Cleaning Up Past Contamination
The District’s Lanham Tree Nursery, the US Botanical Gardens’ Production Facility, and the Naval Receiving Station operated on Poplar Point at a time when environmental consciousness about chemical pollution was not what it is today.
Several studies have discovered evidence of persistent chemical contamination on the Poplar Point site. Notwithstanding all the prior development visions and plans, no transfer of the property to DC can be made until a full pollution remediation plan has been approved.
In 2008, an “Administrative Settlement and Order on Consent” was signed between the National Park Service and the DC Government laying out the terms for a formal “Remedial Investigation and Feasibility Study” process under the federal Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) to characterize the contamination and determine the feasibility of cleaning it up. Within the DC government, the Department of Energy and Environment has responsibility for the “RI/FS” process. The joint National Park Service/DC government exercise took several years to get off the ground, and is still in its initial investigation phases.
While it is not a primary objective of the Working Group, if we can contribute to understanding this painfully slow and technical pollution investigation and remediation process (13 and a half years already, and still in the early stages) we will have performed a public service.
What is in the ground and water?
Perhaps the most authoritative explanation of the contamination, at least as it was known from prior studies a decade ago, comes from a 2011 National Park Service document:
“Beginning in the early 1990s, a number of environmental investigations have been performed at the Site. Most of these investigations focused on the southwestern portion of the Site, in the areas formerly operated as nurseries and greenhouses. Those investigations identified metals, pesticides, semi-volatile organic compounds (SVOCs), volatile organic compounds (VOCs), petroleum hydrocarbons, and polychlorinated biphenyls (PCBs) in Site soils above concentrations that may pose unacceptable risk to human health or the environment (referred to as screening levels). “
“Sediments at the Site were found to contain metals, pesticides, PCBs, and SVOCs above screening levels. Site groundwater sampling detected metals, pesticides, PCBs, VOCs, SVOCs, and petroleum hydrocarbons, and surface water sampling revealed manganese and VOCs all above screening levels. In addition to the prior environmental investigations, abandoned drums and inactive underground and above ground storage tanks were removed from the Site previously.”
What has to be done?
Continuing with the National Park Service document:
“In September 2008, NPS and the District entered into a Consent Order under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), by which the District agreed to conduct a CERCLA Remedial Investigation (RI) and Feasibility Study (FS) of the entire Poplar Point Site under the oversight of NPS. The RI will characterize the environmental conditions of the Site, and will include ecological and human health risk assessments. The FS will present a range of cleanup alternatives and evaluate those alternatives using prescribed criteria. Following completion of the RI and FS, a Proposed Plan identifying the preferred cleanup alternative will be issued. “
Where is the process now?
Thirteen and a half years after the consent order was signed, the District Department of Energy and the Environment and the National Park Service and their contractors are still only part way through the Remedial Investigation phase of the process. After the Remedial Investigation is complete, a Feasibility Study has to be done. When the Feasibility Study is approved, a new agreement has to be struck between the DC Government and the National Park Service covering the rest of the process: a Proposed Plan and Record of Decision, development of more detailed remedial plans and remedial actions, and finally a Complete Remedial Action Report. The question of how the federal government and the District will pay for the cleanup may take additional time to work out. Only after that can a process of transfer begin.
In addition to the CERCLA “RI/FS” process, a National Environmental Policy Act Environmental Impact Statement — another detailed document — must be prepared before a transfer can occur.