United States
                             Environmental Protection
                             Agency
                            Office of
                            Solid Waste and
                            Emergency Response
          Directive No.: 9355.3-01 FS4

                        March 1990
       &EPA
The  Feasibility Study:
Detailed  Analysis  of  Remedial
Action  Alternatives
 Office of Emergency and Remedial Response
 Hazardous Site Control Division OS -220
                                                           Quick Reference Fact Sheet
This is the fourth and final in a series of fact
sheets  describing  the  remedial  in-
vestigation/feasibility study (RI/FS) process.
This fact sheet is a synopsis of Chapter 6 of
the  Guidance for  Conducting Remedial
Investigations and Feasibility Studies Under
CERCLA (October 1988, OSWER Directive
No. 9355.3-01), which addresses the detailed
analysis  of remedial  action  alternatives.
Additionally,  this  fact  sheet  provides
Remedial Project Managers  (RPMs)  with
information on how to manage this phaseof
the FS efficiently and effectively.

The purpose  of the  detailed analysis  of
alternatives is to provide decisionmakers with
adequate information to permit selection of an
          appropriate remedy for a site or operable unit.
          The  detailed analysis of remedial action
          alternatives  follows the  development and
          screening process, which is described in detail
          in Chapter 4 of the RI/FS Guidance and
          summarized in the third FS fact sheet (OSWER
          DirectiveNo. 9355.3-01FS3). The development,
          screening,  and detailed  analysis  of
          alternatives may overlap, with  one  phase
          beginning before another is completed. Also,
          the activities may vary in level of detail based
          on the complexity or scope of the  problem at
          a site. The extent to which alternatives are
          analyzed  during the  detailed analysis is
          influenced by the available data, the number
          and types of alternatives being evaluated, and
          the  degree to  which alternatives  were



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Completed





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Screening of j
Alternatives ^^*/
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I
Further Definition of
Alternatives, as Necessary
1
1
Individual Analysis of
Alternatives
Against Nine Evaluation

fel
1
Comparative Analysis of
Alternatives Using
Evaluation Criteria
to Identify Tradeoffs
\
Issuance of Feasibility Study
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analyzed  during their  development  and
screening. The results of the detailed analysis
provide the basis for identifying a preferred
alternative and preparing the proposed plan.
Upon completion of the detailed analysis, the
FS report, along with the proposed plan (and
the RI report if not already released) is issued
for public review and comment. The results of
the  detailed  analysis support  the  final
selection  of  a  remedy  and provide  the
foundation for the Record of Decision (ROD).
The major components of the detailed analysis
process are presented in Figure 1.

The detailed analysis, like other phases of the
RI/FS process, should be tailored to the scope
and complexity of the site or operable unit.
The level of detail can be expected to vary
from   site  to  site,  although   all  major
components discussed here and in the RI/FS
guidance must always be  addressed.
                                                                              Detailed Analysis Activities

                                                                              Alternative Definition

                                                                              The  alternatives  progressing  from  the
                                                                              development and screening phase of the FS
                                                                              may need to be better defined in order to
                                                                              adequately evaluate them during the detailed
                                                                              analysis.  If available,  additional  site
                                                                              characterization and treatability  study data
                                                                              should be utilized at this time. These datamay
                                                                              not  have  been  available  during the
                                                                              development and screening of remedial action
                                                                              alternatives due to the interactive nature of
                                                                              theRIandFS.
                                                                              Necessary refinements  to
                                                                              alternatives may include:
                                                                         the  remedial
 Figure 1. Major Components of the Detailed Analysis Process
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•   Modification  of contaminated  media
    volume estimates

•   Revision  of  sizing  requirements  of
    process options

•   Selection  of  a   more   suitable
    "representative" process option

•   Addition of other possible unit process
    options to be considered.

Individual Analysis of Alternatives

Once the remedial action alternatives are
sufficiently  defined to  allow for  further
evaluation,  each  alternative  is  assessed
against nine evaluation criteria. These criteria
have been designed to enable the analysis of
each  alternative to address  the  statutory
requirements  and  considerations, and the
technical and policy considerations important
for selecting  among  remedial alternatives.
These evaluation criteria,  listed in Figure 2,
provide the framework for conducting the
detailed  analysis  and  for  subsequently
selecting an appropriate remedial action. Also
included within this figure  are the specific
factors to be considered under each of the
criteria. The individual analysis of alternatives
should  profile  the performance  of each
alternative against  the evaluation criteria,
highlighting  the  specific  strengths  and
weaknesses of a particular alternative relative
to each evaluation criterion.

