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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