United States
Environmental Protection
Agency .
Solid Waste And
Emergency Response
(OS-220)
Directive 9355.3-01 FS3
November 1989
The Feasibility Study
Development And Screening
Of Remedial Action Alternatives
This fact sheet is the third in a series of
four that summarizes the remedial in-
vestigation/feasibility study (RI/FS)
process. The previous two fact sheets in
this series discuss scoping the RI/FS
(OSWER Directive No. 9355.3-01FS1)
and site characterization and treatabil-
ity studies (OSWERDirective No. 9355.3-
01FS2). This fact sheet provides a sum-
mary of Chapter 4 of the Guidance Jar
Conducting Remedial Investigations and
Feasibility Studies Under CERCLA (Oc-
tober 1988. OSWER Directive 9355.3-
01). which discusses the development
and screening of alternatives for reme-
dial action. In addition, this fact sheet
provides information intended to assist
the Remedial Project Manager (RPM) in
managing this portion of the feasibility
study (FS) efficiently and effectively.
The FS process consists of the develop-
ment and screening of remedial action
alternatives and a detailed analysis of a
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ar* typically continued throughout
tha Alternative Development and
Screening process
The need for additional date may
be determined at any time and/or •
number of times throughout the
process
limited number of the most promising
options to establish the basis for a rem-
edy selection decision.
A range of viable alternatives should be
developed that meet the remedial re-
sponse objectives developed during scop-
ing and refined as the study progresses.
This range should reflect the program
expectations to address the principal
threats posed by the site (i.e.. liquids and
highly toxic and/or highly mobile waste)
through treatment, and consider engi-
neering controls (e.g.. containment) to
address low-level contaminated materi-
als and wastes for which treatment is
impracticable. Institutional controls
should be considered primarily as sup-
plements to engineering controls.
In addition to the program expectations,
RPMs should consider the types of re-
sponse actions selected for other sites
with similar problems or contaminants
to identify only those remedial alterna-
tives that carry high potential of being
an effective solution for site problems.
As appropriate, the range of source
control alternatives should include op-
tions employing treatment as a principal
element, one or more containment alter-
natives, and the no-action alternative.
The major components that comprise
the development and screening process
are presented in Figure 1.
Note: The no-action alternative i»
used as a baseline to compare other
alternative*. Measure*, such as
actions taken to reduce the poten-
tial for exposure (e.g., site fencing)
should not be included as compo-
nents of no~action alternatives.
Such mi«*trffl actions should be
studied as « separate, limited-ac-
tion alternative. Environmental
monitoring may be included as part
of • no-action alternative.
Figure 1. Alternative Development and Screening Process
1
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Development and
Screening Activities
Establish Remedial Action
Objectives
The preliminary remedial action objec-
tives identified during scoping are re-
fined as necessary during this phase of
the RI/FS to develop medium-specific
goals for protecting human health and
the environment Remedial action ob-
jectives specify:
• The contaminant(s) and media of
concern
• The exposure route(s) and receptors)
• The remediation goal(s) for each
exposure route
An example of a remedial action objec-
•tive is reducing concentrations of TCE
in potable ground water to 5 ppb.
The contaminants, media of concern.
and exposure routes are the most im-
portant preliminary sources of Informa-
tion necessary for the development of al-
ternatives. That is. the identification of
appropriate remedial technologies can
be initiated without identifying the final
remediation goal or the exact cleanup
requirement. These requirements will
need to be identified prior to the detailed
analysis of alternatives.
During the development of alternatives.
preliminary remediation goals are es-
tablished based on readily available in-
formation such as applicable or relevant
and appropriate requirements (ARAHs).
Whereas, final remediation goals take
into consideration the results of site
characterization and the baseline risk
assessment The baseline risk assess-
ment defines the risks posed by a site
and establishes the need (or lack thereof)
for remedial action.
