UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
| WASHINGTON, D.C. 20460
PRO OFFICE OF
LAND AND EMERGENCY
MANAGEMENT
formerly
OFFICE OF
SOLID WASTE AND
DEC 2 8 2016 EMERGENCY RESPONSE
OLEM Directive 9200.3-117
MEMORANDUM
SUBJECT: Clarification of the Consultation Process for Evaluating the Technical
Impracticability of Groundwater Restoration at G£RCLA Sites
FROM: James E. Woolford, Directoryfj * *""**
Office of Superfund Remedi^ion and Technology Innovation
Charlotte Bertrand, Dir^c^^
Federal Facilities Restoration and Reuse Office
TO: Superfund National Policy Managers, Regions 1-10
PURPOSE
The purpose of this memo is to clarify the U.S. Environmental Protection Agency's (EPA's)
internal consultation process for Superfund groundwater technical impracticability (TI)
Evaluations. It also provides recommendations on how to prepare technically sound TI
Evaluation documents when considering whether a Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) groundwater cleanup site merits an applicable or
relevant and appropriate requirement (ARAR) waiver. This memo is applicable to groundwater
TI Evaluations for Superfund sites, including federal facilities. The memo establishes no new
TI waiver policies for Superfund groundwater sites but, rather, provides clarification for
existing relevant Superfund policy and guidance. It also includes recommendations for
planning and developing TI Evaluation packages and describes the recommended process for
EPA internal review and approval.
The memo transmits five new recommended products: 1) Technical Impracticability
Evaluation Consultation Process Flowchart, 2) Technical Impracticability Evaluation Work-
Planning Flowchart, 3) Regional Technical Impracticability Evaluation Work-Planning
Spreadsheet, 4) Technical Impracticability Evaluation Internal EPA Review Routing Slip, and
198193
Intemel Address (URL) http://www.epa. gov
Recycled/Recyclable Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper
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5) Recommended Summary Checklist for a Superfund Groundwater Technical Impracticability
Evaluation. A workgroup of representatives from the Office of Superfund Remediation and
Technology Innovation (OSRTI), Federal Facilities Restoration and Reuse Office (FFRRO),
and EPA regional groundwater TI contacts prepared these products. These attachments, as well
as the memo, are part of a continuing effort to provide recommendations to help promote
technically sound TI Evaluations and facilitate an effective and consistent consultation process.
BACKGROUND
One of the key existing policy principles for groundwater cleanup/restoration in the Superfund
program is that "Technical impracticability waivers and other waivers may be considered, and
under appropriate circumstances granted if the statutory criteria are met, when groundwater
cleanup is impracticable; the waiver decision should be scientifically supported and clearly
documented."1 The 1993 Guidance for Evaluating the Technical Impracticability of Ground-
Water Restoration2 discusses how EPA considers site-specific factors to evaluate "whether
ground-water [s/'c] restoration is technically impracticable and what alternative measures or
actions must be undertaken to ensure that the final remedy is protective of human health and
the environment." The 1993 guidance includes recommendations on "the types of technical
data and analyses needed to support EPA's evaluation of a particular site and the criteria used to
make a determination." A subsequent guidance entitled Consistent Implementation of the FY
1993 Guidance on Technical Impracticability of Ground-Water [sic] Restoration at Superfund
Sites3 includes recommendations designed to help:
Promote national consistency in TI decision making;
Facilitate transfer of information pertinent to TI decisions between Headquarters and
the regions;
Identify the appropriate persons to conduct reviews of Tl-related documents; and
Clarify the role of Headquarters consultation.
IMPLEMENTATION
The Technical Impracticability Evaluation Consultation Process Flowchart (Attachment 1) lays
out the recommended process for internal EPA review of the TI Evaluation by the regional
offices and Headquarters, specifically the Office of Land and Emergency Management (OLEM).
The Superfund Remedial Project Manager (RPM) generally is a site's overall lead. The site
hydrogeologist or other designated groundwater expert and the regional TI contact (Table I) are
an integral part of the regional TI Evaluation review team. The review team should be included
in relevant technical and policy discussions throughout the TI Evaluation process. EPA regional
' Summary of Key Existing EPA CERCLA Policies for Groundwater Restoration. OSWER Directive 9283.1, June
2009. http://seinspub.epa.gov/src/docuinent/HQ/175202
2
Guidance for Evaluating the Technical Impracticability of Ground-Water Restoration. OSWER Directive 9234.2-
25, September 1993. https://seinspub.epa.eov/src/docuinent/HO/1 75387
3
Consistent Implementation of the FY 1993 Guidance on Technical Impracticability of Ground-Water Restoration
at Superfund Sites. OSWER Directive 9200.4-14, January 19, 1995. https://senispub.epa.gov/src/
document/HQ/1 74489
2
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managers should be included in the regional review process. The regional TI contact is the
liaison with the OLEM Tl contact during the TI Evaluation process.
