United SUtes Environmental Protection Agency
Washington, DC 20460
Directive Initiation Request
11. Directive Number^
9355.3-09
Mai) Cod*
OS-220
Office
HSCD
Telephone Codt
Results of FY-89 Record of Decision Analysis - SMR Implementation
Product Recommendation #25A
4. Summary of Directive (include bnef siatement of purpose)
Transmits the results of the FY-89 ROD analysis conducted by
OERR and OWPE. Report focuses on consistency of remedy selection
decisions with Superfund program expectations as established in
the NCP. Report concludes with recommendations for strengthening
program in future.
5. Keywords
J
. Do
s of Decision/ remedy selection, Superfund, cleanup
6*. Does This Directive Supersede Previous Directive(sj?
o. Does tt Supplement Previous Directive(s)?
No
No
Ye* Whet directive (number. We)
. Dmn Level
A-SignedbyAA/DAA
x Yee What dtoctive (number. tUe)
9335 and 9355 series
B - Signed by Office Director
C- For Review & Comment ["""[ D - In Development
8. Document to be distributed to States by Headquarters? Ij Yt» Q No
This Request Meets OSWER Directives System Format Standards.
9. Sgnsture ol Lesd Office Directives Coordinator
Betti C. VanEpps, Superfund Documents Coordinator
Henry L. 'Longest II and Bruce^ M.
diamond
Date
3/30/90
Date
3/30/90 '
EPA Form 1315-17
5-17)
editions are obsolete.
OSWER OSWER OSWER O
VE DIRECTIVE DIRECTIVE DIRECTIVE
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j.una jocxet & in
Center, Mail Code OS-245, Telephone 202-382-6940.
USB
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
MAR 31 1990
O^CICE O<=
SOLID VViSTE AND EMEf GENCv RESPONSE
OSWER Directive No. 9355.3-09
MEMORANDUM
SUBJECT
FROM:
TO;
Results of FY'89 Record of Decision Analysis
Superfund Management Review Implementation Product -
Recommendation No. 25A
Henry L. Longest II, Director
Office of Emergency and Remedi
Bruce M. Diamond, Directo
Office of Waste Programs
ponse
En
cement
Director, Waste Management Division
Regions I, IV, V, VII, VIII
Director, Emergency and Remedial Response Division
Region II
Director, Hazardous Waste Management Division
Regions III, VI, IX
Director, Hazardous Waste Division
Region X
Purpose
The purpose of this memorandum is to transmit the results of
the analysis of FY'89 Records of Decision (RODs) conducted by the
Office of Emergency and Remedial Response (OERR) and the Office of
Waste Programs Enforcement (OWPE). This report focuses on the
consistency of remedy selection decisions with Superfund program
expectations as established in the National Contingency Plan
(NCP), and the quality of ROD documentation. The report
highlights improvements in ROD quality over last year's RODs and
discusses several trends over the past several years. The report
concludes with recommendations for strengthening aspects of RODs
in the future.
Background
In FY'89, OERR and OWPE performed an analysis of
approximately half of the FY'88 RODs. The analysis focused on
whether RODs adequately documented remedy selection decisions in a
clear, defensible manner consistent with established guidance.
The analysis provided Headquarters and Regional management with a
tool to gauge past performance and aided in establishing goals for
strengthening future performance.
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As part of our ongoing effort to promote continuous
improvement in ROD quality and consistency, OERR and OWPE
undertook a review of RODs signed during FY'89. This year's
review revisited some of the areas covered in last year's
analysis, particularly the quality of documentation and its
consistency with the "Guidance on Preparing Superfund Decision
Documents" (OSWER Directive 9355.3-02, June, 1989) (known as the
"ROD Guidance"). In addition, this year's review examined the
consistency of remedy selection decisions with the Superfund
program's expectations regarding the appropriate use of treatment,
engineering controls and institutional controls for source control
actions. Additionally, the study evaluated how often innovative
technologies are being considered and tested for effectiveness, and
the types of remedies being selected for contaminated ground water.
All FY'89 RODs that were entered into CERCLIS, with the
exception of four (4) RODs that were not received by Headquarters,
were reviewed. The RODs were analyzed by a review team comprised
of Headquarters staff and representatives from a Region, and a
State. RODs that covered more than one site were counted as one
ROD in the analysis, thereby making the total number of RODs
analyzed equal to 131.
