United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
OSWER-9360.0-39FS
PB99-963314
EPA-540-F-99-006
April 2000
vVEPA Improving Site Assessment:
Integrating Removal and
Remedial Site Evaluations
Office of Emergency and Remedial Response
Quick Reference Guidance Series
ABSTRACT
Superfund site assessment events are designed to quickly and accurately describe the potential for human and environmental
exposure to uncontrolled hazardous substances. Where appropriate, integrating assessment activities for the removal and
remedial programs should realize additional savings in time and resources. This document updates the existing guidance on
integrating events performed for the different Superfund programs to reflect organizational changes, incorporate new
technologies, and publicize successful pilot studies that have led to improved site evaluation methods. The primary audience
for this document is the site assessment community, which includes EPA On-Scene Coordinators (OSCs), Site Assessment
Managers (SAMs), Remedial Project Managers (RPMs), their counterparts in States or other Federal Agencies, and site
assessment contractors.
INTRODUCTION
Integrated site evaluations are ameans of speeding the site
evaluation process and saving resources by meeting the
requirements and goals of multiple programs. It is
important to distinguish integrated site evaluations from
combined site assessments. Integrated site evaluations
may merge features of the removal and the remedial
programs to reduce duplication of effort. An example of
integration is collecting data that will meet the needs of
both a removal assessment and a remedial site inspection
(SI), producing a single document Combined
assessments, on the other hand, consolidate specific steps
within either the removal or the remedial program. For
example, you might combine a remedial preliminary
assessment (PA) with a remedial SI to form a PA/SI
combined assessment In summary, integrated evaluations
simultaneously fulfill the requirements of different
programs, whereas combined assessments are within one
program.
Integration is not merely the consideration of the
requirementsofoneprogramwhileperformingevaluations
under the other program. An integrated assessment meets
the standards of multiple uses. Integrated assessments are
not limited to the removal and remedial programs, but can
bejjroadened to include other site assessment activities
under EPA programs other than Superfund, as well as
assessments performed for other Federal and State
programs. This fact sheet is intended to supplement
existing guidance, and to supersede the existing fact sheet
for integrating removal and remedial site evaluations.
TRADITIONAL REMOVAL AND REMEDIAL
SITE EVALUATIONS
Initially, me Superfund program pursued site assessment
activities for the removal and remedial programs
separately. This division was due partly to the separate
definitions and descriptions given to these activities in the
National Oil and. Hazardous Substances Pollution
Contingency Plan (the NCP), and the statute that created
and defined Superfund.1 The removal and remedial
programs developed distinct views regarding the nature of
risks and appropriate responses for their respective sites.
EPA Regions evaluated new sites to determine if the
potential risks at the site warranted emergency response, or
longer-term remedial action. The original site assessment
processes described for each program were similar.
However, the remedial program was tailored toward
scoring a site under the Hazard Ranking System (HRS),
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and placing appropriate sites on the National Priorities List
(NPL). Unlikethe removal program, remedial program
policies for documentation and data quality have been
subject to a process that has increased the complexity,
time, and resources needed to complete remedial site
assessment
Removal Site Evaluation
Removal siteassessrnent activities focus on demonstrating
whether the conditions at the site meet the NCP criteria for
a removal action. The removal assessment is designed to
show if, and how, the site poses a threat to human health or
the environment
Calls and reports of pollution events come to the removal
program from a variety of formal and informal sources.
The removal program screens these reports for emergency
response, removal or remedial action, or no further action.
The removal assessment includes elements similar to both
the remedial PA and SI, and is usually a one-step process.
The scope of the removal assessment can vary widely
depending on the characteristics of the site. Instead of
following a formal checklist or format, the removal
assessment documents specific information regarding
imminent and substantial endangerment to public health,
welfare, and/or the environment
Further removal site assessment may be performed as part
of an engineering evaluation/cost analysis (EE/CA). The
EECA analyzes removal alternatives for sites where Ihe
removal planning period is expected to exceed six months.
Another significant difference between the programs lies
in the procedures associated with data acquisition and use.
Both programs produce high-quality data which is tailored
to the specific intended uses of the data. However, each
program may use its own distinct methods to plan, collect,
and analyze samples of environmental contamination.
