Smart Scoping of an EPA-Lead Remedial Investigation/Feasibility Study

*>EPA

United States
Environmental Protection
Agency

EPA 542-F-19-006 | October 2020

Smart Scoping of an EPA-Lead Remedial
Investigation/Feasibility Study

1.0 INTRODUCTION

This fact sheet is a remedial project manager's (RPM's) guide to "smart" scoping the process for conducting
remedial investigations and feasibility studies (RI/FSs). The integrated, three-step process facilitates well-
supported and effective remedy selection decisions while improving project management by integrating

project risk management concepts. Led by the RPM and

supported by the core project team, the RI/FS smart
scoping process is a structured approach that helps
ensure EPA effectively identifies and addresses
individual site priorities and employs investigative
approaches appropriate to site conditions. The target
audience for this fact sheet are RPMs for U.S.

Environmental Protection Agency-lead (EPA-lead) sites.

This fact sheet incorporates best practices in EPA's
recent technical guides:

Smart Scoping Goals

Identify EPA priorities for the site
Align investigation to the site strategy
and CSM

Support contracts acquisition planning
Establish project planning and
documentation throughout the RI/FS
process

• Smart Scoping for Environmental Investigations Technical Guide (EPA 2018a) and

• Strategic Sampling Approaches Technical Guide (EPA 2018b).

It also supplements EPA's Interim Final Guidance on Conducting Remedial Investigations and Feasibility
Studies Under CERCLA, Chapter Two (EPA 1988), and Getting Ready: Scoping the RI/FS (EPA 1989).

Although the focus is EPA-lead RI/FS projects, many of the document's principles and practices can be applied
to other EPA-lead project phases (remedial design, remedial action, long-term response action). In addition,
RPMs with potentially responsible party (PRP) or federal facility (FF)-lead RI/FS projects are encouraged to
use smart scoping tools and the steps described in this document to support negotiation of enforcement
documents, acquiring support contractors, and project planning and execution with their respective PRP or
FF project teams.

2.0 RI/FS SMART SCOPING PROCESS OVERVIEW

The RI/FS smart scoping process entails three steps (Figure 1). The first two steps are part of RI/FS project
planning and the third step relates to RI/FS team planning and execution. Table 1 provides a brief overview of
the process.

Figure 1. Three Step RI/FS Smart Scoping Process

RI/FS Project Planning

^^/F^^an^Jannjn^n d ^xecutioi^^

Step 3: Conduct
Systematic
Project Planning

-------
Table 1. Overview of RI/FS Smart Scoping Process

Purpose

Activities

Outputs/Deliverables

Step 1:
Conduct
Preliminary
Scoping

Establish high-level RI/FS
project scope and
schedule.

• RPM, in collaboration with their management,
establishes core project team to help develop or
update key planning documents (see outputs).

• Based on outputs, core project team analyzes site
priorities, conceptual site model (CSM) data gaps,
and project risk and determines high-level project
scope and schedule.

• Updated site planning
documents (site
strategy, CSM, project
risk register)

• High-level RI/FS project
scope and schedule

Step 2:

Acquire

RI/FS

Contractor

Develop RI/FS contract
requirement and acquire
RI/FS contractor.

• EPA conducts activities necessary to acquire RI/FS
contractor.

• EPA determines appropriate acquisition tool.

• RPM, supported by core project team, uses
outputs of Step 1: Preliminary Scoping to develop
outputs of Step 2: Acquire RI/FS contractor; Step 1
outputs include technical procurement planning
documents.

• Detailed contract
requirement document

• Independent
government estimate
(IGE)

• Award of RI/FS
acquisition vehicle

Step 3:

Conduct

Systematic

Project

Planning

Ensure sequence and
scope of individual RI/FS
tasks align with key
project needs to advance
RI/FS toward remedy
decision.

• EPA core project team and RI/FS contractor:
o convene during key milestones in RI/FS
schedule;

o update CSM and project risk register;
o review sequence and scope of upcoming RI/FS
tasks to determine if modification needed
and;

o develop decision logic to dynamically guide
sampling in the field.

• Updated CSM and
project risk register

• Agreed upon sequence
and scope of future
RI/FS tasks

The three steps of the smart scoping process are discussed in more detail below.

STEP 1: CONDUCT PRELIMINARY SCOPING

This section addresses key activities and outputs/deliverables
developed or updated during preliminary scoping. These activities
and deliverables are critical to the RI/FS project's planning and
execution.

Establish the Core Project Team

It is recommended that the RPM, in collaboration with their
management, assemble a core project team to support the entire
RI/FS smart scoping process. The team's membership and time
commitment will vary as the process moves through the smart
scoping steps.

