EPA/540/G-87/005
(OSWER Directive 9355.1 -02)
September 1987 •
The RPM Primer
An introductory Guide to the Role and Responsibilities
of the Superfund Remedial Project Manager (RPM)
September 1987
U.S. Environmental Protection Agency
Office of Emergency and Remedial Response
401 M Street, SW
Washington, D.C. 20460
-------
NOTICE
This document has been reviewed in accordance with U.S.
Environmental Protection Agency policy and approved for
publication. Mention of trade names or commercial products
does not constitute endorsement or recommendation for use.
-------
Preface
The purpose of this document is to familiarize new Remedial Project Mangers (RPMs) with their roles and
responsibilities in the Superfund remedial program. It also can serve as an orientation to the Superfund
remedial program for EPA program staff, and the public. It is not intended to be a training document EPA
has developed other materials and conducts courses specifically for training purposes (See Attachment A
for a selected course listing.)
The Acme Waste Disposal Co. site, the people, and the events described in this document are hypothetical
and were created to depict the cleanup of an abandoned hazardous waste site. This example illustrates
typical Superfund remedial response activities and was written to demonstrate specifically the important
role of the RP in managing site cleanup and in coordinating the various participants. Key terminoioqv and
concepts appear in bold face. , yy
For simplicity, the example depicted in the Primer is a Fund-financed, Federal-lead project from start to
finish. In reality, a project may switch from Fund- to Enforcement-lead, and from Federal- to State-lead
°.un"9 t|ie.remed|a| Process- thereby altering roles of the participants. In addition, the example portrays
the RPMs involvement with only one site, when an RPM actually may be involved with several concurrent
projects.
References for detailed information on the various aspects of the Superfund program are provided in an
annotated bibliography (Attachment B). It is important to note that these documents are frequently up-
Q3IGQ.
-------
-------
Contents
Page
List of Exhibits Vj
Acknowledgement . vjj
Acronyms jx
Site Background -j
Your Assignment -j
Background of the Superfund Program 1
The Remedial Response Process 1
Removals 3
Enforcement and Legal Counsel 3
Community Relations 4
Other Program Participants . 4
Project Management Concepts 4
Project Kickoff 5
Phased RI/FS 8
Initial Site Visit and Site Planning 8
Technical Advisory Committee g
Site Management Plan -j 1
Work Plan Review 12
Rl Phase I 14
FS Phases I and II 15
Rl Phase II 16
FS Phase III 16
TAG Meeting and Remedy Selection 17
Public Comment Period 18
Transition to Design 18
ROD Approval , 18
State Assurances 19
Remedial Design ig
Remedial Action 20
Operation and Maintenance 20
Attachment A: RPM Training Course A.-(
Attachment B: Information Sources and Selected OSWER Directives B-1
-------
List of Exhibits
Exhibit Number
1 Fund-Financed, Federal-Lead Remedial
Response Process
2 Map of Acme Waste Disposal Co. Site
3 Site Management Plan for Acme
Waste Disposal Co. Site
4 Generic Schedule for Federal-Lead RI/FS
Page
10
.13
vi
-------
ACKNOWLEDGEMENT
This document was prepared for EPA's Hazardous Site Control Division - Russel Wyer; Director under the
direction of Paul Nadeau and Don White, both of HSCD. The EPA Project Coordinators were Steve Hooper
and Caroline Roe. Additional support was provided by other EPA Headquarters and Regional personnel.
Booz, Allen & Hamilton, Inc., Bethesda, Maryland, prepared the Primer (EPA Contract No. 68-01-7376)
The Booz, Allen Project Managers were Raymond Rose and Robert Kravitz.
The camera-ready copy was prepared by Ebon Research Systems, 1173 Spring Centre South Boulevard
Altamonte Springs, Florida 32714. (EPA Contract No. 68-03-3507).
vn
-------
-------
ACRONYMS
A/OSWER
Assistant Administrator for the Office of Solid
Waste and Emergency Response
A/E
Architectural/Engineering
ARARs
Applicable or Relevant and Appropriate Re-
quirements
ATSDR
Agency for Toxic Substances and Disease
Registry
CERCLA
Comprehensive Environmental Response,
Compensation, and Liability Act of 1980
CLP
Contract Laboratory Program
CRP
Community Relations Plan
DQOs
Data Quality Objectives
EE/CA
Engineering Evaluation/Cost Analysis
EPA
U.S. Environmental Protection Agency
ERA
Expedited Response Action
ERGS
Emergency Response Cleanup Services
ESD
FEMA
Federal Emergency Management Agency
FIT
Field Investigation Team
HRS
Hazard Ranking System
HSWA
Hazardous and Solid Waste Amendments
IAG
Interagency Agreement
IFB
Invitation for Bid
NCP
National Oil and Hazardous Substances Pollu-
tion Contingency Plan (40 CFR Part 300)
NEPA
National Environmental Policy Act
NPDES
National Pollution Discharge Elimination
System
NPL
National Priorities List
O&M
Operation and Maintenance
ORC
Office of Regional Counsel
osc
On-Scene Coordinator
Environmental Services Division
ix
-------
PA/SI
Preliminary Assessment / Site Inspection
PR
Procurement Request
PRPs
Potentially Responsible Parties
QAO
Quality Assurance Officer
RA
Remedial Action
RCRA
Resource Conservation and Recovery Act
RD
Remedial Design
RI/FS
Remedial Investigation / Feasibility Study
ROD
Record of Decision
RPM
Remedial Project Manager
RSCRC
RPO
Regional Superfund Community Relations
Coordinator
SARA
Superfund Amendments and Reauthorization
Act of 1986
SCAP
Superfund Comprehensive Accomplishments
Plan
ssc
Superfund State Contract
TAG
Technical Advisory Committee
TAT
Technical Assistance Team
USGS
U.S. Geological Survey
VOCs
Volatile Organic Compounds
Regional Project Officer
-------
Site Background
The Acme Waste Disposal Co. site received both
municipal and industrial wastes for 15 years until
the owners declared bankruptcy 5 years ago and
abandoned the facility. Two years ago, a fishkill in
nearby Lazy Creek prompted State and local health
officials to investigate. They found partially
covered, corroded, and leaking drums at the site,
along with eroded berms and trails of discolored
soil in areas around two unlined waste ponds on
the 55-acre property. Testing of 12 nearby private
water wells revealed low levels of several
suspected carcinogens.
The U.S. Environmental Protection Agency
(EPA) sent an EPA On-Scene Coordinator (OSC),
assisted by the Technical Assistance Team (TAT)
contractor, to inspect the site. Based on the
results, EPA mobilized the Emergency Response
Cleanup Services (ERGS) contractor to conduct a
removal action that included removing leaking
drums at the surface, stabilizing berms around two
waste ponds, erecting a security fence around the
property, and supplying the 12 affected residences
with bottled drinking water.
Following the removal action, EPA assigned the
Field Investigation Team (FIT) contractor to per-
form a preliminary assessment and site inspection
(PA/SI) to evaluate the need for further long-term
response. The PA/SI results were used to assign
the site a numerical ranking based on potential
hazard, using the Hazard Ranking System (HRS).
EPA then placed the site on the National Priorities
List (NPL), making it eligible for Fund-financed
remedial response actions. Acting in accord with
community concerns and Regional priorities, EPA
budgeted funds for initiating a remedial response
project in October, the beginning of the fiscal year.
Your Assignment
It's now August. You have just begun work with
the Waste Management Division in your Region.
You have been on the job 1 week when things get
really busy. You are called into your Section
Chief's office, where she tells you, "I'm assigning
you to the Acme site. You will be the RPM and it's
your responsibility to manage the site cleanup.
Funds are budgeted on the coming year's SCAP
for an Ri/FS. Pull the site file. Find out what you
can from the OSC. Also, we will need a CRP
ASAP."
It's a great opportunity for you...and a big
responsibility. There's much to become familiar
with—tasks, tools, terminology. Fortunately, you
have some valuable resources available to help
you in completing this important assignment.
Background of the Superf und Program
There are many inactive, abandoned sites
throughout the nation, like the Acme site, where
hazardous wastes have been inadequately or care-
lessly disposed of in the past. These sites are
releasing, or threaten to release, hazardous sub-
stances that endanger human health and the en-
vironment. The Superfund program was created to
address the potentially hazardous conditions at
these sites.
The original Comprehensive Environmental
Response, Compensation, and Liability Act
(CERCLA), Public Law 96-510, was enacted in
December 1980. Under this law, the Federal
Government was given the authority to clean up
hazardous waste sites and to respond to spills of
hazardous substances with money from the Hazar-
dous Substances Response Trust Fund (commonly
called the "Fund"). In addition, the Federal govern-
ment was given the authority to compel those
responsible for the hazardous waste problem,
through judicial action, if necessary, to conduct or
finance the cleanup. The Superfund Amend-
ments and Reauthorization Act (SARA), enacted
in October 1986, strengthened the authorities
under CERCLA for responding to hazardous waste
sites and significantly increased the size of the
Fund. EPA is responsible for managing the Super-
fund program.
The guidelines and procedures for implementing
CERCLA (as amended by SARA) are delineated in
a regulation called the National Oil and Hazar-
dous Substances Pollution Contingency Plan
(NCP), 40 CFR Part 300. The NCP provides fac-
tors to consider in determining the extent of
cleanup that is appropriate for a particular site.
The NCP also describes the process for conduct-
ing a remedial response (Exhibit 1).
The Remedial Response Process
Once a site is proposed for or placed on the NPL
it is eligible for a Fund-financed remedial response.
Remedial response activities are aimed at im-
plementing long-term permanent remedies at NPL
sites. Initial site planning defines the roles and
-------
Exhibit 1
FUND-FINANCED, FEDERAL-LEAD REMEDIAL RESPONSE PROCESS
PRE-REMEDIAL
ACTIVITIES
REMEDIAL
PLANNING
REMEDIAL
IMPIEMENTATION
1
SITE DISCOVERY
OR
NOTIFICATION
PRELIMINARY
ASSESSMENT
REMOVAL '
SITE
INSPECTION
APPLY HAZARD
RANKING SYSTEM
X
x
j
L
1
|
1
1
1
LEAD: FUND OR\-
ENFORCEMENT: \
FEDERAL OR _^
. STATE _^^
jT
FUND-FINANCED,
FEDERAL-LEAD
REMEDIAL
INVESTIGATION
(PHASES 1,11)
FEASIBILITY STUDY
(PHASES 1, II, III)
1
RECORD OF
DECISION
I
REMEDIAL
DESIGN
i
REMEDIAL
ACTION
OPERATION &
MAINTENANCE
I ENFORCEMENT2
1
1 EXPEDITED
J RESPONSE
1 ACTION f
(COST RECOVERY
Removals may occur at any point in the remedial process. If the lead agency determines that there is a threat to human health or the
environment, the lead agency may take a removal action to abate, minimize, stabilize, mitigate, or eliminate the release or threat of
release.
e the responsible parties are known, efforts are made, to the extent practicable, to have them perform the response actions.
Enforcement negotiations commonly occur just prior to the RI/FS and again just prior to the RD/RA.
a
Expedited Response Action (ERAs) are taken at NPL sites by the remedial program using removal program authorities. ERAs must
comply with the policies, procedures, and regulations of the removal program. Like removals, ERAs may occur at any point during the
remedial process.
-------
responsibilities of the response program par-
ticipants and outlines a course of action. EPA, the
State, contractors, other Federal agencies, and the
public, including parties responsible for creating or
contributing to the problem, all play a role in carry-
ing out remedial response activities. EPA, the
State, or the responsible parties may be desig-
nated as the lead organization for planning and
conducting remedial response activities.
Following initial planning, the lead organization
conducts a remedial investigation / feasibility
study (RI/FS). For the Acme site, EPA is the lead
organization. The Rl focuses on collecting data
and characterizing the site in order to assess
threats or potential threats to human health and the
environment posed by the site. The FS provides a
detailed evaluation of remedial alternatives using
environmental, engineering, and economic factors
in accordance with the NCP and CERCLA. The Rl
and FS are conducted as interdependent phases
so that the data gathered during the Rl support the
evaluation needs of the FS. The phased RI/FS
results in a recommendation and selection of
remedial action, which EPA documents in a
Record of Decision (ROD). Together, the RI/FS
and ROD process typically takes 22 months to
complete.
A remedial design (RD) is the next step. During
RD, detailed engineering plans, drawings, and
specifications are prepared. These are used to
solicit competitive bids to implement the remedial
action (RA). Site cleanup is conducted during the
RA, as specified in the engineering design. This
may involve treatment, disposal, and/or contain-
ment of the hazardous waste and cleanup, restora-
tion, or replacement of the affected resources. The
final step in the remedial process is operation and
maintenance (O&M), designed to ensure continued
functioning and effectiveness of the remedial
response action. The total remedial response
process may take 4 to 6 years, or more, to com-
plete and may cost millions of dollars.
Removals
Removals are another type of response action
that may be conducted under Superfund.
