United StatesEnvironmental ProtectionAgency

Office of Emergency andRemedial ResponseWashington, DC 20460

PE89-184626

EPA/540/G-89/004OSWER Directive 9355.3-01October 1988

Superfund

EPA Guidance forConducting RemedialInvestigations andFeasibility StudiesUnder CERCLA

Interim Final

EPA/540/G-89/004OSWER Directive 9355.3-01

October 1988

Guidance for Conducting RemedialInvestigations and Feasibility Studies

Under CERCLA

Interim Final

Office of Emergency and Remedial ResponseU.S. Environmental Protection Agency

Washington, D.C. 20460

Notice

Development of this document was funded, wholly or in part, by the United StatesEnvironmental Protection Agency under Contract No. 68-W8-0098. It has beensubjected to the Agency’s review process and approved for publication as an EPAdocument.

The policies and procedures established in this document are intended solely for theguidance of government personnel. They are not intended and cannot be relied uponto create any rights, substantive or procedural, enforceable by any party in litigationwith the United States. The Agency reserves the right to act at variance with thesepolicies and procedures and to change them at any time without public notice.

Contents

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Contents (continued)

iv

Contents (continued)

V

Contents (continued)

Figures

Number Page

vii

Tables

Number Page

viii

Glossary

ix

NIOSHNPDES

NPL

O&M

OSHA

OSWER

q 1*

PRP

QA

QAPP

QC

RAS

RCRA

RD

RfD

RI/FS

ROD

RPM

SAP

SARA

SAS

SDWA

SI

SITE

SOP

s o w

SPHEM

SWDA

TAT

TBC

TCL

TOM

TSCA

WPRR

National Institute for Occupational Safety and Health

National Pollutant Discharge Elimination System

National Priorities List: A list of sites identified for remediation under CERCLA.

Operation and maintenance

Occupational Safety and Health Administration

Office of Solid Waste and Emergency Response

Cancer potency factor: The lifetime cancer risk for each additional mg/kg bodyweight per day of exposure.

Potentially responsible party

Quality assurance

Quality assurance project plan: A plan that describes protocols necessary toachieve the data quality objectives defined for an RI. (See SAP.)

Quality control

Routine analytical services

Resource Conservation and Recovery Act

Remedial design

The reference dose (RfD) is an estimate (with uncertainty spanning perhaps anorder of magnitude) of a daily exposure to the human population (includingsensitive subgroups) that is likely to be without appreciable risk of deleteriouseffects during a lifetime.

Remedial investigation/ feasibility study

Record of Decision: Documents selection of cost-effective Superfund-financed remedy.

Remedial Project Manager: The project manager for the lead Federal agency.

Sampling and analysis plan, consisting of a quality assurance project plan(QAPP) and a field sampling plan (FSP).

Superfund Amendments and Reauthorization Act of 1986. (See CERCLA.)

Special analytical services

Safe Drinking Water Act

Site investigation

Superfund innovative technology evaluation

Standard operating procedures

Statement of Work

Superfund public health evaluation manual

Solid Waste Disposal Act

Technical assistance team

To be considered

Target compound list

Technical directive memorandum

Toxic Substances Control Act

Work plan revision request

Acknowledgments

This document was developed by EPA’s Office of Emergency and Remedial Response(OERR) with assistance provided by CH2M HILL in partial fulfillment of Contracts No.68-01-7090 and 68-W8-0098. Steven C. Golian served as EPA project manager,with assistance from Elizabeth A. Shaw. The CH2M HILL project team includedElizabeth Dodge, Brint Bixler, Phil Smith, Julie Pfeffer, Brian Marshall, Bill Gould, andJeannie Massie.

In addition to the many EPA Headquarters personnel who assisted in this effort, thefollowing Regional and State representatives provided significant contributions to thepreparation of this document:

Bruce Marshall Region IRobert McKnight Region IIDon Lynch Region IIJeff Pike Region IllBeverly Houston Region IVMartha Berry Region IVCindy Nolan Region VJoan Calabrese Region VMary Tyson Region VJohn Blevins Region IXJohn Rendall Region IXDave Tetta Region XRobert Chapin Texas Water CommissionEd Putnam New Jersey Department of

Environmental ProtectionGary Pulford Minnesota Pollution

Control Agency

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l-l

Chapter 1Introduction

1.1 Purpose of the RI/FS

The remedial investigation and feasibility study(RI/FS) process as out l ined in this guidancerepresents the methodology that the Superfundprogram has established for characterizing the natureand extent of risks posed by uncontrolled hazardouswaste sites and for evaluating potential remedialoptions. This approach should be viewed as adynamic, flexible process that can and should betailored to specific circumstances of individual sites: itis not a rigid step-by-step approach that must beconducted identically at every site. The projectmanager’s central responsibility is to determine howbest to use the flexibility built into the process toconduct an efficient and effective RI/FS that achieveshigh quality results in a timely and cost-effectivemanner. A significant challenge project managersface in effectively managing an RI/FS is the inherentuncertainties associated with the remediation ofuncon t ro l led hazardous was te s i tes . Theseuncertainties can be numerous, ranging from potentialunknowns regarding site hydrogeology and the actualextent of contamination, to the performance oftreatment and engineering controls being consideredas part of the remedial strategy. While theseuncertainties foster a natural desire to want to knowmore, this desire competes with the Superfundprogram’s mandate to perform cleanups withindesignated schedules.

The objective of the RI/FS process is not theunobtainable goal of removing all uncertainty, butrather to gather information sufficient to support aninformed risk management decision regarding whichremedy appears to be most appropriate for a givensite. The appropriate level of analysis to meet thisobjective can only be reached through constantstrategic thinking and careful planning concerning theessential data needed to reach a remedy selectiondecision. As hypotheses are tested and eitherrejected or confirmed, adjustments or choices as tothe appropriate course for further investigations andanalyses are required. These choices, like theremedy selection itself, involve the balancing of awide variety of factors and the exercise of bestprofessional judgment.

1.2 Purpose of the GuidanceThis guidance document is a revision of the U.S.Environmental Protection Agency’s (EPA) Guidanceon Remedial Investigations Under CERCLA (May1985) and Guidance on Feasibility Studies UnderCERCLA (June 1985). These guidances have beenconsolidated into a single document and revised to(1) reflect new emphasis and provisions of theSuperfund Amendments and Reauthorization Act(SARA), (2) incorporate aspects of new or revisedguidance related to aspects of remedial investigationsand feasibility studies (RI/FSs), (3) incorporatemanagement initiatives designed to streamline theRI/FS process, and (4) reflect experience gained fromprevious RI/FS projects.

The purpose of this guidance is to provide the userwith an overall understanding of the RI/FS process.Expected users include EPA personnel, Stateagencies responsible for coordinating or directingactivities at National Priorities List (NPL) sites,potentially responsible parties (PRPs), Federal facilitycoordinators, and consu l tan ts o r compan iescontracted to assist in RI/FS-related activities at NPLs i tes . Th is gu idance descr ibes the genera lprocedures for conducting an RI/FS.1 Where specificguidance is currently available elsewhere, the RI/FSguidance will simply highlight the key points orconcepts as they relate to the RI/FS process andrefer the user to the other sources for additionaldetails.

1.3 Overview of CERCLAReauthorization

SARA was signed by the President on October 17,1986, to amend the Comprehensive EnvironmentalResponse, Compensation, and Liability Act of 1980

1 This guidance document does not typically address differencesin the general procedures (e.g., work plan preparation,reporting requirements) between a Fund-financed and PRP-conducted RI/FS, and the flexibility discussed for certainactivities may not pertain to a PRP-conducted RI/FS.Therefore, when PRPs are conducting an RI/FS, this guidancedocument must be used in conjunction with the “InterimGuidance on PRP Participation in the RI/FS Process” (seeAppendix A).

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(CERCLA). While SARA did not change the basicstructure of CERCLA, it did modify many of theexist ing requirements and added new ones.References made to CERCLA throughout thisdocument should be interpreted as meaning“CERCLA as amended by SARA.”

Many of the new provisions under CERCLA havingthe greatest impact on the RI/FS process arecontained in §121 (Cleanup Standards). Other notablechanges that also affect the RI/FS process arecontained in §104 (Response Authorities, in particularHealth-Related Authorities), portions of §104 and§121 regarding State involvement, §117 (PublicParticipation), §110 (Worker Protection Standards),and §113 (Civil Proceedings). Highlights of thesesections are summarized below.

1.3.1 Cleanup Standards

Section 121 (Cleanup Standards) states a strongstatutory preference for remedies that are highlyreliable and provide long-term protection. In additionto the requirement for remedies to be both protectiveof human health and the environment and cost-effective, additional remedy selection considerationsin 5121(b) include:

l A preference for remedial actions that employtreatment that permanently and significantlyreduces the volume, toxicity, or mobility ofh a z a r d o u s s u b s t a n c e s , p o l l u t a n t s , a n dcontaminants as a principal element

l Offsite transport and disposal without treatment isthe least favored alternative where practicabletreatment technologies are available

l The need to assess the use of permanentsolutions and alternative treatment technologiesor resource recovery technologies and use themto the maximum extent practicable

Section 121 (c) also requires a periodic review ofremedial actions, at least every 5 years after initiationof such action, for as long as hazardous substances,pollutants, or contaminants that may pose a threat tohuman health or the environment remain at the site. Ifit is determined during a 5-year review that theaction no longer protects human health and theenvironment, further remedial actions will need to beconsidered.

1.3.1.1 Applicable or Relevant and AppropriateRequirements

Section 121(d)(2)(A) of CERCLA incorporates into lawthe CERCLA Compliance Policy, which specifies thatSuperfund remedial actions meet any Federalstandards, requirements, criteria, or limitations thatare determined to be legally applicable or relevant

and appropriate requirements (ARARs). Also includedis the new provision that State ARARs must be met ifthey are more stringent than Federal requirements.Federal statutes that are specifically cited in CERCLAinclude the Solid Waste Disposal Act (SWDA), theToxic Substances Control Act (TSCA), the SafeDrinking Water Act (SDWA), the Clean Air Act (CAA),the Clean Water Act (CWA), and the MarineProtection Research and Sanctuaries Act (MPRSA).Additional guidance on ARARs is provided in the“CERCLA Compliance with Other Statutes” manual(U.S. EPA, Draft, August 1988).

Sec t ion 121(d) (4 ) o f CERCLA iden t i f ies s ixcircumstances under which ARARs may be waived:

l The remedial action selected is only a part of atotal remedial action (interim remedy) and thefinal remedy will attain the ARAR upon itscompletion.

l Compliance with the ARAR will result in a greaterrisk to human health and the environment thanalternative options.

l Compl iance with the ARAR is technical lyimpracticable from an engineering perspective.

l An alternative remedial action will attain anequivalent standard of performance through theuse of another method or approach.

l The ARAR is a State requirement that the statehas not consistently applied (or demonstrated thei n t e n t t o a p p l y c o n s i s t e n t l y ) i n s i m i l a rcircumstances.

l For §104 Superfund-financed remedial actions,compliance with the ARAR will not provide abalance between protecting human health and theenvironment and the availability of Superfundmoney for response at other facilities.

1.3.1.2 Offsite FacilitiesThe new statutory requirements contained in§121 (d)(3) for acceptable offsite disposal facilities, inmost respects, incorporate previous Agency policy.Offsite disposal facilities receiving contaminants mustbe in compliance with Resource Conservation andRecovery Act (RCRA) and other Federal and Statelaws. In addition, the unit receiving the waste musthave no releases to ground water, surface water, orsoil; other units that have had releases at the facilitymust be under an approved corrective actionprogram.

1.3.2 Health Assessments

Under CERCLA §104(i) (Health-Related Authorities),the Agency for Toxic Substances and Disease

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Registry (ATSDR) must conduct a health assessmentfor every site proposed for inclusion on the NPL. Thepurpose of these health assessments is to assist indetermining whether current or potential risk tohuman health exists at a site and whether additionalinformation on human exposure and associated healthrisks is needed. The health assessment is required tobe completed “to the maximum extent practicable”before completion of the RI/FS.

1.3.3 State Involvement

Section 104(c)(3)(C) of CERCLA remains in effectrequiring a lo-percent State cost share for remedialactions at privately operated sites and 50 percent atpublicly operated sites. 2 Section 104(c)(3)(A) and104(c)(6) of CERCLA provide that the operation andma in tenance o f g round- and su r face-wa te rrestoration measures be considered part of remedialaction for up to 10 years after commencement ofoperations or until remedial action is complete,whichever is earlier. Therefore, such activities duringthe lo-year period would be eligible for either 50 or90 percent Federal funding depending on whether thesite was publicly or privately operated.

Section 121(d)(2)(A) of CERCLA specifies that morestringent State ARARs apply if they are identified in atimely manner by the state. Section 121 (f) requiresEPA to develop regulations for substantial andmeaningful State involvement in the remedialresponse process and specifies certain minimumrequirements.

1.3.4 Community Involvement

Section 117 of CERCLA (Public Participation)emphasizes the importance of early, constant, andresponsive relations with communities affected byS u p e r f u n d s i t e s a n d c o d i f i e s , w i t h s o m emodifications, current community relations activitiesapplied at NPL sites. Specifically, the law requirespublication of a notice of any proposed remedialaction (proposed plan) in a local newspaper ofgeneral circulation and a “reasonable opportunity” forthe public to comment on the proposed plan andother contents of the administrat ive record,particularly the RI and the FS. In addition, the publicis to be afforded an opportunity for a public meeting.The proposed plan should include a brief explanationof the alternatives considered, which will usually be inthe form of a summary of the FS. Unlike the FS,however, the proposed plan will also provide anexplanation of the preliminary preference for one ofthe options. Notice of the final plan adopted and anexplanation of any significant changes from theproposed plan are also required. CERCLA also

2Remedial planning activities for the RI/FS and remedial designcontinue to be 100 percent federally funded.

authorizes technical assistance grants for localcitizens’ groups potentially affected by an NPL site.The grants are to be used in obtaining assistance ininterpreting information on the nature of hazardsposed by the site, the results of the RI/FS, anyremoval actions, the Record of Decision (ROD), andthe remedial design and remedial action.

1.3.5 Administrative Record

S e c t i o n 1 1 3 o f C E R C L A r e q u i r e s t h a t a nadministrative record be established “at or near thefacility at issue.” The record is to be compiledcontemporaneously and must be available to thepublic and include all information considered or reliedon in select ing the remedy, including publ iccomments on the proposed plan.

1.3.6 Worker SafetySection 126(c) of CERCLA directed the OccupationalSafety and Health Administration (OSHA) to issue,within 60 days of the date of enactment of SARA, aninterim final rule that contains employee protectionrequirements for workers engaged in hazardouswaste operations. OSHA’s interim final rule (29 CFR1910.120) was published in the Federal Register onDecember 19, 1986, with full implementation of thisrule required by March 16, 1987. The worker safetyrule will remain in effect until the final standard isissued by OSHA and becomes effective.

1.3.7 Enforcement Authorities

Section 122(e) authorizes EPA to use “specialnotice” procedures, which for an RI/FS, establishes a60-day moratorium period to provide time for formalnegotiation between EPA and the PRPs for conductof the RI/FS activities. This 60-day period may beextended to 90 days if within the 60-day time period,the potentially responsible parties (PRPs) provideEPA with a good faith offer to conduct or finance theRI/FS.

SARA allows for administrative consent orders to besigned using the authorities of Section 122(d)(3) aspertaining to Section 104(b) without having to make afinding of imminent and substantial endangerment.Section 104(a)(l) outlines special requirements for aPRP-lead RI/FS. These requirements include:making the determination that a PRP is qualified toperform the RI/FS; arranging for a third party to assistin oversight of the RI/FS; and requiring that PRPs payfor third party oversight.3

3Specific guidance on PRP participation in the RI/FS process isfound in Appendix A. Detailed guidance on PRP oversight iscurrently under preparation in the Office of Solid Waste andEmergency Response (OSWER).

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1.4 The RI/FS Process Under CERCLAAlthough the new provisions of CERCLA haveresulted in some modifications to the RI/FS process,the basic components of the process remain intact.The RI continues to serve as the mechanism forcollecting data to characterize site conditions;determine the nature of the waste; assess risk tohuman health and the environment; and conducttreatability testing as necessary to evaluate thepotential performance and cost of the treatmenttechnologies that are being considered. The latteralso supports the design of selected remedies. TheFS continues to serve as the mechanism for thedevelopment, screening, and detailed evaluation ofalternative remedial actions.

The various steps, or phases, of the RI/FS processand how they have been modified to comply with thenew provisions in CERCLA are summarized below. Itis important to note that the RI and FS are to beconducted concurrently and that data collected in theRI influence the development of remedial alternativesin the FS, which in turn affects the data needs andscope of treatability studies and additional fieldinvestigations. Two concepts are essential to thephased RI/FS approach. First, data should generallybe collected in several stages, with initial datacollection efforts usually limited to developing ageneral understanding of the site. As a basicunderstanding of site characteristics is achieved,subsequent data collection efforts focus on fillingidenti f ied gaps in the understanding of si techaracteristics and gathering information necessary toevaluate remedial alternatives. Second, this phasedsampling approach encourages identification of keydata needs as early in the process as possible toensure that data collection is always directed towardproviding information relevant to selection of aremedial action. In th is way the overa l l s i te

characterization effort can be continually scoped tominimize the collection of unnecessary data andmaximize data quality.

Because of the interactive and iterative nature of thisphase of the RI and FS process, the sequence of thevarious phases and associated act ivi t ies, asdescribed below and presented in Figure 1-1, willfrequently be less distinct in practice. A generictimeline intended to illustrate the phasing of RI/FSactivities is presented in Figure 1-2. The actualtiming of individual activities will depend on specificsite situations.

1.4.1 Scoping

Scoping is the initial planning phase of the RI/FSprocess, and many of the planning steps begun hereare continued and refined in later phases of theRI/FS. Scoping activities typically begin with thecollection of existing site data, including data from

previous investigations such as the preliminaryassessment and site investigation. On the basis ofthis information, site management planning isundertaken to preliminarily identify boundaries of thestudy area, identify likely remedial action objectivesand whether interim actions may be necessary orappropriate, and to establish whether the site maybest be remedied as one or several separateoperable units. Once an overall management strategyis agreed upon, the RI/FS for a specific project or thesite as a whole is planned. Typical scoping activitiesinclude:

Initiating the identification and discussion ofpotential ARARs with the support agency

Determining the types of decisions to be madeand identifying the data and other informationneeded to support those decisions

Assembling a “technical advisory committee” toassist in these activities, to serve as a reviewboard for important deliverables, and to monitorprogress, as appropriate, during the study

Preparing the work plan, the sampling andanalysis plan (SAP) (which consists of the qualityassurance project plan (QAPP) and the fieldsampling plan (FSP)), the health and safety plan,and the community relations plan

Chapter 2 describes the various steps in the scopingprocess and gives general information on work-planning methods that have been effective in planningand executing past RI/FSs.

1.4.2 Site CharacterizationDuring site characterization, field sampling andlaboratory analyses are initiated. Field samplingshould be phased4 so that the results of the initialsampling efforts can be used to refine plansdeveloped during scoping to better focus subsequentsampling efforts. Data quality objectives are revisedas appropriate based on an improved understandingof the site to facilitate a more efficient and accuratecharacterization of the site and, therefore, achievereductions in time and cost.

A preliminary site characterization summary isprepared to provide the lead agency with informationon the site early in the process before preparation ofthe full RI report. This summary will be useful indetermining the feasibility of potential technologiesand in assisting both the lead and support agencieswith the initial identification of ARARs. It can also be

4Emphasis is placed on rapid turnaround of sampling results toavoid the need to remobilize and reprocure contractors.

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Figure 1-1. Phased RI/FS Process.

sent to ATSDR to assist them in performing theirhealth assessment of the site.

A baseline risk assessment is developed to identifythe existing or potential risks that may be posed tohuman health and the environment by the site. Thisassessment also serves to support the evaluation ofthe no-action alternative by documenting the threatsposed by the site based on expected exposurescenarios. Because this assessment identifies theprimary health and environmental threats at the site, italso provides valuable input to the development andevaluation of alternatives during the FS. Sitecharacterization activities are described in Chapter 3.

1.4.3 Development and Screening ofAlternatives

The development of alternatives usually begins duringor soon after scoping, when likely response scenariosmay first be identified. The development ofalternatives requires (1) identifying remedial actionobjectives; (2) identifying potential treatment,resource recovery, and containment technologies thatwill satisfy these objectives; (3) screening the

technologies based on their effectiveness,implementability, and cost; and (4) assemblingtechnologies and their associated containment ordisposal requirements into alternatives for thecontaminated media at the site or for the operableunit. Alternatives can be developed to addresscontaminated medium (e.g., ground water), a specificarea of the site (e.g., a waste lagoon or contaminatedhot spots), or the entire site. Alternatives for specificmedia and site areas either can be carried throughthe FS process separately or combined intocomprehensive alternatives for the entire site. Theapproach is flexible to allow alternatives to becombined at various points in the process.

As practicable, a range of treatment alternatives,should be developed, varying primarily in the extent towhich they rely on long-term management ofresiduals and untreated wastes. The upper bound ofthe range would be an alternative that wouldeliminate, to the extent feasible, the need for anylong-term management (including monitoring) at thesite. The lower bound would consist of an alternativethat involves treatment as a principal element (i.e.,treatment is used to address the principal threats at

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the site), but some long-term management ofportions of the site that did not constitute “principalthreats” would be required. Between the upper andlower bounds of the treatment range, alternativesvarying in the type and degrees of treatment andassociated containment/ disposal requirements shouldbe included as appropriate. In addition, one or morecontainment option(s) involving little or no treatmentshould be developed as appropriate, and a no-actionalternative should always be developed.

Once potential alternatives have been developed, itmay be necessary to screen out certain options toreduce the number of alternatives that will beanalyzed in detail in order to minimize the resourcesdedicated to evaluating options that are lesspromising. The necessity of this screening effort willdepend on the number of alternatives initiallydeveloped, which will depend partially on thecomplexity of the site and/ or the number of available,suitable technologies. For situations in which it isnecessary to reduce the initial number of alternativesbefore beginning the detailed analysis, a range ofalternatives should be preserved, as practicable, sothat the decisionmaker can be presented with avariety of distinct, viable options from which tochoose. The screening process involves evaluatingalternatives with respect to their effectiveness,implementability, and cost. It is usually done on ageneral basis and with limited effort (relative to thedetailed analysis) because the information necessaryto fully evaluate the alternatives may not be completeat this point in the process. The development andscreening of alternatives is discussed in Chapter 4.

1.4.4 Treatability Investigations

Should existing site and/or treatment data beinsufficient to adequately evaluate alternatives,treatability tests may be necessary to evaluate aparticular technology on specific site wastes.Generally, treatability tests involve bench-scaletesting to gather information to assess the feasibilityof a technology. In a few situations, a pilot-scalestudy may be necessary to furnish performance dataand develop better cost estimates so that a detailedanalysis can be performed and a remedial action canbe selected. To conduct a pilot-scale test and keepthe RI/FS on schedule, it will usually be necessary toidentify and initiate the test at an early point in theprocess. Treatability investigations are described inChapter 5.

1.4.5 Detailed Analysis

Once sufficient data are available, alternatives areevaluated in detail with respect to nine evaluationcriteria that the Agency has developed to address thestatutory requirements and preferences of CERCLA.The alternatives are analyzed individually againsteach criterion and then compared against one

another to determine their respective strengths andweaknesses and to identify the key tradeoffs thatmust be balanced for that site. The results of thedetailed analysis are summarized and presented tothe decisionmaker so that an appropriate remedyconsistent with CERCLA can be selected. Thedetailed analysis of alternatives is described inChapter 6.

