United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
EPA
DIRECTIVE NUMBER:
9200.3-10
TITLE:
In-House Remedial Investigation and Feasibility Study (RI/FS)
Initiative (Superfund Management Review: Recownendation 45.82}
APPROVAL DATE: 08/01/90
EFFECTIVE DATE: 08/01/90 f
ORIGINATING OFFICE:
El FINAL
D DRAFT
LEVEL OF DRAFT
n A — Signed by AA or DAA
d B — Signed by Office Director
n C — Review & Comment
REFERENCE (other documents):
OSWER OSWER
DIRECTIVE DIRECTIVE
-------
jmted States environmental Protection Agency
Washington. DC 20460
OSWER Directive initiation Request
1 Directive S'.r
9200.3-10
2. Originator Information
Nwne of Contact Person
Super fund Document
Coordinator
Mail Code
OS-245
Office
OERR
.Telephone Code
I (202) 260-9760
3. Title
in-House Remedial Investigation and Feasibility Study (RI/FS) Initiative (Superfund Management Review:
Recommendation 45.82)
4. Summary of Directive (include bnef statement of purpose)
This directive has been prepared to calrify the overall objectives and expectations of the in-house RI/FS
initiative and to provide general guidelines for implementing these events. In addition.
3
RI/FS initiative, implementing.
6« Does This Directive Supersede Previous Directives?
b Does it Supplement.Previous Oir*ctive(s)?
Yes What directive (number, title)
Yes What directive (number, title)
7 Draft level
A - Signed by AA/OAA
8 •- Signed by Office Director
C - For Review & Comment
i 0 - in Development
8.
Document
to
be
distributed
to
States by Headquarters?
X
Yes
' No
This fl«qu««t M««u OSWER Ote«ctlv«« System Format Standards.
9. Signature oUtead Office Directives Coordinator
Date
10. Name and Title of Approving
..._ Henry L. Longest II, Director / Office of Emergency and Remedial Response
Date
08/01/90
EPA Form 1313-17 (H«v. S-*7) Previous editions are oosolete.
OSWER OSWER OSWER O
VE DIRECTIVE DIRECTIVE DIRECTIVE.
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE
OSWER Directive 9200.3-10
MEMORANDUM
SUBJECT: In-House Remedial Investigation and Feasibility Study (RI/FS) Initiative
(Superfund Management Review: Reconfmendation 45.B.2)
FROM: Henry L. Longest II, Director
/ Office of Emergency and Remedial/ Response
TO: Directors, Waste Management Division
Regions I, IV, V, VII, VIII
Director, Emergency and Remedial Response Division, Region II
Directors, Hazardous Waste Management Division, Regions III, VI
Director, Toxic and Waste Management Division, Region IX
Director, Hazardous Waste Division, Region X
Purpose: This Directive has been prepared to clarify the overall objectives and
expectations of the in-house RI/FS initiative and to provide general guidelines for
implementing these events. In addition, I am requesting your assistance in an evaluation
of the in-house RI/FS project.
Background: One recommendation of the Superfund Management Review was
to promote in-house RI/FSs in all Regions (Regions IV and VI have already completed
in-house RI/FS, other Regions have projects underway). During the current fiscal year
SCAP negotiations, in-house RI/FS targets were established for each Region. As part
of the those negotiations, it was agreed that each in-house RI/FS would receive 150% of
the normal FTE and as much as $400,000, primarily for contractor drilling support and
other tasks that cannot be performed in-house.
Objective: Specific objectives of the initiative are to provide training that will
lead to the reduction of RI/FS costs and to improve the training of junior RPMs by:
- providing on-the-job training in the technical, field requirements of RI/FSs;
- improving RPMs' ability to gauge the level of activity required for a RI/FS
and experience in developing independent government cost estimates;
-------
- generally mitigating the frustration often associated with initial RPM
experience; and
- helping the new RPM to develop the independence and confidence needed to
deal with contractors.
The intent is to highlight and encourage greater use of the full range of resources
that are available to each Region, in contrast to the current heavy reliance on contractor
services. (In situations where contractors are used, Regions are encouraged to utilize
existing ARCs contractors whenever appropriate.)
Implementation: The in-house RI/FS concept is fairly new, but it is already
apparent that there are two distinct approaches being used:
(1) Have a seasoned RPM manage the project and perform many of the tasks
which, for other RI/FSs, are routinely contracted out. This approach is
appropriate when the principal objective of the in-house RI/FS is to contain
costs or ensure quality at a particular site.
(2) Establish an RPM team (e.g., 1 seasoned RPM and 2-5 junior RPMs) to
perform most of the required tasks. By matching new and experienced
RPMs on the same RI/FS, this approach ensures reasonable cost control
and quality (as above) and also provides newer RPMs with much needed
hands-on experience. With experience, newer RPMs will develop cost
control expertise that will continue to be useful in the supervision of
contractors.