Removals are conducted to reduce or stop hazard-
ous substance releases or potential releases to the
environment. In general, removal actions require
less detail in planning than remedial actions be-
cause the emphasis is on finding a relatively rapid
and short-term solution, consistent with long-term
remedial action, to a problem having some degree
of urgency. Removals may be time critical
(response needs to be initiated within 6 months of
discovery) or non-time critical, depending on the
urgency of the situation.
CERCLA sets cost and duration limits on
removal actions; they may not exceed $2 million or
last more than 1 year. EPA can waive these limita-
tions, however, under certain situations and with
appropriate approval.
EPA On-Scene Coordinators (OSCs) direct and
coordinate Fund-financed, Federal-lead removal
activities. In some cases, a U.S. Coast Guard rep-
resentative may serve as the OSC. OSCs receive
support from governmental entities—for example,
EPA's Environmental Response Team-and from
EPA contractors, such as the Emergency
Response Cleanup Services (ERGS) and the Tech-
nical Assistance Team (TAT). At sites, where both
removal and remedial activities are undertaken, the
OSC and RPM must coordinate closely. The Su-
perfund Removal Procedures (OSWER Directive
9360.0-3A) provides guidance on conducting
removal activities.
Enforcement and Legal Counsel
For all Superfund sites, EPA and the States
make significant efforts to identify potentially
responsible parties (PRPs) and to compel them,
through legal action, if necessary, to undertake the
required cleanup activities. If EPA cannot compel
PRPs to undertake the necessary response ac-
tions, EPA will proceed with the cleanup and will at-
tempt to recover the costs later. Thus, maintaining
complete and detailed records of site activities is
essential for the purposes of enforcement activities.
During a Superfund remedial response, legal
questions often arise. EPA's Office of General
Counsel and Office of Regional Counsel provide
legal interpretation and direction to program par-
ticipants. The RPM is encouraged to coordinate
closely with the Office of Regional Counsel, par-
ticularly in the identification of applicable or
relevant and appropriate requirements (ARARs)
and in determining applicability of State cleanup
standards.
-------
Community Relations
Community relations activities also are an impor-
tant part of the Superfund program. Conducted
from the beginning of all Superfund responses, ef-
fective community relations encourages two-way
communication between the government agencies
involved and the local residents on site-related is-
sues. The overall objectives of Superfund com-
munity relations activities are to:
• Gather information about the local community
to Identify how citizens would like to be in-
volved in the Superfund process
* Give citizens the opportunity to comment on
and to provide input to technical response
decisions
• Inform the public of planned or ongoing ac-
tions
• Focus and resolve conflict
These objectives guide the planning and im-
plementation of community relations efforts in each
Superfund response project.
Each Regional office has a trained Regional Su-
perfund Community Relations Coordinator
(RSCRC) to work with the RPM to meet these ob-
jectives at each site. Community Relations in Su-
perfund: A Handbook (OSWER Directive 9230.0-
3A) provides additional guidance on the com-
munity relations program.
Other Program Participants
Many organizations assist EPA in responding to
the nation's hazardous waste problems. For ex-
ample, States are encouraged to take responsibility
for planning and managing site cleanups under
agreement with the Federal Government (State-
lead projects). In remedial actions for which the
Federal Government has lead responsibility, the
U.S. Army Corps of Engineers often manages the
remedial design and implementation for EPA. The
Federal Emergency Management Agency (FEMA)
assists EPA if a Superfund response involves the
relocation of residents. Under CERCLA, the Agen-
cy for Toxic Substances and Disease Registry
(ATSDR) conducts health assessments at Super-
fund sites to supplement EPA's public health
evaluations. The Coast Guard assists with hazard-
ous waste spills that occur in coastal areas. EPA
also can call on other Federal agencies (e.g.,
Department of Interior, National Oceanic and At-
mospheric Administration) to provide support, as
appropriate.
Project Management Concepts
The RPM, acting on EPA's behalf, manages
remedial activities. This individual is accountable
for the technical quality, schedule, and cost of the
work. As in most real management situations,
however, the RPM does not have the authority or
control over external factors to "require" that the
project proceed according to plan. Instead, the
RPM must develop a good management approach
and draw on interpersonal skills to facilitate needed
coordination and communication among the or-
ganizations and individuals on the project. Form-
ing and leading a project team are critical to the
success of Superfund projects.
The RPM must bring together individuals, or-
ganizations, and resources with a well formulated
plan to accomplish effectively and efficiently a set
of objectives. The RPM ensures success by:
(1) planning, monitoring, and controlling the
project
(2) directing, coordinating, and communicating
with project participants.
Soon after being assigned to a site, the RPM
must plan the project by:
• Establishing scope-determining project ob-
jectives and identifying discrete tasks needed
to achieve them.
• Scheduling-identifying time frames for each
task and the total project. The RPM may use
project scheduling systems such as, milestone
charts, bar charts, and critical path method
(CPM) diagrams to aid in scheduling.
• Budgeting-assigning costs to individual tasks
and the total project as outlined in the scope
and schedule.
Organizing-arranging personnel and other
resources to achieve the project objectives.
Monitoring and controlling involves observing
technical performance and taking corrective ac-
tions, as needed. The RPM's primary method for
monitoring activities is by comparing actual and
planned performance. The RPM should use
progress review meetings in conjunction with
regular reports on project status. In addition, the
RPM should conduct on-site field inspections
during key field activities. Variances from the
-------
planned project can be avoided or controlled by
taking one or more of the following actions:
have established a file on the Acme site. Several
basic observations about the site are apparent:
• Anticipatory Actions— modify external factors
so that project variances do not occur.
• Work-Around Strategies— respond to an exist-
ing negative variance to accommodate chan-
ges, but with no impact to overall project plan.
• Plan Modifications— accommodate variances
by altering project, schedule, or scope.
Tto control and manage a project effectively, the
RPM must develop strong leadership, com-
munication, and coordination skills. The RPM
must direct EPA contractors in the technical and
administrative aspects of the remedial response.
For example, the RPM must ensure that environ-
mental regulations and policies affecting a par-
ticular site are understood by the contractor as well
as by other program participants.
To avoid project delays, the RPM must coor-
dinate project activities with programs, organiza-
tions, and individuals both internal and external to
EPA, including for example:
• State and local officials.
« The affected community.
• Programs providing services to the project
(e.g., analytical data reviews).
• Offices responsible for other environmental
laws (e.g., the Resource Conservation and
Recovery Act).
• Organizations external to EPA (e.g., ATSDR).
•*'
Finally, regular communication with fellow
RPMs and supervisors is an important activity.
These individuals can often suggest innovative
solutions to complex problems previously en-
countered at other sites.
For additional information on program manage-
ment concepts, the reader should consult the Su-
perfund Federal-lead Remedial Project Manage-
ment Handbook (OSWER Directive 9355.1-1), com-
monly referred to as the RPM Handbook. The RPM
Handbook also provides a list of project manage-
ment references.
Project Kickoff
After a month with the program you are feeling a
bit more knowledgeable. You have obtained valu-
able information about the Superfund program (see
Attachment B for an annotated bibliography) and
• Two unlined waste ponds on the site contain
unspecified waste materials.
• The site contains a 30-acre landfill.
• Volatile organic compounds (VOCs), probably
from the site, have been detected in local
drinking water wells.
Exhibit 2 is a map of the Acme site.
Exhibit 2
MAP OF ACME WASTE
DISPOSAL CO. SITE
Lazy Creek
Unnamed Creek
Access Road
ACME WASTE DISPOSAL SITE
:: :Unlined Waste Ponds
J.C. Michaels, a veteran RPM whom you have iden-
tified as a potential "mentor", suggests that you as-
sign a remedial response contractor to the project
as soon as possible. He explains that the contrac-
tor will provide valuable assistance in conducting
-------
Initial planning for the remedial response project.
J.C. also suggests that you schedule a project
kickoff meeting.
With a somewhat clearer picture of what needs
to be done, you contact the Regional Project Of-
ficer (RPO) responsible for the remedial contract
serving your Region. The RPO explains how to ob-
tain assistance from the remedial contractor. He
also supplies you with a copy of Work Assignment
Procedures for Remedial Contracts (OSWER
Directive 9242.3-3A).
EPA selects remedial response contractors for
their expertise in conducting hazardous waste site
engineering studies and design. The contractor is
responsible for planning and conducting the RI/FS
and is accountable to EPA for its contracted role.
As the RPM, you have other responsibilities.
You must oversee the remedial response, act on
EPA's behalf In the project, and direct the contrac-
tor to keep the project on course and within
schedule and budget. You monitor the
contractor's progress in achieving project mile-
stones and coordinate with the contractor to
develop preventive or corrective actions in order to
keep work on target as problems arise.
Your first step in getting the contractor underway
is to develop a Work Assignment Package, which
consists of:
• A Work Assignment Form
• An interim Statement of Work
• A complete Statement of Work for the total
work assignment, and
• A Procurement Request (PR) (EPA Form
1900-8)
You develop the Work Assignment Package by fol-
lowing an example package supplied by the RPO.
You coordinate with the RPO to ensure that the
package Is complete and accurate. You also verify
that sufficient funding is available on the Super-
fund Comprehensive Accomplishments Plan
(SCAP).*
* Tha SCAP is the official document from the Assistant Ad-
ministrator for the Office of Solid Waste and Emergency
Response (AA/OSWER) identifies funding needs for proposed
Suparfund activities. Activities must be on the approved SCAP
to receive funding. In this example, the Acme Site was on the
SCAP prior to the RPMs involvement.
After completing the Work Assignment Package,
you forward it to the RPO for approval. The RPO
transmits the completed package to the Contract-
ing Officer, with a copy for the Project Officer. The
Contracting Officer then issues a work assignment
to the contractor, who must prepare a Work Plan
Memorandum for your approval within 10 days.
This is a 5-10 page plan for the interim tasks to be
completed, the technical level-of-effort and
schedule, and the name of the proposed Site
Manager. In this case, interim tasks would include
a project kickoff meeting, an initial site visit, Rl
scoping, development of general response objec-
tives, site survey / topographic mapping, sub-
contracting, and preparation of a Site Management
Plan and a final Work Plan. The expenditure limit
indicated on the Work Assignment Form is based
on the tasks in the interim Statement of Work.
With these administrative tasks completed/.you
arrange a project kickoff meeting. This meeting will
provide an opportunity to introduce the key par-
ticipants for the project and define their various
roles and responsibilities. You invite the following
participants:
• Contractor's Site Manager
• State Project Officer
• EPA's OSC for the completed removal effort
• EPA's Regional enforcement program repre-
sentative
• EPA's Office of Regional Counsel (ORC) repre-
sentative
• EPA's Regional Superfund Community Rela-
tions Coordinator (RSCRC)
You prepare and distribute informational packages
and an agenda prior to the meeting to ensure that
all participants are prepared. You also speak with
all invited participants to confirm their receipt of the
information and agenda, and to identify specific
subjects that they should be prepared to discuss.
The meeting runs smoothly. You begin by intro-
ducing everyone and presenting a schedule for in-
itiating the project. The schedule includes an initial
site visit (for which the contractor is already
developing an interim Health and Safety Plan),
development of an overall Site Management Plan,
and development of the contractor Work Plan. The
Site Management Plan will serve as an in-house
planning tool that lays out a schedule of site ac-
tivities from start to finish—from field investigation
and alternatives analysis through implementation of
-------
the remedy and eventual O&M. The plan incor-
porates activities, schedules, and resources and is
used in managing site activities.
Next, you announce that you will establish a
Technical Advisory Committee (TAC) for the
Acme site. The TAC will be composed of the in-
dividuals present at the meeting, plus technical
specialists and other interested parties who will
meet at key points in the remedial process to
review and discuss site issues and progress, You
welcome suggestions for other TAC members from
the group.
As the meeting proceeds, each participant offers
his or her thoughts on the project:
• The OSC describes removal actions conducted
at the Acme site and supplies you with copies
of important documents from the site file, in-
cluding the final Removal Summary Report
prepared by the TAT contractor.
• The RSCRC provides a brief history of com-
munity relations activities conducted during the
removal action and identifies any significant
community concerns associated with the site.
A site-specific Community Relations Plan
(CRP) was developed, as the removal lasted
more than 120 days. Also, during the removal
action an information repository was estab-
lished at the local library and will continue to
serve as a repository for the Administrative
Record for the Acme site*. The RSCRC sug-
gests that it would be wise to have a meeting
with community leaders and the local press
before the initial site visit is conducted. At this
meeting, the RPM can be introduced to com-
munity leaders and can discuss the initiation of
remedial activities at the site. The RSCRC
notes that communities are sometimes con-
fused when the remedial process begins,
believing that EPA's prior removal action was
intended to eliminate all problems associated
* The Administrative Record contains all information upon
which EPA bases the selection of a remedial response
(OSWER Directive 9833.3 Administrative Records for Decisions
on Selection of CERCLA Response Actions). The record must
be availiable to the public at or near the facility, so that the
community can participate in its development and have ac-
cess to important information. Additionally, a duplicate ad-
ministratiive record must be maintained at EPA's Regional
office.
with the site. Also, communities frequently do
not recognize the extensive study that is re-
quired before actual cleanup work begins.