1.5 Special SitesThe use of treatment technologies and, therefore, thedevelopment of a complete range of options, may notbe practicable at some sites with large volumes oflow concentration wastes (e.g., large municipallandfills or mining sites). Remedies involvingtreatment at such si tes may be prohibi t ivelyexpensive or difficult to implement. Therefore, therange of alternatives initially developed may befocused primarily on various containment options.Although this guidance does not specifically state howall such sites should be addressed, factors arediscussed that can be used, as appropriate, to helpguide the development and evaluation of alternativeson a case-by-case basis.

1.6 Community RelationsCommunity relations is a useful and important aspectof the RI/FS process. Community relations activitiesserve to keep communities informed of the activitiesat the site and help the Agency anticipate andrespond to community concerns. A communityrelations plan is developed for a site as the work planfor the RI/FS is prepared. The community relationsplan is based on interviews with interested people inthe community and will provide the guidelines forfuture community relations activities at the site. At aminimum, the plan must provide for a site mailing list,a conveniently located place for access to all publicinformation about the site, an opportunity for a publicmeeting when the RI/FS report and proposed plan areissued, and a summary of public comments on theRI/FS report and proposed plan and the Agency’sresponse to those comments.

The specific community relations requirements foreach phase of the RI/FS are integrated throughoutthis guidance document since they are parallel to andsupport the technical activities. Each chapter of thisguidance has a section discussing communityrelations requirements appropriate to that specificphase of the RI/FS. Additional program requirementsare described in the draft of Community Relations inSuperfund: A Handbook (U.S. EPA, Interim, June1988).

1.7 Lead and Support AgencyThroughout this guidance the terms “lead agency”and “support agency” are used to reflect the fact that

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either EPA or a State or Federal facility can have thelead responsibility for conducting an RI/FS. Thesupport agency plays a review and concurrence roleand provides specific information as necessary to thelead agency (e.g., ARAR identification). The roles ofthe lead and support agencies in each phase of theRI/FS process are described at the end of eachchapter.

1.8 Remedial Project Manager Role andResponsibilities

The Remedial Project Manager’s (RPM’s) role inoverseeing an RI/FS involves, to a large extent,ensuring that the work progresses according to thepriorities and objectives established during sitemanagement and project planning. This role requiresplanning project scopes early and deriving costestimates for the specific tasks and activitiesdescribed in the Statement of Work (SOW).5 It is theRPM’s responsibility to develop realistic cost

est imates, m o n i t o r a n d c o n t r o l c o n t r a c t o rexpenditures, and manage changing site conditionswithin the allocated budget. The RPM facilitates theinteractions among EPA staff, State representatives,contractor personnel, PRPs, and the public to ensurethat all involved parties are aware of their roles andresponsibilities. Throughout the following chapters,and particularly in the discussions of scoping(Chapter 2) and site characterization (Chapter 3),suggestions are provided to guide the RPM indeveloping approaches for conducting RI/FSs so thathigh-quality deliverables are produced in a timelyand cost-effective manner. Additional suggestionsspecific to management of RI/FSs may be found inthe Superfund Federal-Lead Remedial ProjectManagement Handbook (U.S. EPA, December 1986)and Superfund State-Lead Remedial ProjectManagement Handbook (U.S. EPA, December 1986).Oversight responsibilities for PRP-lead RI/FSs areoutlined in Appendix A of this guidance.

5OSWER is developing cost estimating guides and a referencedocument for use by RPMs that will provide historical averagesfor the cost of the various RI/FS tasks.

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CHAPTER 2SCOPING OF THE RI/FS

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Chapter 2Scoping the RI/FS

2.1 Introduction

Scoping is the ini t ial planning phase of si teremediation and is begun, at least informally, by thelead agency’s RPM as part of the funding allocationand planning process. The lead and support agenciesshould meet and, on the basis of avai lableinformation, begin to (1) identify the types of actionsthat may be required to address site problems; (2)identify whether interim actions are necessary orappropriate to mitigate potential threats, preventfurther environmental degradation, or rapidly reducerisks significantly, and (3) identify the optimalsequence of site actions and investigative activities.

Once the lead and support agencies initially agree ona general approach for managing the site, the nextstep is to scope the project(s) and develop specificproject plans. Project planning is done to:

Determine the types of decisions to be made

Identify the type and quality of data qualityobjectives (DQOs) needed to support thosedecisions

Describe the methods by which the required datawill be obtained and analyzed

Prepare project plans to document methods andprocedures

The activities described above relate directly to theestablishment of DQOs - statements that specify thetype and quality of the data needed to supportdecisions regarding remedial response activities. Theestablishment of DQOs is discussed in detail in DataQualify Objectives for Remedial Response Activities(U.S. EPA, March 1987, hereafter referred to as theDQO Guidance).

The ability to adequately scope a specific project isclosely tied to the amount and quality of availableinformation. Therefore, it is important to note that thescope of the project and, to some extent the specificproject plans, are developed iteratively (i.e., as newinformation is acquired or new decisions are made,data requirements are reevaluated and, if appropriate,project plans are modified). In this way, scoping helps

to focus activities and streamline the RI/FS, therebypreventing needless expenditures and loss of time inunnecessary sampling and analyses.

Figure 2-l shows the key steps in the scopingprocess.1

2.2 Project PlanningOnce a general site management approach has beenagreed upon, planning can begin for the scope of aspecific project. The specific activities conductedduring project planning include:2

Meeting with lead agency, support agency, andcontractor personnel to discuss site issues andassign responsibilities for RI/FS activities

Collecting and analyzing existing data to developa conceptual site model that can be used toassess both the nature and the extent ofcontamination and to identify potential exposurepathways and potential human health and/orenvironmental receptors

Initiating limited field investigations if availabledata are inadequate to develop a conceptual sitemodel and adequately scope the project

Identifying preliminary remedial action objectivesand likely response actions for the specific project

Preliminarily identifying the ARARs expected toapply to site characterization and site remediationactivities

Determining data needs and the level of analyticaland sampling certainty required for additional data

1 See Appendix A for a delineation of responsibilities betweenthe lead agency and the PRPs during the scoping process.

2 For a PRP-lead RI/FS the PRPs are typically responsible forthese activities except for conducting community interviews.This responsibility rests with the lead agency. Specific activitiesperformed by the PRPs during scoping are determined duringthe negotiation period and should be specified in theagreement between the PRPs and the lead agency.

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Figure 2-1. Scoping.

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if currently available data are inadequate toconduct the FS

Identifying the need and the schedule fortreatability studies to better evaluate potentialremedial alternatives

Designing a data collection program to describethe selection of the sampling approaches andanalytical options. (This selection is documentedin the SAP, which consists of the FSP and QAPPelements.)

Developing a work plan that documents thescoping process and presents anticipated futuretasks

Identifying and documenting health and safetyprotocols required during field investigations andpreparing a site health and safety plan

Conducting community interviews to obtaininformation that can be used to develop a site-specific community relations plan that documentsthe objectives and approaches of the communityrelations program

2.2.1 Conduct Project Meeting

To begin project planning, a meeting should be heldinvolving key management from the lead and supportagencies. The purpose of this meeting is to allow keypersonnel to become involved in initial planningdecisions and give them the opportunity to discussany special concerns that may be associated with thesite. Furthermore, this meeting should set aprecedent for the involvement of key personnelperiodically throughout the project. Additionalattendees should include contractor personnel whowill be conducting the RI/FS and performing the riskassessment , N a t u r a l R e s o u r c e T r u s t e erepresentatives, when applicable, and individuals withpr io r exper ience a t the s i te [e .g . , the f ie ldinvestigation team (FIT)] or other similar sites whomay be able to provide additional insight into effectivetechniques for addressing potential site problems.

2.2.2 Collect and Analyze Existing DataBefore the activities necessary to conduct an RI/FScan be planned, it is important to compile theavailable data that have previously been collected fora site. These data can be used to determine theadditional work that needs to be conducted both inthe field and within the community. A thorough searchof existing data should help avoid duplication ofprevious efforts and lead to a remedial investigationthat is more focused and, therefore, more efficient inits expenditure of resources.

Information describing hazardous waste sources,migration pathways, and human and environmentalreceptors for a given site is available from manysources. Some of the more useful sources are listedin Table 2-1. Site investigation (SI) data3 gathered inthe hazard ranking process (the process by which asite is listed on the NPL) may be located in filesmaintained by the EPA Regional offices, the FIT, thetechnical assistance team (TAT), contractors, and thestate.

Data relating to the varieties and quantities ofhazardous wastes disposed of at the site should becompiled. The results from any previous samplingevents should be summarized in terms of physicaland chemical characteristics, contaminants identified,and their respective concentrations. Results ofenvironmental sampling at the site should besummarized, and evidence of soil, ground water,surface water, sediment, air, or biotic contaminationshould be documented. If available, information on theprecision and accuracy of the data should beincluded.

Records of disposal pract ices and operat ingprocedures a t the s i te , inc lud ing h is to r ica lphotographs, can be reviewed to identify locations ofwaste materials onsite, waste haulers, and wastegenerators. If specific waste records are absent,waste products that may have been disposed of atthe site can be identified through a review of themanufacturing processes of the waste generators.

A summary of existing site-specific and regionalinformation should be compiled to help identifysurface, subsurface, atmospheric, and biotic migrationpathways. Compiled information should includegeology, hydrogeology, hydrology, meteorology, andecology. Regional information can help to identifybackground soil, water, and air quality characteristics.Data on human and environmental receptors in thearea surrounding the site should be compiled.Demographic and land use information will helpidentify potential human receptors. Residential,municipal, or industrial wells should be located, andsur face water uses shou ld be iden t i f i ed fo rsurrounding areas and areas downstream of the site.

Existing information describing the common flora andfauna of the site and surrounding areas should beco l lec ted . The loca t ion o f any th rea tened ,endangered, or rare species, sensitive environmentalareas, or critical habitats on or near the site should beidentified. Available results from any previousbiological testing should be compiled to document

3 The expanded site investigation (ESI) conducted by the pre-remedial program will provide valuable data (e.g., geophysics,surveys, well inventories) and should serve as an importantsource of information during the scoping process forestablishing the hypotheses to be tested concerning the natureand extent of contamination.

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any known ecological effect such as acute or chronictoxicity or bioaccumulation in the food chain.

Once the available data have been collected, they areanalyzed to (1) establish the physical characteristicsof a site to help determine the scope of futuresampling efforts; and (2) conceptually model potentialexposure pathways and receptors to assist in thepreliminary assessment of risk and the initialidentification of potential remedial technologies. Eachof these uses is discussed below.

2.2.2.1 Establish Physical Characteristics of theSite

The analysis of existing data serves to’ provide abetter understanding of the nature and extent ofcontamination and aids in the design of remedialinvestigation tasks. If quality assurance information onexisting sampling data is available, it should bereviewed to assess the level of uncertainty associatedwith the data. This is important to establish whethersampl ing wi l l be needed to ver i fy or s implysupplement existing data. Important factors toconsider when reviewing existing data are thecomparability of the data (e.g., time of sampling), theanalytical methods, the detection limits, the analyticallaboratories, and the sample collection and handlingmethods.4

Existing data should be used to develop a sitedescription, which should include location, ownership,topography, geology, land use, waste type, estimatesof waste volume, and other pertinent details. The sitedescription should also include a chronology ofsignificant events such as chemical storage anddisposal practices, previous site visits, samplingevents, regulatory violations, legal actions, andchanges in ownership. In addition, informationconcerning previous cleanup actions, such asremoval of containerized waste, is often valuable fordetermining the characteristics of any wastes orcontaminated media remaining at the site. All sourcesof information or data should be summarized in atechnical memorandum or retained for inclusion in theRI report.

2.2.2.2 Develop a Conceptual Site Model

Information on the waste sources, pathways, andreceptors at a site is used to develop a conceptualunderstanding of the site to evaluate potential risks tohuman health and the environment. The conceptualsite model should include known and suspected

4 Regardless of the origin and quality of existing data,they typically are useful in constructing hypothesesconcerning the nature and extent of contamination.

sources of contamination, types of contaminants andaffected media, known and potential routes ofmigration, and known or potential human andenvironmental receptors. This effort, in addition toassisting in identifying locations where sampling isnecessary, will also assist in the identification ofpotential remedial technologies. Additional informationfor evaluating exposure concerns through the use ofa conceptual model is provided in the D Q OGuidance. An example of a conceptual model isprovided in Figure 2-2.

2.2.2.3 Determine the Need for and ImplementLimited Additional Studies

If the conceptual understanding of a site is poor andthe collection of site-specific data would greatlyenhance the scop ing e f fo r t , a l im i ted f ie ldinvestigation may be undertaken as an interimscoping task prior to developing the work plan.5

Normally, the investigation is limited to easily obtain-able data, where results can be achieved in a shorttime. Examples of tasks are as follows:

Preliminary geophysical investigations

Resident ial , industr ial , and agricul tural wel lsampling and analysis

Measurement of well-water level, sampling (onlyfor pre-existing monitoring wells), and analysis

Limited sampling to determine the need for wastetreatability studies

Air monitoring

Site mapping

Preliminary ecological reconnaissance

2.2.3 Develop Preliminary Remedial ActionAIternatives

Once the existing site information has been analyzedand a conceptual understanding of the site isobtained, potential remedial action objectives shouldbe identified for each contaminated medium (Chapter4 presents examples of remedial action objectives)and a preliminary range of remedial action alternativesand associated technologies should be identified. Thisident i f i ca t ion i s no t meant to be a de ta i ledinvestigation of alternatives. Rather, it is intended tobe a more general classification of potential remedialactions based upon the initially identified potentialroutes of exposure and associated receptors. Theidentification of potential technologies at this stage willhelp ensure that data needed to evaluate them (e.g.,

5 The specific procedures for initiating limited fieldinvestigation will be dependent on the lead agency’sadministrative and contractual requirements.

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Btu value of wastes to evaluate thermal destructioncapabilities) can be collected as early as possible. Inaddition, the early identification of technologies willallow earlier determinations as to the need fortreatability studies.

Technologies that may be appropriate for treating ordisposing of wastes should be identified along withsources o f l i t e ra tu re on the techno log ies ’effectiveness, applications, and cost. Furtherassistance in the investigation of technologies isprovided in the Technology Screening Guide forTreatment of CERCLA Soils and Sludges (U.S. EPA,September 1988). Innovative technologies andresource recovery options should be included if theyappear feasible.

To the extent practicable, a preliminary list of broadlydefined alternatives should be developed that reflectsthe goal of presenting a range of distinct, viableoptions to the decision-maker. This list wouldtherefore include as appropr iate a range ofalternatives in which treatment that significantlyreduces the toxicity, mobility, or volume of waste is aprincipal element; one or more alternatives thatinvolve containment with little or no treatment; and ano-action alternative. The list should be limited toonly those alternatives that are relevant and carrysome significant potential for being implemented atthe site. In this way, the preliminary identification ofremedial actions will allow an initial identification ofARARs and will help focus subsequent data-gathering efforts.

Involvement of the various agencies at this time willhelp in identifying remedial alternatives and scopingfield activities. The development of alternatives isdescribed in more detail in Chapter 4 of thisd o c u m e n t .

2.2.4 Evaluate the Need for Treatability Studies

If remedial actions involving treatment have beenidentified for a site, then the need for treatabilitystudies should be evaluated as early as possible inthe RI/FS process. This is because many treatabilitystudies, especially pilot testing, may take severalmonths or longer to complete. If a lengthy study isrequired and is not initiated early, completion of theFS may be delayed.

The initial activities of treatability testing includeresearching other potentially applicable data,designing the study, and procuring vendors andequipment. As appropriate, these activities shouldoccur concurrently with site characterization efforts sothat if it is determined that a potential technology isnot feasible, planned treatability activities for thistechnology can be terminated. Chapter 5 providesguidance on scoping treatability studies.

2.2.5 Begin Preliminary Identification ofARARs and To Be Considered (TX)Information

A preliminary identification of potential ARARs andTBC information in the scoping phase can assist ininitially identifying remedial alternatives and is usefulfor initiating communications with the support agencyto facilitate the identification of ARARs. Furthermore,early identification of potential ARARs will allow betterplanning of field activities.6 Because of the iterativenature of the RI/FS process, ARAR identificationcont inues th roughout the RI /FS as a be t te runderstanding is gained of site conditions, sitecontaminants, and remedial action alternatives.

ARARs may be categorized as chemical-specificrequirements that may define acceptable exposurelevels and therefore be used in establ ishingpreliminary remediation goals; as location-specificrequirements that may set restrictions on activitieswithin specific locations such as floodplains orwetlands; and as action-specific, which may setcontrols or restrictions for particular treatment anddisposal activities related to the management ofhazardous wastes. The document, “CERCLACompliance with Other Laws Manual” (U.S. EPA,Draft, May 1988) contains detailed information onidentifying and complying with ARARs.

Potential chemical- and location-specific ARARsare identified on the basis of the compilation andevaluation of existing site data. A preliminaryevaluation of potential action-specific ARARs mayalso be made to assess the feasibility of remedialtechnologies being considered at this time. In additionto federal ARARs, more stringent state ARARs mustalso be identified. Other federal and state criteria,advisories, and guidance and local ordinances shoulda lso be cons idered , as appropr ia te , in thedevelopment of remedial action alternatives.

For documentation purposes, a list should bemaintained of potential ARARs as they are identifiedfor a site. As the RI/FS progresses, each ARAR willneed to be defined. The assistance of the appropriatesupport agency should be sought in identifyingsupport agency ARARs and conf irming theirapplicability or relevance and appropriateness.

2.2.6 Identify Data Needs

The identification of data needs is the most importantpart of the scoping process. Data needs are identifiedby evaluating the existing data and determining whatadditional data are necessary to characterize the site,develop a better conceptual understanding of the site,

6 In addition, compliance with certain environmental statutes(e.g., the National Historic Preservation Act) is simplified byearly consultation with the responsible Federal agency.

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better define the ARARs, narrow the range ofremedial alternatives that have been identified, andsupport enforcement activities.

The need for additional site data is evaluated relativeto meeting the site-specific RI/FS objectives. Ingeneral, the RI/FS must obtain data to define sourceareas of contamination, the potential pathways ofmigration, and the potential receptors and associatedexposure pathways to the extent necessary to:

Determine whether, or to what extent, a threat tohuman health or the environment exists

Develop and evaluate remedial a l ternat ives(including the no-action alternative)

Support future enforcement or cost-recoveryactivities

If additional data are needed, the intended uses of thedata are identified, strategies for sampling andanalyses are developed, DQOs are established, andpriorities are assigned according to the importance ofthe data in meeting the objectives of the RI/FS.

The possible uses of the data include the following:

Monitoring during implementation

Health and safety planning

Site characterization

Risk assessment

Evaluating alternatives

Determining the PRP

Engineering the design of alternatives

A more complete description of the data uses andtheir appropriate analytical levels (Figure 2-3) can befound in the DQO Guidance.

Setting priorities for data use helps to determine thehighest level of confidence required for each type ofdata. For example, add i t iona l da ta on so i lcontamination may be necessary for all the useslisted above but may be of highest priority for riskassessment and evaluation alternatives. Within thesetwo use categories, the evaluation of alternatives mayrequire a much greater level of confidence in thecontaminant types and concentrations on site so thatcost estimates for treatment can be prepared to meetor approach the goal of a + 50 percent/-30 percentaccuracy level. As a result, data needs specifying thelevel of allowable uncertainty would be set for theevaluation of alternatives use category and wouldtherefore provide an acceptable level of confidencefor the remaining data uses.

Sensitivity analyses may be useful in evaluating theacceptable level of uncertainty in data. Criticalparameters in any of the use categories can be variedover a probable range of values that were identified inthe conceptual site model and that determine theeffect on meeting the RI/FS objectives. For example,preliminary treatment costs for contaminated soil canbe calculated for various contaminant types andvolumes. The sensitivity that contaminant volume andtype has on treatment cost can be assessed so thatsufficient site characterization data are collected toallow costing of treatment alternatives during the FSusing a goal of +50 percent/-30 percent costaccuracy.

In the development of data requirements, time andresource constraints must be balanced with thedesired confidence level of the data. The turnaroundtime necessary for certain analytical procedures may,in some cases, preclude achieving the original levelof confidence desired.

Likewise, resource constraints such as the availabilityof a laboratory, sampling and analysis equipment, andpersonnel may also influence the determination ofdata requirements. Because of the high cost ofsampling and analysis for contaminants on thehazardous substances list, data acquisition should befocused only on the data quality and quantitynecessary and sufficient to meet the RI/FS objectives.It is also important to do any necessary logisticalplanning once data needs are identified. For example,if it will be necessary to acquire aerial photographs toadequately evaluate a site, it should be noted early inthe process so that the acquisition can begin early.

2.2.7 Design a Data Collection Program

Once the level of confidence required for the data isestablished, strategies for sampling and analysis canbe developed. The ident i f icat ion of sampl ingrequirements involves specifying the sampling design;the sampling method; sample numbers, types, andlocations;. and the level of sampling quality control.Data may be collected in multiple sampling efforts touse resources efficiently, and the level of accuracymay increase as the focus of sampling is narrowed.The determination of analytical requirements involvesspecifying the most cost-effective analytical methodthat, together with the sampling methods, will meetthe overall data needs for the RI/FS. Data qualityrequirements specified for sampling and analysisinclude precision, accuracy, representativeness,completeness, and comparability.

A description of the methods to be used in analyzingdata obtained during the RI should be included in aSAP. The level of detail possible in defining the dataevaluation tasks will depend on the quality of the siteconceptual model. If the site is well understood, dataevaluation techniques should be specified and

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DATA USES ANALYTICAL LEVEL TYPE OF ANALYSIS

Figure 2-3. Summary of analytical levels appropriate to data uses.

described. This information is especially important if evaluation techniques could be included, and innumerical modeling is anticipated. If little existing addition to describing site characterization techniques,information is available, the task descriptions may be methods to be used in the risk assessment alsovery general, since it may not be clear which data should be described.evaluat ion techniques wi l l be appropriate. I finformation is lacking, descriptions of potential

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2.2.8 Develop a Work Plan

Tasks to be conducted during the RI/FS should beidentified and documented in a work plan. Althoughthis work plan will constitute the planning through thecompletion of the RI/FS, the level of detail with whichspecific tasks can be described during scoping willdepend on the amount and quality of existing data.Therefore, in situations in which additional data areneeded to adequately scope the development andevaluation of alternatives, emphasis should be placedon limiting the level of detail used to describe thesesubsequent tasks and simply noting that the scope ofthese activities will be refined later in the process.This will reduce the time needed to prepare andreview the initial work plan. As the RI/FS processprogresses and a better understanding of the site isgained, these task descriptions can be refined. Thepreliminary descriptions of tasks needed to completethe RI/FS should be documented in the work plan andcan be used as a basis for scheduling and estimatingthe RI/FS budget.

