guidance on feasibility studies june 1985 guidance on feasibility studies under cercla prepared for:...

United StatesEnvironmental ProtectionAgency

Office of Emergency andRemedial Response andOffice of Waste ProgramsEnforcementOffice of Solid Waste andEnergency ResponseWashington DC 20460

Office of Research andDevelopmentHazardous Waste EngineeringResearch LaboratoryCincinnati OH 45268

Superfund EPA/540/G-85/003 June 1985

Guidance onFeasibility StudiesUnder CERCLA

EPA Region 5 Records Ctr.

EPA/540/G-85/003June 1985

Guidance on Feasibility StudiesUnder CERCLA

Prepared for:

Hazardous Waste Engineering Research LaboratoryOffice of Research and Development

U.S. Environmental Protection AgencyCincinnati, Ohio 45268

and

Office of Emergency and Remedial Responseand

Office of Waste Programs EnforcementOffice of Solid Waste and Emergency Response

U.S. Environmental Protection AgencyWashington, D.C. 20460

NOTICE

The information in this docnaent has been funded, wholly or in part, by theUnited States Environaental Protection Agency under Contract Mo. 68-03-3113to JIB Associates. It has been subject to the Agency's peer and adwinistratireview and has been approved for publication as an EPA docnaent.

Thla docnaent provides guidance for the preparation of .feasibility studiesrequired under the revised National Contingency Plan.

ii

FOREWORD

Under the authorities of the Comprehensive Environmental Response,Compensation and Liability Act of 1980 (CERCLA), the Office of Emergencyand Remdial Response and the Office of Waste Programs Enforcement areresponsible for overseeing the development and implementation of theGovernment's program for response to uncontrolled releases of hazardoussubstances. These responses ensure that threats to public health, welfare,or the environment are appropriately addressed through the effectivemanagement of CERCLA's enforcement and funding authorities. The HazardousWaste Engineering Laboratory develops new and improved technologies andsystems to prevent, treat, and manage hazardous waste pollutant dischargesto minimize the adverse economic, social, health, and aesthetic effects ofpollution.

This document is a cooperative effort between the Office of SolidWaste and Emergency Response and the Office of Research and Development.It is one of a series of reports being published to implement CERCLA,otherwise known as Superfund. These reports provide an array of informationnecessary for compliance with the National Contingency Plan (NCP, 47 FR31180, July 16, 1982), including: guidance for remedial investigation andfeasibility studies, guidance for exposure assessments, analytical andengineering methods and procedures, research reports, technical manuals,toxicologies! and engineering data bases, and other reference documentspertinent to Superfund.

This guidance document provides guidance for the preparation offeasibility studies required under the revised NCP. It provides projectmanagers and decision makers in government and industry with guidelines fordeveloping and evaluating alternative remedial responses to be uncontrolledreleases of hazardous substances. In conjunction with other publicationsin this series, it will assist in meeting the national goal of adequatelyprotecting public health, welfare, and the environment.

ill

ABSTRACT

This guidance ilocimmint is Intended to provide a more detailed structurefor Identifying, evaluating, and selecting remedial action alternativesunder the Comprehensive Environmental Response, Compensation, and LiabilityAct (CERCLA) and the National Contingency Plan (40 CTR 300).

The feasibility study process begins with the development of specificalternatives based on general response actions identified in the remedialinvestigation to address site contamination problems. Technologies withinthe categories are screened for their technical applicability to the site.Technologies considered technically appropriate are then combined to formalternatives that fulfill five specific categories. The alternatives arescreened on the besls of public health and environmental concerns andorder-of-magnltnde costs.

Alternatives that pass the screening process undergo detailed analysesto provide the declslonmaker with Information for selecting the alternativethat is cost-effective. The detailed analyses encompasses engineering,institutional, public health, environmental, and cost analyses. Theengineering analysis evaluates constructability and reliability to ensurethe implementabillty of alternatives. The institutional analysis examinesalternatives in terms of the Federal, State, or local requirements,advisories, or guidance that must be considered to protect the publichealth, welfare, and environment. The public health exposure evaluationIncludes baseline site evaluation, exposure assessment, standards analysis,short- and long-term effects of each alternative, and endangerment assess-ment. The environmental analysis includes assessment of adverse impacts ifno action is taken and the short- and long-term effects of the alternatives.The cost analysis examines capital and operation costs, and involves presentworth and sensitivity analyses.

Once the detailed analyses are conducted, the information is organizedto compare findings of the evaluations for each alternative. The objectiveof this mmwjsry is to ensure that Important information is presented in aconcise format so that the declslonmaker can choose the remedy that providesthe best balance of health and environmental protection, and engineeringreliability with cost.

A recommended format for the Feasibility Study Report is also provided.It describes the specific elements to be included, the rationale for theirinclusions, the level of detail, and the documentation that should accompanythe report.

CONTENTS

Page

FOREWORD iii

ABSTRACT iv

FIGURES x

TABLES Xi

ACKNOWLEDGEMENTS xii

1. EXECUTIVE SUMMARY 1-1

1.1 THE NATIONAL CONTINGENCY PLAN FRAMEWORK FOR THE REMEDIALRESPONSE PROCESS 1-3

1.2 AN OVERVIEW OF THE FEASIBILITY STUDY PROCESS 1-6

1.3 REMEDIAL ALTERNATIVES MUST ADDRESS THE REQUIREMENTS OF OTHERENVIRONMENTAL LAWS 1-8

1.4 THE PROCESS APPLIES TO ENFORCEMENT ACTIONS 1-9

1.5 SUPPLEMENTAL GUIDANCE DOCUMENTS UNDER DEVELOPMENT 1-9

2. DEVELOP A RANGE OF REMEDIAL ALTERNATIVES 2-1

2.1 OVERALL APPROACH 2-2

2.2 IDENTIFY GENERAL RESPONSE ACTIONS 2-42.2.1 Identify Site Problems 2-42.2.2 Identify General Response Actions 2-5

2.3 IDENTIFY AND SCREEN TECHNOLOGIES 2-6

2.4 DEVELOP ALTERNATIVES BY COMBINING TECHNOLOGIES 2-162.4.1 Source Control Remedies 2-182.4.2 Management of Migration Remedies 2-19

2.5 SCREEN ALTERNATIVES FOR PUBLIC HEALTH, ENVIRONMENTAL, ANDCOST FACTORS 2-202.5.1 Environmental and Public Health Screening 2-202.5.2 Cost Screening Factors 2-20

CONTENTS (continued)

Page

3. CONDUCT A DETAILED TECHNICAL EVALUATION 3-1

3.1 PERFORMANCE 3-23.1.1 Effectiveness 3-23.1.2 Useful Life 3-3

3.2 RELIABILITY 3-33.2.1 Operation and Maintenance Requirements 3-33.2.2 Demonstrated Performance 3-3

3.3 OffLEMENTABILITY 3-43.3.1 Constructability 3-43.3.2 Tim* 3-5

3.4 SAFETY 3-5

3.5 SUMMARY OP TECHHICAL FEASIBILITY ANALYSIS 3-6

4. EVALUATE INSTITUTIONAL REQUIREMENTS 4-1

4.1 uvKKVidi* OF INSTITUTIONAL REQUIREMENTS . . . 4-1

4.2 CERCLA COMPLIANCE WITH OTHER ENVIRONMENTAL STATUTES 4-24.2.1 Selection of Remedy 4-4

4.3 EPA GROUND-WATER PROTECTION STRATEGY 4-6

4.4 COMPLIANCE WITH THE NATIONAL ENVIRONMENTAL POLICYACT (KPA) 4-9

4.5 COORDINATION WITH OTHER AGENCIES 4-94.5.1 Federal BBcrgency Management Agency 4-104.5.2 Health and Buean Services 4-104.5.3 U.S. Army Corps of Engineers 4-114.5.4 U.S. Geological Survey 4-114.5.5 Occupational Safety and Health Administration .... 4-124.5.6 National Response Team 4-124.5.7 Other Government Authorities 4-13

4.6 COMMUNITY RELATIONS 4—13

4.7 SUMMARY OF INSTITUTIONAL REQUIREMENTS 4-15

5. EVALUATE PROTECTION OF PUBLIC HEALTH REQUIREMENTS 5-1

5.1 OVERVIEW 5-1

vi

CONTENTS (Continued)

Page

5.2 DEVELOP A BASELINE SITE EVALUATION ............. 5-2

5.3 DEVELOP AN EXPOSURE ASSESSMENT ............... 5-3

5.4 COMPARE ALTERNATIVES TO APPLICABLE OR RELEVANTENVIRONMENTAL STANDARDS ............ ....... 5-85.4.1 Assumptions Underlying Applicable and Relevant

Standards ...................... 5-155.4.2 Resource Conservation and Recovery Act Hazardous

Waste Regulations (40 CFR 264) ...... ...... 5-155.4.3 National Interim Primary Drinking Water Standards

(NIPDWs) and Maximum Contaminant Levels (MCLs). . . . 5-165.4.4 National Ambient Air Quality Standards (NAAQS) ..... 5-165.4.5 Federal Water Quality Criteria and State Water

Quality Standards .................. 5-175.4.6 PCBs ......................... 5-18

5.5 CONSIDER OTHER CRITERIA AND ADVISORIES ........... 5-185.5.1 Criteria for None arc inogens ............. 5-185.5.2 Criteria for Carcinogens ............... 5-185.5.3 Health Advisories (SNARLs) .............. 5-19

. .5.6 ADJUSTMENT OF STANDARDS AND CRITERIA ............ 5-19

5.7 UNAVAILABLE OR INAPPROPRIATE STANDARDS ........... 5-19

5.8 SUMMARY OF PUBLIC HEALTH EVALUATION ............. 5-20

6. EVALUATE ENVIRONMENTAL IMPACTS .................. 6-1

6.1 OVERVIEW OF THE ENVIRONMENTAL ASSESSMENT .......... 6-2

6.2 EVALUATE ALTERNATIVE RESPONSES ............... 6-26.2.1 Beneficial Effects of the Response .......... 6-36.2.2 Adverse Effects of the Response ............ 6-11

6.3 OTHER ASSESSMENT PROGRAMS .................. 6-12

6.4 SUMMARY OF ENVIRONMENTAL ANALYSIS .............. 6-12

7. CONDUCT A DETAILED COST ANALYSIS ................. 7-1

7.1 ESTIMATION OF COSTS ..................... 7-37.1.1 Capital Costs ..................... 7-47.1.2 Operation and Maintenance Costs ............ 7-57.1.3 Sources of Cost Information .............. 7-6

vii

COHTEHTS (Continued)

7.1.4 Updating Coses 7-77.1.5 Accuracy of Cost Estimates 7-7

7.2 PiESEHT WORTH AHALTSIS 7-8

7.3 SMS1T1V1TT ABALYSIS 7-8

7.4 SUMIAftY OF ALTERNATIVES ANALYSIS 7-11

8. SOMIARIZE ALTERNATIVES 8-1

8.1 OVERVIEW 8-1

8.2 CSKCLA COMPLIANCE WITH OTHEft ENVIRONMENTAL LUIS 8-18.2.1 Other Federal Environmental Standards, Guidance, or

Advisories *. 8-38.2.2 State Environmental Standards, Guidance, or

Advisories 8—3

8.3 r»fUlffT7T AND PRESENT UPOtMATIOB 8-3

9. PEASIBILrTT STTJDT EEPOBT FOBMAT 9-1

9.1 ILlECimVE SUM1AKT 9-1

9.2 iaiKODUOTlOH . ...... 9—19.2.1 Sice Background Information 9-39.2.2 mature and Extent of Problems 9-39.2.3 Objectives of temedisl Action 9-4

9.3 SCIEETOK OF REMEDIAL ACTIOR TECHNOLOGIES 9-4

9.4 REMEDIAL ACTIOH ALTEUATIVES 9-5

9.5 AHALTSIS OF BEMEDIAL ACTIOM ALTEBMATIVES . 9-69.5.1 •oncost Criteria Analysis 9-69.5.2 Cost Analysis 9-6

9.6 SUM1AET OF ALTEBHATTVES 9-7

9.7 tECOMMEHDCD REMEDIAL ACTIOB 9-7

9.8 RESPOVSIYEHESS SUMMIT 9-8

9.9 REFEREKES 9-8

9.10 APPEHDICES 9-8

viii

CONTENTS (Continued)

GLOSSARY

REFERENCES

APPENDIX A. FEASIBILITY STUDY MODEL STATEMENT OF WORK

APPENDIX B. PROCEDURES FOR PLANNING AND IMPLEMENTING OFF-SITERESPONSE ACTIONS

APPENDIX C. CERCLA COMPLIANCE WITH OTHER ENVIRONMENTAL STATUTES

jg j A

ix

FIGURES

P«ge

1-1 Current KP Process 1-2

1-2 K/FS Process 1-5

1-3 Feasibility Study Process 1-7

2-1 Feasibility Study Alternative Development and ScreeningProcess 2-3

7-1 Feasibility Study Cost Evaluation Process 7-2

TABLES

Page

2-1 General Response Actions and Associated Remedial Technologies* • 2-7

2-2 Remedial Technologies 2-8

2-3 Site Characteristics That May Affect Remedial TechnologySelection 2-15

2-4 Waste Characteristics That May Affect Remedial TechnologySelection 2-15

3-1 Summary of Technical Feasibility Evaluation 3-7

4-1 Applicable or Relevant Requirements 4-16

4-2 Other Requirements, Advisories, and Guidance to Be Considered* • 4-19

5-1 Questions In Exposure Assessment 5-5

5-2 EPA Ambient Standards and Criteria for SuperfundRemedial Sites 5-9

5-3 Summary of Key Public Health Evaluation Questions 5-21

6-1 Availability of State Ambient Water Quality Criteria orStandards for Toxic Substances 6-5

6-2 Suggested Summary Form for Use by the Environmental Section toEvaluate Remedial Alternatives 6-13

7-1 Present Worth Analysis of Three Alternatives at ThreeDiscount Rates 7-10

3-1 Source Control Alternatives Summary for Lehigh Electric 8-6

8-2 Management of Migration Alternatives Summary for Rellly Tar,First Operable Unit 8-7

8-3 Source Control and Management of Migration Alternatives Summaryfor Hard Times Waste Site 8-8

9-1 Feasibility Study Report Format 9-2

XI

This document was developed for Che Office of Solid Waste and EmergencyResponse and represents a collective effort of many Agency and contractorpersonnel. Richard Stanford1 and Bruce Clemens of the Policy AnalysisStaff, Office of Emergency and Remedial Response (OERR) and Douglas Ammanof the Hazardous Haste Engineering Laboratory were the EPA Co-ProjectOfficers. Richard Stanford is especially acknowledged for conceptualdevelopment and project management. James Lounsbury, Director, PolicyAnalysis Staff, OERR, Brint Blxler, OERR, and Clarence dcoons. Center forEnvironmental Research Information, ORD contributed significantly to theproject. Policy development efforts of James Lounsbury, Syllva Lovrance,Douglas Cohen and Brlnt Bixler are acknowledged. Doris Sanders, RobertCochran, and Virginia Bodge were successive project managers with JRBAssociates and associated with project coordination. The final report is acompilation of efforts of the following contributors:

Paul Rogoshewekl,Robert Cochran,Virginia Bodge, JIBAssso dates

Richard Stanford1, U.S. EPA

Alternative Develand Screening

Evaluation of Technical Feasibility William Adams, BUS Corp.Richard Stanford1, U.S. EPA

Public Bealth Evaluation Joseph Rodricks, EnvironGilah Langner, Stephen Bailey,ICT Incorporated

Van Kozak, Lee Schlltz,Versar, Inc.

Priscllla Bolzclaw, John Hall,U.S. EPA

Institutional Issues Gilah Langner, licholas Bauer,ICF, Incorporated

Envl tal Asses Edward tang, James Warner,Environmental Law Institute

Richard Stanford1, U.S. EPA

Currently with Clean Sites, Inc.

xii

Cost Analysis

Summary of Alternatives

Report Format

Robert Cochran, JRB AssociatesMichael Culpepper, CH.M-HillBruce Clemens, U.S. EPABrint Bixler, U.S. EPA

Richard StanfordU.S. EPA

Virginia Hodge,JRB Associates

Jeff Kolb,

Preparation of this guidance document was aided greatly by theconstructive contributions of the following reviewers:

Barbara IkalanienJohn MateoTom VoltaggioAnthony RutterJohn BrinkCraig WolffRoy MurphyNancy WillisBrine BixlerG.M. GigliottiRobert KissellJim Spatarella

.S.

.S.EPA Region IEPA Region IIEPA Region IIIEPA Region 7EPA Region VIIIEPA OPPEEPA OWPEEPA OERREPA OERREPA CERI

Chemical Manufacturers Assn.U.S. EPA OERR

UUU.S.U.S.U.S.U.S.U.S.U.S.U.S.U.S.

We also appreciate the assistance of the following EPA Work Groupmembers:

James LounsburyLee ModesittRob ClemensHelen Kepi ingerCraig ZamudaStacey KatzDon SanningGary CohenDoug AnmonBrint BixlerBob LinettSam GutterAbe MittelmanArnold M. KuzmackChris DeRosaCharles GreggKaren McCoroackHeidi Hughes

ChairmanOEAOWPEOECM-WasteOERROPPEORD/HWERLOWEPORD/HWERLHSCD/OERROWRSOGCOWPEODWORD/OHEA/ECAOOWOPTSOECM-W

1Currently with Clean Sites, Inc.

Xlll

Jerry Schwartz OECM-VRichard Boblnson OLEPGall Korb OABMDeborah Taylor OA

Appreciation la also extended to Che numerous other Individuals fro»Federal, State, Industry, and enrlrooaencal organizations «ho were contactedon matters related to this guidance document.

xiv

CHAPTER 1

EXECUTIVE SUMMARY

The Comprehensive Environmental Response, Compensation, and LiabilityAct of 1980 (CERCLA) establishes a national program for responding toreleases of hazardous substances into the environment. The fundingmechanism for this program is the Hazardous Substance Response Trust Fund(commonly referred to as the Super fund) , which provides funding for thestudies of such releases and the development and implementation of removaland remedial response actions. The operational centerpiece of this program,that ensures the Super fund is used as effectively as possible for thesepurposes, is the revised National Oil and Hazardous Substances ContingencyPlan (NCP) , originally promulgated under section 311 of the Federal WaterPollution Control Act and revised under section 105 of CERCLA.

Executive Order 12316 delegates to the U.S. Environmental ProtectionAgency (EPA) the authority and responsibility for management of theSuper fund and implementation of the site response program. In accordancewith section 105 of CERCLA, EPA has established procedures for reportingreleases, evaluating remedies, determining the appropriate extent ofresponse, and assuring that remedies are cost-effective; and has incorpo-rated these procedures in the NCP (47 FR 31180, July 16, 1982; 40 CFR 300)as Sub part F (40 CFR 300.61-300.71). Additional amendments were proposed onFebruary 12, 1985, and are anticipated to be published after the publicationof this document. Many of the proposed changes in the revised NCP thatrelate to conducting an RI/FS have been incorporated into this guidancedocument .

Sub part F of the NCP sets forth the process by which remedial actionswill be evaluated and selected, shown in Figure 1-1, and the factors to beconsidered in this process under the requirements of section 105. Responseto and action to minimize damage from hazardous substances releases must, tothe greatest extent practicable, be in accordance with the NCP.

The purpose of this guidance document is to provide a more detailedanalytical structure to the framework for identifying, evaluating, andselecting remedial action alternatives put forth in the NCP. This guidanceshould be used by Federal and State Remedial Project Managers and theircontractors, who are responsible for developing and preparing supportingdocumentation for remedial actions performed under CERCLA. Additionally,this guidance should be used by Federal, State, and private hazardous wastemanagement officials developing remedial actions at sites where enforcementactions are taken, or for which claims against the Fund are to be presented.

1-1

Figure 1-1. Currant NCP Proo«M

It is important to note that, while this document provides analyticalguidance to the user, it does not provide guidance on the overall managementof the remedial process, nor does it provide specific guidance on the bestanalytical techniques to use on a site-by-site basis. Management guidanceis provided in separate EPA/State participation, enforcement, and contractmanagement guidance documents. Technical guidance documents that may beuseful in conducting specific analyses are available or forthcoming. Thesedocuments are discussed further at the end of this chapter.

1.1 THE NATIONAL CONTINGENCY PLAN FRAMEWORK FOR THE REMEDIAL RESPONSEPROCESS

The NCP sets forth a five step remedial response process:

1. Site discovery or notification: A release of hazardous substances,pollutants, or contaminants identified by Federal, State, localgovernment agencies, or private parties is reported to the NationalResponse Center (NRC) . Upon discovery, such potential sites arescreened to identify release situations warranting further remedialresponse consideration. These sites are entered into the Emergencyand Remedial Response Inventory System (ERRIS); this computerizedsystem serves as a data base of site information and tracks thechange in status of a site through the remedial response process.

2. Preliminary assessment and site inspection (PA/SI): Thepreliminary assessment involves the collection and review of allavailable information and may include off-site reconnaissance toevaluate the source and nature of hazardous substances present andto identify the responsible party(s). Depending on the results ofthe PA, a site may be referred for further action. Siteinspections routinely include the collection of samples and areconducted to determine the extent of the problem and to obtaininformation needed to determine whether a removal action is neededat the site or whether the site should be included on the NationalPriorities List (NPL) .

3. Establishing priorities for remedial action: Sites are scoredusing the Hazard Ranking System (HRS) and the data from the PA/SI.This scoring process is the primary mechanism for identifying sitesto be included in the National Priorities List (NPL) , which in turnis the guide for allocating Superfund monies for cleanups. Sitesthat receive a score of 28.5 or greater will be proposed ascandidates for the NPL. After public comment, these sites may beincluded on the NPL.

4. Remedial investigation/ feasibility study (RI/FS): Site investi-gations are conducted to obtain information needed to identify,select, and evaluate remedial action alternatives in the feasi-bility study based on technological, public health, institutional,

1-3

cose, and environmental factors. The final result of this step isselection of the most appropriate, cost-effective solution. In

cases, the 81 may show that no further action is needed.

5. Remedial action design and construction: The actual design of theselected remedial action is developed then implemented throughconstruction.

Under step 4 above, the PCP requires that the need for appropriateresponse actions must be identified in the project scoping stage, prior toplanning the RI, in order to establish a basis for RI and FS funding. Theinformation from the preliminary assessment, site inspection, or othersources is used to determine the general types of response actionsapplicable to the site for use in planning the RI. The 1C? also requiresthat a detailed remedial investigation and feasibility study be conductedfor the sites that are listed on the National Priorities List (section 105of CESCLA) and tar get ted for remedial response under section 104 of CERCLA.in order to obtain the data necessary to define the problem and evaluate andselect alternative remedial measures. The remedial investigation (RI—forwhich separate guidance has been developed) provides site characterizationdata that serve as the basis for development of the feasibility study (FS).In the FS, alternative remedial actions are developed and evaluated in termsof cost, engineering implementation and constructability, the extent towhich each alternative provides protection to public health and the environ-ment, and environmental, impacts during or remaining after implementation.Remedies that are developed and implemented by private parties under CERCLAmust also be consistent with the 1C?.

The feasibility study and remedial investigation are interdependent.The activities comprising these two projects are generally performed con-currently rather than sequentially. The remedial investigation emphasizesdata collection and site characterization while the feasibility study em-phasizes data analysis and evaluation of alternatives. Because of thecomplex nature of many sites, however, new site characterization informationmay be developed as the RI progresses that requires reassessment of thegeneral types of response actions identified, with the possible addition ofother types of responses. In turn, this aay require expanding the remedialinvestigation to develop the data necessary to evaluate the newalternatives.

Figure 1-2 presents a flow chart of the RI/FS process, illustrating theinterdependence and concurrence of tasks performed in the remedial investi-gation and feasibility study. The numbers identifying the tasks (boxes) inthe flow chart are keyed to the tasks in the model contract statements ofwork for remedial investigations and feasibility studies, and are tabulatedunder the flow charts. (EPA's model statement of work for feasibilitystudies is provided in Appendix A of this document.) Chapters of thisdocument and its companion document, the "Remedial Investigation GuidanceDocument," which provides guidance for performing the respective tasks areidentified in this figure by task. Additionally, the figure showsmilestones and identifies specific reports which aay be required.

1-4

Figure 1-2. RI/FS Process

REMEDIAL INVESTIGATION

FFEASIBILITYSTUDY

1

Sue MapInterim Report

] rL

•

i (

Ti i . : . - . i r~n1 1 ! ! 1 L_l 1

Q El Q H QRemedial Options * •Neuoiiations Document SQlM ** B«ncn ** Final Rl Report *

Pent Scak) ftsu ^^ IOA/OC PirnHealth and Salnly Plan

Site Background ManauwnaiM Plan i 1Mature ol Problem Samuliny PlanE.rent ol Problem Communu, RcUnori. Plan D"" FS <* "'"History ol Response o«u MtuauemMU Plan

_ O Q

1 'Kdmewtralrve Reports>ocuinenl Control

Ftfiat Report

S Report

( ,

Assessment'Post Closure PlanCompliance Moniloreiu Schedura

Document Control

"••"— •— •— Fees**,,, Study

Model Sutemenl ot V*xkIn• Remedul Investigations

Ta»k « 1 Description ol Current Situation

Task t2 Plans 6 Management

Task »3 Sue Investigation

Guidance Document lot Model Statement ol MtorkRwnudial Investitfaliona Undw CEHCLA lor FeaseXity Studies

CH 1 Introduction

CH 2 Scoping Task » 8 Descrution ol Proposed Response

CH 3 Sampling Plan Development fas. #• P, »nary Remedial leclwitogies

CH4 Da.aMan ,nH.lP»c..ua. Usk *» D«Uopm«,l ol AjMtnal.,.

CM * E^£!££^ *" T"* * " """ SC"""n9 " *""""-"

CH 6 InsMiuiional issuesTask »4 SIM Invesugatun Analysis

Task *5 Lab

CH 7 Site ChaacMfuauonlank #12 {valuaiian ol Alternatives

oratory b Bunch Scale StudiosCH • Peut and Bench Studies

Task »6 Reports

Task #7 Community Relations Support

t Nu*i4M)

CH » HumedMl Investigation Report Formal jist f |j p,elmtnu* Report

Task #M Fatal Report

Guidance Document lorFeasnikiy Studies Under CEBCLA

CH 1 E«ecuiive Summary

CH 2 Develop a Range ol RemedialAllw natives

CH 3 - Conduct a Delated ladmical/ Evaluation

CH 4 Evaluate Institutional Reduiremtmis

CH 6 Evatiau Protection ol Pubkc HealthRequirements

CH 6 Evaluate Environmental Impacts

CH 7 Cost Analysis

CH B Summarue Alternatives

CH • Feasibility Study Report Format

• in MM bum iL-bi in Ink! duiil»al •> U« Uu>U bUKuwm ul Wuk lo< HI fS uiun CtRCLA UudaiiM auiul F«4«uj.v ntti So. Auuoiik* A

41 Mly UMIH HI VW HI f S |Wut:M» Ml huU|WI 111 •tawcWHHnl

1.2 AH OTOLVTEV OF THE FEASIBILITY STUDY PROCESS

The feasibility study process is outlined in Figure 1-3. The firststep of the feasibility study, defining the objectives of the action andbroadly developing response actions, should be performed as a refinement toproject scoping during the remedial investigation and should be summarizedin the final remedial investigation report. There may be modification ofthis scoping as data are collected or as the general response actions aremore fully developed during the feasibility study stage. The remedialalternatives developed at this point are general response actions whichbroadly define the nature of the response. In general, they should addresswhether source control measures (measures designed to prevent or minimizemigration of hazardous substances from the source) and/or management ofmigration measures (measures designed to mitigate the impact of contamina-tion that has migrated into the environment) are necessary, and what phasingof these measures (operable units) may be necessary. The terms "sourcecontrol" and "management of migration" refer to two general categories ofresponse actions that are useful for developing specific alternatives. Theterm "on-site response actions" in the policy on CERCLA compliance withother environmental laws refers to both source control and management ofmigration measures. These requirements are discussed throughout this

The next step in the process is the development of specific alterna-tives within the general response categories. First, technologies withinthe categories are screened for their technical applicability to the site.Technologies considered technically appropriate are then combined to formoperable units that address one or more aspects of the identified siteproblems. These operable units may then be combined to form alternativesaddressing the complete site. The alternatives are then screened on thebasis of public health, environmental, and cost concerns. Development andscreening of alternatives is discussed in detail in chapter 2.

The next five activities comprise the detailed analysis of alterna-tives, which is necessary to provide the decisionmaker with information forselecting the alternative that is cost-effective. The remaining chapters ofthis guidance document provide a framework for developing the necessaryanalysis for making this selection. Each chapter discusses a major aspectof the feasibility study process. Chapter 3 covers the engineering analysis

Management of migration measures have previously been known as "off-site"measures, as defined in section 300.68(e)(3) of the HCP. This term hasbeen changed to avoid confusion between measures involving the minimizationor mitigation of migration of wastes or contaminants which have moved awayfrom the source, and off-site disposal of wastes following removal from asite. Management of migration measures are measures taken to mitigate orminimize the further migration of contaminants which have already movedfrom the source. Off-site treatment or disposal of wastes followingremoval, referred to as off-site treatment or disposal, is generally asource control measure.

1-6

Figure 1-3. Feasibility Study Process

Ch. 3

Ch. 5•XO.«MMi3lliil2)IOi

nocui»»m. • Her uoo.ow

' OL 2. KT uoa.««t

Ch. i NCP *300.«hHU.O).l3J

Ch. 7NCP

0, r

Ch. t>xo.whMiiiiiiii(e<

en I

en *•

NOW: NCP MCtlOn* idinilflM r«<fr to tfiQM

• Not iMcifod SKtnxv of tnt NCP

citM in tut f*m mgnnr. July It. '9C-

1-7

of che alternatives in cents of construetability and reliability co ensurethe implementabilicy of alternatives. Chapter 4 covers the institutionalanalysis of alternatives in tens of che Federal, State, or local standards,advisories, or guidance that muse be attained or considered co protect chepublic health, welfare, and environment. Chapter 5 covers public healthexposure evaluation, and chapter 6 covers the environmental analysis ofalternatives. The evaluation of the costs of alternatives is discussed inchapter 7. Chapter 8 provides guidance on how to organize and summarize cheinformation developed in analyses described in previous chapters. Theobjective of this summary is to ensure that important information ispresented in a concise format so that che decisionmaker can choose cheremedy that provides che best balance of health and environmentalprotection, and engineering reliability with cost.

Chapter 9 discusses the format of che report for che feasibility study.It identifies the elements of che feasibility study report, che rationalefor their inclusion, Che level of detail, and the documentation necessary coaccompany che report.

1.3 REMEDIAL ALTERNATIVES MOST ADDRESS THE REQUIREMENTS OF OTHEREWTROMEVTAL LAWS

EPA's current policy, regarding compliance of CERCLA response actionswith the requirements of other environmental laws, is co give primary con-sideration to che selection of chose response ace ions that are effective inpreventing or, where prevention is not practicable, minimizing che releaseof hazardous substances so chat they do not migrate co cause substantialdanger to present or future public health, welfare, or che environment. Asa general rule, this can be accomplished by pursuing remedies chac meet thestandards of applicable or relevant Federal public health or environmentallaws. However, because of che unique circumstances ac particular sices,there may be alternatives that do not meet che standards of other laws, butwhich still provide protection of public health, welfare, and the environ-ment. For example, ac certain sices, ic may be technically impractical,environmentally unacceptable, or excessively costly to implement a responseaction that fully attains che requirements of the laws.

This policy effectively examines response actions which preventhazardous substances from migrating into che environment and actions whichminimize migration, recognizing chat CERCLA primarily addresses inadequatepast disposal practices and resultant unique sice conditions.

On—site source control or management of migration measures will notrequire environmental permits; however, off-site waste treatment, storage,or disposal must be at a facility permitted under the appropriateenvironmental law. However, this requirement does not prohibit a State orlocal authority from fulfilling their respective permitting requirements.The application of this policy in developing and selecting remedies ac

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Superfund sites is discussed in subsequent chapters. EPA has also includedrequirements of this policy in the proposed revisions to the NCP.

1.4 THE PROCESS APPLIES TO ENFORCEMENT ACTIONS

Enforcement actions must follow the same analytical steps for develop-ing, and evaluating remedial actions as Federal- and State-lead, Fund-financedactions. Additionally, to support enforcement case preparation, regional andState project managers and their contractors may be required to prepare endan-germent assessments and remedial options negotiations documents. Basically,these documents characterize the threat to public health and the environmentposed by the site and the alternatives for mitigating that threat.

Chapter 10 (forthcoming) discusses in greater detail enforcementactions and necessary support documentation. The chapter identifies theprocedures governing potential responsible party (PRP) participation in thedevelopment of the RI/FS. The chapter highlights stages of PRP participa-tion in an RI/FS that are unique from an enforcement perspective. Thechapter also addresses the differences between PRP and Fund-financed RI/FS.

1.5 SUPPLEMENTAL GUIDANCE DOCUMENTS UNDER DEVELOPMENT

The user should be aware of additional policy, management, andtechnical guidance that may affect the conduct of the FS. Some of the mostimportant of these include:

• "Procedures for Planning and Implementing Off-Site Response Actions"

• "Agency Policy on CERCLA Compliance with other Environmental Laws"

• "Guidance for Remedial Investigations under CERCLA"

• "Methodology for Screening and Evaluation of Remedial Responses"

• Surface Cleanup Guidance for Drums, Tanks, and Lagoons

• Guidance for Alternative Water Supply

e "Remedial Action Costing Procedures Manual"

• "Compendium of Costs for Remedial Technologies"

• "Superfund Public Health Procedures"

• "Health Effects Assessment Documents"

• "Superfund Exposure Assessment Manual"

• "Endangerment Assessment Guidance"

• "User's Guide to the Contract Laboratory Program"

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• "Scare Participation in the Superfund Reaedial Progn

Belationa in Superfund: A Handbook."

Vbile mtaj of che*e doct»ents are available, several are currently in prcparation and will be forthcoming.

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CHAPTER 2

DEVELOP A RANGE OF REMEDIAL ALTERNATIVES

The National Oil and Hazardous Substances Contingency Plan (NCP) out-lines a process for Identifying, developing, and evaluating remedial actionalternatives for a given site. The process begins with project scoping,discussed in chapter 2 of the EPA's "Remedial Investigation GuidanceDocument." As part of project scoping, general response actions to remedyknown problems at the site are identified (based upon existing data) as abasis for planning the Remedial Investigation and Feasibility Study.Remedial response actions fall into three general categories: initialremedial measures , source control, and management of migration. NCPproject scoping requirements are specified in NCP Section 300.68(d) , whichstates in part:

(d) The lead agency, in cooperation with the State(s), will examineavailable information and determine. . .the type or types ofremedial response that may be needed to remedy the release. Thisscoping will serve as the basis for requesting funding for aremedial investigation and feasibility study....

With additional site-specific data from the remedial investigation, remedialalternatives within the general response categories are developed and evalu-ated. As a result of the investigation, it may be determined that addi-tional general response actions are needed.

The development and evaluation of remedial alternatives then proceedsin three phases. First, a limited number of alternatives are developed.Second, an initial screening of these alternatives reduces them to a work-able number. Third, a limited number of remedial alternatives, based onthose that have passed the initial screening, are analyzed in detail*Section 300.68(g), (h), and (1) of the NCP outlines this process:

(g) Development of Alternatives. A limited number of alternativesshould be developed for either source control or fmanagement of

TThe proposed revisions to the NCP eliminate initial remedial measures as aremedial response category. Response actions conducted previously asinitial remedial measures will, in the future, be considered removalactions, source control measures, or management of migration measures.

federal Register, Vol. 47, No. 137, July 16, 1982.

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•igraeion] (or both) depending upon the type of response chat hasbeen identified...aa being appropriate.

(h) Initial Screening of Alternatives. The alternatives developed...will be subjected to an initial screening to narrow the list ofpotential medial actions for further detailed analysis.

(i) Detailed Analysis of Alternatives- (1) A more detailed evaluation•111 be conducted of the Halted number of alternatives thatremain after the initial screening....

This chapter is a guide to the first two phases of this process. Chapters 3through 7 of this document provide guidance on the third phase, the detailedanalysis of alternatives.

