O EDA
OtrA
United States
Environmental Protection
Agency
Solid Waste And
Emergency Response
(OS-220)
Directive 9355.3-01 FS1
November 1989
FILE COPY
Getting Ready
Scoping The RI/FS
This fact sheet is a synopsis of Chapter Two
of the Interim Final Guidance Conducting
Remedial Investigations and Feasibility
Studies Under CERCLA (October 1988,
OWSER Directive No. 9355.3-01). In addition to
summarizing Chapter Two of the guidance, this
fact sheet provides information on how to
manage the scoping phase of the remedial
investigation/feasibility study (RI/F S)process.
The RI/FS is a flexible process that should
be tailored to the specific circumstances
of individual sites. The Remedial
Proj ectManager' s (RPM) central responsibility
is to determine how best to use this flexibility
to conduct an efficient and effective RI/FS that
achieves high-quality results in a timely and
cost-effective manner. Scoping is the initial
planning phase of the RI/FS and is continued
and refined as new information about the site
becomes available.
During scoping, the lead and support agencies
should first identify the type and optimal
sequence of site activities, including whether
the site may best be remedied as separate
operable units.
Operable units are discrete actions that
comprise incremental steps toward the final
remedy, and may be actions that completely
address a geographic portion of a site or a
specific site problem. Operable units may also
be interim or early actions; however, they must
be followed by subsequent actions to
definitively address the scope of the problem.
Early actions must mitigate potential threats,
prevent further environmental degradation, or
rapidly and significantly reduce risks.
Consistent with the general site management
strategy, the specific project scope is then
planned and documented in project plans. A
schematic of the scoping process is presented
in Figure 1.
In the development of the specific project
scope, the objectives of the RI/FS must be
balanced with time and resource constraints.
As an example, to focus efforts and to save
time and expense, a site's sampling program,
developed during scoping, should focus only
on collecting data required to characterize the
risks posed by a site and evaluate those
remedial actions most likely to be appropriate
for a site.
Additionally, to better focus efforts, program
expectations concerning appropriate site
remedies are to be considered and utilized
during proj ect scoping. These expectations will
influence many of the activities described
throughout this fact sheet. In particular,
program expectations will influence the
establishment of remedial action objectives
and the corresponding identification of
potential remedial alternatives. Program
expectations focus on the protection of human
health and the environment through a variety
of methods, including treatment, engineering
controls, and/or institutional controls. EPA has
established the following goal and
expectations to assist in the identification of
those remedial actions that have a significant
potential for being implemented.
Yes
Limited Field
Investigation
\Needed /
Plan
Limited Studies
Execute
Limited Studies
Conduct
Kick-off Meeting
Prepare
Project Plans
Evaluate
Existing [
Technical
Advisory Committee
Develop
Conceptual Site
Model
Initiate
Potential ARAR
Identification
Identify
Remedial Action
Alternatives
Identify
Data Needs and
Corresponding DQOs
Figure 1. The Scoping Process
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Program Goal
The goal of the remedy selection process is
to select remedial actions that are protective
of human health and the environment, that
maintain protection over time, and that
minimize untreated waste.
Program Expectations
Treatment of principal threats will be
used, wherever practicable; principal
threats may include liquids and highly
mobile or highly toxic materials.
•	Engineering controls may be used for
waste that poses a low long-term threat
or where treatment is impracticable.
•	Institutional controls will be used to
mitigate short-term impacts or to
supplement engineering controls; they
will not serve as a sole remedy unless
active response measures are
impracticable.
•	Remedies will often combine treatment
of principal threats with engineering
and institutional controls for treatment
residuals and untreated waste.
•	Innovative technologies should be
considered if they offer the potential
for comparable or superior treatment
performance, fewer/lesser adverse
impacts, or lower costs for a similar
level of performance than
demonstrated technologies.
Ground water will be returned to its
beneficial uses within a timeframe that
is reasonable, where practicable.
Scoping Activities
Conduct Site Kickoff Meetings
To initiate the scoping process and to begin
site management planning, a kickoff meeting
(or series of meetings) is organized by the
RPM. Personnel attending these meetings
should include: representatives from lead and
support agencies including other program staff
(as needed), contractor personnel who will be
performing each portion of the RI/FS or the
oversight, technical experts, (see Technical
Support section), Environmental Services
Division representatives, Natural Resource
Trustee representatives (when applicable),
enforcement staff, and individuals with prior
experience at the site or at similar sites. During
these meetings, the responsibilities for RI/FS
activities will be reviewed and/or assigned. In
addition, lines of communication should be
established among key personnel.
Note: Two or more scoping meetings may
be warranted to reduce project start-up
time and cost. The first mceting(s) may
include Federal and State personnel to
identify the type and optimal sequence of
the site activities and to better focus the
contractor's scope of work. Subsequent
meetings may be held after the work
assignment has been issued and the
contractor has had time to review available
site background data.
