remedy selection

8/2/2019 Remedy Selection

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February 2012 ASCI Training 1

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Remedy Selection


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2 ASCI Training February 2012

Definition and goal of the FS: The NCP ( 300.5) defines an FS as a studyundertaken by a lead agency to develop and evaluate options for remedialaction. The FS emphasizes data analysis and is generally performedconcurrently and in an integrated fashion with the RI. Section 300.430(e)(1)states that, Development of alternatives shall be fully integrated with the sitecharacterization activities of the remedial investigation described in paragraph (d)

of this section.

The goal of the FS is to develop and evaluate an appropriate range of remedialaction options that ensure protectiveness of human health and the environment,that maintain protection over time, and that minimize the amount of untreatedwaste that remains at the site. The range of alternatives then will be evaluatedagainst nine selection criteria described in the NCP to identify a preferredremedy. The preferred remedy then will be set forth in a proposed plan.

The FS process: The FS process consists of five general steps:

Establish or revise the RAO Develop general response actions Identify and screen potential technology types and process options Develop and screen the remedial alternatives Conduct detailed analysis of the alternatives Prepare FS report

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Fundamentals of the FeasibilityStudy

Definition and goal of the FS

FSProcess

Analyze RI Results

Establish or Revise RAOs

Develop General Response Actions

Identify and Screen Technologies and Process Options

Develop and Screen Alternatives

Detailed Analysis of Alternatives

FS Report


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Mandates under CERCLA 121(b) influenced the evaluation criteria for remedyselection that are set forth in the NCP. Section 400.430(e) of the NCP specifies thegoals, expectations, and principles that ensure that appropriate remedial responsealternatives are evaluated and implemented. Consequently, the FS and thesubsequent remedy selection process are based on and mandated by law. Forexample:

Protect human health and the environment: The statutory mandate to protecthuman health and the environment is related to the selection criterion of thesame name, in addition to the criterion related to short-term effectiveness.

Comply with ARARs: The mandate to comply with ARARs is related to thecriterion of the same name.

Be cost effective: The mandate for cost-effectiveness is related to the costcriterion, as balanced by long-term effectiveness and permanence; short-termeffectiveness; and reduction of toxicity, mobility, and volume of contaminants.

Provide permanent solutions to the maximum extent practicable: Themandate for using permanent solutions and alternative treatment technologies to

the maximum extent practicable (MEP) is related to the criteria for long-termeffectiveness and permanence.

Meet preference for treatment: The preference for remedial actions in whichtreatment permanently and significantly reduces the volume, toxicity, or mobilityof hazardous substances shares the goal of the criterion related to reduction oftoxicity, mobility, and volume through treatment. Although this is not a statutorymandate, EPA, by policy, has given serious consideration to treatment overcontainment options due to this preference stated in CERCLA.

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Statutory Mandates

Protect human health and the environmentComply with ARARs

Be cost effective

Provide permanent solutions to the maximumextent practicable

Meet preference for treatment


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Remedial Action Objectives

Analyze Site Characterization Results






FS Report


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RAO statements specify contaminants and media of concern, potential exposurepathways, and remediation goals.

RAOs usually use verbs like prevent and/or limit when describing how tocontrol exposure to contaminants. For example, prevent human exposure toTCE in excess of 5 ppb through ingestion of drinking water.

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RAOs

RAO statements specifycontaminant type and media

of concern, potentialexposure pathways,

and remediation goal.


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RAOs usually use verbs like prevent and/or limit when describing how tocontrol exposure to contaminants. For example, prevent human exposure to TCEin excess of 5 ppb through ingestion of drinking water.

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Example RAO

Prevent human exposure byingestion of

groundwater with TCEconcentrations that

exceed 5 micrograms/Liter.


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General Response Actions

Analyze RI Results






FS Report


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General response actions are broad activities that satisfy RAOs: Generalresponse actions are those actions that will satisfy the RAOs. Like RAOs,general response actions are specific to the medium of concern.