2.2.9 Identify Health and Safety Protocols

Protecting the health and safety of the investigativeteam and the general public is a major concern duringremedial response actions. Workers may be exposedto a variety of hazards including toxic chemicals,biological agents, radioactive materials, heat or otherphysical stresses, equipment-related accidents, andfires or explosions. The surrounding community maybe at increased risk from unanticipated chemicalreleases, fires, or explosions created by onsiteactivities. In recognition of these concerns, OSHA haspublished regulations that stress the importance bothof an underlying health and safety program and ofsite-specific safety planning. The following is a list ofdocuments that contain regulations pertaining toworkers at hazardous waste sites:

American National Standards, Practices forRespiratory Protection (American NationalStandards Institute, 1980)

Guidance Manual for Superfund Activities,Volumes l-9 (National Institute for OccupationalSafety and Health, 1985)

Occupational Health Guidelines for ChemicalHazards (National Institute for OccupationalSafety and Health, 1981)

Safety Manual for Hazardous Waste S i t eInvestigations (U. S. EPA, 1979)

Interim Standard Operating Safety Guides (U.S.EPA, 1982)

Occupational Safety and Health Guidance Manualf o r H a z a r d o u s W a s t e S i t e A c t i v i t i e s(NlOSH/OSHA/USCC/USEPA, 1985)

NIOSH/OSHA Pocket Guide to Chemical Hazards(National Institute for Occupational Safety andHealth, 1978)

National fire Codes (National Fire ProtectionAssociation, 1981)

2.2.10 Conduct Community Interviews

The community relations staff members, which canbe either lead agency or contractor personnel andtechnical staff, should work together during thescoping process so that there is sufficient informationto conduct community interviews. Communityrelations staff members then meet with the identifiedgroups or individuals to gain an understanding of thesite’s history and the community’s involvement withthe site from the community’s perspective. The leadagency will determine on a site-specific basis thetype and number of interviews that need to beconducted to obtain sufficient information to developan effective community relations plan. The results ofthe interviews should be made available to alltechnical staff members to assist in identifyingpotential waste types and disposal practices, potentialpathways of contamination, and potential receptors.On the basis of an understanding of the issues andconcerns of the community, the community relationshistory, and the citizens’ indicated preferences forhow they would like to be informed concerning siteactivities, the community relations plan is prepared.Plans should provide opportunities for public inputthroughout the remedial p lanning process asappropriate.

2.3 Deliverables and CommunicationThere are several points during the scoping processwhen communication is required between the leadagency and its contractor and/or the support agency(see Table 2-2). It is especially important thatdiscussion and information exchange occur if interimactions or limited field investigations are considerednecessary. For all RI/FSs, it is desirable for the leadand support agencies and their contractors to reviewexisting data and to agree on the major tasks to beconducted at a site. Specific guidance for the timingand nature of communications between the lead andsupport agencies is provided in the “SuperfundM e m o r a n d u m o f A g r e e m e n t G u i d a n c e ” ( i npreparation).

Deliverables required for all RI/FSs in which fieldinvestigations are planned consist of a work plan, anSAP, a health and safety plan (HSP), and acommunity relations plan (CRP). Although these plansusually are submitted together, each plan may bedelivered separately. Each of these plans is describedbelow.

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2.3.1 Work Plan

2.3.1.1 Purpose

The work plan documents the decision and evaluationmade during the scoping process and presentsanticipated future tasks. It also serves as a valuabletool for assigning responsibilities and setting theproject’s schedule and cost. Information on planningwork for lead agency staff may be found in theSuper fund Federa l -Lead Remed ia l P ro jec tManagement Handbook (U.S. EPA, December 1986);and the Superfund State-Lead Remedial ProjectManagement Handbook (U.S. EPA, December 1986).The primary user of the RI/FS work plan is the leadagency for the site (usually either the EPA Region orthe appropriate federal or state agency) and theproject team that will execute the work. Secondaryusers of the work plan include other groups oragencies serving in a review capacity, such as EPAHeadquarters and local government agencies. Thework plan is usually made available for publiccomment (often in conjunction with a public meeting)and is placed in the Administrative Record.

2.3.1.2 PreparationThe work plan presents the initial evaluation ofexisting data and background information performedduring the scoping process, including the following:

An analysis and summary of the site backgroundand the physical setting

An analysis and summary of previous responses

Presentation of the conceptual site model,including an analysis and summary of the natureand extent of contaminat ion; prel iminaryassessment of human health and environmentalimpacts; and the additional data needed toconduct the baseline risk assessment

Preliminary identification of general responseactions and alternatives and the data needed forthe evaluation of alternatives

The work plan also defines the scope and objectivesof RI/FS activities to the extent possible. The scopeof the RI site characterization should be documentedin the work plan, with detailed descriptions provided inthe SAP. Later tasks will usually be scoped in lessdetail, pending the acquisition of more complete dataabout the site.

The initial work plan is prepared prior to the RI sitecharacterization. 7 Because the RI/FS process is

7 In enforcement cases, PRPs are typically responsible for thedevelopment of the work plan (See Appendix A).

dynamic and iterative, the work plan or supplementalplans, such as the QAPP and the FSP, can bemodified during the RI/FS process to incorporate newinformation and refined project objectives. The workplan should be revised, if necessary, before (1)additional iterations of site characterization activities,and (2) treatability investigations. On federal-leadsites, a work plan revision request (WPRR) issubmitted for approval of any significant changes tothe budget schedule, or scope. EPA has foundtechnical directive memorandums (TDMs) to beuseful for decreasing administrative time when theproposed work plan changes do not affect the totalbudget or schedule.

2.3.1.3 Work Plan ElementsFive elements (Introduction, Site Background andPhysical Setting, Initial Evaluation, Work PlanRationale, and RI/FS Tasks) typically are included in awork plan. These elements are described in AppendixB.

Among the e lements to be inc luded i s thespecification of RI/FS tasks. For federal-lead sites,14 standard tasks have been defined to provideconsistent reporting and allow more effectivemonitoring of RI/FS projects. Figure 2-4 showsthese tasks and their relationship to the phases of anRI/FS, and detailed task definitions are included inAppendix B. Although RI/FSs that are not federal-lead projects are not required to use these standardtasks, their use provides a valuable projectmanagement tool that allows for compilation ofhistorical cost and schedule data to help estimatethese tasks during project planning and management.

Project Management Considerat ions. Projectmanagement considerations may be specified in thework plan to define relationships and responsibilitiesfor selected task and project management items. Thisspecification is particularly useful when the leadagency is using extensive contractor assistance. Thefollowing project management considerations may bediscussed in the work plan:

Identification of staff (the lead agency’s RPM, thePRP’s project manager, the contractor, thecontractor’s site manager, and other teammembers)

Coordination among the lead agency, the supportagency, the PRPs and the contractors performingthe work

Coordination with other agencies (Typically, thelead agency ’s RPM is the focus fo r thecoordination of all other agency and privateparticipation in site activities and decisions.)

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Table 2-2. Communication and Deliverables During Scoping

Potential MethodsInformation Needed Purpose of Information Exchange

Interim actions (if necessary) For lead agency and contractor to identify actions that will Meetingabate immediate threat to public health or prevent further Tech Memodegradation of the environment; to obtain concurrence of Othersupport agency

Limited field investigations (if necessary) For lead agency and contractor to improve focus of RI and Meetingreduce time and cost; to obtain concurrence of support Tech Memoagency Other

Summary of existing data; field studies For lead agency and contractor to confirm need for field Meetingconducted prior to FS; identification of studies; for lead agency and contractor to plan data Tech Memopreliminary remedial action alternatives collection; to obtain support agency review and Other

concurrence

Documentation of quality assurance (QA) and For contractor to obtain lead agency review and approval; SAP (FSP,QAPP)field sampling procedures for lead agency to obtain support agency review and

comment

Documentation of health and safety procedures For contractor to obtain lead agency agreement that Health and safety planOSHA safety requirements are met

Documentation of all RI/FS tasks For contractor to obtain lead agency review and approval; Work planfor lead agency to obtain support agency concurrence

Coordination of subcontractors, if any, anddescription of health and safety requirements andresponsibilities

Interface for federal-lead projects with theContract Laboratory Program (CLP), if needed, tominimize sampling requirements by use of fieldscreening, to schedule analyses well ahead ofsampling trips, and to accurately complete CLPpaperwork

Cos t con t ro l ( inc lud ing a descr ip t ion o fprocedures for contractors to report expenditures)

Schedule control (including a description ofschedule tracking methods and procedures forcontractors to report activities to the lead agency)

Identification of potential problems so that theRPM and site manager can develop contingencyplans for resolution of problems during the RI/FS

Evidentiary considerations, if needed, to ensurethat project staff members are trained with regardto requirements for admissibility of the work incourt

Cost and Key Assumptions. For federal-lead sites,the RI/FS work plan includes a detailed summary ofprojected labor and expense costs,8 broken down bythe 14 tasks listed in Figure 2-3 and described inAppendix B, and a description of the key assumptionsrequired to make such a cost estimate. During

8The estimated RI/FS costs prepared by the RPM during thescoping process will form the basis for evaluating costs proposedby the contractor in the work plan and should help facilitate thecontrol of project costs as the RI/FS proceeds. Cost estimatesmay not be required for State- and PRP-lead RI/FSs.

scoping, more detailed costs typically are provided forthe RI site characterization tasks than for later phasesof the RI/FS. The less-detailed costs may be refinedas field investigations progress and the nature andextent of site contamination is more fully understood.

RI/FS costs vary greatly among sites and areinfluenced by the following:

The adequacy of existing data

The size and complexity of the site

The level of personnel protection required foronsite workers

The number and depth of wells required and thetypes of subsurface conditions where wells will beinstalled

The number and types of media sampled

The number of samples required for eachmedium

The need for support of enforcement activities

The need for bench- or pilot-scale tests

Schedule. The anticipated schedule for the RI/FS isformulated on the basis of the scope of the project,including the identification of key activities anddeliverable dates. As with cost, the scheduling oftasks varies among sites.

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2.3.1.4 Report Format

The work plan should include the elements describedin Appendix B. Table 2-3 provides a suggestedformat.

Table 2-3. Suggested RI/FS Work Plan Format

Executive Summary

1. Introduction

2. Site Background and Setting

3. Initial Evaluation

Types and volumes of waste present Potential pathways of contaminant migration/preliminary

public health and environmental impacts Preliminary identification of operable units

Preliminary identification of response objectives andremedial action alternatives

4. Work Plan Rationale

DQO needs Work plan approach

5. RI/FS Tasks

6. Costs and Key Assumptions

7. Schedule

8. Project Management

Staffing

Coordination

9. References

Appendices

2.3.2 Sampling and Analysis Plan (SAP)

2.3.2.1 PurposeThe SAP consists of two parts: (1) a qualityassurance project plan (QAPP) that describes thepolicy, organization, functional activities, and qualityassurance and quality control protocols necessary toachieve DQOs dictated by the intended use of thedata; and (2) the field sampling plan (FSP) thatprovides guidance for all fieldwork by defining in detailthe sampling and data-gathering methods to beused on a project. The FSP should be written so thata field sampling team unfamiliar with the site would beable to gather the samples and field informationrequired. Guidance for the selection and definition offield methods, sampling procedures, and custody canbe acquired from the Compendium of Superfund FieldOperations Methods, which is a compilation ofdemonstrated field techniques that have been usedduring remedial response activities at hazardouswaste sites (U.S. EPA, September 1987, hereafterreferred to as the Compendium). To the extentpossible, procedures from this Compendium shouldbe incorporated by reference. In addition, the FSPand QAPP should be submitted as a single document(although they may be bound separately to facilitateuse of the FSP in the field). These efforts will

streamline preparation of the document and reducethe time required for review.

The purpose of the SAP is to ensure that samplingdata collection activities will be comparable to andcompatible with previous data collection activitiesperformed at the site while providing a mechanism forplanning and approving field activities. The plan alsoserves as a basis for estimating costs of field effortsfor inclusion in the work plan.

2.3.2.2 Plan Preparation and Responsibilities

Timing. A SAP is prepared for all field activities. Initialpreparation takes place before any field activitiesbegin, but the SAP may be amended or revisedseveral times during the RI site characterization,treatability investigations, or during the FS as theneed for field activities is reassessed and rescoped.

Preparation and Review. EPA, the states, PRPs, orthe contractors conducting the work should prepareS A PS for all field activities performed. The leadagency’s project officer must approve the SAP.Signatures on the title page of the plan usually showcompletion of reviews and approvals. Environmentalsampling should not be initiated until the SAP hasreceived the necessary approvals.9 A suggestedformat for a SAP is listed in Table 2-4.

2.3.2.3 Field Sampling Plan Elements

The FSP consists of the six elements contained inTable 2-4. These elements are described more fullyin Appendix B.

2.3.2.4 Quality Assurance Project Plan Elements

The QAPP should contain 14 elements. Theseelements are listed in Table 2-4 and described inAppendix B. The required information for each of theelements of a QAPP need not be generated eachtime a QAPP is prepared. Only those aspects of aQAPP that are specific to the site being investigatedneed to be explicitly described. If site-specificinformation is already contained in another document(e.g., the FSP) it need only be referenced. Similarly,any information contained in guidance documentssuch as the D Q O G u i d a n c e shou ld on ly bereferenced and not repeated in the QAPP.

2.3.3 Health and Safety Plan

2.3.3.1 Purpose

Each remedial response plan will vary as to degree ofplanning, special training, supervision, and protectiveequipment needed. The health and safety plan

9 Approval to conduct limited sampling (see Section 2.2.2.3)may be given as part of the interim authorization to prepare thework plans.

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Table 2-4. Suggested Format for SAP (FSP and QAPP)

FSP

1. Site Background

2. Sampling Objectives

3 Sample Location and Frequency

4. Sample Designation

5. Sampling Equipment and Procedures

6. Sample Handling and Analysis

QAPP

Title Page

Table of Contents

1. Project Description

2. Project Organization and Responsibilities

3. QA Objectives for Measurement

4. Sampling Procedures

6. Sample Custody

6. Calibration Procedures

7. Analytical Procedures

6. Data Reduction, Validation, and Reporting

9. Internal Quality Control

10. Performance and Systems Audits

11. Preventative Maintenance

12. Data Assessment Procedures

13. Correctwe Actions

14. Quality Assurance Reports

prepared to support the field effort must conform tothe firm’s or agency’s health and safety programwhich must be in compliance with OSHA.

The site health and safety plan should be preparedconcurrently with the SAP to identify potentialproblems early, such as the availability of adequatelytrained personnel and equipment. OSHA requires thatthe plan include maps and a detailed site description,results of previous sampling activities, and fieldreports. The plan preparer should review siteinformation, along with proposed activities, and useprofessional judgment to identify potentially hazardousoperations and exposures and prescribe appropriateprotective measures. Appendix B of the OccupationalSafety and Health Guidance Manual for HazardousWaste Site Activities (NlOSH/OSHA/USCG/USEPA,

1985) provides an example of a generic format for asite health and safety plan that could be tailored tothe needs of a specific employer or site.

2.3.3.2 Elements of the Health and Safety Plan

Each site health and safety plan should include, at aminimum, the 11 elements described in Appendix Bof this guidance. The specific information required ina site health and safety plan is listed in 29 CFR1910.120.

2.3.3.3 Site Briefings and Inspections

The OSHA regulation requires that safety briefings beheld “prior to initiating any site activity and at suchother times as necessary to ensure that employeesare apprised of the site safety plan and that it is beingfollowed.”

The final component of site health and safetyplanning or informational programs is site auditing toevaluate compliance with and effectiveness of the sitehealth and safety plan. The site health and safetyofficer or that person’s designee should carry out theinspections.

2.3.4 Community Relations Plan

2.3.4.1 Purpose

The CRP documents the community relations historyand the issues of community concern. It shoulddescribe the techniques that will be needed toachieve the objectives of the program. The plan isused by community relations staff, but it should alsobe used by federal and state agency technical staffmembers when planning technical work at the site.

2.3.4.2 Community Relations Plan Elements

Report preparation methods, the elements containedin a CRP, and a recommended format are included inCommunity Relations in Superfund: A Handbook (U.S.EPA, Interim, June 1988). This handbook alsoincludes useful examples of community relationsplans.

2 - 17

CHAPTER 3SITE CHARACTERIZATION

3 - 1

Chapter 3Site Characterization

3.1 Introduction

During site characterization, the sampling andanalysis plan (SAP), developed during projectplanning, is implemented and field data are collectedand analyzed to determine to what extent a site posesa threat to human health or the environment. Themajor components of site characterization arepresented in Figure 3-1 and include:

Conducting field investigations as appropriate

Analyzing field samples in the laboratory

Evaluating results of data analysis to characterizethe site and develop a baseline risk assessment

Determining if data are sufficient for developingand evaluating potential remedial alternatives

Because information on a site can be limited prior toconducting an RI, it may be desirable to conduct twoor more iterative field investigations so that samplingefforts can be better focused. Therefore, rescopingmay occur at several points in the RI/FS process.During site characterization, rescoping and additionalsampling may occur if the results of field screening orlaboratory analyses show that site conditions aresignificantly different than originally believed. Inaddition, once the analytical results of samples havebeen received (either from a laboratory or a mobilelab) and the data evaluated, it must be decidedwhether further sampling is needed to assess siterisks and support the evaluation of potential remedialalternatives in the FS. At this time, it is usuallyapparent whether the data needs identified duringproject planning were adequate and whether thoseneeds were satisfied by the first round of fieldsampling. As discussed in Chapter 4, there are alsopoints during the FS when the need for additional fieldstudies may be identified. These additional studies, ifneeded, can be conducted during subsequent sitecharacterization activities.

This chapter provides detailed descriptions of thoseactivities that may be required during the RI sitecharacterization. As discussed earlier, the complexityand extent of potential risks posed by Superfund sitesis highly variable. Therefore, the lead and support

agencies will have to decide on a site-specific basiswhich of the activities described in this chapter mustbe conducted to adequately characterize theproblem(s) and help in the evaluation of remedialalternatives.

3.2 Field Investigation MethodsField investigation methods used in Rls are selectedto meet the data needs established in the scopingprocess and outlined in the work plan and SAP. Thissection provides an overview of the type of sitecharacterization data that may be required and theinvestigative methods used in obtaining these data.The following sections describe methods for (1)implementing field activities, (2) investigating sitephysical characteristics, (3) defining the sources ofcontamination, and (4) evaluating the nature andextent of contamination. Specific information on thefield investigation methods described below iscontained in the Compendium. Sections of theCompendium that apply to particular types of fieldinvestigations are shown in Table 3-1.

3.2.1 Implement Field Activities

In addition to developing the SAP, fieldwork supportactivities, such as the following, are often necessarybefore beginning fieldwork:

Assure that access to the site and any otherareas to be investigated has been obtained

P r o c u r e s u b c o n t r a c t o r s s u c h a s d r i l l e r s ,excavators, surveyors, and geophysicists

P r o c u r e e q u i p m e n t ( p e r s o n a l p r o t e c t i v eensembles, air monitoring devices, samplingequipment, decontamination apparatus) andsupplies (disposables, tape, notebook, etc.)

Coordinate with analytical laboratories, includingsample scheduling, sample bottle acquisitionreporting, cha in -o f -cus tody records , andprocurement of close support laboratories orother in-field analytical capabilities

Procure onsite facilities for office and laboratoryspace, decontamination equipment, and vehicle

3 - 3

Figure 3-1. Major components of site characterization.

maintenance and repair, and sample storage, as Provide for storage or disposal of contaminatedwell as onsite water, electric, telephone, and material (e.g., decontamination solutions,sanitary utilities disposable equipment, drilling muds and cuttings,

3 - 4

Table 3-1. Relationship Among Site Characterization Tasksand the Compendium

Applicable Sections andSubsections of the Compendiumof Superfund Field Operations

Tasks MethodsField Investigation 7, 11, 15

Air

Biota1 12

Close support laboratories 5.2, 7, 15

RI-derived waste disposal 3.2, 5.2.6.4, 8.1.6.3

Soil gas

Support 3, 17, 16, 19, 20

Well logging 8.1, 8.3

Mapping and survey 14

Geophysical 8.4

Well installation 8.1, 8.5

Ground water 8.5

Soil 8.1, 8.2, 8.3

Source testing 7, 13, 15

Surface water 10

Sample analysis

Fieldwork, close support 5.2, 15laboratoryData validations 16

Sample management 4, 5, 6

Data evaluation 16

1 OSWER is currently developing a Superfund environmentalevaluation manual that will provide guidance for conductingecological investigations.

well-development fluids, well-purging water,and spill-contaminated materials)

Since procurement activities can take up to severalmonths, they should be initiated as early as possibleso as not to affect the overall RI/FS schedule.Schedule impacts should also be avoided bystructuring contracts, where possible, such that thereis no need to reprocure services for subsequent sitecharacterization activities. This may be accomplishedusing contract options that are exercised only in theevent that additional services or facilities are required(e.g., basic ordering agreements for well drilling).

Mobile labs or labs located near the site can oftenreduce the time necessary for completing RIactivities. If such quick-turnaround analysis isavailable, it can be used to determine the location andtype of subsequent sampling that must take place tomore completely characterize the site. This may alsoalleviate the need to reprocure subcontractors, andsignificantly accelerate the completion of the RI. Ifsuch analytical techniques are to be employed, the

work plan and SAP should allow for decisions onsubsequent activities to be made in the field with oralapproval from key management personnel.

3.2.2 Investigate Site Physical Characteristics

Data on the physical characteristics of the site andsurrounding areas should be collected to the extentnecessary to define potential transport pathways andreceptor populations and to provide sufficientengineering data for development and screening ofremedial action alternatives. Information normallyneeded can be categorized as surface features(including natural and artificial features), geology,soils, surface water hydrology, hydrogeology,meteorology, human populations, land use(s) andecology.

3.2.2.1 Surface Features

Surface features may include facility dimensions andlocations (buildings, tanks, piping, etc.), surfacedisposal areas, fencing, property lines and utility lines,roadways and railways, drainage ditches, leachatesprings, sur face-water bod ies , vegeta t ion ,topography, residences, and commercial buildings.Features such as these are usually identified forpossible contaminant migration and the location ofpotentially affected receptors. Investigation of surfacefeatures should not be limited to those that are onsite,but should include significant offsite features as well.Other facilities in the area that are potentialcontr ibutors to contaminat ion should also beidentified.

A history of surface features at the site can bedeveloped from existing data. As discussed inChapter 2 , the da ta may inc lude h is to r i ca lphotographs, past topographic surveys, operationalrecords, and information obtained during interviewswith owners, operators, local residents, and localregulatory agencies. Review of historical photographsis sometimes the most valuable of these methods.Aerial photographs are often available from suchsources as the Environmental Monitoring SupportLaboratory, Las Vegas (EMSL-LV), the Envi-ronmental Photographic Interpretation Center (EPIC),and the Soil Conservation Service of the U.S.Department of Agriculture.

Existing surface features may be described usingaerial photography, surveying and mapping, and siteinspection. Inspection of the site and the surroundingareas is normally augmented with photographs.Section 14 of the Compendium presents additionaldetails on land surveying, aerial photography, andmapping.

3 - 5

3.2.2.2 Geology

Geology may control or affect the following aspects ofa site:

The depths, locations, and extents of water-bearing units or aquifers

The release of contaminants and their subsequentmovement

The eng ineer ing geo log ic aspec ts o f s i teexploration and remediation

The investigation of site geology should be tailored toensure the identification of those features that willaffect the fate and transport of contaminants. Forexample, an understanding of site geology is lessimportant at a site at which release of contaminantsoccurs by volatilization to the atmosphere than at asite at which contaminants are moving toward thewater table.

