRAC Field Offices (FO) will approve installation RODs/DD of $2 

million or less. The Chief, ACSIM BRAC Division will approve all 

RODs/DD of between $2 million and $10 million. All RODs/DD over 

$10 million will be submitted through the BRAC Field Office to the 

BRAC Division in the Office, Assistant Chief of Staff for Installation 

Management (ACSIM) for approval. See Section 6.1.4 

¡ Environmental Restoration Information System (ERIS) and Electronic 

Data Storage – In 1999, the ACSIM directed centralized storage of all environmental restoration data. All BRAC installations must either use the 

ERIS or document how there are meeting requirements by other means. 

See Section 6.2.3. 

¡ Performance-Based Contracting (PBC) - The Army staff and USAEC are 

playing a key role in establishing a formalized PBC approach to cleanup at 

active Army installations. Focusing on results instead of the cleanup 

process, PBC allows the Army to buy environmental cleanups for a fixed 

price and at a set schedule and will allow the Army to reduce out-year 

long-term management (LTM) and Operations and Maintenance (O&M) 

costs. Private remediation firms have the flexibility to conduct environmental cleanups in a manner that is cost effective for their company while 

ensuring that legal requirements are met and required milestones are 

achieved. The Army maintains oversight of the cleanup and determines, 
Table of Contents 

 iii 

in consultation with the regulators, the desired outcome. See Section 

6.5.4. 

¡ Land Use Controls (LUCs) – The Army will document LUCs in 

RODs/DDs, stating only broad objectives, not specific installation implementation actions. Installations will state the LUC, its remedial action 

(RA) objective(s), and any critical LUC commitments. Implementation 

details will be documented in the Remedial Design (RD) Phase. LUCs 

will be a component of the remedy for munitions responses at a MRS. See 

Section 6.11. 

¡ Five-Year Reviews – The USAEC prepares an annual list of installations 

requiring Five-Year Reviews. The ACSIM BRAC Division will set the 

installations’ five-year review schedule for in the next FY. The US Army 

Corps of Engineers (USACE) Hazardous, Toxic and Radiological Waste 

(HTRW) Center of Expertise will execute all Comprehensive Environmental Response Compensation and Liability Act (CERCLA) five-year 

reviews at National Priorities List (NPL) and non-NPL installations being 

funded by BRAC, ER; the only exception will be at those installations that 

have instituted a PBC. For any residual explosive or environmental hazards that do not allow for unrestricted use, the Garrison Commander must 

ensure that the response remains protective of human health and the environment.Installation must obtain ACSIM BRAC Division concurrence before submitting reviews to regulators. See Section 6.12.

 1-1 

Chapter 1 

Purpose and Applicability 

This document provides guidance on the management and execution of the Army 

BRAC ERP. The BRAC ERP includes Installation Restoration Program (IRP) 

category responses, the newly created MMRP category responses (replaces the 

BRAC UXO category), the Building Demolition and Debris Removal Program 

(BD/DR) category responses, and eligible compliance-related cleanups at Army 

BRAC installations. The Army BRAC ERP is a comprehensive program to identify, investigate, and clean up contamination, to include by munitions constituent 

(MC), and UXO and DMM at Army installations designated for closure or realignment under the BRAC program. This document supplements the roles, responsibilities, and procedures contained in AR 200-1 and the accompanying DA 

PAM 200-1. It provides guidance to implement the Army’s BRAC IRP, MMRP, 

and BD/DR requirements in accordance with the DoD’s Management Guidance 

for the Defense Environmental Restoration Program. 

This guidance is not applicable to Army restoration activities overseas, DERP activities at active Army installations, the Compliance-Related Cleanup Program, 

the Formerly Used Defense Sites (FUDS) Program, or those installations that will 

be cleaned up by the ACSIM BRAC Division under the Excess Property Disposal 

Program using Environmental Restoration, Army (ER,A) funds. 

 2-1 

Chapter 2 

Background 

The DERP was formally established by Congress in 1984, and is codified at Title 

10 United States Code (USC) §§2701 – 2707. The program provides for the 

cleanup of DoD hazardous waste sites consistent with the provisions of the Comprehensive Environmental Response, Compensation and Liability Act of 1980 

(CERCLA) as amended by the Superfund Amendments and Reauthorization Act 

of 1986 (SARA); the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) (40 CFR §300); and Executive Order (EO) 12580, Superfund 

Implementation. 

SARA §211 authorizes the Secretary of Defense to carry out the DERP. 

The Army, Navy, Air Force, and Defense Agencies program, budget and 

manage BRAC funds. The Office of the Deputy Under Secretary of 

Defense for Installations and Environment (ODUSD (I&E)) establishes 

program goals and provides program management oversight. The 

ODUSD(I&E) establishes the DERP goals for the Army DERP in the 

Financial Management Regulation (FMR) (previously the Defense 

Planning Guidance (DPG) goals). Implementation guidance and 

procedures to achieve the FMR goals are provided in the DoD 

Management Guidance for the Defense Environmental Restoration 

Program. 

The National Defense Authorization Act (NDAA) for FY02 (Public Law 

107-107) amended the DERP by establishing a new program element for 

the cleanup of property known or suspected to contain UXO, DMM or 

MC. It requires the Army to develop and maintain an inventory of 

Defense Sites (referred to as munitions response sites or MRS) that are 

known or suspected UXO, DMM or MC at other than on operational 

ranges, operating manufacturing or storage facilities, and permitted 

demilitarization facilities). 
 

 2-2 

2.1 ARMY DEFENSE ENVIRONMENTAL RESTORATION 

PROGRAM (DERP) 

The DoD’s Management Guidance for the Defense Environmental Restoration 

Program addresses three umbrella environmental restoration areas: 

¡ Active installations. 

¡ BRAC. 

¡ FUDS, which are defined as real property that was under the jurisdiction 

of the Secretary and owned by, leased by, or otherwise possessed by the 

United States (including governmental entities that are the legal predecessors of DoD or its Components) and those real properties where accountability rested with DoD but where the activities at the property were 

conducted by contractors (i.e. government-owned, contractor-operated 

[GOCO] properties) that were transferred from DoD control prior to 17 

October 1986. The Army is DoD’s Executive Agent for this program. 

USACE executes this program for the Army. 

The Guidance also identifies program categories to describe the types of environmental restoration activities that occur under the DERP. These program categories are: 

¡ The Installation Restoration Program (IRP) category. 

¡ The Military Munitions Response Program (MMRP) category. 

¡ The Building Demolition/Debris Removal (BD/DR) program category.

To simplify and clarify the DERP, the following terms will be used in this document: 

¡ The DERP refers to the entire DoD program as established by Congress. 

¡ Army BRAC ERP refers to that portion of DERP relating to Army BRAC 

installations, including Army National Guard Bureau (NGB) and Army 

Reserve facilities. It does not include Active Army FUDS program, or 

non-BRAC excess properties. The following are categories of the Army 

BRAC ERP:

h The Installation Restoration Program (IRP) category refers to environmental responses (e.g, investigation, cleanup) to hazardous substances, pollutants, contaminants, and POL at BRAC installations. See 

Section 2.2 below. 
Background 

 2-3 

h The Military Munitions Response Program (MMRP) category environmental responses (e.g, investigation, cleanup) to MC. The MMRP 

integrates , to the extent practical, explosives safety and environmental 

requirements to protect public safety, human health, and the environment." See Section 2.3 below. 

h The BD/DR program category refers to the demolition and removal of 

unsafe buildings and structures at facilities or sites. See Section 2.4 

below. 

When the term “Army BRAC” is used in this document the term is meant to imply that the subject is applicable to the IRP, MMRP, and BD/DR categories. 

When there are inherent differences between the IRP and MMRP, the terms 

“BRAC IRP” and “MMRP” will be used to ensure clarity. 

The BRAC program is charged with closing and realigning military installations 

and entails military construction (MILCON), personnel relocation, environmental 

activities, and property transfer. Environmental requirements at realigning and 

closing Army installations include: 

¡ Restoration activities (IRP and MMRP cleanups, closure related compliance). 

¡ The National Environmental Policy Act (NEPA) property reuse and transfer documentation. 

¡ Cultural and Natural Resource considerations.

Under environmental restoration, only three categories are eligible for funding: 

IRP activities, MMRP, and BD/DR. Within the DoD financial system, the 

“BRAC environmental line” has four funding categories: 

¡ Environmental restoration. 

¡ Environmental compliance. 

¡ Planning. 

¡ Management and support.

Compliance within the BRAC ERP refers to closure-related compliance activities 

only. Closure-related compliance projects are associated with facilities and buildings requiring assessments or surveys, and abatement, if required for property 

transfer and may include closure of hazardous waste treatment, storage, and disposal facilities; radon surveys; some types of abatement of asbestos and lead 

based paints; polychlorinated biphenyls cleanup; and removal and closure of some 

types of underground storage tanks. Environmental compliance activities not in 

support of reuse and property transfer or not on the closed or realigning parcel 
 

 2-4 

require use of an installation’s O&M funds. Compliance activities related to 

BRAC are not eligible under the environmental restoration category. The Army 

funds these as a separate line item. 

2.2 BRAC ENVIRONMENTAL RESTORATION 

PROGRAM (ERP)

The Army BRAC ERP is a comprehensive program to identify, investigate, and 

clean up contaminated sites, to include MC-contaminated sites, and/or site known 

or suspected to contain UXO or DMM at closing and realigning Army installations. Restoration sites include those contaminated by past or closing defense activities and where a response is required by the CERCLA, as amended by SARA; 

the Community Environmental Response Facilitation Act (CERFA); and the Resource Conservation Recovery Act (RCRA). CERFA directs federal agencies to 

quickly identify uncontaminated parcels of land available for immediate reuse and 

transfer at all BRAC installations and allows for the transfer or lease of uncontaminated parcels. 

The goal of the BRAC ERP is to protect human health and the environment by 

cleaning up contaminated sites as quickly as resources permit, to facilitate transfer 

of excess Army properties for local reuse. 

Cleanup at BRAC installations includes studies, and where required, environmental cleanup of sites and reduction of risks to human health and the environment from contamination resulting from past Army activities on or emanating 

from the closed or realigning parcel. Eligible cleanup activities at BRAC installations are the same as those defined in the DoD Management Guidance for the Defense Environmental Restoration Program for the Installation Restoration 

Program at operating installations. 

2.2.1 BRAC ERP Eligibility

The BRAC ERP is conducted under CERCLA and the process described in the 

NCP, 40 CFR §300, and, if applicable, consistent with the substantive requirements of the RCRA corrective action process. Identification, investigation, and 

cleanup of Solid Waste Management Units (SWMUs) under the RCRA corrective 

action process may be eligible for BRAC Cleanup funds if contamination at the 

SWMU resulted from past activities and the SWMU was inactive or closed prior 

to being subjected to RCRA requirements. The Army uses BRAC compliance 

funds to investigate and close an active SWMU under the RCRA corrective action 

process and when closure supports property transfer. The BRAC ERP also complies with state, regional, and local requirements that have been identified as Applicable or Relevant and Appropriate Requirements (ARARs) in the CERCLA 

ROD or DD. 
Background 

 2-5 

Appendix D details specific activities eligible and ineligible for funding under 

the Army BRAC ERP.

2.2.2 BRAC Program Coordination

The Army works with federal, state, regional, and local regulatory agencies 

throughout a response to ensure the actions taken are protective of human health 

or the environment. Installations should coordinate and consult with federal, 

state, regional, and local regulatory agencies and Native American tribes on 

BRAC ERP planning and execution. Coordination should begin as early in the 

restoration process as possible and continue until site closeout. The Defense and 

State Memorandum of Agreement/Cooperative Agreement Program 

(DSMOA/CA) reimburses State environmental regulatory agencies for technical 

services provided in support of the Army’s BRAC ERP. A Memorandum of Understanding (MOU) between the U.S. Environmental Protection Agency (USEPA) 

and the DoD allows the Army to pay the USEPA for additional technical assistance for restoration activities at installations when it accelerates cleanup in support of economic revitalization of surrounding communities. While fostering 

open communication between the Army and regulatory agencies, the 

DSMOA/CA Program and EPA/DoD MOU assist in expediting environmental 

restoration at Army BRAC installations. For more information on the DSMOA 

program, see Section 6.9. 

2.2.3 Fast Track Cleanup (FTC)

The objectives of the DoD FTC Program are to protect human health and the environment, to expedite restoration activities, and to facilitate the transfer or lease 

of property at BRAC installations. This includes expediting the restoration process, partnering with federal and state regulatory agencies, and working with local 

communities and other stakeholders. 

Each major closing or realigning installation where property has been identified 

for transfer and where significant cleanup is planned must accomplish the following key requirements of the FTC Program process: 

¡ The Garrison Commander appoints a BRAC Environmental Coordinator 

(BEC) with responsibilities and implementation authority for all BRAC 

ERP requirements. Where a full-time BEC is not required, the Garrison 

Commander will designates a Fast Track Cleanup point of contact (POC).

¡ A BRAC Cleanup Team (BCT) is comprised of the BEC, a state environmental regulatory representative, and an USEPA representative. The BCT 

develops and implements the BRAC Cleanup Plan (BCP). 

¡ The BRAC installation should complete an Environmental Baseline Survey (EBS). An EBS is the starting point to identify environmental 
 

 2-6 

Refer to AR 200-2* and Appendix J for a list of references concerning NEPA 

requirements under the Army’s BRAC ERP. 

sites/compliance activities at the installation, specifically identifying uncontaminated property as required by CERFA and categorizing the environmental condition of all property for transferring property. The 

installation submits a request for approval of uncontaminated property, including the EBS, to the USEPA for NPL installations and to the state regulatory agency for non-NPL installations.

¡ The installation develops a BCP after the draft EBS is available and brings 

together the results of the "bottom up" review. The BCP is a blueprint for 

cleanup and identifies contaminated sites, cleanup requirements, schedules, and costs. The installation develops the BCP in coordination with 

regulatory agencies and public stakeholders. It is the basis for developing 

work plans and budget submissions and should be kept current. An updated BCP Abstract is prepared annually to summarize BCP actions and 

convey key program management information. 

¡ The garrison commander forms a Restoration Advisory Board (RAB) to 

act as a focal point for information exchange among stakeholders and offer opportunities for the community to provide input on the restoration 

process. The BCT members should be the government members of the 

RAB.

2.2.4 National Environmental Policy Act (NEPA) Documentation

The NEPA documentation portion of the BRAC ERP requires that all closing and 

realigning installations consider the environmental and socioeconomic effects of 

disposal and reuse resulting from a BRAC action. 

PL 101-510 relieves the DoD from the NEPA requirement to consider the need 

for closing, realigning, or transferring functions at BRAC installations. However, 

the DoD must still prepare environmental impact analyses during the property 

disposal process and during the process of relocating functions. The environmental impact analyses includes consideration of the direct and indirect environmental and socioeconomic effects of disposal and reuse and the cumulative 

impacts of other reasonably foreseeable actions to make military property available through the BRAC mandated closure process. 

The NEPA Support Team (NST) is responsible for determining whether BRAC 

NEPA documents comply technically and procedurally with NEPA and applicable laws, regulations, policy, and guidance. This pertains to all BRAC NEPA actions, i.e., realignment and disposal/reuse (lease, transfer, or deed). The Mobile 

District, USACE, is the designated Army NST. Installations should involve the 

NST early to assist and advise installations throughout the NEPA process. 
Background 

 2-7 

REFER TO AR 200-3* AND 200-4*, AND SEE APPENDIX J FOR A LIST OF REFERENCES 

CONCERNING CULTURAL AND NATURAL RESOURCE CONSIDERATIONS UNDER THE 

ARMY’S BRAC ERP. 

*AR’S 200-2,3,AND 4 ARE BEING ELIMINATED AND ALL PROVISIONS WILL BE IN THE REVISED AR200-1. 

2.2.5 Cultural/Natural Resource Considerations

BRAC installations are not exempt from applicable cultural and natural resource 

regulatory requirements. The cultural and natural resource portion of the BRAC 

ERP requires that all closing and realigning bases consider the effects of a BRAC 

action on man-made or natural environment resources and try to mitigate any adverse effects. 

Cultural and natural resource considerations are separate from and may extend 

beyond the completion of the BRAC NEPA process. Requirements from associated cultural and natural resource statutes and regulations must be identified and 

met before BRAC actions are undertaken. 

2.3 The Army Military Munitions Response Program (MMRP) 

Category Within Army DERP

The MMRP category has munitions responses to address UXO, DMM and/or 

MC at sites other than on operational ranges. 

Munitions response actions at BRAC installations can occur within the DERP as 

either IRP or MMRP category responses. 

The Army may conduct BRAC munitions responses to address MEC or MC under 

the MMRP category where: 

¡ The release occurred prior to 30 September 2002; and 

¡ The release is at a site that is not a formerly used defense site (FUDS), not 

an operational range, not an active munitions demilitarization facility, or 

See Appendix F for a more detailed definition of MMRP terms. 

The DoD Management Guidance for the Defense Environmental Restoration 

Program identifies eligibility criteria for response actions to address munitions 

reponses. 
 

 2-8 

not an active waste military munitions (WMM) treatment or disposal unit 

that operated after 30 September 2002.

IRP Category Activities - Response activities to address UXO, DMM or MC can 

be conducted where:

¡ The release occurred prior to 30 September 2000, and 

¡ The release is at a site that is not a FUDS, not an operational range, not an 

active munitions demilitarization facility, and not an active WMM treatment or disposal unit.

The Army completed its inventory of former ranges (closed, transferring and 

transferred) on 31 May 2003. The Army entered data collected from this inventory in the Army Range Inventory Database (ARID) and is the basis for converting eligible defense sites for the MMRP into the AEDB-R. Based on the 

inventory, the Army will program specific requirements for munitions response 

actions and CTC in subsequent Program Objective Memorandum (POM) development efforts. The USAEC is responsible for the initial conversion of MRS into 

AEDB-R. 

The USAEC will assign sites in the MMRP a Risk Assessment Code (RAC) to 

assist in establishing priorities. The RAC provides uniform procedures for assessing explosives safety risks at MMRP sites. 

2.4 BUILDING DEMOLITION AND DEBRIS REMOVAL 

PROGRAM (BD/DR)

The BD/DR program category of Army BRAC program is defined as the demolition and removal of unsafe buildings and structures at facilities or sites that are or 

were owned by, leased to, or otherwise possessed by the DoD. (Note: Buildings 

used in the production, demilitarization and/or other munitions-related operations 

may be contaminated with concentrations of MC that present a potential explosive 

hazard. The demolition of such buildings requires assessment of the risks and review by the explosive safety community.) Use of BRAC funding for BD/DR requires extensive preliminary coordination. The ACSIM BRAC Division will not 

normally provide funding for BD/DR unless the unsafe building or structure was 

unused since 17 October 1986, and where the building or structure is: 

¡ An integral part of an IRP or MMRP category response. 

¡ Formally authorized for funding by the DUSD (I&E). 
 3-1 

Chapter 3 

Responsibilities

3.1 DEPARTMENT OF THE ARMY (DA)

The Assistant Secretary of the Army (Installations and Environment) (ASA 

(I&E)) through the Deputy Assistant Secretary of the Army for Environment, 

Safety, and Occupational Health (DASA (ESOH)) provides overall policy and 

guidance concerning all Army environmental programs. 

The Deputy Assistant Secretary of the Army (Installations and Housing) 

(DASA(I&H) has overall responsibility for the Army’s BRAC Program, and 

overall policy and guidance authority concerning all Army BRAC matters with 

the exception of Army environmental programs. 

The ACSIM has staff responsibility for the Army's environmental programs, including providing resources, guidance and authority to execute those programs. 

The Installation Management Agency (IMA), as a Field Operating Agency (FOA) 

under the ACSIM, oversees all US Army-wide installation management, less 

BRAC installations. 

The BRAC Division and the Office of the Director of Environmental Programs 

(ODEP) support the ACSIM. 

The ODEP is responsible for the development Army Environmental Guidance. 

The ODEP reviews and provides recommendations to the ACSIM on all submissions and responses directed to the ACSIM concerning environmental policies, 

planning, programming, budgeting, and oversight of the Army's environmental 

programs and related matters. The ODEP coordinates with the BRAC Division. 

ACSIM BRAC Division is the program manager and develops Army BRAC related policy, manages the Base Closure Account and distributes funds to installations and executors. The BRAC Field Offices (FO) support the BRAC Division 

in managing the cleanup of BRAC installations and supporting property transfer 

initiatives. The BRAC FO collect Work Plan requirements, staff funding requests 

through the BRAC Division, and monitor program execution. The BRAC FO are 

responsible for reporting and managing BRAC program progress. 

The USAEC is a FOA of the ACSIM and supports the BRAC Division concerning the BRAC ERP. The USAEC also assists the BRAC Division in the oversight 

of the execution of the BRAC ERP and has assigned Environmental Restoration 

Managers (ERM) to serve as the technical environmental link between garrison 
 

 3-2 

environmental offices and HQDA. The ERMs are responsible for BRAC technical and programmatic oversight of cleanup activities at their assigned installations. The ERMs also assist their installations and the BRAC FO with 

management decision-making. 

The US Army Corps of Engineers (USACE) Real Estate Office is the Army’s disposal agent for real estate and is involved in all BRAC property disposal and 

transfer activities. 

The NEPA Support Team (NST) performs the NEPA compliance technical review of Army BRAC NEPA documents for the BRAC Division. See Section 

2.1.5 for more information on the NST. 

The United States Army Technical Center for Explosives Safety (USATCES) develops Army policies, procedures, and regulations to ensure compliance with the 

DoD Explosives Safety Standards (DoDD 6055.9-STD). USATCES recommends 

explosives safety policy for the management and cleanup of real property known 

or suspected to contain munitions and explosives of concern (MEC); provides 

technical assistance, and advise on matters related to munition responses and explosives safety to Garrison Commanders and others; reviews and provides Army 

approval for explosive safety submissions, chemical safety submissions, and/or 

explosive or chemical warfare material site plans submitted to the Department of 

Defense Explosives Safety Board for approval. USATCES also reviews the explosives safety provisions (e.g., land use controls or explosive safety-related notices) of transfer documents (e.g., leases, deeds, findings of suitability for transfer) 

for property known or suspected to contain MEC or residual explosive hazards 

that, per DoDD 6055.9-STD, must be submitted to the DDESB for review and 

approval prior to the transfer. 

The Garrison Commander, or other designated authority when there is no Garrison Commander, is responsible for executing the BRAC ERP at his/her installation. Installations are responsible for tasking their BRAC Executor(s); 

coordinating with the USAEC, IMA and BRAC FO POCs; and coordinating regulatory and community involvement and for ensuring compliance with DoD policies, to include explosive safety policies, and applicable federal and state laws and 

regulations. 

The BRAC Transition Coordinator (BTC) is a position created by the President’s 

five-part program for major BRAC installations. These coordinators are located 

on-site at certain installations selected for closure or major realignment. The 

BTCs act as a liaison between the installation and the local community in such 

areas as community outreach, environmental cleanup, federal assistance programs, planning, and property disposal. 

The FTC Program created the BRAC Environmental Coordinator (BEC) position 

to function as the coordinator of the numerous BRAC environmental activities 

that center on the interaction between the Army, the EPA, the state, and the local 
Responsibilities 

 3-3 

community. Nominated by the Garrison Commander and ultimately approved by 

the ACSIM BRAC Division, the BEC is responsible for maintaining contact with 

the installation BRAC and environmental offices, and keeping the BTC informed 

of environmental activities. The BEC has overall responsibility for environmental 

programs related to the transfer of real property at an installation. The BEC coordinates closely with the BRAC Division and the USAEC. 

The Fast Track Coordinator Point of Contact (POC) is a position created by the 

Army where a full-time BEC is not required (see DA Pam 200-1, Section 11-6d). 

The nomination and approval is the same as for the BEC. 

The BRAC Cleanup Team (BCT) is the key element of the Fast-Track Cleanup 

approach to cleanup at closing and realigning bases. A BCT includes an Army 

representative (the BEC), representatives of the state regulatory agency and the 

EPA regional office. Each closing installation where property will be made available for reuse has a BCT unless exempted by the BRAC Division. The BCT is 

the primary forum for addressing cleanup planning and execution issues. 

The BRAC ERP Executor conducts remedial responses (identification, investigation, and cleanup of contamination) at BRAC installations under the direction of 

the installation. The USACE Districts and the US Army Center for Health Promotion and Preventive Medicine (USACHPPM) may also execute specific BRAC 

ERP projects. 

The U.S. Army Center for Health Promotion and Preventive Medicine 

(USACHPPM) provides oversight for the Agency for Toxic Substances and Disease Registry (ATSDR) activities to evaluate public health concerns. These activities include the preparation of Public Health Assessments, health 

consultations, health studies, responses to citizens’ petitions and health education 

activities. The USACHPPM reviews and concurs on human health risk assessments for the Army Surgeon General and also reviews ecological risk assessments

3.2 REGULATORY AGENCIES

State regulatory agencies have established POCs for each installation. CERCLA 

requires that cleanup documents be coordinated with State regulators and appropriate federal agencies, such as those entities serving as Natural Resource Trustees. Installations provide state regulatory agencies access to program 

information (with due consideration of issues related to accuracy, national security, and other established forms of confidentiality or privilege), See Section 6.7 

for additional information concerning regulatory agencies. 

The USEPA is involved in all BRAC installations with property transferring outside the Army and at installations on the USEPA’s National Priorities List (NPL). 

The Army and USEPA work together to develop cleanup schedules, sampling and 

analysis plans, and the appropriate Decision Documents (DD) for both removal 
 

 3-4 

The Local Redevelopment Authority (LRA) is a body established by a state or 

local government charged with developing a reuse plan that supports the interests of the community. The LRA is expected to provide leadership and build 

consensus for reuse of the installation and serves as the community’s point of 

contact for all matters relating to reuse. The BRAC Transition Coordinator is 

the main interface between the LRA and the Army. For additional information 

on community involvement, see Section 6.8. 

actions and RAs at NPL sites. Cleanup terms, document delivery and cleanup 

schedules are memorialized in Federal Facility Agreements (FFAs). 

3.3 LOCAL COMMUNITY

Community involvement activities are an integral part of the Army’s BRAC ERP. 

BRAC installations should seek community involvement early and throughout the 

cleanup process. The Army must afford the public an opportunity to review and 

comment on any proposed RA or non-time critical removal action at an installation. 

The RAB consists of representatives of the local government and community, the 

Army, the USEPA, state environmental regulatory agencies, and Native American 

tribes. All BRAC sites that involve the transfer of property to the community 

must have a RAB. For all other BRAC installations, the commander should establish a RAB where there is sufficient and sustained community interest. Members provide individual views to the BCT concerning restoration activities at the 

installation. An installation representative and a member of the local community 

jointly chair a RAB. 

3.4 OTHER STAKEHOLDERS

Other stakeholders are also involved in the DERP public participation and community involvement activities at various installations. These stakeholders may be 

members of the local communities or Native American tribes or governing bodies. 

In addition, federally recognized tribes may serve as Natural Resource Trustees. 
 4-1 

Army Cleanup Strategy goals and metrics are detailed inAppendix H. 

