United States EPA/540/G-90/002
Environmental Protection February 1990
Agency
Solid Waste and Emergency Response (OS-240)
SCOPER'S NOTES
An RI/FS Costing Guide
Bringing in a Quality RI/FS
On Time and Within Budget
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INTRODUCTION
What
This handbook is intended for use by RPMs during RI/FS scoping
activities to assist them in identifying those options and decisions within
the scoping process that may have significant impact on project budgets.
Why
The average* cost to complete an RJ/FS has more than doubled over
a three year period. Some of this increase is no doubt justified, but some
of the change may be the result of duplication through minimal use of
existing resources, incomplete project planning, and insufficient
schedule and financial control. In fact, past RJ/FS costs have
occasionally appeared excessive because projects were unnecessarily
rated as complex, excessive studies were performed, and/or sampling
and analyses requirements were in excess of the actual needs.
As a Project manager it is your responsibility to provide the project
supervision, schedule maintenance, and financial control of the
RJ/FS project. As an RPM, you should understand the basis and
rationale for project design and be in a position to justify the project
budget in a professional manner.
How
The following pages outline the tasks and sub-tasks typically conducted
as part of an RJ/FS, and present a strategy based on site complexity and
task difficulty for estimating a project's cost. You can use the cost
guidelines to estimate funding needs in advance of issuing a work
assignment and to evaluate contractor proposals to do the work.
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RI/FS SCOPING IN A NUTSHELL
The objective of the scoping process is to develop a conceptual
understanding of a site* based on existing information* so that a
sufficiently detailed workplan for conducting the necessary investigative
and analytical tasks can be prepared. Although site specific conditions
will govern the types of investigations and level of effort required for
any given site* five basic questions need to be answered at all sites:
1. What type and in what quantities are hazardous materials
present?
2. Where are the hazardous materials physically located?
3. What are the potential routes of migration and exposure
pathways?
4. Who and what are potentially at risk through exposure?
5. What remedial strategy(ies) will best reduce or eliminate the
existing and/or potential risk?
6. What are your data needs?
Experience has shown that despite how much money and time is spent
on an RI/FS* some degree of uncertainty concerning the nature and
extent of contamination and/or the expected performance of a remedial
technology will remain. You should keep in mind that the objective of
the RJ/FS is not to remove all uncertainty* but to gather information
sufficient to support and informed risk management decision regarding
what remedy appears to be most appropriate given what is known about
the site.
Resources you will need:
1. Hazard Ranking System (HRS) Report
2. Other reports from previous site work (if any)
3. Notes from site visits(s)
4. Potential Responsible Party (PRP) Search Report
5. Solutions used at other sites
6. Guidance pertaining to site situation
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RI/FS PROJECT TASK BREAKDOWN
The RI/FS project has been divided into 14 standardized tasks to
facilitate the planning process and serve as a management tool for
tracking progress and expenditures during the investigation.
1. Proj ect Planning
2. Community Relations
3. Field Investigation
4. Sample Analysis and Validation
5. Date Evaluation
6. Assessment of Risk
7. Treatability Studies
8. Remedial Investigation Reports
9. Remedial Alternatives Development and Screening
10. Detailed Analysis of Remedial Alternatives
11. Feasibility Study Reports
12. Post RI/FS Support
13. Enforcement Support
14. Miscellaneous Support
Not all tasks may be required for a given site; use only those that are
appropriate.
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SCOPING THE RI/FS
COMING UP WITH THE WORK PLAN
Existing Data
Collection and Review
Develop Conceptual Understanding
of the Site
Nature and Extent of Contamination
Technical Advisory
Committee
Work Plan
T»kl
Limited Site
Investigation
1 I
Community Relations Data Quality
TaikZ Objectives "*
^
Field Sampling
Plan
^
Field Investigation ^
Ta«k3
Alternatives
T«k»
*
Evaluation ^ Treatability Studies
Tank 10 Tssk7
*
FS Report 1
Ta«k 11 ./
QA
Quality /
Proje
!
