ircat'va 9355.3-0.1
GUIDANCE FOR CONDUCTING
REMEDIAL INVESTIGATIONS AND FEASIBILITY STUDIES
UNDER CERCLA
Hazardous Waste
Office of Emergency and Collection
Remedial Response
Office of Solid Waste and
Emergency Response
United States
Environmental Protection Agency
Draft
March 1988
••••NOTICE----
This draft is intended for internal agency review only. It
has not been formally released by the U. S. Environmental
Protection Agency and should not at this stage be construed
to represent agency policy.
• This document may not be cited or its contents quoted
O • K.. -to )O&JA tUtf 0:ziiifcv"n/iflA f)
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OSWER Directive 9355.3-61
DRAFT
GUIDANCE FOR CONDUCTING
REMEDIAL INVESTIGATIONS AND FEASIBILITY STUDIES
UNDER CERCLA
This guidance was produced to assist Regional and State remedial
personnel, contractors and other parties involved in conducting
remedial investigations and feasibility studies and is reflective,
to the extent possible, of the revisions currently being made to
the National Contingency Plan (NCP). This guidance, however,
does not currently address procedures for non-final remedial
actions, which are part of the current revisions to the NCP.
Guidance for initiating non-final actions will be addressed
through a separate guidance or will be incorporated into the
forthcoming revisions to this guidance.
Review Draft
March 1988
Office of Emergency and Remedial Response
U.S. Environmental Protection Agency
Washington, D. C. 20460
Prepared Under Contract 68-01-7090
This review draft is intended for internal agency review only. It has not been formally
relased by the U.S. Environmental Protection Agency and should not at this stage be
construed to represent agency policy.
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CHAPTER 1
INTRODUCTION
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OSWER Directive 9355.3-01
CONTENTS
Chapter
Glossary
Introduction
1.1 Purpose and Objectives
1.2 Overview of CERCLA Reauthorization
1.3 The RI/FS Process Under CERCLA
1.4 Special Sites
1.5 Community Relations
1.6 Lead and Support Agency
1.7 RPM Role and Responsibilities
Scoping the RI/FS
2.1 Introduction
2.2 Site Planning
2.3 Project Planning
2.4 Deliverables and Communication
Site Characterization
3.1 Introduction
3.2 Field Investigation Methods
3.3 Laboratory Analyses
3.4 Data Analyses
3.5 Data Management Procedures
3.6 Community Relations Activities
During Site Characterization
3.7 Reporting and Communication During Site
Characterization
Development of Alternatives
4.1 Introduction
4.2 Alternative Development Process
4.3 Community Relations During
Alternative Development
4.4 Reporting and Communication During
Alternative Development
Screening of Alternatives
5.1 Introduction
5.2 Alternatives Screening Process
5.3 Community Relations During Alternative
Screening
5.4 Reporting and Communication During Alternative
Screening
Treatability Investigations
6.1 Introduction
6.2 Determination of Data Requirements
6.3 Treatability Testing
6.4 Bench Versus Pilot Testing
6.5 Treatability Test Work Plan
6.6 Application of Results
6.7 Community Relation During Treatability
Investigations
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CONTENTS
Chapter
OSWER Directive 9355.3-01
Page
6.8 Reporting and Communication During
Treatability Investigations 6-26
Detailed Analysis of Alternatives 7-1
7.1 Introduction 7-1
7.2 Detailed Analysis of Alternatives 7-4
7.3 Post-RI/FS Selection of the Preferred
Alternative 7-36
7.4 Community Relations During Detailed
Analysis 7-36
7.5 Reporting ani Communication During
Detailed Analysis 7-37
Appendixes
A Interim Guidance on PRP Participation in the
RI/FS Process A-l
B Elements of RI/FS Project Plans B-l
C Bibliography of Technology Process Resource Documents C-l
D Documentation of ARARS D-l
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OSWER Directive 9355.3-01
Tables
2-1 Data Collection Information Sources 2-9
2-2 Communication and Deliverables
Required During Scoping 2-23
2-3 Suggested RI/FS Work Plan Format 2-29
2-4 Suggested Format for SAP (QAPP and FSP) 2-32
3-1 Relationship Among Site Characterization Tasks
and the Compendium 3-5
3-2 Summary of Site Geology 3-9
3-3 Summary of Soil and Vadose Zone Information 3-11
3-4 Summary of Surface-water Information That
May Be Important to Site Characterization 3-12
3-5 Aspects of Site Hydrogeology 3-14
3-6 Features of Ground-water Systems 3-15
3-7 Summary of Important Ground-water Information 3-16
3-8 Summary of Important Atmospheric Information 3-18
3-9 Summary of Important Ecological Information 3-21
3-10 Summary of Important Source Information 3-23
3-11 Outline of Suggested File Structure for
Superfund Sites 3-48
3-12 Reporting and Communication During Site
Characterization 3-51
3-13 Suggested RI Report Format 3-55
4-1 Typical Remedial Action Objectives/ General
Response Actions, Technology Types, and
Example Process Options for the Development
and Screening of Technologies 4-12
4-2 Reporting and Communication During Detailed
Analysis 4-33
5-1 Reporting and Communication During Screening 5-18
6-1 Typical Data Requirements for Remediation
Technologies 6-5
6-2 Bench and Pilot Study Parameters 6-14
6-3 Examples of Bench- and Pilot-scale Testing Programs 6-15
6-4 Data Quality for Treatability Investigations 6-18
6-5 Suggested Format for Bench-scale Work Plan 6-20
6-6 Suggested Format for Pilot-scale Work Plan 6-23
6-7 Reporting and Communication During Treatability
Investigations 6-27
7-1 Factors for Detailed Analysis of Alternatives 7-10
7-2 Short-term Effectiveness 7-13
7-3 Long-term Effectiveness and Permanence 7-15
7-4 Reduction of Toxicity, Mobility, or Volume 7-17
7-5 Implementability 7-19
7-6 Suggested Format for Summarizing Alternatives
Analysis 7-32
7-7 Suggested FS Report Format 7-38
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OSWER Directive 9355.3-01
Figures
1-1 Phased RI/FS Process 1-8
1-2 Generic Phased RI/FS Timeline 1-9
2-1 Scoping 2-3
2-2 Example Conceptual Site Model 2-12
2-3 Summary of Analytical Levels Appropriate to
Data Uses 2-18
2-4 Relationship of RI/FS Tasks to Phased RI/FS Approach 2-26
3-1 Major Components of Site Characterization 3-2
3-2 Representation of the Extent of Contamination 3-33
3-3 Components of the Risk Assessment Process 3-38
3-4 Identification of Exposure Pathways 3-40
4-1 Alternative Development 4-3
4-2 Generic Alternative Development Process 4-6
4-3 Conceptual Treatment Range for Source Control 4-9
4-4A Potential General Response Scenarios for an
Area With Homogeneously Distributed
Contamination 4-20
4-4B Potential General Response Scenarios for an
Area With Unevenly Distributed Contamination 4-20
4-5 An Example of Initial Screening of Technologies
and Process Options 4-22
4-6 An Example of the Evaluation of Process Options 4-25
4-7 Assembling a Range of Alternative Examples 4-30
5-1 Screening of Alternatives . 5-5
5-2 Time to Achieve 10 to 10 Risk Level
for Single-contaminant for Ground-water
Cleanup Under Various Soil Removal Alternatives 5-7
6-1 Treatability Investigations 6-3
7-1 Detailed Analysis of Alternatives 7-5
WDR260/005
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OSWER Directive 9355.3-01
GLOSSARY
ARAR - applicable or relevant and appropriate requirements
ATSDR - Agency for Toxic Substance and Disease Registry: A branch of
the Centers for Disease Control that is responsible for preparing health
assessments at sites.
Bench scale - Treatability tests performed on a small scale, usually in
a laboratory, to better define parameters of a treatment technology.
CAA - Clean Air Act
CERCLA - Comprehensive Environmental Response, Compensation, and
Liability Act of 1980, also known as Superfund: Amended in 1986 by the
Superfund Amendments and Reauthorization Act (SARA).
CLP - Contract Laboratory Program
CRL - central regional laboratory
CRP - community relations plan
CWA - Clean Water Act
DQO - data quality objectives: Statements that specify the data needed
to support decisions regarding remedial response activities.
EMSL - environmental monitoring support laboratory
ERA - expedited response action
Excess lifetime cancer risk - The potential for carcinogenic effects
from exposure to one or more chemicals.
FIT - field investigation team
PS - feasibility study
FSP - field sampling plan: Defines in detail the sampling and data
gathering activities to be used at a site. (See SAP.)
General response action - General types of actions, such as containment,
that may be taken to achieve exposure limits specified by remedial
action objectives.
Health assessment - Assessment of existing risk to human health posed by
NPL sites, prepared by the ATSDR.
Innovative technologies - Technologies that are fully developed but lack
sufficient cost or performance data for routine use at CERCLA sites.
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OSWER Directive 9355.3-01
Lead agency - The agency, either the EPA, Federal agency, or appropriate
State agency having primary responsibility and authority for planning
and executing the remediation at a site.
MCL - maximum contaminant level: Established under the Safe Drinking
Hater Act.
MCLG - maximum contaminant level goal: Established under the Safe
Drinking Water Act.
MPRSA - Marine Protection Research and Sanctuaries Act
NAAQS - National Ambient Air Quality Standards
NATURAL Resource Trustee -
NPL - National Priorities List: A list of sites identified for
remediation under CERCLA.
NCP - National Oil and Hazardous Substances Contingency Plan
NEPA - National Environmental Policy Act
NIOSH - National Institute foi Occupational Safety and Health
NPDES - National Pollutant Discharge Elimination System
O&M - operation and maintenance
OSHA - Occupational Safety and Health Administration
OSWER - Office of Solid Waste and Emergency Response
Operable unit - A discrete action that comprises an incremental step(s)
toward a final remedy. Operable units may address geographic portions
of a site, specific site problems, or this initial phase of an action.
Pilot scale - Treatability tests performed on a large scale to simulate
the physical, as well as chemical, parameters of a process.
g* - cancer potency factor: The lifetime cancer risk for each
additional mgAg body weight per day of exposure.
Present worth analysis - A summary of costs to be incurred over a period
of time, discounted to the present.
PRP - potentially responsible party
QAPP - quality assurance project plan: A plan that describes protocols
necessary to achieve the data quality objectives defined for an RI.
(See SAP.)
RAS - routine analytical services
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OSWER Directive 9355.3-01
RCRA - Resource Conservation and Recovery Act
RD - remedial design
Reference dose (RfD) - For noncarcinogenic effects, the amount of a
chemical that can be taken into the body each day over a lifetime
without causing adverse effects.
Remedial action alternative - A potential approach to preventing or
mitigating site-specific contamination problems, defined in terms of a
remedial action technology option or combination of options and the
volumes or areas of media to which the option or options will be
applied.
Remedial action objective - A description of remedial goals for each
medium of concern at a site; expressed in terms of the contamination of
concern exposure route(s) and receptor(s), and maximum acceptable
exposure level(s).
Remedial action technology type (or technology type) - A general
category encompassing a number of remedial action technology options
that address a similar problem (e.g., capping, containment barriers,
chemical treatment).
Remedial action technology process option (or process option) - A
specific process, system, or action that may be used to clean up or
mitigate contaminant problems (e.g., clay cap, slurry wall,
neutralization).
RfD - reference dose
RI/FS - remedial investigation/feasibility study
ROD - Record of Decision: Documents selection of cost-effective
Superfund-financed remedy.
RPM - Remedial Project Manager: The project manager for the lead
Federal agency.
SAP - sampling and analysis plan, consisting of a quality assurance
project plan (QAPP) and a field sampling plan (FSP).
SARA - Superfund Amendments and Reauthorization Act of 1986. (See
CERCLA.)
SAS - special analytical services
SDWA - Safe Drinking Water Act
Sensitivity analysis - A test of a procedure to determine the overall
changes that will result from any small change in one or more procedural
elements.
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OSWER Directive 9355.3-01
SITE - Superfund innovative technology evaluation
Support Agency - The agency, either the Federal EPA or the State agency,
responsible for review and concurrence in developing and selecting a
remedy at a CERCLA site.
SWDA - Solid Waste Disposal Act
TAT - technical assistance team
TCL - target compound list
Technology process option - See remedial action technology process
option.
Technology type - See remedial action technology type.
TSCA - Toxic Substances Control Act
Treatability studies - Studies performed to better define the physical
and chemical parameters of technology process options being evaluated.
WDR281/040
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OSWER Directive 9355.3-01
CHAPTER 1
INTRODUCTION
1.1 PURPOSE AND OBJECTIVES
This guidance document is a revision of the Environmental Protection
Agency's (EPA) "Guidance on Remedial Investigations Under CERCLA" (May 1985)
and "Guidance on Feasibility Studies Under CERCLA" (April 1985). These
guidances have been consolidated into a single document and revised to
(1) reflect new emphasis and provisions of the Superfund Amendments and
Reauthorization Act (SARA), (2) incorporate aspects of new or revised
guidance related to remedial investigations and feasibility studies
(RI/FSs), (3) incorporate management initiatives designed to streamline the
RI/FS process, and (4) reflect experience from previous RI/FS projects.
The purpose of this guidance is to provide the user with an overall
understanding of the RI/FS process. Potential users include EPA personnel,
State agencies responsible for coordinating or directing activities at
National Priorities List (NPL) sites, potentially responsible parties
(PRPs), Federal facility coordinators, and consultants or companies con-
tracted to assist in RI/FS-related activities at NPL sites. This guidance
describes the general procedures for conducting an RI/FS. Where specific
guidance is currently available elsewhere, the RI/FS guidance will simply
highlight the key points or concepts as they relate to the RI/FS process and
refer the user to the other sources for additional details.
The Agency's experience to date in the Superfund program has clearly
shown that there is a need for flexibility in the RI/FS process, and that
the wide variety of Superfund sites requires that the process be tailored to
meet site-specific needs. For example, large, complex sites will generally
require a greater level of effort with intermediate deliverables necessary
for each phase of the RI/FS process, whereas less complicated sites may not.
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OSWER Directive 9355.3-01
Therefore, the lead agency's remedial project manager and the RI/FS
contractor must thoroughly consider the site conditions, scheduling
constraints, budget limitations, and support agency input, when developing
site-specific work plans to ensure that the RI/FS provides sufficient
information to support the evaluation of remedial alternatives and the
selection of a remedy, and at the same time is as streamlined as possible.
1.2 OVERVIEW OF CERCLA REAUTHORIZATION
The Superfund Amendments and Reauthorization Act (SARA) was signed by
the President on October 17, 1988, to amend the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA). While SARA did
not change the basic structure of CERCLA, it did modify many of the existing
requirements and added new ones. References made to CERCLA throughout this
document should be interpreted as meaning "CERCLA as amended by SARA."
Many of the new provisions under CERCLA having the greatest impact on
the RI/FS process are contained in S121 (Cleanup Standards). Other notable
changes are contained in $104 (Response Authorities, in particular Health-
Related Authorities), portions of $104 and $121 regarding State involvement,
$117 (Public Participation), $110 (Worker Protection Standards), and $113
(Civil Proceedings). Highlights of these sections are summarized below.
1.2.1 Cleanup Standards
Section 121 (Cleanup Standards) states a strong statutory preference
for remedies that are highly reliable and provide long-term protection. In
addition to the requirement for remedies to be both protective of human
health and the environment and cost-effective, additional remedy selection
considerations in $121(b) include:
o A preference for remedial actions that employ treatment that
permanently and significantly reduces the volume, toxicity, or
mobility of hazardous substances, pollutants, and contaminants as
its principal element.
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o Offsite transport and disposal without treatment'is the least
favored alternative where practicable treatment technologies are
available.
o The need to assess the use of permanent solutions and alternative
treatment technologies or resource recovery technologies and use
them to the maximum extent practicable.
Section 121(c) also requires a periodic review of remedial actions, at
least every 5 years after initiation of such action, for as long as
hazardous substances, pollutants, or contaminants that may pose a threat to
human health or the environment remain at the site. If it is determined
during a 5-year review that the action no longer protects human health and
the environment, further remedial actions will need to be considered.
1.2.1.1 Applicable or Relevant and Appropriate Requirements
Section 121(d)(2)(A) of CERCLA incorporates into law the CERCLA
Compliance Policy, which specifies that Superfund remedial actions meet any
Federal standards, requirements, criteria, or limitations that are
determined to be legally applicable or relevant and appropriate requirements
(ARARs). Also included is the new provision that State ARARs must be met if
they are more stringent than Federal requirements. Federal statutes that
are specifically cited in CERCLA include the Solid Waste Disposal Act
(SWDA), the Toxic Substances Control Act (TSCA), the Safe Drinking Water Act
(SDWA), the Clean Air Act (CAA), the Clean Water Act (CWA), and the Marine
Protection Research and Sanctuaries Act (MPRSA). Additional guidance on
ARARs is provided in the "CERCLA Compliance with Other Environmental Laws
Manual" (U.S. EPA Draft, November 1987).
Section 121(d)(4) of CERCLA identifies six circumstances under which
ARARs may be waived:
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OSWER Directive 9355.3-01
o The remedial action selected is only a part of a total remedial
action where the final remedy will attain the ARAR upon
completion.
o Compliance with the ARAR will result in a greater risk to human
health and the environment than alternative options.
o Compliance with the ARAR is technically impracticable from an
engineering perspective.
o An alternative remedial action will attain an equivalent standard
of performance through the use of another method or approach.
o The ARAR is a State requirement that the state has not
consistently applied (or demonstrated the intent to apply
consistently) in similar circumstances.
o For $104 Superfund-financed remedial actions, compliance with the
ARAR will not provide a balance between protecting human health
and the environment and the availability of Superfund money for
response at other facilities.
1.2.1.2 Offsite Facilities
The new statutory requirements contained in S121(d)(3) for acceptable
offsite disposal facilities, in most respects, incorporate previous Agency
policy. Offsite disposal facilities receiving contaminants must be in
compliance with RCRA and other Federal and State ARARs. In addition, the
unit receiving the waste must have no releases to ground water, surface
water, or soil; other units that have had releases at the facility must be
under an approved corrective action program.
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OSWER Directive 9355.3-01
1.2.2 Health Assessments
Under CERCLA S104(i) (Health-Related Authorities), the Agency for Toxic
Substances and Disease Registry (ATSDR) must conduct a health assessment for
every site proposed for inclusion on the NPL. The purpose of these health
assessments is to assist in determining whether current or potential risk to
human health exists at a site and whether additional information on human
exposure and associated health risks is needed. The health assessment is
required to be completed "to the maximum extent practicable" before
completion of the RI/FS.
1.2.3 State Involvement
Section 104(c)(3)(C) of CERCLA remains in effect requiring a 10-percent
State cost share for remedial actions (remedial planning activities for the
RI/FS and remedial design continue to be 100 percent federally funded).
Section 104(c)(3)(A) and 104(c)(6) of CERCLA provide that the operation and
maintenance of ground- and surface-water restoration actions be considered
part of remedial action for up to 10 years after commencement of operations
or until remedial action is complete, whichever is earlier. Therefore, such
activities during the 10-year period would be eligible for 90 percent
Federal funding.
Section 121(d)(2)(A) of CERCLA specifies that more stringent State
ARARs apply and that these requirements must be identified in a timely
manner by the state. Section 121(f) requires EPA to develop State
involvement regulations for substantial and meaningful State involvement in
the remedial response process.
1.2.4 Community Involvement
Section 117 of CERCLA (Public Participation) emphasizes the importance
of early, constant, and responsive relations with affected communities and
codifies, with some modifications, current community relations activities
applied at NPL sites. Specifically, the law requires that notice of the
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OSWER Directive 9355.3-01
proposed remedial actions plan be published and that people be given a
"reasonable opportunity" to comment on the proposed plan in writing, in
person, and at a public meeting. The proposed plan should include a
reasonable explanation of the alternatives considered, which will usually be
in the form of a summary of the feasibility study. Notice of the final plan
adopted and an explanation of any significant changes from the proposed plan
are also required. CERCLA also authorizes technical assistance grants for
local citizens' groups potentially affected by an NPL site. The grants are
to be used in obtaining assistance in interpreting information on the nature
of hazards posed by the site, the results of the RI/FS, any removal actions,
the Record of Decision (ROD), and the remedial action and remedial design.
1.2.5 Worker Safety
Section 110 of CERCLA directed the Occupational Safety and Health
Administration (OSHA) to issue, '-'thin 60 days of the date of enactment of
SARA, an interim final rule that contains employee protection requirements
for workers engaged in hazardous waste operations. OSHA's interim final
rule (29 CFR 1910.120) was published in the Federal Register on December 19,
1986, with full implementation of this rule required by March 16, 1987. The
worker safety rule will remain in effect until the final standard is issued
by OSHA and becomes effective.
1.2.6 Administrative Record
Section 113(K) of CERCLA requires that an administrative record be
established "at or near the facility at issue." The record must be
available to the public and must include all information considered or
relied on in selecting the remedy, including public comments on the proposed
plan.
1.3 THE RI/FS PROCESS UNDER CERCLA
Although the new provisions of CERCLA have resulted in some
modifications to the RI/FS process, the basic components of the process
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OSWER Directive 9355.3-01
remain intact. The RI continues to serve as the mechanism for collecting
data for site and waste characterization and for conducting treatability
testing as necessary to evaluate the performance and cost of the treatment
technologies and support the design of selected remedies. The F,S continues
to serve as the mechanism for the development, screening, and detailed
evaluation of potential remedial alternatives.
The various steps, or phases, of the RI/FS process and how they have
been modified to comply with the new provisions in CERCLA are summarized
below. It is important to note that the RI and FS are conducted
concurrently and that data collected in the RI influence the development of
remedial alternatives in the FS, which in turn affects the data needs and
scope of treatability studies and additional field investigations. Two
concepts are useful to understand the phased RI/FS. First, data can be
collected in several stages, with initial data collection efforts usually
being limited to developing a general understanding of the site. As the
site is better characterized, subsequent data collection efforts can be
focused to fill any existing gaps in the data. Second, this phased sampling
approach encourages identification of key data needs as early in the process
as possible to ensure that data collection is always directed toward
providing information relevant to selection of a remedial action. In this
way the overall site characterization effort can be continually scoped to
minimize the collection of unnecessary data and maximize data quality.
Because of the interactive and iterative nature of this process, the
sequence of the various phases and associated activities, as described below
and presented in Figure 1-1, will frequently be less distinct in practice.
A generic timeline intended to illustrate the phasing of RI/FS activities,
is presented in Figure 1-2. The actual timing of individual activities will
depend on specific site situations.
1.3.1 Scoping
Scoping is the initial planning phase of the RI/FS process, and many of
the planning steps begun here are continued and refined in later phases of
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OSWER Directive 9355.3-01
FIGURE 1-1
PHASED RI/FS PROCESS
REMEDIAL INVESTIGATION
SITEPLANNINa
•COLLECTS ANALYZE
EJOSTMO DATA
•DEVELOP SITE
MANAGEMENT
STRATEGY
pofuccr pumxtMQ
•IDENTIFY INITIAL
PROJECT/OPERABLE
UMT. UKELY RESPONSE
SCENARIOS.*
REMEDIAL ACTION
OBJECTIVES
•INITIATE FEDERAL/
STATE AMAH
IDENTIFICATION
IDENTIFY MTIAL DATA
QUALITY OBJECTIVES
(000.)
•PREPARE PROJECT
PLANS
SITE CHARACTERIZATION
• CONDUCT FIELD INVf STOATON
• DERNB NATURE • EXTENT Of
CONTAMINATION /WASTE
TYPES. CONC ... RATIONS.
• OEN1W F€OERAL«TATE
CONTAMINANT • LOCATION •
SfECyiCAIMMi
• CONDUCT BASELINE RISK
ASSESSMENT
• REFINE REMEO • '- ACTION OOALS
TREATABIUTV
INVESTIGATIONS
• PERFORM BENCH OR WLOT
TREATAIUTV TESTS AS
NECESSARY
FEASIBILITY
STUDY
DEVELOPMENT OF
ALTERNATIVES
.0ENTVV POTENTIAL
TREATMENT TECHNOUXWS.
CONTAINMENT«ISI>OSAL
REOUMEUENTS FOR
RESIDUALS OR UNTREATED
WASTE
ASSEMBLE TECHNOLOOJCS
WTO ALTERNATIVES
DENTVV ACTION-SPECinc
SCREEMNQOF
ALTERNATIVES
> SCREEN ALTERNATIVES
AS NECESSARY
TO REDUCE NUMBER
SUBJECT TO DETAILED
ANALYSIS
•PRESERVE AN
APPROPRIATE RANOiOF
DETAILED ANALYSIS
OF ALTERNATIVES
•FURTHER REFINE
ALTERNATIVES AS
NECESSARY
•ANALYZE ALTERNATIVES
AOAMST THE MM CKTEMA
• COMPARE ALTERNATIVES
AGAINST EACH OTHgR
TO:
•REMEDY SELECTION
•RECORD OF DECISION
•REMEDMLOESION
•REMEDIAL ACTION
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OSWER Directive 9355.3-01
FIGURE 1-2
GENERIC PHASED RI/FS TIMELINE
SCOPING
„; ;pm^n«^
"FMIkinil^toi 'tabUbsS Ow ~ MMgnj'sifeCtmcliiinion ~ R'
1
SITE CHARACTERIZATION (Opta^)
DEVELOPMENT OF ALTERNATIVES
CMkw Ici*«n
SCREENING OF ALTERNATIVES .*«» **
TREATABILITY INVESTIGATION I
Oilim»di
MF8
DETAILED ANALYSIS OF ALTERNATIVES
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OSWER Directive 9355.3-01
the RI/PS. Scoping activities typically begin which the collection of
existing site data, including data from previous investigations such as the
preliminary assessment and site investigation. On the basis of this
information, a site management strategy is developed that preliminarily
identifies boundaries of the study area, identifies likely remedial action
objectives and whether interim actions may be necessary or appropriate, and
establishes whether the site may best be remedied as separate operable
units. Once the site management strategy is developed, the RI/FS for a
specific project or the site as a whole is scoped. Typical scoping
activities include:
o Initiating the identification and discussion of potential
ARARs with the support agency
o Determining the types of decisions to be made and identifying
the data needed '~ support those decisions
o Developing initial data quality objectives
o Assembling a technical advisory committee to assist in these
activities and to serve as a review board of important
deliverables and to monitor progress as appropriate during
the study
o Preparing the work plan, the sampling and analysis plan (SAP)
(which consists of the quality assurance project plan (QAPP)
and the field sampling plan (FSP)), the health and safety
plan, and the community relations plan
Chapter 2 describes the various steps in the scoping process and gives
general information on work planning methods that have been effective in
planning and executing past RI/FSs.
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OSWER Directive 9355.3-01
1.3.2 Site Characterization
During site characterization, field sampling and laboratory analyses
are initiated. Field sampling should be phased so that the results of the
initial sampling efforts can be used to refine plans developed during
scoping to better focus subsequent sampling efforts. Remedial response
objectives are revised as appropriate based on an improved understanding of
the site. This type of approach allows for a more efficient and accurate
characterization of the site and, therefore, reductions in time and cost.
A preliminary site characterization summary is prepared to provide the
lead agency with information on the site early in the process before
preparation of the RI report. .This summary will be useful in determining
the feasibility of potential technologies and in assisting both the lead and
support agencies with the initial identification of ARARs. It can also be
sent to ATSDR to assist them in performing the health assessment for the
site.
A baseline risk assessment is developed to identify the existing or
potential risks that may be posed to human health and the environment by the
site. These assessments also serve to support the evaluation of the
no-action alternative by documenting the threats posed by the site based on
expected exposure scenarios. Because these assessments identify the primary
health and environmental threats at the site, they also provide valuable
input to the development and evaluation of alternatives during the FS. Site
characterization activities are described in Chapter 3.
1.3.3 Development of Alternatives
The development of alternatives usually begins during or soon after
scoping, when likely response scenarios may first be identified. The
development of alternatives requires (1) identifying potential treatment
technologies; (2) screening the technologies based on their effectiveness,
implementability, and cost (although cost plays a limited role at this
phase); and (3) assembling technologies and their associated containment or
1-11
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OSWER Directive 9355.3-01
disposal requirements into alternatives for the contaminated media at the
site or for the operable unit. Alternatives can be developed to address
contaminated media (e.g., ground water), a specific area of the site (e.g.,
a waste lagoon or contaminated hot spots), or the entire site. Alternatives
for specific media and site areas can be either carried through the PS
process separately or combined into comprehensive alternatives for the
entire site. The approach is flexible to allow alternatives to be combined
at various points in the process. However, the final detailed evaluation
must be for alternatives that address the entire site or that portion of the
site being addressed by that specific operable unit.
As practicable, a range of treatment alternatives should be developed,
varying primarily in the extent to which they rely on long-term management
of residuals and untreated wastes. The upper bound of the range would be an
alternative that would eliminate, to the extent practicable, the need for
any long-term management (indue?' .g monitoring) at the site. The lower
bound would consist of an alternative that involves treatment as a principal
element (i.e., treatment is used to address the principal threats at the
site). Between the upper and lower bounds of the treatment range,
alternatives varying in the type and degrees of treatment and associated
containment/disposal requirements should be included as appropriate. In
addition, one or more containment options involving little or no treatment
and a no-action alternative should be developed as appropriate. The
development of alternatives is discussed in Chapter 4.
1.3.4 Screening of Alternatives
Once potential alternatives have been developed, it may be necessary to
screen out certain options to reduce the number of alternatives that will be
analyzed in detail in order to minimize the resources dedicated to
evaluating options that are less promising. The necessity of this screening
effort will be dependent on the number of alternatives initially developed,
which will be partially dependent on the complexity of the site and/or the
number of available/suitable technologies. In these situations where it is
necessary to reduce the initial number of alternatives prior to beginning
1-12
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OSWER Directive 9355.3-01
the detailed analysis, a range of alternatives should be preserved as
practicable so that the decisionmaker can be presented with a range of good
options from which to choose. The screening process involves evaluating
alternatives with respect to their effectiveness, implementabiliHiy, and
cost. It is often done on a general basis and with limited effort (relative
to the detailed analysis) because the necessary information to fully
evaluate the alternatives may not be complete at this point in the process.
The screening of alternatives is discussed in Chapter 5.
1.3.5 Treatability Investigations
Should existing site and/or treatment data be insufficient to
adequately evaluate alternatives, treatability tests may be necessary to
evaluate a particular technology on specific site wastes. Generally,
treatability tests involve bench-scale testing to gather information to
assess the feasibility of a technology. In a few situations, a pilot-scale
study may be necessary to furnish performance data and develop better cost
estimates so that a detailed analysis can be performed and a remedial action
can be selected. To conduct a pilot-scale test and keep the RI/FS on
schedule, it will usually be necessary to identify and initiate the test at
an early point in the process. Treatability investigations are described .In
Chapter 6.
1.3.6 Detailed Analysis
Once sufficient data are available, alternatives are evaluated in
detail with respect to nine evaluation criteria which the Agency has
developed to address the statutory requirements and preferences of CERCLA.
The alternatives are analyzed individually against each criterion and then
compared against one another to determine the respective strengths and
weaknesses of each alternative and identify the key tradeoffs for that i:ita0
As discussed above, alternatives evaluated in this phase of the FS must
address the entire site or that portion of the site being addressed by an
operable unit. The results of the detailed analysis are summarized and
presented to the decisionmaker so that an appropriate remedy consistent with
1-13
-------
OSWER Directive 9355.3-01
CERCLA can be selected. The detailed analysis of alternatives is described
in Chapter 7.
1.4 SPECIAL SITES
The use of treatment technologies, and therefore, the development of a
complete range of options, may not be practicable at some sites with large
volumes of low concentrated wastes (e.g., large municipal landfills or
mining sites). Remedies involving treatment at such sites may be
inhibitingly expensive or difficult to implement. Therefore, the range of
alternatives initially developed may be focused primarily on various
containment options. Although this guidance does not specifically state how
all such sites should be addressed, factors are discussed that can be used
as appropriate to help guide the development and evaluations of alternatives
on a case-by-case basis.
1.5 COMMUNITY RELATIONS
Community relations are a useful and important aspect of the RI/FS
process. Community relations activities serve to keep communities informed
of the activities at the site and helps the Agency anticipate and respond to
key community concerns. A community relations plan is developed for a site
as the work plan for the RI/FS is prepared. The community relations plan is
based on interviews with interested people in the community and will provide
the guidelines for future community relations activities at the site. At a
minimum, the plan must provide for a site mailing list, a conveniently
located place for access to all public information about the site, an
opportunity for a public meeting when the RI/FS report and proposed plan are
published, and a summary of public comments on the RI/FS report and proposed
plan and the Agency's response to those comments.
The specific community relations requirements for each phase of the
RI/FS are integrated throughout this guidance document, since they are
parallel to and support the technical activities. Each chapter has a
section discussing community relations requirements appropriate to that
1-14
-------
OSWER Directive 9355.3-01
specific phase of the RI/FS. Additional program requirements are described
in the March 1986 draft of OSWER Directive Number 9230.0-3A entitled
"Community Relations in Superfund: A Handbook."
1.6 LEAD AND SUPPORT AGENCY
Throughout this guidance the terms "lead agency" and "support agency"
are used to reflect the fact that either EPA or a State or Federal facility
can have the lead responsibility for conducting an RI/FS. The supporting
agency plays a review and concurrence role and provides specific informa-
tion, such as applicable or relevant and appropriate requirements. The
roles of the lead and support agencies in each phase of the RI/FS process
are described at the end of each chapter.
1.7 RPM ROLE AND RESPONSIBILITIES
The RPM's role in overseeing an RI/FS involves, to a large extent,
ensuring the work progresses in accordance with the priorities and
objectives established during site and project planning. This will require
the facilitation of interactions among EPA staff, state representatives,
contractor personnel, PRPs, and the public, to ensure that all involved
parties are aware of their roles and responsibilities. Throughout the
following chapters, and particularly in the discussions of scoping
(Chapter 2) and site characterization (Chapter 3), suggestions are provided
to guide the RPM in developing approaches for conducting RI/FSs so that high
quality deliverables are produced in a timely and cost-effective manner.
Additional suggestions specific to management of RI/FSs may be found in the
Superfund Federal Lead Remedial Project Manager Handbook and Superfund State
Lead Remedial Project Manager Handbook. Oversight responsibilities for
PRP-lead RI/FSs are outlined in Appendix A of this guidance.
WDR314/035
1-15
-------
CHAPTER 2
SCOPING OF THE RI/FS
SITE
CHARACTERIZATION
FROM:
• Preliminary
Aueument
• Ste Inspection
• NPLUsttng
TREATABILITY
INVESTIGATIONS
A
I
I
SCREENING OF
I \ALTEHNAT1VES
DETAILED ANALYSIS
OF ALTERNATIVES
SCOPING
OF THE RI/FS
SITE PLANNING
•Evaluate Existing Data
• Develop Conceptual Site
Model
• Develop Site Management
Strategy
PROJECT PLANNING
• Identify Initial Project/
Operable Unit, Likely
Response Scenarios &
Remedial Action Objectives
• Identify Potential State/
Federal ARARs, Determine
Initial Action Levels
• Identify Initial Data Quality
Objectives (DQOs)
• PrepareProject Plans
TO: >
• Remedy Selection
• Record ol Decision
• Remedial Dtdgn
• Remedial Action
-------
OSWER Directive 9355.3-01
CHAPTER 2
SCOPING THE RI/FS
2.1 INTRODUCTION
Scoping is the initial planning phase of site remediation and is begun,
at least informally, by the lead agency's remedial project manager as part
of the funding allocation and planning process. The first step in scoping
is site planning, which involves developing a site management strategy to
facilitate better planning and management of site activities. The lead and
support agencies should meet to develop a site management strategy on the
basis of available information that will serve to (1) identify the types of
actions that may be required to address site problems; (2) identify whether
interim actions may be taken to mitigate potential threats or prevent
further environmental degradation; (3) identify the-optimal sequence of site
actions and site activities; and (4) identify procedures that may be used to
streamline the RI/FS.
Once the initial site management strategy is developed and both the
lead and support agencies agree on the basic approach, the next step is to
scope the specific project(s) and develop project plans. Project planning
is done for the following reasons:
o Determine the types of decisions to be made
o Identify the data needed to support those decisions
o Describe the methods by which the required data will be obtained
o Describe the methods by which the data will be analyzed
o Prepare work plans to document methods and procedures
These activities directly relate to the establishment of data quality objec-
tives (DQOs)—statements that specify the data needed to support decisions
regarding remedial response activities. Establishing DQOs are discussed in
2-1
-------
OSWER Directive 9355.3-J|
detail in Data Quality Objectives for Remedial Response Activities (OSWER
Directive 9335.0-7B, March 1987, hereafter referred to as the DQO Guidance).
The ability to develop a comprehensive site management strategy or ade-
quately scope a specific project is closely tied to the amount and quality
of information available at the time. Therefore, it is important to note
that the site management strategy and project scope is developed iteratively
(i.e., as new information is acquired or new decisions are made, data
requirements are reevaluated and, if appropriate, the site management
strategy or project scope is modified). In this way, scoping helps to focus
activities and streamline the RI/FS, thereby preventing needless
expenditures and loss of time in unnecessary sampling and analyses.
Figure 2-1 shows the key steps in the scoping process.
2.2 SITE PLANNING
2.2.1 Develop a Site Management Strategy
One purpose for developing the site management strategy is to
facilitate the identification of potential action that can be taken early to
respond to an immediate problem that is worsening with time or to undertake
a limited action that will achieve a significant risk reduction quickly.
If the site response is to involve an interim action or is to be implemented
through operable units, the lead and support agencies should identify the
optimal sequence of the actions. Operable units may comprise incremental
steps toward the final remedy, completely address a geographical portion of
the site or a specific site problem, or initiate action that must be
followed by a final action that will fully address the problem. The
interrelationship of site problems and the need to implement actions quickly
will determine the appropriateness of dividing a remedial response into
separate operable units and/or taking interim actions. To the degree that
site problems are interrelated, (e.g., contaminated soils and ground water),
it may be appropriate to address the problems together. If problems are
separate, phased responses may promote a more rapid and effective cleanup.
-------
FIGURE 2-1
SCOPING
OSWER Directive 9355.3-01
Collect Community
Rotations Data
- Conduct Community
Inisfviaws
UantfyCRIuuM
CoflecVEvarfuaie Existing
DM To
• Develop Conceptual SIM
Develop Sfte Management
Strategy
b
FT*
Investigation
Needed To
Plan Specific
Inttat* OtocuMlon of
Com«mln«ni-€nd Location-
SptcfflcARARi
Uontlfy Dan NMdt
• For SIM CharacttrlzXlon
- For Risk and Environmental
AiMt»mant
and Tachnlqua*
Oavatop Sampling Strataglw
and Analytical Support Haaltti
and Safety Protocol*
Identify Preliminary
Remedial Action
Alternatives
- Identify Potential
Technologies
- Begin Review
of Technologies
• Identify Likely
Alternatives
- Identify Need for
Treatabllity Studies
lily S
Begin Preliminary
Identification
of Action-Specific ARABS
Identify Date Needs
for Evaluation of
Alternatives
Oaacrlba Data Analysis
Methods
• Define Rl and FS Tacks
Prepare CR Plan
Prepare RIFS Worn Plan
- Prepare HSP
• Prepare SAP
-------
OSWER Directive 9355.3-OlB
Although the need for interim actions or for separating the site into
operable units may not be identified until the RI is under way, the site
information available during scoping should be evaluated so that the site
management strategy can identify whether either is likely. Specific project
scoping can then be used to identify the data that are necessary to conduct
the RI/FS for that site or operable unit.
The timing and optimal sequencing of response actions should be
identified as part of the site management strategy to ensure that the most
important activities are to be implemented first. The timing of specific
actions should be determined on -he basis of the urgency of response, the
ability to take rapid action, and the resources to fund and administer
response actions. The identified sequence of activities and actions should
be reevaluated periodically as new information becomes available.
2.2.2 Identify Streamlining Techniques
During the development of the site management strategy, an initial
attempt at tailoring the RI/FS to site circumstances should be made.
Tailoring the RI/FS to the level of site complexity does not change informa-
tion requirements but simply involves identifying specific techniques that
may be used to streamline the process in order to save time and costs while
ensuring that information is sufficient in quantity and quality to select an
appropriate remedy. Examples of streamlining techniques that may be used in
appropriate situations include:
o Focusing the remedial investigation to collect only those data
needed to develop and evaluate alternatives for a specified
response action and to support the design of that action
o Combining the alternative development and screening steps or, when
only a limited number of viable options are available, eliminating
the screening step
. 4
-------
OSWER Directive 9355.3-01
o Tailoring the level of detail of the alternative evaluation to the
scope and complexity of the action
o Tailoring selection and documentation of the remedy tg> the scope
of the action (non-final remedies may require less justification
and documentation than final remedies)
The extent to which streamlining techniques may be used will depend on site
conditions. For example, the development of a range of treatment alterna-
tives may not be appropriate for sites with extremely large volumes of low
concentration wastes, (e.g.., large landfills and mining sites). Although
such a decision may not be finalized until later in the RI/FS process, it is
important that the lead and support agencies agree that treatment tech-
nologies may not be appropriate. Examples of other site-specific charac-
teristics or situations that may be conducive to streamlining techniques
include:
o A single group of chemicals or site characteristics such as frac-
tured bedrock significantly limits applicable technologies.
o The need for prompt action limits the time available to evaluate a
complete range of alternatives in detail.
o ARARs, guidance, or program precedent (e.g., PCS standard for
soils, Superfund Drum and Tank Guidance) limits the choices for
appropriate responses.
o Prohibitive costs for certain alternatives reduce the range of
viable options to address site problems.
.»
o There is a strong probability that no further action is required.
2-5
-------
OSWER Directive 9355.3-01
2.3 PROJECT PLANNING
Once the site management strategy has been developed and potential
streamlining techniques have been identified, planning the specific project
scope follows. The specific steps to project planning include:
o Meeting with EPA regional, state, and contractor personnel to dis-
cuss site issues and assign responsibilities for RI/FS activities
o Collecting and analyzing existing data to develop a conceptual
site that can be used to assess both the nature and the extent of
contamination and to identify potential exposure pathways and
potential human health and/or environmental receptors
o Initiating limited field investigations if available data are
inadequate to develop a ~>nceptual site model and adequately scope
the project
o Identifying the potential remedial action objectives and likely
remedial action alternatives for the specific project
o Identifying the need and the schedule for treatability studies to
better screen and define the potential remedial alternatives
o Preliminarily identifying the ARARs expected to apply to both site
characterization and site remediation activities
o Determining data needs and the level of analytical and sampling
certainty required for additional data if currently available data
are inadequate to conduct the FS
o Designing a data collection program to describe the selection of
the sampling approaches and analytical options (This selection is
documented in the SAP, which consists of the FSP and QAPP
elements.)
2-6
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OSWER Directive 9355.3-01
o Developing a work plan that documents the scoping process and pre-
sents anticipated future tasks
o Identifying and documenting health and safety protocols required
during field investigations and preparing a site health and safety
plan
o Conducting community interviews to obtain information that can be
used to develop a site-specific community relations plan that
documents the objectives and approaches of the community relations
program
Although each of the steps is discussed below, it should be noted that
one or more of them may have been performed to some extent during the
development of the site management strategy.
2.3.1 Conduct Scoping Meeting
To begin project planning, a meeting should be held involving key
management from the lead and support agencies, along with contractor per-
sonnel who will be conducting the RI/FS. The meeting allows key personnel
to become involved in initial planning decisions; it also gives them the
opportunity to discuss any special concerns that may be associated with the
site. Furthermore, this meeting sets a precedent for the continued involve-
ment of key personnel periodically throughout the project.
2.3.2 Collect and Analyze Existing Data
Before the activities necessary to conduct an RI/FS can be planned, it
is important to compile all available data that have previously been col-
lected for a site. These data will be used to determine the additional work
that needs to be conducted both in the field and within the community. A
thorough search of existing data should help avoid duplication of previous
efforts and/or lead to a remedial investigation that is more focused and,
therefore, more efficient in its expenditure of resources.
2-7
-------
OSWER Directive 9355.3-1
Information describing hazardous waste sources, migration pathways, and
human and environmental receptors for a given site is available from many
sources. Some of the more useful sources are listed in Table 2-1. Site
information gathered in the hazard ranking process (the process by which a
site is listed on the NPL) may be located in files maintained by the EPA
Regional offices, the field investigation team (FIT), the technical assis-
tance team (TAT), contractors, and the state.
Data relating to the varieties and quantities of hazardous wastes
disposed of at the site should be compiled. The results from any previous
sampling events should be summarized in terms of physical and chemical char-
acteristics, contaminants identified, and concentrations present. Results
of environmental sampling at the site should be summarized, and evidence of
soil, ground water, surface water, sediment, air, or biotic contamination
should be documented. If available, information on the precision and accur-
acy of the data should be included.
Records of disposal practices and operating procedures at the site,
including historical photographs, can be reviewed to identify locations of
waste materials onsite, waste haulers, and waste generators. If specific
waste records are absent, waste products that may have been disposed of at
the site can be identified through a review of the manufacturing processes
of the waste generators.
A summary of existing site-specific and regional information should be
compiled to help identify surface, subsurface, atmospheric, and biotic
migration pathways. Compiled information should include geology, hydro-
geology, hydrology, meteorology, and ecology. Regional information can help
to identify background soil, water, and air quality characteristics.
Data on human and environmental receptors in the area surrounding the
site should be compiled. Demographic and land use information will help
identify potential human receptors. Residential, municipal, or industrial
wells should be located, and surface water uses should be identified for
surrounding areas and areas downstream of the site.
2-8
-------
TABLE 2-1. DATA COLLECTION INFORMATION SOURCES
Information Source
U.S. EPA Files
U.S. Geological Survey
U.S. DOA, Soil Conservation Service
U.S. DOA, Agricultural Stabilization and Conservation
Service
U.S. DOA, Forest Service
U.S. DOI, Fisb and Wildlife Agencies
U.S. DOI, Bureau of Reclamation
U.S. Army Corps of Engineers b
Federal Emergency Management Agency
U.S. Census Bureau
National Oceanic and Atmospheric Administration
State Environmental Protection or Public Health Agencies
State Geological Survey
State Fisb and Wildlife Agencies
Local Planning Boards
County or City Health Apartments
Town Engineer or Town Hall
Local Chamber of Comerce
Local Airport
Local Library
Local Nell Drillers
Sewage Treatment Plants
Local Nater Authorities
City Fire Departments
Regional Geologic and Hydrologic Publications
Court Records of Legal Action
Department of Justice Files
State Attorney General Files
Facility Records
Facility Owners and Employees
Citizens Residing Near Sitec
Haste Haulers and Generators
Site Visit Reports
Photographs
Preliminary Assessment Report
Field Investigation Analytical Data
FIT/TAT Reports
Site Inspection Report
HRS Scoring Package
EMSL/EPIC (Environmental Monitoring Support Laboratory/
Environmental Photographic Information Center)
Hazardous
Haste
Sources
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Migration Pathways
Subsurface
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Surface
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Air
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Receptors
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
"includes county soil survey reports fron Soil Conservation Service, U.S. DOA.
The Federal Emergency Management Agency publishes floodplaln maps.
clntervlews require EPA concurrence.
HDR229/050
-------
OSWER Directive 9355.3-03
The ecology of the site and surrounding areas should be described and
the common flora and fauna of the area identified. Any threatened, endan-
gered, or rare species on or near the site should also be identified, as
should sensitive environmental areas or critical habitats. Any available
results from biological testing should be compiled to document bioaccumula-
tion in the food chain.
Once the available data have been collected, they are analyzed to:
(1) establish the physical characteristics of a site to help determine the
scope of future sampling efforts; and (2) conceptually model potential
exposure pathways and receptors to assist in the preliminary assessment of
risk and the initial identification of potential remedial technologies.
Each of these uses is discussed below.
2.3.2.1. Establish Physical Characteristics of the Site
Existing data are analyzed to gain a better understanding of the nature
and extent of contamination and of the pathways, receptors, and existing or
potential effects of the site. The data should be used to develop a site
description, which should include location, ownership, topography, geology,
land use, waste type, estimates of waste volume, and other pertinent
details. The extent of contamination for the various media should be
determined for use in designing remedial investigation tasks.
The site description should also include historical events of concern
such as chemical storage and disposal practices, previous site visits,
sampling events, regulatory violations, legal actions, and changes in owner-
ship. In addition, information concerning previous cleanup actions, such as
removal of containerized waste, is often valuable for determining the
characteristics of any wastes or contaminated media remaining at the site.
If quality assurance information on existing sampling data is avail-
able, it should be reviewed to assess the level of uncertainty associated
with the data. This is important to establish whether sampling will be
needed to verify or simply supplement existing data. Important factors to
10
-------
OSWER Directive 9355.3-01
consider when reviewing existing data are the comparability of the data
(e.g., time of sampling), the analytical methods, the detection limits, the
analytical laboratories, and the sample collection and handling methods.
It is also useful to compile a chronology of significant events. All
sources of information or data should be summarized in a technical
memorandum or retained for inclusion in the RI report.
2.3.3.2 Develop a Conceptual Site Model
Information on the waste sources, pathways, and receptors at a site is
used to develop a conceptual site model to evaluate potential risks to human
health and the environment. The conceptual site model should include all
known and suspected sources of contamination, types of contaminants and
affected media, known and potential routes of migration, and all known or
potential human and environmental receptors. If exact data are unavailable
for components of the model, the likely variability in the component should
be identified so that the model identifies the possible range of contaminant
migration and the potential effects on receptors. This effort, in addition
to assisting in identifying where samples need to be taken, will also assist
in identifying appropriate remedial technologies. Additional information
for evaluating exposure concerns through the use of a conceptual model is
provided in the DQO Guidance. Figure 2-2 shows the elements to be contained
in such a model.
2.3.3.3 Determine the Need for and Implement Limited Additional
Studies
If the conceptual site model is poorly defined and the collection of
site-specific data could greatly increase the understanding of the site, a
limited field investigation may be undertaken as an interim scoping task
prior to developing the work plan. Normally, the investigation is limited
to easily obtainable data where results can be achieved in a short time.
Examples of tasks are:
2-11
-------
FIGURE 2-2
EXAMPLE CONCEPTUAL SITE MODEL
OSWER Directive 9355.3-01
SOURCES-1
RELEASE
MECHANISM -1
SOURCES-2 RELEASE PATHWAY
MECHANISM -2
Drums
and
Tanks
\
Spills
Infiltration/
Percolation
Overtopping
Dike
Structures,
Drums. Tanks.
Lagoon
Dust and/or
Volatile
Emissions
RECEPTOR
Human
Biota
-------
OSWER Directive 9355.3-0:
o Preliminary geophysical investigations
o Residential, industrial, and agricultural well sampling and analy-
sis
o Measurement of well-water level, sampling (only for pre-existing
monitoring wells), and analysis
o Limited sampling to determine the need for waste treatability
studies
o Air monitoring
o Site mapping
Once these data are obtained and the conceptual site model is refined,
data needs can be better defined.
2.3.4 Develop and Evaluate Preliminary Remedial Action Alternatives
Once the existing site information has been analyzed and the conceptual
site model developed, potential remedial action objectives should be
identified for each contaminated medium (Chapter 4 presents examples of
remedial action objectives) and a preliminary range of remedial action
alternatives and associated technologies should be identified. This
identification is not meant to be a detailed investigation of alternatives.
Rather, it is intended to be a more general classification of potential
remedial actions based upon the initially identified potential routes of
exposure and associated receptors. The identification of potential
technologies at this stage will help ensure that data needed to conduct the
technical evaluation (e.g., Btu value of wastes to evaluate thermal
destruction technologies) can be collected as early as possible. In
addition, the identification of technologies will help determine whether
treatability studies need to be conducted.
2-13
-------
OSWER Directive 9355.3-oB
Technologies that may be appropriate for treating or disposing of
wastes should be identified, along with sources of literature on the
technologies' effectiveness, applications, and cost. Further assistance in
the investigation of technologies is provided in the "Technology Screening
Guide" (U.S. EPA Draft 1987). Innovative technologies and resource recovery
options should be included if they appear feasible.
To the extent practicable, a preliminary list of broadly defined alter-
natives should be developed that reflects the goal of presenting a range of
good options to the decisionmaJcer. This list would therefore include a
range of alternatives in which treatment significantly reduces the toxicity,
mobility, or volume of waste; one or more alternatives that involve contain-
ment with little or no treatment? and a no-action alternative. The list
should be limited to only those alternatives that are relevant and carry
some significant potential for being implemented at the site. In this way,
the preliminary identification of remedial actions will allow an initial
identification of ARARs and will help focus subsequent data-gathering
efforts.
Involvement of the various agencies at this time will help in identify-
ing remedial alternatives and scoping field activities. The development of
alternatives is described in more detail in Chapter 4 of this document.
2.3.5 Evaluate the Need for Treatability Studies
If remedial actions involving treatment have been identified for a
site, then the need for treatability studies should be evaluated as early as
possible in the RI/FS process. This is because many treatability studies,
especially pilot testing, may take several months or more to complete. If a
lengthy study is required and is not initiated early, the FS may be delayed
while awaiting the results of the treatability testing.
The initial activities of treatability testing include researching
other potentially applicable data, designing the study, and procuring
vendors and equipment. As appropriate, these activities should occur
-------
OSWER Directive 9355.3-D1
concurrently with site characterization efforts so that if.it is determined
that a potential technology is not feasible, treatability activities on this
technology can be stopped before actual analysis of wastes has occurred.
Chapter 6 provides guidance on scoping treatability studies. »
2.3.6 Begin Preliminary Identification of ARARs and To Be Considered
(TBC) Requirements
A preliminary identification of potential ARARs and TBC requirements in
the scoping phase can assist in initially identifying remedial alternatives
and is useful for initiating communications with the support agency to faci-
litate the identification of ARARs. Because of the iterative nature of the
RI/FS process, ARAR identification continues throughout the RZ/FS as a
better understanding is gained of site conditions, site contaminants, and
remedial action alternatives. Furthermore, early identification of
potential ARARs will allow better planning of field activities.
