Accordingly, EPA has determined that, when using presumptive remedies, the site characterization data collection effort can be limited, and the detailed analysis can be limited to the presumptive remedies (in addition to the no-action alternative), thereby streamlining that portion of the FS. Supporting documentation should be included in the Administrative Record for all sites that use the presumptive remedy process to document the basis for eliminating the site-specific identification. This supporting documentation is provided in the presumptive remedy document itself.
Circumstances where a presumptive remedy may not be used include unusual site soil characteristics, mixtures of contaminants not treated by the remedy, demonstration of significant advantages of alternate (or innovative) technologies over the presumptive remedies, or extraordinary community and state concerns. The use of nonpresumptive-remedy technologies, or the absence of a presumptive remedy entirely, does not render the selected treatment technology less effective. The presumptive remedy is simply an expedited approval process, not the only technically feasible alternative. If such circumstances are encountered, additional analyses may be necessary or a more conventional detailed RI/FS may be performed.
There are currently seven published presumptive remedy documents:
Presumptive Response Strategy and Ex-Situ Treatment Technologies for Contaminated Ground Water at CERCLA Sites. Final Guidance (EPA, 1996). EPA Document No. 540-R-96-023.
User Guide to the VOCs in Soils. Presumptive Remedy (EPA, 1996). EPA Document No. 540-F-96-008.
Presumptive Remedy - CERCLA Landfill Caps RI/FS Data Collection Guide (EPA, 1995). EPA Document No. 540-F-95-009.
Presumptive Remedy for Soils, Sediments, and Sludges at Wood Treater Sites (EPA, 1995). EPA Document No. 540-R-95-128.
Presumptive Remedies: Policies and Procedures (EPA, 1993). EPA Document No. 540-F-93-047.
Presumptive Remedies: Site Characterization and Technology Selection for CERCLA Sites with Volatile Organic Compounds in Soils (EPA, 1993). EPA Document No. 540-F-93-048.
Presumptive Remedy for CERCLA Municipal Landfill Sites (EPA, 1993). EPA Document No. 540-F-93-035.
Additional presumptive remedies are currently being determined for wood treating, contaminated ground water, PCB, coal gas sites, and grain storage sites.
In addition, there is a desire among various governmental agencies to expand this process, or develop a parallel process for their remediation projects. For example, the U.S. Air Force Center for Environmental Excellence/Technology Transfer Division (AFCEE/ERT) advocates the use of the following remedies:
Bioventing for fuel-contaminated soils.
A combination of vacuum-enhanced free product recovery and bioremediation for light non-aqueous phase liquid (LNAPL) floating product.
Natural attenuation for petroleum hydrocarbon-contaminated ground water.