&EPA
United States
Environmental Protection
Agency
Solid Waste and
Emergency Response
(5201G)
EPA 540-R-98-016
OSWER Directive 9320.2-09A-P
PB98-963223
January 2000
www.epa.gov.superfund
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Close Out Procedures for
National Priorities List Sites
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EPA 540-R-98-016
OSWER Directive 9320.2-09A-P
PB98-963223
January 2000
Close Out Procedures for
National Priorities List Sites
Office of Emergency and Remedial Response
U.S. Environmental Protection Agency
Washington, D.C. 20460
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ABSTRACT
This guidance document describes the key principles and expectations, interspersed with "best
practices" based on program experience, that should be consulted at the time to Close Out
Superfund's National Priorities List Sites. The Close Out Procedures forNational Priorities List Sites
are organized into five principal areas: Remedial Action Completion, Construction Completion. Site
Completion, Site Deletion and Partial Deletion. The purpose of the guidance is to briefly summarize
key elements of the various close out options for actions at sites. EPA believes that consistent
application of national policy and guidance is an important means by which we ensure
reasonableness, predictability, and consistency in our decisions.
To OBTAIN DOCUMENT
EPA employees can obtain additional copies of this guidance, or copies of documents referenced in
the guidance, by calling the Superfund Document Center at 703-603-9232, or by sending an e-mail
request to superfund.documentcenter@epa.gov. Non-EPA employees can obtain these documents
by contacting the National Technical Information Service at 703-605-6000.
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Table of Contents
1.0 INTRODUCTION [[[ J'J
1.1 Background '"'
1.2 Contents of the Guidance
1 .3 Remedial Project Manager Role
2.0 REMEDIAL
2.1
2.2
2.3
2.4
2.5
2.6
2.7
2.8
ACTION COMPLETION
2.2.1
2.2.2
2.3.1
2.3.2
2.3.3
2.3.4
2.4.1
2.4.2
2.4.3
2.5.1
2.5.2
2.5.3
Introduction
Remedial Action (RA) Completion Definition
Interim RA Report
Final RA Report
Relationship of RA Completion to Other Actions
Operational & Functional (O&F)
Long-Term Response Action (LTRA and PRP LR)
Operation and Maintenance (O&M)
Cleanup Goals Achieved
Inspection Requirements for RA Completion
Fund-lead RA Completion Inspections
Responsible Party-lead RA Completion Inspections
Federal Facility-lead RA Completion Inspections
Preparing the RA Report
Submitting the RA Report
Who Prepares the RA Report
Contents of the RA Report
RA Report Approval
RA Report Distribution
Completion of the Last RA at a Site
2-1
2-1
2-1
2-2
2-2
2-2
I-"1
2-3
2-3
2-4
2-5
2-5
2-5
2-5
2-5
2-6
2-6
2-6
2-6
2-6
2-6
3.0 CONSTRUCTION COMPLETION
3.1
3.2
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j.j
3.4
3.5
3.6
3.7
3.8
*» ** i
j.j.l
3.3.2
3.5.1
3.5.2
3.5.3
3.5.4
3.5.5
3.6.1
3.6.2
3.6.3
3.6.4
3.6.5
Background
Construction Completion Process
Sites Requiring RA in the Final OU
Pre-Final Inspection
Preliminary Close Out Report
Sites Requiring No RA in the Final OU
Technology Considerations for Construction Completions
Ground and Surface Water Restoration Remedies
Phased Ground Water Cleanup Approach
In-situ Soil Vapor Extraction and Bioremediation Remedies
RODs with Contingency Remedies
Monitoring and Institutional Controls
Lead and Authority Considerations for Construction Completions
PRP Lead
Federal Facilities
Removal Authority
Resource Conservation and Recovery Act Deferral
Multiple Authorities Conducting Cleanup at the Same Site
Additional Work at Construction Completion Sites
Construction Completion Checklist
3-1
3-1
3-1
3-3
3-3
3-3
3-5
3-5
3-5
3-5
3-6
3-7
3-7
3-8
3-8
3-8
3-8
3-8
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4.0 SITE COMPLETION , 4-1
4.1 Site Completion Criteria 4-1
4.2 Site Completion Process 4-1
4.2.1 Removal Authority 4-1
4.2.2 Remedial Authority 4-3
4.3 Final Close Out Report 4-3
4.4 Site Completion Checklist 4-5
5.0 SITE DELETION 5-1
5.1 NPL Deletion Criteria 5-1
5.2 NPL Deletion Through Resource Conservation and Recovery Act Deferral (RCRA) . 5-2
5.3 The Deletion Process 5-2
5.3.2 State Concurrence , 5-3
5.3.3 Deletion Docket 5-3
5.3.4 Notice of Intent to Delete 5-3
5.3.5 Publication of the Notice of Intent to Delete and the Local Notice 5-4
5.3.6 Responsiveness Summary and Notice of Deletion 5-5
5.4 Streamlining the Deletion Process 5-5
5.5 Site Deletion Checklist 5-5
6.0 PARTIAL DELETION 6-1
6.1 Partial Deletion Process 6-1
6.2 Special Partial Deletion Requirements 6-2
6.2.1 Mapping Requirements 6-2
6.2.2 Documentation to Support the Partial Deletion Decision 6-3
6.3 Partial Deletion Checklist 6-3
6.4 When Can You Partially Delete 6-4
6.5 Sites with Partial Deletions 6-4
IV
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List of Exhibits
EXHIBIT 2-1, Remedial Action Completion Examples 2-1
EXHIBIT 2-2, End-of-the-Pipeline Examples 2-4
EXHIBIT 2-3, RA Report Contents 2-7
EXHIBIT 3-1, Construction Completion Process 3-2
EXHIBIT 3-2, Examples of Minor "Punch List" Items 3-3
EXHIBIT 3-3, Preliminary Close Out Report Summary 3-4
EXHIBIT 4-1, Site Completion Process 4'2
EXHIBIT 4-2, Final Close Out Report Summary 4'4
EXHIBIT 5-1, Site Deletion Process 5"2
EXHIBIT 5-2, Notice of Intent to Delete Summary 5-4
EXHIBIT 6-1, Partial Deletion Process 6'2
Appendices
Appendix A - REMEDIAL ACTION REPORTS A'l
Appendix B - PRELIMINARY CLOSE OUT REPORTS B-l
Appendix C - FINAL CLOSE OUT REPORT C-l
Appendix D - NOTICES OF INTENT To DELETE D-1
Appendix E - LOCAL NOTICE OF INTENTTO DELETE E-l
Appendix F - NOTICE OF DELETION F-'
Appendix G - PARTIAL SITE DELETION DATA COLLECTION FORM G-
Appendix H - NOTICE OF INTENT OF PARTIAL DELETION H-
Appendix I - NOTICE OF PARTIAL DELETION 1-
Appendix J - SUPERFUND ACRONYMS LIST J-
Appendix K - GLOSSARY K-
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1.0 INTRODUCTION
This guidance document is designed primarily for
U.S. Environmental Protection Agency's (EPA's)
Remedial Project Managers (RPMs). It describes the
process for accomplishing remedial action
completion, construction completion, site
completion, and site deletion. The guidance applies
only to those sites that are or were final on the
National Priorities List (NPL). It supersedes the
following documents:
Office of Solid Waste and Emergency Response
(OSWER) Directive 9320.2-3A, "Procedures for
Completion and Deletion of National Priorities
List Sites," April 1989,
OSWER Directive 9320.2-3B, "Update to the
Procedures for Completion and Deletion of
National Priorities List Sites," Guidance
Document Regarding the Performance of Five-
Year Reviews," December 29, 1989,
OERR Fact Sheet, "Remedial Action Report,"
June 1992,
OSWER Directive 9320.2-3C, "Update No. 2 to
Procedures for Completion and Deletion of NPL
Sites," February 19, 1992,
OSWER memorandum, "Documentation of
Close Out Requirements at Sites Where There is
a No Action Record of Decision," February 2,
1993,
"Superfund Completion Care Package," 2nd
Edition, May 1993,
OSWER Directive 9320.2-06, "NPL
Construction Completion Definition at
Bioremediation and Soil Vapor Extraction
Sites," June 21, 1993, and
OSWER Directive 9320.2-09, "Close Out
Procedures for National Priorities List Sites,"
August 1995.
1.1 Background
Section 105 of the Comprehensive Environmental
Response. Compensation, and Liability Act of 1980
(CERCLA), as amended by the Superfund
Amendments and Reauthorization Act of 1986
(SARA), requires EPA to maintain an NPL of
uncontrolled hazardous waste sites that have released
or pose a threat of release of hazardous substances
into the environment. Pursuant to the National Oil
and Hazardous Substances Pollution Contingency
Plan (NCP) (40 Code of Federal Regulations [CFR
Part 300), sites on the NPL are eligible for
Superfund-financed remedial actions (RAs).
Superfund addresses NPL sites through a
combination of removal and remedial authority.
Cleanup activities under removal authority achieve
prompt risk reduction through emergency,
time-critical, and non time-critical actions. In
general, cleanup actions under removal authority are
documented with an Action Memorandum or an
Engineering Evaluation / Cost Assessment.
Cleanup activities under remedial authority are called
remedial actions. A remedial investigation /
feasibility study (RI/FS) at an NPL site determines
the nature and extent of contamination, and identifies
alternatives for the remedy. The Record of Decision
(ROD) documents the remedial activities selected to
achieve protectiveness. (For pre-SARA sites,
detailed remedial activities sometimes may be
described in other EPA reports such as a consent
decree or an administrative order). Remedial actions
(RAs) are intended to protect human health and the
environment, and they may include any combination
of treatment, containment, or removal of
contaminated material, providing alternate water
supplies, and imposing institutional controls that
address site use.
1.2 Contents of the Guidance
A Superfund site may require several RAs to address
all the site hazards. The process for Remedial Action
completion is described in Chapter 2 of this
guidance.
Once physical construction is complete at the entire
site (through removal or remedial authority), the site
achieves the construction completion milestone.
EPA introduced the construction completion
milestone to better communicate the successful
completion of site construction activities.
Construction completion marks the end of an
important phase in the Superfund completion
process. EPA Headquarters monitors and reports site
progress toward the construction completion
milestone. The process for construction completion
is described in Chapter 3.
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Site completion occurs when no further response is
required at the site, all cleanup goals have been
achieved, and the site is deemed protective of human
health and the environment. Once site completion
is achieved, the site becomes a candidate for NPL
deletion. Chapter 4 covers the site completion
milestone.
When no further response is required at a site or a
portion of the site, all cleanup goals have been
achieved, and the site or portion of the site is deemed
protective of human health and the environment, the
site is eligible for full or partial deletion from the
NPL. This stage, as dictated by the NCP, is known
as site deletion. Essentially, this process entails
documenting the response activities for the site,
verifying and documenting that activities have been
conducted and that the site is protective of human
health and the environment, obtaining State
concurrence, and offering the public an opportunity
for notice and comment before the site is formally
deleted from the NPL. The process is further
described in Chapters 5 and 6.
This guidance provides detailed information on
achieving the various milestones of the NPL site
close out process, highlighting specific activities and
the related reports that indicate each activity's
completion. Appendices A through I provide
examples of the reports discussed. Appendices J and
K are reference materials to be used with this
guidance.
OSWER Directive No. 9200.4-22A. "CERCLA
Coordination With Natural Resource Trustees" dated
July 31, 1997, requires that Trustees listed in the
Regional Contingency Plans be notified of the
completion of construction at each operable unit.
The guidance also indicates that EPA will seek to
consult with Trustees prior to deleting a site from the
NPL. In response to the requirements of the
"CERCLA Coordination With Natural Resource
Trustees" guidance, appropriate language has been
added to this document addressing the notification
requirements.
This guidance replaces OSWER Directive 9320.2-09,
"Close Out Procedures for National Priorities List
Sites," August 1995. The effective date of this
guidance is January 1, 2000.
1.3 Remedial Project Manager Role
The RPM has lead responsibility for ensuring the
successful completion of cleanup activities at an NPL
site and for guiding a site through each successive
phase of the Superfund process. This guidance
document emphasizes the role of the RPM during the
final stages of site remediation. The RPM is
responsible for applying EPA's criteria to a site to
determine its eligibility for achieving each milestone.
The RPM ensures that all statutory, regulatory, and
policy requirements are met, both technically and
procedurally. Each milestone is documented by a
specific report. The RPM should carefully document
all site activities for related reporting needs.
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2.0 REMEDIAL ACTION COMPLETION
2.1 Introduction
This chapter describes the procedures for achieving
Remedial Action (RA) Completion at an Operable
Unit (OU), or portion, of a National Priorities List
(NPL) site. Remedial actions can only be funded at
sites that are final on the NPL. A RA is the
implementation of the remedy selected in the Record
of Decision (ROD). Typically, the ROD identifies an
OU of the overall site cleanup plan.
During the remedial design (RD) and RA stages, an
OU can be broken into phases to accelerate
implementation of the OU. These phases enable
adjustment of the internal steps required to complete
each OU. Each phase becomes a separate RA
sequence under the OU. For purposes of this
chapter, the discussion will assume that each OU has
one RA and, hence, one RA Completion. If the
Region chooses to phase OU implementation, then
there is a separate RA Completion for each phase of
theOU.
2.2 Remedial Action (RA) Completion
Definition
RA Completion for an OU is achieved when the
designated Regional official (Branch Chief or above,
as determined by the EPA Region) approves in
writing the Interim or Final RA Report.
The submission and type (Interim or Final) of RA
Report prepared varies depending on the type of
remedy that was implemented. Exhibit 2-1 provides
examples of RAs and indicates when RA Completion
can be achieved.
EXHIBIT 2-1, Remedial Action Completion Examples
Example RA
Excavation and off-site disposal of
contamination.
On-site treatment of wastes, other than ground
water or surface water, to achieve cleanup
goats (e.g., soil vapor extraction,
bioremediation, incineration).
Containment remedies.
Ground water and surface water restoration
remedies that involve active treatment to
reduce contaminant concentrations to meet
cleanup goals.
Ground water and surface water restoration
remedies that involve monitored natural
attenuation to reduce contaminant
concentrations to meet cleanup goals.
RA is Complete
After all wastes have been excavated, removed from the site to an
approved location, site has been restored, cleanup goals have been
achieved, and the Final RA Report is approved.
After cleanup goals have been achieved for the treated wastes, site
has been restored, and the Final RA Report is approved.
After construction of the designed remedy is complete, cleanup
goals have been achieved, and the Final RA Report is approved.
After construction of the treatment plant and monitoring system
are completed, the plant / system is operating as intended (also
called operational and functional, O&F), and the Interim RA
Report is approved. (The Final RA Report is prepared when
cleanup goals are achieved.)
After the ROD is signed, any necessary RA is conducted, and the
Interim RA Report is approved. (The Final RA Report is prepared
when cleanup goals are achieved.)
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(Example RA
Ground water and surface water restoration
remedies where restoration is later determined
to be technically impracticable (TI waiver).
RA is Complete
RA completion has already been documented by an Interim RA
Report, as above; however, the Region must later prepare a ROD
Amendment to document the TI waiver.
2.2.1 Interim RA Report
The Interim RA Report for a given OU is used only
for RAs that include ground- or surface-water
restoration remedies, including monitored natural
attenuation. Interim reports are used because of the
long delay between construction of the treatment
facility (or ROD signature for monitored natural
attenuation) and achievement of cleanup goals.
Criteria for EPA approval of the Interim RA Report
are:
The remedy includes ground water or surface
water restoration, with active treatment or
monitored natural attenuation, to reduce
contaminant concentrations to meet cleanup
goals (and cleanup goals have not been
achieved);
For active treatment, the construction of the
treatment system is completed, and the system is
operating as intended (operational & functional);
For monitored natural attenuation, any necessary
RA, such as monitoring wells, has been
constructed;
If the OU includes remedy components other
than ground water, construction activities are
complete and cleanup goals specified in the
ROD have been achieved for these components;
A contract final inspection or equivalent has
been conducted; and
The Interim RA Report contains the information
described in Exhibit 2-3.
2.2.2 Final RA Report
Criteria for approval of the Final RA Report for a
given OU are:
All construction activities are complete,
including site restoration and demobilization;
All cleanup goals specified in the ROD have
been achieved, including those for ground- and
surface water restoration, if applicable;
If containment, the remedy is operating as
intended (operational & functional)
A contract final inspection or equivalent has
been conducted; and
The Final RA Report contains the information
described in Exhibit 2-3.
Note: When an Interim RA Report has already been
prepared, the Interim RA report can simply be
amended to create the Final RA Report. The
amendment would add information on activities that
occurred after the Interim RA Report was completed.
2.3 Relationship of RA Completion to
Other Actions
This section describes other actions in the remedial
pipeline that relate to RA Completion. Much of the
language that follows comes from OSWER
Publication 9200.3-14IE, "Superfund / Oil Program
Implementation Manual, Fiscal Year 99/00," (SPIM)
and the National Contingency Plan (NCP). At the
end of the section, the Response Actions are shown
graphically in Exhibit 2-2.
2.3.1 Operational & Functional (O&F)
O&F activities are conducted after physical
construction of the remedy is complete to ensure that
it is functioning properly and operating as designed.
O&F determinations are made for containment
remedies (all media), ground water restoration, and
surface water restoration, but not for monitored
natural attenuation. The phase following
construction of the remedy and before O&F is often
referred to as shakedown, where the constructor
makes minor modifications as necessary to ensure the
remedy is operating as designed.
Formal O&F determinations are primarily made for
Fund-financed projects because O&F governs when
the Regions turn these projects over to the States for
operation and maintenance. The term O&F is also
sometimes applied to Potential Responsible Party
(PRP) lead projects to signify the end of the
shakedown period. For Federal Facilities (FF) lead
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projects, a different determination, Operating
Properly and Successfully, is made.
O&F Determination: A remedy becomes O&F
either one year after construction is complete, or
when the remedy is determined concurrently by EPA
and the State to be functioning properly and is
performing as designed, whichever is earlier. EPA
may grant extensions to the one-year period in
writing, as appropriate. At a minimum, the
attainment of O&F is documented in the Interim or
Final RA Report. It may also be documented by
letter to the interested parties.
2.3.2 Long-Term Response Action (LTRA
and PRP LR)
LTRA is defined as the Fund-financed operation of
ground water and surface water restoration measures,
including monitored natural attenuation, for the first
ten years of operation. The Fund continues to pay 90
percent of the cost during this period, and the State
funds the entire operation after ten years.
Regions have sometimes used the term LTRA
inexactly to describe PRP-conducted ground water
and surface water restoration measures, including
monitored natural attenuation. PRP actions are
covered by a separate action, PRP LR, where LR
refers to Long-Term Response. Since PRP-lead PRP
LR is a specific type of O&M, the ten-year time
frame is not applicable.
The Federal Facilities program does not use LTRA or
PRP LR. Their ground water and surface water
restoration measure's go from RA completion directly
to O&M.
LTRA and PRP LR do not apply to ground water or
surface water containment measures, ground water :
monitoring, ground water or surface water measures
initiated for the primary purpose of providing a
drinking water supply, bioremediation, or soil vapor
extraction.
LTRA or PRP LR Start: LTRA or PRP LR begins
on the date the designated Regional Official (Branch
Chief or above) approves the Interim RA Report.
Fund-Financed LTRA Completion: LTRA is
complete when cleanup goals are achieved, as
documented in a Final RA Report, when a technical
impracticability determination is made, or after ten
years, whichever is earlier. LTRA transitions to
O&M if cleanup goals have not been achieved within
the ten-year period.
PRP LR Completion: PRP LR is complete when
cleanup goals are achieved, as documented in a Final
RA Report, or when a technical impracticability
determination is made, whichever is earlier.
2.3.3 Operation and Maintenance (O&M)
O&M are the activities required to maintain the
effectiveness and integrity of the remedy, and, in the
case of Fund-financed measures to restore ground- or
surface-waters, continued operation of such measures
beyond the LTRA period until cleanup goals are
achieved.
PRP-conducted groundwater and surface water
restoration measures, including monitored natural
attenuation, are technically defined as O&M.
However, regions may use the action, PRP LR, to
indicate that these activities are being performed at
the site.
O&M Start: O&M starts when the RA is complete
and the State or PRPs assume responsibility for all
activities necessary to operate and/or maintain the
long-term effectiveness or integrity of the actions
selected in the ROD. This is the date the designated
Regional official accepts the Final RA Report.
In the case of an LTRA that goes the full ten years
without achieving cleanup goals, O&M starts upon
LTRA completion.
For Federal Facility-lead ground water and surface
water restorations, including monitored natural
attenuation, O&M starts on the date the designated
Regional Official approves the Interim RA Report.
O&M Completion: O&M completion may be
indefinite, as in the case of a landfill cap, or
completion may be accomplished.when cleanup
goals are achieved for ground water and surface
water restoration. Where appropriate, the completion
of O&M is defined as the date the performance
standards or conditions specified in the Cooperative
Agreement that provides funds for the RA;
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Superfund State Contract; or CD is signed by EPA,
the PRPs and Federal judge have been met with
respect to O&M.
2.3.4 Cleanup Goals Achieved
Cleanup Goals Achieved is used for ground water
and surface water restoration, including monitored
natural attenuation remedies. These remedies have
not yet achieved cleanup goals when RA is
completed and the Interim RA Report is signed.
Cleanup Goals Achieved: Cleanup goals are
achieved on the date the designated Regional Official
approves in writing the Final RA Report. This report
should update information previously provided in the
Interim RA Report.
EXHIBIT 2-2, End-of-the-Pipeline Examples
Treatment and Off-site Disposal Remedies Pipeline
Final
RA Report
RA
(no O+M required)
Containment Remedies Pipeline
Final
RA Report
RA
O+M
Ground Water and Surface Water Restoration Pipeline
RA
Interim
RA Report
» LTRA (Fund)
PRP LR (PRP)
O&M (FF)
< 10yrs.
Final RA Report
(Cleanup Goals
Achieved)
O+M
<1yr
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2.4 Inspection Requirements for RA
Completion
With any RA construction contract, regardless of lead
or contracting party, normal construction industry
practice is to conduct contract pre-fmal and final
inspections prior to closing out the construction
contract. These inspections are conducted to
determine whether the construction has been
completed in accordance with the contract design and
specifications. The inspections are generally held
between the contracting party and the construction
contractor, although others can be invited.
During the contract pre-final inspection, the
contracting party's project manager and the
construction contractor inspect all elements of work
to see if the work is complete and ready for
acceptance under the terms of the contract. Some
minor defects may come to light as the inspection
proceeds. The construction manager develops a
"punch list" of all items that need correction or
completion before the work can be accepted. A
pre-final inspection report is prepared, including the
punch list, completion dates for outstanding items,
and a date for a final inspection.
If punch list items are minor, the pre-final inspection
may automatically serve as the final inspection.
Otherwise, a final inspection is conducted later to
determine that punch list items are corrected and all
work has been completed in accordance with the
contract plans and specifications.
The National Contingency Plan, Model Consent
Decree, and Federal Facility Agreements may
require other RA completion inspections. These
inspections may be held concurrently with or
separately from the contract pre-final and final
inspection described above.
2.4.1 Fund-lead RA Completion Inspections
The NCP requires an additional inspection at Fund
lead sites requiring operation and maintenance. An
inspection is conducted jointly by EPA and the State
at the end of all construction activities for that RA.
If convenient, it can be conducted in conjunction
with the contract pre-final or final inspection. After
the inspection, EPA may share in the cost of
operating the RA for up to one year to ensure that the
remedy is O&F. See section 2.3.1.
2.4.2 Responsible Party-lead RA
Completion Inspections
The Model RD / RA Consent Decree of July 1995
requires a pre-certification inspection upon
completion of the RA. This inspection normally
involves the Settling Defendants (PRPs), EPA, and
the State. The purpose of this inspection is to
determine if the RA has been fully performed in
accordance with the terms of the Consent Decree.
After the pre-certification inspection, the Settling
Defendants are also required to submit a written
report to EPA for approval stating that the RA has
been completed in full satisfaction of the
requirements of the Consent Decree. This report, if it
contains the proper information, can serve as the
Final RA Report for the OU. For ground water and
surface water restoration remedies, where an Interim
RA Report is appropriate, EPA may have to prepare
the interim report since it is normally not required in
the Consent Decree.
2.4.3 Federal Facility-lead RA Completion
Inspections
Federal Facility Agreements generally require an
additional set of inspections to determine that all
aspects of the remedy have been implemented in
accordance with applicable enforcement documents
and the ROD. Participants include the EPA,
oversight contractor, and the State. The inspection
can be done concurrently with the contract inspection
described in Section 2.4.
2.5 Preparing the RA Report
The RA Report documents the cleanup activities that
took place at a single OU under remedial authority.
The RA Reports for a site can be used as the
supporting documentation for development of the
Final Closeout Report for the site, as described in
Chapter 4.
The RA Report is a key document to gather historical
cleanup information for analysis of Superfund
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remedies. It is the mechanism used to share
information within EPA, and between EPA and other
Federal agencies. The RA Report includes cost and
performance data which, along with other
information t, assists with future remedy selection
decision-making, provides a means to compare
technology performance, supports improved cost
comparisons, and documents progress made at sites.
2.5.1 Submitting the RA Report
The RA Report should be completed as soon as
possible after contract final inspection of the
completed construction and determination that the
remedy is O&F, if applicable. The RA Report may
take some time to compile; however, the goal is to
have the report submitted to the Region for approval
within 90 days of the final inspection or O&F
determination. In order not to delay the preparation
of the report, estimated costs can be used to
supplement the known actual costs when pending
contractor claims have not been settled.
2.5.2 Who Prepares the RA Report
The RA Report is prepared by the party most familiar
with the RA design and construction efforts, and
associated project costs. Such familiarity provides
the best opportunity to discuss the successes,
difficulties, and lessons learned about the project.
The contracting party for the RA (e.g., the PRPs, the
Army Corps of Engineers, the State, EPA's
contractor, or another Federal Agency) is most
familiar with the RA. While the EPA RPM
sometimes does prepare the RA Report, the
contracting party generally should be tasked with that
effort.
2.5.3 Contents of the RA Report
Exhibit 2-3. at the end of this chapter, presents the
specific contents that should be included in the RA
Report. Appendix A provides a sample RA Report.
2.6 RA Report Approval
Since the RA Report is ideally prepared by the
contracting party, and not EPA, the report must be
approved by EPA in order to achieve RA Completion
for an OU. There is no EPA Headquarters (HQs)
review or concurrence role for RA Reports.
Approval occurs when the designated Regional
official (Branch Chief or above, as determined by the
EPA Region) approves in writing the Interim or Final
RA Report. The approval can be provided with an
appropriate signature on the RA Report cover sheet
or by letter to the originator of the RA Report.
2.7 RA Report Distribution
Once the RA Report is approved, the original is
retained in the Regional site file, and a copy should
be returned to the originator of the report. Upon RA
Completion, the Region is also required to notify the
appropriate Natural Resources Damages Trustees
listed in the Regional Contingency Plans. The
Region should provide a copy of the Interim or Final
RA Report to the Trustees within one week of the
completion and approval of the report.
A copy of the RA Report should also be sent to EPA
HQs for extraction of useful technical information.
Send the report electronically to the appropriate
Regional Center in EPA HQs, Office of Emergency
and Remedial Response.
2.8 Completion of the Last RA at a Site
As the RA Completion for the last OU at the site
nears, the Region needs to plan ahead for achieving
Construction Completion, which is described in
Chapter 3. Often, Construction Completion for the
site is achieved prior to RA Completion for the last
OU. Reasons include:
Due to the need to gather cost and performance
information, the Interim or Final RA Report
(document RA completion) is prepared up to 90
days after the contract final inspection or O&F
determination. The Preliminary Closeout Report
(for the site) can be prepared very soon after the
contract final inspection and before O&F
determination.
For bioremediation and soil vapor extraction
remedies, the RA Report is not prepared until
cleanup goals are achieved, often several years
after construction of the treatment system. The
Preliminary Closeout Report for the site can be
prepared when the system is operating
satisfactorily.
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Even if Construction Completion has already been
achieved, the Region must still ensure that a RA
Report is prepared for the final Operable Unit.
EXHIBIT 2-3, RA Report Contents
SECTION
CONTENTS
Introduction
Include a brief description of the location, size, environmental setting, and
operational history of the site.
Describe the operations and waste management practices that contributed
to contamination of the site.
Describe the regulatory, and enforcement history of the site.
Describe the major findings and results of site investigation activities.
Describe prior removal arid remedial activities at the site.
Describe the other OLJs designated at the site and introduce the OU for
which the RA Report applies.
[I. Operable Unit Background
Summarize requirements specified in the ROD for the OU. Include
information on the cleanup goals, institutional controls, monitoring
requirements, operation and maintenance requirements, and other
parameters applicable to the design, construction, operation, and
performance of the RA.
1 Provide additional information regarding the basis for determining the
cleanup goals for the OU, including planned future land use.
1 Summarize the remedial design, including any significant regulatory or
technical considerations or events occurring during the preparation of the
RD.
