Formatted Title:

Want to Speed up CERCLA? Expedited Path to Remediation

Background/Objectives:

Most sediment remediation sites have an upland component to transload material from the waterway to land and vice versa. If the remedial action includes dredging, the upland component often also includes a sediment processing area. If the remedial action includes capping, amendment, or in situ stabilization (ISS), the upland component often also includes a material stockpiling area. The upland areas are critical to the success of the remedial action. Typically, the upland areas need to be constructed ahead of the remedial action of dredging, capping, placing amendment, or performing ISS. The duration to construct the upland area prolongs the remedial action schedule. This presentation will evaluate an alternative approach to sequence upland component design and construction within Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) to consolidate the schedule for starting the remedial action.

Approach/Activities:

The typical CERCLA tasks once the Record of Decision is issued include remedial design, remedial action work plan, consent decree or administrative order on consent, permit equivalencies, contracting, and access. Once these tasks are completed, the remedial action begins. The construction of the upland component may take months to more than a year, delaying the start of sediment remediation. As the upland component construction does not involve remediating sediment, it could start in parallel with the post Record of Decision CERCLA process for the sediment remediation. Project examples of working within CERCLA to sequence the upland component ahead of the remedial action will be discussed.

Results/Lessons Learned:

The upland component design can be front loaded for United States Environmental Protection Agency's (USEPA) review in advance of the remedial action design. For efficiency, common design elements between the upland component and the remedial action can be shared to eliminate duplication in the designs. Access negotiations for the upland component are often performed during design as the upland area needs to be identified and access secured for the site-specific upland design. The consent decree or administrative order on consent for the remedial design can include the design and construction of the upland component. The applicable or relevant and appropriate requirements and associated permit equivalency for the upland component is often less than for the remedial action, leading to more quickly meeting the substantive requirements. Collaboration between USEPA and the potentially responsible parties facilitates optimizing the remedial action schedule.

Leanne Austrins

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Want to Speed up CERCLA? Expedited Path to Remediation