xvEPA
United States
Environmental Protection
Agency
Office of Research and
Development
Washington. DC 20460
EPA/540/G-91/011
February 1991
Superfund
Guidance on RCRA Corrective
Action Decision Documents
The Statement of Bases
Final Decision and
Response to Comments
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EPA/540/G-91/011
OSWER Directive 9902.6
February 1991
GUIDANCE ON RCRA
CORRECTIVE ACTION
DECISION DOCUMENTS:
THE STATEMENT OF BASIS
FINAL DECISION AND RESPONSE TO COMMENTS
Office of Waste Programs Enforcement
U.S. Environmental Protection Agency
Washington, D.C. 20460
Printed on Recycled Paper
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OSWER Directive 9902.6
This guidance is a general statement of policy; it does not establish or
affect legal rights or responsibilities; it does not establish a binding norm
and is not finally determinative of the issues addressed; Agency decisions in
any particular case will be made applying the law and regulations on the basis
of specific facts and actual action.
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TABLE OF
CHAPTER PAGE
1-1
1.1 Purpose of this Guidance ............... 1-1
1.2 Overview of the RCRA Corrective Action Process ..... 1-2
1.2.1 The RCRA Facility Assessment (RFA) ....... 1-2
1.2.2 Interim Measures (IM) ............. 1-4
1.2.3 RCRA Facility Investigation (RFI) ....... 1-5
1.2.4 Corrective Measures Study (CMS) ........ 1-5
1.2.4.1 Public Comment Period for Selection
of Remedy(ies) ............ 1-6
1.2.4.2 Response to Comments (RTC) ...... 1-6
1.2.5 Corrective Measures Implementation (CMI) .... 1-8
1.3 Additional Information ............... 1-8
2 WRITING THE STATEMENT OF BASIS (SB) ........... 2-1
2.1 Introduction .................... 2-1
2.2 Purpose of the Statement of Basis .......... 2-1
2.3 Writing the Statement of Basis ............ 2-3
2.4 Section by Section Description of the
Statement of Basis ................. 2-6
2.4.1 Introduction ................. 2-6
2.4.2 Proposed Remedy ................ 2-6
2.4.3 Facility Background .............. 2-6
2.4.4 Summary of Facility Risks ........... 2-7
2.4.5 Scope of Corrective Action .......... 2-8
2.4.6 Summary of Alternatives ........... 2-8
2.4.7 Evaluation of the Proposed Remedy and
Alternatives ................. 2-9
2.5 Public Participation ................ 2-11
3 THE NEWSPAPER NOTIFICATION OF PROPOSED CORRECTIVE ACTION
AND AVAILABILITY OF THE AEMINISTRATIVE RECORD ....... 3-1
3.1 Procedures ..................... 3-1
3.2 Writing the Newspaper Notification .......... 3-2
3.2.1 Section by Section Description of the
Newspaper Notification ............. 3-2
3.3 Public Comment Period ................ 3-4
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TABLE QP CONCENTS (Continued)
CHAPTER PAGE
4 ELEMENTS OF THE FINAL DECISION AND RESPONSE TO COMMENTS ... 4-1
4.1 Introduction 4-1
4.2 Purpose of the Response to Comments 4-1
4.3 Writing the Response to Comments 4-2
4.4 Section by Section Description of the Response
to Comments 4-2
4.4.1 Introduction 4-2
4.4.2 Selected Remedy 4-5
4.4.3 Public Participation Activities 4-5
4.4.4 Comments Raised During the Comment Period
and the Agency's Response 4-5
4.4.5 Future Actions 4-5
4.4.6 Declarations 4-5
5 DOCUMENTING LOOTED SCOPE REMEDIAL ACTIONS AND
CONTINGENCY REMEDY DECISIONS 5-1
5.1 Documenting a "Limited Scope Remedial Actions" Decision 5-1
5.2 Decision Documents with Contingency Remedies 5-1
6 EXAMPLE STATEMENT OF BASIS 6-1
6.1 Example Statement of Basis 6-1
7 EXAMPLE FINAL DECISION AND RESPONSE TO COMMENTS 7-1
7.1 Example Final decision and Response to Comments .... 7-1
8 BIBLIOGRAPHY 8-1
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LIST OF EXHIBITS
NUMBER
2-1 Outline for the Statement of Basis 2-4
2-2 Standards lhat May Apply to RCRA Corrective Actions . . 2-10
3-1 Summary of §124.10(d) Public Notice Requirements .... 3-3
4-1 Final Decision and Response to Comments 4-3
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LIST OF FIGURES
NUMBER PflGE
1-1 RCRA Corrective Action Process 1-3
1-2 Evaluation Criteria for Corrective Measures 1-7
2-1 The Corrective Action Decision Making Process 2-2
6-1 EIO Industrial Company Facility and Surroundings . . . 6-3
7-1 EIO Industrial Company Facility and Surroundings
Showing Contaminated Ground Water Plume 7-4
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OSWER Directive 9902.6
CHAPTER 1
INTRODUCTION
1.1 PURPOSE OF THIS GUIDANCE
This guidance on preparing Resource Conservation and Recovery Act (RCRA)
Statement of Basis Documents and the Response to Comments (RTC) has been
developed to present standard formats for documenting RCRA corrective action
decisions and to clarify the roles and responsibilities of the regulatory
agency in developing and issuing decision documents. The decision documents
addressed by this guidance are the Statement of Basis (SB) and the RTC. SBs
and RTCs should be prepared when corrective action is implemented through
either a permit or enforcement order. The SB and RTC represent documents
similar in purpose to the proposed remedial action plan and Record of Decision
(ROD) employed by the Superfund program to fulfill the requirements set forth
under the Comprehensive Environmental Response, Compensation and Liability Act
of 1980 (CERdA).
This guidance has been prepared on the basis of the Hazardous and Solid
Waste Amendments of 1984 (HSWA), the final National Oil and Hazardous Waste
Contingency Plan (NCP), the proposed 40 Code of Federal Regulations (CFR) 264
Subpart S and 40 CFR Part 124.
The primary purpose of the SB/RTC guidance is to standardize the format
of the SB and RTC. Remedies selected in the RCRA program may be reviewed by
the public on a national as well as a local level. Standardizing these remedy
decision documents will:
• Provide consistency among Regions with respect to the organization
and content of decision documents
• Promote clear and logical presentations of rationales for remedy
selection decisions based on facility-specific information and
supporting analysis.
The chapters included in this guidance address the following aspects of
the RCRA remedy selection process:
Chapter 2 presents the standard format for the SB and discusses key
elements to be included in each section.
Chapter 3 presents the standard format for the public notification of
the public comment period.
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OSWER Directive 9902.6
Chapter 4 discusses the standard format for the Response to Comments
(RTC) and discusses key elements to be included in each section.
Chapter 5 discusses the documentation of no effective remedial action
and contingency remedy decisions.
Chapter 6 presents an example SB after which individual site-specific
SBs can be patterned.
Chapter 7 presents an example RTC after which individual site-
specific RTCs can be patterned. The RTC presented in this guidance
includes the regulatory agency's response to comments, in addition to
a brief description of the selected remedy and rationale behind the
selection.
This guidance does not address situations when the selected remedy is
changed or modified after the permit modification has become final or an
enforcement order implementing the remedy has been issued. Procedures
undertaken to reflect the amended remedy should proceed in accordance with
either 40 CFR Part 124 or the terms specified in the enforcement order.
CORRECTIVE ACTION PROCESS
This section describes the relationship between the decision documents
addressed in this guidance and the overall RCRA corrective action process
(Figure 1-1) . Each stage of the corrective action process is briefly
summarized below.
1.2.1 THE RCRA FACILITY ASSESSMENT
The RCRA Facility Assessment (RFA) is often the first step in the
corrective action process. An RFA (or equivalent investigation) is conducted
prior to the issuance of a permit, and in many cases, prior to the issuance of
a corrective action order.
The RFA is a process for:
• Identifying and gathering information on releases at RCRA facilities
• Evaluating and identifying solid waste management units (SWMUs) ,
regulated units, and other areas of concern for releases to all media
(additional SWMUs may be identified after the RFA as a result of
further investigations)
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RCRA Facility Assessment (RFA)
• Hazard Identification
i
Issuance of Enforcement Order or
HSWA Permit
RCRA Facility Investigation (RFI)
• Work Plan
• Facility Characterization
• Risk Assessment
• Laboratory and Bench Scale Studies
1
Corrective Measures Study (CMS)
• Development and Screening of Remedies
• Detailed Analysis of Remedies
Public Notification of Proposed Remedy, Administrative Record,
and Draft Permit Modification (where applicable)*
Statement of Basis (SB)
• Present Proposed Remedy and Information Repository
• Present Discussion of Remedial Alternatives
• Indicate Cleanup Levels or Goals
i
Public Comment Period
• Public Responds to Proposed Remedy
• Possible Public Hearing/Meeting
Response to Comments (RTC)
• Agency Identifies Selected Remedy
» Agency Responds to Comments
Issuance of Order/Order
Amendment or Permit Modification
Corrective Measures Implementation (CMI)
• Remedial Design
• Remedial Construction
• Operation and Maintenance
Figure 1-1: RCRA Corrective Action Process
* The administrative record should be accesible to the public during the entire
corrective action process.
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OSWER Directive 9902.6
• Making preliminary determinations regarding releases of concern and
the need for further actions and interim measures at the facility
• Screening from further investigations those SWMUs which do not pose a
threat to human health and/or the environment
• Helping the regulatory agency to identify, evaluate, prioritize, and
to initially clean up those facilities which present or may present
the greatest threat to human health and the environment as prescribed
in the Environmental Priorities Initiative (EPI).