' Identify and briefly discuss any ROD amendments, explanation of
significant differences, or technical impracticability waivers.
III. Construction Activities
Provide a step-by-step summary description of the activities undertaken to
construct and implement the RA (e.g., mobilization and site preparatory
work; construction of the treatment system; associated site work, such as
fencing and surface water collection and control; system operation and
monitoring; and sampling activities).
If a treatment remedy, refer reader to Appendix A for characteristics, site
conditions, and operating parameters for the system.
IV. Chronology of Events
> Provide a tabular summary that lists the major events for the OU, and
associated dates of those events, starting with ROD signature.
1 Include significant milestones and dates, such as, remedial design submitta
and approval; ROD amendments; mobilization and construction of the
remedy; significant operational events such as treatment system /
application start-up, monitoring and sampling events, system
modifications, operational down time, variances or non-compliance
situations, and final shut-down or cessation of operations; final sampling
and confirmation-of-performance results; required inspections;
demobilization; and completion or startup of post-construction operation &
maintenance activities.
If an Interim RA Report, indicate when cleanup goals are projected to be
achieved for the around or surface water restoration.
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SECTION
CONTENTS
V. Performance Standards and
Construction Quality
Control
1 Describe the overall performance of the technology in terms of comparison
to cleanup goals.
1 For treatment remedies, identify the quantity of material treated, the
strategy used for collecting and analyzing samples, and the overall results
from the sampling and analysis effort.
1 Provide an explanation of the approved construction quality assurance and
construction quality control requirements or cite the appropriate reference
for this material. Explain any substantial problems or deviations.
1 Provide an assessment of the performance data quality, including the
overall quality of the analytical data, with a brief discussion of quality
assurance and quality control (QA/QC) procedures followed, use of a
quality assurance project plan (QAPP), comparison of analytical data with
data quality objectives (DQOs).
1 For PRP-funded projects, discuss EPA's oversight activities and results
with regard to analytical data quality.
VI. Final Inspection and
Certifications
1 Report the results of the various RA contract inspections, and identify
noted deficiencies.
> Briefly describe adherence to health and safety requirements while
implementing the RA. Explain any substantial problems or deviations.
1 If implemented, summarize details of the institutional controls (e.g., the
type of institutional control, who will maintain the control, who will
enforce the control).
1 For RP-lead, describe results of pre-certification inspection.
1 If applicable, certify that the remedy is operational and functional, along
with the date this was achieved.
VII. Operation & Maintenance
Activities
Describe the general activities for post-construction operation and
maintenance activities, such as monitoring, site maintenance, and closure
activities.
Identify potential problems or concerns with such activities.
If an Interim RA Report, describe the future ground water or surface water
restoration activities to meet cleanup goals.
VIII. Summary of Project Costs
1 Provide the actual final costs and applicable year for the project. This is
required for Fund-lead projects and should be provided whenever possible
for PRP-lead projects. If actual costs are not available, provide estimated
costs.
1 Provide the costs previously estimated in the ROD for the selected remedy,
including, as applicable, RA capital costs, PA operating costs, post-RA
annual O&M costs, and number of years of O&M. Adjust the estimates to
the same dollar basis year as the actual project costs, and provide the index
used.
1 Compare actual RA costs to the adjusted ROD estimates. If outside range
of-30 to +50 percent, explain the reasons for differences.
1 If the project is PRP-funded, include a summary of EPA oversight costs for
RD and RA.
For treatment remedies, calculate unit costs based on the sum of the actual
RA capital and RA operating costs divided by the quantity of material
treated.
Refer reader to Appendix A for a detailed breakdown of RA and O&M
costs.
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SECTION
IX. Observations and Lessons
Learned
X. Operable Unit Contact
Information
Appendix A
Cost and Performance
Summary
Other Appendices
CONTENTS
Provide site-specific observations and lessons learned from the project,
highlighting successes and problems encountered and how resolved.
Provide contact information (names, addresses, phone numbers, and
contract / reference data) for the major design and remediation contractors,
EPA oversight contractors, and the respective RPM and project managers
for EPA, the State, and the PRPs, as applicable.
The specific parameters presented in Appendix A are in accordance with
the "Guide to Documenting and Managing Cost and Performance
Information for Remediation Projects," EPA 542-B-98-007. Regions are
encouraged to use the recommended procedures outlined in this Guide for
documenting cost and performance information as part of the RA Report.
Identify the matrix characteristics and site conditions that most affected the
cost and performance, the corresponding values measured for each
characteristic or condition, and the procedures used for measuring those
characteristics or conditions. These items include the soil type and particle
size distribution, environmental setting, media properties, and quantity of
materials treated.
Identify the operating parameters specified by the remediation contractor
that most affected the cost and performance, the corresponding values
measured for each parameter, and the procedures used for measuring those
parameters. These items include system throughput, pumping rate, flow
rate, mixing rates, residence time, operating pressure and temperature,
moisture content, and pH.
Provide a detailed breakout of the actual RA capital costs, RA operating
costs (costs to operate and maintain the treatment process), and estimated
Provide supplemental information in appendices to the RA Report. These
could include a map of the site and operable unit, a schematic of the
treatment system, supplemental performance information, and a list of
references.
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3.0 CONSTRUCTION COMPLETION
3.1 Background
In the first ten years of the Superfund program,
outside audiences often measured Superfund's
progress in cleaning up sites by the number of sites
deleted from the NPL as compared to the number of
sites on the National Priorities List (NPL). This
measure, however, did not and still does not fully
recognize the substantial construction and reduction
of risk to human health and the environment that has
occurred at NPL sites not yet eligible for deletion. In
order to better measure Superfund's progress, the
Superfund 30-Day Task Force Report recommended
setting firm annual targets for completing remedial
construction activities at sites on the NPL.
A construction completion site is a former toxic
waste site where physical construction of all cleanup
actions are complete, all immediate threats have been
addressed, and all long-term threats are under
control.
In a 1990 Federal Register Notice (FR), the
Environmental Protection Agency (EPA) established
the Construction Completion category on the NPL
(FR Volume 55, No. 46, March 8, 1990).
"The category would consist of: (a) sites awaiting
deletion, (b) sites awaiting deletion but for which
CERCLA section 12 Ic requires reviews of the
remedy no less often than five years after initiation,
and (c) sites undergoing long-term response
action(s). EPA believes the new category would
communicate more clearly to the public the status
of cleanup progress among sites on the National
Priorities List."
A later Federal Register Notice (FR Volume 58, No.
29, March 2, 1993) introduced the Superfund
Construction Completions List (CCL)"... to
simplify its system of categorizing sites and to better
communicate the successful completion of cleanup
activities." A total of 155 sites were included in that
list, which also clarified that determination of
construction completion at a site has no legal or
financial significance, as it does not relate to
satisfying contractual or other requirements (e.g.,
cleanup contract, consent decree, cooperative or
interagency agreement), nor to the eligibility of cost
reimbursement from the Fund.
According to the FR, "The CCL is a compilation of
sites presently or formerly on the NPL. Sites qualify
for the CCL when:
(1) Any necessary physical construction is
complete, whether or not final cleanup levels
or other requirements have been achieved;
(2) EPA has determined that the response action
should be limited to measures that do not
involve construction; or
(3) The site qualifies for deletion from the NPL."
(Note: This item does not apply to sites
deferred to RCRA or other authorities and
deleted from the NPL prior to completing
construction.)
Only final NPL sites qualify for inclusion in the
construction completion list. Final NPL sites
qualify for inclusion in the construction completion
list after completion of all construction work in all
operable units of the site.
The Region must carefully evaluate the status of
all response actions at the site and anticipate the
need for additional construction activities. If the
Region believes that additional construction might
be required in the future for the site, the site
should not be placed on the Construction
Completion List.
3.2 Construction Completion Process
The completion of the last response action (removal
or remedial) at a site determines when it becomes
eligible for construction completion. The
construction completion process is illustrated in
ExhibitS-l.
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EXHIBIT 3-1, Construction Completion Process
Does Final O
res Require Construction?^ °
Its Construct!
Completion Criteria
Met?
Draft PCOR; Obtain
Comments From EPA HQs.
No Action ROD; Draft PCOR;
Obtain Comments From EPA
HQs.
No Action ROD; Draft FCOR;
Obtain Comments From EPA
HQs.
Address EPA HQs Comments;
Obtain Regional Division Director
Signature; Forward Copy of
Signed Document to HQs.
HQs Concurs; Construction
Completion Number Assigned;
Site Included on List.
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The following sections provide more detail on the
most common candidates for the construction
completion milestone and their reporting
requirements. NPL sites that are fully addressed
under removal authority can meet the construction
completion and site completion criteria
simultaneously. The preparation of a Final Close Out
Report (FCOR) can be used to document this
milestone. Most NPL sites however, are addressed
under remedial authority. Sites addressed under
remedial authority usually meet the construction
completion criteria first, and upon reaching cleanup
goals the site qualifies for site completion. This
section addresses the following cases:
Sites requiring Remedial Action (RA) in the
final Operable Unit (OU),
Sites requiring no RA in the final OU,
Technology Considerations for Construction
Completions, and
Lead and Authority Considerations for
Construction Completions.
3.3 Sites Requiring RA in the Final OU
This section presents the construction completion
process for sites requiring physical construction in
the final operable unit. At these sites the
construction completion milestone is achieved when
a pre-fmal inspection for the last RA has been
conducted and a Preliminary Close Out Report
(PCOR) has been signed.
3.3.1 Pre-Final Inspection
A pre-final inspection should be conducted for the
site's final OU following the procedures outlined in
Section 2.4. Inspection Requirements for RA
Completion. Construction completion criteria are
satisfied when only minor "punch list" items are
identified in the inspection to finish the work in
accordance with design plans and specifications.
Minor "punch list" items are activities that are part of
the contract but do not affect the functioning of the
remedy. These items must be addressed by the
construction contractor before the final inspection.
Exhibit 3-2 provides examples of minor "punch list"
items that will still allow a construction completion
determination. Because Exhibit 3-2 is only a
representative list, each site must be evaluated
individually.
EXHIBIT 3-2,
Examples of Minor "Punch List" Items
Revegetating landscape (except when integral
remedy component)
Removing construction debris
Installing support equipment, such as security
lighting
1 Repairing poorly installed flashing on roof
1 Repairing other minor defects in workmanship or
construction
1 Demobilization activities
1 Installing additional monitoring wells
1 Resurfacing roads
3.3.2 Preliminary Close Out Report
While much of the input can be provided by the
contractor and through previous RA Reports, the
PCOR is an EPA document that is prepared by the
Remedial project Manager (RPM). Even before the
pre-final inspection is conducted, the RPM can start
drafting portions of the PCOR because much of the
documentation is historical and not dependent on the
outcome of the pre-final inspection.
The PCOR focuses on all OUs at the site, including a
description of the releases at the site, site conditions,
all construction activities (including removals),
completion of construction, Five-year Reviews, and a
detailed schedule of steps remaining for site
completion. The PCOR should contain a status report
by OU of the ROD, estimate of capital and annual
O&M costs, and the construction contract award
amount. This information should be provided for
Fund-lead projects and whenever possible for PRP-
lead projects. If the project is performed by a PRP, a
summary of EPA estimated oversight costs for design
and construction should be provided as well. The
PCOR generally should be five to seven pages and
contain the information shown in Exhibit 3-3.
Appendix B has two examples of PCORs.
The RPM will often prepare the PCOR for the site
before the RA Report for the final OU is completed.
This sequence is typical because the RA report may
take up to 90 days for the preparer (State, PRP,
USAGE, etc.) to submit and get approved, or the site
may have a long period of operation before cleanup
aoals are achieved.
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EPA Headquarters (HQs) has Regional Coordinators
assigned to act as primary reviewers of the PCORs.
These individuals will work closely with the RPM in
performing completion activities and will review the
PCOR. The RPM must send the draft PCOR to the
appropriate EPA HQs Regional coordinator for
review and comments prior to regional signature.
After addressing HQs comments and obtaining the
signature of the appropriate regional official, a copy
of the signed report is forwarded to EPA HQs.
The construction completion milestone is
achieved when the designated Regional official
signs the PCOR or FCOR, a hard copy of the
signed document is sent to EPA HQs, and EPA
HQs concurs. EPA HQs tracks and reports overall
construction completion progress.
EXHIBIT 3-3, Preliminary Close Out Report Summary
SECTION
I. Introduction
II. Summary Of Site Conditions
III. Demonstration Of Cleanup Activity
QA/QC
IV. Activities And Schedule For Site
Completion
V. Summary of Remediation Costs
VI. Five- Year Review
CONTENTS
Include general statement indicating date of pre-fmal inspection and a
statement that contractors or agencies have constructed the remedies
in accordance with remedial design plan;; and specifications.
Provide background summary of site location, site description, and
NPL listing information.
Describe any removal action activities at the site.
Include remedies selected, date RA initiated, method used to
implement RA (e.g., consent decree, contract, cooperative or other
agreement), and date and description of pre-final inspections used to
determine that construction is complete.
If implemented, summarize details of the institutional controls (e.g.,
the type of institutional control, who will maintain the control, who
will enforce the control).
Describe redevelopment potential at the <;ite, or any planned or
ongoing redevelopment work.
Document that the construction quality assurance / quality control
plan was implemented and that construction completion is consistent
with the ROD and remedial design plans and specifications.
Identify activities remaining in order to:
- Assure effectiveness of the remedy (e.g., institutional controls,
work plan for operation and maintenance),
- Assure consistency with the NCP (e.g., joint EPA / State
inspection, operational and functional determination),
- Satisfy requirements for site completion (e.g., Final RA Report).
Specify the organization responsible for implementation of each
activity.
Set dates for completion of the activities and elements required to
satisfy NCP and procedural requirements for issuing a FCOR and
reaching site completion.
Report for each operable unit:
- ROD estimate of capital costs and annual O&M costs,
- Construction contract award amount.
State whether a five-year review is required, what type of review is
required (statutory or policy), and when scheduled.
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Sometimes a PCOR may not be needed because the
site meets both construction completion and site
completion criteria (See Chapter 4) simultaneously.
In these cases, the RPM may elect to prepare a FCOR
to satisfy both documentation requirements
concurrently.
Upon completion of a PCOR or FCOR the
appropriate Trustees listed in the Regional
Contingency Plans will be notified of the
construction completion determination. The Region
will provide a copy of the report to the Trustees
within one week of the completion of the report.
3.4 Sites Requiring No RA in the Final
OU
At some NPL sites, EPA determines that no physical
construction is necessary in the final OU to protect
human health and the environment. There may or
may not have been previous removal or RAs
conducted at other OUs of the site.
These types of sites formerly qualified for
construction completion with a statement in the
certification page of the ROD that "EPA has
determined that its response at this site is complete
and no action / no physical construction is necessary
at this site. Therefore, the site now qualifies for
inclusion on the Construction Completion List." This
guidance changes that policy in order to be consistent
with documentation requirements. In addition,
confusion was created by the term "No Action ROD"
when removal or remedial construction work may
have been done in other OUs of the site. As of the
effective date of this guidance, all sites qualifying
for construction completion, including sites with
No Action RODs in the final operable unit, must
be documented via a Preliminary Close Out
Report or Final Close Out Report.
3.5 Technology Considerations for
Construction Completions
This section includes special requirements for surface
and ground water long-term restoration remedies,
bioremediation, soil vapor extraction, contingency
remedies, monitoring, and institutional controls.
3.5.1 Ground and Surface Water Restoration
Remedies
Ground and surface water restoration remedies are
undertaken to restore ground water or surface water
quality. These actions require a continuous operation
phase long after the system has been constructed, to
achieve the cleanup levels specified in the ROD.
Construction completion at these site is met when
physical construction of the remedy (e.g.,
construction of the treatment plant, pumps, and
extraction wells) is complete, the pre-fmal inspection
has been conducted, the treatment system is
operational, and any expected future adjustments are
likely to be minimal in nature (e.g., well
replacement). If substantial work is expected (e.g.,
installation of an additional extraction network or
treatment components) because the system is
currently experiencing problems or as a result of
phased construction (see section below), the site does
not qualify as a construction completion.
To document construction completion, the RPM
prepares a PCOR. In this case, the PCOR's
"Schedule for Site Completion" should include the
Operational and Functional determination and the
date when the remedy is expected to achieve the
cleanup goals.
Even though the site may be declared construction
complete, the OU involving the long-term
response action (LTRA or PRP LR) must still
achieve cleanup goals specified in the ROD. An
interim RA Report is prepared after the plant is
operating as intended (operational & functional),
and a Final RA Report is prepared when cleanup
goals are achieved.
3.5.2 Phased Ground Water Cleanup
Approach
In some situations, a phased ground water cleanup
approach is employed at a site, often under an interim
ROD. If an interim ROD has been used to initiate the
ground water cleanup, it must be followed by a final
ROD before the site qualifies as a construction
completion.
Phasing a ground water remedy is actually a multi-
phase construction project. The treatment plant and a
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set of wells (a subset of what is expected to be used
for the entire site) may be installed and operated for a
period of time. The goal of this initial phase is to test
and optimize system performance. Upon successful
completion of this phase, a series of additional wells
may be installed and tested in a consecutive manner
according to the remedial design. Because further
construction is expected after the initial treatment
plant and wells are installed, construction completion
would be achieved only after a final ROD has been
signed and all additional work has been completed.
At this point a PCOR could be prepared to document
the construction completion.
3.5.3 In-situ Soil Vapor Extraction and
Bioremediation Remedies
Bioremediation or in-situ soil vapor extraction (SVE)
technologies resemble ground water restoration
remedies in that little day-to-day activity, other than
routine operation of the treatment facility, takes place
once the treatment facility is built. Accordingly, the
construction completion policy for ground and
surface water restoration remedies also applies to
certain applications of SVE, in-situ bioremediation,
and ex-situ bioremediation. Technology descriptions
follow:
In-situ Soil Vapor Extraction
In-situ SVE units are designed to physically
remove volatile compounds from soil layers
located above the water table. The process
employs vapor extraction wells alone or in
combination with air injection wells. Vacuum
blowers induce air through the soil layers, which
strip volatile compounds from the soil and
carries them to the surface via extraction wells.
Volatiles are controlled by adsorption to
activated carbon, incineration, or condensation
by refrigeration. SVE systems vary in size, but
consist of several extraction wells and surface
blower / collection units.
Since SVE is in-situ, construction activity is
primarily limited to the installation of extraction
wells, blowers, and collection unit. Like
groundand surface water restoration, the typical
SVE site requires minimal post-construction
activity. An example is the installation of
additional extraction wells should conditions
change, wells become fouled, or to optimize
performance.
In-situ Bioremediation
In-situ bioremediation uses additives to degrade
organic contaminants in soils and aquifers.
Additives are injected into the soil or aquifer
under pressure through wells or spread on the
surface for infiltration to the contaminated
material. The type of additive used at a
particular site varies, but generally consists of
either an oxygen source, nutrients, or perhaps
micro-organisms.
In-situ bioremediation is similar to ground and
surface water restoration remedies, in that it
generally requires minimal post-construction
activity once the initial installation of injection
wells and surface equipment is completed.
Ex-situ Bioremediation
Ex-situ bioremediation uses microorganisms to
degrade organic contaminants in excavated soil,
sludge, and solids. Several variations of ex-situ
bioremediation exist, and the amount of post-
construction activity varies from site to site.
Two common applications of ex-situ
bioremediation are: slurry-phase
bioremediation, in which soils are mixed with
water to form a slurry; and solid-phase
bioremediation, in which soils are placed in a
liner, tank or building and tilled with water and
nutrients. Variations of the latter process are
called land farming or composting.
Subject to the considerations below, physical
construction at ex-situ bioremediation sites can
be considered completed if the contaminated
material is safely stored, and only routine
activity such as tilling remains to be done.
Should there be planned activities at the site
beyond simple regrading and revegetation (i.e.
covering residuals with a cap as an integral part
in ensuring protectiveness), then construction
would not be complete.
The many variations in applying SVE and
bioremediation technologies to sites make
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establishment of specific criteria for determining
construction completion difficult. Regions may only
declare construction completion at SVE and
bioremediation sites when the treatment unit has been
constructed, is operating as designed, and studies
show that the technology will achieve cleanup
goals. Additional consideration should be given to
ensuring protection against direct contact with
contaminated soils during the treatment process.
Safeguarding measures shall first be taken, such as
stockpiling contaminated soils in an enclosed storage
area, to ensure all pathways of exposure are
eliminated.
Unlike many ground and surface water restoration
remedies, in-situ SVE and bioremediation treatment
units are generally constructed and operated by the
same contractor. Therefore, a pre-fmal inspection
may not be initiated upon completing the
construction of the treatment unit. A thorough
inspection analogous to the pre-fmal inspection shall
be conducted and documented by the Region before
preparing the PCOR.
Even though the site is declared a "construction
completion," the operable unit involving
bioremediation or SVE remains classified as an
ongoing remedial action. It would not be called an
LTRA - that term is used exclusively for ground
water and surface water restoration remedies. The
OU remedial action will not be complete until
cleanup goals specified in the ROD are achieved and
a Final RA Report has been submitted and accepted
by EPA.
3.5.4 RODs with Contingency Remedies
RODs sometimes incorporate contingency remedies
when there is significant uncertainty about the ability
of the selected option to meet cleanup goals. This is
particularly true where an innovative treatment
technology is selected for use at a site. In terms of
the construction completion criteria, the issue of
contingency remedies are of concern only where
remediation may still be ongoing after the site is
considered construction complete (e.g., ground water,
SVE, and bioremediation). For example, where
natural attenuation is selected as the ground water
remedy. EPA may have included a more traditional
pump and treat as the contingency remedy.
Sites that have contingency remedies identified may
be considered construction complete only if the
Region can demonstrate that use of the contingency
remedy is not anticipated at the site. To make this
determination, there must be adequate justification in
the PCOR to support this claim. This documentation
must include the results from the appropriate
sampling data, modeling, etc., to support this
determination, with the information clearly presented
in the PCOR. This determination in no way affects
any Potential Responsible Party (PRP) settlement
documents. Making this determination does not
preclude having to later invoke the contingency
should it be required.
3.5.5 Monitoring and Institutional Controls
A site can be included in the CCL before monitoring
activities begin or institutional controls are in place if
those activities are included in the PCOR's "Schedule
for Site Completion."
Monitoring results provide information about an
RA's performance and the need for future actions.
Monitoring may be appropriate at any stage of an
RA, including operation and maintenance (O&M).
Although monitoring may occasionally identify the
need for future work, the need for monitoring does
not prohibit listing a site as a construction
completion if the site qualifies otherwise. Actual
installation of monitoring wells may also be included
in the "Schedule of Site Completion" if the number
of monitoring wells is not significant or is considered
part of O&M activities.
The term "Institutional Controls" refers to legal /
administrative controls that are intended to affect
human activities in such a way as to prevent or
reduce exposure. Examples are: land and natural
resource use restrictions, prohibitions on well
drilling, building permits, well use advisories, and
deed notices. Institutional controls usually
supplement containment and treatment remedies to
reduce potential threats to human health and the
environment. In rare cases they may be the sole
remedy. Since institutional controls do not require
construction, they may be implemented after
construction completion and should be shown in the
"Schedule of Activities" section of the PCOR.
However, they must be in place to achieve site
completion.
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3.6 Lead and Authority Considerations for
Construction Completions
Some NPL site cleanups are addressed by parties
other than EPA. Close out procedures for these sites
are discussed below.
3.6.1PRP Lead
The preamble to 40 CFR Part 300 states that
inclusion of a site in the Construction Completion
List does not have any legal significance and
therefore, does not affect any enforcement agreement
with the PRPs. Construction completion criteria for
PRP sites are identical to those for Fund lead. The
RPM, however, should carefully determine whether
the activities performed by the PRP are in accordance
with any applicable enforcement documents.
3.6.2 Federal Facilities
Construction completion procedures for Federal
Facility sites are identical to those for Fund- and
PRP-financed remedial actions.
3.6.3 State Lead
State-lead sites with no ROD and sites where the
State assumes all responsibility for overseeing PRP
response actions require State certification of
construction completion. In these situations, EPA
relies heavily on the State to determine the
appropriate response. EPA includes these sites on
the Construction Completion List based on a
determination by the State that all response action is
complete.
In most instances, the State prepares the PCOR and
EPA concurs with this decision by signing the PCOR.
The PCOR must include the Regional concurrence
with the State's determination that no further
response action is appropriate. If the State does not
prepare an actual PCOR. then the State should send a
certification letter to the Region that includes a
detailed summary of all actions taken at the site. It
should also include the followina certification:
"The State of
has determined this site is
protective of human health and the environment.
Therefore, all response action at this site is
complete and no further construction is anticipated.
The site meets the criteria for construction
completion as described in EPA's "Close Out
Procedures for National Priority List Sites.""
3.6.3 Removal Authority
! I !
Action under removal authority achieves prompt risk
reduction through emergency, time-critical, and
non-time critical actions! In general, cleanup actions
under removal authority will not have a ROD as is
normally the case for sites addressed under remedial
authority. NPL sites addressed entirely under
removal authority may reach the construction
completion and site completion milestones
simultaneously when:
The RPM (or On-Scene Coordinator (OSC), as
appropriate) documents in the final Pollution
Report (POLREP) that the contractor is
demobilized and has left the site. In the case of a
potentially responsible party (PRP)-lead site, the
POLREP documents that the PRP's contractor
has completed the removal action specified in
the Action Memorandum and fully met the terms
of the applicable enforcement document.
In some instances, it will be appropriate to document
the removal action with an On-Scene Coordinator
Report. For information regarding POLREP and
OSC Reports refer to Directive 9360.3-03, Superfund
Removal Procedures, Removal Response Reporting:
POLREP and OSC Reports." June 1994.
The RPM or OSC will prepare a PCOR or FCOR, as
appropriate, to document the construction
completion.
3.6.4 Resource Conservation and Recovery
Act Deferral
The same notice that introduced the Construction
Completion List (FR Volume 58, No. 29, March 2,
1993) also indicated that:
" ... deleted sites will not qualify for the CCL if
physical construction remains to be conducted
under another statutoiy authority."
Further, EPA's "Deletion Policy for Resource
Conservation and Recovery Act Facilities" (FR
3-8
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Notice 40 CFR Part 300 dated March 20, 1995). later
amended to make the policy also applicable to
Federal Facility sites (FR Notice 40 CFR Part 300
dated November 24, 1997) indicates the following:
"EPA believes it is appropriate to delete sites from
the NPL based upon deferral to RCRA under
certain circumstances. Deletion of sites from the
NPL to defer them to RCRA Subtitle C Corrective
Action authorities would free CERCLA's oversight
resources for use in situations where another
authority is not available, as well as avoid possible
duplication of effort and the need for an owner /
operator to follow more than one set of regulatory
procedures."
Based on the citations above, if a site is deleted from
the NPL by means of deferral to RCRA prior to
completion of construction, it does not qualify as a
construction completion. Deferral of remediation to
another authority generally means that "physical
construction" originally identified using the
CERCLA process will occur after site deletion.
Since one of the goals in deleting a site from the NPL
after deferral to another authority is to save CERCLA
oversight costs, Regions should not routinely track
these deleted sites. Consequently, sites deleted
from the NPL due to deferral of physical
construction to another authority do not met the
requirements for construction completion.
3.6.5 Multiple Authorities Conducting
Cleanup at the Same Site
Often, cleanup work under different authorities may
be planned or under construction simultaneously.
Operating facilities may have RCRA corrective
action ongoing at one part of the site, while NPL
work is occurring elsewhere. Similar situations may
occur under other authorities. In situations where the
physical construction identified under CERCLA
authority for the NPL site is complete, but other non-
CERCLA work remains, the site can qualify for
construction completion if documentation
requirements are met. An example is CERCLA
physical construction compieted at a nuclear
production facility to address off-site ground water
contamination with remaining work to be completed
as a facility closure several years later under Nuclear
Regulator)' Commission authority. Any physical
construction that has been identified through the
CERCLA process must be finished before the site
can be declared construction complete.
3.7 Additional Work at Construction
Completion Sites
FR Volume 58, No. 29, March 2, 1993. "Notification
of Policy Change; Categorization of Superfund
Sites," addresses the issue of Routine Adjustments at
construction completion sites. The notice indicates:
"Also, routine adjustments and modifications to a
constructed remedy can be expected, but do not
affect a site's status on the CCL. Examples of
adjustments or modifications include the drilling of
additional extraction wells, modifications to unit
processes at ground water treatment plants, and
dismantling and removing on-site remediation
facilities."
Other examples of routine adjustments include:
- maintaining a landfill cap (including
landscaping, erosion control)
- Making service / repair / adjustments to SVE,
bioremediation, ground water, or landfill gas
collection treatment plants
- Clearing drainage system and settling ponds of
debris (including repairs / replacement)
- Modifying the sampling and analysis scheme as
part of monitoring a remedy (i.e. ground water
monitoring, gas collection, stream discharge,
leachate collection). These modifications may
also entail physical equipment replacement,
repairs, equipment location changes.
