EPA
              United States
              Environmental Protection
              Agency
                 Office of Emergency and
                 Remedial Response and
                 Office of Waste Programs
                 Enforcement
                 Office of Solid Waste and
                 Energency Response
                 Washington DC 20460
Office of Research and
Development
Hazardous Waste Engineering
Research Laboratory
Cincinnati OH 45268
              Superfund
                                  EPA/540/G-85/003 June 1985
Guidance on
Feasibility Studies
Under CERCLA

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                                      EPA/540/G-85/003
                                      June 1985
Guidance  on Feasibility Studies
            Under  CERCLA
                  Prepared for:
   Hazardous Waste Engineering Research Laboratory
         Office of Research and Development
        U.S. Environmental Protection Agency
              Cincinnati, Ohio 45268

                     and

     Office of Emergency and Remedial Response
                     and
        Office of Waste Programs Enforcement
    Office of Solid Waste and Emergency Response
        U.S. Environmental Protection Agency
             Washington, D.C. 20460

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                                   NOTICE
The information in this document has been funded, wholly or in part, by the
United States Environmental Protection Agency under Contract No. 68-03-3113
to JRB Associates.  It has been subject to the Agency's peer and administrative
review and has been approved for publication as an EPA document.

This document provides guidance for the preparation of .feasibility studies
required under the revised National Contingency Plan.
                                     ii

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                                  FOREWORD
     Under the authorities of the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA), the Office of Emergency
and Remdial Response and the Office of Waste Programs Enforcement are
responsible for overseeing the development and implementation of the
Government's program for response to uncontrolled releases of hazardous
substances.  These responses ensure that threats to public health, welfare,
or the environment are appropriately addressed through the effective
management of CERCLA1s enforcement and funding authorities.  The Hazardous
Waste Engineering Laboratory develops new and improved technologies and
systems to prevent, treat, and manage hazardous waste pollutant discharges
to minimize the adverse economic, social, health, and aesthetic effects of
pollution.

     This document is a cooperative effort between the Office of Solid
Waste and Emergency Response and the Office of Research and Development.
It is one of a series of reports being published to implement CERCLA,
otherwise known as Superfund.  These reports provide an array of information
necessary for compliance with the National Contingency Plan (NCP, 47 FR
31180, July 16, 1982), including:  guidance for remedial investigation and
feasibility studies, guidance for exposure assessments, analytical and
engineering methods and procedures, research reports, technical manuals,
toxicological and engineering data bases, and other reference documents
pertinent to Superfund.

     This guidance document provides guidance for the preparation of
feasibility studies required under the revised NCP.  It provides project
managers and decision makers in government and industry with guidelines for
developing and evaluating alternative remedial responses to be uncontrolled
releases of hazardous substances.  In conjunction with other publications
in this series, it will assist in meeting the national goal of adequately
protecting public health, welfare, and the environment.
                                    iii

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                                  ABSTRACT
     This guidance document is intended to provide a more detailed structure
for identifying, evaluating, and selecting remedial action alternatives
under the Comprehensive Environmental Response, Compensation, and Liability
Act (CERCLA) and the National Contingency Plan (40 CFR 300).

     The feasibility study process begins with the development of specific
alternatives based on general response actions identified in the remedial
investigation to address site contamination problems.  Technologies within
the categories are screened for their technical applicability to the site.
Technologies considered technically appropriate are then combined to form
alternatives that fulfill five specific categories.  The alternatives are
screened on the basis of public health and environmental concerns and
order-of-magnitude costs.

     Alternatives that pass the screening process undergo detailed analyses
to provide the decisionmaker with information for selecting the alternative
that is cost-effective.  The detailed analyses encompasses engineering,
institutional, public health, environmental, and cost analyses.  The
engineering analysis evaluates constructability and reliability to ensure
the implementability of alternatives.  The institutional analysis examines
alternatives in terms of the Federal, State, or local requirements,
advisories, or guidance that must be considered to protect the public
health, welfare, and environment.  The public health exposure evaluation
includes baseline site evaluation, exposure assessment, standards analysis,
short- and long-term effects of each alternative, and endangerment assess-
ment.  The environmental analysis includes assessment of adverse impacts if
no action is taken and the short- and long-term effects of the alternatives.
The cost analysis examines capital and operation costs, and involves present
worth and sensitivity analyses.

     Once the detailed analyses are conducted, the information is organized
to compare findings of the evaluations for each alternative.  The objective
of this summary is to ensure that important information is presented in a
concise format so that the decisionmaker can choose the remedy that provides
the best balance of health and environmental protection, and engineering
reliability with cost.

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

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                                  CONTENTS

                                                                         Page

FOREWORD	    iii

ABSTRACT	    iv

FIGURES 	    x

TABLES	    xi

ACKNOWLEDGEMENTS	    xii

1.  EXECUTIVE SUMMARY 	    1-1

    1.1  THE NATIONAL CONTINGENCY PLAN FRAMEWORK FOR THE REMEDIAL
         RESPONSE PROCESS  	    1-3

    1.2  AN OVERVIEW OF THE FEASIBILITY STUDY PROCESS  	    1-6

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

    1.4  THE PROCESS APPLIES TO ENFORCEMENT ACTIONS 	    1-9

    1.5  SUPPLEMENTAL GUIDANCE DOCUMENTS UNDER DEVELOPMENT	    1-9

2.  DEVELOP A RANGE OF REMEDIAL ALTERNATIVES	    2-1

    2.1  OVERALL APPROACH  	    2-2

    2.2  IDENTIFY GENERAL RESPONSE ACTIONS	    2-4
         2.2.1  Identify Site Problems	    2-4
         2.2.2  Identify General Response Actions  	    2-5

    2.3  IDENTIFY AND SCREEN TECHNOLOGIES 	    2-6

    2.4  DEVELOP ALTERNATIVES BY COMBINING TECHNOLOGIES  	    2-16
         2.4.1  Source Control Remedies 	    2-18
         2.4.2  Management of Migration Remedies	    2-19

    2.5  SCREEN ALTERNATIVES FOR PUBLIC HEALTH, ENVIRONMENTAL, AND
         COST FACTORS	    2-20
         2.5.1  Environmental and Public Health Screening 	    2-20
         2.5.2  Cost Screening Factors	    2-20

                                      v

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                            CONTENTS (continued)


                                                                       Page

3.  CONDUCT A DETAILED TECHNICAL EVALUATION  	   3-1

    3.1  PERFORMANCE	   3-2
         3.1.1  Effectiveness	   3-2
         3.1.2  Useful Life	   3-3

    3.2  RELIABILITY	   3-3
         3.2.1  Operation and Maintenance Requirements	   3-3
         3.2.2  Demonstrated Performance	   3-3

    3.3  IMPLEMENT ABILITY	   3-4
         3.3.1  Constructability	   3-4
         3.3.2  Time	   3-5

    3.4  SAFETY	   3-5

    3.5  SUMMARY OF TECHNICAL FEASIBILITY ANALYSIS	   3-6

4.  EVALUATE INSTITUTIONAL REQUIREMENTS 	   4-1

    4.1  OVERVIEW OF INSTITUTIONAL REQUIREMENTS 	   4-1

    4.2  CERCLA COMPLIANCE WITH OTHER ENVIRONMENTAL STATUTES	   4-2
         4.2.1  Selection of Remedy	   4-4

    4.3  EPA GROUND-WATER PROTECTION STRATEGY 	   4-6

    4.4  COMPLIANCE WITH THE NATIONAL ENVIRONMENTAL POLICY
         ACT (NEPA)	   4-9

    4.5  COORDINATION WITH OTHER AGENCIES	   4-9
         4.5.1  Federal Emergency Management Agency 	   4-10
         4.5.2  Health and Human Services	   4-10
         4.5.3  U.S. Army Corps of Engineers	   4-11
         4.5.4  U.S. Geological Survey	   4-11
         4.5.5  Occupational Safety and Health Administration ....   4-12
         4.5.6  National Response Team	   4-12
         4.5.7  Other Government Authorities	   4-13

    4.6  COMMUNITY RELATIONS	   4-13

    4.7  SUMMARY OF INSTITUTIONAL REQUIREMENTS	   4-15

5.  EVALUATE PROTECTION OF PUBLIC HEALTH REQUIREMENTS  	   5-1

    5.1  OVERVIEW	   5-1
                                      VI

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                             CONTENTS  (Continued)


                                                                        Page

     5.2   DEVELOP  A BASELINE  SITE  EVALUATION	    5-2

     5.3   DEVELOP  AN EXPOSURE ASSESSMENT 	    5-3

     5.4   COMPARE  ALTERNATIVES TO  APPLICABLE OR RELEVANT
          ENVIRONMENTAL  STANDARDS	    5-8
          5.4.1  Assumptions  Underlying  Applicable  and  Relevant
                Standards	    5-15
          5.4.2  Resource Conservation and  Recovery Act  Hazardous
                Waste Regulations  (40 CFR  264)	    5-15
          5.4.3  National Interim  Primary Drinking  Water Standards
                (NIPDWs) and  Maximum Contaminant Levels (MCLs)....    5-16
          5.4.4  National Ambient  Air Quality  Standards  (NAAQS).  .  .  .    5-16
          5.4.5  Federal Water Quality Criteria  and State Water
                Quality Standards  	    5-17
          5.4.6  PCBs	    5-18

     5.5   CONSIDER OTHER CRITERIA  AND ADVISORIES 	    5-18
          5.5.1  Criteria for  Noncarcinogens 	    5-18
          5.5.2  Criteria for  Carcinogens	    5-18
          5.5.3  Health Advisories  (SNARLs)	    5-19

     5.6  ADJUSTMENT OF STANDARDS AND CRITERIA	    5-19

     5.7  UNAVAILABLE OR INAPPROPRIATE STANDARDS  	    5-19

     5.8  SUMMARY  OF PUBLIC HEALTH EVALUATION	    5-20

6.   EVALUATE ENVIRONMENTAL IMPACTS	    6-1

     6.1  OVERVIEW OF THE ENVIRONMENTAL  ASSESSMENT  	    6-2

     6.2  EVALUATE ALTERNATIVE RESPONSES  	    6-2
         6.2.1  Beneficial Effects of the Response	6-3
         6.2.2  Adverse Effects of the  Response	6-11

     6.3  OTHER ASSESSMENT PROGRAMS 	   6-12

    6.4  SUMMARY OF ENVIRONMENTAL ANALYSIS  	   6-12

7.  CONDUCT A DETAILED COST ANALYSIS	7-1

    7.1  ESTIMATION OF COSTS	7-3
         7.1.1  Capital  Costs	7-4
         7.1.2  Operation and Maintenance Costs	7-5
         7.1.3  Sources  of  Cost Information	7-6
                                     VII

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                            CONTENTS (Continued)
                                                                       Page
         7.1.4  Updating Costs	7-7
         7.1.5  Accuracy of Cost Estimates	7-7

    7.2  PRESENT WORTH ANALYSIS	7-8

    7.3  SENSITIVITY ANALYSIS	7-8

    7.4  SUMMARY OF ALTERNATIVES ANALYSIS	7-11

8.  SUMMARIZE ALTERNATIVES	8-1

    8.1  OVERVIEW	8-1

    8.2  CERCLA COMPLIANCE WITH OTHER ENVIRONMENTAL LAWS	   8-1
         8.2.1  Other Federal Environmental Standards, Guidance, or
                Advisories	".	   8-3
         8.2.2  State Environmental Standards, Guidance, or
                Advisories	   8-3

    8.3  ORGANIZE AND PRESENT INFORMATION 	   8-3

9.  FEASIBILITY STUDY REPORT FORMAT 	   9-1

    9.1  EXECUTIVE SUMMARY	   9-1

    9.2  INTRODUCTION	   9-1
         9.2.1  Site Background Information 	   9-3
         9.2.2  Nature and Extent of Problems	   9-3
         9.2.3  Objectives of Remedial Action	   9-4

    9.3  SCREENING OF REMEDIAL ACTION TECHNOLOGIES	   9-4

    9.4  REMEDIAL ACTION ALTERNATIVES 	   9-5

    9.5  ANALYSIS OF REMEDIAL ACTION ALTERNATIVES . : 	   9-6
         9.5.1  Noncost  Criteria Analysis 	   9-6
         9.5.2  Cost Analysis	   9-6

    9.6  SUMMARY OF ALTERNATIVES	   9-7

    9.7  RECOMMENDED REMEDIAL ACTION	   9-7

    9.8  RESPONSIVENESS  SUMMARY	   9-8

    9.9  REFERENCES	   9-8

    9.10 APPENDICES	   9-8

                                     viii

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                        CONTENTS (Continued)


GLOSSARY

REFERENCES

APPENDIX A.  FEASIBILITY STUDY MODEL STATEMENT OF WORK

APPENDIX B.  PROCEDURES FOR PLANNING AND IMPLEMENTING OFF-SITE
             RESPONSE ACTIONS

APPENDIX C.  CERCLA COMPLIANCE WITH OTHER ENVIRONMENTAL STATUTES
                                 IX

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                                   FIGURES

                                                                        Page

1-1   Current NCP Process	    1-2

1-2   RI/FS Process	    1-5

1-3   Feasibility Study Process	    1-7

2-1   Feasibility Study Alternative Development and Screening
      Process	    2-3

7-1   Feasibility Study Cost Evaluation Process	    7-2

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                                   TABLES

                                                                        Page

2-1  General Response Actions and Associated Remedial Technologies.  .   2-7

2-2  Remedial Technologies	   2-8

2-3  Site Characteristics That May Affect Remedial Technology
     Selection	   2-15

2-4  Waste Characteristics That May Affect Remedial Technology
     Selection	   2-15

3-1  Summary of Technical Feasibility Evaluation	   3-7

4-1  Applicable or Relevant Requirements	   4-16

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

5-1  Questions in Exposure Assessment 	   5-5

5-2  EPA Ambient Standards and Criteria for Superfund
     Remedial Sites 	   5-9

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

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

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

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

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

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

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

9-1  Feasibility Study Report Format	   9-2
                                      XI

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                              ACKNOWLEDGEMENTS
     This document was developed for the Office of Solid Waste and Emergency
Response and represents a collective effort of many Agency and contractor
personnel.  Richard Stanford1 and Bruce Clemens of the Policy Analysis
Staff, Office of Emergency and Remedial Response (OERR) and Douglas Amman
of the Hazardous Waste Engineering Laboratory were the EPA Co-Project
Officers.  Richard Stanford is especially acknowledged for conceptual
development and project management.  James Lounsbury, Director, Policy
Analysis Staff, OERR, Brint Bixler, OERR, and Clarence demons, Center for
Environmental Research Information, ORD contributed significantly to the
project.  Policy development efforts of James Lounsbury, Syliva Lowrance,
Douglas Cohen and Brint Bixler are acknowledged.  Doris Sanders, Robert
Cochran, and Virginia Hodge were successive project managers with JRB
Associates and associated with project coordination.  The final report is a
compilation of efforts of the following contributors:
          Remedial Alternative Development
            and Screening
Paul Rogoshewski,
  Robert Cochran,
  Virginia Hodge, JRB
  Asssociates
Richard Stanford1, U.S. EPA
          Evaluation of Technical Feasibility   William Adams, NUS Corp.
                                                Richard Stanford1, U.S. EPA
          Public Health Evaluation
Joseph Rodricks, Environ
Gilah Langner, Stephen Bailey,
  ICF Incorporated
Van Kozak, Lee Schiltz,
  Versar, Inc.
Priscilla Holzclaw, John Hall,
  U.S. EPA
          Institutional Issues
Gilah Langner, Nicholas Bauer,
  ICF, Incorporated
          Environmental Assessment
Edward Yang, James Warner,
  Environmental Law Institute
Richard Stanford1, U.S. EPA
Currently with Clean Sites, Inc.
                                    xii

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     Cost Analysis
     Summary of Alternatives
     Report Format
Robert Cochran, JRB Associates
Michael Culpepper, CH.M-Hill
Bruce Clemens, U.S. EPA
Brint Bixler, U.S. EPA
Richard Stanford
  U.S. EPA

Virginia Hodge,
  JRB Associates
                                                             1
Jeff Kolb,
     Preparation of this guidance document was  aided  greatly  by  the
constructive contributions of the following  reviewers:
     Barbara Ikalanien
     John Mateo
     Tom Voltaggio
     Anthony Rutter
     John Br ink
     Craig Wolff
     Roy Murphy
     Nancy Willis
     Brint Bixler
     G.M. Gigliotti
     Robert Kissell
     Jim Spatarella
U.S. EPA Region I
U.S. EPA Region II
U.S. EPA Region III
U.S. EPA Region V
U.S. EPA Region VIII
U.S. EPA OPPE
U.S. EPA OWPE
U.S. EPA OERR
U.S. EPA OERR
U.S. EPA CERI
Chemical Manufacturers Assn.
U.S. EPA OERR
     We also appreciate the assistance of  the  following  EPA Work Group
members:
     James Lounsbury
     Lee Modesitt
     Rob Clemens
     Helen Keplinger
     Craig Zamuda
     Stacey Katz
     Don Banning
     Gary Cohen
     Doug Ammon
     Brint Bixler
     Bob Linett
     Sam Gutter
     Abe Mittelman
     Arnold M. Kuzmack
     Chris DeRosa
     Charles Gregg
     Karen McCormack
     Heidi Hughes
Chairman
OEA
OWPE
OECM-Waste
OERR
OPPE
ORD/HWERL
OWEP
ORD/HWERL
HSCD/OERR
OWRS
OGC
OWPE
ODW
ORD/OHEA/ECAO
OW
OPTS
OECM-W
1
 Currently with Clean Sites, Inc.
                                     Xlll

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     Jerry Schwartz                         OECM-W
     Richard Robinson                       OLEP
     Gail Korb                              OARM
     Deborah Taylor                         OA

     Appreciation is also extended to the numerous other individuals from
Federal, State, industry, and environmental organizations who were contacted
on matters related to this guidance document.
                                    xiv

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                                   CHAPTER 1

                               EXECUTIVE SUMMARY
      The Comprehensive Environmental Response, Compensation, and Liability
 Act of 1980 (CERCLA)  establishes a national program for responding to
 releases of hazardous substances into the environment.  The funding
 mechanism for this program is the Hazardous Substance Response Trust Fund
 (commonly referred to as the Superfund), which provides funding for the
 studies of such releases and the development and implementation of removal
 and remedial response actions.   The operational centerpiece of this program,
 that ensures the Superfund is used as effectively as possible for these
 purposes, is the revised National Oil and Hazardous Substances Contingency
 Plan (NCP), originally promulgated under section 311 of the Federal Water
 Pollution Control Act and revised under section 105 of CERCLA.

      Executive  Order  12316 delegates to the U.S.  Environmental Protection
 Agency (EPA) the authority and  responsibility for management of the
 Superfund and implementation of the site response program.  In accordance
 with section 105 of CERCLA,  EPA has established procedures for reporting
 releases, evaluating  remedies,  determining the appropriate extent of
 response, and assuring that  remedies are cost-effective;  and has incorpo-
 rated these procedures in the NCP (47 FR 31180, July 16,  1982; 40 CFR 300)
 as  Subpart F (40 CFR  300.61-300.71).  Additional  amendments were proposed on
 February 12,  1985,  and are anticipated to be published after the publication
 of  this document.   Many of the  proposed changes in the revised NCP that
 relate to conducting  an RI/FS have been incorporated into this guidance
 document.

      Subpart  F  of  the NCP sets  forth the  process  by which remedial actions
 will  be evaluated  and selected,  shown in  Figure 1-1, and  the factors  to be
 considered in this  process under the requirements of section 105.   Response
 to  and action to minimize damage from hazardous substances releases must, to
 the  greatest  extent practicable,  be in accordance with the NCP.

      The  purpose of this  guidance document  is  to  provide  a more  detailed
 analytical  structure  to  the  framework for  identifying,  evaluating,  and
 selecting remedial  action alternatives  put  forth  in the NCP.   This  guidance
 should  be used by Federal  and State Remedial Project Managers  and  their
 contractors,  who are  responsible  for developing and preparing  supporting
 documentation for remedial actions  performed under  CERCLA.   Additionally,
 this guidance should  be  used by  Federal,  State, and private hazardous waste
management  officials  developing  remedial  actions  at  sites  where  enforcement
 actions  are  taken, or  for  which  claims  against  the  Fund are to be  presented.
                                     1-1

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                                                    Figure 1*1. Currant NCP  Process
N)
                                                         Is
                                                        there
                                                      •tin a threat
                                                     to public health.
                                                     welfare, or the
                                                      anvironmenl
                                                                                                      Remedial
                                                                                                       design
Yes


Limited
remedial
planning

-•»
|
Initial
remedial
measures

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     It is important to note that, while this document  provides  analytical
guidance to the user, it does not provide guidance on the overall management
of the remedial process, nor does it provide specific guidance on the  best
analytical techniques to use on a site-by-site basis.   Management guidance
is provided in separate EPA/State participation, enforcement, and contract
management guidance documents.  Technical guidance documents  that may  be
useful in conducting specific analyses are available or forthcoming.   These
documents are discussed further at the end of this chapter.
1.1  THE NATIONAL CONTINGENCY PLAN FRAMEWORK FOR THE REMEDIAL RESPONSE
     PROCESS
     The NCP sets forth a five step remedial response  process:

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

     2.  Preliminary assessment and site inspection (PA/SI):  The
         preliminary assessment involves the collection and  review of  all
         available information and may include off-site reconnaissance  to
         evaluate the source and nature of hazardous substances present and
         to identify the responsible party(s).  Depending  on  the  results of
         the PA, a site may be referred for further action.   Site
         inspections routinely include the collection of samples  and are
         conducted to determine the extent of the problem  and to  obtain
         information needed to determine whether a removal action is needed
         at the site or whether the site should be included  on the National
         Priorities List (NPL).

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

     4.  Remedial investigation/feasibility study (RI/FS):   Site  investi-
         gations are conducted to obtain information needed  to identify,
         select, and evaluate remedial action alternatives in the feasi-
         bility study based on technological, public health,  institutional,
                                     1-3

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         cost, and environmental factors.  The final result of this step  is
         selection of the most appropriate, cost-effective solution.  In
         some cases, the RI may show that no further action is needed.

     5.  Remedial action design and construction:  The actual design of the
         selected remedial action is developed then implemented through
         construction.

     Under step 4 above, the NCP requires that the need for appropriate
response actions must be identified in the project scoping stage, prior to
planning the RI, in order to establish a basis for RI and FS funding.  The
information from the preliminary assessment, site inspection, or other
sources is used to determine the general types of response actions
applicable to the site for use in planning the RI.  The NCP also requires
that a detailed remedial investigation and feasibility study be conducted
for the sites that are listed on the National Priorities List (section 105
of CERCLA) and targetted for remedial response under section 104 of CERCLA
in order to obtain the data necessary to define  the problem and evaluate  and
select alternative remedial measures.  The remedial investigation (RI—for
which separate guidance has been developed) provides site characterization
data that serve as the basis for development of  the feasibility study (FS).
In the FS, alternative remedial actions are developed and evaluated in terms
of cost, engineering implementation and constructability, the extent to
which each alternative provides protection to public health and the environ-
ment, and environmental impacts during or remaining after implementation.
Remedies that are developed and implemented by private parties under CERCLA
must also be consistent with the NCP.

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

     Figure 1-2 presents a flow chart of the RI/FS process, illustrating  the
interdependence and concurrence of tasks performed in the remedial  investi-
gation and feasibility study.  The numbers identifying the tasks (boxes)  in
the flow chart are keyed to the tasks in the model contract statements of
work for remedial investigations and feasibility studies, and are tabulated
under  the flow charts.  (EPA1s model statement of work for feasibility
studies is provided in Appendix A of this document.)  Chapters of this
document and  its companion document, the "Remedial Investigation Guidance
Document," which provides guidance  for performing the respective tasks  are
identified in this  figure by task.  Additionally, the figure  shows
milestones and  identifies specific  reports which may be required.
                                      1-4

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                                                                               Figure  1-2.  RI/FS  Process
 I
Ln
           REMEDIAL INVESTIGATION


It


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- History of Response Data Management Plan






I
                                                                                                                                                                                Endangerment
                                                                                                                                                                                  Assessment"
                                                                                                                                                                                Post-Closure Plan
                                                                                                                                                                                Compliance Monitoring Schedule
                                                                                                                                                                                Administrative Reports
                                                                                                                                                                                Document Control
                                                 Remedial Investigation
                                                                                                                                                   Feasibility Study
                       Model Statement of Work
                       for Remedial Investigations
            Task #1   Description of Current Situation



            Task #2   Plans & Management



            Task #3   Site Investigation

            Task #4   Site Investigation Analysis


            Task #5   Laboratory & Bench-Scale  Studies

            Task #6   Reports

            Task #7 - Community Relations Support
               t   Numbers in ihe boxes refer to tasks described in
               *   Endangerment dbsessments may be prepared at
                Guidance Document for
         Remedial Investigations Under CERCLA

     CH 1  Introduction

     CH 2 - Scoping

     CH 3 - Sampling Plan Development

     CH 4 - Data Management Procedures

     CH 5 - Health and Safety Planning for
           Remedial Investigations

     CH 6  Institutional Issues

     CH 7 - Site Characterization


     CH 8 - Pilot and Bench Studies

     CH 9  Remedial Investigation Report Format
            Model Statement of Work
              for Feasibility Studies
Task # 8 - Description of Proposed Response

Task # 9  Preliminary Remedial Technologies

Task #10  Development of Alternatives

Task #11  Initial Screening of Alternatives
 Task #12  Evaluation of Alternatives



Task #13  Preliminary Report

Task #14 -  Final Report

Task #15 - Additional Requirements
the Model Statement of Work for Rl FS under CERCLA Guidance issued February 1985  See Appendix A
dny point in tin; Rl FS ptocess in support of enforcement actions
             Guidance Document for
         Feasibility Studies Under CERCLA

  CH 1 - Executive Summary
  CH 2   Develop a Range of Remedial
         Alternatives
  CH 3 - Conduct a Detailed Technical
/        Evaluation

  CH 4  Evaluate Institutional Requirements

  CH 5  Evaluate Protection of Public Health
         Requirements

  CH 6  Evaluate Environmental Impacts

  CH 7  Cost Analysis

  CH 8  Summarize Alternatives
                                                                                                                                                              CH 9 - Feasibility Study Report Format

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1.2  AN OVERVIEW OF THE FEASIBILITY STUDY PROCESS
     The feasibility study process is outlined in Figure 1-3.  The  first
step of the feasibility study, defining the objectives of the action and
broadly developing response actions, should be performed as a refinement  to
project scoping during the remedial investigation and should be summarized
in the final remedial investigation report.  There may be modification of
this scoping as data are collected or as the general response actions are
more fully developed during the feasibility study stage.  The remedial
alternatives developed at this point are general response actions which
broadly define the nature of the response.  In general, they should address
whether source control measures (measures designed to prevent or minimize
migration of hazardous substances from the source) and/or management of
migration measures  (measures designed to mitigate the impact of contamina-
tion that has migrated into the environment) are necessary, and what phasing
of these measures (operable units) may be necessary.  The terms "source
control" and "management of migration" refer to two general categories of
response actions that are useful for developing specific alternatives. The
term "on-site response actions" in the policy on CERCLA compliance  with
other environmental laws refers to both source control and management of
migration measures.  These requirements are discussed throughout this
document.

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

     The next five activities comprise the detailed analysis of alterna-
tives, which is necessary to provide the decisionmaker with information  for
selecting the alternative that is cost-effective.  The remaining chapters of
this guidance document provide a framework for developing the necessary
analysis for making this selection.  Each chapter discusses a major aspect
of the feasibility study process.  Chapter 3 covers the engineering analysis
 Management  of migration measures have  previously  been known  as  "off-site"
 measures, as defined  in section 300.68(e)(3)  of the  NCP.   This  term has
 been  changed to  avoid  confusion between measures  involving the  minimization
 or mitigation of migration  of wastes or contaminants which have moved  away
 from  the  source, and  off-site disposal of  wastes  following removal  from  a
 site.  Management  of migration measures are measures taken to mitigate or
 minimize  the further migration of  contaminants which have already moved
 from  the  source.  Off-site  treatment or disposal  of  wastes following
 removal,  referred  to  as off-site treatment or disposal,  is generally a
 source control measure.

                                      1-6

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                                  Figure  1-3.  Feasibility  Study  Process
                                                 Characterize Problem
                                                     and Identity
                                                  General Resoonsa
                                                       Actions
                     Project Scoping
                     See 'Remedial Investigation Guidance
                     Document/  NCP 1300 681 gt
                                                     Formulate ft
                                                       Oeveloo
                                                    Alternatives £r
                                                     Technologies
                     Identify Alternatives
                     Ch  2, NCP 1300 631 g)
          Tecnntcai Analysis
Ch  3              I
NCP 4300 68(hH3HiM2HA)
                                                      Technical
                                                      Screening
                                                  Environmental and
                                                     Public Health
                                                   Cost Screening
                                                  identify Alternative
                                                  Remedial Actions
                                Public Health
                                  Analysis
                   Ch 5
               NCP *30068lhM3)li)l2HD) ' >
                                                                            Screen Alternatives/ Technologies
                                                                            Ch  2. NCP «30Q68(hH1).(2U3}
                                                    Cost Analysis
  |Ch  7
NCP l30068lh)(3)(iH2HB)
                                      Institutional
                                       Analysis
         Ch 4
NCP i300 68(h)(3)li)l2)(C)
                 Environmental
                   Analysis
                                                      Summary
                                                    of Alternatives
                                                                       Ch  8
                                 Oetan«d Analysis
                                 of Alternatives

                                 Cost-Effectiveness
                                 Analysis
                                 NCP ^300 68lnH3)!i)(2)
                                                   Final Feasibility
                                                       Report
                   Ch 9*
     Note NCP sections identified refer to those cited in the Federal Register July 16 1982

     'Not specified sections of the NCP
                                                                  1-7

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of the alternatives in terms of constructability and reliability to ensure
the implementability of alternatives.  Chapter 4 covers the institutional
analysis of alternatives in terms of the Federal, State, or local standards,
advisories, or guidance that must be attained or considered to protect the
public health, welfare, and environment.  Chapter 5 covers public health
exposure evaluation, and chapter 6 covers the environmental analysis of
alternatives.  The evaluation of the costs of alternatives is discussed in
chapter 7.  Chapter 8 provides guidance on how to organize and summarize the
information developed in analyses described in previous chapters.  The
objective of this summary is to ensure that important information is
presented in a concise format so that the decisionmaker can choose the
remedy that provides the best balance of health and environmental
protection, and engineering reliability with cost.

     Chapter 9 discusses the format of the report for the feasibility study.
It identifies the elements of the feasibility study report, the rationale
for their inclusion, the level of detail, and the documentation necessary to
accompany the report.
1.3  REMEDIAL ALTERNATIVES MUST ADDRESS THE REQUIREMENTS OF OTHER
     ENVIRONMENTAL LAWS
     EPA's current policy, regarding compliance of CERCLA response actions
with the requirements of other environmental laws, is to give primary con-
sideration to the selection of those response actions that are effective  in
preventing or, where prevention is not practicable, minimizing the release
of hazardous substances so that they do not migrate to cause substantial
danger to present or future public health, welfare, or the environment.   As
a general rule, this can be accomplished by pursuing remedies that meet the
standards of applicable or relevant Federal public health or environmental
laws.  However, because of the unique circumstances at particular sites,
there may be alternatives that do not meet the standards of other laws, but
which still provide protection of public health, welfare, and the environ-
ment.  For example, at certain sites, it may be technically impractical,
environmentally unacceptable, or excessively costly to implement a response
action that fully attains the requirements of the laws.

     This policy effectively examines response actions which prevent
hazardous substances from migrating into the environment and actions which
minimize migration, recognizing that CERCLA primarily addresses inadequate
past disposal practices and resultant unique site conditions.

     On-site source control or management of migration measures will not
require environmental permits; however, off-site waste treatment, storage,
or disposal must be at a facility permitted under the appropriate
environmental law.  However, this requirement does not prohibit a State or
local authority from fulfilling their respective permitting requirements.
The application of this policy in developing and selecting remedies at
                                     1-8

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Superfund sites is discussed in subsequent chapters.  EPA has  also  included
requirements of this policy in the proposed revisions to the NCP.
1.4  THE PROCESS APPLIES TO ENFORCEMENT ACTIONS
     Enforcement actions must follow the  same analytical  steps  for  develop-
ing and evaluating remedial actions as Federal- and  State-lead,  Fund-financed
actions.  Additionally, to support enforcement case  preparation,  regional  and
State project managers and their contractors may be  required  to  prepare  endan-
germent assessments and remedial options  negotiations documents.  Basically,
these documents characterize the threat to public health  and  the  environment
posed by the site and the alternatives for mitigating that threat.

