EPA/540/G-81/OlOa
Directive No. 9635.1 (c)
GUIDANCE ON OVERSIGHT OF
POTENTIALLY RESPONSIBLE PARTY
REMEDIAL INVESTIGATIONS AND
FEASIBILITY STUDIES
Final
U.S. Environmental Protection Agency
Office of Waste Programs Enforcement
Washington, D,C. 20460
VOLUME 1
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o
ACKNOWLEDGEMENTS
This document.was developed by the Guidance and Evaluation Branch of the CERCLA
Enforcement Division in EPA's Office of Waste Programs, Enforcement Matthew
Charsky served as EPA's Project Coordinator. The project was directed by Sally
Mansbach, Acting Director CERCLA Enforcement Division, with the assistance of
Arthur Wei&sman, Guidance and Evaluation Branch Chief.
The foUowky Regional, State, anil" Headquarter individuals provided significant input in
the development and review of this document:
Susan Cange EPA, OERR
Perry Katz EPA, Region 0
Patricia Tan EPA, Region ffl
Donald Guinyard EPA, Region IV
Rick Karl EPA, Region V
Pauletta France-kens EPA, Region VII
Jeff Rosenbloom EPA, Region EX
Wayne Grother EPA, Region X
Kevin Cabbie EMSL-LV
JohnRotert EMSL-LV
. TonyDiecidue EPA, OWPE
Carrie Capuco EPA, OWPE
Patty Bubar EPA, OWPE
Rashalee Levine EPA, OWPE
Steve Hooper EPA, OWPE
Steve Golian EPA, OERR
Pml King EPA, OERR/AZ State
Sandra Conners EPA, OECM
This handbook was produced by PRC Environmental Management, Inc., under EPA
Contract Ho. 68-01-7331. Paul Dean served as Project Manager for PRC Environmental
Management,
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TABLE OF CONTENTS
. >- -'4 /i-i'v- -
Chapter ' ' " PJ8§
' - .v
1 OVERSIGHT ROLES AND RESPONSIBILITIES . '. '. 1-1
INTRODUCTION l-l
1.1 , PURPOSE OF OVERSIGHT . , . . . : 1-2
1 . - OVERSIG!!"" .!*££ JuNNEL ANJ RESPONSIBILITIES AT
ENFORCEMENT-LEAD SITES 1 , 1-3
1.3 OVERSIGHT RESPONSIBILITIES AT STATE-LEAD SITES 1-13
1.4 OVERSIGHT RESPONSIBILITIES AT FEDERAL FACILITIES I-1J
1.5 STANDARDS OF CONDUCT, NONCQMPLIANCE, AND DISPUTE
RESOLUTION 1-17
/ _
1.6 SCHEDULE FOR OVERSIGHT . . 1-20
1.7 TOOLS FOR OVERSIGHT ..,..,, . 1-21
2 PRE-RI/FS NEGOTIATION SCOPING , 2-1
2.1 INTRODUCTION . '. 2-1
2.2 PURPOSE AND GOAL FOR THE RPM . 2-1
2.3 TIMEFRAME . 2-2
2.4 HOW THE RPM PERFORMS "PRE-SCOPING" 2-2
2.5 FOR FURTHER INFORMATION '..'..... 2-12
2.6 RESOURCES AVAILABLE TO RPMS 2-13
2.7 HELPFUL HINTS FOR THE RPM 2-13
3 POST-AOC SCOPING 3-1
3.1 INTRODUCTION 3-1
3.2 PURPOSE AND GOAL FOR THE RPM ... 3-1
3.3 TIMEFRAME ............;; !....-..... 3-1
3.4 HOW THE RPM OVERSEES POST-AOC SCOPING 3-1
3.5 DELIVERABLES DURING POST-AOC SCOPING . 3-8
3.6 FOR FURTHER INFORMATION ..-..' 3-J1
3.? RESOUP ?ES AVAIL/ 1LE TC "TWl RPM . . 3-12
3.8 HELPFUL HINTS FOR THE RPM . . -. . . . 3-13
111
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TABLE OF CONTENTS
Page
4 SITE CHARACTERIZATION . . ____ ........ . . ........... ...... _______ 4-1
4.1 INTRODUCTION ........ ............ ' . . . : ........ I .......... 4-1
4.2 PURPOSE AND GOAL FOR THE RPM . ____ ..... / .............. . 4-1
4.3 TIMEFRAME ____ ....... ...... . . ; ., ---- , ................... 4-1
4.4 HOW THE RPM OVERSEES SITE CHARACTERIZATION ...... ..... 4-2
4,5 DELIVERABLES DURING SITE CHARACTERIZATION . , . . ; ....... 4-5
' 4.6 FOR FURTHER INFORMATION .... ......... :...... ....... ... 4-7
4.7 RESOURCES AVAILABLE TO THE RPM ...... ..... ............. 4-7
4.8 HELPFUL HINTS FOR THE RPM : . ...... ...................... 4-8
5 BASELINE RISK ASSESSMENT ............ ..... ........... ...... ... 5-1
5.1 INTRODUCTION .... ....... ............ . ...... ......... .... 5-1
/ 5.2 PURPOSE AND GOAL OF THE BASELINE RISK ASSESSMENT ____ ,. 5-1
5.3 TIMEFRAME ____ ..<... ....... . .................... . . ...... 5-2
5.4 HOW THE RPM OVERSEES A PRP RISK ASSESSMENT ......... .... 5-2
5.5 DELIVERABLES DURING OVERSIGHT OF A PRP BASELINE RISK
ASSESSMENT .....;...... ---- . ...... ........ ---- . ....... . . 5-5
5.6 FOR FURTHER INFORMATION ! ...... . ....... . ........ . ....... 5-6
5.7 RESOURCES AVAILABLE TO RPMS .... ...... . ...... .......... ,5-7
5.8 HELPFUL HINTS FOR THE RPM . . . '. ......... ... ...... . ....... 5-7
6 TREATABILITY STUDIES ......... . ............. . ---- ............. 6-1
6.1 INTRODUCTION ................ . . ---- : . . ---- ,. . . . ---- . . ---- 6-1
. . 6.2 PURPOSE AND GOAL FOR THE RPM ____ ........ ---- . ......... 6-1
6.3 TIMEFRAME ., ...... . . ....... . ---- ............. ............ 6-2
6.4 HOW THE RPM OVERSEES TREATABILITY STUDIES . . ...... . ---- 6-2
6.5 DELIVERABLES DURING TREATABILITY STUDIES .............. 6-5
6.6 FOR FURTHER INFORMATION ........ .......... ........... 6-8
6,7 RESOURCES AVAILABLE TO THE RPM ---- . .............. ...... 6-9
6.8 HELPFUL HINTS FOR THE RPM ... ...... . ........ . . ---- ...... 6-10
iv . '
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LIST OjRACRONYMS
(continued)
SCAP
SCEES
SEAM
SFWS
SGS
SHPO
SI
SIF
SITE
SMOA
SNL
SOP
SOW
SPO
SRI
START
TAP
TAT
TSCA
TES
TRIS
TS
TST
UAO
UIC
USCOE
USDA
USFWS
uses
WD
WMD
WP
Superf und Comprehensive Action Plan
Site Cost Estimate and Evaluation Study
Sunerfunu Exposure Assessment Manual
State Fish and Wildlife Service
State Geological Survey
State Historic Preserv?»
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LIST O* TAI LES
Table . . ' . : . . ' Page '
1-1 Capabilities and Specialties of Various Oversight Resources ......'... 1-5
:' '..' ' LIST OF FIG! THES '. "
"* * r ' * *" ' .
Figure , ' , Pjgg
1-1. Phased RI/FS Process ...... ; . . .. 1-4
1-2. Limits of the Oversight Assistant's Roles 1-12
1-3. Types and. Uses of CERCLA Cooperative Agreements 1-14
1-4. Usual Dispute Resolution Process 1-19
1-5. Recommended RI/FS Process: Ideal Scenario . 1-22
1-6. Categories of RI/FS Deliverables ,....<,..,,.., 1^29
. ' t '
>
1-7. Types and Uses of QC Samples 1-31
1-8. Overview of'the Process , ; 1-33
2-1. Useful Sources of Existing Data 2-3
2-2. Overview of the Site File 2-5
2-3. General Physical Conditions . 2-7
2-4. Basic Description of Contamination 2-9
2-5. Program Overview .........;.. 2-11
3-1. Summary of a Kickoff Meeting . 3-3
3-2. Summary of Cost Recovery Documentation .....' 3-6
3-3. Summary of Administrative Record File ....................;.. 3-8
3-4. Elements of Project Plans 3-9
/ .
4-1. Summary of Tools ......' .-.' 4-4
, ~ .
6-1, Kinds of Treatability Studies 6-4
6-2. Predicted Treatment Effectiveness for Contaminated Soil 6-7
8-1. Summary of Nine Evaluation Criteria, £-2
VI
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Purpose
CHAPTER1
OVERSIGHT ROLES AND TOSTONSfiBIUTIES
INTRODUCTION
Volume I of this document addresses oversight of remedial investigations and
feasibility studies (RI/FSs) conduced by potentially .-responsible parties (PRPs)
at enforcement-lead sites addresse under the Compiehensive Environmental
Response, .Compensation and Liability Act, as amended (CERCLA). It
parallels activities described in the "Guidance for Conducting Remedial
Investigations and Feasibility Studies Under CERCLA" (OSWER Directive
No. 9355.3-01, October, 1988, referred to here a* the "RI/FS Guidance") and
the "Model Statement of Work for a Remedial Investigation and Feasibility
Study Conducted by Potentially Responsible Parties" (OSWiR Directive
No, 9835.8, June 2, 1989, referred to here as the "Model SOW for PRP-lead
RI/FSs"). It provides project managers with the procedures required to
organize and perform appropriate oversight duties and responsibilities. This
document is guidance only; it is not a binding set of requirements and does not
create rights for any party.
Volume 2 describes the oversight of sampling and analysis activities (Appendix
Bl) and of well drilling installation activity (Appendix Cl) conducted during a
PRP RL Checklists to assist in the documentation of sampling and analysis
activities and well drilling and installation activities are also found,
respectively, in Appendices B and C.
For a more in-depth discussion of the entire Superfund Enforcement Program
including removal and remedial actions, refer to the "Enforcement Project
Management Handbook" (OSWER Directive No. 9837.2-A, Janua. y 1991).
The handbook addresses the remedial planning and implementation process
from the point of the baseline PRP search (generally conducted after the site is
placed on the National Priorities List (NPL)), to the point of completion of
remedial activity and the site's deletion from the NPL.
Intended
Audience
The intended'audience for this document is remedial project managers
(RPMs), although it can be adapted for use by other parties such as States,
PRPs, contractors and other persons involved in the RI/FS process.
Summary of
Chapters and
Appendices
Volume 1
Chapter 1, "Oversight of PRP RI/FS Activities" gives an overview of the
oversight process and the roles and responsibilities of the different
participants. This chapter also discusses standards of conduct, a schedule for
oversight, and tools available to assist the RPM in performing good oversight.
This chapter is intended for those in the audience with little or no background
in the oversight process.
1-1
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Chapter 2, "Pre-RI/FS Negotiation Scoping" discusses how an RPM performs
site planning with Regional personnel and technical experts prior to
negotiations with the PRP. ,,.
Chapter 3, "Posi-AOC Scoping" discusses the RPM's detailed site-specific
planning of activities during the Rf/FS and the PRP's development of Project
Plans (for example, Work,Plan, Sampling and Analysis Plan, and Health and
+ Safety Plan) prior to the initiation t'ield activities.
Chapter 4, "Site Characterization" discusses how the RPM oversees PRP-
conducted. field activities, with the help of an oversight assistant, in order to
gather data that characterizes the site, defines the site risks, and helps to
evaluate potential alternatives. .
Chapter 5, "Baseline Risk Assessment" discusses the RPM's oversight of PRP-
conducted Baseline Risk Assessments begun before June 21, 1990 and provides
assistance to the RPM and oversight assistant for all EPA-conducted Baseline
Risk Assessments begun after June 21, 1990.
Chapter 6, Treatability Study Task" discusses how the RPM determines the
need for treatability studies and oversees the conduct of treatability studies
during the RI, which should assist in developing viable alternatives in the FS.
Chapter 7, "Development and Screening of Alternatives* discusses the process
of using preliminary remediation goals (PRGs) and the data generated during
the RI to establish performance standards and then develop alternatives that
can satisfy those standards and EPA's nine evaluation criteria.
Chapter 8, "Detailed Analysis of Alternatives* discusses the comparison and
relative performance of the alternatives against EPA's nine evaluation criteria
in order to select an appropriate remedy.
Appendix A, Technical Resources Available to RPMs and Oversight
Assistants* is a mini-bibliography of technical resources at the Federal, State,
and local government levels available to RPMs and oversight assistants.
In addition to Volume 1, a companion guidance document containing two
appendices is being issued to address the identification and resolution of
specific site problems encountered by the RPM during the site characterization
task of the RI.
*
** , .
Volume 2 Appendix B, "Oversight and Documentation of Field Activities Including
Sampling and Analysis Procedures" describes the activities that the oversight .
team should conduct during field activities.
Appendix C, "Oversight and Documentation of Well Drilling and Installation
Activities* describes the activities that the oversight team should conduct
during well drilling and construction activities.
1.1 PURPOSE OF OVERSIGHT ,
The purpose of oversight is to ensure that an RI/FS prepared by a PRP in an
Enforcement-lead response action is equivalent to the RI/FS that EPA would
have prepared if the site were Fund-lead. The RI/FS must conform to the
. ' ' 1-2'
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,v,r.'VJ.xp,'i' " '
requirements of the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP), applicable Agency guidance, and any existing
Administrative Order on Consent (AOC), Consent Decree (CD), or Unilateral
Administrative Order (UAO). Through oversight, EPA provides direction,
assures quality, and avoids and solves problems in the conduct of the RI/FS
(see Figure 1-1, Phased Rl/FS Process).
Note: The terms and condition* governing RI/FS activities may be specified
" in one of three types of ulement documents, an AOC, CD, or UAO.
The AOC, however, is tha preferred settlement document. This
guidance will use "AOC* exclusively when referencing a settlement
document with the understanding that the term encompasses AOCs,
CDs, and UAOs for purposes of this guidance. , .
Under CERCLA Sections I04(a) and 122(a), EPA has the discretion to allow
PRPs to perform an RI/FS and to conduct other response actions. A recent
change in policy for the PRP RI/FS process is that EPA will not enter into
AOCs under which the PRPs perform the risk assessment component of the
RI/FS for new risk assessments is of June 21, 1990 (see Chapter 5.) The
RI/FS, even though conducted by the PRP, must still be conducted to EPA's
standards. EPA determines whether the RI/FS is acceptable, not the PRP.
Based primarily upon and supported by the RI/FS, EPA determines if the site
warrants remediation and, if so, selects the remedy. Overall, EPA is
ultimately responsible for ensuring that the response actions taken at a site
protect human health and the environment and meet statutory requirements for
response actions.
s 3
EPA or an authorized State oversees the conduct of a PRP-lead RI/FS. A
PRP-lead RI/FS must be as comprehensive as a Federally funded RI/FS and
must be of comparable quality. However, because PRPs do not work directly
for EPA, the way EPA oversees a PRP-lead RI/FS must, in some ways, differ
from the RI/FS process at Federally funded NPL sites. EPA's oversight
authority over PRP-lead RI/FSs includes the ability to enforce the AOC, seek
penalties, and ultimately take over the project followed by cost recovery.
Good oversight minimizes EPA's need for using judicial enforcement to obtain
, the quality RI/FS that EPA and the PRPs agreed to in the AOC. Good
planning, continuing review of PRP site activity and deliverables, and regular
and effective communications between EPA and PRPs are key items for
oversight,
1.2 OVERSIGHT PERSONNEL AND RESPONSIBILITIES AT ENFORCEMENT-
LEAD SITES
Introduction The RPM, with support from a contractor (usually Technical Enforcement
Support (TES) or Alternative Remedial Contract Strategy (ARCS)) that is
designated the oversight assistant, oversees the RI/FS. RPMs can get further
assistance from within EPA, other Federal agencies, and individual State
agencies. Together, the RPM, oversight assistant, and additional qualified
personnel in EPA or other Federal and State agencies form the Oversight team.
Table 1 -1 lists sources of assistance available to the RPM and the oversight
assistant during specific tasks of the RI/FS process. Appendix A expand on
this table, describes area(s) of expertise, and explains how to access these
resources. For additional information, refer to the "Enforcement Project
1-3
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figure 1-1. Phased Rl/FS Process
FROM:
Prefcrtnary Stte
Assessment -
Site Inspection
NPiUsteg
REMEDIAL INVESTIGATION
, PR&WFS
NEOOTUTKJN SCOPMO
Obtato General Under-
stand^ of the Site
Coted Existing Data
U«9 Technical Support
Team
/
Visit Site to MentHy
Potential Areas of
Concern
Generate Statement of
Work
1
HOOF
RVF3
xtating Data
SITE
CHARACTERIZATION
Conduct Held Investigation
* Define Nature and Extent of
Contamination (Waste
Types, Concentrations,
Distributions)
Identify federal/Slats
Chemical and Locaaorv
SpecfflcARARs
BASELJME
RISK ASSESSMENT
Coded and Evakiaia Data
* Perform Exposure
Assessment
* Perform Toxicity
Assassment
* Characterise Risk
TflEATABIOTY
INVESTIGATIONS
Perform Bencri or Pilot
Tf eatability Tests (As
Necessary} "
.-
WentHy Project Needs/
Operabte Untt, Ukery
Scenarios, and .
. remedial Adon
Objectives
Initiate Federal/State
ARAB Identification
Prepare Project Plans
I
I
FEASTBIUTY STUDY
DEVELOPMENT AND SCREENING
OF ALTERNATIVES
> Develop Preliminary Remediation Goals
»Identify FederaVSIate AcUon-SpeolHc
ARARs
Identify Potential Treatment Technology,
Contakment/Disposal Requirements tor,
Residuals or Untreated Waste
»Screen Technologies
> Assemble Technologies into Alternatives
DETAILED AN*'""IS
OF ALTERNATIVES
* Moddy Preliminary Remediation Goals
* Further Refine Alternatives ; As Necessary)
Analyze Alternatives Against the Nine
Criteria
* Compare Alternatives Against Each Other
TO:
Remedy Selection
Record ol Decision
Remedial Design
,, Remedial Action
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Table 1-1. Capal iilities and Specialities of Varto-« Oversight Resources (Page 1 of 4}
PRP-Lead RI/FS Tasks
ovnstiar \/P/S/S/S/Jd*W
RESOURCES |/^ / * / * / *r/ * /v" ^ ^r
£FA Regional Offices and Divisions -
Technical Support Team
(TST) or Regional
Equivalent
Environmental Services
Division (ESD)
Peer Review Group
,"
Office of Regional Counsel
Pesticides and Toxics
Division
Water Division
Air Division
Office of Public Affairs
Health Assessment Officer
Risk Advisory Committee
EPA HQ
Office of Waste Programs
Enforcement (OWPE)
Office of Emergency and
Remedial Response
(OERR)
Office of Enforcement -
Superfund Division
Office of General
Counsel
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1 As of June 21,1990, EPA's policy ii not to oiler inio AOCs under which PRPs pcrfefm the risk useuRtent component of
the RI/FS w documenttd in memormduin of August 28,1990.
1-5
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Table 1-1. Cape > ill ties and Specialities of Various Oversight Resources (Page 2 of 4)
PRP-Lead RI/FS Tasks
OVERSIGHT
RESOURCES
EPA HQ (cant.)
Office of Solid Waste and
Emergency Response
Assistant Administrator's
Office (QSWER AA) '
Other EPA Offices
Office of Research and
Development (ORD)
National Enforcement
Investigations Center (NEIC)
Environmental Response
Team(ERT) .
EPA Contracts
Alternative Remedial
Contracting Strategy (ARCS)
Technical Enforcement
Support
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Table 1-1. Capabilities and Specialities of Various Oversight Resources (Page 3 of 4}
" "
OVERSIGHT
RESOURCES
Other Federal Agencies (cont.)
Department of Interior (cont.)
* Bureau of Mines
« Natural Resources
Trustee
Department of Agriculture
(USDA)
Soil Conservation
Service
Forest Service
Agriculture Stabilization
and Conservation Services
Department of Commerce
National Oceanic and At-
mospheric Administration
Department of Energy (DOE)
Nuclear Regulatory
Commission (NRQ
Department of Health and
Human Services (HHS)/
Agency for Toxic Substances
and Disease Registry
(ATSDlg
Department of Justice (DO J)
Department of Labor
» Occupational Safety and
Health Administration
(OSHA)
Federal Emergency Manage-
ment Agency (FEMA)
Department of
Transportation (DOT)
* U.S. Coast Guard
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Can Provide '
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Answer Queitiotu
O Cm Provide Addition*!
Dm «nd Previou*
Studiei ''
1 As of June 21,1990, EPA's policy is not to enter into AOCs under which PRPs perform the risk assessment component of
the RI/FS as documented in memorandum of August 28,1990.
1-7
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Table 1-1. Capabilities and Specialities of Various Oversight Resources (Page 4 of 4)
PRP-Lead RI/FS Tasks
OVERSIGHT I
RESOURCES 1
State Assistance
Stale Agency for
Environmental Protection
Public Health Agency
State Attorney General Office
Court Records of Legal Action
State Fish and Wildlife Service
Slate Soil Conservation Service
State Geological Survey
State Historic Preservation Offiw
State Highway Department
State/Private Academic
Institutions
Local Assistance
County or City Health
Departments
Local Planning Boards
Chamber of Commerce
Town Engineer
Local Library
Local Well Drilling Companies
Local Airports
Residential and Municipal
Well Logs
//
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-------
Management Handbook" (OSWER Directive No, 9837.2-A, January 1991), and
Technical Support Services for Superfund Site Remediation - Interim
Directory" (Winter 1989).
Prospects for a quality PRP RI/FS are greatly enhanced when a PRP fully
understands what EPA expects, .frequently communicates with EPA, and
submits periodic deliverable? on a pre-detertnined schedule. PRPs need to:
Maintain records and other ; oje it documentation;
* Keep the RPM informed of progress and problems encountered during the
required activities through progress reports and meetings; and
* Submit acceptable deliverables within the timetable agreed upon with the
lead agency.
The extent of oversight responsibilities should be discussed during
negotiations, defined in the AOC and its attached Statement of Work (SOW),
and implemented as site-specific conditions require. To further understand
oversight responsibilities in their entirety, all parties involved should
thoroughly review, both this chapter as well as Chapters 2 through 8, Appendix
A in this volume and Appendices B and C in Volume 2, and the RI/FS
Guidance (October 1988).
Remedial
Project
Manager
(RPM)
The RPM is the EPA official with primary responsibility for overseeing all
remedial response actions undertaken by PRPs. The specific duties of the
RPM may vary from site to site and will generally depend upon the PRP*s
commitment to the project and the complexity of the site. The RPM's duties
are discussed, in detail, in Chapter 2 of this manual.
During oversight of a PRP RI/FS, RPMs perform both Regional and other
activities throughout the process, including:
Regional Activities
* Approve an oversight assistant and manage his/her activities;
* Identify persons/agencies/extramural resources with particular expertise
that will provide technical review of activities and deliverables and agree
to the scheduled timeframes;
* . Identify the preliminary scope of RI/FS activity; .
* Identify the site-specific activities and deliverables required from the PRP;
* Prepare a project schedule for the AOC and monitor PRP adherence;
* Budget intramural and extramural resources to support the project and
associated paperwork;
Verify that the planned activities will meet NCP requirements, satisfy Che
RI/FS objectives, and satisfy the provisions of relevant guidances;
* Consult with counsel; '
1-9
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Review all PRP and oversight assistant deliverables to assure quality and
provide related technical comments;
* Obtain internal EPA input on specialized matters (for example,
groundwater contamination, fractured bedrock, contaminants without
toxicity values);
Adhere to EPA j>~> !ule for re jwing drliverables or meeting other
deadlines, *"'"''-,;.
Assure that any aspects of the RI/FS performed by EPA are done
promptly (for example, the risk assessment or, applicable or relevant and
appropriate requirements (ARAR) analysis);
/ f !
* Assure EPA management and legal review at major stages (for example,
Work Plan, draft RI, proposed plan, and record of decision (ROD));
» Finalize any supplements to the RI/FS and write the proposed plan and ,
ROD; and
* Provide monthly updates of budget and project schedule data in the
CERCLA Information System (CERCLIS) in coordination with Regional
Information Management Coordinator (IMC).
Other Activities ', '<>..,'
Coordinate with the State and, as appropriate, other agencies (for example,
Department of Interior (DO!), National Oceanographic and Atmospheric
Administration (NOAA), Agency, for Toxic Substances and Disease
- Registry (ATSDR)) on scoping;
* Conduct scheduled and unscheduled site inspections in conjunction with
the oversight assistant; , .
* Meet with PRPs periodically to communicate EPA's requirements and
discuss work progress;
* Maintain communication with the State throughput the RI/FS process with
an emphasis on understanding State perspective, the State identification of
ARARs, and the coordination of community relations;
» Conduct community relations j itivities, with assistance of the community
relations coordinator;
. ' ' ! ' , '
* Maintain the site file, including cost recovery documentation; and
* Establish and update periodically the Administrative Record File in
conjunction with the Office of Regional Counsel (ORC).
Both the RPM's scope of responsibility and authority and the extent of
' oversight that will be required during the RI/FS will be addressed in the AOC.
The AOC must include specific provisions for oversight, such as the need to
address,the ;eimbursemev * of Age: ?.y oversight costs.
1-10
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Oversight
Assistant
The oversight assistant is the ^qualified person, usually a contractor, required
by CERCLA Section 104(aXl) to assist EPA with oversight. Qualified persons
have the professional qualifications, expertise, and experience necessary to
provide EPA with the assurance that it can provide effective oversight. EPA
selects the oversight assistant, and services performed by the oversight assistant
are paid for by the lead agency, which receives reimbursement through the
AOC from the ?RP. The oversight assistant typically will be a contractor
(TES or ARCS), In some cases, the oversight assistant may be provided by a
State through a Cooperative Agre -ment or by .another Federal agency, such as
the U.S. Army Corps of Engineei (USCOE), through an Interagency
Agreement; in both of these cases the oversight assistant can be a State or
Federal contractor.
The RPM has flexibility in defining the oversight assistant's responsibilities at
the site. The oversight assistant may be responsible for.
* Assisting in planning of project scope and schedule (see Chapter 2 and 3);
* Reviewing existing site information;
Monitoring PRP field activities to verify PRP performance in accordance
with the AOC, consistency with standard protocols, and use of generally
accepted scientific and engineering methods;
* Reviewing deliverables submitted by the PRPs;
* Conducting quality assurance tasks;
* Conducting EPA's risk assessment; .