Unforseen circumstances may require additional
work (e.g., implementing a new remedy, adding a
new treatment train to an existing remedy, removing
newly identified pockets of contamination,
compromised remedies through acts of nature
(floods, hurricanes, etc.) after the site has been
declared a construction complete. The significance
of the work performed would likely trigger a new (or
amended) Action Memo, ROD, or ESD.
The Agency may change the construction completion
categorization of sites where there is a significant
change in site conditions that requires extensive
additional construction activity, in such cases the
site may be removed from the Construction
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Completion List. Upon completion of the
construction activity and compliance with the
construction completion criteria the site will be
restored to the list.
Should significant additional work be required at a
site, the Region must notify the nearby community of
the problem along with a strategy for rectifying the
situation. This notice can be done through a fact
sheet, news bulletin, or public notice. If a change in
the remedy is warranted, then the public participation
requirements outlined in the NCP would apply.
At construction completion sites in which
unanticipated additional work is identified, the
Region should notify EPA HQs (Construction
Completion Coordinator) as soon as the problem is
identified. Within 30 days of the notification, a fact
sheet, no longer than two pages, should be sent to
HQs with a detailed description of the additional
work required at the site and the action planned or
underway to address it. This fact sheet will serve as
documentation of the additional work in the Regional
and HQs files, and EPA HQs will decide, in
consultation with the Region, if the site should
remain on the Construction Completion List or be
removed from the list.
3.8 Construction Completion Checklist
Construction completion activities vary according to
site circumstances. For typical sites, however,
achieving construction completion requires the RPM
to:
S Assess site against construction completion
criteria
S Conduct and document pre-fmal inspection for
final operable unit
- Complete pre-final inspection report
- Document "punch-list" items
S Prepare Preliminary Close Out Report
- Submit draft to EPA HQs for review
- Address HQs comments and finalize PCOR
- Submit PCOR to appropriate Regional
official for signature
- Mail or fax hardcopy of signed PCOR to
HQs
- Upon completion of a PCOR or FCOR
notify the appropriate Trustees listed in the
Regional Contingency Plans.
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4.0 SITE COMPLETION
Site completion signifies the end of all response
actions at National Priorities List (NPL) sites. Site
completion means that the response actions at the
site were successful and no further Superfund
response is required to protect human health and the
environment.
The Remedial Project Manager (RPM) applies the
Environmental Protection Agency's (EPA) site
completion criteria to a site to verify that it is eligible
for site completion status. Site completion is
documented by a Final Close Out Report (FCOR).
This chapter explains the documentation required to
demonstrate that site completion criteria have been
met and site completion has been achieved. The site
completion process is illustrated in Exhibit 4-1.
4.1 Site Completion Criteria
A site must meet all the criteria below to be eligible
for site completion:
Cleanup goals specified in all Records of
Decision (ROD) or removals are met;
Institutional Controls are in place;
All Remedial Action (RA) Reports, On-Scene
Coordinator (OSC) Reports, and Pollution
Reports (POLREP) have been completed;
All RODs, ROD Amendments, and Explanation
of Significant Differences (ESD) have been
completed;
The site is protective of human health and the
environment; and
The only remaining activities, if any, at the site
are operation and maintenance activities that are
performed by the State, Federal Facility or
responsible parties.
4.2 Site Completion Process
Only an FCOR satisfies the site completion
requirements. The following section presents NPL
site completion requirements for cleanup activities
under removal and remedial authority.
4.2.1 Removal Authority
Action under removal authority achieves prompt risk
reduction through emergency, time-critical, and
non-time critical actions. In general, cleanup actions
under removal authority will not have a ROD as is
normally the case for sites addressed under remedial
authority. NPL sites addressed entirely under
removal authority reach the construction completion
and site completion milestones simultaneously when:
« The RPM or OSC, documents in the final
POLREP that the contractor is demobilized and
has left the site, or (in the case of a potentially
responsible party (PRP)-lead site), that the PRP's
contractor has completed the removal action
specified in the Action Memorandum and fully
met the terms of the applicable enforcement
document.
In some instances, the removal action may have been
documented with an On-Scene Coordinator Report.
For information regarding POLREP and OSC
Reports refer to Directive 9360.3-03, Superfund
Removal Procedures. Removal Response Reporting:
POLREP and OSC Reports." June 1994.
4-1
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EXHIBIT 4-1, Site Completion Process
Does Final
yes ^*~ Operable Unit Require ^\ No
Construction?
Sit* Completion
Criteria Met?
Obtain EPA HQs and
State Comments;
Obtain Region and State
Peer Comments.
Obtain Regional
Administrator Signature
and Send Copy of Signed
FCOR to EPA HQs.
Complete
Remedial/Removal
Actions at Site.
4-2
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4.2.2 Remedial Authority
4.3 Final Close Out Report
This section presents the site completion
requirements for:
Sites requiring remedial construction in the final
Operable Unit (OU).
Sites requiring no remedial construction in the
final OU.
Sites where no response action was required.
For the three situations identified above site
completion is documented through a FCOR.
Sites Requiring Remedial Construction in
the Final OU
The site is eligible for site completion when all
remedial actions have been implemented and all site
completion criteria are met. This means that all
issues regarding site completion have been
addressed (e.g., O&M assurances, cleanup
concentrations, and implementation of institutional
controls). Site completion is documented through a
FCOR.
Sites Requiring No Remedial Construction
in the Final OU
This category includes sites where the ROD for the
final OU requires no remedial construction activities.
Sites with RODs requiring institutional controls,
monitored natural attenuation, or monitoring for
other than O&M purposes meet site completion
requirements once the institutional controls are in
place, monitored natural attenuation has reached the
cleanup goals, and all monitoring requirements
specified in the ROD are met. The site will then be
eligible for site completion and site deletion. Site
completion is documented through a FCOR.
Sites where No Response Action Was
Required
For no action sites the RPM prepares a FCOR (in an
abbreviated form because there were no cleanup
activities). The FCOR documentation needs to
address the justification for no action at the site.
The FCOR documents compliance with statuton.
requirements and provides a consolidated record of
all removal and remedial activities for the entire site.
Since it is the final record, the FCOR must be
complete and be able to stand alone. The report does
not signify that the terms of cooperative agreements.
consent decrees, or administrative orders have been
satisfied, nor does it signify resolution of contractual
or other administrative issues for Superfund
activities.
The FCOR describes how the cleanup was
accomplished and provides the overall technical
justification for site completion. Although the
content and format of the report may vary depending
on site circumstances, it should include the
information presented in Exhibit 4-2. This
information should be readily available from
previous documents such as the RI 'FS, the RODs. the
RDs. and the RA reports. The FCOR should also
identify issues that might be of continuing concern to
EPA or the community and explain why these issues
do not preclude the site from achieving site
completion.
The FCOR should contain a status report by OU of
cost expenditures to date and projected costs into the
future (O&M costs). This information is required for
Fund-lead projects and should be provided whenever
possible for PRP-lead projects. If the project is
performed by a PRP, a summary of EPA oversight
costs for design and construction should be provided
as well.
Usually the RPM prepares the FCOR. but may task
the State to prepare it at State-lead sites. The report
should normally be 10 to 15 pages, but may be
longer for large sites with multiple OUs. To keep the
report brief, detailed technical or cost information
and data may be referenced or appended to the
report. As Exhibit 4-1 shows, EPA Headquarters
(HQs) and the State should have an opportunity to
review and comment on the report prior to final
signature.
EPA HQs has Regional Coordinators assigned to act
as primary reviewers of the FCOR. These
individuals will work closely with the RPM in
performing completion activities and will review the
4-3
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draft FCOR. After addressing the HQs and State
comments and obtaining the signature of the
Regional Administrator, a copv of the signed report
is forwarded to EPA HQs. Appendix C presents a
sample FCOR.
!
Upon completion of an FCOR the appropriate
Trustees listed in the Regional Contingent P!ar^
will be notified of the completion of the remedial
action. The Region should provide a cop> of the
report to the Trustees within one week of the
completion of the report.
EXHIBIT 4-2, Final Close Out Report Summary
SECTION
CONTENTS
Introduction
General statement indicating that all response actions at the site have
been successfully performed.
II. Summary Of Site
Conditions
Site background.
Removal actions performed.
Remedial investigation .' feasibility study results.
ROD findings.
Design criteria.
Cleanup activities performed.
Community involvement activities performed.
Describe redevelopment potential at the site, or any planned or ongoing
redevelopment work.
III. Demonstration Of Cleanup
Activity QA.'QC
QA/QC protocol followed.
Sampling and analysis protocol followed.
Results of on-site inspections.
IV. Monitoring Results
Sufficient data to demonstrate cleanup levels specified in the ROD or
Action Memoranda are achieved and implemented and remedies are
performing to design specifications.
Monitoring required at no action sites after the ROD is signed should be
brieflv documented in the FCOR.
V. Summary Of Operation And
Maintenance
Description of required O&M activities.
Assurance that O&M plans are in place and are sufficient to maintain
the protectiveness of the remedy.
Assurance that all necessary institutional controls are in place.
Assurance that O&M activities specified for the site will be performed
by the State or the responsible party.
VI. Summary of Remediation
Costs
ROD estimate of capital costs and annual O&M costs.
Construction contract award amount.
Total remedial action construction cost '(i.e.. capital costs) at time of
FCOR.
Current estimated annual O&M costs.
VII. Protectiveness
Assurance that the implemented remedy (or no action decision)
achieves the degree of cleanup or protection specified in the ROD(s) for
all pathways of exposure and that no further Superfund response is
needed to protect human health and the environment.
Assurance that all areas of concern described in the NPL listing have
been adequately addressed.
4-4
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VIII.
IX.
Five- Year Review
Bibliography
Statement explaining whether a five-year review is appropriate, and
so. the type of review (statutory or policy] and the schedule for the
review.
Summary of Five-Year reviews alreadv completed.
if
Complete citations of all relevant reports.
4.4 Site Completion Checklist
Site completion activities vary according to site
circumstances. For typical sites, however, achieving
site completion requires the RPM to:
/ Verify site completion criteria
- Cleanup activities are successfully
implemented and cleanup goals/levels are met
- Remedy is operational and functional
- Institutional controls are in place
- All removal and remedial activities are
complete
- Site is protective of human health and the
environment
- Assemble all site related reports (PCOR,
RAs. OSC Reports. PolReps. etc.)
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5.0 SITE DELETION
The National Priorities List (NPL) deletion process
begins at most sites once the site completion
milestone has been achieved. Site deletion
requirements ensure that 1) the documentation of
activities and decision making at the site is complete.
2) the activities conducted and documented are
verified, and 3) the public has an opportunity for
notice and comment before a site is formally deleted
from the NPL.
The deletion process is dictated by the National Oil
and Hazardous Substances Pollution Contingency
Plan (NCP).
Deletion of a site from the NPL does not preclude
eligibility for subsequent Fund-financed or
responsible party actions. If future conditions
warrant, the NCP (40 CFR 300.425(e)(3)) provides
that Fund-financed remedial actions may be taken at
sites deleted from the NPL. When there is a
significant release from a site deleted from the NPL.
the site may be restored to the NPL without rescoring
the site. Additional enforcement actions also may be
taken, depending on liability releases in the consent
decree or administrative order. Deletion of a site
does not affect cost recovery efforts under the
Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (CERCLA)
section 107.
This chapter focuses on the site deletion criteria.
process, and documentation required to achieve this
milestone. Site deletion criteria presented in this
section also applies to partial deletions (see Chapter
6.0. Partial Deletion).
5.1 NPL Deletion Criteria
The NCP (40 CFR 300.425(e)) states that a site may
be deleted from, or recategorized on. the NPL when
no response ' no further response is appropriate. The
Environmental Protection Agency ( EPA) must
consult with the State in making this determination.
To delete a site from the NPL. EPA must determine.
in consultation with the State, that one of the
following criteria has been met:
Responsible or other parties have implemented
all appropriate response actions required:
All appropriate Fund-financed response under
CERCLA has been implemented, and no further
response action b\ responsible parties is
appropriate: or
The remedial investigation has shown that the
release poses no significant threat to public
health or the environment, and. therefore, taking
of remedial measures is not appropriate.
If monitoring to determine the need for a future
response action is ongoing at a site, deletion is
premature. In this situation, it is impossible to know
. whether a site satisfies the NCP's deletion standard -
"no further response is appropriate." At sites with
ground and surface water restoration remedies
cleanup goals must be attained before the site
qualifies for deletion (see Chapter 4. Section 4.1. Site
Completion Criteria).
Section 300.5. defines response as removal, remedy,
or remedial action. EPA interprets that to mean that
the site may be deleted when all removals and
remedial actions are completed. Operation and
Maintenance (O&M) is not defined as a response by
the NCP. therefore, a site in O&M can be deleted.
The NCP (40 CFR 300.435 (f) states that:
(f) Operation and maintenance. (1) Operation and
maintenance (O&M) measures are initiated after
the remedy has achieved the remedial action
objectives and remediation goals in the ROD. and
is determined to be operational and functional,
except for ground- or surface-water restoration
actions covered under § 300.435(0(4). A state
must provide its assurance to assume
responsibility for O&M. including, where
appropriate, requirements for maintaining
institutional controls, under § 300.510(c).
Site deletion from the NPL has been separated from
the Five-Year Review Program (56 FR 66601.
December 24. 1991). This means that a site can be
deleted from the NPL without having the first Five-
year review completed. EPA has separate guidance
addressing Five-Year Review requirements.
All deletion related actions will be coordinated with
the appropriate Trustees listed in the Regional
5-1
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Conungenc> Plans. Lpon publication in the Federal
Register (FR) of an> Notice of Intent to Delete
(NO1D) or Final Notice of Deletion (NOD), the
Region will send a cop> of the notice to the Trustees
within one week of publication.
5.2 NPL Deletion Through Resource
Conservation and Recovery Act
Deferral (RCRA)
EPA's "Deletion Policy for Resource RCRA
Facilities" (FR Notice 40 CFR Part 300 dated March
20, 1995). later amended to make policy also
applicable to Federal Facility sites (FR Notice 40
CFR Part 300 dated November 24, 1997) states that:
'EPA believes it is appropriate to delete sites from
the NPL based upon deferral to RCRA under
certain circumstances. Deletion of sites from the
NPL to defer them to RCRA Subtitle C corrective
action authorities would free CERCLA's oversight
resources for use in situations where another
authority is not available, as well as avoid possible
duplication of effort and the need for an owner /
operator to follow more than one set of regulatory
procedures."
A site can de deleted from the NPL through a RCRA
deferral action if it complies with the following
criteria:
The CERCLA site is currently being addressed
by RCRA corrective action authorities under an
existing enforceable order or permit containing
corrective action provisions.
Response under RCRA is progressing
adequately.
Deletion would not disrupt an ongoing CERCLA
response action.
5.3 The Deletion Process
Usually the deletion process begins once the site
achieves the site completion milestone. In general.
the Region initiates the deletion process. A State or
an individual may also initiate the process by
specifically requesting the deletion of a site. Exhibit
5-1 shows the main steps in the typical deletion
process.
EXHIBIT 5-1, Site Deletion Process
Complete Finil
COR for Site.
| Prepare Draft Notice of
| Intent to Delete (NOID):
i Obtain EPA HQs and "
I State Comments.
Provide 30-Day Public Comment I
Period: If Comments are
Received Prepare Draft
Responsiveness Summary and
Obtain EPA HQs Comments.
I
_*_
Place Final Responsiveness I
Summary in Regional
Docket and Local
, Repository. \
I
1 Prepare Notice of
Deletion: Publish in
' Federal Register.
5-2
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The deletion process is divided in three steps:
process initiation, publication of the NOID. and
preparation of a responsiveness summary (and
publication of NOD).
5.3.1 Process Initiation
The Region initiates the deletion process by:
Obtaining a letter of concurrence from the State.
Compiling the deletion docket, and
Preparing a Notice of Intent to Delete
5.3.2 State Concurrence
Early in the deletion process the Region consults with
the State and requests their concurrence on EPA's
intent to delete the site. A site can not be deleted
from the NPL without the State concurrence. If the
State agrees with the deletion they will provide a
concurrence letter.
5.3.3 Deletion Docket
The Region prepares a deletion docket containing all
pertinent information supporting the deletion
recommendation. The deletion docket is not a
continuation of the Administrative Record for the
site. Documents in the Administrative Record can be
referenced and do not have to be duplicated in the
deletion docket (provided the Administrative Record
is still available to the public). The deletion docket
should be available to the public at the EPA Regional
office public docket and at a local repository. The
documents contained in the deletion docket will vary
depending on the type of response (e.g., remedial
action, removal action, no action) and the lead
agency (e.g.. Federal. State, or responsible party).
These documents can be included in the deletion
docket as applicable:
Remedial Investigation / Feasibility Study
Report
Record(s) of Decision (ROD) or equivalent for
each operable unit, including any ROD
amendments or Explanations of Significant
Differences
Consent Decree(s)
Action Memoranda
Community Relations Plans
Superfund State Contract
Cooperative agreements
Agreements with potentially responsible parties
Design plans and specifications
Construction inspection reports
On-Scene Coordinator or Pollution Reports
Documentation of State concurrence letter on
deletion
Operation and Maintenance Plan
Final Close Out Report
Transcripts from public meetings
Bibliography of Administrative Record
Regional program offices should work with their
Superfund community involvement staff to ensure
that complete copies of the deletion docket are placed
in the appropriate Regional and local repositories.
The public will have an opportunity to review this
docket during the 30-day public comment period that
follows publication of the Notice of Intent to Delete
(NOID). Public meetings are optional.
5.3.4 Notice of Intent to Delete
The NOID informs the public of EPA's intention to
delete a site from the NPL. The deletion docket must
be complete before the Region publishes the NOID in
the FR. The NOID contains general information
about the site, EPA Regional staff and other contacts.
and deletion criteria and procedures. It provides for a
30-day public comment period. Site-specific
information needed to prepare the NOID should be
available from the Final Close Out Report (FCOR):
the NOID should contain the sections illustrated in
Exhibit 5-2. Appendix D presents an example of a
NOID. The draft NOID is sent to EPA Headquarters
(HQs) for review and comments. After addressing
HQs comments and obtaining the signature of the
Regional Administrator, the NOID is published in the
FR.
5-3
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EXHIBIT 5-2, Notice oflntent to Delete Summary
SECTION
I, Summary
11. Dates
111. Addresses
IV. Further Information Contact
V. Supplementary Information
VI. Information
VII. NPL Deletion Criteria
VIII. Deletion Procedures
IX. Basis For Intended Site
Deletion
CONTENTS
Announcement of intent to delete.
Dates for 30-day public comment period and submission of
comments.
Name, address, and phone number of a Regional contact where
comments mav be sent and location'of the Regional Docket and
local repository.
Name, address, and phone number of a Regional contact for further
information or questions.
Table of Contents
Identification of site to be deleted, and summary of information in
FCOR.
List of applicable NCP criteria (40 CFR 300.425(e)) and a statement
indicating that EPA retains the ability to use Superfund authority at
a deleted site if future conditions warrant such actions (40 CFR
300.425(e)(3)).
Brief description of procedures followed to delete sites from the
NPL.
Brief description of the following items:
- Site history (location, former use. type of contaminants, FR
citation of proposed and final NPL listing, and site conditions
resulting in listing).
- All response actions taken including scope of Remedial
Investigation, if applicable, general results, and conclusions
regarding future performance of these actions.
- Specific cleanup goals and criteria and results of all confirmatory
sampling and analysis.
- O&M procedures and site monitoring program.
- Reasons for the need for future five-year reviews, when
appropriate, and plans for performance of such reviews.
- Major community involvement activities.
- How site meets deletion criteria.
- State concurrence to delete the site.
5.3.5 Publication of the Notice oflntent to
Delete and the Local Notice
The Region prepares and publishes the NOID in strict
accordance with the Federal Register publication
requirements. EPA HQs staff will review these
notices to ensure national consistency and
completeness.
The Regional Superfund Community Involvement
Coordinator (CIC) should also prepare and distribute
a local notice regarding the NOID. This notice
should be published in a local newspaper of general
circulation. It should announce the Agency's intent
to delete the site from the NPL and the 30-dav public
comment period. The local notice should also
provide an address and telephone number for
submission of comments, and identifv the location of
5-4
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the local repository. Appendix H presents a sample
local notice.
The CIC coordinator should also prepare a press
release and distribute it to the communirv. State, and
local officials: all PRPs: appropriate Federal agencies
(including the Agency for Toxic Substances and
Disease Registry, the National Response Team, and
the appropriate Trustees listed in the Regional
Contingency Plans): Superfund enforcement
personnel; the Office of Regional Counsel (ORC);
and any local repositories. In addition, the ORC
should inform the State Attorney General and other
interested agencies (State or Federal courts and the
U.S. Department of Justice) of the intended deletion
of the site.
5.3.6 Responsiveness Summary and Notice
of Deletion
The Region is responsible for preparing a
responsiveness summary for all local and national
comments received. The responsiveness summary
should present all comments received during the
public comment period paired with detailed
responses to the comments. A draft of the
responsiveness summary is sent to EPA Headquarters
for review and comment. The Region must include a
copy of the responsiveness summary, approved by
the Regional Administrator, in the Regional docket
and local repository.
The Notice of Deletion (NOD), which includes an
effective date (the date of publication), the name of a
Regional contact, supplemental site information and
the responsiveness summary, is signed by the
Regional Administrator and published in the Federal
Register. The NOD states that all appropriate
Fund-financed responses under CERCLA have been
implemented and that no further response is
appropriate. Appendix I presents a sample Notice of
Deletion.
5.4 Streamlining the Deletion Process
A streamlined process to delete sites from the NPL
has been proposed by a Region. The process has
been reviewed by the Office of Regional Counsel and
other EPA HQs staff and there is agreement that at
selected sites the process may be used to streamline
the deletion process.
To obtain more information the Regions must consult
with the appropriate Regional Center in HQ before
using the streamlined approach. This approach
streamlines the deletion process b> combining the
NOID and NOD thereby reducing the amount of
internal time needed to finalize the deletion. Under
this process, sites would be deleted from the NPL
using a direct final notice procedure. In a direct final
deletion action EPA would publish both a NOID and
NOD in the FR and declare that the NOD will
become effective unless EPA receives adverse or
critical comments during the 30-day public comment
period. If no adverse or critical comments are
received, the deletion would become effective
without any further EPA action. This approach
would only be appropriate at sites where no
comments are expected.
5.5 Site Deletion Checklist
For a site to achieve deletion, the RPM must:
S Apply NCP criteria to verify deletion eligibility
^Obtain State concurrence for site deletion
/ Compile deletion docket
- Distribute deletion docket to appropriate
repositories
/ Complete NOID procedures
- Prepare draft
- Submit to EPA HQs and State for review
and comment
- Address HQ and State comments
- Publish in Federal Register
- Provide a 30-day comment period
- Upon publication of the NOID notify the
appropriate Trustees listed in the Regional
Contingency Plans
/ Complete Responsiveness Summary
- Prepare Responsiveness Summary
- Submit to EPA HQs for review and
comment
- Obtain Regional Administrator Approval
- Submit to Regional Docket and Local
Repository
/ Draft NOD
S Publish NOD in Federal Register
S Upon publication of the NOD notify the
appropriate Trustees listed in the Regional
Continaencv Plans
J-0
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6.0 PARTIAL DELETION
The Partial Deletions Rule, which allows the
Environmental Protection Agency (EPA) to delete
portions of National Priorities List (NPL) sites.
provided that deletion criteria are met. was published
in the Federal Register (FR) on November 1. 1995.
Previously. EPA's policy had been to delete only
after cleanup of the entire site. However, deletion of
entire sites does not communicate the successful
cleanup of portions of those sites. Total site cleanup
may take many years, while portions of the site may
have been cleaned up and may be available for
productive use. Such a portion may be a defined
geographic unit of the site, perhaps as small as a
residential unit, or may be a specific medium at the
site, e.g., ground water, depending on the nature or
extent of the release(s).
Any person, including individuals, business entities.
States, local governments, and other Federal agencies
may submit a petition requesting a partial deletion. A
petition may consist of a simple written request from
any interested party. The Office of Emergency and
Remedial Response (OERR) Directive 9320.2-11,
Procedures for Partial Deletions at NPL Sites, dated
April 30, 1996, OERR Directive 9320.2-11, EPA
540/R-96/014, PB 96-963222. provides information
about partial deletions. See Appendices H and I for
examples of Notice of Intent of Partial Deletion
(NOIPD) and Notice of Partial Deletion (NOPD).
The partial deletion process is dictated by the
National Oil and Hazardous Substances Pollution
Contingency Plan (NCP). Deletion of a portion of a
site from the NPL. however, does not preclude
eligibility for subsequent Fund-financed or
potentially responsible party actions. If future
conditions warrant, the NCP (40 CFR 300.425(e)(3))
provides that Fund-financed remedial actions may be
taken at portions of sites deleted from the NPL.
When there is a significant release from a portion of a
site deleted from the NPL, the portion of the site may
be restored to the NPL. without rescoring the site
under the Hazard Ranking System (HRS).
Additional enforcement actions also mav be taken.
depending on liability releases in the consent decree
or administrative order. Deletion of a portion of a
site does not affect cost recovery efforts under
CERCLA section 107.
All partial deletion related actions will be
coordinated with the appropriate Trustees listed in
the Regional Contingency Plans. Upon publication
in the Federal Register of any NOIPD or the NOPD.
the Region will send a copy of the notice to the
Trustees within one week of publication.
6.1 Partial Deletion Process
The NPL partial deletion process begins at most sites
once a portion of the site has been cleaned up and site
deletion criteria are met for that portion of the site.
Requirements for the partial deletion area are the
same as for the full deletion (see Section 5.3). Two
differences are the mapping requirements for the
partially deleted area and the documentation that
supports the decision to partially delete. These will
be discussed fully in Section 6.2. Partial deletion
requirements ensure that 1) the documentation of
activities and decision making at the portion of the
site is complete. 2) the activities conducted and
documented are verified. 3) the area of the site to be
deleted is clearly and accurately defined ' delineated.
and 4) the public has an opportunity for notice and
comment before the portion is formally deleted from
the NPL.
In general, the Region initiates the partial deletion
process. A State or an individual may also initiate
the process by specifically requesting the partial
deletion of a site. Exhibit 6-1 shows the main steps
in the typical partial deletion process.
The partial deletion process is divided in five steps:
process initiation, preparation of mapping data.
publication of the NOIPD. and preparation of a
responsiveness summary and publication of NOPD.
6-1
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EXHIBIT 6-1, Partial Deletion Process
6.2 Special Partial Deletion Requirements
Complete
Documentation to
Support Partial
Deletion Decision,
Prepare Draft Notice of
Intent to Partially Delate
(NOIPO);
and State Comments.
; Obtain EPA HQj * S
Prepare Mapping i
Information and
Provide to EPA HQsJ
Provide 30*Day Public
Comment Pehod; If Comments
are Received Prepare Draft
Responsiveness Summary and
Obtain EPA HQs Comments.
Place Final Responsiveness
Summary in Regional
Docket and Local
Repository.
Prepare Notice of
Partial Deletion:
Publish in Federal
Register.
In order to accurately portray the portion of the site
to be deleted, information about the area of the parcel
or parcels to be deleted must be consistent and
accurate. For this reason, it is important for HQs to
obtain relevant locational information from the
Regions for each partial deletion. This information
will be centrally housed in the Superfund N'PL
Assessment Program (SNAP) database. The SNAP
database tracks site information collected for the
MRS packages at the time of listing. This
information will also be maintained in other HQ
Geographical Information Systems (GIS).
The Partial NPL Site Deletion Data Collection Form
(see Appendix G) is designed to standardize partial
site deletion information for input into SNAP and
other HQ GIS systems. The primary source materials
for completing this form are the NOIPD, site
information supporting the decision to delete the
portion of the site, and electronic locational data.
Requirements for submitting electronic locational
data are included in EPA's Locational Data Policy.
Partial deletion dictates strict mapping and tracking
requirements. These mapping requirements will be
applied to outline and precisely delineate the portion
of the site to be deleted. This will foster a clearer
public understanding of exactly what properties may
or not be included in the NPL site. Precise mapping
will accomplish this goal efficiently.
The mapping information will provide a national
compilation of the total area that has been subject to
the partial deletion policy and improve information
on site locations. Approval for publication of the
NOIPD will be given once the accuracy of the
locational information is verified.
6.2. 1 Mapping Requirements
The mapping requirements of a partial deletion
package includes the following items:
A map. in electronic GIS format, clearly
showing the entire site and that portion to be
deleted (including scale):
Site coordinates (latitude and longitude) that
delineate the boundary of parcel or parcels to be
deleted.
6-2
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Landmarks, such as roads, water bodies, waste
operations, or residential areas (these facilitate
reading the map).
Contacts for both the partial deletion decision
and the electronic data.
The site map must be dated. The date is to reflect the
delineation of the boundaries of the site as of the date
prepared, including the portion to be deleted.
