United States
Environmental Protection
Agency
OH.ceof
Soi'3 Waste and
Emergency Hesoonse
DIRECTIVE NUMBER:9355.0-20
TITLE:RI/FS Improvements
APPROVAL DATE:7/22/87
EFFECTIVE DATE: 7/22/87
ORIGINATING OFFICE: OERR
C FINAL
Q DRAFT
STATUS:
REFERENCE (other documents):
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OSWE
DIRECTIVE DIREC
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OSWER Directive Initiation Request
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RJ/FS Improvements
Provides guidance for initiatives aimed at ijnproving performance on Sueprfund
RI/FS projects.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. O.C. 204CO
JU. 23887
MEMORANDUM
OF
SOLID WASTE AND EMERGENT P63?ONS€
OSWER Directive 9355.U-20
SUBJECT: RI/FS IMPROVEMENTS
FROM: Henry L. Longest II, Director
Office of Emergency and Remedial
TO: Directors, Waste Management Division
Regions I, IV, V, VI, VII, and VIII
Director, Emergency and Remedial Response Division
Region II
Directors, Hazardous waste Management Division
Regions III and X
Director, Toxic and waste Management Division
Region IX
Early in the Superfund program, EPA anticipated that an average RI/FS would
be completed in 18 months. Inefficiencies in the process have resulted in
significant project delays and, in some cases, unnecessary cost increases.
Currently, project planning activities take approximately 6 months to
complete and a full RI/TS runs an average of 25 months. EPA's goal,
through implementing the RI/FS improvement recommendations in the attach-
ment to this memo, is to improve the schedule and cost efficiency of the
RI/FS process while concurrently improving the technical quality of the
RI/FS work.
In a joint effort between Headquarters and the Regions, EPA has developed
several initiatives aimed at improving performance on Superfund RI/FS
projects. The attached RI/FS Improvement Analysis report discusses several
of these initiatives and proposes implementatiori~strategies for improving
project performance while concurrently streamlining the RI/FS schedule.
These initiatives are applicable to both Federal-lead and State-lead RI/FS
projects. The RI/FS Improvement Analysis report was developed by
evaluating previous analyses of the RI/FS process, compiling a detailed
critical path chart of the existing RI/FS process, and modeling various
implementation alternatives aimed at improving project efficiency and
technical quality. In addition to using data from completed fund-lead
projects, the analysis also relied on input from over 50 individuals in 7
Regions. TJie focus of the analysis was to develop a realistic strategy for
implementing a phased RI/FS that would facilitate meeting SARA objectives
without requiring major changes to the remedial program. The study focused
on the following areas for RI/FS improvement:
e Phased RI/FS Execution .._.,.
e Streamlined Project Planning
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OSWER Directive 9355.0-20
of Handoffs and Streamlined Critical Activities
• Quality Control and Technical Advisory Committee
The attachment to this memo presents definitions, recommendations,
implementation assistance, and results for each of the above areas for
program improvement. It also presents information on other guidance
documents, training, and future program initiatives.
OERR recommends that the suggestions contained in this report and the
attachment be used to expedite the RI/FS process and meet the Superfund
improvement objectives. These objectives are (1) to contain project plan-
ning activities within a 3-month period after project initiation, (2) to
ultimately reduce the overall RI/FS process to an 18-month schedule, (3) to
reduce overall costs, and (4) to improve technical quality of the RI/FSs.
These goals are ambitious; however, they are absolutely necessary in light
of the program expansion and schedules mandated by SARA. The success of
this RI/FS improvement initiative will depend largely on your ability to
integrate the guidance and recommendations made here into Regional
operations. Headquarters will continue to provide the Regions with policy
and technical support as well as program management tools to help
accomplish this goal. If you have any questions regarding these
initiatives, feel free to contact me or have your staff contact Don Whit*
or Nancy Willis of my staff at at FTS 475-9755 or FTS 382-2347,
respectively.
