r/EPA
United States
Environmental Protection
Agency
Office of Emergency and
Remedial Response
(5204G)
EPA 540-R-97-001
OSWER 9220.0-24
PB97-963201
January 1997
Superfund
National Remedy Review Board
Progress Report:
Fiscal Year 1996
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National Remedy Review Board
Progress Report:
Fiscal Year 1996
U.S Enviror.msnt?! Prot^'on Agency
Refjo" 0, iib,ao<(pL-12j)
77 West Jacfcsor. boulevard, 12th Floor
Chicago, IL 60604-3590
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Additional copies of this document can be obtained from:
The National Technical Information Service (NTIS)
U.S. Department of Commerce
5285 Port Royal Road
Springfield, VA 22161
Phone number: (703) 487-4600
You can view or download this document at the following
Internet address: http://www.epa.gov/superfnd/
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TABLE OF CONTENTS
Introduction 1
EPA's Superfund Reforms 1
The National Remedy Review Board 2
Summary of Fiscal Year 1996 Accomplishments 4
Board Reviews 4
Year-End Assessment 7
Operating Improvements 8
FY96 Operating Costs and FY97 Cost Projections 9
Conclusion '. 9
Attachments:
Attachment 1
11/28/95 EPA Memorandum: "Formation of the National
Superfund Remedy Review Board"
Attachment 2
National Remedy Review Board Members
Attachment 3
Chart Depicting Board Review Timing for High Cost Cleanups
in the Superfund Site Remediation Process
Attachment 4
Role of Interested Parties in the Review Process
Attachment 5
Full Text of National Remedy Review Board Advisory Recommendations
Publicly Available as of November 1996
Attachment 6
9/26/96 EPA Memorandum: "National Superfund Remedy Review Board"
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Introduction
EPA created the National Remedy Review Board (the Board) in January 1996 as
part of a comprehensive package of reforms designed to make the Superfund program
faster, fairer, and more efficient. This report highlights the Board's significant
accomplishments in its first year of operation. It also presents information intended to
help those interested in the Board's work learn more about the review process, its
contribution to the Superfund program, and how interested parties can contribute to
review efforts.
In the next section we describe the Superfund reform initiative and explain how
the Board contributes to its goals. The following sections present information on the
Board's first year of operation, its effect on Superfund cleanups, and resource issues.
Included as attachments to this report are several EPA documents and memoranda that
provide detailed information about Board operating procedures, cleanup decision reviews,
and other issues.
EPA's Superfund Reforms
The Superfund program is one of our country's most ambitious and complex
environmental programs. It arose out of the need to protect citizens from the dangers
posed by abandoned or uncontrolled hazardous waste sites. When CERCLA1 (the
Superfund law) was enacted, the challenge of cleaning up what was assumed to be a few
hundred discrete, land-based cleanups appeared relatively straightforward. However, the
problem of neglected hazardous waste sites has revealed itself to be far more complicated
and widespread than anyone at first realized.
We now recognize that the number and complexity of hazardous waste sites across
the nation dwarf original estimates. To date, EPA has identified more than 41,000 sites
and assessed more than 39,000 of them. Almost 1,400 of these sites have been
considered a serious enough threat to be designated a Federal priority for cleanup on the
National Priorities List (NPL). EPA has completed construction of all cleanup activity at
about thirty percent (410) of these. The vast majority of the remaining NPL sites are
either under study or being cleaned up.
In addition, Superfund has conducted emergency responses and prompt removal
actions to attack the most immediate threats of toxic exposure at more than 3,000 sites in
Superfund is authorized by the Comprehensive Environmental Response, Compensation, and Liability
Act (CERCLA), as amended. 42 U.S.C. §9601 et. seq. The program's principal implementing regulation is the
National Oil and Hazardous Substances Pollution Contingency Plan, also known as the NCP, 40 CFR Part 300.
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communities across the country. Through these "emergency response" actions, EPA
continues to protect public health and the environment from immediate risks.
As a logical outgrowth of EPA's experience in managing the Superfund program,
EPA has put in place a series of Superfund reforms. These reforms substantively change
the way the Superfund program handles its cleanup responsibilities within existing laws.
They are aimed at accelerating the pace and reducing the cost of cleanups, streamlining
remedy selection, increasing fairness, promoting economic redevelopment, and better
integrating Federal and State cleanup programs. Within these changes, however,
remedies are preferred that incorporate treatment technologies and provide long-term
reliability for site cleanup. The Agency believes these reforms will save cleanup dollars
without sacrificing public health or environmental protection. In October 1995, EPA
announced its final round of reforms. One of the principal reforms in this final round is
the National Remedy Review Board.
The National Remedy Review Board
Assistant Administrator Elliott Laws announced the Board's formation in a
November 28, 1995, memorandum to Regional Waste Management Division Directors
(attachment 1). As stated in the memorandum, the Board's goals are to promote cost-
effectiveness and national consistency in remedy selection at Superfund sites. To
accomplish this, EPA staffed the Board with technical experts and senior managers from
each EPA Region and several EPA Headquarters offices. This group of experienced
personnel provides a unique and impartial audience with which to discuss cleanup
strategies, issues of national consistency, and the cost-effectiveness of cleanup actions.
The Board analyzes proposed site-specific cleanup strategies in "real time" to ensure that
they are consistent with the Superfund law, regulations, and relevant agency guidance.
Attachment 2 presents a list of Board members.
The Board reviews all proposed cleanup decisions where (1) the proposed action
costs more than $30 million; or (2) the proposed action costs more than $10 million and
this cost is 50% greater than that of the least-costly, protective cleanup alternative that
also complies with other laws or regulations that are "applicable" or "relevant and
appropriate" to a site decision or action.
The Board plans to review sites early in the remedy selection process, before the
Region releases the proposed plan for public comment. Occasionally, however, a post-
proposed plan site may benefit from Board review. For example, remedy changes in
response to public comment may increase the total remedy costs. Where these additional
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cleanup costs exceed 20 percent of the original cost estimate and trigger normal Board
review criteria, the Board may review the draft remedy. Please see attachment 3 for a
depiction of the various steps in the Superfund remedial process and where Board review
occurs.
National Remedy Review Board Process
The EPA remedial project manager (RPM) in charge of the site develops an informational
site package that forms the basis of Board review. The package presents basic site
information as well as technical information on exposure and risk assessment scenarios,
cleanup goals, and cost estimates for various cleanup alternatives.
The Region consults with key State/Tribe decision makers to guarantee State/Tribe
concerns are conveyed accurately and completely in the package.
The RPM also solicits information from PRPs who conduct remedial
investigation/feasibility studies (RI/FS) and community representatives. Their
submissions are included as attachments to the informational site package.
Each site decision discussion is divided into two phases: an information sharing phase,
to which State/Tribe representatives are routinely invited, and a deliberative phase. The
Board will invite the State/Tribe to participate in the deliberative discussion for
State/Tribe-lead Fund-financed decisions, and for State/Tribe enforcement-lead decisions
where the State/Tribe seeks EPA concurrence. Otherwise, the Board limits its deliberative
discussions to EPA personnel.
Shortly after each review, the Board sends any advisory recommendations to the
appropriate Regional Division Director in a brief memorandum.
After its review, the Board issues advisory recommendations as to how or whether
a potential Superfund site remedy decision can be improved. The recommendations are
not binding, but EPA Regional decision makers give them substantial consideration.
Although this effort is a valuable enhancement to the current decision making process, it
is important to remember that this reform does not change current delegation of
authorities or diminish hi any way the public's current role in site cleanup decisions.
Please refer to attachment 4 of this document for a more detailed explanation of the role
of interested parties in the review process.
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Summary of Fiscal Year 1996 Accomplishments
Fiscal year 1996 has been a challenging but very productive year. Below are some
of the Board's significant accomplishments in its initial year of operation.
• Developed the Board's mission, identified key technical experts and managers, and
began deliberative operations within eight weeks of the formal announcement from
Assistant Administrator Elliott Laws.
• Held deliberative meetings in January, March, May, June, and August.
• Reviewed each of 12 proposed Regional Superfund decisions that triggered Board
review criteria.
• Issued substantive or technical recommendations for nine of the 12 decisions
reviewed. These recommendations are expected to increase the cost effectiveness
of the decision by strengthening overall cleanup strategies. The Board supported
without substantive comment three of the proposed actions.
• Contributed to improved national consistency in Superfund remedy selection.
• Recommended analyses that may ultimately reduce total cleanup costs for all sites
reviewed in fiscal year 1996 by as much as $15 million to $30 million (please see
next page for further explanation).
• Contributed to an enhanced role in Superfund remedy selection for States/Tribes,
private parties, and communities at high stakes sites.
• Confirmed that, overall, the Superfund program is making sound, cost effective,
remedy decisions that are consistent with the Superfund law, its regulations, and
guidance.
Board Reviews
Of the 12 proposed cleanup decisions submitted by EPA Regional offices for
review, the Board fully supported three decisions with only minor recommendations. Of
the remaining nine, the Board generally supported, with technical recommendations,
another three decisions. For six decisions, the Board offered more substantive
recommendations. In all cases, the Regions will conduct analyses to decide whether and
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to what extent the reviews may ultimately affect their cleanup approaches. For a
summary of characteristics for all decisions reviewed in 1996 see Table 1.