Chapter 4 

Program Development and Management 

The Army ensures program planning to implement approved closures and realignments to transfer property to local communities for economic reuse in accordance with the President’s Five-Part Plan for Community Reinvestment. The 

FTC, part of the President’s plan, outlines an approach to accelerate environmental cleanup at closing installations to prepare the property for community reuse, while ensuring that human health and the environment are protected. The 

Army conducts response actions at BRAC installations to remediate contamination in accordance with the goals set forth in the DoD FMR, the procedures in the 

DUSD (I&E) Management Guidance for DERP, and the policies in AR 200-1 and 

guidance in DA Pam 200-1.

4.1 PROGRAM GOALS AND OBJECTIVES

The DoD developed cleanup goals and objectives for active and BRAC installations and presented the goals and objectives in the FMR. The FMR cites goals 

that require the Army to reduce risk to protect human health and the environment 

as well as comply with legally enforceable agreements, orders, and laws through 

implementation of cost-effective response actions, while concurrently effecting 

timely property transfer. The current FMR establishes environmental restoration 

goals for installations. See Section 4.5.2. 

In addition, the Army has identified BRAC program goals in its Army Cleanup 

Strategy and corresponding Strategic Plan. These additional goals and metrics 

provide direction to implement a cost efficient program. 

4.2 PROGRAM IMPLEMENTATION

To ensure consistency in the manner that the Army’s BRAC ERP is implemented 

to meet the FMR goals, several documents and reports play key roles in the process. The EBS, the BCP and the BCP Abstract, the AEDB-R, the RRSE (RAC for 

MMRP), and the CTC, are all inter-related, require input from one another, and, 

in turn, provide output to each other. Each must be internally coordinated to ensure overall consistency within the Army’s BRAC ERP. 
 

 4-2 

The procedures for conducting an EBS and the EBS review process are described in DA PAM 200-1 (17 Jan 02), Chapter 15-6. 

Environmental Condition of Property categories are defined and described in 

the 1995 BRAC Cleanup Plan Guidebook: 

http://www.dtic.mil/envirodod/Policies/BRAC/brac_toc.htm

4.2.1 Environmental Baseline Survey (EBS)

An EBS is a study of the environmental conditions of Army controlled properties 

and proposed acquisitions, focusing on hazardous substances or other regulated 

hazards. The Army uses the EBS to document existing environmental information related to the storage, release, treatment, or disposal of hazardous substances 

or petroleum products on the property. The EBS determines the presence or 

likely presence of a release or threatened release of any hazardous substance or 

petroleum product. The EBS is also used to determine whether a threat or hazard 

to human health or the environment is present, such as the presence of polychlorinated biphenyls (PCBs), petroleum products and their derivatives, asbestos, radon, lead-based paint, and UXO. 

Army policy requires an EBS be prepared to determine the environmental condition of properties being considered for acquisition, outgrants, and disposals. Reassignments within the Army, permits, licenses, and easements do not require an 

EBS; however, the Army may perform an EBS if desired or when extraordinary 

circumstances exist. The Army uses the EBS to identify potential environmental 

contamination liabilities associated with the real property transactions and to support a Finding of Suitability to Transfer (FOST), a Finding of Suitability to Lease 

(FOSL), or an Environmental Condition of Property (ECOP). 

In all cases, at a minimum, the Army will conduct actions to a level necessary to 

protect human health, safety, and the environment for the planned use of the 

property. The Army uses the BRAC site-wide EBS as a multi-functional document providing required environmental data to identify CERFA parcels and to 

support NEPA actions. The EBS is the starting point for classifying property into 

the seven DoD Environmental Condition of Property (ECOP) categories and becomes the basis for the BRAC Cleanup Plan (BCP). 

The DoD developed ECOP categories to identify the environmental condition of 

all parcels of property at BRAC installations to expedite transfer or lease of effected areas. Parcels of property are categorized during the EBS and used during 

development of the BCP. As cleanup occurs under the BRAC ERP, the DoD 

ECOP classification changes and the Army uses it by to track cleanup progress 

toward Defense Goals established in the FMR. 

The ACSIM BRAC Division also conducts Environmental Site Assessments 
Program Development and Management 

 4-3 

For more information on Environmental Site Assessments, consult the “American Society for Testing and Material (ASTM) Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process, 

designation: E 1527–00”. 

(ESAs) in accordance with General Services Administration (GSA) guidelines for 

the disposal of real property. The purpose of conducting the ESA is to: 

¡ Identify the recognized environmental condition of the property. 

¡ Satisfy one of the requirements to qualify for the innocent landowner/purchaser defense under the CERCLA. 

¡ Improve the commercial marketability of the property in the “eyes” of potential buyers by conducting a commercially accepted ESA. 

4.2.2 BRAC Cleanup Plan (BCP)

The BCP is the key document in the management and execution of the BRAC 

ERP. The BCP is a management tool that presents the entire environmental program for the installation and that the Army uses to expedite and improve environmental response actions for disposal and reuse of a BRAC installation, while 

protecting human health and the environment. The plan is intended to be a roadmap of environmental programs and the macro-level strategy and schedule for 

accelerating environmental cleanup activities. A BCP should provide the status of 

a BRAC installation’s cleanup and compliance programs, the status of base disposal efforts, and the strategy, rationale, schedule, and costs for future execution 

of all environmental programs. 

The installation develops a BCP after the draft EBS is available and brings together the results of the "bottom up" review. Using the EBS to support NEPA 

precludes the need to develop Preliminary Assessment (PA) screening documents. 

For each site within the AEDB-R, the BCP documents BRAC ERP requirements, 

the rationale for the technical approach, and corresponding financial requirements. Prior year funding and cost estimates through the entire remedial process 

are included. Estimates of cost must be fully supportable, either using the 

RACER estimating model or an engineer estimate generated by an industry-wide 

accepted model (see Section 4.2.5). The BCP contains the environmental history; 

current AEDB-R status; contaminants, to include MC, of concern; RRSE status 

and/or for site known or suspected to contain MEC (or RAC); response actions 

taken, if any; past milestones; and any possible future response actions. 

Army installations where property will be available for transfer to the community 

form a BCT. The BCT meets to review the process underway to clean up property, to evaluate methods, to handle problems that develop, and to discuss how to 
 

 4-4 

For more information on preparing BRAC Cleanup Plans and BRAC Cleanup 

Plan Abstracts, see: 

http://www.dtic.mil/envirodod/Policies/BRAC/BCP_factsheet_final.pdf

integrate environmental cleanup priorities with reuse needs. The BCT is responsible for the preparation and implementation of the installation BCP. 

The BCP is updated annually and helps the BCT to integrate reuse and restoration 

efforts. At the beginning of the fiscal year, the BCT should review the BCP and 

update information as required. The review should focus on the BCT/Project 

Team, the Property Disposal and Reuse Plan, the ECOP, and the BRAC ERP. 

The BCT may also determine that it is necessary to update the BCP, based upon 

this review. The installation need not reprint and recopy the entire BCP when a 

change is made. Changes may be tracked by "pen and ink" or by reprinting the 

modified page. 

The BCTs should involve appropriate regulators and, when appropriate tribal 

governmental representatives) and stakeholders (e.g., community members of an 

installation's Restoration Advisory Board (RAB)) when reviewing and updating 

the BCP so they may participate in the planning process. The BCTs are encouraged to make the BCP available on the installation’s home page on the worldwide 

web, if available. The BCTs should also make the BCP available in information 

repositories for public review. However, all BCPs must have the constrained and 

unconstrained site-level CTC removed prior to distribution to the public or regulators or placement in the Administrative Record or information repository. Additionally, public affairs and security reviews of the public version BCP must be 

conducted prior to distribution. . 

If updates to the BCP occurred during the BCT's annual review, the installation 

must annotate changes on the BCP Abstract (i.e., Date of Last BCP Update). A 

statement on any community involvement during the review and update of the 

BCP must be included under the FTC Summary section on the BCP Abstract. 

The BCP Abstract is an Executive Summary of the BCP. The abstract facilitates 

BCP updates, conveys key program management information, and summarizes 

the updated status of the installation’s environmental program. The BCP Abstract 

is useful in focusing attention on the overlap between reuse and cleanup planning 

efforts. A BCP Abstract is required for every installation with a BCT and all 

BRAC 95 installations with a FTC POC. The Army uses the BCP Abstract to 

support the DoD data call requirements, IPRs, and the DERP Annual Report to 

Congress. The BCP Abstracts are updated in August-September and are prepared 

within the AEDB-R. 
Program Development and Management 

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4.2.3 Army Environmental Database-Restoration (AEDB-R)

The AEDB-R, formerly known as the Defense Site Environmental Restoration 

Tracking System (DSERTS) and the Restoration Cost-to-Complete System, is the 

Army database of record that includes installations and sites that are currently included in the BRAC ERP. BRAC UXO sites in DSERTS are now MRS in the 

AEDB-R that are addressed as MMRP category sites. The AEDB-R provides the 

USAEC, installations, and BECs with an automated Internet-based application to 

manage, track, and query data on activities conducted under the Army DERP. 

The AEDB-R data are also used to meet upward reporting requirements. The 

AEDB-R is a source of information for the following:

¡ The DERP Annual Report to Congress. 

¡ Army’s Environmental Restoration Financial Liability Statement. 

¡ Program Objective Memorandum (POM). 

¡ President’s Budget. 

¡ Site-level CTC. 

¡ Relative Risk Site Evaluations (RRSEs) or Risk Assessment Codes 

(RACs). 

¡ BRAC ERP Work Plans. 

¡ DoD IPRs/Measures-of-Merit (MOM). 

¡ ACSIM BRAC Reviews and Program Review Crosswalks. 

¡ The BCPs and Abstracts.

Installation personnel maintain a current list of all sites at the installation in 

AEDB-R that have “Completed,” “Underway,” or “Future” restoration activities. 

Site-level data includes Site Name/Description, Site Type, the BRAC round 

(BRACI, BRACIV), BRAC Program Sub-Code (Restoration, Compliance, or 

MMRP), and Phase/Cleanup Action status. 

As part of AEDB-R, installations must perform a RRSE/RAC on all in-progress 

cleanup sites (i.e., all sites except “Response Complete (RC)” or “Remedy-inPlace” (RIP)). Additionally, installations must report key program-status elements in AEDB-R, such as information on BCP Abstracts such as BRAC specific 

information that is collected in AEDB-R including acreage, narratives, FOST, 

FOSL, and FOSET information, in addition to RODs/DD, Federal Facilities 

Agreements (FFAs), and RABs. Installations will also report on Five-Year Reviews and Land Use Controls (LUCs) through AEDB-R. The installation has the 
 

 4-6 

responsibility to ensure data are consistent with the most current information. Installations are required to correct identified data gaps and inconsistencies. 

The USAEC provides AEDB-R access, user manuals, Army guidance, and training to installation, BRAC FO, BRACD, ODEP and other personnel as required by 

new versions and policy/guidance updates. The USAEC also provides on-site assistance as requested by the installations. 

The USAEC reviews all data submissions for completeness and consistency with 

AEDB-R data call. Any necessary revisions are coordinated through the BRAC 

Field Office to the installation. The USAEC consolidates data files into an Army 

file for submittal to ODUSD (I&E). 

Within AEDB-R the definition of a site is a unique name given to a distinct area 

of an installation containing one or more releases or threatened releases of hazardous substances, to include MC, or known or suspected to contain UXO or 

DMM that are treated as a discreet entity or consolidated grouping for response 

purposes. Includes any building, structure, impoundment, landfill, storage container, or other site or area where a hazardous substance was or has come to be 

located, including formerly used defense sites (FUDS) eligible for BD/DR, or 

UXO or DMM are known or suspected to be present. Installations and former 

ranges may have more than one site. MRS are those defense sites that are known 

or suspected to contain UXO, DMM or MC. MRS do not include any operational 

ranges or facilities that are used for or were permitted for the treatment or disposal 

of military munitions. 

For the BRAC ERP, cleanup, closure-related compliance, and MRS requiring 

funds must be in AEDB-R before the BRAC Division will release funds to complete any work at the site. For BRAC closure-related compliance sites, a project 

addressing multiple sites for a single contaminant (i.e., asbestos, lead-based paint, 

radon) is equivalent to a “site.” RRSEs may not be required for closure-related 

compliance at all MRS. A RAC evaluation will be performed for all MRS that 

are known or suspected to contain MEC. 

New sites are added to the AEDB-R if the sites are identified in an EBS. Installations put new sites in AEDB-R when it completes the PA phase (EBS equivalent) 

and the site requires a follow-on action. Sites with a PA phase (EBS equivalent) 

status of “Underway” or “Future” cannot be input to AEDB-R. 

Installations update the AEDB-R on the web and submit them through the appropriate BRAC FO to USAEC twice per year as required. 

The Army Range Inventory of former ranges (closed, transferring and transferred) 

serves as the PA for MRS. MRS added after the inventory of MRS was completed will require a completed PA and RAC. 
Program Development and Management 

 4-7 

For detailed guidance on the RRSE, see the 1997 DoD Relative Risk Site 

Evaluation Primer and the Relative Risk Site Evaluation Quality Assurance 

Plan, available on the Internet at: 

http://www.dtic.mil/envirodod/Policies/Cleanup/relrisk/relrisk.html.

For details on the Army Range Inventory, see 

http://aec.army.mil/usaec/reporting/arid00.html

For additional information on the AEDB-R, visit the USAEC website at: 

http://aec.army.mil/

The AEDB-R may be accessed at https://aerp.apgea.army.mil/ Contact the 

USAEC Help Desk for user account requests 

The Help Desk can be reached at 410-436-1244 or DSN 584-1244 or by e-mail 

at usaechelpdesk@aec.apgea.army.mil

4.2.4 Relative Risk Site Evaluations (RRSE) and Risk Assessment 

Code (RAC) 

The DoD established risk reduction as a program goal for the DERP. To accomplish the risk reduction goal, DoD adopted a risk management strategy to ensure 

that higher risk sites receive priority in the cleanup process. The RRSE framework is the foundation of that strategy. Due to the inherent differences between 

long term environmental risks and the immediate risks posed by explosives, the 

RAC is the framework for prioritizing the explosive safety hazards. The RAC 

framework identifies the potential explosives safety hazards identified at a site by 

assessing the risk at sites suspected to contain UXO or other explosive safety hazards. Note that USAEC is developing a new Site Prioritization Protocol that will 

eventually replace RAC. 

The RRSE framework uses common standards and rating definitions for all Services to ensure uniform categorization DoD-wide. The RRSE site evaluation considers contaminant concentrations, migration pathways, and human and ecological 

receptors in groundwater, surface water, sediment, and surface soils. Evaluations 

of these factors at a site are combined to place the site in an overall category of 

"high", "medium", or "low" relative risk. 

Pending implementation of the Munitions Response Site Protocol (MRSP), the 

RAC has been adopted as an interim DoD-wide approach for providing a single, 

consistent tool for assigning to an MRS known or suspected to contain MEC a 
 

 4-8 

relative priority. The Army will offer regulators and public stakeholders opportunities to participate in the RAC development process. Each MRS known or suspected to contain MEC, to include MRS where a response has been completed, 

shall be assigned a RAC score, as soon as possible. Until the RAC is assigned, 

MRS known or suspected to contain MEC will be classified as “not yet evaluated.” The installation assign a RAC to a newly identified MRS that are known or 

suspected to contain MEC within 12 months of its identification. 

The RRSE and RAC should not be used to: 

¡ Select a remedy. 

¡ Determine whether a response action is required. 

¡ Substitute for a baseline risk assessment, which identifies the risks, or the 

health assessment, which identifies the potential health effects on the 

community, associated with the site. 

¡ Determine whether a site should be classified as “RC” or "No Further Action". 

¡ Avoid meeting legal requirements.

The Army requires a RRSE/RAC for all AEDB-R sites with ongoing cleanup activities and is performed with available site data. Using the RRSE module in 

AEDB-R, installations evaluate available data for each AEDB-R cleanup site. 

Although previously calculated RRSE data is maintained, a new RRSE calculation is not required and should not be performed at sites:

¡ Classified as having all RIP, even though the sites may be in Remedial 

Action operation (RA(O)) or LTM. 

¡ Classified as “RC” in AEDB-R. 

¡ That has only BD/DR requirements. 

¡ BRAC closure-related compliance. 

Installations may add sites to the AEDB-R database without information to conduct a RRSE as pending sites, but they will not be approved until the RRSE is 

completed and reviewed. Installations may add sites known or suspected to be 

contaminated by chemical agent to AEDB-R, as “Not Evaluated” when it cannot 

safely sample the contamination. Such site should be reported to the U.S. Army 

Corps of Engineers Military Munitions Center of Expertise (MM CX).. Installations with AEDB-R sites having no evaluation for relative risk must provide justification for the lack of RRSE evaluation and provide a schedule for evaluation. 
Program Development and Management 

 4-9 

For detailed guidance on the RAC, see the September 2001, Management Guidance for the Defense Environmental Restoration Program. Available on the 

Internet at http://www.dtic.mil/envirodod/envdocs.html.

Per DoD guidance and Army policy, installations are to solicit stakeholder involvement throughout the RRSE/RAC process. The BCPs, together with the 

RRSE, can serve as the basis for dialogue with stakeholders (local community, 

RABs, and regulator representatives) on sequencing work at sites. 

Installations review and update RRSE/RAC data semi-annually during the April 

and October AEDB-R data calls. The RRSE/RAC data are provided to the 

ODUSD(I&E) at mid-year and at the end of the fiscal year. DoD uses relative 

risk data to measure progress, show risk reduction and potentially adjust program 

goals at the semi-annual DoD IPRs. Certain sites may have a RAC score to address potential explosive hazards and a RRSE to address any environmental risk 

posed by contamination, to include MC, at the site.

4.2.5 Cost-to-Complete (CTC)

The CTC estimate for environmental restoration projects is an important planning 

tool in the budget process. HQDA uses the CTC estimates to support the financial liability statement, to support POM submissions, develop the annual President's budget, and track cost avoidance measures implemented by Army 

installations. 

Since 1990, several federal financial acts added new requirements for DoD and 

the Army to accurately report environmental liabilities. The purpose of these acts 

was to improve general and financial management practices in the federal government. Agencies are required to develop multi-year strategic plans, annual performance plans, and annual performance reports. In addition, federal agencies 

must produce annual auditable financial statements and accurate cost and performance information, as well as to integrate budget, accounting, and program 

data. In summary, these statutes require the DoD and the Army to develop auditable financial statements that report both assets and liabilities. A liability is defined as a probable and estimable future outflow of resources due to a past 

government transaction or event. 

Liability disclosure includes having complete, formal, and auditable documentation of all data, models, and other information used to develop the estimate of the 

environmental restoration liability. CTC estimates and the funding levels in the 

annual financial statements for environmental restoration must be consistent with 

each other. Further, these funding levels must be consistent in any reports provided to outside entities, such as in the DERP Annual Report to Congress. 

CTC estimates form the basis of the environmental liabilities reported in the 

Army’s Annual Financial Statements in compliance with the Chief Finance Offi-
 

 4-10 

cers Act of 1990. In addition, CTC estimates must comply with DoD FMR 

7000.14-R, Volume 4, Chapter 14, Accrued Environmental Restoration (Cleanup) 

Liabilities (October 1999). This regulation requires documentation of data 

sources, methods of estimation and documentation of management review of CTC 

estimates. The FMR 7000.14-R, Section 140105, stipulates that CTC estimates 

are subject to audit. Therefore, information used to develop CTC estimates for 

the environmental restoration programs is subject to audit by the US Army Audit 

Agency and the DoD Inspector General. 

4.2.5.1 CTC ESTIMATES

Installations shall prepare annual CTC estimates for each site in the AEDB-R. 

These estimates shall reflect the environmental restoration strategy and sequence 

as presented in the IAP for the site and any changes that occurred since the last 

report. 

Installations shall prepare a CTC estimate only when there is sufficient sitespecific data to make a “probable” estimate without making unsubstantiated assumptions. If a site-specific CTC estimate is not prepared, installations shall 

document the rationale for not doing so, describe their plan of action and milestones for gathering sufficient site-specific information to develop an estimate, 

and forward that information with the rest of the installation's CTC data. Installations shall ensure the reliability and completeness of the data used to calculate 

their CTC estimates. Installations are required to ensure that these data sets are 

complete, up-to-date, and documented in a manner that will withstand an audit. 

CTC estimates shall include, on a current cost basis (not adjusted for inflation), all 

anticipated costs required to effectively restore the site, as well as the costs of 

complying with applicable legal and regulatory requirements. This requires that 

CTC estimates: 

¡ Be site-specific. 

¡ Consider future land use of the site. 

¡ Be based on currently available technologies. 

¡ Include the cost of completing all remaining studies, restoration, removal, 

or RA (including O&M of remedial systems). 

¡ Include costs in the LTM phase, to include all five-year review costs, costs 

for management and monitoring of LUCs applied to sites where cleanup to 

an unrestricted use can not be attained, costs of decommissioning treatment systems and abandoning monitoring and extraction wells. Prior to 

completion of removal or remedial action requirements, long-term CTC 

estimates shall be adjusted annually, through indexing, to maintain them 

on a current cost basis. 
Program Development and Management 

 4-11 

¡ Include costs associated with deletion from the NPL, where appropriate. 

CTC estimates shall document environmental restoration cost information, to include identifying:

¡ The source of requirements (e.g., applicable laws and regulations). 

¡ Methods for assigning estimated total environmental restoration costs to 

current operating periods. 

¡ Material changes in the total estimated costs of environmental restoration 

activities (e.g., due to changes in laws, technology, plans) and the portion 

of the change in estimate that relates to prior period operations. A material change is defined as evidence that a change of more than 10 percent of 

the prior year ending balance (up or down) will occur. 

¡ Material changes (i.e., when there is evidence that a change of more than 

10 percent of the prior year ending balance (up or down) will occur) in the 

total estimated costs of environmental restoration activities (e.g., due to 

changes in laws, technology, plans) and the portion of the change in estimate that relates to prior period operations. 

¡ The nature of estimates and the disclosure of information regarding possible changes due to inflation, deflation, technology, or applicable laws and 

regulations. 

CTC estimates should include all anticipated future costs, including LTM where 

necessary. In the event the number of years required for LTM is undetermined, as 

may be the case for certain classes of sites, such as landfills, the years should be 

based on past similar sites. LTM for CTC estimates should not exceed 30 years. 

In addition, CTC estimates should include all project management (e.g., USACE 

costs, owner costs) and contingency costs (e.g., risk) associated with the environmental restoration of the site. Legal, regulatory, and administrative costs associated with Site Closeout should also be included in CTC estimates. 

CTC estimates shall not include the costs of environmental compliance cleanup 

not related to the BRAC ERP, pollution prevention, conservation activities, contamination or spills associated with current operations, or treaty obligations, all of 

which are accounted for as part of ongoing operations. Similarly, expenses associated with the operation, management, or sustaining operational ranges are not 

included as environmental restoration liabilities. 

Closure-related compliance and MMRP AEDB-R “sites”/projects also require a 

CTC estimate and are included in the CTC database. 
 

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4.2.5.2 COMPUTER MODELS

In FY02, the Army began using the RACER model to develop CTC estimates for 

sites without a Feasibility Study (FS). The RACER is a cost-estimating tool that 

estimates costs for all phases of remediation: Interim Actions/Interim Measures, 

studies (Preliminary Assessment/Site Investigation (PA/SI), Remedial Investigations/Feasibility Studies (RI/FS), RCRA Facility Investigations/Corrective Measures Studies (RFI/CMS)), RD, RA (including operation and maintenance), and 

site work and utilities. The engineering solutions within RACER are based on 

data from government and industry, construction management agencies, technology contractors and vendors, and historical project information. 

During the development of a ROD/DD, other auditable cost estimating models 

may be used based on site-specific data. If installations use another computerized 

model to calculate CTC estimates, they shall ensure that the computer model used 

for this purpose is verified, validated, and accredited per DoD Instruction (DoDI) 

5000.61 - DoD Modeling and Simulation Verification, Validation, and Accreditation (VV&A). Some estimates cannot be developed using a computer model because some environmental restoration actions are truly site-specific and unique to 

a particular set of contaminants for which no computer model may exist. In these 

instances, estimates must, by necessity, be developed based on engineering studies or estimates. Installations will fully document estimates developed based on 

engineering studies or estimates, other methods, or computer models not validated 

per DoDI 5000.61. The information submitted to the USAEC for inclusion in the 

annual financial statement shall be annotated accordingly. 

4.2.5.3 CTC REVISIONS

Installations shall revise CTC estimates when a “material change” occurs. Such a 

change must be fully documented and the IAP for the site revised to reflect this 

change. The installation shall forward the revised estimate to the appropriate 

BRAC Field Office for concurrence and then to the USAEC for incorporation into 

the Army-wide annual financial statements. The installation must disclose the 

nature of a material change in the liability from year to year. Reasons for such a 

change may include level-of-effort, inflation, and new regulatory requirements. 

Other reasons may include delays in implementation due to events such as legal 

action, natural disaster, or adverse weather. 

The BRAC program uses the BRAC Optimization Model to determine allocations 

down to the site/phase level in AEDB-R (see Section 4.4.3.2). The BRAC FO 

review the model output and make changes/updates. In June of each year, the installations will be advised of their Annual Funding Plan for the next fiscal year as 

well as each year through the POM years (FY+5) or until there are no requirements (whichever is less). The BRAC Division notifies installations of their annual environmental allocations in June and must then “program” their CTC 

estimates in the fall AEDB-R data call to meet their allocations. Installations 

submit their total programmed cleanup requirement by sites to the USAEC 

For more information on CTC, see “Developing Cost-to-Complete Estimates & 

Financial Reporting of Environmental Restoration Liabilities for the US Army 

Environmental Restoration Program”, January 2002. 
Program Development and Management 

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through AEDB-R in October. The BRAC Division uses these requirements to 

develop the BRAC budget and to report the Army environmental liabilities. 

4.2.5.4 CTC AUDITS

Environmental restoration estimates for both the CTC and environmental liability 

reporting in an annual financial statement are subject to audit. The financial management regulations emphasize that financial records, to include CTC estimates, 

must have audit trails to allow transactions to be traced from the point of initiation 

to the final report. A fundamental requirement of a good audit trail is that pertinent documents and source records adequately support all transactions. The 

source document shall include a narrative providing sufficient explanation for the 

basis of the estimate, the date prepared, the preparer's name, and supervisor’s signature. Original estimates and changes in those estimates shall be documented 

and available for review. Documentation must exist at the time of an audit. 

When contractors must develop a cost estimation for a removal or remedial action, the contract Statement (or Scope) of Work should identify these requirements. The contractor’s cost estimation may be subject to audits, thus the 

contractor must be able to justify the process. 

Installations shall include an evaluation of environmental liability disclosure practices as a part of any installation-specific environmental self-auditing programs, 

such as the Army's Environmental Compliance Assessment System (ECAS). 

The ACSIM has directed that the USAEC will institute field audits to verify supporting documentation to the requirements identified for CTC. The USAEC conducts CTC reviews at selected Army BRAC sites. The USAEC will use the 

following protocol to determine sites selected for review: 

¡ Sites with deficiencies identified during previous audits. 