Attachment
cc: Environmental Services Division Directors (Regions I-X)
Air Division Directors (Regions I-X)
Water Division Directors (Regions I-X)
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OSWER Directive 9355.0-20
ATTACHMENT
"' ' RI/FS IMPROVEMENTS
PHASED RI/FS EXECUTION
Definition ,..-. , . .'
The RI/FS is evolving into a more interactive process which leads toward
phasing the HI and FS, as discussed in OSWER Directive 9355.0-19, Interim
Guidance on Superfund Selection of Remedy. In a phased RI/FS, the results
of each phase are evaluated and used to define the more focused scope of
subsequent phases, thereby minimizing extraneous activities. This leads
toward more efficient and effective data collection and evaluation efforts.
The format for each RI/TS must be developed on a site-specific basis, but
the following definitions can be used as a starting point for developing a
phased RI/FS:
• Site Characterization
• Development of Alternatives
• Initial Screening of Alternatives
• Field Investigation/Treatability studies
• Detailed Analysis of Alternatives
Proper planning is important to effective execution of a phased RI/FS.
This requires closely coordinating development of the RI with the FS to
assess data needs for alternative evaluation and treatability studies. The
development of data quality objectives for each phase is important to
ensure collection of adequate data of sufficient quality for each specified
data use. Also, data needs and associated costs should be commensurate
with the level of complexity of the site.
Recommendation
Phasing the RI/FS process, with incorporation of DQOs before the initiation
of each stage of data collection, should become a standard approach for
planning RI/FS projects.
Implementation Assistance
• Inttria Guidance on Superfund Selection of Remedy (OSWER Directive
9355.0-19) - gives explanation of phases irv the RI/FS process and
incorporation of SARA requirements
• Data Quality Objectives for Remedial Response Activities (OSWER
Directive 9355.0-7B) - explains procedures for development of data
quality objectives at different stages in the RI/TS process; focuses
on how to determine data quality needs based on data uses
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OSWER Directive 9355.0-20
• RI/FS Guidance (under revision) - detailed guidance on RI/TS
procedures in compliance with SARA requirements
• Headquarters OERR staff - Headquarters assistance will be available
to Regions in planning and implementing new procedures
• RI/FS Standardized Tasks (OSWER Directive No. 9242.3-7) -
establishes standatd tasks that will expedite project planning
activities
Results
Implementation of a phased RI/FS approach should yield the following
results:
• Interim activities such as the initial site visit and limited field
sampling will help define the work plan and site conceptual model
more clearly from the beginning of the process.
• Earlier initiation of field activities (reduced project planning
phase) because project planning activities can focus on initial
phases of the RI/FS; subsequent phases only need to be discussed in.
general terms in the initial work plan.
• More effective use of resources on the job through using DQOs to
guide data collection activities and working from a very focused
scope at each phase of the work.
e Elimination of infeasible remedial alternatives earlier in the RI/FS
process through evaluation of results from early data collection
phase.
• Assist in reducing overall RI/FS schedule and overall project costs.
• Conduct of treatability studies during the RI/FS.
STREAMLINED PROJECT FLAWING
Definition
Project planning encompasses the period from work assignment initiation
through approval of the work plan. For past RI/FS projects, these
activitietvhave taken 19 to 18 months (with an average of 6 months) and a
full third of the project budget to complete. Efforts to streamline the
project rftT**H"? process are focused on completing these activities within
3 months after work assignment initiation.
An integral part of this planning c/rocess is development of data quality
objectives (DQOs) for each phase of data collection activity. OQOs are
qualitative and quantitative statements wh^ch specify the quality of the
data required for specific uses. DQOs are established^during project
scoping and at the initiation of any subsequent data collection activities
to ensure that data are of sufficient quality for their intended use.
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OSWER Directive'9355.0-20
Recommendation
Recommendation* for streamlining the project planning process are as
follows:
• Consolidate SiA plans and QAPPs - As stand-alone documents, these
plans often are redundant and therefore require duplication of
contractors' efforts.
• Incorporate standard procedures by reference - This will avoid
repeating technical reviews of a procedure that has already been
approved.for use in the Region.
