United States
Environmental Protection
Agency
Solid Waste And
Emergency Response
(OS-220)
Directive 9355.3-01 FS3
November 1989
4>EPA The Feasibility Study
Development And Screening
Of Remedial Action Alternatives
This fact sheet is the third in a series of four
that summarizes the remedial in-
vestigation/feasibility study (RI/FS) process.
The previous two fact sheets in this series
discuss scoping the RI/FS (OSWER Directive
No. 9355.3-01FS1) and site characterization and
treatability studies (OSWER Directive No.
9355.3-01FS2). This fact sheet provides a
summary of Chapter 4 of the Guidance for
Conducting Remedial Investigations and
Feasibility Studies Under CERCLA (October
1988, OSWER Directive 9355.3-01), which
discusses the development and screening of
alternatives for remedial action. In addition,
this fact sheet provides information intended
to assist the Remedial Project Manager (RPM)
in managing this portion of the feasibility
study (FS) efficiently and effectively.
The FS process consists of the develop-
ment and screening of remedial action
alternatives and a detailed analysis of a
limited number of the most promising options
to establish the basis for a remedy selection
decision.
A range of viable alternatives should be
developed that meet the remedial response
objectives developed during scoping and
refined as the study progresses. This range
should reflect the program expectations to
address the principal threats posed by the site
(i.e., liquids and highly toxic and/or highly
mobile waste) through treatment, and consider
engineering controls (e.g., containment) to
address low-level contaminated materials and
wastes for which treatment is impracticable.
Institutional controls should be considered
primarily as supplements to engineering
controls.
In addition to the program expectations, RPMs
should consider the types of response actions
selected for other sites with similar problems
or contaminants to identify only those
remedial alternatives that carry high potential
of being an effective solution for site
problems. As appropriate, the range of source
control alternatives should include options
employing treatment as a principal element,
one or more containment alternatives, and the
no-action alternative. The major components
that comprise the development and screening
process are presented in Figure 1.
Note: The no-action alternative is used as
a baseline to compare other alternatives.
Measures, such as actions taken to reduce
the potential for exposure (e.g.. site
fencing) should not be included as
components of no-action alternatives. Such
minimal actions should be studied as a
separate, limited-action alternative.
Environmental monitoring may be included
as part of a no-action alternative.
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Development and
Screening Activities
Establish Remedial Action
Objectives
The preliminary remedial action objectives
identified during scoping are refined as
necessary during this phase of the RI/FS to
develop medium-specific goals for protecting
human health and the environment. Remedial
action objectives specify:
•	The contaminant(s) and media of concern
•	The exposure route(s) and receptor(s)
•	The remediation goal(s) for each exposure
route
An example of a remedial action objective is
reducing concentrations of TCE in potable
ground water to 5 ppb.
The contaminants, media of concern, and
exposure routes are the most important
preliminary sources of information necessary
for the development of alternatives. That is,
the identification of appropriate remedial
technologies can be initiated without
identifying the final remediation goal or the
exact cleanup requirement. These
requirements will need to be identified prior to
the detailed analysis of alternatives.
During the development of alternatives,
preliminary remediation goals are established
based onreadily available information such as
applicable or relevant and appropriate
requirements (ARARs). Whereas, final
remediation goals take into consideration the
results of site characterization and the
baseline risk assessment. The baseline risk
assessment defines the risks posed by a site
and establishes the need (or lack thereof) for
remedial action.
Note: Identification of location- and
chemical-specific ARARs, begun during
scoping, should be completed during
alternatives development Examples of such
requirements include:
•	Maximum contaminant levels (MCLs)
•	Water quality criteria
•	State-action levels for drinking water
•	State air emission standards
Develop General Response
Actions
General response actions are selected to
satisfy the remedial action objectives for each
medium of concern. These actions, initially
defined during scoping, are refined during this
phase and relate to basic methods of
protection such as treatment or containment.
Generalresponse actions may be combined to
form alternatives such as treatment of highly
toxic material with containment of the
treatment residuals.
The volume or area to which general response
actions might be applied should be identified
at this time and based on: the exposure routes,
the known nature and extent of contamination,
and preliminary remediation goals and a
preliminary list of action-specific ARARs.
Action-specific ARARs set restrictions on
particular remedial activities as related to the
management of hazardous wastes.
Identify and Screen Appropriate
Technologies
Throughout the RI/FS Guidance and this fact
sheet, the term "technology" refers to general
categories of technologies, such as chemical
treatment or capping. The term "technology
process option" refers to specific alternative
processes within each technology family,
such as ion exchange or use of a soil clay cap.
Note: Typical sources of information can
be used to identity technology needs and to
determine capabilities of technology
process options include:
•	ORD technology experts
•	SITE program staff
•	Technology Screening Guide for
Treatment of CERCLA Sludges and
Soils (EPA/540/2-88/004, September
1988)
•	Appendix D of the RI/FS Guidance
•	Contractor process engineers
•	Equipment vendors
A list of potentially applicable technolo-
gies and technology process options,
corresponding to the identified general
response actions, is compiled and then
reduced by evaluating the process options
with respect to technical implementability.
