oEPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER: 9355.3-05
; RI/FS Improvement's Phase 11, Stream! in ing
Recomendatiolis
APPROVAL DATE: 1/89
EFFECTIVE DATE: 1/39
2/14/89
ORIGINATING OFFICE:
G FINAL
C DRAFT
STATUS:
OEPR/HSCI
REFERENCE (other document*):
A- Pending OMB approval
B- Pending AA-OSWER approval
For review &/or comment
' - In development or circulating
headquarters
OSWER OSWER OSWER
VE DIRECTIVE DIRECTIVE Dl
-------
United States environmental Pf-stection Agency
Washington. OC 20460
OSWER Directive Initiation Request
. irective Numoer
9355.3-06
2. Originator information
Name of Contact Person
Victoria VanRoden
Mail Coae iOMice
os-220 IHSCD
Teiepnore Cooe
Title
RI/FS Improvements Phase II, Streamlining Recommendations
^••••••^^^^^^.^^^___^_^^__^_—_
>4. Summary o( Directive (include onet statement ot purpose) •
Presents second set of recommendations for streamlining measures that will
reduce the cost and duration of RI/FS's. Recommendations.include those
related to technical issues, procurement enhancement, project management,
State coordination and enforcement.
[5V Keywords Superfurd, CERCLA, SARA
be. Uoes mu Directrve Supersede Previous Directives?
b. Does It Supplement Previous Oirective(s)?
No.
No
Yes What directive (number, title)
Yea What directive (number, title)
_Qraft Level
A - Signed by AA/OAA
8 - Signed by Office Director
C - For Review ft Comment
0-ln
8. Document to be distributed to States by Headquarters?
X
Yes
No I
This Request M««U OSWER Directives System Format Standards.
9. Signature ol Lead Office Directives Coordinate^? / ^_
BEtti C. VanEpps y^S^i; C^-^-^^-^<^^-
10. Name and Tide ol Approving Official
Henry L. Longest II, Dir.
i/ '
OERR and Bruce Diamond, Dir. OWI
Date
2/14/89
Date
>E 2/14/89
EPA Form 1315-17 (Rev. 5-87) Previous editions are oosoiete.
OSWER OSWER OSWER 0
VE DIRECTIVE DIRECTIVE DIRECTIVE
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UNITED STATES ENVIRONMENT AL PROTECTION AGENCY
. WASHINGTON. D.C. 20460
FEBI48
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FROM:
SUBJECT:
Bruce M. Diamond, Direct
Office of Waste Programs E
TO:
Waste Management Division Directors
Regions I - X
Purpose
The purpose of this memorandum is to bring to your attention
the second set of recommendations for streamlining measures that
will reduce the cost and duration of RI/FS's.
Backqround
Two related projects, the RI/FS Cost Study and the attached
RI/FS Improvements Phase II Streamlining Recommendations, have
been completed recently. Together they address measures to
achieve the national goal of an RI/FS which takes 18 months on
average and typically costs no more than $750,000 per operable
unit and $1.1 million per site. The Cost Study results were sent
to you on October 29, 1988. Included were trends in rising RI/FS
costs, contributing factors, and management tools being developed
to help bring costs down.
The RI/PS Improvements Phase II built on earlier work. Phase
I, a management forum held last January, produced a set of
immediately available streamlining measures. These were
contained in an April 25, 1988 memorandum. Phase II combined
the efforts of five Regional and Headquarters workgroups which
focused on Procurement, Program Management, Technical
Considerations, State Involvement, and Enforcement. Attached are
a set of recommendations forwarded to us by the RI/FS
Streamlining Steering Committee. Incluqed is an example
application of the "Streamlined Approach" based on the
Observational Method used in the geotechnical engineering field.
We endorse the use of this approach for dealing with uncertainty
in subsurface work, providing there are no site- specific
enforcement concerns.
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2
The Cost Study and Streamlining Project results have been
combined to form a joint set of recommendations. Not
surprisingly, several steps we can take to cut back schedule
demands also lower costs. Measures already referred to in the
Cost Study, such as the use of standardized elements in RI/FS
wor~ pla~s, a greater reli3~ce on i~-~oc~~ st~f~ t~ scope and
.fo:us worK p:~~nl~g, and t~e lnc:eased etficiency o~fared through
A~CS, ca~ save both money and ti~e.
Objective
Even though some of these suggested actions continue to be
discussed and evaluated, others may be considered for immediate
implementation. Several recommendations require further work by
joint Headquarters and Regional teams, but other recommendations
are for actions that you can take now. Below, we highlight a
number of these.
Imp lementation
CONTRACTING AND PROCUREMENT
o
Delegating work plan approval to Regional Project
Officers
Once the Contract Officer has approved the work scope
and overall funding for a complete project, the authority
to approve workplans not affecting total costs will be
delegated to Remedial Project Managers. This
recommendation will be incorporated into the forthcoming
ARCS Contracts Users' Manual. Regions should prepare now
to institute this authority.
o
Granting authority for direct subcontracting to ARCS
and REM Contractors
Following successful completion of a Contract
Procurement System Review Audit, each REM and ARCS
contractor will be granted authority to directly approve
subcontracts up to $250,000. HSCD/OSWER will work with
PCHD/OARM to schedule audits based on contractors having
the greatest national workload.
o
Incorporating cost evaluation criteria, cost controls,
and cost standards into ARCS management
The RI/FS Cost Study found that increased emphasis on
cost management through cost reporting by contractors
will lead to the development of cost planning criteria
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3
and enhanced ability to influence pricing at project
planning stages. During the coming year, OPM/OERR and
HSCD/OERR will work with the regions to:
emphasize cost controls and reporting in ARCS
performance reviews,
carry ~ut work de~eloping tre~ds and rules-o~-:hurnb
leading to e'/entual ccst crlter:a, and
build cost control measures into RI/FS Guidance and
train in.; .
PROGRAM MANAGEMENT AND ENFORCEMENT
o
Inplernenting the "Streamlined Approach"
This approach is defined by exanple in the enclosed
cas~ study. Extending past practice under the bias-
for-action, it encourages early identification of that
part of the site where remedial action can begin
quickly. It also encourages the adoption of flexible
remedies which can be adjusted during design and
construction based on actual site conditions encountered
in the field. The underlying assumption is that
complete characterization during the RI/FS is not
feasible or cost effective. Therefore, the streamlined
approach initiates action where the remedy is clear, the
full extent of contamination can be determined while
underway, and other concerns do not preclude this'
approach. In the application of this approach, work on
project scoping, project planning and project approvals
should correspondingly be reduced in depth and detail.
Regional staff should evaluate site specific
circumstances, including enforcement concerns, to
determine the amount of data needed to support remedy
selection and implementation. Both OWPE and OERR will
work closely with the Regions over the coming year in
applying this approach. Regions should review their
sites with planned or recent RI/FS starts for the use of
this approach.
o
Use of RODs which include Contingency Remedies in
Select Cases.
Ordinarily, the Agency identifies a preferred
alternative in the Proposed Plan and selects a single
remedy in the ROD. Generally, a treatment class should
be selected instead of a specific technology
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4
process option. For example, RODs should select
thermal destruction, instead of specifying rotary kiln
incineration and thereby provide flexibility to
implement more than one thermal destruction process.
