CERCLA Remedial Action Site Closure Guidance

Figure 2 Pre-Remedial Activities for CERCLA Operable Units

II-B Remedial Investigation/Feasibility Study (RI/FS)   [top]
The CERCLA remedial investigation/feasibility study (RI/FS) is the methodology used to first characterize the nature, extent, and risks posed by uncontrolled releases of hazardous contaminants, and second, to make an informed decision for evaluating potential remedial options. The primary steps in the RI/FS methodology include:

• Scoping the RI/FS
  
• Conducting the RI: Site Characterization
  
• Conducting the RI: Baseline Risk Assessment
  
• Developing the RI Report
  
• Feasibility Study: Development and Screening of Alternatives
  
• Treatability Studies
  
• Feasibility Study: Detailed Analysis of the Alternatives
  
• Developing the FS Report
  
• Integrating the RI and FS Reports

II-C Remedy Selection   [top]
Following the detailed analysis and feasibility study of remediation alternatives, DOE identifies a preferred alternative for the remedial action that best meets the five statutory requirements as described in CERCLA Section 121:

• Protect human health and the environment;
  
• Attain Applicable or Relevant and Appropriate Requirements (ARARs) or provide reasons for not achieving ARARs;
  
• Be cost effective;
  
• Utilize permanent solutions, alternative solutions, or resource recovery technologies to the maximum extent possible; and
  
• Satisfy the preference for treatment that reduces the toxicity, mobility, or volume of the contaminants as opposed to an alternative that provides only for containment.

In addition to the above statutory requirements for remedial actions, the NCP established nine ‘evaluation criteria’ [40 CFR 300.430(e)(9)(iii)] to judge each alternative. These nine criteria are grouped by, two ‘threshold criteria,’ five ‘primary balancing criteria,’ and finally, two ‘modifying criteria.’ These criteria are based on the CERCLA five statutory requirements in Section 121.

II-D Proposed Plan   [top]
The preferred alternative identified by DOE is presented to the public in the Proposed Plan. A Proposed Plan is required under 40 CFR 330.430(f)(2) . The Proposed Plan describes the remedial alternatives analyzed, identifies the preferred alternative, and discusses the rationale for its selection. It supplements the RI/FS report and is released for public comment along with the RI/FS report. This provides the public with an opportunity to examine and comment on remediation alternatives (including the preferred alternative) and participate in the remedy selection process as required under 40 CFR 300.430(f)(3) .

II-E Record of Decision (ROD)   [top]
When the final remedy is agreed upon and selected, 40 CFR 300.430(f) requires that the decision be documented in the ROD. The ROD is a formal, legal mechanism for documenting the remedy selection process and the analyses and policy determinations that support selection of the final remedy. Under 40 CFR 300.430(f)(5) , the ROD must describe the following:

• How the remedy is protective of human health and the environment, and how it eliminates, reduces, or controls exposure to hazardous substances, pollutants, and contaminants;
  
• The Federal and State ARARs the remedy will attain, those that will not be met and the justification for waivers;
  
• How the remedy is cost effective; and
  
• How the remedy uses permanent solutions and alternative treatment or resource recovery technologies to the maximum extent practicable.

DOE must publish a notice of availability for the ROD, include the ROD in the administrative record for the site, and make it available for public inspection.

• Review the objectives established for the RA;
  
• Revise the Community Relations Plan;
  
• Develop an RD Strategy Document;
  
• Prepare a complete set of detailed construction drawings, document all engineering calculations, and prepare a complete set of process flow diagrams for the RA;
  
• Develop a list of and specifications for all equipment and materials required to implement the RA;
  
• Prepare operational guidance for the remedy;
  
• Develop a cost estimate and proposed schedule;
  
• Revise the Quality Assurance Project Plan used during the RI/FS and Develop a Construction Quality Assurance Plan; and
  
• Revise the Health and Safety Plan used during the RI/FS.

Once the RD process is complete, DOE should provide these documents to EPA and the State for their review. These documents are usually identified in the Federal Facility Agreement (FFA) or Consent Agreement. EPA and the State will review and either approve or reject the documents. Only when EPA and the State have approved the documents should actual construction of the remedy begin.