Engineering and Expeditionary Warfare Center

LTMgt

LTM

Overview

 

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).

Jump to Resources to access Policies & Guidance, Publications, Related Sites, and Tools

 

Process

 

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.

Long-Term Monitoring

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).

Five-Year Reviews

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.

Resources

 

Topics

Title and Description

ERP Manual

DON Environmental Restoration Program Manual: Chapter 11 LTMgt (February 2018)

Outlines key considerations for optimized LTMgt and in meeting LUC and Five-Year Review requirements.

Site Closeout

DON Guidance to Documenting Milestones Throughout the Site Closeout Process (March 2006)

Outlines a consistent approach for documenting specific milestones for achieving site closeout.

Site Closeout

DoD/EPA Joint Guidance on Streamlined Site Closeout and NPL Deletion Process For DoD Facilities (January 2006)

Streamlines the site closeout and National Priorities List (NPL) deletion process for DoD facilities.

Land Use Controls

 

LUC Documentation

DON CERCLA ROD and Post-ROD Policy (January 2004)

Describes a framework for implementing LUCs including documentation of LUC objectives in the ROD.

LUC Policy

SECNAV Policy for Monitoring and Enforcement of Land Use Controls (April 2003)

Describes how to formulate LUC objectives in a ROD and how to document implementation actions through a RD or RAWP.

LUC Policy

DUSD(ES) Guidance on Land Use Controls Agreements with Environmental Regulatory Agencies (March 2001)

Provides an annotated outline for agreements with regulatory agencies for the management and monitoring of LUCs on property under the control of an installation.

LUC Policy

DUSD(ES) Policy on Land Use Controls Associated with Environmental Restoration Activities (January 2001)

Focuses on a framework of implementing, documenting, and managing LUCs for real property being transferred out of Federal control for active installations.

LUC Policy

DON Environmental Policy Memorandum 99-02: Land Use Controls (May 1999)

Establishes requirements for the development and use of LUCs at active and closing bases.

Long-Term Monitoring

 

Optimization Policy

DON Policy for Optimizing Remedial and Removal Actions at All DON Environmental Restoration Program Sites (April 2012)

Clarifies when to perform optimization reviews and provides effective remedial strategies to meet remedial action objectives. Requires consideration of: 1) GSR metrics; 2) remedial alternatives analysis (RAA); and 3) the MMA.

GSR Metrics

DON Guidance on Green Sustainable Remediation (April 2012)

Discusses how to incorporate GSR metrics into projects. Methods for evaluating remedy footprint are discussed, along with case studies and recommended strategies for footprint reduction.

Monitoring Optimization

DON Guidance for Planning and Optimizing Monitoring Strategies (November 2010)

Provides information on the planning and optimizing of monitoring programs. Monitoring for specific media types or site types include groundwater, sediments, groundwater discharge to surface water, ecological resources, vadose zone, landfills, and land use controls.

Five-Year Reviews

 

Five-Year Reviews

Five-Year Review Web Page

A comprehensive list of applicable DON and EPA policies and guidance can be found on the Five-Year Review Web page. 

Topics

Title and Description

Landfill               LTMgt

NAVFAC Sustainable Long-Term Management of Landfills under the Navy's Environmental Restoration Program (April 2016)

Sustainable long-term management of landfills helps to minimize the lifecycle depletion of energy, material, and financial resources.

Passive Sampling

NAVFAC Transitioning from Conventional to Passive Sampling for Groundwater (April 2013)

Provides an overall framework that can be used to assist in designing a transition plan from conventional sampling to passive sampling for groundwater.

Monitoring Reports

NAVFAC Management and Monitoring Approach (MMA) (May 2012)

Provides a format for documenting the application of these principles with a focus on decision-focused data management, evaluation, and reporting.

LUC Tracker

NAVFAC LUC Tracker Quick Reference Guide (March 2011)

Provides a brief overview of the LUC Tracker, which is a Naval Installation Restoration Information Solution (NIRIS) application used to track LUC information, notify when inspections are due, and document inspections.

Topics

Title and Description

Land Use Control

LUC 

Naval Installation Restoration Information Solution (NIRIS): LUC Tracker Tool

The DON Web-based LUC Tracker Tool should be used to document the integrity and implementation of LUCs.

Groundwater

Statistics 

EPA Groundwater Statistics Tool (Version 2)

Designed to evaluate contaminant of concern (COC) concentrations on a well-by-well basis to determine whether a groundwater restoration remedial action is complete.

LTM

Sampling

Metrics

Evaluation 

 

ESTCP Adaptive Long-Term Monitoring at Environmental Restoration Sites

A demonstration/validation project for a software tool to perform LTM optimization related to sampling location/frequencies, tracking of contaminant mass metrics, and performing statistical evaluations.

LTM

Sampling

Monitoring

Frequency 

ESTCP Methods for Minimization and Management of Variability in Long-Term Groundwater Monitoring Results

A demonstration/validation project on the use of alternative field sampling procedures for the collection of groundwater samples in order to minimize variability in groundwater monitoring results. Includes a Monitoring Frequency Optimization Tool.

Groundwater Monitoring 

Monitoring and Remediation Optimization System Software (MAROS)

Data management and evaluation tool to optimize long-term groundwater monitoring programs using both qualitative and quantitative methods.

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