Examples of general response actions include:

Treatment Excavation Containment Engineering controls Institutional controls

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General Response Actions

General response actions are broad activities thatsatisfy RAOs

Examples of general response actions include:

Treatment

Excavation

Containment

Engineering controls

Institutional controls


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Identification of PotentiallyApplicable Technology Types andProcess Options

Analyze RI Results






FS Report


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Technology type and process options: The term technology type refers togeneral categories of technologies, such as chemical treatment, thermaldestruction, immobilization, capping, or dewatering. Technology process optionsare specific processes within each technology type. For example, the chemicaltreatment technology type for an aqueous-phase waste would include suchprocess options as precipitation, ion exchange, and oxidation and reduction.

Screening technology types reduces number of process options toconsider: Identifying and screening general categories of technologies(technology types) saves time. There are many options within eachtechnology type. If an individual technology type can be screened out, it is notnecessary to identify and screen the process options within that particulartechnology type. For example, incineration will not be effective when appliedto soils that contain high levels of mercury; therefore, incineration would notbe considered as a technology type at a site at which high levels of mercuryare present in the soil.

Innovative technologies warrant special consideration: An innovative

technology is a treatment technology for which cost or performanceinformation is incomplete. To support the selection of an innovative treatmenttechnology, more information, such as that generated by treatability studies,is required. Because of potential cost or performance benefits, a promisinginnovative technology may be carried through to the detailed analysis even ifsufficient information is not available about its effectiveness, implementability,and cost.

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Technology Types and ProcessScreening Options

Technology type and process optionsScreening technology types reduces number of

process options to consider

Innovative technologies warrant specialconsideration

A variety of technology information resources isavailable


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A variety of technology information resources is available: It is essentialto identify multiple technologies to provide a range of options in cases inwhich residual risks vary and to provide a range of costs with which tocompare the ranges of residual risk.

Technology types (and process options) may be identified by drawing on a

variety of sources, including references developed for application toSuperfund sites and more standard engineering texts. The AdditionalInformation module at the end of this manual provides a list of thesetechnology resources.

EPAs website on the Internet at provides information aboutmany of these resources.


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Screening Process Options

(continued)

Effectiveness

Implementability

Relative Cost


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Identify a single process option per technology type: During screening,process options are evaluated against themselves to further reduce optionswithin each technology type. Generally, one process option for each applicabletechnology type will be retained.

Three criteria are used to screen options: The following screening criteria are

used to screen process options:

Effectiveness: At this stage in the FS, process option screening shouldfocus primarily on this factor. Effectiveness should be evaluated in relation tothe process options ability to:

Meet the RAOs in a reasonable period of time Handle the areas or volume of media Avoid creation of adverse effects on human health and the environment

during implementation Be reliable with respect to contaminants and conditions at the site

Implementability: Implementability includes both technical andadministrative feasibility in implementing the process option.

Relative cost: This factor plays a limited role at this stage. Costs should beevaluated generally as high, medium, or low, relative to the cost of otherprocess options.

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Identify a single process option per technologytype

Three criteria are used to screen options

Effectiveness

Implementability

Relative cost

Retained options are combined and assembledinto remedial alternatives

(continued)


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Retained options are combined and assembled into remedial alternatives:The process options are assembled into remedial alternatives by combininggeneral response actions that use different technology types and differentvolumes of media. RAOs must be reviewed to ensure that each alternative isresponsive to all the RAOs.


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Evaluate innovative technologies: It is important to consider innovativetechnologies seriously when screening process options because:

The Superfund amendments ( 121) require remedial actions that, to themaximum extent practicable, are permanent solutions or alternative treatmenttechnologies.

The NCP ( 300.430(a)(1)(iii)(E)) expects consideration of innovativetechnologies.