* Drafting any necessary supplements to the RI/FS;
* Conducting contingency planning to protect human health and the
environment in the event of an emergency;
* Assisting in reproducing documents for the Administrative Record File in
the Regional office and at the site (decisions on what documents to include
are made by the RPM in conjunction with ORC); ,
* Preparing and assisting in implementing community relations deliverables
and tasks; and
Providing site-specific inforrt ition to the Regional IMCs for input into
CERCLIS.
Limits of the Figure 1-2 summarizes the limits of the oversight assistant's role. The
Oversight oversight assistant may be allowed to approve minor deviations in field acti-
Assistant'i vities due to situations beyond the control of the contractor for which there is
Role and an obvious solution. For example, these situations may include a change in a
Responsi- surface water sample location due to an unanticipated decrease in the water
bllitles elevation, flooding of a sample or well locution, or the presence of some other
physical obstruction (such as subsurface refusal). The oversight assistant
should contact and obtain the adv'-e of the RPM if the oversight assistant
believes there is any question of his or her authority to approve a deviation.
The oversight assistant mav not approve deviations from the Work Plans. Only
the RPM may approve these changes.
1-11
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Figure 1-2. Loniti of the Oversight Assistant'* Role*
The oversight assistant may be ai:*htrized to:
' » Monitor and document activities specified in the AOC, SOW, and,
Work Plan; ' ,' '
* Conduct quality assurance activities;
* Develop contingency plans for field activities; and
* Approve minor deviations that do not affect the site agreement or
Work Plan.
' '
The oversight assistant is NOT authorized to:
1 f . * '
» Approve modifications in the AOC, SOW, or Work Plan;
i
9 Undertake any responsibility of the PRP;
* Advise or issue directions to any PRP contractor; or
« Assume control of any aspect of the RI/FS,
Management The RPM or oversight assistant may be required to manage a staff of quality
of Site assurance personnel at sites where several activities are being performed
Activities concurrently. These personnel generally will be specialists in the activities
being performed and will conduct quality assurance tasks, including .
documenting procedures, obtaining split or duplicate samples, and providing
quality assurance tests of materials or workmanship. The staff may also be
responsible for providing health and safety monitoring for the community.
Management of the staff will include coordination and designation of each
staff member's responsibilities and daily compilation of activity logs and field
notes (see Section 1.7). !
Contingency The RPM or oversight assistant is also responsible for contingency planning.
Planning If there is an unexpected event or emergency, the RPM or oversight assistant
should be prepared to instruct their staffs and take the precautions necessary
to protect human health and the environment. Unexpected events might
include accidents, temporarily denied site access, a force majeure event, etc.
PRP events that lead to modifications to the Work Plan and disputes are the
responsibility of the RPM, not the oversight assistant.
RPM'i Rerievr
of Oversight
Assistant's
Responsi-
bilities
Prior to the initiation of site work, and periodically through the RI/FS pro-
cess, the RPM must review with the oversight assistant their respective roles
and responsibilities for the project. To help ensure continued proper
performance by the oversight assi- .ant, project responsibilities should be
documented in writing. Key areas to cover include:
1-12
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Review of Work Plans and.quality assurance/quality control (QA/QC)
plans; , - v"\^-/-Vv«ot;-'t'
» Review of existing site information;
* The frequency of site inspections;
The method of documenting field activities;
* The extent of OA/QC (in<-'»ading the number of split, duplicate, and blank
sarr;-c.5. c;u review of PJ } laboratory work (see Section 1.7.2, and
Volume 2, Appendix B));
* Reporting requirements to the RPM;
Continuing communication between the RPM and oversight assistant; and
Monitoring expenditures.
1.3
OVERSIGHT RESPONSIBILITIES AT STATE-LEAD SITES
Introduction CERCLA Section 121(f) and NCP Sections 300,500 to 300.525 require EPA to
provide opportunities for meaningful and substantial State involvement in the
long-term planning process for all CERCLA remedial actions within a State,
and in negotiations with PRPs at CERCLA facilities in that State. Federal
funding may be provided to States to support a broad range of Superfund
response activities. The State's role in overseeing PRP-conducted remedial
activities is determined largely during an annual planning process that takes
place between EPA and the State. A primary function of this planning process
is to determine who will take the lead responsibility for actions at the NPL
cites within the State.
State
Agreements
and Oversight
Activities
Designation of the State as lead may be embodied in a Superfund
Memorandum of Agreement (SMOA), a Cooperative Agreement (CA), or some
other document entered into by EPA and the State. EPA may designate a State
the lead responsibility for an enforcement response at any site within its
jurisdiction, other than a Federal facility. While CAs are legally binding and
often site specific, SMOAs represent a non-binding, general agreement
between the State and EPA that establishes their respective roles at NPL sites
within that State. Provided it has demonstrated to EPA the capability to do so,
the State can have responsibility for the lead role in notifying, negotiating, and
developing an enforceable settlement agreement with PRPs (under State law)
and overseeing site activities.
The SMOA, generally, is program-wide, rather than requiring specific-State-
involvement activities. The nature of overall EPA/State roles in oversight
should be outlined in the SMOA and is based on an assessment of the State's
technical and legal capabilities as well as on its experience in hazardous waste
management practices.
Under CERCLA Section
transfeis funds to a State
respor ibilities for ' site.
correspond to the pnases
EPA will only enter into
(usually the State's pollut
Governor or comparable
104{dXl), the CA is the assistance vehicle that
and documents both EPA's and the State's
T! _;-'e are sin different kinds of CAs that
of cieanup responses and support. (See Figure 1-3.)
a CA with the State agency for Superfund response
ion control agency) as designated by the State's
representative of a political subdivision or Federally
1-13
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Figure 1-3. Types and Uses of CERCLA Cooperative Agreements
Removal - These CAs are available to fund short-term actions taken to prevent,
minimize, or mitigate damage and to stabilize a site prior to further response
actions. Removals can include emergency activities, time-critical activities
(actions with planning periods of less than 6 months) and actions with planning
periods of more than 6 months. Under.curren' Kgency policy, the only removal
actions or which States may have the lead are* emovals with a planning period of
more than 6 months.
Pre-remedial - These CAs are available to fund Preliminary Assessments (PA) to
identify a site and the seriousness of a hazardous substance release, and Site
Inspections (SI) to eliminate from consideration those releases that pose no threat
to human health or the environment.
\ . '
Remedial - These CAs are available to fund long-term actions taken to prevent, ,
minimize, or eliminate exposure and damage to human health and the
environment.
Enforcement - These CAs are available to fund activities to recover costs for
cleanup from PRPs, to oversee cleanup of a site by PRPs, or to compel a PRP to
clean up a site (under State law). .
Support Agency - These CAs are available to States, political subdivisions, and
Federally recognized Indian Tribes to fund management activities that support a
site-specific non -State- lead response.
Core Program - These CAs are available to fund CERCLA program activities that
are not assignable to specific sites but are necessary to support participation by a
State or Federally recognized Indian Tribe in CERCLA response.,
recognized Indian Tribe, Enforcement CAs may authorize States with lead
responsibilities to undertake such activities as PRP searches,"notifications,
negotiations, and PRP oversight. (See 40 CFR Part 35, Subpart O for a listing
of all activities eligible for funding under enforcement CAs.) States, political
subdivisions thereof, and. Federally recognized Indian Tribes may apply for
enforcement CAs and in doing so must demonstrate that they have the
necessary authority, jurisdiction, and administrative capabilities to undertake
enforcement actions. States (or political subdivisions or Indian Tribes) must
also demonstrate, prior to receiving any Fund money through a CA for PRP
oversight, that they have attempted to obtain this funding from the PRPs .
themselves. . , - * ,
Even if the State does not take the lead in entering into and overseeing an
RI/FS settlement agreement, the State may, under certain circumstances,
undertake various, mutually agreed upon oversight activities at PRP-lead sites.
For example, States might participate in reviewing Project Plans or draft and
-final reports,1 overseeing field-related activities, or conducting community
relations activities. The. State may receive, support agency funding unde a
CERCLA Section 104(d) CA Cor performing these activities. The State's and
EPA's respective roles and responsibilities should be clearly defined in a CA.
1-14
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Additional information bn^thei
-------
important to note certain -1-tinci ons that may affect the RI/FS. These
distinctions are'based on the unique characteristics of Federal facilities:
, 'J The RI/FS will, generally, be conducted under Interagency Agreements
(lAGs), also known as Federal Facility Agreements (FFAs),.(including as
parties Federal facilities, EPA, and where possible, the State -- if it
chooses to join) rather than under AOCs; . - >
The RI/FS will usually be conducted by the other Federal agency; EPA, in
j general, would not conduct t! RI/FS (unless requested to do so, and
reimbursed for doing so, by \..s other Federal Agency);
Security clearances may be needed to gain access to parts of the facility for
oversight purposes; . ' "
* Exemptions from statutory requirements are possible with site-specific
Presidential orders for national security concerns; . '
Federal facility cleanups are sometimes very complex and may involve
more than one release and concurrent multiple tenant activities may exist
at each site;
* Federal funding for most remedial actions by a Federal facility does not
come from the Superfund appropriation to EPA, but out of an
appropriation from,Congress directly to the Federal agency; and
* Qualifying Federal facilities with Resource (Conservation and Recovery Act
(RCRA) regulated units routinely are listed on the NPL (at private sites
these facilities generally are not listed).
« t. v
CERCLA CERCLA Section 120 addresses the application of CERCLA to both NPL and
Section 120 non-NPL Federal facilities. EPA has developed, in conjunction with the
affected agencies, model language for key provisions of CERCLA FFAs (or
IAGs) for DOE (memorandum dated May 27, 1988) and for DOD
(memorandum dated June 17, 1988), Other Federal agencies should also be
using the model language as the basis for any IAG. .
Further - In response to the unique considerations of Federal facility oversight, EPA
Information created the Office of Federal Facilities Enforcement (OFFE). OFFE assists
the Regional media programs in overseeing the Federal agency implementation
of CERCLA Section 120 and other statutes. For further information regarding
Federal agency response programs, contact the appropriate Regional
coordinator in OFFE at (FTS) 475-9801. .
References concerning Federal facilities include the following:
* Federal Facilities Hazardous Waste Compliance Manual, OSWER Directive
9992.4, January 18, 1990;
Executive Order 12580, Superf und Implementation, January 23, 1987;
» Executive Order 12088, Federal Compliance with Pollution Control
<' . Standards, October 13, 1978;
-------
1.5
« NPL Listing Policy foPFefierai-Facilifies,' 40 CFR Part 300, 54
Register. March 13, 1989, p, 10520;
Federal Facilities .Negotiations Policy, OSWER Directive No. 9992.3,
August 10, 1989; , -
Enforcement Actions Under RCRA and CERCLA at Federal Facilities,
OSWER Directive No. 9992.0 'anuary 25, 1988;
Agreement with the Department of Defense -- Model Provisions for
CERCLA Federal Facility Agreements, OSWER Directive No. 9992.1,
June 1, 1988;, . .
* Elevation Process for Achieving Federal Facilities Compliance Under
RCRA, OSWER Directive No. 9992.1 a, March 24, 1988;
Agreement with the Department of Energy -- Model Provisions for
CERCLA Federal Facility Agreements, OSWER Directive No. 9992,2,
May 21, 1988; and
Subpart K of the NCP (pending proposal in FY91).
STANDARDS OF CONDUCT, NONCOMPLIANCE, AND DISPUTE RESOLUTION
Standards of The indmdual(s) performing oversight should be aware of certain standards of
Conduct conduct in addition to their specific responsibilities for the project. Oversight
personnel should perform their duties in a professional, responsible, and non-
confrontational manner.
Differences of opinion between the RPM or oversight assistant and the PRPs
or their contractor should be avoided. Any observations or suggestions
pertaining to field activities, which the oversight assistant or his/her staff may
have, generally should be discussed with the PRP field supervisor before
talking to the RPM. It should be noted, however, that there may be
circumstances that warrant checking with the RPM first. In discussions with
the field supervisor, the oversight assistant should avoid the appearance of
directing or approving work. Discussions with the PRP field supervisor should
be documented and reported to the RPM. For a State-lead site, the oversight
personnel should consult the SMOA, CA, or other agreement on the role of the
State at the time.
Non- If, after discussions with the field supervisor, the PRPs or their contractors are
compliance found not to be in compliance with the site plans, then the RPM should orally
contact the PRPs* project manager. Documentation of the conversation
between the RPM and the project manager should be in the form of either a
telephone log or meeting notes, whichever is appropriate. Formal notification
of noncompliance follows this final attempt at informal resolution.
<\
Disputes do not affect the PRPs' obligations to perform. PRPs must continue
to meet their obligations under the AOC while the dispute is pending or risk
the imposition of penalties if the resolution is unfavorable to the PRF
.,1-17
-------
' , Formal notification of .vocompliince occurs when a written notice of
disapproval is sent by the appropriate EPA official (usually a Branch Chief or
, , Division Director) to the appropriate PRP representative. Procedures for such
notification should be spelled out in the AOC.
/ *
Dispute Dispute resolution procedures are negotiated items for each AOC. If the PRPs
Resolution , object to EPA's notice of disapproval, they submit their written objections to
the designated EPA official (usua'V a Regional manager) within the period
: provided in the AOC (usually 14 lys) requesting formal dispute resolution.
Typically,.the parties have 14 days from EPA's receipt of the PRPs* objections
to reach agreement through negotiations. If an agreement cannot be reached
through negotiations, the RPM must ensure that a written decision is prepared
for signature by the appropriate EPA official (usually a Division Director).
. i , This decision is generally final, without the ability to appeal. Figure 1-4
summarizes the process for resolving disputes.
Settlement EPA has begun to use consensus-building techniques or settlement facilitation
Facilitation mechanisms in its dispute resoluti m processes. Due to its informal and
impartial nature, settlement facilitation may help resolve disputes in a manner
which restores the parties* ability to .work together. This is of particular
importance in PRP oversight, since the parties have already reached a
,'. settlement agreement and presumably wish to preserve it. The use of
settlement facilitation is left to the discretion of the Region and does not have
to be specifically provided for in. the AOC (although it may be). For more
information, see the "Interim Guidance on Potentially Responsible, Party
Participation in Remedial Investigations and .Feasibility Studies* (OSWER
Directive No. 9835.la, May 16, 1988). .
Remedies
for Non-
compliance
EPA may impose sanctions in the event that dispute resolution is unsuccessful
or if EPA takes over the site. It is advisable that EPA attorneys in the ORC
and OE- Superfund Division be alerted in each instance. EPA counsel should
be consulted to help determine the.appropriate response to noncompliance.
Types of sanctions available to the Agency include:
* Injunctive relief (court order to comply)
Stipulated penalties . . ,
* Statutory penalties . '
Project takeover and subsequent recovery of costs.
Injunctive If EPA desires PRP performance of the terms of the settlement agreement
Relief instead of, or in addition to, monetary penalties, EPA may seek a court order
compelling performance. Subjecting a PRP to a court order may lead to
further sanctions against the PRP for failure to comply with the order.
1-18
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Figure 1-4. Usual Dispute Resolution Process '<,
Informal Discussion
If work involved is field work, the oversight assistant discusses
apparent deviation from site agreement or Project Plans with PRP
field supervisor. If work involved other than field work, RPM
discusses deviation with a PRP cbc .iinator. Where concerns are
lengthy and very specific (for example, review of a Project Plan),
initial communication may be in writing.
If in the field, the oversight assistant documents decisions of the '
PRP field supervisor and reports it to the RPM. The RPM calls the
PRP project manager regarding the apparent deviation.
Conversations are documented in telephone log or memorandum.
Notice of Noncompliance
* EPA provides formal notice of noncompliance in writing.
Dispute Resolution ,
* PRPs request formal dispute resolution with the Division Director
with support by the RPM. (Usually PRPs have 14 days to make the
request.)
* Parties negotiate (usually for up to 14 days). Region, usually
Division Director or Branch Chief, issues written decision.
Remedies for Noncompliance with the Decision
* If PRPs fail to comply with EPA's 'decision, EPA may take action,
including but not limited to the. following: seek stipulated or
statutory penalties, enforce the decision, or take over the project
and recover costs incurred in assuming responsibility for the
response action and for past costs not otherwise recovered.
Stipulated PRPs may be subject to.monetary penalties, in the form of stipulated and
Penalties statutory penalties, for failure to perform an activity or complete a deliverable
of acceptable quality in accordance with the requirements of the AOC. The
amount and schedule of stipulated penalties is agreed upon by the parties in
the AOC. The obligations to which stipulated penalties adhere, such as
schedule deadlines and deliverables, also are specified in the order or decree.
Additional information on the use of stipulated penalties may be found in the
"Model Administrative Order on Consent for RI/FS" (OSWER Directive No.
9835.10, January 30, 1990) and he "Guidance on Use of Stipulated Penauies in
Hazardous Waste Cases" (OSWER Directive No. 9835.2b, September 9, 1987).
1-19
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Statutory . EPA may seek statutory civil penalties for PRP noneompliance with the AOC.
Penalties CERCLA Section 106 provides for penalties and Section 107 provides for
treble damages for certain violations of AOCs. In CERCLA Section 109, civil
penalties range from $25,000 per violation, to $25,000 per day for each
violation, to $75,000 per day for second or subsequent violations. These
penalties may be assessed administratively, after a hearing, or judicially.
'Depending on the settlement terms, EPA can seek statutory penalties for anv
.» violation of the AOC, wheth or not covered by stipulated penalties.
Project EPA can move to take over all or a portion of the RI/FS by replacing the PRP
Takeover activities with Fund-financed actions. To take over the 'RI/FS, EPA must
notify the PRPs that it will undertake the response action, generally citing the
applicable provision of the AOC, and issuing a stop-work order to the PRPs
with a notification to the EPA remedial contractors.
In issuing stop-work orders, RPMs should be aware that Fund resources may
not be immediately available. But, in the case of PRP actions that
' immediately threaten humar. health or the environment, there may be no other,
course of action than to issue a stop-work order. Once the stop-work order is
issued, a Fund-financed RI/FS will be undertaken consistent with EPA
funding procedures.
In the notice to PRPs and EPA remedial contractors, the effective date of
project takeover should be specified and the reason for the takeover provided.
{ . In addition, EPA's reservation of rights to seek reimbursement for costs
incurred by the United Suites (or the applicable State) should be reiterated in
the notice. EPA counsel in ORC and OE-Superf und Division should be
provided copies of all notices and can assist in determining whether further
legal action should result from PRP noncompliance.
1,6 SCHEDULE FOR OVERSIGHT
RI/FS activities are typically complex and require a significant degree of
organization, coordination, and integration to ensure the development of a
product sufficient to determine an appropriate remedial action. Prior to
negotiations, EPA, with support from a contractor, will determine the project
scope. After the project is scoped, Work Plans will be developed by PRPs and
reviewed in detail and approved by EPA. At the onset of an RI/FS, greater
oversight of planning and proposed field work is necessary. The RPM should
identify the overs pht activities that must be performed as well as the
individuals who will conduct them. The RPM must ensure that these
individuals are fully qualified to oversee the necessary activities.
;
The specific level of oversight will vary from site to site and will depend on
factors such as the complexity of the site or particular components of the
RI/FS. It will also depend on the level of confidence in the technical expertise
of the PRPs (or their contractors) to perform the work, and performance of
PRPs on prior deliverables. Additionally, the level of oversight will vary with
the specific activity or task. For example, the, RPM should be on site to
observe sampling activities, particularly contaminant sampling (as opposed to
stratigraphic sampling), well construction, and drilling operations for at least
the first several wells. The oversight assistant, however, is responsible for
overseeing all site and sample collection activities. RPM oversight for the
initial wells is particularly important to assure that any specified equipment is
. 1-20 . . -
-------
used and decontaminated'before*use'and to observe the diligence of the PRPs*
geologist and driller. On the basis of the initial well installation, less RPM
oversight might be necessary for subsequent drilling operations.
In determining the ? oropriate level of oversight, the RPM also should
examine the Work Plan and the SAP, paying particular attention to the PRPs*
work schedule. This work schedule should be converted to a timeline (see
Figure 1-5 and the "Enforcement Project Management Handbook" (OSWER
Directive No. 9837.2-A, January !91 for examples of timelines)) so that the
critical activities can be identifier In addition, the AOC should require the
PRPs to provide advance notice of sampling events. Examples of critical
activities that occur during the RI/FS include:
* The installation of sampling and monitoring devices (including the
establishment of sampling grids);
Sampling events; - ' '
» The use of on-site field analytical techniques; and
» The submittal of draft and final reports and any other major deliverable*.
In addition to scheduled site visits, some unannounced inspections should be
made periodically, particularly during and after adverse weather conditions
when site characteristics may change (for example, drainage patterns, wind
damage, temperature effects on equipment).
Day-to-day interaction between the RPM and PRPs may be needed,
depending on factors such as site complexity, PRP recalcitrance, and quality of
performance. Day-to-day interaction between the RPM and oversight
assistant, on the other hand, may not be required but is strongly suggested.
1.7 TOOLS FOR OVERSIGHT
Good PRP oversight throughout the RI/FS process involves the use of a
variety of tools available to the RPM. Some of the more important tools
include the following:
* Knowing the location of and how to access various kinds of technical
assistance "m an efficient manner;
* Requiring the amount of PRP documentation necessary to justify (even
before a court) why a decision was made, how to approve or disapprove a
deliverable, why an activity should be conducted or not, and how the
activity performed will generate quality data that can be used to select a
remedy;
* Conducting regular meetings with the PRP (and their contractors) and, as
necessary, with Regional managers, technical experts, the oversight
assistant, States, Natural Resource Trustees, and the community to address
site-specific concerns;
* Requiring PRPs to submit dell arables, iu a timely manner, that are
complete, accurate, and representative of the data obtained; and
* Assuring that the PRP activities satisfy the QA/QC requirements of EPA
and the Regional standard operating procedures,
1-21
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Flgura 1.5a. Reconw ended RI/FS Process: kteai Scenario
Months
EPA
&' c.
** '*
PRP
Model
Order
Deliverable*
-5 -4 -3 -2 -10 1 2
rOfllt . RPM
Committee ^SM*
Compto Inspect
DocumMUaiMi
, | P»p«
A Qwwnl Documert Re^ew
1 MnttrW ' i- v
Section DwUPwinlnaiy
Prepare Drrt SOW
|A*eew Technotogiee| ^SchcdUeB
,,_ , _.,,!'. ,,__
Determkie Potental j
TrMtBbtttyShJdte f Motfty EPA
^JJ^j1*^ ^RPHSnek.
RemadtoBon Goah
.lorScoplngMeailng ySmp,nBM^ilnff
PrapamOmBSOW
&AOC
Prepara Special
Notice
4 Smd S|wcM Motte*
iOpfelfllMlllIB
Mirl ItiMttt fliiiHi hmtta
PRP« Fwm StaMtog Comrrtttee Based on General Notoe Letter
".'*
,
Rl/FS Negotiation
and Moratorium
-
- .
RL/FS Negotiation
Moratorium]
Extension
(cSsaetJooary)
Obtain Access
Prepare CRP
i-*
1 Admlnlstntlv* Order
Draft HSP
Procure Lab]
Prepare Drah WP. SAP. QAPJP
Procure
Conuactor ' |
I Good F.lth Off»r
Negotiation]
Extension '
(Oiscfettonary)
-
"'".Ratfiew
Revise ._
^ -», »*r
Pielim- /s
inary «««*
ARARs
Memo
J ModtyH»ti
1 R**oorc«
on Con**nl
-
Revise WPJ
nrs.»TSMerni»
~ ,SSOW
JT«I
TruMeet
Suppor 1 Contractof)
' ^Obtain Drift 'VP. SAP * QAP)P
Rl/FS Negotiation Scop
-------
Figure i.5b. Recommended RI/FS Process: Ideal Scenario (Continued)
Months
EPA
PRP
Order
DellvertMM
2 3 45 6 7 8 9
| HoM Public UMdng
^^ ; ' « 1 1 i |
Conduct Oo-sile Ovwsight
4 OpM Administrate* R*e*rt Rto
Mobttza {
1 "...- ... -._ »... i. i
Data VaHdatton/Review PRP Reports
| Hevtew TS WorKplan
{
Sol Screening
| DrUBofhgs |
1 Same
-
ound
teg
| (ratal and DewtapWeli
.
- j Accept TS Wofkplan
1
'
Compile/Request ARARs " |
GW Screening {
PRP Data VabdaUon
1 1 1
Conduct TS Overset |
.
[ Prepare Site Characterization Summary
1
Draft PRPTSWP
-
1
Review Site Characterization
CornMte ARARs ". f
Draft Exposure Soenario |
Revise TSWP
Procure TS Contractcx
Conducl TS f
j B>* 4 IB sow Anmntf Jy*K*a» ,**ta J
PUP of 18 An MSP ' > Ju«mo an E«po*ur« <
* 3»» ^F»l« and Transport
j MeoH , ^ Cftt ^ *rlmtlon ^Envfroiinwntil
tion (Inducing Baseline Risk Assessment &
* Continued
-------
Hgur*1.5c. Racon,m«Kled Rl/FS Process: Weal Scenario (Continued)
Months
9 10 11 12 13 14 15 :
''* -
Ocvtfte Owrtight
: Data Vafctatton
Co»npaB/Raqu«8l ARARt
Conduct TSOvwtJtfrt |
1 Review Draft Expoaure Scenario
-
[ Revtew TS Report
ConyltARARs
-
AddWonal Sampling
| Data VaidBfcjo
'
-_
Prepare Draft HI .
Conduct TS |
-
Prepare TS Report |
' -
1
:'.
s-
j-
4 TSEv*wUo«B^>ort
1 .
EPA
PRP
Model
Order
Deliverable*
* Continued
Site Characterization (Inducting Baseline Risk Assessment 8 Treatability Sudtas).
-------
Figure IJd. Recommended RI/FS Process: Ideal Scenario (Continued)
Months
EPA
»*
6r
PRP
Uode*
Older
Detlvecmbtea
14 15 16 17 -18 19 20 21 22
Review At
RnafeeARARt
i
Screening Memo
^HoMPut
t Accept Rl |
IkMMdng
[ RmteeRI j
| Draft F3
Develop Att«nalh*
Screening Memo
flevtooTS Report
-
Review Of aft FS
Oral) Proposed Ran
Accept FS I
Revise FS j
Stale Comments
| Hold Public Milting
PuNic Comment
- Respond to
Comments
-'
"
ROC
JBaseUneRlsk J Draft M J C*nnp*retl** Evaluation A Draft FS*
JEnvtnxwMnM . .
lEvaluetlon Report " ,
i Obi^ctfv^s MMtio ' \ «cifSM)in0 MMIW
IOevetopmerrtand , Detailed .