¡ Sites with RA costs greater than $5 million scheduled for execution in the 

current or next fiscal year. 

¡ Sites where cleanup versus study phase estimates are disproportionate 

(e.g., large study cost with small cleanup costs, design costs with no associated cleanup costs, design costs greater that 40 percent of the associated 

cleanup costs). 

¡ Sites where there is a material change in the financial liability. A material 

change is defined as evidence that a change of more than 10 percent of the 

prior year ending balance (up or down) will occur.
 

 4-14 

4.2.5.5 CTC TRAINING

The USAEC has developed a formal training program to certify installation staff 

engaged in the preparation of CTC estimates, to include CTC estimates for munitions responses. Installations must schedule formal training programs (e.g., introductory training, recurring “refresher” training) for staff personnel engaged in the 

development of CTC estimates or preparation of environmental restoration liability reports. Installations shall document that staff received this training and maintain a record as a part of the audit trail for the annual financial statement. 

Installations shall update their CTC data in the spring of each year. Updates are 

due to the USAEC in May. CTC updates for all sites must reflect an installation’s 

total cleanup requirements. 
Program Development and Management 

 4-15 

4.3 BUDGETING

Budgets are determined based on several factors. The Defense goals and the following are taken into consideration: 

¡ Property transfer. 

¡ Program initiatives. 

¡ Statutory and legal requirements, including agreements with regulatory 

agencies. 

¡ The ability to execute cleanup projects in a given year and the feasibility 

of carrying out the activity in relation to other activities at the installation. 

¡ Cultural, social, and economic factors, including environmental justice 

considerations. 

¡ Short-term and long-term ecological effects and environmental impacts in 

general, including injury to natural resources and lost use. 

¡ Acceptability of the action to regulators, Native American tribes, and public stakeholders. 

¡ Availability of new and innovative technologies that are appropriate for 

use given site conditions. 

¡ Actual and anticipated funding availability.

The BRAC Division develops budgets after running the BRAC Optimization 

Model and providing the model output to the installations for use during the IAP 

Workshop and subsequent AEDB-R programming during August of each year. 

The BRAC Division consolidates the programmed requirements and utilizes this 

information for financial reporting such as the Financial Liabilities Statement, the 

President’s Budget, the Annual Report to Congress, the Program Objective 

Memorandum (POM) and the Budget Estimate Submission (BES). 

The BRAC Division develops the Army BRAC,ER budget by consolidating installation requirements as programmed in the AEDB-R database, Fall submission. 

As DERP activities progress to meet program goals, the budgets are adjusted 

based on the updated CTC database. 
 

 4-16 

4.4 FUNDING BRAC ACTIVITIES

The BRAC funding is maintained in the Office of the Secretary of Defense, Military Construction Appropriation (MILCON) and is comprised of five budget activities: 

¡ Construction. 

¡ Family Housing. 

¡ Operations and Maintenance. 

¡ Procurement. 

¡ Environmental.

The Army funds environmental requirements at BRAC installations through two 

different accounts:

¡ The BRAC Account (BCA) that includes all BRAC cleanup, MMRP, and 

closure related compliance; site specific EBS (FOST/FOSL); and Cultural 

and Natural Resources, environmental planning, and management costs 

¡ Operations and Maintenance, Army (OMA) Account that includes NEPA 

at BRAC sites and program management or activities not attributable to 

realignment/closure that benefits the entire program. 

MILCON, and, therefore, BCA, funding is a five-year account. Specific amounts 

are not appropriated for each budget activity and funds can be shifted among all 

BRAC requirements

4.4.1 Funding Categories

There are nine BRAC ERP categories of accounts addressing environmental activities: 

¡ Program Management. Program management includes salaries, travel, 

supplies, legal support, public involvement support, RAB administrative 

costs, and Technical Assistance for Public Participation (TAPP) costs. 

The BCA may fund public involvement activities related to restoration activities, such as the Community Relations Plan (CRP), CRP implementation, public meetings, and fact sheets. The TAPP program provides 

community members of RABs/TRCs with access to independent technical 

support using government purchase orders. Installations submit individual 

RAB/TAPP Cost Worksheets when identifying program management 

costs for the upcoming fiscal year. 
Program Development and Management 

 4-17 

¡ Cleanup Projects. Projects include: costs tracked by AEDB-R site, IRP 

and MMRP category response costs to execute remedial responses such as 

studies, removals, interim and final RAs, and LTM costs at cleanup sites. 

Contract administration costs (both prior and current year), in-house support, and any costs associated with execution of BRAC ERP activities 

tracked by site are also project costs. 

¡ DSMOA/CA. Funds include support to the DSMOA/CA program for 

state regulatory BRAC ERP services at Army installations. The USACE 

is the DoD Lead Agent for the DSMOA/CA. States propose DSMOA/CA 

eligible requirements for reimbursement to the Army through the USACE. 

See Section 6.9 for more information on DSMOA/CA. 

¡ ATSDR. The USACHPPM is the Army’s liaison and DoD’s Lead Agent 

for the ATSDR program. As the Lead Agent, USACHPPM reports on the 

status of the ATSDR program at the DoD IPRs. The USACHPPM provides the USAEC with the ATSDR draft Annual Plan of Work in Jun of 

each year. The USAEC reviews the proposed ATSDR budget for consistency with the approved BRAC Work Plan and eligibility for reimbursement. The USACHPPM provides installations with a schedule for site 

visits and document delivery by quarter. The USACHPPM will contact all 

installations prior to ATSDR activities at their installation. 

¡ USEPA Support. Funds include support to the USEPA for participation 

on BCT to expedite restoration activities in accordance with the President’s Five-Part Plan for Community Reinvestment. The USEPA proposes eligible support requirements to BRAC Division for reimbursement. 

¡ Cultural and Natural Resources. Referred to as planning requirements, 

cultural and natural resource requirements ensure that base closures and 

realignments do not destroy significant parts of the nation’s heritage, both 

man-made and the natural environment. 

¡ NEPA Documentation. Referred to as planning requirements, NEPA requirements document impacts, irreversible effects and alternatives to 

BRAC environmental actions that significantly affect the quality of the 

human environment. 

The Army funds closure-related environmental compliance cleanup projects from 

a different category than the BRAC ERP category but are part of the BRAC environmental line in the budget. Projects include costs to execute remedial responses 

such as studies, removals, interim and final RAs, and LTM of closure-related 

compliance projects that support property transfer. Contract administration costs 

(both prior and current year), USACE Division or District in-house support, and 

any costs associated with execution of BRAC ERP activities are also project 

costs. 
 

 4-18 

4.4.2 BRAC Work Plan

The BRAC Work Plan is developed from AEDB-R site level. The installations 

identify their BRAC ERP funding requirements for a particular year in the BRAC 

Work Plan. The BRAC Work Plan is a prioritized listing of the Army’s total 

BRAC ERP requirements listed by installation. The Army uses the BRAC Work 

Plan to track execution of the BRAC ERP. The BRAC Work Plan includes 

cleanup, closure-related compliance, and MMRP projects. The BRAC Work Plan 

also includes the proposed obligation of funds by month. 

4.4.2.1 PREPARATION OF THE BRAC WORK PLAN

The BRAC Division prepares the BRAC Work Plan for the current year and the 

program year (FY+1). The Army uses BRAC Optimization Model to prioritize 

BRAC program requirements. 

Installations are required to provide input to the BRAC Work Plans prior to the 

BRAC Work Plan Reviews held in January and June of each year. 

4.4.2.2 ADDITIONS TO THE BRAC WORK PLAN 

When unforeseen issues arise that take precedence over approved line items on 

the BRAC Work Plan, an installation identifies new requirements to be added to 

the work plan and identifies a bill-payer from their approved program to fund the 

new requirement to the BRAC FO and BRAC Division. Installations are responsible for ensuring that any new requirements executed by USACE are fully coordinated with the executing Corps District and HQUSACE. If an Army 

Management Structure (AMS) code does not exist for a project, the BRAC Division must provide the new AMS code and title. The BRAC Division will ensure 

that new codes are entered into the DFAS-IN Pamphlet 37-100-XXXX (where 

XXXX represents the FY) at which time funds can be distributed. 

4.4.2.3 BRAC WORK PLAN REVIEWS

The BRAC Division holds meetings semi-annually, in January and June, with the 

BRAC FO and installations to review execution of the BRAC ERP and discuss 

BRAC ERP issues. At these reviews, the installations brief the BRAC Division 

on their progress in obligating current year Work Plans and any changes to the 

BRAC Work Plan. Requirements for the next two years are also collected, revised, and presented, 

4.4.3 Priority Setting and Sequencing

This section discusses the establishment of priorities and the sequencing of BRAC 

ERP work during a given fiscal year.
Program Development and Management 

 4-19 

4.4.3.1 PROGRAM PRIORITIES

The BRAC Division accomplishes prioritization and sequencing of BRAC ERP 

activities to meet the FMR goals using: 

¡ Imminent threat to human health and the environment. 

¡ Beneficial reuse. 

¡ Legally enforceable requirements. 

¡ Relative risk. 

¡ Earlier funding decisions. 

¡ Other management factors. 

Factors other than reuse and risk to human health and the environment may influence the sequencing of work at sites and the site’s priority for funding. Other 

management factors include:

¡ Program goals and initiatives. 

¡ Ability to execute cleanup projects in a given year and the feasibility of 

carrying out the activity in relation to other activities at the facility. 

¡ Cultural, social, and economic factors, including environmental justice 

considerations. 

¡ Short-term and long term ecological effects and environmental impacts in 

general, including damage to natural resources and lost use. 

¡ Acceptability of the action to regulators, tribes, and public stakeholders. 

¡ Availability of new and innovative technologies. 

¡ Actual and anticipated funding availability. 

4.4.3.2 SEQUENCING WORK

The BRAC Division has implemented the BRAC Optimization Model to assist in 

sequencing work. The BRAC installations annually enter CTC requirements into 

AEDB-R by site and by phase; requirements are then imported into the BRAC 

Optimization Model. The model generates a report that sequences work based on 

available funding levels. The BRAC Division shares the report with the BRAC 

FO for review and comment. The BRAC Division may run the Optimization 

Model several times to adjust the input and prioritization scheme. When the 
 

 4-20 

BRAC Division completes the sequencing of sites, data is exported back into the 

AEDB-R to establish by site/by phase level budgets.

4.4.4 Funds Distribution

The BRAC funds are distributed through the BRAC FO to the installations, the 

USAEC, and the USACE on a semiannual basis. 

Installations must use the web based BRAC Financial Module request process to 

request funds from the BRAC Division. 

4.4.5 Tracking and Reporting

Obligations, disbursement, reimbursement, cost recovery and cost sharing are 

tracked and reported in the BRAC accounting process. 

4.4.5.1 OBLIGATION

The BRAC Division tracks obligations through the web based BRAC Financial 

Module. Quarterly, BRAC Division will meet with all staff and executers to review obligations. 

4.4.5.2 DISBURSEMENT

The BRAC Division coordinates with appropriate financial offices using the Defense Financial Accounting System (DFAS) to track disbursements. The BRAC 

Division reviews disbursements with executers at semi-annual reviews and at the 

Semi-Annual Work Plan Meeting.

4.4.6 Reimbursement for Non-Army Activities

While highly discouraged by DoD, an Interagency Agreement/Federal Facilities 

Agreement (IAG/FFA) may stipulate that the Army will reimburse other federal 

agencies for services associated with cleanup. These services must be those that 

the Army does not have the capability of providing and are incidental to cleanup. 

The outside agency requesting reimbursement must submit a proposed annual 

budget to the installation prior to development of the upcoming fiscal year budget. 

The proposed annual budget is categorized into tasks developed in accordance 

with the scope of work contained in the agreement. The Army will only reimburse the outside agency for those specifically approved tasks. 

All requests for reimbursement of services to federal agencies outside the Army 

are processed in accordance with the Economy Act (31 U.S.C. §1538). The Army 

certifies that use of funds is legal under the Economy Act. The Army approves 

and reimburses only those costs that directly support the Army’s environmental 

mission and are not part of the supporting agency’s Congressionally funded mis-
Program Development and Management 

 4-21 

sion. Installations should contact their resource management and legal offices 

with any questions concerning the Economy Act and reimbursement of services 

provided by agencies outside the Army.

4.4.7 Cost Recovery and Cost Sharing

CERCLA authorizes the Army to pursue recovery of response costs of $50,000 or 

more from either contractors or other entities that are responsible or partly responsible for environmental damage on Army installations. As early as possible in the 

BRAC ERP, BRAC installations must identify CERCLA Potentially Responsible 

Party (PRP) and pursue them to either take responsibility for BRAC cleanups or 

to contribute to the cost of response actions, on a total cost recovery or contribution basis, as appropriate. 

The Environmental Law Division (ELD), Office of the Judge Advocate General 

(OTJAG), is responsible for coordinating with the Department of Justice (DOJ) to 

pursue claims against such parties. The ELD Litigation Branch typically requests 

the installation’s local counsel to prepare a litigation report regarding the proposed claims. When cost recovery or contribution claims appear to be possible, 

the installation, in coordination with the DOJ, will retain records and documents, 

and maintain all costs and project documentation necessary to support cost recovery claims against the PRPs. 

Installations will report all attempts to recover response costs to the USAEC, who 

will inform ODUSD (I&E) through the Army Staff and Army Secretariat. If an 

installation decides that it is not in the best interest of the government to pursue a 

cost recovery, the installation will inform the USAEC and the ODUSD (I&E) of 

its rationale. 

Installations must report the following cost recovery and cost sharing information, 

which will be included in the DERP Annual Report to Congress: 

¡ Installation name. 

¡ City (or county if appropriate) and state where the installation is located. 

¡ Type of Action (Cost Recovery or Cost Sharing). 

¡ Status of cost recovery actions. 

¡ Investigate status of recovery actions deemed sufficient to pursue. 

¡ Cost recovery reported in a previous annual report that has since been determined not to benefit the government. The installation shall report the 

status as “Not Feasible” or “No Cost to be Recovered” and provide a brief 

but complete explanation for the decision. 
 

 4-22 

More information on FMR goals is available on the Internet at 

http://www.dod.mil/comptroller/fmr/02b/Chapter13.pdf

See Appendix H for a detailed explanation of BRAC ERP goals. 

¡ Total amount recovered or shared with another PRP or amount recovered 

from a negligent DoD contractor, as of the end of the reported fiscal year. 

¡ Where the Army initiated recovery actions and recovered some costs, the 

total amount recovered as of the end of the reported fiscal year. If recovery actions are underway and no costs were recovered by the end of the 

reported fiscal year, installations shall report $0 recovered. 

¡ Total costs spent in legal and management costs to pursue recovery, as of 

the end of the reported fiscal year. 

¡ Where recovery actions are underway or completed, the cost to pursue the 

action as of the end of the reported fiscal year. 

¡ Where the cost to pursue the action has not been determined but will be 

determined later, “TBD.”

4.5 EXECUTION STRATEGY

The DoD and the Army have established four goals for the BRAC ERP that must 

be met during program execution.

4.5.1 Obligation Goals

The DoD goal for obligation of funds is 28 percent by first quarter, 55 percent by 

second quarter, 80 percent by third quarter, and 100 percent by fourth quarter of 

each fiscal year. 

4.5.2 Financial Management Regulation (FMR) Goals 

¡ The Army must meet the goals cited in the FMR. The FMR requires that, 

by the end of FY2005, 100 percent of the acres in BRAC categories 5, 6, 

and 7 identified in the end-of-FY 96 baseline will be environmentally suitable for transfer and 100 percent of installations will have all sites with 

remedial systems in place or responses complete. 

4.5.3 Army Cleanup Strategy Goals for BRAC

In 2003, the Army identified program goals in its Cleanup Strategy and corresponding Strategic Plan. The primary goals are to identify common objectives for 
Program Development and Management 

 4-23 

creating consistency and accountability across the Army’s cleanup program and to 

provide direction to implement a cost effective program. 

4.5.4 Disbursement Goals

To ensure that all BRAC ERP funds are disbursed in a timely fashion, the following goals have been established by DoD: 

Year of obligation Cumulative disbursement of funds 

Initial year 22% 22% 

Second year 45% 67% 

Third year 22% 89% 

Fourth year 6% 95% 

Fifth year 5% 100% 

 

4.5.5 Program Management Goals

The Army’s execution goal is to limit total Army program management funds to 

10 percent of the BRAC budget. 

4.6 PERFORMANCE MEASURES

The DoD and the Army have established Work Plan Reviews, ESOH Management Review, and Measures of Merit (MOMs) as performance measures for the 

BRAC ERP. The Army evaluates its performance annually and reports its BRAC 

ERP accomplishments to DoD to for inclusion in the DERP Annual Report to 

Congress. 

4.6.1 Work Plan Review

The BRAC Division and the USAEC will hold meetings with the installations to 

review execution of the BRAC ERP and discuss issues on a semi-annual basis. 

The BRAC Division sends a memorandum detailing specific requirements of the 

Work Plan meeting to the field 30 days prior to the meeting. At these reviews, the 

installations will brief BRAC Division and the USAEC of its progress towards 

obligation of their Annual Funding Plan and any additions to the BRAC Work 

Plan. 

4.6.2 DoD Management Review

The ODUSD (I&E) requires that the Army monitor program progress and report 

semi-annually in June and December/January of each year. The Army uses BCPs 
 

 4-24 

and BCP Abstracts, AEDB-R data, RRSE data, budget data, and CTC information 

to report DERP status in support of the Army BRAC ERP. 

4.6.3 Measures of Merit (MOMs)

The MOMs are the tools used by ODUSD (I&E) to measure the Army’s progress 

toward goals set forth in its planning guidance, the DPG. There are four MOMs 

for BRAC environmental cleanup that the Army reports to OSUSD (I&E) semiannually at the IPR. 

¡ Relative Risk Reduction - This MOM tracks both site counts and funding 

for each relative risk category. The desired trend is toward a lower number of sites in the “High” relative risk category. 

¡ Phase Progress - This MOM tracks the number of sites in study, cleanup, 

and RC/no further action required categories. Progress is indicated as sites 

go from the investigation phase and cleanup phase to the RCor no further 

action required categories. The desired trend is toward an increasing 

number of sites going from investigation to cleanup to closeout. 

¡ Installations Achieving Final Remedy-In-Place/RC - This MOM tracks the 

number of installations that have all sites in the “Remedy-in-Place” or 

“RC” categories. The desired trend is toward an increasing number of 

sites in the “Remedy-in-Place” and “RC” categories. 

¡ Acres suitable for transfer under CERCLA - This MOM tracks the number 

of acres based on the environmental condition of property (ECOP) categories 1-7 defined and described in the BRAC Cleanup Plan Guidebook. 

The desired trend is for the number of acres in categories 2 through 4 to 

increase over time as properties are remediated or remedies are in-place 

and are operating properly and successfully. All category 5, 6, 7 acres 

should be categories 2 through 4 by the end of FY2005. 

Until MOMs have been developed for the MMRP, the Army will track the performance of MRS separately from IRP sites, but will use the same MOM criteria 

as the IRP: Risk Reduction, Phase Progress, Milestones Accomplished, and Installations Achieving Final Remedy-in-Place.

4.6.4 Army Cleanup Strategic Plan Goals

In 2003, the Army implemented a new Cleanup Strategy and identified program 

goals in its corresponding Cleanup Strategic Plan. The primary goals are to identify common objectives for creating consistency and accountability across the 

Army’s cleanup program and to provide direction to implement a cost effective 

program. 

See Appendix H for a detailed explanation of Army Cleanup Strategic Plan 

Goals for BRAC
Program Development and Management 

 4-25 

The DERP Annual Report to Congress is available on the DoD internet home 

page at http://www.dtic.mil/DERP/DERP.htm.

4.6.5 DERP Annual Report to Congress

The Congress requires DoD to submit an annual Report to Congress that describes 

the DERP accomplishments during the previous fiscal year. The report details 

progress made in carrying out environmental restoration activities at military installations, including success stories highlighting significant DERP activities and 

initiatives; narrative summaries for NPL installations, proposed NPL installations, 

and major BRAC installations; and the status of the cleanup. At the end of each 

FY, the USAEC requests that installations submit success story candidates and 

provide information for narrative summaries. 

The AEDB-R Fall Data submission is a critical source of information for the Report to Congress. Therefore, installations should ensure that the AEDB-R data is 

updated and submitted as required. Updates begin in August/September of each 

year. The USAEC then compiles and submits the Army’s input to DoD. The 

DoD must then submit the report to Congress by 31 March of each year. 

4.7 PROGRAM TIMELINES

¡ Oct Report to Congress Draft Narratives 

AEDB-R fall data submission including programmed CTC requirements 

Financed Liabilities Report Due 

Closeout Obligation Plan for prior FY due 

¡ Nov Fall AEDB-R forwarded to thru ODEP/ESOH to DoD 

Semi-Annual BCP Abstract submission 

Report to Congress Success Stories and Narratives submitted 

Army Management Review 

¡ Dec ESOH Management Review 

¡ Jan BRAC Work Plan Review Meeting 

President’s Budget submitted 

¡ Feb AEDB-R spring data call begins 

Begin update of CTC requirements 

Begin POM process 

Begin update of CTC requirements 

BECs contact SPMs for DSMOA 

¡ Mar 31 Annual DERP Report to Congress submitted by DoD 
 

 4-26 

¡ Apr AEDB-R spring data submission 

CTC requirements due to USAEC 

¡ May Run BRAC Optimization Model 

Spring AEDB-R forwarded thru ODEP/ESOH to DoD 

¡ June BRAC Work Plan Review Meeting 

Army Management Review 

ESOH Management Review 

Draft FY+1 Work Plan 

POM submission 

¡ July Second Run of BRAC Optimization Model 

¡ Aug Results of BRAC Optimization Model imported into AEDB-R 

AEDB-R fall data call begins 

Final FY+1 Work Plan 

¡ Sept Installations match phase schedules to the BRAC 

Optimization Model program 

Report to Congress Success Stories and Narratives Submitted 
 5-1 

Chapter 5 

Program Execution

The BRAC installation executes the BRAC ERP. The Garrison Commander, or 

other designated authority where there is no Garrison Commander, is accountable 

for the installation’s BRAC ERP. The BEC, BCT, the designated executor of 

Army restoration projects, the USAEC, and the BRAC Division all play a role in 

the execution of the Army’s BRAC ERP. 

5.1 INSTALLATION

The Garrison Commander is responsible for execution of the restoration program. 

Where there is no Garrison Commander at a BRAC installation, the BRAC Division designates an alternate authority. For NGB BRAC ERP activities, the NGB 

may act as the installation and becomes responsible for environmental reporting. 

The Garrison Commander (or other designated authority), in coordination with 

the BRAC Division, assigns a BEC to ensure all work is accomplished in accordance with regulatory, DoD, and Army policy. If the BRAC Division determines 

a full-time BEC is not required, a FTC POC is appointed. The BEC/FTC POC is 

the installation’s primary restoration point of contact with the installation BCT, 

BTC, the program executor, ATSDR, USACHPPM, USAEC, BRAC Division, 

and the public. The Garrison Commander or a designee will also approve all required ESS, CSS and/or explosive or CWM site plans being submitted, through 

USATCES, to the DDESB for approval for properties for which the installation is 

responsible. 

The BEC/FTC POC duties include:

¡ Work with regulators and serve as the sole point of interface with all regulators. 

¡ Execute the environmental restoration Community Relations Program, including determining interest and, if appropriate, developing a RAB or 

chairing a TRC, establishing and maintaining the public repository, and 

administrative record. 

¡ Prepare and submit BCPs/BCP Abstracts, AEDB-R and CTC updates, 

BRAC Work Plan input, appropriate Environmental Program Requirement 

reports, and related changes through the BRAC FO to BRAC Division and 

the USAEC. 
 

 5-2 

¡ Include ATSDR recommendations from the Public Health Assessment 

into the BCP/BCP Abstracts. 

¡ Implement projects, including identification of funding and reporting requirements and programs necessary BRAC ERP funds through work 

plans, CTC, and AEDB-R with estimates of cost and time requirements 

for performance of specific tasks. 

¡ Ensure that only certified individuals who are properly trained in the 

RACER program develops the CTC and ensure that the CTC has a fully 

auditable trail. 

¡ Select a BRAC ERP Executor to conduct environmental restoration projects. 

¡ Assign tasks to the BRAC program executor describing the general scope 

of activities and provide project criteria, goals and general milestones for 

restoration work. Installations should obtain maximum competition when 

selecting project management services. 

¡ Provide appropriate funds, in coordination with the BRAC Field Office, to 

the program executor for all work required. The BEC/FTC POC ensures 

that funds are allocated to eligible projects only. The installation or 

BRAC ERP Executor ensures that their resource management office account for restoration funds in accordance with DFAS-IN Manual 37-100-

XXXX. 

¡ Approve proposed schedules and deadlines for all tasks and deliverables 

and provides comments and approvals to the program executor on items 

such as scopes of work and project documents in accordance with approved schedules. 

¡ Provide guidance to the program executor concerning all interpretations of 

statutes and regulations that may effect performance of a task and document any deviations from DoD or Army policy. The BEC/FTCPOC is responsible for obtaining concurrence from their MACOM of any deviations 

from policy and guidance. 

¡ Coordinate with the program executor to resolve any impediment to completion of the task on or before the stated deadlines and at or below the 

stated costs. If the program executor fails to meet a deadline resulting in a 

penalty to the Army, the installation BEC/FTC POC is responsible for notifying the BRAC FO, USAEC and the BRAC Division of the penalty and 

any associated costs. 

¡ Provide copies of project documents for review and comment through the 

BRAC FO to appropriate Army proponents of the BRAC ERP such as the 

USAEC, USACHPPM, and ATSDR (when appropriate). 
Program Execution 

 5-3 

¡ Provide copies of all RODs/DD for review and concurrence through the 

BRAC FO to USAEC and USACHPPM prior to release of funds for removal/interim/ RA contracts. 

¡ Evaluate the executor's ability to meet schedules, communicate with the 

installation staff, provide quality reports, effectively use available funding 

resources, etc. If the executor's performance is unsatisfactory, notify the 

Garrison Commander or other designated authority who will contact the 

commander of the executing agency and attempt to resolve the issues. If 

the quality of performance by the executor continues to be unsatisfactory, 

the Garrison Commander or other designated authority may transfer execution to another performer. Appropriate notifications shall be made to 

the executor so that funds can be recovered and redirected to the new performer. 

¡ Coordinate and consult with installation legal counsel on all environmental agreements; coordinate with USAEC on all agreements impacting 

the BRAC ERP. Installation counsel should involve the Environmental 

Law Division, Office of the Judge Advocate General (OTJAG)when 

agreements might be inconsistent with Army/DoD policy. 

5.2 BRAC CLEANUP TEAM (BCT) 

Under FTC, each installation making property available for transfer to the community assembles a BCT, unless the BRAC Division determines a full-time BEC 

is not required. In that case, a FTC POC is appointed. A BCT is not required at 

installations where there is no BEC. 