     Chapter 10 (forthcoming) discusses in greater detail enforcement
actions and necessary support documentation.  The chapter identifies the
procedures governing potential responsible party (PRP) participation in  the
development of the RI/FS.  The chapter highlights stages  of PRP participa-
tion in an RI/FS that are unique from an  enforcement perspective.   The
chapter also addresses the differences between PRP and Fund-financed RI/FS.
1.5  SUPPLEMENTAL GUIDANCE DOCUMENTS UNDER DEVELOPMENT


     The user should be aware of additional policy, management, and
technical guidance that may affect the conduct of the FS.  Some of the most
important of these include:

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

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

     •  "Guidance for Remedial Investigations under CERCLA"

     •  "Methodology for Screening and Evaluation of Remedial Responses"

     •  Surface Cleanup Guidance for Drums, Tanks, and Lagoons
     •  Guidance for Alternative Water Supply

     •  "Remedial Action Costing Procedures Manual"

     •  "Compendium of Costs for Remedial Technologies"
     •  "Superfund Public Health Procedures"

     •  "Health Effects Assessment Documents"

     •  "Superfund Exposure Assessment Manual"

     •  "Endangerment Assessment Guidance"

     •  "User's Guide to the Contract Laboratory Program"
                                     1-9

-------
     •  "State Participation in the Superfund Remedial Program"
     •  "Community Relations in Superfund:  A Handbook."

While many of these documents are available, several are currently  in pre-
paration and will be forthcoming.
                                      1-10

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                                  CHAPTER 2

                  DEVELOP A RANGE OF REMEDIAL ALTERNATIVES
     The National Oil and Hazardous Substances Contingency Plan (NCP) out-
lines a process for identifying, developing, and evaluating remedial action
alternatives for a given site.  The process begins with project scoping,
discussed in chapter 2 of the EPA's "Remedial Investigation Guidance
Document."  As part of project scoping, general response actions to remedy
known problems at the site are identified (based upon existing data) as a
basis for planning the Remedial Investigation and Feasibility Study.
Remedial response actions fall into three general categories:  initial
remedial measures , source control, and management of migration.  NCP
project scoping requirements are specified in NCP Section 300.68(d) , which
states in part:

     (d)  The lead agency, in cooperation with the State(s), will examine
          available information and determine...the type or types of
          remedial response that may be needed to remedy the release.  This
          scoping will serve as the basis for requesting funding for a
          remedial investigation and feasibility study....

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

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

     (g)  Development of Alternatives.  A limited number of alternatives
          should be developed for either source control or [management of
 The proposed revisions to the NCP eliminate initial remedial measures as a
 remedial response category.  Response actions conducted previously as
 initial remedial measures will, in the future, be considered removal
 actions, source control measures, or management of migration measures.

2Federal Register, Vol. 47, No. 137, July 16, 1982.


                                     2-1

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          migration] (or both) depending upon the type of response that has
          been identified...as being appropriate.

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

     (i)  Detailed Analysis  of Alternatives.  (1) A more detailed evaluation
          will be conducted  of .the limited number of alternatives that
          remain after the initial screening....

This chapter is a guide to the first two phases of this process.  Chapters 3
through 7 of this document provide guidance on the third phase, the detailed
analysis of alternatives.
2.1  OVERALL APPROACH
     The recommended alternative development and screening procedure (Figure
2-1) consists of six steps.

Identify General Response Actions

     1.  Identify site problems and pathways of contamination (remedial
         investigation) .

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

Identify and Screen Technologies and Develop Remedial Alternatives

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

     4.  Assemble technologies into operable units based on the remaining
         feasible technologies.

Screen Public Health, Environmental, and Cost Factors

     5.  Screen alternatives, eliminating those that have significant ad-
         verse impacts or that obviously do not adequately protect the
         environment, public health, and public welfare.
3
 Detailed guidance for identifying pathways is forthcoming in the Public
 Health Procedures Manual.
                                     2-2

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                    Figure 2-1. Feasibility Study Alternative Development and Screening Process
NJ
I
U)
r ^
| Identify
I Site
| (Remedial
| Investigation)
i .. _ ., . 	 i





*




Identify
General
Response
Actions


Conduct
Environmental
and Public
Health
Screening






Identify and
Screen
Technologies


Conduct
Pn«!t
Screening






Assemble
Alternatives


Alternatives
for
Detailed
Analysis







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     6.  Screen alternatives, eliminating those that are an order of magni-
         tude higher in cost than other alternatives but do not provide
         significantly greater environmental or public health benefits or
         technical reliability.

     Developing and screening remedial alternatives is actually a repetitive
process that may take place at several points in the RI/FS process.  The
process may begin during the remedial investigation to define the field data
requirements of specific remedial action alternatives.  As more site data
are collected, existing alternatives may be rescreened, or additional alter-
natives developed to reflect improved understanding of the site.  Screening
may also occur during the detailed analysis of alternatives if it is decided
that an alternative should not be considered further, based upon the
screening criteria discussed in steps 5 and 6 (the reasons for such a
decision must be clearly documented).

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

     The alternative development and screening steps described in the
following sections of this chapter are presented rather formally, but the
process is generally a more informal matter of using established engineering
practices.  The formal process, summarized below, need not be followed
rigidly, but it should be used as a framework for documenting the initial
screening decisions.
2.2  IDENTIFY GENERAL RESPONSE ACTIONS


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


     2.2.1  Identify Site Problems


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

                                     2-4

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

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


     2.2.2  Identify General Response  Actions


     Based on site information from the remedial investigation, the  user
should identify general response actions, or classes of response without
necessarily identifying specific technologies.  General response actions
considered should include the "no action" alternative as  a baseline  against
which other measures can be measured.  Examples of general response  actions
include the following:
                 5
     •  No action"

     •  Containment

     •  Pumping

        - On-site

        - Off-site

     •  Collection

     •  Diversion

     •  Complete removal

     •  Partial removal

     •  On-site treatment

     •  In situ treatment

     •  Storage

     •  On-site disposal

     •  Off-site disposal

     •  Alternative drinking water supply

     •  Relocation of receptors

     •  Other off-site measures.
4T
 In preparation.

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

                                     2-5

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2.3  IDENTIFY AND SCREEN TECHNOLOGIES
     The user should identify feasible technologies for each general res-
ponse action identified, recognizing that there may be compatible and incom-
patible combinations of source control and management of migration measures.
Table 2-1 is a partial list of technologies appropriate to the general
response actions described above.  Some technologies should be modified or
eliminated, such as those that may prove extremely difficult to implement,
may not achieve the remedial objective in a reasonable time, or may rely on
unproven technology.

     Table 2-2 is a comprehensive list of remedial technologies classified
according to the kinds of site problems they are intended to mitigate.  For
technologies that can be used in various configurations, several "function
options" are also given.  Similarly, where different materials may be used
in the same technology, "materials options" are provided.  The user should
refer to the EPA "Handbook for Remedial Action at Waste Disposal Sites"
(June 1982) for a more comprehensive description of these technologies.
During technology screening, the use of this list will help ensure that all
remedial technologies are considered.  The list should be updated periodi-
cally to incorporate newly developed technologies.

     The user should review site data to identify conditions that may limit
or promote the use of certain remedial technologies.  Such information is
generally gathered during the site investigation or remedial investigation.
Table 2-3 identifies site characteristics that should be evaluated as part
of the screening process.  Technologies whose use is clearly precluded by
site characteristics should be eliminated from consideration.

     The user should also identify waste characteristics that limit the
effectiveness or feasibility of the remedial technologies.  Such character-
istics include:  (1) physical properties such as volatility, solubility, and
density; (2) specific chemical constituents such as chlorinated organic
chemicals or metals; and (3) properties that determine the waste's toxicity
or degree of hazard, such as persistence, acute toxicity, and ignitability.
Table 2-4 presents waste characteristics that may influence the feasibility
and effectiveness of remedial actions.  Technologies clearly limited by
waste characteristics should be eliminated from consideration.

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

     The user may wish to use a previously developed methodology that
presents feasible remedial technologies and their limiting waste, site, and
technology characteristics.  The EPA manual "Methodology for Screening and
                                      2-6

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             TABLE 2-1.  GENERAL RESPONSE ACTIONS AND ASSOCIATED
                            REMEDIAL TECHNOLOGIES
General Response
     Action
                      Technologies
No Action

Containment


Pumping

Collection


Diversion



Complete Removal


Partial Removal

On-site Treatment


Off-site Treatment


In Situ Treatment


Storage

On-site Disposal

Off-site Disposal

Alternative Water
  Supply


Relocation
Some monitoring and analyses may be performed.

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

Ground water pumping; liquid removal; dredging.

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

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

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

Tanks; drums; soils; sediments; liquid wastes.

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

Incineration; biological, chemical, and physical
treatment.

Permeable treatment beds; bioreclamation; soil
flushing; neutralization; land farming.

Temporary storage structures.

Landfills; land application.

Landfills; surface impoundments; land application.

Cisterns; aboveground tanks; deeper or
upgradient wells; municipal water system; relocation
of intake structure; individual treatment devices.

Relocate residents temporarily or permanently.
                                     2-7

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                 TABLE 2-2.  REMEDIAL TECHNOLOGIES
A.  Air Pollution Controls

    •  Capping

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

    •  Dust Control Measures

       - Polymers
       - Water

B.  Surface Water Controls
    •  Capping (see A.)

    •  Grading

       - Scarification
       - Tracking
       - Contour furrowing

    •  Revegetation

       - Grasses
       - Legumes
       - Shrubs
       - Trees, conifers
       - Trees, hardwoods

    •  Diversion and Collection Systems

       - Dikes and berms
       - Ditches and trenches
       - Terraces and benches
       - Chutes and downpipes
       - Seepage basins
       - Sedimentation basins  and  ponds
                                                             (continued)
                                 2-8

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                      TABLE 2-2.  (continued)
       - Levees
       - Addition of freeboard
       - Floodwalls

C.  Leachate and Ground Water Controls

    •  Capping (see A.)

    •  Containment barriers

       Function options

       - Downgradient placement
       - Upgradient placement
       - Circumferential placement

       Material and construction options (vertical barriers)

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

       Horizontal barriers (bottom sealing)

       - Block displacement
       - Grout injection

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

       Function options

       - Extraction and injection
       - Extraction alone
       - Injection alone

       Equipment  and Material Options

       - Well points
       - Deep wells
                                                            (continued)
                                2-9

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                      TABLE 2-2.  (continued)
       - Suction wells
       - Ejector wells

    •  Subsurface Collection Drains

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

D.  Gas Migration Controls (generally used with treatment)

    •  Capping (gas barriers) (see A.)

    •  Gas collection and/or recovery

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

E.  Excavation and Removal of Waste and Soil

    •  Excavation and removal

       - Backhoe
       - Cranes and attachments
       - Front end loaders
       - Scrapers
       - Pumps
       - Industrial vacuums
       - Drum grapplers
       - Forklifts and attachments

    •  Grading (see B.)

    •  Capping (see A.)

    •  Revegetation (see B.)

F.  Removal and Containment of Contaminated Sediments

    •  Sediment removal
                                                             (continued)
                                2-10

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                      TABLE 2-2.  (continued)
       Mechanical dredging

       - Clamshell
       - Dragline
       - Backhoe

       Hydraulic dredging

       - Plain suction
       - Cutterhead
       - Dustpan

       Pneumatic dredging

       - Airlift
       - Pneuma
       - Oozer

    •  Sediment turbidity controls and containment

       - Curtain barriers
       - Coffer dams
       - Pneumatic barriers
       - Capping

G.  In Situ Treatment
       Hydrolysis
       Oxidation
       Reduction
       Soil aeration
       Solvent flushing
       Neutralization
       Polymerization
       Sulfide precipitation
       Bioreclamat ion
       Permeable treatment beds
       Chemical dechlorination
                                                            (continued)
                                2-11

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                      TABLE 2-2.  (continued)
H.  Direct Waste Treatment

    •  Incineration

       - Rotary kiln
       - Fluidized bed
       - Multiple hearth
       - Liquid injection
       - Molten salt
       - High temperature fluid wall
       - Plasma arc pyrolysis
       - Cement kiln
       - Pyrolysis/starved combustion
       - Wet air oxidation
       - Industrial boiler or furnace

    •  Gaseous waste treatment

       - Activated carbon
       - Flares
       - Afterburners

    •  Treatment of aqueous and liquid waste streams

       Biological treatment

       - Activated sludge
       - Trickling filters
       - Aerated lagoons
       - Waste stabilization ponds
       - Rotating biological disks
       - Fluidized bed bioreactors

       Chemical treatment

       - Neutralization
       - Precipitation
       - Oxidation
       - Hydrolysis
       - Reduction
       - Chemical dechlorination
       - Ultraviolet/ozonation
                                                             (continued)
                                2-12

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               TABLE 2-2.  (continued)
Physical treatment

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

Discharge to a publicy owned treatment works

Solids handling and treatment

Dewatering

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

Treatment

- Neutralization
- Solvent
- Oxidation
- Reduction
- Composting

Solidification, stabilization, or fixation

- Cement-based
                                                     (continued)
                         2-13

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                      TABLE 2-2.  (continued)
       - Lime-based
       - Thermoplastic
       - Organic polymer
       - Self-cementing techniques
       - Surface encapsulation
       - Classification
       - Solidification (i.e., to fly ash, polymers, sawdust)

I.  Land Disposal Storage

       Landfills
       Surface impoundments
       Land application
       Waste piles
       Deep well injection
       Temporary storage

J.  Contaminated Water Supplies and Sewer Lines

    •  In situ cleaning

    •  Removal and replacement

    •  Alternative drinking water supplies

       - Cisterns or tanks
       - Deeper or upgradient wells
       - Municipal water systems
       - Relocation of intake

    •  Individual treatment units
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             TABLE 2-3.  SITE CHARACTERISTICS THAT MAY
               AFFECT REMEDIAL TECHNOLOGY SELECTION
Site volume
Site area
Site configuration
Disposal methods
Climate (precipitation,
  temperature, evaporation)
Soil texture and permeability
Soil moisture
Slope
Drainage
Vegetation
Depth of bedrock
Depth to aquicludes
Degree of contamination
Direction and rate of
  ground water flow
Receptors
Drinking water wells
Surface waters
Ecological areas
Existing land use
Depths of ground water or plume
        TABLE 2-4.  WASTE CHARACTERISTICS THAT MAY AFFECT
                   REMEDIAL TECHNOLOGY SELECTION
Quantity/concentration
Chemical composition
Acute toxicity
Persistence
Biodegradability
Radioactivity
Ignitability
Reactivity/corrosivity
Infectiousness
Solubility
Volatility
Density
Partition coefficient
Compatibility with other chemicals
Treatability
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Evaluation of Remedial Responses"  presents one  such  approach, with
screening tables showing  site, waste,  and  technology  limitations  for
remedial alternatives under each general class.  The  manual  also  has  a
checklist for tracking technologies not excluded by the  limitations given  in
the tables.  This and similar methodologies, however,  should  serve only  as
guides for screening.  They cannot substitute  for  acceptable  engineering
practice in screening technologies.

     The user should give special consideration  to technologies that  perman-
ently contain, immobilize, destroy, or recycle contaminants,  and  technolo-
gies that promote energy  recovery.  Also,  certain  technologies often  are
used in combination, and  the user should have a working  knowledge of  those
technologies.  EPA is currently drafting guidance  for the consideration  of
these technologies.
2.4  DEVELOP ALTERNATIVES BY COMBINING TECHNOLOGIES
     Technologies that have passed the technology screening can be used  to
form more definite alternatives.

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

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

     (a)  Alternatives for treatment or disposal at an off-site facility
          approved by EPA (including RCRA, TSCA* CWA,  CAA, MPRSA, and SDWA
          approved facilities), as appropriate;
 In preparation.

 These alternatives must be consistent with  EPA  Policy  "Procedures  for
 Planning and Implementing Off-Site Response Actions" (see Appendix B).   In
 some cases, off-site disposal or  treatment may  not  be  feasible  and this
 alternative may be eliminated during initial  screening of alternatives.
 The decision documents should reflect this  screening.
                                     2-16

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

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

     (d)  Alternatives which do not attain applicable or relevant public
          health or environmental standards but will reduce the likelihood
          of present or future threat from the hazardous substances.  This
          must include an alternative which closely approaches the level of
          protection provided by the applicable or relevant standards and
          meets CERCLA's objective of adequately protecting public health,
          welfare, and environment.

     (e)  A no action alternative.

     Since ground water contamination is the most frequent type of problem
at NPL sites, the corrective action requirements of Subpart F of the RCRA
regulations (40 CFR Part 264) will be applicable or relevant in many cases
and should be included in alternatives developed under category (b).  Under
the RCRA regulations, corrective actions must attain a ground water cleanup
standard established for each facility.  For a limited number of
potential contaminants, a standard is specified in the regulations at levels
corresponding to National Interim Primary Drinking Water Standards developed
pursuant to the Safe Drinking Water Act.  An alternate concentration limit
(ACL) may be established for any contaminant upon a determination that the
ACL will "not pose a substantial present or potential hazard to human health
or the environment as long as the alternate concentration limit is not
exceeded" [40 CFR 264.94(b)l-  In the absence of an ACL or a standard based
on Safe Drinking Water Act determinations, the ground water protection stan-
dard is background.  The RI/FS should examine whether an ACL is appropriate
at each site where the Subpart F regulations are applicable or relevant.

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

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     Since  the RCRA ground-water protection  program  is  relatively  new,
experience  to date in implementing alternate  concentration  limits  is
limited.  Needed additional guidance  is being  prepared  for  Regional use.
This guidance will discuss factors and conditions  that  may  be  used in
evaluating  alternate concentration limits.

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

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

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

     The NCP specifies that remedial  alternatives, besides  filling each of
the categories, should be classified  either  as source control  [40  CFR
300.68(e)(2)] or off-site (management of migration)  remedial actions [40  CFR
300.68(e)(3)].  The distinction significantly  affects the level of detail
necessary in evaluating remedies.  Source control  remedial  actions address
situations  in which hazardous substances remain at or near  the  areas in
which they  were originally located and are not adequately contained to
prevent migration into the environment.  Off-site  remedial  actions address
situations  in which the hazardous substances  have  largely migrated from
their original locations.  Off-site actions  are now  referred to as manage-
ment of migration actions, to distinguish actions  involving management of
migration from those involving hazardous substance removal  and  disposal in
off-site facilities.  Alternatives developed may  fall solely in either
classification or may involve a combination  of source control  and  management
of migration measures, as determined  by the  specific site problems
addressed.
     2.4.1   Source Control Remedies
     The purpose of  source  control  remedies  is  to  prevent  or  minimize
migration of hazardous  substances  from  the  source  material.   These remedies
may be  applied  to  situations  in which contaminants are  in  the soil,  a
lagoon, or a.pond.   The  extent and  route  of  the release and/or the threat of
release must be documented  to justify specific  source control measures.

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

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

      Where a source  control alternative  involves off-site  treatment [an
 alternative in category  (a)],  destruction,  or disposal  of  wastes following
 removal, section  300.70(c)  of the  NCP  requires  that EPA determine that this
 alternative is either  "(1) more  cost-effective  than other  remedial  actions;
 (2) will create new  [waste  management] capacity...; or  (3) is necessary to
 protect  [human health  and the  environment]...."  To aid in this evaluation,
 the user must, in  those  instances  where an  off-site transport,  treatment,
 storage, or disposal alternative is  among the list  of response  actions,
 include  a comparable on-site  alternative for  evaluation.   For example, when
 off-site disposal  at a landfill  approved under  RCRA is  among  the alterna-
 tives to be evaluated, construction  of such a landfill  on  the  site  should be
 evaluated as well.
     2.4.2  Management of Migration Remedies
     Management of migration remedial actions are necessary where hazardous
substances have migrated  from the original  source of contamination  and  pose
a significant threat to public health, welfare, or the environment;  for
example, where contamination exceeds relevant and applicable public  health
or environmental standards, guidance, and advisories.  Any management of
migration measure that adequately protects  public health, welfare,  and  the
environment (by reducing  contaminant levels) should be considered for imple-
mentation.  Particular consideration should be given to technologies that
permanently contain, immobilize, destroy, or recycle contaminants.

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

     Management of migration alternatives may also involve measures that
prevent or minimize impacts through means such as substitution.  An example
of such an alternative would be provision of an alternative drinking water
source in cases where ground water contamination threatens private welj.s.
                                     2-19

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2.5  SCREEN ALTERNATIVES FOR PUBLIC HEALTH, ENVIRONMENTAL, AND COST FACTORS


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

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

     In some situations, screening may eliminate all alternatives in one of
the five categories listed above under Section 2.4, "Develop Alternatives by
Combining Technologies."  When this occurs, at least one alternative for the
category that was eliminated must be included in the summary of alternatives
presentation described in chapter 8 and should be presented to the decision-
maker with an explanation as to why it was eliminated at the screening
stage.
     2.5.1  Environmental and Public Health Screening
     The user should identify adverse impacts on the environment or on
public health and welfare that may preclude the use of each assembled
alternative.  Alternatives that may have significant adverse impacts or do
not adequately protect the environment and public health should be
eliminated.  At this point, adequate protection should be thought of as a
comprehensive response that addresses all pathways and points of exposure.
The user should identify alternatives that provide similar environmental and
public health and welfare benefits in preparation for the cost screening.


     2.5.2  Cost Screening Factors


     The object of the cost screening is to eliminate alternatives that have
costs an order of magnitude greater than those of other alternatives but do
not provide greater environmental or public health benefits or greater
reliability.

     In preparing cost estimates for screening, certain limiting factors
should be considered to control the level of effort expended in compiling
the estimates.  These factors include accessibility of data sources, the
time available, and the degree of accuracy to be achieved.  The following
                                     2-20

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guidelines are recommended for use when defining the level of effort in cost
screening:
     •  Data sources should be limited to the "Remedial Actions Cost
        Compendium" (ELI, 1984), Handbook:  Remedial Action at Waste
        Disposal Sites (U.S. EPA, 1982), the remedial investigation (for
        revising design assumptions where necessary), standard costs
        indices, and other readily available information.
     •  The time for preparing screening cost estimates should be limited to
        a few days.
     •  The objective in calculating the costs is to achieve an accuracy
        within -50 to +100 percent.
     Cost screening should be undertaken for all remedial alternatives
remaining from the public health and environmental screening.  The cost
screening can be divided into three basic tasks:  (1) estimation of costs,
(2) present worth analysis, and (3) cost screening evaluation.
         2.5.2.1  Estimation of Costs

     Remedial alternatives are screened on the basis of both capital costs
and operating and maintenance costs.  These costs should reflect site-
specific conditions and should be revised using the cost compendium (ELI,
1984) or other standard cost guidance references.
     Capital costs should include the following:
     •  Relocation costs
     •  Costs of land acquisition or obtaining permanent easements
     •  Land and site development costs
     •  Costs of buildings and services
     •  Equipment costs
     •  Replacement costs
     •  Disposal costs
     •  Engineering expenses
     •  Construction expenses
     •  State and local legal fees,  licenses,  and permit costs
     •  Contingency allowances
     •  Startup  and shake-down costs
     •  Costs of anticipated health  and safety requirements  during
        construction.
                                     2-21

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Care should be taken to ensure that all applicable cost components are
considered in the capital cost estimate.

     Operation and maintenance costs should include, where applicable, the
following:

     •  Operating labor costs
     •  Maintenance materials and labor costs
     •  Costs of auxiliary materials and energy
     •  Purchased service costs
     •  Administrative costs

     •  Insurance, taxes, and licensing costs
     •  A maintenance reserve and contingency fund.

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


         2.5.2.2  Present Worth Analysis


     After developing screening cost data, the user must determine the
present worth of both the capital and other expenditures.  Discounting to
present worth is necessary when operation and maintenance costs are
anticipated  for one or more alternatives.  Present worth (or present value)
analysis enables the user to compare sets of costs by computing the current
value of all costs incurred, whether they are incurred in the present  or at
some future  date.  The present worth analysis conducted during screening
relies on less refined cost data but is otherwise  identical  to the present
worth analysis conducted during detailed cost estimation.  This analysis
should be based on the OMB-prescribed  10 percent discount rate.  However,  a
quick calculation of alternative discount rates may be desirable (e.g., 4  or
7 percent) to observe sensitivity of overall estimates to discount rates.
This check is most useful' in cases that involve  future replacement costs.
The procedures for conducting a present worth analysis are discussed  in
detail  in the EPA "Costing Procedures Manual."
Q
 In preparation.
                                      2-22

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     In some cases, wastes removed from a site, such as fuel oils or other
hydrocarbons, may be recoverable.  In such cases, revenues from the sale of
removed materials should be considered in the present worth analysis.
         2.5.2.3  Cost Screening Evaluation
     The user should compare present worth costs of competing alternatives
with similar environmental, public health, and public welfare benefits.
Alternatives should be eliminated if they are deemed much more expensive (an
order of magnitude or more) and offer similar or smaller environmental and
public health benefits but no greater reliability than competing alterna-
tives.  Alternatives that are more expensive but offer substantially greater
environmental and/or health benefits should not be eliminated.
                                     2-23

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                                   CHAPTER  3

                   CONDUCT A  DETAILED  TECHNICAL EVALUATION
     One of the  first concerns  in  the  detailed  analysis  of  alternatives  is
that suggested technologies  are  appropriate  to  site  conditions.   Section
300.68(i)  of the National Oil  and Hazardous  Substances  Contingency Plan
(NCP) requires the  following:

     (i)   Detailed Analysis of  Alternatives

           (1)   A more detailed  evaluation will be conducted  of  the limited
                 number of alternatives  that  remain after the  initial
                 screening....

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

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

                 (C)  Evaluation  in terms  of engineering  implementation,  or
                     constructability....

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


     Each remedial alternative is evaluated for performance,  reliability,
implementability, and safety.  EPA's publication "Methodology for  Screening
and Evaluation of Remedial Responses,"  the Army Corps of Engineers'
Engineer Manual  "Preliminary Guidelines for Selection and Design of  Remedial
Systems for Uncontrolled Hazardous Waste  Sites" (EC  1110-2-244),  and the EPA
"Handbook for Remedial Action at Waste Disposal Sites" (1982)  provide useful
information.   The resulting estimates of  alternatives' technical  feasibility
are included in  the summary of alternatives discussed in chapter 8.   The
elements of technical feasibility are discussed, and  a suggested  format  for
summarizing these evaluations is presented in the remainder of this  chapter.
federal Register, Vol. 47, No. 137, July 16, 1982.
2
 In preparation.
                                    3-1

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3.1  PERFORMANCE
     Two aspects of remedial actions determine  their  desirability  on the
basis of performance:  effectiveness and useful life.  Effectiveness refers
to the degree to which an action will prevent or minimize  substantial danger
to public health, welfare, or the environment.  The useful  life  is  the
length of time this level of effectiveness  can  be maintained.
     3.1.1  Effectiveness
     Remedial alternatives should be evaluated  in  terms  of  their  ability to
perform intended functions, such as containment, diversion,  removal,
destruction, or treatment.  The effectiveness of alternatives  should  be
determined either through design specifications or by performance  evalu-
ation.  These two methods are discussed  further below and in chapter  5 with
respect to evaluations of public health  protection.

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

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

     Standards, criteria, or guidance are not available  for  all situations
at hazardous waste sites; in these cases, performance specifications  based
on acceptable engineering practice must  be developed and used  in  evaluating
alternatives.  The user should give preference  to  those  technologies  that
completely immobilize, destroy, or recycle the  hazardous material, or pro-
mote energy recovery.

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

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

     •  Floodpiain impacts

                                    3-2

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     •   Seismic,  landslide,  subsidence,  or volcanic  impacts

     •   Site geology  (for  example,  is  the site  underlain  by  fractured
         bedrock or karst topography).

These factors should  be considered  to  determine if on-site alternatives  can
be effective.  Engineering modifications may be necessary to mitigate
adverse  locational impacts,  if  appropriate.
     3.1.2  Useful Life
     Most remedial technologies, with  the  possible  exception  of  destruction,
deteriorate with time.  Often, deterioration  can be slowed  through  proper
operation and maintenance, but the  technology eventually may  require  re-
placement.  Each alternative  should be  evaluated in terms of  the projected
service  lives of its component technologies.   Resource  availability in the
future life of the technology, as well  as  the appropriateness  of the  tech-
nologies, must be considered  in estimating  the useful life  of  the project.
3.2  RELIABILITY
     The cost of installing  and operating  remedial  alternatives  and  the
importance of protecting  public health  and  the  environment make  reliability
a serious concern.  Two aspects of remedial  technologies  that  provide  infor-
mation about reliability  are their operation  and maintenance requirements
and their demonstrated reliability at similar sites.
     3.2.1  Operation and Maintenance Requirements
     Evaluations of the operation and maintenance  requirements  of  remedial
alternatives should emphasize the availability of  labor  and materials  as
well as their costs.  Also, the  frequency  and complexity of necessary  opera-
tion and maintenance should be considered  in evaluating  the reliability of
alternatives.  Technologies requiring frequent or  complex  operation  and
maintenance activities should be regarded  as less  reliable than technologies
requiring little or straightforward operation and  maintenance.
     3.2.2  Demonstrated Performance
     The technical analysis of remedial alternatives  should not be based  on
the presumed performance of untested methods.  An estimate of  the probabili-
ty of failure, in either qualitative or quantitative  terms, should be made
for each component technology and for the complete alternative.  The user
should give preference to technologies that have proven effective under

                                    3-3

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waste and site conditions similar to those  anticipated.   However,  innovative
or advanced technology should be evaluated  as  an  alternative  to  conventional
technology, if appropriate.  Sometimes bench-scale  studies will  be necessary
to determine actual performance characteristics;  these studies may be  part
of the remedial investigation or the design phase.

     As more experience is gained in applying  and developing  remedial  tech-
nologies, a broader range of activities will have demonstrated performance.
At present, many technologies are still in  the research  and development
stages.  If such developmental technologies are included  in suggested
remedial alternatives, the user should be certain to  include  information
from researchers supporting its use and evaluating  its expected  reliability.

3.3  IMPLEMENTABILITY
     Another important aspect of remedial alternatives  is  their  implement-
ability—the relative ease of installation and the time required  to  achieve
a given level of response.  Ease of installation, often known  as  construct-
ability, is determined by conditions both internal and external  to the  site.
The time requirements can be generally classified as the time  required  to
implement a technology and the time required before results are  actually
realized.
     3.3.1  Constructability


         3.3.1.1  Site Conditions
     The constructability of remedial technologies under  actual  site  condi-
tions is fundamental to the technical analysis of alternatives.   The  ability
to actually build, construct, or implement the remedial technology  on the
site must be assessed.
         3.3.1.2  Conditions External to the Site
     Conditions external to the site that affect the implementability of
remedial technologies include the availability and  acceptability  of  off-site
disposal sites and the equipment available for construction.

     Certain remedial activities may require zoning clearances  and local
permits in addition to compliance with applicable State and Federal  regula-
tions.  Chapter 4 discusses some of these statutes  in more detail.   In
addition, the public acceptability of the alternative can be of fundamental
importance in determining the implementability of the action.
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     3.3.2  Time
     The time element of remedial  efforts  is  an  important  aspect  of site
remedial planning.  Emphasis  should be on  quickly  eliminating  exposure  to
hazardous substances.  Two measures of time  that  should  be addressed are the
time it takes to implement a  remedy and  the  time  it  takes  to realize bene-
ficial effects.  The importance  of timing  depends  on the nature  of the
hazard; speed is most important  at sites presenting  immediate, rather than
long-term, hazards.
         3.3.2.1  Time  to  Implement


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


         3.3.2.2  Time  to  Achieve  Beneficial Results
     Some remedial alternatives achieve  instantaneous  results  (e.g.,  surface
cleanup or the provision of alternative  water  supplies).   Often,  though,
considerable time is required  from the beginning of  construction  until  the
desired results are achieved.  During this period, ancillary measures,  such
as the temporary provision of  alternative potable water  supplies  or  tem-
porary relocation, are commonly taken to mitigate the  threat.   The user
should evaluate each alternative  in terms of the time  it  takes  to see bene-
ficial results in the environment, exclusive of measures  that  provide tem-
porary protection.  Beneficial results should  be defined  as the reduction in
levels of contamination necessary to attain or exceed  relevant  or applicable
standards.  RCRA standards for corrective action require  meeting  background
MCLs or ACLs within a reasonable  period  of time.  While no specific  length
of time has been specified, the U.S. EPA Office of Solid  Waste  considers
several years to be reasonable, depending on specific  site conditions.
Where no applicable or relevant standards are  available,  the user should
consult headquarters on a case-by-case basis for further  guidance; final
guidance is under development  for such situations.
3.4  SAFETY
     Each remedial alternative should be evaluated with regard  to  safety.
This evaluation should include short-term and long-term threats  to  the
safety of nearby communities and environments as well as those  to workers

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during implementation.  Major risks to consider are fire, explosion, and
exposure to hazardous substances resulting due to both on-site and off-site
activities during remedial action implementation.

