Ti UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
'5? WASHINGTON, D.C. 20460
OFFICE OF
SOLID WASTE AND EMERGENCY RESP<
JUN 2 1989
OSWER Directive 9835.8
MEMORANDUM
SUBJECT: Model Statement of Work for a Remedial Investigation
and Feasibility Study Conducted by Potentially
Responsible Parties
FROM: Bruce M. Diamond, Directoi
Office of Waste Programs Enforcement
TO: Director, Waste Management Division,
Regions I, IV, V, VII, and VIII
Director, Emergency and Remedial Response Division,
Region II
Director, Hazardous Waste Management Division,
Region III and VI
Director, Toxics and Waste Management Division,
Region IX
Director, Hazardous Waste Division,
Region X
Communities and individuals often express concern with the
ability of potentially responsible parties (PRPs) to adequately
perform remedial investigations and feasibility studies (RI/FSs)
at Superfund sites. Some people believe that PRPs may conduct
either an inadequate assessment of the nature and extent of
contamination at a site, and/or an inadequate assessment of the
risks posed by a site. In addition, Regional offices continue to
express an interest in receiving guidance on how to better assure
the quality of a PRP conducted RI/FS.
One step to be employed in improving the quality of a PRP-
conducted RI/FS is the use of a more precise statement of work
(SOW) during negotiations that include the results of preliminary
scoping by EPA. This memorandum transmits a final model SOW
designed to produce a PRP-conducted RI/FS that is consistent with
the Office of Emergency and Remedial Response's Guidance for
Conducting Remedial Investigations and Feasibility Studies.
October 1988 (OSWER Directive 9355.3-01).
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9835.8
Additionally, the model SOW satisfies Regional views that
interim deliverables are a necessary ingredient to advancing the
prospects of a quality PRP-conducted RI/FS. Most of the interim
deliverables covered under the model SOW are in the nature of
technical memoranda that may or may not require EPA approval
before the next step in the RI/FS is commenced by PRPs. Of
course, EPA would be able to direct PRPs to undertake additional
work if the interim deliverable is not satisfactory. In any
event, discretion is provided to tailor the model SOW to the
particular-circumstances of the site or practices of the Regional
office. The instructions to the model SOW provide further
explanation on this subject, as well as on the subject of
reserving portions of the RI/FS for conduct by EPA.
We have made every attempt to incorporate all relevant
comments received from various Headquarters and Regional offices.
As you proceed to use the model SOW, any questions or additional
insights should be directed to Tony Diecidue of my staff at FTS
(202)-382-4015.
Attachment
cc: CERCLA Enforcement Branch Chiefs, Regions I-X
CERCLA Enforcement Section Chiefs, Regions I-X
Regional Counsels, Regions I-X
Henry L. Longest
Glenn L. Unterberger
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9835.8
MODEL STATEMENT OF WORK FOR A
REMEDIAL INVESTIGATION AND FEASIBILITY STUDY
CONDUCTED BY POTENTIALLY RESPONSIBLE PARTIES
INSTRUCTIONS
This model statement of work (SOW) was developed to provide
potentially responsible parties (PRPs) direction in performing
the tasks that are required to successfully complete a remedial
investigation/feasibility study (RI/FS). A SOW for a PRP-lead
RI/FS must be used in conjunction with the Office of Emergency
and Remedial Response's October 1988 Guidance for Conducting
Remedial Investiaa-*ions and Feasibility Studies Under CERCLA
(hereafter referreu to as the RI/FS Guidance) and should be used
with the Office of Waste Programs Enforcement's forthcoming
Guidance on Oversight of Potentially Responsible Party Remedial
Investigations and Feasibility Studies. The organization of this
model SOW is according to the tasks that must be performed during
a PRP-conducted RI/FS. These tasks include:
Task 1 Scoping;
Task 2 Community Relations;
Task 3 Site Characterization;
Task 4 Baseline Risk Assessment;
Task 5 Treatability Studies;
Task 6 Development & Screening of Remedial Alternatives;
Task 7 Detailed Analysis of Remedial Alternatives.
This model SOW is written on the general approach that a PRP
RI/FS is commenced pursuant to an Administrative Order on Consent
(AOC) with an attached SOW, and that the PRPs perform work and
submit deliverables to EPA. Depending on site circumstances and
the relationship to PRPs, it may be necessary to modify this
management approach. Moreover, because the work required to
perform a RI/FS is dependent on a site's complexity and the
amount of available information, it may be necessary to modify
the components of this model SOW in order to tailor the tasks to
the specific conditions at a site. Similarly, the level of
detail within the model SOW will vary according to the site. The
Regions have discretion to develop a site-specific SOW that does
not precisely follow this model SOW, including portions of the
work to be performed by EPA, technical provisions, deliverables
and approvals. An example of an alteration to this model SOW may
include the PRPs' responsibilities concerning the baseline risk
assessment. Because the baseline risk assessment serves as a
primary means for supporting enforcement decisions at most sites,
the Regions may write a site-specific SOW providing for EPA
preparation of the risk assessment or the exposure assumptions.
While not preferred as a general approach, at some sites EPA may
develop itself, or in negotiations, a work plan rather than a SOW
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9835.8
and then enter into an AOC.
When special notice for a RI/FS is issued, at most sites a
draft SOW should be attached as an addendum to a draft AOC.
Prior to the issuance of special notice, EPA, generally with
contractor assistance, will determine both the objectives of the
RI/FS and a general approach for managing the site. Determining
the site objectives and a general site strategy will be required
regardless of whether an administrative order is signed with the
PRPs or the RI/FS is Fund-financed.
The site objectives should specify the purpose of any
activities to be conducted at the site, including any interim
actions that may be necessary, as well as the objectives of the
required remedial actions (e.g., the preliminary cleanup goals).
These objectives should specify the contaminants and media of
concern, the exposure pathways and receptors, and an acceptable
contaminant level or range of levels for each exposure route.
The site objectives are developed'and based on existing site
information, contaminant-specific ARARs, when available, and risk
related factors.
The site management strategy is developed once the
objectives have been established and identifies the study
boundary areas and the optimal sequence of site activities,
including whether the site may best be remedied as separate
operable units. The general management approach should include:
identifying the types of actions that may be required to address
site problems, identifying any interim actions that are necessary
to mitigate potential threats or prevent further environmental
degradation, and determining the optimal sequence of activities
to be conducted at the site. Also included in the site
management strategy should be the decision as to whether the RI
will serve as a continuation of the PRP search. This would be
appropriate at sites such as areawide groundwater contamination
or stream contamination where all of the sources of contamination
are not yet well defined.
