& EPA
United States
Environmental Protection
Agency
Office of Emergency and
Remedial Response
Washington, DC 20460
PE89-184626
EPA/540/G-89/004
OSWER Directive 9355.3-01
October 1988
Superfund
Guidance for
Conducting Remedial
Investigations and
Feasibility Studies
Under CERCLA
Interim Final
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EPA/540/G-89/004
OSWER Directive 9355.3-01
October 1988
Guidance for Conducting Remedial
Investigations and Feasibility Studies
Under CERCLA
Interim Final
Office of Emergency and Remedial Response
U.S. Environmental Protection Agency
Washington, D.C. 20460
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Notice
Development of this document was funded, wholly or in part, by the United States
Environmental Protection Agency under Contract No. 68-W8-0098. It has been
subjected to the Agency's review process and approved for publication as an EPA
document.
The policies and procedures established in this document are intended solely for the
guidance of government personnel. They are not intended and cannot be relied upon
to create any rights, substantive or procedural, enforceable by any party in litigation
with the United States. The Agency reserves the right to act at variance with these
policies and procedures and to change them at any time without public notice.
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Contents
Page
Figures vii
Tables viii
Glossary ix
Acknowledgments xi
1 Introduction 1-1
1.1 Purpose of the RI/FS 1-3
1.2 Purpose of the Guidance 1-3
1.3 Overview of CERCLA Reauthorization 1-3
1.3.1 Cleanup Standards 1-4
1.3.1.1 Applicable or Relevant and Appropriate Requirements 1-4
1.3.1.2 Offsite Facilities 1-4
1.3.2 Health Assessments 1-4
1.3.3 State Involvement 1-5
1.3.4 Community Involvement 1-5
1.3.5 Administrative Record 1-5
1.3.6 Worker Safety 1-5
1.3.7 Enforcement Authorities 1-5
1.4 The RI/FS Process Under CERCLA 1-6
1.4.1 Scoping 1-6
1.4.2 Site Characterization 1-6
1.4.3 Development and Screening of Alternatives 1-7
1.4.4 Treatability Investigations 1-9
1.4.5 Detailed Analysis 1-9
1.5 Special Sites 1-9
1.6 Community Relations 1-9
1.7 Lead and Support Agency 1-9
1.8 Remedial Project Manager Role and Responsibilities 1-10
2 Scoping the RI/FS 2-1
2.1 Introduction 2-3
2.2 Project Planning 2-3
2.2.1 Conduct Project Meeting 2-5
2.2.2 Collect and Analyze Existing Data 2-5
2.2.2.1 Establish Physical Characteristics of the Site 2-7
2.2.2.2 Develop a Conceptual Site Model 2-7
2.2.2.3 Determine the Need for and Implement
Limited Additional Studies 2-7
2.2.3 Develop Preliminary Remedial Action Alternatives 2-7
2.2.4 Evaluate the Need for Treatability Studies 2-9
2.2.5 Begin Preliminary Identification of ARARs and To Be
Considered (TBC) Information 2-9
2.2.6 Identify Data Needs 2-9
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Contents (continued)
2.2.7 Design a Data Collection Program 2-10
2.2.8 Develop a Work Plan 2-12
2.2.9 Identify Health and Safety Protocols 2-12
2.2.10 Conduct Community Interviews 2-12
2.3 Deliverables and Communication 2-12
2.3.1 Work Plan 2-13
2.3.1.1 Purpose 2-13
2.3.1.2 Preparation 2-13
2.3.1.3 Work Plan Elements 2-13
2.3.1.4 Report Format 2-16
2.3.2 Sampling and Analysis Plan (SAP) 2-16
2.3.2.1 Purpose 2-16
2.3.2.2 Plan Preparation and Responsibilities 2-16
2.3.2.3 Field Sampling Plan Elements 2-16
2.3.2.4 Quality Assurance Project Plan Elements 2-16
2.3.3 Health and Safety Plan 2-16
2.3.3.1 Purpose 2-16
2.3.3.2 Elements of the Health and Safety Plan 2-17
2.3.3.3 Site Briefings and Inspections 2-17
2.3.4 Community Relations Plan 2-17
2.3.4.1 Purpose 2-17
2.3.4.2 Community Relations Plan Elements 2-17
3 Site Characterization 3-1
3.1 Introduction 3-3
3.2 Field Investigation Methods 3-3
3.2.1 Implement Field Activities 3-3
3.2.2 Investigate Site Physical Characteristics 3-5
3.2.2.1 Surface Features 3-5
3.2.2.2 Geology 3-6
3.2.2.3 Soils and the Vadose Zone 3-6
3.2.2.4 Surface-Water Hydrology 3-6
3.2.2.5 Hydrogeology 3-6
3.2.2.6 Meteorology 3-7
3.2.2.7 Human Populations and Land Uses 3-7
3.2.2.8 Ecological Investigations 3-10
3.2.3 Define Sources of Contamination 3-13
3.2.4 Determine the Nature and Extent of Contamination 3-13
3.2.4.1 Ground Water 3-17
3.2.4.2 Soil 3-17
3.2.4.3 Surface Water 3-17
3.2.4.4 Sediments 3-17
3.2.4.5 Air 3-18
3.2.5 Additional Site Characterization 3-18
3.3 Laboratory Analyses 3-18
3.4 Data Analyses 3-19
3.4.1 Site Characteristics 3-19
3.4.1.1 Site Physical Characteristics 3-19
3.4.1.2 Source Characteristics 3-19
3.4.1.3 The Nature and Extent of Contamination 3-19
3.4.1.4 Contaminant Fate and Transport 3-19
IV
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Contents (continued)
3.4.2 Baseline Risk Assessment 3-20
3.4.2.1 General Information 3-20
3.4.2.2 Components of the Baseline Risk Assessment 3-20
3.4.3 Evaluate Data Needs 3-23
3.5 Data Management Procedures 3-23
3.5.1 Field Activities 3-26
3.5.2 Sample Management and Tracking 3-26
3.5.3 Document Control and Inventory 3-27
3.6 Community Relations Activities During Site Characterization 3-27
3.7 Reporting and Communication During Site Characterization 3-28
3.7.1 Information for ARAR Identification 3-28
3.7.2 Preliminary Site Characterization Summary 3-28
3.7.3 Draft Rl Report 3-28
4 Development and Screening of Alternatives 4-1
4.1 Introduction 4-3
4.1.1 Purpose of Alternative Development and Screening 4-3
4.1.2 FS Process Overview 4-3
4.1.2.1 Development and Screening of Alternatives 4-3
4.1.2.2 Detailed Analysis of Alternatives 4-5
4.1.3 Alternative Ranges 4-7
4.1.3.1 Source Control Actions 4-7
4.1.3.2 Ground-Water Response Actions 4-7
4.2 Alternative Development Process 4-7
4.2.1 Develop Remedial Action Objectives 4-7
4.2.2 Develop General Response Actions 4-15
4.2.3 Identify Volumes or Areas of Media 4-15
4.2.4 Identify and Screen Remedial Technologies and Process Options ... 4-15
4.2.5 Evaluate Process Options 4-16
4.2.5.1 Effectiveness Evaluation 4-16
4.2.5.2 Implementability Evaluation 4-20
4.2.5.3 Cost Evaluation 4-20
4.2.6 Assemble Alternatives 4-20
4.3 Alternatives Screening Process 4-21
4.3.1 Alternatives Definition 4-21
4.3.1.1 Specific Objectives 4-22
4.3.1.2 Define Media and Process Options 4-22
4.3.2 Screening Evaluation 4-23
4.3.2.1 Effectiveness Evaluation 4-24
4.3.2.2 Implementability Evaluation 4-24
4.3.2.3 Cost Evaluation 4-24
4.3.2.4 Innovative Technologies 4-26
4.3.3 Alternative Screening 4-26
4.3.3.1 Guidelines for Screening 4-26
4.3.3.2 Selection of Alternatives for Detailed Analysis 4-26
4.3.3.3 Post-Screening Tasks 4-26
4.4 Community Relations During Alternative Development and Screening 4-27
4.5 Reporting and Communication During Alternative Development and Screening 4-27
5 Treatability Investigations 5-1
5.1 Introduction 5-3
5.1.1 Objectives of Treatability Investigations 5-3
5.1.2 Overview of Treatability Investigations 5-3
5.2 Determination of Data Requirements 5-3
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Contents (continued)
5.3 Treatability Testing 5-5
5.3.1 Bench-Scale Treatability Studies 5-6
5.3.2 Pilot-Scale Treatability Studies 5-6
5.4 Bench Versus Pilot Testing 5-7
5.4.1 Testing Considerations 5-8
5.4.2 Data Quality Objectives 5-8
5.5 Treatability Test Work Plan 5-8
5.5.1 Bench-Scale Treatability Work Plan 5-9
5.5.2 Pilot-Scale Treatability Work Plan 5-11
5.6 Application of Results 5-11
5.6.1 Data Analysis and Interpretation 5-11
5.6.2 Use of the Results in the RI/FS Process 5-12
5.6.3 Scaling up to Full-Scale 5-12
5.7 Community Relations During Treatability Investigations 5-12
5.8 Reporting and Communication During Treatability Investigations 5-12
6 Detailed Analysis of Alternatives 6-1
6.1 Introduction 6-3
6.1.1 Purpose of the Detailed Analysis of Alternatives 6-3
6.1.2 The Context of Detailed Analysis 6-4
6.1.3 Overview of the Detailed Analysis 6-4
6.2 Detailed Analysis of Alternatives 6-4
6.2.1 Alternative Definition 6-4
6.2.2 Overview of Evaluation Criteria 6-5
6.2.3 Individual Analysis of Alternatives 6-6
6.2.3.1 Overall Protection of Human Health and the Environment 6-6
6.2.3.2 Compliance with ARARs 6-6
6.2.3.3 Long-Term Effectiveness and Permanence 6-8
6.2.3.4 Reduction of Toxicity, Mobility, or Volume Through Treatment . 6-8
6.2.3.5 Short-Term Effectiveness 6-9
6.2.3.6 Implementability 6-9
6.2.3.7 Cost 6-10
6.2.3.8 State (Support Agency) Acceptance 6-13
6.2.3.9 Community Acceptance 6-13
6.2.4 Presentation of Individual Analysis 6-13
6.2.5 Comparative Analysis of Alternatives 6-14
6.2.6 Presentation of Comparative Analysis 6-14
6.3 Post-RI/FS Selection of the Preferred Alternative 6-14
6.4 Community Relations During Detailed Analysis 6-14
6.5 Reporting and Communication During Detailed Analysis 6-15
Bibliography 7-1
Appendices
A Interim Guidance on PRP Participation in the RI/FS Process A-1
B Elements of RI/FS Project Plans 8-1
C Model Statement of Work for Remedial Investigations and Feasibility Studies . . C-1
D Bibliography of Technology Process Resource Documents D-1
E Documentation of ARARs E-1
F Case Example of Detailed Analysis F-1
VI
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Figures
Number Page
1-1 Phased RI/FS process 1-7
1 -2 Generic phased RI/FS timeline 1-8
2-1 Scoping 2-4
2-2 Example conceptual site model 2-8
2-3 Summary of analytical levels appropriate to data uses 2-11
2-4 Relationship of RI/FS tasks to phased RI/FS approach 2-15
3-1 Major components of site characterization 3-4
3-2 Representation of the areal extent of contamination 3-21
3-3 Components of the risk assessment process 3-24
3-4 Identification of exposure pathways 3-25
4-1 Alternative development 4-4
4-2 Generic alternative development process 4-6
4-3 Conceptual treatment range for source control 4-8
4-4 An example of Initial screening of technologies and process options ... 4-17
4-5 Evaluation of process options - example 4-19
4-6 Assembling a range of alternative examples 4-21
4-7 Time to achieve 1 (H to 10-6 risk level for a single- contaminant for ground
water cleanup under various soil removal alternatives 4-23
4-8 Relationship of screening criteria to the nine evaluation criteria 4-25
5-1 Treatability investigations 5-4
6-1 Detailed analysis of alternatives 6-5
6-2 Criteria for detailed analysis of alternatives 6-7
F-1 Site map case example F-2
F-2 Alternative components case example F-4
VII
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Tables
Number Page
2-1 Data Collection Information Sources 2-6
2-2 Communication and Deliverables During Scoping 2-14
2-3 Suggested RI/FS Work Plan Format 2-16
2-4 Suggested Format for SAP (FSP and QAPP) 2-17
3-1 Relationship Among Site Characterization Tasks and the Compendium . . 3-5
3-2 Summary of Site Geology Information 3-7
3-3 Summary of Soil and Vadose Zone Information 3-8
3-4 Summary of Surface-water Information 3-9
3-5 Aspects of Site Hydrogeology 3-10
3-6 Features of Ground-water Systems 3-10
3-7 Summary of Ground-water Information 3-11
3-8 Summary of Atmospheric Information 3-12
3-9 Summary of Ecological Information 3-14
3-10 Summary of Source Information 3-15
3-11 Outline of Suggested File Structure for Superfund Sites 3-27
3-12 Reporting and Communication During Site Characterization 3-29
3-13 Suggested Rl Report Format 3-30
4-1 Example of Remedial Action Objectives, General Response Actions,
Technology Types, and Example Process Options for the Development and
Screening of Technologies 4-10
4-2 Reporting and Communication During Alternative Development
and Screening 4-28
5-1 Typical Data Requirements for Remediation Technologies 5-5
5-2 Bench and Pilot Study Parameters 5-9
5-3 Examples of Bench- and Pilot-scale Testing Programs 5-10
5-4 Data Quality for Treatability Investigations 5-11
5-5 Suggested Format for Bench-scale Work Plan 5-11
5-6 Suggested Format for Pilot-scale Work Plan 5-11
5-7 Reporting and Communication During Treatability Investigations 5-12
6-1 Long-term Effectiveness and Permanence 6-9
6-2 Reduction of Toxicity, Mobility, or Volume through Treatment 6-10
6-3 Short-term Effectiveness 6-10
6-4 Implementability 6-11
6-5 Suggested FS Report Format 6-15
E-1 Documentation of ARARs E-2
F-1 Individual Evaluation of Final Alternatives Case Study F-13
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Glossary
ARAR Applicable or relevant and appropriate requirement
ATSDR Agency for Toxic Substances and Disease Registry: A branch of the Centers
for Disease Control that is responsible for preparing health assessments at
sites.
CAA Clean Air Act
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act of
1980, also known as Superfund: Amended in 1986 by the Superfund
Amendments and Reauthorization Act (SARA).
CLP Contract Laboratory Program
CRL Central regional laboratory
CRP Community relations plan
CWA Clean Water Act
DQO Data quality objectives: Statements that specify the data needed to support
decisions regarding remedial response activities.
EMSL-LV Environmental Monitoring Systems Laboratory, Las Vegas
EPIC Environmental Photographic Interpretation Center
ERA Expedited response action
ESI Expanded site investigation
FIT Field investigation team
FS Feasibility study
FSP Field sampling plan: Defines in detail the sampling and data gathering
activities to be used at a site. (See SAP.)
HSP Health and safety plan
IRIS Integrated Risk Information System
Lead agency The agency, either the EPA, Federal agency, or appropriate State agency
having primary responsibility and authority for planning and executing the
remediation at a site.
MCL Maximum contaminant level: Established under the Safe Drinking Water Act.
MCLG Maximum contaminant level goal: Established under the Safe Drinking Water
Act.
MPRSA Marine Protection Research and Sanctuaries Act
NAAQS National Ambient Air Quality Standards
NCP National Oil and Hazardous Substances Contingency Plan
NEPA National Environmental Policy Act
IX
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NIOSH National Institute for Occupational Safety and Health
NPDES National Pollutant Discharge Elimination System
NPL National Priorities List: A list of sites identified for remediation under CERCLA.
O&M Operation and maintenance
OSHA Occupational Safety and Health Administration
OSWER Office of Solid Waste and Emergency Response
1* Cancer potency factor: The lifetime cancer risk for each additional mg/kg body
weight per day of exposure.
PRP Potentially responsible party
QA Quality assurance
QAPP Quality assurance project plan: A plan that describes protocols necessary to
achieve the data quality objectives defined for an Rl. (See SAP.)
QC Quality control
RAS Routine analytical services
RCRA Resource Conservation and Recovery Act
RD Remedial design
RfD The reference dose (RfD) is an estimate (with uncertainty spanning perhaps an
order of magnitude) of a daily exposure to the human population (including
sensitive subgroups) that is likely to be without appreciable risk of deleterious
effects during a lifetime.
RI/FS Remedial investigation/ feasibility study
ROD Record of Decision: Documents selection of cost-effective Superfund-
financed remedy.
RPM Remedial Project Manager: The project manager for the lead Federal agency.
SAP Sampling and analysis plan, consisting of a quality assurance project plan
(QAPP) and a field sampling plan (FSP).
SARA Superfund Amendments and Reauthorization Act of 1986. (See CERCLA.)
SAS Special analytical services
SDWA Safe Drinking Water Act
SI Site investigation
SITE Superfund innovative technology evaluation
SOP Standard operating procedures
sow Statement of Work
SPHEM Superfund public health evaluation manual
SWDA Solid Waste Disposal Act
TAT Technical assistance team
TBC To be considered
TCL Target compound list
TOM Technical directive memorandum
TSCA Toxic Substances Control Act
WPRR Work plan revision request
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Acknowledgments
This document was developed by EPA's Office of Emergency and Remedial Response
(OERR) with assistance provided by CH2M HILL in partial fulfillment of Contracts No.
68-01-7090 and 68-W8-0098. Steven C. Golian served as EPA project manager,
with assistance from Elizabeth A. Shaw. The CH2M HILL project team included
Elizabeth Dodge, Brint Bixler, Phil Smith, Julie Pfeffer, Brian Marshall, Bill Gould, and
Jeannie Massie.
In addition to the many EPA Headquarters personnel who assisted in this effort, the
following Regional and State representatives provided significant contributions to the
preparation of this document:
Bruce Marshall
Robert McKnight
Don Lynch
Jeff Pike
Beverly Houston
Martha Berry
Cindy Nolan
Joan Calabrese
Mary Tyson
John Blevins
John Rendall
Dave Tetta
Robert Chapin
Ed Putnam
Gary Pulford
Region I
Region II
Region II
Region III
Region IV
Region IV
Region V
Region V
Region V
Region IX
Region IX
Region X
Texas Water Commission
New Jersey Department of
Environmental Protection
Minnesota Pollution
Control Agency
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CHAPTER 1
INTRODUCTION
FROM:
• Preliminary
Assessment
• Site Inspection
• NPL Listing
SITE
CHARACTERIZATION
TREATABILITY
INVESTIGATIONS
SCOPING OF THE RI/FS
DEVELOPMENT AND SCREENING
OF ALTERNATIVES
DETAILED ANALYSIS
OF ALTERNATIVES
• Remedy Selection
• Record of Decision
• Remedial Design
• Remedial Action ,
V J
1-1
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Chapter 1
Introduction
1.1 Purpose of the RI/FS
The remedial investigation and feasibility study
(RI/FS) process as outlined in this guidance
represents the methodology that the Superfund
program has established for characterizing the nature
and extent of risks posed by uncontrolled hazardous
waste sites and for evaluating potential remedial
options. This approach should be viewed as a
dynamic, flexible process that can and should be
tailored to specific circumstances of individual sites: it
is not a rigid step-by-step approach that must be
conducted identically at every site. The project
manager's central responsibility is to determine how
best to use the flexibility built into the process to
conduct an efficient and effective RI/FS that achieves
high quality results in a timely and cost-effective
manner. A significant challenge project managers
face in effectively managing an RI/FS is the inherent
uncertainties associated with the remediation of
uncontrolled hazardous waste sites. These
uncertainties can be numerous, ranging from potential
unknowns regarding site hydrogeology and the actual
extent of contamination, to the performance of
treatment and engineering controls being considered
as part of the remedial strategy. While these
uncertainties foster a natural desire to want to know
more, this desire competes with the Superfund
program's mandate to perform cleanups within
designated schedules.
The objective of the RI/FS process is not the
unobtainable goal of removing all uncertainty, but
rather to gather information sufficient to support an
informed risk management decision regarding which
remedy appears to be most appropriate for a given
site. The appropriate level of analysis to meet this
objective can only be reached through constant
strategic thinking and careful planning concerning the
essential data needed to reach a remedy selection
decision. As hypotheses are tested and either
rejected or confirmed, adjustments or choices as to
the appropriate course for further investigations and
analyses are required. These choices, like the
remedy selection itself, involve the balancing of a
wide variety of factors and the exercise of best
professional judgment.
1.2 Purpose of the Guidance
This guidance document is a revision of the U.S.
Environmental Protection Agency's (EPA) Guidance
on Remedial Investigations Under CERCLA (May
1985) and Guidance on Feasibility Studies Under
CERCLA (June 1985). These guidances have been
consolidated into a single document and revised to
(1) reflect new emphasis and provisions of the
Superfund Amendments and Reauthorization Act
(SARA), (2) incorporate aspects of new or revised
guidance related to aspects of remedial investigations
and feasibility studies (RI/FSs), (3) incorporate
management initiatives designed to streamline the
RI/FS process, and (4) reflect experience gained from
previous RI/FS projects.
The purpose of this guidance is to provide the user
with an overall understanding of the RI/FS process.
Expected users include EPA personnel, State
agencies responsible for coordinating or directing
activities at National Priorities List (NPL) sites,
potentially responsible parties (PRPs), Federal facility
coordinators, and consultants or companies
contracted to assist in RI/FS-related activities at NPL
sites. This guidance describes the general
procedures for conducting an RI/FS.'Where specific
guidance is currently available elsewhere, the RI/FS
guidance will simply highlight the key points or
concepts as they relate to the RI/FS process and
refer the user to the other sources for additional
details.
1.3 Overview of CERCLA
Reauthorization
SARA was signed by the President on October 17,
1986, to amend the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980
'This guidance document does not typically address differences
in the general procedures (e.g., work plan preparation,
reporting requirements) between a Fund-financed and PRP-
conducted RI/FS, and the flexibility discussed for certain
activities may not pertain to a PRP-conducted RI/FS.
Therefore, when PRPs are conducting an RI/FS, this guidance
document must be used in conjunction with the "Interim
Guidance on PRP Participation in the RI/FS Process" (see
Appendix A).
1 -3
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(CERCLA). While SARA did not change the basic
structure of CERCLA, it did modify many of the
existing requirements and added new ones.
References made to CERCLA throughout this
document should be interpreted as meaning
"CERCLA as amended by SARA."
Many of the new provisions under CERCLA having
the greatest impact on the RI/FS process are
contained in §121 (Cleanup Standards). Other notable
changes that also affect the RI/FS process are
contained in §104 (Response Authorities, in particular
Health-Related Authorities), portions of §104 and
§121 regarding State involvement, §117 (Public
Participation), §110 (Worker Protection Standards),
and §113 (Civil Proceedings). Highlights of these
sections are summarized below.
1.3.1 Cleanup Standards
Section 121 (Cleanup Standards) states a strong
statutory preference for remedies that are highly
reliable and provide long-term protection. In addition
to the requirement for remedies to be both protective
of human health and the environment and cost-
effective, additional remedy selection considerations
in 5121 (b) include:
• A preference for remedial actions that employ
treatment that permanently and significantly
reduces the volume, toxicity, or mobility of
hazardous substances, pollutants, and
contaminants as a principal element
• Offsite transport and disposal without treatment is
the least favored alternative where practicable
treatment technologies are available
• The need to assess the use of permanent
solutions and alternative treatment technologies
or resource recovery technologies and use them
to the maximum extent practicable
Section 121 (c) also requires a periodic review of
remedial actions, at least every 5 years after initiation
of such action, for as long as hazardous substances,
pollutants, or contaminants that may pose a threat to
human health or the environment remain at the site. If
it is determined during a 5-year review that the
action no longer protects human health and the
environment, further remedial actions will need to be
considered.
1.3.1.1 Applicable or Relevant and Appropriate
Requirements
Section 121(d)(2)(A) of CERCLA incorporates into law
the CERCLA Compliance Policy, which specifies that
Superfund remedial actions meet any Federal
standards, requirements, criteria, or limitations that
are determined to be legally applicable or relevant
and appropriate requirements (ARARs). Also included
is the new provision that State ARARs must be met if
they are more stringent than Federal requirements.
Federal statutes that are specifically cited in CERCLA
include the Solid Waste Disposal Act (SWDA), the
Toxic Substances Control Act (TSCA), the Safe
Drinking Water Act (SDWA), the Clean Air Act (CAA),
the Clean Water Act (CWA), and the Marine
Protection Research and Sanctuaries Act (MPRSA).
Additional guidance on ARARs is provided in the
"CERCLA Compliance with Other Statutes" manual
(U.S. EPA, Draft, August 1988).
Section 121(d)(4) of CERCLA identifies six
circumstances under which ARARs may be waived:
• The remedial action selected is only a part of a
total remedial action (interim remedy) and the
final remedy will attain the ARAR upon its
completion.
• Compliance with the ARAR will result in a greater
risk to human health and the environment than
alternative options.
• Compliance with the ARAR is technically
impracticable from an engineering perspective.
• An alternative remedial action will attain an
equivalent standard of performance through the
use of another method or approach.
• The ARAR is a State requirement that the state
has not consistently applied (or demonstrated the
intent to apply consistently) in similar
circumstances.
• For §104 Superfund-financed remedial actions,
compliance with the ARAR will not provide a
balance between protecting human health and the
environment and the availability of Superfund
money for response at other facilities.
1.3.1.2 Offsite Facilities
The new statutory requirements contained in
§121 (d)(3) for acceptable offsite disposal facilities, in
most respects, incorporate previous Agency policy.
Offsite disposal facilities receiving contaminants must
be in compliance with Resource Conservation and
Recovery Act (RCRA) and other Federal and State
laws. In addition, the unit receiving the waste must
have no releases to ground water, surface water, or
soil; other units that have had releases at the facility
must be under an approved corrective action
program.
7.3.2 Health Assessments
Under CERCLA §104(i) (Health-Related Authorities),
the Agency for Toxic Substances and Disease
1 -4
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Registry (ATSDR) must conduct a health assessment
for every site proposed for inclusion on the NPL. The
purpose of these health assessments is to assist in
determining whether current or potential risk to
human health exists at a site and whether additional
information on human exposure and associated health
risks is needed. The health assessment is required to
be completed "to the maximum extent practicable"
before completion of the RI/FS.
7.3.3 State Involvement
Section 104(c)(3)(C) of CERCLA remains in effect
requiring a lo-percent State cost share for remedial
actions at privately operated sites and 50 percent at
publicly operated sites.'Section 104(c)(3)(A) and
104(c)(6) of CERCLA provide that the operation and
maintenance of ground- and surface-water
restoration measures be considered part of remedial
action for up to 10 years after commencement of
operations or until remedial action is complete,
whichever is earlier. Therefore, such activities during
the lo-year period would be eligible for either 50 or
90 percent Federal funding depending on whether the
site was publicly or privately operated.
Section 121(d)(2)(A) of CERCLA specifies that more
stringent State ARARs apply if they are identified in a
timely manner by the state. Section 121 (f) requires
EPA to develop regulations for substantial and
meaningful State involvement in the remedial
response process and specifies certain minimum
requirements.
1.3.4 Community Involvement
Section 117 of CERCLA (Public Participation)
emphasizes the importance of early, constant, and
responsive relations with communities affected by
Superfund sites and codifies, with some
modifications, current community relations activities
applied at NPL sites. Specifically, the law requires
publication of a notice of any proposed remedial
action (proposed plan) in a local newspaper of
general circulation and a "reasonable opportunity" for
the public to comment on the proposed plan and
other contents of the administrative record,
particularly the Rl and the FS. In addition, the public
is to be afforded an opportunity for a public meeting.
The proposed plan should include a brief explanation
of the alternatives considered, which will usually be in
the form of a summary of the FS. Unlike the FS,
however, the proposed plan will also provide an
explanation of the preliminary preference for one of
the options. Notice of the final plan adopted and an
explanation of any significant changes from the
proposed plan are also required. CERCLA also
authorizes technical assistance grants for local
citizens' groups potentially affected by an NPL site.
The grants are to be used in obtaining assistance in
interpreting information on the nature of hazards
posed by the site, the results of the RI/FS, any
removal actions, the Record of Decision (ROD), and
the remedial design and remedial action.
7.3.5 Administrative Record
Section 113 of CERCLA requires that an
administrative record be established "at or near the
facility at issue." The record is to be compiled
contemporaneously and must be available to the
public and include all information considered or relied
on in selecting the remedy, including public
comments on the proposed plan.
7.3.6 Worker Safety
Section 126(c) of CERCLA directed the Occupational
Safety and Health Administration (OSHA) to issue,
within 60 days of the date of enactment of SARA, an
interim final rule that contains employee protection
requirements for workers engaged in hazardous
waste operations. OSHA's interim final rule (29 CFR
1910.120) was published in the Federal Register on
December 19, 1986, with full implementation of this
rule required by March 16, 1987. The worker safety
rule will remain in effect until the final standard is
issued by OSHA and becomes effective.
7.3.7 Enforcement Authorities
Section 122(e) authorizes EPA to use "special
notice" procedures, which for an RI/FS, establishes a
60-day moratorium period to provide time for formal
negotiation between EPA and the PRPs for conduct
of the RI/FS activities. This 60-day period may be
extended to 90 days if within the 60-day time period,
the potentially responsible parties (PRPs) provide
EPA with a good faith offer to conduct or finance the
RI/FS.
SARA allows for administrative consent orders to be
signed using the authorities of Section 122(d)(3) as
pertaining to Section 104(b) without having to make a
finding of imminent and substantial endangerment.
Section 104(a)(l) outlines special requirements for a
PRP-lead RI/FS. These requirements include:
making the determination that a PRP is qualified to
perform the RI/FS; arranging for a third party to assist
in oversight of the RI/FS; and requiring that PRPs pay
for third party oversight.3
'Remedial planning activities for the RI/FS and remedial design
continue to be 100 percent federally funded.
'Specific guidance on PRP participation in the RI/FS process is
found in Appendix A. Detailed guidance on PRP oversight is
currently under preparation in the Office of Solid Waste and
Emergency Response (OSWER).
1 -5
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1.4 The RI/FS Process Under CERCLA
Although the new provisions of CERCLA have
resulted in some modifications to the RI/FS process,
the basic components of the process remain intact.
The Rl continues to serve as the mechanism for
collecting data to characterize site conditions;
determine the nature of the waste; assess risk to
human health and the environment; and conduct
treatability testing as necessary to evaluate the
potential performance and cost of the treatment
technologies that are being considered. The latter
also supports the design of selected remedies. The
FS continues to serve as the mechanism for the
development, screening, and detailed evaluation of
alternative remedial actions.
The various steps, or phases, of the RI/FS process
and how they have been modified to comply with the
new provisions in CERCLA are summarized below. It
is important to note that the Rl and FS are to be
conducted concurrently and that data collected in the
Rl influence the development of remedial alternatives
in the FS, which in turn affects the data needs and
scope of treatability studies and additional field
investigations. Two concepts are essential to the
phased RI/FS approach. First, data should generally
be collected in several stages, with initial data
collection efforts usually limited to developing a
general understanding of the site. As a basic
understanding of site characteristics is achieved,
subsequent data collection efforts focus on filling
identified gaps in the understanding of site
characteristics and gathering information necessary to
evaluate remedial alternatives. Second, this phased
sampling approach encourages identification of key
data needs as early in the process as possible to
ensure that data collection is always directed toward
providing information relevant to selection of a
remedial action. In this way the overall site
characterization effort can be continually scoped to
minimize the collection of unnecessary data and
maximize data quality.
Because of the interactive and iterative nature of this
phase of the Rl and FS process, the sequence of the
various phases and associated activities, as
described below and presented in Figure 1-1, will
frequently be less distinct in practice. A generic
timeline intended to illustrate the phasing of RI/FS
activities is presented in Figure 1-2. The actual
timing of individual activities will depend on specific
site situations.
1.4.1 Scoping
Scoping is the initial planning phase of the RI/FS
process, and many of the planning steps begun here
are continued and refined in later phases of the
RI/FS. Scoping activities typically begin with the
collection of existing site data, including data from
previous investigations such as the preliminary
assessment and site investigation. On the basis of
this information, site management planning is
undertaken to preliminarily identify boundaries of the
study area, identify likely remedial action objectives
and whether interim actions may be necessary or
appropriate, and to establish whether the site may
best be remedied as one or several separate
operable units. Once an overall management strategy
is agreed upon, the RI/FS for a specific project or the
site as a whole is planned. Typical scoping activities
include:
• Initiating the identification and discussion of
potential ARARs with the support agency
• Determining the types of decisions to be made
and identifying the data and other information
needed to support those decisions
• Assembling a "technical advisory committee" to
assist in these activities, to serve as a review
board for important deliverables, and to monitor
progress, as appropriate, during the study
• Preparing the work plan, the sampling and
analysis plan (SAP) (which consists of the quality
assurance project plan (QAPP) and the field
sampling plan (FSP)), the health and safety plan,
and the community relations plan
Chapter 2 describes the various steps in the scoping
process and gives general information on work-
planning methods that have been effective in planning
and executing past RI/FSs.
14.2 Site Characterization
During site characterization, field sampling and
laboratory analyses are initiated. Field sampling
should be phased"so that the results of the initial
sampling efforts can be used to refine plans
developed during scoping to better focus subsequent
sampling efforts. Data quality objectives are revised
as appropriate based on an improved understanding
of the site to facilitate a more efficient and accurate
characterization of the site and, therefore, achieve
reductions in time and cost.
A preliminary site characterization summary is
prepared to provide the lead agency with information
on the site early in the process before preparation of
the full Rl report. This summary will be useful in
determining the feasibility of potential technologies
and in assisting both the lead and support agencies
with the initial identification of ARARs. It can also be
4Emphasis is placed on rapid turnaround of sampling results to
avoid the need to remobilize and reprocure contractors.
1 -6
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REMEDIAL INVESTIGATION
SCOPING
OF THE RI/FS
•COLLECT* ANALYZE
EXISTING DATA
• IDENTIFY INITIAL
PROJECT/OPERABLE
UNIT. LIKELY RESPONSE
SCENARIOS. S
REMEDIAL ACTION
OBJECTIVES
•INITIATE FEDERAL/
STATE ARAR
IDENTIFICATION
•IDENTIFY INITIAL DATA
QUALITY OBJECTIVES
(DOOS)
•PREPARE PROJECT
PLANS
SITE CHARACTERIZATION
• CONDUCT FIELD
INVESTIGATION
• DEFINE NATURE S EXTENT OF
CONTAMINATION (WASTE
TYPES, CONCENTRATIONS,
DISTRIBUTIONS)
• IDENTIFY FEDERAL/STATE
CHEMICAL-4 LOCATION -
SPECIFIC ARAR»
• CONDUCT BASELINE RISK
ASSESSMENT
TREATABILITY
INVESTIGATIONS
• PERFORM BENCH OR PILO1
TREATABILITY TESTS AS
NECESSARY
FEASIBILITY
STUDY
DEVELOPMENT AND SCREENING
OF ALTERNATIVES
IDENTIFY POTENTIAL
TREATMENT TECHNOLOGIES
CONTAINMENT/DISPOSAL
REQUIREMENTS FOR
RESIDUALS OR UNTREATED
WASTE
SCREEN TECHNOLOGIES
ASSEMBLE TECHNOLOGIES
INTO ALTERNATIVES
•SCREEN ALTERNATIVES
AS NECESSARY
TO REDUCE NUMBER
SUBJECT TO DETAILED
ANALYSIS
•PRESERVE AN
APPROPRIATE RANGE Of
OPTIONS
•IDENTIFY
ACTION-SPECIFIC ARAHS
DETAILED ANALYSIS
OF ALTERNATIVES
•FURTHER REFINE
ALTERNATIVES AS
NECESSARY
•ANALYZE ALTERNATIVES
AGAINST THE NINE CRITERIA
•COMPARE ALTERNATIVES
AGAINST EACH OTHER
TO:
•REMEDY SELECT!ON
•RECORDOF DECISION
•REMEDIAL DESIGN
•REMEDIAL ACTION
Figure 1-1. Phased RI/FS Process.
sent to ATSDR to assist them in performing their
health assessment of the site.
A baseline risk assessment is developed to identify
the existing or potential risks that may be posed to
human health and the environment by the site. This
assessment also serves to support the evaluation of
the no-action alternative by documenting the threats
posed by the site based on expected exposure
scenarios. Because this assessment identifies the
primary health and environmental threats at the site, it
also provides valuable input to the development and
evaluation of alternatives during the FS. Site
characterization activities are described in Chapter 3.
1.4.3 Development and Screening of
Alternatives
The development of alternatives usually begins during
or soon after scoping, when likely response scenarios
may first be identified. The development of
alternatives requires (1) identifying remedial action
objectives; (2) identifying potential treatment,
resource recovery, and containment technologies that
will satisfy these objectives; (3) screening the
technologies based on their effectiveness,
implementability, and cost; and (4) assembling
technologies and their associated containment or
disposal requirements into alternatives for the
contaminated media at the site or for the operable
unit. Alternatives can be developed to address
contaminated medium (e.g., ground water), a specific
area of the site (e.g., a waste lagoon or contaminated
hot spots), or the entire site. Alternatives for specific
media and site areas either can be carried through
the FS process separately or combined into
comprehensive alternatives for the entire site. The
approach is flexible to allow alternatives to be
combined at various points in the process.
As practicable, a range of treatment alternatives,
should be developed, varying primarily in the extent to
which they rely on long-term management of
residuals and untreated wastes. The upper bound of
the range would be an alternative that would
eliminate, to the extent feasible, the need for any
long-term management (including monitoring) at the
site. The lower bound would consist of an alternative
that involves treatment as a principal element (i.e.,
treatment is used to address the principal threats at
1-7
-------
SCOPING
Analyze L"™
CoieclCUla Pan Neeos Prepare SAP Agency Review
I III OAPP/FSP I I
IDPreHrnARAHs
lOPraemRA
Prepare HSP
_ Prepare CRP'
' Prepare WP J
T^LTJL.~ ~R«idlro«tte«lim DatlLa'b Sle Data"" Additon.19«s~Cnaraa»rtl.»or7 ~RI
Umnedssrnplng Analysis Characterliallon Review (rlrequlred) Report
SITE CHARACTERIZATION (Ootanal) Risk Assessment.
ErMronmental
I I
PSCS Report IDfRevlseAnAH
Scoplngof W"** RanBench/ BenchCTot Snxtos
lnvestiiia'A^ l'Vyort'dra<'1
ao
Figure 1-2. Generic Phased RI/FS Timeline.
-------
the site), but some long-term management of
portions of the site that did not constitute "principal
threats" would be required. Between the upper and
lower bounds of the treatment range, alternatives
varying in the type and degrees of treatment and
associated containment/ disposal requirements should
be included as appropriate. In addition, one or more
containment option(s) involving little or no treatment
should be developed as appropriate, and a no-action
alternative should always be developed.
Once potential alternatives have been developed, it
may be necessary to screen out certain options to
reduce the number of alternatives that will be
analyzed in detail in order to minimize the resources
dedicated to evaluating options that are less
promising. The necessity of this screening effort will
depend on the number of alternatives initially
developed, which will depend partially on the
complexity of the site and/ or the number of available,
suitable technologies. For situations in which it is
necessary to reduce the initial number of alternatives
before beginning the detailed analysis, a range of
alternatives should be preserved, as practicable, so
that the decisionmaker can be presented with a
variety of distinct, viable options from which to
choose. The screening process involves evaluating
alternatives with respect to their effectiveness,
implementability, and cost. It is usually done on a
general basis and with limited effort (relative to the
detailed analysis) because the information necessary
to fully evaluate the alternatives may not be complete
at this point in the process. The development and
screening of alternatives is discussed in Chapter 4.
1.4.4 Treatability Investigations
Should existing site and/or treatment data be
insufficient to adequately evaluate alternatives,
treatability tests may be necessary to evaluate a
particular technology on specific site wastes.
Generally, treatability tests involve bench-scale
testing to gather information to assess the feasibility
of a technology. In a few situations, a pilot-scale
study may be necessary to furnish performance data
and develop better cost estimates so that a detailed
analysis can be performed and a remedial action can
be selected. To conduct a pilot-scale test and keep
the RI/FS on schedule, it will usually be necessary to
identify and initiate the test at an early point in the
process. Treatability investigations are described in
Chapter 5.
7.4.5 Detailed Analysis
Once sufficient data are available, alternatives are
evaluated in detail with respect to nine evaluation
criteria that the Agency has developed to address the
statutory requirements and preferences of CERCLA.
The alternatives are analyzed individually against
each criterion and then compared against one
another to determine their respective strengths and
weaknesses and to identify the key tradeoffs that
must be balanced for that site. The results of the
detailed analysis are summarized and presented to
the decisionmaker so that an appropriate remedy
consistent with CERCLA can be selected. The
detailed analysis of alternatives is described in
Chapters.
1.5 Special Sites
The use of treatment technologies and, therefore, the
development of a complete range of options, may not
be practicable at some sites with large volumes of
low concentration wastes (e.g., large municipal
landfills or mining sites). Remedies involving
treatment at such sites may be prohibitively
expensive or difficult to implement. Therefore, the
range of alternatives initially developed may be
focused primarily on various containment options.
Although this guidance does not specifically state how
all such sites should be addressed, factors are
discussed that can be used, as appropriate, to help
guide the development and evaluation of alternatives
on a case-by-case basis.
1.6 Community Relations
Community relations is a useful and important aspect
of the RI/FS process. Community relations activities
serve to keep communities informed of the activities
at the site and help the Agency anticipate and
respond to community concerns. A community
relations plan is developed for a site as the work plan
for the RI/FS is prepared. The community relations
plan is based on interviews with interested people in
the community and will provide the guidelines for
future community relations activities at the site. At a
minimum, the plan must provide for a site mailing list,
a conveniently located place for access to all public
information about the site, an opportunity for a public
meeting when the RI/FS report and proposed plan are
issued, and a summary of public comments on the
RI/FS report and proposed plan and the Agency's
response to those comments.
The specific community relations requirements for
each phase of the RI/FS are integrated throughout
this guidance document since they are parallel to and
support the technical activities. Each chapter of this
guidance has a section discussing community
relations requirements appropriate to that specific
phase of the RI/FS. Additional program requirements
are described in the draft of Community Relations in
Superfund: A Handbook (U.S. EPA, Interim, June
1988).
1.7 Lead and Support Agency
Throughout this guidance the terms "lead agency"
and "support agency" are used to reflect the fact that
1 -9
-------
either EPA or a State or Federal facility can have the
lead responsibility for conducting an RI/FS. The
support agency plays a review and concurrence role
and provides specific information as necessary to the
lead agency (e.g., ARAR identification). The roles of
the lead and support agencies in each phase of the
RI/FS process are described at the end of each
chapter.
1.8 Remedial Project Manager Role and
Responsibilities
The Remedial Project Manager's (RPM's) role in
overseeing an RI/FS involves, to a large extent,
ensuring that the work progresses according to the
priorities and objectives established during site
management and project planning. This role requires
planning project scopes early and deriving cost
estimates for the specific tasks and activities
described in the Statement of Work (SOW).5It is the
RPM's responsibility to develop realistic cost
estimates, monitor and control contractor
expenditures, and manage changing site conditions
within the allocated budget. The RPM facilitates the
interactions among EPA staff, State representatives,
contractor personnel, PRPs, and the public to ensure
that all involved parties are aware of their roles and
responsibilities. Throughout the following chapters,
and particularly in the discussions of scoping
(Chapter 2) and site characterization (Chapter 3),
suggestions are provided to guide the RPM in
developing approaches for conducting RI/FSs so that
high-quality deliverables are produced in a timely
and cost-effective manner. Additional suggestions
specific to management of RI/FSs may be found in
the Superfund Federal-Lead Remedial Project
Management Handbook (U.S. EPA, December 1986)
and Superfund State-Lead Remedial Project
Management Handbook (U.S. EPA, December 1986).
Oversight responsibilities for PRP-lead RI/FSs are
outlined in Appendix A of this guidance.
5OSWER is developing cost estimating guides and a reference
document for use by RPMs that will provide historical averages
for the cost of the various RI/FS tasks.
1 - 10
-------
CHAPTER 2
SCOPING OF THE RI/FS
FROM:
• Preliminary
Assam me nt
• Ste Inspection
• NPL Listing
SITE
CHARACTERIZATION
TREATABILITV
INVESTIGATIONS
DEVELOPMENT AND SCREENING
OF ALTERNATIVES
DETAILED ANALYSIS
OF ALTERNATIVES
• Remedy Selection
• Record of Decision
• Remedial Design
• Remedial Action
SCOPING
OF THE RI/FS
•Evaluate Existing Data
• Develop Conceptual Site
Model
• Identify Initial Project/
Operable Unit, Likely
Response Scenarios &
Remedial Action Objectives
• Initiate Potential Federal/
State ARARs
Identification
• Identify Initial Data Quality
Objectives (DQOs)
• Prepare Project Plans
2-1
-------
Chapter 2
Scoping the RI/FS
2.1 Introduction
Scoping is the initial planning phase of site
remediation and is begun, at least informally, by the
lead agency's RPM as part of the funding allocation
and planning process. The lead and support agencies
should meet and, on the basis of available
information, begin to (1) identify the types of actions
that may be required to address site problems; (2)
identify whether interim actions are necessary or
appropriate to mitigate potential threats, prevent
further environmental degradation, or rapidly reduce
risks significantly, and (3) identify the optimal
sequence of site actions and investigative activities.
Once the lead and support agencies initially agree on
a general approach for managing the site, the next
step is to scope the projects) and develop specific
project plans. Project planning is done to:
• Determine the types of decisions to be made
• Identify the type and quality of data quality
objectives (DQOs) needed to support those
decisions
• Describe the methods by which the required data
will be obtained and analyzed
• Prepare project plans to document methods and
procedures
The activities described above relate directly to the
establishment of DQOs - statements that specify the
type and quality of the data needed to support
decisions regarding remedial response activities. The
establishment of DQOs is discussed in detail in Data
Qualify Objectives for Remedial Response Activities
(U.S. EPA, March 1987, hereafter referred to as the
DQO Guidance).
The ability to adequately scope a specific project is
closely tied to the amount and quality of available
information. Therefore, it is important to note that the
scope of the project and, to some extent the specific
project plans, are developed iteratively (i.e., as new
information is acquired or new decisions are made,
data requirements are reevaluated and, if appropriate,
project plans are modified). In this way, scoping helps
to focus activities and streamline the RI/FS, thereby
preventing needless expenditures and loss of time in
unnecessary sampling and analyses.
Figure 2-I shows the key steps in the scoping
process.1
2.2 Project Planning
Once a general site management approach has been
agreed upon, planning can begin for the scope of a
specific project. The specific activities conducted
during project planning include:2
• Meeting with lead agency, support agency, and
contractor personnel to discuss site issues and
assign responsibilities for RI/FS activities
• Collecting and analyzing existing data to develop
a conceptual site model that can be used to
assess both the nature and the extent of
contamination and to identify potential exposure
pathways and potential human health and/or
environmental receptors
• Initiating limited field investigations if available
data are inadequate to develop a conceptual site
model and adequately scope the project
• Identifying preliminary remedial action objectives
and likely response actions for the specific project
• Preliminarily identifying the ARARs expected to
apply to site characterization and site remediation
activities
• Determining data needs and the level of analytical
and sampling certainty required for additional data
'See Appendix A for a delineation of responsibilities between
the lead agency and the PRPs during the scoping process.
2 For a PRP-lead RI/FS the PRPs are typically responsible for
these activities except for conducting community interviews.
This responsibility rests with the lead agency. Specific activities
performed by the PRPs during scoping are determined during
the negotiation period and should be specified in the
agreement between the PRPs and the lead agency.
2-3
-------
Collect Community
Relations Data
- Conduct Community
Interviews
Develop CR Objectives
and Techniques
Prepare CR Plan
Collect/Evaluate Existing
Data To
- Develop Conceptual Site
Model
- Identify Data Needs
Is
Limited Field
Investigation
Needed To
Plan Specific
Projects)?
Identify Preliminary
Remedial Action
Alternatives
- Identify Potential
Technologies
- Begin Review
of Technologies
- Identify Likely
Alternatives
- Identify Need for
Treatablllty Studies
Initiate Discussion of
Chemical- and Location-
Specific ARARs
Begin Preliminary
Identification
of Action-Specific ARARs
Identify Data Quality Objectives
- Site Characterization
- Risk Assessment
- Treatablllty Studies
Identify Data Needs
for Evaluation of
Alternatives
Develop Sampling Strategies
and Analytical Support. Health
and Safety Protocols
Describe Data Analysis
Methods
Define Rl and FS Tasks
Prepare Rl/FS Work Plan
- Prepare HSP
- Prepare SAP
Site
Characterization
Development
of Alternatives
Figure 2-1. Scoping.
2-4
-------
if currently available data are inadequate to
conduct the FS
• Identifying the need and the schedule for
treatability studies to better evaluate potential
remedial alternatives
• Designing a data collection program to describe
the selection of the sampling approaches and
analytical options. (This selection is documented
in the SAP, which consists of the FSP and QAPP
elements.)
• Developing a work plan that documents the
scoping process and presents anticipated future
tasks
• Identifying and documenting health and safety
protocols required during field investigations and
preparing a site health and safety plan
• Conducting community interviews to obtain
information that can be used to develop a site-
specific community relations plan that documents
the objectives and approaches of the community
relations program
2.2.7 Conduct Project Meeting
To begin project planning, a meeting should be held
involving key management from the lead and support
agencies. The purpose of this meeting is to allow key
personnel to become involved in initial planning
decisions and give them the opportunity to discuss
any special concerns that may be associated with the
site. Furthermore, this meeting should set a
precedent for the involvement of key personnel
periodically throughout the project. Additional
attendees should include contractor personnel who
will be conducting the RI/FS and performing the risk
assessment, Natural Resource Trustee
representatives, when applicable, and individuals with
prior experience at the site [e.g., the field
investigation team (FIT)] or other similar sites who
may be able to provide additional insight into effective
techniques for addressing potential site problems.
2.2.2 Collect and Analyze Existing Data
Before the activities necessary to conduct an RI/FS
can be planned, it is important to compile the
available data that have previously been collected for
a site. These data can be used to determine the
additional work that needs to be conducted both in
the field and within the community. A thorough search
of existing data should help avoid duplication of
previous efforts and lead to a remedial investigation
that is more focused and, therefore, more efficient in
its expenditure of resources.
Information describing hazardous waste sources,
migration pathways, and human and environmental
receptors for a given site is available from many
sources. Some of the more useful sources are listed
in Table 2-1. Site investigation (SI) data'gathered in
the hazard ranking process (the process by which a
site is listed on the NPL) may be located in files
maintained by the EPA Regional offices, the FIT, the
technical assistance team (TAT), contractors, and the
state.
Data relating to the varieties and quantities of
hazardous wastes disposed of at the site should be
compiled. The results from any previous sampling
events should be summarized in terms of physical
and chemical characteristics, contaminants identified,
and their respective concentrations. Results of
environmental sampling at the site should be
summarized, and evidence of soil, ground water,
surface water, sediment, air, or biotic contamination
should be documented. If available, information on the
precision and accuracy of the data should be
included.
Records of disposal practices and operating
procedures at the site, including historical
photographs, can be reviewed to identify locations of
waste materials onsite, waste haulers, and waste
generators. If specific waste records are absent,
waste products that may have been disposed of at
the site can be identified through a review of the
manufacturing processes of the waste generators.
A summary of existing site-specific and regional
information should be compiled to help identify
surface, subsurface, atmospheric, and biotic migration
pathways. Compiled information should include
geology, hydrogeology, hydrology, meteorology, and
ecology. Regional information can help to identify
background soil, water, and air quality characteristics.
Data on human and environmental receptors in the
area surrounding the site should be compiled.
Demographic and land use information will help
identify potential human receptors. Residential,
municipal, or industrial wells should be located, and
surface water uses should be identified for
surrounding areas and areas downstream of the site.
Existing information describing the common flora and
fauna of the site and surrounding areas should be
collected. The location of any threatened,
endangered, or rare species, sensitive environmental
areas, or critical habitats on or near the site should be
identified. Available results from any previous
biological testing should be compiled to document
3The expanded site investigation (ESI) conducted by the pre-
remedial program will provide valuable data (e.g., geophysics,
surveys, well inventories) and should serve as an important
source of information during the scoping process for
establishing the hypotheses to be tested concerning the nature
and extent of contamination.
2-5
-------
Table 2-1. Data Collection Information Sources
to
I
en
Information Source
U.S. EPA Files
U.S. Geological Survey
U.S. DOA, Soil Conservation Service
U.S. DOA, Agricultural Stabilization and Conservation
Service
U.S. DOA, Forest Service
U.S. DOI, Fish and Wildlife Agencies
U.S. DOI, Bureau of Reclamation
U.S. Army Corps of Engineers .
Federal Emergency Management Agency
U.S. Census Bureau
National Oceanic and Atmospheric Administration
State Environmental Protection or Public Health Agencies
State Geological Survey
State Fish and Wildlife Agencies
Local Planning Boards
County or City Health Departments
Town Engineer or Town Hall
Local Chamber of Commerce
Local Airport
Local Library
Local Well Drillers
Sewage Treatment Plants
Local Water Authorities
City Fire Departments
Regional Geologic and Hydrologlc Publications
Court Records of Legal Action
Department of Justice Flics
State Attorney General Files
Facility Records
Facility Owners and Employees
Citizens Residing Near Sltec
Waste Haulers and Generators0
Site Visit Reports
Photographs
Preliminary Assessment Report
Field Investigation Analytical Data
FIT/TAT Reports
Site Inspection Report
HRS Scoring Package
EMSL/EPIC (Environmental Monitoring Support Laboratory/
Environmental Photographic Information Center)
Haste
Sources
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Migration
Subsurface
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Pathways
Surface
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Air
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Receptors
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
"includes county soil survey reports from Soil Conservation Service, U.S. DOA.
The Federal Emergency Management Agency publishes floodplain maps.
Interviews require lead agency concurrence.
-------
any known ecological effect such as acute or chronic
toxicity or bioaccumulation in the food chain.
Once the available data have been collected, they are
analyzed to (1) establish the physical characteristics
of a site to help determine the scope of future
sampling efforts; and (2) conceptually model potential
exposure pathways and receptors to assist in the
preliminary assessment of risk and the initial
identification of potential remedial technologies. Each
of these uses is discussed below.
sources of contamination, types of contaminants and
affected media, known and potential routes of
migration, and known or potential human and
environmental receptors. This effort, in addition to
assisting in identifying locations where sampling is
necessary, will also assist in the identification of
potential remedial technologies. Additional information
for evaluating exposure concerns through the use of
a conceptual model is provided in the D Q O
Guidance. An example of a conceptual model is
provided in Figure 2-2.
2.2.2.1 Establish Physical Characteristics of the
Site
The analysis of existing data serves to' provide a
better understanding of the nature and extent of
contamination and aids in the design of remedial
investigation tasks. If quality assurance information on
existing sampling data is available, it should be
reviewed to assess the level of uncertainty associated
with the data. This is important to establish whether
sampling will be needed to verify or simply
supplement existing data. Important factors to
consider when reviewing existing data are the
comparability of the data (e.g., time of sampling), the
analytical methods, the detection limits, the analytical
laboratories, and the sample collection and handling
methods.4
Existing data should be used to develop a site
description, which should include location, ownership,
topography, geology, land use, waste type, estimates
of waste volume, and other pertinent details. The site
description should also include a chronology of
significant events such as chemical storage and
disposal practices, previous site visits, sampling
events, regulatory violations, legal actions, and
changes in ownership. In addition, information
concerning previous cleanup actions, such as
removal of containerized waste, is often valuable for
determining the characteristics of any wastes or
contaminated media remaining at the site. All sources
of information or data should be summarized in a
technical memorandum or retained for inclusion in the
Rl report.
2.2.2.2 Develop a Conceptual Site Model
Information on the waste sources, pathways, and
receptors at a site is used to develop a conceptual
understanding of the site to evaluate potential risks to
human health and the environment. The conceptual
site model should include known and suspected
2.2.2.3 Determine the Need for and Implement
Limited Additional Studies
If the conceptual understanding of a site is poor and
the collection of site-specific data would greatly
enhance the scoping effort, a limited field
investigation may be undertaken as an interim
scoping task prior to developing the work plan.5
Normally, the investigation is limited to easily obtain-
able data, where results can be achieved in a short
time. Examples of tasks are as follows:
• Preliminary geophysical investigations
• Residential, industrial, and agricultural well
sampling and analysis
• Measurement of well-water level, sampling (only
for pre-existing monitoring wells), and analysis
• Limited sampling to determine the need for waste
treatability studies
• Air monitoring
• Site mapping
• Preliminary ecological reconnaissance
2.2.3 Develop Preliminary Remedial Action
Alternatives
Once the existing site information has been analyzed
and a conceptual understanding of the site is
obtained, potential remedial action objectives should
be identified for each contaminated medium (Chapter
4 presents examples of remedial action objectives)
and a preliminary range of remedial action alternatives
and associated technologies should be identified. This
identification is not meant to be a detailed
investigation of alternatives. Rather, it is intended to
be a more general classification of potential remedial
actions based upon the initially identified potential
routes of exposure and associated receptors. The
identification of potential technologies at this stage will
help ensure that data needed to evaluate them (e.g.,
4 Regardless of the origin and quality of existing data,
they typically are useful in constructing hypotheses
concerning the nature and extent of contamination.
5The specific procedures for initiating limited field
investigation will be dependent on the lead agency's
administrative and contractual requirements.
2-7
-------
PATHWAY
RECEPTOR
HUMAN BIOTA
ro
I
oo
SOURCES
Drums
and
Tanks
Structures,
Drums, Tanks,
Lagoon
,
/
\'
RELEASE
MECHANISM
Spills
Overtopping
1
1
SOURCES
Soil
RELEASE
MECHANISM
Dust and/or
„ Volatile
^ Emissions
Storm-
Runoff
Wind
Ground Wate
VA/atar anri
Sediments
i
*
r
EXPOSURE
ROUTE
Ingestion
Inhalation
Dermal
contact
Ingesdon
Dermal
contact
Ingestion
Inhalation
Dermal
contact
Ingestion
Inhalation
Dermal
Dermal
contact
Area
Residents
•
•
•
•
•
•
•
•
Site
Visitors
•
t
•
•
•
•
•
Terrestrial
•
•
•
•
•
Aquatic
•
•
Figure 2-2. Example Conceptual Site Model.
-------
Btu value of wastes to evaluate thermal destruction
capabilities) can be collected as early as possible. In
addition, the early identification of technologies will
allow earlier determinations as to the need for
treatability studies.
Technologies that may be appropriate for treating or
disposing of wastes should be identified along with
sources of literature on the technologies'
effectiveness, applications, and cost. Further
assistance in the investigation of technologies is
provided in the Technology Screening Guide for
Treatment of CERCLA Soils and Sludges (U.S. EPA,
September 1988). Innovative technologies and
resource recovery options should be included if they
appear feasible.
To the extent practicable, a preliminary list of broadly
defined alternatives should be developed that reflects
the goal of presenting a range of distinct, viable
options to the decision-maker. This list would
therefore include as appropriate a range of
alternatives in which treatment that significantly
reduces the toxicity, mobility, or volume of waste is a
principal element; one or more alternatives that
involve containment with little or no treatment; and a
no-action alternative. The list should be limited to
only those alternatives that are relevant and carry
some significant potential for being implemented at
the site. In this way, the preliminary identification of
remedial actions will allow an initial identification of
ARARs and will help focus subsequent data-
gathering efforts.
Involvement of the various agencies at this time will
help in identifying remedial alternatives and scoping
field activities. The development of alternatives is
described in more detail in Chapter 4 of this
document.
2.2.4 Evaluate the Need for Treatability Studies
If remedial actions involving treatment have been
identified for a site, then the need for treatability
studies should be evaluated as early as possible in
the RI/FS process. This is because many treatability
studies, especially pilot testing, may take several
months or longer to complete. If a lengthy study is
required and is not initiated early, completion of the
FS may be delayed.
The initial activities of treatability testing include
researching other potentially applicable data,
designing the study, and procuring vendors and
equipment. As appropriate, these activities should
occur concurrently with site characterization efforts so
that if it is determined that a potential technology is
not feasible, planned treatability activities for this
technology can be terminated. Chapter 5 provides
guidance on scoping treatability studies.
2.2.5 Begin Preliminary Identification of
ARARs and To Be Considered (TX)
Information
A preliminary identification of potential ARARs and
TBC information in the scoping phase can assist in
initially identifying remedial alternatives and is useful
for initiating communications with the support agency
to facilitate the identification of ARARs. Furthermore,
early identification of potential ARARs will allow better
planning of field activities.'Because of the iterative
nature of the RI/FS process, ARAR identification
continues throughout the RI/FS as a better
understanding is gained of site conditions, site
contaminants, and remedial action alternatives.
ARARs may be categorized as chemical-specific
requirements that may define acceptable exposure
levels and therefore be used in establishing
preliminary remediation goals; as location-specific
requirements that may set restrictions on activities
within specific locations such as floodplains or
wetlands; and as action-specific, which may set
controls or restrictions for particular treatment and
disposal activities related to the management of
hazardous wastes. The document, "CERCLA
Compliance with Other Laws Manual" (U.S. EPA,
Draft, May 1988) contains detailed information on
identifying and complying with ARARs.
Potential chemical- and location-specific ARARs
are identified on the basis of the compilation and
evaluation of existing site data. A preliminary
evaluation of potential action-specific ARARs may
also be made to assess the feasibility of remedial
technologies being considered at this time. In addition
to federal ARARs, more stringent state ARARs must
also be identified. Other federal and state criteria,
advisories, and guidance and local ordinances should
also be considered, as appropriate, in the
development of remedial action alternatives.
For documentation purposes, a list should be
maintained of potential ARARs as they are identified
for a site. As the RI/FS progresses, each ARAR will
need to be defined. The assistance of the appropriate
support agency should be sought in identifying
support agency ARARs and confirming their
applicability or relevance and appropriateness.
2.2.6 Identify Data Needs
The identification of data needs is the most important
part of the scoping process. Data needs are identified
by evaluating the existing data and determining what
additional data are necessary to characterize the site,
develop a better conceptual understanding of the site,
6 In addition, compliance with certain environmental statutes
(e.g., the National Historic Preservation Act) is simplified by
early consultation with the responsible Federal agency.
2-9
-------
better define the ARARs, narrow the range of
remedial alternatives that have been identified, and
support enforcement activities.
The need for additional site data is evaluated relative
to meeting the site-specific RI/FS objectives. In
general, the RI/FS must obtain data to define source
areas of contamination, the potential pathways of
migration, and the potential receptors and associated
exposure pathways to the extent necessary to:
• Determine whether, or to what extent, a threat to
human health or the environment exists
•Develop and evaluate remedial alternatives
(including the no-action alternative)
• Support future enforcement or cost-recovery
activities
If additional data are needed, the intended uses of the
data are identified, strategies for sampling and
analyses are developed, DQOs are established, and
priorities are assigned according to the importance of
the data in meeting the objectives of the RI/FS.