In the FY'89 ROD analysis, remedial actions were segregated
into five categories: final source control actions, interim
source control actions, final ground water actions, interim ground
water actions, and no action/no further action. A final action is
the last action to be taken at/or on a defined portion of the site
in order to ensure that protection of human health and the
environment has been achieved. Interim actions (e.g., temporary
containment or storage, or partial mitigation of media) are those
actions that must be followed by a subsequent action (and ROD) in
order to achieve definite protection of human health and the
environment at that portion of the site. No action/no further
action RODs are signed where it is determined that no remedial
action (or further remedial action, if a previous action has
occurred) is necessary in order to achieve protection of human
health and the environment. No action/no further action RODs are
also signed in the unusual cases where a determination is made that
there is no CERCLA authority to take a particular action (e.g.,
petroleum) or where no effective action is possible at the site.
While no action/no further action RODs will not call for any active
measures to control exposure (including institutional controls),
they may authorize monitoring. [Note: The FY'88 ROD Analysis was
not based on a categorization of the RODs.] This segregation was
based on the fact that expectations for these different types of
decisions and their respective documentation requirements vary.
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RODs which contained a source control and a ground water component
were evaluated for both actions.1
Results of the analysis demonstrate that 72% (94/131) of
FY'89 RODs reviewed addressed source control. Ninety percent
(90%) (85/94) of these were final source control RODs, and the
remaining 10% (9/94) of the source control RODs were for interim
source control actions. Forty-nine percent (49%) (64/131) of the
FY'89 RODs addressed ground water remediation. Eighty-four
percent (84%) (54/64) of these RODs were final ground water RODs
and the remaining 16% (10/64) of the ground water RODs select
interim ground water actions. Twelve RODs (9% of the total RODs)
were no action/no further action RODs. (See Exhibit 1.)
Objective
The objective of the FY'89 ROD Analysis is to promote ROD
quality and consistency by implementing an annual quality
assurance/quality control (QA/QC) review of RODs.
Findings of Analysis
Results of the FY'89 ROD Analysis relate to: 1) Consistency
of Remedies with Program Expectations, 2) ROD Documentation, and
3) Trends in Remedy Selection over time. The final sections of .
this report summarize the major findings of the study (including
significant improvements made since FY'88) and highlight
recommendations for FY'90 RODs.
CONSISTENCY WITH PROGRAM EXPECTATIONS
The goal of the remedy selection process is to select
remedies that are protective of human health and the environment,
that maintain protection over time, and that minimize untreated
waste. The program expectations state that treatment is most
likely to be appropriate for materials that comprise the principal
threats posed by a site, and that engineering controls are most
likely to be appropriate for materials that pose a low-level threat
or where treatment is impracticable. Institutional controls are
expected to be used to mitigate short-term impacts and/or as a
supplement to the engineering controls to aid in the long-term
management of materials that will remain on-site. Institutional
controls should not substitute for more active measures as the sole
remedy unless active measures are impracticable. Innovative
technologies are to be evaluated closely where there is a
1 No Action/No Further Action decisions for a portion of the
site (e.g., ground water) contained in RODs that authorize
remedial action for another portion of the site (e.g., source
area) have not been counted in the total of no action RODs.
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reasonable belief that they may perform as well or better than
conventional technologies with respect to reduction of toxicity,
mobility or volume, short-term impacts, or cost. Ground water is
to be returned to its beneficial uses within a reasonable timeframe
given particular site circumstances. All final Superfund remedial
actions are expected to be consistent with the program goal and
expectations described in the National Contingency Plan (NCP)
unless an exceptional circumstance exists.
Major Findings: Materials comprising principal threats posed
by sites are being treated in the vast majority of final source
control RODs. Engineering controls are being selected for
materials comprising low-level threats in most cases, although
low-level threats are being treated in some final source control
RODs. The selection of treatment as part of final source control
remedies has increased since last year; selection of innovative
treatment technologies has also increased. Treatability studies
are often planned for remedial design rather than during the
remedial investigation and innovative technologies are sometimes
eliminated when treatability studies have not been conducted or
planned prior to the ROD.
