Risk and Factors

Risk and Factors

Consent Order Section XVI. Corrective Measures Evaluation describes the agreement for evaluating alternatives that meet a threshold criteria, which are evaluation standards derived from EPA’s RCRA Corrective Action Plan, OSWER Directive 9902.3-2A (May, 1994) and a balancing criteria, which are other factors derived from that guidance, to evaluate alternatives meeting the threshold criteria.

The threshold criteria are:

  1. Be protective of human health and the environment.
  2. Attain media cleanup objectives.
  3. Control the sources(s) of releases.
  4. Comply with applicable standards for management of wastes.

The balancing criteria are:

  1. Long-term reliability and effectiveness (including sustainability, long-term stewardship considerations, and long-term environment impacts).
  2. Reduction of toxicity, mobility or volume of waste and contaminated medial.
  3. Short-term effectiveness (including near-term environmental impacts).
  4. Implementability.
  5. Cost.

The balancing criteria are evaluated by the following factors:

1) Long-term Reliability and Effectiveness: The remedy shall be evaluated for long-term reliability and effectiveness, including the consideration of the magnitude of risks that will remain after implementation of the remedy; the extent of long-term monitoring, or other management that will be required after implementation of the remedy; the uncertainties associated with leaving contaminants in place; DOE’s long-term stewardship of the site, environmental impacts; sustainability; and the potential for failure of the remedy. Other criteria being equal, DOE shall give preference to a remedy that reduces risks with minimal long-term management, and that has proven effective under similar conditions. 

2) Reduction of Toxicity, Mobility or Volume: The remedy shall be evaluated for its reduction in the toxicity, mobility, and volume of contaminants. Other criteria being equal, DOE shall give preference to a remedy that uses treatment to more completely and permanently reduce the toxicity, mobility, and volume of contaminants. 

3) Short-Term Effectiveness: The remedy shall be evaluated for its short-term effectiveness, including the consideration of the short-term reduction in existing risks that the remedy would achieve; the time needed to achieve that reduction; the near-term environmental impacts; and the short-term risks that might be posed to the community, workers, and the environment during implementation of the remedy. Other criteria being equal, DOE shall give preference to a remedy that quickly reduces short-term risks as well as near-term environmental impacts, without creating significant additional risks. (This is where consideration of number of trucks moving up and down the hill would be evaluated.)

4) Implementability: The remedy shall be evaluated for its implementability or the difficulty of implementing the remedy, including the consideration of installation and construction difficulties; operation and maintenance difficulties; difficulties with cleanup technology; permitting and approvals; and the availability of necessary equipment, services, expertise, and storage and disposal capacity. Other criteria being equal, DOE shall give preference to a remedy that can be implemented quickly and easily, and poses fewer and lesser difficulties. 

5) Cost: The remedy shall be evaluated for its cost, including a consideration of both capital costs, and operation and maintenance costs. Capital costs shall include, without limitation, construction and installation costs; equipment costs; land development costs; and indirect costs including engineering costs, legal fees, permitting fees, startup and shakedown costs, and contingency allowances. Operation and maintenance costs shall include, without limitation, operating labor and materials costs; maintenance labor and materials costs; replacement costs; utilities; monitoring and reporting costs; administrative costs; indirect costs; and contingency allowances. All costs shall be calculated based on their net present value. Other criteria being equal, DOE shall give preference to a remedy that is less costly, but does not sacrifice protection of human health and the environment.