The possible uses of the data include the following:
• Monitoring during implementation
• Health and safety planning
• Site characterization
• Risk assessment
• Evaluating alternatives
• Determining the PRP
• Engineering the design of alternatives
A more complete description of the data uses and
their appropriate analytical levels (Figure 2-3) can be
found in the DQO Guidance.
Setting priorities for data use helps to determine the
highest level of confidence required for each type of
data. For example, additional data on soil
contamination may be necessary for all the uses
listed above but may be of highest priority for risk
assessment and evaluation alternatives. Within these
two use categories, the evaluation of alternatives may
require a much greater level of confidence in the
contaminant types and concentrations on site so that
cost estimates for treatment can be prepared to meet
or approach the goal of a + 50 percent/-30 percent
accuracy level. As a result, data needs specifying the
level of allowable uncertainty would be set for the
evaluation of alternatives use category and would
therefore provide an acceptable level of confidence
for the remaining data uses.
Sensitivity analyses may be useful in evaluating the
acceptable level of uncertainty in data. Critical
parameters in any of the use categories can be varied
over a probable range of values that were identified in
the conceptual site model and that determine the
effect on meeting the RI/FS objectives. For example,
preliminary treatment costs for contaminated soil can
be calculated for various contaminant types and
volumes. The sensitivity that contaminant volume and
type has on treatment cost can be assessed so that
sufficient site characterization data are collected to
allow costing of treatment alternatives during the FS
using a goal of +50 percent/-30 percent cost
accuracy.
In the development of data requirements, time and
resource constraints must be balanced with the
desired confidence level of the data. The turnaround
time necessary for certain analytical procedures may,
in some cases, preclude achieving the original level
of confidence desired.
Likewise, resource constraints such as the availability
of a laboratory, sampling and analysis equipment, and
personnel may also influence the determination of
data requirements. Because of the high cost of
sampling and analysis for contaminants on the
hazardous substances list, data acquisition should be
focused only on the data quality and quantity
necessary and sufficient to meet the RI/FS objectives.
It is also important to do any necessary logistical
planning once data needs are identified. For example,
if it will be necessary to acquire aerial photographs to
adequately evaluate a site, it should be noted early in
the process so that the acquisition can begin early.
2.2.7 Design a Data Collection Program
Once the level of confidence required for the data is
established, strategies for sampling and analysis can
be developed. The identification of sampling
requirements involves specifying the sampling design;
the sampling method; sample numbers, types, and
locations;, and the level of sampling quality control.
Data may be collected in multiple sampling efforts to
use resources efficiently, and the level of accuracy
may increase as the focus of sampling is narrowed.
The determination of analytical requirements involves
specifying the most cost-effective analytical method
that, together with the sampling methods, will meet
the overall data needs for the RI/FS. Data quality
requirements specified for sampling and analysis
include precision, accuracy, representativeness,
completeness, and comparability.
A description of the methods to be used in analyzing
data obtained during the Rl should be included in a
SAP. The level of detail possible in defining the data
evaluation tasks will depend on the quality of the site
conceptual model. If the site is well understood, data
evaluation techniques should be specified and
2-10
-------
DATA USES
ANALYTICAL LEVEL
TYPE OF ANALYSIS
Site Characterization
Monitoring During
Implementation
LEVEL I
• Total Organic/Inorganic
Vapor Detection Using
Portable Instruments
• Field Test Kits
Site Characterization
Evaluation of Alternatives
Engineering Design
Monitoring During
Implementation
LEVEL II
• Variety of Organ ics by
GC; Inorganics by AA;
XRF
•Tentative ID; Analyte-
Specific
• Detection Limits Vary
from Low ppm to Low
ppb
Risk Assessment
PRP Determination
Site Characterization
Evaluation of Alternatives
Engineering Design
Monitoring During
Implementation
LEVEL III
• Organics/lnorganics
Using EPA Procedures
other than CLP can be
Analyte-Specific
• RCRA Characteristic
Tests
Risk Assessment
PRP Determination
Evaluation of Alternatives
Engineering Design
LEVEL IV
• HSL Organics/lnorganics
by GC/MS; AA; ICP
•Low ppb Detection Limit
Risk Assessment
PRP Determination
LEVEL V
• Non-Conventional
Parameters
• Method-Specific
Detection Limits
• Modification of
Existing Methods
• Appendix 8 Parameters
Figure 2-3. Summary of analytical levels appropriate to data uses.
described. This information is especially important if
numerical modeling is anticipated. If little existing
information is available, the task descriptions may be
very general, since it may not be clear which data
evaluation techniques will be appropriate. If
information is lacking, descriptions of potential
evaluation techniques could be included, and in
addition to describing site characterization techniques,
methods to be used in the risk assessment also
should be described.
2-1 1
-------
2.2.8 Develop a Work Plan
Tasks to be conducted during the RI/FS should be
identified and documented in a work plan. Although
this work plan will constitute the planning through the
completion of the RI/FS, the level of detail with which
specific tasks can be described during scoping will
depend on the amount and quality of existing data.
Therefore, in situations in which additional data are
needed to adequately scope the development and
evaluation of alternatives, emphasis should be placed
on limiting the level of detail used to describe these
subsequent tasks and simply noting that the scope of
these activities will be refined later in the process.
This will reduce the time needed to prepare and
review the initial work plan. As the RI/FS process
progresses and a better understanding of the site is
gained, these task descriptions can be refined. The
preliminary descriptions of tasks needed to complete
the RI/FS should be documented in the work plan and
can be used as a basis for scheduling and estimating
the RI/FS budget.
2.2.9 Identify Health and Safety Protocols
Protecting the health and safety of the investigative
team and the general public is a major concern during
remedial response actions. Workers may be exposed
to a variety of hazards including toxic chemicals,
biological agents, radioactive materials, heat or other
physical stresses, equipment-related accidents, and
fires or explosions. The surrounding community may
be at increased risk from unanticipated chemical
releases, fires, or explosions created by onsite
activities. In recognition of these concerns, OSHA has
published regulations that stress the importance both
of an underlying health and safety program and of
site-specific safety planning. The following is a list of
documents that contain regulations pertaining to
workers at hazardous waste sites:
• American National Standards, Practices for
Respiratory Protection (American National
Standards Institute, 1980)
• Guidance Manual for Superfund Activities,
Volumes I-9 (National Institute for Occupational
Safety and Health, 1985)
• Occupational Health Guidelines for Chemical
Hazards (National Institute for Occupational
Safety and Health, 1981)
• Safety Manual for Hazardous Waste Site
Investigations (U. S. EPA, 1979)
• Interim Standard Operating Safety Guides (U.S.
EPA, 1982)
• Occupational Safety and Health Guidance Manual
for Hazardous Waste Site Activities
(NIOSH/OSHA/USCC/USEPA, 1985)
• NIOSH/OSHA Pocket Guide to Chemical Hazards
(National Institute for Occupational Safety and
Health, 1978)
• National fire Codes (National Fire Protection
Association, 1981)
2.2.10 Conduct Community Interviews
The community relations staff members, which can
be either lead agency or contractor personnel and
technical staff, should work together during the
scoping process so that there is sufficient information
to conduct community interviews. Community
relations staff members then meet with the identified
groups or individuals to gain an understanding of the
site's history and the community's involvement with
the site from the community's perspective. The lead
agency will determine on a site-specific basis the
type and number of interviews that need to be
conducted to obtain sufficient information to develop
an effective community relations plan. The results of
the interviews should be made available to all
technical staff members to assist in identifying
potential waste types and disposal practices, potential
pathways of contamination, and potential receptors.
On the basis of an understanding of the issues and
concerns of the community, the community relations
history, and the citizens' indicated preferences for
how they would like to be informed concerning site
activities, the community relations plan is prepared.
Plans should provide opportunities for public input
throughout the remedial planning process as
appropriate.
2.3 Deliverables and Communication
There are several points during the scoping process
when communication is required between the lead
agency and its contractor and/or the support agency
(see Table 2-2). It is especially important that
discussion and information exchange occur if interim
actions or limited field investigations are considered
necessary. For all RI/FSs, it is desirable for the lead
and support agencies and their contractors to review
existing data and to agree on the major tasks to be
conducted at a site. Specific guidance for the timing
and nature of communications between the lead and
support agencies is provided in the "Superfund
Memorandum of Agreement Guidance" (in
preparation).
Deliverables required for all RI/FSs in which field
investigations are planned consist of a work plan, an
SAP, a health and safety plan (HSP), and a
community relations plan (CRP). Although these plans
usually are submitted together, each plan may be
delivered separately. Each of these plans is described
below.
2-12
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2.3.7
Work Plan
2.3.1.1 Purpose
The work plan documents the decision and evaluation
made during the scoping process and presents
anticipated future tasks. It also serves as a valuable
tool for assigning responsibilities and setting the
project's schedule and cost. Information on planning
work for lead agency staff may be found in the
Superfund Federal-Lead Remedial Project
Management Handbook (U.S. EPA, December 1986);
and the Superfund State-Lead Remedial Project
Management Handbook (U.S. EPA, December 1986).
The primary user of the RI/FS work plan is the lead
agency for the site (usually either the EPA Region or
the appropriate federal or state agency) and the
project team that will execute the work. Secondary
users of the work plan include other groups or
agencies serving in a review capacity, such as EPA
Headquarters and local government agencies. The
work plan is usually made available for public
comment (often in conjunction with a public meeting)
and is placed in the Administrative Record.
2.3.1.2 Preparation
The work plan presents the initial evaluation of
existing data and background information performed
during the scoping process, including the following:
• An analysis and summary of the site background
and the physical setting
• An analysis and summary of previous responses
• Presentation of the conceptual site model,
including an analysis and summary of the nature
and extent of contamination; preliminary
assessment of human health and environmental
impacts; and the additional data needed to
conduct the baseline risk assessment
• Preliminary identification of general response
actions and alternatives and the data needed for
the evaluation of alternatives
The work plan also defines the scope and objectives
of RI/FS activities to the extent possible. The scope
of the Rl site characterization should be documented
in the work plan, with detailed descriptions provided in
the SAP. Later tasks will usually be scoped in less
detail, pending the acquisition of more complete data
about the site.
The initial work plan is prepared prior to the Rl site
characterization.'Because the RI/FS process is
7 In enforcement cases, PRPs are typically responsible for the
development of the work plan (See Appendix A).
dynamic and iterative, the work plan or supplemental
plans, such as the QAPP and the FSP, can be
modified during the RI/FS process to incorporate new
information and refined project objectives. The work
plan should be revised, if necessary, before (1)
additional iterations of site characterization activities,
and (2) treatability investigations. On federal-lead
sites, a work plan revision request (WPRR) is
submitted for approval of any significant changes to
the budget schedule, or scope. EPA has found
technical directive memorandums (TDMs) to be
useful for decreasing administrative time when the
proposed work plan changes do not affect the total
budget or schedule.
2.3.1.3 Work Plan Elements
Five elements (Introduction, Site Background and
Physical Setting, Initial Evaluation, Work Plan
Rationale, and RI/FS Tasks) typically are included in a
work plan. These elements are described in Appendix
B.
Among the elements to be included is the
specification of RI/FS tasks. For federal-lead sites,
14 standard tasks have been defined to provide
consistent reporting and allow more effective
monitoring of RI/FS projects. Figure 2-4 shows
these tasks and their relationship to the phases of an
RI/FS, and detailed task definitions are included in
Appendix B. Although RI/FSs that are not federal-
lead projects are not required to use these standard
tasks, their use provides a valuable project
management tool that allows for compilation of
historical cost and schedule data to help estimate
these tasks during project planning and management.
Project Management Considerations. Project
management considerations may be specified in the
work plan to define relationships and responsibilities
for selected task and project management items. This
specification is particularly useful when the lead
agency is using extensive contractor assistance. The
following project management considerations may be
discussed in the work plan:
• Identification of staff (the lead agency's RPM, the
PRP's project manager, the contractor, the
contractor's site manager, and other team
members)
• Coordination among the lead agency, the support
agency, the PRPs and the contractors performing
the work
• Coordination with other agencies (Typically, the
lead agency's RPM is the focus for the
coordination of all other agency and private
participation in site activities and decisions.)
2-1 3
-------
Table 2-2. Communication and Deliverables During Scoping
Information Needed
Purpose
Potential Methods
of Information Exchange
Interim actions (if necessary)
Limited field investigations (if necessary)
Summary of existing data; field studies
conducted prior to FS; identification of
preliminary remedial action alternatives
Documentation of quality assurance (QA) and
field sampling procedures
Documentation of health and safety procedures
Documentation of all RI/FS tasks
For lead agency and contractor to identify actions that will
abate immediate threat to public health or prevent further
degradation of the environment; to obtain concurrence of
support agency
For lead agency and contractor to improve focus of Rl and
reduce time and cost; to obtain concurrence of support
agency
For lead agency and contractor to confirm need for field
studies; for lead agency and contractor to plan data
collection; to obtain support agency review and
concurrence
For contractor to obtain lead agency review and approval;
for lead agency to obtain support agency review and
comment
For contractor to obtain lead agency agreement that
OSHA safety requirements are met
For contractor to obtain lead agency review and approval;
for lead agency to obtain support agency concurrence
Meeting
Tech Memo
Other
Meeting
Tech Memo
Other
Meeting
Tech Memo
Other
SAP (FSP.QAPP)
Health and safety plan
Work plan
• Coordination of subcontractors, if any, and
description of health and safety requirements and
responsibilities
• Interface for federal-lead projects with the
Contract Laboratory Program (CLP), if needed, to
minimize sampling requirements by use of field
screening, to schedule analyses well ahead of
sampling trips, and to accurately complete CLP
paperwork
• Cost control (including a description of
procedures for contractors to report expenditures)
• Schedule control (including a description of
schedule tracking methods and procedures for
contractors to report activities to the lead agency)
• Identification of potential problems so that the
RPM and site manager can develop contingency
plans for resolution of problems during the RI/FS
• Evidentiary considerations, if needed, to ensure
that project staff members are trained with regard
to requirements for admissibility of the work in
court
Cost and Key Assumptions. For federal-lead sites,
the RI/FS work plan includes a detailed summary of
projected labor and expense costs,8 broken down by
the 14 tasks listed in Figure 2-3 and described in
Appendix B, and a description of the key assumptions
required to make such a cost estimate. During
The estimated RI/FS costs prepared by the RPM during the
scoping process will form the basis for evaluating costs proposed
by the contractor in the work plan and should help facilitate the
control of project costs as the RI/FS proceeds. Cost estimates
may not be required for State- and PRP-lead RI/FSs.
scoping, more detailed costs typically are provided for
the Rl site characterization tasks than for later phases
of the RI/FS. The less-detailed costs may be refined
as field investigations progress and the nature and
extent of site contamination is more fully understood.
RI/FS costs vary greatly among sites and are
influenced by the following:
• The adequacy of existing data
• The size and complexity of the site
• The level of personnel protection required for
onsite workers
• The number and depth of wells required and the
types of subsurface conditions where wells will be
installed
• The number and types of media sampled
• The number of samples required for each
medium
• The need for support of enforcement activities
• The need for bench- or pilot-scale tests
Schedule. The anticipated schedule for the RI/FS is
formulated on the basis of the scope of the project,
including the identification of key activities and
deliverable dates. As with cost, the scheduling of
tasks varies among sites.
2-1 4
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REMEDIAL INVESTIGATION
SCOPING
Task 1 - Project
Planning
SITE CHARACTERIZATION
Task 3 - Field Investigation
Task 4 - Sample Analysis/
Validation
Task 5 - Data Evaluation
Task 6 - Risk Assessment
Task 8 - Rl Reports
TREATABILITY
INVESTIGATIONS
Task 7 - Treatability Studies
Task 8 - Rl Reports
FEASIBILITY
STUDY
DEVELOPMENT AND SCREENING
OF ALTERNATIVES
Task 9 - Remedial
Alternatives
Development/
Screening
DETAILED
ANALYSIS
Task 10 -Detailed
Analysis of
Alternatives
Task 11 - RI/FS
Reports
TO: SOR, ROD,
RD, RA
Task 12-
Post RI/FS
Support
RI/FS WORK PLAN
STANDARD TASKS
TASK
TITLE
1
2
3
4
5
6
7
8
9
10
Project Planning
Community Relations *
Field Investigation
Sample Analysis/
Validation
Data Evaluation
Risk Assessment
Treatability Study/
Pilot Testing
Remedial Investigation
Reports
Remedial Alterna-
tives Development/
Screening
Detailed Analysis of
Alternatives
11 Feasibility Study
(RI/FS) Reports
12 Post RI/FS Support
13 Enforcement Support
14 Miscellaneous
Support *
* Tasks that can
occur in any Phase
of the RI/FS
Figure 2-4. Relationship of RI/FS Tasks to Phased RI/FS Approach.
2-15
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2.3.1.4 Report Format
The work plan should include the elements described
in Appendix B. Table 2-3 provides a suggested
format.
Table 2-3. Suggested RI/FS Work Plan Format
Executive Summary
1. Introduction
2. Site Background and Setting
3. Initial Evaluation
• Types and volumes of waste present
• Potential pathways of contaminant migration/preliminary
public health and environmental impacts
• Preliminary identification of operable units
• Preliminary identification of response objectives and
remedial action alternatives
4. Work Plan Rationale
• DQO needs
• Work plan approach
5. RI/FS Tasks
6. Costs and Key Assumptions
7. Schedule
8. Project Management
• Staffing
• Coordination
9. References
Appendices
2.3.2 Sampling and Analysis Plan (SAP)
2.3.2.1 Purpose
The SAP consists of two parts: (1) a quality
assurance project plan (QAPP) that describes the
policy, organization, functional activities, and quality
assurance and quality control protocols necessary to
achieve DQOs dictated by the intended use of the
data; and (2) the field sampling plan (FSP) that
provides guidance for all fieldwork by defining in detail
the sampling and data-gathering methods to be
used on a project. The FSP should be written so that
a field sampling team unfamiliar with the site would be
able to gather the samples and field information
required. Guidance for the selection and definition of
field methods, sampling procedures, and custody can
be acquired from the Compendium of Superfund Field
Operations Methods, which is a compilation of
demonstrated field techniques that have been used
during remedial response activities at hazardous
waste sites (U.S. EPA, September 1987, hereafter
referred to as the Compendium). To the extent
possible, procedures from this Compendium should
be incorporated by reference. In addition, the FSP
and QAPP should be submitted as a single document
(although they may be bound separately to facilitate
use of the FSP in the field). These efforts will
streamline preparation of the document and reduce
the time required for review.
The purpose of the SAP is to ensure that sampling
data collection activities will be comparable to and
compatible with previous data collection activities
performed at the site while providing a mechanism for
planning and approving field activities. The plan also
serves as a basis for estimating costs of field efforts
for inclusion in the work plan.
2.3.2.2 Plan Preparation and Responsibilities
Timing. A SAP is prepared for all field activities. Initial
preparation takes place before any field activities
begin, but the SAP may be amended or revised
several times during the Rl site characterization,
treatability investigations, or during the FS as the
need for field activities is reassessed and rescoped.
Preparation and Review. EPA, the states, PRPs, or
the contractors conducting the work should prepare
SAPsfor all field activities performed. The lead
agency's project officer must approve the SAP.
Signatures on the title page of the plan usually show
completion of reviews and approvals. Environmental
sampling should not be initiated until the SAP has
received the necessary approvals.9A suggested
format for a SAP is listed in Table 2-4.
2.3.2.3 Field Sampling Plan Elements
The FSP consists of the six elements contained in
Table 2-4. These elements are described more fully
in Appendix B.
2.3.2.4 Quality Assurance Project Plan Elements
The QAPP should contain 14 elements. These
elements are listed in Table 2-4 and described in
Appendix B. The required information for each of the
elements of a QAPP need not be generated each
time a QAPP is prepared. Only those aspects of a
QAPP that are specific to the site being investigated
need to be explicitly described. If site-specific
information is already contained in another document
(e.g., the FSP) it need only be referenced. Similarly,
any information contained in guidance documents
such as the DQO Guidance should only be
referenced and not repeated in the QAPP.
2.3.3 Health and Safety Plan
2.3.3.1 Purpose
Each remedial response plan will vary as to degree of
planning, special training, supervision, and protective
equipment needed. The health and safety plan
'Approval to conduct limited sampling (see Section 2.2.2.3)
may be given as part of the interim authorization to prepare the
work plans.
2-16
-------
Table 24. Suggested Format for SAP (FSP and QAPP)
FSP
QAPP
1. Site Background
2. Sampling Objectives
3 Sample Location and Frequency
4. Sample Designation
5. Sampling Equipment and Procedures
6. Sample Handling and Analysis
Title Page
Table of Contents
1. Project Description
2. Project Organization and Responsibilities
3. QA Objectives for Measurement
4. Sampling Procedures
6. Sample Custody
6. Calibration Procedures
7. Analytical Procedures
6. Data Reduction, Validation, and Reporting
9. Internal Quality Control
10. Performance and Systems Audits
11. Preventative Maintenance
12. Data Assessment Procedures
13. Correctwe Actions
14. Quality Assurance Reports
prepared to support the field effort must conform to
the firm's or agency's health and safety program
which must be in compliance with OSHA.
The site health and safety plan should be prepared
concurrently with the SAP to identify potential
problems early, such as the availability of adequately
trained personnel and equipment. OSHA requires that
the plan include maps and a detailed site description,
results of previous sampling activities, and field
reports. The plan preparer should review site
information, along with proposed activities, and use
professional judgment to identify potentially hazardous
operations and exposures and prescribe appropriate
protective measures. Appendix B of the Occupational
Safety and Health Guidance Manual for Hazardous
Waste Site Activities (NIOSH/OSHA/USCG/USEPA,
1985) provides an example of a generic format for a
site health and safety plan that could be tailored to
the needs of a specific employer or site.
2.3.3.2 Elements of the Health and Safety Plan
Each site health and safety plan should include, at a
minimum, the 11 elements described in Appendix B
of this guidance. The specific information required in
a site health and safety plan is listed in 29 CFR
1910.120.
2.3.3.3 Site Briefings and Inspections
The OSHA regulation requires that safety briefings be
held "prior to initiating any site activity and at such
other times as necessary to ensure that employees
are apprised of the site safety plan and that it is being
followed."
The final component of site health and safety
planning or informational programs is site auditing to
evaluate compliance with and effectiveness of the site
health and safety plan. The site health and safety
officer or that person's designee should carry out the
inspections.
2.3.4 Community Relations Plan
2.3.4.1 Purpose
The CRP documents the community relations history
and the issues of community concern. It should
describe the techniques that will be needed to
achieve the objectives of the program. The plan is
used by community relations staff, but it should also
be used by federal and state agency technical staff
members when planning technical work at the site.
2.3.4.2 Community Relations Plan Elements
Report preparation methods, the elements contained
in a CRP, and a recommended format are included in
Community Relations in Superfund: A Handbook (U.S.
EPA, Interim, June 1988). This handbook also
includes useful examples of community relations
plans.
2-17
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CHAPTER 3
SITE CHARACTERIZATION
FROM:
• Prrtmhary
AiMHtmnt
• Ste Inspection
• NPLUMng j
,\ TREATABILITY
CHAR*Ct6ReAT!ON INVESTIGATIONS
OETAILEO ANALYSIS
TERNATIVES
SITE
CHARACTERIZATION
TO: 1
• RacmdySctocUon
• Record olDacfebn
• FtatradUDMlgn
• Remedial Action
• Conduct Field Investigation
• Define Nature & Extent of
Contamination (Waste
Types, Concentrations,
Distributions)
• Identify Federal/State
Contaminant & Location
Specific ARARs
• Develop Baseline Risk
Assessment
3-1
-------
Site
Chapter 3
Characterization
3.1 Introduction
During site characterization, the sampling and
analysis plan (SAP), developed during project
planning, is implemented and field data are collected
and analyzed to determine to what extent a site poses
a threat to human health or the environment. The
major components of site characterization are
presented in Figure 3-1 and include:
• Conducting field investigations as appropriate
• Analyzing field samples in the laboratory
• Evaluating results of data analysis to characterize
the site and develop a baseline risk assessment
• Determining if data are sufficient for developing
and evaluating potential remedial alternatives
Because information on a site can be limited prior to
conducting an Rl, it may be desirable to conduct two
or more iterative field investigations so that sampling
efforts can be better focused. Therefore, rescoping
may occur at several points in the RI/FS process.
During site characterization, rescoping and additional
sampling may occur if the results of field screening or
laboratory analyses show that site conditions are
significantly different than originally believed. In
addition, once the analytical results of samples have
been received (either from a laboratory or a mobile
lab) and the data evaluated, it must be decided
whether further sampling is needed to assess site
risks and support the evaluation of potential remedial
alternatives in the FS. At this time, it is usually
apparent whether the data needs identified during
project planning were adequate and whether those
needs were satisfied by the first round of field
sampling. As discussed in Chapter 4, there are also
points during the FS when the need for additional field
studies may be identified. These additional studies, if
needed, can be conducted during subsequent site
characterization activities.
This chapter provides detailed descriptions of those
activities that may be required during the Rl site
characterization. As discussed earlier, the complexity
and extent of potential risks posed by Superfund sites
is highly variable. Therefore, the lead and support
agencies will have to decide on a site-specific basis
which of the activities described in this chapter must
be conducted to adequately characterize the
problem(s) and help in the evaluation of remedial
alternatives.
3.2 Field Investigation Methods
Field investigation methods used in RIs are selected
to meet the data needs established in the scoping
process and outlined in the work plan and SAP. This
section provides an overview of the type of site
characterization data that may be required and the
investigative methods used in obtaining these data.
The following sections describe methods for (1)
implementing field activities, (2) investigating site
physical characteristics, (3) defining the sources of
contamination, and (4) evaluating the nature and
extent of contamination. Specific information on the
field investigation methods described below is
contained in the Compendium. Sections of the
Compendium that apply to particular types of field
investigations are shown in Table 3-1.
3.2.7 Implement Field Activities
In addition to developing the SAP, fieldwork support
activities, such as the following, are often necessary
before beginning fieldwork:
• Assure that access to the site and any other
areas to be investigated has been obtained
•Procure subcontractors such as drillers,
excavators, surveyors, and geophysicists
• Procure equipment (personal protective
ensembles, air monitoring devices, sampling
equipment, decontamination apparatus) and
supplies (disposables, tape, notebook, etc.)
• Coordinate with analytical laboratories, including
sample scheduling, sample bottle acquisition
reporting, chain-of-custody records, and
procurement of close support laboratories or
other in-field analytical capabilities
• Procure onsite facilities for office and laboratory
space, decontamination equipment, and vehicle
3-3
-------
C Scoping J
Data Management
- Field Procedures
- Field Measurements
Conduct Field
Investigation
Data Management
- Laboratory
Sample Analysis
(Laboratory)
£
Data Management
- Analytical Data
Data Evaluation
- Site Characterization
Reevaluate
Data Needs ?
Preliminary
Site
Characterization
Summary
Data Evaluation
- Risk Assessment
Rescope Investigation ( Repeat
the Previous Scoping Steps):
- Determine New Data Needs
Revise Sampling Strategies and
Analytical Support Level (if needed
- Amend QAPP/FSP, HSP, and
Work Plan
Data
Sufficient for
Alternative
Developmen
Alternative
Development
Figure 3-1. Major components of site characterization.
maintenance and repair, and sample storage, as
well as onsite water, electric, telephone, and
sanitary utilities
• Provide for storage or disposal of contaminated
material (e.g., decontamination solutions,
disposable equipment, drilling muds and cuttings,
3-4
-------
Table 3-1. Relationship Among Site Characterization Tasks
and the Compendium
Applicable Sections and
Subsections of the Compendium
of Superfund Field Operations
Tasks Methods
Field Investigation
Air
Biota1
Close support laboratories
Rl-derived waste disposal
Soil gas
Support
Well logging
Mapping and survey
Geophysical
Well installation
Ground water
Soil
Source testing
Surface water
Sample analysis
Fieldwork, close support
laboratory
Data validations
Sample management
Data evaluation
7, 11, 15
12
5.2, 7, 15
3.2, 5.2.6.4, 8.1.6.3
3, 17, 16, 19, 20
8.1, 8.3
14
8.4
8.1, 8.5
8.5
8.1, 8.2, 8.3
7, 13, 15
10
5.2, 15
16
4, 5,6
16
'OSWER is currently developing a Superfund environmental
evaluation manual that will provide guidance for conducting
ecological investigations.
well-development fluids, well-purging water,
and spill-contaminated materials)
Since procurement activities can take up to several
months, they should be initiated as early as possible
so as not to affect the overall RI/FS schedule.
Schedule impacts should also be avoided by
structuring contracts, where possible, such that there
is no need to reprocure services for subsequent site
characterization activities. This may be accomplished
using contract options that are exercised only in the
event that additional services or facilities are required
(e.g., basic ordering agreements for well drilling).
Mobile labs or labs located near the site can often
reduce the time necessary for completing Rl
activities. If such quick-turnaround analysis is
available, it can be used to determine the location and
type of subsequent sampling that must take place to
more completely characterize the site. This may also
alleviate the need to reprocure subcontractors, and
significantly accelerate the completion of the Rl. If
such analytical techniques are to be employed, the
work plan and SAP should allow for decisions on
subsequent activities to be made in the field with oral
approval from key management personnel.
3.2.2 Investigate Site Physical Characteristics
Data on the physical characteristics of the site and
surrounding areas should be collected to the extent
necessary to define potential transport pathways and
receptor populations and to provide sufficient
engineering data for development and screening of
remedial action alternatives. Information normally
needed can be categorized as surface features
(including natural and artificial features), geology,
soils, surface water hydrology, hydrogeology,
meteorology, human populations, land use(s) and
ecology.
3.2.2.1 Surface Features
Surface features may include facility dimensions and
locations (buildings, tanks, piping, etc.), surface
disposal areas, fencing, property lines and utility lines,
roadways and railways, drainage ditches, leachate
springs, surface-water bodies, vegetation,
topography, residences, and commercial buildings.
Features such as these are usually identified for
possible contaminant migration and the location of
potentially affected receptors. Investigation of surface
features should not be limited to those that are onsite,
but should include significant offsite features as well.
Other facilities in the area that are potential
contributors to contamination should also be
identified.
A history of surface features at the site can be
developed from existing data. As discussed in
Chapter 2, the data may include historical
photographs, past topographic surveys, operational
records, and information obtained during interviews
with owners, operators, local residents, and local
regulatory agencies. Review of historical photographs
is sometimes the most valuable of these methods.
Aerial photographs are often available from such
sources as the Environmental Monitoring Support
Laboratory, Las Vegas (EMSL-LV), the Envi-
ronmental Photographic Interpretation Center (EPIC),
and the Soil Conservation Service of the U.S.
Department of Agriculture.
Existing surface features may be described using
aerial photography, surveying and mapping, and site
inspection. Inspection of the site and the surrounding
areas is normally augmented with photographs.
Section 14 of the Compendium presents additional
details on land surveying, aerial photography, and
mapping.
3-5
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3.2.2.2 Geology
Geology may control or affect the following aspects of
a site:
•The depths, locations, and extents of water-
bearing units or aquifers
• The release of contaminants and their subsequent
movement
• The engineering geologic aspects of site
exploration and remediation
The investigation of site geology should be tailored to
ensure the identification of those features that will
affect the fate and transport of contaminants. For
example, an understanding of site geology is less
important at a site at which release of contaminants
occurs by volatilization to the atmosphere than at a
site at which contaminants are moving toward the
water table.
To understand the geology of a site, one must
determine the geology of bedrock and of
unconsolidated overburden and soil deposits. Table
3-2 summarizes specific information on overburden
and bedrock geology that may be needed. The
degrees to which overburden and bedrock geology
must be understood depend on the geologic
character of the site area, as well as the physical
characteristics of the site itself. An understanding of
regional geologic characteristics is useful in
determining which aspect of site geology may have
the greatest influence on the fate and transport of
contaminants and the use of potential remedial
technologies.
In general, an investigation of site geology should
include the following steps:
• Determination of regional geology from available
information
• Reconnaissance mapping of the area, which may
include geophysical investigations onsite
• Subsurface explorations
The degree to which these steps are undertaken will
be determined by the degree to which the need to
evaluate geologic aspects of the site dictates the
investigations needed in the RI/FS. These
investigation methods are described in detail in
Section 8 of the Compendium and summarized in
Table 3-2.
3.2.2.3 Soils and the Vadose Zone
Properties of surface soils and the vadose zone
influence the type and rate of contaminant movement
to the subsurface and subsequently to the water
table. Contaminants that can move through the
surface soil and into the vadose zone may move
directly to the water table or they may be partially or
fully retained within the vadose zone to act as
continual sources of ground-water contamination.
Engineering, physical, and chemical properties of soil
and vadose zone materials can be measured in the
field or in the laboratory. Table 3-3 summarizes
typical methods for soil and vadose zone
investigations.
3.2.2.4 Surface-Water Hydrology
Surface-water features may include erosion patterns
and surface-water bodies such as ditches, streams,
ponds, and lakes. The transport of contaminants in
surface-water bodies is largely controlled by flow,
which in streams is a function of the gradient,
geometry, and coefficient of friction. A description of
how flow is measured can be found in Section 10 of
the Compendium. Contaminants have three possible
modes of transport: (1) sorption onto the sediment
carried by the flow, (2) transport as suspended solid,
and (3) transport as a solute (dissolved). The
transport of dissolved contaminants, which move the
fastest, can be determined by characterizing the flow
of the surface water and the contaminant dispersion.
Sediment and suspended solid transport involve other
processes such as deposition and resuspension.
Table 3-4 presents the surface-water information
that may be required for characterizing sites.
If potential pathways include surface water, necessary
data about impoundments may include (1) physical
dimensions such as depth, area, and volume; (2)
residence time; and (3) current direction and rates.
As with impoundments, the direction and velocity of
lake currents are often highly variable and, as a
result, are difficult to measure and accurately predict.
Site mapping will provide much of this information.
Measurement techniques (which are specified in
Section 10, Surface Hydrology, of the Compendium)
include the use of current meters and drogue
tracking.
3.2.2.5 Hydrogeology
Determination of site hydrogeology involves
identifying geologic characteristics, hydraulic
properties, and ground-water use, as defined in
Tables 3-5 and 3-6 and described in Section 8 of
the Compendium. The determination of site geology
and hydrogeology can often be incorporated into a
single investigative program. Regional hydrogeologic
conditions can be determined from existing
information; site-specific hydrogeologic conditions
can be determined using subsurface explorations,
well installations, and field testing of hydraulic
properties. Table 3-7 summarizes the typical data
3-6
-------
Table 3-2. Summary of Site Geology Information
Information Needed
Purpose of Rationale
Geology of unconsolidated overburden
and soil deposits
- Thickness and area! extent of units
- Lithology, mineralogy
- Particle size and sorting; porosity
Geology of bedrock
- Type of bedrock (igneous,
metamorphic, sedimentary)
- Lithology; petrology
- Structure (folds, faults)
- Discontinuities (joints, fractures,
bedding plants, foliation)
- Unusual features such as igneous
intrusive bodies (dikes), lava tubes,
solution cavities in limestone (karst)
For both unconsolidated and bedrock
geology:
• Evaluate ttie influence of geology on
water-bearing units and aquifers
• Evaluate the influence of geology on
release and movement of contaminants
• Obtain information on the engineering
geologic aspects of site remediation
For both unconsolidated and bedrock
geology:
• Determination of regional geology from
available information
- Published reports (geologic reports,
ground-water reports, soil survey
reports)
- State geologic maps
- USGS topographic quadrangle maps
- Descriptions of regional geology from
previous reports of site investigations
• Site reconnaissance mapping
- Field mapping of surficial soil and
overburdewn units, bedrock outcrops,
surface water drainage, springs, and
seeps
- Analyses of aerial photography or
other remote imagery
- Surface geophysics
• Subsurface explorations
- Test borings or core borings (with or
without sampling)
- Test pits and trenches
- Description and logging of subsurface
geologic materials
- Sample collection for laboratory
analyses of physical properties and
mineral content
- Borehole geophysics
collected and available analytical methodologies used
during a hydrogeologic investigation.
3.2.2.6 Meteorology
Meteorological data are often required to characterize
the atmospheric transport of contaminants for risk
assessment determinations and provide real-time
monitoring for health and safety issues.
Representative offsite and site-specific data may be
obtained using sampling methods outlined in Section
11, "Meteorology and Air Quality," of the
Compendium. This publication also discusses data
requirements for using refined air quality modeling
and applicable models. Table 3-8 summarizes
atmospheric investigations.
3.2.2.7 Human Populations and Land Use
Information should be collected to identify,
enumerate, and characterize human populations
potentially exposed to contaminants released from a
site. For a potentially exposed population, information
should be collected on population size and location.
Special consideration may be given to identifying
potentially sensitive subpopulations (e.g., pregnant
women, infants) to better facilitate the characterization
of risks posed by contaminants exhibiting specific
effects (e.g., mutagens, teratogens). Census and
other survey data may be used to identify and
describe the population potentially exposed to
contaminated media. Information may also be
available from U.S. Geological Survey maps, land use
plans, zoning maps, and regional planning authorities.
Data describing the type and extent of human contact
with contaminated media also are needed,'including:
• Location and use of surface waters
Drinking water intakes and distribution
Recreational (swimming, fishing) areas
- Connection between surface-water bodies
•Local use of ground water as a drinking-water
source
Number and location of wells
1ln some situations, information may be available from the
ATSDR if they previously have conducted health consultations.
3-7
-------
Table 3-3. Summary of Soil and Vadose Zone Information
CO
oo
In format ton Heeded
Soil Characteristics:
Type, holding capacity,
temperature, biological
activity, engineering
properties
Soil Chemistry Characteristics:
Solubility, ton speclation,
adsorption coefficients,
teachability, cation exchange
capacity, Mineral partition
coefficients, chemical and
sorptlve properties
Vadose Zone Characteristics:
Peneablllty, variability,
porosity, moisture content,
chemical characteristics,
extent of contamination
Purpose or Rationale
Estimate the effect of the
properties on Infiltration and
retardation of leachates and the
release of gaseous contaminants
Predict contaminant movement
through soils and availability
of contaminants to biological
systems
o Estimate flux In the vadose zone
Collection Methods
Primary
Reports and maps by Federal
and county agencies. Soil
Conservation Service (SCSI
publIcatlons
Existing scientific literature
Secondary
Existing literature
Borehole sampling, laboratory measurements (AST* methods),
water budget methods, Instantaneous rate method, seepage
meters, inflltrometers, test basins
Chemical analysis, column experiments, leaching tests
Nater budget with soil moisture accounting
Draining profile methods
Measurement of hydraulic gradients
Estimates assuming unit hydraulic gradient
Flo* meters
Methods based on estimating or measuring hydraulic
conductivity, using: r
o Laboratory parameter*
o Relationships between hydraulic conductivity and grain site
o Catalog of hydraulic properties
o Field measurements of hydraulic conductivity using single
or multiple veils
o Estimate velocity In the vadose
Existing literature
o Tracers
o Calculations using flux values
o Calculations using long-term Infiltration data
Evaluate pollutant movement In
the vadose cone
Existing literature
Four-probe electrical method
Electrical conductivity probe
Salinity sensors
Solids sampling followed by laboratory extraction of pore water
Solids sampling Cor organic and mlcroblal constituents
Suction Lyslmeters
Sampling perched ground water
-------
Table 3-4. Summary of Surface-Water Information
Information Needed
Drainage Patterns:
o Overland flow, topography,
channel flow pattern,
tributary relationships,
soil erosions, and sediment
transport and deposition
Purpose or Rationale
Determine if overland or
channel flow can result in
onslte or offsite flow and if
patterns for* contaminant
Collection Methods
Primary
Topographic maps, site inspec-
tion, and soil conservation
services
Secondary
Aerial mapping and ground
survey
Surface-Hater Bodies:
o Flow, stream widths and
depths, channel elevations,
flooding tendencies, and
physical dimensions of
co surface-water Impoundments
i
"> o Structures
o Surface-water/ground-water
relationships
Surface-Hater Quality:
o pH, temperature, total sus-
pended solids, suspended
sediment, salinity, and
specific contaminant
concentratIons
Determine volume and
velocity, transport times,
dilution potential, and
potential spread of
contamination
Effect of manMadc structures
on contaminant transport and
migration
Predict contaminant pathways
for Interceptive remedial
actions
Provide capacity of water to
carry contaminants and water/
sediment partitioning
Public agency data and
atlases; catalogs, maps, and
handbooks for background data
Public agency maps and records
and ground survey
Public agency reports and
surveys
Public agency computerized
data files, handbooks, and
open literature
Aerial mapping and ground
survey
Hater level measurements
and modeling
Sampling and analysis
-------
Table 3-5. Aspects of Site Hydrogeology
• Geologic aspects
- Type of water-bearing unit or aquifer (overburden,
bedrock)
- Thickness, areal extent of water-bearing units and
aquifers
- Type of porosity (primary, such as intergranular pore space,
or secondary, such as bedrock discontinuities or solution
cavities)
- Presence or absence of impermeable units or confining
layers
Depths to water table; thickness of vadose zone
• Hydraulic aspects
Hydraulic properties of water-bearing unit or aquifer
(hydraulic conductivity, transmissivity, storativity, porosity,
dispersivity)
Pressure conditions (confined, unconfined, leaky confined)
Ground-water flow directions (hydraulic gradients, both
horizontal and vertical), volumes (specific discharge), rate
(average linear velocity)
Recharge and discharge areas
Ground-water or surface water interactions; areas of
ground-water discharge to surface water
Seasonal variations of ground-water conditions
• Ground-water use aspects
Identify existing or potential aquifers
Determine existing near-site use of ground water
Table 3-6. Features of Ground-Water Systems
• Components of Ground-Water Systems
- Unconfined aquifers
- Confining beds
- Confined aquifers
- Presence and arrangement of components
• Water-bearing openings of the dominant aquifer
- Primary openings
- Secondary openings
• Storage and transmission characteristics of the dominant aquifer
- Porosity
- Transmissivity
• Recharge and discharge conditions of the dominant aquifer
Human use or access to the site and adjacent
areas
- Residential
- Commercial
Recreational use
Location of population with respect to site
- Proximity
Prevailing wind direction
Information on expected land use, as well as current
land use, is desirable. Available population growth
projections, land use plans, and zoning maps can
help develop expected exposure scenarios. This
information may be obtained from zoning boards, the
census bureau, regional planning agencies, and other
local governmental entities.
3.2.2.8 Ecological Investigations
Biological and ecological information collected for use
in the baseline risk assessment aids in the evaluation
of impacts to the environment and also helps to
identify potential effects with regard to the
implementation of remedial actions. The information
should include a general identification of the flora and
fauna associated in and around the site with particular
emphasis placed on identifying sensitive
environments, especially endangered species and
their habitats and those species consumed by
humans or found in human food chains. Examples of
sensitive environments include wetlands, flood plains,
wildlife breeding areas, wildlife refuges, and specially
designated areas such as wild and scenic rivers or
parks.
Depending on the specific circumstances, data may
be needed for species that have key ecological
functions in particular ecosystems, such as primary or
secondary producers, decomposers, scavengers,
predators, or species that occupy key positions in the
food chains of humans or other species.
Bioaccumulation data on food chain organisms, such
as aquatic invertebrates and fish, may be particularly
important to both environmental risk and human risk
assessment.2Data gathered through biological
assessment techniques (e.g., bioassays and/or field
monitoring) may be useful in situations where there
are complex mixtures, incomplete toxicity information,
and/or unidentified or unmeasured compounds. The
Natural Resources Trustees for the site should be
contacted to determine if other ecological data are
available that may be relevant to the investigation. A
summary of environmental information that may be
needed and potential collection methods is provided
in Table 3-9.
Prudent judgment on the part of the site managers is
required to ensure that only relevant data that will aid
in evaluating potential ecological risk and/or potential
remedial actions are collected. Because human health
risks may be more substantial than ecological risks,
and the mitigative actions taken to alleviate risks to
human health are often sufficient to mitigate potential
ecological risks as well, extensive ecological
investigations may not be required for many sites.
2Ecological Information collected to aid in the assessment of risk
to humans exposed through food chain contamination should
be used in accordance with the Superfund Public Health
Evaluation Manual (U.S. EPA, October 1986).
3-10
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Table 3-7. Summary of Ground-Water Information
Collection Methods
Information Needed
Purpose or Rationale
Primary
Secondary*
Ground-Water Occurrence:
• Aquifer boundaries and locations
• Aquifer ability to transmit water
Ground-Water Movement:
• Direction of flow
co
Rate of flow
Define flow limits and degree of aquifer
confinement
Determine potential quantities and rates for
treatment options
Identify most likely pathways of contaminant
migration
Existing literature, water resource atlases
Pumping and injection tests of monitor
wells
Existing hydrologic literature
Determine maximum potential migration rate
and dispersion of contaminants
Ground-Water Recharge/Discharge:
• Location of recharge/discharge areas Determine interception points tor withdrawal
options or areas of capping
Existing hydrologic literature
Existing site data, hydrologic literature,
site inspection
Installation of wells and piezometers
(single level or multilevel)
Ground-water level measurements
(over time to monitor seasonal variations)
Instrument survey of wells for calculation
of ground-water elevations
Borehole and surface geophysics
Water level measurements in monitor
wells
Testing of hydraulic properties using slug
tests, tracer tests, and pump tests
(short- or long-duration, single or
multiple well)
Elevation contours of water table or
potentiometric surface
Analytical calculations of flow directions
and rates
Computer generated simulations of
ground-water flow and contaminant
transport (using analytical or numerical
methods)
Generation of site water balance
Hydraulic gradient, permeability, and
effective porosity from water level
contours, pump test results, and
laboratory analyses
Comparsion of water levels in
observation wells, piezometers, lakes,
and streams
Field mapping of ground-water recharge
areas (losing streams, interstream areas)
and ground-water discharge to surface
water (gaining streams, seeps, and
springs)
Rate
Ground-Water Quality:
• pH, total dissolved solids, salinity,
specific contaminant concentrations
Determine variability of loading to treatment Existing literature
options
Determine exposure via ground water; Existing site data
define contaminant plume for evaluation of
interception methods
Water-balance calculations aided by
geology and soil data
Analysis of ground-water samples from
observation wells, geophysics
'May be appropriate if detailed information is required or if it is the only method due to a lack of published data.
-------
Table 3-8. Summary of Atmospheric Information
Collection Methods
CO
*
_^
to
Information Needed
Local Climate:
oPrecipitation
oTemperature
o Wind speed and direction
o Presence of inversion layers
Weather Extremes:
o storms
o Floods
o Winds
Release Characteristics:
o Direction and speed of plume
movement
o Rate, amount, temperature of
release
Purpose or Rationale
Define recharge, aeolian ero-
sion, evaporation potential,
effect of weather patterns on
remedial actions, area of
deposition of particulates
Determine effect of weather
extremes on selection and
timing of remedial actions,
and extremes of depositional
areas
Determine dispersion
characteristics of release
Primary
National Climate Center (NCC)
of National Oceanic and
Atmospheric Administration;
local weather bureaus
Secondary
Onsite measurements and
observations
NCC; State emergency planning
offices; Federal Emergency
Management Agency flood insurance
studies
Information from source
facility, weather services,
air monitoring services
Onsite measurements
o Relative densities
-------
The use of a review committee comprised of
individuals experienced in conducting ecological
investigations is encouraged to provide design,
planning, and oversight for these investigations and to
follow through to the selection of an environmentally
sound remedy. Section 12 of the Compendium
addresses environmental information that may be
needed and potential collection methods.
3.2.3 Define Sources of Contamination
Sources of contamination are often hazardous
substances contained in drums, tanks, surface
impoundments, waste piles, and landfills. In a
practical sense, heavily contaminated media (such as
soils) may also be considered sources of
contamination, especially if the original source (such
as a leaking tank) is no longer present on the site or
is no longer releasing contaminants.
Source characterization involves the collection of data
describing (1) facility characteristics that help to
identify the source location, potential releases, and
engineering characteristics that are important in the
evaluation of remedial actions; (2) the waste
characteristics, such as the type and quantity of
contaminants that may be contained in or released to
the environment; and (3) the physical or chemical
characteristics of hazardous wastes present in the
source. Key source characterization data are
summarized in Table 3-10.
The location and type of existing containment should
be determined for all known sources. In addition,
where the hazardous substance remains in
containment vessels, the integrity of the containment
structure should be determined so that the potential
for release and its magnitude can be evaluated. This
determination is especially important for buried drums
or tanks, because corrosion may be rapid. These
data, as well as the data identified in Table 3-10,
may be obtained largely through site inspections,
mapping, remote sensing, and sampling and analysis.
The waste type should be determined for each
source. If available waste manifests or facility records
can be reviewed, the industrial processes that
resulted in generation of the waste should be
determined and the types of contaminants usually
present in the process waste identified. Often,
sources are sampled and analyzed for contaminants
found on the Target Compound List (TCL) (formerly
the Hazardous Substances List) or other lists such as
those developed for RCRA3. Quantities of wastes
may be estimated for each waste type either from
verifiable inventories of containerized wastes, from
sampling and analysis, or from physical dimensions of
the source. Section 13 of the Compendium and
'Guidance on determining whether wastes are RCRA-listed or
characteristic wastes can be found in the CERCLA
Compliance with Other Laws Manual (U.S. EPA, May
Characterization of Hazardous Waste Sites - A
Methods Manual, Volume II (U.S. EPA, April 1985)
describe methods suitable for sampling and analysis.
It may be possible to determine the location and
extent of sources and the variation of materials within
a waste deposit by nonchemical analysis.
Methodologies for this determination, which are
described in Section 8 of the Compendium, include
geophysical surveys. A variety of survey techniques
(e.g., ground-penetrating radar, electrical resistivity,
electromagnetic induction, magnetometry, and
seismic profiling), can effectively detect and map the
location and extent of buried waste deposits. Aerial
photography and infrared imagery can aid in defining
sources through interpretation of the ecological
effects that result from stressed biota. However, all of
these geophysical methods are nonspecific, and
subsequent sampling of the sources will probably be
required to provide the data for evaluation of source
control measures at the site.
3.2.4 Determine the Nature and Extent of
Contamination
The final objective of the field investigations is to
characterize the nature and extent of contamination
such that informed decisions can be made as to the
level of risk presented by the site and the appropriate
type(s) of remedial response. This process involves
using the information on source location and physical
site data (e.g., ground-water flow directions, over
land flow patterns) to give a preliminary estimate of
the locations of contaminants that may have migrated.
An iterative monitoring program is then implemented
so that, by using increasingly accurate analytical
techniques, the locations and concentrations of
contaminants that have migrated into the environment
can be documented.
The sampling and analysis approach that should be
used is discussed in Section 4.5.1 of the DQO
Guidance. In short, the approach consists of, where
appropriate, initially taking a large number of samples
using field screening type techniques and then, based
on the results of these samples, taking additional
samples - to be analyzed more rigorously - from
those locations that showed the highest
concentrations in the previous round of sampling. The
final step is to document the extent of contamination
using an analytical level that yields data quality that is
sufficient for the risk assessment and the subsequent
analysis and selection of remedial alternatives.
At hazardous waste sites the nature and extent of
contamination may be of concern in five media:
ground water, soil, surface water, sediments, and air.
The methodologies for conducting sampling and
analysis for each of these media are discussed
below. More detailed descriptions of the investigation
3- 13
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Table 3-9. Summary of Ecological Information
Information Needed
for Public Health Evaluation
Land Use Characteristics
Purpose or Rationale
Determine if terrestrial
environment could result in
human exposure, e.g.,
through hunting or use of
agricultural land
Collection Methods
Primary
Ground and aerial survey maps;
site survpy
Secondary
Ground and aerial surveys
Hater Use Characteristics
u
in
Determine if aquatic
environment could result
human exposure, e.g.,
through fishing or other
recreational water activities
Information Needed for Environmental Evaluation
Ecosystem Components and
Characteristics
Critical Habitats
Determine potentially
affected ecosystems;
determine presence of
endangered species
Determine the area on or near
a site to be protected during
remediation
Hater resource agency reports;
site surveys
Records of area plants and
animal surveys, survey of
plants and animals on or near a
site; survey of a site or area
photographs
Records of site environment
Ground surveys and sample
collection
Ground and water surveys
Blocontamlnatlon
Determine observable impact
of contaminants
Records of site environment
Sampling and analysis
-------
Table 3-10. Summary of Source Information
Information Needed
Purpose or Rationale
Collection Methods
Primary
Secondary
Facility Characteristics:
o Source location
Locate above-ground and
subsurface contaminant
sources
Site inspection facility
records, archival photos
Remote sensing, sampling, and
analysis
o Type of waste/chemical
containment
Determine potential remedies
for releases
Site Inspection
Remote sensing
Oi
o Integrity of waste/chemical
containment
o Drainage control
o Fnglneeered structures
Determine probability of
release and timing of
response
Determine probability of
release to surface water
Identify possible conduits
for migration or Interference
with remedial actions
Site Inspection
Site Inspection; topographic
maps
Site inspection; facility
records
Sampling and analysis;
nondestructive testing
Remote sensing
o Site security
o Known discharge points
(outfalls, stacks)
Determine potential for
exposure by direct contact;
may dictate response
Determine points of
accidental or Intentional
discharge
Site inspection
Site inspection; facility
records
-------
Table 3-10. Continued
u
05
Information Needed
o Napping and surveying
Haste Characteristics:
o Type
o Quantities
o Chemical and physical
properties
o Concentrations
Purpose or Rationale
Locate existing structures
and obstructions for
alternatives evaluation, site
features, and topography
Determine contaminants for
exposure assessments and for
treatment options
Determine magnitude of
potential releases
Determine environmental
nobility, persistence, and
effects; determine
parameters for development
and evaluation of
alternatives
Determine quantities and
concentrations potentially
released to environmental
pathways
Collection Methods
Primary
Existing maps (USGS, county,
land development)
Site Inspection; waste
manifests
Site Inspection
Site inspection, handbooks,
CHHKTREC/OHMTADS, Chemical
Information Service (CIS),
and facility records
Site Inspection
Secondary
Remote sensing; surveying
Sampling and analysis
Sampling and analysis;
geophysical surveys
Sampling and analysis
Sampling and analysis
-------
process can be found in the DQO Guidance and the
Compendium.
3.2.4.1 Ground Water
The nature and extent of ground-water
contamination should be evaluated both horizontally
and vertically. On the basis of geologic and
hydrogeologic investigations, it should be determined
if contamination of an aquifer(s) is possible and if
such contamination could potentially affect human or
environmental receptors. Following this, a ground-
water monitoring program may need to be
implemented, concentrating the placement of wells in
the direction of ground-water flow, in aquifers
subject to contamination, and in places where they
would indicate an existing or future threat to receptor
populations. However, because of the uncertainties
associated with subsurface migration, identifying
background levels, and determining if there is a
contribution from other sources, sampling should also
be conducted in the area perceived to be upgradient
from the contaminant source.
Because of the significant investment necessary to
drill new wells and the resulting limited number of
samples, neither Level I nor field-screening
techniques are appropriate for analysis of ground
water, other than to possibly better define chemical
analysis parameters. Geophysical techniques can be
useful in identifying the location of plumes and
thereby assisting in the location of monitoring wells.
However, geophysical techniques are subject to
influences from external factors and are not
appropriate at all sites. Therefore, care must be taken
in employing these methods, and their results should
always be confirmed with analytical sampling. Specific
guidance on conducting ground water sampling
investigations and response activities can be found in
the Compendium, the DQO Guidance, and the
"Guidance on Remedial Actions for Contaminated
Ground Water at Superfund Sites" (U.S. EPA, Draft,
August 1988).
3.2.4.2 Soil
As with ground-water sampling, the intent of soil
sampling is to characterize and estimate the limits of
existing soil contamination. Field-screening
techniques (e.g., soil gas analysis, mobile laboratories
for target compounds) can be useful for directing soil
sampling into areas of greatest contamination or "hot
spots." If existing information provides no basis for
predicting where hot spots might occur, sampling
locations can be chosen in a grid pattern of
appropriate size such that investigators can be
confident that areas of high concentration have been
located. Often, especially if soil has been
contaminated as a result of overland flow of
contaminants from defined sources, sampling can be
concentrated in those areas that, either through
topography or evidence such as drainage channels, it
is most likely that contaminants have been deposited.
As with ground water, soil contamination should be
documented in both vertical and horizontal directions.
This approach will help determine both areas of
contamination and background concentrations. Soils
to be analyzed usually can be obtained by hand,
allowing many samples to be taken and initially
analyzed with instruments such as a photoionization
detector. Results of field screening can then be used
to determine which samples should be further
analyzed using more rigorous methods.
3.2.4.3 Surface Water
Leachate from contaminant sources or discharge of
contaminated ground water can result in the
contamination of surface waters. Surface-water
sampling locations should be chosen at the perceived
location(s) of contaminant entry to the surface water
and downstream, as far as necessary, to document
the extent of contamination. As with soil, the relative
ease of obtaining samples allows many samples to be
taken and analyzed using field screening methods, a
subset of which can be chosen for more rigorous
analysis.
Contamination of surface water is sometimes the
result of an incidental release of contaminants such
as the overflowing or breach of a surface
impoundment. In these cases, it is not likely that
routine surface water sampling will show
contamination that has or may occur. Therefore, to
document whether such releases occur, sampling
should be conducted during or following periods of
heavy rainfall when possible.
3.2.4.4 Sediments
A potentially more serious and common problem
associated with surface water is the contamination of
sediments. Whereas contamination in surface water
tends to become diluted or transformed as it travels
downstream, contaminants deposited in 'sediments
tend to remain in place. It is therefore important to
monitor for sediment contamination if it is suspected
that surface water has been contaminated.
The choice of sampling locations for sediments is
similar to the criteria applied to surface-water
sampling. Field-screening techniques can be useful
in defining areas of contamination. However, it should
be noted that sediment contamination often consists
of inorganics and/or nonvolatile organics for which
field screening techniques are not as applicable.
Therefore, in designing a sampling program,
consideration of the contaminants of concern is very
important.
3-1 7
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3.2.4.5 Air
Volatilization of organics and emissions of airborne
particulates can be a concern at hazardous waste
sites. For sites at which it appears that air emissions
are a problem (e.g., surface impoundments containing
volatile organics, landfills at which there is evidence
of methane gas production and migration), an air
emissions monitoring program should be undertaken.
A field-screening program is recommended to
determine if there is an air pollution problem, both for
volatile organics and fugitive dust emissions. Because
of the highly variable nature of air emissions from
hazardous waste sites, consideration of
meteorological conditions at the time of sampling is
essential for the proper documentation of potential air
pollution.
3.2.5 Additional Site Characterization
In some situations, additional site information may be
required to refine our understanding of the site and
better evaluate specific remedial alternatives.
Examples include:
• Better delineation of contaminated areas and
depths of contamination so that quantities of
contaminated media to be processed can be
calculated more accurately
• Characteristics of the media that would affect the
feasibility of the remedial alternative, such as soil
permeability for soil-vapor extraction
• Pertinent site characteristics not discovered
earlier in the initial site characterization effort
Before additional site characterization is initiated, the
QAPP/FSP should be reviewed and modified as
appropriate to guide the collection of additional site
data. In addition, site data collected and evaluated as
part of the initial Rl site characterization should be
reviewed and compared to the data needs identified
for conducting the detailed analysis of alternatives.
Reviewing data needs during the preplanning step is
also useful in predicting the necessary number of
samples and types of analyses required.
3.3 Laboratory Analyses
Data that will be used as the basis for decision-
making requires that the analysis of samples in
laboratories meets specific QA/QC requirements. To
meet these requirements, federal- or state-lead site
investigations have the option of using mobile
laboratories; the CLP, which is established by EPA: or
a non-CLP laboratory that meets the DQOs of the
site investigation.4
4The type of laboratory analyses that will be utilized for a
PRP-lead RI/FS may also include any of those listed above,
if approved by the RPM (See Appendix A).
The CLP provides analytical services through a
nationwide network of laboratories under contract to
EPA. The lead agency chooses whether or not to use
a CLP laboratory on the basis of available CLP
capacity and the analytical requirements that meet the
DQOs. If the CLP is not used, a laboratory may be
procured using standard bidding procedures.
Under the CLP, the majority of analytical needs are
met through standardized laboratory services
provided by Routine Analytical Services (RAS). The
RAS program currently provides laboratory services
for the analysis of organics and inorganics in water or
solid samples. Other specialized types of analysis not
yet provided by standardized laboratory contracts may
be scheduled on an as-needed basis under the
special analytical services (SAS) program. The SAS
program is designed to complement the RAS program
by providing the capability for specialized or custom
analytical requirements. If an analytical need is not
ordinarily provided by routine analytical services
(FWS), a specific subcontract can be awarded under
the SAS program to meet a particular requirement.
The decision whether to use mobile laboratories or a
CLP or non-CLP laboratory should be based on
several factors including the analytical services
required, the number of samples to be analyzed, the
desired turnaround time, and the anticipated
turnaround time of the laboratory at the time samples
are to be sent. Mobile or non-CLP laboratories
located close to the site may be the best choice
when fast turnaround of analytical results is required
to meet specific sampling objectives or would result in
a significant reduction of the overall RI/FS schedule.
To facilitate the most efficient completion of the Rl,
mobile or non-CLP laboratories can be used to
initially document the nature and extent of
contamination. Selected duplicate samples can be
sent to CLP laboratories to confirm and validate the
analytical results from the mobile or non-CLP
laboratories. This process assists in the timely
completion of the Rl and the initiation of FS activities,
while still ensuring that legally defensible data are
available for decision-making and potential cost-
recovery actions.
If a non-CLP laboratory is used, analytical protocols
need to be specified in the bid packages sent to
laboratories that are under consideration. For
federal-lead sites, laboratories receiving invitations
to bid have usually been approved by the EPA
Regional QA representative. For state-lead sites at
which non-CLP laboratories are used, the laboratory
usually subcontracts with the prime contractor when
the project is initiated.
Section 5 of the Compendium presents the details of
procedures for the use of CLP laboratories and non-
CLP laboratories. The User's Guide to the Contract
3-18
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Laboratory Program (U.S. EPA, December 1966) also
presents procedures for use of the CLP.
3.4 Data Analyses
Analyses of the data collected should focus on the
development or refinement of the conceptual site
model by presenting and analyzing data on source
characteristics, the nature and extent of
contamination, the contaminated transport pathways
and fate, and the effects on human health and the
environment. Data collection and analysis for the site
characterization is complete when the DQOs that
were developed in scoping (including any revisions
during the Rl) are met, when the need (or lack
thereof) for remedial actions is documented, and
when the data necessary for the development and
evaluation of remedial alternatives have been
obtained. The results of the Rl typically are presented
as an analysis of site characteristics and the risk
associated with such characteristics (i.e., the baseline
risk assessment).
3.4.1 Site Characteristics
The evaluation of site characteristics should focus on
the current extent of contamination and estimating the
travel time to, and predicting contaminant
concentrations at, potential exposure points. Data
should be analyzed to describe (1) the site physical
characteristics, (2) the source characteristics, (3) the
nature and extent of contamination, and (4) the
important contaminant fate and transport
mechanisms.
3.4.1.1 Site Physical Characteristics
Data on site physical characteristics should be
analyzed to describe the environmental setting at the
site, including important surface features, soils,
geology, hydrology, meteorology, and ecology. This
analysis should emphasize factors important in
determining contaminant fate and transport for those
exposure pathways of concern. For example, if
migration of contamination in ground water is of
concern, these factors may include the properties of
the unsaturated zone, the rate and direction of flow in
the aquifer(s), and the extent of subsurface systems.