EPA policy, such as Furthering theUse of Innovative TreatmentTechnologies in OSWER Programs, June 1991 (OSWER Directive 9380.0-17) seeks to advance the use of innovative treatment technologies in supportof the requirements of the SARA and the expectations of the NCP. Of thethree technologies identified for the Concept Chemical, Inc., site, ex situbiodegradation is considered innovative.

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Evaluate innovative technologies Innovative technologies that offer comparable or

superior performance should be retained

The no action option is retained for baselinecomparison


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Innovative technologies that offer comparable or superior performanceshould be retained: Innovative technologies are usually carried through thescreening phase if there is a reason to believe that the innovative technologyoffers the potential for comparable or superior performance or implementability.The advantages may be in the form of better treatment performance orimplementability, fewer adverse effects, or lower costs for similar levels of

performance than demonstrated technologies offer. A reasonable belief exists ifall indications from other full-scale applications under similar circumstances orfrom bench-scale or pilot-scale treatability testing support the expectedadvantages. It may be necessary to offer PRP extra encouragement to considerand use innovative technologies because of the PRPs perception that suchtechnologies may be more expensive than conventional technologies orunproven.

The no action option is retained for baseline comparison: The no actionoption must be carried through to the detailed analysis of alternatives as abaseline point of comparison with potential response actions. Therefore, eventhough the alternatives have been narrowed, the no action option still should be

considered.


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Analyze RI Results






FS Report


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Retained options are combined and assembled into remedial alternatives:Those process options that are retained are now assembled into remedialalternatives that address the threats posed by the site or OU. If the site or OUinvolves more than one media of concern, a large number of alternatives may bedeveloped. For some sites, it may be more manageable to develop alternativesfor groundwater and other media, such as contaminated soil and sediment,

separately and then combine them into site-wide or OU-wide alternatives later.

Remedial alternatives may be screened to reduce the number ofalternatives for detailed analysis to a manageable number: As a generalrule-of-thumb, no more than four to seven alternatives should be retained for thedetailed analysis. If many more alternatives are developed during this phase,then those alternatives can be screened using the criteria of effectiveness,implementability, and cost, to reduce the number of alternatives to a manageablenumber.

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Development and Screening ofAlternatives

Retained options are combined and assembledinto remedial alternatives

Remedial alternatives may be screened to reducethe number of alternatives for detailed analysis toa manageable number


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Analyze RI Results






FS Report


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This slide presents the degree of detail needed to evaluate remedial alternativesduring the RI/FS. Alternatives are reviewed initially against three screeningcriteria: effectiveness, implementability, and cost. The slide shows therelationship between the screening criteria and the nine evaluation criteria.

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Relationship of Screening Criteria tothe Nine Evaluation Criteria

SCREENING

CRITERIA

NINE EVALUATION

CRITERIA

ROLE OF CRITERIA DURING

REMEDY SELECTION

Overall Protection of HumanHealth and Environment

Compliance with ARARs

Long-Term Effectivenessand Permanence

Reductions in Toxicity, Mobility,and Volume (TMV) Through Treatment

Short-Term Effectiveness

Implementability

Cost

State Acceptance

Community Acceptance

Effectiveness

Implementability

Cost

"Threshold"Factors

"Primary Balancing"Factors

"Modifying"Considerations


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SCREENING

CRITERIA

NINE EVALUATION

CRITERIA


REMEDY SELECTION






Implementability

Cost

State Acceptance


Effectiveness

Implementability

Cost

"Threshold"

Factors



SCREENING

CRITERIA

NINE EVALUATION

CRITERIA


REMEDY SELECTION






Implementability

Cost

State Acceptance


Effectiveness

Implementability

Cost

"Threshold"

Factors




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Section 300.430(e)(a) of the NCP requires remedial alternatives to be evaluatedagainst nine criteria. The nine criteria are divided into three categories:

Threshold criteria: In order for an alternative to be considered as a potentialremedy, it must meet the threshold criteria. With the exclusion of a no actionalternative, an alternative that does not meet the threshold criteria should not be

considered past this phase of the FS. The two threshold criteria are:

Overall protection of human health and environment Compliance with ARARs

Balancing criteria: The five balancing criteria are:

Long-term effectiveness and permanence Reduction of toxicity, mobility, and volume (TMV) through treatment Short-term effectiveness Implementability Cost

Modifying criteria: Modifying criteria are generally not evaluated during the FS.The modifying criteria should be considered during remedy selection. The twomodifying criteria are:

State acceptance Community acceptance

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Three Categories of Criteria

Threshold

Balancing

Modifying


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Evaluation of Alternatives


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Focuses on risks remaining at site: This criterion addresses the risk remainingat the site after response objectives have been met. The evaluation ofalternatives under this criterion focuses on the extent and effectiveness of thecontrols that may be required to manage the risk.

Magnitude of risk is evaluated on the basis of residues at completion of

response: The residues remaining at the completion of the remedial activity areidentified and the magnitude of risk those residues pose is assessed. Thepotential risk can be measured by numerical standards (for example, levels ofcancer risk) or by amounts of contaminants remaining on site.

Degree to which residues remain hazardous is considered: Thecharacteristic of the residues that should be considered to evaluate themagnitude of the risk is the degree to which the residues remain hazardous,considering their volume, toxicity, mobility, persistence, and propensity tobioaccumulate.

Adequacy and reliability of engineering or institutional controls areassessed: The adequacy and reliability of engineering and institutional controlsused to manage residual or untreated wastes remaining on site also must beassessed. (For example, the potential need to replace technical componentssuch as a cap, slurry wall, or treatment system must be assessed.)

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Balancing Criteria: Long-TermEffectiveness and Permanence

Focuses on risks remaining at siteMagnitude of risk is evaluated on the basis of

residues at completion of response

Degree to which residues remain hazardous isconsidered

Adequacy and reliability of engineering orinstitutional controls are assessed


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Relates to treatment options: This criterion is best satisfied when treatment isused to reduce the principal threats at a site through destruction of toxiccontaminants, reduction of the total mass of toxic contaminants, irreversiblereduction in the mobility of contaminants, or reduction of total volume ofcontaminated media.

Was established to satisfy statutory and regulatory preferences fortreatment: This criterion is based on the statutory preference for treatment as aprincipal element, as well as the expectation under the NCP that principal threatsare to be treated.

Factors in evaluating treatment options include: Factors in evaluating atreatment options ability to satisfy this criterion include:

The amount of hazardous material that will be destroyed or treated

The degree of expected reduction in toxicity, mobility, or volume measured asa percentage of reduction

The degree to which the treatment will be irreversible

The type and quantity of residues of treatment that will remain followingtreatment

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Balancing Criteria: Reduction ofTMV Through Treatment

Relates to treatment options

Established to satisfy statutory preference for treatment

Factors in evaluating treatment options include:

Amount of hazardous material that will be destroyed ortreated

Degree of expected reduction in TMV measured as apercentage of reduction

Degree to which treatment will be irreversible

Type and quantity of residues of treatment that will

remain following treatment


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Involves evaluation of risk during remedy implementation: Evaluation ofshort-term effectiveness addresses the effects of the alternative during theconstruction and implementation phase, until the response objectives have beenmet.

Objective is to protect workers, community, and environment: When

evaluating alternatives for short-term effectiveness, the key components areprotection of the community and workers during the remedial action and controlof environmental effects.

To evaluate whether the alternatives are protective of the community, workers,and the environment during the construction and implementation of the remedialaction, the risks posed by the remedy are assessed and a determination is madeof how they might be addressed and mitigated. In addition, risks that cannot becontrolled readily are identified.

Should also consider time necessary to achieve response objectives: Timeconsiderations to be addressed when evaluating short-term effectiveness are:

How long will it be until protection against the threats being addressed by theremedial action is achieved?

How long will it be until any remaining threats at the site are addressed?

How long will it be until RAOs are achieved?