Atlamativea ,1 of Alternatives I
-------
Technical Technical assistance available :o the RPM throughout the major tasks of the
Assistance RI/FS was presented in Table 1 -1 of this guidance. Additional sources may
also be found in Appendix A and throughout Chapters 2 through 8, especially
in the 'Resources Available to the RPM* section of each chapter.
Oversight Records '
and Documentation . , > . ,
Preservat;,.n of Under most AC '.J, PRPs mus Preserve all records, documents, and
Records information of any kind relating to the performance of work at the site for a
minimum of 10 years after commencement of construction of any remedial
action. After the 10-year period, the PRPs should offer the records to the
lead agency before destroying them. This matter is covered in the Model
' ' AOC. " '
Decision
Records
Records of particular interest include PRP administrative orders, technical and
analytical documentation, and actions or communications either between PRPs
or between PRPs and a lead agency that involved or lead to a decision.
Document control through consistent maintenance of accurate and complete
records, field logs, and laboratory reports should be a key element of all
recordkeeping practices.
Documentation
Accurate documentation is important for use in cost recovery actions and in
remedy challenges to maintain consistency with NCP requirements. EPA's
oversight responsibilities include maintaining records and other project
documentation. The major repositories for maintaining project records are the
site file and the Administrative Record File. The'following terminology is
useful in discussing the documentation activities associated with CERCLA
sites: '.- ' ' . ' . ,
* Site File - EPA's master filing system, which contains all documents
relating to a site. A summary of information about the site file is
contained in Figure 2-2 of this guidance.
* Administrative Record File - A subset of the site file, which contains
those records that may form the basis of the selected response action. A
summary of information about the Administrative Record File is contained
in Figure 3-3 of this guidance.
* Cost Recovery Documentation - The process of accounting for costs
incurred by EPA that PRH agree to reimburse under or in connection with
an oversight contract or AOC. A summary of information about costs and
categories of expenditures is contained in Figure 3-2 of this guidance.
* ; Activity Reports - The tools that are used by the oversight team to
document PRP field activities may include all or some of the following
activity reports:
- Field activity report - assists in identifying the critical field activities
while also providing a convenient means to document these activities
.(see checklist- in Volivne 2, Appendices B and C, on the documenta-
tion of sampling and Wil drilling procedures to assist the RPM);
1-26
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Field logbook - either records facts that are not necessarily included in
the field, activity reportr(such as pertinent conversations, explanations
of changes, etc.) or substitutes for the field activity report; and,
Photographic or video log - illustrates the critical field activities (such
as sampling and well construction),
r* * *"
Additional information on activity reports is contained in Chapter 4 of this
guidance.
* Laboratory Reports - For all .'ixed, mobile, and local laboratories (used by
either EPA or PRPs), specific reporting requirements should be maintained
including chain-of-custody forms and analytical results. These reports
should specify the QA procedures and QC parameters (e.g., precision,
accuracy, representativeness, completeness, and comparability) that will be
met during the testing analysis. Additional information on the use of '
laboratories is contained in Chapter 4 of this guidance.
* Progress Reports * The oversight assistant and PRP may be required to
submit reports (usually monthly) to the RPM describing all field activities
conducted since the last report, deliverables submitted since the last report
and their review progress, and all QA/QC checks or audits conducted since
the last report. Additional information on project status reports is
contained in Chapter 3 of this guidance.
Meetings
The oversight team should meet regularly with the PRPs and their field
supervisory personnel to discuss performance, status, problems, and new
discoveries that may develop during the required activities. Some meetings
between the PRPs and the lead agency should be mandatory and required in
the AOC. However, other meetings may be requested by either the PRPs or
the lead agency at any time. Generally, meetings are held before the initiation
of work, periodically during field and other activities, prior to each major
task, and following PRP submittal of draft deliverables. Meetings should be
held to provide direction, informally resolve problems, discuss changes in the
scheduling of activities, or identify deficiencies. The frequency of meetings is
subject to Regional discretion in response to PRPs* performance and work.
Examples of some of the types of meetings that the RPM should conduct are
provided in the following sections.
Internal
Scoping
Meeting
A meeting with members of the oversight team, prior to negotiations with the
PRP, to discuss the understanding of the site and identify any specific
concerns of EPA, State, and technical experts. (See Chapter 2 of this
guidance.)
Kickoff A meeting of the RPM, oversight assistant, and members of the Technical
Meeting with Support Team (TST) with the PRPs' project manager and supervisory
PRPs personnel (including contractors) to discuss respective roles, responsibilities,
schedules, and procedures. (See Chapter 3 of this guidance.)
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EPA A series of meetings to discuss specific concerns during project scoping,
Management review of the PRP Work Plan, review of the draft RI (and documents
and State produced during the RI such as EPA's Baseline Risk Assessment, treatability
Review studies, and identification of ARARs), and review of the FS. (See Chapters 2
Meetings through 8 of this guidance.)
Project Status
Meetings .
Regular meetings with the oversight assistant and members of the Technical
Support Team (TST) to discuss the performance, status, and problems that
develop duriag each task of the R FS. (See Chapters 2 through 8 of this
guidance.)
SubmJttml and
Review of
Deliverable!
PRPs submit three categories of deliverables. The first are those that need
EPA approval before work can either begin or continue. The second category
includes interim deliverables that the lead agency has the option to review.
These detivermbtes allow EPA to receive ongoing reports throughout the
oversight process and assure EPA that the work being performed meets the
terms and conditions of the AOC, These interim deliverables are generally the
components of a larger draft or final report and allow EPA to identify
potential problems regarding the collection or interpretation of data before
submission of the entire report. The third category of deliverables involves
review but no approval from the lead agency. These include PRP progress
reports. The purpose of these deliverables is to keep the project on schedule
within predetermined timeframes. Figure 1 -6 gives examples for each of the
three categories of RI/FS deliverables as recommended by the Model SOW in
PRP-lead RI/FSs.
Deliverables (including reporting requirements) beyond those required by
EPA's RI/FS Guidance are appropriate [because of the difference in the
relationship between EPA and the entity conducting the work in a Fund-
versus PRP-lead RI/FS.] RPMs should point out to PRPs that different
deliverables are required in the Model SOWs for Fund- and PRP-lead RI/FS.
The deliverables for a given PRP-lead site are specified in the AOC and its
attached SOW.
Project Plans,
Draft and
Final Reports,
ami Interim
Deliverables
The Model AOC provides, that PRPs submit all Project Plans (Work Plan, SAP,
and HSP), draft and final reports, and interim deliverables to both the lead
and support agency for review. The reports should meet the requirements
described in EPA's RI/FS Guidance and Risk Assessment Guidance.
Specifically, these reports must conform to the format and content
requirements. Deficiencies in the report format or content must be noted so
the PRP can make the appropriate revisions. In general, the RPM should
contact the PRPs' project manager, rather than the PRPs* contractor, in the
event that the RPM disagrees with any aspect of the reports).
Note: EPA should encourage PRPs to select a single point of contact when
dealing with EPA on matters concerning oversight of technical
concerns. This contact point can be mandated in the AOC and might
be a PRP or an independent PRP representative. The use of a single
contact has proven significantly to reduce communication problems
between.EPA and PRP groups. ,.' ,
1-28
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Figure A -6. Categories of RI/FS Deliverable!* ,
t ' ' '" *." ''
Examples of PRP Deliverable! for EPA Review and Approval
Work Plan and Sampling and Analysis Plan (SAP) .
Technical Memorandum on Modeling cf 5s ts Characteristics
» ' jchnical Memorandum . ...ung Hazard is Substances and Chemicals of Concern
* Technical Memorandum Describing Exposure Scenarios and Fate and Transport Models
* Technical Memorandum Listing lexicological and Epidemiological Studies
* Plan for Evaluating Environmental Risk
* Ecological/Environmental Assessment
* Baseline Risk Assessment (if begun by PRPs prior to June 21, 1990)
* Draft Remedial Investigation (RI) Report
* Technical Memorandum Identifying Candidate Technologies
* Treatability Testing Work Plan and SAP
« Treatability Study Evaluation Report «
* Technical Memorandum Summarizing Results of Comparative Analysis of Alternatives
» Draft Feasibility Study (FS) Report
* Final RI Report ' .
FinaKFS Report
Examples of Deliverable! for EPA Review and Comment
/
» Site Health and Safety Plan (HSP)
* Preliminary Site Characterization Summary
» Treatability Testing Statement of Work
» Treatability Study Site HSP
» Technical Memorandum Documenting Revised Remedial Action Objectives**
* Technical Memorandum on Remedial Technologies, Alternatives and Screening
Examples of Deliverable* for EPA Review
Progress Reports
Extncted from OWPE's 'Model Statement of Wo* Conducted by PRJV OSWER Directive No. 9835 A June 2, 1969
N< te: If EPA conduct* .be Bute line RUi .'.tfettmcnt, u> .ncnonoduiB iftouid be reviewed rod «pprwed by EPA. *
1-29
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PRPs may be requested to submit revisions of draft Project Plans and reports
if they do not meet the criteria in the RI/FS Guidance, AOC, or Work Plan.
.Poor quality reports are a primary cause for delay in the RI/FS and often
result in increased oversight costs. To avoid delays and unnecessary oversight
costs, the RPM should meet with the PRPs prior to their submittal of any draft
Project Plan or final report tc, ensure that the repcrt will not be considered
incomplete or of unacceptable quality. The RPM must also verify that the
draft and final reports are submitted in a timely manner consistent with the
schedule of deadlines for deliverables included in the AOC.
' » * "* " " i "
i ' ' . '
Oversight of Performing oversight of QA/QC activities assures the lead agency that the
QA/QC. work conducted by PRPs is done properly and that the data collected are of
Activities sufficient quality, both to support decisions regarding the method,of cleanup
and to stand up in court The purpose of the QA program is to provide
detailed plans to guide the .work and a mechanism to monitor the quality of
that work. The purpose of QC is to take samples and introduce them into a
measurement system at any time during the site analysis phase of the RI/FS,
Goals of
QA/QC
The goals of QA/QC are: /
* Precision - A measurement of the reproducibility of measurements
compared to their average value. Precision is measured by the use of ;
splits, replicate samples, or co-located samples and field audit samples.
* Accuracy - This measures the bias in a measurement system by comparing
a measured value to a true or standard value. Accuracy is measured by the
use of standards, spiked samples, and field audit samples.
* Representativeness - This is the degree to which a sample represents the
characteristic of the population being measured. Representativeness is
controlled by defining sample protocols and adhering to them throughout
the study,
' Completeness - This is the ratio of validated data points to the total ;
samples collected. Completeness is achieved through duplicate sampling
, and resampling.
* Comparability - This is the confidence that one data set can be compared
to another. Comparability is achieved through the use of standard methods
to controt the precision and accuracy,of the data sets to be compared by
use of field audit samples.
QC Audits
and Sampling'
The types of QC samples available to assist the RPM are included in
Figure 1-7. The types of QC audits that should be used by RPMs to document
the implementation of adequate QA measures include:
* Performance Audit - This audit is based on samples with known
concentrations and determines whether the analytical measurements system
is operating within established control limits.
* Technical System Audit - This audit evaluates field operations aganst the
approved protocols and QA pltns.
1-30
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Figure 1-7. Types and Uses of QC Samples
Field Blank
Field Rlnsate Blank
Field Riu.ate
Reagent Blank
Calibration Check
Standard
Spiked Extract
Spiked Sample
Total Recoverable
Laboratory Control
Reextractlon
Split Extract
Field Splits
Field Duplicate
Field Audit
(Trip Blank)
External Laboratory
j
Audit :
Internal Laboratory
Audit
Split Sample
Exposed during sampling to detect accidental or incidental
contain inatior
Sample collected after passing distilled water over the sampling
preparation apparatus after cleaning, to check for residual
contamination.
Sample collected after passing distilled water over the sampling
preparation apparatus after cleaning, to check for residual
contamination.
Organic-free water sample analyzed as a routine sample to check for
reagent contamination.
A standard material to check instrument calibration.
A separate aliquot of extract to which a known amount of analyte is
added to check for extract matrix effects on. the recovery of added
analyte. ,. "
A separate aliquot of sample having an appropriate standard reference
material added to check for sample and extract matrix effects on
recovery, (It is not recommended to spike samples in the field.)
A second aliquot of the sample which is analyzed by a more rigorous
method to check the efficiency of the protocol method.
A sample of known concentration (and known to the laboratory),
carried through the analytical procedure to determine overall method
bias. (These samples are also known as internal laboratory audits or
control audits).
A reextraction of the residue from the first extraction to determine
extraction efficiency.
An additional aliquot of the extract which is analyzed to check
injection and instrument reproducibility.
The prepared sample is split into two or more portions to provide blind
duplicates for the analytical laboratory to indicate within-batch error.
(A third may be sent to a referee laboratory to determine
mterlaboratory precision. Such samples are often called replicates).
An additional sample taken near the field sample to determine total
within-batch measurement variability. (Sometimes called a co-
located sample).
A sample of known concentration that is taken to the field with the
sampling crew, and sent through the sample preparation facility to the
laboratory with the field samples to detect bias in the entire
measurement.
A sample of known concentration sent directly to the laboratory for
analysis.
The analyte concentrations are unknown to the laboratory. This type
of sample is used to estimate laboratory bias and, external QC of, the
laboratory.
A sample of well-characterized media whose analyte concentrations
are known to the laboratory to be used for internal laboratory QC.
An additional sample analyzed by Environmental Services Division
(ESD) to provide an independent check of the PRP chosen laboratory.
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» Data Quality Audit - Thi: ..udit %valuates the documentation of data quality
indicators and determines whether methods and Standard Operating
Procedures (SOPs) in the QA plan were followed and satisfied the data quality
objectives. '
* Management System Audit - This audit evaluates the laboratory certification
program, QA in field operations, QC in the cer.ified laboratory, and
corrective actions of the entire program,
QC of sampling activities should en; t e that:
* A sampling protocol on the sampling objectives, sampling procedures, and
analytical strategies is used;
* Sampling devices must not alter the sample in any way;
* Field QC samples are collected, stored, transported, and analyzed in an
identical manner to those for site samples;
Standard collection procedures surrounding the location of the sample are
used; and
* Samples are preserved between collection and analysis.
Summary of
the Oversight
Process
This chapter describes the professionals and resources available to an RPM in
order to perform oversight of an RI/FS conducted by a PRP. The RI/FS should
take place in accordance with all EPA regulations, guidance, and policy regardless
of who conducts the RI/FS. The data are collected to identify site risks, develop
alternatives, select a preferred remedial alternative, and write a ROD, as
summarized in Figure 1-8, whether EPA, the State, or the PRP assumes the lead.
The major tasks in performing RPM oversight include the following:
* Obtain needed technical, administrative, and legal assistance before
negotiations with a PRP;
* Document all remedial decisions and keep complete records for ail field and
non-field activities;
/
* Contact, as often as needed, all involved parties;
* Develop and keep to a workable schedule for activities and deliverables;
* Ensure that all remedial activities satisfy EPA's QA/QC .concerns; and
* Notify PRPs and, if necessary, EPA counsel of noncompliance.
1-32
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Figure 1-fi. Overview of the Process
FROM;
S«» Inspection
NPL littng
PRE-RVF3
NEGOTIATION SCOPING
H
SITE
CHARACTERIZATION
BASetlNE RISK ' TRiATABtLITY
ASSESSMENT I INVESTIGATIONS
SCOPING OP THE fll/FS
CtnetorS
DEVELOPMENT AND SCREENING
OF ALTERNATIVES
DETAILED ANALYSIS
Of ALTERNATIVES
TO:
Rurmiiy S«char
flooxd <* OtcMOf
H«m«d«t Ottip
RPM "^ *he availab'e Peraoanel and resources to perform
maj°r ttSk °f the RI/FS '* the focus of Cheers 2
1-33
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CHAPTlit 2
PRE-RI/FS NEGOTIATION SCOPING
2.1 INTRODUCTION
Pre-RI/FS negotiation scoping (or "pre-scoping") is the initial task performed
by the RPM with the help of a sv jort contractor. Although usually there is no
enforceable agreement with the /"RP at this time, the RPM needs to begin
developing a site-specific Statement of Work (SOW) that will be attached to the
Administrative Order on Consent (AOC), This pre-scoping usually begins several
months before a Special Notice tetter (SNL) for an Rl/FS has been sent but to
the PRP. Pre-scoping usually is completed when the RPM:
» Visits the site to identify the conditions of the site, the effects of
contaminants, and the potential areas of concern;
» Obtains a general understanding of the site using the existing information,
and determines the general types of data needed to make a remedy selection '
decision
Utilizes a Technical Support Team (TST) to assist on the RI/FS and in
executing the tasks of future PRP oversight; and
* Generates a preliminary site-specific SOW to be included in the AOC.
Note: As a reminder, the terms and conditions governing RI/FS activities may
also be specified in a CD ,or a UAO; however, the AOC is the preferred
. settlement document. In this guidance, AOC, CD, and UAO "re treated
as synonymous.
2.2 PURPOSE AND GOAL FOR THE RPM
During pre-scoping, the RPM needs to gain a general, not detailed, understanding
of the site conditions 'using existing information. This understanding will
facilitate later negotiations with the PRPs. The RPM should determine what
additional general and site-specific information will be needed in order to make
a remedy selection decision. The RPM must ensure that this information will be
obtained during the RI/FS process. The RPM needs to know what the site looks
like, what data exist for the site, what is the extent of the contamination, what
kind of expertise is needed on tht TST, and what specific data requests should
be included in the SOW and AOC.
As a guide for developing the site-specific SOW, the RPM should apply the
"Model Statement of Work for a Remedial Investigation and Feasibility Study
Conducted by Potentially Responsible Parties" (OSWER Directive No. 9835.8,
June 2, 1989), and any Regional Model SOW or Model Work Plan. In some cases,
Regions may prefer to use a Model Work Plan instead of a SOW. By conducting
meetings with the support contractor and members of the TST, the RPM should
gain th" knowledge needed to determine if the SOW satisfies the known needs of
the site, including any concerns specific to the site, and if the SOW addresses
items not appropriate to the site.
2-1
-------
The site-specific SOW will bt included in the negotiated AOC, As a guide for
developing an AOC, the RPM should reference the "Model Administrative Order
oiv Consent for CERCLA Remedial Investigation/Feasibility Study" (OSWER
Directive No. 9835.3-1 A, January 30,1990), and any Regional Model Order. The
AOC establishes what is .expected of the PRP throughout the RI/FS process.
' Under a revised policy, EPA will not enter into AOCs under which the PRPs
perform the risk assessment component of the RI/FS for new risk assessments
effective June 21, 1990. (See "Performance of Risk Assessments in Rem«»rf;"«
Investigation/Feasibility Stud! ; (RI/Ffs) Conducted by Potentially Resc:>4 ,.v'
Parties (PRPs)" (OSWER Direv.ave No. 9835.15, August 28, 199u.^ me AOC
should reflect this development.
The goal of pre-scoping is for the RPM to develop a site-specific SOW, and to
use, the information gathered to determine the RI/FS scope and to plan for the
entire RI/FS. The RPM should avoid dealing with specific details of the site;
they will be addressed in the post-AOC scoping task and beyond. By performing
pre-scoping, the RPM will have a better understanding of the site character-
istics. The RPM should gain a general idea of what information is needed, what
activities should be performed, and, therefore, what is expected of the PRP
throughout the RI/FS process. ;
2.3 TIMEFRAME
Once the support contractor has been procured, the remaining activities in pre-
scoping should take a short period of time (for example, one quarter). The
timeframe for pre-scoping will be dependent on the timeframe for activities
- among members of the oversight team that must be coordinated, the site
complexity, and the availability of existing information.
2.4 HOW THE RPM PERFORMS "PRE-SCOPING" ' -
i , i,
The Model SOW and Model AOC contain specific tasks that need to be performed
throughout the RI/FS process. In order to gather the background data for
overseeing these tasks, the RPM should, at a minimum, perform the following '
activities. These activities can reduce the time spent to prepare for settlement
negotiations, improve the likelihood of developing a usable site-specific SOW,
and help to negotiate an AOC: -
* Hire a support contractor; ' ,
* Begin coordinate jn with State, Trustees and other Regional EPA divisions;
Visit the site;
* Develop a general site management strategy;
* Incorporate EPA's program goal for the remedy selection process;
* Review the PRFs SOW; and
* Provide assistance to ORC In negotiating an AOC.
In addition, the RPM should assess the need for several ongoing activities. Each
of the RPVTs activities are discussed in the following sections.
2-2
-------
Support
Contractor
Hire a support contra;or,for^eehnieal assistance that includes the following:
Start the procurement process early. First, the RPM should consider TES
contractors, then ARCS contractors, State representatives, or designees
from another Federal agency.- The RPM should assure that the contractor
x period *( per{^i*mance covers the entire RI/FS process and allows for
unexpected delays that can occur throughout the RI/FS.
Note: The contractor used for 'echnical support should be checked for any
conflict of intent, giver i detailed work assignment, and, if acceptable,
.be the contractor secured for oversight of the entire RI/FS process.
* Review the prior work of the various support contractors available to the
RPM, Check with other RPMs who have worked with these contractors.
* Request that the contractor gather existing site data. See Figure 2-1 for a
list of some of the more important data sources that the support contractor
should check; see Figure 2-2 for a site file -- established after the site's
NPL placement and in which existing site data should be available
overview. Typical existing data include the following:
- Aerial and historical photographs;
- Geophysical surveys; l
- USGS Topographic Maps;
- Test cores;
- USFWS National Wetlands Inventory Maps;
- Well logs;
- Soil Conservation Service soil surveys; and
- Newspaper clippings. .
* Have the support contractor develop i general conceptual model for the
site. This model should contain a diagram and an explanation of site
surface and any geological (hydrogeological) information, source areas, and
potential exposures. (See "Getting Ready, Scoping the RI/FS* (OSWER
Directive No. 9355.3-01FS1, November 1989), for an example of a
conceptual model.)
Coordination Begin coordination with State, Trustees, other Regional EPA divisions and
request assistance from a TST to:
* Assure that the PRPs gather all necessary information pursuant to the
Work Plan, as directed by the SOW; contact other EPA divisions (including
Regional Counsel), the State, and Natural Resource Trustee and ascertain
whether, in addition to the general requirements of the Model SOW,
requirements associated with the site particulars need to be added.
2-3
-------
Figure 2-1. Useful Sources of Existing Data
t' -"
V '
i- 5 ,4.
' '$
!-,
?-/* i.
.f ';
Federal Sources of Existing Data*
Preliminary Assessment/Site
Inspection (PA/SI)
Hazardous Ranking Scoring (HRS)
documentation
Agency for Toxic Substances and
Disease Registry (ATSDR) health
assessment
PRP search Section 104(e)
letters waste-in listdata requests
tothePRP
Records on removals and disposal
practices
* Permit for dischargesToxic
Rete&$£ Inventory System (TRIS)
National Pollutant Discharge
Elimination System (NPDES)
* Prior Contract Laboratory Program
(CLP) work
RCRA manifests, notifications, and
permit applications and Section 3007
information requests
EPA databases (see Appendix A)
State Sources of Existing Data
* EPA-equivaJent agency
* Public health agency
* Planning board
* Geological Survey
* Fish and Wildlife Service
* Historic Preservation Office
* Natural Resource Department
Local Sources of Existing Data
Public library
« Chamber of Commerce
« Public health department
» Planning board
Town/city hall or court house
Water authority ' " ' .
* Sewage treatment facility
Previous site employees/management
Well drillers .
Residents near site
« Universities (information on local
areas)
* Historical societies
Newspaper files
* Other Federal agenuei may also be able lo provide data. These are noted on page 25.
-------
Figure 2-2, Overview of the Site File
Purpose: The site file contains an accurate and complete documentation of all site
activities, including records pertaining to the administration of the
projects, reports, decision documents, and recoverable costs.
Location: The site file is maintair^d in the Regions. For State-lead sites, tht *'
file is kept in the State lie location.
Contents: PR? reports, oversight reports, oversight assistant reports, field activity
reports, progress reports, and laboratory reports.
Access: Each Region has procedures for opening, compiling, maintaining, closing,
and storing the site file.
Determine which char icteristics of t'.- site will require technical expertise
to evaluate. This may include risk and exposure to human health and
environment; soil contamination, leaching, and remediation; complex
groundwater systems; topographic limitations; air emissions; mixtures of
contaminants; sensitive or protective land use; preservation of natural
resources and threatened or endangered species; State concerns more
protective than Federal levels; and adverse impacts to the local economy.
Choose appropriate TST members to address those areas of concern. These
may include personnel from the following resources:
EPA Regional offices .
Environmental Services Division (ESD)
Environmental Response Team (ERT)
Waste Management Division (WMD)
Water Division (WD) < - .
Air Division (AD) . ,
Public Affairs
Office of Regional Counsel (ORC)
- EPA National offices
Of fire .of Rese? rch tnd Development (ORD)
National Enforcement Investigations Center (NEIC)
Office of Enforcement, Superfund Division
- Other Federal agencies
ATSDR
USCOE
United States Geological Survey (USGS) > <
United States Fish and Wildlife Service (USFWS)
U.S. Department of Agriculture (USDA)
NOAA
DOD .
-- DOE
2-5
-------
Health and Human Services (HHS)
Department of Justice (DOJ)
- States ' , ' -
EPA-equivalent agency
Stat* Geological Survey (SGS)
-~ State Fish and Wildlife Service (SFWS)
State Historic Preservation Office (SHPO) , ,
- Contractors
TES Contractors
Lead-agency approved contractors.
. ' Note: The TST will, at a minimum, require expertise in the following
disciplines: engineering, geology, hydrogeology, toxicology, ecology,
and meteorology. The TST also may require legal counsel from EPA
(ORC and OE -. Superfund Division) or DOJ. After choosing the
experts, the RPM should have them identify any specific requirements
needed in the SOW.
* Discuss the site in meetings with Regional managers and staff and with
members of the TST to gain a general site understanding, including
specific concerns of the Region/State and TST, which should be addressed
in the site-specific SOW. The participants at these meetings will develop a
general site management strategy to be used as a guide for planning future
RI/FS activities.
Site Visit Visit the site and nearby area with the support contractor and necessary
members of the TST to accomplish the following: '
i -,' / .
* Observe the physical conditions and kinds of contamination that exist at
the site. See Figure 2-3 for a checklist of physical conditions on which the
RPM should focus. See Figure 2-4 for examples of site contamination.
General factors that are critical to planning future RI/FS activities include:
- Size of contaminated area (acres);
- Present land use;
- Surrounding area/sources/pathways;
-. Prior activities at site;
- Number of known PRPs;
- Proximity to populations Doth human and environmental; and
- Proximity to sensitive areas.
