The Long-Term Management (LTMgt) phase occurs after completion of the Response Complete (RC) milestone. The LTMgt phase is required at sites where hazardous substances, pollutants, or contaminants remain above levels that would allow unlimited use and unrestricted exposure (UU/UE).
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The LTMgt phase is commonly required for containment type remedies such as landfills. This phase is also required where the site was remediated to levels required for commercial or industrial use and therefore UU/UE is not achieved. Typically, the LTMgt phase is expected to have an extended duration. Actions during this phase may include land use controls (LUCs), long-term monitoring (LTM), and Five-Year Reviews.
Land Use Controls
The Department of the Navy (DON) sites requiring LTMgt are expected to have LUCs implemented. LUCs include engineering controls and institutional controls. Engineering controls are remedies to contain and/or reduce contamination, and/or physical barriers intended to limit access to property. Examples of engineering controls may include fences, signs, guards, landfill caps, provision of potable water, slurry walls, sheet pile, and monitoring wells. Institutional controls include a variety of administrative and/or legal devices to maintain effectiveness of the selected remedy and any engineering controls. For active installations, examples of institutional controls may include restrictions on well drilling, soil excavation, and construction. For Base Realignment and Closure (BRAC) sites, institutional controls may include easements, covenants, zoning, restrictions, and permit requirements.
These LUCs must be defined as part of the selected remedial action in the Record of Decision (ROD)/Decision Document (DD). Procedures for periodic inspections of LUCs are established in the Remedial Design (RD) or Remedial Action Work Plan (RAWP). Remedial Project Managers (RPMs) are required to conduct periodic inspections as outlined in the RAWP and use the DON Web-based LUC Tracker Tool to document the integrity and implementation of LUCs. See the DON LUC policies linked below for additional information.
The LTMgt phase may involve LTM of groundwater, surface water, soil, soil vapor, sediment, and/or landfill gases at Environmental Restoration Program (ERP) sites. A site-specific Monitoring Plan including exit criteria is required for all LTM actions. Further detail is provided in the Environmental Protection Agency’s (EPA’s) Guidance for Monitoring at Hazardous Waste Sites: Framework for Monitoring Plan Development and Implementation (OSWER 9355.4-28). Because objectives may change in the transition from Remedial Action-Operations (RA-O) to LTMgt, the Monitoring Plan will likely require updating and optimization to focus on the LTMgt objectives. The DON Guidance for Planning and Optimizing Monitoring Strategies provides procedures to establish and implement cost-effective LTM programs. See the DON Guidance on Green and Sustainable Remediation (GSR) for details on footprint reduction approaches for LTM actions. Similar to the RA-O phase, annual reports during the LTMgt phase may also be prepared in accordance with the Navy’s Management and Monitoring Approach (MMA).
A Five-Year Review is required throughout the duration of the LTMgt phase as long as hazardous substances or pollutants or contaminants remain at levels that do not allow for UU/UE. More information on applicable DON and EPA policies and guidance can be found on the Five-Year Review Web page.
Completion of the LTMgt phase demonstrates that Site Closeout (SC) has been achieved. SC signifies that DON has completed active management and monitoring at a site, the remedy is protective of human health and the environment, and no additional DON funds are expected to be expended at the site. To document LTMgt completion and the SC milestone, a Remedial Action Completion Report (RACR) Amendment is prepared following the DON Guidance to Documenting Milestones throughout the Site Closeout Process.
For more information, Chapter 11 of the DON Environmental Restoration Program Manual details LTMgt considerations.