3.4.1.2 Source Characteristics
Data on source characteristics should be analyzed to
describe the source location; the type and integrity of
any existing waste containment; and the types,
quantities, chemical and physical properties, and
concentrations of hazardous substances found. The
actual and potential magnitude of releases from the
source and the mobility and persistence of source
contaminants should be evaluated.
3.4.1.3 The Nature and Extent of Contamination
An analysis of data collected concerning the study
area should be performed to describe contaminant
concentration levels found in environmental media in
the study area. Analyses that are important to the
subsequent risk assessment and subsequent
development of remedial alternatives include the
horizontal and vertical extent of contamination in soil,
ground water, surface water, sediment, air, biota, and
facilities.5 Spatial and temporal trends in
contamination may be important in evaluating
transport pathways. Data should be arranged in
tabular or graphical form for clarity. Figure 3-2
shows an example of how the extent of soil and
ground-water contamination can be represented in
terms of excess lifetime cancer risk. Similar figures
can be prepared showing concentrations rather than
risk values.
3.4.1.4 Contaminant Fate and Transport
Results of the site physical characteristics, source
characteristics, and extent of contamination analyses
are combined in the analyses of contaminant fate and
transport. If information on the contaminant release is
available, the observed extent of contamination may
be used in assessing the transport pathway's rate of
migration and the fate of contaminants over the
period between release and monitoring. Contaminant
fate and transport may also be estimated on the basis
of site physical characteristics and source
characteristics.
Either analysis may use analytical or numerical
modeling. While field data generally best define the
extent of contamination, models can interpolate
among and extrapolate from isolated field samples
and can interpret field data to create a more detailed
description. Models also can aid the data reduction
process by providing the user with a structure for
organizing and analyzing field data.
Models applicable to site characterization can be
grouped according to their relative accuracy and their
ability to depict site conditions. Simplified models
(e.g., analytical and semianalytical models) can
quantitatively estimate site conditions with relatively
low accuracy and resolution. Typically, they provide
order-of-magnitude estimates and require that
simplified assumptions be made regarding site
conditions and chemical characteristics.
More detailed numerical models (e.g., numerical
computer codes) provide greater accuracy and
resolution because they are capable of representing
5Cross-media contamination should be considered (e.g.,
potential for contaminated soils to act as a source for ground-
water contamination due to leaching from the soil).
3-19
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spatial variations in site characteristics and irregular
geometries commonly found at actual sites. These
models can also represent the actual configuration
and effects of remedial actions on site conditions.
Detailed mathematical models are sometimes
appropriate for investigations in which detailed
information on contaminant fate and transport is
required.
Models also are useful for screening alternative
remedial actions and may be used for a detailed
analysis of alternatives. Deciding whether analytical or
numerical models should be used and selecting
appropriate models for either the remedial
investigation or the feasibility study can be difficult.
Modeling may not be needed if site conditions are
well understood and if the potential effectiveness of
different remedial actions can be easily evaluated. In
selecting and applying models, it is important to
remember that a model is an artificial representation
of a physical system and is only one way of
characterizing and assessing a site. A model cannot
replace, nor can it be more accurate than, the actual
site data. Additional information on determining
contaminant fate and transport is provided in the
"Superfund Exposure Assessment Manual" (U.S.
EPA, April 1988).
3.4.2 Baseline Risk Assessment
3.4.2.1 General Information
Baseline risk assessments provide an evaluation of
the potential threat to human health and the
environment in the absence of any remedial action.
They provide the basis for determining whether or not
remedial action is necessary and the justification for
performing remedial actions. The baseline risk
assessment will also be used to support a finding of
imminent and substantial endangerment if such a
finding is required as part of an enforcement action.
Detailed guidance on evaluating potential human
health impacts as part of this baseline assessment is
provided in the Superfund Public Health Evaluation
Manual (SPHEM) (U.S. EPA, October 1986).6
Guidance for evaluating ecological risks is currently
under development within OSWER.
In general, the objectives of a baseline risk
assessment may be attained by identifying and
characterizing the following:
Toxicity and levels of hazardous substances
present in relevant media (e.g., air, ground water,
soil, surface water, sediment, and biota)
6This guidance is currently undergoing revision.
• Environmental fate and transport mechanisms
within specific environmental media such as
physical, chemical, and biological degradation
processes and hydrogeological conditions
• Potential human and environmental receptors
• Potential exposure routes and extent of actual or
expected exposure
•Extent of expected impact or threat; and the
likelihood of such impact or threat occurring (i.e.,
risk characterization)
• Level(s) of uncertainty associated with the above
items
The level of effort required to conduct a baseline risk
assessment depends largely on the complexity of the
site. The goal is to gather sufficient information to
adequately and accurately characterize the potential
risk from a site, while at the same time conduct this
assessment as efficiently as possible. Use of the
conceptual site model developed and refined
previously will help focus investigation efforts and,
therefore, streamline this effort. Factors that may
affect the level of effort required include:
• The number, concentration, and types of
chemicals present
• Areal extent of contamination
• The quality and quantity of available monitoring
data
•The number and complexity of exposure
pathways (including the complexity of release
sources and transport media)
• The required precision of sample analyses, which
in turn depends on site conditions such as the
extent of contaminant migration and the proximity,
characteristics, and size of potentially exposed
population(s)
• The availability of appropriate standards and/or
toxicity data
3.4.2.2 Components of the Baseline Risk
Assessment
The risk assessment process can be divided into four
components:
Contaminant identification
Exposure assessment
Toxicity assessment
3-20
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LEGEND*
Soil Area Exceeding 10"s
Lifetime Cancer Risk
Ground Water Exceeding
106Lifetime Cancer Risk
DIRECTION OF
GROUND-WATER FLOW
SOURCE
160'
SCALE IN FEET
*NOTE: 1. Site-specific features should be shown
as appropriate (e.g., actual of potential
ground-water users).
2. Contamination can be represented by
concentrations in addition to risk levels.
Figure 3-2. Representation of the area! extent of contamination.
3-21
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• Risk characterization
Figure 3-3 illustrates the risk assessment process
and its four components. A brief overview of each
component follows.
Contaminant Identification. The objective of
contaminant identification is to screen the information
that is available on hazardous substances or wastes
present at the site and to identify contaminants of
concern to focus subsequent efforts in the risk
assessment process. Contaminants of concern may
be selected because of their intrinsic toxicological
properties, because they are present in large
quantities, or because they are presently in or
potentially may move into critical exposure pathways
(e.g., drinking water supply).
It may be useful for some sites to select "indicator
chemicals" as part of this process/lndicator
chemicals are chosen to represent the most toxic,
persistent, and/or mobile substances among those
identified that are likely to significantly contribute to
the overall risk posed by the site. In some instances,
an indicator chemical may be selected for the
purpose of representing a "class" of chemicals (e.g.,
TCE to represent all volatiles). Although the use of
indicator chemicals serves to focus and streamline
the assessment on those chemicals that are likely to
be of greatest concern, a final check will need to be
made during remedy selection and the remedial
action phase to ensure that the waste management
strategy being implemented addresses risks posed by
the range of contaminants found at the site.
Exposure Assessment The objectives of an exposure
assessment are to identify actual or potential
exposure pathways, to characterize the potentially
exposed populations, and to determine the extent of
the exposure. Detailed guidance on conducting
exposure assessments is provided in the Superfund
Exposure Assessment Manual (U.S. EPA, April
1988), and is briefly discussed below.
Identifying potential exposure pathways helps to
conceptualize how contaminants may migrate from a
source to an existing or potential point of contact. An
exposure pathway may be viewed as consisting of
four elements: (1) A source and mechanism of
chemical release to the environment; (2) An
environmental transport medium (e.g., air, ground
water) for the released chemical; (3) A point of
potential contact with the contaminated medium
(referred to as the exposure point); and (4) An
exposure route (e.g., inhalation, ingestion) at the
exposure point.
The analysis of the contaminant source and how
contaminants may be released involves characterizing
the contaminants of concern at the site and
determining the quantities and concentrations of
contaminants released to environmental media. Figure
3-4 presents a conceptual example identifying actual
and potential exposure pathways.
Once the source(s) and release mechanisms have
been identified, an analysis of the environmental fate
and transport of the contaminants is conducted. This
analysis considers the potential environmental
transport (e.g., ground-water migration, airborne
transport); transformation (e.g., biodegradation,
hydrolysis, and photolysis); and transfer mechanisms
(e.g., sorption, volatilization) to provide information on
the potential magnitude and extent of environmental
contamination. Next, the actual or potential exposure
points for receptors are identified. The focus of this
effort should be on those locations where actual
contact with the contaminants of concern will occur or
is likely to occur. Last, potential exposure routes that
describe the potential uptake mechanism (e.g.,
ingestion, inhalation, etc.) once a receptor comes into
contact with contaminants in a specific environmental
medium are identified and described. Environmental
media that may need to be considered include air,
ground water, surface water, soil and sediment, and
food sources. Detailed procedures for estimating and
calculating rates of exposure are described in detail in
the Super-fund Exposure Assessment Manual.
After the exposure pathway analysis is completed, the
potential for exposure should be assessed.
Information on the frequency, mode, and magnitude
of exposure(s) should be gathered. These data are
then assessed to yield a value that represents the
amount of contaminated media contacted per day.
This analysis should include not only identification of
current exposures but also exposures that may occur
in the future if no action is taken at the site. Because
the frequency mode and magnitude of human
exposures will vary based on the primary use of the
area (e.g., residential, industrial, or recreational), the
expected use of the area in the future should be
evaluated. The purpose of this analysis is to provide
decision-makers with an understanding of both the
current risks and potential future risks if no action is
taken. Therefore, as part of this evaluation, a
reasonable maximum exposure scenario should be
developed, which reflects the type(s) and extent of
exposures that could occur based on the likely or
expected use of the site (or surrounding areas) in the
7The methodology for identifying indicator chemicals for
assessing human health risks is described in the Superfund
Public Health Evaluation Manual (U.S. EPA, October 1986).
"This evaluation does not require an extensive analysis of
demographic trends and a statistically measurable confidence
level for the prediction of future development, only that the
likely use (based on past and current trends, zoning
restrictions, etc.) be evaluated.
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future.9The reasonable maximum exposure scenario
is presented to the decision-maker so that possible
implications of decisions regarding how to best
manage uncertainties can be factored into the risk
management remedy selection.
The final step in the exposure assessment is to
integrate the information and develop a qualitative
and/or quantitative estimate of the expected exposure
level(s) resulting from the actual or potential release
of contaminants from the site.
Toxicity Assessment. Toxicity assessment, as part of
the Super-fund baseline risk assessment process,
considers (1) the types of adverse health or
environmental effects associated with individual and
multiple chemical exposures; (2) the relationship
between magnitude of exposures and adverse
effects; and (3) related uncertainties such as the
weight of evidence for a chemical's potential
carcinogenicity in humans. Detailed guidance for
conducting toxicity assessments is provided in the
SPHEM.
Typically, the Super-fund risk assessment process
relies heavily on existing toxicity information and does
not involve the development of new data on toxicity or
dose-response relationships. Available information
on many chemicals is already evaluated and
summarized by various EPA program offices or
cross-Agency work groups in health and
environmental effects assessment documents. These
documents or profiles will generally provide sufficient
toxicity and dose-response information to allow both
qualitative and quantitative estimates of risks
associated with many chemicals found at Superfund
sites. These documents often estimate carcinogen
exposures associated with specific lifetime cancer
risks (e.g., risk-specific doses or RSDs), and
systemic toxicant exposures that are not likely to
present appreciable risk of significant adverse effects
to human populations over a lifetime (e.g., Reference
Doses or RfDs).
Risk Characterization. In the final component of the
risk assessment process, a characterization of the
potential risks of adverse health or environmental
effects for each of the exposure scenarios derived in
the exposure assessment, is developed and
summarized. Estimates of risks are obtained by
integrating information developed during the exposure
and toxicity assessments to characterize the potential
or actual risk, including carcinogenic risks,
noncarcinogenic risks, and environmental risks. The
final analysis should include a summary of the risks
associated with a site including each projected
exposure route for contaminants of concern and the
distribution of risk across various sectors of the
population. In addition, such factors as the weight-
of-evidence associated with toxicity information, and
any uncertainties associated with exposure
assumptions should be discussed.
Characterization of the environmental risks involves
identifying the potential exposures to the surrounding
ecological receptors and evaluating the potential
effects associated with such exposure(s). Important
factors to consider include disruptive effects to
populations (both plant and animal) and the extent of
perturbations to the ecological community.
The results of the baseline risk assessment may
indicate that the site poses little or no threat to human
health or the environment. In such situations, the FS
should be either scaled down as appropriate to that
site and its potential hazard, or eliminated altogether.
The results of the Rl and the baseline risk
assessment will therefore serve as the primary means
of documenting a no-action decision. If it is decided
that the scope of the FS will be less than what is
presented in this guidance or eliminated altogether,
the lead agency should document this decision and
receive the concurrence of the support agency.
3.4.3 Evaluate Data Needs
As data are collected and a better understanding of
the site and the risks that it poses are obtained, the
preliminary remedial action alternatives developed
during scoping should be reviewed and refined. The
available data should be evaluated to determine if
they are sufficient to develop remedial alternatives. If
they are not, additional data gathering will be
required. When sufficient data are available, remedial
response objectives with respect to the contaminants
of concern, the areas and volumes of contaminated
media, and existing and potential exposure routes and
receptors of concern can be developed as part of the
FS.
3.5 Data Management Procedures
An Rl may generate an extensive amount of
information, the quality and validity of which must be
consistently well documented because this
information will be used to support remedy selection
decisions and any legal or cost recovery actions.
Therefore, field sampling and analytical procedures
for the acquisition and compilation of field and
laboratory data are subject to data management
procedures. "The discussion on data management
'Additional guidance on developing reasonable maximum
exposure scenarios will be provided in the upcoming revision of
the SPHEM.
DQOs will govern the data management procedures used,
and the QAPP/FSP will identify both field-collected and
analytical data. Information to be recorded should include
sampling information, recording procedures, sample
management, and QC concerns.
3-23
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Identification of Contaminants
of Concern
Identify Based on:
• Intrinsic lexicological Properties
• Quantity Present
• Potentially Critical Exposure Routes
• Utility as Indicator Chemicals
Exposure Assessment
Identify Potential Exposure
Pathways and Routes
Characterize Potential
Receptors
Estimate Expected Exposure
Levels
Toxicity Assessment
Evaluate Adverse Effects
of Exposures
Evaluate Uncertainties/
Weight of Evidence
Risk
Characterization
Estimate Potential for
Adverse Health or
Environmental Effects
Based On:
• Carcinogenic Risks
• Noncarcinogenic Risks
• Environmental Risks
Figure 3-3. Components of the risk assessment process.
3-24
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procedures is divided into three categories: field
activities, sample management and tracking, and
document control and inventory.
3.5.1
Field Activities
During site characterization and sampling, consistent
documentation and accurate recordkeeping
procedures are critical because subsequent decisions
will be made on the basis of information gathered
during these tasks. Aspects of data management for
sampling activities during site characterization include:
• Quality Assurance/Quality Control (QA/QC)
Plans - These documents provide records of
responsibility, adherence to prescribed protocols,
nonconformity events, corrective measures, and
data deficiencies.
• A Data Security System - This system outlines
the measures that will be taken in the field to
safeguard chain-of-custody records and
prevent free access to project records, thereby
guarding against accidental or intentional loss,
damage, or alteration.
• Field Logs - The daily field logs are the primary
record for field investigation activities and should
include a description of any modifications to the
procedures outlined in the work plan, field
sampling plan, or health and safety plan, with
justifications for such modifications. Field
measurements and observations should be
recorded directly into the project log books.
Examples of field measurements include pH,
temperature, conductivity, water flow, air quality
parameters, and soil characteristics. Health and
safety monitoring, sampling locations, sampling
techniques, and a general description of daily
activity are typically included in the daily log. Any
unusual occurrences or circumstances should be
documented in these logs and can be used for
reference in determining the possible causes for
data anomalies discovered during data analysis.
Data must be recorded directly and legibly in field
log books with entries signed and dated. Changes
made to original notes should not obliterate the
original information and should be dated and
signed. Standard format information sheets
should be used whenever appropriate and should
be retained in permanent files.
Documentation involved in maintaining field sample
inventories and proper chain-of-custody records
may include the following11:
Specific requirements may vary between state- and
federal-lead sites.
• Sample Identification Matrix
• Sample Tag
• Traffic Report
• High-Hazard Traffic Report
•SAS Packing List
•Chain-of-Custody Form
• Notice of Transmittal
• Receipt for Samples Form
• Central Regional Laboratory (CRL) Sample Data
Report
• Shipping Airbill
Additional information for each of these items, along
with the instructions for their completion, can be
found in Section 6.2 of the Compendium.
3.5.2 Sample Management and Tracking
A record of sample shipments, receipt of analytical
results, submittal of preliminary results for QA/QC
review, completion of QA/QC review, and evaluation
of the QC package should be maintained to ensure
that only final and approved analytical data are used
in the site analysis. In some instances, the use of
preliminary data is warranted to prepare internal
review documents, begin data analysis while
minimizing lost time for the turnaround of QA/QC
comments, and continue narrowing remedial action
alternatives. Preliminary data are considered
unofficial, however, and preliminary data used in
analyses must be updated upon receipt of official
QA/QC comments and changes. Sample results
should not be incorporated in the site characterization
report unless accompanied by QA/QC comments.
The DQOs stated for each task involving sample
analysis must specify whether the information is valid
with qualifiers or not and must specify which qualifiers
can invalidate the use of certain data. For instance,
reproducibility of plus or minus 20 percent may be
acceptable in a treatability study but may not be
acceptable for determining the risk to human health
from drinking water. Acceptability of data quality is not
established until the reviewed QA/QC package
accompanies the analytical data.
The acceptable QA/QC package should be defined in
the approved site QAPP for each discrete task.
Where use of the CLP is involved, review by the CRL
QA Office is typical but may vary from one Region to
the next and may vary from one state to the next in
the case of state-lead sites. Nevertheless, the
3-26
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DQOs outlined for the use of the data will dictate the
level of review required.
3.5.3 Document Control and Inventory
Sample results should be managed in a standardized
form to promote easy reporting of data in the site
characterization report. Precautions should be taken
in the analysis and storage of the data collected
during site characterization to prevent the introduction
of errors or the loss or misinterpretation of data.
The document inventory and filing systems can be
set up on the basis of serially numbered documents.
These systems may be manual or automated. A
suggested structure and sample contents of a file for
Superfund activities are shown in Table 3-11. The
relationship of this filing system to the Administrative
Record is discussed in the "Interim Guidance on
Administrative Records for Selection of CERCLA
Response Actions" (U.S. EPA, Draft, June 1988).
3.6 Community Relations Activities
During Site Characterization
Two-way communication with interested members of
the community should be maintained throughout the
Rl. The remedial project manager and Community
Relations Coordinator keep local officials and
concerned citizens apprised of site activities and of
the schedule of events by implementing several
community relation activities. These actions are
usually delineated in the community relations plan and
typically include, but are not limited to, public
information meetings at the beginning and end of the
Rl; a series of fact sheets that will be distributed to
the community during the investigation and will
describe up-to-date progress and plans for
remedial activities; telephone briefings for key
members of the community, public officials and
representatives of concerned citizens, and periodic
news releases that describe progress at the site.
The files containing the Administrative Record should
be established once the RI/FS work plan is finalized
and kept at or near the site. It is recommended that
the files containing the Administrative Record be kept
at one of the information repositories for public
information at or near the site and near available
copying facilities. Copies of site-related information
should be made available to the community and
should typically include the RI/FS work plan, a
summary of monitoring results, fact sheets, and the
community relations plan. The objective of community
relations activities during the Rl is to educate the
public on the remedial process and keep the
community informed of project developments as they
occur, thereby reducing the likelihood of conflict
arising from a lack of information, misinformation, or
speculation. As directed in the community relations
Table 3-11. Outline of Suggested File Structure for
Superfund Sites
Congressional Inquiries and Hearings:
• Correspondence
• Transcripts
• Testimony
• Published hearing records
Remedial Response:
• Discovery
Initial investigation reports
Preliminary assessment report
- Site inspection report
Hazard Ranking System data
Remedial planning
- Correspondence
- Work plans for RI/FS
- RI/FS reports
Health and safety plan
- QA/QC plan
Record of decision/responsiveness summary
Remedial implementation
Remedial design reports
- Permits
Contractor work plans and progress reports
Corps of Engineers agreements, reports, and
correspondence
State and other agency coordination
- Correspondence
Cooperative agreement/Superfund state contract
State quarterly reports
Status of state assurances
- Interagency agreements
Memorandum of Understanding with the state
Community relations
- Interviews
- Correspondence
Community relations plan
List of people to contact, e.g.. local officials, civic
leaders, environmental groups
- Meeting summaries
- Press releases
- News clippings
- Fact sheets
Comments and responses
- Transcripts
Summary of proposed plan
- Responsiveness summary
Imagery:
• Photographs
• Illustrations
• Other graphics
Enforcement
• Status reports
• Cross-reference to any confidential enforcement files and
the person to contact
• Correspondence
• Administrative orders
Contracts
• Site-specific contracts
• Procurement packages
• Contract status notifications
• List of contractors
Financial Transactions:
• Cross-reference to other financial files and the person to
contact
• Contractor cost reports
• Audit reports
3-27
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plan, all activities should be tailored to the community
and to the site.
3.7 Reporting and Communication
During Site Characterization
During site characterization, communication is
required between the lead agency and the support
agency.12 In addition to routine communication
between members of the lead agency and their
contractor on project progress, written communication
is required between the lead agency and the support
agency as follows:
1. The lead agency should provide the draft work
plan to the support agency for review and
comment (discussed in Chapter 2.)
2. The lead agency should provide information on
contaminant types and affected media to the
support agency for ARAR identification
(chemical- and location-specific ARAR
determinations are finalized once the site
characterization is complete).
3. The lead agency should provide data obtained
during site characterization to ATSDR.13
4. The lead agency should provide a preliminary
summary of site characterization to the support
agency (this may serve as the mechanism for
ARAR identification).
5. The lead agency should provide a draft Rl report
for review and comment by the support agency.
Table 3-12 summarizes the points during site
characterization when written or oral communication
is recommended.
3.7.1
Information for ARA R Identification
The information for the support agency's use in
identifying ARARs should include a description of the
contaminants of concern, the affected media, and any
physical features that may help identify location-
specific ARARs. This information may be supplied by
the preliminary site characterization summary (as
discussed below) or by a letter or other document.
The support agency shall provide location- and
chemical-specific ARARs to the lead agency before
preparation of the draft Rl report.
3.7.2 Preliminary Site Characterization
Summary
A summary of site data following the completion of
initial field sampling and analysis should be prepared.
This summary should briefly review the analytical
results of investigative activities to provide the lead
agency with a reference for evaluating the
development and screening of remedial alternatives.
In addition, the preliminary site characterization
summary may be used to assist the support agency
in identification of ARARs and provide ATSDR with
data (prior to issuance of the draft Rl) to assist in
their health assessment efforts.
The format of this summary is optional and is left to
the discretion of the lead-agency RPM. The format
may range from a technical memorandum, which
simply lists the locations and quantities of
contaminants at the site, to a rough draft of the first
four chapters of the Rl report (see Table 3-13). Use
of the technical memorandum and a progress
meeting is strongly encouraged over the latter to
better facilitate RI/FS schedules and sampling
progress in the field.
3.7.3 Draft Rl Report
A draft Rl report should be produced for review by
the support agency and submitted to ATSDR for its
use in preparing a health assessment and also serve
as documentation of data collection and analysis in
support of the FS. The draft Rl report can be
prepared any time between the completion of the
baseline risk assessment and the completion of the
draft FS. Therefore, the draft Rl report should not
delay the initiation or execution of the FS.
Table 3-13 gives a suggested format for the draft Rl
report. The report should focus on the media of
concern and, therefore, does not need to address all
the site characteristics listed, only those appropriate
at that specific site.
Reporting and communicating during a PRP-lead RI/FS is
discussed in Appendix A and in the forthcoming "Draft
Guidance on Oversight of Potentially Responsible Party
Remedial Investigations and Feasibility Studies."
Guidance for coordinating remedial and ATSDR health
assessment activities is provided in OSWER Directive
9285.4-02.
3-28
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Table 3-12. Reporting and Communication During Site Characterization
Information Needed
Purpose
Potential Methods of
Information Provision
Need to rescope field
activities on the basis of
results of field observations
Need to rescope field
activities on the basis of
results of sample analysis
Preliminary results of field
investigation tasks (e.g.,
geophysical explorations,
monitoring well installation.
etc.)
Descriptive and analytical
results of initial site
characterization results
(excluding risk assessment)
Listing of contaminants,
affected media; location of
wetlands, historic sites, etc.
Refined remedial action
objectives
Documentation of site
characterization field activities
and analyses including any
treatability testing
Needed only if screening indicates that field activities need to be
rescoped; for lead agency and contractor to identify methods to improve
effectiveness of site characterization activities; for lead agency to obtain
support agency review and concurrence
Needed only if analysis of laboratory data indicates field activities need
to be rescoped; for lead agency and contractor to identify methods to
improve effectiveness of site characterization activities; for lead agency
to obtain support agency review and concurrence
Provided by the contractor to the lead agency; need and method of
communication at lead agency's discretion
Provides lead agency with early summary of site data; assists in
supporting agency with identification of ARARs; may also be submitted
to ATSDR for use in preparing health assessment.
For support agency's use in identifying chemical- and location-
specific ARARs.
For lead agency and contractor to define the basis for developing
remedial action alternatives; obtain review and comment from the
support agency
Required for members of lead agency and their contractor to prepare for
public comment and FS support documentation
Meeting
Tech memo
Other
Meeting
Tech memo
Other
Tech memos
Other
Preliminary site
characterization summary
Preliminary site
characterization summary
Meeting
Tech memo
Other
Draft Rl report
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Table 3-13. Suggested Rl Report Format
Executive Summary
1. Introduction
1.1 Purpose of Report
1.2 Site Background
1.2.1 Site Description
1.2.2 Site History
1.23 Previous investigations
1.3 Report Organization
2. Study Area Investigation
2.1 includes field activities associated with site characterization. These may include physical and chemical monitoring of some, but
not necessarily all, of the following:
2.1.1 Surface Features (topographic mapping, etc.) (natural and manmade features)
2.1.2 Contaminant Source Investigations
2.1.3 Meteorological Investigations
2.1.4 Surface-Water and Sediment Investigations
2.1.5 Geological Investigations
2.1.6 Soil and Vadose Zone Investigations
2.1.7 Ground-Water Investigations
2.1.8 Human Population Surveys
2.1.9 Ecological Investigations
2.2 If technical memoranda documenting field activities were prepared, they may be included in an appendix and summarized in this
report chapter.
3. Physical Characteristics of the Study Area
3.1 Includes results of field activities to determine physical characteristics. These may include some, but not necessarily all, of the
following:
3.1.1 Surface Features
3.1.2 Meteorology
3.1.3 Surface-Water Hydrology
3.1.4 Geology
3.1.5 Soils
3.1.6 Hydrogeology
3.1.7 Demography and Land Use
3.1.8 Ecology
4. Nature and Extent of Contamination
4.1 Presents the results of site characterization, both natural chemical components and contaminants in some, but not necessarily all,
of the following media:
4.1.1 Sources (lagoons, sludges, tanks, etc.)
4.1.2 Soils and Vadose Zone
4.1.3 Ground Water
4.1.4 Surface Water and Sediments
4.1.5 Air
5. Contaminant Fate and Transport
5.1 Potential Routes of Migration (i.e., air, ground water, etc.)
5.2 Contaminant Persistence
5.2.1 If they are appliable (i.e., for organic contaminants), describe estimated persistence in the study area environment and
physical, chemical, and/or biological factors of importance for the media of interest.
5.3 Contaminant Migration
5.3.1 Discuss factors affecting contaminant migration for the media of importance (e.g., sorption onto soils, solubility in water,
movement of ground water, etc.)
5.3.2 Discuss modeling methods and results, if applicable.
6. Baseline Risk Assessment
6.1 Human Health Evaluation
6.1.1 Exposure Assessment
6.1.2 Toxicity Assessment
6.1.3 Risk Characterization
6.2 Environmental Evaluation
3 - 30
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Table 3-13 Continued
7. Summary and Conclusions
7.1 Summary
7.1.1 Nature and Extent of Contamination
7.1.2 Fate and Transport
7.1.3 Risk Assessment
7.2 Conclusions
7.2.1 Data Limitations and Recommendations for Future Work
7.2.2 Recommended Remedial Action Objectives
Appendices
A. Technical Memoranda on Field Activities (if available)
B. Analytical Data and QA/QC Evaluation Results
C. Risk-Assessment Methods
3-31
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CHAPTER 4
DEVELOPMENT AND
SCREENING OF ALTERNATIVES
FROM:
• Preliminary
Assessment
• Site Inspection
» NPL Listing
OK.TAILEC
.TERNATIVES
DEVELOPMENT AND
SCREENING
OF ALTERNATIVES
• Identify Potential Treatment
Technologies Containment/
Disposal Requirements for
Residuals or Untreated Waste
• Screen Technologies
• Identify Action-Specific ARARs
• Assemble Technologies into
Alternatives
• Screen Alternatives as
Necessary
^
• Remedial Design
• Remedial Action
\ y
4- 1
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Chapter 4
Development and Screening of Alternatives
4.1 Introduction
4.1.1 Purpose of Alternative Development and
Screening
The primary objective of this phase of the FS is to
develop an appropriate range of waste management
options that will be analyzed more fully in the detailed
analysis phase of the FS. Appropriate waste man-
agement options that ensure the protection of human
health and the environment may involve, depending
on site-specific circumstances, the complete
elimination or destruction of hazardous substances at
the site, the reduction of concentrations of hazardous
substances to acceptable health-based levels, and
prevention of exposure to hazardous substances via
engineering or institutional controls, or some
combination of the above. Alternatives are typically
developed concurrently with the Rl site
characterization, with the results of one influencing
the other in an iterative fashion (i.e., Rl site
characterization data are used to develop alternatives
and screen technologies, whereas the range of
alternatives developed guides subsequent site
characterization and/or treatability studies). An
overview of the entire FS process is presented in the
following subsections.
4.7.2 FS Process Overview
The FS may be viewed (for explanatory purposes) as
occurring in three phases: the development of
alternatives, the screening of the alternatives, and the
detailed analysis of alternatives. However, in actual
practice the specific point at which the first phase
ends and the second begins is not so distinct.
Therefore, the development and screening of
alternatives are discussed together to better reflect
the interrelatedness of these efforts. Furthermore, in
those instances in which circumstances limit the
number of available options, and therefore the
number of alternatives that are developed, it may not
be necessary to screen alternatives prior to the
detailed analysis.
4.1.2.1 Development and Screening of
Alternatives
Alternatives for remediation are developed by
assembling combinations of technologies, and the
media to which they would be applied, into
alternatives that address contamination on a sitewide
basis or for an identified operable unit. This process
consists of six general steps, which are shown in
Figure 4-1 and briefly discussed below:
• Develop remedial action objectives specifying the
contaminants and media of interest, exposure
pathways, and preliminary remediation goals that
permit a range of treatment and containment
alternatives to be developed. The preliminary
remediation goals are developed on the basis of
chemical-specific ARARs, when available, other
available information (e.g., Rfds), and site-
specific risk-related factors.1
• Develop general response actions for each
medium of interest defining containment,
treatment, excavation, pumping, or other actions,
singly or in combination, that may be taken to
satisfy the remedial action objectives for the site.
• Identify volumes or areas of media to which
general response actions might be applied, taking
into account the requirements for protectiveness
as identified in the remedial action objectives and
the chemical and physical characterization of the
site.
• Identify and screen the technologies applicable to
each general response action to eliminate those
that cannot be implemented technically at the
site.2The general response actions are further
'These preliminary remediation goals are reevaluated as site
characterization data and information from the baseline risk
assessment become available.
2It is important to distinguish between this medium-specific
technology screening step during development of alternatives
and the alternative screening that may be conducted
subsequently to reduce the number of alternatives prior to the
detailed analysis.
4-3
-------
S*^ Site ^X
I Characterization j
Establish Remedial Action Objectives
i
Develop General Response
Actions Describing Areas or
Volumes of Media to Which
Containment, Treatment, or
Removal Actions May Be Applied
Identify Potential
Treatment and
Disposal Technologies
and Screen Based on
Technical Implementability
I
Evaluate Process Options Based
on Effectiveness, Implementability,
and Relative Cost, to Select a
Representative Process for each
Technology Type
Repeat Previous Scoping Steps:
- Determine New Data Needs
- Develop Sampling Strategies
and Analytical Support to
Acquire Additional Data
- Repeat Steps in Rl Site
Characterization
Yes
Combine Media-Specific
Technologies into
Alternatives
Detailed Analysis )
\^ of Alternatives J
Figure 4-1 Alternative development.
4-4
-------
defined to specify remedial technology types
(e.g., the general response action of treatment
can be further defined to include chemical or
biological technology types).
• Identify and evaluate technology process options
to select a representative process for each
technology type retained for consideration.
Although specific processes are selected, for
alternative development and evaluation, these
processes are intended to represent the broader
range of process options within a general
technology type.
• Assemble the selected representative technolo-
gies into alternatives representing a range of
treatment and containment combinations, as
appropriate.
Figure 4-2 provides a generic representation of this
process. Section 4.2 contains a more detailed
description and specific examples of alternative
development.
For those situations in which numerous waste
management options are appropriate and developed,
the assembled alternatives may need to be refined
and screened to reduce the number of alternatives
that will be analyzed in detail. This screening aids in
streamlining the feasibility study process while
ensuring that the most promising alternatives are
being considered.
As discussed earlier, in other situations the number of
viable or appropriate alternatives for addressing site
problems may be limited; thus, the screening effort
may be minimized or eliminated if unnecessary. The
scope of this screening effort can vary substantially-
depending on the number and type of alternatives
developed and the extent of information necessary for
conducting the detailed analysis. The scope and
emphasis can also vary depending on either the
degree to which the assembled alternatives address
the combined threats posed by the entire site or on
the individual threats posed by separate site areas or
contaminated media. Whatever the scope, the range
of treatment and containment alternatives initially
developed should be preserved through the
alternative screening process to the extent that it
makes sense to do so.
As part of the screening process, alternatives are
analyzed to investigate interactions among media in
terms of both the evaluation of technologies (i.e., the
extent to which source control influences the degree
of ground-water or air-quality control) and sitewide
protectiveness (i.e., whether the alternative provides
sufficient reduction of risk from each media and/or
pathway of concern for the site or that part of the site
being addressed by an operable unit). Also at this
stage, the areas and quantities of contaminated
media initially specified in the general response
actions may also be reevaluated with respect to the
effects of interactions between media. Often, source
control actions influence the degree to which
ground-water remediation can be accomplished or
the time frame in which it can be achieved. In such
instances, further analyses may be conducted to
modify either the source control or ground-water
response actions to achieve greater effectiveness in
sitewide alternatives. Using these refined alternative
configurations, more detailed information about the
technology process options may be developed. This
information might include data on the size and
capacities of treatment systems, the quantity of
materials required for construction, and the
configuration and design requirements for ground-
water collection systems.
Information available at the time of screening should
be used primarily to identify and distinguish any
differences among the various alternatives and to
evaluate each alternative with respect to its
effectiveness, implementability, and cost. Only the
alternatives judged as the best or most promising on
the basis of these evaluation factors should be
retained for further consideration and analysis.3
Typically, those alternatives that are screened out will
receive no further consideration unless additional
information becomes available that indicates further
evaluation is warranted. As discussed in Section
4.2.6, for sites at which interactions among media are
not significant, the process of screening alternatives,
described here, may be applied to medium-specific
options to reduce the number of options that will
either be combined into sitewide alternatives at the
conclusion of screening or will await further evaluation
in the detailed analyses. Section 4.3 contains more
detail about screening alternatives.
4.1.2.2 Detailed Analysis of Alternatives
During the detailed analysis, the alternatives brought
through screening are further refined, as appropriate,
and analyzed in detail with respect to the evaluation
criteria described in Chapter 6. Alternatives may be
further refined and/or modified based on additional
site characterization or treatability studies conducted
as part of the Rl. The detailed analysis should be
conducted so that decision-makers are provided
with sufficient information to compare alternatives with
respect to the evaluation criteria and to select an
appropriate remedy. Analysis activities are described
in greater detail in Chapter 6.
3 As with the use of representative technologies, alternatives
may be selected to represent sufficiently similar management
strategies; thus, in effect, a separate analysis for each
alternative is not always warranted.
4-5
-------
O)
Media
medium #1
medium #2
-*•
I
u,
r— *•
— •»
Identity Process Options
and Screen Technologies/
Remedial Action General Response Identity Options Based on Technical
Objectives Actions Technology Types Imptementabllty
remedial action tJ
objective «1-1 1
\/
X
/ L
remedial action
objective* 1-2 — ^
abjective *2-1
X
'emediaJ action
.+{ technology ft |
general response —
action »1-1
general response —
action* 1-2
action *2-1
i
general response -
^technology K//\
L»4J technology *4 I
r-»>| technology «1 j
L>j technology *5 [
|-k»| technology *4 |
-•^technology *6 '/^
L*| technology *7 j
i nm^^ -. *
| process *2B —
K,process *3A ////\
I [/process !3B, '///X
1 process *4A
' 1 pnxess*4B
1 process *1A
| process *1C
I 1 process *1D
EvaJuale Process
Options Based on
Effectlveneu,
Institutional ConMne Into AltemattvM
trnplementaoHsty. the Selected Representative
and Relative Cost Processes for Affected Media
1 nrooflsfi *1B 1 \ /
\. /
| process *2B |y / *
process *4A ^ / /\
proc».«B |W / /
. .. — . v\/ /
proce...tA |A^ /
i 1 / V \ /
proce»*1C I/ A /
process *10 {/ W \
t^ nrrkrnr 11" MA A " f f f f\
1 / , , , f S / / / \
FyrT ' "» irA ^ f ^ ,f\
v*. I »OA / / f yi
J >^ _*_»^.« "«y*n f f f J \
\ nrnrsMfi JI7R L
1 ' '
nrnrmft fSR 1 / \ S~
J pmnwfl »4C K^ \
\
Alternative* 1:
• medium 1 • process 1A
• medium 2 - process ID
Alternative *2:
• medium t - process 1A
' medium 2 - process 5A
Alternative *3:
• medium 1 - process 28
• medium 2 - process 4C
Alternative *4:
• medium 1 - process 4A
• medium 2 - process 4C
Alternative (5:
• medium 1 - process 4A
• medium 2 • process 7B
Legend: \///\ - Process options that are screened out | | . process options selected to represent technology type
* Note: The combination ol medium-technology options into sitewide alternatives may be conducted laler in the FS il media interactions are insignificant.
Figure 4-2. Generic alternative development process.
-------
4.1.3 Alternative Ranges
Alternatives should be developed that will provide
decision-makers with an appropriate range of
options and sufficient information to adequately
compare alternatives against one another. In
developing alternatives, the range of options will vary
depending on site-specific conditions. A general
description of ranges for source control and ground-
water response actions that should be developed, as
appropriate, are described below.
4.1.3.1 Source Control Actions
For source control actions, the following types of
alternatives should be developed to the extent
practicable:
• A number of treatment alternatives ranging from
one that would eliminate or minimize to the extent
feasible the need for long-term management
(including monitoring) at a site to one that would
use treatment as a primary component of an
alternative to address the principal threats at the
site."Alternatives within this range typically will
differ in the type and extent of treatment used
and the management requirements of treatment
residuals or untreated wastes.
• One or more alternatives that involve containment
of waste with little or no treatment but protect
human health and the environment by preventing
potential exposure and/or reducing the mobility of
contaminants.
• A no-action alternative5
Figure 4-3 conceptually illustrates this range for
source control alternatives.
Development of a complete range of treatment
alternatives will not be practical in some situations.
For example, for sites with large volumes of low
concentrated wastes such as some municipal landfills
and mining sites, an alternative that eliminates the
need for long-term management may not be
reasonable given site conditions, the limitations of
technologies, and extreme costs that may be
involved. If a full range of alternatives is not
"Alternatives for which treatment is a principal element could
include containment elements for untreated waste or treatment
residuals as well.
'Although a no-action alternative may include some type of
environmental monitoring, actions taken to reduce the potential
for exposure (e.g., site fencing, deed restrictions) should not be
included as a component of the no-action alternatives. Such
minimal actions should constitute a separate "limited" action
alternative.
developed, the specific reasons for doing so should
be briefly discussed in the FS report to serve as
documentation that treatment alternatives were
assessed as required by CERCLA.
4.1.3.2 Ground-water Response Actions
For ground-water response actions, alternatives
should address not only cleanup levels but also the
time frame within which the alternatives might be
achieved. Depending on specific site conditions and
the aquifer characteristics, alternatives should be
developed that achieve ARARs or other health-
based levels determined to be protective within
varying time frames using different methodologies.
For aquifers currently being used as a drinking water
source, alternatives should be configured that would
achieve ARARs or risk-based levels as rapidly as
possible. More detailed information on developing
remedial alternatives for ground-water response
actions may be found in "Guidance on Remedial
Actions for Contaminated Ground Water at Super-fund
Sites" (U.S. EPA, August 1988).
4.2 Alternative Development Process
The alternative development process may be viewed
as consisting of a series of analytical steps that
involves making successively more specific definitions
of potential remedial activities. These steps are
described in the following sections.
4.2.7 Develop Remedial Action Objectives
Remedial action objectives consist of medium-
specific or operable unit-specific goals for protecting
human health and the environment. The objectives
should be as specific as possible but not so specific
that the range of alternatives that can be developed is
unduly limited. Column two of Table 4-1 provides
examples of remedial action objectives for various
media.
Remedial action objectives aimed at protecting human
health and the environment should specify:
• The contaminant(s) of concern
• Exposure route(s) and receptor(s)
• An acceptable contaminant level or range of
levels for each exposure route (i.e., a preliminary
remediation goal)
Remedial action objectives for protecting human
receptors should express both a contaminant level
and an exposure route, rather than contaminant levels
alone, because protectiveness may be achieved by
reducing exposure (such as capping an area, limiting
access, or providing an alternate water supply) as
well as by reducing contaminant levels. Because
4-7
-------
1. No action
I'Hot" Spots
Soil
Exceeds
1x10'4Risk
Soil
Exceeds
1x10'6Risk
Background
2. Treatment which eliminates or minimizes to the extent feasible the need for long-term
management.
2A. All Contaminated Soil
Excavated and Treated
2B. All Soil Above 1x10 "
Excavated & Treated
Figure 4-3 Conceptual treatment range for source control.
4-8
-------
3. Alternatives using treatment as a principal element
"Hot" Spots Excavated
& Treated
4. Containment with little or no treatment
Figure 4-3 (Continued)
4-9
-------
Table 4-1. Example of Remedial Action Objectives, General Response Actions, Technology Types, and Example
Process Options for the Development and Screening of Technologies
Environmental Remedial Action Objectives
Media (trim site characterization)
Ground Hater For Human Health:
Prevent IngestIon of water
having [carcinogen(s)] In
excess of [MCLIsl] and a
total excess cancer risk (for
all contaminants! of greater
than 10 to 10 .
Prevent ingestion of water
having [non-carcinogen(s)] In
excess of [MCDsl] or
(reference dose(s)].
For Environmental Protection:
Restore ground water aquifer
to [concentration(s)] for
(contamlnant(s)].
General Response Actions
(tor all remedial action objectives)
No Action/Institutional Actions:
No action
Alternative residential water supply
Monitoring
Containment Actions:
Contalnnent
Collection/Treatment Actions:
Collectlon/tieat»ent discharge/
In situ groundwater treatment
Individual home treatment units
Remedial Technology Types
(tor general response actions)
No Action/Institutional Options:
Fencing
Deed restrictions
Containment Technologies:
Capping
Vertical barriers
Horizontal barriers
Extraction Technologies:
Ground water collection/pumping
Enhanced removal
Treatment Technologies:
Physical treatment
Chemical treatment
In situ treatment
Disposal Technologies:
Discharge to FOTH (after
treatment)
Discharge to surface
water (after treatment)
Process Options
Clay cap, synthetic membrane, multi-layer
Slurry wall, sheet piling
Liners, grout Injection
Nells, subsurface or leachate collection
Solution mining, vapor extraction, enhanced
oil recovery
Coagulatlon/flocculatlon, oil-water separa-
tion, air stripping, adsorption
Neutralization, precipitation. Ion exchange
oxidation/reduction
Subsurface bloreclamatlon
Soil
For Human Health;
Prevent Ingestlon/direct
contact with soil having
[non-carcinogen(s)] in
excess of [reference
dose(s)].
Prevent direct contact/
ingestion with soil having
10 to 10 excess cancer
ilsk from [carcinogen(s)).
Prevent Inhalation of
[carcinogen(s)] posing excess
cancer risk levels of 10 to
10"7.
For Environmental Protection:
Prevent migration of
contaminants that would
result In ground water
contamination In excess of
[concentration(s)] for
[contaminant(s)].
No Action/Institutional Actions:
No action
Access restrictions
Containment Actions:
Containment
Excavation/Treatment Actions:
Excavatlon/treatment/dlsposal
In situ treatment
Disposal excavation
No Action/Institutional Options:
Fencing
Deed restrictions
Containment Technologies:
Capping
Vertical barriers
Horizontal barriers
Surface controls
Sediment control barriers
Dust controls
Removal Technologies:
Excavation
Treatment Technologies:
Solidification, fixation,
stabilization. Immobilization
Dewatering
Physical treatment
Chemical treatment
Biological treatment
In situ treatment
Thermal treatment
Clay cap, synthetic membrane, multi-layer
Slurry wall, sheet piling
Liners, grout Injection
Diversion/collection, grading, boil
stabilization
Coffer dams, curtain barriers
Revegetatlon, capping
Solids excavation
Sorption, pozzolanlc agents, encapsulation
Belt filter press, dewaterlng, and drying beds
Hater/solvent leaching (with subsequent
liquids treatment)
Lime neutralization
Cultured micro-organisms
Surface bloreclamatlon
Incineration, pyrolysls
-------
Table 4-1. Continued
Environmental Remedial Action Objectives
Media (from site character!ration)
Surface Water For Human Health;
Prevent Ingestlon of water
having (carcinogen(si) in
excess o£ (HCLs] and a total
excess cancer risk of greater
than 10 to 10 .
Prevent ingestion of water
having [non-carcinogen(s)J In
excess of [NCLs] or
(reference dose(s)].
For Environmental Protection:
Restore surface water to
[ambient water quality
criteria] for
[contaminant(s)].
General Response Actions
(tor all remedial action objectives)
No Action/Institutional Actions:
No action
Access restrictions
Monitoring
Collection/Treatment Actions:
Surface water runoff Interception/
treatment/discharge
Remedial Technology Types
(for general response actions)
No Action/Institutional Options:
Fencing
Deed restrictions
Collection Technologies:
Surface controls
Treatment Technologies:
Physical treatment
Chemical treatment
Biological treatment
(organlcs)
In situ treatment
Disposal Technologies:
Discharge to PON (after
treatment)
Process Options
Grading, diversion, and collection
Coagulation/flocculatlon, oil-water separa-
tion, filtration, adsorption
Precipitation, Ion exchange, neutralisation,
freeze crystallisation biological treatment.
Aerobic and anaerobic spray Irrigation
In situ precipitation, In situ bioreclamation
Sediment
For Hum
Health:
Prevent direct contact with
sediment having
(carcinogen-Is)] In excess of
10 to 10 —-~«- —~—.—
risk.
excess cancer
For Environmental Protection:
Prevent releases of
(contaminant(s)J from
sediments that would result
In surface water levels In
excess of [ambient water
quality criteria].
No Action/Institutional Actions:
No action
Access restrictions to
Monitoring
Excavation Actions:
Excavation
Excavation/Treatment Actions:
Removal/di sposal
Removal/treatment/disposal
No Action/Institutional Options:
Fencing
Deed restrictions
Removal Technologies:
Excavation
Containment Technologies:
Capping
Vertical barriers
Horizontal barriers
Sediment control barriers
Treatment Technologies:
Solidification, fixation,
stabilization
Dewaterlng
Physical treatment
Chemical treatment
Biological treatment
In situ treatment
Thermal treatment
Sediments excavation
Removal with clay cap, multi-layer, asphalt
Slurry wall, sheet piling
Liners, grout Injection
Coffer dams, curtain barriers, capping
barriers
Sorptlon, ponolanlc agents, encapsulation
Sedimentation, dewaterlng and drying beds
Hater/solids leaching (with subsequent
treatment)
Neutralization, oxidation, electrochemical
reduction
Landfarming
Surface bioreclamation
Incineration, pyrolysls
Air
For Human Health:
Prevent inhalation of
(carcinogenls)] in excess of
10 to 10 excess cancer
risk.
No Action/Institutional Actions:
No action
Access restrictions to Monitoring
Collection Actions:
Gas collection
No Action/Institutional Options:
Fencing
Deed restrictions
Removal Technologies:
Landfill gas collection
Passive vents, active gas collection syste
-------
Table 4-1. Continued
Environmental
Media
Structures
Remedial Action Objectives
dram site characteriiatlon)
For
Health;
Prevent direct contact with
[carclnogen^s)) in excess of
10 " to 10
risk.
excess cancer
to
Prevent migration of
[carcinogen (s» which would
result in ground water
concentrations in excess of
[NCLs] or 10 * to 10 total
excess cancer risk level.
Prevent migration of
[carcinogen (s)] which would
result in soil concentrations
in excess of [reference
dose(s)].
For Environmental Protection:
Prevent migration of
[contaminants] that would
result in ground water
concentrations In excess of
[concentration(s)].
General Response Actions
(tor all remedial action objectives)
No Action/Institutional Actions:
No action
Access restrictions
Demolition/Treatment Actions:
Denollt ion/disposal
Decontamination
Remedial Technology Types
(tor general response actions)
No Action/Institutional Options:
Fencing
Deed restrictions
Removal Technologies:
Demolition
Excavation
Treatment Technologies:
Solids processing
Solids treatment
Process Options
Demolition
Excavation, debris removal
Magnetic processes, crushing and grinding,
screening
Hater leaching, solvent leaching, steam
cleaning
Solid Hastes For Human Health;
Prevent ingestlon/dlrect
contact with wastes having
[non-carcinogen(s)] in excess
of [reference dose(s)].
Prevent ingestlon/direct
contact wljh wastes having
10 to 10 excess cancer
risk from [carcinogen(s)].
Prevent inhalation of
[carcinogen(s)] posing excess
cancer risk levels of 10 to
10~7.
Prevent migration of
[carcinogen(s)] which would
result in ground water
concentrations In excess of
[HCLs] or 10 * to 10 total
excess cancer risk levels.
No Action/Institutional Actions:
No action
Access restrictions to [location]
Containment Actions:
Containment
Excavation/Treatment Actions:
Removal/disposal
Removal/treatment/disposal
No Action/Institutional Options:
Fencing
Deed restrictions
Containment Technologies:
Capping
Vertical barriers
Horizontal barriers
Removal Technologies:
Excavation
Drum removal
Treatment Technologies:
Physical treatment
Chemical treatment
Biological treatment
Thermal treatment
Solids processing
Clay cap, synthetic membranes, multi-layer
Slurry wall, sheet piling
Liners, grout injection
Dust controls
Solids excavation
Drum and debris removal
Hater/solvent leaching (with subsequent
liquids treatment)
Neutralization
Cultured micro-organisms
Incineration, pyrolysis, gaseous
Incineration
Crushing and grinding, screening,
classification
-------
Table 4-1. Continued
Environmental
Media
Solid Wastes
{continued)
Remedial Action Objectives
(from site characterisation)
For Environmental Protection:
Prevent migration of
contaminants that would
result In ground water
contamination in excess of
[concentratlon(s)) for
[contaminant(s)].
General Response Actions
(for all remedial action objectives!
Remedial Technology Types
(for general response actions)
Process Options
Liquid Hastes For Human Health:
Prevent Ingest Ion/direct
contact with wastes having
[non-carclnogentsl] In excess
of [reference dose(s)].
Prevent Ingestlon/dlrect
contact with wastes having
10~ to 10~ excess cancer
risk from [carcinogen(s) ] .
Prevent inhalation of
[carcinogen(s)] posing ex jess
cancer
10 .
GO
risk levels of 10 to
Prevent migration of
[carcinogen (s)) which would
result In groundwater
concentrations In excmss of
[MCLs] or 10 to 10 total
excess cancer risk levels.
No Action/Institutional Actions:
No action
Access restrictions to [location]
Containment Actions:
Containment
Removal/Treatment Actions:
Remova1/d1sposal
Removal/treatment/disposal
No Action/Institutional Options:
Fencing
Deed restrictions
Containment Technologies:
Vertical barriers
Horizontal barriers
Removal Technologies:
Bulk liquid revoval
Drum removal
Treatment Technologies:
Physical treatment
Chemical treatment
Biological treatment
Thermal treatment (organlcs)
Disposal Technologies:
Product reuse
Discharge to POTW (after
treatment)
Slurry wall
Liners
Bulk liquid removal
Drum removal
Coagulatlon/flocculatIon, adsorption,
evaporation, distillation
Neutralization, oxidation, reduction,
photolysis
Aerobic/anaerobic biological treatment,
biotechnologies Incineration, pyrolysls,
co-disposal
Tor Environmental Protection:
Prevent migration of
contaminants that would
result in groundwater
contamination in excess of
(concentratlon(s)l for
[contaminant!si].
Sludges
For Human Health:
Prevent direct contact with
sludge having (carclnogenls))
in excess of 10 to 10
excess cancer risk.
Prevent ingestion/contact
with sludge having
[non-carclnogen(s)] In excess
of [reference dose(s)].
No Action/Institutional Actions:
No action
Access restrictions to [location)
Containment Actions:
Containment
Removal/Treatment Actions:
Removal/disposa]
No Action/Institutional Options:
Fencing
Deed restrictions
Containment Technologies:
Vertical barriers
Horizontal barriers
Removal Technologies:
Bulk sludge removal
Drum removal
Treatment Technologies:
Solidification, fixation
Slurry wall, sheet piling
Liners
Semi-solid excavation, pumping
Drum removal
Sorption, pozzolanlc agents, encapsulation
-------
Table 4-1. Continued
Environmental Remedial Action Objectives
Hedta (from site characterization)
Sludges Prevent Migration of
(continued) [carcinogen(s)] which would
result in ground water
concentrations In excess of
JO to 10 excess cancer
risk.
For Environmental Protection:
Prevent releases of
[contaminant(s)J from sludge
that would result In surface
water levels In excess of
[ambient water quality
criteria].
Prevent releases of
[contaminant(B)] from sludge
that would result In
ground water levels of
[contaminant(s)) In excess of
(concentration)*)].
General Response Actions
(for all remedial action objectives)
Reaoval/lreatment/dlsposal
Renedial Technology Types
(tor general response actions)
Physical treatment
Chemical treatment
Biological treatment
Thermal treatment (organlcs)
Dewaterlng
Disposal Technologies:
Product reuse
I.an.ltilling (after treatnent)
Process Options
Freeze crystallization, neutralization,
oxidation, electrochemical reduction
Oxidation, reduction, photolysis
Aerobic/anaerobic treatnent, land treat-
ment new biotechnologies
Incineration, pyrolysls, co-disposal
Gravity thickening, belt filter press,
vacuun filtration
-------
remedial action objectives for protecting
environmental receptors typically seek to preserve or
restore a resource (e.g., as ground water),
environmental objective(s) should be expressed in
terms of the medium of interest and target cleanup
levels, whenever possible.
Although the preliminary remediation goals are
established on readily available information [e.g.,
reference doses (Rfds) and risk-specific doses
(RSDs)] or frequently used standards (e.g., ARARs),
the final acceptable exposure levels should be
determined on the basis of the results of the baseline
risk assessment and the evaluation of the expected
exposures and associated risks for each alternative.
Contaminant levels in each media should be
compared with these acceptable levels and include an
evaluation of the following factors:
• Whether the remediation goals for all carcinogens
of concern, including those with goals set at the
chemical-specific ARAR level, provides
protection within the risk range of 10"to 107.
• Whether the remediation goals set for all non-
carcinogens of concern, including those with
goals set at the chemical-specific ARAR level,
are sufficiently protective at the site.
• Whether environmental effects (in addition to
human health effects) are adequately addressed.
• Whether the exposure analysis conducted as part
of the risk assessment adequately addresses
each significant pathway of human exposure
identified in the baseline risk assessment. For
example, if the exposure from the ingestion of fish
and drinking water are both significant pathways
of exposure, goals set by considering only one of
these exposure pathways may not be adequately
protective. The SPHEM provides additional details
on establishing acceptable exposure levels.
4.2.2 Develop General Response Actions
General response actions describe those actions that
will satisfy the remedial action objectives. General
response actions may include treatment, containment,
excavation, extraction, disposal, institutional actions,
or a combination of these. Like remedial action
objectives, general response actions are medium-
specific.
General response actions that might be used at a site
are initially defined during scoping and are refined
throughout the RI/FS as a better understanding of site
conditions is gained and action-specific ARARs are
identified. In developing alternatives, combinations of
general response actions may be identified,
particularly when disposal methods primarily depend
on whether the medium has been previously treated.
Examples of potential general response actions are
included in column three of Table 4-I.
4.2.3 Identify Volumes or Areas of Media
During the development of alternatives an initial
determination is made of areas or volumes of media
to which general response actions might be applied.
This initial determination is made for each medium of
interest at a site. To take interactions between media
into account, response actions for areas or volumes
of media are often refined after sitewide alternatives
have been assembled. The refinement of alternatives
is discussed at greater length in Section 4.3.1.
Defining the areas or volumes of media requires
careful judgment and should include a consideration
of not only acceptable exposure levels and potential
exposure routes, but also site conditions and the
nature and extent of contamination. For example, in
an area with contamination that is homogeneously
distributed in a medium, discrete risk levels (e.g.,
1 O5, 106) or corresponding contaminant levels
may provide the most rational basis for defining areas
or volumes of media to which treatment, containment,
or excavation actions may be applied. For sites with
discrete hot spots or areas of more concentrated
contamination, however, it may be more useful to
define areas and volumes for remediation on the
basis of the site-specific relationship of volume (or
area) to contaminant level. Therefore, when areas or
volumes of media are defined on the basis of site-
specific considerations such as volume versus
concentration relationships, the volume or area
addressed by the alternative should be reviewed with
respect to the remedial action objectives to ensure
that alternatives can be assembled to reduce
exposure to protective levels.
4.2.4 Identify and Screen Remedial
Technologies and Process Options
In this step, the universe of potentially applicable
technology types and process options is reduced by
evaluating the options with respect to technical
implementability. In this guidance document, the term
"technology types" refers to general categories of
technologies, such as chemical treatment, thermal
destruction, immobilization, capping, or dewatering.
The term "technology process options" refers to
specific processes within each technology type. For
example, the chemical treatment technology type
would include such process options as precipitation,
ion exchange, and oxidation/reduction. As shown in
columns four and five of Table 4-1, several broad
technology types may be identified for each general
response action, and numerous technology process
options may exist within each technology type.
Technology types and process options may be
identified by drawing on a variety of sources including
4-15
-------
references developed for application to Superfund
sites and more standard engineering texts not
specifically directed toward hazardous waste sites.
Some of these sources are included in Appendix D of
this document.
During this screening step, process options and entire
technology types are eliminated from further
consideration on the basis of technical
implementability. This is accomplished by using
readily available information from the Rl site
characterization on contaminant types and
concentrations and onsite characteristics to screen
out technologies and process options that cannot be
effectively implemented at the site.
Two factors that commonly influence technology
screening are the presence of inorganic
contaminants, which limit the applicability of many
types of treatment processes, and the subsurface
conditions, such as depth to impervious formations or
the degree of fracture in bedrock, which can limit
many types of containment and ground-water
collection technologies. This screening step is site-
specific, however, and other factors may need to be
considered. Figure 4-4 provides an example of initial
technology screening for ground-water remediation
at a site having organic and inorganic contaminants
and shallow, fractured bedrock.
As with all decisions during an RI/FS, the screening of
technologies should be documented. For most
studies, a figure similar to Figure 4-4 provides
adequate information for this purpose and can be
included in the FS report.
4.2.5 Evaluate Process Options
In the fourth step of alternative development, the
technology processes considered to be
implementable are evaluated in greater detail before
selecting one process to represent each technology
type. One representative process is selected, if
possible, for each technology type to simplify the
subsequent development and evaluation of
alternatives without limiting flexibility during remedial
design. The representative process provides a basis
for developing performance specifications during
preliminary design; however, the specific process
actually used to implement the remedial action at a
site may not be selected until the remedial design
phase. In some cases more than one process option
may be selected for a technology type. This may be
done if two or more processes are sufficiently
different in their performance that one would not
adequately represent the other.
Process options are evaluated using the same criteria
- effectiveness, implementability, and cost - that are
used to screen alternatives prior to the detailed
analysis. An important distinction to make is that at
this time these criteria are applied only to
technologies and the general response actions they
are intended to satisfy and not to the site as a whole.
Furthermore, the evaluation should typically focus on
effectiveness factors at this stage with less effort
directed at the implementability and cost evaluation.
Because of the limited data on innovative
technologies, it may not be possible to evaluate these
process options on the same basis as other
demonstrated technologies. Typically, if innovative
technologies are judged to be implementable they are
retained for evaluation either as a "selected" process
option (if available information indicates that they will
provide better treatment, fewer or less adverse
effects, or lower costs than other options), or they will
be "represented" by another process option of the
same technology type. The evaluation of process
options is illustrated in Figure 4-5 and discussed in
more detail below.
4.2.5.1 Effectiveness Evaluation
Specific technology processes that have been
identified should be evaluated further on their
effectiveness relative to other processes within the
same technology type. This evaluation should focus
on: (1) the potential effectiveness of process options
in handling the estimated areas or volumes of media
and meeting the remediation goals identified in the
remedial action objectives;6(2) the potential impacts
to human health and the environment during the
construction and implementation phase; and (3) how
proven and reliable the process is with respect to the
contaminants and conditions at the site.
Information needed to evaluate the effectiveness of
technology types for the different media includes
contaminant type and concentration, the area or
volume of contaminated media, and, when
appropriate, rates of collection of liquid or gaseous
media. For some media it may be necessary to
conduct preliminary analyses or collect additional site
data to adequately evaluate effectiveness. This is
often the case for processes in which the rates of
removal or collection and treatment are needed for
evaluation, such as for ground-water extraction,
surface-water collection and treatment, or
subsurface gas collection. In such cases, a limited
conceptual design of the process may need to be
developed, and modeling of the potential
environmental transport mechanisms associated with
their operation may be undertaken. Typically,
however, such analyses are conducted during the
6The ability of some collection/removal systems, such as
ground-water pumping, to sufficiently recover contaminated
media for subsequent treatment may also be assessed as part
of this evaluation.