1
/QC ^ Health and Safety
Assurance "* ' Plan
A Plan
f
Sample 4c Analysis ATSDR
Task 4
t
Data Evaluation ^ Risk Analysis
i >
l
Tanks ^" Task*
r
RI Report 1
Task* >/
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GETTING STARTED: COLLECTING EXISTING DATA
Spend time researching existing site information. Start with the Hazard Ranking
System (HRS) package and the draft PRP Report. The PRP search report is prepared
by enforcement personnel and has a lot of useful information on legal property
description* record of ownership permits easements licenses liens* ordinance
violations* etc. If you have to, you can chase down the same information from deed
books* the health department* Sheriff's Office* etc."but don't if it's already
available. It may even be possible to interview a PRP to obtain useful site data.
Visit the local land records office and examine deed books for ownership history if
this information isn't in the HRS or PRP Search Report. Visit the local Agricultural
Extension Agent' Soil Conservation Service representative; these organizations are
great on ground water* aquifers* soil types* surface drainage* etc. The local Health
Department will have data on local drinking well water quality. Local well-drilling
companies will have a collection of drilling logs for the site area. Local waste
haulers may have records of clients that have used the site.
Don't overlook talking to site neighbors or trying to find former employees who can
describe work practices on the site. It is much easier to be told about buried drums
than it is to go looking for them arbitrarily.
The National Weather Records Center* Asheville N.C.* has years of climate data for
all sections of the country including the nearest airport and towns.
Be sure and obtain relevant records from previous removal actions or PA/SI
material. Avoid repeating existing work,
There is a pool of experience from previously completed RI/FS projects. Study good
examples of completed RI/FS projects and don't be afraid to use their better features
to accomplish the work in a more timely and efficient manner. For similar site types"
items such as Health and Safety Plans* Quality Assurance Plans* etc.* do not have to
be re-developed or re-phrased to sound different for each new project. Satisfactory
components from successful completed studies should be adopted wherever they
can contribute to eliminating the time and expense of the duplication of previous
work.
There is no substitute for a personal site visit. After gaining access* walk the site**
respecting safety precautions* and make field notes. Take a camera and use it. The
information you gain will save time* and avoid mistakes and oversights. Keep a
good notebook record for yourself.
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ESTABLISHING A TECHNICAL ADVISORY COMMITTEE
Ask people with the applicable experience and background* and whose
opinion you respect* to serve on a Technical Advisory Committee for
the project. Your Technical Advisory Committee (TAG) should consist
of individuals who have technical* administrative* and enforcement
experience which can help you learn* evaluate* and decide. The goal is
to increase efficiency and conduct the project more economically by
using accumulated experience; that is* to do a professional job within
the budget.
For TAG meetings* always distribute an agenda of topics to be
presented in advance* and clearly state what results you hope to achieve.
Don*t call everybody if your questions aren't of project-wide
importance. Make an appointment with individuals to discuss
specialized topics. If the results of a decision are important* summarize
them in a memo and distribute it so that there is no misunderstanding of
what the results were.
Don*t be afraid to ask questions. That's the only way to make sure that
you understand. Different people have different understandings of
words like normal** average 'adequate** or suitable.' Be sure
there is a common understanding so that what you assume to be
perfectly adequate doesn't turn out in the end to be woefully inadequate
in someone else's view.
You are not expected to be an expert on all things* but you should
know where you can get expert advice when it's needed. It is all right to
question the advice you get and to decide whether or not to use it on
your project. Bounce ideas off your TAG or ask for suggestions. That is
what a TAG is for.
Keep in touch with enforcement personnel assigned to your site' and let
them know of your progress. Invite them to your Technical Advisory
Committee meeting.
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ESTIMATING LEVEL OF EFFORT
The cost of an RI/FS project is made up of two categories of expenditure. The
principal one is the cost of labor spent on project tasks* known as the level of effort
The other* known as other direct costs* (ODCs)* consists of the remainder of the
expenses (e.g.* travel* equipment) related to the study.
The Level of Effort (LOE) is the number of work hours devoted to a particular task.
The LOE is usually divided into skill levels for costing purposes. For instance* a
task might take 40 T2 level hours to locate background material* 60 P2 level hours
to assemble generic material* 40 P3 level hours to write* 20 hours to type* and 10
level P4 hours to review* a total LOE of 170 hours.