It will not always be practicable to conduct sufficient
testing during the RI/FS to address the uncertainties
a~~:~ci~re~ wi~~ ~ t~:~~01c~'/ t~at ~Ql~s cre~~ Dr2~~5e
(.=. ,- ; -,., 0 .. ~ t" ,,;::; ') - .., ,~ ~ 'J :.;;' - - &. C r to 'n Q , , n' ~ e r .. '" _1' 1"1 t" . r
... . .: ., ..'.. l" ..1. V ,.:.:, - - ~ .. 1.'"", ..... .'\. \... ....~. - ~ .. ... ~ '.- i..oi. ..... - ~ -:::I l.. - 1 ,
appears to provije th~ best balance of t~ade-cf!3 with
respect to the nine criteri3. In these situations where
additional testing during remedial design will be
necessary to verify the performance of the preferred
technology, a ROD may be signed that selects that
technplogy but also provides a backup remedy. The ROD
would contain a complete analysis of ,both remedies, and
would show how the primary remedy provides the best
balance, except for the uncertainty associated with that
remedy, and how the backup remedy would provide the best
balance if the primary remedy does not achieve its
goals.
In limited situations, the Agency will select a remedy
from several treatment technologies which appear to be
comparable with respect to the nine criteria. The
comparable technology(ies) may be included in the ROD
as contingency remedies, and implemented if one of them
emerges as more cost-effective or practicable than the
selected remedy as a result of negotiations with PRPs.
In order to implement any contingency remedy, an
explanation of any signific3nt difference between the
remedies needs to be provided to the public. Further
details on policy and procedures associated with these
types of RODs will be available in the "ROD Guidance" to
be completed this winter.
TOOLS AND TECHNICAL SUPPORT
o
Standardizinq Quality Assurance pro;ect Planninq
Documents
With the increased availability and use of field
screening methods, the need for standardized Regional
QAPjP documents to speed site work planning reemerges.
Regional Superfund program staff should continue working
closely with their Environmental Service Division
counterparts during the Remedial Investigation scoping
to incorporate standard QAPjP items wherever possible.
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5
'A workgroup of Headquarters and Regional staff will
supplement current QAPjP guidance with supporting QA
materials for non-CLP analyses. One tool that was
recently distributed is the Field Screening Methods
Catalog.
o
Hcldinq Re3ionell~ spo~sored, Hea~~uarter3 s~pported
tech~l:al meetln~s and ~ork5nops
On a quarterly or semi-annual basis, meetings covering
subjects selected by the Regions for the Regions, and
including State and contractor participation, will be
held to foster technology transfer, exchange of lessons
learned, and elevation of problems needing national
program attention. Headquarters will provide
administrative and facilities Support for these meetings
which will be rotated among the Regions. The first
meeting is planned for the second quarter of FY89.
The attached management summaries of recommended actions
include other steps we can take toward our goal of having an
RI/FS process that takes 18 months and costs $759,999 on average.
These recommendations will be the subject of discussions at
upcoming Division Director and Branch Chief meetings. In the
interim, we invite your comments and suggestions.. Work to
streamline the RI/FS process and reduce costs will require our
focused management attention over the coming year.' These
recommendations give us a good place to start.
Attachment
cc:
J. Winston Porter
Jon Cannon
David O'Connor
Betti Van Epps
Superfund Branch Chiefs
ESD Division Directors
OERR Division Directors
OWPE Division Directors
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OSHER DIR. 9355.3-06
RIfFS IMPROVEMENTS
, . '" .,~". """"".; ._i.: ~.
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PHASE II
STREAMLINING RECOMMENDATIONS
Office of Emergency and Remedial Response
Hazardous Site Control Division
January 1989
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OSWER Directive 9355.3-06
INTRODUCTION
The RI/FS improvements initiatives process began with the
issuance of the July 22, 1987 OSWER Directive 9355.0-20
entitled "RI/FS Improvements". Continuing guidance was
issued to the Regions in the April 25, 1988 OSWER Directive
entitled "RI/FS Improvements Follow-up".
Since that time work has continued regarding the development
of recommendations that could help streamline the RI/FS
process. Six workgroups were formed which were charged with
analyzing various portions of the RI/FS process and
developing solutions to identified problems. The workgroups
addressed the following subjects; 1) Technical issues, 2)
Procurement issues, 3) Program management issues, 4)
Enforcement issues, and 5) State issues. These workgroups
were composed of Regional, Headquarters, State, Federal
Facility, and contractor staff.
A Steering Committee composed of Regional and Headquarters
management also was formed to oversee each workgroup's
activities and provide a Quality Assurance (QA) function.
The committee also developed additional implementation
options to the issues identified by the workgroups.
Attached are a number of recommendations/implementation
options which are the culmination of the workgroups' and
Steering Committee's activities. The recommendations are
listed ~elow:
Technical
o Institute Regional Remedial Contractor Training
o Better Utilize Pre-remedial Data During RI
Scoping
o Make QA Requirements Consistent and Consolidate
Documents Whenever Possible
Procurement
o Delegate Work Plan Approval to Regional Project
Officers
o Grant Authority to REM/ARCS Contractors to
Directly Approve Subcontracts
o Establish Separate Regional Analytical Services
Accounts
o Develop Source Lists for Subcontractors
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OSWER Directive 9355.3-06
Project Manaaement
o Implement the Streamlined Approach.
o Conduct Technical Meetings/Workshops
State
o Improve Training and Technology Transfer
Mechanisms for RPMs
o Use Generic Documents and Core of "Expert"
Reviewers to Expedite Document Production and
Review
Enforcement
o Provide Training to RPMs on RP Oversight and
Interaction
o Initiate New PRP Searches with SOWs Specific to
Site Type .
o Use RODs which Include Contingency Remedies in
Select Cases .
Because of their similarity, the State recommendations
have been combined with recommendations of the Technical and
Program Management workgroups.
2
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OSWER Directive 9355.3-06
A CASE STUDY
THE STREAMLINED APPROACH
INTRODUCTION
EPA, in its search to improve the RIfFS process, is
reviewing a number of possible initiatives. One effort has
involved the formulation of an example of how the inherent
flexibility in the traditional RIfFS process can be maxi-
mized to accomplish more effective, efficient studies. This
example is described as the "Streamlined Approach" in the
case study that follows. The discussion highlights how the
RIfFS process as it traditionally has been practiced can be
modified to reach remedy selection decisions sooner and to
expedite remedial action implementation. The approach also
emphasizes the development of flexible remedies that can be
"fine-tuned" during implementation. .
The intention of this study, and discussion generated from
it, is to determine the applicability of the Streamlined
Approach to Superfund sites and to assess the potential of .
this method to improve the quality, schedule and/or cost of
the RI/FS process. While this particular example represents
a specific approach that is still conceptual in nature, it
should be noted that this technique is fully consistent with
the framework established in the revised "Guidance for Con-
ducting Remedial Investigations and Feasibility Studies under
CERCLA" (Draft March 1988) and the forthcoming National Con-
tingency Plan proposal. This particular approach to stream-
lining is beginning to be piloted informally in some Regions
and States.
STREAMLINED APPROACH
When looking at the remedial process as a whole it has become
apparent that the process has become "bottlenecked" by the
uncertainties associated with fully understanding the nature
of hazardous waste problems. Many of us have mistakenly
assumed that the hazardous waste engineering practice can be
conducted just like conventional engineering. That is, we
have assumed that uncertainties are effectively reduced to
manageable levels during the RI/FS phase, thereby allowing
the design and implementation phases to proceed routinely.
This has not been proven to be the case for many sites as
new information discovered during design and implementation
has forced significant alterations in planned remedies.
This example of a streamlined approach paral~els a method
which was developed by the geotechnical engineering disci-
pline about 40 years ago to deal with the uncertainty of the
1
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OSWER Directive 9355.3-Qt
subsurface environment.l It reflects a recognition that no
reasonable amount of subsurface exploration can resolve all
uncertainty and that remedial actions developed as part of
the method must accommodate surprises or "deviations" from
the original hypothesis.
