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Review Criteria
Non-Federal Facilities Criteria
The Board uses the following criteria to determine whether it will review a site. The National Remedy Review Board (NRRB) will review all proposed interim and final Superfund response decisions at both NPL and non-NPL (including "Superfund Alternative") sites for which:
- The proposed remedial action costs more than $25 million*; or
- The proposed Non-Time-Critical Removal Actions (NTCRAs) other than federal facilities is estimated to cost more than $25 million; or
- There are the following post Proposed Plan Changes:
- The Region selects a different alternative (after the release of the Proposed Plan for public comment) that costs more than 20% from the original proposal and these costs trigger review criteria. The Board will review the new proposal even if the earlier proposed action had undergone Board review.
- The Region develops a new alternative that was not evaluated in the Proposed Plan and the costs of the new alternative would trigger a review, then the Region will present the new alternative to the Board.
- The Board may review (at regional discretion) sites where the proposed action's original cost estimate increases more than 20% after issuance of the Proposed Plan due to updated cost information or minor changes to the alternative and those changes trigger review criteria.
* High Cost Sites that do not Trigger Review Criteria - For sites that are close to, but do not trigger, the $25 million cost criteria: the appropriate Regional Board member will discuss briefly with the Board the key remedy selection and cost issues at the site and present the Region's position on whether the site would benefit from Board review.
Federal Facilities Sites (other than Department of Energy)
- Federal Facility sites (including Formerly Utilized Sites Remedial Action Program- FUSRAP) follow the same review criteria above with the exception of NTCRAs. Federal Facility NTCRAs do not undergo Board review unless requested by the Federal Facility.
Department of Energy Sites (DOE)
- The NRRB will review sites where the primary contaminant is radioactive waste and the proposed remedial action costs more than $75 million; or
- The NRRB will review NTCRAs at NPL sites that exceed $30 million or $75 million for primarily radioactive waste (per joint DOE/EPA Memorandum dated October 5, 1998 [PDF 76K, 3 pages])