     The joint guidelines of the EPA, the Occupational Safety and Health
Administration (OSHA), and the National Institute for Occupational Safety
and Health (NIOSH), or the Corps of Engineers guidance, prepared to ensure
the health and safety of workers at uncontrolled hazardous waste sites, may
be used to determine the risk to worker health and safety during implementa-
tion.  Alternatives should be designed to minimize risk during construction
and should be evaluated in terms of such safety.
3.5  SUMMARY OF TECHNICAL FEASIBILITY ANALYSIS
     Table 3-1 will help the user evaluate alternatives based on
performance, reliability, implementability, and safety.  The user should
assess site conditions that affect constructability and set design and/or
siting criteria for successful construction.

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

     In Table 3-1, alternatives are listed in the left column.   Each alter-
native is described in terms of its component technologies, indicated for
example by "A-l", "A-2", and so on, of alternative "A."  For example,
alternative "A" may consist of site capping, diversion ditches, a slurry
wall, ground-water pumping, and treatment of the effluent.  The user should
describe the absolute degree to which each alternative or technology meets
each criterion.  In addition, the user may also describe the alternatives
and technologies in order of their relative desirability with respect to
each criterion.  The user should provide a consistent description of any
outstanding features that render the technology particularly desirable or
any limitations that may hinder its use for remedial action at the site.
Where possible, quantitative descriptions should be provided so that
absolute incremental differences in the alternatives can be discerned.
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                                  TABLE 3-1.   SUMMARY  OF TECHNICAL FEASIBILITY  EVALUATION
     Remedial Alternative                                                             Criterion

                                               Per formance                                            Reliability

  Remedial                    Effectiveness                   Useful Life          Operation and               Possible
Alternatives                                                                   Maintenance Requirements       Fa I lure Modes

 A
    A-1
    A-2
    A-3
    A-4
    A-5
Remarks:  Alternative A  summary
 B
    B-1
    B-2
    B-3
Remarks:  Alternative B  summary
 C
    C-1
    C-2
    C-3
    C-4
Remarks:  Alternative C  summary
                                                                                                                 (continued)

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                                                                   TABLE 3-1.   (continued)
                                                                             Imp I amentab!IIty
                                                               Constructabi I Ity
                                                                                                                          Time
                                             Site Conditions
                                                                Conditions       To Implement
                                                             External to Site
                                                                                                                To See Desired Results
U)
00
    A-1

    A-2

    A-3

    A-4

    A-5

Remarks:  Alternative A summary

 B

    B-1

    B-2

    B-3

Remarks:  Alternative B summary

 C

    C-l

    C-2

    C-3

    C-4

Remarks:  Alternative C summary
                                                                                                                               (continued)

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                                                                    TABLE 3-1.   (continued)
                                                                               Safety
                                                                           Considerations
                                                 Worker Health and Safety
                                                                                        Neighboring Facilities
                                                                                            & Communities
U>
 I
    A-1

    A-2

    A-3

    A-4

    A-5

Remarks:  Alternative A summary

 B

    B-1

    B-2

    B-3

Remarks:  Alternative B summary

 C

    C-l

    C-2

    C-3

    C-4

Remarks:  Alternative C summary

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                                  CHAPTER 4

                     EVALUATE INSTITUTIONAL REQUIREMENTS


     This chapter describes current EPA policy on the use  of  applicable  and
relevant standards and other criteria, guidance, and advisories  at  Super fund
remedial sites.  The user should be aware that this policy is  subject  to
change  and further interpretation with regard to specific  standards,  and
should consult supplemental policy and program guidance documents that will
be issued as this policy is developed.  If any questions about  specific
applications of this policy arise, the user should consult  EPA headquarters.

     This chapter also discusses other institutional issues in  analyzing
remedial alternatives, such as coordination with other Federal  agencies  and
community relations.


4.1  OVERVIEW OF INSTITUTIONAL REQUIREMENTS


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

     The user should evaluate the effects of Federal, State,  and local
standards and other institutional considerations on the design,  operation,
and timing of each alternative.  In general, it is expected that regulatory
programs under the Resource Conservation and Recovery Act  (RCRA), the  Safe
 This chapter reflects a policy on the applicability of other  environmental
 programs to actions under CERCLA.  This policy  is  subject  to  the  final
 rulemaking of the proposed amendments to the NCP,  and this  chapter  is
 therefore presented as interim guidance.
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Drinking Water Act (SDWA), and the Federal Water Pollution  Control  Act
(Clean Water Act or CWA) , will have  the broadest applications  to  remedial
action alternatives.

     Results of the institutional analysis of  each  remedial  alternative  are
to be presented, in tabular or narrative  form,  in the  feasibility study  as
part of the noncost criteria analysis of  the remedial  action alternatives
(see chapter 9).  All applicable or  relevant public  health  and environmental
standards, interagency coordination  needs, and other institutional  issues
should be identified.

     This chapter is not  intended to serve in  lieu  of  regulations and
policies implementing particular statutory requirements.  The  user  should
consult the appropriate  regulations  and policies to  determine  these require-
ments .
4.2  CERCLA COMPLIANCE WITH OTHER ENVIRONMENTAL  STATUTES
     EPA policy on the use of environmental  and  public  health  standards  at
Superfund  sites is under development.   The draft  policy discussed  in this
chapter is outlined  in the EPA policy memorandum  "CERCLA Compliance  with the
Requirements of Other Environmental  Statutes"  (Appendix C).  The key re-
quirements of this policy have been  incorporated  in  the proposed revisions
to the National Oil  and Hazardous  Substances Contingency Plan  (NCP).

     It is EPA policy to comply with "applicable  or  relevant"  environmental
and public health standards  in CERCLA remedial actions  unless  one  of five
specific circumstances described in  section  4.2.1 exists,  and  to document
all analyses of these circumstances.  Other  regulations, advisories,  and
guidance may be considered in developing  CERCLA  remedies.   Relevant  portions
may be used; if they are not used, the  reasons for not  using them  must be
stated-in  the decision documents.  The  memorandum defines  "applicable" and
"relevant" and includes a preliminary list of  requirements that would be
considered applicable or relevant, and  a  list  of  other  requirements,
advisories, and guidance that should be considered.   The final section of
this chapter summarizes, in  table  form, the  requirements identified  to date.

     Permits are not required for  on-site Fund-financed or enforcement
actions taken under  CERCLA.  They  are required for off-site disposal actions
(those involving removal and treatment, disposal, or destruction  of  wastes
in off-site facilities).  Off-site actions and their permit requirements
include, but are not limited to, the following:

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

     •  Transportation  of hazardous  waste to an  off-site treatment,  storage,
        or disposal  facility (TSDF)  requires RCRA TSDF  permits.
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     •  Discharge of  pollutants  or  contaminants  from a  point  source into
        U.S. waters requires  a National  Pollutant  Discharge Elimination
        System  (NPDES)  permit pursuant to  CWA section 402.

     •  Disposal, treatment,  or  destruction  of hazardous  waste  at sea
        requires permits under the  Marine  Protection Research and
        Sanctuaries Act  (MPRSA).

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

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

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

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

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

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

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

     •  Alternatives which do not attain applicable  or relevant public
        health or environmental  standards but  will reduce the likelihood of
        present or future threat  from the hazardous  substances.   This must
        include an alternative which closely  approaches the level of  protec-
        tion provided by the applicable or relevant  standards and meets
2
 These alternatives must be consistent with EPA's policy "Procedures for
 Planning and Implementing Off-Site Response Actions."  In some cases,
 off-site disposal or treatment may not be feasible and this alternative
 may be eliminated during initial screening of alternatives.  The decision
 documents should reflect this screening (see Appendix B).
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        CERCLA's objectives of adequately protecting public health, welfare,
        and environment.

     •  A no action alternative.

In some cases these alternatives may overlap.


     4.2.1  Selection of Remedy
     The decisionmaker will consider all of  the  alternatives  arrayed  in  the
feasibility study and will give primary consideration  to  remedies  that
attain or exceed applicable or relevant Federal  public health and  environ-
mental standards.  The decisionmaker may select  an on-site  alternative that
does not attain applicable or relevant standards  in  one or  more  of the
circumstances discussed below.  A consideration  in making this determination
is the extent to which the standard was intended  to  apply to  the specific
conditions at the site.  For example, the RCRA program was  not intended  to
regulate a site consisting of 210 miles of roadside  contaminated by indis-
criminant disposal of PCB wastes, or one consisting  of a  river bed contam-
inated with hazardous substances.  If the recommended  alternative  involves
an EPA standard, guidance, or advisory beyond the direct  requirements of
CERCLA, the decisionmaker will ensure coordination with all affected  EPA
programs.

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

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

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

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

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

         (iii)  Unacceptable  environmental impacts - All  alternatives that
                attain or exceed standards would cause unacceptable damage
                to the environment; or,

     3.  Where  the remedy is  to be carried out  pursuant  to  CERCLA section
         106; the Hazardous Response Trust Fund  is unavailable,  or would not
                                     4-4

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

     Where one of these  situations  is  present,  the decisionmaker may select
an alternative which does not attain or  exceed  applicable or  relevant public
health or environmental  standards.   The  basis  for not  meeting the standard
must be fully documented and  explained in the  appropriate decision docu-
ments .

     The Agency anticipates that most  CERCLA remedial  actions will attain  or
exceed applicable or relevant public health or  environmental  standards.
However, where the specific circumstances discussed  above preclude the
selection of a remedy that  attains  standards,  the decisionmaker  will select
the alternative that most closely approaches the level  of protection pro-
vided by the applicable  or  relevant  standard,  considering the reasons for
not meeting that standard.

     EPA also will use public health and environmental  criteria  in
developing appropriate remedial alternatives.   If the  decisionmaker deter-
mines that such criteria are  relevant, but  are  not used in the selected
remedial alternative, the decision  documents will indicate the basis for not
using the criteria.  Where  no relevant or applicable standards are avail-
able, the user should consult headquarters  on  a case-by-case  basis for
guidance.  In general, headquarters  will instruct the  user to develop at
least one option corresponding to a  10   .risk  level.   In  addition, reason-
able alternatives corresponding to  a 10   to 10  risk  level  should also be
developed.

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

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

     State environmental standards, guidance, or advisories should also  be
addressed.  States have an important role in developing remedial  alterna-
tives.   If a State desires the selection of a remedial  action  that would
incorporate State standards more stringent  than Federal standards, the
decisionmaker may select that remedy.  Generally, the State is expected  to
pay any additional costs.
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     Changes will also be made in the Superfund community relations program
as part of this policy to ensure public involvement equivalent to that  in
other permitting programs.  These modifications are discussed in section 4.6
below.

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

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


4.3  EPA GROUND-WATER PROTECTION STRATEGY
     EPA has developed the Ground-Water Protection Strategy  (GWPS)  to  help
State and Federal agencies cope with ground-water problems and  to  improve
the coherence and.consistency of EPA programs dealing with ground  water.
The GWPS is not considered at this time to  fall  in the  category of relevant
or applicable standards, but it should be considered when deciding on  reme-
dial alternatives.  The Agency is planning  to incorporate provisions of the
Ground-Water Protection Strategy into  future regulatory amendments.  At that
time, those provisions may become relevant  or applicable.

     The GWPS has four elements, keyed to specific objectives:

     1.  Strengthening State ground-water programs:  Funds will be set aside
         to support State ground-water program development and  provide
         technical assistance to the States.  Funds will be  provided  to the
         States,  through existing grant programs,  to support the development
         of overall State action plans or strategies;  identify  and remove
         legal  and institutional impediments to  comprehensive State manage-
         ment;  develop general and source-specific ground-water programs;
         and create a data system to increase the  accessibility and quality
         of information.  EPA will continue to  support  a strong research
         program  to assist both Federal and State  protection efforts.
 3
 Not  applicable  to  enforcement  actions.
                                     4-6

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

    3.  Creating a policy framework for EPA programs:   EPA will adopt guide-
        lines for consistency in ground-water protection programs.   These
        guidelines will protect ground water for  the highest  present or
        potential beneficial use.  The guidelines will  use existing  statutes
        to define an appropriate protection strategy for three  classes of
        ground water:

         •  Class 1, Special Ground Waters, includes those highly vulnerable
            to contamination and either irreplaceable or ecologically vital
            sources of drinking water.

         •  Class 2, Current and Potential Sources of Drinking Water and
            Waters Having Other Beneficial Uses,  includes all  other  ground
            waters currently used or potentially  available for  drinking
            water or other beneficial uses.

         •  Class 3, Ground Water Not a Potential Source of Drinking Water
            and of Limited Beneficial Use, includes saline or  otherwise
            contaminated ground waters beyond reasonable use  for  drinking
            water or other beneficial purposes.   Ground water  in  Class 3
            must not be connected to Class 1 or 2 ground water  or to surface
            water in a way that would allow contaminants to migrate  to these
            waters, with potential adverse effects on human health or the
            environment.

         The guidelines will be implemented by  the development  of specific
         requirements in each major program area.  The  resulting  standards
         will be general and performance-oriented to allow flexibility for
         States in implementing EPA—delegated programs.

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

Regional responsibility for ground-water coordination resides  in  the Water
Divisions.  Functions of the regional programs  include  overseeing ground-
water policy development, providing technical and institutional support to
States, and coordinating regional ground-water  program  plans,  state  work
programs, site assessments, and enforcement.
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     The GWPS will affect CERCLA remedial actions mainly  through  the  ground-
water protection guidelines and classification  system.  The  classification
of affected ground waters will not change the hazard  ranking  score  of a
site; however, sites where ground water that is contaminated  or threatened
with contamination is a current source of drinking water  do  score higher
than those where ground water is not a current  source.  Ground-water  clas-
sifications should be used to establish priorities for  initiating remedial
investigations.  Also, the degree of cleanup or protection of groundwater
resources to be achieved at CERCLA sites will generally be keyed  to the
classification of the affected or potentially affected  ground waters.
Therefore, the evaluation and selection of remedial alternatives will have
to take account of the ground-water classification.

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

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

     For CERCLA sites that overlie ground waters not  considered potential
sources of drinking water and of limited beneficial use (Class 3  ground
waters), CERCLA remedial actions will generally not involve  ground-water
cleanup.  The priority of these sites for remedial action will be low in  the
absence of other hazards to human health and the environment  (such  as sur-
face water contamination, fire, or explosion).

     Criteria  for ground-water classification have not  yet been developed  in
detail.  However, the classifications will be determined  in  conjunction with
assessments of the extent of contamination for  CERCLA cleanup actions on  a
site-specific basis.  In many cases,  the geologic and hydrologic  information
necessary to make this classification will have been  gathered as  part of  the
site investigation.  Information collected by other Federal  and State agen-
cies may be used for classification.  Therefore, during preparation of the
feasibility study, the classification should be available for determining
the level of. protection to be achieved.
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4.4  COMPLIANCE WITH THE NATIONAL ENVIRONMENTAL  POLICY  ACT  (NEPA)
     Remedial actions  taken  pursuant  to  sections  104  and  106  of CERCLA are
generally exempt from  the NEPA requirement  to  prepare an  Environmental
Impact Statement (EIS), based on numerous court decisions holding that the
Agency carries out the  functional equivalent of a NEPA review in its  permit-
ting and regulatory activities.  Under this  exemption,  the EPA is not obli-
gated to comply with formal  EIS procedures  if  two criteria are met.   The
first is that the authorizing statute (i.e., CERCLA)  must provide substan-
tive and procedural standards to ensure  full and  adequate consideration of
environmental issues and alternatives.   The  second is that the public must
be afforded an opportunity to participate in evaluating environmental
factors and alternatives before a final  decision  is made.

     Taking the following steps will  ensure  that  Fund-financed remedial
actions meet these criteria  and achieve  functional equivalence with EIS
requirements:

     1.  The process for determining  the extent of the  remedy required by
         CERCLA section 105(3) and described in section 300.68 of the NCP
         must be followed.   To meet the  first  criterion of NEPA functional
         equivalency,  this process includes  the necessary and appropriate
         investigation  and analysis of environmental  factors  as they
         specifically  relate to a Superfund  site,  and alternatives that are
         being considered to correct  the situation.

     2.  To meet the second  criterion, a meaningful opportunity for public
         comment on environmental issues must  be  provided before the  final
         selection of  a remedial alternative.  To meet  this requirement,  EPA
         Regions must  allow both the  opportunity  and  adequate time for the
         public to review draft feasibility  studies.  This should be  accom-
         plished as part of  the community relations program required  at all
         Superfund response  sites.
4.5  COORDINATION WITH OTHER AGENCIES
     CERCLA, the NCP, and Executive Order  12316 delegate  the  authority to
manage certain aspects of Superfund responses  to  several  Federal  agencies.
For example, the Federal Emergency Management  Agency  (FEMA) is  authorized to
manage relocations.  The Department of Health  and Human Services  (HHS)  and
the U.S. Army Corps of Engineers also are  often called on to  assist  in
remedial actions.  These agencies can contribute  useful advice  during  the
remedial investigation and feasibility study and  should be consulted.   The
United States Geological Survey (USGS) is  not  delegated any specific CERCLA
response authority, but its technical knowledge of  geological character-
istics at sites can be valuable in evaluating  remedial alternatives.   If
coordination is required for any remedial  alternative, the feasibility study
                                    4-9

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must indicate that the appropriate agency has been or will be  contacted  and
that the needed coordination mechanism either is in place or can be devel-
oped .
     4.5.1  Federal Emergency Management Agency
     Permanent relocation of residences, businesses, and community
facilities is included in the definition of remedy under CERCLA  section
101(24).  Permanent relocation may be undertaken as part of a remedial
action if human health is in danger and if, alone or in combination  with
other measures, it would be cost-effective and environmentally preferable  to
other responses.  Temporary relocation, including evacuation and temporary
housing of threatened individuals not otherwise provided for, may also be
undertaken as part of a remedial action (e.g., during cleanup at a CERCLA
site to limit exposure or threat of exposure to a significant environmental
hazard).

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

     The required coordination between the agencies may affect implemen-
tation of an alternative.  Also, community interest in remedial  alternatives
that include relocation will be high.  For remedial alternatives that
include relocation, the feasibility study must indicate that FEMA has been
or will be contacted and that the necessary coordination mechanism either  is
established or can be developed.  During the feasibility study the user
should evaluate the effect of relocation on implementation of the remedial
alternatives.
     4.5.2  Health and Human Services
     The Department of Health and Human Services,  through  the  Agency for
Toxic Substances and Disease Registry (ATSDR) and  the National  Institute  for
Occupational Safety and Health (NIOSH), is responsible  for monitoring  the
health of workers and citizens at or near Superfund  sites  and  for  ensuring
adequate health care.  In this capacity, HHS can contribute  to the evalua-
tion of remedial alternatives.  For each alternative, NIOSH  and ATSDR can
provide advice on the procedures that would be  required to conduct worker
health and safety programs and ensure the health of  the local  community.
Furthermore, HHS health and epidemiological studies  may provide data useful
                                    4-10

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in assessing health concerns.  When  the user determines  that  HHS  expertise
is required, he or she should contact the regional HHS representative  to
request NIOSH or ATSDR support.

     A memorandum of understanding between EPA and HHS is being developed to
define the responsibilities of each  agency in responses  pursuant  to  CERCLA.
The memorandum, when approved by both agencies, will  supplement this section
with more detailed guidance on HHS involvement.
     4.5.3  U.S. Army Corps of Engineers
     The U.S. Army Corps of Engineers manages  the  technical work  during  the
remedial design and construction phases of Federal-lead  remedial  actions.
The Corps also helps EPA review State-lead projects  to determine  their
suitability  for bidding and construction.

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

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

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

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


     4.5.4  U.S. Geological Survey


     The user may find it useful to consult with USGS district  offices to
gather basic technical information about a site.   It is  generally not
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appropriate to contract with USGS  to  perform  the  feasibility study in a
Federal-lead remedial action.   Instead,  the USGS  may  be  consulted  as  a
formal contractor to the Remedial  Planning and  Field  Investigation Team
contractor or through an interagency  agreement  (agreements  for  this purpose
already exist).  In State-lead  responses, it may  be appropriate for the USGS
to perform the feasibility  study as a contractor  to the  State.   EPA is cur-
rently exploring this issue to  clarify the appropriate USGS role in
Superfund responses.

     Many States employ geologists who can provide useful  technical infor-
mation about sites in their States; they often  can be contacted through
State departments of natural resources.  Using  State  geologists makes it
possible to bypass any contractual difficulties or delays  caused by the need
for formal contracts with USGS.  State geologists may be especially useful
when the need for a geologist at a site  is not  great  enough to  warrant
hiring a geologist full-time for an indefinite  period.   In  any  case,  State
geologists form a valuable  resource that should not be overlooked.
     4.5.5  Occupational Safety and Health Administration


     While worker safety and health at  Superfund  response sites  are the
responsibility of employers, OSHA has  the authority to  inspect  Superfund
sites and issue citations  for unsafe conditions.   The OSHA health response
team is available to provide technical  assistance to regional  project
managers, OSCs, and contractors in appropriate  safety procedures.  Note that
some States operate their  own occupational safety and health programs in
place of OSHA, and that some working conditions are covered by  Federal agen-
cies other than OSHA (such as the Mining Safety and Health Administration).
These other agencies could have jurisdiction  in some CERCLA response actions
for specific working conditions.


     4.5.6  National Response Team


     The National Response Team (NRT)  and Regional Response Teams (RRTs)
provide an existing structure for the  coordination of activities undertaken
by the agencies and States that may be  involved in a response  action.  The
NRT and RRTs can provide points of contact in Federal agencies  or State
governments for obtaining  information  necessary to the  feasibility study,
and may be able to provide equipment or other support in performance of the
remedial action.
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     4.5.7  Other Government Authorities
     Certain other agencies may also give advice useful  in  planning  and
implementing remedial actions.  These agencies and  their potential roles  in
remedial actions include:

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

     •  The Bureau of Land Management (BLM) of the  Department  of the
        Interior may be helpful when a remedial action involves Federal
        lands on which BLM has authority over waste disposal or access,  such
        as floodplains and landmarks.

     •  The Fish and Wildlife Service of the Department  of  the Interior  can
        provide advice and information on preventing or  lessening impacts on
        fish and wildlife, especially game  species; identifying threatened
        and endangered species; identifying habitats of  special interest;
        and listing or mapping wetlands.  This information  would be  useful
        in applying for permits for the discharge of dredged or fill
        material.

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

     •  The Heritage Conservation and Recreation Service of the Department
        of the Interior can provide advice  and information  on  National
        Register of Historic Places and Natural Areas.

     •  The Department of Housing and Urban Development  can provide
        floodplain maps.

     •  The Department of Transportation may be helpful  if  the remedial
        alternative involves off-site transport of  hazardous wastes.
4.6  COMMUNITY RELATIONS
     Community relations activities are an integral part of every
Superfund-financed remedial action whether it be Federal-, State-,  or
private party-lead, regardless of the choice of remedial alternatives.   The
EPA's "Community Relations in Superfund:  A Handbook"   supplements  this
section with background material, the community relations requirements and
more detailed procedural guidance on planning and implementing effective
community relations programs.
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     A community relations plan (CRP) is a management and  planning  tool  that
outlines the specific communications activities to be used during a
Superfund response and the integration of these activities with  technical
work at the site.  The plan must be based on interviews conducted within the
community with local officials, civic leaders, community "residents  and
leaders, and public interest groups.

     To provide a meaningful opportunity for public comment, the following
steps must be included in the community relations program:

     1.  Interviews with interested and affected community residents must be
         conducted to determine level of interest, major issues, and
         information needs.

     2.  Based on the community interviews, a community relations plan  is
         developed for the site before RI field work begins.

     3.  Regions must provide local notice of the availability of the draft
         feasibility study.  This notice can be provided through publication
         in local newspapers and through civic groups or other organiza-
         tions.  The draft feasibility study should be placed in local
         information repositories such as community libraries or churches.

     4.  At least 3 weeks must be allowed for comment, measured  from the
         date of notice of availability of the draft RI/FS study.   The
         Superfund coordinator, in consultation with the EPA Regional
         Administrator, can allot additional time.  In general,  unless  the
         site problem is highly technical and citizen concern is high,  3
         weeks should be sufficient, so long as the draft  study  is  expedi-
         tiously distributed.  An informal meeting or briefing can  be held
         at the beginning of the review period to discuss  the results of the
         draft study.

     5.  A responsiveness summary must be included in the  final  feasibility
         study.

     In addition to these steps, the following should be performed  so  that
the community relations program is procedurally equivalent to the public
participation requirements of the Federal Environmental Impact Statement
Program:

     •  A fact sheet should be included with the public notice and
        feasibility study provided to the public 2 weeks before  the 3-week
        public comment period.  The fact sheet must clearly  summarize  the
4
 Interim version,  September  1983.
                                     4-14

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

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

     •  If a remedy is identified that is different from those proposed
        during the public comment period on the feasibility study, a new
        3-week public comment period may be required before the Record of
        Decision is amended, taking into consideration the features of the
        alternatives addressed in the public comment period.

     In evaluating remedial alternatives, the user should be sensitive to
public perception of the alternatives.  Alternatives perceived to be unac-
ceptable by the community may be delayed or prohibited by zoning changes or
other measures.  Steps necessary to address public concerns and incorporate
citizen input when feasible should be taken as early as possible.
4.7  SUMMARY OF INSTITUTIONAL REQUIREMENTS
     This section summarizes, in table form, Federal, State, and  local
requirements applicable or relevant to response actions.  Tables  4-1  and 4-2
are intended as a checklist for users; it should not be used as a substitute
for the actual regulations and policies.
                                    4-15

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               TABLE 4-1.  APPLICABLE OR RELEVANT REQUIREMENTS
1.   Office of Solid Waste

    •   Open Dump Criteria (RCRA Subtitle D, 40 CFR Part 257)

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

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

             F.  Ground-Water Protection
             G.  Closure and Post-Closure
             H.  Financial Requirements
             I.  Use and Management of Containers
             J.  Tanks
             K.  Surface Impoundments
             L.  Waste Piles
             M.  Land Treatment
             N.  Landfills
             0.  Incinerators

2.   Office of Water

    •   Maximum Contaminant Levels (for all sources of drinking water
        exposure)

    •   Underground Injection Control Regulations

    •   State Water Quality Standards (applicable for surface water
        discharge)

    •   Requirements established pursuant to sections 301 and 403 of the
        Clean Water Act

    •   Ocean Dumping Requirements including incineration at sea

    •   Pretreatment standards for discharge into publicly owned treatment
        works (POTW).
                                                                 (continued)
5
 'Applies to enforcement action, not applicable or relevant to Fund-financed
 actions.
                                    4-16

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                           TABLE 4-1.  (continued)
3.  Office of Pesticides and Toxic Substances

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

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

4.  Office of External Affairs

    •   Guidelines for Specification of Disposal Sites for Dredged or Fill
        Material [§404(b)(l) Guidelines, 40 CFR Part 230]

    •   Denial or Restriction of Disposal Site for Dredged Material:  Final
        Rule [§404(c)].

5.  Office of Air and Radiation

    •   Uranium mill tailing rules

    •   National Ambient Air Quality Standards

    •   High- and low-level radioactive waste rule

    •   Asbestos disposal rules

6.  Other Federal Requirements

    •   OSHA requirements

    •   Preservation of scientific, historical, or archeological data

    •   D.O.T. Hazardous Materials Transport Rules

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

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

             -  Preservation of rivers on the national inventory, Wild and
                Scenic Rivers Act, §7, 40 CFR Part 6.302(e)


                                                                 (continued)
                                    4-17

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              TABLE 4-1.  (continued)
   Protection of threatened or endangered species and their
   habitats

   Conservation of Wildlife Resources

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

-  Coastal Zone Management Act.
                        4-18

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



1.  Federal Requirements, Advisories,, and Procedures

    A.   Recommended Maximum Concentration Limits (RMCLs)

    B.   Health Advisories, EPA, Office of Water

    C.   Federal Water Quality Criteria

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

    D.   Pesticide and food additive tolerances and action levels data

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

    E.   Waste load allocation procedures, EPA Office of Water

    F.   Federal sole source aquifer requirements

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

    H.   EPA ground-water protection strategy

    I.   New Source Performance Standards for Storage Vessels for Petroleum
        Liquids

    J.   TSCA health data

    K.   Pesticide registration data

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

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

                                                                 (continued)
                                    4-19

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                           TABLE 4-2.  (continued)
    N.  National Environmental Policy Act

    0.  Floodplain and Wetlands Executive Orders.

2.  State Requirements

    A.  State Requirements on Disposal and Transport of Radioactive wastes

    B.  State Approval of Water Supply System Additions or Developments

    C.  State Ground-Water Withdrawal Approvals

    D.  Requirements of authorized (RCRA Subtitle C) State hazardous waste
        programs

    E.  State Implementation Plans and delegated programs under the Clean
        Air Act

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

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

3.  USEPA RCRA Guidance Documents

    A.  EPA RCRA Design Guidelines

        1.  Surface Impoundments, Liners Systems, Final Cover, and Freeboard
            Control

        2.  Waste Pile Design - Liner Systems

        3.  Land Treatment Units

        4.  Landfill Design - Liner System  and  Final Cover.

    B.  Permitting Guidance Manuals

        1.  Permit Applicant's Guidance Manual  for  Hazardous Waste Land
            Treatment, Storage, Disposal Facilities

                                                                  (continued)
                                     4-20

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                       TABLE 4-2.  (continued)
    2.   Permit Writer's Guidance Manual for Hazardous Waste Land
        Treatment, Storage, Disposal Facilities

    3.   Permit Writer's Guidance Manual for Subpart F

    4.   Permit Applicant's Guidance Manual for the General Facility
        Standards

    5.   Waste Analysis Plan Guidance Manual

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

    7.   Model Permit Application for Existing Incinerators

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

    9.   A Guide for Preparing RCRA Permit Applications for Existing
        Storage Facilities

    10. Guidance Manual on Closure and Post-Closure Interim Status
        Standards.

C.  Technical Resource Documents (TRDs)

    1.   Evaluating Cover Systems for Solid and Hazardous Waste

    2.   Hydrologic Simulation of Solid Waste Disposal Sites

    3.   Landfill and Surface Impoundment Performance Evaluation

    4.   Lining of Waste Impoundment and Disposal Facilities

    5.   Management of Hazardous Waste Leachate

    6.   Guide to the Disposal of Chemically Stabilized and Solidified
        Waste

    7.   Closure of Hazardous Waste Surface Impoundments

    8.   Hazardous Waste Land Treatment

                                                              (continued)
                                4-21

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                           TABLE 4-2.  (continued)
        9.   Soil Properties,  Classification, and Hydraulic Conductivity
            Testing.

    D.   Test Methods  for Evaluating Solid Waste

        1.   Solid Waste Leaching Procedure Manual

        2.   Methods for the Prediction of Leachate Plume Migration and
            Mixing

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

        4.   Procedures for Modeling Flow Through Clay Liners

        5.   Test Methods for Evaluating Solid Wastes

        6.   A Method for Determining the Compatibility of Hazardous Wastes

        7.   Guidance  Manual on Hazardous Waste Compatibility

4.  USEPA Office of Water Guidance Documents

    A.   Pretreatment  Guidance Documents

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

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

    B.   Water Quality Guidance uocuments

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

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

            Outlines methods  for conducting use attainability  analyses under
            the  Clean Water Act.
                                                                 (continued)
                                    4-22

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                       TABLE 4-2.  (continued)
    3.  Water-Related Environmental Fate of 129 Priority Pollutants
        (1979)

        Describes the transformation and transportation of priority
        pollutants.

    4.  Water Quality Standards Handbook (1983)

        Provides an overview of the Criteria Standards Program under the
        Clean Water Act and outlines methods for conducting criteria
        standards modification.

    5.  Technical Support Document for Water Quality-Based Toxics
        Control.

C.  NPDES Guidance Documents

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

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

    2.  Biomonitoring Guidance, July 1983, subsequent biomonitoring
        policy statements and case studies on toxicity reduction
        evaluation (May 1983).

D.  Ground-Water/UIC Guidance Document

    1.  Designation of a USDW

    2.  Elements of Aquifer Identification

    3.  Interim guidance for public participation

    4.  Definition of major facilities

    5.  Corrective action requirements

    6.  Requirements applicable to wells injecting into, through, or
        above an aquifer which has been exempted pursuant to
        §146.104(b)(4).

    7.  Guidance for UIC implementation on Indian lands.
                                                             (continued)
                                4-23

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                           TABLE 4-2.  (continued)
        8.  Technical Resource Documents (currently under development by
            OGWP).