ARARs may be categorized as contaminant-specific, which may define
acceptable exposure levels and therefore be used in establishing preliminary
cleanup goals; as location-specific, which may set restrictions on
activities within specific locations such as floodplains or wetlands; and as
action-specific, which may set controls or restrictions for particular
treatment and disposal activities related to the management of hazardous
wastes. The document, "Guidance on CERCLA Compliance With Other Statutes"
(U.S. EPA, July 1987 Draft), contains detailed information on identifying
and complying with ARARs.
Potential contaminant- and location-specific ARARs are identified on
the basis of the compilation and evaluation of existing site data. A pre-
liminary evaluation of potential action-specific ARARs may also be made to
assess the feasibility of remedial technologies being considered at this
time. In addition to Federal ARARs, more stringent State ARARs must also be
identified. Other Federal and State criteria, advisories, and guidance and
local ordinances should also be considered, as appropriate, in the develop-
ment of remedial action alternatives.
2-15
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OSWER Directive 9355.3-0
For documentation purposes, a list should be maintained of all poten-
tial ARARs as they are identified for a site. As the RI/FS progresses, each
ARAR will need to be ascertained. The assistance of the appropriate support
agency should be sought in identifying support agency ARARs and confirming
their applicability or relevance and appropriateness.
2.3.7 Identify Data Needs
The identification of data needs is the most important part of the
scoping process. Data needs are identified by evaluating the existing data
and determining what additional data are necessary to characterize the site,
complete the conceptual site model, better define the ARARs, narrow the
range of preliminarily identified remedial alternatives, and support
enforcement activities.
The need for additional site data is evaluated relative to meeting the
site-specific RI/FS objectives. In general, the RI/FS must obtain data to
define source areas of contamination, the potential pathways of migration,
and the potential receptors and associated exposure pathways to the extent
necessary to:
o Determine whether, or to what extent, a threat to human health or
the environment exists
o Develop and evaluate remedial alternatives (including the
no-action alternative)
o Support enforcement or cost-recovery activities
If additional data are needed, the intended uses of the data are iden-
tified, strategies for sampling and analyses are developed, data quality
objectives are established, and priorities are assigned according to the
importance of the data in meeting the objectives of the RI/FS.
The possible use categories include:
I
2-16
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OSWER Directive 9355.3-0
o Monitoring during implementation
o Health and safety planning
o Site characterization
o Risk assessment
o Evaluating alternatives
o Determining the PRP
o Engineering the design of alternatives
A more complete description of these use categories and their appropri-
ate analytical levels can be found in the DQO Guidance. This is summarized
in Figure 2-3.
Setting priorities for data use helps to determine the highest level of
confidence required for each type of data. For example, additional data on
soil contamination may be necessary for all the above categories but may be
of highest priority for risk assessment and evaluation of alternatives.
Within these two use categories, the evaluation of alternatives may require
a much greater level of confidence in the contaminant types and concentra-
tions onsite so that cost estimates for treatment can be prepared to meet or
approach the goal of +50 percent/-30 percent accuracy level. As a result,
data needs specifying the level of allowable uncertainty would be set for
the evaluation of alternatives use category and vwuld therefore provide an
acceptable level of confidence for the remaining data uses.
Sensitivity analyses may be useful in evaluating the acceptable level
of uncertainty in data. Critical parameters in any of the use categories
can be varied over a probable range of values that were identified in the
conceptual site model and that determine the effect on meeting the RI/FS
objectives. For example, preliminary treatment costs for contaminated soil
can be calculated for various contaminant types and volumes. The sensiti-
vity that contaminant volume and type has on treatment cost can be assessed
so that sufficient site characterization data are collected to allow costing
2-17
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OSWER Directive 9355.3-01
FIGURE 2-3
SUMMARY OF ANALYTICAL LEVELS APPROPRIATE TO DATA USES
DATA USES
ANALYTICAL LEVEL
TYPE OF ANALYSIS
Site Characterization
Monitoring During
Implementation
LEVEL!
• Total Organic/Inorganic
Vapor Detection Using
Portable Instruments
• Field Test Kits
Site Characterization
Evaluation of Alternatives
Engineering Design
Monitoring During
Implementation
LEVEL II
•Variety of Organics by
GC; Inorganics by AA;
XRF
•Tentative ID; Anar/te-
Specific
• Detection Limits Vary
from Low ppm to Low
ppb
Risk Assessment
PRP Determination
Site Characterization
Evaluation of Alternatives
Engineering Design
Monitoring During
Implementation
LEVEL III
•Organics/lnorganics
Using EPA Procedures
other than CLP can be
Analyte-Spedfic
• RCRA Characteristic
Tests
Risk Assessment
PRP Determination
Evaluation of Alternatives
Engineering Design
LEVEL IV
• HSL Organics/lnorganics
byGC/MS;AA;ICP
•Low ppb Detection Limit
Risk Assessment
PRP Determination
LEVEL V
• Non-Conventional
Parameters
• Method-Specific
Detection Limits
• Modification of
Existing Methods
• Appendix 8 Parameters
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OSWER Directive 9355.3-01
of treatment alternatives during the FS using a goal of +50 percent/
-30 percent cost accuracy.
In the development of data requirements, time and resource constraints
must be balanced with the desired confidence level of the data. The turn-
around time necessary for certain analytical procedures may, in some cases,
preclude achieving the original level of confidence desired.
Likewise, resource constraints such as the availability of a labora-
tory, sampling and analysis equipment, and personnel may also influence the
determination of data requirements. Because of the high cost of sampling
and analysis for contaminants on the hazardous substances list, data acqui-
sition should be focused only on the data quality and quantity necessary and
sufficient to meet the RI/FS objectives. It is also important to do any
necessary logistical planning once data needs are identified. For example,
if it will be necessary to acquire aerial photographs to adequately evaluate
a site, it should be noted early in the process so that the acquisition can
begin early.
2.3.8 Design a Data Collection Program
Once the level of confidence required for the data is established,
strategies for sampling and analysis can be developed. The identification
of sampling requirements involves specifying the sampling design; the
sampling method; sample numbers, types, and locations; and the level of
sampling quality control. Data may be collected in multiple sampling
efforts to use resources efficiently, and the level of accuracy may increase
as the focus of sampling is narrowed. The determination of analytical
requirements involves specifying the most cost-effective analytical method
that, together with the sampling methods, will meet the overall data needs
for the RI/FS. Data quality requirements specified for sampling and
analysis include precision, accuracy, representativeness, completeness, and
comparability.
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OSWER Directive 9355.3-01
A description of the methods to be used in analyzing data obtained
during the RI should be included in a sampling and analysis plan (SAP). The
level of detail possible in defining the data evaluation tasks will depend
on the quality of the site conceptual model. If the site is well
understood, data evaluation techniques should be specified and described.
This information is especially important where numerical modeling is
anticipated. If little existing information is available, the task des-
criptions may be very general, since it may not be clear which data evalu-
ation techniques will be appropriate. If information is lacking,
descriptions of potential evaluation techniques could be included. In
addition to site characterization techniques, methods to be used in the risk
assessment should be described.
2.3.9 Develop a Work Plan
Tasks that are to be conducted during the RI/FS should be identified
and documented in a work plan. Although this work plan will constitute the
planning through the completion of the RI/FS, the level of detail with which
specific FS tasks can be described during scoping will depend on the amount
and quality of existing data. Therefore, in situations in which additional
data are needed to adequately scope the development and evaluation of
alternatives, emphasis should be placed on limiting the level of detail used
to describe these subsequent tasks and simply noting in the work plan that
the scope of these activities will be refined at a later point in the
process. This will reduce the time needed to prepare and review the initial
work plan. As the RI/FS process progresses and a better understanding of
the site is gained, these task descriptions can be refined. The preliminary
definitions of tasks necessary to complete the RI/FS should be documented in
the work plan and can be used as a basis for scheduling and estimating the
RI/FS budget.
2.3.10 Identify Health and Safety Protocols
Protecting the health and safety of the investigative team and the
general public is a major concern during remedial response actions. Workers
2-20
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OSWER Directive 9355.3-0:
may be exposed to a variety of hazards including toxic chemicals, biological
agents, radioactive materials, heat or other physical stresses, equipment-
related injuries, and fires or explosions. The surrounding community may be
at increased risk from unanticipated chemical releases, fires, qr explosions
created by onsite activities. In recognition of these concerns, OSHA has
published regulations that stress the importance both of an underlying
health and safety program and of site-specific safety planning. Appendix A
provides an overview of the regulations pertaining to hazardous waste site
workers and focuses on the requirements that employers, contractors, and
subcontractors must meet when involved in remedial response actions.
2.3.11 Conduct Community Interviews
The community relations staff members, which can be either lead agency or
contractor personnel and technical staff, should work together during the
scoping process so that there is sufficient information to conduct community
interviews. Community relations staff members then meet with the identified
groups or individuals to gain an understanding of the site's history and the
community's involvement with the site from the community's perspective. The
lead agency will determine on a site-specific basis the type and number of
interviews that need to be conducted to obtain sufficient information to
develop an effective community relations plan. The results of the
interviews should be made available to all technical staff members to assist
in identifying potential waste types and disposal practices, potential -
pathways of contamination, and potential receptors. On the basis of an
understanding of the issues and concerns of the community, the community
relations history, and the citizens' indicated preferences for how they
would like to be informed concerning site activities, the community rela-
tions plan is prepared. Plans should provide opportunities for public input
throughout the remedial planning process as appropriate.
2.4 DELIVERABLES AND COMMUNICATION
There are several points during the scoping process when communication
is required between the lead agency and its contractor and/or the support
2-21
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OSWER Directive 9355.3-oB
agency (see Table 2-2). It is especially important that discussion and
information exchange occur if interim actions or limited field investiga-
tions are considered necessary. For all RI/FSs, it is desirable for the
lead and support agencies and their contractors to review existing data and
to concur on the major tasks to be conducted at a site. Specific guidance
for the timing and nature of communications between the lead and support
agencies is provided in the "Superfund Memorandum of Agreement Guidance" (in
preparation).
Deliverables required for all RI/FSs in which field investigations are
planned consist of a work plan, a sampling and analysis plan, a health and
safety plan, and a community relations plan. Each of these plans is des-
cribed below.
2.4.1 Work Plan
2.4.1.1 Purpose
The work plan documents the scoping process and presents anticipated
future tasks. It also serves as a valuable tool for assigning responsibi-
lities and setting the project's schedule and cost. Information on planning
work for lead agency staff may be found in the Federal-Lead Remedial Project
Management Handbook (U.S. EPA, December 1986); and the State-Lead Remedial
Project Management Handbook (U.S. EPA, December 1986).
The work plan documents the decisions and evaluations made during the
scoping process and is usually submitted in conjunction with the SAP, health
and safety plan, and the community relations plan, although each plan may be
delivered separately. The work plan should be modified as necessary
throughout the RI/FS process to reflect changes in scope.
2-22
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OSWER Directive 9355.3-01
TABLE 2-2. COMMUNICATION AND DELIVERABLES REQUIRED DURING SCOPING
Information Needed
If interim actions are needed
Purpose
For lead agency and contractor to identify
actions that will abate immediate threat to
public health or prevent further degradation
of the environment; obtain concurrence of
support agency
Potential Methods
of Information
Exchange
Meeting
Tech memo
Other
If limited field investigations
are needed
For lead agency and contractor to improve
focus of RI and reduce time and cost; obtain
concurrence of support agency
Meeting
Tech Memo
Other
Summary of existing data; need
to conduct field studies prior
to FS; identification of
preliminary remedial action
alternatives
Document QA and field sampling
procedures
Document health and safety
procedures
Document all RI/FS tasks
For lead agency and contractor to confirm need
for field studies; for lead agency and contractor
to plan data collection; obtain support agency
review and concurrence
For contractor to obtain lead agency review and
approval; for lead agency to obtain support
agency review and comment
For contractor to obtain lead agency agreement
that OSHA safety requirements are met
For contractor to obtain lead agency review and
approval; for lead agency to obtain support
agency concurrence-
Meeting
Tech Memo
Other
SAP (FSP,QAPP)
Health and
safety plan
Work plan
WDR229/052
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OSWER Directive 9355.3-
The primary user of the RI/FS work plan is the lead agency for the site
(usually either the EPA Region or the appropriate State agency) and the
project team that will execute the work. Secondary users of the work plan
include other groups or agencies serving in a review capacity, such as EPA
Headquarters and local government agencies. In enforcement cases, PRPs may
also review and comment on the work plan. It should also be noted that the
work plan is usually made available for public comment (often in conjunction
with a public meeting) and is placed in the Administrative Record.
2.4.1.2 Preparation
The work plan presents the initial evaluation of existing data and
background information performed during the scoping process, including the
following:
o An analysis and summary of site background and physical setting
o An analysis and summary of previous response actions
o Presentation of the conceptual site model, including an analysis
and summary of the nature and extent of contamination; preliminary
assessment of public health and environmental impacts; and the
additional data needed to conduct the baseline risk assessment
o Preliminary identification of general response actions and alter-
natives and the data needed for the evaluation of alternatives
The work plan also defines the scope and objectives of RI/FS activities
to the extent possible.
The scope of the RI site characterization should be documented in the
work plan, with detailed descriptions provided in the SAP. Later tasks will
usually be scoped in less detail, pending the acquisition of more complete
data about the site.
2-24
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OSWER Directive 9355.3-01
The initial work plan is prepared prior to the RI site characteriza-
tion. Because the RI/FS process is dynamic and iterative, the work plan or
supplemental plans, such as the QAPP and the FSP, can be modified during the
RI/FS process to incorporate new information and refined project* objectives.
The work plan should be revised, if necessary, before (1) additional
iterations of site characterization activities, and (2) treatability inves-
tigations .
2.4.1.3 Work Plan Elements
Five elements typically are included in a work plan. They are
described in Appendix B.
Among the elements to be included is the specification of RI/FS tasks.
For Federal-lead sites, 15 standard tasks have been defined to provide con-
sistent reporting and allow more effective monitoring of RI/FS projects.
Figure 2-4 shows these tasks and their relationship to the phases of an
RI/FS, and detailed task definitions are included in Appendix B. RI/FSs
that are not Federal-lead projects do not need to use these standard tasks,
but the use of these tasks provides a project management tool and allows
historical cost and schedule data to help estimate these factors in project
planning and management.
Project Management Considerations. Project management considerations
may be specified in the work plan to define relationships and responsibili-
ties for selected task and project management items. This specification is
particularly useful when the lead agency is using extensive contractor
assistance. The following project management considerations may be
discussed in the work plan:
o Identification of staff (the lead agency's RPM, the contractor,
the contractor's site manager, and other team members)
o Coordination among the lead agency, the support agency, and their
contractors
2-25
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FIGURE 2-4
OSWER Directive 9355.3-01
RELATIONSHIP OF RI/FS TASKS TO PHASED RI/FS APPROACH
RI/FS WORK PLAN
STANDARD TASKS
TASK TITLE
1 Project Planning
2 Community Relations *
3 Field Investigation
4 Sample Analysis/
Validation
5 Data Evaluation
6 Risk Assessment
7 Treatability Study/
Pilot Testing
8 Remedial Investigation
Reports
9 Remedial Alterna-
tives Screening
10 Remedial Alterna-
tives Evaluation
11 Feasibility Study
(RI/FS) Reports
12 Post RI/FS Support
13 Enforcement Support *
14 Miscellaneous
Support*
15 ERA Planning
Tasks that can
occur in any Phase
of the RI/FS
SCOPING
Task 1 - Project
Planning
Task 15-ERA
Planning
REMEDIAL INVESTIGATION
SITE CHARACTERIZATION
Task 3 - Field Investigation
Task 4 - Sample Analysis/
Validation
Task 5 - Data Evaluation
Task6-Risk Assessment
Task 8 - Rl Reports
Task 15 - ERA Planning
TREATABILITY
INVESTIGATIONS
Task 7 - Treatability Studies
Task 8 - Rl Reports
FEASIBILITY
* STUDY
DEVELOPMENT OF
ALTERNATIVES
Task 9 - Remedial
ABematives
Screening
Task 10 - Remedial
AlematK/es
Evaluation
SCREENING OF
ALTERNATIVES
Task 9 - Remedial
Alternatives
Screening
Task 10 -Remedial
Alternatives
Evaluation
DETAILED ANALYSIS
Task 10 -Remedial
Alternatives
Evaluation
Task 11- RI/FS
Reports
TO: SOR, ROD,
RD.RA
Task 12 -
Post RI/FS
Support
-------
OSWER Directive 9355.3-03
o Coordination with other agencies (Typically, the lead agency's RPM
is the focus for the coordination of all other agency and private
participation in site activities and decisions.)
o Coordination of subcontractors, if any, and description of health
and safety requirements and responsibilities
o Interface for Federal-lead projects with the Contract Laboratory
Program (CLP), if needed, to minimize sampling requirements by use
of field screening, to schedule analyses well ahead of sampling
trips, and to accurately complete CLP paperwork
o Cost control (including a description of procedures for contrac-
tors to report expenditures)
o Schedule control (including a description of schedule tracking
methods and procedures for contractors to report activities to the
lead agency)
o Identification of potential problems so that the RPM and site
manager can develop contingency plans for resolution of problems
during the RI/FS
o Evidentiary considerations, if needed, to ensure that project
staff members are trained with regard to requirements for admis-
sibility of the work in court
Cost and Key Assumptions. For Federal-lead sites, the RI/FS work plan
includes a detailed summary of projected labor and expense costs, broken
down by the 15 tasks listed in Figure 2-3 and described in Appendix B, and a
description of the key assumptions required to make such a cost estimate.
During scoping, more detailed costs typically are provided for the RI site
characterization tasks than for later phases of the RI/FS. The less-
detailed costs may be refined as field investigations progress and the
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OSWER Directive 9355.3-
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OSWER Directive 9355.3-pl
TABLE 2-3. SUGGESTED RI/FS WORK PLAN FORMAT
Executive Summary
1. Introduction
2. Site Background and Setting
3. Initial Evaluation
o Types and volumes of waste present
o Potential pathways of contaminant migration/preliminary
public health and environmental impacts
o Preliminary identification of operable units
o Preliminary identification of response objectives and
remedial action alternatives
4. Work Plan Rationale
o DQO needs
o Work plan approach
5. RI/FS Tasks
6. Costs and Key Assumptions
7. Schedule
8. Project Management
o Staffing
o Coordination
9. References
Appendixes
WDR229/049
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OSWER Directive 9355.3-0*
2.4.2 Sampling and Analysis Plan (SAP)
2.4.2.1 Purpose
The SAP consists of two parts: (1) a quality assurance project plan
(QAPP) that describes the policy, organization, functional activities, and
quality assurance and quality control protocols necessary to achieve DQOs
dictated by the intended use of the data; and (2) the field sampling plan
(FSP) that provides guidance for all fieldwork by defining in detail the
sampling and data-gathering methods to be used on a project. The FSP should
be written so that a field sampling team unfamiliar with the site would be
able to gather the samples and field information required. Guidance for the
selection and definition of field methods, sampling procedures, and custody
can be acquired from the Compendium of Superfund Field Operations Method
(EPA/540/P-87/001a, OSWER Directive 9355.0-14, September 1987). To the
extent possible, procedures from A Compendium of Superfund Field Operations
Methods should be incorporated by reference. In addition, the QAPP and FSP
should be submitted as a single document (although they may be bound
separately to facilitate use of the FSP in the field). These efforts will
streamline preparation of the document and reduce the time required for
review.
The purpose of the SAP is to ensure that sampling data collection
activities will be comparable to and compatible with previous data
collection activities performed at the site while providing a mechanism for
planning and approving field activities. The plan also serves as a basis
for estimating costs of field efforts for inclusion in the work plan.
2.4.2.2 Plan Preparation and Responsibilities
Timing. A SAP is prepared for all field activities. Initial prepa-
ration takes place before any field activities begin, but the SAP may be
amended or revised several times during the RI site characterization or
treatability post-screening investigations or during the FS as the need for
field activities is reassessed and rescoped.
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- •-- OSWER Directive 9355.3-01
Preparation and Review. EPA, the states, or the contractors should
prepare SAPs for all field activities performed. The lead agency's project
officer must approve the SAP. Signatures on the title page of the plan
usually show completion of reviews and approvals. Environmental sampling
should not be initiated until the SAP has received the necessary approvals.
A suggested format for a SAP is listed in Table 2-4.
2.4.2.3 Quality Assurance Project Plan Elements
Every QAPP should contain 14 elements. These are listed in Table 2-4
and described in detail in Appendix B.
It is important to note that the required information for each of the
elements of a QAPP need not be generated each time a QAPP is prepared. On^y
those aspects of a QAPP that are specific to the site being investigated
need to be explicitly described. If site-specific information is already
contained in another document (e.g., the FSP) it need only be referenced.
Similarly, any information contained in guidance documents such as the DQO
Guidance should only be referenced and not repeated in the QAPP.
2.4.2.4 Field Sampling Plan Elements
The second part of the SAP is the FSP. The FSP consists of the six
elements contained in Table 2-4. These elements are described more fully in
Appendix B.
2.4.3 Health and Safety Plan
2.4.3.1 Purpose
Each remedial response plan will vary as to degree of planning, special
training, supervision, and protective equipment needed. The health and
safety plan prepared to support the field effort must conform to the firm's
or agency's health and safety program which must be in compliance with OSHA.
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OSWER Directive 9355.3-
1
TABLE 2-4. SUGGESTED FORMAT FOR SAP (QAPP AND FSP)
QAPP
Title Page
Table of Contents
1. Project Description
2. Project Organization and Responsibilities
3. QA Objectives for Measurement
4. Sampling Procedures
5. Sample Custody
6. Calibration Procedures
7. Analytical Procedures
8. Data Reduction, Validation, and Reporting
9. Internal Quality Control
10. Performance and Systems Audits
11. Preventative Maintenance
12. Data Assessment Procedures
13. Corrective Actions
14. Quality Assurance Reports
FSP
1. Site Background (if not included in QAPP)
2. Sampling Objectives
3. Sample Location and Frequency
4. Sample Designation
5. Sampling Equipment and Procedures
6. Sample Handling and Analysis
WDR229/49
2-32
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OSWER Directive 9355.3-01
The site health and safety plan should be prepared concurrently with
the sampling plan to identify potential problems early, such as the avail-
ability of adequately trained personnel and equipment. The plan should
include maps and a detailed site description, results of previoijs sampling
activities, and field reports. The plan preparer should review site infor-
mation, along with proposed activities, and use professional judgment to
identify potentially hazardous operations and exposures and prescribe appro-
priate protective measures. Appendix B of the NIOSH/OSHA/USCG/USEPA Guid-
ance Manual (1985) provides an example of a generic format for a site health
and safety plan that could be tailored to the needs of a specific employer
or site; the elements required in a site health and safety plan are listed
in 29 CFR 1910.120.
2.4.3.2 Elements of the Health and Safety Plan
Each site health and safety plan should include, at a minimum, the
11 elements described in Appendix B.
2.4.3.3 Site Briefings and Inspections
The OSHA regulation requires that safety briefings be held "prior to
initiating any site activity and at such other times as necessary to ensure
that employees are apprised of the site safety plan and that it is being
followed."
The final component of site health and safety planning or informational
programs is site auditing to evaluate compliance with and effectiveness of
the site health and safety plan. The site health and safety officer or that
person's designee should carry out the inspections.
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OSWER Directive 9355.3-oB
2.4.4 Community Relations Plan
2.4.4.1 Purpose
The community relations plan (CRP) documents the community relations
history and the issues of community concern. It should describe the
techniques that will be employed needed to achieve the objectives of the
program. The plan is used by community relations staff, but it should also
be used by Federal and State agency technical staff members when planning
technical work at the site.
2.4.4.2 Community Relations Plan Elements
Report preparation methods, the elements contained in a CRP, and a
recommended format are included in Community Relations in Superfund; A
Handbook (U.S. EPA, January 1986). This handbook also includes useful
examples of community relations plans.
WDR229/049
2-34
-------
CHAPTER 3
SITE CHARACTERIZATION
FROM:
• PralMnvy
AttMsment
• Sle Inspection
• NPL Listing ,
SCOPING OF THE RVFS
SITE
PLANNING
PROJECT
PLANNING
OF
T_"" K
d4Mue»m»T»r \
"- % ^ ' \
-j "*' r
:, *' . , t
TREATABILITY
INVESTIGATIONS
i
\ ,
E»&araetr « (WeaEmnaoF .DETAILED
MtSlWM& [ ftfWHKfm& \OFALTE
/TO A
• Remedy Selection
ANALYSIS ^ . Ream) ol Decision
RNATIVES * . n.mraiaiD<»ign
• Remedial Action
.-x^--/ \ V J
SITE
CHARACTERIZATION
• Conduct Field Investigation
• Define Nature & Extent of
Contamination (Waste
Types, Concentrations,
Distributions)
• Identify Federal/State
Contaminant & Location
Specific ARARs
• Develop Baseline Risk
Assessment
• Refine Remedial Action
Goals
-------
OSWER Directive 9355.3-01
CHAPTER 3
SITE CHARACTERIZATION
3.1 INTRODUCTION
During site characterization, the sampling and analysis plan (SAP)
developed during project planning is implemented and field data are col-
lected and analyzed to determine to what extent a site poses a threat to
human health or the environment. The major components of site character-
ization are presented in Figure 3-1 and include:
o Conducting field investigations as appropriate
o Analyzing field samples in the laboratory
o Evaluating results of data analysis to characterize the site and
develop a baseline risk assessment
• o Determining if data are sufficient for developing and evaluating
potential remedial alternatives
Because information on a site may be limited prior to conducting an HI,
it is often desirable to conduct two or more iterative field investigations
so that sampling efforts can be better focused. Furthermore, as remedial
alternatives are assembled, screened, and evaluated, the need for more field
studies may be identified. As a result, rescoping can occur at several
points in the RI/FS process. During site characterization, rescoping and
additional sampling may occur if the results of field screening or onsite
laboratory analyses show that site conditions are significantly different
than believed during site and project planning. In addition, once the
sample analytical results have been received (either from a laboratory or
3-1
-------
FIGURE 3-1 OSWER Directive 9355.3-01
MAJOR COMPONENTS OF SITE CHARACTERIZATION
Data Management
• Field Procedures
• Field Measurements
Conduct Field
Investigation
Data Management
- Laboratory
Sample Analysis
(Laboratory)
I
Data Management
- Analytical Data
Data Evaluation
- Site Characterization
Preliminary
Site
Characterization
Summary
Reevaluate
Data Needs ?
Rescope Investigation ( Repeat
the Previous Scoping Steps):
• Determine New Data Needs
Revise Sampling Strategies- and
Analytical Support Level (if needed
- Amend QAPP/FSP, HSP, and
Work Plan
Data Evaluation
- Risk Assessment
Conduct
Interim
Action(s)
Interim
Action(s) Needed?
Data
Sufficient for
Alternative
Development?
Alternative
Development
Draft
Rl Report
-------
OSWER Directive 9355.3-01
a mobile lab) and the data analyzed, it must be decided if further sampling
is needed to support the FS or if data are sufficient to assess risks and
initiate the development of alternatives. At this time, it is usually
apparent whether the data needs identified during project planning were
adequate and whether those needs were satisfied by the first round of field
sampling. As discussed in Chapters 4 and 5, there are also points during
the FS when the need for additional field studies may be identified. These
additional studies can be conducted during subsequent site characterization
activities.
To facilitate ATSDR's health assessment of a site, the lead agency
should provide data obtained during site characterization to ATSDR for its
use in conducting a health assessment. Guidance for coordinating remedial
and ATSDR health assessment activities is provided in OSWER Directive
9285.4-02. The lead agency is also responsible for providing information to
the support agency on the types of contaminants and affected media for
identification of State (for a Federal-lead site) or Federal (for a
State-lead site) ARARs.
This chapter provides detailed descriptions of those activities that
may be required during the RI site characterization. As discussed earlier,
the complexity and extent of potential risks posed by Superfund sites is
highly variable. Therefore, the lead and support agencies will have to
decide on a site-specific basis which of the activities described in this
chapter must be conducted to adequately characterize the problem(s) and help
in the evaluation of potential alternatives.
3.2 FIELD INVESTIGATION METHODS
Field investigation methods employed in RIs are selected to meet the
data needs established in the scoping process and outlined in the work plan
and SAP. This section provides an overview of the type of site characteriza-
tion data that may be required and the investigative methods used in obtain-
ing these data. The following sections describe methods for (1) implementing
field activities, (2) investigating site physical characteristics, (3) defin-
ing the sources of contamination, and (4) determining the nature and extent
3-3
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OSWER Directive 9355.3-01
of contamination. Specific information on the field investigation methods
described below is contained in A Compendium of Superfund Field Operations
Methods (EPA/540/P-87/001a, OSWER Directive 9355.0-14, September 1987).
Sections in A Compendium of Superfund Field Operations Methods that apply to
particular types of field investigations are shown in Table 3-1.
3.2.1 Implement Field Activities
In addition to development of the SAP, fieldwork support activities,
such as the following, are often necessary before beginning fieldwork:
o Assurance that access to the site and any other area to be
investigated has been obtained
o Procurement of subcontractors such as drillers, excavators,
surveyors, and geophysicists
o Procurement of equipment (personal protective ensembles, air
monitoring devices, sampling equipment, decontamination apparatus)
and supplies (disposables, tape, notebook, etc.)
o Coordination with analytical laboratories, including sample
scheduling, reporting, chain-of-custody records, and sample bottle
acquisition and procurement of close support laboratories or other
in-field analytical capabilities
o Procurement of onsite facilities for office space, onsite labora-
tory, decontamination, equipment and vehicle maintenance and
repair, and sample storage, as well as onsite water, electric,
telephone, and sanitary utilities
o Provisions for storage or disposal of contaminated material (e.g.,
decontamination solutions, disposable equipment, drilling muds and
cuttings, well-development fluids, well-purging water, and
spill-contaminated materials)
3-4
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OSWER Directive 9355.3-01
Table 3-1
RELATIONSHIP AMONG SITE CHARACTERIZATION TASKS
AND THE COMPENDIUM
Tasks
Field Investigation
Air
Biota
Close support laboratories
RI-derived waste disposal
Soil gas
Support
Well logging
Mapping and survey
Geophysical
Nell installation
Ground water
Soil
Source testing
Surface water
Sample analysis
Fieldwork, close support laboratory
Data validations
Sample management
Data evaluation
Applicable Sections and Subsections
of the Compendium of Superfund
Field Operations Methods
1, U, 15
12
5.2, 7, 15
3.2, 5.2.6.4, 8.1.6.3
3, 17, 18, 19, 20
8.1, 8.3
14
8.4
8.1, 8.5
8.5
8.1, 8.2, 8.3
7, 13, 15
10
5.2, 15
16
4, 5, 6
16
NDR243/063
3-5
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OSWER Directive 9355.3-01
Since procurement activities can take up to several months, they should
be initiated as early as possible so as not to affect the overall RI/FS
schedule. Schedule impacts should also be avoided by structuring contracts,
where possible, such that there is no need to reprocure services for subse-
quent site characterization activities. This may be accomplished using
contract options that are exercised only in the event that additional
services or facilities are required.
Mobile labs or labs located near the site can often reduce the time
necessary for completing RI activities. If such quick-turnaround analysis
is available, it can be used to determine the location and type of subse-
quent sampling that must take place to more completely characterize the
site. This may also alleviate the need to reprocure subcontractors, and
significantly accelerate the completion of the RI. It is important to note
that if such analytical techniques are to be employed, the work plan and SAP
should allow for decisions on subsequent activities to be made in the field
with verbal approval from key management personnel.
3.2.2 Investigate of Site Physical Characteristics
Data-on the physical characteristics of the site and surrounding areas
should be collected to the extent necessary to define potential transport
pathways and receptor populations and to provide sufficient engineering data
for development and screening of remedial action alternatives. Information
normally needed can be categorized as surface features (including natural
and artificial features), geology, soils, surface water hydrology,
hydrogeology, meteorology, human populations, and land uses and ecology.
3.2.2.1 Surface Features
Surface features may include facility dimensions and locations
(buildings, tanks, piping, etc.), surface disposal areas, fencing, property
lines and utility lines, roadways and railways, drainage ditches, leachate
springs, surface-water bodies, vegetation, topography, residences, and
3-6
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OSWER Directive 9355.3-01
commercial buildings. Features such as these are usually identified for
contaminant migration and the location of potentially affected receptors.
Investigation of surface features should not be limited to ;those that
are onsite, but should include significant offsite features as well. Other
facilities in the area that are potential contributors to contamination
should also be identified.
A history of surface features at the site can be developed from
existing data. As discussed in Chapter 2, "Scoping," the data may include
historical photographs, past topographic surveys, operational records, and
information obtained during interviews with owners, operators, local resi-
dents, and local regulatory agencies. Review of historical photographs is
sometimes the most valuable of these methods. Aerial photographs are often
available from such sources as the Environmental Monitoring Support Labora-
tory, Las Vegas (EMSL-LV), the Environmental Photographic Intrepretation
Center (EPIC), and the Soil Conservation Service of the USDA.
Existing surface features may be described using aerial photography,
surveying and mapping, and site inspection. Inspection of the site and the
surrounding areas is normally augmented with photographs. Section 14 of
A Compendium of Superfund Field Operations Methods presents additional
details on land surveying, aerial photography, and mapping.
3.2.2.2 Geology
Geology may control or affect the following aspects of a site:
o The depths, locations, and extents of water-bearing units or
aquifers
o The release of contaminants and subsequent movement through the
environment
3-7
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OSWER Directive 9355.3-01
o The engineering geologic aspects of site exploration and
remediation
Table 3-2 summarizes detailed aspects of site geology. The
investigation of site geology must be tailored to ensure identification of
those aspects that will affect the fate and transport of contaminants. For
example, an understanding of site geology is less important at a site at
which release of contaminants occurs by volatilization to the atmosphere
than at a site at which contaminants are moving toward the water table.
To understand the geology of a site, one must determine the geology of
bedrock and of unconsolidated overburden and soil deposits. Table 3-1
summarizes specific aspects of overburden and bedrock geology. The degrees
to which overburden and bedrock geology must be understood depend on the
geologic character of the site area, as well as on the physical
characteristics of the site itself. An understanding of the regional
geologic character of a site is useful in determining which aspect of site
geology may have the greatest influence on the determination of the fate and
transport of contaminants and on the use of potential remedial technologies.
In general, an investigation of site geology should include the
following steps:
o Determination of regional geology from available information
o Reconnaissance mapping of the area, which may include geophysical
investigations onsite
o Subsurface explorations
The degree to which these steps are undertaken will be determined by
the degree to which the need to evaluate geologic aspects of the site
dictates the investigations needed in the RI/FS process. Table 3-2
discusses these investigation methods, and the methods are described in
detail in Chapter 8 of A Compendium of Superfund Field Operations Methods.
3-8
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OSHER Directive 9355.3-01
Table 3-2
SUMMARY OF SITE GEOLOGY
Information Needed
o Geology of unconsolldated
overburden and soil deposits
- Thickness and areal extent
of units
- Llthology; mineralogy
- Particle size and sorting;
porosity
o Geology of bedrock
- Type of bedrock (Igneous,
metamorphic, sedimentary)
- Llthology; petrology
- Structure (folds, faults)
- Discontinuities (joints,
fractures, bedding planes,
foliation)
- Unusual features such as
igneous intrusive bodies
(dikes), lava tubes,
solution cavities in
linestone (Karst)
Purpose or Rationale
Collection Methods
For both unconsolidated and bedrock geology:
o Evaluate the influence of geology on
water-bearing units and aquifers
o Evaluate the influence of geology on
release and movement of contaminants
o Obtain Information on the engineering
geologic aspects of site remediation
For both unconsolldated and bedrock geology:
o Determination of regional geology from
available information
- Published reports (geologic reports,
ground-water reports, soil survey reports)
- State geologic maps
- USGS topographic quadrangle maps
- Descriptions of regional geology from
previous reports of site Investigations
o Site reconnaissance mapping
- Field mapping of surficial soil and
overburden units, bedrock outcrops,
surface water drainage, springs, and seeps
- Analyses of aerial photography or other
remote imagery
- Surface geophysics
o Subsurface explorations
- Test borings or core borings (with or
without sampling)
- Test pits and trenches
- Description and logging of subsurface
geologic materials
- Sample collection for laboratory analyses
of physical properties and mineral content
- Borehole geophysics '
HDR243/036
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OSWER Directive 9355.3-01
3.2.2.3 Soils and the Vadose Zone
Properties of surface soils and the vadose zone influence the type and
rate of contaminant movement to the subsurface and subsequently to the water
table. Contaminants that can move through the surface soil and into the
vadose zone may move directly to the water table or they may be partially or
fully retained within the vadose zone to act as continual sources of ground-
water contamination. Engineering, physical, and chemical properties of soil
and vadose zone materials can be measured in the field or in the laboratory.
Table 3-3 summarizes typical investigation methods.
3.2.2.4 Surface-Water Hydrology
Surface-water features may include erosion patterns and surface-water
bodies such as ditches, streams, ponds, and lakes. The transport of con-
taminants in surface-water bodies is largely controlled by flow, which in
streams is a function of the gradient, geometry, and coefficient of fric-
tion. A description of how flow is measured can be found in Section 10 of
A Compendium of Superfund Field Operations Methods. Contaminants have three
possible modes of transport: (1) sorption onto the sediment carried by the
flow, (2) transport as suspended solid, and (3) transport as a solute (dis-
solved) . The transport of dissolved contaminants, which move the fastest,
can be determined by characterizing the flow of the surface water and the
contaminant dispersion. Sediment and suspended solid transport involve
other processes such as deposition and resuspension. Table 3-4 presents the
surface-water information that may be required for RIs.
If potential pathways include surface water, necessary data about
impoundments may include (1) physical dimensions such as depth, area, and
volume; (2) residence time; and (3) current direction and rates. As with
impoundments, the direction and velocity of lake currents are often highly
variable and, as a result, are difficult to measure and accurately predict.
Site mapping will provide much of this information. Measurement techniques,
which are specified in Section 10, Surface Hydrology, of A Compendium of
Superfund Field Operations Methods, include the use of current meters and
drogue tracking.
3-10
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OSMDt Directly* 9355.3-01
Table 3-3
SUMMARY Of SOIL AND VADOSE ZONE INFORMATION
Potential Information Heeded
Soil Characteristics:
Type, holding capacity,
temperature, biological
activity, engineering
properties
Purpose or Rationale
Estimate the effect of the
properties on Infiltration and
retardation of leachates and the
release of gaaeoui contaminants
Collection Methods
Reports and mays by Federal
and county agencies, Soil
Conservation (SCSI publications
Secondary
Borehole sampling, laboratory measurements (ASTH methods),
vater budget methods. Instantaneous rate method, seepage
meters, Inflltroa«ters, test basins
Soil Chemistry Cbaracterlstlcs:
Solubility, Ion speciatlon,
adsorption coefficients,
teachability, cation exchange
capacity, Mineral partition
coefficients, diealcal and
•orptlve properties
Predict contiailnant movement
through soils and availability
of contaminants to biological
systems
Existing scientific literature
Chemical analysis, column experiments, leaching tests
Vadose Zone Characteristics:
Permeability, variability,
porosity, moisture content,
chemical characteristics,
extent of contamination
o Estimate flux In the vadose sone Existing literature
Hater budget with soil moisture accounting '
Draining profile methods
Measurement of hydraulic gradients
Estimates assuming unit hydraulic gradient
Flow meters
Methods based on estimating or measuring hydraulic
conductivity, using:
o Laboratory parameters
o Relationships between hydraulic conductivity and grain slse
o Catalog of hydraulic properties
o Field measurements of hydraulic conductivity using single
or multiple veils
o Estimate velocity in the vadose
Existing literature
o Tracers
o Calculations using fins values
o Calculation using long-term Infiltration data
o Evaluate pollutant movement in
the vadose lone
Existing literature
Four probe electrical method
Electrical conductivity probe
Salinity sensors
Solids sampling followed by laboratory extraction of pore vater
Solids sampling for organic and mlcroblal constituents
Suction Lyslmetera
Sampling perched ground vater
HDR243/040
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OSWER Directive 9355.3-01
Table 3-4
SUMMARY OF SURFACE-HATER INFORMATION THAT MAY BE IMPORTANT TO SITE CHARACTERIZATION
Information Needed
Purpose or Rationale
Appropriate Collection Methods
Primary
Secondary
Drainage Patterns:
Overland flow, topography,
channel flow pattern,
tributary relationships,
soil erosions, and sediment
transport and deposition
Determine if overland or
channel flow can result in
onslte or offsite flow and if
patterns form contaminant
pathways
Topographic maps, site inspec-
tion, and soil conservation
services
Aerial mapping, and ground
survey
Surface-Hater Bodies:
o Flow, stream widths and
depths, channel elevations,
flooding tendencies, and
physical dimensions of
surface-water Impoundments
o Structures
Determine volume and
velocity, transport times,
dilution potential, and
potential spread of
contamination
Effect of manmade structures
on contaminant transport and
mitigation
Public agency data and
atlases; catalogs, maps, and
handbooks for background data
Public agency maps and records
and ground survey
Aerial mapping, and ground
survey
Surface-water/ground-water
relationships
Predict contaminant pathways
for interceptive remedial
actions
Public agency reports and
surveys
Nater level measurements,
and modeling
Surface-Hater Quality:
o pH, temperature, total sus-
pended solids, suspended
sediment, salinity, and
specific contaminant
concent rat ions
Provide capacity of water to
carry contaminants and water/
sediaent partitioning
Public agency computerized
data files, handbooks, and
open literature
Sampling and analysis
'041
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OSWER Directive 9355.3-01
3.2.2.5 Hydrogeology
Determination of site hydrogeology involves identification of geologic
aspects, hydraulic properties, and ground-water use, as defined in Tables 3-5
and 3-6 and described in Chapter 8 of A Compendium of Superfund Field
Operations Methods. The determination of site geology and hydrogeology can
often be incorporated into a single investigative program. Regional hydro-
geologic conditions can be determined from existing information; site-
specific hydrogeologic conditions can be determined using subsurface
explorations, well installations, and field testing of hydraulic properties.
Table 3-7 summarizes the typical data collected during a hydrogeologic
investigation and available analytical methodologies.
3.2.2.6 Meteorology
Meteorological data are often required to characterize the atmospheric
transport of contaminants for risk assessment determinations and provide
real-time monitoring for health and safety-issues. Representative offsite
and site-specific data may be obtained using sampling methods outlined in
Section 11, "Meteorology and Air Quality," of A Compendium of Superfund
Field Operations Methods. This publication also discusses data requirements
for using refined air quality modeling and applicable models. Table 3-8
summarizes atmospheric investigations.
3.2.2.7 Human Populations
Information should be collected to identify, enumerate, and
characterize human populations potentially exposed to contaminants released
from a site. For a potentially exposed population, information should be
collected on population size and location. Special consideration may be
given to identifying potentially sensitive subpopulations such as children,
pregnant women, infants, and the chronically ill. The identification of
these high-risk subpopulations should be linked with the potential
contaminants of concern (i.e., those that are mutagenic, teratogenic, etc.)
3-13
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OSWER Directive 9355.3-01
Table 3-5
ASPECTS OP SITE HYDROGEOLOGY
Geologic aspects
Type of water-bearing unit or aquifer (overburden, bedrock)
Thickness, areal extent of water-bearing units and aquifers
Type of porosity (primary, such as intergranular pore space, or
secondary, such as bedrock discontinuities or solution cavities)
Presence or absence of impermeable units or confining layers
Depths to water table; thickness of vadose zone
Hydraulic aspects
Hydraulic properties of water-bearing unit or aquifer (hydraulic
conductivity, transmissivity, storativity, porosity/ dispersivity)
Pressure conditions (confined, unconfined, leaky confined)
Ground-water flow directions (hydraulic gradients, both horizontal
and vertical), volumes (specific discharge), rate (average linear
velocity)
- Recharge and discharge areas
- ' Ground-water or surface water interactions; areas of ground-water
discharge to surface water
Seasonal variations of ground-water conditions
Ground-water use aspects
Identify existing or potential aquifers
Determine existing near-site use of ground water
WDR243/037
3-14
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OSWER Directive 9355.3-01
Table 3-6
FEATURES OF GROUND-WATER SYSTEMS
Components of the ground-water system
Unconfined aquifers
Confining beds
Confined aquifers
Presence and arrangement of components
Water-bearing openings of the dominant aquifer
Primary openings
Secondary openings
Storage and transmission characteristics of the dominant aquifer
Porosity
Transmissivity
Recharge and discharge conditions of the dominant aquifer.
WDR243/038
3-15
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OSHER Directive 9355.3-O1
Table 3-7
SUMMARY OF IMPORTANT GROUND-HATER INFORMATION
Information Needed
Ground-Hater Occurrence:
o Aquifer boundaries and
locations
o Aquifer ability to
transmit water
Ground-Hater Movement:
o Direction of flow
u>
M
a\
o Rate of flow
Purpose or Rationale
Define flow limits and degree
of aquifer confinement
Determine potential
quantities and rates for
treatment options
Identify most likely pathways
of contaminant migration
Determine maximum potential
migration rate and dispersion
of contaminants
Appropriate Collection Methods
Primary
Existing literature,
water resource atlases
Pumping and injection
tests of monitor wells
Existing hydrologic
literature
Existing hydrologic
literature
Secondary*
Installation of wells and pleiometers
(single level or multilevel)
Ground-water level measurements (over
time to monitor seasonal variations)
Instrument survey of wells for
calculation of ground-water elevations
Borehole and surface geophysics
Hater level
wells
easurements in monitor
Testing of hydraulic properties using
slug tests, tracer tests, and pump
tests (short- or long-duration, single
or multiple well)
Elevation contours of water table or
potentiometrlc surface
Analytical calculations of flow
directions and rates
Computer generated simulations of
ground-water flow and contaminant
transport (using analytical or
numerical methods)
Generation of site water balance
Hydraulic gradient, permeability, and
effective porosity from water level
contours, pump test results, and
laboratory analyses
*May be appropriate If detailed Information is required or If it is the only method due to a paucity of published data.
-------
OSIER Directive 9355.3-01
Table 3-7 (continued)
Information Needed
%
Ground-Hater Recharge/Discharge:
o Location of recharge/
discharge areas
o Rate
Ground-Hater Quality:
o pH, total dissolved solids,
salinity, specific con-
taminant concentrations
Purpose or Rationale
Determine Interception points
for withdrawal options or
areas of capping
Determine variability of
loading to treatment options
Determine exposure via ground
water; define contaminant
plume for evaluation of
interception methods
Appropriate Collection Methods
Secondary*
Existing site data,
hydrologic literature,
site inspection
Existing literature
Existing site data
Comparison of water levels in
observation wells, piezometers, lakes,
and streams
Field mapping of ground-water recharge
areas (losing streams, interstream
areas) and ground-water discharge to
surface water (gaining streams, seeps,
and springs)
Hater-balance calculations aided by
geology and soil data
Analysis of ground-water samples from
observation wells, geophysics
*May be appropriate if detailed information is required or If it is the only method to a paucity of published data.
HDR243/039
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OSHEP Directive 9355.3-01
Table 3-8
SUMMARY OF IMPORTANT ATMOSPHERIC INFORMATION
Information Needed
Local Climate:
o Precipitation
o Temperature
o Hind speed and direction
o Presence of inversion layers
Purpose or Rationale
Define recharge, aeolian ero-
sion, evaporation potential,
effect of weather patterns on
remedial actions, area of
deposition of participates
Appropriate Collection Methods
Secondary
(HOC)
National Climate Center
of National Oceanic and
Atmospheric Administration;
local weather bureaus
Onslte measurements and
observations
• Heather Extremes:
GO
o Storms
o Floods
o Hinds
Determine effect of weather
extremes on selection and
timing of remedial actions,
and extremes of depositlonal
areas
NCC; State emergency planning
offices; Federal Emergency
Management Agency flood insurance
studies
Release Characteristics:
o Direction and speed of plume
movement
o Rate, amount, temperature of
release
o Relative densities
Determine dispersion
characteristics of release
Information from source
facility, weather services,
air monitoring services
Onslte measurements
243
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OSWER Directive 9355.3-01
to identify, how these populations may be at risk. Census and other survey
data may be used to identify and describe the population exposed to various
contaminated media. Information may also be available from USGS maps, land
use plans, zoning maps, and regional planning authorities.
Data describing the type and extent of human contact with contaminated
media also are needed, including:
o Location and use of surface waters
Drinking water intakes and distribution
Recreational (swimming, fishing) areas
Connection between surface-water bodies
o Local use of ground water as a drinking-water source
Number of wells
Distance of wells from the site
Expected direction of ground-water flow
Depth of wells
Availability of alternate sources
o Human use or access to the site and adjacent areas
Recreational use
Hunting
Fishing
Residential
Commercial
o Location of population with respect to site
Proximity
„ - Prevailing wind direction
3-19
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OSWER Directive 9355.3-01
Information on expected land use, as well as current land use, is
desirable. Available population growth projections, land use plans, and
zoning maps can help predict expected exposure scenarios. This information
may be obtained from zoning boards, the census bureau, regional planning
agencies, and other local governmental entities.
3.2.2.8 Ecological Investigations
Biological and ecological information collected for use in the risk
assessment aids in the evaluation of impacts to the environment associated
with a hazardous waste site and also helps to identify potential effects
with regard to the implementation of remedial actions. The information
should include a general identification of flora and fauna in and around
the site (including endangered and threatened species and those consumed by
humans or found in human food chains) and identification of critical habi-
tats. Bioassay information may be needed for species that are known to be
consumed by humans. Chapter 12 of A Compendium of Superfund Field Opera-
tions Methods and Table 3-9 provides a summary of both environmental infor-
mation that may be needed and potential collection methods. The Natural
Resources Trustee for the site should be contacted to determine if other
ecological data are available that may be relevant to the investigation.
3.2.3 Define Sources of Contamination
Sources of contamination are often hazardous substances contained in
drums, tanks, surface impoundments, waste piles, and landfills. In a prac-
tical sense, heavily contaminated media (such as soils) may also be consid-
ered sources of contamination, especially if the original source (such as a
leaking tank) is no longer present on the site or is no longer releasing
contaminants.
Source characterization involves the collection of data describing
(1) facility characteristics that help to identify the source location,
potential releases, and engineering characteristics that are important in
the evaluation of remedial actions; (2) the waste characteristics, such as
3-20
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OOCR Directive 9355.3-01
3-9
SUMAFY CF DfCRISNr BOCUDGKAL INKFMOTCN
Fcuna and Flora
Critical Habitats
Land Use Characteristics
Vfater Use Characteristics
Bicocntandnation
Purpose or Rationale
Determine potentially
affected ecosystems;
determine presence of
endangered species
Determine area en car near
site to be protected during
remediation
Determine if terrestrial
envircrnent could result in
nvman exposure, e.g.,
presence of game animals,
agricultural land
Determine if aquatic
environment could result in
luran exposure, e.g.,
presence of game, fish,
recreational water
Determine observable impact
of contaminants on ecosystems
Primary
Records of area plants and
animals survey, survey of
plants and animals en or near
site; survey of site or area
ftS
appropriate Collection Methods
RtynnTs of site environment
Agricultural and development
maps; site survey
Vbter resource agency reports;
site surveys
Records of site environment
Secondary
Gfcound surveys and sample
collection
Gteund survey
Gkcund and aerial survey
Sampling and analysis
VCR243/D43
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OSWER Directive 9355.3-01
the type and quantity of contaminants that may be contained in or released
to the environment; and (3) the physical or chemical characteristics of
hazardous wastes present in the source. Key source characterization data
are summarized in Table 3-10.
The location and type of containment should be determined for all
sources. In addition, where the hazardous substance remains in containment
vessels, the integrity of the containment structure should be determined so
that the potential for release and its magnitude can be evaluated. This
determination is especially important for buried drums or tanks, because
corrosion may be rapid. These data, as well as the data identified in
Table 3-10, may be obtained largely through site inspections, mapping,
remote sensing, and sampling and analysis.
The waste type should be determined for each source. If available
waste manifests or facility records can be reviewed, the industrial
processes that resulted in generation of the waste can be determined and the
types of contaminants usually present in the process waste can be
identified. Often, sources are sampled and analyzed for contaminants found
on the Target Compound List (TCL) (formerly the Hazardous Substances List)
or.other lists such as those developed for RCRA, as appropriate to the waste
type. Quantities of wastes may be estimated for each waste type either from
verifiable inventories of wastes, from sampling and analysis, or from
physical dimensions of the source. Section 13 of the Compendium of
Superfund Field Operations Methods and Ford, Turina, and Seely (1983)
describe methods suitable for sampling and analysis.
It may be possible to determine the location and extent of sources and
the variation of materials within a waste deposit by nonchemical analysis.
Methodologies for this determination, which are described in Chapter 8 of
the Compendium of Field Operations Methods, include geophysical surveys. A
variety of survey techniques (e.g., ground-penetrating radar, electrical
resistivity, electromagnetic induction, magnetometry, and seismic profiling),
can effectively detect and map the location and extent of buried waste depos-
its. Aerial photography and infrared imagery can aid in defining sources
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C8WR Directive 9355.3-01
Ttsble 3-10
SCMttFY CF TtfCfOfm 3CUCE 3NPQRKFICN
Information
y Needed
Facility Characteristics:
o Source location
o Type of waste/chemical
oontairment
o Integrity of waste/chemical
oontaiment
Purpose or Rationale
locate above-ground and
flBiTsEtf n f^cf* <*i'•!• ffm rMi it
sources
Determine potential remedies
for releases
Determine probability of
release and timing of
Collection Methods
Primary
Site inspection facility
records, archival photos
Site inspection
Site inspection
Remote sensing, sampling, and
analysis
Remote sensing
Sampling and analysis;
nondestructive testing
o Drainage control
o Engineeered stn.ictm.tas
o Site security
o Known discharge points
(outfalls, stacks)
Determine probability of
release to qirfapp water
Identify poffsIM^ conduits
for migration or interference
with remedial actions
Determine potential for
e>qposure by direct contact;
may dictate response
Determine points of
accidental or intentional
discharge
Site inspection; topographic
naps
Site inspection; facility
records
Site inspection
Site inspection; facility
records
Rsnote sensing
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06WR Directive 9355.3-01
•Table 3-10 (continued)
Information Typically Needed
o tapping and surveying
Vbste Characteristics:
o Type
o Quantities
o Chemical and physical
properties
o Obnoentraticns
Purpose or Rationale
Locate existing structures
and obstructions for
alternatives evaluation, site
features, and topography
Determine contaminants for
eaqposure assessments and Łor
treatment options
Determine magnitude of
potential releases
Determine environmental
mobility, persistence, and
effects; determine
parameters for development
and evaluation of
alternatives
Determine quantities and
concentrations potentially
released to environmental
pathways
Collection
Primary
Existing maps (U9G5, county,
land development)
Site inspection; waste
manifests
Site inspection
Site inflection, handbooks,
CHEMiKtivtIMERDS, Chemical
Infonnaticn Service (CIS),
and facility records
Site inspection
Secondary
Remote sensing; surveying
Sampling and analysis
Sampling and analysis;
geophysical surveys
Sampling and analysis
Sampling and analysis
VCR243/044
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OSWER Directive 9355.3-01
through interpretation of the ecological effects that result from stressed
biota. However, all of these geophysical methods are nonspecific, and
subsequent sampling of the sources will probably be required to provide the
data for evaluation of source control measures at the site.