Institutional controls are being used consistently as
supplements to final ground water actions and as supplements to
engineering controls used for long-term management in the majority
of final source control RODs that will leave materials on-site to
be managed. Ground water remedies are completely consistent with
program expectations to restore ground waters to their beneficial
uses within timeframes that are reasonable given particular site
circumstances.
Statistics were compiled and examined to determine the
frequency of the use of treatment and containment in the FY'89
RODs.2 (See Exhibit 2.) Treatment was selected as a major
component of 73% (69/95) of the final source control remedies.
Containment was selected as the sole remedy in the remaining 27%
(26/95) of the final source control RODs. These sites that
selected containment were large landfills, mining waste/smelter
sites or asbestos sites. Treatment was also selected in 70%
(7/10) of interim source control RODs. Active restoration was
2 Two discrete ROD universes were used in compiling data
for this report. The statistics on treatment types and
frequencies presented in the noted paragraph (and in the final
section of this report on treatment trends) were not based on the
FY'89 ROD Analysis data. The data was extracted from the draft
FY'89 ROD Annual Report, which reflects all 143 FY'89 RODs
entered into CERCLIS. RODs that covered multiple sites were
counted as multiple RODs in the ROD Annual Report.
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selected in 97% (62/64) of the.final ground water RODs and in 50%
(5/10) of the interim ground water RODs.
Evaluating consistency of remedies with the program
expectations depends on the availability of information in the ROD
that clearly identifies contaminant concentrations, their volumes,
and location at the site.3 All of the final source control RODs
that identified principal threats (59 RODs) also identified that
the material comprising the principal threats posed by the site
will be treated (see Exhibit 3). Waste defined as comprising a
low-level threat (72 RODs) will be treated in 33% (24/72) of the
cases; all 24 of these cases also involve treatment of principal
threats. [Note: Treatment of both principal and low-level threats
at these sites may be the cost-effective remedy.] Low-level waste
will clearly be contained in the remaining 67% (48/72) of the
cases. Fifty-eight percent (58%) of the final source control RODs
and 72% of the final ground water RODs included the use of
institutional controls as part of the remedy. In all but one final
source control remedy and one final ground water ROD, in which
active response measures are impracticable, these controls are to
be used as a supplement to the treatment and/or engineering
controls.
Forty-four (44) innovative technologies4 (defined as source
treatment technologies other than incineration or
solidification/stabilization and standard ground water treatment
methods such as granular activated carbon and air stripping) were
selected for thirty-nine (39) source control RODs and six (6)
innovative technologies were selected for ground water (see
Exhibit 4). Final ground water remediation was selected in 97%
(64/74) of the RODs that included a ground water remediation
component, 97% (62/64) of which used treatment to address the
ground water contamination (see Exhibit 2). The remaining 3%
(2/64) of the final ground water RODs used other methods: one
selected natural attenuation and the other selected use of an
alternate water supply and monitoring. Interim ground water
remediation was selected in 14% (10/73) of the ground water RODs,
50% (5/10) of which used treatment. The remaining 5 interim
ground water RODs selected natural attenuation (for 1 ROD) and
other methods including enhancement of existing pump and treat
systems, establishing ACLs, and use of institutional controls.
Innovative technologies were considered in 13 additional
final source control RODs, but were not favored due to uncertainty
about effectiveness and the lack of data on the innovative
technologies. Treatability studies were completed prior to ROD
3 The ROD Analysis data base was used to evaluate these
findings.
4 See Footnote 2.
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signature to evaluate eleven (11) of the sixty-four (64) final
source control treatment remedies and three (3) of the fifty (50)
final ground water treatment remedies. Thirty-six (36) additional
treatability studies for final source control actions are planned
for completion during the remedial design phase. (Note:
Treatability studies were not evaluated in ground water RODs.)
Timeframes for restoration and cleanup levels which can be
attained for ground water may be uncertain at the completion of
the RI/FS. A discussion of this uncertainty was provided in 53%
of the final ground water RODs that selected active restoration.
In 59% of these RODs that included a discussion of uncertainty,
the action taken to reduce this uncertainty was to collect
appropriate data to assess the potential performance of extraction
and treatment technologies.