2.1 OVERALL APPROACH

The recommended alternative development and screening procedure (Figure2-1) consists of six steps.

Identify General Response Actions

1. Identify site oroblems and pathways of contamination (remedialInvestigation) .

2. Identify general response actions that address site problems andmeet cleanup goals and objectives.

Identify and Screen Technologies and Develop Remedial Alternatives

3. Identify possible technologies in each general response action,then screen the technologies to eliminate inapplicable andinfeasible technologies based on site conditions.

4. Assemble technologies into operable units based on the remainingfeasible technologies.

Screen Public Health, Environmental, and Cost Factors

5. Screen alternatives, eliminating those that have significant ad-verse impacts or that obviously do not adequately protect theenvironment, public health, and public welfare.

Detailed guidance for identifying pathways is forthcoming in the PublicHealth Procedures Manual.

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Figure 2-1. Feasibility Study Alternative Development and Screening Process

IdentifySite

Problems(Remedial

Investigation)_!

IdentifyGeneral

ResponseActions

Identify and

Technologies

AssembleAlternatives

N>t

ConductEnvironmental

and PublicHealth

Screening

ConductCost

Screening

Alternativesu for

DetailedAnalysis

6. Scrttcn alternatives, eliminating those that are an order of magni-code higher in cost than other alternatives but do not providesignificantly greater environmental or public health benefits ortechnical reliability.

Developing and screening remedial alternatives is actually a repetitiveprocess that may take place at several points in the RI/FS process- Theprocess say begin during the remedial investigation to define the field datarequirements of specific remedial action alternatives- As more site dataare collected, existing alternatives may be re screened, or additional alter-natives developed to reflect improved understanding of the site. Screeningmay also occur during the detailed analysis of alternatives if it is decidedthat an alternative should not be considered further, based upon thescreening criteria discussed in steps 5 and 6 (the reasons for such adecision must be clearly documented).

Each study should, at a minimum, include each of the six elements,although some studies may require modifications of this process to meet siteconditions. Each feasibility study should concisely summarize the resultsof each step, as explained in chapter 9. In some circumstances, especiallyIf the site Is undergoing remediation pursuant to enforcement actions, aninterim report identifying the remaining remedial alternatives may be pre-pared- This report is known as a Remedial Options Negotiation Document andsupports Agency negotiations with responsible parties by identifying appro-priate remedial technologies and alternatives for site cleanup, consideringany previous site work and any in progress. Normally, regional enforcementpersonnel decide whether such a document is required.

The alternative development and screening steps described in thefollowing sections of this chapter are presented rather formally, but theprocess is generally a more Informal matter of using established engineeringpractices. The formal process, summarized below, need not be followedrigidly, but it should be used as a framework for documenting the initialscreening decisions.

2-2 IDENTIFY GENERAL RESPONSE ACTIONS

The development of remedial alternatives (steps 1 through 4 above), isdescribed in detail in the following sections.

2.2.1 Identify Site Problems

The user should identify alternatives that address all significant siteproblems and pathways of contamination identified during the remedialInvestigation. Site problems can generally be placed in one or more of thefollowing categories: (1) air pollution; (2) surface water infiltration orcontamination; (3) leachate generation and contaminated ground water; (4)gas migration; (5) presence of wastes in drums, lagoons, etc.; (6)

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contaminated sediments and soils; and (7) contaminated water supply andsewer lines.

The information needed to identify the site problem is usually gatheredduring the preliminary assessment and the site Inspection and summarized inthe initial scoping of the remedial investigation. The EPA manual"Methodology for Screening and Evaluation of Remedial Responses" presentssample site problems, with their associated classes of remedial responses,as part of a recommended approach to technology selection and screening.

2.2.2 Identify General Response Actions

Based on site information from the remedial investigation, the usershould identify general response actions, or classes of response withoutnecessarily identifying specific technologies. General response actionsconsidered should include the "no action" alternative as a baseline againstwhich other measures can be measured. Examples of general response actionsinclude the following:

• No action

• Containment

• Pumping

- On-site

- Off-site

• Collection

• Diversion

• Complete removal

• Partial removal

• On-site treatment

• In situ treatment

• Storage

• On-site disposal

• Off-site disposal

• Alternative drinking water supply

• Relocation of receptors

• Other off-site measures.

In preparation.

The "no action" alternative does not preclude removal action under theCERCLA removal program.

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2.3 IMUfTLFT AND SCREEN TECHNOLOGIES

The user should identify feasible technologies for each general res-ponse action identified, recognizing chat there may be compatible and Incpatlble combinations of source control and management of migration measures.Table 2-1 is a partial list of technologies appropriate to the generalresponse actions described above. Some technologies should be modified oreliminated, such as those that say prove extremely difficult to implement,may not achieve the remedial objective in a reasonable time, or may rely onunproven technology.

Table 2-2 is a comprehensive list of remedial technologies classifiedaccording to the kinds of sice problems they are Intended to mitigate. Fortechnologies that can be used in various configurations, several "functionoptions' are also given. Similarly, where different materials may be usedin the same technology, "materials options" are provided. The user shouldrefer to the EPA "Handbook for Remedial Action at Haste Disposal Sites"(June 1982) for a more comprehensive description of these technologies.During technology screening, the use of this list will help ensure that allremedial technologies are considered. The list should be updated periodi-cally to incorporate newly developed technologies.

The user should review site data to identify conditions that may limitor promote the use of certain remedial technologies. Such Information isgenerally gathered during the site investigation or remedial investigation.Table 2-3 Identifies site characteristics chat should be evaluated as partof the screening process. Technologies whose use is clearly precluded bysite characteristics should be eliminated from consideration.

The user should also identify waste characteristics that limit theeffectiveness or feasibility of the remedial technologies. Such character-istics include: (1) physical properties such as volatility, solubility, anddensity; (2) specific chemical constituents such as chlorinated organicchemicals or metals; and (3) properties that determine the waste's toxlcityor degree of hazard, such as persistence, acute coxicity, and ignltablllty.Table 2-* presents waste characteristics chat may influence the feasibilityand effectiveness of remedial actions- Technologies clearly limited bywaste characteristics should be eliminated from consideration.

The user should also identify the level of technology development,performance record, and inherent construction, operation, and maintenanceproblem* of each technology considered. Technologies that are unreliable,perform poorly, or are not fully demonstraced should be eliminated. Limita-tions of various remedial technologies are discussed in the EPA "Handbookfor Remedial Action at Waste Disposal Sites" (June 1982) and other documentslisted in the bibliography.

The user may wish to use a previously developed methodology thatpresents feasible remedial technologies and their limiting waste, site, andtechnology characteristics. The EPA aanual "Methodology for Screening and

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TABLE 2-1. GENERAL RESPONSE ACTIONS AND ASSOCIATEDREMEDIAL TECHNOLOGIES

General ResponseAction Technologies

No Action

Containment

Pumping

Collection

Diversion

Complete Removal

Partial Removal

On-site Treatment

Off-site Treatment

In Situ Treatment

Storage

On-site Disposal

Off-site Disposal

Alternative WaterSupply

Relocation

Some monitoring and analyses may be performed.

Capping; ground water containment barrier walls;bulkheads; gas barriers.

Ground water pumping; liquid removal; dredging.

Sedimentation basins; French drains; gas vents; gascollection systems.

Grading; dikes and berma; stream diversion ditches;trenches; terraces and benches; chutes and downpipes;levees; seepage basins.

Tanks; drums; soils; sediments; liquid wastes;contaminated structures; sewers and water pipes.

Tanks; drums; soils; sediments; liquid wastes.

Incineration; solidification; land treatment;biological, chemical, and physical treatment.

Incineration; biological, chemical, and physicaltreatment.

Permeable treatment beds; bioreclamation; soilflushing; neutralization; land farming.

Temporary storage structures.

Landfills; land application.

Landfills; surface impoundments; land application.

Cisterns; aboveground tanks; deeper orupgradient wells; municipal water system; relocationof intake structure; Individual treatment devices.

Relocate residents temporarily or permanently.

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TABLE 2-2. 1EMEDIAL TECHKOLOGIES

A. Air Pollution Controls

• Capping

- Synthetic membranes- Clay- Asphalt- Multimedia cap- Concrete- Chemical sealants/stabilizers

• Dost Control Measures

- Polymers- Hater

B. Surface Hater Control*

• Capping (see A.)

• Grading

- Scarification- Tracking— Contour furrowing

• tevegetation

- Graaaea- Legumes- Shruba- Treea, conifers- Trees,' hardwoods

• Diversion and Collection Systems

- Dikes and bei- Ditches and trenches- Terraces and benches- Chutes and dovnpipes- Seepage basins- Sedimentation basins and ponds

(continued)

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TABLE 2-2. (continued)

- Levees- Addition of freeboard- Floodwalls

C. Leachate and Ground Water Controls

• Capping (see A.)

• Containment barriers

Function options

- Downgradient placement- Upgradient placement- Circumferential placement

Material and construction options (vertical barriers)

- Soil-bentonlte slurry wall- Cement-bentonite slurry wall- Vibrating beam- Grout curtains- Steel sheet piling

Horizontal barriers (bottom sealing)

- Block displacement- Grout injection

• Ground water pumping (generally used with capping and treatment)

Function options

- Extraction and injection- Extraction alone- Injection alone

Equipment and Material Options

- Well points- Deep wells

(continued)

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- Suction veils- Ejector wells

• Subsurface Collection Drains

- French drains- Tile drains- Pipe drains (dual media drains)

D. Gas Migration Controls (generally vised with treatment)

• Capping (gas barriers) (see A.)

e Gas collection and/or recovery

- Passive pipe vents- Passive trench vents- Active gas collection systems

E. E«cs.vation and Removal of Haste and Soil

e Excavation and resjoval

- Backhoe— Cranes and attachments- Front end loaders- Scrapers

- Industrial vacuums- Drum grapplers- Forklifts and attachments

e Grading (see B.)

e Capping (see A.)

e Revegetation (see B.)

F. iemoval and Containment of Contaminated Sediments

• Sediment removal(continued)

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Mechanical dredging

- Clamshell- Dragline- Backhoe

Hydraulic dredging

- Plain suction- Cutterhead- Dustpan

Pneumatic dredging

- Airlift- Pneuma- Oozer

• Sediment turbidity controls and containment

- Curtain barriers- Coffer dams- Pneumatic barriers- Capping

6. In Situ Treatment

HydrolysisOxidationReductionSoil aerationSolvent flushingNeutralizationPolymerizat ionSulfide precipitationBioreclamationPermeable treatment bedsChemical dechlorination

(continued)

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H. Direct Waste Treat

• Incineration

- lotary kiln- Fluidlzed bed- Multiple hearth- Liquid injection- Molten salt- High temperature fluid wall- Plasm* arc pyrolysis- Cement kiln- Pyrolvsis/starved combustion- net air oxidation- Industrial boiler or furnace

• Gaseous waste treatment

- Activated carbon- Flares- Afterburners

e Treatment of aqueous and liquid waste streams

Biological treatment

- Activated sludge- Trickling filters- Aerated lagoons- Baste stabilisation poods- lotating biological disks- Plnldized bed bloreactors

Chemical treatment

- Bentralixatlon- Precipitation- Oxidation- Hydrolysis- leductlon- Chemical dechlorlnatlon- Ultravlolet/osonation

(continued)

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Physical treatment

- Flow equalization- Flocculation- Sedimentation- Activated carbon- Kleensorb- Ion exchange- Reverse osmosis- Liquid-liquid extraction- Oil-water separator- Steam distillation- Air stripping- Steam stripping- Filtration- Dissolved air flotation

Discharge to a publicy owned treatment works

• Solids handling and treatment

Dewaterlng

- Screens, hydraulic classifiers, scalpers- Centrifuges- Gravity thickening- Flocculation, sedimentation- Belt filter presses- Filter presses- Drying or dewatering beds- Vacuum-assisted drying beds

Treatment

- Neutralization- Solvent- Oxidation- Reduction- Composting

• Solidification, stabilization, or fixation

- Cement-based(continued)

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- U»e-haaed- Thermoplastic- Organic polymer- Self-cementing techniques- Surface encapsulation- Classification- Solidification (i.e., to fly ash, polymers, sawdust)

I. Land Disposal Storage

LandfillsSurface impoundmentsLand applicationBaste pilesDeep veil injectionTemporary storage

Contaminated Hater Supplies and Sever Lines

e In situ cleaning

e Immoral and replacement

e Alternative drinking water supplies

- Cisterns or tanks- Deeper or upgradlent veils- Municipal water systems- telocation of intake

e Individual treatment units

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TABLE 2-3. SITE CHARACTERISTICS THAT MAYAFFECT REMEDIAL TECHNOLOGY SELECTION

Site volume Depth of bedrockSite area Depth to aquicludesSite configuration Degree of contaminationDisposal methods Direction and rate ofClimate (precipitation, ground water flowtemperature, evaporation) Receptors

Soil texture and permeability Drinking water wellsSoil moisture Surface watersSlope Ecological areasDrainage Existing land useVegetation Depths of ground water or plume

TABLE 2-4. WASTE CHARACTERISTICS THAT MAY AFFECTREMEDIAL TECHNOLOGY SELECTION

Quantity/concentration InfectlousnessChemical composition SolubilityAcute toxlcity VolatilityPersistence DensityBlodegradabillty Partition coefficientRadioactivity Compatibility with other chemicalsIgnitabillty TreatabilityReactivity/corroslvity

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Evaluation of Remedial Responses" presents one such approach, withscreening tables showing site, waste, and technology Imitations forremedial alternatives under each general class. The manual also has achecklist for tracking technologies not excluded by the limitations given inthe tables. This and similar methodologies, however, should serve only asguides for screening. They cannot substitute for acceptable engineeringpractice in screening technologies.

The user should give special consideration to technologies that perman-ently contain, immobilize, destroy, or recycle contaminants, and technolo-gies that promote energy recovery. Also, certain technologies often areused in combination, and the user should have a working knowledge of thosetechnologies. EPA is currently drafting guidance for the consideration ofthese technologies.

2.4 DEVELOP ALTEUATIVES BT COMBOTIHG TECHNOLOGIES

Technologies that have passed the technology screening can be used toform more definite alternatives.

In developing remedial alternatives, the user should rely on acceptableengineering practice to determine which of the screened technologies appearmost suitable for the site. Consideration should be given to recycle,reuse, waste minimization, destruction, or other advanced, innovative, oralternative technologies, if appropriate. The user should document thereasons for excluding technologies that passed the technology screening.The user should also consider relevant and applicable standards listed inTable 5-2 in selecting and combining technologies into alternatives toachieve specific cleanup goals.

As part of the feasibility study (FS), at least one alternative foreach of the following must, at a minimum, be evaluated within the require-ments of the feasibility study guidance and presented to the decisionmaker(the FS report should discuss those situations where no feasible alternativecan be identified for a given category):

(a) Alternatives for treatment or disposal at an off-site facilityapproved by EPA (including SCBA, TSCA? CM A, CAA, MPRSA, and SWAapproved facilities), as appropriate;

In preparation.

These alternatives must be consistent with EPA Policy "Procedures forPlanning and Implementing Off-Site Response Actions" (see Appendix B). Iniosn cases, off-site disposal or treatment may not be feasible and thisalternative may be eliminated during initial screening of alternatives.The decision documents should reflect this screening.

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(b) Alternatives which attain applicable and relevant Federal publichealth or environmental standards;

(c) As appropriate, alternatives which exceed applicable and relevantpublic health or environmental standards;

(d) Alternatives which do not attain applicable or relevant publichealth or environmental standards but will reduce the likelihoodof present or future threat from the hazardous substances* Thismust include an alternative which closely approaches the level ofprotection provided by the applicable or relevant standards andmeets CERCLA's objective of adequately protecting public health,welfare, and environment*

(e) A no action alternative.

Since ground water contamination is the most frequent type of problemat NPL sites, the corrective action requirements of Subpart F of the RCRAregulations (40 CFR Part 264) will be applicable or relevant in many casesand should be included in alternatives developed under category (b). Underthe RCRA regulations, corrective actions must attain a ground water cleanupstandard established for each facility. For a limited number ofpotential contaminants, a standard is specified in the regulations at levelscorresponding to National Interim Primary Drinking Water Standards developedpursuant to the Safe Drinking Water Act. An alternate concentration limit(ACL) may be established for any contaminant upon a determination that theACL will "not pose a substantial present or potential hazard to human healthor the environment as long as the alternate concentration limit is notexceeded" [40 CFR 264.94(b)]. In the absence of an ACL or a standard basedon Safe Drinking Water Act determinations, the ground water protection stan-dard is background. The RI/FS should examine whether an ACL is appropriateat each site where the Subpart F regulations are applicable or relevant.

Generally, ACLs can be based on a demonstration that there is a lack ofexposure or that levels of exposure are adequate to protect human health.In considering ACLs, it is appropriate to consider attenuation, degradation,and dilution of the contaminants before they reach possible receptors.Engineering approaches can be used to augment natural dilution andattenuation processes. Additionally, institutional controls to assure thatground water within the current or probable reach of the plume ofcontamination will not be withdrawn, or will be withdrawn only at points atwhich contaminants are at concentrations that are safe, may be considered asa basis for controlling exposure. In conjunction with the controlsdescribed above, there may be limited circumstances where treatment of thewater before use can be guaranteed as a means of preventing exposure toharmful levels. The decision criterion is in all cases, however, whether analternate concentration level will pose a substantial hazard to human healthor the environment. Alternatives that do not meet the RCRA Subpart Frequirements for background MCLs or ACLs but significantly reduce publichealth threats (for example engineering controls to attenuate or diluteconcentrations to acceptable levels at the receptor point) should bepresented in category (d).

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Since the RCRA ground-water protection program is relatively new,experience to dace in implementing alternate concentration limits islimited. Heeded additional guidance is being prepared for Regional use.This guidance will discuss factors and conditions that nay be used inevaluating alternate concentration limits.

In some cases, there may be some overlap between the alternativesdeveloped. A single alternative may fit more than one category, and severalalternatives may be developed for each category. Furthermore, alternativesmay be developed that, through changes in the design, fit more than one ofthe categories. For example, an alternative that attains applicable orrelevant Federal standards [category (b) ] may fall in category (c) throughrelatively minor design or operation modifications.

The development of alternatives is closely related to the institutionalreview process discussed in chapter 4. The user should refer to chapter 4for appropriate institutional requirements that must be considered whendeveloping remedial alternatives.

The alternatives developed must also be re-evaluated during the publichealth evaluation dicussed in chapter 5, specifically, after completion ofthe exposure assessment (section 5.3) and comparison of environmental con-centrations to applicable and relevant standards (section 5.4). Alterna-tives in categories (b) and (c) above may need to be modified if differentpathways or exposure concerns are identified.

The 8C? specifies that remedial alternatives, besides filling each ofthe categories, should be classified either as source control [40 CFR300.68(e)(2)] or off-site (management of migration) remedial actions [40 CFR300.68(e)(3)j. The distinction significantly affects the level of detailnecessary in evaluating remedies. Source control remedial action* addresssituations in which hazardous substances remain at or near the areas inwhich they were originally located and are not adequately contained toprevent migration into the environment. Off-site remedial actions addresssituations in which the hazardous substances have largely migrated fromtheir original locations. Off-site actions are now referred to as manage- >**'ment of migration actions, to distinguish actions involving •snugpment ofmigration from those involving hazardous substance removal and disposal inoff-site facilities. Alternatives developed may fall solely in eitherclassification or may involve a combination of source control and managementof migration measures, as determined by the specific site problemsaddressed.

2.4.1 Source Control Remedies

The purpose of source control remedies is to prevent or minimizemigration of hazardous substances from the source material. These remediesmay be applied to situations in which contaminants are in the soil, alagoon, or a pond. The extent and route of the release and/or the threat ofrelease must be documented to justify specific source control measures.

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Source control measures seek to completely remove, stabilize, and/or containChe hazardous substances. Source control measures may be used in manysituations where they will curtail further risk to humans or the environ-ment. In these cases, only a limited public health assessment may be neces-sary in selecting a cost-effective remedy.

Where preventing migration appears infeasible, measures that willreduce future migration from the source should be considered. In thesecases, a more extensive analysis will be necessary to select a cost-effective remedy that adequately protects public health. Chapters 5 and 6address the considerations involved in these analyses. In such situations,management of migration measures should be considered in conjunction withsource control measures.

Where a source control alternative involves off-site treatment [analternative in category (a) ] , destruction, or disposal of wastes followingremoval, section 300.70(c) of the NCP requires that EPA determine that thisalternative is either "(1) more cost-effective than other remedial actions;(2) will create new [waste management] capacity...; or (3) is necessary toprotect [human health and the environment]...." To aid in this evaluation,the user must, in those instances where an off-site transport, treatment,storage, or disposal alternative is among the list of response actions,include a comparable on-site alternative for evaluation. For example, whenoff-site disposal at a landfill approved under RCRA is among the alterna-tives to be evaluated, construction of such a landfill on the site should beevaluated as well.

2.4.2 Management of Migration Remedies

Management of migration remedial actions are necessary where hazardoussubstances have migrated from the original source o.f contamination and posea significant threat to public health, welfare, or the environment; forexample, where contamination exceeds relevant and applicable public healthor environmental standards, guidance, and advisories. Any management ofmigration measure that adequately protects public health, welfare, and theenvironment (by reducing contaminant levels) should be considered for imple-mentation. Particular consideration should be given to technologies thatpermanently contain, immobilize, destroy, or recycle contaminants.

An example of a site at which management of migration action may beappropriate would be one at which a contaminated ground water plume hasmoved downgradient from the site, beyond site boundaries, and is threateningprivate drinking water wells. At such a site, management of migrationmeasures such as aquifer pumping and treatment may be appropriate.

Management of migration alternatives may also involve measures thatprevent or minimize impacts through means such as substitution. An exampleof such an alternative would be provision of an alternative drinking watersource in cases where ground water contamination threatens private wells.

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2.5 SCREEH ALTERNATIVES FOR PUBLIC HEALTH, ENVIRO»ffiHTAL, AW) COST FACTORS

The next step involves screening of remedial alternatives based onenvironmental and public health criteria, followed by an "order ofmagnitude" cost screening. This two-step screening permits an initialassessment of the applicability of each alternative relative to the others.

This process eliminates alternatives that do not provide adequateprotection of public health, welfare, and the environment, and those thatare much more costly than others without providing significantly greaterprotection. When alternatives are eliminated from further consideration,the feasibility study must document the rationale for excluding each alter-native.

In some situations, screening may eliminate all alternatives in one ofthe five categories listed above under Section 2.4, "Develop Alternatives byCombining Technologies." When this occurs, at least one alternative for thecategory that was eliminated must be included in the summary of alternativespresentation described In chapter 8 and should be presented to the decision-maker with an explanation as to why it was eliminated at the screeningstage*

2.S.I Environmental and Public Health Screening

The user should identify adverse impacts on the environment or onpublic health and welfare that may preclude the use of each assembledalternative. Alternatives that may have significant adverse impacts or donot adequately protect the environment and public health should beeliminated. At this point, adequate protection should be thought of as acomprehensive response that addresses all pathways and points of exposure.The user should Identify alternatives that provide similar environmental andpublic health and welfare benefits in preparation for the cost screening.

2.S.2 Cost Screening Factors

The object of the cost screening is to eliminate alternatives that havecosts an order of magnitude greater than those of other alternatives but donot provide greater environmental or public health benefits or greaterreliability.

In preparing cost estimates for screening, certain limiting factorsshould be considered to control the level of effort expended in compilingthe estimates. These factors include accessibility of data sources, thetime available, and the degree of accuracy to be achieved. The following

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guidelines are recommended for use when defining the level of effort in costscreening:

• Data sources should be limited to the "Remedial Actions CostCompendium" (ELI, 1984), Handbook: Remedial Action at WasteDisposal Sites (U.S. EPA, 1982), the remedial investigation (forrevising design assumptions where necessary), standard costsindices, and other readily available Information.

• The time for preparing screening cost estimates should be limited toa few days.

• The objective in calculating the costs is to achieve an accuracywithin -50 to +100 percent.

Cost screening should be undertaken for all remedial alternativesremaining from the public health and environmental screening. The costscreening can be divided into three basic tasks: (1) estimation of costs,(2) present worth analysis, and (3) cost screening evaluation.

2.5.2.1 Estimation of Costs

Remedial alternatives are screened on the basis of both capital costsand operating and maintenance costs. These costs should reflect site-specific conditions and should be revised using the cost compendium (ELI,1984) or other standard cost guidance references.

Capital costs should include the following:

• Relocation costs

• Costs of land acquisition or obtaining permanent easements

• Land and site development costs

• Costs of buildings and services

• Equipment coats

• Replacement costs

• Disposal costs

• Engineering expenses

• Construction expenses

• State and local legal fees, licenses, and permit costs

• Contingency allowances

• Startup and shake-down costs

• Costs of anticipated health and safety requirements duringconstruction.

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Car* should be taken to ensure chat all applicable cose components areconsidered in che capital cose estimate.

Operation and maintenance costs should include, where applicable, thefollowing:

• Operating labor costs

• Maintenance materials and labor coses

• Costs of auxiliary materials and energy

• Purchased service costs

• Administrative costs

• Insurance, taxes, and licensing coses

• A maintenance reserve and contingency fund.

Care should be taken to ensure that all of these cost components are con-sidered. Vendor quotes are not generally available at this stage of theanalysis, because technical information and time are limited. Since site-and remedy-specific factors determine the degree to which each category ofcost is required at a given sice, it will be useful for the cost analyst todevelop a checklist of site- and remedy-specific cost considerations beforeattempting the cost estimate. Such cost considerations are suggested in the"Vemedial Actions Cost Compendia" (ELI, 1984). If necessary, costestimates should be updated to current values using standard cost indices.Procedures for updating cost estimates are discussed in chapter 7.

2.5.2.2 Present Worth Analysis

After developing screening cost data, che user must determine thepresent worth of both the capital and ocher expenditures. Discounting topresent worth is necessary when operation and maintenance costs areanticipated for one or more alternatives. Present worth (or present value)analysis enables the user to compare sets of coses by computing the currentvalue of all costs incurred, whether they are incurred in the present or atsome future date. The present worth analysis conducted during screeningrelies on less refined cost data but is otherwise identical to the presentworth analysis conducted during detailed cose esciaation. This analysisshould be based on the OMB-prescribed 10 percent discount rate. However, aquick calculation of alternative discount races may be desirable (e.g., 4 or7 percent) to observe sensitivity of overall estimates eo discount rates.This check is most useful' in cases that involve future replacement costs.The procedures for conducting a present worth analysis are discussed indetail in the EPA "Costing Procedures Manual."

gIn preparation.

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In some cases, wastes removed from a site, such as fuel oils or otherhydrocarbons, may be recoverable. In such cases, revenues from the sale ofremoved materials should be considered in the present worth analysis.

2.5.2.3 Cost Screening Evaluation

The user should compare present worth costs of competing alternativeswith similar environmental, public health, and public welfare benefits.Alternatives should be eliminated if they are deemed much more expensive (anorder of magnitude or more) and offer similar or smaller environmental andpublic health benefits but no greater reliability than competing alterna-tives. Alternatives that are more expensive but offer substantially greaterenvironmental and/or health benefits should not be eliminated.

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CHAPTER 3

CONDUCT A DETAILED TECHNICAL EVALUATION

One of the first concerns in Che detailed analysis of alternatives isthat suggested technologies are appropriate to site conditions. Section300.68(i) of the National Oil and Hazardous Substances Contingency Plan(NCP) requires the following:

(i) Detailed Analysis of Alternatives

(1) A aore detailed evaluation will be conducted of the limitednumber of alternatives that remain after the initialscreening....

(2) The detailed analysis of each alternative should include:

(A) Refinement and specification of alternatives in detail,with emphasis on the use of established technology....

(C) Evaluation in terms of engineering implementation, orconstructability....

(E) An analysis of...methods for mitigating [adverseenvironmental] impacts....

Each remedial alternative is evaluated for performance, reliability,implementability, and safety. EPA'a publication "Methodology for Screeningand Evaluation of Remedial Responses," the Army Corps of Engineers'Engineer Manual "Preliminary Guidelines for Selection and Design of RemedialSystems for Uncontrolled Hazardous Waste Sites" (EC 1110-2-244), and the EPA"Handbook for Remedial Action at Waste Disposal Sites" (1982) provide usefulinformation. The resulting estimates of alternatives' technical feasibilityare included in the sumnary of alternatives discussed in chapter 8. Theelements of technical feasibility are discussed, and a suggested format forsummarizing these evaluations is presented in the remainder of this chapter.


In preparation.

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3.1 PSRFOWABCE

Two aspects of remedial actions determine their desirability on thebasis of performance: effectiveness and useful life. Effectiveness refersto the degree to which an action will prevent or minimize substantial dangerto public health, welfare, or the environment. The useful life is thelength of time this level of effectiveness can be maintained.

3.1.1 Effectiveness

Remedial alternatives should be evaluated in terms of their ability toperform intended functions, such as containment, diversion, removal,destruction, or treatment. The effectiveness of alternatives should bedetermined either through design specifications or by performance evalu-ation. These two methods are discussed further below and in chapter S withrespect to evaluations of public health protection.

The user should establish which environmental and public health stand-ards are relevant or applicable at the site and evaluate proposed alterna-tives according to those standards. In evaluating alternatives, the usermay institute changes that improve them. Relevant and applicable standardsand guidelines for use in performing these evaluations are presented inchapter 5, the public health section, and chapter 6, the environmentalchapter. Response alternatives should use these standards developed byother EPA programs as design and/or performance specifications, or considerappropriate criteria and guidance. If such criteria are substantiallyadjusted (e.g., for risk level or exposure factors), the basis for theadjustment must be clearly stated (see chapters 4 and S).

Any special site or waate conditions that affect performance should beconsidered, and the design should be tailored to accommodate those condi-tions. The evaluation should also consider the effectiveness of combinationsof technologies. Specifications should be based on ASTM, AASHTO, or otherappropriate engineering standards, if applicable.

Standards, criteria, or guidance are not available for all situationsat hazardous waste sites; in these cases, performance specifications basedon acceptable engineering practice must be developed and used in evaluatingalternatives. The user should give preference to those technologies thatcompletely immobilize, destroy, or recycle the hazardous material, or pro-mote energy recovery.

The evaluation of on-site alternatives should include an analysis oflocations! factors that could impact effectiveness. These factors include:

• Ground-water considerations such as aquifer classification (seesection 4.3)

• Floodplain impacts

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• Seismic, landslide, subsidence, or volcanic impacts•

• Site geology (for example, ia the site underlain by fracturedbedrock or karst topography) .

These factors should be considered to determine if on- site alternatives canbe effective. Engineering modifications may be necessary to mitigateadverse locational impacts, if appropriate.

3.1.2 Useful Life

Most remedial technologies, with the possible exception of destruction,deteriorate with time. Often, deterioration can be slowed through properoperation and maintenance, but the technology eventually may require re-placement. Each alternative should be evaluated in terns of the projectedservice lives of its component technologies. Resource availability in thefuture life of the technology, as well as the appropriateness of the tech-nologies, must be considered in estimating the useful life of the project.

3.2 RELIABILITY

The cost of installing and operating remedial alternatives and theimportance of protecting public health and the environment make reliabilitya serious concern. Two aspects of remedial technologies that provide infor-mation about reliability are their operation and maintenance requirementsand their demonstrated reliability at similar sites.

3.2.1 Operation and Maintenance Requirements

Evaluations of the operation and maintenance requirements of remedialalternatives should emphasize the availability of labor and materials aswell as their costs. Also, the frequency and complexity of necessary opera-tion and maintenance should be considered in evaluating the reliability ofalternatives. Technologies requiring frequent or complex operation andmaintenance activities should be regarded as less reliable than technologiesrequiring little or straightforward operation and maintenance.

3.2.2 Demonstrated Performance

The technical analysis of remedial alternatives should not be based onthe presumed performance of untested methods. An estimate of the probabili-ty of failure, in either qualitative or quantitative terms, should be madefor each component technology and for Che complete alternative. The usershould give preference to technologies that have proven effective under

3-3

waste and sice conditions similar Co chose anticipated. However, innovativeor advanced technology should be evaluated as an alternative co conventionaltechnology, if appropriate. Sometimes beach-scale studies will be necessaryto determine actual performance characteristics; chese studies may be pareof the remedial investigation or the design phase.

As more experience is gained in applying and developing remedial tech-nologies, a broader range of activities will have demonstrated performance.AC present, many technologies are still in the research and developmentstages. If such developmental technologies are included in suggestedremedial alternatives, the user should be certain co include informationfrom researchers supporting ics use and evaluating ics expecced reliability.

3.3 OfPLOfECTABILirY

Another important aspect of remedial alternatives is their implemenc-abilicy—the relative ease of installation and che time required Co achievea given level of response. Ease of installation, often known as conscrucc-abilicy, is determined by conditions both internal and external to che site.The time requirements can be generally classified as che time required Coimplement a technology and the time required before resulcs are actuallyrealized.

3.3.1 Conscructabilitv

3.3.1.1 Sice Conditions

The construccability of remedial technologies under actual site condi-tions is fundamental to the technical analysis of alternatives. The abilityto actually build, construct, or implement the remedial cechnology on Chesice must be assessed.

3.3.1.2 Conditions External co che Sice

Condicions excernal co che sice chac affect the implemencabilicy ofremedial technologies include che availability and acceptability of off-sitedisposal sices and Che equipment available for construction.

Cercain remedial accivicies may require zoning clearances and localpermits in addition to compliance with applicable State and Federal regula-tions. Chapter 4 discusses some of chese statutes in more detail. Inaddicion, che public accepcabilicy of che alternative can be of fundamentalimportance in determining che implemencabilicy of the action.

3-4

3.3.2 Time

The time element of remedial efforts is an important aspect of siteremedial planning. Emphasis should be on quickly eliminating exposure tohazardous substances. Two measures of time that should be addressed are thetime it takes to implement a remedy and the time it takes to realize bene-ficial effects. The importance of timing depends on the nature of thehazard; speed is most important at sites presenting immediate, rather thanlong-term, hazards.

3.3.2.1 Time to Implement

Implementation time includes the time it takes for special studies,design, construction, and any other technical steps that may be required forimplementation. Implementation time estimates should take account ofweather conditions, unanticipated site conditions, and necessary safetyprecautions. The user should evaluate alternatives in terms of the mostlikely construction schedule, based on experience at -similar sites or ona standard engineering procedure like critical path analysis.

3.3.2.2 Time to Achieve Beneficial Results

Some remedial alternatives achieve instantaneous results (e.g., surfacecleanup or the provision of alternative water supplies). Often, though,considerable time is required from the beginning of construction until thedesired results are achieved. During this period, ancillary measures, suchas the temporary provision of alternative potable water supplies or tem-porary relocation, are conmonly taken to mitigate the threat. The usershould evaluate each alternative in terms of the time it takes to see bene-ficial results in the environment, exclusive of measures that provide tem-porary protection. Beneficial results should be defined as the reduction inlevels of contamination necessary to attain or exceed relevant or applicablestandards. RCRA standards for corrective action require meeting backgroundMCLs or ACLs within a reasonable period of time. While no specific lengthof time has been specified, the U.S. EPA Office of Solid Waste considersseveral years to be reasonable, depending on specific site conditions.Where no applicable or relevant standards are available, the user shouldconsult headquarters on a case-by-case basis for further guidance; finalguidance is under development for such situations.

3.4 SAFETY

Each remedial alternative should be evaluated with regard to safety.This evaluation should include short-term and long-term threats to thesafety of nearby communities and environments as well as those to workers

daring implementation. Major risks to consider are fire, explosion, andexposure to hazardous substance* resulting due to both on-site and off-siteactivities daring remedial action implementation.

The joint guidelines of the EPA, the Occupational Safety and HealthAdministration (OSHA), and the Hational Institute for Occupational Safetyand Health (HIOSH), or the Corps of Engineers guidance, prepared to ensurechc health and safety of workers at uncontrolled hazardous waste sices, maybe used to determine the risk to worker health and safety during implementa-tion. Alternatives should be designed to minimize risk during constructionand should be evaluated in terms of such safety.

3.5 STOMARY OP TKHHICAL PCASIBILITT AKALYSIS

Table 3-1 will help the user evaluate alternatives based onperformance, reliability, implementabilit?, and safety. The user shouldassess site conditions that affect conatructability and set design and/or•icing criteria for successful construction.

