vvEPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER: 9355.3-05
TITLE: RI/FS Improvements Follow-Up
APPROVAL DATE: 4/25/33
EFFECTIVE DATE: 4/25/88
ORIGINATING OFFICE: CEBR
0 FINAL
D DRAFT
STATUS:
REFERENCE (other documents): surplenehts
RI/ES Isprovenents {Directive *9355 IK2QJ
OSWER OSWER OSWER
fE DIRECTIVE DIRECTIVE
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Wellington OC 20460
OSWER Directive initiation Request
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9355.3-05
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Bill Hanson
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RI/FS Improvements Follov-Up
|4 Summary ol Directive {incuse on* vatament o» purgoui ——
Provides continuing guidance to regions regarding methods to shorten theRI/FS
process
4. OM is rteavt upcncaa revious ir«cnv«
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UNITED STATES-ENVIRONMENTAl, PROTECTION AGENCY
WASHINGTON. O.C. 204CO
APR 25 1988
" SOUO WASTt ANO «M««GINCV
OSWER Directive 9355.3-35
MEMORANDUM
SUBJECT: RI/FS Improvements Follow-up
FROM: Henry L. Longest II, Director
Office of Emergency and Remedia
TO: Directors, Waste Management Division
Regions I, IV, V, VI, VZZ, and VZZZ
Director, Emergency and Remedial Response Division
Region ZZ
Directors, Hazardous Waste Management Division
' . Regions ZZZ and X
Director, Toxics and Waste Management Division
Region ZX
Director, Environmental Services Division,
Regions I-X
PURPOSE
This memorandum is to provide continuing guidance to the
Regions regarding methods to shorten the RZ/FS process. As
stated by the OSWER memorandum issued by Dr. Porter on
January 15, 1988, it is the goal of the Agency to reduce the
average schedule for completing an RZ/FS to. 13 months (from
work assignment issuance to the public comment FS). The
purpose of this memorandum is to provide guidance to assist
the Regions in working towards achieving that goal. The
focus of this memorandum is on actions which are readily
implementable in most Regions. The attachments provided
with this memorandum elaborate on the specific recommendations.
Solution* to specific procedural problems and more far-reaching
programmatic actions will be the subject of additional future
work involving the Regions, States, other Federal Agencies,
and remedial contractors over the next several months.
BACKGROUND
This memorandum will serve as a continuation of the RI/FS
Improvements process which was discussed in the July 22, 1937
OSWER Directive 9355.0-20 entitled "RI/FS Improvements".
Since July, several other important activities have been
undertaken by Headquarters in conjunction with the Regional
offices. A RZ/FS Improvements follow-up initiative has begun
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which is investigating additional ways to save time in the RI/FS
process while not adversely effecting cost and quality. The initial
findings of this initiative were developed during several brain-
storuing sessions held during January 1988. Participants included
Regional, Headquarters, State and contractor staff.
This .nemorandurn and its attachments will serve as the formal
means of presenting these ideas to the Regions for their consid-
eration. Some of the suggestions may not be implementable in
your particular Region. However, I urge you to consider each of
these initiatives and begin implementing them in your respective
Regions if possible.
Many of the time saving recommendations discussed in this memo
may be more applicable for Federal fund-lead sites. Zt is recognized
that Enforcement and State-lead sites must, in many situations, be
handled differently. These circumstances will be addressed in much
more detail in Phase IX of this effort.
The remainder of this memorandum presents recommended initiatives
divided- into six categories. Discussion will focus on short-tern,
activities that are relatively easy to implement. Several of the
more far reaching initiatives, which may require structural
changes to the existing process, are mentioned in this memo but
are not necessarily recommended at this time. They will-be evaluated
in much greater detail over the next few months in Phase II.
".EXPEDITING PROJECT SCOPING AMD INITIATION
Scoping and planning activities have proven to be a time consuming
portion of the RI/FS process. This activity encompasses the time
from work assignment initiation until work plan approval. These
activities take an average of 4-6 months to complete but have been
known to take much longerc Several possible time saving areas
are provided for consideration below.
RECOMMENDATIONS
o Have the initial work assignment and scope of work
serve as authorization to begin some limited fieldwork.
o Eliminate the interim work plan if it is not
providing for work to begin in the field and
instead use the initial authorization to serve as a
replacement.
o Utilize new listing site inspection data during the
scoping process.