• Limit intra-Agency reviews to contractual requirements - Rely on
contractors' internal quality control/review procedures and RPM
review for most project documents and limit intra-Agency reviews to
the work plan, community relations plan, and SiA plan.
• Initiate preliminary site work upon interim authorization -
Authorization for initiation of Phase I field activities can be
granted upon approval of the Phase I S&A plan, possibly before
approval of the complete work plan.
• Make work plans specific for initial phases of work, general for
later phases - This will expedite development and review of the work
plan; subsequent changes in the technical direction of the work can
be documented through the use of a Technical Direction Memorandum
(TDM), as long as the work is within the original scope and budget
of the assignment.
• Incorporate Technical Advisory Committee (TAG) review into project
planning phase - A TAG is a group of senior level EPA/State and
contractor personnel selected to serve as technical reviewers for a
project, based on their areas of expertise (e.g., hydrogeologist for
a ground water site, etc.). Review of key deliverable* in the draft
stage by senior level personnel can improve the quality of the
documents and expedite EPA intra-Agency review*. The RPM is
expected to be involved in review of interim deliverables. Early
TAG review will also facilitate better management of RI/FS projects
through early identification of technical and policy issues.
• Use •tandardised tasks - The Agency has developed a standard task
structure which can be used for all RI/FS studies. This task
structure will standardize cost and schedule tracking and allow
development of a data base that will be used to better estimate
resource- requirements for new remedial projects.
Implementation Assistance
e Compendium of Field Operations Methods (OSWER Directive 9355.0-14,
planned August 1987) -provides consolidated reference of available
field procedures
}.'.:e".:;Revised work,assignment procedures, including guidance op vising TDMs
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OSWER Directive 93S5.0-20
* RI/FS Standardized Tasks (OSWER Directive No. 9242'.3-7) - provides
standard tasks to expedite project planning
• Data Quality Objectives for Remedial Response Activities (OSWER
Directive 9355.0-7B) - explains procedures for development of data
quality objectives at different stages in the RI/FS process
Results
The results of implementing the above recommendations should be as follows:
• Earlier initiation of field activities helps define conceptual
models more accurately and helps refine the scope of subsequent
field activities
• Shortened review times
• Overall reduction of project planning time and costs through
elimination of duplicative efforts
• Improved quality of deliverables
MANAGEMENT OF HANDOFTS AND STREAMLINED CRITICAL ACTIVITIES
Definition
A handoff is any transfer of responsibility for administrative or technical
project activities. Examples include turning samples into CLP for
analysis, turning data over to ESD for validation, or turning documents
into EPA for intra-Agency review. Project handoffs have been identified as
a major cause for delays in the RI/FS process. Critical activities include
any RI/FS activities that lie on the critical path of the project. A delay
in the execution of a critical activity will result in a delay in the RI/FS
completion. In the RI/FS analysis, many key deliverables and handoff s were
found to be critical activities. SARA requires increased State
participation in the RI/FS process. This entails reviews that may be
critical activities and will therefore have to be managed carefully to
avoid creating project delays.
Recommendation
Since handbffs have been identified as a key source of project delays, they
should be kept to a •inieiei and, when possible, should be planned so that
they do not all on the critical path for the RI/FS. Also, critical
activities] can be ainiaized by scheduling concurrent activities, by
receiving interim approvals, and by phasing critical field tasks. Specific
recommendations include the followinj:
e Turn data over to contractor for pre-analysis prior to data
validation, thereby avoiding delays in data evaluation. However,
invalidated data should not be released to other organizations,
Agencies, or individuals.
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OSWER Directive 9355.0-20
• Allow contractors to validate CLP data according to EPA standard
procedures, with Regional audits, if this will expedite the project
schedule.
• Keep intra-Agency document reviews to only those that are
contractually required (The RPM will be responsible for review of
other deliverables).
• When a responsibility transfer is necessary, obtain a commitment
from the receiving party to meet schedule requirements.
• Involve key decision makers in the TAG meetings to reduce review
time of RI/FS deliverables.