That is, existing information on technologies
and site characterization data are used to
screen out process options that cannot be
effectively implemented at the site. Figure 4-4
of the RI/FS Guidance illustrates the
necessary documentation for this evaluation
of process implementability and can be
included in the FS report.
To the extent possible, design parameters for
the technologies being considered should be
identified to focus sampling efforts during the
site characterization phase. Field investigation
activities will be ongoing during the
development and screening of alternatives
due to the interactive nature of the RI and FS,
which are conducted concurrently.
Select Representative Process
Options
To simplify the development and evaluation of
alternatives, one representative process
option should be selected, if possible, for each
technology type remaining after the technical
implementability screening procedure.
Effectiveness, implementability, and cost are
the criteria used to evaluate and select
representative process options (see page 3 for
a description of these criteria). The sources of
information used to identify the best
representative process option are the same as
those used to identify technology types.
During remedial design, other process options
may be selected if they are found to be more
advantageous.
Note: Given the performance uncertainty
often assosciated with innovative
technologies, it may not be possible to
evaluate innovative process options on the
same basis as conventional processes. If
available information indicates that
innovative technologies will provide
comparable or superior treatment
performance, fewer or lesser adverse
impacts, or lower cost for a similar level
of performance, they should be retained for
further evaluation.
Reevaluate Data Needs
The need for additional data may become
apparent after representative process options
have been selected. Process engineers,
equipment vendors, and PRP in-house
engineers and chemists can help in
determining which data are re-
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quired to assess potential process limitations
and which data are required to establish
design criteria.
Treatability studies are typically needed
whenever treatment has been identified as a
viable alternative. These studies provide data
on technologies and their effectiveness on a
specific waste found at a site. Treatability
studies may not be necessary in those
instances where information already exists
about a treatment process and its performance
on the same type of waste found at the site.
Assemble Technologies Into
Alternatives
To assemble alternatives, general response
actions should be combined, using different
process options applicable to different
volumes of media or areas of the site, to meet
all remedial action objectives. For example, an
alternative might call for incinerating the most
highly contaminated soil from a portion of the
site, while capping other less contaminated
areas. When combining alternatives, it is
necessary to consider interactions between
media, such as the interaction between ground
water and soils through dissolution,
precipitation, and adsorption processes.
Consideration should also be given to how
general response actions can be integrated in
the most efficient ways. For example, residual
streams that could be addressed by two
different response actions may be best
handled together, such as sludge from a
metals precipitation process and ash from
onsite incineration. A description of each
alternative should be included in the FS
report, including the logic behind the
assembly of the specific remedial action
alternatives.
Screen Alternatives, If Required
The alternative development process should
focus only on the most viable options for site
remediation. In the event that a large number
of viable alternatives remains at the
conclusion of the assembly of alternatives, an
additional screening process should be used
to limit the number of alternatives that must
undergo the detailed analysis.
Source control alternatives retained through
the screening process should include those
options that have a significant potential for
being implemented at the site. The range of
options that may be retained could include:
• Treatment options that minimize
long-term management requirements and
address principal threats
•	Containment options, used either in
conjunction with treatment or alone, that
reduce exposure to waste
•	A no-action alternative (which should be
maintained throughout the analysis)
Note: Generally no more than five source
control alternatives should be carried
through to detailed analysis. Fewer
alternatives may be appropriate in the case
of an early action where options are
limited or obvious, or when program
guidance or ARARs establish appropriate
alternatives.
For ground-water response actions,
alternatives should not only address
remediation or clean-up levels but also the
estimated time frame within which these
clean-up levels might be achieved. Although
the goal of ground-water response actions is
to return the ground water to its beneficial
uses (i.e., health-based levels should be
achieved for potentially drinkable water), it
should be recognized that it may not always
be practicable to attain this goal.
Contingencies may need to be planned for and
discussed in the Record of Decision (see
Considerations in Ground Water
Remediation at Superfund Sites, October
1989, OSWER Directive No. 9355.4-03).
Information on the range of alternatives for
groundwater remedial response actions may
be found in the Guidance on Remedial
Actions for Contaminated Groundwater at
Superfund Sites (December 1988, OSWER
Directive No. 9283.1-2).
During screening, each alternative should be
evaluated with regard to:
•	Short- and long-tern effectiveness and
reductions achieved in toxicity, mobility,
or volume
•	Implementability including technical and
administrative feasibility
•	Grossly disproportionate cost
The "short-term" is considered to be the
remedial construction and implementation
period, while "long-term" begins once the
remedial action is complete and remedial
action objectives have been met.
Technical feasibility includes the ability to
construct, reliably operate, and meet
regulations, as well as the ability to meet the
operations and maintenance, replacement, and
monitoring requirements after completion of
the remedial action. Administrative feasibility
includes the ability to obtain approvals from
other agencies; the availability of treatment,
storage, and disposal services; and the
availability of equipment and technical
expertise.
