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2009_0720_Packet
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2009_0720_Packet
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The NCP has certain requirements for action. Those requirements c�epend �pon whether a response <br />action is a"removai" action ar a"remedial" action. <br />�`or a rerr�oval action, the steps included are Iimited and expeditious. They include a <br />Removal S�te Evaluation {400 CFR 300.410) and a Remaval Action (400 CFR 340.415}. A removal <br />site evaluation consists of a removal preliminary assessment and, if warranted, a removal site <br />inspection. 400 CPR 300.410{a). A removal site evaluation shall be undertaken "as promptly as <br />possible." 400 CFR 3Q0.410(b). The removal pretiminary assessment shall be based on readi�y <br />available information. Ifremoval action is not required,' but remedial action under 300:430 may be <br />necessary, a remedial site evalua�ion sha�1 be initiated. 400 CFR 300.�10{i}. <br />Removal actions are to "begin as soon as possible to abate; prevent, minimize, siabilize, <br />mitigate, or eliminate the threat to public health �r welfar� of the United States or the environment." <br />40Q CFA 300.415(b){3).2 Under 400 C�R 300.415(b}(5), removal actions shall be terminated after <br />$2 n�illion has been obligated for the action or 12 months have elapsed from the date that rem.oval <br />activities begin on-site, unless there is a deterinination that (i} there is an immediate risk to public <br />health or �he envirorunent; and continued response actions are irnmediately requireci to preventi, li�nit, <br />or mitigate an emergency; and such assistance will not other�ise be provided; or (ii) continued <br />response acti�n is otherwise appropriate and c�nsistent �ith the remedial action to be taken. Under <br />40 CFR 300.415(g), if a remaval action wiil not fully address the threat and the release may require <br />remedial action; there sha11 be an orderly transition fram rerrrovaI to remedial response activities. <br />In contrast to the relativeIy expeditiaus and preliminary nature of a removal assessment, an <br />investigation for a remedial action includes inany inore formal and fully developed investigation, <br />�lanning and implemenfation steps. These include a Rernedial Preliminary Assessment (PA) (40 <br />CFR 300.420(b)), a Remedial Site Inspection (SI) (40 CFR 300.420(c)) and a Remedial <br />Investigatior�l�'easibility Study (RIIFS) {40 C�'R 300.�30). "Remedia� actions are to be <br />` The NCP provides a Iisting oF factors to be considered i� determining the <br />appropriateness o�a rEmo��val action. �00 CFR 300.415(b}(1). These include: <br />Exposure to nearby human populations, animals or t�e food chain <br />Contamina�i�n of drinking water supplies or sensitive ecosystiems <br />�az�rdous subsfances in drums, barrels, tanks, or other bulk storage containers, that may <br />pose a ihreat of release <br />High levels of hazardous subs�ances Iargely near the surface <br />Weather conditions that rnay cause rr�igration or releases <br />Threat of fire or explosion <br />AvaiIabiIity o�o�her niechanisms io respond <br />Other situations or factors thati rr�ay pose threats <br />2 A list of removal actions is provided at (e){1)-(8), such as �'ences, drainage controls, <br />stabilization oi berms, capping to reduce migration, using chemicals to retard or mitigate spread, <br />excavation or removal of highly contaminated soils �rom drainage areas to reduce spread or direct <br />contact, <br />� <br />
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