As part of an overall on-going technical support role for the National Park Service, The Johnson Company prepared the CERCLA (Comprehensive Environmental Response Compensation and Liability Act, or “Superfund”) documents necessary to begin remedial action at the Valley Forge National Historical Park Asbestos Release Site. These documents included the Final Feasibility Study Report, the Proposed Plan, and the Record of Decision.
Based on the results of the Remedial Investigation and preliminary drafts of the Feasibility Study, The Johnson Company prepared a Final Feasibility Study (FS) which evaluated alternatives for remediation of asbestos- and metals-contaminated soils utilizing different combinations of technologies, including excavation and off-site disposal, capping, and in-situ stabilization. Based on the ability to appropriately manage risks, compliance with Applicable or Relevant and Appropriate Requirements (ARARs), and cost-effectiveness, the National Park Service selected the remedial alternative of shallow soil excavation and off-site disposal in accordance with CERCLA and the National Contingency Plan.
Proposed Plan
The Johnson Company prepared the Proposed Plan document that summarized the results and findings of the Remedial Investigation (RI), Risk Assessment, and FS, and presented the National Park Services’ preferred alternative for cleaning up the contaminated soils at the site pursuant to CERCLA, including the rationale for that preference. The Proposed Plan presented a summary of all remedial alternatives considered in the FS including implementation cost estimates. The Proposed Plan was prepared as part of the public participation requirements of CERCLA, which also included a public comment period, a public meeting, and the preparation of a Responsiveness Summary which provided the NPS’ responses to comments received during the public comment period.
Record of Decision
Based on input received during the public participation process, The Johnson Company prepared the Record of Decision (ROD) for the National Park Service presenting the selected remedy. This ROD documented the steps completed that led to the selected remedy (including the technical rationale for the selection), the remedial action objectives for the clean-up, and statutory determinations under CERCLA. The ROD also included remedial performance standards and remediation goal verification procedures.