During the RFA, Environmental Protection Agency (EPA) or State
investigators will gather information on SWMLJs and other areas of concern at
RCRA facilities, evaluate this information to determine whether there are
releases that warrant further investigation or other action at these
facilities, and upon completion of the RFA, determine the need to proceed to
the second phase (RCRA Facility Investigation (RFI)) of the process.
Each of the three steps of the RFA process requires the collection and
analysis of data to support initial release determinations:
Step 1: The preliminary review focuses primarily on evaluating existing
information.
Step 2: The visual site inspection entails the onsite collection of visual
information to obtain additional evidence of release.
Step 3: The sampling visit fills any data gaps that remain upon completion of
the preliminary review and visual site inspection by obtaining
sampling and field data. Sampling is not always necessary if
sufficient data was gathered during steps 1 and 2 of the RFA process
to adequately identify the hazards at the facility.
1.2.2 INTERIM MEASURES
Interim measures (IM) for corrective action may be initiated, when
appropriate, prior to the initiation or completion of the RFI, Corrective
Measures Study (CMS), or Corrective Measures Implementation (CMI). Decisions
concerning iMs are made based on the immediacy and magnitude of the potential
threat to human health or the environment, and the implications of deferring
the corrective action until the RFI/CMS is completed. Implementation of IMs
must be consistent with regulatory agency priorities and must be related to
protection of human health and the environment. It is not necessary to
prepare a SB or a public notice for IMs implementation.
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OSWER Directive 9902.6
1.2.3 RCRA FACULTY lUVESTIGATION
If the regulatory agency determines that a RFI is necessary, the owner
or operator will be required to perform a RFI either under a permit schedule
of compliance or under an enforcement order. This determination will
generally be based on the results of the RFA and will identify specific units
or releases needing further investigation. The RFI can range widely from a
small specific activity to a complex multimedia study. The investigation
generally includes the characterization/ identification of the hydrogeological
setting, the type and concentration of hazardous waste or hazardous
constituents released, the rate and direction at which the releases are
migrating, and the extent over which releases have migrated.
The regulatory agency ensures that data and information submitted by the
owner or operator during the RFI adequately describe the release(s), and can
be used to make decisions regarding the need for and focus of a CMS. The RFI
also includes a comparison of release characterization data against
established health and environmental criteria. At the completion of the RFI,
a report is prepared by the owner or operator summarizing the investigation
findings. The regulatory agency then interprets these results to determine
whether a CMS is necessary.
Information generated during the RFI is used not only to determine the
potential need for CMI, but also to aid in the selection and implementation of
these measures. While conducting the RFI, the owner or operator must collect
data which may be needed to select and implement the appropriate remedy(ies).
The findings of the RFI provide the rationale and basis for the CMS.
1.2.4 CORRECTIVE MEASURES STUDY
If the need for corrective measures is verified during the RFI process,
the owner or operator is then responsible for performing a CMS. During this
step in the corrective action process, the owner or operator will identify,
evaluate, and recommend specific remedies that will remediate the release(s)
based on a detailed engineering evaluation of the data and the corrective
measure technologies. The remedies evaluated by the owner or operator, along
with the owner or operator's recommendations, are documented in a final
report.
As discussed in the June 26, 1987 "Criteria for Elimination of
Headquarter's Concurrence on Selected RCRA §3008(h) Orders" memorandum
(directive number 9904.3), U.S. EPA Headquarters maintains a 21-day
consultation role for corrective measures decisions made in conjunction with
§3008(h) orders. When the 21- day consultation is in effect, regions should
submit the order or corrective measures decision to Headquarters for review.
If Headquarters does not raise issues during the consultation period, then
agreement can be assumed and the region may issue the order or decision. If a
disagreement between Headquarters and regional staff cannot be resolved, then
the outstanding issues should be raised with management.
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OSWER Directive 9902.6
1.2.4.1 Public Comment Period for Selection of Remedyfies)
The regulatory agency's proposed remedy for a facility is presented to
the public in a SB, and, where applicable, the draft permit modification. The
SB provides a brief summary of all of the alternatives studied in the detailed
analysis phase of the REE/CMS, highlighting the key factors that led to the
identification of the proposed remedy. SBs prepared in conjunction with draft
permit modifications must be drafted in accordance with 40 CFR 124.7. SBs
prepared in conjunction with enforcement ordars are not required by regulation
to adhere to 40 CFR 124.7. However, these regulations and this guidance
supplement each other and may be used in concert to draft SBs.
The remedy proposed in the SB is one that best meets the applicable
standards for remedies and decision factors presented in Figure 1-2. The
remedy selection process as presented in this guidance is simply to be used as
guidance until the Subpart S regulations are promulgated. These decision
factors are further discussed in the proposed Subpart S rule. The SB is made
available for public comment, in addition to the administrative record, the
RFI and CMS Reports, and, where applicable, the draft permit modification.
The public may comment on the RFI and CMS, as well as the proposed remedy, at
this time. If warranted, the regulatory agency may require the owner or
operator to perform additional CMSs in response to public comment. Additional
studies may be conducted pursuant to a modified enforcement order, a new
enforcement order, or permit conditions.
1.2.4.2 Response to Comments
Following receipt of public comments, the regulatory agency is required
to prepare a RTC prior to the issuance of any final permit decision pursuant
to 40 CFR 124.15. This RTC must be prepared in accordance with 40 CFR 124.17.
A RTC should also be prepared after the public comment period but prior to
those facilities undertaking corrective action pursuant to an enforcement
order.
The regulatory agency's response to public comments and the remedy(ies)
selected by the regulatory agency should also be documented in the RTC. A RTC
which documents the selected remedy for a facility will serve three basic
functions:
• Responds to comments received during, or prior to the public comment
period
• Describes the technical parameters of the selected remedy, specifying
the treatment, engineering, and institutional components, as well as
remediation goals
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FOUR GENERAL STANDARDS FOR CORRECTIVE MEASURES
Overall protection
of human health
and the environment
Attain media cleanup
standards
Control the sources of
releases
Comply with
standards for
management of
wastes
How alternatives
provide human health
and environmental
protection
Ability of
alternatives to
achieve the media
cleanup standards
prescribed in the
permit modification
or enforcement
order
How alternatives
reduce or eliminate to
the maximum extent
possible further
releases
. How alternatives
assure that manage-
ment of wastes during
corrective measures
is conducted in a
protective manner
FIVE SELECTION DECISION FACTORS
Long-term reliability
and effectiveness
Reduction of toxicity,
mobility, or volume of
wastes
Short-term
effectiveness
Implementability
Cost
. Magnitude of residual risk • Treatment process used
and materials treated
i Adequacy and reliability
of controls • Amount of hazardous
materials destroyed or
treated
• Degree of expected
reductions in toxicity,
mobility, or volume
• Degree to which treatment
is irreversible
• Type and quantity of
residuals remaining
after treatment
• Protection of
community during
remedial actions
1 Protection of
workers during
remedial actions
• Environmental
impacts
• Time until
remedial action
objectives are
achieved
Ability to construct * Capital costs
and operate the
technology
Reliability of the
technology
• Operating and
maintenance
costs
• Present worth
• Ease of undertaking costs
additional corrective
measures if necessary
• Ability to monitor
effectiveness of
remedy
, Coordination with
other agencies
. Availability of offsite
treatment, storage
and disposal services
and specialists
. Availability of
prospective
technologies
Figure 1-2: Evaluation Criteria for Corrective Measures
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OSWER Directive 9902.6
• Provides the public with a consolidated source of information about
the facility and the chosen remedy, including the rationale behind
the selection.
1.2.5 CORRECTIVE MEASURES IMPLEMENTATIC^
The permit modification or corrective action order provides the
framework for the transition into the next phase of the remedial process, CMI.
The CMI program includes designing, constructing, operating, maintaining, and
monitoring the performance of the remedy (ies) selected to protect human health
and the environment.
1.3 ADDITIONAL INFORMATICS
This guidance addresses only the preparation of the SB and RTC. Other
guidance documents that address other stages of the corrective action process
are also available. Because preparation of the SB relies to a great extent on
the information collected and analyzed during the RFT/CMS process, the RFI
Guidance (OSWER Directive 9502.00-6D, May 1989) may be particularly useful.
Many portions of the SB contain summaries of information that are generated
during the RFI and CMS. Additional sources of information on the corrective
action process and remedy selection are listed in Chapter 8 of this guidance.
1-8
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OSWER Directive 9902.6
CHAPTER 2
WRITING THE STATEMENT OF BASIS
2.1
EPA is committed to providing a meaningful opportunity for the public to
be informed of and participate in decisions that affect them and their
communities. The administrative record is the basis for corrective action
decisions and can be a tool in fulfilling EPA's public involvement objectives.
The SB and draft permit modification (if applicable) are the public
participation documents that summarize the corrective action options and
preferences and solicit public comment. This chapter presents the purpose of
the SB and a suggested outline and format for drafting it.
2.2 PURPOSE OF THE STATEMENT OF BASIS
The administrative record is the documentation assembled during the
corrective action process. Figure 2-1 provides an overview of this process.
The SB summarizes the information contained in the RFI/CMS reports and the
administrative record, and is designed to facilitate public participation in
the remedy selection process by:
• Identifying the proposed remedy for a corrective action at a
facility and explaining the reasons for the proposal
• Describing other remedies that were considered in detail in the RFI
and CMS reports
• Soliciting public review and comment on all possible remedies
considered in the RFI and CMS reports, and on any other plausible
remedies
• Providing information on how the public can be involved in the
remedy selection process.
The SB is a public participation document and is expected to be widely
read. The SB, therefore, should be written in a clear and concise manner
using nontechnical language. In addition, the SB should direct the public to
the RFI and CMS reports as the primary source of detailed information on the
corrective measures analyzed, as well as other site-specific information.
