tf S EPA REGION 5 LIBRARY
PHONE: (312)353-2022
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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.
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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
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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,
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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
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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.
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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
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