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IMPROVING DATA COLLECTION/ ANALYSIS AND MANAGEMENT
To expedite the RI/FS process, Regions, with assistance
from staff in the Environmental Services Divisions (ESD),
should incorporate the data quality objectives (DQO) process
(OSWER * 9355.0-7B) in order'to match analytical levels and
data validation procedures to data needs.
RECOMMENDATIONS
o In the course of completing DQO's, consider choice of
analytical service carefully. Consider field screening
and on site or local lab use along with CLP options.
•
o Ensure field contractor training in CLP procedures.
o Begin scoping of alternatives with unvalidated data.
o Maintain communication with data reviewers to
emphasize priority projects.
o Allow contractor to validate data with ESOs
providing guidance and quality assurance audits.
EARLY IDENTIFICATION AND IMPLEMENTATION OF TREATABILITY
STUDIES
Treatability testing is used to supplement the evaluation of
certain technologies. Included in treatability studies are
evaluations of process performance, process sizing, and costs.
These studies are conducted in sufficient detail to support the
remedy selection process. Currently studies have been taking
12 to 18 months to complete and have caused delays in overall
project Schedules.
RECOMMENDATIONS
o Initiate treatability studies as soon as possible in
th« process. Start planning in the scoping phase if
enough data exists.
o Begin alternative development and screening early in
the RI.
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o Limit the number of alternatives which are evaluated
in detail in order to focus on the treatability
studies which may be necessary.
o 'Jse the Technical Assistance Committee- (TAG) to assist in
screening and evaluation.
EXPEDITED PROCUREMENT AND FUNDING PROBLEMS
In compliance with the Federal Acquisition Regulations
(FAR), the Agency will always seek fair and open competition.
However, it is imperative that the impact of the procurement
process be minimized. Several initiatives, discussed in the
attachment, will be investigated in the future to help address
these procurement issues.
IMPROVING PROGRAM MANAGEMENT AND COORDINATION
The program management aspects of an RI/FS have always been
fundamental in the smooth operation of an RZ/FS. If effective
program'management tools are not in place, the schedule, cost
and quality of an RI/FS will be impacted. Below are several
initiatives which should be considered by each Region.
RECOMMENDATIONS
o Regional Management should be selective when designating
who should review each document. Limit intra-agency
reviews.
o Promote establishment of review schedules to which all
parties can commit. Encourage meetings with reviewers to
discuss and address comments.
r
o Involve staff and management in the process early and
at key decision points.
o Carefully access the amount of data necessary to make a
decision. Numerous delays in decision-making have been
encountered when more data is requested to support a
decision. It is encouraged to acknowledge and accept
some risk in decision-making.
IMPROVE INFORMATION TRANSFER
An enormous amount of information regarding such topics as
treatment technologies and specific cleanup decisions (ROD
updates) is being generated both within the Superfund program
and in the private sector. OERR's position is to facilitate
and promote technology transfer throughout the Superfund
program. To help keep abreast with as much information as
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possible, HSCO has been tasked to begin to develop a variety
of information transfer activities (see attachment 2). it is
our goal that RPMs and contractor staff have a comprehensive
data base to refer to when performing RI/FSs.
PHASE II INITIATIVES
As was mentioned previously/ the primary focus of this memo
is on short-term initiatives that are relatively easy to implement.
However, there were many far-reaching initiatives also identified
during previous discussions. These suggestions may require
structural changes to the existing process. Several areas
that will be focused on in Phase II include: 1) enforcement
aspects; 2) State considerations; 3) interim-action response;
4) technical/procedural aspects (e.g., laboratory support,
treatability studies, scoping); 5) procurement actions
(e.g., well drillers, subcontract procurement) and; 6) program
management aspects (e.g., performance-based goals, risk taking
in decision making, incentives).
Work groups are being established to address these various areas
and a report will be prepared in September, 1988 outlining some
major 'structural/institutional recommendations to the overall
RI/FS process.
COMCLCJSIOM
The recommendations are elaborated on in the attachments. I
believe that by incorporating these recommendations, we will
begin to meet our objective of reducing the time to complete
RI/FSs. We will continue to work with you through Phase II
and hopefully develop solutions to some structural/institutional
problems which have adversely affected the schedule, cost and
quality of the RI/FS process.