• Initiate treatability and/or pilot testing during the RI (after
initial alternatives evaluation) to assist in remedial alternative
selection and expedite predesign, and to keep this activity off the
critical path.
• Use results from the analysis of screening samples to develop a
conceptual model for the site and to perform preliminary technology
and alternative screening.
• Provide interim approvals for initial field activities prior to full
work plan approvals to expedite data collection and analysis.
Implementation Assistance
• RI/FS Improvement Analysis - discusses handoff analysis (Section
2.2) and provides an example of how a project can be structured to
effectively manage handoffs and keep them off the critical path
(Appendix C).
• RI/FS guidance (under revision) - discusses project requirements.
• Guidance on Preparation of Superfund Memorandum of Agceement -
establishes voluntary procedures to assist EPA and the States in
working together to maintain projects on schedule. The SMQA will be
highlighted in the NCP preamble, Subpart P. (Draft, July 1987)
Headquarters staff - available to advise on streamlining project
activities.
Results
Impleavntatien of tht recosnendations above should result in the following:
• Streamlined review of RI/PS deliverables
• Better control over project schedule
• Assist in meeting shorter overall project schedule and costs
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OSWER Directive 9355.0-20
QUALITY CONTROL AND TECHNICAL ADVISORY COMMITTEE
Definition
EPA wants to ensure that the RI/FS process is conducted in a manner that
yields high-quality products and is comparable and consistent among the
Regions. This can be accomplished through implementation of Region-
specific technical quality control processes and involvement of a Technical
Advisory Committee (TAG) at key project milestones. The TAG will consider
such things as major technical or policy issues and if the scope and costs
are commensurate with the level of complexity of the site.
Recommendation
• Identify and draw upon technical experts and/or other agencies
(e.g., Bureau of Mines for a mining site) or within EPA for an early
brainstorming session to review the overall scope of the project and
identify technical or policy issues. The expertise required would
depend on the nature and complexity of the project. Information
from this session would then be made available to the TAG for
consideration in their review of project deliverables.
• Identify and convene a TAC at project milestones; e.g., draft work
plan, preliminary summary of site investigation (first phase RI),
second phase RI, initiation of FS phase, and predesign.
• Develop a Regional RI/FS control process to be implemented for all
remedial projects in your Region.
• Clearly identify reviews and signoffs required for deliverables in
the Region.
Implementation Assistance
• RI/FS Improvements Analysis - presents a discussion of Regional
quality control in Section 4.0.
• RI/FS and ROD guidance (under development) - for a discussion of
project requirements.
• Data Quality Objectives for Remedial Response Activities (OSWER
Directive 9355.0-7B) - explains procedures for development of data
quality objectives at different stages in the RI/FS process.
LUM of Field Operations Methods (OSWER Directive 9355.0-14,
plannsd August 1987) - provides consolidated reference of available
field procedures.
• Regional and Headquarters OA staff are available to advise RPMs
regarding OA and QC issues.
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OSWER Directive 9355.0-20
Results
The above recommendations should yield the following results:
• Standardized Regional quality control review procedures
• Improved consistent quality of RI/FS deliverables
• Strong technical work plans, which will improve project efficiency
• Assist in reducing overall project schedule and cost
OTHER GUIDANCE DOCUMENTS
Additional guidance is available to RPMs, State, and contractor staff to
assist in improving project performance. These documents do not present
specific time-saving mechanisms but their use should improve the flow of
project management activities and minimize schedule slippages.
Superfund Federal-LeacVRemedial Project Management Handbook (OSWER
Directive No. 9255.1-1) and Superfund State-Lead Remedial Project
Management Handbook (OSWER Directive 9355.2-1)
EPA has prepared two handbooks to provide guidance on remedial project
management, one for Federal-lead projects and one for State-lead project*.
Both of these handbooks, which will be updated periodically to incorporate
program changes, are expected to become key reference documents for both
experienced and new RPMS. The objective of these documents is to promote a
proactive management style of preventing problems through better project
planning, thereby avoiding adversely affecting project costs, schedule, or
technical quality.