Also, if information is available:
- Owners) and operators of site (existing/prior);
- Generators of waste; and
- Transporters of waste. .
* Modify the SOW to address specific site needs. The RPM, with contractor
support, must identify general information needs, areas where additional
information will be needed (aud how these areas will be covered in the
site-specific SOW), and areas where additional data will not be needed.
" ^ '
''.'' 2-6 .
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Figure 2-3. Checklist of General Site Conditions (Page 1 of 2)
Examine
Identify
Geology
Soil deposits (types, uses, contamination effects), bedrock
[types, alterations, contamination effects), any remaining
surface material (piles or mounds)
Surface contamination
(subsurface contamination will likely be identified
based upon existing data; a site visit will probably
not provide evidence of subsurface contamination)
Hot spots of contamination
Limitations on site access
Contaminant pathways
Topography
Landforms
Erosion patterns
Natural resources
Media contaminated
Limitations on site access
Locations for institutional controls
Location of natural barriers to migration of contami-
nants
Migration pathways off site
Mt eorology
Effects of current weather
Prior weather conditions (from existing data)
Extreme weather conditions (hurricane, tornado)
Flooding
Aridness
Hot or cold periods
Wind direction, if necessary
Land Use
Residential
Industrial
Agricultural
Recreational ;
Floodplain/wedand
Lands administered by Federal, Slate, or local governments
Media contaminated
Exposure routes
Locations for institutional controls
Limitations on site access
Location of natural and manmade barriers
Migration pathways off site
Vegetation
Plant communities (types, use, contaminauon effects)
Threatened or endangered specks
Protected areas and sensitive ecosystems
Effects of contamination (on vegetative strata, floral
diversity, and food production)
Threatened or endangered species
Hot spots of contam ination
Placement of institutional controls or
natural barriers
Migration pathway off site
-------
Figure 2-3. Checklist of GenertJ Site Conditions (Page 2 of 2)
vViidlife
Water Resources
Air Quality
Man made
Features1
Examine
Terrestrial and aquatic habitats, including bird
refuges or protected areas
Water collection areas
Surface waters (including wetlands)
Floodplain
Location of all potable water supplies (drinking
and industrial usage)
Availability of alternate water supplies
vocation of septic tanks
Areas with unusual or foul odors
Road access
'Railroads
Power lines
Pipelines
Water wells
Bridges
Identify
Effects of contamination (on wildlife habitats
or migratory areas)
Threatened or endangered wildlife
Transport of contamination off site by wildlife
Locations for institutional controls
Limitations on certain remedial actions
Effects of contamination on uanding and
flowing water (i.e., fresh wait . salt water, or
brackish water)
Users of the water resources
-Limits on locations of institutional controls
Prevailing wind direction
Precautions for site workers
Receptors when wind direction changes
Contamination transport through air
Prior environmental assessment (EA) or
environmental impact statement (EIS)
Effects of contamination on manmade features
Limitations on site access '.
Limits on locations for institutional controls
Precautions for site workers
Physical limitations on certain remedial
actions
1 After the site visit, the RPM should contact the appropriate agency responsible for regulating the construction or maintenance of this feature.
-------
Figure 2-4. Basic Description of Contamination
Media of Concern
Common Types of
Site Categories
Common Sources
Common Pathways
Basic Receptors
* Ambient air
* Containerized waste
»Ground water*
* Sludge and slurry
* Soils (surface and
subsurface, water and
vapor)**
* Surface water
* Asbestos
* Battery/lead recyclers
* Dkntins
Landfills
- Industrial
- Municipal
* Metals
Metals/organics
* Mining wastes
* Mixed waste/
radioactive
Multi-source ground
water
* Munitions/explosives
* Organics
PCBs
* Pesticide manufacturing
Plating metals
» Solvents
* Wood preservatives
Buildings/storage
areas
Containers/drums
Dry wells
Holding tanks
Industrial/chemical
manufacturing
processes
Waste pits/pools
Landfills
Human
* Ingestion of soils
Ingestion of
groundwater
Ingestion of fruits and
vegetables
* Ingestion of fish and
meat
* Inhalation of vapors
* Inhalation of
paiticulates
Terrestrial
* Contact with surface
water, vegetation, air,
and soil
Aquatic
* Contact with surface
water and sediments
industrial workers
» Recreational users
Residents
Vegetation
Wildlife
* Without prior knowledge or well data, that will not be determined at this time,
** Cannot be determined by site w»i only.
-------
Site , After performing these activities, the RPM (with contractor support) should
Management devise a general site management strategy to be used for planning purposes.
Strategy Devising this strategy should not be time consuming, but should include a
preli{fl|n|irv list of site objectives. The site strategy may define the following
. \ ' elements:
* Surface and subsurface (if known) extent of contamination and
contaminants of concern affecting soil, surface water, sediment, air, and
, ground water and subsurface s*-uctures (if known), plus the amount of
:, ' solid wastes, Jiquid wastes, an sludges. ,
* Exposure routes and receptors that may result in exposure concentrations
greater than the ARARs, greater than 10"* excess cancer risk, or a hazard
quotient greater than 1.
* Site remediation goals based on ARARs (including maximum contaminant
levels (MCLs)), risk-based concentrations, or nonpromulgated Federal or
State criteria, and advisories (i.e., guidance to-be-considered (TBCs).
, f ,
'Initial site data needs and potential areas of concern, such as site
characteristics; media affected; conditions of contaminants (that is, source,
type, pathways for transport, and receptors) posing present and potential ,
risks; and number of operable units, if necessary.
Note: The oversight team (RPM, Regional experts, TST, States, and Trustees)
should identify any data gaps in the existing site data. Some of the
data gaps will be filled during site characterization. Other data gaps,
however, may be so large that the PRP will need to perform a limited
field investigation even before beginning to develop a Work Plan. The
results of this field investigation should be included in post-AOC
scoping during the development of the PRFs Work Plan and SAP.
Program Goal Consider EPA's program goal, management principles, and expectations from
the NCP in the site management strategy, and during future RI/FS and
selection of remedy activities. (See Figure 2-5.)
PRP SOW After providing a Model SOW to the PRP for use as a guide, review the PRFs
SOW or Work Plan, for accuracy, completeness, and site-specific information,
if available, regarding the proposed activities.
Note: The availability of site information at the time of pre-scoping will
determine the level of detail in the SOW. At sites where little ,.
information exists, site specifics will not be included until the post-
AOC Work Plan. (See Chapter 3.)
The AOC Assist ORC attorney to negotiate and sign an AOC with the PRP. The Model
AOC (OSWER Directive No. 9835.3-1 A, January 30, 1990) should be used as a
guide to ensure completeness of the negotiated AOC. The AOC should
describe: general and site-specific activities to be performed, to the extent
: known; roles and responsibilities of those who will perform these activities; a
schedule the PRP and EPA will fAllow during the RI/FS; and deliverables the
PRP is expected to submit to EPA; and procedures for notifying PRPs and, if
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Figure 2-5. Program Overview
Program Goal
The national goal of the remedy selection process is to select remedies that will be protective of
human health and the environment, maintain protection over time, and minimize untreated waste.
Program Management Principles
Sites should be remediated in operable units when early action is necessary, or phased analysis
or response is necessary to expedite cleanup.
Operable units should be consistent with, and not preclude, implementation of the final remedy.
The scope and complexity of the site should be reflected in the data needs, evaluation of
alternatives, and documentation of the selected remedy.
Program Expectations
Principal threats posed by a site will be treated, if practicable, with priority placed on treating
waste that is iiighly toxic, highly mobile, or liquid,
* Engineering controls will be utilized for wastes posing relatively tow long-term threat, or where
treatment is impracticable.
Institutional controls will be utilized to supplement engineering controls, as appropriate, and
should not substitute for active response measures as the sole remedy.
* Contaminated ground waters will be returned to beneficial uses whenever practical, within a
reasonable time, given the particular circumstances of the site. ,
* A combination of treatment, engineering, and institutional controls will be used, as appropriate,
to protect human health and the environment.
* Innovative technologies will be considered when such technologies offer the potential for
superior treatment performance, fewer or less adverse impacts than other approaches, or lower
costs for performance similar to that of demonstrated technologies.
Note: SourceThe Nptionat Contingency Plan, 40 CFR 300.430(a) (I)
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necessary, EPA counsel of noncompliance and for dispute resolution. (See the
Enforcement Project Management Handbook for details on RI/FS
negotiations/settlements.) ,
Ongoing Throughout the pre-scoping process, the following ongoing activities could be
Activities performed: ,
», Conduct PRP search activitk; The RPM should coordinate the conduct of
PRP searches into the planni 3 of future RI/FS activities. Since additional
PRPs can be identified at any time during the RI/FS process, the activity
plans should be flexible enough to allow activities to be changed with only
a minimum amount of advance warning. (See the Enforcement Project
Management Handbook for details on RPM activities during the conduct
of a PRP Search.)
» Consider the need for performing interim remedial or removal actions to
stabilize the site or address a short-term threat while a final remedial
solution is being developed. The RPM must be able to review the existing
site information and look for clues to suggest that an interim or removal
action will be required. Such actions may be needed to prevent
contaminants from migrating off site. Communications with other
Regional technical experts. States, local governments, and the public will
help the RPM locate these clues.
Consider dividing the site into operable units. The RPM may determine
that acquiring specific information on one operable unit (that is, one
particular media or source) may be helpful in planning activities for the
entire site. Although the breakup of a site into operable units may extend
the time to conduct an RI/FS, it may be necessary to focus the
investigation on one operable unit in order to gather the information
necessary to address all future media of concern.
Note: The process of dividing a site into operable units is determined by each
Region. The RPM should consult their Regional managers for
assistance on designating operable units for a site.
2.5 FOR FURTHER INFORMATION
Current » National Contingency Plan (NCP), 40 CFR 300,430(a).
References . .
« Guidance for Conducting RI/FS Under CERCLA, OSW1R Directive No.
9355,3-01, October 1988, (See Appendix A).
\
Getting Ready, Scoping the RI/FS, OSWER Directive No. 9355.3-01 FS1»
November 1989.
Interim Guidance on PRP Participation in RI/FS» OSWER Directive No.
_ , 9835.18, May 16, 1988.
Enforcement Project Management Handbook, OSWER Directive No,
9837.2-A, January 1991.
* Model Statement of Work for RI/FS Conducted by PRPs, OSWER
Directive No. 983S.8, June 2, 1989.
.".'.- ' ' - ' 2-12 ' / - ',
;<;
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« Model Administrative Order on Consent for RI/FS, OSWER Directive No.
9835.10, January 30, 1990. ,.v
* Interim Guidance on Notice Letters, Negotiations, and Information
Exchange, OSWER Directive No. 9834.10, October 19, 1987.
/ . - . »
Potentially Responsible Party Search Manual, OSWER Directive No.
9834.6, 'August 1987.
Future
Resource
« Annotated Technical Reference for Hazardous Waste Sites (OWPE)
(Projected for Publication in 1991).
2.6 RESOURCES AVAILABLE TO RPMS
Personnel * Support contractor.
Regional staff (TST, ORC, BSD).
States (Environmental Agency, Health Department, SOS, SFWS, SHPO).
* Experts (ORD, other Federal agencies, counties and local sources,
universities).
Documents
Model SOW.
Model AOC.
Data
* Existing site data.
* Region's reference library for similar sites.
* RODs database. ' -
Chronological logbook of meetings and site visit.
2.7
HELPFUL HINTS FOR THE RPM
During pre-scoping, the RPM should anticipate causes for potential project
delays, including the following:
Tlie quality of the support contractor's work, which will determine if this
contractor is to be used as the oversight assistant for the entire RI/FS;
* Areas where limited information exists, but for which data will be needed
before performing future tasks of the RI/FS;
* Areas of expertise lacking in the TST; and
Site-specific concerns presented by the TST that have not been included in
the SOW.
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To help minimize the lime spent on pre-scoping, the RFM can take the
following actions:
* Use general conceptual models and save specific details for the Project
Plans during post-AOC scoping;
* Tailor the SOW with specific concerns to the extent known (additions or
deletions) from the Regional/State Mperts and the TST;
* Establish PRP financial and technical qualifications prior to the AOC;
* Provide the support contractor with a well-defined work assignment to
assure good performance of the pre-scoping activities; and
* Record the support contractor's activities and all RPM decisions in a
chronological logbook to prevent duplication of effort and to provide -
adequate documentation of activities.
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CHAPTER 3
POST-AOC SCOPING
3.1 INTRODUCTION
Post-AOC scoping is the detailed, site-specific activity planning phase of the
RI/FS during which Project Plans are developed. It occurs after negotiations
are completed and an AOC, with SOW, has been signed by EPA and the
PRP. Durjng post-AOC scoping, he RPM refines the oversight team's site
conceptual model, preliminary site objectives and remediation goals, and
preliminary data needs.. This information is used to assist the PRP to develop
a set of usable Project Plans. Based on the evaluation of existing site data, the
RPM reviews, comments on, and approves the Project Plans submitted by the
PRP, with support from TST members and an oversight assistant (probably the
support contractor used during pre-scoping).
3.2 PURPOSE AND GOAL FOR THE RPM
The RPM establishes the foundation during post-AOC scoping for oversight of
the entire RI/FS process. During post-AOC scoping, the RPM, with support
from the oversight assistant and TST members, works with the PRP to develop
the PRP's Project Plans, which include the specific data needs for the site.
The Project Plans establish procedures for PRP performance of field activities,
laboratory testing, and data analysis, in order to characterize the site. Post-
AOC scoping is designed to develop PRP Project Plans - Work Plan, Sampling
and Analysis Plan (SAP), and Health and Safety Plan (HSP) - which must be
approved prior to initiation of field activities. During post-AOC scoping, the
RPM is responsible for developing community relation activities and for
drafting a Community Relations Plan (CRP).
3.3 TIMEFRAME
The PRP Project Plans should be developed within three to six months after
signature of the AOC. Gaps in the existing data and resubmittals may extend
.this period. The timeframe for post-AOC scoping will be determined by'
extent of existing site data, complexity of site characteristics, kinds of
contaminants, coordination within EPA and with State and Natural Resource
Trustees, completeness of EPA instructions to PRPs, and the ability and
willingness of the PRP to develop acceptable Project Plans.
3.4 HOW THE RPM OVERSEES POST-AOC SCOPING
The PRP Project Plans contain detailed information that summarizes the
existing data. In addition, the plans identify the work to be performed,
including methods, rationale, schedules, data reporting requirements,
equipment verification, and QA/QC concerns.
The PRP Work Plan and SAP expands on the activities identified in the SOW
and includes a site conceptual model, preliminary site objectives (including
preliminary re medial ton goals (PFIGs) identified by EPA) and prelim; *ry data
needs. (Each of these items will be compared to its counterpart prepared by
3-1
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this oversight team and ap>opriate. revisions to the PRP Work Plan will be
made.) The PRP Work Plan and SAP also includes a documented and detailed
. sampling plan, a preliminary list of alternatives, documentation of the need for
treatability studies, whether the PRP satisfies/or will need to obtain a waiver
of ARARs, and procedures to acquire additional data when unknown
contaminants ar: discovered, (See RI/FS Guidance Appendix B.)
An efficient way to develop an acceptable PRP Work Plan and SAP is to have
. a set of Regional Standard Operatinr Procedures (SOPs) in place before the
scoping phase. These SOPs should c scribe the types of activities that may be
required, identify the party responsiole for performing these activities,
' determine the format to document the results of these activities, and assure
that the data collected satisfy EPA's standards for quality data. SOPs may be
modified by site-specific circumstances. At a minimum, SOPs need to address
the following:
* Handling and.disposition of RI/FS wastes (that is, soil cuttings, drilling
muds, extracted groundwater, decontamination or cleaning liquids, and
protective clothing); *
Drilling method and sampling method;
Method for sampling an aquifer;
Well screen intervals;
Frequency of sampling intervals during drilling; ' ,
* Method of surface water sampling, if necessary; and
* QA/QC protocols for non-contract labdaiory piogram (non-CLP) labs
. (local or mobile labs).
The RPM (with appropriate support from the oversight assistant and TST
members) must assure that the PRP develops acceptable Project Plans. The
RPM's activities are specified below.
Note: These activities are based on the assumption that the oversight assistant
during post-AOC scoping is the same as the support contractor used in
pre-scoping. If a new contractor must be procured to assist in
oversight, the RPM needs to issue a separate Oversight Work
Assignment, and receive and approve a separate Oversight Work Plan.
Klckoff Conduct a kickoff meeting with the PRP (including oversight assistant and
Meeting TST members) and, if necessary, conduct a site visit. Prior to the meeting, the
RPM will provide guidance documents to the PRP on the RI/FS process
, including roles and responsibilities, activities to be performed, and schedule
for deliverables and activities. (See the references listed in Section 2.5 and in
each RI/FS discussion task of this manual.) During the site visit, the RPM
and PRP representative evaluate the present site condition and discuss conduct
of the future RI/FS activities. A summary of the kickoff meeting is provided
in Figure 3-1.
3-2
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Flgun 5-1, Summary of « Kickoff
PURPOSE:
TIMEFRAMI:
PARTICIPANTS:
TOPICS:
PREPARATION:
This planning meeting is primarily for ensuring that all parties
are familiar with the full scope of site activities and with EPA
expectations.
The kickoff meeting , conducted soon after the AOC is signed
and prior to the dev< .opment of the Work Plan or other plans.
The RPM, oversight assistant, and TST members should meet
with the PRP's project manager and other project supervisory
personnel (including appropriate contractors). Regional
management, and State and local officials may also attend.
The kickoff . meeting should discuss the following:
administrative matters, such as point of contact; EPA and PRP
roles and responsibilities; project schedule for meetings and
activities; preliminary' field procedures, such as site
requirements, locations of work areas, decontamination areas,
clean areas; potential, need for emergency equipment; and
deliverable! expected of the PRP. '
Prior to the kickoff meeting, the RPM should review the
procedures for sampling and well drilling activities for different
types of media. See Appendices B and C in Volume 2 of this
guidance.
Regional
Management
Meeting
Conduct a Regional management meeting to review the following:
* Schedule of activities identifying what will be done, who will do it,
and when will it be done;
* Ways to attain EPA's objectives and goals through PRP performance
of the planned activities;
Budget for activities, personnel, and resources to be used during the
RI/FS; ,
* Data to be included in PRP Project Plans - content and
requirements, specific date needs, data accuracy, and data
completeness; and
* Status and level of cc ajiunication with State representative,
ATSDR, Natural Resource Trustee, and the public.
3-3
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State AUARs Request, in writing, that the State prepare and submit a list of State ARARs to
the lead agency for review. The RPM should ask for advance notice of State
ARARs that may be more stringent than the comparable Federal ARARs.
Laboratory Notify the PRPs* chosen CLP facility of how the CLP will be used during
Facility field sampling (either primary testing or oversight of split samples). Verify
the capability of the PRPs' chosen non-CLP facility (qualified mobile or local
' laboratory), which must adh re to CL ? protocols for sampling. The RciV
: , should review each laboratot ;'s procedures - personnel, equipruciu, MVi«v.aon
levels, routine analytical sampling (R AS), and special analytical sampling
(SAS) - to satisfy EPA's QA/QC concerns.
Work Plan After the PRP has submitted any portion of the draft Work Plan for review
Review (for example, site background summary and history of the site; comprehensive
description of activities including methods, schedule, and rationale; a site
conceptual model; and the PRPs' plan to identify the need for additional data
when data gaps or site unknowns exist), meet with the oversight assistant and
TST, to review and verify the following L;< m in the PRFs submittal:
* Remedial action objectives and preliminary remediation goals (PRGs) and
the methods and rationale for meeting these objectives and goals;
Initial list of remedial alternatives - a range of alternatives, as appropriate,
that includes a no-action alternative, treatment alternatives to reduce the
toxicity, mobility, or volume of waste (see Section 2.5), containment
alternatives which include engineering and institutional controls (see
Section 2.6), or a combination of treatment and containment options; and
\ -
Note; A full range of alternatives may not be appropriate for each site. (See
. . the NCP, 40 CFR 300.430(4).) Screening the initial list of alternatives
.for grossly excessive cost,- effectiveness, and irripiementability may
reduce the number of potential alternatives to be considered by the
RPM throughout the RI/FS process.
* Preliminary list of Federal ARARs. (See the preamble to the final NCP,
40 CFR 300.430(8), pp. 8764 - 1766.) During post-AOC scoping, the PRP
should identify only chemical-specific and location-specific ARARs;
action-specific ARARs will usually be identified during the screening of
alternatives in the FS (see Chapter 7).
For further i uormation and guidance on ARARs, see:
- The Preamble to the NCP. 55 Federal Register 8741*66 (March 8.
1990), and 53 FR 51435-47, December 27, 1988.
- "CERCLA Compliance With Other Laws Manual," EPA/540/G-
89/006, August 1988. , '
. - "CERCLA Compliance With Other Laws Manual, Part II. Clean Air
Act and Other Environmental Statutes and State Requirements,"
EPA/540/G-89/009, August 1989.
* Explanation for the candidate technologies to be used during the
treatability studies task. The RPM should access ORD's Superfund
3-4
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Innovative Technology ^valuation Program (SITE) to review the
demonstrated and emerging technologies that may be currently available
for certain remedial actions (see Section 2.5) and the Alternate Treatment
Technology information Center (ATTIC) Database System (see
Appendix A).
t.t -. , v " -
PRP Project Review the draft and final TRP Project Plans (Work Plan, SAP, and HSP).
Plans Verify that tr-r PRP deliv ables meet EPA's requirements for the Work Plan
and £.'.?, atlc.ess site-speci ; concerns, contain accurate analyses and
conclusions, and include justifications for performing all future, field
activities. N ,
Note: The RPM has three choices after reviewing the PRPs' Work Plan and
SAP: approval, disapproval, and approval on condition. Reasons for
disapproval and conditions for approval should be explicitly explained
by the RPM to the PRP.
Cost Recovery .
Documentation
Develop an ongoing cost recovery documentation program that contains at a
minimum:
* RPM costs including personnel hours and travel;
* Contractor costs charged to the site;
* Any other direct costs charged to the site (for example, TST activities);
and
* A complete set of detailed records (written documentation) that describe
the oversight activitiss.
A summary of the cost recovery documentation process is provided in
Figure 3-2.
Natural
Resource
Trustee
Notify the appropriate Natural Resource Trustee by letter to determine the
need for performing a preliminary Natural Resource Survey. This may
include a Federal Trustee - DOI, NOAA, USDA, DOD, or DOE; State
Trustee designated by the Governor; or both Federal and State Trustees.
Note: It is the Trustee's responsibility, not the RPM*s, to decide if and when
to conduct a Natura' Resource Survey during site characterization.
Community Determine the necessary community relations activities and develop a CRP
Relations with the Regional Community Relations Coordinator. Even though EPA is
responsible for community relations activities, the PRP may participate in such
activities. The RPM (or designee) should inform the public of the content of,
the approved PRP Project Plans and proposed site activities.
Administrative
Record Tile
Open the Administrative Record File when the Project Plans are approved. A
sum:: ary of the A, ministn,;*'* Record is provided in Figure 3-3.
3-5
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figure 3-2. Summary of Cost Recovery Documental ion
PURPOSE:
Accurate and complete, documentation describing oversight site
activities and costs incurred is essential to ensure recovery of EPA's
oversight costs.
LOCATION OF Records and docu'mentatio are filed in the EPA active site file that
DOCUM STATION: is maintained in the Regi j's Record Center or in State active files
in the case of State-lead sues.
CATEGORIESOF
EXPENDITURES:
CERCLA1104(a) provides that PRPs conducting an RI/FS must agree
to reimburse the Fund for any costs incurred by EPA under, or in
connection with, an oversight contract or arrangement. Recoverable
oversight costs include but are not limited to:
* EPA personnel (salaries and benefits), administrative,' and site
travel costs, including associated indirect costs.
* Direct and associated contractor and EPA indirect costs of
contracts or other arrangements for oversight assistance.
* Costs of compiling cost documentation to support the demand for
reimbursement.
* Accrued .interest on the above costs.
The AOC must address oversight reimbursement and provide a
schedule of payments. The billing and reporting of these costs can
be facilitated through use of the oversight Site Information Form
(SIF) which is on the CERCLIS menu. Information concerning the
incurrence and reimbursement of oversight costs should be entered
into CERCLIS in a timely manner along with related site information
as it develops.
RESPONSIBILITIES: With regard to the documentation of such costs, the Cost
Documentation Management System (CDMS) is the primary tool for
summarizing costs. This system draws on the Integrated Financial
Management System (IFMS) and presents .costs in summary form
which can be used to document costs for billing purposes pursuant
to the AOC. The CDMS summaries are also useful in cost recovery
negotiations and litigation.
The use of this system is the joint responsibility of the Financial
Management Office (FMO) and the Cost Recovery Program staff in
the Waste management Division (WMD) of the Region. The ORC uses
the CDMS outputs in negotiations and litigation.
EPA Financial Management Off ices (FMOs) in Headquarters, Regions.
and other field offices (e.g., RTF) are primarily responsible, for
compilation of cost docunv niaiion. The Regional Cost Recovery
3-6
.few?;1-, _'£"
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Figure 3-2. Summary of Cost Recovery Documentation (continued)
RESPONSIBILITIES Program staff is responsible for preparing a cost recovery checklist
(continued)
ASSISTANCE:
that identifies the site, status, period for which documents are
needed, types of documents, and appropriate ORC and Program
contacts to assist the FMOs in this compilation. The Program
staff is also responsible f *T ensuring the completeness and technical
accuracy of ihe cost d s,umentadon packages produced by the
FMO. The ORC is responsible for identifying documents
protected by the Privacy Act and by EPA's Public Information
regulations (40 CFR Part 2), as well as documents that may be
enforcement confidential or otherwise privileged. The ORC may
prepare affidavits for the FMOs to attest as fact witnesses as to the
authority and content of EPA documents.
For further information relating to documentation of oversight
activities or related recoverable costs, contact your Regional Cost
Recovery Program Chief, your Regional FMO or Superfund
Financial Officer (SFQ), or the Chief, Cost Recovery Branch,
CED, OWPE, OS-510W, (703) 308-8454 or FTS 398-8454.
Ongoing
Activities
Throughout the post-AOC process, the following ongoing activities need to be
performed:
Amend Project Plans. Each element of the Work Plan and SAP may not be
known at post-AOC scoping. Field activities, such as Baseline Risk
Assessment and treatability study requirements, may need to have separate
Work Plans to be incorporated into the existing, flexible Work Plan. Non-
field activities, such as identifying action-specific ARARs, may also change
the scope of the Work Plan and SAP.