The SB describes the proposed remedy, but does not select the final
remedy for a facility. This approach allows for additional information to be
2-1
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OSWER Directive 9902.6
considered during the public comment period. Following this period, public
comment and/or additional data may result in changes to the remedy or in
another choice of remedy. After the regulatory agency has considered all
comments from the public, the final decision, selecting the remedy, or
determining the need to develop another option, is documented in the ETC.
In emphasizing that the proposed remedy is only an initial
recommendation, the SB should clearly state that changes to the proposed
remedy, or a change from the proposed remedy to another alternative, may be
made if public comments or additional data indicate that such a change would
result in a more appropriate solution. The final decision regarding the
selected remedy(ies) should be documented in the final permit modification (if
applicable) with the accompanying PTC after the regulatory agency has taken
into consideration all comments from the public. An important function of the
SB is to solicit public comment on all possible alternatives (alternatives not
evaluated in the CMS may be proposed by the public at this time).
2.3 WRITING THE STATEI^NT OF BASIS
The SB summarizes essential information from the RFI and CMS reports.
The KFI and CMS reports should be referenced in the SB. The SB should:
• Briefly summarize the environmental conditions at the facility as
determined during the RFI
• Identify the proposed remedy
• Describe the remedial alternatives evaluated in sufficient detail to
provide a reasonable explanation of each remedy
• Provide a brief analysis that supports the proposed remedy,
discussed in terms of the evaluation criteria.
Exhibit 2-1 provides a recommended outline of the SB. Variations to the
outline may be made as appropriate.
The following subsections provide more specific guidance on the key
elements of the SB.
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EXHIBIT 2-1
OOTUENE FOR THE STATEMENT OF BASIS
INTRODUCTION
Provide facility name and location.
Introduce document's purpose, which is to:
- Identify proposed remedy and explain rationale for preference
- Describe all remedies analyzed
- Serve as companion to the RFI/CMS and administrative record
file
- Solicit public involvement in selection of a remedy(ies).
Stress importance of public input on all alternatives, including
options not previously studied.
PROPOSED REMEDY
• Identify proposed remedy.
FACrLTTY BACKGROUND
Provide brief overview of site.
Describe site history.
Provide brief summary of the RFI.
FACIIJTY RISKS
• Provide an overview of the following:
- Contaminated media
- Chemicals of concern
- Baseline exposure scenarios (e.g., routes of exposure—current
and future land-use scenarios)
- Current and potential facility risks (including both
carcinogenic and noncarcinogenic threats).
• Discuss ecological risk(s), as appropriate.
SCOPE OF CORRECTIVE ACTION
Describe scope of problem that the remedy will address.
If it is a phased remedy, describe the role that each phase will
address.
Identify how the remedy or each phase of the remedy addresses the
problem.
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EXHIBIT 2-1 (continued)
SUMMARY OF ALTERNATIVES
Provide brief narrative description of alternatives evaluated in
detail during the CMS (may include engineering components,
treatment components, estimated present worth cost, implementation
time, and the major standards associated with the alternative (s)) .
EVALUATION OF THE PROPOSED REMEDY AND
• Introduce the evaluation criteria.
• Provide the rationale for the proposed remedy by profiling it
against the evaluation criteria and highlighting how it compares
with the other remedies.
• Discuss methods that will be used to monitor the remedy's
effectiveness .
• Discuss the how the proposed remedy will protect human health and
the environment.
HJBIJC PARTICIPATION*
• Describe previous or ongoing public participation activities and
how they impacted the remedy evaluation (if appropriate) .
• Provide notice of public comment period (written comments are
encouraged) .
• Note time and place for a public meeting(s) (if they are scheduled)
or offer opportunity for meeting.
• Provide the location of administrative record files and
information repositories and times that the record is available
for review (e.g. , 9-5 weekdays, or only upon appointment) .
• Name and phone number of person to contact for more information.
* Public includes the general public, the owner or operator, and
other parties (e.g. , public interest groups, other regulatory
agencies) .
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OSWER Directive 9902.6
2.4 SECTION BY SECTION DESCRIPTION OF THE STATEMENT OF BASIS
2.4.1
This introductory section should include the facility name and
location. The public should be informed of the function of the SB in the
remedy selection process, specifically, that its fourfold purpose is to:
• Identify the proposed remedy for corrective action at a facility and
explain the reasons for the proposal
• Describe the other remedial options considered in detail in the CMS
report
• Solicit public review of and comment on all remedial alternatives,
including those not previously studied
• Provide information on how the public can be involved in the remedy
selection process.
A clear statement should be made that the SB highlights key information
from the RFI and CMS reports but is not a substitute for these documents. The
SB should refer the reader to the RFI and CMS reports and administrative
record as more complete sources of information regarding the corrective
action. The first section of the SB should stress that public input on all
alternatives, and on the information that supports the alternatives, is an
important contribution to the remedy selection process. The public should be
encouraged to submit comments and should be informed that their comments can
influence the regulatory agency's proposal. The point should be made that the
final corrective action plan, as presented in the final permit modification or
corrective action order and RTC, could be different from the proposed remedy,
depending upon new information or an argument that the regulatory agency may
consider as a result of public comments.
2.4.2 PROPOSED REMEDY
The proposed remedy should be identified. Further discussion of the
proposed remedy in terms of the decision criteria should be included in the
"Evaluation of Alternatives" section of the SB.
2.4.3 FACILITY BACKGROUND
The facility background should include a facility map depicting the
facility's location and the areas of concern. This section should also
include a brief description of the facility, including the history of waste
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OSWER Directive 9902.6
generation, management, treatment, storage, and/or disposal that has taken
place, the major contaminants of concern, the contaminated media, and the
extent of contamination.
2.4.4 SUMMARY OF FACULTY RISKS
Although performing a risk assessment (RA) is not a requirement of the
corrective action process, it is strongly recommended that a RA be conducted
as a part of the RFI. The scope of the RA will depend on facility
characteristics. This section of the SB should summarize the extent of
contamination at the facility and the risks posed to human health and the
environment using information developed during the RFI. The summary of
facility risks should include key findings made in the baseline risk
assessment conducted as part of the RFI. This discussion should:
• Identify contaminated media
• Identify contaminants of concern
Describe exposure pathways (e.g., routes of exposure—ground water,
surface water, air, and soil)
• Describe the potentially exposed population
• Discuss environmental risks as appropriate (ecological receptors
potential exposures, and potential effects of exposures)
• Describe how current risks compare to remediation goals (the overall
remediation goal of 10~6 should be used as the point of departure in
situations where there are no existing standards, such as Mds).
The description of facility risks should not rely solely on standard
numeric risk representations (such as cancer risks of 10"3 or a hazard
quotient value of 22). These risk numbers should be accompanied by a
discussion that explains, for example, that a cancer risk level of 10"3 means
that one additional person out of a thousand is at risk of developing cancer
if the facility is not cleaned up. Similarly, for noncarcinogenic effects,
the discussion of the hazard quotient and hazard index should state that a
hazard quotient (the ratio of the level of exposure to an acceptable level)
greater than 1.0 indicates that the exposure level exceeds the protective
level for that particular chemical. If the hazard quotients for individual
chemicals are less than 1.0 but the sum of the hazard quotients for all
substances in an exposure medium (i.e., the hazard index) is greater than 1.0,
then there may be a concern for potential health effects.
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OSWER Directive 9902.6
In addition, for proposed remedies other than "no action," this section
of the SB should include a statement such as:
"Actual or threatened releases of hazardous constituents from
this facility, if not addressed by the proposed remedy or another
remedy, may present a current or potential threat to human health
and the environment."
2.4.5 SCOPE OF CORRECTIVE ACTION
This section of the SB should summarize the overall strategy for
remediating the facility and describe how the remedy being considered in the
SB fits into that overall strategy.
If the response is being carried out in a phased CMI plan, the purpose
of each phase and their sequence should be described. For example, the
following language could be included in this section:
"This is the second of three planned phases for the
facility. The first phase provided the community with an
alternate water supply to prevent ingestion of contaminated
ground water. This phase addresses remediation of the
contaminated ground water, one of the principal threats
posed by the facility. The third and final phase will
address the contaminated soil, which represents the source
of the ground water contamination which is the other
principal threat posed by the facility."
As the above example illustrates, the SB's description of the overall
facility strategy and the function of the proposed remedy should indicate how
and through what action or series of actions the principal threats posed by
the facility will be addressed. This section of the SB should help establish
the basis for the finding made in the RTC as to whether or not the selected
remedy is protective of human health and the environment.
2.4.6 SUMMARY OF AIITERNAnVES
The Summary of Alternatives section should provide a brief narrative of
the remedies studied in the detailed analysis phase of the CMS report. This
description may include the treatment technology(ies); engineering controls;
institutional controls; quantities of waste handled; implementation
requirements; estimated construction, operation, and maintenance costs; and
estimated implementation time frame associated with each remedy.
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OSWER Directive 9902.6
These descriptions also should incorporate the major standards
associated with each option. For example, standards associated with a source
control remedy, such as RCRA Subtitle C or D closure standards, should be
incorporated into the discussion, as appropriate. For treatment based
remedies, the standards associated with treating hazardous substances (e.g.,
RCRA land disposal restrictions, RCRA incineration standards in Subpart O,
Clean Air Act Standards, etc.) should also be described. Exhibit 2-2 lists
standards that may be discussed in describing the remedies.
2.4.7 EVALUATION OF THE PROPOSED REMEDY AND AIITERNATIVES
This section should begin by identifying the proposed remedy. Next,
the evaluation criteria used to evaluate the alternatives in the detailed
analysis in the CMS should be presented. The evaluation criteria encompass
four general standards and five corrective measure selection decision factors
that assist in gauging the overall effectiveness of the remedial alternatives.