The delive'rables described in this model SOW fall under one
of three management categories. Under the first category,
deliverables must be approved by EPA before work can either begin
or continue. This includes the work plan and the site sampling
and analysis plan. Similarly, EPA approval of the final risk
assessment, RI report, treatability studies and FS is the general
approach. Under the second category, EPA may exercise an option,
in drafting the site-specific SOW, to either comment on or review
and approve the deliverables. Review and approval of
deliverables under this second category will be based on the
particular circumstances of the site or practices of the Regional
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9835.8
office. This category will include most of the deliverables that
are described in this model SOW, such as technical memoranda and
reports. A middle ground is to allow work in these areas to
proceed without resubmittal and approval so long as the changes
required by EPA are fully reflected in subsequent deliverables.
This approach of commenting strikes a balance between excessive
approval and dispute resolution of numerous interim activities by
PRPs, which cumulatively results in a lengthy RI/FS, and review
at the end of the six major components of the RI/FS, which could
result in months of unacceptable work not detected until late in
the process. It also assures focus on the major deliverables.
In addition, consistent with the RI/FS guidance, some work is
simultaneously done. Under the third category, deliverables do
not require comment from EPA. This category includes PRP
progress reports. A summary of the major deliverables under
categories one and two, as outlined in this model SOW, is
included in the document.
Interim deliverables in addition to those required by the
RI/FS Guidance are described in this model SOW. These
deliverables are appropriate because of the different
relationships and interactions between a Fund-lead and PRP-lead
RI/FS. Review of these deliverables will help to assure EPA that
the work being performed meets the terms and conditions of the
AOC. Those deliverables other than what are required by the
RI/FS Guidance that are described within this model SOW may not
be necessary or appropriate for all sites. Similarly,
deliverables other than what are described in this model SOW may
be more appropriate for a particular site. The deliverables
determined to be appropriate for a particular site should be
approved by EPA management and must be specified in the AOC. The
timing of the RI/FS and available oversight resources should be
considered prior to determining the appropriate deliverables.
Offices within the Region other than Superfund which will concur
or comment on PRP deliverables should be consulted during the
scoping process.
The Remedial Project Manager (RPM) should assure good
communications with the PRPs. This includes meetings to discuss
EPA's expectations before major phases of work are begun and to
review the conclusions of major components of the RI/FS. In
addition, the RPM should assure that EPA management is informed
and has input on major components of the RI/FS. While this
varies from site to site, management review usually is
appropriate at scoping, final review of the work plan, before
final comments are submitted on the RI, and as the FS is finally
developed.
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SUMMARY OF MAJOR DELIVERABLES'
(AS OUTLINED IN THIS MODEL SOW FOR PRP-CONDUCTED RI/FS)
TASK/DELIVERABLE
TASK 1 SCOPING
RI/FS Work Plan
Sampling and
Analysis Plan (SAP)
Site Health and
Saftey Plan
TASK 3 SITE CHARACTERIZATION
Technical Memorandum
on Modeling of Site
Characteristics (where
appropriate)
Preliminary Site
Characterization
Summary
Draft Remedial
Investigation (RI)
Report
TASK 4 BASELINE RISK ASSESSMENT
Technical Memorandum
Listing Hazardous
Substances and
Indicator Chemicals
- Technical Memorandum
Describing Exposure
Scenarios and Fate
and Transport Models
Technical Memorandum
Listing
Toxicological and
'Epidemiological Studies
Plan for Evaluating
Environmental Risk
MANAGEMENT CATEGORY
(1) Review and Approve
(1) Review and Approve
(2) Review and Comment
(2) Review and Approve
(2) Review and Comment
(1) Review and Approve
(2) Review and Approve
(2) Review and Approve
(2) Review and Approve
(2) Review and Approve
See the Model RI/FS Administrative Order on Consent (AOC)
for additional reporting requirements, and further
instructions on submittal and disposition of
deliverables.
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TASK 5
TASK 6
TASK 7
- Environmental
Evaluation Report
(separate from or
included in the Baseline
Risk Assessment)
Baseline Risk
Assessment Chapter
of the RI Report
TREATABILITY STUDIES
- Technical Memorandum
Identifying
Candidate
Technologies
Treatability Testing
Statement of Work
Treatability Testing
Work Plan (or amendment
to original)
- Treatability Study
SAP (or amendment to
original)
Treatability Study
Site Health and
Safety Plan (or
amendment to original)
Treatability Study
Evaluation Report
(2) Review and Approve
(1) Review and Approve
(2) Review and Approve
(2) Review and Comment
(1) Review and Approve
(1) Review and Approve
(2) Review and Comment
(1) Review and Approve
DEVELOPMENT AND SCREENING OF REMEDIAL ALTERNATIVES
(2) Review and Comment
(2) Review and Comment
Technical Memorandum
Documenting Revised
Remedial Action
Objectives
Technical Memorandum
on Remedial
.Technologies,
Alternatives and
Screening
DETAILED ANALYSIS OP REMEDIAL ALTERNATIVES
Technical Memorandum
Summarizing Results of
Comparative Analysis of
Alternatives
Draft Feasibility
Study (FS) Report
(2) Review and Approve
(1) Review and Approve
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9835.8
MODEL STATEMENT OP WORK FOR PRP-CONDUCTED
REMEDIAL INVESTIGATIONS AND FEASIBILITY STUDIES
INTRODUCTION
The purpose of this remedial investigation/feasibility study
(RI/FS) is to investigate the nature and extent of contamination
at a site, assess the potential risk to human health and the
environment, and develop and evaluate potential remedial
alternatives. The RI and FS are interactive and may be conducted
concurrently so that the data collected in the RI influences the
development of remedial alternatives in the FS, which in turn
affects the data needs and the scope of treatability studies.
The respondent will conduct this RI/FS and will produce a
draft RI and FS report that are in accordance with this statement
of work, the Guidance for Conducting Remedial Investigations and
Feasibility Studies Under CERCLA (U.S. EPA, Office of Emergency
and Remedial Response, October 1988), and any other guidances
that EPA uses in conducting a RI/FS (a list of the primary
guidances is attached), as well as any additional requirements in
the administrative order. The RI/FS Guidance describes the
report format and the required report content. The respondent
will furnish all necessary personnel, materials, and services
needed, or incidental to, performing the RI/FS, except as
otherwise specified in the administrative order.
At the completion of the RI/FS, EPA will be responsible for
the selection of a site remedy and will document this selection
in a Record of Decision (ROD). The remedial action alternative
selected by EPA will meet the cleanup standards specified in
CERCLA Section 121. That is, the selected remedial action will
be protective of human health and the environment, will be in
compliance with, or include a waiver of, applicable or relevant
and appropriate requirements of other laws, will be cost-
effective, will utilize permanent solutions and alternative
treatment technologies or resource recovery technologies, to the
maximum extent practicable, and will address the statutory
preference for .treatment as a principal element. The final RI/FS
report, as adopted by EPA, will, with the administrative record,
form the basis for the selection of the site's remedy and will
provide the information necessary to support the development of
the ROD.