To understand the geology of a site, one mustd e t e r m i n e t h e g e o l o g y o f b e d r o c k a n d o funconsolidated overburden and soil deposits. Table3-2 summarizes specific information on overburdenand bedrock geology that may be needed. Thedegrees to which overburden and bedrock geologymust be understood depend on the geologiccharacter of the site area, as well as the physicalcharacteristics of the site itself. An understanding ofregional geologic character ist ics is useful indetermining which aspect of site geology may havethe greatest influence on the fate and transport ofcontaminants and the use of potential remedialtechnologies.

In general, an investigation of site geology shouldinclude the following steps:

Determination of regional geology from availableinformation

Reconnaissance mapping of the area, which mayinclude geophysical investigations onsite

Subsurface explorations

The degree to which these steps are undertaken willbe determined by the degree to which the need toevaluate geologic aspects of the site dictates theinvest iga t ions needed in the RI /FS. Theseinvestigation methods are described in detail inSection 8 of the Compendium and summarized inTable 3-2.

3.2.2.3 Soils and the Vadose Zone

Properties of surface soils and the vadose zoneinfluence the type and rate of contaminant movementto the subsurface and subsequently to the water

table. Contaminants that can move through thesurface soil and into the vadose zone may movedirectly to the water table or they may be partially orfully retained within the vadose zone to act ascontinual sources of ground-water contamination.Engineering, physical, and chemical properties of soiland vadose zone materials can be measured in thefield or in the laboratory. Table 3-3 summarizest y p i c a l m e t h o d s f o r s o i l a n d v a d o s e z o n einvestigations.

3.2.2.4 Surface-Water Hydrology

Surface-water features may include erosion patternsand surface-water bodies such as ditches, streams,ponds, and lakes. The transport of contaminants insurface-water bodies is largely controlled by flow,which in streams is a function of the gradient,geometry, and coefficient of friction. A description ofhow flow is measured can be found in Section 10 ofthe Compendium. Contaminants have three possiblemodes of transport: (1) sorption onto the sedimentcarried by the flow, (2) transport as suspended solid,and (3) transport as a solute (dissolved). Thetransport of dissolved contaminants, which move thefastest, can be determined by characterizing the flowof the surface water and the contaminant dispersion.Sediment and suspended solid transport involve otherprocesses such as deposition and resuspension.Table 3-4 presents the surface-water informationthat may be required for characterizing sites.

If potential pathways include surface water, necessarydata about impoundments may include (1) physicaldimensions such as depth, area, and volume; (2)residence time; and (3) current direction and rates.As with impoundments, the direction and velocity oflake currents are often highly variable and, as aresult, are difficult to measure and accurately predict.Site mapping will provide much of this information.Measurement techniques (which are specified inSection 10, Surface Hydrology, of the Compendium)include the use of current meters and droguetracking.

3.2.2.5 HydrogeologyDeterminat ion of s i te hydrogeology involvesidenti fy ing geologic characterist ics, hydraul icproperties, and ground-water use, as defined inTables 3-5 and 3-6 and described in Section 8 ofthe Compendium. The determination of site geologyand hydrogeology can often be incorporated into asingle investigative program. Regional hydrogeologiccond i t ions can be de te rmined f rom ex is t inginformation; site-specific hydrogeologic conditionscan be determined using subsurface explorations,well installations, and field testing of hydraulicproperties. Table 3-7 summarizes the typical data

3 - 6

Table 3-2. Summary of Site Geology InformationInformation Needed Purpose of Rationale

collected and available analytical methodologies usedduring a hydrogeologic investigation.

3.2.2.6 Meteorology

Meteorological data are often required to characterizethe atmospheric transport of contaminants for riskassessment determinations and provide real-timem o n i t o r i n g f o r h e a l t h a n d s a f e t y i s s u e s .Representative offsite and site-specific data may beobtained using sampling methods outlined in Section11, “ M e t e o r o l o g y a n d A i r Q u a l i t y , ” o f t h eCompendium. This publication also discusses datarequirements for using refined air quality modelingand applicable models. Table 3-8 summarizesatmospheric investigations.

3.2.2.7 Human Populations and Land UseInformat ion should be col lected to ident i fy,enumerate, and characterize human populationspotentially exposed to contaminants released from asite. For a potentially exposed population, informationshould be collected on population size and location.Special consideration may be given to identifyingpotentially sensitive subpopulations (e.g., pregnant

women, infants) to better facilitate the characterizationof risks posed by contaminants exhibiting specificeffects (e.g., mutagens, teratogens). Census andother survey data may be used to identify anddescribe the population potentially exposed tocontaminated media. Information may also beavailable from U.S. Geological Survey maps, land useplans, zoning maps, and regional planning authorities.

Data describing the type and extent of human contactwith contaminated media also are needed,1 including:

Location and use of surface waters- Drinking water intakes and distribution

- Recreational (swimming, fishing) areas

- Connection between surface-water bodies

Local use of ground water as a drinking-watersource

- Number and location of wells

1 In some situations, information may be available from theATSDR if they previously have conducted health consultations.

3 - 7

Table 3-5. Aspects of Site Hydrogeology

Geologic aspects

- Type of water-bearing unit or aquifer (overburden,bedrock)

- Thickness, areal extent of water-bearing units andaquifers

- Type of porosity (primary, such as intergranular pore space,or secondary, such as bedrock discontinuities or solutioncavities)

- Presence or absence of impermeable units or confininglayers

- Depths to water table; thickness of vadose zone

Hydraulic aspects

- Hydraulic properties of water-bearing unit or aquifer(hydraulic conductivity, transmissivity, storativity, porosity,dispersivity)

- Pressure conditions (confined, unconfined, leaky confined)

- Ground-water flow directions (hydraulic gradients, bothhorizontal and vertical), volumes (specific discharge), rate(average linear velocity)

- Recharge and discharge areas

- Ground-water or surface water interactions; areas ofground-water discharge to surface water

- Seasonal variations of ground-water conditions

Ground-water use aspects- Identify existing or potential aquifers

- Determine existing near-site use of ground water

Table 3-6. Features of Ground-Water Systems

Components of Ground-Water Systems

- Unconfined aquifers

- Confining beds

- Confined aquifers

- Presence and arrangement of components

Water-bearing openings of the dominant aquifer

- Primary openings

- Secondary openings

Storage and transmission characteristics of the dominant aquifer

- Porosity

- Transmissivity

Recharge and discharge conditions of the dominant aquifer

Human use or access to the site and adjacentareas

- Residential

- Commercial

- Recreational use

Location of population with respect to site

- Proximity

- Prevailing wind direction

Information on expected land use, as well as currentland use, is desirable. Available population growthprojections, land use plans, and zoning maps canhelp develop expected exposure scenarios. Thisinformation may be obtained from zoning boards, thecensus bureau, regional planning agencies, and otherlocal governmental entities.

3.2.2.8 Ecological Investigations

Biological and ecological information collected for usein the baseline risk assessment aids in the evaluationof impacts to the environment and also helps toident i f y po ten t ia l e f fec ts w i th regard to theimplementation of remedial actions. The informationshould include a general identification of the flora andfauna associated in and around the site with particulare m p h a s i s p l a c e d o n i d e n t i f y i n g s e n s i t i v eenvironments, especially endangered species andtheir habitats and those species consumed byhumans or found in human food chains. Examples ofsensitive environments include wetlands, flood plains,wildlife breeding areas, wildlife refuges, and speciallydesignated areas such as wild and scenic rivers orparks.

Depending on the specific circumstances, data maybe needed for species that have key ecologicalfunctions in particular ecosystems, such as primary orsecondary producers, decomposers, scavengers,predators, or species that occupy key positions in thef o o d c h a i n s o f h u m a n s o r o t h e r s p e c i e s .Bioaccumulation data on food chain organisms, suchas aquatic invertebrates and fish, may be particularlyimportant to both environmental risk and human riskassessment. 2 Data gathered through biologicalassessment techniques (e.g., bioassays and/or fieldmonitoring) may be useful in situations where thereare complex mixtures, incomplete toxicity information,and/or unidentified or unmeasured compounds. TheNatural Resources Trustees for the site should becontacted to determine if other ecological data areavailable that may be relevant to the investigation. Asummary of environmental information that may beneeded and potential collection methods is providedin Table 3-9.

Prudent judgment on the part of the site managers isrequired to ensure that only relevant data that will aidin evaluating potential ecological risk and/or potentialremedial actions are collected. Because human healthrisks may be more substantial than ecological risks,and the mitigative actions taken to alleviate risks tohuman health are often sufficient to mitigate potentialecological risks as well, extensive ecologicalinvestigations may not be required for many sites.

2 Ecological Information collected to aid in the assessment of riskto humans exposed through food chain contamination shouldbe used in accordance with the Superfund Public HealthEvaluation Manual (U.S. EPA, October 1986).

3 - 1 0

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The use of a review committee comprised ofindividuals experienced in conducting ecologicalinvestigations is encouraged to provide design,planning, and oversight for these investigations and tofollow through to the selection of an environmentallysound remedy. Section 12 of the Compendiumaddresses environmental information that may beneeded and potential collection methods.

3.2.3 Define Sources of ContaminationSources of contamination are often hazardoussubstances contained in drums, tanks, surfaceimpoundments, waste piles, and landfills. In apractical sense, heavily contaminated media (such ass o i l s ) m a y a l s o b e c o n s i d e r e d s o u r c e s o fcontamination, especially if the original source (suchas a leaking tank) is no longer present on the site oris no longer releasing contaminants.

Source characterization involves the collection of datadescribing (1) facility characteristics that help toidentify the source location, potential releases, andengineering characteristics that are important in theevaluation of remedial actions; (2) the wastecharacteristics, such as the type and quantity ofcontaminants that may be contained in or released tothe environment; and (3) the physical or chemicalcharacteristics of hazardous wastes present in thesource. Key source characterization data aresummarized in Table 3-10.

The location and type of existing containment shouldbe determined for all known sources. In addition,where the hazardous subs tance remains incontainment vessels, the integrity of the containmentstructure should be determined so that the potentialfor release and its magnitude can be evaluated. Thisdetermination is especially important for buried drumsor tanks, because corrosion may be rapid. Thesedata, as well as the data identified in Table 3-10,may be obtained largely through site inspections,mapping, remote sensing, and sampling and analysis.The waste type should be determined for eachsource. If available waste manifests or facility recordscan be reviewed, the industrial processes thatresulted in generation of the waste should bedetermined and the types of contaminants usuallypresent in the process waste identified. Often,sources are sampled and analyzed for contaminantsfound on the Target Compound List (TCL) (formerlythe Hazardous Substances List) or other lists such asthose developed for RCRA3. Quantities of wastesmay be estimated for each waste type either fromverifiable inventories of containerized wastes, fromsampling and analysis, or from physical dimensions ofthe source. Section 13 of the Compendium and

3 Guidance on determining whether wastes are RCRA-listed orcharacteristic wastes can be found in the CERCLACompliance with Other Laws Manual (U.S. EPA, May 1988).

Characterization of Hazardous Waste Sites - AMethods Manual, Volume II (U.S. EPA, April 1985)describe methods suitable for sampling and analysis.

It may be possible to determine the location andextent of sources and the variation of materials withina w a s t e d e p o s i t b y n o n c h e m i c a l a n a l y s i s .Methodologies for this determination, which aredescribed in Section 8 of the Compendium, includegeophysical surveys. A variety of survey techniques(e.g., ground-penetrating radar, electrical resistivity,electromagnetic induction, magnetometry, andseismic profiling), can effectively detect and map thelocation and extent of buried waste deposits. Aerialphotography and infrared imagery can aid in definingsources through interpretation of the ecologicaleffects that result from stressed biota. However, all ofthese geophysical methods are nonspecific, andsubsequent sampling of the sources will probably berequired to provide the data for evaluation of sourcecontrol measures at the site.

3.2.4 Determine the Nature and Extent ofContamination

The final objective of the field investigations is tocharacterize the nature and extent of contaminationsuch that informed decisions can be made as to thelevel of risk presented by the site and the appropriatetype(s) of remedial response. This process involvesusing the information on source location and physicalsite data (e.g., ground-water flow directions, overland flow patterns) to give a preliminary estimate ofthe locations of contaminants that may have migrated.An iterative monitoring program is then implementedso that, by using increasingly accurate analyticaltechniques, the locations and concentrations ofcontaminants that have migrated into the environmentcan be documented.

The sampling and analysis approach that should beused is discussed in Section 4.5.1 of the D Q OGuidance. In short, the approach consists of, whereappropriate, initially taking a large number of samplesusing field screening type techniques and then, basedon the results of these samples, taking additionalsamples - to be analyzed more rigorously - fromt h o s e l o c a t i o n s t h a t s h o w e d t h e h i g h e s tconcentrations in the previous round of sampling. Thefinal step is to document the extent of contaminationusing an analytical level that yields data quality that issufficient for the risk assessment and the subsequentanalysis and selection of remedial alternatives.

At hazardous waste sites the nature and extent ofcontamination may be of concern in five media:ground water, soil, surface water, sediments, and air.The methodologies for conducting sampling andanalysis for each of these media are discussedbelow. More detailed descriptions of the investigation

3 - 13

I

process can be found in the DQO Guidance and theCompendium.

3.2.4.1 Ground WaterT h e n a t u r e a n d e x t e n t o f g r o u n d - w a t e rcontamination should be evaluated both horizontallyand vert ical ly. On the basis of geologic andhydrogeologic investigations, it should be determinedif contamination of an aquifer(s) is possible and ifsuch contamination could potentially affect human orenvironmental receptors. Following this, a ground-wate r mon i to r ing p rogram may need to beimplemented, concentrating the placement of wells inthe direction of ground-water flow, in aquiferssubject to contamination, and in places where theywould indicate an existing or future threat to receptorpopulations. However, because of the uncertaintiesassociated with subsurface migration, identifyingbackground levels, and determining if there is acontribution from other sources, sampling should alsobe conducted in the area perceived to be upgradientfrom the contaminant source.

Because of the significant investment necessary todrill new wells and the resulting limited number ofsamples, neither Level I nor f ield-screeningtechniques are appropriate for analysis of groundwater, other than to possibly better define chemicalanalysis parameters. Geophysical techniques can beuseful in identifying the location of plumes andthereby assisting in the location of monitoring wells.However, geophysical techniques are subject toinf luences f rom external factors and are notappropriate at all sites. Therefore, care must be takenin employing these methods, and their results shouldalways be confirmed with analytical sampling. Specificguidance on conducting ground water samplinginvestigations and response activities can be found inthe Compendium, the DQO Guidance, and the“Guidance on Remedial Actions for ContaminatedGround Water at Superfund Sites” (U.S. EPA, Draft,

August 1988).

3.2.4.2 Soil

As with ground-water sampling, the intent of soilsampling is to characterize and estimate the limits ofexist ing soi l contamination. Field-screeningtechniques (e.g., soil gas analysis, mobile laboratoriesfor target compounds) can be useful for directing soilsampling into areas of greatest contamination or “hotspots.” If existing information provides no basis forpredicting where hot spots might occur, samplinglocations can be chosen in a grid pattern ofappropriate size such that investigators can beconfident that areas of high concentration have beenloca ted . Of ten , espec ia l l y i f so i l has beencontaminated as a result of overland flow ofcontaminants from defined sources, sampling can be

concentrated in those areas that, either throughtopography or evidence such as drainage channels, itis most likely that contaminants have been deposited.As with ground water, soil contamination should bedocumented in both vertical and horizontal directions.This approach will help determine both areas ofcontamination and background concentrations. Soilsto be analyzed usually can be obtained by hand,allowing many samples to be taken and initiallyanalyzed with instruments such as a photoionizationdetector. Results of field screening can then be usedto determine which samples should be furtheranalyzed using more rigorous methods.

3.2.4.3 Surface WaterLeachate from contaminant sources or discharge ofcontaminated ground water can resul t in thecontamination of surface waters. Surface-watersampling locations should be chosen at the perceivedlocation(s) of contaminant entry to the surface waterand downstream, as far as necessary, to documentthe extent of contamination. As with soil, the relativeease of obtaining samples allows many samples to betaken and analyzed using field screening methods, asubset of which can be chosen for more rigorousanalysis.

Contamination of surface water is sometimes theresult of an incidental release of contaminants suchas the over f low ing o r b reach o f a su r faceimpoundment. In these cases, it is not likely thatr o u t i n e s u r f a c e w a t e r s a m p l i n g w i l l s h o wcontamination that has or may occur. Therefore, todocument whether such releases occur, samplingshould be conducted during or following periods ofheavy rainfall when possible.

3.2.4.4 SedimentsA potentially more serious and common problemassociated with surface water is the contamination ofsediments. Whereas contamination in surface watertends to become diluted or transformed as it travelsdownstream, contaminants deposited in ‘sedimentstend to remain in place. It is therefore important tomonitor for sediment contamination if it is suspectedthat surface water has been contaminated.

The choice of sampling locations for sediments issimilar to the criteria applied to surface-watersampling. Field-screening techniques can be usefulin defining areas of contamination. However, it shouldbe noted that sediment contamination often consistsof inorganics and/or nonvolatile organics for whichfield screening techniques are not as applicable.Therefore, in designing a sampling program,consideration of the contaminants of concern is veryimportant.

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3.2.4.5 Air

Volatilization of organics and emissions of airborneparticulates can be a concern at hazardous wastesites. For sites at which it appears that air emissionsare a problem (e.g., surface impoundments containingvolatile organics, landfills at which there is evidenceof methane gas production and migration), an airemissions monitoring program should be undertaken.A field-screening program is recommended todetermine if there is an air pollution problem, both forvolatile organics and fugitive dust emissions. Becauseof the highly variable nature of air emissions fromh a z a r d o u s w a s t e s i t e s , c o n s i d e r a t i o n o fmeteorological conditions at the time of sampling isessential for the proper documentation of potential airpollution.

3.2.5 Additional Site Characterization

In some situations, additional site information may berequired to refine our understanding of the site andbetter evaluate specific remedial alternatives.Examples include:

Better delineation of contaminated areas anddepths of contamination so that quantities ofcontaminated media to be processed can becalculated more accurately

Characteristics of the media that would affect thefeasibility of the remedial alternative, such as soilpermeability for soil-vapor extraction

Pertinent site characteristics not discoveredearlier in the initial site characterization effort

Before additional site characterization is initiated, theQAPP/FSP should be reviewed and modified asappropriate to guide the collection of additional sitedata. In addition, site data collected and evaluated aspart of the initial RI site characterization should bereviewed and compared to the data needs identifiedfor conducting the detailed analysis of alternatives.Reviewing data needs during the preplanning step isalso useful in predicting the necessary number ofsamples and types of analyses required.

3.3 Laboratory AnalysesData that will be used as the basis for decision-making requires that the analysis of samples inlaboratories meets specific QA/QC requirements. Tomeet these requirements, federal- or state-lead siteinvestigations have the option of using mobilelaboratories; the CLP, which is established by EPA: ora non-CLP laboratory that meets the DQOs of thesite investigation.4

4 The type of laboratory analyses that will be utilized for aPRP-lead RI/FS may also include any of those listed above,if approved by the RPM (See Appendix A).

The CLP provides analytical services through anationwide network of laboratories under contract toEPA. The lead agency chooses whether or not to usea CLP laboratory on the basis of available CLPcapacity and the analytical requirements that meet theDQOs. If the CLP is not used, a laboratory may beprocured using standard bidding procedures.

Under the CLP, the majority of analytical needs aremet through standardized laboratory servicesprovided by Routine Analytical Services (RAS). TheRAS program currently provides laboratory servicesfor the analysis of organics and inorganics in water orsolid samples. Other specialized types of analysis notyet provided by standardized laboratory contracts maybe scheduled on an as-needed basis under thespecial analytical services (SAS) program. The SASprogram is designed to complement the RAS programby providing the capability for specialized or customanalytical requirements. If an analytical need is notordinarily provided by routine analytical services(FWS), a specific subcontract can be awarded underthe SAS program to meet a particular requirement.

The decision whether to use mobile laboratories or aCLP or non-CLP laboratory should be based onseveral factors including the analytical servicesrequired, the number of samples to be analyzed, thedesired turnaround t ime, and the ant ic ipatedturnaround time of the laboratory at the time samplesare to be sent. Mobile or non-CLP laboratorieslocated close to the site may be the best choicewhen fast turnaround of analytical results is requiredto meet specific sampling objectives or would result ina significant reduction of the overall RI/FS schedule.To facilitate the most efficient completion of the RI,mobile or non-CLP laboratories can be used toin i t ia l l y document the na ture and ex ten t o fcontamination. Selected duplicate samples can besent to CLP laboratories to confirm and validate theanalytical results from the mobile or non-CLPlaboratories. This process assists in the timelycompletion of the RI and the initiation of FS activities,while still ensuring that legally defensible data areavailable for decision-making and potential cost-recovery actions.

If a non-CLP laboratory is used, analytical protocolsneed to be specified in the bid packages sent tolaboratories that are under consideration. Forfederal-lead sites, laboratories receiving invitationsto bid have usually been approved by the EPARegional QA representative. For state-lead sites atwhich non-CLP laboratories are used, the laboratoryusually subcontracts with the prime contractor whenthe project is initiated.

Section 5 of the Compendium presents the details ofprocedures for the use of CLP laboratories and non-CLP laboratories. The User’s Guide to the Contract

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Laboratory Program (U.S. EPA, December 1966) alsopresents procedures for use of the CLP.

3.4 Data AnalysesAnalyses of the data collected should focus on thedevelopment or refinement of the conceptual sitemodel by presenting and analyzing data on sourcecharacter ist ics, t h e n a t u r e a n d e x t e n t o fcontamination, the contaminated transport pathwaysand fate, and the effects on human health and theenvironment. Data collection and analysis for the sitecharacterization is complete when the DQOs thatwere developed in scoping (including any revisionsduring the RI) are met, when the need (or lackthereof) for remedial actions is documented, andwhen the data necessary for the development andevaluation of remedial alternatives have beenobtained. The results of the RI typically are presentedas an analysis of site characteristics and the riskassociated with such characteristics (i.e., the baselinerisk assessment).

3.4.1 Site Characteristics

The evaluation of site characteristics should focus onthe current extent of contamination and estimating thet rave l t ime to , and p red ic t ing con taminan tconcentrations at, potential exposure points. Datashould be analyzed to describe (1) the site physicalcharacteristics, (2) the source characteristics, (3) thenature and extent of contamination, and (4) thei m p o r t a n t c o n t a m i n a n t f a t e a n d t r a n s p o r tmechanisms.

3.4.1.1 Site Physical Characteristics

Data on site physical characteristics should beanalyzed to describe the environmental setting at thesite, including important surface features, soils,geology, hydrology, meteorology, and ecology. Thisanalysis should emphasize factors important indetermining contaminant fate and transport for thoseexposure pathways of concern. For example, ifmigration of contamination in ground water is ofconcern, these factors may include the properties ofthe unsaturated zone, the rate and direction of flow inthe aquifer(s), and the extent of subsurface systems.

3.4.1.2 Source CharacteristicsData on source characteristics should be analyzed todescribe the source location; the type and integrity ofany existing waste containment; and the types,quantities, chemical and physical properties, andconcentrations of hazardous substances found. Theactual and potential magnitude of releases from thesource and the mobility and persistence of sourcecontaminants should be evaluated.

3.4.1.3 The Nature and Extent of Contamination

An analysis of data collected concerning the studyarea should be performed to describe contaminantconcentration levels found in environmental media inthe study area. Analyses that are important to thesubsequent r isk assessment and subsequentdevelopment of remedial alternatives include thehorizontal and vertical extent of contamination in soil,ground water, surface water, sediment, air, biota, andf a c i l i t i e s . 5 S p a t i a l a n d t e m p o r a l t r e n d s i ncontamination may be important in evaluatingtransport pathways. Data should be arranged intabular or graphical form for clarity. Figure 3-2shows an example of how the extent of soil andground-water contamination can be represented interms of excess lifetime cancer risk. Similar figurescan be prepared showing concentrations rather thanrisk values.