Figure 1-2 presents information on the organization of the criteria and the
major points that should be considered under each criterion. The SB should
summarize all alternatives with respect to the applicable criteria. More
specifically, the SB should address the following elements with regard to the
proposed remedy:
• The section should include a description of the technical features
of the remedy. This description must be complete enough to enable a
reviewer to determine that it complies with the standards for
protectiveness, attainment of media cleanup standards, source
control, and waste management practices imposed on all
RCRA remedies.
• Media cleanup standards should be identified.
• The conditions that the owner or operator must fulfill to
demonstrate compliance with the media cleanup standards established
in the remedy selection process should be discussed. In addition,
any techniques that will be used to monitor the remedy's
effectiveness should also be discussed. For example, a modified
permit/enforcement order might require the owner or operator to
continue monitoring ground water over a set period after a cleanup
standard has been achieved to ensure that the level is not
subsequently exceeded. In addition, the permit/enforcement order
might discuss the cleanup standards that apply to the media
undergoing corrective action. Again, specific details on compliance
measurements might not be available at remedy selection, but would
be addressed through remedy design.
• Any procedures the owner or operator must follow to remove,
decontaminate, or close units or structures during remedy
implementation should be discussed, as well as any post-closure care
requirements that will be imposed.
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STANDARDS THAT MAY APPLY
TO RCRA OQRRBCnVE ACTIONS
• Safe Drinking Water Act (SDWA):
- Maximum Contaminant Levels (MCLs); and
- MCL Goals (MCLGs).
• Resource Conservation and Recovery Act (RCRA) Subtitle C
(Hazardous Waste Requirements):
- Closure (i.e., landfill or clean closure)
- Subpart F Ground Water Monitoring (including
post-closure care)
- Subpart X Miscellaneous Units
- Subpart AA Accelerated Air Emissions Standards
- location Standards
- Minimum Technology
- Subpart O Incineration
- Land Disposal Restrictions
- Unit-Specific Design and Operating Standards (e.g., for tanks,
containers)
- Part 261 - Identification and Listing of Hazardous Waste
- Part 262 - Standards Applicable to Generators of Hazardous
Waste
- Part 263 - Standards Applicable to Transporters of Hazardous
Waste
- Proposed Subpart S Corrective Action for Solid Waste Management
Units at Hazardous Waste Management Facilities.
• RCRA Subtitle D (Solid Waste Requirements).
Clean Water Act:
- Federal Water Quality Criteria (FWQC)
- Publicly-Owned Treatment Works (POTW) standards
- Effluent Limitations and Guidelines
- Requirements for Dredge and Fill Activities.
• Toxic Substances Control Act (TSCA):
- Polychlorinated biphenyls (PCB) Standards.
• Clean Air Act (CAA):
- National Ambient Air Quality Standards (NAAQS)
- State Implementation Plan (SIP).
• State Standards.
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OSWER Directive 9902.6
• This section should discuss the schedule for initiating and
cortpleting all major technical features and milestones of the
remedy.
The SB should use the evaluation criteria to profile the performance of
the proposed remedy. In addition, the proposed remedy should be briefly
compared to the other alternatives under the appropriate criteria.
The conclusion of this section of the SB should include a summary that
says, based on information currently available, the proposed remedy provides
the best balance of tradeoffs among the alternatives with respect to the
evaluation criteria. This section should state that the proposed remedy
satisfies the following criteria:
• Be protective of human health and the environment
• Control the sources of releases so as to reduce or eliminate, to the
maximum extent practicable, further releases that may pose a threat
to human health and the environment
• Attain the media cleanup standards
• Comply with applicable standards for management of wastes.
2.5 PUBLIC PARTICIPATION
The public should be informed of the following:
• Dates of the public comment period
• Date(s), time(s), and location(s) of the public meeting(s) scheduled
(offer to hold a meeting upon request if one has not been scheduled)
• Location of information repositories and administrative record
file(s), and hours of availability
• Names, phone numbers, and addresses of the regulatory agency
personnel who will receive comments or supply additional
information.
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OSWER Directive 9902.6
CHAPTER 3
THE NEWSPAPER NOnnCATICN OF PROPOSED CORRECTIVE ACTION
AND AVAILABILITY OF THE ADMINISTRATIVE RECORD
This chapter summarizes the guidelines for the newspaper notification,
which announces the availability of the SB, the RFI/CMS reports, the
administrative record, and, where applicable, the draft permit modification.
In addition, the newspaper notification presents guidance on procedures for
the public comment period.
3.1 PROCEDURES
Upon completion of the RFI and CMS, the agency should prepare a SB and
draft permit modification (where applicable) and notify the public of the
availability of the RFI/CMS reports, SB, draft permit modification (where
applicable), and administrative record. The following guidelines are
recommended:
• Publish a notice and brief analysis of the SB and make the
appropriate documents available to the public.
• Include sufficient information in the notice and analysis as may be
necessary to provide a reasonable explanation of the proposed remedy
and a list of the remedial alternatives analyzed during the CMS.
• Publication should include, at a minimum, publication in a major
local newspaper of general circulation. In addition, each item
developed, received, published, or made available to the public
should be available for public inspection and copying at or near the
facility or site where the corrective action is being considered.
Public libraries, schools, and county courthouses can be used to
house a copy of the administrative record when the facility is not
located in proximity to the regional or state office.
• In addition to English, publications should be printed in dominant
second languages where applicable.
For those facilities undertaking corrective action to satisfy permit
conditions, the agency must notify the public of the availability of the
RFI/CMS reports and the draft permit modification pursuant to 40 CFR Part
124.10.
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OSWER Directive 9902.6
3.2 WRITING THE NEWSPAPER NOTIFICATION
The agency's newspaper notification should include a brief abstract of
the SB, which describes the remedial alternatives analyzed during the CMS and
identifies the proposed remedy. The notice should be published in a widely
read section of the newspaper, rather than in the classified advertisements,
obituary section, or legal notices. Key elements of the notification are
summarized below.
3.2.1 SECTION BY SECTION DESCRIPTION OF THE NEWSPAPER NOTIFICATTON
Newspaper notifications of permit actions must be prepared in accordance
with 40 CFR Part 124.10(d). Exhibit 3-1 lists requirements for public notices
pursuant to 40 CFR Part 124.10 (d). Newspaper notifications prepared for a
facility undergoing corrective action under an enforcement order should also
discuss the specific items specified in 40 CFR 124.10(d). The elements listed
below provide an outline for the newspaper notification.
• Facility Name and Location. The notice should include the proper
facility name and location.
• The Date and Location of a Public Meeting (if scheduled). If a
meeting has not been requested or scheduled, the notice should inform
the public of its right to request one.
• Public Participation. The notice should inform the public of its
role in the remedy selection process and provide the following
information:
- The location of the information repositories and administrative
record
- The methods by which the public may submit comments
- The dates of the public comment period.
• Identification of Proposed Remedy. A brief statement of the major
components of the proposed remedy should be included.
• Alternatives Evaluated in the Detailed Analysis. The notice should
list corrective measure alternatives evaluated in the detailed
analysis phase of the CMS.
• Request for Public Comments. The notice should emphasize that the
agency is soliciting public comment on all of the corrective measure
alternatives, as well as on the proposed remedy. It should include a
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EXHIBIT 3-1
SUMMARY OF §124.10(d) HJBLEC NOTICE REQUIREMENTS
Public Notice Requiremgntg
124.10(d) (1) (i) Name and address of office processing permit action.
124.10(d)(1)(ii) Name and address of permit applicant.
124.10(d)(1)(iii) Brief description of facility activities.
124.10(d)(1)(iv) Name and address of agency contact.
124.10(d)(1)(v) Brief description of the comment procedures.
124.10(d) (1) (vi) The location and availability of the administrative
record.
124.10(d)(1)(ix) Any additional information considered necessary or
proper.
Public Notice Requirements for Hearings
124.10(d) (2) (i) Date of previous public notices relating to permit.
124.10(d)(2)(ii) Date, time, and place of hearing.
124.10(d)(2)(iii) Brief description of the nature of hearing.
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OSWER Directive 9902.6
clear statement that the proposed remedy is only a preliminary
determination and that other options could be selected as the remedy
based upon public comment, new information, or a reevaluation of
existing information. The readers should be referred to the RFI/CMS
report and other contents of the administrative record file for
further information on all of the remedial alternatives considered.
3.3 HJRT.TC OCMMENT PERIOD
The agency should provide a reasonable opportunity for submission of
written and/or oral comments and an opportunity for a public meeting regarding
the proposed remedy, the RFI/CMS reports or any information contained in the
administrative record for the draft permit modification or corrective action
order. Pursuant to 40 CFR 124.10(b), the agency must allow at least 45 days
for public comment on draft permit modifications. It is recommended that 30
to 45 days be allowed for public comment on the proposed remedy when the
corrective action is implemented through an enforcement order.
The agency should make the relevant documents available to the public at
the time the public comment period begins. In addition, the agency should
ensure that any factual information relied upon during the remedy selection
process is included as part of the administrative record and is available to
the public during the public comment period.
The agency is encouraged to respond to oral or written comments received
prior to the public comment period. However, the agency should inform
commenters that if they wish to ensure that comments submitted, before the
comment period receive an agency response, they should resubmit comments that
were initially made during the RFI/CMS process during the formal public
comment period. Written comments should be included in the administrative
record.
Agency personnel may find it useful to request that comments voiced
during public hearings also be submitted in writing at that time. This
practice will help the agency to respond to the comments at a later date
should an immediate response not be available.
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OSWER Directive 9902.6
CHAPTER 4
ELEMENTS OF THE FINAL DECISION AND RESPONSE TO COMMENTS
4.1 INTRODUCTION
A RTC is prepared by the regulatory agency at the conclusion of the
public comment period. The RTC should include a brief summary of comments
received during the public comment period as well as activities (e.g., public
meetings) undertaken by the regulatory agency. The summary should respond to
comments and discuss, where applicable:
Identification of the selected remedy
• Any changes made to the proposed remedy due to comments
• Rationale for not selecting an alternate remedy or making revisions
to the selected remedy as suggested by a commenter(s)
How the selected remedy differs from the community or owner or
operator's proposed remedy
• Any alternatives recommended that were not evaluated in the CMS and
why they were not included.