Evaluate Existing Data
Asa first step to scoping, existing data will be
compiled and evaluated. A key step in the
evaluation of existing data is the determination
of its quality and usability. Existing data does
not have to be of sufficient quality to make
final decisions but maybe helpful in
developing a conceptual understanding of site
dynamics. Evaluating existing data is
necessary to focus RI/FS efforts and to avoid
duplication of previous activities. In addition,
this activity helps to determine additional data
needs. Data are needed to:
•	Characterize the site to the extent
necessary to support subsequent
decisions
•	Define the risk posed by the site
•	Identify viable remedial action alternatives
•	Identify applicable or relevant and
appropriate requirements (ARARs)
•	Evaluate the need for treatability studies
•	Support enforcement activities
The types of existing data that should be
compiled and evaluated include:
•	Site data gathered during the National
Priorities List (NPL) listing process and
the potentially responsible party (PRP)
search
•	Historical and aerial photographs
•	Records of disposal practices and
operating procedures
•	Generator manufacturing process
information
•	Regional geology, hydrology,
meteorology, and ecology
•	Demographic and land use information
•	Location of sensitive environmental areas,
supply wells, and surface water use on or
near the site
Note: Information sources near the site
will provide valuable site data and should
not be overlooked. Such sources include
local land records and deed books;
representatives from the Soil Conservation
Service, the Agricultural Extension
Service, well drilling companies, and the
Sheriffs office; and mctcrological
monitoring stations for local airports and
towns. In addition, interviews with
present/past site owners and employees
will often provide necessary site
information.
Conduct Site Visit
The information obtained from conducting a
site visit will ease the scoping task, save time,
and help to avoid mistakes and oversights.
After gaining access to the site, the RPM
should walk the site taking field notes and
photographs. Specifically, a site visit should
be conducted to: (1) identify the site' s phy sical
characteristics, noting changes from the
historical data base which may necessitate an
early action, and (2) assist in developing an
understanding of waste sources, areas of
contamination, potential exposure pathways,
and potential receptors at or near the site.
Develop Conceptual Site Model
The conceptual site model is used to: (1)
develop a general understanding of the site to
evaluate potential risks to human health and
the environment and (2) assist in identifying
and setting priorities for the activities to be
conducted at the site. The conceptual site
model may be either a pictorial or graphic
representation of site dynamics as illustrated in
Figure 2 of this fact sheet or Figure 2-2 of the
RI/FS Guidance, respectively. The conceptual
site model identifies:
•	Potential sources of contamination
•	Types of contaminants and affected media
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•	Release mechanisms and potential
contaminant pathways
•	Actual and potential human and
environmental receptors
Note: A limited field investigation may be
undertaken if sufficient information exists
to develop the conceptual model. Normally,
a limited investigation focuses on easily
obtainable data where results can be
received in short time. Examples may
include activities such as geophysical
surveys, well water level measurement, or
sampling and analysis of existing wells.
Identify Remedial Action
Objectives and Potential
Remedial Alternatives
Once a conceptual understanding of the site is
obtained, potential remedial action objectives
should be identified for each media to be
addressed. These objectives consist of
medium or operable unit specific goals for
protecting human health and the environment.
An example of such a goal may include
preventing migration of some carcinogen in the
ground water. Following the establishment of
such objectives, general response actions
(e.g., treatment) for each media
of interest are developed. Technology types
(e.g., chemical treatment) applicable to each
general response action are then identified,
followed by the identification and evaluation
of process options for each technology type.
Table 4-1 ofthq RI/FS Guidance illustrates the
alternative development process and provides
examples that illustrate each of these terms.
Performing this task helps to identify the data
needs for the FS and allows for an early
determination of the need for treatability
studies. If remedial actions involving treatment
have been identified, then the need for
treatability studies should be evaluated during
scoping because of the impact they can have
on RI/FS costs and schedule. Specifically,
literature surveys should be conducted during
scoping to gather information on candidate
technologies. If the technologies have riot
been sufficiently demonstrated or can not be
adequately evaluated, based on the available
information, treatability tests should be
performed.
Note: When developing the preliminary
list of remedial action alternatives,
consideration should be given to the
program expectations and to the types of
response actions selected for other sites
with similar problems or contaminants.
Initiate Identification of
Potential ARARs
Identification of potential ARARs during the
scoping phase will assist in: (1) identifying
remedial goals and alternatives and (2)
establishing communication with the support
agency. Furthermore, early identification of
potential ARARs will allow better planning of
field activities. ARAR identification is
progressive, with requirements identified and
refined as a better understanding is gained of
site conditions, site contaminants, and
remedial action alternatives. The CERCLA
Compliance With Other Laws Manual (Part I-
August 1988 and Part II - August 1989,
OSWER Directive Nos. 9234.1 and 9234.1-02
contains detailed information on identifying
and complying with ARARs.