5.  USEPA Manuals from the Office of Research and Development

    A.  SW-846 - laboratory analytic methods

    B.  Laboratory protocols developed pursuant to Clean Water Act §304(h)
                                    4-24

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                                  CHAPTER 5

              EVALUATE PROTECTION OF PUBLIC HEALTH  REQUIREMENTS
5.1  OVERVIEW
     The remedial action selected  for  a  Superfund  hazardous  waste  site must
adequately protect public health, welfare, and  the environment.  This
requires documenting that the action minimizes  the long-term effects of any
residual contamination, and protects the public both during  and  after  the
action.  This chapter provides interim guidance  for ensuring that  remedial
actions limit the concentrations of toxic  substances in  the  environment to
avoid unacceptable threats to human health.

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

     An endangerment assessment must be  conducted  for all enforcement  sites.
At a minimum, it should establish the  potential health and environmental
 This chapter contains interim guidance for public health  evaluation.   Final
 guidance for public health evaluation will be provided  after  completion  of
 risk assessment guidelines for evaluating chemical hazards  that  do  not have
 appropriate standards or criteria.
                                    5-1

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threats of the site in the absence of response  action.  The  endangerment
assessment will have some components of  the  public  health  assessment
described in this chapter, but may be more or less  detailed  depending  on  the
amount, type and quality of data available.  For  example,  if the  endanger-
ment assessment is prepared before an RI has begun  or during the  initial
stages of an RI, less data will be available than if the endangerment
assessment is prepared after an RI is completed.  For some enforcement
sites, the feasibility study public health assessment may  serve as  the
endangerment assessment.  Chapter 10 (forthcoming)  describes endangerment
assessments in detail.

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

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

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

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

     •  Develop, evaluate, and modify remedial  alternatives:  Evaluation  of
        short- and long-term effects of  remedial  alternatives to  remove or
        mitigate exposures of concern identified  during the  exposure
        assessment.  Specific design goals will be  based on  applicable or
        relevant standards, or the absence of appropriate_standards,  to
        develop at least one option corresponding to a  10    risk  level and
        other reasonable alternatives corresponding to  a 10    to  10   risk
        level.
5.2  DEVELOP A BASELINE  SITE  EVALUATION
     Baseline  site  evaluation  is  the  first  step  in  public  health evaluation
 for  all  sites.  First,  the  available  data relevant  to  public  health evalua-
 tion should be  collected, organized,  and reviewed.   The information col-
 lected  should  include  site  background data,  disposal history  (and records,
 if available),  types of remedial  technologies  considered,  on-site and off-
 site chemical data, site  environmental  data  (e.g.,  topography and hydro-
 geology),  information  on  local  human  populations,  and  information on human
 health  effects  (which may be unavailable).   Data sources include preliminary
 assessment data and reports, field  reports,  remedial investigation scoping
 documentation,  and  analytical  data  and  reports available from ongoing site
 characterization  and alternatives screening  activities.
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     Of  particular  importance  in  this  initial  review is the information used
to define  the type  of  action likely  to be  taken at  a site and the level of
detail required  for the  exposure  assessment.   Sites involving contamination
that has not migrated  much  beyond  the  source generally call for relatively
simple source control  measures.   Sites that have evidence of contaminant
migration  beyond  the source (e.g., into ground  water)  may consider source
control  options  as  well  as  management  of migration  alternatives.  Other
sites may  have such extensive migration of contaminants that only management
of migration options would  be  suitable. These  classifications are generally
made at  the RI/FS scoping stage.   The  distinctions  are important in deter-
mining the extent of analysis  and  evaluation required  for each alternative
(see section 5.4).   Thus, all data on  the  extent of contamination, con-
taminant mobility and  migration,  and types of  remedial alternatives should
be carefully reviewed.   The result of  the  baseline  evaluation should be a
determination of  the data required to  conduct  the exposure assessment and
the  level  of detail in this assessment. This  evaluation will generally be
conducted  in conjunction with  development  of the site  sampling plan.

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

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

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

     •   The remedial alternatives  will prevent  or minimize releases of
         contaminants.

Management of migration  measures  should be evaluated if these conditions are
not met.
5.3  DEVELOP AN EXPOSURE ASSESSMENT
     At sites where only  source control  remedial measures  are  being
evaluated, a qualitative  assessment of the  potential  public  health threats
in the absence of remedial action will generally be  conducted.   An in-depth
quantitative analysis  is  not warranted in such  situations  where  (1)  con-
tamination has not migrated into any  transport  media  capable of  producing
human exposures and (2) the only actions under  consideration are those  that
prevent such migration.   However, at  a minimum, a  qualitative  exposure
analysis is required to evaluate the  types,  amounts,  and concentrations of
chemicals at the site, their toxic effects,  the proximity  of target  popula-
tions, the likelihood  of  chemical release and migration  from the site,  and
the potential for exposure.  This health assessment  requires written docu-
mentation.

                                    5-3

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      Source  control  alternatives  will  be based on acceptable engineering
 practice  for preventing  off-site  releases and on applicable or relevant
 standards  (e.g.,  RCRA design standards).  Quantitative health risk assess-
 ment  will  usually not  be required for  alternative selection or design at
 these  sites.  However, the  reliability of such remedies should be evaluated
 in  the context  of engineering  practicality as set forth in chapter 3.  In
 those  situations,  the  operation and maintenance agreement  should include
 effective  monitoring  provisions to ensure that a failure would be identified
 prior  to human  or environmental exposure.

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

      • Identifying  chemicals  present  at the site and selecting indicator
        chemicals  (based on toxicity,  persistence, mobility, and quantity
        present)

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

      • Characterizing populations potentially at risk

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

      In some situations,  there may only be a small number  of chemicals
 present and  all chemicals may  be  evaluated.   At sites where there are a
 large  number of chemicals,  specific indicator chemicals may be selected to
 facilitate a manageable  analytical and  design effort.   These indicators
 should represent  the most toxic,  persistent,  mobile,  and prevalent chemicals
 at  the site.  While  this  document promotes the use of indicator chemicals in
 the development and  analysis of alternatives,  EPA recognizes there may be
 some  short comings in  developing  alternatives  that must be in compliance
 with RCRA  regulations  (CFR  Part 264).   In these instances, the project
manager should consult with  the EPA RCRA office to determine the minimum
 requirements  for  analyzing  constituents  at the site.   In many cases,  an
 analysis of  RCRA Appendix VIII constituents  can be demonstrated using
 carefully  selected indicator chemicals.

     Table 5-1 provides  a reasonably complete  list of questions that  should
 be  answered  in an exposure  assessment.   These  questions apply to both quali-
 tative and quantitative  assessments. Because  extreme  uncertainties are
 likely, a  critical part  of  all exposure  assessments is  documenting assump-
 tions  and  other sources  of  uncertainty.   A detailed manual for conducting
 exposure assessments is  under development.   In the interim,  project managers
 should use their best  judgement in characterizing  each  of  the above
 elements.
                                    5-4

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           TABLE 5-1.  QUESTIONS IN EXPOSURE ASSESSMENT
I.    Chemical Identification

      A.  What chemicals are known or suspected to have been
          disposed at the site?
      B.  What quantities of each chemical were disposed?
      C.  How were they disposed (bulk dumping, drums, bulk
          storage)?
      D.  Which chemicals are now in the environment (air,
          land, surface water, ground water)?
      E.  What are the ambient levels of these chemicals in
          the air, ground water, surface water, and soil?
      F.  What conditions or events could affect contamination
          levels on- and off-site?
      G.  What chemicals can be used as indicators of the
          overall risk at the site?

II.   Surrounding Population

      A.  Describe the population surrounding the site:
          1.  How many people are potentially exposed?
          2.  Who are they (especially high-risk groups,
              e.g., children, the elderly, or the ill)?
          3.  Where is the population located relative to the
              site?
          4.  Is the area mainly for residence or business?
          5.  What type of access is there to the site?
          6.  What normal activities might be affected by
              contamination (e.g., farming by contaminated
              soil)?
      B.  What, if any, health-related complaints have been
          received?  Have these been documented or proven to
          be related to the site?

III.  Potential Exposure Routes

      A.  Unavoidable on-site exposure (residences, etc.)
          1.  How are people exposed?
          2.  What are the routes of exposure (through
              inhalation, the skin, or ingestion)?
          3.  To what chemicals are people exposed?
          4.  To what levels are they exposed (use monitoring
              data and modeling if appropriate)?

                                                   (continued)
                               5-5

-------
                      TABLE 5-1.  (continued)
          5.   How many people are exposed at these levels
              (i.e., through each pathway)?

      B.   Voluntary on-site exposure
          1.   How are people exposed?
          2.   What are the routes of exposure (through
              inhalation, the skin, or ingestion)?
          3.   To what chemicals are people exposed?
          4.   To what levels are they exposed (use monitoring
              data and modeling if appropriate) and how many
              people are exposed at these levels (i.e., through
              each pathway)?
          5.   Can this exposure be prevented?
      C.   Off-site exposure (actual and potential)
          1.   What environmental routes must chemicals take
              for exposure?
          2.   How likely are these routes of exposure?
          3.' When is exposure expected to occur?
          4.   How are people exposed (through inhalation, the
              skin, or ingestion)?
          5.   To what chemicals are people exposed?
          6.   To what levels are they exposed (use monitoring
              data and modeling if appropriate)?
          7.   How many people are exposed at these levels
              (i.e., through each pathway)?
      D.   Other non-waste-related exposures
          1.   Is the population, or are segments of the
              population, exposed to any of these chemicals
              from other routes, e.g., in the workplace?
          2.   Are the ambient environmental levels of any of
              the chemicals known?
          3.   Are they suspected to be abnormally high for any
              reason?

IV.   The Effect of Not Taking Action

      A.   Technical issues
          1.   What will happen if no action is taken (e.g.,
              lagoon failure, aquifer contamination, drum
              failure', air contamination)?
          2.   What chemicals will be of concern?

                                                   (continued)
                               5-6

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                TABLE 5-1.  (continued)
B.  Exposure issues
    1.  What exposure will result from not taking
        action?
    2.  Will exposure increase indefinitely?
    3.  Will exposure rise and then fall?  Over what
        time?
    4.  What is the predicted range of eventual
        contamination and exposure?
                         5-7

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5.4  COMPARE ALTERNATIVES  TO APPLICABLE  OR RELEVANT  ENVIRONMENTAL STANDARDS
     Following the exposure  assessment,  estimated  environmental  concen-
trations of the indicator chemicals  selected  for that  site  should  be
compared to applicable or relevant environmental standards  and criteria.

     This comparison must be made for  each  of  the  alternatives discussed  in
section 4.2.  Table 5-2 lists sub stance-specific relevant and applicable
numerical standards as well  as other numerical  criteria,  advisories,  and
guidance to be considered in the analysis of alternatives.   (See Appendix C,
CERCLA Compliance with the Requirements  of  Other Environmental Statutes,  for
a more complete listing of various types of standards,  criteria, advisories,
and guidance.)  There may be some situations where  applicable or relevant
standards listed in Tables 5-2 and 4-1 are  not  applicable to specific  site
situations (for example, see section 5.4.2).   There may be  situations,  as
well, where there are relevant or applicable standards  that  cover  only  some
of the substances at a site.  In contrast to these  two  situations,  it  is
more likely that a project manager will more frequently use  relevant  or
applicable technology-based  standards  (e.g., 40 CFR 264,  treatment, storage,
and disposal regulations under the Resource Conservation  and Recovery Act)
or consider other advisories, criteria,  and guidance for  specific  substances
at a site in fashioning alternative remedies.

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

     As discussed in Chapter 4, five categories of alternatives must be
examined:

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

     2.  Those that attain applicable or relevant standards;
                                    5-8

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                   TABLE  5-2.   EPA AMBIENT STANDARDS  AND CRITERIA FOR  SUPERFUND REMEDIAL  SITES
01

Applicable or Relevant

Requirements Other Criteria, Advisories, and Guidance




Chemical


Acenaphthene
Acrolein
Acrylonitrile
Aldrin
Ant lawny
Araenic
Asbestos
Bariuai
Benzene
Benzidine
Beryl liim
Cadaiiuai
Carbon axraoxide

Carbon tetrachloride
Chlordane
Chlorinated benzenes
Hexachlorobencene
1 , 2,4,5-Tetrachlorobenzene
Pent achlorobenzene
Trichlorobenzene
Monochl orobenzene
Chlorinated ethanes
, 2-Dichloroethane
, 1 , 1 -Tr ichloroethane
,1,2-Trichloroethane
,1,2,2-Tetrachloroethane
exachloroethane
Monochloroethane
, 1-Dichloroethane
, 1 , 1 ,2-Tetrachloroethane
Pentachloroethane
Safe Drinking
Water Act,
MCLs (««/L Clean Water Act,
unless Water Quality Criteria
otherwise Clean Air Act, for Huaan Health —
noted) NAAQS (ug/m ) Fish and Drinking Water


20 ug/L (organolept ic)
320 ug/L
0 (58 ng/L)
0 (0.074 ng/L)
146 ug/L
0.05 0 (2.2 ng/L)
0 (30,000 fibers/L)
1.0
0 (0.66 ug/L)
0 (0.12 ng/L)
0 (3.7 ng/L)
0.01 . 10 ug/l
40,000 (l-hour)°
10,000 (8-hour)
0 (0.4 ug/L)
0 (0.46 ng/L)

0 (0.72 ng/L)
38 ug/L
74 ug/L
Insufficient data
488 ug/L

0 (0.94 ug/L)
18.4 «g/L
0 (0.6 ug/L)
0 (0.17 ug/L)
0 (1.9 ug/L)
Inaufficient data
Insufficient data
Insufficient data
Insufficient data


Clean Water Act, Safe Drinking Water Act,
Water Quality Criteria Health Advisories
for Huaan Health— (ag/D
Adjusted for 1-day 10-day Chronic
Drinking Water Only* (longer
tens)
20 ug/L ( organolept ic)
540 ug/L
0 (63 ng/L)
0 (1.2 ng/L)
146 ug/L
0 (2.5 ng/L)
0 (30,000 fibera/L)

0 (0.67 ug/L) 0.23 0.07
0 (0.15 ng/L)
0 (3.9 ng/L)
10 ug/L


0 (0.42 ug/L) 0.2 0.02
0 (22 ng/L) 0.0625 0.0625 0.0075

0 (21 ng/L)
180 ug/L
570 ug/L
Inaufficient data
488 ug/L

0 (0.94 ug/L) Insufficient data
19 og/L 1.0
0 (0.6 ug/L)
0 (0.17 ug/L)
0 (2.4 ug/L)
Insufficient data
Inaufficient data
Insufficient data
Insufficient data
                                                                                                      (continued)

-------
                                                                    TABLE  5-2.    (continued)
Ln
 I
Applicable or Relevant
Requirement!
Safe Drinking
Water Act ,
MCL> (ng/L
unless
otherwise Clean Air Act,
Chen ic a 1 noted) NAAQS (ug/m )
Other Criteria, Advisories, and Guidance
Clean Water Act , Clean Water Act ,
Water Quality Criteria Water Quality Criteria
for Hunan Health — for Human Health —
Fish and Drinking Water Adjusted for g
Drinking Water Only
Safe Drinking Water Act,
Health Advisories
(mg/L)
1-day 10-day Chronic
( longer
tens)
Chlorinated naphthalenes
Chlorinated phenols
  3-Monochlorophenol
  4-Monochlorophenol
  2,3-Dichlorophenol
  2,5-Dichlorophenol
  2,6-Dichlorophenol
  3,4-Dichlorophenol
  2,3,4,6-Tetrachlorophenol
  2,4,S-Tr ichlorophenol
  2,4,6-Trichlorophenol
  2-Methyl-4-chlorophenol
  3-Methyl-4-chlorophenol
  3-Methyl-6-chlorophenol
Chlorophenoxys
  2,4-Dichlorophenoxyacet ic
  acid (2,4-D)                 0.1
  2,4,5-Trichlorophenoxy-
  propionic acid (2,4,5-TP)    0.01
Chloroalkyl ethers
  bis-(Chloro«ethyl) ether
  bis-(2-Chloroethyl) ether
  bis-(2-Chloroisopropyl) ether
Chlorofora                     0.1
2-Chlorophenol
Chroniun Cr+6                  0.05
         Cr+3
Copper
Cyanide
DDT
Dichlorobeneenes (all isoners)
Dichlorobenzidines
Dichloroethylenes
  1,1-Dichloroethylene
  1,2-Dichloroethylene
Insufficient data

0.1 ug/L (organoleptic)
0.1 ug/L (organoleptic)
0.04 ug/L (organoleptic)
0.5 ug/L (organoleptic)
0.2 ug/L (organoleptic)
0.3 ug/L (organoleptic)
1.0 ug/L (organoleptic)
2600 ug/L
0 (1.2 ug/L)
1800 ug/L (organoleptic)
3000 .ug/L (organoleptic)
20 ug/L (organoleptic)
                                                                          0 (0.0038 ng/L)
                                                                          0 (30 ng/L)
                                                                          34.7 ug/L
                                                                          0 (0.19 ug/L)
                                                                          O.I ug/L (organoleptic)
                                                                          50 ug/L
                                                                          170 mg/L
                                                                          1 ng/L (organoleptic)
                                                                          200 ug/L
                                                                          0 (0.024 ng/L)
                                                                          400 ug/L
                                                                          0 (10.3 ng/L)

                                                                          0 (33 ng/L)
                                                                          Insufficient data
Insufficient data

0.1 ug/L (organoleptic)
0.1 ug/L (organoleptic)
0.04 ug/L (organoleptic)
0.5 ug/L (organoleptic)
0.2 ug/L (organoleptic)
0.3 ug/L (organoleptic)
1.0 ug/L (organoleptic)
2600 ug/L
0 (1.8 ug/L)
1800 ug/L (organoleptic)
3000 ug/L (organoleptic)
20 ug/L (organoleptic)
                          0 (0.0039  ng/L)
                          0 (30  ng/L)
                          34.7 ug/L
                          0 (0.19  ug/L)
                          0.1 ug/L (organoleptic)
                          50 ug/L
                          179 ng/L
                          1 ng/L (organoleptic)
                          200 ug/L
                          0 O1.2  ng/L)
                          470 ug/L
                          0 (20.7  ng/L)

                          0 (33  ng/L)
                          Insufficient data
                          1.0
                          4.0
                          2.7
                                                                                                                                     0.4
                                                                                                                                     0.27
  0.07
(cis isoner)
(trans isoner)
                                                                                                                                                 (continued)

-------
                    TABLE 5-2.    (continued)
Applicable or Relevant
    Requirements
Other Criteria, Advisories,  and Guidance





Chemical


Dichloromethane
2,4-Dichlorophenol
Dichloropropanes/
Dichloropropenes
Dichloropropanes
Dichloropropenes
Dieldrin
2 ,4-Dimethyl phenol
2-4-Dinitrotoluene
p-Dioxane
1 ,2-Diphenylhydrazine
Endosul fan
End r in
Ethylbenzene
Ethylene glycol
Formaldehyde
Fluoranthene
Fluoride
Haloethers
Halomethanea
Heptachlor
Hexachlorobutadiene
Hexachlorocyclohexanes
Lindane (99Z gamma-HCH)
alpha-HCH
beta-HCH
gaona-HCH
delta-HCH
epsilon-HCH
Technical-HCH
Hexachlorocyclopentadiene
n-Hexane
Hydrocarbons (non-methane)
Isophorone
Kerosene/ fuel oil no. 2

Safe Drinking
Water Act,
MCLs (mg/L Clean Water Act,
unless Water Quality Criteria
otherwise Clean Air Act, for Human Health —
noted) NAAQS (ug/m ) Fish and Drinking Water


See Halomethanes
3.09 mg/L


Insufficient data
87 ug/L
0 (0.071 ng/L)
400 ug/L (organolept ic)
0 (0.11 ug/L)

0 (42 ng/L)
74 ug/L
0.0002 1 ug/L
1.4 «g/L


42 ug/L
1.4-2.4
Insufficient data
0 (0.19 ug/L)
0 (0.28 ng/L)
0 (0.45 ug/L)

0.004
0 (9.2 ng/L)
0 (16.3 ng/L)
0 (18.6 ng/L)
Insufficient data
Insufficient data
0 (12.3 ng/L)
206 ug/L

160 (3-hour)d/f
5.2 mg/L




Clean Water Act, Safe Drinking Water Act,
Water Quality Criteria Health Advisories
for Husan Health. — (sg/L)
Adjusted for 1-day 10-day Chronic
Drinking Water Only (longer
term)
See Halomethanes 13 1.3 0.15
3.09 mg/L


Insufficient data
87 ug/L
0 (1.1 ng/L)
400 ug/L (organoleptic)
0 (0.11 ug/L)
5.68 0.568
0 (46 ng/L)
138 ug/L
1 ug/L
2.4 mg/L
19.0 5.5
0.03
188 ug/L

Insufficient data
0 (0.19 ug/L)
0 (11 ng/L)
0 (0.45 ug/L)


0 (13 ng/L)
0 (23.2 ng/L)
0 (26.4 ng/L)
Insufficient data
Insufficient data
0 (17.4 ng/L)
206 ug/L
13 4.0

5.2 mg/L
0.358
0.23
                                                                                        (cont inued)

-------
                                                   TABLE 5-2.   (continued)
Ln
 I







Cheaical


Lead
Mercury
Hethoxychlor
Methyl Ethyl Re tone
Naphthalene
Nickel
Nitrate (a* N)
Nitrobenzene
Nitrogen dioxide
Nitrophenoli
2,4-Dinitro-o-cresol
Dinitrophenol
Mononitrophenol
Trinitro phenol
Nitrosaaines
n-Nitrosodinethylaaine
n-Nitroaodiethylaaiine
n-Nitroaodi-n-butylaaine
n-Nitroaodiphenylaaine
n-Ni troao pyrrol id ine
Ozone
Particulate Matter

Pentachlorophenol
Phenol
Phthalate eaters
Diaethyl phthal at e
Diethylphthalate
Dibutyl phthal ate
Di-2-ethylhexyl-phthalate
Polychlorinated biphenyla
(PCBs)
Pol/nuclear aroatatic
hydrocarbons (PAHs)
Applicable or Relevant
Requirements
Safe Drinking
Water Act,
MCLs («g/L
unless
otherwise Clean Air Act,
noted) NAAQS (ug/n )


0.05 1.5 (90-day)
0.002
0.1



10.0

100 (l-year)h











235 (1-hour)
260 (24-hour)7
75 (24-hour)













Other Criteria, Advisories, and Guidance


Clean Water Act,
Water Quality Criteria
for Hunan Health —
Fish and Drinking Water


50 ug/L
144 ng/L


Insufficient data
13.4 ug/L

19.8 a*/L


13.4 ug/L
70 ug/L
Insufficient data
Insufficient data

0 (1.4 ng/L)
0 (0.8 ng/L)
0 (6.4 ng/L)
0 (4.9 ug/L)
0 (16 ng/L)



1.01 «g/L
3.5 «g/L

313 «g/L
350 aig/L
34 «g/L
15 Bg/L

0 (0.079 ng/L)

0 (2.8 ng/L)


Clean Water Act, Safe Drinking Water Act,
Water Quality Criteria Health Advisories
for Human Health— (»g/L)
Adjusted for 1-day 10-day Chronic
Drinking Water Only* (longer
tern)
50 ug/L
10 ug/L

7.5 0.750
Insufficient data
15.4 ug/L

19.8 ag/L


13.6 ug/L
70 ug/L
Insufficient data
Insufficient data

0 (1.4 ng/L)
0 (0.8 ng/L)
0 (6.4 ng/L)
0 (7.0 ug/L)
0 (16 ng/L)



1.01 «g/L
3.5 -g/L

350 »g/L
434 «g/L
44 «g/L
21 -g/L

0 O12.6 ng/L) 0.125 0.0125

0 (3.1 ng/L)
                                                                                                    (cont inued)

-------
                                                                   TABLE  5-2.   (continued)
Ul
 I
U)






Chemical


Rad ion ucl ides
Radium-226 and 228
Gross alpha activity
Tritium
Strontium-90
Other man-made
Selenium
Silver
Sulfur dioxide
2,3,7, 8-TCDD
Tetrachloroethylene
Thai 1 iura
Tol uene
Toxaphene
Trichloroethylene .
Trihalomethanes (total)
Vinyl chloride
Xylenes
Zinc
These adjusted criteria
Applicable or Relevant
Requirements
Safe Drinking
Water Act,
HCLs (mg/L
unless
otherwise Clean Air Act,
noted) NAAQS (ug/m3)



5 pCi/L
15 pCi/L
20,000 pCi/L
8 pCi/L
j
0.01
0.05
365 (24-hour}
80 (1-year)"




0.005

; o.i



, for drinking water ingestion only,
Other Criteria, Advisories, and Guidance


Clean Water Act,
Water Quality Criteria
for Human Health —
Fish and Drinking Water








10 ug/L
50 ug/L

0 (0.000013 ng/L)
0 (0.8 ug/L)
13 ug/L
14.3 mg/L
0 (0.71 mg/L)
0 (2.7 ug/L)

0 (2.0 ug/L)

5 mg/L (organoleptic)
were derived from published
1980) for combined fish and drinking water ingestion and for fish ingestion alone. These
Criteria, but may be appropriate for Superfund sites with contaminated ground water. In


Clean Water Act, Safe


Drinking Water Act,
Water Quality Criteria Health Advisories
for Human Health —
Adjusted for 1-day
Drinking Water Only*







10 ug/L
50 ug/L

0 (0.00018 ng/L)
0 (0.88 ug/L) 2.3
17.8 ug/L
15 mg/L 21.5
0 (25.8 mg/L)
(2.8 ug/L) 2.0

(2.0 ug/L)
12
5 mg/L (organoleptic)
EPA Water Quality Criteria (45 FR
adjusted values are not official
(mg/L)
10-day Chronic
( longer
term)










0.175 0.02

2.2 0.34

0.2 0.075


1.2 0.62

79318-79379, November 28,
EPA Water Quality
           liters/day  for drinking water and 6.5  grama/day for fish; human body weight  was  assumed to be 70 kilograms.

           Criteria designated as organoleptic are based on taste and odor effects,  not  hunan health effects.  Health-based Water  Quality  Criteria are not
           available for these chemicals.

           The criterion for all carcinogens is  tero; the concentration given in parentheses corresponds to a carcinogenic risk of 10   .   Water Quality
           Criteria documents present concentrations resulting in risks from 10   to  10~  .   To obtain concentrations corresponding  to risks.of  10,  and 10"5,
           the 10   concentrations should  be multiplied by 100 and 10, respectively.  To  obtain concentrations corresponding to risk of 10   ,  10
          concentrations should be divided by  10.
                                                                                                                                                (continued)

-------
                                                                       TABLE 5-2.    (continued)
               Annual maximum concentration not to be exceeded more than once per year.

               Chloroform is one of four  trihaloraethanes whose sum concentration must be less than O.I  mg/L.

               As a guide in devising implementation plans for achieving oxidant standards.

 I              Seven-day health advisory  for benzene and benzo(a)pyrene  In  kerosene, respectively,
t—'            h
•£*             Annual arithmetic mean concentration.

               Annual geometric mean concentration.

               Activity corresponding to  total body or any internal organ dose of 4 mrem/year.

               Total trihaloraethanes refers to the sum concentration of  chloroform, broraodichloromethane f  dibroraochlororaethane, and bromoform.

-------
      3.   Those that  exceed applicable or relevant standards, as appropriate;

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

      5.   A no  action alternative.

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


      5.4.1 Assumptions Underlying Applicable and Relevant Standards


      Since the applicable and  relevant standards in Table 4-1 and 5-2 were
 developed  under  a variety of statutes, many  incorporate economic or scientific
 factors that do  not  match specific conditions at a CERCLA site.   For example,
 the  standards  generally do not consider simultaneous exposures from multiple
 routes.   Standards may also  be based on different levels, durations, or
 frequencies of exposure than are likely at a specific site.   The assumptions
 underlying the Tables  4-1 and  5-2 standards  that are most frequently relevant
 and  applicable at Superfund  sites are discussed briefly in the following
 sections.
     5.4.2   Resource Conservation  and Recovery Act  Hazardous  Waste
             Regulations  (40 CFR 264)


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


                                    5-15

-------
     5.4.3  National Interim Primary Drinking Water  Standards  (NIPDWs)  and
            Maximum Contaminant Levels  (MCLs)
     Standards under the Safe Drinking Water Act  are  promulgated  as MCLs,
which represent the allowable levels in public water  systems.  As  a matter  of
policy, CERCLA will also use them for other drinking  water  exposures.   They
are generally based on lifetime exposure to the contaminant  for a  70-kg
(154-pound) adult who consumes 2 liters (0.53 gallons)  of water per day.  The
total environmental exposure to contaminants was  generally  considered  in
calculating specific MCLs.  EPA estimated the amount  of the  substance  to which
the average person is likely to be exposed from all sources  (air,  food, water,
etc.), and then determined the fraction of the total  intake  from  drinking
water.

     In addition to addressing health factors, an MCL is required  by  law to
reflect the technological and economic feasibility of removing the contaminant
from the water supply.  The limit set must be feasible  given the
best available technology and treatment techniques.   A  margin of  safety is
included in each of the standards.  Safety margins vary from chemical  to
chemical because of the very different risks associated with each. EPA is  now
developing recommended MCLs (RMCLs) for drinking  water  based entirely  on
health considerations.
     5.4.4  National Ambient Air Quality Standards  (NAAQS)


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

     Primary standards must allow an adequate safety margin for unidentified
hazards and effects, though no rule is used in setting  this margin.   The law
requires EPA to direct its attention to particularly  sensitive  citizens, such
as bronchial asthmatics and emphysematics.  In developing primary NAAQS, EPA
must specify the nature and severity of the health  effects  of each contami-
nant, characterize the pertinent sensitive population,  determine  probable
adverse health effects for this population, and  estimate  the level below which
an adequate safety margin reduces or eliminates  risks.  Primary NAAQS thus
depend mainly on the direct health effects of chemicals to  sensitive  groups
calculated according to scientific data.
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     5.A.5  Federal Water Quality Criteria  and  State Water  Quality Standards


     Federal water quality criteria  for  protecting human  health  now cover
62 of 65 classes of toxic pollutants.  The  health assessment  criterion  is an
estimate of the ambient surface water concentration that  will  not  result  in
adverse health effects in humans, or, in the  case of suspect  or  proven
carcinogens, the concentrations associated  with  incremental cancer risks.
The Federal criteria are nonenforceable  guidelines and, therefore, are
listed as other criteria to be considered in  Table 4-2.   However,  many
States have used these criteria in developing enforceable ambient  water
quality standards.  These State standards   are  considered applicable and
relevant to Superfund remedial actions for  surface water  situations that
involve either drinking water or fish ingestion  exposure  routes.