4.2 FURPOSE OF THE RESPONSE TO COMMENTS
The RTC serves several purposes. First, the RTC identifies the selected
remedy. Second, it provides the regulatory agency decision makers with
information about community preferences regarding the remedial alternatives,
and general concerns about the facility. Third, it demonstrates how public
comments were integrated into the decision making process. Fourth, the ETC
provides a contemporaneous written record of the regulatory agency's RTC.
This will enable a court, or any interested party reviewing the selected
remedy, to determine whether the regulatory agency provided a reasonable RTC
in the record. An adequate RTC is essential in defending final permit
modifications or orders during remedy implementation negotiations or in
judicial proceedings.
To serve these purposes, the RTC should be a concise and complete
summary of comments received from the public, including the owner or operator,
during the public comment period. The comments should be accompanied by the
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OSWER Directive 9902.6
regulatory agency's responses. Responses should be clear, accurate, and
carefully written. Exhibit 4-1 presents an outline that may be used to draft
the RTC.
The RTC is prepared for the signature of the Regional Administrator (RA)
or the signatory of the document that is implementing the corrective action
(e.g., corrective action order or permit modification). The final permit
modification should be accompanied by the RTC. If the selected remedy differs
from the proposed remedy as discussed in the SB, the final permit modification
or order will reflect such changes. These changes should be specified and
explained in the RTC (refer to 40 CFR 124.17(a) (1) for permit modifications).
In the event that comments are not submitted during or prior to the
public comment period, nor is a public hearing requested, a RTC should still
be prepared. In such cases, the RTC will present the selected remedy, state
that comments were not submitted, and include a declaration that the selected
remedy is protective of human health and the environment.
4.3 WRITING THE RESPONSE TO COMMENTS
The RTC should:
Identify the selected remedy (ies), talcing into account the comments
received during the public comment period
Identify comments raised during the public comment period
• Respond to public comments
Discuss any future actions that will accompany the implementation of
the selected remedy.
Additional guidance on preparing the RTC is available in "Guidance on
Public Involvement in the RCRA Permitting Program," (OSWER Directive
9500.00-1A, January 1986).
4.4 SECTION BY SECTION DESCRIPTION OF THE RESPONSE TO COMMENTS
4.4.1 INTRODUCTION
This introductory section should include the facility name and location.
The public should be informed of the function of the RTC in the remedy
selection process. Most importantly, this section should clearly explain how
the regulatory agency considered and responded to the comments received.
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EXHIBIT 4-1
FINAL DECISION AND RESPONSE TO COMMENTS
[FACILITY NAME]
INTRODUCTION
The RTC documents for the public record:
Concerns and issues raised during corrective action planning
• Comments raised during the comment period on the proposed remedy,
RFI, or CMS
• How the regulatory agency considered and responded to these
concerns.
Briefly discuss:
The remedy (ies) selected for implementation at the facility
• Brief justification to support the selection of the corrective
measure (s) using the evaluation criteria.
TTTRT.TQ PARTICIPATION AC1'1V1T1>'S
Briefly discuss:
• Activities conducted by the regulatory agency to elicit public
participation and to address specific concerns and issues (e.g. ,
small group meeting, news conference, and progress reports)
The extent of the public comment period, when it started and ended
• Note whether regulatory agency staff met with concerned citizens
or conducted other communication activities during the comment
period, such as a public meeting or availability of technical
staff to respond to questions. Mention the location, time, and
level of attendance of public meeting (s) , if held.
PUBLIC COMMENTS AND THE AGENCY'S RESPONSE
Briefly describe comments on the proposed remedy, RFI, or CMS from
other regulatory agencies, local officials, and private citizens.
Comments should be immediately followed by the regulatory agency's
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EXHIBIT 4-1 (Continued)
response. This section should address the following (where applicable):
Categorize comments by major issue or topic addressed, where
appropriate.
Provide a verbatim list of the comments received, each followed by
the regulatory agency's response. Where necessary, the comments
and responses can be summarized under the categories as completely
as possible.
Discuss the level of concern over each of the major issues.
Document any modifications or changes in the proposed remedy as a
result of comments.
Give the reasons for rejecting the public's, or owner's, or
operator's proposed remedy if the regulatory agency's selected
remedy is different.
Document, in detail, any remedial alternatives provided by the
public which were not evaluated in the CMS, and explain why they
were not evaluated.
FUTURE ACTIONS
Briefly explain:
Any future actions the regulatory agency will take as an integral
part of remedy implementation (e.g., post-closure permitting,
closure plan approval).
DECLARATIONS
This section should state that the regulatory agency has determined
that the corrective action being taken is appropriate and will be
protective of human health and the environment. The section should
conclude with the signature of the RA, or other person deemed appropriate
by the regulatory agency, and the date the document was signed.
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OSWER Directive 9902.6
4.4.2 SELECTED REMEDY
This section of the RTC should identify and summarize the major
treatment components of the selected remedy, as well as any engineering
controls or institutional controls that will be part of the remedy. This
section should also describe how the selected remedy will provide adequate
protection of human health and the environment. The evaluation criteria used
to select and justify the remedy should be discussed in this section.
4.4.3 PUBLIC PARTICIPATION ACTIVITIES
The communication activities undertaken by the regulatory agency during
the public comment period should be identified in this section. This section
should also identify when the public comment period was in effect, and
where/when public meetings or gatherings were held.
4.4.4 COMMENTS RAISED DURING THE COMMENT PERIOD AND THE AGENCY'S RESPONSE
Comments received, followed by the regulatory agency's response, should
be listed in this section. Where necessary, comments and the regulatory
agency's response can be categorized by major issue and topic addressed. The
level of concern over each major issue and the extent that this issue was
raised should also be included in this section.
Information furnished by the public or other regulatory agencies may
provide the basis for making a significant change to the proposed remedy.
Changes to the proposed remedy resulting from the comments received or the
receipt of new information should be fully documented. It is important that
the regulatory agency respond to all significant comments. This section
should also reference any new supporting information placed into the
administrative record in response to comments. In addition, any remedial
alternatives provided by the public which were not evaluated in the CMS should
be discussed to the extent that information is available. If the changes made
are major, the regulatory agency should consider the need for additional
notice and opportunity to comment. Additional comment opportunities are
particularly appropriate if information obtained after the SB was prepared is
relied upon to change or select another remedy.
4.4.5 FUTURE ACTIONS
This section of the RTC should briefly discuss any future action the
regulatory agency will take as an integral part of remedy implementation
(post-closure permitting, closure plan approval). The opportunity for public
participation for future actions should be made available.
4.4.6 DECLARATIONS
This section should provide the final declaration that the selected
remedy is protective of human health and the environment. This section also
provides the space for the RA or other person deemed appropriate by the
regulatory agency, to concur with the selected remedy. Generally, the person
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OSWER Directive 9902.6
that signs the document implementing the corrective action (e.g., permit
modification or enforcement order) should sign the ETC.
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OSWER Directive 9902.6
CHAPTER 5
DOCUMENTING LIMITED SCOPE REMEDIAL ACTIONS
AND (XNTINGENCY REMEDY DECISIONS
This chapter presents guidance on preparing the SB for two unique types
of corrective action:
Limited scope remedial actions
Contingency remedies.
This chapter defines these decisions and outlines the modifications that
should be made to the standard SB format described in Chapter 2 when
documenting limited scope remedial actions or contingency remedies.
5.1 DOCUMENTING A "LIMITED SCOPE REMEDIAL ACTION" DECISION
The regulatory agency may determine that limited scope remedial action
is appropriate at a facility due to limited available technologies, site
conditions, or the nature of the contamination at the site. For example, it
is possible that the process of remediating a wetland would result in greater
environmental harm than if the contamination were left in place. Another
possible example is the situation where the removal of the contamination, such
as white phosphorus submerged in an estuary, would be technologically
infeasible, due to the risks to the workers, the community, and the
environment that would result from the use of current technology.
When a "limited scope remedial action" is implemented, some assurance
that exposure pathways are restricted is needed. Any "limited scope remedial
action" should be accompanied by assurance that the public is restricted from
being exposed to the hazardous situation. The SB should discuss all actions
that will be taken to protect the public from exposure. For example, the SB
may propose that bottled water will be supplied to the public and the public
drinking water wells be restricted from use.
5.2 DECISION DOCUMENTS WITH CONTINGENCY REMEDIES
In general, the regulatory agency identifies the proposed remedy in the
SB and the draft permit modification (where applicable) and selects the remedy
to be implemented in the final permit modification or order and accompanying
KTC.
There are limited situations, however, in which additional flexibility
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OSWER Directive 9902.6
may be required to ensure implementation of the most appropriate remedy at a
facility. In such situations, the regulatory agency may determine that a
permit modification or order with a selected remedy accompanied by a
contingency remedy is appropriate.
Ihis option serves two purposes. The first is to promote the use of
innovative technologies. An innovative treatment technology may appear to be
the most appropriate remedy for a facility during the CMS but more testing is
needed during design to verify the technology's expected performance
potential. If there are uncertainties about an innovative treatment
technology, then the regulatory agency may elect to include a proven
technology as a contingency remedy in the SB and draft permit modification
(where applicable). The second situation that may be appropriate for
contingency remedies is where two different technologies under consideration
appear to offer comparable performance on the basis of the decision factors,
such that both could be argued to provide the "best balance of tradeoffs."
Under such circumstances, the SB may identify one as the proposed remedy and
the other as a contingency remedy and specify the criteria whereby the
contingency remedy would be implemented.