Note:Identificationoflocation-and
chemical-specific ARARs. begun
during scoping, should be com-
pleted during alternatives devel-
opment. Example* of Mich require-
ments Include;
• ^•^Hnm^n contaminant levels
(MCLs)
• Water quality criteria
• State-action levels for drinking
water
•State air emission standards
Develop General Response
Actions
General response actions are selected to
satisfy the remedial action objectives for
each medium of concern. These actions.
initially defined during scoping, are re-
fined during this phase and relate to
basic methods of protection such as
treatment or containment. General re-
sponse actions may be combined to
form alternatives such as treatment of
highly toxic material with containment
of the treatment residuals.
The volume or area to which general
response actions might be applied should
be identified at this time and based on:
the exposure routes, the known nature
and extent of contamination, and pre-
liminary remediation goals and a pre-
liminary list of action-specific ARARs.
Action-specific ARARs set restrictions
on particular remedial activities as re-
lated to the management of hazardous
wastes.
Identify and Screen Appropriate
Technologies
Throughout the RI/FS Guidance and
this fact sheet the term "technology"
refers to general categories of technolo-
gies, such as chemical treatment or
capping. The term 'technology process
option* refers to specific alternative proc-
esses within each technology family,
such as ion exchange or use of a soil-
clay cap.
Note: Typical sources of informa-
tion that can be used to identify
technology needs and to determine
capabilities of technology process
options include:
• ORD technology experts
• SHre program staff
• Technology Screening Guide for
Treatment qf CERCLA Sludges
and Soils (EPA/640/2-88/004.
September 1088)
• Appendix D of the RI/FS Guid-
ance
• Contractor process engineers
• Equipment Tendon
A list of potentially applicable technolo-
gies and technology process options.
corresponding to the identified general
response actions, is compiled and then
reduced by evaluating the process op-
tions with respect to technical imple-
mentability. That is, existing informa-
tion on technologies and site characteri-
zation data are used to screen out proc-
ess options that cannot be effectively
implemented at the site. Figure 4-4
the RI/FS Guidance illustrates the n
essary documentation for this evaluatio!
of process implementability and can be
included in the FS report.
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To the extent possible, design parame-
ters for the technologies being consid-
ered should be identified to focus sam-
pling efforts during the site characteriza-
tion phase. Field investigation activities
will be ongoing during the development
and screening of alternatives due to the
interactive nature of the RI and FS, which
are conducted concurrently.
Select Representative Process
Options
To simplify the development and evalu-
ation of alternatives, one representative
process option should be selected, if
possible, for each technology type re-
maining after the technical implementa-
bility screening procedure. Effectiveness,
implementability. and cost are the crite-
ria used to evaluate and select represen-
tative process options (see page 3 for a
description of these criteria). The sour
of information used to identify the
representative process option are
same as those used to Identify technol-
ogy types. During remedial design, other
process options may be selected If they
are found to be more advantageous.
Note: Given the performance un-
certainty often associated with
innovative technologies, it may not
be possible to evaluate innovative
process options on the same basis
as conventional processes. If avail-
able information indicates that
innovative technologies will pro-
vide comparable or superior treat-
ment performance, fewer or lesser
adverse Impacts, or lower cost for a
«tmii«i- level of performance, they
should be retained for further evalu-
ation.
Reevaluate Data Needs
The need for additional data may be;
apparent after representative
options have been selected.
engineers, equipment vendors, and PRP
In-house engineers and chemists can
help in determining which data are re-
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quired to assess potential process limi-
tations and which data are required to
establish design criteria.
tability studies are typically needed
enever treatment has been identified
as a viable alternative. These studies
provide data on technologies and their
effectiveness on a specific waste found at
a site. Treatability studies may not be
necessary in those instances where in-
formation already exists about a treat-
ment process and its performance on the
same type of waste found at the site.