Geographic coordinates of points describing a
specific object (e.g.. operable unit or portion of the
site to be deleted) should be included. For additional
information about mapping requirements see
Appendix G.
Regions should also contact their Regional GIS
coordinator to obtain assistance in developing and
preparing the required mapping information. The
following is a list of the Regional GIS Coordinators:
Region 1: Deborah Cohen, 617-565-3659
Region 2: Harvey Simon, 212-637-3594
Ildefonso Acosta. 212-637-4344
Region 3: Don Evans. 215-814-5370
Region 4: Rebecca Kemp, 404-562-8027
Region 5: Noel Kohl, 312-886-6224
Region 6: David Parrish. 214-665-8352
Region 7: Vickie Damm, 913-551-7247
RegionS: Karl Hermann, 303-312-6628
Region 9: Cheryl Henley, 415-744-1754
Region 10: Man Gubitosa. 206-553-4059
The list of Regional GIS Coordinators can also be
found on the intRAnet at:
http://intranet.epa.gov/oerrinet/regional/regionsl-
5.htm
6.2.2 Documentation to Support the Partial
Deletion Decision
In a full deletion a Final Close Out Report (FCOR) is
prepared to document site completion (see section
4.1 and 4.3). In the case of a partial deletion an
FCOR will not yet exist. Therefore, another
document will have to serve the same purpose as an
FCOR for the portion(s) of the site that are being
considered for deletion. These documents may be:
Remedial Action Reports. No Action RODs. ESDs or
ROD Amendments. Final Pollution Reports, or a
memo to the file. Depending on the site
circumstances an\ one of these documents can be
used to document an> of the following: that all work
has been completed at a portion^) ot the site.
including achieving cleanup goals: no further action
is needed: or the RI. FS has determined that the
portion(s) of the site is not contaminated and
therefore warrants no response action. This
document will be the basis for partially deleting a
ponion(s) of the site and will be pan of the partial
deletion docket.
6.3 Partial Deletion Checklist
For a site to achieve partial deletion, the RPM must:
/ Provide documentation that supports the basis
for deletion (section 6.2.2)
/Apply NCP criteria to verify deletion eligibility
/ Obtain State concurrence for partial site deletion
/ Compile partial deletion docket
- Distribute partial deletion docket to
appropriate repositories
/ Complete mapping requirements
- Submit to EPA HQ for review and comment
/ Complete NOIPD procedures
- Prepare draft NOIPD
- Submit to EPA HQs for review and comment
- Publish in Federal Register
- Provide a 30-day comment period
- Upon publication of the NOIPD notify the
appropriate Trustees listed in the Regional
Contingency Plans
/ Complete Responsiveness Summary
- Prepare Responsiveness Summary
- Submit to EPA HQs for review and comment
- Obtain Regional Administrator Approval
- Submit to Regional Docket and Local
Repository
/ Draft Notice of NOPD
/Publish NOPD in Federal Register
/Upon publication of the NOPD notify the
appropriate Trustees listed in the Regional
Continaencv Plans
6-3
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6.4 \VTien Can You Partiallv Delete
6.5 Sites with Partial Deletions
To help clarif> \\hen a site can have a partial
deletion, three different sites are given as examples.
These examples range from simple to more complex
situations.
Example I: At the Geneva Industries site in
Houston. Texas, the source removal and soil removal
actions were complete. The ground water pump and
treat portion of the site would continue for a longer
period of time. Institutional controls were put in
place to prevent disturbance of a RCRA cap. slurry
wall and ground water distribution lines. The surface
of this site was partially deleted to allow site reuse.
Example 2: Another partially deleted site was the
Lakewood Site in Lakewood. WA. In this case the
clean up goals had been achieved for the soil OU.
Therefore, the soil OU was partially deleted. This
allowed reuse of this portion of the site. The ground
water OU will remain on the NPL until clean up
goals are achieved.
Example 3: A more complicated site was the
Celanese Corporation Shelby Fiber Operations
located at Shelby, NC. Three portions of the site
were partially deleted. These consisted of the OU 1
outer tier groundwater extraction wells location area,
OU 2 soil remediation area, and a nearby stream
segment. In OU 1 groundwater samples showed that
remediation levels had been achieved. The data also
indicated that the inner tier wells were containing the
remaining ground water contamination. At OU2 the
soil remediation had been completed. The stream
remediation area was examined and it was
determined that it did not need any further
remediation. Therefore, all three of these areas
qualified for partial deletion.
For a site to be partially deleted all deletion criteria
for the area that is being considered for deletion must
be met.
The following is a list of sites that had a portion! s) of
the site successful!;, partially deleted from the NPL
through FY99. To obtain additional information
about these sites please refer to the Federal Register
Reference Number provided.
1) Bypass 601 Groundwater Contamination.
Concord. NC. Region 4; 63FR 51530.
0928,1998
2) Celanese Corporation Shelby Fiber
Operations. Shelby NC. Region 4: 63FR
19/93. 04 17 1998
3) Com Bay. Near Shore Tide Flats. Tacoma.
WA, Region \0;6IFR'55~5l. 10 29 1996
4) General Electric, Shepherd Farm. East Flat
Rock. NC. Region 4; 61FR 564^', 11'Ol 1996
5) Geneva Industries. Houston. TX. Region 6:
62FR 16-06. 04/08/1997
6) .Harbor Island. Seattle. WA. Region 10: 61FR
5759-t. 07/08/1998
7) Hanford 100-Area (USDOE). WA. Region 10;
63FR 36861. 07/08/1998
8) American Cyanamid. Boundbrook, NJ. Region
2-.63FR71597, 12/29/1998
9) Lakewood Site. Lakewood, WA. Region 10:
61 FR 60/9". H'27/1996
10) Para-Chem Southern. Inc.. Greenville County.
SC. Region 4: 62FR 65225, 12/11 '1997
11) Prewitt Abandoned Refinery. Prewitt. NM.
Region 6: 63FR 439~, 01 29/1998
12) Saegertown Industrial Area Site, Saegertown,
PA.~Region 3: 62FR 52032, 10/06/1997
13) Sangamo Weston/Twelve mile Creek/Lake
Hartwell. Pickens County, SC, Region 4;
63FR51529. 09 '28/1998
14) South Andover Salvage Yards. Andover MN.
Region 5: 63FR 5~60~8. 10/28/1998
15) Treasure Island Naval Station - Hunters Point
Annex. San Francisco. CA. Region 9: 64FR
16351. 04/05/98'
16) Koppers Company, Inc., Morrisville, NC.
Reaion 4: 62FR 46211. 09/02/1997
6-4
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Appendix A - REMEDIAL ACTION REPORTS
A-l
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Appendix A - Sample Remedial Action Report
Remedial Action Report
Record of Preparation. Review, and Approval
U Creosote Superfund Site
Operable Unit 2
Land Treatment of Contaminated Soils
This report has been prepared in accordance with EPA OSWER Directive 9320.2-09A and will be used, alona with
the Remedial Action Report for OU 1. as the basis for.development of the site Final Close Out Report.
RA Report
Prepared
By:
PRP Agent:
Signature
Same-'Title/Companv
Date
Approved
By:
EPA Region 4
Approving Official:
Signature
Name/Title
Date
A-3
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Appendix A - Sample Remedial Action Report
'i/7 Sumptc Remedial Action Report is based on an actual Superfund sue. but some information has been altered
lur illustrative purposes
Content and fnrmat nf actual Remedial Action Reports prepared may vary from this sample due to considerations
such as protect laid and support roles, availability of information, and site-specific conditions.
For more about preparing a Remedial Action Report, refer to OStt'ER Directive 9320 2-9A-P. "Close Out
Procedures for National Priorities List Sites. " EPA 540-R-98-OI6.
A-4
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Appendix A - Sample Remedial Action Report
REMEDIAL ACTION REPORT
U CREOSOTE SUPERFU.ND SITE, LIVE OAK, FLORIDA
EPA CERCLIS ID NUMBER FLXXXXXXXXXX
LAND TREATMENT OF CONTAMINATED SOILS (OU 2)
I. INTRODUCTION
The U Creosote Superfund Site is located approximately two miles from the City of Live Oak. Suwanee County.
Florida, at the intersection of Sawmill Road and Goldkist Road. Homes, businesses, light industry, a trailer park, a
private airport, and a county storage yard are located within one-half mile of the site. Approximately 450 people
live in the trailer park. Sinkholes and public and private wells lie within two miles of the site.
From 1948 to 1986. the ABC company operated the U Creosote site as a lumber treatment facility. Lumber
treatment processes included the pressure-treatment of lumber products, mainly with creosote and occasionally with
pentachlorophenol (PCP). Small rail cars were used to move lumber to two treatment cylinders. A mixture of either
creosote and water or PCP and petroleum was used to treat the lumber. The treated lumber was dried on racks over
bare soil and stored in an area north of the treatment cylinders,
Wastewater from the treatment cylinders was discharged to an oil-water separator. The creosote recovered from the
oil-water separator was sent to a storage tank for reuse. If the creosote was determined to be off specification, it was
sent to a spent creosote storage tank and properly disposed of at an off-site location at a later date. Wastewater from
the oil-water separator discharged through a culvert and drainage ditch to an unlined three-acre lagoon located in the
southwest corner of the site.
In 1989, a former owner of the facility notified Region 4 of the U.S. Environmental Protection Agency (EPA) that
hazardous materials may have been handled at the site. In response, the Florida Department of Environmental
Regulation (FDER) conducted sampling at the site in July 1990. The results showed that soil and sludge in the area
of the treatment cylinders were contaminated with a number of organic compounds and that the treatment cylinders
contained small amounts of solidified creosote and PCP. In addition, creosote was found in the lagoon and the
storage tanks. No contamination was detected in the aquifer underlying the site. EPA proposed in December 1990
that the site be placed on the National Priorities List (NPL). The listing of the site became final in September 1991.
The potentially responsible parties (PRP) conducted a remedial investigation / feasibility study (RI/FS) at the site
between 1992 and 1996 under the terms of a Federal administrative order on consent (AOC). Testing during that
time confirmed that soils and sediments in the lagoon and drainage ditch were contaminated with polycyclic
aromatic hydrocarbons (PAH). During the RI/FS, EPA and the PRPs agreed to address the site as two operable
units (OU).
OU 1 included the lagoon and the former plant facility. Cleanup activities were completed in March 1996. under a
Record of Decision (ROD) signed on July 25, 1995. The lagoon was drained, contaminated sludge and sediment
was excavated, and wastewater was treated and discharged to a publicly owned wastewater treatment facility.
Highly-contaminated sludge and soil were solidified on site.
A ROD for OU2 was signed March 8. 1996, which is the subject of this report.
II. OPERABLE UNIT BACKGROUND
The remed\ described in the ROD for OU 2 included:
On-site biodegradation of remaining, less-severely contaminated soils in a land treatment area constructed
with a liner, internal drainage, and spray irrigation system:
A-5
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Appendix A - Sample Remedial Action Report
Activities necessary to the proper functioning of the land treatment process:
After treatment, covering the land treatment area with clean fill and re-vegetating: and
Five vears of groundwater monitoring to verify that it remains uncontaminated.
The cleanup goals in the ROD were: Within two years from initial seeding, the land treatment process must reduce
the concentration of TCIC to 100 mg.kg throughout the volume of the material treated. The goals were based
upon a risk assessment that focused on attaining at least a 1 x 10'° risk for ingestipn of contaminated soil by a child.
The risk assessment assumed a future industrial land use scenario, with no institutional controls. Cleanup goals
were described by the total concentration of six carcinogenic indicator constituents of creosote -
benzo(a)anthracene. benzo(a)pyrene. benzo(b)fluoranthene. chrysene. dibenzo(a. h (anthracene, and
indeno(1.2.3.c.d)pyrene - referred to as total carcinogenic indicator chemicals (TCIC). EPA selected the six of the
approximately two hundred compounds that make up creosote because of their concentrations in sludge and soil at
the site and their carcinogenic nature. The concentrations of TCIC in the soil to be treated ranged from 100 to 208
mg/kg.
The September 15. 1996, ROD amendment included:
i
Soils contaminated at levels exceeding 100 mg/kg, but less than 5,000 mg/kg TCICs, were to be
biodegraded in the on-site land treatment area.
Soils found contaminated at levels exceeding 5.000 mg/kg TCICs were to be removed, stabilized, and
disposed of at an EPA-approved hazardous waste disposal facility along with the solidified, OU 1 waste
(7.500 yd3).
If the land treatment process did not attain the cleanup goals for the TCIC within two years, but quarterly
monitoring showed substantial progress toward meeting the cleanup goals. EPA would consider extending
the treatment period. However, if substantial progress could not be identified. EPA would consider
alternative means of addressing the contaminated soils, such as capping, removal, incineration.
solidification, or vitrification.
Groundwater monitoring would begin upon completion of construction of the land treatment area.
Based on the original ROD and the ROD amendment, the remedial design was prepared for construction of the
remedy. The design was completed in five months and approved by EPA September 15, 1998, for implementation
of the remedial action.
III. CONSTRUCTION ACTIVITIES
Site Preparation
Site preparation activities included clearing, grubbing, and grading the land where the land treatment area was to be
constructed: building a drainage swale around the land treatment area; preparing a temporary, central soil stockpile
area consisting of several lined cells: and installing a perimeter fence with signs warning against exposure to
hazardous material. Approximately four acres were cleared. An estimated 200 cubic yards of contaminated soil
found to contain less than 5.000 mg/kg TCICs were excavated during the site preparation activities and stored in the
central stockpile area along with previously excavated, contaminated soil.
Off-Site Disposal of the Solidified, OU 1 Waste
To dispose of the 7.500 cubic yards of solidified OU 1 waste, a suitable receiving facility in Emelle, Alabama.
operated by Chemical Waste Management. Inc. (CWM), was identified. The waste was shipped off site to the
facility in Emelle on December 1. 1996.
A-6
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Appendix A - Sample Remedial Action Report
Construction of the Land Treatment System
A clay iaver ranging from one to three feet in thickness was installed throughout the four-acre land treatment area.
The clay was taken from a borrow pit located elsewhere on the site. The borrow pit was shaped and used as a
750.000-gallon retention pond for collecting water and leachate from the land treatment area. Compacted clay
berms were placed around the land treatment area and around the soil stockpile area. Swales were installed outside
the treatment area to intercept and redirect run-on.
The land treatment area was prepared with a one percent slope to the northwest comer, where the subsurface
drainage system drained under the berm into a gravel-lined swale that led to the retention pond. The drainage
system consisted of 12-inch-wide. flat, perforated pipe laterals, spaced every 50 feet in an east-to-west direction.
The pipes connected to a south-to-north drainage trench containing cylindrical, perforated piping sloping to a sump
in the northwest corner of the land treatment area. The entire subsurface drainage system was covered with a
minimum of six inches of clean, sorted sand. Finally, a portable irrigation system, delivering water at 0.5 inches per
hour to an area 70 feet in diameter, was installed at the retention pond, which recirculated the collected water and
sprayed the water over the land treatment area.
System Operation
Land treatment was performed in three lifts, with a total of 8,100 yd3 of soil treated: 3.300 yd3 (Lift 1): 3.000 yd3
(Lift 2); and 1.800 yd3 (Lift 3). For site management and sampling purposes, the land treatment area was divided
into eight half-acre, rectangular subplots. A composite sample was collected from each subplot each quarter, until
the concentration of TCICs in the soil in the subplot was less than 100 mg/kg. An additional lift of soil from the
stockpile area then was placed in the subplot. The process was repeated until all of the stockpiled soil had been
placed in the land treatment area.
In general, the soil for each lift was placed 4 to 12 inches thick in the land treatment area and inoculated with PAH-
degrading microorganisms. The inoculum, sprayed on the soil, was developed by growing seed cultures in mobile.
on-site reactor tanks equipped with aeration and mixing equipment. The land treatment area was cultivated once
every two weeks. An irrigation system was used to maintain a ten percent soil moisture content. The concentration
of microorganisms in the soils at the land treatment area was found to be adequate to support biological activity, and
no inoculum was applied for the second or third lift. Additionally, the total number of lifts applied to each subplot
varied because several of the half-acre areas exceeded the TCIC concentrations of 100 mg/kg. Subsequently, no
additional soil was placed in those subplots until the analytical results indicated less than 100 mg/kg.
Appendix A contains additional data on the characteristics, site conditions, and operating parameters for the system.
Approximately 50 cubic yards of construction debris were removed from the soil and buried on the site. After
validation of the final sampling results and determination that the cleanup goals had been met, the site was
backfilled with clean soil and seeded on September 1, 1998.
IV. CHRONOLOGY OF EVENTS
Date
March 8. 1996
August 3. 1996
September 15. 1996
Octobers. 1996
Event
ROD for OU 2 signed.
Remedial Design (RD) submitted.
RD approved; ROD amendment signed.
Construction of the land treatment area
began.
A-7
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Appendix A - Sample Remedial Action Report
Date
December I. 19%
December 12. 19%
Januarv 12. 1997
Januar>- 19. 1997
January 20. 1997
June 12. 1997
September 15. 1997
March 14. 1998
June 28. 1998
July 24. 1998
September 1 . 1 998
September 22. 1998
Ongoing
Event
Solidified waste from OU1 transported and disposed of off site.
PRPs. EPA. and the State conduct pre-final inspection of the land
treatment area.
PRPs. EPA, and the State conduct final inspection of the land treatment area.
Operation of land treatment area begun; first lift of soil applied to
subplots: sampling of soil in treatment plots begun.
treatment
Semiannual groundwater monitoring initiated .
Preliminary Close Out Report for site signed for site construction
completion.
Second lift of soil applied to treatment subplots.
Third lift of soil applied to treatment subplots.
Final sampling of soil in treatment subplots and in other designated site areas
conducted.
Final soil sampling results validated: cleanup goals achieved.
Land treatment area demobilized and re-vegetated.
PRPs. EPA, and the State conduct pre-certification inspection of the completed
remedial action.
Semiannual groundwater monitoring.
V. PERFORMANCE STANDARDS AND CONSTRUCTION DUALITY CONTROL
Initial concentrations of PAHs in untreated, stockpiled soil ranged from 100 to 208 mg'lcg. Upon completion of
land treatment, the concentration of TCICs in soil ranged from 23 to 92 mg"kg.
All soil and sludge samples collected during operation of the land treatment area were analyzed for PAHs. EPA
Method 8270 was used to measure the concentrations of PAHs in all samples. Composite samples were collected
quarterly from eight subplots in the land treatment area over an 18-month operating period. Once the cleanup goal
had been achieved in a subplot, that subplot was not monitored further until an additional lift of soil was applied to
the subplot.
TABLE 1 - PERFORMANCE RESULTS COMPARED WITH REMEDIATION OBJECTIVES /
CLEANUP GOALS
Remediation Objectives / Cleanup Goals
Reduce concentration of TCICs to 100 rng'Tcg.
Attain desired cleanup goals within two years after
startup of the land treatment operation.
Performance Results
Sampling conducted in June 1998 indicated that the
concentration of TCICs was less than 100 mg/kg and
ranged from 23 to 92 mg/kg in the eight subplots.
Cleanup levels were attained within 18 months after
startup of the land treatment operation.
A-8
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Appendix A - Sample Remedial Action Report
TABLE 1 - PERFORMANCE RESULTS COMPARED WITH REMEDIATION OBJECTIVES /
CLEANUP GOALS
Remediation Objectives / Cleanup Goals
Identity remove, stabilize, and dispose (off site) of
excavated OU 2 soils with TC1C levels greater than
5.000 mg/kg.
Dispose (off site) of 7.500 yd3 of solidified, highly-
contaminated soil and sludge.
Performance Results
Sampling detected no soils with contamination above
specified level.
7.500 yd3 were removed from the site and disposed ot
the CWM landfill in Emelle, Alabama.
this
in
Quality Assurance and Quality Control
The QA/QC program used throughout the operation of the land treatment area was outlined in the RD'RA work plan
and Quality Assurance Project pfan (QAPP) approved by EPA. The program enabled EPA to determine that all
analytical results reported were accurate and adequate to ensure satisfactory execution of the remedial action, in a
manner consistent with the requirements of the ROD.
The RA contractor conducted sampling and analysis activities on the soils each quarter. EPA took split samples
during three sampling events, including the final sampling event on June 28, 1998. EPA periodically conducted
oversight of the PRP contractor's field sampling procedures. While deviations from the approved protocols were
identified, none was sufficiently significant to cause rejection of the data. Matrix spike, duplicate, and blank
samples were analyzed by the laboratory, and the resulting data provided to EPA. On the basis of the split sample
data, the confirmatory sampling data were acceptable to EPA. The Florida Department of Environmental Regulation
(FDER) also reviewed the data and found the data to be acceptable.
The QA/QC program is also being used for the semiannual sampling of groundwater.
VI. FINAL INSPECTION AND CERTIFICATION
Inspections
The pre-fmal inspection of the land treatment area construction was held on site December 12, 1996, in the presence
of EPA. PRP. and FDER representatives. The FDER representative noted the need to fence the lagoon for the
protection of the public, and a fence was constructed around the lagoon area.
The final inspection was conducted January 12, 1997. EPA. the PRPs. FDER, the Florida Department of Health and
Rehabilitative Services (FDHRS). the Suwanee County Coordinator, and the Mayor of Live Oak were present.
Representatives verified by review of the manifest that the 7.500 cubic yards of solidified OU 1 waste had been
properly transported and d'isposed off site at the CWM landfill in Emelle. Alabama. No punch-list items were
identified, and land treatment of the stockpiled contaminated soil was authorized to begin immediately.
Observations, inspections, and testing during operation of the land treatment process found no significant
operational problems affecting the performance of the remedial action. A business east of the site reported
experiencing nuisance smells after the contaminated soils in the land treatment area were tilled. In response, an
effort was made to till when the wind direction was away from the businesses to the east of the site. No further
comments about odors were received during the land treatment operation.
Health and Safety
No health and safety problems were encountered during construction or operation. Modified Level D personal
protective equipment (PPE) was required for all site personnel who came into direct contact with the contaminated
soil. The equipment included coveralls, safety boots, nitrile gloves, and paniculate masks.
A-9
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Appendix A - Sample Remedial Action Report
Certification of Completion
A pre-cenification inspection of the completed remedial action was conducted on September 22. 1998. by
representatives of the PRPs. EPA and the FDER. On October 17. 1998. the PRPs provided a written report that the
remedial action has been fully performed and the Performance Standards of the Consent Decree have been attained.
VII.
OPERATION AND MAINTENANCE
The land treatment area was seeded in September 1998. The vegetative cover will be reseeded in Spring 1999 as
necessary.
, ,. l
The semiannual groundwater monitoring program began in January 1997. No TCICs have been detected as of the
July 1998. sampling: however, naphthalene has been detected persistently at low levels in groundwater monitoring
well No. 7. The levels of naphthalene are below any action level. As specified in the ROD. the PRPs will continue
semi-annual monitoring of groundwater through 2002 to confirm that groundwater will not be adversely impacted
by the land treatment activities.
VIII. SUMMARY OF PROJECT COSTS
1.1 i
Table 2 provides a summary of the costs for each major cost element and a comparison of the actual project costs
with the ROD estimate of project costs. Unit costs for soil treatment were $45/yd3 for 8,100 yd3 of soil treated.
Based on an average soil density of 1.2 tons/yd3, the unit cost for this application was S36/ton for 9.700 tons of soil
treated. Appendix A provides an annotated breakout of the actual costs.
TABLE 2 - COST SUMMARY
Cost Item
RA Capital Cost
RA Operating Cost
Total RA Cost
Projected O & M Cost:
Difference between total project cost and total
ROD cost estimate3
ROD Estimate
(1996 $$)
S266.000
258.000
524.000
ROD Estimate
(1998SS)'
S306.000
295.000
600.000
-$243, 23 8 or -41%
Actual Cost
(1998 SS)
S227.437
129.325
356.762
21.000
IX
ROD Cost was adjusted from 1996 S$ to 1998 S$ using 7% annual inflation
: Ground water monitoring was not included in original ROD.
! Difference between project cost and ROD estimate is largely attributable to
instead of 24 months planned in the ROD.
OBSERVATIONS AND LESSONS LEARNED
The project cost 41% less than the ROD estimate, largely due to reduced labor and materials costs
associated with achieving cleanup goals in 18 instead of 24 months. Use of an on-site laboratory also
contributed to savings.
The land treatment application was found to be more effective at remediating soils on the site when the
soils were tilled once every two weeks, rather than once every four weeks, as was originally planned.
rate.
18 months of actual treatment
A-10
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Appendix A - Sample Remedial Action Report
Application of fertilizers to the soils at the site proved to be unnecessary because of the naturalK high
concentrations of inorganic nitrogen and phosphorous in the soil.
The relatively mild year-round temperatures at the site provided a beneficial growing environment for the
inoculum of PAH-degrading microorganisms. Consequently, relatively high numbers of microorganisms
remained in the soil, thus reducing the need for repeated soil inoculations.
Soils at the site were difficult to till after heavy rains. Natural drying of the soil took an average of two
weeks before tractors could be operated on the land treatment area.
Precautionary measures to avoid nuisance odors on neighboring properties may be necessary in land
treatment remedies.
X. CONTACT INFORMATION
The PRPs used the following contractor for the RA:
Primary Contact Name and Title
Company Same
Address
Phone Number
The EPA used the following contractor for oversight of the RA:
Company Name Contract Number
Address Work Assignment Number
Phone Number
The following companies analyzed samples:
For the PRPs: Company Name For the EPA: Contract Number
Address Company Name
Phone Number Address
Phone Number
The project manager for the PRPs was: The project manager for the EPA was:
Name Name
Company Name U.S. EPA Region
Address Address
Phone Number Phone Number
A-ll
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APPENDIX A -- REMEDIAL ACTION REPORT
I CREOSOTE, LIVE OAK, FL (OU 2).
The specific parameters presented in Appendix A were prepared in accordance with the
"Guide to Documenting and Managing Cost and Performance Information for Remediation
Projects. " EPA 542-B-98-00~. Regions are encouraged to use the recommended
procedures outlined in this Guide for documenting cost and performance information as
part of the Remedial Action Report.
TABLE 1 - CHARACTERISTICS AND SITE CONDITIONS
Parameter
Site Conditions
Measurement Procedure / Comment'
Environmental Setting
Air temperature (°F)
Humidity (%)
Barometric pressure
(inches of mercury)
Average rainfall
(inches)
71 (average for 1997)
72 (average for 1998)
76 (average for 1997)
30.07 (average for 1997)
50.39(1997)
43.53 (1998)
NA
NA
NA
NA
Soil Types
Soil classification
Mixture of lagoon contents:
lagoon had a clay bottom and
sandy contents, which ranged
from silty clay to fine sand
Because the medium treated was a mixture of
lagoon contents, it did not lend itself to a formal
classification analysis.
Aggregate Soil Properties
PH
Total organic carbon
Quantity of soil treated
6.9
1 6.000 mg/kg
8. 100 yd5 (total for 3 lifts)
The value listed represents an average measured
during one of the sampling events; EPA Method
SW-846/9045 was used to measure the pH of the
soil.
The value listed represents an average
during one of the sampling events:
EPA Method SW-846/9060 was used
the total organic carbon in the soil.
measured
to measure
NA
r NA - not applicable. Measurement procedures are reported onK for those parameters where different procedures are available.
A-I:
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APPENDIX A -- REMEDIAL ACTION REPORT
I CREOSOTE, LIVE OAK, FL (OL 2).
TABLE 2 - OPERATING PARAMETERS
Parameter
Site Conditions
Measurement Procedure / Comment'
System Parameters
Soil mixing rate
frequency
Soil placed in the subplots was
tilled everv two weeks.
Mixing rate or frequency is the rate of tilling for
land treatment.
Soil moisture
content (%)
12.4-22.8 (Lift 1)
12.9-21.1 (Lift2)
8.5- 14.7 (Lift 3)
Soil moisture was measured using the
gravimetric ASTM standard D 2216-90. Test
Method for Laboratory Determination of Water
(Moisture) Content of Soil and Rock.
pH
6.6-7.2 (Lift 1)
6.8-7.5 (Lift 2)
6.4 - 7.0 (Lift 3)
Values shown represent the ranges of pH for
each lift. EPA Method SW-846~9045 was used
to measure the pH content.
Residence time
(months)
9- 15 (Lift 1)
6- 10 (Lift 2)
4 (Lift 3)
Ranges are given for each lift because of the
variations by subplot.
Soil temperature (°F)
13-99 (Lift 1)
13- 102 (Lift 2)
29- 102 (Lift 3)
NA
Biological Activity
Carbon'Total Kjeldahl
Nitroaen
8.8- 15.4 (Lift 1)
8.8-78 (Lift 2)
6 - 67 (Lift 3)
Values represent the ratio of Carbon to Total
Kjeldahl Nitrogen in the soil at the time of
measurement for each lift. Ranges are shown for
the eight treatment subplots. EPA Methods
415.1 (Modified) and 351.1 (Modified) were
used.
