&EPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER: 9355.3-08
TITLE: Fiscal Year 1990 Regional Coordination Plan
and Themes for the Remedial Investigation
Feasibility Study and Selection of Remedy Process
APPROVAL DATE: 11-30-89
EFFECTIVE DATE:
ORIGINATING OFFICE:
D FINAL
D DRAFT
STATUS:
REFERENCE (other documents):
OS WER OS WER OS WER
/E DIRECTIVE DIRECTIVE
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Washington, DC 20460
QSWER Directive Initiation Request
9355.3-08
2. OHqfnator Information
NUTM of Contact Panon
Henrv L. Lonoest
Mail Coda
OS-200
Offiea
OERR
Talapnona .
382-2
XTitla
Fiscal Year 1990 Regional Coordination Plan
and Thanes for the Remedial Investigation
Feasibility Study and Selection of Remedy Process
4. Summary ol Oirectiva (indude brief statemant of purposa)
The purpose of this memorandum is to transmit the newly developed
Headquarters' Regional Coordination Plan and to communicate key
themes for implementing the remedial investigation/feasibility study (RI/FS)
and the selection of remedy process.
3. Kaywords
b.Ooas
It Supplamant Pravious Oiracttva(5)?
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GN.
7. Draft Laval
1 1 A-SJgnedbyAA/OAA j~ | B - Slgnad by Offlea Director
1 Yes What directive (numbar. tWa)
j 1 Ya« What dlraettva (numfear. 0da)
C - For Ravtaw & Convnant
| [ 0-lBOtwatepmant
8. Document to be distributed to States by Headquarters? 1 1 YM
D. |
Thla Raquaat Ma«ts OSWtR Dlracttvaa Syatam Format Standard*.
9. Signature of Laad Offlca Oiraoivas Coordinator
Betti VanEpps
10. Nama and TiUa of Approving Official
Henry L. Longest II -%.
Data
11-30-89
Oat*
. f
11-30-89
EPA Form 131S-17 (Rav. «-«7) Prwvioua aditiona art obadJata.
OSWER OSWER OSWER O
VE DIRECTIVE DIRECTIVE DIRECTIVE
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
MPV 3G
SOt_iOWAST = i
OSWER DIRECTIVE 9355.3-08
MEMORANDUM
SUBJECT:
FROM:
TO:
Fiscal Year 1990 Regional Coordination Plan and Themes
for the Remedial Investigation/Feasibility Study and
Selection of Remedy Process.
Superfund Management Review Reco
Henry L. Longest II, Director
Office of Emergency and Remedia
Bruce M. Diamond, Direct6r-
Office of Waste Programs
jrcement
Directors, Waste Management Division, Regions I, IV, V,
VII, and VIII
Director, Emergency and Remedial Response Division,
Region II
Directors, Hazardous Waste Management Division,
Regions III, VI
Director, Toxic and Waste Management Division, Region IX
Director, Hazardous Waste Division, Region X
Purpose
The purpose of this memorandum is to transmit the newly
developed Headquarters' Regional Coordination Plan and to
communicate key theses for implementing the remedial
invest iafltJicnyfeasibility study (RI/FS) and the selection of remedy
procesv^Hm plan describes the expanded role of the
Headqua^HS1 Regional Coordinators, including how the Regional
Coordin4JQH!fe will assist the Regions in implementing the quality
themes in Fiscal Year (FY) 1990 and beyond. These themes address
several issues and subjects particularly important to the
consistency and quality of decision-making. Our intent is to
identify themes at the beginning of each fiscal year as one way to
continually improve the program, and to consider the implementation
of these themes when evaluating program success.
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Background
As the Superfund program has grown, it has become increasingly
apparent that in addition to continuing to improve the management
of the Superfund program, we must also concentrate on improving the
quality of our studies and remedy selection decisions. The themes
described in this memorandum are qualitative in nature and do not
address budgetary or management aspects of the program. It is also
important to note that most of these themes, regardless of specific
topic, focus on early involvement in the RI/FS and selection of
remedy process.
The clarification of the role of the Regional Coordinators
was recommended in the Administrator's Superfund Management
Review. Program experience has indicated that successful
delegation of authority to the Regions should be accompanied by
oversight and coordination by Headquarters. This coordination
will help to ensure that Regions are kept apprised of current
policies and issues, that Regions have a resource for solving
technical and policy issues, and that the selection of remedy
process is consistent nationally.
Objective
The objective of this memorandum is to transmit the FY 90
Regional Coordination Plan and identify quality themes for RI/FSs,
Proposed Plans, and Records of Decision (ROOs). The themes focus
on areas where the program can demonstrate continuing improvement
in consistency and quality, and will be used as one tool in
evaluating progress in the program.