Traditionally, uncertainties have inspired intensive and
lengthy efforts to find the sources of contamination and to
definitively characterize sites. The streamlined approach
recognizes that removal of all uncertainties is usually not
feasible and focuses instead on only collecting sufficient
data to generally characterize a site and support remedy
selection. The resulting remedies are flexible and incor-
porate specific contingencies to respond to new information
discovered during remedial action.
The case study which follows will propose an approach to
recognize and address this uncertainty while proceeding
toward the ultimate goal of site clean-up. It is important
to note that this approach may not be appropriate for all
problems at all sites.
CASE STUDY
This case study presents how the Superfund remedial process
would be conducted in a streamlined manner at the hypotheti-
cal Otis Recycling Superfund site. The case study is organ-
ized into the following sections:
o
o
o
o
o
o
o
Background
Scoping
Phase I remedial investigation
Feasibility study
Record of decision
Remedial design
Remedial action
BACKGROUND
The Otis Recycling site is about 1.5 miles northwest of the
town of Goddard and 0.5 miles north of the Hilton Hills
Ipeck, R. B., Advantaqes and Limitations of the Observational
Method in Applied Soil Mechanics, Ninth Rankine Lecture,
The Institute of Civil Engineers, Thomas Telford, Ltd.,
Edinburgh, 1975.
2
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OSWER Directive 9355.3-06
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OTIS RECYCLING CORPORATION
. OTIS DITCH
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COUNTY RD 89
LOCAL -
GROUNDWATER
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400'
/
HILTON HILLS SUBDIVISION
...................
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FIGURE 2
OTIS RECYCLING CORPORATION
OVERVIEW SITE PLAN
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DRUMS (100)
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BOILER ROOM
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DISTILLING
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LOADING
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OSWER Directive 9355.3-0l
IN
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en
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FIGURE 3
OTIS RECYCLING CORPORATION
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OSWER Directive 9355.3-0t
subdivision, as shown in Figure 1. The Goddard County Airport
is 0.5 miles northwest of the site, and land use in the vicin-
ity of the site is agricultural. The eastern boundary of
the site abuts Otis Ditch, which flows southeast and joins
Matuka Creek 0.2 miles south of the site. Matuka Creek dis-
charges into Wooly Run which in turn discharges to the Wulff
River, as shown in Figure 2.
The site is located on 10 acres and contains a drum storage
area, a drum crushing pad, a distilling house, and a loading
dock, as shown in Figure 3. Drums were removed from the stor-
age area by the emergency response cleanup services (ERCS)
contractor.
The site was operated as a solvent distillation facility and
a waste oil recycling facility from 1967 to 1982. Historical
aerial photographs of the site suggested that a large number
of drums was stored at the storage area throughout the entire
history of the site. The photos also showed that some soil
had been discolored because of spills.
The geology at the site consists of 80 feet of unconsoli-
dated glacial sediments overlying shale bedrock. The over-
burden is divided into an upper and lower aquifer by a
discontinuous, semi-confining silty clay layer. The shallow
aquifer consists of 20 to 40 feet of sandy outwash while the
deeper, or lower, aquifer consists of 10 to 30 feet of sand
and gravel. The top of the water table is 6 to 8 feet below
ground surface, and flow is generally to the southeast.
However, the direction of flow appears to change seasonally,
and the variability of the direction of flow was not deter-
mined. The shale bedrock is of very low permeability and
was not considered an aquifer. Soil at the site consists
primarily of sandy glacial tills. The average yearly rain-
fall at the site is 35 inches.
Private water wells at the Hilton Hills Subdivision were
screened in both the upper and lower aquifers. The toWn of
Goddard used the lower aquifer as well as surface water from
the Wulff River for its drinking water supply. Welis in the
subdivision were not contaminated, and residences were not
on an alternate water supply system.
Groundwater sampled during the field investigation team
(FIT) study was found to be contaminated with volatile
organic compounds (VOCs), with one well containing a total
VOC concentration of 1,100 ppb. Soil at the site was found
to be contaminated with VOCs and polycyclic aromatic hydro-
carbons (PAHs). Concentrations of total VOCs in the soil
were as high as 10,000 ppb, and total PAHs were as high
as 30,000 ppb. The FIT sampling appeared to delineate the
VOC contamination in some detail.
3
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OSWER.Directive
9355.3-(
Goddard
Cctunty
Alrpon
OilS \l
Recycling Y
Corporation .
.
Otis
Dttch
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Light Industr; l
Town of Goddard - 1-
--
Business District
Figure 1
OTIS RECYCLING CO
VICINITY MAP RPORATION
..-
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SCOP!NG
OSWER Directive 9355.3-06
During scoping, the following activities were considered:
o
Collecting and analyzing existing data to develop
a conceptual site model 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 recep-
tors
o
Initiating limited field investigations if avail-
able data are inadequate to develop a conceptual
site model and adequately scope the project
Identifying the potential remedial action objec- .
t~ves and likely remedial action alternatives for
the specific project
o
o
Identifying the need and the schedule for treatabil-
ity studies to better screen and define potential
remedial alternatives
o
Preliminarily identifying the ARARs expected to
apply to 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 ana-
lytical options. (This selection is documented in
the SAP, which consists of the FSP and QAPP ele-
ments. )
o
Developing a work plan that documents the scoping
process and presents anticipated future tasks
o
Identifying and documenting health and safety pro-
tocols required during field investigations and
preparing a site health and safety plan
o
Conducting community interviews to obtain informa-
tion that can be used to develop a site-specific
community relations plan that documents the objec-
tives and approaches of the community relations
progr am
During the streamlining process, these activities were
scaled down and, in some cases, omitted in order to save
4
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OSWER Directive 9355.3-06
time and encourage earlier data collection. In this case,
limited field investigations and treatability studies were
determined to be unnecessary and were not performed during
scoping. .
Highlights of some scoping activities that were completed
are discussed in the following sections.
Review of Existing Data
During scoping the following existing data were reviewed and
summarized:
o.
FIT report
o
u.s. Geological Survey (USGS) and state publica-
tions
o
Soil Conservation Service (SCS) soil survey
o
Topographic maps
o
State files
o
Residential and municipal well logs
o
Historic aerial photographs
o
Log of site visit
Site Conceptual Model
On the basis of the existing data, a site conceptual model
was developed, which is as follows: The soil is contaminat-
ed with VOCs and PAHs, which occur throughout the site. The
highest concentrations of chemicals are expected in the vicin-
ity of the distilling house and in the former drum storage
area. However, the site is much larger than these two areas,
and past site activities beyond these areas are unknown.
The possibility of very high concentrations (hotspots) of
VOCs and other contaminants is high in both the lateral and
vertical directions. In some areas, VOC contamination extends
beyond the unsaturated zone to the water table. Thus, the
shallow aquifer is contaminated with VOCs.
An initial hypothesis is developed that identifies soil vapor
extraction as a promising alternative. This hypothesis is
developed after evaluation of the existing data (which indi-
cates VOCs in soils may be limited in extent of contamina-
tion) and also relying on previous program experience.
A hypothesis is also developed :or the groundwater scenario.
This hypothesis calls for a pump and treat system as a
5
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05WER Directive 9355.3-06
promising alternative. A hypothesis is not able to be devel-
oped, at this time, for the non-volatile soils contamination
due to a lack of sufficient data.
