Tri-Service Remedial Project Manager's Guide for Ecological Risk ...

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l Identify ecological risks resulting from point (e.g., landfill leachate draining into astream) and non-point (e.g., airfield runoff) sources.l Distinguish between changes caused by chemical releases and those from naturalstresses or cycles.l Be non-destructive to the ecological component or the environment.l Promote a rapid turn-around from data collection to decisions on status of theenvironment and remediation.l Protect the existing biological communities within the larger ecosystem.+RZDUH(5$5HVXOWV8VHGIRU0DQDJHPHQWRID6LWH"The goal of the ERA is to provide enough information to assist the risk managers inmaking an informed decision. General management objectives are:l Identify and characterize current threats to the environment from a hazardoussubstance release.l Identify and characterize future threats to the environment from a hazardoussubstance release.RPMs can use ERA data to:l Characterize baseline risk to determinewhether cleanup should be considered.l Determine site-specific contaminantlevels that provide adequate protectionfrom unacceptable risks.l Evaluate remedial alternatives forpotential risks of the remedy.l Determine if the remedy is effectivelyreducing ecological risk.Rule of Thumb #3Criteria for determining “adequateprotection” and “unacceptable risks”should be decided by site managersand regulators before the ERA workplan is finalized. +RZGRHV(5$)LWLQWRWKH5HJXODWRU\&RQWH[W" This section presents a brief overview of the two primary environmental laws where anERA is required. All the requirements for investigation and cleanup of potential hazardouswaste sites are not listed here. &RPSUHKHQVLYH (QYLURQPHQW 5HVSRQVH &RPSHQVDWLRQ DQG /LDELOLW\$FW &(5&/$ DQG 6XSHUIXQG $PHQGPHQWV DQG 5HDXWKRUL]DWLRQ $FW6$5$The CERCLA/SARA law mandates the protection of human health and the environment.Performance of an ERA is the manner in which both EPA and DoD assess potential risks to theenvironment and determine the need for remedial action. There are several sections underCERCLA/SARA that specifically state a requirement that the environment shall be protected;Sections 104, 105(a)(2), 121(b)(1), 121(c), and 121(d).The implementing regulation that states when and where to conduct an ERA is found inthe National Oil and Hazardous Substances Pollution Contingency Plan (NCP) under 40 CFR3
300. To comply with the NCP and CERCLA/SARA, the DoD shall perform a RemedialInvestigation (RI) and Feasibility Study (FS) for each CERCLA/SARA site that does not exit theprocess after the Site Inspection (SI) phase. The NCP requires that:l The lead agency (i.e., DoD) shall perform a baseline risk assessment during the RI.l This risk assessment shall “characterize the current and potential threats to humanhealth and the environment”.l Any remedial action triggered by unacceptable risk must comply with enforceablestandards [Applicable or Relevant and Appropriate Requirements (ARARs)], unlessthe lead agency obtains a waiver.l The FS evaluates remedial options based on the results from the RI.Note: There are requirements under the SI to eliminate sites from further consideration if itdoes not pose a threat to public health and the environment. In some cases, sites can bescreened out because risks are negligible.5HVRXUFH&RQVHUYDWLRQDQG5HFRYHU\$FW5&5$Sections 3004(u) and (v), and 3008(h) of RCRA require a corrective action program forreleases of hazardous wastes or hazardous constituents from solid waste management units(SWMUs) to all media, both on and off the facility, regardless of the time at which the wastewas placed in the SWMU. These requirements are imposed when installations request aRCRA permit for Treatment, Storage and Disposal of hazardous waste. In a 1996 proposedregulation on corrective action (61 Fed. Reg. 19431 (May 1, 1996), EPA mentions that someform of ERA will generally be necessary (61 Fed Reg at 19446 and 19451). This proposed ruleis analogous in many ways to the National Contingency Plan of CERCLA. An ERA may helpcomply with requirements of the RCRA Facility Assessment, RCRA Facility Investigation andCorrective Measures Study.RCRA Facility Assessment (RFA)RFA is comparable to a Preliminary Assessment/Site Inspection of CERCLA/SARA. Anevaluation of the installation is conducted to identify potential Solid Waste Management Units(SWMU) or Areas of Concern (AOC) where a potential release has occurred.RCRA Facility Investigation (RFI)If the results from the RFA indicate a release or potential release of a hazardous wasteor hazardous constituent from a SWMU has occurred, then an RFI must be conducted. TheRFI is a characterization of the site to determine nature and extent of the release, as well as todetermine if the release to the environment poses an unacceptable risk. This phase iscomparable to the CERCLA RI phase.Corrective Measures Study (CMS)4
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