Feasibility Study
Overview on Superfund Cleanup Criteria
There are seven basic criteria the EPA uses for choosing a cleanup option.
However, not all of the criteria receive equal weight in choosing an option.
Overall protection of human health and the environment
For the most part human health is the deciding factor and most Remedial
Investigations do not conduct significant environmental impact studies. The
exceptions may be if an endangered or threatened species is known.
The risk assessment portion of the feasibility plan is used as the
yardstick to meet this criteria.
Compliance with Applicable or Relevant and Appropriate Requirements
In part, a self-fulfilling criteria since Federal projects cannot violate
Federal laws. The Endangered Species Act and more stringent State laws are often
dealt with under this criteria. Often when a regulation does not exist a closely
related rule may be applied. Statutes related to mining applied to an
excavation, for example, or usage of an OSHA requirement for particulate
densities in a marsh.
Cost
Everyone agrees that this is one of the most important criteria. It is
generally the least expensive proposal that meets the requirements of the
"Overall Protection" criteria that gets chosen.
Implementability
At first glance this criteria appears to also be self-fulfilling since an
unimplementable criteria would not be chosen. However, implementability usually
refers to administrative implementation, not technical implementation.
Short-term effectiveness
Since there are often several stages to a cleanup short-term effectiveness
often comes into play during the remedial investigation/remedial planning
stages. For example, cleanup of an adjacent neighborhood in advance of a site
cleanup, or construction of temporary cells or berms to reduce off-site
migration, are short-term effective remedies.
Long-term effectiveness
This is a very important consideration in choosing a criteria. For all
practical purposes a cleanup must be effective permanently- such as restoring
the area to nontoxicity, or the site must be stabile and nontoxic on a
generation time scale.
Reduction of toxicity, mobility or volume
These aspects of the criteria are often interchangeable. For example,
mixing in 20% cement to form a stabilized mass reduces mobility, has no effect
on toxicity, but increases volume. Simple dilution may increase mobility and
volume, but decrease toxicity.
State Acceptance
This is not a true criteria, but instead a "modifying criteria.' In
practice the EPA does not need state approval, but usually seeks to meet state
regulators needs at a site.
Community Acceptance
This criteria is also a modifying criteria, and carries much less weight
than state acceptance.
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