The BEC (representing the Army), USEPA, and state environmental regulatory 

agency representatives make up the BCT. The BCT acts as the primary forum to 

address issues affecting the execution of cleanup to facilitate reuse. . BCTs, with 

input at the community level from stakeholders (e.g., LRAs and RABs), have the 

technical expertise to engage in real-time decision-making, reduce unnecessary 

documentation, and identify innovative ways to accomplish cleanup. 

The BCT responsibilities include management of the five-step BCP process and 

the preparation of the installation’s BCP. The BCT conducts a “bottom up” program review of the installation’s environmental programs to facilitate preparation 

of the BCP. This team approach is designed to accelerate cleanup to make property available for transfer while ensuring protection of human health and the environment. However, the BCT does not replace the need to use the Army chain-ofcommand, nor can the BCT commit the Army to spend funds. It is the BEC’s responsibility to work with the Garrison Commander and the BRAC Field Office on 

these issues. The BCT meets routinely to review the cleanup process underway, 

to evaluate methods, to handle problems that develop, and to discuss how to integrate environmental cleanup priorities with reuse needs.
 

 5-4 

5.3 BRAC ERP EXECUTOR

The DERP Executor conducts environmental responses at BRAC installations. 

The USACE and the USACHPPM may execute specific projects for the DERP. 

The USACE established Hazardous, Toxic and Radiological Waste (HTRW) Design Districts for executing environmental cleanup activities and Military Munitions Center of Expertise (MM CX) Design Centers for executing munitions 

responses, including those of the Army BRAC ERP. The USACE District Project 

Manager coordinates the support of the districts and center. Each HTRW and 

MM CX Design District works within specific geographic boundaries. The Director of Military Programs at HQUSACE may grant approval for an installation 

to use a USACE District outside of the designated geographic boundary. 

The BRAC ERP Executor duties are as follows:

¡ Assign a project manager to be the primary point of contact for the BEC/ 

FTC POC. The project manager completes tasks under the authority and 

direction of the installation BEC/FTC POC. 

¡ Provide estimates of costs and time requirements for performance of specific tasks forwarded by the installation. The estimates include in-house 

costs, specific contract and pricing data, and costs charged for contract supervisory and administrative services applicable to each FY for the contract administration. The project manager uses historical cost data from 

analytical laboratories to ensure the executor can negotiate the lowest 

available price. 

¡ Propose schedules for all deliverables and accomplish all tasks within time 

deadlines set forth by the installation. Tasks will not be considered complete until reviews are prepared for all work performed and accepted by 

the installation BEC/FTC POC. 

¡ Recognize the installation BEC/FTC POC as the sole point of interface 

with all environmental regulators, report any contacts by regulators immediately and attend all meetings as requested by the installation BEC/FTC 

POC. 

¡ Request specific approval from the installation BEC/FTC POC before release for publication of any information gathered. The program executor 

will not release any information concerning the installation's restoration 

program without approval from the installation BEC/FTC POC. 

¡ Use existing contracts before initiating new contracts for environmental 

work. 
Program Execution 

 5-5 

5.4 US ARMY ENVIRONMENTAL CENTER (USAEC)

The USAEC is a FOA under the direction of the ACSIM. The USAEC provides 

support to BRAC Division for the BRAC ERP and provides a broad range of program management and oversight services in support of the BRAC Division and 

installations. 

5.4.1 Technical Review and Assistance

In support of the BRAC Division, the USAEC conducts the HQDA-initiated independent technical review and assistance programs (see Section 6.5). The 

USAEC compiles teams of independent technical experts that review specific 

remediation projects for installations and provide recommendations concerning 

the technical feasibility of the projects.

5.4.2 Restoration Oversight

The USAEC also has an oversight function for all BRAC Army installations. In 

addition to overseeing execution of the BRAC ERP for the BRAC Division, the 

USAEC provides technical assistance with AEDB-R updates and other revisions 

including BCP Abstracts, CTC updates, and guidance in the BRAC ERP process. 

The USAEC uses the BCPs/BCP Abstracts, in conjunction with the installation 

BRAC Work Plans, to oversee and track the progress of the BRAC ERP at each 

installation. 

5.4.3 HQDA Support

The USAEC supports business initiatives of HQDA with site review, technical 

evaluation, and final selection of Performance-Based Contracting (PBC) (see Section 6.5.4).

5.4.4 Environmental Restoration Managers (ERMs) 

The USAEC ERMs are responsible for the technical programmatic oversight of 

the BRAC ERP for installations assigned to them. The ERMs provide quality assurance on the data provided by installations for use in reporting Army requirements. All requirements must meet Army criteria for eligibility and must have 

RRSEs/RACs completed in accordance with current Army guidance. 

The ERMs coordinate with assigned installations and the associated BRAC FO 

POCS prior to installation site visits and notify same of any issues that arise from 

the site visit. Installations will submit BRAC ERP project documents to the assigned USAEC ERMs for review. The ERMs submit copies of final Program 

documents to the Army’s Technical Information Center, the centralized repository 

of all Army environmental documents located at the USAEC, Aberdeen Proving 

Ground, MD. 
 

 5-6 

To obtain USAEC ERM POC information for a specific installation, contact the 

USAEC’s Cleanup Division at DSN 584-3461 or commercial (410) 436-3461. 

USAEC ERM duties include:

¡ Work as closely as possible with the installation, BEC, and BCT but maintain Army perspective and objectivity. 

¡ Assess program viability; ensure schedules, cost and approach are consistent and reasonable; ensure program planning includes closeout focus and 

strategy. 

¡ Identify possible roadblocks to progress and work with the installation to 

overcome those roadblocks. Enlist the resources necessary to get programs on track. 

¡ Review Technical Documents (RI/FS & RFI/CMS documents): 

h Coordinate reviews, including Groundwater Extraction and Treatment 

Effectiveness Review (GWETER), with USACHPPM/USAEC technical support. 

h Ensure Data Quality Objectives are identified. 

h Ensure plans detail an acceptable technical approach. 

h Ensure plans support decision points.

¡ Review Proposed Plans, DD, and RODs:

h Work with installation on Army position at the RI/FS stage. 

h Ensure proposed plans and DD reflect Army position. 

h Coordinate USACHPPM and Legal input and review. 

¡ Perform quality assurance checks on program management data and coordinate corrections with the installations. 

¡ Identify opportunities where use of Performance-Based Contracts (PBC) 

will enable more efficient use of funds and/or site closeout. Monitor obligation performance against installation obligation plans and work with the 

installations to expedite actions.
Program Execution 

 5-7 

5.5 US ARMY CENTER FOR HEALTH PROMOTION AND 

PREVENTIVE MEDICINE (USACHPPM)

The USACHPPM provides medical and health related oversight of Army restoration activities and serves as the Army Liaison and the DoD Lead Agent for the 

Agency for Toxic Substances and Disease Registry (ATSDR). The USACHPPM 

provides oversight of the preparation of Public Health Assessments, health consultations, health studies, responses to citizens’ petitions and public health education activities; and reports on the status of the ATSDR program at the DoD IPRs. 

The USACHPPM also reviews and concurs on human health risk assessments and 

Decision Documents (RODs/DD) for the Army Surgeon General and reviews ecological risk assessments. 

5.6 BRAC DIVISION AND BRAC FIELD OFFICES (FO)

The BRAC Division, under the direction of the ACSIM, is the Army’s program 

manager for all BRAC activities. The BRAC Division provides guidance to the 

installations on the execution of program requirements and directs distribution of 

all BCA funds for the BRAC ERP. 

The BRAC Division and its designated FO have responsibility for managing 

DERP progress at non-BRAC excess installations. These offices work closely 

with USAEC to identify and prioritize DERP activities. The BRAC Division and 

designated FO also have the responsibility of facilitating property transfer. 

5.7 U.S. ARMY TECHNICAL CENTER FOR EXPLOSIVE 

SAFETY (USATCES) 

The USATCES reviews and approves all Explosive Safety Submissions (ESS), 

Chemical Safety Submissions and/or explosive or CWM site plans for consistency 

with DoD Explosives Safety Standards (DoDD 6055.9-STD) and with DoD and 

Army explosives safety policies. USATCES also reviews the explosives safety 

provisions (e.g., land use controls or explosive safety-related notices) of transfer 

documents (e.g., leases, deeds, findings of suitability for transfer) for property 

known or suspected to contain MEC or residual explosive hazards that, per DoDD 

6055.9-STD, must be submitted to the DDESB for review and approval prior to 

the transfer. 

The ESS and explosive site plan are critical documents for munitions responses to 

MEC. A DDESB-approved approved ESS is required prior to implementation of 

the agreed upon munitions response to MEC. The purpose of the ESS is to ensure 

that all applicable DoD and DA explosive safety standards are applied during a 

munitions response. See Sections 6.15.2. and 6.15.3 

 6-1 

Chapter 6 

Program Procedures

The BRAC ERP addresses the Army’s cleanup responsibilities under CERCLA 

for transferring Army properties closed or realigned pursuant to the BRAC process

1

. The following sections address certain property transfer environmental requirements, that are involved under the BRAC ERP. 

6.1 DECISION DOCUMENTS (DD)

The term “Decision Document” encompasses RODs and Action Memoranda for 

remedies and removals, and Statements of Basis for RCRA corrective actions. 

Installations will maintain all DDs in the installation Administrative Record and 

their permanent environmental files and provide copies to USAEC. 

6.1.1 CERCLA REMEDIAL RECORDS OF DECISION 

(ROD)/DECISION DOCUMENTS (DD)

Under the CERCLA/NCP RA process at both NPL and non-NPL sites, a remedy 

must be selected and documented in a ROD (for NPL) or DD following receipt of 

the Proposed Plan, public comments, and consultation with the regulators. The 

ROD or DD serves as certification that the Army selected the remedy pursuant to 

CERCLA Section 104 and following the process in CERCLA Section 120 and the 

NCP Section 300.430. All RODs must explain how the NCP’s nine evaluation 

criteria2

 were used to select a remedy.3 All facts, analyses of facts, and sitespecific policy determinations considered in implementing a remedy should be 

documented in a ROD in an appropriate level of detail.4

 A ROD describes the site 

and types of contamination at issue, outlining the risks being addressed. The FS 

alternatives are summarized with a discussion of why the selected alternative was 

chosen. A ROD explains why the remedy is protective of human health and the 

environment and the applicable or relevant and appropriate requirements 

 1

 10 USC 2687, note 

2

 The nine NCP criteria are: overall protection of human health and the environment; compliance with applicable or relevant and appropriate requirements; long-term effectiveness and permanence; reduction of toxicity, mobility, or volume through treatment; short-term effectiveness; 

implementability; cost; state acceptance; and community acceptance. These criteria and a brief 

explanation of their scope can be found in 40 Code of Federal Regulations 300.430(e)(9) and 

(f)(1). These criteria are based on the requirements in CERCLA section 121 (42 U.S.C. 9621). 

For a further explanation of the 9 NCP criteria, see 55 Federal Register at 8719 (March 8,1990). 

3 40 CFR 300.430(f)(5)(i). 

4

 40 CFR 300.430(f)(5)(i). See also 55 FR at 8731 (March 8,1990), for a general description 

concerning decision documentation. 
 

 6-2 

(ARARs) of other federal and state laws to be attained.5

 There should also be a 

description of how the technical aspects of the remedy will address the specific 

site contaminants and whether five-year reviews are needed.6

 A ROD should also 

show how the remedy is cost-effective proportional to its protectiveness.7

 

A ROD should contain the following nine parts: 

a. Site Conditions and Background 

b. Current and Potential Future Land/ Water Use 

c. Site Risks 

d. Remedial Action Objectives8 

e. Description and Comparative Analysis of Alternatives9

f. Description, Cost and Outcome of Selected Remedy 

g. Statutory Determinations (ARARs & Periodic Review)10

h. Responsiveness Summary(i.e., summary of responses/significant 

comments)11

i. Declaration of Remedy & Signature 

Pursuant to NCP §300.430 (f)(6), after the ROD is signed, the Army is required 

to: 

¡ Publish a notice of the availability of the ROD in a major local newspaper 

of general circulation (the USEPA will publish the notice in the Federal 

Register). 

¡ Make the ROD available for public inspection and copying at the information repositories located on or near the facility prior to the commencement 

of any RA. 

 5 40 CFR 300.430(f)(ii)(A) and (B). 

6

 40 CFR 300.430(f)(5)(ii)(E) and 300.430(f)(iii)(C). 7

 40 CFR 300.430(f)(5)(ii)(D).

8

 40 CFR 300.430(f)(5)(iii)(A). 

9 40 CFR 300.430(f)(5)(ii). 

10 40 CFR 300.430(f)(5)(ii) identifies the statutory requirements of CERCLA section 121 (42 

U.S.C. 9621). 11 40 CFR 300.430(f)(5)(iii)(B). See also USEPA, Solid Waste and Emergency Response, 

Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection 

Decision Documents, EPA540-R-98-031 (July 1999). 
Program Procedures 

 6-3 

Per CERCLA §120 (e)(2), the RA must commence within 15 months of signing 

the ROD. 

A signed ROD may be re-evaluated at any point during the RA process (i.e., during RD, before or after operations are in place, when the selected remedy is found 

to be ineffective, more stringent cleanup standards are promulgated, or if recently 

developed technology may be more beneficial towards cleanup). If, after reevaluation, the selected remedy fundamentally changes, the Army will have to 

modify or amend the ROD before the changes can be implemented (see Section 

6.1.4). 

6.1.2 Removal Action Memoranda/DDs 

An Action Memorandum serves as the primary DDsubstantiating the need for a 

removal response, identifying the proposed action, and explaining the rationale 

for the removal.12 There are, however, three types of removal actions: emergency, time-critical, and non-time critical. While the NCP does not explicitly 

categorize Removal Actions into these categories, USEPA uses these terms in implementation guidance.13 In emergency or time-critical situations, it may be necessary to initiate action prior to the preparation of an Action Memorandum.14 

Thus, documentation consistent with this guidance to the extent practicable may 

occur after the removal action for emergency or time critical removals. 

For non-time critical removals, or where time permits prior to time-critical removals, the Action Memorandum should contain the following six parts: 

1. Purpose 

2. Site Conditions and Background 

3. Threats to Public Health or Welfare or the Environment 

4. Proposed Action(s) and Estimated Cost (including identified ARARs) 

 12 See OSWER Dir. 9360.3-01, Superfund Removal Procedures Action Memorandum Guidance (Dec. 1990). 

13 For example, EPA Publication 9360.0-32, Guidance on Conducting NonTime-Critical Remedial Actions Under CERCLA, 1993, states that: EPA has 

categorized removal actions in three ways: emergency, time-critical, and nontime critical, based on the type of situation, the urgency and threat of the release 

or potential release, and the subsequent time frame in which the action must be 

initiated. Emergency and time-critical removal actions respond to releases requiring action within 6 months. Non-time-critical removal actions respond to releases 

requiring action that can start later than 6 months after the determination that a 

response is necessary. 

14 See OSWER Dir. 9360.3-01, Superfund Removal Procedures Action Memorandum Guidance, at page 5 (Dec. 1990). 
 

 6-4 

5. Recommendation 

6. Signature 

The Site Conditions and Background should include a site description and other 

actions to date. The NCP at 40 CFR 300.415(b) requires a determination that 

there is a threat to public health or welfare or the environment based on eight factors.15 Thus the Action Memorandum documents why removal (as opposed to 

remedial) action is appropriate.16 The Action Memorandum also describes the 

proposed action and estimated costs, including how the removal action, to the extent practicable, contributes to the efficient performance of any anticipated longterm RA (NCP at 40 CFR 300.415(c)). This section also discusses ARARs, 

which are to be attained to the extent practicable considering the exigencies of the 

situation. Non-time critical removals should also refer to the Engineering Evaluation/Cost Analysis (EE/CA) and discuss the alternative actions considered. 

6.1.3 Corrective Action Statements of Basis (SB)/DDs 

A SB or similar state designated document serves as the primary DD substantiating the need for a RCRA corrective RA with evaluation of the proposed remedy 

and other alternatives based on risk-based selection criteria. The regulator should 

prepare a SB when corrective action is implemented through either a permit or an 

enforcement order17. A SB is a remedial selection document similar in purpose to 

 15 The eight factors are: 

(i) Actual or potential exposure to nearby human populations, animals, or the food chain from 

hazardous substances or pollutants or contaminants 

(ii)Actual or potential contamination of drinking water supplies or sensitive ecosystems; 

(iii) Hazardous substances or pollutants or contaminants in drums, barrels, tanks, or other 

bulk storage containers, that may pose a threat of release; 

(iv) High levels of hazardous substances or pollutants or contaminants in soils largely at or 

near the surface, that may migrate; 

(v) Weather conditions that may cause hazardous substances or pollutants or contaminants to 

migrate or be released 

(vi) Threat of fire or explosion; 

(vii) The availability of other appropriate federal or state response mechanisms to respond to 

the release, and 

(viii) Other situations or factors that may pose threats to public health or welfare or the environment. 

16 See USEPA, Office of Enforcement and Compliance Assurance, Use of Non-Time-Critical 

Removal Authority in Superfund Response Action, February 14, 2000.

17 See OSWER Dir 9902.6, Guidance of RCRA Corrective Action Decision Documents: The 

Statement of Basis Final Decision and Response to Comments, (Feb 1991). Note that remedy 

selection and/or site closeout status should eventually be identified in the permit provisions concerning RCRA corrective action or if a corrective action order is updated. 
Program Procedures 

 6-5 

a CERCLA ROD. Because the SB is issued by a regulator, a CMS can serve as 

the DD for Army staffing purposes. 18

Although state specific requirements may vary somewhat, a DD/SB should contain the following six parts: 

1. Purpose 

2. Site Risk and Background 

3. Proposed Remedy and Scope of Corrective Action 

4. Summary of Alternatives 

5. Evaluation of the Proposed Remedy and Alternatives 

6. Public Participation if a RAB exists or permit conditions require 

7. Declaration and Signature 

The Site Risk and Background should include a site description of the contaminated media, the contaminants of concern, exposure pathways, the potential exposed population, and the level of risk to human health and the environment. The 

USEPA’s guidance on corrective action established a two-phased evaluation for 

remedy selection sufficient to meet first threshold then balancing criteria in order 

to identify the remedy that provides the best relative combination of attributes. A 

DD/SB should also describe how the scope of the proposed remedy fits into the 

overall IRP strategy and effectively balances treatment with exposure control for 

reasonably anticipated reuse.19 

6.1.4 DD Staffing and Approval Procedures

The review and approval procedures for DDs are contained in the DASA(ESOH) 

memorandum,7 August 2003, subject: Policies for Staffing and Approving Decision Documents. The portion of the 7 Aug 03 memorandum applicable to the 

Army BRAC installations is at Appendix G. 

 18 If a CMS is used as the DD for Army staffing purposes, the SB does not need to be restaffed unless there are significant differences between the CMS and the SB. 

19 See for use as guidance USEPA Proposed Rule for Corrective Action for Releases from 

Solid Waste Management Units at Hazardous Waste Management Facilities, 61 Federal Register 

19431. (May 1, 1996). Threshold criteria: Remedies must (1) be protective of human health and 

the environment; (2) attain media cleanup standards; (3) control the source(s) of releases so as to 

reduce or eliminate, to the extent practicable, further releases of hazardous waste that might pose 

threats to human health and the environment ; and (4) comply with applicable standards for waste 

management. Balancing criteria: For choosing among alternatives that meet the threshold criteria: 

(1) long-term reliability and effectiveness; (2) reduction of toxicity, mobility, or volume of wastes; 

(3) short-term effectiveness, (4) implementability, and (5) cost. 
 

 6-6 

6.1.4.1 RESPONSIBILITIES

Installations must ensure that DDs that commit the Army to future expenses are: 

¡ Legally sufficient and compliant with CERCLA, the NCP or RCRA requirements. 

¡ Eligible for BRAC ERP funding. 

¡ Included in the BRAC Work Plan. 

¡ Conform to priorities for risk reduction. 

The Army will not support funding ineligible actions with BRAC funds. Installations must fund those projects with installation operating or construction funds. 

Projects not complying with the above may require renegotiation of agreements 

with regulators. 

Installations must prepare DDs in accordance with applicable law, staff the DDs 

for review and concurrence on the selected action, and obtain the appropriate approvals prior to requesting the release of funds for award of a cleanup contract. 

For the most part, environmental remediation contracts should not be awarded 

prior to the approval of DDs. Such projects may be subject to contract modification and will be reported to the ACSIM during IPRs. Additionally, these projects 

can be challenged as being pre-selected in the ROD/NCP process. 

6.2 RECORDS MANAGEMENT

Installations must collect and retain environmental restoration records in accordance with applicable statutes and regulations and be consistent with USEPA 

guidelines. Environmental restoration records will be collected as they are generated or received in the course of the decision-making process. 

6.2.1 Administrative Record

Installations shall establish an Administrative Record that contains the documents 

that form the basis for the selection of a response action. The installation shall 

compile and maintain the Administrative Record in accordance with CERCLA 

and 40 CFR §300, Subpart I and USEPA guidance. 

The Administrative Record serves two purposes. First, the Administrative Record 

acts as a vehicle for public participation in selecting a response action. Second, 

judicial review of any issue concerning the adequacy of any response action is 

limited to the contents of the Administrative Record. Under this provision of 

CERCLA the Administrative Record is the sole source of documentation that can 

be used by a party challenging a response action. It is also the sole source of 
Program Procedures 

 6-7 

documents available for the defense of a response action by an installation. It is 

critical that the installation take care in compiling the Administrative Record. If 

the installation fails to compile a complete and accurate Administrative Record, it 

may significantly impact DoD's ability to defend, and the court's ability to review, 

a challenged decision. A permanent record of the data gathered to characterize a 

site and a clear audit trail of pertinent data analysis and resulting decisions and 

actions are required. 

The Administrative Record shall include, but is not limited to including: 

¡ Documents and materials containing information that may form a basis for 

the Army's selection of a response action. 

¡ Documents and materials available to the installation at the time the decision was made. 

¡ Documents and materials that were considered by or relied upon by the installation. 

¡ Documents and materials that were available to the installation at the time 

of a decision, even if the decision maker did not specifically consider 

those documents. 

¡ Privileged and non-privileged confidential documents and materials.

¡ Documents received, published, or made available to the public as required by CERCLA for removal or remedial site assessments or actions.

6.2.2 MMRP Documentation

For MMRP response actions, installations shall have a permanent record of the 

data gathered to characterize a site and a clear audit trail of pertinent data analysis 

and resulting decisions and actions. To the maximum extent practicable, the permanent record shall include sensor data that is digitally recorded and georeferenced. The ACSIM shall approve exceptions where digitally recording and 

geo-referencing are impractical. These data shall be included in the Administrative Record. 

6.2.3 Environmental Restoration Information System (ERIS) and 

Electronic Data Storage Requirements

The ACSIM established an Army policy that requires the storage of environmental restoration data in a centralized database. The ERIS was developed for 

this purpose and has replaced the outdated Installation Restoration Data Management Information System. The ACSIM expected all installations that have re-
 

 6-8 

See the 17 February 1999 memorandum from the ACSIM, subject: Policy on 

Electronic Storage of Environmental Restoration Data. See the 12 November 

2003 memorandum from the ACSIM, subject: Implementation Guidance for the 

Use of the ERIS. 

ceived BRAC funds to collect environmental restoration data to enter that data 

into the ERIS and to modify existing laboratory contracts accordingly. However, 

BRAC Division has not directed Army BRAC installations to use ERIS to meet 

their electronic data storage requirements. Therefore, use of the ERIS at BRAC 

installations for electronic data storage is voluntary. BRAC installations that elect 

not to use ERIS must document how the ACSIM requirement is being satisfied 

and must submit the documentation to their assigned USAEC ERM. 

6.3 PUBLIC HEALTH REQUIREMENTS

A Public Health Assessment (conducted by ATSDR) is required when an installation is proposed for the NPL or is the subject of a citizen’s petition. Upon proposal for the NPL, the installation is contacted by the USACHPPM. The Center 

instructs the installation on the requirements for a Public Health Assessment, the 

role of the ATSDR, and negotiates a schedule for an initial ATSDR site visit 

within 18 months of proposal to the NPL. The USACHPPM provides installations with a schedule for site visits and documents delivery by quarter. 

6.4 OFF-SITE RESPONSE ACTION

To fulfill its CERCLA responsibilities, the Army has the authority to conduct response actions outside of the installation boundaries, where the installation is reasonably considered to be the sole or the major source of the release. Off-site 

actions can be complex and often require extensive coordination with federal, 

state and private interests because of the lack of Army control over the off-site 

property. 

For DoD, only Explosive Ordnance Disposal (EOD) units have execution authority for explosives or munitions emergency response actions to control, mitigate, or 

eliminate the actual or potential threat encountered during an explosives or munitions emergency. 

AR 200-1 states that the DASA (ESOH) will approve all off-site response actions. 

However, since publication of the February 1997 AR 200-1, the DASA (ESOH) 

has designated authority to the Garrison Commander to approve off-site data collection to determine contamination migration and any off-post monitoring to en-
Program Procedures 

 6-9 

Requirements for notification procedures and the response plan can be obtained 

from DA PAM 200-1 Section 11-14. Available on the Internet at 

http://usapa.army.mil.

sure that contamination has not migrated off-site. If there is an actual or high potential threat to human health or safety on or off the installation, the DASA 

(ESOH) will be immediately notified by the BEC through USAEC and BRAC 

Division. The DASA (ESOH) approves off-post response actions to include either starting or stopping the provision of bottled water, alternative water supplies, 

wellhead treatment devices, or connection to a municipal water system. 

The installation must provide a response plan through the command chain (with 

information directly to USAEC) to the DASA (ESOH) for any off-site response 

actions. In emergencies, this plan may be submitted after receiving verbal or 

electronic approval from the DASA(ESOH) to respond.

6.5 TECHNICAL REVIEW AND ASSISTANCE

In support of the BRAC Division, the USAEC ensures that the BRAC ERP is 

conducted as effectively and efficiently as possible. Therefore, the USAEC has 

established a Technical Review and Assistance Branch within its Cleanup Division to provide both technical review of installation actions and technical assistance in developing sound technical approaches to cleanup problems. 

Independent Technical Review (ITR) was the initial project-level technical and 

legal review and assistance mechanism. This mechanism has been superceded by 

several initiatives that support the cleanup program. 

6.5.1 Site-Specific Technical Assistance 

Site-Specific Technical Assistance is useful in the development of investigative 

and cleanup plans. The overall objective of Site-Specific Technical Assistance is 

to meet the Army’s obligation to protect human health and the environment while 

ensuring that planned response actions are cost-effective. The Site-Specific 

Technical Assistance process provides access to top environmental experts from a 

variety of environmental disciplines. The assistance group reviews specific projects to determine whether the investigative approach, proposed actions, proposed 

monitoring plans, and exit strategies are technically and legally sound. The assistance is intended to improve decision-making and to support technically and legally sound initiatives. Site-specific technical assistance is adaptive and flexible 

to meet the needs of the Army. 
 