• The Regional enforcement program and ORC
representatives discuss the enforcement status
of the site. Acme Waste Disposal Co/declared
bankruptcy 5 years ago; however, EPA is pur-
suing enforcement actions against other poten-
tially responsible parties (PRPs) who allegedly
wastes to Acme for disposal. These parties
have declined to perform the RI/FS. The cur-
rent enforcement strategy, therefore, is to
negotiate an agreement with PRPs to conduct
the RD/RA. If such an agreement cannot be
achieved within the mandated period of time**,
EPA will proceed with the cleanup and attempt
to recover costs after completion.
• The State Project Officer expresses the State's
willingness to cooperate in the cleanup effort
and desire to participate in technical meetings,
technical document reviews, and remedy
selection. Because they have been involved
with the site since it was identified 2 years ago,
the State adds a historical perspective to the
project. The State Project Officer notes that
the Intergovernmental Review has taken
place and that the State is satisfied with EPA's
responses to their concerns. The State also is
in the process of identifying any contaminant-
or location-specific State ARARs which may
apply to the Acme site. In addition, the State
Project Officer indicates that the State will be
submitting an application to amend its current
Multi-Site Cooperative Agreement with EPA
in order to receive funds for its management
assistance activities (e.g., meeting attendance,
document reviews) for the Acme site.
Your planning paid off. Not only was the meeting
informative to participants and well organized, but
you have time at the end of the day to meet with
J.C. Michaels and Art Becket, the contractor's Site
Manager. The three of you discuss the more tech-
nical aspects of the site and the scope of the initial
tasks of the phased Ri/FS.
** PRPs have 60 days to respond to EPA's enforcement
notice. If EPA receives a "good faith" proposal from the PRPs,
the negotiations window may be extended up to 120 days
from the date they receive the notice receipt.
-------
Phased Rl/FS
A phased Rl/FS approach uses the close inter-
dependecy of the Rl and FS activities to make the
remedial process more efficient. In this approach,
RPMs and contractors identify potential remedial
approaches and technologies prior to developing
sampling strategies so that the Rl can focus specifi-
cally on the data needs of the FS.
J.C. explains that previous RIs and FSs were
planned as two distinct steps with only one major
sampling period. During the Rl, EPA contractors
would analyze numerous soil, air, and water
samples. However, the data did not always allow
for thorough evaluation and development of
remedial alternatives during the FS. In such cases,
additional, unscheduled sampling was necessary,
requiring added time and expense.
By conducting the Rl/FS in phases, EPA now in-
corporates schedule- and activity-related decision
points into the Rl/FS process. This allows future ef-
forts to be redirected, rescheduled and/or re-
scoped, as necessary, in response to important
new information. During the phased Rl/FS, data
quality objectives (DQOs) are established prior to
sampling and analysis, sampling episodes are rela-
tively small In scope, and field screening techni-
ques are used to limit the number of analyses.
Mobile laboratories are commonly used for quick
analyses. In addition, treatability data are often col-
lected expressly for assessing the feasibility of an
alternative. Each phase may take only 2 or 3
months. The types of decisions that must be made
at the end of each phase include:
* Is the Rl meeting the data requirements of the
FS? If not, how will the Rl be redirected to
provide the data?
• Can the scope and/or schedule of the Rl be
reduced and still achieve the technical objec-
tives of the Rl/FS?
• Have sufficient types and amounts of validated
data been generated to terminate the Rl and
still complete the FS?
• Have the nature and extent of contamination
been adequately defined?
The phased approach allows the RPM to exert
more control over the project. In a phased Rl/FS,
funds are approved incrementally (i.e., through the
expenditure limit on the Work Assignment Form) to
correspond with resource needs for each phase of
the project. Because the decision points are in-
tegrated into the planning for the phased ap-
proach, the budget and schedule for the total Rl/FS
are likely to change. The phased Rl/FS approach
should lead to savings in both time and money.
Initial Site Visit and Site Planning
The initial site visit will provide a good oppor-
tunity to observe the integrity of the waste pond
berms that were stabilized during the removal ac-
tion. The contractor's Health and Safety Officer in-
forms you that protective boots are the only
precautionary measure necessary for this initial site
visit assuming you remain at least 15 feet from the
waste ponds. If you want to inspect the ponds
more closely, a self-contained breathing apparatus
is required.
The local residents should not be surprised to
see you at the site. You and Art met with com-
munity leaders last week, and the local newspaper
ran an article describing EPA's field investigation
plans.
The first stop on your site tour is the waste
ponds. The berms seem to be holding up well.
There are no signs of breaches or erosion. The
pond levels, however, are quite elevated from the
recent rains.
At the next stop, where the unnamed creek bor-
ders the site on the west, you make a new and im-
portant observation. There are stained strata and
stressed vegetation in an area along the embank-
ment providing evidence of intermittent seepage of
contaminated leachate. Art proposes taking
several grab samples along the bank and analyzing
them for priority pollutants. Quick turnaround
analyses will be needed to allow project scoping
activities to proceed on schedule. Depending on
the results, another removal action may be war-
ranted to provide short-term control of surface-
water contamination.
You move on to the designated landfill area.
Using site maps, you identify where the ERGS con-
tractor removed the drums and the visibly con-
taminated soils. Information from site files indi-
cates that other portions of the landfill received
only municipal wastes.
This initial site visit was useful. You and Art are
now more familiar with the site layout and with
potential problem areas. You can now prepare a
-------
more realistic Site Management Plan. The first step
in developing this plan is defining project objec-
tives. The long-term objective, of course, is clean-
ing up the site. The shorter-term objectives are to:
• Control on-going contamination of the
creek
• Define the extent of ground-water
contamination
« Define the source of the ground-water
contamination
• Assess risk to human health and the
environment
• Evaluate alternatives to remedy site
problems
To assist in planning response actions, you and Art
divide the site cleanup into conceptual "operable
units." Operable units help you think of the overall
cleanup as discrete efforts that will be undertaken
to decrease a release, threat of release, or pathway
of exposure. You envision two initial operable
units:
• Operable Unit 1 — Evaluate source control
measures by characterizing the pond wastes
and assessing various options for removing the
probable source of ground-water and surface-
water contamination.
• Operable Unit 2—Characterize ground-water
contamination and evaluate remedial alterna-
tives.
Work can proceed on both operable units concur-
rently.
Based on progress in conceptualizing your ap-
proach to needs at the site, you develop an overall
Site Management Plan (Exhibit 3), keeping it
general, in order to have the larger picture in mind.
As work progresses and more information be-
comes available, you can update and further
develop the plan. For example, results from initial
field investigations may indicate the need for a
removal action to supply affected residents with a
permanent uncontaminated drinking water source.
Also, short-term relief may need to be provided for
the apparent periodic contamination of the un-
named creek from seepage observed in the initial
site visit.
Technical Advisory Committee
You're now a month into the project, and it's
time for the first meeting of the TAG. You never
realized how difficult it could be to coordinate
everyone's schedule in addition to your own. You
did not anticipate being out of the office for 3 days
to attend contract administration training, but a slot
opened up and your Section Chief selected you to
attend. The training was well-timed for your new
responsibilities. It gave you a good understanding
of the contracting process and your critical role in
contract administration, particularly your authority
in obligating government resources. However, it
also made preparation for the first TAG meeting a
little hectic.
The TAG for the Acme site consists of a core
.group of individuals that includes your Section
Chief, the contractor's Site Manager, the enforce-
ment program representative, the RSCRC, the
State Project Officer and yourself. The TAG may
be supplemented by various specialists and other
interested parties whose time and extent of par-
ticipation will depend on the particular stage of the
project and the specific technical expertise re-
quired. Present at this first meeting are the core
group plus the Regional Quality Assurance Officer
(QAO) from the Environmental Services Division
(ESD), a U.S. Geological Survey (USGS) repre-
sentative, and a ground-water specialist from the
Region's Water Division. Also on the TAG is a
private consultant, hired by the community under
an EPA Technical Assistance Grant, who will act as
a spokesman for the community and report back
on project issues. Invited, but not able to attend
the first TAG meeting, were representatives from
ATSDR and the Corps. ATSDR did indicate in a let-
ter, however, that the data from the site inspection
would be sufficient to develop a preliminary health
assessment. ATSDR anticipates no special data re-
quirements beyond those normally generated
during an Rl. In order to do the final assessment,
however, ATSDR will need the Rl reports as they
become available.
Your Section Chief begins the meeting by
reiterating EPA's commitment to achieving site
cleanup. She is encouraged to see the appropriate
involvement of other programs both inside and out-
side EPA.
You describe your site visit and your plan to
divide the site into two operable units: source con-
trol measures aimed at the on-site waste ponds
-------
Exhibit 3
SITE MANAGEMENT PLAN FOR ACME WASTE DISPOSAL CO. SITE
Project Year
Months
Activity
Operable units 1 & 2:
Source Control;
GW Remediation
Pre-RI/FS Planning
RI/FS
ROD
Remedial Design
Remedial Action
O&M
1
f ? ?
-'hs
^ISMonths
2
f f ?
^•n
3 Months
^
3
? f ?
l^onths
^^^^^^^^^^^^^^H
•i
4
• ? f ?
•iiiliiiiiJiciZ::
5
? f ?
HI
? Months ^^
Legend
GW
Rt/FS
ROD
O&M
Ground Water
Remedial Investigation / Feasibility Study
Record Of Decision
Operation and Maintenance
and ground-water activities aimed at evaluating
and, if necessary, cleaning up the contaminated
aquifer.
You also recommend an Expedited Response
Action (ERA) to stop the threat of surface-water
contamination from the seepage area observed at
the Initial site visit. The grab samples taken at the
unnamed creek embankment show elevated levels
of heavy metals, including chromium, and other
priority pollutants, such as vinyl chloride. You ex-
plain that the ERA should focus on preventing
seepage from flowing into the unnamed creek and
suggest that the 12 affected residents be supplied
with a permanent source of drinking water.
To prevent further contamination of the creek,
the contractor's Site Manager suggests that the
flow be intercepted and diverted away from the
creek into a holding area. The collected leachate
could then be treated on-site and discharged to the
creek. The batch treatment facility also can be
used for future ground-water treatability studies.
Your Section Chief notes that permits are not re-
quired for Superfund response activities involving
on-site actions, however, the substantive require-
ments of a National Pollution Discharge Elimination
System (NPDES) permit should be met.
The ERA also will address the drinking water
problem of the 12 affected residents. These
residences, currently using bottled water, will be
permanently connected to the town's water dis-
tribution system which is uncontaminated. You will
10
-------
need to meet with the RSCRC and the contractor
to discuss the technical, budget, and scheduling is-
sues associated with this operation, including com-
munity relations activities.
The on-site waste ponds also were assessed for
inclusion in the ERA. However, lack of an im-
mediate threat and statutory limits of $2 million and
1 year timeframe precluded pond cleanup as an
ERA. Early estimates for the pond cleanup far ex-
ceeded the $2 million statutory limit. Thus, the
ponds will be addressed as an operable unit for
source control.
You explain that in order, to initiate an ERA, a
threat or potential threat to the public or the en-
vironment must exist. In fact, an ERA is officially
a removal action and therefore must comply with
the regulations, procedures, and policies of the
removal program. One major distinction from a
removal action though, is that EPA's remedial
program and remedial contractors carry out the
ERA. You and Art believe that the contaminant
levels in the seepage, and the potential for con-
taminants to migrate as a result of rainfall, con-
stitute the degree of threat required for an ERA.
The degree of threat is not so significant, however,
to warrant a time-critical removal, which would be
conducted by a removal contractor.
The ERA plan will begin with an Engineering
Evaluation / Cost Analysis (EE/CA), which is
similar to a feasibility study although smaller in
scope. The EE/CA must consider all Federal and
State ARARs and should stress the use of per-
manent solutions and alternative treatment
technologies to the maximum extent prac-
ticable. In addition, the EE/CA must meet National
Environmental Policy Act (NEPA) equivalency and,
therefore, must undergo a public comment period
and include a responsiveness summary. Like a
removal, the EPA Regional Administrator must offi-
cially approve an Action Memorandum for the ERA.
After formal presentations at the TAG meeting,
you open the floor to discussion. Everyone agrees
that your plans seem reasonable. The USGS rep-
resentative indicates that the area had been sur-
veyed recently and that he would gather and pass
along this data. The hydrogeologist from the Water
Division notes that the site overlays an aquifer cur-
rently used for drinking water, and thus requires
protection under the Safe Drinking Water Act. The
State Project Officer also notes that State drinking
water standards are more stringent than Federal
standards for certain contaminants. Both the
Federal and State requirements will need to be ap-
propriately considered in planning and conducting
the remedial response.