Implementation
Role of the Regional Coordinators
In order to be responsive to Regional needs, the Office of
Emergencvwd Remedial Response (OERR) and the Office of Waste
Program«i|te|crcement (OWPE) have developed a Regional Coordination
Plan fOBJdMpSQ- (Attachment 1). The major goals of this plan are to
provide^jp£p$tfegions with on-going support from RI/FS scoping
through po*t-ROD activities, and to provide a national quality
assurance program. Additional resources have been shifted to
regional coordination in order to provide direct project support on
a limited number of projects at various stages in the RI/FS and
selection of remedy process, along with day-to-day issue
resolution. As described in the attached plan, the Regional
Coordinators will focus on the themes described in this memo.
Regions are encouraged to use the Regional Coordinators as a
resource. Attachment 2 provides a current list of Regional
Coordinators in OERR and OWPE.
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Themes for FY 90
In order to continue to improve the quality of the RI/FSs,
Proposed Plans and RODs in FY 90 and beyond, the Regions should
consider the themes identified below, and explained in greater
detail in Attachment 3. These themes should be considered as early
as possible, and throughout the remedial process, as appropriate.
1) Develop remedial alternatives which are consistent with
the program goals and expectations described in the
proposed National Contingency Plan (NCP).
2) Conduct treatabilitv studies for alternatives which rely
on treatment technologies where performance is uncertain,
to enhance the use of new and innovative technologies.
3) Optimize consistency in risk assessment, where
appropriate, by integrating standardized exposure
assumptions in the baseline risk assessment.
4) Establish realistic expectations for ground water
remedies.
5) Address Land Disposal Restrictions (LDRs) in all Proposed
Plans and RODs.
As in the past, the RI/FS and selection of remedy process
should reflect use of the nine evaluation criteria described in
the proposed NCP, and the RI/FS and ROD guidances. All Proposed
Plans and RODs need to present a clear rationale for our remedy
selection decisions. As presented in the ROD guidance, it is
important to fully describe the selected remedy, what the remedy
will accomplish (e.g., cleanup levels), and the cost. We hope that
these themes can assist you in focusing your efforts, and we
encourage you to use the Regional Coordinators as a resource.
cc: Superfund Branch Chiefs, Regions I-X
Supjurfiond Regional Counsel Branch Chiefs, Regions I-X
Section Chiefs, Regions I-X
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Goals
Attachment 1
Regional Coordination Plan
Provide on-going Regional support from RI/FS scoping
through limited post-ROD activities
Provide program quality assurance
Scoping Support
Support to focus on
Likely technologies and need for treatability
studies
Data needs identification and analytical support
options
Maximizing schedule and cost efficiency
Focus effort on significant ground water projects
and those likely to include innovative technologies
RI/FS Support
Support to focus on
Post RI
o Risk posed by the site
o Adequate data to support FS
o Alternatives to be developed
Draft FS
o Establishment of cleanup and treatment levels
o Screening of alternatives
o Comparative analysis of alternatives
Ground water remediation approach
ARARs analysis
Support to focus on
Documentation of risk
Comparative analysis of alternatives
Land ban discussion
Ground water remediation approach
Documentation of conformance with the National
Contingency Plan (NCP)
ROD consultations
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Post ROD Support
Review Pre-Design Technical Summary reports
Focus .review on consistency with ROD, need for
ESD/ROD amendment, LDR application
Provide ESD/ROD amendment support as requested
FY 89
o Conduct Comparative Analysis Study of similar type sites
o Analysis of FY 89 RODS
o Participate in Regional ROD forums
Issue Resolution
o Provide day-to-day Regional support as requested to
resolve issues, problems, and questions
includes phone calls, memos, directives, etc.
o Where possible, identify subject/site type expert
support
HQ Management Support
o Provide support to HQ management.
site and ROD status tracking, Regional delegation,
SCAP and SPMS, response to reports and inquiries,
coordination of "mega sites."
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Attachment 2
Superfund Regional Coordinators
RI/FS and ROD Regional Coordinators
Region
1
11
III
IV
V
VI
VII
VIII
IX
X
Fund-OERR
Nam*
Jennifer Haley
Alison Barry
Sharon Frey
Tish Zimmerman
Trudi Fancher
Sandra Panena
Robin Anderson
Tish Zimmerman
Steve Golian
David Cooper
Steve Golian
FTSNo.
475-6705
475-9839
475-9754
382-2461
475-9759
475-9757
382-2446
382-2461
475-9750
475-6703
475-9750
Region
1
II
III
IV
V
VI
VII
VIII
IX
X
Enforcement • OWPE
Nam*
Candace Wingfield
Neilima Senjalia
Jack Schad
Candace Wingfield
Kurt Lamber
Joe Tieger
Jack Schad
Joe Tieger
Joe Tieger
Kurt Lamber
FTS No.