Although several Regions are still considering Board comments on proposed
decisions, already the Agency is encouraged by the range of benefits observed from the
review process, including improved national consistency, clarity of decisions, and cross-
Regional communication on key remedy selection issues. In some cases review
recommendations have contributed to much lower site cleanup costs. For example, in
Region 8, Board advisory recommendations regarding management of low-level threats at
the Petrochem/Ecotek site contributed to an estimated reduction in total cleanup costs of
approximately $8 million.
What Does The Board Look At
When It Reviews A Site Decision?
The Board analyzes the cleanup strategy to ensure that it is consistent with the Superfund law and
the National Oil and Hazardous Substances Pollution Contingency Plan (or NCP). The NCP is the
Federal regulation that details procedures for responding to oil or hazardous substance releases.
The Board also considers relevant EPA cleanup guidance.
When they review a site, the Board members ask many questions about the proposed cleanup
strategy. Site-specific circumstances nearly always influence the nature of the discussion. Among
others, Board members investigate subjects like these below:
• What are the site characteristics that present a threat to human health and the environment?
• What is the rationale behind exposure scenarios and risk assumptions?
• What are the details of the Regional proposal for site cleanup?
• Are the cleanup goals appropriate and attainable?
• Have other approaches to achieve the cleanup goals been evaluated?
• Are the cost estimates reasonable?
• What are the concerns of the States/Tribes, PRPs, and communities?
• Is the strategy consistent with other Agency decisions?
At the Jack's Creek site hi Region 3, Board discussion of principal threats may
ultimately reduce soil cleanup costs at the site by as much as $10 million to $15 million.
EPA expects additional cost reductions in the future from other fiscal year 1996 reviews.
Overall, the Board members indicate potential cost reductions in the range of $15 million
to $30 million in total site cleanup costs from reviews conducted this fiscal year.
Of course, cost reductions are only part of the story. By targeting sites for review
early in the Superfund process ~ in most cases before proposed plan issuance ~ important
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sites benefit from the Board's expertise and discussion before EPA site managers make
key decisions in the final remedy, reducing the potential for revising the cleanup
strategies later in the process. Moreover, cost reductions do not reflect the value of
benefits that come from a general increase in scrutiny of cleanup costs, increased national
consistency in remedy selection, improved technical analysis of promising cleanup
strategies, better-articulated decision rationale at high stakes sites, and increased
confidence of Agency staff and stakeholders in the final remedy.
In addition, the review process has stimulated cross-Regional dialogue on a broad
range of issues that affect sites other than the high-cost sites. For example, the Jack's
Creek review exposed the fact that although most EPA Regions used a particular model to
assist in calculating adult lead exposure, several did not. Because the Board members
communicate the lessons learned from their reviews within and across the Regions,
project managers at a site in Dallas, Texas, realized that they might also use the model.
As a result, they were able to adjust lead cleanup goals and potentially save a significant
amount of money while improving overall program consistency.
Attachment 5 provides the full text of publicly available Board recommendations
as of November 1, 1996.
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TABLE 1: FY96 BOARD REVIEW SUMMARY
Site and Region
Fernald(OU5),R5
Petrochem, R8
Operating Industries,
Incorporated, R9
Fernald (OU3), R5
Coieman Evans, R4
Petroleum Products, R4
DuPont Necco Park, R2
Roebling Steel, R2
Jack's Creek, R3
Harbor Island
Sediments (OU2), RIO
New Brighton Arden
Hills, R5
New Bedford Harbor,
Rl
Review
Date
January
January
January
March
May
May
May
June
June
August
August
August
Decision
Stage at Review
Post PP
Post PP
PrePP
PrePP
Post PP
PrePP
PrePP
PrePP
PrePP
Post PP
PrePP
PrePP
Nature of Recommendations
Fully Support*
Substantive*
Fully support*
Fully support
w/ minor comment*
Substantive
Substantive
Technical*
Technical*
Substantive*
Substantive
Substantive
Technical*
Decision
Stage as of
9/30/96
ROD signed
ROD signed
ROD signed
ROD signed
Pending
Pending
PP issued
ROD signed
Pending
Pending
Pending
Pending
Key: OU=6perable unit, R=Region, PP=proposed plan, ROD=record of decision
Asterisk indicates that the Board review memorandum for this site is publicly available as of November 1996, and
is contained in attachment 5. Please consult the appropriate Regional Board member for the status of the remaining
memoranda.
Year-End Assessment
To assess its overall performance in fiscal year 1996, the Board conducted an in-
depth analysis of its effect on individual site decisions. In interviews with Regional staff
who participated in the reviews, Board members addressed subjects such as the effects of
the reviews on site cleanups; how the reviews affected management involvement in site
decisions; and whether the reviews improved remedy consistency, remedy protectiveness,
or cost effectiveness. They also discussed ways to improve the review process.
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Overall, participants found the experience a positive and worthwhile contribution
to the remedy selection process for their respective sites. Generally, these Regional staff
believe the process improves national consistency on important issues, adds credibility to
Regional decisions, and can identify money-saving alternatives the initial Regional
analyses did not consider. On the other hand, Regional staff expressed some frustration
with the workload the review process places on them. They also raised concerns about
the potential for delays in cases where reviews raise fundamental questions. Summarized
below are responses from the Regional review participants to general questions about the
Board's effect on the cleanup decisions.
• The reviews did not affect the cleanup schedules for most of the proposed
decisions.
• Overall, the prospect of Board review increased Regional management
involvement in the proposed decisions. It also resulted, in some cases, in
management interest at an earlier point in the decision making process than would
have occurred otherwise.
• Some participants see a benefit for the Regions in that Board reviews and
subsequent advisory recommendations add credibility to final Regional decisions
since these decisions will have had the added benefit of additional independent
technical review.
Operating Improvements
EPA recognizes that the Board's operating protocol need to reflect a meaningful
role for parties with a stake in the review process. With this in mind the Board made a
substantial investment early on to work with interested parties and understand their
concerns. For example, States/Tribes felt strongly that since they work closely with EPA
in developing proposed cleanup strategies the Board discussions would benefit from the
State perspective. The Board agreed, and has adopted procedures to ensure significant
State/Tribe involvement in the review process. In addition, PRPs and community
advocates sought to guarantee that their interests would be accurately and completely
conveyed in materials reviewed by the Board. In response to this concern the Board
decided to solicit written technical comments from key PRPs and community groups.
Attachment 4 describes in greater detail the role of interested parties in the review
process.
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As a result of the Board's dialogue with interested parties EPA issued a September
26, 1996, memorandum titled "National Superfund Remedy Review Board" that
formalizes refinements in the Board's operating protocol (see Attachment 6). These
refinements reflect the concerns of interested parties as well as EPA Regional project
managers. Among other things, they will ensure: 1) timely review of proposed site
decisions prior to the issuance of the proposed plans; 2) prompt notification of key private
sector stakeholders, States/Tribes, recognized community groups and technical assistance
grantees, and other Federal agencies; 3) thorough consideration of stakeholder concerns
in the review discussions; and 4) a continuing dialogue with interested parties to assure
that the Board process is agreeable and fair to all involved.
FY96 Operating Costs and FY97 Cost Projections
EPA estimates that fiscal year 1996 Board activities cost approximately $523,250.
These estimates include salary and expense monies for Board members, Board support
staff, and Regional management/RPMs; travel to and from the Board meetings; and
incidental costs (e.g., fees for meeting rooms). These costs average out to approximately
$43,600 per decision reviewed by the Board.
In fiscal year 1997 the Board will likely review between 10 and 20 sites. Based on
the 1996 average of approximately $43,600 per decision and a five percent inflation rate,
the Board will require between $450,000 to $900,000 for salaries, expenses, and travel.
Conclusion
This past fiscal year was a challenging one for the entire Agency. Government
shutdowns and funding uncertainty disrupted site cleanups and increased the workload on
both Headquarters and Regional EPA staff. Even so, the National Remedy Review Board
accomplished a great deal. The hard work of the Board members and strong support of
Regional management and staff has paid off in significant cost savings, improved national
consistency, more robust decision analysis, and an enhanced role in the remedy selection
process for States/Tribes, private parties, and communities at high stakes sites.
Overall, the Board believes its reviews confirm that the Superfund program is
making sound, cost effective, remedy decisions that are protecting public health and the
environment consistent with CERCLA, its regulations, and guidance. At the same time,
the experience of the past year has shown that there are instances in which the
management level, cross-Regional Board discussions can save money and add value both
to proposed cleanup strategies and to program decision making as a whole. As the
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Superfund program continues its work in the coming years, it remains important for EPA
to provide both the public and Congress the assurance that Superfund remedies are both
cost effective and protective of public health and the environment. The Board believes it
has made important contributions to these goals in fiscal year 1996 and looks forward to
similar success in the coming year.
Attachments:
1) 11/28/95 EPA Memorandum: "Formation of the National Superfund Remedy
Review Board"
2) National Remedy Review Board Members
3) Chart Depicting Board Review Timing for High Cost Cleanups in the Superfund
Site Remediation Process
4) Role of Interested Parties in the Review Process
5) Full Text of Publicly Available National Remedy Review Board Advisory
Recommendations
6) 9/26/96 EPA Memorandum: "National Superfund Remedy Review Board"
10
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ATTACHMENT 1
*
11/28/95 EPA Memorandum:
"Formation of the
National Superfund Remedy Review Board
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
NOV 28 1995
OFFICE OF
SOLID WAS*; AND EMERGENCY
RESPONSE
MEMORANDUM
SUBJECT: Formation of .Jationa
FROM:
Elliott P. Law,
Assistant -Admi
TO:
fund Remedy Review Board
Director, Office of Site Remediation and Restoration
Region I
Director, Emergency and Remedial Response Division
Region II
Director, Hazardous Waste Management Division
Region III, IX
Director, Waste Management Division
Region IV
Director, Superfund Division
Region V, VI, VII
Assistant Regional Administrator, Office of Ecosystems
Protection and Remediation
Region VIII
Director, Environmental Cleanup Office
Region X
PURPOSE
This memorandum requests your assistance in establishing the
National Superfund Remedy Review Board recently announced by the
Administrator as one of the key Superfund Administrative Reforms.