4-16
-------
Ground Water General
Response Actions
Remedial Technology Process Options
Description
Screening Comments*
No acton
Deeds for property in the area of Influence
would include restrictions on wells
Extension of existing municipal well system
to serve residents In the area of Influence
New uncontamlnated wells to serve residents
in the area of Influence
Ongoing monitoring of wells
Series of wells to extract contaminated
ground water
Injection wells Inject uncontamlnated
water to Increase flow to extraction wells
Perforated pipe in trenches backfilled with
porous media to collect contaminated water
Extracted water discharged to stream on
the site
— '"beep welflnfection ' f///\ Extracted water discharged to deep well
^/ .;.<<'... / / / /\ injection system
Extracted water discharged to local POTW
for treatment
Extracted water discharged to river offsite
POTW
Pipeline to river
Cap
Clay and soil
Asphalt
Concrete
Multimedia cap
^^^. '/////A
Compacted day covered with soil over areas
of contamination
Spray application of a layer of asphalt over
areas of contamination
Installation of a concrete slab over areas
of contamination
Clay and synthetic membrane covered by soil
over areas of contamination
Trench around areas of contamination is filled
with a soil (or cement) bentonite slurry
Pressure injection of grout In a regular pattern
of drilled holes
Vibrating force to advance beams into the ground
with injection of slurry as beam Is withdrawn
Pressure injection of grout at depth through
closely spaced drilled holes
In conjunction with vertical barriers, injection
of slurry in notched injection holes
Required for consideration by NCP
Potentially applicable
Potentially applicable
Potentially applicable
Potentially applicable
Not feasible for Intercepting contaminants
in fractured bedrock
Not feasible for Intercepting contaminants
in fractured bedrock
Potentially applicable
Potentially applicable
Deep aquifer not suitable lor injection
of contaminants
Potentially applicable
Potentially applicable
Potentially applicable
Potentially applicable
Potentially applicable
Potentially applicable
Not feasible because of very shallow depth
to bedrock
Not effective because of fractured bedrock
Not feasible because of very shallow depth
to bedrock
Not effective because of fractured bedrock
Not feasible because of very shallow depth
to bedrock
Legend if s s /n - Technologies that are screened out.
* Screening comments may or may not be applicable to actual sites.
Figure 4-4. An example of initial screening of technologies and process options.
-------
Ground Water General
Response Actions Remedial Technology Process Options
Description
Screening Comments*
00
Offslte treatment
/ / / / / / //////
Fluidized bed //////
_P
' |_|
|
POTW
• See "Collection/Discharge" above
Degradation of organics using mlcroorganisims
in an aerobic environment
Degradation of organlcs using mlcroorganisims
In an anaerobic environment
Alteration of chemical equilibria to reduce
solubility of the contaminants
Mixing large volumes of air with water in a
packed column to promote transfer of VOCs to air
Adsorption of contaminants onto activated carbon
by passing water through carbon column
Use of high pressure to force water through a
membrane leaving contaminants behind
Contaminated water is passed through a resin bed
where ions are exchanged between resin and water
Combustion in a horizontally rotating cylinder
designed for uniform heat transfer
Waste injected Into hot agitated bed of sand where
combustion occurs
Extracted ground water discharged to local POTW
RCRA tadlily
i/ / s s s / s
-^Bioreclarnajion
/ / / / ////////}(
ration ////////\
Permeabe treatment beds
rjsjssssj S / / / J
^Chemical reaction^ ////\
Onslte discharge
Local stream
Offslte discharge
POTW
/yyy'x'x'y'y'y' / / / /\
,,Deep wejl Injection^ ////
Extracted ground water discharged to liscensed
RCRA facility for treatment and/or disposal
System of injection and extraction wells introduce
bacteria and nutrients to degrade contamination
System of wells to inject air into ground water to
remove volatlles by air stripping
Downgradient trenches backfilled with activated
carbon ID remove contaminants from water
System of Injection wells to inject oxidizer such
as hydrogen peroxide to degrade contaminants
(See Discharge under "Collection/
Discharge" above
Pipeline to river
Legend i
- Technologies that are screened out.
Not feasible for intercepting contaminants
in fractured bedrock
Not feasible for intercepting contaminants
in fractured bedrock
Potentially applicable
Not applicable to inorganic contaminants
found in ground water at the site
Not applicable to inorganic contaminants
found in ground water at the site
Potentially applicable
Not applicable to inorganic contaminants
found In ground water at the site
Not applicable to inorganic contaminants
found in ground water at the site
Contaminant concentrations too low for
treatment
Potentially applicable
Not applicable to inorganic contaminants
found in ground water at the site
Not applicable to inorganic contaminants
found in ground water at the site
Potentially applicable
Potentially applicable
Not feasible because of fractured bedrock
Not feasible because of fractured bedrock
Not feasible because of shallow depth to bedrock,
fractured bedrock
Not feasible because of fractured bedrock
Potentially applicable
Potentially applicable
Deep aquifer not suitable for injection
of contaminated water
Potentially applicable
'Screening comments may or may not be applicable to actual sites.
Figure 44. Continued.
-------
CD
Ground Water General Remedial Technology
Resoonse Actions
No Action None |
1 — 1 Access restrictions 1
1 1 Alternate water [""
Institutional supply — 1
Actions 1—
_ Monitoring
Cotlectiorv 1 Subsurface drains |
Qn*it¥ *>*t*ww
—I Oflsite discharge ~|~
L
i —
1 —
I Subsurface drains
Treatment/ Physical/chemical I —
Discharge . I
' '
1 Offsite treatment 1 — 1
1 ' 1_
1 — 1 Onsite discharge
r
1 Offsite discharge 1 1
1 1 [_
Process Options
Not applicable
Deed restrictions
City water supply
New community well
Ground water mentoring
Interceptor trenches
IPOTW
Pipeline to river
Clay + soil
Asphalt
Multi-media-cap
1 !«•« M •VA«*4tA«)
! Precipitation
Ion exchange
RCRA facility
Local stream
IPOTW
Pipeline to river
Effectiveness Implementability Cost
Does not achieve remedial action objectives Not acceptable to local/ None.
public government.
implementation. Does not reduce Legal requirements and Negligible cost.
contamination. authonty.
. . ^^ _ . .
ground water. No contaminant reduction. requires local approvals. o&M.
Effective in preventing use of contaminated Conventional construction. High capital, low
ground water. No contaminant reduction. requires local approvals. O&M.
...... . ... Atone, not acceptable to public/ Low capital, low
Useful for documenting conditions. Does i..-! government O&M
Effective for downgradient fracture Very difficult to implement-re - Very high capital.
flow interception. quires deep trenching through rock low O&M.
Effective and reliable discharge method. Discharge permits required. Low capital, very
Does not eliminate contamination. low O&M.
Effective and reliable discharge method. Discharge permits required. High capital, tow
Does not eliminate contamination. o&M
Effective and reliable discharge method. Discharge permits required. High capital, tow
Does not eliminate contamination. O&M.
Effective, susceptible to cracking, but has Easily implemented. Low capital, low
self-healing properties. Restrictions on future land use. maintenance.
Effective but susceptible to weathering Easily implemented. Low capital, high
Effective but susceptible to weathering Eas||y implemented. Moderate capital.
and cracking. Restrictions on future land use. high maintenance.
Effective, least susceptible to cracking. Easily implemented. Moderate capital,
Restrictions on future land use. mod. maintenance.
Effective for downgradient fracture Very difficult to implement-re - Very high capital,
flow interception. quires deep trenching through rock tow O&M.
Effective and reliable; conventional Readily implementable. High capital,
technology. Requires sludge disposal. moderate O&M.
Effective and reliable; proper pretreatment Readily implementable. hij;?h SKI •
required. nignuaiw.
Effectiveness and reliability require Readily implementable, Moderate capital,
pilot test to determine. permit required. tow O&M.
Effective and reliable treatment; transpor- Nearest RCRA facility High transporta-
tation required. 250 miles away. ton cost.
Effective and reliable. Readily implementable, Low capital, very
Permit required. tow O&M.
Effective and reliable. Permit required. High capital, low
O&M.
Effective and reliable. Permit required. High capital, tow
O&M
Figure 4-5. Evaluation of Process Options - Example.
-------
later phases of the FS when alternatives are refined
and evaluated on a sitewide basis.
If modeling of transport processes is undertaken
during the alternative development and screening,
phases of the FS to evaluate removal or collection
technologies, and if many contaminants are present
at the site, it may be necessary to identify indicator
chemicals, as is often done for the baseline risk
assessments, to simplify the analysis. Typically,
indicator chemicals are selected on the basis of their
usefulness in evaluating potential effects on human
health and the environment. Commonly selected
indicator chemicals include those that are highly
mobile and highly toxic.
4.2.5.2 Implementability Evaluation
Implementability encompasses both the technical and
administrative feasibility of implementing a technology
process. As discussed in Section 4.2.4, technical
implementability is used as an initial screen of
technology types and process options to eliminate
those that are clearly ineffective or unworkable at a
site. Therefore, this subsequent, more detailed
evaluation of process options places greater
emphasis on the institutional aspects of
implementability, such as the ability to obtain
necessary permits for offsite actions, the availability of
treatment, storage, and disposal services (including
capacity), and the availability of necessary equipment
and skilled workers to implement the technology.
4.2.5.3 Cost Evaluation
Cost plays a limited role in the screening of process
options. Relative capital and O&M costs are used
rather than detailed estimates. At this stage in the
process, the cost analysis is made on the basis of
engineering judgment, and each process is evaluated
as to whether costs are high, low, or medium relative
to other process options in the same technology type.
As discussed in Section 4.3, the greatest cost con-
sequences in site remediation are usually associated
with the degree to which different general technology
types (i.e., containment, treatment, excavation, etc.)
are used. Using different process options within a
technology type usually has a less significant effect
on cost than does the use of different technology
types.
4.2.6 Assemble Alternatives
In assembling alternatives, general response actions
and the process options chosen to represent the
various technology types for each medium or
operable unit are combined to form alternatives for
the site as a whole. As discussed in Section 4.1.2.1,
appropriate treatment and containment options should
be developed. To assemble alternatives, general
response actions should be combined using different
technology types and different volumes of media
and/or areas of the site. Often more than one general
response action is applied to each medium. For
example, alternatives for remediating soil
contamination will depend on the type and distribution
of contaminants and may include incineration of soil
from some portions of the site and capping of others.
For sites at which interactions among media are not
significant (i.e., source control actions will not affect
ground-water or surface-water responses) the
combination of medium-specific actions into site
wide alternatives can be made later in the FS
process, either after alternatives have been screened
or prior to conducting the comparative analysis of
alternatives. For example, if media interactions are
not of concern, an FS might describe three source
control options, three soil remediation options, and
four ground-water remediation options, (instead of
developing numerous comprehensive sitewide
alternatives). Although this approach permits greater
flexibility in developing alternatives and simplifies the
analyses of sitewide alternatives, it may involve
greater effort in developing and analyzing medium-
specific options.
Figure 4-6 illustrates how general response actions
may be combined to form a range of sitewide
alternatives. For this relatively simple example, the
two media of interest are soil and ground water. The
range of alternatives developed include a no-action
alternative (alternative 1); a limited action alternative
(alternative 2); source containment options with and
without ground water treatment (alternatives 3 and 4);
and three alternatives that employ various levels of
source treatment, with ground-water collection and
treatment (alternatives 5, 6, and 7).
Although not shown in this example, a description of
each alternative should be included in the FS report.
For the alternatives presented in Figure 4-6, such
descriptions would include the locations of areas to
be excavated or contained, the approximate volumes
of soil and/or ground water to be excavated and
collected, the approximate locations of interceptor
trenches, the locations of potential city water supply
hook-ups, the locations of connections to the local
publicly owned treatment works (POTW),
management options for treatment residuals, and any
other information needed to adequately describe the
alternative and document the logic behind the
assembly of general response actions into specific
remedial action alternatives. In describing alternatives,
it may be useful to note those process options that
were not screened out and that are represented by
those described in the alternative.
4-20
-------
General Response Action
Medium
Soil
Ground Water*
Technology
Type
Access
Restrictions
(Fencing)
Excavation
Disposal
Treatment
Onslte
Incineration
Otfsite
Capping
Alternate
Water
Suoolv
Monitoring
Collection
With
Interceptor
Trenches
Treatment
With
Precipitation
Onsite
Discharge
Area or
Volume
Onsite RCRA
Landfill
Offsite RCRA
Landfill
In Situ
Stabilization
Bioremedlaflon
To 10-*
All
(Remaining)
Soil Above
10 •«
All Residents
In Affected
Area
All
Monitoring
Wells Twice
A Year
All Water
AbovelCT*
Within 10Yrs.
All Water
Above W6
Within 20 yrs
Prstrsaimsni
Offsite
ToPOTW
1
No
Action
•
2
Limited
Action
•
•
•
3
Source
Containment;
NoGW
Controls
•
•
•
•
•
4
Source
Containment;
GW
Collection,
Pretreatment,
POTW
•
•
•
•
•
•
•
•
5
In Situ
Stabilization,
Cap;GW
Collection,
Pretreatment,
POTW
•
•
•
•
•
•
•
6
Bio-degradation,
Cap;GW
Collection,
Prelreatment,
POTW
•
•
•
•
•
•
7
Incineration;
GW Collection,
Pretreatment,
POTW
•
•
•
•
•
•
•
"This is
a conceptual example using the example of carcinogenic risk ranges; however, In general, when MCLs are available they will apply.
Figure 4-8. Assembling a range of alternative examples.
4.3 Alternatives Screening Process
4.3.1 Alternatives Definition
Before beginning screening, alternatives have been
assembled primarily on medium-specific
considerations and implementability concerns.
Typically, few details of the individual process options
have been identified, and the sizing requirements of
technologies or remediation timeframes have not
been fully characterized (except for timeframes
identified to develop ground-water action
alternatives). Furthermore, interactions among media,
which may influence remediation activities, have
usually not been fully determined, nor have sitewide
protectiveness requirements been addressed.
Therefore, at this point in the process, such aspects
of the alternatives may need to be further defined to
4-21
-------
form the basis for evaluating and comparing the
alternatives before their screening.
4.3.1.1 Specific Objectives
Alternatives are initially developed and assembled to
meet a set of remedial action objectives for each
medium of interest. During screening, the assembled
alternatives should be evaluated to ensure that they
protect human health and the environment from each
potential pathway of concern at the site or those
areas of the site being addressed as part of an
operable unit. If more than one pathway is present,
such as inhalation of airborne contaminants and
ingestion of contaminants in ground water, the overall
risk level to receptors should be evaluated. If it is
found that an alternative is not fully protective, a
reduction in exposure levels for one or more media
will need to be made to attain an acceptable risk
level.
In refining alternatives, it is important to note that
protectiveness is achieved by reducing exposures to
acceptable levels, but achieving these reductions in
exposures may not always be possible by actually
cleaning up a specific medium to these same levels.
For example, protection of human health at a site may
require that concentrations of contaminants in
drinking water be reduced to levels that could not
reasonably be achieved for the water supply aquifer;
thus, protection could be provided by preventing
exposures with the use of a wellhead treatment
system. The critical selection of how risk reductions
are to be achieved is part of the risk management
decisionmaking process.
4.3.1.2 Define Media and Process Options
Alternatives should be defined to provide sufficient
quantitative information to allow differentiation among
alternatives with respect to effectiveness,
implementability, and cost. Parameters that often
require additional refinement include the extent or
volume of contaminated material and the size of
major technology and process options.
Refinement of volumes or areas of contaminated
media is important at some sites at which ongoing
releases from the source (or contaminated soils)
significantly affect contaminant levels in other media
(e.g., ground water) because such interactions may
not have been addressed when alternatives were
initially developed by grouping medium-specific
response actions. If interactions among media appear
to be important at a site, the effect of source control
actions on the remediation levels or time frames for
other media should be evaluated.
Figure 4-7 provides an example of such an analysis
in which volatile organics in soil are migrating into an
underlying aquifer composed of unconsolidated
materials. Using a model of transport processes at
the site, the effect of different soil removal actions on
ground-water remediation (using a specified
extraction scheme) could be estimated. In this
example, development of alternatives that consider
ground water actions independent of soil removal
(i.e., the no-soil-removal scenario) could result in
underestimating the achievable remediation level or
overestimating the time frame for ground-water
remediation. This could result in an overestimation of
the extraction and treatment requirements for
technology processes for ground water. By evaluating
soil and ground water actions together, the rates and
volumes of ground water extraction to achieve the
target remediation levels can be refined more
accurately.
After the alternatives have been refined with respect
to volumes of media, the technology process options
need to be defined more fully with respect to their
effectiveness, implementability, and cost such that
differences among alternatives can be identified. The
following information should be developed, as
appropriate, for the various technology processes
used in an alternative:
• Size and configuration of onsite extraction and
treatment systems or containment structures -
For media contaminated with several hazardous
substances, it may be necessary to first
determine which contaminant(s) impose the
greatest treatment requirements; then size or
configure accordingly. Similarly, for ground-
water extraction technologies at sites with multiple
ground-water contaminants, it may be necessary
to evaluate which compounds impose the
greatest limits on extraction technologies, either
because of their chemical/physical characteristics,
concentration, or distribution in ground water.
• Time frame in which treatment, containment, or
removal goals can be achieved - The remediation
time frame is often interdependent on the size of
a treatment system or configuration of a ground-
water extraction system. The time frame may be
determined on the basis of specific remediation
goals (e.g., attaining ground-water remediation
goals in 10 years), in which case the technology
is sized and configured to achieve this; the time
frame may also be influenced by technological
limitations (such as maximum size consideration,
performance capabilities, and/or availability of
adequate treatment systems or disposal
capacity).
• Rates or flows of treatment - These will also
influence the sizing of technologies and time
frame within which remediation can be achieved.
4-22
-------
- 1 x 103
1 x 10-'
70
80
90
TIME IN YEARS
Figure 4-7. Time to achieve 104to 10*risk level for a single-contaminant for ground water cleanup under various soil
removal alternatives.
Spatial requirements for constructing treatment or
containment technologies or for staging
construction materials or excavated soil or waste
Distances for disposal technologies - These
include approximate transport distances to
acceptable offsite treatment and disposal facilities
and distances for water pipelines for discharge to
a receiving stream or a POTW.
Required permits for offsite actions and imposed
limitations - These include National Pollutant
Discharge Elimination System (NPDES),
pretreatment, and emission control requirements;
coordination with local agencies and the public;
and other legal considerations. These may also
encompass some action-, location-, and
chemical-specific ARARs.
4.3.2 Screening Evaluation
Defined alternatives are evaluated against the short-
and long-term aspects of three broad criteria:
effectiveness, implementability, and cost. Because
the purpose of the screening evaluation is to reduce
the number of alternatives that will undergo a more
thorough and extensive analysis, alternatives will be
evaluated more generally in this phase than during
the detailed analysis. However, evaluations at this
time should be sufficiently detailed to distinguish
among alternatives. In addition, one should ensure
4-23
-------
that the alternatives are being compared on an
equivalent basis (i.e., definitions of treatment
alternatives are approximately at the same level of
detail to allow preparation of comparable cost
estimates).
Initially, specific technologies or process options were
evaluated primarily on the basis of whether or not
they could meet a particular remedial action objective.
During alternative screening, the entire alternative is
evaluated as to its effectiveness, implementability,
and cost.
During the detailed analysis, the alternatives will be
evaluated against nine specific criteria and their
individual factors rather than the general criteria used
in screening. Therefore, individuals conducting the FS
should be familiar with the nine criteria (see Section
6.2.2) at the time of screening to better understand
the direction that the analysis will be taking. The
relationship between the screening criteria and the
nine evaluation criteria is conceptually illustrated in
Figure 4-8.
It is also important to note that comparisons during
screening are usually made between similar
alternatives (the most promising of which is carried
forward for further analysis); whereas, comparisons
during the detailed analysis will differentiate across
the entire range of alternatives. The criteria used for
screening are described in the following sections.
4.3.2.1 Effectiveness Evaluation
A key aspect of the screening evaluation is the
effectiveness of each alternative in protecting human
health and the environment. Each alternative should
be evaluated as to its effectiveness in providing
protection and the reductions in toxicity, mobility, or
volume that it will achieve. Both short- and long-
term components of effectiveness should be
evaluated; short-term referring to the construction
and implementation period, and long-term referring
to the period after the remedial action is complete.
Reduction of toxicity, mobility, or volume refers to
changes in one or more characteristics of the
hazardous substances or contaminated media by the
use of treatment that decreases the inherent threats
or risks associated with the hazardous material.
4.3.2.2 Implementability Evaluation
Implementability, as a measure of both the technical
and administrative feasibility of constructing,
operating, and maintaining a remedial action
alternative, is used during screening to evaluate the
combinations of process options with respect to
conditions at a specific site. Technical feasibility
refers to the ability to construct, reliably operate, and
meet technology-specific regulations for process
options until a remedial action is complete; it also
includes operation, maintenance, replacement, and
monitoring of technical components of an alternative,
if required, into the future after the remedial action is
complete. Administrative feasibility refers to the ability
to obtain approvals from other offices and agencies,
the availability of treatment, storage, and disposal
services and capacity, and the requirements for, and
availability of, specific equipment and technical
specialists.
The determination that an alternative is not technically
feasible and is not available will usually preclude it
from further consideration unless steps can be taken
to change the conditions responsible for the
determination. Typically, this type of "fatal flaw"
would have been identified during technology
screening, and the infeasible alternative would not
have been assembled. Negative factors affecting
administrative feasibility will normally involve
coordination steps to lessen the negative aspects of
the alternative but will not necessarily eliminate an
alternative from consideration.
4.3.2.3 Cost Evaluation
Typically, alternatives will have been defined well
enough before screening that some estimates of cost
are available for comparisons among alternatives.
However, because uncertainties associated with the
definition of alternatives often remain, it may not be
practicable to define the costs of alternatives with the
accuracy desired for the detailed analysis (i.e., +50
percent to -30 percent).
Absolute accuracy of cost estimates during screening
is not essential. The focus should be to make
comparative estimates for alternatives with relative
accuracy so that cost decisions among alternatives
will be sustained as the accuracy of cost estimates
improves beyond the screening process. The
procedures used to develop cost estimates for
alternative screening are similar to those used for the
detailed analysis; the only differences would be in the
degree of alternative refinement and in the degree to
which cost components are developed.
Cost estimates for screening alternatives typically will
be based on a variety of cost-estimating data. Bases
for screening cost estimates may include cost curves,
generic unit costs, vendor information, conventional
cost-estimating guides, and prior similar estimates
as modified by site-specific information.
Prior estimates, site-cost experience, and good
engineering judgments are needed to identify those
unique items in each alternative that will control these
comparative estimates. Cost estimates for items
common to all alternatives or indirect costs
(engineering, financial, supervision, outside contractor
support, contingencies) do not normally warrant
4-24
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SCREENING
CRITERIA
NINE EVALUATION
CRITERIA
ROLE OF CRITERIA DURING
REMEDY SELECTION
-1^
01
Implementability
Overall Protection of Human Health
and Environment
Compliance with ARARS
Long-term Effectiveness and Permanance
Reductions in Toxicity, Mobility, and
Volume Through Treatment
Short-term Effectiveness
Implementability
Cost
Cost
"Threshold" Factors
"Primary Balancing" Factors
State Acceptance
Community Acceptance
"Modifying" Considerations
Figure 4-8. Relationship of Screening Criteria to the Nine Evaluation Criteria.
-------
substantial effort during the alternative screening
phase.
Both capital and O&M costs should be considered,
where appropriate, during the screening of
alternatives. The evaluation should include those
O&M costs that will be incurred for as long as
necessary, even after the initial remedial action is
complete. In addition, potential future remedial action
costs should be considered during alternative
screening to the extent they can be defined. Present
worth analyses should be used during alternative
screening to evaluate expenditures that occur over
different time periods. By discounting all costs to a
common base year, the costs for different remedial
action alternatives can be compared on the basis of a
single figure for each alternative.
A more detailed discussion of cost evaluations is
presented in Chapter 6.
4.3.2.4 Innovative Technologies
Technologies are classified as innovative if they are
developed fully but lack sufficient cost or performance
data for routine use at Superfund sites. In many
cases, it will not be possible to evaluate alternatives
incorporating innovative technologies on the same
basis as available technologies, because insufficient
data exist on innovative technologies. If treatability
testing is being considered to better evaluate an
innovative technology, the decision to conduct a test
should be made as early in the process as possible to
avoid delays in the RI/FS schedule.
Innovative technologies would normally be carried
through the screening phase if there were reason to
believe that the innovative technology would offer
significant advantages. These advantages may be in
the form of better treatment performance or
implementability, fewer adverse impacts than other
available approaches, or lower costs for similar levels
of performance. A "reasonable belief" exists if
indications from other full-scale applications under
similar circumstances or from bench-scale or pilot-
scale treatability testing supports the expected
advantages.
4.3.3 Alternative Screening
4.3.3.1 Guidelines for Screening
Alternatives with the most favorable composite
evaluation of all factors should be retained for further
consideration during the detailed analysis. Alternatives
selected for further evaluation should, where
practicable, preserve the range of treatment and
containment technologies initially developed. It is not
a requirement that the entire range of alternatives
originally developed be preserved if all alternatives in
a portion of the range do not represent distinct viable
options.
The target number of alternatives to be carried
through screening should be set by the project
manager and the lead agency on a site-specific
basis. It is expected that the typical target number of
alternatives carried through screening (including
containment and no-action alternatives) usually
should not exceed 10. Fewer alternatives should be
carried through screening, if possible, while
adequately preserving the range of remedies. If the
alternatives being screened are still medium-specific
and do not address the entire site or operable unit,
the number of alternatives retained for each specific
medium should be considerably less than 10.
4.3.3.2 Selection of Alternatives for Detailed
Analysis
Once the evaluation has been conducted for each of
the alternatives, the lead agency and its contractor
should meet with the support agency to discuss each
of the alternatives being considered. This meeting
does not correspond to a formal quality control review
stage but provides the lead agency and its contractor
with input from the support agency and serves as a
forum for updating the support agency with the
current direction of the FS.
The alternatives recommended for further
consideration should be agreed upon at this meeting
so that documentation of the results of alternative
screening is complete; any additional investigations
that may be necessary are identified; and the detailed
analysis can commence.
Unselected alternatives may be reconsidered at a
later step in the detailed analysis if similar retained
alternatives continue to be evaluated favorably or if
information is developed that identifies an additional
advantage not previously apparent. This provides the
flexibility to double check a previous decision or to
review variations of alternatives being considered
(e.g., consideration of other similar process options).
However, it is expected that under most
circumstances, once an alternative is screened out it
will not be reconsidered for selection.
4.3.3.3 Post-screening Tasks
The completion of the screening process leads
directly into the detailed analysis and may serve to
identify additional investigations that may be needed
to adequately evaluate alternatives. To ensure a
smooth transition from the screening of alternatives to
the detailed analysis, it will be necessary to identify
and begin verifying action-specific ARARs and
initiate treatability testing (if not done previously) and
additional site characterization, as appropriate.
4-26
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Although the consideration of action-specific ARARs
begins earlier as process options are combined, the
identification of action-specific ARARs will need to
be more definitive as the alternatives become better
defined. At the conclusion of screening, sufficient
information should exist on the technologies and the
most probable configurations of technologies so that
the lead agency and support agency can better define
and agree on action-specific ARARs. As with
chemical-specific ARARs, action-specific ARARs
should include all Federal requirements and any State
requirements that either are more stringent than
Federal ARARs or specify requirements where no
Federal ARARs exist.
Once the field of alternatives has been narrowed, the
technology processes of greatest interest can be
identified. At this point, the need for treatability tests
(if not identified earlier) can be determined for
process options that will require additional data for
detailed analysis. Although the results of treatability
testing may not be used until the detailed analysis,
they should be initiated as early in the process as
possible to minimize any potential delays on the FS
schedule. The type and scope of treatability tests
depends on the expected data requirements for
detailed analysis of alternatives. Factors involved in
determining the need for and scope of treatability
studies are discussed in Chapter 5.
In some cases, the need for additional site
characterization may also be identified during the
screening phase. Because the nature and extent of
contamination is usually well defined at this time,
additional field investigations should be conducted
only to better define the effect of site conditions on
the performance of the technology processes of
greatest interest.
4.4 Community Relations During
Alternative Development and
Screening
The community relations activities implemented for
site characterization may also be appropriate during
the development of alternatives. Activities focus on
providing information to the community concerning
the development and screening of remedial
alternatives and obtaining feedback on community
interests and concerns associated with such alter-
natives. Community relations activities should be
site- and community-specific and are usually
stipulated in the community relations plan that is
prepared during scoping activities. Community
relations activities during the development of
alternatives may include, but are not limited to, a fact
sheet describing alternatives identified as potentially
feasible, a workshop presenting citizens with the
Agency's considerations for developing alternatives,
briefings for local officials and concerned citizens on
alternatives under consideration, a small group
meeting for citizens involved with the site, and news
releases describing technologies being evaluated. It is
important to note that public interest typically
increases as the feasibility study progresses; and that
the technical adequacy of a remedy does not ensure
community acceptance. Therefore, the community
relations activities should be planned and conducted
to address such interest and potential concerns.
If alternatives are being developed concurrently with
the Rl site characterization, information on the
screening of technologies and remedial alternative
development should be included in public information
materials and activities prepared during site
characterization. If alternatives are developed after
site characterization, additional community relations
activities should be conducted. In general, community
relations activities during alternative development and
screening are most appropriate if citizens are
significantly concerned over site conditions, and RI/FS
activities that are being implemented at the site. The
level of effort for community relations at this phase
should be described in the community relations plan.
4.5 Reporting and Communication
During Alternative Development and
Screening
Although no formal report preparation is required
during the development and screening of alternatives
(except whatever routine administrative and project
management tracking methods have been designated
for use by the lead agency and its contractors))7,
some form of written documentation of the methods,
rationale, and results of alternative screening (e.g.,
graphical representation similar to Figures 4-5 and
4-6 or a technical memorandum) needs to be
provided to the lead and support agencies. If a
technical memorandum is prepared, it can serve as
the basis for later development of the chapters) in
the FS report that discusses the development and
screening of alternatives.
Communication among the lead and support agencies
and their contractor(s) is very important to obtain
input and agreement on the technologies or
processes and alternatives considered for
implementation at the site. As shown in Table 4-2,
communication should occur to facilitate the initial
screening of technologies and process options, to
agree on what additional site data may be needed,
and to gain input and agreement on the choice of
representative processes and combinations to be
7The RPM may require a written deliverable from the PRPs
during alternative development and screening for a PRP-lead
RI/FS.
4-27
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used to assemble alternatives. In addition, the
following key coordination points are required:
• The lead and support agencies should agree on
the set of alternatives selected for detailed
analysis.
• The lead and support agencies must coordinate
identification of action-specific ARARs.
• The lead agency and its contractor are to
evaluate the need for any additional investigations
that may be needed before they conduct the
detailed analysis.
For purposes of speed and efficiency, the preferred
approach for the exchange of information is through
meetings. However, other approaches that facilitate
effective review and input (e.g., technical
memorandums for review) may be used at the lead
agency's discretion.
Because the final RI/FS report may eventually be
subject to judicial review, the procedures for
evaluating, defining, and screening alternatives should
be well documented, showing the rationale for each
step. The following types of information should be
documented in the final RI/FS report to the extent
possible:
• Chemical- and/or risk-based remedial
objectives associated with the alternative
• Modifications to any media-specific alternatives
initially developed to ensure that risk from
multiple-pathway exposures and interactions
among source- and ground-water-remediation
strategies are addressed
• Definition of each alternative including extent of
remediation, volume of contaminated material,
size of major technologies, process parameters,
cleanup timeframes, transportation distances, and
special considerations
• Notation of process options that were not initially
screened out and are being represented by the
processes comprising the alternative
Table 4-2. Reporting and Communication During Alternative Development and Screening
Information Needed
Purpose
Potential Methods for Information Provision
All potential technologies included for
consideration
Need for additional field data or
treatability studies
Process evaluation and alternative
development
Results of alternative screening (if
conducted)
Identification of action-specific ARARs
Need for additional investigation
For lead agency and contractor to identify
potential technologies; for lead agency to
obtain support agency review and
comment
For lead agency and contractor to
determine whether more field data or
treatability tests are needed to evaluate
selected technologies; for lead agency to
obtain support agency review and
comment
For lead agency and contractor to
communicate and reach agreement on
technology screening and alternative
development; for lead agency to obtain
support agency review and comment
For lead agency and contractor to
communicate and reach agreement on
alternative screening; for lead agency to
obtain support agency review and
comment
For lead agency to obtain input from the
support agency on action-specific ARARs
For lead agency and contractor to
determine whether additional investigations
are needed to evaluate selected
alternatives; for lead agency to obtain
support agency review and comment
Meeting
Tech Memo
Other
Meeting
Tech Memo
Other
Meeting
Tech Memo
Other
Meeting
Tech Memo
Other
Meeting
Letter
Other
Meeting
Tech Memo
Other
4-28
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CHAPTER 5
TREATABILITY
INVESTIGATIONS
FROM: \
• PreHmhaiy | w
Assessment ^
• She Inspection
• NPLUstlng J
SITE /1 THE*tA»UTV
CHARACTERIZATION/ j &|VgBTIGATlQN$
SCOPING OF THE HI/FS
re VEXOPMCKT AND SCREENING
/ OFAtTE
D6TAft.EO*»\LYSIS
TO:
• Remedy Schdlon
• Record of DccMon
• Remedial DMlgn
• Remedial Action
TREATABILITY
INVESTIGATIONS
• Perform Bench or Pilot
Treatability Tests as Necessary
5-1
-------
Chapter 5
Treatability Investigations
5.1 Introduction
As discussed earlier, the phased RI/FS process is
intended to better focus the site investigation so that
only those data necessary to support the RI/FS and
the decision-making process are collected. Data
needs are initially identified on the basis of the
understanding of the site at the time the RI/FS is
initially scoped. Therefore, initial sampling and testing
efforts may be limited until a more complete
understanding of the site allows subsequent sampling
efforts to be better focused. As site information is
collected during the Rl and alternatives are being
developed, additional data needs necessary to
adequately evaluate alternatives during the detailed
analysis are often identified. These additional data
needs may involve the collection of site
characterization data, as described in Chapter 3, or
treatability studies to better evaluate technology
performance. This chapter is intended to provide an
overview of the types of treatability studies (i.e.,
bench scale, pilot scale) that may be used, their
specific purposes, and important factors that need to
be considered when contemplating their use.
5.7.7 Objectives of Treatability Investigations
Treatability studies are conducted primarily to achieve
the following:
• Provide sufficient data to allow treatment
alternatives to be fully developed and evaluated
during the detailed analysis and to support the
remedial design of a selected alternative
• Reduce cost and performance uncertainties for
treatment alternatives to acceptable levels so that
a remedy can be selected
5.7.2 Overview of Treatability Investigations
Treatability studies to collect data on technologies
identified during the alternative development process
are conducted, as appropriate, to provide additional
information for evaluating technologies. The RI/FS
contractor and the lead agency's RPM must review
the existing site data and available information on
technologies to determine if treatability investigations
are needed. As discussed earlier, the need for
treatability testing should be identified as early in the
RI/FS process as possible. A decision to conduct
treatability testing may be made during project
scoping if information indicates such testing is
desirable. However, the decision to conduct these
activities must be made by weighing the cost and
time required to complete the investigation against
the potential value of the information in resolving
uncertainties associated with selection of a remedial
action. In some situations a specific technology that
appears to offer a substantial savings in costs or
significantly greater performance capabilities may not
be identified until the later phases of the RI/FS. Under
such circumstances it may be advantageous to
postpone completion of the RI/FS until treatability
studies can be completed. Project managers will need
to make such decisions on a case by case basis. In
other situations, treatability investigations may be
postponed until the remedial design phase.
The decision process for treatability investigations is
shown conceptually in Figure 5-1 and consists of
the following steps:
• Determining data needs
• Reviewing existing data on the site and available
literature on technologies to determine if existing
data are sufficient to evaluate alternatives
• Perform treatability tests, as appropriate, to
determine performance, operating parameters,
and relative costs of potential remedial
technologies
• Evaluating the data to ensure that DQOs are met
5.2 Determination of Data Requirements
To the extent possible, data required to assess the
feasibility of technologies should be gathered during
the site characterization (e.g., moisture and heat
content data should be collected if incineration of an
organic waste is being considered). Because data
requirements will depend on the specific treatment
process and the contaminants and matrices being
considered, the results of the site characterization will
influence the types of alternatives developed and
screened, which will in turn influence additional data
5-3
-------
Determine
Data Needs
Evaluate Existing
Technology Data
Evaluate Existing
Site Data
Data
Adequate
to Screen or
Evaluate
Alternatives ?
Figure 5-1. Treatability investigations.
needs. However, data collected during site
characterization will not always be adequate for
assessing the feasibility of remedial technologies,
and, in fact, the need for detailed data from
treatability tests may not become apparent until the
initial screening of alternatives has been completed. A
description of data requirements for selected
technologies is presented in Table 5-1. The
Technology Screening Guide for Treatment of
CERCLA Soils and Sludges (U.S. EPA. September
1988) summarizes data needs for a larger number of
available and innovative technologies. The Superfund
Innovative Technology Evaluation (SITE) program is
another source to assist with the identification of data
needs and to obtain performance information on
innovative technologies.
Additional data needs can be identified by conducting
a more exhaustive literature survey than was originally
conducted when potential technologies were initially
5 - 4
-------
Table 5-1. Typical Data Requirements for Remediation Technologies
Technology Waste Matrix
Example Data Required
Thermal Destruction Soils
Liquids
Air Stripping
Metal Hydroxide
Precipitation
In Situ Vapor
Extraction
Ground Water
Ground Water
Soils
Moisture content
Heat value
Chlorine content
Destruction efficiency
Heat value
Concentration of metals
Destruction efficiency
Concentration of volatile contaminants. Concentration of non-volatile contaminants
Contaminant removal efficiencies (obtainable from mathematical models)
Metals concentration
Contaminant removal efficiency
Sludge generation rate and composition
Soil type
Particle size distribution. Concentration of volatile compounds
Presence of non-volatile contaminants
Contaminant removal efficiencies (usually requires bench- or pilot-scale work)
Note: Tables used in this outline are only partial examples.
being identified. The objectives of a literature survey
are as follows:
• Determine whether the performance of those
technologies under consideration have been
sufficiently documented on similar wastes
considering the scale (e.g., bench, pilot, or full)
and the number of times the technologies have
been used
• Gather information on relative costs, applicability,
removal efficiencies, O&M requirements, and
implementability of the candidate technologies
• Determine testing requirements for bench or pilot
studies, if required
5.3 Treatability Testing
Certain technologies have been demonstrated
sufficiently so that site-specific information collected
during the site characterization is adequate to
evaluate and cost those technologies without
conducting treatability, testing. For example, a
ground-water investigation usually provides sufficient
information from which to size a packed tower air
stripper and prepare a comparative cost estimate.
Other examples of when treatability testing may not
be necessary include:
• A developed technology is well proven on similar
applications.
• Substantial experience exists with a technology
employing treatment of well-documented waste
materials. (For example, air stripping or carbon
adsorption of ground water containing organic
compounds for which treatment has previously
proven effective.)
• Relatively low removal efficiencies are required
(e.g., 50 to 90 percent), and data are already
available.
Frequently, technologies have not been sufficiently
demonstrated or characterization of the waste alone
is insufficient to predict treatment performance or to
estimate the size and cost of appropriate treatment
units. Furthermore, some treatment processes are not
sufficiently understood for performance to be
predicted, even with a complete characterization of
the wastes. For example, often it is difficult to predict
biological toxicity in a biological treatment plant
without pilot tests. When treatment performance is
difficult to predict, an actual testing of the process
may be the only means of obtaining the necessary
data. In fact, in some situations it may be more
cost-effective to test a process on the actual waste
than it would be to characterize the waste in sufficient
detail to predict performance.
Treatability testing performed during an RI/FS is used
to adequately evaluate a specific technology,
including evaluating performance, determining
process sizing, and estimating costs in sufficient
detail to support the remedy-selection process.
Treatability testing in the RI/FS is not meant to be
used solely to develop detailed design or operating
parameters that are more appropriately developed
during the remedial design phase.
Treatability testing can be performed by using
bench-scale or pilot-scale techniques, which are
described in detail in the following sections. However,
in general, treatability studies will include the following
steps:
• Preparing a work plan (or modifying the existing
work plan) for the bench or pilot studies
5-5
-------
• Performing field sampling, and/or bench testing,
and/or pilot testing
• Evaluating data from field studies, and/or bench
testing, and/or pilot testing
• Preparing a brief report documenting the results
of the testing
5.3.7 Bench-Scale Treatability Studies
Bench testing usually is performed in a laboratory, in
which comparatively small volumes of waste are
tested for the individual parameters of a treatment
technology. These tests are generally used to
determine if the "chemistry" of the process works
and are usually performed in batch (e.g., "jar tests"),
with treatment parameters varied one at a time.
Because small volumes and inexpensive reactors
(e.g., bottles or beakers) are used, bench tests can
be used economically to test a relatively large number
of both performance and waste-composition
variables. It is also possible to evaluate a treatment
system made up of several technologies and to
generate limited amounts of residuals for evaluation.
Bench tests are typically performed for projects
involving treatment or destruction technologies.
However, care must be taken in attempting to predict
the performance of full-scale processes on the basis
of these tests.
Bench-scale testing is useful for a developing
technology, because it can be used to test for a wide
variety of operating conditions.1 In such cases, bench
tests can also be used to determine broad operating
conditions to allow optimization during additional
bench or possibly larger-scale pilot tests to follow.
Bench-scale testing usually consists of a series of
tests, with the results of the previous analysis
determining the next set of conditions to evaluate.
The first tests usually cover a broad range of potential
operating conditions in order to narrow the conditions
for subsequent tests. For example, pH is the most
important parameter for hydroxide precipitation of
heavy metals. An initial "screening" jar test might be
performed in which the pH range is varied from 7
through 12 in whole pH units. After finding a minimum
metals concentration at pH 9, additional testing could
be performed at narrower pH intervals around 9. The
initial screening tests need not be performed to the
same high level of accuracy used in the final tests to
predict treatment effectiveness.
'Bench tests may also be conducted for well-developed and
documented technologies that are being applied to a new
waste.
Bench-scale testing can usually be performed over
a few weeks or months, and the costs are usually
only a small portion of the total RI/FS cost.
Bench-scale testing should be performed, as
appropriate, to determine the following:
• Effectiveness of the treatment alternative on the
waste (note that for some technologies bench-
scale testing may not be sufficient to make a final
effectiveness determination)
• Differences in performance between competing
manufacturers (e.g., activated carbon adsorption
isotherms, polymer jar tests)
• Differences in performance between alternative
chemicals (e.g., alum versus lime versus ferric
chloride versus sodium sulfide)
• Sizing requirements for pilot-scale studies (e.g.,
chemical feed systems)
• Screening of technologies to be pilot tested (e.g.,
sludge dewatering)
• Sizing of those treatment units that would
sufficiently affect the cost of implementing the
technology
• Compatibility of materials with the waste
The preplanning information needed to prepare for
bench-scale treatability testing includes: a waste
sampling plan; waste characterization; treatment goals
(e.g., how clean or resistant to leaching does the
waste need to be); data requirements for estimating
the cost of the technology being evaluated (e.g.,
sufficient for an order of magnitude cost estimate
(i.e., +50/-30 percent)); and information needed for
procurement of equipment and analytical services.
5.3.2 Pilot-Scale Treatability Studies
Pilot studies are intended to simulate the physical as
well as chemical parameters of a full-scale process;
therefore, the treatment unit sizes and the volume of
waste to be processed in pilot systems greatly
increase over those of bench scale. As such, pilot
tests are intended to bridge the gap between bench-
level analyses and full-scale operation, and are
intended to more accurately simulate the performance
of the full-scale process.
Pilot units are designed as small as possible to
minimize costs, yet large enough to get the data
required for scaling up. Pilot units are usually sized to
5-6
-------
minimize the physical and geometric effects of test
equipment on treatment performance to simulate
full-scale performance. Examples of these effects
include mixing, wall effects, accurate settling data,
and generation of sufficient residues (sludges, off
gases, etc.) for additional testing (dewatering, fixation,
etc.). Pilot units are operated in a manner as similar
as possible to the operation of the full-scale system
(i.e., if the full-scale system will be operated
continuously, then the pilot system would usually be
operated continuously).
In many instances, significant time is required to
make a changeover in operating conditions of a pilot
plant and get a reliable result of the change.
Therefore, time and budget constraints often limit the
ability to test a large number of operating conditions.
Since pilot tests usually require large volumes of
waste that may vary in characteristics, consideration
should be given to performing tests on wastes that
are representative of actual site conditions and full-
scale operations (e.g., it may be necessary to blend
or spike wastes to test all waste characteristics
anticipated at the site and/or to conduct onsite tests
using mobile laboratories).
In addition to the preplanning requirements for
bench-scale tests, information needed to prepare for
a pilot-scale treatability test includes:
• Site information that would affect pilot-test
requirements (i.e., waste characteristics, power
availability, etc.)
• Waste requirements for testing (i.e., volumes,
pretreatment, etc.)
• Data requirements for technologies to be tested
Because substantial quantities of material may be
processed in a pilot test and because of the
material's hazardous characteristics, special
precautions may be required in handling transport and
disposal of processed waste. It may be necessary to
obtain an agreement with a local sewer authority or
cognizant State agencies or to obtain an NPDES
permit for offsite discharge of treated effluent. Solid
residuals must be disposed of properly offsite or
stored onsite to be addressed as part of the remedial
action.
5.4 Bench Versus Pilot Testing
Alternatives involving treatment or destruction
technologies may require some form of treatability
testing, if their use represents first-of-its-kind
applications on unique or heterogeneous wastes.
Once a decision is made to perform treatability
studies, the RI/FS contractor and lead agency
remedial project manager will have to decide on the
type of treatability testing to use. This decision must
always be made taking into account the technologies
under consideration, performance goals, and site
characteristics.
The choice of bench versus pilot testing is affected
by the level of development of the technology. For a
technology that is well developed and tested, bench
studies are often sufficient to evaluate performance
on new wastes. For innovative technologies, however,
pilot tests may be required since information
necessary to conduct full-scale tests is either limited
or nonexistent.
Pilot studies are usually not required for well-
developed technologies except when treating a new
waste type or matrix that could affect the physical
operating characteristics of a treatment unit. For
example, incineration of fine sands or clay soils in a
rotary kiln that has been developed for coarser solids
can result in carryover of fine sands into the
secondary combustion chamber.
During the RI/FS process, pilot- scale studies should
be limited to situations in which bench-scale testing
or field sampling of physical or chemical parameters
provide insufficient information from which to evaluate
an alternative (e.g., it is difficult to evaluate the ability
of a rotary kiln incinerator to handle a new waste
matrix using a bench-scale test). Pilot-scale tests
may also be required when there is a need to
investigate secondary effects of the process, such as
air emissions, or when treatment residues (sludge, air
emissions) are required to test secondary treatment
processes.
Because of the time required to design, fabricate, and
install pilot- scale equipment and to perform tests for
a reasonable number of operating conditions,
conducting a pilot study can add significant time and
cost to the RI/FS. The decision to perform a pilot test
should, therefore, be considered carefully and made
as early in the process as possible to minimize
potential delays to the FS.
To determine the need for pilot testing, the potential
for improved performance or savings in time or
money during the implementation of a technology
should be balanced against the additional time and
cost for pilot testing during the RI/FS. Technologies
requiring pilot testing should also be compared to
technologies that can be implemented without pilot
testing. Innovative technologies should be considered
if they offer the potential for more efficient treatment,
destruction of the waste, or significant savings in time
or money required to complete a remedial action.
The final decision as to how much treatability testing
(or collection of additional data of any kind) should be
undertaken involves balancing the value of the
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additional data against increased cost, schedule
delay, and level of allowable uncertainty in the
remedy-selection process. Generally, one of the
following choices must be made:
• Collect more data using treatability testing
• Provide additional safety factors in the remedial
design to accommodate the uncertainties
• Proceed with the remedy selection, accepting the
uncertainty and the potential cost and
performance consequences
The final decision may be a combination of several of
these choices. The lead agency's RPM must base
the decision upon the characteristics of the site, the
cost of the studies, and the uncertainties of
proceeding without them.
Table 5-2 provides a comparison between bench
and pilot studies, and Table 5-3 shows examples of
bench and pilot testing programs.
5.4.7 Testing Considerations
Shipment of substantial volumes of contaminated
material from a site for testing can prove to be
difficult;"residual material not consumed in testing will
need to be disposed of safely, and the disposal must
be adequately documented. Therefore, the volume of
materials to be tested offsite should be minimized to
avoid related problems.
A second testing consideration is the possible
difficulty of getting a representative sample of waste
for treatability testing. For example, although
ground-water samples collected from monitoring
wells during site characterization may be available for
testing treatment technologies, separate extraction
wells may need to be used to produce the required
ground- water flow patterns during remedial actions.
Consequently, because the characteristics of ground
water from extraction wells may be different from
monitoring wells, representative waste samples may
be unavailable until extraction wells are installed and
pumped.
A similar concern arises when trying to obtain
representative samples for testing the treatment of
contaminated soil. Since the soil characteristics will
vary both horizontally and vertically on the site it may
not be possible to obtain a sample that fully
represents full-scale conditions without blending or
spiking.
2 See 40 CFR parts 260 and 261 for specific details on
treatability study sample exemptions.
5.4.2 Data Quality Objectives
The data quality required for analytical results of
treatability tests is a key concern since it greatly
affects the cost and time required for the analyses.
Analytical levels and corresponding levels of quality
are discussed in Chapter 2 of this guidance.
Since the results of bench and pilot studies are used
to support selection of a remedial alternative, results
of such studies will support the ROD and become
part of the Administrative Record. Furthermore,
results of treatability testing also may be used on
other sites with similar characteristics. Therefore,
procedures followed in testing should be well
documented. Sampling and analyses for tests used to
develop predictive results will need to be performed
with the same level of accuracy and care that was
used during the site characterization. Because cost
and time required for analyses increase significantly
with increased quality, potential savings can be
derived by carefully determining the level(s) of data
quality necessary for each analytical level required.
Table 5-4 presents the data quality usually required
for the various analyses that may be performed
during treatability investigations. Bench- and pilot-
scale testing require some moderate and some
high-quality data. Sufficient high-quality data are
needed to document treatment performance of the
technologies considered for further evaluation.
5.5 Treatability Test Work Plan
Laboratory testing can be expensive and time
consuming. A well-written work plan is a necessary
document if a treatability testing program is to be
completed on time, within budget, and with accurate
results. Preparation of a work plan provides an
opportunity to run the test mentally and review
comments before starting the test. It also reduces the
ambiguity of communication between the lead
agency's RPM, the contractor's project manager, the
technician performing the test, and the laboratory
technician performing the analyses on test samples.
The treatability test work plan, which may be an
amendment to the original work plan, if the need for
the treatability tests was not identified until later in the
process, or a separate one specifically for this phase.
Regardless, the work plan should be reviewed and
approved by the lead agency's RPM. The RPM and
RI/FS contractor should determine the appropriate
level of detail for the work plan since a detailed plan
is not always needed and will require time to prepare
and approve. In some situations the original work plan
may adequately describe the treatability tests and a
separate plan is not required (e.g., the need for
treatability testing can be identified during the scoping
phase if existing information is sufficient). Section
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Table 5-2. Bench and Pilot Study Parameters
Parameter
Bench
Pilot
Purpose
Size
Quantity of Waste and Materials
Required
Number of Variables That Can Be
Considered
Time Requirements
Typical Cost Range
Most Frequent Location
Limiting Considerations
Define process kinetics, material
compatibility, impact of environmental
factors, types of doses of chemicals,
active mechanisms, etc.
Laboratory or bench top
Small to moderate amounts
Many
Days to weeks
0.5-2% of capital costs of remedial
action
Laboratory
Wall, boundary and mixing effects;
volume effects; solids processing difficult
to simulate; transportation of sufficient
waste volume
Define design and operation criteria,
materials of construction, ease of material
handling and construction, etc.
1-100% of full scale
Relatively large amounts
Few (greater site-specificity)
Weeks to months
2-5% of capital costs of remedial
action1
Onsite
Limited number of variables; large waste
volume required; safety, health, and other
risks; disposal of process waste material
'Actual percentage cost of pilot testing will depend significantly on the total cost of the remedial action.
2.3.1 and Appendix B.2 provide additional information
on work plan preparation.
5.5.1 Bench-Scale Treatability Work Plan
Table 5-5 provides a suggested work plan format for
bench-scale testing; the various sections of the'
recommended format for the work plan are described
below.
• Project Description and Site Background - Briefly
describe the site and the types, concentrations,
and distributions of contaminants of concern
(concentrating on those for which the technology
is being considered).
• Remedial Technology Description - Give a brief
description of the technology(ies) to be tested.
• Test Objectives - Describe the purpose of the
test, the data that are to be collected from the
bench-scale test, and how the data will be used
to evaluate the technology.
• Specialized Equipment and Materials - Describe
unique equipment or reagents required for the
test.
• Experimental Procedures - List specific steps to
be performed in carrying out the bench-scale
test; include volumes to be tested, descriptions of
reactors to be employed, and materials needed
(i.e., transfer by graduated cylinder 500 ml of
waste to a 600 ml borosilicate glass beaker).
Specify the accuracy of measurements by
specifying standard laboratory glassware (e.g., a
graduated cylinder has 5 percent accuracy
whereas a pipet has 1 percent) and how samples
are to be taken, which containers are to be used,
which preservatives, etc.
• Treatability Test Plan - Include the variable
conditions that are to be tested (e.g., a
combination of 4 pH units and 5 doses of a
chemical would produce 40 discrete tests [if
replicated]); include parameters to be measured if
they vary for different test conditions.
• Analytical Methods - The analytical method is
dependent on test objectives, technology, waste,
and other site factors. Survey available analytical
methods and select the most appropriate.
Describe analytical procedures or cite and
reference standard procedures to be employed
and define the level of accuracy needed for each
of the analyses (perform initial testing to roughly
determine optimal operating conditions; and use
moderately accurate analytical techniques or
analyses of only one or a few indicator
compound(s) to greatly reduce the time and cost
of these initial tests). After achieving best
treatment, perform more complete and accurate
testing to confirm the earlier results. Most bench
tests require results in short order to allow varied
test runs. Bench tests remote from the analyzing
laboratory are difficult; therefore, analyze the
duplicate final or check samples by the CLP, if
necessary.
• Data Management - Testing procedures must be
well documented, using bound notebooks,
photographs, etc.; provisions need to be made for
making backup copies of critical items of data.
Describe the parameters to be measured,
accuracy that the results are to be recorded to,
and how these are to be recorded. Prepare a
sample data sheet to be used in the bench test;
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Table 5-3. Examples of Bench- and Pilot-Scale Testing Programs
Remedial Technology
Example Testing Programs
A. Air Pollution and Gas Migration Control
1. Capping
2. Dust Control
3. Vapor Collection and Treatment (carbon adsorption,
air stripping, etc.)
B. Surface Water Controls
1. Capping
2. Grading
3. Revegetation
4. Diversion and Collection
C. Leachate and Ground-Water Controls
1. Containment barriers (slurry walls, grout curtains,
etc.)
2. Ground-water pumping (well points, suction wells,
etc.)
3. Subsurface collection drains
4. Permeable treatment beds (limestone, activated
carbon)
5. Capping
D. Direct Waste Control
1. Thermal Treatment
2. Solidification/Stabilization
3. Biological Treatment
Activated sludge
Facultative lagoons
Trickling filters
hemical Treatment
Oxidation/reduction
Precipitation
Neutralization
Ion exchange resins
hysical Treatment
Carbon adsorption
Flocculation
Sedimentation
Membrane processes
Dissolved air flotation
Air stripping
Wet air oxidation
n Situ Treatment
Vapor extraction
Soil flushing
Microbial degradation
• Neutralization/detoxification
• Precipitation
• Nitrification
Land Disposal (landfill, land application)
Bench: Soil density and bearing capacity vs. moisture content
curves for proposed capping materials
Pilot: In-place soil densities; determination of gas withdrawal
rates to control releases
Bench: Column testing of capping material compatibility with
wastes present
Pilot: In-place testing of geotextiles for control of erosion in
grassed diversion ditches
Bench: Determination of basicity and headless vs. grain size of
limestone materials for a treatment bed; determination of
chemical compatibility of compacted clay with a leachate
stream
Pilot: In-place testing of a soil-type and grain-size
specification and tile-drain configuration for a subsurface
collection drain
Bench: Characterization of chemical and heat content of
hazardous waste mixes; chemical, physical, and biological
treatability studies to define rate constants, minimal-maximal
loading rates and retention times, optimal pH and temperature,
sludge generation rates and characteristics, and oxygen
transfer characteristics; chemical type and dose rates; solids
flux rate vs. solids concentration in sludge thickening systems;
air/volume ratios for stripping towers
Pilot: Test burns to determine retention times, combustion-
chamber and after-burner temperatures, destruction and
removal efficiency, and fuel requirements for the incineration of
a waste; endurance performance tests on membranes in
reverse-osmosis units for ground-water treatment; in situ
microbial-degradation testing of nutrient-dose and aeration
rates to support in-place degradation of underground leak;
evaluation of in-place mixing procedures for the solidification
of a sludge in a lagoon
E.
Soil and Sediment Containment and Removal
1. Excavation
2. Dredging
3. Grading
4. Capping
5. Revegetation
Bench: Determination of soil-adsorptive (cation exchange
capacity) properties and chemical composition
Pilot: Small-scale dredging to assess sediment resuspension
or production rates
Table 54. Data Quality for Treatability Investigations
Analytical Level Field Data
Bench/Pilot Data
Level ll/
Level III
Level IV/
Level V
Feasibility screening
Enforcement related evaluations and
recommendations of alternatives
Testing to optimize operating conditions
Monitoring
Predesign sizing
Establish design criteria establishing standards documenting
performance in treatability studies to screen alternatives
include procedures to be employed to ensure that
the results are protected from loss.
Data Analysis and interpretation - Describe in
detail the procedures to be followed to reduce
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Table 5-5. Suggested Format for Bench-Scale Work
Plan
1. Project Description and Site Background
2. Remediation Technology Description
3. Test Objectives
4. Specialized Equipment and Materials
5. Laboratory Test Procedures
6. Treatability Test Plan Matrix and Parameters to Measure
7. Analytical Methods
8. Data Management
9. Data Analysis and Interpretation
10. Health and Safety
11. Residuals Management
raw analytical data to a form useful for
interpretation. The most helpful are methods of
graphical interpretation based on known physical
or chemical phenomena or common practice
(e.g., plotting concentrations of metal remaining in
solution versus pH or chemical dosage).
• Health and Safety - Modify the site health and
safety plan as needed to account for waste
handling and onsite testing operations.
• Residual Management - Describe the types of
residuals anticipated and how they will be
managed.
5.52 Pilot-Scale Treatability Work Plan
Table 5-6 contains a suggested work plan format.
Although many of the sections are similar to those of
the bench-scale work plan format, differences
between the two are discussed below.
Table 5-6. Suggested Format for Pilot-Scale Work
Plan
1. Project Description and Site Background
2. Remedial Technology Description
3. Test Objectives
4. Pilot Plant Installation and Startup
5. Pilot Plant Operation and Maintenance Procedures
6. Parameters to be Tested
7. Sampling Plan
8. Analytical Methods
9. Data Management
10. Data Analysis and Interpretation
11. Health and Safety
12. Residuals Management
• Pilot Plant Installation and Startup - For onsite
pilot studies, describe the equipment required and
method to be employed to get the equipment
onsite and installed for the test period.
•Pilot Plant Operation and Maintenance
Procedures - Describe the specific conditions
under which the pilot test will be conducted. Pilot
plants are normally run with relatively large
volumes of waste to simulate full-scale operation
and, therefore, waste characteristics usually have
to be measured and operating controls adjusted
(e.g., chemical feed rates) to match instructions
for startup and shutdown of the pilot plant. These
specifications need to be included in the
procedures list.
Parameters to be Tested - List the operating
conditions under which the pilot units are to be
tested and the variations in control parameters
that are to be evaluated (e.g., chemical feed rates
or pH set points in a chemical precipitation test,
or combustion temperature or gas residence time
for an incinerator test).
Sampling Plan - Describe locations and a
schedule for samples to be taken from the pilot
plant to determine performance; readings from
in-line instruments, such as pH probes and
sampling methods, containers, preservative,
labeling, etc., should be included.
Health and Safety Plan - Health and safety
concerns are more critical during pilot tests
because larger amounts of waste are involved
and equipment is more complex. Equipment
design and construction must comply with
applicable code requirements.
5.6 Application of Results
5.6.7 Data Analysis and Interpretation
Following the completion of the treatability testing,
results are reduced to a useful in accordance with the
work plan. Data are interpreted on the technology's
effectiveness, implementability, and/or cost, and
anticipated results are compared with actual results.
Graphical techniques are frequently used to present
the results. Note that the level of reliability of the test
results is usually based on the accuracy of the
analytical methods employed.
Major differences between the anticipated and actual
results may necessitate a modification of the work
plan and retesting of the technology. In addition,
raw-waste and effluent characteristics as well as
by-products and emissions are evaluated to predict
the ability of a full-scale unit to respond to variations
in waste composition and meet performance
specifications.
5.6.2
Use of the Results in the RI/FS Process
The purpose of a treatability evaluation is to provide
information needed for the detailed analysis of
alternatives and to allow selection of a remedial action
to be made with a reasonable certainty of achieving
the response objectives. All results are useful, even
negative ones, because they can be used to eliminate
technologies for further consideration. The results of
bench and pilot tests can be used to ensure that
conventional and innovative treatment or destruction
technologies can be evaluated equally with non-
5-1 1
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treatment alternatives during the detailed analysis
phase of the FS. Secondary use of treatability results
provides information for the subsequent detailed
design of the selected remedial technology. Operating
conditions must be carefully and completely
documented so that this information can be used in
the full-scale system.
The characteristics of residuals from the remedial
technology should be determined during pilot testing.
This information is useful in determining how the
residuals can be handled or disposed and in
predicting the effects of their disposal or 'emission.
Information can often be collected to determine if the
residuals should be considered hazardous wastes or
disposed of as a non-hazardous waste.
5.6.3 Scaling up to Full-Scale
The study findings need to be evaluated for
application of the technology at full-scale; the
limitations of the bench- or pilot-scale test (size,
wall, and boundary effects, etc.) need to be
compensated for. Scale-up can be done on the
basis of either previous experience with the treatment
equipment with other wastes or established rules of
similitude (used to relate physical laws to variations in
scale) and mathematical models. This evaluation may
include a sensitivity analysis to identify the key
parameters and unknowns that can affect a full-
scale system. The potential need for process
modifications during design or operation must be
considered.
5.7 Community Relations During
Treatability Investigations
Treatability testing is potentially controversial within a
community and, therefore, additional community
relations activities may be required. An assessment of
issues and concerns the community may have about
planned treatability testing should be conducted. The
assessment should augment the previously prepared
community relations plan (if treatability testing was not
part of the original work plan) and should include a
discussion of any issues unique to the proposed
procedures such as onsite pilot testing, transporting
contaminated materials offsite, schedule changes
resulting from conducting bench or pilot tests,
disposal of residuals, uncertainties pertaining to
innovative technologies, and the degree of
development of the technology being tested.