General Response Actions
Using the existing site information and the site conceptual
model, general response actions were evaluated. This was
done to ensure that potential location-specific and action-
specific ARARs would be identified and that the data needed
to select a remedial alternative would be collected. The
alternatives that could potentially be implemented at the
site were considered for development, and are listed below
for soil and ground water:
o
50il
No action (natural attenuation)
In situ treatment (e.g. soil vapor extraction,
biological treatment, soil washing)
Containment (e.g. grout walls/curtains, cap-
ping)
Removal and onsite treatment (e.g. inciner-
ation, composting)
Removal and offsite treatment (e.g. incinera-
tion)
Removal and offsite disposal in a RCRA land-
fill
Combination of containment and removal
o
Ground water
No action (natural attenuation)
Extraction and treatment (e.g., pumping with
air stripping
Physical and hydraulic containment of the
shallow aquifer; not applicable to the deep
'aquifer if it is also contaminated
In situ treatment was excluded for ground water because the
technology is not applicable to the wide variety and concen-
trations of contaminants found at the site.
6
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Data Needs
OSWER Directive 9355.3-0(
Data needs identified at the site during scoping are as fol-
lows:
o
Site geolo~y and stratigraphy
Site hydrogeology including aquifer and confining
layer properties, hydraulic conductivity, horizon-
tal continuity of the confining layer, flow direc-
tions and vertical and horizontal gradients,
ground-water velocities, and recharge/discharge
relations
o
o
Nature and extent of ground-water contamination
o
Nature and extent of soil contamination
o
Nature and extent of surface-water and sediment
contamination
PHASE I REMEDIAL INVESTIGATION
This section describes the objectives of the actual Phase I
RI. The field activities and the conclusions of the Phase I
RI are also described.
Objectives of the RI
The objectives of the Phase I RI are presented below:
o
Characterize the horizontal and vertical extent of
soil contamination throu~hout the entire site,
focusing in particular on the drum storage area
and the distilling house .
o
Characterize the horizontal and vertical extent of
groundwater con~amination throughout the entire
site
o
Gather enough information to complete the Feasibil-
ity Study (FS)
o
Help prove or disprove the initial hypotheses and
assist in the selection of the preferred alterna-
tive
These sampling programs are designed to gather sufficient
data to determine the qeneral extent and nature of contami-
nation. The objectives are not designed to "fully charac-
terize" the site, as has been done traditionally.
-------
OSWER Directive 9355.3-0l
Field Activities
To accomplish the objectives outline above, the following
field activities were completed for soil, surface water and
sediment, and groundwater:
o
Soil
Approximately 30 soil borings were drilled to
the top of the water table at and around the
drum storage area, distilling house, and load-
ing dock. Samples were taken from various
depths and analyzed using standard contract
laboratory program (CLP) protocols for stan-
dard routine analytical services (RAS) chemi-
cals.
A shallow soil sampling program was conducted
throughout the remaining portion of the site
(a total of 10 acres) using a grid pattern.
Fifty samples were analyzed for VOCs using
portable screening equipment. Samples that
exceeded screening criteria were submitted
for laboratory analysis along with about ten
percent of the samples with negative screen-
ing results.
Five soil samples were submitted for geotech-
nical analysis (i.e. moisture content, den-
sity, grain size, Atterberg limits).
Up to ten background subsurface and surface
soil samples were collected from off-site
areas and remote areas of the site for analy-
sis of chemical constituents.
A soil gas analysis program was conducted to
investigate for VOC hotspots.
o
Surface water and sediment
Four surface-water samples were
from both Otis Ditch and Matuka
were analyzed for RAS chemicals
protocols.
collected
Creek: they
using CLP
Four sediment samples were collected from
Otis Ditch: one was upgradient and three were
downgradient of known source areas (i.e. 'the
drum storage areas, the drum crushing pad,
and the distilling house). Also, one upgra-
dient and three downgradient samples were
8
-------
OSWER Directive 9355.3-0t
collected from Matuka Creek. They were also
analyzed for RAS chemicals using CLP proto-
cols.
o
Groundwater
A soil gas analysis program was conducted to
determine monitoring well locations.
A geophysical survey (electrical resistivity)
study was conducted to define the depth to
the clay layer and determine the lateral
extent and continuity of the clay layer.
Four well nests were installed with one well
screened in the upper portion of the shallow
aquifer, one in the lower portion of the shal-
low aquifer, and one in the deep aquifer.
Six well nests were installed with one well
screened in the upper portion of the shallow
aquifer and one in the lower portion of the
shallow aquifer.
Slug tests were conducted in each well to
determine the hydraulic conductivity of the
upper and lower aquifer.
,
Staff gauges were installed in
Matuka Creek, and Wooly Run to
discharge conditions.
Otis Ditch,
assess recharge-
Water level measurements were obtained from
all of the wells.
All monitoring and selected residential wells
were sampled using CLP protocols for standard
RAS chemicals, and selected samples were ana-
lyzed for BOD, COD, total suspended solids,
oil and grease, and alkalinity, as well.
Conclusions From The Phase I RI
The understanding of the regional geology was confirmed by
the Phase I RI activities. The ground-water flow direction
was found to be to the southeast in both aquifers. The shal-
low aquifer appears to discharge to Wooly Run except during
dry periods when it probably discharges to the Wulff River,
while Otis Creek and Mantuka Creek appear to be ground-water
recharge sources.
9
-------
OSWER Directive 9355.3-0t
The' two aquifers may be directly hydraulically connected if
the silty clay layer does not exist: otherwise, there is an
indirect connection such that the vertical gradient is gener-
ally downward. The flow rate from the upper to the lower
aquifer is estimated to be about 10 feet per year. The hori-
zontal flow rate in the shallow aquifer is estimated to be'
about 110 feet per year, while in the deep aquifer it is 200
feet per year.
The results of the Phase I RI soil sampling program were as
follows:
o
VOCs and PAHs were detected at a maximum depth of
6 feet below the surface in and near the drum stor-
age area and near the distilling house. Concentra-
tions were at or above health based levels.
o
Significant levels of lead were found throughout
the site at various depths.
o
High concentrations of VOCs were unexpectedly
detected in soil borings to the extreme north of.
the known drum storage area.
o
Low levels of pesticides were found throughout the
site at concentrations below health-based levels.
o
The results of the soil-gas program were viewed as
unreliable for assessing the distribution of on-site
soil contamination because they reflected the distri-
bution of groundwater contamination. .
The results of the Phase I RI surface-water and sediment
sampling program were that no contaminants wer.e detected in
either the surface-water samples or the sediment samples.
Therefore, no further sampling, in these media, will take
place.
The results of the Phase I RI groundwater sampling program
were as follows:
o
VOCs contaminated the shallow aquifer (above health
based levels).
o
Contaminants were detected in all the wells that
were furthest east; therefore, the eastern bound-
ary of the plume was not defined.
o
Low levels of VOCs were detected in the deep well
immediately downgradient of the distilling house.
10
-------
OSWER Directive 9355.3-0t
A risk analysis was performed that showed that the
contained soil and ground-water contaminatio~ that
risk to the public's health and welfare and to the
environment.
site
posed a
Determine Need for Additional Data
This is the point of greatest divergence with the stream-
lined approach. Traditionally, we have asked "have we fully
characterized the site yet?" Getting a "no" answer we plan
a phase II RI to fill in the data gaps. Additional data
would be collected-for soil-VOCs and groundwater.
Note that we actually only fill in the data gaps until
we are "comfortable" with our site understanding--we
neve~ really can fully characterize the site. There-
fore, some of the mindset differences with the stream-
lined approach is where the "comfort" zone is reached--
"how much is enough?"
