tf S EPA REGION 5 LIBRARY
PHONE: (312)353-2022
FAX;
DaterJ__~_         	-United States
                                                                         PB93-963341
                           -Environmental Protection
                           -Agency
                                                Office of
                                                Solid Waste and
                                                Emergency Response
Directive 9345.1-16FS
.EPA540-F-93-038
September 1993
          ^Epft—Integrating  Removal  and
                            Remedial  Site  Assessment
                            Investigations
        Office of Emergency and Remedial Response
        Hazardous Site Evaluation Division (5204G)
                                                                    Quick Reference Fact Sheet
      Increased efficiency and shorter response times are the primary objectives of integrating removal and remedial site
      assessment investigations under the Superfund Accelerated Cleanup Model (SACM).   This  is based on the
      assumption that there is duplication of effort between the programs.  A critical element of SACM is a continuous
      and integrated approach  to assessing sites.  The concept of integrating removal and remedial  site assessment
      activities was introduced in Assessing Sites Under SACM—Interim Guidance (OSWER Publication 9203.1-051,
      Volume 1, Number 4, December 1992). This fact sheet examines areas of duplication and key differences between
      the two types of investigations, and describes some approaches for integrating assessments. The primary audience
      for this information is the site assessment community which includes EPA On-Scene Coordinators (OSCs) and Site
      Assessment Managers (SAMs), their counterparts in state or other federal agencies, and assessment contractors.
REMOVAL ASSESSMENTS AND
REMEDIAL SITE ASSESSMENTS

Figure 1 illustrates traditional assessment activities of
the removal and remedial programs prior to SACM.
Typically, when EPA is notified of a possible release
(under CERCLA Section 103), the removal program
determines whether there is  a need for  emergency
response  by   EPA.    If  a response is deemed
necessary,  an  OSC  and/or  a  removal program
contractor will visit the site. If circumstances allow,
a file and telephone investigation  should be initiated
prior to the site visit.  The OSC may decide to take
samples during this initial visit  or  may postpone
sampling.  EPA can initiate a removal action at any
point in  the  assessment  process.    If  the  OSC
determines that the site does not warrant a removal
action,  he may refer  the  site  to remedial site
assessment or the State for further  evaluation,  or
recommend no further federal response action.

The remedial site assessment process is similar to that
of the  removal program.  Once a site has  been
discovered and entered into the CERCLIS data base,
the SAM directs that a preliminary assessment  (PA)
be performed at the site.  The  focus of PA data
collection is the set of Hazard Ranking System (HRS)
                                                       factors that can be obtained without sampling (e.g.,
                                                       population within 1/4 mile). The PA includes a file
                                                       and telephone investigation, as well as a site visit (the
                                                       PA reconnaissance, or "recon").   The  PA recon
                                                       differs from  the typical removal site visit because
                                                       samples are not collected and observations are often
                                                       made from the perimeter of the site (although some
                                                       Regions prefer on-site PA  recons).  From the PA
                                                       information, the SAM determines if a site inspection
                                                       (SI)  is needed (i.e., whether the site could score
                                                       greater than the 28.5 needed to qualify for inclusion
                                                       on the National Priorities List (NPL)).  The SI would
                                                       include sufficient sampling  and other information to
                                                       allow the  SAM to determine  whether the score is
                                                       above  28.5.   Even in cases  where  SI data are
                                                       adequate for  this  decision, it  may  be  necessary to
                                                       conduct an expanded site inspection (ESI) to obtain
                                                       legally defensible documentation.

                                                       In general, the remedial site assessment  process is
                                                       more structured than the  removal assessment and
                                                       operates on a less intensive schedule.  The remedial
                                                       site assessment process  is focused on collecting data
                                                       for the HRS, while Removal  assessments are based
                                                       on whether site conditions meet National Contingency
                                                       Plan (NCP) criteria for  a removal action.