Attachments
cc: Superfund Branch Chiefs, Region 1-10
Quality Assurance Officers, Regions 1-10
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RI/FS IMPROVEMENTS FOLLOW-UP
ATTACHMENT I
INTRODUCTION
This attachment will elaborate on the improvement initiatives
recommended in the attached memorandum in some greater detail.
The recommendation and the results of implementing each
recommendation are discussed below. The primary focus will be on
the short-term initiatives which are relatively easy to implement
in each category. These recommendations are referred to as the
Phase I initiatives. The more far reaching initiatives will be
touched upon here, but will be investigated in much greater
detail in Phase II of this effort.
EXPEDITING PROJECT SCOPING AND INITIATION
Description
Scoping and planning activities have proven to be a time
consuming portion of the RI/PS process. These activities take an
average of 4-6 months to complete but have been known to take
much longer. Several possible time saving areas are provided for
consideration below.
Recommendations/Results
Phase I
o Have the initial work assignment and scope of work
serve as authorization to begin limited field work.
Thus, no other interim documentation would be required
^ for work to begin. The contractor would begin initial
field work as soon as receiving approval from the RPM.
This would allow project initiation while planning is
underway. Data which are collected and evaluated
during this time frame should assist in the
project scoping phase.
o In some Regions, SI data has not been made readily
available to the contractor tasked to perform a RI/FS.
Each RPM should make sure that all appropriate data ace
made available to those working on a site. Utilizing
data collected during the SI (particularly the listing
SI) or, as in Region IV, data gathered between the NPL
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Phase II
listing and the work assignment issuance (forward
planning) has proven beneficial during the scoping
process. The evaluation of these data along with all
other previously collected data .could prevent
duplication of effort and provide a better
understanding of future data needs and better help to
focus the scope of the project earl/ in the process.
Region IV has found it preferable to task the same
contractor to perform this early sampling and the
RI/FS.
It is important that each regional office : remedial
contractor communicate routinely regardinq .-joining
work assignments. Contractors will perform more
effectively if they have time to plan internal and
subcontractor resources. Therefore, regular
communication could help avoid scheduling problems. '
Work plan approval has been a long and uncertain
process. .To assist in the timing of this approval
process, many Regions have found it to be advantageous
to hold a meeting between the EPA RPM, State RPM,
community relations, ORC, enforcement staff and
contractor prior to work plan development. By creating
an early consensus on objectives and general approach,
this meeting may help reduce work plan detail and
special reviews.
To reduce the time required to develop and rove work
plans, it may also be appropriate to use s- .iardized
formats, incorporate routine items by reference and/or
use a generic format on plans such as QAPjPs.
Due to the time spent on work plan preparation,
initiatives will be analyzed to have the work plan
document simplified. If a work plan is simplified,
field conditions, which may change in the scope of the
RX, may be more easily dealt with and formal work plan
amendments may not be necessary.
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IMPROVING DATA COLLECTION, ANALYSIS AND MANAGEMENT
Description
To expedite the RZ/FS process, Regions should follow the Data
Quality Objectives (DQO) process in order to natch analytical
level and details to data needs.
Recommendations/Results
Phase I
o The choice of analytical service must be carefully
considered during each step of the RX/FS process. Full
Contract Laboratory Program (CLP) analysis may not be
the appropriate mechanism to use in all cases. Regions
should consider: CLP VQA-only analysis (two week turn-
around requirement), the use of BSD labs, field
screening with CLP confirmation,, and the use of CLP •
Special Analytical Services. Regions are also
encouraged to consider using local and on-site labs
with appropriate CLP confirmation for other analytical
requirements. The proper selection of analytical
services as part of the OQO process should help reduce
the time required to process samples.
o Regions should keep in mind the REM and ARCs
contractors' capability to perform analytical work
through their own labs or through a subcontractor.
o Poor sample preservation or chain-of-custody procedures
can result in loss of data and/or resampling. Regions
p should ensure that field contractors are trained in
proper CLP procedures and should follow-up when field
contractors are causing delays by not following proper
procedure*.
o Concern has arisen that the data validation process is
causing unreasonable delays during the RI/FS.
Therefore, in certain situations, it may be appropriate
to begin the alternatives evaluation or scoping of
subsequent site characterization phases with
unvalidated data. Conclusions can then be updated and
verified, as needed, once validated data become
available. By doing this, the second phase of field
work and the feasibility study process can be initiated
earlier, thus helping to shorten the overall schedule.