Additional community relations implementation
activities may be recommended in the assessment
and may include a public meeting to explain the
proposed bench or pilot test, a fact sheet describing
the technology and proposed test, a briefing to public
officials about the treatability studies, and small group
consultations with members of the community
concerned about EPA's actions at the site. Other
community relations activities may be needed, and
consultations between the lead agency's project
manager and the community relations coordinator
should be used to establish the appropriate
community relations activities.
5.8 Reporting and Communication
During Treatability Investigations
Deliverables for the treatability investigations are
listed in Table 5-7 and include the following:
• Revised work plans, as necessary, including
bench and/or pilot tests
• Revised QAPP/FSP, as necessary
• Test results and evaluation report
Table 5-7. Reporting and Communication During
Treatability Investigations
Information Needed
Purpose
Potential Method for
Information Provision
Need for Treatability
Testing
Approval of Site Data
Collection or
Treatability Testing
For lead agency and Meeting
contractor to determine Tech Memo
whether more cost and
performance data are
needed to evaluate
alternatives and select
remedy; for lead
agency to obtain
support agency review
and comment
Obtain lead agency QAPP (revised)
approval of treatability FSP
activities Treatability Study
Work Plan
The treatability test evaluation report should describe
the testing that was performed, the results of the
tests, and an interpretation of how the results would
affect the evaluation of the remedial alternatives being
considered for the site. Effectiveness of the treatment
technology for the wastes on the site should be
presented. This report should also contain an
evaluation of how the test results would affect
treatment costs developed during the detailed
analysis of alternatives (e.g., chemical requirements
or settling rates required for effective treatment).
Because the report may be used as an information
source by other EPA and contractor staff at other
sites with similar characteristics, it should be written
clearly and concisely.
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CHAPTER 6
DETAILED ANALYSIS
OF ALTERNATIVES
FROM:
• Preliminary
Awewmsnt
• Site Inspection
i • NPL Listing I
SITE i TREATABILITY
CHARACTERIZATION i INVESTIGATIONS
• Remedy Selection
• Record of Decision
• Remedial Design
• Remedial Action
DEVELOPMENT AND SCREENING!
OF ALTERNATIVES/
DETAILED ANALYSIS
OF ALTERNATIVES
• Further Define Alternatives as
Necessary
Analyze Alternatives Against
Evaluation Criteria
• Compare Alternatives Against
Each Other
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Chapter 6
Detailed Analysis of Alternatives
6.1 Introduction
6.1.1 Purpose of the Detailed Analysis of
Alternatives
The detailed analysis of alternatives consists of the
analysis and presentation of the relevant information
needed to allow decisionmakers to select a site
remedy, not the decisionmaking process itself. During
the detailed analysis, each alternative is assessed
against the evaluation criteria described in this
chapter. The results of this assessment are arrayed
to compare the alternatives and identify the key
tradeoffs among them. This approach to analyzing
alternatives is designed to provide decisionmakers
with sufficient information to adequately compare the
alternatives, select an appropriate remedy for a site,
and demonstrate satisfaction of the CERCLA remedy
selection requirements in the ROD.
The specific statutory requirements for remedial
actions that must be addressed in the ROD and
supported by the FS report are listed below. Remedial
actions must:
• Be protective of human health and the
environment
• Attain ARARs (or provide grounds for invoking a
waiver)
• Be cost-effective
• Utilize permanent solutions and alternative
treatment technologies or resource recovery
technologies to the maximum extent practicable
• Satisfy the preference for treatment that reduces
toxicity, mobility, or volume as a principal element
or provide an explanation in the ROD as to why it
does not
In addition, CERCLA places an emphasis on
evaluating long-term effectiveness and related
considerations for each of the alternative remedial
actions ($121 (b)(l)(A)). These statutory
considerations include:
A) the long-term uncertainties associated with land
disposal;
B) the goals, objectives, and requirements of the
Solid Waste Disposal Act:
C) the persistence, toxicity, and mobility of
hazardous substances and their constituents, and
their propensity to bioaccumulate;
D) short- and long-term potential for adverse
health effects from human exposure;
E) long-term maintenance costs:
F) the potential for future remedial action costs if the
alternative remedial action in question were to fail;
and
G) the potential threat to human health and the
environment associated with excavation,
transportation, and redisposal, or containment.
Nine evaluation criteria have been developed to
address the CERCLA requirements and
considerations listed above, and to address the
additional technical and policy considerations that
have proven to be important for selecting among
remedial alternatives. These evaluation criteria serve
as the basis for conducting the detailed analyses
during the FS and for subsequently selecting an
appropriate remedial action. The evaluation criteria
with the associated statutory considerations are:
• Overall protection of human health and the
environment
• Compliance with ARARs (B)
• Long-term effectiveness and permanence
(A,B,C,D,F,G)
• Reduction of toxicity, mobility, or volume (B,C)
• Short-term effectiveness (D,G)
• Implementability
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• Cost (E,F)
• State acceptance (relates to Section 121 (f))
• Community acceptance (relates to Sections 113
and 117)
6.7.2 The Context of Detailed Analysis
The detailed analysis of alternatives follows the
development and screening of alternatives and
precedes the actual selection of a remedy. As
discussed in Chapter 4, the phases of the FS may
overlap, with one beginning before another is
completed, or they may vary in the level of detail
based on the complexity or scope of the problem.
The extent to which alternatives are analyzed during
the detailed analysis is influenced by the available
data, the number and types of alternatives being
analyzed, and the degree to which alternatives were
previously analyzed during their development and
screening.
The evaluations conducted during the detailed
analysis phase build on previous evaluations
conducted during the development and screening of
alternatives. This phase also incorporates any
treatability study data and additional site
characterization information that may have been
collected during the Rl.
The results of the detailed analysis provide the basis
for identifying a preferred alternative and preparing
the proposed plan. Upon completion of the detailed
analysis, the FS report, along with the proposed plan
(and the Rl report if not previously released), is
submitted for public review and comment. The results
of the detailed analysis supports the final selection of
a remedial action and the foundation for the Record
of Decision.
6.1.3 Overview of the Detailed Analysis
A detailed analysis of alternatives consists of the
following components:
• Further definition of each alternative, if necessary,
with respect to the volumes or areas of
contaminated media to be addressed, the
technologies to be used, and any performance
requirements associated with those technologies
• An assessment and a summary profile of each
alternative against the evaluation criteria
• A comparative analysis among the alternatives to
assess the relative performance of each
alternative with respect to each evaluation
criterion
Figure 6-1 illustrates the steps in the detailed
analysis process.
6.2 Detailed Analysis of Alternatives
6.2.7 Alternative Definition
Alternatives are defined during the development and
screening phase (see Chapter 4) to match
contaminated media with appropriate process
options.1 However, the alternatives selected as the
most promising may need to be better defined during
the detailed analysis. Each alternative should be
reviewed to determine if an additional definition is
required to apply the evaluation criteria consistently
and to develop order-of-magnitude cost estimates
(i.e., having a desired accuracy of + 50 percent to
-30 percent). The information developed to define
alternatives at this stage in the RI/FS process may
consist of preliminary design calculations, process
flow diagrams, sizing of key process components,
preliminary site layouts, and a discussion of
limitations, assumptions, and uncertainties concerning
each alternative. The following examples illustrate
situations in which additional alternative definition is
appropriate:
• The assumed sizing of the process option must
be revised on the basis of results of treatability
data (e.g., a taller air stripping tower with more
packing is required to attain the treatment target).
• A different process option is to be used to
represent the technology type on the basis of the
results of treatability data (e.g., activated carbon
rather than air stripping is required).
• The estimated volume of contaminated media has
been refined on the basis of additional site
characterization data.
As described in Chapter 4, alternatives can be
developed and screened on a medium-specific or
sitewide basis at the lead agency's discretion.
Although it is acceptable to continue the evaluation of
alternatives on a medium-specific basis during the
detailed analysis, it is encouraged that alternatives be
configured to present the decision-maker with a
range of discrete options each of which addresses
the entire site or operable unit being addressed by
the FS.2Therefore, if separate alternatives have been
developed for different areas or media of the site, it is
recommended that they be combined during the
detailed analysis phase to present comprehensive
'This matching is done by identifying specific remedial action
objectives (e.g., a risk-based cleanup target such as 1x10-s)
and sizing process options to attain the objective (e.g., 10
ground-water extraction wells extracting 50 gpm each,
activated carbon treatment for 500 gpm).
2 This approach will better facilitate and simplify the nine criteria
evaluation and preparation of a rationale for remedy selection
in the Record of Decision.
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Development/
Screening of
Alternatives
Results of Treatability
Investigations if Conducted
Further Definition
of Alternatives as
Necessary
I
Individual Analysis
of Alternatives
Against Evaluation
Criteria
Comparative Analysis of
Alternatives Against
Evaluation Criteria
Issuance of Feasibility
Study Report
Figure 6-1. Detailed analysis of alternatives.
options addressing all potential threats posed by the
site or that area being addressed by the operable
unit. This can be accomplished either at the
beginning of the detailed analysis or following the
individual analysis when the alternatives are
summarized and a comparative analysis is performed.
6.2.2 Over view of Evaluation Criteria
The detailed analysis provides the means by which
facts are assembled and evaluated to develop the
rationale for a remedy selection. Therefore, it is
necessary to understand the requirements of the
remedy selection process to ensure that the FS
analysis provides the sufficient quantity and quality of
information to simplify the transition between the FS
report and the actual selection of a remedy. The
analytical process described here has been
developed on the basis of statutory requirements of
CERCLA Section 121 (see Section 6.1.1); earlier
program initiatives promulgated in the November 20,
1985, National Contingency Plan; and site-specific
experience gained in the Super-fund program. The
nine evaluation criteria listed in Section 6.1.1
encompass statutory requirements and technical,
cost, and institutional considerations the program has
determined appropriate for a thorough evaluation.
Assessments against two of the criteria relate directly
to statutory findings that must ultimately be made in
the ROD. Therefore, these are categorized as
threshold criteria in that each alternative must meet
them.3These two criteria are briefly described below:
• Overall Protection of Human Health and the
Environment (described in Section 6.2.3.1) - The
assessment against this criterion describes how
the alternative, as a whole, achieves and
maintains protection of human health and the
environment.
3 The ultimate determination and declaration that these findings
can be made of the selected remedy is contained in the ROD.
6-5
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• Compliance with ARARs (described in Section
6.2.3.2) - The assessment against this criterion
describes how the alternative complies with
ARARs, or if a waiver is required and how it is
justified. The assessment also addresses other
information from advisories, criteria, and guidance
that the lead and support agencies have agreed is
"to be considered."
The five criteria listed below are grouped together
because they represent the primary criteria upon
which the analysis is based.
• Long-term Effectiveness and Permanence
(described in Section 6.2.3.3) - The assessment
of alternatives against this criterion evaluates the
long-term effectiveness of alternatives in
maintaining protection of human health and the
environment after response objectives have been
met.
• Reduction of Toxicity, Mobility, and Volume
Through Treatment (described in Section 6.2.3.4)
- The assessment against this criterion evaluates
the anticipated performance of the specific
treatment technologies an alternative may
employ.
• Short-term Effectiveness (described in Section
6.2.3.5) - The assessment against this criterion
examines the effectiveness of alternatives in
protecting human health and the environment
during the construction and implementation of a
remedy until response objectives have been met.
• Implementability (described in Section 6.2.3.6) -
This assessment evaluates the technical and
administrative feasibility of alternatives and the
availability of required goods and services.
• Cost (described in Section 6.2.3.7) - This
assessment evaluates the capital and operation
and maintenance (O&M) costs of each alternative.
The level of detail required to analyze each alternative
against these evaluation criteria will depend on the
type and complexity of the site, the type of
technologies and alternatives being considered, and
other project-specific considerations. The analysis
should be conducted in sufficient detail so that
decisionmakers understand the significant aspects of
each alternative and any uncertainties associated with
the evaluation (e.g., a cost estimate developed on the
basis of a volume of media that could not be defined
precisely).
The final two criteria, state or support agency
acceptance and community acceptance, will be
evaluated following comment on the RI/FS report and
the proposed plan and will be addressed once a final
decision is being made and the ROD is being
prepared. The criteria are as follows:
• State (Support Agency) Acceptance (described in
Section 6.2.3.8) - This assessment reflects the
state's (or support agency's) apparent
preferences among or concerns about alter-
natives.
• Community Acceptance (described in Section
6.2.3.9) - This assessment reflects the
community's apparent preferences among or
concerns about alternatives.
Each of the nine evaluation criteria has been further
divided into specific factors to allow a thorough
analysis of the alternatives. These factors are shown
in Figure 6-2 and discussed in the following
sections.
6.2.3 Individual Analysis of Alternatives
6.2.3.1 Overall Protection of Human Health and
the Environment
This evaluation criterion provides a final check to
assess whether each alternative provides adequate
protection of human health and the environment. The
overall assessment of protection draws on the
assessments conducted under other evaluation
criteria, especially long-term effectiveness and
permanence, short-term effectiveness, and
compliance with ARARs.
Evaluation of the overall protectiveness of an
alternative during the RI/FS should focus on whether
a specific alternative achieves adequate protection
and should describe how site risks posed through
each pathway being addressed by the FS are
eliminated, reduced, or controlled through treatment,
engineering, or institutional controls. This evaluation
also allows for consideration of whether an alternative
poses any unacceptable short-term or cross-media
impacts.
6.2.3.2 Compliance with ARARs
This evaluation criterion is used to determine whether
each alternative will meet all of its Federal and State
ARARs (as defined in CERCLA Section 121) that
have been identified in previous stages of the RI/FS
process. The detailed analysis should summarize
which requirements are applicable or relevant and
appropriate to an alternative4and describe how the
alternative meets these requirements. When an
ARAR is not met, the basis for justifying one of the
six waivers allowed under CERCLA (see Section
1.2.1.1) should be discussed.
4This effort will require input from the support agency.
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OVERALL PROTECTION
OF HUMAN HEALTH
AND THE ENVIRONMENT
I How Alternative Provides Human
Health and Environmental Protection
COMPLIANCE WITH ARARs
• Compliance With Chemical-Specific
ARARs
• Compliance With Action-Specific ARARs
• Compliance With Location-Specific ARARs
• Compliance With Other Criteria, Advisories,
and Guidances
LONG-TERM
EFFECTIVENESS
AND PERMANENCE
• Magnitude of
Residual Risk
• Adequacy and
Reliability of
Controls
REDUCTION OF TOXICITY
MOBILITY, AND VOLUME
THROUGH TREATMENT
SHORT-TERM
EFFECTIVENESS
• Treatment Process Used and
Materials Treated
• Amount of Hazardous
Materials Destroyed or
Treated
• Degree of Expected
Reductions in Toxicity,
Mobility, and Volume
• Degree to Which
Treatment Is Irreversible
• Type and Quantity of
Residuals Remaining After
Treatment
• Protection of Community
During Remedial Actions
• Protection of Workers
During Remedial Actions
• Environmental Impacts
• Time Until Remedial
Action Objectives Are
Achieved
IMPLEMENTABILITY
• Ability to Construct and
Operate the Technology
• Reliability of the
Technology
• Ease of Undertaking
Additional Remedial
Actions, if Necessary
• Ability to Monitor Effective-
ness of Remedy
• Ability to Obtain
Approvals From Other
Agencies
• Coordination With Other
Agencies
• Availability of Offsite
Treatment, Storage, and
Disposal Services and
Capacity
• Availability of Necessary
Equipment and
Specialists
• Availability of Prospective
Technologies
• Capital
costs
'Operating and
Maintenance Costs
• Present Worth
cost
STATE 1
ACCEPTANCE
COMMUNITY1
ACCEPTANCE
1 These criteria are assessed following comment on the RI/FS report and the proposed plan.
Figure 6-2. Criteria for detailed analysis of alternatives.
The following should be addressed for each
alternative during the detailed analysis of ARARs:5
5Other available information that is not an ARAR (e.g.,
advisories, criteria, and guidance) may be considered in the
analysis if it helps to ensure protectiveness or is otherwise
appropriate for use in a specific alternative. These TBC
materials should be included in the detailed analysis if the lead
and support agencies agree that their inclusion is appropriate.
Compliance with chemical-specific ARARs (e.g.,
maximum contaminant levels) - This factor
addresses whether the ARARs can be met, and if
not, whether a waiver is appropriate.
Compliance with location-specific ARARs (e.g.,
preservation of historic sites) - As with other
ARAR-related factors, this involves a
6-7
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consideration of whether the ARARs can be met
or whether a waiver is appropriate.
• Compliance with action-specific ARARs (e.g.,
RCRA minimum technology standards) - It must
be determined whether ARARs can be met or will
be waived.
The actual determination of which requirements are
applicable or relevant and appropriate is made by the
lead agency in consultation with the support agency.
A summary of these ARARs and whether they will be
attained by a specific alternative should be presented
in an appendix to the RI/FS report. A suggested
format for this summary is provided in Appendix E of
this guidance. More detailed guidance on determining
whether requirements are applicable or relevant and
appropriate is provided in the "CERCLA Compliance
with Other Laws Manual" (U.S. EPA, Draft, May
1988).
6.2.3.3 Long-term Effectiveness and
Permanence
The evaluation of alternatives under this criterion
addresses the results of a remedial action in terms of
the risk remaining at the site after response
objectives have been met. The primary focus of this
evaluation is the extent and effectiveness of the
controls that may be required to manage the risk
posed by treatment residuals and/or untreated
wastes. The following components of the criterion
should be addressed for each alternative:
• Magnitude of residual risk - This factor assesses
the residual risk remaining from untreated waste
or treatment residuals at the conclusion of
remedial activities, (e.g., after source/soil
containment and/or treatment are complete, or
after ground-water plume management activities
are concluded). The potential for this risk may be
measured by numerical standards such as cancer
risk levels or the volume or concentration of
contaminants in waste, media, or treatment
residuals remaining on the site. The
characteristics of the residuals should be
considered to the degree that they remain
hazardous, taking into account their volume,
toxicity, mobility, and propensity to bio-
accumulate.
• Adequacy and reliability of controls - This factor
assesses the adequacy and suitability of controls,
if any, that are used to manage treatment
residuals or untreated wastes that remain at the
site. It may include an assessment of containment
systems and institutional controls to determine if
they are sufficient to ensure that any exposure to
human and environmental receptors is within
protective levels. This factor also addresses the
long-term reliability of management controls for
providing continued protection from residuals. It
includes the assessment of the potential need to
replace technical components of the alternative,
such as a cap, a slurry wall, or a treatment
system; and the potential exposure pathway and
the risks posed should the remedial action need
replacement.
Table 6-1 lists appropriate questions that may need
to be addressed during the analysis of long-term
effectiveness.
6.2.3.4 Reduction of Toxicity, Mobility, or
Volume Through Treatment
This evaluation criterion addresses the statutory
preference for selecting remedial actions that employ
treatment technologies that permanently and
significantly reduce toxicity, mobility, or volume of the
hazardous substances as their principal element. This
preference is satisfied when treatment is used to
reduce the principal threats at a site through
destruction of toxic contaminants, reduction of the
total mass of toxic contaminants, irreversible
reduction in contaminant mobility, or reduction of total
volume of contaminated media.
This evaluation would focus on the following specific
factors for a particular remedial alternative:
• The treatment processes the remedy will employ,
and the materials they will treat
• The amount of hazardous materials that will be
destroyed or treated, including how the principal
threat(s) will be addressed
• The degree of expected reduction in toxicity,
mobility, or volume measured as a percentage of
reduction (or order of magnitude)
• The degree to which the treatment will be
irreversible
• The type and quantity of treatment residuals that
will remain following treatment
• Whether the alternative would satisfy the statutory
preference for treatment as a principal element6
In evaluating this criterion, an assessment should be
made as to whether treatment is used to reduce
principal threats, including the extent to which toxicity,
mobility, or volume are reduced either alone or in
6 It may be that alternatives for limited actions (e.g., provision of
an alternative water supply) will not address principal threats
within their narrow scope.
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Table 6-1. Long-Term Effectiveness and Permanence
Analysis Factor
Specific Factor Considerations
Magnitude of residual
risks
Adequacy and
reliability of controls
What is the magnitude of the remaining risks?
What remaining sources of risk can be identified? How much is due to treatment residuals, and how
much is due to untreated residual contamination?
Will a 5-year review be required?
What is the likelihood that the technologies will meet required process efficiencies or performance
specifications?
What type and degree of long-term management is required?
What are the requirements for long- term monitoring?
What operation and maintenance functions must be performed?
What difficulties and uncertainties may be associated with long-term operation and maintenance?
What is the potential need for replacement of technical components?
What is the magnitude of the threats or risks should the remedial action need replacement?
What is the degree of confidence that controls can adequately handle potential problems?
What are the uncertainties associated with land disposal of residuals and untreated wastes?
combination. Table 6-2 lists typical questions that
may need to be addressed during the analysis of
toxicity, mobility, or volume reduction.
6.2.3.5 Short-term Effectiveness
This evaluation criterion addresses the effects of the
alternative during the construction and implementation
phase until remedial response objectives are met
(e.g., a cleanup target has been met). Under this
criterion, alternatives should be evaluated with
respect to their effects on human health and the
environment during implementation of the remedial
action. The following factors should be addressed as
appropriate for each alternative:
• Protection of the community during remedial
actions - This aspect of short-term effectiveness
addresses any risk that results from
implementation of the proposed remedial action,
such as dust from excavation, transportation of
hazardous materials, or air-quality impacts from
a stripping tower operation that may affect human
health.
• Protection of workers during remedial actions -
This factor assesses threats that may be posed to
workers and the effectiveness and reliability of
protective measures that would be taken.
• Environmental impacts - This factor addresses
the potential adverse environmental impacts that
may result from the construction and imple-
mentation of an alternative and evaluates the
reliability of the available mitigation measures in
preventing or reducing the potential impacts.
• Time until remedial response objectives are
achieved - This factor includes an estimate of the
time required to achieve protection for either the
entire site or individual elements associated with
specific site areas or threats.
Table 6-3 lists appropriate questions that may need
to be addressed during the analysis of short-term
effectiveness.
6.2.3.6 Implementability
The implementability criterion addresses the technical
and administrative feasibility of implementing an
alternative and the availability of various services and
materials required during its implementation. This
criterion involves analysis of the following factors:
• Technical feasibility
- Construction and operation - This relates to
the technical difficulties and unknowns
associated with a technology. This was
initially identified for specific technologies
during the development and screening of
alternatives and is addressed again in the
detailed analysis for the alternative as a
whole.
Reliability of technology - This focuses on the
likelihood that technical problems associated
with implementation will lead to schedule
delays.
Ease of undertaking additional remedial action
- This includes a discussion of what, if any,
future remedial actions may need to be
undertaken and how difficult it would be to
implement such additional actions. This is
particularly applicable for an FS addressing an
interim action at a site where additional
operable units may be analyzed at a later
time.
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Table 6-2. Reduction of Toxicity, Mobility, or Volume Through Treatment
Analysis Factor Specific Factor Considerations
Treatment process and •
remedy •
Amount of hazardous
material destroyed or •
treated •
Reduction in toxicity, •
mobility, or volume •
•
Irreversibility of the •
treatment
Type and quantity of •
treatment residual •
Statutory preference •
for treatment as a •
principal element
Does the treatment process employed address the principal threats?
Are there any special requirements for the treatment process?
What portion (mass, volume) of contaminated material is destroyed?
What portion (mass, volume) of contaminated material is treated?
To what extent is the total mass of toxic contaminants reduced?
To what extent is the mobility of toxic contaminants reduced?
To what extent is the volume of toxic contaminants reduced?
To what extent are the effects of treatment irreversible?
What residuals remain?
What are their quantities and characteristics?
What risks do treatment residuals pose?
Are principal threats within the scope of the action?
Is treatment used to reduce inherent hazards posed by principal threats at the site?
Table 6-3. Short-Term Effectiveness
Analysis Factor
Basis for Evaluation During Detailed Analysis
Protection of
community during
remedial actions
Protection of workers
during remedial
actions
Environmental
impacts
Time until remedial •
response objectives*
are achieved .
What are the risks to the community during remedial actions that must be addressed?
How will the risks to the community be addressed and mitigated?
What risks remain to the community that cannot be readily controlled?
What are the risks to the workers that must be addressed?
What risks remain to the workers that cannot be readily controlled?
How will the risks to the workers be addressed and mitigated?
What environmental impacts are expected with the construction and implementation of the
alternative?
What are the available mitigation measures to be used and what is their reliability to minimize
potential impacts?
What are the impacts that cannot be avoided should the alternative be implemented?
How long until protection against the threats being addressed by the specific action is achieved?
How long until any remaining site threats will be addressed?
How long until remedial response objectives are achieved?
- Monitoring considerations - This addresses
the ability to monitor the effectiveness of the
remedy and includes an evaluation of the
risks of exposure should monitoring be
insufficient to detect a system failure.
Administrative feasibility
- Activities needed to coordinate with other
offices and agencies (e.g., obtaining permits
for offsite activities or rights-of-way for
construction)
Availability of services and materials
- Availability of adequate offsite treatment,
storage capacity, and disposal services
- Availability of necessary equipment and
specialists, and provisions to ensure any
necessary additional resources
Availability of services and materials, plus the
potential for obtaining competitive bids, which
may be particularly important for innovative
technologies
Availability of prospective technologies
Table 6-4 lists typical questions that may need to be
addressed during the analysis of implementability.
6.2.3.7 Cost
A comprehensive discussion of costing procedures
for CERCLA sites is contained in the Remedial Action
6-10
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Table 64. Implementability
Analysis Factor
Specific Factor Considerations
Technical Feasibility
Ability to construct and
operate technology
Reliability of technology
Ease of undertaking additional
remedial action, if necessary
Monitoring considerations
Administrative Feasibility
Coordination with other
agencies
Availability of Services and
Materials
Availability of
treatment, storage capacity,
and disposal services
Availability of necessary
equipment and specialists
Availability of prospective
technologies
What difficulties may be associated with construction?
What uncertainties are related to construction?
What is the likelihood that technical problems will lead to schedule delays?
What likely future remedial actions may be anticipated?
How difficult would it be to implement the additional remedial actions, if required?
Do migration or exposure pathways exist that cannot be monitored adequately?
What risks of exposure exist should monitoring be insufficient to detect failure?
What steps are required to coordinate with other agencies?
What steps are required to set up long-term or future coordination among agencies?
Can permits for offsite activities be obtained if required?
Are adequate treatment, storage capacity, and disposal services available?
How much additional capacity is necessary?
Does the lack of capacity prevent implementation?
What additional provisions are required to ensure the needed additional capacity?
Are the necessary equipment and specialists available?
What additional equipment and specialists are required?
Does the lack of equipment and specialists prevent implementation?
What additional provisions are required to ensure the needed equipment and
specialists?
Are technologies under consideration generally available and sufficiently demonstrated
for the specific application?
Will technologies require further development before they can be applied full-scale to
the type of waste at the site?
When should the technology be available for full-scale use?
Will more than one vendor be available to provide a competitive bid?
Costing Procedures Manual (U.S. EPA, September
1985). The application of cost estimates to the
detailed analysis is discussed in the following
paragraphs.
Capital Costs. Capital costs consist of direct
(construction) and indirect (nonconstruction and
overhead) costs. Direct costs include expenditures for
the equipment, labor, and materials necessary to
install remedial actions. Indirect costs include
expenditures for engineering, financial, and other
services that are not part of actual installation
activities but are required to complete the installation
of remedial alternatives. (Sales taxes normally do not
apply to Superfund actions.) Costs that must be
incurred in the future as part of the remedial action
alternative should be identified and noted for the year
in which they will occur. The distribution of costs over
time will be a critical factor in making tradeoffs
between capital-intensive technologies (including
alternative treatment and destruction technologies)
and less capital-intensive technologies (such as
pump and treatment systems).
Direct capital costs may include the following:
• Construction costs - Costs of materials, labor and
equipment required to install a remedial action
• Equipment costs - Costs of remedial action and
service equipment necessary to enact the remedy
(these materials remain until the site remedy is
complete)
• Land and site-development costs - Expenses
associated with the purchase of land and the site
preparation costs of existing property
• Buildings and services costs - Costs of process
and nonprocess buildings, utility connections,
purchased services, and disposal costs
• Relocation expenses - Costs of temporary or
permanent accommodations for affected nearby
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residents. (Since cost estimates for relocations
can be complicated, FEMA authorities and EPA
Headquarters should be consulted in estimating
these costs.)
• Disposal costs - Costs of transporting and
disposing of waste material such as drums and
contaminated soils
Indirect capital costs may include:
• Engineering expenses - Costs of administration,
design, construction supervision, drafting, and
treatability testing
• License or permit costs - Administrative and
technical costs necessary to obtain licenses and
permits for installation and operation of offsite
activities
• Startup and shakedown costs - Costs incurred to
ensure system is operational and functional
• Contingency allowances - Funds to cover costs
resulting from unforeseen circumstances, such as
adverse weather conditions, strikes, or
contaminant not detected during site
characterization
Annual O&M Costs. Annual O&M costs are post-
construction costs necessary to ensure the continued
effectiveness of a remedial action. The following
annual O&M cost components should be considered:
• Operating labor costs - Wages, salaries, training,
overhead, and fringe benefits associated with the
labor needed for post-construction operations
• Maintenance materials and labor costs - Costs for
labor, parts, and other resources required for
routine maintenance of facilities and equipment
• Auxiliary materials and energy - Costs of such
items as chemicals and electricity for treatment
plant operations, water and sewer services, and
fuel
• Disposal of residues - Costs to treat or dispose
of residuals such as sludges from treatment
processes or spent activated carbon
• Purchased services - Sampling costs, laboratory
fees, and professional fees for which the need
can be predicted
• Administrative costs - Costs associated with the
administration of remedial O&M not included
under other categories
• Insurance, taxes, and licensing costs - Costs of
such items as liability and sudden accidental
insurance; real estate taxes on purchased land or
rights-of-way; licensing fees for certain
technologies: and permit renewal and reporting
costs
• Maintenance reserve and contingency funds -
Annual payments into escrow funds to cover
costs of anticipated replacement or rebuilding of
equipment and any large unanticipated O&M
costs
• Rehabilitation costs - Cost for maintaining
equipment or structures that wear out over time
• Costs of periodic site reviews - Costs for site
reviews that are conducted at least every 5 years
if wastes above health-based levels remain at
the site
The costs of potential future remedial actions should
be addressed, and if appropriate, should be included
when there is a reasonable expectation that a major
component of the alternative will fail and require
replacement to prevent significant exposure to
contaminants. Analyses described under Section
6.2.3.3, "Long-term Effectiveness and Perma-
nence," should be used to determine which
alternatives may result in future costs. It is not
expected that a detailed statistical analysis will be
required to identify probable future costs. Rather,
qualitative engineering judgment should be used and
the rationale documented in the FS report.
Accuracy of Cost Estimates. Site characterization and
treatability investigation information should permit the
user to refine cost estimates for remedial action
alternatives. It is important to consider the accuracy
of costs developed for alternatives in the FS.
Typically, these "study estimate" costs made during
the FS are expected to provide an accuracy of + 50
percent to -30 percent and are prepared using data
available from the Rl. It should be indicated when it is
not realistic to achieve this level of accuracy.
Present Worth Analysis. A present worth analysis is
used to evaluate expenditures that occur over
different time periods by discounting all future costs
to a common base year, usually the current year.
This allows the cost of remedial action alternatives to
be compared on the basis of a single figure
representing the amount of money that, if invested in
the base year and disbursed as needed, would be
sufficient to cover all costs associated with the
remedial action over its planned life.
In conducting the present worth analysis,
assumptions must be made regarding the discount
rate and the period of performance. The Superfund
program recommends that a discount rate of 5
percent before taxes and after inflation be assumed.
Estimates of costs in each of the planning years are
6-1 2
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made in constant dollars, representing the general
purchasing power at the time of construction. In
general, the period of performance for costing
purposes should not exceed 30 years for the purpose
of the detailed analysis.
Cost Sensitivity Analysis. After the present worth of
each remedial action alternative is calculated,
individual costs may be evaluated through a
sensitivity analysis if there is sufficient uncertainty
concerning specific assumptions. A sensitivity
analysis assesses the effect that variations in specific
assumptions associated with the design,
implementation, operation, discount rate, and effective
life of an alternative can have on the estimated cost
of the alternative. These assumptions depend on the
accuracy of the data developed during the site
characterization and treatability investigation and on
predictions of the future behavior of the technology.
Therefore, these assumptions are subject to varying
degrees of uncertainty from site to site. The potential
effect on the cost of an alternative because of these
uncertainties can be observed by varying the
assumptions and noting the effects on estimated
costs. Sensitivity analyses can also be used to
optimize the design of a remedial action alternative,
particularly when design parameters are
interdependent (e.g., treatment plant capacity for
contaminated ground water and the length of the
period of performance).
Use of sensitivity analyses should be considered for
the factors that can significantly change overall costs
of an alternative with only small changes in their
values, especially if the factors have a high degree of
uncertainty associated with them. Other factors
chosen for analysis may include those factors for
which the expected (or estimated) value is highly
uncertain. The results of such an analysis can be
used to identify worst-case scenarios and to revise
estimates of contingency or reserve funds.
The following factors are potential candidates for
consideration in conducting a sensitivity analysis:
• The effective life of a remedial action
• The O&M costs
• The duration of cleanup
• The volume of contaminated material, given the
uncertainty about site conditions
• Other design parameters (e.g., the size of the
treatment system)
• The discount rate (5 percent should be used to
compare alternative costs, however, a range of 3
to 10 percent can be used to investigate
uncertainties)
The results of a sensitivity analysis' should be
discussed during the comparison of alternatives.
Areas of uncertainty that may have a significant effect
on the cost of an alternative should be highlighted,
and a rationale should be presented for selection of
the most probable value of the parameter.
6.2.3.8 State (Support Agency) Acceptance
This assessment evaluates the technical and
administrative issues and concerns the state (or
support agency in the case of State-lead sites) may
have regarding each of the alternatives. As discussed
earlier, this criterion will be addressed in the ROD
once comments on the RI/FS report and proposed
plan have been received.
6.2.3.9 Community Acceptance
This assessment evaluates the issues and concerns
the public may have regarding each of the
alternatives. As with state acceptance, this criterion
will be addressed in the ROD once comments on the
RI/FS report and proposed plan have been received.
6.2.4 Presentation of Individual Analysis
The analysis of individual alternatives with respect to
the specified criteria should be presented in the FS
report as a narrative discussion accompanied by a
summary table. This information will be used to
compare the alternatives and support a subsequent
analysis of the alternatives made by the decision-
maker in the remedy selection process. The narrative
discussion should, for each alternative, provide (1) a
description of the alternative and (2) a discussion of
the individual criteria assessment.
The alternative description should provide data on
technology components (use of innovative
technologies should be identified), quantities of
hazardous materials handled, time required for
implementation, process sizing, implementation
requirements, and assumptions. These descriptions,
by clearly articulating the various waste management
strategies for each alternative, will also serve as the
basis for documenting the rationale of the applicability
or relevance and appropriateness of potential Federal
and State requirements. Therefore, the significant
ARARs for each alternative should be identified and
integrated into these discussions.
The narrative discussion of the analysis should, for
each alternative, present the assessment of the
alternative against each of the criteria/This
discussion should focus on how, and to what extent,
the various factors within each of the criteria are
7 As noted previously, State and community acceptance will be
addressed in the ROD once comments have been received on
the RI/FS report and proposed plan.
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addressed."The uncertainties associated with
specific alternatives should be included when
changes in assumptions or unknown conditions could
affect the analysis (e.g., the time to attain ground-
water cleanup targets may be twice as long as
estimated if assumptions made about aquifer
characteristics for a specific ground-water extraction
alternative are incorrect.) An example of an individual
analysis is presented in Appendix F.
The FS also should include a summary table
highlighting the assessment of each alternative with
respect to each of the nine criteria. Appendix F
provides an example of such a summary table.
6.2.5 Comparative Analysis of Alternatives
Once the alternatives have been described and
individually assessed against the criteria, a
comparative analysis should be conducted to evaluate
the relative performance of each alternative in relation
to each specific evaluation criterion. This is in
contrast to the preceding analysis in which each
alternative was analyzed independently without a
consideration of other alternatives. The purpose of
this comparative analysis is to identify the advantages
and disadvantages of each alternative relative to one
another so that the key tradeoffs the decisionmaker
must balance can be identified.
Overall protection of human health and the
environment and compliance with ARARs will
generally serve as threshold determinations in that
they must be met by any alternative in order for it to
be eligible for selection. The next five criteria (long-
term effectiveness and permanence; reduction of
toxicity, mobility, and volume through treatment;
short-term effectiveness; implementability; and cost)
will generally require the most discussion because the
major tradeoffs among alternatives will most
frequently relate to one or more of these five.
State and community acceptance will be addressed in
the ROD once formal comments on the RI/FS report
and the proposed plan have been received and a final
remedy selection decision is being made.
6.2.6 Presentation of Comparative Analysis
The comparative analysis should include a narrative
discussion describing the strengths and weaknesses
of the alternatives relative to one another with respect
to each criterion, and how reasonable variations of
'The factors presented in Tables 6-1 through 6-4 have been
included to illustrate typical concerns that may need to be
addressed during the detailed analysis. It will not be necessary
or appropriate in all situations to address every factor in these
tables for each alternative being evaluated. Under some
circumstances, it may be useful to address other factors not
presented in these tables to ensure a better understanding of
how an alternative performs with respect to a particular criterion.
key uncertainties could change the expectations of
their relative performance. An effective way of
organizing this section is, under each individual
criterion, to discuss the alternative(s) that performs
the best overall in that category, with other
alternatives discussed in the relative order in which
they perform. If innovative technologies are being
considered, their potential advantages in cost or
performance and the degree of uncertainty in their
expected performance (as compared with more
demonstrated technologies) should also be
discussed. Appendix F provides an example of a
comparative analysis.
The presentation of differences among alternatives
can be measured either qualitatively or quantitatively,
as appropriate, and should identify substantive
differences (e.g., greater short-term effectiveness
concerns, greater cost, etc.). Quantitative information
that was used to assess the alternatives (e.g.,
specific cost estimates, time until response objectives
would be obtained, and levels of residual con-
tamination) should be included in these discussions.
6.3 Post-RI/FS Selection of the
Preferred Alternative
Following completion of the RI/FS, the results of the
detailed analyses, when combined with the risk
management judgments made by the decision-
maker, become the rationale for selecting a preferred
alternative and preparing the proposed plan.
Therefore, the results of the detailed analysis, or
more specifically the comparative analysis, should
serve to highlight the relative advantages and
disadvantages of each alternative so that the key
tradeoffs can be identified. It will be these key
tradeoffs coupled with risk management decisions
that will serve as the basis for the rationale and
provide a transition between the RI/FS report and the
development of a proposed plan (and ultimately a
ROD). Specific guidance for preparing proposed
plans and RODs is provided in the draft guidance on
preparing Superfund decision documents.
6.4 Community Relations During
Detailed Analysis
Site-specific community relations activities should be
identified in the community relations plan prepared
previously. While appropriate modifications of
activities may be made to the community relations
plan as the project progresses, the plan should
generally be implemented as written to ensure that
the community is informed of the alternatives being
evaluated and is provided a reasonable opportunity to
provide input to the decision-making process.
Often, a fact sheet is prepared that summarizes the
feasible alternatives being evaluated. As appropriate,
small group consultations or public meetings may be
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held to discuss community concerns and explain
alternatives under consideration. Public officials
should be briefed and press releases prepared
describing the alternatives: Other activities 'identified
in the community relations plan should be imple-
mented.
The objective of community relations during the
detailed analysis is to assist the community in
understanding the alternatives and the specific
considerations the lead agency must take into
account in selecting an alternative. In this way, the
community is prepared to provide meaningful input
during the upcoming public comment period.
6.5 Reporting and Communication
During Detailed Analysis
Once the draft RI/FS report is prepared, the lead
agency obtains the support agency's review and
concurrence, the public's review and comment, and
local agency and PRP input, if appropriate. The RI/FS
report also provides a basis for remedy selection by
EPA (or concurrence on State and Federal facility
remedy) and documents the development and
analysis of alternatives. A suggested FS report format
is given in Table 6-5.
Table 6-5. Suggested FS Report Format
Executive Summary
1. Introduction
1.1 Purpose and Organization of Report
1.2 Background Information (Summarized from Rl Report)
1.2.1 Site Description
1.2.2 Site History
1.2.3 Nature and Extent of Contamination
1.2.4 Contaminant Fate and Transport
1.2.5 Baseline Risk Assessment
2. Identification and Screening of Technologies
2.1 Introduction
2.2 Remedial Action Objectives -
Presents the development of remedial action objectives for each medium of interest (i.e., ground water, soil, surface
water, air, etc.). For each medium, the following should be discussed:
Contaminants of interest
Allowable exposure based on risk assessment (including ARARs)
Development of remediation goals
2.3 General Response Actions -
For each medium of interest, describes the estimation of areas or volumes to which treatment, containment, or
exposure technologies may be applied.
2.4 Identification and Screening of Technology Types and Process Options - For each medium of interest, describes:
2.4.1 Identification and Screening of Technologies
2.4.2 Evaluation of Technologies and Selection of Representative Technologies
3. Development and Screening of Alternatives
3.1 Development of Alternatives -
Describes rationale for combination of technologies/media into alternatives. Note: This discussion may be by medium
or for the site as a whole.
3.2 Screening of Alternatives (if conducted)
3.2.1 Introduction
3.2.2 Alternative 1
3.2.2.1 Description
3.2.2.2 Evaluation
3.2.3 Alternative 2
3.2.3.1 Description
3.2.3.2 Evaluation
3.2.4 Alternative 3
4. Detailed Analysis of Alternatives
4.1 Introduction
4.2 Individual Analysis of Alternatives
4.2.1 Alternative 1
4.2.1.1 Description
4.2.1.2 Assessment
4.2.2 Alternative 2
4.2.2.1 Description
4.2.2.2 Assessment
4.2.3 Alternative 3
4.3 Comparative Analysis
Bibliography
Appendices
6-1 5
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American National Standard, Practices for
Respiratory Protection. ANSI Z88.2, 1980k. ANSI,
New York.
Ford, P.J., P.J. Turina, and D.E. Seely. 1983.
Characterization of Hazardous Waste Sites - A
Methods Manual. Volume II - Available Sampling
Methods. EPA Report No. 600/4-83-040. NTIS
No. PB 84-126920. U.S. EPA, Las Vegas.
National Fire Protection Association. 1981. National
Fire Codes. Volumes 1-16. Quincy,
Massachusetts.
National Institute for Occupational Safety and Health.
1985. Guidance Manual for Superfund Activities.
Volumes 1-9. U.S. Department of Health and
Human Services, National Institute for Occupational
Safety and Health, Cincinnati, Ohio.
National Institute for Occupational Safety and Health.
1978. NIOSH/OSHA Pocket Guide to Chemical
Hazards. NIOSH Publication No. 78-210. National
Institute for Occupational Safety and Health and
Occupational Safety and Health Administration,
U.S. Government Printing Office, Washington, D.C.
National Institute for Occupational Safety and Health.
1981. Occupational Health Guidelines for Chemical
Hazards. DHHS (NIOSH) Publication No. 81-123.
Superintendent of Documents, U.S. Government
Printing Office, Washington, D.C.
NIOSH/OSHA/USCG/USEPA. 1985. Occupational
Safety and Health Guidance Manual for Hazardous
Waste Site Activities. U.S. DHHS.
U.S. EPA. 1979. Safety Manual for Hazardous Waste
Site Investigations. National Enforcement
Investigations Center, Washington, D.C.
U.S. EPA. September 1982. Interim Standard
Operating Safety Guides. Hazardous Response
Support Division, Office of Emergency and
Remedial Response, Washington, D.C.
U.S. EPA. April 1985. Characterization of Hazardous
Waste Sites - A Methods Manual. Volume II.
EPA/600/4-841075.
U.S. EPA. May 1985. Guidance Document for
Cleanup of Surface Tanks and Drums. OSWER
Directive No. 9380.0-3.
U.S. EPA. May 1985. Guidance on Remedial
Investigations Under CERCLA. EPA, OSWER,
HWERL; EPA Report #540/6-85/002; NTIS Ref
#PB-85-268616; OSWER Directive 9355.0-
06B. U.S. EPA, Cincinnati, Ohio.
U.S. EPA. June 1985. Guidance on Feasibility
Studies Under CERCLA. EPA, OSWER, OWPE;
EPA Report #540/G-85/003; NTIS Ref #PB-85-
238-590; OSWER Directive 9355.0-05C. U.S.
EPA, Washington, D.C.
U.S. EPA. June 1985. NEIC Policies and Procedures.
Revised. EPA-33019-78-001-R.
U.S. EPA. September 1985. Remedial Action Costing
Procedures Manual. Washington, D.C.
EPA/OERR/HSCD; EPA Report #600/8-87/049;
OSWER Directive 9355.0-10.
U.S. EPA. November 1985. Chemical Emergency
Preparedness Program: Interim Guidance. OSWER
Directive No. 9223.0-1A.
U.S. EPA. January 1986. Superfund Exposure
Assessment Manual. Draft. OSWER Directive
9285.5-01. U.S. EPA, Washington, D.C.
U.S. EPA. October 1986. Superfund Public Health
Evaluation Manual (SPHEM). EPA/540/1-86/060,
OSWER Directive 9285.4-I. U.S. EPA,
Washington, D.C.
U.S. EPA. December 1986. Superfund Federal-Lead
Remedial Project Management Handbook. OSWER
Directive No. 9355.1-1.
U.S. EPA. December 1986. Superfund Innovative
Technology Evaluation (SITE) Strategy and
Program Plan. OSWER Directive No. 9380.2-3.
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U.S. EPA. December 1986. Superfund State-Lead
Remedial Project Management Handbook.
EPA/OERR/HSCD, EPA Report #540/G-87/001,
OSWER Directive 9355.2-01. U.S. EPA,
Washington, D.C.
U.S. EPA. December 1986. User's Guide to the
Contract Laboratory Program.
U.S. EPA. March 1987. Data Qualify Objectives for
Remedial Response Activities. OSWER Directive
9335.0-7B. (Also called DQO Guidance.) U.S.
EPA, Washington, D.C.
U.S. EPA. March 1987. Guidance for Coordinating
ATSDR Health Assessment Activities with the
Superfund Remedial Process. OSWER Directive
No. 9285.4-02.
U.S. EPA. September 1987. Compendium of
Superfund Field Operations Methods. OSWER
Directive 9355.0-14, EPA/540/P-87/00/a (also
called Compendium).
U.S. EPA. March 1988. Draft Guidance on Preparing
Superfund Decision Documents. OSWER Directive
9355.3-02.
U.S. EPA. May 1988. CERCLA Compliance with
Other Laws Manual. Draft. OSWER Directive
9234.1-01. U.S. EPA, Washington, D.C.
U.S. EPA. June 1988. Community Relations in
Superfund: A Handbook. Interim. OSWER Directive
9230.0-3A.
U.S. EPA. June 1988. "Interim Guidance on
Administrative Records for Selection of CERCLA
Response Actions." Draft. OSWER Directive No.
9833.3A.
U.S. EPA. August 1988. Guidance on Remedial
Actions for Contaminated Ground Water at
Superfund Sites, Draft. OSWER Directive No.
9283.1-2.
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of Superfund Memorandum of Agreement. OSWER
Directive No. 9375.0-01.
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Guide for Treatment of CERCLA Soils and
Sludges. EPA/540/2-88/004.
U.S. EPA. April 1988. Superfund Exposure
Assessment Manual. OSWER Directive No.
9285.5-1.
U.S. EPA. CLP Invitation for Bids.
U.S. EPA. Functional Guidelines for Evaluating
Organic Analyses. (EPA 69-01-6699.)
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Appendix A
Interim Guidance on PRP Participation in the RI/FS Process"
I. Introduction
This memorandum sets forth the policy and
procedures governing the participation of potentially
responsible parties (PRPs) in the development of
remedial investigations (Rl) and feasibility studies (FS)
under the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), as
amended by the Superfund Amendments and
Reauthorization Act (SARA) of 1986. This
memorandum discusses:
• The initiation of enforcement activities including
PRP searches and PRP notification;
• The circumstances in which PRPs may conduct
the RI/FS;
• The development of enforceable agreements
governing PRP RI/FS activities;
• Initiation of PRP RI/FS activities and oversight of
the RI/FS by EPA;
• EPA control over PRP RI/FS activities; and
• PRP participation in Agency-financed RI/FS
activities.
More detailed information regarding each of the above
topics is included in Attachments I-4 of this
appendix.
This document is consistent with CERCLA and EPA
guidance in effect as of October 1988, and is
intended to supersede the March 20, 1984
memorandum from Assistant Administrators Lee M.
Thomas and Courtney M. Price entitled "Participation
of Potentially Responsible Parties in Development of
Remedial Investigations and Feasibility Studies Under
CERCLA" (OSWER Directive No. 9835.1). Users of
this guidance should consult the RI/FS Guidance or
any relevant guidance or policies issued after
distribution of this document before establishing
EPA/PRP responsibilities for conducting RI/FS
activities. Additional guidance regarding procedures
for EPA oversight activities will be available in the
Office of Waste Program Enforcement's (OWPE)
forthcoming "Guidance Manual on Oversight of
Potentially Responsible Party Remedial Investigation
and Feasibility Studies".
II. Background
Sections 104/122 of CERCLA provide PRPs with the
opportunity to conduct the RI/FS when EPA
determines (1) that the PRPs are qualified to conduct
such activities and (2) they will carry out the activities
in accordance with CERCLA requirements and EPA
procedures. 1The Agency will continue its policy of
early and timely PRP searches as well as early PRP
notification and negotiation for RI/FS activities.
It is also the policy of EPA to encourage the early and
active participation of PRPs in conducting RI/FS
activities. EPA believes that early participation of
PRPs in the remedial process will encourage PRP
implementation of the selected remedy. PRP
participation in RI/FS activities will ensure that they
have a better and more complete understanding of
the selected remedy, and thus will be more likely to
agree on implementation of the remedy. Remedial
activities performed by PRPs will also conserve Fund
monies, thus making additional resources available to
address other sites.
As part of the Agency's effort to encourage PRP
participation in remedial activities, EPA will consider
the PRPs' role in conducting RI/FS activities when
assessing an overall settlement proposal for the
remedial design and remedial action. For example,
when the Agency performs a non-binding allocation
of responsibility (NEAR), the Agency may consider
previous PRP efforts and cooperation. This will
provide an additional incentive for PRPs to be
cooperative in conducting RI/FS activities.
* This memorandum was signed by the AA OSWER and
released for distribution on May 16, 1988. Technical
clarifications/updates have been made to this guidance for
insertion into Appendix A of the "Interim Final Guidance for
Conducting Remedial Investigations and Feasibility Studies"
(October 1988-OSWER Directive No. 9355.3-01) (Referred
to herein as the RI/FS Guidance).
'The legal authority to enter into agreements with PRPs is
found in CERCLA Section 122(a). This section then refers to
response actions conducted pursuant to Section 104(b). For
the purposes of this guidance, Sections 104/122 will be cited
when referring to such authority.
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Although EPA encourages PRP participation in
conducting the RI/FS, the Agency and CERCLA
impose certain conditions governing their partici-
pation. These conditions are intended to assure that
the RI/FS performed by the PRPs is consistent with
Federal requirements and that there is adequate
oversight of those activities. These conditions are
discussed both in Section III and Attachment I of this
memorandum.
At the discretion of EPA, a PRP (or group of PRPs)
may assume full responsibility for undertaking RI/FS
activities pursuant to Sections 104/122 of CERCLA.
The terms and conditions governing the RI/FS
activities should be specified in an Administrative
Order. The use of Administrative Orders is authorized
in CERCLA Section 122(d)(3); they are the preferred
type of agreement for RI/FS activities since they are
authorized internally and therefore, may be negotiated
more quickly than Consent Decrees. Before SARA,
Administrative Orders were signed using the
authorities of Section 106 of CERCLA. New
provisions in SARA allow for Orders to be signed
using the authorities of Sections 1041122; Section
104/122 Orders do not require EPA to make a finding
of imminent and substantial endangerment.
RI/FS activities developed subsequent to the
Administrative Order are set forth in a Statement of
Work, which is then embodied or incorporated by
reference into the Order. A Work Plan describing
detailed procedures and criteria by which the RI/FS
will be performed is developed by the PRPs and, after
approval by EPA, should also be incorporated by
reference into the Administrative Order.
It is the responsibility of the lead agency to ensure
the quality of the effort if the PRPs assume
responsibility for conducting the RI/FS. Therefore,
EPA will establish oversight procedures and project
controls to ensure that the response actions are
consistent with CERCLA and the National
Contingency Plan (NCP). Section 104(a)(1) of
CERCLA mandates that no PRP be allowed to
undertake an RI/FS unless EPA determines that the
party(ies) conducting the RI/FS is qualified to do so.
In addition, Section 104(a)(l) requires that a qualified
party be contracted with or arranged for to assist in
overseeing and reviewing the conduct of the RI/FS
and, that the PRPs agree to reimburse EPA for the
costs associated with the oversight contract or
arrangement.
III. Initiation of Enforcement Activities
As part of effective management of enforcement
activities, timely settlements for RI/FS activities are to
be pursued. This includes conducting PRP searches
early in the site discovery process and subsequent
notification to all PRPs of their potential liability and of
their opportunity to perform response activities.
Guidance on conducting timely and effective PRP
searches is contained in the guidance manual,
"Potentially Responsible Party Search Manual"
(August 17, 1987 - OSWER Directive No. 9834.6).
EPA policy has been to notify PRPs of their potential
liability for the planned response activities, to
exchange information about the site, and to provide
PRPs with an opportunity to undertake or finance the
response activities themselves. In the past this has
been accomplished by issuing a "general notice"
letter to the PRPs. In addition to the use of the
general notice letter, Section 122(e) of CERCLA now
authorizes EPA to use "special notice" procedures,
which for an RI/FS, establish a 60 to 90 day
moratorium and formal negotiation period. The
purpose of the moratorium is to provide time for
formal negotiation between EPA and the PRPs for
conduct of RI/FS activities. In particular, use of the
special notice procedures triggers a 60 day
moratorium on EPA conduct of the RI/FS. During the
60 day moratorium, if the PRPs provide EPA with a
"good faith offer" to conduct or finance the RI/FS, the
negotiation period can be extended to a total of 90
days. EPA considers a good faith offer to be a written
proposal where the PRPs make a showing of their
qualifications and willingness to conduct or finance
the RI/FS. Minor deficiencies in the PRPs' initial
submittals should not be grounds for a determination
that the offer is not a good faith offer or that the
PRPs are unable to perform the RI/FS.
To facilitate, among other things, PRP participation in
the RI/FS process, Section 122(e)( 1) requires the
special notice letter to provide the names and
addresses of other PRPs, the volume and nature of
substances contributed by each PRP, and a ranking
by volume of substances at the site, to the extent this
information is available at the time of special notice.
Regions are encouraged to release this information to
PRPs when the notice letters are issued. To expedite
settlements, Regions are also encouraged to give
PRPs as much guidance as possible concerning the
RI/FS process. It is appropriate to transmit to PRPs
copies of important guidance documents such as the
RI/FS Guidance, as well as model Administrative
Orders and Statements of Work. A model
Administrative Order can be found in the
memorandum from Gene Lucero entitled, "Model
CERCLA Section 106 Consent Order for an RI/FS"
(January 31, 1985 - OSWER Directive No. 9835.5).
This model order is currently being revised to reflect
SARA requirements and will be forthcoming. A model
Statement of Work has been included as Appendix C
to the RI/FS Guidance, while a model Statement of
Work for PRP-lead RI/FSs is currently being
developed by OWPE. Other Regional and
Headquarters guidance relating to technical issues
may be given to PRPs, as well as examples of project
plans (plans that must be developed prior to the
conduct of the RI/FS) that are of high quality. A
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description of the required project plans is included in
Attachment II.
Although use of the special notice procedures is
discretionary, Regions are encouraged to use these
procedures in the majority of cases. If EPA decides
not to employ the special notice procedures
described in Section 122(e), the Agency will notify the
PRPs in writing of such a decision, including an
explanation as to why EPA believes the use of the
special notice procedures is inappropriate. Additional
information on the content of special notice letters,
including the use of these notice provisions, can be
found in the memorandum entitled "Interim Guidance
on Notice Letters, Negotiations, and Information
Exchange" (October 19, 1987 - OSWER Directive
No. 9834.10).
Section 121 (f)( 1) requires that the State be notified of
PRP negotiations and that an opportunity for State
participation in such negotiations be provided. In
addition, Section 12 2(j)(l) requires that if a release or
threat of release at the site in question may have
resulted in damages to natural resources, EPA must
notify the appropriate Federal or State Trustee and
provide an opportunity for the Trustee to participate in
the negotiations. To simplify the notification of Federal
Trustees, the Agency intends to provide a list of
projects in the Superfund Comprehensive
Accomplishments Plan (SCAP) to the Trustees as
notice to participate in the negotiations. In those
cases where there is reason to believe that a
significant natural resource will be affected, direct
coordination with the Federal and/or State Trustee will
be required.
IV. Conditions for EPA Involvement in,
and PRP Initiation of, RI/FS Activities
Under Section 104(a)( 1) EPA may authorize PRPs to
conduct RI/FS activities at any site, provided the
PRPs can do so promptly and properly and can meet
the conditions specified by EPA for conducting the
RI/FS. These conditions are discussed in Attachment
I of this appendix and involve the scope of activities,
the organization of the PRPs, and the PRPs' (and
their contractors') demonstrated expertise. EPA
encourages PRPs to conduct the RI/FS provided that
the PRPs commit in an Order (or Consent Decree)
under CERCLA Sections 104/122 (or Sections
106/122 for a Decree) to conduct a complete RI/FS to
the satisfaction of EPA, under EPA oversight.2
Oversight of RI/FS activities by the lead agency is
required by Section 104(a)(l) and is intended to
assure that the RI/FS is adequate for lead agency
2 For a State-lead enforcement site the State is responsible for
oversight unless otherwise specified in the agreement between
the State and EPA. EPA should maintain communication with
the State to ensure that the State is providing oversight of the
remedial activities.
identification of an appropriate remedy, and that it will
otherwise meet the Agency requirements of CERCLA,
the NCP, and relevant Agency guidance. EPA will
allow PRPs to conduct RI/FS activities and will
provide review and oversight under the following
general circumstances.
EPA's priority is to address those NPL sites that have
been identified on the SCAP. The SCAP is an EPA
management plan which identifies site- and
activity-specific Superfund financial allocations for
each quarter of the current fiscal year. When
employing Section 122(e) notice procedures, EPA will
notify PRPs of its intention to conduct RI/FS activities
at NPL sites in a manner that allows at least 90 days
notice before obligating the funds necessary to
complete the RI/FS (see Section III of this guidance).
During this time frame PRPs may elect to conduct the
RI/FS, under the review and oversight of EPA. If the
PRPs agree to conduct the RI/FS they must meet the
conditions discussed in Attachment I. The scope and
terms for conducting the studies are embodied in an
Agreement; as mentioned in Section II, Administrative
Orders are the preferred type of Agreement for RI/FS
activities.
EPA will not engage in lengthy discussions with PRPs
over whether the PRPs will conduct the RI/FS; rather,
EPA will adhere to the time frames established by the
Section 122 special notice provisions. In most
instances, once Fund resources have been obligated
to conduct the RI/FS, the PRPs will no longer be
eligible to conduct the RI/FS activities at the site.
The actions described below are typically taken to
initiate RI/FS activities:
• EPA develops a site-specific Statement of Work
(SOW) in advance of the scheduled RI/FS start.
This SOW is then provided to the PRPs along
with a draft of the Administrative Order (or
Consent Decree) at the initiation of negotiations.
(PRPs may, with EPA approval, submit a single
site plan that incorporates the elements of an
SOW and a detailed Work Plan as a first
deliverable once the Agreement has been signed.
This combined site plan must clearly set forth the
scope of the proposed RI/FS and would be
incorporated into the Agreement in place of the
SOW.)
• Final provisions of the SOW are negotiated with
the Order.
• EPA determines whether the PRPs possess the
necessary capabilities to conduct an RI/FS in a
timely and effective manner (conducted
simultaneously with other negotiations).
• EPA develops a Community Relations Plan
specifying any activities that may be required of
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the PRPs. (Community relations activities are
discussed in Attachment II.)
• EPA determines contractor and staff resources
required for oversight and initiates planning the
necessary oversight requirements. This process
may include preparing a Statement of Work, if a
contractor is to develop an "oversight plan."
• EPA and PRPs identify and procure any
necessary assistance.
• PRPs submit a Work Plan to EPA for Agency
review and approval. The Work Plan must present
the methodology and rationale for conducting the
RI/FS as well as detailed procedures and
requirements, if such procedures have not been
set forth in the Agreement. This Work Plan, which
in most instances is one of the first deliverables
under the Order, is commonly incorporated into
the Agreement following EPA approval.
• PRPs are responsible for obtaining access to the
site; however, if access cannot be obtained, EPA,
with the assistance of DOJ, will secure access
subject to PRP reimbursement for the costs
incurred in securing such access.
These standardized actions ensure that the scope of
the RI/FS activities to be conducted by the PRPs, and
the procedures by which the RI/FS is performed, are
consistent with EPA policy and guidance. Additional
actions may be required either for a technically
complex site or for a site where a number of PRPs
are involved. Regardless of the circumstances, the
actions listed in this section should be negotiated as
expeditiously as possible. Specific elements of these
actions are discussed in Attachment II.
V. Development of the RI/FS
Administrative Order or Consent
Decree
The PRPs must respond to EPA's notice letter by
either declining, within the time specified, to
participate in the RI/FS, or by offering a good faith
proposal to EPA for performing the RI/FS. Declining
to participate in the RI/FS may be implied if the PRPs
do not negotiate during the moratorium established by
the notice letter. If the PRPs have declined to
participate, or the time specified has lapsed, EPA will
obligate funds for performing the RI/FS. If a good faith
proposal is submitted, EPA will negotiate with the
PRPs on the scope and terms for conducting the
RI/FS.
The results of successful negotiations will, in most
cases, be contained in an Administrative Order, or
where the site is in litigation, in a Judicial Consent
Decree entered into pursuant to Section 122(d) of
CERCLA. Guidance for the development of an
Administrative Order is provided in OWPE's
document "Administrative Order: Workshop and
Guidance Materials" (September 1984), and in the
memorandum from Gene Lucero entitled "Model
CERCLA Section 106 Consent Order for an RI/FS"
(January 31, 1985). (The latter guidance is currently
being revised since the provisions in SARA allow for
Orders to be signed using the authorities of Sections
104/122.)
An Administrative Order (or Consent Decree) will
generally contain the scope of activities to be
performed (either as a Statement of Work or Work
Plan), the oversight roles and responsibilities, and
enforcement options that may be exercised in the
event of noncompliance (such as stipulated
penalties). In addition to the above, the Agreement
will typically include the following elements, as agreed
upon by EPA, the PRPs, and other signatories to the
Agreement.
• Jurisdiction - Describes EPA's authority to enter
into Administrative Orders or Consent Decrees.
• Parties bound - Describes to whom the
Agreement applies and is binding upon.
