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.
------- |