The removal program often considers large numbers of
samples from a site, and employs field screening methods
to minimize the time and costs of sampling and analysis,
while still producing data of acceptable quality. Most of
the resultant data has either associated quality assurance
data or confirmation data from an EPA approved method
0.C., EPA 600 series, SW 846 methods, or Contract
Laboratory Program (CLP) methods.) These screening
methods are often developed, reviewed, approved and
documented by EPA chemists on a site-by-site basis, to
allow more rapid and sensitive detection of specific
analytes of interest This allows OSCs to "screen"
thousands of samples in short time frames.
Remedial Site Evaluation
The original remedial site evaluation process included a
series of screening events to determine the likelihood of
relative risk. As a site progressed through screening
events, greater time and resources were spent to
characterize site conditions and to generate the HRS
factors that determined whetherthe Agency considered the
site a priority for future remedial action. If not, EPA
"screened ouf' the site with aNo Further Remedial Action
Planned (NFRAP) decision. IfEPAdidnotNFRAPthe
site, the end result would likely be further site
characterization in a Remedial. Investigation and Feasibility
Study.
The remedial assessment process begins when the site is
discovered and entered into the Comprehensive
Environmental Response, Compensation, and Liability
Information System (CERCLIS) (for further guidance on
CERCLIS screening, see Improving Site Assessment: Pre-
CERCLIS Screening Assessments).2 The SAM then orders
a PA for the site, to gather basic site information which
does not require sample collection or analysis, and
generally includes a cursory site visit (PA reconnaissance,
or "recon."). For the purposes of this document, "PA"
includes innovative approaches to remedial site
assessment, such as abbreviated PAs and combined
PA/SIs.
If the PA does not screen the site out of the process, the
SAM generally orders an SI. The SI gathers additional
evidence, including environmental samples, to determine
a preliminary site HRS score. In some cases, additional
information is needed, and the Agency performs an
expanded site inspection (ESI) to gather the additional data
needed to complete the site assessment.
While the removal program rapidly analyzes large
numbers of samples using field screening methods, the
remedial program generally relies on the formal and
resource-intensive Contract Laboratory Program (CLP),
which manages a core set of certified labs. These labs use
prescribed sample handling and analysis techniques to
meet the need for exhaustive documentation for remedial
site investigation. The high costs associated with this
approachmean that remedial investigations usually involve
a limited number of samples, with meticulous
documentation.
Remedial site assessment activities which do not result in
a NFRAP generally culminate in an HRS package,
documenting the EPA's evaluation activities and
describing the rationale for placing the site on the NPL.
EPA publishes proposals to place a release on the NPL in
the Federal Register, and provides an opportunity for
public comment. As a result, the data quality and level of
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documentation have become increasingly rigorous in the
remedial program. The corresponding time frame to
perform remedial site assessment activities has grown in
proportion to the complexity and frequency of legal
challenges to the Agency's listing decisions.
IOTEGRATING ASSESSMENT ACTIVITIES
With time, removal and remedial personnel came to
recognize a class of sites that straddle the boundaries of
their programs, sometimes requiring assessment and
response work from both programs. As part of the
Superfund Accelerated Cleanup Model (SACM), EPA
encouraged site assessment personnel to design field
activities to meet the goals and needs of the two programs,
conserving time and resources. SACM was intended to
increase efficiency and shorten response times. The
concept was elaborated in. Assessing Sites Under SACM-
Interim Guidance? Pilot tests in seven EPA regions
revealed mat integrated site assessments can improve and
streamline the process by reducing sampling, duplication
of effort, and inactive periods between steps in the
process.4
In spite of the different objectives of removal and remedial
assessments, the two programs share many goals. Bolh
evaluate the potential for human exposure through the
same media (ground water, surface water, soil and air);
account for sensitive environments; and include file
investigations, site vishs, and (in some cases) site sampling
events. These overlapping objectives offer many
opportunities to consolidate site assessment activities.
One of the most interesting possibilities for integration is
in sample analysis. Remedial site assessment could be
greatly improved by incorporating screening methods
which are routinely used by the removal program. This
could result in more efficient placement of sampling
points, and better confidence that the CLP samples reflect
thepoints of greatest contamination at the site. In addition,
remedial assessment would provide a more accurate
picture of site conditions, if it incorporated more than just
a handful of samples. New approaches to data production,
such as Performance-based measurement systems, hold
great promise for integrated assessment
Site Discovery/Screening
Integrating removal and remedial site evaluations may not
be appropriate at all sites. EPA regions have begun to
evaluate new sites after discovery using a "one-door"
screening process to determine whether the site should be
addressed by purely removal or purely remedial
authorities, or by a hybrid of the two. In addition, EPA has
begun cooperating with State and other Federal Agencies
in joint efforts and voluntary cleanup programs that may
create fester and easier ways to meet the objectives and
requirements of the NCP (see Exhibit 1 attached).
