RI/FS IMPROVEMENT ANALYSIS JULY 1987 ------- RI/FS IMPROVEMENT ANALYSIS U.S. Environmental Protection Agency Region III Information Resource - Center (3PM52) 841 Chestnut Street W Philadelphia, PA 19107 /dalliifr PREPARED FOR: Office of Emergency and Remedial Response U.S. Environmental Protection Agency 401 M Street., SW Washington, DC 20460 PREPARED BY: CDM Federal Programs Corporation 13135 Lee Jackson Memorial Highway, Suite 200 Fairfax, Virginia 22033 July 1987 ------- TABLE OF CONTENTS SECTION PAGE 1.0 INTRODUCTION 1-1 1.1 The Current RI/FS Process 1-1 1.2 Improvements to the RI/FS Process 1-2 1.3 Quality Control Initiatives 1-5 1.4 Impact of SARA on the RI/FS Process I -5 1.5 Format of this Report 1 -6 2.0 ANALYSIS OF THE EXISTING RI/FS PROCESS 2-1 2.1 Critical Path Analysis 2-1 2.2 Handoffs Analysis 2-1 2.3 RI/FS Analysis Questionnaire 2-6 2.4 Conclusions 2-7 3.0 RECOMMENDATIONS FOR PROGRAM IMPROVEMENT 3-1 3.1 Phased RI/FS Approach 3-7 3.2 Streamlined Project Planning 3-8 3.3 Reduced Handoffs and Streamlined Critical Activities 3-12 4.0 QUALITY CONTROL INITIATIVES FOR THE RI/FS PROCESS 4-1 5.0 EFFECT OF SUPERFUND REAUTHORIZATION OF RI/FS EXECUTION 5-1 6.0 REFERENCES 6-1 Appendix A - Generic Report Outlines Appendix B - Questionnaire Results Appendix C - Modified RI/FS Model with SARA Changes BK4A-4 ------- LIST OF FIGURES FIGURE PAGE 1-1 RI/FS CPM Schedule Scenario Analysis 1-4 2-1 Existing RI/FS Critical Path Schedule 2-2 3-1 Summary CPM Modified RI/FS Scenario 3-2 3-2 Modified Critical Path Schedule 3-5 3-3 RI/FS CPM Schedule Scenario Analysis 3-6 3-4 Implementation Options for Remedial Work Assignment 3-9 LIST OF TABLES TABLE PAGE 2-1 Handoffs Summary for RI/FS Process - Fund-Lead Site 2-4 3-1 RI/FS Standard Tasks 3-11 4-1 RI/FS Process with QC Reviews 4-4 4-2 Quality Control Reviewers and Approval Responsibilities 4-5 BK4A-8 iii ------- 1.0 INTRODUCTION Despite the increasing experience base and guidance available on the remedial program, Rl/FS projects continue to be troubled by increasing costs and schedule durations. Early in the program, EPA estimated that a typical RI/FS would take 12-18 months to complete and cost less than $500,000. However, the execution of a typical assignment has not gone as quickly or as economically as originally desired. Currently, it takes an average of 25 months to complete an RI/FS at an average cost of $700,000. Of greater concern to EPA is that the schedule and costs may increase further as the requirements of SARA are implemented. This document reports the results of an analysis of the current RI/FS process to determine how the process can be streamlined to improve the quality of deliverables while at the same time reduce schedules and costs. 1.1 THE CURRENT RI/FS PROCESS The execution of an RI/FS is affected by many elements that have little to do with technical analyses needed to select a remedial alternatives for a Superfund site. In many instances, schedules and cost have been increased due to delayed deliveries of validated data, lengthy review times, or because insufficient or inappropriate data were collected during the RI. These elements and others were evaluated by collecting data on completed studies and by running a series of critical path method schedules to analyze the impacts of these various delay elements on total project duration. Several of the key findings of the analysis of current studies are summarized below and discussed in Section 2.0. Critical Path Analysis The primary basis for this evaluation was a detailed critical path method (CPM) schedule analysis of the remedial process. As a starting point, a baseline CPM chart of the entire remedial process, from listing a site on the NPL through delisting, was developed. This schedule and cost model was based upon the experiences of CDM and Agency personnel, and also reflected actual costs and timeframes experienced to date in the RI/FS program. The baseline model was developed and refined through workshops held in August and October 1986 with Agency Headquarters and Regional staff, and remedial contractor representatives. Working from the baseline, a series of program improvement scenarios were developed to predict time or cost savings that would result from changes in the execution of the RI/FS. BK4A-2 1-1 ------- A typical RI/FS is currently executed in four phases (project planning. RI, FS and post FS) that can include over 100 separate activities. Approximately 34 percent of the activities occur along the critical path, including many of the report production and review tasks. The project planning phase has the largest number of activities (41), with almost 25 percent of these occurring on the critical path. Therefore it is not surprising that it takes, on average. 6 months to complete the project planning phase for a typical RI/FS. Handoffs Analysis An element that has had a major impact on the execution of an RI/FS is the number of handoffs involved in the process. A "handoff" is defined as a point in the process where responsibility for a task changes hands. Based on the baseline CPM created for purposes of analysis, a total of 31 handoffs occur during the RI/FS process. Of this total. 52 percent of the handoffs occur during project planning phase and account for a total of 29 weeks. More importantly, however, is that 43 percent of these RI/FS handoffs are on the critical path. RI/FS Analysis Questionnaire A questionnaire was sent to the Regions to solicit input on problems with and potential improvements to the RI/FS process. Responses received from 45 individuals in 6 Regions indicated that data validation and approval of project planning documents cause the most problems in creating project delays. Other chronic problem areas identified were review and approval of the quality assurance project plan and sampling and analysis plan, and a lack of standardized document formats and review procedures. Overall, the Regions were supportive of program improvement initiatives that could really streamline the RI/FS process. 1.2 IMPROVEMENTS TO THE RI/FS PROCESS Over the past year, the Agency has conducted several analyses aimed at identifying ways to streamline or generally improve the execution of the RI/FS. Earlier studies looked at the current process and identified major areas where delays occurred. Program changes (e.g.. contractor continuity, expedited response actions, alternate remedial contract strategy) that could improve the quality and timeliness of the remedial process were discussed as potential concepts for further development. BK4A-2 1-2 ------- The focus of this study was to identify program improvements that could be made immediately and which would not depend on major program changes or extensive documentation or retraining. The analysis keyed in on those elements that have been effectively applied on a limited number of sites but which have general applicability to all RI/FSs conducted by EPA and State agencies. Program improvement initiatives are outlined briefly below and discussed in greater detail in Section 3.0. Phased RI/FS Execution The major change recommended as a result of this analysis is the incorporation of phased execution in most RI/FS designs. By phasing data and sampling collection activities, better data and feasibility analyses can be completed, which will result in more complete and defensible Records of Decision. In addition, the CPM analyses have shown that a phased study, if properly planned and executed, will reduce the schedule and cost of the study. Comparisons of the modified CPM analysis to the current execution CPM model are shown graphically in Figure 1-1. In the first diagram schedules are compared; in the second diagram, costs by phase are compared. The analyses completed to date have demonstrated that even though more money may be spent in the project planning and RI phases of a phased RI/FS. the overall cost and duration will be reduced. The modified CPM analysis is discussed in Section 3.0. Streamlined Project Planning Phase In the past it was not uncommon for the work plan development phase of a typical RI/FS to take 6-9 months and cost well over $100,000. A major hurdle to getting a fully approved work plan was in reaching agreement for major scope items that would be completed a year or two in the future. Several changes are proposed that allow projects to: (1) be initiated more rapidly. (2) involve key reviewers at critical stages in the development, (3) reduce the number of documents and redundacy in documents that receive complete external reviews, and (4) allow work to proceed while final work plan negotiations are completed. The goal is to have field work underway within 3 months after the work assignment is received. BK4A-2 1-3 ------- RI/FS CPM SCHEDULE COMPARISON Baseline CPM Updated CPM Planning | Rl | FS POST-FS Planning | RI1 | RI2 | FS | POSTFS | Months 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 RI/FS COST/RESOURCE COMPARISON POSTFS Baseline CPM Planning Rl FS Updated CPM Planning RI1 | RI2 | FS POST-FS Cost ($1,000's) 50 100 150 200 250 300 350 400 450 500 550 600 650 700 750 800 FIGURE 1-1 RI/FS CPM SCHEDULE SCENARIO ANALYSIS 1-4 REM 3003 ------- Management of Handoffs and Streamlined Critical Activities One major reason why RI/FS schedules have increased is due to frequent and lengthy document reviews. In addition, some of the reviewers are not accountable to the RPM and have not had the responsibility to complete reviews in a timely manner. This has added time to the completion of a typical RI/FS. Since many of the reviews were on the critical path and directly affecting project schedules, one of the goals of the modified RI/FS is to decrease the number of handoffs and take as many off the critical path as possible. Critical activities, that is. any activity that has a direct impact on the project schedule, should be kept to a minimum to avoid delays. This can often be accomplished by scheduling concurrent activities, phasing critical field tasks, and initiating field activities on interim approvals. 1.3 QUALITY CONTROL INITIATIVES The project management responsibility that has been transferred to the Regions includes responsibility for the consistent and defensible quality of RI/FS work products. The Regions are encouraged to initiate a standardized and documented quality control system of review and signoff authority within their Region. Section 4.0 presents a model from which individual Regional programs can be built. It includes an approach to quality control and identifies key project milestones which are appropriate for standardized reviews. 1.4 IMPACT OF SARA ON THE RI/FS PROCESS The Superfund Amendment and Reauthorization Act of 1986 (SARA) includes many provisions that impact the execution of the RI/FS. While SARA now outlines a series of implementation schedules that will require rapid planning and execution, the new requirements of SARA have the potential to lengthen schedules for most RI/FSs completed in the future. This adds increasing importance to EPA's effort to maximize the efficiency and effectiveness of RI/FS management practices. A series of CPM schedule analyses were completed based upon the new elements of SARA. Preliminary estimates based on currently available information indicate that the duration of a typical RI/FS could potentially increase by over 3 months and cost slightly more to complete. Although no changes in task or subtask durations have been documented to date, the new requirements have a strong potential to affect project schedules. Increased time is required to: (1) accommodate increased State reviews. (2) meet new PRP notification and negotiation requirements. (3) include treatability testing as part of the RI/FS and (4) coordinate with other agencies such as ATSDR. BK4A-2 1-5 ------- 1.5 FORMAT OF THIS REPORT The analysis of the existing RI/FS process included an evaluation of the critical path network, identification of handoffs from the RI/FS contractor to other entities, a questionnaire distributed to the EPA Regions, and evaluation of cost and resource utilization associated with the various RI/FS tasks. The CPM model and its analysis are discussed in Section 2.0. Based on the analysis, a number of initiatives and recommendations for improving the RI/FS process were identified. The program improvements are discussed in Section 3.0. Recommendations include the removal of some EPA intra-Agency reviews from the critical path, phased execution of the RI/FS. utilization of a standard task structure, streamlining of the project planning phase, and reliance on standard document formats. Quality control initiatives for the RI/FS process are presented in Section 4.0. These initiatives were an outgrowth of the RI/FS analysis task and provide for increased program management oversight within the EPA Regional offices and recommended QC checkpoints during the RI/FS. Section 5.0 discusses the impacts of Superfund reauthorization on RI/FS execution. BK4A-2 1-6 ------- 2.0 ANALYSIS OF THE EXISTING RI/FS PROCESS The existing RI/FS process was analyzed through studies of critical path method (CPM) models of a typical RI/FS. Sources for analysis of the existing RI/FS process included studies conducted by CH2M Hill (1985) and ICF (1985), discussions with EPA Headquarters and Regional staff, questionnaires filled out by Regional staff, and discussions from workshops attended by EPA and remedial contractor representatives. Recommendations for program improvement are discussed in Section 3.0. 2.1 CRITICAL PATH ANALYSIS All data used in developing the CPM model were obtained from experience gained on REM II sites and through two workshops attended by EPA Headquarters. Regional, and remedial contractor staff. The CPM model activities were developed to provide a generic model for analysis. Actual activities, network logic, and durations are highly dependent on site conditions. The baseline CPM model used in this analysis included 111 separate activities within the RI/FS process. These activities were selected to develop a generic model for analysis and represent a typical RI/FS. The majority of activities occur during the project planning phase, followed by the RI. FS. and post FS. respectively. The remedial contractor is responsible for 74 percent of project activities, followed by EPA Regional program management (RPMs) with 15 percent. Regional Environmental Services Divisions with 3 percent. Headquarters contracts with 3 percent. CLP with 3 percent, and U.S. Army Corps of Engineers with 2 percent. Figure 2-1 illustrates the critical path schedule for a typical fund-lead Federal-lead RI/FS. Under current procedures, a typical RI/FS takes approximately 27 months to complete. Seven months are required for project planning, 8 months are required for the RI, 9 months are required for the FS and ROD production, and an additional 3 months are required for producing the final RI/FS report, predesign. and project closeout. 2.2 HANDOFFS ANALYSIS An analysis was conducted to identify the "handoffs" which occur during fund-lead. Federal-lead projects within the remedial planning. RI/FS. design, and construction phases. A "handoff" is BK4B-4 2-1 ------- MONTHS 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Site ;lnspef:tion jcharacter&atiorj S&A Plin ; < rm~\: ; Work fllan L Drilfing/Spmplihg &P o Data Validation r—i GW Model d Rfek Assessment r—i Alternative Screerting/Evjiluatiop [' ' (3 Report IMI I 'ublic Comment/ Responsiveness t=P Summary of RA Selection !~: HOD Preparation CD BRP Negotiation Summary J Clqse-outj&WAC/R I | EPA/State Review FIGURE 2-1 EXISTING RI/FS CRITICAL PATH SCHEDULE ------- defined as a point where overall responsibility for a task shifts from one entity to another. Handoffs include transfers of responsibility between the Agency and contractors as well as inter- and intra-Agency responsibility transfers. The large number of handoffs that occur throughout the remedial process complicate management of the Superfund program. The transfers of responsibility tend to impede the progress of the site cleanup process. The potential impacts of handoffs may include schedule delays, higher costs due to decreased efficiency, and reduced quality when transfers are not effectively accomplished. The objective of this analysis was to identify the points where handoffs occur and the time associated with them in order to assess their role in the remedial process. Emphasis was placed on the identification of handoffs occurring along the critical path since they have the greatest potential for impacting the process. Handoffs were identified from a review of the remedial process CPM model. A summary of handoffs was also prepared to indicate the entities involved, nature of the transfer, duration, and critical path items. This information is presented in Table 2-1. Table 2-1 indicates that 21 handoffs occur during the RI/FS process. The total time associated with these handoffs is 58.4 weeks, with the average time per handoff being 2.8 weeks. Approximately 43 percent of the handoffs lie along the critical path. The average time per critical path handoff is 2.5 weeks. Non-critical path handoffs take an average of 2.3 weeks to complete. Fifty-two percent (11 of 21) of the handoffs occur during the project planning phase of the RI/FS. The planning phase is followed by the post FS phase with 24 percent, the RI with 19 percent, and FS with 5 percent. A majority of handoffs (18 of 21) occur between contractors and government agencies (EPA and COE). Three interagency handoffs (between EPA and CLP or EPA and states) were also identified. Eight of the 18 contractor/agency handoffs are critical path activities. Two of the three interagency handoffs are on the critical path. Contractor/agency handoffs typically consist of reviews; interagency handoffs usually correspond to project initiation handoffs. The average time per contractor/agency handoff (both critical path and non-critical path) is 2.7 weeks. On the average. 2 weeks are required for non-critical path interagency handoffs. while 4 weeks are required for critical path handoffs. BK4B-4 2-3 ------- TABLE 2-1 HANDOFFS SUMMARY FOR RI/FS PROCESS - FUND-LEAD SITE Handoff PROJECT PLANNING Contracts - REM Cont. Region - REM Cont. Region - REM Cont. Region - REM Cont. Region - REM Cont. Region - REM Cont. Region - REM Cont. Region - REM Cont. REM Cont. - HSCD/ Contracts REM Cont. - Region/ Contracts Region - REM Cont. REMEDIAL INVESTIGATION Contracts-REM Cont. Description Issue WA to REM contractor Review draft work plan memo Acknowledge final work plan memo Review draft work plan Review draft interim report Review draft sampling plan Review draft QA project plan Review draft POP Subcontractor procurement (drilling, surveying, etc.) WA amendments (additional field investigations, treatability/ pilot studies, etc.) Review draft CR plan Authorize REM Cont. to proceed with RI Duration (weeks) 3 3 6 Critical Path Item Yes 0.4 No No Yes No Yes No No No No No Yes REM Cont. - CLP Sample analysis Yes BK4B-5/1 2-4 ------- TABLE 2-1 HANDSOFF SUMMARY FOR RI/FS PROCESS - FUND-LEAD SITE (Continued) Handoff CLP - EPA Region ESD Region/State - REM Cont. FEASIBILITY STUDY Region/State - REM Gont. POST RI/FS REM Cont. - Region State - Region Region - HSCD Region - HSCD Region - REM Cont. Region/HSCD - REM Cont. Description Data validation Review draft RI report Review draft FS report Prepare summary of remedial alternative selection State concurrence on selected remedy Prepare ROD Approve ROD Review predesign report Review WACR Duration (weeks) Critical Path Item Yes No Yes Yes No Yes Yes No Yes BK4B-5/2 2-5 ------- Approximately 81 percent of the handoffs occur during project initiation and review periods. Project initiation handoffs typically consist of administrative/contractual items. Six such handoffs were identified and 11 handoffs associated with reviews were identified. Two handoffs are associated with sample analysis/data validation. Half of the administrative/contractual handoffs are critical path items while about 27 percent of the review/inspection handoffs are critical path items. Each of the handoffs associated with sample analysis/data validation lies along the critical path. The average time per administrative/contractual handoff along the critical path is 1.5 weeks. Non-critical path administrative/contractual handoffs take longer, averaging 2.3 weeks. Review handoffs for critical path items require an average of 3.3 weeks to complete. An average of 5 weeks are needed to complete sample analysis/data validation handoffs. 