United States
                               Environmental Protection
                               Agency
                       Office of
                       Solid Waste and
                       Emergency Response
Directive No. 9378.0-11FS
EPA 540-F-97-019
PB97-963303
October 1997
      &EPA
A  Citizen's Guide
to  Understanding
Presumptive  Remedies
    Office of Emergency and Remedial Response
    5202G
        Cleaning up abandoned hazardous waste sites has been the charge of EPA's Superfund program since 1980.
        Over the past 17 years, Superfund has gained considerable experience on hazardous waste cleanup
        approaches and technologies.  As we gained experience, we found that certain sites have similar
 characteristics that we could use to our advantage to improve the cleanup process. The "presumptive remedy"
 initiative is one of the results. Essentially, we said: "Here's a site similar in all key ways to many other sites we've
 cleaned up. Wouldn't it make sense to use that cleanup approach here, too?"

 Presumptive remedies benefit both Superfund and you—the community members affected by a Superfund site.
 Keep reading to find the answers to questions you may have about presumptive remedies, how they work, and
 why we use them.
1.   What are presumptive remedies?

    As Superfund worked through hundreds of cleanups, we
    discovered similarities. Certain types of sites, like wood
    treater sites, have similar chemical contaminants. Other
    sites, like municipal landfills, share similar charac-
    teristics. At similar sites, standard remedies (called
    "presumptive") can be applied. Presumptive remedies are
    based on historical patterns of remedy selection and our
    scientific and engineering evaluation of how well cleanup
    technologies perform. EPA now expects presumptive
    remedies to be considered at all applicable sites. And they
    should—those applicable sites make up more than 60% of
    sites on the National Priorities List!

2.   Why use presumptive remedies?

    Presumptive remedies have helped us streamline the
    cleanup process. This approach has led to many
    advantages, for you and for Superfund. When we first
    investigate a site, we  try to decide whether it is a
    candidate for a presumptive remedy. If it is, then we can
    narrow down the cleanup choices. This could save us a lot
    of time in site investigation and data collection efforts.
    More importantly, it means that we spend less time in
    your community, so there are fewer disruptions. And,
    since the presumptive remedies have been successfully
    implemented at other sites, you can be confident that it
                         will fully protect your health and your community's
                         environment.

                         One of the most important advantages is that, the sooner
                         your community knows the remedy, the sooner you can
                         plan for how you may want to use the site once it's cleaned
                         up. We can work with your local land planning group to
                         help determine how the community would like to use the
                         cleaned up site.  Finally, some sites that have used
                         presumptive remedies have shown significant time and cost
                         savings. The more time and money we save at a site, the
                         more resources we have available to clean up other sites.
                     3.   What are the different types of presumptive remedies?

                         Presumptive remedies have been developed for four kinds
                         of sites: municipal landfills, volatile organic chemicals
                         (VOCs) in soils, wood treater sites, and contaminated
                         ground water. Presumptive remedies can be grouped by the
                         type of cleanup plan: containment, treatment, and response
                         strategy. "Containment" holds the waste and prevents the
                         spread of contaminants. "Treatment" uses a single
                         technology or group of technologies to get rid of the
                         contaminants. A "response strategy" is a long-term
                         approach with several steps and options to decide among
                         treatment and containment options for different sections of
                         a site.

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 -?VV
-J
      'What is the presumptive remedy for municipal
      landfills?
   .//.The presumptive remedy for municipal landfills is
      -containment, which can include some or all of the
      following components, as appropriate, on a site-specific
      basis: landfill cap, to minimize infiltration of rain water
      through the buried waste and to ground water below;
      leachate collection and treatment; source area ground
      water control to contain plume; landfill gas collection
      and/or treatment; and institutional controls to ensure that
      the integrity of the landfill cap is preserved.
 fS. :'What is the presumptive remedy for a site with VOCs
    "in the soils?

   ^••";We have three presumptive remedy technologies to treat
'iS~~\ a site with soils contaminated with VOCs. The preferred
      remedy is soil vapor extraction. With this method, we
      can leave the soil in place and remove contaminants with
      a process that forces air through the soil. The other
      choices are thermal desorption and incineration. Both of
      these technologies require us to excavate the soil and
      treat it with a  process using heat. Once the soil is treated,
      cleaned, and tested, we can return it to the site.
  ^''i
 \6. ; What is the presumptive remedy for a wood treater
   " 'site?

   //\\The presumptive remedy for a wood treater site depends -
'   ~ .'on the types of contaminants located at the site. If the
      contaminants  are organic, we use bioremediation,
      thermal desorption, or incineration. If they are inorganic,
      we use immobilization. Bioremediation is a natural
      process that uses microorganisms, such as bacteria,
      fungi, or yeast, that "eat" harmful contaminants and
      transform them into nonhazardous products. Thermal
      desorption and incineration are the same technologies
      described above to  treat VOCs in soils. Immobilization
      does not treat  the contaminants, but rather prevents them
      from spreading. This process mixes the hazardous
      substances with chemicals and cement-like materials to
      bind them and makes them immobile and  inactive.
-(7. J/What is the presumptive remedy for a site with
   ' "contaminated ground water?

  ''.T'tWe use a response strategy to address sites with
 ~S~~ .contaminated ground water. This means we take a phased
     approach to characterize and clean the site. Information
     from each sequence of steps, or phase, helps us to
     improve future investigations or actions. Basically, this
     presumptive remedy helps us with the process of selecting
     a remedy rather than choosing a particular remedy.
   -.'-^ -v.
 '%. ./Couldn't this "cookie cutter" approach overlook
     special problems at my site?

   j. No. Presumptive remedies are  meant to improve the
 / ", remedy selection process, not undermine it. Our site
     investigation professionals use their expertise  to
     examine every site carefully. EPA is committed to the
     best and the safest cleanup for every community. And  .
     Superfund understands your community's need to find a
     unique solution to your unique problems. You can rest
     assured that when a  full-length investigation of the
     remedy alternatives  is considered necessary, we will
     do it.

•(9. iCan the community ask EPA to consider other
     cleanup alternatives?

   v\ Your voice will be heard! Communities are  full partners
/;^.'in the remedy selection process.  If residents request it,
     we will  consider investigating other cleanup approaches
     even if a presumptive remedy exists, or give you a full
     explanation of why the presumptive remedy was
     selected. We will assess each suggested alternative on its
     own merits, and may proceed with further studies.

     Presumptive remedies still add value even if we include
     other approaches. Presumptive remedies provide a
     baseline for protecting human health and the
     environment; if we consider other specific cleanup
     alternatives,  they add additional layers of protection.

     For more information about each presumptive
     remedy, see the box  titled "For Further Reading."
                         For Further Reading
                         The following documents are available at:

                         National Technical Information Service (NTIS)
                         (703) 487-4650  (800) 553-NTIS (rush service only)

                         •    VOCs in Soil, EPA 540F-93-048/PB93-963346
                         •    Municipal Landfills, EPA 540-F-93-035/PB93-963339
                         •    Wood Treater Sites, EPA 540/R-95/128 PB-963410
                         •    Ground Water Strategy, EPA 540/R-96/023 PB96-963508

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