The cost of the LOE is the sum of the costs for each skill level. The total cost per
hour is the actual cost of labor* an overhead percentage which covers fringe
benefits and other personnel costs* a percentage for general and administrative
expense* and a percentage fee. A base labor cost of 18 dollars an hour can result in a
cost to the project of over 50 dollars per hour after the other factors are applied.
To estimate task LOEs assign hours for each skill level required based on the
type* amount* and difficulty of the task. A contingency amount should be included
for inclement weather and other delays due to unforeseen factors. Approving skill
level assignments that are higher than are reasonably required for the task performed
will result in higher costs for no real gain in quality.
OTHER DIRECT COSTS
As a rule of thumb "labor costs add up to about 60 percent of the total cost of an
RI/FS project. The remaining 40 percent is made up of items such as travel*
communications* equipment rentals or purchase* printing* expendables*
subcontracts* etc. These costs are lumped together and called other direct costs* or
ODCs.
Travel costs (including per-diem) can be a substantial project expense and should
be monitored carefully. Travel costs incur a G & A charge (General and
Administrative expense) and are part of the cost basis used to compute a contractors
award fee. The particular G&A charge depends on how the contractor keeps the
books but can run as high as 35 percent.
Printed reports that are unnecessarily elaborate are extra expense items as are reports
that contain duplicate information. Review any items that are to be reproduced in
any quantity to make sure that they are assembled efficiently.
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STRATEGY FOR ESTIMATING
RI/FS STANDARD TASK COSTS
Upper and lower cost bounds for budget estimates for each of the 14
standard RI/FS tasks have been established (Table I). The amounts
shown are in 1989 dollars and are meant to include satisfaction of all
current guidance requirements for RI/FS project tasks. The cost ranges
have been determined by analyzing technical requirements and past
experience records as well as professional judgment. They are
considered reasonable and of a broad enough range to serve as a
general guideline for RI/FS cost-estimating efforts.
The allocated costs for some tasks vary significantly with site
complexity while for other tasks the costs are less affected by site
conditions. (Key factors affecting site complexity are found on Page
11.) Following a site examination* an RPM should step through each
task* considering the factors listed and the site's complexity and
establish a task cost target. From Table I* the highest allowance
(complex) is intended to be applied to those sites where site conditions
fully justify the added cost allocation. Average sites should fall
somewhere around Average* costs* and for the simpler sites* it may
even be possible to accomplish the task for less than the lower cost
bound shown. You should be in a position to justify your estimates on
broad terms to your management. If a task is unnecessary and does not
need to be conducted in a particular RJ/FS* it should be omitted.
The intent of this strategy is not to limit the proper conduct of your
study* but to stress the need to conduct the work in an efficient manner.
Although each site has unique aspects* it is not necessarily complex.
Evaluate your site carefully to avoid excessive expenditures for
marginally valuable results.
Using this method as a planning or evaluation tool will help establish an
independent estimate which can be used to evaluate contractor
proposals.
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TABLE I
RI/FS ESTIMATED LOE AND COST SCHEDULE
Task
Uncomplicated
LOE Budget
hrj k$*
Site Type
Average
LOE Budget
hrj k$*
Complex
LOE Budget
hrj k$*
Planning
850 60
1102 97
1500 143
Remedial Investigation
Field Investigation
Sample Analysis
Data Evaluation
Risk Assessment
Remedial Investigation
Report(s)
Treatability Studies**
100
610
460
360
500
290
158
45
30
28
25
16
2714
709
560
450
600
390
240
85
50
40
48
35
3300
933
665
519
910
460
418
120
60
60
48
80
Feasibility Study
Remedial Alternatives
Development and 260
Screening
Remedial Alternatives
Analysis 370
FS Report(s) 460
Post RI/FS Support 150
40
25
10
300
450
526
300
25
40
28
20
360
620
845
400
45
100
48
40
Community Relations
210 16
210 16
450 25
Other
Enforcement Support 15
Miscellaneous Support 150
20
10
200
150
45/20
10
200
150
45/35
10
Project Budget Total
6785 503
8661 779
11312 1242
I Based on a skill level combination of 6%-P4- 8%-P3- 40%-P2- 30%-Pl- 13.5%-T2- 1%-Tl-
and 1%-clerical' averaged over the whole project. The dollar budget to support the task is
obtained by multiplying the LOE by an average labor cost for the skill combination shown"
and adding an amount for ODCs.