Hydrocarbon
degradation
(mg kg month)
13-58 (Lift 1)
No values were determined for
Lifts 2 and 3.
Calculation of hydrocarbon degradation was
based on the difference between the initial and
final TCIC concentrations in the first lift and
dividing that value by the amount of time
required for treatment of soil in that cell in the
first lift. The values shown represent the range
measured for the eight treatment subplots.
A-14
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APPENDIX A -- REMEDIAL ACTION REPORT
U CREOSOTE, LIVE OAK, FL (Ol 2)
TABLE 2 - OPERATING PARAMETERS
Parameter
Site Conditions
Measurement Procedure / Comment'
PAH degraders
(cfugm)
l.OxiO5- 5.0x10" (Lift 1)
7.0x!0:-4.5x10" (Lift 2)
No values were determined for
Lift 3.
"Replica Plating Method for Estimating
Phenanthrene-Utilizing and _Phenanthrene-
Cometabolizing-Microorganisms." Shiaris. M..
Cooney. J.. Applied and Em-ironmental
Microbiology. February 1983. Vol. 45. No. 2. pp.
706-710.
Total heterotrophs
(cfu,'gm)
7xl05-9.9x10" (Lift 1)
6.3xl05-6.6xl07(Lift2)
7.0xl04- l.lxlO?(Lift3)
"Agar-Plate Method for Total Microbial Count.
F. Clark. Methods of Soil Analysis. Vol. 2, pp.
1460-1465.
"NA - not applicable. Measurement procedures are reported only tor those parameters where different procedures are available.
TABLE 3 - DETAIL OF PROJECT COSTS
Cost Element
Cost (1998$$)
RA Capital Costs:
Mobilization / Demobilization
Site Work / Preparation
Clearing and grading
Excavation (of soil)
Fencing
Site restoration
Equipment and Appurtenances
Installation of clay layer
Shape retention pond
Installation of subsurface drainage
Construction of perimeter containment berms
Installation of run-on drainage swales
Installation of irrigation system
Rental of tractor and tiller
Non-Process Equipment
Purchase of Level D personal protective equipment
$33,769
16.357 (S4.090/acre x 4 acres)
7.655($0.95/yd3x8.100yd3)
21.666
8.445
39.931 (S5.70/yd3 x 7.000 yd3)
5.658
48.216
11.305($5.65/ftx2.000ft)
5.928 ($1.98/ftx 3,000 ft)
15.802
10.653
2.052
Total Capital Cost
227.437
A-15
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APPENDIX A -- REMEDIAL ACTION REPORT
U CREOSOTE, LIVE OAK, FL (OL 2)
TABLE 3 - DETAIL OF PROJECT COSTS
Cost Element
Cost (1998SS)
RA Operating Costs (January 19 - July 24. 1998):
Direct Labor
Operation of tiller and sprayer
Direct Materials (includes utility and fuel costs)
Diesel fuel ' fertilizer inoculum seed cultures
Spread contaminated soil
Equipment Overhead
Maintenance ' repair of site vehicles
Analytical (related to technology performance, not compliance
monitoring)
Use of on-site laboratory
Disposal of Residuals
Highly contaminated sludge
Total RA Operating Costs
15.232 .
3.251
38.551 (S4.76/yd3x8.100vd;)
4.292
64.700
3.299 (7,500 yd3)
129.325
Total RA Cost
356,762
Projected O & M Cost (Sept. 1998 - Sept. 1994)
Semiannual groundwater monitoring (five-year total) 21,000
Total Projected O & M Costs
21.000
A-16
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Appendix B - PRELIMINARY CLOSE OUT REPORTS
B-l
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11 "I"
These Sample Preliminary Close Out Reports are hased on an actual Superfund sites, hut fume int'-r
-------
Appendix B - Sample Preliminary Close Out Reports
Preliminary Close Out Report
Waste-Be-Gone Disposal Corp. Site
Dumpsburg, Refuse County, Iowa
I. INTRODUCTION
This Preliminary Close Out Report documents that the U.S. Environmental Protection Agency (EPA) completed
construction activities at the Waste-Be-Gone Disposal Corp. site in accordance with Close Out Procedures for
National Priorities List Sites (OSWER Directive 9320.2-09A-P). EPA and the Iowa Department of Environmental
Protection (State) conducted a pre-final inspection on June 2. 1999. and determined that the contractors have
constructed the remedy in accordance with remedial design (RD) plans and specifications, and no further response is
anticipated. EPA and the State have initiated the activities necessary to achieve performance standards and site
completion.
II. SUMMARY OF SITE CONDITIONS
Background
The Waste-Be-Gone Disposal Corp. site is a 40-acre facility located in Dumpsburg, Refuse County. Iowa. The site
is in a rural area in the south central portion of the State, near the Missouri border. Approximately 180 persons live
and work within one mile of the site. The majority of this population lives to the east of the site and obtains
drinking water from a public supply. The nearest residential area, a small subdivision of 28 persons, is
approximately one-half mile to the east.
Waste-Be-Gone Disposal has operated the site as a disposal facility since 1965. Originally, the facility accepted
only solid waste from residential sources. However, the facility accepted small quantities of pesticides and other
organic wastes generated by the local agricultural industry from 1969 to 1971. Site records indicate that the
majority of pesticides and organic wastes were disposed of in the southeastern portion of the site. Additionally, site
operators occasionally sprayed waste oil on the dirt access roads as a dust suppressant.
Through initial investigations of the site. EPA determined that the following contaminants of concern were present
in surface soil, with lower concentrations of these contaminants found in underlying soil areas:
Pesticides (including aldrin. 0.35 milligrams per kilogram (mg/kg); chlordane. 70 mg/kg: dichlorodiphenyl
trichloroethane (DDT), 211 mg/kg; and toxaphene. 712 mg/kg):
Solvents (including acetone. 100 mg/kg, and toluene. 75 mg'kg): and
Metals (including arsenic, 537 mg/kg).
These soil contaminants posed the greatest risk to human health through dermal contact. Concentrations of
contaminants in the ground water beneath the site have been, and continue to be. below health-based levels, and
therefore, do not pose a threat.
EPA proposed the site to the National Priorities List (NPL) on December 30, 1987 (47 FR 58476). and added it to
the final list on September 8. 1988 (48 FR 40674).
Remedial Construction Activities
On June 28. 1991. the Regional Administrator signed a Record of Decision (ROD) documenting the remedial action
(RA) for Operable Unit 1 (OU 1), which included implementing institutional controls and installing ground water
monitoring wells and performing sampling and analysis as an interim remedy. A second ROD on November 9.
B-3
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Appendix B - Sample Preliminary Close Out Reports
1995. selected the following remed> to address OL'2:
Sampling and analysis of soil to define the estimated lateral and vertical extent of contamination:
; | , , ; "
Excavating highly contaminated surface soil, primarily from the southeastern portion of the site, which
exceeds health-based performance standards specified in the ROD:
Treating the contaminated soil on-site using soil washing followed by solidification ' stabilization
technologies and consolidating treatment residuals in the main landfill area:
, |
Backfilling the excavated areas with clean impermeable fill, regrading. and revegetating:
Placing a multi-media Resource Conservation and Recovery Act (RCRA) cap on the landfill with
subsequent revegetation;
Implementing site access and groundwater use restrictions: and
Continuing groundwater monitoring.
i
Health-based performance standards specified in the ROD are: aldrin, 0.25 mg/kg; chlordane, 5 mg'kg; DDT. 10
mg/kg: toxaphene. 3 mg'kg; acetone. 10 mg/kg: toluene. 1 mg'kg; and arsenic, 50 mg/kg. The selected remedy
eliminates the principal threat posed by the site by reducing the toxicity and mobility of the highly contaminated
materials through treatment, thereby reducing the potential for exposure to pesticides;, solvents, and metals detected
in surficial soils.
Before beginning the RD, EPA sampled and analyzed surface and subsurface soil primarily in the southeastern
portion of the site and along site access roads. The analytical results indicated that approximately 1.375 cubic yards
of highly contaminated soil from the southeastern portion of the site and 800 cubic yards from the site access roads
would require excavation, treatment, and consolidation within the main landfill area.
On August 21, 1996. EPA processed a work assignment to the Remedial Action Contractor (RAC) to develop a
work plan for the RD. The RAC responded with the final work plan on September 4, 1996. The RAC completed
the RD on February 10. 1997.
EPA awarded an RA contract on March 23. 1998. EPA and the State conducted remedial activities as planned, and
no additional areas of contamination were identified. Next. EPA conducted a pre-fmal inspection on June 2, 1999.
in conjunction with the State, and developed a list of outstanding contract items. The RA activities were performed
according to design specifications set forth in the 1997 RD package, including:
Sampling and analyzing soils to define the area of contamination:
Constructing on-site treatment systems for soil washing followed by solidification / stabilization:
Excavating and treating contaminated soils and backfilling the excavated area;
Consolidating treatment residues in the landfill;
Regrading, capping, and revegetating the landfill: and
* Constructing a chain-link fence around the perimeter of the site with a locked gate to restrict the access of
unauthorized persons and equipment, and posting appropriate warning signs.
During pilot-scale treatability tests. EPA monitored air quality and took dust suppression measures to ensure that
contaminated materials did not become an airborne threat. EPA also continued to monitor the groundwater.
Contaminant concentrations analyzed within these media did not exceed health-based or regulatory standards.
B-4
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Appendix B - Sample Preliminary Close Out Reports
Remaining activities to be completed by the EPA contractor include periodic adjustments and or modifications to
the constructed remedy to maintain optimum performance, as uell as demobilization of on-site facilities no longer
required to conduct the remedial action. EPA and the State have not yet concurred on the operational and functional
(O&F) period.
No activities using removal authority were conducted at this site.
The Refuse County Recreation Department is investigating the possibility of placing a sports complex on the site.
The site appears suitable for this use; however, a source of funds for constructing and operating the complex has not
been identified.
III. DEMONSTRATION OF CLEANUP ACTIVITY QUALITY ASSURANCE AND QUALITY
CONTROL
EPA and the State reviewed the remedial action contract and construction for compliance with quality assurance and
quality control (QA/QC) protocols. Construction activities at the site were determined to be consistent with the
ROD, RD plans and specifications, and RD/RA statement of work issued to the RACs contractor.
The subcontractor for construction adhered to the approved construction quality control plan (CQCP). The
construction quality assurance plan (CQAP) incorporated all EPA and State requirements. All confirmatory
inspections, independent testing, audits, and evaluations of materials and workmanship were performed in
accordance with the construction drawings, technical specification and CQAP. Construction quality assurance was
performed by the RAC contractor firm, which maintained a constant on-site presence. The EPA RPM and State
regulators visited the site approximately three times per month during construction activities to review construction
progress and evaluate and review the results of QA/QC activities. Deviations or non-adherence to QA/QC
protocols, drawings, or specifications were properly documented and resolved.
The Quality Assurance Project Plan (QAPP) incorporated all EPA and State QA/QC procedures and protocol. EPA
analytical methods were used for all confirmation and monitoring samples during RA activities. Procedures and
protocol followed for soil sample analysis during the RA were conducted using a laboratory under contract to the
Contract Laboratory Program (CLP). The air sample analysis followed the EPA protocols in the Compendium of
Methods for the Determination of Toxic Organic Compounds in Ambient Air. EPA and the State determined that
analytical results are accurate to the degree need to assure satisfactory execution of the RA.
IV.
ACTIVITIES AND SCHEDULE FOR SITE COMPLETION
The following activities remain for the Waste-Be-Gone Disposal site:
Task
1 ) Approve O&M Plan
2) Complete Final Inspection
3) Determine Remedy O&F
4) Approve RA Report
5) Five-Year Review
6) Approve Final Close Out
Report
7) Deletion From NPL
Estimated Completion
06/30/00
06/02/01
06/02/01
08/02/01
03/30/03
04/01/03
09-30/03
Responsible Organization
EPA/State
EPA/State
EPA/State
EPA/State
EPA
EPA
EPA
B-5
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Appendix B - Sample Preliminary Close Out Reports
V. SUMMARY OF REMEDIATION COSTS
The original cost estimate to implement the remedial action described in the ROD for operable unit 2 (OU2) was
S14 million (net present worth). Costs were estimated for an anticipated 30-year O & M time period and a discount
rate of" ~°o was used in the ROD estimate. More detailed cost estimate documentation can be found in the
Feasibility Studs for OL'2.
The bid price for the project was $15 million. This was due to the need for additional aquifer and plume data to
optimize the design of the extraction well system. An additional 30 monitoring wells at 19 locations were needed
because the Rl data was inadequate to design the selected remedial action.
At the time that this Preliminary Closeout Report was prepared, all of the project costs have not yet been reported
forOU2. The ROD estimate for the capital costs of OU1 was S3 million. The final RA cost for OU 1 is S3.6 million
(more detailed RA cost information can be found in the RA report for OU 1). For O(J2. approximately S15 million
has been expended to date for RA construction, with another SI million anticipated due to lagging costs and
shakedown period refinements. Final RA costs for OU2 will be documented in the RA report. RA cost growth
from the bid estimate of S15 million to the anticipated final RA costs of S19 million is due to change orders
associated with an unanticipated increase in the total volume of contaminated soil requirement excavation and
treatment. Annual O & M expenditures have increased from the $400.000 originally estimated in the ROD to
S500.000 due to an increase in the number of monitoring wells that need to be sampled.
VI.
FIVE-YEAR REVIEW
Hazardous substances will remain at the site above levels that allow unlimited use and unrestricted exposure after
the completion of the remedial action. Pursuant to CERCLA section 12l(c) and as provided in the current guidance
on Five Year Reviews: OSWER Directive 9355.7-02. Structure and Components of Five-Year Reviews. May 23.
1991. OSWER Directive 9355.702A. Supplemental Five-Year Review Guidance. July 26. 1994. and the Second
Supplemental Five-Year Review Guidance. December 21, 1995, EPA must conduct a statutory five-year review.
The Five-Year Review Report will be completed prior to March 2003 (five years after RA onsite mobilization).
iSignaturel
Director, Waste Management Division
(Date)
i
Date
B-6
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Appendix B - Sample Preliminary Close Out Reports
Preliminary Close Out Report
Miller & Metal Smelting Corp. Site
Meltstown, Slag County, Colora'do
f. INTRODUCTION
This Preliminary Close Out Report documents that the U.S. Environmental Protection Agency (EPA) completed all
construction activities for the Miller's Metal Smelting Corp. site in accordance ,with Close Out Procedures for
National Priorities List Sites (OSWER Directive 9320.2-09A-P). EPA and the Colorado Department of Health
(State) conducted a pre-fmal inspection on May 16. 1995. and determined that the potentially responsible parties
(PRPs) constructed the remedy in accordance with remedial design (RD) plans and specifications. The PRPs have
initiated activities necessary to achieve performance standards and site completion.
II. SUMMARY OF SITE CONDITIONS
Background
The Miller's Metal Smelting Corp. site is a 75-acre lead smelter in Meltstown. Slag County. Colorado. This site is
just south of Midcounty Road and east of Evergreen Street. Approximately 230 persons live and work within a one-
mile radius of the site. The majority of this population lives to the west of the site near Meltstown. and most obtain
drinking water from a public supply. Six private wells are located within one mile of the site.
Miller's Metal Smelting acquired the facility in 1956 from Carpenter Refining Corp. and operated it until 1981. The
facility had served as a primary lead smelter since the turn of the century. Throughout this time, ore typically was
brought to the smelter via rail cars and stored in several on-site facilities. Waste generated from the smelting
process included: a hot speiss from the dross plant which was pumped into the unlined speiss pond, process waste
water that was sent to Simpson Pond, and fugitive air emissions from the smelter stack.
Contaminants of concern at the Miller's Metal Smelting site include arsenic, cadmium, and lead. The site posed
potential threats to human health and the environment through dermal contact or ingestion of contaminated soil,
sediment, groundwater. and surface water, as well as inhalation of airborne contaminated-paniculate matter.
EPA proposed the site to the National Priorities List (NPL) on September 8, 1988 (53 FR 40674). and added it to
the final list on September 21, 1989 (54 FR 37070).
Remedial Construction Activities
On December 31. 1992, the Regional Administrator signed a Record of Decision (ROD) selecting the following
remedy:
Replacing the process ponds with steel tanks; installing secondary containment for the tanks: and treating
the process waste water via co-precipitation prior to storage in the steel tanks;
Excavating and disposing off-site approximately 150.000 cubic yards of contaminated soil and sediments.
followed by sampling:
Pumping and treating contaminated groundwater via co-precipitation for approximately 10 years, with
groundwater monitoring; and
Conducting surface water monitoring for 10 years after completion of the remedial action (RA).
The ROD specified cleanup levels for soils and sediments, wastewater. and groundwater. For soils and sediments
contaminated with arsenic, cadmium, and lead, the ROD specified excavation to a depth of 18 inches or until the 10'
0 risk level is achieved. The cleanup levels for wastewater. containing arsenic, cadmium, and lead, were 0.02
B-7
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Appendix B - Sample Preliminary- Close Out Reports
milligrams per liter(mg 1) for arsenic: 0.01 mg 1 for cadmium: and 0.004 mg I for lead. LastK. the ROD specified
cleanup levels for groundwater. reducing levels of arsenic, cadmium, and lead to maximum contaminant levels of
0,05 mg I. 0.0! mg I. and 0,05 mg 1. respectivelv.
In a consent decree signed with EPA. the PRPs agreed to perform the remedial design remedial action (RD RA).
The RD was conducted in conformance with the approved ROD. The RA was initiated on November 2. 1993. when
the PRP awarded the RA contract. The contractor conducted remedial activities as planned, and no additional areas
of contamination were identified. EPA and the State conducted a pre-fmal inspection on May 16. 1995. which
included a description and schedule for correcting minor construction contract items by the contractor. These
"punch" list items included re-establishing the turf around the pumphouse: installation of fire extinguishers, and
removal of the construction trailer. EPA and the State determined that the following KA activities were constructed
and or completed according to the ROD design specifications:
Rempving and treating process waste waters via co-precipitation, as well as installing storage tanks and
containment systems:
. I , ,, |
Excavating and disposing off-site contaminated soil and sediments, followed by sampling to characterize
the excavated area;
1 ' i i i i
Backfilling the excavated area with clean soil; and
Pumping and treatment of contaminated groundwater via co-precipitation.
The contractor began pumping and treating the contaminated groundwater via co-precipitation and will continue
this process for an estimated 10 years. Remaining activities to be completed by the contractor include any periodic
adjustments and / or modifications to the constructed remedy to maintain optimum performance. EPA and the State
have approved the operations and maintenance (O&M) plan.
No activities were conducted using removal authority at this site.
I. ...I ""' ', ,',:'. I ' [
No reuse is currently planned for the site.
III. DEMONSTRATION OF CLEANUP ACTIVITY QUALITY ASSURANCE AND QUALITY
CONTROL
EPA and the State reviewed the remedial action contract and construction for compliance with quality assurance and
quality control (QA QC) protocols. Construction activities at the site were determined to be consistent with the
ROD. RD plans and specifications, and RD/RA statement of work in the consent decree.
The PRP construction contractor adhered to the approved construction quality control plan (CQCP). The
construction quality assurance plan (CQAP) incorporated all EPA and State requirements. All confirmatory
inspections, independent testing, audits, and evaluations of materials and workmanship were performed in
accordance with the construction drawings, technical specification and CQAP. Construction quality assurance was
performed by an independent firm retained by the PRP. The EPA RPM and State regulators visited the site
approximately twice per month during construction activities to review construction progress and evaluate and
review the results of QA QC activities. Deviations or non-adherence to QA/QC protocols, drawings, or
specifications were properly documented and resolved.
The Quality Assurance Project Plan (QAPP) incorporated all EPA and State QA/QC procedures and protocol. EPA
analytical methods were used for all confirmation and monitoring samples during RA activities. Sampling of soil.
sediments, and water followed the EPA protocol Test Methods for Evaluating Sol id Wastes. Physical/Chemical
Methods. EPA and the State determined that analytical results are accurate to the degree need to assure satisfactory
execution of the RA.
B-8
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Appendix B - Sample Preliminary Close Out Reports
IV. ACTIVITIES AND SCHEDULE FOR SITE COMPLETION
The following activities will be completed according to the following schedule:
Task
Complete Punch List Items
Complete Final Inspection
Determine Remedy O&F
Approve Interim RA Report
Five- Year Review
Complete Surface Water Monitoring
2nd Five- Year Review
Complete Ground Water Pump & Treat
Pre-Certification Inspection
Approve Final RA Report
Approve Final Close Out Report
Delete Site
Estimated Completion
09 15 95
01' 15 '97
Ori5-'97
03.- 15 97
05 3000
io/oro5
05,30/05
H'31'05
01/05/06
01/31/06
03/30/06
06/30/06
Responsible Organization
PRP
EPA State
EPA State PRPs
EPA State PRPs
PRP
PRP
PRP
PRP
EPA/State/PRP
EPA
EPA
EPA
SUMMARY OF REMEDIATION COSTS
V.
The original cost estimate to implement the remedial action described in the ROD was SI7.5 million. The PRPs
reported that the construction contract award amount was $20.3 million and the estimated final construction cost is
$22.8 million. The increase in cost from ROD to RA award is attributed to an improved definition of the scope of
the project in going from the RI/FS to the final design of the project. The cost growth during construction was
caused mainly by an increase in the estimated quantity of contaminated soil that was excavated and shipped off-site
for disposal.
The ROD estimate for annual maintenance costs was S650.000. The actual annual cost of maintenance is reported
by the PRPs to be approximately 5720,000, well within the accuracy of the ROD estimate. EPA's oversight cost for
the construction was $340,000. and $27,000 a year for the oversight of annual maintenance activities.
VI.
FIVE-YEAR REVIEW
Upon completion of this remedy, no hazardous substances will remain on-site above levels that prevent unlimited
use an unrestricted exposure. However, because this remedy will require greater than five years to achieve these
levels, pursuant to CERCLA section 121(c) and as provided in the current guidance on Five Year Reviews [OSWER
Directive 9355.7-02, Structure an components of Five-Year Reviews. May 23, 1991. OSWER Directive 9355.702A,
Supplemental Five-Year Review Guidance, July 26, 1994. and the Second Supplemental Five-Year Review
Guidance. December 21. 1995], EPA must conduct a policy five-year review. Therefore, the Five-Year review will
be completed prior to May 2000 (five years after construction completion date).
Director. Waste Management Division
Date
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Appendix C - FINAL CLOSE OUT REPORT
C-l
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This Sample Final Close Out Report \us *--/.svJ on an actual Superfund site, hut some information has V<.7;
altered for illustrative purposes.
Content and formal of actual Final Close Out Reports prepared may vary from these samples due to
considerations such as project lead and support roles. a\'ailabilit\' of information, and site-specific conditions
For more about preparing a Final Close Out Report, refer to OStt'ER Directive 9320.2-9A-P. "Close Out
Procedures for \ational Priorities List Sites. " EPA 540-R-9H-016.
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Appendix C - Sample Final Close Out Report
Final Close Out Report
Metal Waste Products Inc. Site
Wasteville, Hazard Countv, California
I. INTRODUCTION
This Final Close Out Report documents that the U.S. Environmental Protection Agency (EPA) completed all
response actions for the Metal Waste Products, Inc. site in accordance with Close Out Procedures for National
Priorities List Sites (OSWER Directive 9320.2-09A-P).
II. SUMMARY OF SITE CONDITIONS
Background
The Metal Waste Products. Inc. site covers 9 acres in Wasteville. Hazard County, California. The site is situated in
an industrial area of town, approximately 2.000 feet downstream from the confluence of the American and
Sacramento Rivers. Approximately 400 feet northwest and upstream of the site, is the surface water intake
supplying water for up to 145.000 people in Wasteville. Concern for impact on this water supply was the primary
reason the site was proposed for the National Priorities List (NPL) on December 30, 1982.
Between 1950 and 1965, the company salvaged all grades and types of metal, including railroad cars, army tanks.
batteries, and some electrical transformers. The total quantities of hazardous or non-hazardous materials handled or
disposed of at this site are unknown. In 1965. the State of California purchased the site as easement for the pending
construction of Interstate 5 (1-5). By 1967,1-5 and the realigned Main Street covered 6.7 acres of the original 9-acre
site.
Remedial Investigation / Feasibility Study
Between 1981. when the site first came to the attention of the California Department of Health Services (DHS). and
1985, the 2.3 acres not covered by roadway structures and adjacent areas were sampled seven times. EPA
performed a remedial investigation (RJ) between June 1983 and June 1984. Lead, copper, and zinc were detected in
the top foot of soil throughout the 2.3 acres at levels significantly higher than State criteria. Specifically, the
maximum concentrations detected in the 27 surface samples from the 2.3 acres were 13.600 parts per million (ppm)
lead. 3,450 ppm copper, and 19,700 ppm zinc. Of 48 subsurface samples from the 2.3-acre area, contamination was
detected at only four locations at depths ranging from 3 to 10 feet below ground level. The final RI report
summarized all site analyses results.
On February' 14, 1985. EPA released a draft of the Feasibility Study (FS) for a three-week public comment period.
The FS provided an in-depth summary and discussion of site sampling activities, a public health assessment, and an
analysis of remedial alternatives. The FS concluded that no action at the site could result in a potential health threat
to the public through dermal contact with soil contaminated with lead. The FS then provided a detailed analysis of
capping, excavation and off-site removal, encapsulation, and no action remedial alternatives. No activities using
removal authority were conducted at this site.
ROD Findings
On May 9. 1985. consistent with the Remedy Delegation Report of March 8. 1985. the Regional Administrator
approved a Record of Decision (ROD), which selected excavation and off-site disposal of all soil contaminated with
lead above background levels (200 ppm). This ROD was amended on October 4, 1985. based on recent guidance
allowing clean site closure action levels to exceed background levels where EPA can demonstrate that the residual
contamination would pose no threat to human health or the environment. Based on cleanup objectives at other
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Appendix C - Sample Final Close Out Report
Federal and State hazardous waste sites, as well as recommendations from the l',S. Centers for Disease Control, the
5UO-ppm lead cleanup level was determined to be protective of health and the environment at the site.
Design Criteria
On June 10. 1985. EPA issued an Interagency Agreement for S72.500 to the USAGE to perform the remedial
design. The Fund-lead RD was completed on August 28. 1985. The project was also a Fund-lead construction.
' , ' ! ' i ;;>ii '' * I '< :','' ! ; ); i1
Between April 1985 and September 1985. EPA and the State negotiated a State Superrund Contract (SSC). The
SSC was reviewed and revised five times before a final contract was signed on April 1. 1986. The SSC provided
that the State pay lO°'o of the remedial action costs and assume responsibility for all of the operation and
maintenance (Q&M) requirements, as required by CERCLA.
Between October 1985 and March 1986. USAGE held three open bid periods on the remedial action construction
contract. The contract award was delayed primarily because of difficulties in implementing the previously untested
EPA Off-Site Disposal Policy (Procedures for Planning and Implementing Off-Site Response Actions. EPA
Memorandum, May 6. 1985). USAGE awarded a contract on July 17, 1986. to U.S. Cleanup Contractors. The
contractor identified an off-site disposal facility in compliance with the Superrund off-site policy.
Remedial Construction Activities
On August 18, 1986. EPA held a public meeting and gave a presentation to the City of Wasteville Toxics
Commission on pending cleanup activities. EPA issued a Notice to Proceed to the contractor on August 20, 1986.
After thorough review, the final work plan was approved October 15. 1986. On-site activities (specifically,
background air monitoring and site mobilization) began on October 5, 1986. On November 20, 1986, EPA held a
well-attended on-site press conference.
Excavation of contaminated soil began October 5, 1986, and the first off-site shipment of contaminated soil
occurred December 2. 1986. During the on-site stockpiling of material in October and November of 1986. the
contractor discovered the first of many unanticipated subsurface objects. These items included concrete foundations
and footings, gas cylinders, drums, and sewer lines.
The contractor sampled all material discovered to identify any hazardous materials, except for concrete which was
taken directly to the approved disposal facility. Any material found to contain lead at levels greater than 500 ppm
or any RCRA priority pollutant at levels higher than de minimus levels was also removed to the approved facility.
In all. the contractor removed approximately 11,000 tons of contaminated material, over twice the amount originally
estimated in the ROD. Following the removal of all contaminated soil and debris, the site was covered with three
feet of clean fill material, regraded to ensure proper drainage, and hydro seeded to prevent soil erosion.
The contractor completed remedial construction in early May 1987 and EPA, USAGE, and DHS held a pre-final
inspection on May 27, 1987. Establishing vegetation required an additional 60 days before the construction contract
could be termed completed. On July 26. 1987. USAGE conducted the final inspection in conjunction with State and
EPA representatives and determined that the remedial action had been successfully executed.
i '']'' I ' !
On March 30. 1988. USAGE submitted a Remedial Action Report signifying successful completion of construction
activities.