 6-10 

6.5.2 Groundwater Extraction and Treatment Effectiveness Review 

(GWETER)

The GWETER program focuses specifically on assessing the effectiveness of existing groundwater treatment systems. The primary purpose of these reviews is to 

determine whether there are more cost-effective alternatives to pump and treat 

that were not considered during initial remedy selection. These reviews use technical experts, from the government and regulatory agencies to ensure that existing 

systems have performance goals that define when cleanup is completed and systems can be shut down. In addition, these reviews are to be used to ensure that 

the systems are capable of meeting these performance goals in a reasonable period 

and that there are not new technologies that can meet these goals in a more cost 

effective manner. For example, protocols for determining the effectiveness of 

natural attenuation have matured and the use of natural attenuation in conjunction 

with a pump and treat system can be very cost effective. The GWETER examines 

the basis for risk management decisions and cost effective cleanup by analyzing 

all aspects of the groundwater exposure pathway. Secondarily, GWETER looks 

at pump and treat systems still in the proposed stage to insure that all alternatives 

to pump and treat are being considered. 

6.5.3 Principles of Environmental Restoration (PER) Workshop 

A number of general ITR recommendations have been quite common among a 

large percentage of installation projects reviewed. To address these recurring recommendations and lessons learned, USAEC developed an additional assistance 

program to provide environmental restoration assistance to the Army: The 

USAEC adopted the PER workshop to provide more streamlined and direct assistance to Army installations on specific issues, especially decision-based planning. 

This initiative is the result of an effort to capitalize on a training program developed jointly by the Department of Energy (DOE) and the USEPA to improve the 

DOE cleanup program. 

The purpose of the PER workshop is to provide tools and approaches that will 

help decision-makers collect appropriate investigative information and proceed 

more quickly to acceptable site closeout. The workshop stresses the need for 

early planning and development of data quality objectives and early development 

of exit criteria to ensure investigations and cleanups stay on track. The workshop 

is intended to: 

¡ Provide sufficient understanding of environmental restoration principles to 

ensure that proposed investigative and cleanup requirements are needed to 

support risk-based decisions and actions, and 

¡ Improve the process within which the installation project teams operate to 

better focus on the end objectives of the restoration program. 
Program Procedures 

 6-11 

Central to the PER workshop are four key principles of environmental restoration. 

These principles are: 

¡ Building an effective project management team. 

¡ Clear, concise, and accurate problem identification. 

¡ Early identification of possible response actions. 

¡ Uncertainties are inherent and will always need to be managed. 

The workshop addresses the applicability of these principles across the spectrum 

of restoration efforts - from site investigation planning through site closeout - and 

how they can be used to improve the decision-making process at most sites. 

6.5.4 Performance-Based Contracting (PBC)

For the Army’s active installations, the USAEC is playing a key role in establishing a formal PBC program. PBC is a concept based on reforms mandated to all 

Federal Agencies by the President’s Management Agenda, the Government Performance and Results Act of 1993, and the Federal Acquisition Streamlining Act 

of 1994. These reforms emphasized the need to maximize the focus on results 

instead of focusing on the process. Using this approach, the government no 

longer develops a prescriptive statement of work dictating how the contractor will 

achieve project milestones. Instead, a performance-based approach to environmental cleanup emphasizes the outcomes the contractor will achieve (e.g., RC, 

RIP) but does not specify how to achieve those end results. This approach allows 

private remediation firms the flexibility to conduct environmental cleanups in a 

manner that is cost effective for their company while still ensuring that safety is 

maintained, legal requirements are met, and required milestones are achieved. 

PBC allows the Army to buy environmental cleanups for a fixed price and at a set 

schedule. The Army maintains oversight of the cleanup and determines upfront 

(in consultation with the regulators) the desired outcome (typically remedy in 

place) that will be achieved. In guaranteed fixed price remediation contracts, the 

use of environmental insurance offers the Army protection from environmental 

liabilities. 

The PBC process involves three phases: 

¡ Initiation of the procurement process:

h Preparation of a Performance Work Statement or Statement of Objectives 

h Development of the Independent Government Cost Estimate (IGCE). 
 

 6-12 

Requirements for notification procedures and the response plan can be obtained 

from DA PAM 200-1 Section 11-14. For detailed information on PBC, contact 

the USAEC at 410-436-1528. For other Technical Review and Assistance information, contact USAEC’s Cleanup Division at 410-436-5793/1522 or DSN 

584-5793/1522.

h Development of the Request for Proposal by the contracting organization. 

h Scoping/Bidders Meeting at the installation to initiate the proposal 

process. 

¡ Evaluation of the proposals, negotiation, and award/non-award decision. 

¡ Contract oversight and deliverables.

Some remediation efforts may not be good candidates for a PBC. Restoration efforts where characterization data is sketchy or incomplete or where regulatory 

closure is not easily defined are not good candidates for this approach because of 

the high risk due to uncertainty. As the level of uncertainty increases so does the 

risk and high-risk projects may not be good candidates for the necessary environmental insurance. 

Monetary incentives may be included in a PBC in an effort to encourage a contractor to achieve regulatory closure on a particular site in an expedited manner. 

This approach can assist the Army in reducing out-year LTM and O&M costs. 

Award of a PBC is not automatic nor is the award guaranteed to incumbent contractors at the installation. Candidate bidders must have completed elements of 

their current work that impinge on the scope of the request for proposal. During 

scope development, the Army team attempts to reduce the amount of uncertainty 

present in order to ensure a sufficient pool of qualified bidders. 

Prior to entering into final negotiations with the bidders, the Army develops a negotiation strategy to identify the agreed-upon point at which the PBC will not be 

awarded should bids exceed the IGCE and negotiations fail to close the gap to the 

Army’s satisfaction. 

6.6 INTERAGENCY AGREEMENT (IAG)/FEDERAL 

FACILITY AGREEMENT (FFA) 

Upon an installation’s nomination to the NPL, the installation, the USEPA, and , 

if the State requests, appropriate state regulatory agencies enter into an IAG/FFA 
Program Procedures 

 6-13 

to complete of all necessary RAs at the installation. The Garrison Commander 

and the DASA (ESOH) will both sign the IAG/FFA for the Army. 

In order to maintain consistency throughout DoD, DoD and USEPA developed 

the 1988 EPA-DoD FFA model language, with edits for state participation dated 

17 March 1989, and the most recent revision of 10 February 1999. This model 

language forms the basis for all FFA negotiations. The FFA model language was 

not intended to cover all issues that would be included in an FFA, and installations may negotiate additional, necessary provisions on a site-by-site basis that do 

not conflict with the FFA model language. Such additional provisions do not become part of the model language, nor are they binding precedent for other FFAs 

for that or any other DoD installation. 

In addition to following the FFA Model Language, Army installations will also 

incorporate FFA terms outlined in accordance with the DASA(ESOH) memorandum, 2 March 2004, subject: Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) Record of Decision (ROD) and Post-ROD 

Policy. This would include adding a site-wide closeout document or a final RA 

completion report as a primary document. 

The ODUSD must approve deviations to the model language. The concepts of 

“flexible” schedules, funding constraints, and relative risk must be incorporated 

into IAGs/FFAs. For re-negotiated agreements, the DoD and the Army, again, 

strongly support incorporation of the concept of flexible schedules. 

To the extent that an installation negotiates provisions that deviate from the FFA 

model language in a proposed FFA, that installation will specifically identify each 

such change and its rationale when submitting the proposed FFA for ODUSD review. In addition, the installation will identify and provide rationale to reviewers 

for any other significant provision in the draft FFA that would qualify or limit any 

FFA model provision, as well as novel additions to the model language. 

The installation’s servicing legal office has the lead in IAG/FFA negotiations; 

however, the legal chain of command may designate another lead should the installation request assistance. The USAEC counsel and OTJAG will provide assistance during the negotiation process. When the IAG/FFA is sent to DASA 

(ESOH) through the command chain for signature, the ACSIM requests concurrence from the OTJAG and USAEC. The installation should provide USAEC 

with copies of the draft IAG/FFA for review and concurrence prior to sending the 

IAG/FFA to DASA (ESOH) for signature. 

See the 10 May 2000, memorandum from the DUSD(ES), subject: Federal Facility Agreement – Deadlines and Funding Model Language for the latest guidance on FFA model Language. See 6 December 2000, memorandum from the 

DUSD(ES), subject: Federal Facility Agreement Model Language-Policy on 
 

 6-14 

Deviations for the latest policy update. 

http://aec.army.mil/usaec/cleanup/popup/library/index.html.

6.7 REGULATORY PARTICIPATION 

It is the Army’s intent to work cooperatively with regulatory agencies so that 

Army’s restoration goals can be accomplished cost effectively, in accordance with 

applicable laws and regulations. To accomplish this, Army installations should 

identify points of contact in regulatory agencies, determine communication channels, and establish cooperative relationships. Installations should provide regulators with ready access to program information, including draft data and 

documents, and establish procedures for obtaining pertinent information from 

regulators on a timely basis. 

Installations should involve regulatory agencies in: 

¡ BCTs. 

¡ RRSEs and RAC scoring. 

¡ Project planning, budgeting, and implementation (including BCPs). 

¡ Work Plan development and site and project prioritization. 

¡ Development of the Conceptual Site Model and sampling and analysis 

plans and updates. 

¡ Response Complete and Site Closeout determinations. 

¡ RABs and other community involvement initiatives. 

¡ FOST, FOSL, FOSET. 

6.8 PUBLIC PARTICIPATION AND COMMUNITY 

INVOLVEMENT

Local communities are interested in the results of environmental studies conducted under the ERP because of the potential impact on their health, environment, and economic well-being. The Army fully supports public involvement 

programs that require the Army to solicit and consider the individual advice from 

the interested individuals, groups, and government bodies before selecting a remedial alternative. 

Installations should consult with stakeholders and the general community 

throughout the planning and execution process. Consultation involves providing 
Program Procedures 

 6-15 

CRP guidelines and related information are available on the Internet at 

http://www.denix.osd.mil/denix/Public/Library/Planning/html. 

For additional information on Environmental Justice see the Department of Defense Strategy on Environmental Justice, 24 Mar 95, which is also available on 

the Internet at 

http://www.denix.osd.mil/denix/Public/Library/Planning/Justice/note7.htm. 

information and seeking feedback/input before decisions are made. Although 

there is public involvement, the Army retains final decision authority at non-NPL 

installations as lead agency. Consultation should begin in the program formulation phase, and continue to site closeout. Consultation would be re-initiated 

should the remedy be significantly changed or should a ROD amendment be required. The extent of consultation may vary over the life of the program and 

should be commensurate with the level of restoration activity and stakeholder interest. The RAB, comprised of representatives of the installation, regulatory 

agencies and the local community, shall be the primary forum for consultation. 

When changes to the program become necessary, installations will consult with 

stakeholders, to include the general community, to the extent possible, before final decisions are made. This could be in the form of activities such as public 

meetings, public information sessions, newsletters, and press releases. 

6.8.1 Community Relations Plan (CRP)

A CRP is required for all Army properties funded by BRAC. The plan provides 

the guidelines for future community relations activities associate with installation 

cleanup. The installation public relations staff normally prepares the CRP with 

input from the environmental staff. 

6.8.2 Environmental Justice

Army installations will address and consider environmental justice concerns and 

issues in its restoration programs. On 11 Feb 94, the President issued EO 12898 

entitled Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations. The EO measure requires federal agencies to 

identify and address disproportionately high and adverse human health and environmental effects of federal programs, policies, and activities on minority and 

low-income populations. Environmental justice issues within a community will 

be identified as part of the process of developing the CRP. The primary mechanism for input from the environmental justice community on restoration issues 

should be from RABs. 
 

 6-16 Additional RAB guidance and information on TAPP, can be found on the 

USAEC library web site, 

http://aec.army.mil/usaec/cleanup/popup/library/index.html.

RAB policy is contained in the DA Pam 200-1 Environmental Quality, Environmental Protection and Enhancement, 17 Jan 02 at 

http://www.usapa.army.mil/gils. 

6.8.3 Technical Review Committee (TRC)

Per 10 USC §2705(c), a TRC is established to review and comment on the Army's 

actions with respect to releases or threatened releases of hazardous substances at 

installations. The TRC meetings serve as working sessions for exchanging information and organizational viewpoints. Members of a TRC include at least one 

representative from the Army; appropriate USEPA, state and local authorities; 

and representatives from surrounding communities. The Installation Commander 

is responsible for establishing and chairing or designating an installation/Army 

chairperson for the TRC. 

6.8.4 Restoration Advisory Board (RAB)

RABs are a forum between governmental decision-makers and the affected local 

community providing the opportunity for meaningful community input to the decision-making process including project prioritization. Every installation participating in the Army BRAC ERP that is on the NPL or transferring property to the 

local community must establish a RAB. RABs meet the requirement of 10 U.S.C 

§2705c requiring a TRC at NPL installations. 

The installation must keep the RAB apprised of program funding status and possible impact of any cuts prior to and during program execution. The installation 

should, at a minimum, provide the RAB with copies of the IAP and if appropriate 

have the RAB participate in the annual update of the IAP. Project work plans 

should also be provided to the RAB to ensure they are knowledgeable of the 

plans, including any changes. 

The RAB members should be involved by providing individual input on activities/projects, including scope, timing, schedule, and overall environmental restoration funding at the installation. Installations shall inform TRC/RAB members 

of the existence of fiscal controls, and identify priorities so that, should budget 

reductions or program adjustment become necessary, RAB members can provide 

informed input. 

6.8.5 Technical Assistance for Public Participation (TAPP)

Community RAB/TRC members may seek independent technical assistance to 

contribute to the public’s ability to participate in the restoration program. To obtain funding, community members of RABs/TRCs must apply for TAPP. The 

installation reviews the application for eligibility and approval before developing 

appropriate TAPP funding requirements. 
Program Procedures 

 6-17 

For detailed guidance on the DSMOA/CA Program, see the USACE handbook 

“Working Together to Achieve Cleanup: A Guide to the Cooperative Agreement 

Process”, available on the Internet at http://www.edod.net/dsmoa/. 

6.9 DEFENSE STATES MEMORANDA OF AGREEMENT 

(DSMOA)/COOPERATIVE AGREEMENT (CA)

PROGRAM

The DSMOA/CA program funds state environmental regulatory agencies for 

technical services provided in support of the ERP. The goals of the DSMOA/CA 

Program are to expedite the cleanup process, to comply with state regulations, and 

to improve coordination and cooperation between DoD and state/territorial regulatory communities. The USACE is the executive agent of the DSMOA/CA Program. The Army provides USACE funding for the states that have a signed 

DSMOA/CA. 

The DSMOA describes how a state will provide technical services and the Army 

will provide funds for those services. The CA specifies short-term services to be 

provided and the costs of those services for two years. The CA also includes a 

narrative summary plan of long-term activities with reasonable estimates of cost 

for an additional four years, as necessary. CAs will be updated to reflect MMRP 

requirements. 

6.10 MONITORED NATURAL ATTENUATION FOR 

ENVIRONMENTAL RESTORATION

While natural attenuation has no specific regulatory definition, the Army defines 

natural attenuation as the reduction of contaminant concentrations in the environment through biological processes (aerobic and anaerobic biodegradation, plant 

and animal uptake), physical phenomena (advection, dispersion, dilution, diffusion, volatilization, sorption/desorption), and chemical reactions (ion exchange, 

complexation, abiotic transformation). Terms such as intrinsic remediation or 

biotransformation are included within the more general natural attenuation definition. 

Natural attenuation is not a no-further-action alternative. Natural attenuation 

typically requires extensive monitoring to ensure that the predicted natural processes are taking place. Natural attenuation remedies might take longer than engineered remedies to correct the problem. Additionally, there should be a readily 

available contingent remedy for the site. It will take credible scientific data, site 

characterization data, and predictive modeling to prove that natural processes are 

sufficient to reduce risk in the time frame required. 
 

 6-18 

For more information on monitored natural attenuation, consult EPA Directive 

Number 9200.4-17P, Use of Monitored Natural Attenuation at Superfund, 

RCRA Corrective Action, and Underground Storage Tank Sites, Apr 21, 1999. 

Army policy directs that natural attenuation must be considered as a candidate 

remedy for contaminated sites either alone or in combination with active engineered measures. Prior to approving an engineered RA, natural attenuation must 

be proven to be an inappropriate remedial solution. 

Full protocols on the use of natural attenuation for different classes of contaminants commonly found at Army bases are presently under development at 

USAEC. Until these protocols are available, the Air Force Center for Environmental Excellence’s protocol (Technical Protocol for Implementing the Intrinsic 

Remediation (Natural Attenuation) with Long-term Monitoring Option for Dissolved-Phase-Fuel Contamination in Ground Water) for petroleum contaminants 

is recommended.

6.11 LAND USE CONTROLS (LUCS)

The LUCs are physical, legal, and other mechanisms that restrict property use. 

The LUCs are used to mitigate risks associated with exposure to potential hazards 

(e.g., environmental, explosives) during or residual to cleanup, when it is inappropriate or not feasible to eliminate those risks by removing or treating the contaminated media to unrestricted use levels. LUCs should considered a component 

of other response actions, unless leaving contaminants in place proves to be the 

most favorable risk management decision (e.g., due to technical or economic limitations, concerns regarding worker safety, or to prevent collateral ecological injuries). As with any environmental response action, complete characterization and 

cleanup of all MEC during a munitions response is not possible due to technical 

impracticability, cost, or other issues (e.g., worker safety, overall risk). Because 

residual hazards or risks will remain at an MRS after a responses complete decision had been made, LUCs will normally be required to manage those residual 

hazards or risks. The primary LUC mechanisms are defined as follows: 

¡ Physical mechanisms encompass a variety of engineered remedies that reduce or eliminate exposure to contaminated media. Such controls are intended to keep trespassers away from a site, warn people of dangers, or 

restrict or contain actual or potential contaminant migration. These 

mechanisms are also known as Physical Controls or Engineering Controls 

(ECs). 

¡ Legal mechanisms used for LUCs may be the same as those used for Institutional Controls (ICs) as discussed in the NCP. These mechanisms are 

primarily imposed to ensure that restrictions on land use, developed as part 

of a remedy decision, stay in place. Examples of legal mechanisms in-
Program Procedures 

 6-19 

clude restrictive covenants, equitable servitudes, and deed restrictions for 

transfer properties 

The objective of LUCs is to ensure that future land use remains compatible with 

the land use that was the basis for the evaluation, selection, and implementation of 

the response action. As such, LUCs are a common component of any response 

action that does not allow for unrestricted land use following the completion of 

the response action or when the response action allows for unrestricted use, but 

there is a need to protect the integrity of the remedy. Because current technologies do not allow for complete removal of all MEC, LUCs will be a component of 

all munitions responses at MRS known to contain MEC. 

There are instances where restrictions on the use of a property pre-date the conditions that gave rise to the need for environmental restoration activities. Where 

there is a pre-existing restriction, it shall be used to establish the “reasonably anticipated future land use.” However, since it is not being instituted as a part of the 

environmental restoration activities, that pre-existing restriction need not be 

evaluated as a response alternative. 

At all sites where a use restriction is part of environmental restoration activities, 

the LUC must be clearly defined, established in coordination with affected parties, and enforceable. Implementing LUCs through established real estate and 

land use management mechanisms provides a means to assure that LUCs remain 

effective. Use of a system of mutually reinforcing controls is often a necessary 

component in a LUC strategy. When considering LUCs as part of the response 

alternatives, the unrestricted use alternative must also be considered. 

6.11.1 LUCs at Transferring Property 

For property that is to be transferred with some type of LUC, the types of mechanisms that restrict land use are generally either governmental or proprietary. 

Governmental mechanisms originate from state or local police power authorities, 

including zoning, permitting, and local redevelopment ordinances. Proprietary 

controls are contractual mechanisms, usually established in a transfer deed or contract for sale in the form of covenants or easements. 

The LUCs should be managed and maintained at the local level whenever possible. In the case of a BRAC installation, to the maximum extent possible, the 

transferee or other local party should assume the bulk of LUC duties. The future 

landowner has an active role in managing the land in their possession; so on-theground LUC responsibilities should become the duty of the transferee. 

At properties transferring from federal control, Components should use state LUC 

registries where available. Components may grant a property interest to the relevant state or local agency that will allow the state or local agency to maintain and 

enforce the LUC. As most LUCs are memorialized in the deed as deed restrictions or in other publicly available legal instruments that would be discovered 
 

 6-20 

during a real estate transaction, it is essential that the Component consult state 

property law and state environmental law when drafting the restriction because 

state law may require the use of a particular type of instrument or operative language. 

6.11.2 Documenting and Implementing LUCs in RODs/DDs 

Coordinate with the installation legal office on LUC documentation and implementation to ensure consistency with any recent guidance. The most recent 

HQDA guidance is contained in DASA (ESOH) memorandum, subject: The 

CERCLA Record of Decision (ROD) and Post-ROD Policy, dated 2 March 2004 

(Appendix F). Only broad LUC objectives, not specific installation implementation actions, will be included in the CERCLA ROD/DD. This means that installations will keep the ROD lean (by stating what the LUC is and what the LUC’s 

purpose (RA objective(s)) is in the ROD). The implementation details are to be 

included in documentation for the RD Phase (this may be a RD Work Plan, RA 

Work Plan, LUC Implementation Plan, RD, etc., depending on the terminology 

used by the specific installation, state and USEPA region). Once further guidance 

on LUCs is approved, it will be provided via memorandum and on the USAEC 

web site. 

6.12 CERCLA FIVE-YEAR REVIEWS

In accordance with CERCLA and the NCP, if hazardous substances, pollutants, or 

contaminants remain at a site after a response action, at levels that do not allow 

for unlimited use and unrestricted exposure, a CERCLA five-year review is required. However, where RCRA Corrective Action has been implemented, the 

Army will not require a five-year review. However, where residual explosive 

hazards form MEC remain, the BEC will ensure that five-year reviews or, if appropriate, more frequent reviews are required to ensure that the completed response remains protective. 

The CERCLA five-year review will be conducted no less often than every five 

years after a selected RA has been initiated, or in accordance with the ROD/DD. 

The first review will be conducted no more than five years after the initiation of 

on-site construction for the first site requiring a five-year review. All sites will be 

included in the first review regardless of their phase of cleanup unless they have 

already been cleaned up for unrestricted use. Five-year reviews will continue until contaminants are below levels that allow for unrestricted use for all sites, as 

determined by the Army. 

The USAEC will distribute an annual memorandum notifying affected installations that a five-year review is due in the next FY. BRAC Division will actually 

develop the schedule for five-year reviews and BRAC installations. The BEC will 

review the RA to ensure that human health and the environment are being protected. The review process will also be used to determine whether active treatment remedies and long-term monitoring programs are operating efficiently and 
Program Procedures 

 6-21 

Final Guidance is currently being reviewed and staffed for signature. See the 5 

April 2000 memorandum from the ACSIM, subject: Interim Guidance for Conducting Five-Year Reviews for current guidance. 

continue to be cost effective. The BEC will obtain USAEC concurrence prior to 

submitting copies to regulators for review and comment. If a selected remedy is 

determined to be inoperative and/or not protective of human health and the environment, a new remedy will be selected that complies with the provisions of 

CERCLA and the NCP. 

For BRAC ERP projects, five-year reviews will be funded by BRAC. Installations will be responsible for updating the associated CTC and for programming 

for funds in AEDB-R. BRAC Work Plans will list USAEC as the executor to allowing funding transfer directly from USAEC to the executor. The USACE 

HTRW Center of Expertise will conduct all CERCLA five-year reviews at BRAC 

ERP installations. The only exception will be at those installations that have instituted a PBC that holds the contractor responsible for conducting the five-year review within the contract period of performance. 

6.13 END OF RESTORATION PROGRAM

Sites remain in the BRAC ERP until all required response actions have been 

completed. Requirements at these sites will continue to be programmed and 

budgeted in the appropriate BCA account.

6.13.1 Response Complete (RC)

Consistent with CERCLA, the DERP, and applicable Executive Orders and regulations, IRP category environmental response activities shall be considered “RC” 

when all the response objectives identified in an appropriately signed ROD/DD 

have been achieved and documented. 

If BRAC ERP activities allow for unrestricted use of the property, RC occurs 

when there is verification of the achievement of the response objectives detailed 

in the ROD/DD. 

If BRAC ERP activities do not allow for unrestricted use of the property, RC occurs when the following three conditions are met: 

¡ There is verification of the achievement of the response objectives detailed 

in the ROD/DD. 

¡ At least one subsequent five-year review has been conducted to ensure 

that the response action has remained effective and continues to be protective of public safety, human health and the environment as defined by the 

response objectives detailed in the ROD/DD. 
 

 6-22 

¡ At least five years have elapsed since the RA objectives were first 

achieved. 

6.13.2 Reopened Sites

A “reopened environmental restoration site” is any site previously determined to 

have completed all required response actions that requires additional response actions to achieve the response objectives identified in the ROD/DD. 

The second type of reopened site relates to sites where the investigation(s) have 

been completed (PA, SI, RI/FS) and subsequently, an investigative phase is reopened. These sites are also “reopened environmental restoration sites.” Additional environmental study or response action requirements at such sites shall be 

identified during AEDB-R updating. Reopening of a site or investigation requires 

justification. That justification will be included in the narrative field of the site 

general information in AEDB-R. 

6.13.3 Post-Remedial Design (RD) Procedures

The terminology for work in the final stages of remediation was developed to 

more accurately reflect the status of the site. Remedial Action-Construction 

(RA(C)) is the phase during which the final remedy is installed or constructed. 

The end date signifies that the installation or construction is complete, all testing 

is accomplished, and that the remedy will function properly. Remedial ActionOperations (RA(O)) is the phase during which the remedy is in place and operating to achieve the cleanup objective identified in the ROD/DD. Any system operation or monitoring requirements during this time should be termed RA (O). 

RC signifies that the remedy is in place and RA-O (if required) is no longer required. If there is no RA (O) phase, then the RA(C) end date will also be the RC 

date. Once a site is RC, environmental monitoring or review of site conditions 

and/or maintenance of the RA to ensure the remedy remains effective is termed 

Long-Term Management (LTM). “LTM” is reserved for monitoring once a site is 

RC, and should not be used to refer to monitoring after Remedy in Place (RIP) 

which is included in RA(O) (this includes sites for which the selected remedy is 

natural attenuation). 

Installations and ERMs should review AEDB-R data inputs to ensure that data 

reflect the terminology described herein. 

Post-remedial design phase milestones are shown in the following diagram. 
Program Procedures 

 6-23 

Remedial Action 

Construction

Remedy in Place

Remedial Action 

Operation

Response Complete*

Long-term 

Management

LTM

Requirements

Complete

Start

Milestone

Complete

*Response Complete could occur after construction if there is limited or no operation.

Milestones

6.14 NATURAL RESOURCE INJURIES (NRI)

As stated in the ODUSD (I&E) memorandum, Interim Policy on Integration of 

Natural Resource Injury Responsibilities and Environmental Restoration Activities (2 May 2000), the Secretary of Defense has delegated the authority as a 

CERCLA natural resource trustee to the head of each Component, with authority 

to re-delegate a representative as appropriate. Installation Commanders do not 

serve as natural resource trustee representatives. 