Emergency Responses
This guidance is intended to provide the EPA regions and
those who perform Superfund site evaluations with
flexibility in meeting the goals of the removal and remedial
programs. This should be accomplished in a manner that
preserves the Regions' ability to respond to environmental
emergencies. In the event of a "classic" emergency, the
region should implement response actions immediately.
Sample collection and removal actions precede
administrative investigation activities in these cases.
File Search
Integrated file search activities should include all of the
elements of the removal assessment file search. However,
the removal assessment need only include information
pertinent to documenting an imminent and substantial
endangerment Refer to the list of elements displayed in
Exhibit 2. Thorough documentation of these elements can
be critical to meeting me needs of both programs.
EXHIBir2
FILE SEARCH AND PERSONAL INTERVIEW
Elements Common to Both Programs
Regulatory program file search (e.g., RCRA,
water, state)
Site access information and property ownership
Site history, industrial processes, and
management practices
Substances used at site
Past releases (substances, locations, impacts)
Latitude and longitude
Topographic maps, aerial photographs
Generally Removal Assessment Only
Potentially responsible party (PRP) search
Treatment technology review •
Site Visits - Field Investigation/ PA Recon
Generally, site visit activities and documentation needs are
similar for the removal and remedial programs. Integrated
assessments can easily meet the needs of both programs,
without significant increases in time and resources.
Currently, someregions occasionally performremedialPA
recons from the site perimeter. The assessment team must
gain site access approval for an integrated site visit Refer
to Exhibit 3 for additional details on common elements.
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Complete the Removal Assessment/Remedial PA
Based on site-conditions and the information already
gathered for the file search, the Region identifies and
collects any information required to complete removal and
remedial assessments.5 For example, the remedial PA
requires specific information about potential or actually
exposed targets, to produce a preliminary HRS score.
Therefore, an integrated assessment must include this
information (see Exhibit 4). Based on the results, me
Region should either assign the site the No Further
Remedial Action Planned (NFRAP) designation, or
complete the integrated assessment Remember, the
information needed for the removal assessment alone may
only include some of the elements shown in Exhibit 3.
EXHIBITS
DATA GATHERED IN THE SriEVisrr
Elements Common to both Programs
Current human exposure identification
Source identification (locations, types, sizes)
Information on substances present (labels on
drums and containers)
Containment evaluation
Evidence of releases (e.g., stained soils, stressed
vegetation)
Locations of wells (on site/immediate vicinity)
Runoff channels or pathways (PPEs)
Location of surface water bodies
Identification of nearby wetlands
Nearby land uses (e.g., residential, schools,
parks)
Distance measurements or estimates for
possible targets (e.g., wells, residences,
wetlands)
Public accessibility (e.g., fences, posted signs)
Blowing soils and air contaminants
Photo documentation
Site sketch
Generally Removal Assessment Only
Eligible petroleum releases
Fire and explosion threat
Urgency of need for response
Response and treatment alternatives evaluation
Greater emphasis on specific pathways
Sampling
Generally Remedial Assessment Only
Perimeter survey
Number of people within 200 feet
Sensitive environments (e.g., endangered
species habitats)
Review all pathways
Integrated assessments are often appropriate at sites where
work beyond a remedial PA will clearly be needed. They
enable you to plan a single sampling event and prepare a
single assessment document You may choose to write a
combined PA/SI as part of the integrated assessment
document, or you may perform an abbreviated PA prior to
initiating the integrated assessment (for further guidance,
see Improving Site Assessment: Abbreviated Preliminary
based on the appropriate Agency guidance.
EXHIBIT 4
ADDITIONAL DATA NEEDS
TO COMPLETE THE REMEDIAL PA
Population within 1 and 4 miles
All private and municipal wells within 4 miles •
Depth to ground water
Local or regional geology and climate
Distance to surface water measured
Fisheries along 15-mile TDL for surface water
migration pathway
Size of wetlands
Previous cleanup or sampling activities
Oversight authority
Preliminary HRS score
Integrated Sampling Plans
When a site will require a remedial SI, producing an
integrated sampling plan can further conserve time and
resources. At this stage, the Remedial Project Manager
(RPM) should join the OSC and the SAM in designing the
sampling and analysis plan to ensure that it addresses the
goals of both programs, if possible (see Exhibit 5). This
is especially important at sites where the Region intends to
initiate the Remedial Investigation prior to NPL listing, or
where an EE/C A might be needed for subsequent non-time
critical removal actions.
