United States Environmental Protection Agency Office of Solid Waste and Emergency Response Directive No.: 9355.3-01FS4 March 1990 The Feasibility Study: Detailed Analysis of Remedial Action Alternatives Office of Emergency and Remedial Response Hazardous Site Control Division OS-220 Quick Reference Fact Sheet This is the fourth and final in a series of fact sheets describing the remedial in- vestigation/feasibility study (RI/FS) process. This fact sheet is a synopsis of Chapter 6 of the Guidance for Conduct- ing Remedial Investigations and Feasi- bility Studies Under CERCLA (October 1988. OSWER Directive No. 9355.3-01), which addresses the detailed analysis of remedial action alternatives. Addi- tionally, this fact sheet provides Reme- dial Project Managers (RPMs) with infor- mation on how to manage this phase of the FS efficiently and effectively. The purpose of the detailed analysis of alternatives is to provide declsionmakers with adequate information to permit se- lection of an appropriate remedy for a site or operable unit. The detailed analy- sis of remedial action alternatives fol- lows the development and screening process, which is described In detail in Chapter 4 of the RI/FS Outdance and summarized in the third FS fact sheet (OSWER Directive No. 9355.3-01FS3). The development, screening, and de- tailed analysis of alternatives may over- lap, with one phase beginning before another is completed. Also, the activities may vary in level of detail based on the complexity or scope of the problem at a site. The extent to which alternatives are analyzed during the detailed analysis is influenced by the available data, the number and types of alternatives being ^^" ^"^-^^^ f Results of Trealabilily \. ( Investigations and \^_^^^. V Additional Site ./ N. Characterization j/ ARARs Identification Completed - Otevelopment/ *s. Screening of ) Alternatives ^^^' I Further Definition of Alternatives, as Necessary Individual Analysis of Alternatives Against Nine Evaluation to| \ Comparative Analysis of Alternatives Using Evaluation Criteria to Identify Tradeoffs \ Issuance of Feasibility Study Report evaluated, and the degree to which al- ternatives were analyzed during their development and screening. The results of the detailed analysis provide the basis for identifying a preferred alternative and preparing the proposed plan. Upon completion of the detailed analysis, the FS report, along with the proposed plan (and the RI report if not already released) Is issued for public review and com- ment. The results of the detailed analy- sis support the final selection of a rem- edy and provide the foundation for the Record of Decision (ROD). The major components of the detailed analysis process are presented In Figure 1. The detailed analysis, like other phases of the RI/FS process, should be tailored to the scope and complexity of the site or operable unit. The level of detail can be expected to vary from site to site, al- though all major components discussed here and in the RI/FS guidance must always be addressed. Detailed Analysis Activities Alternative Definition The alternatives progressing from the development and screening phase of the FS may need to be better defined in order to adequately evaluate them during the detailed analysis. If available, addi- tional site characterization and treata- bility study data should be utilized at this time. These data may not have been available during the development and screening of remedial action alterna- tives due to the interactive nature of the RI and FS. Necessary refinements to the remedial alternatives may Include: Figure 1. Major Components of the Detailed Analysis Process er ------- Modification of contaminated media volume estimates Revision of sizing requirements of process options Selection of a more suitable "repre- sentative" process option Addition of other possible unit proc- ess options to be considered. Individual Analysis of Alternatives Once the remedial action alternatives are sufficiently defined to allow for fur- ther evaluation, each alternative Is as- sessed against nine evaluation criteria. These criteria have been designed to enable the analysis of each alternative to address the statutory requirements and considerations, and the technical and policy considerations Important for se- lecting among remedial alternatives. These evaluation criteria, listed in Fig- ure 2, provide the framework for con- ducting the detailed analysis and for subsequently selecting an appropriate remedial action. Also Included within this figure are the specific factors to be considered under each of the criteria. The