The user should explicitly evaluate the technical characteristics ofthe components of the alternative as well as those of the entire alterna-tive; measures that aggregate many factors cannot be used effectively indistinguishing between alternatives with similar general characteristics.

In Table 3-1, alternatives are listed in the left column. Each alter-native is described in terms of its component technologies, indicated forexample by "A-l", "A-2", and so on, of alternative "A." For example,alternative "A" may consist of site capping, diversion ditches, a slurryvail, groand-vater pumping, and treatment of the effluent. The user shoulddescribe the absolute degree to which each alternative or technology meetseach criterion. In addition, the user may also describe the alternativesand technologies in order of their relative desirability with respect toeach criterion. The user should provide a consistent description of anyoutstanding features that render the technology particularly desirable orany limitations chat may hinder its use for remedial action at the site.Vhere possible, quantitative descriptions should be provided so thatabsolute incremental differences in the alternatives can be discerned.

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TABLE 3-1. SUMMARY OF TECHNICAL FEASIBILITY EVALUATION

Remedial Alternative Criterion

Performance Reliability

RemedialAlternatives

Effectiveness Useful Life Operation andMaintenance Requirements

possibleFailure Modes

A-1

A-2

A-3

A-4

A-9

Remarks: Alternative A si

aB-l

B-2

B-J

Remarks! Alternative B

C

01

C-t

C-3

C-4

Renark*: Alternative C

(continued)

TABLE 3-1• (continued)

lit* CoMltlont CoMltloM{**•?••! to lit*

lo lo !•• D**lr*4 HMult*

A- I

A-l

A-S

A- 4

(JB

All*«n«flv« A »«

B-2

ft-J

H«Mrfcti Altwnaflv* •

C

C-l

C-J

C-J

C-4

(continued)

A

A-1

A-2

A-3

U, A-4I« A-J

HwMWkt: Alternative A

B

B-t

B-2

B-J

RMwrMi Alternative B s

C

C-l

C-2

C-J

C-4

c: Alternative C


SafetyConsiderations

Worker Health end Safety Neighboring Facilitiesi CoMwnltUs

CHAPTER 4

EVALUATE INSTITUTIOHAL REQUIREMENTS

This chapter describes current EPA policy on the use of applicable andrelevant standards and other criteria, guidance, and advisories at Superfundremedial sites. The user should be aware that this policy is subject tochange and further interpretation with regard to specific standards, andshould consult supplemental policy and program guidance documents that willbe issued as this policy is developed. If any questions about specificapplications of this policy arise, the user should consult EPA headquarters.

This chapter also discusses other institutional issues in analyzingremedial alternatives, such as coordination with other Federal agencies andcommunity relations.

4.1 OVERVIEW OP INSTITUTIONAL REQUIREMENTS

It is EPA policy that, in selecting remedial actions, primary consider-ation be given to remedies that attain applicable or relevant Federal envi-ronmental and public health standards. State and local standards should beconsidered; however, State standards that are more stringent than Federalstandards may form the basis for a remedy only if the result is consistentwith the cost-effective remedy based on Federal standards. (The State willgenerally be required to pay for the additional cost where more restrictiveState standards are used.) EPA does not require that environmental permitsbe obtained for Fund-financed or enforcement actions taken at a sitepursuant to sections 104 or 106 of CERCLA. However, States and privateparties are not precluded from obtaining permits. In contrast, all off-siteremoval, treatment, storage, or disposal actions must be in compliance withother environmental laws, including permit requirements.

The user should evaluate the effects of Federal, State, and localstandards and other institutional considerations on the design, operation,and timing of each alternative. In general, it is expected that regulatoryprograms under the Resource Conservation and Recovery Act (RCRA), the Safe

This chapter reflects a policy on the applicability of other environmentalprograms to actions under CERCLA. This policy is subject to the finalrulemaking of the proposed amendments to the NCP, and this chapter istherefore presented as interim guidance.

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Drinking Water Act (SDWA), and the Federal Water Pollution Control Act(Clean Water Act or CHA) , will have the broadest applications to remedialaction alternative*.

Results of the institutional analysis af each remedial alternative areto be presented, in tabular or narrative fora, in the feasibility study aspart of the noncost criteria analysis of the reaedial action alternatives(see chapter 9). All applicable or relevant public health and environmentalstandards, interagency coordination needs, and other institutional issuesshould be identified.

This chapter is not intended to serve in lieu of regulations andpolicies implementing particular statutory requirements. The user shouldconsult the appropriate regulations and policies co determine these require-ments.

4.2 QCRCLA CGNPLIABCE WITH OTHER EHVIROMMEIfTAL STATUTES

EPA policy on the use of environmental and public health standards atSuperfund sites is under development. The draft policy discussed in thischapter is outlined in the EPA policy memorandum "CERCLA Compliance with theRequirements of Other Environmental Statutes" (Appendix C). The key re-quirements of this policy have been incorporated in the proposed revision*to the national Oil and Hazardous Substances Contingency Plan (BCP).

It is EPA policy to comply with "applicable or relevant" environmentaland public health standards in CERCLA remedial actions unless one of fivespecific c ire ms traces described in section 4.2.1 exists, and to documentall analyses of these circumstances. Other regulations, advisories, andguidance may be considered in developing CERCLA remedies. Relevant portion*may be need; if they are not used, the reasons for not using them must bestated'in the decision documents. The memorandum define* "applicable" and"relevant" and includes a preliminary list of requirements that would beconsidered applicable or relevant, and a list of other requirements,advisories, and guidance chat should be considered. The final section ofthis chapter summarizes, in table form, the requirements identified to date.

Permits are not required for on-site Fund-financed or enforcementaction* taken under CERCLA. They are required for off-site disposal action*(those involving removal and treatment, disposal, or destruction of wastesin off-site facilities). Off-site actions and cheir permit requirementsinclude, but are not limited to, the following:

• Injection into an underground formation requires an UndergroundInjection Control permit.

e Transportation of hazardous waste co an off-sice treatment, storage,or disposal facility (TSDF) requires RCRA TSDF permits.

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• Discharge of pollutants or contaminants from a point source intoU.S. waters requires a National Pollutant Discharge EliminationSystem (NPDES) permit pursuant to CWA section 402.

• Disposal, treatment, or destruction of hazardous waste at searequires permits under the Marine Protection Research andSanctuaries Act (MPRSA).

• Discharge of pollutant contaminants into a publicly owned treatmentworks (POTV) may require permits issued by the local POTW.

• Emissions of pollutants to the air may require Clean Air Act (CAA)permits, depending on the substance emitted, its quantity, and theclassification of the area.

The responsible party or State must obtain the appropriate permits or assurethat they are obtained; State responsibilities will be specified in the con-tract or cooperative agreement.

As explained in chapter 2, the feasibility study must examine andpresent to the decisionmaker at least one alternative in each of thefollowing categories, if feasible:

• Alternatives for treatment or disposal at an off-site facilityapproved by EPA (including RCRA, TSCA, MPRSA, CWA, CAA, and SDWAapproved facilities), as appropriate (for cost-effectivenesscomparison purposes, this alternative must be compared to an on-sitetreatment or disposal alternative);

• Alternatives which attain applicable and relevant Federal publichealth or environmental standards;

• As appropriate, alternatives which exceed applicable or relevantpublic health or environmental standards;

• Alternatives which do not attain applicable or relevant publichealth or environmental standards but will reduce the likelihood ofpresent or future threat from the hazardous substances. This mustinclude an alternative which closely approaches the level of protec-tion provided by the applicable or relevant standards and meets

2These alternatives must be consistent with EPA's policy "Procedures forPlanning and Implementing Off-Site Response Actions." In some cases,off-site disposal or treatment may not be feasible and this alternativemay be eliminated during initial screening of alternatives. The decisiondocuments should reflect this screening (see Appendix B).

A 14-3

CEBCLA's objectives of adequately protecting public health, welfare,and environment.

• A no action alternative.

In some case* the** alternative* may overlap.

4.2.1 Selection of R

The decisionmaker will consider all of the alternatives arrayed in thefeasibility study and will give primary consideration to remedies thatattain or exceed applicable or relevant Federal public health and environ-mental standards. The decisionmaker may select an on-site alternative thatdoes not attain applicable or relevant standards in one or more of thecircumstance* discussed below. A consideration in making this determinationis the extent to which the standard was intended to apply to the specificconditions at the site. For example, the RCRA program was not intended toregulate a site consisting of 210 miles of roadside contaminated by indis-criminant disposal of PCS wastes, or one consisting of a river bed contam-inated with hazardous substances. If the recommended alternative involvesan EPA standard, guidance, or advisory beyond the direct requirements ofCERCLA, the decisionmaker will ensure coordination with all affected EPAprogram*.

The following specific circumstances are those in which thedecisionmaker may select an on-site alternative that does not comply fullywith applicable or relevant standards:

1. The selected alternative is not the final remedy and will becomepart of a more comprehensive remedy;

2. All of the alternatives which meet applicable or relevant standardsfall into one or more of the following categories:

(i) Fund-balancing - for Fund-financed actions only; exercisethe Fund-balancing provisions of CERCLA section 104(c)(4);

(ii) Technical impracticability - it is technically impracticablefrom an engineering perspective to achieve the standard atthe specific site in question;

(iii) Unacceptable environmental impacts - All alternatives thatattain or exceed standards would cause unacceptable damageto the environment; or,

3. where the remedy is to be carried out pursuant to CERCLA section106; the Hazardous Response Trust Fund is unavailable, or would not

4-4

1f|P-

be used; there is a strong public interest in expedited cleanup;and the litigation probably would not result in the desired remedy.

Where one of these situations is present, the dec is ionmaker may selectan alternative which does not attain or exceed applicable or relevant publichealth or environmental standards. The basis for not meeting the standardmust be fully documented and explained in the appropriate decision docu-ments.

The Agency anticipates that most CERCLA remedial actions will attain orexceed applicable or relevant public health or environmental standards.However, where the specific circumstances discussed above preclude theselection of a remedy that attains standards, the decisionmaker will selectthe alternative that most closely approaches the level of protection pro-vided by the applicable or relevant standard, considering the reasons fornot meeting that standard.

EPA also will use public health and environmental criteria indeveloping appropriate remedial alternatives. If the decisionmaker deter-mines that such criteria are relevant , but are not used in the selectedremedial alternative, the decision documents will indicate the basis for notusing the criteria. Where no relevant or applicable standards are avail-able, the user should consult headquarters on a case-by-case basis forguidance. In general, headquarters will instruct the user to develop atleast one option corresponding to a 10 .risk level. In addition, reason-able alternatives corresponding to a 10* to 10~ risk level should also bedeveloped.

For Fund-financed actions, where State standards are part of the cost-effective remedy, the Fund will pay to attain those standards. Where thecost-effective remedy does not include those State standards, the State maypay the difference to attain them.

There may be situations in which the decisionmaker may select a remedythat exceeds a standard, rather than simply attaining it, if under thecircumstances it is appropriate to select a more protective level. Forexample, a land disposal alternative may have a lower present worth than atreatment alternative, however, the treatment alternative may more effec-tively protect public health and the environment. This selection processmust be determined on a site-specific basis.

State environmental standards, guidance, or advisories should also beaddressed. States have an important role in developing remedial alterna-tives. If a State desires the selection of a remedial action that wouldincorporate State standards more stringent than Federal standards, thedecisionmaker may select that remedy. Generally, the State is expected topay any additional costs.

Changes will also be aade in the Superfund community relations programas part of this policy to ensure public involvement equivalent to that inother permitting programs. These aodificacions are discussed in section 4.6below.

The QtBCLA enforcement program will also enhance public participation,in the cases of both consent decrees and administrative orders, to substan-tial equivalence with that in Fund-financed actions. Furthermore, consentdecrees and administrative orders will incorporate recordkeeping and moni-toring requirements similar to those mandated by other environmental pro-grams.

This policy applies only to response actions taken pursuant to theFund-financed or enforcement provisions of CERCLA.

4.3 EPA GROOHD-tfATER PROTECTION STRATEGY

EPA has developed the Ground-Water Protection Strategy (GHPS) to helpState and Federal agencies cope with ground-water problems and to improvethe coherence and-consistency of EPA programs dealing with ground water.The GSfPS is not considered at this time to fall in the category of relevantor applicable standards, but it should be considered when deciding on reme-dial alternatives. The Agency is planning to incorporate provisions of theGround-Water Protection Strategy into future regulatory amendments. At thattime, those provisions may became relevant or applicable.

The GUPS has four elements, keyed to specific objectives:

1. Strengthening State ground-water programs: Funds will be set asideto support State ground-water program development and providetechnical assistance to the States. Funds will be provided to theStates, through existing grant programs, to support the developmentof overall State action plans or strategies; identify and removelegal and institutional impediments to comprehensive State manage-ment; develop general and source-specific ground-water programs;and create a data system to increase the accessibility and qualityof information. EPA will continue to support a strong researchprogram to assist both Federal and State protection efforts.

Sot applicable to enforcement actions.

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2. Treating unaddressed ground-water problems: EPA will identify,evaluate, and develop means of coping with unaddressed ground-waterproblems including leaking underground storage tanks and non-hazardous surface impoundments and landfills. The Agency willincrease efforts to protect ground water from contamination bynitrates or pesticides. EPA will also prepare a ground-watermonitoring strategy to facilitate the evaluation of ground-watercontamination from all sources.

3. Creating a policy framework for EPA programs: EPA will adopt guide-lines for consistency in ground-water protection programs. Theseguidelines will protect ground water for the highest present orpotential beneficial use. The guidelines will use existing statutesto define an appropriate protection strategy for three classes ofground water:

• Class 1, Special Ground Waters, includes those highly vulnerableto contamination and either irreplaceable or ecologically vitalsources of drinking water.

• Class 2, Current and Potential Sources of Drinking Water andWaters Having Other Beneficial Uses, includes all other groundwaters currently used or potentially available for drinkingwater or other beneficial uses.

• Class 3, Ground Water Not a Potential Source of Drinking Waterand of Limited Beneficial Use, includes saline or otherwisecontaminated ground waters beyond reasonable use for drinkingwater or other beneficial purposes. Ground water in Class 3must not be connected to Class 1 or 2 ground water or to surfacewater in a way that would allow contaminants to migrate to thesewaters, with potential adverse effects on human health or theenvironment.

The guidelines will be implemented by the development of specificrequirements in each major program area. The resulting standardswill be general and performance-oriented to allow flexibility forStates in implementing EPA-delegated programs.

4. Strengthening EPA'a internal ground-water organization: The Officeof Ground-Water Protection has been established in the Office ofWater to coordinate ground-water activities and to identify anddevelop ground-water policies and guidelines.

Regional responsibility for ground-water coordination resides in the WaterDivisions. Functions of the regional programs include overseeing ground-water policy development, providing technical and institutional support toStates, and coordinating regional ground-water program plans, state workprograms, site assessments, and enforcement.

The GBPS will affect CEKCIA remedial actions vainly through che ground-water protect ion guidelines and classification system. The classificationof affected ground waters will not change che hazard ranking score of asite; however, sites where ground water that is contaminated or threatenedwith contamination is a current source of drinking water do score higherthan those where ground water is not a current source. Ground-water clas-sifications should be used to establish priorities for initiating remedialinvestigations. Also, the degree of cleanup or protection of ground waterresources to be achieved at CKRCLA sites will generally be keyed to theclassification of the affected or potentially affected ground waters.Therefore, the evaluation and selection of remedial alternatives will haveto take account of the ground-water classification.

Remedial actions at sites that overlie Class 1 ground waters (SpecialGround Waters) will be given high priority. Cleanups will be to drinkingwater standards or levels that protect human health. Cleanup beyond thesite boundaries may also be necessary. Statutory factors (e.g., Fund-balancing) and the need to achieve rapid private party response may requireoccasional acceptance of lower levels of cleanup.

Ac sites that overlie Class 2 ground waters, the goal of CKBCLAcleanup* will be drinking water quality or Alternative Concentration Limits(ACLs) under BCBA upon a determination that the ACL will not pose substan-tial present or potential hazard to human health or the environment. In theabsence of an ACL or a drinking water standard, the goal of cleanup is thebackground level. Modifications are more likely for potential drinkingwater supplies than for current supplies. Consequently, alternatives toground-water cleanup and restoration may be appropriate. In such a case,the plume of contamination may be monitored and managed to prevent or miti-gate its migration into a current source of drinking water or to avoid wide-spread damage. In certain situations involving current sources of drinkingwater, such as when technical feasibility is an issue, the cost-effectiveremedy may be to provide an alternative drinking water supply rather thanrestoring the contaminated aquifer.

For nf^^M sites -that overlie ground waters not considered potentialsources of drinking water and of limited beneficial use (Class 3 groundwaters), "F^^M remedial actions will generally not involve ground-watercleanup. The priority of these sites for remedial action will be low in theabsence of other hazards to human health and the environment (such as sur-face water contamination, fire, or explosion).

Criteria for ground-water classification have not yet been developed indetail. However, the classifications will be determined in conjunction withassessments of the extent of contamination for CEBCLA cleanup actions on asite-specific basis. In many cases, the geologic and hydro logic informationnecessary to make this classification will have been gathered as part of thesite investigation. Information collected by other Federal and State agen-cies may be uaed for classification. Therefore, during preparation of thefeasibility study, the classification should be available for determiningthe level of. protection to be achieved.

4-8

4.4 COMPLIANCE WITH THE NATIONAL ENVIRONMENTAL POLICY ACT (NEPA)

Remedial actions taken pursuant to sections 104 and 106 of CERCLA aregenerally exempt from the NEPA requirement to prepare an EnvironmentalImpact Statement (EIS), based on numerous court decisions holding that theAgency carries out the functional equivalent of a NEPA review in its permit-ting and regulatory activities. Under this exemption, the EPA is not obli-gated to comply with formal EIS procedures if two criteria are met. Thefirst is that the authorizing statute (i.e., CERCLA) must provide substan-tive and procedural standards to ensure full and adequate consideration ofenvironmental issues and alternatives. The second is that the public mustbe afforded an opportunity to participate in evaluating environmentalfactors and alternatives before a final decision is made.

Taking the following steps will ensure that Fund-financed remedialactions meet these criteria and achieve functional equivalence with EISrequirements:

1. The process for determining the extent of the remedy required byCERCLA section 105(3) and described in section 300.68 of the NCPmust be followed. To meet the first criterion of NEPA functionalequivalency, this process includes the necessary and appropriateinvestigation and analysis of environmental factors as theyspecifically relate to a Superfund site, and alternatives that arebeing considered to correct the situation.

2. To meet the second criterion, a meaningful opportunity for publiccomment on environmental issues must be provided before the finalselection of a remedial alternative. To meet this requirement, EPARegions must allow both the opportunity and adequate time for thepublic to review draft feasibility studies. This should be accom-plished as part of the community relations program required at allSuperfund response sites.

4.5 COORDINATION WITH OTHER AGE-NCIES

CERCLA, the NCP, and Executive Order 12316 delegate the authority tomanage certain aspects of Superfund responses to several Federal agencies.For example, the Federal Emergency Management Agency (FEMA) is authorized tomanage relocations. The Department of Health and Human Services (HHS) andthe U.S. Army Corps of Engineers also are often called on to assist inremedial actions. These agencies can contribute useful advice during theremedial investigation and feasibility study and should be consulted. TheUnited States Geological Survey (USGS) is not delegated any specific CERCLAresponse authority, but its technical knowledge of geological character-istics at sites can be valuable in evaluating remedial alternatives. Ifcoordination is required for any remedial alternative, the feasibility study

*•' 4-9

must indicate chat the appropriate agency hat been or will be contacted andthat the needed coordination mechanism either is in place or can be devel-oped.

4.5.1 Federal Emergency Management Agency

Permanent relocation of residences, businesses, and communityfacilities is included in the definition of remedy under CERCLA section101(24). Permanent relocation may be undertaken as part of a remedialaction if human health is in danger and if, alone or in combination withother measures, it would be cost-effective and environmentally preferable toother responses. Temporary relocation, including evacuation and temporaryhousing of threatened individuals not otherwise provided for, may also beundertaken as part of a remedial action (e.g., during cleanup at a CERCLAsite to limit exposure or threat of exposure to a significant environmentalhazard).

EPA and FEMA efforts must be coordinated when a remedial actioninclude* relocation. Executive Order 12316 delegates to the Director ofFEMA the authority to carry out relocation under CERCLA. A memorandum ofunderstanding between EPA and FEMA is being developed to define the respon-sibilities of these agencies in such relocation actions. The memorandum,when approved by both agencies, will supplement this section with moredetailed guidance on the roles of FEMA and EPA in relocation and proceduresfor initiating relocation actions.

The required coordination between the agencies may affect implemen-tation of an alternative. Also, community interest in remedial alternativesthat include relocation will be high. For remedial alternatives thatinclude relocation, the feasibility study must indicate that FEMA has beenor will be contacted and that the necessary coordination mechanism either isestablished or can be developed. During the feasibility study the usershould evaluate the effect of relocation on implementation of the remedialalternatives.

4.5.2 Health and Human Services

The Department of Health and Human Services, through the Agency forToxic Substances and Disease Registry (ATSDR) and the Rational Institute forOccupational Safety and Health (IIOSH), is responsible for monitoring thehealth of workers and citizens at or near Superfund sites and for ensuringadequate health care. In this capacity, HHS can contribute to the evalua-tion of remedial alternatives. For each alternative, HIOSH and ATSDR canprovide advice on the procedures that would be required to conduct workerhealth and safety programs and ensure the health of the local community.Furthermore, HHS health and epidemiological studies may provide data useful

4-10

in assessing health concerns. When che user determines that HHS expertiseis required, he or she should contact the regional HHS representative torequest NIOSH or ATSOR support.

A memorandum of understanding between EPA and HHS is being developed todefine the responsibilities of each agency in responses pursuant to CERCLA.The memorandum, when approved by both agencies, will supplement this sectionwith more detailed guidance on HHS involvement.

4.5.3 U.S. Army Corps of Engineers

The U.S. Army Corps of Engineers manages the technical work during theremedial design and construction phases of Federal-lead remedial actions.The Corps also helps EPA review State-lead projects to determine theirsuitability for bidding and construction.

The Corps benefits from early involvement in the remedial investigationand feasibility study by learning about site problems before a remedy isselected. The Corps also can contribute valuable technical assistance fromthe earliest stages. For example, the Corps may require certain data aboutthe site for design and construction that may not be needed to evaluate andrecomend remedial alternatives. Collecting such data during the remedialinvestigation is generally leas costly than going back to the site after theremedy has been selected.

The Corps can also provide useful advice about the technicalfeasibility of the various remedial alternatives, ensuring that the alter-native selected can be engineered and constructed. EPA will not assign aremedial action to the Corps for management if the Corps determines that theaction is not reasonable to design, construct, operate, and maintain. Inaddition, the Corps can initiate the process of securing rights-of-way, thusreducing the delay between selection and implementation of an alternative.

The Corps' expertise may also be useful in cases in which Corps-administered permits are applicable (e.g., when the remedial action involvesdischarge of dredged or fill material). When the user determines that Corpsadvice is needed, he should contact the appropriate District Engineer.

The Corps may also be called upon to perform compliance monitoring ofremedial construction activities of responsible parties under enforcement.

4.5.4 U.S. Geological Survey

The user may find it useful to consult with OSGS district offices togather basic technical information about a site. It is generally not

4-11

appropriate to contract with OSGS co perform the feasibility study in aFederal-lead remedial action. Instead, the OSGS may be consulted as a.formal contractor co the Remedial Planning and Field Investigation Teamcontractor or through an interagency agreement (agreements for this purposealready exist). In State-lead responses, it may be appropriate for the OSGSto perform the feasibility study as a contractor to Che State. GPA is cur-rently exploring this issue to clarify the appropriate OSGS role inSuper fund responses.

Many States employ geologists who can provide useful technical infor-mation about sites in their States; they often can be contacted throughState departments of natural resources. Using State geologists makes itpossible to bypass any contractual difficulties or delays caused by the needfor formal contracts with OSGS. State geologists may be especially usefulwhen the need for a geologist at a site is not great enough to warranthiring a geologist full-time for an indefinite period. In any case, Stategeologists form a valuable resource that should not be overlooked.

4.5.5 Occupational Safety and Health Administration

Vhile worker safety and health at Super fund response sites are theresponsibility of employers, OSHA has the authority to inspect Superfundsites and issue citations for unsafe conditions. The OSHA health responseteam is available to provide technical assistance to regional project

(ers, OSCa, and contractors in appropriate safety procedures. Note thatStates operate their own occupational safety and health programs in

place of OSHA, and that some working conditions are covered by Federal agen-cies other than OSHA (such as the Mining Safety and Health Administration).These other agencies could have jurisdiction in some CEBCLA response actionsfor specific working conditions.

4.5.6 national Response Team

The Rational Response Team (HRT) and Regional Response Teams (RRTs)provide an existing structure for the coordination of activities undertakenby the agencies and States that may be involved in a response action. TheMET and RBTs can provide points of contact in Federal agencies or Stategovernments for obtaining information necessary to the feasibility study,and may be able to provide equipment or other support in performance of theremedial action.

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4.5.7 Other Government Authorities

Certain other agencies may also give advice useful in planning andimplementing remedial actions. These agencies and their potential roles inremedial actions include:

• The Advisory Council on Historic Preservation can consult onremedial actions involving landmarks, historic sites, or areas ofscientific, cultural, or historic interest.

• The Bureau of Land Management (BLM) of the Department of theInterior may be helpful when a remedial action involves Federallands on which BLM has authority over waste disposal or access, suchas flood pi a ins and landmarks .

• The Fish and Wildlife Service of the Department of the Interior canprovide advice and information on preventing or lessening impacts onfish and wildlife, especially game species; identifying threatenedand endangered species; identifying habitats of special interest;and listing or mapping wetlands. This information would be usefulin applying for permits for the discharge of dredged or fillmaterial .

• The Forest Service of the Department of Agriculture can provideadvice and information on the Wild and Scenic Rivers System.

• The Heritage Conservation and Recreation Service oE the Departmentof the Interior can provide advice and information on NationalRegister of Historic Places and Natural Areas.

• The Department of Housing and Prban Development can providefloodplain maps.

• The Department of Transportation may be helpful if the remedialalternative involves off-site transport of hazardous wastes.

4.6 COMMUNITY RELATIONS

Community relations activities are an integral part of everySuper fund- financed remedial action whether it be Federal-, State-, orprivate party-lead, regardless of the choice of remedial alternatives. TheEPA' 3 "Community Relations in Super fund: A Handbook" supplements thissection with background material, the community relations requirements andmore detailed procedural guidance on planning and implementing effectivecommunity relations programs.

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A community re lac loos plan (CRF) is a management and planning cool chatoutline* the specific communication* activities to be used during aSuperfind response and the integration of these activities with technicalwork at the site. The plan must be based on interviews conducted within thecommunity with local officials, civic leaders, community residents andleaders, and public interest groups.

To provide a meaningful opportunity for public comment, the followingstep* must be included in the community relation* program:

1. Interview* with interested and affected community residents must beconducted to determine level of interest, major issues, andinformation needs.

2. Based on the community interviews, a community relation* plan isdeveloped for the site before SI field work begin*.

3. Region* mu*t provide local notice of the availability of the draftfeasibility study. This notice can be provided through publicationin local newspapers and through civic groups or other organiza-tion*. The draft feasibility study should be placed in localinformation repositories such a* community libraries or churches.

4. At least 3 week* mu*t be allowed for comment, measured from thedate of notice of availability of the draft RI/FS study. TheSuperfund coordinator, in consultation with the EPA RegionalAdministrator, can allot additional time. In general, unless thesite problem is highly technical and citizen concern i* high, 3week* should be sufficient, so long as the draft study is expedi-tiou*ly distributed. An informal meeting or briefing can be heldat Che beginning of the review period to discus* the results of thedraft study.

5. A responsiveness iimmisi • must be included in the final feasibilitystudy.

In addition to these steps, the following should be performed so thatthe community relations program i* procedurally equivalent to the publicparticipation requirements of the Federal Environmental Impact StatementProgram:

• A fact sheet should be included with the public notice andfeasibility study provided to the public 2 week* before the 3-week,public comment period. The fact sheet must clearly summarize the

Interim version, September 1983.

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feasibility study response alternatives and other issues, includingwhich alternatives comply with other environmental laws. For alter-natives that meet the goals of CERCLA in protecting human health andthe environment but do not meet the technical requirements of otherenvironmental laws, the fact sheet shall identify the ways theydiffer and the reason for each difference. The public notice shouldinclude the schedule on which a decision will be reached, any tenta-tive determinations made by the Agency, the location where relevantdocuments can be obtained, community involvement opportunities, thename of an Agency contact, and other appropriate information.

• A public notice and updated fact sheet should be prepared when theAgency has selected the response action and again when the finalengineering design is complete, to demonstrate that the remedyprovides adequate protection and satisfies the public's concerns.

• If a remedy is identified that is different from those proposedduring the public comnent period on the feasibility study, a new3-week public comment period may be required before the Record ofDecision is amended, taking into consideration the features of thealternatives addressed in the public comment period.

In evaluating remedial alternatives, the user should be sensitive topublic perception of the alternatives. Alternatives perceived to be unac-ceptable by the community may be delayed or prohibited by zoning changes orother measures. Steps necessary to address public concerns and incorporatecitizen input when feasible should be taken as early as possible.

4.7 SUMMARY OF INSTITUTIONAL REQUIREMENTS

This section sunmarizes, in table form, Federal, State, and localrequirements applicable or relevant to response actions. Tables 4-1 and 4-2are intended as a checklist for users; it should not be used as a substitutefor the actual regulations and policies.

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TABLE 4-1. APPLICABLE OK RELEVAlfT HEQCTIBZMESTS

1. Office of Solid Waste

e Open Dump Criteria (RCRA Subtitle 0, 40 CPR Part 257)

Rote: Only relevant to nonhazardous wastes. In most situations,Superfund wastes will be handled in accordance with RCRA Subtitle Crequiresients.

• Hazardous Waste Regulations (RCRA Subtitle C, 40 CFR Part 264)including liner, cap, ground-water, and closure requirements underthe following subparts:

F. Ground-Water ProtectionG. Closure and Post-ClosureH. Financial RequirementsI. Ose and Management of ContainersJ. TanksK. Surface ImpoundmentsL. Waste PilesM. Land TreatmentB. Landfills0. Incinerators

2. Office of Water

• Marianas Contaminant Levels (for all sources of drinking waterexposure)

• Underground Injection Control Regulations

e State Water Quality Standards (applicable for surface waterdischarge)

e Requirements established pursuant to sections 301 and 403 of theClean Water Act

• Ocean Dumping Requirements including incineration at sea

Pretreatsent standards for discharge into publicly owned treatswntworks (POTW).

(continued)

Applies to enforcement action, not applicable or relevant to Fund-financedactions.

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3. Office of Pesticides and Toxic Substances

• PCB Requirements including Disposal and Marking Rule (43 FR 7150,2/17/78); PCB Ban Rule (44 FR 31514, 5/31/79).

• 40 CFR 775 Subpart J - Disposal of Waste Material Containing TCDD.

4. Office of External Affairs

• Guidelines for Specification of Disposal Sites for Dredged or FillMaterial [J404(b)(l) Guidelines, 40 CFR Part 230]

• Denial or Restriction of Disposal Site for Dredged Material: FinalRule [U04(c)].

5. Office of Air and Radiation

• Uranium mill tailing rules

• National Ambient Air Quality Standards

• High- and low-level radioactive waste rule

• Asbestos disposal rules

6. Other Federal Requirements

• OSHA requirements

• Preservation of scientific, historical, or archeological data

• D.O.T. Hazardous Materials Transport Rules

• Regulation of activities in or affecting waters of the United Statespursuant to 33 CFR Parts 320-329

• The following requirements are triggered by Fund-financed actions:

- Preservation of rivers on the national inventory, Wild andScenic Rivers Act, 17, 40 CFR Part 6.302(e)

(continued)

4-17


- Protection of threatened or endangered species and theirhabitats

- Conservation of Vildlife Resource*

- Executive Orders related to Floodplains (11988) and Wetlands(11990)

- Coastal Zone Management Act.

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TABLE 4-2. OTHER REQUIREMENTS, ADVISORIES, AND GUIDANCE TO BE CONSIDERED

1. Federal Requirements. Advisories,, and Procedures

A. Recommended Maximum Concentration Limits (RMCLs)

B. Health Advisories, EPA, Office of Water

C. Federal Water Quality Criteria

Note: Federal water quality criteria are not legally enforceable.State water quality standards, developed using appropriate aspectsof Federal water quality criteria, are legally enforceable. In manycases, States water quality standards do not include specific numer-ical limitations on a large number of priority pollutants. Whenthere are no numerical State standards for a given pollutant,Federal water quality criteria should be considered.

D. Pesticide and food additive tolerances and action levels data

Note: Germane portions of tolerances and action levels may berelevant to certain situations.

E. Waste load allocation procedures, EPA Office of Water

F. Federal sole source aquifer requirements

G. Public health basis in listing decision under section 112 of theClean Air Act

H. EPA ground-water protection strategy

I. New Source Performance Standards for Storage Vessels for PetroleumLiquids

J. TSCA health data

K. Pesticide registration data

L. TSCA chemical advisories (two or three issued to date)

M. Advisories issued by FWS and NWFS under the Fish and WildlifeCoordination Act

(continued)

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•. Bational Environmental Policy Act

0. Floodplain and wetlands Executive Orders.

2. State Bequirements

A. State Bequirements on Disposal and Transport of Badioactive wastes

B. State Approval of Mater Supply System Additions or Developments

C. State Ground-Water Withdrawal Approvals

D. Requirements of authorized (BCBA Subtitle C) State hazardous wasteprograms

K. State Implementation Plans and delegated programs under the CleanAir Act

P. All other State requirements, not delegated through EPA authority.

Vote: Many other State and local requirements could be relevant.The guidance for feasibility studies will include a more compre-hensive list.

3. OSEPA BdA Guidance Documents

A. EPA BOA Design Guidelines

1. Surface Impoundments, Liners Systems, Final Cover, and FreeboardControl

2. Baste Pile Design - Liner Systems

3. Land Treatment Units

4. Landfill Design - Liner System and Final Cover.

B. Permitting Guidance Manuals

1. Permit Applicant's Guidance Manual for Hazardous Haste LandTreatment, Storage, Disposal Facilities

(continued)

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2. Permit Writer's Guidance Manual for Hazardous Waste LandTreatment, Storage, Disposal Facilities

3. Permit Writer's Guidance Manual for Subpart F

4. Permit Applicant's Guidance Manual for the General FacilityStandards

5. Waste Analysis Plan Guidance Manual

6. Permit Writer's Guidance Manual for Hazardous Waste Tanks

7. Model Permit Application for Existing Incinerators

8. Guidance Manual for Evaluating Permit Applications for theOperation of Hazardous Waste Incinerator Units

9. A Guide for Preparing RCRA Permit Applications for ExistingStorage Facilities

10. Guidance Manual on Closure and Post-Closure Interim StatusStandards.

C. Technical Resource Documents (TRDs)

1. Evaluating Cover Systems for Solid and Hazardous Waste

2. Hydrologic Simulation of Solid Waste Disposal Sites

3. Landfill and Surface Impoundment Performance Evaluation

4. Lining of Waste Impoundment and Disposal Facilities

5. Management of Hazardous Waste Leachate

6. Guide to the Disposal of Chemically Stabilized and SolidifiedWaste

7. Closure of Hazardous Waste Surface Impoundments

8. Hazardous Waste Land Treatment

(continued)

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9. Soil Properties, Classification, and Hydraulic ConductivityTesting.

D. Test Methods for Evaluating Solid Waste

1. Solid Waste Leaching Procedure Manual

2. Methods for the Prediction of Leachate Plume Migration andMixing

3. Hydrologic Evaluation of Landfill Performance (HELP) ModelHydrologic Simulation on Solid Waste Disposal Sites

4. Procedures for Modeling Flow Through Clay Liners

5. Test Methods for Evaluating Solid Wastes

6. A Method for Determining the Compatibility of Hazardous Wastes

7. Guidance Manual on Hazardous Waste Compatibility

4. 'JS&PA Office of Water Guidance Documents

A. Pretreatment Guidance Documents

1. 304(g) Guidance Document Revised Pretreatment Guidelines (3Volumes)

Provides technical data describing priority pollutants and theireffects on wastewater treatment processes to be used in devel-oping local limits; describes Technologies applicable to cate-gorical industries.

