Document E75mVGZDY4b4vG0yaMZVk04L

NCP Issues for Comments 51407 51409-10 51413 51415 51415 51415 51416 51418 51418 51419 51419 51420 o Definition of "on-site" for permitting purposes. o Removal limitation implementation. I o Deferral policy/remedial site evaluation poliiccyy.j (PA/SI). o Merits of creating a construction completion category for sites on the NPL. ^ -J/rr fyzi, o Whether deferra authorities. * be extended to state o Whether deferral should be extended to sites where PRPs enter into Federal enforcement agreements for site remediation. o Deferral policy.-j. extension to other federal authorities. * o The appropriateness of deferring generally to \ Federal authorities and whether these authorities should be required to meet some or all CERCLA standards. \ o Comments on two state deferral options deferral based on State petition requesting deferral. ^ //fax/6usJ deferral based on states certification of its commitment and ability to address the site according to CERCLA standards. - TAG grants public notice (public meeting) - ATSDR Non NPL listing for deferral sites o Deferral policy - sites regulated by multiple authorities. o Deferral of sites with agreements und^r CERCLA enforcement authorities - 2 options deferral prior to NPL proposal based on agreement to carry out EPA - RD/RA pursuant to consent decree. deferral at time of proposal based on agreement to conduct a RI/FS for that site, with the proposed sited dropped if PRP CTL016150 51420 r 51421 t 51421-2 51426 51431 51432 subsequently agrees to perform RD/RA pursuant to consent decree. o Appropriate method for identifying problem sites, if those sites are not proposed for the NPL because of deferral to CERCLA enforcement agreement. o Deferring placement of sites on NPL when other authorities are available to address / contamination at the site and deferring sites when PRPs have signed enforceable CERCLA consentv orders. 1 o Deleting final sites based upon deferral to other authorities/criteria o Risk ranges -two in particular current 10 to.10 alternative 10 to 10 issues related to these or alternative ranges Potential advantages and disadvantages of alternative site-specific balancing approaches related to type of criteria considered steps for making statutory findings degree of proposed structure ^ Two alternative approaches are site specific balancing with a costeffectiveness screen sequential decision making approach"*" Appropriateness and desirability of pursuing of the following alternative strategies - point of departure u, - site stabilization ~ on I jc>6. vsa f y</)esG//cj o Potential advantages and disadvantages of- the following analytical techniques screening against threshold criteria pairwise comparison ranking alternatives or criteria scoring (measuring alternatives against a consistent scale) weighting alternatives or criteria construction of a multi-attribute model cTL016151 51433-5 o Groundwater remediation approach \ rr -vrr -v~ 51436 i Criteria for ARARs 51439-40,. J Waiver of ARARs interim remedy equivalent performance fund balancing - specific amount CW Where ARARs must and TBCs should be attainec Community relations/public comment Community relations during RD/RA phases Interpretation of "restore ground and surface) water quality" and on the merits of alternatives EPA has not adopted. 51454 Whether ten year O&M rule should extend to JOC. situations where primary purpose of ground watei treatment is to provide drinking water supplies / f. from water contaminated at the site without j C*/i restoring it. 51454 51455 Appropriateness of requiring regions to enter into SMOAs if states request them and have demonstrated capability to take the lead for response action. \ 51456 o Comment on criteria for state lead designation overall expertise legal authorities administrative and contracting capability - financial management systems - availability of general resources complexity of site availability of site-specific resources workload and expertise past Federal and State actions at the site past State cleanup activity (should other criteria be added?) 51461 Subpart H comments consistency with NCP for private party cleanups "51468 Should a notice of availability of administrative record or of commencement of public comment ^ period be published in the Federal Register? (administrative record for remedial action)'^' I JZT CTL016152 51469 51469-70 51470 o Should public comment be solicited on activities that have already been completed at the time the record is made available? (administrative record for removal action) o Comment on approaches to developing ,, administrative record for removal actions.* o Comment on adding documents to record after selection of response action, tv" CTL016153