Data quality is a major concern in conducting
remedial activities, and in discussion of this impor-
tant subject the Regional QAO provides some valu-
able guidance on developing DQOs for the
remedial response project. He explains that to en-
sure that data generated during the remedial
response at the Acme site are adequate to support
EPA's decisions, the project planning process must
clearly define the objective and the method by
which decisions will be made. This is ac-
complished through the development of site-
specific DQOs, which are qualitative and quantita-
tive statements made to ensure that data of known
quality are obtained.
The QAO goes on to explain the three-stage
process of developing DQOs:
• Identify decision types
• Identify data users and needs
• Design a data collection program
This is a lot to absorb at one meeting. Fortunately,
Data Quality Objectives for Remedial Response
Activities, Volumes I and II (OSWER Directive
9355.0-7B) are available for you to study, and the
QAO will provide further consultation as needed.
Generally, the first TAG meeting was very infor-
mative. The next time the TAG gets together it will
discuss the contractor's draft Work Plan, which
should be available for review in about 6 weeks. In
addition to drafting the Work Plan, the contractor
will also be working on the EE/CA for the ERA and
a CRP update. You amend the interim scope of
work activities to include preparation of the EE/CA.
This is done via approval of an interim amendment
on the Work Assignment Form.
Site Management Plan
You've just reviewed the contractor's detailed
Site Management Plan outlining the many tasks in-
volved in cleaning up a hazardous waste site; it
looks pretty good. Of course, most of the detail is
devoted to the immediate tasks, the interim RI/FS
tasks and the ERA involving leachate collection /
treatment and permanent water supply connection.
Since you are new to the program, you decide to
11
-------
confer with senior RPM J.C. Michaels again. He
suggests that you look at some of his old files to
compare schedules and unit costs for various
tasks. You also want to meet with Art Beckett to
discuss the Site Management Plan before the con-
tractor drafts the final Work Plan.
In the Site Management Plan, there is a potential
problem with the schedule. It calls for the ERA to
be implemented toward the end of winter. This
may be a problem if it includes construction ac-
tivities that cannot be performed under conditions
of cold temperatures and possible snow. You and
Art must consider weather impacts on the schedule
and develop appropriate anticipatory actions and
contingency plans.
The Superfund program will be conducting
studies at many other sites this spring. For
Federal-lead sites, samples are usually sent to the
Contract Laboratory Program (CLP) for analyses.
This may strain the CLP's capacity in the spring. In
order to expect reasonable turnaround time on
analyses, you should plan to avoid the seasonal
log jam. The Regional Sample Control Center
Coordinator for the CLP offers some advice:
• Schedule early if you plan to use the CLP
during the busy season
• Limit analyses to those truly needed to meet Rl
objectives
• Use field screening to limit sample numbers
• Use unvalidated data, with caution, to continue
project work and adjust, as necessary, when
validation is complete
These are all good ideas assuming that they fit in
with your project objectives and DQOs.
After discussing the Site Management Plan, Art
describes the automated system recently brought
on-line in the Region to monitor and control site
progress. With the software available (both the
Region and the contractor have copies), you can
enter site data (task, schedule, budget, and
responsibility) and generate critical path analyses,
progress reports, resource requirements analyses,
and other project management functions. This
computer program helps monitor site progress and
anticipate future events such as schedule slippages
and cost overruns. The data to be entered into the
program can be taken from the contractor's
monthly progress reports and other communica-
tions, (Exhibit 4 shows an example of the
software's output.) You recognize, of course, that
you cannot just sit behind a computer terminal and
make things happen. This automated system,
however, can prove to be an excellent tool, if used
effectively.
Work Plan Review
The contractor has just submitted the draft Work
Plan, the Sampling and Analysis Plan, and an up-
dated CRP for the initial phases of the RI/FS. You
had seen portions of these plans earlier. Now your
job is to review the plans for approval. You may
use specialists to help with the reviews, but you
must coordinate their involvement to prevent
schedule slippages. These specialists may include
the Regional QAO and other RPMs'with particular
expertise in chemistry, biology, toxicology, or
hydrogeology. The TAG members: also will be
reviewing these plans. In addition, you may want
to consider asking J.C. Michaels to briefly look at
the plans. You've allowed 3 weeks for review, fol-
lowed by a meeting to discuss any comments.
J.C. suggests that you involve the Corps now,
since EPA has selected them to be the lead for
design and construction activities. This is handled
through a site-specific Interagency Agreement
(IAG) for technical assistance. You will need to
prepare the IAG paperwork and obtain approvals in
the Region.
Meanwhile, the contractor is well into the EE/CA
portion of the ERA. A problem with the diversion
system requires additional grading to stabilize the
slope. This will add $50,000, bringing the ERA cost
to $450,000. The total cost for the previous
removal action plus the ERA is below the $2 million
statutory ceiling for removal actions. The response
time, however, will likely exceed 1 year, which will
require approval of an exemption request by the
Regional Administrator.
You confer with another RPM experienced in
civil engineering before approving the additional
work. You also check the SCAP to ensure that suf-
ficient funds are available. The diversion system is
designed to collect and treat an estimated 95 per-
cent of the leachate discharging to the creek. With
the EE/CA complete and the public comment
period underway, you develop an Action Memoran-
dum for the Regional Administrator to sign. Once
this memo is signed, you can issue funds and a
work assignment amendment to instruct the con-
tractor to prepare plans and engineering specifica-
12
-------
Exhibit 4
GENERIC SCHEDULE FOR FEDERAL-LEAD RI/FS
Year! Year 2 Years
• - . . Jul Sep Nov Jan Mar May Jul Sep Nov Jan Mar May Jul
Status .
Work Planning / Mobilization C
WP Memo Submitted P
Draft WP CRP & Supp. Plans Submit. P
WP, CRP & Supp. Plan Review
Final Plans Submitted P
WP, CRP & Supp. Plan Approval C
Public Info Meeting
Field Investigation C
Sample Analysis / Validation PC
Analysis & Rl Report PC
Rl Report Submitted C
Tech Assist. Funds to Corps C
Rl Report Review C
Analysis & FS Report C
Draft FS Submitted p
FS Review
Prepare ROD C
Final FS Submitted p
FS to Public C
Public Comment Period C
Pre-design Activities
PRP Negotiations C
Design Assist. Funds to Corps P
A/E Selection for RD (Corps) C
Public Meeting p
Prepare IAG for RD
Prep. Responsiveness Summary C
Draft ROD Circ. for Comment PC
ROD Briefing Period C
State Concurrence p
ROD Signature C
nn
M
M
M
M
M
M
M
Mi
M
D - Done
C - Critical
R - Resource Conflicts
P — Partial Dependency
Task Um I Slack Time
Started Task kiMIHH Resource Delay
M - Milestone - Conflict
Scale: Each character equals 1 week
TIME LINE Gantt Chart Report
This Is a generic schedule for a Federal-lead RI/FS. Specific RtfFSs may have different tasks and schedules.
13
-------
tions for the ERA. The contractor subsequently will
select a construction sub-contractor and manage
construction of the ERA.
Rl Phase I
The RI/FS Work Plan and the Sampling and
Analysis Plan for the first phase of the RI/FS are on
target Only a few minor adjustments are neces-
sary. You also question some of the level-of-effort
allocations. The contractor makes the necessary
revisions and resubrnits the Work Plan 2 weeks
later for approval. You then approve the Work Plan
and Increase the expenditure limit to authorize the
Rl Phase I.
The first phase of sampling and analysis is a
screening effort aimed at defining where further
work should be directed. In this case, you want to
determine the nature and extent of ground-water
contamination and identify the constituents in the
two on-site ponds. With this information, you can
establish Initial cleanup goals, characterize con-
centration ranges and profiles, and determine
waste types, mixtures, and volumes. The data also
will be used to analyze contaminant transport and
determine danger to human and environmental
receptors. During this phase, you will evaluate and
refine DQOs to ensure meeting the needs for en-
vironmental, treatability, and health effects data.
Identifying the various constituents in the ponds
will be a tricky job since apparently several discrete
layers of materials are present. The job will require
sophisticated sampling. You think it would be a
good idea to arrange for J.C. Michaels, a senior
RPM, to accompany you to observe the first
several days of sampling.
Only limited hydrogeologic sampling is required
since Rl scoping revealed that a few years earlier
the USGS had collected data on ground water flow
and subsurface strata in the area. Based on your
review of USGS data, ground water appears to flow
In a northwesterly direction under the site. The first
monitoring phase calls for six wells-four along the
site's northwestern boundary and two upgradient
from the site. The 12 contaminated local wells,
which are no longer used for drinking water, will
also be sampled. The need for further wells will be
determined from initial sampling results. The con-
tractor also plans to use a volatile organics
analyzer to assess the presence of VOCs in the un-
saturated zone as an indicator of potential con-
tamination in the ground water below.
Initial field samples will be analyzed in the
contractor's mobile laboratory. Subsequent
samples will be sent to a CLP laboratory for or-
ganic and inorganic analyses. Because of prior
scheduling of the CLP analyses with the Regional
Sample Control Center Coordinator, you should
receive validated data 6 weeks after submitting
samples.
The field investigation seems to be off to a good
start. However, just as you are congratulating
yourself, Art Beckett, the contractor's Site
Manager, informs you that ground-water sampling
will be delayed a week or two. Evidently, the sub-
contractor hired to drill the monitoring wells had
limited hazardous waste experience. The individual
scheduled to operate the drilling rig would not take
seriously the clothing requirements in the Health
and Safety Plan and refused to wear proper safety
gear. It may take a week to mobilize a qualified
drilling team. ;
You wish you had taken a closer look at the
subcontractor's qualifications. However, it is the
contractor's job to screen qualifications of sub-
contractors before assigning tasks to them. You
note this oversight in your logbook. It will be in-
cluded in your Performance Evaluation Report of
the contractor during the next trimester Award Fee
Determination, in accordance with the Regional
Award Fee procedures.
Your immediate concern though, is how the
delay will affect your scheduled CLP analyses. You
inform the Regional Sample Control Center Coor-
dinator of the problem. He no longer can guaran-
tee a 6-week turn-around for analysis and valida-
tion. You hope your earlier discussion and well-in-
tentioned efforts to plan and coordinate with the
CLP through the Sample Control Center will have a
positive influence on turn around time.
If not, you do. have a contingency plan. You and
Art had previously discussed the option of using
data produced by the laboratory but not validated
by the ESD. Another option is to have your con-
tractor prepare for the next phase Of sampling (if
needed) while the data is being validated.
Previously you thought the benefits of saving a few
weeks would not outweigh the risks of proceeding
with unvalidated data. Now, however, you con-
sider the risk worth taking to get back on schedule.
14
-------
FS Phases I and II
While the Rl activities are underway, you begin
the process of developing alternatives for cleaning
up the site. In this first phase of the FS, you want
to identify potential remedial technologies,
prescreen them for application at the site, and as-
semble technology and/or disposal combinations
into alternatives.
The contractor has been doing some preliminary
work on potential remedies. You ask Art to
prepare a preliminary list with general descriptions.
You schedule a meeting with the TAG to discuss
possible alternatives, and to identify their preferen-
ces and concerns.
The TAG meeting is being held at the Regional
Office. In attendance are the Regional Coordinator
from EPA Headquarters, the RSCRC, a Regional
representative from the Resource Conservation
and Recovery Act (RCRA) program, the State
Project Officer, the Corps' representative, the
ATSDR Regional liaison, and the contractor.
You begin by describing the types of alternatives
being considered. At a minimum, alternatives
should range from remedies that eliminate the
need for long-term management (including
monitoring) at the site to those that involve treat-
ment and that reduce toxicity, mobility, or volume
of waste as their principal element. Although alter-
natives may involve different technologies (that will
most often address toxicity and mobility) for dif-
ferent types of waste, they will vary mainly in the
degree to which they rely on long-term manage-
ment of treatment residuals or low-concentration
wastes. In addition to the range of treatment alter-
natives, containment options involving little or no
treatment and a no-action alternative should also
be developed.
The Corps' representative notes his concern
about using remedies involving alternative tech-
nologies such as chemical and/or physical fixation
of pond wastes. Preliminary evidence suggests
that these are not feasible alternatives for the Acme
site. You indicate that treatability testing will be
conducted to fully assess these alternatives.
The State Project Officer is also concerned that
the selected remedy attains State drinking water
standards for lead and chromium. You explain that
under CERLCA, EPA must meet State ARARs, or
obtain a waiver. You stress the importance of
achieving both the drinking water standards and
other standards related to health and the environ-
ment for additional media such as soil and air. In
addition, you indicate that the contractor will be as-
sessing any action-specific ARARs for the remedies
under consideration. These include any require-
ments stemming from the remedial actions being
considered (e.g., thermal destruction and removal
efficiencies or land ban restrictions under the
RCRA Hazardous and Solid Waste Amendments
[HSWA]).
The RSCRC reports on the community relations
activities to date and the public's attitude toward
the site cleanup. Generally, the citizens seem
satisfied with site progress. They are, of course,
concerned that the contamination of ground water
and Lazy Creek be stopped. Several citizens have
expressed their appreciation for receiving routine
updates on site progress. Typically, these updates
include site fact sheets, community interviews,
public meetings, and telephone communication
with key community representatives.