3.2.4 Determine the Nature and Extent of Contamination
The final objective of the field investigations is to characterize the
nature and extent of contamination. This process involves using the
physical site characterization data (e.g., ground-water flow directions,
overland flow patterns) to give a preliminary estimate of the locations of
contaminants that may have migrated. An iterative monitoring program is
then implemented so that, by using increasingly accurate analytical
techniques, the locations and concentrations of contaminants that have
migrated into the environment can be documented.
The sampling and analysis approach that should be used is discussed in
Section 4.5.1 of the DQO Guidance. In short, the approach consists of,
where appropriate, initially taking a large number of samples using field
screening type techniques and then, based on the results of these samples,
taking additional samples—to be analyzed more rigorously—from those
locations that showed the highest concentrations in the previous round of
sampling. The final step is to document the extent of contamination using
an analytical level that yields data quality that is sufficient to serve as
input to a risk assessment and to a subsequent analysis and selection of
remedial alternatives.
At hazardous waste sites, the nature and extent of contamination is of
concern in five media: ground water, soil, surface water, sediments, and
air. The methodologies for conducting sampling and analysis for each of
these media are discussed below. More detailed descriptions of the
investigation process can be found in the DQO Guidance and A Compendium of
Superfund Field Operations Methods.
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OSWER Directive 9355.3-01
3.2.4.1 Ground Water
The nature and extent of ground-water contamination must be determined
in both the horizontal and vertical directions. On the basis of geologic
and hydrogeologic investigations, it must be determined if contamination of
an aquifer(s) is possible and if such contamination could potentially affect
human or environmental receptors. Following this, a ground-water monitoring
program should be implemented, concentrating the placement of wells in the
direction of ground-water flow, in aquifers subject to contamination, and in
places where they would indicate an existing or future threat to receptor
populations. However, because of the uncertainties associated with
subsurface migration, identifying background levels, and determining if
there is a contribution from other sources, sampling should also be
conducted in the area perceived to be upgradient from the contaminant
source.
Because of the significant investment necessary to drill new wells and
the resulting limited number of samples, neither Level I nor field-screening
techniques are appropriate for analysis of ground water, other than to
possibly better define chemical analysis parameters. Geophysical techniques
can be useful in identifying the location of plumes and thereby assisting in
the location of monitoring wells. However, geophysical techniques are
subject to influences from external factors and are not appropriate at all
sites. Therefore, care must be taken in employing these methods, and their
results should always be confirmed with analytical sampling. Guidance on
conducting ground-water sampling can be found in A Compendium of Superfund
Field Operations Methods and the DQO Guidance.
3.2.4.2 Soil
As with ground-water sampling, the intent of soil sampling is to
identify limits of existing soil contamination and characterize the
contamination. However, whereas field-screening techniques can be
inappropriate for ground-water sampling, these techniques are appropriate
for directing soil sampling into areas of greatest contamination or "hot
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OSWER Directive 9355.3-01
spots." If existing information provides no basis for predicting where hot
spots might occur, sampling locations can be chosen in a grid pattern of a
size to ensure that investigators can be confident that areas of high
concentration have been located. Often, especially if soil has been
contaminated as a result of overland flow of contaminants from defined
sources, sampling can be concentrated in those areas that, either through
topography or evidence such as drainage channels, it is most likely that
contaminants have been deposited.
As with ground water, soil contamination should be documented in both
vertical and horizontal directions. This approach will help determine both
areas of contamination and background concentrations. Soils to be analyzed
usually can be obtained by hand, allowing many samples to be taken and
initially analyzed with instruments such as a photoionization detector.
Results of field screening can then be used to determine which samples
should be further analyzed using more rigorous methods.
3.2.4.3 Surface Water
Leachate from contaminant sources or discharge of contaminated ground
water can cause surface water to become contaminated. Surface-water
sampling locations should be chosen at the perceived location(s) of
contaminant entry to the surface water and downstream, as far as necessary,
to document the extent of contamination. As with soil, the relative ease
with which samples can be taken means that many samples can be taken and
analyzed using field screening methods; then a subset of samples can be
chosen for more rigorous analysis.
Contamination of surface water is sometimes the result of an incidental
release of contaminants such as the overflowing or breach of a surface
impoundment. In these cases, it is not likely that routine surface water
sampling will show contamination that has or will occur. Therefore, to
document whether such releases occur, sampling should be conducted during or
following periods of heavy rainfall.
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OSWER Directive 9355.3-01
3.2.4.4 Sediments
A potentially more serious problem associated with the contamination of
surface water by hazardous waste sites is contaminated sediments. Whereas
contamination in surface water tends to become diluted or transformed as it
travels downstream, contaminants deposited in sediments tend to remain in
place and concentrate. It is therefore very important to monitor for
sediment contamination if it is suspected that surface water has been
contaminated.
The choice of sampling locations for sediments is similar to the
criteria applied to surface-water sampling. Field-screening techniques can
be useful in defining areas of contamination. However, it should be noted
that sediment contamination often consists of inorganics and/or nonvolatile
organics, for which field screening techniques are not as applicable.
Therefore, in designing a sampling program, consideration of the
contaminants of concern is very important.
3.2.4.5 Air
Volatilization of organics and emissions of airborne particulates can
be a concern at hazardous waste sites. For sites at which it appears that
air emissions may be a problem (e.g., surface impoundments containing
volatile organics, landfills at which there is evidence of methane gas
production and migration), an air emissions monitoring program should be
undertaken. A field-screening program is recommended to determine if there
is an air pollution problem, both for volatile organics and fugitive dust
emissions. Because of the highly variable nature of air emissions from
hazardous waste sites, consideration of meteorological conditions at the
time of sampling is essential for the proper documentation of potential air
pollution.
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OSWER Directive 9355.3-01
3.2.5 Additional Site Characterization
In some situations, additional site information may be required to
refine our understanding of the site and better evaluate specific remedial
alternatives. Examples include:
o Better delineation of contaminated areas and depths of
contamination so that quantities of contaminated media to be
processed can be calculated more accurately
o Characteristics of the media that would affect the feasibility of
the remedial alternative, such as soil permeability for soil-vapor
extraction
o Pertinent site characteristics not initially discovered in the
initial site characterization process
Before additional site characterization is initiated, the most recent
QAPP/FSP should be reviewed and modified as appropriate to guide the
collection of additional site data. In addition, site data collected and
evaluated as part of the initial RI site characterization should be reviewed
and compared to the data needs identified for conducting the detailed
analysis of alternatives. Reviewing data needs during the preplanning step
is also useful in predicting the approximate characteristics of the samples
to be collected.
3.3 LABORATORY ANALYSES
Data that will be used as the basis for decisionmaking requires that
the analysis of samples in laboratories meets specific QA/QC requirements.
To meet these requirements, Federal- or State-lead site investigations have
the option of using mobile labs; the CLP, which is established by EPA; or a
non-CLP laboratory that meets the data quality objectives of the site
investigation.
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OSWER Directive 9355.3-01
The CLP provides analytical services through a nationwide network of
laboratories under contract to EPA. The lead agency chooses whether or not
to use a CLP laboratory on the basis of available CLP capacity and the
analytical requirements that meet the data quality objectives. If the CLP
is not used, a laboratory is procured using standard bidding procedures.
Under the CLP, the majority of analytical needs are met through
standardized laboratory services provided by Routine Analytical Services
(RAS). However, other specialized types of analysis not yet provided by
standardized laboratory contracts may be scheduled on an as-needed basis
under the Special Analytical Services (SAS) program. The RAS program
currently provides laboratory services for the analysis of organics and
inorganics in water or solid samples. The SAS program is designed to
complement the RAS program by providing the capability for specialized or
custom analytical requirements. If an analytical need is not ordinarily
provided by RAS, a specific subcontract can be awarded under the SAS program
to meet a particular requirement.
The decision whether to use mobile labs or a CLP or non-CLP laboratory
should be based on several factors including the analytical services
required, the number of samples to be analyzed, and anticipated turnaround
time of the laboratory at the time samples are to be sent. Mobile or
non-CLP labs located close to the site may be the best choice when fast
turnaround of analytical results is required to meet specific sampling
objectives or would result in a significant reduction of the overall RI/FS
schedule. To facilitate the most efficient completion of the RI, mobile or
non-CLP labs can be used to initially document the nature and extent of
contamination. Selected duplicate samples can be sent to CLP labs to
confirm and validate the analytical results from the mobile or non-CLP labs.
This process assists in the timely completion of the RI and the initiation
of FS activities, while still ensuring that legally defensible CLP data are
available for decisionmaking and potential cost-recovery actions.
If a non-CLP laboratory is used, analytical protocols need to be
specified in the bid packages sent to labs that are under consideration.
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OSWER Directive 9355.3-01
For Federal-lead sites, labs receiving invitations to bid have usually been
approved by the EPA Regional QA representative. For State-lead sites at
which non-CLP labs are used, the laboratory usually subcontracts with the
prime contractor when the project is initiated.
Section 5 of A Compendium of Superfund Field Operations Methods
presents the details of procedures for the use of CLP laboratories and
non-CLP laboratories. The User's Guide to the Contract Laboratory Program
also presents procedures for use of the CLP.
3.4 DATA ANALYSES
Analyses of the data collected should focus on the development or
refinement of the conceptual site by presenting and analyzing data on source
characteristics, the nature and extent of contamination, the contaminated
transport pathways and fate, and the effects on human health and the
environment. Data collection and analysis for the site characterization is
complete when the DQOs that were developed in scoping (including any
revisions during the RI) are met, when the need (or lack thereof) for
remedial actions is documented, and when the data necessary for development,
screening, and evaluation of remedial actions have been obtained. The
presentation of data in the RI can be divided into an analysis of site
characteristics and the baseline risk assessment.
3.4.1 Site Characteristics
The evaluation of site characteristics should define the current extent
of contamination and estimate the travel time to, and the predicted
contaminant concentrations at, potential exposure points. Data should be
analyzed to describe (1) the site physical characteristics, (2) the source
characteristics, (3) the nature and extent of contamination, and (4) the
important contaminant fate and transport mechanisms.
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OSWER Directive 9355.3-01
3.4.1.1 Site Physical Characteristics
Data on site physical characteristics should be analyzed to describe
the environmental setting at the site, including important surface features,
soils, geology, hydrology, meteorology, and ecology. This analysis should
emphasize factors important in determining contaminant fate and transport
for those exposure pathways of concern. For example, if migration of
contamination in ground water is of concern, these factors may include the
properties of the unsaturated zone, the rate and direction of flow in the
aquifer(s), and the extent of subsurface systems.
3.4.1.2 Source Characteristics
Data on source characteristics should be analyzed to describe the
source location; the type and integrity of any existing waste containment?
and the types, quantities, chemical and physical properties, and
concentrations of hazardous substances found. The actual and potential
magnitude of releases from the source and the mobility and persistence of
source contaminants should be evaluated.
3.4.1.3 The Nature and Extent of Contamination
An analysis of data collected concerning the study area should be
performed to describe contaminant concentration levels found in
environmental media in the study area. Analyses that are important to the
subsequent risk assessment and subsequent development of remedial
alternatives include the horizontal and vertical extent of contamination in
soil, ground water, surface water, sediment, air, biota, and facilities.
Spatial and temporal trends in contamination may be important in evaluating
transport pathways. Data should be arranged in tabular or graphical form
for clearer understanding. Figure 3-2 shows an example of how the extent of
soil and ground-water contamination can be represented in terms of excess
lifetime cancer risk. Similar figures can be prepared showing
concentrations rather than risk values.
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FIGURE 3-2 OSWER Directive 9355.3-01
REPRESENTATION OF THE EXTENT OF CONTAMINATION
LEGEND*
Soil Area Exceeding 1(H>
Lifetime Cancer Risk
Ground Water Exceeding
Lifetime Cancer Risk
SOURCE:
DIRECTION
CF
GROUND-WATER
FLOW
•NOTE: 1. Site-specific features should be shown
as appropriate (e.g., actual or potential
ground-water users).
2. Contamination can be represented by
concentrations rather than risk levels.
SCALE IN FEET
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OSWER Directive 9355.3-01
3.4.1.4 Contaminant Fate and Transport
Results of the site physical characteristics, source characteristics,
and extent of contamination analyses are combined in the analyses of
contaminant fate and transport. If information on the contaminant release
is available, the observed extent of contamination may be used in assessing
the transport pathway's rate of migration and the fate of contaminants over
the period between release and monitoring. Contaminant fate and transport
may also be estimated on the basis of site physical characteristics and
source characteristics.
«
Either analysis may use analytical or numerical modeling. While field
data generally best define the extent of contamination, models can inter-
polate among and extrapolate from isolated field samples and can interpret
field data to create a more detailed description. Models also can aid the
data reduction process by providing the user with a structure for organizing
and analyzing field data.
Models applicable to site characterization can be grouped according to
their relative accuracy and their ability to depict site conditions.
Simplified models (e.g., analytical and semianalytical models) can
quantitatively estimate site conditions with relatively low accuracy and
resolution. Typically, they provide order-of-magnitude estimates (U.S. EPA,
1982a) and require that simplified assumptions be made regarding site
conditions and chemical characteristics.
More detailed numerical models (e.g., numerical computer codes) provide
greater accuracy and resolution (U.S. EPA, 1982a), because they are capable
of representing spatial variations in site characteristics and irregular
geometries commonly found at actual sites. These models can also represent
the actual configuration and effects of remedial actions on site conditions.
Detailed mathematical models are sometimes appropriate for investigations in
which detailed information on contaminant fate and transport is required.
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OSWER Directive 9355.3-01
Models are also useful for screening alternative remedial actions and
may be used for a detailed analysis of alternatives. Deciding whether
analytical or numerical models should be used and selecting appropriate
models for either the remedial investigation or the feasibility study can be
difficult. Detailed modeling may not be needed if site conditions are well
understood and if the potential effectiveness of different remedial actions
can be easily evaluated. In selecting and applying models, it is important
to remember that a model is an artificial representation of a physical
system and is only one way of characterizing and assessing a site. A model
cannot replace, nor can it be more accurate than, the actual site data.
3.4.2 Baseline Risk Assessment
3.4.2.1 General Information
Baseline risk assessments provide an evaluation of the potential threat
to human health and the environment in the absence of any remedial action.
They provide the basis for determining whether or not remedial action is
necessary and the justification for performing remedial actions. Detailed
guidance on conducting risk assessments is provided in the Superfund Public
Health Evaluation Manual (SPHEM)(EPA/540/1-861060, OSWER Directive 9285.4-1,
October 1986).
In general, the objectives of a baseline risk assessment may be
attained by identifying and characterizing the following:
o Toxicity and quantity of hazardous substances present in relevant
media (e.g., air, ground water, soil, surface water, sediment, and
biota)
o Environmental fate and transport mechanisms within specific
environmental media such as physical, chemical, and biological
degradation processes and hydrogeological conditions
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OSWER Directive 9355.3-01
6 Potential exposure pathways and extent of actual or expected
exposure
o Potential human and environmental receptors
o Extent of expected impact or threat; and the likelihood of such
impact or threat occurring (i.e., risk characterization)
o "Acceptable" levels of exposure based on regulatory and
toxicological information
•r
The level of effort required to conduct a baseline risk assessment
depends largely on the complexity.of the site. The goal is to gather suf-
ficient information to adequately, and as accurately as possible, charac-
terize the potential risk from a site, while at the same time conduct this
assessment as efficiently as possible. Use of the conceptual exposure model
developed and refined previously will help focus investigation efforts and,
therefore, streamline this effort. Factors that may affect the level of
effort required include:
o The number, concentration, and identity of chemicals present
o The quality and quantity of available monitoring data
o The number and complexity of exposure pathways (including the
complexity of release sources and transport media)
o The necessity for precision of the results, which in turn depends
on onsite conditions such as the extent of contaminant migration
and the proximity, characteristics, and size of potentially
exposed population(s)
o The availability of appropriate standards and/or toxicity data
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OSWER Directive 9355.3-01
o The likelihood that no action will be the chosen alternative. If
no action is a likely choice, it is necessary that all potential
pathways and routes of exposure have been thoroughly assessed to
ensure that the site poses no threat to human health and the
environment.
3.4.2.2 Components of the Baseline Risk Assessment
The risk assessment process can be divided into four components:
o Contaminant identification
o Exposure assessment
o Toxicity assessment
o Risk characterization
Figure 3-3 illustrates the risk assessment process and its four
components. The following provides a brief overview of each component.
Contaminant Identification. The objective of contaminant
identification is to screen the information that is available on hazardous
substances or wastes present at the site and to identify contaminants of
'concern to focus subsequent efforts in the risk assessment process.
Contaminants of concern may be selected because of their intrinsic
toxicological properties, because they are present in large quantities, or
because they are present in potentially critical exposure pathways (e.g.,
drinking water supply).
It may be useful for some sites to select "indicator chemicals" as part
of this process. The methodology for identifying indicator chemicals is
described in the SPHEM. Indicator chemicals are to represent the most toxic
and/or mobile substances among those identified or those substances for
which the best information is available.
Exposure Assessment. The objectives of an exposure assessment are to
identify actual or potential exposure pathways, to characterize the
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OSWER Directive 9355.3-01
FIGURE 3-3
COMPONENTS OF THE RISK ASSESSMENT PROCESS
Assess Exposure
Identify Potential Exposure
Pathways
Characterize Potential
Receptors
Identify Potential Exposure
Routes
Estimate Expected Exposure
Levels
Identify Contaminants
of Concern ^
Identify Based on:
• Intrinsic lexicological Properties
• Quantity Present
» Potentially Critical Exposure Routes
• Utility as Indicator Chemicals
Conduct Risk
Characterization
Estimate Potential for
Adverse Health or
Environmental Effects
Based On:
• Carcinogenic Risks
• Noncarcinogenic Risks
• Environmental Risks
Assess Toxicity
Determine Acceptable
Levels Based On:
• ARARs,TBCs&
lexicological Data
Compare Acceptable
Levels with Actual
Levels
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OSWER Directive 9355.3-01
potentially Exposed populations, and to determine the extent of the
exposure. Detailed guidance on conducting exposure assessments is discussed
in the Superfund Exposure Assessment Manual (EPA, under development). These
objectives are attained by:
o Identifying exposure pathways
o Analyzing exposed populations
o Estimating expected exposure levels
Identifying potential exposure pathways helps to conceptualize how
contaminants may migrate from a source to an existing or potential point of
contact. An exposure pathway consists of four elements:
1. A source and mechanism of chemical release to the environment
2. An environmental transport medium (e.g., air, ground water) for the
released chemical
3. A point of potential contact with the contaminated medium (referred to
as the exposure point)
4. An exposure route (e.g., inhalation, ingestion) at the contact point
The first element of an exposure pathway analysis is an analysis of the
contaminant source and how contaminants may be released. This analysis in-
volves characterizing the contaminants of concern at the site and determin-
ing the amount of concentration and the mean and maximum concentrations of
each contaminant released to each environmental medium. Figure 3-4 presents
a conceptual example identifying actual and potential exposure pathways.
In the second element of exposure pathway analysis, the environmental
fate and transport of the contaminants are analyzed. This portion considers
environmental transport (e.g., ground-water migration, airborne transport);
transformation (e.g., biodegradation, hydrolysis, and photolysis); and
transfer mechanisms (e.g., sorption, volatilization). The results of these
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FIGURE 3-4 IDENTIFICATION OF EXPOSURE PATHWAYS
OSWER Directive 9355.3-01
MOT/VOLATILIZATION ,•".-
INHALATION i JM
'V"\ * ,.-,->-"X"''""v"
' '*
• fDtMW Finura Patfimy
•10-
3
•71 J
-==/// *//!!= til '/// —
-------
OSWER Directive 9355.3-01
analyses provide information on the potential magnitude and extent of
environmental contamination.
The third element identifies potential exposure points for receptors.
To estimate the potential worst-case total risk, the locations of the
highest potential exposure concentrations for a given release source and
transport media combination should be estimated, along with the concentra-
tion of contaminants at that point. Exposure points with lower predicted
chemical concentrations and large existing potentially exposed populations
also need to be evaluated.
The fourth element of exposure pathway analysis is the identification
and description of potential exposure routes. Exposure routes describe how
a receptor can come into contact with contaminants in a specific environmen-
tal medium. Environmental media to be considered include air, ground water,
surface water, soil and sediment, and food. Exposure routes include inges- •
tion, dermal absorption, and inhalation. Procedures for estimating and cal-
culating rates of exposure are described in detail in the Superfund Exposure
Assessment Manual.
After the exposure pathway analysis is completed, the potential for
exposure to populations should be assessed. This may involve gathering
information on the frequency, mode, and magnitude of exposure. These data
are then assessed to yield a value that represents the amount of contaminat-
ed media contacted per day. This analysis should include not only identifi-
cation of currently exposed populations but also exposures that may occur
in the future if no action is taken at the site. Because the frequency of
human exposures will vary based on whether the primary use of the site is
residential, industrial, or recreational, the expected land use should be
evaluated. However/ this evaluation does not require the prediction of fu-
ture development, only that the likely use (and expected exposure scenarios
on the basis of that land use) be evaluated. Part of this evaluation should
include the development of a maximum plausible exposure scenario (i.e./
worst-case scenario) for comparative purposes during the risk management
decisionmaking process.
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OSWER Directive 9355.3-01
The final step in the exposure assessment is to integrate the infor-
mation and develop a qualitative or quantitative estimate of the expected
exposure level(s) resulting from the actual or potential release of
contaminants from the site.
Toxicity Assessment. To assess the risks from a site, a comparison of
acceptable levels of contamination with actual levels identified during the
exposure assessment must be made. Contaminant-specific ARARs, when avail-
able, should be used to determine acceptable levels. When ARARs are not
-4
available or ARARs represent a risk greater than 10 , acceptable levels
should be based on concentration levels that would yield exposures less than
or equal to reference doses (RfDs) for noncarcinogens and specified risk
levels based on potency factors (q1*s) for carcinogens. The preliminary
goals for carcinogens
lifetime cancer risk.
-4 -7
goals for carcinogens will be based on the risk range of 10 to 10 excess
While priority will be given to the RfDs and q *s in setting these
goals, other available values may be useful in establishing final
chemical-specific cleanup levels. Additional guidance on the use of RfDs
and q *s for calculating acceptable concentrations in environmental media or
for determining the toxicity of substances for which RfDs or q *s have not
been developed is provided in the SPHEM.
Risk Characterization. In the final component of the risk assessment
process, risk characterizations—the potential for adverse health or envir-
onmental effects for each of the exposure scenarios derived in the exposure
assessment—are estimated. These estimates are attained by integrating
information developed during the exposure and toxicity assessments to char-
acterize the potential or actual risk including carcinogenic risks, noncar-
cinogenic risks, and environmental risks. The final assessment should
include a summary of the risks associated with a site including each pro-
jected exposure route for contaminants of concern and the distribution of
risk across various sectors of the population. In addition, such .factors as
the weight-of-evidence associated with toxicity information, the estimated
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OSWER Directive 9355.3-01
uncertainty of the component parts, and the assumptions contained within the
estimates should be discussed.
Characterization of the environmental risks involves identifying the
potential exposures to the surrounding ecological receptors and evaluating
the potential effects associated with such exposure(s). Important factors
to consider include disruptive effects to populations (both plant and
animal) and the extent of perturbations to the ecological community.
The results of the baseline risk assessment may indicate that the site
poses little or no threat to human health or the environment. In such
situations, the FS should either be scaled down as appropriate to that site
and its potential hazard or eliminated altogether. The results of the
remedial investigation and the baseline risk assessment will therefore serve
as the primary means of documenting a no-action decision. If it is decided
that the scope of the FS will be less than what is presented in this
guidance or eliminated all together, the lead agency should document this
decision and receive the concurrence of the support agency.
3.4.3 Evaluate Data Needs
As data are collected and a better understanding of the site and the
risks that it poses are obtained, the preliminary remedial action
alternatives developed during scoping should be reviewed and refined. The
available data should be evaluated to determine if they are sufficient to
develop remedial alternatives. If they are not, additional data gathering
will be required. When sufficient data are available, preliminary remedial
response objectives with respect to the contaminants of concern, the areas
and volumes of contaminated media, and existing and potential exposure
routes and receptors of concern can begin to be developed as part of the FS.
3.5 DATA MANAGEMENT PROCEDURES
An fll may generate an extensive amount of information, the quality
and validity of which must be consistently well documented because this
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OSWER Directive 9355.3-01
information will be used to support remedy selection decisions and any legal
or cost recovery actions. Therefore, field sampling and analytical procedures
for the acquisition and compilation of field and laboratory data are subject
to data management procedures. The discussion on data management procedures
is divided into three categories: field activities, sample management and
•tracking, and document control and inventory.
3.5.1 Field Activities
During site characterization and sampling, consistent documentation and
accurate recordkeeping procedures are critical because subsequent decisionmak-
ing will be based on information gathered during these tasks. Aspects of
data management for sampling activities during site characterization include:
o QA/QC Plans—These documents provide records of responsibility,
adherence to prescribed protocols, nonconformity events,
corrective measures, and data deficiencies.
o A Data Security System—This system outlines the measures that
will be taken in the field to safeguard chain-of-custody records
and prevent free access to project records, thereby guarding
against accidental or intentional loss, damage, or alteration.
o Field Logs—The daily field logs are the primary record for field
investigation activities and should include a description of any
modifications to the procedures outlined in the work plan, field
sampling plan, or health and safety plan, with justifications for
such modifications. Field measurements and observations should be
recorded directly into the project log books. Examples of field
measurements include pH, temperature, conductivity, water flow,
air quality parameters, and soil characteristics. Health and
Data quality objectives will govern the data management methods used, and
the QAPP/FSP will identify both field-collected and analytical data. This
material should include sampling information, recording procedures, sample
management, and QC concerns.
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OSWER Directive 9355.3-01
safety monitoring, sampling locations, sampling techniques, and
a general description of daily activity are typically included in
the daily log. Any unusual occurrences or circumstances should be
documented in these logs and can be used for reference in determin-
ing the possible causes for data anomalies discovered during data
analysis. Data must be recorded directly and legibly in field log
books with entries signed and dated. Changes made to original
notes should not obliterate the original information and should be
dated and signed. Standard format information sheets should be
used whenever appropriate and should be retained in permanent
files.
Documentation involved in maintaining field sample inventories and
proper chain-of-custody records may include the following :
o Sample Identification Matrix
o Sample Tag
o Traffic Report
o High-Hazard Traffic Report
o SAS Packing List
o Chain-of-Custody Form
o Notice of Transmittal
o Receipt for Samples Form
o CRL Sample Data Report
o Shipping Airbill
Additional information for each of these items, along with the
instructions for their completion, can be found in Section 6.2 of the
Compendium of Superfund Field Operations Methods.
Specific requirements may vary between State- and Federal-lead sites.
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OSWER Directive 9355.3-01
3.5.2 Sample Management and Tracking
A record of sample shipments, receipt of analytical results, submittal
of preliminary results for OA/QC review, completion of QA/QC review, and
evaluation of the QC package should be maintained to ensure that only final
and approved analytical data are used in the site analysis. In some
instances, the use of preliminary data is warranted to prepare internal
review documents, to begin data analysis while minimizing lost time for the
turnaround of QA/QC comments, and to continue narrowing remedial action
alternatives. Preliminary data are considered unofficial; however, until
the QA/QC package is complete, any preliminary data used in analysis must be
updated upon receipt of official QA/QC comments and changes. Sample results
should not be incorporated in the site characterization report unless
accompanied by QA/QC comments.
The data quality objectives stated for each task involving sample
analysis must specify whether the information is valid with qualifiers or
not and must specify which qualifiers can invalidate the use of certain
data. For instance, reproducibility of plus or minus 20 percent may be
acceptable in a treatability study but may not be acceptable for determining
the treatment for establishing a risk to human health from drinking water.
Acceptability of data quality is not established until the reviewed QA/QC
package accompanies the analytical data.
The acceptable QA/QC package should be defined in the approved site
QAPP for each discrete task. Where use of the CLP is involved, review by
the CRL QA Office is typical but may vary from one Region to the next and
may vary from one state to the next in the case of State-lead sites.
Nevertheless, the data quality objectives outlined for the use of the data
will dictate the level of review required.
3.5.3 Document Control and Inventory
Sample results should be managed in a standardized form to promote easy
reporting of data in the site characterization report. Precautions should
3-46
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OSWER Directive 9355.3-01
be taken in-the analysis and storage of the data collected during site
characterization to prevent the introduction of errors or the loss or
misinterpretation of data.
The document inventory and filing systems can be based on serially
numbered documents. These systems may be manual or automated. A suggested
structure and sample contents of a file for Superfund activities are shown
in Table 3-11. The relationship of this filing system to the Administrative
Record is discussed in the "Administrative Record Guidance" (under
development).
3.6 COMMUNITY RELATIONS ACTIVITIES DURING SITE CHARACTERIZATION
Two-way communication with interested members of the community should
be maintained throughout the remedial investigation. The remedial project
manager and Community Relations Coordinator keep local officials and
concerned citizens apprised of site activities and of the schedule of events
by implementing several community relation activities. These actions are
usually delineated in the community relations plan and typically include,
but are not limited to, public information meetings at the beginning and end
of the remedial investigation; a series of fact sheets that will be
distributed to the community during the investigation and will describe
up-to-date progress and plans for remedial activities; telephone briefings
of key members of the community—public officials and representatives of
concerned citizens; and periodic news releases that describe progress at the
site.
The files containing the administrative record should be established
once the RI/FS work plan is finalized and kept at or near the site. It is
recommended that the files containing the Administrative Record be kept at
one of the information repositories for public information at or near the
site and near available copying facilities. Copies of site-related
information should be made available to the community and should typically
include the RI/FS work plan, a summary of monitoring results, fact sheets,
and the community relations plan. The objective of community relations
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OSWER Directive 9355.3-01
Table 3-11
OUTLINE OF SUGGESTED FILE STRUCTURE FOR SUPERFUND SITES
Congressional Inquiries and Hearings:
o Correspondence
o Transcripts
o Testimony
o Published hearing records
Remedial Response:
o Discovery
Initial investigation reports
Preliminary assessment report
Site inspection report
Hazard Ranking System data
o Remedial planning
Correspondence
Work plans for RI/FS
RI/FS reports
Health and safety plan
Quality assurance/quality control plan
Record of Decision/responsiveness summary
/
o Remedial implementation
Remedial design reports
Permits
Contractor work plans and progress reports
Corps of Engineers agreements, reports, and correspondence
o State and other agency coordination
Correspondence
Cooperative agreement/Superfund State contract
State quarterly reports
Status of State assurances
Interagency agreements
Memorandum of Understanding with the state
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OSWER Directive 9355.3-01
Table 3-11 (continued)
o Community relations
Interviews
Correspondence
Community relations plan
List of people to contact, e.g., local officials, civic
leaders, environmental groups
Meeting summaries
Press releases
News clippings
Fact sheets
Comments and responses
Transcripts
Summary of proposed plan
Responsiveness summary
Imagery:
o Photographs
o Illustrations
o Other graphics
Enforcement:
o Status reports
o Cross-reference to any confidential enforcement files and the
person to contact
o Correspondence
o Administrative orders
Contracts:
o Site-specific contracts
o Procurement packages
o Contract status notifications
o List of contractors
Financial Transactions:
o Cross-reference to other financial files and the person to contact
o Contractor cost reports
o Audit reports
WDR243/045
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OSWER Directive 9355.3-01
activities during the RI is to educate the public on the remedial process
and keep the community informed of project developments as they occur,
thereby reducing the likelihood of conflict arising from a lack of informa-
tion, misinformation, or speculation. As directed in the community rela-
tions plan, all activities should be tailored to the community and to the
site.
3.7 REPORTING AND COMMUNICATION DURING SITE CHARACTERIZATION
During site characterization, communication is required between the
lead agency and the support agency. In addition to routine communication
between members of the lead agency and their contractor on project progress,
written communication is required between the lead agency and the support
agency as follows:
1. The lead agency should provide the draft work plan to the support
agency for review and comment.
2. The lead agency should provide information on contaminant types and
affected media to the support agency for ARAR identification.
3. The lead agency should provide a preliminary summary of site character-
ization to the support agency (this may serve as the mechanism for ARAR
identification).
4. The lead agency should provide a draft RI report for review and comment
by the support agency.
These communication requirements are discussed in the following
section. Table 3-12 summarizes the points during site characterization when
written or verbal communication is recommended.
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OSWER Directive 9355.3-01
Table 3-12
REPORTING AND COMMUNICATION DURING SITE CHARACTERIZATION
Information Needed
Purpose
of results of field
observations
Need to rescope field Needed only if screening
activities on the basis indicates that field
activities need to be
rescoped; for lead agency
and contractor to identify
methods to improve effec-
tiveness of site charac-
terization activities; for
lead agency to obtain
support agency review and
concurrence
Potential Methods
of Information
Provision
Meeting
Tech memo
Other
Need to rescope field
activities on the basis
of results of sample
analysis
Preliminary results of
field investigation
tasks (e.g.,
geophysical
explorations,
monitoring well
installation, etc.)
Descriptive and
analytical results
of initial site char-
acterization results
(excluding risk
assessment)
Needed only if analysis of
lab data indicates field
activities need to be
rescoped; for lead agency
and contractor to identify
methods to improve effec-
tiveness of site charac-
terization activities;
for lead agency to obtain
support agency review and
concurrence
Provided by the contractor
to the lead agency; need
and method of
communication at lead
agency's discretion
May also be submitted to
ATSDR for use in preparing
health assessment; assists
in supporting agency with
identification of ARARs;
provides lead agency with
early summary of site data
Meeting
Tech memo
Other
Tech memos
Other
Preliminary
site characteri-
zation summary
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OSWER Directive 9355.3-01
Table 3-12 (continued)
Potential Methods
of Information
Information Needed Purpose Provision
Listing of For support agency's use Preliminary
contaminants, affected in identifying contamin- site character-
media; location of ant- and location-specific ization summary
wetlands, historic ARARS.
sites, etc.
Refined remedial action For lead agency and Meeting
objectives contractor to define the Tech memo
basis for developing Other
remedial action
alternatives; obtain
review and comment from
the support agency
Documentation of site Required for members of Draft RI report
characterization field lead agency and their
activities and analyses contractor to prepare for
including any treata- public comment and FS
bility testing support documentation
WDR243/018
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OSWER Directive 9355.3-01
3.7.1 Information for ARAR Identification
The information for the support agency's use in identifying ARARs
should include a description of the contaminants of concern, the affected
media, and any physical features that may help identify location-specific
ARARs. This information may be supplied by the preliminary site character-
ization summary (as discussed below) or by a letter or other document. The
support agency shall provide location and contaminant-specific ARARs to the
lead agency before preparation of the draft RI report.
3.7.2 Preliminary Site Characterization Summary
A summary of site data following the completion of initial field sam-
pling and analysis should be prepared. This summary should briefly review
investigative activities that have taken place and should strive to provide
the lead agency with a reference for evaluating the development and screen-
ing of remedial alternatives. In addition, the preliminary site character-
ization summary may be used to assist the support agency in identification
of ARARs and provide ATSDR with the data (prior to issuance of the draft RI)
to assist their health assessment efforts.
The format of this summary is optional and left to the discretion of
the lead-agency RPM. The format may range from a technical memorandum,
which simply lists the locations and quantities of contaminants at the site,
to a rough draft of the first four chapters of the RI report (see
Table 3-13).
3.7.3 Draft RI Report
A draft RI report should be produced for review by the support agency
and submitted to ATSDR for its use in preparing a health assessment. It
also serves as documentation of data collection and analysis in support of
the FS. The draft RI report can be prepared any time between the completion
of the baseline risk assessment and the completion of the draft FS.
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OSWER Directive 9355.3-01
Therefore, the draft RI report should not delay the initiation or execution
of the FS.
•*= -
Table 3-13 gives a suggested format for the draft RI report. The
report should focus on the media of concern and, therefore, does not need to
address all the site characteristics listed in Table 3-13; only those
appropriate at that specific site.
WDR243/016
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OSWER Directive 9355.3-01
Table 3-13
SUGGESTED RI REPORT FORMAT
Executive Summary
1. Introduction
1.1 Purpose of Report
1.2 Site Background
1.2.1 Site Description
1.2.2 Site History
1.2.3 Previous Investigations
1.3 Report Organization
2. Study Area Investigation
2.1 Includes field activities associated with site
characterization. These may include physical and chemical
monitoring of some, but not necessarily all, of the following:
2.1.1 Surface Features (topographic mapping, etc.) (natural
and manmade features)
2.1.2 Contaminant Source Investigations
2.1.3 Meteorological Investigations
2.1.4 Surface-Water and Sediment Investigations
2.1.5 Geological Investigations
2.1.6 Soil and Vadose Zone Investigations
2.1.7 Ground-Water Investigations
2.1.8 Human Population Surveys
2.1.9 Ecological Investigations
2.2 If technical memoranda documenting field activities were
prepared, they may be included in an appendix and summarized
in this report chapter.
3. Physical Characteristics of the Study Area
3.1 Includes results of field activities to determine physical
characteristics. These may include some, but not necessarily
all, of the following:
3.1.1 Surface Features
3.1.2 Meteorology
3.1.3 Surface-Water Hydrology
3.1.4 Geology
3.1.5 Soils
3.1.6 Hydrogeology
3.1.7 Demography and Land Use
3.1.8 Ecology
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OSWER Directive 9355.3-01
Table 3-13 (continued)
4. Nature and Extent of Contamination
4.1 Presents the results of site characterization, both natural
chemical components and contaminants in some, but not
necessarily all, of the following media:
4.1.1 Sources (lagoons, sludges, tanks, etc.)
4.1.2 Soils and Vadose Zone
4.1.3 Ground Water
4.1.4 Surface Water and Sediments
4.1.5 Air
5. Contaminant Fate and Transport
5.1 Potential Routes of Migration (i.e., air, ground water, etc.)
5.2 Contaminant Persistence
5.2.1 If they are applicable (i.e., for organic
contaminants), describe estimated persistence in the
study area environment and physical, chemical, and/or
biological factors of importance for the media of
interest.
5.3 Contaminant Migration
5.3.1 Discuss factors affecting contaminant migration for
the media of importance (e.g., sorption onto soils,
solubility in water, movement of ground water, etc.)
5.3.2 Discuss modeling methods and results, if applicable.
6. Baseline Risk Assessment
6.1 Public Health Evaluation
6.1.1 Exposure Assessment
6.1.2 Toxicity Assessment
6.1.3 Risk Characterization
6.2 Environmental Assessment
7. Summary and Conclusions
7.1 Summary
7.1.1 Nature and Extent of Contamination
7.1.2 Fate and Transport
7.1.3 Risk Assessment
7.2 Conclusions
7.2.1 Data Limitations and Recommendations for Future Work
7.2.2 Recommended Remedial Action Objectives
Appendixes
A. Technical Memoranda on Field Activities (if available)
B. Analytical Data and QA/QC Evaluation Results
C. Risk Assessment Methods
WDR243/020
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CHAPTER 4
DEVELOPMENT
OF ALTERNATIVES
FROM:
• Preliminary
AMMSrmm
• Sle Inspection
• NPLUUng
SCOPING OF THE RLTS
SITE
PLANNING
T
SITE i
CHARACTERIZATION ,
TBEATABILITY
INVESTIGATION
PROJECT
PLANNING
I
I
_*_
* SCREENNG OF
«f«U0W*f*Eft I AkTERNATIVES
DETAILED ANALYSIS
OF ALTERNATIVES
DEVELOPMENT OF
ALTERNATIVES
• Identify Potential Treatment
Technologies Containment/
Disposal Requirements for
Residuals or Untreated Waste
• Screen Technologies
• Identify Action-Specific ARARs
• Assemble Technologies into
Alternatives
TO:
• Remedy S*l«aion
• Record al Dsccian
• Remedial Design
• Remedial Action
-------
OSWER Directive 9355.3-01
CHAPTER 4
DEVELOPMENT OF ALTERNATIVES
4.1 INTRODUCTION
4.1.1 Purpose of Alternative Development
The primary objective of this phase of the FS is to develop
alternatives that protect human health and the environment and encompass
a range of appropriate waste management options. Appropriate waste man-
agement options may involve, depending on site-specific circumstances,
eliminating the hazardous substances at the site, reducing hazardous
substances to acceptable levels, and preventing exposure to hazardous
substances or some combination of elimination, reduction, and exposure
prevention. Alternatives are typically developed concurrently with the
RI site characterization, with the results of one influencing the other
in an iterative fashion (i.e., RI site characterization data are used to
develop alternatives and screen technologies, whereas the range of
alternatives developed guides subsequent site characterization and/or
treatability studies, as appropriate).
In developing alternatives, two important activities take place.
First, volumes or areas of media are identified to which treatment and
containment actions may be applied, possibly in combination with excava-
tion, disposal, or institutional actions. The media to be treated or
contained are determined by information on the nature and extent of con-
tamination, ARARs, and risk factors. Second, the remedial action alter-
natives and associated technologies identified during project planning
(Section 2.3) and any newly identified technologies are screened to
identify those that would be effective for the contaminants and media of
interest at the site. The information obtained during these two activi-
ties is used in assembling technologies (and the media to which they
4-1
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OSWŁK directive yjbb.3-01
will be applied) into alternatives for the site as a whole or a specific
operable unit. An overview of the entire PS process is presented in the
following subsections.
4.1.2 FS Process Overview
The feasibility study may be viewed (for explanatory purposes) as
occurring in three phases: the development of alternatives, the screen-
ing of the alternatives, and the detailed analysis of alternatives.
However, it is useful to note that there is no specific point at which
one phase ends and the next begins. For example, the initial configura-
tions of alternatives developed may be subsequently modified, refined,
or eliminated during later FS phases as additional information becomes
available on site conditions, technology performance, or the construc-
tion and operation requirements of alternatives. Furthermore, in those
instances in which circumstances limit the number of available options,
and therefore the number of alternatives that are developed, it may not
be necessary to screen alternatives prior to the detailed analysis.
4.1.2.1 Development of Alternatives
Alternatives for remediation are developed by assembling
combinations of technologies, and the media to which they would be
applied, into alternatives that address contamination on a sitewide
basis or for an identified operable unit. This process consists of six
general steps, which are shown in Figure 4-1 and briefly discussed
below:
o Develop remedial action objectives specifying the contaminants
and media of interest, exposure pathways, and remediation
goals that permit a range of treatment and containment
alternatives to be developed. The objectives developed are
based on contaminant-specific ARARs, when available, and
risk-related factors.
4-2
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FIGURE 4 -1
ALTERNATIVE DEVELOPMENT
OSWER Directive 9355.3-01
( Scoping J
If
Determine Remedial Action Objectives
Based on Risk Assessment and ARARs
Identification
i
Develop General Response
Actions Describing Areas or
Volumes of Media to which
Containment, Treatment, or
Removal Actions may be Applied
I
Identify Potential
Treatment and
Disposal Technologies .
and Screen Based on
Technical Implementability
Evaluate Process Options Based
on Effectiveness, Implementability,
and Relative Cost, to Select a
Representative Process for each
Technology Type
Repeat Previous Scoping Steps:
• Determine New Data Needs
• Develop Sampling Strategies
and Analytical Support to
Acquire Additional Data
- Amend QAPP/FSP, HSP, and
Work Plan as Appropriate
- Repeat Steps in Rl Site
Characterization
YES
Reevaluate
Data Needs?
Combine Media-Specific
Technologies into
Alternatives
Screening of
Alternatives
-------
OSWER Directive 9355.3-01
Develop general response actions for each jnedium of interest
defining containment, treatment, excavation, pumping, or other
actions, singly or in combination, that may be taken to
satisfy the remedial action objectives for the site.
Identify volumes or areas of media to which general response
actions might be applied, taking into account the requirements
for protectiveness as identified in the remedial action objec-
tives and the chemical and physical characterization of the
site.
Identify and screen the technologies applicable to each
general response action to eliminate those that cannot be
implemented technically at the site. The general response
actions are further defined to specify remedial technology
types (e.g., the general response action of treatment can be
further defined to include chemical or biological technology
types).
Identify and evaluate technology process options to select a
representative process for each technology type retained for
consideration. Although specific processes are selected for
alternative development and evaluation, these processes are
intended to represent the broader range of process options
within a general technology type.
Assemble the selected representative technologies into
alternatives representing a range of treatment and containment
combinations, as appropriate.
It is important to distinguish between this medium-specific technology
screening step during development of alternatives and the alternative
screening that may be conducted subsequently to reduce the number of
alternatives prior to the detailed analysis.
4-4
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OSWER Directive 9355.3-01
Figure 4-2 provides a generic representation of this process.
Section 4.2 contains a more detailed description and specific examples
of tlM alternative development phase.
4.1.2.2 Screening of Alternatives
For those situations in which numerous waste management options
were appropriate and developed, the assembled alternatives should be
refined and screened to reduce the number of alternatives that will be
analyzed in detail. In addition, the alternatives are analyzed to
investigate interactions among media in terms of both the evaluation of
technologies (i.e., the extent to which source control influences the
degree of ground-water or air-quality control) and sitewide protective-
ness (i.e., whether the alternative provides sufficient reduction of
cumulative risk from all media and pathways for the site or that part of
the site being addressed by an operable unit). On the basis of this
analysis, alternatives may be modified or refined with respect to the
technologies used or the volumes or areas of media to be affected.
The refined alternatives are evaluated on a general basis with
respect to their effectiveness, implementability, and cost to identify
the most promising alternatives which encompass an appropriate range of
waste management options. As with the use of representative technolo-
gies, alternatives may be selected to represent sufficiently similar
alternatives; thus, in effect, a separate analysis for each alternative
is not warranted. Elements of the screening process are described at
greater length in Chapter 5.
4.1.2.3 Detailed Analysis of Alternatives
During detailed analysis, the alternatives brought through
screening are further refined, as appropriate, and analyzed in detail
with respect to the nine evaluation criteria described in Chapter 7.
Alternatives may be further refined and/or modified through additional
site characterization or treatability studies conducted as part of the
4-5
-------
FIGURE 4-2
GENERIC ALTERNATIVE DEVELOPMENT PROCESS
OSWER Dk«ctV* 93S6.3-01
UEOM REMEDIAL ACTION GENERAL RESPONSE OENTFY
OBJECTIVES ACTONS TECHNOLOGY TYPES
DENTFY PROCESS OPTONS
AND SCREEN TECHNOLOGIES/
OPTIONS BASED ON TECHMCAL
MPLEMENTAM.nY
EVALUATE PROCESS
OPTIONS BASED ON
EFFECTIVENESS.
MSTmjTONAL
MPLEMEMTABUTY.
AM) RELATIVE COST
! MTOAUEMNATMES
THE SELECTED NEf NESENTAT1VE
I technology 12
medium «1
'ir-^/^r .T«-=-
! ob|K>tv.«12 l—a4 .cdonet-z
tie
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Process options lhal am screened out
[ j
•IB
PCOOM*«7B
PraoMS options MlecMHl to repreacnl technology type
"1
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]
1
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1
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1
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1
J
1
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pn>cMt*4B
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|
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/
/
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r
i
Note: The combination ot medhm-lechnology options Into ciewide alemallves may be conducted later hi the FSI media Interactions are Insigniacanl
AlMnullMM:
•mdhml-proo
•m*dhra2-prao
MB4A
weTB
-------
OSWER Directive 9355.3-01
RI. The detailed analysis should be conducted so that decisionmakers
are provided with sufficient information to compare alternatives with
respect to the nine evaluation criteria and to select an appropriate
remedy. Analysis activities are described in greater detail in
Chapter 7.
4.1.3 Alternative Ranges
Alternatives should be developed that will provide decisionmakers
with an appropriate range of options and sufficient information to
adequately compare alternatives against one another. In developing
alternatives/ the range of options will vary depending on site-specific
conditions. A description of ranges for source control and ground-water
response actions that should be developed, as appropriate, are described
below.
4.1.3.1 Source Control Actions
For source control actions, the following types of alternatives
should be developed to the extent practicable:
o A number of treatment alternatives ranging from one that would
eliminate, or minimize to the extent feasible, the need for
long-term management (including monitoring) at a site to one
that would use treatment as a primary component of an
alternative to address the principal threats at the site
o One or more alternatives that involve containment of waste
with little or no treatment but protect human health and the
environment by preventing potential exposure and/or by
reducing the mobility
o A no-action alternative
Alternatives for which treatment is a principal element could include
containment elements as well.
4-7
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OSWER Directive 9355.3-01
Figure 4-3 conceptually illustrates this range for source control
alternatives.
Develofoent of a complete range of treatment alternatives will not
be practical in some situations. Alternatives within this range
typically will differ in the type and extent of treatment used and the
management requirements of treatment residuals or untreated wastes. For
example, for sites with large volumes of potentially low concentrated
wastes such as some municipal landfills and mining sites, an alternative
that eliminates the need for long-term management may not be reasonable
given site conditions, the limitations of technologies, and extreme
costs that may be involved. If a lull range of alternatives is not
developed, the reasons for doing so should be documented.
No-action alternatives may include some minimal actions such as
fencing, using institutional controls, or monitoring, if no action at
all is clearly not viable. If a no-action alternative with minimal
controls is developed, a baseline risk assessment using no-action
exposure scenarios will still need to be performed to help define
cleanup goals for different media and the site as a whole.
4.1.3.2 Ground-water Response Actions
For ground-water response actions, alternatives should address not
only cleanup levels but also the time frame within which the
alternatives might be achieved. Depending on specific site conditions
and the aquifer characteristics, alternatives should be developed that
achieve ARARs or other risk-based levels determined to be protective
within varying time frames using different methodologies. For aquifers
currently being used as a drinking water source, alternatives should be
configured that would achieve ARARs or risk-based levels as rapidly as
possible. More detailed information on developing remedial alternatives
for ground-water response actions may be found in "Guidance on Remedial
Actions for Contaminated Groundwater at Superfund Sites (DRAFT)" (U.S.
EPA, October 1986).
4-8
-------
FIGURE 4-3 OSWER Dir«ctiv« 9355.3-01
CONCEPTUAL TREATMENT RANGE FOR SOURCE CONTROL
."Hot" Spots
Soil
Exceeds
1x10'4
Soil
Exceeds
1xlO'6
Background
2. Treatment which eliminates or minimizes to the extent feasible the need for long-term
management.
2A. All Contaminated Soil
Excavated and Treated
2B. All Soil Above 1x10
Excavated & Treated
-6
(Continued)
-------
FIGURE 4-3 (continued)
OSWER Directive 9355.3-01
3. Alternatives using treatment as a principal element
•Hot" Spots Excavated
& Treated
4. Containment with little or no treatment
-------
OSWER Directive 9355.3-01
4.2 ALTERNATIVE DEVELOPMENT PROCESS
The alternative development process nay be viewed as consisting of
steps that involves making successively more specific definitions of
potential remedial activities. These steps are described in the
following sections.
4.2.1 Develop Remedial Action Objectives
Remedial action objectives consist of medium-specific or operable
unit-specific goals for protecting human health and the environment.
The objectives should be as specific as possible but not so specific
that the range of alternatives that can be developed is unduly limited.
Column two of Table 4-1 provides examples of remedial action objectives
for various media.
Remedial action objectives aimed at protecting human health and the
environment should specify:
o The contaminant(s) of concern
o Exposure route(s) and receptor(s)
o An acceptable contaminant level or range of levels for each
exposure route
Remedial action objectives for protecting human receptors should express
both a contaminant level and an exposure route, rather than contaminant
levels alone, because protectiveness may be achieved by reducing expo-
sure (such as capping an area, limiting access, or providing an alter-
nate water supply) as well as by reducing contaminant levels. Because
remedial action objectives for protecting environmental receptors typi-
cally seek to preserve or restore a resource (e.g., as ground water),
environmental objective(s) should be expressed in terms of the medium of
interest and target cleanup levels, whenever possible.
4-11
-------
i Dlrocttva OSS.1-01
1UU 4-1. TTFICAL
iut ACTION ouKnvn, onouu.
ACTION, TKOUUXa tTPO, MB 0AKFU
omen* FOB
bnlronaaotal
Nadla
Daaadlal Action Objactlvne
(from «lta charactartiatlon)
General Baaponae Action*
(for all mnadlal action objective*)
Technology Tfliaa
I for general raaponaa action
it
Optlfl
Ground Mat*r
For
healthl
Frevaat Inanition of *atar
having (carcteogaal*)) U
esc*** of (HO.UII aaa •
toUl i«nm rmutr rttk (for
•11 u»tl»t»*»rt •
^ UIO '.
of Mt«r
Ho Actloe/IatltutlaiMl ActtOMi
No actloa
Altonwtlvo raldMtUl ratar
HonltorlDO
Action*!
of (NCLUIl or
(referaooa doaa(*l).
For tnvtr.on»anUi FroUctloni
•actor* grand •atar agalfar
to IconcantratlonUI] for
IccnUnlaantU)].