This Review Board is intended to help control remedy costs and to
promote both consistent and cost-effective decisions at Superfund
sites, including federal facilities.
BACKGROUND
As you all know, cost plays an important role in Superfund
response decisions. The statute, in fact, mandates that, in
addition to being protective, all remedies must be cost-
effective. This mandate is built into the remedy selection
process established under the National Contingency Plan (NCP),
and expanded upon in a number of related program guidances. In
this year of greatly reduced budgets, it is even more important
for us to focus on this criterion in our decision making, On
October 2, 1995, EPA Administrator Carol Browner announced a
Recycled/Recyclable
<""\ Printed wltfi Soy/Canola Ink on paper thai
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collection of Administrative Reforms intended to help our program
achieve significant cost savings without compromising a remedy's
protection of human health or the environment or reliability.
Today, as one of these Reforms, I am announcing the formation of
the National Superfund Remedy Review Board.
DISCUSSION
By establishing this Board, I intend to help control remedy
costs by providing a cross -Regional management -level review of
high cost (and thus, potentially controversial) decisions in
"real time" on a site-specific basis.
Board Struct" -re an i Ft'- J
This national Review Board will be comprised of senior
Agency managers or experts on remedy selection, cost
effectiveness, and program implementation from both the Regions
and Headquarters. Each Region will have one management -level
representative on the Board. Headquarters representatives will
include national experts from the Federal Facilities Restoration
and Reuse Office, the Technology Innovation Office, the Office of
General Counsel, ORD's National Risk Management Research
Laboratory, and the Office of Emergency and Remedial Response
(OERR) . Other Offices may be requested to participate as the
need arises. The Board will be chaired by Bruce Means, Senior
Process Manager for Response Decisions in OERR.
All proposed cleanup actions at sites where: (1) estimated
costs for the preferred alternative are over $30M; or (2)
proposed remedy costs are over $10M and 50% greater than the
costs of the least -costly, protective, ARAR-compliant remedy will
be subject to the Board's review. As other cost control "rules
of thumb" are developed (under a separate Administrative Reform) ,
these "guides" may also be used to signal the need for this
Board's review. My overall expectation, based on previous ROD
history, is that this program should result in Board review of
approximately 10% of FY96 actions.
The Review Board will consider the nature of the site, the
risks posed by the site, regional and state/tribal opinions on
proposed actions, the quality and reasonableness of the cost
estimates, and ai y other relevant factors or program guidances in
making "advisory recomntendat ions" to the Regional Administrator
regarding EPA's preferred remedy before a proposed plan is issued
for public comment. The overall goal of the reviews will be to
ensure sound decision making consistent with current law,
regulations, and guidance. The Board's reviews will be performed
quickly but will require advanced planning by the Region to
account for the added review time. Remedies subject to Board
review should be brought to the Board's attention as soon as the
Region has identified them as likely 'preferred alternatives, '
but in any case before the proposed plan is announced for public
comment . Regions are encouraged to coordinate with OERR Regional
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Service Center Coordinators as early as possible in the process .
Especially since we are operating under a greatly reduced
budget this year, I am sensitive to the likely increase in
workload for you and your staff. This new Board will require
additional work for us all and may briefly delay release of a
small number of proposed plans by about two months. For these
reasons, the Board will work to establish a review process that
requires a minimum of. travel and effort for Board participants.
The Board is likely to form standing subgroups, based upon
geography, expertise or workload. Reviews are likely to involve
the faxing of relevant materials to subgroup (s) for discussion by
conference call after a brief review period. Details will be
developed further as part of the Board's initial organizing
discussions.
The Board is expected to be fully operational by January
1996. However, proposed remedies planned for issuance in the
first quarter of FY ' 96 which meet the screening criteria noted
above should also be discussed with my office.
Key Messages
By establishing this Board, I want to encourage decision
makers to think even harder about the costs of response actions
at every Superfund site.
However, this effort does not change the Agency's delegation
authorities or alter in any way the public's current role in site
decisions. This current effort is intended to facilitate the
application of our national program's extensive experience to a
select number of "high stakes" and thus, potentially
controversial site decisions.
IMPLEMENTATION
If you have not already done so, please send your
nominations for Board membership by December 8, to Bruce Means at
(703) 603-8815; FAX: (703) 603-9103; Mail code- (5204G) . We
have already welcomed the nominations of Walter Graham (Region
3), Wendy Carney (Region 5), Bill Honker (Region 6), and Wa"ne
Pierre (Region 10) . Bruce will be contacting your represent-
atives shortly to schedule an introductory conference call later
this month. For your information, Attachments A and B present an
overview of the Board's tentative start up schedule and
membership, respectively. I expect the Board to be up and
running by the bggiitfiing of January 1996.
I recognize that this additional review for the sites that
exceed these cost control triggers may briefly delay the release
of proposed plans. However, it is critically important to the
Agency that we provide both the public and Congress the necessary
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assurances that Superfund dollars are being well spent. This
Board will do much to provide those assurances.
Thank you for your prompt attention to this important
matter.
Attachments
cc: Regional Administrators
Steve Herman, OECA
Bob Huggett, ORD
Jon Cannon, OGC
Romona Trovato, ORIA
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Attachment A
National Superfund Remedy Review Board
Tentative Start-Up Schedule
(11/20/95)
Oc tober/November
Analyze past RODs meeting trigger criteria to examine trends.
Issue memorandum to Regions announcing the Board kickoff.
Complete membership list.
December
Initial meeting/conference call to introduce concepts, discuss
possible charter, operations/workflow models, roles.
Develop / revise charter; determine need for additional
Regional/HQ members/contacts.
January
Fully operational.
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Attachment B
National Superfund Remedy Review Board
Proposed Membership
(11/20/95)
Region 1
Region 2
Region 3
Region 4
Region 5
Region 6
Region 7
Region 8
Region 9
Region 10
TBD
John Frisco
Walter Graham
TBD
Wendy Carney
Bill Honker
TBD
TBD
TBD
Wayne Pierre
OERR - Bruce Means
ORD/National Risk Management Research Lab - TBD
FFRRO - Jim Woolford
OGC - TBD
OSWER/TIO - TBD
Other Offices may be invited to participate as needed.
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ATTACHMENT 2
•
National Remedy Review Board
Members
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NATIONAL REMEDY REVIEW BOARD
MEMBERSHIP
December, 1996
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
REGION
OERR
Region 1
Region 2
Region 3
Region 4
Region 5
Region 6
Region 7
Region 8
Region 9
Region 10
OERR
OERR/ERT
OGC
TIO
FFRRO
ORD/
NRMRL-Cin
ORIA
FPEO
ORD/
NRMRL-Ada
NAME
Bruce Means (Chair)
Richard Cavagnero
John Frisco
Walter Graham
Jan Rogers
Wendy Carney
Bill Honker
Craig Smith
Gwen Hooten
John Kemmerer
Wayne Pierre
Paul Nadeau
Andre' Zownir
Brian Grant
Mike Kosakowski
Tim Mott
Donald Sanning
Mike Boyd
Jean Rice
Clint Hall
PHONE
(703)603-8815
(617)573-9641
(212)637-4400
(215)566-3146
(404)562-8792
(312)353-6553
(214)665-6726
(913)551-7050 '
(303)312-6571
(415)744-2421
(206)553-7261
(703)603-8794
(908)321-6744
(202)260-6512
(703)603-7192
(202)260-2447
(513)569-7861
(202)233-9395
(202)564-2589
(405)436-8511
FAX
(703)603-9133
(617)573-9662
(212)637-4439
(215)566-3001
(404)562-8788.
(312)353-9306
(214)665-6660
(913)551-7145
(303)312-6897
(415)744-1917
(206)553-0957
(703)603-9133
(908)321-6724
(202)260-0584
(703)603-9135
(202)260-5646
(513)569-7620
(202)233-9650
(202)501-0069
(405)436-8528
NKKB Start Lead: Rich Norrzs (703-603-9053)
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ATTACHMENT 3
Chart Depicting Board Review Timing
for High Cost Cleanups in the
Superfund Site Remediation Process
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Board Review Timing for High Cost Cleanups
in the Superfund Site Remediation Process
Site
Discovery
Preliminary Assessment
Site Inspection
Expanded Site Inspection
Removal Evaluation
Hazard Ranking System
National Priorities List
Remedial Investigation
Feasibility Study
3Z
NATIONAL REMEDY
REVIEW BOARD
Proposed Plan
Selection of Remedy
Record of Decision
Remedial Design
Remedial Action
Construction Completion
NPL Deletion
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ATTACHMENT 4
Role of Interested Parties in the Review Process
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NATIONAL REMEDY REVIEW BOARD
ROLE OF INTERESTED PARTIES IN THE REVIEW PROCESS
The Agency has made noteworthy efforts to guarantee that concerns of States, Tribes, communities, and PRPs
are heard during the review process. EPA Headquarters management and several Board members attended a variety
of meetings this past year to help characterize and resolve concerns of those affected by the Board. EPA and State
representatives held a special meeting in June 1996 to discuss State concerns and options for their involvement in Board
activities. In addition, Agency managers participated in a meeting of the Information Network for Superfund
Settlements in May to discuss private party concerns with the Board's operation. EPA also met extensively with the
Federal departments that the Board's activities may affect.