2.3 RI/FS ANALYSIS QUESTIONNAIRE A questionnaire was developed to elicit information to assist EPA in identifying problems and investigating alternatives for improvement of the RI/FS process. The questionnaire focused on the RI/FS process and requested information about successes and failures in program improvement at the Regional level, usefulness of project deliverables, methods and effectiveness of con tractor-EPA communication, and any additional ideas on potential methods for improving the RI/FS process. The questionnaire was distributed to the REM Regional Project Officers in November 1986: responses were received from 45 individuals in six Regions. The questionnaire responses are summarized below. The compiled responses on the questionnaire and a summary are included in Appendix B of this document. The questionnaire respondents identified data validation and approval of project planning documents as causing the most problems in creating project delays. A range of 2-4 months was identified as a reasonable timeframe for project planning. Other chronic problem areas identified were review and approval of the QAPP and S&A plan, and a lack of standardized document formats and review procedures. The work plan, S&A plan, and the QAPP were ranked as the top three planning documents according to to their practical usefulness. The work plan memorandum was ranked the lowest in terms of practical usefulness. Good communications were identified as critical for successful project performance. Other factors considered helpful included interim deliverables, turning data over to contractor prior to validation, and field screening of samples. BK4B-4 2-6 ------- 2.4 CONCLUSIONS The analysis of the existing RI/FS process indicated that the unacceptable length of a typical RI/FS, approximately 27 months, is largely due to the following factors: • For each project phase, the percentage of activities that are on the critical path are as follows: Project planning - 24 percent Remedial investigation - 23 percent Feasibility study - 65 percent Post FS - 42 percent • Handoffs, which involve primarily review and administrative activities, account for 24 percent of the critical path activities (9 of 38). and 26.4 weeks of the RI/FS duration. • Sample analysis by CLP and data validation continue to be sources of project delays. • Additional factors, including: redundancy in project planning documents, lack of standardized formats, external reviews, and PRP negotiations. Modified scenarios for the RI/FS process were developed with the goal of reducing the number of handoffs on the critical path, streamlining the project planning phase, and improving the efficiency and effectiveness of the RI and FS phases. Recommendations for program improvement are discussed in Section 3.0. BK4B-4 2-7 ------- 3.0 RECOMMENDATIONS FOR PROGRAM IMPROVEMENT Working from the baseline CPM schedule discussed in Section 2.0, a series of modifications/- improvements were evaluated in an attempt to streamline the execution of a typical RI/FS. The primary goals that were established were: (1) to reduce the amount of down time for the personnel executing the study. (2) removing review times from the critical path to the greatest extent possible, and (3) incorporating the new work assignment procedures into the process to expedite approvals and amendments. The modified CPM schedule is summarized in Figure 3-1. The modified CPM reflects incorporation of a number of program changes intended to improve the RI/FS process. Each of these program changes is discussed in the subsections below. The effects of the changes on the RI/FS schedule are illustrated on Figure 3-2. The modified process reduces the time needed to complete a typical RI/FS and produce a ROD by 2 months while at the same time optimizing data gathering and analysis tasks and incorporating SARA requirements. Increased savings in time and cost can be accomplished for different type of sites (operable units, focused feasibility studies, etc.): the model discussed in this section is a fully-phased major RI/FS study. Figure 3-3 shows a comparison of the baseline RI/FS process with the modified scenario in terms of schedule and resources. The reduced schedule and improved efficiency of the process can result in significant cost savings. The FS may seem inappropriately small when compared to the expanded RI. This is somewhat misleading since the FS is conducted concurrently with the RI and the schedules do overlap. The lack of change in the post-FS phase is attributed to a more precise definition of tasks and time requirements in the modified CPM model. In reality, time and cost savings are anticipated for the post-FS phase due to better project planning, including such things as conducting pilot/treatabi 1 ity testing during the RI. The CPM in Figure 3-1 was developed as an improvement scenario to the baseline CPM and does not include all new SARA provisions. Modifications to the CPM to reflect SARA are reflected in Figures 3-2 and 3-3. They are also discussed in Section 5.0 and shown in Appendix C. EPA has several initiatives under way that will prove instrumental in further reducing project schedules. These include examining strategies to streamline subcontracting procedures, developing expert systems for application to remedial projects, instituting a nationwide treatability/pilot studies subcontracting support system, and developing additional standard technical procedures. Also, the alternate remedial contracts strategy (ARCS) should improve schedule and cost control by keeping more management activities in the Regions. BK4C-4 3-1 ------- PROJECT PLANNING COMMUNITY RELATIONS FIELD INVESTIGATION 8AMPLE ANALYSIS/VALIDATION DATA EVALUATION — ¦ I -| i 1 Interim WP Evaluate Existing initial Information Visit r TAC Mtg. WP Wckofl Initial Held SampMng I Draft WP Preparation EPA/State Review Revision Approval //&/////////. ^ i l—~ Develop / Review/Finalize H&S Draft SAA Plan (PA/State ' Review ^///////////.¦* Approval EPA/Stale Dw®0|)CHP Review "PP!01"" Prepare interim ERA Procurement Documents Review . Y//////////S+ Submittal/Receipt of Procurement Package Prepare Procurement for (tilling Submit for Bid Select/ Approve Driller Drill/ Sample Ground Water Phase I Field Sampling Sample Analysis Data Validation Data Evaluation of Screenig Phase II Samples Scoping RISK ASSESSMENTS TREATABILITY STUDIE8 Rl REPORTS Prepare Preliminary Phase I Rl Report F8 REPORT POST F8 ERA PLANNING Develop Plans/Specs for ERA Figure 3-1 SUMMARY CPM - MODIFIED RI/FS SCENARIO REM 3003 ------- 13 i- Phase II Field Investigation Phase II Sample Analysis/ Data Validation Data Evaluation Analyize/Evaiuate Screening Samples FS Brainstorming Conduct/Complete Treatability Studies FS TDM Review/ Approval PROJECT PLANNING COMMUNITY RELATIONS FIELD INVESTIGATION U> u> 8AMPLE ANALYSIS/VALIDATIOK DATA EVALUATION RISK A8SE8SMENT8 TREATABILITY 8TUDIES Rt REPORTS Phase II Approve z? Phase I Data Review/Evaluation Identify Approval to Treatability/ Commence PUot Studies Pilot Testing *////////////,*- ftaiiow Phase I Rl I FS REPORT P08T F8 REPORT ERA PLANNING ERA Implementation Figure 3-1 SUMMARY CPM - MODIFIED RI/FS SCENARIO (CONT.) ------- 22 PROJECT PLANNING COMMUNITY RELATIONS FIELD INVESTIGATION SAMPLE ANALYSIS/VALIDATIOI DATA EVALUATION U> t -Ft RISK ASSESSMENTS TREATABILITY STUDIES Rl REPORTS F8 REPORT POST FS I Prepare Draft Phase II Rl Report y//////////A- Prepare Final Pase il Rl Report Notice to PRPs 60 Day Moratorium Prepare Draft FS Report EPA/State Review -'/////A. Prepare (or Public FS Comment Prepare PuMIC Responsiveness 01X1 Comment Summary S'fl™*' Complete Pre Design/ Post ROD Activities WA Closeout WACR Preparation ERA PLANNING Figure 3-1 SUMMARY CPM - MODIFIED RI/FS SCENARIO (CONT.) ------- MONTHS 0 ! 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 t I Site TAC P Inspection/Field Screening Work Plan V//A I grilling CLP CD * Data Validation P Alternative Screening & Analysis :~ i ! Phase II S&A Plan, TDM, TAC i Phase II Field Investigation Sample Analysis a Validation Data Evaluation; a FSTDM ~ ; Draft FS Report V/A Moratorium / PRP Negotiations Predesign up ! Close-out &WACR V///////A EPA/State Review FIGURE 3-2 MODIFIED CRITICAL PATH SCHEDULE ------- RI/FS CPM SCHEDULE COMPARISON Baseline CPM Planning | Rl FS POST-FS Updated CPM Planning R11 RI2 FS | POST-FS | Months 12 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 RI/FS COST/RESOURCE COMPARISON f POST-FS Baseline CPM Planning | Rl FS | Updated CPM Planning RI1 I RI2 I FS | K POST-FS Cost ($1,000's) 50 100 150 200 250 300 350 400 450 500 550 600 650 700 750 800 FIGURE 3-3 RI/FS CPM SCHEDULE SCENARIO ANALYSIS 3-6 REM 3003 ------- There have been a series of initiatives proposed by the Agency over the past year aimed at reducing the time necessary to complete an RI/FS while at the same time improving the quality of the analyses completed. These initiatives were evaluated using CPM schedule analyses techniques to determine their usefulness and to quantify any time or dollar savings. If the initiatives could be successfully implemented they were then adopted and incorporated into the modified CPM. The major improvements that were adopted for inclusion in the modified CPM are discussed briefly below and are represented graphically in Figure 3-1. 3.1 PHASED RI/FS APPROACH The modified CPM assumes that the study is executed using the phased RI/FS approach. This type of study execution optimizes data collection activities at a site and results in a more complete and accurate information. Under this type of study execution, the results of each phase will define the scope of work for subsequent phases, increasingly focusing the study to minimize extraneous activities. The development of data quality objectives (DQOs) is an integral part of the phased RI/FS process. DQOs are qualitative and quantitative statements which specify the quality of the data required to support Agency decisions during remedial response activities. Guidance on developing DQOs for a phased RI/FS is available in two EPA documents. Data Quality Objectives for Remedial Response Activities - Development Process (EPA 1987a) and Data Quality Objectives for Remedial Response Activities - Example Scenario (EPA 1987b). During the analysis of any project, three critical factors are evaluated. These factors include scope and quality of work, schedule, and budget. Based upon a preliminary analysis, a phased RI/FS would provide a logical method for the collection of data. This approach will reduce the potential for collection of unnecessary or inadequate data and improve the overall data base for a site, thereby improving the quality of the FS. Most importantly, however, is that it will allow site investigation work to be focused earlier in the process and reduce the number of alternatives that need to be analyzed through earlier data evaluation. This focusing of data collection and alternative analysis will save both time and money compared to current RI/FS studies. A comparison of the existing RI/FS process to the phased approach is summarized in Figure 3-3. BK4C-4 3-7 ------- The use of the phased approach during the execution of an RI/FS can reduce time and cost for several reasons: • The study is initiated more quickly since the work plan only details the first phase of field investigation and provides less refined estimates of later stages. This allows a smaller plan to be written in a shorter time, which should result in a more expedited review. • Convening a Technical Advisory Committee (TAC) early on in the project planning phase and at other critical milestones will provide better directions for the design of the study and will also result in a more focused study plan. • Completing an initial limited field investigation during the project planning phase will provide a conceptual model of the site early, which will allow later sampling programs to be confirmatory in nature and more focused. Also, data analyses and feasibility study tasks can be initiated early based on the early data results received. • The phased RI/FS process will better optimize environmental sampling and well locations established in earlier phases thereby reducing costs for some of the major tasks of the investigation. There are various implementation options that can be considered for a site depending on the waste sources present, the amount of data available characterizing the onsite problem, and the remedial options available to clean up the site. A flow chart describing several of the major remedial implementation options and a number of decision points is presented in Figure 3-4. Depending on the site characteristics, the study can proceed along any of the paths diagrammed in Figure 3-4. The phased RI/FS process, which involves staged data collection activities, is the optimum study design for most sites where remedial investigations will occur. 3.2 STREAMLINED PROJECT PLANNING The existing project planning phase often takes over 6 months to complete and usually does not include field work or site data collection. In addition, current implementation depends on a series of key deliverable reviews that potentially stop work execution (e.g., review of draft work plan), which disrupts resource utilization and puts the schedule on hold. In the modified schedule analysis several elements have been adopted which streamline the project planning phase so that it can routinely be completed in less than 4 months. The cost for the execution of the project planning phase is now higher than in the baseline analysis. This is because field work is now included in the cost, and because other non-administrative tasks are now completed earlier on in the project. The major changes that are recommended are described below. BK4C-4 3-8 ------- WA INTIAL SITE VISIT AND DATA EVALUATION LFI n FS ROD \ TECH ADVISORY COMMITTEE / f © WORK PLAN \ N OPTIONAL TECH ADVISORY COMMITTE FS ROD vo LRI ERA JUSTIFICATION ACTION MEMORANDUM DESIGN EXECUTE (^) — Work plan includes detailed Scope and Budget for Rl & ERA (FS & ROD if non-phased) General Scope & Budget for RI/ERA/FS/ROD if phased ERA - Expedited Response Action FFS - Focused Feasibility Study FS - Feasibility Study LFI - Limited Field Investigation Rl - Remedial Investigation - Phase 1 Rl - Remedial Investigation - Phase 2 ROD - Record of Decision WA - Work Assignment FIGURE 3-4 IMPLEMENTATION OPTIONS FOR REMEDIAL WORK ASSIGNMENT ------- Standard Task Structure Over the past year, the Agency has been developing a standard task structure that will be used for all RI/FS assignments. A standard task structure results in several important improvements, including the following: • Achieves consistency among all parties conducting RI/FSs • Allows standard management information systems and reporting requirements to be established • Allows the Agency to develop a better data base on task duration and tasks which will assist in the management of ongoing studies and estimating new studies A new set of RI/FS tasks has now been established which will be employed for all RI/FS work. The tasks are listed in Table 3-1. The use of these tasks will improve overall effectiveness by enabling contractors to operate under a consistent set of tasks. It will also improve schedule and cost tracking throughout the RI/FS process. The standard tasks are decribed in OSWER Directive 9242.3-7. Standard Formats and Document Consolidation Appendix A presents standard outlines for work plans and S&A plans. Adherence to these outlines in the document development will expedite review and approval, and enhance the contractors' overall ability to meet work assignment schedules. The outline for the S&A plan incorporates the components of the QAPP. This is one means of reducing redundancy between documents and thereby streamlining project planning. The updated RI/FS guidance (under development by EPA) should be consulted for standard formats for RI and FS reports. Standard Procedures The use of standard procedures for RI/FS activities can save time in review of S&A plans, as well as ensure consistent and controlled quality of results. S&A plan review time is reduced by eliminating technical review of procedures that have already been approved for use in the Region. If site-specific changes must be made to a procedures, it will require technical review. The use of standard procedures for RI/FS activities assures EPA of reliable data and that results will be comparable between sites. BK4C-4 3-10 ------- TABLE 3-1 RI/FS STANDARD TASKS Task Title 1 Project Planning 2 Community Relations 3 Field Investigation 4 Sample Analysis/Validation 5 Data Evaluation 6 Assessment of Risks 7 Treatability Study/Pilot Testing 8 Remedial Investigation Reports 9 Remedial Alternatives Screening 10 Remedial Alternatives Evaluation 11 Feasibility Study (RI/FS) Reports 12 Post RI/FS Support 13 Enforcement Support 14 Miscellaneous Support 15 ERA Planning BK4C-3 3-11 ------- Initial Site Characterization At many sites a short site characterization round of sampling is conducted during the project planning phase. This short general site characterization task has proved to be extremely useful and has been adopted in the modified CPM. This site visit/sampling task occurs early on in the study and relies on screening type sampling and analysis. The initial site characterization may also be strongly supported by development and implementation of the expanded site investigation concept, which is currently being developed by a work group. Technical Direction Memorandum (TDM) The new work assignment procedures proposed by EPA include a provision for using a Technical Direction Memorandum (TDM) to easily modify work execution at an EPA Regional level if the changes are within the overall scope and budget of the assignment. TDMs are used at key intervals in the modified CPM to initiate new phases of study and to execute tasks that were defined in general terms in the work plan. Early Technical Advisory Committee (TAC) Review Incorporation of TAC review into project planning through review of the draft work plan can improve the quality of the document, expedite EPA intra-Agency review through early identification and resolution of technical flaws, and provide a more technicallly sound direction for the project from the outset. The reservoir of knowledge gained through senior level staff experience is thus made available to less experienced project managers or those without technical knowledge in specific areas. 3.3 MANAGEMENT OF HANDOFFS AND STREAMLINED CRITICAL ACTIVITIES When activities lie on the critical path of a project, they have the potential to directly impact the project schedule. When delays occur with these activities, the completion of the RI/FS is inevitabley postponed. These are exactly the types of events that this analysis has sought to identify and resolve. The principal recommendation associated with project handoffs, if they are necessary, is to avoid structuring them as critical activities. BK4C-4 3-12 ------- Data Validation and Pre-Analysis of Data As discussed in Section 2.0, data validation has been identified by the Regions as one of the most persistent problems in causing RI/FS delays. To avoid or minimize this problem, RPMs are encouraged to consider alternatives which will allow contractors access to the data as early as possible to expedite evaluation of remedial alternatives. One method is to release unvalidated data to the contractor, to allow data evaluation to begin concurrently with validation of the data. Another alternative is to allow the contractor to provide data validation services, in accordance with EPA procedures, and with audits by EPA Regional personnel. Intra-Agency Reviews EPA intra-Agency and State reviews are also sources of project delays, especially when they are associated with an activity that has a direct impact on the project schedule. OERR recommends that the Regions limit intra-Agency reviews to contractual deliverables, the work plan, community relations plan, and S&A plan, and to rely on contractor internal review mechanisms to a greater degree. The RPM should still be involved in review of interim deliverables as part of his or her responsibilities for overseeing management of the project. Schedule Commitments A problem that has arisen with document reviews as well as sample analysis and data validation handoffs has been that the recipient of the project responsibility is often not held responsible for meeting the project schedule requirements that the RPM is committed to. Whenever possible, the RPM should obtain a commitment from the recipient to meet a reasonable deadline in completing their project activities. This commitment must also be supported by the recipient's supervisor to be fully effective. Such arrangements should be made at the appropriate administrative levels for the particular job at hand. BK4C-4 3-13 ------- Pilot/Treatability Testing The potential for completing pilot or treatability testing has been incorporated into the modified CPM schedule. Because this task often takes numerous months to complete and because its results are used in alternative selection and other FS tasks it remains on the critical path. However, by using data from the first RI phase and conducting the testing while the second RI phase is under way, the schedule impact of this key task is minimized. Screening Analysis Results Screening samples (quick turnaround. non-CLP analysis) are taken during initial site characterization and during the first major field investigation. The results of these visits can provide an accurate conceptual model for the site, the pollutants of concern, and the extent of contamination. The modified CPM relies on the use of screening sample results to provide a first level conceptual model of the site, to develop an initial set of remedial alternatives, and to allow the first screening of alternatives to be completed quickly and reliably. The modifications and improvements discussed above and included in the modified CPM are intended as guidance as new RI/FS studies are planned and as ongoing assignments are amended. There are many ways to execute an RI/FS at a particular site and the implementation options across all NPL sites is endless. However, if the improvements discussed in this section are adopted, time and cost savings can be realized at most sites. BK4C-4 3-14 ------- 4.0 QUALITY CONTROL INITIATIVES FOR THE RI/FS PROCESS EPA management has been delegating an increasing amount of responsibility for the RI/FS process to the Regions. This delegation of responsibility is consistent with improving responsiveness to Regional concerns as well as increased efficiency and cost-effectiveness for the overall Superfund program. It is EPA's responsibility to ensure that Superfund remedial actions meet the intentions of the law fully, are legally defensible, and are implemented in a cost-effective and timely manner. To meet these obligations. EPA must ensure that the RI/FS process is conducted at a high level of efficiency and that the quality level is comparable and consistent among the EPA Regions. The objective of this section is to provide the Regions with an evaluation methodology for quality control (QC) of contract deliverables during the RI/FS process, from initial issuance of the work assignment through submittal and approval of the work assignment completion report (WACR). This methodology provides a framework for maintaining the quality of the RI/FS process while allowing flexibility in the specific implementation procedures. It also provides a mechanism for State involvement as required by SARA. The goal of integrating these QC reviews into the RI/FS process is to insure clear communication between EPA. the State, and the contractor early in the planning process