The evaluation criteria have been divided into
three  groups based on the  function of the
criteria in remedy selection. The  threshold
criteria relate to statutory requirements that
each alternative must satisfy in order to be
eligible for selection and include:

•   Overall protection of human  health and
    the environment

•   Compliance with Applicable or Relevant
    and Appropriate Requirements (ARARs).

The primary balancing criteria are the technical
criteria upon which the detailed analysis is
primarily based and include:
THRESHOLD CRITERIA
Overall Protection of Human
Health and the Environment

Compliance with ARAFU

• How Alternative Provides Protection of Human • Chemical-Specific
Health and Environment
• Action-Specific
• Location-Specific
BALANCING CRITERIA

Long-term
Effectivoncu
and
Permanenc*
• Magnitude of
Residual Risk
• Adequacy and
Reliability of
Controls
1 The assessments of the
proposed plan is receiv
Reduction of
Toxicrty, Mobility,
or Volume
Through
Treatment

Short-term
Effectiveneis

Imptemcntabilrty

Cost
Treatment Process • Protection of • Ability to Construct • Capital
Used and Materials Community During and Operate
Treated Remediation Technology • Operating and
Maintenance
Volume of Materi- • Protection of • Reliability of _ .... ..
als Destroyed or Workers During Technology " Present Wottri
Treated Remediation
• Ease of Undertak-
Degree of Ex- • Environmental Ing Additional RAs.
peeled Reductions Impacts If Necessary
Degree to Which -TimeUntllRA • Ability to Monitor
Treatment is Objectives Are Effectiveness of
Irreversible Achieved Remedy
Type and Quantity • Ability to Coordi-
of Residuals nate and Obtain
Remaining Approvals from
Other Agencies
• Availability of
Services and
Materials
MODIFYING CRITERIA



State/Support Agency „ . . ,
Acceptance! Community Acceptance1

se criteria are generally not completed until after public comment on the RI/FS report and the
Bd.
•   Long-term effectiveness and
    permanence

•   Reduction of toxicity, mobility, or
    volume through treatment

•   Short-term effectiveness

•   Implementability

    Cost.
The third group is made up of the modifying
criteria and includes:

•   State/Support agency acceptance

•   Community acceptance.

These last two criteria are assessed formally
after the public comment period, although to
the extent they are known, they are factored
into  the identification   of  the  preferred
alternative.   Based   on  this   formal
consideration, the lead agency may modify
aspects of the preferred alternative or decide
that another alternative is more appropriate.
The RPM should try to develop and maintain
a  thorough  understanding  of  State  and
community concerns  throughout the RI/FS
process. This understanding is essential to
prevent  issues  from arising  that  could
fundamentally change the alternatives being
considered after completion of the RI/FS and
proposed plan.
                                                                                            Note:  Risks associated with alternatives
                                                                                            are   considered  during   the   detailed:
                                                                                            analysis. The evaluation of the long-term
                                                                                            effectiveness and permanence afforded by
                                                                                            alternatives assesses the effectiveness an
                                                                                            alternative will have in eliminating exposure
                                                                                            pathways or reducing levels of exposure
                                                                                            identified in the baseline risk assessment.
                                                                                            During  the  evaluation  of  short-term
                                                                                            effectiveness, exposures associated  with
                                                                                            implementation of alternatives, such as
                                                                                            short-term health effects from  release of
                                                                                            volatiles during excavation of  soils are
                                                                                            addressed.  This may require  assistance
                                                                                            from the risk assessor.
 Figure 2.  Criteria for Detailed Analysis of Alternatives
                                                                                           The level of detail in which each alterna-
                                                                                           tive  is  analyzed relative to  the  evaluation
                                                                                           criteria will  depend  upon  the  type  and
                                                                                           complexity  of the site, the types of tech-
                                                                                           nologies  and  alternatives   being  consid-
                                                                                           ered, the level  of information  available on
                                                                                           the  alternatives,  and  other  project-spe-
                                                                                           cific  considerations.  The  analysis  should
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be conducted in sufficient detail to enable
decisionmakers to understand the significant
and/or  controversial  aspects  of  each
alternative and any uncertainties associated
with  the  anticipated  performance  or
evaluation of the remedies.
 Note: All alternatives may not need to be
 evaluated with  respect  to  all of  the
 subcriteria presented in Figure 2. The
 key is to identify the subcriteria by which
 the alternatives vary significantly and to
 focus the evaluation on those factors.
Comparative Analysis

Once the  alternatives  have  been  fully
described and individually assessed against
the nine criteria,  a  comparative analysis
should be conducted to evaluate the relative
performance of the alternatives in relation to
each  specific  evaluation  criterion.  The
purpose  of the comparative analysis is to
identify the advantages and disadvantages of
each alternative relative to one another so the
tradeoff's that will have to be balanced to
select a remedy  are  fully  understood. The
comparative analysis generally will focus on
the differences between  alternatives with
respect to the primary balancing criteria since
these  factors  play   the  major role   in
determining which options are cost-effective
and  which remedy utilizes  permanent
solutions and treatment to the maximum extent
practicable.