As a result of these discussions, the Board has included in its operating procedures a clear and meaningful role
for affected groups: communities, States and Tribes, and key PRPs now all have an opportunity to present concerns
to the Board. From the beginning, stakeholders expressed great interest and enthusiasm for the Board in concept.
However, each group expressed practical concerns about how specific Board operating protocol might affect them.
Some of the more fundamental issues and related Board procedures are summarized below and are detailed in a
September 26, 1996, EPA memorandum (See attachment 5).
• States/Tribes felt strongly that, although they work closely with EPA in developing proposed cleanup
strategies, the Board discussions would benefit from the State perspective as "co-regulator." The Board
agreed, and has adopted procedures to ensure significant State/Tribe involvement in the review process. The
Region will consult with the affected State/Tribe well before the Board meeting to ensure the key State/Tribe
decision makers understand the nature and intent of the review process. The Region will also consult with key
State/Tribe decision makers when developing the informational site review package provided to all Board
members to guarantee State/Tribe concerns are conveyed accurately and completely. The State/Tribe will also
be given an opportunity to present their views to the Board at the review meeting.
• The Board will routinely invite State/Tribe decision makers to the information-gathering phase of its site
reviews. The Board will invite the State/Tribe to participate in the deliberative discussion for State-lead fund-
financed decisions, and for State/Tribe enforcement-lead decisions where the State/Tribe seeks EPA
concurrence. Otherwise, the Board will limit its deliberative discussion to Agency personnel.
• PRPs and community advocates sought to guarantee that their interests would be accurately and completely
conveyed in materials reviewed by the Board. In response to this concern the Board decided to solicit written
technical comments from key PRPs and community groups. These submissions are to be attached to the
informational site package provided to all Board members.
• Federal Facilities that deal with radioactive wastes or Base Realignment and Closure sites expressed concern
that the initial criteria for deciding which sites the Board would review were too stringent. They believed this
stringency would subject an unnecessarily large percentage of decisions to a lengthy Board review. The Board
recognized that Federal Facility sites often present different cleanup challenges and involve different
management and oversight frameworks. Therefore the Board, in coordination with EPA's Federal Facilities
Restoration and Reuse Office and its Federal Facilities Enforcement Office, has been working to establish
separate Federal Facility review criteria. The Board is using interim criteria until the final Federal Facility
criteria are adopted. These are outlined in the September 26, 1996, memorandum mentioned above. As the
Board gains experience reviewing Federal Facility sites it may re-evaluate these criteria.
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ATTACHMENT 5
Full Text of National Remedy Review Board
Advisory Recommendations Publicly Available
as of November 1996
Fernald OU5, Region 5
Petrochem, Region 8
Operating Industries, Inc., Region 9
Fernald OU3, Region 5
DuPont Necco Park, Region 2
Roebling Steel, Region 2
Jack's Creek, Region 3
New Bedford Harbor, Region 1
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY ml
! WASHINGTON, D.C. 20460 \f\ ,,m Q ' 1996
\
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or alter in any way the public's current role in site decisions. This Reform is intended to bring to
bear the program's extensive experience on decisions at a select number of high stakes sites.
NRRB Findings.
The NRRB reviewed relevant site information submitted on OU 5 for the Fernald
Environmental Management Project Site and discussed related issues with the EPA Regional
Remedial Project Manager on January 25, 1996. Based on this review and related discussion, the
NRRB finds the proposed remedy to be consistent with actions taken at similar sites in other EPA
Regions. Further, the NRRB finds that the proposed remedial action meets the requirements set
forth in the National Oil and Hazardous Substances Contingency Plan (NCP) and applicable
program guidance.
The Board members would like to thank Regional staff and management for their support
and participation in this review process. If you have any questions about these findings, please
call me at 703-603-8815.
cc: V. Adamkus
S.Luftig
E. Laws
T. Fields
J. Woolford
J. Breen
J. Clifford
P. Nadeau
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
30 1396
OFFICE Of
MEMORANDUM SOLID WASTE AND EMERGENCY
RESPONSE
SUBJECT: National Remedy Review Board Recommendations on the
Petrochem/Ekotek Superfund Site.
FROM: Bruce Means, Chairman
National Remedy Review Boa?
TO: Max Dodson, Assistant Regional Administrator
Office of Ecosystems Protection and Remediation
EPA Region 8
Purpose.
The purpose of this memorandum is to document the findings of the National Remedy
Review Board (NRRB) on the proposed remedial action for the Petrochem/Ekotek Superfund
Site in Utah.
Background.
As you recall, the NRRB was established as one of the October 1995 Superfund
Administrative Reforms to help control remedy costs and promote both consistent uid
cost-effective decisions at Superfund sites. All proposed cleanup actions are to be reviewed by
the Board where: (1) the estimated cost of the prefeired alternative exceeds S30M; or (2) the
preferred alternative costs ever $10 M and this cost is 50% greater than that of the lea*: -costly,
protective, ARAR-compliant alternative. In its review, the NRRB considers the nature and
complexity of the site; health and environmental risks; the range of alternative actions considered
to address site risks; the quality and reasonableness of the cost estimates for alternatives; regional,
State/tribal, and other stakeholder opinions on the proposed actions to the extent they are known
at the time of review; and any other relevant factors or program guidances.
Generally, th NRRB makes "advisory recommendations" to the appropriate Regional
decision maker prior to issuance of the proposed plan who is expected to give the Board's
recommendations substantial weight. However, otner important factors may influence the final
Regional decision such as subsequent public comment or technical analyses of remedial options.
It is important to remember that the NRRB does not change the Agency's delegation authorities
or alter in any way the public's current role in site decisions. This Reform is intended to bring to
bear the programs extensive experience on decisions at a select number of high stakes sites.
R«cyclod/R«cyeJabta • Primed wim Vegetable Oil Based Inns on 100% Recycled Paper (40% Posiconsumer)
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NRRB Findings.
The NRRB reviewed the proposed plan for the Petrochem/Ekotek site along with other
relevant site information and discussed related issues with the EPA Regional Project Manager
and State of Utah participants (J.D. Keetly, Project Manager, and Brad T. Johnson, CERCLA
Branch Manager) on January 31, 1996. Based on this review and discussion, the members of the
NRRB make the following observations:
The National Oil and Hazardous Substances Pollution Contingency Plan (NCP) sets forth
program expectations for the Agency in developing appropriate remedial alternatives. One such
expectation is to treat principal threats, wherever practicable. Another expectation is to contain
low level threats, because treatment for these wastes is likely not to be cost effective or
practicable. For many sites, the NCP further states that EPA expects to use a combination of
treatment and containment. While no exact definition of principal threat and low-level threat has
been provided, EPA has issued "A Guide to Principal Threat and Low Level Threat Wastes,"
which indicates that low level threats would include "low toxicity source material... soil
concentrations not greatly above reference dose levels or that present an excess cancer risk near
the acceptable risk range."
o Based on these NCP expectations and previous program experience, the NRRB fully
supports the proposed remedial approach for addressing light non-aqueous phase liquids
(LNAPLs), soil hot spots, and contaminated debris which constitute the principle threats at the
Petrochem site. The NRRB also fully supports the proposed approach for addressing
contaminated groundwater.
o However, based on the analysis of available information and slated discussions, as well as
other NCP expectations and Superfund program experience, the NRRB recommends the
following:
— The Region should reconsider the action proposed to address the low level contaminated
-soils at this site (i.e. thermal desorption). The Board believes that other approaches *o
remediating the threat of low level soil contamination, which could still fully satisfy the NCP, are
available at significantly lower cost.
— The Region should continue to work closely with the State, community and other
stakeholder. !o ccnsu'-r approaches taken at similar sites in other Regions, where low level soil
contamination laa been addressed through ofisite disposal at a SubtitL D facility, use of various
cover m*tfti*ii cnntainiuent, and/or land use contiols \,» deed restrictions. These alternative
approaches for addressing Superfund low level threats are fully protective of human healui and
the environment and allow for a wide range of recreational, commercial, or other beneficial uses.
— Notwithstanding the above comments, the NRRB also acknowledges that, overall, the
proposed approach is not inconsistent with the NCP remedy selection criteria. The Board further
recognizes that the Region must take into account the opinions of the community and the State in
making remedy selection decisions. Based on the information presented to the Board, it appears
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that in this case these two modifying criteria are the main drivers for the preference of a more
costly remedy.
The NRRB appreciates the extensive Regional efforts already made in working closely
with the State, community, and responsible parties to identify the currently proposed remedy.
However, the NRRB believes that the Region may benefit from considering other less costly
alternatives :hat address only the principal threats through treatment while yielding fully beneficial
property use with minimum restrictions
The Board members especially want to thank the Region and the State of Utah for their
participation in the review process. We encourage Region 8 management and staff to work with
the Regional NRRB representative and the OERR Region 3/8 Service Center at Headquarters to
discuss appropriate followup actions. If you have any questions, please do not hesitate to call me
at 703-603-8815.
cc: S. Luftig
E. Laws
T. Fields
J. Clifford
J. McGraw, Acting Regional Administrator
T. Sheckells, Region 3/8 Accelerated Response Center
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
MAY 30 1996
OFFICE OF
SOLID WASTE AND EMERGENCY
RESPONSE
MEMORANDUM
SUBJECT: National Remedy Review Board Findings on the Operating
Industries, Inc.