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Balancing Criteria: Short-TermEffectiveness

Involves evaluation of risk during remedyimplementation

Objective is to protect workers, community, andenvironment

Should also consider time necessary to achieveresponse objectives


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Implementability refers to technical and administrative feasibility: Theimplementability criterion addresses the technical and administrative feasibility ofimplementing an alternative and the availability of various services and materialsrequired during its implementation.

Technical implementability includes ability to construct and operate,

reliability, and spatial requirements: Some technical issues related toimplementability to be addressed are:

Ability to construct and operate the technology Reliability of the technology Ease of undertaking additional remedial actions Monitoring considerations Spatial requirements for the technology (such as staging areas and heavy

equipment areas)

Administrative issues include permitting, procurement, and technologyavailability: Issues of administrative feasibility to be considered are activitiesthat require coordination of efforts with other offices and agencies (forexample, obtaining permits for off-site activities or rights of way forconstruction; availability of special equipment or specialists; and availability oftreatment, storage, and disposal capacity and disposal services).

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Balancing Criteria: Implementability

Implementability refers to technical andadministrative feasibility

Technical implementability includes ability toconstruct and operate, reliability, and spatialrequirements

Administrative issues include permitting,procurement, and technology availability


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Cost analysis reveals least expensive alternative: The cost analysis revealsthe least expensive alternative among the cost-effective technology alternatives.

Various sources of cost data are available: Cost data come from sitecharacterization and treatability investigation information, the Cost of RemedialAction (CORA) model, and independent government estimation staff of the

USACE.

Components of cost data include capital and O&M costs: The components ofcost data that should be analyzed and compared are capital costs and annualO&M costs. The methods of calculating those costs are included in theevaluation, as well.

Costs are presented as a present-worth analysis: Costs are presented forcomparison as a present-worth analysis. The analysis is used to evaluate allexpenditures that occur over different time periods by discounting all future costto a common base year, usually the current year. Using this approach to analysisallows comparisons of the costs of remedial action alternatives on the basis of asingle figure that represents the amount of money that, if invested in the baseyear and disbursed as needed, would be sufficient to cover all costs associatedwith the remedial action over its planned life.

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Balancing Criteria: Cost

Cost analysis reveals least expensive alternativeVarious sources of cost data are available

Components of cost data include capital andO&M costs

Costs are presented as a present-worth analysis

Sensitivity analysis can be performed ifuncertainty exists


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Sensitivity analysis can be performed if uncertainty exists: If there isuncertainty concerning specific assumptions, such as the effective life of theremedial action, the O&M costs, the duration of cleanup, or the volume ofcontaminated material, a sensitivity analysis can be conducted. During thatanalysis, the cost of specific assumptions can be determined by varying theassumptions and noting the effects of the variations on estimated costs. A

sensitivity analysis identifies the variables in the cost estimate that are most likelyto change over time.


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Consider: Modifying criteria consider:

State acceptance Community acceptance

Evaluated following comment on the RI/FS and proposed plan: EPA obtains

information about the states acceptance and community acceptance throughcomments from state authorities and the public on the proposed plan, as well asthrough effective community involvement activities. The usual effect of themodifying criteria is that, once all comments have been evaluated, acceptanceon the part of the state and the community may influence modifications of theproposed remedy. Rarely do such considerations fundamentally alter theproposed remedy, and in no case will EPA sacrifice protection to gain theacceptance of the state or the community.

Modifying criteria are applied after completion of the plan and included inthe ROD: The modifying criteria are applied after the proposed plan has beencompleted and made public; they are addressed in the ROD when the leadagency makes its final decision on a remedy.

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Modifying Criteria

ConsiderState acceptance

Community acceptance

Evaluated following comment on the RI/FS andproposed plan

Modifying criteria are applied after completion ofthe plan and included in the ROD


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Feasibility Study Report

Analyze RI Results






FS Report


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Documents FS process: The FS report documents the complete FS process,from beginning to end. It does not however, indicated the EPAs preferredalternative.