* Conduct project status meetings. The RPM, oversight assistant, and TST
members should meet with the PRPs and their field supervisory personnel
regularly to discuss the .content of the Project Plans, make changes to the
schedule, as needed, and identify problem areas early. Some problems may
be avoided by acquiring the needed access to the site, mobilizing necessary
field equipment, looking out for unexpected site conditions, discussing
proposed activities with the community, reviewing the capabilities of
personnel and equipment of the PRP proposed laboratory, verifying that the
sampling data and monitoring well placement will acquire quality data, and
committing the PRPs to a workable schedule of draft and final deliverables.
* Decision to divide project into phases. The RPM, oversight assistant, and
TST members may agree in post-AOC scoping that the PRP perform a
sampling event on one operable unit with hopes that the data obtained will
help provide a better understanding for future sampling events or other
operable units. The number of phases, however, may be amended at any
time as additional data on the site become known.
3-7
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figure 3-rv. Summary of Administrative Recc._ File
PURPOSE.
MAINTENANCE;
CONTENT:
FOR FURTHER
INFORMATION
The Administrative Record File contains documents that
may form the basis for EPA's selection of response actions.
This File provides documentation of the basis, for Agency
action if EPA decisions are challenged, and provides the
public an opportunit to review and comment on site
activities and plans.
the Administration Record File is maintained by the
Regional (or State) office.
The Administrative Record File should include factual
information and date that may form the basis for the selection
of a response action; including reports on the site response
activities; policy and guidance documents relevant to the site,
(as contained in the OSWER "Compendium of CERCLA
Guidance Documents Used for Selection of CERCLA
Response Actions") public participation documentation;
information from parties outside EPA, such as documentation
of State involvement, ATSDR health assessment or reports
by Trustees; enforcement documents pertaining to response
selection; public comments; and decision documents.
See "Final Guidance on Administrative Records for Selecting
CERCLA Response Actions" (OSWER Directive No. 9833.3A-
1, December 3, 1990).
3.5 DELIVERABLES DURING POST-AOC SCOPING
The Project Plans are the first deliverables submitted by the PRP to the lead
- agency. The lead agency will review and approve the PRPs' Work Plan,and
SAP, and only review and comment on the PRPs' HSP. The minimum
requirements for each of these deliverables are contained in Figure 3*4.
v
Work Plan , A PRP RI/FS Work Plan should at a minimum contain a comprehensive
Content description of the five areas (see RI/FS Guidance, Chapter 2 and Appendix B
in Volume 2) discussed in the following sections.
Introduction The introduction to the Work Plan should provide a general explanation of the
objectives for performing the RI and FS and the goals to be achieved during
each portion of the process. The PRPs should discuss the activities to be
performed, the deliverables to be submitted, and the.schedules for performing
activities and submitting deliverab s.
V !=- 4-
jg
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Figure 3-4. Elements of Project Plans
Elements of a Work Pirn
A comprehensive description of the work to be performed, the information
needed far each task, the information to be produced during and after each task,
and description of weak products submitted to die RPM (see RltFS Guidance,
Chapter 2 and Appendix a, and me Enforcement Project Management Hand-
book, RllFS Implementation Chapter);
* The methods that will be used during each activity (see RllFS Guidance
Appendix B, and Section 1.7 of Ms manual an QAJQC);
* A, whc^te (at competing ^twito (see timeline in Figure 13 and activities
checUist in the Enforcement Project Management Handbook, Rl/FS Implementa-
tion Chapter);
* The nticmale for performing or not performing an activity (see Rl/FS Guidance
Appendix B, and the Enforcement Project Management Handbook Rl/FS
Implementation Chapter);
* A f«e backgrojnd summary and history of lite (ste the Pre-PRP Negotiation
Task in Chapter 2);
« A vile conceptual model (see the Pre-PKP Negotiation Task in Chapter 2);
* An ickentificauon of pfcliminaiy site obji:ciivei which includes preliminary
remediation goalsifsee Chapter 2 of this manual);
The need fig additional data when future iite mitoiowns are identified (see Model
SOW. Task 1, and the Enforcement Project Management Handbook, RllFS
Implementation Chapter);
* The manner of identifying Federal and State ARARs (seethe Post-AOC Scoping
Task in Section 22 and the Development and Screening of At tentative Task in
Chapters);
An identification of preliminary alternatives Itee Chapter 3 of this manual) and
Rl/FS guidance; and
A plan for meeting treaubility itudy requirements (see Chapter 6 of this
manual).
Health and Safety Plan (Continued)
Employee training assignments;
* A description of persotial protective cquipmeni K«i an identification of those
operation* when it will be used;
* Medical surveillance requirements;
* The frequency and types of monitoring, personne; monitoring, and environ-
mental sampling technique* and instrumentation;
* Site control measures;
» Decontamination procedures;
* Standard operating procedures for the site;
* A contingency plan thai meets the requirements of 29 CFR 1910.120(1X1)
and (1X2); and
* Entry procedures for confined spaces, .
pemeqfe gf tag Sampling «ftd Analysts Plan
Quality Assurance Project Plan (QAPJP)
* Sampling procedures, sample custody procedures, analytical procedures, data
reduction, data validation, data reporting, and personnel qualifications (see,
Chapters I and 3 in Volume I. and Appendices B and C in Volume 2 of Ms
manual);
The qualification* of each laboratory to conduct work (Note: If a laboratory
selected is not in the Contract Laboratory Program (CLP), the non-CLP tab's
methods must be consistent with CLP methods In order to satisfy EPA's QAl
QC procedures) (see Chapter I of this manual); and
The use of internal controls, such as unannounced site, performance, and
system audits (see Section 1.7 of this manual);
Elements of tht Hearth and Safety Plan iLeadAgenc* Supplies i ^mrruas Only) Field Sampling Plan (FSP)
* Identification of die tile health and safety officer, key personnel, and alternates,
.at tile health and safety;
* The risk analysis for existing site conditions, each site task, and operation;
The sampling objectives, sample locations and frequency, sampling equip-
ment and procedures, and the program for sample handling and analysis (see
Section 17 in Volume 1, and Appendices B and C in Volume 2 of this
manual).
-------
Site
Background
and Physical
Setting
The site background and physical setting section should describe current site
conditions, site history >nd available existing site information.
Initial The initial evaluatic .should provide a site conceptual model, which contains
Evaluation EPA's assessment of the site's current and potential risks to human health and
the environment, exposure pathways, and current and potential routes of
migration of the contaminants of concern.
Work Plan The Work Plan rationale should provide tn explanation and illustration of how
Rationale the data needs will satisfy the oversight team's preliminary site objectives,
especially an EPA-conducted risk assessment, and the preliminary list of
alternatives. This Section will incorporate the site-specific concerns that are
included in both parts of the SAP - the Field Sampling Plan (FSP) and the
Quality Assurance Project Plan (QAPjP).
Note: Regions that have devised SOPs and generic QAPjPs can save
substantial time during Project Plan development.
RI/FS Tasks
The RI/FS task discussions should describe the activities to be performed
during scoping, site characterization (including EPA's (or PRPs', if an AOC
was signed before June 21, 1990) Baseline Risk Assessment and treatability
studies), and the development and analysis of potential alternatives. The site-
specific items identified in the SAP (both FSP and QAPjP) should also be
included in the discussion of the activities for each task (see RI/FS Guidance
Appendix B). '
SAP Content A PRP SAP should contain a QAPjP and an FSP to ensure that the proposed
sampling data collection activities are compatible with previous data collection
; activities and serve as a mechanism for the PRP to acquire EPA quality data.
(See RI/FS Guidance, Chapter 2 and the "Compendium of Superf und Field
Operations Methods" (OSWER Directive No. 9355.0-14, August 1987).)
Project Plaits
and the
Baseline Risk
Assessment
Depending upon the existing site data and the complexity of the site, the PRP
Work Plan and SAP may cot fully address EPA's Baseline Risk Assessment (or
PRP assessments started prior to June 21, 1990) and treatability studies. When
the RPM determines that these activities will be needed, an amended or
separate Work Plan and SAP will have to be developed by the PRP and
approved by EPA. (For further information see Baseline Risk Assessment in
Chapter 5 and treatability studies in Chapter 6 of this guidance.)
Project Plan The progress of the RI/FS study should be compared to the anticipated
Progress progress as presented in the Work Plan, and reported monthly. At a minimum,
Reporting progress reports should: (1) describe the actions that have been taken to
comply with the AOC; (2) include all results of sampling and tests and all
other data received from PRPs; (3) describe the work planned, specific work
schedules, and relationship to the overall project schedule for completing the
RI/FS; and (4) describe all problems encountered, any anticipated problems or
delays, and any solutions to address these problems or delays.
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Questions for The RPM, with help f<"^"n the oversight assistant and members of the TST,
Proje :! Plan should make sure that the Prc.ect Plan data and analyses answer the following
Review, questions;
Work Plan and Sampling and Analysis Plan (SAP)
Are the plans consistent with the NCP, EPA guidances, and the
activities, schedules, and procedures listed in the AOC and SOW?
Has the RPM suj; !ied the PRP with appropriate EPA guidance
documents and, i available, SOPs?
- Do the plans contain the minimum required data to meet the
activities checklist in the Enforcement Project Management
Handbook or Figure 3-4 of this manual?
- Do the plans address and provide resolution of site-specific
concerns of the oversight team (RPM, oversight assistant, TST,
and States) especially regarding EPA's risk assessment?
- Do the plans include activities and objectives that are sufficiently
broad to include the need for future data and activities, fill in the
existing data gaps, and handle all types of delays due to natural
and physical events?
Is it clear who will perform each activity, how the activity will be
performed, what information will be needed prior to each
activity, and what information will .be produced at the conclusion
of each activity?
- Will the planned activities meet technically accepted engineering
procedures, CLP protocols, and QA/QC concerns?
Health and Safety Plan (HSP)
Does the plan meet the Occupational Safety and Health
Administration (OSHA) requirements for worker safety?
Does the plan contain each of the required elements, as shown in
Figw* 3-4?
\ . , ' *
* Other Deliverables: Progress/Status Reports
Will the PRP and oversight assistant submit biweekly or monthly
status reports on the portions of the Project Plans that will
involve potential areas of disagreement regarding the site
characteristics or contaminants?
3.6 FOR FURTHER INFORMATION
* National Contingency Plan (NCP), 40 CFR 300.430(a).
Guidance for Conducting RI/FS Under CERCLA, OSWER Directive No.
9355.3-01, October 1988. fbipter 2 and Appendix B).
* Interim Guidance on PRP Participation in RI/FS, OSWER Directive No.
9835Ja, May 16, 1988.
3-11
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Getting Ready, Scoping the RI/FS, OSWER Directive No. 9355.3-01 FSi,
November 1989. ,
Scoper's Notes, An RI/FS Costing Guide, EPA/540/G-90/002, February
1990. .'-.',
Enforcement Project Management Handbook, OSWER Directive No.
9837.2-A, January 1991.
« Data Quality Objectives frr Remedial Response Activities, OSWER
Directive No. 9335.0-7B, 4arch 1987.
CERCLA Compliance With Other Laws Manual (ARARs): Interim Final
OSWER Directive No. 9234.1-01, August 8, 1988.
* CERCLA Compliance With Other Laws Manual: Part II, Clean Air Act
and Other Environmental Statutes and State Requirements, OSWER
Directive No. 9234.1-02, August 1989.
* Interim Guidelines and Specifications for Preparing Quality Assurance
Project Plans, U.S. EPA, Office of Exr'^atory Research, QAMS - 005/80,
December 1980.
* A Compendium of Technologies Used in the Treatment of Hazardous
Wastes, EPA/625/8-87/014, September 1, 1987,
« A Compendium of Superfuhd Field Operations Methods, OSWER Directive
No. 9355,0-14, August 1987.
) '
* Occupational Safety and Health Guidance Manual for Hazardous Waste Site
Activities, NIOSH/OSHA/USCG/USEPA. 1985,
/ - '
i ' \
3.7 RESOURCES AVAILABLE TO THE RPM
Personnel * Oversight Assistant.
« Technical Support Team (TST). ,
Regional Staff (Peer Review, Management Review, ESD, ORC, and ORD).
» Headquarters Staff (OWPE, OGC, OE - Superfund Division).
i .
Other Feden! Agencies (ATSDR, USCOE, Natural Resource Trustees).
* State Representatives.
* CLP and non-CLP Laboratories.
Documents *, PRP Site Conceptual Model.
PRP List of Data Quality Objectives (DQOs).
* PRP List of Federal and State ARARs.
3-12
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* , PRP List of Treatment Technologies. " .
' .l.^fWt^*
-------
. Document information obtained from the oversight assistant, from the
PRPs, and from site visits;
Specify level of detail and content of PRP Project Plans early, preferably
during kickof f meeting;
» Alert Natural Resource Trustees;
« Open the Administrative Record File at the end of post-AOC scoping; and
< *
» Notify-the public via meeting or fact sheet of the planned field activities.
3-14
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CHAPTER 4 -_ - - ' -
' . ' ' " V. ' * - " ,
SITE CHARACTERIZATION
4.1 INTRODUCTION . >
The site characterization task seeks to gather sufficient data to define the site
risks, to evaluate alternatives, and to assess the physical and biolcgicai
characteristics of the site inc'uding contamination source, nature, extent,
transport and fate of the coi animation. The RPM and ovenigh* '"'' ~
oversee the field activities performed by the PRP, including field sampling
and laboratory analysis activities (see Appendices B and C in Volume 2), tor
ensure that the PRP activities conducted during site characterization conform
to the Project Plans previously approved by EPA. Data are gathered for other
analyses conducted during Site Characterization (for example, EPA's Risk
Assessment, Treatability Study Evaluation, and the Natural Resource Trustee
Survey), so that the FS can be conducted and completed without the need for-
additional information gathering.
4.2 PURPOSE AND GOAL FOR THE RPM
During site characterization, the RPM approves the PRPs* sampling and well
drilling activities, verifies the PRPs* documentation of the field activities, and
verifies that the PRPs meet ARARs (to the extent practicable) for actions
conducting during the RI (e.g., during well drilling at a historic site). In
addition, the RPM should ensure that any wastes generated during the RI
which are taken off-site for treatment or disposal are managed in accordance
with applicable Federal and State requirements.- Information obtained through
this process will serve as the basis for determining the remedial action to be
taken. The RPM can identify areas where additional data will be needed to
characterize the site, ensure that this information is obtained to meet QA/QC
concerns, and attempt to avoid unnecessary sampling activities. The RPM also
should review the PRPs* definition of site characteristics, and the source(s),
nature and extent, volumes/levels, and the potential transport and fate of the
known contaminants. These activities should be described in the draft and
final RI Reports.
4.3 TIMEFRAME
Due to the iterative nature of sampling phases and resampling events, one
cycle of the sits :haracterizrtion task can take up to 12 months to complete.
The timeframe for site characterization, however, will depend on the
following: ,
* Potential extent and number of site problem areas (for example, with
respect to soils, surface water, groundwater, air emissions, etc.);
* Potential for multiple sampling events and drilling phases (for example, for
source control, soils, groundwater, surface water, etc.);
» Turnaround time for laboratory analysis; -
4-1
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* Need for resampling if initial data are unacceptable or for additional
sampling to fill data gaps and determine the extent of contamination;,
* Time needed for EPA to perform the Baseline Risk Assessment and for
EPA or the State to support the need for Treatability Studies;
Seasonal variations-and adverse climatic conditions that affect collecting
accurate and representative samples; .,
Time for EPA to review deliveraf *.ss; and
* Unexpected discoveries of new sources.
* , ' ,( i
4.4 HOW THE RPM OVERSEES SITE CHARACTERIZATION
The RPM and/or oversight assistant perform the following oversight activities,
focusing on the PRPs' sampling and analysis tasks, to acquire accurate and
complete data, as described in the following sections:
» Meet with the oversight team;
Review proposed field activities; . ,
'* * i
Visit the site;
* Document and track field activities;
* Assess changes in original data needs;
* Conduct meetings; " ,
1 ' <
. * Review progress and interim reports;
* Conduct management review; and
« Update the files.
Each of these is discussed below. ,
Oversight Meet with the oversight team (including, as appropriate, oversight assistant,
Team Meeting TST, States, ATSDR, Natural Resource Trustees) prior to initiating the'
planned field activities to determine:
* Qualifications of any additional subcontractors not previously evaluated
that are needed to perform the various field procedures;
* The technical resources and remedial equipment available to the PRP or its
, contractor; *,.'"'
-' \ >.'*" - * '
* How the field activities will characterize the site, define the types and
sources of contaminants, and describe the nature and extent of
contamination; ...
How to ensure that the planned activities will correspond to the Work Plan
and SAP;
4-2
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Procedures for notifying PRPs and, if necessary, EPA counsel if PRPs'
field procedures deyiate-f vom. the .Work Plan and SAP;
< ' .
-------
Figure 4-1. Summary of Tools to Document Field Activities
Field Activity Reports ,
Purpose:
Uses:.
Specifics:
.Assistance:
These reports help the RPM and the oversight assistant to be consistent regarding the need to document
field activities. '.
These reports are a way to check that the conducted field activities are consistent with procedures agreed
to in the Work Plan and SAP, and are available to assist EPA if the field activity leads to future litigation.
Use water-resistant i^k. .iri Wough all err. i, initial all corrections, and date and sign all reports.
See checklists for documenting the conduct of sampling and well drilling activities in Volume 2,
Appendices B and C. , .
Field Logbook ,
Purpose:
Uses: .
Specifics: ,
Assistance:
' This logbook supplements the field activity report to record additional site incidents and activities.
, This logbook contains information supplemental to decision making, such as conversations with key
personnel, potential or actual problems encountered, explanations for changes in project plans, and other
oversight discussions or observations. .
Use water-resistant ink, draw through all errors, initial all corrections, number and bind the log, and date
< and sign all entries. ' , '
.The RPM, as needed, determines the content of this logbook.
Photographic or Videotape Log
Purpose:
Uses:
Specifics:
Assistance:
This log gives a visual presentation of (he physical conditions of the site and can be used to show how
field activities were conducted and verify what equipment was used, i
This log is a way to, check that the conducted field activities are consistent with procedures agreed to in
the Work Plan and SAP, when the field activity pertains to remedy selection, and is available to assist
EPA if the field activity leads to future litigation.
'. '
Include date, time, and location on each entry, an orientation of the photographs or video, a description of
the activity on the back of the photograph or orally on the videotape, and the person(s) responsible for the
photographs or video. . " . ,
\ . ' (
Contents and maintenance of the log are the decision of the RPM. '
' . Laboratory Reports
Purpose:
Uses:
Specifics:
Assistance:
These reports document that the sampling procedures were conducted to satisfy EPA collection
protocols, wexe performed to the agreed upon chain-of-custody procedures, and were analyzed
according to EPA's CLP protocols, ' (
These reports verify that the conducted field activities are consistent with procedures agreed to in the
Work Plan and SAP, consistent with CLP protocols, verifiable using QA/QC parameters - important
when the field activity pertains to remedy selection, and are available to assist EPA if the field activity
leads to future litigation. .
.,abel samples wiui time, date, location, and i/pe; properly store and transport samples; follow
appropriate chain-of-custody procedures; regularly calibrate the, sampling equipment; perform QC of
sample types; and conduct field and laboratory audits as needed. . -
References for documenting sampling and well drilling activities are listed in Appendices B and C in
Volume 2 of this guidance.
4-4
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Data Needs
Ensure that the PRP satisf ies|tHe?,data, needs or activities of the Natural
Resource Trustee's Preliminary Survey, EPA's Baseline Risk Assessment, and
the Treatability Study Evaluation Report during site characterization. Get
input from these parties on their specific concerns before performing
unnecessary field activities,
Progress
Meetings
Conduct meetings with the PRP, oversight assistant, and members of the 1ST
(including State representative) on the content of monthly progress reports, the
Preliminary Site Characterizati i Summary, and the direction of future field
activities..
Review
Summary and
Report
With assistance of the TST and Slate, when appropriate, review and comment
on the Preliminary Site Characterization Summary and the draft RI Report.
Management Conduct a Regional management review meeting to discuss the Preliminary
Review Site Characterization Summary, EPA's Baseline Risk Assessment (if already
Meeting . conducted), and the RI Report.
File Updates Continually update the site file. Administrative Record File, and cost recovery
documentation.
Fact Sheet If appropriate,, develop a fact sheet from the generated data, the Site
Characterization Summary, and the final RI Report to present to the public.
Send a copy of the RI Report to ATSDR.
-. Note: . The community may need to be notified before conducting
apparent or intrusive field activities (for example, forewarn the
community of drilling activities in streets or a school yard).
4,5
DELIVERABLES DURING SITE CHARACTERIZATION
The PRP will submit a Preliminary Site Characterization Summary and a
Technical Memorandum on Modeling the Site Characteristics (if necessary) for
review and comment, and a draft RI Report for review and approval.
Additional deliverable* requiring review and comment or approval will be
associated with the Treatability Study Evaluation Report (see Chapter 6) and a
final RI Report. The PRP deliverables during site characterization should
answer the following types of questions:
* Site Characterization Summary ' ,
Does the summary provide a brief description (a few pages or set
of tables) on the site characteristics to satisfy the requirements of
this summary in the RI/FS Guidance, Chapter 3?
Does the summary assure that EPA gets data for the Baseline Risk
Assessment as soon as possible?
Does the summary satisfy the checklist of items in the
Enforcement Project Management Handbook, RI/FS
Implementation Chapter, Section 6?
4-5
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Does this summary contain information to help the RPM or State
identify ARARs?
* Technical Memorandum on Modeling Site Characteristics (if necessary)
Does tfc: ske complexity require this model?
Does this memorandum identify and describe any special site
features that would be addressed by modeling? >
Can the modeling assumptions be identified clearly?
» Draft/Final RI Report
Does this report follow the format in the RI/FS Guidance,
Chapter 3, Table 3-13, and the Enforcement Project Management
Handbook, RI/FS Implementation Chapter?
- . Does this report include deliverables on the need to conduct
Treatability Studies, if necessary?
Does this report reflect specific concerns from EPA, State,
ATSDR, and Natural Resource Trustees raised during review of
the RI/FS Work Plan and SAP?
Does this report identify and justify additional activities needed?
Other Monthly Progress Reports
Deliverables " , -
Do these reports contain useful, accurate, and timely data?
* Laboratory Reports ,
Do these reports satisfy our QA/QC concerns for a data analysis
. that is legally defensible?
» Field Activity Reports
Do these reports describe the site activities in detail to justify the
activities in progress and support the need for future field
activities?
* Photographic Logs/Aerial Photographs
Do these photographs help to justify performing the present
activities and support the need for future activities?
Shipment Records
Do these records identify owners, generators, transporters, types,
volumes, concentrations, and dates of disposal of site
contaminants?
4-6
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4.6 FOR FURTHER INFORMATION
« National Contingency Plan (NCP), 40 CFR 300.430(a). /
» Guidance for Conducting RI/FS Under CERCLA, OSWER Directive No.
9355.3-01, October 1988, (Chapter 3).
The Remedial Investigation - Site Characterization and Treatability
Studies, OSWER Directh. Mo. 9355.3-01FS2, November 1989.
ItiU. j/. Guidance on PRI 'articiparion in RI/FS, OSWER Directive No.
9835-la, May 16, 1988.
Model Statement of Work for RI/FS Conducted by PRPs, OSWER
Directive No. 9835.8, June 2, 1989.
* Enforcement Project Management Handbook, OSWER Directive No.
9837.2-A, January 1991.
. * Risk Assessment Guidance for Superfund, Human Health Evaluation
Manual (HHEM) Part A, OSWER Directive No. 9285.701 A, July 1989.
* Risk Assessment Guidance for Superfund, Volume II, Environmental
Evaluation Manual (EEM), EPA/540/1-89/001, March 1989.
Superfund Exposure Assessment Manual, OSWER Directive No. 9285.5-1,
April 1, 1988. ,
* Compendium of Superfund Field Operation Methods, OSWER Directive
No. 9355.0-14, August 1987.
* Chemical, Physical, a.-d Biological Properties of Compounds Present at
Hazardous Waste Sites, OSWER Directive No. 9850.3, September 27, 1985.
4.7 RESOURCES AVAILABLE TO THE RPM
Personnel * Oversight Assistant. ,
» Technical Support Team (TST).
* Regional Staff (Peer Review, Management Review, ESD, ORC and ORD).
* Headquarters Staff (OWPE, OGC, OE - Superfund Division).
* Other Federal Agencies (ATSDR, USCOE, USDA-SCS, Natural Resource
Trustee, U.S. Department of Commerce (DOC)-USFWS).
. * States (EPA-equivalent, SFWS, SGS, State Trustee).
1 * Contract Laboratory Program (CLP) and non-CLP Laboratories.
Documents * Work Plan and Sampling and Analysis Plan (SAP).
-'<."..-
ATSDR Health Assessment.
* Site Characterization Summary.
4-7
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* Draft RI (with or without Baseline Risk Assessment).
* Checklists on sampling and wall drilling (Appendices B and C).
* EPA's Baseline Risk Assessment (if available).
Data * Sampling Activities Summary ' .
- Collection.
. , i, - i Analysis.
Evaluation. ,
Well Drilling Activities
- Number/Location.
- Cores;
- Analysis. ,
Evaluation.
- Monitoring.
4.8 HELPFUL HINTS FOR THE RPM
During Site Characterization, the RPM should:
* Ensure that field activities are consistent with the Work Plan and SAP;
* .Oversee the oversight assistant's performance and its timely reporting of
site characterization activities;
* Determine the ability of PRP (and PRP contractors) to conduct field
. activities, for example, drill the needed exploratory, development, or
monitoring wells and collect quality samples, consistent with site
complexity; -
* Identify previously unknown contaminants; >
* Review the major PRP delivcrables (Preliminary Site Characterization
Summary, Treatability Study Evaluation Report, and draft and final RI
Reports) and interim deliverables;
* Notify PRPs and, if necessary, EPA counsel of any AOC noncompliance;
* Keep the public informed of upcoming field activities,1 especially highly
visible or intrusive field work; and
* Ensure location-specific ARARs (and other known ARARs) have been
considered (for example, critical habitat, historic property).
To help minimize the time spent on site characterization, the RPM should:
» Visit the site during initial sampling and well drilling activities;
* Take QC samples and audit the PRPs* laboratory to meet QA/QC concerns;
Ensure documentation of field activities and all generated findings;
4-8
-------
* Incorporate EPA's Baseline Risk Assessment, where available (see
Chapter 5), and trie Treatat ility Study Evaluation (see Chapter. 6) activities
into site characterization;
Coordinate with the Natural Resource Trustee, ATSDR, and State;
, Update the site file, Administrative Record File, and cost recovery
documentation and information; and
* When PRP deiiverables are .'viewed, impose deadlines and followup with
tardy reviewers, and notify ,'RPs and, if necessary, EPA counsel of
noncompliance..