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

      States must adopt water quality standards  stringent enough to protect
designated uses.  Numerical criteria may be based on EPA  recommendations  or
on other scientifically defensible methods.   States may also modify EPA's
recommended criteria to reflect local environmental conditions and human
exposure patterns.  When a criterion to  protect human health must  be  devel-
oped for a chemical that has no national criterion, the user should consult
EPA Headquarters for assistance.  The latest  guidelines for deriving  health-
related water quality criteria are published  in 45 FR 79341 (November 28,
1980).  Guidance (unpublished) on modifying human health  criteria  may be
found in the JRB Associates (1982) report "Suggested Protocol  by Which
States Could Recommend Surface Water Quality  Criteria for Specific  Water
Bodies for the Purpose of Protecting Human  Health" (EPA,  Office of Water
Regulation and Standards).  In general,   the user will be  directed  toward
specific risk level ranges as described  in  section 5.7.
2
 States with specific numerical ambient standards for toxics include
 Arizona, Arkansas, California, Colorado, District of Columbia, Delaware,
 Florida, Idaho, Kentucky, Louisiana, Maine, Maryland, Mississippi, Nevada,
 New Hampshire, New Jersey, New York, North Carolina, North Dakota, Ohio,
 Oklahoma, Oregon, Puerto Rico, South Dakota, Virginia, and West Virginia.
 Appropriate agencies in other states should be consulted to determine if
 standards have recently been adopted.
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     For most chemicals, Federal water quality criteria  to protect human
health are available for two different exposure pathways.  One  criterion  is
based on ingestion of both drinking water and aquatic  organisms,  and  the
other is based on ingestion of aquatic organisms alone.  The  criteria cal-
culations incorporate the assumption that a 70-kilogram  adult consumes  2
liters of water and/or 6.5 grams of aquatic organisms  daily  for a 70-year
lifetime.  Of course, calculations can be made to derive an  adjusted  cri-
terion for drinking water ingestion only, based on  the two published
criteria and the same dose assumptions.  Table 5-2  lists these  adjusted
criteria by chemical, along with the published criteria  for  combined
drinking water and aquatic organism ingestion.  The  adjusted  criteria are
more appropriate for Superfund sites with groundwater  contamination because
the criteria are based on a more realistic exposure  assumption.
     5.4.6  PCBs
     Superfund remedial actions should  consider EPA's  current  draft  PCB
cleanup policy currently under development by  the  Office of  Pesticides  and
Toxic Substances under authority of the Toxic  Substances Control  Act (TSCA)
Headquarters should be consulted to determine  the  impact of  this  policy on
specific RI/FS projects.  All disposal  of PCBs must  be in  accordance with
the PCB disposal and  labeling regulations (40  CFR  761).
5.5  CONSIDER OTHER  CRITERIA AND ADVISORIES
     Tables 4-2  and  5-2  list other  criteria,  advisories  and  guidance that
 should be  considered in  the development  and  evaluation of alternatives.
      5.5.1   Criteria  for Noncarcinogens


      On  the  basis  of  a survey of  the  toxicological literature, EPA has
developed a  "no  observed adverse  effect  level"  (NOAEL)  for many chemicals.
The  NOAELs are usually based  on animal  studies,  although human data are used
wherever available.   Safety  factors are  then applied to account for the
uncertainty  in using  available data to  calculate human  effects resulting in
an acceptable daily  intake (ADI).  Criteria (e.g., water concentrations) are
derived  from the ADIs and  the standard  dose assumptions given above.
      5.5.2   Criteria for  Carcinogens


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

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"safe"  levels of  carcinogens  because  there  is  no way at present to establish
a  threshold  for carcinogenic  effects.   Criteria for all carcinogens state
that  the  recommended  concentration  for  maximum protection of human health is
zero.   EPA has also estimated water concentrations  corresponding to incre-
mental  risk  levels using  a  linear,  nonthreshold extrapolation model.
Extrapolation models  provide  only an  estimate  of risk,  but are the best
available tool for describing the potential  threat  of a substance, given
certain assumptions.   In  its  criteria,  EPA  provides water7concentrations_,.
corresponding to  incremental  lifetime cancer risks  of 10  ,10  ,  and 10
     5.5.3  Health Advisories  (SNARLs)
     In addition  to MCLs,  EPA  also  provides  drinking water suppliers with
guidance on chemicals  that may be  intermittently  encountered in water sys-
tems and are believed  to pose  a near-term  risk, yet  are unregulated in
drinking water.   These guidelines  are  developed by  the  Office of Drinking
Water in the form of health  advisories  or  SNARLs.  Health  advisories are not
mandatory.  They  are calculated to  reflect the consumption and toxicological
characteristics of a 10-kg child (1-year-old  infant)  who consumes an esti-
mated 1 liter of  water daily.   SNARLs  are  calculated  for three exposure
levels:  1 day, 7 or 10 days,  and  for  a longer term  (weeks or months).   A
safety margin is  factored  in to protect  the most  sensitive members  of the
general population.  However,  SNARLs ignore  carcinogenic risks and  synergis-
tic effects of chemicals.  SNARLs  for  certain chemicals contain carcinogenic
risk estimates that can be used when appropriate.
5.6  ADJUSTMENT OF STANDARDS AND CRITERIA
     As a result of various technical aspects of  standards  development,  some
concentration limits will require adjustment before being applied  to  a  spe-
cific site.  The first step is to determine whether each concentration  limit
is directly applicable or must be adjusted for the specific  site conditions.
As an illustration of this, water quality criteria, which were  developed  for
surface water, can be adjusted for ground water by recalculating and
excluding the assumption of fish ingestion (as in Table 5-2).   Additional
guidance on adjusting standards for specific sites is under  development.


5.7  UNAVAILABLE OR INAPPROPRIATE STANDARDS
     As Table 5-2 shows, relevant or applicable ambient concentration limits
are not available for all media for many chemicals commonly found at
Superfund sites.

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

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

     Guidance on risk assessment is under development for those situations
where relevant or applicable standards are not available for every chemical
of concern.  The guidance will specify procedures for both carcinogens  and
non-carcinogens, and will address the issue of chemical mixtures.
Furthermore, the guidance will specify the risk range that alternatives will
be designed to meet.
5.8  SUMMARY OF PUBLIC HEALTH EVALUATION
     A summary of the public health effectiveness must be presented  for  each
alternative analyzed.  This includes an evaluation of the extent  to  which
each alternative attains, exceeds, or  falls short of applicable or relevant
environmental standards. Where these are not available,  the  analysis for
management of migration alternatives should evaluate the risks of various
exposure levels projected or remaining after implementation  of the
alternative under consideration.  Table 5-3 presents key questions to be
summarized in quantifying the public health effects associated with  each
alternative.  The summary presentation is  also  addressed in  chapter  8.
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TABLE 5-3.  SUMMARY OF KEY PUBLIC HEALTH EVALUATION QUESTIONS
   A.   Technical issues

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

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

       3.   What chemical releases will not be minimized or
           prevented?

       4.   Over what time will chemical concentrations be
           reduced at receptor locations, e.g., on-site, at
           drinking water intakes, in ambient air, etc.?
           (Be as specific as possible, providing
           qualifications if necessary.)

   B.   Exposure issues

       1.   What exposure is expected during the remedial
           action?

       2.   What exposure is expected after the remedial
           action?

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

       4.   What other criteria,  guidance  or advisories will
           be  met?

       5.   What adjustments were made to  standards,
           criteria,  advisories, or guidance?
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                                  CHAPTER 6

                       EVALUATE ENVIRONMENTAL IMPACTS
     In developing and evaluating response alternatives,  a major  concern  is
adequate remediation and protection of the environment.   The National  Oil
and Hazardous Substances Contingency Plan (NCP) requires, in section
300.68(i)(2)(D)  :

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

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

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

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

     Environmental contamination is often widespread  and may originate from
several sources.  The environmental assessment should focus on the site
problems and pathways of contamination actually addressed by the  alterna-
tives identified through screening.  The environmental assessment will help
determine which remedial alternativeCs) will achieve  adequate  protection  and
improvement of the environment at those sites where environmental damage  is
an important consideration.  A detailed analysis of environmental effects
need not be performed when they are not within the  scope of those alter-
natives.  However, any known environmental problems not  addressed by the
remedial alternatives should be clearly described.
1Federal Register, Vol. 47, No. 137, July 16, 1982.
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6.1  OVERVIEW OF THE ENVIRONMENTAL ASSESSMENT
     An environmental assessment of the "no-action"  alternative  should  be
performed for all sites.  This environmental assessment describes  the
current site situation and the environmental conditions anticipated  if  no
emergency or remedial actions are taken.  The  assessment  should  (1)  deter-
mine the value (or uses) of the areas  that  are  contaminated  or threatened
with contamination, (2) identify the types  of  impacts  that are likely,  and
(3) assess the general significance of the  impacts.

     The user can forego detailed analysis  of  the  adverse effects  of any
remedial alternatives under consideration if the preliminary analysis
conducted during the screening stage shows  that implementation will  not
result in any of the following:

     •  A substantial increase in airborne  emissions

     •  A new discharge to surface or  ground waters

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

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

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

The above criteria are based on the concepts of categorical  exclusion as
provided for in the National Environmental  Policy  Act  and subsequent
regulations (40 CFR 1508.4; 40 CFR 6.107, 6.506) and the  provisions  for a
finding of no significant impact (40 CFR 1508.13), which  exempts Federal
agencies from preparing an Environmental Impact Statement.   If an
alternative will not result in significant  adverse impacts and,  therefore,
does not' require preparation of a detailed  environmental  assessment  of
adverse effects, a statement should be prepared that documents that  finding
and summarizes the supporting reasoning.
6.2  EVALUATE ALTERNATIVE RESPONSES
     The environmental assessment should  address  the  effects  of  each
remedial alternative under consideration,  including long-term and  short-term
effects.  The level of detail  in the  environmental assessment should  depend
on the degree of actual or potential  damage  to  the environment providing  the
impetus for response.  The appropriate  level  of detail  will be determined by
the user but should be adequate to compare  the  expected environmental
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benefits of different  alternatives meaningfully  and  to  determine the extent
of the  impacts of  remedial  construction  and  operations.   Such information
should  assure the  public  and EPA  that  the  impacts  of remedial measures are
not significant  or result  from  the only  viable option,  and  should identify
problem areas and  suggest measures for mitigating  adverse impacts.

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

      Findings should  be  presented to  allow  comparing the environmental
effects of alternatives.   Environmental  effects of remedial  actions may
include a wide range of effects,  including hydrology, geology, air quality,
biology, socioeconomics,  land use, and archeological and historical sites.
In general, each alternative should be evaluated  by  considering such
beneficial effects of  the  response as  changes in  the release of contaminants
and final environmental conditions, improvements  in  the biological
environment, and improvements in  the resources that  people  use.  Expected
adverse effects  of remedial construction or  operations  should also be
considered in addition to  the effects  of the final remedy.   Each of these
topics  is discussed further below.

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


     6.2.1  Beneficial  Effects of the Response
         6.2.1.1  Changes in the Release of Contaminants  and Final
                  Environmental Conditions

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

     Federal legislation and regulations relevant to assessing environmental
impacts were discussed in chapter 4, notably the Clean Water Act; Marine
Protection, Research, and Sanctuaries Act; the Clean Air Act and the
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National Environmental Policy Act.  The regulations under these Acts  can
provide benchmarks to evaluate current or anticipated environmental
conditions.

     The ambient residual contamination predicted for different remedial
alternatives should be compared to existing criteria and standards.   How-
ever, available environmental criteria and standards may not  always be
suitable for direct comparison.  The user should determine  if the  site
conditions are substantially different from those used  to calculate the
criteria.  If they are, the criteria should be adapted  to actual site con-
ditions.  The user should consult with Federal and State agency personnel
who have expertise in modifying criteria or in determining  criteria for
substances that had none.  The following sections summarize criteria  that
have been developed or can be obtained by consultation with Federal and
State officials.

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

     States must adopt water quality criteria stringent enough to  protect
the designated uses.  Table 6-1 identifies States with  water  quality  stan-
dards by type of standard.  Numerical criteria may be based on EPA recom-
mendations or on other scientifically defensible methods.   States  may also
modify EPA's recommended criteria and set site-specific criteria where  (1)
background water quality parameters, such as pH, hardness,  temperature, and
color, appear to differ significantly from the laboratory water used  in
developing EPA's recommended criteria, or (2) the types of  local aquatic
organisms differ significantly from those actually tested in  developing the
EPA's recommended criteria or have adapted to higher pollutant levels.
Guidance on modifying national criteria on aquatic life is  found in the
"Water Quality Standards Handbook" (EPA, December 1983) and the "Draft
Technical Support Document For Water Quality-Based Toxics Control" (EPA,
Office of Water Regulation and Standards, November 28,  1980).  When a
criterion must be developed for a chemical for which a  national criterion
has not been established, the user should consult EPA headquarters for
assistance.  Guidelines for developing water quality criteria for  aquatic
life are published in 45 FR 79341 (November 28, 1980).  Revisions  to  these
guidelines have been proposed; see 49 FR 4553 (February 7,  1984).

     The revised water quality standards regulation (see 40 CFR 131;  48 FR
51400, November 8, 1983) emphasizes criteria for toxic  pollutants  in  State
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      TABLE 6-1.  AVAILABILITY  OF  STATE  AMBIENT  WATER QUALITY  CRITERIA
                     OR  STANDARDS  FOR  TOXIC  SUBSTANCES
State
Freshwater Criteria
   or Standards
    (Numerical)
Saltwater Criteria
   or Standards
    (Numerical)
                                                                Comments
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of
  Columbia

Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
          X
          X
          X
          X

          X
          X
          X
                   Numerical criteria
                   are effluent
                   limits for total
                   chlorinated
                   pesticides, PCBs,
                   and radioactivity
                   Adopted 304(a)
                   guidance
                   Currently revising
                   WQS to include
                   numerical criteria
                   for freshwater
                                                                 (continued)
 Includes both organic and inorganic contaminants.
 Narrative "free-form" toxics criteria for freshwater and saltwater are
 available for all states.
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                          TABLE 6-1.  (continued)'
State
Freshwater Criteria
   or Standards
    (Numerical)
Saltwater Criteria
   or Standards
    (Numerical)
Comments
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
          X
          X
          X
          X
          X
          X
          X
          X
          X
          X
          X

          X


          X

          X
                   Criteria are only
                   for rivers that
                   have drinking
                   water use desig-
                   nations
                                 X

                                 X
 Includes both organic  inorganic contaminants.
 'Narrative "free-form"  toxics  criteria  for  freshwater  and  saltwater  are
 available for all  states.
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 standards as the basis for permit limitations under the National Pollutant
 Discharge Elimination System.  Most State standards do not include numerical
 criteria for many toxic chemicals.  When standards do not specify criteria
 for toxic chemicals, guidance documents on criteria or literature reports
 are used.  All States have a general narrative requirement in their water
 quality standards that their waters must not contain toxic substances in
 toxic amounts.  Most State standards include a narrative criterion for fish
 and wildlife designated uses that applies after mixing and requires no
 chronic toxicity to representative test organisms.  These State standards
 typically include application factors for deriving a discharge chronic
 toxicity value from an acute toxicity value (i.e., 0.05 for nonpersistent
 wastes and 0.01 for persistent wastes).

      Ground Water.   The ground-water policy discussed in chapter 4 provides
 guidance but not specific ground-water criteria.   The user should consult
 guidance documents  appropriate to ground-water protection when they become
 available from OGWP.

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

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

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

     When  commercial crops  are threatened by  airborne substances  some
measure  of the air quality  should  be developed to  take account of crop
damage.  The  National  Crop  Loss Assessment Network gathers data on  the
relationships between  yields  of major agricultural  crops and exposure  to
substances like sulfur  dioxide.
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         6.2.1.2  Improvement in the Biological Environment


     The user should describe the remedial alternatives' likely improvements
in the biological environment.  An uncontrolled waste site often threatens
nearby biological communities, for example, by changing the ecological
structure that supports organisms.  The ability of alternatives to  reduce or
eliminate such threats should be clearly stated.

     The user should note the benefits of the alternative, especially with
regard to:

     •  Sole source aquifers

     •  Wetlands

     •  Floodplains

     •  Coastal zone

     •  Critical habitats

     •  Prime agricultural lands
     •  Federal parklands

     •  National forests

     •  Wildlife sanctuaries  and refuges

     •  Habitat productivity.

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

     Sole Source Aquifers.   A sole  source  aquifer is  designated under
section 1424(a)(l)  of  the Safe Drinking Water Act as  being  the sole or
principal drinking  water source  for  an  area  and,  if  contaminated,  a signif-
icant hazard  to public health.   EPA  has now  designated  17  sole source
aquifers  and  is considering  petitions  for  other  areas.

     Wetlands.  Wetlands are  areas  inundated or  saturated by  surface water
or ground water  frequently and persistently  enough to support vegetation
adapted to  saturated  soil.   Wetlands generally  include  swamps, marshes,
bogs, and similar  areas, and  may be  defined  by  referring  to U.S.  Fish  and
Wildlife  Circular  39  (1956)  and  later  revisions  resulting  from the  National
Wetlands  Inventory.   A wetlands  assessment must  be conducted  as part of the
feasibility study.  EPA  is preparing a formal  policy for  conducting wetlands
assessments at  Superfund sites.   Information on environmental stress and
remedial  actions  for  wetlands can  be obtained from the  U.S.  Department of
the  Interior,  the  U.S. Department  of Commerce,  the U.S. Army Corps of
Engineers,  and  appropriate State offices.
                                     6-8

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

      Coastal Zones.  Coastal zones are areas  subject to management plans
 under the Coastal  Zone  Management Act.  Information on the effects of
 releases on coastal zones can be obtained from the Department of Commerce
 and  from State agencies with management responsibilities under the Coastal
 Zone  Management Act.

      Critical  Habitats  of Threatened or Endangered Species.  The Secretary
 of the  Interior has determined that certain habitats are critical to the
 continued existence of  threatened or endangered species listed under section
 4 of  the Endangered Species Act of 1973.  Information about effects of
 releases on threatened  and endangered species and critical habitats can be
 obtained from  the  Department of the Interior, the Department of Commerce,
 and  State fish and wildlife agencies.

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

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

     National Forests.   If  a  site's  condition threatens  national  forest
 land, the user should consult  the  U.S.  Forest  Service at  the Department of
Agriculture.   The  Forest  Service  is  required  by the  Forest and Rangeland
Renewable Resources Planning Act  of  1974  and  the  National  Forest  Management
Act of  1976 to prepare  Federal  and  regional management plans.   The  user
should note the effects  of  remedial  activities  on  these  plans.
                                    6-9

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

     •  National park system
     •  National wildlife refuge system

     •  National wilderness preservation system
     •  Wild and scenic river system

     •  National trail system
     •  Marine and estuarine sanctuaries program.

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

     Habitat Productivity.  The productivity of the habitat of a
commercially or recreationally important species can be threatened by  the
discharge from an uncontrolled site.  Such reduction in productivity can
take various forms:

     •  Loss of species
     •  Changes in their relative abundance

     •  Changes in their sizes
     •  Changes in their age structure.

In such cases, the user should note the species and their habitats and
discuss the improvement expected from each alternative.  The  user may  wish
to consult the EPA STORET water quality file for data on water quality
indicator substances.  States often have standards  for specific habitats  and
harvesting areas.  The user should consult the appropriate public health  and
fish and wildlife agencies.


         6.2.1.3  Improvements in Resources People  Use


     Often an uncontrolled site damages or threatens to damage resources
people use.  Many of these resources, such as fishing waters  and recreation-
al areas, directly affect the welfare of local communities.   Users should
note the ability of alternatives to protect present or potential human uses
of resources, especially commercial, residential, recreational, esthetic,
and cultural uses.

     Commercial Uses.  Many environmental resources at sites  provide
important goods and services traded in the marketplace.  Commercially


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

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

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

     Esthetic Uses.  Many environmental  resources  are appreciated for their
esthetic value, which can be  impaired either  by  a  discharge or by the
response to it.  Esthetic value is  a subjective  matter,  and the users of
this manual should  not be encumbered with  an  in-depth study of site
esthetics.  The user's own judgment  supported by  consultation with local
community associations should determine  the extent of concern.
     6.2.2  Adverse Effects of the Response


         6.2.2.1  Expected Effects of Remedial Alternatives


     The user should identify and evaluate any expected adverse effects of
remedial construction and operations.  In identifying these effects, the
user should especially consider sensitive environmental areas and resources
people use.  The user should distinguish inevitable effects from possible
ones, so that the evaluation of alternatives can estimate the probability of
expected adverse effects.  Equally important is recognizing that some
effects are irreversible.  The users should state that effects are rever-
sible or irreversible if they are significant.
                                    6-11

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         6.2.2.2  Mitigative Measures
     If any alternative appears to have significant inevitable or  irreversi-
ble effects, the user should state the mitigative measures to be taken  in
conjunction with the alternative.  The statement should discuss the  tech-
nology to be employed and its expected mitigating effects (e.g., percentage
reduction in adverse effects).  It is generally assumed that mitigating
measures will not affect the success of remedial alternatives.  If success
may be compromised by the mitigative measure, the user should note this.
6.3  OTHER ASSESSMENT PROGRAMS
     The user can obtain assistance in developing an assessment  program by
consulting information on other environmental damage assessment  procedures.
These procedures have been developed by State and Federal agencies  charged
with protecting environmental resources.  Most have been field tested  and
reflect the need for applicability rather than the higher methodological
rigor characteristic of research.  An important element in  these  procedures
is selecting assessment methods that can be used given available  time  and
resources.  The following references may be particularly useful:

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

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

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

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

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

     •  Battelle Pacific Northwest Laboratory, "Field Guide  for  Scientific
        Support Activities Associated with  Superfund Responses,"  Battelle
        Memorial Institute, 1979.
6.4  SUMMARY OF ENVIRONMENTAL ANALYSIS
     The output  format  suggested here  condenses  the  discussion of alter-
natives to  five  composite  criteria.  The  format  is  illustrated in Table 6-2.
                                     6-12

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

                                                 TO EVALUATE REMEDIAL ALTERNATIVES
                            Beneficial  Effects
                                                                                              Adverse Effects
              Final
          Environmental
Alternative Conditions
Improvements  In
   Biological
    Environment
Improvements In
   Human Use
    Resource
Const/Operation
Mltlgatlve Measures
1st
2nd
3nd
4th
 Indicate whether adverse effects are expected to be reversible or Irreversible over time.

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     The relative desirability of each alternative should be described with
respect to each of the evaluation criteria.  The user may choose to describe
the alternatives in order of their relative desirability with respect to
each criterion, or to describe them on an absolute basis according to the
degree to which they fulfill each criterion.  Whichever method is chosen,
the user should provide a consistent discussion of each alternative.
                                     6-14

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                                  CHAPTER 7

                      CONDUCT A DETAILED COST ANALYSIS
     This chapter outlines the recommended approach to developing  and
analyzing costs for each of the remedial action alternatives remaining after
initial screening (see chapter 2).  EPA is developing a "Remedial  Action
Costing Procedures Manual" which presents more detailed costing procedures.
The object of the costing exercise is to develop cost estimates for alter-
natives, as specified in section 300.68(i)(2)(B)1 of the NCP:

     (i) Detailed Analysis of Alternatives

          (1)  A more detailed evaluation will be conducted of the limited
               number of alternatives that remain after the initial
               screening in paragraph [h]

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

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

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

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

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

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

     4.  Summarization of alternatives analysis:  Summarize data used in the
         alternatives analysis for use in selecting a remedial action
         alternative.

Figure 7-1 illustrates these steps, which are discussed in the following
sections.
federal Register, Vol. 47, No. 137, July 16, 1982.
                                    7-1

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      FIGURE 7-1.   Feasibility Study Cost Evaluation Process
                                Remedial
                               Investigation
                              Estimation of
                                 Costs
                              Present Worth
                                Analysis
  Feasibility
    Study
Cost Evaluation
  Activities
                               Sensitivity
                                Analysis
                                Input to
                               Alternatives
                                Analysis
                               Selection of
                           Remedial Alternative
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7.1  ESTIMATION OF COSTS
     The user should identify all capital and operation and maintenance
costs for each remedial action alternative, and estimate the cost of these
components using the sources suggested below under section 7.1.3, "Sources
of Cost Information."  Where cost estimates are derived from data a year or
more old, they should be updated using the cost indices discussed under
section 7.1.4, "Updating Costs."

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

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

     Only costs incurred during the remedial action phase are eligible for
funding under Superfund.  EPA defines remedial actions as activities
required to prevent or mitigate migration of hazardous materials released
from an uncontrolled site.  Remedial actions are directed at achieving
cleanup goals.  Post-closure activities occur after completion of the
remedial action and include continued operations necessary to stop such
releases.

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

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

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

                                    7-3

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     •  Post-closure activities include measures that (1) are required  to
        maintain releases at levels protective of public health, welfare,
        and the environment, (2) require long-term  implementation,  (3)  have
        no definable endpoint, (4) maintain the physical integrity  of the
        remedy, or (5) provide for scheduled monitoring or repair.


     While the distinction between remedial action  and post-closure
activities is made for purposes of determining eligibility,  it  should not be
a factor in feasibility cost analysis.  Cost estimates should give  compara-
tive life-cycle cost information for the remedial action alternatives under
consideration.  These alternatives should include all costs  incurred as part
of both the remedial action and post-closure phases.  As in  conventional
construction, cost estimation distinctions are made between  capital and
operation and maintenance costs.


     7.1.1  Capital Costs


     Capital costs consist of direct (construction) and indirect
(nonconstruction and overhead) costs.  Direct costs include  expenditures for
the equipment, labor, and materials necessary to install remedial actions.
Indirect costs include expenditures for engineering, financial, and other
services not part of actual installation activities but required to complete
the installation of remedial alternatives.  Capital costs that must be
increased in future years as part of the remedial action alternative should
be identified and noted for the year in which they will occur.  It  is
particularly important to emphasize out year capital costs in the summary of
alternatives and to examine the impact of alternative discount  rates in the
sensitivity analysis.  These will be critical factors in making tradeoffs
between capital intensive technologies (including alternative treatment and
destruction technologies) and non-capital intensive technologies (such  as
pump and treatment systems).


         7.1.1.1  Direct Capital Costs


     Direct capital costs may include:

     •  Construction costs:  Costs of materials, labor (including fringe
        benefits and worker's compensation), and equipment required to
        install a remedial action.

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

     •  Land and site-development costs:  Expenses  associated with  purchase
        of land and development of existing property.
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     •  Buildings and services costs:  Costs of process and nonprocess
        buildings, utility connections, purchased services, and disposal
        costs.

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

     •  Disposal costs:  Costs of transporting and disposing of waste
        materials, such as drums and contaminated soils.
        7.1.1.2  Indirect Capital Costs


     Indirect capital costs may include:
     •  Engineering expenses:  Costs of administration, design, construction
        supervision, drafting, and testing of remedial action alternatives.

     •  Legal fees and license or permit costs:  Administrative and
        technical costs necessary to obtain licenses and permits for
        installation and operation.

     •  Startup and shakedown costs:  Costs incurred during remedial action
        startup.

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


     7.1.2  Operation and Maintenance Costs
     Operation and maintenance costs are post-construction costs necessary
to ensure continued effectiveness of a remedial action.  The user should
consider the following operation and maintenance cost components:

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

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

     •  Auxiliary materials and energy:  Costs  of such items as chemicals
        and electricity for treatment plant operations, water and sewer
        service,  and fuel.

                                    7-5

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

     •  Administrative costs:  Costs associated with administration of
        remedial action operation and maintenance not included under other
        categories.

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

     •  Maintenance  reserve  and contingency funds:   Annual payments into
        escrow funds to cover (1) costs of anticipated replacement or
        rebuilding of equipment and (2) any large unanticipated operation
        and maintenance costs.

     •  Rehabilitation costs:  To maintain equipment or structures that wear
        out over time.

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


     7.1.3  Sources  of Cost  Information
     In estimating costs, the user should consider site-specific factors
identified in the remedial investigation and the development of remedial
action alternatives.  The sources for these estimates are discussed below.
         7.1.3.1  Vendor Estimates
     Based on detailed site and design information, equipment vendors and
construction companies can provide site-specific remedial action construc-
tion and equipment cost estimates.  Equipment vendors can provide informa-
tion on their equipment's service requirements.  Equipment specifications
often provide information on auxiliary materials and energy usage costs.
Recommended maintenance schedules can provide a good indication of annual
costs, although they are often estimated as percentages of capital costs.


         7.1.3.2  Estimates for Similar Projects


     Estimates for similar projects or, preferably, actual experience with
such projects, are good sources of cost information.  Where necessary, these
costs should be updated as described below in section 7.1.4.
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         7.1.3.3  Standard Costing Guidance


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

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


     7.1.4  Updating Costs


     Cost estimates are frequently based on data several years old and must
be updated for the' current year.  Appropriate cost indices include the
following:

     •  Engineering News Record Construction Cost Index (capital costs of
        construction)

     •  Marshall and Stevens Index (for treatment facility costs)

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

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


     7.1.5  Accuracy of Cost Estimates


     Detailed site characterization information from the remedial investiga-
tion should permit the user to refine cost estimates for remedial action
alternatives.  In some cases, studies will be necessary to determine actual
design characteristics so costs can be accurately estimated.  Although they
may be performed to obtain design data relevant to the feasibility study,
such studies should be considered part of the remedial investigation.  Only
the results of these studies are addressed in the feasibility study.  When
the applicability of the alternative has been established and can be esti-
mated with the required accuracy, the bench-scale studies could be delayed
until after the remedy has been accepted, in which case the engineer should
provide a best estimate of design parameters for use in estimating costs.
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     It is important to consider the accuracy of costs developed for a
feasibility study.  Typically, these "study estimate" costs provide an
accuracy of -30 to +50 percent, and are prepared at relatively low cost
using data available from the remedial investigation.  Costs developed with
accuracies other than -30 to +50 percent should be identified in the
feasibility study.
7.2  PRESENT WORTH ANALYSIS
     Present worth analysis is used to evaluate expenditures that occur over
different time periods by discounting all future costs to a common base
year, usually the present.  This allows the cost of remedial action alterna-
tives to be compared on the basis of a single figure representing the amount
of money, that, if invested in the base year and disbursed as needed, would
be sufficient to cover all costs associated with the remedial action over
its planned life.

     In conducting the present worth analysis, assumptions must be made
regarding the discount rate and the period of performance.  For the first, a
discount rate of 10 percent before taxes and after inflation should be
assumed, as outlined in OMB Circular No. A-94.  This rate represents the
average rate of return on private investment.  In addition to using a
discount rate of 10 percent, it is useful to conduct a sensitivity analysis
using other discount rates as well (e.g., 4 percent, 7 percent).  This is
discussed further in the next section.  Estimates of costs in each of the
planning years are made in constant dollars, representing the general
purchasing power at the time of construction.  The period of performance
should not exceed 30 years for the purpose of detailed feasibility analysis.


7.3  SENSITIVITY ANALYSIS
     After the present worth of each remedial action alternative is
calculated, each cost should be evaluated for effects of variations in
assumptions through sensitivity analysis.  A sensitivity analysis assesses
the effect that variations in specific assumptions associated with the
design, implementation, operation, discount rate, and effective life of an
alternative can have on the estimated cost of the alternative.  These
assumptions depend on the accuracy of the data developed during the remedial
investigation and on predictions of the future behavior of the remedial
technology and are subject to varying degrees of uncertainty.  The
sensitivity of costs to these uncertainties can be observed by varying these
assumptions and noting the effects on estimated costs.  Sensitivity analysis
can also be used to optimize the design of a remedial action alternative,
particularly when design parameters are interdependent (e.g., treatment
plant capacity for contaminated ground water and the length of the period of
performance).
                                    7-8

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

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

     •  Effective life of  remedial action  (replacement)

     •  Operation and maintenance costs

     •  Duration of cleanup (period of performance)

     •  Extent of cleanup, given uncertainty  about  site conditions
     •  Other design parameters
     •  Discount rate.

     The choice of a discount rate could be critical in options  that include
high operation and maintenance costs over  extended  periods.  The user  is
encouraged to identify those situations  when  the choice of  a 4  percent or
7 percent discount rate would produce a  different low cost  option.   In those
situations, sensitivity analyses about differing discount rates  should be
included in the presentation of alternatives.

     The "time value" of money can substantially affect the present  worth
ranking of competing alternatives, particularly where there is  wide
disparity between capital  and operation  and maintenance costs  among  the
alternatives.  The sensitivity of the present  worth of  competing alterna-
tives to the assumed discount rate is best illustrated  by an example
comparison.  Table 7-1 presents an analysis of three ground-water  protection/
cleanup alternatives at applied discount rates of 4, 7, and 10  percent over
30-year system lives.  Application of the  lowest discount rate  tends to
favor (to result in lowest present worth)  alternatives  having  relatively  low
operation and maintenance  costs and high capital costs, while  application of
the highest discount rate  tends to favor alternatives having relatively low
capital costs and high operation and maintenance costs. . This  trend  is shown
in the ranking of costs of the three alternatives in Table  7—1;  it is
possible that a given alternative may have the highest, lowest,  or an
intermediate present worth, depending on the discount rate  being considered.

     Additional guidance is under development  which contains worksheets
enabling the user to manipulate key parameters affecting remedial  action
cost and to measure the resulting effect.  The manual also  discusses factors
the user may choose to analyze, and provides an example showing  completed
worksheets for a hypothetical alternative.
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              TABLE  7-1.   PRESENT WORTH ANALYSTS OF  THREE ALTERNATIVES AT THREE DISCOUNT RATES
Alternative
                               Descript ion
Capital
                                                 OS. M
Cost Estimates ($1,000)

             Annual
 Capital      O&M
                                                                       Present Worth at
                                                                    Discount  Rate ($1,000)
                                                                                                4%
ior
 I
I—•
o
             Install slurry cut-off
             wall and ground-water
             monitoring system

             Install ground-water
             pumping and treatment
             system and ground-water
             monitoring system

             Install ground-water
             pumping system and
             ground-water monitoring
             system
                 Inspect  surface            10,000         200
                 conditions  and
                 monitor  ground water

                 Provide  energy,  labor,      5,000         600
                 and materials  to afford
                 pumping  and  treatment
                 and monitor  ground  water

                 Provide  energy,  labor,      1,000       1,000
                 and materials  to afford
                 pumping,  haul  water to
                 off-site  treatment
                 facility, and  monitor
                 ground water
                                                                                              13,458   12,482   11,885
                                                                                              15,375   12,445   10,656
                                                                                              18,292   13,409   10,427
                                       Ranking
                                          C-B-A
                                                       A-B-C
                                                                                              A-B-C    B-A-C    C-B-A
 Present worth of annuity factor for 30 years  =  17.292
 Present worth of annuity factor for 30 years  =  12.409
 Present worth of annuity factor for 30 years  =   9.427
 In order of lowest to highest cost.