The core project team may include staff or management with the expertise needed to address site-specific
technical issues, RI/FS policy issues, and stakeholder concerns/challenges. Core team members may include
geologists; hydrogeologists; human health and ecological risk assessors; engineers; sediments, radiation or
mining site experts; community involvement coordinators; and budget and acquisition support staff.

Preliminary Scoping Steps

Establish the core project team
Develop or update the CSM
Conduct project risk analysis
Define site strategy
Document high-level RI/FS scope
and schedule

-------
Additional support may come from EPA regions, Headquarters, Office of Research and Development
laboratories, states, tribes, other federal agencies, or support contractors.

Develop or Update the Conceptual Site Model

The CSM is an iterative, 'living representation' of a site (see Table 2 for CSM components). The CSM helps the
core project team visualize and understand available information, and it is a primary project planning and
management tool, updated and used throughout a project's life (EPA 2011). The CSM developed at the

Table 2. Components of a CSM

preliminary scoping stage
outlines key site
characteristics, data gaps,
and assumptions.

The CSM format reflects a
site's complexity and the
amount of available site-
specific information. Maps,
figures, and tables can be
used to effectively capture
many of the CSM
components. Table 3 shows
an example CSM format and
Table 4 provides an example
of one element from one
component of a site CSM
from preliminary scoping.

The core project team's
technical members assist in
CSM development. The team
uses the preliminary scoping
CSM to identify data gaps,
which, in turn, will inform site
priorities and the high-level
RI/FS scope's development.

This CSM will be used and updated during Step 3: Conduct Systematic Project Planning.

Table 3. Example Conceptual Site Model Format

CSM Component

Description

Past Use and
Disposal

Uses of site, known and suspected locations of sources, and
contaminants of concern.

Previous
Investigations

Conclusion and results from previous investigations conducted
at site by EPA, state, or other entity.

Media and Transport

Media impacted by contamination and how contaminants are
transported in media and between media.

Potential media include sources of waste and contaminants;
soil in unsaturated zone as a source or media for transport of
vapors; groundwater, including soil and bedrock transporting
groundwater; surface water; sediment; and air, including
ambient air and indoor air affected by vapor intrusion.

Intended Reuse

Current and potential uses and local interest in reuse.

Decision Criteria

Criteria technical members of the core project team use to
compare sampling results and make project-related decisions
for each medium to be investigated.

Pathway Receptor
Network

Primary and secondary sources, migration pathways,
receptors, and exposure routes. Risk assessor on core project
team takes lead on developing this component.

Technologies and
Approaches

Characterization technologies and approaches and
technologies and remedial actions that may be applicable to
site conditions and that could be used to mitigate risks early in
project and over the long term.

Completion Strategy

Strategy and schedule for operable units and pipeline phases
of each operable unit; early actions; priorities; phasing of
operable units and early actions; and completion of activities
sitewide.

Project Manager:

Date:

CSM Element

Known Information

Data Gaps

Project Risks

Past Use

Previous Investigations

Media and Transport

Intended Reuse

Described in Table 5.

Decision Criteria

Pathway-Receptor Network

Technologies and Approaches

Completion Strategy

-------
Table 4. CSM Example Excerpt from Site with Vapor Intrusion

Project Manager:

Date:

CSM Element

Known Information

Data Gaps

Project Risks

Previous
Investigations

- Extensive Rl:
included soil,
groundwater, vapor
intrusion
contamination
delineation, and
source identification

- Risk assessment not conducted

- Some commercial sites not sampled

- Utility conduits not evaluated as a potential
migration pathway

- Presence of dense non-aqueous phase liquid
indicated but not confirmed

- Other potential sources not evaluated

Excerpt in
Table 6.

Conduct Project Risk Analysis

Project risk events are items that may affect a project's scope, schedule, budget, and contracting. Project
managers continually evaluate such risks as the project progresses; project risks are separate and distinct
from the human health or ecological risks assessed as part of the RI/FS process. Project risk events may
represent technical or policy considerations, such as nature and extent of contamination, emerging
contaminants, newly identified human health and ecological exposure pathways, and technology
performance or effectiveness. Project risk events may also include project execution or management
considerations, such as weather delays and seasonal work restrictions, site access, funding or contracting
delays, and community or enforcement actions.

The core project team's technical and policy members help the RPM brainstorm and identify a site's project
risk events. The core project team can analyze identified risks, namely the probability of occurrence and the
potential impact on scope, schedule, or budget. This effort can help the core project team identify those
project risk events that are high priority (i.e., have potential for greatest impact) and develop strategies to
mitigate them.

