&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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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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                               -2-
 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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                                -2-


     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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                                -3-
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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                           -4-
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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