and at project milestones, thereby keeping projects on track and resulting in project deliverables that meet project requirements with a minimum of revisions. Contractors currently executing RI/FS investigations have internal technical review procedures or systems in place to monitor the quality and completeness of deliverables submitted to EPA. Because of resource constraints, the Regions are not always able to complete detailed multidisciplinary reviews for major deliverables submitted by these contractors. Therefore, the methodology developed herein requires that the EPA Regions, at a minimum, oversee the contractors' management and quality control systems and not duplicate their detailed level of review. The methodology will also be useful in the near future when the alternate remedial contract strategy (ARCS) is initiated. The methodology will assist the Regions to determine a contractor's eligibility for future projects or extension of contract upper limits. The methodology outlined in this section is not intended to be a completeness checklist for each of the RI/FS deliverables. Rather, the evaluation methodology describes an approach which outlines criteria to be used during project milestone evaluations. BK4D-2 4-1 ------- Quality control reviews are conducted to evaluate the following: • Data quality or the accuracy of all data contained in the report • Technical content for adequacy, defensibility and merit • Contractual performance to ensure compliance with the requirements of the contract and scope of work in the work plan Characteristics of data quality include precision, accuracy, representativeness, completeness and comparability. Evaluations of data quality are done through cross-checks of calculations, specifications, plans, and diagrams. Quality control for data quality will remain the responsibility of the remedial contractors and will be performed in accordance with quality assurance project plans. Quality control activities of the REM contractors will be subject to EPA Regional audits. The focus of the QC portion of the RI/FS process is the evaluation of technical adequacy in compliance with contractual requirements. To ensure that the RI/FS process results in technically sound remediation, evaluation criteria which are applicable to each stage of the RI/FS process are necessary. A three-tiered QC process will consist of the following components: 1. Regional technical reviewer(s) who will review key deliverables and work products (e.g.. ground water models, risk assessment, etc.) 2. Remedial project manager(s) who will be responsible for ensuring the consistency and quality of the work for a particular site 3. Regional manager(s) (Regional Project Officer, Section Chief. Branch Chief) who will be responsible for ensuring consistency of assessments and response actions across sites The RI/FS process consists of a sequence of tasks which are interdependent. Reviews of deliverables and audits may be insufficient to ensure quality RI/FS decisions; therefore, an evaluation process will be implemented which consists of five QC review stages. These stages cover ongoing RI/FS work and are established to correspond with the endpoints of key project phases. The five RI/FS QC review stages are: • QC Review Stage 1 - Formal discussion of draft work plan prior to initiation of major field activities. This stage will include review of available data and known or suspected contamination. It will focus on scope of work and data needs for RI report including development of data quality objectives. Screening of remedial technologies will also occur at this stage. BK4D-2 4-2 ------- • QC Review Stage 2 - A Technical Advisory Committee (TAC) meeting will be conducted upon completion of the first phase of sampling. The meeting will include a review of data collected, identification of data gaps, revision of the scope of work if necessary, and identification of remedial alternatives. At this point, data quality objectives for subsequent data collection efforts will be developed. 0 QC Review Stage 3 - TAC and pre-FS meetings will be held after treatability, bench, and. if appropriate, pilot studies have been performed and field work has been completed. The evaluation of remedial alternatives will be conducted using all field data and test results. Final findings will be incorporated in the FS for public comment. o QC Review Stage 4 - A meeting will be conducted following the preparation of the FS for public comment. The contractor will also ensure that the data and the RI/FS structure are sufficient to support the ROD. • QC Review Stage 5 - A responsiveness summary will be prepared and a final evaluation of alternatives will be developed prior to the Record of Decision (ROD) and design. A close-out meeting will be held at the end of the project to finalize and reconcile all project accounts, make sure all contractual obligations have been fulfilled, and develop and submit a final WACR. These QC reviews are recommended project QC milestones. A summary of how the QC reviews fit in with the RI/FS standard tasks and deliverables is shown in Table 4-1. The listed reviews and procedures that follow constitute the model that headquarters will use to evaluate the Region's oversight of remedial contractors. Therefore, Regions are encouraged to develop procedures consistent with this model when evaluating the quality of contractor deliverables. Activities in the RI/FS process may overlap as work is staggered to streamline the overall approach. Therefore, the reviews defined above can serve as both a means to ensure consistency between the different stages and to keep the phased RI/FS studies moving ahead as planned. The ultimate responsibility for Superfund activities in each region rests with the Regional Administrator. The Waste Management Division is responsible for management of hazardous waste programs as required by RCRA, CERCLA and SARA. Responsibility for each QC review is summarized in Table 4-2. The table identifies key reviewers and appropriate approval and sign-off responsibilities. BK4D-2 4-3 ------- TABLE 4-1 RI/FS PROCESS WITH QC REVIEWS RI/FS Standard Tasks Project Planning Phase Project Planning Remedial Investigation Phase Field Investigation Sample Analysis/Validation Data Evaluation Risk Assessment Treatability Study/ Pilot Testing RI Report Alternative Screening Feasibility Study Phase Alternative Evaluation FS Report Post RI/FS Phase Post RI/FS Support Enforcement Support ROD Support RI/FS Deliverables QC Review Work Plan Memo Initial Brainstorming Session Work Plan. Draft & Final QC Review 1 First Phase S&A Plan (all planning (draft & final) activities) First Phase Results and TDM/S&A Plan for Second Phase Second Phase Results QC Review 2 First Phase results Pre-FS Meeting RI Report (draft & final) QC Review 3 (Second Phase results) Bench/Pilot Test Results FS Report (draft & final) QC Review 4 Responsiveness Summary Predesign report Closeout QC Review 5 (WACR) BK4D-3 4-4 ------- QUALITY CONTROL REVIEWERS AND APPROVAL RESPONSIBILITIES TABLE 4-2 QUALITY CONTROL REVIEWERS AND APPROVAL RESPONSIBILIT1 QC Review Stage QC Reviewers Approval 1 SR, TAC. QAO RPO. RPM 2 SR, TAC RPO, RPM 3 SR, TAC RPO, RPM, 4 SR. TAC RPO. RPM, WMD 5 SR. TAC RPO. RPM WMD - EPA Waste Management Director RPO - EPA Regional Project Officer RPM - EPA Remedial Project Manager QAO - EPA Quality Assurance Officer (audits) SR - State Representatives TAC - Technical Advisory Committee members, as appropriate * QC measures will include individual reviews and TAC meetings as appropriate BK4D-4 4-5 ------- The documentation of all reviews conducted by the technical specialists or individual EPA staff or managers is critical to quality control. Forms to document reviews may include the following: • Document number • Work assignment and site • Deliverable type (report type and draft, final, revision number) • Schedule (submitted date for review, scheduled review date, actual review date) • Reviewers (comments, review signature and date) • Approval/certification (signature and date) In addition there should be documentation of the response to each reviewer's comments (i.e., how it was reconciled and what corrective actions were taken). The EPA Administrator is legally responsible for all technical work performed under the Superfund program. Therefore, to assure quality and consistency among the Regions, Headquarters will conduct periodic reviews of the Regional work, including Records of Decision (RODs). These quality assurance functions may include scheduled or unscheduled reviews. BK4D-2 4-6 ------- 5.0 EFFECT OF SARA ON RI/FS EXECUTION There are a number of provisions that were included in the Superfund Amendments and Reauthorization Act of 1986 (SARA) that have a direct impact on the execution of a typical RI/FS. In addition to the many schedule requirements and new enforcement provisions, SARA includes requirements that impact remedy selection, involve the States and citizens in the decision-making process to a greater degree, and allow PRPs greater time to evaluate proposed remedies at a site. All of these elements impact both the cost and schedules of RI/FS assignments. While this section is not intended to be an exhaustive analysis of SARA it will point out the key SARA provisions that have been included in this RI/FS analysis report and how they impact the CPM schedule for a typical RI/FS. What this analysis has shown is that SARA will have a major impact on the execution of every major RI/FS completed by EPA. the States or by responsible parties. Based on currently available information, the updated CPM model and analyses have shown that the new provisions have the potential for adding over 3 months to the typical RI/FS schedule and may increase costs by up to 3 percent. The actual impact of SARA on costs and schedules for RI/FSs will be more certain after more experience is gained under the new requirements. Currently, OERR's intent is to offset any increases through improved efficiency and effectiveness in the conduct of remedial projects, particularly in the project planning phase. Major SARA Provisions Analyzed While there are numerous changes that will occur as a result of the implementation of SARA, only those that have a direct bearing on the RI/FS schedule were included in the revised SARA CPM (Appendix C) schedule at this time. This schedule was designed to include all pertinent SARA requirements and to estimate the resultant cost and schedule impacts. The elements that have been included in the modified CPM analysis are summarized below. State Involvement - State involvement in the RI/FS process is accomplished by including State personnel in TAC meetings and through review of key deliverables. States may also be involved in review of the draft ROD PRP negotiations. The State is responsible for notifying EPA of applicable or relevant and appropriate requirements (ARARs). BK4E-2 5-1 ------- ATSDR Involvement - The Agency for Toxic Substances and Disease Registry (ATSDR) will receive the Preliminary Summary of the Site Investigation (PSSI). as well as draft and final RI reports completed by the Agency's contractors or the States. In addition. ATSDR will be responsible for preparing a health assessment for the site. Presently. ATSDR acts as a consultant to the process, therefore, it is assumed that their involvement does not impact the critical path schedule. PRP Negotiations - PRPs are now more actively involved in the RI/FS process. They have more opportunities to review project documents in addition to several moratorium periods in which they can determine the degree of continuing involvement of site activity. This additional level of involvement is on the critical path and does have an impact on the RI/FS duration. Emphasis on Selection of Permanent Remedies - SARA calls for the Agency to concentrate on remedies that use treatment to permanently and significantly reduce the mobility, toxicity, or volume of wastes over those remedies that do not. While the analyses conducted to better evaluate permanent remedies are no more extensive than current FS analyses, additional time has been built into the modified CPM schedule to ensure complete alternative evaluation and to comply with this new SARA requirement. Pilot/Treatability Testing - The modified CPM includes the provision to perform pi lot/treatability testing as needed as part of the RI analyses. The results of these studies will be available prior to the FS and will strengthen support for more permanent types of remedies. SARA Impacts not Analyzed While many of the major SARA provisions and their impact of RI/FS execution have been analyzed in the modified CPM schedule, several elements have not been analyzed at this time. For example, some of the SARA provisions will affect the time needed to complete typical RI/FS tasks. However durations of individual tasks have not been modified until more knowledge on task execution under SARA is gained. In addition, the degree of citizen involvement in the execution of an RI/FS under SARA has not yet been determined. The increased emphasis placed on citizen involvement under SARA could have major impacts on study durations at some sites where there is a high degree of community involvement. BK4E-2 5-2 ------- 6.0 REFERENCES CH2M Hill. 1985. Analysis of Superfund RI/FS Program Requirements. ICF Incorporated. 1985. Assessing the Superfund Remedial Investigation and Feasibility Study Process. U.S. Environmental Protection Agency (EPA). 1987a. Data Quality Objectives For Remedial Response Activities - Development Process. OSWER Directive 9355.0-7A. Office of Emergency and Remedial Response, Office of Waste Programs Enforcement, Office of Solid Waste and Emergency Response. Washington, D.C. . 1987b. Data Quality Objectives for Remedial Response Activities - Example Scenario: RI/FS Activities at a Site with Contaminated Soils and Ground Water. Office of Emergency and Remedial Response. Office of Waste Programs Enforcement, and Office of Solid Waste and Emergency Response, Washington, DC. Center for Environmental Research Information. Cincinnati, Ohio. EPA/540/G-87-004. . 1987c. Superfund Federal-Lead Remedial Project Management Handbook. Office of Emergency and Remedial Response. Washington, D.C. EPA/540/G-87/001. . 1987d. Superfund State-Lead Remedial Project Management Handbook. Office of Emergency and Remedial Response. Washington. D.C. EPA/540/G-87/002. . under development. Updated Guidance on Remedial Investigations. Office of Emergency and Remedial Response, Washington. D.C. . under development. Updated Guidance on Feasibility Studies. Office of Emergency and Remedial Response, Washington. D.C. BK4-15 6-1 ------- APPENDIX A GENERIC REPORT OUTLINES ------- GENERIC OUTLINE SAMPLING AND ANALYSIS PLAN 1.0 INTRODUCTION 2.0 PROJECT DESCRIPTION 2.1 General 2.2 Background 2.2.1 Site History 2.2.2 Environmental Setting 2.3 Project Objectives 2.3.1 Media Number, Location 2.3.2 Reference Maps 2.4 Schedule 3.0 PROJECT ORGANIZATION AND RESPONSIBILITY 3.1 Project Organization 3.2 Site Management 3.2.1 Site Security 3.2.2 Site Operations 3.2.3 Contingency Plan 3.3 Subcontractors 4.0 QUALITY ASSURANCE OBJECTIVES 4.1 Legal Requirements 4.2 Quality Assurance Measures 4.2.1 Field Investigations 4.2.2 Sample Collection 4.3 Accuracy, Precision, and Sensitivity of Analysis 4.4 Completeness, Representativeness, and Comparability BK4A-3 ------- GENERIC OUTLINE SAMPLING AND ANALYSIS FLAN (continued) 5.0 SAMPLING PROCEDURES - REFERENCE STANDARD PROCEDURES 6.0 SAMPLE AND DOCUMENT CUSTODY PROCEDURES 7.0 CALIBRATION PROCEDURES AND FREQUENCY 8.0 ANALYTICAL PROCEDURES 9.0 DATA REDUCTION, VALIDATION, AND REPORTING 10.0 PERFORMANCE AND SYSTEM AUDITS 12.0 PREVENTIVE MAINTENANCE 13.0 DATA MEASUREMENT ASSESSMENT PROCEDURES 14.0 CORRECTIVE ACTION 15.0 QUALITY ASSURANCE REPORTS TO MANAGEMENT BK4A-3 ------- GENERIC OUTLINE WORK PLAN PREPARATION VOLUME I - TECHNICAL SUBMITTAL Title Page Cover Letter (Transmittal Letter) Sign-off Page 1.0 INTRODUCTION/BACKGROUND 1.1 Site Location and History 1.2 Site Status and Project Type 1.3 Overview 2.0 INITIAL SITE EVALUATION 2.1 Site Description 2.2 Contamination Problem Definition 2.3 Contaminant Migration/Environmental Health Effects 2.4 Initial Remedial Measures 3.0 PRELIMINARY ASSESSMENT OF REMEDIAL ALTERNATIVES 3.1 Identification of Remedial Alternatives 3.1.1 Performance Criteria/Standards of Remedial Alternatives 3.1.2 Approach to Alternative Evaluation 3.2 Identification of Data Requirements 3.3 Remedial Investigation/Feasibility Study Objectives 4.0 REMEDIAL INVESTIGATION SCOPE OF WORK 4.1 Project Operations Plan 4.1.1 Study Area Survey 4.1.2 Source Characterization 4.1.3 Site Characterization 4.1.4 Identify ARARs BK4A-5 ------- GENERIC OUTLINE WORK PLAN PREPARATION (continued) 4.2 Feasibility Study Testing 4.3 Data Validation 4.4 Contaminant Pathway and Transport Evaluation 4.5 Public Health Evaluation 4.6 EPA Designated Activities 4.7 Remedial Investigation Report 4.8 Community Relations 4.9 Quality Assurance 4.10 Technical and Financial Management 5.0 FEASIBILITY STUDY SCOPE OF WORK 5.1 Preliminary Remedial Alternative Development 5.2 Remedial Alternative Screening 5.3 Remedial Alternative Analysis 5.4 Comparative Evaluation of Acceptable Alternatives 5.5 Feasibility Study Report 5.6 EPA Decision Document Preparation Assistance 5.7 Pre-Design Report 5.8 Community Relations 5.9 Quality Assurance 5.10 Technical and Financial Management 5.11 Work Assignment Completion Report BK4A-5 ------- GENERIC OUTLINE WORK PLAN PREPARATION (continued) 6.0 SCHEDULING 7.0 STAFFING/PROJECT ORGANIZATION 8.0 SUBCONTRACTING PLAN 9.0 SPECIAL EQUIPMENT NEEDS VOLUME II - COST SUBMITTAL Title Page 1.0 INTRODUCTION 2.0 BUDGET 2.1 Work Assignment Form (WAF) 2.2 Optional Form 60 2.3 Labor Costs - (by phase) 2.4 Expenses - (by phase) 2.5 Other Direct Costs - (by phase) BK4A-5 ------- APPENDIX B QUESTIONNAIRE RESULTS ------- QUESTIONNAIRE SUMMARY The following were identified as the causing the most problems in creating project delays: ¦ Data validation • Approval of project planning documents • Sample analysis by CLP • Work plan scope and cost negotiations • State review of documents The following were identified as causing the least problems in creating project delays: • Equipment shortages/delays • Contractor staff shortages • EPA staff shortages • Obtaining staff access • Obtaining CLP slots Other chronic problem areas identified were QAPP and S&A plan review and approval and a lack standardized document formats and review procedures. Respondents were requested to rank project planning documents according to their practical usefulness in day-to-day project operations. The responses indicated the following ranking of planning documents: 1. Work plan 2. Sampling and analysis plan 3. Quality assurance project plan 4. Interim report 5. Community relations plan 6. Health and safety plan 7. Work plan memorandum BK4B-10/1 ------- The work plan and sampling and analysis plan were both ranked as critical by 37 of the 45 respondents. The health and safety plan and quality assurance project plan followed; they were both ranked as critical by 26 of the 45 respondents. The work plan memorandum was indicated most frequently as a noncritical document; 29 respondents labeled it as noncritical. Surprisingly, the work plan was rated as noncritical by three respondents and the sampling and analysis plan was rated noncritical by one respondent. Respondents identified a reasonable time frame for project planning ranging from 1 to 6+ months. The most frequently indicated time frames were between 2 and 4 months. Good communications between contractors and EPA was identified as consistent factor in successful projects. In particular, project review meetings were felt to give contractors direction, keep projects on track, identify problems early, and generally result in improved performance and communication. Other factors identified as helpful in improving project performance included use of interim deliverables and approvals, turning data over to contractors prior to completion of validation, and field screening of samples. Setting strict time frames for submittal and review of documents has yielded mixed results, making their value in improving performance inconclusive. Respondents felt that the usefulness of the award fee could be improved as a project management tool. Low scores were felt to lead to improvement of contractor performance, but not necessarily over the long term. A larger award fee pool, larger percentage of fee contingent on performance, and revised criteria were among the suggestions for improvement. Respondents were supportive of the use of expanded site investigations as a potential tool for expediting the project planning process. Issues raised on ESIs included the use of remedial contractors for conducting the ESIs and conduct of ESIs under remedial program lead. BK4B-10/2 ------- INTRODUCTION This document presents the compiled results of the RI/FS analysis questionnaire which was distributed to the regions in November 1986. The results are transcribed literally from the handwritten responses, except for minor changes for consistency in the document, spelling, and grammar. Some respondents indicated that they lacked experience to answer specific questions. These responses were not included in this compilation because they did not provide information relevant to the issues at hand. ------- DOCUMENT RANKING TALLY RESPONSES TO QUESTION 1A RANK DOCUMENT 1 2 3 4 5 6 7 8 CRITICAL Work Plan Memorandum 2 1 3 4 2 1 7 8 2 Work Plan 36 2 1 - 1 1 - - 37 Interim Report - 2 3 10 6 4 4 2 13 Health and Safety Plan 1 6 6 2 6 9 5 1 26 Sampling and Analysis Plan 4 21 7 6 - - - - 37 Quality Assurance Project Plan 3 7 8 5 8 5 1 1 26 Project (site) Operations Plan 4 5 5 2 - 2 5 2 16 Community Relations 29 3 21 11 II 14 Plan 13469734 t8 17 Others Risk Assessment(l) I ..... i Existing Site Conditions Memo(2) ........ . | Note: Tally indicates number of respondents that marked designated rank for that document, e.g., 36 individuals ranked work plan as no. 1,2 individuals ranked it as no. 2. ------- lb. Where are there redundancies between documents? Health and safety, sampling and analysis, and QAPP are generally part of site operations plan.