Provides basis for proposing preferred alternative: The FS report providesthe basis the RPM to recommend a preferred alternative and to prepare the

proposed plan for the remedy.

Made available with the proposed plan: The FS report is made available forpublic review at the same time that the proposed plan is issued. The FS report isan important part of the administrative record and copies are available at the siteinformation repository and in the Regional office.

FS report outline: The RI/FS guidance provides a suggested FS report format,which is included below:

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FS Report

Documents FS processProvides basis for proposing preferred alternative

Made available with the proposed plan

FS report outline


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Executive Summary1. Introduction

1.1. Purpose and Organization of Report1.2. Background Information (Summarized from RI Report)

1.2.1. Site Description1.2.2. Site History

1.2.3. Nature and Extent of Contamination1.2.4. Contaminant Fate and Transport1.2.5. Baseline Risk Assessment

2. Identification and Screening of Technologies2.1. Introduction2.2. Remedial Action Objectives Presents the development of remedial

action objectives for each medium of interest (i.e., groundwater, soil,surface water, air, etc.). For each medium, the following should bediscussed: a) contaminants of interest, b) allowable exposure based onrisk assessment (including ARARs), and c) development of remediationgoals.

2.3. General Response Actions For each medium of interest, describes

the estimation of areas or volumes to which treatment, containment, orother technologies may be applied.

2.4. Identification and Screening of Technology Types and Process Options For each medium of interest, describes:2.4.1. Identification and Screening of Technologies2.4.2. Evaluation of Technologies and Selection of Representative

Technologies3. Development and Screening of Alternatives

3.1. Development of Alternatives Describes rationale for combination oftechnologies/media into alternatives. Note: This discussion may be bymedium or for the site as a whole.

3.2. Screening of Alternatives (if included)

3.2.1. Introduction3.2.2. Alternative 1

3.2.2.1. Description3.2.2.2. Evaluation

3.2.3. Alternative 23.2.3.1. Description3.2.3.2. Evaluation

3.2.4. Alternative 34. Detailed Analysis of Alternative

4.1. Introduction4.2. Individual Analysis of Alternatives

4.2.1. Alternative 1

4.2.1.1. Description4.2.1.2. Assessment

4.2.2. Alternative 24.2.2.1. Description4.2.2.2. Assessment

4.2.3. Alternative 34.3. Comparative Analysis

BibliographyAppendices


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Remedy Selection Process forSuperfund

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Process for Issuing a ROD

Develop Proposed Plan

Issue Proposed Plan

Develop ROD

Issue ROD


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Be as specific as possible: The more specific the ROD or Action Memo isabout what is required, the easier the response action will be to design, and laterto review. It is especially important to be specific about the following items:

Cleanup levels: Describe the exact level to be achieved for each chemical ofconcern and how, where, and when compliance will be measured.

Technical requirements and performance standards: Specify thetechnical requirements of the remedy, such as the specific layers of a capand the spatial area to be covered by the cap, and the performancestandards of the remedy, such as 90% reduction in the level of a specificcontaminant through a treatment process.

ARARs: Describe exactly what ARARs are to be complied with rather thanincluding a general citation to a lengthy regulation.

Institutional controls: Describe what the controls is designed to do, how thecontrol is to be accomplished, and who is responsible to achieving andenforcing the control.

Deferred decisions/contingencies: Specify how and when EPA will decideon issues that are deferred or on the triggers for any contingencies.

O&M/PRSC: Specify the O&M/Post-removal site control (PRSC) activitiesthat must be performed and for how long they must continue.

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Advice for Preparing DecisionDocuments

Be as specific as possibleCleanup levels

Technical requirements and performancestandards

ARARs

Institutional controls

Deferred decisions/contingencies

O&M/PRSC


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Identify preferred alternative and draft proposed plan: Using the informationfrom the RI/FS and in consultation with the support agency, the RPM shouldidentify the preferred alternative from among the alternatives analyzed in the FS.The preferred alternative will then be presented to the public in the proposedplan. The RPM is responsible for drafting the proposed plan.