There has been some negative public response
as well. The RSCRC reports that several citizens
have called her complaining of project delays,
especially in obtaining hook-ups to town water.
The RSCRC also learned that the delivery of the
bottled water to these twelve families has been late
on several occasions. The RSCRC believes that
resolution of that problem will reassure citizens of
EPA's concern for their health.
You instruct the contractor to inquire about
water deliveries. Upon verification of the delays,
the RSCRC will telephone the affected residents to
acknowledge the problem and explain the correc-
tive actions that will be taken. You note these
problems in your logbook for future reference
when evaluating contractor performance.
At the conclusion of the TAG meeting, you out-
line the next steps for completing the RI/FS. Prior
to releasing the FS Report for public comment, you
plan to reconvene the TAG to receive internal com-
ments on the report and to plan for the selection of
remedy process. This process culminates in the
development and approval of the ROD which forms
the basis for future administrative and legal ac-
tivities.
15
-------
With the meeting concluded, you instruct the
contractor to continue work on developing and
screening alternatives and agree to a tentative
schedule for drafting the FS Report.
Ri Phase II
You and Art meet to discuss the second phase
of the RI. The first phase indicated ground-water
contamination from the site and a slow rate of con-
taminant migration. However, the extent of the
plume and specific source(s) of contamination can-
not be defined sufficiently from the data. The
ponds are a likely source since some of the same
hazardous substances were found in both the
ground water and the ponds. Based on results
from the first phase of sampling, however, it could
not be determined if materials buried in the landfill
also were contributing to the ground-water con-
tamination. In Phase II, your goal is to develop
data that Is sufficient to clearly define sources and
to make a remedy decision.
Sampling of the ponds from the first phase of the
RI revealed four distinct layers:
• A bottom layer consisting of a highly viscous
sludge containing heavy metals, including lead
and chromium, paint sludges, long-chain
hydrocarbons, and an assortment of other or-
ganics
• A second layer of organics with high specific
gravities
• A third layer of organics soluble in water
• A top layer of low specific gravity organics in-
soluble in water
During the first RI phase, you identified the
materials in the ponds, but gathered little informa-
tion on the best way to handle them. A couple of
remedial alternatives under consideration are in-
situ chemical fixation and thermal destruction.
Characteristics such as heats of combustion, vapor
pressure versus temperature profiles, and vis-
cosities need to be defined in order to evaluate
various options for treating and/or disposing of
these wastes. The CLP does not routinely conduct
such physical analyses, thus you will need to make
special arrangements for these analytical services.
You recommend that, during RI Phase II, the
contractor initiate bench-scale tests to determine
the effectiveness of these alternatives and to
provide cost estimates. This information will
enable you and the contractor to evaluate in detail
the various treatment and/or disposal options. The
results also can be used to develop performance
standards to be included in the jlnvitation for Bid
(IFB) package for remedial action. This second
phase of sampling also should determine the full
extent of the contaminant plume and whether the
landfill area is a contributing source of ground-
water contamination.
You approve the second phase of the RI by issu-
ing a Technical Direction Memorandum that in-
creases the expenditure limit for the work assign-
ment and approves the more detailed scope of ac-
tivities. You also decide to have the contractor up-
date the Work Plan at this time and develop a fact
sheet to inform the local community of progress
achieved and future plans.
You revise your Site Management Plan accord-
ingly and schedule a meeting with your Section
Chief to brief her on the project and to obtain her
input. As a courtesy and to continue good com-
munications, you also prepare a short report to in-
form key parties (State, the JGorps, ATSDR,
RSCRC, and Regional Coordinator) of site
progress and the planned course of action.
FS Phase III
The second phase of sampling was completed
and analytical results validated. It was clear that
the ponds were the major source \ of ground-water
contamination in the area. The contaminants ap-
parently are leaching from under and around the
unlined waste ponds, entering the aquifer, and
migrating under the landfill and! beyond to the
northwest. With this information irj hand, you con-
fer with the contractor and decide to discontinue
further sampling.
During the third phase of the FS, the contractor
evaluates in further detail the alternatives that
passed through the initial screening in FS Phases I
and II. The alternatives are analyzed against a
range of factors and a comparative analysis is con-
ducted. The major factors considered are effec-
tiveness, implementability, and cost.
Under effectiveness, the alternatives must be
evaluated for their protectiveness of human health
and the environment (compliance with ARARs).
Preference also is given to alternatives that per-
manently and significantly reduce the toxicity,
mobility, or volume of contaminants. When as.-
16
-------
sessing the implementability of alternatives, EPA
must consider the technical feasibility, administra-
tive feasibility, and availability of the various
remedies. Finally, EPA must evaluate the alterna-
tives in terms of short-term (capital) and long-term
(operation and maintenance) costs. These are all
key factors in the final selection of remedy.
As RPM, this is also an appropriate time for you
to submit a ROD delegation request and briefing
package to EPA Headquarters for the Acme site.
The briefing package describes the site, and iden-
tifies significant issues, waivers, and Regional
recommendations. The ROD delegation transfers
remedy selection authority from the AA/OSWER to
the Regional Administrator.
Generally, these next few months are going to
be busy. Among the activities upcoming are:
• Development of the draft FS report and
Proposed Plan
• Public comment period on the FS, including
a public meeting
• Intergovernmental review of the proposed ac-
tion
Enforcement negotiations with PRPs
Updating the Administrative Record
ROD preparation, briefing to the RA, and ROD
signature
IAG with the Corps for remedial design
Pre-selection of design contractor by the
Corps
• Transfer of information between the contractor
and the Corps
• RI/FS closeout
It will take all of your planning, communication, and
coordination skills to keep things on track.
However, if you can overlap these various ac-
tivities, you can save 3 to 6 months.
EPA's Regional enforcement program will be
negotiating with PRPs to reach an agreement to
conduct the RD/RA. EPA has set a 60- to 120-day
enforcement window, which usually begins no later
than with release of the FS Report. If there is no
agreement with PRPs by the end of that period,
cleanup will proceed as a Fund-lead project, and
the enforcement program will pursue cost recovery
actions with the PRPs at the end of the cleanup.
TAG Meeting and Remedy Selection
Within a matter of weeks you receive a draft FS
Report from the contractor. You had seen a
preliminary draft about a month earlier so there are
no surprises. You distribute this version to the TAG
for review. After a 3-week review period, the TAG
meets to discuss the draft FS Report and outline
the next steps and responsibilities in the remedial
process. In general, the committee has no major
problems with the report. The contractor had been
responsive to everyone's concerns. You note this
in your logbook as a reminder for when it is time to
evaluate the contractor's performance.
The report outlines five basic alternatives, some
with various options that would alter the degree of
cleanup. The options address both operable units,
source control, and ground-water cleanup.
1) In-situ fixation of pond wastes, construction of a
slurry wall around the ponds, construction of an
impermeable clay cap over the site, and off-site
monitoring.
2) Thermal destruction of pond wastes and
underlying soils, land disposal of treatment
residues, and off-site monitoring.
3) Same as No. 1, plus on-site pumping and
reatment of ground water.
4) Same as No. 2, plus' on-site pumping and
reatment of ground water.
5) No action alternative.
The TAG is leaning towards alternative No. 4,
believing that in-situ fixation is too risky and would
not receive public support. Also, alternative No. 4
includes thermal destruction of portions of the
pond wastes, which is consistent with EPA's policy
of using alternative treatment technologies and
selecting permanent remedies to the maximum ex-
tent practicable. Thermal destruction residues and
nonburnable wastes will be landfilled at an ap-
proved facility as needed. The State Project Officer
also prefers alternative No. 4.
Originally, both you and Art thought it was un-
necessary to pump and treat ground water after
removing the source and minimizing the migration
routes. Initial modeling efforts indicated that
17
-------
natural dilution and other natural chemical and
biological processes would reduce contaminants
to acceptable levels beyond the site boundaries
once the major source of contamination was
removed. However, the time-frame in which
natural attenuation would occur is not acceptable
In terms of the immediate public health concerns.
The option of pumping and treating the ground
water will reduce contaminants to an acceptable
level In a reasonable period and will restore the
ground water to its original beneficial use as a
drinking water source, and help prevent further
contamination of adjacent surface waters. Ground-
water monitoring will also be initiated to track the
change in contaminant levels in response to pump-
Ing and treatment.
With the TAG in agreement, EPA can develop a
proposed plan for public comment. The proposed
plan Is a companion to the FS and the administra-
tive record. It describes the alternatives con-
sidered In the detailed evaluation. Most important-
ly It Identifies, describes, and explains the rationale
for selecting the preferred remedy. EPA also must
publish a notice and brief analysis of the proposed
plan in a major local newspaper and make the plan
available to the public. You plan to enlist the sup-
port of the RSCRC and ask the contractor to assist
you in preparing these documents.
Public Comment Period
During the public comment period, a number of
activities must be accomplished, one of which in-
cludes drafting as much of the ROD as possible.
At this point, the ROD will include any background
information, RI/FS data, and a summary of
remedial alternatives considered. At the end of the
comment period, the RSCRC will work with you to
prepare the Responsiveness Summary, which
documents the public's substantive comments and
EPA's responses. You will have a better feel for
what this will entail following the public meeting
scheduled In 4 weeks.
To prepare for the public meeting, you meet with
the RSCRC to go over the meeting agenda. The
RSCRC will lead the meeting and discuss the Su-
perfund remedial response process in general
terms. She also will discuss community relations
activities that have occurred and how the public
contributes to EPA's remedy selection decision.
You will then discuss the technical points of the
project including the Rl, the ERA, and any sig-
nificant project delays / changes (why they were
necessary and how you corrected them). You will
devote most of your presentation to providing an
overview of the various alternatives considered,
highlighting the advantages and disadvantages of
each. Finally, you will discuss the preferred alter-
native and your reasons for choosing it. A week
before the meeting, you and the RSCRC plan to
rehearse your presentations to improve them and
learn of any problems in delivery.
The meeting will conclude with a question and
answer session, which the RSCRC will moderate.
To prepare for this and the press interviews that will
follow, you and the RSCRC try to anticipate ques-
tions that are likely to be asked.
[
Transition to Design
Since PRP negotiations do not seem to be going
well, you can issue a Phase I design work assign-
ment to the Corps to develop a1 short list of
qualified architectural / engineering (A/E) firms.
This could have been done earlier, however, since
the negotiating window with the PRPs was still
open and their intentions were not cigar, you chose
not to proceed at that time.
All of these activities should go smoothly be-
cause all parties were involved early ;in the process.
The Corps should have a good understanding of
the site and, therefore, should be able to develop
an appropriate short list of A/E firms. The State is
expected to concur in writing oh the remedy
selected since the State helped to develop the al-
ternatives and had the opportunity to voice its con-
cerns earlier.
ROD Approval
The ROD is now prepared and authority has
been delegated to the Region for its approval.
Now you must brief the Regional Administrator, to
obtain approval of the ROD. You're slightly nerv-
ous about this. Public speaking was never your
strong point; however, you did a very credible job
at the public meeting. This is also an excellent op-
portunity for you to demonstrate your abilities to
your supervisors. To prepare, you attend several
ROD briefings for other sites in the Region.
18
-------
Since the Regional Administrator will decide if an
appropriate remedy has been selected, he normal-
ly asks for a brief comparison of alternatives,
paying particular attention to community concerns
compliance with ARARs, and cost-effectiveness.
You also note that the Regional Administrator re-
quires that the ROD specify performance levels.
Performance levels provide a baseline for
demonstrating remedy effectiveness and com-
pliance with other environmental regulations. They
also provide criteria for future decisions regarding
deletion of sites from the NPL.
Your planning and preparation pay off again.
The ROD briefing goes extremely well. The
Regional Administrator has a few tough questions,
but you handle them well. The past four months
were certainly hectic, but you obtain the Regional
Administrator's signature on the ROD—a sig-
nificant achievement in the remedial process.
State Assurances
During all phases of the RD/RA, you must con-
tinue to coordinate with the State. Specifically, you
must negotiate a Superfund State Contract (SSC)
for the remedial action during RD and execute it
when the RD is completed. The SSC is a legally
binding document in which the State agrees to
provide:
• An off-site treatment / disposal facility, if neces-
sary
• A share of the costs for the response
• Post-remedial O&M
Since the selected remedy for the Acme site invol-
ves disposal of residues from the treated pond
wastes, you must ensure that the off-site facility
chosen complies with applicable RCRA regula-
tions. You consult EPA's policy and Procedures
for Planning and Implementing Off-Site Response
Actions (OSWER Directive 9330.2-1) and also meet
with Regional RCRA program personnel. Although
CERCLA requires that the State ensure the
availability of an off-site facility as needed, this is
normally done by the construction contractor
through the bidding process. During bidding the
contractor will identify and select such a facility
based on marketplace conditions and availability of
a facility in compliance with RCRA regulations.