4-9
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CHAPTER 5 ,
BASELINE RISK ASSESSMENT
5.1 INTRODUCTION
The Baseline Risk Assessment is conducted during the RI. It is an iterative
process that begins at post-AOC scoping and ends with preparation of a
document that usually is included. -s a chapter in the RI Report. Beginning
with ail AOCs signed after June I , 1990, it is EPA's policy that the Agency
will- prepare the Baseline Risk Assessment at Enforcement-lead sites (see
"Performance of Risk Assessments in Remedial Investigation/Feasibility
Studies (RI/FSs) Conducted by Potentially Responsible Parties (PRPs)"
(OSWER Directive No. 9835.15, August 28, 1990)). For those sites with an
ongoing PRP risk assessment, careful oversight is critical in order to ensure the
timely development of an acceptable Baseline Risk Assessment. The above-
referenced directive also states that EPA should certify that each PRP risk
assessment is acceptable.
Note: EPA is preparing a guidance document on how to conduct the Baseline
Risk Assessment at PRP-lead sites. The guidance will include language
Changes to the Model AOC and Model SOW.
5.2 PURPOSE AND GOAL OF THE BASELINE RISK ASSESSMENT
The Baseline Risk Assessment has two major purposes. The first purpose is to
help determine if a site poses a current or potential risk to human health .
(through a human health evaluation) or the environment .(through an ecological
assessment) in the absence of any remedial action. The risk assessment may
form the basis for finding that the site may present an imminent and
substantial endangerment. The risk assessment also may show that the baseline
risks are acceptable and that remediation is not needed in spite of the site's
Hazard Ranking System (HRS) scoring. The second major purpose of the
Baseline Risk Assessment is to help determine remediation goals for the site
contaminants. Remediation goals are chemical concentrations set at risk-
based levels that are protective of human health and the environment (or at
chemical-specific ARAR levels, where available);
The RPM needs to involve Regional staff and TST members early in post-
AOC scoping to ensure that PRPs are given adequate direction to perform the
site characterization activities. The quality of the Baseline Risk Assessment is
based upon the accuracy of the activities performed, data collected, and data
evaluated during site characterization. If the proper number of samples is not
taken in the proper location and appropriate media of concern, the risk
assessment will not accurately reflect the risks presented by releases from the
site.
The RPM also should ensure that when preliminary remediation goals (PRGs),
developed in post-AOC scoping, are modified based on the risk assessment
results, these modified remediation goals are then used in the FS to establish
refined remedial action objectives and to develop, screen, and perform a -
detailed analysis of the potential alternatives.
5-1
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5.3
5.4
TIMEFRAME
Baseline Risk Assessment is performed concurrently with site characterization,
and may take up to 12 months to complete. It should be noted, however, that
data for the Baseline Risk Assessment usually lap behind fieldwork data. The
risk assessment repc : cannot be written until all sampling data have been
verified. The timeframe for the Baseline Risk Assessment, however, will be
influenced by many factors, including amount of existing site data, complexity
of the site, contaminants (type, concentration, media affected, pathways, etc.),
turnaround time for laboratory ai .lysis, number of resampling events, and
choice of risk models and assumptions used to generate the remediation goals.
HOW THE RPM OVERSEES A PRP RISK ASSESSMENT
Procedures for performing a PRP Baseline Risk Assessment are in Volumes 1
and 2 of the Risk Assessment Guidance for Superfund (RAGS):
* Risk Assessment Guidance for Superfund, Volume 1, Human Health
Evaluation Manual (OSWER Directive No. 9285.701 A, EPA/540/1-89/002,
December 1989); and
* Risk Assessment Guidance for Superfund, Volume II, Environmental
Evaluation Manual, EPA/540/1-89/001, March 1989.
The .RPM must ensure that the PRP and its contractor follow Volume 1 for
developing a human health evaluation, Volume 2 for developing the
environmental evaluation or ecological assessment, other guidances listed in
Section 5.6, and any subsequent guidance on risk assessment. The RPM must
ensure that there are frequent discussions between EPA Regional risk assessors
and the PRP and its contractor.
The RPM, with the assistance of the Regional risk assessors and/or the
oversight assistant, performs the tasks described in the following sections
during a PRP Baseline Risk Assessment.
Risk Assessor
Meetings
During post-AOC scoping, meet with Regional risk assessors (usually one
assessor for human health and one for the environment) or oversight assistant
to discuss existing site information (PA/SI or other data); EPA's preliminary
site conceptual model (chemicals of concern, potential sources of
contamination, exposure pathways, existing risks to human health and the
environment); and the preliminary site objectives and remediation goals.
PRP Work
Plan Contents
for the
Baseline Risk
Assessment
Ensure that the PRPs* Work Plan is amended and contains a preliminary
analysis of the following:
* Chemicals of concern;
* Site objectives including remediation goals;
Potential ARARs affected by the site;
* Risk-based levels to be achieved, (PRGs are set at 10** if the site has no
chemical-specific ARARs that are deemed to be protective);
5-2
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* Populations'at risk; and
; -^/i^y
The need for interim actions.
PRP Staff and Verify the teehnicalquality of PRP staff and contractor to perform the risk
Contractor assessment before the initiation of field activities.
During site characterization, verify that for the Baseline Risk Assessment, the
following occurs:
Data Collection
- All key site characteristics including soil/sediment, hydrological,
hydrogeological, and meteorological parameters are documented;
- All appropriate media are sampled for existing and potential
contamination;
- All potential "hot spots" as well as appropriate background locations are
to be sampled, if necessary;
- The sampling maps are sufficiently detailed for locating sampling
locations and, if necessary, for assuring that fie Id work space is
available for performing sampling activities; and
- The data reflect EPA's preference to accurately represent contaminant
levels, by using unfiltered groundwater/surface water sampling results.
* Data Evaluation .
-No site-related chemicals are eliminated from the risk assessment
' unless a valid explanation is supplied by the PRP;
- Sample concentrations are compared to concentrations in the blanks;
\
- Sample concentrations are compared to background samples;
- All chemicals found at the site are listed by the PRP in the risk
assessment; and
- Contaminants of concern are identified for use in the risk assessment.
« Exposure Assessment
- All current and potential future land uses are identified;
- All populations of concern, especially any sensitive groups and aquatic
and terrestrial populations, are identified;
- All exposure pathways for each medium of concern are evaluated;
- Exposure concentrations reported for each medium represent the 95
percent upperbound estimate of the mean;
5-3
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- Exposure intakes for each chemical for each exposure scenario are
based on reasonable maximum exposure (RME) assumptions;
- The appropriateness of the exposure assumptions used, if different
from the standard EPA default values, is evaluated;
i. - Appropriate chemical intakes across pathways within the same media
are combined; and .
Uncertainties in the e posure assumptions are identified ov *^° r*T
. Toxicity. Assessment
For noncarcinogenic effects, EPA-verified chronic and subchronic
reference dosages (RFDs) for each route of exposure (oral, inhalation,
dermal) are used when available;
For carcinogenic effects, EPA-verified cancer potency factors are used
when available;
\
- PRPs' selection of toxicity values for all chemicals for which there are
no EPA-verified toxicity values must b« approved by EPA; and
/.-. Uncertainties in the toxicity information are evaluated by the oversight
team. ' , _ ' . :
!
* Risk Characterization ~
PRPs calculate a cancer risk and/or a hazard index for each chemical
of concern; "
Aggregate risks or hazard indices for multiple chemicals are presented;
. - Total cancer risk and hazard index are estimated;
- Uncertainties in the Baseline Risk Assessment results are evaluated;
and
- Results of the Baseline Risk Assessment are compared to the ATSDR
Health Assessment ror consistency.
Oversight
Team.Meeting
Meet, as needed, with members of the oversight team, especially risk assessors,
State, ATSDR, ana Natural Resource Trustee representative to review the
PRPs* preparation of the Baseline Risk Assessment. (See the Reviewer
Checklist in Exhibit 9-2 and the Checklist for Manager Involvement in
Exhibit 9-3 of the Human Health Evaluation Manual (HHEM)).
Technical Review and comment on PRP technical memoranda (regarding chemicals of
Memoranda , concern, amendments to the Work Plans for performing Baseline Risk
Assessment activities, use of exposure scenarios and assumptions, and
. verification of toxicity values used), included in the draft and fina* Baseline ,
Risk Assessment (human health evaluation and ecological assessment). See
suggested Outline for a Baseline Risk Assessment Report in Exhibit 9-1 of the
HHEM.
5-4
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.. ,
Admlnlstrati/c Continually update the Administrative Record File and cost recovery
Record documentation.
I . t
Fact Sheet If appropriate, the pPM or oversight assistant should develop a fact sheet
explaining existing and potential risks to human health and the environment
and present it to the public. , ,
5.5
DELIV ERABLES DURING OVERS- iHT OF A PRP BASELINE RISK
ASSESSMENT
The PRP submits, at a minimum, the documents listed below during a PRP
Baseline Risk Assessment. They should be reviewed by Regional risk
assessors, other Regional scientists, and appropriate members of the TST
(including States) to answer the following questions for each document:
* Memorandum listing all hazardous substances found at the site and those
selected as chemicals of potential concern: . . .
Is there a complete list of chemicals of concern?
* Work Plan for evaluating environmental risks to aquatic and terrestrial
organisms: " ' - .
Are appropriate media covered by the sampling plan?
. - Will the sampling locations identify potential routes of migration and
"hot spots* of contamination? ... -
* Memorandum describing all appropriate exposure scenarios and all
assumptions and exposure factors used to calculate the reasonable
maximum exposure (RME). This includes a description of any fate and
transport models:
Are RMEs identified using exposure concentrations, standard default
values, and spatial relationships?
Are current and future land uses addressed?
Are residential risk and risk to sensitive subpopulations presented
accurately?
- Are contaminant pathways for all affected media presented?
1 ^
* f *
Are there any cross-media transfer effects that need to be considered?
* Memorandum listing any toxkity values used and not verified by EPA
(that is, not in the Integrated Risk Information System (IRIS) or the Health
Effects Assessment Summary Tables (HE AST) databases):
Are the toxicity values developed according to EPA guidance for
documentation?
- Are the appropriate toxicity values based on 'nature of exposure"?
5-5
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Are the appropriate "route-to-route* extrapolations identified in cases
where a toxicity value is applied across "differing" routes of exposure?.
- Are any carcinogens excluded? Why?
Draft and final Baseline Risk Assessment reports (including the hurna*
health evaluation and the ecological assessment):
- Is the format consistent with the suggested outline in Exhibit 9-1 of
the HHEM?
- Are the necessary items of the Reviewer's Checklist (Exhibit 9-2 of the
HHEM) included in the Baseline Risk Assessment?
- Are the necessary items of the Checklist for Manager Involvement .,
(Exhibit 9-3) included in the Baseline Risk Assessment?
- Does the Baseline Risk Assessment address all Regional, State and local
concerns? '
5,6
General
References
FOR FURTHER INFORMATION
* National Contingency Plan (NCP), 40 CFR 300,430(d),
* Roles of the Baseline Risk Assessment in Superfund Remedy Selection .
Decisions, OSWER Directive No. 9355.0-30, March 1991.
* Performance of Risk Assessments in Remedial Investigation/Feasibility
Studies (RI/FSs) Conducted by Potentially Responsible Parties (PRPs),
OSWER Directive No. 9835.15, August 28, 1990.
* Risk Assessment Guidance for Superfund, Volume 1, HHEM, OSWER
Directive No. 9285.701 A, EPA/540/1-89/002, December 1989.
» Risk Assessment Guidance for Superfund, Volume II, EEM, EPA/540/
1-89/001, March 1989.
* Ecological Assessment of Hazardous Waste Sites: A Field and Laboratory
Reference, EPA/600/3-89/013, March 1989.
* Superfund Exposure Assessment Manual (SEAM), OSWER Directive No..
9285.5-1, April I, 1988.
Databases
* Risk Assistant (ORD database for risk assessments).
IRIS.
» HEAST. _ ';
* AQUIRE (ORD's aquatic toxicity database).
5-6
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5.7 RESOURCES AVAIL ABLE TO.-RPMS^. ..... ' '
Personnel Oversight Assistant. . .
Regional staff (risk assessors, health and ecological scientists iti ESD, ORC,
and ATSDR representative).
Technical Support Team (TST).
» Biological Technical As stance Group (BTAG),
» Headquarters Staff (OWPE, OGC, OE - Superfund Division).
» Other Federal Agencies - USCOE, USGS, USFWS, Center for Disease
Control (CDC).
States - EPA-equivalent Agency, SGS, SFWS, SHPO.
Documents
Memorandum listing alt hazardous substances found and those selected as
chemicals of concern.
- V
Work Plan for evaluating environmental risk.
Memorandum describing all appropriate exposure scenarios (based on RME
assumptions) and fate and transport models.
Memorandum listing any lexicological and epidemiological studies used
(supplementing EPA values).
Draft and final Baseline Risk Assessment report (includes the human
health evaluation and the ecological assessment).
Data
* ATSDR Health Assessment and Toxicological Profiles.
* Results from all Technical Memoranda.
» EPA Standard Values for Exposure and Toxieity.
5.8
HELPFUL HINTS FOR THE RPM
To avoid projec: aelays during a PRP Baseline Risk Assessment, the RPM
should look for the following:
* Inappropriate elimination of chemicals from the risk assessment by the
PRP;
* Failure of PRP to consider all exposure pathways;
* Failure to sum the appropriate hazard indices and cancer risks;
* Failure to sample all appropriate media of concern;
* Failure to properly estimate the RME concentration for each medium;
5-7
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* Inappropriate exposure scenarios;
* Failure to address non-cancer effects of carcinogens; and
Failure to use non-residential exposure scenarios when future exposures
outside of those to residents is likely to occur.
i '
To help minimize'the'time spent on performing and evaluating a PRP Baseline
Risk Assessment, the RPM should:
* Present PRPs (or PRP contract! s) with examples of acceptable Baseline
Risk Assessments;
Have Regional risk assessors meet with PRP contractors to clarify any
ambiguity;
. Check PRP progress on technical memoranda (interim deliverables) before
final Baseline Risk Assessment report;
* Check the standard exposure scenarios for similar sites;
* Establish early the contaminants to be evaluated;
* Establish early the exposure scenarios to be used; and
. Notify PRPs and, if necessary, EPA counsel of any noncompliance.
5-8
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CHAPTER 6
' - -" V ."A*;.
TREATABILITY STUDIES
i i
6.1 INTRODUCTION
Treatability studies are laboratory or field tests designed to provide the data
needed to evaluate and select one or more treatment technologies, Treatability
studies performed during the RI/FS to provide information to support the
detailed analysis and remedy se ;tion taslcs and to determine whether the
potential technology can be expected to achieve the remediation goals set in
.the FS, Treatability studies are*performed when a technology cannot be
adequately evaluated on the basis of the existing information. This may be
due to the level of development of the potential technology, the composition
of waste, and the nature and representativeness of the required data.
Treatability study activities occur throughout the RI/FS; a literature survey is
performed during post-AOC scoping, field studies are performed during the
RI, and an analysis of the treatability studies will support the treatment
alternatives developed and screened during the FS. The time, needed to
perform and evaluate treatability studies may be extensive so that beginning
treatability studies in post-AOC scoping can help to prevent project delays in
the FS and later in the remedial design/remedial action (RD/RA). Therefore,
treatability studies should be conducted and completed during the RI.
6.2 PURPOSE AND GOAL FOR THE RPM
During the treatability study task, PRPs identify a general list of treatment
technologies, in which treatment is used to the maximum extent practicable
and only where it is practicable. These technologies should address
groundwater contamination and the principal threats of contamination. The
technologies also should meet the following capabilities (as stated in NCP
Section 300.430(d)):
* Protect human health and the environment;
Maintain protection over time;
* Minimize the amount of untreated waste;
* Return contaminated ground water to its previous beneficial uses, if
appropriate;
* Reduce the mobility or concentration of contamination by 90 to 99
percent, either individually or by treatment trains; and
* Identify, to the extent available, the use of innovative technologies for
treatment of the toxic/mobile contaminants.
The goal of the RPM is to determine, with support from the members of the
TST, ORD, or other approved contractor with expertise in treatment
technologies, the need for treatability studies early in the RI/FS process 'for
example, in post-AOC scoping). The RPM should emphasize the importance
of the following:
6-1
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* How acquiring the additional treatability data will satisfy the preliminary
remedial objectives and alternatives; and .
v » Hop the PRP will use the treatability study data to evaluate alternatives
and aid in remedy selection.
'
If the treatability studies are conducted after the RI (during either FS or RA),
the time needp , conduct t atability studies can lead to a major project
delay, niter ti-eatability stu< ,js have been completed, the RPM, with
technical support, should verify and document the quality of the treatment
data generated by each proposed study,
6.3 TIMEFRAME
The time necessary for the treatability studies task is directly related to the
number and kind of studies required. Treatability studies can and should be
completed during site characterization; therefore, these studies can take up to
12 months. The completion of treatability studies, however, is dependent on
the following;
i
Size or complexity of the site;
* Specific site limitations that would preclude the use of certain treatment
technologies;
* Type of treatment data needed: laboratory, bench-scale, and pilot-scale;
* Treatment and residual levels to be attained; and
* Content and quality of ths treatability study evaluation report.
6.4 HOW THE RPM OyiRSEIS TREATABILITY STUDIES
During post-AOC scoping, the PRP conducts a literature survey to determine
the need for treatability studies. The resulting PRP memorandum describes
the need (or lack of need) for performing treatability studies, identifies the
treatment and residual levels (for example, MCLs, maximum contaminant level
goals (MCLGs), ARARs, PRGs, etc.) to be attained by performing treatability
' studies, and lists the potential treatment technologies that may be able to meet
these treatment and residual levels.
The need for treatability studies can depend on activities performed after
approval of the PRPs* Work Plan (for example, ATSDR's Health Assessment,
Site Characterization Summary, Baseline Risk Assessment (EPA or PRP), and
the Preliminary Natural Resource trustee Survey). Therefore, the PRPs may
need to revise or amend the existing PRP Work Plan, SAP, and HSP to include
treatability studies. The RPM, with support from the oversight assistant and
TST, should review the PRPs' memorandum and approve the revisions or
amendments to the Project Plans.
The i-PM and ove ::ght ass. .int should perform the activities described lr*;the
following sections to oversee the PRPs, either during post-AOC scoping when
determining the need for treatability studies, or during site characterization
6-2
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_
when determining the applicability and feasibility of using the identified
treatment technologies. ' ,
Relevant Supply the PRPs with relevant guidance documents (for example, references
Guidance listed in Section 2,5). The RPM can contact ORD's SITE Program, Superfund
Documents Technical Assistance Response Team (START), Treatability Assistance.
Program (TAP), ATTIC, and oth»r approved contractors with expertise in
treatment technologies for assist ice. See Appendix A to access these
resources.
Technical
Memorandum
Review and approve the PRPs1 Technical Memorandum that identifies the
candidate technologies and describes how the literature survey was performed
by the PRPs during post-AOC scoping.
Treatment Meet with the oversight assistant, TST, State, and ORD to comment on the
Technology adequacy, of the list of treatment technologies. Treatment technologies
List decisions and treatability study type decisions should be performed for each
technology (for example, laboratory, bench-scale, or pilot-scale). (See
Figure 6-1.) The PRPs, with support from experts on treatment programs,
should devise a schedule for preliminary study to be performed during site
characterization. The RPM should approve the schedule of treatability
activities.
PRP Project If necessary, review the original PRP Project Plans (Work Plan, SAP, HSP) and
plans revise or amend the Project Plans to include a detailed description and
Amended for explanation of the need for and kind(s) of treatability studies to be performed,
Treatability or reasqn(s) not to perform, a particular study. The RPM should make sure
Studies that the amended .Project Plans adequately consider innovative technologies.
* x
Note: These last two steps correspond to the first, step during site
characterization. Plans to describe which activities need to be
, performed, who will perform these activities, and what will be gained
from performing these activities must be in place prior to the initiation
of field activity. . ' ,
Treatability Prior to PRP initiation of activities relating to treatability, studies, the RPM or
Studies oversight assistant should verify the following:
* Qualifications of the PRPs, PRP contractors, and laboratory to perform
each study;
Proper protocols that conform to CLP protocols will be used by the PRP
laboratory;
* Reasons for, or expectations of, each study (for example, identify
remediation goals to be met that protect human health and the
environment; comply with ARARs (Federal or State), including land
disposal restrictions (LDRs); reduce waste toxtctty, mobility, or volume,
for delisting a RCRA waste);
6-3
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Figure 6-1. Kinds of Treatability Studies
Laboratory Screening
Studies
Bench-Scale Testing
Pilot-Scale Testing
Purpose
To determine whether a tech-
nology is potentially viable to
treat a waste.
To identify a technology's
performance on a waste-
specific basis for an operable
unit.
To provide -:, wtitaiive perfor
mance and cost data and to
optimize design parameters on
an operable unit.
Approximate
Cost
$10Kto$50K
$50Kto$250K
$250Kto$l,OOOK
Timeframe
Hours or days to complete.
Days or weeks to complete.
Months to complete.
Result
To decide whether to proceed
with bench- or pilot-scale
testing.
To decide whether to pro-
ceed to pilot-scale or
whether the technology can
meet expected remediation
goals and can support the
nine evaluation criteria in
the detailed analysis portion
oftheFS.
To determine whether the
technology can meet expected
remediation goals and support
the use of innovative technolo-
gies.
Data Needed
for Decision
Qualitative with less "statisti-
cal significance" needed;
fewer process parameters are
included in the evaluation.
(Note: Generally not used as
a sole basis for selecting a
remedy.)
Quantitative performance
estimate and rough cost data.
Quantitative performance and
cost data, data on operational
parameters, and data on side
streams and residuals. (Note:
The data should provide proof
that the technology can meet
remediation goals.)
-------
* Equipment to be used ,ir.,each study; and
* Validation of the data that will be generated from performing each study.
Note: There is a presumption that response actions involving the placement
of treated soil and debris contaminated with RCR A -regulated wastes
will utilize a Treatability Variance to comply with LDRs and that,
under these variances, the treatment levels outlined in Superfund
, Guide *6A (OSWER Jl/ective No. 9347.3-06FS, July 1989 and revised
Marc* * "0) will sei : as alteraative "treatment standards."
Site Visit
Conduct a site visit during an initial stage of a treatability study, especially if
the potential treatment technology will involve the use of an in situ process or
will include how to ascertain the emissions resulting from any excavation. The
RPM also can oversee the feasibility of using a treatment process as well as
verifying the data generated by the treatment study.
Treatability
Study
Evaluation
Report
Review and approve the draft PRF Treatability Study Evaluation Report with
input and comments from the TST, ORD, other support staff, and State to
ensure that
* The performed work satisfies Federal and State requirements to conduct
the test;
* Technologies for treatment include innovative technologies where possible;
The type and volume of waste to be treated, media of contamination, and
area required for treatment process are identified; ' '
Treatment levels (for example, land ban, percentage or order of magnitude
reduction expected, MCLs (or MCLGs greater than zero) satisfied) are
discussed;
* Residual levels (e.g. RCRA clean closure, National Pollutant Discharge
Elimination System (NPDES) limits, and RCRA delisting, as appropriate)
are discussed; and
* The assumptions, implementation requirements, specific limitations, and
uncertainties used at the site are explained.
Administrative
Record File
Continually update the Administrative Record File and cost recovery
documentation.
6.5
DELIVERABLES DURING TREATABILITY STUDIES
The deliverable* relating to treatability studies will be submitted by the PRPs
during the post-AOC scoping and the site characterization tasks. During post-
AOC scoping, the RPM will review and approve the PRPs' Technical
Memorandum Identifying Candidate Technologies and review and approve or
comment on revisions or amendments to the PRP Project Plans (Work Plan,
SAP, HSP). Durii site chu bCterization, th£ RPM will review and appro.e
the draft and final PRP Treatability Study Evaluation Report.
6-S
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As a g aide for reviewing the PRP treatability study deliverables, the RPM
should use the "effectiveness of treatment technology for contaminated soils*
matrix presented in Figure 6-2 (taken from the "Summary of Treatment
Technology Effectiveness for Contaminated Soils," EPA/540/2-89/053,
February 1989). This figure identifies which treatment technology is effective
or ineffective on a particular type of soil contaminant until EPA develops
standard soil cleanup levels. The RPM can obtain additional, up-to-date
information by contacting ORD's SITE Program and ATTIC database.
The ?
-------
Figure 6J Potential Treatment Effectiveness For Contaminated Soil
" Eiample
Contaminant
DDT,
DDE
Vinyl Chloride
TrkUometiiyknB
Toiaphane, Lindane
TNT.RDK
Baneae, Tokcoc
TCS.PCE
-
Chromium, Copper.
Aracnic Cadmium t90% wenge tonovil efiidcocy)
pMcmiil Effecu»ent« (>70% ivcnfc removal efficiency)
No Eipecud E/Teoivenen (no eipcotd imerfeicnoe 10 ptoccti)
(<70% average itmova] efficiency)
No Expected Effrctiveneii (pounual advene effecu to oiviroranert or proceu)
1 D*U were not available for ihii lre«Ubtlily group Cooctu»ionl «e drawn from data f« compoondt
with »tmila/ phyiical and chemical duraderitiica, ' '
High itmwal effkiencie* implied by ihe data m»y be due u> volniiizalioa or toil wishing.
1 Hie prtdiaed effecuvenen may be differeni than the dua imply, due 10 limiuuoni in the u*t
conditioDi.
These technologiet may have limned applicability to high leveli of organici and ihould not be uied for
volatile organici.
Source Sununaiy of Treatment Technology Eflecliveneu for Coraammaied Soil EPA/S4CV2-89/QS3
-------
Did the treatment technology data generated satisfy QA/QC concerns?
Have the treatability study results been reviewed by experts on the
TST, ORD, BSD, and State?
Are the treatability study results documented in the draft and final R!
/Report? . .- ' . ' '
6:6
General
References
FOR FURTHER INFORMATION _
» National Contingency Plan (NCP), 40 CFR 300.430(d).
» Guide for Conducting Treatability Studies Under CERCLA, EPA/540/2-
89/058, ORD, December 1989.
» Treatability Studies Under CERCLA: An Overview OSWER Directive No.
9380.3-02FS, December 1989. ^
* Guidance for Conducting RI/FS Under CERCLA, OSWER Directive No.
9355.3-01, Chapter 5, October 1988,
The Remedial Investigation - Site Characterization and Treatability
Studies, OSWER Directive No. 9355J-OIFS2, November 1989.
* Enforcement Project Management Handbook, OSWER Directive No.
9837.2-A, January 1991.
* Guide to Treatment Technologies for Hazardous Wastes at Superfund Sites,
EPA/540/2-89/052, March 1989.