FROM: Bruce Means, Chairman
National Remedy Review Board
TO: Keith Takata, Director
Superfund Division
EPA Region 9
Purpose.
The purpose of this memorandum is to document the findings of the National Remedy
Review Board (NRRB) on the proposed final site-wide remedial action at the Operating
Industries, Inc. site in California.
Background.
As you recall, the NRRB was established as one of the October 1995 Superfund
Administrative Reforms to help control remedy costs and promote both consistent and
cost-effective decisions at Superfund sites. All proposed cleanup actions are to be icviewed by
the Board where: (1) the estimated cost of the preferred alternative exceeds $30M; or (2) the
preferred alternative costs over $10 M and this cost is 50% greater than that of the least-costly,
protective, ARAR-compliant alternative. In its review, the NRRB considers the nature and
complexity of the site; health and environmental risks; the range of alternative actions considered
to address c'»e risks; the quality and reasonableness of the cost estimates for alternatives; regional,
State/tribal, and other stakeholder opinions on the proposed actions to the extent they are known
at the time of i jview; and any other relevant favors or program guidances.
Generally, the NRRB makes "advisory recommendations" to the appropriate Regional
decision maker prior to issuance of the proposed plan who is expected to give the Board's
recommendations substantial weight. However, other important factors may influence the final
Regional decision such as subsequent public comment or technical analyses of remedial options.
Racycl*d/R*cyclabl« • Pnnlec wim Vegetable Oil Based Inks on 100% Recycled Paper (40% Posiconsumer)
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It is important to remember that the NKRB does not change the Agency's delegation authorities
or alter in any way the public's current role in site decisions. This Reform is intended to bring to
bear the program's extensive experience on decisions at a select number of high stakes sites.
NRRB Findings.
The NRRB reviewed relevant site information submitted on this site and discussed related
issues with both the EPA Regional and State Remedial Project Managers on January 31,1996.
Based on this review and related discussion, the NRRB finds the proposed site-wide remedy to
be consistent with actions at similar sites in other EPA Regions. Further, the NRRB finds that the
proposed remedial action meets requirements set forth in the National Oil and Hazardous
Substances Contingency Plan (NCP) and applicable program guidance.
The Board members would especially like to thank the State and Regional staff for their
support and participation in this review process. If you have any questions about these findings,
please call me at 703-603-8815.
cc: S. Luftig
E. Laws
T. Fields
J. Clifford
F. Marcus
M. Newton
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>\
*
ro UNITED STATES ENVIRONMENTAL PROTECTION .
? WASHINGTON, D.C. 20460
f
;w 3 a «a SUPERFuNo Diw5io%
ppirr OP TMP D1REC'
OFFICE OF
SOLID WASTE AND EMERGENCY
RESPONSE
MEMORANDUM
SUBJECT: National Remedy Review Board Findings on the FernaJd
Environmental Management Project Site - OU3
FROM: . Bruce Means, Chairman
National Remedy Review Board
TO: William E. Muno, Director
Superfund Division
EPA Region 5
Purpose.
The purpose of this memorandum is to document the findings of the National Remedy
Review Board (NRRB) on the proposed remedial action described as OU3 for the Fernald
Environmental Management Project Site in Ohio.
Background.
As you recall, the NRRB was established as one of the October 1995 Superfund
Administrative Reforms to help control remedy costs and promote both consistent and
cost-effective decisions at Superfund sites. All proposed cleanup actions are to be reviewed
by the Board where: (1) the estimated cost of the preferred alternative exceeds S30M; or (2)
the preferred alternative costs over $10 M and this cost is 50% greater than that of the
least-costly, protective, ARAR-compliam alternative. In its review, u«. NRRB considers the
nature and complexity of the site; health and environmental risks; the range of alternative
actions considered to address site risks; the quality and reasonableness of the cost estimates
for alternatives; regional. State/tribal, and other stakeholder opinions on the proposed actions
to the extent they are known at the time of review; and any other relevant factors or program
guidances.
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Generally, the NRRB makes "advisory recommendations" to the appropriate Regional
decision maker prior to issuance of the proposed plan who is expected to give the Board's
recommendations substantial weight. However, other important factors may influence the
final Regional decision such as subsequent public comment or technical analyses of remedial
options. It is important to remember that the NRRB does not change the Agency's
delegation authorities or alter in any way the public's current role in site decisions. This
Reform is intended to bring to bear the program's extensive experience on decisions at a
select number of high stakes sites.
NRRB Findings.
The .NRRB reviewed relevant information submitted by Region 5 on OU 3 for the
Fernald Environmental Management Project Site and discussed related issues with Region 5
staff on March 4 and 12, 1996. A representative from the Ohio Environmental Protection
Agency participated in the conference call on March 12. Based on this review and related
discussion, the NRRB finds the proposed remedy to be cost-effective and consistent with
other actions taken at this site. Further, the NRRB finds that the proposed remedial action
fully satisfies the requirements set forth in the National Oil and Hazardous Substances
Contingency Plan (NCP) and applicable program guidance. Finally, the NRRB
acknowledges that potentially cost-saving refinements to the remedy may occur during the
design phase as a result of already planned value engineering studies, and the potential to
recycle waste materials.
The Board members would like to thank Regional staff and management for their
support and participation in this review process. If you have any questions about these
findings, please call me at 703-603-8815.
cc: V. Adamkas
S.Lufb'g
E. Laws
T. Fields
J. Woolford
J. Breen
J. Clifford
P. Nadeau
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
AUG 12
OFFICE OF
SOLID WASTE AND EMERGENC •
RESPONSE
MEMORANDUM
SUBJECT: National Remedy Review Board Recommendations on the DuPont, Necco
Park Site.
FROM: Bruce Means, Chair
National Remedy Review BoarJ
TO: Richard L. Caspe, Director
Emergency and Remedial Response Division
EPA Region 2
The purpose of this memorandum is to document the findings of the National
Remedy Review Board (NRRB) on the proposed remedial action for the DuPont, Necco
Park Site in New York State.
Background.
As you recall, the Administrator established the NRRB as one of the October
1995 Superfun'l Administrative Reforms to help control remedy costs and promote
consistent and cost-effective decisions. The Board will review all proposed cleanup
actions where: (1) the estimated cost of the preferred alternative exceeds $30 million,
or (2) the preferred alternative costs more than $10 million and is 50% more expensive
than the least-costly, protective, ARAR-compliant alternative. In its review, the NRRB
considers the nature and complexity of the site; health and environmental risks; the
range of alternatives that address site risks; the quality and reasonableness of the cost
estimates for Alternatives; regional, State/tribal, and other stakeholder opinions on the
proposed actions (to the extent they are known at the time of review); and any other
relevant factors jr program guidance.
Generally, the NRRB makes "advisory recommendations" to the appropriate
Regional decision maker before the Region issues the proposed plan. These
recommendations are then to be included in the Administrative Record for the site.
While the Region is expected to give the Board's recommendations substantial weight.
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R«cycl«d/R«cyclabl« • Printed win Vegetable Oil Based Inks on 100% Reryoed Paper (40% Postconsumer)
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other important factors, such as subsequent public comment or technical analyses of
remedial options, mo, influence the final Regional decision. It is important to
remember that the NRRB does not change the Agency's delegation authorities or alter
in any way the public's current role in site decisions This Reform is intended to focus
the program's extensive experience on decisions at a select number of high stakes
sites.
NRRB Findings.
The NRRB reviewed the proposed plan for the Necco Park site along with other
relevant site information with Regional staff, including Dale Carpenter, Kevin Lynch,
and George Shanahan, on May 7, 1996. Based on the information provided, the NRRB
generally supports the Agency's proposal for source control presented in Alternative 9.
Key objectives of Alternative 9 are to minimize constituent loading to the far-field
aquifer, create a physical barri°r to subsurface DNAPL migration, minimize
precipitation percolation through contaminated soil in the DNAPL source area, prevent
direct human contact with contaminated soil, and reduce the overall volume of
subsurface DNAPL. Based on these objectives, the NRRB recommends:
• At this time, the scope of the ROD should be limited to source control only, and
should not make a final decision on off-site ground water in the far field aquifer.
" The Board recommends that this proposed alternative include evaluating the
impact of the source control remedy on far-field groundwater contamination.
• Additional site characterization (sampling and analysis) should be conducted to
ussess whether natural attenuation may be effective ii. addressing far-field
contamination.
• The proposed alternative includes upgrading the existing cap over portions of
the Necco Park site to reduce percolation within the source area, while at the
same time leaving other areas within the source area uncovered. 1 r»3 Region
should consider extending the cap (or the use of other cover materials) to
address infiltration in areas within the proposed grout curtain but not currently
addressed by this upgrade.
• Given the status (i.e., near completion) of cleanups for other sites in the area
and that several unsuccessful attempts were made to design ai i are >wi Je multi-
source c'sanup strategy, the Board supports the current source-by-source
approach for addressing regional contamination. However, the RRB notes that
conditions in this area suggest a more global, or multi-source cleanup/waste
management strategy may have been appropriate, and recommends that the
Region evaluate this type of approach for any future proposed remediation of the
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far-field aquifer contamination. For example, the Region may want to assess, as
a future alternative, a strategy of adapting existing man-made structures, such
as the Falls Street tunnel and the NYPA conduit drain jacket system; as an
integral part of a collection system for multi-source treatment of far field
contamination.