Proposed plan format: EPAs ROD guidance recommends a format for andcontent of the proposed plan for most sites. The guidance states that the level ofdetail and content of the Proposed Plan be tailored to the needs and concerns ofthe individual community that lives around the Superfund site and stakeholdersinvolved in the Superfund remedy selection process. The suggested format andcontent affords the public and involved stakeholders the most complete andexplicit rationale for the Preferred Alternative. A shorter summary of the remedyselection process, with less technical information, may help to ensure that thewidest possible audience is reached. Therefore, EPA recommends thedevelopment of a Proposed Plan fact sheet whenever a more detailed ProposedPlan is prepared.

Major sections of proposed plan: The proposed plan has ten major sections.The RI and FS should be used to provide most of the text for the proposed plan.

The general content of the ten sections is described below.

A. Introduction - This section identifies the site and describes the publicparticipation process.

B. Site Background - This section provides facts about the site which providethe context for the subsequent sections of the Proposed Plan.

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Identify preferred alternative and draft proposed plan

Proposed plan format

Major sections of proposed plan

A. Introduction

B. Site Background

C. Site Characteristics

D. Scope and Role

E. Summary of Site Risks

F. Remedial Action Objectives

G. Summary of Alternatives

H. Evaluation of Alternatives

I. Preferred Alternative

J. Community Participation

(continued)


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C. Site Characteristics - This section describes nature and extent of sitecontamination.

D. Scope and Role - This section describes how the operable unit or responseaction fits into the overall site strategy.

E. Summary of Site Risks - This section briefly summarizes the results of thebaseline risk assessment, and the land use and groundwater use assumptionsused in the analysis.

F. Remedial Action Objectives - This section describes what the proposed sitecleanup is expected to accomplish. The remedial action objectives can be takendirectly from those developed in the RI/FS.

G. Summary of Alternatives - This section describes the options for attainingthe identified remedial action objectives and includes the alternatives analyzed indetail in the FS.

H. Evaluation of Alternatives - This section explains the rationale for selectingthe Preferred Alternative in terms of its ability to appropriately balance the trade-offs with respect to the nine criteria. This section may include summary tables butmust also include a supporting narrative. This section is not intended to be acomprehensive analysis of each alternative in relation to each of the nine criteria.

I. Preferred Alternative - This section describes the Preferred Alternative,

summarizes support agency comments, and affirms that it is expected to fulfillstatutory and regulatory requirements.

Tips for Drafting Summary of Site Risks Section

Tip 1: Discuss in two subsections (1) human health risks, and (2) ecological risk.

Tip 2: Use a narrative rather than detailed risk summary tables (required in ROD) and only discuss the majorcontaminants that are driving risk.

Tip 3: Explain all numeric risk representations in plain English.Tip 4: This section should only be 2 to 3 paragraphs long unless site complexities require a more lengthy explanation.

Tip 5: Link site risks to the basis for action and end the section with standard statement (see Highlight 3-2 in RODguidance).

Tips for Drafting Summary of Alternatives Section

Tip 1: Identify the Preferred Alternative at the beginning of its description.

Tip 2: Include enough information in the description of alternatives about remedy components and distinguishing featuresof each alterative so that the public will understand the comparative analysis.

Tip 3: Describe components common to a number of alternatives only once.Tip 4: Include all three components of estimated cleanup cost - capital, annual O&M, and total present worth.


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J. Community Participation - This section provides information on how thepublic can provide input to the remedy selection process. It identifies the startand end dates of the comment period, location of the information repositories, thedate and time of the public meeting, and the names, phone numbers, andaddresses of the RPM, support agency contact, and Community InvolvementCoordinator.

Tips for Drafting Preferred Alternative Section

Tip 1: Clearly describe the decisive factors that form the basis of why the Preferred Alternative is recommended over theother alternatives.