3.4.1.4 Contaminant Fate and Transport

Results of the site physical characteristics, sourcecharacteristics, and extent of contamination analysesare combined in the analyses of contaminant fate andtransport. If information on the contaminant release isavailable, the observed extent of contamination maybe used in assessing the transport pathway’s rate ofmigration and the fate of contaminants over theperiod between release and monitoring. Contaminantfate and transport may also be estimated on the basiso f s i te phys ica l charac te r is t i cs and sourcecharacteristics.

Either analysis may use analytical or numericalmodeling. While field data generally best define theextent of contamination, models can interpolateamong and extrapolate from isolated field samplesand can interpret field data to create a more detaileddescription. Models also can aid the data reductionprocess by providing the user with a structure fororganizing and analyzing field data.

Models applicable to site characterization can begrouped according to their relative accuracy and theirability to depict site conditions. Simplified models(e.g., analytical and semianalytical models) canquantitatively estimate site conditions with relativelylow accuracy and resolution. Typically, they provideorder-of-magnitude estimates and require thatsimplified assumptions be made regarding siteconditions and chemical characteristics.

More detailed numerical models (e.g., numericalcomputer codes) provide greater accuracy andresolution because they are capable of representing

5 Cross-media contamination should be considered (e.g.,potential for contaminated soils to act as a source for ground-water contamination due to leaching from the soil).

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spatial variations in site characteristics and irregulargeometries commonly found at actual sites. Thesemodels can also represent the actual configurationand effects of remedial actions on site conditions.Detailed mathematical models are sometimesappropriate for investigations in which detailedinformation on contaminant fate and transport isrequired.

Models also are useful for screening alternativeremedial actions and may be used for a detailedanalysis of alternatives. Deciding whether analytical ornumerical models should be used and selectingappropr ia te mode ls fo r e i the r the remed ia linvestigation or the feasibility study can be difficult.Modeling may not be needed if site conditions arewell understood and if the potential effectiveness ofdifferent remedial actions can be easily evaluated. Inselecting and applying models, it is important toremember that a model is an artificial representationof a physical system and is only one way ofcharacterizing and assessing a site. A model cannotreplace, nor can it be more accurate than, the actualsite data. Additional information on determiningcontaminant fate and transport is provided in the“Superfund Exposure Assessment Manual” (U.S.EPA, April 1988).

3.4.2 Baseline Risk Assessment

3.4.2.1 General Information

Baseline risk assessments provide an evaluation ofthe potential threat to human health and theenvironment in the absence of any remedial action.They provide the basis for determining whether or notremedial action is necessary and the justification forperforming remedial actions. The baseline riskassessment will also be used to support a finding ofimminent and substantial endangerment if such afinding is required as part of an enforcement action.Detailed guidance on evaluating potential humanhealth impacts as part of this baseline assessment isprovided in the Superfund Public Health EvaluationManual (SPHEM) (U.S. EPA, October 1986).6

Guidance for evaluating ecological risks is currentlyunder development within OSWER.

In general, the object ives of a basel ine r iskassessment may be attained by identifying andcharacterizing the following:

Toxicity and levels of hazardous substancespresent in relevant media (e.g., air, ground water,soil, surface water, sediment, and biota)

6 This guidance is currently undergoing revision.

Environmental fate and transport mechanismswithin specific environmental media such asphysical, chemical, and biological degradationprocesses and hydrogeological conditions

Potential human and environmental receptors

Potential exposure routes and extent of actual orexpected exposure

Extent of expected impact or threat; and thelikelihood of such impact or threat occurring (i.e.,risk characterization)

Level(s) of uncertainty associated with the aboveitems

The level of effort required to conduct a baseline riskassessment depends largely on the complexity of thesite. The goal is to gather sufficient information toadequately and accurately characterize the potentialrisk from a site, while at the same time conduct thisassessment as efficiently as possible. Use of theconceptual site model developed and refinedpreviously will help focus investigation efforts and,therefore, streamline this effort. Factors that mayaffect the level of effort required include:

The number , concen t ra t ion , and types o fchemicals present

Areal extent of contamination

The quality and quantity of available monitoringdata

T h e n u m b e r a n d c o m p l e x i t y o f e x p o s u r epathways (including the complexity of releasesources and transport media)

The required precision of sample analyses, whichin turn depends on site conditions such as theextent of contaminant migration and the proximity,characteristics, and size of potentially exposedpopulation(s)

The availability of appropriate standards and/ortoxicity data

3.4.2.2 Components of the Baseline RiskAssessment

The risk assessment process can be divided into fourcomponents:

Contaminant identification

Exposure assessment

Toxicity assessment

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LEGEND*

Soil Area Exceeding 10-6

Lifetime Cancer Risk

Ground Water Exceeding10-6 Lifetime Cancer Risk

*NOTE: 1. Site-specific features should be shownas appropriate (e.g., actual of potentialground-water users).

SCALE IN FEET 2. Contamination can be represented byconcentrations in addition to risk levels.

Figure 3-2. Representation of the areal extent of contamination.

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Risk characterization

Figure 3-3 illustrates the risk assessment processand its four components. A brief overview of eachcomponent follows.

Contaminant Ident i f icat ion. The object ive ofcontaminant identification is to screen the informationthat is available on hazardous substances or wastespresent at the site and to identify contaminants ofconcern to focus subsequent efforts in the riskassessment process. Contaminants of concern maybe selected because of their intrinsic toxicologicalproperties, because they are present in largequantities, or because they are presently in orpotentially may move into critical exposure pathways(e.g., drinking water supply).

It may be useful for some sites to select “indicatorchemicals” as part of this process.7 I n d i c a t o rchemicals are chosen to represent the most toxic,persistent, and/or mobile substances among thoseidentified that are likely to significantly contribute tothe overall risk posed by the site. In some instances,an indicator chemical may be selected for thepurpose of representing a “class” of chemicals (e.g.,TCE to represent all volatiles). Although the use ofindicator chemicals serves to focus and streamlinethe assessment on those chemicals that are likely tobe of greatest concern, a final check will need to bemade during remedy selection and the remedialaction phase to ensure that the waste managementstrategy being implemented addresses risks posed bythe range of contaminants found at the site.

Exposure Assessment The objectives of an exposureassessment are to identify actual or potentialexposure pathways, to characterize the potentiallyexposed populations, and to determine the extent ofthe exposure. Detailed guidance on conductingexposure assessments is provided in the SuperfundExposure Assessment Manual (U.S. EPA, April1988), and is briefly discussed below.

Identifying potential exposure pathways helps toconceptualize how contaminants may migrate from asource to an existing or potential point of contact. Anexposure pathway may be viewed as consisting offour elements: (1) A source and mechanism ofchemical release to the environment; (2) Anenvironmental transport medium (e.g., air, groundwater) for the released chemical; (3) A point ofpotential contact with the contaminated medium(referred to as the exposure point); and (4) Anexposure route (e.g., inhalation, ingestion) at theexposure point.

7 The methodology for identifying indicator chemicals forassessing human health risks is described in the SuperfundPublic Health Evaluation Manual (U.S. EPA, October 1986).

The analysis of the contaminant source and howcontaminants may be released involves characterizingthe contaminants of concern at the si te anddetermining the quantities and concentrations ofcontaminants released to environmental media. Figure3-4 presents a conceptual example identifying actualand potential exposure pathways.

Once the source(s) and release mechanisms havebeen identified, an analysis of the environmental fateand transport of the contaminants is conducted. Thisanalysis considers the potential environmentaltransport (e.g., ground-water migration, airbornetransport); transformation (e.g., biodegradation,hydrolysis, and photolysis); and transfer mechanisms(e.g., sorption, volatilization) to provide information onthe potential magnitude and extent of environmentalcontamination. Next, the actual or potential exposurepoints for receptors are identified. The focus of thiseffort should be on those locations where actualcontact with the contaminants of concern will occur oris likely to occur. Last, potential exposure routes thatdescribe the potential uptake mechanism (e.g.,ingestion, inhalation, etc.) once a receptor comes intocontact with contaminants in a specific environmentalmedium are identified and described. Environmentalmedia that may need to be considered include air,ground water, surface water, soil and sediment, andfood sources. Detailed procedures for estimating andcalculating rates of exposure are described in detail inthe Super-fund Exposure Assessment Manual.

After the exposure pathway analysis is completed, thepoten t ia l fo r exposure shou ld be assessed.Information on the frequency, mode, and magnitudeof exposure(s) should be gathered. These data arethen assessed to yield a value that represents theamount of contaminated media contacted per day.This analysis should include not only identification ofcurrent exposures but also exposures that may occurin the future if no action is taken at the site. Becausethe frequency mode and magnitude of humanexposures will vary based on the primary use of thearea (e.g., residential, industrial, or recreational), theexpected use of the area in the future should beevaluated. 8The purpose of this analysis is to providedecision-makers with an understanding of both thecurrent risks and potential future risks if no action istaken. Therefore, as part of this evaluation, areasonable maximum exposure scenario should bedeveloped, which reflects the type(s) and extent ofexposures that could occur based on the likely orexpected use of the site (or surrounding areas) in the

8 This evaluation does not require an extensive analysis ofdemographic trends and a statistically measurable confidencelevel for the prediction of future development, only that thelikely use (based on past and current trends, zoningrestrictions, etc.) be evaluated.

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future.9 The reasonable maximum exposure scenariois presented to the decision-maker so that possibleimplications of decisions regarding how to bestmanage uncertainties can be factored into the riskmanagement remedy selection.

The final step in the exposure assessment is tointegrate the information and develop a qualitativeand/or quantitative estimate of the expected exposurelevel(s) resulting from the actual or potential releaseof contaminants from the site.

Toxicity Assessment. Toxicity assessment, as part ofthe Super-fund baseline risk assessment process,considers (1) the types of adverse health orenvironmental effects associated with individual andmultiple chemical exposures; (2) the relationshipbetween magnitude of exposures and adverseeffects; and (3) related uncertainties such as theweight of evidence for a chemical’s potentialcarcinogenicity in humans. Detailed guidance forconducting toxicity assessments is provided in theSPHEM.

Typically, the Super-fund risk assessment processrelies heavily on existing toxicity information and doesnot involve the development of new data on toxicity ordose-response relationships. Available informationon many chemicals is already evaluated andsummarized by various EPA program offices orc r o s s - A g e n c y w o r k g r o u p s i n h e a l t h a n denvironmental effects assessment documents. Thesedocuments or profiles will generally provide sufficienttoxicity and dose-response information to allow bothqualitative and quantitative estimates of risksassociated with many chemicals found at Superfundsites. These documents often estimate carcinogenexposures associated with specific lifetime cancerrisks (e.g., risk-specific doses or RSDs), andsystemic toxicant exposures that are not likely topresent appreciable risk of significant adverse effectsto human populations over a lifetime (e.g., ReferenceDoses or RfDs).

Risk Characterization. In the final component of therisk assessment process, a characterization of thepotential risks of adverse health or environmentaleffects for each of the exposure scenarios derived inthe exposure assessment, is developed andsummarized. Estimates of risks are obtained byintegrating information developed during the exposureand toxicity assessments to characterize the potentialor actual r isk, including carcinogenic r isks,noncarcinogenic risks, and environmental risks. Thefinal analysis should include a summary of the risksassociated with a site including each projected

9Additional guidance on developing reasonable maximumexposure scenarios will be provided in the upcoming revision ofthe SPHEM.

exposure route for contaminants of concern and thedistribution of risk across various sectors of thepopulation. In addition, such factors as the weight-of-evidence associated with toxicity information, andany uncer ta in t ies assoc ia ted w i th exposureassumptions should be discussed.

Characterization of the environmental risks involvesidentifying the potential exposures to the surroundingecological receptors and evaluating the potentialeffects associated with such exposure(s). Importantfactors to consider include disruptive effects topopulations (both plant and animal) and the extent ofperturbations to the ecological community.

The results of the baseline risk assessment mayindicate that the site poses little or no threat to humanhealth or the environment. In such situations, the FSshould be either scaled down as appropriate to thatsite and its potential hazard, or eliminated altogether.The results of the RI and the basel ine r iskassessment will therefore serve as the primary meansof documenting a no-action decision. If it is decidedthat the scope of the FS will be less than what ispresented in this guidance or eliminated altogether,the lead agency should document this decision andreceive the concurrence of the support agency.

3.4.3 Evaluate Data Needs

As data are collected and a better understanding ofthe site and the risks that it poses are obtained, thepreliminary remedial action alternatives developedduring scoping should be reviewed and refined. Theavailable data should be evaluated to determine ifthey are sufficient to develop remedial alternatives. Ifthey are not, additional data gathering will berequired. When sufficient data are available, remedialresponse objectives with respect to the contaminantsof concern, the areas and volumes of contaminatedmedia, and existing and potential exposure routes andreceptors of concern can be developed as part of theFS.

3.5 Data Management ProceduresAn RI may generate an extensive amount ofinformation, the quality and validity of which must becons is ten t l y we l l documented because th isinformation will be used to support remedy selectiondecisions and any legal or cost recovery actions.Therefore, field sampling and analytical proceduresfor the acquisition and compilation of field andlaboratory data are subject to data managementprocedures. 10 The discussion on data management

1 0 DQOs will govern the data management procedures used,and the QAPP/FSP will identify both field-collected andanalytical data. Information to be recorded should includesampling information, recording procedures, samplemanagement, and QC concerns.

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Figure 3-3. Components of the risk assessment process.

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procedures is divided into three categories: fieldactivities, sample management and tracking, anddocument control and inventory.

3.5.1 Field Activities

During site characterization and sampling, consistentdocumenta t ion and accura te recordkeep ingprocedures are critical because subsequent decisionswill be made on the basis of information gatheredduring these tasks. Aspects of data management forsampling activities during site characterization include:

Quality Assurance/Quality Control (QA/QC)Plans - These documents provide records ofresponsibility, adherence to prescribed protocols,nonconformity events, corrective measures, anddata deficiencies.

A Data Security System - This system outlinesthe measures that will be taken in the field tosa feguard cha in -o f -cus tody records andprevent free access to project records, therebyguarding against accidental or intentional loss,damage, or alteration.

Field Logs - The daily field logs are the primaryrecord for field investigation activities and shouldinclude a description of any modifications to theprocedures outlined in the work plan, fieldsampling plan, or health and safety plan, withjustifications for such modifications. Fieldmeasurements and observations should berecorded directly into the project log books.Examples of field measurements include pH,temperature, conductivity, water flow, air qualityparameters, and soil characteristics. Health andsafety monitoring, sampling locations, samplingtechniques, and a general description of dailyactivity are typically included in the daily log. Anyunusual occurrences or circumstances should bedocumented in these logs and can be used forreference in determining the possible causes fordata anomalies discovered during data analysis.Data must be recorded directly and legibly in fieldlog books with entries signed and dated. Changesmade to original notes should not obliterate theoriginal information and should be dated andsigned. Standard format information sheetsshould be used whenever appropriate and shouldbe retained in permanent files.

Documentation involved in maintaining field sampleinventories and proper chain-of-custody recordsmay include the following11:

11 Specific requirements may vary between state- andfederal-lead sites.

Sample Identification Matrix

Sample Tag

Traffic Report

High-Hazard Traffic Report

SAS Packing List

Cha in-o f -Custody Form

Notice of Transmittal

Receipt for Samples Form

Central Regional Laboratory (CRL) Sample DataReport

Shipping Airbill

Additional information for each of these items, alongwith the instructions for their completion, can befound in Section 6.2 of the Compendium.

3.5.2 Sample Management and TrackingA record of sample shipments, receipt of analyticalresults, submittal of preliminary results for QA/QCreview, completion of QA/QC review, and evaluationof the QC package should be maintained to ensurethat only final and approved analytical data are usedin the site analysis. In some instances, the use ofpreliminary data is warranted to prepare internalreview documents, begin data analysis whi leminimizing lost time for the turnaround of QA/QCcomments, and continue narrowing remedial actionalternat ives. Prel iminary data are consideredunofficial, however, and preliminary data used inanalyses must be updated upon receipt of officialQA/QC comments and changes. Sample resultsshould not be incorporated in the site characterizationreport unless accompanied by QA/QC comments.

The DQOs stated for each task involving sampleanalysis must specify whether the information is validwith qualifiers or not and must specify which qualifierscan invalidate the use of certain data. For instance,reproducibility of plus or minus 20 percent may beacceptable in a treatability study but may not beacceptable for determining the risk to human healthfrom drinking water. Acceptability of data quality is notestablished until the reviewed QA/QC packageaccompanies the analytical data.

The acceptable QA/QC package should be defined inthe approved site QAPP for each discrete task.Where use of the CLP is involved, review by the CRLQA Office is typical but may vary from one Region tothe next and may vary from one state to the next inthe case of state-lead sites. Nevertheless, the

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DQOs outlined for the use of the data will dictate thelevel of review required.

3.5.3 Document Control and Inventory

Sample results should be managed in a standardizedform to promote easy reporting of data in the sitecharacterization report. Precautions should be takenin the analysis and storage of the data collectedduring site characterization to prevent the introductionof errors or the loss or misinterpretation of data.

The document inventory and filing systems can beset up on the basis of serially numbered documents.These systems may be manual or automated. Asuggested structure and sample contents of a file forSuperfund activities are shown in Table 3-11. Therelationship of this filing system to the AdministrativeRecord is discussed in the “Interim Guidance onAdministrative Records for Selection of CERCLAResponse Actions” (U.S. EPA, Draft, June 1988).

3.6 Community Relations ActivitiesDuring Site Characterization

Two-way communication with interested members ofthe community should be maintained throughout theRI. The remedial project manager and CommunityRelations Coordinator keep local officials andconcerned citizens apprised of site activities and ofthe schedule of events by implementing severalcommunity relation activities. These actions areusually delineated in the community relations plan andtypically include, but are not limited to, publicinformation meetings at the beginning and end of theRI; a series of fact sheets that will be distributed tothe community during the investigation and willdescribe up-to-date progress and plans forremedial activities; telephone briefings for keymembers of the community, public officials andrepresentatives of concerned citizens, and periodicnews releases that describe progress at the site.

The files containing the Administrative Record shouldbe established once the RI/FS work plan is finalizedand kept at or near the site. It is recommended thatthe files containing the Administrative Record be keptat one of the information repositories for publicinformation at or near the site and near availablecopying facilities. Copies of site-related informationshould be made available to the community andshould typically include the RI/FS work plan, asummary of monitoring results, fact sheets, and thecommunity relations plan. The objective of communityrelations activities during the RI is to educate thepublic on the remedial process and keep thecommunity informed of project developments as theyoccur, thereby reducing the likelihood of conflictarising from a lack of information, misinformation, orspeculation. As directed in the community relations

Table 3-11. Outline of Suggested File Structure forSuperfund Sites

Congressional lnquiries and Hearings: Correspondence Transcripts Testimony Published hearing records

Remedial Response:Discovery- Initial investigation reports- Preliminary assessment report- Site inspection report- Hazard Ranking System data

Remedial planning- Correspondence- Work plans for RI/FS- Rl/FS reports- Health and safety plan- QA/QC plan- Record of decision/responsiveness summary

Remedial implementation- Remedial design reports- Permits- Contractor work plans and progress reports- Corps of Engineers agreements, reports, and

correspondence

State and other agency coordination- Correspondence- Cooperative agreement/Superfund state contract- State quarterly reports- Status of state assurances- Interagency agreements- Memorandum of Understanding with the state

Community relations- Interviews- Correspondence- Community relations plan- List of people to contact, e.g.. local officials, civic

leaders, environmental groups- Meeting summaries- Press releases- News clippings- Fact sheets- Comments and responses- Transcripts- Summary of proposed plan- Responsiveness summary

Imagery:PhotographsIllustrationsOther graphics

EnforcementStatus reportsCross-reference to any confidential enforcement files andthe person to contact

CorrespondenceAdministrative orders

ContractsSite-specific contractsProcurement packagesContract status notificationsList of contractors

Financial Transactions:Cross-reference to other financial files and the person tocontact

Contractor cost reportsAudit reports

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plan, all activities should be tailored to the communityand to the site.

3.7 Reporting and CommunicationDuring Site Characterization

During site characterization, communication isrequired between the lead agency and the supportagency.12 In addition to routine communicationbetween members of the lead agency and theircontractor on project progress, written communicationis required between the lead agency and the supportagency as follows:

1.

2.

3.

4.

5.

The lead agency should provide the draft workplan to the support agency for review andcomment (discussed in Chapter 2.)

The lead agency should provide information oncontaminant types and affected media to thesuppor t agency fo r ARAR ident i f i ca t ion(chemical- a n d l o c a t i o n - s p e c i f i c A R A Rdeterminations are finalized once the sitecharacterization is complete).

The lead agency should provide data obtainedduring site characterization to ATSDR.13

The lead agency should provide a preliminarysummary of site characterization to the supportagency (this may serve as the mechanism forARAR identification).

The lead agency should provide a draft RI reportfor review and comment by the support agency.

Table 3-12 summarizes the points during sitecharacterization when written or oral communicationis recommended.

3.7.1 Information for ARA R Identification

The information for the support agency’s use inidentifying ARARs should include a description of thecontaminants of concern, the affected media, and anyphysical features that may help identify location-specific ARARs. This information may be supplied bythe preliminary site characterization summary (as

discussed below) or by a letter or other document.The support agency shall provide location- andchemical-specific ARARs to the lead agency beforepreparation of the draft RI report.

3.7.2 Preliminary Site CharacterizationSummary

A summary of site data following the completion ofinitial field sampling and analysis should be prepared.This summary should briefly review the analyticalresults of investigative activities to provide the leadagency w i th a re fe rence fo r eva lua t ing thedevelopment and screening of remedial alternatives.In addition, the preliminary site characterizationsummary may be used to assist the support agencyin identification of ARARs and provide ATSDR withdata (prior to issuance of the draft RI) to assist intheir health assessment efforts.

The format of this summary is optional and is left tothe discretion of the lead-agency RPM. The formatmay range from a technical memorandum, whichs imp ly l i s ts the loca t ions and quant i t ies o fcontaminants at the site, to a rough draft of the firstfour chapters of the RI report (see Table 3-13). Useof the technical memorandum and a progressmeeting is strongly encouraged over the latter tobetter facilitate RI/FS schedules and samplingprogress in the field.

3.7.3 Draft RI Report

A draft RI report should be produced for review bythe support agency and submitted to ATSDR for itsuse in preparing a health assessment and also serveas documentation of data collection and analysis insupport of the FS. The draft RI report can beprepared any time between the completion of thebaseline risk assessment and the completion of thedraft FS. Therefore, the draft RI report should notdelay the initiation or execution of the FS.

Table 3-13 gives a suggested format for the draft RIreport. The report should focus on the media ofconcern and, therefore, does not need to address allthe site characteristics listed, only those appropriateat that specific site.

1 2

1 3

Reporting and communicating during a PRP-lead RI/FS isdiscussed in Appendix A and in the forthcoming “DraftGuidance on Oversight of Potentially Responsible PartyRemedial Investigations and Feasibility Studies.”Guidance for coordinating remedial and ATSDR healthassessment activities is provided in OSWER Directive9285.4-02.