Contal
Cnllactlon/TraatMBt Action* i
Collectlon/treatnent dlacbarga/
in *ltu groundeater traatnant
Individual boa* treatnant onlt*
No Actlon/lMtltntlonal Optional
Daad ra*triction*
CootaloMnt Taekaoloolaat
Capping
Vertical barrloT*
•orliontal barrlar*
Bitractloa Taea*ei.egt«lf ,,
Ground vat«r collactlon/pvaplaf
lonancad ranove]
Traatnant Tactaologlaai
Pbyalcal traatmot
Ckantcal traatnwt
In *lt» traataant
Dlapoaal VKbaologlaMi
M*charo> to MM laftar
traatnaotl
DlMfcaroB to wrfaea
•atar (aftar traataant)
Clay onp, ayatkatlo
•lony aall, *baat
Llnara, fraA InJacliaB
••II*,
•olatlon alatng,
all
• ar laackata oallactlon
vapor attraction, ankano
Co*nmI«ti«nynaooU«tioa. ail
tlon, air atripplng, adaorptlon
Nautrnlliatlon, precipitation, Ian
oaldatlon/reductloa
* bioi
•oil
For
fcalthi
Frevaat lageitIan/direct
ooetact with noil having
|non-carclnogan(*l] in
mean of (reference
Fravant dlract contact/
Ingaatlon with aoll hivlag
10 ' to 10 '
rink fron learclnognnl*)).
Frcvant Inhalation of
learcloogmUII poalng agon*
oancar rink lovala of 1
-------
I Directive •HS.S-Ol
TABLE 4-1
(Continued)
vlrnanintal
Modia
i Mater
CCr
Ml Action Objective*
alto i
General Meaponae Action*
(for all renodinl action ebloetiveo)
aiai Vectaoiogv Typo*
(for general reaponao actl
Prevent Inaeatlaa of noter
having (carclooaoaU)) la
e*coi* of iMCta) mi • total
excea* cancer rjfk of greater
tnan ufto 10 *.
of wt«r
bcvlng |ooo-o*rclBo«MiU)| to
•cc*n of |NCL*I or
[rofo
•o Ktlon
ACCOM raitrlctloiu
Monitoring
Colloctlon/TraotMBt Act loo* i
Sarfoco ««t«r runoff Intoraptloo/
troitMat/dUdivgo
tor
fn>toctlo»i
Matoro •arf *oo wator to
[Mfclont ntor
erltorU] for
Ho Actton/lMtltattoMl Optlaoas
roociog
Ooofl rwtrlctloM
Collection Tochnologlo*!
Surfoco coatrol*
Treotoont Toctoologloos
trootaont
tcol troatMot
Biological troat
(organic*)
In alta troaUnait
Dlaposal TochoologlMi
Dlacbargo to Mm (aftor
troataaatl
Oradlnt, dlvoralon.
I colloctlon
tloo, filtration, ateorpUon
Pradpltatloa, Ion «d>maa, navtml lent Ion,
frooio eryatnllUatlon biological tiaaU»«»t,
•arable and nanoroblc nprat irrigation
In alto nrodpltatloa. In alto nloraclnnatlon
Sodlnoot For team B»altn»
Proroot dlroct contact wltn
aodlnont bwlng
Icacclnogonia) 1 la oxcona of
10 to 10 oxcaaa cnaoar
rlak.
for fcnrlroonoatal »rotacttoni
Mo •ctlon/Inatltntlonal Actlorai
Ho action
Accra* rcatrlctlona to
MMltorlog
Bicnvatlon Action*!
r«lM»aa of
IcontaBlnaatUI] Iron
•odlnoat* that vonld raoult
in anrfaeo vntar lovala In
•icnan of (anblont vatar
quality crltorla).
bcavatton/Troatncnt Action*) >
•awnral/dlapoMl
Tal/traatnant/dlnponal
Ho Actloa/Inatltutla
Fonclog
Dood roitrlctlona
il Optional
lanoval Tochaologioat
bcaratIon
ContalmMot Tncnaologlant
Capping
Vertical barrlara
Horltontal barrlor*
Sodlnant control barrlora
TroaUant lachnologlajit
Solidification, fUatlon,
atabllliatlon
Oovatortng
rtqralcal traatnent
Biological troatnant
In ilto troatnont
namal traatjiant
vation
•1 rttn clay cap, naltl-larar,
•lury vail, aboot piling
tlnora, grant lajoctlon
Coffor anna, curtain barrlan, enae
barrlara
SorDtlon, paatolnale ngnnt*.
ation
atarlng and drying badn
Matar/aollda loacnlng (vltn aatmjaant
troaUMrt)
Moatralliation, onldation, alactrocnaalonl
radoctloa
Laadfanlng
•orfaca blomclanntion
Inclnaratlon, pyrolraia
Air
Por
•aaltbi
Pi«»ont Inhalation of
(carclnoocg^*)] In oxcoa* of
10 to 10 axcoaa coacar
rlak.
MB Actloa/Inatltatlonal Actloaai
•o action
Acceaa rcatrlctlona to Monitoring
Collection Actlonai
Ga* colloctloo
No Action/Institutional Optional
Fonclog
Oood roatrlctlona
•Moval Tccnnotogloai
Undflll ga* collection
Paaalvo ventn, nctlvo gna oollactloa ay
-------
1UU 4-1
(caotlDuod)
EnvlroiMonUl
NodU
•traetunw
taodlol Action Ob)oetl*t*
Itrtm olto cMroctorlioUeo)
rlok.
»i«»o»t BloTotlon of
Maid
roaalt la froood water
ooDcoatratlaoa In OBCOM of
or 10* to 10 ^tol
OBoaaa canoor ririt !•*•!.
of
(cuclftoonU)) itilcti Mala
rvoalt in fall ooaomtratloo*
tn OBOOM of Info
For B»rlrQ»int«l Protoctloat
Vnvoat •lantloa of
looatMlMBt*] ttat would
rooult !• gionna «>tor
coaccatration* la OZOOM of
(onooBtntloBCol].
Cooorml Koipoaoo Jkctloo*
(for oil roaoflUl octton ebloetttrool
ifor
alooy Type*
•ctlono)
No ActloB/lMtltutloMl tetloMi
No octloa
•carai rootrtctloM
DcMlltlon/TraotMat ftctloaoi
DMolltloa/dlopoMl
Doaoatoalnotloo
No Actlon/lMUtutloMl 0»tloui
Foocln^
Oood rovtrlcUoM
»•!
Doaolltlaa
bcovotloa
Trootaoat Todntologloot
Solid* pnoosolag
Solldi tnotxat : •>
olltloa
Solid
fter
jMltkt
oootoct with raotoo kavlag
|no» c«rclnoota<»)l to otee
of Iraforooxa doMdl]'
m*wt la«o>tloo/41roct
ooatoct vltk ••atos bovlag
10^ to 10 OK30M OBOOr
rlok fro
Ufeolo*lo» of
toorclDoa«o(tl| poslag OEMS
coaotr rlok lorol* of 10 »-
10 '.
to
Blfntlon of
(corclnogonli)) i*lcn Maid
rooult In yiuund w»tor
caacvotrotlopj !• OBOOO* »f
(MTU) or 10* to lO^toUl
rlok lovolt.
No Actlaa/lMtltatloMl Jtctlaaat
No octloo
•otrlctloiu to (location)
Actloaoi
Contoli
Contoli
Bico*otloo/TrMto*ot Jtctionoi
Honvol/dlnoool
>ol/trootMBt/dl
No Actlon/IoatUatlanol Optlo
Dood roatrlctlaaa
CoBtalaaoat TocBBOlogloai
Copping
Vortical barrlora
Horliontal barrlora
olofloos
boivotlOB
Drai roBOvol
TrootMBt Tocbnoloqlooi
Rir«lcol trootojcot
ChoBlcal trootomt
Bloloalcol trootiMot
trootont
Sol loo proooooloq
Cloy o«>,
Sl«rrr Mil, oboot ptllo
Llooro, oro«* lajoctlac
Diwt oootrolo
•dU-lafor
Solids
otloo.
dobrla
Notor/ool
llojuldo trootMot)
Noatrolltotlao)
Culturod •Icro-oraoolaeo
loclaoratloci, pyrolfolc,
iBcloorotloo.
CnMBlBf OBd OTlOdlOf,
claalflootloB
Cvltk
-------
Directive tlSS.1-01
•M0U 4-1
(continued)
EBvlronaantal fteaadtal Action Objective* General •eapooae Action*
Media (tram alte cfcaractarlMtlon) (for all rcaedlal action objective*)
Renadlal Technology Typea
(for general re*poaae action*) Pinoaaa mil ana
Solid «**tJa Por «nvii. m rti» *ratactloa;
(contlmad)
Prove** alfntloB of
COCltaajlaaat* that VMM
malt ID ground eater
contaBlnatlon In e*ceae of
(concentrationla)) for
IcontaBloantla)).
Liquid Hut*«
•Ithi
contact with waate* having
(non-carcinogen(a)| to exceaa
of (reference doaa(a)].
Prevent IngaaUon/dlract
contact "1U vaataa having
10 to 10 exce** cancer
rlak froa (carcinogen(a)].
mvnt InbaUtlan of
(ewclno9oa(il) pocln
cancer rlak l«*oli of 10
to
Ptevent algratloa of
(carctaogenl*)) which would
reealt In gronadwater
concaotratlona la excae* of
(MCLa) or 10 to 10 total
a>caaa cancer rlak level*.
for
rretoetioni
Prcvant •lorattoa of
coataalnmta that vould
nanlt In onwodMtar
ooataatnatlon In CEOM* of
(caoc*ntratlon(«)| for
Icootaalnantla)).
Mo ActlOB/Inatltotlooal Action*:
Ho action •
Aoccsa raatrictlon* to [location]
ContatnaMt Actlonas
Contalnaaot
Raamal/Tnataant Actlonai
RccoTal/diaposal
•aaoval/traatamt/dlapoaal
No Actloo/Initltatlonal Optional
Fencing
Paod raatrictlona
ContalnMnt Tacbaologlaai
Vertical barrier*
Horliootal barrier*
•at TadiBoloaloat
Bulk liquid roanval
Dnm raaoval
TrcaUwnt Tecbnologlaas
Fbyalcal traataant
Slurry vail
Llaar*
•Ik liquid
Biological troatMOt
Tnaraal treataant (orgaaica)
Dl*po*al Tocbaologlaai
Produce rauaa
Dladwrg* to POIW (after
treatamtl
Coaaalatlon/flooeulatloa, adaocptlon,
evaporation, diatlllatloa
HautralltatloB, oaldaUaa. tMacUoa,
pbotolyala
Aerobic/aaaaintile biological traataaat,
blotecbaologlaa Inclneratloa, prrolyda,
oo-diapoaal
Sludgaa
Por
Healtki
Preveflt direct contact »ltb
aladge having Icarcloognd)]
In nceaa of 10 to 10
ar rlak.
Piavaut Ingeatlon/oontact
•1th *ludge having
|noo-carclnogen(*l| la
of (rafaraoc* doaa(al).
Ho Actlon/In*tltutlonal Actloo*»
Ho action
Accca* reitrlctlona to (location]
Contalnawnt Actloaai
Contalnaant
•eaoval/Treatannt ActIon*i
Reaoval/dlcpoaal
Mo Actlon/Inatltutlonal Option*:
Penclng
Dead restriction*
Contalnaant Tecfanologlaat
Vertical barrier*
Horltontal barrier*
val Icdmologlaat
Bulk *ludo* reaoval
OruB moral
Treetaoit Technologic*!
Solidification, fixation
Slarry vail,
Liner*
Saal-aoltd
vatIon, poaplng
Sorptloa, poatolanlc agent*,
al
ilatloa
-------
ora Dinette* »s».i-oi
TABLE 4-1
(contlnuod)
BBvtronMotal RnnodUl Action Objoctivo* Oonoral ftMponoo Action* KModUl Tocteology TTMO
KodU Uron otto cturoctorltotlon) Uor all roaadlal action ebjoctl«oo) (for aonoral rooponoo octlono)
•l«d«M Provoot nltrotloo of Pbyolcol trootaont Prooso _. .
(oontlnood) |carclnoaM(«|) •kick voald Roaovnl/tiMtaont/dlopoool ocldatloo,, oloctrodMnleal
roault la froand ••'or Cfeonlcol troatavnt Oxldotlon, rodoctlon,
10 to 10 ^MOM OOBCOT MM blotocfcaolofloo
riak. ItMmal trootnont (oroonlca) Inelnorotlon, p*rotfBi*L
Domtorlao. Onvlty tblckoning, ko.lt filtor BTBM,
VOOMBI filtration
tlonooa of Product rouoo
Icontaainontl*)] from olndoi Londfllllna (aftor t
tkot weald roMlt In omrfooo
••tor lovol* in BOOM of
(••bloat mtor quality
criteria).
••^•ok^^A —-^* — ~ — jboT
rTWvVBK IwlMMB «»
(oontMlBontlill from nlndg*
that would roo«lt In
I ••tor leroli of
IcoBtOBlaantUH in »»P«BI of
DtrationU)).
-------
OSWER Directive 9355.3-01
Acceptable exposure levels for human health should be determined on
the basis of the risk factors and contaminant-specific ARARs identified
during the site characterization. Contaminant levels in each media
should be compared with these acceptable levels. Acceptable exposure
levels should be determined on the basis of an evaluation of the
following factors:
o For carcinogens, whether the chemical-specific ARAR provides
-4 -7
protection within the risk range of 10 to 10 and whether
achievement of each chemical-specific ARAR will sufficiently
reduce the total risk from exposure to multiple chemicals
o For non-carcinogens, whether the chemical-specific ARAR is
sufficiently protective if multiple chemicals are present at
the site
o Whether environmental effects (in addition to human health
effects) are adequately addressed by the ARARs
o Whether the ARARs adequately address all significant pathways
of human exposure identified in the baseline risk assessment.
For example, if the exposure from the ingestion of fish and
drinking water are both significant pathways of exposure,
application of an ARAR that is based only on drinking water
ingestion (e.g., MCLs) may not be adequately protective.
If an ARAR is determined to be protective, it should be used to
establish the acceptable exposure level. If an ARAR is not protective
-4
(i.e., presents a risk greater than 10 ), does not exist for the spe-
cific chemical or pathways of concern, or multiple contaminants may be
posing a cumulative risk, acceptable exposure levels should be identi-
fied through the risk assessment process. The Superfund Public Health
Evaluation Manual provides additional details on establishing acceptable
exposure levels when no ARARs exist.
4-17
-------
OSWER Directive 9355.3-01
4.2.2 Develop General Response Actions
General response actions describe those actions that will satisfy
the remedial action objectives. These nay include treatment, contain-
ment, excavation, extraction, disposal, institutional actions, or a
combination of these. Like remedial action objectives, general response
actions are medium-specific.
General response actions that might be taken at a site are
initially defined during scoping and are refined throughout the RI/FS as
a better understanding of site conditions is gained and action-specific
ARARs are identified. In developing alternatives, combinations of
general actions may be identified, particularly when disposal methods
are strongly dependent on whether the medium has been previously
treated. Examples of potential general response actions are included in
column three of Table 4-1.
4.2.3 Identify Volumes or Areas of Media
During development of alternatives an initial determination is made
of areas or volumes of media to which general response actions might be
applied. This initial determination is made for each medium of interest
on a site. Response actions for areas or volumes of media are often
refined after sitewide alternatives have been assembled to take
interactions between media into account. The refinement of alternatives
is discussed at greater length in Chapter 5 of this guidance document.
Defining the areas or volumes of media requires careful judgment
and should include a consideration of not only acceptable contaminant
levels and exposure routes, but also site conditions and the nature and
extent of contamination. For example, in an area with contamination
that is homogeneously distributed in a medium, discrete risk levels
(e.g., 10~ , 10~ ) or corresponding contaminant levels may provide
most rational basis for defining areas or volumes of media to which
4-18
-------
OSWER Directive 9355.3-01
treatment, containment, or excavation actions may be applied, as
illustrated in Figure 4-4A.
for sites with discrete hot spots or areas of more concentrated
contamination, however, it may be more useful to define areas and
volumes for remediation on the basis of the site-specific relationship
of volume (or area) to contaminant level, as shown in Figure 4-4B.
Therefore, when areas or volumes of media are defined on the basis of
site-specific considerations such as volume versus concentration
relationships, the volume or area addressed by the alternative should be
reviewed with respect to the remedial action objectives to ensure that
alternatives can be assembled to, as a minimum, reduce exposure to
protective levels.
4.2.4 Identify and Screen Remedial Technologies and Process
Options
In this step, the universe of potentially applicable technology
types and process options is reduced by evaluating the options with
respect to technical implementability. In this guidance document, the
term "technology types" refers to general categories of technologies,
such as chemical treatment, thermal destruction, solidification,
capping, or dewatering. The term "technology process options" refers to
specific processes within each technology type. For example, the
chemical treatment technology type would include such process options as
precipitation, ion exchange, and oxidation/reduction. As shown in
columns four and five of Table 4-1, several broad technology types may
be identified for each general response action, and numerous technology
process options may exist within each technology type.
Technology types and process options may be identified by drawing
on a variety of sources including references developed for application
to Superfund sites and more standard engineering texts not specifically
directed toward hazardous waste sites. Some of these sources are
included in Appendix C of this document.
4-19
-------
OSWER Directive 9355.3-01
FIGURE 4-4A.
POTENTIAL GENERAL RESPONSE SCENARIOS FOR AN AREA
WITH HOMOGENEOUSLY DISTRIBUTED CONTAMINATION
High
Volume for
removal or
treatment
(or area for
containment)
Low
CONTAMINANT CONCENTRATION TARGET
High
FIGURE 4-4B. POTENTIAL GENERAL RESPONSE SCENARIOS FOR AN AREA
WITH UNEVENLY DISTRIBUTED CONTAMINATION
High
Volume for
removal or
treatment
(or area for
containment)
Low
CONTAMINANT CONCENTRATION TARGET
High
Potential General Response Action Level
-------
Ground Water General
FIGURE 4-5
AN EXAMPLE OF INITIAL SCREENING OF TECHNOLOGIES AND PROCESS OPTIONS
Remedial Technology Proceee Options Description
No Action None |—
Institutional .^___
Actions
^L
— | Not applicable
— 1 Access restrictions 1 1 Deed restrictions
Afawnaie taajef
•upphr
L Monitoring
|-%*Ł5Ł22^
|~| City water supply
* 1 rtow cofTVTKjnny wofl
— | Ground water monitoring
1 \ r * f P*?"! '////yl witii injection of slurry as beam is withdrawn.
•— fXrirnfit M«n'in^ '////A Prwsur« Injection of grout at depth through
PowndaJy appkabte.
Potendaly appleable.
Not feasible for Intercepting corttammarts
In fractured bodrock.
Not IxiibU lor tnttrcaptfng conCBnvnana
In fractured bedrock,
Potontlaly appleable.
Potontiaiy appleable.
Deep aquifer not suitable tor Injection
of contaminants.
Potendaly appleable.
Poisndaly apptcable.
PotanHaly appkaMe.
Potsmialy apptcebto.
to bedrock.
Not effective because of fractured bedrock.
Not feasMe because of very shadow depti
to bedrock.
Not effective because of fracsurad bedrock.
'nu^L A- \*Lf ' f.S//A "* conjunction with vertical barriers
,Btock displacement ///X of slurry in notched Injection holes.
Not feesMe because of vary shalow depth
to bedrock.
legend iftf* • TecfmatoglH llwt M wr««wd oul
-------
OSWER Directive 9355.3-01
During this screening step, process options and entire technology
types are eliminated from further consideration on the basis of
technical inplementability. This is accomplished by using readily
available information from the RI site characterization on contaminant
types and concentrations and onsite characteristics to screen out
technologies and process options that cannot be effectively implemented.
Two factors that commonly influence technology screening are the
presence of inorganic contaminants, which limit the applicability of
many types of treatment processes, and the subsurface conditions, such
as depth to impervious formations or the degree of fracture in bedrock,
which can limit many types of containment and ground-water collection
technologies. This screening step is site-specific, however, and other
factors may need to be considered. Figure 4-5 provides an example of
initial technology screening for ground-water remediation at a site
having organic and inorganic contaminants and shallow, fractured
bedrock.
As with all decisions during an RI/FS, the screening of
technologies should be documented. For most studies, a figure similar
to Figure 4-5 provides adequate information for this purpose and can be
included in the FS report.
4.2.5 Evaluate Process Options
In the fourth step of alternative development, the technology
processes considered to be implementable are evaluated in greater detail
before selecting one process to represent each technology type. One
representative process is selected, if possible, for each technology
type to simplify the subsequent development and evaluation of
alternatives without limiting flexibility during remedial design. The
representative process provides a basis for developing performance
specifications during preliminary design; however, the specific process
actually used to implement the remedial action at a site may not be
selected until the remedial design phase. In some cases more than one
4-21
-------
Ground Water General
Response Actions
Remedial Technology
FIGURE 4-5 (continued)
Process Option* Description
Scnvsfilfifl CoffMnonta
Collection
Treatment
Discharge
\
,fotraclion/jri|ection wetey'yj > See 'Colftctlon/Oischarg*' above
-JsobturlaceeValo, |—| ^vcepM trenches \J
\™&'///////A
Degradation ol organic* using microorganisms
In an aerobic environment
Degradation ol organlcs using microorganisms
In an anaerobic environment
PhyslcaJ/chemlcal
treatment
T
Precipitation
1
—Y/&?&&y'//A
I ^r f ******
\}ttfj/ft/ SJL\ \/ Rotary kiln /
-^Thermal destruction /s\\ '_'_'__
-jOffslte treatment
Alteration of chemical equUbria to reduce
solublity of the contaminants
-JWStnppino'XX/TXTxl Mixing targe volumes of air wl*i water In a
YSss Vs//////s'\ packed column to promote transfer of VOCs to air
Adsorption of contaminants onto activated carbon
by passing water through carbon column
Use of high pressure to force water through a
membrane leaving contaminants behind
Contaminated water to passed through a resin bed
where Ions are exchanged between resin and water
Combustion In a horizontally rotating cylinder
designed tor uniform heat transfer
Waste Injected Into hot agitated bed of sand where
combustion occur*
Extracted ground water discharged to beat POTW
for treatment
Extracted ground water discharged to llscemed
RCRA tadfity for treatment and/or disposal
elslntrodu
jr f r r f r '.'////\
Reverse osmosis '////\
; - 1
|
Ion exchange
. j ) i f f
(/^f luidjzed
POTW
RCRAIadKty
\r/rrr s~r' f f f s f
~|/,P»fmeabto treatnani beds
jOnslle discharge | [ Local
System of Injection and extrscdo
bacteria and nutrients to degrade contamination
System of wells to Inject air Into ground water to
remove volatile* by air stripping
Downgradlent benches backfilled with activated
carbon to remove contamlnaM from water
System of Injection wells to Inject oxMizer such
as hydrogen peroxide to degrade contaminants
stream
Offslle discharge
POTW
\ Pipeline to rrver 1 J
. See Discharge under "ColeclkxV
' Discharge* above
Not feasible far kitorcepang contamlnanti
In fractured bedrock.
Not feasible far kitercaptng contamlnaBt*
In fractured bedrock.
PotenUeJry applicable.
Mot appBoable to Inorganic contamlnintt
found ki ground water at to she.
Mot applicable to Inorganic contaminants
found in ground water at the *lta.
Potentfany applicable.
Not applicable to Inorganic contaminant*
found in ground water at the site.
Not applicable to Inorganic contaminants
found In ground water at the ska.
Contaminant concentration* too tow tor
treatment.
Potentially applicable.
Not applicable to inorganic contaminant*
found ki ground water at the stte.
Not appll«hle to Inorganic contaminant*
found in ground water at the she.
Potently applicable.
PotenUAy applicable.
NM WttSebW D*BCBU99 Of nttCfcJtOO D6OTOCK.
Not feasWe because of fractured bedrock.
Not feaaMe because of shaeow deptfi 13 bedrock.
fractured bedrock.
Not feasible because of fractured bedrock.
Potensafty applicable.
Potentially applicable.
Deep aquifer not suitable tor Injection
of contaminated water.
Potentfany applicable.
-------
OSWER Directive 9355.3-01
process option may be selected for a technology type. This may be done
if two or more processes are sufficiently different in their performance
or effect that one would not adequately represent the other.
Process options are evaluated using the same criteria—
effectiveness, implementability, and cost—that is used to screen
alternatives prior to the detailed analysis. An important distinction
to make is that at this time these criteria are applied only to
technologies and the general response actions they are intended to
satisfy—and not to the site as a whole. Furthermore, the evaluation
should typically focus on effectiveness factors at this stage with less
effort directed at the implementability and cost evaluation.
Because of the limited data on innovative technologies, it may not
be possible to evaluate these process options on the same basis as other
demonstrated technologies. Typically, if innovative technologies are
judged to be implementable they are retained for evaluation either as a
"selected" process option (if available information indicates that they
will provide better treatment, fewer or less adverse effects, or lower
costs than other options), or they will be "represented" by another
process option of the same technology type. The evaluation of process
options is illustrated in Figure 4-6 and discussed in more detail below.
4.2.5.1 Effectiveness Evaluation
Specific technology processes that have been identified should be
evaluated further on their effectiveness relative to other processes
within the same technology type. This evaluation should focus on:
1) the potential effectiveness of process options in handling the
estimated areas or volumes of media and meeting the contaminant
reduction goals identified in the general response actions;
the ability of some collection/removal systems, such as ground-water
pumping, to sufficiently recover contaminated media for subsequent
treatment may also be assessed as part of this evaluation.
4-24
-------
fcu
AN EXAMPLE OF THE EVALUATION Of PROCESS OPTIONS
Ground Water General
Response Actions
Remedial Technology
Process Option*
Effectiveness
Coat
No Action None
AlMmats water
Institutional supply
Actions
L_ Monitoring
Collection/ Subsurlac* drains
IMadiaroB
— | Oflilte discharge
Containment Cap j.
VM.mv.n-.
-• • — D'oatment
| 1 Not applicable
1 Deed restrictions
|~~j city water supply
1— | New community well
— | Ground water monitoring
Interceptor trenches
n Local stream
|~T~| POTW
1 '
L| Pipeline to river
r— | day + sol
1 ...
1 Asphalt
1 Concrete
1 1 Mum-media cap
[ Interceptor trenches
^ Precipitation
Ion exchange
(— j POTW
H
| RCRA facility
1 Onslte discharge [ | Local stream
1 | Offsitt discharge f-
* Selected representative technologies
H POTW
I 1
1 | Pipeline to river
1
|
1
I
1
1
1
1
I
I
1
1
1
1
1
I
1
1
1
— '
I
* Does not achieve remedial action objectives
Effectiveness depends on continued future Im-
plementation. Does not reduce contamination..
• Effective In preventing use of contaminated
ground water. No contaminant reduction.
Effective In preventing use of contaminated
ground water. No contaminant reduction.
« Useful for documenting conditions. Does not
reduce risk by Itself.
* Effective for downgradlent fracture
low Interception.
• Effective and reliable dlschi
not eliminate contamination
» Effective and reliable dlschi
not eliminate contamination
Effective and reliable dlsch
not eliminate contamination
t Effective, susceptible to en
self-healing properties.
Effective but susceptible to
and cracking. •
Effective but susceptible to
and cracking.
Effective, least susceptible
, Effective tor downgradtont ft
flow Interception.
, Effective and retabl*; conv
technology. Requires sludg
Effective and reliable; prop*
required.
Effectiveness and reliability
pilot test to determine.
Effective and ratable treatn
tation required.
* Effective and reliable.
* Effective and reliable.
Effective and reliable.
srge method. Does
•rge method. Doe*
srge method. Does
icklng. but has
weathering
weathering
to cracking.
•acture
sntkmal
e disposal.
x pretreatment
require
tenl; transpor-
Not acceptable to local/
pubic government.
Leg*) requirements.
Convention*) conskucdon.
requires local approvals.
Conventional constuctton,
requires local approvals.
Alone, not acceptable to pufaOor
local government
Very difficult to Implement - re-
quires deep trending through rack.
Discharge permits required.
Discharge permits required.
Discharge permits required.
Easly Implemented.
Restrictions on Mure land us*.
Eatly hnpftmenttd
Restrictions on future land us*.
Easly Implemented.
Restrictions on future tend us*.
Restrictions on future land us*.
Very dMcutt to Implement-re -
quires deep trenching through rock.
Reaovy tmpl*msnMbls.
Readvy (mpiemanialils,
pei mil inquired.
Nearest RCRA fadlty
250 miles away.
Deadly tiipleiiientable.
Permit required.
Permit leqUred.
Permit required.
Nan*.
rhuJjMs cost
•^^^ ^^~ .^^j ^^—
nsjn aapajsj, nw v
OftM.
Htah Cfa^risM. tow
O&M.
Low capita), low
O&M.
Very high capital.
tow O&M.
tM,^. «^hMfc«l l«^^
nsjj" capm. low
OftM.
Hkjh capital, low
O&M.
Low capital, tow
maintenance.
Low capital, high
maintenance.
Moderate capital,
high maintenance
Moderate capital.
mod. maintenance.
Very high capital.
tow O&M.
Hghcapke).
moderate OAM.
Hkjh capital.
high O&M.
Moderate capital.
low O&M.
Hkjh transport*-
tion cost
Low capital, very
low O&M.
Hkjh capital, low
O&M.
OAM.
-------
OSWER Directive 9355.3-01
2) the effectiveness of the process options in protecting human health
and the environment during the construction and implementation phase;
and 3) hov proven and reliable the process is with respect to the
contaminants and conditions at the site.
Information needed to evaluate the effectiveness of technology
types for the different media includes contaminant type and concentra-
tion, the area or volume of contaminated media, and, when appropriate,
rates of collection of liquid or gaseous media. For some media it may
be necessary to conduct preliminary analyses or collect additional site
data to adequately evaluate effectiveness. This is often the case for
processes in which the rates of removal or collection and treatment are
needed for evaluation, such as for ground-water extraction,
surface-water collection treatment, or subsurface gas collection. In
such cases, a limited conceptual design of the process may need to be
developed, and modeling of the potential environmental transport
mechanisms associated with their operation may be undertaken.
Typically, however, such analyses are conducted during the later phases
of the FS when alternatives are refined and evaluated on a sitewide
basis.
If modeling of transport processes is undertaken (during either the
alternative development or screening phases of the FS) to evaluate
removal or collection technologies, and if many contaminants are present
at the site, it may be necessary to identify indicator chemicals, as is
sometimes done for risk assessments, to simplify the analysis.
Typically, indicator chemicals are selected on the basis of their
usefulness in evaluating potential effects on public health and the
environment. Commonly selected indicator chemicals include those that
are most mobile and most toxic. The Superfund Public Health Evaluation
Manual contains more information on selecting indicator chemicals.
4-26
-------
OSWER Directive 9355.3-01
4.2.5.2 Implementability Evaluation
iBplomcntability encompasses both the technical and institutional
feasibility of implementing a technology process. As discussed in Sec-
tion 4.2.4, technical implementability is used as an initial screen of
technology types and process options to eliminate those that are clearly
ineffective or unworkable at a site. Therefore, this subsequent, more
detailed evaluation of process options places greater emphasis on the
institutional aspects of implementability, such as the ability to obtain
necessary permits for offsite actions, the availability of treatment,
storage, and disposal services (including capacity), and the availabil-
ity of necessary equipment .and skilled workers to implement the
technology.
4.2.5.3 Cost Evaluation
Cost plays a limited role in the screening of process options.
Relative capital and O&M costs are used rather than detailed estimates.
At this stage in the process, the cost analysis is based on engineering
judgment, and each process is evaluated as to whether costs are high,
low, or medium relative to other process options in the same technology
type. As discussed in Chapter 5, "Screening of Alternatives," the
greatest cost consequences in site remediation are usually associated
with the degree to which different general technology types (i.e.,
containment, treatment, excavation, etc.) are used. Using different
process options within a technology type usually has a lesser effect on
cost.
4.2.6 Assemble Alternatives
In assembling alternatives, general response actions and the
process options chosen to represent the various technology types for
each medium or operable unit are combined to form alternatives for the
site as a whole. As discussed in Section 4.1.2.2, appropriate treatment
and containment options should be developed. To assemble alternatives,
4-27
-------
OSWER Directive 9355.3-01
general response actions should be combined using different technology
types and different volumes of media and/or areas of the site. Often
more than one general response action is applied to each medium. For
example, alternatives for remediating soil contamination will depend on
the type and distribution of contaminants and may include incineration
of soil from some portions of the site and capping of others.
For sites at which interactions among media are not significant
(i.e., source control actions will not affect ground-water or surface-
water responses) the combination of medium-specific actions into
sitewide alternatives can be made later in the FS process, either after
alternatives have been screened or the detailed analysis has been
completed. If media interactions are not of concern, the FS may, for
example, describe three soil remediation options, four ground-water
remediation options, and three remediation of contaminated structures
(instead of developing 36 sitewide alternatives). These
10 medium-specific options could be screened in the following FS phase
and evaluated during detailed analysis prior to being combined into
sitewide alternatives. Although this approach permits greater
flexibility in developing alternatives and simplifies the analyses of
sitewide alternatives, it may involve greater effort in developing and
analyzing medium-specific options.
Figure 4-7 illustrates how general response actions may be combined
to form a range of sitewide alternatives. For this relatively simple
example, the two media of interest are soil and ground water. The range
of alternatives developed include: a no-action alternative
(alternative 1); an alternative that provides for treatment of all soil
-6
contaminants to the 10 risk level and rapid remediation of ground
-6
water to 10 risk level (alternative 2); three alternatives that
employ treatment of soil and ground water to various risk levels with
different disposal options (alternatives 3, 4, and 5); and three
alternatives that employ various levels of containment, with and without
ground-water collection and treatment (alternatives 6, 7, and 8).
4-28
-------
OSWER Directive 9355.3-01
Although not shown in this example, a description of each
alternative should be included in the FS report. For the alternatives
•hewn in Figure 4-7, such descriptions would include the locations of
areas to be excavated or contained, the approximate volumes of soil
and/or ground water to be excavated and collected, the approximate
locations of interceptor trenches, the locations of potential city water
supply hook-ups, the locations of potential discharges to surface water
or connections to the local POTW, management options for treatment
residuals, and any other information needed to adequately describe the
alternative and document the logic behind the assembly of general
response actions into specific remedial action alternatives. In
describing alternatives, it is important to note those process options
that were not screened out and that are represented by those described
in the alternative.
4.3 COMMUNITY RELATIONS DURING ALTERNATIVE DEVELOPMENT
Community relations activities implemented for site
characterization may also be appropriate during the development of
alternatives. Activities focus on providing information to the
community concerning the development of remedial alternatives and
obtaining feedback on community interests and concerns associated with
such alternatives. Community relations activities should be site- and
community-specific and are usually stipulated in the community relations
plan that is prepared during scoping activities. Community relations
activities during the development of alternatives may include, but are
not limited to, a fact sheet describing alternatives identified as
potentially feasible, a workshop presenting citizens with Agency
considerations in developing alternatives, briefings of local officials
and concerned citizens on alternatives under consideration, a small
group meeting for citizens involved with the site, and news releases
describing technologies being evaluated.
If alternatives are being developed concurrently with the RI site
characterization, then information on the screening of technologies and
remedial alternative development should be included in public
4-29
-------
FIOURE 4-7
AttEMtUMQ A RANOE OP ALTERNATIVE EXAMPLES
OPCRAt RUEONK
term
MEDUM
•OM.
OROUNOWATEf
TECHNOLOGY
TWE
ACCESS
NtBTNenoM
PULMU)
EXCAVATION
OMPOSAL
TNEAT1CNT
ONSITE
TREATMENT
OFRSTTE
CAfVMO
ALTERNATE
WATER
SUPPLY
MDJWTOmNC
COLLECTION
wrrw
BflEHCCPTOt
TRENCHES
TREATMENT
wrrw
ONOTE
OKIIMVt
MEAOR
VOLUME
EMTIRE
•m
AUtOIL .
A«OVE 10*
AUMIL^
AtOVEtO-4
ONHTERCRA
LANDFILL
ONSfTE
NON-RCRA
LANDFILL
arrsm
RCRA
LANDRLL
ALL SOIL
TOUT*
ALL SOIL
T0103
ENTfC
SITE
ALL
(REWUNINa)
•OIL ABOVE
10«
ALLRESIDENTa
INAmCTED
AfCA
ALL
MONITORING
WELLS TWICE
AVEAR
ALL WATER
ABOVE 104
WTTHIN 10 VRJ
Aa WATER
ABOVE 1C4
WITHIN 10 VRi
ALL WATER.
ABOVE 10*
WITHIN K VR
TO 104
TO Iff4
OMMTI TO
LOCAL
STWAM
OFWTE
TOPOTW
1
NO
ACTON
•
•
•
2
NO
LONQ-TERM
SOURCE
lUNAQEMBfl
«EDED,
MPOOW
CXEAN4JP
•
•
•
•
•
•
•
3
TREATMENT
ASA
PftMCFAL
ELEMENT
(10*)
•
•
•
•
•
•
4
TREATMENT
ASA
PRNCPAL
ELEMENT
Off4)
•
•
•
•
•
•
•
•
5
TREATMENT
ASA
PRMCIPAL
ELEMENT
•
•
•
•
•
•
•
6
SOURCE
CONTAMMEK
OH
CONTROLS
•
•
•
•
•
•
7
SOURCE
OONTAMMEN
NOOW
CONTROLS
•
•
•
•
•
8
CONTAINMEN
•4NMUM)
•
•
•
Not*: Th*»«c
fe Ming «• ovrpfe of oMnogwife rirt angm:
4-30
-------
OSWER Directive 9355.3-01
information materials and activities prepared during site
characterization. If alternatives are developed after site
characterization, additional community relations activities should be
conducted. In general, community relations activities during
alternative development are most appropriate if citizens are
significantly concerned over site conditions and RI/FS activities which
are being implemented at the site. The following are objectives of
community relations activities at this phase:
o Keep the community apprised of the Agency's decisionmaking
process
o Enhance citizen understanding of issues pertaining to
development, evaluation, and selection of remedial
alternatives
o Obtain feedback from the community on any concerns they may
have with technologies and alternatives under consideration
The level of effort for community relations at this phase should be
described in the community relations plan.
4.4 REPORTING AND COMMUNICATION DURING ALTERNATIVE DEVELOPMENT
No formal report preparation is required during alternative
development except whatever routine administrative and project
management tracking methods have been designated for use by the lead
agency and their contractor(s). However, communication among the lead
and support agencies and their contractor(s) is very important during
the development of alternatives to obtain input and agreement on the
technologies or processes and alternatives considered for implementation
at the site. As shown in Table 4-2, communication should occur to
facilitate the initial screening of technologies and process options, to
agree on what additional site data may be needed, and to gain input and
agreement on the choice of representative processes and combinations
4-31
-------
OSWER Directive 9355.3-01
to b« used to assemble alternatives. For purposes of speed and
efficiency, the preferred approach for the exchange of information is
through meetings. However, other approaches that facilitate effective
review and input (e.g., technical memorandums for review) may be used at
the lead agency's discretion.
WDR276/012
4-32
-------
OSWER Directive 9355.3-01
Table 4-2
REPORTING AND COMMUNICATION DURING ALTERNATIVE DEVELOPMENT
Information Needed
All potential tech-
nologies included
for consideration
Need for additional
field data or treat-
ability studies
Purpose
For lead agency and contractor
to identify potential technolo-
gies; for lead agency to obtain
support agency review and
comment
Potential
Methods for
Information
Provision
1 - Meeting
2 - Tech Memo
3 - Other
Process evaluation
and alternative
development
For lead agency and contractor to 1 - Meeting
determine whether more field data 2 - Tech Memo
or treatability tests are needed 3 - Other
to evaluate selected technologies;
for lead agency to obtain support
agency review and comment
For lead agency and contractor to 1 - Meeting
communicate and reach agreement 2 - Tech Memo
on technology screening and 3 - Other
alternative development; for
lead agency to obtain support
agency review and comment
WDR276/014
4-33
-------
CHAPTER 5
FS PHASE II
SCREENING OF
ALTERNATIVES
FROM:
• Prtiminwy
AMMimwrt
• Sit ln*p«tion
• NPLUltlng ,
1
SITE i
4 A *
• i
SCOPING OF THE RVFS 1 1
SITE
PLANNING
PROJECT 1 |
PLANNING i I
^ Y
w DEVELOPMENT/ | fiCNEEfWO
TREATABILITY
INVESTIGATIONS
\
>
/:. ^
s fe.=H:SH-
, \ • R«iiBdi*l Adion
SCREENING OF
ALTERNATIVES
• Screen Alternatives to Reduce
Number Subject to Detailed
Analysis
• Preserve Good Range of
Options
-------
OSWER Directive 9355.3-01
CHAPTER 5
SCREENING OF ALTERNATIVES
5.1 INTRODUCTION
5.1.1 Purpose of Alternative Screening
The objective of alternative screening is to narrow the list of
potential alternatives (based on their effectiveness, implementability,
and cost) that will be evaluated in detail. This screening aids in
streamlining the feasibility study process while ensuring that the most
promising alternatives are being considered. As discussed earlier, in
some situations the number of viable alternatives to address site prob-
lems may be limited; thus, the screening effort may be minimized or
unecessary.
Screening is used as a tool throughout the alternative development
process to narrow the universe of options being considered. When alter-
natives are first being developed, individual technologies are screened
primarily on their ability to meet medium-specific remedial action
objectives, as well as with respect to their implementability and cost.
The remaining technologies are then assembled into alternatives designed
to meet the remedial action objectives developed for the site or
operable unit. Dependent on the number of viable alternatives initially
developed, the list of potential alternatives may need to be screened to
reduce the number of alternatives that will be analyzed in detail.
While screening alternatives, the range of treatment and containment
alternatives initially developed should be preserved to the extent it
makes sense to do so.
5-1
-------
OSWER Directive 9355.3-01
5.1.2 Context of Screening
The screening of alternatives follows the conceptual development of
alternatives and precedes the detailed analysis of alternatives. Prior
to screening, technologies should be identified and combined into alter-
natives, although specific details of the alternatives may not be
defined. During screening, the extent of remedial action (e.g.,
quantities of media to be affected), the sizes and capacities of process
options, and other details of each alternative should be further
defined, as necessary, so that screening evaluations can be conducted.
Because the FS may be comprised of many complex, interrelated, and
overlapping steps, the boundaries between the FS phases, as described
here, are often less distinct in actual practice. This three phased
discussion of the FS is used primarily to help portray more simply the
overall process.
The scope of screening can vary substantially depending on the num-
ber and type of alternatives developed and the extent of information
necessary for conducting the detailed analysis. The scope and emphasis
of screening can also vary depending on either the degree to which the
assembled alternatives address the combined threats posed by the entire
site or on the individual threats posed by separate site areas or
contaminated media.
5.1.3 Screening Process Overview
Three distinct steps are typically conducted during the screening
of alternatives. First, the alternatives are further refined as
appropriate. Second, the alternatives are evaluated on a general basis
to determine their effectiveness, implementability, and cost. Third, a
decision is made, based on this evaluation, as to which alternatives
should be retained for further analysis.
Alternatives are further refined by better quantifying the areas
and volumes of media of interest and the sizes and capacities of the
process options that make up each of the alternatives. During this
phase, the remedial action objectives developed earlier for each medium
5-2
-------
OSWER Directive 9355.3-01
or operable unit are revised as necessary to incorporate any new risk
assetotent information being generated from the RI to ensure that the
alternatives provide adequate protectiveness. Also at this stage, the
areas and quantities of contaminated media initially specified in the
general response actions may also be reevaluated with respect to the
effects of interactions between media. Often, source control actions
influence the degree to which ground-water remediation can be
accomplished or the time frame in which it can be achieved. In such
instances, further analyses may be conducted to modify either the source
control or ground-water response actions to achieve greater
cost-effectiveness in sitewide alternatives.
Using the refined alternative configurations developed above, more
detailed information about the technology process options may be
developed. This information might include data on the size and
capacities of treatment systems, the quantity of materials required for
construction, and the configuration and design requirements for
ground-water collection systems.
Information available at the time of screening should be used
primarily to identify and distinguish any differences among the various
alternatives and evaluate each alternative with respect to its effec-
tiveness, implementability, and cost. Only the alternatives judged as
the best or most promising on the basis of these evaluation factors
should be retained for further consideration and analysis. Typically,
those alternatives that are screened out will receive no further consid-
eration unless additional information becomes available that indicates
further evaluation is warranted. As discussed in Section 4.2.6, for
sites at which interactions among media are not significant, the process
of screening alternatives, described here, may be applied to medium-
specific options to reduce the number of options that will either be
It is important to avoid confusion between the screening of
technologies done during the development of alternatives (see
Section 4.2.4) and the screening of alternatives described in this
Chapter.
5-3
-------
OSWER Directive 9355.3-01
combined into sitewide alternatives at the conclusion of screening or
will await further evaluation in the detailed analyses. The screening
of alternatives is shown conceptually in Figure 5-1.
5.2 ALTERNATIVES SCREENING PROCESS
5.2.1 Alternatives Definition
Before beginning screening, alternatives have been assembled pri-
marily on medium-specific considerations and iaplementability concerns.
Typically, few details of the individual process options have been iden-
tified, and the sizing requirements of technologies or remediation time
frames have not been fully characterized (except for time frames iden-
tified to develop ground-water action alternatives). Furthermore,
interactions among media, which may influence remediation activities,
have usually not been fully determined, nor have sitewide protectiveness
requirements been addressed. Therefore, at this point in the process,
such aspects of the alternatives must be further defined to form the
basis for evaluating and comparing the alternatives prior to their
screening.
5.2.1.1 Specific Objectives
Alternatives are initially developed and assembled to meet a set of
remedial action objectives for each medium of interest. During screen-
ing, the assembled alternatives should be evaluated to ensure that they
protect human health and the environment from all potential pathways at
the site or those areas of the site being addressed as part of an
operable unit. If more than one pathway is present, such as inhalation
of airborne contaminants and ingestion of contaminants in ground water,
the overall risk level to receptors should be evaluated. If it is found
that an alternative is not fully protective, a reduction in exposure
levels for one or more media will need to be made to attain a risk level
-4 -7
within the target range (i.e., 10 to 10 ).
5-4
-------
FIGURE 5-1
SCREENING OF ALTERNATIVES
OSWER Directive 9355.3-01
Refine Remedial
Action
Objectives
Development of
Alternatives
Unselected
Alternatives
FAIL
Alternatives
(Combinations of
Process Options)
Define Alternatives
Evaluate
Defined
Alternatives
Retained
Alternatives
Verify
Action-Specific
ARARs
1
r
Reevaluate
Data Needs
Detailed
Analysis of
Alternatives
Additional
Investigations
as Necessary
-------
OSWER Directive 9355.3-01
In refining alternatives, it is important to note that
protectiveness is achieved by reducing exposures to acceptable levels,
but achieving these reductions in exposures may not always be possible
by actually cleaning up a specific medium to these same levels. For
example, protectiveness of human health at a site may require that
concentrations of contaminants in drinking water be reduced to levels
that could not reasonably be achieved for the water supply aquifer;
thus, protectiveness could be provided by preventing exposures with the
use of a wellhead treatment system. The critical selection of how risk
reductions are to be achieved is part of the risk management
decisionmaking process„
5.2.1.2 Define Media and Process Options
Alternatives should be defined to provide sufficient quantitative
information to allow differentiation among alternatives with respect to
effectiveness, implementability, and cost. Parameters that often
require additional refinement include the extent or volume of
contaminated material and the size of major technology and process
options.
Refinement of volumes or areas of contaminated media is important-
at some sites at which ongoing releases from the source (or contaminated
soils) significantly affect contaminant levels in other media (e.g.,
ground water), because such interactions may not have been addressed
when alternatives were initially developed by grouping medium-specific
response actions. If interactions among media appear to be important at
a site, the effect of source control actions on the remediation levels
or time frames for other media should be evaluated.
Figure 5-2 provides an example of such an analysis in which volatile
organics in soil are migrating into an underlying aquifer composed of
unconsolidated materials. Using a model of transport processes at the
site, the effect of different soil removal actions on ground-water reme-
diation (using a specified extraction scheme) could be estimated. In
5-6
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FIGURE 5-2. TIME TO ACHIEVE 10~4 TO 10~6 RISK LEVEL FOR A SINGLE-
CONTAMINANT FOR GROUNDWATER CLEANUP UNDER VARIOUS
SOIL REMOVAL ALTERNATIVES
10
ui
_i
X
in
tr.
cc
UJ
u
10
80
90
TIME IN YEARS
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OSWER Directive 9355.3-01
thia example, development of alternatives that consider ground-water
actions independent of soil removal (i.e., the no-soil-removal scenario)
could result in underestimating the achievable remediation level or
overestimating the time frame for ground-water remediation. This could
result in an overestimation of the extraction and treatment requirements
for technology processes for ground water. By evaluating soil-ground-
water interactions together, the rates and volumes of ground-water
extraction to achieve the target remediation levels can be refined more
accurately.
After the alternatives have been refined with respect to volumes of
media, the technology process options need to be defined more fully with
respect to their effectiveness, implementability, and cost such that
differences among alternatives can be identified. The following infor-
mation should be developed, as appropriate, for the various technology
processes used in an alternative:
o Size and configuration of onsite extraction and treatment sys-
tems or containment structures—For media contaminated with
several hazardous substances, it may be necessary to first
determine which contaminant(s) impose the greatest treatment
requirements; then size or configure accordingly. Similarly,
for ground-water extraction technologies at sites with
multiple ground-water contaminants, it may be necessary to
evaluate which compounds impose the greatest limits on
extraction technologies, either because of their chemical/
physical characteristics, concentration, or distribution in
ground water.
o Time frame in which treatment, containment, or removal goals
can be achieved—The remediation time frame is often interde-
pendent on the size of a treatment system or configuration of
a ground-water extraction system. The time frame may be based
on specific remediation goals (e.g., attaining ground-water
remediation goals in 10 years), in which case the technology
is sized and configured to achieve this; the time frame may
also be influenced by technological limitations (such as
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OSWER Directive 9355.3-01
maximum size consideration, performance capabilities, and/or
availability of adequate treatment systems or disposal
capacity).
o Rates or flows of treatment—These will also influence the
sizing of technologies and time frame within which remediation
can be achieved.
o Spatial requirements for constructing treatment or containment
technologies or for staging construction materials or
excavated soil or waste
o Distances for disposal technologies—These include approximate
transport distances to acceptable offsite treatment and
disposal facilities and distances for water pipelines for
discharge to « receiving stream or a POTW.
o Required permits and imposed limitations—These include NPDES,
pretreatment, and emission control requirements; coordination
with local agencies and the public, and other legal consid-
erations. These may also encompass some action-specific as
well as location- and chemical-specific ARARs.
5.2.2 Screening Evaluation
Defined alternatives are evaluated against the short- and long-term
aspects of three broad criteria: effectiveness, implementability, and
cost. Because the purpose of the screening evaluation is to reduce the
number of alternatives that will undergo a more thorough and extensive
analysis, alternatives will be evaluated more generally in this phase
than during the detailed analysis. However, evaluations at this time
should be sufficiently detailed to distinguish among alternatives. In
addition, one should ensure that the alternatives are being compared on
an equivalent basis (i.e., definitions of treatment alternatives are
approximately at the same level of detail to allow preparation of
comparable cost estimates).
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OSWER Directive 9355.3-01
Initially! specific technologies or process options were evaluated
primarily on whether or not they could meet a particular remedial action
objective. During alternative screening, the entire alternative is
evaluated as to its effectiveness, iroplementability, and cost.
During the detailed analysis, the alternatives are evaluated
against nine specific criteria and their individual factors rather than
the general criteria used in screening. Therefore, individuals
conducting the FS should be familiar with the nine criteria at the tine
of screening to better understand the direction that the analysis will
be talcing.
It is also important to note that comparisons during screening are
usually made between similar alternatives (the most promising of which
is carried forward for further analysis); whereas, comparisons during
the detailed analysis will differentiate across the entire range of
alternatives. The criteria used for screening are described in the fol-
lowing sections.
5.2.2.1 Effectiveness Evaluation
A key aspect of the screening evaluation is the effectiveness of
each alternative in protecting human health and the environment. Each
alternative should be evaluated as to the protectiveness it will provide
and the reductions in toxicity, mobility, or volume it will achieve.
Both short- and long-term components of protectiveness should be evalu-
ated; short-term referring to the construction and implementation
period, and long-term referring to the period after the remedial action
is complete. Reduction of toxicity, mobility, or volume refers to
changes in one or more characteristics of the hazardous substances or
contaminated media by the use of treatment that decreases the threats or
risks associated with the hazardous material.
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OSWER Directive 9355.3-01
5.2.2.2 Implementability Evaluation
ISplementability, as a measure of both the technical and
administrative feasibility of constructing, operating, and maintaining a
remedial action alternative, is used during screening to evaluate the
combinations of process options with respect to conditions at a specific
site. Technical feasibility refers to the ability to construct,
reliably operate, and meet technology-speed fie regulations for process
options until a remedial action is complete; it also includes operation,
maintenance, replacement, and monitoring of technical components of an
alternative, if required, into the future after the remedial action is
complete. Administrative feasibility refers to the ability to obtain
approvals from other offices and agencies, the availability of
treatment, storage, and disposal services and capacity, and the
requirements for, and availability of, specific equipment and technical
specialists.
Determinations of an alternative not being technically feasible and
not being available will often preclude it from further consideration
unless steps can be taken to change the conditions responsible for the
determination. Often, this type of fatal flaw would have been
identified during technology screening, and the infeasible alternative
would not have been assembled. Negative factors affecting
administrative feasibility will normally involve coordination steps to
lessen the negative aspects of the alternative but will not necessarily
eliminate an alternative from consideration.
5.2.2.3 Cost Evaluation
Typically, alternatives will have been defined well enough before
screening that some estimates of cost are available for comparisons
among alternatives. However, because uncertainties associated with the
definition of alternatives often remain, it may not be practicable to
define the costs of alternatives with the desirable accuracy (i.e.,
+50 percent to -30 percent) used in the detailed analysis.