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Regions should maintain continual communication with
data reviewers emphasizing priority sample packages,
critical and non-critical substances, and the level of
required data review identified during the OQO process.
Regions should also consider directing their
contractors to validate all their data rather than
using Environmental.Services Division (ESO) staff for
this purpose (see 3/18/93 memo from Henry Longest).
This would allow ESO to play a much more active role in
providing guidance on data validation as well as allow
ESO to be auditors in the field -nd in the
laboratories. Several Regions ats presently operating
this way.
Phase II
o Other considerations are the possible disincentives to'
using field screening, field analyses, and methods
other than CLP Routine Analytical Services (RAS) that
exist in the program. Phase- II will focus on issues
that motivate Regions to use Levels 4 and 5 analyses
(CLP RAS and non-standard analyses) when DQOs would
dictate other types of analyses are more appropriate.
•
o Several Regions have noted that the need for sample re-
analysis can adversely affect project schedules. Phase
II will examine ways to expedite re-analysis of
samples.
EARLY IDENTIFICATION AND IMPLEMENTATION OF TREATABILITY STUDIES
r
Description
Treatability testing is used to supplement the evaluation of
certain technologies. Included in treatability studies are
evaluations of process performance, process sizing, and costs.
These studies are conducted in sufficient detail to support the
remedy selection process. Currently studies have been taking 12
to 13 months to complete and have caused delays in overall
project schedules.
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Recommendations/Results
Phase I
Phase ZI
It is very important* as early as possible in the
process, to identify the need for and then initiate
treatability studies. It is important, however, to make
sure that sufficient quality data are used to determine
the need for a treatability study.
Keeping alternatives to a minimum will help avoid
schedule delays. Early resolution on the need for
treatability studies should result from initiating
alternative screening early in the RX process as well
as limiting the number of alternatives which are
screened. A method for achieving early brainstorming
and consensus on screening is to use a Technical
Advisory Committee (TAG). The TAC consists of
individuals with expertise in the appropriate technical.
areas. A TAC should be considered to assist the RPM in
the early screening and evaluation of alternatives.
The TAC has been shown to bring valuable expertise and
insight to this process.
The possibility of performing generic treatability
studies will be investigated by OERR during the Phase
II process. Data would be generated on classes of
wastes or sites which could be used by Regions or PRPs
addressing similar situations. The elimination of the
need for formal QAPjP documents during the treatability
study (while"adhering to a QA process, which could save
time and contractor costs) will also be investigated.
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EXPEDITED PROCUREMENT AMD FUNDING PROBLEMS
Description
As a matter of policy/ the Agency will'always seek open and fair
competition, however/ it is imperative that the impact of the
procurement process be minimized. I IT nutnerous situations/ it
appears that the process employed in the procurement of second
tier subcontractors such as drillers has led to numerous delays
in the RI/FS process. Contract documents are not providing for
routine scope changes or the provision of second phases of field
services. This then requires a second time consuming procurement
cycle to account for these shortcomings. Awarding the contract
is complicated by the unpredictability of the work plan approval
schedule. The following suggestions will be evaluated by
Headquarters:
Recommendations/Results
Phase
Phase II
Awarding multiple procurements where possible has been
used successfully on numerous occasions. Multiple
sampling or drilling episodes can be procured
simultaneously thus avoiding delay between the* first
and second phase procurement.
Use of mobile or local labs to provide faster
analytical turnaround is being used more routinely now
by many Regions (e.g. Seymour Recycling Region V).
This will avoid the need to demobilize/remobilize field
contractors if analytical turnaround can be
accomplished rapidly.
Several of the REM and ARCs contractors are utilizing
Basic Order Agreements (BOAs) to maintain a short-list
of subcontractors for remedial projects. Use of BOAs
ha* expedited the procurement of subcontractors.
Many Regions have also commented that initial funding
is too limited to accomplish meaningful work and alnost
all Federal fund-lead sites are incrementally funded
creating a delay at each funding step. OERR will work
very closely with regional offices to try to address
this concern.
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o It is also recognized that procurement regulations are
causing delays in State-lead RI/PSs. We- hope to work
with each State.in trying to minimize this delay. Due
to the important role each State plays in the Superfund
process, a Phase II workgroup has been established to
specifically address State issues.
