Engineering and Expeditionary Warfare Center

Remedy Selection

Rem_Selection

Overview

 

The Remedy Selection phase identifies a preferred response action based on the comparative analysis of remedial alternatives developed in the Feasibility Study (FS). Remedy Selection includes the development of a Proposed Plan (PP) for review and comment by the public and other stakeholders. This is followed by the development of a Record of Decision (ROD)/Decision Document (DD), which details the rationale for the selected remedial action.

Jump to Resources to access Policies & Guidance, Publications, Related Sites, and Tools

 

Process

 

Remedy Selection builds on the comparison of remedial strategies and recommendations developed in the FS. During this step, the preferred alternative is identified and described in a PP. After review and comment by the public and other stakeholders, the selected alternative is documented in a ROD or DD.

Proposed Plan

The PP identifies the preferred alternative for the site and briefly describes other remedial alternatives that were analyzed. The rationale for selection of the preferred alternative is summarized in accordance with the nine criteria described in the National Contingency Plan (NCP) [40 CFR Part 300]. The Department of the Navy (DON) makes the PP available for public comment and hosts a public meeting to discuss the plan. After the comment period is completed, DON prepares a Responsiveness Summary, which documents significant comments and responses, along with any new relevant information submitted by stakeholders.

Record of Decision/Decision Document

The preferred alternative presented in the PP is then formalized in a written ROD/DD. The ROD/DD should identify the applicable legal authority for the response, describe the hazards and unacceptable risks necessitating the response, and summarize the evaluation criteria used during remedy selection. For petroleum or Resource Conservation and Recovery Act (RCRA) sites where the NCP does not apply, applicable requirements for DDs should be followed. All RODs/DDs must undergo the enhanced internal NAVFAC review process called Quality Document Review (QDR) before final approval. The ROD/DD must be signed before a remedial action is initiated. The ROD is a legally-binding agreement between DON and regulatory agencies and therefore changing the ROD can be a complicated process. For this reason, the ROD should be carefully developed to allow for flexibility in addressing evolving site conditions and accommodating technology transitions over time. Additional information on building flexible RODs is provided in the DON Guidance for Optimizing Remedy Evaluation, Selection, and Design. When RAOs cannot likely be achieved within a reasonable timeframe, the RODs can incorporate flexibility through the use of interim performance objectives.

The PP and ROD/DD contents are outlined by the Environmental Protection Agency’s (EPA’s) A Guide to Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection Decision Documents (OSWER 9200 1-23P). The ROD Toolkit is a supplemental resource to EPA ROD Guidance to support the development of effective and streamlined documents. A QDR is required for the PP and ROD documents prior to submittal to regulatory agencies.

For more information, Chapter 9 of the DON Environmental Restoration Program Manual details PP and ROD/DD considerations.

Resources

 

Topics

Title and Description

ERP Manual

DON Environmental Restoration Program Manual: Chapter 9 Remedy Selection (February 2018)

Outlines key considerations for remedy selection including preparation of the PP and ROD/DD.

Document Review

NAVFAC ER,N Program Directive for Quality Document Review (QDR) of DON Installation Restoration Program (IRP) Sites (June 2018)

Summarizes the process for obtaining the required internal reviews of key documents including the PP and ROD/DD.

Optimization Policy

DON Policy for Optimizing Remedial and Removal Actions at All DON Environmental Restoration Program Sites (April 2012)

Clarifies when to perform optimization reviews and provides effective strategies to meet remedial action objectives. Requires consideration of: 1) green and sustainable remediation (GSR) metrics; 2) remedial alternatives analysis (RAA); and 3) the Management and Monitoring Approach (MMA).

GSR Metrics

DON Guidance on Green Sustainable Remediation (April 2012)

Discusses how to incorporate GSR metrics into projects. Methods for evaluating remedy footprint are discussed, along with case studies and recommended strategies for footprint reduction.

ROD Toolkit

NAVFAC Guidance on Toolkit for Preparing CERCLA Records of Decision (November 2011)

Provides direction for the preparation of Navy decision documents using the EPA ROD Toolkit (2011). The ROD Toolkit is linked in the Publications section below.

Remedy Evaluation

DON Guidance for Optimizing Remedy Evaluation, Selection, and Design (March 2010)

Provides a general overview and explanation of key optimization concepts as they pertain to the FS, ROD, and Remedial Design (RD) and provides specific recommendations for optimizing remedy selection and design.

Streamlined ROD

DON Strategy Memo Streamlined Record of Decision Strategy (August 2007)

Promotes the use of a streamlined ROD, which utilizes an innovative format to present the remedy selection for a site.

ROD Policy

DON CERCLA ROD and Post-ROD Policy (January 2004)

Describes a framework for implementing land use controls (LUCs) including documentation of LUC objectives in the ROD.

Topics

Title and Description

ROD Toolkit

Toolkit for Preparing CERCLA Records of Decision (OWSER 9355.6-10)  

Summarizes communication and graphical tools to effectively convey information in a concise manner, while presenting the full rationale for remedy selection in a streamlined ROD.

ARARs Toolkit

NAVFAC Toolkit for Identifying Applicable or Relevant and Appropriate Requirements (ARARs) (August 2014)

Outlines the key concepts in identifying and documenting ARARs.

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