individual analysis of alternatives should profile the performance of each alternative against the evaluation crite- ria, highlighting the specific strengths and weaknesses of a particular alterna- tive relative to each evaluation criterion. The evaluation criteria have been di- vided into three groups based on the function of the criteria in remedy selec- tion. The threshold criteria relate to statutory requirements that each alter- native must satisfy In order to be eligible for selection and include: Overall protection of human health and the environment Compliance with Applicableor Rele- vant and Appropriate Requirements (ARARs). The primary balancing criteria are the technical criteria upon which the de- THRESHOLD CRITERIA Ovcri Hnlt II Protection ol Human n and tne Environment Compliance with AHAR. How Alternative Provides Protection of Human Chemical-Specific Health and Environment Action-Specific Location-Specific BALANCING CRITERIA . Long-totm Effecuvwm* and Permanence Magnitude of Residual Risk Adequacy and Reliability of Controls 1 The assessments of tl proposed plan is rece Reduction ol ToxicHy, Mobility, or volume Through Treatment Short-term Effectiveness Implement* bilHy Coat Treatment Process Protection of Ability to Construct Capital Used and Materials Community During and Operate Treated Remediation Technology Operating and Maintenance Volume of Materl- Protection of Reliability ol ata Destroyed or Workers During Technology ' Present "o"" Treated Remediation Ease of Undertak- Degree of Ex- Environmental ing Additional RAs. peeled Reductions Impacts It Necessary Degree to Which Time Until RA Ability to Monitor Treatment Is Objectives Are Effectiveness of Irreversible Achieved Remedy * Type and Quantity > Ability to Coordt- ol Residuals nate and Obtain Remaining Approvals from Other Agencies Availability of Services and Materials MODIFYING CRITERIA Acceptance ' ' Community Acceptance lese criteria are generally not completed until after public comment on the RI/FS report and the ved. tailed analysis is primarily based and include: Long-term effectiveness and perma nence Reduction of toxiclty, mobility, or volume through treatment Short-term effectiveness Implementability Cost. The third group is made up of the modify- ing criteria and Includes: State/Support agency acceptance Community acceptance. These last two criteria are assessed for mally after the public comment period, al though to the extent they are known, they are factored into the identification of the preferred alternative. Based on this for mal consideration, the lead agency may modify aspects of the preferred alterna- tive or decide that another alternative is more appropriate. The RPM should try to develop and maintain a thorough under- standing of State and community con- cerns throughout the RI/FS process. This understanding is essential to prevent issues from arising that could fundamen tally change the alternatives being con- sidered after completion ofthe RI/FS and proposed plan. Note: Risks associated with alterna- tives are considered during the de- tailed analysis. The evaluation of the long-term effectiveness and per- manence afforded by alternatives assesses the effectiveness an alter- native will have in eliminating expo- sure pathways or reducing levels of exposure identified in the baseline risk assessment. During the evalu- ation of short-term effectiveness, exposures associated with implem- entation of alternatives, such as short-term health effects from re- lease of volatiles during excavation of soils are addressed. This may re- quire assistance from the risk asses- sor. Figure 2. Criteria for Detailed Analysis of Alternatives The level of detail In which each alterna- tive is analyzed relative to the evaluation criteria will depend upon the type and complexity ofthe site, the types of tech- nologies and alternatives being consid- ered, the level of information available on the alternatives, and other project -spe- cific considerations. The analysis should ------- be conducted in sufficient detail to en- able decisionmakers to understand the significant and/or controversial aspects of each alternative and any uncertain- ties associated with the anticipated per- formance or evaluation of the remedies. Note: All alternatives may not need to be evaluated with respect to all of the subcriterla presented in Fig- ure 2. The key is to identify the subcriteria by which the alterna- tives vary significantly and to focus the evaluation on those factors. Comparative Analysis Once the alternatives have been fully described and individually assessed against the nine criteria, a