As specified in CERCLA Section 104(a)(1), as amended by
SARA, EPA will provide oversight of the respondent's activities
throughout the RI/FS. The respondent will support EPA's
initiation and conduct of activities related to the
implementation of oversight activities.
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9835.8
TASK 1 - SCOPING (RI/F8 Guidance, Chapter 2)
Scoping is the initial planning process of the RI/FS and is
initiated by EPA prior to issuing special notice. During this
time, the site-specific objectives of the RI/FS are determined by
EPA. Scoping is therefore initiated prior to negotiations
between the PRPs and EPA, and is continued, repeated as
necessary, and refined throughout the RI/FS process. In addition
to developing the site specific objectives of the RI/FS, EPA will
determine a general management approach for the site. Consistent
with the general m.; jagement approach, the specific project scope
will be planned by the respondent and EPA. The respondent will
document the specific project scope in a work plan. Because the
work reguired to perform a RI/FS is not fully known at the onset,
and is phased in accordance with a site's complexity and the
amount of available information, it may be necessary to modify
the work plan during the RI/FS to satisfy the objectives of the
study.
The site objectives for the site
located in the State of have been determined
preliminarily, based on available information, to be the
following:
The strategy for the general management of the_
site will include the following:
When scoping the specific aspects of a project, the
respondent must meet with EPA to discuss all project planning
decisions and special concerns associated with the site. The
following activities shall be performed by the respondent as a
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9835.8
function of the project planning process.
a. Site Background (2.2)
The respondent will gather and analyze the existing site
background information and will conduct a site visit to assist in
planning the scope of the RI/FS.
Collect and analyze existing data and document the need for
additional data (2.2.2; 2.2.6; 2.2.7)
Before planning RI/FS activities, all existing site data
will be thoroughly compiled and reviewed by the respondent.
Specifically, this will include presently available data
relating to the varieties and quantities of hazardous
substances at the site, and past disposal practices. This
will also include results from any previous sampling events
that may have been conducted. The respondent will refer to
Table 2-1 of the RI/FS Guidance for a comprehensive list of
data collection information Sources. This information will
be utilized in determining additional data needed to
characterize the site, better define potential applicable or
relevant and appropriate requirements (ARARs), and develop a
range of preliminarily identified remedial alternatives.
data quality objectives (DQOs) will be established subject
to EPA approval which specify the usefulness of existing
data. Decisions on the necessary data and DQOs will be made
by EPA.
Conduct Site Visit
The respondent will conduct a site visit during the project
scoping phase to assist in developing a conceptual
understanding of sources and areas of contamination as well
as potential exposure pathways and receptors at the site.
During the site visit the respondent should observe the
site's physiography, hydrology, geology, and demographics,
as well as natural resource, ecological and cultural
features. This information will be utilized to better scope
the project and to determine the extent of additional data
necessary to characterize the site, better define potential
ARARs, and narrow the range of preliminarily identified
remedial alternatives.
b. Project Planning (2.2)
Once the respondent has collected and analyzed existing data
and conducted a site visit, the specific project scope will be
planned. Project planning activities include those tasks
described below as well as identifying data needs, developing a
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work plan, designing a data collection program, and identifying
health and safety protocols. The respondent will meet with EPA
regarding the following activities and before the drafting of the
scoping deliverables below. These tasks are described in Section
c. of this task since they result in the development of specific
required deliverables.
Refine and document preliminary remedial action objectives
and alternatives (2.2.3)
Once existing site information has been analyzed and a
conceptual understanding of the potential site risks is
reached, the respondent will review and, if necessary,
refine the remedial action objectives that have been
identified by EPA for each actually or potentially
contaminated medium. The revised remedial action objectives
will be documented in a technical memorandum and subject to
EPA approval. The respondent will then identify a
preliminary range of broadly defined potential remedial
action alternatives and associated technologies. The range
of potential alternatives should encompass where
appropriate, alternatives in which treatment significantly
reduces the toxicity, mobility, or volume of the waste;
alternatives that involve containment with little or no
treatment; and a no-action alternative.
Document the need for treatability studies (2.2.4)
If remedial actions involving treatment have been identified
by the respondent or EPA, treatability studies will be
required except where the respondent can demonstrate to
EPA's satisfaction that they are not needed. Where
treatability studies are needed, initial treatability
testing activities (such as research and study design) will
be planned to occur concurrently with site characterization
activities (see Tasks 3 and 5).
Begin preliminary identification of Potential ARARs (2.2.5)
The respondent will conduct a preliminary identification of
potential state and federal ARARs (chemical-specific,
location-specific and action-specific) to assist in the
refinement of remedial action objectives, and the initial
identification of remedial alternatives and ARARs associated
with particular actions. ARAR identification will continue
as site conditions, contaminants, and remedial action
alternatives are better defined.
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c. Scoping Deliverables (2.3)
At the conclusion of the project planning phase, the
respondent will submit a RI/FS work plan, a sampling and analysis
plan, and a site health and safety plan. The RI/FS work plan and
sampling and analysis plan must be reviewed and approved by EPA
prior to the initiation of field activities.
RI/FS Work Plan (2.3.1)
A work plan documenting the decisions and evaluations
completed during the scoping process will be submitted to
EPA for review and approval. The work plan should be
developed in conjunction with the sampling and analysis plan
and the site health and safety plan, although each plan may
be delivered under separate cover. The work plan will
include a comprehensive description of the work to be
performed, including the methodologies to be utilized, as
well as a corresponding schedule for completion. In
addition, the work plan must include the rationale for
performing the required activities.
Specifically, the work plan will present a statement of the
problem(s) and potential problem(s) posed by the site and
the objectives of the RI/FS. Furthermore, the plan will
include a site background summary setting forth the site
description including the geographic location of the site,
and to the extent possible, a description of the site's
physiography, hydrology, geology, demographics, ecological,
cultural and natural resource features; a synopsis of the
site history and a description of previous responses that
have been conducted at the site by local, state, federal, or
private parties; a summary of the existing data in terms of
physical and chemical characteristics of the contaminants
identified, and their distribution among the environmental
media at the site. The plan will also include a conceptual
"model" describing the contaminant sources, and potential
migration and exposure pathways and receptors. In addition,
the plan will include a description of the site management
strategy developed by EPA during scoping; a preliminary
identification of remedial alternatives and data needs for
evaluation of remedial alternatives. The plan will reflect
coordination with treatability study requirements (see Tasks
1 and 5). It will include a process for and manner of
identifying Federal and state ARARs (chemical-specific,
location-specific and action-specific).