It may be beneficial for the potentially responsible party (PRP) or lead agency seeking the TI
waiver and the Tl Evaluation author (generally a contractor supporting the site) to conduct a pre-
planning call or meeting with regional staff and, as appropriate, OLEM before developing the
document. OLEM recommends that these calls or meetings continue throughout the TI
Evaluation process, as needed. The regional team will review the Tl Evaluation for technical
criteria and policy in accordance with the 1993 TI guidance. The regional office will determine
whether the document should be: 1) sent forward to OLEM for consultation, 2) returned to the
author with comments to be addressed or 3) terminated if the TI Evaluation cannot be adequately
supported. Scenarios 1 and 2 will eventually direct the TI Evaluation to OLEM for consultation;
however, Scenario 2 will likely require additional technical assessment, which may include
collection of additional site data to satisfy the TI criteria. If the region is considering terminating
the Tl Evaluation at this point, the region can contact OLEM to provide additional policy and
technical input to the decision, when needed.
When OLEM receives a regional Tl Evaluation, it will review and determine whether the
Evaluation satisfies the TI criteria. If it does, OLEM will provide the region with a written
response that the TI consultation is complete. However, if OLEM determines that the document
does not satisfy the TI criteria, OLEM will initiate the TI issue resolution process. OLEM will
provide written comments to the region. The process may also include one or more calls between
OLEM and the region. After the call(s), if OLEM and the region agree that the TI Evaluation can
be revised to satisfy TI criteria, the region will return the TI Evaluation to the author for revision.
The region will provide a final revised version to OLEM, and OLEM will provide the region
with a written response that the Tl consultation is complete. However, if there is still
disagreement between OLEM and the region about the Evaluation, the region or OLEM will
document outstanding issues and elevate them for resolution per Elevating Site-Specific
Superfund Remedy Selection Issues between the Office of Superfund Remediation and
Technology Innovation and Regional Superfund Program Offices.*' The result of this process will
either lead to proceeding with the TI Evaluation with or without revision, or terminating the
Evaluation, The site administrative record, in accordance with the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP) §300.810 and the 1993 Tl guidance (Section 6.1),
should include applicable documents supporting the Tl Evaluation decision.
Elevating Site-Specific Superfund Remedy Selection Issues between the Office of Superfund Remediation and
Technology Innovation and Regional Superfund Program Offices. Directive 9200.3-68, March 31, 2010.
htias://seriiSDi)b.er)a.iiov/sic/dDcunient/HO/886038
3
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Table 1
Regional and OLEM Technical Impracticability Contacts
Region 1
Bill Brandon
Region 6
Vince Malott
Region 2
Robert Alvey and John Prince
Region 7
Dan Nicoski
Region 3
Kathy Davies
Region 8
Andrew Schmidt and Fran Costanzi
Region 4
Bill Osteen
Region 9
Herb Levine
Region 5
David Wilson
Region 10
Jonathan Williams
OSRTI
Dave Bartenfelder
FFRRO
Ben Simes
OLEM and the regions should use the Technical Impracticability Evaluation Work-Planning
Flowchart (Attachment 2) and the Regional Technical Impracticability Evaluation Work-
Planning Spreadsheet (Attachment 3) together to help staff manage and plan workload and
timing of a given document review during a fiscal year in order to ensure adequate review
opportunities throughout the consultation process. The intent of the Flowchart and
Spreadsheet is also to help plan for sufficient time to develop information and data for
inclusion in the administrative record to support a TI waiver in the proposed and final decision
documents (i.e.. Record of Decision [ROD] and ROD Amendment). If there is a delay
between the consultation and finalizing the decision document, the outcome of the TI waiver
consultation is valid as long as site conditions, the conceptual site model, and available
remedial approaches remain the same. If, however, site conditions or state of practice for
remedial alternatives change between the TI consultation and the development of the final
decision documentation, OLEM recommends that the region and OLEM revisit the TI
consultation to account for those changes. Changes in site conditions can include, but are not
limited to: identification of new contaminants of concern (COCs), changes in COC
concentration(s), and changes in the vertical and/or horizontal boundaries of the groundwater
plume.
