The Cleanup Process. Operation and Maintenance Construction Completion Post Construction Completion NPL Deletion Reuse

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1 SUPERFUND The Cleanup Process Compiled from Site discovery PA/SI NPL Ranking and Listing RI/FS Scoping Site Characterization Development and Screening of Alternatives Treatability Investigations Detailed Analysis Public Comments ROD RD/RA Operation and Maintenance Construction Completion Post Construction Completion NPL Deletion Reuse Preliminary Assessment/Site Inspection The Preliminary Assessment (PA) and Site Inspection (SI) are used by EPA to evaluate the potential for a release of hazardous substances from a site. Preliminary Assessment: An assessment of information about a site and its surrounding area. A Preliminary Assessment is designed to determine whether a sites poses little or no threat to human health and the environment or if it does pose a threat, whether the threat requires further investigation. PA investigations collect readily available information about a site and its surrounding area. The PA is designed to distinguish,

2 based on limited data, between sites that pose little or no threat to human health and the environment and sites that may pose a threat and require further investigation. The PA also identifies sites requiring assessment for possible actions. If the PA results in a recommendation for further investigation, a Site Inspection is performed. The EPA publication Guidance for Performing Preliminary Assessments Under CERCLA, September 1991, (NTIS PB , EPA A) provides more information on conducting PAs. Site Inspection: identifies sites that enter the NPL Site Listing Process and provides the data needed for Hazard Ranking System (HRS) scoring (Introduction to the HRS) and documentation. SI investigators typically collect environmental and waste samples to determine what hazardous substances are present at a site. They determine if these substances are being released to the environment and assess if they have reached nearby targets. The SI can be conducted in one stage or two. The first stage, or focused SI, tests hypotheses developed during the PA and can yield information sufficient to prepare an HRS scoring package. If further information is necessary to document an HRS score, an expanded SI is conducted. The EPA publication Guidance for Performing Site Inspections Under CERCLA; Interim Final, September 1992, (NTIS PB , EPA ) provides more information on conducting SIs. Information collected during the PA and SI is used to calculate an HRS score. Sites with an HRS score of or greater are eligible for listing on the NPL and require the preparation of an HRS scoring package. Introduction to the Hazard Ranking System (HRS) The Hazard Ranking System (HRS) is the principal mechanism EPA uses to place uncontrolled waste sites on the National Priorities List (NPL). It is a numerically based screening system that uses information from initial, limited investigations - the preliminary assessment and the site inspection - to assess the relative potential of sites to pose a threat to human health or the environment. Any person or organization can petition EPA to conduct a preliminary assessment using the Preliminary Assessment Petition (PDF) (4 pp, 485 K, About PDF). HRS scores do not determine the priority in funding EPA remedial response actions, because the information collected to develop HRS scores is not sufficient to determine either the extent of contamination or the appropriate response for a particular site. The sites with the highest scores do not necessarily come to the EPA's attention first - this would require stopping work at sites where response actions were already underway. EPA relies on more detailed studies in the remedial

3 investigation/feasibility study which typically follows listing. The HRS uses a structured analysis approach to scoring sites. This approach assigns numerical values to factors that relate to risk based on conditions at the site. The factors are grouped into three categories: likelihood that a site has released or has the potential to release hazardous substances into the environment; characteristics of the waste (e.g. toxicity and waste quantity); and people or sensitive environments (targets) affected by the release. Four pathways can be scored under the HRS: ground water migration (drinking water); surface water migration (drinking water, human food chain, sensitive environments); soil exposure (resident population, nearby population, sensitive environments); and air migration (population, sensitive environments). After scores are calculated for one or more pathways, they are combined using a root-mean-square equation to determine the overall site score. The electronic scoring tool Quickscore can be used to do the scoring calculations. If all pathway scores are low, the site score is low. However, the site score can be relatively high even if only one pathway score is high. This is an important requirement for HRS scoring, because some extremely dangerous sites pose threats through only one pathway. The HRS Training Course is available but limited to EPA regional, state, tribal, and contractor personnel who support EPA in the Superfund site assessment/npl Listing process. The training course is intended to enable staff to prepare HRS packages for the NPL and to plan PAs and SIs to address future HRS scoring issues. For more information, please consult the EPA publications, The Hazard Ranking System Guidance Manual; Interim Final, November 1992, (NTIS PB , EPA ) and the December 14, 1990 Federal Register, Hazard Ranking System; Final Rule (55 FR 51532). Remedial Investigation/Feasibility Study After a site is listed on the NPL, a remedial investigation/feasibility study (RI/FS) is performed at the site. The remedial investigation serves as the mechanism for collecting data to:

4 characterize site conditions; determine the nature of the waste; assess risk to human health and the environment; and conduct treatability testing to evaluate the potential performance and cost of the treatment technologies that are being considered. The FS is the mechanism for the development, screening, and detailed evaluation of alternative remedial actions. The RI and FS are conducted concurrently - data collected in the RI influence the development of remedial alternatives in the FS, which in turn affect the data needs and scope of treatability studies and additional field investigations. This phased approach encourages the continual scoping of the site characterization effort, which minimizes the collection of unnecessary data and maximizes data quality. The RI/FS process includes these phases: Scoping; Site Characterization; Development and Screening of Alternatives; Treatability Investigations; and Detailed Analysis. For more information, please consult the RI/FS and Treatability Studies Overview. Scoping Scoping is the initial planning phase of the Remedial Investigation/Feasibility Study (RI/FS) process. Many of the planning steps begun here are continued and refined in later phases of the RI/FS. Scoping activities typically begin with the collection of existing site data, including data from previous investigations such as the preliminary assessment (PA) and site inspection (SI). On the basis of this information, site management planning is undertaken to: preliminarily identify boundaries of the study area; identify likely remedial action objectives and whether interim actions may be necessary or appropriate; and establish whether the site may best be remedied as one or several separate operable units. Once an overall management strategy is agreed upon, the RI/FS for a specific project or the site as a whole is planned. Typical scoping activities include: Initiating the identification and discussion of potential Applicable or Relevant and Appropriate Requirements (ARARs) with the support agency. (see Terms of Environment)

5 Determining the types of decisions to be made and identifying the data and other information needed to support these decisions. Assembling a technical advisory committee to assist in activities, serve as a review board for important deliverables, and monitor progress during the study. Preparing the work plan, sampling and analysis plan, health and safety plan, and community relations plan. Site Characterization Field sampling and laboratory analyses are initiated during the site characterization phase of the Remedial Investigation/Feasibility Study (RI/FS). A preliminary site characterization summary is prepared to provide the lead agency with information on the site early in the process before preparation of the full remedial investigation (RI) report. This summary is useful in determining the feasibility of potential technologies and in assisting both the lead and support agencies with the initial identification of Applicable or Relevant and Appropriate Requirements (ARARs). The summary can also be sent to the Agency for Toxic Substances and Disease Registry (ATSDR) to assist them in performing their health assessments. (see Terms of Environment) A baseline risk assessment is developed to identify the existing or potential risks that may be posed to human health and the environment by the site. Because this assessment identifies the primary health and environmental threats at the site, it also provides valuable input to the development and evaluation of alternatives during the feasibility study (FS). Development and Screening of Alternatives The development of alternatives phase of the Remedial Investigation/Feasibility Study (RI/FS) process usually begins during scoping when likely response scenarios may first be identified. The development of alternatives requires: 1. identifying remedial action objectives; 2. identifying potential treatment, resource recovery, and containment technologies that will satisfy these objectives; 3. screening the technologies based on their effectiveness, implementability, and cost; and 4. assembling technologies and their associated containment or disposal requirements into alternatives for the contaminated media at the site or for the operable unit. Alternatives can be developed to address contaminated medium, a specific area of the site, or the entire site. Once potential alternatives have been developed, it may be necessary to screen out certain options to reduce the number of alternatives that will be analyzed. The screening process involves evaluating alternatives with respect to their effectiveness, implementability, and cost. It is usually done on a