Finally, the major part of the work plan is a detailed
description of the tasks to be performed, information needed
for each task (e.g., for health and environmental risk
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9835.8
evaluation), information to be produced during and at the
conclusion of each task, and a description of the work
products that will be submitted to EPA. This includes the
deliverables set forth in the remainder of this statement of
work; a schedule for each of the required activities which
is consistent with the RI/FS guidance; and a project
management plan, including a data management plan (e.g.,
requirements for project mangement systems and software,
minimum data requirements, data format and backup data
management), monthly reports to EPA and meetings and
presentations to EPA at the conclusion of each major phase
of the RI/FS. The respondent will refer to Appendix B of
the RI/FS Guidance for a comprehensive description of the
contents of the required work plan.
Because of the unknown nature of the site and iterative
nature of the RI/FS, additional data requirements and
analyses may be identified throughout the process. The
respondent will submit a technical memorandum documenting
the need for additional data, and identifying the DQOs
whenever such requirements are identified. In any event,
the respondent is responsible for fulfilling additional data
and analysis needs identified by EPA consistent with the
general scope and objectives of this RI/FS.
Sampling and Analysis Plan (2.3.2)
The respondent will prepare a sampling and analysis plan
(SAP) to ensure that sample collection and analytical
activities are conducted in accordance with technically
acceptable protocols and that the data meet DQOs. The SAP
provides a mechanism for planning field activities and
consists of a field sampling plan (FSP) and a quality
assurance project plan (QAPP).
The FSP will define in detail the sampling and data-
gathering methods that will be used on the project. It will
include sampling objectives, sample location and frequency,
sampling equipment and procedures, and sample handling and
analysis. " The QAPP will describe the project objectives and
organization, functional activities, and quality assurance
and quality control (QA/QC) protocols that will be used to
achieve the desired DQOs. The DQOs will at a minimum
reflect use of analytic methods to identifying contamination
and remediating contamination consistent with the levels for
remedial action objectives identified at 40 CFR Part 300,
pages 51425-26 and 51433 (December 21, 1988). In addition,
the QAPP will address sampling procedures, sample custody,
analytical procedures, and data reduction, validation,
reporting and personnel qualifications. Field personnel
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9835.8
should be available for EPA QA/QC training and orientation
where applicable.
The respondent will demonstrate, in advance to EPA's
satisfaction, that each laboratory it may use is qualified
to conduct the proposed work. This includes use of methods
and analytical protocols for the chemicals of concern in the
media of interest within detection and quantification limits
consistent with both QA/QC procedures and DQOs approved in
the QAPP for the site by EPA. The laboratory must have and
follow an approved QA program. If a laboratory not in the
Contract Laboratory Program (CLP) is selected, methods
consistent with CLP methods that would be used at this site
for the purposes proposed and QA/QC procedures approved by
EPA will be used. If the laboratory is not in the CLP
program, a laboratory QA program must be submitted for EPA
review and approval. EPA may require that the respondent
submit detailed information to demonstrate that the
laboratory is qualified to conduct the work, including
information on personnel qualifications, equipment and
material specifications. The respondent will provide
assurances that EPA has access to laboratory personnel,
equipment and records for sample collection, transportation
and analysis.
Site Health and Safety Plan (2.3.3)
A health and safety plan will be prepared in conformance
with the respondent's health and safety program, and in
compliance with OSHA regulations and protocols. The health
and safety plan will include the 11 elements described in
the RI/FS Guidance, such as a health and safety risk
analysis, a description of monitoring and personal
protective equipment, medical monitoring, and site control.
It should be noted that EPA does not "approve" the
respondent's health and safety plan, but rather EPA reviews
it to ensure that all necessary elements are included, and
that the plan provides for the protection of human health
and the environment.
TASK 2 - COMMUNITY RELATIONS
The development and implementation of community relations
activities are the responsibility of EPA. The critical community
relations planning steps performed by EPA include conducting
community interviews and developing a community relations plan.
Although implementation of the community relations plan is the
responsibility of EPA, the respondent may assist by providing
information regarding the site's history, participating in public
meetings, or by preparing fact sheets for distribution to the
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9835.8
general public. In addition, the respondent may establish a
community information repository, at or near the site, to house
one copy of the administrative record. The extent of PRP
involvement in community relations activities is left to the
discretion of EPA. The respondents' community relations
responsibilities, if any, are specified in the community
relations plan. All PRP-conducted community relations activities
will be subject to oversight by EPA.
TASK 3 - SITE CHARACTERIZATION (RI/FS Guidance, Chapter 3)
!,
As part of the RI, the respondent will perform the
activities described in this task, including the preparation of a
site characterization summary and a RI report. The overall
objective of site characterization is to describe areas of a site
that may pose a threat to human health or the environment. This
is accomplished by first determining a site's physiography,
geology, and hydrology. Surface and subsurface pathways of
migration will be defined. The respondent will identify the
sources of contamination and define the nature, extent, and
volume of the sources of contamination, including their physical
and chemical constituents as well as their concentrations at
incremental locations to background in the affected media. The
respondent will also investigate the extent of migration of this
contamination as well as its volume and any changes in its
physical or chemical characteristics, to provide for a
comprehensive understanding of the nature and extent of
contamination at the site. Using this information, contaminant
fate and transport is then determined and projected.
During this phase of the RI/FS, the work plan, SAP, and
health and safety plan are implemented. Field data are collected
and analyzed to provide the information required to accomplish
the objectives of the study. The respondent will notify EPA at
least two weeks in advance of the field work regarding the
planned dates for field activities, including field lay out of
the sampling grid, excavation, installation of wells, initiating
sampling, installation and callibration of equipment, pump tests,
and initiation of analysis and other field investigation
activities. The respondent will demonstrate that the laboratory
and type of laboratory analyses that will be utilized during site
characterization meets the specific QA/QC requirements and the
DQOs of the site investigation as specified in the SAP. In view
of the unknown site conditions, activities are often iterative,
and to satisfy the objectives of the RI/FS it may be necessary
for the respondent to supplement the work specified in the
initial work plan. In addition to the deliverables below, the
respondent will provide a monthly progress report and participate
in meetings at major points in the RI/FS.
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9835.8
a. Field Investigation (3.2)
The field investigation includes the gathering of data to
define site physical characteristics, sources of contamination,
and the nature and extent of contamination at the site. These
activities will be performed by the respondent in accordance'with
the work plan and SAP. At a minimum, this shall address the
following:
Implement and document field support activities (3.2.1)
The respondent will initiate field support activities
following approval of the work plan and SAP. Field support
activities may include obtaining access to the site,
scheduling, and procuring equipment, office space,
laboratory services, and/or contractors. The respondent
will notify EPA at least two weeks prior to initiating field
support activities so that EPA may adequately schedule
oversight tasks. The respondent will also notify EPA in
writing upon completion of field support activities.