At sites where the Army is acting as CERCLA Lead Agent, installations shall 

identify potential NRI attributable to releases of hazardous substances as they perform site characterizations. This evaluation is intended to provide relevant information regarding the current condition of the natural resources. Such data are then 

used to assist the installation in the assessment of the threshold criteria of “overall 

protection of human health and the environment” that is part of the evaluation of 

response alternatives. As part of the evaluation of response alternatives, installations shall assess: 

¡ How each response alternative considered addresses the potential natural 

resource injuries caused by Army activities. 

¡ Whether implementation of that particular response alternative will itself 

cause additional potential natural resource injury.

The installation shall notify all appropriate Trustees, which may include federal 

agencies, states, and Native American tribes, of potential injury to natural resources and shall coordinate documents and proposed environmental restoration 

activities with these Trustees. This coordination does not, however, grant the 

other Trustees a role in selection of a response. The installation shall also coordinate with Army-wide natural resource professionals to obtain relevant ecosystem 

information. Installations are encouraged, when feasible and cost-effective, to 

select a response that will result in the least amount of potential natural resource 

injury. 
 

 6-24 

6.15 BRAC PROPERTY TRANSFER REQUIREMENTS 

Policies and guidance for accomplishing BRAC property transfers are documented in AR 200-1 and DA Pam 200-1. The ACSIM BRAC Division and its FO 

accomplish those activities described in the DA Pam as responsibilities of the 

Army MACOMs. 

Under FTC, the following BRAC property transfer requirements are to be accomplished within the BRAC ERP. 

¡ Identify uncontaminated property that can be made available for transfer 

or reuse within 18 months after Congressional action on a BRAC list, as 

required under CERFA, and obtain regulatory concurrence on those properties. The BCT may readdress this issue later than 18 months after Congressional action on a BRAC list if the Army deems it necessary and it 

will facilitate the expeditious transfer of property. Identification of 

CERFA uncontaminated property is performed during the EBS. 

¡ Conduct EBS, prepare FOSL and FOST, and demonstrate compliance 

with the notification, covenant, and regulatory and public involvement requirements of the process. 

¡ Conduct all environmental analyses required under NEPA, to the extent 

practicable, within 12 months of receiving a LRA final reuse plan. In the 

event that the LRA does not submit a reuse plan by the time, the Army 

needs to initiate the NEPA analysis necessary to support a disposition decision. The Army will begin preparation of its NEPA analysis using reasonable assumptions as to the likely reuse scenario and its alternatives. 

¡ Develop future land use assumptions based on the LRA reuse plan and in 

close coordination with the local community. 

¡ Consider reuse and the RRSE framework in sequencing restoration activities at BRAC installations. In instances where reuse plans are being implemented, or are likely to be implemented, reuse should be the primary 

consideration for sequencing activities.

6.15.1 Determination of Operating Properly 

and Successfully

CERCLA §120(h) placed certain requirements on the deed transfer of U.S. Government owned property to other parties. The primary purpose of §120 (h) is to 

ensure that property contaminated by the federal government is environmentally 

restored before being conveyed outside the federal government. CERCLA 

§120(h)(3) requires that deeds transferring property where hazardous substances 

have been stored, released, or disposed of have a covenant warranting that “all 
Program Procedures 

 6-25 

Additional guidance on the determination of operating properly and successfully 

can be found in the EPA guidance “Guidance for Evaluation of Federal Agency 

Demonstrations that Remedial Actions are Operating Properly and Successfully 

Under CERCLA Section 120(h)(3), August 1996. Available on the internet at 

http://www.epa.gov/swerffrr/doc/896mm.htm. 

remedial action necessary to protect human health and the environment with respect to any hazardous substance remaining on the property has been taken before 

the date of such transfer.” CERCLA §120 (h)(3) states that that all necessary actions at a site allow for property transfer “if the construction and installation of an 

approved remedial design has been completed and the remedy has been demonstrated to the EPA Administrator to be operating properly and successfully.” 

A remedial action is operating “properly” and “successfully” if it is operating as 

designed, the remedy is protective of human health and the environment and the 

system will achieve the cleanup levels or performance goals delineated in the decision document. . The success of a particular remedial action is to be evaluated 

based on whether it successfully addresses the particular contaminant(s) it was 

designed to remediate. Where more than one remedial action is required for a 

parcel, all such actions must operate properly and successfully, and the Army 

must demonstrate to the EPA that all the actions are operating properly and successfully prior to making the determination that the property is suitable for transfer.

6.15.2 Authority to Transfer Property before Completing 

Environmental Restoration Actions 

The Early Transfer Authority (ETA) provided by CERCLA §120(h)(3)c allows 

federal property to be transferred to a non-federal entity before completion of all 

necessary RA. It is DoD policy that the ETA be pursued whenever doing so is 

beneficial both to DoD and the transferee. It is also DoD policy to encourage the 

transferee to undertake any required response actions. The ETA is not a conveyance authority, nor is it necessary for transfer of property to other federal agencies. The required suitability determination is documented in a Finding of 

Suitability for Early Transfer (FOSET). The following approvals are required for 

ETAs: 

¡ For non-NPL property, the Governor of the state where the property is located must approve the request for an early transfer. 

¡ For NPL property, the USEPA Regional Administrator, with the concurrence of the Governor of the state, must approve the early transfer. 
 

 6-26 

More specific explosive safety requirements are identified in The US Army 

Corps of Engineers Pamphlet Explosives Safety Submission (EP 385-1-95b) and 

the Army Explosives Safety Program (AR 385-64 and PAM 385-64).

More specific explosive safety requirements are identified in The US Army 

Corps of Engineers Pamphlet Explosives Safety Submission (EP 385-1-95b) and 

the Army Explosives Safety Program (AR 385-64 and PAM 385-64).

Upon transfer of any property using ETA, the Army must submit a written notice 

to ODUSD (I&E) that: 

¡ Lists the date the property was transferred. 

¡ Describes the property was transferred using ETA, including a statement 

of the size of the transferred parcel in acres. 

¡ Lists all environmental restoration sites on the transferred parcel. 

¡ States that the installation has requested adequate funding and provided 

the required response action assurances. 

DoD 6055.9 STD, Chapter 12, requires that an appropriate munitions response be 

completed before transfer or lease of property known or suspected to contain 

MECHowever, DoDD 6055.9-STD allows the lease or transfer of such property 

provided the appropriate Deputy Assistant Secretary of the Army approves the 

transfer or lease; the explosives safety or chemical agent (CA) safety aspects of 

any provisions for a transfer or lease have been submitted, through USATCES, 

for DDESB review and approval; and the receiver is advised of any known or 

suspected explosive or CA hazards present 

6.15.3 Deed Covenants

CERCLA §120(h) has specific requirements for covenants that must be given 

when transferring property by deed outside the federal government. The Installation Legal Office must be consulted to determine when the covenants are required. 

When conveying by deed to a nonfederal entity, a property where a CERCLA 

hazardous substance was stored for one year or more, or known to have been released, or known to have been disposed on the property, CERCLA §120(h)(3) requires two covenants in the deed (unless the property recipient is a PRP under 

CERCLA): 

(unless the property recipient is a PRP for contamination on the property): 

The first covenant, under CERCLA §120(h)(3)(i), states that all necessary RA 

with respect to any hazardous substance remaining on the property has been taken 

before the date of transfer. In the case of early transfer, this covenant will be 

withheld upon conveyance, and issued instead upon completion of cleanup. 
Program Procedures 

 6-27 

Additional guidance on early transfer authority can be found in the ODUSD(ES) 

memorandum “Environmental Review Process to Obtain the Finds of Suitability 

Required for Use of Early Transfer Authority for Property Not on the National 

Priorities List”, 24 Apr 1998. 

¡ The second covenant, under CERCLA §120(h)(3)(ii), warrants that any 

additional RA found to be necessary after the date of the transfer would be 

conducted by the United States.

In addition, the deed must contain a clause granting to the United States access 

rights to enter the property to conduct any future remedial activities. Further, the 

deed will specify that, in the event a transferee discovers hazardous substances 

that were remaining on the Property at the time of the conveyance, the transferee 

will immediately secure the site and notify the Army of the existence of the hazardous substances, and the transferee will not further disturb such hazardous substances without the written permission of the Army. 

When conveying by deed to a non-federal entity, property that has been identified 

as “uncontaminated” (i.e., where no CERCLA hazardous substance, petroleum 

product, or petroleum product derivative was released or disposed) and the appropriate environmental regulator has concurred that the property is uncontaminated, 

where no RA has been necessary, the deed shall contain a covenant required by 

CERCLA §120(h)(4)(D)(i) warranting that any RA found to be necessary after 

the date of the transfer will be conducted by the United States. In addition, the 

deed must contain a clause granting to the United States access rights to enter the 

property to conduct any future remedial activities. 

For property known or suspected to contain MEC, to include property on which 

there is a potential for residual explosive hazards to remain, a covenant or notice 

is required. At a minimum, the notice should advise of the former use of property 

as a military installation, that there is a possibility that MEC may exist on the 

property, that should MEC be found on the property it should not be moved, disturbed or destroyed, but shall immediately reported to the local police who will 

request DoD support of an explosives or munitions emergency. 

. 

6.16 CLEANUP RESPONSIBILITIES AFTER PROPERTY 

TRANSFER 

DoD policy outlines the circumstances under which the Army would perform additional cleanup of Army property that was transferred by deed to any entity outside of the DoD. DoD policy requirescoordination with the local community and 
 

 6-28 

the integration of the land use planning and environmental restoration process to 

the maximum extent practicable.. 

If a remedy put in place prior to property transfer is no longer protective of human 

health and the environment, the Army is responsible for additional environmental 

restoration if the land use has not changed. If additional contamination attributable to Army activities is discovered after transfer, the Army is also responsible 

for response actions. The Army retains responsibility for contaminated property 

subject to the covenant requirements of CERCLA 120(h).Additional restoration 

necessary to address contamination attributable to Army activities and consistent 

with the land use assumptions used to determine the original remedy will be performed consistent with CERCLA §120(hThe Army will not conduct additional 

response actions to accommodate changes in land use after transfer. 

The Army will make full disclosure to communities and the transferee regarding 

property being transferred. This shall include the basis for the Army’s decision to 

consider a particular land use in formulating remedial alternatives, any LUCs relied upon to support the selected remedy, and the finality of the remedy selection 

decision. The Army will also include DoD’s policy on additional restoration after 

transfer contained in the 25 Jul 1997, USD (A&T) Memorandum, Responsibility 

for Additional Environmental Cleanup after Transfer of Real Property. 

The USACE Real Estate Directorate is the Army property disposal agent for 

BRAC. The Army property disposal agent ensures that the property transfer 

documents reflect use restrictions and enforcement mechanisms specified in the 

remedy DD. The Army reserves the right to take appropriate cleanup actions to 

protect human health and the environment due to action or inaction from the entity responsible for releasing contamination onto the property. 

After the property transfer, the Army will conduct additional cleanup under the 

following conditions: 

¡ The selected remedy fails and is no longer protective of human health and 

the environment. 

¡ Additional contamination is found that is attributable to Army activities. 

¡ Munition and explosives of concern are discovered. Under normal conditions, the initial response will be by Explosives Ordnance Disposal personnel who will respond to local law enforcement requests for support as 

an explosives or munitions emergency response under the Environmental 

Protections Agency’s Military Munitions Rule. If an assessment of the 

discovery indicates that a follow-on response is required, the Army will 

work with the regulatory community to determine the appropriate response to address the discovery. 

¡ Regulatory requirements are revised to reflect new scientific/health data 

establishing the remedy in effect to be ineffective.
Program Procedures 

 6-29 

After the property transfer, the Army will not conduct nor pay for additional 

cleanup when the additional cleanup facilitates a land use prohibited by deed restrictions or other appropriate LUCs or there is a release onto the property resulting from a violation of a deed restriction or other restrictive covenant. 

The Army will initiate actions to revise deed restrictions or other LUCs as appropriate when the remedy has achieved cleanup level and restrictions are no longer 

required. The Army will cooperate with the transferee to revise and remove restrictions to facilitate a broader range of land uses when the transferee undertakes 

and pays for efforts required which fully demonstrate the continuance of protection of human health and the environment. The transferee must apply to the 

Army disposal agent for revision or removal of deed restrictions. 

The Army will disclose to the community or LRA the Army’s intent to consider 

land use expectations in the remedy selection process. Public notifications ordinarily made throughout the restoration process will also include full disclosure of 

the assumed land use used in the remedy selection process. 

6.17 CLOSE OUT

Installations should plan and complete all environmental restoration activities in 

accordance with DPG goals. BCTs will be closed out when the following requirements and activities have been accomplished: 

¡ The final RA for the installation is in place (construction and installation 

of an approved RD) and the remedy has been demonstrated to be operating 

properly and successfully. 

¡ Reuse has been approved for all properties identified for transfer. 

¡ All environmental analyses required by NEPA have been completed and 

no further restoration is required. 

¡ All FOSTs have been completed. 

Site closure under BRAC reflects the requirements associated with real property 

transfer. In order to facilitate reuse-planning efforts, "uncontaminated" installation 

property must be identified as defined by the CERFA. No property can be conveyed by deed or can be leased until a FOST, FOSET or a FOSL has been 

signed. 

The BCT will take the following actions before it is adjourned: 

¡ To preserve institutional knowledge and to provide an accurate historical 

perspective for future reference the BCT shall prepare and submit to the 

BRAC Division a final “Closeout BCP” that: 
 

 6-30 

h Summarizes the environmental restoration activities that have occurred, including summaries of individual site histories describing the 

type and concentration of the contamination or MEC that was present 

(and if appropriate, that remains) at the site, the remedy used, and any 

required future management activities. 

h Identifies responsibilities for environmental restoration conditions and 

activities continuing after property transfer. 

¡ Formally notify the RAB and LRA of the BCT adjournment. This notification shall include a complete list of points of contact for environmental 

restoration and support of reuse responsibilities with DoD and other federal, state or tribal, or local agencies. 

¡ Submit a final BCP abstract to the Deputy Assistant Secretary of the Army 

for Installation and Housing (SAILE (I&H)) and ODUSD (I&E) that includes a statement that this is the final BCP Abstract submission, the date 

of the BCT adjournment, and the notification provided to the RAB and 

LRA (with the accompanying point of contact documentation). 
 7-1 

Chapter 7 

Available BRAC Environmental Guidance 

For a list of available BRAC Environmental guidance used in the preparation of 

this document, see Appendix J. 

All major DOD environmental regulations, policies and guidance are available on the Internet at http://www.denix.osd.mil. For Army publications visit 

http://www.usapa.army.mil/gils/.

 A-1 

Appendix A

Army BRAC Installations 

BRAC 1 

Alabama AAP, AL 

ARL-Watertown, MA 

Bennett ARNG Training Site, CO 

Cameron Station, VA (BCT Adjourned) 

Camp Navajo, AZ 

Cape St. George, FL 

Coosa River Storage Annex, AL 

Defense Mapping Agency-Herndon, VA 

Fort Des Moines, IA 

Fort Douglas, UT 

Fort George G. Meade, MD 

Fort Holabird, MD 

Fort Sheridan, IL 

Fort Wingate, NM 

Gaithersburg Research Facility, MD 

Hamilton Army Air Field, CA 

Indiana AAP, IN 

Jefferson Proving Ground, IN 

Kapalama Military Reservation, HI 

Lexington Facility-LBAD, KY 
 A-2 

Military Ocean Terminal, New Orleans, LA 

Nike Aberdeen, MD 

Nike Kansas City 30, MO 

Pontiac Storage Activity, MI 

Presidio of San Francisco, CA (BCT Adjourned) 

Pueblo Chemical Depot, CO 

Tacony Warehouse, PA 

Umatilla Chemical Depot, OR 

53 Family Housing Sites 

BRAC 91 

ARL-Woodbridge, VA (BCT Adjourned) 

Fort Benjamin Harrison, IN (BCT Adjourned) 

Fort Devens, MA 

Presidio of Monterey, CA 

Sacramento Army Depot, CA 

BRAC 93 

Fort Monmouth, NJ 

Tooele Army Depot, UT 

Vint Hill Farms Station, VA 

BRAC 95 

Big Coppitt Key, FL 

C.E. Kelly Support Facility BRAC, PA 

Camp Bonneville, WA 

Camp Kilmer, NJ 
Army BRAC Installations 

 A-3 

Camp Pedricktown, NJ 

Defense Distribution Depot, Ogden, UT 

Detroit Arsenal Tank Plant, MI 

East Fort Baker, CA 

Fitzsimmons Army Medical Center, CO 

Fort Bragg Recreation Center #2, NC 

Fort Chaffee, AR 

Fort Dix, NJ 

Fort Holabird, MD 

Fort Hunter Liggett, CA 

Fort Indiantown Gap, PA 

Fort McClellan, AL 

Fort Missoula, MT 

Fort Pickett, VA 

Fort Ritchie, MD 

Fort Totten, NY 

Hingham Annex, MA 

Letterkenny Army Depot, PA 

Lompoc Disciplinary Barracks, CA 

Military Ocean Terminal, Bayonne, NJ 

Oakland Army Base, CA 

Red River Army Depot, TX 

Rio Vista Reserve Training Area, CA 

Savanna Depot Activity, IL 

Seneca Army Depot, NY 
 A-4 

Sierra Army Depot, CA 

Stratford Army Engine Plant, CT 

Sudbury Training Annex, MA 

USA Bellmore Maintenance Facility, NY 
 B-1 

Appendix B 

Department of the Army Command Structure 

IMA Regions 

Assistant Secretary of the Army 

(Installations and Environment) 

Deputy Assistant Secretary 

of the Army 

(Environment, Safety & Occupational Health)

Assistant Chief of Staff 

for Installation Management

Director, 

Environmental 

Programs

US Army Center 

for Health Promotion 

and Preventive Medicine 

US Army 

Corps of Engineers 

Chief, 

BRAC 

Division

BRAC Installations 

Command 

Program Management 

Support 

Active Installations 

US Army 

Environmental Center 

Installation Management Agency 

BRAC Field Office 

 C-1 

Appendix C

Restoration Concept 

 USAEC 

BRAC Support 

Restoration Functional Manager 

Reporting 

Absorb former MACOM 

 oversight role 

Funding Recommendations 

Coordinate Restoration 

Priorities 

Active Army DERP

BRAC 

 Installations 

Support to BRACD 

Requirements 

Flow 

Coordination 

Funds Flow 

Installation Support

BRAC Restoration

Installation 

Mgt Agency 

IMA 

Regions 

Active 

Installations 

 BRAC 

DIVISION 

BRAC MDEP Manager 

Funds Approval 

Compliance/Conservation 

Excess Property Disposal 

BRAC FIELD 

OFFICES 

Coordinate disposal and 

Environmental efforts 

ODEP 

 D-1 

Appendix D

Examples of Restoration Activities Eligible and 

Ineligible for BRAC Funding 

ELIGIBLE “CLEANUP” PROJECTS

 Investigations to identify, confirm, and determine the risk to human health and the 

environment resulting from past DoD contamination. This also includes feasibility 

studies or engineering evaluation and cost analysis (EE/CA); RA plans and designs; 

and removal or RAs. 

 Expenses associated with cooperative multi-party cleanup plans and activities 

litigation expenses. 

 The RAs to protect or restore (not enhance) natural resources injured by contamination from past hazardous waste disposal activities. 

 Cleanup of low-level radioactive waste sites which have been identified as 

restoration sites. 

 Management expenses associated with the BRAC ERP. Management expenses are 

those overhead costs required for adequate program oversight and management. 

 Operation and maintenance costs for remedial and monitoring systems. 

 Immediate actions necessary to address health and safety concerns resulting from 

past Army contamination such as providing alternate water supplies or treatment of 

contamination drinking water. 

 Studies to locate abandoned underground tanks, activities to determine whether a 

release has occurred, and clean up of contamination. 

 Response to releases from in service tanks discovered during initial integrity testing 

(leak detection monitoring) per 40 CFR 280 where testing was conducted prior to 

the regulatory date of December 22, 1993. 

 The CERCLA response actions and eligible RCRA corrective actions identified in 

FFA/IAGs. 

 Corrective actions at SWMUs needed because of past Army activities unless the 

SWMU is subject to RCRA closure requirements. 
 

 D-2 

 Support services provided by another agency in accordance with 10 USC 2701(d). 

 Fines and penalties imposed by regulatory agencies assessed under the authority of 

the Federal Facilities Compliance Act associated with restoration activities. (Note: 

These fines must be identified in the BES for the budget year.) 

 Munitions responses to UXO, DMM or MC where the release occurred prior to 30 

September 2000 and the site was identified and included in DSERTS (now AEDBR) prior to 30 September 2002 and was not classified as RC. 

ELIGIBLE “CLOSURE-RELATED COMPLIANCE”

PROJECTS

 Remediation and closure of active underground tanks in support of property 

transfer. 

 Costs of testing and disposing of PCB transformers in support of property transfer. 

 Costs of surveys, containment, removal or disposal of asbestos and lead based paint. 

ELIGIBLE MMRP PROJECTS

 Munitions responses to UXO, DMM or MCwhere the release occurred prior to 30 

Sep 02 and the site’s CTC estimate is more than 50 per cent attributed to UXO, 

DMM or MC. 

 Archive Search Reports, investigations and responses at non-operational ranges and 

sites deemed eligible for the MMRP during the Army's Phase 3 Range Inventory 

Program 

 Reasonable costs for munitions response in support of reuse or property transfer. 

The Army will work with property recipients to design a response that will allow 

the land’s use in the agreed uponmanner and athat re technically feasible and affordable. 

INELIGIBLE CLEANUP OR CLOSURE-RELATED 

RESTORATION ACTIVITIES

 Closing or capping sanitary landfills. 

 Construction of hazardous waste storage, transfer, treatment or disposal facilities, 

except when part of a restoration RA. 

 Testing or repair of active underground tanks and costs of replacing leaking 

underground tanks. 
Examples of Restoration Activities Eligible and Ineligible for BRAC funding 

 D-3 

 Costs of storing or replacing PCB transformers and testing of PCB transformers not 

to be removed under BRAC for property reuse. 

 Costs of spill prevention and containment measures for operating equipment and 

facilities. 

 Costs of operation, maintenance or repair to hazardous waste treatment, storage or 

disposal facilities which are in use (i.e. regulated or permitted), except when part of 

a RA or for closure. 

 Activities responding to UXO, DMM or MC where the release occurred on or after 

1 Oct 00. 

 Activities responding to UXO, DMM or MC where the site was listed in DSERTS 

prior to 30 Sep 00 and it was classified as response complete. 

 Archive Search Reports, investigations and responses at non-operational ranges and 

sites deemed eligible for the MMRP during the Army's Range Inventory Program. 

INELIGIBLE MMRP PROJECTS

 Activities responding to MEC or MC where the release occurred on or after 1 

Ocober 2002. 

 Activities responding to MEC or MC at locations outside the United States. 

 Investigations and responses to munitions constituents (explosives) released to the 

soil, surface water, sediments or groundwater as a result of ammunition or explosives production or manufacturing. 

 Response activities for MEC or MC resulting from combat operations. 

 Response activities for MEC or MC at operational ranges. 

 Response activities for MEC or MC at facilities that are used for or were permitted 

for the treatment or disposal of military munitions. 

 E-1 

Appendix E

Table of Eligibility 

CLEANUP ACTIVITIES ELIGIBLE UNDER THE UNDER THE BRAC PROGRAM 

Component BRAC ER Funds 

Activity 

Installation 

Restoration 

Munitions 

Response BD/DR 

Installation Restoration program category activities at sites where the 

release occurred prior to October 17, 1986. E NE NE 

Installation Restoration program category activities at sites where the 

release occurred between October 17, 1986, and September 30, 2000, 

and where the site was identified and included in the DSERTS prior to 

September 30, 2000. 

E 

NE NE 

Installation Restoration program category activities where the release 

occurred after October 17, 1986, and where the site was not identified 

and include in the DSERTS prior to September 30, 2000. 

NE NE NE 

Installation Restoration program category activities involving military 

munitions (i.e., UXO or WMM) or the chemical residues of munitions 

activities where: 

• The release occurred prior to September 30, 2000; and 

• The site release is not at a FUDS, operational range, active 

 munitions demilitarization facility, or active WMM treatment or 

disposal unit; and 

• The site was identified and included in the RMIS prior to September 30, 2000, and was not classified as “response complete.” 

E NE NE 

Military Munitions Response program category activities where: the 

release occurred prior to September 30, 2002; the release is not at a 

FUDS, operational range, active munitions demilitarization facility, or 

active WMM treatment or disposal unit that operated after September 

30, 2002, and the site was not identified or included in the DSERTS 

prior to September 30, 2000. 

NE E NE 

Military Munitions Response program category activities at operational ranges, active munitions demilitarization facilities, or active 

WMM treatment or disposal units, or at non-range locations where the 

release occurs after September 30, 2002. 

NE NE NE 

Building Demolition/Debris Removal program category activities to 

address unsafe buildings or structures unused since October 17, 1986, 

where the activities are an integral part of actions under the Installation Restoration or Military Munitions Response program categories 

NE NE E 

Building Demolition/Debris Removal program category activities to 

address unsafe buildings or structures unused since October 17, 1986, 

where the activities are not an integral part of actions under the Installation Restoration or Military Munitions Response program categories. Components must be granted approval by ODUSD (I&E) 

before funds may be programmed. 

NE NE E 

Building Demolition/Debris Removal program category activities to 

address unsafe buildings or structures used since October 17, 1986. NE NE NE 

KEY: E= Eligible NE= Ineligible 

F-1 

Appendix F

Definitions for the Military Munitions 

Response Program 

Anomaly Avoidance. Techniques employed on property known or suspected to contain MEC, or CWM in OTM 

configurations to avoid contact with potential surface or subsurface explosive or CA hazards, to allow entry to the area 

for the performance of required operations. 

Chain of Custody. The activities and procedures taken throughout the inspection, re-inspection and documentation 

process to maintain positive control of Material Potentially Presenting an Explosive Hazard (MPPEH) to ensure the 

veracity of the process used to determine the status of material as to its explosive hazard. This includes all such activities from the time of collection through final disposition. 

Chemical Agent (CA). CA means an agent that, through its chemical properties, produces lethal or other damaging 

effects on human beings, except that such term does not include riot control agents, chemical herbicides, smoke and 

other obscuration materials. 

Chemical Agent (CA) Hazard. A condition where danger exists because CA is present in a concentration high 

enough to present potential unacceptable effects (e.g., death, injury, damage) to people, operational capability, or the 

environment.

Chemical Warfare Material (CWM). Items generally configured as a munition containing a chemical substance 

that is intended to kill, seriously injure, or incapacitate a person through its physiological effects. CWM includes 

V- and G-series nerve agents or H-series (mustard) and L-series (lewisite) blister agents in other-than-munition configurations; and certain industrial chemicals (e.g., hydrogen cyanide (AC), cyanogen chloride (CK), or carbonyl dichloride (called phosgene or CG)) configured as a military munition. Due to their hazards, prevalence, and militaryunique application, chemical agent identification sets (CAIS) are also considered CWM. CWM does not include: riot 

control devices; chemical herbicides; industrial chemicals (e.g., AC, CK, or CG) not configured as a munition; smoke 

and flame producing items; or soil, water, debris or other media contaminated with low concentrations of chemical 

warfare agents where no CA hazards exist. 

