Background

In 1980, Congress enacted the Comprehensive Environmental Response Compensation and Liability Act (CERCLA). CERCLA, also known as the Superfund law, calls for the investigation of and response to hazardous substance releases that could endanger public health and the environment. It also provides the public with an opportunity to comment on proposed cleanup actions.

CERCLA at the Presidio

The first steps in the CERCLA cleanup process consist of limited-scope investigations of a site to determine if and where a hazardous substance has been released to the soil or water. Hazardous substances can be any chemical contaminant such as metals (lead, mercury, and cadmium), pesticides, chlorinated solvents, etc. except for petroleum products. If these preliminary investigations conclude that the contaminants at a site may pose a threat to human health and the environment, then a more comprehensive study of soil and water contamination, called a Remedial Investigation (RI), is conducted.

The Feasibility Study

Upon conclusion of the RI, a Feasibility Study (FS) is prepared. The Feasibility Study analyzes and recommends cleanup actions for a site. The recommended cleanup actions must be protective of human health and the environment and be cost-effective.

Remedial Action Plans (RAPs)

After the FS is complete, the next step is the preparation of a Remedial Action Plan, or RAP. At the Presidio, regulatory decision documents are called RAPs instead of Record of Decisions (or RODs) because the Trust is also following the conventions and requirements of the State of California Health and Safety Code. The RAP is the legal decision document which requires final cleanup action for a particular site. The Trust and the state regulatory agencies sign and concur on the RAP document. The public is afforded a 30-day public comment period on every draft RAP.

Once a RAP is final, the next step is to design and plan how to implement the cleanup action. After the designs are complete, the actual cleanup work is conducted in the field. The final step consists of monitoring the site to ensure that the cleanup work was successful.

“Clean Closure”

There are about 50 hazardous substances sites at the Presidio. The Trust’s preferred remedy for most of these sites is “clean closure.” Clean closure entails removing contaminated soil and debris and transporting the material off site to a certified waste management facility.

In 2002, the Trust and regulatory agencies signed a final RAP for two sites known as Landfill 4 and Fill Site 5 (shown here). The RAP required “clean closure” for both sites. Work was completed in early 2003. Also in 2003, a second final RAP was signed for three sites known as Baker Beach Disturbed Area 3 and 4 and Fill Site 6A. All three of these sites were “clean closed” in 2004-2005. For more information about these efforts, visit Featured Projects.

A third rap covering 28 CERCLA sites was released and signed in June 2007. A total of seven RAPs are anticipated for all Presidio CERCLA sites.