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OSWER Directive 9355.3-01
Absolute accuracy of cost estimates during screening is not criti-
cal. The focus should be to make comparative estimates for alternatives
with relative accuracy so that cost decisions among alternatives will be
sustained as the accuracy of cost estimates improves beyond the
screening process. The procedures used to develop cost estimates for
alternative screening are similar to those used for the detailed analy-
sis; the only differences would be in the degree of alternative
refinement and in the sources used to develop cost components.
Cost estimates for screening alternatives typically will be based
on a variety of cost-estimating data. Bases for screening cost esti-
mates may include cost curves, generic unit costs, vendor information,
conventional cost-estimating guides, and prior similar estimates as
modified by site-specific information.
Prior estimates, site-cost experience, and good engineering
judgments are needed to identify those unique items in each alternative
that will control these comparative estimates. Cost estimates for items
common to all alternatives or indirect costs (engineering, financial,
supervision, outside contractor support, contingencies) do not normally
warrant substantial effort during the alternatives screening phase.
Both capital and O&M costs should be considered, where appropriate,
during the screening of alternatives. The evaluation should include
those O&M costs that will be incurred for as long as necessary, even
after the initial remedial action is complete. Likewise, potential
future remedial action costs should be considered during alternative
screening to the extent they can be defined. Present worth analyses
should be used during alternative screening to evaluate expenditures
that occur over different time periods. By discounting all costs to a
common base year, the costs for different remedial action alternatives
can be compared on the basis of a single figure for each alternative.
A more detailed discussion of evaluating cost is presented in
Chapter 7.
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OSWER Directive 9355.3-01
5.2.2.4 Innovative Technologies
Technologies are classified as innovative if they are developed
fully but lack sufficient cost or performance data for routine use at
Superfund sites. In many cases, it will not be possible to evaluate
alternatives incorporating innovative technologies on the same basis as
available technologies, because insufficient data exist on innovative
technologies. If treatability testing is being considered to better
evaluate an innovative technology, the decision to conduct a test should
be made as early in the process as possible to avoid delays in the RI/FS
schedule.
Innovative technologies would normally be carried through the
screening phase if there is a reason to believe that the innovative
technology will be shown to offer significant advantages. These advan-
tages may be in the form of better treatment performance or imple-
mentability, fewer or lesser adverse impacts than other available
approaches, or lower costs for similar levels of performance. A
"reasonable belief exists if all indications from other full-scale
applications under similar circumstances or from bench-scale or pilot-
scale treatability testing supports the expected advantages.
5.2.3 Alternative Screening
5.2.3.1 Criteria for Screening
Alternatives with the most favorable composite evaluation of all
factors should be retained for further consideration during detailed
analysis. Alternatives selected for further evaluation should, where
practicable, preserve the range of treatment and containment techno-
logies initially developed. It is not a requirement that the entire
range of alternatives originally developed be preserved if all alterna-
tives in a portion of the range are not good viable options.
The target number of alternatives to be carried through screening
should be set on a site-specific basis in conjunction with the lead
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OSWER Directive 9355.3-01
agency. It is txpected that the typical target number of alternatives
carried through screening (including containment and no-action alterna-
tives) would not exceed 10. Fewer alternatives should be carried
through screening, if possible, while adequately preserving the range of
remedies. If the alternatives being screened are still medium-specific,
rather than addressing the entire site or operable unit, the number of
alternatives retained for each specific medium would be considerably
less than 10.
5.2.3.2 Selection of Alternatives for Detailed Analysis
Once the evaluation has been conducted for each of the alterna-
tives, the lead agency and its contractor should meet with the support
agency to discuss each of the alternatives being considered. This meet-
ing does not correspond to a formal quality control review stage but
provides the lead agency and its contractor with input from the support
agency and serves as a forum for updating the support agency with the
current direction of the FS.
The alternatives recommended for further consideration should be
agreed upon at this meeting so that documentation of the results of
alternative screening is complete; any additional investigations that
may be necessary are identified; and the detailed analysis can commence.
Unselected alternatives may be reconsidered at a later step in the
detailed analysis if similar retained alternatives continue to be evalu-
ated favorably or if information is developed that identifies an addi-
tional advantage not previously apparent. This provides the flexibility
to double check a decision that was made previously or to review vari-
ations of alternatives being considered (e.g., consideration of other
similar process options). However, it is expected that under most cir-
cumstances, once an alternative is screened out, it will not be
reconsidered for selection.
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OSWER Directive 9355.3-01
5.2.3.3 Post-screening Tasks
The completion of the screening process leads directly into the
detailed analysis and nay serve to identify additional investigations
that may be needed to adequately evaluate alternatives. To ensure a
smooth transition from the screening of alternatives to the detailed
analysis, it will be necessary to identify and begin verifying action-
specific ARARs and initiate treatability testing (if not done
previously) and additional site characterization, as appropriate.
Although the consideration of action-specific ARARs begins earlier
as process options are combined, the identification of action-specific
ARARs will need to be more definitive as the alternatives become better
defined. At the conclusion of screening, sufficient information should
exist on the technologies and configurations of greatest interest so
that the lead agency can initiate discussion with the support agency on
action-specific ARARs. As with chemical-specific ARARs, action-specific
ARARs should include all Federal requirements and any State requirements
that either are more stringent than Federal ARARs or specify require-
ments where no Federal ARARs exist.
Once the field of alternatives has been narrowed, the technology
processes of greatest interest can be identified. At this point, the
need for treatability tests (if not identified earlier) can be deter-
mined for process options that will require additional data for detailed
analysis. Although the results of treatability testing will not be used
until the detailed analysis, they should be initiated as early in the
process as possible to minimize any potential delays on the FS schedule.
The type and scope of treatability tests depends on the expected data
requirements for detailed analysis of alternatives. Factors involved in
determining the need for and scope of treatability studies are discussed
in Chapter 6.
In some cases, the need for additional site characterization may
also be identified during the screening phase. Because the nature and
extent of contamination should be well defined by the end of the RI site
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OSWER Directive 9355.3-01
characterizations, field investigations at this time should be conducted
only to batter define the effect of site conditions on the performance
of the technology processes of greatest interest.
5.3 COMMUNITY RELATIONS DURISG A1XERHATIVE SCREENING
Conmunity relations activities implemented earlier in the RI/FS
process may be appropriate for screening. Activities should focus on
providing information to the community concerning the screening of
alternatives and on obtaining feedback on community interests and
concerns. These activities should be site- and community-specific and
are usually stipulated in the community relations plan that is prepared
during the scoping of the project. It is important to note that public
interest typically increases as the flexibility study progresses; and
that the technical adequacy of a remedy does not ensure community
acceptance. Therefore, the community relations activities should be
planned and conducted to address such interest and potential concerns.
Community relations activities that may be appropriate include, but
are not limited to, briefings of local officials and concerned citizens
on alternatives under consideration, a fact sheet or workshop presenting
citizens with alternatives identified for detailed analysis, a small
group meeting with citizens involved with the site, and news releases
describing technologies being evaluated.
For some sites, it may be appropriate to combine some community
relations activities for screening with those for alternative develop-
ment, especially when these two FS phases are combined to streamline the
process. Presentations to the commtmity on the screening of technolo-
gies and the development and screening of alternatives may, at times, be
grouped together logically to provide information on how alternatives
were selected for detailed analysis.
In general, community relations activities during screening are
most appropriate at sites where citizens are actively concerned over
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OSWER Directive 9355.3-01
•ite conditions and remedial actions being implemented at the site. The
following are objectives of community relations activities during this
phase:
o Keep the community apprised of the Agency's decisionmaking
process
o Enhance citizen understanding of issues pertaining to the
screening and selection of remedial alternatives
o Obtain feedback from the community on alternatives under con-
sideration
The level of effort for community relations during this phase
should be described in the community relations plan.
5.4 REPORTING AND COMMUNICATION DURING ALTERNATIVE SCREENING
Coordination between the lead and support agencies is important
throughout the RI/FS process. During screening, the following key coor-
dination points are required:
o The lead and support agencies should agree on the set of
alternatives selected for detailed analysis.
o The lead and support agencies must coordinate identification
of action-specific ARARs.
o The lead agency and its contractor are to evaluate the need
for additional investigations that may be needed prior to
conducting the detailed analysis.
Table 5-1 summarizes the communication requirements among the lead
agency, the support agency, and the FS contractor during screening.
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OSWER Directive 9355.3-01
. Table 5-1
REPORTING AND COMMUNICATION
DURING SCREENING
Potential Methods
of Information
Information Needed Purpose Provision
Results of Alternative For lead agency and contrac- Meeting
Screening tor to communicate and reach Tech Memo
agreement on alternative Other
screening; for lead agency
to obtain support agency re-
view and comment
Identification of For lead agency to obtain Meeting
Action-Specific ARARs input from the support Letter
agency on action-specific Other
ARARs
Need for Additional For lead agency and con- Meeting
Investigation tractor to determine whether Tech Memo
additional investigations Other
are needed to evaluate
selected alternatives; for
lead agency to obtain
support agency review and
comment
WDR276/022
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OSWER Directive 9355.3-01
Reporting approaches should be agreed upon between the FS
contractor and the lead agency RPM. Although no formal report is
required during alternative development and screening, some form of
written documentation of the methods, rationale, and results of
alternative screening (e.g., graphical representation similar to
Figures 4-5 and 4-6 or a technical memorandum) needs to be provided to
the lead and support agencies. If a technical memorandum is prepared,
it can serve as the basis for later development of the chapter(s) in the
FS report that discusses the development and screening of alternatives.
Because the final RI/FS report may eventually be subject to
judicial review, the procedures for evaluating, defining, and screening
alternatives should be well documented, showing the rationale for each
step. The following types of information should be documented to the
extent possible:
o Chemical- and/or risk-based remedial objectives associated
with the alternative
o Modifications to any media-specific alternatives initially
developed to ensure that risk from multiple-pathway exposures
and interactions among source- and ground-water-remediation
strategies are addressed
o Definition of each alternative including extent of remedia-
tion, volume of contaminated material, size of major tech-
nologies, process parameters, cleanup time frames, transporta-
tion distances, and special considerations
o Notation of process options that were not initially screened
out and are being represented by the processes comprising the
alternative
o Screening evaluation summaries of each alternative
o Comparison of screening evaluations among alternatives
WDR309/039
-------
CHAPTER 6
TREATABILITY
INVESTIGATIONS
FROM:
• PrXMnwy
AiMMment
• SIM Intpealan
• NPLUthg
SCOPING OF THE RVFS
Sto
Project
I Planning
SfTE
CHARACTERIZATION/
OEVELOPMENT I
ERNATircS I
/ 1
OETM(.a»
Of ALTER
/v >
• Remedy Selection
• Recon) at Decision
• Remedial Design
• Remedial Action
TREATABILITY
INVESTIGATIONS
• Perform Bench or Pilot
Treatability Tests as Necessary
-------
OSWER Directive 9355.3-01
CHAPTER 6
TREATABILITY INVESTIGATIONS
6.1 INTRODUCTION
As discussed earlier, the phased RI/FS process is intended to better
focus the site investigation so that only those data necessary to support
the RI/FS and the decisionmaking process are collected. Data needs are
initially identified on the basis of the understanding of the site at the
tine the RI/FS is initially scoped. Therefore, initial sampling and testing
efforts may be limited until a more complete understanding of the site
allows subsequent sampling efforts to be better focused. As site
information is collected during the RI and alternatives are being developed,
additional data needs necessary to adequately evaluate alternatives during
the detailed analysis are often identified. These additional data needs may
involve the collection of site characterization data, as described in
Chapter 3, or treatability studies to better evaluate technology
performance. This chapter is intended to provide an overview of the types
of treatability studies (i.e., bench scale, pilot scale) that may be used,
their specific purposes, and important factors that need to be considered
when contemplating their use.
6.1.1 Objectives of Treatability Investigations
The primary objectives of treatability studies are:
. o Provide sufficient data to allow treatment alternatives to be
fully developed and evaluated during the detailed analysis and
support remedial design of a selected alternative
o Reduce cost and performance uncertainties for treatment alterna-
tives to acceptable levels so that a remedy can be selected
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OSWER Directive 9355.3-01
6.1.2 Overview of Treatability Investigations
Treatability studies to collect data on technologies identified during
the alternative development process are conducted/ as appropriate, to pro-
vide additional information for evaluating technologies. The RI/FS contrac-
tor and the lead agency's RFM must review the existing site data and avail-
able information on technologies to determine if treatability investigations
are needed. As discussed earlier, the need for treatability testing should
be identified as early in the RI/FS process as possible. A decision to
conduct treatability testing may be made during project scoping if
information indicates such testing is desirable. However, the decision to
conduct these activities must be made by weighing the cost and time required
to complete the investigation against the potential value of the information
in resolving uncertainties associated with selection of a remedial action.
In some situations, the need for treatability investigations may not be
identified until later in the process and, therefore, may be postponed until
the remedial design phase.
The decision process for treatability investigations is shown concep-
tually in Figure 6-1 and consists of the following steps:
o Determining data needs
o Reviewing existing data on the site and available literature on
technologies to determine if existing data are sufficient to eval-
uate alternatives
o Performing treatability tests, as appropriate, to determine per-
formance, operating parameters, and relative costs of potential
remedial technologies
o Evaluating the data to ensure that data quality objectives are met
6-2
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FIGURE 6-1 OSWER Dlractiv* 9355.3-01
TREATABILITY INVESTIGATIONS
Determine
Data needs
Evaluate Existing
Technology Data
Evaluate Existing
Site Data
Data
Adequate
to Screen or
Evaluate
Alternatives ?
-------
OSWER Directive 9355.3-01
6.2 DETERMINATION OF DATA REQUIREMENTS
To th« extent possible, data required to assess the feasibility of
technologies should be gathered during the site characterization (e.g.,
moisture and heat contact data should be collected if incineration of an
organic waste is being considered). Because data requirements will depend
on the specific treatment process and the contaminants and matrices being
considered, the results of the site characterization will influence the
types of alternatives developed and screened, which will in turn influence
additional data needs. However, data collected during site characterization
will not always be adequate for assessing the feasibility of remedial tech-
nologies, and, in fact, the need for detailed data from treatability tests
may not become apparent until the initial screening of alternatives has been
completed. A description of data requirements for selected technologies is
presented in Table 6-1. The Technology Screening Guide for Treatment of
Contaminated Soils and Sludges (EPA, under preparation) summarizes data
needs for a larger number of available and innovative technologies. The
Superfund Innovative Technology Evaluation (SITE) program is another source
to assist with the identification of data needs and to obtain performance
information on innovative technologies.
Additional data needs can be identified by conducting a more exhaustive
literature survey than was originally conducted when potential technologies
were initially being identified. The objectives of a literature survey are
as follows:
o Determine whether the performance of those technologies under con-
sideration have been sufficiently documented on similar wastes
considering the scale (e.g., bench, pilot, or full) and the number
of times the technologies have been used
o Gather information on relative costs, applicability, removal effi-
ciencies, O&n requirements, and implementability of the candidate
technologies
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OSWER Directive 9355.3-01
TABLE 6-1. TYPICAL DATA REQUIREMENTS FOR REMEDIATION TECHNOLOGIES
Technology
Thermal
Destruction
Waste Matrix
Soils
Air Stripping
Liquids
Ground Water
Metal Hydroxide
Precipitation
Ground Water
In Situ Vapor
Extraction
Soils
Example Data
Required
Moisture content
Heat value
Chlorine content
Destruction efficiency
Heat value
Concentration of metals
Destruction efficiency
Concentration of volatile
contaminants
Concentration of non-
volatile contaminants
Contaminant removal
efficiencies (obtain-
able from mathematical
models)
Metals concentration
Contaminant removal
efficiency
Sludge generation rate
and composition
Soil type
Particle size
distribution
Concentration of
volatile compounds
Presence of non-volatile
contaminants
Contaminant removal
efficiencies (usually
requires bench- or
pilot-scale work)
[Note: Tables used in this outline are only partial examples.]
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OSWER Directive 9355.3-01
o Determine testing requirements for bench or pilot studies, if
required
6.3 TREATABILITY TESTING
Certain technologies have been sufficiently demonstrated so that
site-specific information collected during the site characterization is
adequate to evaluate and cost those technologies without conducting
treatability testing. For example, a ground-water investigation usually
provides sufficient information from which to size a packed tower air
stripper and prepare a comparative cost estimate. Other examples of when
treatability testing may not be necessary include:
o A developed technology is well proven on similar applications.
o Substantial experience exists with a technology treating well
documented waste materials. (For example, air stripping or carbon
adsorption of ground water contain organic compounds that have
been treated previously in other applications.)
o Relatively low removal efficiencies are required (e.g., 50 to
90 percent), and data are already available.
Frequently, technologies have not been sufficiently demonstrated or
characterization of the waste alone is insufficient to predict treatment
performance or to estimate the size and cost of appropriate treatment units.
Furthermore, some treatment processes are not sufficiently understood for
performance to be predicted, even with a complete characterization of the
wastes. For example, it is often difficult to predict biological toxicity
in a biological treatment plant without pilot tests. When treatment
performance is difficult to predict, an actual testing of the process may be
the only means of obtaining the necessary data. In fact, in some situations
it may be more cost-effective to test a process on the actual waste than it
would be to characterize the waste in sufficient detail to predict perfor-
mance.
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OSWER Directive 9355.3-01
Treatability testing performed during an RI/FS is used to adequately
evaluate a specific technology, including evaluating performance, determin-
ing process sizing, and estimating costs in sufficient detail to support the
remedy-selection process. Treatability testing in the RI/FS is not meant to
be used soley to develop detailed design or operating parameters that are
more appropriately developed during the remedial design phase.
Treatability testing can be performed by using bench-scale or pilot-
scale techniques, which are described in detail in the following sections.
However, in general, treatability studies will include the following steps:
o Preparing a work plan (or modifying the existing work plan) for
the bench or pilot studies
o Performing field sampling, and/or bench testing, and/or pilot
testing
o Evaluating data from field studies, and/or bench testing, and/or
pilot testing
o Preparing a brief report documenting the results of the testing
6.3.1 Bench-Scale Treatability Studies
Bench testing usually is performed in a laboratory, in which compara-
tively small volumes of waste are tested for the individual parameters of a
treatment technology. These tests are generally used to determine if the
"chemistry" of the process works and are usually performed in batch (e.g.,
"jar tests"), with treatment parameters varied one at a time. Because small
volumes and inexpensive reactors (e.g., bottles or beakers) are used, bench
tests can be used economically to test a relatively large number of both
performance and waste-composition variables. It is also possible to evalu-
ate a treatment system made up of several technologies and to generate
limited amounts of residuals for evaluation. Bench tests are typically per-
formed for projects involving treatment or destruction technologies. How-
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OSWER Directive 9355.3-01
ever, care Bust be taken in attempting to predict the performance of
full-scale processes on the basis of these tests.
Bench-scale testing is useful for a developing technology, because it
can be used to test for a wide variety of operating conditions. In such
cases, bench tests can also be used to determine broad operating conditions
to allow optimization during additional bench or possibly larger-scale pilot
tests to follow.
Bench-scale testing usually consists of a series of tests, with the
results of the previous analysis determining the next set of conditions to
evaluate. The first tests usually cover a broad range of potential operat-
ing conditions in order to narrow the conditions for subsequent tests. For
example, pH is the most important parameter for hydroxide precipitation of
heavy metals. An initial "screening" jar test might be performed in which
the pH range is varied from 7 through 12 in whole pH units. After finding a
minimum metals concentration at pH 9, additional testing could be performed
at narrower pH intervals around 9. The initial screening tests need not be
performed to the same high level of accuracy used in the final tests to pre-
dict treatment effectiveness.
Bench testing can usually be performed over a few weeks or months, and
the costs are usually only a small portion of the total RI/FS cost. Costs
for bench testing are usually significantly lower than those for pilot test-
ing for similar technologies.
Bench-scale testing should be performed, as appropriate, to determine
the following:
o Effectiveness of the treatment alternative on the waste (note that
for some technologies bench-scale testing may not be sufficient to
make a final effectiveness determination)
Bench tests may also be conducted for we11-developed and documented tech-
nologies that are being applied to a new waste.
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OSWER Directive 9355.3-01
o Differences in performance between competing manufacturers (e.g.,
activated carbon adsorption isotherms, polymer jar tests)
o Differences in performance between alternative chemicals (e.g.,
alum versus lime versus ferric chloride versus sodium sulfide)
o Sizing requirements for pilot-scale studies (e.g., chemical feed
systems)
o Screening of technologies to be pilot tested (e.g., sludge
dewatering)
o Sizing of those treatment units that would affect the cost of the
technology sufficiently to affect the FS evaluation process
o Compatibility of materials with the waste
6.3.1.1 Preplanning Information Needs
The preplanning information needed to prepare for a bench-scale
treatability test includes preparing and identifying test procedures; a
waste sampling plan; waste characterization; treatment goals (e.g., how
clean or resistant to leaching does the waste need to be); data requirements
for estimating the cost of the technology being evaluated (e.g., sufficient
for an order of magnitude cost estimate (i.e., +50/-30 percent)); and test
services, equipment, chemical, and analytical service procurement.
6.3.2 Pilot-Scale Treatability Studies
Pilot studies are intended to simulate the physical as well as chemical
parameters of a full-scale process, and therefore the treatment unit sizes
and the volume of waste to be processed in pilot systems greatly increase
over those of bench scale. As such, pilot units are intended to bridge the
gap between bench and full-scale and are intended to more accurately simu-
late the operation of the full-scale process than would bench-scale testing.
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OSWER Directive 9355.3-01
Pilot units are designed as small as possible to minimize costs, yet
large enough to get the data required for scaling up. Pilot units are
usually sized to minimize the physical and geometric effects of test equip-
ment on treatment performance to simulate full-scale performance. Examples
of these effects include mixing, wall effects, accurate settling data, and
generation of sufficient residues (sludges, off gases, etc.) for additional
testing (dewatering, fixation, etc.). Pilot units are operated in a manner
as similar as possible to the manner of operation of the full-scale system
(i.e., if the full-scale system will be operated continuously, then the
pilot system would usually be operated continuously).
In many instances, significant time is required to make a changeover in
operating conditions of a pilot plant and get a reliable result of the
change. Therefore, time and budget constraints often limit the ability to
test a large number of operating conditions. Since pilot tests usually
require large volumes of waste that may vary in characteristics, consider-
ation should be given to performing tests on wastes that are representative
of actual site conditions and full-scale operations (e.g., it may be neces-
sary to blend or spike wastes to test all waste characteristics anticipated
at the site and/or to conduct onsite tests using mobile laboratories).
6.3.2.1 Preplanning Information Needs
In addition to the preplanning requirements for bench-scale tests,
information needed to prepare for a pilot-scale treatability test includes:
o Site information that would affect pilot-test requirements (i.e.,
waste characteristics, power availability, etc.)
o Waste requirements for testing (i.e., volumes, pretreatment, etc.)
o Data requirements for technologies to be tested
Because substantial quantities of material may be processed in a pilot
test and because of the material's hazardous characteristics, special pre-
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OSWER Directive 9355.3-01
cautions nay be required in handling transport and disposal of processed
waste. It may be necessary to obtain an agreement with a local sewer
authority or cognizant State agencies or to obtain an NPDES permit for off-
site discharge of treated effluent. Solid residuals must be disposed of
properly offsite or stored onsite to be addressed as part of the remedial
action.
6.4 BENCH VERSUS PILOT TESTING
Alternatives involving treatment or destruction technologies may
require some form of treatability testing, if their use represents
first-of-its-kind applications on unique or heterogeneous wastes.
Once a decision is made to perform treatability studies, the RI/FS
contractor and lead agency remedial project manager will have to decide on
the type of treatability testing to use. This decision must always be made
taking into account the technologies under consideration, performance goals,
and site characteristics.
The choice of bench versus pilot testing is affected by the level of
development of the technology. For a technology that is well developed and
tested, bench studies are often sufficient to evaluate performance on new
wastes. For innovative technologies, however, pilot tests may be required
since information necessary to conduct full-scale tests is either limited or
nonexistent.
Pilot studies are usually not required for well-developed technologies,
except when treating a new waste type or matrix that could affect the physi-
cal operating characteristics of a treatment unit. For example, incinera-
tion of fine sands or clay soils in a rotary kiln that has been developed
for coarser solids can result in carryover of fine sands into the secondary
combustion chamber.
During the RI/FS process, pilot-scale studies should be limited to
situations in which bench-scale testing or field sampling of physical or
chemical parameters provide insufficient information from which to evaluate
an
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OSWER Directive 9355.3-01
alternative (e.g., it is difficult to evaluate the ability of a rotary kiln
incinerator to handle a new waste matrix using a bench-scale test). Pilot-
scale tests may also be required when there is a need to investigate
secondary effects of the process, such as air emissions, or when treatment
residues (sludge, air emissions) are required to test secondary treatment
processes.
Because of the time required to design, fabricate, and install pilot-
scale equipment and to perform tests for a reasonable number of operating
conditions, conducting a pilot study can add significant time to the RI/FS
schedule and can be quite costly. The decision to perform a pilot test
should, therefore, be considered carefully and made as early in the process
as possible to minimize potential delays of the FS.
To determine the need for pilot testing, the potential for improved
performance or savings in time or money during the implementation of a tech-
nology should be balanced against the additional time and cost for pilot
testing during the RI/FS. Technologies requiring pilot testing should also
be compared to technologies that can be implemented without pilot testing.
Innovative technologies should be considered if they offer the potential for
more permanent treatment, destruction of the waste, or significant savings
in time or money required to complete a remedial action.
The final decision as to how much treatability testing (or collection
of additional data of any kind) should be undertaken must balance the value
of the additional data against increased cost, schedule delay, and level of
allowable uncertainty in the remedy-selection process. Generally, one of
the following choices must be made:
o Collect more data using treatability testing
o Provide additional safety factors in the remedial design to
accommodate some uncertainties
o Proceed with the remedy selection, accepting the uncertainty and
the potential cost and performance consequences
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OSWER Directive 9355.3-01
The final decision may also be a combination of several of these
choices. The lead agency's RPM must base the decision upon the character-
istics of the site, the cost of the studies, and the uncertainties of pro-
ceeding without them.
Table 6-2 provides a comparison between bench and pilot studies, and
Table 6-3 shows examples of bench and pilot testing programs.
6.4.1 Testing Considerations
Shipment of substantial —-lumes of contaminated material from a site
for testing can prove to be c ficult; residual material not consumed in
testing will need to be disposed of safely, and the disposal must be ade-
quately documented. Therefore, the volume of materials to be tested offsite
should be minimized to avoid related problems.
A second testing consideration is the possible difficulty of getting a
representative sample of waste for treatability testing. For example,
although ground-water samples collected from monitoring wells during site
characterization may be available for testing treatment technologies, separ-
ate extraction wells may need to be used to produce the required ground-
water flow patterns during remedial actions. Consequently, because the
characteristics of ground water from extraction wells may be different from
monitoring wells, representative waste samples may be unavailable until
extraction wells are installed and pumped. Samples sufficient for bench
testing can be collected from monitoring wells, if allowances are made for
potential differences in the composition of wastes to be derived from
extraction wells. While pilot testing may require volumes of waste greater
than can be collected from monitoring wells—unless monitoring wells are
sized sufficiently—pilot tests can be performed on water produced from
extraction wells during pump testing and before the remedial action begins.
A similar concern arises when trying to obtain representative samples for
testing the treatment of contaminated soil. Since the soil characteristics
will vary both horizontally and vertically on the site it may not be
possible to obtain a sample that fully represents full-scale conditions
without blending or spiking.
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TABLE.6-2. BENCH AND PILOT STUDY PARAMETERS
Parameter
Bench
Pilot
I
t->
•fe.
Purpose
Size
Quantity of Waste and
Materials Required
Number of Variables That
Can Be Considered
Time Requirements
Typical Cost Range
Most Frequent Location
Limiting Considerations
Define process kinetics, material
compatibility, impact of environ-
mental factors, types of doses of
chemicals, active mechanisms, etc.
Laboratory or bench top
Small to moderate amounts
Many
Days to weeks
0.5-2% of capital costs of remedial
action
Laboratory
Wall, boundary and mixing .effects;
volume effects; solids processing
difficult to simulate, transporta-
tion of sufficient waste volume
Define design and operation
criteria, materials of construc-
tion, ease of material handling
and construction, etc.
1-100% of full scale
Relatively large amounts
Few
Weeks to months
2-5% of capital costs of remedial
action
Onsite
Limited number of variables;
large waste volume required;
safety, health, and other risks;
disposal of process waste
material
WDR309/035
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OSWER Directive 9355.3-01
TABLE 6-3. EXAMPLES OF BENCH- AND PILOT-SCALE TESTING PROGRAMS
Remedial Technology
Example Testing Programs
A. Air Pollution and Gas Migration
Control
1. Capping
2. Dust Control
3. Vapor Collection and
Treatment (carbon
adsorption, air stripping,
etc.)
B. Surface Water Controls
1. Capping
2. Grading
3. Revegetation
4. Diversion and Collection
Leachate and Ground-Water
Controls
1. Containment barriers
(slurry walls, grout
curtains, etc.)
2. Ground-water pumping (well
points, suction wells,
etc.)
3. Subsurface collection
drains
4. Permeable treatment beds
(limestone, activated
carbon)
5. Capping
Direct Waste Control
1. Thermal Treatment
2. Solidification/Stabilization
3. Biological Treatment
o Activated sludge
o Facultative lagoons
o Trickling filters
4. Chemical Treatment
o Oxidation/reduction
o Precipitation
o Neutralization
o Ion exchange resins
5. Physical Treatment
o Carbon adsorption
o Flocculation
o Sedimentation
Bench: Soil density and bearing
capacity vs. moisture content
curves for proposed capping
materials
Pilot: In-place soil densities;
determination of gas withdrawal
rates to control releases
Bench: Column testing of capping
material compatibility with
wastes present
Pilot: In-place testing of
geotextiles for control of erosion
in grassed diversion ditches
Bench: Determination of basicity
and headless vs. grain size of
limestone materials for a
treatment bed; determination of
chemical compatibility of a
compacted clay with a leachate
stream
Pilot: In-place testing of a soil-
type and grain-size specification
and tile-drain configuration for a
subsurface collection drain
Bench: Characterization of
chemical and heat content of haz-
ardous waste mixes; chemical,
physical, and biological treat-
ability studies to define rate
constants, minimal-maximal loading
rates and retention times, optimal
pH and temperature, sludge genera-
tion rates and characteristics,
and oxygen transfer characteris-
tics; chemical type and dose
rates; solids flux rate vs. solids
concentration in sludge thickening
systems; air/volume ratios for
stripping towers
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OSWER Directive 9355.3-01
Table 6-3
(Continued)
Remedial Technology
o Membrane processes
o Dissolved air flotation
o Air stripping
o Wet air oxidation
In Situ Treatment
o Vapor Extraction
o Soil flushing
o Microbial degradation
o Neutralization/
detoxification
o Precipitation
o Nitrification
Land Disposal (landfill,
land application)
E. Soil and Sediment Containment
and Removal
1. Excavation
2. Dredging
3. Grading
4. Capping
5. Revegetation
Example Testing Programs
Pilot: Test burns to determine
retention time, combustion-chamber
and after-burner temperatures,
destruction and removal efficiency,
and fuel requirements for the
incineration of a waste; endurance
performance tests on membranes in
r«verse-osmosis units for ground-
water treatment; in situ microbial-
degradation testing of nutrient-
dose and aeration rates to support
in-place degradation of underground
leak; evaluation of in-place mixing
procedures for the solidification
of a sludge in a lagoon
Bench: Determination of soil-
ads orptive (cation exchange
capacity) properties and chemical
composition
Pilot: Small-scale dredging to
assess sediment resuspension or
production rates
WDR309/036
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OSWER Directive 9355.3-01
6.4.2 Data-Quality Objectives
Th« data quality required for analytical results of treatability tests
is a key concern since it greatly affects the cost and time required for the
analyses. Analytical levels and corresponding levels of quality are dis-
cussed in Chapter 2 of this guidance (Figure 2-3).
Since the results of bench and pilot studies are used to support selec-
tion of a remedial alternative, results of such studies will support the ROD
and become part of the Administrative Record. Furthermore, results of
treatability testing may also be used on other sites with similar charac-
teristics. Therefore, procedures followed in testing will need to be well
documented. Sampling and analyses for tests used to develop predictive
results will need to be performed with the same level of accuracy and care
that was used during the site characterization. Because cost and time
required for analyses increase significantly with increased quality, poten-
tial savings can be derived by carefully determining the level of data qual-
ity required for the analytical level to be used.
Table 6-4 presents the data quality usually required for the various
analyses that may be performed during treatability investigations. Bench-
and pilot-scale testing require some moderate and some high-quality data.
Sufficient high-quality data are needed to document treatment performance of
the technologies considered for further evaluation as well as those dropped
from consideration.
6.5 TREATABILITY TEST WORK PLAN
Laboratory testing can be expensive and time consuming. A well-written
work plan is a necessary document if a treatability testing program is to be
completed on time, within budget, and with accurate results. Preparation of
a work plan provides an opportunity to mentally run the test and review com-
ments prior to starting the test. It also reduces the ambiguity of communi-
cation between the lead agency's RPM, the contractor's project manager, the
technician performing the test, and the laboratory technician performing the
analyses on test samples. The work plan, which may be an amendment to the
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TABLE 6-4. DATA QUALITY FOR TREATABILITY INVESTIGATIONS
Analytical
L«vel Field Data Bench/Pilot Data
Level II/ Feasibility Testing to optimize
Level III screening operating conditions
Monitoring
Predesign sizing
Level IV/ Enforcement related Establish design
Level V evaluations and criteria establishing
recommendations standards documenting
of alternatives performance in treat-
ability studies to
screen alternatives
WDR309/037/1
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OSWER Directive 9355.3-01
original work plan, if the need for the treatability tests was not
identified until later in the process, or a separate one specifically for
this phase. Regardless, the work plan should be reviewed and approved by
the lead agency's RPN. The RPM and RI/FS contractor should determine the
appropriate level of detail for the work plan since a detailed plan is not
always needed and will require time to prepare and approve. In some
situations the original work plan may adequately describe the treatability
tests and a separate plan is not required (e.g., the need for treatability
testing can be identified during the scoping phase if existing information
is sufficient). Section 2.4 and Appendix B-2 provide additional information
on work plan preparation.
6.5.1 Bench-Scale Treatability Work Plan
Table 6-5 provides a suggested work plan format for bench-scale test-
ing; the various sections of the recommended format for the work plan are
described below.
o Project Description and Site Background—Briefly describe the site
and the types, concentrations, and distributions of contaminants
of concern (concentrating on those for which the technology is
being considered).
o Remedial Technology Description—Give a brief description of the
technology(ies) to be tested.
o Test Objectives—Describe the purpose of the test, the data that
are to be collected from the bench test, and how the data will be
used to evaluate the technology.
o Specialized Equipment and Materials—Describe unique equipment or
reagents required for the test.
o Experimental Procedures—List specific steps to be performed in
carrying out the bench test; include volumes to be tested, des-
criptions of reactors to be employed, and materials needed (i.e.,
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TABLE 6-5. SUGGESTED FORMAT FOR BENCH-SCALE WORK PLAN
1. Project Description and Site Background
2. Remediation Technology Description
3. Test Objectives
4. Specialized Equipment and Materials
5. Laboratory Test Procedures
6. Treatability Test Plan Matrix and Parameters to Measure
7. Analytical Methods
8. Data Management
9. Data Analysis and Interpretation
10. Health and Safety
11. Residuals Management
WDR309/037/2
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OSWER Directive 9355.3-01
transfer by graduated cylinder 500 ml of waste to a 600 ml boro-
silicate glass beaker). Specify the accuracy of measurements by
specifying standard laboratory glassware (i.e., a graduated
cylinder has 5 percent accuracy but a pipet is 1 percent);
describe steps sequentially; and describe how samples are to be
taken for analysis, which containers are to be used, which
preservatives, etc.
Treatability Test Plan—Include the variable conditions that are
to be tested (e.g., a combination of 4 pH units and 5 doses of a
chemical would produce 40 discrete tests [if replicated]);
include parameters to be measured if they vary for different test
conditions.
Analytical Methods—The analytical method is dependent on test
objectives, technology, waste, and other site factors. Survey
available analytical methods and select the most appropriate.
Describe analytical procedures or cite and reference standard pro-
cedures to be employed; define the level of accuracy needed for
each of the analyses; perform initial testing to roughly determine
optimal operating conditions; and use moderately accurate analy-
tical techniques or analyses of only one or a few indicator com-
pound (s) to greatly reduce the time and cost of these initial
tests. After achieving best treatment, perform more complete and
accurate testing to confirm the earlier results. Most bench tests
require results in short order to allow varied test runs. Bench
tests remote from the analyzing laboratory are difficult; there-
fore, analyze the duplicate final or check samples by the CLP, if
necessary.
Data Management—Testing procedures must be well documented, using
bound notebooks, photographs, etc.; provisions need to be made for
making backup copies of critical items of data. Describe the
parameters to be measured, accuracy that the results are to be
recorded to, and how these are to be recorded. Prepare a sample
data sheet to be used in the bench test; include procedures to be
employed to ensure that the results are protected from loss.
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o Data Analysis and Interpretation—Describe in detail the proce-
~.dure« to be followed to reduce raw analytical data to a form use-
ful for interpretation. The most helpful are methods of graphical
interpretation based on known physical or chemical phenomena, or
common practice (e.g., plotting concentrations of metal remaining
in solution versus pH or chemical dosage).
o Health and Safety—Modify the site health and safety plan as
needed to account for waste handling and onsite testing opera-
tions .
o Residual Management—Describe the types of residuals anticipated
and how they will be disposed of.
6.5.2 Pilot Scale Treatability Work Plan
Table 6-6 contains a suggested work plan format. Although many of the
sections are similar to those of the bench-scale work plan format, differ-
ences between the two are discussed below.
o Pilot Plant Installation and Startup—For onsite pilot studies,
describe the equipment required and method to be employed to get
the equipment onsite and installed for the test period.
o Pilot Plant Operation and Maintenance Procedures—Describe the
specific conditions under which the pilot test will be conducted.
Pilot plants are normally run with relatively large volumes of
waste to simulate full-scale operation and, therefore, usually
have to provide that waste characteristics are measured and oper-
ating controls are adjusted (i.e., chemical feed rates) to match
instructions for startup and shutdown of the pilot plant; this
needs to be included in the procedures list.
o Parameters to be Tested—List the operating conditions under which
the pilot units are to be tested and the variations in control
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OSWER Directive 9355.3-01
•TABLE 6-6. SUGGESTED FORMAT FOR PILOT-SCALE WORK PLAN
1. . Project Description and Site Background
2. Remedial Technology Description
3. Test Objectives
4. Pilot Plant Installation and Startup
5. Pilot Plant Operation and Maintenance Procedures
6. Parameters to be Tested
7. Sampling Plan
8. Analytical Methods
9. Data Management
10. Data Analysis and Interpretation
11. Health and Safety
12. Residuals Management
WDR309/037/3
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OSWER Directive 9355.3-01
parameters are to be evaluated (e.g., chemical feed rates or pH
•et points in a chemical precipitation test, or combustion tem-
perature or gas residence time for an incinerator test).
o Sampling Plan—Describe locations and a schedule for samples to be
taken from the pilot plant to determine performance; readings from
in-line instruments, such as pH probes and sampling methods, con-
tainers, preservative, labeling, etc., should be included.
o Health and Safety. Plan—Health and safety concerns are more criti-
cal during pilot tests because larger amounts of waste are
involved and equipment is more complex. Equipment design and con-
struction must comply with applicable code requirements.
6.6 APPLICATION OF RESULTS
6.6.1 Data Analysis and Interpretation
Following the completion of the treatability testing, results are
reduced to a useful form according to the work plan. Data are interpreted
on the technology's effectiveness, implementability, or cost, and antici-
pated results are compared with actual results. Graphical techniques are
frequently used to present the results. Note that the level of reliability
of the test results is usually based on the accuracy of the analytical
methods employed.
Major differences between the anticipated and actual results may neces-
sitate a modification of the work plan and retesting of the technology. In
addition, raw-waste and effluent characteristics as well as by-products and
emissions are evaluated to predict the ability of a full-scale unit to
respond to variations in waste composition and meet performance
requirements.
6.6.2 Use of the Results in the RI/FS Process
The purpose of the treatability evaluation is to provide information
needed for the detailed analysis of alternatives and to allow selection of a
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OSWER Directive 9355.3-01
remedial action to be made with a reasonable certainty of achieving the
response objectives. All results are useful, even negative ones, because
they can be used to eliminate technologies for further consideration. The
results of bench and pilot tests can be used to ensure that conventional and
innovative treatment or destruction technologies can be evaluated equally
with non-treatment alternatives during the detailed analysis phase of the
FS. Secondary use of treatability results provides information for the sub-
sequent detailed design of the selected remedial technology. Operating con-
ditions must be carefully and completely documented so that this useful
information can be used in the full-scale system.
The characteristics of residuals from the remedial technology should be
determined during pilot testing. This information is useful in determining
how the residuals can be handled or disposed and in predicting the effects
of their disposal or emission. Information can often be collected to deter-
mine if the residuals should be considered hazardous wastes or disposed of
as a non-hazardous waste.
6.6.3 Scaling up to Full-Scale Testing
The study findings need to be evaluated for application of the technol-
ogy at full-scale; the limitations of the bench or pilot scale of the test
(size, wall, and boundary effects, etc.) need to be compensated for. Scale-
up can be done on the basis of either previous experience with the treatment
equipment with other wastes or established rules of similitude (used to
relate physical laws to variations in scale) and mathematical models. This
evaluation should include a sensitivity analysis to identify the key
parameters and unknowns that can affect a full-scale system. In the case of
innovative technologies, full-scale systems may not be in wide use. The
potential need for process modifications during design or operation must be
considered.
6.7 COMMUNITY RELATIONS DURING TREATABILITY INVESTIGATIONS
Treatability testing is potentially controversial within a community
and, therefore, additional community relations activities may be required.
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OSWER Directive 9355.3-01
An assessment of issues and concerns the community may have about planned
treatability testing should be conducted. The assessment should augment the
previously prepared community relations plan (if treatability testing were
not part of the original work plan) and should include a discussion of any
issues unique to the proposed testing such as onsite pilot testing, trans-
porting contaminated materials offsite, schedule changes resulting from
conducting bench or pilot tests, disposal of residuals, uncertainties
pertaining to innovative technologies, and the degree of development of the
technology being tested.
Additional community relations implementation activities may be recom-
mended in the assessment and may include a public meeting to explain the
proposed bench or pilot test, a fact sheet describing the technology and
proposed test, a briefing to public officials about the treatability
studies, and small group consultations with members of the community con-
cerned about EPA's actions at the site. Other community relations activi-
ties may be needed, and consultations between the lead agency's project
manager and the community relations coordinator should be used to establish
the appropriate community relations activities.
6.8 REPORTING AND COMMUNICATION DURING TREATABILITY INVESTIGATIONS
Deliverables for the treatability investigations are listed in
Table 6-7 and include the following:
o Revised work plans, as necessary, including bench and/or pilot
tests
o Revised QAPP/FSP, as necessary
o Test results and evaluation report
The treatability test evaluation report should describe the testing
that was performed, the results of the tests, and an interpretation of how
the results would affect the evaluation of the remedial alternatives being
considered for the site. Effectiveness of the treatment technology for the
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OSWER Directive 9355.3-01
TABLE 6-7. REPORTING AND COMMUNICATION DURING TREATABILITY INVESTIGATIONS
Potential Method
for Information
Information Needed Purpose Provision
Need for Treatability For lead agency and contrac- Meeting
Testing tor to determine whether Tech Memo
more cost and performance
data are needed to evaluate
alternatives and select
remedy; for lead agency to
obtain support agency review
and comment
Approval of Site Obtain lead agency approval QAPP (revised)
Data Collection or of treatability activities FSP
Treatability Testing Treatability
Study Work Plan
WDR309/034
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OSWER Directive 9355.3-01
wastes on the site should be presented. This report should also contain an
evaluation of how the test results would affect treatment costs developed
during the detailed analysis of alternatives (e.g., chemical requirements or
settling rates required for effective treatment). The report may often be
used by other EPA and contractor staff to provide information for use on
sites with similar characteristics.
WDR309/034
6-28
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CHAPTER 7
DETAILED ANALYSIS
OF ALTERNATIVES
FROM:
• PnHkrinan/
AttMsmant
• Sitt kupMlon
• NPLLMIng
w
1
^ SITE 1
SCOPING OF THE RI/FS
SI.
Planning
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^ CHARACTERIZATION |
A A -
i i
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1 1
1 1
f *
w
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INVESTIGATIONS
{
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OP ALTERNATIVES | ALTEHNAJMEB
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DETAILED ANALYSIS
OF ALTERNATIVES
• Further Define Alternatives as
Necessary
• Analyze Alternatives Using the
Nine Criteria
• Compare Alternatives Against
Each Other
™ N
• Remetfy SetecSoet
• Record at Decision
• Remedial Design
• Remedial Action
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OSWER Directive 9355.3-01
CHAPTER 7
DETAILED ANALYSIS OF ALTERNATIVES
7.1 INTRODUCTION
7.1.1 Purpose of the Detailed Analysis of Alternatives
The detailed analysis of alternatives is the analyses and
presentation of the relevant information needed to allow decisionmakers
to select a site remedy, not the decisionmaking process itself. During
the detailed analysis, each alternative is assessed against the nine
evaluation criteria described in this chapter. The results of this
assessment are arrayed such that comparisons can be made among alter-
natives and the key tradeoffs among alternatives can be identified.
This approach to analyzing alternatives is designed to provide
decisionmakers with sufficient information to adequately compare the
alternatives, select an appropriate remedy for a site, and demonstrate
satisfaction of the statutory requirements in the ROD.
The specific CERCLA requirements that must be addressed in the ROD
and supported by the FS report are listed below:
o Be protective of human health and the environment
o Attain ARARs (or provide grounds for invoking a waiver)
o Be cost-effective
o Use permanent solutions and alternative treatment technologies
or resource recovery technologies to the maximum extent
practicable
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OSWER Directive 9355.3-01
o Satisfy the preference for treatment that reduces toxicity,
mobility, or volume as a principal element (or provide an
explanation in the ROD as to why it does not)
In addition, CERCLA places an emphasis on evaluating long-term
effectiveness and related considerations for each of the alternative
remedial actions. These statutory considerations include:
A) the long-term uncertainties associated with land disposal;
B) the goals, objectives, and requirements of the Solid Waste
Disposal Act;
C) the persistence, toxicity, and mobility of hazardous
substances and their constituents, and their propensity to
bioaccumulate;
D). short- and long-term potential for adverse health effects from
human exposure;
E) long-term maintenance costs;
F) the potential for future remedial action costs if the
alternative remedial action in question were to fail; and
G) the potential threat to human health and the environment
associated with excavation, transportation, and redisposal, or
containment.
Nine evaluation criteria have been developed to address the CERCLA
requirements and considerations listed above as well as additional tech-
nical and policy considerations that have proven to be important for
selecting among remedial alternatives. These evaluation criteria serve
as the basis for conducting the detailed analyses during the FS and for
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OSWER Directive 9355.3-01
subsequently selecting an appropriate remedial action. The evaluation
criteria and associated statutory considerations are:
o Short-term effectiveness (D,G)
o Long-term effectiveness and permanence (A,C,D)
o Reduction of toxicity, mobility/ or volume (C)
o Implementability
o Cost (E,F)
o Compliance with ARARs (B)
o Overall protection of human health and the environment
o State acceptance
o Community acceptance
7.1.2 The Context of Detailed Analysis
The detailed analysis of alternatives follows the development and
screening of alternatives and precedes the actual selection of a remedy.
As discussed in Chapters 4 and 5, these phases may overlap, with one
beginning before another is completed, or they may vary in the level of
detail based on the complexity or scope of the problem. The extent to
which alternatives are analyzed during the detailed analysis is
influenced by the available data, the number and types of alternatives
being analyzed, and the degree to which alternatives were previously
analyzed during their development and screening.
The evaluations conducted during the detailed analysis phase build
on previous evaluations conducted during the development and screening
of alternatives. This phase also incorporates any treatability study
data and additional site characterization information that may have been
collected during the RI.
The results of the detailed analysis provide the basis for
identifying a preferred alternative and preparing the proposed plan.
Upon completion of the detailed analysis, the FS report, along with the
proposed plan, is submitted for public review and comment. The results
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OSWER Directive 9355.3-01
of the detailed analysis serve to document the evaluations of
alternatives and provide the basis for selecting a remedy.
7.1.3 Overview of the Detailed Analysis
A detailed analysis of alternatives consists of the following
components:
o Further definition of each alternative, if appropriate, with
respect to the volumes or areas of contaminated media to be
addressed, the technologies to be used, and any performance
requirements associated with those technologies
o An assessment and a summary of each alternative against the
nine evaluation criteria
o A comparative analysis among the alternatives to assess the
relative performance of each alternative with respect to each
evaluation criterion
Figure 7-1 illustrates the steps in the detailed analysis process.
7.2 DETAILED ANALYSIS OF ALTERNATIVES
7.2.1 Alternative Definition
The alternatives that remain after screening may need to be refined
more completely prior to the detailed analysis. Alternatives have
already been defined during the development and screening phases (see
Section 5.2.1) to match contaminated media with appropriate process
options; this matching is done by identifying specific remedial response
••6
objectives (e.g., a risk-based cleanup target such as 1x10 ) and sizing
process options to attain the objective (e.g., 10 groundwater extraction
wells extracting 50 gpm each, activated carbon treatment for 500 gpm).
During the detailed analysis, each alternative should be reviewed to
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FIGURE 7-1 OSWER Directive 9355.3-01
DETAILED ANALYSIS OF ALTERNATIVES
Development/
Screening of
Alternatives
Results of
Treatabilrty
Investigations
If Conducted
Further Definition
of Alternatives as
Necessary
I
Individual Analysis
of Alternatives
Against Evaluation
Criteria
Comparative Analysis of
Alternatives Against
Evaluation Criteria
I
Issuance of
Feasibility Study Report
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OSWER Directive 9355.3-01
determine if additional definition is required to apply the evaluation
criteria consistently and to develop order-of-magnitude cost estimates
(i.e., having a desired accuracy of +50 percent to -30 percent). The
following illustrate situations in which additional alternative
definition is appropriate:
o The assumed sizing of the process option must be revised on
the basis of results of treatability data (e.g., a taller air
stripping tower with more packing is required to attain the
treatment target).
o A different process option should be used to represent the
technology type on the basis of the results of treatability
data (e.g., activated carbon rather than air stripping is
required).
o The volume of contaminated media has been refined on the basis
of additional site characterization data.
The information developed to define alternatives at this stage in
the RI/FS process may consist of preliminary design calculations,
process flow diagrams, sizing of key process components, preliminary
site layouts, and a discussion of limitations, assumptions, and
uncertainties concerning each alternative.
As described in Chapter 4, alternatives can be developed and
screened on a medium-specific or sitewide basis at the lead agency's
discretion. However, during the detailed analysis, the alternatives
must be configured to present the decisionmaker with a range of options
addressing the entire site or operable unit being addressed by the FS.
If separate alternatives have been developed for different areas or
media of the site, they should be combined to present a comprehensive
remedy that addresses all the potential threats posed by the site or
that area being addressed by the operable unit. This can be
accomplished either at the beginning of the detailed analysis or
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OSWER Directive 9355.3-01
following .the analysis when the alternatives are summarized and a
comparative analysis is performed.
7.2.2 Overview of Evaluation Criteria
The detailed analysis provides the means by which facts are
assembled and evaluated to develop the rationale for a remedy selection.
Therefore, it is necessary to understand the requirements of the remedy
selection process to ensure that the FS analysis provides the sufficient
quantity and quality of information to simplify the transition between
the FS report and the actual selection of a remedy. The analysis pro-
cess described here has been developed on the basis of statutory
requirements of CERCLA Section 121, (see Section 7.1.1); earlier program
initiatives promulgated in the November 20, 1985, NCP; the existing
"Guidance on Remedial Investigations and Feasibility Studies Under
CERCLA," dated May 1985; and site-specific experience gained in the
Superfund program. The nine evaluation criteria listed in Section 7.1.1
encompass technical, cost, and institutional considerations; compliance
with specific statutory requirements; and state and community
acceptance.
The five criteria listed below are grouped together because they
represent the primary criteria upon which the analysis is based taking
into account technical, cost, institutional, and risk concerns.
o Short-term Effectiveness (described in Section 7.2.3.1)—The
assessment against this criterion examines the effectiveness
of alternatives in protecting human health and the environment
during the construction and implementation period until
response objectives have been met.
o Long-term Effectiveness and Permanence (described in
Section 7.2.3.2)—The assessment of alternatives against this
criterion evaluates the long-term effectiveness of
alternatives in protecting human health and the environment
after response objectives have been met.
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OSWER Directive 9355.3-01
o Reduction of Toxicity, Mobility, and Volume (described in
Section 7.2.3.3)—The assessment against this criterion
evaluates the anticipated performance of the specific
treatment technologies.
o Implementability (described in Section 7.2.3.4)—This
assessment evaluates the technical and administrative
feasibility of alternatives and the availability of required
resources.
o Cost (described in Section 7.2.3.5)—This assessment evaluates
the capital and O&M costs of each alternative.
The level of detail required to analyze each alternative against these
evaluation criteria will depend on the type and complexity of the site,
the type of technologies and alternatives being considered, and other
project-specific considerations. The analysis should be conducted in
sufficient detail such that decisionmakers understand the significant
aspects of each alternative and any uncertainties associated with their
evaluation (e.g., a cost estimate may have been developed on the basis
of a volume of media that could not be precisely defined).
Assessments against two of the criteria relate directly to
statutory findings that must ultimately be made in the ROD: compliance
with ARARs and overall protection of human health and the environment.
These two criteria are briefly described below. Although these
assessments draw on information developed under the previous five cri-
teria, they are conducted independently. Generally, these are threshold
criteria, in other words, the evaluation of them involves describing
whether, and how, each alternative does or does not meet the two
criteria.