B. Water Quality Guidance jocuments

1. Ecological Evaluation of Proposed Discharge of Dredged Materialinto Ocean Waters (1977)

2. Technical Support Manual: Waterbody Surveys and Assessments forConducting Use Attainability Analyses (1983)

Outlines methods for conducting use attainability analyses underthe Clean Water Act.

(continued)

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3. Water-Related Environmental Fate of 129 Priority Pollutants(1979)

Describes the transformation and transportation of prioritypollutants.

4. Water Quality Standards Handbook (1983)

Provides an overview of the Criteria Standards Program under theClean Water Act and outlines methods for conducting criteriastandards modification.

5. Technical Support Document for Water Quality-Based ToxicsControl.

C. NPDES Guidance Documents

1. NPDES Best Management Practices Guidance Manual (June 1981)

Provides a protocol for evaluating BMPs for controlling dis-charges of toxic and hazardous substances to receiving waters.

2. Biomonitoring Guidance, July 1983, subsequent biomonitoringpolicy statements and case studies on toxicity reductionevaluation (May 1983).

D. Ground-Water/UIC Guidance Document

1. Designation of a USDW

2. Elements of Aquifer Identification

3. Interim guidance for public participation

4. Definition of major facilities

5. Corrective action requirements

6. Requirements applicable to wells injecting into, through, orabove an aquifer which has been exempted pursuant toS146.104(b)(4).

7. Guidance for UIC implementation on Indian lands.(continued)

4-23


8. Technical Resource Documents (currently under development byOCWP).

5. DSEPA Manual* from the Office of Research and Development

A. W-846 - laboratory analytic methods

B. Laboratory protocols developed pursuant to Clean Water Act §304(h)

4-24

CHAPTER 5

EVALUATE PROTECTION OF PUBLIC HEALTH REQUIREMENTS

5 . 1 OVERVIEW

The remedial action selected for a Super fund hazardous waste site mustadequately protect public health, welfare, and the environment. Thisrequires documenting that the action minimizes the long-term effects of anyresidual contamination, and protects the public. both during and after theaction. This chapter provides interim guidance for ensuring that remedialactions limit the concentrations of toxic substances in the environment toavoid unacceptable threats to human health.

More comprehensive guidance on assessing public health effects is underdevelopment. The schedules of many remedial actions, however, make itnecessary to disseminate interim guidance for ongoing feasibility studies.This guidance will aid in data collection and decisionmaking until finalguidance is prepared. In accordance with current procedures, the publichealth evaluation may be done by EPA Regions, the State, a responsibleparty, or their consultants. When the Regional Administrator finds itappropriate, he or she may request the help of EPA's Office of Research andDevelopment (ORD) (for environmental exposure and risk assessments) or theAgency for Toxic Substances and Disease Registry (ATSDR) (for human healthstudies, health assessments, and health advisories) in evaluating publichealth effects at a site. EPA's assessments will be developed in consul-tation with ASTDR so the assessment results will serve as input to ASTDR1 spublic health evaluations for both Fund-financed as well as enforcementcases. Until the necessary toxicological data and guidance on their appli-cation can be generated and provided in a standard format, Headquarterspersonnel will also help in the evaluation, providing necessary informationand reviewing final documentation.

An endangerment assessment must be conducted for all enforcement sites.At a minimum, it should establish the potential health and environmental

This chapter contains interim guidance for public health evaluation. Finalguidance for public health evaluation will be provided after completion ofrisk assessment guidelines for evaluating chemical hazards that do not haveappropriate standards or criteria.

5-1

threats of the sice in che absence of response action. The endangementassessment will have some coaponencs of the public health assessmentdescribed in this chapter, but may be more or less detailed depending on theamount, type and quality of data available. For example, if the endanger-ment assessment is prepared before an RI has begun or during the initialstages of an RI, less data will be available Chan if the endangermentassessment is prepared after an RI is completed. For some enforcementsites, the feasibility study public health assessment may serve as theendangerment assessment. Chapter 10 (forthcoming) describes endangermentassessments in detail.

These interim guidance procedures were developed to account for thegreat variety of conditions at different Superfund sites. All remedialsites should undergo a public health evaluation, although the form andextent of the assessment will depend on the situation. The interim publichealth evaluation has several steps (though not all apply to all remedialsites):

• Baseline site evaluation: Preliminary evaluation and classificationthat all sites must undergo.

Exposure assessment: Analysis of the extent and duration ofexposure to site contaminants in the absence of remedial action.

Standards analysis: Comparison of projected environmental concen-trations to appropriate ambient standards or criteria.

Develop, evaluate, and modify remedial alternatives: Evaluation ofshore- and long-term effects of remedial alternatives to remove ormitigate exposures of concern identified during the exposureassessment. Specific design goals will be baaed on applicable orrelevant standards, or the absence of appropriate standards, todevelop at least one option corresponding to a 10 _ri»k level andother reasonable alternatives corresponding to a 10 to 10 risklevel.

5.2 DEVELOP A BASELINE SITE EVALUATION

Baseline site evaluation is the firsc step in public health evaluationfor all sites. First, the available data relevant to public health evalua-tion should be collected, organised, and reviewed. The information col-lected should include site background data, disposal history (and records,if available), types of remedial technologies considered, cm-sice and off-site chemical data, site environmental data (e .g . , topography and hydro-geology), information on local human populations, and information on humanhealth effects (which may be unavailable). Data sources include preliminaryassessment data and reports, field reports, remedial investigation scopingdocumentation, and analytical data and reports available from ongoing sitecharacterization and alternatives screening activities.

5-2

Of particular importance in this initial review is the information usedto define the type of action likely to be taken at a site and the level ofdetail required for the exposure assessment. Sites involving contaminationthat has not migrated much beyond the source generally call for relativelysimple source control measures. Sites that have evidence of contaminantmigration beyond the source (e.g., into ground water) may consider sourcecontrol options as well as management of migration alternatives. Othersites may have such extensive migration of contaminants that only managementof migration options would be suitable. These classifications are generallymade at the RI/FS scoping stage. The distinctions are important in deter-mining the extent of analysis and evaluation required for each alternative(see section 5.4). Thus, all data on the extent of contamination, con-taminant mobility and migration, and types of remedial alternatives shouldbe carefully reviewed. The result of the baseline evaluation should be adetermination of the data required to conduct the exposure assessment andthe level of detail in this assessment. This evaluation will generally beconducted in conjunction with development of Che site sampling plan.

To be considered a source control situation, the site and the remedialalternatives must meet all of the following conditions:

• The known and suspected chemical contamination at the site isrestricted to near its original location.

• The remedial alternatives considered include both on-site controlmeasures, and removal and off-site disposal or treatment at afacility approved under the Resource Conservation and Recovery Act(RCRA) or other environmental laws including TSCA, CWA, CAA, MPRSA,or SDWA, aa appropriate.

• The remedial alternatives will prevent or minimize releases ofcontaminants.

Management of migration measures should be evaluated if these conditions arenot met.

5.3 DEVELOP AN EXPOSURE ASSESSMENT

At sites where only source control remedial measures are beingevaluated, a qualitative assessment of the potential public health threatsin the absence of remedial action will generally be conducted. An in-depthquantitative analysis is not warranted in such situations where (1) con-tamination has not migrated into any transport media capable of producinghuman exposures and (2) the only actions under consideration are those thatprevent such migration. However, at a minimum, a qualitative exposureanalysis is required to evaluate the types, amounts, and concentrations ofchemicals at the site, their toxic effects, the proximity of target popula-tions, the likelihood of chemical release and migration from the site, andthe potential for exposure. This health assessment requires written docu-mentation.

Source control alternatives will be based on acceptable engineering - v-*r

practice for preventing off-site releases and on applicable or relevantstandards (e.g., ICRA design standards). Quantitative health risk assess-ment will usually not be required for alternative selection or design atthese sites. However, the reliability of such remedies should be evaluatedin the context of engineering practicality as set forth in chapter 3. Inthose situations, the operation and maintenance agreement should includeeffective monitoring provisions to ensure chat a failure would be identifiedprior to human or environmental exposure.

At sites where management of migration options are being considered, aquantitative exposure assessment should be undertaken. The objective ofexposure assessment is to estimate the frequency, magnitude, and duration ofhuman exposure to toxic chemical contaminants released from a site. Severaltasks are required in this assessment:

• Identifying chemicals present at the site and selecting indicatorchemicals (based on toxicity, persistence, mobility, and quantitypresent) x"-

• Identifying points of potential human exposure and exposure pathwaysfor each remedial alternative considered

• Characterizing populations potentially at risk

• Estimating at key exposure points the environmental concentrationsof each indicator substance.

In some situations, there may only be a small number of chemicalspresent and all chemicals may be evaluated. At sites where there are alarge number of chemicals, specific indicator chemicals may be selected tofacilitate a manageable analytical and design effort. These indicatorsshould represent the most toxic, persistent, mobile, and prevalent chemicalsat the site. Vhile this document promotes the use of indicator chemicals inthe development and analysis of alternatives, EPA recognizes there may besome short comings in.developing alternatives that must be in compliancewith BC1A regulations (CFR Part 264). In these instances, the projectmanager should consult with the EPA RCRA office to determine the minimumrequirements for analyzing constituents at the site. In many cases, ananalysis of KCXA Appendix VIII constituents can be demonstrated usingcarefully selected indicator chemicals.

Table 5-1 provides a reasonably complete list of questions that shouldbe answered in an exposure assessment. These questions apply to both quali-tative and quantitative assessments. Because extreme uncertainties arelikely, a critical part of all exposure assessments is documenting assump-tions and other sources of uncertainty. A detailed manual for conductingexposure assessments is under development. In the interim, project managersshould use their best judgement in characterizing each of the aboveelements.

5-4

TABLE 5-1. QUESTIONS IN EXPOSURE ASSESSMENT

I. Chemical Identification

A. What chemicals are known or suspected to have beendisposed at the site?

B. What quantities of each chemical were disposed?C. How were they disposed (bulk dumping, drums, bulk

storage)?D. Which chemicals are now in the environment (air,

land, surface water, ground water)?E. What are the ambient levels of these chemicals in

the air, ground water, surface water, and soil?F. What conditions or events could affect contamination

levels on- and off-site?6. What chemicals can be used as indicators of the

overall risk at the site?

II. Surrounding Population

A. Describe the population surrounding the site:1. How many people are potentially exposed?2. Who are they (especially high-risk groups,

e.g., children, the elderly, or the ill)?3. Where is the population located relative to the

site?4. Is the area mainly for residence or business?5. What type of access is there to the site?6. What normal activities might be affected by

contamination (e.g., farming by contaminatedsoil)?

B. What, if any, health-related complaints have beenreceived? Have these been documented or proven tobe related to the site?

III. Potential Exposure Routes

A. Unavoidable on-site exposure (residences, etc.)1. How are people exposed?2. What are the routes of exposure (through

inhalation, the skin, or ingestion)?3. To what chemicals are people exposed?4. To what levels are they exposed (use monitoring

data and modeling if appropriate)?

(continued)

5-5


5. Bow many people are exposed at these levels(i.e., through each pathway)?

B. Voluntary on-site exposure1. How are people exposed?2. What are the routes of exposure (through

inhalation, the skin, or ingestion)?3. To what chemicals are people exposed?4. To what levels are they exposed (use Monitoring

daca and modeling if appropriate) and how manypeople are exposed at these levels (i.e., througheach pathway)?

5. Can this exposure be prevented?C. Off-site exposure (actual and potential)

1. flhat envirooBental routes Bust chemicals takefor exposure?

2. How likely are these routes of exposure?3.- when is exposure expected to occur?4. How are people exposed (through inhalation, the

skin, or ingestion)?5. To what chemicals are people exposed?6. To what levels are they exposed (use monitoring

data and modeling if appropriate)?7. How many people are exposed at these levels

(i.e., through each pathway)?D. Other non-waste-related exposures

1. Is the population, or are segments of thepopulation, exposed to any of these chemicalsfrom other routes, e.g., in Che workplace?

2. Are the ambient environmental levels of any ofthe chemicals known?

3. Are they suspected to be abnormally high for anyreason?

IV. The Effect of Sot Taking Action

A. Technical issues1. What will happen if no action is taken (e.g.,

lagoon failure, aquifer contamination, drumfailure-, air contamination)?

2. What chemicals will be of concern?

(continued)

5-6


B. Exposure issue*1. What exposure will result from not taking

action?2. Will exposure increase indefinitely?3. Will exposure rise and then fall? Over what

time?4. What is the predicted range of eventual

contamination and exposure?

5.4 COMPASS ALTERHATIVES TO APPLICABLE OR RELEVANT ENVHOHMEHTAL STAHDARDS

FoIloving the exposure assessment, estimated environmental concen-trations of the indicator chemicals selected for that site should becompared to applicable or relevant environmental standards and criteria.

This comparison must be made for each of the alternatives discussed insection 4.2. Table 5-2 lists substance-specific relevant and applicablenumerical standards as well as other numerical criteria, advisories, andguidance to be considered in the analysis of alternatives. (See Appendix C,CERCLA Compliance with the Requirements of Other Environmental Statutes, fora more complete listing of various types of standards, criteria, advisories,and guidance.) There may be some situations where applicable or relevantstandards listed in Tables 5-2 and 4-1 are not applicable to specific sitesituations (for example, see section 5 .4 .2) . There may be situations, asveil, where there are relevant or applicable standards that cover only someof the substances at a site. In contrast to these two situations, it ismore likely that a project manager will more frequently use relevant orapplicable technology-based standards (e.g., 40 CFR 264, treatment, storage,and disposal regulations under the Resource Conservation and Recovery Act)or consider other advisories, criteria, and guidance for specific substancesat a site in fashioning alternative remedies.

In fashioning alternatives, it is first necessary to determine whetherany relevant or applicable standards exist. Applicable standards are thosethat would legally apply if the action was not being taken under CERCLA.Relevant standards are those designed to apply to circumstances sufficientlysimilar to those encountered at CERCLA sites in which their applicationwould be appropriate at a specific site although not legally required.These relevant and applicable standards (both technology- and substance-specific) should be used as primary design goals. In addition, otheradvisories, criteria, and guidance should be considered, especially in caseswhere relevant and applicable standards do not exist. Other advisories,criteria, and guidance should be examined closely to determine whether theyneed to be modified to fit site conditions (e.g., where exposure assumptionsunderlying a criterion are significantly different than site conditions).The project manager and decisionmaker will find that the use of othercriteria, advisories, and guidance yield somewhat more flexibility inalternatives design and selection than relevant or applicable standards(which must be attained unless one of the five specific circumstancesexists). Section 5.4.1 provides a summary of the assumptions underlyingsome of the standards, criteria, and advisories that may be most frequentlyused.

1. Treatment or disposal at an off-sice facility;

2. Those that attain applicable or relevant standards;

5-8

TABLE 5-2. EPA AMBIENT STANDARDS AND CRITERIA FOR SUPERFUND REMEDIAL SITES

Applicable or kelevantlenuireejeata Other Criteria. Mviaorlea, aed Guidance

Ckeaical

fata DrinkiMHater Act.HCU (M/LUnleae

otkerviee•at**)

CUM Air Act.MAQf <ug/«J)

Clean Heter Act,Hater Quality Criteria

far kunaa Healtk--riak and Driaklnt Hater

Clean Hater Act.Hater Quality Criteria

for •—•» •ealtk--Adjuated for

Brinklnf Hater Ool»

fefe DrinkiM Hater Act,•aattk Advleorlee

(M/L)l-day IO-4ay Ckreaic

( longerten)

Ln

vo

AceneafctkeneAcroleieAcrylamitrlleANriaAntivaayAreeeic 0.01Aeveataeleriua 1.0teaaene•e*ai4ine•erylliuaiCxk.i« 0.01Carbon aoooda'e

Carbon tetracklorUeCklordaiMChlorinated benaenea

Neiackl orobenaenel,2,4,i-TetracklarobeaEenePeat eckl arabenaeaeTrickier obanaeneHona«hlerobenaene

Cklorinatea1 etkanea,2-Dickl«roetka*e, 1 , 1 -Tr ickloroetkane, 1 . J-Tr icklaroetkane,1.2,1-Tetracbloreetkaneeaeckloroetkenelonockloroetkane,1-Dicbloroetkane, 1 . 1 ,1-Tetrackloroetkane

Peatacbloroetkaae

10 uf/L (ersanoleatic)310 MC/t

(U a«/L>(O.OM •»/!.)

44 y|/L(I.I M/t)(M.OM fibera/L)

(O.M ••/!.>(•.11 M/t)(1.1 M/U)

. 10 nf/L40.000 (l-koitr)"10.000 (l-kour)

0 (0.4 «(/L>• (0.4* n|/L>

0 (0.72 ag/L)M y«/L74 a|/LInenfflclent date4M ut/L

0 (0.«4 u«/L)It. 4 M/L• (0.« U|/L)• (O.IT uc/L)• (l.» ueJL)Ineyfllclent dataInauffieient 4ateUaufflcieM aataInaufficient eat a

10 uf/L (ortaaaleptic)MO U|/L

<a) nt/L)(1.1 M/L)

4* M/L(l.S M/L)(M.OOO fibera/L)

(0..7 u|/L> 0.23 0.07(0.11 M/L)(J.» M/L)

10 M/L

0 (0.41 M/L) 0.1 0.02• (12 M/L) O.M2) 0.062S 0.007}

0 (21 M/L)110 M/L1JO M/LiMufficienc 4ate4M M/L

0 (O.M ut/L) Iaau((lcl«al eat a1* M/L 1.0• (0.4 u|/L>• (0.17 M/L)0 (2.4 M/L)Uaufficlea* 4ataIneufflclent e«taInaufficient 4ateInanfflclent data

(continued)

TAIL! 5-2. (continued)

ttk*f CtlltrU, M<l*«rl«>, M4 OoUMM*

CIM«U*I

••(• OrloklMtt*l*f 441,MCU (M/L•*!••••IktrvU* CltM 41 r *|l,

—— (M/« )

OI«MOr!«•/!• M*l«f

(•rCrllirlt

«ita» 0*1 y*

OrUkUoKllk A4*lMI

(lMf*rl«ra)

I•-•O

CkUrU«i*4 MI

4.4-Tfl«kUiark«Ml

Ckl.Milky 1-t-ikUtaplMMl

1.4 plckl»raH>«M»r«:«l Ic

•cU (1,4-0)

Cklor««lkyl «lk«r*

kl«- ( l Ckl*ia*lk rl> «lk«rkit (l-Ck

Chi era(«nl-cm>r»Ht*Ml

CkraaluM Cr»4Cr«l

Camper

O.I

0.01

Yl"

o.ot

onDlcklarokdiiH** (ill l(HBtlt)DUklnrakMiUlMtDlcklara«ck|rlt***

l,l-Oliklai»ilkyUM

04 M/L (•f|M*UHl<>

M/L1400 M/l• (I .I M/L)

I M/L («§••• .I M/L (ar|M*l«»ilc)04 M/L (•r|MMl*»llt)t M/L (ar|M»l«Ml<)t M/L (ai|«t*l«pllt)t M/L (ar|»«l«»lU)0 M/L (ar«MMliMl«)

10

1400 M/L• (I.I M/L)1000 M/L (•r|«Mli»llc>MOO M/L (•r|Hul*»lU)10 M/L (ar|«»aU>llt)

0 (O.OOM M/L)0 (M M/L>

0 (O.It M/L)O.I M/L (*t|«Ml«ptl*)tO M/L||g M/L1 M/L (•ro*Ml«Hl*)100 M/L0 (0.114 M/L>400 M/L0 (10.) M/L)

0 (II M/L)l*«u((UI*M 4<t«

0 (O.Ml* M/L)0 (M M/L)M.I M/L0 (O.I* yfl/L)O.I M/L (ar|MwU>lU)tO M/Ll»» M/L1 M/L (ar|Malt»ll«>MO M/L0 Ol.t M/L>410 M/L0 (10. > M/D

0 (11 M/L) 1.0 0.07iMvllltl**! *••!• 4.0 0.4 (ill l*o».r>

I.) O . l> (Ifmt l«o»»r)

(C(M|I*IM4)

c


applicable ar 1*1 avail ttaaulr«»aata Otkar Criteria, Advlaerlee, and Culdaace

Chemical

Dicklarometkaae2,4-BicklarapkeaalDlchloraprapaaea/Dickloraarepeoea

DicklarapraoaaeeDichloreareeeaaa

DieUria2.4-DimetkylpheaalX-4-OlaitiotolueMp-Oioxaae1 . 2-Diphcoylhyerealae(ndoaul f aaIndriatthylbeatee*llhyleae (lycalraneldekyderiuareatkeaeFluorideHalaetkeraHalcaietkaneaHeptacklarHexachl orobut ad ieae

Lindaae (MX (eama-HCH>alpha-He*beta-HCHlama-HCNdelie-HCHepailoa-UCH

Tachnical-MCHUexacklarocyclapealadieue

Safe DrUkiMHater Act,NCLe (M/L Cleaa Hater Act,ualeae Hater Quality Criteriaatkervlee Cleaa Air Act, for Huaaa Health —•ataAl «aA,qe (»»/•) liah am4 BtUhlM Hater

tee Kalomackaaea1.0* M/L

laaufficiaat date•7 M/L0 (0.071 at/L)400 u|/L (•rfaaaleptic)ft (ft. 11 u(/L>

0 (42 M/L>74 M/L

0.0002 1 ut/L1.4 M/L

42 M/L1.4-2.4

laeufflclent data(O.I* u|/L)(0.2* M/L)(O.M M/L>

O.OO4(*.2 M/L>(U.I a|/L)(It.t M/L)

laaufflcleat datalaaufflcleat dete0 (12.1 at/L)104 u|/L

Cleea Hater Act, Safe Driakiag Hater Act,Heter Quality Criteria Maaltk Advlaerlee

far Bumaa) lUaltk— (•£.'!.)adiuatad lar 1-day Jft-day Otroaic

•riaklM Hater Only (laagerterm)

•ee Halamatkeaee 11 1.1 O.li1.0* M/L

Uaufflcieat data17 u|/L0 (1.1 M/L>400 M/L (ar(aaaleptic)ft (O.tl ut/U

i.4i O.S6I0 (44 M/L)111 M/L1 ut/L2.4 M/L

l«.0 i.i0.01

IM u|/L

laaufflcieat data0 (O.I* M/L)0 (II a|/L)ft (ft.4t u|/U

0 (11 M/L)0 (21.2 M/L>0 (2t.4 M/L)Ia*ufflcleal detelaaufflcleat deta0 (17.4 M/L)206 u|/L

a-Haaaae•ydrocarbaoa (noa-metkana)laopharoneKeroaene/fuel oil aa. 2

160 (J-kour)*"1.2 i.J M/L

11 4.0

0.21

(continued)

TAIL! 3-2. (continued)

«f •*!•«••<

Ml*IU«« Ail,NOU (••/!.«•!•*•

Ual

M*lk«y«kl«rNclkyl likyl UIMM

Ui (M

Ml«4>

• .I

10.•

CUM Air Ail,MAOJ (>*/•>

1.1 (M-4.jk

100 (I-

•I It ••«•!•••

OiaiM III (l-k*yr)140 (14-kvtt*)'

f ••! « kl •(

••!•(•

Palr<klotU*l«4(Kit)

(FAMt)

01 Mr

CI.M NM*C Ail,U*l«r quilltf Cfll.fl.

!•« •>•«• •••Ilk--rl«k M4 BcUklH W«i*r

M ««/L144 *•/>•

11.4 <*/!.

11.4 .

11.410 «4/t

(1.4<•.•(4.4

4*14

lMI 4M«

<4.» «|/L(It «»/t)

1.01 M/l1.1 ••A

111 «/LIM M/tM W/LIt M/k

• (4.0M

0 (I.I M/L>

, A4*l*«rU«, «t4 0»I4«M

Ol**« H*l«f All,M*l*r 4v*lllf CdltrU

l*r •>••• •••lik—A4tv*l«4 IM

OtlMllM M«l*r tely

••!• IkiUklM W*l*r All,•••Ilk AtolMfU*

iM/kl1-4., l«-4«r OkrMl.

(I«i4*rI. rat

M «4/kU

M t.fM4«i*

11.4

II.• -4/L

11.4 «4/t

M 4««*

• (1.4• (0.4• (4.4• O.O• (14 H4/L)

1.01 M/LI.I «4/L

IM Bg/L4M *4/L44 «4/lII

• Oil.4 H4/D

• (1.1 ••/!•>

O.IH O.Olit


in

t->OJ

Applicable or laleventleauireMnta Otb*r Crit<ri«, MvirarU*. w4 Cuidmc*

Safe PrinkingHater Act.HCU tng/Lualeeeotherviae Clean Air

Clean Water Act,Hater Quality Criteria

for (Man Bealth—

Clean Hater Act,Hater Quality Criteria

for Huaan Health—

Safe Drinking Uatar Act,•ealth Adviaoriae

(•g/L)Chemical

tad iopucl ideatadiun-224 and 22SCroaa alpha activityTritiunStrantluarMOther •aa-made

SeleniumSilverSulfur d lorn id*

2,1,7,0-TCOOTetrachlaroethyleneThelllumTol ueneToBepheneTricbloroetbylene k

Trihala«tbenea (total)Viayl chloridelyleneeZinc

noted) NAAQS (»g/« )

} pCi/L1) pCi/L20.000 pCi/L0 pCi/L10.010.0} .

141 (24-hour/SO (l-yeor)*

0.00}

O.I

flak and Drinking Hater

10 ug/L50 ug/L

0 (0.000011 ng/L>0 (O.S ug/t)11 ug/L14.1 M/L0 (0.71 n«/L)0 (2.7 ug/L)

0 (2.0 ug/L)

} "g/L (organolaptlc)

Adiuatad farDrinking Water Only*

10 ug/L50 ug/L

0 (0.00010 ng/L>0 (O.SS ug/L)17.0 ng/L1} Bg/L

0 (2S.I vg/L)(I.I ug/L)

(2.0 ug/L)

} ng/L (organolaptlc)

1-day 10-day Chronic( longer

term)

2.1 0.17} 0.02

21. S 2.2 0.14

2.0 0.2 0.07)

12 1.2 0.42

*Tha*« adiuatad crltaria. for ariakini mtar la|aatla« only. Mr* darivad fro* publiahad IPA Uatar Quality Critaria (4} f« »»ll»-7«37*. No»a^ar 20.H60) for coabUad fiah aod drinkioc vatar intaatioa *ad for flab !•«••( 1<» alona. Itiaaa adjuatad yaluaa ara aot official IPA Uatar QualityCritaria. but nay ba appropriate far Super fund iitaa witb caataaUated (rouod «atar. la tba derivation of tbaae valuaa, iataka ttaa aaauaad to be 2litera/day for driakiog vatar aad 4.} f.ra«a/day for (i»kj buaaa body vei|ht ••• aaauaed to be 70 kilograM.

Criteria deai(aatad aa orgaaolaptic ara baaed oa teata aad odor effecta, actavailable for tbeaa cbealcala.

buaiaa baaltb affect a. •ealth-baaad Water Quality Criteria ara not

c —4Th« criterion for all carcioogeaa la ««ro; the caoceatratlon givea if pareat^eaea correapooda to • carcinogenic riak of 10 . Hater Quality ,

Criteria docmMata preaant coacentrationa raaultlog In riaka from I0~ to 10 . to obtain concentrationa correaponding to rlaka.ot 10. aad 10* .the 10 concentre!lone ebould ba multlpliad by 100 and 10, reapactively. To obtain concentrationa correapanding to rlak of 10 , 10cooceatretiona ebould be divided by 10.

(coatinued)

TABU 5-2. (continual!)

W •*t*»4m4 mult lka« MX* act yaal.

'Chlurufaio !• ana al lour if IkaluMihama uhaaa •«• •••««»Cf«cl«« KMI kt !••• HMD O.I w|/L.

*• • guH« In 4«vl<lng l>|«l«Miil«llaii pl«n> lor (chUoIng *i

*i»««n-«l«ir k«lili >4»l»uiy luf Wn««M «>4 k*ma(()pyi«B« In

fcAnnual aililiaiilc ««in conc.nl KI Ian.

Annw.l |cu>Mllltf BaAn &uMc«i«lr«l Iwi.

' «"> Inl.ttl.l «cg>« 4

TuKl n lti«lu««ili«n«« i«(«ii la llw >•«• conr.ntcd Ian al ckleiafala, kiaaa4lchlvraa«lk<lM , 4lb(ojucMut««lh4n< , ami kliwuto

(

S»/ 3. Those that exceed applicable or relevant standards, as appropriate;

4. Those that do not attain applicable or relevant standards but willreduce the likelihood of present or future threats to public health;and

5. A no action alternative.

In completing the public health evaluation, the extent to which eachalternative attains or exceeds relevant or applicable standards, criteria,advisories, or guidance should be carefully documented. If no relevant orapplicable standards exist, all of the alternatives will fall in categories 1,3, and 5 above. Chapter 4 also discusses five specific circumstances that mayexist which would justify selection of an alternative in the fourth categoryabove, even if relevant or applicable standards do exist. The analysis of analternative in the last category must be carefully documented.

i rf^^ 5.4.1 Assumptions Underlying Applicable and Relevant Standards

Since the applicable and relevant standards in Table 4-1 and 5-2 weredeveloped under a variety of statutes, many incorporate economic or scientificfactors that do not match specific conditions at a CERCLA site. For example,the standards generally do not consider simultaneous exposures from multiple

^ ^ routes. Standards may also be based on different levels, durations, orf pC . frequencies of exposure than are likely at a specific site. The assumptions

underlying the Tables 4-1 and 5-2 standards that are most frequently relevantand applicable at Superfund sites are discussed briefly in the followingsections.

5.4.2 Resource Conservation and Recovery Act Hazardous WasteRegulations (40 CFR 264)

Portions of these regulations include technology based requirements forground-water protection, closure and post-closure actions, surface impound-ments, waste piles, land treatment, landfills, and incinerators. In somecases, these requirements may not be applicable or relevant to specific siteconditions such as in the cases where 200 miles of roadway shoulder wascontaminated with PCBs, or where acres of forest were sprayed with wastesubstances. In other cases, these regulations require meeting public health-based standards (either background, SDWA Maximum Contaminant Levels, orAlternate Concentration Limits) as cleanup standards for corrective action.The background and MCL standards may be used directly in developing a remedialalternative. An ACL, however, requires a demonstration that concentrationshigher than an MCL will not be adverse to human health or the environment.The EPA Office of Solid Waste is revising its ACL guidance. In the interim,it is advisable to consult with OSW or OERR headquarters staff to determinewhether an ACL is an appropriate standard to pursue.

5-15

5.4.3 tot ion* I Interim Primary Drinking Water Standards (HIPPWs) andMaxisnai Contaminant Levels (MCLs)

Standard* aider Che Safe Drinking Water Ace are promulgated as MCLs,which represent Che al lovable level* in public water systems. As a matter ofpolicy, CT1CLA will also use them for other drinking water exposures. Theyare generally based on lifetime exposure to the contaminant for a 70-kg(154-pound) adult who consoles 2 liters (0.53 gallons) of water per day. Thetotal environmental exposure to contaminants was generally considered incalculating specific MCLs. EPA estimated the amount of the substance to whichChe average person is likely to be exposed from all sources (air, food, water,etc.), and then determined the fraction of the total intake from drinkingwater.

In addition to addressing health factors, an JCL is required by lav toreflect Che technological and economic feasibility of removing Che contaminantfrom the water supply. The limit set must be feasible given thebest available technology and treatment techniques . A margin of safety isincluded in each of the standards. Safety margins vary from chemical Cochemical because of the very different risks associated with each. EPA is nowdeveloping recommended ICLs (RICLa) for drinking water based entirely onhealth considerations.

5.4.4 national Ambient Air Quality Standards (HAAQS)

In developing HAAQS, all sources of exposure to the contaminant (food,water, air, etc.) are considered in determining the health risk. In addition,by statute, HAAQS must be based exclusively on the air quality criteria issuedby EPA for each air pollutant. The Clean Air Act does not require EPA toconsider the economics of achieving the standards or the technological feasi-bility of implementing them. Standards can be promulgated as annual maxianau,annual geometric means, or annual arithmetic means, or for other time periodsfrom one hour to one year, depending on the pollutant.

Primary standards must allow an adequate safety margin for unidentifiedhazards and effects, chough no rule is used in setting this margin. The lawrequires EPA co direct ics attention to particularly sensitive citizens, suchas bronchial asthmatics and emphysematics. In developing primary HAAQS, EPAmust specify Che nature and severity of the health effects of each contami-nant, characterize the pertinent sensitive population, determine probableadverse health effects for this population, and estimate the level below whichan adequate safety margin reduces or eliminates risks. Primary HAAQS thusdepend mainly on Che direct health effects of chemicals to sensitive groupscalculated according co scientific data.

5-16

5.4.5 Federal Water Quality Criteria and State Water Quality Standards

Federal water quality criteria for protecting human health now cover62 of 65 classes of toxic pollutants. The health assessment criterion is anestimate of the ambient surface water concentration that will not result inadverse health effects in humans, or, in the case of suspect or provencarcinogens, the concentrations associated with incremental cancer risks.The Federal criteria are unenforceable guidelines and, therefore, arelisted as other criteria to be considered in Table 4-2. However, manyStates have used these criteria in developing enforceable ambient waterquality standards. These State standards are considered applicable andrelevant to Superfund remedial actions for surface water situations thatinvolve either drinking water or fish ingestion exposure routes.

Water quality standards establish goals for specific water bodies andalso serve as the regulatory basis for water quality-based controls beyondthe technology-based levels of treatment required by sections 301(b) and 306of the Clean Water Act. Water quality standards are adopted by States (or,where necessary, promulgated by EPA) to protect the public health or welfareand enhance water quality. A water quality standard consists of two mainparts: (1) specification of designated use (or uses) that considers thewater body's value for public water supplies; propagation of fish, shell-fish, and wildlife; recreational use; navigation; and agricultural, indus-trial, and other purposes; and (2) criteria specifying numerical limits orother factors necessary to protect the designated use.

States must adopt water quality standards stringent enough to protectdesignated uses. Numerical criteria may be based on EPA recommendations oron other scientifically defensible methods. States may also modify EPA1srecommended criteria to reflect local environmental conditions and humanexposure patterns. When a criterion to protect human health must be devel-oped for a chemical that has no national criterion, the user should consultEPA Headquarters for assistance. The latest guidelines for deriving health-related water quality criteria are published in 45 FR 79341 (November 28,1980). Guidance (unpublished) on modifying human health criteria may befound in the JRB Associates (1982) report "Suggested Protocol by WhichStates Could Recommend Surface Water Quality Criteria for Specific WaterBodies for the Purpose of Protecting Human Health" (EPA, Office of WaterRegulation and Standards). In general, the user will be directed towardspecific risk level ranges as described in section 5.7.

States with specific numerical ambient standards for toxics includeArizona, Arkansas, California, Colorado, District of Columbia, Delaware,Florida, Idaho, Kentucky, Louisiana, Maine, Maryland, Mississippi, Nevada,New Hampshire, New Jersey, New York, North Carolina, North Dakota, Ohio,Oklahoma, Oregon, Puerto Rico, South Dakota, Virginia, and West Virginia.Appropriate agencies in other states should be consulted to determine ifstandards have recently been adopted.

5-17

For most chemicals , Federal water qual icy criteria to protect humanhealth are available for cwo different exposure pathways. One criterion isbased on ingest ion of both drinking water and aquatic organises, and tneother is based on ingest ion of aquatic organisms alone. The criteria cal-culations incorporate the assumption that a 70-kilogram adult consoles 2liters of water and/ or 6.5 grams of aquatic organisms daily for a 70-yearlifetime. Of course, calculations can be made to derive an adjusted cri-terion for drinking water ingest ion only, based on the two publishedcriteria and the same dose assumptions. Table 5-2 lists these adjustedcriteria by chemical, along with the published criteria for combineddrinking water and aquatic organism ingest ion. The adjusted criteria aremore appropriate for Super fund sites with groundwater contamination becausethe criteria are based on a more realistic exposure assumption.

