Hudson River PCBs Superfund Site
The Feasibility Study / Proposed Plan
The Feasibility Study is the portion of the Reassessment in which EPA evaluated alternatives to address the PCBs in the sediment of the Upper Hudson River. The Feasibility Study provided EPA with the information necessary to identify its preferred alternative, which was presented to the public in the Proposed Plan.
There are two major studies that comprise a Superfund site investigation, the Remedial Investigation and the Feasibility Study. During the Remedial Investigation, the Agency delineates the nature and extent of contamination at the site and evaluates the risks posed by the contaminants. Simply put, the Remedial Investigation tells us what contaminants are present, how much is there, where it is going and what effects the contaminants have on human health and the environment. For the Hudson River PCBs Reassessment, the Remedial Investigation consists of the Phase 1 and Phase 2 Reports.
In the Feasibility Study, information generated during the Remedial Investigation is used to evaluate alternatives for cleanup, including the No Action alternative required by Superfund law. The Feasibility Study for the Hudson River PCBs Site was Phase 3 of the Reassessment. To outline and explain the work to be done, EPA issued the Feasibility Study Scope of Work in September 1998 and a Responsiveness Summary for the Feasibility Study Scope of Work in June 1999. It is important to note that some Feasibility Study work was conducted concurrently with the Remedial Investigation in order to incorporate the most recent scientific findings into the third phase of work.
In the Feasibility Study, released in December 2000, EPA identified remedial action objectives, which are the goals for protecting human health and the environment at the site. The remedial action objectives specify contaminants and media of concern, potential exposure pathways, and preliminary remediation goals. The preliminary remediation goals can be either applicable or relevant and appropriate requirements (ARARs) of other Federal and State environmental laws or risk-based concentrations.
Once the remediation goals were established, general response actions and potentially suitable technologies, including innovative technologies, were identified. General response actions are those actions that will satisfy the remedial action objectives. The general response actions identified in the Feasibility Study Scope of Work included:
Potentially suitable treatment technologies and process options are then screened for effectiveness, implementability, and relative cost.
After screening the treatment technologies and process options, EPA then developed and screened (again, using effectiveness, implementability and cost) various scenarios or alternatives to evaluate which would best achieve the remedial action objectives for the site. The alternatives were then evaluated and compared to one another using seven of the Agency's nine criteria for selecting a remedy at Superfund sites. Two criteria, state acceptance and community acceptance, were evaluated after the Agency received public comment on its preferred alternative and before the Agency selected its final remedy.
The Proposed Plan is the document issued to the public that identifies the EPA's preferred alternative (in other words, its proposed cleanup method). The document outlines pertinent information from the Remedial Investigation and Feasibility Study and provides a summary of the alternatives that the Agency evaluated. The Proposed Plan was released concurrently with the Feasibility Study for the Hudson River PCBs site in December 2000. EPA helda number of public meetings during which time the Proposed Plan was formally presented. EPA also held a public comment period during which oral and written comments from the public on the Proposed Plan were considered. After the public comments were reviewed, EPA signed a Record of Decision (ROD) in 2002 that documented its final decision for the Reassessment. Along with the Record of Decision, EPA also issued a responsiveness summary that provided the Agency's response to all significant comments submitted during the public comment period.