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

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8. Description of Alternatives<br />

The overall purpose of the FFS Report (USEPA, 2010) was to identify and evaluate two<br />

kinds of alternatives that address unacceptable exposures to human health and the<br />

environment in the Upper Coeur d’Alene Basin:<br />

• Remedial alternatives that address the widespread contamination impacting surface<br />

water in the Upper Basin; and<br />

• <strong>Remedy</strong> protection alternatives that enhance the protectiveness of the existing human<br />

health remedies <strong>for</strong> OUs 1, 2, and 3.<br />

As described previously, ecological remedies selected in previous decision documents, like<br />

the interim remedy described in the ROD <strong>for</strong> OU 3 (USEPA, 2002), could not be<br />

implemented <strong>for</strong> several reasons, including availability of funding, cost, and uncertainties<br />

involved with predicting their effectiveness, particularly on a Basin-wide basis. Since the<br />

2001 NRRB Presentation <strong>In<strong>for</strong>mation</strong> (USEPA, 2001b; Supplemental CD, File B2-1) was<br />

submitted and reviewed, USEPA has conducted studies and collected data with which to<br />

identify a comprehensive solution to the ecological conditions in the Upper Basin. At the<br />

same time, USEPA has implemented significant portions of the human health remedies and<br />

has observed and evaluated impacts to protective barriers that may affect the protectiveness<br />

of the remedies. In the development and evaluation of the alternatives in the FFS Report,<br />

remedial actions that can be applied incrementally by using an adaptive management<br />

approach were favored, as was maximizing the effectiveness of limited resources.<br />

8.1 Remedial Alternatives<br />

A general framework of alternatives to meet CERCLA goals and objectives was developed<br />

and evaluated in the FFS Report. Remedial alternatives were first developed separately <strong>for</strong><br />

the Upper Basin portion of OU 3 and <strong>for</strong> OU 2. These separate alternatives were then<br />

combined to produce 10 combined remedial alternatives that address all of the Upper Basin.<br />

These combined remedial alternatives, along with a No Action Alternative included <strong>for</strong><br />

baseline comparison purposes, were evaluated in the FFS Report, using the CERCLA<br />

threshold and primary balancing criteria to identify a comprehensive surface water remedy<br />

<strong>for</strong> the Upper Basin. A detailed description of the FFS approach is provided in Part B,<br />

Section 3.3 of this <strong>Site</strong> <strong>In<strong>for</strong>mation</strong> <strong>Package</strong>.<br />

The remedial alternatives <strong>for</strong> the Upper Basin portion of OU 3 and <strong>for</strong> OU 2 are described in<br />

Sections 8.1.1 and 8.1.2, respectively.<br />

8.1.1 Remedial Alternatives <strong>for</strong> the Upper Basin Portion of OU 3<br />

In the 2001 FS Report (USEPA, 2001d), six remedial alternatives, including Alternative 1 (No<br />

Action), were selected <strong>for</strong> evaluation to address ecological risks posed to fish, waterfowl,<br />

other birds, and plants in the Upper and Lower Basins. Of these, Ecological Alternatives 1, 2,<br />

5, and 6 were not retained <strong>for</strong> further evaluation because they were determined to be<br />

B8-1

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