* Figures in 1989 dollars
"* Does not include conducting bench tests- only determining their feasibility.
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THE DEVELOPMENT OF SITE COMPLEXITY
SMALL SITE AREA
DIRECT CONTACT
SPIU5
UNCOMPLEX
RUNOPP
ON SATURATED 50)15 "
STORAGE
ODORS
AVERAGE..
AQUIFER.
LARGE SITE AREA
POPULATION
I; .CKOUNP WATER'~~
COMPLEX; ^t^ill^^^^^^^gi
(MULTIPLE ~
fRAC.TVKE.0 SEDfiOCK
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INVESTIGATION VERSUS REMEDIATION
FIRST LOOK* *SITE COMPLEXITY RATING
Exposure Risk Factors
significant closest population (1500m"
working drinking water wells (no-
offsite sensitive areas (no"
adjacent agriculture land use (no-
Site Surface Factors
area in acres (<5
access (for equipment) (easy-
topographic variation in feet (<5
ponds or lagoons (0"
streams on site (0"
soil type (loam"
rock outcrops (0"
vegetation on site (no
evident soil erosion (no-
utility easements on site (no-
safety precautions necessary (no-
evidence of flooding (no-
Estimated Media Contaminated
soil stains (no-
odors (no-
wind blown particulate (no-
buildings' structures (No-
water table depth (<12"
offsite complaints (fishskills) (no-
discolored sediment deposits (no-
multiple aquifers (no-
annual rainfall (<18
Waste Conditions
drums (no-
storage tanks (no
container condition (good-
known high hazard substances (no-
contaminants present (few
Range
500m"
5-25
avg"
5-20
1-
1-
sandy
1
sparse"
some-
1
few-
some
little-
few
13-25"
few-
few-
19-30"
few-
few"
avg"
little-
100m-)
yes)
yes)
yes)
>25)
hard)
>20)
>1)
>1)
rocky)
>1)
heavy)
heavy)
>1)
yes)
yes)
many)
strong)
much)
many)
>25)
many
many)
yes)
>30)
many)
many)
poor)
much)
many)
Rank
L M H
Site complexity is estimated by the number of checks appearing in each
vertical column. Complex sites will rank to the right.
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USING THE TASK EVALUATION QUESTIONNAIRE
The following pages present each of the 14 standard tasks of an RI/FS project along
with qualitative questions that cover some of the factors that will influence the
difficulty of the task and the budgeting of funds to complete the work.
Each task includes a cost range (from Table I) which relates to how difficult the task
appears to be at this stage of project scoping. These ranges are provided to be used
as a framework against which to judge the reasonableness of bid costs to do the
work. Indicate your answers to the questions and use the proportion of yes* and
no* answers to estimate the likely cost of the task (e.g.* 50/50 distribution would
suggest using the Average* cost). Enter the resulting estimate in the Allocation*
box for that particular task. If site-specific factors justify a different level of effort
then alternative cost estimates may be used.
TASKI PROJECT PLANNING
ALLOCATION
This task is most important since it will determine the course of the project.
It is a good idea to return to it as you step through the other tasks to make
sure everything that is required is included and that there are no
unnecessary steps that consume time and resources. The objective is to
clean up a site* not study it unnecessarily.
No Yes
* Does existing site data indicate complexity?
* Is this one of several OUs?
* Will pre-sampling be required?
* Will special maps be needed?
* Has any site activity occurred?
* Are there several contaminated media involved?
* Must Health- QA- FSP- etc. be developed?
* Will special analytical techniques be required?
Other:
Complexity:
uncomplicated
60
average
97.,
complex
143k$
Notes:
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TASK 4 SAMPLE ANALYSIS/VALIDATION
ALLOCATION
This task includes the analysis of field samples- and the quality control and quality
assurance of the analytical procedures. In the past this was almost always handled
away from the site using CLP laboratory assistance. If initial analysis can be done on-
site with portable or mobile laboratory facilities' satisfactory results can be made
available more rapidly and at lower cost.
No
Yes
Complexity:
Notes:
* Must sampling protocols be developed?
* Are all samples processed in a (remote) CLP lab?
* Is there more than one medium involved?
* Are unusually toxic materials known to be present?
