Comment on cleanup guidance

When cleaning up a contaminated site, the Model Toxics Control Act (MTCA) requires using permanent solutions to the maximum extent practicable. Permanent solutions do not rely on controls (such as containment barriers or land use restrictions) to remain protective after the cleanup is complete. MTCA requires more permanent solutions if their added benefit is greater than their added cost.

The MTCA Cleanup Regulations specify how to select a cleanup action that meets this statutory requirement using a disproportionate cost analysis (DCA). The evaluation involves identifying the benefits (such as protectiveness and long-term effectiveness) and costs (both construction and post-construction) of possible cleanup alternatives. The process ranks them by their degree of permanence then compares their relative benefits and costs starting with the most permanent.

We are developing this guidance to help people conducting cleanups understand how to complete the evaluation required by the rule. We also created a tool using Microsoft Excel to help people conduct the evaluation. The guidance includes instructions on how to use the tool.

We invite your comments on:

• Draft Guidance and Tool for Determining if a Cleanup Action uses Permanent Solutions to the Maximum Extent Practicable using Disproportionate Cost Analysis
• The draft DCA Tool