475-9317
475-7027
382-4848
475-9317
382-4331
475-8372
382-4848
475-8372
475-3372
382-4831
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Attachment 3
Discussion of Themes of Fiscal Year 1990
1) Develop.remedial alternatives which are consistent with the
program goals and expectations described in the proposed
National Contingency Plan (NCP),
The goal of the remedy selection process is to select
remedial actions that are protective of human health and the
environment, that maintain protection over time, and that
minimize untreated waste. The program expectations identified
below are intended to focus the evaluation of alternatives to
those which are realistic for site conditions:
o Treatment of principal threats (i.e. liquids, highly
mobile or toxic materials) will be used, whenever
practicable;
o Engineering controls are most appropriate for waste that
poses a low, long-term threat or where treatment is
impracticable;
o Institutional controls will be used to mitigate short-term
impacts or to supplement engineering controls; they will
not serve as a sole remedy unless active response measures
are impracticable;
o Remedies will often combine treatment of principal threats
with engineering and institutional controls for treatment
residuals and untreated waste;
o Innovative technologies should be considered if they c-fer
the potential for comparable or superior treatment
performance, reduce adverse impacts, or lower costs for
similar levels of performance than demonstrated
technologies;
id water will be returned to it beneficial uses within
imeframe that is reasonable, where practicable.
2) Conduct treatability studies for alternatives which rely on
treatment technologies where performance is uncertain, to
enhance use of innovative treatment technologies.
Treatability studies should be conducted for technologies
for which limited or no performance data is available.
Treatability studies should be planned for and conducted early
in the RI/FS process as noted in the February 21, 1989
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Directive from Henry Longest and Bruce Diamond (OSWER
Directive No. 9355.0-26). In some cases, it may be
appropriate to conduct more than one treatability study. In
addition, treatability studies can extend the time required
for the RI/FS. This is warranted if the data is needed to
provide greater assurance that the technology selected can
meet the performance standards identified in the ROD.
Regional planning should factor in the time and resources
required for these studies.
The need for a treatability study should be based on
available data (i.e., literature survey) and site specific
information, and the RI/FS should document the source of the
data which support the remedy evaluation. The EPA Office of
Research and Development (ORD) will provide expert assistance
through the Superfund Technical Assistance Team (START) and
the Superfund Technical Support Project (TSP) to aid in the
determination of the need for, and the planning of,
treatability studies. In addition, ORD is preparing guidance
documents to facilitate the performance of treatability
studies, the first of which is entitled "Guide for Conducting
Treatability Studies under CERCLA." This guidance, to be
issued in December, 1990, will present an overall strategy for
planning treatability studies and provides protocols for
conducting the studies (e.g., work assignment through final
reports). The Office of Solid Waste and Emergency Response
(OSWER) will issue short-sheets related to treatability study
guidance documents.
3) Optimize consistency in risk assessment, where appropriate, by
integrating standardized exposure assumptions in the baseline
risk assessment.
Conditions vary among sites, and risk assessments should
be tailored accordingly. Despite site-specific differences,
risJtfjtsessments frequently evaluate similar types of exposure
rottSRfrand pathways, and should rely on standardized risk
asjHBHUons which are discussed in the "Risk Assessment
GuiJijpM for Superfund - Human Health Evaluation Manual"
(OSWER Directive No. 9285.7-Ola.).
As part of the RI/FS, it is important to consider all
potential pathways of exposure, and to eliminate those which
are unrealistic given the site conditions and potential
exposures. The ROD should clearly define all the risks and
exposure pathways existing at a site, and should explain how
the selected remedy addresses the risks. Risks or routes that
are not germane to the site should be briefly discussed, but
should not be a major focus of the ROD.
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4) Establish realistic expectations for around water remedies;
Program experience with some remedies which include ground
water pump and treatment has indicated that while the need for
ground water treatment is clear, the timeframes for
restoration and the cleanup levels which can be attained may
be uncertain at the completion of the RI/FS. For these sites,
the following recommendations should be considered:
o Collect appropriate data to assess potential performance
of pump and treatment technologies. Examples include
vertical variations in hydraulic conductivity and
contaminant concentration in the soil of the saturated
zone. .
o Consider initiating early action to prevent contaminant
migration while the RI is completed, and collect data on
plume response to gradient control.
o Consider interim actions or contingency Records of
Decision (ROOs) where achievement of health based
standards over portions of the area of attainment is
uncertain.
5) Address Land Disposal Restrictions (LORs) in all Proposed
Plans and ROOs.
Usually, only those requirements that are ARAR for a
particular alternative need to be documented. However, due to
the importance and complexity of LDRs, these restrictions
should be addressed in the description of each alternative
that appears in RI/FSs and RODs. Specifically, the
description of alternatives should indicate whether or not
placaaent of restricted RCRA waste is involved.
>ther important LOR consideration to keep in mind is
reatability variances will often be needed for
al«iSRn»tives involving the treatment of soil and debris
contaminated with restricted RCRA wastes and where Best
Demonstrated Available Technology (BOAT) standards cannot be
met or are not appropriate. In these cases, the alternate
treatment levels to be achieved under such variances should be
stated in the RI/FS, Proposed Plan, and ROD. (See Superfund
LOR Guide #6A, "Obtaining a Soil and Debris Treatability
Variance for Remedial Actions," OSWER Directive 9347.3-06fs.)
LOR Guide #7, entitled "Determining When Land Disposal
Restrictions (LDRs) are Relevant and Appropriate to CERCLA
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Response Actions," to be issued in December 1989, should be
consulted to determine when LDRs should be attained when they
are not applicable.
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