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

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                               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.

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                 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;

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      -  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

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      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

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            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.

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      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.

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           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

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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.

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         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:

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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)














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