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7.4  SUMMARY OF ALTERNATIVES COST ANALYSIS
     Data developed in the cost estimation and present worth analysis stages
are used in a summary table to describe the alternatives (see chapter 8).
Decisionmakers responsible for cost-effectiveness determinations must have a
common basis for comparing costs when evaluating various remedial action
alternatives.  Therefore, three critical cost elements should be developed
and assembled for input into the cost-effectiveness analysis:  (1) total
capital cost, (2) present worth costs, and (3) the cash flow over the life
of the remedial action alternative.

     The cash flow of a remedial action alternative presents a tally of the
anticipated costs for each year of the remedial action alternative.  The
presentation of costs in this manner allows decisionmakers to identify and
assess future capital and operation and maintenance outlays, which are
important in planning budgets.

     It should be noted that the presentation of the costs for each
alternative should include all costs associated with implementation of the
alternative.  Costs common to all alternatives must be included with each
alternative so that the total estimated cost for each is readily apparent.
                                    7-11

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                                   CHAPTER 8

                            SUMMARIZE ALTERNATIVES
 8.1   OVERVIEW
      This  chapter  is  a guide to summarizing the detailed technology, public
 health,  environment,  and cost evaluations discussed in chapters 3 through 7.
 The summary of alternatives is a key step in comparing the alternatives so
 the decisionmaker  can select the cost-effective remedy in accordance with
 CERCLA and the NCP.

      The diversity of site characteristics, the mass of information
 collected,  and the range of factors  that  must  be considered makes evaluating
 remedial alternatives and selecting  one  for implementation difficult.  In
 this  context,  decisionmaking cannot  be carried out  by applying a
 deterministic  decision rule.  The decisionmaker, armed with the necessary
 information, must  instead consider relevant and applicable standards,
 appropriate criteria  or  guidance,  health  and environmental concerns,
 technological  reliability,  cost,  and other  appropriate factors associated
 with  each  alternative.   These factors must  be  evaluated and specific circum-
 stances  at  a site  must be taken into account during their evaluation.


 8.2   CERCLA COMPLIANCE WITH OTHER ENVIRONMENTAL LAWS
     Chapter 4 discusses the categories of alternatives  that must be
examined under the "CERCLA compliance with other  laws  policy."   The summary
of alternatives must present these to the decisionmaker  as well.

     When the specific conditions preclude development of alternatives  in
one of the required categories, the feasibility study must document the
reasons for that decision.  Occasionally, an alternative may fall into more
than one category.

     The decisionmaker will consider all of the alternatives arrayed in the
summary, and will give primary consideration to the remedies that attain or
exceed applicable or relevant Federal public health and environmental
standards.  The decisionmaker would then select a remedy that attains or
exceeds applicable standards unless one of the specific circumstances
discussed below is determined to exist by the decisionmaker.  Where relevant
or applicable standards are not available or criteria or advisories are not
                                    8-1

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used, the user will be directed by EPA headquarters to achieve a specific
risk level or range of risk levels as described in chapter 5.

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

     If disposal of hazardous substances off-site is part of the selected
response, the decisionmaker also would ensure that the off-site facility
selected is acceptable under the policy in force at the time.  Appendix B
describes current EPA policy.

     The decisionmaker may select a remedial action that includes both
source control and management of migration response actions consistent  with
this policy.

     The decisionmaker may select an on-site alternative that does not
attain applicable or relevant standards in one of the following specific
circumstances, recognizing that a consideration in making this determination
is the extent to which the standard was intended to apply to the specific
circumstances present at the site :

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

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

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

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

         (iii)  Unacceptable environmental impacts - all alternatives that
                attain or exceed standards would cause unacceptable damage
                to the environment; or,
 In determining whether  a  particular  standard  is  applicable  or  relevant,  the
 decisionmaker should refer to  the list of "Applicable  or  Relevant  Require-
 ments"  in the CERCLA compliance  policy.  For  example,  RCRA  did  not "contem-
 plate"  the regulation of  indiscriminant disposal  of waste over  210 miles of
 roadway, or  the contamination  of a river bed  with hazardous waste.  In such
 situations,  RCRA regulations would not be applicable per  se, but  on a case-
 by-case basis, part of  the regulation may be  relevant.
                                     8-2

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     3.  Where the remedy is to be carried out pursuant  to  CERCLA  section
         106; the Hazardous Response Trust Fund is unavailable;  there  is a
         strong public interest in expedited cleanup; and the  litigation
         probably would not result in the desired remedy.

     The Agency anticipates that most CERCLA remedial actions  will  attain or
exceed applicable or relevant public health or environmental standards.
However, where the specific circumstances discussed above preclude  the
selection of a remedy that attains standards, the decisionmaker  would  select
the alternative that most closely approaches the level of protection pro-
vided by the applicable or relevant standard, considering the  reasons  for
not meeting that standard.


     8.2.1  Other Federal Environmental Standards, Guidance, or  Advisories


     EPA will encourage other Federal agencies to use their statutory
authorities in connection with response actions.  In developing  remedial
alternatives, the EPA should take these standards, guidance, or  advisories
into consideration.  If an alternative is selected after consideration of
these standards, guidance, or advisories but does not achieve  them, the
decision documents would state the reasons for the decision.
     8.2.2  State Environmental Standards, Guidance, or Advisories
     If a State desires the selection of a remedial action  incorporating
State standards more stringent than Federal standards, the  decisionmaker may
select that remedy.  The State generally would be expected  to pay  additional
costs incurred in achieving the more stringent standards, but the  EPA
decision official may make exceptions to this policy in appropriate
circumstances.
8.3  ORGANIZE AND PRESENT INFORMATION
     Pertinent information on costs, health risks, environmental effects,
reliability, and other factors should be presented for each remedial alter-
native, including the no-action alternative, so that the key differences
among alternatives are evident.  Remedial alternatives that attain or exceed
the requirements of applicable environmental regulations should be iden-
tified.

     A narrative summary describing such factors as cost, technology,
reliability, adverse impacts, and other factors should be used to compare
all on-site alternatives to each other and to off-site disposal alterna-
tives .
                                    8-3

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     If there are not applicable or relevent Federal public health or
environmental standards, the evaluation should be based on the degree to
which each alternative mitigates and minimizes threats to and provides
adequate protection of public health, welfare, and the environment, con-
sidering cost, technology, adverse impacts, and the reliability of the
alternative.

     The following information, at a minimum, must be provided for each
remedial alternative:

     •  Present worth of total costs:  The net present value of capital and
        operating and maintenance costs must be presented.

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

     •  Environmental effects:  To simplify the evaluation, only the most
        important.effects should be summarized.  Reference can be made to
        supplemental information in a separate table, if necessary.

     •  Technical aspects of the alternative:  This information may strongly
        influence the selection of a remedial alternative, and it is
        important to describe carefully the technical advantages and
        disadvantages of alternatives.  Such information generally is based
        on the professional opinion of engineers familiar with the site and
        with the technologies comprising the alternatives.

     •  Information on the extent to which alternatives meet the technical
        requirements and environmental standards of appropriate environ-
        mental regulations:  This information should be arrayed so that
        differences between the alternatives, in terms of how they satisfy
        such standards, are readily apparent.  The kinds of standards
        applicable at the site may include (1) RCRA design and operating
        standards,  (2) drinking water standards, and (3) environmental
        discharge standards.

     •  Information on community effects:  The types of information that
        should be provided include (1) the extent to which implementing an
        alternative would disrupt the community (e.g., traffic, temporary
        health risks, and relocation) and (2) the likely public reaction.

     •  Information on remedies involving removal of materials for off-site
        disposal:  This information should document compliance with EPA
        policy on selecting off-site EPA approved facilities for disposal of
        materials from CERCLA sites.
                                    8-4

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

     Tables 8-1 through 8-3 are  examples  showing how  to summarize the most
important information to consider  in the  selection  of a remedy.  This
summary, supported by the RI/FS  studies,  provides the body  of  information
the decisionmaker must use to select a cost-effective remedy.  Table 8-1
lists hypothetical alternatives  for source control measures  at the  Lehigh
Electric site, and Table 8-2, for management  of migration measures  at the
Reilly Tar site.  Table 8-3 presents a hypothetical case in  which both
source control and management of migration measures were developed  for
analysis.  In  some cases, both source  control measures  and management of
migration measures may be combined to  form one alternative,  and  are
presented in the table as a combined alternative.   Each table  describes the
alternatives in terms of effectiveness, cost, and other features.

     When on-site alternatives are being  considered,  the feasibility study
will generally recommend the  alternative which attains  or exceeds applicable
or relevant Federal public health or environmental  standards except when
five specific  circumstances are determined to exist at  the  site, as required
by EPA's policy on compliance with other environmental  laws  (described in
section 8.2).  In addition, appropriate Federal public  health,  and environ-
mental criteria, advisories,  and guidance, and State  standards can  be used
in recommending the alternative.

     The summary of alternatives should highlight important  differences
among alternatives, reducing  to manageable proportions  the  information to be
reviewed by the decisionmaker.   The summary's precision should be consistent
with the extent of knowledge  about the problem and  the  expected  results of
remedies.
                                    8-5

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                      TABLE 8-1.  SOURCE CONTROL ALTERNATIVES  SUMMARY FOR LEHIGH ELECTRIC
co
Alternative
1.




2-3.



4-6.




7.



No action




Soil removal to
10 ppm, site
management or
capping
Soil removal to
50 ppm, site
management ,
capping, or
encapsulation
Soil removal to
50 ppm with
additional
excavation
Cost ($1,000)
Present
Capital Worth
10




7,500 7,500
7,600 7,600


6,100 6,100
6,500 6,500



6,400 6,400



Public Health
Concerns
PCB exposure: Ingestlon,
Inhalation, and dermal
exposure to PCBs above
50 ppm.

Assume PCBs are Immobil-
ized (no risk).


Assume PCBs are Immobil-
ized (no risk).



Assume PCBs are Immobil-
ized (no risk).


Community
Environmental Technical Response
Concerns Concerns Concerns Other
Minimal protection — Unacceptable. Landfill PCBs
for migration to (Standards are
aquifer and river. 50 ppm).
No contamination
documented to date.
Minimal — Acceptable.
potential for migration.


Minimal
potential for migration. — Unacceptable.



Minimal — Negotiated. Agreement.
potential for migration.


             Option selected.

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                 TABLE  8-2.    MANAGEMENT  OF  MIGRATION  ALTERNATIVES  SUMMARY  FOR  REILLY  TAR,   FIRST  OPERABLE UNIT
00
Cost (SI, 000)
Present7 Public Health
Alternative Capital Worth Concerns
1.

2.


3.




No action

Connection to 250
Hlnneapoll a
water aysten
Drill deeper 1,870
underlying
formations


Unacceptable exposure to
PAH during gumer or
during
8,102 Reduces
threat
fires.
public health
to less than
Environmental
Concerns
Continued migration
of contaminated
ground water.
Does not control
ground water.
Technical
Concerns
—

Relies on staple
technology.
10 " (migration).
2,916 Reduces
10"K.



public health




Does not control
water migration.
Depletes Halted
water resources In
deeper aquifer.
Relies on proven
no ogy



Community
Response
Concerns
High
resistance*

Other


Acceptable. Has significantly
O&M and
cost.
Acceptable. Has second




present

highest







higher
worth






4.  Aqulfer t reatment

   A.  Ozone          374     1,618




                    459     2,109





                    709     2,434
B. Granular
     activated
     carbon
     (GAC)
                                    633
                                           2,150
                                    633    2.263
                                                   Removes taste and odor,
                                                     but results In 10~  to
                                                     10   risk (2,000 ng/L
                                                     for noncarclnogenlc PAH)  .
                                                     risk (1,000 ng/L for
                                                     noncarc1nogenlc PAH)a
Results  In  10   or less
  risk (280 ng/L for
  noncarc1nogenlc PAH)a.

Removes  taste and odor
  but  results In 10~  to
  10~* risk (2,000 ng/L
  for  noncarclnogenlc
  PAH)a.

Results  In  10~5 to 10~6
  risk (1,000 ng/L for
  noncarclnogenlc PAH)a.
                            Blocks migration  and
                             allows additional
                             wells to be opened*
                                                                              Blocks migration  and
                                                                                allows additional
                                                                                wells to be opened.
Not used  on wide scale.      Acceptable.
  Less responsive than
  granular activated
  carbon  to slug loading.
  Would be expensive to
  retrofit If treatment
  goals change.  Certainty
  that target risk levels
  In "Public Health Concerns"
  column  will not be
  consistently
  met is  low due to
  operational Inflexibility.
Considered best available    Acceptable.
  technology.  Proven over
  a wide  range of operating
  conditions.  Responds well
  to slug loading.

Likely to meet risk target
  in "Public Health Concerns"
  column, consistently.
                                                                                                                          Present worth is less
                                                                                                                            than for GAC at  low
                                                                                                                            treatment level,  but
                                                                                                                            greater at recommended
                                                                                                                            (lowest risk) level.
                                    633   24,058
                                                   Results  In 10   or less
                                                     risk (280 ng/L for
                                                     noncarclnogenic PAH)*.
                 Approximate organoleptlc threshold.
                                                                                          Present worth Is less
                                                                                            at  recommended
                                                                                            t reatment leve1•

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        TABLE 8-3.    SOURCE  CONTROL AND MANAGEMENT  OF  MIGRATION  ALTERNATIVES  SUMMARY  FOR  HARD TIMES  WASTE  SITE
- - - 	
Cost ($1,000)
Present ~ Public Health
Alternative Capital Worth Concerns
I . Source Control
1. No action 10 — Unacceptable exposure to
TCE through continued

Could potentially cause
(direct contact
with humans, unsecured
areas).
subsurface and surface water.
removal of drums Public risk reduced
Community
Environmental Technical Response
Concerns Concerns Concerns Other
Continued migration — Unacceptable.
to the ground water

Could threaten
endangered aquat Ic
species.
air and surface technology. to RCRA permitted
water. Ground- facility.
                                  ,
                          fence                          surface waste and con-     continues but                                   effectiveness
                                                        tamlnated  areas secured),   majority of                                    monitoring
                                                                            '      source (above                                   required.
 I                                                                                 ground) Is
Oo                                                                                controlled.
                                                                                  Impact to endangered
                                                                                  aquatic species  Is
                                                                                  reduced.

                    3.  Surface  and sub-    650  9,350   Assume no direct contact   Reduces release       Proven       Moderately    Removal of waste
                          surface  removal,               or Ingest Ion (no risk).     to air and surface    technology.   acceptable.   to RCRA-permlttcd
                          security fence,                                          water.  Ground-                                 facility.   High
                          alternative water                                        water release  con-                              0 & M costs
                          supply                                                  tinues but majority                             associated  with
                                                                                  of source (above                               alternative water
                                                                                  ground) Is controlled.                          supply.  Effective-
                                                                                  Impact to endangered                            ness must be
                                                                                  aquatic species  is                              monitored.
                                                                                  reduced.

                    4.  Surface  removal,  2,500  3,000   Assume no direct contact   Eliminates release   Proven       Moderately    Removal of waste to a
                          capping  and                    or ingest Ion (no risk).     to air and           technology.   acceptable.   RCRA permitted
                          grading,                       Controls source of         surface water.                                 facility.   The
                          temporary                      ground-water release.      Impact on endangered                            Blurry wall must
                          alternative                                              aquatic species                                 contain a large
                          water  supply                                             eliminated.                                    area because of
                          security                                                                                              the current
                          fence, 360°                                                                                            ground-water plume
                          slurry wall                                                                                            boundaries.
                                                                                                                                Effectiveness must
                                                                                                                                be monitored.

                                                                                                                                    (continued)

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                                                                       TABLE  8-3.    (continued)
00
 I
Cost (51,000)
Present
Alternative Capital Worth
1 I . Management of
mlgrat ion
1. No action 10






2. Pumping con- 1,750 2,120
laminated
ground water,
pret reat ing
and discharging
to local POTW,
capping and
grading
3. Pumping 1 ,830 2,420
contaminated
ground water,
pret reat Ing and
discttarg ing to
local surface
water body, cap-
ping and grading
4. In situ 1,950 3,850
biological and
chemical treat-
ment of contami-
nated soils and
ground water.
capping and
grading.
temporary
alternative water
supply
Public Health
Concerns


Unacceptable exposure to
TCE through continued
air, and ground water.
Could potentially cause
(direct contact
with humans, unsecured
areas).
Assume no direct ..contact
(leas than 10 , to
10 cancer rink) .





to less than 10



Results In 10~* to 10~5
cancer risk.









Community
Environmental Technical Response
Concerns Concerns Concerns


Continued migration — Unacceptable.
to the ground water
and surface water.
Could threaten
species.


Controls existing Proven Acceptable
contaminant plume technology. negotiated
In ground water. agreement.





water release technology. acceptable.
through capping
and grading
col lee ted ground
water .

Treats contamln- Difficult Unacceptable.
ated soils and to design
ground water. May delivery
be concern over system and
introducing addi- to monitor
tlonal chemicals effect Iveness
and organisms to in situ
the environment treatment-
through in situ
treatment
methodologies.










Mua
mi
d
ra<
4
r
SI
w
m-
o
NPD!
ri
bi
Si
I


In i
ti
fi
M.
c«
ri





Must determine and
  meet  local POTW
  discharge require-
  ments and Federal
  403 pretreatment
  regulatIons.
  Should be combined
  with  source control
    asures 1-2, 1.3,
  or 1.4.

NPDES Permit may be
   equired.  Should
  be combined with
  source control
  measures 1.2,
  1.3,  or 1.4.
                                                                                                                                          situ treatment
                                                                                                                                         technology not
                                                                                                                                         fully developed.
                                                                                                                                         May have to
                                                                                                                                         contend with UlC
                                                                                                                                          equirements.

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                                  CHAPTER 9

                       FEASIBILITY STUDY REPORT FORMAT
     This chapter presents and discusses the recommended format for CERCLA
feasibility study reports.  This consistent format ensures that all major
issues are addressed, makes it possible to compare feasibility studies for
different sites, and ensures that decisions are adequately documented.  The
result will be more rapid and efficient selection and implementation of the
most cost-effective remedies.  Table 9-1 shows the recommended format, with
its numbering system, as it would appear in the report.
9.1  EXECUTIVE SUMMARY
     The executive summary is a brief overview of the study and the analyses
underlying the recommended remedial action.  Information about the site and
the feasibility analysis is summarized so that the reader can review the
findings in a logical order.

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

     Discussions under each of these headings briefly convey important
characteristics, criteria, and findings.  Tables and figures are used where
possible to summarize information clearly and concisely.  The Executive
Summary should be 5 to 10 pages long with at most one or two tables or
figures.
9.2  INTRODUCTION
     As the introduction to the report, chapter 1 briefly characterizes the
site in terms relevant to the analysis of remedial action strategies.  The
introduction has three main topics:  (1) site background information, (2)
the nature and extent of contamination problems at the site, and (3) reme-
dial objectives.
                                    9-1

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                 TABLE 9-1.  FEASIBILITY STUDY REPORT FORMAT
Executive Summmary

1.0  Introduction

     1.1  Site background information
     1.2  Nature and extent of problems
     1.3  Objectives of remedial action

2.0  Screening of Remedial Action Technologies

     2.1  Technical criteria
     2.2  Remedial action alternatives developed
     2.3  Environmental and public health criteria
     2.4  Other screening criteria
     2.5  Cost criteria

3.0  Remedial Action Alternatives

     3.1  Alternative 1 (No Action)
     3.2  Alternative 2
     3.N  Alternative N

4.0  Analysis of Remedial Action Alternatives

     4.1  Noncost criteria analysis

          4.1.1  Technical feasibility
          4.1.2  Environmental evaluation
          4.1.3  Institutional requirements
          4.1.4  Public health evaluation

     4.2  Cost analysis

5.0  Summary of Alternatives

6.0  Recommended Remedial Action  (optional)

7.0  Responsiveness Summary  (in final version  only)

References

Appendices
                                     9-2

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      9.2.1   Site Background  Information


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

      •  Facility location, size, existing structures

      •  The  time period of waste-related activities

      •  Historical descriptions  of:

        - Facility type
        - Activities and  operations
        - Types of wastes
        - Condition  of wastes (originally and  at  present)
        - Incidents  that  occurred  (fire, explosion, ground-water
          contamination,  etc.)
        - Site investigations, response actions,  and  enforcement  activities

      •  Physiography

      •  Hydrogeology

      •  Other items

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

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


      9.2.2  Nature and Extent of Problems
     The nature and extent of the problems at the site should be described
in a way that establishes a framework for determining remedial objectives
and defines criteria for selecting remedial action alternatives.  This
section of the introduction focuses on existing and potential on-site and
off-site health and environmental effects.  It should include the following:

     •  Type, physical state, and quantity of wastes or hazardous substances
        on the site

     •  Special waste considerations (e.g., explosive or radioactive
        materials)

                                    9-3

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     •  Present condition of materials and structures (including drums,
        tanks,  landfills, etc.)

     •  Changes in site conditions (e.g.,  filling in a waste pit or lagoon,
        applying cover material  to buried  or partly buried drums)

     •  Effects of contaminants  from the site (as indicated by monitoring
        and geotechnical studies):

        - Types of contaminant releases (e.g.,  leachate,  runoff)
        - Affected media, movements of contaminants
        - Resources,  population, or environments threatened by contaminant
          movement
        - Human exposure

     •  Near-future effects of site conditions and contaminant migration

     •  Actions previously taken to mitigate problems and the results of
        these actions.
     9.2.3  Objectives of Remedial Action


     The final section of the introduction identifies the objectives of
remedial actions at the site.  Objectives should be identified in terms of
general goals (e.g., minimize off-site contaminant migration) as well as
specific goals (e.g., prevent waste from coming into contact with ground
water, raise site above 100-year floodplain, etc.).  This section should
also describe or tabulate environmental criteria and standards that form the
basis for remedial actions.
9.3  SCREENING OF REMEDIAL ACTION TECHNOLOGIES


     Chapter 2 of the report summarizes the screening process used to iden-
tify the most appropriate remedial action alternatives to undergo detailed
analysis.  Technical discussions should address the technologies initially
considered and identify the most promising technologies, the methods used to
develop remedial action alternatives from those technologies, and the alter-
natives developed.  It should also discuss the problems associated with
applicable technologies.  The chapter should also discuss the following four
categories of screening criteria:

     •  Environmental and public health

     •  Other site-related considerations such as public welfare, site
        access, etc.

     •  Cost.


                                    9-4

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The discussion should explain the reasons  for  eliminating  certain  alterna-
tives.

     The final section of the chapter  identifies  the most  promising  alterna-
tives.  Detailed descriptions and preliminary  conceptual designs for these
alternatives should be placed in chapter 3.


9.4  REMEDIAL ACTION ALTERNATIVES
     Chapter 3 of the report  summarizes  the remedial action  alternatives
developed from the applicable technologies identified  in the initial
screening.

     The description details the cost and noncost features of each remedial
action alternative.  Specific elements in these discussions  should include
the following:

     •  The intent of the remedial alternative, such as source control or
        mitigation of contaminant migration or effects of migration, etc.

     •  Key features of the alternative

        - Description of the technologies making up the alternative

     •  Control, storage, treatment, and/or disposal requirements

     •  Phasing of work, if necessary

     •  Special engineering, safety, environmental, public health, public
        welfare, or other considerations that affect the feasibility of each
        alternative

     •  Operation, maintenance, and monitoring requirements  (short and long
        term)

     •  Aspects of the site problem that the alternative will or will
        not control.

If the alternative involves a series of separate activities, each activity
should be identified and briefly described.  It should also  be noted whether
the particular strategy provides a single-medium or multimedia solution,
where such a solution is applicable.  A site layout diagram, process flow
diagram,  and the like should be included to illustrate each  alternative.

     A summary of the remedial action alternatives may be included in matrix
form.   Such a summary would include a list of the strategies, key features
of each concept, the problems to be controlled, and the expected result of
each alternative.
                                    9-5

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9.5  ANALYSIS OF REMEDIAL ACTION ALTERNATIVES
     Chapter 4 of the feasibility study report presents detailed analyses of
the remedial action alternatives.  The majority of the analyses and sup-
porting data will be presented in Appendices to the FS report.  This chapter
presents an overview of these analyses and is divided into two major sec-
tions:  noncost criteria analyses and cost analysis.
     9.5.1  Noncost Criteria Analysis


     The noncost criteria section addresses considerations of technical
feasibility, environmental protection, public health, and institutional
issues.  Each of these analyses is presented in a separate subsection.

     For each noncost criteria category, the report summarizes the analysis
performed, identifying and briefly discussing the criteria and methods used.
Where possible, the results of the specific analysis for each of the alter-
natives should be summarized using tables and figures to consolidate com-
parative information.  The technical discussion should concentrate on the
feasibility and implementability of each alternative.  The environmental
discussion should assess each alternative's positive and negative impacts on
the environment.  The institutional discussion should discuss regulatory and
community relations issues for each alternative, and their impacts on the
choice of an alternative.

     The final section of this chapter reviews the public health aspects of
each remedial alternative, examining the relevant public health goals and
public health aspects of each remedial alternative, including relevant and
applicable standards, criteria, advisories, and guidance considered, and an
explanation of adjustments made to standards, criteria, etc.  Alternatives
failing to meet these goals are noted, with brief explanations of these
failures and of the anticipated effects of the level of control in question.

     At a minimum, the noncost analysis of each alternative  should include a
discussion of the subject areas listed in section 8.3.

     9.5.2  Cost Analysis


     The cost analysis section should summarize the estimated costs  of each
alternative, review the main cost items, and discuss important considera-
tions  in the cost analysis.  Cost analysis topics should include the
following:

        Costing methodology
        Capital costs
        Operation and maintenance costs
        Present worth analysis
        Phasing of the work and its  impact on cost  (if  required)

                                     9-6

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     •  Distribution of costs over time (stream of costs)
     •  Results of the sensitivity analyses.

For ease of presentation and to permit direct comparison of the various
alternatives, much of the cost data should be presented in tables and
figures.
9.6  SUMMARY OF ALTERNATIVES
     Chapter 5 of the feasibility study report summarizes the remedial
alternatives and presents the results of the analysis using appropriate
summary tables and figures.  The alternatives are compared, with clear
statements of their advantages and disadvantages.  At the end of this
comparative analysis, the recommended alternative is identified, and the
reasons for the selection are given.
9.7  RECOMMENDED REMEDIAL ACTION


     Chapter 6 of the report, a detailed description of the recommended
remedial action, is prepared to meet certain specific regional requirements.
This is based on regional discretion.  In some cases, the description of the
recommended action will not be prepared at this stage, but after approval of
the Record of Decision (ROD).  Generally, for enforcement-lead sites, the
Regional Administrator may elect not to include a recommended alternative at
this stage.

     The recommended remedial action chapter would include the following:

     •  A review of what the remedial action will and will not accomplish

     •  Special engineering considerations and special studies needed during
        final design

     •  Operation,  maintenance,  and monitoring requirements

     •  Off-site disposal needs and transportation plans

     •  Temporary storage requirements

     •  Appropriate treatment and disposal technologies

     •  Brief descriptions of the environmental and public health problems
        that may be encountered  during implementation

     •  Means of mitigating the  associated environmental and public health
        problems (and their costs).
                                    9-7

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9.8  RESPONSIVENESS SUMMARY
     The responsiveness summary is included only in the final version of a
feasibility study report, after public comment on the study.  This chapter
summarizes the public comment on the draft feasibility study report, includ-
ing views expressed by potentially responsible parties, whether or not
labelled as "comments," and actions taken regarding these comments.
9.9  REFERENCES
     The references section contains the complete bibliographic citation for
each information source used and cited in the main text of the report.
References to sources cited in an appendix should appear in a separate list
with that appendix.


9.10  APPENDICES
     The text of the feasibility study report summarizes the site infor-
mation evaluated and the analysis conducted in selecting the most promising
remedial action alternative.  So that this summary presents the major fea-
tures of the analysis and decision process clearly and logically, detailed
discussions, diagrams, and supporting analyses may be presented as appen-
dices.

     A feasibility study report may include the following appendices:

     •  Appendix A:  Supporting Documentation for the Screening Process

     •  Appendix B:  Supporting Documentation for Cost Analysis of Best
        Alternatives

     •  Appendix C:  Technical Feasibility Analysis

     •  Appendix D:  Public Health Evaluation

     •  Appendix E:  Environmental Evaluation

     •  Appendix F:  Exposure Analysis

     •  Appendix G:  Institutional Analysis.

Depending on the features and problems of a site, and the complexity of the
accompanying analysis, some of these appendices may be unnecessary, or
additional appendices may be needed.
                                    9-8

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                                  GLOSSARY
AASHTO - American Association of State Highway Transportation Officials

Acceptable engineering practices - technologies or practices which are
     technically sound, reliable, and applicable with respect to a
     particular site problem.

ACL - Alternative Concentration Limit

ASTM - American Society for Testing and Materials.

Budget estimates - estimates of capital operation and maintenance or service
     costs provided by a vendor.

CAA - Clean Air Act.

CERCLA - Comprehensive Environmental Response, Compensation, and Liability
     Act of 1980.  Also known as Superfund.

Cleanup - the elimination, reduction, or containment of pollutants from a
     site by a selected remedial action.

Community impacts - any change in the normal way of life, directly or
     indirectly attributable to the selected remedial action, including
     temporary or permanent relocation, initiation of health monitoring
     programs, formation of citizens' groups to review remedial alter-
     natives, etc.

CRP - Community Relations Plan.

CWA - Clean Water Act.

Durability - the projected length of time that a designed level of
     effectiveness can be maintained.  It is also measured in terms of the
     operation and maintenance requirements (parameter of reliability).

EDD - Enforcement Decision Document; a public document that is similar in
     purpose to a ROD.  It documents the selection of a remedy and is used
     in settlement or litigation with potential responsible parties.

Environmental carrying capacity - the alternate uses a site is capable of
     supporting, especially after remedial actions.

FEMA - Federal Emergency Management Agency.

                                     1

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General response action - a response action category consisting of groupings
     of related response technologies that may be used for a specific site
     problem (e.g., surface water controls, air pollution controls).

HHS - Department of Health and Human Services.

HWM - hazardous waste management.

Implementability - a measure of successful prior installation of a remedial
     technology either on similar sites or on a research and development
     basis.  Includes well understood installation and operational practices
     requiring minimal monitoring.

Institutional factors - analytical factors associated with Federal, State,
     and local regulations, guidance, and advisories concerning public
     health and welfare, environmental considerations, community relations,
     and other social, political, and economic concerns.

Isolation - a situation in which the transport of pollutants from a site to
     the surrounding environment has been stopped or slowed by the selected
     remedial action, but no pollutants have actually been removed.

MCL - Maximum Concentration Limit, established under to Safe Drinking Water
     Act.

MPRSA - Marine Protection Resource and Sanctuaries Act.

NAAQS - National Ambient Air Quality Standards.

NCP - National Oil and Hazardous Substances Contingency Plan.

NDD - Negotiated Decision Document; a confidential enforcement document
     containing a discussion of alternatives identified in the draft RI/FS,
     indicates preferred alternatives; serves as basis for negotiation with
     potential responsible parties.

NEPA - National Environmental Policy Act.

NESHAPs - National Emission Standards for Hazardous Air Pollutants.

NIOSH - National Institute for Occupational Safety and Health.

NOEL (No-Observed Effect Level) - the maximum experimental dose of a
     substance at which no toxic effect was observed.

NPDES - National Pollutant Discharge Elimination System.

NSPS - New Source Performance Standards.

O&M - operation and maintenance.

OSHA - Occupational Safety and Health Administration.

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 Operable unit - a discrete part of a  remedial action  that  can  function  inde-
     pendently as a unit and contributes to preventing or  minimizing  a
     release or threat of release.

 Physiography - general description of a site; for example  geographic
     position, vegetative cover, and  topography.

 Present worth - a summary of costs to be incurred over a period of time
     discounted to the present.

 PSD - Prevention of Significant Deterioration (air permit).

 RCRA - Resource Conservation and Recovery Act.

 Relevant or applicable standards - established Federal or  State procedural
     requirements or limit values (such as MCLs) pertaining specifically to
     chemicals, environmental  impacts, or technology  operations conducted or
     anticipated at a site.

 Reliability - a measure of the effectiveness and durability of a technology.

 Remedial Action Alternative -  a remedial technology or a combination  of
     remedial action technologies which will prevent  or mitigate site-
     specific contamination problems.

 Remedial Action Technology ("Technology") - a general category encompassing
     a number of remedial action technology options that address a similar
     problem (e.g., capping, containment barriers, chemical treatment).