The streamlined approach evaluates the phase I data to deter~
mine if the initial hypotheses have been tested to the point -
where action can be taken. In this case, it was concluded.
that action could be taken on two elements which are (1) the
shallow aquifer, and (2) soil volatiles. These elements are
combined into one operable unit.
For the shallow aquifer, it was determined that extraction
and treatment would be consistent with the likely long-term
remedy and would not create a condition worse than the pres-
ent. For the soil-VOCs, it was determined that, high concen-
trations of soil volatiles should be removed under any soils
remedial action because leaving mobile volatiles under a cap
should be minimized as should exposing workers and the public
to volatiles during excavation. Previous program experience
also indicated that these alternatives would be viable
options.
Dealing with the non-volatile soils was less straight for-
ward. An economic analysis (done at this stage under the
Streamlined Approach) showed that to cap the entire site
would conservatively cost about $5 million and to incinerate
just the two acres of probable PAH contamination would cost
at least $15 million (not including $2 to $4 million to cap
the remainder). However, it was concluded, based on the
selection of remedy criteria, that more evaluation (Phase II
RI) and comment would be required to reach a decision. Addi-
tionally, data collected during the SVE (which must be com-
pleted first anyway) and the groundwater extraction remedy
would aid in the decision-making process. It was also -
determined that additional data collection activities would
be required regarci~g the deep aquifer.
11
-------
OSWER Directive 9355.3-0(
The data evaluation procedure also leads to the development
of a number of reasonable deviations. These deviations are
addressed during the RI/FS and monitored for during the imple-
mentation of the remedy.
Development of Reasonable Deviations
The most probable conditions have already been discussed
(Site Conceptual Model). The most reasonable deviations to
the site conditions are presented below for soil and
ground-water:
o
Soil
VOC contamination could extend beyond currently
known areas of contamination. Only 50 samples
were analyzed for VOCs beyond the main source
areas, and use of other areas of the site for
hazardous materials handling, storage, or
disposal has not been ruled out. VOCs hot-
spots that have not been identified could be
present in the soil since only a limited num-
ber of samples were taken.
The composition of the soil could vary. This
would affect the effectiveness of several of
the general response actions, such as soil
vapor extraction.
Soil vapor extraction will vary in effective-
ness based on the volatility of the compounds.
Because the site had been a recycling facil-
ity, there could be contaminants other than
PAHs and VOCs on site that were not detected
at the sampling locations.
o
Groundwater
The lower aquifer could contain hotspots that
have not been identified.
Concentrations of pesticides could be present
in the shallow aquifer.
The VOC contaminant plume could extend beyond
the area indicated by the results of the
Phase I RI sampling.
Characteristics of the upper aquifer could
vary substantially. This would affect
jroundwater extraction effectiveness.
12
-------
OSWER Directive 9355.3-06
FEASIBILITY STUDY FOR SHALLOW GROUNDWATER AND SOIL VOCS
Upon completion of Phase I it was determined that the nature
and extent of the contamination had been adequately defined.
Applicable general response actions and technologies address-
ing the contamination were then identified. The remedial
alternatives that were developed for soil and groundwater
are listed below:
o
Soil VOCs
No action
Soil vapor extraction in the drum storage
area and the distilling house
Removal and incineration of soil
o
Groundwater
No action
Installation of an extraction well system in
the shallow aquifer and treatment of extracted
groundwater with air stripping
Continued monitoring of both the shallow and
the. deep aquifers
Each alternative or combination of alternatives was analyzed
against the nine criteria. This information was then used
to compare the alternatives and support the subsequent analy-
sis made in the remedy selection process.
RECORD OF DECISION
For the VOC contamination in soil, soil vapor extraction
(SVE) with vapor extraction wells extending to the water
table in conjunction with continued monitoring is the selec-
ted remedy because SVE is lower in risk and cost than leav-
ing the VOCs under a cap or excavating and treating them.
Remedial action to remove VOCs from soil is initiated before
selecting the remedy for soil contaminated with lead and
PAHs. While VOCs removal was being undertaken, sampling is
conducted to help determine the remedial action for the soil
contaminated with lead and PAHs.
The ROD for the removal of VOC contamination from soil would
be flexible to allow for the ad~ition or modification of the
remedial action (RA). The ROD therefore would include a
discussion of the deviations and would address the contingen-
cies to be implemented if any of the deviations were encoun-
tered. These deviations would have included the following:
13
-------
OSWER Directive 9355.3-06
o
If the composition or concentration of the VOC
contamination is different than expected, the time
frame for operating the SVE system would be modi-
fied. If the time frame for operating the system
becomes too long, the site will be covered with 6
inches of clean sand and gravel to minimize expo-
sure while continuing the SVE system.
o
If the extent of soil contamination is greater
than expected, or if the composition of the soil
causes the SVE system to be less effective than
expected, more SVE wells will be constructed.
For shallow groundwater, extraction, and air stripping treat-
ment along with continued monitoring is the selected remedy.
This remedy was chosen because it will address the know VOC
contamination. The remedy is also flexible enough to address
the reasonable deviations without major changes to the sys-
tem. The ROD would discuss the following reasonable devia-
tions and proposed alternatives:
o
If the shallow contaminant plume extends farther
than expected, extraction wells will be added or
pumping rates will be increased.
o
If VOC concentrations are
if the composition of the
to be less effective than
will be operated longer.
higher than expected, or
soil causes the system
expected, the system
o
If pesticides are detected at high concentrations
in the upper aquifer, the treatment system will be
modified to remove pesticides from the water.
o
If the lower aquifer is more heavily contaminated
than expected, additional extraction wells will be
installed in the lower aquifer.
o
If contamination is detected in monitoring wells
(i.e., if contaminants are not being captured by
the extraction system), additional wells will be
. added to the system.
REMEDIAL DESIGN
Pre-design requires a pump test to determine shallow aquifer
properties under stress. The remaining elements of the RD
are:
o
Design of the soil vapor and the groundwater extrac-
tion systems.
14
-------
OSWER Directive 9355.3-06
REMEDIAL ACTION
The SVE system and the groundwater extraction and treatment
system begin operation. As part of the on-going monitoring
program, pesticides are detected in the groundwater extrac-
tion wells. The lead agency is prepared for this situation
under this approach because this "reasonable deviation" has
been addressed ahead of time and the RPM is much more pre-
pared to respond to it in a technically sound and timely
manner.
The monitoring which takes place during the implementation
of the remedial action takes on a very important role in the
overall clean-up process. The RPM is not only reviewing
these monitoring data to ensure that the remedial action is
operating properly, but is also looking for indications of
the presence of any of the reasonable deviations.
WDR374/001
15
-------
RI/FS IMPROVEMENTS
APPENDIX
The following is a compilation of the suggested improvements
developed by the various RI/FS Improvements workgroups and a brief
summary of their implementation status. For further information 01
any recommendation! consult the RI/FS Streamlining Package or
contact Randall Kaltreider, FTS 382-4491.