* Will special analysis procedures be required?
* Do a large number of samples need to be validated?
* Will expedited CLP turnaround time be requested?
Other:
no uncomplicated average complex
Q 45 gj 120k$
TASK 5 DATA EVALUATION
ALLOCATION
This task accounts for activities related to the evaluation of data for use in
calculations' analyses- effects predictions- modeling- and any other types of analysis
where specific site data are used.
No Yes
* Must DQOs be prepared and reviewed?
* Will non-standard analytical methods be developed?
* Is historical data insufficient or as yet unvalidated?
Other:
Complexity:
Notes:
no uncomplicated average
0 "30 SO
\J --------------- J\J ------------------- JI\J
complex
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TASK 2 COMMUNITY RELATIONS
ALLOCATION
No
This task covers preparation and conduct of community relations services during the
life of the RI/FS.
Yes
* Is the site reasonably close to a community?
* Has there been a high level of community interest?
* Has local or State government been closely involved?
* Administrative record repository not yet identified?
* Key community spokespersons not yet identified?
Interest:
Notes:
uncomplicated
16
average
16
complex
-25k$
TASKS
FIELD INVESTIGATION
No
ALLOCATION
The task includes fieldwork to survey gather data' collect samples' perform tests en-
sile* etc. In the typical project' over 50 percent of the RI/FS cost is the result of
activities in this task. The activity in this task is especially high (and costly) for
complex sites. This task should be analyzed carefully and scoped with care to control
sampling duplication- unnecessary drilling and testing- and interruptions to site work
requiring re-mobilization.
Yes
Will there be more than one project phase?
Is more than one medium involved?
Will more than one subcontractor be required?
Will weather affect field operation schedules?
Will high protection levels be required for people?
Will there be contaminated waste produced?
Are there surface waters or stored liquids?
Are there buildings on-site?
Will test excavations be required for buried wastes?
Will any off-site work be required?
Are there any problems in physical site access?
Other:
Complexity:
Notes:
uncomplicated
158
average
240-
complex
418k$
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TASK 6 ASSESSMENT OF RISKS
ALLOCATION
This task provides a determination of the estimated risk to human health and other
aspects of the environment due to the hazardous substances present and the potential
pathways of exposure.
No Yes
Is there more than one contaminated medium involved?
Is there more than one significant exposure pathway?
Will assessment models be developed?
Are there known highly toxic or carcinogenic materials present?
Has the use of indicator chemicals been rejected?
Are significant populations/receptors involved?
Are there sensitive environmental issues (e.g. wetland-
endangered species)?
Other:
uncomplicated average complex
Complexity:
no
0 28 40 60k$
Notes:
TASK 7 TREATABILITY STUDIES
ALLOCATION
This task includes efforts directed toward the development of site-specific
performance data for treatment technologies being considered. These studies can
include bench and/or pilot tests. Most commonly pilot tests are used for innovative
technologies or conventional methods being applied to a waste type for which
performance data do not exist. There should be a reasonable probability of success
before a pilot study is initiated.
No Yes
* Are a number of conventional technologies available?
* Will bench or pilot testing be required?
* Is the toxicity or volume great?
* Are potential ARARs severe/numerous/ complex?
* Will testing be conducted offsite?
* Will clarification of soil cleanup goals be required?
Other:
Complexity:
Notes:
no uncomplicated average complex
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TASK 8 REMEDIAL INVESTIGATION REPORTS
ALLOCATION
This task covers the preparation of draft and final reports summarizing findings of the
data gathering and validation tasks. It is comprised mostly of labor hours in report
preparation' review and revision.
No
Yes
* Are more than two review agencies involved?
* Will new report formats be developed?
* Have a large number of samples been proposed?
* Is more than one significant medium involved?
* Are there several significant pathways?
Other:
Complexity:
Notes:
no uncomplicated average complex
0 25 48 48k$
TASK 9 REMEDIAL ALTERNATIVES DEVELOPMENT AND
SCREENING
This task provides for the initial evaluation and identification of the most suitable
remediation methods from the set of possible methods applicable to a site. A
judgement about the most likely remedial actions appropriate to the site will be of
great benefit in planning your project. Only those methods with a solid likelihood of
being selected should be considered. (Typically no more than three to five
alternatives are evaluated in detail under the following Task 10.)