The objective of the cost evaluation is to
eliminate from further consideration those
alternatives whose costs are grossly excessive
for the effectiveness they provide. Cost
estimates for alternatives should be
sufficiently accurate to continue to support
resulting decisions when their accuracy
improves beyond the screening level. Capital,
O&M, and present worth costs should be
determined. Documentation of the screening
process, if conducted, is required, Figure 4-5
oftheRI/FSGuidance provides an example of
adequate documentation.
Note: Potential action-specific ARARs,
identified earlier, in the process, are
evaluated further with respect to the
remaining remedial action alternatives.
This process continues until the
comparative analysis of he detailed
analysis. By this time all action-specific
ARARs must be identified.
Development and
Screening Deliverables
Although generally no formal report is
required during this phase of the FS, it is
important that the lead and the support
agencies agree in writing on the set of
alternatives selected for detailed analysis.
Based on agreement between the lead and
support agencies, the following information
should be documented in the FS report, which
is submitted following the detailed analysis of
alternatives:
•	Chemical- and/or risk-based remedial
objectives
•	Technologies evaluated and reasons for
exclusion or inclusion
•	Process option representation rationale
•	Rationale for screening out alternatives, if
applicable
•	Clear, concise description of each
alternative, including its respective
chemical-, location-, and action-specific
ARARs
The Detailed Analysis Fact Sheet con-
tains a further description of the con-
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tents of the FS report (OSWER Directive No.
9355.3-01FS4.)
RPM Responsibilities
The RPM is responsible for managing this
phase of the F S and specifically to ensure that
adequate technical support is provided and
that control of the project's schedule and cost
is maintained.
Technical Supervision
Activities needed to ensure that adequate
technical supervision is provided during the
development and screening of alternatives
include:
•	Communication with the support agency,
the contractor, and other technical
experts (i.e., members of the Technical
Advisory Committee [TAC]) to obtain
early agreement on the
technologies/alternatives to be
considered and on ARARs.
It may be appropriate for ORD's START
team to be included on the TAC when
treatment will be considered for complex
or difficult to treat waste. See the Scoping
Fact Sheet (OSWER Directive No. 9355.3-
01FS1) for additional information on the
START team and other technical experts.
•	Emphasize, and provide direction to the
contractor or potentially responsible
parties (PRPs) (if it is a PRP-lead RI/FS),
on the need to focus the effort to identify
and screen technologies so that only a
reasonable range of viable alternatives is
developed.
Schedule and Cost Control
Recommendations that should aid in schedule
and cost control of this phase of the RI/FS
include the following:
•	Hold frequent meetings or conference
calls to monitor progress. These meetings
can be informal, with discussion focusing
on work plan activities that need to be
accomplished in the immediate future and
the status of in-progress tasks that
should be completed. Avoid creating
delays associated with the preparation of
lengthy deliverables to monitor progress.
•	Review contractor monthly financial
statements and make sure all costs are
reasonable and justifiable. If appropriate,
monthly financial statements should be
supplemented by talking with the
contractor's project manager about the
schedule and budget.
•	Control the schedule for inter- and
intra-agency reviews, and schedule
review meetings in advance to emphasize
the deadlines for completion of reviews.
•	Understand the significance of the labor
hour cost to determine if the most
efficient staffing levels are being used.
•	Anticipate cost and schedule problems
based on the contractor's previous
month's performance and take actions to
minimize cost overruns and schedule
delays.
Enforcement
Considerations
The development and screening of remedial
alternatives is conducted much the same
whether it is being financed by the Fund or by
PRPs. If this phase of the RI/FS is being
conducted by the PRPs, they will review, and
if necessary, propose refinement of the
remedial action objectives proposed by EPA
during the proj ect planning phase. Revision of
the objectives is subject to EPA approval.
After refinement of the remedial action
objectives, the PRPs will typically conduct,
underthe oversight of EPA, all aspects of this
phase of the FS. It is suggested that EPA
reviews be scheduled after: screening
technologies and process options, assembling
alternatives, screening alternatives, and
identify ing action-specific ARARs. Additional
information describing 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 Model Statement of Work for PRP-
Conducted Remedial Investigations and
Feasibility Studies (June 2, 1989).
Points to Remember
•	Apply the framework provided by the
RI/FS Guidance appropriately, and
avoid trying to satisfy each step
unnecessarily.
•	Begin the development of alternatives
as soon as preliminary information on
site characteristics is available.
•	Draw on the experience of contractor
process engineers, vendors, ORD, and
other RPMs to help identify appropriate
technologies and process options.
•	Focus alternative development only on
the most viable options for site
remediation. Generally, no more then
five sitewide source control options
should be analyzed in detail.
•	Conduct alternatives screening when
more alternatives have been developed
than can reasonably be evaluated.
•	To the extent possible, identify design
parameters for the technologies being
considered so that relevant data can be
collected during site characterization.
•	Develop alternatives involving
innovative technologies and retain for
detailed analysis if they have the
potential for comparable or superior
treatment performance, fewer or lesser
adverse impacts, or lower costs for a
similar level of performance than a
conventional technology.
•	Communicate with key personnel,
including the TAC, throughout this
portion of the FS.
•	Establishproject management controls
such as status meetings.
•	Closely monitor PRP activities.
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