3 - 28

Table 3-12. Reporting and Communication During Site Characterization

Information Needed PurposePotential Methods ofInformation Provision

Need to rescope fieldactivities on the basis ofresults of field observations

Need to rescope fieldactivities on the basis ofresults of sample analysis

Preliminary results of fieldinvestigation tasks (e.g.,geophysical explorations,monitoring well installation.etc.)Descriptive and analyticalresults of initial sitecharacterization results(excluding risk assessment)

Listing of contaminants,affected media; location ofwetlands, historic sites, etc.

Refined remedial actionobjectives

Documentation of sitecharacterization field activitiesand analyses including anytreatability testing

Needed only if screening indicates that field activities need to berescoped; for lead agency and contractor to identify methods to improveeffectiveness of site characterization activities; for lead agency to obtainsupport agency review and concurrence

Needed only if analysis of laboratory data indicates field activities needto be rescoped; for lead agency and contractor to identify methods toimprove effectiveness of site characterization activities; for lead agencyto obtain support agency review and concurrence

Provided by the contractor to the lead agency; need and method ofcommunication at lead agency’s discretion

Provides lead agency with early summary of site data; assists insupporting agency with identification of ARARs; may also be submittedto ATSDR for use in preparing health assessment.

For support agency’s use in identifying chemical- and location- Preliminary sitespecific ARARs. characterization summary

For lead agency and contractor to define the basis for developingremedial action alternatives; obtain review and comment from thesupport agencyRequired for members of lead agency and their contractor to prepare forpublic comment and FS support documentation

MeetingTech memo

Other

MeetingTech memo

Other

Tech memos

Preliminary sitecharacterization summary

MeetingTech memo

Other

Draft RI report

3 - 29

Table 3-13. Suggested RI Report Format

Executive Summary

1. Introduction1.1 Purpose of Report1.2 Site Background

1.2.1 Site Description1.2.2 Site History

1.23 Previous investigations1.3 Report Organization

2. Study Area Investigation2.1 includes field activities associated with site characterization. These may include physical and chemical monitoring of some, but

not necessarily all, of the following:2.1.1 Surface Features (topographic mapping, etc.) (natural and manmade features)2.1.2 Contaminant Source Investigations2.1.3 Meteorological Investigations2.1.4 Surface-Water and Sediment Investigations2.1.5 Geological Investigations2.1.6 Soil and Vadose Zone Investigations2.1.7 Ground-Water Investigations2.1.8 Human Population Surveys2.1.9 Ecological Investigations

2.2 If technical memoranda documenting field activities were prepared, they may be included in an appendix and summarized in thisreport chapter.

3. Physical Characteristics of the Study Area3.1 Includes results of field activities to determine physical characteristics. These may include some, but not necessarily all, of the

following:3.1.1 Surface Features3.1.2 Meteorology3.1.3 Surface-Water Hydrology3.1.4 Geology3.1.5 Soils3.1.6 Hydrogeology3.1.7 Demography and Land Use3.1.8 Ecology

4. Nature and Extent of Contamination4.1 Presents the results of site characterization, both natural chemical components and contaminants in some, but not necessarily all,

of the following media:4.1.1 Sources (lagoons, sludges, tanks, etc.)4.1.2 Soils and Vadose Zone4.1.3 Ground Water4.1.4 Surface Water and Sediments4.1.5 Air

5. Contaminant Fate and Transport5.1 Potential Routes of Migration (i.e., air, ground water, etc.)5.2 Contaminant Persistence

5.2.1 If they are appliable (i.e., for organic contaminants), describe estimated persistence in the study area environment andphysical, chemical, and/or biological factors of importance for the media of interest.

5.3 Contaminant Migration5.3.1 Discuss factors affecting contaminant migration for the media of importance (e.g., sorption onto soils. solubility in water,

movement of ground water, etc.)5.3.2 Discuss modeling methods and results, if applicable.

6. Baseline Risk Assessment6.1 Human Health Evaluation

6.1.1 Exposure Assessment6.1.2 Toxicity Assessment6.1.3 Risk Characterization

6.2 Environmental Evaluation

3 - 30

Table 3-13 Continued

7. Summary and Conclusions7.1 Summary

7.1.1 Nature and Extent of Contamination7.1.2 Fate and Transport7.1.3 Risk Assessment

7.2 Conclusions7.2.1 Data Limitations and Recommendations for Future Work7.2.2 Recommended Remedial Action Objectives

AppendicesA. Technical Memoranda on Field Activities (if available)B. Analytical Data and QA/QC Evaluation ResultsC. Risk-Assessment Methods

3 - 3 1

CHAPTER 4DEVELOPMENT AND

SCREENING OF ALTERNATIVES

4 - 1

Chapter 4Development and Screening of Alternatives

4.1 Introduction

4.1.1 Purpose of Alternative Development andScreening

The primary objective of this phase of the FS is todevelop an appropriate range of waste managementoptions that will be analyzed more fully in the detailedanalysis phase of the FS. Appropriate waste man-agement options that ensure the protection of humanhealth and the environment may involve, dependingon site-specific circumstances, the completeelimination or destruction of hazardous substances atthe site, the reduction of concentrations of hazardoussubstances to acceptable health-based levels, andprevention of exposure to hazardous substances viaengineering or institutional controls, or somecombination of the above. Alternatives are typicallyd e v e l o p e d c o n c u r r e n t l y w i t h t h e R I s i t echaracterization, with the results of one influencingthe other in an iterative fashion (i.e., RI sitecharacterization data are used to develop alternativesand screen technologies, whereas the range ofalternatives developed guides subsequent sitecharacterization and/or treatability studies). Anoverview of the entire FS process is presented in thefollowing subsections.

4.1.2 FS Process Overview

The FS may be viewed (for explanatory purposes) asoccurring in three phases: the development ofalternatives, the screening of the alternatives, and thedetailed analysis of alternatives. However, in actualpractice the specific point at which the first phaseends and the second begins is not so distinct.Therefore, the development and screening ofalternatives are discussed together to better reflectthe interrelatedness of these efforts. Furthermore, inthose instances in which circumstances limit thenumber of available options, and therefore thenumber of alternatives that are developed, it may notbe necessary to screen alternatives prior to thedetailed analysis.

4.1.2.1 Development and Screening ofAlternatives

Alternatives for remediation are developed byassembling combinations of technologies, and themedia to which they would be appl ied, intoalternatives that address contamination on a sitewidebasis or for an identified operable unit. This processconsists of six general steps, which are shown inFigure 4-1 and briefly discussed below:

Develop remedial action objectives specifying thecontaminants and media of interest, exposurepathways, and preliminary remediation goals thatpermit a range of treatment and containmentalternatives to be developed. The preliminaryremediation goals are developed on the basis ofchemical-specific ARARs, when available, otheravailable information (e.g., Rfds), and site-specific risk-related factors.1

Develop general response act ions for eachmedium of interest def in ing containment,treatment, excavation, pumping, or other actions,singly or in combination, that may be taken tosatisfy the remedial action objectives for the site.

Identify volumes or areas of media to whichgeneral response actions might be applied, takinginto account the requirements for protectivenessas identified in the remedial action objectives andthe chemical and physical characterization of thesite.

Identify and screen the technologies applicable toeach general response action to eliminate thosethat cannot be implemented technically at thesite.2 The general response actions are further

1 These preliminary remediation goals are reevaluated as sitecharacterization data and information from the baseline riskassessment become available.

2 It is important to distinguish between this medium-specifictechnology screening step during development of alternativesand the alternative screening that may be conductedsubsequently to reduce the number of alternatives prior to thedetailed analysis.

4 - 3

Figure 4-1 Alternative development.

4 - 4

defined to specify remedial technology types(e.g., the general response action of treatmentcan be further defined to include chemical orbiological technology types).

Identify and evaluate technology process optionsto select a representative process for eachtechnology type retained for consideration.Although specific processes are selected, foralternative development and evaluation, theseprocesses are intended to represent the broaderrange of process options within a generaltechnology type.

Assemble the selected representative technolo-gies into alternatives representing a range oftreatment and containment combinations, asappropriate.

Figure 4-2 provides a generic representation of thisprocess. Section 4.2 contains a more detaileddescription and specific examples of alternativedevelopment.

For those situations in which numerous wastemanagement options are appropriate and developed,the assembled alternatives may need to be refinedand screened to reduce the number of alternativesthat will be analyzed in detail. This screening aids instreamlining the feasibility study process whileensuring that the most promising alternatives arebeing considered.

As discussed earlier, in other situations the number ofviable or appropriate alternatives for addressing siteproblems may be limited; thus, the screening effortmay be minimized or eliminated if unnecessary. Thescope of this screening effort can vary substantially-depending on the number and type of alternativesdeveloped and the extent of information necessary forconducting the detailed analysis. The scope andemphasis can also vary depending on either thedegree to which the assembled alternatives addressthe combined threats posed by the entire site or onthe individual threats posed by separate site areas orcontaminated media. Whatever the scope, the rangeof treatment and containment alternatives initiallydeveloped should be preserved through thealternative screening process to the extent that itmakes sense to do so.

As part of the screening process, alternatives areanalyzed to investigate interactions among media interms of both the evaluation of technologies (i.e., theextent to which source control influences the degreeof ground-water or air-quality control) and sitewideprotectiveness (i.e., whether the alternative providessufficient reduction of risk from each media and/orpathway of concern for the site or that part of the sitebeing addressed by an operable unit). Also at thisstage, the areas and quantities of contaminated

media initially specified in the general responseactions may also be reevaluated with respect to theeffects of interactions between media. Often, sourcecontrol actions influence the degree to whichground-water remediation can be accomplished orthe time frame in which it can be achieved. In suchinstances, further analyses may be conducted tomodify either the source control or ground-waterresponse actions to achieve greater effectiveness insitewide alternatives. Using these refined alternativeconfigurations, more detailed information about thetechnology process options may be developed. Thisinformation might include data on the size andcapacities of treatment systems, the quantity ofmater ials required for construct ion, and theconfiguration and design requirements for ground-water collection systems.

Information available at the time of screening shouldbe used primarily to identify and distinguish anydifferences among the various alternatives and toevaluate each al ternat ive with respect to i tseffectiveness, implementability, and cost. Only thealternatives judged as the best or most promising onthe basis of these evaluation factors should beretained for further consideration and analysis.3

Typically, those alternatives that are screened out willreceive no further consideration unless additionalinformation becomes available that indicates furtherevaluation is warranted. As discussed in Section4.2.6, for sites at which interactions among media arenot significant, the process of screening alternatives,described here, may be applied to medium-specificoptions to reduce the number of options that willeither be combined into sitewide alternatives at theconclusion of screening or will await further evaluationin the detailed analyses. Section 4.3 contains moredetail about screening alternatives.

4.1.2.2 Detailed Analysis of Alternatives

During the detailed analysis, the alternatives broughtthrough screening are further refined, as appropriate,and analyzed in detail with respect to the evaluationcriteria described in Chapter 6. Alternatives may befurther refined and/or modified based on additionalsite characterization or treatability studies conductedas part of the RI. The detailed analysis should beconducted so that decision-makers are providedwith sufficient information to compare alternatives withrespect to the evaluation criteria and to select anappropriate remedy. Analysis activities are describedin greater detail in Chapter 6.

3 As with the use of representative technologies, alternativesmay be selected to represent sufficiently similar managementstrategies; thus, in effect, a separate analysis for eachalternative is not always warranted.

4 - 5

4.1.3 Alternative Ranges

Alternatives should be developed that will providedecision-makers with an appropriate range ofoptions and sufficient information to adequatelycompare alternatives against one another. Indeveloping alternatives, the range of options will varydepending on site-specific conditions. A generaldescription of ranges for source control and ground-water response actions that should be developed, asappropriate, are described below.

4.1.3.1 Source Control Actions

For source control actions, the following types ofalternatives should be developed to the extentpracticable:

A number of treatment alternatives ranging fromone that would eliminate or minimize to the extentfeasible the need for long-term management(including monitoring) at a site to one that woulduse treatment as a primary component of analternative to address the principal threats at thesite.4 Alternatives within this range typically willdiffer in the type and extent of treatment usedand the management requirements of treatmentresiduals or untreated wastes.

One or more alternatives that involve containmentof waste with little or no treatment but protecthuman health and the environment by preventingpotential exposure and/or reducing the mobility ofcontaminants.

A no-action alternative5

Figure 4-3 conceptually illustrates this range forsource control alternatives.

Development of a complete range of treatmentalternatives will not be practical in some situations.For example, for sites with large volumes of lowconcentrated wastes such as some municipal landfillsand mining sites, an alternative that eliminates theneed for long-term management may not bereasonable given site conditions, the limitations oftechnologies, and extreme costs that may beinvolved. If a full range of alternatives is not

4 Alternatives for which treatment is a principal element couldinclude containment elements for untreated waste or treatmentresiduals as well.

5 Although a no-action alternative may include some type ofenvironmental monitoring, actions taken to reduce the potentialfor exposure (e.g., site fencing, deed restrictions) should not beincluded as a component of the no-action alternatives. Suchminimal actions should constitute a separate “limited” actionalternative.

developed, the specific reasons for doing so shouldbe briefly discussed in the FS report to serve asdocumentation that treatment alternatives wereassessed as required by CERCLA.

4.1.3.2 Ground-water Response ActionsFor ground-water response actions, alternativesshould address not only cleanup levels but also thetime frame within which the alternatives might beachieved. Depending on specific site conditions andthe aquifer characteristics, alternatives should bedeveloped that achieve ARARs or other health-based levels determined to be protective withinvarying time frames using different methodologies.For aquifers currently being used as a drinking watersource, alternatives should be configured that wouldachieve ARARs or risk-based levels as rapidly aspossible. More detailed information on developingremedial alternatives for ground-water responseactions may be found in “Guidance on RemedialActions for Contaminated Ground Water at Super-fundSites” (U.S. EPA, August 1988).

4.2 Alternative Development ProcessThe alternative development process may be viewedas consisting of a series of analytical steps thatinvolves making successively more specific definitionsof potential remedial activities. These steps aredescribed in the following sections.

4.2.1 Develop Remedial Action ObjectivesRemedial action objectives consist of medium-specific or operable unit-specific goals for protectinghuman health and the environment. The objectivesshould be as specific as possible but not so specificthat the range of alternatives that can be developed isunduly limited. Column two of Table 4-1 providesexamples of remedial action objectives for variousmedia.

Remedial action objectives aimed at protecting humanhealth and the environment should specify:

The contaminant(s) of concern

Exposure route(s) and receptor(s)

An acceptable contaminant level or range oflevels for each exposure route (i.e., a preliminaryremediation goal)

Remedial action objectives for protecting humanreceptors should express both a contaminant leveland an exposure route, rather than contaminant levelsalone, because protectiveness may be achieved byreducing exposure (such as capping an area, limitingaccess, or providing an alternate water supply) aswell as by reducing contaminant levels. Because

4 - 7

Figure 4-3 Conceptual treatment range for source control.

Figure 4-3 (Continued)

4 - 9

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r e m e d i a l a c t i o n o b j e c t i v e s f o r p r o t e c t i n genvironmental receptors typically seek to preserve orrestore a resource (e.g. , as ground water) ,environmental objective(s) should be expressed interms of the medium of interest and target cleanuplevels, whenever possible.

Although the preliminary remediation goals areestablished on readily available information [e.g.,reference doses (Rfds) and risk-specific doses(RSDs)] or frequently used standards (e.g., ARARs),the final acceptable exposure levels should bedetermined on the basis of the results of the baselinerisk assessment and the evaluation of the expectedexposures and associated risks for each alternative.Contaminant levels in each media should becompared with these acceptable levels and include anevaluation of the following factors:

Whether the remediation goals for all carcinogensof concern, including those with goals set at thechemica l -spec i f i c ARAR leve l , p rov idesprotection within the risk range of 10-4 to 10-7.

Whether the remediation goals set for all non-carcinogens of concern, including those withgoals set at the chemical-specific ARAR level,are sufficiently protective at the site.

Whether environmental effects (in addition tohuman health effects) are adequately addressed.

Whether the exposure analysis conducted as partof the risk assessment adequately addresseseach significant pathway of human exposureidentified in the baseline risk assessment. Forexample, if the exposure from the ingestion of fishand drinking water are both significant pathwaysof exposure, goals set by considering only one ofthese exposure pathways may not be adequatelyprotective. The SPHEM provides additional detailson establishing acceptable exposure levels.

4.2.2 Develop General Response Actions

General response actions describe those actions thatwill satisfy the remedial action objectives. Generalresponse actions may include treatment, containment,excavation, extraction, disposal, institutional actions,or a combination of these. Like remedial actionobjectives, general response actions are medium-specific.

General response actions that might be used at a siteare initially defined during scoping and are refinedthroughout the RI/FS as a better understanding of siteconditions is gained and action-specific ARARs areidentified. In developing alternatives, combinations ofgeneral response act ions may be ident i f ied,particularly when disposal methods primarily dependon whether the medium has been previously treated.

Examples of potential general response actions areincluded in column three of Table 4-l.

4.2.3 Identify Volumes or Areas of MediaDuring the development of alternatives an initialdetermination is made of areas or volumes of mediato which general response actions might be applied.This initial determination is made for each medium ofinterest at a site. To take interactions between mediainto account, response actions for areas or volumesof media are often refined after sitewide alternativeshave been assembled. The refinement of alternativesis discussed at greater length in Section 4.3.1.

Defining the areas or volumes of media requirescareful judgment and should include a considerationof not only acceptable exposure levels and potentialexposure routes, but also site conditions and thenature and extent of contamination. For example, inan area with contamination that is homogeneouslydistributed in a medium, discrete risk levels (e.g.,1 0-5, 10-6) or corresponding contaminant levelsmay provide the most rational basis for defining areasor volumes of media to which treatment, containment,or excavation actions may be applied. For sites withdiscrete hot spots or areas of more concentratedcontamination, however, it may be more useful todefine areas and volumes for remediation on thebasis of the site-specific relationship of volume (orarea) to contaminant level. Therefore, when areas orvolumes of media are defined on the basis of site-specific considerations such as volume versusconcentration relationships, the volume or areaaddressed by the alternative should be reviewed withrespect to the remedial action objectives to ensurethat alternatives can be assembled to reduceexposure to protective levels.

4.2.4 Identify and Screen RemedialTechnologies and Process Options

In this step, the universe of potentially applicabletechnology types and process options is reduced byevaluating the options with respect to technicalimplementability. In this guidance document, the term“technology types” refers to general categories oftechnologies, such as chemical treatment, thermaldestruction, immobilization, capping, or dewatering.The term “technology process options” refers tospecific processes within each technology type. Forexample, the chemical treatment technology typewould include such process options as precipitation,ion exchange, and oxidation/reduction. As shown incolumns four and five of Table 4-1, several broadtechnology types may be identified for each generalresponse action, and numerous technology processoptions may exist within each technology type.

Technology types and process options may beidentified by drawing on a variety of sources including

4 - 1 5

references developed for application to Superfundsites and more standard engineering texts notspecifically directed toward hazardous waste sites.Some of these sources are included in Appendix D ofthis document.

During this screening step, process options and entiretechnology types are eliminated from furtherc o n s i d e r a t i o n o n t h e b a s i s o f t e c h n i c a limplementability. This is accomplished by usingreadily available information from the RI sitecharac te r i za t ion on con taminant t ypes andconcentrations and onsite characteristics to screenout technologies and process options that cannot beeffectively implemented at the site.

Two factors that commonly influence technologys c r e e n i n g a r e t h e p r e s e n c e o f i n o r g a n i ccontaminants, which limit the applicability of manytypes of treatment processes, and the subsurfaceconditions, such as depth to impervious formations orthe degree of fracture in bedrock, which can limitmany types of containment and ground-watercollection technologies. This screening step is site-specific, however, and other factors may need to beconsidered. Figure 4-4 provides an example of initialtechnology screening for ground-water remediationat a site having organic and inorganic contaminantsand shallow, fractured bedrock.

As with all decisions during an RI/FS, the screening oftechnologies should be documented. For moststudies, a figure similar to Figure 4-4 providesadequate information for this purpose and can beincluded in the FS report.

4.2.5 Evaluate Process Options

In the fourth step of alternative development, thet e c h n o l o g y p r o c e s s e s c o n s i d e r e d t o b eimplementable are evaluated in greater detail beforeselecting one process to represent each technologytype. One representative process is selected, ifpossible, for each technology type to simplify thesubsequent deve lopment and eva lua t ion o falternatives without limiting flexibility during remedialdesign. The representative process provides a basisfor developing performance specifications duringpreliminary design; however, the specific processactually used to implement the remedial action at asite may not be selected until the remedial designphase. In some cases more than one process optionmay be selected for a technology type. This may bedone if two or more processes are sufficientlydifferent in their performance that one would notadequately represent the other.

Process options are evaluated using the same criteria- effectiveness, implementability, and cost - that areused to screen alternatives prior to the detailedanalysis. An important distinction to make is that at

th is t ime these c r i te r ia a re app l ied on ly totechnologies and the general response actions theyare intended to satisfy and not to the site as a whole.Furthermore, the evaluation should typically focus oneffectiveness factors at this stage with less effortdirected at the implementability and cost evaluation.

Because o f the l im i ted da ta on innovat ivetechnologies, it may not be possible to evaluate theseprocess opt ions on the same basis as otherdemonstrated technologies. Typically, if innovativetechnologies are judged to be implementable they areretained for evaluation either as a “selected” processoption (if available information indicates that they willprovide better treatment, fewer or less adverseeffects, or lower costs than other options), or they willbe “represented” by another process option of thesame technology type. The evaluation of processoptions is illustrated in Figure 4-5 and discussed inmore detail below.

4.2.5.1 Effectiveness Evaluation

Specific technology processes that have beenidentified should be evaluated further on theireffectiveness relative to other processes within thesame technology type. This evaluation should focuson: (1) the potential effectiveness of process optionsin handling the estimated areas or volumes of mediaand meeting the remediation goals identified in theremedial action objectives;6 (2) the potential impactsto human health and the environment during theconstruction and implementation phase; and (3) howproven and reliable the process is with respect to thecontaminants and conditions at the site.

Information needed to evaluate the effectiveness oftechnology types for the different media includescontaminant type and concentration, the area orvo lume o f con tamina ted med ia , and , whenappropriate, rates of collection of liquid or gaseousmedia. For some media it may be necessary toconduct preliminary analyses or collect additional sitedata to adequately evaluate effectiveness. This isoften the case for processes in which the rates ofremoval or collection and treatment are needed forevaluation, such as for ground-water extraction,su r face-wate r co l lec t ion and t rea tment , o rsubsurface gas collection. In such cases, a limitedconceptual design of the process may need to bedeveloped, a n d m o d e l i n g o f t h e p o t e n t i a lenvironmental transport mechanisms associated withtheir operation may be undertaken. Typically,however, such analyses are conducted during the

6The ability of some collection/removal systems, such asground-water pumping, to sufficiently recover contaminatedmedia for subsequent treatment may also be assessed as partof this evaluation.

4 - 1 6

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later phases of the FS when alternatives are refinedand evaluated on a sitewide basis.

If modeling of transport processes is undertakenduring the alternative development and screening,phases of the FS to evaluate removal or collectiontechnologies, and if many contaminants are presentat the site, it may be necessary to identify indicatorchemicals, as is often done for the baseline riskassessments, to simplify the analysis. Typically,indicator chemicals are selected on the basis of theirusefulness in evaluating potential effects on humanhealth and the environment. Commonly selectedindicator chemicals include those that are highlymobile and highly toxic.