During preliminary scoping, the project risk analysis has two purposes. It can: (1) help the core project team
develop or refine the site strategy (discussed in the next section) to ensure site-level goals and priorities are
informed and consider the project risk analysis' findings; and (2) assist in the high-level RI/FS scope's
development and highlights key decision points in the implementation of site activities. These activities
include the types of data collection activities or technology evaluations that might be considered during RI/FS
execution.

The core project team may use a project risk register table (Table 5), a tool commonly used to present project
risks in a concise, organized format. Table 6 provides an excerpt from the project risk register for the site in
Table 4. The excerpt analyzes project risks related to the data gap of "other potential sources not evaluated."

-------
Table 5. Example Project Risk Register

Project Risk Register for [Site Name]

Remedial Pro

ect Manager:

Date:

Item No.

Description of

Probability of

Consequence

Project Risk

Occurrence

Description (Scope,

Magnitude of Impact

Mitigation

Event

(High/Medium/Low)

Schedule, Budget)

(High/Medium/Low)

Strategies

Table 6. Excerpt Example from Project Risk Register

Project Risk Register for [Site Name]

Remedial Project Manager:

Date:

Item No.

Description of
Project Risk
Event

Probability of
Occurrence
(High/
Medium/Low)

Consequence

Project Risk
Mitigation
Strategies

Description (Scope, Schedule,
Budget)

Magnitude of
Impact
(High/Medium/Low)

Additional
undiscovered
sources of VI
contamination
exist

High

Record of Decision that does
not address all VI sources
Delay in completing cleanup
Unacceptable human health
risks

High

Include
additional
source
identification
in RI/FS scope

Develop the Site Strategy

A site strategy documents and prioritizes site cleanup goals, identifies key issues and challenges, and outlines
a site-specific approach (strategy), including key CERCLA remedial activities, needed to achieve these goals.
Informed by the CSM and project risk analysis, the site strategy serves as a framework for planning and
scheduling the detailed activities necessary to achieve the project goals. Thus, the site strategy is the basis for
the planning data entered into EPA's Superfund Enterprise Management System (SEMS). Like the CSM, the
site strategy is a living document; the RPM and core project team review and update it throughout the site
cleanup process to ensure it reflects current goals, issues, and priorities. It is recommended that RPMs revisit
the site strategy at least annually.

The high-level RI/FS scope and schedule discussed in the next section should align with the site strategy.

Document High-Level RI/FS Scope and Schedule

Preliminary scoping's final step is to develop the RI/FS' overarching scope and schedule based on the site
planning documents - preliminary CSM, project risk register, and site strategy. This high-level scoping and
scheduling support the development of the next step's contract documentation. Table 7 lists the three main
elements of a high-level RI/FS scope and schedule and provides examples for each element.

-------
Table 7. Elements of High-Level RI/FS Scope and Schedule

Element

Examples

1. Part of site

- Operable Unit

being addressed

- Media

2. List of tasks to

- Types of sampling anticipated

be conducted

- Modeling needs

and planned

- Applicable or relevant and appropriate requirements to be identified and

timeframe

evaluated

-	Reuse assessment (EPA 2001) to determine and document reasonably
anticipated future land use

-	Types of human health and ecological risk assessments needed

-	Types of technologies and alternatives to be evaluated

-	Any treatability studies envisioned

-	Community involvement needs

-	Any RI/FS support needed, such as technical meeting support and technical
support during development of decision documents

3. Key milestones

- RI/FS acquisition completion

and schedule

- RI/FS completion

for achievement

- Decision document completion

STEP 2: ACQUIRE RI/FS CONTRACTOR

Using the preliminary scoping information, the RPM, with the
core project team's support, initiates the acquisition of a
contractor to perform the RI/FS. This initiation includes
recommending the RI/FS acquisition vehicle, drafting the
procurement package's technical documents, and as
appropriate, participating in the RI/FS contractor selection
process.

Determine RI/FS Acquisition Vehicle

For an EPA-lead RI/FS, the Agency can use EPA pre-placed contracts, interagency agreements (lAs) with other
federal agencies, or cooperative agreements (CAs) with states and tribes. Using the high level-RI/FS scope
and schedule, the RPM works closely with the EPA contracting office to determine the most appropriate
acquisition vehicle to deliver the RI/FS support services.

Develop Technical Procurement Planning Documents

Based on the selection of the acquisition vehicle, the RPM and the core project team use the preliminary
scoping outcomes to develop the technical procurement planning documents, including a work statement, an
IGE, and any technical evaluation factors necessary to acquire the RI/FS contractor.