Next Steps

The detailed analysis develops information
used  in  selecting an appropriate remedy
based  on  statutory  requirements under
CERCLA, as  amended  by SARA.  As
illustrated in Figure 3, the nine criteria have
been developed to organize  the  evaluation
which supports the determination that these
statutory requirements  are met.  Further
information  on remedy  selection  will be
provided in a subsequent fact sheet.

         Detailed Analysis
            Deliverables

Table 6-5 of the RI/FS Guidance  presents a
suggested format for the final F5 report. The
major elements to be included in the FS report
are:
•   Comparative analysis of the alternatives
    with respect to each evaluation criterion
    (narrative)
•   Documentation of ARARs.

Individual Analysis Presentation

The presentation of the individual analysis in
the FS should include a narrative description
of each alternative and a discussion of the
evaluation of each alternative against the nine
criteria.  The  narrative  descriptions  of
alternatives should include:

•   Technology components (identify ing any
    innovative technologies)

•   Quantities of materials handled

•   Scale of process options

•   Time required for implementation

•   Implementation requirements

    Major ARARs

•   Assumptions, uncertainties, and
    limitations.

The   discussion   of  the  evaluation  of
alternatives should focus on how, and to what
extent, each  alternative performs in terms of
the key factors under each criterion. This
includes an analysis of the possible effect of
any change in assumptions on the alternative.
The analysis should include a summary table
highlighting   the   assessment  of  each
alternative with respect to each of the nine
criteria to assist the public and decisionmakers
in understanding  the  options. A  sample
presentation of an  individual  analysis  is
provided  in  Appendix  F  of the  RI/FS
Guidance.
Comparative Analysis
Presentation

The presentation of the comparative analysis
in the FS should describe the strengths and
weaknesses of the alternatives relative to one
another with respect to each criterion.  An
effective way to organize this section is to
discuss for each individual criterion  the
alternative(s) that performs best overall under
that  criterion, with other alternatives then
discussed in the order of their performance.
Significant subcriteria should be highlighted
and  the possible effect of  a  change in
assumptions should be noted. The differences
among alternatives may be measured either
qualitatively or quantitatively, as appropriate.
Quantitative information used to assess  the
alternatives, such as cost estimates and  the
time  until  response objectives  would  be
achieved,   should  be  included  in   the
presentation  of  the  analysis.   A  sample
    Description of alternatives and individual
    analysis (narrative and table)
             NINE CRITERIA
   STATUTORY FINDINGS
           PROTECTION OF HH&E
   PROTECTION OF HH&E
           COMPLIANCE WITH ARARs
           LONG-TERM EFFECTIVENESS
           AND PERMANENCE
           TOXICITY, MOBILITY, OR
           VOLUME REDUCTION
           THROUGH TREATMENT
           SHORT-TERM EFFECTIVENESS
           IMPLEMENTABILITY
           COST
           STATE/SUPPORT AGENCY
           ACCEPTANCE
           COMMUNITY ACCEPTANCE
   COMPLIANCE WITH ARARs OR
   JUSTIFICATION OF A WAIVER
   COST-EFFECTIVENESS
   UTILIZATION OF PERMANENT
   SOLUTIONS AND TREATMENT
   OR RECOVERY TO THE
   MAXIMUM EXTENT
   PRACTICABLE("MEP")
                                               PREFERENCE FOR TREATMENT
                                               AS A PRINCIPAL ELEMENT OR
                                               EXPLANATION AS TO WHY
                                               PREFERENCE NOT SATISFIED
   Figure 3. The Relationship of the Nine Criteria to the Statutory Findings
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presentation  of  a  comparative analysis is
given in Appendix F of the RI/FS Guid-
 Note: innovative technologies are being
 considered, their potential advantages in
 cost or performance and the degree of
 uncertainty  associated  with  these
 advantages    (as  compared  with  the
 conventional  technologies  being
 considered) should be discussed.
ARAR Documentation