• Purpose - Describes the purpose of the
Agreement in terms of mutual objectives and
public benefit.
• Findings of fact, determination, and conclusions
of law - Provides an outline of facts upon which
the Agreement is based, including the fact that
PRPs are not subject to a lesser standard of
liability and will not receive preferential treatment
from the Agency in conducting the RI/FS.
• Notice to the State - Verifies that the State has
been notified of pending site activities.
• Work to be performed - Provides that PRPs
submit project plans to the lead-agency for
review and approval before commencing RI/FS
activities. Project plans are those plans developed
in order to effectively conduct the RI/FS project
and include: a Work Plan, describing the
methodology, rationale, and schedule of all tasks
to be performed during the RI/FS; a Sampling and
Analysis Plan, describing the field sampling
procedures to be performed as well as the quality
assurance procedures which will be followed for
sampling and analysis (including a description of
how the data gathered during the RI/FS will be
managed) and the analytical procedures to be
employed; and a Health and Safety Plan
describing health and safety precautions to be
exercised while onsite. (More information on the
contents of these project plans can be found in
Attachment II of this appendix.)
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• Compliance with CERCLA, the NCP, and
Relevant Agency Guidance - Specifies that the
actions at a site will comply with the requirements
of CERCLA, the NCP, and relevant Agency
guidance determined to be appropriate for site
remediation.
• Reimbursement of costs - Specifies that PRPs
will assume all costs of performing the work
required by the Agreement. In addition, this
section commits PRPs to reimbursement of costs
associated with oversight activities. This includes
reimbursement for qualified party assistance in
oversight, as required by Section 104(a)(l). This
section should also specify the nature and kind of
cost documentation to be provided and the
process for billing and receiving payment.
• Reporting - Specifies the type and frequency of
reporting that PRPs must provide to EPA.
Normally the reporting requirements will, at a
minimum, include the required project plans as
well as those deliverables required by the RI/FS
Guidance. Additional reporting requirements are
left to the discretion of the Regions. That is,
Regions may require additional deliverables such
as interim reports on particular Rl or FS activities.
• Designated EPA, State, and PRP project
coordinators - Specifies that EPA, the State, and
PRPs shall each designate a project coordinator.
• Site access and data availability - Stipulates that
PRPs shall allow access to the site by EPA, the
State, and oversight personnel. Access will be
provided for inspection and monitoring purposes
that in any way pertain to the work undertaken
pursuant to the Order. In addition, access will be
provided in the event of project takeover. This
section also stipulates that EPA will be provided
with all currently available data.
• Record preservation - Specifies that all records
must be maintained by both parties for a
minimum of 6 years after termination of the
Agreement, followed by a provision requiring
PRPs to offer the site records to EPA before
destruction.
• Administrative record requirements - Provides
that all information upon which the selection of
remedy is based must be submitted to EPA in
fulfillment of the administrative record
requirements pursuant to Section 113 of
CERCLA. (Additional information on administrative
record requirements is contained in Attachment
• Dispute resolution - Specifies steps to be taken if
a dispute occurs. The Administrative Order states
that with respect to all submittals and work
performed, EPA will be the final arbiter, while the
court is the final arbiter for a Consent Decree.
(More information on dispute resolution can be
found in Attachment IV of this appendix.)
• Delay in performance/stipulated penalties -
Specifies EPA's authority to invoke stipulated
penalties for noncompliance with Order or Decree
provisions. Section 121 of CERCLA requires that
Consent Decrees contain provisions for penalties
in an amount not to exceed $25,000 per day. In
addition to stipulated penalties, Section 122(1)
provides that Section 109 civil penalties apply for
violations of Administrative Orders and Consent
Decrees. Delays that endanger public health
and/or the environment may result in termination
of the Agreement and EPA takeover of the RI/FS.
(More information on stipulated penalties can be
found in the Office of Enforcement and
Compliance Monitoring's (OECM) "Guidance on
the Use of Stipulated Penalties in Hazardous
Waste Consent Decrees" (September 21, 1987)
and in Attachment IV of this appendix.)
• Financial assurance - Specifies that PRPs should
have adequate financial resources or insurance
coverage to address liabilities resulting from their
RI/FS activities. When using contractors, PRPs
should certify that the contractors have adequate
insurance coverage or that contractor liabilities
are indemnified.
• Reservation of rights - States that PRPs are not
released from all CERCLA liability through
compliance with the Agreement, or completion of
the RI/FS. PRPs may be released from liability
relating directly to RI/FS requirements, if PRPs
complete the RI/FS activities to the satisfaction of
EPA.
• Other claims - Provides that nothing in the
Agreement shall constitute a release from any
claim or liability other than, perhaps, for the cost
of the RI/FS, if completed to EPA satisfaction.
Also provides that nothing in the Agreement shall
constitute preauthorization of a claim against the
Fund under CERCLA. This section should also
specify the conditions for indemnification of the
U.S. Government.
• Subsequent modifications/additional work -
Specifies that the PRPs are committed to perform
any additional work or subsequent modifications
which are not explicitly stated in the Work Plan, if
EPA determines that such work is needed to
enable the selection of an appropriate response
action. (Attachment IV contains additional
information on this clause.)
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VI. Statement of Work and Work Plan
Based upon available models and guidance, the
Region should present to the PRPs at the initiation of
negotiations a Statement of Work (SOW) and draft
Administrative Order. The SOW describes the broad
objectives and general activities to be undertaken in
the RI/FS. (The PRPs may develop the SOW if it is
determined to be appropriate for a particular case.)
Once the PRPs receive the SOW they develop a
more detailed Work Plan, which should be
incorporated by reference into the Order following
EPA approval. The Work Plan expands the tasks
described in the SOW and presents the rationale and
methodology (including detailed procedures and
schedules) for conducting the RI/FS. It should be
noted that EPA, rather than the PRPs, may develop
the work plan in the event of unusual circumstances.
VII. Review and Oversight of the RI/FS
To ensure that the RI/FS conforms to the NCP and
the requirements of CERCLA, including Sections
104(a)( 1) and 121, EPA will review and oversee PRP
activities. Oversight is also required to ensure that the
RI/FS will result in sufficient information to allow for
remedy selection by the lead agency.
The oversight activities that EPA, the State, and other
oversight personnel will be performing should be
determined prior to the initiation of the RI/FS.
Different mechanisms will be used for the review and
oversight of different PRP products and activities.
These mechanisms, and corresponding PRP
activities, should be determined and if possible
incorporated in the Order. Generally, the following
oversight activities should be specified:
• Review of plans, reports, and records;
• Oversight of field activities (including maintenance
of records and documentation);
• Meetings; and
• Special studies.
Section 104(a)(l) requires that the President contract
with or arrange for a "qualified person" to assist in
the oversight and review of the conduct of the RI/FS.
EPA believes that qualified persons, for the purposes
of overseeing RI/FS activities, are those firms or
individuals with the professional qualifications,
expertise, and experience necessary to provide
assurance that the Agency is conducting meaningful
and effective oversight of PRP activities. In this
context, the qualified person generally will be either
an ARCs, TES, or REM contractor. EPA employees,
employees of other Federal agencies, State
employees, or any other qualified person EPA
determines to be appropriate however, may be asked
to perform the necessary oversight functions.
As part of the Section 104 requirements, PRPs are
required to reimburse EPA for qualified party
oversight costs. It is Agency policy to recover all
response costs at a site including all costs associated
with oversight. Additional guidance on oversight and
project control activities is presented in Attachments
III and IV, respectively.
VI11. Control of Activities
EPA will usually not intervene in a PRP RI/FS if
activities are conducted in conformance with the
conditions and terms specified by the Order. When
deficiencies are detected, EPA will take immediate
steps to correct the PRP activities. Deficiencies will
be corrected through the use of the following
activities: (1) identification of the deficiency; (2)
demand for corrective measures; (3) use of dispute
resolution mechanisms, where appropriate; (4)
imposition of penalties; and if necessary, (5) PRP
RI/FS termination and project takeover or judicial
enforcement. These activities are described in detail
in Attachment IV of this appendix.
IX. PRP Participation in Agency-
Financed RI/FS Activities
PRPs that elect not to perform the RI/FS should be
allowed an opportunity for involvement in a Fund-
financed RI/FS. Private parties may possess technical
expertise or knowledge about a site which would be
useful in developing a sound RI/FS. Involvement by
PRPs in the development of a Fund-financed RI/FS
may also expedite remediation by identifying and
satisfactorily resolving differences between the
Agency and private parties.
Section 113(k)(2)(B) requires that interested persons,
including PRPs, be provided an opportunity for
participation in the development of the administrative
record. PRP participation may include the submittal of
information, relevant to the selection of remedy, for
inclusion in the record and/or the review of record
contents and submittal of comments on such
contents.
The extent of additional PRP involvement will be left
to the discretion of the Region and may include
activities such as:
• Access to the site to observe sampling and
analysis activities;
• Access to validated data and draft reports.
With respect to PRP access to a site, it is within the
Regions' discretion to impose conditions based on
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safety and other relevant considerations. To the
extent that the Region determines that access is
appropriate under the circumstances, PRPs must
reimburse EPA for all identifiable costs incurred with
the connection of the accesses afforded the PRPs,
and must execute appropriate releases in favor of the
EPA and its contractors. With respect to providing
data, it should be noted that the Region is required to
allow private citizens access to the same information
that is provided to the PRPs. The Regions must
therefore take this into consideration when
determining the extent of the PRP's involvement in a
Fund-financed RI/FS.
Aside from participation in the administrative record,
which is a statutory requirement, the final decision
whether to permit PRPs to participate in other
aspects of the Fund-financed RI/FS (as well as the
scope of any participation) rests with the Regions.
This decision should be based on the ability of PRPs
to organize themselves so that they can participate as
a single entity, and the ability of PRPs to participate
without undue interference with or delay in completion
of the RI/FS, and other factors that the Regions
determine are relevant. The Region may terminate
PRP participation in RI/FS development if
unnecessary expenses or delays occur.
X. Contact
For further information on the subject matter
discussed in this interim guidance, please contact
Susan Cange (FTS 475-9805) of the Guidance and
Oversight Branch, Office of Waste Program
Enforcement.
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Attachment I
Conditions for PRP Conduct of the RI/FS
Organization and Management
When several potentially responsible parties are
involved at a site they must be able to organize
themselves quickly into a single representative body
to negotiate with EPA. To facilitate this negotiation
process, EPA will make available the names and
addresses of other PRPs, in accordance with the
settlement provisions of CERCLA Section 122(e).
Either a single PRP or an organized group of PRPs
may assume responsibility for development of the
RI/FS.
Scope of Activities
As part of the negotiation process PRPs must agree
to follow the site-specific Statement of Work (SOW)
as the basis for conducting an RI/FS. PRPs are
required to submit an RI/FS Work Plan setting forth
detailed procedures and tasks necessary to
accomplish the RI/FS activities described in the SOW.
EPA may approve reasonable modifications to the
SOW and will reject any requests for modifications
that are not consistent with CERCLA (as amended by
SARA), the NCP, the requirements set forth in this
guidance document, the RI/FS Guidance, or other
relevant CERCLA guidance documents.
Demonstrated Capabilities
PRPs must demonstrate to EPA that they possess, or
are able to obtain, the technical expertise necessary
to perform all relevant activities identified in the SOW,
and any amendments that may be reasonably
anticipated to that document. In addition, PRPs must
demonstrate that they possess the managerial
expertise and have developed a management plan
sufficient to ensure that the proposed activities will be
properly controlled and efficiently implemented. PRPs
must also demonstrate that they possess the financial
capability to conduct and complete the RI/FS in a
timely and effective manner. These capabilities are
discussed briefly below.
• Demonstrated Technical Capability
PRPs should be required to demonstrate the
technical capabilities of key personnel involved in
executing the project. Personnel qualifications may be
demonstrated by submitting resumes and references.
PRPs may demonstrate the capabilities of the firm
that will perform the work by outlining their past areas
of business, relevant projects and experience, and
overall familiarity with the types of activities to be
performed as part of the remedial investigation and
feasibility study.
It is important that qualified firms be retained for
performing RI/FS activities. Firms that do not have the
necessary expertise for performing RI/FS studies may
create unnecessary delays in the project and may
create situations which further endanger public health
or the environment. These situations may be created
when PRP contractors submit insufficient project
plans, submit deficient reports, or perform inadequate
field work. Furthermore, excessive Agency oversight
may be required in the event that an unqualified
contractor performs the RI/FS; the Agency may have
to significantly increase its workload by providing
repeated reviews of project plans, reports, and
oversight of field activities.
The PRPs must also demonstrate the technical
capabilities of the laboratory chosen to do the
analysis of samples collected during the RI/FS. If a
non-CLP laboratory is selected, EPA may require a
submission from the laboratory which provides a
comprehensive statement of the laboratories'
personnel qualifications, equipment specifications,
security measures, and any other material necessary
to prove the laboratory is qualified to conduct the
work.
• Demonstrated Management Capability
PRPs must demonstrate that they have the
administrative capabilities necessary for conducting
the RI/FS in a responsible and timely manner. A
management plan should be submitted to EPA either
during negotiations or as a part of the Work Plan
which includes a discussion of roles and
responsibilities of key personnel. This management
plan should include an RI/FS team organization chart
describing responsibilities and lines of authority.
Positions and responsibilities should be clearly related
to technical and managerial qualifications. The PRPs
should also demonstrate an understanding of effective
communications, information management, quality
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assurance, and quality control systems. PRPs usually
procure the services of consultants to conduct the
required RI/FS activities. The consultants must
demonstrate, in addition to those requirements stated
above, effective contract management capabilities.
• Demonstrated Financial Capability
The PRPs should develop a comprehensive and
reasonable estimate of the total cost of anticipated
RI/FS activities. EPA will decide on a case-by-case
basis if the PRPs will be required to demonstrate that
they have the necessary financial resources available
and committed to conduct the RI/FS activities. The
resources estimated should be adequate to cover the
anticipated costs for the RI/FS as well as the costs
for oversight, plus a margin for unexpected expenses.
If, during the conduct of the RI/FS the net worth of
the financial mechanism providing funding for the
RI/FS is reduced to less than that required to
complete the remaining activities, the PRPs should
immediately notify EPA. Under conditions specified in
the Order, PRPs are required to complete the RI/FS
irregardless of initial cost estimates or financial
mechanisms.
• Assistance for PRP Activities
If PRPs propose to use consultants for conducting or
assisting in the RI/FS, the PRPs should specify the
tasks to be conducted by the consultants and submit
personnel and corporate qualifications of the pro-
posed firms to the EPA for review. Verification should
be made that the PRPs' consultants have no conflict
of interest with respect to the project. Any consultants
having current EPA assignments as prime contractors
or as subcontractors must obtain approval from their
EPA Contract Officers before performing work for
PRPs. Lack of clarification on possible conflicts of
interest may delay the PRP RI/FS. EPA will reserve
the right to review the PRPs' proposed selection of
consultants and will disapprove their selection if, in
EPA's opinion, they either do not possess adequate
technical capabilities or there exists a conflict of
interest. It should be noted that the responsibility for
selection of consultants rests with the PRPs.
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Attachment II
Initiation of PRP RI/FS Activities
Development of the Statement of Work
After the PRPs have been identified in the PRP
Search Report they are sent either a general notice
letter followed by a special notice letter or a general
notice letter followed by an explanation pursuant to
Section 122(a) why special notice procedures are not
being used. EPA will engage in negotiations with
those PRPs who have submitted a good faith offer in
response to the notice letter and therefore have
volunteered to perform the RI/FS. While the PRPs are
demonstrating their capabilities for conducting the
RI/FS, EPA will negotiate the terms of the
Administrative Order. Either an acceptable Statement
of Work or Work Plan must be incorporated by
reference into the Agreement.
The Statement of Work (SOW) is typically developed
by EPA and describes, in a comprehensive manner,
all RI/FS activities to be performed, as reasonably
anticipated, prior to the onset of the project. The
SOW focuses on broad objectives and describes
general activities that will be undertaken to achieve
these objectives. Detailed procedures by which the
work will be accomplished are not presented in the
SOW, but are described in the subsequent Work Plan
that is developed by the PRPs. In certain instances,
with the approval of EPA, PRPs may prepare a single
site plan incorporating the elements of an SOW and a
Work Plan. In such instances, the site plan will be
incorporated into the Order in place of the broader
sow.
• Use of the EPA Model SOW
EPA has developed a model SOW defining a
comprehensive RI/FS effort which is contained in the
RI/FS Guidance. Additionally, a model SOW for a
PRP-lead RI/FS is being developed by OWPE and
will be forthcoming. The Regions should develop a
site-specific SOW based upon the model(s). RI/FS
projects managed by PRPs will involve, at a
minimum, all relevant activities set forth in the EPA
model SOW. Further, all plans and reports identified
as deliverables in the EPA model SOW must be
identified as deliverables in the site-specific SOW
and/or the Work Plan developed by the PRPs.
Additional deliverables may be required by the
Regions and should be added to the Administrative
Order.
• Modification of the EPA Draft SOW Requirements
The activities set forth in the model SOW are
considered by EPA to be the critical RI/FS activities
that are required by the NCP. PRPs should present
detailed justifications for any proposed modifications
and amendments to the activities set forth in the
SOW. EPA will review all proposed modifications and
approve or disapprove their inclusion in the SOW
based on available information, EPA policy and
guidance, overall program objectives, and the
requirements of the NCP and CERCLA. EPA will not
allow modifications that, in the judgment of the
Agency, will lead to an unsatisfactory RI/FS or
inconsistencies with the NCP.
Review of the RI/FS Project Plans
RI/FS project plans include those plans developed for
the RI/FS. At a minimum the project plans should
include a Work Plan, a Sampling and Analysis Plan, a
Health and Safety Plan, and a Community Relations
Plan. The Community Relations Plan is developed by
EPA and should include a description of the PRPs'
role in community relations activities, if any. EPA
review and approval of the work plan and sampling
and analysis plan will usually be required before PRPs
can begin site activities. An example when limited
project activities may be initiated prior to approval of
the project plans would be if additional information is
required to complete the Sampling and Analysis Plan.
Additionally, conditional approvals to the Work Plan
and Sampling and Analysis Plan may be provided in
order to initiate field activities in a more timely
manner. It should be noted that EPA does not
"approve" the PRPs' Health and Safety Plan but
rather, it is reviewed to ensure the protection of public
health and the environment. The PRPs may be
required to amend the plan if EPA determines that it
does not adequately provide for such protection.
• Contents of the Work Plan
The Work Plan expands the tasks of the SOW, and
the responsibilities specified in the Agreement, by
presenting the rationale and methodology (including
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detailed procedures) for conducting the RI/FS.
Typically the Work Plan is developed after the draft
Order and then incorporated into the Agreement. In
some cases however, it may be appropriate for EPA
to develop the Work Plan prior to actual negotiation
with the PRPs and attach the plan to the draft
Agreement. The PRP RI/FS Work Plan must be
consistent with current EPA guidance. Guidance on
developing acceptable Work Plans is available in the
RI/FS Guidance. Additional guidance will be
forthcoming in the proposed NCP. Once the Work
Plan is approved by EPA, it becomes a public
document and by the terms of the Agreement, should
be incorporated by reference into that document. The
Work Plan should, at a minimum, contain the
following elements.
Inroduction/Background Statement - PRPs should
provide an introductory or background statement
describing their understanding of the work to be
performed at the site. This should include
historical site information and should highlight
present site conditions.
Objectives - A statement of what is to be
accomplished and how the information will be
utilized.
Scope - A detailed description of the work to be
performed including a definition of work limits.
Management Plan - A description of the project
management showing personnel with authority and
responsibility for the appropriate aspects of the
project and specific tasks to be performed. A
single person should be identified as having
overall responsibility for the project.
Work Schedule - A statement outlining the
schedule for each of the required activities. This
could be presented in the form of a Gantt or
milestone chart. The schedule in the Work Plan
must match that in the draft Order.
Deliverables - A description of the work products
that will be submitted and their schedule for
delivery. The schedule should include specific
dates, if possible. Otherwise, the schedule should
be in terms of the number of days/week after
approval of the work plan.
• Contents of the Sampling and Analysis Plan.
A Sampling and Analysis Plan (SAP) must be
submitted by the PRPs before initiation of relevant
field activities. This plan contains two separate
elements: a Field Sampling Plan and a Quality
Assurance Project Plan. These documents were
previously submitted as separate deliverables, but are
now combined into one document. Though the SAP
s typically implemented by PRP contractors, it is the
responsibility of the PRPs to ensure that the goals
and standards of the plan are met. (Verification that
the goals and standards of the SAP are met will also
be part of EPA's oversight responsibilities.) The SAP
should contain the following elements:
Field Sampling Plan - The Field Sampling Plan
includes a detailed description of all RI/FS
sampling and analytical activities that will be
performed. These activities should be consistent
with the NCP and relevant CERCLA guidance.
Further guidance on developing Field Sampling
Plans is presented in the RI/FS Guidance.
Quality Assurance Project Plan - The SAP must
include a detailed description of quality
assurance/quality control (QAQC) procedures to
be employed during the RI/FS. This section is
intended to ensure that the RI/FS is based on the
correct level or extent of sampling and analysis
required to produce sufficient data for evaluating
remedial alternatives for a specific site. A second
objective is to ensure the quality of the data
collected during the RI/FS. Guidance on
appropriate QAQC procedures may be found in
the RI/FS Guidance as well as "Data Quality
Objectives for the RI/FS Process" (March 1987 -
OSWER Directive No. 9355.0-7B).
If the SAP modifies any procedures established in
relevant guidance, it must provide an explanation and
justification for the change.
• Other Project Plans
Other project plans that are likely to be required in the
RI/FS process include the Health and Safety Plan and
the Community Relations Plan.
Health and Safety Plan - PRPs should include a
Health and Safety Plan either as part of the Work
Plan or as a separate document. The Health and
Safety Plan should address the measures taken
by the PRPs to ensure that all activities will be
conducted in an environmentally safe manner for
the workers and the surrounding community. EPA
reviews the Health and Safety Plan to ensure
protection of public health and the environment.
EPA does not, however, "approve" this plan.
Guidance on the appropriate contents of a Health
and Safety Plan may be found in the RI/FS
Guidance. In addition, Health and Safety
requirements are found in "OSHA Safety and
Health Standards: Hazardous Waste Operations
and Emergency Response" (40 CFR Part
1910.120).
Community Relations Plan - EPA must prepare a
Community Relations Plan for each NPL site. The
extent of PRP involvement in community relations
activities should be detailed in this plan. Additional
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information on Community Relations activities is
contained below.
• Review and Approval
PRPs must submit all of the required RI/FS project
plans (with the exception of the Community Relations
Plan which is developed by EPA) to EPA for review,
and in the case of the Work Plan and SAP, approval.
EPA will review the plans for their technical validity
and consistency with the NCP and relevant EPA
guidance. Typically, the Agency must review and
approve these plans before PRPs can begin any site
activities. Any disagreements that arise between EPA
and PRPs over the contents of the plans should be
resolved according to the procedures set forth in the
dispute resolution section of the relevant EPA/PRP
Agreement.
Community Relations
EPA is responsible for developing and implementing
an effective community relations program, regardless
of whether RI/FS activities are Fund-financed or
conducted by PRPs. At State-lead enforcement
sites, funded by EPA under Superfund Memoranda of
Agreement (see the "Draft Guidance on Preparation
of a Superfund Memorandum of Agreement (October
5, 1987 - OSWER Directive No. 9375.0-01)), the
State has the responsibility for development and
implementation of a community relations program.
PRPs may, under certain circumstances, assist EPA
or the State in implementing the community relations
activities. For example, PRPs may wish to participate
in community meetings and in preparing fact sheets.
PRP participation in community relations activities
would, however, be at the discretion of the Regional
Office, or the State, and would require oversight by
the lead-agency. EPA will not under any
circumstances negotiate press releases with PRPs.
EPA designs and implements community relations
activities according to CERCLA and the NCP. A
Community Relations Plan must be developed by
EPA for all NPL sites as described by the EPA
guidance, "Community Relations in Superfund: A
Handbook" (U.S. EPA, 1988 - OSWER Directive No.
9230.0-03). The Community Relations Plan must be
independent of negotiations with PRPs. Guidance for
conducting community relations activities at
Superfund enforcement sites is specifically addressed
by Chapter VI of the Handbook and the EPA memo
entitled "Community Relations Activities at Superfund
Enforcement Sites—Interim Guidance" (November
1988 - OSWER Directive No. 9230.0-38). In some
instances the decision regarding PRP participation in
community relations activities will be made after the
Community Relations Plan has been developed. As a
result, the plan will need to be modified by EPA to
reflect Agency and PRP roles and responsibilities.
EPA, or the State, will provide the Community
Relations Plan to all interested parties at the same
time. In general, if the case has not been referred to
the Department of Justice (DOJ) for litigation,
community relations activities during the RI/FS should
be the same for Fund- and PRP-lead sites. If the
case has been (or may potentially be) referred to
DOJ for litigation, constraints will probably be placed
on the scope of activities. The EPA Community
Relations Plan may be modified after consultation with
the technical enforcement staff, the Regional Counsel
and other negotiation team members, including, if the
case is referred, the lead DOJ or Assistant United
States Attorneys (i.e., the litigation team). This
technical and legal staff must be consulted prior to
any public meetings or dissemination of fact sheets or
other information; approval must be obtained prior to
releases of information and discussions of technical
information in advance. PRP participation in
implementing community relations activities will be
subject to EPA (or State) approval in administrative
settlements and EPA/DOJ in civil actions. Key
activities specific to community relations programs for
enforcement sites include the following:
• Public Review of Work Plans for Administrative
Orders
The PRP Work Plan, as approved by EPA, is
incorporated into the Administrative Order (or
Consent Decree). Once the Agreement is signed, it
becomes a public document. Although there is no
requirement for public comment on an Administrative
Order, Regional staff are encouraged to announce,
after the Order is final, that the PRP is conducting the
RI/FS. Publication of notice and a corresponding 30-
day comment period is required however, for Consent
Decrees.
• Availability of RI/FS Information from the PRPs
PRPs, in agreeing to conduct the RI/FS, must also
agree to provide all information necessary for EPA to
implement a Community Relations Plan. The
Agreement should identify the types of information
that PRPs will provide, and contain conditions
concerning the provision of this information. EPA
should provide the PRPs with the content of the plan
so that the PRPs can fully anticipate the type of
information that will be made public. All information
submitted by PRPs will be subject to public inspection
(i.e., available through Freedom of Information Act
requests, public dockets, or the administrative record)
unless the information meets an exemption. An
example would be if the information is deemed either
as enforcement sensitive by EPA, or business
confidential by EPA (based on the PRPs'
representations), in conformance with 40 CFR Part 2.
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Development of the ATSDR Health Assessment
Section 104(j)(6) of CERCLA requires the Agency for
Toxic Substances and Disease Registry (ATSDR) to
perform health assessments at all NPL facilities
according to a specified schedule. The purpose of the
health assessment is to assist in determining whether
any current or potential threat to human health exists
and to determine whether additional information on
human exposure and associated health risks is
needed.
The EPA remedial project manager (RPM) should
coordinate with the appropriate ATSDR Regional
representative for initiation of the health assessment.
In general, the health assessment should be initiated
at the start of the RI/FS. The ATSDR Regional
representative will provide information on data needs
specific to performing a health assessment to ensure
that all necessary data will be collected during the Rl.
The RPM and the ATSDR Regional representative
should also coordinate the transmission and review of
pertinent documents dealing with the extent and
nature of site contamination (i.e., applicable technical
memoranda and the draft Rl). As ATSDR has no
provisions for withholding documents, if requested by
the public, the RPM must discuss enforcement
sensitive documents and drafts with the ATSDR
Regional representative rather than providing copies
to them. This will ensure EPA's enforcement
confidentiality. Further guidance on coordination of
RI/FS activities with ATSDR can be found in the
document entitled "Guidance for Coordinating ATSDR
Health Assessment Activities with the Superfund
Remedial Process" (March 1987 - OSWER Directive
No. 9285.4-02).
Identification of Oversight Activities
EPA will review RI/FS plans and reports as well as
provide field oversight of PRP activities during the
RI/FS. To ensure that adequate resources are
committed and that appropriate activities are
performed, EPA should develop an oversight plan that
defines the oversight activities that must be
performed including EPA responsibilities, RI/FS
products to be reviewed, and site activities that EPA
will oversee. In planning for oversight, EPA should
consider such factors as who will be performing
oversight and the schedule of activities that will be
monitored. A tracking system for recording PRP
milestones should be developed. This system should
also track activities performed by oversight personnel
and other appropriate cost items such as travel
expenses.
Identification and Procurement of EPA Assistance
In accordance with Section 104(a)(1) EPA must
arrange for a qualified party to assist in oversight of
the RI/FS. The following section provides guidance for
identifying and procuring such assistance for EPA
activities.
• Assistance for EPA Activities
As specified in Section 104(a)(l), EPA is required to
contract with or arrange for a qualified person to
assist in oversight of the RI/FS. Qualified individuals
are those groups with the professional qualifications,
expertise, and experience necessary to provide
assurance that the Agency is conducting appropriate
oversight of PRP RI/FS activities.
Normally, EPA will obtain oversight assistance either
through the Technical Enforcement Support (TES)
contract, the Alternative Remedial Contracts Strategy
Contract (ARCS), or occasionally through the
Remedial Action (REM) contracts. In some cases
oversight assistance may be provided by States
through the use of Cooperative Agreements.
Oversight assistance may also be obtained through
the U.S. Army Corps of Engineers or other
governmental agencies; interagency Agreements
should be utilized to obtain such assistance.
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Attachment III
Review and Oversight of the RI/FS
Review of Plans, Reports, and Records
EPA will review all RI/FS products which are
submitted to the Agency as specified in the Work
Plan or Administrative Order. PRPs should ensure
that all plans, reports, and records are
comprehensive, accurate, and consistent in content
and format with the NCP and relevant EPA guidance.
After this review process, EPA will either approve or
disapprove the product. If the product is found to be
unsatisfactory, EPA will notify the PRPs of the
discrepancies or deficiencies and will require
corrections within a specified time period.
• Project Plans
EPA will review all project plans that are submitted as
deliverables in fulfillment of the Agreement. These
plans include the Work Plan, the Sampling and
Analysis Plan (including both the Field Sampling Plan
and the Quality Assurance Project Plan), and the
Health and Safety Plan. If the initial submittals are not
sufficient in content or scope, the RPM will request
that the PRPs submit revised document(s) for review.
EPA does not "approve" the PRP's Health and
Safety Plan but rather, it is reviewed to ensure the
protection of public health and the environment. The
PRP's Work Plan and Sampling and Analysis Plan, on
the other hand, must be reviewed and approved prior
to the initiation of field activities. Conditional approval
to these plans may be provided in order to initiate
field activities in a more timely manner.
The PRPs may be required to develop additional
Work Plans or modify the initial Work Plan contained
in or created pursuant to the Agreement. These
changes may result from the need to: (1) re-
evaluate the RI/FS activities due either to changes in
or unexpected site conditions; (2) expand the initial
Work Plan when additional detail is necessary; or (3)
modify or add products to the Work Plan based on
new information (e.g., a new population at risk). EPA
will review and approve all Work Plans and/or
modifications to Work Plans once they are submitted
for review.
• Reports
PRPs will, at a minimum, submit monthly progress
reports, technical memorandums or reports, and the
draft and final RI/FS reports as required in the
Agreement. To assist in the development of the RI/FS
and review of documents, additional deliverables may
be specified by the Region and included in the
Agreement. These reports and deliverables will be
reviewed by EPA to ensure that the activities
specified in the Order and approved Work Plan are
being properly implemented. These reports will
generally be submitted according to the conditions
and schedule set forth in the Agreement. Elements of
the PRP reports are discussed below.
Monthly Progress Reports - The review of monthly
progress reports is an important activity performed
during oversight. These reports should provide
sufficient detail to allow EPA to evaluate the past and
projected progress of the RI/FS. PRPs should submit
these written progress reports to the RPM. The report
should describe the actions and decisions taken
during the previous month and activities scheduled
during the upcoming reporting period. In addition,
technical data generated during the month (i.e.,
analytical results) should be appended to the report.
Progress reports should also include a detailed
statement of the manner and extent to which the
procedures and dates set forth in the Agreement/
Work Plan are being met. Generally, EPA will
determine the adequacy of the performance of the
RI/FS by reviewing the following subjects discussed in
progress reports:
• Technical Summary of Work
The monthly report will describe the activities and
accomplishments performed to date. This will
generally include a description of all field work
completed, such as sampling events and
installation of wells; a discussion of analytical
results received; a discussion of data review
activities; and a discussion of the development,
screening, and detailed analysis of alternatives.
The report will also describe the activities to be
performed during the upcoming month.
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Schedule
- Unsatisfactory QA/QC performance;
EPA will oversee PRP compliance with respect to
those schedules specified in the Order. Delays,
with the exception of those specified under the
Force Majeure clause of the Agreement, may
result in penalties, if warranted. The RPM should
be immediately notified if PRPs cannot perform
required activities or cannot provide the required
deliverables in accordance with the schedule
specified in the Work Plan. In addition, PRPs
should notify the RPM when circumstances may
delay the completion of any phase of the work or
when circumstances may delay access to the
site. PRPs should also provide to the RPM, in
writing, the reasons for, and the anticipated
duration of, such delays. Any measures taken or
to be taken by the PRPs to prevent or minimize
the delay should be described including the
timetables for implementing such measures.
• Budget
The relationship of budgets to expenditures
should be tracked where the RI/FS is funded with
a financial mechanism established by the PRPs. If
site activities require more funds than originally
estimated, EPA must be assured that the PRPs
are financially able to undertake additional
expenditures. While EPA does not have the
authority to review or approve a PRP budget,
evaluating costs during the course of the RI/FS
allows EPA to effectively monitor activity to
ensure timely completion of RI/FS activities. If the
PRPs run over budget, EPA must be assured that
they can continue the RI/FS activities as
scheduled. Therefore, if specified in the
Agreement, PRPs should submit budget
expenditures and cost overrun information to
EPA. Budget reports need not present dollar
amounts, but should indicate the relationship
between remaining available funds and the
estimate of the costs of remaining activities.
Problems
Any problems that the PRPs encounter which
could affect the satisfactory performance of the
RI/FS should be brought to the immediate
attention of EPA. Such problems may or may not
be a force majeure event, or caused by a force
majeure event. EPA will review problems and
advise the PRPs accordingly. Problems which
may arise include, but are not limited to:
Delays in mobilization or access to necessary
equipment;
- Unanticipated laboratory/analytical time
requirements:
Requirements for additional or more complex
sampling;
Prolonged unsatisfactory weather conditions;
Unanticipated site conditions; and
- Unexpected, complex community relations
activities.
Other Reports - All other reports, such as
technical reports and draft and final RI/FS reports,
should be submitted to EPA according to the
schedule contained in the Order or the approved
Work Plan. EPA will review and approve these
reports as they are submitted. Suggested formats
for the RI/FS reports are presented in the RI/FS
Guidance.
• Records
PRPs should preserve all records, documents, and
information of any kind relating to the performance of
work at the site for a minimum of 6 years after
completion of the work and termination of the
Administrative Order. After the 6-year period, the
PRPs should offer the records to EPA before their
destruction.
Document control should be a key element of all
recordkeeping. The following activities require careful
recordkeeping and will be subject to EPA oversight:
Administration - PRP administrative activities
should be accurately documented and recorded.
Necessary precautions to prevent errors or the
loss or misinterpretation of data should be taken.
At a minimum, the following administrative actions
should be documented and recorded:
Contractor work plans, contracts, and change
orders;
- Personnel changes;
- Communications between and among PRPs,
the State, and EPA officials regarding
technical aspects of the RI/FS;
- Permit application and award (if applicable);
and
- Cost overruns.
Technical Analysis - Samples and data should be
handled according to procedures set forth in the
Sampling and Analysis Plan. Documentation
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establishing adherence to these procedures
should include:
- Sample labels:
- Shipping forms;
- Chain-of-custody forms; and
- Field log books.
All analytical data in the RI/FS process should be
managed as set forth in the Sampling and
Analysis Plan. Such analytical data may be the
product of:
- Contractor laboratories;
- Environmental and public health studies; and
- Reliability, performance, and implementability
studies of remedial alternatives.
Decision Making - Actions or communications
among PRPs that involve decisions affecting
technical aspects of the RI/FS should be
documented. Such actions and communications
include those of the project manager (or other
PRP management entity), steering committees, or
contractors.
• Administrative Record Requirements
Section 113(k) of CERCLA requires that the Agency
establish an administrative record upon which the
selection of a response action is based. A suggested
list of documents which are most likely to be included
in any adequate administrative record is provided in
the memorandum entitled "Draft Interim Guidance on
Administrative Records for Selection of CERCLA
Response Actions" (June 23, 1988 - OSWER
Directive No. 9833.3A). More detailed guidance will
be forthcoming, including guidance provided in the
revisions to the NCP. There are, however, certain
details associated with compiling and maintaining an
administrative record that are unique to PRP RI/FS
activities.
EPA is responsible for compiling and maintaining the
administrative record, and generating and updating an
index. If EPA and the PRPs mutually agree, the PRPs
may be allowed to house and maintain the
administrative record file at or near the site; they may
not, however, be responsible for the actual
compilation of the record. Housing and maintaining
the administrative record would include setting up a
publicly accessible area at or near the site and
ensuring that documents remain and are updated as
necessary. EPA must always be responsible for
deciding whether documents are included in the
administrative record; transmitting records to the
PRPs; and maintaining the index to the repository.
The information which may comprise the
administrative record must be available to the public
from the time an RI/FS Work Plan is approved by
EPA. Once the Work Plan has been approved the
PRPs must transmit to EPA, at reasonable, regular
intervals, all of the information that is generated
during the RI/FS that is related to selection of the
remedy. The required documentation should be
specified in the Administrative Order. The Agreement
should also specify those documents generated prior
to the RI/FS that must be obtained from the PRPs for
inclusion in the record file. This may include any
previous studies conducted under State or local
authorities, management documents held by the
PRPs such as hazardous waste shipping manifests,
and other information about site characteristics or
conditions not contained in any of the above
documents.
Field Activities
• Field Inspections
Field inspections are an important oversight
mechanism for determining the adequacy of the work
performed. EPA will therefore conduct field
inspections as part of its oversight responsibilities.
The oversight inspections should be performed in a
way that minimizes interference with PRP site
activities or undue complication of field activities. EPA
will take corrective steps, as described in Section VII
and Attachment IV of this appendix, if unsatisfactory
performance or other deficiencies are identified.
Several field-related tasks may be performed during
oversight inspections. These tasks include:
On-site presence/inspection - As specified in
Section 104(e)(3), EPA reserves the right to
conduct on-site inspections at any reasonable
time. EPA will therefore establish an on-site
presence to assure itself of the quality of work
being conducted by PRPs. At a minimum, field
oversight will be conducted during critical times,
such as the installation of monitoring wells and
during sampling events. EPA will focus on
whether the PRPs adhere to procedures specified
in the SOW and Work Plan(s), especially those
concerning QA/QC procedures. Further guidance
regarding site characterization activities is
presented in the RI/FS Guidance, the
"Compendium of Superfund Field Operations
Methods" (August 1987 - OSWER Directive No.
9355.0-l 41), the "RCRA Ground Water
Technical Enforcement Guidance Document"
(September 1986 - OSWER Directive No.
9950.1) the NEIC Manual for Groundwaterl
Subsurface Investigations at Hazardous Waste
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Sites (U.S. EPA, 1981c), and OWPE's
forthcoming "Guidance on Oversight of Potentially
Responsible Party Remedial Investigations and
Feasibility Studies."
Collection and analysis of samples - EPA may
collect a number of QA/QC samples including
blank, duplicate, and split samples. The results of
these sample analyses will be compared to the
results of PRP analyses. This comparison will
enable EPA to identify potential quality control
problems and therefore help to evaluate the
quality of the PRP investigation.
Environmental Monitoring - EPA may supplement
any PRP environmental monitoring activity. Such
supplemental monitoring may include air or water
studies to determine additional migration of
sudden releases that may have occurred as a
result of site activities.
• QA/QC Audits
EPA may either conduct, or require the PRPs to
conduct (if specified in the Agreement), laboratory
audits to ensure compliance with proper QA/QC and
analytical procedures, as specified in the Sampling
and Analysis Plan. These audits will involve on-site
inspections of laboratories used by PRPs and
analyses of selected QA/QC samples. All procedures
must be in accordance with those outlined in The
User's Guide to the Contract Laboratory Program,
(U.S. EPA, 1986) or otherwise specified in the
Sampling and Analysis Plan.
• Chain-of-Custody
Chain-of-custody procedures will be evaluated by
EPA. This evaluation will focus on determining if the
PRPs and their contractors adhere to the procedures
set forth in the Sampling and Analysis Plan. Proper
chain-of-custody procedures are described in the
National Enforcement Investigation Center (NEIC)
Policies and Procedures Manual, (U.S. EPA, 1981 b).
Evaluation of chain-of-custody procedures will
occur during laboratory audits as well as during on-
site inspections of sampling activities.
Meetings
Meetings between EPA, the State, and PRPs should
be held on a regular basis (as specified in the
Agreement) and at critical times during the RI/FS.
Such critical times may at a minimum include when
the SOW and the Work Plan are reviewed, the Rl is
in progress and completed, remedial alternatives are
developed and screened, detailed analysis of the
alternatives is performed, and the draft and final RI/FS
reports are submitted. These meetings will discuss
overall progress, discrepancies in the work
performed, problems encountered in the performance
of RI/FS activities and their resolution, community
relations, and other related issues and concerns.
While meetings may be initiated by either the PRPs
or EPA at any time, they will generally be conducted
at the stages of the RI/FS listed below.
• Initiation of Activities
EPA, the State, and the PRPs may meet at various
times before field activities begin to discuss the initial
planning of the RI/FS. Meetings may be arranged to
discuss, review, and approve the SOW; to develop
the EPA/PRP Agreement; and to develop, review, and
approve the Work Plan.
• Progress
EPA may request meetings to discuss the progress of
the RI/FS. These meetings should be held at least
quarterly and will focus on the items submitted in the
monthly progress reports and the findings from EPA
oversight activities. Any problems or deficiencies in
the work will be identified and corrective measures
will be requested (see Section VIII and Attachment IV
of this appendix).
• Closeout
EPA may request a closeout meeting upon
completion of the RI/FS. This meeting will focus on
the review and approval of the final RI/FS report,
termination of the RI/FS Agreement, and any final
on-site activities which the PRPs may be required to
perform. These activities may include maintaining the
site and ensuring that fences and warning signs are
properly installed. The transition to remedial design
and remedial action will also be discussed during this
meeting.
Special Studies
EPA may determine that special studies related to the
PRP RI/FS are required. These studies can be
conducted to verify the progress and results of RI/FS
activities or to address a specific complex or
controversial issue. Normally, special studies are
performed by the PRPs; however, there may be
cases in which EPA will want to conduct the
independent studies. The +PRPs should be informed
of any such studies and given adequate time to
provide necessary coordination of site personnel and
resources. If not provided for in the Agreement,
modifications to the Work Plan may be required.
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Attachment IV
Control of Activities
Identification of Deficiencies
Oversight activities may identify unsatisfactory or
deficient PRP performance. The determination of
such performance may be based upon findings such
as:
• Work products are inconsistent with the SOW or
Work Plan;
• Technical deficiencies exist in submittals or other
RI/FS products;
• Unreasonable delays occur while performing
RI/FS activities; and
• Procedures are inconsistent with the NCP.
Corrective Measures
The need to perform corrective measures may arise
in the event of deficiencies in reports or other work
products, or unsatisfactory performance of field or
laboratory activities. When deficiencies are identified
corrective measures may be sought by: (1) notifying
the PRPs; (2) describing the nature of the deficiency;
and (3) either requesting the PRPs to take whatever
actions they regard as appropriate or setting forth
appropriate corrective measures. The following
subsections describe this process for each of the two
general types of activities that may require corrective
measures.
• Corrective Measures Regarding Work Products
Agency review and approval procedures for work
products generally allow three types of responses: (1)
approval; (2) approval with modifications; and (3)
non-approval. Non-approval of a work product
(including project plans) immediately constitutes a
notice of deficiency. EPA will immediately notify the
PRPs if any work product is not approved and will
explain the reason for such a finding.
Approval with modifications will not lead to a notice of
deficiency if the modifications are made by the PRPs
without delay. If the PRPs significantly delay in
responding to the modifications, the RPM would issue
a notice of deficiency to the PRP project manager
detailing the following elements:
A description of the deficiency or a statement
describing in what manner the work product
was found to be deficient or unsatisfactory;
- Modifications that the PRPs should make in
the work product to obtain approval;
- A request that the PRPs prepare a plan, if
necessary, or otherwise identify actions that
will lead to an acceptable work product;
- A schedule for submission of the corrected
work product;
- An invitation to the PRPs to discuss the
matter in a conference; and
A statement of the possibility of EPA takeover
at the PRPs' expense, EPA enforcement, or
penalties (as appropriate).
• Corrective Measures Regarding Field Activities
When the lead agency discovers that the PRPs (or
their contractors) are performing the RI/FS field work
in a manner that is inconsistent with the Work Plan,
the PRPs should be notified of the finding and asked
to voluntarily take appropriate corrective measures.
The request is generally made at a progress meeting,
or, if immediate action is required, at a special
meeting held specifically to discuss the problem. If
corrective measures are not voluntarily taken, the
RPM should, in conjunction with appropriate Regional
Counsel, issue a notice of deficiency containing the
following elements:
A description of the deficiency;
A request for an explanation of the failure to
perform satisfactorily and a plan for
addressing the necessary corrective
measures;
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A statement that failure to present an
explanation may be taken as an admission
that there is no valid explanation;
An invitation to discuss the matter in a
conference (where appropriate);
A statement that stipulates penalties may
accrue or are accruing, project termination
may occur, and/or civil action may be initiated
if appropriate actions are not taken to correct
the deficiency; and
A description of the potential liabilities
incurred in the event that appropriate actions
are not taken.
forth the terms and conditions for conducting the
RI/FS. An element of this Agreement is a statement
of the specific steps to be taken if a dispute arises
between EPA (or its representatives) and the PRPs.
These steps should be well defined and agreed upon
by all signatories to the Agreement.
A dispute with respect to the Order is followed by a
specific period of discussion with the PRPs. After the
discussion period, EPA issues a final decision which
becomes incorporated into the Agreement.
Administrative Orders should clarify that with respect
to all submittals and work performed, EPA will be the
final arbiter. The court, on the other hand, is the final
arbiter for Consent Decrees.
Modifications to the Work Plan/Additional Work
Under the Administrative Order (or Consent Decree),
PRPs agree to complete the RI/FS, including the
tasks required under either the original Work Plan or
a subsequent or modified Work Plan. This may
include determinations and evaluations of conditions
that are unknown at the time of execution of the
Agreement. Modifications to the original RI/FS Work
Plan are frequently required as field work progresses.
Work not explicitly covered in the Work Plan is often
required and therefore provided for in the Order. This
work is usually identified during the Rl and is driven
by the need for further information in a specific area.
In general, the Agreement should provide for fine-
tuning of the Rl, or the investigation of an area
previously unidentified. As it becomes clear what
additional work is necessary, EPA will notify the PRPs
of the work to be performed and determine a
schedule for completion of the work.
EPA must ensure that clauses for modifications to the
Work Plan are included in the Agreement so that the
PRPs will carry out the modifications as the need for
them is identified. To facilitate negotiation on these
points, EPA may consider one or more of the
following provisions in the Agreement for addressing
such situations:
- Defining the limits of additional work
requirements;
- Specifying the dispute resolution process for
modified Work Plans and additional work
requirements;
- Defining the applicability of stipulated
penalties to any additional work which the
PRPs agree to undertake.
Dispute Resolution
As discussed elsewhere in this guidance, the RI/FS
Order developed between EPA and the PRPs sets
Penalties
As an incentive for PRPs to properly conduct the
RI/FS and correct any deficiencies discovered during
the conduct of the Agreement, EPA should include
stipulated penalties. Section 121 provides up to
$25,000 per day in stipulated penalties for violations
of a Consent Decree while Section 122 allows EPA to
seek or impose civil penalties for violations of
Administrative Orders.3 Penalties should begin to
accrue on the first day of the deficiency and continue
to be assessed until the deficiency is corrected. The
type of violation (i.e., reporting requirements vs.
implementation of construction requirements), as well
as the amounts, should be specified as stipulated
penalties in the Agreement to avoid negotiations on
this point which may delay the correction. The
amounts should be set pursuant to the criteria of
Section 109 and as such must take into account the
nature, circumstances, extent, and gravity of the
violations as well as the PRPs' ability to pay, prior
history of violations, degree of culpability, and the
economic benefit resulting from noncompliance.
Additional information on stipulated penalties can be
found in OECM's "Guidance on the Use of Stipulated
Penalties in Hazardous Waste Consent Decrees"
(September 27, 1987).
Project Takeover
Generally, EPA will consult with PRPs to discuss
deficiencies and corrective measures. If these
discussions fail, EPA has two options: (1) pursue
legal action to force the PRPs to continue the work;
or (2) take over the RI/FS. If taking legal action will
not significantly delay implementation of necessary
remedial or removal actions, EPA may commence
civil action against the noncomplying PRP to enforce
the Administrative Order. Under a Consent Decree,
the matter would be presented to the court in which
3 In order to provide for stipulated penalties in an Administrative
Order the parties must voluntarily include them in the terms of
the Agreement.
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the Decree was filed to enforce the provisions of the
Decree.
If a delay in RI/FS activities endangers public health
and/or the environment or will significantly delay
implementation of necessary remedial actions, EPA
should move to replace the PRP activities with
Fund-financed actions. The RPM will take the
appropriate steps to assume responsibility for the
RI/FS, including issuing a stop-work order to the
PRPs and notifying the EPA remedial contractors. In
issuing stop work orders, RPMs should be aware that
Fund resources may not be automatically available.
But, in the case of PRP actions which threaten
human health or the environment, there may be no
other course of action. Once this stop work order is
issued, a fund-financed RI/FS will be undertaken
consistent with EPA funding procedures.
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Appendix B
Elements of RI/FS Project Plans
I. Elements of a Work Plan1
Introduction - A general explanation of the reasons
for the RI/FS and the expected results or goals of the
RI/FS process are presented.
Site Background and Physical Setting - The current
understanding of the physical setting of the site, the
site history, and the existing information on the
condition of the site are described. (See Section
2.2.2.1.)
Initial Evaluation - The conceptual site model
developed during scoping is presented, describing the
potential migration and exposure pathways and the
preliminary assessment of human health and
environmental impacts. (See Section 2.2.2.2).
Work Plan Rationale - Data requirements for both the
risk assessment and the alternatives evaluation
identified during the formulation of the DQOs are
documented, and the work plan approach is
presented to illustrate how the activities will satisfy
data needs.
RI/FS Tasks - The tasks to be performed during the
RI/FS are presented. This description incorporates Rl
site characterization tasks identified in the QAPP and
the FSP, the data evaluation methods identified
during scoping (see Section 2.2.9), and the
preliminary determination of tasks to be conducted
after site characterization (see Section 2.2.7 of this
guidance).
II. Standard Federal-Lead RI/FS Work
Plan Tasks
Task 1. Project Planning (Project Scoping)
This task includes efforts related to initiating a project
after the SOW is issued. The project planning task is
defined as complete when the work plan and
supplemental plans are approved (in whole or in part).
The following typical elements are included in this
task:
• Work plan memorandum
• Kickoff meeting (RI/FS brainstorming meeting)
• Site visit/meeting
• Obtaining easements/permits/site access
• Site reconnaissance and limited field investigation
• Site surveyVtopographic map/review of existing
aerial photographs
• Collection and evaluation of existing data
• Development of conceptual site model
• Identification of data needs and DQOs
• Identification of preliminary remedial action
objectives and potential remedial alternatives
• Identification of treatability studies that may be
necessary
• Preliminary identification of ARARs
• Preparation of plans (e.g., work plan, health and
safety plan, QAPP, FSP)
• Initiation of subcontract procurement
• Initiation of coordination with analytical
laboratories (CLP and non-CLP)
• Task management and quality control
Task 2. Community Relations
This task incorporates all efforts related to the
preparation and implementation of the community
relations plan for the site and is initiated during the
scoping process. It includes time expended by both
technical and community relations personnel. This
task ends when community relations work under Task
'These elements are required in a work plan but do not
necessarily represent the organization of a work plan.
2 A site survey may be conducted during project planning or
may occur during the field investigation task but should not
occur in both.
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12 is completed, but the task does not include work
on the responsiveness summary in the ROD (see
Task 12). The following are typical elements included
in this task:
• Conducting community interviews
• Preparing a community relations plan
• Preparing fact sheets
• Providing public meeting support
• Providing technical support for community
relations
• Implementing community relations
• Managing tasks and conducting quality control
Task 3. Field Investigation
This task involves efforts related to fieldwork in
conducting the Rl. It includes the procurement of
subcontractors related to field efforts. The task begins
when any element, as outlined in the work plan, is
approved (in whole or in part) and fieldwork is
authorized."Field investigation is defined as complete
when the contractor and subcontractors are
demobilized from the field. The following activities are
typically included in this task:
• Procurement of subcontracts
• Mobilization
• Media sampling
• Source testing
• Geology/hydrogeological investigations
• Geophysics
• Site survey/topographic mapping (if not performed
in project planning task)
• Field screening/analyses
• Procurement of subcontractors
• Rl waste disposal
• Task management and quality control
Task 4. Sample Analysis/ Validation
This task includes efforts relating to the analysis and
validation of samples after they leave the field.
Separate monitoring of close support laboratories may
be required. Any efforts associated with laboratory
procurement are also included in this task. The task
ends on the date that data validation is complete. The
following typical activities are usually included in this
task:
• Sample management
• Non-CLP analyses
• Use of mobile laboratories
• Data validation
• Testing of physical parameters
• Task management and quality control
Task 5. Data Evaluation
This task includes efforts related to the analysis of
data once it has been verified that the data are of
acceptable accuracy and precision. The task begins
on the date that the first set of validated data is
received by the contractor project team and ends
during preparation of the Rl report when it is deemed
that no additional data are required. The following are
typical activities:
• Data evaluation
• Data reduction and tabulation
• Environmental fate and transport model-
ing/evaluation
• Task management and quality control
Task 6. Assessment of Risks
This task includes efforts related to conducting the
baseline risk assessment. The task will include work
to assess the potential human health and
environmental risks associated with the site. Work will
begin during the Rl and is completed once the
baseline risk assessment is completed ."The following
are typical activities:
• Identification of contaminants of concern (or
indicator chemicals)
• Exposure assessment (including any modeling
performed specifically for this function)
• Toxicity assessment
• Risk characterization
• Task management and quality control
3 Note that limited fieldwork during project scoping may be
authorized as part of the work assignment to prepare the RI/FS
work plan.
4 Limited efforts to assess potential human health and
environmental risks are, to some extent, initiated during
scoping when the conceptual site model is being developed.
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Task 7. Treatability Study/Pilot Testing
This task includes efforts to prepare and conduct
pilot, bench, and treatability studies. This task begins
with the development of work plans for conducting
the tests and is complete once the report has been
completed. The following are typical activities:
• Work plan preparation or work plan amendment
• Test facility and equipment procurement
• Vendor and analytical service procurement
• Equipment operation and testing
• Sample analysis and validation
• Evaluation of results
• Report preparation
• Task management and quality control
Task 8. Remedial Investigation Reports
This task covers all efforts related to the preparation
of the findings once the data have been evaluated
under Tasks 5 and 6. The task covers all draft and
final Rl reports as well as task management and
quality control. The task ends when the last Rl
document is submitted by the contractor to EPA. The
following are typical activities:
• Preparation of a preliminary site characterization
summary (see Section 3.7.2 of this guidance)
• Data presentation (formatting tables, preparing
graphics)
• Writing the report
• Reviewing and providing QC efforts
• Printing and distributing the report
• Holding review meetings
• Revising the report on the basis of agency
comments
• Providing task management and control
Task 9. Remedial Alternatives
Development/Screening
This task includes efforts to select the alternatives to
undergo full evaluation. The task is initiated once
sufficient data are available to develop general
response actions and begin the initial evaluation of
potential technologies. This task is defined as
complete when a final set of alternatives is chosen for
detailed evaluation. The following are typical activities:
• Identifying/screening potential technologies
• Assembling potential alternatives
• Identifying action-specific ARARs
• Evaluating each alternative on the basis of
screening criteria (effectiveness, implementability,
cost)
• Reviewing and providing QC of work effort
• Preparing the report or technical memorandum
• Holding review meetings
• Refining the list of alternatives to be evaluated
Task 10. Detailed Analysis of Remedial
Alternatives
This task applies to the detailed analysis and
comparison of alternatives. The evaluation activities
include performing detailed human health,
environmental, and institutional analyses. The task
begins when the alternatives to undergo detailed
analysis have been identified and agreed upon and
ends when the analysis is complete. The following are
typical activities:5
• Refinement of alternatives
• Individual analysis against the criteria
• Comparative analysis of alternatives against the
criteria
• Review of QC efforts
• Review meetings
• Task management and QC
Task 11. Feasibility Study (or RI/FS) Reports
Similar to the Rl reports task, this task is used to
report FS deliverables. However, this task should be
used in lieu of the Rl reports task to report costs and
schedules for combined RI/FS deliverables. The task
ends when the FS (or RI/FS) is released to the public.
The following are typical activities:
5 State and community acceptance will be evaluated by the lead
agency during remedy selection.
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• Presenting data (formatting tables, preparing
graphics)
• Writing the report
• Printing and distributing the report
• Holding review meetings
• Revising the report on the basis of agency
comments
• Providing task management and quality control
Task 12. Post RI/FS Support
This task includes efforts to prepare the proposed
plan, the responsiveness summary, support the ROD,
conduct any predesign activities, and close out the
work assignment. All activities occurring after the
release of the FS to the public should be reported
under this task. The following are typical activities:
• Preparing the predesign report
• Preparing the conceptual design
• Attending public meetings
• Writing and reviewing the responsiveness
summary
• Supporting ROD preparation and briefings
• Reviewing and providing QC of the work effort
• Providing task management and QC
Task 13. Enforcement Support
This task includes efforts during the RI/FS associated
with enforcement aspects of the project. Activities
vary but are to be associated with efforts related to
PRPs. The following are typical activities:
• Reviewing PRP documents
• Attending negotiation meetings
• Preparing briefing materials
• Assisting in the preparation of ROD
• Providing task management and QC
Task 14. Miscellaneous Support
This task is used to report on work that is associated
with the project but is outside the normal RI/FS scope
of work. Activities will vary but include the following:
• Specific support for coordination with and review
of ATSDR activities and reports
• Support for review of special State or local
projects
The following are some specific comments applicable
to the 14 tasks described above:
• All standard tasks or all work activities under each
task need not be used for every RI/FS. Only
those that are relevant to a given project should
be used.
• Tasks include both draft and final versions of
deliverables unless otherwise noted.
• The phases of a task should be reported in the
same task (e.g., field investigation Phase I and
Phase II will appear as one field investigation
task).
• If an RI/FS is divided into distinct operable units,
each operable unit should be monitored and
reported on separately. Therefore, an RI/FS with
several operable units may, in fact, have more
than 15 tasks, although each of the tasks will be
one of the 15 standard tasks.
• Costs associated with project management and
technical QA are included in each task.
• Costs associated with procuring subcontractors
are included in the task in which the
subcontractor will perform work (not the project
planning task).
• Lists of standard tasks define the minimum level
of reporting. For federal-lead tasks, some RPMs
and contractors currently report progress in a
more detailed fashion and may continue to do so
as long as activities are associated with standard
tasks.
III. Elements of a Quality Assurance
Project Plan
Title Page - At the bottom of the title page, provisions
should be made for the signatures of approving
personnel. As a minimum, the QAPP must be
approved by the following:
• Subcontractor's project manager (if a
subcontractor is used)
• Subcontractor's QA manager (if a subcontractor
is used)
• Contractor's project manager (if applicable)
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• Contractor's QA manager (if applicable)
• Lead agency's project officer
• Lead agency's QA officer (if applicable)
Provision should be made for the approval or review
of others (e.g., regional laboratory directors), if
applicable.
Table of Contents - The table of contents will include
an introduction, a serial listing of the 16 QAPP
elements, and a listing of any appendixes that are
required to augment the QAPP. The end of the table
of contents should include a list of the recipients of
official copies of the QAPP.
Project Description - The introduction to the project
description consists of a general paragraph identifying
the phase of the work and the general objectives of
the investigation. A description of the location, size,
and important physical features of the site such as
ponds, lagoons, streams, and roads should be
included (a figure showing the site location and layout
is helpful). A chronological site history including
descriptions of the use of the site, complaints by
neighbors, permitting, and use of chemicals needs to
be provided along with a brief summary of previous
sampling efforts and an overview of the results.
Finally, specific project objectives for this phase of
data gathering need to be listed, and ways in which
the data will be used to address each of the
objectives must be identified. Those items above
that are also included in the work plan need not
be repeated in the QAPP and, instead, may be
incorporated by reference.
Project Organization and Responsibilities - This
element identifies key personnel or organizations that
are necessary for each activity during the study. A
table or chart showing the organization and line of
authority should be included. When specific personnel
cannot be identified, the organization with the
responsibility should be listed.
QA Objectives for Measurement - For individual
matrix groups and parameters, a cooperative effort
should be undertaken by the lead agency, the
principal engineering firm, and the laboratory staff to
define what levels of quality should be required for
the data. These QA objectives will be based on a
common understanding of the intended use of the
data, available laboratory procedures, and available
resources. The field blanks and duplicate field sample
aliquots to be collected for QA purposes should be
itemized for the matrix groups identified in the project
description.
The selection of analytical methods requires a
familiarity with regulatory or legal requirements
concerning data usage. Any regulations that mandate
the use of certain methods for any of the sample
matrices and parameters listed in the project
description should be specified.
The detection limits needed for the project should be
reviewed against the detection limits of the laboratory
used. Special attention should be paid to the
detection limits provided by the laboratory for volatile
organic compounds, because these limits are
sometimes insufficient for the analysis of drinking
water. Detection limits may also be insufficient to
assess attainment of ARARs. For Federal-lead
projects, if QA objectives are not met by CLP RASs,
then one or more CLP SASscan be written.
Quantitative limits should be established for the
following QA objectives:
1. Accuracy of spikes, reference compounds
2. Precision
3. Method detection limits
These limits may be specified by referencing the
SOW for CLP analysis, including SAS requests, in an
appendix and referring to the appendix or owner/
operator manuals for field equipment.
Completeness, representativeness, and comparability
are quality characteristics that should be considered
during study planning. Laboratories should provide
data that meet QC acceptance criteria for 90 percent
or more of the requested determinations. Any sample
types, such as control or background locations, that
require a higher degree of completeness should be
identified. "Representativeness" of the data is most
often thought of in terms of the collection of
representative samples or the selection of
representative sample aliquots during laboratory
analysis. "Comparability" is a consideration for
planning to avoid having to use data gathered by
different organizations or among different analytical
methods that cannot reasonably be compared
because of differences in sampling conditions,
sampling procedures, etc.