Under CERCLA, the State must provide a per-
centage of the cleanup costs. In this case, since
the site was privately-owned at the time of disposal,
the State must contribute at least 10 percent of RA
costs. For a State-operated site, the State would
be responsible for at least 50 percent of both the
planning (i.e., RI/FS, RD) and the RA costs. In
either case, the State's cost share is not due until
the RA begins.
The State must make assurances to provide
O&M for the Acme site following the RA. O&M en-
sures continued functioning and effectiveness of
the RA. As the RA begins to wind down, you will
have to execute a Cooperative Agreement for
O&M, the mechanism for transferring Federal funds
to a State. For now, however, you need only the
State's assurance in the SSC.
The State also is responsible, to the extent of its
legal ability, for obtaining access to the site for the
RD/RA if necessary. This was not a problem for the
RI/FS, since the State condemned the property fol-
lowing Acme's bankruptcy. However, you should
consider any additional access rights needed for
off-site drilling. None are anticipated, but it would
be wise to check on this. Site access problems
have delayed many response actions at other sites.
Remedial Design
With the ROD signed, you should execute the
site-specific IAG with the Corps for design procure-
ment and contractor oversight to initiate design ac-
tivities. Although the Corps will be managing the
RD/RA for EPA, as EPA's representative you still
have oversight responsibility for the project. You,
therefore, must monitor project activities and
provide timely and meaningful input to the Corps.
You also will continue to be involved with com-
munity relations efforts, such as developing fact
sheets for key milestones of the RD/RA.
As outlined in the Superfund Remedial Design
and Remedial Action Guidance (OSWER Directive
9355.0-4A), several items require your attention
during RD. Once you have started the design, you
will be reviewing design plans and specifications at
various stages of development. Your primary
focus during these reviews is to ensure that the
plans and specifications are consistent with EPA
regulations, policies, and the approved ROD. You
will also review the design value engineering study,
if one is prepared for the site, for consistency with
the intent of the selected remedy. In value en-
gineering, plans and specifications are reviewed for
potential cost savings through the replacement or
modification of high-priced design items. For ex-
19
-------
ample, it may be possible to use on-site rather than
off-site materials as fill for the emptied ponds
without reducing the effectiveness of the remedy.
When cost estimates for construction are avail-
able, you should contact the enforcement repre-
sentative working on the cost recovery case
against the PRPs. EPA will need this information
when presenting their case to the Department of
Justice.
Remedial Action
Once the RD package has been completed and
approved by the Corps, and the EPA and the State
have concurred, you should execute the SSC with
the State. Also, you will need to prepare and ex-
ecute a site-specific IAG with the Corps to procure
a construction contractor. The Corps then issues
the bid package and invites contractors to bid for
the construction project. Again, although the
Corps has the lead for the RA, you must remain in-
volved to provide EPA oversight and guidance.
Your participation may include attending review
meetings, inspecting construction, and reviewing
progress reports.
As the RPM, you also may get involved with
these procurement / contractor issues:
• Bid protests, which are written complaints
filed by parties with a direct financial interest
that is affected by the Corps' procurement ac-
tion. Complaints typically concern the solicita-
tion or the actual award of contracts. The
Corps is responsible for handling bid protests.
Your main concern, however, is that any
protest be resolved quickly to avoid excessive
project delays.
* Change orders, which are written orders is-
sued by the Corps authorizing an addition to,
deletion from, or revision of a contract for
either engineering or construction services.
They are usually issued in response to a re-
quest from the contractor. Change orders may
be necessary during any phase of the remedial
response. However, they are most likely to be
needed during construction, when there is a
greater chance of encountering unforeseen
site conditions, changes in estimated quan-
tities, or other potential problems impacting
contractor performance. The Corps is respon-
sible for managing change order requests.
Each remedial project has a construction con-
tingency of 8 to 10 percent of total project
costs. The Corps has the authority to approve
any change order that totals up to 20 percent
of the project contingency fund. Any change
order exceeding 20 percent requires EPA/RPM
approval. The Corps may continue to approve
such change orders until 75 percent of the total
contingencies has been depleted. Thereafter,
EPA/RPM also must approve. In Addition, the
RPM must ensure that any needed revisions to
agreements with the State or modifications to
EPA management systems (e.g., SCAP) result-
ing from the change order are made. (State
cost share also applies to RA change orders
and claims.) Of course, if the change order
significantly modifies the scope of work, the
RPM must get involved with evaluating impacts
on the project.
• Claims, which are demands or written asser-
tions by a contractor seeking, as a matter of
right, changes to the contract which the Corps
has originally rejected through the change
order process. As with change orders, the
Corps has lead responsibility for managing the
claim.
Once the Corps completes the RA, they will con-
duct a final inspection and prepare a report certify-
ing completion of the RA. The Regional Ad-
ministrator then shall provide written notice to the
Corps of EPA's acceptance of the completed
project. You also must coordinate with EPA enfor-
cement staff in order to pass along final cost data
for the project and revised O&M estimates for cost
recovery purposes.
Operation and Maintenance
The Corps'/EPA's acceptance of the completed
RA indicates that the project has been built as
designed and is operating and functioning proper-
ly. This also is the point at which the State takes
over O&M responsibilities.
As the RPM, you must work with the State to
develop a Cooperative Agreement for that phase of
O&M involving EPA funds. EPA shares (90 or 50
percent) in that phase of response necessary to
ensure that the remedy is operational and function-
al for up to 1 year. After that, the State must as-
sume full responsibility for O&M under a Coopera-
tive Agreement with EPA. This agreement should
be in place when EPA and the State accept the
remedy as complete. Consult State Participation in
20
-------
the Superfund Program, Volume I (OSWER Direc-
tive 9375.1-4) for details on executing a Coopera-
tive Agreement. .
You will need to negotiate with the State to work
out the details for the transition from RA to O&M, in
particular, defining when RA ends and O&M
begins. This is important when the RA involves on-
site treatment such as the systems for pumping
and treating ground water at the Acme site. Under
GERCLA, up to 10 years of ground-water or sur-
face-water treatment may be considered part of the
RA.
Finally, as the RA nears completion, you must in-
itiate the NPL deletion process. Deletion signifies
that EPA has completed what is considered to be
appropriate and necessary actions at the site and
that the site no longer presents a threat to human
health and the environment. It is the culmination of
the remedial response. Detailed procedures for
deleting sites from the NPL are given in Guidance
on Deletion of Sites from the National Priorities List
(NPL) (OSWER Directive 9320.2-3).
A remedial project may take 4 to 6 years, or more,
and cost millions of dollars. The process involves
many participants representing a variety of inter-
ests. In addition, each site has unique characterise
tics, both technical and administrative.
As a new RPM 5 years ago, you had little or no
experience with planning, budgeting, and schedul-
ing projects of this magnitude. You were ap-
prehensive about public speaking. Now, you have
proven your abilities in all of these areas. New
RPMs are now approaching you for advice.
You have learned that a key element to being an
effective RPM is establishing clear and open com-
munications with program participants, particularly
with the public. By effectively using and coordinat-
ing available resources (contractors and technical
specialists) you were able to complete the remedial
project on time and under budget.
You recognize that the ability to anticipate and
respond to obstacles is another key factor in keep-
ing the project moving towards completion. You
anticipated and resolved such problems as poor
weather conditions, inexperienced well drillers, and
irate citizens. In addition, you have successfully
worked within a system of changing regulatory and
administrative requirements.
As a result of your successes, you have gained
valuable knowledge, experience, and confidence
that will help advance your career. The article in
the local newspaper complimenting EPA's efforts
at the Acme site certainly caught your Section
Chiefs eye. In fact, she has nominated you for a
cash award for outstanding achievement.
Taken as a whole, the RPM's job is varied and
challenging. It requires a unique blend of technical
and managerial skills, many of which can be
learned only on the job.
21 ,
-------
-------
Attachment A
RPM Training Courses
-------
-------
RPM TRAINING COURSES
The following training courses are available to EPA
RPMs:
CERCLA Orientation
OSC/RPM Basic Course
Personnel Protection and Safety
Remedial Investigation and Feasibility Study
Contracts Administration
Risk Assessment in Superfund
Basic Ground-Water Course
Hazardous Materials Cleanup Technologies
Corrective Actions for Containing and
Controlling Ground-Water Contamination
Community Relations in Superfund:
Concepts and Skills
Management of Construction in the Superfund
Program
CERCLA ORIENTATION
(3 Days)
This introductory course is designed to intro-
duce new employees to the Superfund Program.
Course presents an overview of the CERCLA and
RCRA legislation, the National Contingency Plan,
program implementation and policy implications,
community relations, and the removal, remedial,
enforcement and support programs. Includes
classroom lectures, group discussion, problem
solving, case studies, and student exercises. Par-
ticipants will be offered insights into the actual
"nuts and bolts" of these programs.
OSC/RPM BASIC COURSE
(41/2 Days)
This introductory course is designed to intro-
duce new OSCs or RPMs to their roles and respon-
sibilities and to provide interaction among
employees from various Regions.
Presents an overview of the tasks new OSCs and
RPMs perform, including notification, evaluation
and planning, and removal operations for OSCs;
and site plan development, RI/FSs, RODs, RD/RAs
for RPMs. Consists of classroom lectures, group
discussion, case studies, and student exercises.
PERSONNEL PROTECTION AND
SAFETY (165.2)
(5 Days)
This course is for relatively inexperienced per-
sonnel who respond to accidents involving hazard-
ous substances or investigate uncontrolled hazard-
ous waste sites. Topics include: fundamentals of
respiratory protection; types of respiratory protec-
tion apparatus; use and limitation of equipment;
selection of respiratory protection equipment;
protective clothing; air monitoring; and safety pro-
cedures for conducting response operations.
Course familiarizes personnel with general con-
cepts, principles, and procedures for protecting
themselves from the harmful effects of hazardous
materials.
Segments require wearing of respiratory equip-
ment which precludes the use of glasses. Par-
ticipation may be limited for students who are
severely restricted without glasses. Portions of this
course and course 165.5, Hazardous Materials Inci-
dent Response Operations, are redundant. Per-
sons considering application to both courses
should confer with the registrar.
REMEDIAL INVESTIGATION AND
FEASIBILITY STUDY
(3 Days)
This introductory course is primarily intended for
Regional and State program management
employees and for technical and enforcement staff
members. Provides extensive discussion of
remedial investigations, feasibility studies, and
program management.
Some topics for the remedial investigation in-
clude purpose and objectives and how to plan an
investigation. Topics for the feasibility study are
purpose, available criteria, alternatives, and con-
ceptual design. Consists primarily of classroom
lectures and discussions.
A-1
-------
CONTRACT ADMINISTRATION
(3 Days)
This course is designed to provide EPA Project
Officers, Work Assignment Managers, and Delivery
Order Officers with a better understanding of the
contract administration process and their critical
rotes in the process. Consists of combination of
lecture, video presentation, and active student par-
ticipation. Includes an open-book examination at
the end of the course.
The text for the course is Contract Administra-
tion: A Guide for Project Officers, which serves as
a handy, desk-top reference long after completion
of the course.
RISK ASSESSMENT IN SUPERFUND
(2 Days)
This beginning course is intended for Federal
and State employees responsible for reviewing, su-
pervising or facilitating the work of consultants or
technical experts in performing risk assessments.
Consists of lectures, discussions, and practical ex-
ercises. Topics include an overview of chemical
risk assessment, hazard identification and dose-
response assessment, exposure assessment and
risk characterization, and risk communication.
Day 2 provides an overview of the Superfund
Public Health Evaluation Process, including an in-
ensh/e case study exercise.
After completing the course, students will have a
better understanding of toxicology for use in
recommending or reinforcing site safety proce-
dures, supervising or reviewing site activities, and
presenting site related toxicological data to the
public as well as direct experience in utilizing the
Superfund Public Health Evaluation Process.
BASIC GROUND-WATER COURSE
(3 Days)
This introductory course is intended for all EPA
and State employees who require a better under-
standing of ground-water issues. Offers a general
overview of basic hydrogeology and ground-water
movement, contaminant transport, ground-water
Investigations, aquifer restorations and ground-
water modeling. Consists of lectures, demonstra-
tions, and classroom discussions. Upon comple-
tion of the course, students will have a better un-
derstanding of basic hydrogeology, ground-water
movement, and related subjects.
HAZARDOUS MATERIALS CLEANUP
TECHNOLOGIES
(2 Days)
This introductory course is intended for State
and Regional CERCLA program management staff.
Offers an in-depth review of the fuii range of haz-
ardous cleanup technologies applicable to the
variety of Superfund sites on the National Priority
List. Consists of lectures, discussions and case
studies. Topics include hazardous materials
cleanup technologies and a methodology for
selecting appropriate technologies. Course ex-
amines costs for each technology, institutional
constraints, and other pros and cons.
After completing the course, students will have a
better understanding of the available hazardous
material cleanup technologies and the appropriate-
ness of those technologies to a particular site.
