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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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
Report
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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