Sampling Procedures - These procedures append
the site-specific sampling plan. Either the sampling
plan or the analytical procedures element may
document field measurements or test procedures for
hydrogeological investigations.
For each major measurement, including pollutant
measurement systems, a description of the sampling
procedures to be used should be provided. Where
applicable, the following should be included:
• A description of techniques or guidelines used to
select sampling sites
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• A description of the specific sampling procedures
to be used
• Charts, flow diagrams, or tables delineating
sampling program
• A description of containers, procedures, reagents,
and so forth, used for sample collection,
preservation, transport, and storage
• A discussion of special conditions for the
preparation of sampling equipment and containers
to avoid sample contamination
• A description of sample preservation methods
• A discussion of the time considerations for
shipping samples promptly to the laboratory
• Examples of the custody or chain-of-custody
procedures and forms
• A description of the forms, notebooks, and
procedures to be used to record sample history,
sampling conditions, and analyses to be
performed
The DQO document described above can also be
incorporated by reference in this section. In addition,
the Compendium of Superfund Field Operations
Methods (U.S. EPA, September 1987) contains
information pertinent to this section and can be
incorporated by reference.
Sample Custody - Sample custody is a part of any
good laboratory or field operation. If samples were
needed for legal purposes, chain-of-custody
procedures, as defined by the NEIC Policies and
Procedures (U.S. EPA, June 1985), would be used.
Custody is divided into three parts:
• Sample collection
• Laboratory
• Final evidence files
The QAPP should address all three areas of custody
and should refer to the User's Guide to the Contract
Laboratory Program (U.S. EPA, December 1986) and
Regional guidance documents for examples and
instructions. For federal-lead projects, laboratory
custody is described in the CLP SOW; this may be
referenced. Final evidence files include all originals of
laboratory reports and are maintained under
documented control in a secure area.
A sample or an evidence file is under custody if:
• It is in your possession.
• It is in your view, after being in your possession.
• It was in your possession and you placed it in a
secure area.
• It is in a designated secure area.
A QAPP should provide examples of chain-of-
custody records or forms used to record the chain of
custody for samples, laboratories, and evidence files.
Calibration Procedures - These procedures should
be identified for each parameter measured and should
include field and laboratory testing. The appropriate
standard operating procedures (SOPs) should be
referenced, or a written description of the calibration
procedures to be used should be provided.
Analytical Procedures - For each measurement,
either the applicable SOP should be referenced or a
written description of the analytical procedures to be
used should be provided. Approved EPA procedures
or their equivalent should be used.
Data Reduction, Validation, and Reporting - For each
measurement, the data reduction scheme planned for
collected data, including all equations used to
calculate the concentration or value of the measured
parameter, should be described. The principal criteria
that will be used to validate the integrity of the data
during collection and reporting should be referenced.
Internal Qualify Control - All specific internal QC
methods to be used should be identified. These
methods include the use of replicates, spike samples,
split samples, blanks, standards, and QC samples.
Ways in which the QC information will be used to
qualify the field data should be identified.
Performance and Systems Audits - The QAPP should
describe the internal and external performance and
systems audits that will be required to monitor the
capability and performance of the total measurement
system. The current CLP Invitation for Bids for
organic and inorganic analyses may be referenced for
CLP RAS performance and systems audits. The
Compendium of Superfund Field Operations Methods
(U.S. EPA, September 1987) may be referenced for
routine fieldwork.
The systems audits consist of the evaluation of the
components of the measurement systems to
determine their proper selection and use. These
audits include a careful evaluation of both field and
laboratory QC procedures and are normally performed
before or shortly after systems are operational.
However, such audits should be performed on a
regular schedule during the lifetime of the project or
continuing operation. An onsite systems audit may be
required for formal laboratory certification programs.
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After systems are operational and are generating
data, performance audits are conducted periodically
to determine the accuracy of the total measurement
system or its component parts. The QAPP should
include a schedule for conducting performance audits
for each measurement parameter. Laboratories may
be required to participate in the analysis of
performance evaluation samples related to specific
projects. Project plans should also indicate, where
applicable, scheduled participation in all other
interlaboratory performance evaluation studies.
In support of performance audits, the environmental
monitoring systems and support laboratories provide
necessary audit materials and devices, as well as
technical assistance. These laboratories conduct
regular interlaboratory performance tests and provide
guidance and assistance in the conduct of systems
audits. The laboratories should be contacted if
assistance is needed in the above areas.
Preventive Maintenance - A schedule should be
provided of the major preventative maintenance tasks
that will be carried out to minimize downtime of field
and laboratory instruments. Owner's manuals may be
referenced for field equipment.
Specific Routine Procedures Used to Assess Data
(Precision, Accuracy, and Completeness) - The
precision and accuracy of data must be routinely
assessed for all environmental monitoring and
measurement data. The QAPP should describe
specific procedures to accomplish this assessment. If
enough data are generated, statistical procedures
may be used to assess the precision, accuracy, and
completeness. If statistical procedures are used, they
should be documented.
Corrective Actions - In the context of QA, corrective
actions are procedures that might be implemented on
samples that do not meet QA specifications.
Corrective actions are usually addressed on a case-
by-case basis for each project. The need for
corrective actions is based on predetermined limits
for acceptability. Corrective actions may include
resampling, reanalyzing samples, or auditing
laboratory procedures. The QAPP should identify
persons responsible for initiating these actions,
procedures for identifying and documenting corrective
actions, and procedures for reporting and followup.
Quality Assurance Project Plans - QAPPs should
identify the method to be used to report the
performance of measurement systems and data
quality. This reporting should include results of
performance audits, results of systems audits, and
significant QA problems encountered, along with
recommended solutions. The Rl report should include
a separate QA section that summarizes the data
quality.
IV. Elements of a Field Sampling Plan6
Site Background - If the analysis of existing data is
not included in the work plan or QAPP, it must be
included in the FSP. This analysis would include a
description of the site and surrounding areas and a
discussion of known and suspected contaminant
sources, probable transport pathways, and other
information about the site. The analysis should also
include descriptions of specific data gaps and ways in
which sampling is designed to fill those gaps.
Including this discussion in the FSP will help orient
the sampling team in the field.
Sampling Objectives - Specific objectives of a
sampling effort that describe the intended uses of
data should be clearly and succinctly stated.
Sample Location and Frequency - This section of the
sampling plan identifies each sample matrix to be
collected and the constituents to be analyzed. A table
may be used to clearly identify the number of
samples to be collected along with the appropriate
number of replicates and blanks. A figure should be
included to show the locations of existing or proposed
sample points.
Sample Designation - A sample numbering system
should be established for each project. The sample
designation should include the sample or well
number, the sampling round, the sample matrix (e.g.,
surface soil, ground water, soil boring), and the name
of the site.
Sampling Equipment and Procedures - Sampling
procedures must be clearly written. Step-by-step
instructions for each type of sampling are necessary
to enable the field team to gather data that will meet
the DQOs. A list should include the equipment to be
used and the material composition (e.g., Teflon,
stainless steel) of the equipment along with
decontamination procedures.
Sample Handling and Analysis - A table should be
included that identifies sample preservation methods,
types of sampling jars, shipping requirements, and
holding times. SAS requests and CLP SOWs may be
referenced for some of this information.
Examples of paperwork and instructions for filling out
the paperwork should be included. Use of the CLP
requires that traffic reports, chain-of-custody
forms, SAS packing lists, and sample tags be filled
out for each sample. If other laboratories are to be
used, the specific documentation required should be
6 Field sampling plans are site-specific and may include
additional elements.
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identified. Field documentation
notebooks and photographs.
includes field
Provision should be made for the proper handling and
disposal of wastes generated onsite. The site-
specific procedures need to be described to prevent
contamination of clean areas and to comply with
existing regulations.
V. Elements of a Health and Safety
Plan
1. The name of a site health and safety officer and
the names of key personnel and alternates
responsible for site safety and health
2. A health and safety risk analysis for existing site
conditions, and for each site task and operation
3. Employee training assignments
4. A description of personal protective equipment to
be used by employees for each of the site tasks
and operations being conducted
5. Medical surveillance requirements
6. A description of the frequency and types of air
monitoring, personnel monitoring, and environ-
mental sampling techniques and instrumentation
to be used
7. Site control measures
8. Decontamination procedures
9. Standard operating procedures for the site
10. A contingency plan that meets the requirements
of 29 CFR 1910.120(l)(1) and (l)(2)
11. Entry procedures for confined spaces
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Appendix C
Model Statement of Work for Remedial Investigations and Feasibility Studies
Introduction
This model statement of work (SOW) was developed
to provide users of this guidance with an illustrative
example of how the specific tasks1 carried out during
a remedial investigation (Rl) and feasibility study (FS)
may be presented. Because an RI/FS is phased in
accordance with a site's complexity and the amount
of available information, it may be necessary to
modify components of the SOW in order to tailor the
tasks to the specific conditions at a site. Similarly, the
level of detail and the specification of individual tasks
will vary according to the budget, size, and complexity
of the contract. Therefore, a SOW may differ, or
additional tasks may be added to what is presented
here.
A SOW should begin with a section identifying the
site, its regulatory history, if any, and a statement and
discussion of the purpose and objectives of the RI/FS
within the context of that particular site. This section
should be followed by a discussion of the specific
tasks that will be necessary to meet the stated
objectives. The SOW should be accompanied by U.S.
EPA's Guidance for Conducting Remedial Investi-
gations and Feasibility Studies Under CERCLA (EPA,
October 1988).
1REM contractor standard tasks have been developed for cost
accounting purposes (see Appendix B) and are the basis of the
format of this model SOW.
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Model SOW for Conducting an R/IFS
Purpose
The purpose of this remedial investigation/feasibility
study (RI/FS) is to investigate the nature and extent of
contamination at the OTR site and to develop and
evaluate remedial alternatives, as appropriate. The
contractor will furnish all necessary personnel,
materials, and services needed for, or incidental to,
performing the RI/FS, except as otherwise specified
herein. The contractor will conduct the RI/FS in
accordance with the Guidance for Conducting
Remedial Investigations and Feasibility Studies Under
CERCLA (U.S. EPA, October 1988).
This statement of work (SOW) has been developed
for the OTR site that operated as a former drum
recycling center from 1968 through 1979. OTR was
proposed for inclusion to the NPL in September 1980
and appeared as final on the NPL in September 1981.
A removal action taken in 1982 removed all visible
drums and disposed of them in an offsite landfill.
Three buildings remain onsite along with visibly
stained soil that is assumed to be contaminated with
TCE, benzene, and other organics. It is suspected
that releases from the site have contaminated nearby
surface waters and ground waters beneath the site.
Scope
The specific RI/FS activities to be conducted at the
OTR site are segregated into 11 separate tasks.
• Task 1 - Project Planning
• Task 2 - Community Relations
• Task 3 - Field Investigations
• Task 4 - Sample Analysis/Validation
• Task 5 - Data Evaluation
• Task 6 - Risk Assessment
• Task 7 - Treatability Studies
• Task 8 - Rl Report(s)
• Task 9 - Remedial Alternatives Development and
Screening
• Task 10 - Detailed Analysis of Alternatives
• Task 11 - FS Report(s)
The contractor shall specify a schedule of activities
and deliverables, a budget estimate, and staffing
requirements for each of the tasks which are
described below.
Task 1 Project Planning
Upon receipt of an interim authorization memorandum
(used to authorize work plan preparation) and this
SOW from U.S. EPA outlining the general scope of
the project, the contractor shall begin planning the
specific RI/FS activities that will need to be
conducted. As part of this planning effort, the
contractor will compile existing information (e.g.,
topographic maps, aerial photographs, data collected
as part of the NPL listing process, and data collected
as part of the drum removal of 1982) and conduct a
site visit to become familiar with site topography,
access routes, and the proximity of potential
receptors to site contaminants. Based on this
information (and any other available data), the
contractor will prepare a site background summary
that should include the following:
• Local Regional Summary - A summary of the
location of the site, pertinent area boundary
features and general site physiography,
hydrology, geology, and the location(s) of any
nearby drinking water supply wells.
• Nature and Extent of Problem - A summary of the
actual and potential onsite and offsite health and
environmental effects posed by any remaining
contamination at the site. Emphasis should be on
providing a conceptual understanding of the
sources of contamination, potential release
mechanisms, potential routes of migration, and
potential human and environmental receptors.
• History of Regulatory and Response Actions - A
summary of any previous response actions
conducted by local, State, Federal, or private
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parties. This summary should address any
enforcement activities undertaken to identify
responsible parties, compel private cleanup, and
recover costs. Site reference documents and
their locations should be identified.
• Preliminary Site Boundary - A preliminary site
boundary to define the initial area(s) of the
remedial investigation. This preliminary boundary
may also be used to define an area of access
control and site security.
The contractor will meet with EPA to discuss the
following:
• The proposed scope of the project and the
specific investigative and analytical activities that
will be required
• Whether there is a need to conduct limited
sampling to adequately scope the project and
develop project plans
• Preliminary remedial action objectives and general
response actions
• Potential remedial technologies and the need for
or usefulness of treatability studies
• Potential ARARs associated with the location and
contaminants of the site and the potential
response actions being contemplated
• Whether a temporary site office should be set up
to support site work
Once the scope has been agreed upon with EPA, the
contractor will (1) develop the specific project plans to
meet the objectives of the RI/FS2and (2) initiate
subcontractor procurement and coordination with
analytical laboratories. The project plans will include:
a work plan which provides a project description and
outlines the overall technical approach, complete with
corresponding personnel requirements, activity
schedules, deliverable due dates, and budget
estimates for each of the specified tasks; a sampling
and analysis plan [composed of the field sampling
plan (FSP) and the quality assurance project plan
(QAPP)]; a health and safety plan; and a community
relations plan. The latter three plans are described
below.
Sampling and Analysis Plan - The contractor will
prepare a SAP which will consist of the following:
2 At some sites it may be necessary to submit an interim work
plan initially until more is learned about the site. A subsequent,
more thorough project planning effort can then be used to
develop final workplans.
Field Sampling Plan. The FSP should specify and
outline all necessary activities to obtain additional site
data. It should contain an evaluation explaining what
additional data are required to adequately
characterize the site, conduct a baseline risk
assessment, and support the evaluation of remedial
technologies in the FS. The FSP should clearly state
sampling objectives; necessary equipment; sample
types, locations, and frequency; analyses of interest;
and a schedule stating when events will take place
and when deliverables will be submitted.
Quality Assurance Project Plan. The QAPP should
address all types of investigations conducted and
should include the following discussions:
• A project description (should be duplicated from
the work plan)
• A project organization chart illustrating the lines of
responsibility of the personnel involved in the
sampling phase of the project
• Quality assurance objectives for data such as the
required precision and accuracy, completeness of
data, representativeness of data, comparability of
data, and the intended use of collected data
• Sample custody procedures during sample
collection, in the laboratory, and as part of the
final evidence files
• The type and frequency of calibration procedures
for field and laboratory instruments, internal
quality control checks, and quality assurance
performance audits and system audits
• Preventative maintenance procedures and
schedule and corrective action procedures for
field and laboratory instruments
• Specific procedures to assess data precision,
representativeness, comparability, accuracy, and
completeness of specific measurement
parameters
• Data documentation and tracking procedures
Standard operating procedures for QA/QC that
have been established within EPA will be
referenced and not duplicated in the QAPP.
Health and Safety Plan - The contractor will develop
an HSP on the basis of site conditions to protect
personnel involved in site activities and the
surrounding community. The plan should address all
applicable regulatory requirements contained in 20
CFR 1910.120(i)(2) - Occupational Health and Safety
Administration, Hazardous Waste Operations and
Emergency Response, Interim Rule, December 19,
1986; U.S. EPA Order 1440.2 - Health and Safety
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Requirements for Employees Engaged in Field
Activities; U.S. EPA Order 1440.3 - Respiratory
Protection; U.S. EPA Occupational Health and Safety
Manual; and U.S. EPA Interim Standard Operating
Procedures (September, 1982). The plan should
provide a site background discussion and describe
personnel responsibilities, protective equipment,
health and safety procedures and protocols,
decontamination procedures, personnel training, and
type and extent of medical surveillance. The plan
should identify problems or hazards that may be
encountered and how these are to be addressed.
Procedures for protecting third parties, such as
visitors or the surrounding community, should also be
provided. Standard operating procedures for
ensuring worker safety should be referenced and
not duplicated in the HSP.
Community Relations Plan - The contractor will
prepare a community relations plan on how citizens
want to be involved in the process based on
interviews with community representatives and
leaders. The CLP will describe the types of
information to be provided to the public and outline
the opportunities for community comment and input
during the RI/FS. Deliverables, schedule, staffing, and
budget requirements should be included in the plan.
The work plan and corresponding activity plans will be
submitted to EPA as specified in the contract or as
discussed in the initial meeting(s). The contractor will
provide a quality review of all project planning
deliverables.
Task 2 Community Relations
The contractor will provide the personnel, services,
materials, and equipment to assist EPA in undertaking
a community relations program. This program will be
integrated closely with all remedial response activities
to ensure community understanding of actions being
taken and to obtain community input on RI/FS
progress. Community relations support provided by
the contractor will include, but may not be limited to,
the following:
• Revisions or additions to community relations
plans, including definition of community relations
program needs for each remedial activity
• Establishment of a community information
repository(ies), one of which will house a copy of
the administrative record
• Preparation and dissemination of news releases,
fact sheets, slide shows, exhibits, and other
audio-visual materials designed to apprise the
community of current or proposed activities
• Arrangements of briefings, press conferences,
workshops, and public and other informal
meetings
• Analysis of community attitudes toward the
proposed actions
• Assessment of the successes and failures of the
community relations program to date
• Preparation of reports and participation in public
meetings, project review meetings, and other
meetings as necessary for the normal progress of
the work
• Solicitation, selection, and approval of
subcontractors, if needed
Deliverables and the schedule for submittal will be
identified in the community relations plan discussed
under Task 1.
Task 3 Field Investigations
The contractor will conduct those investigations
necessary to characterize the site and to evaluate the
actual or potential risk to human health and the
environment posed by the site. Investigation activities
will focus on problem definition and result in data of
adequate technical content to evaluate potential risks
and to support the development and evaluation of
remedial alternatives during the FS. The aerial extent
of investigation will be finalized during the remedial
investigation.
Site investigation activities will follow the plans
developed in Task 1. Strict chain-of-custody
procedures will be followed and all sample locations
will be identified on a site map. The contractor will
provide management and QC review of all activities
conducted under this task. Activities anticipated for
this site are as follows:
• Surveying and Mapping of the Site3- Develop a
map of the site that includes topographic
information and physical features on and near the
site. If no detailed topographic map for the site
and surrounding area exists, a survey of the site
will be conducted. Aerial photographs should be
used, when available, along with information
gathered during the preliminary site visit to
identify physical features of the area.
• Waste Characterization - Determine the location,
type, and quantities as well as the physical or
chemical characteristics of any waste remaining
at the site. If hazardous substances are held in
3 May be conducted under Task 1 as part of the site visit or
limited investigation.
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containment vessels, the integrity of the
containment structure and the characteristics of
the contents will be determined.
• Hydrogeologic Investigation - Determine the
presence and potential extent of ground water
contamination. Efforts should begin with a survey
of previous hydrogeologic studies and other
existing data. The survey should address the
soil's retention capacity/mechanisms, dis-
charge/recharge areas, regional flow directions
and quality, and the likely effects of any
alternatives that are developed involving the
pumping and disruption of ground water flow.
Results from the sampling program should
estimate the horizontal and vertical distribution of
contaminants, the contaminants' mobility, and
predict the long-term disposition of
contaminants.
• Soils and Sediments Investigation - Determine
the vertical and horizontal extent of contamination
of surface and subsurface soils and sediments
and identify any uncertainties with this analysis.
Information on local background levels, degree of
hazard, location of samples, techniques used, and
methods of analysis should be included. If initial
efforts indicate that buried waste may be present,
the probable locations and quantities of these
subsurface wastes should be identified through
the use of appropriate geophysical methods.
• Surface Water Investigation - Estimate the extent
and fate of any contamination in the nearby
surface waters. This effort should include an
evaluation of possible future discharges and the
degree of contaminant dilution expected.
• Air Investigation - Investigate the extent of
atmospheric contamination from those
contaminants found to be present at the site. This
effort should assess the potential of the
contaminants to enter the atmosphere, local wind
patterns, and the anticipated fate of airborne
contaminants.
Information from this task will be summarized and
included in the RI/FS report appendixes.
Task 4 Sample AnalysislValidation
The contractor will develop a data management
system including field logs, sample management and
tracking procedures, and document control and
inventory procedures for both laboratory data and
field measurements to ensure that the data collected
during the investigation are of adequate quality and
quantity to support the risk assessment and the FS.
Collected data should be validated at the appropriate
field or laboratory QC level to determine whether it is
appropriate for its intended use. Task management
and quality controls will be provided by the contractor.
The contractor will incorporate information from this
task into the RI/FS report appendixes.
Task 5 Data Evaluation
The contractor will analyze all site investigation data
and present the results of the analyses in an
organized and logical manner so that the relationships
between site investigation results for each medium
are apparent. The contractor will prepare a summary
that describes (1) the quantities and concentrations of
specific chemicals at the site and the ambient levels
surrounding the site; (2) the number, locations, and
types of nearby populations and activities; and (3) the
potential transport mechanism and the expected fate
of the contaminant in the environment.
Task 6 Risk Assessment
The contractor shall conduct a baseline risk
assessment to assess the potential human health and
environmental risks posed by the site in the absence
of any remedial action. This effort will involve four
components: contaminant identification, exposure
assessment, toxicity assessment, and risk
characterization.
• Contaminant Identification - The contractor will
review available information on the hazardous
substances present at the site and identify the
major contaminants of concern. Contaminants of
concern should be selected based on their
intrinsic toxicological properties because they are
present in large quantities, and/or because they
are currently in, or potentially may migrate into,
critical exposure pathways (e.g., drinking water).
• Exposure Assessment - The contractor will
identify actual or potential exposure pathways,
characterize potentially exposed populations, and
evaluate the actual or potential extent of
exposure.
• Toxicity Assessment - The contractor will provide
a toxicity assessment of those chemicals found to
be of concern during site investigation activities.
This will involve an assessment of the types of
adverse health or environmental effects
associated with chemical exposures, the
relationships between magnitude of exposures
and adverse effects, and the related uncertainties
for contaminant toxicity, (e.g., weight of evidence
for a chemical's carcinogenicity).
• Risk Characterization - The contractor will
integrate information developed during the
exposure and toxicity assessments to
characterize the current or potential risk to human
health and/or the environment posed by the site.
This characterization should identify the potential
C-5
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for adverse health or environmental effects for the
chemicals of concern and identify any
uncertainties associated with contaminant(s),
toxicity(ies), and/or exposure assumptions.
The risk assessment will be submitted to EPA as part
of the Rl report.
Task 7 Treatability Studies
The contractor will conduct bench and/or pilot studies
as necessary to determine the suitability of remedial
technologies to site conditions and problems.
Technologies that may be suitable to the site should
be identified as early as possible to determine
whether there is a need to conduct treatability studies
to better estimate costs and performance capabilities.
Should treatability studies be determined to be
necessary, a testing plan identifying the types and
goals of the studies, the level of effort needed, a
schedule for completion, and the data management
guidelines should be submitted to EPA for review and
approval. Upon EPA approval, a test facility and any
necessary equipment, vendors, and analytical
services will be procured by the contractor.
Upon completion of the testing, the contractor will
evaluate the results to assess the technologies with
respect to the goals identified in the test plan. A
report summarizing the testing program and its results
should be prepared by the contractor and presented
in the final RI/FS report. The contractor will implement
all management and QC review activities for this task.
Task 8 Rl Report
Monthly reports will be prepared by the contractor to
describe the technical and financial progress at the
OTR site. Each month the following items will be
reported:
• Status of work and the progress to date
• Percentage of the work completed and the status
of the schedule
• Difficulties encountered and corrective actions to
be taken
• The activity(ies) in progress
• Activities planned for the next reporting period
• Any changes in key project personnel
• Actual expenditures (including fee) and direct
labor hours for the reporting period and for the
cumulative term of the project
• Projection of expenditures needed to complete
the project and an explanation of significant
departures from the original budget estimate
Monthly reports will be submitted to U.S. EPA as
specified in the contract. In addition, the activities
conducted and the conclusions drawn during the
remedial investigation (Tasks 3 through 7) will be
documented in an Rl report (supporting data and
information should be included in the appendixes of
the report). The contractor will prepare and submit a
draft Rl report to EPA for review. Once comments on
the draft Rl report are received, the contractor will
prepare a final Rl report reflecting these comments.
Task 9 Remedial Alternatives Development and
Screening
The contractor will develop a range of distinct,
hazardous waste management alternatives that will
remediate or control any contaminated media (soil,
surface water, ground water, sediments) remaining at
the site, as deemed necessary in the Rl, to provide
adequate protection of human health and the
environment. The potential alternatives should
encompass, as appropriate, a range of alternatives in
which treatment is used to reduce the toxicity,
mobility, or volume of wastes but vary in the degree
to which long-term management of residuals or
untreated waste is required, one or more alternatives
involving containment with little or no treatment; and a
no-action alternative. Alternatives that involve
minimal efforts to reduce potential exposures (e.g.,
site fencing, deed restrictions) should be presented
as "limited action" alternatives.
The following steps will be conducted to determine
the appropriate range of alternatives for this site:
• Establish Remedial Action Objectives and
General Response Actions4- Based on existing
information, site-specific remedial action
objectives to protect human health and the
environment should be developed. The objectives
should specify the contaminant(s) and media of
concern, the exposure route(s) and receptor(s),
and an acceptable contaminant level or range of
levels for each exposure route (i.e., preliminary
remediation goals).
Preliminary remediation goals should be established
based on readily available information (e.g., Rfds) or
chemical-specific ARARs (e.g., MCLs). .The
contractor should meet with EPA to discuss the
remedial action objectives for the site. As more
information is collected during the Rl, the contractor,
4 Preliminary remedial action objectives are developed as part of
the project planning phase.
C-6
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in consultation with EPA, will refine remedial action
objectives as appropriate.
General response actions will be developed for each
medium of interest defining contaminant, treatment,
excavation, pumping, or other actions, singly or in
combination to satisfy remedial action objectives.
Volumes or areas of media to which general response
actions may apply shall be identified, taking into
account requirements for protectiveness as identified
in the remedial action objectives and the chemical
and physical characteristics of the site.
• Identify and Screen Technologies - Based on the
developed general response actions, hazardous
waste treatment technologies should be identified
and screened to ensure that only those
technologies applicable to the contaminants
present, their physical matrix, and other site
characteristics will be considered. This screening
will be based primarily on a technology's ability to
effectively address the contaminants at the site,
but will also take into account a technology's
implementability and cost. The contractor will
select representative process options, as
appropriate, to carry forward into alternative
development. The contractor will identify the need
for treatability testing (as described under Task 7)
for those technologies that are probable
candidates for consideration during the detailed
analysis.
• Configure and Screen Alternatives - The potential
technologies and process options will be
combined into media-specific or sitewide
alternatives. The developed alternatives should be
defined with respect to size and configuration of
the representative process options; time for
remediation; rates of flow or treatment; spatial
requirements; distances for disposal; and required
permits, imposed limitations, and other factors
necessary to evaluate the alternatives. If many
distinct, viable options are available and
developed, a screening of alternatives will be
conducted to limit the number of alternatives that
undergo the detailed analysis and to provide
consideration of the most promising process
options. The alternatives should be screened on a
general basis with respect to their effectiveness,
implementability, and cost. The contractor will
meet with EPA to discuss which alternatives will
be evaluated in the detailed analysis and to
facilitate the identification of action-specific
ARARs.
Task 10 Detailed Analysis of Alternatives
The contractor will conduct a detailed analysis of
alternatives which will consist of an individual analysis
of each alternative against a set of evaluation criteria
and a comparative analysis of all options against the
evaluation criteria with respect to one another.
The evaluation criteria are as follows:
• Overall Protection of Human Health and the
Environment addresses whether or not a remedy
provides adequate protection and describes how
risks posed through each pathway are eliminated,
reduced, or controlled through treatment,
engineering controls, or institutional controls.
• Compliance with ARARs addresses whether or
not a remedy will meet all of the applicable or
relevant and appropriate requirements of other
Federal and State environmental statutes and/or
provide grounds for invoking a waiver.
• Long-Term Effectiveness and Permanence
refers to the ability of a remedy to maintain
reliable protection of human health and the
environment over time once cleanup goals have
been met.
• Reduction of Toxicity, Mobility, or Volume Through
Treatment is the anticipated performance of the
treatment technologies a remedy may employ.
• Short-Term Effectiveness addresses the period
of time needed to achieve protection and any
adverse impacts on human health and the
environment that may be posed during the
construction and implementation period until
cleanup goals are achieved.
• Implementability is the technical and
administrative feasibility of a remedy, including
the availability of materials and services needed
to implement a particular option.
• Cost includes estimated capital and operation and
maintenance costs, and net present worth costs.
• State Acceptances (Support Agency) addresses
the technical or administrative issues and
concerns the support agency may have regarding
each alternative.
• Community Acceptance"addresses the issues
and concerns the public may have to each of the
alternatives.
The individual analysis should include: (1) a technical
description of each alternative that outlines the waste
management strategy involved and identifies the key
5 These criteria will be addressed in the ROD once comments
on the RI/FS report and proposed plan have been received
and will not be included in the RI/FS report..
C-7
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ARARs associated with each alternative; and (2) a
discussion that profiles the performance of that
alternative with respect to each of the evaluation
criteria. A table summarizing the results of this
analysis should be prepared. Once the individual
analysis is complete, the alternatives will be
compared and contrasted to one another with respect
to each of the evaluation criteria.
Task 11 FS Report(s)
Monthly contractor reporting requirements for the FS
are the same as those specified for the Rl under Task
The contractor will present the results of Tasks 9 and
10 in a FS report. Support data, information, and
calculations will be included in appendixes to the
report. The contractor will prepare and submit a draft
FS report to EPA for review. Once comments on the
draft FS have been received, the contractor will
prepare a final FS report reflecting the comments.6
Copies of the final report will be made and distributed
to those individuals identified by EPA.
6The final FS report may be bound with the final Rl report.
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Appendix D
Bibliography of Technology Process Resource Documents
I. Containment Technologies
Capping
The Asphalt Institute. Nov. 1976. Asphalt in
Hydraulics. Manual Series No. 12 (MS-12), The
Asphalt Institute.
Brady, N.C. 1974. The Nature and Properties of Soils.
8th Ed., MacMillan, NY.
Brawner, C.O., Ed. 1980. First International
Conference on Uranium Mine Waste Disposal.
Society of Mining Engineers AIME, NY.
Chamberlain, E.J., and A.J. Gow. 1979. Effect of
Freezing and Thawing on the Permeability and
Structure of Soils. Engineering Geology, 13,
Elsevier Scientific Publishing Co., Amsterdam, The
Netherlands, pp. 73-92.
Daniel, D.E., and H.M. Liljestrant, Univ. of Texas.
Jan. 1984. Effects of Landfill Leachates on Natural
Liner Systems. Chemical Manufacturer's
Association.
England, C.B. 1970. Land Capability; A Hydrologic
Response Unit in Agricultural Watersheds. ARS
41-172, Agricultural Research Service, U.S.
Department of Agriculture.
Ghassemi, M. May 1983. Assessment of Technology
for Constructing and Installing Cover and Bottom
Liner Systems for Hazardous Waste Facilities. Vol.
1, EPA Contract No. 68-02-3174, work
assignment No. 109, U.S. EPA.
Kays, W.B. 1977. Construction of Linings for
Reservoirs, Tanks, and Pollution Control Facilities.
John Wiley & Sons, NY.
Kmet, P., K.J. Quinn, and C. Slavik. Sept. 1981.
Analysis of Design Parameters Affecting the
Collection Efficiency of Clay Lined Landfills. Univ.
of Wisconsin Extension.
Lambe, W.T., and R.V. Whitman. 1979. Solid
Mechanics, SI Version. John Wiley and Sons, NY.
Lutton, R.J. 1982. Evaluating Cover Systems for Solid
and Hazardous Waste. SW867 (Revised Edition),
U.S. EPA, Washington, DC.
Lutton, R.J. et al. 1979. Design and Construction of
Covers for Solid Waste Landfills. EPA-600/2-
79-165, U.S. EPA, Cincinnati, OH.
Morrison, W.R., and L.R. Simmons. 1977. Chemical
and Vegetative Stabilization of Soil: Laboratory and
Field Investigations of New Materials and Methods
for Soil Stabilization and Erosion Control. Bureau of
Reclamation Report No. 7613.
Oldham, J.C., et al. 1977. Materials Evaluated as
Potential Soil Stabilizers. Paper No. S-77-15
Army Engineers, Waterways Experimental Station,
Vicksburg, MS.
Richards, L.A. 1965. Physical Condition of Water in
Soil. In: Methods of Soil Analysis - Part . C.A.
Black, Ed., American Society of Agronomy, Inc.
Schroeder, P.R., et al. The Hydrologic Evaluation of
Landfill Performance (HELP) Model. Vol. 1,
EPA/530-SW-84-009, U.S. EPA.
Tchobanoglous, G., et al. 1977. Solid Wastes:
Engineering Principles and Management Issues.
McGraw-Hill, NY.
U.S. EPA. Construction Quality Assurance for
Hazardous Waste Land Disposal Facilities. Public
Comment Draft, J.G. Herrmann, Project Officer.
EPA/530-SW-85-021, U.S. EPA.
U.S. EPA. July 1982. Draft RCRA Guidance
Document Landfill Design, Liner Systems and Final
Cover. U.S. EPA.
U.S. EPA. 1983. Lining of Waste Impoundment and
Disposal Facilities. SW870, U.S. EPA.
U.S. EPA. Procedures for Modeling Flow Through
Clay Liners to Determine Required Liner
Thickness. EPA/530-SW-84-001, U.S. EPA.
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Warner, R.C., et al. Demonstration and Evaluation of
the Hydrologic Effectiveness of a Three Layer
Landfill Surface Cover Under Stable and
Subsidence Conditions - Phase I, Final Project
Report.
Warner, R.C., et al. Multiple Soil Layer Hazardous
Waste Landfill Cover: Design, Construction,
Instrumentation and Monitoring. In: Land Disposal
of Hazardous Waste Proceedings of the Tenth
Annual Research Symposium.
Dust Controls
Ritter, L. J., Jr., and R.J. Paquette. 1967. Highway
Engineering. 3d Ed., The Ronald Press Co., NY.
pp. 726-728.
Horizontal Barriers
Bureau of Reclamation. Pressure Grouting. Technical
Memo 646.
U.S. EPA. Handbook for Evaluating Remedial Action
Technology Plans.
Sediment Control Barriers
California Department of Conservation. May 1978.
Erosion and Sediment Control Handbook.
Department of Conservation, State of California.
U.S. EPA. August 1972. Guidelines for Erosion and
Sediment Control Planning and Implementation.
U.S. EPA, Environmental Protection Technical
Services.
U.S. EPA. Sept. 1978. Management of Bottom
Sediment Containing Toxic Substance Procedure,
3rd vs - Japan Meeting. U.S. EPA.
U.S. EPA. June 1982. Handbook - Remedial Action
at Waste Disposal Sites. EPA-625/6-6-82-
006, U.S. EPA, Cincinnati, OH.
Surface Controls
Lutton, R.J., et al. 1979. Design and Construction of
Covers for Solid Waste Landfills. EPA-600/2-
79-165, U.S. EPA Cincinnati, OH.
U.S. EPA. July 1982. Draft RCRA Guidance
Document Landfill Design, Liner Systems, and
Final Cover. U.S. EPA.
U.S. EPA. June 1982. Handbook - Remedial Action
at Waste Disposal Sites. EPA-625/6-6-82-
006, U.S. EPA, Cincinnati, OH.
Vertical Barriers
Bureau of Reclamation. Pressure Grouting. Technical
Memo. 646.
Shuster, J. 1972. Controlled Freezing for Temporary
Ground Support. Proceedings, 1st North American
Rapid Excavation and Tunneling Conference.
Xanthakos, P. Slurry Walls. McGraw Hill, NY.
II. Treatment Technologies
Air Emission Controls/Gas Treatment
Bonner, T., et al. 1981. Hazardous Waste Incineration
Engineering. Noyes Data Corporation.
Kern, D.Q. 1950. Process Heat Transfer. McGraw-
Hill, NY.
Kohl, A., and F. Riesenfeld. 1979. Gas Purification.
Gulf Publishing Co.
Perry and Chilton Chemical Engineers' Handbook. 5th
Ed., 1973, McGraw-Hill, NY.
Research and Education Association. 1978. Modern
Pollution Control Technology. Vol. 1, Air Pollution
Control. Research and Education Association.
Biological Treatment
Benefield, L.D., and C.W. Randall. 1980. Biological
Process Design for Wastewater Treatment.
Prentice- Hall, Englewood Cliffs, NJ.
Clark, J.W., W. Viessman, Jr., and J. Hammar. 1977.
Water Supply and Pollution Control. IEP, Dun-
Donnelly, NY.
Eckenfelder, W., Jr. 1980. Principles of Water Quality
Management. CBI Publishing, Boston.
Fair, G., J. Geyer, and D. Okun. 1968. Water and
Wastewater Engineering. Vol. 2, John Wiley, NY.
Junkins, R., et al. 1983. The Activated Sludge
Process: Fundamentals of Operation. Ann Arbor
Science Publishers, Ann Arbor, Ml.
Manual of Practice No. 16, Anaerobic Sludge
Digestion. W PCF, 1968.
Metcalf & Eddy. 1972. Wastewater Engineering:
Treatment, Disposal, Reuse. 2nd Ed., McGraw-
Hill, NY.
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Overcash. 1979. Design of Land Treatment Systems
for Industrial Wastes.
Shreve, R. N., and J.A. Brink, Jr. 1977. Chemical
Process Industries. McGraw-Hill, NY.
Smith, E.D., et al. 1980. Proceedings First National
Symposium/Workshop, Rotating Biological
Contractor Technology. University of Pittsburgh.
Speece, R.E., and J.F. Malina, Jr., Eds. 1973.
Applications of Commercial Oxygen to Water and
Wastewater Systems. Univ. of Texas, Austin.
U.S. EPA. Dec. 1985. Guide for Identifying Cleanup
Alternatives at Hazardous- Waste Sites and Spills.
EPA/600/3-83/063; NTIS PB86-144664, U.S.
EPA.
U.S. EPA. 1980. Hazardous Waste Land Treatment,
EPA SW 874, U.S. EPA.
U.S. EPA. Dec. 1984. Permit Guidance Manual on
Hazardous Waste Land Treatment Demonstrations.
Draft, EPA 530-SW-84-015, U.S. EPA.
U.S. EPA. Process Design Manual, Sludge
Treatment and Disposal. U.S. EPA.
U.S. Municipal Environmental Research Laboratory.
Oct. 1983. Process Design Manual for Land
Application of Municipal Sludge. EPA 625/I-83-
016, U.S. EPA.
Vesilind, P.A. Sludge Treatment and Disposal.
Chemical Treatment
Audrieth, L.F., and B.A. Ogg. 1951. The Chemistry of
Hydrazine. John Wiley, NY.
Berkowitz, J.B., et al. 1978. Unit Operations for
Treatment of Industrial Wastes. Noyces Data
Corp., Park Ridge, NJ.
Butler, J.W. 1964. Solubility and pH Calculations.
Addision-Wesley.
Duffey, J.G., S.B. Gale, and S. Bruckenstein.
Electrochemical Removal of Chromates and Other
Metals. In: Cooling Towers. Vol. 2, pp 44-50.
Metcalf & Eddy, Inc., revised by Tchobanoglous, G.
1979. Wastewater Engineering: Treatment,
Disposal, Reuse. 2nd Ed.
McHugh, M.A., and V.J. Krukonis. 1986. Supercritical
Fluid Extraction Principles and Practice.
Butterworth Publishers, Boston.
Reduction by Direct Current (Electrochemical
Treatment) References: Scull, G.W., and K.D.
Uhrich. Electrochemical Removal of Heavy Metals
in the Presence of Chelating Agents. Andco
Environmental Processes, Inc., Amherst, NY.
Simpson, O.K. Safety Handling Hydrazine. Prepared
for the Water Industrial Power Conference,
Southfield, Ml, Oct. 16-19, 1983.
Tsusita, R.A., et al. 1981. Pretreatment of Industrial
Wastes Manual of Practice. No. FD-3, Water
Pollution Control Federation, Washington, DC.
In Situ Treatment
Ahlert, R.C., and D.S. Kosson. In-Situ and On-Site
Biodegradation of Industrial Landfill Leachate.
NTIS, Springfield, VA.
American Petroleum Institute. Feb. 1982. Enhancing
the Microbial Degradation of Underground
Gasoline by Increasing Available Oxygen. Texas
Research Institute.
References on the use of H202 in Subsurface
Bioreclamation: American Petroleum Institute.
1985. Feasibility Studies on the Use of Hydrogen
Peroxide to Enhance Microbial Degrations of
Gasoline. API Publication 4389.
Baker, R., et al. Oct. 1986. In Situ Treatment for Site
Remediation. Paper presented at Third Annual
Hazardous Waste Law and Management
Conference, Seattle, WA, and Portland, OR.
Ellis, W.D., and T.R. Fogg. August 1986. Treatment
of Soils Contaminated With Heavy Metals.
EPA/600/9-86/022, U.S. EPA, pp. 201-207.
Flathman, P.E., and J.A. Caplan. April 1985.
Biological Cleanup of Chemical Spills. Paper
presented at Hazmacon '85 Conference, Oakland,
CA.
Nyer, E.K. 1985. Treatment Methods for Organic
Contaminants: Biological Methods - In Situ
Treatment. In Groundwater Treatment Technology.
Van Nostrand Reinhold. pp: 10-108.
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In Remedial Action at Waste Disposal Sites.
Revised, EPA/625/6/-85/006, U.S. EPA.
U.S. EPA. Sept./Nov. 1984. Review of In-Place
Treatment Techniques for Contaminated Surface
Soils. Vol. 1, Technical Evaluation, Vol. 2,
Background Information for In Situ Treatment.
EPA-540/2-84-003a, and EPA-540/284-
003b, (NTIS PB-124881 and PB-124899), U.S.
EPA.
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Ward, C.H., and M.D. Lee. 1985. In Situ
Technologies. In Groundwater Pollution Control.
Canter and Knox, Eds., Lewis Publishers.
Wetzel, R.S., et al. August 1986. Field Demonstration
of In Situ Biological Treatment of Contaminated
Groundwater and Soils. EPA/600/9-86/022, U.S.
EPA, pp. 146-160.
Yaniga, P.M., and W. Sanith. 1984. Aquifer
Restoration via Accelerated In Situ Biodegradation
of Organic Contaminants. In Proceedings,
NWWA/API Conference on Petroleum
Hydrocarbons and Organic Chemicals in
Groundwater - Prevention, Detection, and
Restoration, pp. 451-470.
Physical Treatment
Cheremisinoff, P.M., and F. Ellerbusch. 1980. Carbon
Adsorption Handbook. Science Publishers, Ann
Arbor, Ml.
Cheremisinoff, N., and Azbel, D. 1983. Liquid
Filtration. Science Publishers, Ann Arbor, Ml.
Dobbs, R.A., and J.M. Cohen. April, 1980. Carbon
Adsorption Isotherms for Toxic Organics. EPA-
600/8-80-023, U.S. EPA.
Cosset, J.M., et al. June 1985. Mass Transfer
Coefficients and Henry's Constants for Packed-
Tower Air Stripping of Volatile Organics:
Measurement and Correlation. ESL-TR-85-18,
Final Report, U.S. Air Force.
Kavanaugh, M.C., and R.R. Trussel. Dec. 1980.
Design of Aeration Towers to Strip Volatile
Contaminants from Drinking Water. Journal AWWA.
Modern Pollution Control Technology, Vol. 2, Water
Pollution Control. Research and Education
Association, 1978.
Perry and Chilton, Chemical Engineers' Handbook.
5th Ed., 1973, McGraw-Hill, NY.
Schweitzer, P.A. 1979. Handbook of Separation
Techniques for Chemical Engineers. McGraw-Hill,
NY.
Shukla, Harish M., and Hicks, R.E. Process Design
Manual for Stripping of Organics. EPA/600-/2-
84-130, U.S. EPA.
Treybal, R. 1983. Mass Transfer Operations. 3rd Ed.
McGraw-Hill, NY.
Solids Dewatering
Metcalf and Eddy, Inc. 1972. Wastewater
Engineering: Collection, Treatment, Disposal.
McGraw-Hill, NY.
Perry and Chilton, Chemical Engineers' Handbook.
5th Ed., 1973, McGraw-Hill, NY.
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Pollution Control Technology Vol. II, So/id Waste
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Given, I.A. 1973. Mining Engineering Handbook.
Society of Mining Engineers, NY.
Taggert, A.F. 1951. Elements of Ore Dressing. John
Wiley, NY.
Solidification, Fixation and Stabilization
Technical Handbook for Stabilization/Solidification
Alternatives for Remedial Action at Uncontrolled
Hazardous Waste Sites. Environmental Laboratory,
U.S. Army Engineers Waterways Experiment
Station, Vicksburg, MS.
U.S. EPA. Sept. 1982. Guide to the Disposal of
Chemically Stabilized and Solidified Waste. EPA
Doc. No. SW-872. Municipal Environmental
Research Laboratory, U.S. EPA, Cincinnati, OH.
U.S. EPA. June 1982. Remedial Action at Waste
Disposal Sites. Municipal Environmental Research
Laboratory, U.S. EPA, Cincinnati, OH.
Thermal Treatment
Ahling, B. Nov. 1979. Destruction of Chlorinated
Hydrocarbons in a Cement Kiln Environmental
Science and Technology. Vol. 13, No. 11.
Brunner, C.R. 1984. Incineration Systems Selection
and Design. Van Nostrand Reinhold, NY.
Environment Canada, Environmental Protection
Service, Environmental Impact Control Directorate,
Waste Management Branch. 1982. Destruction
Technologies for Polychlorinated Biphenyls
(PCB). Based on a report to the Waste
Management Branch by M.M. Dillon Ltd.,
Consulting Engineers and Planners, Toronto,
Ontario, Canada.
Frankel, I., Sanders, N., and Vogel, G. 1983. Survey
of the Incineration Manufacturing Industry. CEP,
March 1983.
D-4
-------
Journal of the Air Pollution Control Association. July
1982, Vol. 32, No. 7.
Lauber, J.D. 1982. Burning Chemical Wastes as
Fuels in Cement Kilns. Journal of the Air Pollution
Control Association, July 1982, Vol. 32, No. 7.
McBride, J.L., and Heimback, J.A. Skid Mounted
System Gives California Hazardous Wastes Hot
Time. Pollution Engineering, July 1982.
McCarthy, J.J. Feb. 1982. Technology Assessment of
the Vertical Well Chemical Reactor. EPA-600/2-
82-005, Prepared for U.S. EPA, Municipal
Environmental Research Laboratory, Office of
Research and Development.
Oberacker, D.A. 1984. Hazardous Waste Incineration
Performance Evaluations by the United States
Environmental Protection Agency. EPA-600/D-
84-285. Prepared for U.S. EPA, Cincinnati, OH.
Peters, J.A., T.W. Hughes, and R.E. Mourninghan.
1983. Evaluation of Hazardous Waste Incineration
in a Cement Kiln at San Juan Cement. Monsanto
Research Co., Dayton, OH.
Seebold, J. A. Practical Flare Design. Chemical
Engineering, December 10, 1984.
U.S. Congress, Office of Technology Assessment,
Industry, Technology, and Employment Program.
1985. Superfund Strategy-Preventing a Toxic
Tomorrow.
U.S. EPA. Sept. 1981. Engineering Handbook for
Hazardous Waste Incineration. NTIS Report No.
P881-248163, Prepared for U.S. EPA by
Monsanto Research Corp., Dayton, OH.
Weltzman, L. 1983. Cement Kilns as Hazardous
Waste Incinerators. Environmental Progress, Feb.
1983, Vol. 2, No. 1.
Wilhelmi, A.R., and Knopp, P.V. Wet Air Oxidation -
An Alternative to Incineration. CEP, Aug. 1979.
Williams, I.M., Jr. 1982. Pyrolytic Incineration
Destroys Toxic Wastes Recovers Energy. Pollution
Engineering, July 1982.
Zanetti, W.J. Plasma: Warming Up to New CPI
Applications. Chemical Engineering, December
1983.
III. Removal/Collection Technologies
Clean/Replace Contaminated Water and Sewer
Lines
Cleaning Pipelines: A Pigging Primer. Chemical
Engineering, Feb. 4, 1985.
U.S. EPA. Oct. 1983. Demonstration of Sewer
Relining by the Insituform Process, Northbrook, IL.
EPA-600/2-83-064.
WPCF. 1980. Operation and Maintenance of
Wastewater Collection Systems. Manual of
Practice No. 7, WPCF.
Drum and Debris Removal
U.S. EPA. June 1982. - Handbook - Remedial Action
at Waste Disposal Sites. EPA-625-6-6-82-
006, Cincinnati, OH.
Enhanced Removal
Donaldson, E.G., G.U. Chilingarian, and T.F. Ven.
1985. Enhanced Oil Recovery. Fundamentals and
Analyses, 1, Elsevier Science Publishers B.V.,
Amsterdam, The Netherlands.
H.K. Van Poollen and Assoc., Inc. 1980. Enhanced
Oil Recovery. Pennwells Publishing Company,
Tulsa, OK.
Koltuniak, D.L. In Situ Air Stripping Cleans
Contaminated Soils. Chemical Engineering, August
18, 1986, pp. 30-31.
Patton, C.C. 1981. Oilfield Water Systems, Norman,
Oklahoma. Campbell Petroleum Series.
Schumacher, M.M., Ed. 1980. Enhanced Recovery of
Residual and Heavy Oils. Noyes Data Corp., Park
Ridge, NJ. (Contains references.)
Excavation
Peurifoy, R.L. 1970. Construction Planning,
Equipment and Methods. 2nd Ed., McGraw-Hill,
NY. (Somewhat dated but a good overview of
solids handling equipment.)
Gas Collection
Argonne National Laboratory. Feb. 1982.
Environmental Impacts of Sanitary Landfills and
Associated Gas Recovery Systems. (ANL/CNSV-
27), Argonne National Laboratory, Argonne, IL.
Emcon Associates. 1980. Methane Generation and
Recovery From Landfills. Science Publishers, Ann
Arbor, Ml.
Landfill Methane Recovery. 1983. Energy Technology
Review #80. Noyes Data Corp.
Tchobanoglous, Theisen, and Eliassen. 1977. Solid
Wastes - Engineering Principals and
Management Issues. McGraw-Hill, NY.
D-5
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Groundwater Collection/Pumping
Bureau of Reclamation. 1978. Drainage Manual. U.S.
GPO, Washington, DC, 286 pp.
Bureau of Reclamation. 1981. Groundwater Manual.
2nd Ed., U.S. GPO, Washington, DC, 480 pp.
Freeze, et al. 1979. Groundwater. Prentice-Hall inc.,
Englewood Cliffs, NJ.
Johnson Division, UOP, Inc. 1975. Groundwater and
Wells. Johnson Division, UOP, Inc., Saint Paul,
MN.
U.S. Army. 1971. Dewatering: Groundwater Control
for Deep Excavations. Technical Manual No. 5
818-5, Prepared by the Army Engineers
Waterways Experiment Station.
U.S. Department of Agriculture. 1971. Section 16,
Drainage of Agricultural Land. In SCS National
Engineering Handbook. Engineering Division Soil
Conservation Service, Washington, DC.
U.S. EPA. June 1982. Handbook for Remedial Action
at Waste Disposal Sites (Revised). EPA-625/6-
85/006, Prepared by Hazardous Waste Engineering
Research Laboratory, Cincinnati, OH.
U.S. EPA. RCRA Groundwater Monitoring Technical
Enforcement Guidance Document (TEGD).
IV. Disposal Technologies
Atmospheric Discharge
GCA Corp. Dec. 1984. Evaluation and Selection of
Models for Estimating Air Emissions from
Hazardous Waste Treatment, Storage and
Disposal Facilities. EPS-450/3-84-020.
Kohl, A., and F. Riesenfeld. 1979. Gas Purification,
3rd Ed. Gulf Publishing Co.
Vogel, G. May 1985. Air Emission Control at
Hazardous Waste Management Facilities. Journal
of the Air Pollution Control Association, May 1985.
Wastewater Discharge
Florida Department of Environmental Regulation. April
1981. Class V Injection Well Inventory.
U.S. EPA. Dec. 1977. An Introduction to the
Technology of Subsurface Wastewater Injection.
EPA-600/2-77-240. Prepared for the U.S. EPA
by Don L. Warner, University of Missouri-Rolla
and Jay H. Lehr, National Water Well Association.
U.S. EPA. Sept. 1982. Fate of Priority Pollutants in
Publicly Owned Treatment Works. Volumes I and II,
EPA 440/1-82/303, U.S. EPA, Water and Waste
Management Series, Effluent Guidelines Division
WH-522.
U.S. EPA. July 1980. Treatability Manual, Volume
Treatability Data. EPA-600/8-80-042a, U.S.
EPA Research and Development Series.
Versar, Inc. Dec. 1979. Water-Related
Environmental Fate of 129 Priority Pollutants.
Volumes I and II, NTIS PB80-204381, Versar,
Inc., Springfield, VA. Prepared for U.S. EPA,
Washington, DC.
D-6
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Appendix E
Documentation of ARARs
The accompanying table presents a suggested format
for summarizing the identification and documentation
of ARARs in the RI/FS process. This format assumes
that two previous ARARs identification steps have
taken place during the RI/FS. First, it assumes that a
list of Federal and State ARARs has been developed
through consultations between the lead and support
agencies. This list should include chemical-,
location-, and action-specific requirements and, in
the case of multiple ARARs (e.g., both a Federal and
State requirement for a particular chemical), the
ARAR to be used for the site or alternative (generally
the more stringent) should be specified. Second, it
assumes that the key requirements and the reasons
for their applicability or relevance and appropriateness
have been integrated into the narrative descriptions of
each alternative as part of the "Detailed Analysis"
chapter in the FS report. This appendix, therefore,
serves as a summary of the ARARs for each
alternative and indicates whether the alternative is
anticipated to meet those ARARs, or, if not, what type
of waiver would be justified.
The suggested format for the documentation of
ARARs is presented here in the form of an example.
The example is intended for illustrative purposes only;
the ARARs identified for the sample alternatives may
not be appropriate in a specific site situation.
The site in the example was a battery and cleaning
solution storage facility operated and closed prior to
the effective date of the RCRA hazardous waste
storage regulations. The site is also located in a
floodplain. The site consists of two areas of
contaminated soil: Area 1 is contaminated with lead;
Area 2 is contaminated with TCE. There is also a
ground water plume associated with the site that
contains levels of TCE as high as 100 ppb and lead
as high as 500 ppb. The alternatives evaluated in
detail for the site are:
• Alternative 1 - No action
• Alternative 2 - Capping of the contaminated soil;
natural attenuation of the ground water
• Alternative 3 - In situ soil vapor extraction of the
TCE-contaminated soil; capping of the lead-
contaminated soil; ground water pump/treat with
offsite discharge to a nearby creek
• Alternative 4 - In situ soil vapor extraction of the
TCE-contaminated soil; in situ fixation of the
lead-contaminated area, followed by a soil cap;
ground water pump/treat with offsite discharge to
a nearby creek
• Alternative 5 - Incineration of the TCE-
contaminated soil; offsite disposal of
nonhazardous ash in the Subtitle D facility; in situ
fixation of the lead-contaminated soil, followed
by a soil cap; ground water pump/treat with off
site discharge to a nearby creek
For this example, it has been assumed that the TCE
is not an RCRA-listed or characteristic waste but that
the lead-contaminated area is hazardous because of
its characteristic of EP toxicity. Following in-situ
fixation, the lead-contaminated soil is anticipated to
be nonhazardous. Because none of the alternatives
involves the placement of RCRA hazardous waste
(lead-contaminated soil), the land disposal
restrictions are assumed to be neither applicable nor
relevant and appropriate.
The example also assumes that post-closure care
requirements of RCRA (e.g., ground water
monitoring) will generally be relevant and appropriate
wherever closure is performed with waste in place.
Finally, it is also assumed that the RCRA location
standards, while not applicable because none of the
alternatives involve RCRA-regulated treatment,
storage, or disposal, are nonetheless relevant and
appropriate to all the action alternatives. Typically, the
rationale for determinations of applicability or
relevance and appropriateness will be integrated into
the description of alternatives in the detailed analysis
of the FS report.
The following table identifies the applicable or relevant
and appropriate requirements for each of the five
alternatives, indicates whether the alternative is
expected to achieve that standard, and notes any
ARAR waivers that may be required-
E- 1
-------
Table E-1. Documentation of ARABS
Chemical-Specific
TCE
m
Lead
Alternative 1
No Action
5 ppb Federal MCL will
not be achieved in
ground water; no
waiver is justified
Neither 50 ppb Federal
MCL nor State standard
of 20 ppb will be
achieved in ground
water; no waiver is
justified
Alternative 2
Cap
Natural Attenuation
5 ppb Federal MCL
will be met in
30 years
50 ppb Federal MCL
will be met in
30 years; State
standard of 20 ppb
will not be net;
technical
impracticability
waiver justified
Alternative 3
In Situ SVE of TCE, Cap
Lead Area, CW Pump/Treat
5 ppb Federal MCL will
be met in 10 years
50 ppb Federal MCL
will be met in
10 years; State Stan-
dard of 20 ppb will
not be met; technical
impracticability
waiver justified
Alternative 4
In Situ
SVE of TCE, In Situ
Fixation, Cap of Lead
Area, GH Pump/Treat
See Alternative 3
See Alternative 3
Alternative 5
Incineration
of TCE Soil/Offsite
Disposal of Ash, In Si
Fixation, Cap of Lead
Area, (J> Pump/Treat
See Alternative 3
See Alternative 3
-------
Table E-1. Continued
Location-Specific
I. RCRA location of TSD
facility in 100-year
floodplain
(40 CFR 264.18)
Alternative 1
No Action
Alternative 2
Cap
Natural Attenuation
Will meet
Alternative 3
In Situ SVE of TCF, Cap
Lead Area, GH Pump/Treat
See Alternative 2
Alternative 4
In Situ
SVE of TCE, In Situ
Fixation, Cap of Lead
Area, GH Pump/Treat
See Alternative 2
Alternative 5
Incineration
of TCE Soll/Offsite
Disposal of Ash, In Situ
Fixation, Cap of Lead
Area, GH Pump/Treat
See Alternative 2
m II. Executive Order 11988
^ (Floodplain Management)
Evaluate potential
effects of actions,
avoid adverse impacts
to the extent possible
(40 CFR 6, Appendix A)
III. State siting standard
for new incinerators
Hill meet
See Alternative 2
See Alternative 2
See Alternative 2
Hill meet substantive
requirements of
incinerator standards
-------
Table E-1. Continued
Action-Specific
Alternative 1
No Action
Alternative 2
Cap
Alternative 4
In Situ
Alternative 3 SVE of TCE, In Situ
In Situ SVE of TCE, Cap Fixation, Cap of Lead
Natural Attenuation Lead Area, GH Pump/Treat Area, OH Pump/Treat
Alternative 5
Incineration
of TCE Soil/Offsite
Disposal of Ash, In Situ
Fixation, Cap of Lead
Area, GH Pump/Treat
I. Resource Conservation
and Recovery Act (RCRA)
as amended by Hazardous
and Solid Haste Amendments
(HSHA) (42 USCA 7401-7642)
m
A. Closure and Post-Closure
1. Clean Closure
(40 CTR 264.111)
Hill meet in Area 2
(TCE area)
Hill meet in Area 2
(TCE area)
Hill Meet in Area 2
(TCE area)
2. Closure Hith Haste
in Place (capping)
(40 CFR 264.228)
Hill not meet; no
waiver Is justified
Hill meet
3. Post-Closure Care
(40 CFR 264.310)
Hill not meet; no
waiver is justified
Hill meet
B. Incineration
(40 CFR 264.340-345)
Performance stan-
dards will be
met by onsite
incinerator
-------
Table E-1. Continued
Action-Specific
C. Solid Haste Disposal
(40 CFR 241.200-212)
m
en
II. Clean Hater Act (CHA)
(33 USCA 1251 - 1376)
Alternative 1
No Action
Alternative 2
Cap
Alternative 4
In Situ
Alternative 3 SVE of TCE, In Situ
In Situ SVE of TCE, Cap Fixation, Cap of Lead
Natural Attenuation Lead Area, OH Pump/Treat Area, GH Pump/Treat
Hill meet In Area 1
See Alternative 3
Alternative 5
Incineration
of TCE Soil/Offsite
Disposal of Ash, In Situ
Fixation, Cap of Lead
Area, GH Pump/Treat
Non-hazardous residuals
from incineration of
TCE area will be dis-
posed in an offsite
Subtitle D facility;
fixed lead trill be
capped
A. National Pollutant
Discharge Elimination
System (NPDES)
(40 CFR 122 - 125)
Permit for offsite
discharge will be
obtained
See Alternative 3
See Alternative 3
B. Hater Quality
Standards
(CHA 402 (a)(D)
Compliance will occur
by meeting NPDES
limitations
See Alternative 3
See Alternative 3
-------
Appendix F
Case Example of Detailed Analysis
Introduction
Purpose
This appendix provides an example of how the results
of the individual and comparative analyses of remedial
alternatives may be presented in the FS report. As
discussed in Chapter 6 of this guidance, the individual
analysis consists of a narrative description of the
alternative including a discussion of how the
alternative performs with respect to each of the
evaluation criteria1 The comparative analysis that
follows the individual analysis consists of a narrative
discussion summarizing the relative performance of
the alternatives in relation to one another.
The amount of information presented in a detailed
analysis will depend on the complexity of the site and
on the extent of investigations and analysis
conducted. In addition, as noted in Chapter 6, the
level of detail and extent of discussion for the
individual subfactors under each criterion will vary
based on the relevance of that particular criterion to
the alternatives being considered and the scope of
the action being taken. Therefore, the amount of
detail required to adequately document the results of
the evaluations and the specific subfactors that will
actually be discussed may differ somewhat from that
presented in this case example.
The reader should also keep in mind that an actual
RI/FS report will typically include maps, plans,
schematics, and cost details that would be presented
in previous chapters of the report (e.g., Development
and Screening of Alternatives) or in the detailed
analysis chapter itself. The purpose of this particular
example is to give readers an idea of the types of
information that should be provided when describing
individual alternatives and discussing their
performance against the evaluation criteria.
'The criteria are discussed in the following order: overall
protection of human health and the environment; compliance
with ARARs; long-term effectiveness and permanence;
reduction of toxicity, mobility, or volume through treatment;
short-term effectiveness; implementability; and cost.
Community and state acceptance will generally not be
addressed until the ROD, following receipt of formal comments
on the RI/FS report and the proposed plan.