4.2.5.2 Implementability Evaluation

Implementability encompasses both the technical andadministrative feasibility of implementing a technologyprocess. As discussed in Section 4.2.4, technicalimplementability is used as an initial screen oftechnology types and process options to eliminatethose that are clearly ineffective or unworkable at asite. Therefore, this subsequent, more detailedevaluation of process options places greatere m p h a s i s o n t h e i n s t i t u t i o n a l a s p e c t s o fimplementability, such as the ability to obtainnecessary permits for offsite actions, the availability oftreatment, storage, and disposal services (includingcapacity), and the availability of necessary equipmentand skilled workers to implement the technology.

4.2.5.3 Cost EvaluationCost plays a limited role in the screening of processoptions. Relative capital and O&M costs are usedrather than detailed estimates. At this stage in theprocess, the cost analysis is made on the basis ofengineering judgment, and each process is evaluatedas to whether costs are high, low, or medium relativeto other process options in the same technology type.As discussed in Section 4.3, the greatest cost con-sequences in site remediation are usually associatedwith the degree to which different general technologytypes (i.e., containment, treatment, excavation, etc.)are used. Using different process options within atechnology type usually has a less significant effecton cost than does the use of different technologytypes.

4.2.6 Assemble AlternativesIn assembling alternatives, general response actionsand the process options chosen to represent thevarious technology types for each medium oroperable unit are combined to form alternatives forthe site as a whole. As discussed in Section 4.1.2.1,appropriate treatment and containment options should

be developed. To assemble alternatives, generalresponse actions should be combined using differenttechnology types and different volumes of mediaand/or areas of the site. Often more than one generalresponse action is applied to each medium. Forexample, a l t e r n a t i v e s f o r r e m e d i a t i n g s o i lcontamination will depend on the type and distributionof contaminants and may include incineration of soilfrom some portions of the site and capping of others.

For sites at which interactions among media are notsignificant (i.e., source control actions will not affectground-water or surface-water responses) thecombination of medium-specific actions into sitewide alternatives can be made later in the FSprocess, either after alternatives have been screenedor prior to conducting the comparative analysis ofalternatives. For example, if media interactions arenot of concern, an FS might describe three sourcecontrol options, three soil remediation options, andfour ground-water remediation options, (instead ofdeveloping numerous comprehensive sitewidealternatives). Although this approach permits greaterflexibility in developing alternatives and simplifies theanalyses of sitewide alternatives, it may involvegreater effort in developing and analyzing medium-specific options.

Figure 4-6 illustrates how general response actionsmay be combined to form a range of sitewidealternatives. For this relatively simple example, thetwo media of interest are soil and ground water. Therange of alternatives developed include a no-actionalternative (alternative 1); a limited action alternative(alternative 2); source containment options with andwithout ground water treatment (alternatives 3 and 4);and three alternatives that employ various levels ofsource treatment, with ground-water collection andtreatment (alternatives 5, 6, and 7).

Although not shown in this example, a description ofeach alternative should be included in the FS report.For the alternatives presented in Figure 4-6, suchdescriptions would include the locations of areas tobe excavated or contained, the approximate volumesof soil and/or ground water to be excavated andcollected, the approximate locations of interceptortrenches, the locations of potential city water supplyhook-ups, the locations of connections to the localp u b l i c l y o w n e d t r e a t m e n t w o r k s ( P O T W ) ,management options for treatment residuals, and anyother information needed to adequately describe thealternative and document the logic behind theassembly of general response actions into specificremedial action alternatives. In describing alternatives,it may be useful to note those process options thatwere not screened out and that are represented bythose described in the alternative.

4 - 2 0

a This is a conceptual example using the example of carcinogenic risk ranges; however, In general, when MCLs are available they will apply.

Figure 4-8. Assembling a range of alternative examples.

4.3 Alternatives Screening Process

4.3.1 Alternatives Definition

technologies or remediation timeframes have notbeen fully characterized (except for timeframesi d e n t i f i e d t o d e v e l o p g r o u n d - w a t e r a c t i o nalternatives). Furthermore, interactions among media,which may influence remediation activities, haveusually not been fully determined, nor have sitewideprotectiveness requirements been addressed.Therefore, at this point in the process, such aspectsof the alternatives may need to be further defined to

Before beginning screening, alternatives have beena s s e m b l e d p r i m a r i l y o n m e d i u m - s p e c i f i cconsiderations and implementability concerns.Typically, few details of the individual process optionshave been identified, and the sizing requirements of

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form the basis for evaluating and comparing thealternatives before their screening.

4.3.1.1 Specific Objectives

Alternatives are initially developed and assembled tomeet a set of remedial action objectives for eachmedium of interest. During screening, the assembledalternatives should be evaluated to ensure that theyprotect human health and the environment from eachpotential pathway of concern at the site or thoseareas of the site being addressed as part of anoperable unit. If more than one pathway is present,such as inhalation of airborne contaminants andingestion of contaminants in ground water, the overallrisk level to receptors should be evaluated. If it isfound that an alternative is not fully protective, areduction in exposure levels for one or more mediawill need to be made to attain an acceptable risklevel.

In refining alternatives, it is important to note thatprotectiveness is achieved by reducing exposures toacceptable levels, but achieving these reductions inexposures may not always be possible by actuallycleaning up a specific medium to these same levels.For example, protection of human health at a site mayrequire that concentrations of contaminants indrinking water be reduced to levels that could notreasonably be achieved for the water supply aquifer;thus, protection could be provided by preventingexposures with the use of a wellhead treatmentsystem. The critical selection of how risk reductionsare to be achieved is part of the risk managementdecisionmaking process.

4.3.1.2 Define Media and Process Options

Alternatives should be defined to provide sufficientquantitative information to allow differentiation amonga l te rna t ives w i th respect to e f fec t iveness ,implementability, and cost. Parameters that oftenrequire additional refinement include the extent orvolume of contaminated material and the size ofmajor technology and process options.

Refinement of volumes or areas of contaminatedmedia is important at some sites at which ongoingreleases from the source (or contaminated soils)significantly affect contaminant levels in other media(e.g., ground water) because such interactions maynot have been addressed when alternatives wereinitially developed by grouping medium-specificresponse actions. If interactions among media appearto be important at a site, the effect of source controlactions on the remediation levels or time frames forother media should be evaluated.

Figure 4-7 provides an example of such an analysisin which volatile organics in soil are migrating into an

underlying aquifer composed of unconsolidatedmaterials. Using a model of transport processes atthe site, the effect of different soil removal actions onground-water remediat ion (using a specif iedextraction scheme) could be estimated. In thisexample, development of alternatives that considerground water actions independent of soil removal(i.e., the no-soil-removal scenario) could result inunderestimating the achievable remediation level oroverestimating the time frame for ground-waterremediation. This could result in an overestimation ofthe extraction and treatment requirements fortechnology processes for ground water. By evaluatingsoil and ground water actions together, the rates andvolumes of ground water extraction to achieve thetarget remediation levels can be refined moreaccurately.

After the alternatives have been refined with respectto volumes of media, the technology process optionsneed to be defined more fully with respect to theireffectiveness, implementability, and cost such thatdifferences among alternatives can be identified. Thefollowing information should be developed, asappropriate, for the various technology processesused in an alternative:

Size and configuration of onsite extraction andtreatment systems or containment structures -For media contaminated with several hazardoussubstances, i t may be necessary to f i rstdetermine which contaminant(s) impose thegreatest treatment requirements; then size orconfigure accordingly. Similarly, for ground-water extraction technologies at sites with multipleground-water contaminants, it may be necessaryto evaluate which compounds impose thegreatest limits on extraction technologies, eitherbecause of their chemical/physical characteristics,concentration, or distribution in ground water.

Time frame in which treatment, containment, orremoval goals can be achieved - The remediationtime frame is often interdependent on the size ofa treatment system or configuration of a ground-water extraction system. The time frame may bedetermined on the basis of specific remediationgoals (e.g., attaining ground-water remediationgoals in 10 years), in which case the technologyis sized and configured to achieve this; the timeframe may also be influenced by technologicallimitations (such as maximum size consideration,performance capabilities, and/or availability ofadequate t rea tment sys tems or d isposa lcapacity).

Rates or flows of treatment - These will alsoinfluence the sizing of technologies and timeframe within which remediation can be achieved.

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TIME IN YEARS

Figure 4-7. Time to achieve 10-4 to 10-6 risk level for a single-contaminant for ground water cleanup under various soilremoval alternatives.

Spatial requirements for constructing treatment or and other legal considerations. These may also

con ta inment techno log ies o r fo r s tag ing encompass some ac t ion - , l oca t ion - , and

construction materials or excavated soil or waste chemical-specific ARARs.

Distances for disposal technologies - Theseinclude approximate transport distances toacceptable offsite treatment and disposal facilitiesand distances for water pipelines for discharge toa receiving stream or a POTW.

Required permits for offsite actions and imposedlimitations - These include National PollutantDischarge El iminat ion System (NPDES),pretreatment, and emission control requirements;coordination with local agencies and the public;

4.3.2 Screening Evaluation

Defined alternatives are evaluated against the short-and long-term aspects of three broad criteria:effectiveness, implementability, and cost. Becausethe purpose of the screening evaluation is to reducethe number of alternatives that will undergo a morethorough and extensive analysis, alternatives will beevaluated more generally in this phase than duringthe detailed analysis. However, evaluations at thistime should be sufficiently detailed to distinguishamong alternatives. In addition, one should ensure

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that the alternatives are being compared on anequivalent basis (i.e., definitions of treatmentalternatives are approximately at the same level ofdetail to allow preparation of comparable costestimates).

Initially, specific technologies or process options wereevaluated primarily on the basis of whether or notthey could meet a particular remedial action objective.During alternative screening, the entire alternative isevaluated as to its effectiveness, implementability,and cost.

During the detailed analysis, the alternatives will beevaluated against nine specific criteria and theirindividual factors rather than the general criteria usedin screening. Therefore, individuals conducting the FSshould be familiar with the nine criteria (see Section6.2.2) at the time of screening to better understandthe direction that the analysis will be taking. Therelationship between the screening criteria and thenine evaluation criteria is conceptually illustrated inFigure 4-8.

It is also important to note that comparisons duringscreening are usual ly made between simi laralternatives (the most promising of which is carriedforward for further analysis); whereas, comparisonsduring the detailed analysis will differentiate acrossthe entire range of alternatives. The criteria used forscreening are described in the following sections.

4.3.2.1 Effectiveness Evaluation

A key aspect of the screening evaluation is theeffectiveness of each alternative in protecting humanhealth and the environment. Each alternative shouldbe evaluated as to its effectiveness in providingprotection and the reductions in toxicity, mobility, orvolume that it will achieve. Both short- and long-term components of ef fect iveness should beevaluated; short-term referring to the constructionand implementation period, and long-term referringto the period after the remedial action is complete.Reduction of toxicity, mobility, or volume refers tochanges in one or more characteristics of thehazardous substances or contaminated media by theuse of treatment that decreases the inherent threatsor risks associated with the hazardous material.

4.3.2.2 Implementability Evaluation

Implementability, as a measure of both the technicaland administrative feasibility of constructing,operating, and maintaining a remedial actionalternative, is used during screening to evaluate thecombinations of process options with respect toconditions at a specific site. Technical feasibilityrefers to the ability to construct, reliably operate, andmeet technology-specific regulations for processoptions until a remedial action is complete; it also

includes operation, maintenance, replacement, andmonitoring of technical components of an alternative,if required, into the future after the remedial action iscomplete. Administrative feasibility refers to the abilityto obtain approvals from other offices and agencies,the availability of treatment, storage, and disposalservices and capacity, and the requirements for, andavailability of, specific equipment and technicalspecialists.

The determination that an alternative is not technicallyfeasible and is not available will usually preclude itfrom further consideration unless steps can be takento change the condit ions responsible for thedetermination. Typically, this type of “fatal flaw”would have been identified during technologyscreening, and the infeasible alternative would nothave been assembled. Negative factors affectingadministrat ive feasibi l i ty wi l l normally involvecoordination steps to lessen the negative aspects ofthe alternative but will not necessarily eliminate analternative from consideration.

4.3.2.3 Cost Evaluation

Typically, alternatives will have been defined wellenough before screening that some estimates of costare available for comparisons among alternatives.However, because uncertainties associated with thedefinition of alternatives often remain, it may not bepracticable to define the costs of alternatives with theaccuracy desired for the detailed analysis (i.e., +50percent to -30 percent).

Absolute accuracy of cost estimates during screeningis not essential. The focus should be to makecomparative estimates for alternatives with relativeaccuracy so that cost decisions among alternativeswill be sustained as the accuracy of cost estimatesimproves beyond the screening process. Theprocedures used to develop cost estimates foralternative screening are similar to those used for thedetailed analysis; the only differences would be in thedegree of alternative refinement and in the degree towhich cost components are developed.

Cost estimates for screening alternatives typically willbe based on a variety of cost-estimating data. Basesfor screening cost estimates may include cost curves,generic unit costs, vendor information, conventionalcost-estimating guides, and prior similar estimatesas modified by site-specific information.

Prior estimates, site-cost experience, and goodengineering judgments are needed to identify thoseunique items in each alternative that will control thesecomparative estimates. Cost estimates for itemscommon to al l a l ternat ives or indirect costs(engineering, financial, supervision, outside contractorsupport, contingencies) do not normally warrant

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substantial effort during the alternative screeningphase.

Both capital and O&M costs should be considered,where appropriate, dur ing the sc reen ing o falternatives. The evaluation should include thoseO&M costs that will be incurred for as long asnecessary, even after the initial remedial action iscomplete. In addition, potential future remedial actioncosts should be considered during alternativescreening to the extent they can be defined. Presentworth analyses should be used during alternativescreening to evaluate expenditures that occur overdifferent time periods. By discounting all costs to acommon base year, the costs for different remedialaction alternatives can be compared on the basis of asingle figure for each alternative.

A more detailed discussion of cost evaluations ispresented in Chapter 6.

4.3.2.4 Innovative Technologies

Technologies are classified as innovative if they aredeveloped fully but lack sufficient cost or performancedata for routine use at Superfund sites. In manycases, it will not be possible to evaluate alternativesincorporating innovative technologies on the samebasis as available technologies, because insufficientdata exist on innovative technologies. If treatabilitytesting is being considered to better evaluate aninnovative technology, the decision to conduct a testshould be made as early in the process as possible toavoid delays in the RI/FS schedule.

Innovative technologies would normally be carriedthrough the screening phase if there were reason tobelieve that the innovative technology would offersignificant advantages. These advantages may be inthe form of bet ter t reatment performance orimplementability, fewer adverse impacts than otheravailable approaches, or lower costs for similar levelsof performance. A “reasonable belief” exists ifindications from other full-scale applications undersimilar circumstances or from bench-scale or pilot-scale treatability testing supports the expectedadvantages.

4.3.3 Alternative Screening

4.3.3.1 Guidelines for ScreeningAlternatives with the most favorable compositeevaluation of all factors should be retained for furtherconsideration during the detailed analysis. Alternativesselected for further evaluation should, wherepracticable, preserve the range of treatment andcontainment technologies initially developed. It is nota requirement that the entire range of alternativesoriginally developed be preserved if all alternatives in

a portion of the range do not represent distinct viableoptions.

The target number of alternatives to be carriedthrough screening should be set by the projectmanager and the lead agency on a site-specificbasis. It is expected that the typical target number ofalternatives carried through screening (includingcontainment and no-action alternatives) usuallyshould not exceed 10. Fewer alternatives should becarr ied through screening, i f possible, whi leadequately preserving the range of remedies. If thealternatives being screened are still medium-specificand do not address the entire site or operable unit,the number of alternatives retained for each specificmedium should be considerably less than 10.

4.3.3.2 Selection of Alternatives for DetailedAnalysis

Once the evaluation has been conducted for each ofthe alternatives, the lead agency and its contractorshould meet with the support agency to discuss eachof the alternatives being considered. This meetingdoes not correspond to a formal quality control reviewstage but provides the lead agency and its contractorwith input from the support agency and serves as aforum for updating the support agency with thecurrent direction of the FS.

T h e a l t e r n a t i v e s r e c o m m e n d e d f o r f u r t h e rconsideration should be agreed upon at this meetingso that documentation of the results of alternativescreening is complete; any additional investigationsthat may be necessary are identified; and the detailedanalysis can commence.

Unselected alternatives may be reconsidered at alater step in the detailed analysis if similar retainedalternatives continue to be evaluated favorably or ifinformation is developed that identifies an additionaladvantage not previously apparent. This provides theflexibility to double check a previous decision or toreview variations of alternatives being considered(e.g., consideration of other similar process options).However, i t i s e x p e c t e d t h a t u n d e r m o s tcircumstances, once an alternative is screened out itwill not be reconsidered for selection.

4.3.3.3 Post-screening TasksThe completion of the screening process leadsdirectly into the detailed analysis and may serve toidentify additional investigations that may be neededto adequately evaluate alternatives. To ensure asmooth transition from the screening of alternatives tothe detailed analysis, it will be necessary to identifyand begin verifying action-specific ARARs andinitiate treatability testing (if not done previously) andadditional site characterization, as appropriate.

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Although the consideration of action-specific ARARsbegins earlier as process options are combined, theidentification of action-specific ARARs will need tobe more definitive as the alternatives become betterdefined. At the conclusion of screening, sufficientinformation should exist on the technologies and themost probable configurations of technologies so thatthe lead agency and support agency can better defineand agree on action-specific ARARs. As withchemical-specific ARARs, action-specific ARARsshould include all Federal requirements and any Staterequirements that either are more stringent thanFederal ARARs or specify requirements where noFederal ARARs exist.

Once the field of alternatives has been narrowed, thetechnology processes of greatest interest can beidentified. At this point, the need for treatability tests(if not identified earlier) can be determined forprocess options that will require additional data fordetailed analysis. Although the results of treatabilitytesting may not be used until the detailed analysis,they should be initiated as early in the process aspossible to minimize any potential delays on the FSschedule. The type and scope of treatability testsdepends on the expected data requirements fordetailed analysis of alternatives. Factors involved indetermining the need for and scope of treatabilitystudies are discussed in Chapter 5.

In some cases, the need for addit ional si techaracterization may also be identified during thescreening phase. Because the nature and extent ofcontamination is usually well defined at this time,additional field investigations should be conductedonly to better define the effect of site conditions onthe performance of the technology processes ofgreatest interest.

4.4 Community Relations DuringAlternative Development andScreening

The community relations activities implemented forsite characterization may also be appropriate duringthe development of alternatives. Activities focus onproviding information to the community concerningthe development and screening of remedialalternatives and obtaining feedback on communityinterests and concerns associated with such alter-natives. Community relations activities should besite- and community-specific and are usuallystipulated in the community relations plan that isprepared during scoping activities. Communityrelations activities during the development ofalternatives may include, but are not limited to, a factsheet describing alternatives identified as potentiallyfeasible, a workshop presenting citizens with theAgency’s considerations for developing alternatives,briefings for local officials and concerned citizens on

alternatives under consideration, a small groupmeeting for citizens involved with the site, and newsreleases describing technologies being evaluated. It isimportant to note that public interest typicallyincreases as the feasibility study progresses; and thatthe technical adequacy of a remedy does not ensurecommunity acceptance. Therefore, the communityrelations activities should be planned and conductedto address such interest and potential concerns.

If alternatives are being developed concurrently withthe RI site characterization, information on thescreening of technologies and remedial alternativedevelopment should be included in public informationmaterials and act ivi t ies prepared during si techaracterization. If alternatives are developed aftersite characterization, additional community relationsactivities should be conducted. In general, communityrelations activities during alternative development andscreening are most appropriate if citizens aresignificantly concerned over site conditions, and RI/FSactivities that are being implemented at the site. Thelevel of effort for community relations at this phaseshould be described in the community relations plan.

4.5 Reporting and CommunicationDuring Alternative Development andScreening

Although no formal report preparation is requiredduring the development and screening of alternatives(except whatever routine administrative and projectmanagement tracking methods have been designatedfor use by the lead agency and its contractor(s))7,some form of written documentation of the methods,rationale, and results of alternative screening (e.g.,graphical representation similar to Figures 4-5 and4-6 or a technical memorandum) needs to beprovided to the lead and support agencies. If atechnical memorandum is prepared, it can serve asthe basis for later development of the chapter(s) inthe FS report that discusses the development andscreening of alternatives.

Communication among the lead and support agenciesand their contractor(s) is very important to obtaininput and agreement on the technologies orp rocesses and a l te rna t i ves cons idered fo rimplementation at the site. As shown in Table 4-2,communication should occur to facilitate the initialscreening of technologies and process options, toagree on what additional site data may be needed,and to gain input and agreement on the choice ofrepresentative processes and combinations to be

7 The RPM may require a written deliverable from the PRPsduring alternative development and screening for a PRP-leadRI/FS.

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used to assemble alternatives. In addition, thefollowing key coordination points are required:

The lead and support agencies should agree onthe set of alternatives selected for detailedanalysis.

The lead and support agencies must coordinateidentification of action-specific ARARs.

The lead agency and i ts contractor are toevaluate the need for any additional investigationsthat may be needed before they conduct thedetailed analysis.

For purposes of speed and efficiency, the preferredapproach for the exchange of information is throughmeetings. However, other approaches that facilitatee f fec t ive rev iew and input (e .g . , techn ica lmemorandums for review) may be used at the leadagency’s discretion.

Because the final RI/FS report may eventually besubject to judicial review, the procedures for

evaluating, defining, and screening alternatives shouldbe well documented, showing the rationale for eachstep. The following types of information should bedocumented in the final RI/FS report to the extentpossible:

Chemical - a n d / o r r i s k - b a s e d r e m e d i a lobjectives associated with the alternative

Modifications to any media-specific alternativesinitially developed to ensure that risk frommultiple-pathway exposures and interactionsamong source- and ground-water-remediationstrategies are addressed

Definition of each alternative including extent ofremediation, volume of contaminated material,size of major technologies, process parameters,cleanup timeframes, transportation distances, andspecial considerations

Notation of process options that were not initiallyscreened out and are being represented by theprocesses comprising the alternative

Table 4-2. Reporting and Communication During Alternative Development and Screening

Information Needed Purpose

All potential technologies included forconsideration

For lead agency and contractor to identifypotential technologies; for lead agency toobtain support agency review andcomment

Potential Methods for Information Provision

MeetingTech Memo

Other

Need for additional field data ortreatability studies

For lead agency and contractor todetermine whether more field data ortreatability tests are needed to evaluateselected technologies; for lead agency toobtain support agency review andcomment

Process evaluation and alternativedevelopment

Results of alternative screening (ifconducted)

For lead agency and contractor tocommunicate and reach agreement ontechnology screening and alternativedevelopment; for lead agency to obtainsupport agency review and comment

For lead agency and contractor tocommunicate and reach agreement onalternative screening; for lead agency toobtain support agency review andcomment

Identification of action-specific ARARs For lead agency to obtain input from thesupport agency on action-specific ARARs

Need for additional investigation For lead agency and contractor todetermine whether additional investigationsare needed to evaluate selectedalternatives; for lead agency to obtainsupport agency review and comment

MeetingTech Memo

Other

MeetingTech Memo

Other

MeetingTech Memo

Other

MeetingLetterOther

MeetingTech Memo

Other

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CHAPTER 5TREATABILITY

INVESTIGATIONS

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Chapter 5Treatability Investigations

5.1 Introduction

As discussed earlier, the phased RI/FS process isintended to better focus the site investigation so thatonly those data necessary to support the RI/FS andthe decision-making process are collected. Dataneeds are initially identified on the basis of theunderstanding of the site at the time the RI/FS isinitially scoped. Therefore, initial sampling and testingefforts may be limited until a more completeunderstanding of the site allows subsequent samplingefforts to be better focused. As site information iscollected during the RI and alternatives are beingdeveloped, additional data needs necessary toadequately evaluate alternatives during the detailedanalysis are often identified. These additional datan e e d s m a y i n v o l v e t h e c o l l e c t i o n o f s i t echaracterization data, as described in Chapter 3, ortreatability studies to better evaluate technologyperformance. This chapter is intended to provide anoverview of the types of treatability studies (i.e.,bench scale, pilot scale) that may be used, theirspecific purposes, and important factors that need tobe considered when contemplating their use.