Chemical Warfare Material (CWM) Response. Munitions responses and other responses to address the chemical 

safety; explosives safety, when applicable; human health; or environmental risks presented by CWM regardless of 

configuration. (See munitions response.)

Construction Support. Assistance provided by DoD EOD or UXO-qualified personnel and/or by personnel trained 

and qualified for operations involving CWM during intrusive construction activities on property known or suspected 

to contain MEC, or CWM in OTM configurations to ensure the safety of personnel or resources from any potential 

explosive or CA hazards. 

Chemical Agent (CA) Safety. A condition where operational capability and readiness, people, property, and the environment are protected from the unacceptable effects or risks of a mishap involving chemical warfare material 

(CWM).
 

F-2 

Defense Sites. Locations that are or were owned by, leased to, or otherwise possessed or used by the Department of 

Defense. The term does not include any operational range, operating storage or manufacturing facility, or facility that is 

used for or was permitted for the treatment or disposal of military munitions. (10 U.S.C. 2710(e)(1))

Discarded Military Munitions (DMM). Military munitions that have been abandoned without proper disposal or removed from storage in a military magazine or other storage area for the purpose of disposal. The term does not include 

unexploded ordnance, military munitions that are being held for future use or planned disposal, or military munitions 

that have been properly disposed of consistent with applicable environmental laws and regulations. 

(10 U.S.C. 2710(e)(2)) 

Disposal. End of life tasks or actions for residual materials resulting from demilitarization or disposition operations. 

Disposition. The process of reusing, recycling, converting, redistributing, transferring, donating, selling, demilitarizing, treating, destroying, or fulfilling other life-cycle guidance, for DoD property. 

Documentation of the Explosives Safety Status of Material. Documentation recording that material: (1) does not 

present an explosive hazard and is consequently safe for unrestricted transfer within or release from DoD control or (2) 

is MPPEH, with the stated known or suspected explosive hazards, and is consequently is only transferable or releasable 

to a qualified receiver. This documentation must be signed by a technically qualified individual with direct knowledge 

of: (1) the results of both the 100 percent inspection and 100 percent re-inspection, and (2) the chain-of-custody of the 

material originally classified as MPPEH. This certification is followed by a verification signed by a technically qualified individual who inspects the material on a sampling basis (sampling procedures are determined by DoD entity that 

is generating the MPPEH).

Environmental Regulators and Safety Officials. Include, but may not be limited to environmental regulators, environmental coordinators or hazardous material coordinators, law enforcement officers, and safety personnel of the US 

Environmental Protection Agency (USEPA), American Indians and Alaska Natives, other Federal Land Managers, 

and/or the States. When appropriate, public health officials of various agencies may also be involved. 

Explosive Hazard. A condition where danger exists because explosives are present that may react (e.g., detonate, deflagrate) in a mishap with potential unacceptable effects (e.g., death, injury, damage) to people, property, operational 

capability, or the environment.

Explosive Ordnance Disposal (EOD). The detection, identification, on-site evaluation, rendering safe, recovery, and 

final disposal of unexploded ordnance and of other munitions that have become hazardous by damage or deterioration.

Explosive Ordnance Disposal (EOD) Personnel. Military personnel who have graduated from the Naval School, 

Explosive Ordnance Disposal; are assigned to a military unit with a Service-defined EOD mission; and meet Service 

and assigned unit requirements to perform EOD duties. EOD personnel have received specialized training to address 

explosive and certain CA hazards during both peacetime and wartime. EOD personnel are trained and equipped to perform Render Safe Procedures (RSP) on nuclear, biological, chemical, and conventional munitions, and on improvised 

explosive devices.

Explosive Ordnance Disposal (EOD) Unit. A military organization constituted by proper authority; manned with 

EOD personnel; outfitted with equipment required to perform EOD functions; and assigned an EOD mission.

Explosives or Munitions Emergency Response. All immediate response activities by an explosives and munitions 

emergency response specialist to control, mitigate, or eliminate the actual or potential threat encountered during an explosives or munitions emergency. An explosives or munitions emergency response may include in-place render-safe 

procedures, treatment or destruction of the explosives or munitions, and/or transporting those items to another location 

to be rendered safe, treated, or destroyed. Any reasonable delay in the completion of an explosives or munitions emergency response caused by a necessary, unforeseen, or uncontrollable circumstance will not terminate the explosives or 

munitions emergency. Explosives and munitions emergency responses can occur on either public or private lands and 

are not limited to responses at RCRA facilities. (Military Munitions Rule, 40 CFR 260.10) 

Explosives Safety. A condition where operational capability and readiness, people, property, and the environment are 
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F-3 

protected from the unacceptable effects or risks of potential mishaps involving military munitions.

Interim Holding Facility (IHF). A temporary storage facility designed to hold recovered chemical warfare material 

(RCWM) pending transportation for off-site treatment or storage, or on-site treatment. 

Land Use Controls (LUC). LUC are physical, legal, or administrative mechanisms that restrict the use of, or limit 

access to, real property to manage risks to human health and the environment. Physical mechanisms encompass a variety of engineered remedies to contain or reduce contamination and/or physical barriers to limit access to real property, 

such as fences or signs. 

Long-term Management (LTMgt). The period of site management (including maintenance, monitoring, record keeping, 5-year reviews, etc.) initiated after response (removal or remedial) objectives have been met (i.e., after Response 

Complete). 

Material Potentially Presenting an Explosive Hazard (MPPEH). Material potentially containing explosives or munitions (e.g., munitions containers and packaging material; munitions debris remaining after munitions use, demilitarization, or disposal; and range-related debris); or material potentially containing a high enough concentration of 

explosives such that the material presents an explosive hazard (e.g., equipment, drainage systems, holding tanks, piping, 

or ventilation ducts that were associated with munitions production, demilitarization or disposal operations). Excluded 

from MPPEH are munitions within DoD's established munitions management system and other hazardous items that 

may present explosion hazards (e.g., gasoline cans, compressed gas cylinders) that are not munitions and are not intended for use as munitions. 

Military Munitions. Military munitions means all ammunition products and components produced for or used by the 

armed forces for national defense and security, including ammunition products or components under the control of the 

Department of Defense, the US Coast Guard, the US Department of Energy, and the National Guard. The term includes 

confined gaseous, liquid, and solid propellants, explosives, pyrotechnics, chemical and riot control agents, smokes, and 

incendiaries, including bulk explosives, and chemical warfare agents, chemical munitions, rockets, guided and ballistic 

missiles, bombs, warheads, mortar rounds, artillery ammunition, small arms ammunition, grenades, mines, torpedoes, 

depth charges, cluster munitions and dispensers, demolition charges, and devices and components of the above. 

 The term does not include wholly inert items, improvised explosive devices, and nuclear weapons, nuclear devices, 

and nuclear components, other than non-nuclear components of nuclear devices that are managed under the nuclear 

weapons program of the Department of Energy after all required sanitization operations under the Atomic Energy Act 

of 1954 (42 U.S.C. 2011 et seq.) have been completed. (10 U.S.C. 101(e)(4)(A) through (C))

Minimum Separation Distance (MSD). MSD is the distance at which personnel in the open must be from an intentional or unintentional detonation.

Mutual Agreement. A meeting of the minds on a specific subject, and a manifestation of intent of the parties to do or 

refrain from doing some specific act or acts. Inherent in any mutual agreement or collaborative process are the acknowledgement of each member’s role in the process and their differing views of their authorities. The mutual agreement process will provide a means of resolving differences without denying the parties an opportunity to exercise their 

respective authorities should mutual agreement fail to be achieved. 

Munitions and Explosives of Concern (MEC). This term, which distinguishes specific categories of military munitions that may pose unique explosives safety risks means: (A) Unexploded ordnance (UXO), as defined in 10 U.S.C. 

101(e)(5)(A) through (C); (B) Discarded military munitions (DMM), as defined in 10 U.S.C. 2710(e)(2); or (C) Munitions constituents (e.g., TNT, RDX), as defined in 10 U.S.C. 2710(e)(3), present in high enough concentrations to pose 

an explosive hazard.

Munitions Constituents (MC). Any materials originating from unexploded ordnance, discarded military munitions, or 

other military munitions, including explosive and non-explosive materials, and emission, degradation, or breakdown 

elements of such ordnance or munitions. (10 U.S.C. 2710). 
 

F-4 

Munitions Debris. Remnants of munitions (e.g., fragments, penetrators, projectiles, shell casings, links, fins) remaining 

after munitions use, demilitarization, or disposal.

Munition with the Greatest Fragmentation Distance (MGFD). The munition with the greatest fragment distance that 

is reasonably expected (based on research or characterization) to be encountered in any particular area. 

Munitions Response. Response actions, including investigation, removal actions and remedial actions to address the 

explosives safety, human health, or environmental risks presented by unexploded ordnance (UXO), discarded military 

munitions (DMM), or munitions constituents (MC). 

Munitions Response Area (MRA). Any area on a defense site that is known or suspected to contain UXO, DMM, or 

MC. Examples include former ranges and munitions burial areas. A munitions response area is comprised of one or 

more munitions response sites. 

Munitions Response Site (MRS). A discrete location within an MRA that is known to require a munitions response. 

One Percent Lethality Distance. A distance calculated from a given CA MCE and meteorological conditions (temperature, wind speed, Pasquill stability factor) and established as the distance at which dosage from that MCE agent release would be 150 mg-min/m 3 for H and HD agents, 75 mg-min/m3 for HT agent, 150 mg-min/m3 for Lewisite, 10 mgmin/m3 for GB agent, 4.3 mg-min/m3 for VX vapor, and 0.1 mg-min/m3 for inhalation and deposition of liquid VX. 

On-call Construction Support. Support provided, on an as needed basis, by DoD EOD or UXO-qualified personnel 

and/or by personnel trained and qualified for operations involving CWM during intrusive construction activities on 

property known or suspected to contain MEC or CWM in OTM configurations, where the probability of encountering 

such has been determined to be low. This support can respond from off-site when called, or be on-site and available to 

provide required construction support. 

On-site Construction Support. Dedicated support provided by DoD EOD or UXO-qualified personnel and/or by personnel trained and qualified for operations involving CWM during intrusive construction activities on property known or 

suspected to contain MEC, or CWM in OTM configurations, where the probability of encountering such has been determined to be moderate to high. 

On-call UXO Construction Support. Support provided, on an as needed basis, by DoD EOD or UXO-qualified personnel during intrusive construction activities on property known or suspected to contain UXO or other munitions that 

have experienced abnormal environments where the probability of encountering such has been determined to be low. 

This support can respond from off-site when called, or be on-site and available to provide required construction support. 

On-site UXO Construction Support. Dedicated support provided by DoD EOD or UXO-qualified personnel during 

construction activities on property known or suspected to contain UXO or other munitions that have experienced abnormal environments where the probability of encountering such has been determined to be moderate to high. 

On-the-Surface. A situation in which UXO, DMM or CWM are: (A) entirely or partially exposed above the ground 

surface (i.e., the top of the soil layer); or (B) entirely or partially exposed above the surface of a water body (e.g., as a 

result of tidal activity).

Open Burn (OB). An open-air combustion process by which excess, unserviceable, or obsolete munitions are destroyed to eliminate their inherent explosive hazards. 
[Click here and type chapter title)] 

F-5 

Open Detonation (OD). An open-air process used for the treatment of excess, unserviceable or obsolete munitions 

whereby an explosive donor charge initiates the munitions being treated. 

Operational Range. A range that is under the jurisdiction, custody, or control of the Secretary of Defense and that is 

used for range activities; or although not currently being used for range activities, that is still considered by the Secretary

to be a range and has not been put to a new use that is incompatible with range activities. (10 U.S.C. 101(e)(3)(A) and 

(B)). Also includes “military range,” “active range,” and “inactive range” as those terms are defined in 40 CFR 

§266.201. (See reference (f)).

Primary Explosives. Primary explosives are highly sensitive compounds that are typically used in detonators and 

primers. A reaction is easily triggered by heat, spark, impact or friction. Examples of primary explosives are lead azide 

and mercury fulminate.

Public Access Exclusion Distance (PAED). The PAED is defined as longest distance of the hazardous fragment distance, IBD for overpressure, or the One Percent Lethality Distance. For siting purposes, the PAED is analogous to the 

IBD for explosives; therefore, personnel not directly associated with the chemical operations are not to be allowed 

within the PAED. 

Qualified Receiver. Entities that have personnel who are, or individuals who are, trained and experienced in the identification and safe handling of used and unused military munitions, and any known or potential explosive hazards that 

may be associated with the MPPEH they receive; and are licensed and permitted or otherwise qualified to receive, manage, and process MPPEH. 

Range. A designated land or water area that is set aside, managed, and used for range activities of the Department of 

Defense. The term includes firing lines and positions, maneuver areas, firing lanes, test pads, detonation pads, impact 

areas, electronic scoring sites, buffer zones with restricted access, and exclusionary areas. The term also includes airspace areas designated for military use in accordance with regulations and procedures prescribed by the Administrator of 

the Federal Aviation Administration. (10 U.S.C. 101(e)(1)(A) and (B)) 

Range activities. Research, development, testing, and evaluation of military munitions, other ordnance, and weapons 

systems; and the training of members of the armed forces in the use and handling of military munitions, other ordnance, 

and weapons systems. (10 U.S.C. 101(e)(2)(A) and (B))

Range-Related Debris. Debris, other than munitions debris, collected from operational ranges or from former ranges 

(e.g., targets).

Render Safe Procedures (RSP). The portion of EOD procedures that involves the application of special disposal 

methods or tools to interrupt the functions or separate the essential components of UXO to prevent an unacceptable 

detonation. 

Secondary Explosives. Secondary explosives are generally less sensitive to initiation than primary explosives and are 

typically used in booster and main charge applications. A severe shock is usually required to trigger a reaction. Examples are TNT, cyclo-1,3,5-trimethylene-2,4,6-trinitramine (RDX or cyclonite), HMX, and tetryl. 

Small Arms Ammunition. Ammunition, without projectiles that contain explosives (other than tracers), that is .50 

caliber or smaller, or for shotguns. 

Team Separation Distance (TSD). The distance that munitions response teams must be separated from each other during munitions response activities involving intrusive operations. 

Technical Escort Unit (TEU). A DoD organization manned with specially trained personnel that provide verification, 

sampling, detection, mitigation, render safe, decontamination, packaging, escort and remediation of chemical, biological 

and industrial devices or hazardous material. 
 

F-6 

Technology-aided Surface Removal. A removal of UXO, DMM or CWM on the surface (i.e., the top of the soil layer) 

only, in which the detection process is primarily performed visually, but is augmented by technology aids (e.g., handheld magnetometers or metal detectors) because vegetation, the weathering of UXO, DMM or CWM, or other factors 

make visual detection difficult. 

Time Critical Removal Action (TCRA). Removal actions where, based on the site evaluation, a determination is made 

that a removal is appropriate, and that less than 6 months exists before on-site removal activity must begin. (40 CFR 

300.5) 

Unexploded Ordnance (UXO). Military munitions that (A) have been primed, fuzed, armed, or otherwise prepared for 

action; (B) have been fired, dropped, launched, projected, or placed in such a manner as to constitute a hazard to operations, installations, personnel, or material; and (C) remain unexploded either by malfunction, design, or any other cause. 

(10 U.S.C. 101(e)(5)(A) through (C)))

UXO Avoidance. Techniques employed on property known or suspected to contain UXO or other munitions that have 

experienced abnormal environments, to avoid contact with potential explosive or CA hazards, to allow entry to the area 

for the performance of required operations.

UXO Technicians. Personnel who are qualified for and filling Department of Labor, Service Contract Act, Directory of 

Occupations, contractor positions of UXO Technician I, UXO Technician II, and UXO Technician III.

UXO-Qualified Personnel. Personnel who have performed successfully in military EOD positions, or are qualified to 

perform in the following Department of Labor, Service Contract Act, Directory of Occupations, contractor positions: 

UXO Technician II, UXO Technician III, UXO Safety Officer, UXO Quality Control Specialist, or Senior UXO Supervisor.

Venting. Exposing any internal cavities of MPPEH, to include training or practice munitions 

(e.g., concrete bombs), using DDESB- or DoD Component-approved procedures, to confirm that an explosive hazard is 

not present.

1

 This list expands the list of definitions contained in the 28 Oct 03 memorandum, 

DASA(ESOH), Subject: Definitions Related to Munitions Response Actions. 
G-1 

Appendix G 

Policy for Staffing and Approving Decision Documents 

(DD)1

1. References: 

a. DA Pamphlet 200-1, January 2002. 

b. Base Realignment and Closure Program Management Plan, April 1999. 

c. Installation Restoration Program Management Plan, March 1999. 

d. Management Guidance for the Defense Environmental Restoration Program 

(DERP), ODUSD (I&E), 28 September 2001. 

2. This policy applies to decision documents (DD), including ROD, Interim RODs, Action Memoranda, and Statements of Basis for response or corrective actions taken in 

accordance with the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA); the National Contingency Plan; Executive Order 12580; and the 

Resource Conservation and Recovery Act (RCRA). 

3. Decision documents are required to document response or corrective actions that 

are DERP eligible per reference 1c, including interim remedial actions, remedial actions, 

removals, or implementation of land use controls that Army imposes as part of a remedy 

to address a CERCLA risk or eligible RCRA corrective action. Emergency response actions shall be documented after the fact. All DDs must be included in the Administrative 

Record for the installation. 

4. Policy: Approval thresholds for DDs are described below: 

a. The Chief, BRAC FO is the approval authority for DDs that have a selected 

remedy with a present worth cost estimate of $2 million or less. 

b. The Chief, Base Realignment and Closure (BRAC) Division (DAIM-BD) is the 

approval authority for DDs that have a selected remedy with a present worth cost estimate of more than $2 million but less than or equal to $10 million. The Chief, BRAC Division may delegate this approval authority for Installation Restoration Program 

category responses to the Chiefs of BRAC FO with the concurrence of the Deputy Assistant Secretary of the Army (Environment, Safety and Occupational Health) 

(DASA(ESOH)). Approval authority for DDs for Military Munitions Response Program 

category responses may not be delegated. 

c. The ACSIM is the approval authority for DDs that have a selected remedy with 

a present worth cost estimate of more than $10 million. 
 Staffing and Approving Decision Documents (cont)

G-2 

d. For DDs of interest to the Army Secretariat, the DASA(ESOH) may elect to 

co-sign the DD. 

5. Staffing Procedures for BRAC and excess installations (Schematic showing the 

process for staffing is at TAB A): 

a. Regardless of approval level, before signing or forwarding decision documents for approval, the Chief, BRAC FO shall staff DDs with their environmental, legal, 

and public affairs offices. They shall also obtain coordination from USAEC, the US 

Army Center for Health Promotion and Preventive Medicine (USACHPPM), and, for Military Munitions Response Program (MMRP) category responses with explosive hazards, 

the US Army Technical Center for Explosive Safety (USATCES). 

b. DDs with costs of more than $2 million requiring ACSIM or Chief, BRAC Division approval: 

Submit six copies of final DDs through the appropriate BRAC FO, with an information copy to 

the appropriate Installation Management Agency (IMA) region, to. HQDA, (DAIM-BD/COL 

ROBERT DERRICK), ACSIM, 600 ARMY PENTAGON, WASH DC 20310-0600. The 

DAIM-BD will provide copies to the appropriate Headquarters, Department of Army (HQDA) 

Staff elements for staffing. 

c. The staffing matrix at TAB B shall be completed and included when forwarding a DD to the Chief, BRAC Division or ACSIM for approval. 

d. Chief, BRAC FO shall provide information copies of all DDs being staffed to 

the appropriate supporting Garrison Commander. 

6. The Environmental Law Division (ELD), Office of The Judge Advocate General 

(DAJA-EL) is available to assist the installations and BRAC FO's legal staffs. If installations or BRAC FOs identify legal concerns, they are encouraged to consult with ELD 

when staffing draft DDs. 

7. In addition to placing a copy of all signed DDs in the installation’s Administrative Record, installations shall provide one paper and one electronic copy of signed DDs to the 

USAEC, SFIM-AEC-CD, 5179 Hoadley Road, Aberdeen Proving Ground, MD 21010-

5401 for regular mail or USAEC, SFIM-AEC-CD, E4480 Beal Road, Aberdeen Proving 

Ground, MD 21010-5401 for FedX. In addition, the approving headquarters shall prepare a short executive summary of all signed DDs and send the executive summary via 

email to the Chief of the Cleanup Division, Office of the Director of Environmental Programs (ODEP); to the Assistant for Restoration, Office of the DASA(ESOH); and to the 

appropriate supporting garrison and IMA Region. The executive summary should describe the selected response action and its relationship to other cleanup actions/operable units. It should also contain such information as the degree of risk 

reduction, present value cost of the remedy and the contribution to the installation CTC 

for all remedies, amounts and fiscal year(s) that funds are required for remedial action 
 Staffing and Approving Decision Documents (cont)

G-3 

design and construction, duration of any remedial action operations, land use controls 

required and means for maintaining them, and other potential remedies considered. 

8. Responsibilities: BRAC and excess installations and BRAC FOs shall ensure that 

DDs that commit the Army to future expenses pass the following checks: 

a. The project must be DERP eligible per reference 1d. 

b. The BCP for BRAC installations or the Installation Action Plan for excess installations contains funding for the project(s), and the costs are accurately described in 

the installation’s CTC report. DAIM-BD as program manager for BRAC Cleanup Account funds must ensure that adequate funding exists within the President's Budget 

(budget years) and Future Year Defense Plan (program years) to support the project(s). 

c. The project(s) are consistent with priorities for relative risk reduction and 

property transfer as set forth in program guidance. 

9. Suspense: 

a. Transmittal memoranda should advise the chain of command of any negotiated or imposed deadlines and allow sufficient time for staffing at each level. To assist 

in planning, TAB A provides the time required for staffing at each stage. BRAC and excess installations and BRAC FO should plan on a minimum of two to four weeks to obtain approval after receipt of a complete DD packet at HQDA. They should also ensure 

regulators are aware of these time constraints during negotiations. 

b. For Fast Track Cleanup or in situations when an Interagency Agreement or 

Federal Facilities Agreement deadline might be missed because of staffing requirements for DDs with costs over $10 million: 

(1) The BRAC FO should convene a conference call with the USAEC restoration manager and installation, US Army Corps of Engineer district (when appropriate), and DAIM-BD representatives. 

(2) The conference call should result in an understanding of any deadlines 

and if and how the process will be expedited. 

(3) The BRAC and excess installation should send, via e-mail (PDF file 

format for smaller documents) or overnight or next day commercial delivery, a copy of 

the final DD to DAIM-BD to initiate the HQDA staffing process. 

10. Changes: 

a. BRAC FO chiefs may approve Explanation of Significant Differences (ESD) 

and ROD amendments for RODs originally approved by HQDA, if the ESD or ROD 

amendment does not increase the cost of the project by more than $2 million. Those 
 Staffing and Approving Decision Documents (cont)

G-4 

ESDs or ROD amendments that that increase the cost of the project by more than $2 

million shall be forwarded to DAIM-BD or ACSIM, as appropriate, for approval in accordance with paragraph 5 above. 

b. The actual cost of the remedy may exceed the authority of the original approval 

authority (e.g., $1.5 million ROD approved by BRAC FO; actual cost exceeds $2 million) due to, for example, a change in project scope or remedy cost. In that circumstance, the BRAC FO shall provide the next higher-level approval authority (DAIMBD or ACSIM, as appropriate) information regarding the original scope and cost estimate of the project and the nature, extent, and costs of any changes thereto. 

11. This guidance supersedes all previous guidance on this subject, including that in 

references 1a, 1b, and 1c and will be in effect until these references are revised and incorporate this guidance. 

1

 This appendix is extracted from the DASA(ESOH) memorandum, 7 Aug 03, Subject: 

Policies for Staffing and Approving Decision Documents. The words and graphics are 

from Enclosure 1, which applies to active and excess installations. Staffing Procedures 

5.b. and 7. were updated October 2004, with a correct mailing and Federal Express address.
 Staffing and Approving Decision Documents (cont)

G-5 
 Staffing and Approving Decision Documents (cont)

G-6 

 STAFFING MATRIX FOR DECISION DOCUMENTS

DECISION DOCUMENT TITLE: 

ORGANIZATION STAFF ACTIVITY POC NAME

OFFICE 

SYMBOL

PHONE 

NUMBER FAX NUMBER E-MAIL

INSTALLATION ENVIRONMENT

LEGAL 

PUBLIC AFFAIRS

CHPPM

1

For MMRP USAEC

 w/explosives risk

USATCES1

BRAC FO2 ENVIRONMENT

2 For BRAC & excess LEGAL 

 installations

PUBLIC AFFAIRS

USAEC3 ENVIRONMENT

3 For Active (operational) LEGAL 

 installations PUBLIC AFFAIRS

HQDA ODEP DAIM-EDC 703-601-0599 703-602-0857 firstname.lastname@hqda.army.mil

TJAG DAJA-EL 703-696-1230 703-696-2940 firstname.lastname@hqda.army.mil

ARMY PUBLIC 

AFFAIRS SAPA-PD 703-693-5591 703-693- firstname.lastname@hqda.army.mil

OTSG DASG-HS 703-681-3130 703-681-3163 firstname.lastname@otsg.amedd.army.mil

ODASA(ESOH) SAIE-ESOH 703-697-1987 703-604-2344 firstname.lastname@hqda.army.mil

BRACD2 DAIM-BD 703-601-1911 703-614-1568 firstname.lastname@hqda.army.mil

ARMY SAFETY OFF1 SAIE-ESOH 703-697-3123 703-614-5822 firstname.lastname@hqda.army.mil

TAB B to Enclosures 1 and 2
H-1 

Appendix H 

Army BRAC Cleanup Program Goals

Army BRAC Program Goals are ultimately derived from the the Army Environmental Cleanup 

Strategy (AECS). The AECS identifies overarching objectives to create consistency and accountability across the Army’s cleanup programs. A Strategic Plan for each program, in this 

case for BRAC, identifies specific objectives, targets, success indicators, reporting mechanisms, 

and management review processes for each program area identified in AECS. 

Overarching Vision 

for Army 

Environmental 

Cleanup 

The Army will be a national leader in cleaning 

up contaminated land 

to protect human health 

and the environment as 

an integral part of its 

mission.

Army Environmental Cleanup Strategy 

The Army’s environmental cleanup vision statement communicates the Army’s commitment to correct contamination of the environment for which the Army is responsible. 

From the vision statement, the Army develops a strategy 

that sets the stage for development of a strategic plan that 

is consistent with the principles of an Environmental Management System (ISO 14001) in the Army’s cleanup programs. 

Army Cleanup Strategic Plan

Key elements of the Strategic Plan are: 

Objectives: Specific outcomes that need to be accomplished within each of the cleanup 

program areas. 

Targets: The desired time or event milestones for achieving the objectives. 

Success Indicators: The specific measures of success in accomplishing the objectives. 

Reporting Mechanisms: Collecting, performing quality control, maintaining, and reporting data. 

Management Review: The procedures for ensuring that the objectives are sustained. 
 Army BRAC Program Goals (cont) 

H-2 

The cleanup program areas addressed in this strategic plan include cleanup efforts that have been 

conducted separately under the DERP, BRAC and compliance programs. The figure below depicts the differences and commonalities between the cleanup program areas. 