comparative analysis should be conducted to evalu- ate the relative performance of the alter- natives In relation to each specific evalu- ation criterion. The purpose of the com- parative analysis Is to identify the ad- vantages and disadvantages of each al- ternative relative to one another so the tradeoffs that will have to be balanced to select a remedy are fully understood. The comparative analysis generally will focus on the differences between alter- natives with respect to the primary bal- ancing criteria since these factors play the major role In determining which options are cost-effective and which remedy utilizes permanent solutions and treatment to the maximum extent prac- ticable. Next Steps The detailed analysis develops informa- tion used in selecting an appropriate remedy based on statutory requirements under CERCLA, as amended by SARA. As Illustrated In Figure 3, the nine crite- ria have been developed to organize the evaluation which supports the determi- nation that these statutory requirements are met. Further information on remedy selection will be provided in a subse- quent fact sheet. Detailed Analysis Deliverables Table 6-5 of the RI/FS Guidance pre- sents a suggested format for the final FS report. The major elements to be In- cluded in the FS report are: Description of alternatives and Indi- vidual analysis (narrative and table) Comparative analysis of the alterna- tives with respect to each evaluation criterion (narrative) Documentation of ARARs. Individual Analysis Presentation The presentation of the Individual analy- sis In the FS should Include a narrative description of each alternative and a dis- cussion of the evaluation of each alter- native against the nine criteria. The narrative descriptions of alternatives should Include: Technology components (identifying any innovative technologies) Quantities of materials handled Scale of process options Time required forimplementatlon Implementation requirements Major ARARs Assumptions, uncertainties, and limitations. The discussion of the evaluation of alter- natives should focus on how, and to what extent, each alternative performs in terms of the key factors under each criterion. This includes an analysis of the possible effect of any change in as- sumptions on the alternative. The analy- sis should Include a summary table highlighting the assessment of each al- ternative with respect to each of the nine criteria to assist the public and decision- makers In understanding the options. A sample presentation of an Individual analysis Is provided In Appendix F of the RI/FS Guidance. Comparative Analysis Presentation The presentation of the comparative analysis in the FS should describe the strengths and weaknesses of the alter- natives relative to one another with re- spect to each criterion. An effective way to organize this section is to discuss for each Individual criterion the altemative(s) that performs best overall under that criterion, with other alternatives then discussed In the order of their perform- ance. Significant subcriteria should be highlighted and the possible effect of a change in assumptions should be noted. The differences among alternatives may be measured either qualitatively or quan- titatively, as appropriate. Quantitative information used to assess the alterna- tives, such as cost estimates and the time until response objectives would be achieved, should be included in the presentation of the analysis. A sample NINE CRITERIA PROTECTION OF HH&E STATUTORY FINDINGS PROTECTION OF HH&E COMPLIANCE WITH ARARs LONG-TERM EFFECTIVENESS AND PERMANENCE TOXICITY, MOBILFTY, OR VOLUME REDUCTION THROUGH TREATMENT SHORT-TERM EFFECTIVENESS IMPLEMENTABILITY COST STATE/SUPPORT AGENCY ACCEPTANCE COMMUNITY ACCEPTANCE COMPLIANCE WITH ARARs OR JUSTIFICATION OF A WAIVER COST-EFFECTIVENESS UTILIZATION OF PERMANENT SOLUTIONS AND TREATMENT OR RECOVERY TO THE MAXIMUM EXTENT PRACTICABLE ("MEP") PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT OR EXPLANATION AS TO WHY PREFERENCE NOT SATISFIED Figure 3. The Relationship of the Nine Criteria to the Statutory Findings ------- presentation of a comparative analysis Is given in Appendix F of the RI/FS Guid- ance. Note: If innovative technologies re being considered, their poten- tial advantages in cost or perform- ance and the degree of uncertainty associated with these advantages (as compared with the conventional technologies being considered) should be discussed. ARAR Documentation Major ARARs associated with alterna- tives that undergo detailed analysis should be Integrated into the description of alternatives in the Detailed Analysis