The actual determination and declaration that these findings have been
made is contained in the ROD.
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OSWER Directive 9355.3-01
o -Compliance with ARARs (described in Section 7.2.3.6)—The
assessment against this criterion describes how the alterna-
tive complies with ARARs, or if a waiver is required and how
it is justified. The assessment includes information from
advisories/ criteria/ and guidance that the lead and support
agencies have agreed is necessary and appropriate.
o Overall Protection (described in Section 7.2.3.7)—The assess-
ment against this criterion describes how the alternative, as
a whole, protects and maintains protection of human health and
the environment.
The final two criteria, state acceptance and community acceptance,
should be evaluated to the extent possible on the basis of the
information available at the time of the detailed analysis. Because
available information on these two criteria will usually be limited or
not known at this stage of the RI/FS (i.e., before the public comment
period on the proposed plan and the RI/FS), they typically will not be
evaluated thoroughly until a final decision is being made and the ROD is
being prepared. The criteria are as follows:
o State Acceptance (described in Section 7.2.3.8)—This
assessment reflects the state's (or supporting agency's)
apparent preferences or concerns about alternatives.
o Community Acceptance (described in Section 7.2.3.9)—This
assessment reflects the community's apparent preferences or
concerns about alternatives.
Each of the nine evaluation criteria has been further divided into
specific factors to allow a thorough analysis of the alternatives.
These factors are shown in Table 7-1 and discussed in the following
sections.
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TABLE 7-1 OSWER Directive 9355.3-01
CRITERIA FOR DETAILED ANALYSIS OF ALTERNATIVES
SHORT-TERM
EFFECTIVENESS
• Production of Communfey
During Remedial Actions
• Protection of Workers
During Remedial Actions
• Envi
wmal Impacts
• Time UWI Remedial
Action Objectives At*
Achieved
IOC-TERM
EFFECTIVENESS
• Magnitude of
RnidualRisk
• Adequacy of
Controls
• Reliability of
Controls
REDUCTION OF TOXCfTY,
MOeiUTY.ANOVaUME
• Treamm Process Used and
Materials Treated
• Amount of Hazardous
Materials Destroyed or
Treated
• Degree of Expected
Reductions in Toxiaty.
Mobility, and Volume
• Degree to Which
Treatment Is Irreversible
• Type and Quantify of
Residuals Remaining After
Treatment
IMPLEMENTABILfTY
• Ability to Construct and
Operate the Technology
• Reliability of the
Technology
» Ease of Undertaking
Additional Remedial
Actions, if Necessary
• Ability to Monitor Effective-
ness of Remedy
• Ability to Obtain
Approvals From Othei
Agencies
• Coordination With Other
Agendas
• Availability of Offsite
Treatment, Storage, and
Disposal Services and
Capacity
• Availability of Necessary
Equipment and
Specialists
• Timing of New Technology
Under Consideration
• Capital
Costs
• Operating and
Maintenance Costs
• Present Worth
Cost
PROTECTION OF HUMAN HEALTH
AND THE ENVIRONMENT
How Alternative Provides Human
Health and Environmental Protection
COMPLIANCE WITH ARARs
• Compliance With Contaminant-Specific
ARARs
• Compliance With Acton-Specific ARARs
• Compliance With Location-Specific ARARs
• Compliance With Other Criteria, Advisories,
and Guidances
STATE1
ACCEPTANCE
COMMUNITY'
ACCEPTANCE
Onty very preliminary assessments of these criteria wifl be included in the RVFS. They will be fully assessed in the proposed plan and the ROD.
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OSWER Directive 9355.3-01
7.2.3' Individual Analysis of Alternatives
7.2.3.1 Short-term Effectiveness
This evaluation criterion addresses the effects of the alternative
during the construction and implementation phase until remedial response
objectives are met (e.g., a health-based cleanup target has been met).
Under this criterion, alternatives should be evaluated with respect to
their effects on human health and the environment during implementation
of the remedial action. The following factors of this analysis
criterion should be addressed for each alternative:
o Protection of the community during remedial actions—This
aspect of short-term effectiveness addresses any risk that
results from implementation of the proposed remedial action,
such as dust from excavation or air-quality impacts from a
stripping tower operation that may affect human health.
o Protection of workers during remedial actions—This factor
assesses threats that may be posed to workers and the
effectiveness and reliability of protective measures that
could be taken.
o Environmental impacts—This factor addresses the potential
adverse environmental impacts that may result from the
implementation of an alternative and evaluates how effective
available mitigation measures would be in preventing or
reducing the impacts.
o Time until remedial response objectives are achieved—This
factor includes an estimate of the time required to achieve
protection for either the entire site or individual elements
associated with specific site areas or threats.
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OSWER Directive 9355.3-01
Table 7-2 lists appropriate questions to be addressed during the
analysis of short-term effectiveness.
7.2.3.2 Long-term Effectiveness and Permanence
The evaluation of alternatives using this criterion addresses the
results of a remedial action in terms of the risk remaining at the site
after response objectives have been met. The primary focus of this
evaluation is the extent and effectiveness of the controls that may be
required to manage the risk posed by treatment residuals and/or
untreated wastes. The following components of the criterion should be
addressed for each alternative:
o Magnitude of remaining risk—This factor assesses the residual
risk remaining from untreated waste or treatment residuals at
the conclusion of remedial activities, (e.g., after source/
soil containment and/or treatment are complete, or after
ground-water plume management activities are concluded). The
potential for this risk may be measured by numerical standards
such as cancer risk levels or the volume or concentration of
contaminants in waste, media, or treatment residuals remaining
on the site. The characteristics of the residuals should be
considered to the degree that they remain hazardous, taking
into account their toxicity, mobility, and propensity to
bioaccumulate.
o Adequacy of controls—This factor assesses the adequacy and
suitability of controls, if any, that are used to manage
treatment residuals or untreated wastes that remain at the
site. It may include an assessment of containment systems and
institutional controls to determine if they are sufficient to
ensure that any exposure to human and environmental receptors
is within protective levels.
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OSWER Directive 9355.3-01
Table 7-2 ,
SHORT-TERM EFFECTIVENESS
Analysis Factor
Basis for Evaluation
During Detailed Analysis
Protection of community
during remedial actions
Protection of workers
during remedial actions
Environmental impacts
Time until remedial
response objectives
are achieved
What are the risks to the community
that must be addressed?
How will the risks to the community be
addressed and mitigated?
What risks remain to the community
that cannot be readily controlled?
What are the risks to the workers
that must be addressed?
What risks remain to the workers that
cannot be readily controlled?
How will the risks to the workers be
addressed and mitigated?
What environmental impacts are
expected with the construction and
implementation of the alternative?
What are the available mitigative
measures and their reliability to
minimize potential impacts?
What are the impacts that cannot be
avoided should the alternative be
implemented?
How long until protection against the
threats being addressed by the specific
action is achieved?
How long until any remaining site
threats will be addressed
How long until remedial response
objectives are achieved?
WDR290/058/3
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OSWER Directive 9355.3-01
o Reliability of controls—This factor addresses the long-term
reliability of management controls for providing continued
protection from residuals. It includes the assessment of the
potential need to replace technical components of the alterna-
tive, such as a cap, a slurry wall, or a treatment system; the
potential exposure pathway; and the risks posed should the
remedial action need replacement.
Table 7-3 lists appropriate questions to be addressed during the
analysis of long-term effectiveness.
7.2.3.3 Reduction of Toxicity, Mobility, and Volume
This evaluation criterion addresses the statutory preference for
selecting remedial actions that employ treatment technologies that
permanently and significantly reduce toxicity, mobility, or volume of
the hazardous substances as their principal element. This preference is
satisfied when treatment is used to reduce the principal threats at a
site through destruction of toxic contaminants, reduction of the total
mass of toxic contaminants, irreversible reduction in contaminant
mobility, or reduction of total volume of contaminated media.
This evaluation would focus on the following specific factors for a
particular remedial alternative:
o The treatment processes, the remedies they will employ, and
the materials they will treat
o The amount of hazardous materials that will be destroyed or
treated, including how principal threat(s) will be addressed
o The degree of expected reduction in toxicity, mobility, or
volume measured as a percentage of reduction (or order of
magnitude)
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OSWER Directive 9355.3-01
Table 7-3
LONG-TERM EFFECTIVENESS AND PERMANENCE
Analysis Factor
Magnitude of residual risks o
Adequacy of controls
Reliability of controls
Basis for Evaluation
During Detailed Analysis
What is the magnitude of the remaining
risks?
What remaining sources of risk can be
identified? How much is due to treat-
ment residuals/ and how much is due to
untreated residual contamination.
What is the likelihood that the tech-
nologies will meet required process
efficiencies or performance specifi-
cations?
What type and degree of long-term
management is required?
What are the requirements for long-
term monitoring?
What operation and maintenance
functions must be performed?
What difficulties and uncertainties
may be associated with long-term
operation and maintenance?
What is the potential need for replace-
ment of technical components?
What is the magnitude of the threats
or risks should the remedial action
need replacement?
What is the degree of confidence that
controls can adequately handle poten-
tial problems?
What are the uncertainties associated
with land disposal of residuals and
untreated wastes?
WDR290/058/4
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OSWER Directive 9355.3-01
o The degree to which the treatment will be irreversible
o The type and quantity of treatment residuals that will remain
following treatment
In evaluating this criterion, an assessment should be made as to
whether treatment is used to reduce principal threats, including the
extent to which toxicity, mobility, or volume are reduced either alone
or in combination. Table 7-4 lists typical questions to be addressed
during the analysis of toxicity, mobility, or volume reduction.
7.2.3.4 Implementability
The implementability criterion addresses the technical and adminis-
trative feasibility of implementing an alternative and the availability
of various services and materials required during its implementation.
This criterion involves analysis of the following factors:
o Technical feasibility
Construction and operation—This relates to the technical
difficulties and unknowns associated with a technology.
This was initially identified for specific technologies
during the development and screening of alternatives and
is addressed again in the detailed analysis for the
alternative as a whole.
Reliability of technology—This focuses on the ability of
a technology to meet specified process efficiencies or
performance goals. The likelihood that technical
problems will lead to schedule delays should be
considered as well.
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OSWER Directive 9355.3-01
Table 7-4
REDUCTION OF TOXICITY, MOBILITY, OR VOLUME
Analysis Factor
Treatment process and
remedy
Amount of hazardous
material destroyed or
treated
Reduction in toxicity,
mobility, or volume
Basis for Evaluation
During Detailed Analysis
o Does the treatment process employed
address the principal threats?
o Are there any special requirements for
the treatment process?
o What portion (mass, volume) of
contaminated material is destroyed?
o What portion (mass, volume) of
contaminated material is treated?
o To what extent is the total mass of
toxic contaminants reduced?
o To what extent is the mobility of toxic
contaminants reduced?
o To what extent is the volume of toxic
contaminants reduced?
Irreversibility of the
treatment
Type and quantity of
treatment residual
o To what extent are the effects of
treatment irreversible?
o What residuals remain?
o What are their quantity and
characteristics?
o What risks do treatment residuals pose?
WDR290/058/5
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OSWER Directive 9355.3-01
Ease of undertaking additional remedial action—This
includes a discussion of what, if any, future remedial
actions may need to be undertaken and how difficult it
would be to implement such additional actions. This is
particularly applicable for an FS addressing an interim
action at a site where additional operable units may be
analyzed at a later time.
Monitoring considerations—This addresses the ability to
monitor the effectiveness of the remedy and includes an
evaluation of the risks of exposure should monitoring be
insufficient to detect a system failure.
o Administrative feasibility
Activities needed to coordinate with other offices and
agencies (e.g., obtaining permits for offsite activities
or rights-of-way for construction)
o Availability of services and materials
Availability of adequate offsite treatment, storage
capacity, and disposal services
Availability of necessary equipment and specialists and
provisions to ensure any necessary additional resources
Timing of the availability of technologies under
consideration
Availability of services and materials, plus the
potential for obtaining competitive bids, which may be
particularly important for innovative technologies.
Table 7-5 lists typical questions to be addressed during the
analysis of implementability.
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Table 7-5
IMPLEMENTAB1LITY
Analysis Factor
Technical Feasibility
Ability to construct
technology
Reliability of technology
Basis for Evaluation
During Detailed Analysis
Ease of undertaking
additional remedial action,
if necessary
Monitoring considerations
Administrative Feasibility
Coordination with other
agencies
What difficulties may be associated
with construction?
What uncertainties are related to
construction?
How reliably does the technology meet
specified process efficiencies or
performance goals?
What is the likelihood that technical
problems will lead to schedule delays?
What likely future remedial actions
may be anticipated?
How difficult would it be to implement
the additional remedial actions, if
required?
Do migration or exposure pathways
exist that cannot be monitored
adequately?
What risks of exposure exist should
monitoring be insufficient to
detect failure?
What steps are required to coordinate
with other agencies?
What steps are required to set up
long-term or future coordination
among agencies?
Can permits for offsite activities be
obtained if required?
WDR290/058/6
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OSWER Directive 9355.3-01
Table 7-5
(continued)
Analysis Factor
Basis for Evaluation
During Detailed Analysis
Availability of Services
and Materials
Availability of treatment,
storage capacity, and
disposal services
Availability of necessary
equipment and specialists
Availability of prospective
technologies
Are adequate treatment, storage
capacity, and disposal services
available?
How much additional capacity is
necessary?
Does the lack of capacity prevent
implementation?
What additional provisions are
required to ensure the needed
additional capacity?
Are the necessary equipment and
specialists available?
What additional equipment and
specialists are required?
Do the lack of equipment and
specialists prevent implementation?
What additional provisions are
required to ensure the needed
equipment and specialists?
Are technologies under consideration
generally available and sufficiently
demonstrated for the specific
application?
Will technologies require further
development before they can be applied
full-scale to the type of waste at the
site?
When should the technology be available
for full-scale use?
Will more than one vendor be available
to provide a competitive bid?
WDR290/058/7
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-7.2.3.5 Cost
A comprehensive discussion of costing procedures for CERCLA sites
is contained in the Remedial Action Costing Procedures Manual (USEPA,
1985). The application of cost estimates to alternatives evaluation is
discussed in the following paragraphs.
Capital Costs. Capital costs consist of direct (construction) and
indirect (nonconstruction and overhead) costs. Direct costs include
expenditures for the equipment, labor, and materials necessary to
install remedial actions. Indirect costs include expenditures for
engineering, financial, and other services that are not part of actual
installation activities but are required to complete the installation of
remedial alternatives. (Sales taxes normally do not apply to Superfund
actions.) Costs that must be incurred in the future as part of the
remedial action alternative should be identified and noted for the year
in which they will occur. The distribution of costs over time will be a
critical factor in making tradeoffs between capital-intensive
technologies (including alternative treatment and destruction
technologies) and less capital-intensive technologies (such as pump and
treatment systems).
Direct capital costs may include the following:
o Construction costs—Costs of materials, labor (including
fringe benefits and worker's compensation), and equipment
required to install a remedial action
o Equipment costs—Costs of remedial action and service
equipment necessary to enact the remedy; (these materials
remain until the site remedy is complete)
o Land and site-development costs—Expenses associated with the
purchase of land and the site preparation costs of existing
property
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o Buildings and services costs—Costs of process and nonprocess
buildings, utility connections, purchased services, and
disposal costs
o Relocation expenses—Costs of temporary or permanent
accommodations for affected nearby residents. (Since cost
estimates for relocations can be complicated, FEMA authorities
and EPA Headquarters should be consulted in estimating these
costs.)
o Disposal costs—Costs of transporting and disposing of waste
material such as drums and contaminated soils
Indirect capital costs may include:
o Engineering expenses—Costs of administration, design,
construction supervision, drafting, and treatability testing
o Legal fees and license or permit costs—Administrative and
technical costs necessary to obtain licenses and permits for
installation and operation
o Startup and shakedown costs—Costs incurred during remedial
action startup
o Contingency allowances—Funds to cover costs resulting from
unforeseen circumstances, such as adverse weather conditions,
strikes, and inadequate site characterization
Annual Costs. Annual costs are post-construction costs necessary
to ensure the continued effectiveness of a remedial action. Although
some annual costs are borne by the lead agency and others by the support
agency, this distinction should not be called out in the FS. The
following annual cost components should be considered:
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OSWER Directive 9355.3-01
^Operating labor costs—Wages, salaries, training, overhead,
and fringe benefits associated with the labor needed for
post-construction operations
Maintenance materials and labor costs—Costs for labor, parts,
and other resources required for routine maintenance of
facilities and equipment
Auxiliary materials and energy—Costs of such items as
chemicals and electricity for treatment plant operations,
water and sewer services, and fuel
Disposal of residues—Costs to treat or dispose of residuals
such as sludges from treatment processes or spent activated
carbon
Purchased services—Sampling costs, laboratory fees, and
professional fees for which the need can be predicted
Administrative costs—Costs associated with the administration
of remedial action O&M not included under other categories
Insurance, taxes, and licensing costs—Costs of such items as
liability and sudden accidental insurance; real estate taxes
on purchased land or rights-of-way; licensing fees for certain
technologies; and permit renewal and reporting costs
Maintenance reserve and contingency funds—Annual payments
into escrow funds to cover costs of anticipated replacement or
rebuilding of equipment and any large unanticipated O&M costs
Rehabilitation costs—Cost for maintaining equipment or
structures that wear out over time
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OSWER Directive 9355.3-01
o Costs of periodic site reviews—Costs for site reviews that
are conducted at least every 5 years if wastes above
health-based levels remain at the site
The costs of potential future remedial actions should be addressed,
and if appropriate, should be included when there is a reasonable
expectation that a major component of the alternative will fail and
require replacement to prevent significant exposure to contaminants.
Analysis, described under Section 7.2.3.2, "Long-term Effectiveness and
Permanence," should be used to determine which alternatives may result
in future costs. It is not expected that a detailed statistical
analysis will be required to identify probable future costs. Rather,
qualitative engineering 'judgment should be used and the rationale should
be well documented in the FS report.
Accuracy of Cost Estimates. Site characterization and treatability
investigation information should permit the user to refine cost
estimates for remedial action alternatives. It is important to consider
the accuracy of costs developed for alternatives in the FS. Typically,
these "study estimate" costs made during the FS are expected to provide
an accuracy of +50 percent to -30 percent and are prepared using data
available from the RI. Costs developed with expected accuracies other
than +50 percent to -30 percent should be identified as such in the FS.
Present Worth Analysis. A present worth analysis is used to
evaluate expenditures that occur over different time periods by
discounting all future costs to a common base year, usually the current
year. This allows the cost of remedial action alternatives to be
compared on the basis of a single figure representing the amount of
money that, if invested in the base year and disbursed as needed, would
be sufficient to cover all costs associated with the remedial action
over its planned life.
In conducting the present worth analysis, assumptions must be made
regarding the discount rate and the period of performance. A discount
7-24
-------
OSWER Directive 9355.3-01
rate of 5"percent before taxes and after inflation should be assumed.
Estimates oŁ costs in each of the planning years are made in constant
dollars, representing the general purchasing power at the time of
construction. In general, the period of performance should not exceed
30 years for the purpose of the detailed analysis.
Cost Sensitivity Analysis. After the present worth of each
remedial action alternative is calculated, individual costs may be
evaluated through a sensitivity analysis if there is sufficient
uncertainty concerning specific assumptions. A sensitivity analysis
assesses the effect that variations in specific assumptions associated
with the design, implementation, operation, discount rate, and effective
life of an alternative can have on the estimated cost of the
alternative. These assumptions depend on the accuracy of the data
developed during the site characterization and treatability
investigation and on predictions of the future behavior of the
technology. Therefore, these assumptions are subject to varying degrees
of uncertainty from site to site. The potential effect on the cost of
an alternative because of these uncertainties can be observed by varying
the assumptions and noting the effects on estimated costs. Sensitivity
analyses can also be used to optimize the design of a remedial action
alternative, particularly when design parameters are interdependent
(e.g., treatment plant capacity for contaminated ground water and the
length of the period of performance).
Use of sensitivity analyses should be considered for the factors
that can significantly change overall costs of an alternative with only
small changes in their values, especially if the factors have a high
degree of uncertainty associated with them. Other factors chosen for
analysis may include those factors for which the expected (or estimated)
value is highly uncertain. The results of such an analysis can be used
to identify worst-case scenarios and to revise estimates of contingency
or reserve funds.
7-25
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OSWER Directive 9355.3-01
The following factors are potential candidates for consideration in
conducting a sensitivity analysis:
V?1
o The effective life of a remedial action
o The O&M costs
o The duration of cleanup
o The volume of contaminated material, given the uncertainty
about site conditions
o Other design parameters (e.g., the size of the treatment
system)
o The discount rate (5 percent should be used to compare
alternative costs, however, a range of 3 to 10 percent can be
used to investigate uncertainties)
The results of a sensitivity analysis should be discussed during
the comparison of alternatives. Areas of uncertainty that may have a
significant effect on the cost of an alternative should be highlighted,
and a rationale should be presented for selection of the most probable
value of the parameter.
7.2.3.6 Compliance with ARARs
This evaluation criterion is used to determine how each alternative
complies with applicable or relevant and appropriate Federal and State
requirements, as defined in CERCLA Section 121. There are three general
categories of ARARs: chemical-, location-, and action-specific. ARARs
for each category have been identified in previous stages of the RI/FS
process (e.g., chemical-specific ARARs should be preliminarily identi-
fied during scoping of the project). The detailed analysis should sum-
marize which requirements are applicable or relevant and appropriate to
7-26
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OSWER Directive 9355.3-01
an alternative and describe how the alternative meets these require-
ments. NtiM) an ARAB is not not, the basis for justifying one of the six
•-?$'
waivers allowed under CERCLA (see Section 1.2.1.1) should be discussed.
Other information in the form of advisories, criteria, and guidance
that are not ARARs may be available, but because they may be necessary
to ensure protectiveness and are appropriate for use in a specific
alternative they should still be considered in the analysis. These
to-be-considered (TBC) criteria should be included in the detailed
analysis if the lead and support agencies agree that their inclusion is
necessary and appropriate.
The following should be addressed for each alternative during the
detailed analysis of ARARs:
o Compliance with chemical-specific ARARs (e.g., MCLs)—This
factor addresses whether the ARARs can be met, and if not,
whether a waiver may be appropriate.
o Compliance with action-specific ARARs (e.g., RCRA minimum
technology standards)—It must be determined whether ARARs can
be met or waived.
o Compliance with location-specific ARARs (e.g., preservation of
historic sites)—As with other ARAR-related factors, this
involves a consideration of whether the ARARs can be met or
whether a waiver is appropriate.
*
o Compliance with appropriate criteria, advisories, and guid-
ances—This involves a consideration of how well the alter-
native meets Federal and State guidelines that are not ARARs
(e.g., not promulgated) but have been identified by lead and
This effort will require the direct involvement of the lead agency as
well as input from the support agency.
7-27
-------
OSWER Directive 9355.3-01
support agencies as TBCs because they have been determined to
bo necessary to ensure protection of human health and the
•K^itfonment and are appropriate for the circumstances of the
•ite.
The actual determination of which requirements are applicable or
relevant and appropriate is made by the lead agency in consultation with
the support agency. A summary of these ARARs and whether they will be
attained by a specific alternative should be presented in an appendix to
the RI/FS report. A suggested format for this summary is provided in
Appendix D of this guidance. More detailed guidance on determining
whether requirements are applicable or relevant and appropriate is
provided in the "CERCLA Compliance With Other Laws Manual" (U.S. EPA,
Draft, November 1987).
7.2.3.7 Overall Protection of Human Health and the
Environment
This evaluation criterion provides a final check to assess whether
each alternative meets the requirement that it is protective of human
health and the environment. The overall assessment of protection is
based on a composite of factors assessed under other evaluation cri-
teria, especially long-term effectiveness and permanence, short-term
effectiveness, and compliance with ARARs.
Evaluation of the overall protectiveness of an alternative during
the RI/FS should focus on how a specific alternative achieves protection
over time and how site risks are reduced. The analysis should indicate
how each source of contamination is to be eliminated, reduced, or
controlled for each alternative.
7-28
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OSWER Directive 9355.3-01
7.2.3.8 State Acceptance
This assessment evaluates the technical and administrative issues
and concerns the state (or support agency in the case of State-lead
sites) may have regarding each of the alternatives.
The analysis should be limited to formal comments made during
previous phases of the RI/FS and should describe the process used by the
lead agency to obtain input from the support agency during preparation
of the RI/FS. This may include meetings, opportunities for support-
agency review, and the transmittal of comments between agencies.
No formal opportunity is provided for support-agency review of the
detailed analysis at this stage in the process. Rather, formal comments
can be provided during the comment period on the RI/FS- report and pro-
posed plan. These comments will be fully evaluated during preparation
of the ROD and the responsiveness summary. To the extent that it is
known at the time of the detailed analysis, this criteria should address
those features of alternatives that the state (or support agency)
supports, has reservations about, or opposes.
7.2.3.9 Community Acceptance
This assessment incorporates public input into the analysis of
alternatives. There are several points in the RI/FS process at which
the public may have previously provided comments to the lead agency
(e.g., comments on the RI report or screening of alternatives). As with
the previous assessment of state acceptance, there is no formal
opportunity for public comment during the preparation of the RI/FS.
Formal public comments are provided during the 30-day public comment
period on the RI/FS report and proposed plan. Public concerns or
comments will be addressed in the ROD and responsiveness summary. When
community positions on specific alternatives has been documented during
preparation of the RI/FS, the detailed analysis should address those
features the community supports, has reservations about, or opposes.
7-29
-------
OSWER Directive 9355.3-01
Section 7.4 discusses community relations activities that should be
conducted during the detailed analysis and included in this assessment,
as appropriate,
./
7.2.4 Presentation of Individual Analysis
The analysis of individual alternatives against the nine criteria
should be presented in the FS report as a narrative discussion accom-
panied by a su&anary table. This information will be used to compare the
alternatives and support a subsequent analysis of the alternatives made
by the decisionmaker in the remedy selection process. The narrative
discussion should, for each alternative, provide (1) a description of
the alternative and (2) a discussion of the individual criteria
assessment.
The alternative description should provide data on technology
components (use of innovative technologies should be identified),
quantities of hazardous materials handled, time required for
implementation, process sizing, implementation requirements, and
assumptions. These descriptions, by clearly articulating the various
waste management strategies for each alternative, will also serve as the
basis for documenting the rationale of the applicability or relevance
and appropriateness of potential Federal and State ARARs. Therefore,
the key ARARs for each alternative should be identified and integrated
into these discussions.
The narrative discussion of the analysis should, for each
alternative, present the assessment o'f the alternative against each of
the nine criteria. This discussion should focus on how, and to what
extent, the various factors within each of the nine criteria are
addressed. The factors presented in Tables- 7-2 through 7-5 have been
included to illustrate typical concerns that may need to be addressed
As noted previously information on State acceptance and community
acceptance may not be available and therefore these criteria would not
be addressed at this time.
7-30
-------
(continued)
Asmsssment Factor*
Alternative I—No Action
Alternative 2—Contalnment
Capping
Alternative 3--Containment,
Onslte BCBA Landfill
Alternative 4—In-Sltli
Treatment. Vapor Extraction
Alternative a—Trmetamnt,
Incineration Omit*
Long-Term Effectiveness
and Permanence ~
- Magnitude of residual
risk
- Adequacy of control*
- Heliability of control*
Significant risk remain*
from ground-water contamina-
tion of MOug/1 1C! onjlte.
Concentratlom* of M uo/1
1CS arc projected to occur
In 100 re*tiamU*l well*
In 10 to ISfmte?. M«k
also remalam'frem contamina-
ted soil Md bulldlmgs on-
•ite, which a*y act a« a
continuing source of dust
and ground-water contaalna-
tloo.
No direct engineering
control* to prevent expo-
sure to contaminated *oll
and ground vater; fence la
susceptible to vandalIan;
annual inapectloo and re-
pair 1* required.
Ground-niter Monitoring
•ill track pluae movement,
but will not mediate
contamination.
Sole reliance on fence and
Institutional reatrlctlons
to prevent exposure) high
level of residual risk;
further degradation of
ground water likely.
Bivlronaental degradation
would occur due to mlgra-
tloo of contaainated
ground water a* described
for Alternative 1. Poten-
tial exists for human expo-
sure* due to unauthorised
us* of contaminated ground
vater. Potential for risk
frost soils also exist*
should the cap fall.
Multimedia cap will reduce
the potential for direct
contact with contaainated
soil* and dusti leaching
to ground water reduced,
but not eliminated; cap-
ping Is a well-established,
proven technology) regular
maintenance and Inspection
is required; cap will
probably need replacement
in 30 years.
Ground-water oonltorlng
will track plune moveaent,
but not remediate
contamination.
Likelihood of failure Is
small as long as out is
performed; risk from
direct contact reduced;
further degradation of
ground water likely.
After ground-water extrac-
tion and treatment Is corn-
plate, aquifer will have
lOug/1 ICE onslt* and <5ug/l
offslte. Potential exists
for exposure to soil at
76,100 ag/tg O10 *), or
continued ground-water con-
tamination should the land-
fill containment system
fall.
Reduces to* potential for
direct contact! prevent*
leaching of contaminant* to
ground water.
KM landfill 1* a proven
technology; annual Inspec-
tion and aalntenance
required; ground water
offslte will be restored to
drinkable quality.
Ground-water monitoring will
verify the effectiveness of
the extraction system.
Likelihood of landfill
failure Is small as long as
O(M is performed; ground-
water nonltoring needed to
verify performance.
Treatment of soil and
ground water significantly
reduce* residual *lt* rl*k.
BMldual ICE to rail « ,
64^*"mjg/«g CUT* to 10 ').
Reduced potential for human
exposure to moll and/or
contaelnant migration to
ground water. Ground water
will have lOug/1 KS
onslte, <5ug/l offslt*.
Hultlmedl* cap reduce* tbe
potential for direct con-
tact with contaminants re-
maining In soil; vapor ex-
traction will significantly
reduce contaminant* In
•oil, but will require
pilot testing; ground water
offalte will be reatored to
drinkable quality.
Ground-water monitoring will
verify tbe effectiveness of
the extraction system, soil
treatment, and cap.
Cap failure unlikely;
testing needed to verify
performance of vapor
extraction aystea.
After Mil* new* bmeo
inclnmratad, alaor risk
reaalB* frmm trmataamt
onslt*.
TO r-lMfliU rmldual*.
water will k* watered to
Incln*r*tlon 1* • proven
technology; no long-term
annulment of treatment
residuals required.
Limited monitoring needed
to verify ground-water
restoration to <5ug/l.
Bendy will bo highly
reliable dua to removal of
material posing • rl*k.
Reduction of Toxlcltr.
Hoblllty. or Volumf^
Implemeotablllty
- Technical feasibility
No reduction in toxlclty,
mobility, or volume, since
no treatment employed.
Pence is easily
constructed; ground-water
monitoring would be easy to
Implement and construct;
spread of ground water
plume vould make remedia-
tion more difficult In the
future.
No reduction in TMV of the
soil contamination itself.
Cap and alternate Hater
supply are easily
implemented.
Spread of ground-water
plume vould make remedia-
tion more difficult to
effect in the future.
Same as Alternative 2 for
•oil; volume and toxlclty of
ground-water contamination
almost completely remediated
by extraction and treatment
to Sug/l offslte.
RCRA landfill relatively
easy to Implement; staging
of soil excavation required;
monitoring needed to assess
effectiveness of ground-
water extraction/treatment;
connection of residential
wells to municipal vater
supply still feasible If
extraction does not perform
as expected.
Toxlclty and volume of
contaminants in soil
significantly reduced by
treatment; ground-water
contamination same as
Alternative 3.
Soil vapor extraction
relatively easy to
Implement, requires some
specialIted equipment and
specialists for startup;
the technology has been
demonstrated at sites with
similar conditions.
Ground water as described
in Alternative 3.
Toxlclty and volume of coll
and ground-water contamina-
tion almost completely
eliminated; soil treated to
1x10 , ground water to
Sug/l TCE.
Incineration would require
special equipment and
operators; residuals
require testing to verify
treatment effectiveness;
tbe technology has been
demonstrated at sites witb
similar conditions.
Ground water as described
in Alternative 3.
-------
T«bl« 7-6
(continued)
06HB) Directive MSS.3-O1
assessment Factors
Alternative I—Mo Action
Alternative 2--CootalD
Alternative J--Containment,
On»tte KM Landfill
Alternative 4—Io-81ta
Treetment. Vapor ftitractlc
Al tenet Iv* ft—^Treatment,
IncflnaraUoa Oomtte
Implementabllttv (cont'd)
- Administrative
feasibility
- Availability of
services and materials
Coat
- Capital cost
- OU*
- Promt north
No ofCmitm omajstnsetion,
thereto**, W meCBltS
require*). •
Service* mad Mterlali
locally available.
$40,000
$40,000
$100,000
Approval ior water hook-up
needed frea ounlclpal vator
authorit?.
8 Alternative 1.
Save aa Alternative 1.
$11,850,000
$580,000
$16,185,000
> M Alternative 1.
Service* and eatorlala
available, 00121 •peclallata
reqolrod for oeaatructlon
and startup.
$10,680,000
$1,600,000
$17,900,000
Can an alternative 1.
Bobllo snclDMQtoar and
operators ooe^cffl? avail*
ebllltp (ren it» oouroe*
looatad 9O3 alias one*.
$27,860,000
$1,320,000
$35,660,000
Coeollance with *B»B»/TBC8
- Coepllanoe with ARARi
Approprlateneaa of
valvera
Coepllance with criter-
ia, advlaorlea, and
gulduoe
HCU In ground water
would not be attained.
Hot Justifiable
Doea not Met atate health
departaent criteria for
ground-vater quality.
Aquifer In exceaa of NCI*.
Cuaulatlvf.rick In eicesi
of 1 • 10 .
Not Justifiable
Saae a* Alternative 1.
All ARABS will be Mt.
Not required
CoepUes with atate and
local criteria and federal
advisories.
All ARABS will be Mt.
Not required
Sas» as Alternative 3.
All ARMS will be Mt.
Not required
SaM u Alternative 3.
Orerall Protection of
Hunan Health and the
BivlronnenT
- How risks are elimin-
ated, reduced, or coo-
trolled
State Acceoti
CuasmiiiltT Acceptance
Risk of direct contact wltb
contealnated solla coo-
trolled by fence; risk to
huaan health froa dust and
Ingeatlon of contaailnated
ground water la not coo-
trolled; environmental
degradation will Increase
as ground-water contami-
nation spreads and leaching
from onslte soils
continues.
Risk of direct contact
wltb contaminated soils
and dust cootrolled by
multimedia cap; risk of
ground-water logestlon con-
trolled by alternate water
supply and deed restrictions;
contaminant migration froa
onslte soils to ground water
controlled by cap but not
eliminated; envlronaentel
degradation will Increase
as ground-water contamina-
tion continues to spread.
Risk of direct contact with
contaminated soils and dust
controlled by landfill cap;
contaolnant migration from
onslte soils to ground water
significantly reduced by
landfill liner and leacbate
collection system; risk to
huaan health and the environ-
ment froa ground-water con-
tamination significantly
reduced by ground-water
extractIon and treatment.
Risk of direct contact with
contaminated soils and dust
significantly reduced by
treatment of soil) risk
froa direct contact to
contamination remaining
after treatment controlled
by multimedia cap.
Contaminant migration from
onslte soils to ground
water significantly reduced
by soil treatment and
capping; risk to human
health and the environment
significantly reduced by
ground-water extraction and
treatment.
Risk oŁ direct contact wltb
contaelnated soils and dust
eliminated by treatment of
soils to 1 s U>° risk
level; risk to human health
and the environment froa
ground-water contamination
permanently eliminated by '
treataent of soils and
ground water.
To be addressed following public <
-------
OSWER Directive 9355.3-01
during the detailed analysis. It may not be necessary or appropriate to
address every factor for each alternative being evaluated and, further-
more it My be useful to address other factors to ensure a better
understanding of how an alternative is evaluated against the criteria.
The uncertainties associated with specific alternatives should be
included when changes in assumptions or unknown conditions could affect
the analysis (e.g., the time to attain ground-water cleanup targets may
be twice as long as estimated if assumptions made about aquifer
characteristics for a specific ground-water extraction alternative are
incorrect.)
The FS should also include a summary table highlighting the
assessment of each alternative with respect to each of the nine
criteria. Table 7-6 provides an example of such a summary prepared for
a site at which volatile organic compounds have contaminated soils and
an underlying unconsolidated aquifer. In this example, the plume is
migrating toward residential water supply wells and is predicted to
intercept them in 10 to 15 years.
7.2.5 Comparative Analysis of Alternatives
Once the alternatives have been individually assessed against the
nine criteria, a comparative analysis should be conducted to evaluate
the relative performance of each alternative in relation to each
specific evaluation criterion. This is in contrast to the preceding
analysis in which each alternative was analyzed independently without
the consideration of interrelationships between alternatives. The
purpose of this comparative analysis is to identify the advantages and
disadvantages of each alternative relative to one another so that the
key tradeoffs to be evaluated by the decisionmaker can be identified.
The first five criteria (short-term effectiveness; long-term
effectiveness, and permanence; reduction of toxicity, mobility, and
7-31
-------
Directive 9)55.1-01
Table 7-6
SUGGESTED rOMAT FOR SOMIUtlXING ALTESMATIVCS MULTSIS
Asseaimsnt Factor*
Alternative 1—Mo Action
Alternative 2--Contalnnent
Capping
Alternative 1—Contalnment.
Onalte KM Landfill
Alternative 4—Ia-81tu
Treatment. Vapor attraction
Alternative 5—Tnatawat,
Incineration Onsite
Short-Term Effectiveness
- TIM intll protection
Is achieved (after BOO
signing)
Fence en tin cite, deed
restrictions to prevent
onslte llsiijlgiyjjt/a**)
coslte ami «iisite Me
of rmntemlmstee' frouod
water) ongoimg monitoring.
•eduction of potential for
direct contact could be
achieved In 1 weeks or
less) rlak fro» ground-water
logeation remain*.
• Protection of community
during remedial action*
Slight Increaea In dust
during fence construction.
Protection of workers
during remedial actions
- Envlroneental Impacts
Protection required against
derail contact and Inhala-
tion during fence construc-
tion.
Ho significant adverse
environmental Impacts free
construction
Denollsb and shred build-
ings; place sjultlMdla cap
over entire site) fence,
deed restrictions) alter-
nate Hater supply) ongoing
oonltorlng.
Cap construction could take
2 years, allowing time for
design, bidding, construc-
tion, and downtime during
•Inter.
Sin sooths for water
connection.
Increase In dust during cap
construction) contaminated
soils remain largely undis-
turbed.
Protection required against
dermal contact and Inhala-
tion of contaminated dust
during cap construction.
Ho significant adverse
environmental impacts from
construction.
Denollah and shred bulld-
Ingsi^excavate soil to
1x10 cancer risk) dispose
onslte In a KM landfill)
fence, deed restrictions)
collect ground water and
treat by air stripping)
ongoing aonltorlng.
RCRA landfill could take
2.5 years for design and
construction, allowing time
for staging of excavated
soils and downtIce during
winter.
Ground-water collection and
treatment system would take
up to 12 months for pilot
testing, design, and con-
struction. Pumping time of
20 to 10 years would be _*
required to reach the 1x10
cancer risk level In ground
watar.
Significant Increase In dust
from contaminated soils
during excavation and
staging.
Air Impacts from stripping
tower largely mitigated by
emissions control system.
Protection required against
dermal contact and Inhala-
tion of contaminated dust
during landfill construc-
tion. Also, protection
needad agalnat dust and
vapors during construction
and operation of air strip-
ping system.
Aquifer drawdown during
ground-water extraction and
treatment (20 to 30 years))
minor air Impacts from
stripping towers.
Demolish buildings, piece
nibble onslte) Install soil-
vapor extraction system and
multimedia ccp) fence, deed
restrictions) collect/
treat ground water ao In
Alternative 1) ongoing
monitoring.
Soil vapor extraction
system would take 10 months
for pilot testing, design,
and oonotructloo. the
system would be operated
for 5 to 8 year* after
which a multimedia cap,
requiring about !• aonths
to construct, would be
placed over the site.
Ground-water component as
aoscrlbed In Alternative 3.
Slight increase In dust
during construction of
fence and moll vapor
extraction ayatom.
Air Impact* from vapor
extraction and stripping
towers mitigated by
emissions control systems.
Protection requlrod against
dermal contact, Inhalation
of dust or vapors during
Installation, and operation
of soil vapor extraction
and air stripping systems.
Sam* as Alternative 1, plus
minor air Impacts from
soil-vapor extraction
system.
Demolish kvildtoom and
Incin-
erate* pl" rubble mod
rtlspomm «f ;r**14ual* onslte
and cap) collect/treat
ground mater a* 1m
Alternative 3.
12 to 16 sooths for trial
burn, design, and construc-
tion of Incinerator)
6.5 yearSito incinerate)
95,500 yd* of coil end
demolition tobr.'.a.
Ground-water component as
described In Alternative 1.
Significant Increase In
dust during excavation and
staging.
Air Impacts from
Incinerator mitigated by
emissions control system)
air Impacts from stripping
tower mitigated by
emission* control •yatem.
Protection required against
dermal contact, inhalation
of soil* and duat during
excavation and staging]
protection also required
against dust and vapors
during startup and
operation of incineration
and air stripping aystems.
Same as Alternative 1, plus
potential minor air quality
impacts from Incinerator
emission*.
-------
OSWER Directive 9355.3-01
volume; inplenentability; and cost) will generally require more
discussion than the remaining criteria because the key tradeoffs or
concerns aaong alternatives will most frequently relate to one or more
of these live. The overall protectiveness and compliance with ARARs
if
criteria will generally serve as threshold determinations in that they
either will or will not be met. Community and state acceptance will
likely be evaluated only preliminarily (if at all) during the RI/FS
because such information frequently is not available. Community and
state acceptance can be addressed more thoroughly once comments on the
RI/FS report and the proposed plan have been received and a final remedy
selection decision is being made.
7.2.6 Presentation of Comparative Analysis
The comparative analysis should include a narrative discussion
describing the strengths and weaknesses of the alternatives relative to
one another with respect to each criterion, and how reasonable varia-
tions of key uncertainties could change the expectations of their
relative performance. If innovative technologies are being considered,
their potential advantages in cost or performance and the degree of
uncertainty in their expected performance (as compared with more
demonstrated technologies) should also be discussed.
The presentation of differences between alternatives can be
measured either qualitatively or quantitatively, as appropriate, and
should identify substantive differences (e.g., greater short-term
effectiveness concerns, greater cost, etc.) between alternatives.
Quantitative information that was used to assess the alternatives (e.g.,
specific coat estimates, time until response objectives would be
obtained, Ifid levels of residual contamination) should be included in
these discussions.
Minor differences between alternatives may also need to be highlighted
when comparing options providing fairly similar levels of performance
and protection.
7-35
-------
OSWER Directive 9355.3-01
7.3 POST-RI/FS SELECTION OF THE PREFERRED ALTERNATIVE
FolSdiring completion of the RX/FS, the results of the detailed
analyses/' when combined with the irisk management judgments made by the
decisionmaker, become the rationale for selecting a preferred
alternative and preparing the proposed plan. Therefore, the results of
the detailed analysis, or more specifically the comparative analysis,
should serve to highlight the relative advantages and disadvantages of
each alternative so that the key tradeoffs can be identified. It will
be these key tradeoffs compiled with risk management decisions that will
serve as the basis for the rationale and provide a transition between
the RI/FS report and the development of a proposed plan (and ultimately
a ROD). Specific guidance for preparing proposed plans and RODs is
provided in the Draft Guidance on preparing Superfund Decision Documents
(OSWER Directive number 9355.3-02).
7.4 COMMUNITY RELATIONS DURING DETAILED ANALYSIS
Site-specific community relations activities should be identified
in the community relations plan prepared previously. While appropriate
modifications of activities may be made to the community relations plan
as the project progresses, the plan should generally be implemented as
written to ensure that the community is informed of the alternatives
being evaluated and is provided a reasonable opportunity to provide
input to the decisionmaking process.
Often, a fact sheet is prepared that summarizes the feasible
alternatives being evaluated. As appropriate, small group consultations
or public meetings may be held to discuss community concerns and explain
alternatives under consideration. Public officials should be briefed
and press releases prepared describing the alternatives. Other activi-
ties identified in the community relations plan should be implemented.
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OSWER Directive 9355.3-01
The objective of community relations during the detailed analysis
is to assist the community in understanding the alternatives and the
specific considerations the lead agency must take into account in
selectiriSta remedial alternative. In this way, the community is
"TSSF-'
prepared^to provide meaningful input during the upcoming public comment
period.
7.5 REPORTING AND COMMUNICATION DURING DETAILED ANALYSIS
Once the draft RI/FS report is prepared, the lead agency obtains
the support agency's review and concurrence, the public's review and
comment, and local agency and PRP input, if appropriate. The RI/FS
report also provides a basis for remedy selection by EPA (or concurrence
on State and Federal facility remedy) and documents the development and
analysis of alternatives. A suggested FS report format is given in
Table 7-7.
WDR294/027
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OSWER Directive 9355.3-01
Table 7-7
SUGGESTED FS REPORT FORMAT
Executive Summary
1 Introduction
1.1 Purpose and Organization of Report
1.2 Background Information (Summarized from RI Report)
1.2.1 Site Description
1.2.2 Site History
1.2.3 Nature and Extent of Contamination
1.2.4 Contaminant Fate and Transport
1.2.5 Baseline Risk Assessment
2 Identification and Screening of Technologies
2 . 1 Introduction
2.2 Remedial Action Objectives —
Presents the development of remedial action objectives for each
medium of interest (i.e., ground water, soil, surface water,
air, etc.). For each medium, the following should be
discussed:
- Contaminants of interest
- Allowable exposure based on risk assessment
- Allowable exposure based on ARARs
- Development of remedial action objectives
2.3 General Response Actions —
For each medium of interest, describes the estimation of areas
or volumes to which treatment, containment, or exposure
technologies may be applied.
2.4 Identification and Screening of Technology Types and Process
Options — For each medium of interest, describes:
2.4.1 Identification and Screening of Technologies
2.4.2 Evaluation of Technologies and Selection of
Representative Technologies
3 Development and Screening of Alternatives
3.1 Development of Alternatives —
Describes rationale for combination of technologies/media into
alternatives. Note: This discussion may be by medium or for
'^ihe site as a whole.
3.2 Screening of Alternatives
3.2.1 Introduction
3.2.2 Alternative 1
- Description
- Evaluation
- Effectiveness
- Implementability
- Cost
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OSWER Directive 9355.3-01
Table 7-7
(continued)
.3 Alternative 2
- Description
- Evaluation
3.2.4 Alternative 3
3.2*.5 Summary of Screening
4 Detailed Analysis of Alternatives
4d Introduction
4.2 Alternative Analysis
4.2.1 Alternative 1
4.2.1.1 Description
4.2.1.2 Assessment
- Short-Term Effectiveness
- Long-Tenn Effectiveness and Permanence
- Reduction of Mobility, Toxicity, and
Volume
- Implementability
- Cost
- Compliance with ARARs
- Overall Protection
- State Acceptance
- Community Acceptance
4.2.2 Alternative 2
4.2.2.1 Description
4.2.2.2 Assessment
4.2.3 Alternative 3
4.2.4 Sunmary of Alternatives Analysis
4.3 Comparison Among Alternatives
4.3.1 Short-Term Effectiveness
4.3.2 Long-Tenn Effectiveness and Permanence
4.3.3 Reduction of Toxicity, Mobility, and Volume
4.3.4 Implementability
4.3.5 Cost
4.3.6 Compliance with ARARs
4.3.7 Overall Protection
4.3.4 State Acceptance
4.3.9 Community Acceptance
4.3.10 Summary of comparisons among alternatives
4.4 Summary of Detailed Analysis
Bibliography
Appendices
WDR294/027
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OSWER Directive 9355.3-01
Appendix A
INTERIM GUIDANCE ON PRP PARTICIPATION
IN THE RI/FS PROCESS
WDR319/010
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE
DRAFT
MEMORANDUM
SUBJECT: Interim Guidance on Potentially Responsible Party
Participation in Remedial Investigations and
Feasibility Studies
ER
i
:OM: J. Winston Porter
Assistant Administrator
Regional Administrators, Regions I-X
Regional Counsel, Regions I-X
Director, Waste Management Division,
Regions I, IV, V, VII, and VIII
Director, Emergency and Remedial Response Division,
Region II
Director, Hazardous Waste Management Division,
Regions III and VI
Director, Toxics and Waste Management Division,
Region IX
Director, Hazardous Waste Division, Region X
INTRODUCTION
This memorandum sets forth the policy and procedures governing
Ke participation of potentially responsible parties (PRPs) in
e development of remedial investigations (RI) and feasibility
udies (FS) under the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA), as amended by the
Iuperfund Amendments and Reauthorization Act (SARA) of 1986.
his memorandum discusses:
I
The initiation of enforcement activities including PRP searches
and PRP notification.
The circumstances in which PRPs may conduct the RI/FS.
The development of enforceable agreements governing PRP RI/FS
activities.
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o Initiation of PRP RI/FS activities and oversight of the RI/FS
by EPA.
o EPA control over PRP RI/FS activities including correction
of deficiencies, dispute resolution, and termination of PRP
RI/FS activities.
o PRP participation in Agency RI/FS activities.
More detailed information regarding each of the above topics is
included in the attached Appendices.
This document is consistent with CERCLA and EPA guidance in
effect as of December 1987, and is intended to supersede the
March 20, 1984 memorandum from Assistant Administrators Lee M.
Thomas and Courtney M. Price entitled ""Participation of •:
Potentially Responsible Parties in Development of Remedial
Investigations and Feasibility Studies Under CERCLA" (OSWER
Directive No. 9835.1). Users of this guidance should consult the
draft "Guidance For Conducting Remedial Investigations and
Feasibility Studies Under CERCLA" (March 1988) or any relevant
guidance or policies issued after distribution of this document
before establishing EPA/PRP responsibilities for conducting RI/FS
activities. Additional guidance regarding procedures for EPA
oversight activities will be available in the forthcoming EPA
"Guidance Manual on Oversight of Potentially Responsible Party
Remedial Actions Under CERCLA."
II. BACKGROUND . .
Sections 104/122 x of CERCLA provides PRPs with the
opportunity to conduct the RI/FS when EPA determines that, 1) the
PRPs are qualified to conduct such activities and 2) that they
will carry out the activities in accordance with CERCLA
requirements and EPA procedures. It is the policy of EPA to
encourage the early and active participation of PRPs in
conducting RI/FS activities. To encourage PRP participation, the
Agency will continue its policy of early and timely PRP searches
as veil as early PRP notification and negotiation for RI/FS
activities.
1. The legal authority to enter into agreements with PRPs
is found in CERCLA Section 122(a). This section then refers to
response actions conducted pursuant to Section 104(b). For the
purposes of this guidance, Sections 104/122 will be cited when
referring to such authority.
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Although EPA encourages PRP participation in conducting the
RI/FS, the Agency and CERCLA impose certain conditions governing
their participation. These conditions are intended to assure
that the RI/FS performed by the PRPs is consistent with Federal
requirements and that there is adequate oversight of those
activities. These conditions &re discussed in Section III of
this memorandum and Appendix I, respectively.
At the discretion of EPA, & PRP (or group of PRPs) may
assume full responsibility for undertaking RI/FS activities
pursuant to Sections 104/122 of CERCLA. The terms and conditions
governing the RI/FS activities should be specified in an
Administrative Order. The use of Administrative Orders are
authorized in CERCLA and are the preferred type of agreement for
RI/FS activities since they are authorized internally and
therefore, may be negotiated more quickly than Consent Decrees.
Before SARA, Administrative Orders were signed using the
•authorities of Section 106 of CERCLA. New provisions in SARA
allow for Orders to be signed using the authorities of Sections
104/122; Section 104/122 Orders do not require EPA to make a
finding of imminent and substantial endangerment. RI/FS
activities developed subsequent to the Administrative Order are
set forth in a Statement of Work, which is then embodied or
incorporated in the Order. A Work Plan describing detailed
procedures and criteria by which the RI/FS will be performed must
be developed by the PRPs and, after approval by EPA, should also
be incorporated into the Administrative Order.
It is the responsibility of the lead Agency to ensure the
quality of the effort if the PRPs assume responsibility for
conducting the RI/FS. Therefore, EPA will establish oversight
procedures and project controls to ensure that the
appropriateness of response actions are consistent with CERCLA
and the National Contingency Plan (NCP). Section 104(a)(1) of
CERCLA mandates that no PRP be allowed to undertake and RI/FS
unless EPA determines that the party(ies) conducting the RI/FS
are qualified to do so and further, that the PRPs agree to
reimburse EPA for the costs associated with qualified third party
oversight. Third party oversight is required by Section
104(a)(1) and will be provided to assist in overseeing and
reviewing t&« conduct of the RI/FS.
EPA believes that early participation of PRPs in the
remedial process will encourage PRP implementation of the
selected remedy. PRP participation in RI/FS activities will
ensure that they have a better and more complete understanding of
the selected remedy, and thus will be more likely to agree on
implementation of the remedy. Remedial activities performed by
PRPs will also conserve Fund monies, thus making additional
resources available to address other sites.
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III. INITIATION OF ENFORCEMENT ACTIVITIES
A© part of effective management of enforcement activities,
timely settlements for RI/FS activities are to be pursued. This
ifieludes conducting PRP searches early in the site discovery
process and subsequent notification to all PRPs of their
potential liability and of their opportunity to perform response
activities. Guidance on conducting timely and effective PRP
searches is contained in the guidance manual, "Potentially
Responsible Party Search Manual" (August 27, 1937 - OSWER
Directive No. 9834.6).