5.4.6 PCBs

Soperfund remedial actions should consider EPA's current draft PCBcleanup policy currently under development by the Office of Pesticides andToxic Substances under authority of the Toxic Substances Control act (TSCA).Headquarters should be consulted to determine the impact of this policy onspecific EI/FS projects. All disposal of PCBs must be in accordance withthe PCB disposal and labeling regulations (40 C7R 761).

5.5 CONSIDER OTHER CRITERIA AID ADVISORIES

Tables 4-2 and 5-2 list other criteria, advisories and guidance thatshould be considered in the development and evaluation of alternatives.

5.5.1 Criteria for Soncareinogens

On the basis of a survey of the coxicological literature, EPA hasdeveloped a "no observed adverse effect level" (ROAEL) for many chemicals.The XUELs are usually based on animal studies, although human data are usedwherever available. Safety factors are then applied to account for theuncertainty in using available data to calculate huaan effects resulting inan acceptable daily intake (ADI). Criteria (e.g. , water concentrations) arederived from the ADIs and the standard dose assumptions given above.

5.5.2 Criteria for Carcinogens

The same exposure pathways and dose assumptions are used for carcino-gens as for noncarcinogens. A literature search of human and animal car-cinogenic effects forms the basis for EPA's estimate of the risk posed bypotential human carcinogens. There is no scientific basis for estimating

5-18

"safe" levels of carcinogens because there is no way at present to establisha threshold for carcinogenif effects. Criteria for all carcinogens statethat the recommended concentration for maximum protection of human health iszero. EPA has also estimated water concentrations corresponding to incre-mental risk levels using a linear, nonthreshold extrapolation model.Extrapolation models provide only an estimate of risk, but are the bestavailable tool for describing the potential threat of a substance, givencertain assumptions. In its criteria, EPA provides water7concentrations_-corresponding to incremental lifetime cancer risks of 10 ,10 , and 10

5.5.3 Health Advisories (SNARLs)

In addition to MCLs, EPA also provides drinking water suppliers withguidance on chemicals that may be intermittently encountered in water sys-tems and are believed to pose a near-term risk, yet are unregulated indrinking water. These guidelines are developed by the Office of DrinkingWater in the form of health advisories or SNARLs. Health advisories are notmandatory. They are calculated to reflect the consumption and toxicologicalcharacteristics of a 10-kg child (1-year-old infant) who consumes an esti-mated 1 liter of water daily. SNARLs are calculated for three exposurelevels: 1 day, 7 or 10 days, and for a longer term (weeks or months). Asafety margin is factored in to protect the most sensitive members of thegeneral population. However, SNARLa ignore carcinogenic risks and synergis-tic effects of chemicals. SNARLs for certain chemicals contain carcinogenicrisk estimates that can be used when appropriate.

5.6 ADJUSTMENT OF STANDARDS AND CRITERIA

As a result of various technical aspects of standards development, someconcentration limits will require adjustment before being applied to a spe-cific site. The first step is to determine whether each concentration limitis directly applicable or must be adjusted for the specific site conditions.As an illustration of this, water quality criteria, which were developed forsurface water, can be adjusted for ground water by recalculating andexcluding the assumption of fish ingestion (as in Table 5-2). Additionalguidance on adjusting standards for specific sites is under development.

5.7 UNAVAILABLE OR INAPPROPRIATE STANDARDS

As Table 5-2 shows, relevant or applicable ambient concentration limitsare not available for all media for many chemicals commonly found atSuper fund sites.

Where no relevant or applicable standards are available, the usershould consult headquarters on a case-by-case basis for further guidance.In general, headquarters will instruct the user to develop at least one

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option that corresponds to a 10 risk level. In addition, the user will beinstructed to develop reasonable alternatives chat correspond to a 10 co10 risk level. The specific manner of presentation of exposure and risklevels will be in accordance with Agency guidelines (OSEPA, 1984a-f).Further, it may be necessary for headquarters to request review by otherprogram offices to determine the appropriate response.

Guidance on risk assessment is under development for Chose situationswhere relevant or applicable standards are not available for every chemicalof concern. The guidance will specify procedures for both carcinogens andnon-carcinogens, and will address the issue of chemical mixtures.Furthermore, the guidance will specify the risk range that alternatives willbe designed to meet.

S.8 SDMIAIY OF PUBLIC HEALTH EVALUATTOH

A nimmii j of the public health effectiveness must be presented for eachalternative analyzed. This includes an evaluation of the extent to whicheach alternative attains, exceeds, or falls short of applicable or relevantenvironmental standards. Where these are not available, the analysis formanagement of migration alternatives should evaluate the risks of variousexposure levels projected or remaining after implementation of chealternative under consideration. Table 5-3 presents key questions to besummarized in quantifying che public health effects associated with eachalternative. The summary presentation is also addressed in chapter 8.

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TABLE 5-3. SUMMARY OF KEY PUBLIC HEALTH EVALUATION QUESTIONS

A. Technical issue*

1. What technologies will minimize or preventexposures otherwise expected at the site?

2. What chemical releases will be minimized orprevented by the remedial action?

3. What chemical releases will not be minimized orprevented?

4. Over what time will chemical concentrations bereduced at receptor locations, e.g., on-aita, atdrinking water intakes, in ambient air, etc.?(Be as specific as possible, providingqualifications if necessary.)

B. Exposure issues

1. What exposure is expected during the remedialaction?

2. What exposure is expected after the remedialaction?

3. What relevant and applicable standards will bemet/not met?

4. What other criteria, guidance or advisories willbe met?

5. What adjustments were made to standards,criteria, advisories, or guidance?

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CHAPTER 6

EVALUATE ENVIRONMENTAL IMPACTS

la developing and evaluating response alternatives, a major concern isadequate remediation and protection of the environment. The National Oiland Hazardous Substances Contingency Plan (NCP) requires, in section300.68(i)(2)(D) :

An assessment of each alternative in terms of the extentto which it is expected to effectively mitigate andminimize damage to, and provide adequate protection of,public health, welfare, and the environment, relative tothe other alternatives analyzed....

Section 300.68(i)(2)(E) requires:

An analysis of any adverse environmental impacts, methodsfor mitigating these impacts, and costs of mitigation.

This chapter provides guidance for preparing the environmentalassessment of proposed remedial alternatives. Generally accepted methods ofenvironmental analysis will be appropriate for many hazardous waste sites,but unique conditions may require innovative procedures. The evaluation ofalternatives should be performed by persons with expertise in the environ-mental sciences and should be based on the best available data and evalua-tion techniques appropriate for the particular site and the alternativesbeing addressed.

Environmental contamination is often widespread and may originate fromseveral sources. The environmental assessment should focus on the siteproblems and pathways of contamination actually addressed by the alterna-tives identified through screening. The environmental assessment will helpdetermine which remedial alternative(s) will achieve adequate protection andimprovement of the environment at those sites where environmental damage isan important consideration. A detailed analysis of environmental effectsneed not be performed when they are not within the scope of those alter-natives. However, any known environmental problems not addressed by theremedial alternatives should be clearly described.


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6.1 OVERVIEW OF THE EHVI&OHMEHTAL ASSESSMENT

AD environmental assessment of che "no-act ion" alternative should beperformed for all sites. This environmental assessment describes thecnrrenc site situation and the environmental conditions anticipated if noemergency or remedial actions are taken. The assessment should (1) deter-mine the value (or uses) of the areas that are contaminated or threatenedwith contamination, (2) identify the types of impacts chat are likely, and(3) assess the general significance of the impacts.

The user can forego detailed analysis of the adverse effects of anyremedial alternatives mder consideration if Che preliminary analysisconducted during the screening stage shows that implementation will notresult in any of the following:

• A substantial increase in airborne emissions

discharge to surface or ground waters

• An increase in the volume of loading of a pollutant from existingsources or a new facility to receiving waters

• Known or expected significant adverse effects on the environment oron tnman use of environmental resources

• Known or expected direct or indirect adverse effects on environ-mentally sensitive resources or areas, such as wetlands, prime andunique agricultural lands, aquifer recharge zones, archeological andhistorical sites, and endangered and threatened species.

The above criteria are based on the concepts of categorical exclusion asprovided for in the National Environmental Policy Act and subsequentregulations (40 CFR 1508.4; 40 CFR 6.107, 6.506) and the provisions for afinding of no significant impact (40 CFR 1508.13), which exempts Federalagencies from preparing an Environmental lapact Statement. If analternative will not result in significant adverse impacts and, therefore,does not require preparation of a detailed environmental assessment ofadverse effects, a statement should be prepared chat doctmients that findingand summarizes the supporting reasoning.

6.2 EVALUATE ALTERNATIVE 8ESPOHSES

The environmental assessment should address the effects of eachledial alternative under consideration, including long-term and short-term

effects. The level of detail in che environmental assessment should dependon the degree of actual or potential damage co che environment providing theimpetus for response. The appropriate level of detail will be determined bythe user but should be adequate to compare che expected environmental

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benefits of different alternatives meaningfully and to determine the extentof the impacts of remedial construction and operations. Such informationshould assure the public and EPA that the impacts of remedial measures arenot significant or result from the only viable option, and should identifyproblem areas and suggest measures for mitigating adverse impacts.

Factors generally considered in determining the detail demandedinclude the following: (1) effects on environmentally sensitive areas,(2) violation of environmental standards, (3) short' and long-term effects,and (4) irreversible commitments of resources.

Findings should be presented to allow comparing the environmentaleffects of alternatives. Environmental effects of remedial actions mayinclude a wide range of effects, including hydrology, geology, air quality,biology, socioeconomics, land use, and archeological and historical sites.In general, each alternative should be evaluated by considering suchbeneficial effects of the response as changes in the release of contaminantsand final environmental conditions, improvements in the biologicalenvironment, and improvements in the resources that people use. Expectedadverse effects of remedial construction or operations should also beconsidered in addition to the effects of the final remedy. Each of thesetopics is discussed further below.

The evaluation should discuss both primary and secondary effects of theremedial action. Primary effects of the remedy are direct adverse or bene-ficial results and are generally associated with the immediate reason fortaking action at the site. Direct adverse effects may result from construc-tion activities, from stabilization following completion of the construc-tion, or from long-term remedial activities. Indirect adverse or beneficialresults of the alternative, such as effects on the economy of the area or onmigration patterns, generally should not be discussed unless specialcircumstances affect environmental impacts.

6.2.1 Beneficial Effects of the Response

6.2.1.1 Changes in the Release of Contaminants and FinalEnvironmental Conditions

The user should estimate the effects of remedial measures in terms ofthe concentrations of contaminants in each environmental medium of concern,both during and after these measures, and the time required to reach desiredlevels. These evaluations should be the same or similar in content andclosely coordinated with those for technical performance and implement-ability, discussed in chapter 3.

Federal legislation and regulations relevant to assessing environmentalimpacts were discussed in chapter 4, notably the Clean Water Act; MarineProtection, Research, and Sanctuaries Act; the Clean Air Act and the

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Hational Environmental Policy Act. The regulations under these Aces canprovide benchmarks to evaluate current or anticipated environmentalconditions.

The ambient residual contamination predicted for different remedialalternatives should be compared to existing criteria and standards. How-ever, available environmental criteria and standards may not always besuitable for direct comparison. The user should determine if Che siceconditions are substantially different from those used to calculate Checriteria. If they are, the criteria should be adapted to actual sice con-ditions. The user should consult with Federal and State agency personnelwho have expertise in modifying criteria or in determining criteria forsubstances chat had none. The following sections summarize criteria thathave been developed or can be obtained by consultation with Federal andScace officials.

Surface Wacer. Wacer quality standards establish goals for specificwacer bodies and also serve as the basis for water quality-based controlsbeyond the technology-baaed levels of treatment required by sections 301(b)and 306 of Che Clean Wacer Act. Wacer quality standards are adopted byStates (or, where necessary, promulgated by EPA) to protect Che publichealth or welfare and enhance the quality of the water. A wacer qualitystandard consists of two main parts: (1) a specification of designated use(or uses) chat considers the wacer body's value for public wacer supplies;propagation of fish, shellfish, and wildlife; recreational use; navigation;and agricultural, industrial, and other purposes; and (2) criteria specify-ing numerical limits or ocher factors necessary to protect the designated

States muse adopt water quality criteria stringent enough Co protectChe designated uses. Table 6-1 identifies States with water quality stan-dards by type of standard. Numerical criteria may be based on EPA recom-mendations or on other scientifically defensible methods. States may alsomodify EPA's recommended criteria and sec sice-specific criteria where (1)background wacer quality parameters, such as pH, hardness, temperature, andcolor, appear Co differ significantly from the laboratory wacer used indeveloping EPA's recommended criteria, or (2) the types of local aquaticorganisms differ significantly from chose actually tested in developing theEPA's recommended criteria or have adapted co higher pollutant levels.Guidance on modifying national criteria on aquatic life is found in the"Water Quality Standards Handbook" (EPA, December 1983) and the "DraftTechnical Support Document For Wacer Quality-Based Toxics Control" (EPA,Office of Wacer Regulation and Standards, November 28, 1980). When acriterion muse be developed for a chemical for which a national criterionhas aoc been established, the user should consult EPA headquarters forassistance. Guidelines for developing water quality criteria for aquaticlife are published in 45 Ft 79341 (November 28, 1980). Revisions to theseguidelines have been proposed; see 49 FR 4553 (February 7, 1984).

The revised water quality standards regulation (see 40 CFR 131; 43 FR51400, Sovember 8, 1983) emphasizes criteria for toxic pollutants in State

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TABLE 6-1. AVAILABILITY OF STATE AMBIENT WATER QUALITY CRITERIAOR STANDARDS FOR TOXIC SUBSTANCES

State

Freshwater Criteriaor Standards(Numerical)

Saltwater Criteriaor Standards(Numerical) Comments

AlabamaAlaskaArizonaArkansasCalifornia

ColoradoConnecticutDelawareDistrict ofColumbia

FloridaGeorgiaHawaiiIdahoIllinoisIndianaIowaKansasKentuckyLouisiana

MaineMarylandMassachusetts

XXX

X

X

XX

Numerical criteriaare effluentlimits for totalchlorinatedpesticides, PCBs,and radioactivity

Adopted 304(a)guidance

Currently revisingWQS to includenumerical criteriafor freshwater

(continued)

Includes both organic and inorganic contaminants.Narrative "free-form" toxics criteria for freshwater and saltwater areavailable for all states.

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TABLE 6-1. (continued)'

State

Freshwater Criteriaor Standards(BuBerical)

Saltwater Criteriaor Standards(Numerical) Comments

MichiganMinnesotaMississippiMissouriMontanaBebraskaBevadaSew Hampshirelew JerseyBew Mexico

IIZX Criteria are only

for rivers thathave drinkingwater use desig-nations

YorkBorth CarolinaBorth DakotaOhioOklahomaOregonPennsylvaniaPuerto RicoXhode IslandSouth CarolinaSouth DakotaTennesseeTexasUtahVermontVirginiaWashingtonVest VirginiaWisconsinWyoming

XXXXX

X

X

X

X

X

X

.Includes both organic inorganic contaminants.Barrative "free-form" toxics criteria for freshwater and saltwater areavailable for all states.

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standards as the basis for permit limitations under the National PollutantDischarge Elimination System. Most State standards do not include numericalcriteria for many toxic chemicals. When standards do not specify criteriafor toxic chemicals, guidance documents on criteria or literature reportsare used. All States have a general narrative requirement in their waterquality standards that their waters must not contain toxic substances intoxic amounts. Most State standards include a narrative criterion for fishand wildlife designated uses that applies after mixing and requires nochronic toxicity to representative test organisms. These State standardstypically include application factors for deriving a discharge chronictoxicity value from an acute toxicity value (i.e., 0.05 for nonpersistentwastes and 0.01 for persistent wastes).

Ground Water. The ground-water policy discussed in chapter 4 providesguidance but not specific ground-water criteria. The user should consultguidance documents appropriate to ground-water protection when they becomeavailable from OGWP.

Soils. Two general types of threats should be considered whendeveloping criteria for soils: (1) direct contact by intruders onto thesite, and (2) contamination of other environmental media by the soils.Unfortunately, there are no currently promulgated environmental criteria orstandards for contaminants in soils, except PCB-contaminated soils, whichare subject to TSCA limits. However, procedures for closing existing land-fills under RCRA may provide relevant approaches. Also, action levels suchas the 1 ppb limit for dioxin established by ASTDR for the Minker Stout sitein Missouri may provide further guidance.

Air. Hazardous air pollutants at sites create a serious threat toworker health and safety during investigations and remedial action. Seriousair pollution may also result from migration of toxic gases to the surround-ing environment and nearby populations. In most instances, a serious airpollution problem would have an impact on public health.

Guidance on source emissions can be obtained from section 112 of theClean Air Act, which defines an ambient hazardous air pollutant as a sub-stance emitted by a stationary source ("any building, structure, facility,or installation which emits or may emit any air pollutant") that, accordingto EPA, "causes, or contributes to, air pollution which may reasonably beanticipated to result in an increase in mortality or an increase in seriousirreversible, or incapacitating reversible, illness." EPA is also requiredby the 1977 Clean Air Act amendments to review the primary and secondarystandards for major criteria pollutants. Users should consult these crite-ria whenever such pollutants are released into the atmosphere from the site.

When commercial crops are threatened by airborne substances somemeasure of the air quality should be developed to take account of cropdamage. The National Crop Loss Assessment Network gathers data on therelationships between yields of major agricultural crops and exposure tosubstances like sulfur dioxide.

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6.2.1.2 Improvement in cbe Biological Environment

The user should describe Che remedial alternatives' likely improvementsin Che biological environment. An uncontrolled waste site often threatensnearby biological communities, for example, by changing the ecological•truetore that supports organisms. The ability of alternatives to reduce oreliminate such threats snould be clearly seated.

The user should note the benefits of Che alternative, especially withregard to:

• Sole source aquifers

• Wetlands

• Floodplains

• Coastal zone

• Critical habitats

• Prim* agricultural lands

• Federal parklands

• national forests

• Wildlife sanctuaries and refuges

• Habitat productivity.

Discussion of these areas can be found in regulations protecting themand in research reports. However, in many cases the user is urged to con-sult with Che relevant Federal, State, local fish and wildlife agencies, anduniversities for more specific information.

Sole Source Aquifers. A sole source aquifer is designated undersection I424(a)(l) of the Safe Drinking Water Act as being the sole orprincipal drinking water source for an area and, if contaminated, a signif-icant hazard to public health. EPA has now designated 17 sole sourceaquifers and is considering petitions for other areas.

Wetlands. Wetlands are areas inundated or saturated by surface wateror ground wacer frequently and persistently enough to support vegetationadapted to saturated soil. Wetlands generally include swamps, marshes,bogs, and similar areas, and may be defined by referring to U.S. Fish andWildlife Circular 39 (1956) and later revisions resulting from the RationalWetlands Inventory. A wetlands assessment must be conducted as part of thefeasibility study. EPA is preparing a formal policy for conducting wetlandsassessments at Superfund sices. Information on environmental stress andremedial actions for wetlands can be obtained from the U.S. Department ofthe Interior, the U.S. Department of Commerce, the U.S. Army Corps ofEngineers, and appropriate State offices.

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Floodplains. One-hundred-year floodplains are designated on FloodHazard Boundary Maps and Flood Insurance Race Maps prepared by the U.S.Department of Housing and Urban Development. The user should include aflood assessment if the site is on or near a floodplain. EPA is preparing aformal policy for conducting floodplains assessments at Superfund sites.Information on floodplains can be obtained from the Federal InsuranceAdministration, the Federal Emergency Management Agency, and appropriateState agencies.

Coastal Zones. Coastal zones are areas subject to management plansunder the Coastal Zone Management Act. Information on the effects ofreleases on coastal zones can be obtained from the Department of Commerceand from State agencies with management responsibilities under the CoastalZone Management Act.

Critical Habitats of Threatened or Endangered Species. The Secretaryof the Interior has determined that certain habitats are critical to thecontinued existence of threatened or endangered species listed under section4 of the Endangered Species Act of 1973. Information about effects ofreleases on threatened and endangered species and critical habitats can beobtained from the Department of the Interior, the Department of Commerce,and State fish and wildlife agencies.

Prime and Unique Farmland. The Department of Agriculture's SoilConservation Service (SCS) must keep an inventory of important farmlands(7 CFR 757.5). Prime farmland has the best combination of physical andchemical characteristics for producing food, feed, forage, fiber, and oil-seed crops. It is also available for pasture, range, and forest land.Unique farmland produces specific high-value food and fiber crops. If theuser suspects that prime and unique farmlands are threatened by a site'scondition, he or she should contact the State SCS office to verify thefarmland's status. Any beneficial effects on such areas should be includedin the feasibility study.

Federal Parklands. Federal parklands are areas of recognized scenic,recreational, archeological, or historical value. As required by regula-tion, when the resource affected is designated by the Federal government,the Federal management agency responsible for the area should be consulted.Designated areas included are national parks, national wilderness areas,national recreational areas, national wild and scenic rivers, nationalhistoric places, national natural resource areas, and national wildliferefuges.

National Forests. If a site's condition threatens national forestland, the user should consult the U.S. Forest Service at the Department ofAgriculture. The Forest Service is required by the Forest and RangelandRenewable Resources Planning Act of 1974 and the National Forest ManagementAct of 1976 to prepare Federal and regional management plans. The usershould note the effects of remedial activities on these plans.

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Wildlife Sanctuaries and Refuges. Various land management systfprotect wildlife sanctuaries and refuges. Public lands are managed by theBureau of Land Management, the U.S. Fish and Wildlife Service, the NationalPark Service, the Water and Power Resources Service, the U.S. ForestService, and the National Oceanic and Atmospheric Administration. Publicsanctuaries and refuges are identified in the following systems:

• National park system

• National wildlife refuge system

• National wilderness preservation system

• Wild and scenic river system

• National trail system

• Marine and estuarine sanctuaries program.

State, local, and private sanctuaries should also be considered. Fish andwildlife agencies are good sources of information.

Habitat Productivity. The productivity of the habitat of acommercially or recreationally important species can be threatened by thedischarge from an uncontrolled site. Such reduction in productivity cantake various form*:

• Loss of species

e Change* in their relative abundance

• Change* in their sizes

e Change* in their age structure.

In such cases, the user should note the species and their habitat* anddiscuss the improvement expected from each alternative. The user may wishto consult the EPA STORET water quality file for data on water qualityindicator substances. States often have standards for specific habitats andharvesting area*. The user should consult the appropriate public health andfish and wildlife agencies.

6.2.1.3 Improvements in Resources People Use

Often an uncontrolled site damages or threatens to damage resourcespeople use. Many of these resources, such aa fishing waters and recreation-al area*, directly affect the welfare of local communities. Users shouldnote the ability of alternatives to protect present or potential human usesof resource*, especially commercial, residential, recreational, esthetic,and cultural uses.

trcial Uses. Many environmental resources at sites provideimportant goods and services traded in the marketplace. Commercially

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harvested fish are one example (public health concerns also arise in thiscase because fish is a food). Tackle shops, boat rentals, and hotels canall be affected by deterioration in the environment supporting their goodsand services. Sometimes commercial crops are threatened by airborne sub-stances from a site, such as sulfur dioxide and ethylene. The user shouldconsult the National Crop Loss Assessment Network to determine the alter-natives' likely improvements. Ground water is a natural resource supportingcommercial activities, such as irrigation and water use at commercial facil-ities. When such activities are affected by the loss or reduction of groundwater from discharges at the site, the benefits of the alternatives for com-mercial activities should be noted.

Residential Uses. Unpleasant physical impacts of the site—such ascurtailment of water supply, unpleasant odors, loss of property values,disruption in living patterns, outward migration, and loss of employment-are important considerations in determining the desirability of the remedialalternatives. The user should evaluate the effects of site remediation onresidential land use.

Recreational Uses. Response alternatives can improve recreationalactivities by restoring the environmental resource damaged by the discharge.Open beaches, public waterways, and lakes are among the resources forhunting, fishing, birdwatching, swinning, and camping. Standard parametersmeasuring recreational uses are number of visitors, number of visitor days,crowd densities, number of licenses, and average catch.

Esthetic Uses. Many environmental resources are appreciated for theiresthetic value, which can be impaired either by a discharge or by theresponse to it. Esthetic value is a subjective matter, and the users ofthis manual should not be encumbered with an in-depth study of siteesthetics. The user's own judgment supported by consultation with localcommunity associations should determine the extent of concern.

6.2.2 Adverse Effects of the Response

6.2.2.1 Expected Effects of Remedial Alternatives

The user should identify and evaluate any expected adverse effects ofremedial construction and operations. In identifying these effects, theuser should especially consider sensitive environmental areas and resourcespeople use. The user should distinguish inevitable effects from possibleones, so that the evaluation of alternatives can estimate the probability ofexpected adverse effects. Equally important is recognizing that someeffects are irreversible. The users should state that effects are rever-sible or irreversible if they are significant.

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6.2.2.2 Mitigative Measures

If any alternative appears to have significant inevitable or irreversi-ble effects, the user should state the mitigative measures to be taken inconjunction with the alternative, the statement should discuss the tech-nology to be employed and its expected mitigating effects (e.g., percentagereduction in adverse effects). It is generally assumed that mitigatingmeasures will not affect the success of remedial alternatives. If successmay be compromised by the mitigative measure, the user should note this.

6.3 OTHER ASSESSOR PROGRAMS

The user can obtain assistance in developing an assessment program byconsulting information on other environmental damage assessment procedures.These procedures have been developed by State and Federal agencies chargedwith protecting environmental resources. Most have been field tested andreflect the need for applicability rather than the higher methodologicalrigor characteristic of research. An important element in these proceduresis selecting assessment methods that can be used given available time andresources. The following references may be particularly useful:

• Department of Ecology, Washington State, "Guideline for EvaluatingFreshwater Resources Damages," 1980.

• Rational Oceanic and Atmospheric Administration, "Marine ResourceDamage Contingency Plan," U.S. Government Printing Office,Washington, D.C., 1980.

• U.S. Fish and Wildlife Service, "Habitat as a Basis for Environ-mental Assessment," Ecological Service Manual 101. U.S. GovernmentPrinting Office, Washington, D.C., 1980.

• Department of Fishery, Washington State, "Marine Water QualityCompendium of Washington State," 1979.

• State of Alaska, "Alaska Oil Spill Status Booklet," 1982.

• Battelle Pacific Rorthwest Laboratory, "Field Guide for ScientificSupport Activities Associated with Superfund Responses," Battelle

>rial Institute, 1979.

6.4 SUMMARY OP EBYIROmWEFTAL ANALYSIS

The output format suggested here condenses the discussion of alter-natives to five composite criteria. The format is illustrated in Table 6-2.

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c

TABLE 6-2. SUGGESTED SUMMARY FORM FOR USE BY THE ENVIRONMENTAL SECTION

TO EVALUATE REMEDIAL ALTERNATIVES

Beneficial Effects Adverse Effects"

Final |Mprove«ents In laprovements In Const/Operation Mltlgatlve MeasuresEnvironmental Biological Hunan Use

Alternative Conditions Environment Resource

1st2nd3nd4th

Indicate whether adverse effects are expected to be reversible, or Irreversible over tleie.

The relative desirability of each alternative should be described with "**-*'respect co each of the evaluation criteria. The user may choose to describethe alternatives in order of cheir relative desirability with respect toeach criterion, or to describe the* on an absolute basis according to thedegree to which they fulfill each criterion. Whichever Method is chosen,the uaer should provide a consistent 'discussion of each alternative.

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CHAPTER 7

CONDUCT A DETAILED COST ANALYSIS

This chapter outlines the recommended approach to developing andanalyzing costs for each of the remedial action alternatives remaining afterinitial screening (see chapter 2). EPA is developing a "Remedial ActionCosting Procedures Manual" which presents more detailed costing procedures.The object of the costing exercise is to develop.cost estimates for alter-natives, as specified in section 300.68(i)(2)(B)L of the NCP:

(1) Detailed Analysis of Alternatives

(1) A more detailed evaluation will be conducted of the limitednumber of alternatives that remain after the initialscreening in paragraph fh]

(2) The detailed analysis of each alternative should include....

(B) Detailed cost estimation, including distribution ofcosts over time....

In developing detailed cost estimates, the user should perform the fol-lowing steps:

1. Estimation of costs: Estimate capital and operation andmaintenance costs for remedial action alternatives.

2. Present worth analysis: Using estimated costs, calculate annualcoats and present worth for each remedial action alternative.

3. Sensitivity analysis: Evaluate the sensitivity of cost estimatesto changes in key parameters, such as discount rates.

4. Summarization of alternatives analysis: Summarize data used in thealternatives analysis for use in selecting a remedial actionalternative.

Figure 7-1 illustrates these steps, which are discussed in the followingsections.


7-1

RGURE 7-1. Feasibility Study Cost Evaluation Procass

7-2

7.1 ESTIMATION OF COSTS

The user should identify all capital and operation and maintenancecosts for each remedial action alternative, and estimate the cost of thesecomponents using the sources suggested below under section 7.1.3, "Sourcesof Cost Information." Where cost estimates are derived from data a year ormore old, they should be updated using the cost indices discussed undersection 7.1.4, "Updating Costs."

Federal construction programs have traditionally distinguished capitalcosts from operation and maintenance costs. This distinction is not easilymade for Superfund response activities* Often, the completion of construc-tion will not achieve public health or environmental protection, which maybe attained only after the remedial technology has operated for a period oftime.

However, the distinction must be made to determine which costs areeligible under Superfund. Therefore, Superfund response activities shouldbe divided into two phases for the purposes of determining Fund eligibility:remedial action and post-closure.

Only costs incurred during the remedial action phase are eligible forfunding under Superfund. EPA defines remedial actions as activitiesrequired to prevent or mitigate migration of hazardous materials releasedfrom an uncontrolled site. Remedial actions are directed at achievingcleanup goals. Post-closure activities occur after completion of theremedial action and Include continued operations necessary to stop suchreleases.

The remedial action phase may include activities that havetraditionally been considered operation and maintenance costs, as whenconstruction by itself will not achieve cleanup goals. For example, aremedial action addressing ground water contamination may involve pumping,treating, and reinjecting ground water in order to achieve site cleanup.Costs associated with treatment system construction, and continued operation(e.g., labor and utilities) may be eligible. Costs associated with equip-ment replacement or continued operation following achievement of safe con-taminant concentrations would be Ineligible for funding. It is important tonote that EPA policy regarding Fund eligibility is currently being reviewed.Therefore, a review of the most recent policy may be necessary at the timeof feasibility analysis.

In general, the following criteria should be used to distinguishremedial actions from post-closure activities:

• Remedial actions include measures that (1) control contamination ator near the source of the release, (2) result in the initial miti-gation of a release to levels protecting public health, welfare, andthe environment, (3) have a definable endpoint based on contaminantlevels, (4) are related to the Initial construction effort (i.e..capping), or are of limited duration (usually less than 4 years).

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• Post-closure activities Include measures that (1) are required tomaintain releases at levels protective of public health, welfare,and the environment, (2) require long-term implementation, (3) haveoo definable end point , (4) maintain the physical integrity of theremedy, or (5) provide for scheduled monitoring or repair.

Vhile the distinction between remedial action and post-closureactivities is made for purposes of determining eligibility, it should not bea factor in feasibility cost analysis. Cost estimates should give compara-tive life-cycle cost information for the remedial action alternatives underconsideration. These alternatives should include all costs incurred as partof both the remedial action and post-closure phases. As in conventionalconstruction, cost estimation distinctions are made between capital andoperation and maintenance costs.

7.1.1 Capital Costs

Capital coats consist of direct (construction) and indirect(ooncons true t ion and overhead) costs. Direct costs include expenditures forthe equipment, labor, and materials necessary to install remedial actions.Indirect costs include expenditures for engineering, financial, and otherservice* not part of actual installation activities but required to completethe installation of remedial alternatives. Capital costs that must beincreased in future years as part of the remedial action alternative shouldbe identified and noted for the year in which they will occur. It isparticularly important to emphasise out year capital costs in the summary ofalternatives and to examine the impact of alternative discount rates in thesensitivity analysis. These will be critical factors in making tradeoffsbetween capital intensive technologies (including alternative treatment anddestruction technologies) and non-capital intensive technologies (such as

and treatment systems) .

7.1.1.1 Direct Capital Costs

Direct capital costs may include:

• Construction costs: Costs of materials, labor (including fringebenefits and worker's compensation), and equipment required toinstall a remedial action.

• Equipment costs: Costs of remedial action and service equipmentnecessary to enact the remedy; these materials remain until the siteremedy is complete.

• Land and site-development costs: Expenses associated with purchaseof land and development of existing property.

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Buildings and services costs: Costs of process and nonprocessbuildings, utility connections, purchased services, and disposalcosts.

Relocation expenses: Costs of temporary or permanent accommodationsfor affected nearby residents* (Since cost estimates for reloca-tions can be complicated, FEMA authorities and EPA Headquartersshould be consulted in estimating these costs.)

Disposal costs: Costs of transporting and disposing of wastematerials, such as drums and contaminated soils*

7.1.1.2 Indirect Capital Costs

Indirect capital costs may include:

• Engineering expenses: Costs of administration, design, constructionsupervision, drafting, and testing of remedial action alternatives.

• Legal fees and license or permit costs: Administrative andtechnical costs necessary to obtain licenses and permits forinstallation and operation.

• Startup and shakedown costs: Costs incurred during remedial actionstartup.

• Contingency allowances: Funds to cover costs resulting from unfore-seen circumstances, such as adverse weather conditions, strikes, andinadequate site characterization.

7.1.2 Operation and Maintenance Costs

Operation and maintenance costs are post-construction costs necessaryto ensure continued effectiveness of a remedial action. The user shouldconsider the following operation and maintenance cost components:

• Operating labor costs: Wages, salaries, training, overhead, andfringe benefits associated with the labor needed for post-construction operations.

• Maintenance materials and labor costs: Costs for labor, parts, andother resources required for routine maintenance of facilities andequipment.

• Auxiliary materials and energy: Costs of such items as chemicalsand electricity for treatment plant operations, water and sewerservice, and fuel*

7-5

e Purchased services: Sampling costs, laboratory fees, and „ ,.professional fees for which the need can be predicted.

• Administrative costs: Costs associated with administration ofremedial action operation and maintenance not included under othercategories.

e Insurance, taxes, and licensing costs: Costs of such items asliability and sudden accidental insurance; real estate taxes on pur-chased land or rights-of-way; Licensing fees for certain technol-ogies; and permit renewal and reporting costs.

• Maintenance reserve and contingency funds: Annual payments Intoescrow funds to cover (1) costs of anticipated replacement orrebuilding of equipment and (2) any large unanticipated operationand maintenance costs.

• Rehabilitation costs: To maintain equipment or structures that wearout over time. \j

• Other costs: Items that do not fit any of the above categories.

7.1.3 Sources of Cost Information

In estimating costs, the user should consider site—specific factorsIdentified In the remedial Investigation and the development of remedialaction alternatives. The sources for these estimates are discussed below.

7.1.3.1 Vendor Estimates

Based on detailed site and design information, equipment vendors andconstruction companies can provide site-specific remedial action construc-tion and equipment cost estimates. Equipment vendors can provide informa-tion on their equipment's service requirements. Equipment specificationsoften provide information on auxiliary materials and energy usage costs.Recommended maintenance schedules can provide a good indication of annualcosts, although they are often estimated as percentages of capital costs.

7.1.3.2 Estimates for Similar Projects

Estimates for similar projects or, preferably, actual experience withsuch projects, are good sources of cost information. Where necessary, thesecosts should be updated as described below in section 7.1.4.

7-6

7.1.3.3 Standard Costing Guidance•

Costs may also be estimated using standard costing guides such as the"Means Guide" and the "Dodge Guide" and the various remedial action costingmanuals developed by the EPA, including the "Remedial Action CostCompendium" and the "Handbook: Remedial Action at Waste Disposal Sites"(both published in 1982). If standard construction costing manuals areused, the estimates should be adjusted to allow for the additional costs ofsafety precautions and reduction of efficiency due to such precautions(i.e., wearing protective equipment).

Labor and energy cost data are published by the Bureau of Labor Statis-tics (Department of Labor) and Department of Energy, respectively. Thesesources are particularly useful in determining regional differences inlabor, material, and energy costs.