(II-l) Primarily between the POP, H&SP, and QAPP. The latter two should be incorporated into the POP for consolidation of work and elimination of duplicate efforts. (II-2) QA plan, sampling and analysis plan and health and safety plan usually are and should be part of the POP. (II-3) 1. Work plan/POP 2. POP/SAP/QAPP (II-4) Work plan memorandum and work plan redundant. Work plan is more useful. (II-7) The health and safety plan, sampling and analysis plan, and quality assurance project plan should all be part of the project operations plan. (II-8) Most RPMs see redundancies between the work plan, S&AP and QAPP. (V-S) Region V Quality Assurance Office requires much of the same background information in the QAPP as is required in the work plan. If interim reports or work plan memos are required, information is also often redundant. (V-l) The work plan, sampling and analysis plan and the QAPP all contain some overlap with each other. (V-2) 1. S&AP should be issued only as an appendix to QAPP. It's frequently done that way now- but it is sometimes issued as a separate deliverable too. 2. Operations plans should be another term for site work documented in QAPP or S&AP. 3. Work plan memo should be much shorter than current format. (V-3) Work plan memorandum seems pretty worthless. Work plan and sampling plan are somewhat redundant-sampling plan is part of QAPP. (V-5) Work Plan memo is unnecessary. Interim reports should be incorporated directly into final reports with minimal changes. (V-6) Yes, between work plan and sampling and analysis plan, and site operations plan. (V-7) The QAPP could contain the sampling plan, work plan and site operations plan. The work plan usually includes the information in the work plan memorandum. (V-8) The WP and QAPP often repeat information (IV-1) S&A plan/QA/QC plan POP/WP (VI-3) Work plan/sampling and analysis plan/QAPP (VI-4) H&S plan, QA/QC plan, and sampling plan actually comprise the work plan. (VI-7) ------- lb. Where are there redundancies between documents? Sampling & analysis plans are typically extremely similar to, or may replace work plans. QAPPs may also overlap with S&A plans. (VI-8) Sampling & analysis and POP. (VI-9) Depends who writes them - CDM and Hill both are different Ideally all "planning" and field information could be contained in two documents; the work plan and the sampling and analysis plan. The QAPP and POP should be rolled into these. (VI-10) Sampling/analysis plan and health/safety are often part of the overall work plan. (VI-11) Safety plan & QAPP (VI-12) Work plan and project operations plan (ie., all material could be incorporated into one document). (VI-14) All of the above, site history, introduction, site description. (VII-1) Between work plan and WP memo, but necessary. (VII-2) Region VII Quality Assurance Officer requires the QAPP to follow the document "Guidance for Preparation of combined Work/Quality Assurance Project Plans for Environmental Monitoring." This causes a duplication between the work plan and QAPP. Background information is always put at the beginning of every document, causing duplication. (VII-3) QAPP and SAPP: much redundancy Work plan memorandum and interim report Work plan, POP, SAP and QAPP all contain same background and objectives section. (IX-S) Sampling and analysis plan and quality assurance project plan contain background information and objectives from the RI/FS work plan. (IX-1) Project operations plan sounds like the work plan—is it similar? (IX-2) Some redundancy exists between quality assurance project plan and sampling and analysis plan. These two documents could be integrated more efficiently. (IX-3) Much redundancy between QAPP and SAP (sampling methods). (IX-4) Work plan memorandum and interim report are redundant because they are iterations of the work plan. (1X-5) There is some overlap between the work plan, the project operations plan, the SAP, and the health and safety plan. (IX-6) Sampling plan and QAPP often duplicate information. (IX-7) Sampling plans and QAPPs overlap in content. Work plan and project operations plans overlap some. (IX-8) ------- lc. What document reviews are required to ensure the quality of project deliverables (RPM, State, etc.)? How are the results of these reviews documented? Enforcement and remedial RMs, state counterparts ESD review of sampling and QA plans Also on case by case basis, RCRA, SDWA, GW counterparts Also, in special cases, PRP reviews are documented in comment letters or memos. (II-1) RPM reviews all the above especially WP and POP. State reviews solicited for WP, POP, HASP, and CRP. Comments are transmitted and acknowledged in correspondence between EPA and the state. (II-2) RPO - documented in letter form RPM - documented in letter form State - documented in letter form Local (i.e. town and county) - documented in letter form. (II-3) Work plan - RPM and state - correspondence, meetings SAP, POP. QAPP - RPM, State. ESD-QA - memos, correspondence, meetings. (II-4) Reviews completed by RPM, NJDEP and the Corp of Engineers. Results are documented by meeting notes, revised reports and addenda to reports.(II-6) RPM, QA officer, state Comment letter to contractor. (II-7) The state submits comments in writing to the RPM, who reviews them and includes the comments he/she agrees with along with his/her own comments in a letter to the contractor. The enforcement counterpart and RPM's section chief many times review the documents and submit comments. The POP is reviewed by the Environmental Services Division in Region 2. (II-8) Work plan, QA/QC plan, and expeditious review of analytical data as it comes in. RPM and review personnel shouldn't wait for RI/FS report to review data. (III-2) It is critical to have state/regional reviews of the work plan and the S&AP. Appropriate program specialists review the CRP, QAPP and H&SP. (V-S) Work plan - RPM, state Health & safety plan - RPM. state Quality assurance project plan - RPM, state, QAO Sampling plan - RPM, state, QAO Community relations plan - RPM, state, OPA (V-l) 1. Contractors internal review - none 2. U.S. EPA review - comments generated and submitted to contractor. 3. QAO review of QAPP - comments transmitted to RPM for transmission to contractor. 4. State review - comments submitted to RPM for transmission to contractor (V-2) ------- lc. What document reviews are required to ensure the quality of project deliverables (RPM, State, etc.)? How are the results of these reviews documented? 1. RPM in on formulation of document to guide contractor direction and assumptions 2. Concurrent RPM/state review with REM internal review (I & 2 desirable, rarely done, never required) 3. State and regions generally have technical stafF to review and comment on appropriate sections of deliverables. Internal memos generally issued to RPM, who forwards them to contractor. Conference calls and meetings expedite process. 4. Outside review by additional subcontractors or HQ sometimes needed. These comments frequently not documented. (V-3) All documents are reviewed by RPM and state PM. Results not always formally documented. (V-4) Presently RPM, state, sometimes supervisor (seldom). Regional proposing - experienced RPMs will review other less experienced. (V-5) Documents Where Review is 1. Documents Needing Review Helpful but Not Essential Work plan Community relations plan Sampling plan H&SP Interim reports QAPP 2. Results are documented by a transmittal letter/memo which outline the necessary changes/modifications followed by the acceptance of the revised document. V-6) Work plan, QAPP and sampling plan reviews are important and usually reviewed by RPM and state and QAO. Sometimes state QAO reviews QAPP, too. (V-7) Reviews are documented using telephone, memo, and letters and by marking the document. (V-8) Fund lead - RM State lead - RPM and state Results of reviews documented in letters. Approval of WP may be verbally given; however, must be followed up with a letter. (VI-1) a. RPM and state in state lead and RPM in federal lead b. In letters (to states and/or contractors) stipulating necessary revisions to documents. (VII-2) RPM and state for state lead projects. Results of reviews documented in letters to the state requesting the revisions. (VI-3) Work plan - RPM, state, USACE, ATSDR QAPP and sampling & analysis plan - RPM, Quality Assurance Office Community relations plan - RPM, comm. relations staff, state programs staff All other documents - RPM only Documentation by letter/memo response to RPM. (VI-4) ------- lc. What document reviews are required to ensure the quality of project deliverables (RPM, State, etc.)? How are the results of these reviews documented? RPM review of all documents CDC review of sampling and analysis plan. (VI-5) RPM, state, CDC (sampling and analysis plan). (VI-6) Work plan, QA/QC plan, sampling plan, community relations plan. Documented through approval or comment letters to submitter. RPM reviews are provided to PRPs in writing and often later discussed. (VI-8) RPM and state. State submits comments, RPM makes written comments. (VI-9) 1. In-house contractors 2. RPM—EPA 3. RPM's supervisor 4. State Many times the different reviewers' comments are not documented to any great extent. The different comments are reflected in new drafts. (VI-10) Very little input from the state. Review comments are documented in memoranda or letters and placed in the project file. (VI-11) RPM and state review are both needed for each; QA officer should review QAPP; review generally documented in letter to contractor. (VI-12) Assuming the project is enforcement-lead conducted by PRPs, the RPM and EPA contractor conduct reviews. EPA's contractor sends formal comments to the RPM and these comments are combined with the RPMS's comments and incorporated into a formal response to the report writers. (VI-14) Preliminary draft Draft Final draft (optional) (VII-1) RPM review of work plans; Environmental Services Division review of sampling and health & safety plans; Office of Public Affairs review of CRPs. Comments documented and transmitted to contractor via technical memorandum. (VII-2) Teams are formed for each site. The team is made up of EPA people in other programs that are relevant to the site (RCRA, WATR, NPDES, Counsel, Air, Lab, QA officer). The appropriate team members review the documents. The state team members also review documents. Comments are submitted to the RPM in writing. The comments are compiled by the RPM and submitted to the contractor. (VII-3) EPA RPMs review all deliverables. Other branches and divisions of EPA, EPA management, state counterparts, other contractors, community members, USACE, advisory committees, and PRPs sometimes review documents/deliverables. Comments are transmitted in memos, or marked up copies are sent to the contractor. Meetings are often held to discuss comments. (IX-S) ------- lc. What document reviews are required to ensure the quality of project deliverables (RPM, State, etc.)? How are the results of these reviews documented? The work plan requires the review of EPA personnel, contractors, state personnel and, in some cases, the community. All correspondence related to this review is filed for documentation. All other documents were reviewed internally by EPA and our contractors. (IX-1) All of the reviews are documented in memos to the contractor or in submittal of marked up copies-copies of which are kept by EPA. RPM has reviewed all documents—state has been invited to review all documents. (IX-2) Work plan - RPM Sampling and analysis plan - EPA, slow and unpredictable Quality assurance project plan - EPA, slow and unpredictable Community relations plan - RPM (IX-3) RPM reviews and generally section chief, state and local agencies. Written comments (or marked up copies to contractor). (IX-4) 1. Work plans - RPM and state. In some cases written comments are generated and transmitted to the contractor. In most cases, marked up copies of the document and verbal comments are given to the contractor. In most cases, a follow-up meeting is held to discuss/clarify comments. 2. Sampling & analysis plan/QAPP - RPM, Field Inspection Section and Laboratory Support Section. In all cases, written comments are received from the FIS and LSS and directly transmitted to the contractor. Follow-up meetings are almost always held with the contractor. (IX-5) RPM and various technical experts. Results documented via memorandums from REM contractor responding to comments. (IX-6) RPM reviews all documents. Sampling plan and QAPP also reviewed by other offices within the region. Community may review CRP. Review documented by memo. (IX-7) RPM must review all of the above. State reviews work plan, QAPP and sampling plans. Reviews are documented in written comments, given to RPM. (IX-8) ------- Id. Are there chronic problem areas which standardized procedures or program changes could help? At least one: reviewers actually finding time to review documents adequately. When received, they should be scanned (at a minimum) to note any major problems or obvious errors. Cumulative impact of delays can be minimized by (1) telephoning major comments ASAP (2) follow up with letter. (II-2) The delineation of EPA jurisdiction and effectiveness regarding the uncertain policy an on-site vs. off-site remedial action. (II-3) Yes - (1) delays in WP approval caused by non-specificity of sampling needs in WP and subsequent identification of sampling needs in SAP and POP; therefore, identify proposed monitoring in WP and eliminate SAP and/or portions of POP. (2) POPs are still not site specific enough! Refine to essential site specific information. (II-4) Subcontracting - especially small dollar items (less than $10,000) which the REM contractor must spend large sums to procure a small subcontract. (II-6) Work plan memo is unnecessary step. Many tasks in the POP could be standardized through reference to standard sampling/drilling procedures. (III-l) Although Region III has adequate project review by toxicologists, hydrogeologists, a fate and transport specialist and senior RPM, other regions have no project review. It think all regions should be required to have specialists review reports. (III-3) QAPP's are mentioned frequently as a problem area. A good deal of standarization is possible in the QA process. (V-S) It would be helpful to have a work plan guidance document so that new project managers in both EPA and contractors have an idea of what should be included. A chronic problem area is QAPP approval-review times are lengthy and comments very general, resulting in several revisions and a lot of time until approval. (V-2) Internal Agency review times should be standardized for each routinely required review. This should be left to regions, however. Could give us information on actual and target timeframes for various steps in RI/FS process. (V-3) QAPP approval, since need approval prior to fieldwork this slows up whole process, (partial approvals have alleviated this problem within the region). Keep Annandale out of CDMs signoff. (V-5) QAPP process should become more standardized and less subjective. Data transfer problem-new contractors basically end up reinventing generic formats already in use by established contractors. (V-6) Yes, with the QAPP. Then should be more standardization especially with respect to SASs (Special Analytical Services). (V-7) QAPP approval is slow because WMD has little capability in review of laboratory analytical procedures. (V-8) ------- Id. Are there chronic problem areas which standardized procedures or program changes could help? Delegate QAPjP approval to the RPM. Allow ESD to perform audits of the plans. (VI-1) Environmental Services Division currently reviews and provides final approval of QAPjPs. In some instances the time involved in their review/approval process has caused delays in RI/FS startup. (VI-2) QA/QC plans reviewed currently by ESD, delays in getting approval are chronic and usually conditional approval must be given. (VI-3) Quality Assurance Office needs to be briefed on project scope prior to being able to comment specifically on QAPP. (VI-4) QA/QC plan reviews currently not in our program. Plans could be streamlined to fit needs of program better. (VI-7) Budget overruns—cost plus contracting gives the contractors little incentive to control costs. (VI-9) In-house - QA/QC plan approval - QA/QC reviewer in a different division. (VI-10) Obligation of funds to a particular project CLP data turnaround. (VI-II) None that could be significantly helped with changes. (VI'12) Environmental Services Division's review of the QA plan can cause significant delays. They get hung up on "petty issues" which have little significance to the overall objectives of the project. (VI-14) Format of reports Statement of objectives QAPP vs. combined work plan/QA plan. (VII-1) Delays in processing work assignments. Contractor must wait until contracting officer approves WA, even for initial tasks, before initiating work. This sometimes causes substantial delays. (VII-2) There are too many steps to get a project started. The work plan to prepare a work plan is too time consuming. (VII-3) The major problem area is in the development and review of SAPs and QAPPs (I) EPA needs to provide better guidance and training to contractors; (2) internal review (by EPA) needs to be streamlined. (IX-S) Internal document review such as sampling plans and QAPPs need standardization. There is no model currently available for these documents and they are often prepared in the dark. Work plan preparation can't be adequately done in the given time frame. (IX-1) As REM contractors get more experience, they get better at preparing work plans and sampling plans. Poor submittals and revisions can seriously delay a project. (IX-2) ------- Id. Are there chronic problem areas which standardized procedures or program changes could help? Yes, in the review of QAPP and site sampling plan. If standardized needs are introduced it would help in preparation of these documents. (IX-3) Major problems-review/approval of QAPP and site sampling plans Standard QAPPs (generalized) would help enormously. (IX-4) The development, review and approval of the sampling plan and QAPP is an area where significant delays have been experienced and contribute to corresponding delays in start-up of Held activities. The greatest delay is experienced in developing an approved QAPP, the reason is that the contractor is unclear about what EPA wants and the Agency has not clearly communicated its needs to contractor. Training would help. (IX-5) QAPP, SAP review. Distribution of work plans for review by outside parties. (IX-6) Development and approval of SSP and QAPPs takes too long - contractors and EPA need to do these faster and better. (IX-8) ------- le. The enclosed CPM chart shows proposed chances that would take a number of historical deliverables off of the critical path. What comments do you have on these proposed changes? Nothing major (II-2) I like the idea of starting the procurement process for the driller after the draft work plan is prepared and the scope of the drilling is agreed upon. One problem in the ROD and public comment process that has arisen in this region is that the recommended alternative was presented at the public meeting and then after the public meeting EPA changed their recommended alternative. As a result, we have to go back out to the public. To avoid this problem, no recommended alternative should be presented at the public meeting. All alternatives should be presented and the public allowed to comment. If, however, the region (fed-lead) or state (state-lead) feels strongly about presenting a recommended alternative at these meetings, the Regional Administrator should be briefed and give verbal concurrence to the recommended alternative. This would help to assure that, unless the public points out any major issues, the recommended alternative will eventually be the selected alternative. (II-8) This is good—the work plan is the focus of most discussion. (III-l) We did not receive in-depth comments regarding the RI/FS timeline. The copy we had was close to indecipherable. It is critical for Agency managers to understand the RI/FS process. I recommend that RPMs from the regions be gathered together to discuss the proposed timeline and to relate their actual experiences with contractor performance, scheduling, etc. I believe you would find their insights most useful. (V-S) No quality assurance project plan is included in the chart. Approval of this document is what most often holds up the start of field work in Region V. (V-l) I do not understand the chart enough to know which items have been changed. In addition, the QAPP is missing. (V-2) - QAPP is on critical path since can't start field work till approved: - Move CRP to start of WA - Explain expectation/assumptions in document reviews (REM or Agency not noted) - Check out estimates for time between fieldwork and draft RI. Unrealistic. - The CPM does not fit with CDM timelines in existing work plans - CPM lists items after ROD which are not critical path and forgets negotiations with PRPs (up front) which may be critical path. (V-3) What are the changes? (V-8) As is, can't follow the attached CPM - how about sending a decent copy. (VI-3) (Note: Region VI made xerox copies of CPM and attached it to the questionnaire). Add a combination sampling/analysis & QAPP - contractor work plans should present overall project scope, EP/State, ATSDR or USACE may revise. Detailed field/lab protocols should follow with QA. (VI-4) The final field operations plan is the truly important document. The others are all incorporated into it but do not really have to be completed until that point. (VI-9) ------- le. The enclosed CPM chart shows proposed changes that would take a number of historical deliverables off of the critical path. What comments do you have on these proposed changes? Is the endangerment assessment to be included in RI? You may need more lead-time to prepare RI report prior to preparing FS May have to screen additional RAS after phase II field activity. (VI-14) Cannot follow your chart. (VII-1) The chart is too confusing to make much sense, although it does seem to double up activities. I agree with doubling up as long as we can still control what is going on with the project. The RI report does need to go final ASAP, not to wait for the FS. (VII-3) Many time frames are not realistic For example, drilling and sampling is given less than 2 months. It may take 4 or 5 months. (IX-1) ------- 2a. What is a reasonable timeframe for the project planning process? 