Technical Workgroup
Recommendation:
Institute Regional Remedial Contractor Training
Status:
Recommendation forwarded to the Regions for
consideration/implementation; see Streamlining
package
Recommendation:
Better Utilize Pre-Remedial data during RI Scopin~
Status:
Recommendation forwarded to the Regions for
consideration/implementation; see Streamlining
package
Recommendation:
Make QA Requirements Consistent and Consolidate
Documents Whenever Possible
Status:
Recommendation forwarded to Regions for
consideration/implementation; Headquarters
and HSCD are coordinating follow-up; see
Streamlining package
HSED
Recommendation:
Issue Memorandum Explaining Treatability Exclusior
Status:
Memo presently being prepared by Hazardous Site
Control Division; contact Robin Anderson, FTS 382-
464~
Recommendation:
Better Focus RI/FS Data Collection
Status:
Recommendation consolidated with pre-remedial date
recommendation discussed above
Recommendat'ion:
Expand CLP RAS
Status:
Recommendation not fully endorsed by RI/FS
Improvements Steering Committee; HSED presently
conducting surveys of the Regions to determine the
types of additional RAS services which may be
needed
-------
Recommendation:
ESD should be more Involved in the Development qi
Guidance
Status:
Recommendation to be implemented by Headquarters
when appropriate guidance is being developed
Recommendation:
QA Requirements should be Standardized Among the
Regions
Status:
Recommendation not fully endorsed by workgroup or
RI/FS Improvements Steering Committee; instead,
Headquarters will strive to consolidate QA
requirements and make them consistent as describe
above
Recommendation:
Explore Mechanisms which will Establish Groups of
Contractors who Offer Specific Types of Treatment
to Perform Treatability Testing
Status:
Recommendation will not be implemented in
treatability testing memo discussed above
encourage contractors to develop capacity
perform treatability tests
full;
will
to
Procurement Workgroup
Recommendation:
Delegate Workplan Approval to Regional Project
Officers
Status:
Recommendation forwarded to Regions for
information purposes; Headquarters follow-up
required; see RI/FS Streamlining package
Recommendation:
Grant Authority to REM/ARCs Contractors to
Directly Approve Subcontracts
Status:
Recommendation forwarded to Regions for
information purposes; Headquarters follow-up
required; see Streamlining package
Recommendation:
Establish Separate Regional Analytical Service
Accounts
Status:
Recommendation forwarded to Regions for
information purposes; Headquarters presently
implementing recommendation; see Streamlining
package
Recommendation:
Develop Source list for Subcontractors
2
-------
Status:
Recommendation:
Status:
Recommendation forwarded to Regions for
consideration/implementation; see Streamlining
package . .
Provide More Substantial Funding for RI/FSs
Recommendation being implemented by Headquarters;
management has planned full funding of new RI/FS
starts
Program Management Workgroup
Recommendation:
Status:
Recommendation:
Status:
Recommendation:
Status:
Implement the Streamlined Approach
Recommendation forwarded to Regions for
consideration/implementation; see Streamlining
package
Conduct National Technical Meetings/Workshops'
Recommendation to be implemented with Headquarter~
lead and Regional support; see Streamlining
package
Increase the Role/Authority/Responsibility of the
RPM
Recommendation referred to the OSWER Task Force
dealing with RPM development; the task force will
circulate recommendations and implementation
plans as they are developed
State Issues Workgroup
Recommendation:
Status:
Recommendation:
Status:
Recommendation:
("'0 p~~)
t ,~~:.~: C~s.~<. R:~.ov,~r?, ~\~uir~~e~t~"at ~~,~ha~ .Si:~.es
\ ~ - . - - .
~. Reco~m~~dation' r~ferred to Enforcement Workgroup
for consideration
Improve Training and Technology Transfer
Mechanisms for Remedial Project Managers;
that Guidance is Guidance; Reduce RPM
Inflexibility
Stress
Recommendation consolidated with National Training
recommendation discussed earlier under Program
Management
Allow Contingency Fund within RI/FS Cooperative
Agreements
3
-------
Status:
Recommendation:
Status:
Recommendation:
Status:
Recommendation not endorsed by management
Allow Greater Funding Flexibility for Awarding
Subcontracts
'.
Recommendation referred to Procurement Workgroup
for consideration
Use Generic Documents and Core of "Expert"
Reviewers to Expedite Document Production and
Review
Recommendation determined to be included in RI/F~
Improvement recommendations previously forwarded
to the Regions in July 1987 and April 1988
Enforcement Workgroup
Recommendation:
Status:
Recommendation:
Status:
Recommendation:
Status:
Recommendation:
Status:
RI/FS Takeovers (Fund lead to RP lead) should be
avoided' ,
Recommendation forwarded to PRP Lead RI/FS
Evaluation Study; evaluation to be completed at
the end of FY 89
Case "Studies" (e.g., copies of special notice
letters soliciting good faith offers, the
corresponding offers received, and the Regional
responses) from negotiation of RI/FSs from each
Region should be distributed to all Regions with
brief assessments of good practice
Recommendation to be implemented by OWPE
Compliance Branch; Regions should submit copies
to Candace Wingfield, OS-219, FTS 475-9317
Initiate New PRP Searches with SOWs Specific to
Site Type
Recommendation forwarded to Regions for
consideration/implementation; Headquarters
implementing recommendation; see Streamlining
package
Use of Multi-Headed or Contingency RODs in Select
Cases Involving the Selection of Innovative
Technologies
Recommendation forwarded to Regions for
4
-------
Recommendation:
Status:
Recommendation:
Status:
Recommendation:
Status:
Recommendation:
Status:
consideration/implementation; see Streamlining
package
Provide RPM Training on Oversight and Interactior
Recommendation forwarded to Regions for
consideration/implementation; Headquarters is
expediting model AOC and SOW for RI/FS guidance;
c'training planned for FY 89; OWPE compliance branc
will track enforcement of RI/FS AOCs in FY 89; SE
Streamlining package
Use Conditional Phased Workplan Approvals (to
facilitate onsite RI/FS progress while maintainir
control) for Fund Lead RI/FSs as currently
practiced for RP Lead RI/FSs
Recommendation being implemented by the Regions
The PRP Oversight Guidance should dictate that
PRPs must conduct treatability studies during thE
RI/FS when early data on remedial treatment,
alternatives facilitates remedy selection;
appropriate guidance for RPMs in overseeing thesE
activities should be included
Recommehdation implemented by Headquarters
Assemble a Database of RI/FS Oversight Costs
Recommendation being implemented by Headquarters
OERR and OWPE
5
-------
OSWER Directive 9355.3-06
ENFORCEMENT
RECOMMENDATION:
Use RODs which Include Contingency
Remedies in Select Cases
BACKGROUND:
Ordinarily, the Agency identifies a
preferred alternative in the Proposed
Plan and selects a single remedy in
the ROD. However, in certain
instances, it may be advantageous to
include in the ROD additional
provisional remedies which could be
implemented in lieu of the selected
remedy.
DISCUSSION:
In situations where additional testing
during remedial design will be
necessary to verify the performance of
the lead and support agencies'
preferred technology, a ROD that
selects that technology but also
provides a backup remedy may be
signed. The ROD should contain a
complete analysis of both remedies and
would show how the primary remedy
provides the best balance across the
nine criteria, except for the
uncertainty associated with that
remedy, and how the backup remedy
would provide the best balance if the
primary remedy does not achieve its
goal. The ROD should describe the
criteria used to resolve the
uncertainty associated with the
primary remedy. The revised ROD
guidance will provide additional
guidance in this area.
In selected situations, the Agency
will select a remedy from several
treatment technologies which appear to
be comparable with respect to the nine
criteria. The comparable
technology(ies) may be included in the
ROD as provisional remedies, and
19
-------
IMPLEMENTATION PLAN:
HQ CONTACT:
OSWER Directive 9355.3-06
implemented if one of them emerges as
more cost-effective or practicable
than the selected remedy as a result
of negotiations with PRPs.
In order to implement any provisional
remedy, an explanation of significant
differences must be provided to the
public.