No Yes
* Are there multiple technology and process options?
* Is more than one medium involved?
* Are new evaluation criteria required?
* Are treatability studies proposed?
* Has any prior site remediation occurred?
Other:
Complexity:
Notes:
no uncomplicated average complex
Q 20 25 45k$
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TASK 10 DETAILED ANALYSIS OF REMEDIAL
ALTERNATIVES
ALLOCATION
This task is devoted to the detailed evaluation of the most likely remedial methods
identified in Task 9.
No
Yes
Complexity:
Notes:
* Is more than one medium involved?
* Are there multiple exposure pathways?
* Do any ARARs modify methods or require a waiver?
* Are there more than five reasonable alternatives?
* Has there been previous remediation?
* Are there restrictive climate conditions?
* Are there innovative technologies proposed?
Other:
uncomplicated average complex
no
0 40
40 100k$
TASK 11 FEASIBILITY STUDY RI/FS REPORTS
ALLOCATION
This task includes the preparation of reports that summarize the various
analyses of site conditions and proposed remedial action decisions.
No
Yes
Complexity:
Notes:
* Are more than two agencies reviewing?
* Are new reporting formats required?
* Are there potential multi-media remedies?
* Are there more than five alternatives analyzed?
Other:
no uncomplicated average complex
U 2*J 2*
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TASK 12 POST RI/FS SUPPORT
ALLOCATION
This task is initiated once the RI/FS is completed. It includes such tasks as preparing
the proposed plan' pre-design activities' and close out of the work assignment.
No
Yes
* Will a pre-design report be prepared?
* Will ROD support be required?
* Will a responsiveness summary be prepared?
* Is an addendum to the FS likely?
* Are there numerous comments from the public' including
PRPs?
Other:
Site type:
no uncomplicated average complex
Q i Q 20 40k$
Notes:
TASK 13 ENFORCEMENT SUPPORT
ALLOCATION
This task includes work done during the RI/FS Project which is for the purpose of
supporting enforcement actions (consult enforcement personnel).
No
Yes
Will additional PRP search work be needed?
Is an RI/FS takeover by the Fund possible?
Is an RI/FS enforcement action possible?
Will preparation for RD/RA special notice(s) be required?
Will the PRP be a Federal Facility?
Are State issues involved?
Other:
Site type:
Notes:
no uncomplicated average complex
0 90 "30 4SH;
\J jLAJ J\J T-_JJViJJ
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TASK 14 MISCELLANEOUS SUPPORT
No
ALLOCATION
This task was established to account separately for minor work effort
associated with* but not directly a part of* the RI/FS process. It is not a
contingency fund. The budgeted amount is for allied items like:
Yes
* Assistance to ATSDR in review* update* etc.
* Support for related State or local projects
Since these costs cannot be estimated at this point* a nominal amount
(10k$) should be budgeted* unless it is known that there are specific site
circumstances that can be expected to occur.
Site type:
no uncomplicated average complex
0 10 10 10H;
\J L\J L\J 1 v/JVtP
Notes:
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DEALING WITH CONTRACTORS
As RPM you will be dealing with contractors. As in all relationships
some work out better than others. What the contractor is contracted to do
is specified in the contract Scope of Work. Scope changes (change
orders) are expensive and time-consuming actions and should be
examined carefully and used sparingly. Only the Contract Officer can
change the Scope of Work. Do not make verbal commitments about
work assignments to contractors. These frequently result in a request for
a change order. Only the Contract Officer can make commitments.
Be sure that you review all contractor invoices. Make a careful check of
hours and skill level versus work accomplished. Compare task actuals
against budgets to guard against cost or labor hour over-runs. Catch
budget problems early so they can be fixed in time. Resolve to set
objectives with costs as well as results in mind. Ask questions and insist
on justifications for things that are not clear. After all* it's your project.
Most contracts have incentive award provisions. This is a bonus payable
as a percentage of the total contract cost* and is for rewarding the
contractor for above average performance. In most cases the award will
be substantial. This should not be treated as a contractor's right* but
should* if awarded* be fairly earned. You are in a position to influence
if* and how much* of the award fee will be granted. Be prepared to
justify your recommendations with facts and figures.