EPA policy has been to notify PRPs of their potential
liability for the planned response activities, to exchange
information about the site, and to provide PRPs with an
opportunity to undertake or finance, the response activities
themselves. In the past this has been accomplished by issuing a
"general notice" letter to the PRPs. Section 122(e) of CERCLA
now authorizes EPA to use "special notice" procedures.which
'establish a 60 to 90 day moratorium and formal negotiation
period. The purpose of the moratorium is to provide time for
formal negotiation between EPA and the PRPs for conduct of RI/FS
activities. In particular, use of the special notice procedures
triggers a 60 day moratorium on EPA conduct of the RI/FS. During
the 60 day moratorium, if the PRPs provide EPA with a "good faith
offer" to conduct or finance the RI/FS, the negotiation period
can be extended to a total of 90 days. EPA considers a "good
faith offer" to be a written proposal where the PRPs make a
showing of their qualifications and willingness to conduct or
finance the RI/FS. Such & showing should include the major
elements of a Statement of Work or Work Plan (see Appendix II).
Minor deficiencies in the initial submittals should not be
grounds for a determination that the offer is not a "good faith
offer" or that the. PRPs are unable to perform the RI/FS.
To facilitate PRP participation in the RI/FS process,
Section 122(e)(l) requires the special notice letter to provide
the names and addresses of other PRPs, the volume and nature of
substances contributed by each PRP, and a ranking by volume of
substances at the site, to the extent this information is
available at the time of special notice. Regions are encouraged
to release this information to PRPs with the notice letters, to
the extent the information is available, when the notice letters
are issued. To expedite settlements, Regions are also encouraged
to give PRPs as much guidance as possible concerning the RI/FS
process. It is appropriate to transmit to PRPs copies of
important guidance documents such as the draft "Guidance for
Conducting Remedial Investigations and Feasibility Studies Under
CERCLA" (March 1988), as well as model Administrative Orders and
Statements of Work. A model Administrative Order can be found in
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the memorandum from Gene Lucero entitled, "Model CERCLA Section
106 Consent Order for an RI/FS" (January 31, 1985 - OSWER
Directive No. 9835.5) and a model Statement of Work is contained
as an appendix to the "Guidance on Remedial Investigations Under
CERCLA" (June 1985). (The model Order and the model Statement of
Work are being revised to reflect SARA requirements and will be
forthcoming.) Other Regional and Headquarters guidance relating
to technical issues may be given to PRPs, as well as examples of
project plans (plans that must be developed for the RI/FS
activities) that are of high quality. A description of the
required project plans is included in Appendix I.
Although use of the special notice procedures is
discretionary, Regions are expected to use these procedures in
the majority of cases. If EPA decides not to employ the special
notice procedures in Section 122(e) the Agency will notify the
PRPs in writing of such a decision, including an explanation as
•to why EPA believes the use of the special notice procedures is
inappropriate. Additional information on the content of special
notice letters, including the use of these notice provisions, can
be found in the memorandum entitled "Interim Guidance on Notice
Letters, Negotiations, and Information Exchange" (October 19,
1987 - OSWER Directive No. 9834.10).
The State must be notified of PRP negotiations; an
opportunity for State participation in such negotiations must
also be extended. In addition, if a release or threat of release
at the site in question may have resulted in damages to natural
resources, EPA must notify the appropriate Federal or State
Trustee and provide an opportunity for the Trustee to participate
in the negotiations. To simplify the notification of Federal
Trustees, the Agency intends to provide a list of projects in the
Superfund Comprehensive Accomplishments Plan (SCAP) to the
Trustees as notice to participate in the negotiations.
IV. CONDITIONS FOR EPA INVOLVEMENT IN AND PRP INITIATION OF
RI/FS ACTIVITIES
Under Section 104(a)(1) EPA may authorize PRPs to conduct
RI/FS activities at any site, provided the PRPs meet the
conditions specified by EPA for conducting the RI/FS. These
conditions are discussed in Appendix I of this document and
involve the scope of activities, the organization of the PRPs,
and the PRPs1 (and their contractor's) demonstrative expertise.
EPA encourages PRPs to conduct the RI/FS provided that the PRPs
commit in an Order (or Consent Decree) under CERLCA Sections
104/122 (or Section 106 for a Decree) to conduct a complete RI/FS
to the satisfaction of EPA, under EPA (or State) oversight.
Oversight of RI/FS activities by the lead agency is required by
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Section 104 (a) (1) and is intended to assure that the RI/FS is
adequate for l*ad agency identification of an appropriate remedy,
and* that it will otherwise meet the Agency requirements of
CERCLA, the NCP, and relevant Agency guidance. EPA will allow
PRPs to conduct RI/FS activities and will provide review and
oversight under the following general circumstances.
EPA's priority is to address those MPL sites that have been
identified on the SCAP. The SCAP is an EPA management plan which
identifies site- and activity- specific Superfund financial
allocations for each quarter of the current fiscal year. When
employing Section 122(e) notice procedures, EPA will notify PRPs
of its intention to conduct RI/FS activities at NPL sites in a
manner that allows at least 90.. days notice before obligating the
funds necessary to complete the RI/FS (see Section III of this
guidance). During this 9.0- day: timeJf.ra.vne PRPs; mR,y elect to
conduct the RI/FS, under the review ,anc* oversight of EPA. If the
PRPs agree to conduct the RI/FS they must meet the conditions
discussed in Appendix I of this, guidance. As mentioned in
Section II, Administrative Orders are the preferred type of
agreement for RI/FS activities.
EPA will not engage in lengthy discussions with PRPs over
whether the PRPs will conduct the RI/FS; in general, EPA will
adhere to the timefraraes established by the Section 122 special
notice provisions. In most instances, one® Fund resources have
been obligated to conduct the RI/FS, the PRPs will no longer be
eligible to conduct the RI/FS activities at the site.
The following actions are taken to initiate RI/FS
activities:
o EPA develops a site-specific Statement of Work (SOW) in
advance of the scheduled RI/FS start. This SOW is then
provided to the PRPs along with a draft of the
Administrative Order (or Consent D©eree) at the time of
special notice. PRPs may, with EPA approval, submit a
single project plan that incorporates the elements of a
SOW and a detailed Work Plan. This combined site plan
must clearly set forth the scope of the proposed RI/FS and
would be incorporated into the Order (or Decree) in place
of the SOW.
o Final provisions of the SOW are negotiated with the Order
(or Decree).
o EPA determines whether the PRPs possess the necessary
capabilities to conduct an RI/FS in a timely and effective
manner (conducted simultaneously with other
negotiations).
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c EPA ipvelops a Community Relations Plan specifying any
activities that may be required of the FRPs. (Community
relations activities are discussed in Appendix II of this
guidance.)
o EPA determines contractor and staff resources required for
oversight and initiates the development of an
oversight plan. Initiation of the oversight plan may
include preparing a Statement of Work, if a contractor is
to develop the oversight plan.
o EPA and PRPs identify and procure any necessary
assistance.
o PRPs submit a Work Plan to EPA for Agency review and
approval. The Work Plan must present detailed procedures
and requirements for conducting the RI/FS if such
procedures have not been set forth in the Order (or
Decree). This Work Plan, which in most instances is one
of the first deliverables under the Order (or Decree), is
commonly incorporated into the Order (or Decree) following
EPA approval.
These standardized actions ensure that the scope of the RI/FS
activities to be conducted by the PRPs, and the procedures by
which the RI/FS is performed, are consistent with EPA policy and
guidance. Additional actions may be required, either for a more
complex site or for a site where a number of PRPs are involved;
regardless of the circumstances, these basic actions should be
negotiated as expeditiously as possible. Specific elements of
these actions are discussed in Appendix II.
V. DEVELOPMENT OF THE RI/FS ADMINISTRATIVE ORDER OR CONSENT
DECREE
The PRPs must respond to EPA's notice letter by either
declining, within the time specified to participate in the RI/FS,
or by offering a "good faith" proposal to EPA for performing the
RI/FS. Declining to participate in the RI/FS may be implied by
no response to the notice letter on the part of the PRPs. If the
PRPs have declined to participate, or the time specified has
lapsed, EPA will obligate funds for performing the RI/FS. If a
good faith proposal is submitted, EPA will negotiate with the
PRPs on the scope and terms for conducting the RI/FS.
The results of successful negotiations will in most cases be
contained in an Administrative Order or where the site is in
litigation, in a Judicial Consent Decree entered into pursuant to
Section 122(d) of CERCLA. Guidance for the development of an
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Administrative Order is provided in the document "Administrative
Order: Workshop and Guidance Materials" (U.S. EPA, 1985f), end in
the memorandum from Gene Lucero entitled "Model CERCLA Section
106 Consent Order for an RI/FS" (January 31, 1985). (The latter
guidance is currently being revised in light of additional SARA
requirements.) Before SARA, Administrative Orders were signed
using the authorities of Section 106 of CERCLA. New provisions
in SARA allow for Orders to be signed using the authorities of
Sections 104/122. This is significant because the Agency is no
longer required to make a finding of imminent and substantial
endangerment when entering into RI/FS agreements under Section
104/122 authorities.
An Administrative Order (or Consent Decree) will generally
contain the scope of activities to be performed (either as a
Statement of Wo*k 01:; Woc«,k pl&n); EPA c>?: State oversight roles and
responsibilities, and enforcement options that may be exercised
(such as stipulated penalties). In addition to the above, the
Order (or Decree) will typically include the following elements,
as agreed upon by EPA, the PRPs, and other signatories to the
Order (or Decree):
o Jurisdiction. Describes EPA's authority to enter into
Administrative Orders or Consent Decrees.
o Parties bound. Describes to whom the Order (or Decree)
applies and is binding upon.
o Purpose. Describes the purpose of the Order (or Decree)
in terms of mutual objectives and public benefit.
o Findings of fact, determination, and conclusions of law.
Provides an outline of facts upon which the Order (or
Decree) is based, including the fact that PRPs are not
subject to a lesser standard of liability and will not
receive preferential treatment from the Agency in
conducting the RI/FS.
o Notice to the state. Verifies that the State has been
notified of pending site activities.
o Work to be Performed. Provides that PRPs submit Project
Plan* for EPA or State review and approval before
commencing RI/FS activities. Project plans are those
plans developed for the RI/FS project and include: a Work
Plan describing all tasks to be performed during the
RI/FS, including the schedules for EPA review and approval
procedures as well as a schedule for Work Plan submission
and RI/FS implementation; a Sampling and Analysis Plan
describing the field sampling to be performed and the
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quality assurance procedures which will be followed for
•aa&lirig and analysis (including a description of how the
datatr gathered during the RI/FS will be managed); and a
Health and Safety Plan describing health and s&fety
precautions to be exercised while onsite. (More
information on the Project Plans can be found in Appendix
II of this guidance.)
o Compliance with CERCLA. the NCP. and Relevant Aaencv
Guidance. Specifies that remedial action at a site will
comply with the requirements of CERCLA, the NCP, and
relevant Agency guidance determined to be appropriate for
site remediation.
o Reimbursement of costs. Specifies that PRPs will assume
all costs of performing the work required by the Order (or
Decree). In addition, this section commits PRPs to
reimbursement of all costs associated with EPA review and
oversight activities. This includes reimbursement for
third party assistance in oversight, as required by
section 104(a)(1). This section should also specify the
nature and kind of cost documentation to be provided and
the process for billing and receiving payment.
o Reporting. Specifies the type and frequency of
reporting that PRPs must provide to EPA. Normally the
reporting requirements will, at a minimum include the Work
Plan(s), a RI sususary, a summary describing the
development end screening of alternatives, results of
treatability studies, progress reports, and the draft and
final RI/PS reports. Additional reporting requirements
are left to the discretion of the Regions. That is,
Regions may require additional deliverables such as
interim reports on particular RI or FS activities.
o Designated EPA. State, and PRP project coordinators.
Specifies that EPA, the State, and PRPs shall each
designate a project coordinator.
o Sit* access and data availability. Stipulates that PRPs
shfll allow access to the site by EPA, the State, and
third party oversight officials. Access will be for
inspection, review, oversight, and monitoring in any way
pertaining to the work undertaken pursuant to the Order
(or Decree). In addition, access will be provided in the
event of project takeover. This section also stipulates
that EP& will be provided with all currently available
data.
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Specifies that all records must be
by both parties for a minimum of 6 years after
termination of the Order (or Decree), followed by a
provision requiring PRPs to offer the site records to EPA
before destruction.
o Administrative record requirements. Provides that all
information upon which the selection of remedy is based
must be submitted to EPA in fulfillment of the
administrative record requirements pursuant to Section 113
of CERCLA. (Additional information on administrative
record requirements is contained in Appendix III of this
guidance.)
'. ':-. > v .<•'•'•
o Dispute resolution. Specifies steps to be taken if a
dispute occurs»• The.;-AdminirJtrative.Order states that with
respect to all subaittals and work performed, EPA will be
the final arbiter while the court is the final arbiter for
a Consent Decree. (More information on dispute resolution
can be found in Appendix IV of this guidance.)
o Delay in performance/stipulated penalties. Specifies
EPA's authority to invoke stipulated penalties for
noncompliance with Order or Decree provisions. Section
121 of CERCLA requires that Consent Decrees contain
provisions for penalties in an amount not to exceed
$25,000 per day0 In addition to stipulated penalties,
Section 122 provides civil penalties for violations of
Administrative Orders and Consent Decrees. Delays that
endanger public health and/or the environment may result
in termination of the Order or Decree and EPA takeover of
the RI/FSo Moire information on stipulated penalties can
be found in the Office of Enforcement and Compliance
Monitoringfs (OECM) "Guidance on the use of Stipulated
Penalties in Hazardous Waste Consent Decrees" (September
21, 1987) and in Appendix IV of this guidance.
o Financial assurance. Specifies that PRPs should have
adequate financial resources or insurance coverage to
address liabilities resulting from their RI/FS activities.
When using contractors, PRPs should certify that the
contractors have adequate insurance coverage or that
contractor liabilities are indemnified.
o Reservation of rights. States that PRPs are not released
from all CERCLA liability through compliance with the
Order (or Decree), or completion of the RI/FS. PRPs may
be released from liability relating directly to RI/FS
requirements, if PRPs complete the RI/FS activities to the
satisfaction of EPA.
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-". — -j •
o ftthfjf plains. Provides that nothing in the Order (or
Decx%«) shall constitute a release from any claim or
liability other than, perhaps, for the cost of the RI/FS,
if completed to EPA satisfaction. This section should
also specify the conditions for indemnification of the
U.S. Government.
o Subsequent modifications/Additional work. Specifies that
the PRPs are committed to perform any additional work or
subsequent modifications which are not explicitly stated
in the Work Plan if EPA determines that such work is
needed to enable the selection of an appropriate response
action. (Appendix IV of this guidance contains additional
information on this clause.)
As part of the Agency's effort to encourage PRP
participation in remedial activities, EPA will consider the PRPs1
role in conducting RI/FS activities when assessing an overall
settlement proposal for the remedial design and remedial action.
For example, when the Agency performs a non-binding allocation of
responsibility (NEAR), the Agency may consider previous PRP
efforts and cooperation. This will provide an additional
incentive for PRPs to be cooperative in conducting RI/FS
activities.
VI. STATEMENT OF WORK AND WORK PLAN
Based upon available models and guidance, the Region should
.send a Statement of Work (SOW) to the PRPs with the special
notice and draft Administrative Order (or Consent Decree). The
SOW describes the broad objectives and general activities to be
undertaken in the RI/FS. Once the PRPs receive the SOW they
develop a more detailed Work Plan, which is commonly incorporated
into the Order (or Decree) following EPA approval.
VII. REVIEW AND OVERSIGHT OF THE RI/FS
To ensure that the RI/FS conforms to the procedures of the
NCP and th« requirements of CERCLA, including Sections 104(a) and
121, EPA will review and oversee PRP activities. Oversight is
also required to ensure that the RI/FS will result in sufficient
information to allow for remedy selection by the lead Agency.
An oversight plan should be developed which specifies the
activities EPA, the State, and EPA contractors (or other
oversight officials) will be performing. Different mechanisms
will be used for the review and oversight of different PRP
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products and activities. These mechanisms, and corresponding PRP
activities, oheuld be specified in the oversight plan.
Generally, however, the following oversight activities should be
specified:
o Review of plans, reports, and records by EPA and the
State.
o Oversight of Field activities (including maintenance of
records and documentation).
o Meetings.
o Special studies.
Section 2.04 (Ł•)(!') requires that the President contract with
or arrange for a "qualified person" to assist in the oversight
and review of the conduct of the RI/FS. EPA believes that
qualified persons, for the -purposes of overseeing RI/FS
activities, are those firms or individuals with the professional
qualifications, expertise, and experience necessary to provide
assurance that the Agency is conducting meaningful and effective
oversight of PRP activities. In this context, the qualified
person generally will be TES contractors, but may also be REM, or
ARCs contractors as. well as EPA employees, St?-te employees,
employees of other Federal agencies, or any other "qualified
person" EPA determines to be appropriate to perform the necessary
oversight function.
As part of the Section 104 requirements, PRPs are required
to reimburse EPA for third party oversight costs. All oversight
costs however are recoverable; at a minimum, it is the goal of
the Agency to recover all costs of third-party oversight of RI/FS
activities. Further guidance on these oversight and project
control activities is presented in Appendices III and IV of this
guidance, respectively.
VIII. CONTROL OF ACTIVITIES
EPA will usually not intervene in a PRP RI/FS if activities
are conducted.in conformance with the conditions and terms
specified by the Order (or Decree). However, when deficiencies
are detected, EPA will take immediate steps to correct the PRP
activities. Deficiencies will be corrected through the use of
the foil ox-ring activities: (1) identification of the deficiency,
(2) demand for corrective measures, (3) use of dispute resolution
mechanisms, where appropriate, (4) imposition of penalties, and
if necessary, (5) PRP RI/FS termination and project takeover or
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#9835.la
judicial enforcement. These activities are described in detail
in Appendi* IV of this guidance.
IX. PRP PARTICIPATION IN AGENCY-FINANCED RI/FS ACTIVITIES
PRPs that elect not to perform the RI/FS may be allowed
involvement in a Fund-Financed RI/FS. Section 113(k)(2)(b)
establishes procedures for the participation of interested
persons, including PRPs, in the development of the administrative
record. PRP participation may include the submittal of
information, relevant to the selection of remedy, for inclusion
in the record and/or the review of record contents and submittal
of comments on such contents. The extent of additional PRP
involvement will be left to the discretion of the Region and may
include activities such as:
° Access to the site to observe sampling and analysis
activities.
o Access to raw data and draft reports.
The Agency continues to encourage PRP participation in
Agency-Funded RI/FS to the maximum extent possible. Private
parties may possess technical expertise or knowledge about a site
which would be useful in developing a sound RI/FS. Involvement
by PRPs in the development of a Fund-finaneed RI/FS may also
expedite site cleanup by identifying and satisfactorily resolving
differences between the Agency and private parties that might
otherwise be the subject of litigation.
The final decision whether to permit PRPs to participate in
the Fund-financed RI/FS (as well as the scope of any
participation) rests with the Regions. This decision should be
based on the ability of PRPs to .organize themselves so that they
can participate as a single entity, and the ability of PRPs to
participate without undue interference with or delay in
completion of the RI/FS, and other factors that the Regions
determine are relevant. The Region may terminate PRP
participation in RI/FS development if unnecessary expenses or
delays occur.
X. CONTACT
For further information on the subject matter discussed in
this interim guidance, please contact Susan Cange (FTS 475-9805)
of the Guidance and Oversight Branch, Office of Waste Programs
Enforcement.
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CONDITIONS FOR PRP CONDUCT OF THE
Organization and Management
When several potentially responsible parties are involved at
a site they must be able to organize themselves quickly into a
single representative body to negotiate with EPA. To facilitate
this negotiation process, EPA will make available the names of
and addresses of other PRPs, in accordance with the settlement
provisions of CERCLA Section 122(e). Either a single PRP or an
organized group of PRPs may assume responsibility for development
of the RI/FC. •-•••-
{Scope of Activities •"
.t •
As part of the negotiation process PRPs must agree to follow
the site~specific Statement of Work (SOW) developed by EPA,
including reasonable modifications acceptable to EPA, as the
basis for conducting an RI/FS. PRPs are required to submit an
RI/FS Work Plan setting forth detailed procedures and tasks
necessary to accomplish the RI/FS activities described in the
SOW. EPA will reject any request for modifications to the SOW
that are not consistent with CERCLA (as amended by SARA), the
NCP, the requirements set forth in this guidance document, the
draft "Guidance on Remedial Investigations and Feasibility
Studies Under CERCLA" (March 1988), or other relevant CERCLA
guidance documents.
Demonstrated Capabilities
PRPs must demonstrate to EPA that they possess or are able
to obtain the technical expertise necessary to perform all
relevant activities identified in the SOW, and any amendments
that may be reasonably anticipated to that document. In
addition, PRPs must demonstrate that they possess the managerial
expertise and have developed a management plan sufficient to
ensure that the proposed activities will be properly controlled
and efficiently implemented. This management plan should be
submitted to EPA for approval either during negotiations or as a
part of th*Work Plan. As stated previously, a Work Plan
describing detailed procedures and criteria by which the RI/FS
will be performed is developed by the PRPs after the EPA SOW is
developed. The PRP management plan should be equivalent in scope
ancl content to the discussion of roles and responsibilities of
key personnel usually contained in the Quality Assurance Project
Plan (see the draft "Guidance on Remedial Investigations and
Feasibility Studies Under CERCLA" (March 1988)). In addition to
demonstrating their managerial qualifications, the PRPs should
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demonstrate that they possess the financial capability to conduct
and complete the RI/FS in a timely and effective manner. These
capabilities are discussed briefly below.
o Demonstrated Technical Capability
PRPs should be required to demonstrate the technical and
scientific capabilities of key personnel involved in executing
the project. Personnel qualifications may be demonstrated by
submitting resumes and references. PRPs should demonstrate the
capabilities of the firm or firms that will perform the work by
outlining their past areas of business, relevant projects and
experience, and overall familiarity with the types of activities
to be performed as part of the remedial response.
It is important that qualified firms be retained for
performing RI/FS activities. Firms that do not have the
necessary expertise for performing RI/FS studies may create
unnecessary delays in the project and may create situations which
further endanger public health or the environment. These
situations may be created when PRP contractors submit
insufficient project plans (all plans developed for the RI/FS
project), submit deficient reports, or perform inadequate field
work. Furthermore, excessive Agency oversight may be required in
the event that an unqualified contractor performs the RI/FS; the
Agency may have to significantly increase its workload by
providing repeated (and oftentimes excessive) reviews of project
plans, reports, and oversight of field activities.
o Demonstrated Management Capability
PRPs must demonstrate that they have the administrative
capabilities necessary for conducting the RI/FS in a responsible
and timely manner. An RI/FS team organization chart should be
prepared describing responsibilities and lines of authority.
Positions and responsibilities should be clearly related to
technical and managerial qualifications. The PRPs should also
demonstrate an understanding of effective communications,
information management, quality assurance, and quality control
systems. If PRPs propose using consultants, the consultants must
demonstrate, in addition to those requirements stated above,
effective contract management capabilities.
o Demonstrated Financial Capability
The PRPs should develop a comprehensive and reasonable
estimate of the total cost of anticipated RI/FS activities. EPA
will decide on a case-by-case basis if it will require the PRPs
to demonstrate that they have the necessary financial resources
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av&il&Sbl© end comitted to conduct the RI/FS activities. The
resources estimated sh©uld be adequate to cover the anticipated
coetg fo? the RI/FS ae well ae the costs for oversight, plus a
n&sfgin fes m}
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APPENDIX II
INITIATION OF PRP RI/FS ACTIVITIES
After the PRPs have been identified in the PRP Search Report
and sent the special notice letter, EPA will engage in
negotiations with those PRPs who have submitted a good faith
offer and are therefore volunteering to perform the RI/FS. As
the PRPs are demonstrating their capabilities for conducting the
RI/FS, EPA will negotiate the terms of the Administrative Order
(or Consent Decree) including, within the Order (or Decree) an
acceptable Statement of Work or Work Plan.
Development of the Statement of Work
The Statement of Work (SOW) is developed by EPA and
describes, in a comprehensive manner, all RI/FS activities to be
performed as reasonably anticipated prior to the onset of the
project. The SOW focuses on broad objectives and describes
general activities that will be undertaken to achieve these
objectives. Detailed procedures by which the work will be
accomplished are not presented in the SOW, but are described in
the subsequent Work Plan that is developed by the PRPs. In
certain instances, with the approval of EPA, PRPs may prepare a
single site plan incorporating the elements of a SOW and a Work
Plan. In such instances, the site plan will be incorporated into
the Order (or Decree) in place of the broader SOW.
o Use of the EPA Model SOW
EPA has developed a model SOW defining a comprehensive RI/FS
effort which is contained in the June, 1985 "Guidance on Remedial
Investigations under CERCLA." The Regions should develop a site-
specific SOW based upon the model and taking into account SARA
requirements. RI/FS projects managed by PRPs will involve, at a
minimum, all relevant activities set forth in the EPA model sow.
Further, all plans and reports identified as deliverables in the
EPA model SOW must be identified as deliverables in the EPA sow
and/or the Work Plan developed by the PRPs. Additional
deliverables may be required by the Regions and should be added
to the Administrative Order (or Consent Decree).
o Modification of the EPA Draft SOW Requirements
The activities set forth in the model SOW are considered by
EPA to be critical RI/FS activities that are required by the NCP.
PRPs should present detailed justifications for any proposed
modifications and amendments to the activities set forth in the
SOW developed for the site by EPA. EPA will review all proposed
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modifications and approve or disapprove their inclusion in the
SOtt based OH evsilable information, KP/> poliey, requirements of
the NCP and -CgsaCLA, relevant CERCL& guidaaeg, and overall program
objectives. 1BPA will not allow s&difieations that, in the
judgment of €he Agency, will lead to an unsatisfactory RI/FS.
Raviev of tha RI/FS Project Planes
As stated previously, RI/FS project plans include those
plans developed for the RI/FS. At a minimum the project plans
should include a Work Plan, a Sampling and Analysis Plan, a
Health and Safety Plan, and a Community Relations Plan. Review
and approval of the RI/FS project plans by EPA will usually be
required before PRPs can begin site activities.
o Contents of the Work Plan
The Work Plan expands the tasks of the SOW, and the
responsibilities specified in the Agreement, by presenting
detailed procedures for conducting the RI/FS. Typically the Work
Plan is developed after the draft Order (or Decree) and then
incorporated into the Agreement. In some cases however it may be
appropriate for EPA to develop the Work Plan prior to actual
negotiation with the PRPs and attach the plan to the draft Order
(or Decree). The PRP RI/FS Work Plan must be consistent with
current EPA guidance. Guidance on developing acceptable Work
Plans is available in the draft "Guidance on Conducting Remedial
Investigations and Feasibility Studies Undeir CERCLA" (March
1988). Additional guidance will be forthcoming in the proposed
NCP. Once the Work Plan is approved by EP&, it becomes a public
document. The Work Plan should, at & minimum, contain the
following elements:
Introduction/Background Statement. FRPs should provide an
introductory or background statement describing their under-
standing of the work to be performed at the site. This
should include historical site information and should
highlight present site conditions.
Description of RI/FS Tasks in Chronological Order. The PRPs
should prepare a chronological description of the
anticipated RI/FS activities. Important milestones,
reports, meetings, and deliverables should be noted.
A list of standardized RI/FS tasks has been developed
and is available in the guidance entitled "RI/FS
Improvements" (July 23, 1987 - OSWER Directive No.
9355.0-20).
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o Contents of the sampling and Analysis Plan
A Sampling &nd Analysis Plan (SAP) must be submitted by the
PRPs before initiation of relevant field activities. This plan
contains two separate elements; a Field Sampling Plan and a
Quality Assurance Project Plan. These documents were previously
submitted as separate deliverables, but are now combined into one
document. Though the SAP is typically implemented by PRP
contractors, it is the responsibility of the PRPs to ensure that
the goals and standards of the plan are met. This document
should contain the following elements:
Field Sampling Plan. The Field Sampling Plan includes a
detailed description of all RI/FS sampling and analytical
activities that will be performed. These activities should
be consistent with the NCP and relevant CERCLA guidance.
Further guidance on developing Field Sampling Plans is
presented in the "Guidance For Conducting Remedial
Investigations and Feasibility Studies Under CERCLA" (March
1988).
Quality Assurance Project Plan. The SAP must include a
detailed description of QA/QC procedures to be employed
during the RI/FS. This section is intended to ensure that
the RI/FS is based on the correct level or extent of
sampling and analysis required to produce sufficient data
for evaluating remedial alternatives for a specific site. A
second objective is to ensure the quality of the data
collected during the RI/FS. Guidance on appropriate QA/QC
procedures may also be found in the draft "Guidance For
Conducting Remedial Investigations and Feasibility Studies
Under CERCLA" (March 1988). Another publication on this
subject is the guidance document, "Data Quality Objectives
for fehe RI/FS Process" (March, 1987 - OSWER Directive No.
9355.0-7B).
If the PRP Work Plan modifies any procedures established in
the NCP or relevant guidance, it must provide an explanation and
justification for the change.
o Other Project Plans
Other project plans that are likely to be required in the
RI/FS process include the Health and Safety Plan and the
Community Relations Plan.
Health and Safety Plan. PRPs should include a Health and
Safety Plan as part of the Work Plan or as a separate
document. The Health and Safety Plan should address the
measures taken by the PRPs to ensure that all activities
will be conducted in an environmentally safe manner for the
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workers and the surrounding community. Guidance on the
appropriate contents of a Health and Safety Plan say be
found in the draft "Guidance For Conducting Remedial
Investigations and Feasibility Studies Under CERCLA" (March
1988) o '$.
Community Relations Plan. A Community Relations Plan must
be prepared for each NPL site. This plan must be consistent
with the NCP and EPA guidance. More information on
Community Relations activities is contained below.
o Review and Approval
PRPs must submit all of the required RI/FS project plans to
EPA for review and approval. EPA will review the Plans for their
technical validity and consistency with the NC? and relevant EPA
guidance. Typically, the Agency must review and approve these
plans before PRPs can begin any site activities. Any
disagreements that arise between EPA and the PRPs over the
contents of the plans should be resolved according to the
procedures set forth in the dispute resolution section of the
relevant EPA/PRP Agreement.
Relations
EPA is responsible for developing and implementing an
effective community relations program, regardless of whether
RI/FS activities are fund-financed or conducted by PRPs. At
State-lead enforcement sites, funded by EPA under Superfund
Memoranda of Agreement, the State has the responsibility for
development and implementation of a community relations program.
PRPs may, under certain circumstances, assist EPA or the State in
implementing the community relations activities. For example,
PRPs may wish to participate in community meetings and in
preparing fact sheets. PRP participation in community relations
activities would, however, be at the discretion of the Regional
Office, or the State, and would require oversight by EPA or the
State. EPA will not under any circumstances negotiate press
releases with PRPs.
EPA (or the State) design and implement community relations
activities according to CERCLA and the NCP. A Community
Relations Plan must be developed by EPA for all NPL sites as
described by the EPA guidance, "Community Relations in Superfund:
A Handbook" (U.S. EPA, 1983a - OSWER Directive No. 9230.0-03)
(This guidance is being revised to reflect the new requirements
of SARA and will be forthcoming.) The Community Relations Plan
must be independent of negotiations with PRPs. Guidance for
conducting community relations activities at Superfund
enforcement sites is specifically addressed by Chapter VI of the
Handbook and the EPA memo entitled "Community Relations
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Activities at Superfund Enforcement Sites—Interim Guidance"
(U.S. EPA, 1985 - OSWER Directive No. 9230.0-03-a). In some
instances th« decision regarding PRP participation in community
relations activities will be made after the Community Relations
Plan has b«en developed. As a result, the plan will need to be
modified by EPA or State staff to reflect Agency and PRP roles
and responsibilities.
EPA, or the State, will provide the Community Relations Plan
to all interested parties at the same time. In general, if the
case has not been referred to the Department of Justice (DOJ) for
litigation, community relations activities during the RI/FS
should be the same for Fund- and PRP-lead sites. If the case has
been (or may potentially be) referred to DOJ for litigation,
constraints will likely be placed on the scope of activities.
The EPA Community Relations Plan may be modified after
consultation with the technical enforcement staff, the Regional
Counsel, the Office of Enforcement and Compliance Monitoring, and
other negotiation team members, including, if the case is
referred, the lead DOJ or Assistant United States Attorneys (i.e,
the litigation team). This technical and legal staff must be
consulted prior to any public meetings or dissemination of fact
sheets or other information; approval must be obtained prior to
releases of information and discussions of technical information
in advance. PRP participation in implementing community
relations activities will be subject to EPA (or State) approval
in administrative settlements and EPA/DOJ in civil actions. Key
activities specific to community relations programs for
enforcement sites include the following:
PRP preparation of Work Plans and public review of Work
Plans for Administrative Orders. The PRP Work Plan, as
approved by EPA, is incorporated into the Administrative
Order (or Consent Decree). Once the Agreement is signed, it
becomes a public document. Although there is no requirement
for public comment on an Administrative Order, Regional
staff are encouraged to announce, after the Order is final,
that the PRP is conducting the RI/FS. Publication of notice
and a corresponding 30-day comment period is required
however, for Consent Decrees. EPA may also consult with
community representatives on the PRP Work Plan.
Availability of RI/FS information from the PRPs. PRPs, in
agreeing to conduct the RI/FS, must also agree to provide
all information necessary for EPA -(or the State) to
implement a Community Relations Plan. The Order (or Decree)
should identify the types of information that PRPs will
provide, and contain conditions concerning the provision of
this information. EPA should provide the PRPs with the
content of the plan so that the PRPs can fully anticipate
the type of information that will be made public. All
information submitted by PRPs will be subject to public
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inspection (i.e., available through Freedom of Information
Act requests, public dockets, or the administrative record
(if the information is relevant to remedial action decision
making)} unless it is deemed either as enforcement sensitive
by EPA, or business confidential by PRPs, in conformance
with 40 CFR Part 2.
Development of the ATSDR Health Assessment
Section 110 of CERCLA requires the Agency for Toxic
Substances and Disease Registry (ATSDR) to perform health
assessments at all NPL facilities according to a specified
schedule. The purpose of the health assessment is to assist in
determining whether any current or potential threat to human
health exists and to determine whether additional information on
human exposure and associated health risks is needed.
The EPA remedial project manager (RPM) should coordinate
with the appropriate ATSDR Regional representative for
initiation of the health assessment. In general, the health
assessment should be initiated at the start of the RI/FS. The
ATSDR Regional representative will provide information on data
needs specific to performing a health assessment to ensure that
all necessary data will be collected during the RI. The RPM and
the ATSDR Regional representative should also coordinate the
transmission and review of pertinent documents dealing with the
ejrtent and nature of site contamination (i.e., applicable
technical memoranda and the draft RI). As ATSDR has no
provisions for withholding documents if requested by the public,
the RPM must discuss the review of enforcement sensitive
documents and drafts with the ATSDR Regional representative
rather than to hand them over, to ensure EPA's enforcement
confidentiality. Further guidance on coordination of RI/FS
activities with ATSDR can be found in the document entitled
"Guidance for Coordinating ATSDR Health Assessment Activities
with the Superfund Remedial Process11 (March, 1987 - OSWER
Directive No. 9285.4-02).
Development of the Oversight Plan
EPA will review RI/FS plans and reports as well as provide
field oversight of PRP activities during the RI/FS. To ensure
that adequate resources are committed and that appropriate
activities are performed, the EPA will develop an oversight plan
that defines EPA responsibilities, identifies RI/FS products to
be reviewed, and lists activities that EPA will oversee. In
preparing the plan, EPA should consider such factors as who will
be doing the oversight and the schedule of activities that will
be monitored. A tracking system for recording PRP milestones and
cost estimates should be developed. This system should also
track third party activities and other appropriate cost items
such as travel needs.
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Identification and Prp^rgffent of EPA Assistance
In accordance with Section 104(a) EPA must arrange for a
third par% to assist in oversight of the RI/FS. The following
section provides guidance for identifying and procuring such
assistance for EPA activities.
o Assistance for EPA Activities
As specified in Section 104(a)(1), EPA is required to
contract with or arrange for a qualified person to assist in
oversight of the RI/FS. Qualified individuals are those groups
with the professional qualifications, expertise, and experience
necessary to provide assurance that the Agency is conducting
appropriate oversight of PRP RI/FS activities.
Normally, EPA will obtain oversight assistance through the
Technical Enforcement Support (TES) contract issued through the
Office of Waste Programs Enforcement or occasionally through the
Remedial Action (REM) contracts issued through the Office of
Emergency and Remedial Response. The latest version of the TES
User Guide (January 1986) contains detailed instructions
regarding access to these contracts. In some cases oversight
assistance may be provided by States through the use of Coopera-
tive Agreements. Oversight assistance may also be obtained
through the U.S. Aray Corps of Engineers or other governmental
agencies, Interagency Agreements should be utilized to obtain
such assistance.
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APPENDIX III
REVIEW AND OVERSIGHT OF THE RI/FS
Review of Plans. Reports, and Records
EPA will review all RI/FS products which are submitted to
the Agency as specified in the Work Plan or Administrative Order
(or Consent Decree). PRPs should ensure that all plans, reports,
and records are comprehensive, accurate, and consistent in
content and format with the NCP and relevant EPA guidance. After
this review process, EPA will either approve or disapprove the
product. If the product is found to be unsatisfactory, EPA will
notify the PRPs of the discrepancies or deficiencies.
o Project Plans
EPA will review all project plans that are submitted as
deliverables in fulfillment of the Agreement. These plans
include the Work Plan, the Sampling and Analysis Plan (including
both the Field Sampling Plan and the Quality Assistance Project
Plan), and the Health and Safety Plan. If the initial submittals
are not sufficient in content or scope, the RPM will request that
the PRPs submit revised document(s) for review. When all
required project plans have been reviewed and accepted, EPA will
give approval for the PRPs to commence field activities and other
tasks designated in the Work Plan.
The PRPs may be required to develop additional Work Plans or
modify the initial Work Plan contained in or created pursuant to
the Agreement. These changes may result from the need to: (1)
re-evaluate the RI/FS activities due to changes in, or
unexpected, site conditions, (2) expand the initial Work Plan
when additional detail is necessary, or (3) modify or add
products to the Work Plan based on new information (e.g., a new
population at risk). EPA will review and approve all new Work
Plans and modifications as soon as they are developed and
submitted for review.
o Reports
PRPs will, at a minimum, submit monthly progress reports,
technical reports (including a summary of RI activities, a
summary of the development and screening of alternatives, and
results of treatability studies), and draft and final RI/FS
reports as required in the Order (or Decree). To assist in the
development of the RI/FS and review of documents, additional
deliverables may be specified in the Agreement. These reports
and deliverables will be reviewed by EPA to ensure that the
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activities specified in the Order (or Decree) and approved Work
Plan are being properly implemented. These reports will
generally .be submitted according to the conditions and schedule
set forth in the Agreement. Elements of the PRP reports are
discussed below.
Monthly Progress Reports. The review of monthly progress
reports is an important activity performed during oversight.
These reports should provide sufficient detail to allow EPA to
evaluate the past and projected progress of the RI/FS. PRPs
should submit these written progress reports to the RPM. The
report should describe the actions and decisions taken during the
previous month and activities scheduled during the upcoming
reporting period. In addition, technical data generated during
the month (i.e., analytical results) should be appended to the
report. Progress reports should also include a detailed
statement of the manner and extent to which the procedures and
dates set forth in the Agreement/Work Plan are being met. The
draft "Guidance For Conducting Remedial Investigations and
Feasibility Studies Under CERCLA" (March 1988) lists suggested
procedures for PRPs to use in managing and documenting RI/FS
performance through progress reports. Generally, EPA will
determine the adequacy of the performance of the RI/FS by
reviewing the following subjects discussed in progress reports:
o Technical Summary of Work
The monthly report will describe the activities and
accomplishments performed to date. This will generally include a
description of all field work completed, such as sampling events
and installation of wells; a discussion of analytical results
received; and a discussion of data review activities developed
for the RI/FS. The report will also describe the activities to
be performed during the upcoming month.
o Schedule
EPA will oversee PRP compliance with respect to those
schedules specified in the Order (or Decree). Delays, with the
exception of those specified under the Force Majeure clause of
the Agreement, may result in penalties, if warranted. If PRPs
cannot perform required activities or cannot provide the required
deliverables specified in the Work Plan; they should notify the
RPM by telephone immediately. In addition, PRPs should notify
the RPM when circumstances may delay the completion of any phase
of the work or when circumstances may delay access to the site.
PRPs should also provide to the RPM, in writing, the reasons for,
and anticipated duration of, such delays. Any measures taken or
to be taken by the PRPs to prevent or minimize the delay should
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be described including the timetables for implementing such
measures.
o Budget
The relationship of budgets to expenditures is to be tracked
where the RI/FS is funded with a financial mechanism established
by the PRPs. If site activities require more funds than
originally estimated, EPA must be assured that the PRPs are
financially able to undertake additional expenditures. While EPA
does not have the authority to review or approve a PRP budget, it
is believed that by evaluating costs during the course of the
RI/FS EPA can effectively monitor activity to ensure timely
completion of RI/FS activities. If the PRPs run over budget, EPA
must be assured that they can continue the RI/FS activities as
scheduled. Therefore, PRPs should submit budget expenditures and
all cost overrun information to the EPA. Budget reports need not
present dollar amounts, but should indicate the relationship
between remaining available funds and the estimate of the costs
of remaining activities. This information should be included in
the PRP monthly progress reports.
o Problems
Any problems that the PRPs encounter which could affect the
satisfactory performance of the RI/FS should be brought to the
immediate attention of EPA. Such problems may or may not be a
force majeure event, or caused by a force majeure event. EPA
will review problems and advise the PRPs accordingly. Problems
which may arise include, but are not limited to:
Delays in mobilization or access to necessary
equipment.
Unanticipated laboratory/analytical time requirements.
Unsatisfactory QA/QC performance.
Requirements for additional or more complex sampling.
Prolonged unsatisfactory weather conditions.
Unanticipated site conditions.
- Unexpected, complex community relations
activities.
Other Reports. All other reports, such as technical reports
and draft and final RI/FS reports, should be submitted to EPA
according to the schedule contained in the Order (or Decree) or
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the approved Work Plan. EPA will review and approve these
reports as they are submitted. Suggested formats for the RI and
FS report* are presented in the draft "Guidance for conducting
Remedial Investigations and Feasibility studies under CERCLA"
(March 1988).
o Records
PRPs should preserve all records, documents, and information
of any kind relating to the performance of work at the site for a
minimum of six years after completion of the work and termination
of the Administrative Order (or Decree). After the six year
period, the PRPs should offer the records to EPA before their
destruction.
Document control should be a key element of all
recordkeeping. The following activities require careful
recordkeeping and will be subject to EPA oversight:
Administration. PRP administrative activities should be
accurately documented and recorded. Necessary precautions to
prevent errors or the loss or misinterpretation of data should be
taken. At a minimum, the following administrative actions should
be documented and recorded:
Contractor work plans, contracts, and change orders.
• Personnel changes.
Communications between and among PRPs, the State, and
EPA officials regarding technical aspects of the RI/FS.
Permit application and award (if applicable).
Cost overruns.
Technical Analysis. Samples and data should be handled
according to procedures set forth in the Sampling and Analysis
Plan. Documentation establishing adherence to these procedures
should include:
Sample labels.
Shipping forms.
- Chain-of-custody forms.
Field log books.
All analytical data in the RI/FS process should be managed as set
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forth in the Sampling and Analysis Plan. Such analytical data
may be the product of:
Contractor laboratories.
Environmental and public health studies.
Reliability, performance, and implementability studies
of remedial alternatives.
Decision Making. Actions or communications among PRPs that
involve decisions affecting technical aspects of the RI/FS should
be documented. Such actions and communications include those of
the project manager (or other PRP management entity), steering
committees, or contractors.
Administrative Record Requirements. Section 113(k) of
CERCIA requires that the Agency establish an administrative
record upon which the selection of a response action is based. A
suggested list of documents which are most likely to be included
in any adequate administrative record is provided in the
memorandum entitled "Administrative Records for Decisions on
Selection of CERCIA Response Actions" (May 29, 1987 - OSWER
Directive No. 9833.3). More detailed guidance will be
forthcoming, including guidance provided in the revisions to the
NCP. There are, however, certain details associated with
compiling and maintaining an administrative record that are
unique to PRP RI/FS activities.
The information which may comprise the administrative record
must be available to the public from the time an RI/FS Work Plan
is approved by EPA. From this point on PRPs must transmit to EPA
all of the relevant information such as that identified in the
above mentioned guidance. The required documentation should be
specified in the Administrative Order (or Decree). EPA will
compile the administrative record and that record will include
all information considered by the Agency, not just the
information upon which the Agency relied in the selection of
remedy. The Agreement should specify which pre-Rl/FS documents
must be obtained from the PRPs for inclusion in the record. This
may include any previous studies conducted under State or local
authorities, management documents held by the PRPs such as
hazardous waste shipping manifests, and other information about
site characteristics or conditions not contained in any of the
above documents.
EPA is responsible for compiling and maintaining the
administrative record, and generating and updating an index. If
EPA and the PRPs mutually agree, the PRPs may be allowed to house
and maintain the administrative record file at or near the site;
they may not however be responsible for the actual compilation of
the record. Housing and maintaining the administrative record
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would include setting up a publicly accessible area at or near
the site and ensuring that documents remain and are updated as
necessary. EPA must always be responsible for: deciding whether
docuiaentf*are included in the administrative record, transmitting
records to the PRPs, and maintaining the index to the repository.
Draft documents which are generated by EPA or their
contractors are considered internal Agency documents and are
generally not included in the administrative record unless
released to outside parties (including PRPs) or in circumstances
where there is no final document containing the information
considered or relied on by EPA. EPA will consider drafts
generated by PRPs or their contractors similarly. Draft
documents generated by PRPs conducting the RI/FS will not be
included in the record unless they are released to parties other
than the participating regulatory agencies. In addition, any
information in the draft document that is used for decision
making and is not contained elsewhere in the administrative
record should be extracted and included in the record.
Field Activities
o Field Inspections
Field inspections are an important oversight mechanism for
determining the adequacy of the work performed. EPA will
therefore conduct field inspections as part of its oversight
responsibilities. The oversight inspections should be performed
in a way that minimizes interference with PRP site activities or
undue complication of field activities. EPA will take corrective
steps, as described in Section VII and Appendix IV, if un-
satisfactory performance or other deficiencies are identified.
Several field-related tasks may be performed during
oversight inspections. These tasks include:
On-site presence/inspection. As specified in Section
104(e)(3), EPA reserves the right to conduct on-site inspections
at any reasonable time. EPA will therefore establish an on-site
presence to assure itself of the quality of work being conducted
by PRPs. At a minimum, field oversight will be conducted during
critical times, such as the installation of monitoring wells and
during sampling events. EPA will focus on whether the PRPs
adhere to procedures specified in the SOW and Work Plan(s),
especially those concerning QA/QC procedures. Further guidance
regarding site characterization activities is presented in the
NEIC Manual for Groundwater/Subsurface Investigations at
Hazardous Waste Sites (U.S. EPA, 1981c), the draft "Guidance For
Conducting Remedial Investigations and Feasibility Studies Under
CERCLA" (March 1988), the "RCRA Ground Water Technical
Enforcement Guidance Document" (September, 1986 - OSWER Directive
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No. 9950.1), and the forthcoming "Guidance Manual on Oversight of
Potentially Responsible Party Remedial Actions Under CERCLA."
analyses of samples. EPA may collect a
number of QA/QC samples including blank, duplicate, and split
samples. The results of these sample analyses will be compared
to the results of PRP analyses. This comparison will enable EPA
to identify potential quality control problems and therefore help
to evaluate the quality of the PRP investigation.
Environmental Monitoring. EPA may supplement any PRP
environmental monitoring activity. Such supplemental monitoring
may include air or water studies to determine additional
migration or sudden releases that may have occurred as a result
of site activities.
o QA/QC Audits
EPA may either conduct, or require the PRPs to conduct (if
specified in the Agreement) , laboratory audits to ensure
compliance with proper QA/QC and analytical procedures, as
specified in the Sampling and Analysis Plan. These audits will
involve on-site inspections of laboratories used by PRPs and
analyses of selected QA/QC samples. All procedures must be in
accordance with those outlined in The User's Guide to the
Contract Laboratory Program. (U.S. EPA, 1986) or otherwise
specified in the Sampling and Analysis Plan.
o Chain-of-Custody
Chain-of -custody procedures will be evaluated by EPA. This
evaluation will focus on determining if the PRPs and their
contractors adhere to the procedures set forth in the Sampling
and Analysis Plan. Proper chain-of -custody procedures are
described in the draft "Guidance For Conducting Remedial
Investigations and Feasibility Studies Under CERCLA" (March 1988)
and in the National Enforcement Investigation Center fNEIC)
Policies and Procedures Manual. (U.S. EPA, 1981b) . Evaluation of
chain-of -custody procedures will occur during laboratory audits
as well as during on-site inspections of sampling activities.
Meetings
Meetings between EPA, the State, and PRPs should be held on
a regular basis (as specified in the Order (or Decree) ) and at
critical times during the RI/FS. Such critical times may include
when the SOW and the Work Plan are reviewed, the RI is completed,
remedial alternatives are developed and being screened prior to
final analysis, and the draft and final RI/FS reports are
submitted. These meetings will discuss overall progress,
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discrepancies in the work performed, problems encountered in the
performance of RI/FS activities and their resolution, community
relations, and other related issues and concerns. While meetings
may be initiated by either the PRPs or EPA at any time, they will
generally be conducted at the stages of the RI/FS listed below.
o Initiation of Activities
EPA, the State, and the PRPs may meet at various times
before field activities begin to discuss the initial planning of
the RI/FS. Meetings may be arranged to discuss, review, and
approve the SOW; to develop the EPA/PRP Agreement; and to
develop, review, and approve the Work Plan.
o Progress
EPA may request meetings to discuss the progress of the
RI/FS. These meetings should be held at least quarterly and will
focus on the items submitted in the monthly progress reports and
the findings from EPA oversight activities. Any problems or
deficiencies in the work will be identified and corrective
measures (see Section VIII and Appendix IV) will be requested.
o Closeout
EPA may request a closeout meeting upon completion of the
RI/FS. This meeting will focus on the review and approval of the
final RI/FS report, tetsiination of the RI/FS Agreement, and any
final on-site activities which the PRPs may be required to
perform. These activities may include maintaining the site and
ensuring that fences and warning signs are properly installed.
The transition to remedial design and remedial action will also
be discussed during this meeting.
Special Studies
EPA may determine that special studies related to the PRP
RI/FS are required. These studies can be conducted to verify the
progress and results of RI/FS activities or to address a specific
complex or controversial issue. Normally, special studies are
performed by the PRPs; however, there may be cases in which EPA
will want to conduct independent studies. The PRPs should be
informed of any such studies and given adequate time to provide
necessary coordination of site personnel and resources. If not
provided for in the Agreement, modifications to the scope of
work, through the addition of a special study, may be required to
the Agreement and/or the Work Plan.
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APPENDIX IV
CONTROL OF ACTIVITIES
Identification of Deficiencies
Oversight activities may identify unsatisfactory or defi-
cient PRP performance. The determination of such performance may
be based upon findings such as:
o Work products inconsistent with the SOW or Work Plan.
o Technical deficiencies in submittals or other RI/FS
products.
o Unreasonable delays in performing RI/FS
activities.
o Procedures inconsistent with the NCP.
Corrective Measures
The need to perform corrective measures may arise in the
event of deficiencies in reports or other work products or
unsatisfactory performance of field or laboratory activities.
When deficiencies are identified corrective measures may be
sought by: (1) notifying the PRPs, (2) describing the nature of
the deficiency, and (3) either requesting the PRPs to take
whatever actions they regard as appropriate or setting forth
appropriate corrective measures. The following subsections
describe this process for each of the two general types of
activities that may require corrective measures.
o Corrective Measures Regarding Work Products
Agency review and approval procedures for work products
generally allow three types of responses: (1) approval, (2)
approval with modifications, and (3) non-approval. Non-approval
of a work product (including project plans) immediately
constitutes a. notice of deficiency. EPA will immediately notify
the PRPs if ||iy work product is not approved and will explain the
reason for such a finding.
Approval with modifications will not lead to a notice of
deficiency if the modifications are made by the PRPs without
delay. If the PRPs significantly delay in responding to the
modifications, the RPM should issue a notice of deficiency to the
PRP project manager detailing the following elements:
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A description of the deficiency or a statement
describing in what manner the work product was found to
be deficient or unsatisfactory.
Modifications that the PRPs should make in the work
product to obtain approval.
A request that the PRPs prepare a plan, if necessary,
or otherwise identify actions that will lead to an
acceptable work product.
- A schedule for submission of the corrected work
product.
An invitation to the PRPs to discuss the matter in a
conference.
A statement of the possibility of EPA takeover at the
PRPs expense, EPA enforcement, or penalties (as
appropriate).
o Corrective Measures Regarding Field Activities
When the lead°Agency discovers that the PRPs (or their
contractors) are performing the RI/FS field work in a manner
that is inconsistent with the Work Plan, the PRPs should be
notified of the finding and asked to voluntarily take appropriate
corrective measures. The request is generally made at a progress
meeting, or, if immediate action is required at a special meeting
held specifically to discuss the problem. If corrective measures
are not voluntarily taken, the RPM should, in conjunction with
appropriate Regional Counsel, issue a notice of deficiency
containing the following elements:
A description of the deficiency.
A request for an explanation of the failure to perform
satisfactorily and a plan for addressing the necessary
restoration activities.
A statement that failure to present an explanation may
be taken as an admission that there is no valid
- explanation.
Where appropriate, an invitation to discuss the matter
in a conference.
A statement that project termination may occur and/or
civil action may by initiated if appropriate actions
are not taken to correct the deficiency.