The NRRB appreciates the Region's efforts to develop the proposed remedy.
The Board especially wants to thank the Region for their participation in the review
process. The NRRB encourages Region 2 management and staff to work with their
Regional NRRB representative and the OERR Region 2/6 Regional Accelerated
Response Center at Headquarters to discuss appropriate follow-up actions.
Please do not hesitate to give me a call at 703-603-8815 should you have any
questions.
. Luftig
E. Laws
T. Fields
B. Breen
J. Fox
E. Shaw
- Pre-Decisional; Not for Distribution -
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
MJG 12 fl96
OFFICE OF
SOLID WASTE AND EMERGEN<~
RESPONSE
MEMORANDUM
SUBJECT: National Remedy Review Board Recommendations on the Roebling Steel
Company Superfund Site
FROM: Bruce Means, Chair
National Remedy Review Board
TO: Richard L. Caspe, Director
Emergency and Remedial Response Division
EPA Region 2
Purpose.
The purpose of this memorandum is to document the findings of the National
Remedy Review Board (NRRB) on the proposed remedial action for the Roebling Steel
Company Superfund Site in Florence Township, New Jersey.
Background.
As you •ecall, the Administrator established the NRRB as one of the October
1 995 Superfund Administrative Reforms to help control remedy costs and promote
consistent and cost-effective decisions. The Board will review all proposed cleanup
actions where: (1) the estimated cost of the preferred alternative exceeds $30 million,
or (2) the preferred alternative costs more than $10 million and is 50% more expensive
than the least-costly, protective, ARAR-compliant alternative. In its review, the NRRB
considers the nature and complexity of the site; health and environmental risks; the
range of ^".arnatives that address site risks; the quality and reasonableness of the cost
estimates for alternatives; regional, State/tribal, and other stakeholder opinions on the
proposed actions (to ihe extent they are known ct the time of review); and &.iy other
relevant factors or program guidance.
Generally, the NRRB makes "advisory recommendations" to the appropriate
Regional decision maker before the Region issues the proposed plan. These
recommendations are then to be included in the Administrative Record for the site.
— Pre-Dec/s/ona/; Not for Distribution —
R*cycl«d/HacycUbl« • Pnmed wiin Vegetable Oil Based Inks on 100% flecyCed Paper (40% Posiconsumer)
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While the Region is expected to give the Board's recommendations substantial weight,
other important factors, such as subsequent public comment or technical analyses of
remedial options, may influence the final Regional decision. It is important to
remember that the NRRB does not change the Agency's delegation authorities or alter
in any way the public's current role in site decisions. This Reform is intended to focus
the program's extensive experience on decisions at a select number of high stakes
sites.
NRRB Findings.
The NRRB reviewed the proposed plan for the Roebling Steel Company site,
along with other relevant site information, and discussed related issues with EPA
Regional Project Manager Tamara Rossi on June 25, 1996. Based on this review and
discussion, the NRRB generally supports the Agency's proposed cleanup strategy as
presented in Alternative 3 of the proposed plan. However, the NRRB makes the
fallowing observations:
• The NRRB suggests that the Region consider an additional alternative that
would consist of: (1) demolishing the "A Buildings" (those buildings that are
contaminated and structurally unsound) and disposing the contaminated debris
in an on-site landfill; and (2) decontaminating the "B Buildings" (which are also
contaminated but structurally sound) to a risk level suitable for the expected
future use. This recommendation should not be viewed as a proposal to select
this alternative; only as a suggestion to evaluate it alongside others considered.
• Alternative 1, identified in the draft Proposed Plan as "no further action with
institutional controls," should be amended to evaluate only "no further action" in
order to establish the true baseline condition. Institutional controls should not be
included as part of a no action alternative.
» Alternative 2. as it is explained in the draft pioposed plan, does not appear to
pass the NCP threshold criteria. It does not address lead contamination in the
buildings, which contributes significantly to site risks.
• If the Region chooses Alternative 3, the Board believes that fine-tuning the
buildinc, specific decontamination strategies may save money during remedial
design. For this analysis it may help to evaluate the per-building cost for varying
decontamination le /els and compare that data to the target residual "isk levels.
The Region rhould consider using value engineering to explore these
opportunities.
The Board encourages the Region, during the post-ROD remedial design phase,
to continue working with potential site developers to determine the level of
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building decontamination necessary for potential future use. The remedy should
not spend resources on decontaminating buildings for future use if the buildings
will later be demolished by site developers.
The NRRB appreciates the Region's efforts to work closely with the State and
community to identify the current proposed remedy. The Board especially wants to
thank the Region and the State of New Jersey for their participation in the review
process. The Board encourages Region 2 management and staff to work with their
Regional NRRB representative end the Headquarters Region 2/6 Regional Accelerated
Response Center to discuss appropriate follow-up actions.
Please do not hesitate to give me a call at 703-603-8815 if you have any
questions.
cc: S. Luftig
E. Laws
T. Fields
B. Breen
J. Fox
E. Shaw
- Pre-Decisional; Not for Distribution -
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(J&
V-^MhftV
\s, 4?
UNITED STATES ENVIRONMENTAL PROTECT1C.V» AGENCY
WASHINGTON, D.C. 20460
fi IQQfi
u Wiro SOLID WASTE AND EMERGENCY
OFFICE Of
iSTEANOEMI
RESPONSE
MEMORANDUM
SUBJECT: National Remedy Review Board Recommendations on the Jack's Creek
Superfund Site
FROM: Bruce Means, Chair
National Remedy Review Board
TO: Thomas C. Voltaggio, Director
Hazardous Wasie Management Division, Region 3.
Purpose
The National Remedy Review Board (NRRB) has completed its review of the
proposed remedial action for the Jack's Creek Superfund Site in Maffland,
Pennsylvania. This memorandum documents the NRRB's advisory recommendations.
Context for NRRB Review
As you recall, the Administrator announced the NRRB as one of the October
1995 Superfund Administrative Reforms to help control remedy costs and promote
consistent and cost-effective decisions. The NRRB furthers these goals by providing a
cross-regional, management-level, "real time" review of high cost (and thus potentially
controversial) proposed response actions. The Board will review all proposed cleanup
actions where: (1) the estimated cost of the preferred alternative exceeds $30 million, or
(2) the preferred attemrtive costs more than $10 million and is 50% more expensive
than the (easi-costiy, prclajtive, ARAR-comp,.ant alternative. In te> leview, ue i 'RRB
considers the nature and complexity of the site; health and environmental risks; the
range of alternatives that address site risks; the quality and reasonableness of the cost
estimates for alternatives; Regional, State/tribal, and other stakeholder opinions on the
proposed actions (to the extent they are known at the time of review); and any other
relevant factors or program guidance.
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Generally, the NRRB makes "advisory recommendations" to the appropriate
Regional decision maker before the Region issues the proposed plan. The Region will
then include these recommendations in the Administrative Record for the site. White
the Region is expectedtr> nive the Board's recommendations substantial weight, other
important factors, such as subsequent public comment or technical analyses of
remedial options, may influence the final Regional decision. It is important to remember
that the NRRB does not change the Agency's delegation authorities or alter in any way
the public's role in site decisions.
NRRB Advisory Recommendations
The NRRB reviewed the draft proposed plan (dated June 1996) for the Jack's
Creek Site, a submission by potentially responsible parties for the site, and other
relevant site information, and discussed site issues with EPA .\agion 3 Remedial
Project Manager Garth Connor and Commonwealth of Pennsylvania representatives on
June 26,1993. Based on this review and discussion, the NRRB does not believe there
is sufficient information at this time to support the draft proposed plans' preferred
alternative (alternative 9). Specific concerns include the following elements that were
not deariy defined: site specific remedial action objectives (including a dear rationale
for determining a principal threat level for lead in soils above which treatment is
necessary), and current and future impacts on ground water. These concerns along
with other recommendations are described below.
First, the Region should clarify the rationale for how contamination will be
addressed in the context of site-specific remedial action objectives. For example, if
treatment in alternative nine is preferred because contamins~t levels grea*ar than
10,000 ppm lead are believed to constitute a principal threat at this site, the Region
should more thoroughly explain the basis for determining this lead cbncer.traiJon. The
Preamble to the NCP sets out a program expectation regarding the treatment of
principal threats wherever practicable, and defines a principal threat"... as wastes
that cannot be reliably controlled in place, such as liquids, highly mobile nSeriate (e.g.,
solvents), and high concentrations of toxic compounds (e.g., several orders of
magnitude above levels that allow for unrestricted use and unlimited exposure)."
The NRRB aJcnowtedoes that lead concentrations at the Jack'- Creek site are
sufficient:, high (up to 160 000 PPM) as to constitute a principal threat at some level.
However, the Regional rationale for determining the principal threat level above which
treatment is practicable and deemed necessary is undear. Such a level should be
determined on a site-specific basis and may be justified in several different ways. The
Region should refer to "A Guide to Principal Threat and Low Level Threat Wastes"
Superiund Publication 9380.3-06FS, dated November 1991 for additional information.
Ateo, in considering this issue, the Region may benefit from conducting site-specific fate
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and transport modeling to help evaluate the potential threat of lead leaching to ground
water from the proposed containment area. It is important to remember that white the
NCP expectations and the principal threat guidance support the development of
alternatives, the selectioi. an approp. i^te waste management strategy is determined
ultimately through the remedy selection process outlined in the NCP (i.e., all remedy
selection decisions are site-specific and must be based on a comparative analysis of
the alternatives using the nine criteria).