ROD DOCUMENTATION
Definition of Principal Threats and Low-Level Threats
The manner in which the ROD defined principal and low-level
threats in terms of concentrations and volumes was examined
closely. A clear definition of principal versus low-level threats
is necessary for measuring the consistency of remedies with the
program expectations to treat principal threats whenever
practicable and to use engineering controls when waste poses a
low, long-term threat or where treatment is impracticable. In
order to make this determination, contaminant concentrations and
volumes need to be linked to specific areas of the site.
Major Findings: Principal threats are being described
relatively clearly. Low-level-threats could be defined more
clearly.
For sites that included discrete areas thought to comprise
the principal threats posed by the site, approximately 80% (59/74)
of the final source control RODs clearly defined the principal
threats at the site and all of these RODs provided both the volumes
and concentrations of the contaminants in these areas. Forty-nine
percent (49%) (35/72) of the final source control RODs with areas
that pose a low-level threat defined and identified the
contaminants in these areas, and about 60% of the descriptions
included the volume of this contaminated material.
Documentation of Site Risks
Major Findings: Documentation of site risks is the priority
area for improvement.
All RODs for final actions should summarize the results of
the baseline risk assessment conducted for the site, including the
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results of the exposure and toxicity assessments and the pathway-
specific risks. The ROD should clearly identify both the
carcinogenic and noncarcinogenic risks for the populations at risk
at the site.
The ROD should clearly define current and future expected
land use scenarios and the reasonable exposure pathways affecting
each population group identified. Environmental risks should also
be summarized. While nearly all of the final source control and
the final ground water RODs identified the current land use and the
reasonable exposure pathways affecting the population groups, 38%
of the final source control RODs provided future land use. Nearly
all of the final ground water RODs identified the potential
beneficial use of the ground water. Basic toxicity information
about the contaminants, daily intake factors, and assumptions
regarding the intake were identified in less than half of the final
action RODs.
Populations at risk5 were identified in 72% and 83% of the
final source control and final ground water RODs, respectively
(see Exhibit 5). Fifty-four percent (54%) of the final source
control RODs provided the carcinogenic risk or hazard indices for
the pathway-specific risks and for the population groups at risk
at the site. Only 43% of the final ground water RODs provided the
total risks for the population at risk and 67% provided pathway-
specific risks.
Approximately 66% of the final source control RODs and 72% of
the final ground water RODs specifically documented that the
baseline risk was greater than the carcinogenic risk range.
Several RODs did not clearly explain the relationship of the
baseline risk to the risk range. Forty-four percent (44%) of the
final source control RODs and 56% of the final ground water RODs
documented potential environmental exposures.
The summary of site risks section of the ROD should state
that imminent and substantial endangerment to public health,
welfare, or, the environment may occur if no action is taken at
the site. While this statement appeared in the declaration of 53%
of the final source control RODs, only 27% included it in the risks
summary also. (Note: Ground water RODs were not reviewed for
these statements.)
In the description of alternatives section, the ROD should
clearly define all the risks and exposure pathways existing at a
site, and should explain how the selected remedy addresses the
5 Populations at risk refers to a group of individuals
potentially exposed at Superfund sites, based on current or
future land use under reasonable maximum exposure assumptions.
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8
risks. Only 28% of the final source control RODs included a
description of initial risks for a pathway or population and 46%
provided the risk reduction for each alternative. However, in the
comparative analysis sections of the source control and ground
water RODs, about 75% of the RODs provided this information under
the discussion of "overall protection" as well as in the statutory
determinations section of the ROD under the "Protection of Human
Health and the Environment" determination. Forty-four percent
(44%) of the final source control RODs provided risk levels
corresponding to concentration-based remediation goals in the
description of the selected remedy.
Alternatives Description and Analysis
Major Finding: Improvement over last year was seen in use of
the nine criteria in the comparative analysis.
The description of each alternative should allow the reader
of the ROD to fully track all waste identified on the site to its
final destination, including residuals. Sixty-six percent (66%)
of the final source control RODs and 63% of the final ground water
RODs provided such a description of the alternatives (see Exhibit
6). About half of the final ground water RODs that selected active
restoration identified the area of attainment and the provisions
for monitoring the ground water once the system is shut off to
ensure remediation levels are maintained.
The ROD should highlight the key differences in the
alternatives in relation to the nine criteria. Eighty-six percent
(86)% of the final source control RODs and 91% of the final ground
water RODs provided a comparative analysis that used the nine
criteria consistent with NCP definitions, compared to 80% last
year. Several final action RODs did not provide a comparative
analysis of alternatives.