12-18 months (II-1 > Dependent largely on (1) changes in coverage specified in SARA and (2) effects of reducing deliverable schedule/number of deliverables. (II-2) Be more specific. However, if you regard important deliverables such as the work plan and POP as this process period, though site specific, I might give a ball park figure of 4 months. However, it is usually significantly longer. (II-3) Unclear with SARA (II-4) 3 to 4 months (II-6) 1 month (II-7) With the REM II contract, there has been a learning curve for the project planning process. Mine was an early RI/FS and the planning process took about 12 months. I think now it could be completed in 5 months. (II-8) 2 months (III-l) 3 months is reasonable. We have been experiencing 6-8 month processes. That is unacceptable. (V-S) 4-6 months (V-l) From WA initiation to approved plans has taken 10 months on my projects (V-2) Looks good as shown on chart. Chart does not elaborate on the agency/state and REM review system frequently used. (V-3) 3 months (V-4) 4-6 months for all pre-RI/FS deliverables/approvals; 8 quarters for RI/FS to public. (V-S) It varies from site to site based on complexity; typically for all planning prior to field work 3-5 months. (V-6) Depends on complexity of project and whether it is state or federal lead. (V-7) 2 months for fund lead 4 months for state lead (VI-1) 4 months (VI-2) 4-6 months (VI-3) Simple site - 3 months Complex site - 6 months (VI-4) ------- 2a. What is a reasonable timeframe for the project planning process? 2-3 months (VII-5) 2-3 months (VII-6) 10 weeks from notice to proceed (VII.7) 6 months (VII-8) 3 months (VI-9) It is project specific, but 1-3 months (VI-10) 6 months (VI-II) 12 weeks (VI-12) 3 months (VII-13) 3-4 months to prepare, review and Finalize the necessary work plans. (VI-14) 45-90 days when sufficient info is available. (VII-1) Approximately 2 months from issuance of a work assignment to final work plan approval. (VII-2) 2 months considering all the necessary paperwork, I would prefer 1 month. (VII-3) 3-5 months. A very complex site may take longer (from the chart it appears that project planning includes: CRP development SAP, WP, H&S plan, interim tasks, where does QAPP fit in?) (IX-S) Given the CPM model, I am not sure what is considered project planning. If, for an enforcement site, it is all time prior to signing an enforcement agreement, I would say 4-6 months would be excellent. (IX-1) Approximately 4-6 months, plus or minus (IX-2) 3-5 months (IX-3) 2-3 months (IX-4) Work plan: 4-6 months to obtain a quality product plan that EPA/state can live with RI/FS: 18-24 months (IX-5) 3 quarters from listing to work plan (IX-8) ------- 2b. Would your region support modifications to the project planning phase (e.g.., combining, replacing, or modifying project planning documents)? Sounds good (II-1) Yes - some basic organizational changes are being made using system software and dBASE and LOTUS packages. (II-2) Ask the R.A. (II-3) Yes (II-4) Yes (II-7) I believe that the work pan and project operations plan are adequate. (II-8) Yes, get the H&S plan, S&AP QAPP and POP condensed into one document. (Ill-1) We would certainly support changes that would speed up RI/FSs. (V-S) It would depend on the modification. (V-l) Only if the modifications are realistic and streamline the planning process. (V-2) Great! Would enforcement program agree? (V-3) Yes (V-4) I think we already have, no project operations plans (POP). (V-5) Probably, but it would really depend on the changes. (V-6) Yes (V-7) I hope so. The WP should be a combination of H&SP, QAPP, and sampling plan . These documents should not be written to be "stand alone" documents. (VI-1) I do not know. (VI-2) Probably yes (VI-4) Give it a try (VI-5) Yes (VI-6) Yes (VI-8) Yes (VI-10) Personally no (VI-12) Combine the major documents, they are often redundant. (VI-14) ------- 2b. Would your region support modifications to the project planning phase (e.g.., combining, replacing, or modifying project planning documents)? Can't respond for region—personally would (VII-2) Yes (VII-3) Yes. We need to develop strong planning frameworks, to maintain the ability to cost recover; however, the planning phase could be simplified and semi-standardized. Detailed outlines may before useful than narrative texts. (IX-S) Maybe. As long as we could lay a solid framework for the project (with sufficient detail) during the planning phase. (IX-1) Yes (IX-2) Yes, any combination of the above would be helpful. (IX-3) Yes (IX-4) Yes (IX-5) Yes (IX-6) Yes-anything to streamline process but maintain ability to cost recover. (IX-7) Yes-simplify, semi-standardize, and shorten all. Use detailed outiines instead of narrative text. (IX-8) ------- 2c. What are some new program activities that could expedite the planning process (e.g., expanded data gathering during the PA/SI phase, expedited response actions, etc.)? Can't think of any nor do I see how "adding" a "new activity" is going to speed things up. Things might get slower. (II-l) Organize our experience into some kind of data base or information system to provide a "track record" for new work, to be consulted and compared during scheduling. (II-2) Prime contractors whose site managers are not overloaded. Expanded data gathering during PA/SI would only help if the same contractor handled this phase along with RI/FS. (II-3) 1. HQ guidance on access acquisition 2. HQ guidance on handling of RI/FS generated wastes, i.e., drilling cuttings, well development water, well sampling purge water, pump test water, disposable clothing 3. Clarification and simplification of process to evaluate and implement usage of POTWs 4. Clarification of ARAR evaluation in remedy selection 5. Additional data gathering in PA/SI-ONLY if done by REM; otherwise REM will duplicate 6. ERAs should expedite, if evaluation/justification is not excessively burdensome 7. Develop standard limited list of alternatives to be considered for categories of sites. 8. Add well drillers and surveyors to REM team. (II-4) Modify REM internal review Modify REM subcontracting. (II-6) I believe that the more data gathered during the PA/SI phase could help to expedite the planning process. (II-8) Zone well drilling contracts (i.e., mini CLP for drillers) Encourage REM to purchase mobile labs Permit reference to SOPs for field activities (III-l) Most responders approve of expanded PA/SIs and expedited response actions, but expressed reservations. Further detail is necessary. (V-S) Expanded PA/SIs would help and/or limited data collection during project planning phase. (V-l) Expanded site inspections would allow for a more directional RI/FS. It would eliminate an entire characterization phase of the RI/FS. (V-2) I don't like the idea of expanding the PA/SI phase, unless the subsequent RI work is conducted by the same contractor. I think the phased RI is the best hope for improving the process. (V-4) What will expedite the planning process is a better incentive for consultants to bring projects within budget/schedule. It seems that expanding data gathering early could work but I'll bet the REM contractor would want to recollect data. The number of samples is not really what takes so long - its the remobilization that slows down and costs a lot! (V-5) ------- 2c. What are some new program activities that could expedite the planning process (e.g., expanded data gathering during the PA/SI phase, expedited response actions, etc.)? More standardized documents such as QAPP, and work plan. The sampling plan would be the only true site specific document. (V-6) Both would help the planning process, in addition to quick reviews of deliverables. (V-7) Obviously gathering more data during PA/SI would expedite the planning process; however, this would cause delays in starting the RI/FS process. (VI-1) Expanded SI would help, especially where ground water issues are expected. (VI-3) Expanded data gathering during PA/SI. (VI-4) Both of those mentioned above. (VI-5) The above sounds good. (VI-6) Define extent and magnitude of contamination in PA/SI program. (VI-7) The R1 guidance should be expanded and rewritten to give more specific direction to the planning process. (VI-8) The more data we get up front in the PA/SI phase the better the RI will be. (VI-9) Possibly-expanded PA/SI -remedial program needs lead role in this. (VI-10) More comprehensive review of existing data. (VI-12) If the RPM had more information (data) to start the planning process. (VI-14) Inadequate SI data can prolong the planning process indefinitely. (VI1-1) Greatly expanded SI in appropriate cases. (VII-2) 1. Expanded sampling during SI phase may facilitate project scoping 2. Forward planning money needs to be more available from HQ 3. Lesser QA/QC for some sampling; not all samples have to be of enforcement quality 4. ERAs at sites where RI/FS and RD/RA will extend over several years 5. Better knowledge on behalf of the contractors of what is going on at other sites may help. (IX-S) Improved Sis would greatly expedite the process. (IX-1) Expanded information collection(sampling), during the SI would make scoping the RI much easier and more accurate. (IX-2) ------- 2c. What are some new program activities that could expedite the planning process (e.g., expanded data gathering during the PA/SI phase, expedited response actions, etc.)? Expedited response actions, particularly at sites where the RI/FS and RD/RA process will extend over several/many years, would be useful in correcting the public's perception that EPA is not responding fast enough to NPL sites. (IX-S) Better knowledge of what's been done at similar sites in other regions so we are not constantly reinventing the wheel. (IX-6) Lesser QA/QC for some samples-not all of enforcement quality. (IX-7) Create the ability for FIT or REM or TES contractors to gather more data at time of listing—i.e., sampling and draft work plan. It's been too difficult to get forward planning money from HQ. (IX-8) ------- 3a. At what point in the RI/FS process do you formulate remedial alternatives? 3b. How would the RI/FS schedule be affected if you did this earlier, to focus field investigations? 3c. How would the RI/FS schedule be affected if you did this later, when more data are available? a. After sampling and analysis are complete. (II-l) b. Doubt it would change anything. Might slow things if we look at wrong or too many alternatives (II-1) c. Sufficient data is already available after sampling and analysis. There is no point in waiting any longer. (II-1) a. In the FS phase, after identification and evaluation of all applicable remedial technologies and integration of screened technologies into remedial components, with evaluation of these. (II-2) b. If an applicable technology were overlooked, it could delay the project severely, if discovered later. (II-2) c. May either extend it or not affect it much at all. That is, more data could allow more informed decisions regarding which elements should be incorporated into which alternatives. (II-2) a. The contractor formulates remedial alternatives, generally, after RI fieldwork completed, though often sooner. (II-3) b. A good contractor consultant should be considering very early onto focus field investigations. (II-3) c. Should be considered initially and after more data available Effect if not considered is generally need for more data, after the fact! (11-3) a. Upon identification of the extent of contamination and exposure pathways. (II-4) b. Would be beneficially shortened - This could be implemented more easily jf a standardized and limited list of alternatives to be considered for several typical types of situations at sites could be developed. (II-4) c. Lengthens schedule. (II-4) a. As soon as a draft RI is available. (II-5) b. Depending on the amount of state data and PA/SI you do try to focus field work. (II-5) c. The problem now is that the review and selection of alternatives is so close to the ROD process there is not time to optimize the selection and make it truly cost-effective. (II-5) ------- 3a. At what point in the RI/FS process do you formulate remedial alternatives? 3b. How would the Rl/FS schedule be affected if you did this earlier, to focus field investigations? 3c. How would the Rl/FS schedule be affected if you did this later, when more data are available? a. After receipt of CLP data. (II-6) a. After selection of response objectives and cleanup criteria. (II-7) b. Probably done as early as possible, can't make any earlier (II-7) c. Would delay project. (II-7) a. When the Held investigations are complete and a portion of the data has been returned, formulation of remedial alternatives begins. (II-8) b. This should be done earlier ~ in some preliminary form — to focus field investigations, so the necessary data is obtained during the RI rather than finding obvious holes during the ROD process. (II-8) c. I think it would lengthen the overall process unnecessarily. (II-8) a. Should start conceptually in early to mid-RI. (III-l) b. May not have significant impact, but, will expedite treatability studies. (Ill-1) b&c The problem is not formulating alternatives, the problem is collecting data to support EPA policies, (i.e., data to support GW modeling which is used to set cleanup standards). (III-l) a. I begin thinking of alternatives during the work plan stage. (III-2) b. It is essential to screen alternatives as early as possible so that bench scale and pilot studies can be completed expeditiously during the RI/FS. (III-2) a. We begin formulating remedial alternatives after RI data are'available. (V-S) b. Formulating remedial alternatives early in the RI could easily bias the investigation. We try to approach the site investigation without preconceived notions of the remedial action. Historically, RI/FSs which have been conducted along a focused path have run into problems in the FS. (V-S) c. The general consensus is that remedial alternatives should be considered between phase I and II in the RI. (V-S) a. When we receive RI analytical data (V-l) b. I would be afraid of screening out some alternatives too early and perhaps having to go back and collect more data when an alternative that didn't look feasible with limited data starts to look more feasible when more data are collected. (V-l) c. Would definitely slow things down. If alternatives are informally screened immediately when RI data becomes available one can recognize the need for additional data early in the process and add parameters to a second round of sampling. (V-l) ------- 3a. At what point in the Rl/FS process do you formulate remedial alternatives? 3b. How would the RI/FS schedule be affected if you did this earlier, to focus field investigations? 3c. How would the RI/FS schedule be affected if you did this later, when more data are available? a. We began screening at the RI/FS start, based on the alternatives technological suitability to the site, site conditions and needs. At the end of Phase I an update to the screening will take place. (V-2) c. I think the FS would take a greater period of time to complete. (V-2) a. Ideally, before phase II fieldwork — as noted on chart. (V-3) b. Good -- especially if the site has potential for use of alternative technologies. (V-3) a. Recently, we have been emphasizing development of potential remedial alternatives after the results of phase I RI activity and before phase II fieldwork. (V-4) b. I do not think it could be done much earlier. (V-4) c. I think it would have an adverse effect. (V-4) a. After the screening in FS for technical impracticability, environmental protection. (V.-5) b. I think unconsciously, this is done at the beginning of project (RI/FS). (V-5) a. Alternatives, not technologies, part way into the FS. (V-6) b. You can't preselect alternatives. That is what this question is proposing. (V-6) c. This is done later. Bad question. (V-6) a. In a preliminary report after the data gathering task. (V-7) b. Probably shorten RI/FS. (V-7) c. Probably lengthen RI/FS. (V-7) b. That would in effect be eliminating some alternatives in advance. (V-8) a. Begin developing possible alternatives after setting the FS objectives. Usually, 1-2 months after fieldwork is complete. (VI-1) b. It would expedite process; however, it would limit the number of alternatives from the start of the RI; therefore, it would appear a decision had been made from the beginning. (VM) c. Doing this would enable the justification of deleting certain alternatives. (VI-1) a. As soon as enough data are available. Usually there are sufficient data in existence to formulate a preliminary list of alternatives. (VI-2) b. It would expedite the process. (VI-2) ------- 3a. At what point in the RI/FS process do you formulate remedial alternatives? 3b. How would the RI/FS schedule be affected if you did this earlier, to focus field investigations? 3c. How would the RI/FS schedule be affected if you did this later, when more data are available? c. In the long term it could help focus the remedial alternative formulation process and eliminate alternative(s) which were inappropriate prior to the FS. (VI-2) a. Whenever sufficient data exists, usually after RI is complete. (VI-3) b. Sounds like you want to put the cart before the horse, just to meet schedules! (VI-3) c. That is the way its done now, usually. (VI-3) a. During scoping of RI. (VI-4) b. Not at all. (VI-4) c. Not much as a rule; the formulation step taken in RI scoping needs to be revisited after site results become available. It is possible that some of the contaminants found at the site were not though to be present previously and the pre RI alternative formulations will be inadequate. (VI-4) a. After RI data has been evaluated, but before the RI is finalized. (VI-5) b. Field investigation could be shorter and more directed, shortening the schedule by that amount of time. (VI-5) c. All data is available using current system. (VI-5) a. At the start. (VI-6) b. It would be shorter. (VI-6) c. It would affect the schedule as much as potential funds that could be saved. (VI-6) a. During draft RI phase. (VI-7) b. Would shorten schedule by reducing need for second phase field activity. (VI-7) c. Schedule would be longer. (VI-7) a. Before half-way through the RI. (VI-8) b. Might help, but actually you need the field investigations to help focus the remedial alternatives. (VI-8) c. Could drag out the RI/FS for an extra six months. Preliminary phase 1 data should be sufficient. (VI-8) a. General alternatives when the RI data comes in. (VI-9) b. It cannot be done earlier unless the information on contaminants an physical properties of waste was determined in PA/SI. (VI-9) ------- 3a. At what point in the RI/FS process do you formulate remedial alternatives? 3b. How would the RI/FS schedule be affected if you did this earlier, to focus Held investigations? 3c. How would the RI/FS schedule be affected if you did this later, when more data are available? c. General alternatives can be determined early on. The later work is just eliminating or refining alternatives from the original group. VI-9) a. Start to at the beginning of RI ~ true formulation comes at the beginning of FS. (VI-10) b. We try to already - tends to shorten time. (VI-10) c. May tend to lengthen time. (VI-10) a. End of RI. (VI-11) a. Potential RA alternatives in the work plan, formal ones in the FS. (VI-12) b. Might reduce need to go back and collect more data during RD and could allow more certainty in remedy selection. (VI-12) c. Would probably slow process down. (VI-12) a. Late RI; early FS (VI-13) b. Could delay schedule if wrong assumptions are made and work has to be redone. (VI-13) b&c Depend on amount of data available prior to beginning RI/FS. (VI-13) a. Near the completion of the RI. once you have had a chance to review a majority of the investigatory information. (VI-14) b. Most likely allow the RPM to develop alternatives earlier. (VI-14) c. No change over present methods. (VI-14) a. Work plan phase (VII-1) b. PA/SI is done by a different division (VII-1) c. Could lengthen time to produce FS. (VII-1) a. Early in development of FS. (VII-2) b. Schedule may be shortened for some projects, but this may result in unnecessary field work in others if data is gathered for alternatives found not to be appropriate. (VII-2) c. Obviously, schedule may be delayed. The decision on the extent of field investigation prior to development of remedial alternatives should be a case-by-case decision made by the region. (VII-2) a. During FS, technologies are broadly reviewed during RI. (VII-3) ------- 3a. At what point in the Rl/FS process do you formulate remedial alternatives? 3b. How would the RI/FS schedule be affected if you did this earlier, to focus field investigations? 