7.1.4 Updating Costs

Cost estimates are frequently based on data several years old and mustbe updated for the* current year. Appropriate cost indices include thefollowing:

• Engineering News Record Construction Cost Index (capital costs ofconstruction)

• Marshall and Stevens Index (for treatment facility costs)

• American City and County Municipal Cost Index (manpower costs)

• The Producer Price Index for Finished Goods, published by theDepartment of Labor in the Monthly Labor Review.

7.1.5 Accuracy of Cost Estimates

Detailed site characterization information from the remedial investiga-tion should permit the user to refine cost estimates for remedial actionalternatives. In some cases, studies will be necessary to determine actualdesign characteristics so costs can be accurately estimated. Although theymay be performed to obtain design data relevant to the feasibility study,such studies should be considered part of the remedial investigation. Onlythe results of these studies are addressed in the feasibility study. Whenthe applicability of the alternative has been established and can be esti-mated with the required accuracy, the bench-scale studies could be delayeduntil after the remedy has been accepted, in which case the engineer shouldprovide a best estimate of design parameters for use in estimating costs.

7-7

It Is important to consider the accuracy of coses developed for a -.feasibility study. Typically, these "study estimate" costs provide anaccuracy of -30 to +50 percent, and are prepared at relatively low costusing data available from the remedial investigation. Costs developed withaccuracies other than -30 to +50 percent should be identified in thefeasibility study.

7.2 PRESEHT WORTH AHALYSIS

Present worth analysis is used to evaluate expenditures that occur overdifferent time periods by discounting all future costs to a common baseyear, usually the present. This allows the cose of remedial action alterna-tives to be compared on the basis of a single figure representing the amountof money, that, if invested In the base year and disbursed as needed, wouldbe sufficient to cover all costs associated with the remedial action overIts planned life.

^In conducting the present worth analysis, assumptions must be maderegarding the discount rate and the period of performance. For the first, adiscount rate of 10 percent before taxes and after inflation should beassumed, as outlined in OMB Circular Ho. A-94. This rate represents theaverage rate of return on private investment. In addition to using adiscount rate of 10 percent, it is useful to conduct a sensitivity analysisusing other discount rates as well (e.g., & percent, 7 percent). This Isdiscussed further In the next section. Estimates of costs in each of the ,..planning years are made in constant dollars, representing the generalpurchasing power at the time of construction. The period of performanceshould not exceed 30 years for the purpose of detailed feasibility analysis.

7.3 SEBS1TIV1TT AHALYSIS

After the present worth of each remedial action alternative iscalculated, each cost should be evaluated for effects of variations inassumptions through sensitivity analysis. A sensitivity analysis assessesthe effect that variations in specific assumptions associated with thedesign, implementation, operation, discount rate, and effective life of analternative can have on the estimated cost of the alternative. Theseassumptions depend on the accuracy of the data developed during the remedialinvestigation and on predictions of the future behavior of the remedialtechnology and are subject to varying degrees of uncertainty. Thesensitivity of costs to these uncertainties can be observed by varying theseassumptions and noting the effects on estimated costs. Sensitivity analysiscan also be used to optimize the design of a remedial action alternative,particularly when design parameters are interdependent (e.g., treatmentplant capacity for contaminated ground water and the length of the period ofperformance).

7-8

Sensitivity analysis is especially concerned with factors that cansignificantly change overall costs with only small changes in the values ofthe factors. Other factors chosen for analysis should be those for whichthe value is most uncertain. The results of the analysis can be used toidentify "worst case" scenarios and to revise estimates of contingency orreserve funds.

The following factors are primary candidates for consideration in con-ducting sensitivity analysis:

• Effective life of remedial action (replacement)

• Operation and maintenance costs

• Duration of cleanup (period of performance)

• Extent of cleanup, given uncertainty about site conditions

• Other design parameters

• Discount rate.

The choice of a discount rate could be critical "in options that includehigh operation and maintenance costs over extended periods. The user isencouraged to identify those situations when the choice of a 4 percent or7 percent discount rate would produce a different low cost option. In thosesituations, sensitivity analyses about differing discount rates should beincluded in the presentation of alternatives.

The "time value" of money can substantially affect the present worthranking of competing alternatives, particularly where there is widedisparity between capital and operation and maintenance costs among thealternatives. The sensitivity of the present worth of competing alterna-tives to the assumed discount rate is best illustrated by an examplecomparison. Table 7-1 presents an analysis of three ground-water protection/cleanup alternatives at applied discount rates of 4, 7, and 10 percent over30-year system lives. Application of the lowest discount rate tends tofavor (to result in lowest present worth) alternatives having relatively lowoperation and maintenance costs and high capital costs, while application ofthe highest discount rate tends to favor alternatives having relatively lowcapital costs and high operation and maintenance costs. . This trend is shownin the ranking of costs of the three alternatives in Table 7-1; it ispossible that a given alternative may have che highest, lowest, or anintermediate present worth, depending on the discount rate being considered.

Additional guidance is under development which contains worksheetsenabling the user to manipulate key parameters affecting remedial actioncost and to measure the resulting effect. The manual also discusses factorsthe user may choose to analyze, and provides an example showing completedworksheets for a hypothetical alternative.

7-9

TABLE 7-1. PKE8KNT WORTH ANALYSIS <W TMKEK ALTERNATIVES AT TIIMKK DISCOUNT HATKS

Ir-1O

Al t uriiMt iva

Daacript ionPr*s*nt Worth M

float KstUalas (Sl.OOOt Discount Hutu ($1,000)

Capital

Install slurry cu t -o f fwal l and ground-wat«r•on it or ing aysta*

Install grounil-waturpin ping and tr«al«anlayat«« and ground-watvr•onitoring ayatM

Inatall grotind-watvrpunping uyt tam andgroimd-waler monitoring• yatra

04N

Inapact atirfacacand it iona and•on 11 or ground watar

Provida anargy, labor,and aatorialt to af fordpiMBping and Irvatiaantand •onltor ground watar

Provida unargy, labor,and aiatariala to a f fordpimping, haul water too f f - a i t a traat«ant 'fac i l i ty , and Monitorground watar

Ranking

Capital

10,000

1,000

I.OOO

Anon*IMM

200

600

1,000

4t 7T' lOt

I2.AB2

,17) 12,444 10,646

I 8 , 2 < > 2 10,427

C-»-A A-»-C A-B-C B-A-C C-B-A

Praaent worth of annuity factor for 10 yaara • 17.292

Praaant worth of annuity factor for 10 yaara • 12.409

Praaent worth of annuity factor for 10 yaara • 9.427i

'in ordar of lowest to hlghaat coat.

7.4 SUMMARY OF ALTERNATIVES COST ANALYSIS

Data developed in the cost estimation and present worth analysis stagesare used in a summary table to describe the alternatives (see chapter 8).Decisionmakers responsible for cost-effectiveness determinations must have acommon basis for comparing costs when evaluating various remedial actionalternatives. Therefore, three critical cost elements should be developedand assembled for input into the cost-effectiveness analysis: (1) totalcapital cost, (2) present worth costs, and (3) the cash flow over the lifeof the remedial action alternative.

The cash flow of a remedial action alternative presents a tally of theanticipated costs for each year of the remedial action alternative. Thepresentation of costs in this manner allows decisionmalters to identify andassess future capital and operation and maintenance outlays, which areimportant in planning budgets.

It should be noted that the presentation of the costs for eachalternative should include all costs associated with implementation of thealternative. Costs common to all alternatives must be included with eachalternative so that the total estimated cost for each is readily apparent.

7-11

CHAPTER 8

SUMMARIZE ALTERNATIVES

8.1 OVERVIEW

This chapter is a guide to summarizing the detailed technology, publichealth, environment, and cost evaluations discussed in chapters 3 through 7.The summary of alternatives is a key step in comparing the alternatives sothe decisionmaker can select the cost-effective remedy in accordance with

%»* CERCLA and the NCP.

The diversity of site characteristics, the mass of informationcollected, and the range of factors that must be considered makes evaluatingremedial alternatives and selecting one for implementation difficult. Inthis context, decisionmaking cannot be carried out by applying adeterministic decision rule. The decisionmaker, armed with the necessaryinformation, must instead consider relevant and applicable standards,

Mjf appropriate criteria or guidance, health and environmental concerns,technological reliability, cost, and other appropriate factors associatedwith each alternative. These factors must be evaluated and specific circum-stances at a site must be taken into account during their evaluation.

8.2 CERCLA COMPLIANCE WITH OTHER ENVIRONMENTAL LAWS

i^m Chapter 4 discusses the categories of alternatives that must beexamined under the "CERCLA compliance with other laws policy." The summaryof alternatives must present these to the decisionmaker as well.

When the specific conditions preclude development of alternatives inone of the required categories, the feasibility study must document thereasons for that decision. Occasionally, an alternative may fall into morethan one category.

The decisionmaker will consider all of the alternatives arrayed in thesummary, and will give primary consideration to the remedies that attain orexceed applicable or relevant Federal public health and environmentalstandards. The decisionmaker would then select a remedy that attains orexceeds applicable standards unless one of the specific circumstancesdiscussed below is determined to exist by the decisionmaker. Where relevantor applicable standards are not available or criteria or advisories are not

W 8-1

used, the user will be directed by EPA headquarters to achieve a specificrisk level or range of risk levels as described in chapter S.

The decisionmaker may consider, and modify if necessary, criteria thatwere not developed for the specific application under consideration. Forexample, Federal Water Quality Criteria are based on consumption of 2 litersof water and 6.5 grams of fish per day. If these criteria are used forground-water remedies, an adjustment should be made to consider consumptionof water only. The decisionmaker would document cases where he/she does notuse or adjust relevant standards or criteria.

If disposal of hazardous substances off-site is part of the selectedresponse, the decisionmaker also would ensure that the off-site facilityselected is acceptable under the policy in force at the time. Appendix Bdescribes current EPA policy.

The decisionmaker may select a remedial action that includes bothsource control and management of migration response actions consistent withthis policy.

The decisioomaker may select an on-site alternative that does notattain applicable or relevant standards in one of the following specificcircumstances, recognizing that a consideration in making this determinationis the extent to which the standard was intended to apply to the specificcircumstances present at the site :

1. The selected alternative is not the final remedy and will becomepart of a more comprehensive remedy;

2. All of the alternatives which meet applicable or relevant standardsfall into one or more of the following categories:

(i) Fund balancing - for Fund financed actions only; exercisethe Fund balancing provisions of CERCLA section 104(c)(4);

(ii) Technical impracticality - it is technically impracticalfrom an engineering perspective to achieve the standard atthe specific site in question;

(iii) Unacceptable environmental impacts - all alternatives thatattain or exceed standards would cause unacceptable damageto the environment; or,

In determining whether a particular standard is applicable or relevant, thedecisionmaker should refer to the list of "Applicable or Relevant Require-ments" in the CERCLA compliance policy. For example, RCRA did not "contem-plate" the regulation of indiscriminant disposal of waste over 210 miles ofroadway, or the contamination of a river bed with hazardous waste. In suchsituations, RCRA regulations would not be applicable per se, but on a case-by-case basis, part of the regulation may be relevant.

8-2

3. Where Che remedy is Co be carried out pursuant Co CERCLA section106; Che Hazardous Response Trust Fund is unavailable; Chere is astrong public interest in expedited cleanup; and Che litigationprobably would not result in the desired remedy.

The Agency anticipates that most CERCLA remedial actions will attain orexceed applicable or relevant public health or environmental standards.However, where the specific circumstances discussed above preclude theselection of a remedy that attains standards, the decisionmaker would selectthe alternative that most closely approaches Che level of protection pro-vided by the applicable or relevant standard, considering the reasons fornot meeting ChaC standard.

8.2.1 Other Federal Environmental Standards, Guidance, or Advisories

EPA will encourage other Federal agencies to use their statutoryauthorities in connection with response actions. In developing remedialalternatives, the EPA should take these standards, guidance, or advisoriesinto consideration. If an alternative is selected after consideration ofthese standards, guidance, or advisories but does not achieve them, thedecision documents would state the reasons for the decision.

8.2.2 State Environmental Standards. Guidance, or Advisories

If a State desires the selection of a remedial action incorporatingState standards more stringent than Federal standards, the decisionmaker mayselect that remedy. The State generally would be expected to pay additionalcoats incurred in achieving the more stringent standards, but the EPAdecision official may make exceptions to this policy in appropriatecircumstances .

8.3 ORGANIZE AND PRESENT INFORMATION

Pertinent information on costs, health risks, environmental effects,reliability, and other factors should be presented for each remedial alter-native, including the no-action alternative, so that the key differencesamong alternatives are evident. Remedial alternatives that attain or exceedthe requirements of applicable environmental regulations should be iden-tified.

A narrative summary describing such factors as cost, technology,reliability, adverse impacts, and other factors should be used to compareall cm-site alternatives to each other and to off-site disposal alterna-tives .

8-3

If there are not applicable or relevent Federal public health orenvironmental standards, the evaluation should be based on the degree towhich each alternative mitigates and ainimizes threats to and providesadequate protection of public health, welfare, and the environment, con-sidering cost, technology, adverse impacts, and the reliability of thealternative.

The following information, at a minimum, aust be provided for eachremedial alternative:

e Present worth of total costs: The net present value of capital andoperating and maintenance costs aust be presented.

e Health information: For the no action alternative, EPA prefers aquantitative statement including an estimated range of maximumindividual risks. For source control options, a quantitative riskassessment is not required. For management of migration measures, aquantitative risk assessment, including an estimated range ofmaximum individual risks, is required.

e Environmental effects: To simplify the evaluation, only the mostimportant.effects should be summarized. Reference can be made tosupplemental information in a separate table, if necessary.

e Technical aspects of the alternative: This information may stronglyinfluence the selection of a remedial alternative, and it isimportant to describe carefully the technical advantages anddisadvantages of alternatives. Such information generally is basedon the professional opinion of engineers familiar with the site andwith the technologies comprising the alternatives.

e Information on the extent to which alternatives meet the technicalrequirements and environmental standards of appropriate environ-mental regulations: This information should be arrayed so thatdifferences between the alternatives, in terms of how they satisfysuch standards, are readily apparent. The kinds of standardsapplicable at the site may include (1) RCHA design and operatingstandards, (2) drinking water standards, and (3) environmentaldischarge standards.

e Information on community effects: The types of information thatshould be provided include (1) the extent to which implementing analternative would disrupt the community (e.g. , traffic, temporaryhealth risks, and relocation) and (2) the likely public reaction.

• Information on remedies involving removal of materials for off-sitedisposal: This information should doctmient compliance with EPApolicy on selecting off-site EPA approved facilities for disposal ofmaterials from fT**TJV sites.

• Other factors: This category of information would include institu-tional factors that may inhibit implementing a remedial alternativeand other important site-specific factors.

Tables 8-1 through 8-3 are examples showing how to summarize the mostimportant information to consider in the selection of a remedy. Thissummary, supported by the RI/FS studies, provides the body of informationthe decisionmaker must use to select a cost-effective remedy. Table 8-1lists hypothetical alternatives for source control measures at the LehighElectric site, and Table 8-2, for management of migration measures at theReilly Tar site. Table 8-3 presents a hypothetical case in which bothsource control and management of migration measures were developed foranalysis. In some cases, both source control measures and management ofmigration measures may be combined to form one alternative, and arepresented in the table as a combined alternative. Each table describes thealternatives in terms of effectiveness, cost, and other features.

When on-site alternatives are being considered, the feasibility .studywill generally recommend the alternative which attains or exceeds applicableor relevant Federal public health or environmental standards except whenfive specific circunatances are determined to exist at the site, as requiredby EPA's policy on compliance with other environmental laws (described insection 8.2). In addition, appropriate Federal public health, and environ-mental criteria, advisories, and guidance, and State standards can be usedin recommending the alternative.

The summary of alternatives should highlight important differencesamong alternatives, reducing to manageable proportions the information to bereviewed by the decisioonaker. The summary's precision should be consistentwith the extent of knowledge about the problem and the expected results ofremedies.

8-5

TABI.K B-l. SOURCE CO NT HO 1. ALTtRNATlVES SUMMARY COR LEIIICH ELECTRIC

«••» -_-i.Fr«*«*l PuklU Ma.llh t**lr«.m.»a4*l T.ehnlc.lAll.rn.llv. C.pli.l Uorlk Coiw.r** CetM.rM Conc.fH* CoM.rit* Other

I. Me oclloD 10 -- PCI •ipo.ui«i ln|«*llo., Nlnla.1 .rMMlU* -- U«.KC**l.kl*. L**4flll PCI*lo*i<l.l Ion. .n4 4»r.ul far vlgr.!!** I* <Il.n4.r4* *r*.ipu.ur* I* PCI* *ku«. MHlf*r M>4 rl».r. W\0 •••. He ca.lMl

21. toll rvMV.I I* I.MO r,VK> A..UM PCI* *r* iMokll- N10 ••«, .It. f.MO I,*00 li*4 (*• rl.k). pal. M I.I far •lir.llo*.

••I or

0,, 4 ». loll r*M*.l !• •.100 t.100 A..I.M PCI* .r« laMkl I MlttltulI M ff», .It. t.VOO t,WO lt.4 (tw rl*k>. pot.nil*! far al|r.llan. -- Un*cc.*t.kl..

.tic.|l.ul.lla«

I. loll r.M».l I* ».»00 k,400 A..UM PCI. .r. lawikll- Nlnla.1M ft* vllh la.4 (xa tlrt). pal.Ml*! far alfrctlB*..J4Klon.il•ic.v.lIon*

.ll ..l.rl.4.

TABLE 8-2. MANAGEMENT OF MIGRATION ALTERNATIVES SUMMARY FOR REILLY TAR, FIRST OPERABLE UNIT

CD

Alternative

,.

I.

1.

No action

Connect lorn toMliweapollawater ayalei

Brill deeperwella lounderlyingformat lone

Coat QI.OOO)Praeeat

Capital Worth

ZMt -.101

•

1.8)0 l.tit

Public HealthConcerna

Unacceptable eipoaure toPAN during inmair orduring lira*.

•educee public healththreat to leaa than10** (migration).

•educea public healththreat to leaa than10 .

Environmental TechnicalConceraa Cone erne

Continued migration•f contaminatedground water.

Doea not 'control tellea on elmpleground water. technology.

Doea not control lei lea an provencontinued ground- technology.water migration.Deplete! limitedwater reeourcee Indeeper aeuflfer.

CommunityReapoaaeConcarna

••a*racial anca.

Acceptable.

Acceptable.

Other

Haa nlgnlf Icantly higherOeH and praaant worthcoat.

Haa aecond hi ghee tpraaent worth coat .

•• A^ullar traataenl

A. Oione I,alt lenovea laate end odor,but raault* In 10*' to10"* rlak (2.000 ng/Lfor noncarclnogenlc PAH)*

2.10* leaulta In I0~* In 10"*rlak (l.OOO ng/L for

PAN)*.

2.4M

Blocka a>l(racla« aa4allova aMIIIoaalwalla la >e apee«4.

•eaulta In 10 or laaarlak (2*0 iig/L fornoncaiclnogenlc PAH)*.

Mat weed on wlee ecale.Laaa reapaoalva thangraaular activatedcaraoa to alwg Iaa4lag.HouU W e.peaeloe laret red t If treelaeatgaala change. Cartalalythat target rlak la«alala "Pufcllr Heallh Coaceraa"cnluo* wttl Ml becaaalaleotly•at la low 4ua tooperational Indelibility.

Acceptable. Freeent wrlb la laaathan for CAC at lowtreetawnt level, butgreater al recoMaeada(lawaat rlak) level.

a. Craoular all 1.IW leaovea laata an4 o«aractivated but reaulta In 10* tocaraoa 10'* dak (l.OOO ng/L(CAC> for noacarclaageatc

•AM)*.

all I.Jal Icaulta In lo"* to IO**rlak (l.OOO ag/L foraoncarclaogaalc fU)*.

til 24. Oil leaulta In 10** or lea*rlak (1U ag/L lotawicarclaoaeiilc fall)*.

ilocka ajlgralloa and Coaaldarad aeat avallahl* Acceptable.allowa additional technology, rrovaa averwalla to he opened. a wide range af operating

conditions, leapanda wallto alug loadlag.

tlkaly to oeet rlak targetla "fubllc Health CoMerna'coluan, coaelateatly.

rreaeat worth la laaa•t lecoomendedtroataaat level.

'Approilaete organaleptIc tkreehold.

TABLE 8-3. SOURCE CONTROL AND MANAGEMENT OP MIGRATION ALTERNATIVES SUMMARY POR I1ARD TIMES WASTE SITE

Caal (|I,Q«»| _ Ca*a»Mlly»' •••Ilktfc.||k Ca««IM Cwwata* Ca*aafaa C«M«fM OllMf

11 ta«f < • 1'rtlM fal

I. Ha arllM 10 - WaarxptakU •••••of* !• C*M l***4ICI ikfM§* aaMl*Ma4 la Ik* |iaM4 wlarf«l*M* I* aoffMa "<l*l, Ml4 talaac* !• «lf•If, a*4 |fWM4 **t«f.C<Ml4 pai*Ml*lly CMIM

(4lf*cl caMacI ••»!••.xllk kiiaiM, a«aacHf»4

}. •wtl*r* MH| MM) VOO l«4M<«c !•!•••• In all t«4W*« !•!•••• !• fi*««a, •••••••4. •••«i«al •! M«|«••«kawilac« 4M4 •«•!•&• a«t«f. «lf ai^ •"*!•£• ••dHtalagy* la AMA ••••lll*4t«*»<l at 4fMM fukllc flak f*4w>4 ««l»l. Of*a«4- iMllllf.•«4 Ian*, •••ullly <aa 4ll*cl caMMI vllk iMHI f*l««*l ••aa4lll act la*I»M* xillac* MHl* an4 raa- taallauai kirt •llacl !••••••

I4«la«la4 •!••• ••C«fa4>. ••|allly al •MllaflagCD »««f« (••••• l«a,iill*J>I fiaita4) !•

). lultac* •••! >«k »M f.tSO A..UM >a •ll.rl onlarl•ullcci i.•»«•!. af l>t«lla* («• il(k). la (If «a4 •arlic* Kcknalafy. •rciaKkl*. la ICI*-aar*lll>4••cur II r !.».., «•!•!. OtaaM- Uilllly. «l«k• ll»ii»ll«< ««l«r ««l«r !•!•••• caa.- 0 ft N CMI*•nafly lla»«« kul M|«ill> ••aacl«l*4 "Ilk

tli«a4) I* ca«lrall(4. •"»•*!• Illcclln-mftct la •a4«n>*f«4 •••• WMl k«

f«4i>r>4.

4. tvit*r« l*w»*l, I,tUO I,OM Kttam* M 4lr«rl caalarl I Hal nil •• »!•••• fra««« Ho4»t«l«l» Irao**! al «••!• la •rapping M4 af InfMilan (na flak). la •!( aii4 lack««la|y. (cofKcU. ICU p*r«lll«4gta4ln4, Cunlral* ••wrcc af •uifac* wa iv f * facil i ty* Ika• ••patflry §fuw«4"w«i«f !•!••••! lapacl an •n4an§«ra4 alyfry wall ajualali«iii<ll>* atiiMlU ••»!•• <Mlal« a Uf|«vaiar aupply alla.!«it4i •'•• W«*»a« •!••railly Ik* calf»m'•Ma, UO* (faaM-iwItf plwa*• larry wall awMafl**.

Itlacl!»••••• *yal

(cmllMM4l


Alternative

Can (SI

Capital

PreaentNorth

Public Health

Cooceroa

Environmental

Concerna

Technical

Concaraa

•aapunaaCoacaraa Other

II. Hanagement of•IgratIon

IO

2.

00

Unacceptable aipoeura to Continued migrationTCI through continued to the ground watertetenae to aucfoce water. and releeee to airair. and ground water. MW| eurface water.Could potentially cawa* Could thraataaj••caaa caaccr rlak «aj4aa|cr«4 aajuaclc(alract contact apcclca.ulth huaiaaa. twaocMradaraaa).

Unacceptable.

Pumping con-laminatedground water,prel teat Ingand dlacharglnglo local POTU.capping andgrading

I,7M 2.IJO Aaaume no direct.contact(leaa than 10 . toIO cancer rlak).

Controla eilatlngcontaminant plumeIn ground water.

Proventechnology.

Accept ablenegotiatedagreemeol.

Nuet determine andmeet local POTMdlacharga require-ment a and Federal40) prelrealmenlregulatlona.Should be combinedwith aource controlmeaaurea 1.2, I.),or 1.4.

). Pumping l.nIO 2.420contaminatedground water,pretreatlng anddlacharglag tolocal eurfacewater body, cap-ping and grading

4. In altu I.«M ).«Mbiological andchemical treat-ment of contami-nated aolla andIround water,capping andgrading,temporaryalternative wateraupply

Aeducea cancer rlafclo leaa than I0~ .

•eaultacancer rlak

10"* 10 IO"S

Controla aurfacawater releaaethrough cappingand gradingand pretrcatlngcollected groundwater.

Treata contamin-ated aolla andground water. Haybo concern overIntroducing addi-tional chemlcalaand organ I au tothe environmentthrough In altutreatmentmelhodologlea.

Proven Moderatelytechnology. acceptable

Difficultto dealgndeliveryayatem andla monitoreffectIveneeeIn altotraatmeat.

Unacceptable.

NPMS Permit may berequired. Shouldbe combined withaourca control•eaaurea 1.2.1.1. or 1.4.

In altu treatmenttechnology motfully developed.May have locontend with UICrequlrementa.

CHAPTER 9

FEASIBILITY STODY REPORT FORMAT

This chapter presents and discusses the recommended format for CERCLAfeasibility study reports* This consistent format ensures that all majorissues are addressed, makes it possible to compare feasibility studies fordifferent sites, and ensures that decisions are adequately documented* Theresult will be more rapid and efficient selection and implementation of themost cost-effective remedies. Table 9-1 shows the recommended format, withits numbering system, as it would appear in the report.

9.1 EXECUTIVE SUMMARY

The executive summary is a brief overview of the study and the analysesunderlying the recommended remedial action* Information about the site andthe feasibility analysis is summarized so that the reader can review thefindings in a logical order.

The major topics addressed in the executive summary are (1) the purposeof a feasibility study; (2) the site, its background, and its problems;(3) the promising remedial action alternatives; and (4) the recommendedremedial action and Its advantages over other alternatives.

Discussions under each of these headings briefly convey importantcharacteristics, criteria, and findings. Tables and figures are used wherepossible to summarize information clearly and concisely. The ExecutiveSummary should be 5 to 10 pages long with at most one or two tables orfigures *

9.2 INTRODUCTION

As the Introduction to the report, chapter 1 briefly characterizes thesite in terms relevant to the analysis of remedial action strategies. Theintroduction has three main topics: (1) site background information, (2)the nature and extent of contamination problems at the site, and (3) reme-dial objectives.

9-1

TABLE 9-1. FEASIBILITY STUDY REPORT FORMAT

Executive S«

1.0 Introduction

1.1 Sit* background Information1.2 lUtore and extent of problems1.3 Objectives of remedial action

2.0 Screening of Remedial Action Technologies

2.1 Technical criteria2.2 Remedial action alternatives developed2.3 Environmental and public health criteria2.4 Other screening criteria2.5 Cost criteria

3.0 iemediil Action Alternatives

3.1 Alternative 1 (Ho Action)3.2 Alternative 2

3.1 Alternative •

4.0 Analysis of Remedial Action Alternatives

4.1 Boncost criteria analysis

4.1.1 Technical feasibility4.1.2 Environmental evaluation4.1.3 Institutional requirements4.1.4 Public health evaluation

4.2 Cost analysis

5.0 Summary of Alternatives

6.0 Recommended Remedial Action (optional)

7.0 Responsiveness Summary (in final version only)

References

Appendices

9-2

9.2.1 Site Background Information

The site background information discussion describes the site in termsof past and present activities, concentrating on the physical, biological,and socioeconomic factors that affect site conditions. Specific topics mayinclude the following:

• Facility location, size, existing structures

• The time period of waste-related activities

• Historical descriptions of:

- Facility type- Activities and operations- Types of wastes- Condition of wastes (originally and at present)- Incidents that occurred (fire, explosion, ground -watercont aminat ion , etc.)

- Site investigations, response actions, and enforcement activities

• Physiography

• Hydrogeology

• Other items

- Community perception- Planned use of site- Conflicting or missing information- Site map showing location, size, water supplies, sensitiveenvironmental areas, and nearby populations.

All discussions should be pertinent to the use of the facility for managinghazardous wastes.

9.2.2 Nature and Extent of Problems

The nature and extent of the problems at the site should be describedin a way that establishes a framework for determining remedial objectivesand defines criteria for selecting remedial action alternatives. Thissection of the introduction focuses on existing and potential on-site andoff-site health and environmental effects. It should include the following:

• Type, physical state, and quantity of wastes or hazardous substanceson the site

• Special waste considerations (e.g., explosive or radioactivematerials)

9-3

• Present condition of materials and structures (including drums,tanks, landfills, etc.)

• Changes In site conditions (e.g., filling in a waste pit or lagoon,applying cover material to burled or partly burled drums)

• Effects of contaminants from the site (as indicated by monitoringand geotechnical studies):

- Types of contaminant releases (e.g., leachate, runoff)- Affected media, movements of contaminants- Resources, population, or environments threatened by contaminant

ent

Bear-future effects of site conditions and contaminant migration

• Actions previously taken to mitigate problems and the results ofthese actions.

9.2.3 Objectives of Remedial Action

The final section of the introduction identifies the objectives ofremedial actions at the site. Objectives should be identified in terms ofgeneral goals (e.g., minimize off-site contaminant migration) as veil asspecific goals (e.g., prevent waste from coming into contact with groundwater, raise site above 100-year floodplain, etc.). This section shouldalso describe or tabulate environmental criteria and standards that form thebasis for remediil actions.

9.3 SCREEHIBG OF REMEDIAL ACTTOH TECHNOLOGIES

Chapter 2 of the report summarizes the screening process used to iden-tlfy the most appropriate remedial action alternatives to undergo detailedanalysis. Technical discussions should address the technologies initiallyconsidered and Identify the most promising technologies, the methods used todevelop remedial action alternatives from those technologies, and the alter-natives developed. It should also discuss the problems associated withapplicable technologies. The chapter should also discuss the following fourcategories of screening criteria:

e Environmental and public health

e Other site-related considerations such as public welfare, siteaccess, etc.

e Cost.

The discussion should explain the reasons for eliminating certain alterna-tives .

The final section of the chapter identifies the most promising alterna-tives* Detailed descriptions and preliminary conceptual designs for thesealternatives should be placed in chapter 3.

9.4 REMEDIAL ACTION ALTERNATIVES

Chapter 3 of the report summarizes the remedial action alternativesdeveloped from the applicable technologies identified in the initialscreening.

The description details the cost and noncost features of each remedialaction alternative. Specific elements in these discussions should includethe following:

• The intent of the remedial alternative, such as source control ormitigation of contaminant migration or effects of migration, etc*

• Key features of the alternative

- Description of the technologies making up the alternative»

• Control, storage, treatment, and/or disposal requirements

• Phasing of work, if necessary

• Special engineering, safety, environmental, public health, publicwelfare, or other considerations that affect the feasibility of eachalternative

• Operation, maintenance, and monitoring requirements (short and longterm)

• Aspects of the site problem that the alternative will or willnot control.

If the alternative involves a series of separate activities, each activityshould be identified and briefly described. It should also be noted whetherthe particular strategy provides a single-medium or multimedia solution,where such a solution is applicable. A site layout diagram, process flowdiagram, and the like should be Included to illustrate each alternative.

A summary of the remedial action alternatives may be Included In matrixform. Such a summary would Include a list of the strategies, key featuresof each concept, the problems to be controlled, and the expected result ofeach alternative.

9-5

9.5 ANALYSIS OF REMEDIAL ACTIOH ALTERNATIVES

Chapter 4 of che feasibility study report presents detailed analyses ofthe remedial action alternatives. The majority of che analyses and sup-porting data will be presented in Appendices to che FS report. This chapterpresents an overview of these analyses and is divided into two major sec-tions: noncost criteria analyses and cost analysis.

9.5.1 Honcost Criteria Analysis

The noncost criteria section addresses considerations of technicalfeasibility, environmental protection, public health, and institutionalissues. Each of these analyses is presented in a separate subsection.

For each noncost criteria category, che report summarizes the analysisperformed. Identifying and briefly discussing the criteria and methods used.Where possible, the results of the specific analysis for each of the alter-natives should be summarized using tables and figures to consolidate com-parative Information. The technical discussion should concentrate on thefeasibility and Implementability of each alternative. The environmentaldiscussion should assess each alternative's positive and negative Impacts onthe environment. The institutional discussion should discuss regulatory andcommunity relations Issues for each alternative, and cheir impacts on thechoice of an alternative.

The final section of this chapter reviews the public health aspects ofeach remedial alternative, examining the relevant public health goals andpublic health aspects of each remedial alternative, including relevant andapplicable standards, criteria, advisories, and guidance considered, and anexplanation of adjustments made to standards, criteria, etc. Alternativesfalling to meet these goals are noted, with brief explanations of thesefailures and of the anticipated effects of the level of control in question.

At a minimum, the noncost analysis of each alternative should include adiscussion of the subject areas listed in section 8.3.

9.5.2 Cost Analysis

The cost analysis section should summarize che estimated costs of eachalternative, review the main cost items, and discuss important considera-tions in the cost analysis. Cost analysis topics should include thefollowing:

Costing methodologyCapital costsOperation and maintenance costsPresent worth analysisPhasing of the work and its impact on cost (if required)

9-6

• Distribution of costs over time (stream of costs)• Results of the sensitivity analyses.

For ease of presentation and to permit direct comparison of the variousalternatives, much of the cost data should be presented in tables andfigures .

9.6 SUMMARY OF ALTERNATIVES

Chapter 5 of the feasibility study report summarizes the remedialalternatives and presents the results of the analysis using appropriatesummary tables and figures. The alternatives are compared, with clearstatements of their advantages and disadvantages. At the end of thiscomparative analysis, the recommended alternative is Identified, and thereasons for the selection are given.

9.7 RECOMMENDED REMEDIAL ACTION

Chapter 6 of the report, a detailed description of the recommendedremedial action, Is prepared to meet certain specific regional requirements.This is based on regional discretion. In some cases, the description of therecommended action will not be prepared at this stage, but after approval ofthe Record of Decision (ROD). Generally, for enforcement-lead sites, theRegional Administrator may elect not to include a recommended alternative atthis stage.

The recommended remedial action chapter would include the following:

• A review of what the remedial action will and will not accomplish

• Special engineering considerations and special studies needed duringfinal design

• Operation, maintenance, and monitoring requirements

• Off-site disposal needs and transportation plans

• Temporary storage requirements

• Appropriate treatment and disposal technologies

• Brief descriptions of the environmental and public health problemsthat may be encountered during implementation

• Means of mitigating the associated environmental and public healthproblems (and their costs).

"-' 9-7

9.8 RESPONSIVENESS STOWART

The responsiveness summary is included only in Che final version of afeasibility study report, after public coanent on the study. This chaptersummarizes the public comment on the draft feasibility study report, includ-ing views expressed by potentially responsible parties, whether or notlabelled as "comments," and actions taken regarding these consents.

9.9

The references section contains the complete bibliographic citation foreach information source used and cited in the main text of the report.References to sources cited in an appendix should appear in a separate listwith chat appendix.

9.10 APPEBDICES

The text of the feasibility study report summarizes the site Infor-mation evaluated and the analysis conducted in selecting the most promisingremedial action alternative. So that this summary presents the major fea-tures of the analysis and decision process clearly and logically, detaileddiscussions, diagrams, and supporting analyses may be presented as appen-dices.

A feasibility study report may include the following appendices:

e Appendix A: Supporting Documentation for the Screening Process

e Appendix B: Supporting Documentation for Cost Analysis of BestAlternatives

• Appendix C: Technical Feasibility Analysis

• Appendix D: Public Health Evaluation

• Appendix E: Environmental Evaluation

• Appendix F: Exposure Analysis

• Appendix G: Institutional Analysis.

Depending on the features and problems of a site, and the complexity of theaccompanying analysis, some of these appendices may be unnecessary, oradditional appendices may be needed.

9-8

GLOSSARY

AASHTO - American Association of State Highway Transportation Officials

Acceptable engineering practices - technologies or practices which aretechnically sound, reliable, and applicable with respect to aparticular site problem.