Develop Work Statement

The work statement, commonly referred to as a "performance work statement" or "statement of work,"
defines RI/FS activities, deliverables, and timelines that the contractor will support. The core project team
uses the CSM, project risk register, and high-level RI/FS scope to develop a work statement with the
specificity necessary for the RI/FS contractor to provide a technical approach and estimated cost for the
entire RI/FS effort. In the case of assisted acquisitions (i.e., lAs and CAs), the outputs of preliminary scoping

RI/FS Contractor Acquisition Steps

Determine RI/FS acquisition vehicle
Develop technical procurement
planning documents
Award RI/FS acquisition vehicle

6

-------
should be conveyed in the IA or CA requirement with sufficient detail to support the state or other federal
agency's work statement development. The work statement includes priority data needs for the CSM and
mitigation strategies to address any high priority project risks. The format of the work statement depends on
the selected acquisition vehicle.

Develop Independent Government Estimate

The IGE includes detailed cost estimates for all RI/FS tasks in the work statement. For EPA contracts, the
estimates comprise the labor, equipment, travel, subcontracting, and other direct costs for the task's
completion. The project risk register, which helps identify those items or tasks that have a high change
probability, can help the core project team determine the contracting structure and pricing methods that
best accommodate these project risks.

Technical Evaluation Factors or Criteria

If an EPA contract is being used to acquire the RI/FS contractor, the RPM, with support from the core project
team, identifies what technical qualifications and capabilities are critical for the RI/FS contractor to possess to
ensure successful execution of the work. Those qualifications and capabilities are communicated and
coordinated with the EPA acquisition office to support the procurement package's development and any
evaluation procedures needed.

Award RI/FS Acquisition Vehicle

Based on the selected acquisition vehicle, EPA will acquire the RI/FS contractor in accordance with the
Federal Acquisition Regulation and EPA acquisition guidance.

STEP 3. CONDUCT SYSTEMATIC PROJECT PLANNING

At this point, RI/FS acquisition activities have been completed,

and the RI/FS contractor becomes part of the core project team.

RI/FS projects are typically multi-year projects where tasks are
sequenced and scoped based on the best available information
and the baseline CSM. Since there are considerable data gaps in
the CSM during an RI/FS, there is high probability that either the
sequence or scope of RI/FS tasks may change as the project
progresses.

Systematic Project Planning:
Timing

At kick-off meeting after RI/FS
contract award
Before each RI/FS data
collection effort

Systematic project planning is a process that requires the
core project team to convene during key milestones in the
RI/FS schedule in order to update the CSM and project risk
register, and to review the sequence and scope of
upcoming RI/FS tasks to determine if they are still
appropriate or need modification. Systematic planning
ensures that budget and resources are focused on those
items critical to advancing the RI/FS project towards
remedy decision. EPA promotes the use of systematic
planning after RI/FS contract award for EPA-lead projects
and, at a minimum, before each RI/FS data collection effort. More information on systematic planning is
found in Guidance on Systematic Planning Using the Data Quality Objectives Process (EPA 2006).

Goal of Collaborative Systematic Project
Planning Meetings

Develop a consensus (or divergence)
on known site conditions, contaminant
fate and transport hypotheses, data
gaps, data collection plans, and
potential remedial challenges.

-------
The systematic project planning activities described below focus on: (1) Systematic planning during kickoff
meeting, and (2) Systematic planning meetings during RI/FS execution. The RPM, supported by the core
technical team and the RI/FS contractor, leads systematic project planning.

Kickoff Meeting

After EPA awards the RI/FS acquisition vehicle, the EPA project team and the RI/FS contractor, jointly referred
to below as the RI/FS team, generally hold a kickoff meeting to discuss the project. EPA should include
systematic project planning as an agenda item. At the kickoff meeting, systematic planning efforts focus on
striving for understanding and consensus around the project scope and schedule and the related key project
management and contracting documents. Below are some systematic planning agenda items to consider for
the kickoff meeting:

• Review preliminary CSM. The RI/FS team discusses the preliminary CSM developed during
preliminary scoping. This discussion ensures the RI/FS team becomes familiar with the CSM's content
and that the team strives to reach consensus on data gaps and how the RI/FS scope and sequence of
activities address those gaps.

• Review project risk register. The RI/FS team reviews the project risk register's contents and adds or
modifies project risk events, based on RI/FS contractor input.