3c. How would the Rl/FS schedule be affected if you did this later, when more data are available? b. It could not be done before the field work unless there is an extensive SI. If the data is available, some review of technologies should be in the planning of RI. (VII-3) c. Acceptable to look at technologies. (VII-3) a. In the past, some initial identification of alternatives has been done in the RI phase, followed by in-depth scoping during the FS. In the future, more scoping will be done in the planning process and RI. (IX-S) b. It may shorten the RI/FS schedule somewhat. (IX-S) c. While the FS may be more comprehensive, the schedule would probably be delayed for two reasons: (1) extraneous data may have been gathered, or (2) additional data may be required which would result in another field effort. (IX-S) a. The formulation begins early in the proess, after preliminary sampling has been done. (IX-1) b. I don't think it could be done much earlier and still be effective. It could require inefficient use of RI activities. (IX-1) c. It would delay the schedule. (IX-1) a. This should be done early in the RI process ~ i.e., at the very start of field sampling, if not before. Then the region will have time to collect necessary samples or design bench scale studies for an alternative technology that may have specific data requirements that might not otherwise be addressing. (IX-2) b. It would have minimal impact on the schedule and would make the RI much more logicial, since the RI would more realistically address data needs for assessment of several different alternatives including alternative technology, remedial alternative. (IX-2) c. At Celtor Chem works, FS would have been set back three months had CH2M Hill not been able to extremely quickly do additional testing necessary to evaluate an alternative technology. The problem arose because CH2M Hill and EPA did not properly scope out alternative until early FS. (IX-2) a. End of RI beginning of FS (IX-3) a. As early as possible. Conceptual alternatives should be identified at beginning of RI/FS. (IX-4) b. Should not have a large effect. (IX-4) It may lead you to realize that you didn't collect all of the types of data you need to complete the FS, leading to a delay in the project. (IX-4) a. As early in the RI phase as possible (IX-5) ------- 3a. At what point in the RI/FS process do you formulate remedial alternatives? 3b. How would the RI/FS schedule be affected if you did this earlier, to focus field investigations? 3c. How would the RI/FS schedule be affected if you did this later, when more data are available? b. It may be difficult to predict at the beginning of the RI what remedial technolgies might apply to a site that has yet to be characterized. If it could happend, it would be possible that the RI/FS period would be shortened. (IX-S) c. There would probably be a minor delay if any. However, if additional data were still needed to evaluate potential RAs , the agency would be fared with having to do more RI work or not develop what could be a very attractive RA aiternative(s). (IX-5) a. Depends on complexity of individual sites. Sometimes you can formulate alternatives before work plan is developed. (IX-6) b. Could speed up RI/FS in some cases and save unnecessary field work. (IX-6) c. Could slow process. Data gathered could be extraneous to analysis of alternatives. Additional field work may be required. (IX-6) a. RI (IX-7) b. We try to. Schedule still extremely long. (IX-7) a. During FS, when RI is well underway (IX-8) b. It may be shorter (IX-8) c. It would be a more informative FS. (IX-8) ------- SOURCES OF DELAY - DEGREE OF PROBLEM RESPONSES TO QUESTIONNAIRE ITEM 4A. MOST LEAST Approval of project planning documents 25 8 Work plan scope and cost negotiations 20 17 Obtaining site access 13 22 ~ PRP negotiations & interaction (prog-lead) 2 2 Before work assignment initiation 8 14 After work assignment initiation 6 13 PRP negotiations (enforcement-lead)* 3 Before work assignment initiation 6 S After work assignment initiation 7 5 Equipment shortages/delays 3 32 Contractor staff shortages 7 27 EPA staff shortages 12 23 Obtaining CLP slots (w/in last 18 months) 10 21 Sample analysis by CLP (w/in last months) 21 11 Data validation (w/in last 18 months) 27 8 Technical performance of contractors or subcontractors 16 20 Planning and communication (headquarters, regions, and contractors) 10 20 State review of documents 19 17 Headquarters policy and guidance 13 17 Headquarters processing of documents 13 17 * PRP negotiations (program or enforcement lead) marked only when respondent did not check before or after work assignment initiation. ------- 4b. Please give examples of how you have prevented or minimized delays in our region (e.g., ROD teams, interim deliverables). Partial approval of documents (e.g., WP, and POP) to allow RI/FS to begin as close to original schedule as possible. Planned implementation of a project tracking system to keep future milestones in perspective and provide "early warning system." (II-2) Constant communication and cooperation with contractors Effective RPO, who understands contractual obligations (II-3) Make clear to contractors that revised fee evaluations will be affected Use new WA forms to set interim expenditure limits, even though EPA and REM can't agree on total costs Field screening of samples (III-l) Performed some technical tasks, such as modeling, myself. (III-2) Communication is heavily highlighted as the answer for minimizing problems. (V-S) I have worked hard and been persistent! (V-2) Joint reviews, face to face meetings. (V-3) Maximum utilization of documents from other sites Interim deliverables incorporated directly into a final report Parallel ROD and document reviews instead of sequential reviews (V-6) Draft reports were distributed when available. Many face to face meetings were held to keep the project on track. (V-7) Interim deliverables, especially on FS, such that between draft FS and final FS fewer changes are required. (VI-3) Interim work plan approvals (VI-4) Weekly conference calls with contractor and state staff during FS. Presents issues to be resolved by agencies and gives direction to contractor. Better feeling for draft products. (VI-7) Frequent communications with PRP project managers A very specific well-laid out work plan. (VI-8) Interim deliverables, particularly portions of RI/FS, enable early correction of problem before they become embedded into the reports. (VI-9) Emphasize communications with states and contractors, etc. Have utilized interim deliverables in some instances (VI-10) Use of operable units (VI-12) ------- 4b. Please give examples of how you have prevented or minimized delays in our region (e.g., ROD teams, interim deliverables). Enforce "drop dead" dates during PRP negotiations. Include strong language regarding "disputes" in consent orders signed with PRFs~can cause significant delays negotiating work plans. (VI-14) Attempt to have ROD approval authority delegated to region. Interim deliverables (preliminary agency review draft) Must have regional counsel involvement early in ROD process. (VII-2) Kickoff meeting with contractor and meeting between kickoff and work plan draft. (VII-3) 1. Use interim work plans to allow work to begin while final SOW and costs are negotiated 2. Split sampling plans into separate subplans to allow sampling to begin 3. Keep state and technical committee informed of schedules to ensure timely reviews of documents 4. Contract bidding before QAPP final 5. REM contract office in close proximity to EPA has facilitated communication. (IX-S) Contractor should be required to give advance notification of all project deliverables and delays. (IX-2) Used interim work plans to allow work to move along while final scope and cost of entire project is negotiated Split up sampling plans into separate subplans to allow sampling work to begin while portions of the sampling plan were still in questions. (IX-4) Try to keep state fully informed—technical committee. Contractor bidding before QAPP final. (IX-7) Have REM contractor in close proximity to office. (IX-8) ------- 4c. What has been successful or failed in improving project performance, and why (e.g., field screening of samples, use of alternate labs, turning data over to contractor before completion of data validation, regional procedural guidance, strict timeframes for reviews by states others)? Plus - use of an on-site GC to characterize subsurface contaminants and refine locations for wells available through Edison facility, although we used a subcontractor. Minus - Nature of CLP contract has produced a "seller's market" and gives us little leverage. (II-2) Turning data over before data validation has helped. (II-4) Turning data over to contractor before completion - this works. Strict timeframes - this is needed. (II-5) Turning data over to contractor before data validation. (II-7) Turning data over to contractor before completion of data validation has helped to expedite data reduction. (II-8) Project performance can always be improved by doing more investigative work in the RI and not formulating alternatives without adequate data...This is common. (III-2) Maintaining and adhering to detailed schedules seems to work well in moving projects forward. (V-S) Doing some preliminary field work during the work plan development phase. (V-l) Items that have failed in improving project performance: (1) strict timeframes for review, (2) using alternate labs. (V-2) Monthly meeting with RPMs/site managers and unit chiefs/contractor. Use of alternate labs definitely speeds things up—if you do not need QAPP approval. (V-5) Tightly set and enforced project schedules including review times Communication with contractors and states Issuance of draft documents and information for review prior to validation and thorough proofing in-house. (V-6) Timeframes for reviews by state and others. All others mentioned above. (V-7) RPM review/comment on QAPjP reduced the approval process (VI-1) Field screening of samples reduced number of samples needing lab analysis, thereby reducing turnaround time for sample results. Using strict timeframes for QAPjP review/approval has failed because of disagreement between the RPM and the QAO as to the comprehensive nature of the QAPjP. (VI-2) Phasing sampling efforts such that full blown analysis not needed on every sample, once "marker" compounds identified. (VI-3) More frequent project status meetings prior to work plan submittal. (VI-4) ------- 4c. What has been successful or failed in improving project performance, and why (e.g., field screening of samples, use of alternate labs, turning data over to contractor before completion of data validation, regional procedural guidance, strict timeframes for reviews by states others)? See above statement (4b.) (VI-7) Field screening is particularly useful in waste disposal of exploratory wastes and turning data over before validation speeds up the RI/FS process. (VI-9) Success - Use of private labs (other than CLP) - Contractor data validation Failures - Indicator compounds - Inflexibility in schedules (VI-10) Review workshops with the contractors, RPMs and state were successful in expediting project completion. (VI-U) Review deadlines do not work except for those most closely involved with project. (VI-12) Strict timeframes for review/revision process. (VI-14) On expedited projects, RPM travel to contractor offices to assist in review and preparation of initial agency review draft—reduces degree of revision required later. (VII-2) Turning data over to contractor before completion of data validation - never. Soil gas screening, strict timeframe to contractor. (VII-3) Successes:(l) turning data over to contractor prior to data validation; (2) use of field screening of samples; (3) regional guidance; (4) monthly meetings with REM RMs. (IX-S) Field screening of samples allows for engineering judgment to be used in the proper placement of wells or taking of samples. Turning data over before complete data validation allows for preliminary design, engineering work to be completed. (IX-3) Strict formalized review of sampling and QAPP's. Data may have been marginally better quality, but large time delay was caused in the project schedule. (IX-4) Turning data over to contractors before data validation. (IX-5) Strict timeframes for reviews have foiled. States and others just do not comment at all. Regional guidance on preparation of SAPS and QAPPs has helped. (IX-6) ------- 5a. Has sampling been required during the FS phase? Why? 5b. If so, what mechanisms have been instituted to improve data gathering (e.g., phased RI/FS, operable units, longer project planning period, other approaches)? What has worked in your region? a. Yes. Failure of state (NY) to pursue/investigate source(s) on state lead projects. (II-1) b. Operable units have been used. (II-l) a. Not yet. but two possibilities: 1. If PRP decontaminates on-site buildings, follow-up sampling required. 2. Treatability studies may require samples for simulation. (II-2) a. Yes. RI inadequacy identified at FS or ROD stage; design data necessary for fine tuning of remedy. Conflict between developing design data prior to ROD remedy selection. (II-4) b. All three of the above; operable units has worked. Phased RI/FS will have to wait and see. (II-4) a. During the FS, yes, when the lab data was invalidated and another round of sampling took place. (II.5) a. REM design contractor insists that additional data is needed for design. (II-6) b. 1. Phased RI/FS and 2. Operable units are good 3. Beginning this work after RI/FS is complete and before ROD signing. (II-6) a. Yes. Because unforeseen circumstances or data gaps are discovered. (II-7) b. Phased RI/FS and operable units. (II-7) b. On a project with a large RI scope, we have designated some probable operable units. This directs the sampling priorities, as well as allowing for an expedited response to some of the problems there. (II-8) a. Yes. Need to more completely define excavation limits when off site disposal or placement is scheduled. (Ill-1) b. More field screening is being used to collect the large number of sample required by EPA policies. (Ill-1) a. Yes, because adequate data was not collected during the RI. (III-2) b. Operable units provide a mechanism to satisfy bean counts and get back to a site and collect adequate data for subsequent operable units. (III-2) a. Sampling has been required during the FS, to fill in data gaps. (V-S) b. Phasing the RI works well for Region V. (V-S) a. Sometimes for technology specific data or resolution of issues key to decision making. (V-3) b. Phased approach is good, operable unit implementation generally not considered as mechanism for improved data gathering. (V-3) a. Yes, to confirm assumptions made on data base. (V-4) b. Phased RI (V-4) ------- 5a. Has sampling been required during the FS phase? Why? 5b. If so, what mechanisms have been instituted to improve data gathering (e.g., phased RI/FS, operable units, longer project planning period, other approaches)? What has worked in your region? a. Yes, not enough data to deftne"clean" areas and depth of removal. Tried to minimize number samples due to problems with CLP space, budgets. I suggest using same contractor to gather all added info in "pre-design". If you give the work to the design contractor, it is like doing a whole new RI/FS (work plan, QAPP) and gets very expensive. I opt for getting the RI/FS finished as soon as a defensible cleanup alternative can be recommended, sign ROD and do data gathering/pilots/bench as needed immediately following as pre-design (while Corps is getting design contractor if that is the case. (V-5) a. Not during FS In RD or RA: to verify cleanup and to aid in RD. (V-6) b. Phased projects and operable units can speed up RAs when data gaps are identified. (V-6) a. No, but this may be possible for other projects. (V-7) b. Phased RI/FS. (V-7) a. Yes, Highlands Acid Pit (HAP) is currently undergoing a ground water study to determine if remediating the GW is necessary. (VI-1) b. HAP has been divided into operable units. (VI-1) a. No, however, additional sampling has been required after the draft RI report was submitted. b. Because the limits of surface and ground water contamination were not defined adequately. (VI-2) a. No (VI-3) a. Yes, it is virtually impossible to collect sufficient data for all investigative components to specify remediation to the existent required for design. (VI-4) b. I have been using both the phased RI/FS and operable unit approach but have not completed any of these projects. Project administration is more complex but remediation of "hot" areas begins sooner. (VI-4) a. Yes, don't know, not my site. (VI-5) b. Phased RI. Has not been implemented yet. (VI-5) a. Yes, site boundaries expanded. (VI-6) b. Phased RI/FS work. (VI-6) a. Yes, characterize waste for remedy evaluation. (VI-7) b. Identify potential remedial technologies prior to finalization of RI work plan. (VI-7) a. Yes, normally due to offsite contamination over a greater area than anticipated. (VI-9) b. Operable units. (VI-9) a. b. Typically not. We do use operable units. (VI-10) ------- 5a. Has sampling been required during the FS phase? Why? 5b. If so, what mechanisms have been instituted to improve data gathering (e.g., phased RI/FS, operable units, longer project planning period, other approaches)? What has worked in your region? a. No (VI-ll) a. No (VI-12) a. No, no experience with this situation or need. (VI-14) a. No, but will be. Cleanup procedure involves iterative sampling to be performed as part of RA. (VII-2) b. No sampling during FS. (VII-2) a. Yes, to gather more specific information to evaluate particular technologies or alternatives. (VII-3) b. Operable units. (VII-3) a. Yes, for a number of reasons: (I) inadequate data collection/RI by states or PRPs; (2) to support updated or amended RODs; (3) potentially, sampling could be conducted post-FS or ROD to further evaluation alternative technologies, or as predesign studies. (IX-S) b. (I) Start identifying alternatives earlier in RI/FS so ensure that appropriate data is collected during the RI; (2) operable units. (IX-S) a. Yes, when alternative are not fully considered prior to RI. Data is collected in a vacuum, much more detailed characterizations are required to support alternative technologies and even standard excavations. (IX-2) b. Perhaps HQ should specify recommended 20' grid sampling to lowest expected depth and 5' at 2.5' intervals for all possible contaminants of concern. (IX-2) a. Yes, to expand data base obtained during RI/FS to support updated/amended ROD. (IX-3) a. Yes, evaluate new innovative source control RA alternative. (IX-5) b. The IMM ROD was for an operable unit, it also authorizes additional funding to conduct studies to evaluate the new source control technology. (IX-S) a. No (IX-6) a. Yes, inadequate RI by state. (IX-7) a. b. During the FS, yes. PRP did not collect adequate data (IX-8) Start FS screening sooner in RI process. (IX-8) ------- 6a. Please briefly describe a site in your region where the work has gone exceptionally well. 6b. What features contributed to the success of work at the site? a. Technical work has gone well at Waldick, once it started: geophysical surveys, well installation, test pits, soil gas, etc. b. Good response from contractor and subcontractor, and resourcefulness in the face of various obstacles. (II-2) a. Marathon Battery supplemental RI/FS phase 1 b. Good EPA/contractor communication and enough money to pay for the accelerated schedule. (H-7) a. Fiftown (?) Pesticide b. Strong contractor project manager—committed to schedule Use of existing data Innovative thinking (III-1 > 6, 7, 8. The RPMs did not provide much information; probably from professional courtesy. A meeting as proposed in le., could lead to open discussion of RI/FS successes and failures. (V-S) a. I think no matter how hard you try all projects have gliches because Superfund sites are like mysteries we are trying to solve. (V-2) a. Industrial Excess Landfill; ongoing RI which has had effective cost, schedule, and quality control. b. Regular discussion of project status (cost, schedule, quality) by respective project managers. (V-4) a. Lake Sandy Jo, Gary, IN b. Speedy reviews, little revisions needed on deliverables. (V-7) a. Crystal City Airport b. Well written LOED Review of WP/QAPjP was fast tracked by both EPA and the state On-site lab was used to screen samples; therefore, data gaps were defined prior to completing fieldwork. (VI-1) a. Brio Refining b. Little hassle with government contracting procedures PRPs interested in identifying and completing any action required at the sites RSPO who took great interest in keeping the project moving Good quality EPA contractor performing oversight work. (VI-4) b. The key seems to be in PRP attitude, if they are cooperative work will proceed. If they are recalcitrant you can count on delays. (VI-9) a. Cecil Lindsey RD - Fast track time frame-project came under budget and ahead of schedule. b. Exceptional communications between contractor (Hill) and RPM-mutual cooperation. (VI-10) ------- 6a. Please briefly describe a site in your region where the work has gone exceptionally well. 6b. What features contributed to the success of work at the site? a. Brio Refining Site - PRP conducted RF/FS; enforcement-lead, federal oversight. b. Open communications between EPA and PRPs Close contact between EPA oversight contractor and PRP contractor. (VI-14) a. Montrose: a joint funding site with soil and ground water contamination Iron Mountain Mine (IMM) RI b. Effort of EPA RPMs of contractors. Also, contractor familiar with IMM site due to previous involvement. (IX-S) a. The RI/FS at IMM went very well through the RI stage; the FS went well up to the point where RA alternatives needed to be evaluated in terms of consistency with applicable and relevant and appropriate federal and state requirements. b. The contractor, by previous work at the site thru a state contractor, was very familiar with the site and its environmental problems. (IX-S) a. Montrose—a joint funding site, with extreme soil and ground water contamination. b. Hard work by project manager, and excellent support from REM contractor. Problems in getting it listed final on NPL persist. (IX-8) ------- 7a. 7b. Please briefly describe a site in your region where the work has gone poorly. What caused the problems at the site? a. Some sites can fit into either category, depending on how reviewed -- more sites lean toward "poor," however. (II-2) a. Scheduling and sample processing have both been poor at Waldick; major delays due to contractor liability issues, QA/QC procedures, et al. at Comb Fill South and Burnt Fly Bog. b. Lack of contractor experience in scheduling/performing certain types of field work; nature of CLP contract and staffing/communication problems between CLP and MMB personnel; contractor tendency to give us dates that sound good, but that are not realistic. (II-2) b. Overloaded contractor site - managers CLP data problems (analysis e.g., extended holding times) (II-3) a. Relatively poorly - Roebling Steel - large site - partially active b. Large with many potential sources - phased approach should fix - but much time lost. (H-4) a. The planning process for my federal lead site was entirely too long at 12 months. This caused a significant delay in progressing with the RI/FS. b. It was an early Rl/FS for the REM II contractor and the delays were due to problems they had internally. (II-8) a. McAdoo b. Poor contractor project manager Poor policy direction from EPA on soil cleanup standards and procedures for defining the standards (III-1) a. McAdoo Associates b. Bad planning, very poor quality work (III-2) a. Several state lead projects - introducing a new layer of bureaucracy in general adds to the time and costs for projects. (V-1) a. Same answer [as for 6a]. (V-2) a. Laskin Poplar - Ineffective control of all three of the critical aspects of a project; schedule, cost, and quality b. Poor management oversight of the subcontractor; lack of knowledge of the program by the sub; poor communication. (V-4) a. Peterson Sand And Gravel, IL b. Poor deliverables from contractor (V-7) a. Bailey b. Consultant did not track samples once shipped to lab; 90% of holding times were exceeded due to consultant inability to track status of samples. (VI-1) b. State leads cause problems from day one! (Double review of everything). (VI-3) ------- 7a. Please briefly describe a site in your region where the work has gone poorly. 