Site Background
The site used in this example is an old battery and
cleaning solution storage facility located in a rural
area. Improper handling and storage activities at this
site from 1968 to 1978 resulted in both soil and
ground water contamination. The area of
contamination referred to as Area 1 contains 25,000
cubic yards (cy) of contaminated soil with
concentrations of lead exceeding 200 mg/kg
(concentrations of lead reach 500 mg/kg at several
locations within this area). There is also a discrete
area of approximately 20,000 cy of TCE-contami-
nated soil at the site referred to as Area 2. Analysis of
soil samples from this area show TCE concentrations
up to 6 percent and slightly elevated levels of metals
compared to background. Although the risk
assessment did not identify a human health or
environmental risk from these metals, there is a small
possibility that hot spots of metal contamination may
have been missed. The soils of both Areas 1 and 2
are fairly permeable. Figure F-l presents a simplistic
map of the site.
The affected aquifer is shallow, with the water table
lying approximately 12 feet under the site, and is
currently used for drinking water. This aquifer has the
characteristics of a Class IIA aquifer as defined under
U.S. EPA's Ground Water Classification System. The
aquifer consists of fractured bedrock, making ground
water containment technologies difficult to implement.
Ground water extraction may also be difficult due to
the fractured bedrock. A plume of TCE above the 5
mg/l Maximum Contaminant Level (MCL) (measured
as high as 50 ppm) is estimated to be moving in the
direction of residential wells at an interstitial velocity
of 65 ft/yr. The nearest residential well is 600 feet
from the site boundary and the plume of
contaminated ground water is likely to reach the well
in an estimated 1 to 3 years at concentrations
exceeding federal drinking water standards. Sampling
conducted during the Rl shows that no existing
residential wells are currently contaminated.
The exposure pathways of concern identified during
the baseline risk assessment include direct contact
with possible ingestion of contaminated soil (1 x
1 O3associated excess cancer risk), and potential
ingestion of contaminated ground water in the future
F-1
-------
200
400
Scale
*
CE - Contaminated Soil
Areal
(Lead - Contaminated Soil)
Approximate
Location of
Ground water
Contaminated
Above MCLs
County Road
Residential Well
Residential Well
Figure F-1. Site map case example.
through existing or newly installed offsite wells (2 x
1 O2 associated excess cancer risk). The MCL for
TCE (5 ng/l)) has been determined to be a relevant
and appropriate remediation level for the
contaminated ground water at this site since the
ground water is used for drinking water. Based on the
site-specific risk assessment, the MCL was
determined to be sufficiently protective as the aquifer
remediation goal.
The risk assessment also concluded that 200 mg/kg
for lead in soil would be a protective level for
expected site exposures along with a 1 x 1 O6
F-2
-------
excess cancer risk level for TCE-contaminated soil
(56 ppm). Based on investigations of activities at the
site, the TCE-contaminated soil has not been
determined to be a listed, RCRA hazardous waste
since the cleaning solution records indicate the
solutions contained less than 10 percent TCE.
However, the lead-contaminated soil is an RCRA
hazardous waste by characteristic in this instance due
to EP-toxicity. None of the waste is believed to have
been disposed at the site after November 19, 1980
(the effective date for most of the RCRA treatment,
storage, and disposal requirements).
The site is located in a state with an authorized
RCRA program for closure which subsumes Federal
requirements and specifies more stringent state
requirements. Therefore, only the state closure
requirements need to be analyzed for potential
applicability or relevance and appropriateness to the
remedial alternatives considered. No potential
location-specific ARARs have been identified for this
site.2 Additionally, this example assumes that EPA
and the State have agreed upon what non-ARAR
information (i.e., guidance, advisories) is to be
considered in designing the remedial alternatives.
Detailed Analysis - Case Example
Individual Analysis of Alternatives
The assembled remedial action alternatives represent
a range of distinct waste management strategies
which address the human health and environmental
concerns associated with the site. Although the
selected alternative will be further refined as
necessary during the predesign phase, the
description of the alternatives and the analysis with
respect to the nine criteria presented below reflect
the fundamental components of the various
alternative hazardous waste management approaches
being considered for this site.
The primary components of each alternative are listed
in Figure F-2 and a technical description of these
components is presented. After the technical
description, a discussion of the alternative with
respect to overall protection of human health and the
environment; compliance with ARARs; long-term
effectiveness and permanence; reduction of toxicity,
mobility, or volume through treatment; short-term
effectiveness; implementability; and cost follows.
The analysis of each alternative with respect to
overall protection of human health and the
environment provides a summary evaluation of how
2 Determinations of what standards/requirements are applicable
or relevant and appropriate are made on a site-specific basis
and, in some cases, on an alternative-specific basis.
Therefore, the ARAR determinations in this example should
not be construed necessarily as appropriate rationales for such
determinations at other sites.
the alternative reduces the risk from potential
exposure pathways through treatment, engineering, or
institutional controls. This evaluation also examines
whether alternatives pose any unacceptable short-
term or cross-media impacts.
The major Federal and State requirements that are
applicable or relevant and appropriate to each
alternative are identified. The ability of each
alternative to meet all of its respective ARARs or the
need to justify a waiver is noted for each.
Long-term effectiveness and permanence are
evaluated with respect to the magnitude of residual
risk and the adequacy and reliability of controls used
to manage remaining waste (untreated waste and
treatment residuals) over the long-term. Alternatives
that afford the highest degrees of long-term
effectiveness and permanence are those that leave
little or no waste remaining at the site such that
long-term maintenance and monitoring are
unnecessary and reliance on institutional controls is
minimized.
The discussion on the reduction of toxicity, mobility,
or volume through treatment addresses the
anticipated performance of the treatment technologies
a remedy may employ. This evaluation relates to the
statutory preference for selecting a remedial action
that employs treatment to reduce the toxicity,
mobility, or volume of hazardous substances. Aspects
of this criterion include the amount of waste treated
or destroyed, the reduction in toxicity, mobility, or
volume, the irreversibility of the treatment process,
and the type and quantity of residuals resulting from
any treatment process.
Evaluation of alternatives with respect to short-term
effectiveness takes into account protection of workers
and the community during the remedial action,
environmental impacts from implementing the action,
and the time required to achieve cleanup goals.
The analysis of implementability deals with the
technical and administrative feasibility of implementing
the alternatives as well as the availability of necessary
goods and services. This criterion includes such
items as: the ability to construct and operate
components of the alternatives; the ability to obtain
services, capacities, equipment, and specialists; the
ability to monitor the performance and effectiveness
of technologies; and the ability to obtain necessary
approvals from other agencies.
The cost estimates presented in this report are
order-of-magnitude level estimates. These costs
are based on a variety of information including quotes
from suppliers in the area of the site, generic unit
costs, vendor information, conventional cost
estimating guides, and prior experience. The
feasibility study level cost estimates shown have been
F-3
-------
Alternative
34
Ground Water
Monitoring
Natural Attenuation
Extraction Wells
Onsite Air Stripping
Soil
Soil/Clay Cap (Area 1)
Soil/Clay Cap (Area 2)
Fixation (Area 1)
Soil Vapor Extraction (Area 2)
Onsite Incineration (Area 2)
N
O
A
C
T
I
O
N
Others
Institutional Controls
Road Reconstruction
Fence
•
•
Figure F-2. Alternative components case example.
prepared for guidance in project evaluation and
implementation from the information available at the
time of the estimate. The actual costs of the project
will depend on true labor and material costs, actual
site conditions, competitive market conditions, final
project scope, the implementation schedule, and
other variable factors. A significant uncertainty that
would affect the cost is the actual volumes of
contaminated soil and ground water. Most of these
uncertainties would affect all of the costs presented in
this FS similarly.
Capital costs include those expenditures required to
implement a remedial action. Both direct and indirect
costs are considered in the development of capital
cost estimates. Direct costs include construction
costs or expenditures for equipment, labor, and
materials required to implement a remedial action.
Indirect costs include those associated with
engineering, permitting (as required), construction
management, and other services necessary to carry
out a remedial action.
Annual O&M costs, which include operation labor,
maintenance materials, and labor, energy, and
purchased services, have also been determined. The
estimates include those O&M costs that may be
incurred even after the initial remedial activity is
complete. The present worth costs have been
determined for 30 years at a 5 percent discount rate.
Alternative 1 - No Action
The no-action alternative provides a baseline for
comparing other alternatives. Because no remedial
activities would be implemented with the no-action
alternative, long-term human health and
environmental risks for the site essentially would be
the same as those identified in the baseline risk
assessment.
Criteria Assessment
Alternative 1 provides no control of exposure to the
contaminated soil and no reduction in risk to human
health posed through the ground water. It also allows
for the possible continued migration of the
contaminant plume and further degradation of the
ground water.
F-4
-------
Because no action is being taken, it would not meet
any applicable or relevant and appropriate
requirements such as the MCL for TCE.
This alternative includes no controls for exposure and
no long-term management measures. All current
and potential future risks would remain under this
alternative.
This alternative provides no reduction in toxicity,
mobility, or volume of the contaminated soil or ground
water through treatment.
There would be no additional risks posed to the
community, the workers, or the environment as a
result of this alternative being implemented.
There are no implementability concerns posed by this
remedy since no action would be taken.
The present worth cost and capital cost of Alternative
1 are estimated to be $0 since there would be no
action.
Alternative 2-5: Common Components
All of the remaining alternatives have four
components in common (use of institutional controls,
reconstruction of access road, erection of a fence
around the site, and ground water monitoring).
Although the description of these components is not
repeated in the discussions for each alternative,
differences in their planned implementation are
identified where appropriate.
• Institutional controls: The current owner has
agreed to allow the state to place a deed
restriction on the site which would prohibit soil
excavation and construction of buildings on any
part of the site still containing hazardous materials
upon completion of the remedy.3 In addition, a
local ground water well regulation requiring state
review of all installation plans for ground water
wells would be used to prohibit the installation of
drinking water supply wells in contaminated parts
of the aquifer.
• Road reconstruction: Some of the road on the
site (primarily near Area 2) would be restabilized
and improved to allow construction activities and
the movement of materials.
• Fencing: Approximately 1,600 feet of fencing
would be installed around the perimeter of the site
to restrict public access. Signs warning of the
presence and potential danger of hazardous
materials would be posted on the fence to further
discourage unauthorized access to the site.
3 The legal authority to implement deed restrictions will vary from
state to state. Therefore, a key factor to consider during the
evaluation of institutional controls is whether a particular state
can actually impose restrictions on specific activities or
whether their authorities are limited to nonenforceable actions
such as deed notices.
• Ground water monitoring: Two new monitoring
wells would be installed offsite. Analytical results
from the new wells, some of the existing wells,
and the residential wells would be used to monitor
future conditions and to assess the effectiveness
of the final action. Sampling would be conducted
quarterly with four replicate samples at each well.
The samples would be analyzed for volatiles and
metals and results compared to background
values using the Student's T-test. If the mean
value of any compound at any facility boundary
well is greater than background at the 0.05
significance level in two successive sampling
rounds, appropriate investigative and remedial
action(s) would be initiated as necessary.
Alternative 2 - Cap and Natural Attenuation
The primary components of Alternative 2 are capping
of Areas 1 and 2 and natural attenuation of the
contaminated ground water. Two caps would be
installed, a 3-acre cap over Area 1 (lead-
contaminated soil) and a 3-acre cap over Area 2
(TCE-contaminated soil). The cap would be
consistent with the State RCRA landfill closure
requirements. While these requirements are not
applicable since the action does not involve the
disposal of any RCRA hazardous waste, certain
closure requirements have nevertheless been
determined to be relevant and appropriate to this
alternative. The State's RCRA requirements are more
specific and stringent than the Federal requirements,
which require a cap to have a permeability less than
or equal to the permeability of natural underlying soil.
The soil/clay caps would include a 2-foot thick
compacted clay barrier layer with a permeability not to
exceed 107cm/sec, a geonet drainage layer, and a
cover layer equal to the average frost level
(approximately 3.5 feet) above the barrier layer. This
cover layer would include 6 inches of topsoil and 3
feet of compacted native soil materials. The drainage
layer and the extra frost protection depth are
necessary because the rainfall rate would exceed
surface runoff and evaporation rates, and the average
frost depth (3.5 feet) is greater than the minimum 2
feet of cover recommended by U.S. EPA.
A geonet drainage layer was chosen for this
alternative since the Hydrologic Evaluation of Landfill
Performance (HELP) model showed it to be more
effective than sand in controlling leachate production
but it is comparable in cost. The HELP model
predicted a 75 to 80 percent reduction in leachate
production. Geotextile layers would be laid on either
side of the geonet drain to prevent clogging. A
minimum slope of 3 percent would be provided to
meet state requirements. To achieve this slope, it is
estimated that 4,000 cy of backfill material from
elsewhere on the site would have to be placed prior
to cap construction.
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To determine the effect of natural attenuation on the
contaminated ground water, two assumptions about
the subsurface have been made. First, despite the
fractured nature of the bedrock, it has been assumed
that the subsurface is homogeneous to facilitate the
evaluation. Second, the potential for reduction in TCE
concentrations has been assessed using a
hydrogeologic model. The model took into account
the fact that the cap would reduce existing leachate
production by 75 percent. This model predicted that
the concentration of TCE in the ground water would
be reduced to a 1 x 10"excess cancer risk level
(280 pg/l) at the edge of the contaminated soil areas
within 35 years, a 1 x 105excess cancer risk level
(28 pg/l) in 60 years, and a 1 x 106excess cancer
risk level (2.8 pig/I, approximately equal to the MCL) in
approximately 100 years.
An alternate water supply would be included in this
alternative to provide a safe and reliable source of
drinking water until levels in the aquifer reached
acceptable levels. The alternate system would consist
of two new community wells4 installed upgradient of
the contamination, 1,000 to 2,000 feet from the site
and a water main along the county road to feeder
pipes for each resident. The required pumping
capacity is estimated to be 100 gpm and the wells
would provide water for the four residents located
closest to the site, downgradient of the contaminated
plume. The well water would be monitored for TCE
and lead as part of the site-wide monitoring plan on
a semiannual basis until the MCL levels are met and
then thereafter consistent with the relevant and
appropriate aspects of the RCRA post-closure care
program.
Criteria Assessment
Although protective of human health since exposure
to all contamination would be controlled, Alternative 2
would allow continued migration of the existing
contaminated ground water. It would prevent
exposure to the contaminated soil and would
minimize further release of contaminants to the
ground water by limiting future infiltration through the
cap.
This alternative would control exposure to the
contaminated ground water through provision of an
alternate supply of drinking water and deed
restrictions until the MCL for TCE is eventually
reached. The ground water may require up to 100
years of natural attenuation to reach the chemical-
specific ARAR of 5 pg/l of TCE at the edge of the
contaminated soil. Landfill closure requirements are
not applicable to this alternative since the planned
actions do not involve the disposal of any RCRA
4 The actual location of these wells would be determined during
predesign activities.
hazardous waste; however, certain landfill closure
requirements have been determined to be relevant
and appropriate. This alternative would meet the
RCRA landfill closure requirements by constructing a
soil/clay cap that meets the State RCRA standards,
and the guidance specifications that the lead and
support agencies have agreed are to be considered
(TBC).
In order for this alternative to remain effective over
the long-term, careful maintenance of the alternate
water supply through monitoring and periodic repair of
pipes and pumps and careful maintenance of a
healthy vegetative layer over the caps would be
required. Any erosional damage of the caps would
have to be repaired. Failure to address reduction in
the cap's impermeability could result in increased
leachate production, subsequent ground water
contamination, and the potential for direct contact
with the contaminated soil. Because the contaminated
soil would remain onsite and because the ground
water may remain contaminated above health-based
levels for 100 years, long-term monitoring,
maintenance, and control would be required under
this alternative. An alternate water supply and
institutional controls would be used to limit risk to
present and potential future users of the
contaminated ground water. The institutional controls
would only be effective with a high degree of certainty
in the short term, not over the long term; once all
design and construction activities are complete. The
local municipality cannot ensure the enforceability of
the local water use regulation beyond a few years.
Because this alternative would leave hazardous
substances onsite, a review would be conducted at
least every 5 years to ensure that the remedy
continues to provide adequate protection of human
health and the environment in accordance with
CERCLA 121 (c).
This alternative would provide no reduction in the
toxicity, mobility, or volume of the contaminated soil
or ground water through treatment. The 20,000 cy of
TCE-contaminated soil and 25,000 cy of lead-
contaminated soil would remain onsite.
Within an estimated 6 months of beginning
construction, the caps and the alternate water supply
would be installed preventing direct exposure and
reducing ground water contaminant migration.
Provision of the alternate water supply would alleviate
the risk from ingestion of contaminated ground water.
The potential for a slight, temporary increase of risk
to the community (and workers) due to particulate
emissions during construction of the caps would be
controlled through the use of dust control
technologies (e.g., water or foam sprays).
No special techniques, materials, permits, or labor
would be required to construct either the wells or
caps. The native soil and clay are available locally,
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within 20 miles of the site. About 50,000 cy of soil
and clay would be needed to construct the caps. The
action could be enhanced by enlarging the caps if
more contamination were discovered and by
expanding the alternate water supply if more residents
were affected than originally estimated.
The 30-year present worth cost of this alternative is
estimated to be $4,800,000, with a capital cost of
$4,200,000 and an annual O&M cost of $60,000.
The capital cost is primarily for the installation of the
caps. The annual O&M costs are primarily for the
ground water monitoring program and for maintaining
the caps.
Alternative 3 - In Situ Soil Vapor Extraction, Cap,
Ground Water Pump and Treat
This alternative consists of capping Area 1 (lead-
contaminated soil) with the same soil/clay cap as
described in Alternative 2 (2 feet of clay underlying a
surface drainage layer and 3.5 feet of soil), using in
situ vapor extraction to treat the TCE-contaminated
soil in Area 2, extracting the ground water, and
treating it onsite through an air stripping system and
discharging it to a tributary of North Creek.
The soil vapor extraction technology involves
collection of soil vapor from the unsaturated zone by
applying a vacuum at a series of extraction points.
The vacuum not only draws vapor from the
unsaturated zone, but also decreases the pressure
around the soil particles, thereby releasing additional
volatiles. In addition, due to the pressure differential,
clean air from the atmosphere enters the soil to
replace the extracted air.
Pilot tests conducted during the Rl showed vapor
extraction to be a feasible and effective technology
for removing TCE from the soil at this site. It is
anticipated that the TCE can be removed to 56 ppm
which is the 1 x 106risk level for the direct
contact exposure route within 3 to 5 years. This
represents a 99.9 percent reduction in the
concentration. To provide flexibility of operation, the
contaminated area would be divided into two discrete
areas, each with its own vapor extraction system. The
major components of each vapor extraction system
would include: 20 extraction wells, the necessary
piping and valves, and a positive displacement blower
(vacuum pump). The air discharged would be sent
through two activated carbon units and the carbon
would be regenerated for reuse.
Because the evacuation and collection of volatiles
would be through a vacuum system, volatile
contaminants would be controlled as a single point
emission. The potential for fugitive losses of air
contaminants would be minimal.
A ground water extraction scenario consisting of five
wells at a combined pumping rate of 300 gpm was
selected after a series of numerical simulations with a
variety of well arrangements. This arrangement was
found to provide more rapid restoration of the shallow
aquifer than other arrangements evaluated (see
Chapter # of the FS). The three onsite extraction
wells would be located within the TCE plume but
downgradient of its center. They would reverse the
natural ground water flow direction offsite
immediately, so the contaminants would not migrate
further than their existing location. The residential
wells should not be contaminated in the future.
Because it was determined that the pumping rate
should not depress the ground water table more than
10 feet, not all of the plume could be captured by the
onsite wells. Two offsite wells would be used to
remediate the area of the offsite contaminated
aquifer.
The ground water model simulation for this scenario
assumed that the soil remedial action would include
treatment of the TCE-contaminated soil to levels
indicated above, and that the lead-contaminated soil
would be capped. The simulation indicated that the
shallow aquifer could be restored to 5 mg/l (MCL) in
25 to 40 years. Without soil remediation, from 60 to
100 years would be required. Monitoring would be
used to determine when the ground water cleanup
goal of 5 pg/l had been reached at the boundaries of
the waste management area and to evaluate the
effectiveness of the alternative.
To treat the extracted ground water, an air stripper
would be constructed on the site. The air stripper
would be a counter-current packed tower, where air
enters at the bottom and exhausts at the top while the
ground water flows down through the media. The air
stripper would be approximately 45 feet tall and 4 feet
in diameter and would be designed to meet the
performance goal of 5 mg/l TCE concentrations. The
exhaust air would be discharged through carbon beds
to collect the volatiles by adsorption. The carbon
would be sent offsite for regeneration upon bed
exhaustion. Because little iron or other metals are in
the ground water, no pretreatment to prevent fouling
of the air stripper would be required.
Upon completion of ground water treatment, the water
would be discharged offsite to the nearby tributary of
North Creek. An NPDES permit would be obtained
before implementation.
Criteria Assessment
This alternative would protect both human health and
the environment. Soil vapor extraction and the cap
over the contaminated soil would reduce risk to
human health by direct contact and soil ingestion.
Ground water extraction and onsite treatment would
reduce the threat to human health by ingestion of
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contaminated ground water, and reduce the possibility
of further environmental degradation.
This alternative would meet the MCL for TCE. To
meet action-specific ARARs, the air treatment
systems for this alternative would be designed to
meet State air pollution control standards. Preliminary
analysis also indicates that the ground water
treatment system can be designed to meet State
NPDES limitations which will result in no
exceedances of the Water Quality Standards in the
creek. Because the treatment of the TCE-
contaminated soil would be conducted entirely in situ
and the TCE is not a listed, RCRA hazardous waste,
placement of RCRA hazardous waste would not
occur and the land disposal restrictions would not be
applicable nor relevant and appropriate. The cap
constructed over Area 1 would meet the State RCRA
requirements for landfill closure as under Alternative
2.
To provide for long-term effectiveness of this
alternative, careful maintenance of the controls would
be needed. As discussed for Alternative 2, the
alternate water supply and cap would require
maintenance. Further ground water contamination is
reduced by removal of TCE through soil vapor
extraction. Because lead is not expected to migrate
rapidly, failure of the cap would increase the potential
risk through direct contact but pose little or no
concern for further ground water contamination.
Human health risks posed by ingestion of ground
water in the future would be reduced to less than
5 ng/l by the pump and treat systems. However,
because of the fractured nature of the bedrock, the
ability of the pump and treat system to effectively
reach the cleanup goal is somewhat uncertain. To
determine its long-term effectiveness and to lessen
the uncertainty of reaching cleanup goals, the ground
water pump and treat systems would be monitored
under a long-term program. Necessary modifications
to either system would be made based on monitoring
results. The area treated by soil vapor extraction
would not require any additional maintenance or
monitoring upon completion of the technology. This
alternative also would require a 5-year review.
Vapor extraction is an irreversible treatment process
that would reduce the toxicity of contaminated soil by
removing over 99.9 percent of TCE from 20,000 cy of
soil. The TCE would be collected on carbon.5The air
stripper would also reduce the toxicity and mobility of
TCE in the ground water. Contaminants in the air
stream would be collected on carbon and destroyed
during regeneration making this ground water
treatment component irreversible. This alternative
would leave 25,000 cy of untreated lead-
TCE would be destroyed by incineration when the carbon is
regenerated.
contaminated soil onsite under a soil/clay cap. This
alternative meets the statutory preference for using
treatment as a principal element since the principal
threats are addressed through treatment.
During operation of the vapor extraction system, the
contaminated soil would remain uncovered, although
the fence to be installed around the site would
discourage trespassers and limit potential exposure.
Although unlikely, the possibility of a small additional
risk through inhalation to the community would exist if
the extracted air collection system were to fail. As
with the soil vapor extraction system, there is the
slight additional risk of failure of the air collection
system on the air stripper. Safety techniques
including monitoring the equipment would be used to
minimize any failures of the components. Once the
extraction and treatment systems are installed, the
contaminant plume would begin to recede from its
current position. Between 25 and 40 years would be
required to reach ground water remediation goals,
and 3 to 5 years of soil vapor extraction would be
required to reach soil remediation goals.
This alternative involves the use of proven
technologies. The cap requires 25,000 cy of soil and
clay to be brought to the site, placed, and graded to
construct the cap. The onsite air stripper and both
gaseous carbon adsorption systems require available
equipment. Operation of the alternative would require
frequent monitoring of the ground water and the air to
assess the effectiveness of the soil vapor extraction
and ground water extraction and treatment systems.
Controlling operating conditions would be necessary
to improve the effectiveness of these systems. Soil
vapor extraction uses reliable equipment. Engineering
judgment would be required during operation to
determine the operating parameters of the alternative,
such as air flow rate in the air stripper, the blower
speed in the vapor extraction system, and TCE in the
exhaust gas. All of the components could be
expanded if additional contamination were discovered.
The 30-year present worth cost is estimated to be
$7,300,000 with a projected $3,300,000 for capital
expenditures and $440,000 for year 1 annual O&M
costs. The most expensive item is the soil/clay cap
followed by the ground water treatment system. The
O&M costs would cover operating the soil and ground
water treatment systems from year 1 to 5. After year
5 the O&M costs would drop to approximately
$200,000 to continue ground water treatment and
monitoring.
Alternative 4 - In Situ Soil Vapor Extraction, In
Situ Soil Fixation, Cap, and Ground Water Pump
and Treat
This alternative includes in situ soil vapor extraction of
TCE-contaminated soil (Area 2), in situ soil fixation
of lead-contaminated soil (Area 1), cap (Area 1), and
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ground water pump and treat components of
Alternative 3.
The moisture content of the soil has been determined
to be approximately 50 percent under worst case
conditions. Using this information and results from
vendor tests, it has been determined that a minimum
dose of one part solidification reagent to two parts soil
is required for migration control of lead. Testing has
shown that the optimum solidification reagent mixture
would consist of approximately 50 percent fly ash and
50 percent kiln dust. Thus, approximately 7,000 tons
each of fly ash and cement kiln dust would be
required. The reagents would be added in situ with a
backhoe. As one area of the soil is fixed, the
equipment could be moved onto the fixed soil to
blend the next section. It is anticipated that the soil
volume would expand approximately 20 percent due
to the fixation process. This additional volume would
be used to achieve the needed slope for the cap. An
RCRA soil/clay cap placed over the solidified material
is necessary to prevent infiltration and additional
hydraulic stress on the fixed soil. It is estimated that
the fixation would reduce lead migration by 40
percent and that the fixed soil would pass the EPTox
levels for lead.
Criteria Assessment
This alternative would protect human health and the
environment. This alternative protects against direct
contact with contaminated soil and further ground
water degradation by treating part of the soil and
fixing and capping the remaining soil. It protects
against ingestion of contaminated ground water by
collecting and treating the affected aquifer to health-
based levels.
This alternative meets the MCL for TCE and action-
specific ARARs such as air and water discharge
limits. As with Alternative 3, the land disposal
restrictions are not an ARAR for this alternative since
placement does not occur. The cap would meet State
RCRA requirements for landfill closure.
The long-term effectiveness of this alternative would
be enhanced by the application of treatment
technologies that reduce the inherent hazards posed
by the sources; all of the contaminated soil would be
treated or immobilized by fixation and the
contaminated ground water would also be extracted
and treated. Even in the unlikely event of cap failure
in Area 1, the fixed soil would pose little if any risk of
ground water contamination. The potential for cap
failure would be minimized through the maintenance
program. This alternative would also require a 5-year
review.
Soil vapor extraction and air stripping with gaseous
carbon adsorption are irreversible. Soil fixation would
reduce the mobility of lead by about 40 percent but
would increase the volume of contaminated soil from
25,000 cy to about 30,000 cy. Although this
technology is not completely irreversible, the
possibility exists that the contaminants could regain
some mobility should the cap fail. However, the risk
would be small. The residual soil remaining following
treatment would not pose a risk to human health or
the environment. This alternative satisfies the
statutory preference for using treatment as a principal
element since it addresses principal threats posed by
the site through treatment.
During the vapor extraction process, the
contaminated soil would be uncovered and the
potential exists for contaminant release into the air
(although the risk would be small due to the control
system that would be used). In situ soil fixation would
release some particulate matter into the atmosphere.
However, the fixation process would require only a
few months for implementation, lessening the
likelihood of any potential risk. Dust control methods
would be used to limit the release of particulate
matter.
Implementability information for the soil vapor
extraction system, the cap, and the ground water
pump and treat systems to be used for this
evaluation, is provided under Alternative 3. As for the
additional fixation process, vendors needed to fix the
soil are readily available. The necessary reagents are
available within 50 miles of the site. All of the
components could be expanded if additional
contamination was discovered.
The 30-year present worth cost of this alternative is
estimated to be $10,200,000. The primary cost items
are the cap, the ground water treatment system, and
the soil fixation of Area 2. The capital cost is
estimated to be $6,200,000, with an annual O&M
cost of $480,000 for the first 5 years. After year 5,
the O&M costs would decrease to $200,000 for
ground water treatment and monitoring.
Alternative 5 - Incineration, In Situ Soil Fixation,
Ground Water Pump and Treat
This alternative contains components of Alternatives 3
and 4 but introduces a thermal destruction
component to address the TCE-contaminated soil.
The lead-contaminated soil in Area 1 would be fixed
and covered with a soil/clay cap, as described in
Alternative 4. The ground water would be addressed
through pumping and treating, via an air stripper, as
described in Alternatives 3 and 4. The TCE-
contaminated soil in Area 2 would be excavated and
treated onsite by a thermal destruction unit.
For the purposes of this analysis, the thermal
destruction unit is assumed to be a rotary kiln unit.
The specific type of incineration would be determined
in the Remedial Design phase after competitive
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bidding has taken place. The incinerator would be
mobilized, operated, and closed according to the
specific requirements found in RCRA, Subpart O (40
CFR 264.340). The substantive requirements of the
permitting process, though not applicable because the
action does not involve RCRA-regulated hazardous
waste, have been determined to be relevant and
appropriate. A discussion of the ARARs associated
with the remediation of Area 1 and the ground water
can be found under Alternative 4.
It is estimated that approximately 20,000 cy of
contaminated soil would need to be excavated and
treated. The risk from the remaining soil would not
exceed 1 x 106excess cancer risk level as soil
containing TCE at concentrations greater than 56
ppm would be excavated. There are still some
uncertainties with this volume estimate so it would be
necessary to sample during excavation to determine
when sufficient material has been removed.
Incineration of soils contaminated with organic
compounds is a proven technology. Conservative
estimates about the organic and moisture contents
were made to develop the incineration component.
The incinerator would be operated continuously (24
hours/day, 365 days/year) in order to reduce the
thermal stress on the refractory, although some down
time would be required (20 percent) for regular
maintenance. Due to the need to maintain continuous
operation, a waste pile for the purpose of temporary
storage would be constructed in accordance with the
relevant and appropriate requirements of RCRA (40
CFR 264.251) which requires a liner and leachate
collection system. This storage would ensure
operation during periods of poor weather when
excavation may not be possible.
The incinerator would operate at a feed rate of 3.5
tons/hr. At this feed rate and assuming that about
20,000 cy of material would be excavated, more than
1 year would be required for incineration. About 30
gallons/hr of fuel oil would be required to run the
incinerator. It is assumed that the incinerator would
be operated to achieve 99.8 percent TCE removal
from the soil and a destruction efficiency as required
by RCRA. Specific operating practices to meet the
performance objectives, including 99.99 percent
destruction of stack emissions as dictated by Subpart
O of RCRA, would be determined through a trial burn
at the site after installation of the incinerator. Other
performance standards include hydrogen chloride
emissions not to exceed 1.8 kg/hr and particulate
matter emissions of less than 0.08 grains per day
standard cubic foot.
The facility would use a dry scrubber system for
emission control, which would almost eliminate the
need for wastewater treatment. Any water from
emission control and from decontamination
procedures would be treated in the onsite ground
water treatment system. The residual soil and
collected ash is assumed to be nonhazardous and
can be disposed of in a solid waste disposal facility in
compliance with Subtitle D of RCRA. In the event that
they cannot be delisted due to the presence of
metals, either residuals will be managed as part of the
closure of Area 2 (lead-contaminated soil).
Criteria Assessment
This alternative would be protective of human health
and the environment. The contaminated ground water
would be collected and treated, reducing further the
threat of ingesting contaminated ground water. The
risk from ingesting ground water would be lowered to
less than 1 x 106. The direct contact risk would be
reduced by fixing soil exceeding 200 pg/kg lead and
incinerating TCE-contaminated soil with an excess
cancer risk level greater than 1 x 106.
Although this alternative would involve the excavation
and placement of waste, thus making the land
disposal restrictions a potential ARAR, TCE-
contaminated soil at this site is not an RCRA
hazardous waste and therefore these requirements
would not be applicable. The U.S. EPA is undertaking
an LDR rulemaking that will specifically apply to soil
and debris. Until that rulemaking is completed, the
CERCLA program will not consider the land disposal
restrictions to be relevant and appropriate to soil and
debris that does not contain RCRA-restricted
wastes.
The long-term effectiveness of this alternative is
enhanced by the destruction of about half of the
contaminated soil by thermal destruction and
reduction in the mobility of contaminants in the other
half through fixation. The ground water pump and
treat component is also effective but would require
long-term management or monitoring and
maintenance. The area where soil is removed for
incineration would not require long-term monitoring
whereas the contaminated soil that is fixed would
remain under a cap and would require long-term
monitoring and maintenance. This alternative could be
enhanced to effectively control greater areas of
contamination or different contaminants (i.e., possible
metals in Area 2). Because the fixed soil will remain
onsite, this alternative would require a 5-year review.
This alternative reduces the toxicity, mobility, and
volume of soil contaminants by incineration.
Incineration would destroy an estimated 99.8 percent
of the hazardous constituents present in the soil of
Area 2, based on previous experience with this
technology at other sites. Approximately 18,000 cy of
treated soil that would pose minimal risk to human
health or the environment would be disposed offsite
in the local municipal landfill. Approximately 30,000 cy
of soil in Area 1 would remain although the mobility of
the lead would be reduced by approximately 40
percent through fixation. Virtually no risk from this soil
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would exist as long as the cap is properly maintained
to control exposure. Ninety-six percent of the
contaminants in the ground water would be removed
and eventually destroyed as discussed under
Alternatives 3 and 4. This alternative meets the
statutory preference for using treatment as a principal
element since it addresses the principal threats posed
by the site through treatment.
Fixation would require approximately 6 months to
complete and would potentially release particulate
matter into the air. Excavation and incineration would
require approximately a year and may release
volatiles into the air. The minor risks from both
situations to both workers and the community would
be temporary. Air monitoring and foam covers would
be used to further minimize the likelihood of risk. The
additional risk to workers through operating an
incinerator (because of the complexity of the
equipment and the high operational temperatures)
would be mitigated through the proper use of safety
protocols, proper drainage controls, and restrictions
on access to contaminated areas. Although emissions
from the incinerator would comply with all air quality
regulations, potential accidental releases could
temporarily affect air quality in the vicinity of the site.
This alternative is inherently difficult to implement due
to the incineration component. Operation of an
incinerator is mechanically complex and has stringent
monitoring requirements to provide proper.
performance. Consequently, the incinerator and
associated facilities require highly trained staff and a
substantial amount of attention. In addition, it may be
necessary to postpone the implementation until an
available mobile incinerator can be found. If metal
concentrations in the soil are very high, incineration
would not be used and the soil would be fixed along
with the soil in Area 1.
It has been estimated that the present worth cost for
this alternative would be $16,000,000, primarily
because of the incineration component. The capital
cost would be $13,000,000 and the first year annual
O&M is estimated at $1,200,000 with most of the
cost as a result of operating the incinerator.
Subsequent year O&M costs would be about
$200,000 since only the ground water treatment and
monitoring systems would be operating.
Table F-l summarizes the above discussion.
Comparative Analysis
In the following analysis, the alternatives are
evaluated in relation to one another for each of the
evaluation criteria.'The purpose of this analysis is to
6State and community acceptance will be addressed in the
ROD following comments on the RI/FS report and the
proposed plan.
identify the relative advantages and disadvantages of
each alternative.
Overall Protection of Human Health and the
Environment
All of the alternatives, except Alternative 1 (no action),
provide adequate protection of human health and the
environment. Risk through direct contact and ground
water ingestion are reduced to cancer risk levels less
than 1 x 106through each pathway. Alternatives 3,
4, and 5 prevent further migration of the contaminated
ground water by extracting and treating the plume to
health-based ARAR levels.
Alternative 2 achieves protection by preventing
exposure through capping and natural attenuation of
the contaminated ground water. Alternative 3
combines treatment to reduce the risk from the
TCE-contaminated soil and ground water and
capping of the lead area. Alternatives 4 and 5 reduce
risks posed by all portions of the site through
treatment.
There is some uncertainty about the potential
presence of metals in the TCE-contaminated soil of
Area 2. If metal concentrations of concern are
present, only Alternatives 2 and 5 would protect
against direct contact and further ground-water
contamination through a cap and incineration,
respectively. Incineration of metal-contaminated soil
may result in a hazardous waste residue which would
have to be disposed of in a hazardous waste landfill.
Alternatives 3 and 4 rely on vapor extraction to
remedy the soil in Area 2. Soil vapor extraction would
not lower risks from metals to human health or the
environment.
Compliance with ARARs
The evaluation of the ability of the alternatives to
comply with ARARs included a review of chemical-
specific and action-specific ARARs that was
presented earlier in the report. There are no known
location-specific ARARs for this site. All alternatives
will meet all of their respective ARARs except the
no-action alternative.
Long-Term Effectiveness and Permanence
Alternatives 4 and 5 afford the highest degrees of
long-term effectiveness and permanence because
both alternatives use treatment or fixation
technologies to reduce hazards posed by all known
wastes at the site. While some contaminated soil
would remain after implementation of both
alternatives, it would be fixed to reduce mobility.
These two alternatives differ only in the technology
used to treat the TCE-laden soil. Although
incineration would destroy more TCE than soil vapor
F-11
-------
extraction, both alternatives reduce risks posed by the
waste to a 1 x 106cancer risk levels through both
the ground water and soil pathways.
Alternatives 4 and 5 would rely on a soil/clay cap to
control infiltration, a reliable technology if properly
maintained. In addition, Alternative 5 would also
employ a solid waste landfill to manage the residue
from incineration. Upon completion, some long-term
maintenance of the cap and ground water monitoring
would be required for both alternatives until the
alternative has met the health-based cleanup goals
for ground water, at which point the monitoring can
be discontinued. These alternatives would have
almost no long-term reliance on institutional
controls.
Alternative 3 eliminates the risk of exposure at the
site to the same levels as Alternatives 4 and 5 in the
short-term; however, it relies solely upon a cap for
controlling the waste remaining in Area 1. Although
capping is an effective and accepted approach for
reducing risk from direct contact with wastes, it is
less reliable in the long-term than treatment to
remove or fix contaminants in soil since the inherent
hazard of the lead would remain. Since a potential for
cap failure, however small, would exist, the long-
term effectiveness of Alternative 3 would not be as
reliable as Alternatives 4 and 5. Long-term
management requirements for Alternative 3 are
similar as those of Alternative 4 or 5; operation of the
ground water pump and treat systems would be
required for 25 to 40 years. However, the capped
area under Alternative 3 is greater in size than the
capped areas under Alternatives 4 and 5.
Alternative 2 leaves all of the contaminated waste at
the site and relies solely upon a cap and institutional
controls to prevent exposure. Although the alternate
water supply lowers the risk of ingesting
contaminated ground water from existing wells, the
local municipality estimates that the existing
regulations to be used as institutional controls would
not be effective with a high degree of certainty for
more than 5 to 10 years in preventing the installation
of new wells and the ingestion of contaminated
ground water.
Alternative 2 also has long-term ground water
monitoring and cap maintenance requirements
(mowing, revegetation, cap repair) which are more
critical for the effectiveness of this alternative since all
of the waste (without any type of treatment to reduce
their mobility, toxicity, or volume) remains at the site
under the caps. Failure to detect a problem with the
cap may result in direct contact with the contaminated
soil and further degradation of the ground water
through leachate production. Monitoring will continue
until the health-based cleanup goals are met. A 5-
year review would be necessary to verify that the
remedy remains protective.
Reduction of Toxicity, Mobility, or Volume
Through Treatment
Alternatives 4 and 5 use treatment or fixation
technologies to reduce the inherent hazards posed by
all known waste at the site. Both of these alternatives
would either treat, fix, or excavate and incinerate all
soil posing more than a 1 x 106 ex cess cancer risk
level by ingestion. Both alternatives treat the ground
water and then treat the contaminated air stream from
the air stripper with GAG. Regeneration of the GAG
ultimately destroys the ICE. The soil vapor extraction
system also contains GAG gaseous treatment. Both
alternatives also fix the soil contaminated with lead,
reducing the mobility of the lead by an estimated 40
percent. Neither alternative completely treats all of the
soil at the site. Both alternatives produce 30,000 cy of
fixed soil, and 18,000 to 20,000 cy of treated soil.
Under Alternative 5, 18,000 cy of soil (with 99.8
percent of the TCE destroyed) would remain. Under
Alternative 4, 20,000 cy of soil (with 99.9 percent of
the TCE removed and ultimately destroyed) would
remain. These two alternatives would satisfy the
statutory preference for treatment as a principal
element.
Alternative 3 treats the principal threats posed by the
soil and the ground water and thus also satisfies the
statutory preference for treatment as a principal
element. Approximately 25,000 cy of lead-
contaminated soil would remain untreated onsite.
However, the mobility of this lead is very low.
Alternative 3 reduces the toxicity of 20,000 cy of
TCE-contaminated soil by using soil vapor extraction
at Area 1. Alternative 3 also reduces the volume and
toxicity of contaminated ground water.
Alternative 2 uses no treatment technologies. All of
the contaminated soil, controlled by a cap, and all of
the contaminated ground water would remain,
although the contaminants in the groundwater will
naturally attenuate.
Short-Term Effectiveness
Alternative 2 is anticipated to have the greatest
short-term effectiveness. Alternative 2 presents the
least amount of risk to workers, the community, and
the environment. Some particulate emissions from
cap installation is anticipated during implementation;
however, dust control methods should reduce this
risk. The other alternatives could release volatiles
during excavation activities or soil vapor extraction.
These emissions may be more difficult to control.
The time required to achieve short-term protection
would be shorter than for any other alternative. It is
anticipated that only 6 months would be required to
F-12
-------
Criteria
PROTBCTlVtMESS
Human Health Protection
- Direct Contact/
Soil Ingest Ion
Alternative 1
Ho Action
No significant reduc-
tion In risk. Some re-
duction In access to
risk through fence.
Table P-l
INDIVIDUAL EVALUATION OF FINAL ALTERNATIVES
CASE STUDY
Alternative 2
Cap, Natural
Attenuation
Cap reduces direct con-
tact risk and soil In-
gest Ion risk to less
than 1 x 10 .
Alternative 3
In-sltu Sol] Vapor En-
tractlon. Cap, Ground-
water tump and Treat
Cap and vapor extraction
reduce direct contact/
soil Inoestlon risk to
less than 1 x 10 .
Alternative 4
In-sltu Soil Vapor Bt-
tractlon, In-sltu Soil
Fixation, Cap, Ground-
water Pimp and Treat
Cap, fixation, vapor
extraction reduce direct
contact/soil Ingestlon
risk to less than 1 x
10'6.
Alternative S
In-sltu Soil
Fixation, Cap,
Incineration, Ground-
water Pusip and Treat
Cap, fixation. Incinera-
tion reduce direct con-
tact/sol 1 Ingestlon risk
to less than 1 x in"6.
Ground-Kilter
Ingest Ion for
Bilst.iiig Users
Ground-water
Ingestlnn for
Future Users
No reduction In risk.
No reduction In risk.
Protects against exist-
ing risk by providing
an alternate wotei
supply.
Institutional controls
provide protection
against risk from
ground-water Ingestlon.
Reduces risk,to Itss
than 1 x 10 *y pump
•ml treat.
Reduces risk,to less
than I x 10"
and treat.
See Alternative 3.
See Alternative 3.
See Alternative 3.
See Alternative 3.
Environmental
Protection
Allows continued con-
tamination of the
ground water.
Continued contamination
Is curtailed by use oi
cap. Continued migra-
tion of contaminated
groundwater Is
allowed.
Continued contamination
Is curtailed by anil
vapor extraction and by
cap. Migration of con-
taminated ground water
Is curtailed by pump
and treat.
Continued contamination
is curtailed by soli
vapor extraction, soil
fixation, and cap.
Migration of contami-
nated ground water la
curtailed by pump and
treat.
Continued contamination
Is curtailed by soil
fixation and Incinera-
tion. Migration of con-
taminated groundwater
is curtailed by pump
and treat.
COMPLIANCE HITIt ARABS
Chemical-Specific
ARARs
Does not meet ground-
water standards past
the site boundary.
Mould meet MCla at the
waste boundary in over
SO yearn.
Would meet MCI* at the
waste boundary in 25-40
years.
See Alternative 3.
Fee Alternative 3.
Location-Specific
ARARs
Action-Specific ARARs
Other Criteria and
Guidance
Net relevant. There
are no location-
specific ARARs.
Mould not meet any
ARARs since there will
be no action.
Would allow Inoestlon
of ground water exceed-
ing 1 x 10 . Mould
not protect against Pb
levels above 200 mg/kg
In moll.
See Alternative 1.
Mill meet RCRA land-
fill closure
requirements.
Protects against sail
Ingestlon to 1 x 10
level and ground-water
IngestIon at 1 x 10
level. Covers moll with
Pb above 200 mg/kg.
See Alternative ].
Nould meet RCRA land-
fill closure require-
ments. Would also
meet air release
standards trom the
vapor extraction
system. Would meet
NPULS rf-rjiiJrements.
See Alternative 7.
See Alternative 1.
Would meet air release
standards from air strip-
pers and vapor extraction
system. Mould meet HIDES
requirements. Would
meet RCRA landfill
closure requirements.
See Alternative 2.
See Alternative 1.
Mould meet regulations
concerning incineration
and air stripping*
Would meet NFDES
requirements. Would
meet RCRA landfill
closure requirements.
See Alternative 2.
-------
Criteria
Alternative 1
No Action
Table F-l (Contlnwil)
Alternative 2
Cap, Natural
Attenuation
Alternative 3
Tn-sltu Soil Vapor Ex-
traction, Cap, firound-
water Pump and Treat
Alternative 4
In-sltu Soil Vapor at-
traction, In-sltu Soil
Fixation, Cap, Ground-
water Pimp and Treat
Alternrtt Ive 5
Tn-sltu Soil
Fixation, Cap,
Incineration, firound-
water Punp and Treat
LONG-TERN EFFECTIVENESS AN) PERMANENCE
Magnitude of Residual
Risk
- Direct Contact/
Soil Ingestlor
- Ground-watpr
Inoestloti for
Existing Users
Source has not been
removed. Bilstlng risk
will remain.
Future risk greater as
pi me Migrates to resi-
dents. Eventually
natural attenuation and
dilution may decrease
risk. Risk significant
for about 100 rears.
Risk eliminated as long
as cap la Maintained.
Because source Is only
contained, Inherent
hazard of waste
remains.
Risk eliminated by pro-
viding alternate water
supply. Some risk would
renaln for over 1OO
years If the ground
water Is used.
Risk eliminated through
vapor extraction and
cap. Some Inherent
hazard remains In the
lead material under the
cap. Risk from lead
would only occur If
the cap were destroyed.
Risk eliminated by
extracting ground water
exceeding 10 ' cancer
risk levels. Safe
drinking water achieved
In 25-40 years with
source control.
Slight chance of
future risk from fixed
lead-contaminated
soil.
See Alternative 3.
See Alternative 4.
See Alternative 3.
- Ground-water
Ingestlon for
Future Users
Adequacy and
Reliability of
Controls
Risk greater as area of
contamination Increases.
Eventually natural
attenuation and dilution
may decrease risk. Risk
slgnlfleant for about
1OO years.
No controls over
remaining contamination.
No reliability.
Institutional controls
used to control use of
contaminated ground
water. Unauthorized
use of ground water
would result In
Increased risk.
Risk to ground water
controlled by alternate
water supply and Insti-
tutional controls.
Soil/clay cap controls
contaminated soil. Cap
effective for Area 2
even If metals are
present. Institutional
controls are limited Jn
effectiveness.
Reliability of cap can
be high if maintained.
Institutional controls
to control use of
ground water not very
reliable.
Risk eliminated t>y
extracting ground water
exceeding 10 cancer
risk levels. Safe
drinking water achieved
in 25-40 years with
source control.
Soil/clay cap controls
remaining contaminated
soil In Area 1. Mould
need additional con-
trols for Area 2 If
metals are present
since soil vapor extrac-
tion would not remove
metals. Groundwater ex-
traction controls con-
taminated groundwater.
Both are adequate.
Reliability of vapor
extraction high because
no long-term O&M Is re-
quired. Cap reliable
If maintained. Ground-
water pump and treat Is
reliable.
See Alternative 3.
See Alternative 3.
Reliability of fixation
with cap high, as are
vapor extraction and
ground-water pump and
treat.
See Alternative 3.
Similar to Alternative 3.
Incinerator ash disposed
in municipal landfill. If
metals are present in
Area 2, incinerator asti
would he disposed In RCRA
landfill.
Incineration very reli-
able because material is
destroyed. Fixation
with cap and ground-
water pump and treat are
reliable.
Meed for 5-Year
Review
Review would be required
to ensure adequate
protection of human
health and the environ-
ment Is maintained.
See Alternative I.
TCE and lead soil would
remain onslte.
See Alternative 1.
Lead-contaminated soil
would remain onslte.
See Alternative 1.
Fixed lead residuals
would remain onslte.
See Alternative 1.
Fixed lead residuals
would remain onslte.
-------
Table F-l (Continued)
Criteria
Alternative 1
Ho Action
Alternative 2
Cap, Natural
Attenuation
REDUCTION OF TOXICITY, MOBILITY, OR VOLDHE THROUGH TKEATHPfT
Treatment Process Used None.
AMtint Destroyed or
Treated
Reduction of Toxlclty,
Nobility, or Volume
None.
None.
None.
None.
None.
Irreversible Treatment
Type and Quantity of
Rest dual a BMW In In?
After Treat»ent
Statutory Preference
For Treatment
None.
No residuals remain.
None.
None.
Does not satisfy.
Does not satisfy.
Alternative 3
In-sltu Soil Vapor Ex-
traction, Cap, Ground-
water Pump and Treat
Vapor extraction of soil
anil groundwater air
stripping.
99.94 of volatiles In
soil and 96% volatiles
In groundwater removed
and destroyed by carbon
regeneration.
Reduced volume and
toxlclty ot contam-
Inated groundwater.
Toxlclty of soil con-
tamination reduced.
Vapor extraction and
Alt stripping are irre-
versible with regenera-
tion of carbon used for
tilr stream treatment.
No detectable residuals
in Area 2 regain.
Carnon fro* gaseous
treat»ent requires
regeneration.
Satisfies.
Alternative 4 '
In-sltu Soil Vapor De-
traction, In-situ Soil
Fixation, Cap, Ground-
water Pump and Treat
Vapor extraction, soil
fixation, and groundwater
air stripping.
Sane as Alternative 3
plus 25,000 cy of con-
taminated soil is fixed.
Reduced volune and
toxlclty of contami-
nated groundwater.
Toxlclty of soil con-
tamination in Area 2
reduced 97%. Mobility
of contaminants in
Area 1 reduced 10%
while volume increased
30%.
See Alternative 3.
No detectable residuals
in Area 2 remain.
30,000 cy of fixed soils
remain ID Area 1.
Satisfies.
Alternative 5
In-sltu Soil
Fixation, Cap,
Incineration, Ground-
water Pump and Treat
Incineration, soil fixa-
tion, and qroundwater
air stripping.
99.B% of volatiles In
20,000 cy of soil des-
troyed and 25,000 cy of
contaminated soil is
fixed.
Incineration reduces
volume of contaminated
soil by 20,000 cy and
reduces toxlclty.
Mobility of contaminants
in Area 1 la reduced.
Volume and toxlclty of
contaminated ground
water is reduced.
Incineration io Irrevers-
ible. Air stripping with
subsequent gaseous carbon
treatment and regeneration
is Irreversible.
Incinerated soil (18,000
cy) and fixed soils
(30,000 cy) remain.
Incinerated soil expected
to be nonhatardous.
Caibon from gaseous
treatment remains, re-
quiring regeneration.
Satisfies.
SHORT-TEBM EFFECT IVBIESS
Community Protection
Worker Protection
Risk to conmnity not
Increased by remedy
implementation, but,
contaminated water
may reach the resi-
dents within 1-3
years.
No significant risk to
workers.
Temporary Increase In
dust production through
cap installation.
Contaminated soils
remain undisturbed.
Protection required
against denial contact
and inhalation of
contaminated dust
during cap
construction.
Soil would remain uncov-
ered during vapor extrac-
tion for 3-5 years.
Temporary Increase In dust
production during cap
Installation.
Protection required
against dermal contact,
vaper or dust Inhala-
tion during construc-
tion and operation of
vapor extraction
system and atr
stripper.
Similar to Alternative 3.
Fixation may result In
dust and odor Increase.
Protection required
against dermal
contact, vapor, or dust
Inhalation during
construction and
operation of vapor
extraction system,
fixation, and air
stripper.
Soil would remain uncov-
ered during Incineration
(about 1 year). f>cava-
tlon and fixation would
release dust and odors
to the atmosphere.
Protection required
against dermal contact
and inhalation of vol-
atiles and particulate.s
as a result of excava-
tion, fixing, and
Incinerating TCE soil.
-------
Criteria
Alternative 1
No Action
SHORT-TO* EFFfCTIVBIESS (Cont'd)
Table r-1 (Continued)
Alternative }
Cap, Natural
Attenuation
Alternative 3
In-sltu Soil Vapor Ex-
traction, Cop. Hround-
water Pump and Treat
Alternative 1
m-«ltu Soil Vapor Ex-
traction, In-altu Soil
Fixation, Cap, Ground-
water Pump and Treat
Alternative i
In-sltu Soil
Fixation, Cap,
Incineration, firound-
iiater tump and Treat
Environmental Impacts
Tim* Until Action Is
Complete
Continued l»pact fro
existing conditions.
Not applicable
Hould be some •!grotIon
of contaminant plume
as part of attenuation
process.
Cap Installed in 6
months. Risk fro*
ground water reduced
within 3 norths due
to alternate water
supply and Institu-
tional controls.
Vapor extraction may
Impact air quality and
odors although It kill
•eet Mission standards.
Kould be aquifer draw-
down during ground-
water extraction.
Soil vapor extraction
complete In 3-5 years.
Capping complete In
6 nonths. Ground-water
renedlal action com-
plete In 25-40 years.
See Alternative 3.
Fixation Bay also
affect air quality
and produce odors.
Fixation and capping
completed In 9 Months.
Soil vapor extraction
complete In 3-S years.
Ground-water action co»-
plete In 25-40 years.
Incineration Bay Ippact
air quality, produce
odors, although It will
•eet emission standards.
Incineration complete In
2 years fro* design
completion. Fixation
and capping conpletc In
9 norths. Groundwater
action <:ttMpl(*te In
25-40 years'.
IHPLEHENTABILITY
Ability to Construct
«nd Operate
Tl
i
_*
O>
Ease of Doing More
Action If Needed
Ability to Monitor
Effectiveness
Ho construction or
operation.
If Monitoring Indicates
•ore action Is necessary,
•ay need to go through
the FS/ROO process again.
No monitoring. Failure
to detect contamination
means IngestIon of con-
taminated ground water.
Simple to operate and
construct. Hould require
materials handling or
about 50,000 cy of soil
and clay.
Simple to extend extrac-
tion system and cap. Cap
would be sufficient If
metals were significant
In Area 2. Could Imple-
ment ground-water treat-
ment If necessary.
Proposed monitoring will
give notice of failure
before significant ex-
posure occurs.
Vapor extraction requires
some operation. Fairly
straightforward to con-
struct. Cap construction
would require materials
handling of J5.OOO cy of
soil and clay. Onslte
•jround-weter treatment
requires operation.
Simple to extend ground-
water extraction system,
vapor extraction system,
and cap. However, If
significant metal con-
centrations are present
In Area 2, may need
additional soil treat-
ment or would need to
extend cap.
See Altetnatlve 2.
Fixation with cap some-
what difficult to con-
struct. Otherwise
similar to Alternative 3.
Fairly complete alterna-
tive. Can Increase
volume of or modify all
technologies. If signif-
icant Metal concentra-
tions are present In
Area 2, could use
fixation.
See Alternative 2.
Incineration Is difficult
to operate. Fixation with
cap is somewhat difficult
to construct. Similar to
Alternative 3 with respect
to ground woter.
Complete alternative.
Can handle varying
volumes or concentra-
tions.
See Alternative 2.
-------
Table F-l (Continued)
Criteria
Alternative 1
Mo Action
Alternative 2
Cap. Natural
Attenuation
IMPLIMHIT ABILITY (Cont'd)
Alternative 3
In-situ Soil Vapor Ex-
traction, Cap, Ground-
water Pump and Treat
Alternative 4
In-sltu Soil Vapor Ex-
traction, In-sltu Soil
Fixation, Cap, Ground-
water Pump and Treat
Alternative S
In-sltu Soil
Fixation, Cap,
Incineration, Ground-
irater Pump and Treat
Ability to Cfctain
Approvals and Coordi-
nate with Other
Agencies
Availability of
Services and
CanacltIcs
Availability of Equip-
ment, Specialists, and
Materials
Availability of
Technologies
COST
Capital Cost
First Tear Annual OM Cost
Present Worth Cost
Ho approval necessary.
Ho services or capaci-
ties required.
None required.
None required.
Sec Alternative 1.
See Alternative 1.
No special equipment,
•attrial, or specialists
required. Cap
Materials available
within 20 Biles.
Cap technology readily
available.
$ 4,200,000
60 ,OOO
4,BOO,000
Need an NPDES permit.
Should be easy to
obtain.
See Alternative 1.
Needs readily available
specialists to install
and monitor vapor
extraction system.
Need treatment plant
operators. Cap
Materials available
within 20 Biles.
Vapor extraction well
developed. Mill require
pilot testing.
$ 3,300,000
440,000
7,300,000
See Alternative 3.
Need fixation services.
See Alternative 3.
Vapor extraction and
fixation well developed.
Hill require pilot
testing.
$ 6,200,000
460,000
10,300,000
Need to demonstrate
technicfll Intent of
incinerator peniit.
Need an NPDES permit.
Need fixation and Incin-
eration services.
Need a mobile Incinera-
tor and trained opera-
tors. Need treatment
plant operators.
Closest source of
Incinerator la 500
miles from site.
Incineration and fixation
well developed. Hill re-
quire pilot testing.
$13,000,000
1,200,000
16,000,000
-------
install a new cap and to provide an alternate water
supply. Alternatives 3 and 4, involving vapor
extraction require 3 to 5 years before the risk from
direct soil contact and ingestion is controlled.
Alternatives 3 and 4 are very similar with respect to
short-term effectiveness. Implementing the soil
vapor extraction system requires the most time of the
source control actions. There is a small potential for
risk to the community, workers, and the environment
through volatile emissions during extraction to the air
in the unlikely event of control failure.
Alternative 5 would take longer to implement than
Alternative 2 and has a greater potential of releasing
volatiles to the atmosphere during excavation than
Alternatives 3 and 4. However, implementation of
Alternative 5 would take less time than Alternatives 3
and 4 since incineration would require less time than
soil vapor extraction to remediate the soil to safe
levels. However there may be a possibility of volatile
emissions during excavation that would need to be
controlled. Alternative 5 has the disadvantage of
requiring incineration equipment (the most technically
complex equipment of any of the alternatives) which
could increase the risk to workers in the event of a
failure. Careful implementation of standard safety
protocols would lessen this risk.
Implementability
Alternative 2 would be the simplest to construct and
operate. While construction of a cap would have
significant materials handling requirements, the
materials are available locally. Expansion of the cap
could incorporate other areas of contamination if
discovered during activities at the site, specifically if
metals become an issue at Area 2. Periodic
maintenance of the cap should control its reliability in
the future. The ground water monitoring program
would determine the effectiveness of the cap at
decreasing future contamination of the ground water.
The alternate water supply would reliably supply safe
drinking water despite the fractured nature of the
aquifer.
Construction requirements for Alternative 3 are fairly
simple. Alternative 3 has more operational
requirements than Alternatives 1 and 2 because of
the soil vapor extraction system and the air stripper.
As with the other alternatives, if additional
contamination is found at the site, the components
could be sized to include the additional areas.
However, if metals were found in Area 2, soil vapor
extraction would not effectively treat the soil and
another technology would need to be used to control
the risk from direct contact.
Soil vapor extraction is a fairly reliable technology
because of its mechanical simplicity. Very little
downtime is anticipated. However, as with any in situ
treatment system, samples throughout the soil (both
varying in location and in depth) must be taken
frequently to determine the effectiveness of the
technology.
Alternative 3 would require readily available
engineering services and cap materials. An air
stripper could readily be obtained and constructed
onsite. All of the treatment technologies proposed for
this alternative are proven. However, it would be
difficult to evaluate the effectiveness of the ground
water extraction system in the fractured aquifer. It
would be difficult to determine where to install
extraction wells to intercept contamination since the
fractures would be difficult to locate. Additional
treatability studies for the soil treatment component of
this alternative and some fracture trace analysis
would help ensure the success of this alternative.
Alternative 4 is more complex than Alternative 3
because of the in situ soil fixation component. While
this component has no additional operation
requirements, it would require additional construction
techniques that would have to be supplied by
specialists in this area. Vendors for soil fixation are
readily available. Additional treatability work may be
required to optimize the reagent doses. Other than
the in-situ solidification component, Alternative 4 is
similar to Alternative 3 in terms of implementability.
However, the solidification component could be easily
used on Area 2 if significant metal contamination
were found.
Alternative 5 is the most complex alternative to
construct and, during implementation, to operate.
However, despite anticipated frequent downtime due
to mechanical complexity,, incineration could reliably
meet the cleanup goals. A mobile incinerator would
have to be located and brought onsite. During
operation of the incinerator, this alternative would
require the most attention because incinerators
require periodic sampling of the residue and
modification of operating parameters. However, the
incinerator would operate for slightly more than a
year, whereas the soil vapor extraction system of
Alternative 4 would operate for 3 to 5 years.
As with Alternatives 3 and 4, some initial treatability
work would be necessary to determine operating
parameters. Other than locating, constructing, and
operating the incinerator, the other implementability
aspects of this alternative are similar to Alternatives 3
and 4. Incineration would also not be effective in
treating Area 2 soils if metals are determined to be a
health risk. The ash would be a hazardous waste
under this scenario and would require disposal at an
RCRA Subtitle C landfill.
F-18
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Cost alternatives because of the incinerator component.
Alternative 2 has a lower present worth and O&M The cost details of all of the alternatives are included
cost than Alternative 3, but because of the additional m the aPPendlx to thls FS reP°rt-
cap required, it has a higher capital cost ($4,200,000
versus $3,300,000). The cap is one of the most State Acceptance
expensive components to construct. Alternative 4 has To be addressed in the ROD.
a higher capital, O&M, and present worth cost than
Alternatives 2 and 3. Alternative 5 has the highest /-„„,„,„„:+„ n *
capital ($13,000,000), first year O&M ($1,200,000), Community Acceptance
and present worth cost ($16,000,000) of all of the To be addressed in the ROD.
U.S. GOVERNMENT POINTING OFFICE: 1993—3 if 1 -9 32 '82626
F-19
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