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A description of the potential liabilities incurred in
the event that appropriate actions are not taken.
to the Work Plan/Additional Work
Under the Administrative Order (or Consent Decree) , PRPs
agree to complete the RX/FS, including the tasks required under
either the original Work Plan or the subsequent or modified Work
Plan. This may include determinations and evaluations of
conditions that are unknown at the time of execution of the Order
Agreement. Modifications to the original RI/FS Work Plan are
frequently required as field work progresses. Almost uniformly
work not explicitly covered in the Work Plan is required and
provided for in the Order (or Decree) . This work is usually
identified during the RI and is driven by the need for further
information in a specific area. In general, the Agreement should
provide for fine-tuning of the RI, or the investigation of an
area previously unidentified. As it becomes clear what
additional work is necessary, EPA will notify the PRPs of the
.work to be performed and determine a schedule for completion of
the work.
EPA must ensure that clauses for modifications to the Work
Plan are included in the Agreement so that the PRPs will carry
out the modifications as the need for them is identified. To
facilitate negotiation on these points, EPA may consider one or
more of the following provisions in the Order (or Decree) for
addressing such situations:
Specifying the dispute resolution process for modified
Work Plans and additional work requirements.
Defining the applicability of stipulated penalties to
any additional work which the PRPs agree to undertake.
Defining the limits of additional work requirements.
pispute Resolutions
As discussed elsewhere in this guidance, the RI/FS Order (or
Decree) developed between EPA and the PRPs sets forth the terms
and conditions for conducting the RI/FS. An element of this
Agreement i* a statement of the specific steps to be taken if a
dispute arises between EPA (or its representatives) and the PRPs.
These steps should be well defined and agreed upon by all
signatories to the Agreement.
A dispute with respect to the Order (or Decree) is followed
by a specific period of discussion with the PRPs. After the
discussion period, EPA issues a final decision which becomes
incorporated into the Agreement. Administrative Orders should
clarify that with respect to all submittals and work performed,
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EPA will be the final arbiter, the court, on the other hand, is
the final arbiter for Consent Decrees.
Penalties ';
As an incentive for PRPs to properly conduct the RI/FS and
correct any deficiencies discovered during the conduct of the
Agreement, EPA should include stipulated penalties. Section 121
provides up to $25,000 per day in stipulated penalties for
violations of a Consent Decree while Section 104/122 authorizes
EPA to impose civil penalties for violations of Administrative
Orders. Penalties should begin to accrue on the first day of the
deficiency and continue to be assessed until the deficiency is
corrected. The type of violation (i.e, reporting requirements
vs. implementation of construction requirements), as well as the
amounts, should be specified as stipulated penalties in the
Agreement to avoid negotiations on this point which may delay the
correction. The amounts should be set pursuant to the criteria
of Section 109 and as such should take into account the nature,
circumstances, extent, and gravity of the violations as well as
the PRPs ability to pay, prior history of violations, degree of
culpability, and the economic benefit resulting from
noncompliance.
Project Takeover
Generally, EPA will consult with PRPs to discuss
deficiencies and corrective measures. If these discussions fail,
EPA has two options: (1) pursue legal action to force the PRPs
to continue the work, or (2) take over the RI/FS. If taking
legal action will not significantly delay implementation of
necessary remedial or removal actions, EPA may commence civil
action against the noncomplying PRP to enforce the Administrative
Order. Under a Consent Decree, the matter would be presented to
the court in which the Decree was filed as a motion to enforce
the provisions of the Decree.
If a delay in RI/FS activities endangers public health
and/or the environment or will significantly delay implementation
of necessary remedial actions, EPA should move to replace the PRP
activities with Fund-financed actions. The RPM will take the
appropriate steps to assume responsibility for the RI/FS,
including Issuing a stop-work order to the PRPs and notifying the
EPA remedial contractors. In issuing stop work orders, RPMs
should be aware that Fund resources may not be automatically
available. But, in the case of PRP actions which threaten human
health or the environment, there may be no other course of
action. Once this stop work order is issued, a fund-financed
RI/FS will be undertaken consistent with EPA funding procedures.
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Directive) nss.1-01
Appendix D
Documentation of ABARs
Alternative 1
action
OOMICAL sncinc
ICE
Beniene
Cadmium
S ppb Federal NCL Is not
achieved In ground water
5 ppb Federal NCL Is not
achieved in ground water
10 ppb Federal NO. 1» not
achieved In ground water.
S ppb State ground water
standard Is not achieved.
1.1 ppb Federal ANQC Is not
achieved In surface water
ACTION SPECIFIC
40 CHI HI
Standard* for
•rators
40 Cm 364-365
Standards for owners
and operators of
hatardous wast*
treat sent, storage,
and disposal facilities
State air toxics
regulations governing
emissions of ICE and
Benzene
40 CFR 2C4
Regulating Incineration
LOCATION SPECIFIC
40 CHI 364.ialb)
Location of TSD within
100 vear floodplaln
State la* governing
location of new
Incinerators
Mill not comply with 40 CFR
264-265
Alternative 3
Offslte disposal of vast*
and contaminated soil/
ground-water entractlon
md treatment
S ppb Federal NCL Is
achieved In ground water
S ppb Federal NCL Is
achieved In ground water
10 ppb Federal HCL is
achieved In ground water.
S ppb State ground water
ntanCerd Is not achieved.
1.1 ppb Federal ;»OjC Is not
achieved In surface water.
Technical infeasibllltv
waiver Is anticipated for
both State ground water
standard and Federal AHQC
Full compliance with
40 CFR Part 262
Balsslons fro> air
stripping unit In full
cospllance with State air
toxics regulations
Alternative S
Onalte disposal of waste)
and coataalnated soil/
ground-water extraction
and treatoent
3 ppb Federal NCL Is
achieved la ground water
S ppb Federal NCL Is
achieved In ground water
10 ppb Federal NCL is
achieved In ground water.
5 ppb State ground water
standard Is not achieved.
1.1 ppb Federal ANDC la not
achieved la surface water.
Technical Infeaslbllltv
waiver Is anticipated for
both State ground water
standard and Federal AMOjC
Full coapllanoe with
40 CFR Part 263
Full coBpllance with 40 CFH
264-265
Falsslons from air
stripping unit In full
compliance with State
air toxics regulations
Alternative 4
Onalte soil Incineration of
waste and contaminated soil/
ground-vater extraction and
treatment
S ppb Mm. sO.
achieved to
Full compliance with
with 40 CFR 264.18(b)
S ppb Federal NO. is
achieved In ground water
10 ppb Federal NCL is
achieved in ground water.
S ppb State ground water
standard is not achieved.
1.1 ppb Federal AHQC la not
achieved In surface water.
Technical Infeeslbllltv
waiver Is anticipated for
both State ground water
standard and Federal JWOC .
Pull compliance with
40 CFR Part 363
Pull coapllaaae with 40 CPU
264-265
Emissions from air
stripping unit and
incinerator In full
compliance with State
air toxics regulations
Rill meet all performance
atandarda for onsite
Incinerators
Pull compliance with
with 40 CPR 264.18(b)
Pull compliance with State
law
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APPENDIX B
ELEMENTS OF RI/FS PROJECT PLANS
B.I ELEMENTS OF A WORK PLAN
Introduction. Presents a general explanation of the reasons for
the RI/FS and the expected results or goals of the RI/FS process.
Site Background and Physical Setting. Describes the current
understanding of the physical setting of the site, the site history, and
the existing information on the condition of the site. (See Section
2.2.2.1 of guidance)
Initial Evaluation. Presents the conceptual site model developed
during scoring describing the potential migration and exposure pathways
and the preliminary assessment of public health and environmental
impacts. (See Section 2.2.2.2 of the RI/FS guidance)
Work Plan Rationale. Documents data requirements for both the risk
assessment and the alternatives evaluation identified during the
formulation of the DQOs and presents work plan approach to illustrate
how the activities will satisfy data needs.
RI/FS Tasks. The tasks to be performed during the RI/FS are
presented. This description incorporates RI site characterization tasks
identified in the QAPP and FSP, the data evaluation methods identified
during scoping (see Section 2.2.7), and the preliminary determination of
tasks to be conducted after site characterization (see Section 2.2.7 of
this guidance).
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B.2 STANDARD FEDERAL-LEAD RI/FS WORK PLAN TASKS
Task 1. Project Planning
This task includes efforts related to initiating a project after
the work assignment is issued. Site survey work may be conducted during
project planning or may occur during the field investigation task. It
should not occur in both. The project planning task is defined as
complete when the work plan and supplemental plans are approved (in
whole or in part). The following typical elements are included in this
task:
o Work plan memorandum
o Kickoff meeting
o Site visit/meeting
o Easements/permits
o Site reconnaissance and limited sampling
o Site survey/topographic map/review of existing aerial photos
o RI/FS brainstorming session
o Collection and evaluation of existing data
o Identification of preliminary remedial alternatives
o Preliminary risk assessment
o Screening of expedited response alternatives
o Determination of applicable, relevant, and appropriate
regulations
o RI scoping
o Preparation of plans (e.g., work plan, health and safety plan,
QAPP, FSP)
o Task management and quality control
Task 2. Community Relations
This task incorporates all efforts related to the preparation and
implementation of the community relations plan for the site. It
includes time expended by both technical and community relations
personnel. It will end when community relations work under Task 12 is
B-2
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completed. This task does not include work on the responsiveness
summary (Task 12). The following are typical elements included in this
task: '*.
o Community interviews
o Community relations plan
o Fact sheets
o Public meeting support
o Technical support for community relations
o Community relations implementation
o Task management and quality control
Task 3. Field Investigation
This task involves efforts related to fieldwork in implementing the
RI. It includes the procurement of subcontractors related to field
efforts. The task begins when any element authorizing fieldwork, as
outlined in the work plan, is approved (in whole or in part). Field
investigation is defined as complete when the contractor and
subcontractors are demobilized from the field. The following activities
are typically included in this task:
o Mobilization
o Media sampling
o Source testing
o Geology/hydrogeological investigations
o Geophysics
o Site survey/topographic mapping (if not performed in project
,' „ planning task)
o Field screening/analyses
o Procurement of subcontractors
o RI waste disposal
o Task management and quality control
B-3
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Task 4. Sample Analysis/Validation
This task includes efforts relating to samples after they leave the
•fe*
field. Separata monitoring of close support laboratories may be
• *• -
required. Any efforts associated with laboratory procurement are also
included in this task. The task ends on the date that data validation
is complete. The following typical activities are usually included in
this task:
o Sample management
o Non-CLP analyses
o Use or mobile laboratories
o Data validation
o Testing of physical parameters
o Task management and quality control
Task 5. Data Evaluation
This task includes efforts related to the analysis of data once it
has been verified that the data are of acceptable accuracy and
precision. The task begins on the date that the first set of validated
data is received by the contractor project team and ends during
preparation of the RI report when it is deemed that no additional data
are required. The following are typical activities:
o Data evaluation
o Data reduction and tabulation
o Environmental fate and transport modeling/evaluation
o Task management and quality control
;*Ł
Task 6. Assessment of Risks
This task includes efforts related to conducting assessments of
risks to human health and the environment. The task will include work
under the RI to assess the baseline risks and set preliminary performance
goals under the FS, to compare risks evaluated among alternatives. Work
B-4
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will begin during the data evaluation and end during the remedial
alternatives evaluation tasks. The following are typical activities:
o Environmental assessment
o Endangerment assessment
o Modeling specific to exposure assessment
o Task management and quality control
Task 7. Treatability Study/Pilot Testing
This task includes efforts to prepare and conduct pilot, bench, and
treatability studies, associated task management, and quality control.
The following are typical activities:
o Work plan preparation
o Test facility and equipment procurement
o Vendor and analytical service procurement
o Equipment operation and testing
o Sample analysis and validation
o Report preparation
o Task management and quality control
Task 8. Remedial Investigation Reports
This task covers all efforts related to the preparation of the
findings once the data have been evaluated under Tasks 5 and 6. The
task covers all draft and final RI reports as well as task management
and quality control. The task ends when the last RI document is
submitted by the contractor to EPA. The following are typical
activities:
o Formatting tables/data presentation
o Writing the report
o Preparing graphics associated with the report
o Reviewing and providing QC efforts
B-5
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o Printing and distributing the report
o Holding review meetings
o Revising report based on agency comments
o Providing task management
Task 9. Remedial Alternatives Screening
This task includes efforts to select the alternatives to undergo
full evaluation. The task starts during data evaluation when sufficient
data are available to begin the screening process. For reporting
purposes, the task is defined as complete when a final set of
alternatives is chosen for detailed evaluation. The following are
typical activities:
o Listing potential technologies
o Screening technologies
o Assembling potential alternatives
o Evaluating each alternative based on screening criteria
o Reviewing and providing QC of work effort
o Preparing report or technical memorandum
o Holding review meetings
o Refining list of alternatives to be evaluated
Task 10. Remedial Alternatives Evaluation
This task applies to the detailed analysis and comparison of
alternatives. The evaluation activities include performing detailed
public health, environmental, and institutional analyses. The task ends
with the start of the preparation of the FS report. The following are
.• **-
typical act-iyities:
o Technical evaluation of each alternative
o Public health evaluation of each alternative
o Environmental evaluation of each alternative
o Institutional evaluation of each alternative
B-6
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o Cost evaluation of each alternative
o Comparison of alternatives
o : Review of QC efforts
o - Review meetings
o Task management and quality control
Task 11. Feasibility Study/RI/FS Reports
Similar to the RI reports task, this task is used to report FS
deliverables. However, this task should be used in lieu of the RI
reports task to report costs and schedules for combined RI/FS
deliverables. The task ends when the FS (or RI/FS) is released to the
public. The following are typical activities:
o Formatting tables/data presentation
o Preparing graphics associated with the report
o Writing the report
o Printing and distributing the report
o Holding review meetings
o Revising the report on the basis of agency comments
o Providing task management and quality control
Task 12. Post RI/FS Support
This task includes efforts to prepare the responsiveness summary,
support the ROD, conduct any predesign activities, and close out the
work assignment. All activities occurring after the release of the FS
to the public should be reported under this task. The following are
typical Activities:
o Preparing the predesign report
o Preparing the conceptual design
o Attending public meetings
o Writing and reviewing the responsiveness summary
o Supporting ROD preparation and briefings
-------
o Reviewing and providing QC of the work effort
o Providing task management and quality control
Task 13. Enforcement Support
This task includes efforts during the RI/FS associated with
enforcement aspects of the project. Activities vary but are to be
associated with efforts related to potentially responsible parties. The
following are typical activities:
o Reviewing PRP documents
o Attending negotiation meetings
o Preparing briefing materials
o Assisting in the preparation of EDO
o Providing task management and quality control
Task 14. Miscellaneous Support
This task is used to report on work that is associated with the
project but is outside the normal RI/FS scope of work. Activities will
vary but include the following:
o Specific support for review of ATSDR activities
o Special efforts related to public health assessments
o Support for review of special state or local projects
Task 15. ERA Planning
This task is to be used specifically for planning expedited response
actions (ERAs) after the appropriate remedial action is selected.
Activities will fall into the two major categories of administrative
support and technical support. The following are typical activities:
o Drafting and supporting preparation of action memorandums
B-8
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o 'Preparing briefing materials
o Attending meetings
o Preparing ERA plans and specifications
o Preparing procurement activities
o Reviewing proposals
Note: The following are some specific comments applicable to the
15 tasks described above:
o All standard tasks or all work activities under each task need
not be used for every RI/FS. Only those that are relevant to
a given project should be used.
o Tasks include both draft and final versions of deliverables
unless otherwise noted.
o The phases of a task should be reported in the same task
(e.g., field investigation Phase I and Phase II will appear as
one field investigation task).
o If an RI/FS is divided into distinct operable units (OUs),
each OU should be monitored and reported on separately.
Therefore, an RI/FS with several OUs may, in fact, have more
than 15 tasks, although each of the task? will be one of the
15 standard tasks.
o Costs associated with project management and technical quality
assurance are included in each task.
o Costs associated with procuring subcontractors are included in
- the task in which the subcontractor will perform work (not the
project planning task).
o This list of standard tasks defines the minimum level of
reporting. For Federal-lead tasks, some RPMs and REM
B-9
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contractors currently report progress in a more detailed
fashion and nay continue to do so as long as activities are
associated with standard tasks.
OF A QUALITY ASSURANCE PROJECT PLAN
Title Page. At the bottom of the title page, provisions should be
made for the signatures of approving personnel. As a minimum, the QAPP
must be approved by the following:
o Subcontractor's project manager (if a subcontractor is used)
o Subcontractor's QA manager (if a subcontractor is used)
o Contractor's project manager (if applicable)
o Contractor's QA manager (if applicable)
o Lead agency's project officer
o Lead agency's QA officer (if applicable)
Provision should be made for the approval or review of others (e.g.,
regional laboratory directors), if applicable.
Table of Contents. The table of contents will include an introduc-
tion, a serial listing of the 16 QAPP elements, and a listing of any
appendixes that are required to augment the QAPP. The end of the table
of contents should include a list of the recipients of official copies
of the QAPP.
Project Description. The introduction to the project description
consists of a general paragraph identifying the phase of the work and
the general objectives of the investigation. A description of the
location, •Jdse, and important physical features of the site such as
Ea'"
ponds, lagoons, streams, and roads should be included (a figure showing
the site location and layout would be helpful). A chronological site
history including descriptions of the use of the site, complaints by
neighbors, permitting, and use of chemicals needs to be provided along
with a brief summary of previous sampling efforts and an overview of the
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results. Finally, specific project objectives for this phase of data
gathering need to be listed, and ways in which tho data will be used to
address each of the objectives must be identified. However, those items
above that are also included in the work plan need not be repeated in
the QAPP and, instead, may be incorporated by reference.
Project Organization and Responsibilities. This element identifies
key personnel or organizations that are necessary for each activity
during the study. A table or chart showing the organization and line
authority should be included. When specific personnel cannot be
identified, the organization with the responsibility should be listed.
QA Objectives for Measurement. For individual matrix groups and
parameters, a cooperative effort should be undertaken by the lead
agency, the principal engineering firm, and the laboratory staff to
define what levels of quality should be required for the data. These QA
objectives will be based on a common understanding of the intended use
of the data, available laboratory procedures, and available resources.
The field blanks and duplicate field sample aliquots to be collected for
QA purposes should be itemized for the matrix groups identified in the
project description.
The selection of analytical methods requires a familiarity with
regulatory or legal requirements concerning data usage. Any regulations
that mandate the use of certain methods for any of the sample matrices
and parameters listed in the project description should be specified.
The detection limits needed for the project should be reviewed
against the detection limits of the laboratory used. Special attention
should be paid to the detection limits provided by the laboratory for
volatile organic compounds, because these limits are sometimes insuf-
ficient for the analysis of drinking water. Detection limits may also
be insufficient to assess attainment of ARARs. For Federal-lead
projects, if QA objectives are not met by CLP Routine Analytical
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Services (HAS), then one or more CLP Special Analytical Services (SAS)
can be written.
Quantitative limits should be established for the following QA
objectivesi
1. Level of QA effort
2. Accuracy of spikes, reference compounds, and so forth
3. Precision
4. Method detection limits
These limits may be specified by referencing the statement of work
(SOW) for CLP analysis, including SAS requests, in an appendix and
referring to the appendix or owner/operator manuals for field equipment.
Completeness, representativeness, and comparability are quality
characteristics that should be considered during study planning.
Laboratories should provide data that meet QC acceptance criteria for
90 percent or more of the requested determinations. Any sample types,
such as control or background locations, that require a higher degree of
completeness should be identified. "Representativeness" of the data is
most often thought of in terms of collection of representative samples
or selection of representative sample aliquots during laboratory analy-
sis. "Comparability" is a consideration during planning to avoid having
to use data gathered by different organizations or among different
analytical methods that cannot be reasonably compared because of
differences in sampling conditions, sampling procedures, etc.
Sampling Procedures. These procedures append the site-specific
sampling, plan. Either the sampling plan or the analytical procedures
element My document field measurements or-test procedures for
hydrogeological investigations.
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For .each major measurement, including pollutant measurement
systems, a description of the sampling procedures to be used should be
provided. Where applicable, the following should be included:
V-
o A description of techniques or guidelines used to select
sampling sites
o A description of the specific sampling procedures to be used
o Charts, flow diagrams, or tables delineating sampling program
operations
o A description of containers, procedures, reagents, and so
forth, used for sample collection, preservation, transport,
and storage
o A discussion of special conditions for the preparation of
sampling equipment and containers to avoid sample
contamination
o A description of sample preservation methods
o A discussion of the time considerations for shipping samples
promptly to the laboratory
o Examples of the custody or chain-of-custody procedures and
forms
o -,••• A description of the forms, notebooks, and procedures to be
used to record sample history, sampling conditions, and
analyses to be performed
The DQO document described above can also be incorporated by
reference in this section. In addition, the Compendium of Superfund
Field Operations Methods (EPA/SAO/P-87/001a, OSWER Directive 9355.0-14)
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contains information pertinent to this section and can be incorporated
by reference.
Custody. Sample custody is a part of any good laboratory or
field operation. If samples may be needed for legal purposes, chain-of-
custody procedures, as defined by the NEIC Policies and Procedures
(EPA-330/9-78-001-R, revised June 1985) , will be used. Custody is
divided into three parts:
o Sample collection
o Laboratory
o Final evidence files
The QAPP should address all three areas of custody and should refer
to the CLP User's Guide and Regional guidance documents for examples and
instructions. For Federal-lead projects, laboratory custody is
described in the CLP SOW; this may be referenced. Final evidence files
include all originals of laboratory reports and are maintained under
documented control in a secure area.
A sample or an evidence file is under custody if:
o It is in your possession.
o It is in your view, after being in your possession.
o It was in your possession and you placed it in a secure area.
o It is in a designated secure area.
A QAPP should provide examples of chain-of -custody records or forms
used to record the chain of custody for samples, laboratories, and
evidence -files .
Calibration Procedures. These procedures should be identified for
each parameter measured and should include field and laboratory testing.
The appropriate standard operating procedures (SOP) should be
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referenced, or a written description of the calibration procedures to be
used should be provided.
Analytical Procedures. For each measurement, either the applicable
SOP should be referenced or a written description of the analytical
procedures to be used should be provided. Approved EPA procedures or
their equivalent should be used.
Data Reduction, Validation, and Reporting. For each measurement,
the data reduction scheme planned for collected data, including all
equations used to calculate the concentration or value of the measured
parameter, should be described. The principal criteria that will be
used to validate the integrity of the data during collection and
reporting should be referenced from Functional Guidelines for Evaluating
Organics Analyses (EPA 68-01-6699) and Functional Guidelines for
Evaluating Inorganics Analyse's (Ref.).
Internal Quality Control. All specific internal quality control
methods to be used should be identified. These methods include the use
of replicates, spike samples, split samples, blanks, standards, and QC
samples. Ways in which the quality control information will be used to
qualify the field data should be identified.
Performance and Systems Audits. The QAPP should describe the
internal and external performance and systems audits that will be
required to monitor the capability and performance of the total measure-
ment system. The current CLP Invitation for Bids for organic and
inorganic analyses may be referenced for CLP RAS performance and systems
audits. The Compendium of Superfund Field Operations Methods may be
referenced for routine fieldwork.
The systems audits consist of the evaluation of the components of
the measurement systems to determine their proper selection and use.
These audits include a careful evaluation of both field and laboratory
quality control procedures and are normally performed before or shortly
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after systems are operational. However, such audits should be performed
on a regular schedule during the lifetime of the project or continuing
operation; An onsite systems audit may be required for formal
laboratory certification programs.
After systems are operational and are gensrating data, performance
audits are conducted periodically to determine the accuracy of the total
measurement system or its component parts. The QAPP should include a
schedule for conducting performance audits for each measurement
parameter. Laboratories may be required to participate in the analysis
of performance evaluation samples related to specific projects. Project
plans should also indicate, where applicable, scheduled participation in
all other interlaboratory performance evaluation studies.
In support of performance audits, the environmental monitoring
systems and support laboratories provide necessary audit materials and
devices, as well as technical assistance. These laboratories conduct
regular interlaboratory performance tests and provide guidance and
assistance in the conduct of systems audits. The laboratories should be
contacted if assistance is needed in the above areas.
Preventative Maintenance. A schedule should be provided of the
major preventative maintenance tasks that will be carried out to mini-
mize downtime of field and laboratory instruments. Owner's manuals may
be referenced for field equipment.
Specific Routine Procedures Used to Assess Data (Precision,
Accuracy, and Completeness). The precision and accuracy of data must be
routinely assessed for all environmental monitoring and measurement
data. The QAPP should describe specific procedures to accomplish this
assessment. If enough data are generated, statistical procedures may be
used to assess the precision, accuracy, and completeness. If statistical
procedures are used, they should be documented.
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Corrective Actions. In the context of quality assurance, corrective
actions are procedures that might be implemented with respect to samples
that do not meet QA specifications. Corrective actions are usually
addressed on a case-by-case basis for each project. The need for
corrective actions is based on predetermined limits for acceptability.
Corrective actions may include resampling or reanalysis of samples and
recommending an audit of laboratory procedures. The QAPP should identify
persons responsible for initiating these actions, procedures for
identifying and documenting corrective actions, and reporting and
followup procedures.
Quality Assurance Reports. QAPPs should identify the method to be
used to report the performance of measurement systems and data quality.
These reports include results of performance audits, results of systems
audits, and significant QA problems encountered, along with recommended
solutions. The final report for each project must include a separate QA
section that summarizes the data quality information contained in the
periodic reports.
B.4 ELEMENTS OF A FIELD SAMPLING PLAN
Site Background. If the analysis of existing data is not included
in the work plan or QAPP, it must be included in the FSP. This analysis
would include a description of the site and surrounding areas and a dis-
cussion of known and suspected contaminant sources, probable transport
pathways, and other information about the site. The analysis should
also include descriptions of specific data gaps and ways in which
sampling is designed to fill those gaps.
Sampling Objectives. Specific objectives of a sampling effort that
describe the intended uses of data should be clearly and succinctly
stated.
Sample Location and Frequency. This section of the sampling plan
identifies each sample matrix to be collected and the constituents to be
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analyzed. A table may be used to clearly identify the number of samples
to be collected along with the appropriate number of replicates and
blanks. A figure should be included to show the locations of existing
or proposed sample points.
Sample Designation. A sample numbering systeo. should be
established for each project. The sample designation should include the
sample or well number, the sampling round, the sample matrix (e.g.,
surface soil, ground water, soil boring), and the name of the site.
Sampling Equipment and Procedures. Sampling procedures must be
clearly written. Step-by-step instructions for each type of sampling
are necessary to enable the field team to gather data that will meet the
DQOs. A list should include the equipment to be used and the material
composition (e.g., Teflon, stainless steel) of the equipment.
Sample Handling and Analysis. A table should be included that
identifies sample preservation methods, types of sampling jars, shipping
requirements, and holding times. SAS requests and CLP SOWs may be
referenced for some of this information.
Examples of paperwork and instructions for filling out the
paperwork should be included. Use of the CLP requires that traffic
reports, chain-of-custody forms, SAS packing lists, and sample tags be
filled out for each sample. If other laboratories are to be used, the
specific documentation required should be identified.
Provision should be made for the proper handling and disposal of
wastes generated onsite. The site-specific procedures need to be
described :Ao prevent contamination of clean areas and to comply with
existing regulations.
B.5 ELEMENTS OF A HEALTH AND SAFETY PLAN
1. The name of a site health and safety officer and the names of key
personnel and alternates responsible for site safety and health
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2. A safety and health risk analysis for existing site conditions, and
for each site task and operation
3. Employee training assignments
4. A description of personal protective equipment to be used by
employees for each of the site tasks and operations being conducted
5. Medical surveillance requirements
6. A description of the frequency and types of air monitoring,
personnel monitoring, and environmental sampling techniques and
instrumentation to be used
7. Site control measures
8. Decontamination procedures
9. Standard operating procedures for the site
10. A contingency plan that meets the requirements of
29 CFR 1910.120(1)(1) and (1)(2)
11. Entry procedures for confined spaces
WDR272/007
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APPENDIX C
BIBLIOGRAPHY OF TECHNOLOGY PROCESS
RESOURCE DOCUMENTS
I - CONTAINMENT TECHNOLOGIES
CAPPING
The Asphalt Institute. Nov. 1976. Asphalt in Hydraulics. Manual
Series No. 12 (MS-12), The Asphalt Institute.
Brady, N.C. 1974. The Nature and Properties of Soils. 8th Ed.,
MacMillan, NY.
Brawner, C.O., Ed. 1980. First International Conference on Uranium
Mine Waste Disposal. Society of Mining Engineers AIME, NY.
Chamberlain, E.J., and A.J. Gow. 1979. Effect of Freezing and Thawing
on the Permeability and Structure of Soils. Engineering Geology, 13,
Elsevier Scientific Publishing Co., Amsterdam, The Netherlands,
pp. 73-92.
Daniel, D.E., and H.M. Liljestrant, Univ. of Texas. Jan. 1984. Effects
of Landfill Leachates on Natural Liner Systems. Chemical Manufacturer's
Association.
England, C.B. 1970. Land Capability; A Hydrologic Response Unit in
Agricultural Watersheds. ARS 41-172, Agricultural Research Service,
U.S. Department of Agriculture.
Ghassemi, M. May 1983. Assessment of Technology for Constructing and
Installing Cover and Bottom Liner Systems for Hazardous Waste
Facilities. Vol. 1, EPA Contract No. 68-02-3174, work assignment
No. 109, U.S. EPA.
Kays, W.B. 1977. Construction of Linings for Reservoirs, Tanks, and
Pollution Control Facilities. John Wiley & Sons, NY.
Kmet, P., K.J. Quinn, and C. Slavik. Sept. 1981. Analysis of Design
Parameters Affecting the Collection Efficiency of Clay Lined Landfills.
Univ. of Wisconsin Extension.
Lambe, W»T., and R.V. Whitman. 1979. Solid Mechanics, SI Version.
John Wiley and Sons, NY.
Lutton, R.J. 1982. Evaluating Cover Systems for Solid and Hazardous
Waste. SW867 (Revised Edition), U.S. EPA, Washington, DC.
Lutton, R.J. et al. 1979. Design and Construction of Covers for Solid
Waste Landfills. EPA-600/2-79-165, U.S. EPA, Cincinnati, OH.
C-l
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Morrison, W.R., and L.R. Simmons. 1977. Chemical and Vegetative
Stabilization of Soil; Laboratory and Field Investigations of New
Materials and Methods for Soil Stabilization and Erosion Control.
Bureau of Reclamation Report No. 7613.
Oldham, J.C., et al. 1977. Materials Evaluated as Potential Soil
Stabilizers. Paper No. S-77-15 Army Engineers, Waterways Experimental
Station, Vicksburg, MS.
Richards, L.A. 1965. Physical Condition of Water in Soil. In:
Methods of Soil Analysis - Part . C.A. Black, Ed., American Society of
Agronomy, Inc.
Schroeder, P.R., et al. The Hydrologic Evaluation of Landfill
Performance (HELP) Model. Vol. 1, EPA/530-SW-64-009, U.S. EPA.
Tchobanoglous, G., et al. 1977. Solid Wastes; Engineering Principles
and Management Issues. McGraw-Hill, NY.
U.S. EPA. Construction Quality Assurance for Hazardous Waste Land
Disposal Facilities. Public Comment Draft, J.G. Herrmann, Project
Officer. EPA/530-SW-85-021, U.S. EPA.
U.S. EPA. July 1982. Draft RCRA Guidance Document Landfill Design,
Liner Systems and Final Cover. U.S. EPA.
U.S. EPA. 1983. Lining of Waste Impoundment and Disposal Facilities.
SW870, U.S. EPA.
U.S. EPA. Procedures for Modeling Flow Through Clay Liners to Determine
Required Liner Thickness. EPA/530-SW-84-001, U.S. EPA.
Warner, R.C., et al. Demonstration and Evaluation of the Hydrologic
Effectiveness of a Three Layer Landfill Surface Cover Under Stable and
Subsidence Conditions - Phase I, Final Project Report.
Warner, R.C., et al. Multiple Soil Layer Hazardous Waste Landfill
Cover: Design, Construction, Instrumentation and Monitoring. In: Land
Disposal of Hazardous Waste Proceedings of the Tenth Annual Research
Symposium.
DUST CONTROLS
Ritter, L»J., Jr., and R.J. Paquette. 1967. Highway Engineering. 3d
Ed., The Ronald Press Co., NY. pp. 726-728.
HORIZONTAL BARRIERS
Bureau of Reclamation. Pressure Grouting. Technical Memo 646.
U.S. EPA. Handbook for Evaluating Remedial Action Technology Plans.
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SEDIMENT CONTROL BARRIERS
California Department of Conservation. May 1978. Erosion and Sediment
Control Handbook. Department of Conservation, State of California.
U.S. EPA.' August 1972. Guidelines for Erosion and Sediment Control
Planning and Implementation. U.S. EPA, Environmental Protection
Technical Services.
U.S. EPA. Sept. 1978. Management of Bottom Sediment Containing Toxic
Substance Procedure, 3rd vs - Japan Meeting. U.S. EPA.
U.S. EPA. June 1982. Handbook - Remedial Action at Waste Disposal
Sites. EPA-625/6-6-82-006, U.S. EPA, Cincinnati, OH.
SURFACE CONTROLS
Lutton, R.J., et al. 1979. Design and Construction of Covers for Solid
Waste Landfills. EPA-600/2-79-165, U.S. EPA Cincinnati, OH.
U.S. EPA. July 1982. Draft RCRA Guidance Document Landfill Design,
Liner Systems, and Final Cover. U.S. EPA.
U.S. EPA. June 1982. Handbook - Remedial Action at Waste Disposal
Sites. EPA-625/6-6-82-006, U.S. EPA, Cincinnati, OH.
VERTICAL BARRIERS
Bureau of Reclamation. Pressure Grouting. Technical Memo. 646.
Shuster, J. 1972. Controlled Freezing for Temporary Ground Support.
Proceedings, 1st North American Rapid Excavation and Tunneling
Conference.
Xanthakos, P. Slurry Walls. McGraw Hill, NY.
II - TREATMENT TECHNOLOGIES
AIR EMISSION CONTROLS/GAS TREATMENT
Bonner, T., et al. 1981. Hazardous Waste Incineration Engineering.
Noyes Data Corporation.
•v
Kern, D.Q. 1950. Process Heat Transfer. .McGraw-Hill, NY.
Kohl, A., and F. Riesenfeld. 1979. Gas Purification. Gulf Publishing
Co.
Perry and Chi1ton Chemical Engineers' Handbook. 5th Ed., 1973,
McGraw-Hill, NY.
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Research and Education Association. 1978. Modern Pollution Control
Technology. Vol. 1, Air Pollution Control. Research and Education
Aacociatien.
BIOLOGICMkTREATMENT
Beneield, L.D., and C.W. Randall. 1980. Biological Process Design for
Wastewater Treatment. Prentice-Hall, Englewood Cliffs, NJ.
Aerobic Biotreatment Reference: Clark, J.W., w. Viessman, Jr., and J.
Hananar. 1977. Water Supply and Pollution Control. IEP, Dun-Donnelly,
NY.
Eckenfelder, W., Jr. 1980. Principles of Water Quality Management.
CBI Publishing, Boston.
Fair, G., J. Geyer, and D. Okun. 1968. Water and Wastewater
Engineering. Vol. 2, John Wiley, NY.
Junkins, R., et al. 1983. The Activated Sludge Process; Fundamentals
of Operation. Science Publishers, Ann Arbor, MI.
Manual of Practice No. 16, Anaerobic Sludge Digestion. EPCF, 1968.
Metcalf & Eddy. 1972. Wastewater Engineering; Treatment, Disposal,
Reuse. 2nd Ed., McGraw-Hill, NY.
Overcash. 1979. Design of Land Treatment Systems for Industrial
Wastes.
Shreve, R. N., and J.A. Brink, Jr. 1977. Chemical Process Industries.
McGraw-Hill, NY.
Smith, E.D., et al. 1980. Proceedings First National Symposium/
Workshop, Rotating Biological Contractor Technology. University ot
Pittsburgh.
Speece, R.E., and J.F. Malina, Jr., Eds. 1973. Applications of
Commercial Oxygen to Water and Wastewater Systems. Univ. of Texas,
Austin.
U.S. EPA. Dec. 1985. Guide for Identifying Cleanup Alternatives at
Hazardous-Waste Sites and Spills. EPA/600/3-83/063; NTIS PB86-144664,
U.S. EPA.
U.S. EPA. 1980. Hazardous Waste Land Treatment, EPA SW 874, U.S. EPA.
U.S. EPA. Dec. 1984. Permit Guidance Manual on Hazardous Waste Land
Treatment Demonstrations. Draft, EPA 530-SW-84-015, U.S. EPA.
U.S. EPA. Process Design Manual, Sludge Treatment and Disposal. U.S.
EPA.
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U.S. Municipal Environmental Research Laboratory. Oct. 1983. Process
Design Manual for Land Application of Municipal Sludge.
EPA 625/1-83-016, U.S. EPA.
Vesilind, P.A. Sludge Treatment and Disposal.
CHEMICAL TREATMENT
Audrieth, L.F., and B.A. Ogg. 1951. The Chemistry of Hydrazine. John
Wiley, NY.
Berkowitz, J.B., et al. 1978. Unit Operations for Treatment of
Industrial Wastes. Noyces Data Corp., Park Ridge, NJ.
Butler, J.W. 1964. Solubility and pH Calculations. Addision-Wesley.
Duffey, J.G., S.B. Gale, and S. Bruckenstein. Electrochemical Removal
of Chromates and Other Metals. In: Cooling Towers. Vol. 2, pp 44-50.
Metcalf & Eddy, Inc., revised by Tchobanoglous, G. 1979. Wastewater
Engineering; Treatment, Disposal, Reuse. 2nd Ed.
McHugh, M.A., and V.J. Krukonis. 1986. Supercritical Fluid Extraction
Principles and Practice. Butterworth Publishers, Boston.
Reduction by Direct Current (Electrochemical Treatment) References:
Scull, G.W., and K.D. Uhrich. Electrochemical Removal of Heavy Metals
in the Presence of Chelating Agents. Andco Environmental Processes,
Inc., Amherst, NY.
Simpson, O.K. Safety Handling Hydrazine. Prepared for the Water Indus-
trial Power Conference, Southfield, MI, Oct. 16~1S, 1983.
Tsusita, R.A., et al. 1981. Pretreatment of Industrial Wastes Manual
of Practice. No. FD-3, Water Pollution Control Federation, Washington,
DC.
IN SITU TREATMENT
Ahlert, R.C., and D.S. Kosson. In-Situ and On-Site Biodegradation of
Industrial Landfill Leachate. NTIS, Springfield, VA.
American Petroleum Institute. Feb. 1982. Enhancing the Microbial
Degradation of Underground Gasoline by Increasing Available Oxygen.
Texas Research Institute.
References on the use of H202 in Subsurface Bioreclamation: American
Petroleum Institute. 1985. Feasibility Studies on the Use of Hydrogen
Peroxide to Enhance Mierobial Degrations of Gasoline. API
Publication 4389.
Baker, R., et al. Oct. 1986. In Situ Treatment for Site Remediation.
Paper presented at Third Annual Hazardous Waste Law and Management
Conference, Seattle, WA, and Portland, OR.
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Ellis, W.D., and T.R. Fogg. August 1986. Treatment of Soils
Contaminated With Heavy Metals. EPA/600/9-86/022, U.S. EPA,
pp. 201-207.
Flathman, P.E., and J.A. Caplan. April 1985. Biological Cleanup of
Chemical Spills. Paper presented at Hazmacon '85 Conference, Oakland,
CA.
Nyer, E.K. 1985. Treatment Methods for Organic Contaminants:
Biological Methods - In Situ Treatment. In Groundwater Treatment
Technology. Van Nostrand Reinhold. pp: 10-108.
U.S. EPA. 1985. In Situ Treatment - Bioreclamation. In Remedial
Action at Waste Disposal Sites. Revised, EPA/625/6/-85/006, U.S. EPA.
U.S. EPA. Sept./Nov. 1984. Review of In-Place Treatment Techniques for
Contaminated Surface Soils. Vol. 1, Technical Evaluation, Vol. 2,
Background Information for In Situ Treatment. EPA-540/2-84-003a, and
EPA-540/284-003b, (NTIS PB-124881 and PB-124899), U.S. EPA.
Ward, C.H., and M.D. Lee. 1985. In Situ Technologies. In Groundwater
Pollution Control'. Canter and Knox, Eds., Lewis Publishers.
Wetzel, R.S., et al. August 1986. Field Demonstration of In Situ
Biological Treatment of Contaminated Groundwater and Soils.
EPA/600/9-86/022, U.S. EPA, pp. 146-160.
Yaniga, P.M., and W. Sanith. 1984. Aquifer Restoration via Accelerated
In Situ Biodegradation of Organic Contaminants. In Proceedings,
NWWA/API Conference on Petroleum Hydrocarbons and Organic Chemicals in
Groundwater - Prevention, Detection, and Restoration, pp. 451-470.
PHYSICAL TREATMENT
Cheremisinoff, P.N., and F. Ellerbusch. 1980. Carbon Adsorption
Handbook. Science Publishers, Ann Arbor, MI.
Cheremisinoff, N., and Azbel, D. 1983. Liquid Filtration. Science
Publishers, Ann Arbor, MI.
Dobbs, R.A., and J.M. Cohen. April, 1980. Carbon Adsorption Isotherms
for Toxic Organics. EPA-600/8-80-023, U.S. EPA.
Cosset, Jilt., et al. June 1985. Mass Transfer Coefficients and Henry's
Constants for Packed-Tower Air Stripping of Volatile Organics;
Measurement and Correlation. ESL-TR-85-18, Final Report, U.S. Air
Force.
Kavanaugh, M.C., and R.R. Trussel. Dec. 1980. Design of Aeration
Towers to Strip Volatile Contaminants from Drinking Water. Journal
AWWA.
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Modern Pollution Control Technology, Vol. 2, Water Pollution Control.
Research and Education Association, 1978.
Perry and Chi1tonf Chemical Engineers' Handbook. 5th Ed., 1973, McGraw
Hill, NY.
Schweitzer, P.A. 1979. Handbook of Separation Techniques for Chemical
Engineers. McGraw Hill, NY.
Shukla, Harish M., and Hicks, R.E. Process Design Manual for Stripping
of Organics. EPA/600-/2-84-130, U.S. EPA.
Treybal, R. 1983. Mass Transfer Operations. 3rd Ed. McGraw-Hill, NY.
SOLIDS DEWATERING
Metcalf and Eddy, Inc. 1972. Wastewater Engineering; Collection,
Treatment, Disposal. McGraw-Hill, NY.
Perry and Chilton, Chemical Engineers' Handbook. 5th Ed., 1973,
McGraw-Hill, NY.
Research and Education Association. 1978. Modern Pollution Control
Technology Vol. II, Solid Waste Disposal. Research and Education
Association.
SOLIDS PROCESSING
Given, I.A. 1973. Mining Engineering Handbook. Society of Mining
Engineers, NY.
Taggert, A.F. 1951. Elements of Ore Dressing. John Wiley, NY.
SOLIDIFICATION, FIXATION, AND STABILIZATION
Technical Handbook for Stabilization/Solidification Alternatives for
Remedial Action at Uncontrolled Hazardous Waste Sites. Environmental-
Laboratory, U.S. Army Engineers Waterways Experiment Station, Vicksburg,
MS.
U.S. EPA. Sept. 1982. Guide to the Disposal of Chemically Stabilized
and Solidified Waste. EPA Doc. No. SW-872. Municipal Environmental
Research/Laboratory, U.S. EPA, Cincinnati, OH.
U.S. EPA. June 1982. Remedial Action at Waste Disposal Sites. Munic-
ipal Environmental Research Laboratory, U.S. EPA, Cincinnati, OH.
THERMAL TREATMENT
Ahling, B. Nov. 1979. Destruction of Chlorinated Hydrocarbons in a
Cement Kiln Environmental Science and Technology. Vol. 13, No. 11.
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Brunner, C.R. 1984. Incineration Systems Selection and Design. Van
Nostrand Reinhold, NY.
Environment- Canada, Environmental Protection Service, Environmental
Impact Control Directorate, Waste Management Branch. 1982. Destruction
Technologies for Polychlorinated Biphenyls (PCBs). Based on a report to
the Waste Management Branch by M.M, Dillon Ltd., Consulting Engineers
and Planners, Toronto, Ontario, Canada.
Frankel, I., Sanders, N., and Vogel, G. 1983. Survey of the
Incineration Manufacturing Industry. CEP, March 1983.
Journal of the Air Pollution Control Association. July 1982, Vol. 32,
No. 7.
Lauber, J.D. 1982. Burning Chemical Wastes as Fuels in Cement Kilns.
Journal of the Air Pollution Control Association, July 1982, Vol. 32,
No. 7.
McBride, J.L., and Heimback, J.A. Skid Mounted System Gives California
Hazardous Wastes Hot Time. Pollution Engineering, July 1982.
McCarthy, J.J. Feb. 1982. Technology Assessment of the Vertical Well
Chemical Reactor. EPA-600/2-82-005, Prepared for U.S. EPA, Municipal
Environmental Research Laboratory, Office of Research and Development.
Oberacker, D.A, 1984. Hazardous Waste Incineration Performance
Evaluations by the United States Environmental Protection Agency.
EPA-600/D-84-285. Prepared for U.S. EPA, Cincinnati, OH.
Peters, J.A., T.W. Hughes, and R.E. Mourninghan. 1983. Evaluation of
Hazardous Waste Incineration in a Cement Kiln at San Juan Cement.
Monsanto Research Co., Dayton, OH.
Seebold, J. A. Practical Flare Design. Chemical Engineering,
December 10, 1984.
U.S. Congress, Office of Technology Assessment, Industry, Technology,
and Employment Program. 1985. Superfund Strategy—Preventing a Toxic
Tomorrow.
U.S. EPA. Sept. 1981. Engineering Handbook for Hazardous Waste
Incineration. NTIS Report No. P881-248163, Prepared for U.S. EPA by
Monsanto Research Corp., Dayton, OH.
Weltzman, L. 1983. Cement Kilns as Hazardous Waste Incinerators.
Environmental Progress, Feb. 1983, Vol. 2, No. 1.
WilhelHi, A.R., and Knopp, P.V. Wet Air Oxidation—An Alternative to
Incineration. CEP, Aug. 1979.
Williams, I.M., Jr. 1982. Pyrolytic Incineration Destroys Toxic Wastes
Recovers Energy. Pollution Engineering, July 1982.
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Zanetti, W.J. Plasma: Harming Up to New CPI Applications. Chemical
Engineering, December 1983.
Ill - REMOVAL/COLLECTION TECHNOLOGIES
CLEAN/REPLACE CONTAMINATED WATER AND SEWER LINES
Cleaning Pipelines: A Pigging Primer. Chemical Engineering, Feb. 4,
1985.
U.S. EPA. Oct. 1983. • Demonstration of Sewer Relining by the Insituform
Process, Northbrook, IL. EPA-600/2-83-064.
WPCF. 1980. Operation and Maintenance of Wastewater Collection
Systems. Manual of Practice No. 7, WPCF.
DRUM AND DEBRIS REMOVAL
U.S. EPA. June 1982. Handbook - Remedial Action at Waste Disposal
Sites. EPA-625-6-6-82-006, Cincinnati, OH.
ENHANCED REMOVAL
Donaldson, E.G., G.U. Chilingarian, and T.F. Ven. 1985. Enhanced Oil
Recovery. Fundamentals and Analyses, 1, Elsevier Science Publishers
B.V., Amsterdam, The Netherlands.
H.K. Van Poollen and Assoc., Inc. 1980. Enhanced Oil Recovery.
Pennwells Publishing Company, Tulsa, OK.
KoltuniaJc, D.L. In Situ Air Stripping Cleans Contaminated Soils.
Chemical Engineering, August 18, 1986, pp. 30-31.
Patton, C.C. 1981. Oilfield Water Systems, Norman, Oklahoma. Campbell
Petroleum Series.
Schumacher, M.M., Ed. 1960. Enhanced Recovery of Residual and Heavy
Oils. Noyes Data Corp., Park Ridge, NJ. (Contains references.)
EXCAVATION
Peurifoy, R.L. 1970. Construction Planning, Equipment and Methods.
2nd Ed. ,'i McGraw-Hill, NY. (Somewhat dated but a good overview of solids
handling equipment.)
GAS COLLECTION
Argonne National. Laboratory. Feb. 1982. Environmental Impacts of
Sanitary Landfills and Associated Gas Recovery Systems. (ANL/CNSV-27),
Argonne National Laboratory, Argonne, IL.
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Encon Associates. 1980. Methane Generation and Recovery From
Landfills. Science Publishers, Ann Arbor, MI.
Landfill Methane Recovery. 1983. Energy Technology Review #80. Noyes
Data Corp, ~
Tchobanoglous, Theisen, and Eliassen. 1977. Solid Wastes - Engineering
Principals and Management Issues. McGraw-Hill, NY.
GROUNDWATER COLLECTION/PUMPING
Bureau of Reclamation. 1978. Drainage Manual. U.S. GPO, Washington,
DC, 286 pp.
Bureau of Reclaaation. 1981. Groundwater Manual. 2nd Ed., U.S. GPO,
Washington, DC, 480 pp.
Freeze, et al. 1979. Groundwater. Prentice-Kail Inc., Englewood
Cliffs, NJ.
Johnson Division, UOP, Inc. 1975. Groundwater and Wells. Johnson
Division, UOP, Inc., Saint Paul, KN.
U.S. Array. 1971. Dewatering; Groundwater Control for Deep Excavations.
Technical Manual No. 5-818-5, Prepared by the Army Engineers Waterways
Experiment Station.
U.S. Department of Agriculture. 1971. Section 16, Drainage of
Agricultural Land. In SCS National Engineering Handlxaok. Engineering
Division Soil Conservation Service, Washington, DC.
U.S. EPA. June 1982. Handbook for Remedial Action at Waste Disposal
Facilities. EPA-625/6-820-006, Prepared by Municipal Environmental
Research Laboratory, Cincinnati, OH.
U.S. EPA. RCRA Groundwater Monitoring Technical Enforcement Guidance
Document (TEGD).
IV - DISPOSAL TECHNOLOGIES
ATMOSPHERIC DISCHARGE
GCA Corp. Dec. 1984. Evaluation and Selection of Models for Estimating
Air Emissions from Hazardous Waste Treatment, Storage and Disposal
Facilities. EPS-450/3-84-020.
Kohl, A., and F. Riesenfeld. 1979. Gas Purification, 3rd Ed. Gulf
Publishing Co.
Vogel, G. May 1985. Air Emission Control at Hazardous Waste Management
Facilities. Journal of the Air Pollution Control Association, May 1985.
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WASTEWATER DISCHARGE
Florida Department of Environmental Regulation. April 1961. Class V
Injection Jfcll Inventory.
U.S. EPA. Dec. 1977. An Introduction to the Technology of Subsurface
Wastewater Injection. EPA-600/2-77-240. Prepared for the U.S. EPA by
Don L. Warner, University of Missouri-Rolla and Jay H. Lehr, National
Water Well Association.
U.S. EPA. Sept. 1982. Fate of Priority Pollutants in Publicly Owned
Treatment Works. Volumes I and II, EPA 440/1-82/303, U.S. EPA, Water
and Waste Management Series, Effluent Guidelines Division WH-522.
U.S. EPA. July 1980. Treatability Manual, Volume Treatability Data.
EPA 600 8-80-042a, U.S. EPA Research and Development Series.
Versar, Inc. Dec. 1979. Water-Related Environmental Fate of 129
Priority Pollutants. Volumes I and II, NTIS PB80-204381, Versar, Inc.,
Springfield, VA. Prepared for U.S. EPA, Washington, DC.
WDR280/022
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OSWER Directive 9355.3-01
APPENDIX D
DOCUMENTATION OF ARARs
The accompanying table presents a suggested foiwat for summarizing the
identification and documentation of ARARs in the RI/FS process. This
format assumes that two previous ARARs identification steps have taken
place during the RI/FS. First, it assumes that a list of Federal and
State ARARs has been developed through consultations "between the lead
and support agencies. This list should include chemical-, action-, and
location-specific requirements and, in the case of multiple ARARs (e.g.,
both a Federal and State chemical-specific ARAR), the ARAB to be used
for the site in question should be specified. Second, it assumes that
identified requirements and the reasons for their applicability or
relevance and appropriateness have been integrated into the narrative
descriptions of each alternative as part of the "Detailed Analysis"
chapter in the FS report. Therefore, this appendix serves as a summary
of the ARARs for each alternative, whether the alternative will meet its
ARARs, and if not, what type of waiver would be required.
The suggested format for the documentation of ARARs is presented here in
the form of an example. The example is meant to be generic and
conceptually simplistic, while demonstrating the different types of
documentation that may be required.
The sit*'consists of an inactive landfill. TCE, benzene, and cadmium
contamination have been found in the soils, ground water, and a stream
adjacent to the landfill at the following levels:
Soils GW Surface Water
TCE 1-100 ppm 1-100 ppb 1-10 ppb
Benzene 1-100 ppm 1-100 ppb 1-10 ppb
Cadmium 1-500 ppm 1-100 ppb 1-5 ppb
D-l
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OSWER Directive 9355.3-01
The alternatives considered are:
o Alternative 1—No action
o Alternative 2—Excavation and offsite disposal in an approved
RCRA landfill
o Alternative 3°-Excavation and onsite disposal in an approved
RCRA landfill
o Alternative 4—Excavation and onsite incineration of waste and
contaminated soil
In addition, Alternatives 2, 3, and 4 include the extraction and
treatment of ground water. Treatment will consist of precipitation and
air stripping.
As documented in the table, the Federal MCL of 5 ppb will be achieved by
air stripping psrior to reinjection into the ground water for TCE and
benzene for each alternative. Similarly, the federal MCL of 10 ppb for
cadmiusi will foe achieved by the precipitation treatment.. The State
ground-'wstes standard of 5 ppb will not be met, however, for any of the
alternatives. Because of the characteristics of the ground water, this
level cannot be met using available technologies; therefore, a technical
infeasibility waiver is anticipated. In addition, none of the action
alternatives will directly address the surface water; consequently, a
waiver may also be required.
Each of the action- and location-specific alternatives are listed and
compliance is documented under the alternatives for which they apply.
Both State and Federal requirements are listed, and the component of the
alternative that the requirement addresses is documented.
WDR303/043
D-2
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