Under the NYC BCP, analysis of the proposed
remedial action must consider the following factors:
Threshold
Criteria - all remedies must
satisfy threshold criteria for the intended use:
- Protection of public health;
and
- Protection of the
environment.
Balancing
Criteria:
- Compliance with standards, criteria and guidance;
- Short-term effectiveness and
impacts;
- Long-term effectiveness and
permanence;
- Reduction of toxicity, mobility and volume of
contaminated material;
- Implementability;
- Cost
effectiveness;
- Community
Acceptance;
- Land use; and
- Sustainability of the remedial
action.
Evaluation of these criteria is documented in a Remedial
Alternatives Analysis that is contained in the Remedial Action Work Plan. The
Alternatives Analysis is required to
consider a permanent cleanup option (also known as a Track
1 cleanup).
Permanent
remedies, including complete source elimination by removal or treatment on-site,
are preferred.
Engineering and Institutional Controls can be employed in the
remedy if pathways for human health exposure are addressed and off-site
migration is controlled. Potential
human health exposure pathways will be evaluated by NYC Department of Health and
Mental Hygiene (NYC DOHMH). OER
will obtain the concurrence of the NYC DOHMH prior to approving the
RAWP.