Non-Time-Critical Removal Actions
Removal responses are common at Superfund Sites when the contamination poses an immediate threat to human health and the environment. Removals are classified as either emergency, time-critical, or non-time-critical depending on the extent and type of contamination. Site managers have many logistical considerations to balance under high time constraints. The documents below are a partial list of EPA's guidance for removals, with a focus on Non-Time-Critical Removal Actions (NTCRA). For additional information, please visit EPA's Role in Emergency Response.
This memorandum will guide project managers during the decision process of selecting between remedial and removal actions. Pertinent NCP criteria are summarized to ensure that Regions properly consider and document the rationale for employing removal authorities.
OSWER 9360.0-40P, February 2000
The purpose of this guidance is to provide information on the procedures and activities EPA uses in conducting non-time-critical removal actions under CERCLA and the NCP. On-Scene Coordinators (OSCs) and Remedial Project Managers (RPMs) should use this guidance to ensure that non-time-critical removal actions are conducted in accordance with applicable laws, regulations, and EPA policy. This guidance focuses primarily on those aspects of the removal process that are unique to non-time-critical removal actions. EPA 540/F-93/057, OSWER 9360.0-32, August 1993
- Conducting Non-Time-Critical Removal Actions under CERCLA Fact Sheet(PDF) (4 pp, 63 K)
Summarizes "Guidance on Conducting Non-Time-Critical Removal Actions Under CERCLA" (OSWER Directive 9360.0-32). The guidance is to be used in conjunction with EPA's Superfund Removal Procedure (SRP) manual.
EPA 540/F-94/009, OSWER 9360.0-32FS, NTIS: PB93-963422, December 1993
- Guidance on Non-NPL Removal Actions Involving Nationally Significant or Precedent-Setting Issues (PDF)(9 pp, 69 K)
Outlines the defining criteria to determine if a non-NPL removal action requires Headquarters concurrence. Also details procedures that should accommodate removals belonging to five categories that do not require HQ concurrence. For mercury, see updated policies described in "Concurrence Policy For Mercury Removals" (May 1998).
OSWER 9360.0-19, March 1989
- Final Guidance on Implementation of the "Consistency" Exemption to the Statutory Limits on Removal Actions (PDF)1(5 pp, 47 K)
Outlines the appropriate applications of the "Consistency" exemption for removal actions exceeding the statutory limit of one year or $2 million. Supersedes the 1987 guidance.
OSWER 9360.0-12A, June 1989
- Concurrence Policy for Mercury Removals (PDF)(3 pp, 36 K)
Modifies Headquarters consultation requirements concerning removal actions addressing certain residential mercury contaminations. Mercury contamination will no longer be considered "nationally significant" unless the contamination is contained within the building structure, in which case consultation requirements should be followed in accordance with "Response Actions at Sites with Contamination Inside Buildings" (August 1993).
OSWER 9360.1-05, May 1998
This memorandum clarifies OSRTI policy regarding removal actions at methane gas release sites under CERCLA authority.
OSWER 9360.0-8, January 1986