» Model Statement of. Work'for RI/FS Conducted by PRPs, OSWER
Directive No. 9835.8, June 2, 1989.
Treatability
References
Compendium of Technologies Used in Treatment of Hazardous Wastes,
EPA/625/8-87/014, ORD/CERI, September 1, 1987.
Inventory of Treatability Study Vendors Vol. 1 aad Vol. 2, Draft Interim
Final, Pre-publication version, December 1989.
., ' v
Treatment Technologies for Hazardous Wastes at Superfund Sites - A
guide, EPA/540/2-89/052, OERR, February 1989.
Technology Screening Guide for Treatment of CERCLA Soils and Sludges,
EPA/540/2-88/004, OERR, September 1, 1988.
Superfund Innovative Technology Evaluation (SITE) Strategy and Program
Plan, OSWER Directive No. 9380.2-3, December 1986.
Analysis of Treatability Data for Soil and Debris: Evaluation of Land Ban
Impact on Use of Superfund Treatment Technologies, OSWER Directive
No. 9380.3-04, November 30, 1989.
6-8
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Present and
Future
References
6.7
Personnel
Treatment Technology Bulle1inS;&*hich* are being developed by OERR and
ORD. The initial bulletins will address the following:
* Soil Washing Treatment (EPA/540/2-90/017, September 1990). .
« Slurry Biodegration (EPA/540/2-90/016, September 1990),
N
Chemical Dehalogenation Treatment: APEG Treatment (EPA/540/2-
90/015, September 1990).
Solvent Extraction Treatment (EPA/540/2-90/013, September 1990).
Mobile/Transportable Incineration Treatment (EPA/540/2-90/014,
September 1990).
' ' Soil Washing-and Solvent Extraction.
APEG Treatment.
* Slurry Biodegradation and Incineration.
» Low Temperature Thermal Desorption.
* In Situ Biodegradation.
* In Situ Vitrification.
In Situ Steam Extraction.
In Situ Soil Vapor Extraction.
Due in FY91:
i
* Granular Activated Carbon Treatment.
EPA Technology Preselection Data Requirements.
» In Situ Soil Flushing.
* Chemical Oxidation Treatment. .
* Control of Air Emissions from Material Handling.
* Air Stripping of Liquids.
More information on these bulletins can be obtained by contacting the ORD
office in Cincinnati, OH (FTS) 398-8444. .
RESOURCES AVAILABLE TO THE RPM
* Regional Staff (Peer Review, TST, ORC, Management Review Team,
ESD).
' Oversight Assistant. ,
6-9
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* ORD (Technology Sioport Centers, SITE, START, TAP, ATTIC,
Technology Forums).
Headquarters Staff (OWPE, OGC, OE - Superfund Division).
, Other Federal A<-«ncies (USCOE, USDA-SCS).
* States. , - ,
» CLP or non-CLP Laboratorie ,
Documents Originai or amended Project Plans (Work Plan, SAP, HSP).
List of Candidate Technologies.
ORD Publications and Databases.
Data Site characterization data.
* Sampling analysis and well drilling core data.
- * Literature search.
» Kinds of Studies - laboratory, bench-scale, or pilot-scale.
* Treatment and residual levels to be attained.
" '. ' " '
6.8 HELPFUL HINTS FOR THE RPM
During the treatability study task, the RPM should ensure that .
PRP Project Plans address treatability studies;
/ . *
* Treatment technologies focus on ground water and on the principal threats
to protect human.health and the environment, maintain this protection ,
over time, and minimize the amount of untreated waste;
Treatment technologies address concerns relating to emissions during
excavations;
* Treatment and residual levels are identified for each treatability study;
* Only technologies that are not cost prohibitive and that are potentially
effective in treating the waste should be considered;
* Advice .can be obtained from members of the TST, ORD, State, or other
. l expert support staff on the number and type of treatability studies to be
performed; ;
* Innovative technologies have been considered to the extent practicable; and
6-10
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* PRPs obtain representative sample v'properly ship hazardous materials,
properly dispose of test residuals, and identify the risks to communities
and workers during each test.
To help minimize the time spent on treatability studies, the RPM should:
» Verify, in post-AOC scoping, the need for treatability studies and the list
of candidate technologies;
\ * *
Contact a representative from OR: to obtain latest information on
conducting treatability studies and obtain the most current list of
demonstrated and innovative treatment technologies;
* Include a representative from one of ORD's programs on the TST, or
ensure that one is present during one of the post-AOC scoping meeting;
* Determine early in post-AOC scoping the type of treatability studies
needed - laboratory, bench-scale, pilot-scale;
* Verify the qualifications of the participants, the laboratory, and the
equipment .that will perform the studies;
Notify PRPs and, if necessary, EPA counsel of any noncomptiance;
* Review content of draft and final Treatability Study Evaluation Report
deliverable and request comments from TST, ORD, and State; and
* Make sure that sufficient information on the treatment technologies is
collected to determine whether the technology can achieve remediation
goals and support the FS analysis based on the nine evaluation criteria.
-------
CHAPTER 7
DEVELOPMENT AND SCREENING OF ALTERNATIVES
7.1 INTRODUCTION
The process of developing and analyzing an appropriate list of RA alternatives
(usually no more than four to five for a site of average complexity) is one of
the initial tasks of the FS. This ' ;t of RA alternatives uses the PRGs
generated jm post-AOC scoping,. jodified when appropriate (using the RI and
ARARs) to refine remediation goals and establish the performance standards
to be attained at each particular site. After the performance standards are
refined, remedial action alternatives should be compared to the expectations
(stated in the NCP Section 300.430), which include:
Treatment controls to address principal threats of contamination;
* Engineering (or containment) controls to address low-level threats or
where treatment is impracticable;
* A combination of treatment, engineering, and institutional controls where
appropriate; . t
Institutional controls (such as water use and deed restrictions) as
supplements to engineering controls;
* Innovative technologies which offer the potential for comparable or
superior treatement performance when compared to the performance of
demonstrated technologies; and
* Return usable ground waters to their beneficial uses wherever practicable
in a reasonable timeframe.
Note: Development of a range of alternatives may not be necessary in all
situations (for example, sites with large volumes of low level
contamination, sites where treatment is impracticable, and sites where
treatment of the entire site is cost prohibitive). In these situations, the
formal screening process may not be necessary due to the limited
number of alternatives. , . .
* - \
The aim of this task is to devise a complete and concise list of remedial
alternatives and screen this list, if necessary, according to cost, effectiveness,
and implementability. Screening may not be needed if only a small number of
/ alternatives are developed by the PRP (see note above). In either case, the
PRP must generate a comprehensive list that covers the range of reasonable
alternatives from which the RPM will be able to select a proposed remedy.
7.2 PURPOSE AND GOAL FOR THE RPM
During the development and screening of alternatives, the PRP should develop
a reasonable range of preliminary alternatives to meet the preliminary remedial
action goals and then screen the alternatives that are not effective, or
implementable, or that are gross': excessive in cost.
7-1
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When developing a preliminary list of the alternatives, the RPM should review
the alternatives for completeness and accuracy, and for technologies which
have shown potential success at other sites, or which are innovative and offer
the potential for comparable or superior treatment performance,
When screening alternatives, the RPM should ensure that only those
alternatives that are unnecessary, duplicative, or impracticable or eliminau:d.
The most efficient way for the PRP to present the range of alternatives is as
an alternatives array document, v. ich, usually contains the following:
Media of concern;
» Remedial action objectives;
* General response actions;
Remedial technology and type;
Process options based on technical practicability;
* An evaluation of the options based on effectiveness, implementability, and
cost; and
* An alternative based on the control or combination of controls to
remediate the affected media.
An example of an alternatives array document is provided in the RI/FS
Guidance, Figure 4-6, The alternatives array document should be part of the
final FS Report.
7,3 TIMEFRAME
The development and screening of alternatives begins while site
characterization activities are underway and field information is gathered on
the alternatives. The initial task of the FS, development and analysis of the
alternatives, should take up to three months. The completion of' this task is
dependent on the following factors:
* Size or complexity of the site;
* Number of operable units, if lecessary;
i
* Number of location- and action-specific ARARs triggered (particularly
land disposal restriction (LDR));
» Number of alternatives that need to be developed; and
* Content and quality of the alternatives array document to be included in
the FS Report..
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7.4 HOW TO OVERSEE THE DEVELOPMENT AND SCREENING OF
ALTERNATIVES .. .<*-< o-'+ '& *
During pre-RI/FS negotiation scoping, the RPM and oversight assistant should
have developed a nondetailed conceptual model and identified preliminary site
objectives, including site remediation goals. During post-AOC scoping, the
conceptual model and site objectives, and remediation goals may have been
modified by EPA, or in limited cases by the PRPs and approved by EPA.
Modifications may have been included in the PRP -Project Plans and used to
help determine the need to perform field activities. During the development
uid screening process, PRPs us existing, data from all of the planninp an>-.
field activities, and the site per.ormance standards established by tne uversight
team, to devise a list of alternatives that address how to treat or control all
hazardous substances at the site, including any residuals.
The RPM and the oversight assistant can oversee the PRPs' development and
screening of alternatives by performing the activities described in the
following sections.
Oversight Meet with the oversight team to establish site performance standards and
.Team Meeting review the PRPs' refined conceptual model av.J aite objectives, including
remediation goals, for consistency with performance standards.
Relevant
Guidance
Supply the PRPs (and subcontractors) with relevant guidance. Give the PRPs
an example of an alternative array document and the contents of an alternative
description. The description of each alternative should address the following:
Approximate volumes of material to be remediated;
* Implementation of requirements and timetables;
* Method of remediation and general response actions for each medium;
* Remedial technologies (treatment or containment) and process options;
* Monitoring procedures;
* Capital, operation and maintenance (O $L M) costs;
Need for 5-year review; and
a
ARARs triggered (particularly LDRs),
Focus the FS Use the NCP expectations (see Figure 2-5, Program Overview) to focus the FS
on only those alternatives that are appropriate to the site circumstances,
including the following;
The site is straightforward and it would be inappropriate to develop a full
range of alternatives;
* The need for prompt action outweighs the need to examine all appropriate
alternatives (in this case, an interim or removal action would be the
7-3
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appropriate avenue and an Engineering Evaluation/Cost Analysis (EE/CA)
may be necessary); and
* ARARs, relevant guidance, or precedents at other sites/indicate (hat there
are only a limited number of alternative,
\ '
Note: The'EE/CA is an analysis of removal alternatives conducted for a site
when a removal action is appropriate!
' "' . " !"
ARARs and Have the PRPs develop a list of action-specific ARARs and draft a technical
Technical memorandum documenting the revised remedial action objectives based on
Memoranda EPA's Baseline Risk Assessment. (Remember that chemical- and location-
specific ARARs were developed in post-AOC scoping,) This technical
memorandum needs to address source control actions and groundwater
response actions.
Sources of ARAR guidance include: « .
* NCP Preamble, 55 Federal Register 8740-66 (March 8, 1990).
CERCLA Compliance With Other Laws Manual, EPA/S40/G-89/006,
August 1988.' . ,
N
CERCLA Compliance With Other Laws Manual, Part II. Clean Air Act and
Other Environmental Statutes and State Requirements, EPA/540/G-
89/009, August 1989.
Meeting
Conduct a meeting with oversight assistant,and TST (including State), to ,
discuss the ARARs identified for the site and how the PRPs can meet these
ARARs (or obtain a waiver).
Range of Review the PRPs' range of alternatives against the program goals and
Alternatives expectations (see the preamble 'to the final NCP, 55 ggderaj Register 8666, pp.
8702-8707, or Section 3Q0.43Q(a)(lXi»)Mo see if the PRPs' proposed
technologies can help guide the development of alternatives, as well as satisfy
the individual site objectives so that the PRPs fully consider the most
promising alternatives. (See the RI/FS Guidance for aa example of a generic
alternative development process. Also see Figure 4-2.)
Screened . Review the PRPs* screened alternatives (if the number of aiternatives requires
Alternatives screening) to ensure that alternatives satisfy the NCP's cost, effectiveness and
implementability criteria. Examine how the alternatives will meet Federal and
State ARARs or whether a waiver of ARARs will be necessary. (See the
RI/FS Guidance for an example of the screening process.)
Technical Review, with the oversight assistant and members of the TST, the content of
Memoranda the technical memorandum summarizing the work performed and the results of
Review , , each activity, including the, alternative array document.
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Administrative
Record File
Document the development -and..screening process in the Administrative
Record File and compile information for cost recovery documentation.
Fact Sheet If appropriate, have the oversight assistant or PRP create a fact sheet to release
to the public on the results of the development and screening process.
7.5
DELIVERABLES DURING DEVELOPMENT AND SCREENING OF
ALTERNATIVES
The RPM approves and comments on the PRPs* Technical Memorandum
Documenting the Revised Remedial Action Objectives and the Technical
Memorandum on Remedial Technologies, Alternatives, and Screening. The
RPM will verify that these deliverables answer the following types of
questions;
* Memorandum Documenting the Revised Remedial Action Objectives
- Does this memorandum specify each contaminant and media of
concern?
- Does this memorandum identify each exposure route and receptor?
Does this memorandum identify EPA's remediation goals for each
exposure route?
Memorandum on Remedial Technologies* Alternatives, and Screening
- Does this memorandum identify which media are affected and how the
response actions, remedial technologies (including innovative
technologies), and representative process options are developed for
each medium?
- Did the PRPs consider NCP expectations to develop the alternatives?
- Does the PRP range of alternatives address, as needed, the appropriate
site controls -treatment, engineering (or containment), institutional, or
a combination of treatment, engineering, or institutional - and a no-
. action alternative? ,
Did the PRPs screen the alternatives using grossly excessive cost,
effectiveness, and implementability in accordance with the NCP
Section 30Q.430(eX7)?
- Does a preliminary review suggest that each alternative will meet
identified ARARs or that a waiver of ARARs will be appropriate?
- Does this memorandum contain complete descriptions of each
alternative and an alternatives array document?
- Was there noncompliance which warrants notification to the PRPs and,
if necessary, to EPA counsel?
7-5
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7.6
7.7
Personnel
FOR FURTHER INFORMATICM
/ **
National Contingency Plan (NCP), 40 CFR 300.430
Guidance for Conducting RI/FS Under CERCLA, OSWER Directive No,
93.r5.3-01, Chapter 4, October 1988.
The Feasibility Study - Development and Screening of Remedial Action
Alternatives OSWER Dir-ctive No. 9355.3-01FS3, November 1989.
Enforcement Project Management Handbook, OSWER Directive No.
9837.2-A, January 1991.
Model Statement of Work for RI/FS Conducted by PRPs, OSWER
Directive No. 9835.8, June 2, 1989.
CERCLA Compliance With Other Laws, OSWER Directive No. 9234.1-
010, August 8, 1988.
CERCLA Compliance With Other Laws Manual: Part II. Clean Air Act
and Other Environmental Statutes and State Requirements, OSWER
Directive No. 9234.1-02, August 1989.
Compendium of Technologies Used in Treatment of Hazardous Wastes,
EPA/625/8-87/014, September 1, 1987.
RESOURCES AVAILABLE TO THE RPM
Regional Staff (Peer Review, TST, ORC, ESD).
» Oversight Assistant.
ORD (Technology Support Centers, START and SITE Programs,
Technology Forum Representatives)..
* .Headquarters Staff (OWPE, OGC, OE - Superfuhd Division).
Other Federal Agencies (ERT, USCOE). ,
« States.
Documents Project Plans (Work Plan, SAP, HSP).
» Site Characterization Summary.
* Baseline Risk Assessment Report.
* Treatability Study Evaluation Report.
« Draft RI Report.
7-6
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Data « List of remedial action objectjves^.|:,- ' .
!
List of remedial technologies.
» List of Federal and State ARARs. .
i
Site Characterization Data.
* Baseline Risk Assessment Data.
Treatability Study Data,.
7.i HELPFUL HINTS FOR THE RPM
During the alternatives development and screening task, the RPM should
address the following: - ,
* Alternatives that address worst problems first;
* Alternatives that follow the NCP expectations;
* Alternatives that are not grossly excessive in cost, are effective and
implementable, and practicable; and
* Alternatives that satisfy site objectives.
To help minimize the time spent on developing and screening of alternatives,
the RPM should:
Focus, during post-AOC scoping, on the PRPs' preliminary list of
alternatives in its Project Plans;
Supply the PRPs with an alternative array document and an outline for
each alternative's description;
Verify the PRPs' action-specific and location-specific ARARs with the
oversight assistant and TST (including State and other Federal agencies);
* Review the PRPs' screening process to identify alternatives that satisfy
cost, effectiveness, and implementability criteria in NCP Section
300.430(eX7);
* Realize that in certain site situations, the PRPs will not need to develop a
full range of alternatives for eat h contaminant or medium of concern; and
Notify PRPs and, if necessary, EPA counsel of any noncompliance in
performing this task.
7-7
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CHAPTER 8
DETAILED ANALYSIS OF ALTERNATIVES
^ -
8.1 INTRODUCTION
Detailed analysis of developed and screened alternatives is the final task of the
FS prior to issuance of the draft and final FS Report. Detailed analysis
involves evaUs: ^ each scre« ed alternative against EPA's set of nine
evaluation criteria and then csparing (he relative performance of the
alternatives against the criteria. The nine evaluation criteria should serve as a
toot .for selecting the appropriate remedy. The aim of the RFM is to document
the detailed analysis through review and approval of a PRP-generated
memorandum, which summarizes the results of the comparative analysis. The
PRPs develop a draft and final FS Report, which also requires EPA review
and approval.
8.2 PURPOSE AND GOAL FOR THE RPM
During the detailed analysis of alternatives, the PRPs evaluate how the
screened alternatives compare with EPA's nine evaluation criteria. The PRP
also should compare each of the screened alternatives against eachother to
identify the key tradeoffs between the potential remedies, A viable remedy
will be an alternative that is protective of human health and the environment,
complies with or justifies a waiver of ARARs, is cost-effective, and utilizes
permanent solutions and alternative treatment technologies to the maximum
extent practicable,
8.3 TIMZFRAME
The detailed analysis of alternatives, like the development and screening
phases, if a non-field activity that can take up to two months. The completion
of the detailed analysis, however, is dependent on the following:
* Size or complexity of the site;
* Number and range of alternatives; and ,
* Content and quality of the detailed analysis study in a PRP memorandum
and draft and final FS Report.
8.4 HOW TO OVERSEE THE DETAILED ANALYSIS OF ALTERNATIVES
During the previous task of developing and screening alternatives, alternatives
were identified that satisfy the cost, effectiveness, and implementability
criteria. The PRPs now evaluate each screened alternative against EPA's nine
evaluation criteria (see Figure 8-1) where each criterion is given equal weight.
As part of this evaluation, the PRPs compare each screened alternative against
each other and identifies any key tradeoffs that may be helpful to consider
during Jhe selection of remedy phase.
8-1
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Figure 8-1, Summary of Nine Evaluation Criteria
For additional information on the Nine Evaluation Criteria, see the
NCP,40CFR300.430(d)
Overall protection of human health and the environment describes how
existing and potential risks from pathway of concern are eliminated, reduced, or
co, .trolled through treatment, engineering .ontrols, institutional controls or by a
combination of controls.
Compliance with ARARs addresses whether an alternative meets its
respective chemical-, location-, and action-specific requirements or can invoke a
waiver for an ARAR, '
Long-term effectiveness and permanence evaluates performance alternatives
in protecting human health and the environment after response objectives have
been met and includes:
\_ '
~ Magnitude of residual risk (untreated waste and treatment residuals)
~ Adequacy and reliability of controls (engineering and institutional) used
to manage untreated waste and treatment residuals over time.
1 ' '
Reduction of toxicity, mobility, or volume through treatment assesses
performance of alternatives in terms of reducing toxicity, mobility, or volume
through treatment and whether or not statutory preference for treatment as a
principal element is satisfied. . .
Short-term effectiveness addresses the impacts of alternatives on human
health and the environment during construction and implementation until
response objectives are met and the length of time until protection is achieved.
Imple tnentability assesses degree of difficulty and uncertainties with
undertaking specific technical and administrative steps and the availability of
various service and materials. . ,
- '
Cost addresses costs of construction (capital) and necessary costs of*
operation and maintenance (present worth analysis assumes 10 percent discount
ra*«s, and the period of performance for costing purposes should not exceed 30
years)'. ., ,' . v _ .
State (support agency) acceptance evaluates technical and administrative
issues and concerns the support agency may have regarding each of the
alternatives. N
Community acceptance evaluates issues and concerns the community may
have for each alternative.
i-2
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The RPM and oversight assistant can overs** the detailed analysis of
alternatives by performing the activities described in the following sections.
Relevant
Guidance
Supply the PRPs (and subcontractors) with relevant guidance. Give the FRPs
a good example of a detailed analysis memorandum and an FS Report,
Screened Review the PRPs' analysts of each screened alternative against each of EPA's
Alternatives nine evaluation criteria with the ^ersight contractor and TST.
Note: This is a qualitative evaluation where each criterion is evaluated on a
relative basis. \
" Note: The oversight team should scrutinize aay containment-only remedies
and determine if there are any "hot spots* of contamination that should
be addressed through treatment.
Comparative Review the PRPj* comparative analysis of alternatives against each other and
Analysis identify key tradeoffs (strengths and weaknesses) among the alternatives.
^
Management Conduct a management review meeting with Regional managers, oversight
Review assistant, TST, and State to review the comparative study in the detailed
analysis memorandum and FS Report.
Administrative
Record File
Document the FS report in the Administrative Record File and update
expenses for cost recovery documentation purposes.
Fact Sheet If appropriate, develop a fact sheet or assign it to the oversight assistant to
allow public input and/or conduct a public meeting on the FS Report.
(Alternatively, public input on the FS Report can be obtained in conjunction
with the Proposed Plan.)
Final FS
Report
Consider comments on the FS Report from the State and incorporate these
comments, if applicable, into the final FS Report.
8.5
DELIVERABLES DURING THE DETAILED ANALYSIS OF ALTERNATIVES
During the detailed analysis task; the RPM reviews and approves the following
PRP deliverable!: the Technical Memorandum Summarizing the Results of the
Individual and Comparative Analyses of Alternatives and the draft and final
FS Report. The RPM should verify that these deliverable! answer questions in
the following areas:
* Memorandum Summarizing the Results of the Comparative Analysis of
Alternatives
- Does this memorandum address each of the nine evaluation criteria?
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8.6
8.7
Personnel
Does this memorandum include a comparison of alternatives against
each other to 'identify tradeoffs?
" Draft FS Report
- Similar questions as above.
- Are the strengths aad weaknesses of the different alternatives clearly
described between etch otw'-r?
FOR FURTHER INFORMATION
* National Contingency Plan (NCP), 40 CFR 300.430
-------
Treatability Study Evaluation R iport.
Draft RI Report.
Revbed Remedial Action Objectives Memorandum.
« Remedial Technologies, Alternatives, and Screening Memorandum,
Data List of revised remedial action >jectives.
* List of revised remedial technologies.
* List of Federal and State ARARs.
i
Site Characterization Data.
Baseline Risk Assessment Data,
I ;
* Treatability Study Data.
* List of Screened Alternatives, if applicable.
8.8 HELPFUL HINTS FOR THE RPM
/
During the detailed analysts of alternatives task, the RPM should ensure that
* PRPs addresses all nine criteria in its detailed analysis;
* PRPs compares each screened alternative against each other;
* RPM receives input from the oversight assistant, TST (including State),
and the Regional management review team on the completeness of the
detailed analysis;
* PRPs are not slanting analysis of alternatives, without the appropriate
justification, towards no or little action;
» PRPs are not slanting analysis of alternatives, without the appropriate
justification, towards the least costly remedy; and
* Alternatives are protective of human health and the environment and meet
ARAR(s) or can qualify for a waiver of ARARs.
The RPM can help minimize the time spent on the detailed analysis of
alternatives by: ^
* Supplying the PRPs with sample documents of a detailed analysis technical
memorandum and an FS Report;
. * Ensuring that the PRP analyzes each screened alternative against each of
the nine evaluation criteria without assigning greater weight to any
criterion;
8-5
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Ensuring that the PRP* perform the comparative analysis of screened
alternatives against each other to identify individual advantages and
disadvantages and tradeoffs; and
,'
Reviewing, with th? oversight assistant, TST (including State), and the
Regional management review team, the quality and content of the detailed
analysis memorandum and the draft and final FS Report; and
Notifying PRPs and, if necessary EPA counsel of any nbncomplianee in
performing this task.
8-6
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. ' APPENKXA
TECHNICAL RESOURCES AVAILABLE THROUGHOUT THE RI/FS
Although the EPA remedial project manager (RPM) is ultimately responsible
' for overseeing a remedial investigation/feasibility study (RI/FS) led by
potentially responsible parties (PRPs), the RPM has many different technical.
resources available to assist with or carry out the RI/FS oversight. These
include resources from within th* EPA Regional office, EPA Headquarters
offices, EPA contractors and co ablauts, other Federal agencies and ,
departments, and State and local governments.
i *
Chapter 1.1 of this guidance addresses the role of the RPM and his or her
designated oversight assistant. This appendix helps to identify further
resources that can assist the RPM and oversight assistant during the different
phases of the RI/FS. Obtaining access to a resource for oversight activities
may require the RPM to have funds available to transfer to the selected
resource. The RPM may also be required to complete work-initiation forms
and attach a Statement of Work (SOW) or work assignment. In all cases, it is
important for the RPM to identify during the pre-Rl/FS negotiation scoping
phase the oversight resources that will be most appropriate and the
requirements for obtaining access to them.
i
A.I HEADQUARTERS ASSISTANCE
Office of Waste Programs Enforcement (OWPE) - The CERCLA
Enforcement Division can assist in the review of legal or technical documents
or respond to questions about oversight implementation or procedures. OWPE
Regional Coordinators should be the prime point of contact.
CERCLA Enforcement Division (FTS) 398-8404
or (703) 308-8404
* Guidance and Evaluation Branch (FTS) 475-6770
* Compliance Branch (Regional Coordinators) (FTS) 398-8484
or (703) 308-8484
Office of Emergency and Remedial Response (OERR) - The Hazardous Site
Control Division (HSCD) can assist in the review of technical documents or
respond to questions on implementing procedures for Fund-lead sites. HSCD
publishes the "Superf und Records of Decision (ROD) Update" to aid RPMs in
developing RODs by providing u-eful information and a means for RPMs with
1 similar site issues to interact. OERR Regional Coordinators should be the
prime point of contact.