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OSWER Directive 9902.6
CHAPTER 6
EXAMPLE STATEMENT OF BASIS
6.1 EXAMPLE STATEMENT OF BASIS
The following is an example of a SB which follows the standard format
presented in Chapter 2. The model facility is imaginary and any similarity
with an actual facility is purely coincidental.
EIO INDUSTRIAL COMPANY
Nameless, Tennessee
INTRODUdTC^
This SB for the EIO Industrial Company explains the proposed remedy for
cleaning up the contaminated soils and explains the reasons for this proposal
identified in the draft permit modification or proposed corrective action
order, if applicable. In addition, the SB includes summaries of other
remedies analyzed for this facility. EPA will select a final remedy for the
facility only after the public comment period has ended and the information
submitted during this time has been reviewed and considered.
EPA is issuing this SB as part of its public participation
responsibilities under RCRA.
This document summarizes information that can be found in greater detail
in the RFI and CMS reports and other documents contained in the administrative
record for this facility. EPA and the State encourage the public to review
these other documents in order to gain a more comprehensive understanding of
the facility and RCRA activities that have been conducted there.
EPA may modify the proposed remedy or select another remedy based on new
information or public comments. Therefore, the public is encouraged to review
and comment on all alternatives. The public can be involved in the remedy
selection process by reviewing the documents contained in the administrative
record file and attending the public meeting scheduled for June 22, 1990.
PROPOSED REMEDY
The U.S. EPA [or state agency] is proposing the following remedy to
address the contaminated media at the EIO facility:
- Excavate 7,500 yd3 of contaminated soils
- Employ a low temperature volatilization step to capture the highly
mobile Volatile Organic Constituents (VOCs)
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OSWER Directive 9902.6
- Stabilize soils
- Dispose of treated soil onsite in a capped unit.
A more detailed discussion of the proposed remedy is included below.
FACILITY BACKGROUND
In 1947, the EIO Industrial Company began disposing of septic waste at
its plant located at 129 Franklin Street in Nameless, Tennessee (see Figure
6-1). In the late 1960s, the company also began to accept shipments of
hazardous waste. Wastes were stored in 13 storage tanks in the 5-acre tank
farm area. The wastes subsequently were pumped to seven unlined lagoons. The
site ceased operation in August 1987, and is currently in the closure process.
During facility operations, soils at the tank farm area were
contaminated by wastes spilled during pumping and from leaking tanks.
Although the lagoons were emptied and backfilled with clean soil by the EIO
Industrial Company in 1981, the subsurface soils in the 5-acre lagoon area
were contaminated. In addition, both the municipal well, located a mile from
the facility, and several residential wells, located within a half mile, have
been contaminated by wastes from the facility.
Between 1986 and 1988, the EIO Industrial Company conducted an RFI and a
CMS pursuant to permit conditions/enforcement order. They were conducted to
identify the types, quantities, and locations of contaminants and to develop
ways of addressing the contamination problems. The results of these studies
are as follows:
• Onsite surface soils in the former lagoon and tank farm area are
contaminated with varying levels of lead, chromium, and cadmium
• Onsite subsurface soils in the former lagoon and tank farm area are
contaminated with trichloroethylene (TCE), other chlorinated
aliphatic and polynuclear aromatic hydrocarbons, and lead
• A nearby municipal well is contaminated
• A plume of contaminated ground water extends from the site to the XYZ
River.
SUMMARY OF FACILITY RISKS
During the RFI, an analysis was conducted to estimate the health or
environmental problems that could result if the soil contamination at the EIO
facility was not cleaned up. This analysis is commonly referred to as a
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'Closed Lagoons \x\v
Area N^
Ground
Water Flow
£222 TCE-Contarninated Soil
KS^^H Metals-Contaminated Soil
D Private Wells
Facility Boundary
Municipal Well
Figure 6-1: EIO Industrial Company Facility And
Surroundings
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OSWER Directive 9902.6
baseline risk assessment. In conducting this assessment, the focus was on
direct ingestion of the soil by a child playing in the area. The analysis
focused on the major contaminant of concern, TCE. TCE is a volatile organic
compound that is known to cause cancer in laboratory animals and thus is
classified as a carcinogen. TCE is a highly mobile contaminant that typically
migrates through the soil into the ground water.
Sampling of the soil at the facility found that the average
concentration of TCE in the soils was 140 parts per million. This
concentration level is associated with an excess lifetime cancer risk of 10"3.
This means that if no cleanup action is taken by EPA, one additional person
per one thousand has a chance of contracting cancer as a result of the
exposure to TCE-contaminated soil. This estimate was developed by taking into
account various conservative assumptions about the length and quantity of
exposure endured by a person and the toxicity of TCE.
EPA and the State have determined that in cleaning up the contaminated
soil at the EIO facility to a concentration of 13 ppm of TCE, the excess
lifetime cancer risk posed by the facility following remediation will be
reduced to 10 . This cleanup target would reduce the probability of
contracting cancer as a result of exposure to the contaminants in the soil to
one additional person in one million. Because there are no Federal or State
cleanup standards for contamination in soil, this cleanup target was
established for this site as part of the risk assessment conducted during the
RFI. The cleanup target was established to reduce direct contact exposure to
an acceptable level, as well as to ensure that the migration of the TCE into
the ground water is minimized.
Actual or threatened releases of hazardous constituents from this
facility, if not addressed by the proposed remedy or one of the other remedies
considered, may present a current or potential threat to human health and the
environment.
SCOPE OF CORRECTIVE ACTION
The problems at the EIO facility are complex. As a result, EPA has
divided the work into three manageable phases. These are as follows:
• Phase One: Remediation of Contamination in the municipal well.
• Phase Two: Remediation of Contamination of the ground water
aquifer.
• Phase Three: Remediation of Contamination in the soils.
EPA has already selected remedies for Phases One and Two (the municipal
well and the contaminated ground water) as noticed in the July, 1989 (permit
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OSWER Directive 9902.6
modification/order) and accompanying ETC. The contaminated ground water is a
principal threat at this site because of the potential for direct ingestion of
contaminants through drinking water wells. Both of the actions for Biases One
and Two are in the CMI stage, which means that the engineers are developing
specific plans for implementation of the remedy. Actual construction is
planned for March 1991.
The third phase addresses the contaminated soils in the lagoon and tank
farm area. This contiguous area was determined to be a principal threat at
the site because of the potential threat of direct contact with the soils and
the soil's impact on ground water. The cleanup objectives for this phase are
to prevent current or future exposure to the contaminated soils through
treatment and/or containment, and to reduce the migration of contaminants from
the soil to ground water.
SUMMARY OF AT.TFRNATTVES
The alternatives analyzed for Phase Three are presented below. These
are numbered to correspond with the numbers in the CMS Report. The
alternatives for the soil cleanup are the following:
• Alternative 1: No Action.
• Alternative 2: Capping.
• Alternative 3: Excavation, Treatment of Volatile Organic Compounds in
a Vaporization loop, Lime Stabilization of Soils,
Capping, and Disposal Onsite.
• Alternative 4: Excavation and Off site Thermal Destruction.
• Alternative 5: Excavation, Onsite Thermal Destruction, and
Solidification.
EIO has calculated the following costs associated with each alternative
and ttoe time needed for implementation:1
Capital Annual Operational & Present Months to
Alternative OostfSl Maintenance Costsf$) Worthf$) Complete
1 00 00
2 740,485 18,120 910,260 5
3 4,666,000 41,000 5,050,150 12-15
4 39,056,421 26,200 39,301,905 36-72
5 42,463,300 26,200 42,708,780 30
These numbers are purely hypothetical and do. not represent
Agency determinations of remedial cost.
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OSWER Directive 9902.6
Alternative 1:
NO ACTION
The "no action" alternative is often evaluated to establish a baseline for
comparison. Under this alternative, EPA would take no further action at the
site to prevent exposure to the soil contamination.
Alternative 2:
CAPPING
The contaminated soil would be left in place and a 24-inch compacted cap
would be installed over the entire 10 acres of contaminated surface soils in
the tank farm and lagoon areas. The cap would be designed to meet the RCRA
landfill closure standards in 40 CFR 264.310, which, among other things,
specify that the permeability of the cap must be less than or equal to the
permeability of the natural underlying soils at the facility.
Alternative 3:
EXCAVATION, VOLATILIZATION, STABILIZATION, AND DISPOSAL ONSITE
The 7,500 yd3 of VOC-contaminated soils from the tank farm and lagoon area
would be excavated. To remove the highly mobile VOCs, a low temperature
volatilization step would be inserted into the cleanup process between
excavation and landfilling. Granular activated carbon (GAC) canisters would
separate the volatile contaminants from the soils leaving only the less mobile
organic and metal compounds in the soil to be landfilled onsite. All
contaminants subject to the Land Disposal Restrictions will be treated to the
treatment standards specified in 40 CFR 268. Approximately 99 percent of the
VOCs would be removed by this treatment process. The used carbon canisters
would be shipped offsite to be regenerated.
The treated soils would then be returned to the lagoon and tank farm area
and stabilized with the 3,500 yd3 of metal-contaminated soils not previously
excavated. The lagoon and tank farm area would be regraded and revegetated
and capped in accordance with the standards for RCRA landfill closure in 40
CFR 264.310.
Alternative 4:
EXCAVATION AND OFFSITE THERMAL DESTRUCTION
All 11,000 yd3 'of contaminated soils would be excavated, transported, and
destroyed in an offsite thermal destruction unit. This thermal destruction
process would address the VOCs in the soil; however, metals would remain in
the ash and would require proper disposal. The excavation process would leave
the site "clean," requiring no long-term management controls. The off site
thermal destruction unit would comply with technical standards for
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OSWER Directive 9902.6
incinerators, which include stack scrubbers and other recovery mechanisms to
ensure that no untreated hazardous substances are released into the
environment. The incinerator would destroy 99.99 percent of the VDCs in the
contaminated soils. The resulting ash would be properly handled and disposed
of by the operators of the thermal destruction unit.