ARARs Identification (Land Disposal Restrictions. RCRA Waste
Documentation. Closure. Endangered Species Act. State ARARs)
Major Findings: Improvement is needed in documenting a
determination of whether wastes at the site are RCRA wastes,
whether LDR is an ARAR, and whether RCRA closure requirements are
ARARs. State ARARs'are being addressed most of the time.
Describing the ARARs that are actually to be attained needs to be
improved.
Key ARARs were documented in 52% of the final source control
RODs in the description of the alternatives, compared to 70% of
the 75 RODs reviewed last year (see Exhibit 6). Several ARARs in
particular, listed above, were highlighted in this year's
analysis. Forty-nine percent (49%) of the final source control
RODs documented whether the waste is a RCRA waste and provided a
determination of the Land Disposal Restrictions (LDR) as an ARAR;
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forty-three percent (43%) of the final ground water RODs provided
this documentation and determination. RCRA closure requirements
were documented as ARARs for approximately half of the actions
that involved capping, excavation or disposal. Approximately 25%
of the sites with final source control actions where endangered
species may be encountered identified the Endangered Species Act
as an ARAR. State ARARs were addressed in 86% and 83% of the
final source control and final ground water RODs, respectively.
In the comparative analysis of alternatives, 73% and 78% of the
final source control and final ground water RODs, respectively,
highlighted that each alternative meets ARARs. Ninety-three
percent (93%) of the final source control RODs documented the
statutory determination that the selected remedy complies with
ARARs, and about 85% of the ground water RODs provided this
statement; however only about 70% of the final action RODs listed
and described the ARARs that would be attained.
Selected Remedy
Major Findings: Remediation goals and points of compliance
need to be documented more clearly.
The description of the selected remedy should provide the
remediation goals and the points of compliance for each medium or
area at the site that is being addressed. Sixty-two percent (62%)
of the final source control RODs provided remediation goals and 33%
specified the points of compliance for each medium (see
Exhibit 6). Less than half (48%) of the final source control RODs
documented the method for managing residuals. The final ground
water RODs provided remediation goals 87% of the time.
Statutory Determinations and .Rationale for Remedy Selection
Major Findings: There is a marked improvement over last year
in providing clear rationales for the remedy selection in terms of
the five primary balancing criteria.
All RODs must provide a description of how the selected
remedy satisfies each of the four statutory requirements for
remedial actions and the preference for treatment. The discussion
under "utilization of permanent solutions and treatment to the
maximum extent practicable" is where the rationale is to be found.
Seventy-one percent (71%) of the final source control RODs
(compared to 50% last year) and 37% of the final ground water RODs
provided the rationale for remedy selection in terms of a balancing
of the five primary balancing criteria (see Exhibit 6).
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10
TRENDS IN REMEDY SELECTION6
Use of Treatment
Major Findings: Use of treatment, including innovative
treatment technologies, is increasing annually.
An historical overview of FY'87 through FY'89 source control
RODs was conducted to compare selected remedies since the
enactment of the Superfund Amendments and Reauthorization Act of
1986. This analysis demonstrates that the use of treatment for
source control RODs has increased from 54% (27/50) in FY'87, to
69% (69/100) in FY'88, and 72% (76/105) [or 73% (69/95) of final
source control RODs] in FY'89. Additionally, the use of
innovative treatment technologies in source control RODs that
selected treatment has also increased from 26% (7/27) in FY'87, to
40% (28/69) in FY'88, and 51% (39/76) in FY'89. Thus, there has
been a progressive increase in the frequency of the use of
treatment to address source control, and a twofold increase in the
employment of innovative technologies for the treatment selected
since FY'87.
Conclusions and Recommendations for FY'90 RODs
In conclusion, we continue to improve in our efforts to
produce high-quality RODs. Clarity in the descriptions of
remedies and the rationale for selection of a remedy help improve
the quality and consistency of RODs and assist in enforcement and
negotiation efforts, and in ROD implementation. The results of
the analysis show success in improving those areas targeted as a
result of last year's ROD Analysis.
