Document e5YVyZOKR6bodj6vMq8oy3Dee

NCP Issues for Comments 51407 51409 10 51413 51415 51415 51415 51416 51418 51418 51419 51419 51420 Definition of "on-site" for permitting purposes. ) J0&. 406 j o Removal limitation implementation. ) V/f* j /few o Deferral policy/remedial site evaluation policy) (PA/SI) J -A*.. J/fe ^2/ \Merits of creating a construction completion category for sites on the NPL. ^ Whether deferral should.be extended to state authorities. * Whether deferral should be extended to sites where PRPs enter into Federal enforcement agreements for site remediation. Deferral policy .% extension to other federal authorities. The appropriateness of deferring generally to Federal authorities and whether these authoritie should be required to meet some or all CERCLA standards. JCO. r* Comments on two state deferral options deferral based on State petition requesting deferral. f&cA/sJ -y Jt/t&y/.: / ' //t6r/ 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 Deferral policy - sites regulated by multiple authorities. Deferral of sites with agreements under 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 CTL018748 subsequently agrees to perform RD/RA pursuant to consent decree. Appropriate method for identifying problem sites, if those sites are not proposed for the NPL because of deferral to CERCLA enforcement agreement. Deferring placement of sites on NPL when other authorities are available to address / contamination at the site and deferring sites I when PRPs have signed enforceable CERCLA consent! orders. 1 Deleting final sites based upon deferral to other authorities/criteria Risk ranges -_wo in particular current 10~ to.10 alternative 10~ to 10~ issues related to these or alternative ranges risk 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 cost- effectiveness screen .. sequential decision making approach'*' Appropriateness and desirability of pursuing on of the following alternative strategies point of departure tj site stabilization ~ J06. VM *'/*f f f Atsvejy 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 CTL018749 VC 51433-5 o Groundwater remediation approach -{ 7T ~W~ -TT 51436 ( Criteria for ARARs 51439-4CW 1 o Waiver of ARARs interim remedy equivalent performance fund balancing - specific amount V Where ARARs must and TBCs should be attained 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. J 51454 Whether ten year O&M rule should extend to situations where primary purpose of ground watei ^ __ treatment is to provide drinking water supplies^ f from water contaminated at the site without restoring it. j CfJf j 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 1 J MerS "31468 Should a notice of availability of administrative record or of commencement of public comment } fperiod be published in the Federal Register?^ (administrative record for remedial action)'*' V[ CTL018750 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."^"" J CTL018751