Alternative 5:
EXCAVATION, ONSITE THERMAL DESTRUCTION, AND SOLIDIFICATTON
A mobile, thermal destruction unit would be brought to the site, and
11,000 ydr of contaminated soils would be excavated and destroyed onsite.
This thermal destruction process would address the VDCs, but the metals in the
soils would remain in the ash. The onsite thermal destruction unit would
comply with technical standards for incinerators. Off-gases and scrubber
wastes from the thermal destruction unit would be collected and properly
disposed. This incinerator would destroy 99.99 percent of the VOCs in the
soil. Residual metals and ash would be solidified and disposed of off site in
a RCPA Subtitle C facility.
EVALUATION OF THE PROPOSED REMFny ANT> ALTERNATIVES
The proposed remedy for cleaning up the soils (the source control phase)
at the EIO facility is Alternative 3—Excavation, Volatilization,
Stabilization, and Onsite Disposal in a capped unit. This section profiles
the performance of the proposed remedy against the four general standards and
the five remedy decision factors, noting how it compares to the other options
under consideration.
1. Overall Protection. All of the alternatives, with the exception of the
"no action" alternative, would provide adequate protection of human
health and the environment by eliminating, reducing, or controlling risk
through treatment, engineering controls, or institutional controls. The
proposed remedy would treat the volatile organic contaminants in the
soils, stabilize the remaining wastes, and cap the remaining residuals
to reduce the risks associated with direct contact and minimize the
migration of contamination from the ground water.
Because the "no action" alternative is not protective of human health
and the environment, it is not considered further in this analysis as an
option for this facility.
2- Attainment of Media Cleanup Standards. All alternatives would meet
their respective media cleanup standards of Federal and State
environmental laws. Because the proposed remedy would involve the
excavation and placement of hazardous waste, compliance with all
applicable land disposal restrictions (LDR) standards must be ensured.
3- Controlling the Sources of Releases. All of the alternatives would be
effective in reducing, to the maximum extent practicable, further
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OSWER Directive 9902.6
releases of contaminants to the ground water, surface water, air, and
other soils. Ihe proposed remedy would remove the VDC contamination in
the soils through volatilization and control the release of metals by
stabilization.
4. Compliance with Waste Management Standards. Alternatives 3, 4, and 5,
which involve soil excavation and either treatment or off site disposal,
would comply with the applicable requirements for the management of
solid waste. This would assure that the management of wastes is
conducted in a protective manner.
5. long-term Reliability and Effectiveness. The proposed remedy would
reduce the inherent hazards posed by the volatile organic exsnpounds in
the contaminated soils. Ihe treated soils would still be contaminated
with other organic and metal compounds; however, the long-term risks of
exposure to the remaining contaminants in the soils would be reduced by
stabilizing and sealing the soils in the capped area, which would
prevent migration of the contaminants to ground water, surface water,
air, and other soils. A ground water monitoring system would be
installed around the lagoon and tank farm area to assess the
effectiveness of the treatment and disposal in the closed area.
Alternatives 4 and 5 would permanently destroy most of the organic soil
contamination (TCE, Polynuclear Aromatic Hydrocarbons (PAHs)). The ash
generated by the thermal destruction units, however, would be
contaminated by those metal compounds not destroyed by this process.
Under Alternative 4, the ash would be disposed of in an off site landfill
to protect against risks of future human contact. Under Alternative 5,
the contaminated ash would be solidified to prevent the possibility of
human contact. The solidified waste would be disposed of off site in a
RCRA Subtitle C landfill.
Alternative 5 would remove all waste to a permitted, offsite landfill,
thereby eliminating the long-term risks of exposure at the EIO facility.
The cap that would be implemented in Alternative 2 would provide
long-term reductions in the amount of water that otherwise would pass
through the contaminated soils. This would reduce the generation of
contaminated leachate that could migrate to the ground water. Because
the highly mobile VDCs will not be treated, the contaminated soils that
constitute a principal threat would remain at the facility and would
pose potential long-term risks of exposure. The cap's effectiveness
would be evaluated through long-term monitoring. The cap would require
long-term maintenance, and portions of it might need to be replaced in
the future.
6. Reduction of Toxicitv. Mobility, or Volume of Wastes. Only three of the
alternatives would treat the wastes to reduce the toxicity, mobility, or
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OSWER Directive 9902.6
volume of the organics. Alternative 3 would involve treatment of the
most mobile cxjntaminants, the volatile organic ocrapounds. The treated
soils would still be contaminated with less mobile organic and metal
compounds. These soils would be stabilized with the metal-contaminated
soils in the lagoon and tank farm area and the area would then be
capped.
Alternatives 4 and 5 both would involve incineration processes that
would permanently destroy the organic osntaioinants. The contaminated
ash would be disposed of in a RCRA landfill. Alternative 2 achieves no
reduction in toxicity, mobility, or volume.
7. Short-term Effectiveness. Alternative 3 would contain the treated soils
and reduce the possibility of direct human contact with contaminants
more quickly than all the other alternatives, except Alternative 2
(i.e., capping). Under the proposed remedy, once the volatile organic
ccmpounds have been collected in canisters, there is some minor,
short-term risk of exposure to the community during transportation of
the canisters to a treatment facility. All of the alternatives that
include excavation would pose some short-term risks of exposure to VOCs
during the excavation process.
Because the capacity of onsite and off site thermal destruction units is
limited under Alternatives 4 and 5, contaminated soils would be
stockpiled for up to 6 years. Under these two alternatives, the risks
of direct contact with stockpiled, contaminated soils would be increased
until incineration has been completed because of dust. In addition,
there are some risks of exposure to air emissions from the incinerators
and the piles.
8. Implementability. Alternative 2 has few associated administrative
difficulties that could delay implementation. Alternatives 3, 4, and 5
must recognize and comply with lERs. The long-term monitoring that
would be required to establish the continued viability of the proposed
remedy would be less extensive than would be necessary for Alternative
2. The activated carbon canisters that are part of the vaporization
step used in the proposed remedy are available in the area. In
contrast, there is uncertainty about the availability of adequate
capacity at an off site incinerator. This could lead to delays of up to
6 years in implementing Alternative 4. Because there is only one mobile
incinerator that could be used at the site, the implementation of
Alternative 5 may take over 2 years to complete.
9. Post. The present worth cost of the proposed remedy is $5,050,150. The
lowest cost alternative is Alternative 2 at $910,260. The highest cost
alternative is Alternative 5 at $42,708,780. Alternative 4 has a cost
of $39,301,905.
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OSWER Directive 9902.6
In summary, Alternative 3 would achieve substantial risk reduction
through treatment of the principal threat remaining at the facility (i.e., the
mobile lagoon waste) and by providing for the safe management of other
material that will remain at the facility. Alternative 3 achieves this risk
reduction more quickly than any of the other treatment options. Based on
information currently available, the proposed remedy provides the best balance
of tradeoffs among the alternatives with respect to the evaluation criteria.
EPA and the State of Tennessee believe that the proposed remedy would be
protective of human health and the environment; attain media cleanup standards
consistent with those proposed under 40 CFR 264.525(d) and (e); control the
sources of releases so as to reduce or eliminate to the maximum extent
practicable, further releases; and comply with applicable standards for
management of waste.
PUBLIC PARTICIPATION
EPA solicits input from the community on the cleanup methods proposed
under each of the previous alternatives. The public is also invited to
provide comment on remedial alternatives not addressed in the CMS. EPA has
set a public comment period from June 22 through August 22, 1990, to encourage
public participation in the selection process. The comment period includes a
public meeting at which EPA will present the SB (and draft permit
modification), answer questions, and accept both oral and written comments.
The public meeting is scheduled for 7:30 p.m., June 22, 1990, and will
be held at the Nameless Community Hall, 123 Market Road, in Nameless,
Tennessee.
The administrative record is available at the following locations:
Nameless Public Library
125 Elm Street
Nameless, TN 00000
(101) 999-1099
Hours: Mon-Sat, 9 a.m. - 9 p.m.
and
U.S. EPA Docket Room, Region IV
Federal Building, 10th Floor
Atlanta, GA
(555) 555-1212
Hours: Mbn-Fri, 8:30 a.m. - 4:30 p.m.
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OSWER Directive 9902.6
Comments will be summarized and responses provided in the Response to
Comments. The Response to Comments will be drafted at the conclusion of the
public comment period and incorporated into the administrative record. To
send written comments or obtain further information, contact:
Jane Doe
Community Relations Coordinator
U.S. Environmental Protection Agency
123 Peachtree Street, Atlanta, GA 00000
(555) 555-4640. Toll-free 1 (800) 333-1515
between 8:30 a.m. and 4:30 p.m. (Monday - Friday)
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OSWER Directive 9902.6
CHAPTER 7
EXAMPLE FINAL DECISION AND RESPONSE TO COMMENTS
7.1 EXAMPLE RESPONSE TO COMMENTS
The following is an example of a RTC following the standard format for a
ETC that was presented in Chapter 4. As previously noted, the model facility
is an imaginary facility and is the same facility for which the Example SB was
written.
EIO INDUSTRIAL COMPANY
Nameless, Tennessee
INTRODUCTION
This RTC is being presented by the U.S. EPA. The purpose of the RTC is
to identify the selected remedy, present concerns and issues raised during the
public comment period, and provide responses. All of the comments received
were carefully reviewed during the final selection of the remedy, and have
been answered in this RTC. No additional alternatives were raised that were
not considered in the CMS and the proposed remedy was not altered as a result
of public comments.
The selected remedy for the contaminated soil at this facility is
excavation, volatilization of organics, stabilization, and onsite disposal.