-------

-------
                  11
                   .
CO
CO
CD

O

O
E
(O
(0
CD
(O
CO
"J
 c
.o
°43

TO
 CO
 0)

 3
 O)
rr
O
O
rr
CL



I

LU
rr
111
s5!
s ° -
It
QC

O

O
IT
CL
Q
LU

2
LU
cc
               ~LJ

-------
    INTEGRATING ASSESSMENT ACTIVITIES

™"\ While there are differences in objectives  between
  ^removal  and  remedial  assessments  (i.e.,   NCP
    removal criteria versus HRS), many of the  same
    factors are important to both programs:  the potential
    for human  exposure through drinking water,  soils,
    and   air   pollution;   and  threats  to  sensitive
    environments such as wetlands.  Similarities  in the
    activities required by  both assessments—telephone
    and  file investigations, site  visits or PA recons,
    removal  or SI  sampling  visits—suggest that the
    activities can  be consolidated.  The challenge of
    integrating assessments is to organize the activities to
    enhance efficiency.

    The basic goals of an integrated assessment program
    under SACM are:

      •  Eliminate duplication of effort.
         Expedite the process.   At a minimum, avoid
         delays for time-critical removal actions or early
         actions (see Early Action and Long-Term Action
         Under SACM— Interim  Guidance, OSWER
         Publication 9203.1-051,  Volume 1, Number 2,
         December 1992, for details on early and long-
         term actions).
J
       •  Minimize  the number of site visits and  other
          steps in the process.

       •  Collect only the data needed to assess the site
          appropriately.

     The last point is critical to enhancing efficiency since
     not all sites need to be assessed in  depth  for both
     removal   and  remedial  purposes.     Integrating
     assessments does not mean simply adding together the
     elements of both assessments for all sites—efficient
     decision  points must  be  incorporated   into the
     integration process. The elements deemed necessary
     for an integrated assessment depend on the particular
     needs of a specific site and  could involve similar,
     additional,  or  slightly  different  activities  from
     traditional removal or remedial site assessments.

     Figure 2 shows an approach for integrating the two
     assessments  and   indicates   ways   to   eliminate
     unnecessary data collection.   The most important
     features   of the   approach  are   the  combined
     notification/site discovery/screening  function; the
     single site  visit  for both programs;  phased file
searches  as  appropriate;  and  integrated  sample
planning and inspection.  This approach is detailed
below.

Notification/Site Discovery/Screening

This "one door" notification process is a combination
of  the   current  removal  and  remedial  program
notification/discovery.  All remedial  and removal
program discovered sites  are  screened for possible
emergency response.   The  screening step  would
determine whether there is time for a file search prior
to the initial site visit.

(Classic) Emergency

If an emergency is identified, the response would be
implemented immediately.   Emergency  responses
require  immediate sampling and removal actions and
allow  little  or  no  time  for  file  or  telephone
investigations prior to site activity.

File Search

The integrated file search includes all elements of the
current  removal  assessment file search.   All file
search elements should be thoroughly documented to
serve the needs of both programs.  Table 1 lists data
elements that are commonly a part of the file search.
The timing of the file search relative to the initial site
visit   would   be   determined  during   the
notification/screening step.
                                                                     Table 1:  File Search and
                                                                      Telephone Investigation
                                                                   Elements Common to Both Programs
                                                                  Regulatory program file search (e.g., RCRA,
                                                                  water, state)
                                                                  Site access information and property
                                                                  ownership
                                                                  Site history, industrial processes
                                                                  Substances used at site
                                                                  Past releases (substances, locations, impacts)
                                                                  Latitude and longitude
                                                                  Topographic maps
                                                                    Generally Removal Assessment Only
                                                                  Potentially responsible party (PRP) search
                                                                  Treatment technology review

-------
                           o
                          I
                          I
                          t
 (A
 (0
 



0 ^
J JL
71 "5
s
,1 E
c
o
Q






























« t
« C
5 <
O E
LL
J








^








*




M
B:




09
A
~ *" 0.
lit


t
•D n
• c
a — c
»- a. n

r^i
Ii
"I
M
^k
It
'= >
u o
E tc.










f|
o
a























-------
  Initial Field Investigation/PA Recon
y^
     integrated site visit combines elements of both
  e removal assessment field visit and the remedial
PA recon.  Because removal and remedial program
site visit activities are similar, only a small increase
in effort would be required to meet the needs of both
programs.   Documentation needs of remedial  site
assessment might require  slight revision of removal
assessment procedures. For example, one might need
to document the distance to the nearest residence, in
addition to locating any  contaminated  residential
properties; for removal  assessment needs, one might
need to assess  the  extent of contamination.   The
assessment  team  will  need  to  gain site  access
approval for the site visit, in contrast widi current
remedial PA recons performed from the perimeter in
some Regions.   Table 2  lists  elements that are
commonly part of the screening site visit.

Sample (Optional)

Integrated  assessment  sampling  should follow the
current removal assessment approach, except  that
HRS data  needs should be considered in selecting
sample  locations  and  laboratory  analyses.    The
emphasis, however, is on removal assessment needs.

Review Data/Decide Further Action

Both removal and remedial programs would jointly
recommend   a  course  of  action,   taking   into
consideration  any previous removal  actions.  A site
might undergo either a continuation of the removal
assessment, a remedial  site assessment PA, or both
concurrently.   Alternatively, a time-critical removal
action could be performed prior to deciding whether
the site should undergo a PA.  Completing the PA
might be expedited in order to determine early in the
process   whether   remedial   site   assessment
requirements  should be included in  sampling plans.
When planning the  site inspection, the Region may
also want to consider the effect of a removal action
on the HRS score (see  The Revised Hazard Ranking
System:  Evaluating Sites After Waste  Removals,
OSWER Publication 9345.1-03FS, October 1991).

Complete the  PA
"v  Collect any information needed for the remedial site
 j assessment that was not part of the earlier file search,
-•' and calculate the preliminary HRS score.  For sites
   assigned  the SEA  (site  evaluation  accomplished)
                                                           Table 2:  Data Elements of the Site Visit
                                                                  Elements Common to Both Programs
                                                                 Current human exposure identification
                                                                 Sources identification, including locations,
                                                                 sizes, volumes
                                                                 Information on substances present
                                                                 Labels on drums and containers
                                                                 Containment evaluation
                                                                 Evidence of releases (e.g., stained soils)
                                                                 Locations of wells on site and in immediate
                                                                 vicinity
                                                                 Runoff channels or pathways
                                                                 Location of site or sources relative to surface
                                                                 waters
                                                                 Nearby wetlands identification
                                                                 Nearby land uses (e.g., residential, schools,
                                                                 parks, industrial)
                                                                 Distance measurements or estimates for wells,
                                                                 land uses (residences and schools), surface
                                                                 waters, and wetlands
                                                                 Public accessibility (e.g., site fence)
                                                                 Blowing soils and air contaminants
                                                                 Photodocumentation
                                                                 Site sketch
                                                                  Generally Removal Assessment Only
                                                                 Petroleum releases (eligible)
                                                                 Fire and explosion threat
                                                                 Urgency of need for response
                                                                 Response and treatment alternatives evaluation
                                                                 Greater emphasis on specific pathways (e.g.,
                                                                 direct contact)
                                                                 Sampling
                                                                Generally Remedial Site Assessment Only
                                                                 Perimeter survey (in some Regions)
                                                                 Number of people within 200 feet
                                                                 Some sensitive environments (e.g., endangered
                                                                 species habitats)
                                                                 Review all pathways
                                                           designation, also complete the PA report.  Depending
                                                           on circumstances and the Region's approach, the PA
                                                           report might be included as part of a comprehensive
                                                           PA/SI report for sites scoring above 28.5. Table 3
                                                           lists typical data elements of this activity.  If after the
                                                           PA it is evident that a site is likely to qualify for the
                                                           NPL, the site would be referred to  the  Regional
                                                           Decision  Team   (RDT).    (See  SACM  Regional
                                                           Decision   Teams—Interim    Guidance,    OSWER
                                                           Publication  9203.1-051,  Volume  1,  Number  5,