 Remedial Action Technology Option ("Technology Option") -  a specific
     process, system, or action that may be used to cleanup or mitigate
     contaminant problems (e.g., slurry wall, clay cap, activated sludge
     treatment).

 REMFIT contractor - Remedial Planning and Field Investigation Teams contract
     to the U.S. EPA.

 Risk Level - Cancer risk level provides an estimate of the additional
     incidence of cancer that may be expected in a population exposed to a
     given contaminant.  A risk of 10~ , for example, indicates a probabili-
     ty of one additionnal case of cancer for every 100,000 people exposed.
     A risk of 10   indicates one additional case of cancer for every one
     million people exposed.  A risk of 10   would be one case in 10 million
     people exposed.

 RMCL - Recommended Maximum Concentration Limit,  developed under Safe
     Drinking Water Act.

 ROD - Record of Decision,  documents selection of cost-effective
     Fund-financed remedy.

RPM - Remedial Project  Manager.

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S&E Manual - procedural manual entitled "Methodology for Screening and
     Evaluation of Remedial Responses."

SDWA - Safe Drinking Water Act.

Sensitivity analysis - a test of a procedure to determine the overall
     changes that result from any small changes in one or more procedural
     elements.

Significant adverse impact - a public health or environmental effect that
     cannot be mitigated or ameliorated.

SIP - State Implementation Plan under the Clean Air Act.

Site - a landfill, surface impoundment, storage facility, or any other site
     or facility of any kind, at which a hazardous substance is present as a
     result of a release of such hazardous substance from a facility as
     defined under CERCLA.

SNARL - Suggested No Adverse Response Level

Social costs - perceived negative impacts resulting from a remedial action,
     including impacts manifested in psychological, sociological, political,
     legal, and organizational changes.

Technology status - the state-of-the-art, relative to application to
     uncontrolled hazardous waste sites, of remedial alternatives; described
     as proven, widely used, or experimental.

TSD - treatment, storage, or disposal facility.

UCR (Unit Carcinogenic Risk) - probability that cancer will be produced for
     each unit of dose.

UIC - Underground Injection Control Programs.

USDW - Underground source of drinking water.

Unit operation - the basic physical operations of chemical and civil
     engineering that may be applied as remedial actions, for example
     capping, groundwater pumping, biological treatment, containment
     barrier; a technology.

User - any person involved with conducting a remedial action feasibility
     study; the user of this document.

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 7.  Casarett, L.J. and J. Doull, Eds., 1975.  Toxicology: The Basic Science
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 9.  Congressional Research Service.  March 1980.   "A Catalog of Resource
     Losses from Surface Water,  Groundwater & Atmospheric Contamination".

10.  Cummings and Mattingly, EPA, July 1982.  Assessment and Predictions  of
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11.  Department of Commerce.  August 1977.  "Selected Annotated Bibliography
     of Economic Values of Fish and Wildlife and their Habitats."  Prepared
     for Office of Water Research and Technology,  Washington, D.C.

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12.  Department of Ecology, Washington State.  1980.  Guideline for Evaluating
     Freshwater Resources Damages.

13.  Department of Energy.  November 1982.  Draft EIS, "Remedial Actions at
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14.  Department of Energy.  February 1983.  Draft EIS, "Remedial Actions at
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15.  Department of Fishery, Washington State.  1979.  Marine Water Quality
     Compendium of Washington State.

16.  Department of Interior U.S.  Fish and Wildlife Service, Division of
     Ecological Services.  September 1980.  Ecological Services Manual 101.
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17.  Environmental Law Institute, Remedial Action Cost Compendium.  In Print.
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18.  Environmental Policy Institute.  April 1976.  "Oil Study of Pollution
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19.  Federal Register (40 CFR 300), Volume 47, No. 137, July 16, 1982.
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20.  Geraghty and Miller, Inc. and Booz, Allen and Hamilton, Inc. 1982.
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21.  Halter, Faoth., Joel Thomas. 1981.  Ecological Law Quarterly. 10:5.
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22.  Heer, John and D.J. Hajerty. 1977.  Environmental Assessment and
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23.  ICF Inc.  1980.  Chemical Substances Designation.  U.S. EPA, Office of
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24.  JRB Associates.  1982.  Remedial Action at Waste Disposal Sites.  U.S.
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26.  Kufs, C. et al.  1983.  Procedures and Techniques for Controlling the
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     Division.  Municipal Environmental Research Laboratory, Cincinnati,  Ohio.

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 27.   Kuhnhold, W.W.  1979.   "Impact  of  Argo  Merchant  Oil  Spill  on Macrobenthic
      and  Pelagic  Organisms."  Proceedings  from  a Conference  on Assessment of
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 28.   McGraw-Hill  Information  Systems Company, Dodge  Guide, New York,  New York,
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 29.   Mitre,  September  1981.   "Working  Paper."

 30.   Office  of Coastal Zone Management,  NOAA.   1980.  Marine Resource Damage
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 31.   Pennsylvania Power  and Light.  January 1982.  Laboratory  and Aquatic
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 32.   Radian  Corporation.   1983.  In Print.   Methodology  Manual  - Evaluating
      Cost Effectiveness  of Remedial Actions  at  Uncontrolled Hazardous Waste
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      Waste Research Division, Municipal  Environmental Research  Laboratory,
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 33.   Raniere, L.  1982.  Field Guide for Scientific  Support Activities
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 34.   Ricklefs, R.E., 1973.  Ecology.  Chiron Press, Portland, OR.

 35.   Robert  Snow Means Company, Inc., Building  Construction Cost  Data 1983,
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 37.   Spooner, P.A. et al.  In Print.  Slurry Trench Construction  for  Pollution
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 38.   State of Alaska.  1982.  Alaska Oil Spill Status Booklet.

 39.  Tetratech, undated,  Water Quality Aasessment: A Screening Procedure for
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40.  Toxic Waste  Assessment Group,  1981.  Alternatives to Land Disposal of
     Hazardous Wastes.   California Governors' Office of Appropriate
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41.  Tusa, W.K. and B.D. Gillen.  Fred. Hart, Inc., 1982.  Conference on
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42.  U.S. EPA.  In Press.  Community Relations in Superfund:  A Handbook.

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45.  U.S. EPA.  December 1981.  Draft Guidance Manual for Superfund
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46.  U.S. EPA.  Guide to the Disposal of Chemically Stabilized and
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47.  U.S. EPA.  1982.  Handbook:  Remedial Action at Waste Disposal Sites.
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55.  U.S. EPA.  1984b.  Guidance for the Preparation of Exposure Assessments.
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56.  U.S. EPA.  1984c.  Revised Interim Guidelines for the Health  Assessment
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57.  U.S. EPA.  1984d.  Interim Guidelines for Mutagenicity Risk Assessment.
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                        APPENDIX A


                   MODEL STATEMENT OF WORK
              FOR CONDUCTING FEASIBILITY STUDIES

PURPOSE

    The purpose of this feasibility study is to develop
and evaluate remedial alternatives for  [specific site].
The Engineer will furnish the necessary personnel,
materials, and services necessary to prepare the remedial
action feasibility study, except as otherwise specified.

SCOPE

    The feasibility study consists of eight tasks:

    Task 8  - Description of Proposed Response
    Task 9  - Preliminary Remedial Technologies
    Task 10 - Development of Alternatives
    Task 11 - Initial Screening of Alternatives
    Task 12 - Evaluation of the Alternatives
    Task 13 - Preliminary Report
    Task 14 - Final Report
    Task 15 - Additional Requirements.

    A work plan that includes a detailed technical
approach, a budget, personnel requirements, and schedules
will be submitted for the proposed feasibility study.

TASK 8 - DESCRIPTION OF CURRENT SITUATION

    Information on the site background, the nature  and
extent of the problem, and previous response activities
presented in Task 1 of the remedial investigation may  be
incorporated by reference.  Any changes to the original
project scope described in the Task 1 description should
be discussed and justified based on results of the
remedial investigation.

    Following this summary of the current situation, a
site-specific statement of purpose for  the response, based
on the results of the remedial investigation, should be
presented.  The statement of purpose should identify the
actual or potential exposure pathways that should be
addressed by remedial alternatives.
                        A-l

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TASK 9 - PRELIMINARY REMEDIAL TECHNOLOGIES

    Based on the site-specific problems and statement of
purpose identified in Task 8, develop a master list of
potentially feasible technologies.   These technologies
will include both on-site and off-site remedies,  depending
on site problems.  The master list  will be screened based
on site conditions, waste characteristics, and technical
requirements, to eliminate or modify those technologies
that may prove extremely difficult  to implement,  will
require unreasonable time periods,  or will rely on
insufficiently developed technology.  [The results of this
task may be requested as a separate memorandum (Remedial
Options Negotiation Document) by the State or EPA.]

TASK 10 - DEVELOPMENT OF ALTERNATIVES

    Based on the results of the remedial investigation and
consideration of preliminary remedial technologies
(Task 9), develop a limited number  of alternatives for
source control or off-site remedial actions, or both, on
the basis of objectives established for the response.

    a.   Establishment of Remedial  Response Objectives

         Establish site-specific objectives for the
         response.  These objectives will be based on
         public health and environmental concerns, the
         description of the current situation (from
         Task 1), information gathered during the remedial
         investigation, section 300.68 of the National
         Contingency Plan  (NCP), EPA's interim guidance,
         and the requirements of any other applicable EPA,
         Federal, and State environmental standards,
         guidance, and advisories as defined under EPA's
         CERCLA compliance policy.   Objectives for source
         control .measures should be developed to prevent
         or significantly minimize  migration of
         contamination from the site.  Objectives for
         management of migration measures should prevent
         or minimize impacts of contamination that has
         migrated from the site.  Preliminary cleanup
         objectives will be developed in consultation with
         EPA and the State.

    b.   Identification of Remedial Alternatives

         Develop alternatives  to incorporate remedial
         technologies  (from Task 9), response objectives,
                          A-2

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         and other appropriate considerations into a
         comprehensive, site-specific approach.
         Alternatives developed should include the
         following (as appropriate):

                   Alternatives for off-site treatment or
                   disposal, as appropriate

                   Alternatives which attain applicable
                   and/or relevant Federal public health
                   or environmental standards

                   Alternatives which exceed applicable
                   and/or relevant public health or
                   environmental standards

                   Alternatives which do not attain
                   applicable and/or relevant public
                   health or environmental standards but
                   will reduce the likelihood of present
                   or future threat from the hazardous
                   substances.  This must include an
                   alternative which closely approaches
                   the level of protection provided by the
                   applicable or relevant standards

                   No action.

         There may be overlap among the alternatives
         developed.  Further, alternatives outside of
         these categories may also be developed, such as
         non-cleanup alternative (e.g., alternative water
         supply, relocation).  The alternatives shall be
         developed in close consultation with EPA and the
         State.  Document the rationale for excluding any
         technologies identified in Task 9 in the
         development of alternatives.

TASK 11 - INITIAL SCREENING OF ALTERNATIVES

    The alternatives developed in Task 10 will be screened
by the Engineer to eliminate those that are clearly
infeasible or inappropriate, prior to undertaking detailed
evaluations of the remaining alternatives.
                          A-3

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Considerations to be Used in Initial Screening

    Three broad considerations must be used as a basis for
    the initial screening:  cost, public health, and the
    environment.  More specifically, the following factors
    must be considered:

    1.   Environmental Protection.  Only those
         alternatives that satisfy the response objectives
         and contribute substantially to the protection of
         public health, welfare, or the environment will
         be considered further.  Source control
         alternatives will achieve adequate control of
         source materials.  Management of migration
         alternatives will minimize or mitigate the threat
         of harm to public health, welfare, or the
         environment.

    2.   Environmental Effects.  Alternatives posing
         significant adverse environmental effects will be
         excluded.

    3.   Technical Feasibility.  Technologies that may
         prove extremely difficult to implement, will not
         achieve the remedial objectives in a reasonable
         time period, or will rely upon unproven
         technology should be modified or eliminated.

    4.   Cost.  An alternative whose cost far exceeds that
         of other alternatives will usually be eliminated
         unless other significant benefits may also be
         realized.  Total costs will  include the cost of
         implementing the alternatives and the cost of
         operation and maintenance.

         The cost screening will be conducted only after
         the environmental and public health screenings
         have been performed.

TASK  12 - EVALUATION OF THE ALTERNATIVES

    Evaluate the cost-effectiveness of alternative
remedies that pass through the  initial screening  in
Task  11.  Alternative  evaluation will be preceded by
detailed development of the remaining alternatives.

    a.   Technical Analysis

         The Technical Analysis  will, as a minimum:

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1.   Describe appropriate treatment, storage, and
     disposal technologies.

2.   Discuss how the alternative does (or does
     not) comply with specific requirements of
     other environmental programs.  When an
     alternative does not comply, discuss how the
     alternative prevents or minimizes the
     migration of wastes and public health or
     environmental impacts and describe special
     design needs that could be implemented to
     achieve compliance.

3.   Outline operation, maintenance, and
     monitoring requirements of the remedy.

4.   Identify and review potential off-site
     facilities to ensure compliance with
     applicable RCRA and other EPA environmental
     program requirements, both current and
     proposed.  Potential disposal facilities
     should be evaluated to determine whether
     off-site management of site wastes could
     result in a potential for a future release
     from the disposal facility.

5.   Identify temporary storage requirements,
     off-site disposal needs, and transportation
     plans.

6.   Describe whether the alternative results in
     permanent treatment or destruction of the
     wastes, and, if not, the potential for
     future release to the environment.

7.   Outline safety requirements for remedial
     implementation (including both on-site and
     off-site health and safety considerations).

8.   Describe how the alternative could be phased
     into individual operable units.  The
     description should include a discussion of
     how various operable units of the total
     remedy could be implemented individually or
     in groups, resulting in a significant
     improvement to the environment or savings in
     cost.
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     9.   Describe how the alternative could be
          segmented into areas to allow implementation
          in differing phases.

     10.  Describe special engineering requirements of
          the remedy or site preparation
          considerations.

b.   Environmental Analysis

     Perform an Environmental Assessment (EA)  for each
     alternative.  The EA should focus on the site
     problems and pathways of contamination actually
     addressed by each alternative.   The EA for each
     alternative will include, at a  minimum, an
     evaluation of beneficial effects of the response,
     adverse effects of the response, and an analysis"
     of measures to mitigate adverse effects.   The
     no-action alternative will be fully evaluated to
     describe the current site situation and
     anticipated environmental conditions if no
     actions are taken.  The no-action alternative
     will serve as the baseline for  the analysis.

c.   Public Health Analysis

     Each alternative will be assessed in terms of the
     extent to which it mitigates long-term exposure
     to any residual contamination and protects public
     health both during and after completion of the
     remedial action.  The assessment will describe
     the levels and characterizations of contaminants
     on-site, potential exposure routes, and
     potentially affected population.  The effect of
     "no action" should be described in terms of
     short-term effects (e.g., lagoon failure),
     long-term exposure to hazardous substances, and
     resulting public health impacts.  Each remedial
     alternative will be evaluated to determine the
     level of exposure to contaminants and the
     reduction over time.  The relative reduction in
     public health impacts for each alternative will
     be compared to the no-action level.  For
     management of migration measures, the relative
     reduction in impact will be determined by
     comparing residual levels of each alternative
     with existing criteria, standards, or guidelines
     acceptable to EPA.  For source control measures
     or when criteria, standards, or guidelines are


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     not available, the comparison should be based on
     the relative effectiveness of technologies.   The
     no-action alternative will serve as the baseline
     for the analysis.

d.   Institutional Analysis

     Each alternative will be evaluated based on
     relevant institutional needs.  Specifically,
     regulatory requirements, permits, community
     relations, and participating agency coordination
     will be assessed.

e.   Cost Analysis

     Evaluate the cost of each feasible remedial
     action alternative (and.for each phase or segment
     of the alternative).  The cost will be presented
     as a present worth cost and will include the
     total cost of implementing the alternative and
     the annual operating and maintenance costs.   Both
     monetary costs and associated non-monetary costs
     will be included.  A distribution of costs over
     time will be provided.

f.   Evaluation of Cost-Effective Alternatives

     Alternatives will be compared using technical,
     environmental, and economic criteria.   At a
     minimum, the following areas will be used to
     compare alternatives:

     1.   Present Worth of Total Costs.  The net
          present value of capital and operating and
          maintenance costs also must be presented.

     2.   Health Information.  For the no-action
          alternative, EPA prefers a quantitative
          statement including a range estimate of
          maximum individual risks.  Where
          quantification is not possible, a
          qualitative analysis may suffice.  For
          source control options, a quantitative risk
          assessment is not required.  For management
          of migration measures, present a
          quantitative risk assessment including a
          range estimate of maximum individual risks.
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Environmental Effects.  Only the most
important effects or impacts should be
summarized.  Reference can be made to
supplemental information arrayed in a
separate table, if necessary.

Technical Aspects of the Remedial
Alternatives.  The technical aspects of each
remedial alternative relative to the others
should be clearly delineated.  Such
information generally will be based on the
professional opinion of the Engineer
regarding the site and the technologies
comprising the remedial alternative.

Information on the Extent to Which Remedial
Alternatives Meet the Technical Requirements
and Environmental Standards of Applicable
Environmental Regulations.  This information
should be arrayed so that differences in how
remedial alternatives satisfy such standards
are readily apparent.  The general types of
standards that may be applicable at the site
include:

a.   RCRA design and operating standards; and

b.   Drinking water standards and criteria.

Information on Community Effects.  The type
of information that should be provided is
the extent to which implementation of a
remedial alternative disrupts the community
(e.g., traffic, temporary health risks, and
relocation).

Other Factors.  This category of information
would include such things as institutional
factors that may inhibit implementing a
remedial alternative and any other
site-specific factors identified in the
course of the detailed analysis that may
influence which alternative  is eventually
selected.
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TASK 13 - PRELIMINARY REPORT

    Prepare a preliminary report presenting the results of
Tasks 8 through 13.  Submit  [specify number and
distribution] copies of the preliminary report to EPA and
the State [specify recipients].  (Note:  EPA and the State
will review and select a remedial alternative.)

TASK 14 - FINAL REPORT

    Prepare a final report for submission to EPA and the
State'.  The report will include the results of Tasks 8
through 13,  and should include any supplemental
information in appendices.  This report will include a
responsiveness summary on public comments received.
Submit [specify number and distribution of copies] to EPA
and the State [specify recipients].

TASK 15 - ADDITIONAL REQUIREMENTS

    [Specified based on site-specific issues.]
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                               APPENDIX B
PROCEDURES FOR PLANNING AND IMPLEMENTING  OFF-SITE RESPONSE ACTIONS
             UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                         WASHINGTON, O.C. Z04«0
                                                          OFFICE Ct
                                                 SOLIDWASTE AND EVEP11-
MEMORANDUM
SUBJECT:  Procedures for Planning and  Implementing  Off-site
          Resp«n«e Act-i'ona
           /<£**?//' '/ '//>-<*<-•
FROM:     J/ack \»: MtfGra*/
          Acting Assistant Administrator
         */
TO:       Regional Administrators
          Regions I-X

     This memorandum addresses procedures  that oust  be  observed
when a  response . action involving off-site  storage,  treatment  or
disposal of hazardous substances is  selected  under  the  Compre-
hensive Environmental Response, Compensation, and Liability Act
of  1980 (CERCLA), and the Resource Conservation  and  Recovery  Act
(RCRA).  It prohibits use of a RCRA  facility  for off-site  manage-
ment of Superfund hazardous substances  if  it  has significant
RCRA violations' or other environmental conditions  that  affect
the satisfactory operation of the facility.   It  also addresses
requirements for analyzing and selecting  response actions  that
Involve permanent methods of managing  hazardous  substances.

     In November of 1984, amendments to the Resource Conservation
and Recovery Act were enacted.  These  amendments impose  new
requirements for the safe management of hazardous wastes.   In
the case of land disposal facilities,  the  amendments require
that certain types of units (new, replacement and lateral  exten-
sions)  be double lined by May 9, 1985.  The amendments  impose
technical requirements to ensure that  when land  disposal  facilities
are used they are used safely.

     EPA Intends to follow the direction  established by  Congress
In  the  RCRA amendments when undertaking on-site  response  actions
 1 A  significant violation  Includes  a  Class  I  violation  as  defined
  by the RCRA Enforcement  Response  Policy  (December  21,  1984).
  This  policy defines  a  Class  I  violation  as  a  violation  that
  results  In a  release or  a  serious  threat  of  releaae  of  hazardous
  waste into the  environment,  or involves  the  failure  to  assure
  that  ground water will be  protected,  that proper  closure and
  post  closure  activities  will be undertaken,  or  that  hazardous
  wastes will be  destined  for  and delivered to  RCRA  permitted  or
  interim  status  facilities.   The policy  containa  a  list  of
  examples  of violations which are  Class  I  violations.   Regions
  should recognize  that  violations  other  than  Class  I  violations
  may be significant  for purposes of  these  procedures,  depending
  on the situation  at  the  facility.
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and when response actions Involve off-site management of hazardous
substances.  This memorandum details how the Agency plans to
achieve these goals.

     Section I of this memorandum discusses background Issues.
Section II A discusses the need to consider treatment, recycling
and reuse before off-site land disposal is used.   Section II B
details procedures that must be followed in selecting any off-site
facility for management of hazardous substances.   This section
also discusses the criteria to be used in making  the selection.
For facilities in assessment monitoring, this part states that
conditions which lead to and result from being in assessment
monitoring may constitute conditions that render  the facility
unsuitable for disposal of hazardous substances.   Therefore,
when a facility is in assessment, the conditions  which lead to
the required assessment, and any monitoring data, must be evalu-
ated to determine if the facility poses such conditions.  If so,
the facility may not be used unless the owner or  operator commits
to correct the problems and the unit to be used for disposal
poses no problems.

     Section III discusses RCRA manifest requirements.  Section IV
discusses PCB disposal requirements.  Finally, Section V details
how this policy will be implemented.  Attachment  A is a chart
summarizing the policy on use of off-site RCRA facilities.  This
chart should be used in conjunction with the policy document, not
in lieu of 1t.

     These procedures are applicable to all response and enforce-
ment actions taken pursuant to CERCLA and section 7003 of RCRA.

     This memorandum replaces guidance entitled "Requirements for
Selecting an Off-Site Option in a Superfund Response Action",
dated January 28, 1983.  This policy is an interim one that the
Agency intends to publish as a notice in the Federal Register
in order to receive public comment on its provisions.  After
reviewing these comments EPA will determine whether revisions
are necessary.

     These revisions strengthen previous requirements in several
ways :

     * Coverage - This memorandum extends requirements  to
       enforcement actions under *106 of CERCLA and  J7003 of RCRA,
       and expands requirements for removal actions.

     0 Use of Treatment - These procedures  require  consideration
       of  treatment, recycling or reuse for all response and
                                  B-2

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       enforcement actions, to foster the use of more permanent
       solutions, and, in the case of remedial actions, where
       cost-effective.  The Agency is not certain whether
       sufficient capacity is available at this time to use
       treatment in all cases where it is feasible.  As more
       information on capacity becomes available, the Agency
       will re-examine requirements for treatment to determine
       whether they can be strengthened.  The previous procedures
       did not address use of treatment.

     ' Requirements for a treatment, storage or disposal facility
       Previous guidance required inspection within 12 months
       before contract award for storage, treatment or disposal.
       The revisions require Inspection within six months of
       actual storage, treatment or disposal.  It also stated
       that if a facility had deficlences that resulted In unsound
       treatment, storage or disposal practices it should not be
       used.  The guidance also required RCRA violations that
       adversely affected facility performance to be corrected
       prior to contract award.  Under the revisions, a facility
       that has significant RCRA violations or other environmental
       conditions that affect its satisfactory operation may not
       be used unless certain conditions are met.  First, there
       must be a compliance agreement in place to correct all
       deficiencies at the facility; second, the unit that is
       used must not cause or contribute to significant problems
       at the facility.  This provision recognizes that in some
       situations it is infeasible to complete correction of all
       violations prior to using a facility (for example, it may
       take several years before pumping and treating of xround-
       water is completed) and that there may be a unit at such
       a facility that is sound.

     * Land Disposal Facilities - The '984 RCRA amendments Impose
       new requirements on land dlspo  .i facilities.  When use
       of such facilities is contemplated, the policy requires that
       the facility meet these minimum technical requirements.

I. BACKGROUND

    Facilities that are not in compliance with RCRA requirements
may be unacceptable to use for treatment, storage ar disposal of
hazardous substances from response actions.  Facilities used for
management of substances In connection with response actions
should not pose a significant threat to public health, welfare or
the environment.

    CERCLA contains two references to off-site management of
hazardous substances.  First, CERCLA section 104(c) requires, as
a condition of Fund-financed remedial response, that the State
assure the availability of an acceptable facility in compliance
with the requirements of subtitle C of RCRA for any off-site
management of hazardous substances.  Second, where remedial
measures include off-site storage, treatment, destruction or
secure disposition, the statute also requires such measures to
be more cost-effective than other remedial measures, create new
disposal capacity In compliance with Subtitle C of RCRA or be
necessary to protect public health, welfare or the environment

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fro* a present or potential  risk which nay be created by further
exposure to substances.  Section 300.65 (b)(6) of the National
Contingency Plan (40 CFR 300) states that when off-site action  is
taken in connection with a removal action the facility used for
off-site management must be  In compliance with Subtitle C of
RCRA.  This memorandum establishes procedures for Implementing
these CERCLA and NCP provisions.

     These procedures apply  to all removal,  remedial, and enforce-
ment actions taken pursuant  to CERCLA and section 7003 of RCRA.
Any other parties undertaking cleanup under  other authorities
are urged to comply with these procedures.  In the case of
Superfund-financed removal actions or enforcement actions taken
as a removal action In response to an immediate and significant
threat, compliance with these procedures is  mandatory unless the
On-Seene Coordinator (OSC) determines that the exigencies of the
situation require off-site treatment, storage or disposal without
following the requirements.   This exception  may be used In cases
where the OSC believes that  the immediacy of the threat posed by
the substances makes it imperative to remove the substances and
there is Insufficient time to observe these  procedures without
endangering public health, welfare or the environment.  In such
cases, the OSC should consider, to the extent possible, temporary
solutions (e.g., interim storage) in order that the feasibility
of using treatment can be evaluated prior to a decision to use
land disposal.  Also, in such cases, the OSC must provide a
written explanation of his decision to the Regional Administrator.
This explanation should be provided within 60 days of taking
the action.  In Regions in which authority to make removal deci-
sions has not been fully delegated by the Regional Administrator,
the decisions discussed above must be made by the Regional official
that is delegated removal decision making authority.

II. PROCEDURES FOR SELECTING HAZARDOUS WASTE MANAGEMENT FACILITIES

     This section discusses in  detail the requirements Regions
must follow in assessing and selecting an off-site RCRA facility
for management of Superfund hazardous substances.  Part A requires
consideration of treatment, recycling or reuse for on-site and
off-site actions in order to foster the use of more  permanent
methods of managing hazardous substances.  These policies are
consistent with directions taken by Congress in  the  1984  amend-
ments  to the Resource Conservation and Recovery  Act.  Furthermore,
Part B of this section establishes procedures Regions must use
in  selecting an off-site RCRA facility for management of  hazardous
substances.  Where off-site  land disposal must be used,  this Part
requires that disposal  facilities be  in  compliance with  the  appli-
cable  technical requirements of  RCRA.

     A.  Treatment
       It  is  EPA's  policy  to pursue  response  actions  that  use
 treatment,  reuse or  recycling  over  land  disposal  to  the  greatest
                                 B-4

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extent practicable, consistent with CERCLA requirements for
cost-effective remedial actions.  EPA requires that such alterna-
tives be considered for all Fund-financed and private party
removal and remedial actions.  For Fund-financed removals or
enforced actions in response to iamediate and significant threats,
treatment, reuse or recycling must be considered, unless the OSC
determines that treatment, reuse or recycling methods are not
reasonably available considering the exigencies of the situation,
or they pose a significant environmental hazard.

     When developing remedial alternatives, treatment, reuse or
recycling must be considered.  Such alternatives should not be
screened out on the basis of cost alone.  Section 300.68(h)(l) of
the HCP allows rejection of alternatives during the screening
stage based on cost, only when the cost of the alternative far
exceeds the cost of others (e.g., by an order of magnitude) and
does not provide substantially greater public health and environ-
mental benefits.

     Detailed analysis of these alternatives should include
consideration 'of long-term effectiveness of treatment and compara-
tive long and short term coses of treatment as compared to other
remedial alternatives.  Finally, when recommending and selecting
the appropriate remedial action, treatment, reuse or recycling
may be found more protective of public health and the environment
than land disposal.  Such alternatives may be recommended as the
appropriate remedial action where the detailed analysis of
alternatives shows that the alternative is more cost-effective
than others in minimizing the* damage to public health, welfare
or the environment.  During the next six months, EPA will be
developing additional guidelines for evaluating the comparative
long-term costs of treatment and land disposal.

     At this time, the Agency does not know the current and
projected treatment capacity available, nor the needs or capacity
that will be required for Superfund actions in the future.  Over
the next several months, the Agency plans to undertake a study
of available treatment and interim storage capacity and needs.
Once completed, this analysis will provide information on treat-
ment facilities currently operating for Regions to use.  Additional
information on capacity will be provided at a later date through
a more comprehensive capacity survey being undertaken in support
of the implementation of the 1984 RCRA amendments.

     B. Requirements for selecting storage, treatment or disposal
        facilities

     Selection of an appropriate facility for off-site management
of hazardous substances requires that a judgment be made as
to the overall acceptability of the facility to receive the
substances and the acceptability of the unit that will receive
the hazardous substances.  In making this judgment the following
steps must be observed:

     1. The owner or operator of any hazardous waste management
facility under consideration for off-site storage, treatment or
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actions under CE1CLA or ••ctloo 7003 of RCRA must have an applic-
able ICIA permit or Interim status.2

     2. A RCRA compliance inspection must be performed at any
hssardous watte management facility before It can receive hazardous
substances from a response action.  This inspection must assess
whether there are any significant violations or other environmental
conditions that affect the satisfactory operation of the facility.
The RCRA compliance inspection must have taken place not more than
six months prior to the storage, treatment or disposal of the
hasardous substances from a response action.  If the inspection
has not taken place or is not scheduled, REM/FIT contractor
personnel may conduct the Inspection under the direction of the
Deputy Project Officer, working in cooperation with RCRA Regional
personnel.  If Regions use contractor personnel, the Region should
ensure that auch peraonnel are adequately trained to conduct
Inspections.  Further guidance on conducting Inspections when a
facility is being considered for management of hazardous substances
will be issued in the near future.  The FY 85 and FY 86 RCRA Imple-
mentation Plans establish compliance monitoring and enforcement
targets.  For FY 85 the guidsnce requires Comprehensive Ground-
Water Monitoring Evaluations (CGMEs) st one third of the ground
water monitoring facilities.  Top priorities for this type of
inspection are all facilities receiving wastes from Superfund
sites.

     In States with Phase I or II Interim authorization or final
authorization, the inspection should be conducted In accordance
with State regulations or permit conditions.  EPA Regions
should always involve States when undertaking an inspection
at a RCRA facility that is likely to accept Superfund wastes.

     Regions must use the results from the inspection, along
with other information, to determine whether the facility Is an
acceptable one.
  Both permitsand interim status apply to specific wastes and
  specific storage, treatment or diaposal processes.  The Remedial
  Project Manager (RPM) or OSC must determine thst the facility's
  permit or interim status Includes the waates that would be
  transported to the facility and the type of process for which
  wastes are being taken to the facility.  Because of these
  concerns, it is important that facility selection be coordinated
  with RCRA personnel.  However, not all CERCLA substances are
  hazardous wastes under RCRA.  Therefore, it is possible that a
  particular permit may not cover a hazardous substance that may
  be  taken to the RCRA facility if it is not a hazardous waste.
  Moreover, In some situations a hazardous substance under CERCLA
  may trigger diaposal requirements under other laws (for example,
  PCBs and some radioactive substances).  In such  cases the
  applicable requirements of  these other laws must be observed.
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     3. It !• BPA's policy to minimize the use of land disposal In
accordance with the direction taken by Congress In amending RCRA.
Where land disposal Is used, these amendments establish nev tech-
nical standards for land disposal facilities.  New disposal units,
lateral expansions and replacement units (defined as of November 8,
1984) of interim status landfills and surface impoundments must
have et least two liners and a leachate detection, collection
end removal system above (In the case of landfills) and between
the liners, if they receive wastes after Nay 8, 1985.  All Fund-
financed and enforced response actions (removal and remedial)
Involving the off-site disposal of hazardous substances must Involve
use of disposal facilities that are in compliance with applicable
RCRA minimum technical reqlurements.  This means that units first
receiving wastes after November 8, 1984 cannot receive wastes
after May 8, 1985 If not double lined.  The RCRA statute does
allow continued use of existing units after that date.  In consider-
ing whether to use an existing unit that does not meet the double
liner requirements, the Agency will consider the toxlclty, persis-
tence and mobility of the hazardous substances and the need to
segregate these substances from others.  Such a unit can be
used only if it is shown to adequately protect public health and
the environment.