7b. What caused the problems at the site? a. South Valley (my site) b. Contractor changeovers: LOE depletion on REM/FIT; conflict of interest on REM II EPA personnel changes: four RSPOs during RI alone Schedule problems and technical coordination/quality concerns with the significant enforcement component of project Lack of interest/cooperation on part of city who will actually benefit by the project Site complexity: Multiple sources, complex hydrogeology, low contamination concentrations. (VI-4) a. Sheridan Disposal Services b. A great deal of substandard work was completed by the PRPs, without proper oversight, prior to the proposal of the site to the NPL. (VI-8) a. Gurley Pit - remedial investigation of pit used for disposal of refining of used oil wastes. b. Work was all subcontracted out. The prime contractor had little control over the subcontractor. (VI-9) a. Cecil Lindsey RI - project delays and cost increases. b. Poor communication and a subcontractor that was something less than exceptional. (VI-10) a. Industrial Waste Control-Fort Smith, Arkansas b. Use of the FIT as a subcontractor to CH2M Hill CLP delays, lost samples, poor quality. (VI-l 1) a. During an RI/FS for ground water at a uranium mill, site access was denied, drillers did not perform, severe weather problems occurred, access was difficult to Indian lands, and the project went severely over budget without completion of the RI/FS. b. Uncooperative PRP, confusion by the state as to appropriate role of EPA with regard to NRC. (VI-12) a. Bliss portion of Ellisville site includes dioxin-contaminated soil, other organic and buried drums in rapidly developing residential area. b. A poor-quality RI/FS prepared in 1983 made development of a ROD very difficult. RI was far from being comprehensive enough to justify remedy selection. (VII-2) a. (1) MGM Brakes - remedial funding was not available for this "enforcement" site. Data was gathered by PRP and is not comprehensive enough to finish FS. Public is questioning accuracy of PRJP data. (2) Purity Oil - bogged down by delays; RI was started 3 years ago; (3) IMM - for evaluation of applicable federal and state standards during FS, but FS has not started yet. b. Purity - lab analysis problems led to delays (work could not be conducted until adequacy of data quality determined); changing RI/FS guidance and NCP required major changes in SOW; inept contract management on behalf of the state under the cooperative agreement; indecisiveness of EPA management to take over lead for project. (IX-S) a. McColl b. Poorly planned RI/FS—however, this was conducted pre-CERCLA involvement. (IX-3) ------- 7a. 7b. Please briefly describe a site in your region where the work has gone poorly. What caused the problems at the site? a. South Valley (my site) b. Contractor changeovers: LOE depletion on REM/FIT; conflict of interest on REM II EPA personnel changes: four RSPOs during RI alone Schedule problems and technical coordination/quality concerns with the significant enforcement component of project Lack of interest/cooperation on part of city who will actually benefit by the project Site complexity: Multiple sources, complex hydrogeology, low contamination concentrations. (VI-4) a. Sheridan Disposal Services b. A great deal of substandard work was completed by the PRPs, without proper oversight, prior to the proposal of the site to the NPL. (VI-8) a. Gurley Pit - remedial investigation of pit used for disposal of refining of used oil wastes. b. Work was all subcontracted out. The prime contractor had little control over the subcontractor. (VI-9) a. Cecil Lindsey RI - project delays and cost increases. b. Poor communication and a subcontractor that was something less than exceptional. (VI-10) a. Industrial Waste Control-Fort Smith. Arkansas b. Use of the FIT as a subcontractor to CH2M Hill CLP delays, lost samples, poor quality. (VI-11) a. During an RI/FS for ground water at a uranium mill, site access was denied, drillers did not perform, severe weather problems occurred, access was difficult to Indian lands, and the project went severely over budget without completion of the RI/FS. b. Uncooperative PRP, confusion by the state as to appropriate role of EPA with regard to NRC. (VI-12) a. Bliss portion of Ellisville site includes dioxin-contaminated soil, other organic and buried drums in rapidly developing residential area. b. A poor-quality RI/FS prepared in 1983 made development of a ROD very difficult. RI was far from being comprehensive enough to justify remedy selection. (VII-2) a. (1) MGM Brakes - remedial funding was not available for this "enforcement" site. Data was gathered by PRP and is not comprehensive enough to finish FS. Public is questioning accuracy of PRP data. (2) Purity Oil - bogged down by delays; RI was started 3 years ago; (3) IMM - for evaluation of applicable federal and state standards during FS, but FS has not started yet. b. Purity - lab analysis problems led to delays (work could not be conducted until adequacy of data quality determined); changing RI/FS guidance and NCP required major changes in SOW; inept contract management on behalf of the state under the cooperative agreement; indecisiveness of EPA management to take over lead for project. (IX-S) a. McColl b. Poorly planned RI/FS-however, this was conducted pre-CERCLA involvement. (IX-3) ------- 8b. What do you feel are the worst features of the RI/FS process in you region? Branch - Slow turnaround time for data and document review. Scheduling realistically. (II-2) LOE contract REM - real easy money. (II-3) The RI and review exceed schedule thus crowding the FS portion and ROD process. (II-5) The REM contractors are charging excessive amounts for the preparation of work plans and other preplanning documents. (II-6) The CLP system has so many problems that it is just ridiculous. The labs can exceed holding times which invalidat e the data and still get paid for the analysis, and we are left with an RI that has no accurate information. (II-8) Projects are pushed along to sign RODs when very often adequate data is not collected. (III-2) Lack of coordination between program and enforcement personnel, objectives, accountability systems, etc.!! (V-3) Lack of effective schedule controls. (V-4) Time to complete, inexperience of contractors, approving/revising QAPPs. (V-5) Paperwork and waiting for headquarter's approval. (V-7) Too few sites are fund lead. State lead sites usually take longer. (VI-1) The fact that all sites managed by my section are state lead and the state tends to take more time than is necessary for the RI/FS process. (VI-2) State lead forward planning. (VI-5) Planning and trying to stay on schedule. (III-6) Too many people are involved in the process without a clear definition of duties. Too many other agencies involved. (VI-7) In many cases the guidance and rules we work under are changed in mid-project. This means repetition of work already done. (VI-9) QA/QC offices in a different region. (VI-10) Required management of the CLP by a different division. (VI-11) It takes too long. (VI-12) Environmental Services Division review of QA report when EPA contractors do a much between and more reasonab le job ensuring QA during the RI/FS. (VI-14) Lack of coordination with HQ staff and OGC during RI/FS process, especially for non-delegated ROD's. (VII-2) ------- 8a. What do you feel are the best features of the RI/FS process in your region? Branch - Reasonably good exchange of information between RPMs to facilitate efficient handling of sites. Ability to address and respond to unexpected situations in a reasonable time, and to get timely input from enforcement and legal personnel. (II-2) Work plan holds contractor in some semblance of restriction as to scope and dollars to be spent. (II-3) The contracting system encourages the contractor to do a mediocre job because the more time spent working on something—the more they get paid. The small award fees are not enough to encourage a better quality of work. (II-8) We have increased updating on project status and deliverable schedules Strongly encourage field screening methods. (Ill-1) Good project review. Region III does not rely on its contractors as much as other regions do. (III-2) There is autonomy for project managers to tailor needs of an individual project. (V-7) Work plans are usually well written and provide excellent details of the proposed fieldwork. Those sites where detailed LOED were developed, enabled an expedited development of these work plans. (VI-1) The signing of the ROD to end the headache! (VI-3) Outstanding RPMs and first level supervisors. (VI-11) Flexibility (VI-12) RPM control over RI/FS work, contractor support for federal oversight of PRP conducted RI/FSs. (VI-14) Close working relationship between RPMs and SPMs Monthly meetings/conference calls involve EPA management in issues. (VII-2) Good relationship with contractor and contractor's willingness to do the work we request. (VII-3) Negotiating detailed work plans with PRPs prior to consent orders Effort of RPMs in overseeing projects and contractors. (IX-S) Negotiating detailed work plans with PRPs prior to entering into consent orders. (IX-1) Review of work plans. (IX-6) Intense oversight of PRPs and REM contractors by project managers. (IX-8) ------- 8b. What do you feel are the worst features of the RI/FS process in you region? SAP and QAPP reviews and data validation. This is a long process and often inconsistent reviews are given. If site is not high priority long delays are encountered. (IX-S) Reluctance (in the past) to go fund-lead when negotiating with PRPs. (IX-1) Procedures for sample plan/QAPP review and data validation-long, drawn out process; inconsistent reviews, focus o n review comments that will not improve data quality. Region sets priority so that if a site is not a priority, large delays in getting through the process will occur. (IX-4) There are few, if any, incentives built into the REM contract that discourage the production of mediocre to low-quality documents. The award-fee is not an effective tool to correct problem areas in the RI/FS process; this has the potential to cause (and in several cases it actually has) project over-runs. (IX-5) Delays in review of supporting plans. RPMs do not have enough time to push through system. (IX-6) Time it takes to get PR approved by headquarters and contractors to start working. (IX-8) ------- 9a. How effective is the award fee as a program/project management tool? 9b. How could the award fee be improved (e.g., revised criteria)? a. Minimally so~in practice, a partial award is given for adequate work, while higher-quality performance means a higher award. If adequate work is rewarded, the incentive to excel is virtually nonexistent. b. Make it mean something ~ reduce or eliminate the "base award" (or call it something else) and consider raising the upper end. (II-2) a. Almost noneffective (II-3) a. Somewhat (II-4) b. Unnecessary cost/time overruns should decrease or eliminate the pool. (II-5) a. Totally ineffective b. Eliminate the award fee pool. Penalaties should be imposed for REM work which is inadequately performed. (II-6) a. Probably insignificant b. Larger pool (II-7) a. Not effective enough. The contract encourages mediocrity and not excellence (#8a). (II-8) a. Could be better—Phase I should be changed to let RPM give site specific response during project implementation b. Large pool may help—again, better site specific phase I procedures may help (III-l) a. It is not. It's just gravy to REM contractors already making too much money for low quality work. LOE contracts favor using as many hours as possible. No incentive to do good quality work at a reasonable cost. b. Either go to a fixed fee contract or make the "award" fee a substantial portion (greater than 25%) of their actual prenegotiated payment. No quality ~ no 25% (III-2) a. We received mixed opinions on the efficacy of the award fee as a management tool. (V-5) b. Most reponders indicate a preference for a larger award fee pool tied to more precise award criteria. (V-5) a. Not very! b. The contractors need some sort of incentive to perform better (V-2) a. RPM need to know when phase I is awarded (project specifically) and when b. Project progress needs to be linked closer to award fee. Maybe by comparison to "ideal" timeline (V-3) a. I think it is an effective tool. b. Make it clear what our performance expectations are (V-4) a. Contractors are very paranoid of getting a 2—in fact, if an RPM wants to give 3's (which are fully successful) the contractors try to bully the RPM into giving 4's. b. (I) To make contractors aware of criteria, (2) to have a larger % award fee. (V-5) ------- 9a. How effective is the award fee as a program/project management tool? 9b. How could the award fee be improved (e.g., revised criteria)? a. Non-effective—the only meaning it has to the contractors is if it is not average or above. Dollar values are too small to be meaningful b. Vastly increase the size No automatic percentage (V-6) a. There is a heavy emphasis on it from contractor, so it is effective. (V-7) b. Increasing it. (V-7) a. Seems to be effective. (VI-1) b. Could be improved by revising/expanding rating criteria. (VI-1) a. Some contractors seem more concerned than others. (VI-4) b. Larger % award fee, providing it does not add to overall contract cost. (VI-5) a. Fair b. More gradations in the fee awarded. (VI-8) a. It varies, but is fairly effective. b. The criteria need to be revised with more emphasis on production of work products on time and within budget. (VI-9) a. It appears fairly effective-even though I think the % of award is relatively low. b. Larger percentage award fee pool (VI-10) a. Somewhat effective - (VI-11) a. Not very b. Larger differential between fee/no fee (VI-12) a. Not very! (VI-14) a. Difficult to estimate at regional level. Obviously provides incentive for contractor for high quality work, but unclear how much or if quality would drop if award fee eliminated b. Evaluation criteria should be as simple and straightforward as possible. System should be less quantitative, i.e. allowing for only several general qualitative observation and associated scores (VII-2) a. Have not seen it work as a tool b. Need better explanation of how to do an evaluation. There needs to be more standardization (VII-3) a, It is only effective when "I" or "2" ratings are given, then contractors respond, but only in the short run. The cost reimbursement/award fee type contract creates little incentive for the contractor to produce high quality documents. They get paid to produce poor documents and paid again to rewrite them. This has led to cost overruns. b. (1) make difference in award fee for ratings of 3, 4 and 5 greater (e.g., 3 = 0-20%, 4 = 21-60%, 5 = 61-100%); (2) develop a mechanism to penalize contractors for specific areas, e.g., scheduling. Individual areas of poor performance often got lost in the overall evaluation; (3) training for RPM for consistent and tougher evaluations (IX-S). ------- 9a. How effective is the award fee as a program/project management tool? 9b. How could the award fee be improved (e.g., revised criteria)? a. Has been effective. Low scores have led to improvement. (IX-1) a. Not that effective. Only a 2 on a performance evaluation gets any response from contractor. b. Make the difference between marginally successful, fully successful; and exceeds expectation be large enough in terms of award fee for contractors to take notice. (IX-4) a. Not effective (IX-5) a. Fairly effective (IX-6) b. Tougher criteria (IX-6) a. Very effective at least over the short term. Then contractors slack off again. b. Mechanism to penalize one area of bad performance, like scheduling. In the ratings this can be overshadowed by other areas. (IX-7) a. Very useful if you give 2's - nothing else gets their attention (IX-8) b. Simplify process - fewer forms, faster, fewer comments, less "process." (IX-8) ------- 9a. How effective is the award fee as a program/project management tool? 9b. How could the award fee be improved (e.g., revised criteria)? a. Minimally so—in practice, a partial award is given for adequate work, while higher-quality performance means a higher award. If adequate work is rewarded, the incentive to excel is virtually nonexistent. b. Make it mean something ~ reduce or eliminate the "base award" (or call it something else) and consider raising the upper end. (II-2) a. Almost noneffective (II-3) a. Somewhat (II-4) b. Unnecessary cost/time overruns should decrease or eliminate the pool. (II-5) a. Totally ineffective b. Eliminate the award fee pool. Penalaties should be imposed for REM work which is inadequately performed. (II-6) a. Probably insignificant b. Larger pool (II-7) a. Not effective enough. The contract encourages mediocrity and not excellence (#8a). (II-8) a. Could be better—Phase I should be changed to let RPM give site specific response during project implementation b. Large pool may help-again, better site specific phase I procedures may help (III-1 > a. It is not. It's just gravy to REM contractors already making too much money for low quality work. LOE contracts favor using as many hours as possible. No incentive to do good quality work at a reasonable cost. b. Either go to a fixed fee contract or make the "award" fee a substantial portion (greater than 25%) of their actual prenegotiated payment. No quality — no 25% (III-2) a. We received mixed opinions on the efficacy of the award fee as a management tool. (V-5) b. Most reponders indicate a preference for a larger award fee pool tied to more precise award criteria. (V-5) a. Not very! b. The contractors need some sort of incentive to perform better (V-2) a. RPM need to know when phase I is awarded (project specifically) and when b. Project progress needs to be linked closer to award fee. Maybe by comparison to "ideal" timeline (V-3) a. I think it is an effective tool. b. Make it clear what our performance expectations are (V-4) a. Contractors are very paranoid of getting a 2—in fact, if an RPM wants to give 3's (which are fully successful) the contractors try to bully the RPM into giving 4's. b. (1) To make contractors aware of criteria, (2) to have a larger % award fee. (V-5) ------- 9a. How effective is the award fee as a program/project management tool? 9b. How could the award fee be improved (e.g., revised criteria)? a. Non-effective--the only meaning it has to the contractors is if it is not average or above. Dollar values are too small to be meaningful b. Vastly increase the size No automatic percentage (V-6) a. There is a heavy emphasis on it from contractor, so it is effective. (V-7) b. Increasing it. (V-7) a. Seems to be effective. (VI-1) b. Could be improved by revising/expanding rating criteria. (VI-1) a. Some contractors seem more concerned than others. (VI-4) b. Larger % award fee, providing it does not add to overall contract cost. (VI-5) a. Fair b. More gradations in the fee awarded. (VI-8) a. It varies, but is fairly effective. b. The criteria need to be revised with more emphasis on production of work products on time and within budget. (VI-9) a. It appears fairly effective-even though I think the % of award is relatively low. b. Larger percentage award fee pool (VI-10) a. Somewhat effective - (VI-11) a. Not very b. Larger differential between fee/no fee (VI-12) a. Not very! (VI-14) a. Difficult to estimate at regional level. Obviously provides incentive for contractor for ; high quality work, but unclear how much or if quality would drop if award fee eliminated b. Evaluation criteria should be as simple and straightforward as possible. System should be less quantitative, i.e. allowing for only several general qualitative observation and associated scores (VII-2) a. Have not seen it work as a tool b. Need better explanation of how to do an evaluation. There needs to be more standardization (VII-3) a. It is only effective when "1" or "2" ratings are given, then contractors respond, but only in the short run. The cost reimbursement/award fee type contract creates little incentive for the contractor to produce high quality documents. They get paid to produce poor documents and paid again to rewrite them. This has led to cost overruns. b. (I) make difference in award fee for ratings of 3, 4 and S greater (e.g., 3 = 0-20%, 4 = 21-60%, 5 = 61-100%); (2) develop a mechanism to penalize contractors for specific areas, e.g., scheduling. Individual areas of poor performance often got lost in the overall evaluation; (3) training for RPM for consistent and tougher evaluations (IX-S). ------- 9a. How effective is the award fee as a program/project management tool? 9b. How could the award fee be improved (e.g., revised criteria)? a. Has been effective. Low scores have led to improvement. (IX-1) a. Not that effective. Only a 2 on a performance evaluation gets any response from contractor. b. Make the difference between marginally successful, fully successful; and exceeds expectation be large enough in terms of award fee for contractors to take notice. (IX-4) a. Not effective (IX-5) a. Fairly effective (IX-6) b. Tougher criteria (IX-6) a. Very effective at least over the short term. Then contractors slack off again. b. Mechanism to penalize one area of bad performance, like scheduling. In the ratings this can be overshadowed by other areas. (IX-7) a. Very useful if you give 2's - nothing else gets their attention (IX-8) b. Simplify process - fewer forms, faster, fewer comments, less "process." (IX-8) ------- 10a. How are project review meetings used in your region? How are they helpful? 