IMPROVING PROGRAM MANAGEMENT AMD COORDINATION
.Description • _ *
Program management aspects of an RI/FS have always been
fundamental in the smooth operation of an RI/FS. If effective
program management tools are not in place, the schedule,.cost' and
quality of an RI/FS will be impacted. Below are, several
initiatives which should be considered:
Recommendations/Results
Phase I
o The process of deliverable* review needs to be improved
by 1) achieving early consensus on approval, 2)
shortening reviewer schedules, 3) increasing the
predictability of the review schedules, and 4) limiting
the number of reviewers in the critical path. Progress
of an RI/FS is often hindered by the time required to
get all of the necessary reviews of each document.
Regional Management should be encouraged to be
selective when designating who should review each
document. Review schedules should be established to
which all. parties can commit. If these schedules are
not met by a reviewer, that individual would forfeit
r their right to comment.
o To achieve a consensus on approach, it is also
important that meetings be held at fixed times
throughout the process to discuss important items.
Meetings should be held internally with Agency
management as well as with others involved in the
process. Many of these meetings could be workshops
during which deliverable reviews are brought to a
close, as is now done in Region IV, rather than waiting
for all parties' comments to be. returned.
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Phase II
Managers must be willing to accept some cisk and move
forward with the available information. Numerous delays
have been encountered due to the fact that management
is routinely asking for more data when it may not be
necessary. The need to collect a sufficient amount of
data to make a sound decision has always been a
priority of Agency management, however, a decision to
proceed must be made as quickly as possible. Early
management involvement, as discussed above, has been
shown to lead to a more rapid management acceptance of
the final remedy.
RPM turnover has been pointed to as a major reason for
schedule slippage when it does occur. RPM retention is
a problem of growing magnitude which will be
investigated in Phase II. The use of higher non-
supervisory grades as well as improving incentives
(e.g., Region .III has an RPM of the Month program )
will be investigated. Training opportunities, to
better develop the management and interpersonal skills
as well as technical skills of the RPMs, will be
explored. The RPM bears the majority of the
responsibility for completing the process and should be
rewarded for getting the work done on time and within
budget.
Given the responsibility RPMs have for execution and
completion of a RI/FS, initiatives will be investigated
to give more authority to the RPMs.
The delays caused by the enforcement impacts to the
RI/FS process are of great concern to the Agency.
Switching work between enforcement groups and fund-lead
groups has been identified as one key problem. The
organizational structure in several Regions (1, 4, 5,
li) where one RPM is responsible for both fund-lead and
enforcement-lead activities will be studied.
Additionally, the new ARCS contracts will include TES
functions so that it will not be necessary to switch
contractors if a site's status is changed. An
enforcement workgroup will be established during Phase
II to discuss these and any other enforcement related
issues.
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RI/FS IMPROVEMENTS FOLLOW-UP
ATTACHMENT 2
Remedial Information Transfer A
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accomplishments in the ROD process; ROD summaries which
describe site conditions and k»y contaminants, selected
remedial actions, specific remedy performance standards and
$oals, and i nsti tuti onal-^control s for each ROD signed in a
yiven fiscal year; 'the ROD summary Tahle which summarizes
all remedial actions, capital and operation and maintenance
costs, contaminated nedia, and operahle unit information for
each ROD 1n a given fiscal year; the Index of Approved
Remedial Actions which summarizes selected remedial actions
for prior fiscal year RODS; and the ROD Keyword List which
provides major key word categories and their subcategories
for all ROOs signed to date.
Outreach/Coordination Activities
ROD Update - Periodic updates with current information on
ongoing RI/FS and ROO activ1ti.es. Current Issues include
statistical summaries and hrief discussions of policy.
Future issues will Include discussions on selected policy
.Issues, schedules of upcoming meetings, training and policy
directives, "helpful hints" on managing projects, and
potentially others.
CR Update - These reports are similiar to the ROD update, hut
focus on community relations issues.
Design and Construction update - Periodic updates 'designed to
share information among the Regions on the complex
technical and management issues they face as they move into
the RO and construction phase of many Superfund projects.
Workshops and RO Meeting . HSCO Workshops with RPMs, managers,
arrd contractors provide first hand information on
technical, policy and administrative issues. Upcoming
RPM/OSC meetings will he organized hy QERR to increase
information transfer among Regional offices.
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