     CERCLA hazardous substances which are not hazardous wastes
under RCRA may, in some circumstances,be disposed of in other
legal units.  In such cases, disposal should take place in accordance
with other legal requirements.  Hazardous substances which are not
hazardous wastes may be taken to a RCRA unit under the terms out-
lined in the preceeding paragraph, or to a unit legal under other
statutory provisions (for example, PCBs may be disposed of in a
TSCA approved disposal facility and radlocatlve materials In a
radioactive materials disposal facility).  This disposal must be
consistent with Section 104(c)(3) of CERCLA, when applicable.

     4. Interim status land disposal facilities under considera-
tion for off-site disposal must have adequate ground water
monitoring data to assess whether the facility poses a threat to
ground water.3 Due to the lack of compliance with RCRA ground
water requirements, available data nay not be adequate to assess
the facility.  Moreover, l«cK of evidence of contamination from
the monitoring data does not necessarily mean the facility Is
secure.  The monitoring data may be faulty.  In addition, there
may be other problems at the facility such as air emissions or
surface run-off.  Where doubt exists concerning the acceptability
of a facility,  an on-slte inspection should be undertaken to
specifically address these concerns.  Where possible, this
on-slte inspection should be part of the required RCRA compliance
inspection.
  All remaining land disposal permit applications will be
  requested in FY 1985.  These applications contain summaries
  of ground water monitoring data obtained during the interim
  status period,  and are required to Identify any plume
  contamination.
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     5. Using information gathered fro* the compliance Inspection,
other data sources (e.g., RCRA facility permit data), any other
facility visits and all other relevant information, Regional
Offices »ust evaluate and make a judgment on the acceptability of
uslag the facility for storage, treatment or disposal of hazardous
substances.  For the facility as a whole, this evaluation should
consider whether there are any RCRA violations or other environ-
mental conditions* at the facility which affect its satisfactory
operation.  This evaluation should Include consideration of
facility operations as well as whether there arc physical condi-
tions at the facility that pose a aignlficant threat to public
health, welfare or the environment.  For facilities in assessment
monitoring, the conditions which lead to required assessment
monitoring, as well as resulting monitoring data, must be evaluated,
The evaluation also should consider the nature and quantity of the
substances and whether it is feasible to treat the substances prior
to land disposal to mitigate any adverse effects.

     No Superfund hazardous substances shall be taken off-site to
a RCRA facility if the Region determines that the facility has
significant RCRA violations or other environmental conditions that
affect the satisfactory operation of the facility, unless
both the following conditions are met:

     (1)  The owner or operator must commit, through an enforce-
          able agreement (i.e., consent order or decree), to
          correct the problem.  The agreement must be signed
          before the facility may receive the hazardous
          substances.  In addition, the Regional Administrator
          must determine that the agreement is likely to result
          in correction of the problem and the owner or operator
          of the facility Is capable of compliance with the terms
          of the agreement; and

     (2)  Disposal only occurs within the facility at a new or
          existing unit that is in compliance with RCRA require-
          ments.  The new or existing unit must not  contribute
          in any significant way to adverse conditions  at the
          facility.

III. MANIFEST REQUIREMENTS

     If an off-site option is chosen, a manifest  for  the transpor-
tation of the hazardous waste must be obtained.   The  manifest muse
   It  is  recognized that the RCRA regulations may not  at  this
   time cover all environmental conditions at a facility.   Regional
   offices may  consider other environmental  factors  at  a  facility
   under  consideration Including other  State and/or  Federal
   environmental  laws.  If  a facility Is  In  assessment  monitor-
   ing, the  conditions which lead to assessment monitoring  may
   constitute environmental conditions  that  adversely  affect
   facility  operations.  In such cases, Regions should  assess the
   conditions at  the  facility prior to  using the  facility for
   Superfund purposes.
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b«  la compliance with RCRA  for the transportation of hazardous
wastes.  Th« manlfeat must be a Uniform Hasardoua Wast* Manifest
in  compliance with requirement* at 40 CPR 262 (see 49 FR 10490,
March 20, 1984).  The lead agency or other party undertaking
the cleanup must ensure that the tranaporter properly notifies
under RCRA section 3010.  Where the lead agency allows contractors
to  fill out the manifest, the agency should ensure that the
manifest is properly filed.

IV.  PCS DISPOSAL REQUIREMENTS

     Requirements for the disposal of PCBs are established in
40 CFR 761.60.  Generally, these regulations require that whenever
disposal of PCBs are undertaken, they muat be Incinerated, unless
the concentrations are less than 50 ppm.  If the concentrations
are between 50 and 500 ppm, the rule provides for certain excep-
tions that provide alternatives to the incineration requirements.
The principal alternative Is disposal in an EPA approved landfill
for PCBs.  Landfills used for PCB disposal muat be inspected
within six months prior to disposal.  Regions must determine the
acceptability of the facility based on the same criteria used to
evaluate RCRA facilities in Section II.B.5.

V. IMPLEMENTATION

     Beginning (30 days from date this document is signed) all
Records of Decision (RODs) and Enforcement Decision Documents
(EDDs) for Superfund-lead and enforcement lead actions, respec-
tively, must Include a discussion of compliance with theae pro-
cedures for alternatives involving off-site management of Superfund
hazardous substances at RCRA facilities.  Decision documents for
removal actions also should Include discussion of compliance with
theae procedures.  It is recognized that actual offslte facility
Information will not be available at the ROD stage.  However, the
RI and FS should use actual off-site facilities in costing remedial
alternatives,  in order to have cost figures that are aa accurate
as possible.  It Is recognized that additional facilities are
likely to be considered during the bidding process.  Any facility
ultimately selected for disposal, treatment or storage must meet
the requirements of this policy.

     Provisions requiring compliance with these procedures must be
Included in any contracta for response, cooperative agreements
with Statea undertaking Superfund response and all enforcement
agreements.   For ongoing projects, these provisions will be
implemented aa follows:

     RI/FS:  The Regions  shall  immediately notify Agency contractors
            and States that 1) alternatives for off-site management
            of wastes must be evaluated pursuant to the provisions
            of this policy, and 2) consistent with the policy on
            other environmental laws,  treatment  alternatives
            should not be dropped during the screening stage.

     RD:     The Regions  shall  immediately notify Agency contractors,
            the Statea,  and the U.S.  Army Corps of Engineers that


                                B-9

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         RA:
Enforcement:
            all remedies that  Include off-site disposal  of  hazardous
            substances must comply with the provisions of this
            policy pertaining  to selection of an acceptable off-site
            facility.

            The Regions shall  immediately assess the compliance
            status of  land disposal facilities receiving hazardous
            wastes from ongoing projects.  For a facility not  in
            compliance, the Region should take immediate steps
            to bring the facility Into compliance with the  policy.

            Actions currently  under negotiation and all  future
            actions must comply with these procedures.  Existing
            agreements need not be amended. However, EPA reserves
            the right  to apply these procedures to existing
            agreements, to the extent it is consistent with the
            release and reopener clauses in the settlement  agree-
            ment (See  the Interim CERCLA Settlement Policy. Part
            VII; Thomas, Price, Rablcht; December S, 1984).

     If the response action la proceeding under a Federal-lead,
the Regions should work with the Corps of Engineers or EPA
Contracts Officer to negotiate a contracts modification to an
existing contract, if  necessary.  If the response action is
proceeding under a State-lead, the Regions should amend the
cooperative agreement.  Exceptions for existing contracts and
cooperative agreements may be  allowed on a case-by-case basis
by the appropriate Headquarters Office Director.

     All Regions must  adopt procedures to implement and continual-
ly monitor compliance  with these requirements.  The procedures
must Include designation of a  management official who is respon-
sible for providing information on RCRA facilities in the Region
to other Regions.  It  is the responsibility of the Region in
which the RCRA offsite facility is locsted to assess the accept-
ability of the facility in consultation with the Region planning to
ship wastes to the facility.  The namea of these officials should
be provided to the Office of Waste Programs Enforcement by May
21, 1985.  These names will then be forwarded to all Regions.
If you have any questions concerning these procedures, please
contact Sylvia K.  Lowrance (FTS 382-4812).

Attachments
                                     B-10

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3928
                                     APPENDIX C

Federal  Register f Vol. 50, No.  29 / Tuesday, February 12, 1985 / Proposed Rules
Appendix
  Not*.—This is an Appendix to the
document and will not appear in the Code of
Federal Regulations.

Memorandum
Subject: CERCLA Compliance With
    Other Environmental Statutes
From: Lee M. Thomas, Assistant
    Administrator
To: Regional Administrator Regions I-X
  This memorandum sets forth the
Environmental Protection Agency (EPA)
policy on the applicability of the'
standards, criteria, advisories, and
guidance of other State and Federal
environmental and public health
statutes to actions taken pursuant to
sections 104 and 106 of the
Comprehensive Environmental
 Response, Compensation, and Liability
 Act of 1980 (CERCLA). This policy
 addresses considerations for on-site and
 off-site actions taken under CERCLA.

 I. Discussion
   The National Contingency Plan (NCP)
 establishes the process for determining
 appropriate removal and/or remedial
 actions at Superfund sites. In the course
 of this process, EPA will give primary
 consideration to the selection of those
 response actions that are effective in
 preventing or, where prevention is not
 practicable, minimizing the release of
 hazardous substances so that they do
 not migrate to cause substantial danger
 to present or future public health,
 welfare, or  the environment. As a
 general rule, this can be accomplished
 by pursuing remedies that meet the
 standards of applicable or relevant
 Federal public health or environmental
 laws. However, because of the unique
 circumstances at particular sites, there
 may  be alternatives that do not meet the
 standards of other laws, but which still
 provide protection of public health,
 welfare, and the environment.
                           Although response actions which
                         prevent hazardous substances from
                         migrating into the environment are seen
                         as the most effective under CERCLA,
                         actions which minimize migration must
                         also be considered since CERCLA
                         primarily addresses inadequate past
                         disposal practices and resulting unique
                         site conditions. At certain sites, it may
                         be technically impracticable,
                         environmentally unacceptable or
                         excessively costly to implement a
                         response action that prevents migration
                         or restores the site to its original,
                         uncontamir.ated condition.

                         II. Policy

                           Section 104 of CERCLA requires that
                         for off-site remedial actions, storage.
                         destruction, treatment or secure
                         disposition be in compliance with
                         subtitle C of Resource Conservation and
                         Recovery Act (RCRA). CERCLA is
                         silent,  however, concerning the
                         requirements of other laws with regard
                         to all other response actions taken
                         pursuant to sections 104 and 106. As a
                         general rule,  the Agency's policy is to
                         attain  or exceed applicable or relevant
                         environmental  and public health
                         standards in  CERCLA response actions
                         unless one of the specifically
                         enumerated situations is present. Where
                         such a situation is present and a
                         standard is not used, the Agency must
                         document and explain the reasons in  the
                         decision documents. Federal criteria and
                         advisories, and State standards also will
                         be considered in fashioning CERCLA
                         remedies and. if appropriate, relevant
                         portions will be used. If EPA does not
                         use a relevant part of these standards,
                         criteria or advisories in  the remedial
                         action, the decision documents will state
                         the reasons.

                         A. On-site Response Actions

                            (1) For removal actions. EPA's policy
                         is to pursue actions that will meet
                         applicable or relevant standards, and
                         criteria of other Federal environmental
                         and public health laws to the maximum
                         extent practicable, considering the
                         exigencies of the situation.
  (2) For remedial actions. EPA's policy
is to pursue remedies that attain or
exceed applicable and relevant
standards of other Federal public health
and environmental laws, unless specific
circumstances, identified below, exist.
  CERCLA procedural and
administrative requirements will be
modified to provide safeguards similar
to those provided under other laws.
Application for and receipt of permits is
not required for on-site response actions
taken under the Fund-financed or
enforcement authorities of CERCLA.

fl. Off-Site Response Actions
  CERCLA removal and remedial
activities that involve the removal of
hazardous substances from a CERCLA
site to off-site facilities for proper
storage, treatment or disposal must be in
compliance with all applicable or
relevant standards of Federal
environmental and public health
statutes.
  Off-site facilities that are used for
storage, treatment, or disposal of
Superfund wastes must have all
appropriate permits or authorizations.
  If the facility or process that is being
considered for receipt of the Superfund
wastes has not been permitted or
authorized, the State or responsible
party will be required to obtain all
appropriate permits. A State's
responsibility for obtaining any
appropriate Federal. State or local
permits (e.g. RCRA. TSCA. NPDES.
Clean Air. etc.) will be specified in a
contract or cooperative agreement with
the State as part of its assurances
required under section 104(c) of
CERCLA.

HI. Federal and State Requirements That
May Be Relevant or Applicable to
Response Action*
  Federal and State environmental
standards, guidance and advisories fall
into two categories:

  • Federal standards that are relevant
or applicable.
  • Other standards, criteria, advisories
or guidance to be considered.
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               Federal Register  / Vol. 50. No.  29 / Tuesday,  February 12. 1985  /  Proposed Rules
                                                                         5929
A complete list of both categories of
requirements is attached. This list is our
initial effort. A revised and annotated
list will be included in the forthcoming
Guidance for Feasibility Studies.

A. Federal Standards That Are Relevant
or Applicable
  Applicable standards are those
standards that would be specifically
triggered by the circumstances
associated with the proposed Superfund
remedy except for the fact that the
proposed action would be undertaken
pursuant to CERCLA section 104 or
section 106.
  Relevant standards are those
designed to apply to circumstances
sufficiently similar to those encountered
at CERCLA sites in which their
application would be appropriate at a
specific site although not legally
required. Standards also are relevant if
they would be legally applicable to
CERCLA ( 104 or 1108 actions but for
legal technicalities such as trigger dates
or definitions. For example. TSCA PCB
standards would be relevant even
though the PCBs were produced prior to
January 1976. which triggers TSCA
requirements.
B. Other Requirements. Advisories or
Guidances To Be Considered
   This category includes other
standards, criteria, advisories and
guidance that may be useful in
developing Superfund remedies. These
requirements, advisories and guidances
were developed by EPA, other Federal
Agencies and the States. The data
underlying these requirements may be
used at Superfund sites in an
appropriate way.
IV. Implementation
A. Removal Actions
   For both on and off-site removal
actions, the On-Scene-Coordinator
 should consult with the Regional
 Response Team within the framework of
 the Regional Contingency Plan to
 determine the most effective action.
   (1) On-site. For on-site removal
 actions, the OSC should attempt to
 attain all Federal applicable or relevant
 public health or environmental
 standards. The OSC also should
 consider other Federal criteria, guidance
 and advisories as well as State
 standards in formulating the removal
 action. However, because removal
 actions often involve situations
 requiring expeditous action to protect
 public health, welfare, or the
 environment, it may not always be
 feasible to fully meet them. In those
 circumstances where they cannot be
attained, the decision documents. OSC
reports, or other documents should
specify the reasons.
  (2) Off-site. Off-site facilities that are
used for storage, treatment, or disposal
of Superfund wastes must have all
appropriate permits or authorizations.

B. Remedial Actions
  1. Presentation and Analysis of
Alternatives. As part of the feasibility
study (FS), at least one alternative for
each of the following must, at a
minimum, be evaluated within the
requirements of the feasibility study
guidance and presented to the decision-
maker.
  (a) Alternatives for treatment or
disposal in an off-site facility, as
appropriate;1
  (b) Alternativs which attain
applicable and relevant Federal public
health or environmental standards;
  (c) As appropriate, alternatives which
exceed applicable and relevent public
health or environmental standards;
  (d) Alternatives which do not attain
applicable or relevant public' health or
environmental standards but will reduce
the likelihood of present  or future threat
from the hazardous substances. This
must include an alternative which
closely approaches the level of
protection provided by the applicable or
relevant standards  and meets CERCLA'5
objective of adequately protecting
public health, welfare and environment;
  (e) A no action alternative.
  In some cases, there may be some
overlap between these alternatives.
  2. Selection of Remedy. The decision-
maker will consider all of the
alternatives arrayed in the feasibility
study and wihVgive primary
consideration to remedies that attain or
exceed applicable or relevant Federal
public health and environmental
standards. Where the selected remedy
 involves an EPA standard, criterion, or
 advisory, the decision-maker will ensure
 appropriate coordination with affected
 EPA programs.
   In appropriate cases, the decision-
 maker may select a remedial action that
 includes both on and off-site
 components.
   The decision-maker may select an
 alternative that does not attain
 applicable or relevant standards in one
 of the following circumstances.
 recognizing that a consideration in
making this determination is the extent
to which the standard was intended to
apply to the specific circumstances
present at the site.2
  a. The selected alternative is not the
final remedy and will become part of a
more comprehensive remedy;
  b. All of the alternatives which meet
applicable or relevant standards fall
into one or more of the following
categories:
  (i) Fund-Balancing—For Fund-
financed actions only; exercise the
Fund-balancing provisions of CERCLA
section 104(c)(4);
  (ii) Technically impracticahty—It is
technically impractical from an
engineering perspective to achieve the
standard at the specific site in question;
  (iii) Unacceptable environmental
impacts—All alternatives that attain or
exceed standards would cause
unacceptable damage to the
environment: or
  (c) Where the remedy is to be carried
out pursuant to CERCLA section 106: the
Hazardous Response Trust Fund is
unavailable or would be used: there is a
strong public interest  in expedited clean
up; and the litigation probably would
not result in the desired remedy.
  Where one of these situations is
present,  the decision-maker may select
an alternative which does not attain or
exceed applicable or relevant public
health or environmental standards. The
basis for not meeting the standard must
be fully documented and explained in
the appropriate decision documents.
  The Agency anticipates that most of
CERCLA remedial actions will attain or
exceed applicable or  relevant public
health or environmental standards.
However, where the specific
circumstances discussed above preclude
 the selection of a remedy that attains
 standards, the decision-maker will
 select the alternative that most closely
approaches the level of protection
 provided by the applicable or relevant
 standard, considering the reasons for
 not meeting that standard.
   EPA also will use appropriate Federal
 public health and environmental
 criteria, advisories, and guidance and
 State standards in developing
 appropriate remedial alternatives. If the
 decision-maker determines that such
   1 Thcu alternative! mull bt continent with
 forthcoming guidance on "Procedure* for
 Implementing CERCLA Delegation! for Off-Sue
 ReiponM Actiona." In tome casee. off-site diipotal
 or treatment may not be feanble and thil
 altemetive may be eliminated during initial
 icreemng of altemaiivei. The daemon document!
 should reflect this screening.
   1 In determining whether l particular standard is
 applicable or relevant (he decinon-maker should
 refer to the attached list "Applicable or Relevant
 Requirements " For example. RCRA did not
 "contemplate ' the regulation of the mdiscnmmanl
 disposal of waste over 210 miles of roadway, or the
 contamination of a mer bed with hazardous waste
 In such situations. RCRA regulations would not be
 applicable per se. but on a case-by-case basis part
 of the regulation may be relevant
                                                        C-2

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5f»
Federal  BefUter / Vol. 50. No. 29  /  Tuesday, February 12. 1985 /  Proposed Rules
 standard!, criteria, advitories or
 goideance we relevant bat are not used
 in the selected remedial alternative, the
 decision documents will indicate the
 basis for not using them.
   For Fund-financed action*, where
 State standard* are part of the colt-
 effective remedy, the Fond will pay to
 attain thoee standard*. Where the  cost-
 effective remedy doe* not include thoaa
 State standards, the State may pay the
 difference to attain them.
   3. AdmiiuitraUve and Procedural
 Aspects. The following modification*
 will be made to the Superfuitd
 community relation* program to ensure
 that it provides a similar level of public
 involvement to that provided by the
 permitting program* of other
 environmental law*;
   • A-fact sheet should be included
 with the public notice and feasibility
 study which i* provided to tae public Z
 week* before the 3 week public
 comment period. The fact sheet will
 clearly summarize the feasibility study
 response alternative* and other issues.
 including which alternatives attain or
 exceed public  health and environmental
 standards and criteria. For those
 alternatives that do not attain
 applicable and relevant standard* of
 other public health and environmental
 law*, the fact sheet shall identify how
 they fail to attain the standard* and
 explain how they nonetheless meet the
 goals of CERCLA. The public notice
 should include a timetable  in which a
 decision will be reached, any tentative
 determinations which the Agency has
 made, the location where relevant
 document* can be obtained,
 identification of community involvement
 opportunities, the name of an Agency
 contact and other appropriate •
 information.
  • A public notice and updated fact
 sheet should be prepared upon [1]
 Agency  selection of the final response
 action and (2) upon completion of the
 final engineering design. Prior to
 selecting the final engineering design.
 the Agency may hold a public meeting to
 inform the public of the design
 alternatives and solicit comments.
  • If a  remedy is identified that is
 different from those proposed during the
 feasibility study public comment period.
 a new 3 week public comment period
 may be required prior to amending  the
 record of decision, taking into
consideration the features of the
alternatives addressed in the public
comment period.
  In addition, certain aspects of the
CERCLA administrative process may be
modified to assure comparability with
the administrative requirements (i.e.
                         recordkeeping. monitoring) of the other
                         environmental programs.
                           The CERCLA enforcement community
                         relations program will also be modified
                         to provide for an enhanced public
                         participation program for both consent
                         decrees and administrative orders. This
                         program will be substantially equivalent
                         to the revised program for Fund-
                         financed actions. Furthermore, consent
                         decrees and administrative orders will
                         incorporate administrative requirements
                         (i.e. recordkeeping. monitoring) similar
                         to those mandated by other
                         environmental programs.

                         V. Applicability of Policy
                           This policy applies to three different
                         situations:
                           •  A site specific FS has not yet been
                         initiated.
                           •  The  FS ha* been initiated, but the
                         remedy ha* not yet been selected.
                           •  The FS is completed and the remedy
                         has  been selected.
                           All sites where the FS ha* not yet
                         been initiated must meet all of the
                         requirement* of this policy.
                           Where the  FS ha* been initiated and
                         the remedy ha* not yet been selected,
                         the requirement* of this policy do not
                         apply to Record of Decisions (ROD*)
                         signed before March 1.1985. RODs
                         signed before March 1.1985. should
                         present to the decision-maker at least
                         one  alternative that attains or exceeds
                         applicable or relevant standards and, if
                         it is  not selected should indicate the
                         reasons why  it was not selected.
                           Where the FS is complete and the
                         remedy has been selected, the decision-
                         maker may on a case-by-case basis
                         revise the selected remedy.
                           If you have any questions or
                         comments, please contact William N.
                         Hedeman. Director. Office of Emergency
                         and  Remedial Response (FTS 382-2180)
                         or Douglas Cohen of his Policy Analysis
                         Staff (FTS 382-3044).
                           Attachment

                         Applicable or Relevant Requirement*

                         7. Office of Solid Waste
                           •  Open Dump Criteria (RCRA Subtitle
                         D. 40 CFR Part 257)
                          Not*.—OnTy  relevant to nonhatardons
                         waste* In molt ntuatioos Supcrfund wanes
                         will be handled in accordance with RCRA
                         Subtitle C requirements.
                           •  Hazardous Waste Regulations
                         [RCRA Subtitle C. 40 CFR Part 254)
                         including liner, cap, groundwater. and
                         closure requirements under the
                         following subpartr
                         F. Ground-Water Protection
                         G. Closure and Post Closure
                         H. Container*
                         I. Tanks
 J. Surface Impoundments
 K. Waste Piles
 L Land Treatment
 M. Landfills
 N. Incinerators

 2. Office of Water
   •  Maximum Contaminant Levels (for
 alt sources of drinking water exposure).
   •  Underground Injection Control
 Regulations.
   •  State Water Quality Standards
 (apply for surface water discharge).
   •  Requirements establiahed pursuant
 to section 301 and section 403(c) of the
 Clean Water Act.
   •  Ocean Dumping Requirements
 including incineration at sea.
   •  Pretreatment standards for
 discharge into a publicly owned
 treatment work*.

 3. Offica of Pesticides and Toxic
 Substances

   •  "PCS Requirements including
 Disposal and Marking Rule (43 FR 7150,
 2-17-78): PCB Ban Rule (44 FR 31514. 5-
 31-79) PCB Electrical Equipment Rule
 (47 FR 37342, August 25,1982):
 Uncontrolled PCBs Rule (49 FR 28172,
 July  10.1984) and other related   -
 rulemakings."
   •  40 CFR 775 Subpart J—Disposal of
 Waste Material Containing TCDD.

 4. Office of External Affain
   •  Guidelines for Specification of
 Disposal Sites for Dredged or Fill
 Material (section 404fb)(l) Guidelines.
 40 CFR Part 230).
   •  Denial or Restriction of Disposal
 Site  for Dredged Material Final rule
 (section 404(c)).

5. Office of Air and Radiation
   •  Uranium mill tailing rules.
   •  National Ambient Air Quality
Standards.
   •  High and low level  radioactive
waste rule.
  •  Asbestos disposal rules.
6. Other Federal Requirements
  •  OSHA requirements.
  •  Preservation of scientific, historical
or archaeological data.
  • D.O.T. Hazardous Materials
 Transport Rules.
  • Regulation of activities in or
affecting waters of the United States
pursuant to 33 CFR 320-329.
  • The following requirements are
triggered by fund-financed actions:
—Preservation of rivers on the national
  inventory. Wild and Scenic Rivers
  Act. section 40 CFR 8.302(e).
—Protection of threatened or
  endangered species and their habitats
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              Federal  Register / Vol. 50, No. 29  /  Tuesday, February 12. 1985 /  Proposed Rules
                                                                       5931
—Conservation or Wildlife Resources.
—Executive Orders related to
  Floodplams (11988) and Wetlands
  (11990).
—Coastal Zone Management Act.

Other Requirements. Advisories and
Guidance To Be Considered
1. Federal Requirements. Advisories and
Procedures
  • Recommended Maxim-un
Concentration Limits (RMCLs).
  • Health Advisories, EPA. Office of
Water.
  • Federal Water Quality Criteria.
  Not*.—Federal water quality criteria are
not legally enforceable. State water quality
standards, developed using appropriate
aspects of Federal water quality criteria, are
legally enforceable. In many cases, States
water quality standards do not include
specific numerical limitations on a large
number of priority pollutants. When there are
no numerical state standards for a given
pollutant Federal water quality criteria
should be considered.
  • Pesticide and Food additive
tolerances and action levels data.
  Note.—Germane portions of tolerances and
action levels may be relevant in certain
situations.
   • Waste load allocation procedures,
EPA Office of Water.
   • Federal Sole Source Aquifer
requirements.
   • Public health basis in listing
decisions under sec. 112 of the Clean Air
Act.
   • EPA's groundwater protection
 strategy.
   • New Source Performance Standards
 for Storage Vessels for Petroleum
 Liquids.
   • TSCA health data.
   •  Pesticide registration data.
   •  TSCA chemical advisories (2 or 3
 issued to date).
   •  Advisories issued by FWS and
 NWFS under the Fish and Wildlife
 Coordination Act.
   • National Environmental Policy Act.
   • Floodplain and Wetlands Executive
 Orders.
   • TSCA Compliance Program Policy.

 2. State Requirements
   •  State Requirements on Disposal and
 Transport of Radioactive wastes.
   •  State Approval of Water Supply
 System Additions or Developments.
   •  State Ground Water Withdrawal
 Approvals.
   •  Requirements of authorized
 (Subtitle C of RCRA) State hazardous
 waste programs.
   •  State Implementation Plans and
 Delegated Programs Under Clean Air
 Act.
  • All other State requirements, not
delegated through EPA authority.
  Note.—Many other State and local
requirements could be relevant. The guidance
for feasibility studies will include a more
comprehensive list.

3. USEPA RCRA Guidance Documents

A. EPA's RCRA Design Guidelines
  (1) Surface Impoundments, Liners
Systems, Final Cover and Freeboard
Control.
  (2) Waste Pile Design—Liner Systems.
  (3) Land Treatment Units.
  (4) Landfill Design—Liner Systems
and Final Cover.
B. Permitting Guidance Manuals
  (1) Permit Applicant's Guidance
Manual of Hazardous Waste Land
Treatment, Storage. Disposal Facilities.
  (2) Permit Writer's Guidance Manual
for Hazardous Waste Land Treatment
Storage. Disposal Facilities.
  (3) Permit Writer's Guidance Manual
for Subpart F.
   (4) Permit Applicants Guidance
Manual for the General Facility
Standards.
   (5) Waste Analysis Plan Guidance
Manual.
   (6) Permit Writer's Guidance Manual
for Hazardous Waste Tanks.
   (7) Model Permit Application for
Existing Incinerators.
   (8) Guidance Manual for Evaluating
Permit Applications for the Operation of
Hazardous Waste Incinerator Units.
   (9) A Guide for Preparing RCRA
Permit Applications for Existing Storage
 Facilities.
   (10) Guidance Manual  on closure and
 post-closure Interim Status Standards.
 C. Technical Resource Documents
 (TRDs)
   (1) Evaluating Cover Systems for Solid
 and Hazardous Waste.
   (2) Hydrologic Simulation of Solid
 Waste Disposal Sites.
   (3) Landfill and Surface Impoundment
 Performance Evaluation.
   (4) Lining of Water Impoundment and
 Disposal Facilities.
    (5) Management of Hazardous Waste
 Leachate.
    (6) Guide to the Disposal of
 Chemically Stabilized and Solidified
 Waste.
    (7) Closure of Hazardous Waste
  Surface Impoundments.
    (8) Hazardous Waste  Land Treatment.
    (9) Soil Properties. Classification, and
  Hydraulic Conductivity  Testing.

  D. Test Methods for Evaluating Solid
  Waste
    (1) Solid Waste Leaching Procedure
  Manual.
  (2) Methods for the Prediction of
Leachate Plume Migration and Mixing.
  (3) Hydrologic Evaluation of Landfill
Performance (HELP) Model Hydrologic
Simulation on Solid Waste Disposal
Sites.
  (4) Procedures for Modeling Flow
Through Clay Liners.
  (5) Test Methods for Evaluating Solid
Wastes.
  (8) A Method for Determining the
Compatibility of Hazardous Wastes.
  (7) Guidance Manual on Hazardous
Waste Compatibility.

4. USEPA Office of Water Guidance
Documents
A. Pretreatment Guidance Documents
  (1) 304(g) Guidance Document Revised
Pretreatment Guidelines (3 Volumes).
  Provides technical data describing
priority pollutants and their effects on
wastewater treatment processes to be
used in developing local limits:
descnbes technologies applicable to
categorical industries.
B. Water Quality Guidance Documents
   (1) Ecological Evaluation of Proposed
Discharge of Dredged Material into
Ocean Waters  (1977).
   (2) Technical Support Manual:
Waterbody Surveys and Assessments
for Conducting Use Attainability
Analyses (1983).
   Outlines methods for conducting use
attainability analyses under  the Clean
Water Act.
   (3) Water-Related Environmental Fate
 of 129 Priority Pollutants (1979).
   Describe the transformation and
 transportation of priority pollutants.
   (4) Water Quality Standards
 Handbook (1983).
   Provides an  overview of the Criteria
 Standards Program under the Clean
 Water Act and outlines methods for
 conducting criteria standards
 modification.
   (5) Technical Support Document for
 Water Quality-based Toxics Control.
 C. NPDES Guidance Documents
   (1) NPDES Best Management Practices
 Guidance Manual (June 1981).
   Provides a protocol for evaluating
 BMPs for controlling discharges of toxic
 and hazardous substances to receiving
 waters.
   (2) Biomomtoring Guidance. July 1983,
 subsequent biomonitoring policy
 statements, and case studies on toxicity
 reduction evaluation (May 1983).

 D. Ground Water/UlC Guidance
 Document
    (1) Designation of a USDW.
    (2) Elements of Aquifer Identification.
                                                       C-4

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5*82	Federal Re&fter  /  Vol.  50,  No. 29  /  Tuesday. February 12. 1965  /  Proposed Rules
  (3) Interim guidance for public
participation.
  (4) Definition of major facilities.
  (5) Corrective action requirements.
  (6) Requirement! applicable to wells
injecting into, through or above an
aquifer which has been exempted
pursuant to 5 146.104(b)(4).
  (7) Guidance for UIC implementation
on Indian lands.

J. USEPA Manuals From the Office of
Research and Development
  (1) EW 846 method*—laboratory
analytic methods.
  (2) Lab protocols developed pursuant
to Clean Water Act section 304(h).
(FR Doc. 85-2402 Filed 2-11-83. 8:45 am]
                                                    f1— S
                                                       J                 u US. GOVERNMENT PRINTING OFFICE 1985 - 559-111/10857

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