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Headquarters Remedy Consultation

The EPA Office of Superfund Remediation Technology Innovation (OSRTI) is the Headquarters Office for the Superfund Program.  The office provides support to Regional offices in policy interpretation and requirements and provides site-specific support to ensure that decision documents comply with the Statutory and regulatory requirements and consider Agency policy to the extent appropriate.  Various initiatives and policy memorandum have been issued that direct the Region to consult with OSRTI, generally prior to the proposed action phase.  Below is a compilation of current initiatives and Agency policy memorandum that request OSRTI consultation.

TOPIC QUICKFINDER


GENERAL DIRECTIVES
National Remedy Review Board (NRRB)
Contaminated Sediments Technical Advisory Group (CSTAG)
Overarching Guidance
Removal Action

SITE TYPE OR ACTION SPECIFIC DIRECTIVES
Dioxin
Groundwater
Lead
Mercury 
Methyl Tertiary-Butyl Ether (MTBE) 
Radioactive Materials 
Sediment
Structures / Buildings
TI Waiver (Groundwater)

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General Directives

National Remedy Review Board (NRRB)

EPA's National Remedy Review Board (NRRB)
Created in 1996, the NRRB reviews proposed Superfund cleanup decisions to assure they are consistent with Superfund regulations and guidance, and to verify that remedy selection is cost effective. Lists criteria required for site review and links to documents summarizing the results of NRRB-reviewed proposed actions.

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Contaminated Sediments Technical Advisory Group (CSTAG)

"Changes to the Roles and Responsibilities of the Contaminated Sediments Technical Advisory Group (CSTAG)." This memorandum supplements OSWER Directive 9285.6-08: "Principles for Managing Contaminated Sediment Risks at Hazardous Waste Sites", issued February 12, 2002, by defining the level of CSTAG involvement in the National Remedy Review Board review of proposed plans at large contaminated sediment sites. Sep 9, 2009 [4 pp]
OSWER 9285.6-20
PDF Searchable (655 K)

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Overarching Guidance

"Consolidated Guide to Consultation Procedures for Superfund Response Decisions" (May 1997)
Developed to clarify and consolidate the various EPA Headquarters consultation procedures established for response selection decision making. It specifies continuation of the consultation procedures established in 1996 for the four focus areas (see OSWER 9200.1-17 below).
EPA 540/F-97/009,OSWER 9200.1-18FS, NTIS:PB97-963216
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"Focus Areas for Headquarters Support for Regional Decision-Making" (May 1996)
Identifies selected issue areas that represent the current focus of OSRTI's national Regional coordination effort. These areas include risk management and cost-effectiveness, decision documentation, ground water policy, lead policy, and presumptive remedies implementation. [24 pp]
OSWER 9200.1-17
PDF Image (1 MB)

"National Consistency in Superfund Remedy Selection" (September 1996)
This directive to Regional Division Directors requests that program managers fully use existing tools and consultation opportunities to promote national consistency in remedy selection. [6 pp]
OSWER 9200.0-21
PDF Searchable (48 K)

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Removal Actions at Non-NPL Sites and Use of Non-Time Critical Removals

"Guidance on Non-NPL Removal Actions Involving Nationally Significant or Precedent-Setting Issues" (March 1989)
Outlines the defining criteria to determine if a non-NPL removal action requires Headquarters concurrence. Also details procedural requirements that should accommodate removals belonging to five categories not requiring concurrence. For mercury policies, see updated directive: "Concurrence Policy For Mercury Removals" (5/98) [9 pp]
OSWER 9360.0-19
PDF Searchable (69 K)

"Use of Non-Time-Critical Removal Authority in Superfund Response Actions" (February 2000)
Will guide project managers during the decision process of selecting between remedial and removal actions. Also specifies the circumstances under which site managers must consult with Headquarters before performing a non-time-critical removal. [7 pp]
OSWER 9360.0-40P
PDF Searchable (69 K)

"Concurrence Policy for Mercury Removals" (May 1998)
Modifies Headquarters consultation requirements concerning removal actions addressing certain residential mercury contaminations. Mercury contamination will no longer be considered "nationally significant" unless the contamination is contained within the building structure, in which case consultation requirements should be followed in accordance with ""Response Actions at Sites with Contamination Inside Buildings" (August 1993). [3 pp]
OSWER 9360.1-05
PDF Searchable (21 K)

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Specific Site-Type or Contaminant Directives

Dioxin

"Headquarters Consultation for Dioxin Sites" (December 1996)
Requests that Regional Offices consult with EPA Headquarters on sites where remediation goals are to be developed for dioxin in soils. [2 pp]
EPA 540/F-97/014, OSWER9200.4-19, NTIS:PB97-963225INX
PDF Searchable (32 K)

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Groundwater and Technical Impracticability (TI)