Note: During scoping, the emphasis should
be on the identification of contaminant- and
location-specific requirements as well as
determining the presence of Resource
Conservation and Recovery Act (RCRA)
regulated hazardous waste. In addition to
Federal ARARs, more stringent State
ARARs must also be identified.
Volatilization
Ingestion/
Inhalation/
Dermal Contact
Dermal
Contact
Dermal
Contact/
Ingestion
Volatilization
Inhalation
Dust/
Volatilization
Volatilization
Ingestion/
Dermal Contact
051
Spills/teaks Lsaks
Surface Water Body
Residential Wells
Fin* to Medium Sand
Infiltration
Infiltration Infiltration
LEGEND
^ Ground Water Table
Elfllllliilj Contaminated Media
Release Mechanism
i>
Exposure Route
Figure 2. Example of a Conceptual Site Model
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Identify Initial Data Needs and
Data Quality Objectives
Thorough and focused identification of data
needs and data quality objectives (DOQs) will
help to avoid data gaps and delays later in the
RI, and should minimize reviews/revisions of
planning documents. Sufficient data must be
obtained to define:
•	Site physical characteristics
•	Physical and chemical characteristics of
sources of contamination
•	Volume of contamination and extent of
migration
•	Potential receptors and associated
exposure pathways
•	Expected performance requirements of
treatment alternatives
This information will be utilized to:
•	Determine contaminant fate and transport
•	Determine the risks posed by a site
•	Determine and evaluate remedial
alternatives
Identify ARARs
•	Identify the need for treatability studies
• Support future enforcement or cost
recovery activities
Once data needs are identified, the strategies
for sampling and analysis are developed, and
the DQOs are established. DQO's specify the
quality of the data required during the different
phases of the RI/FS. The type and quality of
data needed are based on the intended use of
the data, which may include health and safety
planning, site characterization, remedial
alternatives evaluation, or risk assessment.
Additional information on the establishment of
DQOs can be found in Data Quality
Objectives for Remedial Response Activities
(March 1989, OSWERDirectiveNo. 9335.0-7B).
Note: Logistics planning should be
initiated during scoping once data needs
are identified. As an example, procurement
of sampling equipment during scoping may
be necessary as well as making
arrangements with the appropriate
lal)oratorv(ics) because of backlog.
Scoping Deliverables
The deliverables developed during the scoping
phase include several project plans. These
plans are derived directly from activities and
data needs identified during scoping.
Work Plan (WP)
The WP documents the decisions and
evaluations made during scoping and
describes the tasks required to conduct the
RI/FS. The WP includes a description of the
site management strategy, including the
remedial action goals, any short- and long-term
actions that may be required to address site
problems, and the optimum sequence of site
actions and investigative activities. In
addition, the WP describes the site's physical
setting and includes a background summary
detailing the history of previous site activities.
To document the decisions made during
scoping, the WP should include an evaluation
of existing site data, representation of the
conceptual site model, and a description of
potential remedial alternatives. A
comprehensive description of the work to be
performed, including the methodologies to be
utilized, as well as the rationale for performing
the required activities comprises the main body
of the WP. This section also assigns project
responsibilities and sets the project's schedule
and cost.
The format of the WP should follow the 14
standardized tasks that are described in
Appendix B of the RI/FS Guidance. These
tasks have been developed to provide for
consistent reporting and effective
monitoring of all Fund-financed
REMEDIAL INVESTIGATION
Scoping
Taskl*- Project
Planning
Task 2+- Community
Relations
Site Characterization
Treatability Investigations
Task 3*- Field Investigation
Task 7*- Treatability Studies
Task 4*- Sample Analysis/
Validation
Task 8 - RI Reports
I
Task 5 - Data Evaluation
I
I
Task 6 - Risk Assessment
1
1
Task 8 - RI Reports
1
* Those tasks where streamlining
techniques should be used
+ Conducted throughout RI/FS
f f FEASIBILITY f
I 1 STUDY
I
Development and Screening
Detailed
of Alternatives
Analysis
Task 9- Remedial
Task 10- Detailed
Alternatives
Analysis of
Development/
Alternatives
Screening
Task 11- RI/FS

Reports
Task13+- Enforcement
Support
Task 14+- Miscellaneous
	Support
To: SOR, ROD,
RD.RA
Task 12- Post
RI/FS
Support
Figure 3. Relationship of RI/FS Tasks to Phased RI/FS Approach
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RI/FS project. These tasks are also
recommended for use on State- and PRP-lead
projects. Figure 3 depicts the relationships
among these standardized tasks and the role
that they play during the RI/FS. Those tasks
highlighted with an asterisk have been
identified as areas where streamlining
techniques should be utilized to improve the
RI/FS process. Such techniques are described
in O S WER Directive 9355.3-06 (2/14/89) 9355.3-
05 (4/25/88) and 9355.0-20 (7/22/87).