• Review rationale for RI/FS tasks' sequence and scope. Typically, when EPA executes an RI/FS, the
work statement has a sequence of RI/FS tasks. The RI/FS team discusses the rationale for the
sequence of tasks, with a focus on near-term (funded) tasks, their objectives, and how the
information will be used to inform scope and sequence of the next set of tasks.

• Establish milestones for subsequent systematic project planning meetings. As is discussed in the next
section, systematic planning meetings are important throughout RI/FS execution, particularly when
planning for and after execution of an investigation or data collection event.

Meetings During RI/FS Execution

The purpose of systematic project planning meetings is to ensure adequate planning is conducted throughout
the RI/FS. These meetings are an essential part of the process the RI/FS team uses to collaboratively review
and update key project management documents and make needed changes to the RI/FS scope and sequence
of activities. This process ensures that, throughout RI/FS execution, time and resources are allocated to
activities that effectively advance the RI/FS process towards
remedy selection.

Prepare for and Conduct Systematic Project
Planning meetings

Systematic project planning meetings occur at key
milestones throughout the RI/FS process, prepare for a field
investigation or data collection event, or after these events.

To prepare for each systematic planning meeting, the RI/FS
team refines the current CSM based on information
collected from ongoing RI/FS activities or any new site
information that has come to the RI/FS team's attention.

At each systematic project planning meeting, the RI/FS team
discusses and further refines key project management
documents based on the team discussions and consensus.

Discussions include:

Systematic Project Planning Aligns
CSM and Project Risk
Updates with RI/FS Tasks

As part of systematic project
planning, the RI/FS team reviews the
scope and sequence of upcoming
RI/FS tasks in contracting
documents. The review focuses on
whether the task scope adequately
addresses key CSM needs and
project risk events or if modification
is needed.

-------
• Review and update current CSM. The RI/FS team reviews and discusses the current CSM. The team
focuses on data gaps, evaluates sequencing dynamic work strategy tasks, and identifies any potential
remedial challenges. The team should strive for consensus on the types of data collection or
information gathering needed to address these gaps and challenges.

• Review and update project risk register. After review of the CSM, the RI/FS team reviews the project
risk register, which may result in changes to existing project risk events, particularly in terms of
probability or consequence, and changes to mitigation strategies. The project risk analysis may also
identify new risks based on ongoing RI/FS activities.

Meeting Outcomes

If contracting documents require changes, the EPA RPM summarizes the change and discusses with the
contracting agency (i.e., EPA contracting office, other federal agency, or state). As appropriate, the EPA team
assists in preparing documentation to support the appropriate contract modification action.

When the RI/FS team agrees on the upcoming tasks' scope, EPA may request that the RI/FS contractor
prepare a detailed workplan for this activity. It is recommended that these workplans focus on a dynamic
work strategy describing the tools and techniques for the site investigation and event sequencing to be used
to fill data gaps. The dynamic work strategy's purpose is to collect data, make decisions, and adjust
investigative activities in real time. Important components of a dynamic work strategy include a flexible
sampling approach, an adaptive quality control program and clearly documented decision logic (EPA 2005).
The RI/FS contractor integrates the dynamic work strategy into project plans such as the health and safety
plan, sampling and analysis plan, quality assurance project plan, and data management plan.

3.0 CONCLUSION

Smart scoping supports the development of a robust CSM needed for effective response action development,
selection and implementation (EPA 2018a). Smart scoping, including systematic project planning, integrates
the CSM and project risk management with the overall site strategy, which, in turn, supports the
development of the RI/FS, including its scope, schedule, and budget needs.

4.0 REFERENCES

EPA. 1988. Interim Final Guidance on Conducting Remedial Investigations and Feasibility Studies Under
CERCLA. EPA 540-G-89-007. October.

EPA. 1989. Getting Ready: Scoping the RI/FS. Directive 9355.3-01FS01. November.

EPA. 2001. Reuse Assessments: A Tool to Implement the Superfund Land Use Directive. OSWER Directive No.
9355.7-06P.June.

EPA. 2005. Use of Dynamic Work Strategies Under a Triad Approach for Site Assessment and Cleanup -
Technology Bulletin. EPA 542-F-05-008. September.

EPA. 2006. Guidance on Systematic Planning Using the Data Quality Objectives Process. EPA QA/G4.
EPA/240/B-06/001. February.

EPA. 2011. Environmental Cleanup Best Management Practices: Effective Use of the Project Life Cycle
Conceptual Site Model. EPA 542-F-11-011. July.

EPA. 2018a. Smart Scoping for Environmental Investigations Technical Guide. EPA 542-G-18-004. November.

EPA. 2018b. Strategic Sampling Approaches Technical Guide. EPA 542-F-18-005. November.

-------