"Summary of Key Existing EPA CERCLA Policies for Groundwater Restoration" (June 2009)
This Directive provides a compilation of some key existing EPA groundwater policies to assist EPA Regions in making groundwater restoration decisions pursuant to CERCLA and the NCP.  It addresses: Whether CERCLA remedial action is warranted, Appropriate role of institutional controls (ICs), Groundwater classification and Beneficial use policy, Remedial action cleanup levels and Groundwater point of compliance. [11 pp]
OSWER Directive 9283.1-33.
PDF Searchable (2.5 M)

"Superfund Ground Water RODs: Implementing Change This Fiscal Year" (July 1995)
Addresses policies concerning Records of Decision (RODs) for sites with ground-water contamination. Emphasizes that Technical Impracticability (TI) waivers will generally be appropriate for sites with contaminated ground water where restoration to drinking water standards is technically impracticable (eg. DNAPL sites), or the Region must inlcude a written justification for departure from this policy. [2 pp]
EPA-540-F-99-005, OSWER 9335.5-03P, NTIS:PB99-963220
PDF Searchable (34 K)

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Lead

"Lead Site Response Decisions: Formation of the Lead Sites Consultation Group" (May 1997)
Reiterates the 3 site criteria that could trigger review of lead-related Proposed Plans and summarizes the consultation requirements for such sites. [5 pp]
OSWER 9355.4-26
PDF Searchable (57 K)

"Administrative Reforms for Lead Risk Assessment" (April 1996)
Includes a request for information on residential lead risk assessments and a draft plan for achieving these goals. [38 pp]
OSWER 9200.4-20, EPA 540-F-97-015, NTIS: PB97-963226
PDF Image (1 MB)

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Mercury

"Concurrence Policy for Mercury Removals" (May 1998)
Modifies Headquarters consultation requirements concerning removal actions addressing certain residential mercury contaminations. Mercury contamination will no longer be considered "nationally significant" unless the contamination is contained within the building structure, in which case consultation requirements should be followed in accordance with ""Response Actions at Sites with Contamination Inside Buildings" (August 1993). [3 pp]
OSWER 9360.1-05
PDF Searchable (21 K)

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Methyl Tertiary Butyl Ether (MTBE)

"Headquarters Consultation for Addressing Methyl Tertiary Butyl Ether (MTBE) Contamination Under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)" (May 1997)
Requests Headquarters consultation when considering the use of CERCLA authority to address MTBE contamination.
OSWER 9200.4-21 [2 p]
PDF Searchable (19 K)

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Radioactive Materials

"Headquarters Consultation for Radioactively Contaminated Sites" (July 2000)
Requests that Regional Offices consult with EPA Headquarters on CERCLA response decisions involving on-site management of radioactive materials or when there is a potential national precedent setting issue related to a radioactive substance. [4 pp]
OSWER 9200.1-33P, NTIS: PB2000 963304
PDF Image (419 K)

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Sediment

"Changes to the Roles and Responsibilities of the Contaminated Sediments Technical Advisory Group (CSTAG)."
This memorandum supplements OSWER Directive 9285.6-08: "Principles for Managing Contaminated Sediment Risks at Hazardous Waste Sites", issued February 12, 2002, by defining the level of CSTAG involvement in the National Remedy Review Board review of proposed plans at large contaminated sediment sites. Sep 9, 2009 [4 pp]
OSWER 9285.6-20
PDF Searchable (655 K)

"Principles for Managing Contaminated Sediment Risks at Hazardous Waste Sites"1
Presents eleven risk management principles to use as guidelines for site assessment and response when addressing contaminated sediment sites. This directive is consistent with the strategies of the NRC 2001 report "A Risk management Strategy for PCB-Contaminated Sediments." New Headquarters consultation requests are included. [8 pp]
OSWER 9285.6-08
PDF Searchable (43.2 K)

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Structures/Buildings

"Response Actions that Affect Residential or Commercial Structures" (May 1998)
Specifies for Regions to consult with OSWER, through their OSRTI Regional Accelerated Response Center, before making any final decisions regarding a response which will impact a residential or commercial building. [2 pp]
OSWER 9360.3-20, EPA 540/F-98/029, NTIS:PB98-963243
PDF Searchable (30 K)

"Response Actions at Sites with Contamination Inside Buildings" (August 1993)
Addresses the use of the CERCLA authority to conduct response actions within buildings that are contaminated. Includes a flow-chart that designates the sequence of steps to take when addressing indoor contamination scenarios. Headquarters consultation requirements are defined. See updated policies concerning mercury contamination in "Concurrence Policy For Mercury Removals" (5/98). [6 pp]
OSWER 9360.3-12
PDF Searchable (102 K)

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Superseded Documents

1 This document supersedes: "Fiscal Year 2001 Appropriations Conference Report Language on Contaminated Sediments" - Memorandum (March, 2001) OSWER 9200.0-36

 

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