Community Relations Activities
The water supply was the object of considerable public interest in Wasteville. As a result, the Region's community
relations staff conducted an active campaign to ensure that the residents were well-informed about the activities at
the site. Community relations activities included: public meetings, an on-site press conference, routine publication
of progress fact sheets, and a final close-out meeting and site tour when site construction activities were completed.
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Appendix C - Sample Final Close Out Report
III. DEMONSTRATION OF CLEANUP ACTIVITY QUALITY ASSURANCE AND QUALITY
CONTROL
EPA. the L'SACE. and the State reviewed the remedial action contract and construction for compliance with quality
assurance and quality control (QA.QC) protocols. Construction activities at the site were determined to be
consistent with the ROD and the RD plans and specifications.
The construction contractor adhered to the approved construction quality control plan (CQCP). The construction
quality assurance plan (CQAP) incorporated all USAGE and EPA requirements. All confirmatory inspections.
independent testing, audits, and evaluations of materials and workmanship were performed in accordance with the
construction drawings, technical specification and CQAP. Construction quality assurance was performed by the
USACE. The EPA RPM and State regulators visited the site approximately three times per month during
construction activities to review construction progress and evaluate and review the results of QA'QC activities.
Deviations or non-adherence to QA.'QC protocols, drawings, or specifications were properly documented and
resolved.
All procedures and protocol followed for groundwater, soil and air sample analysis during the remedial action are
well documented. Only EPA analytical methods, or where no EPA methods existed, other Federally approved
methods were used (such as National Institute of Occupational Safety and Health methods for the analysis of
airborne contaminants). The soil and groundwater samples were analyzed by a laboratory under contract to the
Contract Laboratory Program (CLP). The EPA Field Investigation Team (FIT) and the EPA Environmental
Monitoring Systems Laboratory sampled and analyzed the air samples. EPA, USACE. and the State determined
that analytical results are accurate to the degree need to assure satisfactory execution of the RA.
IV. MONITORING RESULTS
The contract for the remedial action detailed a rigorous sampling and analysis program for the remedial action.
Specifically, sampling was required and implemented to: 1) protect the off-site public. 2) protect on-site workers.
and 3) confirm compliance with RA objectives. The sampling program included:
Daily perimeter air monitoring for total particulates, respirable particulates. total lead;
Daily personnel air sampling of exclusion-zone workers for copper, lead, and zinc;
Random instantaneous on-site and perimeter air sampling for total particulates:
Confirmatory soil sample(s) for all site contaminants, wherever additional contamination was suspected or
known to occur;
Complete sampling of backfill soil for all site contaminants; and
Ground-water samples for all site contaminants.
The contractor excavated and removed additional soil to the approved disposal facility wherever lead was detected
at a level above 500 ppm or any site contaminant was detected at a level higher than acceptable risk standards.
Overall, contaminated soil was excavated to depths greater than one foot from over 50 percent of the 2.3-acre site.
resulting in the removal of 11,000 cubic yards of material. Subsequent sampling confirmed that this quantity- was
sufficient to ensure that all contamination was removed from the site, and that the cleanup level for lead of s'oO ppm
specified in the ROD was achieved.
The Final Technical Report and Contractor Quality Control Summary Report contains documentation of the
complete results and accuracy of the confirmatory sampling program.
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Appendix C - Sample Final Close Out Report
V. SUMMARY OF OPERATION AND MAINTENANCE
The cleanup of the site complies with the "clean closure" requirements, consistent with the Resource Conservation
and Recovery Act of 1976. as amended. 40 CFR section 264.111. Site operation and maintenance (O&M) acmuies
to be performed include annual inspections of the site to ensure erosion control measures are effective, routine
mowing, and maintenance of the perimeter fence. Per the SSC, the State has assumed all responsibility for O&M.
VI. SUMMARY OF REMEDIATION COSfS
The originalcost estimate to implement the remedial action described in the amended ROD (10/4 85) was S2
million. The construction contract award amount was S1.95 million. Due to the 21 above noted change orders, the
final remedial action cost totaled S3.991.315. This cost increase is attributable to the discovery of many
unanticipated subsurface objects. A breakdown of the final costs can be found in the Remedial Action Report for
this project. The ROD estimated annual maintenance costs, of SI0,000, as compared with State actual costs of
SI 3.000.
VII. PROTECTIVENESS
This site meets all the site completion requirements as specified in OSWER Directive 9320.2-09-A-P, Close Out
Procedures for National Priorities List Sites. Specifically, confirmatory sampling verifies that the site has achieved
the ROD cleanup objective, that all lead has been removed to levels below 500 ppm, and that all cleanup actions
specified in the ROD have been implemented. Furthermore. EPA has removed all other contamination detected to
acceptable risk levels. Confirmatory ground-water sampling and backfilling the site with clean soil provide further
assurance that the site no longer poses any threats to human health or the environment. The only remaining activity
to be performed is O&M that the State has guaranteed. A bibliography of all reports relevant to the completion of
this site under the Superfund program is attached.
VIII. FIVE-YEAR REVIEW
As a matter of policy. EPA has decided to conduct a Five-Year review at this site. The review will be conducted
pursuant to CERCLA 121 (c) and as provided in the current guidance on Five Year Reviews: OSWER Directive
9355.7-02. Structure and Components of Five-Year Reviews, May 23. 1991, OSWER Directive 9355.702A.
Supplemental Five-Year Review Guidance. July 26. 1994. and the Second Supplemental Five-Year Review
Guidance. December 21. 1995. The Five-Year Review Report will be completed by October 1996.
i ,:
i
Approved By:
Regional Administator
IX. BIBLIOGRAPHY
[Include complete citations of all documents relevant to the cleanup of the site.]
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Appendix D - NOTICES OF INTENT To DELETE
D-l
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r/it'.7ef \ottce nt Intent to Delete Samples are based on an actual Superfund sues, hut some information has ^cc
altered for illustrative purposes.
Cement and format of an actual \otice of Intent to Delete may vary from these samples due to considerations
such as project lead and support roles, availability oj information, and site-specific conditions.
For more ahout preparing a \otice of Intent to Delete, refer to OSH'ER Directive 9320 2-9A-P. "Close Out
Procedures for \attonal Priorities List Sites. " EPA 540-R-Q8-OI6.
D-2
j|IIL._ jj jlJiik' J_...^iiLJiJu. jji!klij '___ 1 jii/_
iiiinJiikiJ. 'n,.!!' ' !, 1, n,
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Appendix D - Sample Notices Of Intent To Delete
ENVIRONMENTAL PROTECTION AGENCY
40 CFR Part 300
National Oil and Hazardous Substances Pollution Contingency Plan: National Priorities List
AGENCY: Environmental Protection Agency.
ACTION: Notice of Intent to Delete the Aztec Mountain Mine from the National Priorities List.
SUMMARY: The Environmental Protection Agency (EPA) Region 10 announces the intent to delete the Aztec
Mountain Mine site ("the site") from the National Priorities List (NPL) and requests public comment on this
proposed action. The NPL constitutes Appendix B of 40 CFR part 300 which is the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP), which EPA promulgated pursuant to section 105 of the
Comprehensive Environmental Response. Compensation and Liability Act (CERCLA) of 1980, as amended. EPA
and the State of Washington Department of Ecology (Ecology) have determined that the remedial action for the site
has been successfully executed.
DATE: Comments concerning the proposed deletion of this Site from the NPL may be submitted on or before
(INSERT DATE 30 DAYS FROM PUBLICATION IN THE FEDERAL REGISTER).
ADDRESSES: Comments may be mailed to: [RPM Name], U.S. Environmental Protection Agency. Region ,
[Street Address], [Mailstop], [City, State Zip Code]
Comprehensive information on this site is available through the Region 10 public docket which is available for
viewing by appointment only. Appointments for copies of the background information from the Regional public
docket should be directed to the EPA Region 10 Docket office at the following address: SUPERFUND Records
Center U.S. Environmental Protection Agency, Region 10. [Street Address], [Mailstop]. [City, State Zip Code]
The deletion docket is also available for viewing at the following location:
FOR FURTHER INFORMATION CONTACT: [RPM Name], U.S. Environmental Protection Agency, [Street
Address], [Mailstop]. [City, State Zip Code], [(XXX) XXX-XXXX or 1-800-XXX-XXXX.]
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Introduction
II. NPL Deletion Criteria
III. Deletion Procedures
IV. Basis of Intended Site Deletion
I. Introduction
The U.S. Environmental Protection Agency (EPA) Region 10 announces its intent to delete the Aztec Mountain
Mine site in [County. State], from the National Priorities List (NPL) and requests public comment on this proposed
action. The NPL constitutes Appendix B of 40 CFR part 300 which is the Oil and Hazardous Substances Pollution
Contingency Plan (NCP). which EPA promulgated pursuant to section 105 of the Comprehensive Environmental
Response. Compensation and Liability Act (CERCLA) of 1980. as amended. EPA identifies sites that appear to
present a significant risk to public health, welfare, or the environment and maintains the NPL as the list of these
sites. EPA and the State of Washington Department of Ecology (Ecology) have determined that the remedial action
D-3
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Appendix D - Sample Notices Of Intent To Delete
for the site has been successfully executed.
EPA will accept comments on the proposal to delete this site for thirty (30) days after publication of this document
in Federal Register. '.
Section II of this document explains the criteria for deleting sites from the NPL. Section III discusses the procedures
EPA is using for this action. Section IV discusses the Aztec Mountain Mine site and explains how the site meets the
deletion criteria.
II. NPL Deletion Criteria
Section 300.425(e)(l) of the NCP provides that releases may be deleted from, or recategorized on the NPL where no
further response is appropriate. In making a determination to delete a release from the NPL. EPA shall consider, in
consultation with the state, whether any of the following criteria have been met:
(i) Responsible parties or other persons have implemented all appropriate response actions required: or
,: ,.!:! , , : I ; ' J ' 1 ' ': !' I ;
(11) All appropriate Fund-financed responses under CERCLA have been implemented, and no further response
action by responsible parties is appropriate: or
(iii) The Remedial Investigation has shown that the release poses no significant threat to public health or the
environment and. therefore, remedial measures are not appropriate.
Even if a site is deleted from the NPL. where hazardous substances, pollutants, or contaminants remain at the site
above levels that allow for unlimited use and restricted exposure, EPA's policy is that a subsequent review of the
site will be conducted at least every five years after the initiation of the remedial action at the site to ensure that the
site remains protective of public health and the environment. If new information becomes available which indicates
a need for further action. EPA may initiate additional remedial actions. Whenever there is a significant release from
a deleted site from the NPL. the site may be restored to the NPL without application of the Hazard Ranking System.
In the case of this site, the selected remedy is protective of human health and the environment. Consistent with the
State Superfund Contract. Ecology has agreed to take over operation and maintenance of the site and conduct an
annual inspection. EPA has conducted the first five-year review of the final remedy, and will also perform future
five-year reviews.
III. Deletion Procedures
! f
The following procedures were used for the intended deletion of this site: (1) All appropriate response under
CERCLA has been implemented and no further action by EPA is appropriate; (2) [State] has concurred with the
proposed deletion decision: (3) a notice has been published in the local newspapers and has been distributed to
appropriate federal, state, and local officials and other interested parties announcing the commencement of a 30-day
public comment period on EPA's Notice of Intent to Delete: and (4) all relevant documents have been made
available in the local site information repositories.
Deletion of the site from the NPL does not itself create, alter, or revoke any individual's rights or obligations. The
NPL is designed primarily for informational purposes and to assist Agency management. As mentioned in section
II of this notice. Sec. 300.425(e)(3) of the NCP states that the deletion of a site from the NPL does not preclude
"eligibility for future response actions.
For deletion of this site. EPA's Regional Office will accept and evaluate public comments on EPA's Notice of Intent
to Delete before making a final decision to delete. If necessary, the Agency will prepare a Responsiveness
Summary to address any significant public comments received.
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Appendix D - Sample Notices Of Intent To Delete
A deletion occurs when the Regional Administrator places a final notice in the Federal Register. GeneralK. the
NPL will reflect deletions in the final update following the Notice. Public notices and copies of the Responsiveness
Summary will be made available to local residents by the Regional Office.
IV. Basis of Intended Site Deletion
The following site summary provides the Agency's rationale for the proposal to delete this site from the NPL.
Site Background and History
Aztec Mountain Mine is an abandoned heap-leach mining operation located approximately six air miles northwest
of Greenville, in Western County, Washington. The site consists of five acres of range land on a 358-acre tract of
privately owned land. The site was placed on the NPL in 1984 due to concerns about a cyanide-contaminated
leachate pond, saturated mine tailings, and the potential for arsenic and cyanide contamination of the regional
ground water aquifer.
The risk assessment identified arsenic and cyanide as the primary contaminants of concern. The Remedial
Investigation (RI) identified and evaluated three potential sources of contaminants at the site: the heap leach pile.
the unprocessed rock, and the mine drainage water. Potential exposure pathways for contaminants were identified
as: On- site soils, on-site surface water, on-site ground water in a shallow aquifer, and off-site ground water in the
region. During the RI. the highest arsenic levels found were in the mined material (1080 mg/kg) and in the water
from a stock water tank (95 up/1). Both arsenic and cyanide were also found in the perched shallow aquifer just at
the edge of the heap leach pile.
The Feasibility Study screened twenty-three various methods of cleaning up the site. From this list, eight
alternatives were developed and evaluated against criteria listed in the NCP. Alternatives ranged from capping
on-site to treatment and off-site disposal.
Response Actions
The Record of Decision (ROD) for Aztec Mountain Mine was signed on March 27, 1990, and included a number of
construction elements to implement the Remedial Action. In October 1994, EPA completed an Explanation of
Significant Differences (ESD) to document changes in the Remedial Action due to unforeseen conditions
encountered at the site during implementation of the selected remedy. The remedial action at the site ultimately
included:
Consolidating and contouring contaminated mine waste overburden and tailings,
Covering and capping the site with a soil and clay cap,
-Fencing the site to protect the cap and allow seeded grass cover to develop,
Closure of the mine entrance and diversion of the mine drainage so that it flows away from the site, and
Deed restrictions on property to protect the cap.
Construction was completed during 1992 and the deed restrictions were finally obtained in December 1996.
The five-year review inspection occurred on May 27. 1997. and determined that the remedial objectives have been
achieved. The constructed remedy is performing as designed and is controlling the risks to human health and the
environment as specified in the ROD and ESD. The cap was in excellent shape with no evidence of subsidence,
erosion, or animal burrows. The grass cover is well established and provides thorough coverage of the cap; minimal
weeds and woody vegetation were growing on the cap. The mine entrance and mine vent were both closed and
covered with rocks.
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Appendix D - Sample Notices Of Intent To Delete
Cleanup Standards
The remedial action cleanup activities at the Aztec Mountain Mine site are consistent with the objectives of the NCP
and will provide protection to human health and the environment. The cleanup standards for the heap leach pile and
mine dump materials and the surrounding soils are 200 mg "kg for arsenic and 95 mgVkg for total cyanide.
According to the data obtained during the construction work, the cyanide in the soils is below detection (0.5 mg kg).
and the concentrations of arsenic that remain in the areas that were cleaned up are less than 100 mg'kg. Risks at the
site have been reduced below the Hazard Index of 1.0 or health based levels: and for arsenic, a human carcinogen.
the cancer risk factor has been reduced below one in ten thousand.
The major source of contaminants identified in the ROD, the rock material from the mining operations (heap and
mine dump), has been addressed. The mine drainage was reevaluated in the Explanation of Significant Differences
and it was determined that the mine drainage did not pose an ecological threat. According to the risk assessment
arid amended risk assessment, the inhalation and ingestion of the contaminated soils were the major routes of
exposure. The arsenic-laden waste rock from the mine was contained and capped. The cleanup also reduced the
impacts to the ground water by diverting the run-on water away from the capped mine waste and by limiting
potential leachate generation.
Operation and Maintenance
The site is designed to require very little maintenance. The area is remote and the semi-arid climatic conditions
suggest that only minimal maintenance is expected! The mined rock material under the cover is not expected to
settle which is often the major cause of cap disturbance. The rainfall is low with an annual average precipitation of
11 inches/year which is primarily as snow and spring rain. It is expected that Ecology personnel, per the State
Superfund Contract, will be able to provide the annual maintenance with a minimal amount of work.
Five-Year Review
The Comprehensive Environmental Response, Compensation and Liability Act (CERCLA or Superfund) requires a
five-year review of all sites with hazardous substances remaining above the health-based levels for unrestricted use
of the site. Since the cleanup of the Aztec Mountain Mine site utilized containment of the hazardous materials as
the method to reduce the risk, the five-year review process will be used to insure that the cap is still intact and
blocking exposure pathways for human health and the environment. As indicated above, EPA has conducted the
first statutory five-year review and has determined that the remedy selected for Aztec Mountain Mine remains
protective of human health and the environment. For future five-year reviews, EPA will review Ecology's annual
reports on the operation and maintenance at the site and perform a five-year review inspection. EPA plans to
complete the next Five-Year Review prior to May 27. 2002.
' I , ' I : I ''..
Community Involvement
EPA published its Community Relations Plan in December 1987, after interviews with local residents and officials.
An information repository was established at the County Courthouse and all of the documents used to make the
decision were placed there before the final Record of Decision was signed. All other reports and fact sheets were
sent to the repository as they were completed. Those individuals on the mailing list were informed by fact sheet
prior to construction activities on-site. No public meetings have been requested thus far.
Applicable Deletion Criteria
One of the three criteria for site deletion specifies that EPA may delete a site from the NPL if "all appropriate
Fund-financed response under CERCLA has been implemented, and no further response action by responsible
parties is appropriate." 40 CFR 300.425(e)(l)(ii). EPA, with the concurrence of the State of Washington through
the Department of Ecology, believes that this criterion for deletion has been met. Subsequently. EPA is proposing
deletion of this site from the NPL. Documents supporting this action are available from the docket.
!' ! '' ' ! ' ' I ;;"'
, D-6
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Appendix D - Sample Notices Of Intent To Delete
State Concurrence
In a letter dated June 17. 1997. the Washington Depanment of Ecology concurs with the proposed deletion of the
Aztec Mountain Mine Superfund site from the NPL.
Dated: July 17. 1997.
John Doe. Actina Regional Administrator. U.S. EPA Reaion 10.
D-7
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" Ilillillll", I Ill1
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Appendix D - Sample Notices Of Intent To Delete
ENVIRONMENTAL PROTECTION AGENCY
40 CFR Part 300
National Oil and Hazardous Substances Pollution Contingency Plan National Priorities List
AGENCY: Environmental Protection Agency (EPA).
ACTION: Notice of intent to delete the SF Industries Landfill Site from the National Priorities List
SUMMARY: The Environmental Protection Agency (EPA) Region II announces its intent to delete the SF
Industries Landfill Site (Site) from the National Priorities List (NPL) and requests public comment on this action.
The NPL constitutes Appendix B of 40 CFR part 300 which is the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP), which EPA promulgated pursuant to section 105 of the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA), as amended, 42 U.S.C 9601 et seq. EPA and the
New Jersey Department of Environmental Protection (NJDEP) have determined that the Site poses no significant
threat to public health or the environment and, therefore, further remedial measures pursuant to CERCLA are not
appropriate.
DATES: Comments concerning the proposed deletion of this Site for the NPL may be submitted on or before
[Insert date 30 days from publication in the Federal Register.]
ADDRESSES: Comments may be mailed to: [RPM Name], Remedial Project Manager, U.S. Environmental
Protection Agency, Region 2. [Mailcode] [Street, City, State Zip Code]
The deletion docket and other comprehensive information on this Site is available for viewing at the SF Industries
Landfill Site information repository at the following location: Town of Terraville Municipal Building, [Street
Address, City, State Zip Code] (XXX) XXX-XXXX.
FOR FURTHER INFORMATION CONTACT: [RPM Name], Remedial Project Manager. U.S. Environmental
Protection Agency. Region [ ], [Mailcode] [Street, City, State Zip Code], (XXX) XXX~XXXX.
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Introduction
II. NPL Deletion Criteria
III. Deletion Procedures
IV. Basis for Intended Site Deletion
I. Introduction
EPA Region II announces its intent to delete the SF Industries Landfill Site, which is located in Terraville. Terra
County New Jersey, from the NPL. which constitutes Appendix B of the NCP. 40 CFR part 300, and requests
comments on this deletion. EPA identifies sites that appear to present a significant risk to public health, welfare, or
the environment and maintains the NPL as the list of these sites. As described in Sec. 300.425(e)(3) of the NCP.
sites deleted from the NPL remain eligible for remedial actions in the unlikely event that conditions at the site
warrant such action.
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Appendix D - Sample Notices Of Intent To Delete
EPA will accept comments on the proposal to delete this Site for thirty (30) days after publication of this document
in the Federal Register.
Section II of this notice explains the criteria for deleting sites from the NPL. Section III discusses the procedures
that EPA is using for this action. Section IV discusses the Site and explains how the Site meets the deletion criteria
II. NPL Deletion Criteria
Section 300.425(e) of the NCP provides that sites may be deleted from the NPL where no further response is
appropriate. In making a determination to delete a site from the NPL. EPA in consultation with NJDEP. shall
consider whether any of the following criteria have been met:
(i) Responsible parties or other parties have implemented all appropriate response actions required: or
(ii) All appropriate responses under CERCLA have been implemented and no further action by responsible
parties is appropriate; or
(iii) The remedial investigation has shown that the release of hazardous substances poses no significant threat to
public health or the environment and, therefore, remedial measures are not appropriate.
Even when a site is deleted from the NPL. where hazardous substances, pollutants, or contaminants remain at the
site above levels that allow for unlimited use and restricted exposure, EPA is required, by statute or policy, to
I1:,' ; "' , .| ' ' : - 1.1 H i , , i " "i'
conduct a subsequent review of the site at least every five years after the initiation of the remedial action at the site
to ensure that the site remains protective of public health and the environment. If new information becomes
available which indicates a need for further action. EPA may initiate additional remedial actions. Whenever there is
a significant release from a deleted site from the NPL, the site may be restored to the NPL without application of the
Hazard Ranking System.
III. Deletion Procedures
The following procedures were used for the intended deletion of this Site: (1) EPA Region II issued a Record of
Decision (ROD) which documented the remedial acjtion activities; (2) all appropriate responses under CERCLA
have been implemented as documented in the Final Close-Out Report dated September 25. 1997: (3) the NJDEP
concurred with the proposed deletion; (4) a notice has been published in the local newspaper and has been
distributed to appropriate Federal, State and local officials and other interested parties announcing the
commencement of a 30-day public comment period on EPA's Notice of Intent to Delete: and (5) all relevant
documents have been made available for public review in the local Site information repository.
Deletion of sites from the NPL does not itself create, alter, or revoke any individual's rights or obligations. The NPL
is designed primarily for informational purposes and to assist Agency management of Superfund sites. As
mentioned in section II of this document. Sec. 300.425 (e)(3) of the NCP states that the deletion of a site from the
NPL does not preclude eligibility for future response actions.
For deletion of this Site. EPA's Regional Office will accept and evaluate public comments before making a final
decision to delete. If necessary, the Agency will prepare a Responsiveness Summary to address any significant
public comments received.
A deletion occurs when the Regional Administrator places a final notice in the Federal Register. Generally, the NPL
will reflect deletions in the final update following the notice. Public notices and copies of the Responsiveness
Summary will be made available to local residents bv the Regional Office.
D-10
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Appendix D - Sample Notices Of Intent To Delete
IV. Basis for Intended Site Deletion
The following summary provides the Agency's rationale for the proposal to delete this Site from the NPL.
Site Background and History
The Site is located along New Road, approximately one-half mile northwest of U.S. Route 1. in Terra County, New
Jersey. The landfill occupies an area of approximately 68 acres. A significant portion of the land surrounding the
Site is wooded. It is owned by SF Industries (SF1) of Terraville. SFI(Site). which operated for more than 20 years
as a solid waste landfill, accepted municipal refuse, pesticides, chemical wastes and hazardous wastes.
In June 1980. EPA conducted an investigation of the Site. The sampling results revealed elevated levels of volatile
organic compounds in several on-site monitoring wells, as well as on-site surface water sampling locations.
The data from this sampling effort resulted in the Site being proposed for the Superfund NPL on December 30.
1982, and the Site was included on the NPL on September 8. 1983.
In April 1982. SFI and EPA entered into an agreement concerning the remedial efforts to be performed. The
agreement was in the form of a Resource Conservation and Recovery Act (RCRA) Administrative Order on Consent
(Index No. RCRA-7003XXXXX) which outlined the remedial approach.
Response Actions
The remedial action activities, initiated in February 1983, consisted of the construction of a leachate
collection/treatment system, slurry wall, multi-layer cap and gas venting system. The remedial action was completed
in September 1985. EPA issued a Record of Decision on September 30, 1987, which affirmed that the remedial
action undertaken was consistent with CERCLA. as amended, and to the extent practicable, the NCP.
Cleanup Goals
The May 1993 EPA-approved Post-Remedial Environmental Monitoring Program (PREMP) Work Plan was
designed to assess the effectiveness of the completed Remedial Action and evaluate off-Site migration of
contaminants. The PREMP was conducted from May 1993 to January 1994 and included the collection of
twenty-seven groundwater samples, thirty-four soil samples, eight surface water samples and twelve sediment
samples. Post-remedial environmental monitoring indicated that volatile organic compounds (.VOCs), semi-VOCs.
and inorganic contaminant concentrations have decreased in surface water, groundwater, sediment and soil samples.
Therefore, the results from this investigation document the effectiveness of the remedy and indicate there is no
significant off-Site migration of contaminants. Although minimal groundwater contamination was detected in the
southeastern portion of the Site in the area of monitoring well R-10, regulating the leachate collection system to
induce inward gradients appears to have significantly reduced contamination. As part of the overall Site Operation
and Maintenance Plan activities. EPA has required SFI to periodically evaluate the effectiveness of the leachate
collection system and routinely monitor well R-10 and downgradient surface water quality to ensure the
effectiveness of the remedy. The multi-layered cap has effectively reduced infiltration, as indicated by the
significant reduction in the amount of leachate generation over time.
The leachate collection system and slurry wall have reduced leachate levels within the landfill, resulting in inward
hydraulic gradients over much of the Site. Historically, leachate was pre-treated to reduce iron concentrations in the
effluent. SFI has been notified by the Sunny Brook Regional Sewage Authority (SBRSA) of a change in SFI's
license classification from a Class 1 to Restricted Industrial User. SFI is no longer required to treat for iron. SFI
discharges directly to the sanitary sewer line while still monitoring monthly per the requirements of the license
issued by the SBRSA. Also, the gas venting system is operating in accordance with the existing NJDEP Air
Pollution Control Program permit and a series of perimeter gas monitoring probes are periodically monitored.
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Appendix D - Sample Notices Of Intent To Delete
The cleanup of the Site was performed in compliance with "clean closure" requirements and consistent with the
Resource Conservation and Recovery Act of 1976. as amended. CERCLA. as amended, and to the extent
practicable, the NCP.
Operation and Maintenance
Pursuant to the 1989 Administrative Order. SFI has committed to performing Operation and Maintenance (O&M)
activities at the Site. In August 1997. EPA approved the Site O&M Plan, which defines the long-term O&M
activities for the Site. The 6&M Plan addresses those activities required for controlling the groundwater gradient in
the area of monitoring well R-10, maintaining the effectiveness of the response action, and monitoring Site
conditions to determine the occurrence of any environmental threat. O&M activities include periodic inspections
and monitoring, certain institutional controls, periodic leachate collection an3 treatment measures! or any other
activities necessary1 to ensure the continued protection of public health and the environment.
Project Managers from EPA and SFI conducted a Five-Year Review on September 12, 1995. The purpose of this
inspection was to determine the current status of the Site and the adequacy of the Site cleanup and that the remedial
action remains protective of human health and the environment. The remedial action, completed since September
1985. remains in place and is operating and functioning as designed, and the site is protective of human health and
the environment._Another Five-Year review will be completed by September 2000.
Major Community Involvement Activities
A public availability session was conducted by EPA in August 1987 to discuss with the community the remedial
actions implemented and the post-remedial environmental monitoring program. Public comments were received and
addressed in the Responsiveness Summary portion of the September 30, 1987, Record of Decision.
Applicable Deletion Criteria/State Concurrence
All the completion requirements for this Site have been met as described in the Final Close-Out Report (COR) dated
September 25. 1997. The Final COR documents the effectiveness of the post-remedial environmental monitoring
and that the remedy (slurry wall, multi-layered cap, leachate collection system, gas venting system and installation
of a Site security fence) remains protective. Site O&M activities will be performed by SFI, with EPA oversight.
In a letter dated October 21. 1997, NJDEP concurred with EPA that all appropriate Fund-financed responses under
CERCLA at the Site have been completed, and that no further construction activities by responsible parties is
necessary except for operation and maintenance requirements. EPA will be providing oversight of all operation and
maintenance activities. Consequently, EPA is proposing deletion of this Site from the NPL. Documents supporting
this action are available in the docket.
Dated; November 12, 1997.
