# Presentation: 943305

## Module 5:Remedial Process

- Module 5:Remedial Process

## Module Overview

- Module Objective:  Discuss the definition of a remedial action and explain the major steps and activities performed in conducting remedial actions under CERCLA
- Topics:
- Phases of the remedial process
- General requirements for remedial actions under CERCLA
- Role and responsibilities of the RPM
- General activities and requirements for each phase of the remedial process
- Management of documents and other records

## Definition of Remedial Action

- Long-term action to achieve a permanent remedy
- Typical remedial actions

## Major Phases in Remedial Process

- NCP defines six major phases in the remedial process
- RI
- FS
- Selection of remedy
- RD
- RA
- O&M (including site closeout)

## Remedial Program Goal and Management Principles

- National goal of remedy selection is to select remedies that are:
- Protective of human health and the environment
- Maintain protection over time
- Minimize untreated waste
- Management principles:
- Sites should generally be remediated in OUs
- OUs should not be inconsistent with final remedy
- Data collection and alternative analysis reflects scope and complexity of site problems

## Expectations for Developing Appropriate Remedial Alternatives

- Use treatment to address principal threats wherever practicable
- Use engineering controls to address long-term, lower level threats
- Use a combination of treatment, engineering controls, and institutional controls
- Use institutional controls to supplement engineering controls
- Consider using innovative technologies
- Return usable groundwater to its beneficial uses wherever practicable

## Risk Management Principles:  Remedial Action Objectives

- RAOs specify contaminants and media of concern, potential exposure pathways, and remediation goals
- PRGs are used initially and adjusted based on site-specific information
- Final remediation goals are determined when the remedy is selected

## Risk Management Principles:Remediation Goals

- Establish acceptable exposure levels
- Must consider ARARs and facility siting laws and the following factors:
- For systemic toxicants, levels that do not cause adverse effects
- For carcinogens, levels corresponding to excess lifetime cancer risk between 10-4 and 10-6
- For carcinogens, use 10-6 level as point of departure for PRGs when ARARs are not available or sufficiently protective because of multiple contaminants and pathways
- Factors related to technical limitations and uncertainty
- Other pertinent information

## Risk Management Principles: Additional Considerations for RAOs

- Attain MCLG set above zero where relevant and appropriate
- Attain MCL when MCLG is set at zero
- Attain water quality criteria where relevant and appropriate
- Establish alternative concentration level in accordance with CERCLA
- Evaluate environmental threats

## Responsibilities of the RPM

- The RPM has the authority and the responsibility to:
- Participate in all decision-making processes
- Coordinate with all parties involved

## Overview of the RI/FS Process

- RI/FS supports selection of the remedy
- RI is performed to characterize the site
- FS is used to develop and analyze remedial action alternatives
- Various lead agencies may conduct the RI/FS

## Interdependency of the RI and FS

## Main Activities of the RI

- Site characterization
- Baseline risk assessment
- Treatability studies

## Main Activities of the FS

- Development and screening of alternatives
- Detailed analysis of alternatives

## Development and Screening of Alternatives

- Development and screening involve seven general steps:
- Refine the RAOs
- Develop general response actions
- Identify volumes or areas of media
- Identify remedial technologies
- Identify and screen process options
- Assemble alternatives
- Screen alternatives

## Scoping the RI/FS

- Goal of RI/FS is to support the ROD
- RI/FS process begins with scoping
- Key Activities
- Form a site team
- Conduct a kickoff meeting with the site team
- Develop a CSM
- Identify initial DQOs
- Identify RAOs, general response actions, and ARARs
- Collect and evaluate existing data
- Conduct a site visit

## RI/FS Project Plans

- The RPM is responsible for overseeing the preparation of several work plans
- RI/FS work plan
- SAP
- QAPP
- FSP
- HASP
- CIP

## RI/FS Report

- The RI/FS report
- Forms foundation of support in remedy selection process
- Documents the development and screening of remedial alternatives

## Detailed Analysis of Alternatives

- Nine evaluation criteria are the basis for remedy selection
- The nine criteria are separated into three levels
- Threshold criteria
- Balancing criteria
- Modifying criteria

## Nine Evaluation Criteria

- Threshold criteria
- Overall protection of human health and the environment
- Compliance with ARARs
- Balancing criteria
- Long-term effectiveness and permanence
- Reduction of toxicity, mobility, or volume through treatment
- Short-term effectiveness
- Implementability
- Cost
- Modifying criteria
- State (support agency) acceptance
- Community acceptance

## Overview of the Remedy Selection Process

- CERCLA establishes specific requirements
- The NCP establishes procedures for proposing and documenting final remedy
- Changes that occur after selection of the remedy need to be addressed
- EPA reforms to improve thequality of selected remedies

## CERCLA Requirementsfor Remedy Selection

- Protect human health and the environment
- Attain (or waive) ARARs
- Be cost-effective
- Use permanent solutions and alternative treatment technologies to the maximum extent practicable
- Satisfy the preference for treatment as a principal element of the remedy
- Involve states in a substantial and meaningful manner
- Consistency with the NCP

## The Remedy Selection Process

## Proposed Plan

- Highlights key aspects of the RI/FS
- Describes remedial alternatives
- Explains the rationale for selection of the preferred alternative
- Requests comments from the public
- Includes the views of support agencies

## Document the Final Selection of the Remedy in a ROD

- Review public comments
- Address significant changes in the selected remedy
- Solicit additional comments
- Reassess initial determination of the preferred alternative
- Select the final remedy
- The lead agency has responsibility
- The PRP should not influence the decision
- The best balance among the criteria should be evaluated

## ROD and Responsiveness Summary

- A ROD is:
- The official decision document on remedy selection
- A technical, legal, and public document
- A responsiveness summary is:
- A written summary of responses to each significant comment submitted during the public comment period

## Preparing the ROD

- Prepare draft
- ROD

- Brief lead
- agency management

- Revise
- ROD for
- signature

- Receive
- concurrence
- from support
- agency

- Brief Regional
- Administrator, and
- support agency, as
- necessary

- Review at
- support
- agency

- Obtain all appropriate
- concurrents and
- final signatures

- Issue ROD

- Review at EPA headquarters (if requested)

- (continued)

## Preparing the ROD

- The lead agency prepares the ROD
- EPA retains final authority over remedy selection
- The ROD is supported by documents in the AR
- Follow procedures for review, concurrence, and signature

## Content of the ROD

- Declaration
- Formal statement signed by RA
- Decision summary
- Overview of problems and risks
- Rationale for remedy selection
- Responsiveness summary
- Addresses comments received

## Post-ROD Changes

- Changes are prompted by new information, enforcement agreements, or developments during RD/RA
- There are three types of ROD changes
- Minor
- Significant
- Fundamental
- Different requirements andprocedures apply to each type of post-ROD change

## Superfund Reforms — Remedy Selection

- Superfund reforms improve consistency in remedy selection