Headquarters will develop guidance on
policy and procedures associated with
these types of RODs. This information
will be available in the "ROD
Guidance" to be completed this winter.
Linda Boornazian (FTS) 382-4836
Darsi Foss (FTS) 475-9843
20
-------
RECOMMENDATION:
BACKGROUND:
DISCUSSION:
IMPLEMENTATION PLAN:
CONTACT:
OSWER Directive 9355.3-0
ENFORCEMENT
Provide Training to RPMs on RP
Oversight and Interaction
The number of RI/FSs which are
performed by responsible parties has
increased and is expected to continue
to increase. Accordingly, a larger
number of enforcement actions as well
as increased attention to oversight
are expected to be necessary. RPMs
are experienced in daily interactions
withPRPs, but would benefit from
inter-regional training addressing
common issues. Further, there is
relatively little experience with
enforcement of some AOU or AOC
provisions directed at improving the
timing and quality of RP work, for
example, stipulated penalties.
Standard language has been developed
in the context of the Settlement I/D
Workgroup for specific AOU/AOC
provisions. Training on uniform
enforcement of existing agreements and
uniform language for new agreements
will improve RI/FS quality. Training
on daily interactions,
cross-regionally, will also improve
quality and programmatic consistency.
OWPE training staff should design a
course for implementing this training.
Debby Thomas (FTS) 475-7028
17
-------
RECOMMENDATION:
BACKGROUND:
DISCUSSION:
IMPLEMENTATION PLAN:
HQ CONTACT:
OSWER Directive 9355.3-Q(
ENFORCEMENT
Initiate New PRP Searches with SOWs
Specific to Site Type
Often a single individual is
responsible for initiating searches
for these sites, which are seldom
assigned to a RPM at this stage.
A single generic SOW is not
appropriate for a range of site types.
Region I has had success with the
recommended approach. Site-specific
changes necessary to modify these
scopes are minimal, making a workload
of up to 30 searches more manageable.
The enforcement policy branch, in
OWPE, is encouraged to develop scopes
of work for initiating PRP searches
which are specific to site type using
the Region I experience as a basis.
After Regional review and comment, the
model language should be distributed
to the Regions.
Steve Suprin (FTS) 475-8254
IS
-------
OSWER Directive 9355.3-0(
PROGRAM ~AGEMENT
RECOMMENDATION:
Conduct Technical Meetings/Workshops
BACKGROUND:
Due to the ever evolving nature of the
hazardous waste field, technologies
and policies are constantly changing.
Many RPMs have the responsibility of
managing highly technical and policy
sensitive projects while having little
or no previous experience. It is
therefore very important to
continually provide opportunities for
junior RPMs and more experienced
project managers to meet and learn
from each other's experiences.
DISCUSSION:
These meetings should be topic
specific as well as provide the latest
policy regarding the specific subject.
Topic specific briefing papers should
be prepared as a product of these
meetings and distributed to the
Regions. Sample topics could include
wood preserving sites, battery
recycling sites and municipal landfill
sites. .
Following are issues which may be
considered in the context of each
topic: 1) Technical skills, and 2)
Guidance updates. However, a variety
of topics should be made available.
In addition, meetings will have a
session on interpersonal skills.
IMPLEMENTATION PLAN:
OERR will coordinate with the Regions
to help organize these meetings. The
regional programs (Division Director)
will be asked to provide topics,
suggested times and locations, and
technical and logistical support for
the meetings on a rotating basis. The
first meeting is tentatively planned
15
-------
OSWER Directive 9355.3-06
for 2nd quarter FY 89.
RPMs and others will be asked to
present topic specific papers at these
meetings. This will facilitate the
exchange of ideas and experience among
Regions.
Management is also encouraged to
ensure that sufficient funds are
allocated for these meetings and
workshops. Managers should keep
abreast of the training needs of
staff as well as the training
opportunities available to them.
their
State representatives and contractors
staff should also be encouraged to
attend and participate in these
meetings. .
HQ CONTACT:
Randy Kaltreider FTS 382-4491
16
-------
RECOMMENDATION:
BACKGROUND:
DISCUSSIO~:
IMPLEMENTATION PLAN:
HQ CONTACT:
OSWER Directive 9355.3-06
PROCUREMENT
Develop Source Lists for
Subcontractors
Considerable time delays have been
encountered during the subcontractor
procurement process. Pre-qualified
lists of subcontractors must be
developed by the prime contractor as
part of this process. This has
proven to be a long and tedious
procedure.
The use of a pre-qualified list of
drilling subcontractors during the REM
IV contract has helped reduce the time
required to procure these services.
Source lists could be developed and
maintained by the Regional offices and
used by the ARCS contractors within
each Region. These source lists would
be available to aid them in developing
their specific pre-qualified lists of
subcontractors (i.e. drilling,
treatability studies, surveying,
et c . ) .
The Regional offices, with
Headquarters assistance, should
compile a list of subcontractors that
have been used by the REM contractors
in the Region. This list should then
be made available to all ARCS
contractors for possible services.
The REM contractors should be
contacted and asked to generate this
list.
Randy Kaltreider (FTS) 382-4491
-------
RECOMMENDATION:
BACKGROUND:
DIsceSSION:
IMPLEMENTATION PLAN:
HQ CONTACT:
OSWER Directive 9355.3-06
PROGRAM MANAGEMENT
Implement the Streamlined Approach
The Streamlined Approach (see
accompanying case study) is an
approach to the remedial process which
implements the NCP's goal of a bias
for action. It explicitly recognizes
and addresses the uncertainties
encountered during hazardous waste
site remediation.
This approach requires the RPM to
closely evaluate existing data and
determine the earliest point in time
that work can begin at the site (bias
for action). The approach encourages
earlier remedy selection and remedial
action. It also emphasizes the
development of flexible remedies that
can accommodate changes encountered in
the field.
The case study will be given to the
Regions to highlight the Streamlined
Approach. Each Region should look at
implementing this approach during
FY89. HQ will provide the Regional
Offices with support during the
planning and implementation phases of
these studies in FY89. Regional staff
should evaluate site specific
circumstances, including enforcement
concerns, to determine the amount of
data needed to support remedy
selection and the ability to implement
the remedy.
Randy Kaltreider FTS 382-4491
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OSWER Directive 9355.3-06
to facilitate successful completion of
the CPSR audit.
HQ CONTACT:
Randy Kaltreider (FTS) 382-4491
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RECOMMENDATION:
BACKGROUND:
DISCUSSION:
IMPLEMENTATION PL&~:
HQ CONTACT:
OSWER .Direc.ti ve 9355.3-06
PROCUREMENT
Establish Separate Keglonal Analytical
Services Accounts
Concern has arisen that since CLP
services are "free" to the Regions,
RPMs will under-utilize other
available analytical services rather
than budget them in individual RIfFS
projects.
Separate Regional analytical services
accounts should be established to fund
certain CLP levels, with the remaining
funding to be used by the Region at
their discretion (i.e. local labs,
mobile labs, contractor labs, CLP
labs, etc.). This would ensure
adequate CLP utilization while
providing the RPM with a range of
financially "equal" analytical
alternatives to choose from. Regional
ability to track the CLP budget will
not solve this problem.
Representatives of OERR and Contracts
are continuing to meet to work out the
funding and contractual changes that
must be made to the system in order to
put this recommendation into place.
The SCAP would also have to include
this budget item.
This issue will be resolved by the 3rd
quarter of FY 89 so the Regions can
plan for it in their FY 90 budgets.