CORRECTIVE ACTIONS FOR
CONTAINING AND CONTROLLING
GROUND-WATER CONTAMINATION
(3 Days)
This is an intensive introductory course
developed by the National Water Wells Association
to provide training in containing ground water pol-
lution. Emphasis is on practical aspects and ap-
plications with a minimum of theoretical discussion.
Course is directed toward EPA, State and local
employees with RCRA or CERCLA responsibilities,
especially those involved in cleanup of leaking un-
derground storage tanks.
Participants will develop an understanding of
regulations governing the application of corrective
actions, proper application of available tech-
nologies, and effectiveness of technologies in
specific situations. Topics include hydrogeologic
considerations in corrective action planning, inves-
tigative techniques for defining contaminant
plumes, exhumation and waste removal, caps and
cover design and installation, remedial actions in
the vadose zone, active physical containment, pas-
sive physical containment with low permeability
barriers, field applications, treatment technologies,
physical recovery of petroleum hydrocarbons, and
in-situ aquifer restoration.
A-2
-------
COMMUNITY RELATIONS IN
SUPERFUND: CONCEPTS AND SKILLS
(2 Days)
This course is intended for Regional and State
Program Management and Technical staff. The
course involves skill development in dealing with
citizens and local officials, building good media
relations, and conflict management. Case studies
are used in the course for instruction as well as for
discussion purposes.
MANAGEMENT OF CONSTRUCTION
IN THE SUPERFUND PROGRAM
(3 Days)
This course provides an introduction to manage-
mentof construction in the Superfund program. It
is intended to help provide Regional and State
managers with a perspective on what is needed to
plan, schedule and control a Superfund construc-
tion project. The course addresses the manage-
ment issues to be considered in the construction
activity, and provides a foundation from which at-
tendees will grow in their technical and administra-
tive competence.
Course topics include successful management
practices, the bidding process, procurement prac-
tices, project design, management of change or-
ders and claims, and construction inspections.
Training is provided by means of classroom lec-
ture, case studies, and group discussion.
Upon completion of this course, participants will
be able to act more effectively as managers in the
Superfund program. Participants will be more
familiar with construction management and will
have a clearer understanding of authorities and
responsibilities of all parties involved in construc-
tion.
A-3
-------
-------
Attachment B
Information Sources and
Selected OSWER Directives
z~r
-------
-------
INFORMATION SOURCES
An annotated bibliography of documents specifically related to Superfund site remedial processes follows.
These documents are accessible through the EPA library network as part of the Hazardous Waste Collec-
tion. The referenced documents are frequently updated.
The Hazardous Waste Collection
The EPA library network has a hazardous waste library collection consisting of EPA Reports, OSWER
policy and guidance directives, books, periodicals, and a listing of commercial databases containing haz-
ardous waste information. Hard copies of these documents are available in the Headquarters and Regional
libraries, the National Enforcement Investigations Center, and some EPA laboratory libraries.
dBASE III Access
The entire hazardous waste collection is accessible on a database using an IBM PC/AT. EPA reference
librarians search the database at no charge to EPA staff. The database provides automated search and
retrieval capability by the following access points:
Keyword/subject heading
Abstract
Title
Author
Sponsoring organization/office
Project manager's name
Contact number.
The data base collection is organized into three areas:
• Periodicals
• Monographs: books; non-EPA reports; EPA reports; OSWER policy and guidance directives
• Commercial databases.
B-1
-------
SUBJECT INDEX TO SELECTED OSWER DIRECTIVE
SUBJECT
OSWER: DIRECTIVE
1. Remedial Project Management
2. Remedial Investigation / Feasibility Study (RI/FS)
General
Alternatives development
and evaluation
Compliance with other
environmental laws
Contracts (REM)
Health and safety
Public health assessment
Site characterization
9355.1-1, 9355.2-1
9355.0-5C, 9355.0-6B
9355.0-8, 9355.0-10,
9355.0-13, 9380.0,
9280.0, 9283.1-2, 9380.2-3
9234.0-2, 9234.0-3,
9347.0-1
9242.3
9285.1-18, 9285.2
9285.4, 9285.5, 9295.1
9240.0-1, 9285.2,
9355.0-7A, 9355.0-14
3. Record of Decision (ROD)
General
Functional NEPA equivalency
4. Remedial Design / Remedial Action (RD/RA)
9340.2-1
9318.0
General
Off-Site response actions
9355.0-4A
9330.2
5. Site Closeout
NPL deletion
Operation and maintenance
9320.2
9355.0-4A
6. Other
Community relations
Enforcement
Federal facilities
Interagency agreements
Removal / remedial interface
State participation
9230.0-3, 9320.4
9234.01-1, 9340.1
9272.0
9295.1, 9295.2,
9295.3, 9295.5
9360.0-3A, 9360.0-6A
9375.1-4, 9375.1-5
B-2
-------
Abstract of Selected Oswer Publications
9230.0-3 Community Relations in Superfund:
A Handbook
Provides program guidance for conducting
community relations activities in the Superfund
program. Offers specific guidance for EPA and
State staff on how to design and implement an
effective community, relations program.
Describes community relations activities during
both removal and remedial actions. (March
1986)
9234.0-1 CERCLA Compliance/Enforcement
Policy Compendium
Compiles all currently enforceable guidance
relating to CERCLA compliance enforcement
activities. (February 1984)
9234.0-2 CERCLA Compliance With Other
Environmental Statutes
Describes policy on applicability of standards,
criteria, advisories, and guidance of other State
and Federal environmental and public health
statutes to actions taken pursuant to Sections
104 and 106 of CERCLA. Addresses con-
siderations for on-site and off-site actions taken
under CERCLA. (J.W. Porter, October 2,1985)
(also included in NCP [50 FR 47912], Novem-
ber 20, 1985) (See also 9234.0-3 and 9330.2-1).
9234.0-3 Draft Guidance on CERCLA Compliance
With Other Environmental Statutes
(RCRA Requirements)
Expands CERCLA Compliance With Other En-
vironmental Statutes (9234.0-2). Current draft
addresses only the requirements of RCRA that
may be applicable or relevant and appropriate
for CERCLA response actions. Other Federal
public health and environmental statutes will be
addressed subsequently. (December 16,
1985)
9240.0-1 User's Guide to the Contract Laboratory
Program
Describes procedures for using the CLP. Outlines
organic, inorganic, and dioxin analytical program
requirements, and analytical procedures of CLP
protocols. (October, 1984)
9242.3-3A Work Assignment Procedures for
Remedial Contracts
Outlines various steps and stages of a work as-
signment from inception through completion.
Includes a streamlined Work Plan Memoran-
dum package and provides several scenarios,
including phased approval and execution, and
a strong emphasis on more Regional manage-
ment control. (November 1986)
9242.3-5 REMII Contract Award Fee Performance
Evaluation Plan
Describes REM II award fee procedures, which
are essentially the same as the revised
REM/FIT procedures. The one exception is the
need for each Region to assess the
contractor's Regional management activities.
Describes specific procedures and review
schedules. (July 25,1984)
9272.0-1 Implementation of CERCLA Strategy at
Federal Facilities
Describes implementation phase of Federal
Facility CERCLA Strategy (Memorandum, April
2, 1984, J. Cooper, AAfor External Affairs, to L.
Thomas, AA, OSWER).
9272.0-2 Initial Guidance on Federal Facilities
CERCLA Sites
Outlines status and direction of OSWER efforts
to implement hazardous site cleanup at
Federal facilities. Divides primary responsibility
for national management of Superfund Federal
facility programs between OWPE and OERR.
(L Thomas, Decembers, 1984)
B-3
-------
9272.0-3 Responsibilities for Federal Facilities
Clarifies responsibilities of OWPE and OERR
on Federal facilities. (Memorandum, August
19, 1985, G. Lucero, Director OWPE, to W.
Hedeman, Director OERR)
9272.0-4 Federal Facilities
Clarifies responsibilities and direction of efforts
within OWPE for Federal facility activities.
(Memorandum, August 19,1985, G. Lucero)
9272.0-5 Responsibilities for Federal Facilities
Provides transition for the OERR Facilities
Program. Describes manual development
responsibilities that OWPE assumed and
clarifies responsibilities between OERR and
OWPE for Federal facilities. (Memorandum,
August 26, 1985, W. Hedeman, Director,
OERR, to G. Lucero, Director, OWPE).
9280.0-1 Flood Plain Requirements
Adopts policy that CERCLA actions must meet
the requirements of the Flood Plains Manage-
ment Executive Order (E.O. 11988) and EPA
Implementing regulations (40 CFR 6 Appendix
A). (W. Hedeman, November 14, 1983) (Sup-
plemented by 9280.0-2)
9280.0-2 Po//cy on Flood Plains and Wetlands
Assessments
Discusses situations that require preparation of
a flood plains or wetlands assessment, and the
factors which should be considered in prepar-
ing an assessment for response actions under-
taken pursuant to CERCLA sections 104 and
106. (W. Hedeman, August 6, 1985) (Supple-
ments 9280.0-1)
9283.1-2 Guidance on Remedial Actions for Con-
taminated Ground Water at Super-
fund Sites
Focuses on key decision-making issues in the
development, evaluation, and selection of
ground-water remedial actions at Superfund
sites. Outlines key considerations during the
selection of a ground-water remedy, provides a
consistent approach to cost-effectiveness
decisions, and presents case studies of proper
ground water cleanup decision making proces-
ses. Does not discuss in detail technical
aspects of ground-water investigation,
evaluation, and cleanup. (October 1986)
9285.1 -1B Standard Operating Safety Guide Manual
Revises guidance on health and safety to com-
plement professional judgment and ex-
perience, and to supplement existing Regional
safety criteria. Reflects additional experience
EPA personnel have gained in responding to
environmental incidents involving hazardous
substances. Not meant to be a comprehensive
safety manual for incident response.
(W. Hedeman, November 19,1984)
9285.2 Field Standard Operating Procedures
(FSOP) Manual
Provides additional guidance in a cookbook
format on health and safety to complement
professional judgment and experience and to
supplement existing Regional safety criteria.
[Not a manual on its own — made up of the fol-
lowing FSOPs.]
.
9285.2-1 FSOP #4 - Site Entry [
Provides site entry procedures that field
response personnel can use to minimize risk of
exposure to hazardous substances. (January
1985)
9285.2-2 FSOP #7 - Decontamination of Response
Personnel
Provides decontamination procedures that
field response personnel can use to minimize
risk of exposure to hazardous substances.
(January 1985) >
9285.2-3 FSOP #8 - Air Surveillance
Provides air monitoring procedures that field
response personnel can use to obtain data
needed to minimize risk of exposure to hazard-
ous substances. (January 1985)
B-4
-------
9285.2-4 FSOP #6 - Work Zones
9295.1 -1 MOU Between the ATSDR and EPA
Provides procedures for establishing work
zones for control of hazardous materials and to
minimize risk of exposure of field response per-
sonnel. (April 1985)
9285.2-5 FSOP #9 - Site Safety Plan
Establishes requirements for protecting the
health and safety of field response personnel
during all activities conducted at an incident.
Contains safety information, instructions, and
procedures. (April 1985)
9285.4-1 Draft - Superfund Public Health
Evaluation Manual
Establishes a framework for analyzing public
health risks at Superfund sites and for develop-
ing design goals for remedial alternatives
based on applicable or relevant and ap-
propriate requirements of other laws, where
available, or risk analysis where those require-
ments are not available. [Procedures are
designed to conform with EPA's proposed risk
assessment guidelines (49 FR 46294-46331,
November 23, 1984, and 50 FR 1170-1176,
January 9,1985)]. (December 18,1985)
9285.5-1 Draft - Superfund Exposure
Assessment Manual,
Outlines framework for a comprehensive, con-
sistent, and appropriate assessment of human
exposure associated with uncontrolled hazard-
ous waste sites. Presents an integrated
methodology designed to guide the three
major component analyses of such assess-
ments: (1) analysis of toxic contaminants
released from a site, (2) determination of en-
vironmental fate of such contaminants, and (3)
evaluation of nature and magnitude of human
population exposure to such contaminants.
(January 14,1986)
Establishes policies and procedures for con-
ducting response and non-response health ac-
tivities related to releases of hazardous sub-
stances. (J. McGraw, April 25, 1985, and D. R.
Hoper,May28,1985)
9295.2-3 Interagency Agreement Between the U.S.
Army Corps of Engineers and the USEPA
in Executing P.L. 96-510, CERCLA
Defines the assistance the U.S. Army Corps of
Engineers will provide to EPA in implementing
EPA Fund-lead, State Fund-lead, and EPA en-
forcement-lead projects. (J. McGraw and R.
Dawson, Decembers, 1984)
9295.3-1 MOU Between DOD and EPA for the
Implementation of P.L. 96-510, CERCLA
Clarifies Department of Defense/EPA respon-
sibilities and commitments for conducting and
financing response actions authorized by
CERCLA and specifically delegated by E.O.
