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VCMA measure calculated - when and with what data

  • "For Superfund remedial actions, at the time an enforcement document is finalized (e.g. issuance of a unilateral order or corrective action order, signing of an agreement on consent or consent decree) using data available from the remedial investigation, feasibility study, and/or record of decision (or any other relevant data). 

 

  • For Superfund non-time critical removal actions, at the time an enforcement document is finalized using data available from the engineering evaluation/cost analysis, and/or the action memorandum (or any other relevant data).  

 

  • For Superfund time-critical removal actions, at the time an enforcement document is finalized using data available from the action memorandum (or any other relevant data).  Sometimes few data are available for such cases at the time of the action memorandum.  If insufficient data exist for an estimate at the time of the action memorandum, the value for the measure should be entered at the soonest practical time after the settlement as data are available to calculate the measure; with the caveat that the best available value for the measure should always be entered in the same fiscal year in which the enforcement document is finalized.

 

  • For RCRA corrective actions, at the time an enforcement document is finalized using data available from RCRA inspections or corrective action investigations."

 

Source: 12/12/03 "Final Methodology for Estimating Superfund and RCRA Corrective Action Case Conclusion Data Sheet (CCDS) Environmental Benefits", p. 6 of the guidance.

 

See Also

      Volume of Contaminated Medium Addressed Definition

      Volume of Contamiated Medium Addressed Guidance

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