The purpose of the recommended Technical Impracticability Evaluation Internal EPA Review
Routing Slip (Attachment 4) is to identify the regional TI contact who is the liaison with OLEM,
and to help ensure that the appropriate regional and OLEM staff and management have been
informed and have adequate opportunity to provide input on the TI Evaluation. OLEM review
includes OSRTI for non-federal facilities and both OSRT1 and FFRRO for federal facilities.
Finally, the Recommended Summary Checklist for a Superfund Groundwater Technical
Impracticability Evaluation (Attachment 5) identifies many of the important technical
components, consistent with the 1993 TI guidance, for consideration in a TI Evaluation.
Regions and others may use the Summary Checklist in preparing and reviewing TI
Evaluations for consistency and adequacy, although not all items in the checklist are
applicable to every site. The TI Evaluation should be a stand-alone document that addresses
the applicable criteria with sufficient detail to support the Evaluation, while being as concise
as possible. The complexity of the site and TI issues should drive the length of the document,
although it is recommended that the document not exceed 150 pages, excluding summary
maps, data and other information.
4
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If you or your staff have any questions about this memo or the TI waiver process, please
contact Dave Bartenfelder, OSRTI Science Policy Branch, at (703) 603-9047. This document
is available at https://www.cpa.gov/supertund/
supcrfund-groundwater-groundwater-responsc-sc lection.
Attachments (5)
cc: Mathy Stanislaus, OLEM
Barry Breen, OLEM
Nitin Natarajan, OLEM
Reggie Cheatham, OLEM/OEM
David Lloyd, OLEM/OBLR
Barnes Johnson, OLEM/ORCR
Carolyn Hoskinson, OLEM/OUST
Cyndy Mackey, OECA/OSRE
Richard L. Albores, OECA/FFEO
John Michaud, OGC/SWERLO
Dana Stalcup, OLEM/OSRTI/ARD
Monica Gardner, OECA/OSRE/PPED
Mike Scozzafava, OLEM/OSRTI/ARD
Dave Bartenfelder, OLEM/OSRTI/ARD
Ben Simes, OLEM/FFRRO
Jill Lowe, Superfund Lead Region
Coordinator, US EPA Region 3
Federal Facility Program Managers
FFRRO Regional Coordinators
Regional Technical Impracticability Contacts
NARPM Co-Chairs
Technical Support Project Forum Co-Chairs
5
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Attachment 1
Technical Impracticability Evaluation
Consultation Process Flowchart
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OLEM Directive 9200.3-117
Technical Impracticability Evaluation Consultation
Process Flowchart
Region conducts pre-TI planning call
or meeting with Tl stakeholders
(Includes OLEM as appropriate)
Yes
r
Submit Tl Evaluation for
OLEM1 review
Region documents
termination of Tl Evaluation
Yes
Yes, without Revision
OLEM documents decision
and completion of Tl
consultation
Proceed, with Revision
Issues elevated to appropriate
OLEM and regional managers for
resolution
Decision reached per elevation
process
Proceed without Revision
Terminate Tl Evaluation
OLEM documents decision
to terminate Tl Evaluation
and consultation
Tl = Technical impracticability; OLEM = Office of Land and Emergency Management
1For nonfederal facilities, Office of Supefund Remediation and Technology Innovation (OSRTI); for federal facilities,
OSRTI and Federal Facilities Restoration and Reuse Office (FFRRO).
2Elevating Site-Specific Superfund Remedy Selection Issues between OSRTI and Regional Superfund Program Offices.
OSWER Directive 9200.3-68, March 31, 2010.
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Attachment 2
Technical Impracticability Evaluation
Work-Planning Flowchart
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OLEM Directive 9200.3-117
Technical Impracticability Evaluation Work-Planning Flowchart*
*Notes about EPA OLEM reviews of TI Evaluations:
1. For annual reporting, use TI Evaluation Work- Planning Spreadsheet.
2. Plan for 6 weeks for initial OLEM review.
3. TI Evaluation completed prior to Proposed Plan and ROD or ROD Amendment.
4. If there is a delay between the consultation and finalizing the decision document, the outcome of the TI waiver consultation is valid as long as
site conditions, the conceptual site model, and available remedial approaches remain the same. If, however, site conditions or state of practice
for remedial alternatives change between the TI consultation and the development of the final decision documentation, OLEM recommends that
the region and OLEM revisit the TI consultation to account for those changes. Changes in site conditions can include, but are not limited to:
identification of new contaminants of concern (COCs), changes in COC concentration(s), and changes in the vertical and/or horizontal
boundaries of the groundwater plume.
