A removal action is a response implemented in an expedited manner to address contamination that poses a threat to human health and the environment. Removal actions can occur during any phase of the cleanup process.
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A removal action may be warranted when there is a release or threat of release into the environment of a hazardous substance, pollutant, or contaminant that poses an imminent and substantial danger to human health or the environment. The type of response is selected based on the site-specific situation, the urgency of the threat of the release, and the planning period before the action is initiated. Removal actions are categorized as follows:
- Emergency Removal Action: An emergency removal action is necessary when a release requires that on-site activities begin within hours or days. These actions must be conducted immediately and can be initiated using verbal authorization.
- Time-Critical Removal Action (TCRA): A TCRA is used when the planning period before field work starts is less than six months. In this case, an Engineering Evaluation/Cost Analyses (EE/CAs) is not required, although it is still important to have an appropriate work plan to implement the removal action and mitigate the threat.
- Non Time-Critical Removal Action (NTCRA): An NTCRA is conducted when a removal action is determined to be appropriate, but a planning period of at least six months is available before on-site activities will begin. The NTRCA requires the development of an EE/CA.
For emergency removals, TCRAs, and NTCRAs, the Remedial Project Manager (RPM) prepares an Action Memorandum (AM). The AM for an interim action specifies what threat is being addressed and how long the action will remain effective. The AM should state what type of final action may be conducted and how the removal action contributes to the implementation of the final action. The AM for final actions should specify the performance standards or cleanup levels to be reached by the actions.
A QDR is required for the AM and EE/CA documents prior to submittal to regulatory agencies.
Based on the extent to which the threats are mitigated by the action, a removal action could be either the final remedy or an interim action followed by a remedial action as the final remedy. Both TCRAs and NTCRAs can be final actions, but emergency removals are seldom final actions. In cases where the removal action is the final remedy, the removal action may lead to either response complete (RC) or site closeout (SC). If the removal action was conducted during the Preliminary Assessment/Site Inspection (PA/SI) phase and achieves SC, this should be documented by obtaining a No Further Action (NFA) determination from regulatory agencies as part of the PA/SI. If the removal action was accomplished during the Remedial Investigation/Feasibility Study (RI/FS) phase, any final determination of RC and/or SC must be documented in the Record of Decision (ROD)/Decision Document (DD) including any long-term management requirements. Removal actions conducted during subsequent Environmental Restoration Program (ERP) phases needs to follow the RC and SC requirements per the applicable ROD/DD.
For more information, Chapter 7 of the DON Environmental Restoration Program Manual details removal action considerations.