John Doe.
Acting Regional Administrator.
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Appendix E - LOCAL NOTICE OF INTENT To DELETE
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This heal Sotice Sample is based on an actual Supc_'-twid tiu: hut some information has been altered tor
illustrative purposes
Content and format of an actual local \otice of Intent to Delete may vary from this sample due to considerations
such as project lead and support roles, availability of information, and site-specific conditions.
For more about preparing a local \otice. refer to OSU'ER Directive 9320.2-9A-P, "Close Out Procedures for
\ational Priorities List Sites. " EPA 540-R-9S-016
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Appendix E - Sample Local Notice of Intent to Delete
The U.S. Environmental Protection Agencv (EPA) announces the deletion of the ABC Recvcling Co. site in
Wasteland. Idaho, from the National Priorities List (NPL). which is Appendix B of the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP). EPA requests comments on this deletion. EPA and the State have
determined that all appropriate Fund-financed responses under the Comprehensive Environmental Response.
Compensation and Liability Act (CERCLA). as amended, have been implemented and that no further cleanup b>
responsible panics is appropriate. Moreover. EPA and the State have determined that remedial actions conducted at
the site to date have been protective of public health, welfare, and the environment. However, this deletion does not
preclude future actions under Superfund.
The public is invited to comment on the proposed decision to delete this site from the NPL. The public comment
period will begin on January 1. 1999. and extend for 30 days. Written comments must be postmarked no later than
January 30. 1999. and should be addressed to:
Name: Jane Doe
Address: U.S. Environmental Protection Agency, Region 10
Region 10 Docket Office
1200 Sixth Avenue
Seattle. WA 98101
Oral comments will also be received through this date and should be directed to Susan Johnson at (206) 555-1 111.
A local repository has been established to provide detailed information concerning this site at the following address:
Name: John Doe
Address: Local Superfund Information Repository
111 Main Street
Wasteland. ID 84601
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Appendix F - NOTICE OF DELETION
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These Soiice ot Deletion Sample is hascd i>n an actual Supcrjund site, but some information has heen altered /< >r
illustrative purposes.
Content and format of an actual Sotice of Deletion may vary from this sample due to considerations such as
pro/eel lead and support roles, availability of information, and site-specific conditions.
For more about preparing a Sotice of Deletion, refer to OSll'ER Directive 9320.2-9A-P. "Close Out Procedures
for National Priorities List Sites. " EPA 540-R-QS-Olfi,
F-2
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Appendix F - Sample Notice of Deletion
ENVIRONMENTAL PROTECTION AGENCY
40 CFR Part 300
National Oil and Hazardous Substances Pollution Contingency Plan; National Priorities List Update
AGENCY: Environmental Protection Agency.
ACTION: Notice of deletion of the SF Industries Landfill Superfund site from the National Priorities List.
SUMMARY: The U.S. Environmental Protection Agency (EPA) announces the deletion of the SF Industries
Landfill Site in [City. County. State] from the National Priorities List (NPL). The NPL is Appendix B of 40 CFR
part 300 which is the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). which EPA
promulgated pursuant to section 105 of the Comprehensive Environmental Response. Compensation, and Liability
Act of 1980 (CERCLA). as amended.. EPA and the State of New Jersey have determined that the Site poses no
significant threat to public health or the environment and. therefore, no further remedial measures pursuant to
CERCLA are appropriate.
EFFECTIVE DATE: (INSERT DATE NOTICE IS PUBLISHED).
FOR FURTHER INFORMATION CONTACT: [RPM Name], Remedial Project Manager. U.S. Environmental
Protection-Agency. Region .[Street Address. Mailcode. City. State Zip Code] (XXX)XXX-XXXX.
SUPPLEMENTARY INFORMATION: The site to be deleted from the NPL is:
SF Industries Landfill Site. Terraville, Terra County. New Jersey.
A Notice of Intent to Delete for this Site was published in the Federal Register on November 20. 1997 (62 FR
60058). The closing date for comments on the Notice of Intent to Delete was December 22. 1997. No comments
were received therefore, EPA has not prepared a Responsiveness Summary.
EPA identifies sites that appear to present a significant risk to public health, welfare, or the environment and it
maintains the NPL as the list of those sites. Any site deleted from the NPL remains eligible for Fund-financed
remedial actions in the unlikely event that conditions at the site warrant such action. Section 300.425(e)(3) of the
NCP states that Fund-financed actions may be taken at sites deleted from the NPL. Deletion of a site from the NPL
does not affect responsible party liability or impede agency efforts to recover costs associated with response efforts.
List of Subjects in 40 CFR Part 300
Environmental protection. Air pollution control. Chemicals. Hazardous substances. Hazardous waste.
Intergovernmental relations. Penalties. Reporting and record keeping requirements. Superfund. Water pollution
control, and Water supply.
Dated: February 2, 1998.
John Doe,
Acting Regional Administrator.
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Appendix F - Sample Notice of Deletion
For the reasons set out in the preamble. 40 CFR pan 300 is amended as follows:
PART 300-[ AM ENDED]
1 The authority citation for part 300 continues to read as follows:
Authority; 42 C. S.C. 9601-9657: 33 U.S.C. 1321(c)(2): E.O. 12777. 56 FR 54757. 3CFR. 1991 Comp.. p.35,1: E.6.
12580. 52 FR 2923. 3 CFR. 1987 Comp.. p.193.
Appendix B[Amended]
2. Table 1 of Appendix B to part 300 is amended by removing the entry for the SF Industries Landfill site in
Terraville. Terra Countv. New Jersey.
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Appendix G - PARTIAL SITE DELETION DATA
COLLECTION FORM
G-l
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Appendix G - Partial Site Deletion Data Collection Form
Partial NPL Site Deletion Data Collection Form
(Version 1.0, March 1996)
Site Name:
CERCLIS ID*:
Name of Deleted Portion:
Region: State:.
This form should be completed for all proposed
deletions of portions of NPL sites. Include this form as
part of the Notice of Intent to Delete (NOID) submitted
to EPA Headquarters.
State, Tribal, and Site Identification Center
U.S. Environmental Protection Agency
G-3
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Appendix G - Partial Site Deletion Data Collection Form
Partial NPL Site Deletion Data Collection Form
General Form Instructions
The Partial NPL Site Deletion Data Collection Form is designed to standardize partial site deletion information for
input into the Superfund NPL Assessment Program (SNAP) data base. This data base serves as a repository for
general information about NPL sites and is used to respond to queries about NPL sites from a variety of sources
including the general public, the media, other government agencies, and members of Congress. The primary source
materials for completing this form are the Notice of Intent for Partial Deletion (NOID). site information supportins
the decision to delete this portion of the site, and electronic locational data. Requirements for submitting electronic
locational data are included in EPA's Locational Data Policy.
As you complete the Partial NPL Site Deletion Data Collection Form, keep the following points in mind.
» A map clearly showing the entire site and that portion to be deleted (including scale);
» Site coordinates (latitude and longitude) for at least three reference points on the map.
» Landmarks, such as roads, water bodies, waste operations, or residential areas (these facilitate reading the
map).
" Contacts for both the partial deletion decision and the electronic data.
The above materials are to be provided in both hard and electronic copy. Electronic files in ARC/INFO. Maplnfo.
GIS+, or those mentioned below are acceptable. If mapping information is not available in these packages, the
Center should be contacted to determine how to submit the electronic information.
Electronic files submitted with the partial deletion package should:
Include all vector / raster layers for the site necessary to recreate a map;
» Include all attribute information associated with the data layers;
» Be delivered in one of the following formats:
1. ARC/INFO native or export (.EOO) format,
2. ArcView shape files
3. Maplnfo native Maplnfo Interchange Format (MIF), Maplnfo Boundary Interchange File (MBI), or Maplnfo
Map Interchange Format (MMI)
4. GIS-1- native
5. AutoCAD DXF format
6. ASCII delimited file (include data structure and format for recreation)
If electronic files are to be delivered in a format other than one of those identified in the list above, obtain prior
approval from EPA Headquarters. To facilitate the integration of data into these systems it is important that coding
of geographic coordinates and associated attributes be standardized.
The site map must be dated. The date is to reflect the delineation of the boundaries of the site as of the date
prepared, including the portion to be deleted. Geographic coordinates of points describing a specific object (e.g..
operable unit or portion of the site to be deleted) should be included.
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Appendix G - Partial Site Deletion Data Collection Form
Additional Information
A printout of locational data fields for each data layer in the electronic files should be provided with the electronic
files. The printout should include:
1. Projection of data - Map projections allow areas on the surface of the Earth (a spheroid) to be represented on
a map (a fiat surface) while minimizing distortion. This information is important because it represents the
1 geometric accuracy of the data and it is critical in determining; the measurement accuracy'.
,;; 2, Units of Measure - Map units are the units in which the coordinates of the spatial data represented in your
image are stored. They may be in kilometers, inches, feet, etc.
3. Projection Spheroid -Defines the shape of trie spheroid for calculating the transformation of coordinates from
;;(:;" a particular shape. "' " ' '"" ""' "
-' 4. Projection Zone (i.e. UTM 11 or State Plane Zone 1101 Maryland East) - identify' the map projection or
;;;; i coordinate system used in creating the map. Map projections allow areas on the surface of the Earth (a
spheroid) to be represented on a map (a flat surface).
5. Horizontal Datum - A datum is a set of parameters defining a coordinate system, and a set of control points
whose geornetric relationships are known, either through measurement or calculation.
6. False Northing ' False Easting - Any offset on the x and / or y axis applied to coordinates of the data.
7. Source - Describe the source of the geographic data used in creating the file.
1'" g. Source Icate - Map scale is the relationship between the dimensions of a map and the dimensions of the
Earth. It is usually expressed as a ratio between a distance on the map and a distance on the Earth, like
1:63.360.
9. Point-Line-Area - Predominant feature type of data (i.e., a point feature may represent a monitor well or a
benchmark, a line feature may represent a street, a polygon feature may represent a body of water or an area of
contamination).
' 10. Method of collection - Describe the methodology used in collecting the data (i.e.. scanning, manual.
digitizing, GPS. etc.).
11. Description and structure of data and anv attribute information.
Although not required, the following additional locational data is useful:
! ' i '
1. Accuracy value & unit
2. Xmin. Ymin, Xmax, Ymax of data layer
; ' ,,:;;;;,,' , ':;; ;;;;;: , , ' ,, ', "", i' ,; , , , ' :; ' , ; , "l|,;1:",; ' i ,;;, ', " ,;;,; i!
3. Precision of Data
4. Source Projection
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Appendix G - Partial Site Deletion Data Coliection Form
Partial Site Deletion Data Collection Form
Site Name: Pa£e =
1. Basic Identifying Information
1.1 Site Name (as entered in CERCLIS):
1.2 CERCLIS ID Number:
NPL Site Location: City: State:
County: Zip Code:
Name Given to Deleted Portion of the Site: .
Is this the first, second, third, etc. partial deletion at the site? (Enter the deletion number):
Name of Person(s) Completing Form:
Affiliation (agency / company): ;
Phone Number:
1.7 Name of Person(s) Completing Electronic Locational Data:
Affiliation (agency / company):
Phone Number:
1.8 BRIEF PARTIAL DELETION NARRATIVE. Provide a brief narrative describing the location
and extent of the release to be deleted. Include a discussion of the locational data and method(s) used
to delineate the deleted release. Attach additional pages if necessary.
G-7
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Appendix G - Partial Site Deletion Data Collection Form
-i
Partial Site Deletion Data Collection Form
Site Name: Paee =
'<9 ., PAR|?' REQUESTING DELETION. Which parry or parties requested the partial deletion (check all
that apply):
'' . ' i;l !' ,r '" i;i|ll ' . " 'il' . " ' " ; J1, ,'lh, ' ' | "Fill ''I' » ''I + / .' , ,; . i1 - jj i !'
Z Developer
I ;,l j : i*, - i^jf.' Property Owner Operator
:M ,,j i ', ' , l=i 13; City Municipality
:: ,': ,:,:/" .' v C1 '"State
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C Citizen aroup
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I! Other Interest group
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Appendix G - Partial Site Deletion Data Collection Form
Partial Site Deletion Data Collection Form
Site Name: Page =
2.2 Which Iocational data fields have been provided in both electronic and printout form? (Check onK the
fields that apply)
Electronic Printout
Z Z -Projection of data
Z Z Units of measure
[I Z Projection spheroid
Z . Z "" Projection zone (i.e.. UTM 11 or State Plane Zone 1101 Maryland East)
C Z Horizontal Datum
Z Z XShift ' YShift
Z Z Source
Z Z Source Scale
Z Z Point-Line-Area
Z Z Method of collection
Z Z Description and structure of data and any attribute information
Z Z Accuracy value and unit
D Z Xmin. Ymin, Xmax. Ymax of data layer
Z Z Precision of data
Z Z Source projection
Z Z Source units of measure
Z Z Source projection spheroid
Z Z Source horizontal datum
2.3 In what format(s) were the partial deletion electronic files submitted? (Check all that apply.)
Z ARC/INFO native or export (.EDO)
Z Arc View shape files
Z Maplnfo native Map Info Interchange Format (MIF)
Z Maplnfo Boundary Interchange (MBI)
Z Maplnfo Map Interchange (MMI)
Z GIS-r native
Z AutoCAD DXF
Z ASCII delimited file (include data structure and format for re-creation)
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Appendix G - Partial Site Deletion Data Collection Form
Partial Site Deletion Data Collection Form
: :, ,',; - ,,; Site Name: . ' ' Page =
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f-;" ';''::;,; ' |:":: -''2.4 $\VL SITE COORDINATES. Coordinates of the'entire site should be provided in the tbrm of polygons.
's^f' ' 'ly v :" ;'IJarfing with the northern-most coordinate and moving clockwise (in degrees, minutes, seconds, and
s '.'*, thousandths of seconds):
'ill "I!11 ...iiul" i|, 'It1! , ','.." . , .'','" "" > '! , i . ,. ' '' ,., '.' , ! ,,! ,t !.. * , i'..;i. ,' , I 'li!:,',1'1 ii 'lill'!' n]!!!11 '; : ' "
': i 1. _° '__. " North Latitude ' ° "' . . " West Longitude
', ;r , 2. ° ' ' . " North Latitude ° ' " ' f _^ _" West Longitude
' '; , < '> ' ' , ' i - ' ': I! , .' ;,i ',: .rt, ' J'l ' '| '' " *! " ' ' i I i- >, , "~&. f ''SflSii: || \ A '' ''I l.l ',/"
3". ° '" : ' . " North Latitude ° ' .' " West Longitude
"ilf'i, ,. ' 4. ° l'_ ._____"" North Latitude ' ' __° __; __^_ ^ '"" West Longitude "
:""-.' J"" ' "' ' " .'.- 5. ° ' . 1 " North Latitude ° ' . " West Lonaitude
?;:',;-.'.' i "," .> f?''''. 6. ° .'""^ "._ "'North "Latitude ""° " ' '' ' ,' '" " West Lonaltude
.1:":: .'".'' ";" ' ". ' 7. "" °_ '_ .J_ ^'""""hlort'h Latitude ° ' " ". "" West Longitude
illlj, Jin |i i | 'i i i1 ii"1 ir '!, 'i'," """"~^ ij! MI , i> ij,<< i11 "ii" ;, ',,1 .. 'ir . , 'MI '; ni,!,, i i ; '.MI., iji1;. , M iii« "::, : ?°[ I'^r,* "' v !, ,'ii, ' '."1'iiii!1. ,; y1!1; t s .iPii1',,., >,'t' '' ' * ^^f
ii, ii r«,i .4it ''Kvi V i in ii "[.," '"' ' ".' ' '. -i, h .' ", - ;ii::i. ;IM. i It \,, ,-?:::,:i ''(. ..r'iril Vv.K'i"1!1. ?'' fi7)1' . . ,,':'' nil1' 'iS/jwjfr'ii1!! ;,;«:;''!
I; '' 'I i « ./.'"!'.. If thousandths of seconds are unknown, use "0" as a default value. If necessary, refer to Appendix E oj
EPA's 1991 PA guidance document for directions on how to determine coordinates.
" ' '^r'i 2.5 "'DELETED PORTION COORDINATES."''Coori
provided in the form of polygons, starting with the northern-most coordinate and moving clockwise (in
degrees, minutes, secondsl and thousandths of seconds):
3.
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,'"!.,'i,
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;,» .
2.6
Dates
3.1
3.2
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;3. ° " North Latitude
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4. ° " North Latitude
5. ° ' . " North Latitude
6, ° " North Latitude
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EPA 's 1991 PA guidance document for directions on how to determine <
What method was used to identify the NPL site and deleted portion coo
Date this Form Was Completed:
Date Partial Deletion Proposed in FR:
Date Partial Deletion Finalized in FR:
" West Lonaitude
ii;;,1 , "',1,11, ''il ' .',iiir , i fc,
" West Lonaitude
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cessary, refer to Appendix E of
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G-10
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Appendix H - NOTICE OF INTENT OF PARTIAL
DELETION
-------
.
'"SI '" ' I l/llil'l
Th>>s
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Appendix H - Sample Notice of Intent of Partial Deletion
ENVIRONMENTAL PROTECTION AGENCY
40 CFR Part 300
National Oil and Hazardous Substances Pollution Contingency Plan: National Priorities List
AGENCY: Environmental Protection Agency.
ACTION: Notice of intent for partial deletion of the Bluelake Site from the National Priorities List.
SUMMARY: The United States Environmental Protection Agency (EPA) Region 10 announces its intent to delete
the soil unit of the Bluelake Site located in Bluelake County, Washington, from the National Priorities List (NPL)
and requests public comment on this action. The NPL constitutes Appendix B to the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP), 40 CFR Part 300, which EPA promulgated pursuant to Section 105
of the Comprehensive Environmental Response. Compensation, and Liability Act (CERCLA). This partial deletion
of the Bluelake Site is proposed in accordance with 40 CFR 300.425(e) and the Notice of Policy Chanae: Partial
Deletion of Sites Listed on the National Priorities List. 60 Federal Register 55466 (Nov. 1, 1995).
This proposal for partial deletion pertains to the soil unit and includes all contaminated soil / sludge on the Speedy
Cleaners (a dry cleaner) property, which was the source of the soil and ground-water contamination at the Bluelake
Site. A plume of contaminated ground water, resulting from former disposal practices at the dry cleaner, is treated
via air stripping at the Bluelake Water District production wells. The ground-water unit will remain on the NPL,
and treatment via air stripping will continue at the Bluelake Water District production wells. EPA bases its proposal
to delete the soil unit at the Bluelake Site on the determination by EPA and the State of Washington Department of
Ecology (Ecology), that all appropriate actions under CERCLA have been completed to protect human health.
welfare and the environment related to soil contamination at the site.
DATES: EPA will accept comments concerning its proposal for partial deletion for thirty (30) days after
publication of this document in the Federal Register and a newspaper of record.
ADDRESSES: Comments may be mailed to: [RPM Name], Superfund Site Manager. U.S. EPA. Region [ ]
[Mailcode], [Street Address. City, State, Zip Code] 1-800-XXX-XXXX or (XXX) XXX-XXXX.
INFORMATION REPOSITORIES: Comprehensive information on the Bluelake Site as well as information
specific to this proposed partial deletion is available for review at EPA's Region [ ]office in [City. State], and at
the information repositories listed below. Since this site predates the Superfund Amendments and Reauthorization
Act (SARA), no Administrative Record exists: however, the Site File and the Deletion Docket for this partial
deletion are maintained at EPA Region [ ]'s Regional Office Superfund Records Center, [Street Address. City,
State. Zip Code]. The Record Center's hours of operation are 8:30-4:30 p.m., Monday-Friday, and the Records
Center staff can be reached at (XXX) XXX-XXXX.
Other information repositories where the Deletion Docket is available for public review include: Bluelake Library.
[Street Address, City, State. Zip Code]; Bluelake County Public Library, [Street Address, City, State. Zip Code].
FOR FURTHER INFORMATION CONTACT: [RPM Name] (XXX) XXX-XXXX.
H-:
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; ij';1 'ws:; : 'i <:',x:;'' i1 ts 'V. * w' i -T .', *HK : w, si m:i:. :*~' !! in "Ti ' .s1 jr "' \K i :i t . 'i" sw1""''11
Appendix H - Sample Notice of Intent of Partial Deletion
SUPPLEMENTARY INFORMATION:
- Table of Contents |
1. Introduction
II. NPL Deletion Criteria
III. Deletion Procedures
IV. Basis for Intended Panial Site Deletion
I
I. Introduction
The United States Environmental Protection Agency (EPA) Region 10 announces its intent to delete a portion of the
Bluelake Site, located in Bluelake County, Washington, from the National Priorities List (NPL). which constitutes
Appendix B of the National Oil and Hazardous Substances Pollution Contingency Plan (N'CP). 40 CFR Part 300.
; and requests comments on this proposal. This proposal for partial deletion pertains to the soil unit, and includes all
contaminated soil ' sludge on the Speedy Cleaners (a dry cleaner) property, which was the source of the soil and
ground-water contamination at the site. A plume of contaminated ground water, resulting from former disposal
practices at the dry cleaner, is treated via air stripping at the Bluelake Water District production wells. The primary
contaminant in soil was perchloroethylene (PERC)l The soil unit was confined to an area on the Speedy Cleaners
property. The site boundary, including the plume of contaminated ground water, is predominantly residential to the
nohhpfthe Burlington Northern Railroad tracks and commercial / light industrial along the Pacific Highway.
Bluelake Water District's two production wells are located on a fenced site immediately south of Speedy Cleaners.
across Interstate 5. Residential property lies to the east. and_AFB Air Force Base to the southeast of the wells.
' 'ii( ' i ', i, ' i,' 11 ; ".,;: i' <
In July 1981. EPA sampled drinking water wells in the Bluelake area for contamination by volatile organic
compounds. The tests indicated that the Bluelake Water District production wells. H1 and H2. were contaminated
« vvitfi trichjoroethylene (TCE).tetrachioroethylene (PERC). and cls-1.2 dichloroethylene (cis-i.2 DCEJ. In August"
1981. the Bluelake W'ater District took these wells temporarily out of production and notified its customers of the
problem. EPA installed 24 monitoring wells, and contaminated surficial soil in the source area was excavated.
Following the shutdown of the wells, the State of Washington Department of Ecology (Ecology) and EPA
conducted several investigations and cleanup activities. Soil on the Speedy Cleaners property was contaminated
with PERC. a solvent that Speedy Cleaners used in their dry cleaning process. Ecology determined that solvents
used in the dry cleaning process were dumped onto the ground and into three on-site. bottomless septic tanks.
causing the soil contamination. Ecology sampled septic tanks on the Speedy Cleaners property between October
1981 and January 1983. The Bluelake Site was listed on the NPL on September 8. 1983.
' : ' -11" P*. : ! : " ' ;
In April 1983. Ecology issued an enforcement order requiring Speedy Cleaners to cease dumping solvent-containing
materials into the septic system. A stipulated agreement for remedial action was reached between Ecology and
Speedy Cleaners in September, 1983. Speedy Cleaners agreed to discontinue their prior solvent disposal practices.
ii. i install a system for reclaiming cleaning solvents, and send drummed waste water and sludge to a suitable off-site
disposal facility. The contents of the septic tanks were removed and the tanks backfilled to reduce the potential for
"further contamination during the EPA remedial action. Speedy Cleaners successfully fulfilled the terms of the
agreement.
, i . , -r . ... .:- I . , i - ,, !
:i[ : In May 1984. EPA completed a focused feasibility study identifying an interim remedial action (IRM) needed to
'"' " address those contaminant problems posing the most immediate threat at the site.
'Ill,' » ' ' II I ",! Fill" !,* li'»'l I, ''hl'lll'l- , " ~ ,," ^- , ,, , , , , , ,,,, ,
, { nl : , , , '
'" - ' - '" EPA's contractor conducted a remedial investigation from August 1984 to July 1985 to further determine the extent
i of ground-water contamination at the site, test the soil at Speedy Cleaners for remaining contaminants, and
determine wither,.Other sources were contributing to the ground-water problem.
' :::' " -'<*""" !:;:: " ; - " ' " '>-: H-4
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Appendix H - Sample Notice of Intent of Partial Deletion
The dr> cleaning operation's discharge of solvents into its bottomless (i.e. permeable) septic system and the disposal
of other wastes containing solvents onto the ground outside their building were suspected of causing the soil and
ground-water contamination. It was later confirmed that contamination had resulted from effluent discharges from
septic tanks behind the Speedy Cleaners building and sludge disposal on the ground surface. Ecology found that
supernatant (liquid overlying material deposited by settling or precipitation) in the dry cleaner's septic system
contained 550 parts per billion (ppb) PERC and 29 ppb TCE.
The feasibility study for the Bluelake site was published in July 1985. and the ROD was signed shortly thereafter on
September 30. 1985. An amended ROD was signed on November 14. 1986. All'of the selected remedies and
administrative restrictions in the September 30. 1985 ROD for the aquifer unit remained the same.
In 1987. the Soil Vapor Extraction System (SVES) was installed within the contaminated area to extract PERC from
the shallow unsaturated soil at the site. Soil sampling in 1990 indicated elevated concentrations of PERC at about
12 feet below the surface. Based on concerns that the SVES would not be able to reduce PERC concentrations
below the 500 ppb cleanup level. EPA excavated the contaminated sludge and soil from the area, and disposed of it
off-site. On-site soil remediation activities were completed in July 1992. including the dismantling and
decommissioning of the SVES. Subsequent sampling confirmed that attainment of the 500 ppb soil cleanup goal
had been achieved.
On September 15, 1992, EPA published an Explanation of Significant Difference(ESD) which identified cleanup
goals for the site contaminants. The groundwater cleanup levels are 5.0 ppb for PERC and TCE, and 70 ppb for
cis-1.2 DCE consistent with the federal maximum contaminant levels (MCLs). These concentrations are also the
cleanup standards under the State of Washington Model Toxic:; Control Act (MTCA). The soil cleanup level for
PERC was set at 500 ppb, in compliance with State requirements (based on protection of ground water), is within
EPA's acceptable risk range of 10"* to 10"6, and is protective of ground water.
The ESD also documented additional revisions needed in order to comply with the original ROD, amended ROD
and regulatory requirements. The additional issues requiring revision were: (1) further remedial action necessary to
remove the source of the contamination at the site, and (2) elimination of the requirement to implement institutional
controls on land and ground-water use.
The institutional controls requirement on soil, as called for in the ROD and amended ROD, was addressed in the
ESD as follows:
The success of the final soil remedial action eliminated the need for institutional controls on land use.
No further action is necessary to protect human health and the environment in relation to soil contamination at the
Site.
EPA proposes to delete the soil unit because all appropriate CERCLA response activities have been completed in
those areas where soil contamination exceeded the cleanup level. However, response activities at the groundwater
unit are not yet complete, and the site will remain on the NPL and is not the subject of this partial deletion.
The NPL is a list maintained by EPA of sites that EPA has determined present a significant risk to human health,
welfare, or the environment. Sites on the NPL may be the subject of remedial actions financed by the Hazardous
Substance Superfund (Fund). Pursuant to 40 CFR Sec. 300.425(e) of the NCP, any site or portion of a site deleted
from the NPL remains eligible for Fund-financed remedial actions if conditions at the site warrant such action.
EPA will accept comments concerning its intent for partial deletion for thirty (30) days after publication of this
notice in the Federal Register and a newspaper of record.
H-5
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Appendix H - Sample Notice of Intent of Partial Deletion
II.
NPL Deletion Criteria
The N'CP establishes the criteria that EPA uses to.delete sites from the.NPL.. In accordance with 40 CFR Sec.
300.425(e), sitesma\ be deleted from the NPL where no further response is appropriate to protect human health or
,,, jhe environment, in making such a determination pursuant to section 300.425 (e), EPA will consider, in
: consultation with the State, whether anv of the following criteria have been met:
: Section 3Q0.425|e)(lXi). Responsible parties or other persons have implemented all appropriate response actions
required; or . ' "
'. ' !: ',: :- : I!,: , : : : !"'' ',' , ' : : ' , " : , ! * .' '. . J ".: : !! ":':»' > ' ;.: ll" . "i
... Section 300.425(e)(l)(ii). All appropriate Fund-financed response under CERCLA has been implemented, and no
further response action by responsible panics is appropriate; or
Section 300.425(e)(l)(iiij. The remedial investigation has shown that trie release poses no significant threat to
human health or the environment and, therefore, taking of remedial measures is not appropriate.
Deletion of a portion of a site from the NPL does not preclude eligibility for subsequent Fund-financed actions at
the area deleted if future site conditions warrant such actions. Section 300.425(e)(3) of the NCP provides that
Fund-financed actions may be taken at sites that have been deleted from the NPL. A partial deletion of a site from
the NPL does not affect or impede EPA's ability to conduct CERCLA response activities at areas not deleted and
ferna{nin| on the NPL. In addition, deletion of a portion of a site from the NPL does not affect the liability of
responsible parties or impede agency efforts to recover costs associated with response efforts.