5. OLEM = Office of Land and Emergency Management (OSRTI = Office of Superfund Remediation and Technology Innovation; FFRRO = Federal
Facilities Restoration and Reuse Office); TI = Technical impracticability
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Attachment 3
Regional Technical Impracticability Evaluation
Work-Planning Spreadsheet
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OLEM Directive 9200.3-117
Regional Technical Impracticability Evaluation Work-Planning Spreadsheet1
Region
Site Name/OU
Lead
(EPA,
State,
Federal,
Private)
Names ofRPM(s) &
Regional Site
Hydrogeologist (if
applicable)
Estimated TI
Evaluation
Submittal Date
(FY/Q)
Estimated
Proposed Plan
Date (FY/Q)
Estimated
Decision Document
Date & Type
(ROD or AROD)
(FY/Q)
Actual Decision
Document Date &
Type (ROD or
AROD) or Date
Terminatedor
Withdrawn
1 Regional TI contact will provide to OLEM TI contact. Includes TI Evaluations under consideration.
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Attachment 4
Technical Impracticability Evaluation
Internal EPA Review Routing Slip
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OLEM Directive 9200.3-117
Technical Impracticability Evaluation Internal EPA Review Routing Slip1
(For Tracking Purposes Only)
Region
SiteName/OU
Version
Reviewer
Reviewer Signature, Date
Remedial Project Manager
Regional Site Hydrogeologist or Other Designated
Groundwater Expert
Regional TI Contact2
Regional Manager(s)
Other Regional Reviewer (if appropriate)
Regional TI Contact for transmittal to OLEM
OLEM TI Contact
OLEM Manager(s)
1 The purpose of this routing slip is to submit final draft TI Evaluations to OLEM. OLEM could also potentially route these
documents back to the region (and subsequently the PRP) to address technical and policy issues. The process could be an
iterative one that might take several cycles to complete.
2 For those regions where multiple TI contacts have been designated, more than one signature may be needed.
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Attachment 5
Recommended Summary Checklist for a Superfund Groundwater
Technical Impracticability Evaluation
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A rnA OLEM Directive 9200.3-117
svtra December 2016
United States
Environmental Protection
Agency
Recommended Summary Checklist for a Superfund Groundwater
Technical Impracticability Evaluation
Purpose and Scope
The purpose of this "Recommended Summary Checklist for a Superfund Groundwater Technical
Impracticability Evaluation " ("Summary Checklist") is to facilitate the preparation and review
of an evaluation of a technical impracticability (TI) waiver for groundwater at a Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA) National Priorities List
site. The Summary Checklist does not modify the 1993 Guidance for Evaluating the Technical
Impracticability of Ground-Water Restoration ("1993 TI guidance").1 The checklist is intended
to help ensure that the TI evaluation process encompasses key technical components of the 1993
TI guidance. Generally, a TI Evaluation should address these elements to help reviewers decide
whether a TI waiver is appropriate based on the site-specific circumstances at a CERCLA
groundwater cleanup site. Regions and others preparing and reviewing TI Evaluations for
consistency and adequacy may use the Summary Checklist, although not all items in the
checklist are applicable to every site. In addition to using this document, regions should consider
the recommendations in the 1993 TI guidance to help develop adequate information for
inclusion in both the TI Evaluation and the administrative record to ensure support of a TI
waiver.
Depending on site-specific circumstances, the inclusion of the Summary Checklist information in
the TI Evaluation may not necessarily ensure that the TI Evaluation reflects consideration of all
of the appropriate criteria for making a TI waiver decision.
Length of the Technical Impracticability Evaluation
It is recommended that the TI Evaluation be a stand-alone document that addresses the applicable
criteria with sufficient detail to support the Evaluation, while being as concise as possible. The
complexity of the site and TI issues should drive the length of the document, although it is unlikely
that it would need to be more than 150 pages, excluding summary maps, data and other
information. A longer document would be too difficult and cumbersome for reviewers and the
public.
1 Guidance for Evaluating the Technical Impracticability of Ground-Water Restoration. OSWER Directive 9234.2-25,
September 1993. https ://semspub .epa. gov/work/HO/1753 87 .pdf
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Use of the Summary Checklist
Each of the Summary Checklist's lettered and numbered sections corresponds to 1993 TI guidance
sections, which are indicated in brackets. As noted above, additional supporting information can
be included as appendices.
