The U.S. Coast Guard is responsible for numerous surplus or underutilized real property, including Lighthouses, Range Lights, Former Life Saving Stations, and Old Boat Stations, that the federal government is considering for divestment.  Many of the properties have environmental impacts derived from historical use of lead-based paint on exterior structures as well as other solid and hazardous materials utilized at the sites. Federal statues require that properties to be divested must be investigated and remediated in a manner consistent with the National Oil and Hazardous Substances Pollution Contingency Plan (NCP).
 
ARCADIS has assisted the U.S. Coast Guard since 2007 with establishing a consistent and predictable process to address impacted sites being considered for divestiture that satisfied federal, state, and local regulations and eliminate unacceptable risks to human health, welfare, and the environment for current and anticipated future land uses. ARCADIS regulatory experts recommended the U.S. Coast Guard take a programmatic approach to addressing the impacted properties.  The programmatic approach involves utilizing the U.S. Coast Guard’s ability to act as the lead agency under Executive Order 12580, and facilitates the conduct of non-time-critical removal actions consistent with the Comprehensive Environmental Response Compensation and Liability Act (CERCLA) and the NCP, Code of Federal Regulations (CFR) 40 CFR Part 300.   ARCADIS’ services include establishing agendas for and attending meetings with USEPA Region 3 and Region 5, assistance with preparation and negotiation of a interagency agreement (IAG) between the U.S. Coast Guard and USEPA, and assisting in the development of a general activities, decisions, and a document flow outline.  In order to ensure a consistent approach for site characterization, identification of potential risks and performance of removal actions at the properties to be divested, ARCADIS prepared templates for five primary documents that comprise the basis for conducting non-time critical removal actions under this  program, including:
• Quality Assurance Project Plan (QAPP)
• Field Sampling Plan (FSP)
• Engineering Evaluation/Cost Analysis (EE/CA)
• Removal Action Work Plan (RAWP)
• Removal Action Completion Report (RACR)

In additional, ARCADIS performed a comprehensive analysis of potential applicable, or relevant and appropriate statutes and regulations (ARARs), as well as to be considered (TBC) guidance.
The USEPA Regions 3 and 5 welcomed the conceptual programmatic approach that ARCADIS and the U.S. Coast Guard, and worked closely to formalize the approach.  In addition, other USEPA Regions have approached the U.S. Coast Guard to learn more about the program.  The predictable and consistent programmatic approach and use of templates facilitates rapid regulatory review and concurrence, allowing sites to proceed from start to finish through the process within 12 months, significantly faster than time frames experienced previously under state-lead regulatory programs.   

ARCADIS is currently applying this programmatic approach and using the template documents to facilitate environmental clean-up and divestiture at several sites within USEPA Region 5, including: Sturgeon Point Lighthouse, MI; Old Station Ludington, MI; Old Station Portage, MI; and within USEPA Region 3, including: Liston Rear Range Light, DE; Ready Island Rear Range Light, DE; and Base Support Unit Portsmouth, VA.  Under the direction of the U.S. Coast Guard other contractors have adopted the same approach at several other sites utilizing the templates developed by ARCADIS.