Major ARARs  associated  with  alterna-
tives  that  undergo  detailed  analysis
should be integrated into the description
of  alternatives in  the  Detailed  Analysis
chapter of  the  FS. In  addition, the FS
should  include  in an  appendix  a table
that  summarizes  all  Federal and  State
requirements  determined  to  be   ARARs
for those alternatives.  The  table  should
cite  the  ARAR,  indicate which alterna-
tives  meet  the  ARAR,  and  identify  any
waiver and  its justification.  The  specific
requirement  should be   stated  in  addi-
tion to (not instead of) the  appropriate
regulatory  reference,  (for example,  CWA
MCL of 5 ppb  TCE).  Appendix  E of the
RI/FS Guidance  presents   a suggested
format  for  documenting  the  identified
ARARs.
  Note:   Other  available  information
  that is  not an  ARAR  (e.g.,  adviso-
  ries; criteria,  and  guidance)  may be
  considered in  the  analysis if  it helps
  to  evaluate  the  alternatives'  effec-
  tiveness   or   protectiveness   and  if
  the  lead and  support agencies agree
  that  its  inclusion  is  appropriate.
  This  "to be considered" (TBC) infor-
  mation   is utilized  in the  detailed
  analysis along with ARARs.
RPM Responsibilities

Ensuring  that  adequate  technical  su-
pervision is being  provided  during the
detailed  analysis as well as oversight of
the RI/FS schedule and budget  are, the
responsibilities   of  the  RPM.   Communi-
cation  with  appropriate  technical  ex-
perts  and,  in   particular,  the  contractor
during this phase of the FS  will help the
RPM fulfill these responsibilities.
Technical Support

The detailed analysis is a technical evaluation
and should not contain conclusions about
remedy selection. Sources of technical support
include the Technical Advisory Committee
(TAC); ORD's Risk Reduction Engineering
Laboratory  and Technical Support Project;
and the Alternative  Treatment Technology
Information Center  (ATTIC), an automated
information system (contact Miles Morse at
FTS-475-7161). See the Scopping Fact Sheet
[OSWER Directive  No. 9355.301FS1  )  for
further information on appropriate technical
experts to utilize during this phase.

Schedule and Cost Control

To complete  this phase of the FS in a cost-
effective and timely manner, the RPM should
ensure that the key participants  have been
involved in all the previous phases of the FS.
These participants include personnel from the
lead   and  support  agencies,   contractor
personnel, members of the TAC, PRPs, and
community  representatives, as appropriate.
Other schedule and cost control techniques
include:

•   Briefing  lead  and  support  agency
    decisionmakers  prior to  the  detailed
    analysis  to  obtain firm  agreement  on
    which alternatives will be evaluated in
    detail.

•   Holding frequent (e.g., monthly) progress
    meetings  or  conference  calls  with
    contractors to review progress and to set
    schedules forcompletingupcomingtasks.

•   Reviewing monthly financial statements
    fromconsultants and making sure that all
    costs are justifiable.

•   Anticipating cost and schedule problems
    based on the previous month's activities,
    and taking actions to avoid or minimize
    unnecessary cost increases and schedule
    delays.
             Enforcement
            Considerations

In an RI/FS project conducted by PRPs, all
aspects of the detailed analysis of alternatives
are typically performed by the PRPs. The RPM
should meet  with the PRP representatives
before they initiate the detailed analysis to
ensure agreement on alternatives, including
process options, that will be evaluated. EPA
should oversee all  aspects of the detailed
analysis. In addition, ARARs identified by the
PRPs should be reviewed and approved by
both  the  lead  and  support  agencies.
Additional information on PRP participation in
the RI/FS and EPA's oversight role  can be
found in Appendix A of the RI/FS Guidance
and in OWPE's Mode I Statement of Work for
PRP-Conducted Remedial Investigations and
Feasibility Studies (June 2, 1989).
         Points to Remember
     Limit  the  evaluation  to  viable,
     distinctive alternatives.

     Focus the evaluation on the strengths
     and weaknesses of each alternative
     relative to the others with respect to
     each criterion.

     Include  sufficient  detail to enable
     decisionmakers   to   understand
     distinctive  features  of  each
     alternative.

     Continue seeking  to identify major
     public concerns during the FS, and if
     possible,  prior to issuance of the
     proposed plan.

     Ensure lead  and support  agencies
     discuss  and agree upon ARARs and
     TBCs.

     Use  sources   of   information
     consistently throughout the FS, such
     as vendors, contractor process/design
     engineers, and members of the TAC.

     Use tables and figures effectively in
     the  presentation   of  the  detailed
     analysis. They will be helpful when
     prepaying  briefings,  the  proposed
     plan, and the ROD.

     Present alternatives  analysis  in a
     level of  detail   that  makes  the
     differences clear, but is not as detailed
     as design specifications.
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