ACL - Alternative Concentration Limit

ASTM - American Society for Testing and Materials*

Budget estimates - estimates of capital operation and maintenance or servicecosts provided by a vendor.

CAA - Clean Air Act.

CERCLA - Comprehensive Environmental Response, Compensation, and LiabilityAct of 1980. Also known as Superfund.

Cleanup - the elimination, reduction, or containment of pollutants from asite by a selected remedial action.

Community impacts - any change in the normal way of life, directly orindirectly attributable to the selected remedial action, includingtemporary or permanent relocation, initiation of health monitoringprograms, formation of citizens' groups to review remedial alter-natives, etc.

CRP - Community Relations Plan.

CWA - Clean Water Act.

Durability - the projected length of time that a designed level ofeffectiveness can be maintained. It is also measured in terms of theoperation and maintenance requirements (parameter of reliability).

EDD - Enforcement Decision Document; a public document that is similar inpurpose to a ROD. It documents the selection of a remedy and is usedin settlement or litigation with potential responsible parties.

Environmental carrying capacity - the alternate uses a site is capable ofsupporting, especially after remedial actions.

FEMA - Federal Emergency Management Agency.

1

General response action - a response action category consisting of groupingsof related response technologies that may be used for a specific siteproblem (e.g., surface water controls, air pollution controls).

BBS - Department of Health and Human Services.

HUM - hazardous waste management.

Implementabillty - a measure of successful prior Installation of a remedialtechnology either on similar sites or on a research and developmentbasis. Includes well understood installation and operational practicesrequiring minimal monitoring.

Institutional factors - analytical factors associated with Federal, State,and local regulations, guidance, and advisories concerning publichealth and welfare, environmental considerations, community relations,and other social, political, and economic concerns.

Isolation - a situation in which the transport of pollutants from a site tothe surrounding environment has been stopped or slowed by the selectedremedial action, but no pollutants have actually been removed.

MCL - Marfmnm Concentration Limit, established under to Safe Drinking HaterAct.

MPRSA - Marine Protection Resource and Sanctuaries Act.

RAAQS - Rational Ambient Air Quality Standards.

RCP - Rational Oil and Hazardous Substances Contingency Plan.

ROD - Negotiated Decision Document; a confidential enforcement documentcontaining a discussion of alternatives identified in the draft RI/FS,indicates preferred alternatives; serves as basis for negotiation withpotential responsible parties.

REPA - Rational Environmental Policy Act.

RESHAPs - Rational Emission Standards for Hazardous Air Pollutants.

RIOSH - Rational Institute for Occupational Safety and Health.

ROEL (So-Observed Effect Level) - the maximum experimental dose of asubstance at which no toxic effect was observed.

RPDES - Rational Pollutant Discharge Elimination System.

RSPS - Rev Source Performance Standards.

O&M * operation and maintenance.

OSBA - Occupational Safety and Health Administration.

Operable unit - a discrete part of a remedial action that can function inde-pendently as a unit and contributes to preventing or minimizing arelease or threat of release.

wPhysiography - general description of a site; for example geographic

position, vegetative cover, and topography.

Present worth - a summary of costs to be incurred over a period of timediscounted to the present.

PSD - Prevention of Significant Deterioration (air permit).

RCRA - Resource Conservation and Recovery Act.

Relevant or applicable standards - established Federal or State proceduralrequirements or limit values (such as MCLs) pertaining specifically tochemicals, environmental impacts, or technology operations conducted oranticipated at a site.

Reliability - a measure of the effectiveness and durability of a technology.

Remedial Action Alternative - a remedial technology or a combination ofremedial action technologies which will prevent or mitigate site-specific contamination problems.

Remedial Action Technology ("Technology") - a general category encompassinga number of remedial action technology options that address a similarproblem (e.g., capping, containment barriers, chemical treatment).

Remedial Action Technology Option ("Technology Option") - a specificprocess, system, or action that may be used to cleanup or mitigatecontaminant problems (e.g., slurry wall, clay cap, activated sludgetreatment)•

REMFIT contractor - Remedial Planning and Field Investigation Teams contractto the U.S. EPA.

Risk Level - Cancer risk level provides an estimate of the additionalincidence of cancer that may be expected in a population exposed to agiven contaminant. A risk of 10 , for example, indicates a probabili-ty of one addltionnal case of cancer for every 100,000 people exposed.A risk of 10~ indicates one additional case of cancer for every onemillion people exposed. A risk of 10 would be one case in 10 millionpeople exposed.

RMCL - Recommended Maximum Concentration Limit, developed under SafeDrinking Water Act.

ROD - Record of Decision, documents selection of cost-effectiveFund-financed remedy.

RPM - Remedial Project Manager.

S&E **"»nl - procedural «»«nil entitled "Methodology for Screening andEvaluation of Remedial Responses."

SDWA - Safe Drinking Water Act.

Sensitivity analysis - a test of a procedure to determine the overallchanges that result from any small changes in one or more proceduralelements.

Significant adverse impact - a public health or environmental effect thatcannot be mitigated or ameliorated.

SIP - State Implementation Plan under the Clean Air Act.

Site - a landfill, surface impoundment, storage facility, or any other siteor facility of any kind, at which a hazardous substance is present as aresult of a release of such hazardous substance from a facility asdefined under CERCLA.

SHARL - Suggested Ho Adverse Response Level

Social costs - perceived negative Impacts resulting from a remedial action,including impacts manifested in psychological, sociological, political,legal, and organizational changes.

Technology status - the state-of-the-art, relative to application touncontrolled hazardous waste sites, of remedial alternatives; describedas proven, widely used, or experimental.

TSD - treatment, storage, or disposal facility.

OCR (Unit Carcinogenic Risk) - probability that cancer will be produced foreach unit of dose.

UIC - Underground Injection Control Progr

USDH - Underground source of drinking water.

Unit operation * the basic physical operations of chemical and civilengineering that may be applied as remedial actions, for examplecapping, groundvater pumping, biological treatment, containmentbarrier; a technology.

User - any person involved with conducting a remedial action feasibilitystudy; the user of this document.

REFERENCES

1. Alexander, Maurice M. et al. 1978. "The Ecological Impact of Bunker COil on Fish and Wildlife in St. Lawrence River Marshes," Conference onAssessment of Ecological Impacts of Oil Spills.

2. Alaska, State of: A) April 1982 booklet Oil Spill Status. B) "AlaskanCivil Penalties Regulations for Oil Spills: The Record."

3. Arthur D. Little, Inc. 1976. Physical, Chemical and BiologicalTreatment Techniques for Industrial Wastes. U.S. EPA Office of SolidWaste Management Programs.

4. SNA State Water Laws: Environmental Reporter, (e.g., Alaska 706:0102,p.74) "Definitions of damage, benefit".

5. Bonner, T. et al. 1980. In Print. Engineering Handbook for HazardousWaste Incineration. Monsanto Research Corporation, Dayton, Ohio.SPA Contract No. 68-03-2550. U.S. EPA, Industrial Environmental Research

\jf Laboratory, Cincinnati, Ohio.

6. Cairns, John. 1980, The Recovery Process in Damaged Ecosystems. AnnArbor. Science, Ann Arbor, MI.

7. Casarett, L.J. and J. Doull, Eds., 1975. Toxicology: The Basic Scienceof Poisons. MacMillian Publishing Co., New York.

8. Cochran, R.S.; Yang, E. et al. 1983. In Print. Survey and Case Studiesof Remedial Actions at Hazardous Waste Sites. JRB Associates, McLean,Virginia and the Environmental Law Institute, Washington, D.C. EPAContract No. 68-01-3113 and Cooperative Agreement 809392. U.S. EPA Solidand Hazardous Waste Research Division, Municipal Environmental ResearchLaboratory, Cincinnati, Ohio.

9. Congressional Research Service. March 1980. "A Catalog of ResourceLosses from Surface Water, Groundwater & Atmospheric Contamination".

10. Gummings and Mattingly, EPA, July 1982. Assessment and Predictions ofEffects of Environmental Impacts on Fish and Wildlife Habitat.

11. Department of Commerce. August 1977. "Selected Annotated Bibliographyof Economic Values of Fish and Wildlife and their Habitats." Preparedfor Office of Water Research and Technology, Washington, D.C.

12. Department of Ecology, Washington State. 1980. Guideline for EvaluatingFreshwater Resources Damages.

13. Department of Energy. November 1982. Draft EIS, "Remedial Actions atthe Former Vitro Rare Metals Plant Site Canonsburg, Washington County,Pennsylvania". DOE/EIS-0096-D.

14. Department of Energy. February 1983. Draft EIS, "Remedial Actions atthe Former Vitro Chemical Company. Sire South. Salt Lake, Salt LakeCounty, Utah." DOE/EIS-009-D.

15. Department of Fishery, Washington State. 1979. Marine Water QualityCompendium of Washington State.

16. Department of Interior U.S. Fish and Wildlife Service, Division ofEcological Services. September 1980. Ecological Services Manual 101."Habitat as a basis for Environmental Aasessment."

17. Environmental Law Institute, Remedial Action Cost Compendium. In Print.July 26, 1983.

18. Environmental Policy Institute. April 1976. "Oil Study of PollutionLiability Insurance Laws."

19. Federal Register (40 CFR 300), Volume 47, So. 137, July 16, 1982.Sational Oil and Hazardous Substances Contingency Plan.

20. Geraghty and Miller, Inc. and Booz, Allen and Hamilton, Inc. 1982."Injection Well Construction Practices and Technology." U.S. EPA, Officeof Drinking Water.

21. Halter, Faoth., Joel Thomas. 1981. Ecological Law Quarterly. 10:5."Recovery of Damages by States for Fish and Wildlife losses caused byPollution."

22. Beer, John and D.J. Hajerty. 1977. Environmental Assessment andStatements. Van Hostrand Press.

23. ICF Inc. 1980. Chemical Substances Designation. U.S. EPA, Office ofToxics Integration.

24. JIB Associates. 1982. Remedial Action at Waste Disposal Sites. U.S.EPA, Municipal Environmental Research Laboratory.

25. JIB Associates, Remedial Action Costing Procedures Manual. In Print.August 26, 1983.

26. Kufs, C. et al. 1983. Procedures and Techniques for Controlling theMigration of Leachate Plumes. JRB Associates, McLean, Virginia. EPAContract Mo. 68-01-3113. U.S. EPA Solid and Hazardous Waste ResearchDivision. Municipal Environmental Research Laboratory, Cincinnati, Ohio.

27. Kuhnhold, W.W. 1979. "Impact of Argo Merchant Oil Spill on Macrobenthicand Pelagic Organisms." Proceedings from a Conference on Assessment ofEcologic Impact of Oil Spills.

28. McGraw-Hill Information Systems Company, Dodge Guide, New York, Hew York,1983.

29. Mitre, September 1981. "Working Paper."

30. Office of Coastal Zone Management, NOAA. 1980. Marine Resource DamageContingency Plan.

31. Pennsylvania Power and Light. January 1982. Laboratory and AquaticSurvey Results. Stroudsburg Coal Tar Site. CCN 773097/001.

32. Radian Corporation. 1983. In Print. Methodology Manual - EvaluatingCost Effectiveness of Remedial Actions at Uncontrolled Hazardous WasteSites, Austin, Texas. DCN83-203-001-60-10. U.S. EPA Solid and HazardousWaste Research Division, Municipal Environmental Research Laboratory,Cincinnati, Ohio.

33. Raniere, L. 1982. Field Guide for Scientific Support ActivitiesAssociated with Superfund Responses. Pacific Northwest Laboratory,Battelle Memorial Institute - PNL 4093, 112 pp.

34. Ricklefs, R.E., 1973. Ecology. Chiron Press, Portland, OR.

35. Robert Snow Means Company, Inc., Building Construction Cost Data 1983,Kingston, Mass., 1983.

36. Sorensen, Phillip. 1979. "Economic Evaluation of Environmental DamageResulting, from the Santa Barbara Oil Spill. (Preliminary Report)."Proceedings from a Conference on the Draft Ecological Effects of OilSpills.

37. Spooner, P.A. et al. In Print. Slurry Trench Construction for PollutionMigration Control. JRB Associates, McLean, Virginia. EPA Contract No.68-01-3113. U.S. EPA Solid and Hazardous Waste Research Division,.Municipal Environmental Research Laboratory, Cincinnati, Ohio. EPA540/2-84-00.

38. State of Alaska. 1982. Alaska Oil Spill Status Booklet.

39. Tetratech, undated, Water Quality Assessment: A Screening Procedure forToxic and Conventional Pollutants. Vols. I and II.

40. Toxic Waste Assessment Group, 1981. Alternatives to Land Disposal ofHazardous Wastes. California Governors' Office of AppropriateTechnology.

41. Tusa. W.K. and B.D. Gillen. Fred. Hart, Inc., 1982. Conference onManagement of Uncontrolled Hazardous Waste Sites. "Assessment of H.W.Mismanagement Cases." Washington State Department of Ecology.

42. U.S. EPA. In Press. Community Relations in Superfund: A Handbook.

43. U.S. EPA. Vovember 1980. Criteria and Standards Division, 1980. WaterQuality Criteria Dociaients; Availability. Federal Register.

44. U.S. EPA. January 1980. Damages and Threats Caused by HazardousMaterial Sites. EPA/430/9-80/004.

45. U.S. EPA. December 1981. Draft Guidance Manual for SuperfundFeasibility Studies.

46. U.S. EPA. Guide to the Disposal of Chemically Stabilized andSolidified Waste. U.S. Army Engineer Waterways Experiment Station,Vicksburg, Mississippi. Solid and Hazardous Waste Research Division,Municipal Environmental Research Laboratory, Cincinnati, Ohio.

47. U.S. EPA. 1982. Handbook: Remedial Action at Waste Disposal Sites.Technology Transfer. EPA 625/6-82-006, Office of Emergency and RemedialResponse, Washington, D.C.

48. U.S. EPA. 1981. Hazardous Waste Site Investigation Training CourseGuide.

49. U.S. EPA. Mulbolland, R. J. 1978. Rev Sampling Theory for MeasuringEcosystem Structure. Oklahoma State University, Electrical EngineeringDent.

50. U.S. EPA. Radeau Royal. 1979. Proceedings from the ConferenceAssessment of Ecological Impacts of Oil Soills. "Repco 140 Oil Spill".

51. U.S. EPA. October 1981. Protocol for bioassessment of BfS. Appendix A"Biological tests for Bioassessment of HtfS" EPA October 1981.

52. U.S. EPA. Office of Water Planning and Standards. July 1976. QualityCriteria For Water. (The "Red Book").

53. U.S. EPA. October 1982. "Water Quality Standards Handbook" (Draft).

54. U.S. EPA. 1984a. Health Risk Assessment Guidelines for ChemicalMixtures. Draft. Environmental Criteria and Assessment Office,Cincinnati, Ohio.

55. U.S. EPA. 1984b. Guidance for the Preparation of Exposure Assessments.Draft. Environmental Criteria and Assessment Office, Cincinnati, Ohio.

56. U.S. EPA. I984c. Revised Interim Guidelines for the Health Assessmentof Suspect Carcinogens. Draft. Environmental Criteria and AssessmentOffice, Cincinnati, Ohio.

57. U.S. EPA. 1984d. Interim Guidelines for Mutagenicity Risk Assessment.Draft. Environmental Criteria and Assessment Office, Cincinnati, Ohio.

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59. U.S. EPA. 1984f. Health Risk Assessment Guidelines for SystemicToxicants. Draft. Environmental Criteria and Assessment Office,Cincinnati, Ohio.

60. U.S. Pish and Wildlife Service. 1980. Habitat as a Basis for Environ-mental Assessment, Ecological Service Manual 101.

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63. Walsh, J. and D. Gillespie. 1983. In Print. Selecting AmongAlternative Remedial Actions for Uncontrolled Hazardous Waste Sites. SCSEngineers, Covington, Kentucky. EPA Contract No. 68-01-4885. US EPA,Solid and Hazardous Waste Research Division, Municipal EnvironmentalResearch Laboratory, Cincinnati, Ohio.

64. Washington State, Dec. 1980. A) "Marine Resource Damage ContingencyPlan." B) June 1980. "Guideline for Evaluating Freshwater ResourcesDamages."

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APPENDIX A

MODEL STATEMENT OF WORK

FOR CONDUCTING FEASIBILITY STUDIES

PURPOSE

The purpose of this feasibility study is to developand evaluate remedial alternatives for [specific site].The Engineer will furnish the necessary personnel,materials, and services necessary to prepare the remedialaction feasibility study, except as otherwise specified.

SCOPE

The feasibility study consists of eight tasks:

Task 8 - Description of Proposed ResponseTask 9 - Preliminary Remedial TechnologiesTask 10 - Development of AlternativesTask 11 - Initial Screening of AlternativesTask 12 - Evaluation of the AlternativesTask 13 - Preliminary ReportTask 14 - Final ReportTask IS - Additional Requirements.

A work plan that includes a detailed technicalapproach, a budget, personnel requirements, and scheduleswill be submitted for the proposed feasibility study.

TASK 8 - DESCRIPTION OF CURRENT SITUATION

Information on the site background, the nature andextent of the problem, and previous response activitiespresented in Task 1 of the remedial investigation may beincorporated by reference. Any changes to the originalproject scope described in the Task 1 description shouldbe discussed and justified based on results of theremedial investigation.

Following this summary of the current situation, asite-specific statement of purpose for the response, basedon the results of the remedial investigation, should bepresented. The statement of purpose should identify theactual or potential exposure pathways that should beaddressed by remedial alternatives.

A-l

TASK 9 - PRELIMINARY REMEDIAL TECHNOLOGIES

Based on the site-specific problems and statement ofpurpose identified in Task 8, develop a master list ofpotentially feasible technologies. These technologieswill include both on-site and off-site remedies, dependingon site problems. The master list will be screened basedon site conditions, waste characteristics, and technicalrequirements, to eliminate or modify those technologiesthat may prove extremely difficult to implement, willrequire unreasonable time periods, or will rely oninsufficiently developed technology. [The results of thistask may be requested as a separate memorandum (RemedialOptions negotiation Document) by the State or EPA.]

TASK 10 - DEVELOPMENT OF ALTERNATIVES

Based on the results of the remedial investigation andconsideration of preliminary remedial technologies(Task 9), develop a limited number of alternatives forsource control or off-site remedial actions, or both, onthe basis of objectives established for the response.

a. Establishment of Remedial Response Objectives

Establish site-specific objectives for theresponse. These objectives will be based onpublic health and environmental concerns, thedescription of the current situation (fromTask 1), information gathered during the remedialinvestigation, section 300.68 of the NationalContingency Plan (NCP), EPA's interim guidance,and the requirements of any other applicable EPA,Federal, and State environmental standards,guidance, and advisories as defined under EPA'sCSRCLA compliance policy. Objectives for sourcecontrol measures should be developed to preventor significantly minimize migration ofcontamination from the site. Objectives formanagement of migration measures should preventor minimize impacts of contamination that hasmigrated from the site. Preliminary cleanupobjectives will be developed in consultation withEPA and the State.

b. Identification of Remedial Alternatives

Develop alternatives to incorporate remedialtechnologies (from Task 9), response objectives.

and other appropriate considerations into acomprehensive, site-specific approach.Alternatives developed should include thefollowing (as appropriate):

Alternatives for off-site treatment ordisposal, as appropriate

Alternatives which attain applicableand/or relevant Federal public healthor environmental standards

. Alternatives which exceed applicableand/or relevant public health orenvironmental standards

Alternatives which do not attainapplicable and/or relevant publichealth or environmental standards butwill reduce the likelihood of presentor future threat from the hazardoussubstances. This must include analternative which closely approachesthe level of protection provided by theapplicable or relevant standards

No action.

There may be overlap among the alternativesdeveloped. Further, alternatives outside of.these categories may also be developed, such asnon-cleanup alternative (e.g., alternative watersupply, relocation). The alternatives shall bedeveloped in close consultation with EPA and theState. Document the rationale for excluding anytechnologies identified in Task 9 in thedevelopment of alternatives.

TASK 11 - INITIAL SCREENING OF ALTERNATIVES

The alternatives developed in Task 10 will be screenedby the Engineer to eliminate those that are clearlyinfeasible or inappropriate, prior to undertaking detailedevaluations of the remaining alternatives.

A-3

Considerations to be Used in Initial Screening

Three broad considerations must be used as a basis forthe initial screening: cost, public health, and theenvironment. More specifically, the following factorsmust be considered:

1. Environmental Protection. Only thosealternatives that satisfy the response objectivesand contribute substantially to the protection ofpublic health, welfare, or the environment willbe considered further. Source controlalternatives will achieve adequate control ofsource materials. Management of migrationalternatives will minimize or mitigate the threatof harm to public health, welfare, or theenvironment.

2. Environmental Effects. Alternatives posingsignificant adverse environmental effects will beexcluded.

3. Technical Feasibility. Technologies that mayprove extremely difficult to implement, will notachieve the remedial objectives in a reasonabletime period, or will rely upon unproventechnology should be modified or eliminated.

4. Cost. An alternative whose cost far exceeds thatof other alternatives will usually be eliminatedunless other significant benefits may also berealized. Total costs will include the cost ofimplementing the alternatives and the cost ofoperation and maintenance.

The cost screening will be conducted only afterthe environmental and public health screeningshave been performed.

TASK 12 - EVALUATION OF THE ALTERNATIVES

Evaluate the cost-effectiveness of alternativeremedies that pass through the initial screening inTaak 11. Alternative evaluation will be preceded bydetailed development of the remaining alternatives.

a. Technical Analysis

The Technical Analysis will, as a minimum:

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1. Describe appropriate treatment, storage, anddisposal technologies.

2. Discuss how the alternative does (or doesnot) comply with specific requirements ofother environmental programs. When analternative does not comply, discuss how thealternative prevents or minimizes themigration of wastes and public health orenvironmental impacts and describe specialdesign needs that could be implemented toachieve compliance.

3. Outline operation, maintenance, andmonitoring requirements of the remedy.

4. Identify and review potential off-sitefacilities to ensure compliance withapplicable RCBA and other EPA. environmentalprogram requirements, both current andproposed. Potential disposal facilitiesshould be evaluated to determine whetheroff-site management of site wastes couldresult in a potential for a future releasefrom the disposal facility.

5. Identify temporary storage requirements,off-site disposal needs, and transportationplans.

6. Describe whether the alternative results inpermanent treatment or destruction of thewastes, and, if not, the potential forfuture release to the environment.

7. Outline safety requirements for remedialimplementation (including both on-site andoff-site health and safety considerations).

8. Describe how the alternative could be phasedinto individual operable units. Thedescription should include a discussion ofhow various operable units of the totalremedy could be implemented individually orin groups, resulting in a significantimprovement to the environment or savings incost.

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9. Describe how the alternative could besegmented into areas to allow implementationin differing phases.

10. Describe special engineering requirements ofthe remedy or site preparationconsiderations.

b. Environmental Analysis

Perform an Environmental Assessment (EA) for eachalternative. The EA should focus on the siteproblems and pathways of contamination actuallyaddressed by each alternative. The EA for eachalternative will include, at a minimum, anevaluation of beneficial effects of the response,adverse effects of the response, and an analysis'of measures to mitigate adverse effects. Theno-action alternative will be fully evaluated todescribe the current site situation andanticipated environmental conditions if noactions are taken. The no-action alternativewill serve as the baseline for the analysis.

c. Public Health Analysis

Each alternative will be assessed in terms of theextent to which it mitigates long-term exposureto any residual contamination and protects publichealth both during and after completion of theremedial action. The assessment will describethe levels and characterizations of contaminantson-site, potential exposure routes, andpotentially affected population. The effect of•no action" should be described in terms ofshort-term effects (e.g., lagoon failure),long-term exposure to hazardous substances, andresulting public health impacts. Each remedialalternative will be evaluated to determine thelevel of exposure to contaminants and thereduction over time. The relative reduction inpublic health impacts for each alternative willbe compared to the no-action level. Formanagement of migration measures, the relativereduction in impact will be determined bycomparing residual levels of each alternativewith existing criteria, standards, or guidelinesacceptable to EPA. For source control measuresor when criteria, standards, or guidelines are

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not available, the comparison should be based onthe relative effectiveness of technologies. Theno-action alternative will serve as the baselinefor the analysis.

d. Institutional Analysis

Each alternative will be evaluated based onrelevant institutional needs. Specifically,regulatory requirements, permits, communityrelations, and participating agency coordinationwill be assessed.

e. Cost Analysis

Evaluate the cost of each feasible remedialaction alternative (and.for each phase or segmentof the alternative). The cost will be presentedas a present worth cost and will include thetotal cost of implementing the alternative andthe annual operating and maintenance costs. Bothmonetary costs and associated non-monetary dostswill be included. A distribution of costs overtime will be provided.

f. Evaluation of Coat-Effective Alternatives

Alternatives will be compared using technical,environmental, and economic criteria. At aminimum, the following areas will be used tocompare alternatives:

1. Present Worth of Total Costs. The netpresent value of capital and operating andmaintenance costs also must be presented.

2. Health Information. For the no-actionalternative, EPA prefers a quantitativestatement including a range estimate ofmaximum individual risks. Wherequantification is not possible, aqualitative analysis may suffice. Forsource control options, a quantitative riskassessment is not required. For managementof migration measures, present aquantitative risk assessment including arange estimate-of maximum individual risks.

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3. Environmental Effects. Only the mostimportant effects or impacts should besummarized. Reference can be made tosupplemental information arrayed in aseparate table, if necessary.

4. Technical Aspects of the RemedialAlternatives.The technical aspects of eachremedial alternative relative to the othersshould be clearly delineated. Suchinformation generally will be based on theprofessional opinion of the Engineerregarding the site and the technologiescomprising the remedial alternative.

5. Information on the Extent to Which RemedialAlternatives Meet the Technical Retirementsand Environmental Standards of Applicable ""Environmental Regulations.This informationshould be arrayed so that differences in howremedial alternatives satisfy such standardsare readily apparent. The general types ofstandards that may be applicable at the siteinclude:

a. RCRA design and operating standards; and

o. Drinking water standards and criteria.

6. Information on Community Effects. The typeof information chat should be provided isthe extent to which implementation of aremedial alternative disrupts the community(e.g., traffic, temporary health risks, andrelocation).

7. Other Factors. This category of informationwould include such things as institutionalfactors that may inhibit implementing aremedial alternative and any othersite-specific factors identified in thecourse of the detailed analysis that mayinfluence which alternative is eventuallyselected.

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TASK 13 - PRELIMINARY REPORT

Prepare a preliminary report presenting the results ofTastes 8 through 13. Submit [specify number anddistribution! copies of the preliminary report to EPA andthe State [specify recipients]. (Note: EPA and the Statewill review and select a remedial alternative.)

TASK 14 - FINAL REPORT

Prepare a final report for submission to EPA and theState*. The report will include the results of Tasks 8through 13, and should include any supplementalinformation in appendices. This report will include aresponsiveness summary on public comments received.Submit [specify number and distribution of copies] to EPAand the State [specify recipients].

TASK 15 - ADDITIONAL REQUIREMENTS

[Specified based on site-specific issues.]

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APPENDIX BPROCEDURES FOR PLANNING AND IMPLEMENTING OFF-SITE RESPONSE ACTIONS

UNITCO STATES ENVIRONMENTAL PROTECTION AGENCY. o.c

HKMORAMPPM

SUBJECT: Procedure* for Planning end lapleaentlng Off-siteKeapeaaa Act'loaa

lion,Acting Assistant Administrator

V

TO: legloaal AdainlstrstorsKegioaa I-X

Thla aaaorandu* addresses procedureo chat aaat ba observedwhea a raapaaaa.accloa involving off-lit* storage, eraataaat ordlapoaal of haxardoua tubataaeaa i« talaetad uadar cha Coapta-haaalva Kavlroaaaatal Raapoaaa, Coapaaaacloa, aad Liability Actof 1980 (CEXCLA). aad tha Raaoarea Coaaarvatioa aad Xaeovary Act(ICtA). It prohibit* uaa of a ICIA facility for off-alt* aanaia-aane of Suparfaad haaardoua aubataacaa if it baa aiffaificaatRCtA violacioaa1 or ochar anviroamaatal eoaditioaa that affacttha aaelefactory oparaeioa of tha facility. It alae addraaaaara^uiraaaata for analyalof aad talactiaf raapoaaa aetloaa thatlavolva parvaaaat aathoda of aaaaflnf haxardoaa aubataacaa^

la Novaabar of 1984, aaaadaanta to tha Kaaourea Coaaarvatlonaad lacovary Act war* *aaetad. Thaaa aaaadaiaata lapoaa navraquiraaaata for th* «afa aaaafaaane of haaardoua waataa. latha eaa* of laad dlapoaal faeilltiaa, tha a*aad»aata r*a.alrathat cartaia typaa of units (nav, raplae*a*nt and lataral cxtan-•loai) b* doubla liaad by Hay 9, 1983. Th* aa*nda*ne* iapoa*tceholcal raqulraaaata to oaaara that whaa land disposal facllltlatara uaad thay ara uaad saf*ly<

EfA lataada to follow tha diractlon ••tabllshad by Confrr«*«la tha RCtA aaandaanta whan uadartaklag on-alta raaponaa actions

A significantviolation includaa a Class I violation as d*fin*dby th* RCXA Eaforccaant Raspons* Policy (0*c*«b*r 21, 1984).This policy d*fln*s a Class I violation as a violation thatrasults la a calaas* or a serious thraat of ralaasa of hazardouswaata into tha tnviroaaiant, or involves th* fallur* to assur*that (round watar will ba prot*ct*d, that propar closure andpost closure activities will b* undertaken, or that hasardouswastes will ba destined for aad delivered to ftC&A paraitteH orInterla status facilities. Th* policy contains a Hat ofexamples of violations which ara Class I violatioaa. Rejtlonsshould recognize that violations other than Class I violationsaay b* significant for purposes of these procedures, dependingon tha situation at cha facility.

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••4 whoa reopoaoo actloaa Involve off-tic* eana*eoenc of ha«ardoos•••OCMCOO. Tola MMraadaj) deceit a how eho Agency plaaa toeckleve ckeeo geelo.

Seccloa I of chia aoaieraades) discusses backgrouad Issues.Sectlea II * discusses the need to consider treataoac. recycliaya«4 ro«*o before off-sice laad disposal Is used. Soetloa II Idecalle procedures that smsc b« followed in selecciag «ay off-«ictfaelllcy for •••agoaoae of haaardoaa •ub«t«ac««. THla aoetlonalso 41«c««a*a eho ertcoria ea ko aaod ia aaklag eho •olaeclox.For facillcioo la aaaooa««ac •oaicorlag. thl« part acatoa chateoodltloo* •hick load co aa4 roaalc fro* balag la ••••••••at•••Itorlag MT eovoeleaco coadltloaa that raador tho faeiltcy••••icahlo for 4iaaoaal of kasardoaa •«b«eaaea«. Thoroforo.•hoa o faeiltcy la la aaaaaavoac. tho eoadltloaa vhleh laad Cocho roo«lro4 aaao*a*oat. aa4 «ay •oaltorlag data, avat bo aval*-•co4 co docor«lao If cho facility aoooa avch coodltlona. If so.Cho faelllcy «ay aoc ho aao4 aalaaa cho owaor or oporacor covaltato eorroet cho problaco aad cho aalc eo bo aao4 for dlapoaalpoaoa ao prohloaa.

Soettoa III dlacataoa ICtA aaalfaac ro«alro«oaca. Soecloa IV41oc««oo* PCI disposal rooalroaioaca. riaally, Sactloa V detailshov this policy will bo laplavoatad. Ateachvoac A Is a charta«ojsj«r:cla< cho policy oa aoo of off-site ICtA facilities. Thischart shovld ho eaed la eoajaaecloa «lth the policy doeoaieae, notla lie* of 1C.

These procedures are applicable co all raapoaao aad eaforce-•eat actioas takea p«rs«aac Co CCICLA aad sactloa 700] of 1C1A.

This •o«eraa4«sj replaces galdaace eaciclee' 'laqalreaieats forSoloeclag aa Off-Sico Opcioa la a Saperfand tespoaao Actioa*.dated Jaevary 28. 1983. Tils policy Is aa iaterl* oao that theAfeacy Inteads Co pahllah aa a aoclco ia the federal lesjisterla order to receive pahlle eoatateat oa Its provisions. Afterreviewing these coaaeacs tPA will determine whether revlsioasere aecessary.

These revlsioas scroagchoa previous requlreaeats ia several•ays:

* Coverate - This aosraraadaai extends r«4uir*aents toeaforceceac aetloaa aader 1106 of CEXC1A «nd 17003 of *C2A.aad expaada reqalresjoaca for reaoval actions.

* Ose of Treataeat - These procedure* require considerationof treetaeac, recycling or reuse far all respoase and

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eaforeemeat ectlone, to fatter the use of aore permanentsolutions, earf, in the case of remedlel actions, whereeoet-effective. The Agency Is not certain whethersufficient capacity is available at this time to u»etreatment ia all cases »here it i« feasible. As moreInformatloa oa capacity becomes available, the Agencywill re-exemlne requirements for treatment to determinewhether they caa be strengthened. The previous proceduresdid not eddreee uee of treatment.

• Requirements for a treetajent. storage or disposal facilityPrevious guidance required inspection within 12 southsbefore coatract avard for storage, treatment or disposal.The revlsioas require Inspection within six months ofactual storage, trestaent or disposal. It also statedthat if a facility had deficieacee that reeulted in unsoundtreataeat, storage or disposal practices it should aot beused. The guidance also required 1CIA violations thatadversely affected facility perforaence to be correctedprior to contract award. Under the revisions, a facilitythat has significant RCXA violations or other environmentalconditions that affect its satisfactory operation may notbe used ualeee certain coaditloas are aet. First, thereauat be a coapllance agreement in piece to correct alldeficieaciea at the facility; second, the unit that isused aust not cause or eoatrlbute to significant problemsac the facility. This provisioa recognises chat in soaesituetloas it is lafeasible to complete correction of ellviolations prior to using a facility (for example, it aeytake several years before pumping and treating of ground-water is coapleted) sad that there aay be a unit at sucha facility that is souad.

* Land Disposal Facilities - The ''84 RCRA saendaents imposenew requireaents on land dlspo..i facilities. When useof such facilities is contemplated, the policy requires thatthe facility aeet these alnlau* technical requireaents.

I. BACKGROUND

facilities thet are not in compliance with RCRA rsqulrenentsaay be unacceptable to use for treatment, storage vr disposal ofhasardoua substaaeee fro* response actione. Facilities used foraanageaent of snbstsaces in connection with response actionsshould not pose a significant threat to public health, welfare orthe environaent.

CKXCLA contains two references to off-site tianagenent ofhasardous substances. First, CKXCLA section 104(c) requires, ase condition of Fund-financed remedial response, thet the Stateaseure the availability of an acceptable facility in conpllancewith the requireaents of subtitle C of RCRA for sny off-siteaanageaent of hasardous substances. Second, where renedialaeaauree Include off-site storage, treetaent, destruction orsecure disposition, the etatute alao requires such aeasures tobe aore coet-effectlve then other remedial aeasures, create newdisposal capacity ia compliance with Subtitle C of RCRA or beaeceeeary to protect public health, welfare or the environment

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frea • proeeet or petoatlal rick which aay be created by fartherexpeeare to aebataocea. Sectloa 300.t) (b)<») of the letloaalCeatlogeocy Flea (40 CFt 300) otatee that whoa off-tlte •eclon :•takeo to ceeeectiea with • roaavel actloa tho facility •••4 foroff-elte aaaageaeat aaet be ta coapllaace with Sebcitle C of•CBA. TMo aeaoraedoo. eatabllabaa procadarea for iapleaeatinithooo CSBCLA aad Kt prowlaloaa.

