& 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

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              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

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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

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          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

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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

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  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

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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

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                                       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

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                                   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

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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

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 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

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            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

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           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

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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.

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            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

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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

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            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

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             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

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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.
                                                 3-22

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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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                                                                                                                             LEGEND


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          Figure 3-4.   Identification of exposure pathways.

-------
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
                                                              3-29

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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 \




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nrnrmft fSR 1 / \ S~


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\





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

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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

-------
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
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• 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

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                                              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

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                                            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

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    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
                                                  5-7

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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;
                                                    5-9

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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
                                                          5-10

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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.
                                                 5-12

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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
                        6- I

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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
                                                6-3

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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.
                                                   6-4

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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

-------
•  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.
                                                 6-6

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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

-------
    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.
                                                 6-8

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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.
                                                    6-9

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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
                                                       6-11

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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.
                                                 6-13

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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
                                                 6-14

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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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                                         Bibliography
American National Standards Institute.  1980.
  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.
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  Methods Manual. Volume II - Available  Sampling
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National Fire  Protection Association.  1981. National
  Fire  Codes.  Volumes  1-16.  Quincy,
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National Institute for Occupational Safety  and Health.
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National Institute for Occupational Safety  and Health.
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National Institute for Occupational Safety  and Health.
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NIOSH/OSHA/USCG/USEPA.  1985.  Occupational
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U.S. EPA. 1979. Safety Manual for Hazardous Waste
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  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
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U.S.  EPA.  June 1985.  Guidance on Feasibility
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U.S. EPA. June 1985. NEIC Policies and Procedures.
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U.S. EPA. September 1985. Remedial Action Costing
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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,
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  Washington, D.C.

U.S. EPA. December 1986. Superfund Federal-Lead
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  Program Plan. OSWER Directive No. 9380.2-3.
                                             7- 1

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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,
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  Washington, D.C.

U.S.  EPA. December  1986. User's  Guide to  the
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U.S.  EPA.  March  1987.  Data  Qualify  Objectives for
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  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
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  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
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U.S. EPA. June  1988. "Interim  Guidance on
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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.
                                                A-13

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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.
                                                A-14

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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
                                            A-15

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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
                                               A-16

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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.
                                               A-1 7

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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;
                                                A-1 8

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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.
                                                A-20

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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.
                                                  B-2

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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.
                                                  B-3

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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)
                                                B-4

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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
                                                 B-5

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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.
                                                B-6

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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.
                                                B-7

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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
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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.
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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.
                                                  C-8

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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.
                                              D-1

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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.
                                                D-2

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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.

U.S. EPA. 1985. In Situ  Treatment - Bioreclamation.
  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.
                                               D-3

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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.

Research and  Education Association. 1978. Modern
  Pollution  Control Technology  Vol. II,  So/id Waste
  Disposal. Research and Education Association.

Solids Processing

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

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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

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    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

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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

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 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

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  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

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                                             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

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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

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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

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                                                                     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
                                                 F-7

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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.

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                                                                                      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

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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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