Complete the Removal Assessment/Remedial SI
The remedial SI seeks to confirm assumptions made at the
remedial PA stage, and to gather more detailed information
about the site. Based on the integrated sampling plan, the
Region should collect any analytical data required to
satisfy the goals of both programs.7
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FLEXIBILITY IN APPROACH
The approach taken to integration will vary depending on
the site situation and regional dynamics. Successful
integrated evaluations begin with a strong working
relationship between the two programs. This could be
achieved in several ways. Cross-training the personnel
from each program to recognize the needs of the other
would facilitate integration. The two programs could be
merged into a single program channeling all sites.
Implementation strategies must be appropriate to the
structure and dynamics of each Region to ensure success.
EXHIBITS
DIFFERENCES IN SAMPLING EMPHASIS
Removal Assessment Emphasis
Sampling from containers
Physical characteristics of wastes
Treatability and other engineering concerns
On-site contaminated soils
Composite and grid sampling
Rapid turnaround on analytical services
Screening data with definitive confirmation
PRP-lead removal actions
Goal of characterizing site (e.g., defining extent
of contamination)
Focus on NCP removal action criteria
Remedial Assessment Emphasis
Attribution to the site
Background and observed release samples
Ground water samples
Grab samples from residential soils
Surface water sediment samples
HRS targets related to sample locations
Average of 10 - 30 samples
Strategic sampling for HRS factors and level of
contamination
Analysis via CLP labs
Full screening organic and inorganic analysis
Definitive data
Documentation of targets and receptors
Computing HRS scores
Standardized reports
OTHER CONSIDERATIONS
Removal actions often involve screening decisions and
quick response to reduce or eliminate threats. Regions
may ensure that the integrated sampling plan meets
remedial program needs by completing a PA, abbreviated
PA, or the PA portion of a combined PA/SI before
producing the sampling and analysis plan. This should be
accomplished in a manner which does not delay a removal
response.
Sample analysis has traditionally been a point of departure
between the removal and remedial programs. Analytical
services must be designed to include documentation and
reporting that support appropriate data validation. If the
removal assessment requires analyses which might not
support HRS uses, you should consider separate analysis
using "split" samples, or find an appropriate mechanism
that will satisfy HRS documentation requirements without
delaying removal response.
The HRS data requirements of the remedial site
assessment program must form the basis for common data
elements. In instances where samples can be analyzed
consistent with both programs, Regions are encouraged to
integrate their actions. When this proves impracticable,
other methods should be applied to dovetail the work of
removal and remedial personnel and ensure appropriate
programmatic collaboration. . Once an integrated
evaluation has been completed, the achievements should
be reported in CERCLIS according to guidance for both
programs.
REFERENCES
1. U.S. Environmental Protection Agency, Office of
Emergency and Remedial Response, January 1992.
National Oil and Hazardous Substances Pollution
Contingency Plan (NCP), Publication 9200.2-14.
2. U.S. Environmental Protection Agency, October
1999. QuickReference Guidance Series - Improving
Site Assessment: Pre-CERCLIS Screening
Assessments. Publication 9375,2-1 IPS.
3. U.S. Environmental Protection Agency, Office of
Solid Waste and Emergency Response, December
1992. Assessing Sites Under SACM - Interim
Guidance, Publication 9203.1-051.
4. U.S. General Accounting Office, July 1997.
SUPERFUND: Integrated Site Assessments May
Expedite Cleanups, Publication GAO/RCED-97-
181.
5. U.S. Environmental Protection Agency, Office of
Emergency and Remedial Response, September
1991. Guidance for Performing Preliminary
Assessments Under CERCLA, Publication 9345.0-
01A.
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Exhibit 1
Site Assessment
Flow Chart
6. U.S. Environmental Protection Agency, October
1999. QuickReferenceGuidanceSeries-/»jprav/«g
Site Assessment: Abbreviated Preliminary
Assessments. Publication 9375.2-09FS.
7. U.S. Environmental Protection Agency, Office of
Emergency and Remedial Response, September
1992. Guidance for Performing Site Inspections
Under CERCLA, Directive 9345.1-05.
FOR MORE INFORMATION
For more information on Integrated Site Assessments,
please contact Daniel Thornton at EPA Headquarters,
phone (703) 603-8811, or email thornton.dan@epa.gov.
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