A second fundamental concern of the NRRB is that the .analysis did not clearly
define current and future impacts from the site on groundwater. The narrative provided
by the Region suggests elevated contamination levels in domestic drinking water
sources on a sporadic basis. Further, the RPM for the site indicated that another round
of samples had been taken and results were expected in the near future. The NRRB
recommends that any impacts, especially as they might result in contamination of
dcrmtic supply wells, be sufficiently characterized and addressed through remedial
action as necessary. Fate and transport modeling may be helpful in these analyses.
In addition, the NRRB offers the following recommendations:
The Region should consider using one or more of the recently developed adult
lead exposure models (e.g., the "Bowers model" currently under consideration by a
subgroup of the Superfund Lead Technical Review Workgroup) to assist in the
evaluation of baseline risk, and to-help establish a-site-specific lead cleanup level.
Although not yet adopted in formal Agency policy, use of such a model can help fine-
tune, or provide additional scientific and technical support for the Region's proposed
soil lead cleanup level.
Also, the NRRB noted its support for the inclusion of the limited actions
described in ^Kemauve two as part of any selected remedial action for the bite. This
support was qualified by the recommendation that these limited actions also include
groundwater monitoring and an action to permanently prevent the domestic use of any
onsite contaminated groundwater.
Finally, the NRRB questions the appropriateness of the proposed reconstruction
of wetlands at Jack's Creek as a fund-financed action. Based on the information
presented, this action does not appear to be an appropriate remediatiuu expenditure.
Creating a new wetia id to replace one destroyed by the apparent expansion of si e
operations is not an integral part of addressing the current or potential riskr from site-
specific contamination. This situation should be distinguished from situations in which
cleaning up site contamination damages the wetlands. In these cases, restoring the
affected wetlands under Superfund authorities would be appropriate. The NRRB
recommends that the Region explore other authorities to pursue the proposed wetlands
work at Jack's Creek.
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The Board members especially want to thank the Region and the
Commonwealth of Pennsylvania for their part;ctpatic,i in the review prc ™ *. We
encourage Region 3 management and staff to work with their Regional NRRB
representative and the OERR Region 3/8 Accelerated Response Center at
Headquarters to discuss appropriate follow-up actions. If you have any questions,
please do not hesitate to call me at 703-603-8815.
CC: W. M. McCabe
S. Luftig
E. Laws
T. Fields
T. Sheckells
B. Breen
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* A i
W
^i, W pensive than
theteast-cc^,pro*8Cth«,ARAR-axTpHarrtanefnative. In its review, the NRFB
cc>n»k^ the natoeartd complexity of the site; health and environmental risks; the range
of aAsfTtativvAflMtaddjreM sito risks; the quafly and reasonableness of the cost estimates
fbraftBfliflifc«ft;f%0atoMl.S^^
actions (to the eocbnt they am known at the time of review); arid any c
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Generally, the NRRB makes "advisory recommendations" to the appropriate
Regional decision maker before the Region issues the proposed plan. The Region will
then include these recommendations in the Administrative Record for the site. While the
Region is expected to give the Board's recommendations substantial v jioht, other
important factors, such as subsequ -* public comment or technical analyses of remedial
options, may influence the final Regional decision. It is important to remember that the
NRRB does not change the Agency's delegation authorities or alter in any way the public's
role in site decisions.
NRRB Advisory Recommendations
The NRRB reviewed the proposed plan for the New Bedford Harbor site, along with
other relevant site information, on August 14th, 1996. The Board discussed the site with
Commonwealth of Massachusetts Project Officer Paul Craffey, EPA RPM David
Dickerscr,, EPA site attorney Cii,w/ Catri, and Office of Site Remediation and Restoration
Deputy Director Frank Ciavattieri. Based en this review and discussion, the NRRB
generally supports the Agency's proposed cleanup strategy as presented in the proposed
plan. The NRRB makes the following observations:
The Commonwealth and Region have ensured that community interests are well
represented in the decision making process through the use of several techniques,
including professional facilitation. The Board accepted the Memorandum of
Agreement announced on August 1, 1996, outlining the community's support of the
proposed remedy as representing community concerns and issues.
The NRRB believes that the air monitoring costs are high, given the nature of the
proposed remedial action and contaminants to be addressed. The Board
recommends that the Region carefully examine the need for what appears to be an
overly extensile air monitoring program.
The water treatment costs appear to be disproportionately large relative to the
overa* remediation costs: The Board recommends that the Region examine the
ComnomweaJtti and Federal ARARs that drive t>e stringency of the effluent
discharge imis to oV^ermme whether a less costly treatment process would be
The Board also notes that the proposed remedial actions targeting PCBs wtfl
address the highest comantrations of metals a» wet If Region 1 selects a PCS
deanup goal other than the proposed 10 ppm/50 ppm for the upper and lower
harbor, respectively, they should examine the effect of this change on metal
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The NRRB appreciates the Region's efforts to work closely with the
Commonwealth, local government and community to identify the current proposed
remedy. The Board members also express their appreciation to both the Region and the
Commonwealth f Mass- •• isetts for tl iair participation in the review process. ' Vr
encourage Region 1 manciyement and staff to work with their Regional NRRB
representative and the Region 1/9 Regional Accelerated Response Center at
Headquarters to discuss appropriate follow-up actions.
Please do not hesitate to give me a call if you have any questions at 703-603-8815.
cc: J. DeVillars
S. Luftig
E. Laws
T. Fields.
M Newton
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ATTACHMENT 6
•
9/26/96 EPA Memorandum:
"National Superfund Remedy Review Board"
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
26 1996
OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE
MEMORANDUM
SUBJECT:
FROM:
TO:
National Remedy Review Board
Stephen D. Luftig, Director O'*^ v *T 1
Office of Emergency and Remedial Response j
Director, Office of Site Remediation and Restoration
Region I
Director/ Emergency and Remedial Response Division
Region II
Director/ Hazardous Waste Management Division
Regions III, IX
Director, Waste Management Division
Region IV
Director, Superfund Division
Regions V, VI, VII
Assistant Regional Administrator, Office of Ecosystems
Protection and Remediation
Region VIII
Director, Environmental Cleanup Off.' ce
Region X
Purpose
The purpose of this memorandum ib to update you or National
Remedy Review beard progress and bring to your attention
important Board operating procedures.
Background
As you knew, Assistant Administrator Elliott Laws formed the
Board.in Noveiuber 1995 as part cf Administrate^ Browner's .
Superfund reform initiatives. The Board's goals are to help
control remedy costs and promote consistent and cost-effective
decisions at Superfund sites. It has been functioning since
January 1996. Though impeded by FY 96 appropriation delays, to
date, the Board has held four meetings and numerous conference
calls, during which it completed reviews on twelve sites. The
Board has also worked to finalize the procedures under which it
will operate in the near future.
Printed on Recyc/ea
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This dedicated group of Regional and national Agency
experts, coupled with the hard work of many Regional program
colleagues, has already contributed greatly to improved
consistency and cost effectiveness in cleanup decisions. I want
to thank you and your staff especially for working so closely
with us during this important first year. Board efforts in FY T6
will be detailed in a year-end report for your information.
Key Operating Protocol
To ensure that the upcoming fiscal year's Board activities
are as productive as those of the past nine months, we need your
continued assistance. An effective site review requires
significant advance preparation, organization, and time
commitment from the Regional management and staff who
participate. In particular, the RPM is responsible for several
important coordination functions as highlighted below. I
recognize that the past year's budget situation has stretched our
already limited resources. Nonetheless, it is essential that we
commit the resources necessary to guarantee informed and
constructive dialooue at Board meetings.
For your information, the text below highlights several
important operating protocol describing how the Board expects to
work with the Regions, involve important stakeholders and handle
the timing of reviews. Involvement of the Board is a key step
for many sites in the Superfund remedy selection process. Each
Regional office is responsible for ensuring that these protocol
are followed to avoid delaying proposed plan issuance.
Regional Responsibilities
As indicated in the original Reform language, the Board
makes ^advisory recommendations'* to the Regional decision maker
who then makes the final remedy decision giving consideration to
the complete range of available information. While the Region is
expected to give the Board's recommendations substantial weight,
other iiujxjrtant factors, such as subsequent public comment or
techr'cal analyses of remedial options, may influence the final
Regional decision. It is important to remember that the NRRB
does not change the Agency's delegction authorities or alter in
any way the public's role in site decisions. It is expected,
however, that the Regions will provide for the record a written
response to Board recommendations. In general, a Region should
not issue the proposed plan until it has received and considered
the written Board recommendations.
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State/Tribal Involvement
The Board recognizes that the states and tribes have a
unique role in the Superfund program as "co-regulators," and has
taken steps to ensure their significant involvement in the review
process. With this in mind:
• The Region is to consult with the affected state or tribal
government well before the Board meetings to ensure that key
decision makers understand the background and intent of th&
review process. The Region should also make clear that the
states and tribes will have the opportunity to present their
views directly to the Board.
• As part of current procedure, the Region develops an
informational site package that forms the basis of Board
review. The Board asks that each Region work with
appropriate state and tribal personnel to ensure that the
"summary of state issues" section of that package is
accurately developed.
• The Regional RPM is to distribute the full site package to
the appropriate state and/or tribe concurrent with Board
distribution. He or she should also solicit their general
reaction to the material at this time.