~"" ," .«''.: . ,i, :'..,' ".',,;.'.. " ,'" \" : ~: ", : ."',." :'::.; ..'..,: ,: ' .} :.;. " ...; " , . i ';
HI. Deletion Procedures
Deletion of a portion of a site from the NPL does not itself create, alter, or revoke any person's rights or obligations.
The NPL is designed primarily for informational purposes and to assist Agency management.
The following procedures were used for the proposed deletion of the soil unit at the Bluelake Site:
(1) EPA has recommended the partial deletion and has prepared the relevant documents.
(2 j The State of Washington through the Washington Department of Ecology concurs with this partial deletion.
(3) Concurrent with this national Notice of Intent for Partial Deletion, a notice has been published in a newspaper
, ' of recqrdajid has been distributed to appropriate federal. State, and local officials, and other interested parties.
These notices announce a thirty (30) day public comment period on the deletion package, which commences on
the date of publication of this notice in the Federal Register and a newspaper of record.
(4) EPA has made all relevant documents available at the information repositories listed previously.
This Federal Register document, and a concurrent notice in a newspaper of record, announce the initiation of a thirty
(30) day public comment period and the availability of the Notice of Intent for Partial Deletion. The public is asked
to comment on EPA's proposal to delete the soil unit from the NPL. All critical documents needed to evaluate
EPA's decision are included in the Deletion Docket and are available for review at tfee EPA Region 10 information
repositories. ,
Upon completion of the thirty (30) day public comment period. EPA will evaluate all comments received before
issuing the final decision on the partial deletion. EPA will prepare a Responsiveness Summary for comments
i'r'eceived during the' public comment period and will address concerns presented in the comments, the
I Responsiveness Summary will be made available to the public at the information repositories listed previously.
Members of the public are encouraged to contact EPA Region 10 to obtain a copy of the Responsiveness Summarv.
If. after review of all public comments, EPA determines that the partial deletion from the NPL is appropriate. EPA
will publish a final notice of partial deletion in the Federal Register. Deletion of the soil unit does not actually occur
until the final Notice of Partial Deletion is published in the Federal Register.
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Appendix H - Sample Notice of Intent of Partial Deletion
IV. Basis for Intended Partial Site Deletion
The following provides EPA's rationale for deletion of the soil unit from the NPL and EPA's finding that the criteria
in 40 CFR Sec. 300.425(e) are satisfied.
Background
The Bluelake Site is located in Bluelake County, Washington and includes property upon which a business known
as Speedy Cleaners has operated for several years. The regional aquifer is contaminated within about a 2.000-foot
radius down gradient from the Speedy Cleaners.
The area is predominantly residential to the north of the Burlington Northern Railroad tracks, and commercial
light industrial along the Pacific Highway. Bluelake Water District has two of its production wells (HI and H2) on
a fenced site immediately south of Speedy Cleaners, across Interstate 5. Residential property lies to the east, and
AFB Air Force Base to the southeast of the wells. In July 1981. EPA sampled drinking water wells in the Bluelake
area for contamination by volatile organic compounds. The tests indicated that the Bluelake Water District
production wells. HI and H2. were contaminated with trichloroethylene (TCE), tetrachloroethylene (PERC). and
cis-1,2 dichloroethylene (cis-1,2 DCE). In August 1981, the Bluelake Water District took these wells temporarily
out of service and notified its customers of the problem. EPA installed 24 monitoring wells, and contaminated
surficial soil in the source area was excavated. Following the shutdown of the wells. Ecology and EPA conducted
several investigations and cleanup activities. Soil on the Speedy Cleaners property was contaminated with PERC, a
solvent they used in their dry cleaning process. Ecology determined that solvents used in the dry cleaning process
were dumped onto the ground and into three on- site, bottomless septic tanks, causing contamination of the soil.
Ecology sampled septic tanks on the Speedy Cleaners site between October 1981 and January 1983. In April 1983.
Ecology issued an enforcement order requiring Speedy Cleaners to cease dumping solvent-containing materials into
the septic system. The contents of the septic tanks were later removed and the tanks backfilled to reduce the
potential for further contamination during the EPA remedial action.
In May 1984. EPA completed a focused feasibility study identifying an interim remedial action (IRM) needed to
address those contaminant problems posing the most immediate threat at the site. The objectives of the IRM were
to: (1) Restrict the spread of contamination within the aquifer. (2) restore normal water service to the area: (3) and.
initiate ground-water treatment as quickly as possible. By November 15, 1984, two air strippers had been installed
to treat wells HI and H2 and were fully operational following implementation of the IRM.
EPA's contractor conducted a remedial investigation from August 1984 to July 1985 to further determine the extent
of ground-water contamination at the site, test the soil at Speedy Cleaners for remaining contaminants, and
determine whether other sources were contributing to the ground-water problem. The field work conducted during
the RI included:
~ Installation of nine deep and three shallow monitoring wells to provide a comprehensive picture of the
ground-water regime (e.g. flow patterns, hydraulic connections between layers); determine the nature . extent of
ground-water contamination; and, identify possible sources of the contamination.
-- Excavation of the waste line at Speedy Cleaners and drilling of seven soil borings to determine the extent /
character of remaining sources of contamination at Speedy Cleaners, and to determine if other sources besides
Speedy Cleaners exist.
Collection of samples for field and laboratory analysis to determine the extent / concentration of soil and aquifer
contamination within the study area.
The dry cleaning operation's discharge of solvents into its bottomless (i.e. permeable) septic system and the disposal
of other wastes containing solvents onto the ground outside their building were suspected of causing the soil and
ground-water contamination, it was later confirmed that contamination had resulted from effluent discharges from
H-7
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11 sis''
I 111!!
ill V 'T r : I I I;||
till ll'li .:!!!'! I -II' ,|n > "lli! ill: ' ' -i '. Ji1 '*" , ' J;i .f '' * !»":' ! '"'"S - '»> "1 iv"l "
Appendix H - Sample Notice of Intent of Partial Deletion
,'yseptic tanks behind the Speedv Cleaners building and sludge disposal on the ground surface.
Hi 1" Jill,;;,, i " 'I'liii!'",!!,, JjniK! r'}:] ; " ,11 '' ^ ' «» ;r ' "I"' ;;*' ; "~!il 'JIM; ' '"',''iil1*,,;;;':,;!''If, "i ;;,», ' ,"1 -I" rtP, ,,;'!f ' ^ I; ' 1: 'i i.f /il.i1 ''I:,,11:1' I1";1"1'
Ecology found that supernatant (liquid overlying material deposited by settling or precipitation) in the dry cleaner's
septic s>stem contained 550 pans per billion (ppb) PERC and 29 ppb TCE.
= Data for the m o production \\ells (HI and H2) ranged from 100 to 500 ppb PERC prior to initiating the
ground-water treatment. Contaminant concentrations decreased rapidly after several days of pumping, and have
cb'hiinued to decrease. Maximum and mean concentrations in other ground-water monitoring wells within the
study area prior to treatment were: PERC-922 ppb and 16 ppb, respectively, anck TCE-57 ppb and 3 ppb.
respectively. The only detected concentration for cis-1.2 DCE was 85 ppb in a monitoring well upgradient of the
production wells.
The RI indicated that PERC contamination in soil was highest where solvent-contaminated wastes were
intentionally disposed on the ground surface. Except for several small pockets of contamination, most of the
PERC from the soil borings and test pit was located in the upper 12 to 13 feet of soil in the immediate vicinity of
the dry cleaner's septic tanks and drain field. Where it was detected, PERC concentrations ranged from 11 to 3.800
ppb. The average PERC concentration in soil was 500 ppb. Maximum TCE and cis-1.2 DCE concentrations in soil
were 5 ppb and 4 ppb. respectively.
iijjTrje, feasibility study for the Bluelake site was published in July 1985, and the ROD was signed shortly thereafter
on September 30, 1985. The remedy selected in the ROD consisted of the following major elements:
^ Continued operation of the H1-H2 production wells' treatment system to cleanup the aquifer. Installation of
higher efficiency equipment or modification of existing energy reducing equipment used in the treatment svstem.
r- Installation of additional rnonitqring wells, upgrading of existing wells, and continuation of routine sampling
and analysis of the aquifer to monitor progress and provide early warning of potential new contaminants.
~ Excavation and removal of contaminated septic tanks and drain field piping to avoid the possible spread of
contamination viaMjincontrolled excavation ^i.e.. future property development). The septic tanks were found to be
bottomless, and. therefore, they were not removed.
'"- Placement of administrative restrictions on the installation and use of ground-water wells and on excavation
into the contaminated soils to minimize the potential for use of contaminated ground water and reduce the risks
associated with uncontrolled excavation.
^in amended ROD was signed on November 14, 1986. All of the selected remedies and administrative restrictions
in the September 30, 1985 ROD for the aquifer unit remained the same. Additions or modifications to the soil unit
cleanup were as follows:
^Installation of; an SVES covering the area of soil contamination over and around the historical drain field
qn-site to extract PERC! from tfie remaining contaminated soil.
* Reduction in the amount of septic tank contents to be removed and treated off-site. At that time, the capability
of off-site disposal consistent with the CERCLA off-site policy was not available within Region [ ] for the
J3fbposed 90S cubic yards of soil requiring removal, as called for in the original ROD. Therefore, contaminated
solids and any water were removed from the septic tanks and disposed off-site. The remainder of the
contaminated soil within the septic tanks and around the historicardrain field was treated via SVES. During
irnpiementation of the remedy in the original ROD, the septic tanks were found to be bottomless, were left in
:;i place, and the soil treated via SVES. "
Soil and vapor testing continued until soil treatment was deemed complete.
H-8
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Appendix H - Sample Notice of Intent of Partial Deletion
Final Response Actions
In 1987, soils were excavated from inside and around the three septic tanks to remove the source of PERC
contamination. An SV'ES was installed within the contaminated area to extract PERC from the shallow unsaturated
soil at the site. Soil sampling in 1990 indicated elevated concentrations of PERC at about 12 feet below the
surface.
Cleanup goals for the site contaminants were identified in an Explanation of Significant Differences (ESD)
published on September 15. 1992. EPA published ground-water cleanup levels at 5.0 ppb for PERC and TCE. and
70 ppb for cis-1.2 DCE consistent with the federal maximum contaminant levels (MCLs). These concentrations are
also the cleanup standards under the State of Washington Model Toxics Control Act (MTCA). The soil cleanup
level for PERC was set at 500 ppb, in compliance with [cite regulations] requirements (based on protection of
ground water), is within EPA's acceptable risk range of 10"1 to 10'°. and is protective of ground water.
The ESD also documented additional revisions needed in order to comply with the original ROD, amended ROD
and regulatory- requirements. The additional issues requiring revision were: (1) further remedial action necessary to
remove the source of the contamination at the site, and (2) elimination of the requirement to implement institutional
controls on land and ground-water use.
The institutional controls requirement on soil, as called for in Khe ROD and amended ROD, was addressed in the
ESD as follows:
The success of the final soil remedial action eliminated the need for institutional controls on land use.
Based on concerns that the SVES would not be able to reduce PERC concentrations below the cleanup level. EPA
excavated the contaminated sludge and soil from the area, and disposed of it off-site. On-site soil remediation
activities were completed in July 1992. including the dismantling of the SVES. Subsequent sampling confirmed
that the attainment of the 500 ppb soil cleanup goal was achieved. No further action is necessary to protect human
health and the environment in relation to soil contamination at the Site. EPA proposes to delete the soil unit
because all appropriate CERCLA response activities have been completed in those areas where soil contamination
exceeded cleanup levels.
All of the response actions at the soil unit were conducted using funds from the Hazardous Substance Superfund.
Community Relations Activities
Community interest in this site has been low. Most residents seem confident that the water they receive is safe.
Most of the citizens concerned about contamination were not served by drinking water supply wells H1 and H2.
but by other wells which they feared might be affected by the contamination at the site. There has been little press
interest since the Bluelake Water District production wells, H1 and H2, were returned to use.
A major goal of the Community Relations Section was to inform residents of the status of the remedial activities.
EPA sent letters to property owners and well-drillers advising them not to drink from private wells or drill new
wells in the zone of contamination. EPA has mailed fact sheets to local residents since 1984, most recently in
September. 1992.
Current Status
Final on-site soil remediation activities were completed in July 1992. Contaminated sludge and soil was excavated
to a maximum depth of 18 feet. Attainment of the 500 ppb soil cleanup level has been achieved.
While EPA does not believe that any future response actions in the soil unit will be needed, if future conditions
warrant such action, the proposed deletion area of the Bluelake Site remains eligible for future Fund-financed
response actions. Furthermore, this partial deletion does not alter the status of the groundwater unit of the Bluelake
Site which is not proposed for deletion and remains on the NPL.
H-9
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Appendix H"- Sample Notice of Intent of Partial Deletion
In a letter dated September 5. the State of Washington through its Department of Ecology, has concurred on EP'A's
final determination regarding the partial deletion.
Dated: September 17. 1996.
John Doe. Regional Administrator. U.S. Environmental Protection Agencv. Region 10.
i;"!B, . \ , .: t , I
H-10
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Appendix I - NOTICE OF PARTIAL DELETION
1-1
-------
This \otice '}f Partial Deletion Sample is based on an actual Superfitnd site, but sonic information has Ken
altered for illustrative purposes,
OwifcW and format of an actual Sotice of Partial Deletion may vary from this sample due to considerations
Hitch as project lead and support roles, availability of information, and site-specific conditions.
For more about preparing a Xotice of Partial Deletion, refer to OStt'ER Directive 9320.2-9A-P. "Close Out
for \atinnal Priorities List Sites. " EPA 540-R-9K-016.
lit S
1-2
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Appendix I - Sample Notice of Partial Deletion
ENVIRONMENTAL PROTECTION AGENCY
40 CFR Part 300
National Oil and Hazardous Substances Pollution Contingency Plan; National Priorities List
AGENCY: Environmental Protection Agency.
ACTION: Notice of partial deletion of the Prewitt Abandoned Refinery Superfund Site from the National Priorities
List.
SUMMARY: The United States Environmental Protection Agency (EPA) Region 6 announces the deletion of the
surface portion of the Prewitt Abandoned Refinery Superfund Site (the Site) from the National Priorities List (NPL).
The NPL. promulgated pursuant to section 105 of the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA) of 1980, as amended. 42 U.S.C. 9605, is codified at Appendix B of the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP), 40 CFR part 300. This partial deletion is consistent
with the EPA's Notice of Policy Change: Policy Regarding Partial Deletion of Sites Listed on the National Priorities
List. 60 Federal Register 55466 (November 1, 1995). This partial deletion pertains to the surface portion, which
includes all surface soils, and also includes the former separator area. This partial deletion does not pertain to the
subsurface portion of the Site including without limitation ground water and subsurface soils. The subsurface
portion of the Site will remain on the NPL, and response activities will continue at that portion. With the
concurrence of the State of New Mexico through the New Mexico Environment Department (NMED), and with the
concurrence of the Navajo Nation through the Navajo Nation Superfund Office (NSO), the EPA has determined
that responsible parties have implemented all appropriate response actions required at the surface portion of the
Site (neither the CERCLA-required five-year reviews, nor operation and maintenance of the constructed remedy is
considered further response action for these purposes), that all appropriate Hazardous Substance Response Trust
Fund (Fund) financed response actions under CERCLA have been implemented at the surface portion of the Site.
and that no further response action by responsible parties is appropriate for the surface portion of the Site.
Moreover, the EPA, with State of New Mexico concurrence through the NMED, and with Navajo Nation
concurrence through the NSO. has determined that Site investigations show that the surface portion of the Site now
poses no significant threat to public health or the environment: consequently, pursuant to CERCLA section 105.
and 40 CFR 300.425(e), the surface portion of the Site is hereby deleted from the NPL.
EFFECTIVE DATE: (INSERT DATE NOTICE IS PUBLISHED)
FOR FURTHER INFORMATION CONTACT: [RPM Name]. Remedial Project Manager, (XXX)
XXX-XXXX, United States Environmental Protection Agency, Region [ ]. Mail Code: [ ] [Street
Address, City. State Zip Code]. Information on the Site is available at the local information repository located at:
Prewitt Fire House. PO Box 472, Prewitt, New Mexico 87045, (505) 876-4068. Requests for comprehensive
copies of documents should be directed formally to the Regional Superfund Management Branch, care of [Name].
(XXX) XXX-XXXX, EPA Region [ ], Mail Code:[ ], [Street Address, City. State Zip Code].
SUPPLEMENTARY INFORMATION: The site to be partially deleted from the NPL is the Prewitt Abandoned
Refinery Superfund Site located near the town of Prewitt. in McKinley County, New Mexico. This partial deletion
pertains to the surface portion of the Site, which consists of all surface soils and the former separator area. This
partial deletion does not pertain to the subsurface portion of the Site including without limitation ground water and
subsurface soils. This Partial Deletion is in accordance with 40 CFR 300.425(e) and the Notice of Policy Change:
Partial Deletion of Sites Listed on the National Priorities List. 60 Federal Register 55466 (Nov. 1, 1995). A Notice
of Intent for Partial Deletion was published on October 6. 1997 (62 FR 52074).
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Appendix I - Sample Notice of Partial Deletion
The closing date for comments on the Notice of Intent for Partial Deletion was November 5. 1997. The EPA
received t\v^ comment letters, both of which supported the partial deletion.
1 ''*"=i: Ii1 ' ' "!' , ",:, ''" .- ..' . "" ":-}':' '":'.' "' ':' '.':' -^f. L":;"T '::'[' "' ' ' "'' ',' '" : ' '
The EPA identifies sites which appear to present a significant risk to public health, welfare, or the environment and
it maintainsjlje NPT '"as "the "list "of thos? sites. Site's PR the .NPL.may be the subject of Fund-financed remedial
factions.Section 300.425(^(3) of the NCP.40 CFR 300.425(eK3). states thaj Fund-financed actions ma> be taken '
at sites deleted from the NPL in the unlikely event that conditions at the site warrant such action. Deletion of a site
from the NPL does not affect responsible party liability or impede EPA efforts to recover costs associated with
response efforts. ' MI " _
joists of'Subjects in 40 CFR Part 300
Environmental protection. Air pollution control. Chemicals. Hazardous substances. Hazardous waste.
Intergovernmental relations. Penalties. Reporting and record keeping requirements, Superfund, Water pollution
control. Water supply.
Dated: January 8, 1998.
Lynda F. Carroll, Acting Regional Administrator (6RA), Region 6.
For the reasons set out in the preamble, 40 CFR part 300 is amended as follows:
PART 300-[AMENDED]
1. The authority citation for Part 300 continues to read as follows:
Authority: 33 U.S.C. 1321(c)(2); 42 U.S.C. 9601-9657; E^O. 12777, 56 FR 54757, 3 CFR 1991 Comp.. p. 351: E.O.
12580, 52 FR 2923, 3 CFR 1987 Comp., p. 193.
[(Page 4398]] ' ' :
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2. Table 1 of Appendix B to part 300 is amended by revising the entry for "Prewitt Abandoned Refinery" by adding
a note "P" so that it reads as follows:
Appendix B{'Amended]
Table 1 .General Superfund Section
((I, l"-§!a^i! , Site^ame, _ i | City /County Notes <SUP>(a)
NM Prewitt Abandoned Refinery Prewitt
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PBSites with partial deletion(s).
1-4
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Appendix J - SUPERFUND ACRONYMS LIST
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Appendix J - Superfund Acronyms List
CERCLA: Comprehensive Environmental Response. Compensation, and Liability Act of 1980. as amended
CFR: Code of Federal Regulations
COR: ' Close Out Report
EPA: Environmental Protection Agency
ESD: Explanation of Significant Difference
FCOR: Final Close Out Report
FR: Federal Register
GIS: Geographical Information System
HQ: EPA Headquarters
MRS: Hazard Ranking System
LTRA: Long-Term Response Action
;
MCL: Maximum Contaminant Level
NCP: National Oil and Hazardous Substances Pollution Contingency Plan
NOD: Notice of Deletion
NOID: Notice of Intent to Delete
NOIPD: Notice of Intent of Partial Deletion
NPL: National Priorities List
O&M: Operations and Maintenance
ORC: Office of Regional Counsel
OSWER: Office of Solid Waste and Emergency Response
OU: Operable Unit
PA: Preliminary Assessment
PCOR: Preliminary Close Out Report
POLREP: Pollution Report
PRP: Potentially Responsible Party
QA/QC: Quality Assurance / Quality Control
RA: Remedial Action
RCRA: Resource Conservation and Recovery Act of 1976. as amended
RD: Remedial Design
RI: Remedial Investigation
RI 'FS: Remedial Investigation / Feasibility Study
J-3
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Appendix J - Superfund Acronyms List
ROD: Record of Decision
RP: Responsible Pam
RPM: Remedial Project Manager
SARA: Superfund Amendments and Reauthorization Act of 1986
SI: Site Inspection
(JSACE: United States Army Corps of Engineers
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Appendix K - GLOSSARY
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I i
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Appendix K - Glossary of Environmental Terms
Code of Federal Regulations (CFR): Document that codifies final regulations having general applicability and
legal effect that have previously appeared in the Federal Register.
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA): A Federal law passed
in 1980 that established Federal authority for responding to the release of hazardous substances into the
environment including creating a Federal fund to finance responses and imposing liability for releases on the
responsible parties. CERCLA was amended in 1986 by the Superfund Amendments and Reauthorization Act.
Final Close Out Report: A 'stand alone' report documenting compliance with the statutory requirements of
CERCLA and providing a consolidated record of all remedial activities at all of a site's operable units.
Final Pollution Report (POLREP): The document that signifies that a removal has been completed (i.e.. when all
objectives outlined in the Action Memorandum and any addenda, such as removal and transport of wastes off site.
waste disposal, and demobilization have been accomplished).
Hazard Ranking System (HRS): A scoring system developed as part of the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP) used to evaluate potential relative risks to public health and the
environment from releases or threatened releases of hazardous substances. EPA and States use the HRS to calculate
a site score based on an actual or potential release of hazardous substances from a site through air migration, surface
water migration, groundwater migration, or soil exposure pathways. This score is used to decide if a hazardous
waste site should be placed on the National Priorities List (NPL).
Hazardous Substance: Under CERCLA section 101(14), any element, compound, mixture, solution, or substance
that, when released to the environment, may present substantial danger to public health / welfare or the
environment. The term also includes substances designated as hazardous or toxic under the Clean Air Act. the
Federal Water Pollution Control Act. as amended by the Clean Water Act of 1986. the Resource Conservation and
Recovery Act. as amended and the Toxic Substances Control Act. The term does not encompass petroleum.
including crude oil, natural gas liquids, liquefied natural gas. or synthetic gas usable for fuel.
Local Notice of Intent to Delete: A notice published in a local newspaper of general circulation, announcing the
Agency's intent to delete a site from the NPL. It also announces a 30-day public comment period, among other
things, and identifies the location of the local repository.
Long-Term Response Action (LTRA): A ground or surface water restoration remedy site that requires on-site
treatment before the cleanup levels specified in the ROD are achieved.
National Oil and Hazardous Substances Pollution Contingency Plan (NCP): The regulation for Federal
response actions under CERCLA, commonly referred to as the National Contingency Plan, or NCP. The NCP sets
forth the Hazard Ranking System and establishes procedures and standards for responding to releases of hazardous
substances. The plan has been codified in Title 40 CFR Pan 300.
National Priorities List (NPL): EPA's list of the most serious uncontrolled hazardous waste sites identified for
possible long-term remedial response. This list is based primarily on the score a site receives on the Hazard
Ranking System. EPA is required to update the NPL at least once a year.
Notice of Deletion (NOD): A notice published in the Federal Register announcing a site's deletion from the NPL.
Notice of Intent to Delete (NOID): A notice published in the Federal Register announcing the Agency's intent to
delete a site from the NPL. This notice provides information about the site and associated cleanup activities, and
provides the public with a 30-day public comment period.
Operable Unit (OU): A term for each of a number of discrete activities undertaken as part of a Superfund site
cleanup. An example of an operable unit would be removing drums and tanks from a surface of a site.
K-3
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Appendix K. - Glossary of Environmental Terms
...... , ......................... ! ................ III,,! ...... ,,l| ..... ,
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n and Maintenance (O&M): .......... Activities conducted at a site after.a Superfund site action is completed to
......... '''""",'
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.,?PtenJti?Hy Responsible Party (PRP): Any individual(s) or company(s) (such as owner, operator, transporter, or
generator) potentially responsible for. or contributing to. contamination at a CERCLA site. Whenever possible.
' EPA requires PRPs. through administrative and legal actions, to clean up hazardous waste sites that they have
contaminated,
............... " i ......... ' .......... " ..... , ............... " ..................... ','" ..... I '"' .......... ! ......... ""i"": '' "" " .............. I ""!';""
Preliminary Assessment (PA): The process of collecting and reviewing existing information about a known or
suspected hazardous waste site or release. EPA uses this information to, determine if the site requires further stud>,
If further study is needed, a site inspection is performed.
' ' . i ' : , - j '
Preliminary Close Out Report: A report, documenting the completion of the physical remedy construction at a
site, that is prepared after work at the final operable unit is complete. To name a few, it summarizes the release at
the site, site conditions, construction activities, and any response actions.
ii i In ' ii I ' ', "I'll ...... i ....... ; . ..... jih i .;.'. ...... i'*:/:*,' i! ..... c id. ;,.;/(»]; i1 .,"?" » L 'rtMA:.1*!* :. -M,. \ . «:* "..iOT;iT#r:
Quality Assurance / Quality Control (QA/QC): A system of procedures, checks, audits, and corrective actions to
ensure that all EPA research design and performance, environmental monitoring and sampling, and other technical
reporting activities are of known and documented quality.
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Record of Decision (ROD): A public document that explains which cleanup altemative(s) will be used at National
Priorities List sites. The ROD is based on information and technical analysis generated during the remedial
investigation / feasibility study and consideration of public comments.
l: Iake,n instead of or in addition to arempval action, a remedial response is the permanent remedy taken
at a site: it s^eks to prevent or minimize the release of hazardous substances and to prevent further migration.
R°mecl'§! a9t!ons I!iay. incfuc1^ ^tp^g6' conf!nernent- perimeter protection, neutralization, cleanup, recycling, repair
of leaking containers, bioremediation, and incineration.
Reniedial Action Report: The Remedial Action Report documents the activities that occur under each specific
""y16^! act'on opera^'e umt at a s'te- II a'so, Pr,°y'des documentation that a particular operable unit has met its
objectives, and certifies that all items in the settlement agreement and any incorporated documents have been met.
Remedial Design (RD): A phase of remedial action that follows the remedial investigation / feasibility study and
includes development of engineering drawings and specifications for a site cleanup.
Remedial Investigation /Feasibility Study (RJ/FS): Two distinct but related studies. They are usually performed
" pft-'the spmeiiffle,|rj4|pgem'erare RI/FS.' ^They 'are 'intended to: "(1) ..... gather'the data necessary to
determine the type and extent of contamination at a CERCLA site listed on the National Priorities List (2) establish
criteria for cleaning up the site; (3) identify and screen cleanup alternatives for remedial action; and (4) analyze in
detail the technology and costs of the alternatives.
Remedial Project Manager (RPM): The EPA or state official responsible for overseeing remedial action at a site.
Removal Action (RA): The cleanup or removal of released hazardous substances from the environment or the
taking of other actions as may be necessary to prevent, minimize, or mitigate damage to the public health or welfare
when immediate action is considered to be necessary. In addition to physically removing hazardous substances
ijlrom the sited, rernoyal actions ...... rnay include measures to limit access to the site and the provision of alternative water
supplies and temporary housing.
, and,,Recpverv Act (RCRA): An amendment to the Solid Waste Disposal Act, addressing
', ...... !,he safe rpapagement of the hazardous and non-hazardous municipal and industrial waste generated nationwide.
This act governs hazardous waste treatment, storage and disposal facilities, and was amended in 1984 by the
Hazardous and Solid Waste Amendments.
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K-4
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Appendix K - Glossary of Environmental Terms
Site Inspection (SI): An investigatory phase following a preliminan. assessment in which more extensive
information is collected through site sampling. The collected information is used to score a site under the Hazard
Ranking System to determine whether the site will be placed on the National Priorities List.
Superfund: The common name used for the Comprehensive Environmental Response. Compensation, and
Liability Act of 1980. as amended in 1986 and the EPA activities implementing the Act.
Superfund Amendments and Reauthorization Act (SARA): Amendments to CERCLA enacted on October 17.
1986. that expanded the size of the cleanup fund, established cleanup standards and deadlines for response actions.
and addressed cleanup of Federal facilities.
Trust Fund: Commonly referred to as "Superfund." this is a fund established by CERCLA to pay for the cleanup
of hazardous waste sites and for the costs of legal action necessary to force those responsible for creating the sites to
clean them up or pay for clean up costs.
K-5
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&EPA
United States
Environmental Protection Agency
(5201G)
Washington, DC 20460
Official Business
Penalty for Private Use
$300
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