10b. How frequently are the meetings held and who attends? 10c. Are the meeting results documented? What purpose does this documentation serve? a. Whenever direction is needed (e.g. scoping, review comments on draft reports, progress delays, decision points). b. See above - enforcement and remedial RPMs (sometimes supervisors), REM project manager, EPA hydrogeologist if necessary, EPA attorney (enforcement), state representative (sometimes) c. Generally, to document decisions, to schedule follow-up actions <11-1) a. Used to present major aspects/issues, solicit opinion and, if possible, arrive at a consensus. They get EPA, the state, and contractor together to keep one another better informed b. Pre-RI, pre-FS, pre-ROD and others as circumstances dictate — i.e. as problems arise and need to be addressed and resolved as interagency issues. EPA and state officials and usually contractor personnel, as well. c. Documentation is usually the RPM's responsibility (for a federal - lead site) to provide to those unable to attend and go into the site file. Action items are noted and followed up on. (II-2) a. Used constantly—very effective in project management, specifically scheduling and cost control b. Once a month between RPM and site manager once every 3-4 months with RPM, RPO, site manager and consultants regional manager c. Yes, it serves to prevent misunderstandings and misinterpretation regarding what was said. (II-3) a. Identify problems quickly b. Pre-RI with RPM Pre-FS—high levels with state high-level counterparts c. Yes - RPM reminder and direction (II-4) a. The state/EPA reviews are often difficult particularly if you are trying to hold these to the cost-effectiveness criterion. b. RI, pre-FS, FS. The state likes to hold these close to home and outnumber the EPA. c. No minutes, but the contractor has to come out of those meetings with some direction. (II-5) a. These meetings appear to be very helpful to the REM contractors, especially when they need more money. EPA RPMs to learn of circumstances at other sites. b. Meetings are held periodically to update EPA, state and Corps personnel of work. c. Yes usually by REM contractor - reminder of responsibilities. (II-6) a. Not helpful (II-7) b. Pre-RI/FS, pre-alternative analysis, post-RI. RPM, state c. Documented if necessary - usually not. Documentation might be necessary or justify response levels, etc. (II-7) ------- 10a. How are project review meetings used in your region? How are they helpful? 10b. How frequently are the meetings held and who attends? 10c. Are the meeting results documented? What purpose does this documentation serve? a&b These meetings are held at the end of the RI to discuss the results and the direction of the FS. They are held again at the end of the FS to discuss the alternatives and recommend one. The state, contractor and EPA attend these meetings. c. There is no formal documentation of these meetings. (II-8) a. I prefer documented status reports and task-by-task tracking. b. Work plan, pre-FS - attended by RPM and regional technical support personnel. c. No (III-l) a. They provide a good opportunity to see how the project is progressing. Many times, contractors don't inform RPMs of the technical details of projects which is then only reviewed after the RI/FS is submitted. b. Pre-RI. mid RI, pre-FS, post FS. c. RPM provide input to contractors (III-2) a&b We have monthly meetings in Region V between the RPMs and the contractors. The meetings have helped us in meeting schedules, budgets, and ensuring quality products. We are assured that the RPMs are reviewing these items, in detail, at least once per month. c. Meeting results are documented for review by the unit chiefs. (V-S) a. Monthly meetings work out well between RPM and SM. Shouldn't be mandatory however because sometimes flexibility is needed—like during field work. b. Project summaries (beyond SMPs) are needed for state, attorney, other staff at milestone points. RPMs should be more encouraged to do this. c. Raises issues early. (V-3) a. Project review meetings are held at critical points during the RI/FS between state, region and contractor. They are essential to effective project management. We have had trouble getting in the state's upper management to focus on the project until the ROD process, which is too late. (V-4) b. Develop SOW; work plan kick-off; pre-QAPP; draft RI; during FS as alternatives developed. c. Not as formally as they probably should be. (V-4) a. Monthly; helpful in steering contractor in direction, distributing guidance, reviewing budget/schedule/ reports. b. Proposing to have monthly meetings with lawyers, enforcement counterpart and conference call with state c. Yes - to assure that important issues are discussed, understood ~ also will become part of administrative record. (V-5) a. It is more important and helpful to have regular conversations with the project manager for the contractor. b. Monthly project status meeting between RPM and contractor in addition to regular dialogue. c. Monthly - yes; daily - depends on topics discussed; documentation is for future accountability. (V-6) ------- 10a. How are project review meetings used in your region? How are they helpful? 10b. How frequently are the meetings held and who attends? 10c. Are the meeting results documented? What purpose does this documentation serve? a. To focus projects. They are helpful. b. Pre-RI, mid RI, pre-FS. c. Yes. To keep people focused should problems arise or project scope change. (V-7) a. Usually to plan/discuss upcoming phase of project. Yes. b. Report reviews, pre-RI, pre-FS, pre-RD, pre-RA. RPM/state. c. Results are documented for pre-FS meeting. This meeting sets the FS objectives. (VI-1) b. Pre-RI, pre-FS, pre-design, pre-RA; contractor, state and EPA. (VI-2) a. Used frequently. b. Pre-FS, post Ri — to review data from RI and set FS objectives — state, contractor, EPA personnel. Mid-FS - to discuss alternatives developed and screening process; same persons attend. c. Meeting results documented in a memo from contractor summarizing results. (VI-3) a. During work planning, RI results presentation, and during key portions of the FS. Meetings are helpful. b. Several (SPM/RSPO) pre-RI, work plan (RSPO, RPO, key contractor staff) presentation, a few (RSPO/SPM) during RI, RI (RSPO/SPM report, key contractor staff and occasionally RPO. c. Key meetings are documented for files; documentation can be used to determine the thoroughness of the technical evaluation during the course of the project. (VI-4) a. State lead sites, therefore state handles meetings. c. We (EPA) does not receive. (VI-5) a. To inform the personnel involved where the project is and where it is headed. b. Pre-RI/FS, (contractors, state). c. No (VI-6) a. Discuss progress of contractor and issues raised during project. b. Depends on project. Actually meetings have been held at screening or decision points. Conference calls weekly. c. Record of communication, file notes. Comment letter. (VI-7) a. They are helpful if the appropriate people are present. b. Usually one pre-RI and pre-FS meeting, one in mid project and a final meeting after a final draft report has been prepared. c. Only in terms of direct changes required to work plans or work products. To ensure needed changes are made. (VI-9) a. We do not have "formal" project review meetings. When we do have them, they are somewhat helpful for planning and ongoing management. b. We have them on an as-needed basis; attendees - contractor PO, RPM, RPM's supervisor. c. Meetings are often, but not always, documented - serves only as a record. (VI-10) ------- 10a. How are project review meetings used in your region? How are they helpful? 10b. How frequently are the meetings held and who attends? 10c. Are the meeting results documented? What purpose does this documentation serve? a. Very helpful (VI-ll) a Most handled as conference calls. b. Often c. Memo to file to preserve the record (VI-12) a. Very helpful between EPA and their contractor on oversight projects. b. At least once per month c. Meeting results are documented for future reference—especially during PRP conducted RI/FSs. (VI-14) a. Monthly meeting is very helpful to resolve branch level policy matters. (VII-1) a. Monthly technical coordination meetings held with EPA branch and section management help to identify issues and resolve them, which keeps projects on track. b. Project specific meetings generally held after issuance of work assignment (kick-off), during screening of alternatives, and perhaps near completion of agency review of draft report. c. Meeting notes taken by contractor and distributed to attendees - serves to document decisions reached, reducing likelihood of misunderstandings (VII-2) a. No b. Monthly meeting are hel that are worthless to me. Individual project meetings are held on an as needed basis. c. Only meeting notes (VII-3) a. Contractor/EPA meetings have been extremely benefically for keeping informed of project status, identifying problems, resolving issues, providing guidance etc. RPMs meet with REM project managers as needed; section chiefs and RPO meet with REM regional managers monthly, and keep in constant telephone contact. b. RPMs and REM project managers meet on an as needed basis. At a minimum, they meet during work plan development, at draft and final RI phase, pre-FS, draft and final FS report. Also, monthly or bimonthly during the RI/FS. Section chiefs and REM regional managers attend as needed. c. Often the REM contractor or EPA RPM will write a meeting summary to document agreements, schedules, summarize issues or performance problems, etc. This is useful as a reference document and can be given to management to alert them to problems and of project status. (IX-S) a. They are very helpful is ensuring that the contractor and EPA are in full agreement. b. Usually at work plan development. RI completion, FS scoping, and project turnover (after 10% design). Are attended by RPM and contractor project manager - sometimes section chief and contractor management attend. More frequent meetings - such as quarterly, may be very useful. c. Only if RPM takes notes. Contractor should be required to document and submit summary in 10 days. This will help ensure that all parties have effectively communicated and understood protect needs and will make follow-up much easier. (IX-2) ------- 10a. How are project review meetings used in your region? How are they helpful? 10b. How frequently are the meetings held and who attends? 10c. Are the meeting results documented? What purpose does this documentation serve? a. They are used by RPM to assist in managing the project. They are very useful in that a large variety of issues can be discussed more efficiently in a face-to-face meeting than through phone conversations. b. Monthly or bimonthly meetings between RPM and contractor personnel during RI/FS to review progress, set priorities, establish schedules, etc. c. Sometime, through a follow-up letter to document agreements on priorities, deliverable schedules, etc. and to summarize major issues or performance shortcomings. By sending a copy to management, lets them know of project status. (IX-4) a. In the case of IM, we established a TAC comprised of federal and state agencies and the contractor. In general, we met on an as-needed basis. This was helpful because each agency contributed certain expertise and understanding of the problem and it helped to shape, and in some cases, re-direct the project. b. Pre-RI, draft RI, pre-FS and FS stages. The TAC attended. c. No. (IX-5) a. Meet with REM contractors to review overall status of project and redirect resource and priorities. b. With regional project manager ~ constantly With REM contractor — monthly With REM management ~ quarterly c. Yes — improved performance and communication (IX-8) ------- 11. Emphasis on treatability and pilot testing will be encouraged due to the recent signing of SARA. 11a. Has the use of treatability and pilot testing been successfully used in your region? lib. At what point in the RI/FS is it most advantageous to commence these tests? b. After sampling and analysis, and before formulating final alternatives. (II-1) a. No, not on any of my sites. b. As early as possible in the FS phase but only after the RI data is assimilated. (II-2) a. For POTW use-necessary for state concurrence-often unsuccessful in convincing POTWs. b. Ideally, at the point at which the type of treatment necessary is certain. However, we cannot pilot test all possible options. (II-4) b. As soon as the treatment process is identified. (II-6) a. Yes, bench scale testing for Marathon Battery helped provide technical basis for evaluating remedial alternatives. b. Post RI stage. (II-7) a. No, in our region treatability studies have usually been deferred to remedial design. The need for doing them in the RI/FS is evident. b. After enough data is gathered to rule out the no action alternative, a decision on whether or not to do one at all should be made. The tests should occur during the FS process. (II-8) a. Only during design - not yet during an RI/FS b. Early in the RI because of their time schedules. (Ill-1) a. Studies are usually postponed after ROD is signed. b. Alternatives must be screened early because studies take at least 2 or 3 months. Studies should be completed by submittal of FS. (III-2) a&b There was little response to this question due to lack of experience. (V-S) b. How do we decide when its better to spend time and pilot testing in FS vs. RD? (V-3) a. Currently being used during design of New Lyme remedy. b. Prior to evaluation of final remedial alternatives. (V-4) a. Pilot studies during design at New Lyme (RBC on site and study in T&E facility USEPA-Cincinnati) and activated carbon at Oil Mill. (V-S) b. In FS after technologies have been screened. (V-6) b. If pilot testing is needed, it should be done during RI so that the project shcedule is not delayed. (VI-1) a. No (VI-2) a. Not that I'm aware of. b. During RI field work, I assume. (VI-3) ------- 11. Emphasis on treatability and pilot testing will be encouraged due to the recent signing of SARA. 1 la. Has the use or treatability and pilot testing been successfully used in your region? 1 lb. At what point in the RI/FS is it most advantageous to commence these tests? a. Not to any great extent. b. During early FS. (VI-4) b. Right after remedial alternatives are formulated. (VI-5) a. Bio-treatment - Triangle b. After remedial alternatives have been selected (VI-6) a. Yes -- help define design parameters b. Prior to evaluation of remedial alternatives. (VI-7) a. No. I still don't like the idea. I feel as though this has the potential to greatly increase the time schedule for RI/FSs. b. None - (VI-10) a. No b. During RI (VI-11) a. Not on my sites b. In later stages, if necessary (VI-12) a. No. could be improved due to SARA. b. Upon completing Phase I of the RI. (VI-14) a. EPA mobile incinerator located in southwest Missouri was successful at treating dioxin-contaminated soil, demonstrating effectiveness of technology. b. Should be early in RI/FS process in order to compare innovative technology with other remedial alternatives. (VII-2) a. A PRP did a treatability study on a site and thought it was useful. b. After alternatives are being evaluated, not before (VII-3) a. Yes (1) carbon column tests were conducted for Stringfellow; (2) soil flushing study was used successfully at Celtor Chemical b. As early as possible so as not to delay the FS and ROD. Tests could commence during the RI if applicable technologies are identified during the alternative scoping process. (IX-S) a. No. Some PRP treatability work was done prior to the enforcement agreement without EPA oversight. b. As soon as possible. (When a given contamination problem/pathway is identified) (IX-1) a. A soil flushing treatability study was very successful at Celtor Chemical Works, though it showed that soil flushing would not work. b. Early in the RI (IX-2) ------- 12. Please add any other ideas you have about how to make the RI/FS process in your region more efficient and cost-effective. A [more] effective project tracking system could be the single biggest improvement we could make. Once master schedules are set and agreed to, everyone understands the work. Such activities as project tracking and this questionnaire can provide an information source (cumulative experience/track record) that can be applied to present and future projects. The RI/FS phase involves continual refinement of the perceived situation at a given site and each task provides data that should be evaluated in light of all remaining tasks. This can be done unofficially to minimize delays due to added reviewes, but should permeate the entire phase. Because the RI is designed to generate data and information, little or no explicit focusing should be done until all material is in. The FS is properly the time to screen technologies. (II-2) See item 2b. (II-4) Meeting higher state codes under SARA, will make cost-effectiveness almost inoperable. (II-5) 1. REM internal review of documents is a disaster — much too time consuming. 2. Subcontracting is inefficient and time consuming especially for small items such as a small survey or installation of one well. REM needs these subcontractors on their team. (H-6) In many cases, the community relations contractor gets too out of hand in proposals for work at sites. I, as RPM, like handling my own community relations as much as possible, so the public knows that EPA is in control of the project. It seems like some of the work prepared for some sites, where there is not a significant public interest, is prepared just to generate work for the contractor (II-8) Better guidance on how much risk regional managers can take in selecting an alternative technology. Do we need to prove its applicability during the RI with a treatability study? Can we take large risks and sign ROD with alternative technology and do a very focused treatability study during design. If decision makers believe they have to have treatability studies for a series of alternative technologies in every RI/FS, we will have very lengthy and expensive RI/FSs. (Ill-1) See above comments. Similar comments have been suggested by many people at many times, but as yet - have not been implemented. (III-2) I want to thank you for giving us the opportunity to comment. These issues require a lot of thought and deliberation. A work group composed of RPMs may prove more useful than a questionnaire in exploring these issues. (V-S) Communication is most vital aspect! Contractors need to know policy. (V-5) Don't use open ended LOE contracts. Hold contractor accountable to fixed prices/estimates for work product. (V-6) Simplify and standarize QAPPs. Control receipt of data from CLP more (i.e., in a month data is available). (V-7) Stop state leads, we're paying double~the states and the contractors (VI-3) Stronger oversight capabilities for the EPA over the state on state-lead projects. (VI-5) ------- 11. Emphasis on treatability and pilot testing will be encouraged due to the recent signing of SARA. 11a. Has the use of treatability and pilot testing been successfully used in your region? lib. At what point in the RI/FS is it most advantageous to commence these tests? a. No, but it is trying to be implemented at various sites. b. Two windows exist; (i) during the late stages of the RI, or (2) during the design stage to ensure the chosen alternative works. The work could also be implemented between FS and ROD stage if time restrictions do not guide the project. (IX-3) a. Hasn't been used at my sites. b. At the earliest point in the project when it becomes obvious that certain technologies (existing and unproven) apply to a given site. (IX-S) a. Yes - but not in my section b. During Rl. (IX-8 ------- 12. Please add any other ideas you have about how to make the RI/FS process in your region more efficient and cost-effective. Allow EPA to have stronger authority in state-lead sites. (VI-6) Increase use of EPA's in-house expertise - Improve EPA's science library. Improve EPA's in-house support services to improve efficiency and allow the RPM more time for technical tasks. (VI-8) More frequent review of work in progress by regional project officers at the offices of the contractors. In particular, review of draft sections of RI and FS reports. (VI-9) Remedial program contracted expanded Sis Regional ROD delegation (VI-10) More subcontractor use in the future (VI-12) 1. Delegate authority to appropriate levels (VII-1) 2. Design better measures/targets for SPMS/SCAP Delegate CO responsibility (award of work assignments) to regions (VII-2) 1. Simplify the funding process-avoid delays of incremental funding and redundant paperwork 2. Consolidate QAPP/SAP, data validation process under the Superfund program rather than having this function in other branches. (IX-S) Put the responsibility for sampling plan/QAPP review and data validation under Superfund management. These activities should be managed and evaluated on how they work within Superfund goals (timely completion of quality RI/FSs), not as stand-alone functions. (IX-4) Simplify the funding process to eliminate itsy bitsy increments of funding from HQ (IX-8) ------- APPENDIX C CPM CHART WITH PROGRAM IMPROVEMENTS ------- |