What is a Presumptive Response Strategy?

Presumptive Response Strategy

What is a presumptive response strategy and how does it differ from a presumptive remedy?

The Superfund Accelerated Cleanup Model (SACM) is a response approach aimed at moving sites more quickly through the Superfund cleanup process while still meeting all CERCLA statutory and regulatory requirements.One acceleration tool EPA developed under the SACM is the presumptive remedy concept.Presumptive remedies are preferred technologies for common categories of sites.They are based on historical patterns of remedy selection and EPA’s scientific and engineering evaluation of performance data on technology implementation.EPA has developed presumptive remedies for several types of sites such as former wood treatment facilities, municipal landfills, and sites with volatile organic compounds (VOCs) in soils.In October 1996, EPA published “Presumptive Response Strategy and Ex-Situ Treatment Technologies for Contaminated Ground Water at CERCLA Sites.”

A presumptive response strategy (PRS) expands upon presumptive remedies by integrating site characterization, early actions, remedy selection, performance monitoring, remedial design, and remedy implementation activities into a comprehensive, overall response strategy for sites.Although the PRS will not necessarily streamline the remedial investigation/feasibility study (RI/FS) phase, EPA expects that the use of the PRS will result in significant time and cost savings for the overall response to contaminated groundwater.By providing a mechanism for selecting achievable remediation objectives, the PRS will minimize the need for changing these objectives during remedy implementation.The October 1996 guidance illustrates how to employ the SACM at sites needing groundwater remediation by using a phased approach to site characterization and response actions.

In a phased approach, site response activities occur in a sequence of steps that use information gained from earlier phases to refine subsequent investigations, objectives, or actions.

EPA recognizes that phased implementation of groundwater remedies may not be appropriate for all sites, however, the Agency expects that some elements of the PRS will be appropriate for all sites with contaminated groundwater and that all elements will be appropriate for many of these sites.EPA plans to publish additional presumptive response strategies for other types of sites in the future.