&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 ------- 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)? 1 JNo 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 ------- 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. ------- 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. ------- 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 ------- 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 ------- -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." ------- 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 ------- 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 ------- -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. ------- -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 ------- -4- Response Actions," to be issued in December 1989, should be consulted to determine when LDRs should be attained when they are not applicable. ------- |