• For each site, the Board meets in two stages: information-
gathering and deliberations. The Board will routinely
invite state and/or tribal decision makers to the
information-gathering phase of its site reviews. The Board
will invite the state and/or tribe to participate in the
deliberative discussion for state-lead fund-financed
decisions, and for state/tribe enforcement-lead decisions
where the state/tribe seeks EPA concurrence. Otherwise, the
Boaid will limit its deliberative discussion to Agency
personnel.
PRP Involvement
• Private oarties significantly involved with the site study
and/or response actions are to be notified by the
appropriate Regional office of the Board's site j-eview.
• The Board believes that PRPp who conduct the RI/FS can
provide valuable input to the review process. Therefore,
the Regional RPM is to solicit technical comment or ,
discussion, well before the Board meetings, from the PRPs
that are substantively involved in conducting the RI/FS.
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. These submissions should not exceed five pages in length,
and should be attached to the informational site package
provided to all Board members.
• The Board recognizes that PRPs who do not conduct the RI/FS
may conduct studies that might also be valuable to the
Board's review process. In these cases, the Region may, at
its discretion, solicit similar input from these
stakeholders.
Community Involvement
• For sites at which EPA has awarded a Technical Assistance
Grant (TAG) or recognized a Community Advisory Group (CAG),
the Region is to notify appropriate contacts well before the
meeting and ensure they also understand the review process.
• The Region is to offer the TAG recipient and/or CAG the
opportunity to submit written comments or concerns to the
Board concerning site-specific issues they think will be
important to the Board's discussions. These submissions are
also limited to five pages in length.
• Where the Region has established substantial working
relationships with other stakeholder groups early in the
RI/FS process, the Region may, at its discretion, offer
similar opportunity for written comment from these parties.
Timing of Review
• The Board plans to review sites early in the remedy
selection process, before the Region releases the proposed
plan for public comment.
• Occasionally, however, a post-proposed plan site may benefit
from Board review. For example, remedy changes in response
to public comment may increase the total remedy costs.
Where these additional cleanup costs exceed 20 percent of
the original cost estimate and trigger normal Board review
criteria, the Board may review the draft remedy.
Federal Facilities Review Criteria
The Board is continuing its discussions with representatives
from the Federal Facilities Restoration and Reuse Office (FFRRO),
the Federal Facilities Enforcement Office (FFEO), and with other
federal agencies to develop review criteria for federal facility
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sites. Wiile these final criteria are under development, FFRRO
and FFEO have recommended the following interim criteria:
• For federal J«cility sites where the primary contaminant is
radioactive waste/ the Board will raise the dollar trigger
from $30 million to $60 million and delete the W50% greater
than the least costly alternative" criterion.
• The Board will not review NPL site decisions on Base
Realignment and Closure (BRAG) sites.
• All other federal facility sites (i.e., those that involve
non-radioactive waste only) are subject to standard review
criteria.
To assist you in communicasing with other Superfund
stakeholders about the Beard review process, I am attaching to
this memorandum a fact sheet titled "Questions and Answers on
EPA's NRRB." Additional tools to'assist you and your staff with
the review process will be available shortly'.
I believe this Reform has accomplished much during the past
nine months. The hard work put forth by your staff and'the Board
members has paid off in significant cost savings. I look forward
to similar success over the next fiscal year. Finally, the Board
plans to continue its dialogue with interested stakeholders to
work toward a process that is agreeable anu fair to all involved.
He welcome your thoughts in this area as well.
Please contact me, or National Remedy Review Board Chair
Bruce Means (at 703-603-8815) if you have any questions or
comments.
cc: E. Laws
T. Fields
OERR Center Directors
CERR Senior Process Managers
B Breen
J. Wool ford
W. Xovalic
L. Starfield
W. Farland
R. Olexsey
E. Trovato
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xx EPA ROUND THREE:
SUPERFUND REFORMS AT A GLANCE
EPA National Superfimd Remedy
Review Board
This reform is one of twenty new "common sense" administrative reforms announced in
October 1995, by US EPA Administrator Carol Browner. These reforms mil fundamentally
redirect the Superfimd program to make it faster, fairer, and more efficient.
WHAT Is THE NATIONAL REMEDY
REVIEW BOARD?
The National Remedy Review Board (the
Board) is one of the principle Superfimd
Reforms that Administrator Browner
announced in October 1995. Its goal is to
promote cost-effectiveness and appropriate
national consistency in remedy selection at
Superfund sites. To accomplish this, the
Board analyzes proposed site-specific cleanup
strategies to ensure they are consistent with
current law and regulations. The Board also
considers relevant Agency guidance. The
Board's members are technical experts and
managers from each EPA Region and several
EPA Headquarters offices.
After its review, the Board issues
recommendations as to how or whether a
potential Superfund site remedy decision can
be improved. Although Board
recommendations are not binding, EPA
Regional decision makers give them
substantial consideration. EPA believes the
Board is contributing significantly to more
cost-effective, consistent Superfund remedies.
WHAT ARE THE CRITERIA THAT
TRIGGER BOARD REVIEW?
The Board will review proposed remedies for
which (1) the proposed remedy cost is more
than $30 million; or (2) the proposed remedy
costs more than $10 million and is 50%
greater than the least-costly, protective
cleanup alternative that also complies with
other laws or regulations that are either
"applicable" or "relevant and appropriate" to
a site decision.
The Board expects to review every proposed
decision that meets the above criteria at
Superfund sites that are not Federal facilities.
Because of their size and complexity, the
Board is developing a separate set of Federal
facility site review criteria. EPA encourages
anyone with concerns about a particular site to
contact the EPA Region in which that site
resides.
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WHAT DOES THE BOARD LOOK AT
WHEN IT REVIEWS A SITE?
The Board analyzes the cleanup strategy to
ensure that it is consistent with the Superfund
law and the National Oil and Hazardous
Substances Pollution Contingency Plan (or
NCP). The NCP is the Federal regulation that
details procedures for responding to oil or
hazardous substance releases. The Board also
considers relevant EPA cleanup guidance.
When they review a site, the Board members
ask many questions about the proposed
cleanup strategy. Site-specific circumstances
often influence the nature of the discussion.
Among others, Board members investigate
subjects like these below:
-What are the details of the Regional
proposal for site cleanup?
—What are the positions of the
State/Tribe, potentially responsible
parties (PRPs), and communities?
—Will the cleanup strategy be
effective?
—What is the rationale behind exposure
scenarios and risk assumptions?
—Are the cleanup goals appropriate and
attainable?
—Have other approaches to achieve the
cleanup goals been evaluated?
—Are the cost estimates reasonable?
—Is the strategy consistent with other
Agency decisions?
WHAT Is THE ROLE OF INTERESTED
PARTIES IN THE REVIEW PROCESS?
Community Involvement
For sites at which EPA has awarded a
Technical Assistance Grant (TAG) or
recognized a Community Advisory Group
(CAG), the Region will notify appropriate
contacts well before the Board meets to ensure
they understand the nature and intent of the
review process.
The Region will offer the TAG recipient
and/or CAG the opportunity to submit written
comments or concerns to the Board
concerning site-specific issues they think are
important. These submissions are limited to
five pages in length.
Where the Region has established substantial
working relationships with other interested
groups early in the RI/FS process, the Region,
at its discretion, may offer similar opportunity
for written comment.
State/Tribe Involvement
The Board recognizes the unique State/Tribe
role in the Superfund program as "co-
regulators," and has taken steps to ensure
significant State involvement in the review
process.
The Region will consult with the affected
State/Tribe well before the Board meeting to
ensure that key State/Tribe decision makers
understand the nature and intent of the review
process. They will also make clear that the
State/Tribe will have the opportunity to
present their views at Board meetings.
As part of current procedure, the Region
develops an informational site package that
forms the basis of Board review. The Board
will ask that each Region work with the
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appropriate State/Tribe to ensure that the
"summary of State issues" section of that
package is accurately developed.
The Region will distribute the full site
package to the appropriate State/Tribe
concurrent with Board distribution. They also
will solicit the State/Tribe's general reaction to
the material.
For each site, the Board meets in two stages:
information-gathering and deliberations. The
Board will routinely invite State/Tribe
decision makers to the information-gathering
phase of its site reviews. The Board will
invite the State/Tribe to participate hi the
deliberative discussion for State/Tribe-lead
Fund-financed decisions, and for State/Tribe
enforcement-lead decisions where the
State/Tribe seeks EPA concurrence.
Otherwise, the Board will limit its deliberative
discussion to Agency personnel.
PRP Involvement
The Board believes that PRPs who conduct
the RI/FS can provide valuable input to the
review process. Therefore, the Regional
Project Manager (RPM) will solicit technical
comment or discussion, well before the Board
meetings, from the PRPs that are substantively
involved hi conducting the RI/FS. These
submissions should not exceed five pages hi
length, and should be attached to the
informational site package provided to all
Board members.
The Board also recognizes that PRPs who do
not conduct the RI/FS may conduct valuable
studies. In these cases, the Region, at its
discretion, may solicit similar input.
How Do I FIND OUT WHETHER THE
RRB WILL REVIEW A SITE?
If you have questions about a particular
Superfund site, please call the EPA Region in
which it is located. They will put you hi touch
with someone who knows about the site.
FOR MORE INFORMATION.
You may also call EPA's Superfund Hotline at
1-800-424-9346 (or 703-412-9810 within the
Washington, D.C. area) to get general
information about EPA, the Remedy Review
Board, and the Superfund program. The
Hotline will refer you to the appropriate EPA
Region, program office, or staff member
should you have questions they cannot
answer.
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