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A presumptive remedy is a technology that EPA believes, based
upon its past experience, generally will be the most appropriate
remedy for a specified type of site. EPA is establishing
presumptive remedies to accelerate site-specific analysis of
remedies by focusing the feasibility study efforts. EPA expects
that a presumptive remedy, when available, will be used for all
CERCLA sites except under unusual circumstances.
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:
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.
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