The Army addresses the following questions in a five-year review to assess remedy protectiveness:
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Is the remedy functioning as intended by the decision documents?
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Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives used at the time of the remedy selection still valid?
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Has any other information come to light that could call into question the protectiveness of the remedy?
The U.S. Army Environmental Command (USAEC) is the Army program manager for five-year reviews. Each year, USAEC notifies installations for which reviews are due in the upcoming fiscal year. Five-year reviews must be completed and signed no less than every five years after a selected remedial action has been initiated, and every five years thereafter. The DD/ROD and five-year review due dates are recorded in the Army Environmental Database-Restoration (AEDB-R).
A five-year review must be conducted for those sites where remedial actions do not allow for UU/UE. A review is also required for a site if the remedial action will result in UU/UE but will not achieve it within five years. Generally, all sites on an installation requiring five-year reviews are reviewed concurrently. Separate reviews may be conducted, however, for large or complex sites where operable units (OUs), or groups of OUs, have been treated as individual sites during the remedial process. Installations identify their five-year review requirements in their Cost-to-Complete, Installation Action Plan, and AEDB-R submissions. The data in AEDB-R are also used to prepare the Defense Environmental Program Annual Report to Congress (DEP ARC).
The U.S. Army Corps of Engineers Directorate of Environment and Munitions Center of Excellence (EM CX) conducts the five-year reviews for installations funded by the Environmental Restoration, Army (ER,A) account. The Army BRAC division chooses the executor for reviews at BRAC sites. The EM CX provides quality assurance and tracking for all Army five-year reviews regardless of executor.
Army five-year reviews include background document reviews, a site visit, and a report. The DERP guidance directs the Army to be consistent with the analytical framework found in the EPA document “Comprehensive Five-year Review Guidance” and supplements to that guidance, as directed by DoD and Army policy.
The five-year review report must contain a signed determination by the Installation Commander, or BRAC designee, that a selected remedy is or is not protective of human health and the environment. Copies of the final signed report are placed in the Installation Administrative Record and Information Repository, and provided to the USAEC, EPA and state regulators.
Where active, a Restoration Advisory Board (RAB) /Technical Review Committee (TRC), must be apprised of an upcoming five-year review, including the scope, conclusions reached, and where and when the final report may be viewed. Whether there is an active RAB or not, the installation must announce via newspaper of largest general circulation when a five-year review begins and when it has been completed.