The revised work assignment procedures, included as an appendix to the
Federal-lead handbook, rely greatly on a new work assignment form that
replaces a series of forms used previously. The new procedures also allow
modifications to the technical work to be approved at the Regional level
using Technical Direction Memorandum (TDM). This procedure avoids the need
for work assignment amendments if the changes are within the overall scope
and budget of the assignment.
Community Relations in Super fund; A Handbook (OSWER Directive 9230.3A)
Under the requirements of SARA, community relations for remedial response
activitiM will be a more visible part of the remedial program. It is
imperative that community relations activities be effectively integrated
with the technical work being conducted at Superfund sites. The interim
version of Community Relations in Superfund; A Handbook was issued by EPA
in March 19B&TThe handbook is currently undergoing revision to
incorporate the new public participation provisions required under SARA.
Upon final approval of.the NCP, the handbook again will be revised to
reflect the new regulations. Currently, the handbook is used by a wide
range of individuals, including EPA, State, and local technical and
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OSWER Directive 9355.0-20
community relations staff. Along with required coimunity relations
activities, the handbook suggests activities to consider in the development
of a site-specific community relations program.
TRAINING
EPA has a number of training courses available that are tailored toward
remedial program management needs and the Superfund program. Among these
are the following:
e CERCLA Orientation Course
e RPM/OSC Training Course
e Construction Management Course
e Project Officer Course
e Contract Administration Course
In addition to the above courses, RI/FS and ROD workshops are held
annually. EPA encourages Regional staff to take advantage of these
training opportunities. If your Region needs specialty training in
specific technical areas, contact Joe Bahnick at FTS 475-8600.
FUTURE PROGRAM INITIATIVES
The guidance and recommendations described above provide project managers
with readily available information for immediate use in improving
performance on RI/FS projects. Additional program initiatives are under
way which will assist in further reducing project schedules to the 18-month
goal. EPA is delegating increasing authority over remedial assignments to
the Regions. Among these efforts are revised award fee procedures and the
alternate remedial contracts strategy (ARCS). .OERR also has initiatives
under way to develop a nationwide treatability/pilot study subcontracting
support system and to develop additional technical standard procedures, we
will be monitoring the effectiveness of these initiatives during Regional
reviews.
Revised award fee procedures are discussed in OSWER Directive No.
9242.3-07,:Implementation of the Decentralized Contractor Performance
Evaluation and Mqrd Fee Process for Selected Remedial Program Contracts.
This initiative gives the Regions more control over evaluation of
contractor performance and will be an integral part of ARCS implementation.
TWs initiative was developed in part based on the responses to the
questionnaire sent out as part of the RI/TS Improvements Analysis (Appendix
B). We will evaluate the effectiveness of the new procedures over the next
award fee period and will revise them as appropriate.
In addition, an initiative is under way to evaluate various strategies for
streamlining the subcontracting process. Among the alternatives being
examined are initiating subcontracting procedures early in the project
planning phase and expediting signoffs on individual subcontracts.
8
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OSWER Directive 9355.0-20
Expert sy»te»» are also being examined for potential applications
throughout the remedial program. A demonstration prototype has been
developed to determine tasks, resources, and costs for an RI/FS for
landfill sites. Additional modules are expected to be produced and will be
available to the Regions by the end of the fiscal year. Another expert
system is now available to estimate remedial construction costs for ongoing
remedial assignments. This system was developed to assist with out-year
budget projections only.
To facilitate transfers of information about methods for measuring and
screening chemicals in the field and for quick-turnaround analyses, EPA is
developing a Catalog of Field Screening Methods. The catalog will be
provided to users as both a pocket guide and on disk in a dBase III system.
Currently, the catalog includes about 30 field sampling or screening
methods, including several gas chromatography methods, two x-ray
fluorescence methods, ultraviolet fluorescence, fiber optic sensors,
innunoassay, mass spectroscopy, and atomic absorption. For more
information, contact Carla Oempsey of the Analytical Operations Branch at
FTS 382-7906.
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