Document E75mVGZDY4b4vG0yaMZVk04L
NCP Issues for Comments
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o Definition of "on-site" for permitting purposes.
o Removal limitation implementation.
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o Deferral policy/remedial site evaluation poliiccyy.j
(PA/SI).
o Merits of creating a construction completion category for sites on the NPL. ^
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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
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Federal authorities and whether these authorities
should be required to meet some or all CERCLA standards.
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o Comments on two state deferral options deferral based on State petition requesting deferral.
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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
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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
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contamination at the site and deferring sites
when PRPs have signed enforceable CERCLA consentv
orders.
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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 ~
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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
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o Groundwater remediation approach
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i Criteria for ARARs
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Waiver of ARARs interim remedy equivalent performance fund balancing - specific
amount
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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.
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Whether ten year O&M rule should extend to
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situations where primary purpose of ground watei
treatment is to provide drinking water supplies /
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from water contaminated at the site without
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restoring it.
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Appropriateness of requiring regions to enter into SMOAs if states request them and have demonstrated capability to take the lead for response action.
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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?)
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Subpart H comments consistency with NCP for private party cleanups
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Should a notice of availability of administrative
record or of commencement of public comment
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period be published in the Federal Register?
(administrative record for remedial action)'^' I
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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
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administrative record for removal actions.*
o Comment on adding documents to record after selection of response action, tv"
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