Assemble Technologies Into
Alternatives
To assemble alternatives, general re-
sponse actions should be combined,
using different process options appli-
cable to different volumes of media or
areas of the site, to meet all remedial
action objectives. For example, an alter-
native might call for incinerating the
most highly contaminated soil from a
portion of the site, while capping other
less contaminated areas. When combin-
ing alternatives, it is necessary to con-
sider interactions between media, such
as the interaction between ground water
and soils through dissolution, preclpita-
•on, and adsorption processes. Consid-
eration should also be given to how
general response actions can be inte-
grated in the most efficient ways. For
example, residual streams that could be
addressed by two different response
actions may be best handled together.
such as sludge from a metals precipita-
tion process and ash from onsite incin-
eration. A description of each alternative
should be included in the FS report,
including the logic behind the assembly
of the specific remedial action alterna-
tives.
Screen Alternatives, If Required
The alternative development process
should focus only on the most viable
options for site remediation. In the event
that a large number of viable alternatives
remains at the conclusion of the assem-
bly of alternatives, an additional screen-
ing process should be used to limit the
number of alternatives that must un-
dergo the detailed analysis.
Source control alternatives retained
through the screening process should
include those options that have a signifi-
cant potential for being Implemented at
the site. The range of options that may
be retained could Include:
• Treatment options that minimize
long-term management require-
ments and address principal threats
• Containment options, used either in
conjunction with treatment or alone,
that reduce exposure to waste
• A no-action alternative (which should
be maintained throughout the analy-
sis)
Note: Generally no more than five
source control alternatives should
be carried through to detailed
analysis. Fewer alternatives may
be appropriate 'n the case of an
early action, where options are
limited or obvious, or when pro-
gram guidance or ARARs establish
appropriate alternatives.
For ground-water response actions, al-
ternatives should not only address re-
mediation or clean-up levels but also the
estimated time frame within which these
clean-up levels might be achieved. Al-
though the goal of ground-water response
actions is to return the ground water to
Its beneficial uses (i.e., health-based
levels should be achieved for potentially
drinkable water). It should be recognized
that it may not always be practicable to
attain this goal. Contingencies may need
to be planned for and discussed in the
Record of Decision (see Considerations
in Ground Water Remediation at Super-
jund Sites, October 1989. OSWER Di-
rective No. 9355.4-03). Information on
the range of alternatives for groundwa-
ter remedial response actions may be
found in the Guidance on Remedial Ac-
tions for Contaminated Ground tuater at
Superjund Sites (December 1988.
OSWER Directive No. 9283.1-2).
During screening, each alternative
should be evaluated with regard to:
• Short- and long-term effectiveness
and reductions achieved in toxicity.
mobility, or volume
• Implementability including techni-
cal and administrative feasibility
• Grossly disproportionate cost
The "short-term" Is considered to be the
remedial construction and Implementa-
tion period, while "long-term" begins once
the remedial action Is complete and re-
medial action objectives have been met
Technical feasibility includes the ability
to construct, reliably operate, and meet
regulations, as well as the ability to meet
the operations and maintenance, re-
placement and monitoring requirements
after completion of the remedial action.
Administrative feasibility includes the
ability to obtain approvals from other
agencies: the availability of treatment,
storage, and disposal services; and the
availability of equipment and technical
expertise.
The objective of the cost evaluation is to
eliminate from further consideration
those alternatives whose costs are grossly
excessive for the effectiveness they pro-
vide. Cost estimates for alternatives
should be sufficiently accurate to con-
tinue to support resulting decisions when
their accuracy improves beyond the
screening level. Capital, O&M, and pres-
ent worth costs should be determined.
Documentation of the screening proc-
ess, if conducted, is required. Figure 4-5
of the RI/FS Guidance provides an ex-
ample of adequate documentation.
Note: Potential action-specific
ARARs, identified earlier in the
process, are evaluated further with
respect to the remaining remedial
action alternatives. This process
continues until the comparative
analysis of the detailed analysis.