-------
                     Table 3:  Data Elements Needed to Complete the PA
      Population within 1 and 4 miles
      All private and municipal wells within 4 miles
      Depth to ground water (sometimes also collected for removal assessment)
      Local or regional geology and climate
      Distance to surface water measured (removal assessment only estimates distance)
      Fisheries along a 15-mile surface water migration pathway
      Sensitive environments along a 15-mile surface water migration pathway
      Size of wetlands
      Preliminary MRS score
December 1992, for details on the composition and
role of the RDT.)

Integrated Sampling Plan

This combines planning for  the current screening
level  SI  (see  section  2.1  of  the  Guidance for
Performing Site Inspections Under CERCLA, OSWER
Directive  9345.1-05,   1992)  and  any   removal
sampling activities not already addressed by the initial
visit.  When it appears that a remedial action will be
appropriate, and the site looks like a candidate for
NPL  listing, a Remedial Project  Manager (RPM)
should join the OSC and SAM in sample planning to
incorporate the objectives of any potential long-term
actions  at the site.  For applicable  sites, this will
enhance  the  efficiency  of   progressing   from
assessment to remediation,  or  starting a remedial
investigation prior to   NPL  proposal.   Likewise,
sample  planning should anticipate  the needs of any
possible engineering evaluation/cost analysis (EE/C A)
that might be needed for subsequent non-time-critical
removal actions.

Si/Removal Assessment Sampling

This is  a single sampling event designed to meet the
needs of both programs, where appropriate. Along
with the site visit and  the  file  search, integrating
sampling  would  improve  efficiency.    Table  4
describes  differences in emphasis  between removal
and remedial site assessment sampling approaches
which need to be considered when developing a joint
sampling plan.

RDT  Decisions

The RDT determines the course  of action needed to
address a site,  based  on the outcome of the site
assessment PA, Si/removal assessment, and any time-
critical  removal actions.  This can include proposing
to list the site on the NPL; conducting an  early
action; starting the remedial investigation (RI) early;
or combining the RI with the data collection needed
for listing.
One option open to the RDT is to start the RI as soon
as it is apparent that the site will qualify for the NPL
(e.g., after a PA), even if further documentation is
needed  for NPL rulemaking.  The needs of NPL
listing and the RI can  be integrated into a single
sampling plan to give  a  headstart to a  long-term
action.

Flexibility in Approach

Figure 2 addresses the  most likely approaches  for
screening site assessments; in fact, the approach will
vary according to the site and other factors.  Time-
critical  removal  actions  can occur  at  any time.
Enforcement,  community  relations,  and remedial
planning considerations can  be factored  into data
collection as needed at any point along the process.
OTHER CONSIDERATIONS

Methods of recording or documenting information
vary between programs.  Documentation is a major
consideration  for both  programs,  but the  MRS
requires a specific data set.  In order for a common
data element to  be  used by both programs,  HRS
documentation needs to be addressed.