Investigate and define site physical characteristics (3.2.2)
The respondent will collect data on the physical
characteristics of the site and its surrounding areas
including the physiography, geology, and hydrology, and
specific physical characteristics identified in the work
plan. This information will be ascertained through a
combination of physical measurements, observations, and
sampling efforts and will be utilized to define potential
transport pathways and receptor populations. In defining
the site's physical characteristics the respondent will also
obtain sufficient engineering data (such as pumping
characteristics) for the projection of contaminant fate and
transport, and development and screening of remedial action
alternatives, including information to assess treatment
technologies.
Define sources of contamination (3.2.3)
The respondent will locate each source of contamination.
For each location, the areal extent and depth of
contamination will be determined by sampling at incremental
depths on a sampling grid. The physical characteristics and
chemical constituents and their concentrations will be
determined for all known and discovered sources of
contamination. The respondent shall conduct sufficient
sampling to define the boundaries of the contaminant sources
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to the level established in the QA/QC plan and DQOs.
Defining the source of contamination will include analyzing
the potential for contaminant release (e.g., long term
leaching from soil), contaminant mobility and persistence,
and characteristics important for evaluating remedial
actions, including information to assess treatment
technologies.
Describe the nature and extent of contamination (3.2.4)
The respondent will gather information to describe the
nature and extent of contamination as a final step during
the field investigation. To describe the nature and extent
of contamination, the respondent will utilize the
information on site physical characteristics and sources of
contamination to give a preliminary estimate of the
contaminants that may have migrated. The respondent will
then implement an iterative monitoring program and any study
program identified in the work plan or SAP such that by
using analytical techniques sufficient to detect and
quantify the concentration of contaminants, the migration of
contaminants through the various media at the site can be
determined. In addition, the respondent will gather data
for calculations of contaminant fate and transport. This
process is continued until the area and depth of
contamination are known to the level of contamination
established in the QA/QC plan and DQOs. Information on the
nature and extent of contamination will be utilized to
determine the level of risk presented by the site and will
help to determine aspects of the appropriate remedial action
alternatives to be evaluated.
b. Data Analyses (3.4)
Evaluate site characteristics (3.4.1)
The respondent will analyze and evaluate the data to
describe: (1) site physical characteristics, (2)
contaminant source characteristics, (3) nature and extent of
contamination, and (4) contaminant fate and transport.
Results of the site physical characteristics, source
characteristics, and extent of contamination analyses are
utilized in the analysis of contaminant fate and transport.
The evaluation will include the actual and potential
magnitude of releases from the sources, and horizontal and
vertical spread of contamination as well as mobility and
persistence of contaminants. Where modeling is appropriate,
such models shall be identified to EPA in a technical
memorandum prior to their use. All data and programming,
including any proprietary programs, shall be made available
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to EPA together wjth a sensitivity analysis. Also, this
evaluation shall provide any information relevant to site
characteristics necessary for evaluation of the need for
remedial action in the risk assessment and for the
development and evaluation of remedial alternatives.
Analyses of data collected for site characterization will
meet the DQOs developed in the QA/QC plan stated in the SAP
(or revised during the RI).
c. Data Management Procedures (3.5)
The respondent will consistently document the quality and
validity of field and laboratory data compiled during the RI.
Document field activities (3.5.1)
Information gathered during site characterization will be
consistently documented and adequately recorded by the
respondent in well maintained field logs and laboratory
reports. The method(s) of documentation must be specified
in the work plan and/or the SAP. Field logs must be
utilized to document observations, measurements, and
significant events that have occurred during field
activities. Laboratory reports must document sample
custody, analytical responsibility, analytical results,
adherence to prescribed protocols, nonconformity events,
corrective measures, and/or data deficiencies.
Maintain sample management and tracking (3.5.2; 3.5.3)
The respondent will maintain field reports, sample shipment
records, analytical results, and QA/QC reports to ensure
that only validated analytical data are reported and
utilized in the development and evaluation of remedial
alternatives. Analytical results developed under the work
plan will not be included in any site characterization
reports unless accompanied by or cross-referenced to a
corresponding QA/QC report. In addition, the respondent
will establish a data security system to safeguard chain-of-
custody forms and other project records to prevent loss,
damage, or alteration of project documentation.
o
d. Site Characterization Deliverables (3.7)
The respondent will prepare the preliminary site
characterization summary and, once the baseline risk assessment
(Task 4) is complete, the remedial investigation report.
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Preliminary Site Characterization Summary (3.7.2)
After completing field sampling and analysis, the respondent
will prepare a concise site characterization summary. This
summary will review the investigative activities that have
taken place; describe and display site data documenting the
location and characteristics of surface and subsurface
features and contamination at the site including the
affected medium location, types, physical state,
concentration of contaminants and quantity. In addition,
the location, dimensions, physical condition and varying
concentrations of each contaminant throughout each source
and the extent of contaminant migration through each of the
affected media will be documented. The site
characterization summary will provide EPA with a preliminary
reference for developing the risk assessment, and evaluating
the development and screening of remedial alternatives and
the refinement and identification of ARARs.
Remedial Investigation (RI) Report (3.7.3)
The respondent will prepare and submit a draft RI report to
EPA for review and approval after completion of the baseline
risk assessment (see Task 4). This report shall summarize
results of field activities to characterize the site,
sources of contamination, nature and extent of
contamination, the fate and transport of contaminants, and
results of the baseline risk assessment. The respondent
will refer to the RI/FS Guidance for an outline of the
report format and contents. Following comment by EPA, the
respondent will prepare a final RI report which
satisfactorily addresses EPA's comments.
TASK 4 - BASELINE RISK ASSESSMENT (3.4.2)
A baseline risk assessment will identify and characterize
the toxicity and levels of hazardous substances present,
contaminant fate and transport, the potential for human or
environmental exposure, or both, and the risk of potential
impacts or thre'ats on human health and the environment. It will
provide the basis for determining whether or not remedial action
is necessary, and a justification for performing remedial
actions. The procedures to perform a baseline risk assessment
for human health are outlined in EPA's Superfund Public Health
Evaluation Manual (SPHEM). These procedures are outlined below
and must be followed by the respondent. Other resources that the
respondent must utilize when performing the baseline risk
assessment include: EPA's Superfund Exposure Assessment Manual
(SEAM), the Integrated Risk Information System (IRIS), the Public
Health Risk Evaluation Database (PHRED), and the Interim Final
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9835.8
Risk Assessment Guidance for Superfund - Environmental Evaluation
Manual.
a. Human Health and Risk Assessment Components
The risk assessment process is divided into the four
components listed below. During the scoping of the risk
assessment, the respondent will discuss with EPA the format of
the risk assessment report as well as the references to be
utilized during the baseline risk assessment.
