Final Site Information Package for National Remedy Review Board ...

SITE INFORMATION PACKAGE FOR NATIONAL REMEDY REVIEW BOARD
PART B, SECTION 3: SCOPE AND ROLE OF THE FFS AND ROD AMENDMENT
Based upon the comparative analysis presented in the ROD for OU 3, USEPA determined
that Ecological Alternative 3 (More Extensive Removal, Disposal, and Treatment)
represented the best balance of trade-offs for a long-term cleanup approach, and would best
meet the requirements for protection of the environment and compliance with the ARARs.
The ROD for OU 3 included an interim ecological remedy that was a prioritized subset of
the numerous actions included in Ecological Alternative 3. This interim remedy included
cleanup actions that would be both technically and administratively implementable and
would achieve significant reduction in residual risks relative to its cost.
As discussed previously, given the NAS recommendations (NAS, 2005) and new
information about Upper Basin conditions, USEPA is refining its long-term cleanup plan for
the Upper Basin. The FFS Report provides the basis for the refined cleanup plan.
Section 300.430(e)(9) of the NCP (40 Code of Federal Regulations [CFR] 300) specifies that
“detailed analysis should be conducted on the limited number of alternatives that represent
viable approaches to remedial action after evaluation in the screening stage.” Based upon
the NCP and the findings presented in the 2001 FS Report and the 2002 ROD for OU 3,
USEPA determined that it was appropriate to carry forward only the Upper Basin
components of Ecological Alternatives 3 and 4 as the basis for remedial alternatives to be
considered in the FFS Report. USEPA has also determined that Ecological Alternatives 1, 2,
5, and 6 in the 2001 FS Report would not be sufficiently protective of human health and the
environment; therefore, they do not warrant further analysis. Carrying forward both
Ecological Alternative 3 and the more extensive cleanup contemplated under Ecological
Alternative 4 into the FFS Report was consistent with previous considerations of the
CERCLA evaluation criteria and the level of cleanup that will be necessary to meet the
ARARs for the Upper Basin. Therefore, the FFS Report updated and expanded Ecological
Alternatives 3 and 4 in a consistent manner based on new information obtained for the
Bunker Hill Box and other Upper Basin areas since issuance of the 2002 ROD for OU 3.
It is important to note that the Lower Basin of the Coeur d’Alene River is not within the
scope of the FFS Report or the forthcoming ROD Amendment. Since the ROD for OU 3 was
issued, the primary focus of remedial actions in the Lower Basin has been human-healthfocused
cleanup actions (in residences, recreational areas, and other common-use areas) and
the Lower Basin agriculture-to-wetland conversion project. This approach has allowed time
to further refine the understanding of the Lower Basin and evaluate the complex remedial
actions that are necessary to address contaminated sediment transport. USEPA is continuing
to support data collection and analysis efforts in the Lower Basin to provide decisionmakers
with an improved understanding of the Lower Basin and to support the evaluation of
specific remedial alternatives.
3.4 ROD Amendment
A ROD Amendment will be prepared to document the selection of the amended remedy
after consideration of public comments on the Proposed Plan. The ROD Amendment will
also update and add to previous cleanup plans described in the RODs for OUs 1, 2, and 3
and related decision documents. In addition, the ROD Amendment will address
recommendations made by the NRRB in 2001 and the NAS in 2005. In particular, the ROD
Amendment will provide a final remedy for:
B3-5