Tip 2: Mention any uncertainties or contingencies related to the Preferred Alternative.Tip 3: Emphasize that the Preferred Alternative is based on current information and that it could change in response to

public comment or new information.


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Seek appropriate internal review: Review of the proposed plan by the Regionalprogram offices is optional. Review of the ROD is required. However, if thepreferred alternative has any significant issues that affect other program offices,such as water, RCRA, or air, then the RPM should consult with these officeswhen drafting the proposed plan and may seek review and comment. ORCshould usually review the draft proposed plan.

Provide support agency opportunity to comment: The support agency will beclosely involved in site decisions. The support agency should review andcomment on the draft proposed plan in order to ensure a smoother remedyselection process.

Provide draft to HQ contact: All draft proposed plans should be sent to theappropriate EPA HQ contact for review pursuant to EPAs guidance document,Focus Areas for Headquarters OERR Support for Regional Decision Making,May 1996, OSWER No. 9200.1-17. Some remedy decisions will also be eligiblefor consultation with the National Remedy Review Board (NRRB) or anothercross-regional review group.

Brief decision maker: The RPM should brief the Regional decision maker andensure the support agency contact briefs their management also.

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Seek appropriate internal reviewProvide support agency opportunity to comment

Provide draft to HQ contact

Brief decision maker


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Publish notice in newspaper: When the proposed plan is issued, a notice mustbe published in the newspaper to inform the public that the proposed plan, RI/FS,and administrative record is available for review and comment by the public. Thenotice should be published two weeks to ten days before the beginning of thecomment period.

Make proposed plan and RI/FS available: The proposed plan, RI/FS, andadministrative record file must be made available at the start of the publiccomment period. The location of the administrative record file and the hourswhen it can be accessed should be included in the published notification.

Initiate public comment period: The public comment period must be aminimum of 30 days. Upon timely request, the public comment period may beextended a minimum of 30 additional days. However, some sites may warrantlonger public comment periods.

Hold public meeting: The lead agency must provide an opportunity for a publicmeeting to be held at or near the site during the comment period. A transcript ofthe meeting conducted during the public comment period must be madeavailable to the public and should be included as part of the AdministrativeRecord. The lead agency is legally obligated to respond to written or oralcomments received during the public comment period and should advise thosethat submitted comments during the RI/FS process but before the commentperiod to resubmit them to ensure they are addressed.

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Issue Proposed Plan

Publish notice in newspaperMake proposed plan and RI/FS available

Initiate public comment period

Hold public meeting


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Remedy Selection


Develop ROD: The lead agency is responsible for drafting the ROD. Mostportions of the ROD can be drafted early in the remedy selection process andthen revised after public comments, program office comments, and supportagency comments are received. Management should be briefed on the RODafter comments have been received from the public and before the draft ROD issubmitted to the program offices and support agency. The ROD should be

finalized based on comments from the program offices and support agency.Finally, decision makers at both the lead and support agencies should be briefedonce more in preparation for issuance of the ROD.

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Develop and Issue ROD

Develop RODDraft ROD

Review and address public comments andrevise ROD accordingly

Brief management

Submit draft ROD to program offices andsupport agency for review

(continued)


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Remedy Selection


Issue ROD: The ROD will be signed by the lead agency decision maker. It mayalso be signed by the support agency manager, depending on the provisions ofthe agreement between the lead and support agency (that is, cooperativeagreement or Superfund memorandum of agreement). In some Regions, a letterof concurrence from the support agency is used instead of a signature on theROD. At Federal Facilities, the federal agency will issue the proposed plan and

draft the ROD, but EPA must approve and sign the ROD. As required by theNCP, the lead agency must publish a notice in the newspaper that the ROD isavailable and the ROD must be placed in the administrative record file.

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Develop and Issue ROD

Issue RODObtain appropriate signatures (lead and

support agencies)

Publish notice of availability of ROD and makeit available


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Remedy Selection

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Questions