Contaminant identification and documentation
The respondent will review the information that is available
on the hazardous substances present at the site and will
identify the contaminants of concern. The indicator
chemicals, or contaminants of concern, are not chosen solely
on the basis of chemical-specific ARARs. Rather, they are
selected based on quantity, the concentration of
contaminants on site as compared to levels that pose a risk,
or critical exposure pathways, such as drinking water. When
selecting the indicator chemicals, the respondent must also
consider the additive effect of risks. The respondent shall
submit to EPA for review and approval a technical memorandum
listing the hazardous substances present at the site and the
indicator chemicals with the known corresponding ambient
concentrations of these contaminants. Chemical-specific
ARARs should also be identified at this time.
Exposure assessment and documentation
Using the information in the SEAM, the respondent will
identify actual and potential exposure points and pathways.
Exposure assumptions must be supported with validated data
and must be consistent with Agency policy. Validation of
data that has not previously undergone Agency review may be
performed as long as it does not delay the RI/FS schedule.
For each exposure point, the release source, the transport
media (e.g., ground water, surface water, air) and the
exposure r~oute (oral, inhalation, dermal) must be clearly
delineated. The current number of people at each exposure
point must be estimated and, both sensitive and potentially
exposed populations must be characterized. Both present and
future risks at the site must be considered, and both
current and maximum reasonable use scenarios must be
considered. The respondent will submit to EPA for review
and approval a technical memorandum describing the exposure
scenarios with a description of the assumptions made and the
use of data. In addition, the respondent will submit to EPA
for review and approval a description of the fate and
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9835.8
transport models that will be utilized, including a summary
of the data that will be used with these models.
Representative data must be utilized and the limitations and
uncertainties with the models must be documented.
Toxicitv assessment and documentation
The respondent will utilize the information in IRIS to
provide a toxicity assessment of the indicator chemicals.
This assessment will include the types of adverse health
and/or environmental effects associated with chemical
exposures (including potential carcinogenicity), the
relationships between magnitude of exposures and adverse
effects, and the related uncertainties for contaminant
toxicity (e.g., the weight of evidence for a chemical's
carcinogenicity). For those substances lacking an EPA
toxicity value for which the respondent wishes to develop
its own toxicity value, the respondent will submit to EPA
for review and approval a technical memorandum listing the
toxicological and epidemiological studies that will be
utilized to perform the toxicity assessment. All data
utilized in the toxicity assessment must be validated and
have gone through EPA review. Validation of data that has
not previously undergone Agency review may be performed as
long as it does not delay the RI/FS schedule.
Risk characterization
The respondent will integrate the ambient concentrations and
reasonable worst case assumptions with the information
developed during the exposure and toxicity assessments, to
characterize the current and potential risk to human health
and the environment posed by the site. This risk
characterization must identify any uncertainties associated
with contaminants, toxicities, and/or exposure assumptions.
b. Baseline Risk Assessment Deliverables
The respondent is required to prepare the technical
memoranda liste'd in Item a of Task 4 of this SOW. The final risk
assessment report is submitted at the completion of site
characterization with the draft Rl report (see Task 3).
Baseline Risk Assessment Chapter of the RI Report
The baseline risk assessment report will be submitted to EPA
for review and approval. The report will include a
comprehensive description of the four components of the risk
assessment and will follow the principles established in the
SPHEM. A discussion of sources of uncertainty, data gaps,
14
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9835.8
incomplete toxicity information, and modeling
characteristics must be included. The respondent will refer
to the SPHEM for an outline of the report format.
c. Environmental Evaluation and Deliverables
In addition to the human health risk assessment, the risks
to the environment from exposure to the contaminants must be
addressed.
Environmental Evaluation Plan
The respondent will submit for EPA's review and approval a
plan for the evaluation of the environmental risk. This
plan must specify the objectives of the evaluation and the
information necessary to adequately characterize the nature
and extent of environmental risk or threat resulting from
the site. At a minimum, this plan must demonstrate how the
environmental evaluation will address: (1) any critical
habitats affected by site contamination; and (2) any
endangered species or habitats of endangered species
affected by the contamination. The respondent will utilize
the Interim Final Risk Assessment Guidance for Superfund -
Environmental Evaluation Manual.
Environmental Evaluation Report
The environmental evaluation report will be submitted to EPA
for review and approval. This evaluation may be included in
the baseline risk assessment report or as a document
separate from the human health risk assessment. At a
minimum, the environmental evaluation report will include an
assessment of any critical habitats, and any endangered
species or habitats of endangered species affected by the
contamination at the site.
TASK 5 - TREATABILITY STUDIES (RZ/FS Manual, Chapter 5)
Treatability testing will be performed by the respondent to
assist in the d'etailed analysis of alternatives. In addition, if
applicable, testing results and operating conditions will be used
in the detailed design of the selected remedial technology. The
following activities will be performed by the respondent.
a. Determination of Candidate Technologies and of the Need for
Testing (5.2; 5.4)
The respondent will identify in a technical memorandum,
subject to EPA review and approval, candidate technologies for a
treatability studies program during project planning (Task 1).
15
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9835.8
The listing of candidate technologies will cover the range of
technologies required for alternatives analysis (Task 6 a.) The
specific data requirements for the testing program will be
determined and refined during site characterization and the
development and screening of remedial alternatives (Tasks 2 and
6, respectively).
Conduct literature survey and determine the need for
treatability testing (5.2)
The respondent will conduct a literature survey to gather
information on performance, relative costs, applicability,
removal efficiencies, operation and maintenance (O&M)
requirements, and implementability of candidate
technologies. If practical candidate technologies have not
been sufficiently demonstrated, or cannot be adequately
evaluated for this site on the basis of available
information, treatability testing will be conducted. Where
it is determined by EPA that treatability testing is
required, and unless the respondent can demonstrate to EPA's
satisfaction that they are not needed, the respondent will
submit a statement of work to EPA outlining the steps and
data necessary to evaluate and initiate the treatability
testing program.
Evaluate treatability studies (5.4)
Once a decision has been made to perform treatability
studies, the respondent and EPA will decide on the type of
treatability testing to use (e.g., bench versus pilot).
Because of the time required to design, fabricate, and
install pilot scale equipment as well as perform testing for
various operating conditions, the decision to perform pilot
testing should be made as early in the process as possible
to minimize potential delays of the FS. To assure that a
treatability testing program is completed on time, and with
accurate results, the respondent will either submit a
separate treatability testing work plan or an amendment to
the original site work plan for EPA review and approval.
b. Treatability Testing and Deliverables (5.5; 5.6; 5.8)
The deliverables that are required, in addition to the
memorandum identifying candidate technologies, where treatability
testing is conducted include a work plan, a sampling and analysis
plan, and a final treatability evaluation report. EPA may also
require a treatability study health and safety plan, where
appropriate.