Randy Kaltreider (FTS) 382-4491
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RECOMMENDATION:
BACKGROUND:
DISCUSSION:
IMPLEMENTATION PLAN:
HQ CONTACT:
OSWER Directive 9355.3-06
PROCUREMENT
Delegate Work Plan Approval to
Regional Project Officers (RPOs)
Substantial time is lost during the
work plan approval process when
documents must be sent to HQ to be
approved by the Contracting Officer
(CO). Re~ional authority would
eliminate the time required to obtain
CO approval.
Work plan approval, not involving
additional funding, should be
delegated to the RPOs. The Federal
Acquisition Regulations (FAR) do not
require that the CO approve these
types of requests. It should,
therefore, be a relatively simple
process to incorporate this suggestion
in the existing SOPs.
OERR is presently working with PCMD to
finalize the details regarding the
implementation of this recommendation,
which will be incorporated into the
forthcoming ARCS Contracts Users'
Manual.
Randy Kaltreider (FTS) 382-4491
9
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RECOMMENDATION:
BACKGROUND:
DISCUSS:ON:
!MFLE~EN:A::8N ?L~\:
OSWER Directive 9355.3-0~
PROCUREMENT
Grant Authority to REM/ARCS
Contractors to Directly Approve
Subcontracts
The process of subcontractor approval
is taking too long and is delaying
remedial activities. The number of
contract document handoffs must be
reduced as much as possible.
REM/ARCS contractors should be given
the 'authority to directly approve
subcontracts up to $250,000. The
$250K figure represents 90% of the
subcontracts awarded by REM II, REM
III, and REM IV.
Fcllowing ~he successful completion of
a Contract Procurement System Review
(CPSR) audit, the REM/ARCS contractor
will be granted the authority to
directly approve subcontracts up to
S250K. This approval will be for any
EPA Superfund contract that is
operated out of the office and follows
the same financial policies and
procedures.
OERR will work with PCMD to set a
priority for scheduling these audits.
The ARCS contractors with the greatest
national work load will be the first
to have audits performed of their
procurement systems. This list will
be developed in the first quarter of
FY 89 and the reviews will follow.
Regions are encouraged, through the
contract:=- performance evaluation
process, to hold REM/ARCS contractors
acc~untable for having acceptable
procurement systems in place in order
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RECOMMENDATION:
BACKGROUND:
DISCUSSION:
IMPLEMENTATION PLAN:
OSWER Directive 9355.3-06
TECHNICAL
Make QA Requirements Consistent and
Consolidate Documents Whenever
Feasible
Historically, Headquarters and the
Regions have tended to view QA
requirements separate from the
remainder of the data collection
process. This has led to some
miscommunications between the
Superfund program and ESDs. When QA
is not considered early in the RI
scoping process, delays in QAPjP
preparation and errors in field work
can result. .
A concern has .also arisen regarding
the non-uniformity of QA requirements'
among the Regions. Other Federal
Agencies, the contracting community
and responsible parties have found
that QA requirements are not at all
consistent from Region to Region.
Although this is partly a Regional
responsibility, in several cases,
Headquarters guidance has been
contradictory in its treatment of QA.
The process of standardizing QAPPs,
field screening methods, and QA
requirements for non-CLP labs will
lead to ease in the consolidation of
these items into SAPs and Work Plans.
For example, Region III has begun a
similar initiative and has found that
standard items can now easily be
incorporated into planning documents
(such as the SAP) by reference. This
has ~een shown to save time during
document preparation and review.
Regional Superfund programs should
continue to work closely with their
ESDs during the entire remedial
process. Special attention should be
given to assure that ESDs are involved
in the RI scoping process, especially
in designing a sampling program to
achieve DQOs, once an RPM has
determined them.
-------
OSWER Directive 9355.3-06
The Regions should be made aware that
the Field Screening Methods Catalog,
presently being prepared by OERR, will
be available shortly. It contains
descriptions of approximately 31
methods currently being used in the
Regions.
Regional and Headquarters staff should
also consider convening a workgroup
which would further tailor the current
QAPP guidance to the Superfund
program.
HQ CONTACT:
Lisa Carson (FTS) 475-9758
c
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OSWER Directive 9355.3-06
TECHNICAL
RECOMMENDATION:
Better Utilize Expanded Pre-remedial
Data During RI Scoping
'-
BACKGROUND:
Only a limited ,amount of data
collected by the FIT have been useful
in the RI scoping process. In some
cases, the SI data were too old and
generic in nature and therefore not
very useful during RI scoping. At
other times, due to poor
communication, the remedial program
has no: obtained potentially useful
pre-remedial data.
DISC~SS!ON:
The pre-remedial program has developed
the guidance for the Expanded Site
Investigation (ESI). They would like
input from the remedial program
regarding the types of additional data
that could be gathered during an ESI
whic~ would also be useful during RI
scoping. The pre-remedial program
will be updating this guidance even
further when the revised Hazard
Ranking System (HRS) is final. [The
term ESI will be replaced by Listing
Site Inspection (LSI) in FY 89.]
The following data could be collected
during an ESI and would be useful
during RI scoping:
o Utility survey
o Meteorological survey
o Physical properties of test
cores
The following have also been
identified as potentially useful and
are already par: 0: the ESI.
o Geophysics
o Surveying and mapping
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:M?LEMEN7AT!O~ ?L~~:
HQ CONTACT:
OSWER Directive 9355.3-06
o Aerial photos
o Existing well inventory
o Health & Safety Plan prep.
o Chemicals of concern
During all of the above mentioned
activities, non-time critical
information will be collected which
the workgroup feels will be helpful
during RI scoping. However, where
necessary, these data should be
updated routinely; prior to scoping
and during work plan preparation to
aid in scoping and to be more time
efficient.
The remedial and pre-remedial programs
are encouraged to interact prior,
during, and after the commencement of
the ES1/LS1 to encourage the
collection of data that will benefit
both programs. In most cases, data
~equired by the pre-remedial program
may prove useful in RI scoping.
Discussions with pre-remedial staff in
each Region may point out areas where
the p~e-~emedial data may satisfy
remedial program needs.
The RPMs should determine the need to
update the existing information during
the scoping process.
The pre-remedial workgroup can be used
as a forum to increase communication
between pre-remedial and remedial
staff and as a resource to ensure that
remedial data needs are addressed as
much as possible in the future.
Lisa Carson (FTS) 475-9758
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RECOMMENDATIONS:
BACKGROUND:
DISCUSSION:
IMPLEMENTATION PLk~:
OSWER Directive 9355.3-06
TECHNICAL
Institute Regional Remedial Contractor
Training
Regions III & IX have found that
investing time upfront to educate its
REM/ARCS contractors about the
Regions' expectations for RI/FSs makes
for a smoother RI/FS process.
Resources will be required upfront,
however, the Region's investment will
ensure that all parties involved begin
on a solid, common foundation.
Regions III and IX have concentrated
on training which teaches the
contractors the "how tos" of dealing
with their individual Regions.
ESD's contribution to the training is
especially helpful in clarifying QA
requirements. A list of possible
training topics is found below.
o Data validation
o Regional review process
o Sample scheduling
o Mechanics of sample submission
o Use of ESATs and other Regional
contracts
o DQOs
OERR will keep Regions abreast of
other Regional training activities.
However, Regions are encouraged to
communicate with eac'h other regarding
contractor training. It is also
important to invite State
participation in this activity.
OE~~ recognizes that there is Regional
variation regarding these training
topics. Therefore, the Region III &
-------
OSHER Directive 9355~3-06
IX training materials could be used as
guidelines and supplemented as
necessary.
HQ CONTACT:
Lisa Carson FTS 475-9758
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