The general theme is the same for either approach. Non-contractor resources
should be used to accomplish most, if not all, of the 14 standardized RI/FS tasks (see
Appendix B of the Guidance for Conducting Remedial Investigations and Feasibility
Studies Under CERCLA. OSWER Directive 9355.3-01, October 1988 for a description
of each of the tasks). Initial project planning should assume that the RPM team (the
RPM or RPMs assigned to perform the in-house RI/FS) will be directly involved in
every task. As planning progresses, the Region is responsible for determining what mix
of available resources (contractor and non-contractor) is most appropriate for particular
tasks. The following guidelines are intended to be illustrative and not to inhibit the use
of other resources which may be available to particular Regions.
(1) Project Planning - RPMs should either develop all workplans or participate
extensively with those who do, including the determination as to which
subsequent actions will be required during the RI/FS and the extent to
which the RPM team will be involved in each. A technical advisory team
can be utilized to provide the necessary expertise as to which particular
tasks should involve contractor support.
(2) Community Relations - The RPM team will need to work with the
designated community relations coordinator to ensure that community
-------
relations activities (e.g., public meetings, preparation of fact sheets) are
conducted.
(3) Field Investigation - RPMs will need to identify qualified non-contractor
resources to assist with the subtasks that require additional technical
support, and utilize their services in a manner which maximizes the
exposure/involvement of junior RPMs on the team. Potential approaches
that may be utilized to conduct specific subtasks are provide below:
- Procurement of Subcontracts and Site Mobilization - RPMs assisted by
Regional administrative staff (e.g., contract specialists) and service
vendors (e.g., ARCs contractors);
- Site Survey/Topographic Mapping - RPMs with assistance from
EMSL-Las Vegas, USGS, EPIC, NOAA, local surveyors, etc.;
- Site Sampling - RPMs with assistance from BSD;
- Drilling - Generally ARCs contractors with RPM involvement to the
extent practical;
- Investigation of Site Geology/Hydrology - RPMs with assistance from
in-house technical specialist, BSD, FIT, USGS, Bureau of Mines, ARCs,
etc.;
- Procurement of Subcontractors - RPMs with assistance from
administrative staff;
- Task Management and Data Quality Control - RPMs with assistance
from ESD, SMO, other lab services, etc.
(4) Sample Analysis/Validation - RPMs can accomplish much of the work
with supervision/assistance from qualified technical support (e.g., ESD,
in-house chemists).
(5) Data Evaluation - RPMs can accomplish much of the work with
supervision/assistance from qualified technical support (e.g., ESD,
Regional scientists and statisticians).
(6) Assessments of Risks - RPMs can accomplish much of the work with
supervision/assistance from qualified technical support (e.g., Regional
lexicologists, scientist in ORD, HQ staff in the Toxics Integration Branch,
ATSDR).
(7) Treatability Study/Pilot Testing - RPMs, working with qualified technical
support (e.g., ORD, START teams) and existing technology data bases
(e.g., ATTIC) can identify and specify what studies/testing are required
-------
and, can arrange to have studies conducted through ARCS contractors,
ORD-Cincinnati, BOM/USACE, or others, as appropriate.
(8) Remedial Investigation Reports - RPMs can draft these reports with the
assistance and input/review by the individuals involved in the collection
and analysis of site data.
(9) Remedial Alternatives Development/Screening - RPMs can conduct the
necessary technology screenings and alternative development with the
assistance and input of appropriate technical staff, experienced RPMs
familiar with similar site problems and approaches taken at other sites,
and expertise from outside agencies, (e.g., the Bureau of Mines) as
appropriate.
(10) Detailed Analysis of Remedial Alternatives - RPMs can conduct this
analysis with the assistance and input of the appropriate technical start
identified under the preceding task.
(11) Feasibility Study Reports - RPMs can draft these documents with
assistance from appropriate technical support staff.
(12) Post RI/FS Support - RPMs should be able to handle the majority of work
to develop any necessary management briefings, the proposed plan, and
the Record of Decision. RPMs can call on other technical and legal
support (e.g., the Regional Counsel) as necessary.
(13) Enforcement Support - RPMs in conjunction with enforcement support
staff (consistent with Regional organization).
(14) Miscellaneous Support - RPMs would be expected to handle any of the
tasks that may fall under this task.
Special Considerations: Staffing - As mentioned above, an allocation of 150% of
the normal FTE has been set for each in-house RI/FS. In those instances where a
multi-person team is used the experienced RPM(s) serves as group leader and mentor,
and will be expected to:
- help organize a technical advisory group and identify other potential resource
support;
- help define the scope of the study, including the specific tasks that must be
conducted; and
- review the various reports and documents that are prepared over the course of
the study.
-------
In addition to keeping the project on track, the mentor should ensure that each
team member is exposed to as many RI/FS activities as possible, and that the project is
successful both as a well conducted investigation and as a learning experience.