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9835.8
Treatabilitv testing work plan (5.5)
The respondent will prepare a treatability testing work plan
or amendment to the orignal site work plan for EPA review
and approval describing the site background, remedial
technology(ies) to be tested, test objectives, experimental
procedures, treatability conditions to be tested,
measurements of performance, analytical methods, data
management and analysis, health and safety, and residual
waste management. The DQOs for treatability testing should
be documented as well. If pilot-scale treatability testing
is to be performed, the pilot-scale work plan will describe
pilot plant installation and start-up, pilot plant operation
and maintenance procedures, operating conditions to be
tested, a sampling plan to determine pilot plant
performance, and a detailed health and safety plan. If
testing is to be performed off-site, permitting requirements
will be addressed.
Treatabilitv study SAP (5.5)
If the original QAPP or FSP is not adequate for defining the
activities to be performed during the treatability tests, a
separate treatability study SAP or amendment to the original
site SAP will be prepared by the respondent for EPA review
and approval. Task 1, Item c. of this statement of work
provides additional information on the requirements of the
SAP.
Treatabilitv study health and safety plan (5.5)
If the original health and safety plan is not adequate for
defining the activities to be performed during the treatment
tests, a separate or amended health and safety plan will be
developed by the respondent. Task 1, Item c. of this
statement of work provides additional information on the
requirements of the health and safety plan. EPA does not
"approve" the treatability study health and safety plan.
Treatabili'tv study evaluation report (5.6)
Following completion of treatability testing, the respondent
will analyze and interpret the testing results in a
technical report to EPA. Depending on the sequence of
activities, this report may be a part of the RI/FS report or
a separate deliverable. The report will evaluate each
technology's effectiveness, implementability, cost and
actual results as compared with predicted results. The
report will also evaluate full-scale application of the
technology, including a sensitivity analysis identifying the
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9835.8
key parameters affecting full-scale operation.
TASK 6 - DEVELOPMENT AND SCREENING OF REMEDIAL ALTERNATIVES
(RI/FS Manual, Chapter 4)
The development and screening of remedial alternatives is
performed to develop an appropriate range of waste management
options that will be evaluated. This range of alternatives
should include as appropriate, options in which treatment is used
to reduce the toxicity, mobility, or volume of wastes, but
varying in the types of treatment, the amount treated, and the
manner in which long-term residuals or untreated wastes are
managed; options involving containment with little or no
treatment; options involving both treatment and containment; and
a no-action alternative. The following activities will be
performed by the respondent as a function of the development and
screening of remedial alternatives.
a. Development and Screening of Remedial Alternatives (4.2)
The respondent will begin to develop and evaluate a range of
appropriate waste management options that at a minimum ensure
protection of human health and the environment, concurrent with
the RI site characterization task.
Refine and document remedial action objectives (4.2.1)
The respondent will review and if necessary propose
refinement to the site-specific remedial action objectives
that were established by EPA prior to negotiations between
EPA and the respondent. The revised remedial action
objectives will be documented in a technical memorandum.
These objectives will specify the contaminants and media of
interest, exposure pathways and receptors, and an acceptable
contaminant level or range of levels for each exposure
route.
Develop general response actions (4.2.2)
The respondent will develop general response actions for
each medium of interest defining containment, treatment,
excavation, pumping, or other actions, singly or in
combination, to satisfy the remedial action objectives.
Identify areas or volumes of media (4.2.3)
The respondent will identify areas or volumes of media to
which general response actions may apply, taking into
account requirements for protectiveness as identified in the
remedial action objectives. The chemical and physical
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9835.8
characterization of the site will also be taken into
account.
Identify, screen, and document remedial technologies (4.2.4;
4.2.5)
The respondent will identify and evaluate technologies
applicable to each general response action to eliminate
those that cannot be implemented at the site. General
response actions will be refined to specify remedial
technology types. Technology process options for each of
the technology types will be identified either concurrent
with the identification of technology types, or following
the screening of the considered technology types. Process
options will be evaluated on the basis of effectiveness,
implementability, and cost factors to select and retain one
or, if necessary, more representative process for each
technology type. The technology types and process options
will be summarized for inclusion in a technical memorandum.
The reasons for eliminating alternatives must be specified.
Assemble and document alternatives (4.2.6)
The respondent will assemble selected representative
technologies into alternatives for each affected medium or
operable unit. Together, all of the alternatives will
represent a range of treatment and containment combinations
that will address either the site or the operable unit as a
whole. A summary of the assembled alternatives and their
related action-specific ARARs will be prepared by the
respondent for inclusion in a technical memorandum. The
reasons for eliminating alternatives during the preliminary
screening process must be specified.
Refine alternatives
The respondent will refine the remedial alternatives to
identify contaminant volume addressed by the proposed
process and sizing of critical unit operations as necessary.
Sufficient information will be collected for an adequate
comparison of alternatives. Remedial action objectives for
each medium will also be refined as necessary to incorporate
any new risk assessment information being generated from the
remedial investigation. Additionally, action-specific ARARs
will be updated as the remedial alternatives are refined.
Conduct and document screening evaluation of each
alternative (4.3)
The respondent may perform a final screening process based
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9835.8
on short and long term aspects of effectiveness,
implementability, and relative cost. Generally, this
screening process is only necessary when there are many
feasible alternatives available for detailed analysis. If
necessary, the screening of alternatives will be conducted
to assure that only the alternatives with the most favorable
composite evaluation of all factors are retained for further
analysis.
As appropriate, the screening will preserve the range of
treatment and containment alternatives that was initially
developed. Tne range of remaining alternatives will include
options that use treatment technologies and permanent
solutions to the maximum extent practicable. The respondent
will prepare a technical memorandum summarizing the results
and reasoning employed in screening, arraying alternatives
that remain after screening, and identifying the action-
specific ARARs for the alternatives that remain after
screening.
b. Alternatives Development and Screening Deliverables (4.5)
The respondent will prepare a technical memorandum
summarizing the work performed in and the results of each task
above, including an alternatives array summary. These will be
modified by the respondent if required by EPA's comments to
assure identification of a complete and appropriate range of
viable alternatives to be considered in the detailed analysis.
This deliverable will document the methods, rationale, and
results of the alternatives screening process.