The 7,500 yd3 of VOC-contaminated soils from the tank farm and lagoon area
will be excavated. A low temperature thermal desorption unit will be used to
remove the highly mobile VOCs. The off -gas from this unit will be passed
through GAG canisters to remove the VOCs to meet air discharge requirements.
This treated soil will then be stabilized to immobilize the less mobile
organic and metal compounds. This treatment is expected to meet applicable
land disposal restrictions. The remaining 3,500 yd3 of metal-contaminated
soils will be excavated and also treated by stabilization. The 11,000 yd3 of
stabilized soil will be placed back into the tank farm and lagoon area. This
area will be regraded, revegetated, and capped in accordance with the
standards for RCRA landfill closure in 40 CFR 264.310. A ground water
monitoring system will be installed around the facility to ensure the
long-term effectiveness of the treatment method.
All of the proposed remedies initially screened in the CMS, with the
exception of the "no action" alternative, would provide adequate protection of
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OSWER Directive 9902.6
human health and the environment by eliminating, reducing, or controlling risk
through treatment, engineering controls, or institutional controls. However,
the selected remedy will achieve site remediation more quickly (12 to 15
months) than any of the other proposed remedies. (Alternative 2—cap
installation, would take less time than the selected remedy. However, it was
not chosen because it would not provide as much long-term reliability and
effectiveness, and would not reduce the toxicity, mobility, or volume of the
waste.) The selected remedy will be reliable and effective over the long-term
by reducing the inherent hazards posed by the volatile organic compounds in
the contaminated soils. The remaining organic and metal contamination will be
treated by stabilization thereby reducing the mobility of the contaminants.
Although Alternatives 4 (excavation and offsite thermal destruction) and 5
(excavation, onsite thermal destruction, and solidification) would provide
comparable long-term reliability and effectiveness, they were not selected due
to the increased risk of direct contact with stockpiled, contaminated soil.
The selected remedy provides the best balance among the alternatives with
respect to the evaluation criteria, including:
• long-term reliability and effectiveness
• Reduction of toxicity, mobility, or volume of waste
• Short-term effectiveness
• Implementability
• Cost.
PUBLIC PARTICIPATION ACTIVITIES
A public comment period was set from June 22 through August 22, 1990. A
public meeting was held on June 22, 1990 at the Nameless Community Hall, 123
Market Road, in Nameless, Tennessee. The meeting was attended by a total of
23 people, including representatives of EPA, the Tennessee Pollution Control
Board, the local government, and citizens. A number of comments were raised
and are presented below.
COMMENTS RAISED AND THE AGENCY'S RESPONSE
Concern:
Citizens were concerned as to when the cleanup activities would begin.
Response:
The EIO Industrial company is a complex site with both soil and ground
water contamination. Therefore, EPA has divided the corrective action into
three phases. The three phases are for correcting contamination in the
municipal well, the ground water aquifer, and the soils. EPA has already
selected remedies for Phases One and Two (the municipal well and the
contaminated ground water). A RTC for Phases One and Two was completed in
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OSWER Directive 9902.6
July, 1989. Construction for these two phases is planned for March 1991. CMI
for Phase Three (soil contamination) is expected to begin in September 1991.
Concern:
Representatives of the local government reported that they found
contamination in another of their municipal wells (well #9) located
approximately 5 miles downgradient of the facility. They stated that the
contamination was similar to that found at the EIO Industrial Company.
They requested that the facility provide financial assistance to the local
government for remediation of well #9.
Response:
The administrative record contains no evidence of any spill or
industrial activity near well #9 that would link the EIO Industrial Company
with the chemicals contaminating well #9. Also, according to the RFI report,
the contaminated ground water plume only extends 1 mile downgradient of the
facility (refer to Figure 7-1). However, EPA will initiate an investigation
of this new area of contamination.
Concern:
Citizens voiced concerns regarding the possibility that excavation of
the contaminated soil during the CMI process will create dust emissions that
may endanger the community.
Response:
An EPA representative reported that the dust emissions created are not
expected to be carried by wind as far as the local community, 1 mile from the
excavation area. Continuous air monitors will be set up to ensure that dust
levels are maintained at acceptable levels during excavation. If dust
emissions exceed acceptable levels the work will be stopped until those
conditions abate. It was also noted that the risk of dust emissions was
associated with four of the six alternatives suggested in the CMS due to soil
excavation.
Concern:
The panel was asked to explain the stabilization process.
Response:
Following soil excavation and treatment by volatilization of organics,
the contaminated soil will be stabilized. The soil will be mixed with the
stabilization compounds (examples are cement, lime, and flyash), and placed
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Y///A TCE-Contaminated Soil
INSNN Metals-Contaminated Soil
D Private Wells
m Contaminated Ground Water Plume
Facility Boundary
Municipal Well
Figure 7-1: EIO Industrial Company
Facility And Surroundings Showing Contaminated Ground
Water Plume
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OSWER Directive 9902.6
into monolith sections in the lagoon and tank farm areas. A treatability
study will be performed prior to onsite stabilization to determine the optimum
stabilization mixture for the EIO Industrial Company soil. The technology
will not result in the destruction of the contaminants, however, it will
result in permanent reduction of mobility or toxicity of the contaminants.
The volume of the soils will be increased as a result of stabilization. The
optimum stabilization mixture will provide a reduction in mobility of the
contaminants in excess of 95 percent.
Concern:
Citizens raised concerns regarding the cancer risk associated with
leaving the treated waste onsite following volatilization and stabilization.
Response:
The selected remedy must meet applicable environmental standards, to
protective of human health and the environment, and be reliable and
implementable. The selected remedy was chosen by evaluating these criteria.
It was determined during the evaluation process that the significantly higher
cost associated with offsite disposal of the soil would not provide a
proportionally greater benefit in terms of being protective of human health
and the environment. The estimates of increased lifetime cancer risks made
during the CMS were performed using conservative models and based on a worst
case scenario. The selected remedy is expected to meet standards and to be
protective of human health and the environment.
The public has not requested that a remedy other than the proposed
remedy be implemented at the EIO facility. No modifications or changes to the
selected remedy were made as a result of the public comments.
HJTORE ACTIONS
To determine whether specific cxmmunity concerns arise during the CMI
process, information will be provided to the public through press releases or
other appropriate means, such as additional public meetings.
DEdARATIONS
Based on the administrative record compiled for this corrective action,
I have determined that the selected remedy to be ordered at this site (or in
the permit modification for this site) is appropriate and will be protective
of human health and the environment.
EPA Regional Administrator
Date
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OSWER Directive 9902.6
CHAPTER 8
BIBLIOGRAPHY
"Carcinogenic Risk Assessment," 51 Federal Register (FR) 33932, September 24,
1986.
"CERCXA Compliance with Other Laws Manual," OSWER Directive 9234.1-01, August
1988.
"Chemical, Physical and Biological Properties of Compounds Present at
Hazardous Waste Sites," EPA/OWPE, September 1985.
"Community Relations in Superfund: A Handbook," OSWER Directive 9230.0-3B,
June 1988.
"Construction Quality Assurance for Hazardous Waste Land Disposal Facilities,"
EPA/530-SW-85-031, July 1986.
"Corrective Action for Solid Waste Management Units at Hazardous Waste
Management Facilities; Proposed Rule," 55 FR 30798, July 27, 1990.
"Exposure Assessment," 51 FR 34042, September 1986.
"Guidance for Conducting Remedial Investigations and Feasibility Studies Under
CERdA," OSWER Directive 5355.3-01, October 1988.
"Guidance on Administrative Records for RCRA 3008(h) Actions," OSWER Directive
9940.4, July 1989.
"Guidance on Public Involvement in the RCRA Permitting Program," OSWER
Directive 9500.00-1A, January 1986.
"Guidance on Remedial Actions for Contaminated Ground Water at Superfund
Sites," OSWER Directive 9283.1-2, December 1988.
"Guidelines for the Health Risk Assessment of Chemical Mixtures," 51 FR 34014.
"The Health Assessment of Suspect Developmental Toxicants," 51 FR 34028,
September 1986.
"The Health Risk Assessment of Chemical Mixtures," 51 FR 34014, September 24,
1986.
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OSWER Directive 9902.6
"Interim Final Guidance on Preparing Superfund Decision Documents," OSWER
Directive 9355.3-02, June 1989.
"Interim Final RCRA Facility Investigation (RFI) Guidance," OSWER Directive
9502.00-6D, EPA 530/SW-89-031, May 1989.
"Methods for Chemical Analysis of Water and Waste," EPA-600/4-79-020, March
1979.
"Mutagenicity Risk Assessment," 51 FR 34006, September 24, 1986.
"National Oil and Hazardous Substances Pollution Contingency Plan; Proposed
Rule," FR, December 21, 1988.
"RCRA Corrective Action Plan - Interim Final," OSWER Directive 9902.3,
EPA/530-SW-88-028, June 1988.
"RCRA Ground Water Monitoring Technical Enforcement Guidance Document, Final,"
EPA/OWPE, September 1986.
"Remedial Action at Waste Disposal Sites (Revised)," EPA/625/6-85/006, 1985.
"Risk Assessment Guidance for Superfund," Volume 1: Human Health Evaluation
Manual (Part A), Interim Final (EPA, December 1989 - EPA/540/1-89/002).
"Superfund Federal-Lead Remedial Project Management Handbook," OSWER Directive
9355.1-1, December 1986.
Superfund Program; Part 1. Public Health Risk Assessment and Part 2.
Ecological Risk Assessment (EPA 901/5/89-001, June 1989).
"Superfund Remedial Design and Remedial Action Guidance," OSWER Directive
9355.0-4A, June 1986.
"Test Methods for Evaluating Solid Waste, Physical/Chemical Methods," Third
Edition, November 1986.
"Toxicology Handbook - Principles Related to Hazardous Waste Site
Investigations," EPA/OWPE, August 1985.
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