Theae procederea ••ply to «11 reaowal, reaedlal. aad eaforce-•••C octlovo t*ko« ••rsvaac to CIICLA a«4 ••ctlo* 7003 of 1CIA.Aay ochor oorttoo oarfortaklog cl«a«o aador othor ••thorleio*• ro «rfo4 to co«yly with thooo •rocoo'oroo. la tho cooo ofS«porf«a4-ftaoac«4 roo>owol octloao or *aforco«oat aetloao takoaoo o rovawol actlea la roopoaoo to •• la««dl«t« aad •igaifleoattkrooc. coaiplloac* with thooo oroco4«reo !• aoadotory valooo thoOo-Scoao Co«r4iaotor (OSC) cotoralao« thot tho oxlgoaeloo of thoottvotloo. roovlro off-«lto trootaoae. otorofo or 41opoool wlcheatfollovlag tho roooireaoata. Tkla oxeoftloa aay bo aoed la caaet••ore tho OSC belle*** that tho I«eie41acy of tho throat poee4 bytho ••botooceo aakoo It looeratlve to reaowe tho eabotaaeoe aadthere lo laeeffIctoat tioe to obaorwo thoae •roeo4ereo wlthovtea4aogeria( •w.bllc health, volfare or tho •avlroaveat. ta a«e*icaoeo. the OSC thow.14 coaol4or. to tho extoat poaeible. tevaoraryaoletioao (e.f.. later!* atoraio) la order thot the feaalbllltyof eo:a| troatejoat caa bo owaleate4 prior to a decision to eoeIea4 41apoool. Aloe, la a«eb caooe. the OSC east provide awritten •xplaaatloa of bio doelaloa to tho lefloaal Ad«lal»trator.Thlo ecplaaatloo aho«ld bo prowlded vlthla tO 4ayo of takla*tho aetloa. la logloao la which a«thorlty to oak* reewval decl-•loao hao aot booa tally dolefotod by the Keglooal Ad«lalttracor,tho deelsloao 41«coooe4 abowe ««at bo aado by the legloaol officialthat la delegated roMvel doelaloo •eklag aathorlty.

it. rtociDuiES rot siticriwc IAIAIOOCS WASTE xAHACgMtrr TACILITIES

TM» aoctloo dlaeaoooo la detail Che requl reveatt legloao••ot follow la aoaeealag aad aelectiag ta off-tlta 1CIA facilityfar •aaageaieoc of Seperfuad haaardooa tubataaco*. ?art A reqaireacoaolderatioa of treatseat. rocycllax ar rauae for oa-alte aadoff-alt* actloaa la order to foater the «ae of aor* perwaoeat•etaoda of aaaaglag haaardooo aebataacat. Theae policlea arecoaalateat with dlrectioaa takea by Coagreaa In the 198* aaead-•oata ta tho Kooo»rco Coaaervacloa aad lecovery Act. Fnrtheraor*.Part • of title aectloa eotabllahea proctdarea lefioaa aoat as*la aelectiag aa off-aite ICLA facility for aanagevent of hazardousawbataac**. Where eff-aite laad diapoaal aaat be uaed. thla Pinree,alrea that diipoaal facllltiea be la coopllaoc* with the appll-cabl* cechalcal r*«ulr*oeot* of tCtA.

A. Troataeat

It ia CPA'a policy to peraee reapoaae actloaa that eaetreotaoat. rewoe or recycliag ower laad diapoaal to the craateat

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exceat practicable, coaalataat with CXICtA reouireaenea forceat-«<fe«tiv« reae«lal actlea*. CVA. require* chat such alterna-tive* be eoaeldered for all Fttad-flaaaced and private pareyreaeval and reaedial accloaa. Par Puad-f laanced reaovels or•af oread actloaa la reapoaae to iaaadlate aad significant ehraaes,treacaeae, reuee or recycling muee ba eoaaidarad. unless ehe OSCdateralaea that treataeat, raaaa or recycling aothoda ara noeroaaoaably available eoaalderiag tha cxigenciea of eha situation,ar thay poaa a •Ifnlfleaac anvlroaaaaeal haaard.

Vhaa davalopiac raaadlal alearaaelvaa, traataaat, rauaa orraeyellaf auae ba eoaaidarad. Such alcarnaclvaa should not baaeraaaad one oa eha baala of eoae aloaa. Saetloa 300.6l(h)(l) ofeha tier allow* rajaetloa of alearaaclvaa durlaf eha aeraanlngataia baaad aa eoae, only waaa eha eoae of eha alearnaci*a faraxeaada eha eaae of oehara (a.f., by aa ordar of aagalcuda) anddaaa aae pro*! da aubacaaclally graaear public haaleh aad aaviroa-•aacal baaaflea.

Oaeallad analyal* of ehaaa alearaaelvaa ihoald Includaeoaaldaraeioa 'of long-tara af f aetlvaaaaa of eraaeaane aad eoapara-clva loaf aad chore ear* eoaca of eraaeaane aa eoaparad eo ocharraaadlal alcaraacl vaa. Finally, whaa raeoaaanding aad falaecingtha approarlata raaadlal aeeloa, eraaeaaat. rauaa or racyclinjaay ba found aora proeacelva of public haaleh and eha aavlroaaancChan laad dlapoaal. Such alearnatlvaa aay ba raeoaaandad aa ehaapproprlaea raaadial aetloa whara tha daeailad aaalyata ofalearaacl**a ahova ehae eha alearaaclva la aara eaae-af faecivathaa othar* la alaialslag tha> daaaga eo public haalth, tfalfaraor eha aavlroaaane. During eha aaxc alx aoaeha, S?A will badavaloplng additional guldallaaa for avaluaeiag eha coaparativalong-tara eoaea of eraaeaaae aad laad dlapoaal.

Ac ehla elaa, eha Agaaey doaa aae know eha currant andprojaeead eraaeaane capacity available, aor eha naada or capacityehac will ba raaulrad for Suparfuad aetlona In tha futura. 0»«reha naxc tavaral aontha, eha Aganey plan* eo undareaka a studyof available eraaeaane aad inearia storage capacity and needs.Once caapleted, thia analysis will provide inforaatloa on ereae-aane faellielea eurranely operating for Kagiona eo use. Additionalinformation oa capacity will be provided ac a lacar dace througha aora coaprehaaalva capacity survey being undertaken in supportof the lapleaaacaeioa of the 1984 KCHA aaendaenta.

B. Reauireaeaea for selecting storage, treataent or disposalfacilities

Selection of sn ap-proprlaee facility for off-sice managementof hasardoua substances requires ehae a judgaene be aede asCo eha overall acceptability of the facility to receive thesubstances aad the acceptability of Che unit that will receivethe haxardoua substances. la aaklng this judgment the followingseepa auae be obeerved:

1. Tha owaar or operator of any hasardous waste aanagenentfacility under consideration for off-tic* storage, treatment or

octieaa aa4er end* or aoctloa 7003 af ICtA Mat hava •• applic-able tCtA aomc •» latarla atatae.2

2. A tCtA eeeipllaace laepactlea •»•« •• performed at aayka*ar4*«e vaate MaagaMat facility kefore ic cam receive hacardoaaeeketaacea free) • reepeaae actlea. Thia laopectloe Mat •••••••tether tkere era aoy algalficaat vlalatloao or other eaviroaMetalcee41tloae tkac affect tho aatlafactory ovoracloa of th« facility.Tk« ICtA eo«flla«e« laa»«ctl*a mmtt ka«« takaa placa aec awra tha«•ts Macho trior to tho •corafa. troaccoat or dlaooaal of thohoaartfovo awhocaacoa fro* a roaoaaao actloa. If tho laoooccioaho* oot takoo olaco or la oot acho4»lo4, IIK/FIT cootraetorMr000*01 atay eo«4«cc tho laaooetloo «ador tho dlroetioa of tho•••vcy Project Offieor. •orklag la eoeooratlo* »ltk ICIA loglooal••raoaaol. If Rofleoa «ao eoatractor aoraoaaol. tho togloo ako*14o*o«ro tkoc ovck peraooael aro •4o^matoly tralao4 to ce«4«ctla«*«<tlo«o. Parthor («14aoeo oo coo4octl«« laaooctlooo vkoa afacility la kaiag eooo!4oro4 for aaaafoaoat of haiar4*aa aaaataacaawill »o lao««4 la tho ooar fatara. Tko PT «3 aa4 PT •* ICtA laialo-a«atatloa Plaaa aotakliah eoaollaaeo aoaltorlag aa4 aaforeowaatt argot a. Par PT S3 tho gal4aaca roqalrea Coajarahaaalva Croaa4-Wator Baattorlaf Ivalaatloao (CCHIa) at oaa third of tho groaa4•atar a*alterlag faclllclao. Too ariorltloa for thia type oflooaactloa ara all faellltioa raealvlag aaacaa fro* Sa**rfaa4aitaa.

la Stataa with Pkaae t or IX latarla aatherlsatloa or fiaalaacborisatlo*. tko laaaactlaa ahoal4 ba eoa4acto4 la accordaaeawith Staca ragalatlaaa or aor*lt eoa4itloaa. IP& tagioaaak«al4 alwaya lavolva Statoa whoa aa4artaklag aa laapactlaaat a tCXA facility that la llkaly to accoot Sooorfvad vaataa*

tagioaa aaat aaa tka raaalta fro* tha looaoctioa, aloavwith athar laforvatloa, ta datarmlao vhathor tho facility la aaocceatable oaa.

loth pormlts aa4 latorla atatao aaaly to (pacific waataa aod•pacific atoraga. traataoat or 4i*poaal proeaaaaa. Tha loaodialProject Xaaager (tPH) or OSC aaat dacaraioa that tha facility'spar«it or latorla atatao tacladaa tha aaataa that vaald hatraaop*rto4 t* tha facility aa4 tha typo of procaaa for whichvaatao aro kalag takaa to tha facility. locaaaa of thoaocoacaraa. it la laportaat that facility salactloa ba coordinatedwith tCIA poraoaaal. lotrovor, aot all CS1CLA aahataacaa arohaaardoaa waataa aa4ar ICtA. Thorofora, It !a poaalhlo that apartlcalar porait aay aat co*ar a hasardoaa tahataaca that aayka tafcaa to th* ICtA facility If It la not a haiardoaa vaato.Maroovar. la aoaio aitaatiooa a haiardoaa ••bataace aadar CCtCLAaay trigger 41apaaal ro^alroawata aadar otbor lava (for axaapl*.PCSa aad aoao ra41oactlvo aakataacaa). la sack eaaao thoapplicable ro^alroaioata of thaaa othor lawa aaat ba obaerved.

B-6

9. It ia iJA'e policy to ainiaise the oae of lead diapoaal iaaeeerdaace with the directloa takea by Coagreee ia aaeadiag KCKA.Whore lead disposal is need, ehoao saendaeata establish aow tech-nical ataadarda for laad diepoeal faeilitiaa. lew diapoaal ualta,lateral expaneione aad replaceaeat unite (defined •• of Moveaber 8,1914) of interia statue laadfllla aad aarfaee lapouadaeata auathawa at leeet tw« llnere tad • leachata doccecioa, eolloeeioa••d raaovcl lyaeoai abovo (la cho eaao of landfills) aad botvooaebo liaora, if thay roeaiva waataa aftar Nay 8, 1983. All fuad-fiaaaead aad aaforead raapoaaa aetioaa (ravoval aad raaadlal)iaTolTlaf eh* off-aica diapoaal of baaardova aabataaeaa auat InvolT*«ao of diapoaal faeiliciaa that aro ia eoapliaaea with applieabla1CIA aiaiaaa taebaleal raqiaraaaaca. Thia aaaaa that walea firaeraeaiviag waacaa afear Hovaabar 8, 1984 eaaaoe raeaivo vaaeaaaftar May 8, 198S if aot doubla llaad. Tha 1CKA atatnta doaaallow eoaciaaad «aa of oxiatiag tiaiea aftar that data. Xa eoaaldar-iag vhathar to aaa aa axiatiag vait that doaa aot aoot tha doabloliaor raqnlraaaata, tba Agaaey «ill eoaaidor tho eoxlcity. p«raia-taaea aad aobility of tha hasardoaa aabataaeaa aad tho aaod toaagragata thaao aubataaeaa froa othara. Such a aait eaa baaaad oaly if it ia shown to adaqaataly protaet pablie hoalth aadtha aoylroaaaae.

CKKCtA haaardoaa aubataaeaa which ara aot haaardoaa waataaaadar ICKA aay, ia aoaa eireuaataaeaa, ba diapoaad of ia othorlagal valea. la aueh eaaaa, diapoaal should caka plaeo ia aeeordancawith othar lagal ra^airaaaata. laaardoao aabataaeaa which ara aothasardoaa waataa aay ba takaa to a 1C1A aait nador tha taraa oat-liaad ia tha praeaadiag paragraph, or to a aalt lagal nadar atharatatatory provisions (for sxaapla, FCBa aay ba diapoaad of ia aTSCA approvad diapoaal facility aad radlocatlva aatarlala ia aradioaetiva aatariala diapoaal facility). Thia diapoaal auat baeaaaiataat with Saetioa I0*(c)(3) of CItCIA, whoa applieabla.

4. lataria atataa laad diapoaal faeilitiak uadar eoasidars-tloa for off-sita disposal auat hava adaquata ground wataraoaitoriag data to aaaaaa vhathar tha facility poaaa a thraat toground watar.3 -Daa to tha lack of eoapliaaea with KCKA groundwatar raqulraaaata, available data aay aot ba adaquata to aaaaaatha facility. Moraotrar, lack of avldaaca of eoataalnatioa froatha aoalcoriag data doaa aot naeaaaarlly aaan tha facility iaaacura. Tha aoaitoriag data aay ba faulty. Ia additioa, tharaaay ba othar problaaa at tha facility sueh aa air aaissions orsurfaea run-off. Vhara doubt exiata concerning tha acceptabilityof a facility, aa oa-slte inapaetion should ba undertaken cospecifically addraaa theaa eoneeraa. Where possible, thisoa-aita inapeetlon ahould ba part of tha required KC1A coapllanceiaapectlon.

All reaalaing land diapoaal parait applications will barequeated in FT 1983. Thaae applicationa contain auaaarleaof ground water aoaitoriag data obtained during tha ineerlastatue period, aad ara required to identify any pluaecontaalnatloa.

B-7

S. laia* laie»»**iesj gathered frea the eoapllaaca laapectloa.ether data eearcee (••••. Id* facility perolt data). aay otherfacility visits aad all ether relevaac laferaatioa. legloealOffices MSC aval sat a aad aake s Jadgaeat em ths acceptability of•sis* *•• facility for ataraga, treataeat or dlapeaal of hatardoaaeasataacea. For tho facility as • •tool*. thla evaleatioa ahoaldcoealder whether there are aay IClA violation* or other eaviroa-eescsl ceedltloee4 at tho facility which affect Ita aatlafactoryeporscto*. Tbia evaleatlee aho«14 iacl«4o eoaaltforatloa offacility overatloaa as trail aa whether there are physical coadl-ti»»a ac ths facility that soas a •Igaifleaat threat to swhllchealth, welfare or ths oswl roaateat . for facilities la aaaoaaaeatSMiterlag. ths coa41tloea which Iss4 ta rse,w.lra4 aaaeaosoacs«s4torla(. as well aa raawltlsf sealtarlaf data, swat he evaluates*.T«« swsls«cis« alas ehe«14 cosalcer ths aataro as4 ««a>tlty of thssvsscascss a«4 whether It la fssslhls to treat the ashatascoa priorts la«4 41ss««*l «• Bitlgats aay a4vsras effects.

*e S«s«tf«s4 haaar4s«a a«hataacea ahall %• caksm off •sic* tos tCtA fscility if ths Ksglss 4ster«iasa that the facility hasaifslf least ICtA vlolatlosa or other eswlroasisstal costfitloss thstsffsct ths oatlafactory oooratles sf ths facility, aalsssh«th ths fsllswiag coaaltleee ara set:

(1) Ths ovasr or operator s»at coswit. throsfh as esforce-ahls sgrssswat (i.e.. coaaest order or dscrss). tscsrrsct the prohles). Ths •greo«sst Mst hs elo«4before ths facility say receive ths hasardsesashstascss. la add! ties, ths Kaglsssl Admlalatrators«sc dstermlae that ths agrsss>sat la likely ts rss«ltis correctlos of ths prshlsa aad the ovssr or operatorof the facility la cspahls of casjpllaaca with ths tsrvssf ths agrsssiest; aad

(2) Oiapssal osly occsra wit hi a the facility at a aew orexiatiac esit thst la la eoapliaace with ICIA reeeire-•eat a. The aew or exlatiag aaie a«at aot eoatrihetois aay algaificast way to adverse eoodltioaa at thefacility.

in. iu«irtsT

If aa off-aits sptlos la chsasa. a aaalfaat for tho craoapor-taclsa of ths hssardeaa waeto aaat he obc«laed« The aaalfaat aaat

* It la recogaised that ths 1CXA ragalatiaaa aay not at thiatia>s csvsr all eavlrosvestal ceadltloaa at a facility. Ketioaaloffices aey coaalder other eavlroaajoatal factora at a facilityaader cessideratloe lacladlag other State aad/or Federaleavlroe*eatal lawa. If a facility la ia aaaeaaaeat aooltor-iag. the coadltloea which load to aaaeacaeet aoaltarlaf aayceastitacs eavlroaaisatal coadltloaa that adveraaly affectfacility eperatleaa. Is aach caaea. lefloaa ahovld aaaoaa thecesdltloaa at the facility prior to aaiag the facility forSeperfead parpesss.

3-8

be la coapllaace with 1CIA far the traaaportatioa 9! hasardousveatea. The aaalfeet euat b« • Uaifora Ha*ardoua Waste Manifestla coapllaace with requireaeata at 40 CM 262 (aae 49 Ft 10490.March 20, 1914). The lead agaaey or other party undertakingthe cleanup aaae aaaure that tha tranaporter properly aotlfieauader tCSA aectloa 3010* Whara tha lead agaaey allows eoatraetorato fill oat tha aaaifeat, tha agency should aaaura that thaaaaifeat ia properly fllad.

It. PCJ DISPOSAL MOPIMMIMT3

tequlreaaaca for tha dlapoeal of PCBa ara aatabliahad la40 C7I 761.60. eeaerally, Chaaa ragulationa require that vhaaavardiaaoaal of PCla ara uadartakaa, ehay auat ba laelaaratad, nalaaatha eoneantratioaa ara laaa than 30 pp«. If tha eoteaneratioaaara hatwaaa SO aad SOO ppa, tha rvla provldaa for cartain aseap*tioaa that prorlda altaraativaa to tha laetaaratloa ra^alraaanta.Tha principal altaraativa ia diapoaal ia aa «?A approvad landfillfor PCla. Laadfilla aaad for PCB dispoaal a«at ba laapaetadwithia aix aoncha prior to diapoaal. Kaflona auat datarmiaa thaacceptability of tha facility baaad oa tha aaaja critaria «aad toavaluata ICtA facilitlaa la Sactioa II.I.5.

V.

Beginning (30 daya froa dace thla daeaaaat ia signed) allRecorde of Oaclsioa (ROOa) aad Knforeaaeat Deciaioa Oocuaeata(IDOa) for Superfuad-lead aad anforceaent lead aetioaa. respec-tively, aaat include a discussion of eoapllaaee with thaae pro-cedurea for altaraatlTee involving off-alta aaaageaeat at Superfuadhasardoua sabataacea at RCXA faellltlaa. Deciaioa docuaaata forrcaovel aetioaa also should Include discussion of coapllaace withtheaa procedurea. It ia recogaised that actual offsita facilityiaforaation will not ba available at the 100 atage. However, thetl aad FS ahould uaa actual off-site facilitlaa In coating raaedlalalternatives, la order to have coat flgurea that are aa accurateaa possible. It ia recognised thet additional facilitlaa arelikely to be considered during the bidding proceaa. Any facilityultlaately selected for diapoaal. traataeat or storage aaat aeetthe requireaeata of thla policy.

Provialona requiring eoapllaaee with theaa procedurea auat beincluded la «ny contracts for response, cooperative agreeaentswith Stataa undertaking Superfuad response and all enforceaentagraeaeata. For oagolag projects, theae provisions will baiaplaaeated ee follow*:

RI/FS: The Raglan* shell iaaedletely notify Agency contractorsand Stataa that 1) alternatives for off-site eanageaentof waatea auat be evaluated pursuant to the provisionsof this policy, aad 2) conalstent with the policy onother envlronaental lawe, treataent alternative*should not be dropped during the screening stage.

ROt The Reglone shall laaadiataly notify Agency contractors,tha Statae. aad tha U.S. Aray Corps of Englneera thet

B-9

•11 r00*41eo tko( ioclada aff-oita dlapoaal of kaaardooa••kocaacee o«ai coaiply vitk tka provlaloaa of tkiapolicy portaialag ta (elect!** of *a accaptaklo off-tie*facility.

Tko togleaa akall inodiately aaaaaa tka eoaipllaacaatatoa of laod diapoaal facllltlea racolviag kasardoaa•aataa fro* aagolog project*. Par a facility aot iacoopllaace. tko logleo akoold take loaiodlate atapato krlag tko facility lace coajpllaoca wick tko policy*

Actlooo cvrreacly oodor aagotiatioo aad all fataraactiooa awac coolly wltk tkoaa procedure*. Cxiatlagagraavoat* aood aot ko aajoadod. lovovor. KPA raaerveetko rlgkc to aooly tkoae pracadaraa to oxiaeiagagroooMoco. to Cko exteat It la cooaiataat with tkoroloaaa aad raopoaor elaoaaa la tko *ettle«aat agree-a>ooc (Soo tko laterlo C11CLA Settleaoat Policy. Partfll; TkoaMO, Prico, laklcat; 3ecaaiker 3. H84).

If tko roaaoooo accio* ia arocaodiag aadar a Fodaral-load,tko togiooa akovld work wltk tko Cor*a at lagiaoora or tPACoatracta Officor to aogoclata a cootraeta oodlflcatloa to aaodatlog cootract, if aocaaaary. If tka raaaoaoo actio* la•rocoodiag aodor a Scata-load. tko loglooo akovld aoood tkocooporaclvo acraaawot. Cccaytlooo for asiatiag coatracta aadco«p«**t**« agroo«oota oay ko allowod oa a caaa-ky-caao koalaky tko appropriate loadaaartara Offica 91ractor.

All togioaa *«at adapt procodaraa to taploaiaac aad coociaoal-ly oooltor covpliaaco »ltfc tkoao ro^oiroaioata. Tba procodoroa•vac iacla4o doalfaatloo of a aaaacraoac official vko ia roapoa»aikla for provldlag lafarvatio* oo KCtA faclllclaa ia tka kocioato ockor togioaa. It It tko raapoaaikllity of tka lagioa la•kick cko 1C1A offaita facility ia locatad to •••••• tho aeeaat-akility of tko facility ia eaoaoltatiaa with eka •••loo plaaalac toakip vaatoa to tko facility. Tka aa*o« of thaaa official* akoaldko pro^ldod to tko Offico of Vaata Prograaia laforcooaat ky May21. 19t). Tkaao aa«aa will tkoo ko forvardad to all Kacloaa.If yo« kava aay ^aoaelaaa coacoraiag choa* proeaduraa. pleat*caotact Sylvia K. Lovraaca (FTJ 382-4812).

Attackawata

3-10

APPENDIX C

Rtfirttt /" Vol. M. No. 29 / Tuesday. February 12. 1965 / Propa»«d Rules

N*tb— This if u Appendix to thesad will M< appnr is the Cad* of

Sabfect CERCLA Compliance WithOther Environmental SutulM

Prom: LM M. Thorn**. AssistantAdmutomtor

To: Regional Administrator Regions WCTV* memorandum set* forth the

Environmental Protection Agency (EPA]peUey an the applicability of theitandarda. criteria. advisories. andguidance of othtr SUM tad Federalenvironmental tad pubUe healthfUtutM to Ktionf tikn puntunt to•action* 104 and 10» of th*Comprehensive EnvironmentalRespaase, Compensation. out LiabilityAct of MM (CZRCLA). This policyaddressee cansidcratioas for on-elio todoff-tifa actions taken tmdtr CERCLA.

The National Contingency Ptw (NCP)eMblishe* the procees for determiningappropriate removal tod/or remedialaction* tt SuporroBd site*, la tht court*of ihit proeeee, EPA will give primaryconsideftOon to UM leiection of OMMresponse) action* that «r* effective inprtvcattiig or. wh«r* pramtlon i* notpnctfcablo. minimirni too rtltM* ofouardoo* nibtuncn «o that th«y donot Di«rmt* to caut* lubtUntiti dinftrto pr»MHt or fatur* public health,wtiftrt. or tb* twnronnwnt. At aItnaral rota, this can b* accomplUlwdby pnnaiaf muditi that mitt toti taudarda of applieabl* or raiavantFtdaral public health or nvironmntallaw*. How«»ar. bacau** of tha nnlqaadrcunataacaa at particular «it*a. thanmay ba tltamattvn that do not maat thaitaadarda of other law*, but which tttllprovide protection of public health,weUara. and the envinaoMBL

Although r**ponM ictioai whichprevent hazardous «ubitancat frommifretin*; into tha environment are seenas the most effective under CERCLA.actions which nunifliize migration nustalso be considered since CERCLAprimarily addresses inadequate pastdisposal practices and resulline; uniquesite conditions. At certain sites, it maybe technically impracticable,enviraamemaily unacceptable orexcessively costly to implement aresponse action that prevents migrationor restores the lite to its original,uncontamioatsd condition.

(LPottcy

Section 104 of CERCLA requires thatfor off-site remedial actions, storaae.destruction, treatment or securedisposition be in compUanc* withsubtitle C of Resource Conservation andRecovery Act (RCRA). CERCLA issilent however, concerning therequirements of other Uwa with regardto ill other response tenon* tokenpursuant to sections 10* and 108. A* ageneral role, the Agency's policy is toattain or exceed applicable or relevantenvironmental and public healthstandards in CERCLA reaoaunless on* of the specificallyenumerated situations is present Wheresuch a situation is present and astandard i* not used, the Agency mustdocument and explain the reason* in thedecision documents. Federal criteria andadvisories, and State standards tlso willbe cofin'dered in fashioning CERCLAremedies and. if appropriate, relevantportions will be used. If EPA does notuse a relevant part of these standards,criteria or advisories in the remedialaction, the decision documents will Matethe reasons.

A. On-titt Xespans* Action*

(1) For removal actions. EPA's policyla to pursue action* that will meetapplicable or relevant standards, tndcriteria of other Federal f nviranmentaland public health law* to the maximumextent practicable, eonsidsring theexigencies of the situation.

(2) For remedial actions. EPA'i policyis to pursue remedies that attain orexceed applicable and relevantstandards of other Federal public healthand environmental laws, unless specificcircumstances, identified below, exist.

CERCLA procedural andadministrative requinraents w;ll bemodified to provide safeguards similarto those provided under other laws.Application for and receipt of permits isnot required for on-site response tc'Jonstaken under the Fund-financed orenforcement authorities of CERCLA.

A Off-Sitt RttpooM Action*

CERCLA removal and remedialactivities that involve the removal ofhazardous substance* from a CERCLAsite to off-site faculties for properstorage, treatment or disposal must be ineomollattce with all applicable orrelevant standards of Federalitrriraamental end public healthstatute*.

Off-site facilities that are used forstorage, treatment or disposal ofSuperfuad waste* must have tilappropriate permits or authorizations.

U the facility or process that is beingconsidered far receipt of die Superrandwaste* ha* not been permitted orauthorized, the Stele or responsibleparty will be required to obtain attappropriate permit*. A State'snsponaibiUty for obtaining anyappropriate Federal State or localpermits (e.g. RCRA. TSCA. NTOES.Qeen Air. etc.) will be specified in acontract or cooperative agreement withthe State aa part of its assurancesrequired under section 104(c| ofCERCLA.

in. Federal tad SUVUy B* Retoveol or AppiieaWe to

Federal and State environmentalstandards, guidance and advisories fallinto two categories:

• Federal standarda that are relevantor applicable.

• Other standard*, criteria, advisorivsor guidance to be considered.

01

/ Vol SOL No. a / ToMday. F*nvj 12. IMS / Prapowd Rait*

ihowd to wtuch dn Haodard «*•»•poiy to ibv sptdfic

M proooBf M too •«.'a. Tbt toiocad •tarmoovt u not tte

Raal iMMdy «ad wul bocoBM port

1. AVMOHDOM gmtAuatr*** ofA* poit of tbo (Matabty

iFSl. M WMI ox «toM«ii»« farOf tto W»MO> MOL M •

b*ofte

M 004M ttoilCr. M

(c» Wkm *t iMHdr a to bt

mm ifloaad prandM by ite

C-2

/ VoL 50. No. a / TSmday. Fafcnury tz 1985 / Prepqaad

JlBHllarqiL UllBCla* adVtaortaaj Ofgodaanea «i raiavwi. b«t an not otadin tha saiactad tMMdtai aitaraattva. thadacwondoaunaata w«U indxata thabaata for apt using d>am

Stata standards an part of tha coat-•ffactrtoraeMdy.iha Fund will pay toattain tfcssasiaikdaraa. Whan oa cost-tffacttwe raaMdy do* aol iadada taoaaState standards, tha SUM may pay toodiffannca 10 attain i

mllb«foiloto A* Supvten*

that it pravtdaa • tfcsolar lavai of publicthai provtdad by tha

iaf< '

• A Ad aaaat ahoaid ba rschi didwith aa pnoUa aottaa mi haalhilHy•tudy which w prmrtdad M the pabita 2waatobafanuwawawkpaoaVscoaaaattt parted. Tha fact saaet winrlaartr lamaiarlia tin faaaiNIIH itaifr

t and othar i

axeaadpsttkbaallhstandards Md ottarla, * er ttltHiMitvw that d» MtippUabto tad ral*ra*t atudwdi ofodMr p^Hc hMith Md MviraoMttlU«n. tte fact shMt tUl ld«uif!r how(hty tail to «tUia th« iludud* udtxpkte hew ttey aoMttMUM OMM tteVMi« of CDtOA. tta pubUe ootle*tfaould lacfod* • tfmMbte in which •dicMo* will ba rMctad. lay tnufrr*dMwniaattaM whtek tte A|ncy humad*, tte locattoa wlwn nl«v«u

idntifleattea of ceoBnity ta*otv*antappocnmiHM, th« namt of in Actnqrcontact ud oth«r tporoprUtt •

• A public notica tad apdaud (actffcMt ihmld b* prtp«rtd upoa (1)AfVBCy MlCCtlUU Oi tlM aBW fMpOQMaction aed (2) upoa completion of dMfinal •ngnawmi dtafa. Prtoe toMlcctinf th» final tn^n itf<th« Agtney nay hold a pubUe auoODf toinform UM public of to* daiipialtatnattvM and toUdt commaata.

• If a ranady ia idanttflad that iaditfamu bom thota prapoa*d dnriaf thaftanbJUtjr study public commant pariod.a oaw 3 w«ak public coramant pariodmay ba raquirad prior to amandins '"•racord of daciaion. takirtf intoconndaration tha hacurm of thaalttrniUvw addraaaad in tha public

In addition, cartara aapacta of thtCERCLA adminutrattva pracata atay bamodifiad to asaura comparability withtha admiaiatratrvo Faquinrnanta (La.

racofdkaalpni%\ nmutortnaj 01 tha onartnvtronniannu profrwna^

Tha CERCLA anforcamont communityraktfam proawm will aiao ba aodifiadto p*o*ida for a* anhaacad pvbtieparticn^autiB pvo%TVD raf uuth conaantdatfaaa aod adBunlatfattva ordapa. Traaprocram will ba tubauuiaUy aquivaiattto tha raviaad pntram for Fund-flnancad actions* Funhanmn* conaantJauna and admmiatrattva ordan wtUlocorporati admmiatraa>a raqwananta(La. racordlMapna^ mooitortnaj dmiUrto ttmamandatad by othar

V.AppOeaallltyorMkyThla pottey appllaa to tfarao dUhratt

tttuattooa:• AtttoapadflcFShMMtyatbaaB

iaitlatad.• TbaFSh«abawtaMiatad.b«iBo

rvfaWoy DM ort yvt DMB MwctaMt• Tha FS ta co«okt«d and tha unady

Att allaa whan tho « haa not yatbaaa WtfMad not maot att of tha

of tftfa pottey.tho n boa baaa iaittattd and

tha nina il| haa am yat ba«« itha finaliaaami of Htfa poUey do notapply to Raaart of OocMona (KOOa)»i|Bad bafara MMh L tflH. ROOi•tanad bafora March j. 19H. *ao«UptaaaM to tho daeiatoMakar at laaatona aUamattv* that attatea or axcaooaappUeaWo or ntovaat Mmndarda and. ifit ia not talactad tbould Indlcata thoFV*UOBC Wfty It WaH DO* MWCtCQ*

Wham (ha PS la conpim and tharanady haa baan caiactad. tha daeuioa-nakar may on a etaa by<aaa baaiaraviao tho aaiactad ranady.

If yon hava any qaaittona orcomnanu. plaaaa contact William N.HauaoiaB. Dtractor. Offlca of Emarajancyand Ranadlal Raaponaa (FTS 382-2180)or OoufUa Cohan of hia Policy AnalystsStaff (TO 3*tOOM|.

AttadmantAaajttcabla or Halavmt

• Opan Dump Critaria (RCRA Subtitlaa 40 CFR Part 237)

wtttn. Ia SMM iitutaaM Siiatrfuadmil bt haadM in aceardaaca «ntaftOlASubmit C rtqunaunia.

• Hasardoua Waata fligulaaons(RCRA Subtitlt C 40 CFR Part 294)including linar. cap. groundwatar. andelosun raquinmanta undar thafollowing rabpanrf. Ground-Watsr ProtectionC. Cloture and Pott CloauraH. CoataioanLTanks

J. Suriaca bopouadmantaK. Waata PllaaU Land TraaonantViUndfinaN. uicsiicrQtors

• Maximum Contaminant Lavala (forall tourcaa of drtnkin» walar axpoaura).

• Undatfround lafactton ControlRtfulationa.

• Stata Watar Quality Standards(apply for surfaoa watar dtacaarfB).

• Raquiramaat* tatabliaaad pursuantto sactton 301 and sactton 41B(c| of thaOaan Watar Act

• Ocaan DumpJrojRti|y|iaiBaanincludmi indaaratton at aaa.

• Pimaaunaut ttaadarda fardischarfs into a pubUdy ownadtraai

ooafTonc

• -TCBRaoaranamaiacludinfDisposal aad Martina Rate (« FR n»

S Baa Rota (44 FK 31 J14. 1-

(47 r» ma. Auauat 29. ueitUnconaoOad «3a Rula (49 P» atTZ.July Ittlflotl and othar rtlatad -

• 40 CFR 7T5 SutaWaata Malarial Caataining TONX

liof

• CuidaoMamrSpadneatloaofDlapoaal Silas for Oradasd or FfflMatartal (aacmm 404(bMll Cuidaunaa.

DamalorRaaMctionofOlapoaalSit* for Dradftd Mattnak Final rola(laction 404(c|).5. Officu of Air aad Radiation

• Uraniuni mill tailing rulaa.• National Ambiant Air Quality

Standards.• High and tow laval radloactiva

wnsta rula.• Aabaatoa disposal rulaa.

i. Ortttr FtderaJ Rfqujrtmtnti

• OSHA raouiramanta.• Pmanranoa of Kiannflfc historical

or archaaoloqical data.• O.O.T. Hasardous Matarials

Transport Rula*.• Raguiarion of icnvirttt in or

affecting watarsof tha Unitad Slataspursuant to 33 CFR 320-329.

• Tha following raquiramants antnggartd by fund-ftnancad actions:— PrutrvaSon of nvtn on tha national

inventory. Wild and Scamc RirtrsAct itction 40 CFR 9J02(t).

— Protection of thraataned orendangered ipacias and thair habitan-

C-3

/ VoL JO. No. » / Trimuj U UM /

Act.

C-4

Federal Refieeer / Vol. 30. No. 29 / Tmtday. Febnury U. 1985 / PrapOMd Rdt>

(3| IniMn guidance /or pubttcparticipaaoa.

(4» Oefinitioa of OMfar f«aUtie&|I) Canecttve acttan rtquiremeata.[8J Requimneatt applkehle to well*

injecting, into, tbroufh or above anaquifer which ha* bea exeBptedpunuant to i 14a.lOt(b|(4).

(7) Guidance for UIC implemmudan

1 UStPA .Waanob Awn Ot» OfflctofAutarch and DfruJopnwit

(1) EW S46 method* Ubontoryanalytic authodi.

(2| Ub ptotocolt dcviloptd pumuot10 QMO Water Act secnon 304(h).(TK Ooo. M-aot nM a-u-afc k« toil

C-5 . !•• - »*-m/io*37