chapter of the FS. In addition, the FS should Include In an appendix a table that summarizes all Federal and State requirements determined to be ARARs for those alternatives. The table should cite the ARAR indicate which alterna- tives meet the ARAR, and identify any waiver and its Justification. The specific requirement should be stated In addi- tion to (not instead of) the appropriate regulatory reference, (for example, CWA MCL of 5 ppb TCE). Appendix E of the RI/FS Guidance presents a suggested format for documenting the identified ARARs. Note: Other available information that is not an ARAR (e.g.. adviso- ries, criteria, and guidance) may be considered in the analysis if It helps to evaluate the alternatives' effec- tiveness or protectlveness and if the lead and support agencies agree that its inclusion is appropriate. This "to be considered" (TBC) infor- mation is utilized in the detailed analysis along with ARARs. RPM Responsibilities Ensuring that adequate technical su- pervision is being provided during the detailed analysts as well as oversight of the RI/FS schedule and budget are, the responsibilities of the RPM. Communi- cation with appropriate technical ex- perts and, In particular, the contractor during this phase of the FS will help the RPM fulfill these responsibilities. Technical Support The detailed analysis is a technical evalu- ation and should not contain conclusions about remedy selection. Sources of tech- nical support include the Technical Advi- sory Committee (TAC); ORD's Risk Re- duction Engineering Laboratory and Technical Support Project; and the Alter- native Treatment Technology Informa- tion Center (ATTIC), an automated infor- mation system (contact Miles Morse at FTS-475-7161). See the Scoping Fact Sheet [OSWER Directive No. 9355.3- 01FS1 ] for further information on appro- priate technical experts to utilize during this phase. Schedule and Cost Control To complete this phase of the FS in a cost- effective and timely manner, the RPM should ensure that the key participants have been involved in all the previous phases of the FS. These participants in- clude personnel from the lead and sup- port agencies, contractor personnel, members of the TAC, PRPs, and commu- nity representatives, as appropriate. Other schedule and cost control techniques include: Briefing lead and support agency de- cislonmakers prior to the detailed analysis to obtain firm agreement on which alternatives will be evaluated in detail. Holding frequent (e.g., monthly) prog- ress meetings or conference calls with contractors to review progress and to set schedules for completing upcom- ing tasks. Reviewing monthly financial state- ments from consultants and making sure that all costs are justifiable. Anticipating cost and schedule prob- lems based on the previous month's activities, and taking actions to avoid or minimize unnecessary cost in- creases and schedule delays. Enforcement Considerations In an RI/FS project conducted by PRPs, all aspects of the detailed analysis of alternatives are typically performed by the PRPs. The RPM should meet with the PRP representatives before they initiate the detailed analysis to ensure agree- ment on alternatives, including process options, that will be evaluated. EPA should oversee all aspects of the detailed analysis. In addition, ARARs identified by the PRPs should be reviewed and ap- proved by both the lead and support agencies. Additional information on PRP participation in the RI/FS and EPA's oversight role can be found in Appendix A of the RI/FS Guidance and in OWPE's Model Statement of Work Jor PRP Con ducted Remedial Investigations and Fea- sibility Studies (June 2, 1989). Points to Remember Limit the evaluation to vi- able, distinctive alternative*. Focus the evaluation on the strengths and weaknesses of each alternative relative to the others with respect to each criterion. Include sufficient detail to enable decisionmakers to understand distinctive fea- tures of each alternative. Continue seeking to identify major public concerns dur- ing the FS. and if possible. prior to issuance of the pro- posed plan. Ensure lead and support agencies discuss and agree upon ARARs and TBCs. Use sources of information consistently throughout the FS, such as vendors, contrac- tor process/design engineers, and members of the TAC. Use tables and figures effec- tively in the presentation of the detailed analysis. They will be helpful when prepar- ing briefings, the proposed plan, and the ROD. Present alternatives analysis in a level of detail that makes the differences clear, but is not as detailed as design specifications. ------- |