Each section contains a list of topics that correspond to recommendations in the 1993 TI
guidance. In general, the TI Evaluation should address each of these topics in the body of the TI
evaluation. The Summary Checklist is designed for those preparing and reviewing a TI
evaluation to use as a way of affirming that each topic is considered.
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RECOMMENDED SUMMARY CHECKLIST FOR A SUPERFUND GROUNDWATER
TECHNICAL IMPRACTICABILITY EVALUATION
Site Name/OU Version
Name of Preparer/Reviewer Date
Regions should consider the recommended checklist below when evaluating whether they have
sufficient information to support a TI evaluation for the administrative record. [EPA 1993, 4.4]:
A. Specific ARARs or Media Cleanup Standards [EPA 1993, 4.4.1]
^Identifies the specific ARARs for which the TI waiver is sought (TI eval. pp. )
~ Identifies the technical feasibility of restoring some of the groundwater contaminants
(TI eval. pp. )
~ Identifies potential benefits of attaining ARARs for some of the specific COCs
(TI eval. pp. )
B. Spatial Extent of TIDecisions [EPA 1993, 4.4.2]
Q Specifies the spatial distribution (vertical and horizontal) of subsurface contaminants in
the unsaturated and saturated zones where the TI is sought (TI eval. pp. )
^Identifies the spatial extent of the TI zone as small as possible (TI eval. pp. )
^Identifies the vertical limit of the TI zone in either absolute (e.g., mean sea level) or
relative (e.g., aquifer system) terms (TI eval. pp. )
C. Development and Purpose of the Site Conceptual Model [EPA 1993, 4.4.3, Figure 4]
1. Background Information [EPA 1993, 4.4.3]
I I Groundwater classification (TI eval. pp. )
^Location of potential environmental receptors (TI eval. pp. )
| | Nearby wellhead protection areas or sole-source aquifers (TI eval. pp. )
^Location of water supply wells (TI eval. pp. )
2. Geologic and Hydrologic Information [EPA 1993, 4.4.3]
~ Detailed description of regional and site geology (TI eval. pp. )
~ Physical properties of subsurface materials (TI eval. pp. )
I I Stratigraphy, including thickness, lateral extent, continuity of units, and presence of
depositional features, such as channel deposits, that may provide preferential pathways
for, or barriers to, contaminant transport (TI eval. pp. )
~ Hydraulic gradients (horizontal and vertical) (TI eval. pp. )
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QGeologic structures or other subsurface features that may form preferential pathways for
NAPL migration or zones of accumulation (TI eval. pp. )
| | Hydraulic properties of subsurface materials (TI eval. pp. )
Temporal variability in hydrologic conditions (TI eval. pp. )
~ Groundwater recharge and discharge information (TI eval. pp. )
~ Groundwater/surface water interactions (TI eval. pp. )
I I Characterization of secondary porosity features (e.g., fractures, karst features) to the
extent practicable (TI eval. pp )
I I Depth to groundwater (TI eval. pp. )
3. Contaminant Source and Release Information [EPA 1993, 4.4.3]
~ Location, nature, and history of previous contaminant releases or sources
(TI eval. pp. )
~ Locations and characterizations of continuing releases or sources (TI eval. pp. )
~ Locations of subsurface sources (e.g., NAPLs) (TI eval. pp. )
4. Contaminant Distribution, Transport, and Fate Parameters [EPA 1993, 4.4.3]
^Temporal trends in contaminant concentrations in each phase (TI eval. pp. )
I lEstimates of subsurface contaminant mass (TI eval. pp. )
I IPhase distribution of each contaminant in the unsaturated and saturated zones (e.g.,
gaseous, aqueous, sorbed, free-phase NAPL, or residual NAPL) (TI eval. pp. )
I I Spatial distribution of subsurface contaminants in each phase in the unsaturated and
saturated zones (TI eval. pp. )
I I Sorption information, including contaminant retardation factors (TI eval. pp. )
I IContaminant transformation processes and rate estimates (TI eval. pp. )
I IContaminant migration rates (TI eval. pp. )
^Assessment of facilitated transport mechanisms (e.g., colloidal transport)
(TI eval. pp. )
^Properties of NAPLs that affect transport (e.g., composition, effective solubility, density,
viscosity) (TI eval. pp. )
I iGeochemical characteristics of subsurface media that affect contaminant transport and
fate (TI eval. pp. )
~ Other characteristics that affect distribution, transport, and fate (e.g., vapor transport
properties) (TI eval. pp. )
D. Evaluation of Restoration Potential [EPA 1993, 4.4.4]