By this time, all action-specific
ARARs must be identified.
Development and
Screening Deliverables
Although generally no formal report is
required during this phase of the FS, It is
Important that the lead and the support
agencies agree in writing on the set of al-
ternatives selected for detailed analysis.
Based on agreement between the lead
and support agencies, the following in-
formation should be documented in the
FS report, which is submitted following
the detailed analysis of alternatives:
• Chemical- and/or risk-based reme-
dial objectives
• Technologies evaluated and reasons
for exclusion or inclusion
• Process option representation ra-
tionale
• Rationale for screening out alterna-
tives. If applicable
• Clear, concise description of each
alternative, including Its respective
chemical-, location-, and action-
specific ARARs
The Detailed Analysis Fact Sheet con-
tains a further description of the con-
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tents of the FS report (OSWER Directive
No. 9355.3-01FS4.)
RPM Responsibilities
The RPM is responsible for managing
this phase of the FS and specifically to
ensure that adequate technical support
is provided and that control of the pro-
ject's schedule and cost Is maintained.
Technical Supervision
Activities needed to ensure that ade-
quate technical supervision is provided
during the development and screening
of alternatives include:
• Communication with the support
agency, the contractor, and other
technical experts (i.e., members of
the Technical Advisory Committee
[TAG]) to obtain early agreement on
the technologies/alternatives to be
considered and on ARARs.
It may be appropriate for ORD's
START team to be included on the
TAC when treatment will be consid-
ered for complex or difficult to treat
waste. See the Scoping Fact Sheet
(OSWER Directive No. 9355.3-
01FS1) for additional information
on the START team and other tech-
nical experts.
• Emphasize, and provide direction to
the contractor or potentially respon-
sible parties (PRPs) (if it is a PRP-
lead RI/FS), on the need to focus the
effort to identify and screen tech-
nologies so that only a reasonable
range of viable alternatives is devel-
oped.
Schedule and Cost Control
Recommendations that should aid in
schedule and cost control of this phase
of the RI/FS include the following:
• Hold frequent meetings or confer-
ence calls to monitor progress. These
meetings can be informal, with dis-
cussion focusing on work plan ac-
tivities that need to be accomplished
in the immediate future and the
status of in-progress tasks that
should be completed. Avoid creating
delays associated with the prepara-
tion of lengthy deliverables to moni-
tor progress.
Review contractor monthly financial
statements and make sure all costs
are reasonable and justifiable. If
appropriate, monthly financial state-
ments should be supplemented by
talking with the contractor's project
manager about the schedule and
budget
Control the schedule for inter- and
intra-agency reviews, and schedule
review meetings in advance to em-
phasize the deadlines for completion
of reviews.
Understand the significance of the
labor hour cost to determine if the'
most efficient staffing levels are being
used.
Anticipate cost and schedule prob-
lems based on the contractor's previ-
ous month's performance and take
actions to minimize cost overruns
and schedule delays.
Enforcement
Considerations
The development and screening of reme-
dial alternatives is conducted much the
same whether it is being financed by the
Fund or by PRPs. If this phase of the RI/
FS is being conducted by the PRPs. they
will review, and if necessary, propose re-
finement of the remedial action objec-
tives proposed by EPA during the project
planning phase. Revision of the objec-
tives is subject to EPA approval. After re-
finement of the remedial action objec-
tives, the PRPs will typically conduct.
under the oversight of EPA. all aspects of
this phase of the FS. It is suggested that
EPA reviews be scheduled after. screen-
Ing technologies and process options.
assembling alternatives, screening alter-
natives, and identifying action-specific
ARARs. Additional information describ-
ing PRP participation in the RI/FS and
EPA's oversight role can be found in
AppendixAof the RI/FS Guidance and in
OWPE's ModelStaternentofWorkforPRP-
Canducted Remedial Investigations and
Feasibility Studies (June 2. 1989).
Points to Remembe
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