Application of New CERCLA Five-Year Review Guidance at Hanford - 16403
Under CERCLA, the implementation of remedial actions established in records of decision (ROD) are required to be reviewed every five years to evaluate their effectiveness in protecting human health and the environment. Past reviews have included evaluation of actions that were not implemented under existing RODs and, therefore, not subject to the requirement. While commendable for its transparency, discussing these out-of-scope actions created confusion and elicited comments that required time and effort to resolve. The fourth CERCLA Five Year Review (FYR) at the Hanford Site embraces the EPA guidance designed to streamline the process and focuses on the specific objectives of the review. This guidance and the training materials developed jointly by multiple federal agencies including EPA, DOE, DOD, and Department of the Interior (DOI), demonstrate a focused approach to the FYR process and offer real-world examples for streamlining this important document. This paper discusses the focused approach and process changes implemented at the Hanford Site that reduced the size and complexity of the document and provided the DOE, Richland Operations Office, with an efficient, effective template for preparing subsequent reviews. One key change was a thorough evaluation of what operable units were discussed and what operable units were not discussed in the five-year review. This process resulted in a reduction of 14 operable unit discussions. Additionally, extensive referencing of previously published CERCLA documents including closure reports and periodic groundwater monitoring reports minimized the amount of analytical data tables necessary to support the discussion. The Hanford five year review made good use of technology and provided internet links to existing documents where detailed information and voluminous analytical data reside. This eliminated the use of extensive data tables and summaries. The resulting five protectiveness determinations include: 1) 'Protective' which is used when there is sufficient data to conclude that the remedy is functioning as intended; 2) 'Protective in the short term' which is used when the data and/or documentation review raises issues that could affect future protectiveness; 3) 'Will be protective' which is used when the remedy under construction is anticipated to be protective on completion; 4) 'Protectiveness deferred' which is typically used when additional information is needed; and 5) 'Not protective' which is used when risks are not under control. Reviewing only on the appropriate operable units, and supporting the analysis of remedy performance with focused data, the resulting protectiveness determinations and overall effectiveness of the document were significantly improved. (authors)