Subcontracts are entered into by the prime contractor who is responsible
for screening and selecting appropriate candidates. The sub-contractor
will be responsible to the contractor. You are free to look at a
subcontractor's work at any time* but leave all direction of the sub to the
prime. Any comments you have should be directed to your contractor**
not the sub.
Avoid asking your contractor to perform personal services such as
typing notes for you or writing any report that you* as Project Manager**
are responsible for.
Don't turn over your decisions to a contractor. It is your project and you
and your management should assume the responsibility for all major
decisions.
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PHASING THE INVESTIGATION
Phasing an investigation allows you flexibility in the early stages of the work by
not requiring high levels of sampling accuracy or precision while establishing ball-
park values. These phase on data then become design parameters for follow-on
focused data quality objectives.
To benefit from conducting the RI in phases each phase must be designed to use
the information developed in prior work. This will improve the design of
subsequent steps and improve efficiency. By phasing the work logically you can
identify potential mistakes or faulty initial information and save valuable time and
expense by not developing unproductive lines of investigation. Logical phasing
allows you to focus on a more narrowly defined objective.
While phasing the work you should not assume that the RI/FS will extend over a
longer period of time. If the phasing is done correctly it should result in efficiencies
over a "heads up" approach or study designs that are entered into without valid
knowledge about actual site conditions. Examine proposals for phasing the work
carefully to make sure it will benefit the progress* not just divide the tasks into sub-
tasks which will take longer and result in a higher cost. If a phased study cannot be
clearly shown to lead to improved output* less time or lower overall costs* it
shouldn't be done.
DRILLING SAMPLING WELLS
A significant cost item in RI/FS projects is drilling and casing test wells for
groundwater sampling. In addition to per foot drilling costs* larger diameters and
stainless steel casing add considerable expense to installing a well. Small diameter
(two-inch) wells are adequate for sampling only. If there is a strong possibility that
pump-and-treat will be a potential remedial methodology* installation of a larger
diameter well may be justified during the initial Field Investigation sampling.
Casing material should be chosen based upon its chemical and structural resistance
to natural groundwater chemistry and the chemistry of the constituents of concern.
The materials should retain their structural integrity and neither adsorb nor leach
chemical constituents which would bias groundwater samples. Stainless steel casing
and screen materials should be used in the saturated zone when sampling for
volatile organics. Stainless steel should not be used in acidic* corrosive
environments when the constituents of concern are metals rather than organics:
under these conditions* P VC or flurocarbon resins are preferable. P VC well casings
and screens are appropriate only if trace metals or non-volatile organics are the
contaminant anticipated. Composite wells may be constructed with PVC casing
materials in the unsaturated zone and more inert materials (such as stainless steel) in
the saturated zone.
A large part of well drilling costs is in mobilization to get all of the required
equipment on site. Some checking of local climate history will keep from
scheduling activities during periods of normally expected inclement weather.
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DATA QUALITY OBJECTIVES
In establishing Data Quality Objectives it is important to
distinguish between what is possible* what would be nice* to
have* and what will be adequate. Outline what data you think
you will need to have at various decision making stages of the
work and determine how confident you need to be about the
reliability of the data. Use different data specifications for
different data uses. If there is a breakpoint value of 10 and the
observation is about 14* then there is nothing added if the
measurement were extended to 14.236* especially if it is more
costly to to provide the added precision.
Accuracy is more important than precision. A tape measure may
allow you to measure with an indicated precision of a
hundredth of an inch but it may not be accurate. Initial data
used to establish yes or no decisions or ball-park estimates need
not be very precise* but it should be accurate.
Some chemical concentrations on site may need to be measured
to the parts per billion range. These are difficult measurements
to make reliably. If you specify a high level of data quality
make sure it will be worth the effort.
Since soils* surface water* and ground water in different regions
contain a variety of natural* chemicals* be sure to determine
the site background before drawing conclusions from sampling
results. There are lots of concentrated mineral deposits. A
representative site sample is not taken after a hard rain or
during a hard freeze. There should be up* grade sampling
locations in at least two orthogonal directions unless you're
sitting on top of a knoll.