* Hazardous Site Control Division (FTS) 398-8313
or (703) 308-8813
* Remedial Operations and Guidance (FTS) 398-8444
Branch or(703) 308-8444
* Design and Construct? in (FTS) 475-670">
Management Branch or (703) 308-8393
A-l
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State and Local Coordination (FTS) 398-8380
Branch , or(703) 308-8380
Office of General Counsel (OGC) - OGC can provide assistance in reviewing
legal or technical documents or respond to questions about oversight
implementation, NCP procedures, or legal questions under CERCLA,
Generally, contact with OGC is made through the Office of Regional Counsel
(ORC) or OWPE/OERR Regional Coordinators.
Office of Enforcement (OE) - OE ca provide additional assistance in
reviewing legal documents responding to legal questions about CERCLA, NCP
procedures, and oversight implementation, and taking enforcement actions. In
addition, the Regional Coordinators for Federal facilities are now in OE.
Generally, contact with OE is made through each Region's ORC.
Office of Research and Development (ORD) Contact with ORD can be made
through the ORD Regional liaison in each Regional office. ORD is located in
Headquarters or in one of the following Technical Support Centers:
* 5
* Risk Reduction Engineerng Laboratory 'RREL) Center for
Engineering Programs and Treatability Studies in
Cincinnati, OH. The center can assist in planning and
researching for Engineering and Treatment Support,
Treatability Assistance Program (TAP), and the Superfund
Technical Assistance Remedial Technology (START) team,
(FTS) 684-7406,
* Environmental Research Laboratory (ERL), Center for
Exposure Assessment and Ecological Risk Technology
Support in Athens, GA. This includes the Center for
Exposure Assessment Modeling (CEAM), (FTS) 250-3134.
* Robert S. Ken- Environmental Research Laboratory
(RSKERL) Center for Groundwater Fate and Transport in
Ada, OK. The laboratory includes the Subsurface
Remediator Information Clearinghouse in Ada and the
International Groundwater Modeling Center at the Holcomb
Research Institute in Indianapolis, IN, (FTS) 743-2224.
>
Environmental Monitoring Systems Laboratory (EMSL)
Center for Monitoring and Site Characterization in Las
Vegas, NY, (FTS) 545-2523,
Environmental Criteria ai.d Assessment Office (ECAO),
Center for Health and Risk Assessment in Cincinnati, OH,
(FTS) 629-4173.
* Other environmental research laboratories are located in
Narragansett, Rt (FTS) 838*6001; Gulf Breeze, FL; (FTS)
686-9011; Duluth, MN; (FTS) 780-5549; and Corvallis; OR,
(FTS) 420-4601.
A-2
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. .
Technical assistance is also available through the following programs:
' » The REEL Superfund Innovative Technology Evaluation (SITE)
program can assist in conducting or reviewing treatability studies,
serening/ Analyzing remedial alternatives, and bench/pilot/full-
scale testing of remediation technologies. Access to SITE is
obtained by contacting the ORO Regional liaison (ORD employees)
located in each Region.
Groundwater and Engineering Technical Support Forums.
Representatives from Groundwater Fate and Transport and
Engineering and Treatment Forums transfer information
between the Technical Support Centers and the Regions.
Most forums are informal sessions organized by Regional
Section Chiefs.
National Enforcement Investigations Center (NEIC) - serves as the principal
source of expertise for civil and criminal litigation, and technical support.
NEIC access usually requires an oral request from a jiuperfund Branch Chief.-
The center, located in Denver, can be reached at (FTS) 776-5100.
A.2 REGIONAL AND NON-EPA ASSISTANCE
RPMs have a wide variety of resources available in the Regional offices.
Initial access to these resources usually requires informal contact (phone call or
visit) between the RPM and staff members in the desired office or division,
Peer Review - Regional in-house peer review can help in responding to
specific technical questions or reviewing technical memoranda and reports
(sometimes exists as a technical support section).
Environmental Services Division (ESD) - Regional ESDs can review site
project plans, oversee field activities,' provide blank and spiked samples for
quality assurance, and conduct laboratory and field audits. ESD can oversee
activities up to and including performance of the RI.
Environmental Response Team (ERT) la Edison, NJ - ERT can provide
assistance la conducting and overseeing removal and remedial actions. ERTs
capabilities include review of site project plans and reports, oversight of field
activities, review of conceptual designs, and provision of expert testimony.
Office of Regional Counsel (ORC) - ORC provides primary assistance to the
RPM in reviewing legal documents negotiating orders and decrees, making
referrals to the Department of Justice (DOJ), and taking enforcement actions.
i
Water Division - Regional Water Division provides information on surface
water and drinking water concerns from the following areas: Office of
Groundwater Protection, Water Quality Planning tnd Standards Section, Water
Supply Section, Toxicology, and Wetlands.
Air Division - Regional Air Division provides information on air emission and
ambient air standards from the following areas: Toxic Substances Control
Act-PCBs, Modeling, and Air Toxin.
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Waste Management Division - Regional Waste Management Division provides
information on Resource Conservation and Recovery Act waste management
requirements, .
Public Affaire - Regional Public Affairs is helpful in disseminating
information to Stales, local governments, and the community. For example,
the Community Relations Coordinator (usually not in Public Affairs Office)
can assist in implementing a community relations plan (CRP).
A;3 REGIONAL CONTRACTS
EPA maintains several contracts with architectural and engineering firms to
assist EPA Headquarters and Regions in implementing the Comprehensive
Environmental Response, Compensation and Liability Act (CERCL A). These
level-of-effort (LOE) contracts allow specific tasks to be assigned to the
contractor on an as-needed basil, within the restrictions of the overall contract
SOW and within the technical labor hours and dollar ceilings established by the
contract.
Technical Enforcement Support (TES) Contracts - These are the primary
contracts for overseeing PRPs during CERCL A response activities. These
LOE contracts allow specific tasks to be assigned to the contractor on an as-
needed basis, within the restrictions of the overall contract and within the
technical labor hours and dollar ceilings established by the contract. Oversight,
tasks assigned to TES contractors include the following:
* Financial assessments;
, * Expert witness/consultant;
* . Technical review of documents;
Records compilation;
* Risk assessment;
t
* Oversight of field activities, including compliance monitoring;
* Sampling analysis;
Evidence storage/preservation;
* Special studies; .
» Design development, placement, and data evaluation for ground-
water monitoring wells;
* Design and implementation of surface and subsurface site
investigations;
* Collection and evaluation of evidence on PRP waste activity;
» Development of negotiation ?nd litigation strategies;
* Evaluation of PRP settlement offers;
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* Development of mechanisms for financing FRF settlements; and
< *
* Design and preparation of technical assistance training programs on
oversight for RPMs.
These .tasks are assigned 10 the contractor through individual written work
assignments that contain SOWs, delivery schedules, and other performance
schedules. Questions regarding access to TES contractors should be directed to (,.
the appropriate regional conwt. Additional information on TES contract *
be obtained from the "TES U T Guide," June 1987 and the fortJv- -'--
updated TES User Guide" (planned for early 1992), , ,
Alternative Remedial COD tracts Strategy (ARCS) - This program also is used
for overseeing PRPs during CERCLA response actions.. The ARCS contracts
are also LOE based. The contracts under this program provide remedial
planning, design, and implementation, as well as site-specific project
management and other technical and management assistance. The ARCS
program incorporated the contracts previously covered by the Remedial
Engineering Management (REM) program. The types of oversight tasks that
may be assigned to an ARCS contractor inr»",de the following:
Project planning;
* Remedial oversight;
Risk assessment;
* Sample analysis and validation;
* Enforcement support;
* Community relations; and
j
Data management.
Questions regarding access to ARCS contractors should be directed to the
appropriate Regional contact
Field Investigation Team (FIT) Contracts - Contractors in this program can
assist in collecting and reviewing preliminary assessment/site investigation
(PA/SI) data, scoping and planning schedules, field oversight of site
characterization, and report review. FIT is accessed by issuing a work
assignment through developing a SOW, and working with the Regional FIT
contracting office; "
Technical Assistance Team (TAT) Contracts - This program can assist in
removal actions, oversight of removal actions, and planning and scoping for
interim measures. TAT is accessed by issuing a work assignment through
developing a SOW, and working with the Regional TAT contracting officer.
Emergency Response Cleanup Services (ERCS) Contracts - This program can
assist in emergency response, spill response, oversight of removal actions, and
planning and scoping activities. ERCS is accessed by issuing a work
assignment through developing a SOW, and working with the Regional ERCS
contracting officer.
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Contracting Laboratory Program (CLP) - This program is a major source of
analytical data for use in the RI and Baseline Risk Assessments, CLP is a
nationwide network of contractor laboratories and a major vehicle for
Superfund analysis, especially to provide routine analytical services (RAS) and
special analytical services (SAS). When a non-CLP laboratory is chosen at
PRP-lead sites, CLP is responsible for using split samples as quality assurance
(QA) and quality ..control (QC) procedures to verify the accountability and
accuracy of the sampling procedures employed at the site. At a minimum, for
enforcement considerations, 10 percent of the samples should be split and sent
to a CLP lab.
For information regarding the CLP, contact the Analytical Operations Branch
of OERR at FTS 382-7906 or the Sample Management Office at (703) 6S4-
5678. Additional contacts can be obtained from the fact sheet. Contract
Laboratory Program (OSWER Directive No. 9200.5-320 F/5, September 1990).
A.4 OTHER FEDERAL AGENCIES
RPMs also can obtain oversight assistance from other Federal agencies. This
generally requires RPMs to reallocate funds to the appropriate agency through
an interagency agreement (IAG). These lAGs usually are executed in
coordination with a Regional contact in the Region's Superf und Contracts and
Administration Section. <
Agency for Toxic Substances and Disease Registry (ATSDR) - A' part of the
Centers for Disease Control,. ATSDR can assist in determining current or
potential risk to human health that exists at a site. The regional ATSDR
representative should be contacted during pre-PRP negotiation and, if
possible, should be a member of the Technical Support Team (TST).
s
Department of Defense (DOD) - The U.S. Army Corps of Engineers
(USCOE) - can provide the following:
* Expert witness during RI/FS negotiation and litigation;
* Oversight of field activities;
* Hydrogeologic studies;
* Treatability Studies; and
* Other special studies. .
Department of Interior (DOI) * The U.S. Fish and Wildlife Service
(USFWS) - can provide the following:
* Expert witness during RI/FS negotiation and litigation;
* Natural resource endangerment studies; and
Preliminary Natural Resource Surveys (for migratory birds,
federally listed threatened and endangered species, anadromous
fish, Federal minerals, National Park land, and Tribal Trust
resources). «
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DOI - The U.S. Geological Surrey (USGS) - can provide the following:
* Expert witness during RI/FS negotiation and litigation;
« Oversight of field activities during RI;
Hydrogeologic studies; and _
Other special studies,
U.S. Department of Agriculture'(USDA) - USDA can provide expertise in
managing agricultural, forest, and wilderness areas. In addition, the Soil
Conservation Service (SCS) can help predict fate and transport of pollutants in
soil, and can provide expertise for the TST when soils are contaminated.
Department of Commerce (DOG) - National Oceanic and Atmospheric
Administration (NOAA) - NOAA can provide information on meteorologic,
hydrologic, ice, and oceanographic conditions for marine, coastal, and inland
waters and can provide expertise on certain living marine resources and their
habitats.
Department of Energy (DOE) - DOE can assist in identifying, removing, and-
disposing of radioactive contamination.
/
Department of Health and Human Services (HHS) - HHS can assist in
assessing site health hazards and protecting site personnel and public health.
* * !
\
Department of. Justice (DOJ) - DOJ represents the Federal government in N
litigation. The Land and Natural Resources division commonly, is involved in
environmental litigation.
Department of Labor (DOL) - DOL can assist in identifying Occupational
Safety and Health Administration (OSHA) requirements for hazardous waste
sites.
Department of Transportation (DOT) - DOT can assist in identifying
requirements for the manifesting and transport of hazardous waste and
materials (see Appendix B in Volume 2 of this manual).
A.5 DATABASES
There are a number of databases available to RPMs through the Regional
libraries or through personal compucer (PC)-modem (phone-line) connections
from PCs in their sections. These include commercial, EPA, and other Federal
and State databases. Described below are several of the primary databases that
can assist RPMs with PRP oversight. They generally can be divided into three
types:
Those that track similar components of response actions or case
histories at other sites;
* Those that provide detailed sources of data to support the many
types of analyses associa :d with an RI/FS; and
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Those that serve as bulletin boards and provide technology transfer
and information on other resources.
Tracking Case
History
Databases
Technical
Analysts
Databases
Enforcement Document Retrieval System (EDRS) - EDRS is menu-driven and
allows the user to search through EPA enforcement documents by document
category, specified time period, or specified law, or by any word or set of
words within the document text. Three types of documents are routinely
updated: policies and procedv,:ar administrative enforcement, and judicial
action. The sys?« -.can be acr 'sed by terminals that are direct-wired to
EP^'s M i:caaj Computer Cei )r (NCC) in Research Triangle Park. For
additional information, check the EDRS User's Manual, the Regional EDRS
Contact in ORC, or call OE at (FTS) 382-2614.
Hazardous Waste Caseflnder System (Caseflnder) - The Casefinder includes
the hazardous waste cases found or cited in the Federal Reporter system, the
Hazardous Waste Litigation Reporter, the Toxics Law Reporter, the Chemical
Waste Litigation Reporter, the Environmental Law Reporter, and a
considerable number of important unreported cases. As of October 1987, 700
Federal court opinions had been categorized and entered into the Casefinder.
New cases are added monthly. In order to use Casefinder, the user must have
a valid user ID to access the NCC in Research Triangle Park. For additional
information concerning Casefinder, contact the OE at EPA Headquarters.
RODS Database - RODS contains Superf und Records of Decision (ROD),
which describe the planned course of action to clean up a site. The database,
installed on a mainframe at EPA's NCC in Research Triangle Park, allows
searching for selected information from ROD documents or National Technical
Information System (NTIS) Abstracts. Access is via modem from a PC.
Register through the RODS Hotline at (202) 252-0056.
Fxpert Resources Inventory System (ERIS) - ER1S is a searchable database
that contains resumes in summary form and information on qualifications, area
of expertise, and previous experience of specialists available as expert
witnesses or consultants to support hazardous waste enforcement actions. The
database hid been classified as "enforcement confidential" and is protected
under the Privacy Act of 1974. The database may be accessed by EPA and
DOJ staff upon request. Users should contact the EPA OWPE for information
on accessing the database. >
Hazardous Waste Collection Database (HWCD) - HWCD is a bibliographic
database containing abstracts of EPA and other government agency reports,
commercial books, policy and guidance directives, legislation, and regulations
concerning hazardous waste, is searchable by subject; and has a database
thesaurus to aid users in designing efficient searches. The database is available
through the EPA library system. <
Alternative Treatment Technology Information Center (ATTIC) - The ATTIC
system is designed to provide technical information on alternative methods of
hazardous waste treatment. ATTIC is available through any modem-equipped
IBM-compatible PC using standard communications software. The core of the
ATTIC system is the ATTIC database, a keyword-driven system that contains
technical information .in the form ofabstracts or report summaries from a
variety of sources including the SITE program. States, industry, DOD/DOE,
RODS Database, and treatability studies. Other databases contained in the
ATTK. system that ;n be dL ~t!y tcctssed include:
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* RREL (Water) Treatability Database.
* RSKERL Soil Transport and Fate Database. -
* EPA Library Hazardous Waste Collection Database.
* Cost of Remedial Action (CORA) Model.
Geophysics Advisor ;xpert System.
Also available through ATTIC is the Computerized On-Line Information
System (COLIS) and its three databases: Case File History, Library Search
System, and SITE Application Analysis Report File. To access ATTIC, contact
the ORD Regional liaison in your Region or the ATTIC system operator at
(301)816-9153.
Integrated Risk Information System (IRIS)'- IRIS contains health risk data,
bibliographic and textual information on risk management, water quality
criteria, and drinking water standards. It is available on-line through EPA's
electronic mail system (E-MAIL). To access IRIS through E-MAIL, after
signing on, type "IRIS" at the ">" prompt
ORD Superfund Remediation Information (SRI) Database - SRI contains
information pertaining to fate, transport, and in-place treatability of
contaminants in subsurface environments. SRI can be used to locate other
information sources pertinent to reclamation of contaminated soils and ground
waters, including planned, active, and completed subsurface remediations.
Users need to contact the ORD RSKERL in Ada, OK, to access the system:
ORD Aid for Evaluating the Redevelopment of Industrial Sites (AERIS) -
AERIS helps make risk-based cleanup calculations,at industrial sites. AERIS
evaluates on-site costs for one chemical, one receptor, one land use, and one
environmental setting. It relies on data from past soil contamination. Users
need to contact the ORD RSKERL in Ada, OK, to access the system. .
Technical Information Exchange (TIX) - 71X is a compiled database available
on diskettes to EPA Regional and contracts personnel and State personnel.
TIX provides a complete file of each applications analysis for technologies
evaluated under the Superfund Innovative Technology Evaluation (SITE)
program. Diskettes are available from Hugh Masters of EPA ORD at FTS
340-6678.
RISK'ASSISTANT - RISK*AS5ISTANT Is a microcomputer software system
designed to help assess health risks posed by hazardous waste.
RISK*ASSISTANT is not a substitute for expert evaluation, but provides easy-
to-use databases and analytical tools that screen potential hazards, exposures,
and risks at hazardous waste sites. RISK*ASSISTANT was developed by the
Hampshire Research Institute, (703) 683-6695, in conjunction with the Office
of Health and Environmental Assessment (OHEA).
CERCLA Scheduling and Cost Estimating Expert System (SCEES) - SCEES is
an expert system under development to provide site-specific Superfund
Comprehensive Action Plan (SCAP) quality schedule and cost estimates for the
RI/FS process. SCEES is a tool for determining timely resource and
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scheduling estimates. For more information on SCEES, contact the CERCLA
program office.
Commercial Databases - DIALOG, Chemical Information System, and BRS
Search Services are examples of commercial databases that abstract information
relevant to EFA's hazardous and solid waste programs and are searchable free
of charge via EPA Headquarters and Regional librarians. For more
information, contact your Regional librarian.
A.fi COMPUTER-BASED BULLETIN BOARD
, x »
OSWER Electronic Bulletin Board System (BBS) - OSWER BBS facilitates
communication and the dissemination of information among EPA staff in
Regional offices. Headquarters, and research laboratories. To use the OSWER
BBS, the user needs a PC or terminal, a modem, and a communications
program. To access the OSWER BBS, dial (202) 589-8366 or (301) 589-8366
after setting CrossTalk parameters to 8 data bits, 1 stop bit, and no parity.
Choose a password, complete an on-line registration questionnaire, and within
24 hours you will be a registered user with full access to all features of the
system. The BBS is available to EPA staff and current contractors and State
and Federal agency personnel.
Major features of the OSWER BBS include the following:
* Information bulletins.
* Message exchange.
*i . ; » File exchange.
* Technical publications ordering.
* On-line databases and directories.
A.7 HOTLINES
EPA Headquarters has established several national telephone hotlines that can
be used by anyone in need of technical assistance or wishing to report~
findings. Additional Regional, State, or commercial hotlines may also be
available.
RCRA/Siiperfund Hotline
National Toll-Fre* 800-424-9346
EPA's largest and busiest toil-free number, the RCRA/Superf und Hotline
answers nearly 100,000 questions and document requests each year. Hotline
specialists answer regulatory and technical questions and provide documents on
virtually all aspects of the RCRA and Superf und programs. Because of die
complexity and changing nature of these programs, the hotline is used widely
by the regulated community, people involved in managing and cleaning up
hazardous'waste. Federal, State, and local governments, and the general public.
The RCRA/Superf und Hotline can be reached Monday through Friday from
' 8:30 a.m. to 4:30 p.m. Eastern Stai.lard Time (EST).
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Federal Facilities Docket Hotlije
National Toll-Free 800-548-1016
Washington, D.C., Metro 703-883x8577
Operated by the EPA Office of Federal Facilities Enforcement (OFFE), the
hotline has been in service since 1988. The hotline responds, to specific
questions about Federal facility compliance with the docket requirements
outlined in Section 120 of CEBC1 A., as amended. The hotline can be accessed
Monday through ^ :dtay from P '0 a.m, to 5:30 p.m. EST.
National Response Center Hotline
National Toll-Free 800-424-8802
Washington, D.C., Metro 202-426-2675
Operated by the U.S. Coast Guard, the National Response Center Hotline
responds to all kinds of accidental releases of oil and hazardous substances.
This hotline is available 24 hours a day, 7 days a week, every day of the year.
Chemical Emergency Preparedness Program (CEPP) Hotline
National Toll-Free 800-535-0202
Washington, D.C., Metro and Alaska 202-479-2449
The CEPP Hotline has been in operation since late 1985, responding to
questions concerning community preparedness for chemical accidents. The
Superfund Amendments and Reauthorization Act (SARA) increased the CEPP
Hotline's responsibilities, which now also include Emergency Planning and
Community Right-to-Know and SARA Title II! questions and requests. The
CEPP Hotline, which complements the RCRA/Superfund Hotline, is
maintained as an information resource rather than an emergency number.
Calls are answered Monday through Friday from 8:30 a.m. to 4:30 p.m. EST.
National Pesticides Telecommunications Network (NPTN)
National Toll-Free 800-858-7378
(858 -P-E-S-T)
Texas 806-743-3091
Operating 24 hours a day, 7 days a week, every day of the year, the NPTN
provides information about pesticides to the medical, veterinary, and
professional communities as well as to Federal agencies and the general public.
Originally a service for physicians wanting information on pesticide toxicology.
and on recognition and management of pesticide poisoning, the NPTN has
expanded to serve the public and Federal agencies by providing impartial
information on pesticide products, basic safety practices, health and
environmental effects, and cleanup and disposal procedures. Staffed by
pesticide specialists at Texas Technical University's Health Sciences Center
School of Medicine, this hotline handles about 18,000 calls each year.
Small Business Hotline
National Toll-Free 800-368-5888
Washington, D.C., Metro 703-557-193*
Sponsored by the EPA Small Business Ombudsman's Program, this hotline
assists small business in complying with environmental laws and EPA
regulations. The Small Business Hotline gives companies easy access to EPA,
lod in. jstigates and rsolves i .Menu and disputes with EPA. Acting as a
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liaison with Agency program offices, the hotline ensures that EPA considers
small business issues during its normal regulatory activities. The Small
Business Hotline operates Monday through Friday front 8:30 a.m. to S p.m.
EST, handling over 7,000 inquiries each year.
Safe Drinking Water Hotline
National Toil-Free 800-426-4791 . ' "
Washington, D.C., Metro 202-382-5533
The EPA's Safe Drinking Water Ho :ne began operating in July 198?. Its
primary function is to assist the public and the regulated community,
including Federal facilities, in understanding EPA's regulations and programs
developed in response to the Safe Drinking Water Act Amendments of 1986.
The hotline service provides information on EPA's drinking water programs,
including the Public Water Supply (PWS1 and Underground Injection Control
(U1C) programs. The hotline operates Monday through Friday (except Federal
holidays) from 8:30 a.m. to 4:30 p.m., EST.
Inspector General's Whistle Blower Hotline
National Toll-Free 800-424-4000
Washington, D.C., Metro 202-382-4977
The EPA Inspector General's Office maintains the Whistle-Blower Hotline to
receive reports of EPA-related waste, fraud, abuse, or mismanagement from
the public and from EPA and other government employees. EPA employees
may make complaints or give information to the Inspector General's Office
confidentially and without fear of reprisal. The Whistle-Blower Hotline is
staffed to answer calls in person from 10 a.m. to 3 p.m. EST, Monday through
Friday. At other times, callers may leave a message to be answered during the
next work day. The hotline handles about 1,500 calls each year.
TSCA Assistance Information Service
Washington, D.C., Metro
202-554-1404
t,
The TSCA Assistance Information Service provides information on TSCA
regulations to the chemical industry, labor and trade organizations,
environmental groups. Federal facilities, and the general public. Technical
and general information is available. To help facilities comply with TSCA, a
variety of services are offered, including regulatory advice and aid,
publications, and audio-visual materials. The TSCA Assistance Information
Service now handles about 2,500 calls a month and can be reached from 8:30
a.m. to 5 p.m. EST, Monday through Friday.
A.S PUBLICATIONS
There are several compendium* and catalogs of Superfund and hazardous
waste reference materials, guidances, and other publications. RPMs should
check with the Regional or Headquarters librarian for these publications or
sources indicated below.
Catalog of Saperfund Program Publications - OSWER Directive No. 9200.7-
02A, October 1990 (85 pages). This catalog provides a reference to policy,,
procedural, and technical directives Find publications governing the Supe '"urid
program. Regular supplements are planned. Publications abstracted must be
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have copies. Copies of the catalog may be obtained from the Superfund
Document Center by writing the S.ipeVfund Documents Coordinator (OS-
240), U.S. EPA, 401 M St. S.W., Washington, DC 20460.
OSW1R Directives - System Catalog - OSWER Directive No. 9013.15-3D (30
pages). Provides a list of OSWER Directives published through June 1988,
Each Region cAso has an OSWER Directive Coordinator.
Superfund Risk Assessment Information Directory - OSWER Directive No:
9285.6-1 (202 pages). Publication vrumber EPA/540/1-86/061. The directory
identifies and describes sources of ^formation useful in conducting risk
assessments. The directory covers sources of information to aid in hazard
identification, dose-response assessments, exposure assessments, and risk
characterization. Available from the Superfund Document Center.
Annotated Technical Reference for Hazardous Waste Sites ,
Contact OWPE CERCLA Guidance and Evaluation Branch, at (FTS)
475-6770.
This reference, though still in draft, provides information on 14 common site
types: asbestos, battery recycling/lead, dioxias, landfills, metals, mining
wastes, mixed waste, multi-source ground water, munitions, PCBs, pesticides,
plating, solvents, and wood preserving. Other information is directed at
ARARs, risk assessments, and summaries of typical site characterizations.
This reference provides access to technical expertise through lists of Regional
technical experts and technical references.
CERCLA Administrative Records: Compendium of Frequently Used
Guidance Documents in Selecting Response Actions
Contact: OWPE, CERCLA Guidance and Evaluation Branch, FTS 475-
6770, or Regional Administrative Records Coordinator
This reference serves as a central library of guidance documents in each
Region. It saves resources by avoiding the need to copy such documents for
each administrative record,
Accessing Superfuod Guidance Documents
U.S. EPA staff can obtain reports, fact sheets, or directives
(OERR/OWPE) from the Superfund Document Center by calling FTS 382-
5628. Rule making and Federal Register listings can be obtained from .the
Superfund Docket by calling FTS 382-3046. Information on innovative
technologies can be obtained from the Treatment Innovation Office (T1O)
by calling (703) 308-8800. Many documents can be ordered from the
Center for Environmental Research Information (CERI) by calling FTS
684-7562. State personnel may order documents from NTIS by calling
(703) 487-4650.
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