6 general basis and with limited resources, because the information necessary to fully evaluate the alternatives may not be complete at this point in the process. Treatability Investigations Treatability investigations are the next to the last phase of the Remedial Investigation/Feasibility Study (RI/FS) process. Treatability investigations are conducted primarily to: provide sufficient data to allow treatment alternatives to be fully developed and evaluated during the detailed analysis phase and to support the remedial design (remedial design/remedial action) of selected alternatives, and reduce cost and performance uncertainties for treatment alternatives to acceptable levels so that a remedy can be selected. Detailed Analysis Detailed analysis is the last phase of the Remedial Investigation/Feasibility Study (RI/FS) process. Once sufficient data are available, alternatives are evaluated in detail with respect to nine evaluation criteria that the Agency has developed to address the statutory requirements and preferences of CERCLA (CERCLA Overview). The nine criteria include: overall protection of human health and the environment; compliance with ARARs (see Terms of Environment); long-term effectiveness and permanence; reduction of toxicity, mobility, or volume; short-term effectiveness; implementability; cost; State acceptance; and community acceptance. The alternatives are analyzed individually against each criterion and then compared against one another to determine their respective strengths and weaknesses and to identify the key trade-offs that must be balanced for the site. The results of the detailed analysis are summarized so that an appropriate remedy consistent with CERCLA can be selected. Record of Decision The Record of Decision (ROD) is a public document that explains which cleanup alternatives will be used to clean up a Superfund site. The ROD for sites listed on the NPL (NPL Site Listing Process) is created from information generated during the Remedial Investigation/Feasibilty Study (RI/FS).

7 A ROD contains site history, site description, site characteristics, community participation, enforcement activities, past and present activities, contaminated media, the contaminants present, scope and role of response action and the remedy selected for cleanup. You can search for RODs in EPA's Record of Decision System. It contains full-text Records of Decision (RODs), ROD Abstracts, ROD Amendments (AMDs) and Explanations of Significant Differences (ESDs). Examples of well written RODs are available on the ROD of the Year Contest Web page. The purpose of the ROD-of-the-Year Contest is to foster increased awareness of decision document quality. Remedial Design/Remedial Action Remedial Design (RD) is the phase in Superfund site cleanup where the technical specifications for cleanup remedies and technologies are designed. Remedial Action (RA) follows the remedial design phase and involves the actual construction or implementation phase of Superfund site cleanup. The RD/RA is based on the specifications described in the record of decision (ROD). Policy for Issuing Superfund IAGs for Assigning Superfund Remedial Design or Remedial Action Work to the U.S. Army Corps of Engineers and Other Federal Agencies (April 3, 2008) OSWER (25 pp, 6.7M) Remedial Design/Remedial Action Handbook (June 1995) OSWER B, EPA 540/R-95/059 Guidance for Scoping the Remedial Design (March 1995) OSWER , EPA/540/R-95/025 Main Document (66 pp, 970KB) Appendices (132 pp, 2.3M) Classic Two-Party Superfund State Contract (SSC) Model Clauses (August 1990) (24 pp, 1.5M) Contractor Signing of Uniform Hazardous Waste Manifests for Materials Leaving a Superfund Site (February 6, 1989) OSWER memorandum (4 pp, 198KB) Emergency Responders Agreements for Fund-Lead Remedial Actions (March 1994) OSWER FS, EPA 540-F (4 pp, 300KB) EPA Oversight of Remedial Designs and Remedial Actions Performed by Potentially Responsible Parties (February 1990) OSWER /FS (8 pp, 677KB)

8 EPA Oversight of Remedial Designs and Remedial Actions Performed by Potentially Responsible Parties - Interim Final (April 1990) OSWER (55 pp, 2.8M) EPA/USACE Payment Process: Direct Cite/Revised Reimbursement Methods (May 1990) OSWER FS (4 pp, 383KB) Expediting Remedial Construction (October 1989) OSWER /FS (6 pp, 558KB) Guidance on Expediting Remedial Design and Remedial Action (August 1990) OSWER , EPA/540/G-90/006 Chapters 1-4 (32 pp, 1.9M) Chapters 5-7 (28 pp, 1.9M) Health and Safety Roles and Responsibilities at Remedial Sites (July 1991) OSWER (6 pp, 658KB) Model RD/RA Consent Decree (June 2001) (57 pp, 423KB) Model Unilateral Administrative Order for Remedial Design and Remedial Action Under Section 106 of CERCLA (March 30, 1990) OSWER (b) (45 pp, 1.6M) Updated text on QA/QA (August 2001) (3 pp, 30KB) Permits and Permit "Equivalency" Processes for CERCLA On-site Response Actions (February 19, 1992) OSWER (8 pp, 586KB) Procedure for Use of USACE Preplaced Contracts to Expedite Superfund Cleanup Tasks (April 1994) OSWER , EPA-540- F (4 pp, 331KB) Scoping the Remedial Design (March 1995) OSWER FS, EPA 540/F-95/008 (4 pp, 62KB) Real Estate Acquisition Procedures for USACE Projects (February 1990) OSWER FS (6 pp, 90KB) Value Engineering Fact Sheet (November 2005) (PDF) OSWER FS (2 pp, 68KB) Directive (April 2006) (PDF) (4 pp, 272KB) Construction Completions EPA has developed the construction completions list (CCL) to simplify its system of categorizing sites and to better communicate the successful completion of cleanup activities. Sites qualify when:

9 any necessary physical construction is complete, whether or not final cleanup levels or other requirements have been achieved; or EPA has determined that the response action should be limited to measures that do not involve construction; or the site qualifies for Deletion from the NPL. Inclusion of a site on the CCL has no legal significance. The "Closeout Procedures for National Priorities List Sites" provides guidance on achieving the construction completion milestone. Locate Construction Completion Sites: by State or by Date Number of Construction Completions by Fiscal Year Policy for Including Sites Deleted from the NPL on the Construction Completion List Post Construction Completion Proposed Policy Change (PDF) (65 FR 47988, August 4, 2000) (2pp, 122KB) Final Policy Change (PDF) (65 FR 57810, September 26, 2000) (2pp, 121KB) The goal of Post Construction Completion activities is to ensure that Superfund response actions provide for the long-term protection of human health and the environment. EPA's Post Construction Completion activities also involve optimizing remedies to increase effectiveness and/or reduce cost without sacrificing long-term protection of human health and the environment. You can learn more about Post Construction Completion in the Post Construction Completion Web area. Information in this area includes: Long-Term Response Actions (LTRA); Operation and Maintenance; Institutional Controls; Five-Year Reviews; Remedy Optimization; and NPL Deletion How Sites are Deleted from the NPL EPA may delete a final NPL site if it determines that no further response is required to protect human health or the environment. Under Section (e) of the National Contingency Plan (55 FR 8845,

10 March 8, 1990), a site may be deleted where no further response is appropriate if EPA determines that one of the following criteria has been met: EPA, in conjunction with the State, has determined that responsible or other parties have implemented all appropriate response action required. EPA, in consultation with the State, has determined that all appropriate Superfund-financed responses under CERCLA have been implemented and that no further response by responsible parties is appropriate. A Remedial Investigation/Feasibility Study has shown that the release poses no significant threat to public health or the environment and, therefore, remedial measures are not appropriate. Since 1986, EPA has followed these procedures for deleting a site from the NPL: The Regional Administrator approves a "close-out report" that establishes that all appropriate response actions have been taken or that no action is required. The Regional Office obtains State concurrence. EPA publishes a notice of intent to delete in the Federal Register and in a major newspaper near the community involved. A public comment period is provided. EPA responds to the comments and, if the site continues to warrant deletion, publishes a deletion notice in the Federal Register. Sites that have been deleted from the NPL remain eligible for further Superfund-financed remedial action in the unlikely event that conditions in the future warrant such action. Partial deletions can also be conducted at NPL sites. Guidance for Deleting Sites from the National Priorities List Direct Final Process for Deletions "Closeout Procedures for National Priorities List Sites" (January 2000) OSWER Directive A-P, EPA 540-R

11 Deleting Resource Conservation and Recovery Act (RCRA) Facilities Policy for Non-Federal Facilities (PDF) (60 FR 14641, March 20, 1995) [5 pp, 67KB, About PDF] Policy Revised for Federal Facilities (PDF) (62 FR 62523, November 24, 1997) [4 pp, 56KB, About PDF] Site Reuse/Redevelopment EPA's goal is to make sure that at every cleanup site, the Agency and its partners have an effective process and the necessary tools and information needed to fully explore future uses, before the cleanup remedy is implemented. This gives the Agency the best chance of making its remedies consistent with the likely future use of a site. In turn, EPA gives communities the best opportunity to productively use sites following cleanup. In the Superfund Redevelopment Web area, you can learn more about the Superfund program is working with communities and other partners to return hazardous waste sites to safe and productive use without adversely affecting the remedy.