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CONTRACT LAB PROGRAM
Don't automatically assume that all analyses have to be
performed by Contract Lab Program (CLP) services. You can
often save time and effort by using portable* on-site mobile
laboratory services* or other fixed labs for rapid results. These
results can guide the progress of the work and allow you to
send a smaller number of samples to the CLP for confirmation
purposes.
Assignment of samples to the CLP for analysis should not be
abused. Because this is a service* it does not appear on the
RI/FS project budget. It is* however* an expensive procedure
and a significant budget item within Superfund. Furthermore**
CLP resources are limited and excessive testing for one site
may preclude needed analysis at another.
A review of FS reports from completed projects often shows
that even though round one sampling results are negative the
same parameter analyses are requested in each successive
round. CLP resources are too valuable to be wasted. Scale back
testing requirements by eliminating parameters that were
conclusively negative in earlier tests.
Site samples analyzed by CLP services take an average of a few
months to produce results. Why not consider at least a first
look* sampling on-site instead of marking time waiting for the
results? A well run mobile lab can produce results as good as
any other facility* and maybe better because the sample isn't
preserved** transported* or left sitting on a shelf for a few
months waiting to get into the analytical schedule. Samples can
change with time* as a result of pressure and temperature
changes* exposure to air or light* etc. Besides* if you uncover
something interesting* you can follow it up immediately if
you're on site. Mobile lab services can replace CLP service if
QA/QC certification is adequate.
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HEALTH AND SAFETY
Safety is a full time job and deserves to be foremost in planning
site work. After you become familiar with your site conditions"
examples of satisfactory Health and Safety Plans used at other
sites can be used as guides in adapting them to your site
conditions* or evaluating a contractor proposed plan. It isn't
necessary to start from scratch every time.
Field Investigation costs are very sensitive to the required
worker protection level. Site work should be scheduled with
respect to required protection levels because of the reduced
efficiency of operations using protective measures. In hot
weather* using class B protection can triple on-site labor costs
because of the reduced time a single worker can perform under
the restricted conditions.
ENFORCEMENT CONSIDERATIONS
While the quality of your work should always be as high as it
can reasonably be* it is particularly important in defending
conclusions drawn from data. A large quantity of sloppy data is
no match for a smaller quantity of high quality data when in
court. Potential litigation for cost recovery from Responsible
Parties need not drive up the cost of your project if the
planning and conduct of the work is monitored carefully as
the work progresses so that there are no significant omissions
that would require costly fixes.
Remember* enforcement is charged with trying to recover the
cost of site cleanups from PRPs. You may be called on to
defend any action you took during the RI/FS as being
necessary and economically sound
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COMMUNITY RELATIONS DEALING WITH THE PUBLIC
People like to be in* on what's going on
Always answer inquiries promptly
Play it straight tell the truth don't get angry
Present your case in layman's terms* the way you would
explain activities to your parents
A readable sign at the point of site access can explain
activities to curious locals and help to limit unauthorized
access if the site is not fenced
Utilize your regional office community relations staff
resources
Clear major information releases with other related
agencies first
Keep the public administrative record neat and timely
Inexpensive Community Relations Activities
Keep Photographic Record of Progress
Check in with Local Police and Fire Groups
Volunteer a Short Talk to Service Clubs
Local Newspapers Thrive on Local Stories
Meet and Brief Local Politicians
Visit Local High School Science Classes
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REFERENCE DOCUMENTS
The following is a selection of reference material which
will provide a great deal of information on conducting RI/FS
projects. The first three should be reviewed for overall
philosophy and guidance. They will provide some of the
professional background for your site planning.
1. The RPM Primer
EPA 540/G87/005- September 1987
2. Superfund Federal Lead Remedial Project
Management Handbook
EPA 540/G87/001-December 1986
3. Guidance for Conducting RI and FS Under CERCLA
EPA/540/G-89/004'October 1988
4. Data Quality Objectives for Remedial Response
EPA 540/G87/003 and 004' March 1987
5. Guidance on Remedial Actions for Contaminated
Groundwater at Superfund Sites
EPA/540/G-88/003'December 1988
6. Technology Screening Guide for Treatment of
CERCLA Soils and Sludges
EPA/540/2-88/004' September 1988
7. CERCLA Compliance with Other Laws Manual:
Parts 1 and 2
EPA/540/G-89/006 and 009
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NOTES
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