Identifying and Considering ARARs at Federal Facility Cleanups

The Federal Facilities Subcommittee’s Remediation & Reuse Focus Group developed this paper to address the ASTSWMO members’ concerns with the identification of and federal agency acceptance of State applicable or relevant and appropriate requirements (ARARs) in CERCLA federal facility cleanups. The Focus Group reviewed statutory requirements and policies, guidance, and decisions documents from EPA and other federal agencies to summarize when and how State ARARs are identified throughout the CERCLA process for both removal and remedial actions. The paper also includes a resource table and flow chart for identifying, considering, and selecting ARARs, short case summaries and site examples, recommendations, and a list of resources to assist States.

Removals Request Form

The ASTSWMO Removals Focus Group (Focus Group) has developed a form for putting together consistent referral packages across the States and Territories (States). This form identifies critical information needed to appropriately evaluate the commitment of limited resources by the U.S. Environmental Protection Agency (EPA) when reviewing referral requests. It also addresses the need for consistency in the removal action request process that has been identified by EPA headquarters, the regions and States.

Uniformity of Time Critical Removal Actions

The ASTSWMO Removals Focus Group has developed a form for putting together consistent referral packages across States. This form identifies critical information needed to appropriately evaluate the commitment of limited resources by the U.S. EPA when reviewing referral requests. It also addresses the need for consistency in the removal action request process that has been identified by U.S. EPA headquarters, the regions and States.

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Time-Critical Removal Capabilities

The ASTSWMO Removals Focus Group has produced research that builds off of previous work from their 2013 Transition Issues Analysis. This research focuses on the capacities and needs of the EPA Regions and States in the performance of Time Critical Removal Actions by identifying the resources each potentially offers to this type of response action, and the dynamics of the partnerships created between Federal and State agencies. The result successfully identifies ways to more efficiently use and share limited resources available at all levels and build synergistic partnerships between agencies in the satisfaction of this vital environmental service that protects human health and the environment.

Post Removals Site Controls: Ensuring the Long-Term Integrity of Removal Actions

The Removals Focus Group developed this report as an update to their 2010 report “Transition Issues Analysis”. One area that needed additional review was Post Removals Site Controls (PRSCs). Timely input from the State is needed throughout the removal decision making process. The document includes Institutional, Proprietary and Government Controls, as well as zoning, groundwater use restrictions, fish consumption advisories, and more.

Transition Issues Analysis

The purpose of the research was to gather information on issues relating to the transition of removal sites to and from the State and federal programs. The purpose was also to identify approaches, concerns, strengths and weaknesses related to these transitions. Transition Issues Analysis Paper Emergency Response Matrix Non-TCRA Matrix TCRA Matrix Removal Action Process Timeline Schematic