Timing and duration of the activities  also need to be
considered by Regional personnel who are setting up
integrated  assessments.     One  critical  timing
consideration involves the step "complete the  PA."
At some sites this can proceed on a routine schedule,
but if a Region decides that sampling is needed to

-------
                   Table 4:  Site Inspection/Removal Assessment Sampling
                                    Remedial Site Assessment Emphasis
      Attribution to the site
      Background samples
      Ground water samples
      Grab samples from residential soils
      Surface water sediment samples
      HRS factors related to surface water sample locations (e.g., floodplains, watershed area)
      Fewer  samples  on average (10-30) than removal assessment
      Strategic sampling for HRS
      Contract Laboratory Program (CLP) usage (no separate funding for analytical services)
      Full screening organics and inorganics analyses
      Definitive analyses
      Documentation, including targets and receptors (e.g., maps, census data)
      Computing HRS scores
      Standardized reports
                                      Removal Assessment Emphasis
      Sampling from containers
      Physical characteristics of wastes
      Treatability and other engineering concerns
      On-site contaminated soils
      Composite and grid sampling
      Rapid turnaround on analytical services
      Field/screening analyses
      PRP-lead removal actions
      Goal of characterizing site (e.g., defining extent of contamination)
      Focus on NCP removal action criteria
determine  whether  to  undertake  a  time-critical
removal action,  the PA should be completed before
developing the integrated sampling plan.  Otherwise,
the remedial site assessment sampling needs may not
be appropriately factored into the sampling plan. By
collecting enough data to develop a preliminary HRS
score, the Region can determine whether the site may
be eligible for the NPL and whether it is worthwhile
to collect HRS-related samples.  The PA report can
be combined  with an  SI report  at  a  later  time,  if
appropriate.

An integrated sampling approach implies the need for
a  coherent  approach  to  sample  analysis.   Some
general principles should be followed to avoid major
problems.  Analytical data must be suitable for NPL
purposes.  Analytical services  should include the
appropriate reporting requirements to allow for data
validation at a later date, if necessary.  Table 5 lists
some data quality considerations for analytical data
used to support an HRS score.

The focus of this fact sheet is on the technical
integration of assessments at  sites where there is a
potential for  no action, early actions, or long-term
actions.  In some cases, the Region will rule out the
need for one of those, and the assessment process
under SACM will be similar to a traditional removal
or remedial site assessment.

Integration of assessments under SACM will reduce
duplication of effort at sites by addressing them with
a single assessment approach which incorporates the
objectives  of both  programs  as  applicable to each
site.   Integration  of assessments  is  an  efficient
blending  of  similar  procedures  which  may  be
appropriate at some sites and meets the objectives and
needs of both programs.

-------
            Table 5:  Analytical Data Quality Needs For MRS Observed Releases
      Sampling procedures, location, and conditions documented in field log.                                            j
      Chain of custody.                                                                                         ^
      Field blanks for each parameter for each day of sampling. The concentration of contaminants detected must be at
      least one order of magnitude below corresponding sample results.
      Initial 2-point calibration. Low level standard at or below concentration level of concern.  High concentration
      standard no more than 2 orders of magnitude above the low concentration standard.
      Continuing calibration using low level concentration standard after 10 to 15 sample analyses, or at the end of the
      day/sampling event, whichever occurs first.  (This step ensures consistent instrument response.)
      Blanks run after high level samples to avoid cross contamination.
 Specific examples of acceptable field methods:
   •  -X-ray fluorescence (XRF) for metals with site-specific standard matrix or with 10 percent lab confirmation by
      accepted EPA atomic absorption (AA) method.
   •  Field headspace or vadose zone VOC analysis with site specific standards, coupled with previous site information
      such as spill composition, 10 percent split for verification by an accepted EPA method, or successful field
      analysis of a PE or reference sample.
                                  Additional copies can be obtained from:
             Public                                                 EPA Employees
National Technical Information Service (NTIS)          or            Superfund Documents Center
U.S. Department of Commerce                                      U.S. Environmental Protection Agency
5285 Port Royal Road                                              401 M Street, SW (OS-245)
Springfield, VA  22161                                             Washington, DC  20460
(703) 487-4650                                                     (202) 260-9760 or (202) 260-2596 (FAX)
Order #:  PB93-963341                                                                                        \
United States
Environmental Protection Agency
5204G
Washington, DC 20460

$300 Penalty  for Private Use

-------