Management Review - For a conventional RI/FS, the bulk of the work is done by
contractors while the RPM and internal contractor management share responsibility for
project quality and schedule. For an in-house RI/FS, Regional management should
assume responsibility for ensuring that a quality job is accomplished within a reasonable
time.
Site Selection - Selecting an appropriate site for an in-house RI/FS will increase
the probability of successfully completing a project and meeting the objectives of this
initiative. As a general rule, smaller, less complex sites should be chosen. At the same
time, sites should be complex enough that a wide assortment of RI/FS tasks/skills (e.g.,
limited drilling, sampling, etc.) will be required as part of the study. A second important
consideration is the proximity of the site to the Regional office. Travel costs could
become prohibitive if a site is difficult to get to and a multi-person team is involved.
Lastly, selecting sites for which the Region has previous experience (one or more OUs
at the same site or other similar sites) may allow for a more streamlined and focussed
study. This is especially true where a good RI/FS report is available to serve as a
model and the individuals responsible for managing those projects are available for
consultation.
Evaluation: Attached to this memorandum is an evaluation form. The form has
been prepared as part of an effort to evaluate the in-house RI/FS experience. I ask that
you use this form keep us informed about your experience with in-house RI/FS projects.
Your cooperation in this evaluation will assist us in determining whether the objectives
of the in-house RI/FS initiative are being met and to share experience across Regions.
Your commentary will also help determine whether to continue this effort on a limited
basis, to expand the number of RI/FSs involved or, perhaps, to discontinue it entirely.
For all in-house RI/FSs that are currently in progress, please submit a completed
questionaire by August 31, 1990. Please retain a copy of the questionaire, we will
probably want to do a follow-up survey at some point in the future. Responses should
be sent to Chad Littleton at:
U.S. EPA
401 M Street, SW
Washington, DC 20460
Mail Code OS-240
Conclusion: The principal objectives of the in-house RI/FS initiative are to
provide a high quality comprehensive learning experience for RPMs and to reduce
RI/FS costs. I believe this initiative can significantly improve the ability of new RPMs
to scope and cost a study, evaluate contractor proposals to conduct such studies, and
manage the study over time.
-------
Should you have any questions concerning the implementation of this initiative,
please contact Chad Littleton (FTS 475-7294) in the Office of Program Management or
Steve Golian (FTS 475-9750) in the Hazardous Site Control Division.
Attachment
cc: Regional Superfund Branch Chiefs
Regional Superfund Section Chiefs
7
-------
NOTE
SUBJECT: Inclusion of Evaluation Form
TO: Tom Sheckells
FROM: Chad Littleton
I have included the evaluation form, and appropriate language, in this memo, but
I am concerned about introducing it at this time.
I fully agree with the idea of collecting information as we move through tasks
such as this. I have been promoting the collection of similarly informative data about
other (existing) parts of the program until both you and Terry are tired of hearing about
it.
My concern relates more to timing. I think that the most appropriate time to
collect this information will be at the end of the activity. Only at the end of the RI/FS
will the respondent be able to answer all of the questions. Collecting these forms any
earlier will necessitate a requirement that they be submitted again at the end of the
RI/FS, if we want to get the full and accurate picture. If experience is any teacher, the
answers received on the initial submission will be altogether different than those on the
second.
If you agree that it would be more useful to collect the desired information at the
end of the RI/FS, I suggest that the memo be revised. The questionnaire can still be
attached but the language should only indicate that such a questionnaire will be required
when the RI/FS is completed. Doing this also gives us time to make sure that we have
identified all of the right questions.
The down-side of this suggestion is that we would not get any information for
approximately one year, and then it would come in only as RI/FSs are completed. I
don't think this is a problem if we are comfortable that the in-house RI/FS is a good
idea that will be around for awhile. If we are already having doubts about the idea,
maybe we should take another (quick) hard look at what we are asking before we go
formal.
-------
IN-HOUSE RI/FS PROJECT EVALUATION FORM
Site Name:
EPA ID: _
Lead RPM Name:
RI/FS Team:
Senior Member(s)
Other Member(s)
Other Federal Resources: (AH outside Waste Management Division)
Contractor Resources:
Description Cost ($000)
2.
J.
4.
5.
Scope of Initial Study:
Successes/Positive Experiences:
Major Difficulties:
-------
IN-HOUSE RI/F5 PROJECT EVALUATION FORM - Page 2 of 2
Cost of 14 Standard Tasks
STANDARD TASK
2. Community Relations
J, Field Investigation
4. Sample Analysis/Validation
5. Data Evaluation
6. Assessments of Risks
7. Treatability Study/Pilot Testing
8. Remedial Investigation Reports
9. Remedial Alternatives Development/Screening
10. Detailed Analysis of Remedial Alternatives
1 1. Feasibility Study Reports
12. Post RI/FS Support
13. Enforcement Support
14. Miscellaneous Support
FTE
COST
($000)
COMPLETE?
(Y/N)
------- |