1. Source Control Measures [EPA 1993. 4.4.4.1]
~ Demonstrates that contamination sources have been located and will employ removal,
migration control or containment, or treatment, to the extent practicable
(TI eval. pp. )
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2. Remedial Action Performance Analysis [EPA 1993. 4.4.4.2]
Q Demonstrates that the groundwater monitoring program within and outside the aqueous
contaminant plume is of sufficient quality and detail to fully evaluate remedial action
performance (e.g., to analyze plume migration or containment and identify concentration
trends within the remediation zone) (TI eval. pp. )
QDemonstrates that the existing remedy has been effectively operated and adequately
maintained (TI eval. pp. )
Describes and evaluates the effectiveness of any remedy modifications (whether
variations in operation, physical changes, or augmentations to the system) designed to
enhance its performance (TI eval. pp. )
~ Evaluates trends in subsurface contaminant concentrations. Consider such factors as
whether the aqueous plume has been contained, whether the areal extent of the plume is
being reduced, and the rates of contaminant concentration decline and contaminant mass
removal. Further considerations include whether aqueous-phase concentrations rebound
when the system is discontinued, whether dilution or other natural attenuation processes
are responsible for observed trends, and whether contaminated soils on site are
contaminating groundwater (TI eval. pp. )
~ Analyzes performance of any ongoing or completed remedial actions, including:
~ Operational information (TI eval. pp. )
~ Enhancements to original remedy (including optimization efforts) (TI eval. pp. )
3. Restoration Timeframe Analysis [EPA 1993. 4.4.4.3]
EH Estimates timeframe for groundwater restoration (TI eval. pp. )
I I Documents predictive analyses of the timeframes to attain required cleanup levels as part
of the overall demonstration using available technologies and approaches laying out the
associated modeling inputs and uncertainties (TI eval. pp. )
4. Other Applicable technologies [EPA 1993. 4.4.4.4]
~ Conducted and documented a literature search to determine what cleanup approaches are
possible based on the contaminants and geology at the site (TI eval. pp. )
I I Lists technologies and approaches that were evaluated (TI eval. pp. )
I I Analyzed chemical and hydrogeologic data to support any technology capable of
achieving cleanup levels (TI eval. pp. )
~ Evaluated treatability study data (bench, pilot or full-scale) (TI eval. pp. )
~ Provide study objectives (TI eval. pp. )
~ Provide study results (TI eval. pp. )
^Demonstrates that no other remedial technologies (conventional or innovative) could
reliably, logically, or feasibly attain the cleanup levels at the site within a reasonable
timeframe (TI eval. pp. )
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E. Cost Estimates [EPA 1993, 4.4.5]
~ Provides cost estimates for the potentially viable remedial alternatives included in the
Evaluation of Restoration Potential, including construction, operation and maintenance
costs (TI eval. pp. )
I I Provides cost estimates of selected remedy(s) for continued operation of existing remedy
including operation and maintenance costs (if a remedy has been implemented)
(TI eval. pp. )
~ Provides cost estimates for the proposed Alternative Remedial Strategy (ARS)
(TI eval. pp. )
F. Alternate Remedial Strategies (ARS) [EPA 1993, 5.0]
~ Selects and summarizes an ARS that is technically practicable, protective of human
health and the environment, and satisfies Superfund statutory and regulatory requirements
[EPA 1993, 5.1] (TI eval. pp. )
~ Demonstrates that the ARS addresses exposure prevention [EPA 1993, 5.1.1]
(TI eval. pp. )
I [Demonstrates that the ARS addresses source control and remediation [EPA 1993, 5.1.2]
(TI eval. pp. )
I [Demonstrates that the ARS addresses aqueous plume remediation [EPA 1993, 5.1.3]
(TI eval. pp. )
G. Additional Remedy Selection Considerations [EPA 1993, 5.2.3]
^Aggressive action for shorter timeframes than other options (TI eval. pp. )
| |Shorter timeframe to reduce potential human exposures (TI eval. pp. )
| IShorter timeframe to reduce impacts to environmental receptors (TI eval. pp. )
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Other
I I Discusses additional information or analyses considered for the TI evaluation
(summarized below, with page numbers, if applicable).
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