Remedial Investigation/Feasibility Study
The Department of Environmental Conservation (DEC), along with the Departments of Health (DOH) and Law (DOL), is responsible for ensuring the cleanup of inactive hazardous waste disposal sites across the state. Under New York State's Inactive Hazardous Waste Disposal Site Remedial Program, the process begins with the discovery of a potential hazardous waste site and follows a path of thorough investigation, remedy selection, design, construction and monitoring. This fact sheet highlights one stage in the comprehensive process, the Remedial Investigation/Feasibility Study (RI/FS).
Remedial Investigation/Feasibility Study (RI/FS)
RI/FS begins when hazardous waste contamination is confirmed.
The RI/FS follows preliminary site investigations by DEC and DOH that verify the presence of hazardous wastes that pose a significant threat to public health and the environment.
DEC and DOH gather detailed site information to work toward an effective remedial action.
DEC's Division of Environmental Remediation or the responsible party under an enforceable consent order carries out a Remedial Investigation (RI) to determine the nature and extent of contamination. DEC, along with DOH, uses the RI information to then perform a Feasibility Study (FS) that evaluates possible remedies. The FS becomes the basis for selection of a remedy that effectively eliminates the threat posed by contaminants at the site. The RI/FS results in a Record of Decision (ROD) describing the cleanup that will be carried out and documenting the decisions that led to the chosen remedy.
The state initiates a variety of activities to inform and involve the public during the remedial process.
Throughout the remedial process, the state encourages public involvement by giving the public a key role in the remedy selection process of the RI/FS. Public meetings, newsletters, fact sheets, and project documents contribute to the exchange of information and provide opportunity for comment.
The state achieves successful hazardous waste remediation with the cooperation of many groups.
The RI/FS process requires a detailed examination of a site to fully understand its impact on public health and the environment before deciding on a remedy. Because of this, State engineers, geologists, chemists, and health specialists work with consultants, contractors, municipalities, potentially responsible parties, and citizens to investigate the contamination and select an appropriate remedy. The process can take up to two years to complete.
The sections below describe how the state chooses on an appropriate remedy.
Remedial Investigation (RI)
The RI defines the threat to public health and the environment.
The responsible party or DEC performs an RI at each Class 2 inactive hazardous waste disposal site after preliminary investigations have shown that contaminants pose a significant threat to public health or the environment. Through extensive sampling and laboratory analyses, the RI identifies the length, depth and width of contamination, defines the pathways of migration and measures the degree of contamination in surface water, groundwater, soils, air, plants, and animals. Information gathered during the RI fully describes the hazardous waste problem at the site so that the appropriate remedy can be selected.
DOH evaluates ways in which people may be exposed to hazardous waste.
DOH reviews and recommends activities that will be performed during the RI to ensure that a complete picture of potential health impacts is understood. Such activities include identifying the ways contamination can reach people, such as through direct contact, eating, drinking, or breathing.
Feasibility Study (FS)
Remedial action choices are developed during the FS.
The Feasibility Study uses RI information to develop alternative remedies that will eliminate the site's threat to public health or the environment. Wherever feasible, the state selects a remedy that permanently reduces or eliminates the contamination.
The state evaluates the remedial alternatives to reach a balanced decision that protects people and the environment.
The responsible party and DEC screen each alternative to make sure the remedy is technically suitable for the site. Following the initial screening, DEC and DOH weigh the remaining alternatives against a number of other conditions, including:
- overall protection of public health and the environment
- reduction in toxicity, mobility and volume of hazardous waste (e.g., by thermal destruction, biological or chemical treatments or containment wall construction)
- long-term effectiveness and permanence
- short-term effectiveness and potential impacts during remediation
- implementation and technical reliability
- compliance with statutory requirements
- community acceptance
DEC prepares the proposed remedial action plan for public comment.
The outcome of the selection process is the recommendation of a remedy that best satisfies a combination of these conditions. The remedy becomes part of a proposal that is presented to the public for comment.
Proposed Remedial Action Plan and Public Comment
The state presents the proposed remedial action plan to the public.
After the RI/FS is completed, DEC and DOH hold a public meeting to propose the remedial solution. The Proposed Remedial Action Plan (PRAP) summarizes the decision that led to the recommended remedial action by discussing each alternative and the reasons for choosing or rejecting it.
Public comment can make a difference in the remedial action plan.
The public is encouraged to review the PRAP and make comments either at the meeting or during the comment period that follows. The comments are reviewed and compiled in a Responsiveness Summary and modifications to the proposed remedial action plan may be made. Additional public notice is required if a modified remedial action plan differs significantly from the earlier selection.
The final remedial decision is documented in the record of decision.
DEC drafts a Record of Decision (ROD) which includes the selected remedial action, the Responsiveness Summary and a bibliography of documents that were used to reach the remedial decision. DOH and DOL have an opportunity to comment on the draft ROD before final DEC approval. When the ROD is finalized, remedial design and construction can begin.