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



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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

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•   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

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 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

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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.

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