Note: Work plans may need to be amended
when additional data are required to
adequately scope later phases of the RI/FS
or before conducting treatability studies. If
any significant changes to either the
budgetor scope of the WP are required for
Federally funded sites, a Work Plan
Revision Request is submitted for approval.
When changes to the WP do not affect the
budget or schedule, Technical Directive
Memoranda have been found to be useful
for decreasing administrative time.
Sampling and Analysis Plan (SAP)
The SAP is prepared so that sample collection
activities are conducted in accordance with
technically acceptable protocols and that the
data collected in the field meet the DQOs
established during scoping. The plan also
serves as a basis for estimating field costs for
inclusion in the WP. The SAP consists of field
sampling plan (FSP) and a quality assurance
project plan (QAPP). The FSP will define in
detail the data-gathering methods that will be
used ontheproject. TheFSP should be written
so that a field sampling team, unfamiliar with
the site, would be able to gather the required
information. The QAPP will describe the
project objectives and quality
assurance/quality control (QA/QC) protocols
that will be used to achieve the desired DQOs.
A suggested format for the SAP is included in
Table 2-4 of the RI/FS Guidance. Appropriate
guidance on field methods, sampling
procedures, and sample custody requirements
is found inA Compendium of SuperfundField
Operations Methods (August 1987, OSWER
Directive No. 9355.0-14).
Note: Standard sampling and analytical
procedures may be incorporated by
reference into the project plans to avoid
repeating technical review of a procedure
that has already been approvedfor use in a
Region. As an example, there is no need to
explain how to take a split-spoon sample; a
reference to the appropriate American
Society of Testing and Materials (ASTM)
document will suffice.
Health and Safety Plan (HSP)
The HSP identifies potentially hazardous
operations and exposures and prescribes
appropriate protective measures for onsite
workers, the surrounding community, and the
environment. The HSP should include a
detailed site description accompanied by site
maps and the results of previous sampling
activities. The HSP must conform to the firm's
or agency's health and safety program, which
must comply with Occupational Safety and
Health Administration (OSHA) regulations and
protocols. Each HSP should include, at a
minimum, the 11 elements described in
Appendix B of the RI/FS Guidance.
Community Relations Plan (CRP)
The CRP documents the history of community
relations and the issues of community concern
at a site. It describes the objectives of the
community relations activities and how these
objectives will be met and includes a
discussion of planned community interviews,
fact sheets, and public meetings. Discussions
with the community should be initiated during
scoping as relevant information may be
gathered at that time. Report preparation
methods, the elements contained in a CRP, and
a recommended format are included in
Community Relations in Superfund: A
Handbook (June 1988, OSWER Directive No.
9230.0-3B).
RPM Responsibilities
The RPM is responsible for managing each
phase of the RI/FS. These responsibilities
include ensuring that adequate technical,
support is being provided as well as schedule
maintenance and financial control of the
project.
Technical Support
Techniques the RPM may use during scoping
to enhance technical supervision of this phase
include:
•	Identify people with the appropriate
background and experience to serve on
technical Advisory Committee (TAC). The
TAC is a group of personnel from EPA
and other Federal agencies, States, and
consulting firms selected to serve as
technical advisors for a project based on
their areas of expertise. Members of this
committee should include personnel from
ORD's Superfund Technical Assistance
Response Team (START) as well as
personnel from EPA or other treatability
testing laboratories.
The START is a group of engineering
technology experts from ORD whose
primary focus is to provide technical
support on remedy evaluation, selection,
and implementation. Such support will be
provided during scoping in the form of
identification of potential remedial
alternatives and the evaluation of data
needs in support of identified
technologies. For more information on
START, contact Ben Blaney of ORD's
RiskReduction Engineering Laboratory in
Cincinnati, FTS-684-7406 or (513) 569-7406.
•	Incorporate TAC participation into the
project planning phase to identify
technical and/or policy issues early in the
process.
•	Communicate on a regular basis with all
involved parties (key decision makers
from the lead and support agencies;
consultants; Federal Trustees, as
appropriate; and other TAC members) to
reach an early consensus on the project
approach. Inform key decision makers of
all circumstances that relate to making the
final decisions regarding the site
management strategy.
•	Communicate any special concerns
associated with the site to all appropriate
personnel, including the members of the
TAC.
•	Communicate with contractor personnel at
each juncture of the scoping process.
Contractors are not responsible for making
major decisions.
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