Improvement in the FY'90 RODs should be based on the lessons
learned from the FY'89 ROD Analysis. Specifically, emphasis
should be placed on the following areas:
1) Documentation of site risks;
2) Describing principal and low-level threats;
3) Describing the link between principal and low-level
threats and the method of achieving protection in
accordance with the Superfund program's expectations;
4) Documentation of ARARs, particularly LDR;
5) Increasing the use of treatability studies conducted
during the remedial investigation to support the
selection of innovative technologies.
6 See Footnote 2.
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11
Headquarters will assist Regional efforts to enhance ROD
quality through the ROD forums which will be held in each Region
during the Third Quarter. At that time we will provide good
examples of various sections of the ROD to Remedial Project
Managers (RPMs). We will also distribute revised short sheets
reflecting the latest guidance and a ROD checklist to be used by
RFMs as an additional QA/QC tool.
If you have any questions about the FY'89 ROD Analysis,
please contact Sandra Panetta in the Remedial Operations and
Guidance Branch, Hazardous Site Control Division, OERR, at FTS-
475-9757.
Attachments
cc: Superfund Branch Chiefs, Regions I-X
Superfund Section Chiefs, Regions I-X
Regional Counsels, Regions I-X
Regional Counsel Superfund Branch Chiefs, Regions I-X
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FY'89 RECORD OF DECISION ANALYSIS DATA SUMMARY
Exhibit 1. Final vs. Interim Actions
O)
t»
u
u
I
Z
100 -
80 -
60 -
40 -
20 -
• Thtny-nirw RCOs •npioym; ground water rvnodtaion components
also •mpioy*c a sourc* ccrrns1 n»m«c^".cn componerr:
Selected Remedy
Interim Action
Final Action
Q No Action
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FT89 RECORD OF DECISION ANNUAL REPORT DATA SUMMARY
Exhibit 2. Treatment vs. Containment
I
V
JD
100 -\
80 -
60 -
40 -
20 -
0 -J
* Forry-«>;ni of tr»M sn«s ampioyw} ground watar
and seurc* control rtmadiation components
Note Th« statics creunied i^ this ein&'t w*f» >:'
tasAC on Lie FV89 ROD Analysts da:a The da'j
w»r« •xtraa»e from tr» drat: Pf"89 ROD Annual
R«por:, which retiACS all 143 FY69 RODs 0nt«feC
irtio CE5CLJS RODs that cov»r»c muP.cw st*s w»'
couni«3 as mutto* RODs in ins FV89 ROD Annua1
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FT8Q RECORD OF DECISION ANALYSIS DATA SUMMARY
Exhibit 3. Treatment vs. Containment of Principal Threats and Low-Level
Threats in Final Source Control RODs
Principal Threats and Low-Level Threats
2
o
K
.a
2
60
50
40
30
20
10
0
61
35
48
48
M Principal Threats
B Principal Threats and
Low-Level Threats
CD Low-Level Threats
O Principal Threats or
Low-Level Threats*
Treatment
Containment
Selected Remedy
* These 2 sites did not clearly delineate areaa a3 principal or low-level threats.
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FV89 RECORD OF DECISION ANNUAL REPORT DATA SUMMARY
Exhibit 4. Innovative vs. Conventional Treatment Technologies
8
o
1
80 _
60 _
40 -
20 -
• These 76 RODs empioyod 100 source control Iroaimenis.
Note: The statisiics presented in this eihibt were not
easec on :r.« FV89 ROD Analysis ca:a_ The caia were
erraoed Irom me drafl FVG9 ROD Annual Reper. wn.cr
fef'eas all U3 FV'89 ROI^s enterec mio CERCLIS. RODs
ir.a: ooverec mjii^te sues were countec as muHo*e RODs
in ihe FY'89 ROD Annual Repor.
Remedial Action Components
Conventional Technologies
Innovative Technologies
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FTS9 RECORD OF DECISION ANALYSIS DATA SUMMARY
Exhibit 5. Documentation of Risks at Final Source and Final Ground Water RODs
Final Source
Control:
(A
§
*
•w
V
8
£
80 n
60-
40
Risk Assessment
Final Ground
Water:
Q
§
•s
I
C
u
8
Risk Assessment
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FY89 RECORD OF DECISION ANALYSIS DATA SUMMARY
Exhibit 6. Documentation Findings
Final Source
Control:
100 -i
71
Record of Decision Documentation Sections
Final Ground
Water:
100n
,c/
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