Defense Environmental 

Restoration Program 

(DERP)

Compliance-Related 

Cleanup

Army Environmental Cleanup Program Areas

Formerly Used

Defense Sites

(ER, FUDS)

Remediation Overseas (OMA)

Base Realignment and Closure (BRAC)

BRAC ’88 BRAC ’91 BRAC ’93 BRAC ’95 Future BRAC

Active Installations

Excess Installations

(ER,A) Special Installations (OMA, Mission, AWCF) 

Military 

Munitions 

Response 

Program 

(MMRP)

(ER,A &

MILCON)

ER,A OMA

(MILCON)

The Army has identified BRAC program goals within the Army Cleanup Strategy and corresponding Strategic Plan. These additional goals and metrics provide direction for implementing 

a cost efficient program. The Strategic Plan is updated on a bi-annual basis. The current BRAC 

program goals and objectives within the Army Cleanup Strategic Plan can be found at the 

USAEC Website at: http://aec.army.mil/usaec/cleanup/index.html 
I-1 

Appendix I

Abbreviations and Acronyms 

AECS Army Environmental Cleanup Strategy 

ACSIM Assistant Chief of Staff for Installation Management 

AEDB-R Army Environmental Database-Restoration 

AMS Army Management Structure 

AR Army Regulation 

ARAR Applicable or Relevant and Appropriate Requirement 

ARID Army Range Inventory Database 

ATSDR Agency for Toxic Substances and Disease Registry 

BCP BRAC Cleanup Plan 

BCT Base Realignment and Closure Cleanup Team 

BD/DR Building Demolition and Debris Removal 

BEC BRAC Environmental Coordinator 

BES Budget Estimate Submission 

BRAC Base Realignment and Closure 

BTC Base Realignment and Closure Transition Coordinator 

CA Cooperative Agreement 

CERCLA Comprehensive Environmental Response Compensation and 

Liability Act 

CERFA Community Environmental Response Facilitation Act 

CMS Corrective Measure Study 

CRP Community Relations Plan 

CTC Cost-to-Complete 

DA Department of the Army 

DASA (ESOH) Deputy Assistant Secretary of the Army for Environment, 
 

 I-2 

Safety and Occupational Health 

DASA(I&H) Deputy Assistant Secretary of the Army for Installation and 

Housing 

DD Decision Document 

DDESB DoD Explosives Safety Board 

DERP Defense Environmental Restoration Program

DFAS Defense Financial Accounting System 

DoD Department of Defense 

DODD Department of Defense Directive 

DODI DoD Instruction 

DOE Department of Energy 

DOJ Department of Justice 

DPG Defense Planning Guidance 

DSERTS Defense Site Environmental Restoration Tracking System 

DSMOA Defense and State Memorandum of Agreement 

DUSD (IA&I) Deputy Under Secretary of Defense, Industrial Affairs and 

Installations 

EBS Environmental Baseline Survey 

EC Engineering Controls 

ECOP Environmental Condition of Property 

EE/CA Engineering Evaluation/Cost Analysis 

ELD Environmental Law Division 

EOD Explosives Ordnance Disposal 

EPR Environmental Program Requirement 

ER,A Environmental Restoration, Army 

ERIS Environmental Restoration Information System 

ERM Environmental Restoration Manager 

ERP Environmental Restoration Program 
Abbreviations and Acronyms 

 I-3 

ESA Environmental Site Assessment 

ESD Explanation of Significant Differences 

ESS Explosive Safety Submissions 

ETA Early Transfer Authority 

FFA Federal Facility Agreement 

FMR Financial Management Regulation 

FO Field Office 

FOA Field Operating Agency 

FOSET Finding of Suitability for Early Transfer 

FOSL Finding of Suitability to Lease 

FOST Finding of Suitability to Transfer 

FTC Fast Track Cleanup 

FUDS Formerly Used Defense Sites 

FS Feasibility Study 

GSA General Services Administration 

GWETER Groundwater Extraction and Treatment Effectiveness Review 

HQ Headquarters 

HTRW Hazardous, Toxic and Radiological Waste 

IAG Interagency Agreement 

IAP Installation Action Plan 

IC Institutional Controls 

IGCE Independent Government Cost Estimate 

IPR In Progress Review 

IRA Interim Remedial Action 

IRP Installation Restoration Program

ITR Independent Technical Reviews 

LUC Land Use Control 
 

 I-4 

LRA Local Redevelopment Authority 

LTM Long Term Management 

MACOM Major Army Command 

MC Munitions Constituents 

MEC Munitions and Explosives of Concern 

MILCON Military Construction 

MMRP Military Munitions Response Program 

MOM Measure of Merit 

MOU Memorandum of Understanding 

NCP National Oil and Hazardous Substances Pollution Contingency Plan 

NDAI No DoD Action Indicated 

NEPA National Environmental Policy Act 

NGB National Guard Bureau 

NPL National Priorities List 

NRI Natural Resource Injuries 

NST NEPA Support team 

OE Ordnance and Explosives 

ODEP Office of the Director of Environmental Programs 

ODUSD (I&E) Office of the Deputy Under Secretary of Defense, Installations and Environment 

O&M Operations and Maintenance 

OMA Operation and Maintenance Account 

OTJAG Office of The Judge Advocate General 

PA/SI Preliminary Assessment/Site Inspection 

PAM Pamphlet 

PBC Performance-Based Contracting 

PCB Polychlorinated Biphenyl 
Abbreviations and Acronyms 

 I-5 

PER Principles of Environmental Restoration 

POC Point of Contact 

POM Program Objective Memorandum 

PRP Potentially Responsible Party 

RA Remedial Action 

RAB Restoration Advisory Board 

RAC Risk Assessment Code 

RA(C) Remedial Action - Construction 

RACER Remedial Action Cost Engineering and Requirements 

RA(O) Remedial Action - Operation 

RC Response Complete 

RCRA Resource Conservation and Recovery Act 

RD Remedial Design 

RFI/CMS RCRA Facility Investigations/Corrective Measures Studies 

RI/FS Remedial Investigation/Feasibility Study 

RIP Remedy-In-Place 

ROD Record of Decision 

RRSE Relative Risk Site Evaluation 

SARA Superfund Amendments and Reauthorization Act of 1986 

SB Statement of Basis 

SWMU Solid Waste Management Unit 

TAPP Technical Assistance for Public Participants 

TRC Technical Review Committee 

USACE US Army Corps of Engineers 

USATCES US Army Technical Center for Explosives Safety 

USACHPPM US Army Center for Health Promotion and Preventive Medicine 

USAEC US Army Environmental Center 
 

 I-6 

USEPA US Environmental Protection Agency 

UXO Unexploded Ordnance 

WMM Waste Military Munitions 
 J-1 

Appendix J

Available BRAC Environmental Guidance 

AVAILABLE BRAC ENVIRONMENTAL GUIDANCE 

1. DoD. Management Guidance for the Defense Environmental Restoration 

Program, Office of the Deputy Under Secretary of Defense (Environmental Security), Washington, DC, September, 2001. Internet 

http://www.dtic.mil/envirodod/envdocs.html 

2. DoD. Base Reuse Implementation Manual, Office of the Deputy Under 

Secretary of Defense (Industrial Affairs and Installations), Washington, 

DC, December, 1997. Internet http://emissary.acq.osd.mil/bccr/brim.nsf

3. HQDA. Environmental Quality: Environmental Protection and Enhancement. Army Regulation No. 200-1, Headquarters, Department of the Army, 

Washington, DC, 21 Feb 97. Internet 

http://www.army.mil/usapa/epubs/index.html

4. HQDA. Environmental Quality: Environmental Effects of Army Actions, 

Army Regulation No. 200-2, Headquarters, Department of the Army, 

Washington, DC. Internet http://www.army.mil/usapa/epubs/index.html

5. HQDA, 1995. Environmental Quality: Natural Resources – Land, Forest 

and Wildlife Management, Army Regulation No. 200-3, Headquarters, 

Department of the Army, Washington, DC. Internet 

http://www.denix.osd.mil/denix/Public/Policy/Army/ar200-3.html 

6. HQDA, 1998. Environmental Quality: Cultural Resources Management, 

Army Regulation No. 200-4, Headquarters, Department of the Army, 

Washington, DC. 

7. HQDA. Environmental Quality: Environmental Protection and Enhancement. Army Pamphlet No. 200-1, Headquarters, Department of the Army, 

Washington, DC, 17 Jan 2002. Internet http://www.usapa.army.mil/gils

8. USAEC. US Army Environmental Restoration Programs Guidance Manual, US Army Environmental Center, Aberdeen Proving Ground, MD, 

April 1998. Internet 

http://www.denix.osd.mil/denix/Public/Policy/Army/ERP/erptoc.html

9. USEPA. The Final Report of the Federal Facilities Environmental Restoration Dialogue Committee (FFERDC), US Environmental Protection 
Available BRAC Environmental Guidance 

 

 J-2 

Agency, Washington D.C., April 1996. Internet http:// www.epa.gov/ 

swerffrr/ferdcrpt /toc.htm 

10. Websites:

Defense Environmental Restoration Program (DERP) Report to 

Congress. Online copy of the 1994 through 2000 DERP Reports to 

Congress. http://www.dtic.mil/envirodod/envdocs.html

DoD Environmental Cleanup Home Page. Up-to-date information 

on the DoD cleanup program. 

http://www.dtic.mil/envirodod/index.html

US Army Corps of Engineers (USACE) Environmental Division. 

General information on USACE. 

htpp://hq.environmental.usace.army.mil/

Office of the Director of Environmental Programs – Army. General 

information on ODEP. http://www.hqda.army.mil/acsimweb/env/

US Army Environmental Center (USAEC). General information on 

USAEC. http://aec.army.mil

ATSDR 

1. DASA(ESOH). Memorandum on Agency for Toxic Substances and Disease Registry (ATSDR) Program Management Plan, Deputy Assistant 

Secretary of the Army (Environment, Safety and Occupational Health), 

Washington DC, 20 Mar 98. 

2. DoD. Guidelines for the Coordination of Comprehensive Environmental 

Response, Compensation, and Liability Act (CERCLA) Activities between 

the Agency for Toxic Substances and Disease Registry and the Department 

of Defense, Office of the Deputy Under Secretary of Defense (Environmental Security), Washington, DC, Feb 1995. 

3. USEPA. Guidance for Coordinating ATSDR Health Assessment Activities 

with the Superfund Remedial Process, OSWER Directive 9285.4-02, US 

Environmental Protection Agency, Washington DC, March 1987. 

COMMUNITY INVOLVEMENT

1. ACSIM. US Army Restoration Advisory Board and Technical Assistance 

for Public Participation, Assistant Chief of Staff for Installation Management, US Army Environmental Center, Aberdeen Proving Ground, MD, 

April 1998. Internet 

http://www.denix.osd.mil/denix/Public/Policy/Army/IRP/rabapr98.html
Available BRAC Environmental Guidance 

 J-3 

2. DoD. Restoration Advisory Board (RAB) Resource Book, Office of the 

Deputy Under Secretary of Defense (Environmental Security), Washington, DC, Sep 96. Internet 

http:// www.dtic.mil/envirodod/rab/rabresource

3. ASA(IL&E). Memorandum on Issuance of Policy – The Role of Restoration Advisory Boards (RABs) in Environmental Cleanup, Assistant Secretary of the Army (Installations, Logistics and the Environment), 

Washington DC, 7 May 1996. 

5. DoD. Restoration Advisory Board (RAB) Implementation Guidelines, Office of the Deputy Under Secretary of Defense (Environmental Security), 

Washington, DC and the US Environmental Protection Agency, Washington, DC, Sep 1994. Internet 

http://www.dtic.mil/envirodod/rab/finalrab.html

7. USEPA. Innovative Methods to Increase Public Involvement in Superfund 

Community Relations, OSWER Directive 9230.0-20, US Environmental 

Protection Agency, Washington, DC, Nov 1990. 

8. HQDA, 2000. The Army Public Affairs Program, Army Regulation No. 

360-1, Headquarters, Department of the Army, Washington, DC. . 

http://www.army.mil/usapa/epubs/pdf/r360_1.pdf 

9. Websites: 

RAB Information Home Page. Provides a list of publications and information about RABs. http://www.dtic.mil/envirodod/rab/ 

Cost Estimating 

1. ACSIM. Memorandum on Environmental Restoration Cost-to-Complete 

(CTC) Update, Assistant Chief of Staff for Installation Management, US 

Army Environmental Center, Aberdeen Proving Ground, MD, 28 Mar 98. 

2. ACSIM. Memorandum on Restoration Program Reporting, Office of the 

Assistant Chief of Staff for Installation Management (Office of the Director of Environmental Programs), Washington DC, 19 Mar 97. 

3. ACSIM. Memorandum on Managing the BRAC Environmental Program 

on a Site Level Basis, Office of the Assistant Chief of Staff for Installation 

Management (BRAC Office), Washington DC, 8 Aug 96. 

4. USEPA. Guide to Documenting Cost and Performance for Remediation 

Projects, Federal Remediation Technologies’ Roundtable, EPA/542/B95/002, US Environmental Protection Agency, Washington DC, March 

1995. 
Available BRAC Environmental Guidance 

 

 J-4 

CULTURAL/NATURAL RESOURCES

1. DAIM-BO, Memorandum on Interim Guidance - Proposed Resolutions to 

ACHP Issues, Office of the Assistant Chief of Staff for Installation Management (BRAC Office), Washington DC, 1 Sep 94. 

2. DAIM-ED-N. Memorandum on Endangered/Threatened Species Guidance, Office of the Assistant Chief of Staff for Installation Management 

(Environmental Division), Washington DC, 15 Feb 94. 

Decision Documents/Records of Decision 

1. DoD. Interim Guidance on Environmental Restoration Records of Decision, Office of the Under Secretary of Defense, Washington DC, 4 Jun 

2002. 

2. Memorandum, DASA(ESOH), 7 Aug 03, Subject: Policies for Staffng 

and Approving Decision Documents. 

3. ACSIM. Interim Notification Guidance on Documenting and Reviewing 

Land Use Controls (LUCs) developed under the Army Environmental Restoration Program, Assistant Chief of Staff for Installation Management, 

DAIM-BO, Washington DC, 25 Apr 2002. 

4. USEPA. Guidance for Preparing Superfund Decision Documents; The 

Proposed Plan, The Record of Decision, Explanation of Significant Differences, and The Record of Decision Amendment (Interim Final), 

EPA/540/G-89/007, OSWER Directive 9355.3-02, US Environmental 

Protection Agency, Washington DC, July 1989. 

DSMOA 

USACE. Working Together to Achieve Cleanup: A Guide to the Cooperative 

Agreement Process, Headquarters, US Army Corps of Engineers, Washington, 

DC, 22 Aug 97. Internet http://www.mrd.usace.army.mil/mrdedh/access/DSMOA/dsmoa.html

ENVIRONMENTAL JUSTICE

DoD. Strategy on Environmental Justice, Office of the Under Secretary of Defense, Washington DC, 24 Mar 95. Internet 

http://www.denix.osd.mil/denix/Public/Library/Planning/Justice/note7.html 

FAST TRACK CLEANUP

1. DoD. Memorandum on Submission of Fiscal Year 1997 BRAC Cleanup 

Plan (BCP) Abstracts, Office of the Deputy Under Secretary of Defense 
Available BRAC Environmental Guidance 

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(Environmental Security), Washington, DC, Aug 1997. Internet 

http://www.dtic.mil/envirodod/brac/bcp_abs/index.html

2. DoD. Memorandum on Modifications to the Fast Track Cleanup at Closing Installations, Office of the Deputy Under Secretary of Defense, Washington, DC, 18 May 1996. Internet 

http://www.dtic.mil/envirodod/brac/reissued.html

3. DoD. BRAC Cleanup Plan (BCP) Guidebook, Department of Defense, 

Washington DC, Fall, 1996. Internet 

http://www.dtic.mil/envirodod/brac/toc.html

4. USEPA. Guidance for Implementing the Fast Track Cleanup Program at 

Closing or Realigning Military Bases, US Environmental Protection 

Agency (Office of Solid Waste and Emergency Response), Washington 

DC, Feb 1996. 

5. ACSIM. Memorandum on BRAC 95 Environmental Baseline Surveys 

(EBSs) and BRAC Cleanup Plans (BCPs), Assistant Chief of Staff for Installation Management, US Army Environmental Center, Aberdeen Proving Ground, MD, 3 May 95. 

6. DAIM-BO. Memorandum on BRAC Implementation Guidance – BRAC 

95, Office of the Assistant Chief of Staff for Installation Management 

(BRAC Office), Washington DC, 28 Feb 95. 

7. DAIM-BO. Memorandum on BRAC 95 BTC/BEC Guidance, Office of the 

Assistant Chief of Staff for Installation Management (BRAC Office), 

Washington DC, 24 Feb 95. 

8. DAIM-ED-R. Memorandum on Policy Guidance – Version 2 BCPs, Office of the Assistant Chief of Staff for Installation Management (Office of 

the Director of Environmental Programs), Washington DC, 8 Dec 94. 

9. DAIM-BO. Memorandum on BRAC Environmental Restoration Policy 

Changes, Office of the Assistant Chief of Staff for Installation Management (BRAC Office), Washington DC, 22 Jul 94. 

10. DAIM-BO, 1994. Memorandum on Command Emphasis in Support of 

BRAC Environmental Coordinators, Office of the Assistant Chief of Staff 

for Installation Management (BRAC Office), Washington DC, 4 Feb 94. 

11. DAIM-BO. Memorandum on Additional Information on BRAC Cleanup 

Team Program Execution, Office of the Assistant Chief of Staff for Installation Management (BRAC Office), Washington DC, 4 Feb 94. 
Available BRAC Environmental Guidance 

 

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12. DAIM-BO. Memorandum on Funding of Fast Track Cleanup at Closing 

Installations, Office of the Assistant Chief of Staff for Installation Management (BRAC Office), Washington DC, 14 Jan 94. 

13. DAIM-BO. Memorandum on Implementing Guidance for Fast Track 

Cleanup at Closing Bases, Office of the Assistant Chief of Staff for Installation Management (BRAC Office), Washington DC, 8 Oct 93. 

14. DAIM-BO. Memorandum on Fast Track Cleanup at Closing Installations, Office of the Assistant Chief of Staff for Installation Management 

(BRAC Office), Washington DC,17 Sep 93. 

15. DoD. DoD Guidance and Policies on Fast Track Cleanup at Closing Installations, Office of the Deputy Under Secretary of Defense, Washington, 

DC, 9 Sep 93. 

FEDERAL FACILITIES AGREEMENT/INTER-AGENCY AGREEMENT AT NPL

INSTALLATIONS

DoD. Memorandum on DoD's Policy on NPL Site Agreements, Office of the Assistant Secretary of Defense, Washington DC, April 18, 1988. 

Five-Year Reviews 

1. ACSIM. Guidance for US Army Compliance with CERCLA Five-Year 

Review Requirements at Army Installations, Assistant Chief of Staff for 

Installation Management, US Army Environmental Center, Aberdeen 

Proving Ground, MD, 17 Jul 98. 

2. USEPA. Second Supplemental Five-Year Review Guidance, OSWER Directive 9355.7-03A, US Environmental Protection Agency, Washington, 

DC, 21 Dec 95. 

3. USEPA. Supplemental Five-Year Review Guidance, OSWER Directive 

9355.7-02A, US Environmental Protection Agency, Washington, DC, 26 

Jul 94. 

4. USEPA, 1991. Structure and Components of Five-Year Reviews, OSWER 

Directive 9355.7-02, US Environmental Protection Agency, Washington, 

DC, 23 May 91. 

Independent Technical Review 

ACSIM. Memorandum on Implementation of Technical Peer Review for Environmental Restoration Projects for Fiscal Year 1998, Interim Final, Assistant 

Chief of Staff for Installation Management, US Army Environmental Center, Aberdeen Proving Ground, MD, 2 Sep 97. 
Available BRAC Environmental Guidance 

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LAND USE CONTROLS

1. USAEC. Interim Army Land Use Controls (LUC) Management Plan, US 

Army Environmental Center, Aberdeen Proving Ground, MD, August 

2001. 

2. DoD. Interim Guidance on Environmental Restoration Records of Decision, Office of the Assistant Secretary of Defense, Washington DC, 4 Jun 

2002. 

3. ACSIM, Interim Guidance on Environmental Restoration Records of Decision, Assistant Chief of Staff for Installation Management, DAIM-BO, 

Washington DC, 6 Aug 2002. 

4. ACSIM. Interim Notification Guidance on Documenting and Reviewing 

Land Use Controls (LUCs) developed under the Army Environmental Restoration Program, Assistant Chief of Staff for Installation Management, 

DAIM-BO, Washington DC, 25 Apr 2002. 

NATIONAL ENVIRONMENTAL POLICY ACT (NEPA) 

1. DAIM-BO. Memorandum on General Information Concerning BRAC 

NEPA Documentation – BRAC 95, Office of the Assistant Chief of Staff 

for Installation Management (BRAC Office), Washington DC, 3 Apr 96. 

2. DAIM-BO. Memorandum on Delegation of Authority for BRAC NEPA 

Documentation, Office of the Assistant Chief of Staff for Installation 

Management (BRAC Office), Washington DC, 1 Apr 96. 

3. DAIM-BO. Memorandum on Checklist and Legal Review Certifications 

for BRAC NEPA Documentation Staffing at HQDA, Office of the Assistant Chief of Staff for Installation Management (BRAC Office), Washington DC, 17 Jul 96. 

4. USACE. Base Realignment and Closure Manual for Compliance with the 

National Environmental Policy Act, US Army Corps of Engineers, Mobile 

District, Mobile, AL, Sep 1995. 

5. DAIM-BO, 1994. Memorandum on BRAC NEPA Documentation, Office 

of the Assistant Chief of Staff for Installation Management (BRAC Office), Washington DC, 1 Sep 94. 

6. DAIM-BO. Memorandum on Disposal/Reuse NEPA Documentation, Office of the Assistant Chief of Staff for Installation Management (BRAC 

Office), Washington DC, 19 Oct 93. 
Available BRAC Environmental Guidance 

 

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NATURAL ATTENUATION

ACSIM. Memorandum on Interim Army Policy on Natural Attenuation for Environmental Restoration, Office of the Assistant Chief of Staff for Installation Management (Office of the Director of Environmental Programs) DAIM-ED-R, 

Washington DC, 19 Oct 93. 

RADIOLOGICAL SURVEYS

1. USAMC. Memorandum on Radiological Survey Policy for US Army Materiel Command (AMC) Radioactive Commodity Base Realignment and 

Closure (BRAC) Sites, US Army Materiel Command, Alexandria 17 Apr 

98. 

2. USEPA. Multi-Agency Radiation Survey and Site Investigation Manual, 

NUREG-1575/EPA 402-R-97-016, US Environmental Protection Agency, 

Washington DC, Dec 97. Internet http://www.epa.gov/radiation/marssim

3. DAIM-BO. Memorandum on Radiologic Contamination on Base Realignment and Closure (BRAC) Installations, Office of the Assistant Chief 

of Staff for Installation Management (BRAC Office), Washington DC, 25 

Mar 94. 

4. NRC. Residual Radioactive Contamination From Decommissioning, 

Technical Basis for Translating Contamination Levels to Annual Effective 

Dose Equivalent, NUREG/CR-5512, US Nuclear Regulatory Commission, 

Washington DC, Oct 1992. 

5. NCR. Manual for Conducting Radiological Surveys in Support of License 

Termination, NUREG/CR-5849, US Nuclear Regulatory Commission, 

Washington DC, Jun 1992. 

6. USEPA. Risk Assessment Guidance for Superfund, Volume 1: Human 

Health Evaluation Manual, Chapter 10, US Environmental Protection 

Agency, Washington DC, Sep 1989. 

7. Department of the Army. Ionizing Radiation Protection (Licensing, Control, Transport, Disposal, and Radiation Safety), Army Regulation No. 

385-11, Headquarters, Department of the Army, Washington, DC, 1 May 

1980. 

PROPERTY TRANSFER

1. USEPA. Memorandum on EPA Guidance on the Transfer of Federal 

Property by Deed Before All Necessary Remedial Action Has Been Taken 

Pursuant to CERCLA Section 120(h)(3), U. S. Environmental Protection 

Agency, Washington DC, 16 Jun 98. 
Available BRAC Environmental Guidance 

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2. DoD. Memorandum on Environmental Review Process to Obtain the 

Finding of Suitability Required for Use of Early Transfer Authority for 

Property Not on the National Priorities List, Office of the Deputy Under 

Secretary of Defense (Acquisition and Technology), Washington, DC, 24 

Apr 98. 

3. DoD. Memorandum on Responsibility for Additional Environmental 

Cleanup After Transfer of Real Property, Office of the Deputy Under Secretary of Defense (Acquisition and Technology), Washington, DC. 25 Jul 

97. 

4. DAIM-BO. Memorandum on Clarification of Meaning of Uncontaminated 

Property for Purposes of Transfer by the United States, Office of the Assistant Chief of Staff for Installation Management (BRAC Office), Washington DC, 9 Dec 96. 

5. DAIM-BO. Memorandum on Guidance for Leasing of BRAC Properties, 

Office of the Assistant Chief of Staff for Installation Management (BRAC 

Office), Washington DC, 31 May 96. 

6. DAIM-BO. Memorandum on Army Policy on Consideration of Future 

Land Use in Determining Cleanup Standards for Base Realignment and 

Closure (BRAC) Property, Office of the Assistant Chief of Staff for Installation Management (DAIM-ED-R), Washington DC, 23 Apr 96. 

7. DoD. Fast Track To FOST, Interim Final, Office of the Deputy Under 

Secretary of Defense (Environmental Security), Washington, DC. Feb 95. 

8. DAIM-ED-R, 1995. Memorandum on Implementing Guidance for Signature Authority and Staffing Procedures for Finding of Suitability to Transfer/Lease (FOST/FOSL), Office of the Assistant Chief of Staff for 

Installation Management, Washington DC 23 Aug 95. 

9. DAIM-ED-R. Memorandum on Use of Environmental Baseline Surveys 

(EBSs)- Transfer Policy Memorandum, Office of the Assistant Chief of 

Staff for Installation Management, Washington DC 11 Apr 94. 

Unexploded Ordnance 

1. DOD 6055.9 STD: DOD Ammunition and Explosives Safety Standards, 

Department of Defense Explosive Safety Board, Washington, DC. 

2. AR 385-64. US Army Explosives Safety Program, Headquarters, Department of the Army, Washington, DC. 

3. DA PAM 385-64. US Army Explosives Safety Program, Headquarters, 

Department of the Army, Washington, DC. 
Available BRAC Environmental Guidance 

 

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4. ER 385-1-92. Safety and Occupational Health Requirements for Hazardous, Toxic, and Radioactive Waste (HTRW) Activities, US Army Corps of 

Engineers, Washington, DC.

5. EM 200-1-2. Technical Project Planning, US Army Corps of Engineers, 

Washington, DC.

6. EP 385-1-95b. Explosives Safety Submission, US Army Corps of Engineers, Washington, DC