12088. Clarifies respective operational roles,
responsibilities and procedures. (L Korb and
L Thomas, August 12, 1983). (Expired on
December 1, 1985, - has now been extended
until December 1, 1986 OR until Reauthoriza-
tion of Superfund.)
9295.5-1 MOU Between FEMA and EPA for the
Implementation of CERCLA Relocation
Activities under P.L. 96-510, CERCLA
Describes major responsibilities and outlines
areas of mutual support and cooperation be-
tween EPA and Federal Emergency Manage-
ment Agency relating to relocation activities as-
sociated with response actions pursuant to
CERCLA; Executive Order 12316; and the
NCP, 40 CFR Part 300. (J. W. McGraw,
March 29, 1985, and S. W. Speck, April 5,
1985, effective until April 1989)
B-5
-------
9295.5-2 Implementation of EPA/FEMA MOU on
CERCLA Relocations
9320.2-1 Interim Procedures for Deleting Sites
from the NPL
Forwards EPA/FEMA MOU on CERCLA
Relocations (9295.5-1) to Regional Ad-
ministrators. Provides guidance in establishing
Regionai/Headquarters/FEMA relocation con-
tacts and following standards established in
the MOU. (J. McGraw, June 14,1985)
Sets forth criteria and interim procedures for
deleting sites from the NPL to indicate sites
that have been cleaned up or that have been
determined not to present a Hazard to health,
welfare or environment. (L Thomas, March 27,
1984)
9318.0-1 Interim Policy for Compliance with
the National Environmental Pol Icy Act
9320.2-2 Guidance on Deletion of Sites from the
National Priorities List NPL
Addresses policy under NEPA for remedial ac-
tions, or long-term actions consistent with per-
manent cleanup of a site. Also requires that
design of remedies be the result of weighing al-
ternatives and be cost-effective. (M. Cook,
May 18,1981) (Supplemented by 9318.0-2)
9318.0-2 Guidance on Superfund NEPA Policy:
Areas of Responsibility
Identifies areas of responsibility of Superfund
staff for preparation of Environmental Impact
Statements to ensure compliance with NEPA
for Superfund remedial action projects. (M.
Cook and W. Hedeman, August 17, 1981)
(Supplements 9318.0-1)
9318.0-3 CERCLA Remedial Actions and NEPA/EIS
Functional Equivalency
Urges RA's to develop close working relation-
ship between OSWER, Office of Federal Ac-
tivities and Regions to ensure that reviews for
remedial actions under CERCLA are functional-
ly equivalent to the Environmental Impact
Statement requirements of section 102(2)(C).
(L Thomas and J. Cooper, August 22, 1984)
(Supplemented by 9318.0-4)
9318.0-4 Coordination between Regional
Superfund Staffs and OFA Regional
Counterparts on CERCLA Actions
Revises procedures and criteria for making
deletions to the NPL to indicate sites that have
been cleaned up or that have been determined
not to present a hazard to health, welfare, or
environment. (September 1986)
93204-1 Interim Information Release Policy
Provides interim policy for NPL information
release. For use by the Regions to prepare a
coordinated response to Public Citizen FOIA
Requests. (W. Hedeman, April 18,1985)
9330.2-1 Procedures for Planning and Imple-
menting Off-Site Response Actions
Addresses procedures for a response action
involving off-site storage, treatment, or dis-
posal of hazardous substances selected under
CERCLA and RCRA; also, discusses proce-
dures for selecting any off-site facility for
management of hazardous substances under
CERCLA. Prohibits use of RCRA facility for off-
site management of Superfund hazardous sub-
stances if it has significant RCRA violations or
other environmental conditions that affect
satisfactory operation. Also addresses require-
ments for analyzing and selecting response ac-
tions that involve permanent methods of
managing hazardous substances. (J. McGraw,
May 6, 1985) (Supplemented by 9330.2-2 and
9330.2-3)
Encourages coordination between the
Regional Superfund staffs and Office of Federal
Activities Regional counterparts in carrying out
CERCLA actions. (W. Hedeman and A. Hirsch,
October 29,1984) (Supplements 9318.0-3)
B-6
-------
9330.2-3 Guidance on Procedures for Planning
and Supplementing Off-Site Response
Actions
Provides follow-up to off-site disposal policy
(see 9330.2-1). Explains actions OSWER has
or will take to implement this policy. (Novem-
ber 1986)
9340.1 -1 Participation of Potentially Responsible
Parties in Development of Remedial
Investigations and Feasibility Studies
under CERCLA
Sets forth policy and procedures governing
participation of PRPs in development of RI/FS
under CERCLA. Discusses circumstances in
which RI/FS may be conducted by PRPs; pro-
cedures for notifying PRPs when Agency has
identified target sites for development of RI/FS;
and principles governing PRP participation in
Agency-financed RI/FS. (L. Thomas, March 20,
1984)
9340.2-1 Preparation of Decision Documents for
Approving Fund-Financed and
Potentially Responsible Party. Remedial
Actions Under CERCLA
Assists Regional Offices in preparation of
decision documents required for approval of
Fund-financed and PRP remedial actions. A
Record of Decision, Enforcement Decision
Document or Negotiation Decision Document
is required for all remedial actions financed
from the Fund. Documents Agency's decision-
making process and demonstrates that the re-
quirements of CERCLA and the NCP have
been met. Procedure provides basis for any
future cost-recovery action. (J. McGraw,
February 27,1985)
9347.0-1 Interim RCRA/CERCLA Guidance on
Non-Contiguous Sites and On-Site
Management of Waste Residue
Addresses several RCRA/CERCLA interface is-
sues at MOTCO, Texas site, which have broad
implications for remedial actions at many other
Superfund sites. Lays out EPA policy on
several issues including combined treatment of
CERCLA waste from noncontiguous locations,
limitations on construction of hazardous waste
incinerators for on-site CERCLA use, and on-
site disposal of treatment residue. (March 26,
1986)
9355.0-4A Superfund Remedial Design and
Remedial Action Guidance
Assists agencies and parties who plan, ad-
minister and manage remedial design (RD) and
remedial action (RA) at Superfund sites. Per-
tains to Fund-financed RD/RA (i.e. Federal-lead
and State-lead) and responsible party RD/RA,
and provides procedural guidance to ensure
that RD/RA are performed properly, consistent-
ly, and expeditiously. (June 1986)
9355.0-5C Guidance on Feasibility Studies Under
CERCLA
Provides a more detailed structure for identify-
ing, evaluating, and selecting remedial action
alternatives under CERCLA and the NCP (40
CFR 300). (Junex 1985) (Supplemented by
9355.0-7B and 938d.O-3)
9355.0-6B Guidance on Remedial Investigations
Under CERCLA
Describes remedial investigations to obtain
data to evaluate and select measures to con-
trol specific problems caused by uncontrolled
hazardous waste sites. For use by other
Federal agencies and PRPs when undertaking
remedial response pursuant to the NCP and
CERCLA Section 104 or section 107. Com-
pliance with this guidance will help meet NCP
requirements. (June 1985) (Supplemented by
9355.0-7B and 9380.0-3)
9355.0-7B Data Quality Objectives for Remedial
Response Activities, Volumes I and II
Volume I guides user through process of
developing data quality objectives for generic
remedial response activities. Volume II il-
lustrates how the DQO development process
would be applied to a remedial investiga-
tion/feasibility study at a site with contaminated
soils and ground water. (March 1987) (Sup-
plements 9355.0-5C and 9355.0-6B)
B-7
-------
9355.0-8 Modeling Remedial Actions at
Uncontrolled Hazardous Waste Sites
Provides guidance on selection and use of
models for evaluating effectiveness of remedial
actions at uncontrolled hazardous waste sites.
Provides a comprehensive set of guidelines to
regulatory officials for incorporation of models
into remedial action planning process at
Federal and State Superfund sites. (April 1985)
9355.0-10 Remedial Action Costing Procedures
Manual
Provides guidance to project managers and
decision makers in government and industry
for preparation of detailed feasibility cost es-
timates of remedial action alternatives required
under revised NCP. (September 1985)
9355.0-14 Quality Assurance/Field Operations
Methods Manual
Provides Remedial Project Managers and
quality assurance officers with a consolidated,
ready reference of existing field methods to
guide remedial field activities. Primary objec-
tives are to promote quality and consistency in
field work and to help streamline project plan-
ning process, particularly preparation of sam-
pling and analysis plans and Quality Assurance
Project Plans. Once approved, Compendium
will be used by the EPA remedial contractors,
and also can be made available to States and
private parties. The Compendium supplement
the Rl and FS Guidance documents and the
DQO guidance. (April 1986)
9355.1 -1 Superfund Federal-Lead Remedial
Project Management Handbook
Assists EPA Remedial Project Managers in
managing Federal-lead remedial response
projects. Describes in detail responsibilities of
the RPM during planning, design, construction,
operation, and close-out of remedial response
projects. Provides information on procedures
for conducting Federal-lead remedial projects
from pre-RI/FS activities through site close-out.
(December 1986) (Supplements 9355.2-1)
9355.2-1 Superfund State-Lead Remedial
Project Management Handbook
Assists EPA Remedial Project Managers
(RPMs) in managing State-lead remedial
response projects. Describes in detail respon-
sibilities of the RPM during planning, design,
construction, operation and close-out of
remedial response projects. (December 1986)
(Supplements 9355.1-1)
9360.0-3A Superfund Removal Procedures
Provides EPA response officials with uniform,
Agency-wide, guidance on removal actions.
Guidance provided is essentially procedural
and focuses on implementation of the hazard-
ous substances removal program for multi-
media releases from facilities and vessels
within EPA's area of responsibility.
(March 1986)
9360.0-6A Relationship of the Removal and
Remedial Program Under the
Revised NCP
Outlines revisions to the NCP that redefine
removal and remedial actions to expedite
cleanup activities. Addresses management is-
sues that may arise between the two programs
in Headquarters and the Regions. (March
1986) (Supercedes 9360.0-6)
9375.1 -4 State Participation in the Superfund
Program, Volume I
Describes State participation in implementing
approved remedial response activities at NPL
sites in accordance with the NCP and options
now available to States for expediting cleanup
activities. (February 1984) (Being reissued by
OSWER Directive 9375.1-2 and 9375.1-2A on a
chapter by chapter and appendix by appendix
basis.)
B-8
-------
9375.1 -5 State Participation in the Superfund
Program, Volume II
Explains salient points of EPA's general regula-
tions that apply to all State procurement under
Superfund Cooperative Agreement; discusses
procurement of A/E services, and the type of
activities these firms can manage on behalf of
the State throughout response (RI/FS, RD, RA
and O&M); discusses procurement of con-
struction services, subagreement administra-
tion, and claims management. (March 1986)
9380.0-2 Slurry Trench Construction for
Pollution Migration Control
•^Provides in-depth guidance on use of slurry
walls for control of subsurface pollutants.
.(February 1984)
9380.0-3 Guidance Document for Cleanup of
Surface Tank and Drum Sites
Provides guidance on carrying out concurrent
remedial planning activities and accelerating
project implementation for cleanup of surface
tanks and drums containing hazardous waste.
Provides systematic approach to remedial ac-
tion for hazardous wastes stored in tanks and
drums. (May 1985) (Supplements 9355.0-5C
and 9355.0-6B)
9380.0-4 Remedial Action at Waste Disposal
Sites Handbook (Revised)
Provides basic reference for understanding
remedial technologies; selecting potentially ap-
plicable technologies for a given waste site,
and planning for remedial action.
(October 1985)
9380.0-5 Leachate Plume Management
Provides an overview of the fundamental con-
cepts, procedures, and technologies used in
leachate plume management. Discusses
plume generation dynamics and delineation.
Evaluates plume control technologies and
defines selection criteria. (November 1986)
9380.0-6 Guidance Document for Cleanup of
Surface Impoundment Sites
Assists on-scene Federal, State, or local offi-
cials and private firms to develop remedial ac-
tions at NPL sites with one or more surface im-
poundments containing hazardous waste.
Provides detailed guidance for conducting a
limited remedial investigation and a limited
feasibility study for the purpose of selecting an
appropriate remedy. (June 1986)
9380.2-3 Superfund Innovative Technology Eval-
uation (SITE) Strategy and Program Plan
Presents EPA's strategy for implementing the
SITE program. Primary purpose of SITE is to
enhance development and demonstration,
thereby establishing the commercial
availability, of innovative technologies at Su-
perfund sites. (December 1986)
9833.3 Administrative Records for Decisions on
Selection of CERCLA Response Actions
Outlines requirements for establishing an ad-
ministrative record and lists significant docu-
ments to be included in the record. (May
1987)
Mobile Treatment Technologies for Superfund
Wastes, EPA Report No. 540/2-86-003F
Addresses the use of established and develop-
ing mobile systems to treat Superfund wastes.
Discusses capabilities and limitations of five
broad treatment categories: thermal, immobi-
lization, chemical, physical, and biological
treatment. (September 1986)
B-9
. S. GOVERNMENT PRINTING OFFICE: 1988/548-158/67074
-------
------- |