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IMPLEMENTATION <br /> Superfund <br /> This interim directive applies to all future CERCLA Remedial <br /> Investigation/Feasibility Study (RI/FS) work; this interim <br /> directive should generally not be applied at sites for which risk <br /> assessments have been completed. For removal sites, this interim <br /> directive recommends that decisions regarding removal actions be <br /> considered first by the Regional Decision Team (RDT) . The RDT <br /> will then refer sites to the removal program for early action, as <br /> appropriate. <br /> The approach in this interim directive helps meet the goals <br /> set by the Superfund Accelerated Cleanup Model (SACM) for <br /> streamlining remedial decision-making. (This streamlined approach <br /> is described in Appendix A, Suggested Decision Logic for CERCLA <br /> and RCRA Corrective Action. ) This interim directive also <br /> recognizes that other methods (e.g. , slope studies and others) <br /> for evaluating risks at lead sites may also be appropriate and <br /> may be used in lieu of, or in conjunction with, the IEUBK model. <br /> If an alternate approach to lead risk assessment is to be <br /> applied, an EPA scientific review should be obtained. For <br /> example, expert statisticians would need to review slope factor <br /> calculations for statistical biases before their use could be <br /> supported. Recognizing that all assessment methods involve some <br /> uncertainties, the Agency, at this time, believes the IEUBK model <br /> is the most appropriate and widely applicable tool for Superfund <br /> and RCRA sites. Alternatively, EPA may require setting c..:anup <br /> levels below the screening level if site-specific circumstances <br /> warrant (e.g, ecological risk) . For further information on the <br /> use of the IEUBK model at CERCLA sites, contact the Regional <br /> Toxics Integration Coordinators identified in Appendix B. <br /> RCRA Corrective Action <br /> It is expected that the RCRA corrective action program will <br /> generally follow an approach similar to CERCLA's (as described <br /> above) in using the IEUBK model. In the case of RCRA facilities <br /> at which lead contaminated soils are of concern, collection and <br /> evaluation of data for the purpose of using the model will be <br /> primarily the responsibility of the owner/operator. <br /> Issues for Both Programs <br /> Cleanup of soils vs. other lead sources: OSWER's approach to <br /> assessing and managing risks from lead is intended to address the <br /> multi-media/multi-source nature of environmental lead exposures <br /> because it is expected that people at or near CERCLA and RCRA <br /> Corrective Action sites will experience lead exposures from <br /> sources in addition to contaminated soil. In some instances, <br /> these other exposures may be large (e.g. , where there are <br /> -11- <br /> s; <br /> Q <br />