TASK 7 - DETAILED ANALYSIS OF REMEDIAL ALTERNATIVES (RI/FS
Guidance, Chapter 6)
The detailed analysis will be conducted by the respondent to
provide EPA with the information needed to allow for the
selection of a site remedy. This analysis is the final task to
be performed by the respondent during the FS.
a. Detailed Analysis of Alternatives (6.2)
The respondent will conduct a detailed analysis of
alternatives which will consist of an analysis of each option
against a set of nine evaluation criteria and a comparative
analysis of all options using the same evaluation criteria as a
basis for comparison.
Apply nine criteria and document analysis (6.2.1 - 6.2.4)
The respondent will apply nine evaluation criteria to the
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9835.8
assembled remedial alternatives to ensure that the selected
remedial alternative will be protective of human health and
the environment; will be in compliance with, or include a
waiver of, ARARs; will be cost-effective; will utilize
permanent solutions and alternative treatment technologies,
or resource recovery technologies, to the maximum extent
practicable; and will address the statuory preference for
treatment as a principal element. The evaluation criteria
include: (1) overall protection of human health and the
environment; (2) compliance with ARARs; (3) long-term
effectiveness and permanence; (4) reduction of toxicity,
mobility, or volume; (5) short-term effectiveness; (6)
implementability; (7) cost; (8) state (or support agency)
acceptance; and (9) community acceptance. (Note: criteria 8
and 9 are considered after the RI/FS report has been
released to the general public.) For each alternative, the
respondent should provide: (1) a description of the
alternative that outlines the waste management strategy
involved and identifies the key ARARs associated with each
alternative, and (2) a discussion of the individual
criterion assessment. If the respondent does not have
direct input on criteria (8) state (or support agency)
acceptance and (9) community acceptance, these will be
addressed by EPA.
Compare alternatives against each other and document the
comparison of alternatives (6.2.5; 6.2.6)
The respondent will perform a comparative analysis between
the remedial alternatives. That is, each alternative will
be compared against the others using the evaluation criteria
as a basis of comparison. Identification and selection of
the preferred alternative are reserved by EPA. The
respondent will prepare a technical memorandum summarizing
the results of the comparative analysis.
b. Detailed Analysis Deliverables (6.5)
In addition to the technical memorandum summarizing the
results of the'comparative analysis, the respondent will submit a
draft FS report to EPA for review and approval. Once EPA's
comments have been addressed by the respondent to EPA's
satisfaction, the final FS report may be bound with the final RI
report.
Feasibility study report (6.5)
The respondent will prepare a draft FS report for EPA review
and comment. This report, as ultimately adopted or amended
by EPA, provides a basis for remedy selection by EPA and
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documents the development and analysis of remedial
alternatives. The respondent will refer to the RI/FS
Guidance for an outline of the report format and the
required report content. The respondent will prepare a
final FS report which satisfactorily addresses EPA's
comments.
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REFERENCES FOR CITATION
The following list, although not comprehensive, comprises
many of the regulations and guidance documents that apply to the
RI/FS process:
The (revised) National Contingency Plan
"Guidance for Conducting Remedial Investigations and Feasibility
Studies Under CERCLA," U.S. EPA, Office of Emergency and Remedial
Response, October 1988, OSWER Directive No. 9355.3-01.
"Interim Guidance on Potentially Responsible Party Participation
in Remedial Investigation and Feasibility Studies," U.S. EPA,
Office of Waste Programs Enforcement, Appendix A to OSWER
Directive No. 9355.3-01.
"Guidance on Oversight of Potentially Responsible Party Remedial
Investigations and Feasibility Studies," U.S. EPA, Office of
Waste Programs Enforcement, (forthcoming), OSWER Directive No.
9835.3.
"A Compendium of Superfund Field Operations Methods," Two
Volumes, U.S. EPA, Office of Emergency and Remedial Response,
EPA/540/P-87/001a, August 1987, OSWER Directive No. 9355.0-14.
"EPA NEIC Policies and Procedures Manua," May 1978, revised
November 1984, EPA-330/9-78-001-R.
"Data Quality Objectives for Remedial Response Activities," U.S.
EPA, Office of Emergency and Remedial Response and Office of
Waste Programs Enforcement, EPA/540/G-87/003, March 1987, OSWER
Directive No. 9335.0-7B.
"Guidelines and Specifications for Preparing Quality Assurance
Project Plans," U.S. EPA, Office of Research and Development,
Cincinnati, OH, QAMS-004/80, December 29, 1980.
"Interim Guidelines and Specifications for Preparing Quality
Assurance Project Plans," U.S. EPA, Office of Emergency and
Remedial Response, QAMS-005/80, December 1980.
"Users Guide to the EPA Contract Laboratory Program," U.S. EPA,
Sample Management Office, August 1982.
"Interim Guidance on Compliance with Applicable or Relevant and
Appropriate Requirements," U.S. EPA, Office of Emergency and
Remedial Response, July 9, 1987, OSWER Directive No. 9234.0-05.
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"CERCLA Compliance with Other Laws Manual," Two Volumes, U.S.
EPA, Office of Emergency and Remedial Response, August 1988
(draft), OSWER Directive No. 9234.1-01 and -02.
"Guidance on Remedial Actions for Contaminated Ground Water at
Superfund Sites," U.S. EPA, Office of Emergency and Remedial
Response, (draft), OSWER Directive No. 9283.1-2.
"Draft Guidance on Preparing Superfund Decision Documents," U.S.
EPA, Office of Emergency and Remedial Response, March 1988, OSWER
Directive No. 9355.3-02
"Superfund Public Health Evaluation Manual," U.S. EPA, Office of
Emergency and Remedial Response, EPA/540/1-86/060, October 1986,
OSWER Directive No. 9285.4-1.
"Superfund Exposure Assessment Manual," U.S. EPA, Office of
Emergency and Remedial Response, September 22, 1987, OSWER
Directive No. 9285.5-1.
"Interim Final Risk Assessment Guidance for Superfund -
Environmental Evaluation Manual," U.S. EPA, Office of Emergency
and Remedial Response, March 1989, OSWER Directive No. 9285.7-01.
"Health and Safety Requirements of Employees Employed in Field
Activities," U.S. EPA, Office of Emergency and Remedial Response,
July 12, 1981, EPA Order No. 1440.2.
OSHA Regulations in 29 CFR 1910.120 (Federal Register 45654,
December 19, 1986).
"Interim Guidance on Administrative Records for Selection of
CERCLA Response Actions," U.S. EPA, Office of Waste Programs
Enforcement, March 1, 1989, OSWER Directive No. 9833.3A.
"Community Relations in Superfund: A Handbook," U.S. EPA, Office
of Emergency and Remedial Response, June 1988, OSWER Directive
No. 9230.0-3B.
"Community Relations During Enforcement Activities And
Development of the Administrative Record," U.S. EPA, Office of
Waste Programs Enforcement, November 1988, OSWER Directive No.
9836.0-1A.
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