Fact Sheet #2000-09
December 2000

Choosing a Cleanup Plan for IRP Groundwater Treatment Systems

A fact sheet describing how a cleanup plan is selected.

Introduction

Contaminated groundwater plumes have migrated beyond the boundary of the Massachusetts Military Reservation (MMR), and therefore must be cleaned up and/or monitored by the Air Force. Choosing a plan to clean up groundwater in areas owned by private individuals or by the public property involves balancing a complex mix of scientific, engineering, financial and community concerns.

This fact sheet describes how multiple concerns are balanced while deciding upon a cleanup plan. A cleanup plan describes generally how a specific groundwater plume will be treated, but does not include detailed treatment system or monitoring well location information. Refer to the fact sheet, Design and Construction of IRP Groundwater Treatment Systems, for a description of how multiple concerns are considered during the design and construction of treatment systems or monitoring wells on non-MMR property.

Q: Who makes decisions on the cleanup plan for a groundwater plume?

A: Decisions are made by the Air Force Center for Environmental Excellence (AFCEE) with input from citizens, local officials, the Massachusetts Department of Environmental Protection (DEP), and the U.S. Environmental Protection Agency (EPA). At the Installation Restoration Program (IRP), AFCEE first evaluates several general plans that would meet cleanup goals for a specific groundwater plume. This evaluation includes input from the EPA and DEP. The public is then presented with AFCEE’s preferred cleanup plan and a comparison of the alternate plans evaluated. Cleanup plans are conceptual and specific locations of treatment systems or monitoring wells have not yet been determined.

Q: How is the public involved in making a decision on a cleanup plan?

A: A minimum 30-day public comment period is provided so the public can comment on the different cleanup plans evaluated by AFCEE. Public meetings are held and presentations are made to citizen advisory teams before and during the comment period. All comments are recorded, considered, and affect final decisions that are made. All comments received are responded to in a written summary.

News releases and paid advertisements that describe AFCEE’s preferred cleanup plan, comment period dates, and dates of public meetings are placed in local newspapers. In addition to public notice through the news media and paid advertisements, residents living over the plume or near the proposed treatment system location are notified individually by mail of public meeting dates, and locations of documents for public review and comment. They also will receive updates in the future on the cleanup work.

Q: How Does AFCEE Choose a Cleanup Plan?

A: AFCEE uses nine criteria developed by EPA to compare a variety of cleanup plans and then selects a final cleanup plan. These nine criteria make up the evaluation process established under Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) Section 121 and regulations promulgated in the National Contingency Plan. They are standard criteria used for all Superfund sites.

Of these nine criteria, protection of human health and the environment and compliance with applicable or relevant and appropriate requirements (ARARs) are considered to be the most important (threshold) criteria that must be met for a cleanup plan to be selected. The next five criteria, called balancing criteria, are used to evaluate and compare the elements of the various cleanup plans. This comparison enables decision-makers to evaluate which cleanup plan provides the best balance of trade-offs with respect to the balancing criteria. Consideration of state and community comments may prompt AFCEE to modify aspects of a cleanup plan or decide that another cleanup plan provides a more appropriate balance. State and community acceptance is factored into a final balancing of all criteria used to select a cleanup plan. The following list highlights these nine criteria and some questions AFCEE must consider in selecting a final cleanup plan.

Threshold Criteria

  1. Overall protection of human health and the environment: Will the cleanup plan protect human health and plant and animal life on and near the area? The chosen cleanup plan must meet this criterion.
  2. Compliance with Applicable or Relevant and Appropriate Requirements (ARARs): Does the cleanup plan meet all pertinent federal and state environmental statutes, regulations, and requirements? The chosen cleanup plan must meet this criterion.

Balancing Criteria

  1. Long-term effectiveness and permanence: How reliable will the cleanup plan be at long-term protection of human health and the environment? Is contamination likely to present a potential risk again?
  2. Reduction of toxicity, mobility or volume through treatment: Does the cleanup plan incorporate treatment to reduce the harmful effects of the contaminants, their ability to spread, and the amount of contaminated soil and/or groundwater present?
  3. Short-term effectiveness: How soon will risks be adequately reduced? Are there short-term hazards to workers, the community, or the environment that could occur during the cleanup process?
  4. Implementability: Is the cleanup plan technically and administratively feasible? Are the goods and services needed to implement the cleanup plan (e.g., treatment machinery, space at an approved disposal facility) readily available?
  5. Cost: What is the total cost of constructing and operating the cleanup plan? Costs presented in most documents represent the present worth costs of construction, operations, and monitoring for the anticipated lifetime of the specific cleanup plan being evaluated.

Modifying Criteria

  1. State acceptance: Do state environmental agencies agree with the recommendations? What are their preferences and concerns?
  2. Community acceptance: What suggestions or modifications do residents of the community offer during the public comment period? What are their preferences and concerns?

Q: Where Can I Get More Information?

A: Maps and fact sheets that describe groundwater plumes originating from the MMR and cleanup plans are available. Other fact sheets produced by AFCEE, EPA and MassDEP include Real Estate Issues Explained, Access to Property, Homeowners Exempt From Superfund Cleanup Costs, and the Massachusetts Good Neighbor Policy. These and other informational items are available from the main libraries in Bourne, Falmouth, Mashpee and Sandwich, the US Coast Guard library at MMR, and the IRP office at MMR. Information also can be obtained by visiting the MMR web site at www.mmr.org.

Who Can I Contact?

Jim Murphy, Community Involvement Coordinator
USEPA New England, Suite 1100
1 Congress Street, (RAA)
Boston, MA 02203
Toll free phone: 1-888-372-7341 ext. 81028
Phone: (617) 918-1028 Fax: (617) 918-1029
e-mail: murphy.jim@epa.gov

Ellie Grillo, Community Involvement Coordinator
MassDEP
20 Riverside Drive
Lakeville, MA 02346Phone: (508) 946-2866 Fax: (508) 947-6557
e-mail: ellie.grillo@state.ma.us

Doug Karson, Community Involvement Specialist
HQ AFCEE/MMR
322 East Inner Road
Otis ANG Base, MA 02542-5028
Phone: (508) 968-4678 ext. 2 Fax: (508) 968-4673
e-mail: doug.karson@mmr.brooks.af.mil

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