5.1.1 Objectives of Treatability Investigations

Treatability studies are conducted primarily to achieve the following:

Provide suff ic ient data to al low treatmentalternatives to be fully developed and evaluatedduring the detailed analysis and to support theremedial design of a selected alternative

Reduce cost and performance uncertainties fortreatment alternatives to acceptable levels so thata remedy can be selected

5.1.2 Overview of Treatability Investigations

Treatability studies to collect data on technologiesidentified during the alternative development processare conducted, as appropriate, to provide additionalinformation for evaluating technologies. The RI/FScontractor and the lead agency’s RPM must reviewthe existing site data and available information ontechnologies to determine if treatability investigationsare needed. As discussed earlier, the need for

treatability testing should be identified as early in theRI/FS process as possible. A decision to conducttreatability testing may be made during projectscoping if information indicates such testing isdesirable. However, the decision to conduct theseactivities must be made by weighing the cost andtime required to complete the investigation againstthe potential value of the information in resolvinguncertainties associated with selection of a remedialaction. In some situations a specific technology thatappears to offer a substantial savings in costs orsignificantly greater performance capabilities may notbe identified until the later phases of the RI/FS. Undersuch circumstances it may be advantageous topostpone completion of the RI/FS until treatabilitystudies can be completed. Project managers will needto make such decisions on a case by case basis. Inother situations, treatability investigations may bepostponed until the remedial design phase.

The decision process for treatability investigations isshown conceptually in Figure 5-1 and consists ofthe following steps:

Determining data needs

Reviewing existing data on the site and availableliterature on technologies to determine if existingdata are sufficient to evaluate alternatives

Perform treatability tests, as appropriate, todetermine performance, operating parameters,and re la t i ve cos ts o f po ten t ia l remed ia ltechnologies

Evaluating the data to ensure that DQOs are met

5.2 Determination of Data RequirementsTo the extent possible, data required to assess thefeasibility of technologies should be gathered duringthe site characterization (e.g., moisture and heatcontent data should be collected if incineration of anorganic waste is being considered). Because datarequirements will depend on the specific treatmentprocess and the contaminants and matrices beingconsidered, the results of the site characterization willinfluence the types of alternatives developed andscreened, which will in turn influence additional data

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Figure 5-1. Treatability investigations.

needs . However , da ta co l lec ted dur ing s i techaracterization will not always be adequate forassessing the feasibility of remedial technologies,and, in fact, the need for detailed data fromtreatability tests may not become apparent until theinitial screening of alternatives has been completed. Adescription of data requirements for selectedtechnologies is presented in Table 5-l. T h eTechnology Screening Guide for Treatment ofCERCLA Soils and Sludges (U.S. EPA. September

1988) summarizes data needs for a larger number ofavailable and innovative technologies. The SuperfundInnovative Technology Evaluation (SITE) program isanother source to assist with the identification of dataneeds and to obtain performance information oninnovative technologies.

Additional data needs can be identified by conductinga more exhaustive literature survey than was originallyconducted when potential technologies were initially

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Table 5-1. Typical Data Requirements for Remediation Technologies

Technology Waste Matrix Example Data Required

Thermal Destruction Soils Moisture contentHeat valueChlorine contentDestruction efficiency

Liquids Heat valueConcentration of metalsDestruction efficiency

Air Stripping Ground Water Concentration of volatile contaminants. Concentration of non-volatile contaminantsContaminant removal efficiencies (obtainable from mathematical models)

Metal HydroxidePrecipitation

Ground Water Metals concentrationContaminant removal efficiencySludge generation rate and composition

In Situ VaporExtraction

Soils Soil typeParticle size distribution. Concentration of volatile compoundsPresence of non-volatile contaminantsContaminant removal efficiencies (usually requires bench- or pilot-scale work)

Note: Tables used in this outline are only partial examples.

being identified. The objectives of a literature surveyare as follows:

Determine whether the performance of thosetechnologies under consideration have beensufficiently documented on similar wastesconsidering the scale (e.g., bench, pilot, or full)and the number of times the technologies havebeen used

Gather information on relative costs, applicability,removal efficiencies, O&M requirements, andimplementability of the candidate technologies

Determine testing requirements for bench or pilotstudies, if required

5.3 Treatability TestingCertain technologies have been demonstratedsufficiently so that site-specific information collectedduring the site characterization is adequate toevaluate and cost those technologies withoutconducting treatability, testing. For example, aground-water investigation usually provides sufficientinformation from which to size a packed tower airstripper and prepare a comparative cost estimate.Other examples of when treatability testing may notbe necessary include:

A developed technology is well proven on similarapplications.

Substantial experience exists with a technologyemploying treatment of well-documented wastematerials. (For example, air stripping or carbonadsorption of ground water containing organiccompounds for which treatment has previouslyproven effective.)

Relatively low removal efficiencies are required(e.g., 50 to 90 percent), and data are alreadyavailable.

Frequently, technologies have not been sufficientlydemonstrated or characterization of the waste aloneis insufficient to predict treatment performance or toestimate the size and cost of appropriate treatmentunits. Furthermore, some treatment processes are notsufficiently understood for performance to bepredicted, even with a complete characterization ofthe wastes. For example, often it is difficult to predictbiological toxicity in a biological treatment plantwithout pilot tests. When treatment performance isdifficult to predict, an actual testing of the processmay be the only means of obtaining the necessarydata. In fact, in some situations it may be morecost-effective to test a process on the actual wastethan it would be to characterize the waste in sufficientdetail to predict performance.

Treatability testing performed during an RI/FS is usedto adequately evaluate a specific technology,including evaluating performance, determiningprocess sizing, and estimating costs in sufficientdetail to support the remedy-selection process.Treatability testing in the RI/FS is not meant to beused solely to develop detailed design or operatingparameters that are more appropriately developedduring the remedial design phase.

Treatability testing can be performed by usingbench-scale or pilot-scale techniques, which aredescribed in detail in the following sections. However,in general, treatability studies will include the followingsteps:

Preparing a work plan (or modifying the existingwork plan) for the bench or pilot studies

5 - 5

Performing field sampling, and/or bench testing,and/or pilot testing

Evaluating data from field studies, and/or benchtesting, and/or pilot testing

Preparing a brief report documenting the resultsof the testing

5.3.1 Bench-Scale Treatability Studies

Bench testing usually is performed in a laboratory, inwhich comparatively small volumes of waste aretested for the individual parameters of a treatmenttechnology. These tests are generally used todetermine if the “chemistry” of the process worksand are usually performed in batch (e.g., “jar tests”),with treatment parameters varied one at a time.Because small volumes and inexpensive reactors(e.g., bottles or beakers) are used, bench tests canbe used economically to test a relatively large numberof both performance and waste-composit ionvariables. It is also possible to evaluate a treatmentsystem made up of several technologies and togenerate limited amounts of residuals for evaluation.Bench tests are typically performed for projectsinvolving treatment or destruction technologies.However, care must be taken in attempting to predictthe performance of full-scale processes on the basisof these tests.

Bench-scale testing is useful for a developingtechnology, because it can be used to test for a widevariety of operating conditions.1 In such cases, benchtests can also be used to determine broad operatingconditions to allow optimization during additionalbench or possibly larger-scale pilot tests to follow.

Bench-scale testing usually consists of a series oftests, with the results of the previous analysis

determining the next set of conditions to evaluate.The first tests usually cover a broad range of potentialoperating conditions in order to narrow the conditionsfor subsequent tests. For example, pH is the mostimportant parameter for hydroxide precipitation ofheavy metals. An initial “screening” jar test might beperformed in which the pH range is varied from 7through 12 in whole pH units. After finding a minimummetals concentration at pH 9, additional testing couldbe performed at narrower pH intervals around 9. Theinitial screening tests need not be performed to thesame high level of accuracy used in the final tests topredict treatment effectiveness.

1 Bench tests may also be conducted for well-developed anddocumented technologies that are being applied to a newwaste.

Bench-scale testing can usually be performed overa few weeks or months, and the costs are usuallyonly a small portion of the total RI/FS cost.

Bench-scale testing should be performed, asappropriate, to determine the following:

Effectiveness of the treatment alternative on thewaste (note that for some technologies bench-scale testing may not be sufficient to make a finaleffectiveness determination)

Differences in performance between competingmanufacturers (e.g., activated carbon adsorptionisotherms, polymer jar tests)

Differences in performance between alternativechemicals (e.g., alum versus lime versus ferricchloride versus sodium sulfide)

Sizing requirements for pilot-scale studies (e.g.,chemical feed systems)

Screening of technologies to be pilot tested (e.g.,sludge dewatering)

Sizing of those treatment units that wouldsufficiently affect the cost of implementing thetechnology

Compatibility of materials with the waste

The preplanning information needed to prepare forbench-scale treatability testing includes: a wastesampling plan; waste characterization; treatment goals(e.g., how clean or resistant to leaching does thewaste need to be); data requirements for estimatingthe cost of the technology being evaluated (e.g.,sufficient for an order of magnitude cost estimate(i.e., +50/-30 percent)); and information needed forprocurement of equipment and analytical services.

5.3.2 Pilot-Scale Treatability Studies

Pilot studies are intended to simulate the physical aswell as chemical parameters of a full-scale process;therefore, the treatment unit sizes and the volume ofwaste to be processed in pilot systems greatlyincrease over those of bench scale. As such, pilottests are intended to bridge the gap between bench-level analyses and full-scale operation, and areintended to more accurately simulate the performanceof the full-scale process.

Pilot units are designed as small as possible tominimize costs, yet large enough to get the datarequired for scaling up. Pilot units are usually sized to

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minimize the physical and geometric effects of testequipment on treatment performance to simulatefull-scale performance. Examples of these effectsinclude mixing, wall effects, accurate settling data,and generation of sufficient residues (sludges, offgases, etc.) for additional testing (dewatering, fixation,etc.). Pilot units are operated in a manner as similaras possible to the operation of the full-scale system(i.e., if the full-scale system will be operatedcontinuously, then the pilot system would usually beoperated continuously).

In many instances, significant time is required tomake a changeover in operating conditions of a pilotplant and get a reliable result of the change.Therefore, time and budget constraints often limit theability to test a large number of operating conditions.Since pilot tests usually require large volumes ofwaste that may vary in characteristics, considerationshould be given to performing tests on wastes thatare representative of actual site conditions and full-scale operations (e.g., it may be necessary to blendor spike wastes to test all waste characteristicsanticipated at the site and/or to conduct onsite testsusing mobile laboratories).

In addition to the preplanning requirements forbench-scale tests, information needed to prepare fora pilot-scale treatability test includes:

Site information that would affect pilot-testrequirements (i.e., waste characteristics, poweravailability, etc.)

Waste requirements for testing (i.e., volumes,pretreatment, etc.)

Data requirements for technologies to be tested

Because substantial quantities of material may beprocessed in a pilot test and because of themater ial ’s hazardous character ist ics, specialprecautions may be required in handling transport anddisposal of processed waste. It may be necessary toobtain an agreement with a local sewer authority orcognizant State agencies or to obtain an NPDESpermit for offsite discharge of treated effluent. Solidresiduals must be disposed of properly offsite orstored onsite to be addressed as part of the remedialaction.

5.4 Bench Versus Pilot TestingAlternatives involving treatment or destructiontechnologies may require some form of treatabilitytesting, if their use represents first-of-its-kindapplications on unique or heterogeneous wastes.

Once a decision is made to perform treatabilitystudies, the RI/FS contractor and lead agencyremedial project manager will have to decide on the

type of treatability testing to use. This decision mustalways be made taking into account the technologiesunder consideration, performance goals, and sitecharacteristics.

The choice of bench versus pilot testing is affectedby the level of development of the technology. For atechnology that is well developed and tested, benchstudies are often sufficient to evaluate performanceon new wastes. For innovative technologies, however,pilot tests may be required since informationnecessary to conduct full-scale tests is either limitedor nonexistent.

Pilot studies are usually not required for well-developed technologies except when treating a newwaste type or matrix that could affect the physicaloperating characteristics of a treatment unit. Forexample, incineration of fine sands or clay soils in arotary kiln that has been developed for coarser solidscan result in carryover of fine sands into thesecondary combustion chamber.

During the RI/FS process, pilot- scale studies shouldbe limited to situations in which bench-scale testingor field sampling of physical or chemical parametersprovide insufficient information from which to evaluatean alternative (e.g., it is difficult to evaluate the abilityof a rotary kiln incinerator to handle a new wastematrix using a bench-scale test). Pilot-scale testsmay also be required when there is a need toinvestigate secondary effects of the process, such asair emissions, or when treatment residues (sludge, airemissions) are required to test secondary treatmentprocesses.

Because of the time required to design, fabricate, andinstall pilot- scale equipment and to perform tests fora reasonable number of operating conditions,conducting a pilot study can add significant time andcost to the RI/FS. The decision to perform a pilot testshould, therefore, be considered carefully and madeas early in the process as possible to minimizepotential delays to the FS.

To determine the need for pilot testing, the potentialfor improved performance or savings in time ormoney during the implementation of a technologyshould be balanced against the additional time andcost for pilot testing during the RI/FS. Technologiesrequiring pilot testing should also be compared totechnologies that can be implemented without pilottesting. Innovative technologies should be consideredif they offer the potential for more efficient treatment,destruction of the waste, or significant savings in timeor money required to complete a remedial action.

The final decision as to how much treatability testing(or collection of additional data of any kind) should beundertaken involves balancing the value of the

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additional data against increased cost, scheduledelay, and level of allowable uncertainty in theremedy-selection process. Generally, one of thefollowing choices must be made:

Collect more data using treatability testing

Provide additional safety factors in the remedialdesign to accommodate the uncertainties

Proceed with the remedy selection, accepting theu n c e r t a i n t y a n d t h e p o t e n t i a l c o s t a n dperformance consequences

The final decision may be a combination of several ofthese choices. The lead agency’s RPM must basethe decision upon the characteristics of the site, thecost of the studies, and the uncertaint ies ofproceeding without them.

Table 5-2 provides a comparison between benchand pilot studies, and Table 5-3 shows examples ofbench and pilot testing programs.

5.4.1 Testing Considerations

Shipment of substantial volumes of contaminatedmaterial from a site for testing can prove to bedifficult; 2 residual material not consumed in testing willneed to be disposed of safely, and the disposal mustbe adequately documented. Therefore, the volume ofmaterials to be tested offsite should be minimized toavoid related problems.

A second testing consideration is the possibledifficulty of getting a representative sample of wastefor treatability testing. For example, althoughground-water samples collected from monitoringwells during site characterization may be available fortesting treatment technologies, separate extractionwells may need to be used to produce the requiredground- water flow patterns during remedial actions.Consequently, because the characteristics of groundwater from extraction wells may be different frommonitoring wells, representative waste samples maybe unavailable until extraction wells are installed andpumped.

A similar concern arises when trying to obtainrepresentative samples for testing the treatment ofcontaminated soil. Since the soil characteristics willvary both horizontally and vertically on the site it maynot be possible to obtain a sample that fullyrepresents full-scale conditions without blending orspiking.

2 See 40 CFR parts 260 and 261 for specific details ontreatability study sample exemptions.

5.4.2 Data Quality Objectives

The data quality required for analytical results oftreatability tests is a key concern since it greatlyaffects the cost and time required for the analyses.Analytical levels and corresponding levels of qualityare discussed in Chapter 2 of this guidance.

Since the results of bench and pilot studies are usedto support selection of a remedial alternative, resultsof such studies will support the ROD and becomepart of the Administrative Record. Furthermore,results of treatability testing also may be used onother sites with similar characteristics. Therefore,procedures followed in testing should be welldocumented. Sampling and analyses for tests used todevelop predictive results will need to be performedwith the same level of accuracy and care that wasused during the site characterization. Because costand time required for analyses increase significantlywith increased quality, potential savings can bederived by carefully determining the level(s) of dataquality necessary for each analytical level required.

Table 5-4 presents the data quality usually requiredfor the various analyses that may be performedduring treatability investigations. Bench- and pilot-scale testing require some moderate and somehigh-quality data. Sufficient high-quality data areneeded to document treatment performance of thetechnologies considered for further evaluation.

5.5 Treatability Test Work PlanLaboratory testing can be expensive and timeconsuming. A well-written work plan is a necessarydocument if a treatability testing program is to becompleted on time, within budget, and with accurateresults. Preparation of a work plan provides anopportunity to run the test mentally and reviewcomments before starting the test. It also reduces theambiguity of communication between the leadagency’s RPM, the contractor’s project manager, thetechnician performing the test, and the laboratorytechnician performing the analyses on test samples.The treatability test work plan, which may be anamendment to the original work plan, if the need forthe treatability tests was not identified until later in theprocess, or a separate one specifically for this phase.Regardless, the work plan should be reviewed andapproved by the lead agency’s RPM. The RPM andRI/FS contractor should determine the appropriatelevel of detail for the work plan since a detailed planis not always needed and will require time to prepareand approve. In some situations the original work planmay adequately describe the treatability tests and aseparate plan is not required (e.g., the need fortreatability testing can be identified during the scopingphase if existing information is sufficient). Section

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Table 5-2. Bench and Pilot Study Parameters

Parameter Bench Pilot

Purpose Define process kinetics, material Define design and operation criteria,compatibility, impact of environmental materials of construction, ease of materialfactors, types of doses of chemicals, handling and construction, etc.active mechanisms, etc.

Size

Quantity of Waste and MaterialsRequiredNumber of Variables That Can BeConsidered

Time Requirements

Typical Cost Range

Most Frequent Location

Limiting Considerations

Laboratory or bench top

Small to moderate amounts

1-100% of full scale

Relatively large amounts

Many Few (greater site-specificity)

Days to weeks Weeks to months

0.5-2% of capital costs of remedial 2-5% of capital costs of remedialaction action 1

Laboratory Onsite

Wall, boundary and mixing effects; Limited number of variables; large wastevolume effects; solids processing difficult volume required; safety, health, and otherto simulate; transportation of sufficient risks; disposal of process waste materialwaste volume

1 Actual percentage cost of pilot testing will depend significantly on the total cost of the remedial action.

2.3.1 and Appendix B.2 provide additional information are to be taken, which containers are to be used,on work plan preparation. which preservatives, etc.

5.5.1 Bench-Scale Treatability Work Plan

Table 5-5 provides a suggested work plan format forbench-scale testing; the various sections of the’recommended format for the work plan are describedbelow.

Treatability Test Plan - Include the variablecond i t ions tha t a re to be tes ted (e .g . , acombination of 4 pH units and 5 doses of achemical would produce 40 discrete tests [ifreplicated]); include parameters to be measured ifthey vary for different test conditions.

Project Description and Site Background - Brieflydescribe the site and the types, concentrations,and distributions of contaminants of concern(concentrating on those for which the technologyis being considered).

Remedial Technology Description - Give a briefdescription of the technology(ies) to be tested.

Test Objectives - Describe the purpose of thetest, the data that are to be collected from thebench-scale test, and how the data will be usedto evaluate the technology.

Specialized Equipment and Materials - Describeunique equipment or reagents required for thetest.

Experimental Procedures - List specific steps tobe performed in carrying out the bench-scaletest; include volumes to be tested, descriptions ofreactors to be employed, and materials needed(i.e., transfer by graduated cylinder 500 ml ofwaste to a 600 ml borosilicate glass beaker).Specify the accuracy of measurements byspecifying standard laboratory glassware (e.g., agraduated cylinder has 5 percent accuracywhereas a pipet has 1 percent) and how samples

Analytical Methods - The analytical method isdependent on test objectives, technology, waste,and other site factors. Survey available analyticalmethods and select the most appropriate.Describe analytical procedures or cite andreference standard procedures to be employedand define the level of accuracy needed for eachof the analyses (perform initial testing to roughlydetermine optimal operating conditions; and usemoderately accurate analytical techniques orana lyses o f on ly one o r a few ind ica to rcompound(s) to greatly reduce the time and costof these initial tests). After achieving besttreatment, perform more complete and accuratetesting to confirm the earlier results. Most benchtests require results in short order to allow variedtest runs. Bench tests remote from the analyzinglaboratory are difficult; therefore, analyze theduplicate final or check samples by the CLP, ifnecessary.

Data Management - Testing procedures must bewell documented, using bound notebooks,photographs, etc.; provisions need to be made formaking backup copies of critical items of data.Describe the parameters to be measured,accuracy that the results are to be recorded to,and how these are to be recorded. Prepare asample data sheet to be used in the bench test;

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Table 5-3. Examples of Bench- and Pilot-Scale Testing ProgramsRemedial Technology Example Testing Programs

A. Air Pollution and Gas Migration Control1. Capping2. Dust Control3. Vapor Collection and Treatment (carbon adsorption,

air stripping, etc.)

B. Surface Water Controls1. Capping2. Grading3. Revegetation4. Diversion and Collection

Bench: Soil density and bearing capacity vs. moisture contentcurves for proposed capping materials

C. Leachate and Ground-Water Controls1. Containment barriers (slurry walls, grout curtains,

etc.)2. Ground-water pumping (well points, suction wells,

etc.)3. Subsurface collection drains4. Permeable treatment beds (limestone, activated

carbon)5. Capping

D. Direct Waste Control1. Thermal Treatment2. Solidification/Stabilization3. Biological Treatment

Activated sludge Facultative lagoons Trickling filters

4. Chemical Treatment Oxidation/reduction Precipitation Neutralization Ion exchange resins

5. Physical Treatment Carbon adsorption

FlocculationSedimentation

Membrane processesDissolved air flotation

Air strippingWet air oxidation

6. In Situ Treatment Vapor extraction Soil flushing Microbial degradation Neutralization/detoxification Precipi tat ion Ni t r i f i ca t ion

7. Land Disposal (landfill, land application)

E. Soil and Sediment Containment and Removal1. Excavation2. Dredging3. Grading4. Capping5. Revegetation

Pilot: In-place soil densities; determination of gas withdrawalrates to control releases

Bench: Column testing of capping material compatibility withwastes present

Pilot: In-place testing of geotextiles for control of erosion ingrassed diversion ditches

Bench: Determination of basicity and headloss vs. grain size oflimestone materials for a treatment bed; determination ofchemical compatibility of compacted clay with a leachatestream

Pilot: In-place testing of a soil-type and grain-sizespecification and tile-drain configuration for a subsurfacecollection drain

Bench: Characterization of chemical and heat content ofhazardous waste mixes; chemical, physical, and biologicaltreatability studies to define rate constants, minimal-maximalloading rates and retention times, optimal pH and temperature,sludge generation rates and characteristics, and oxygentransfer characteristics; chemical type and dose rates; solidsflux rate vs. solids concentration in sludge thickening systems;air/volume ratios for stripping towers

Pilot: Test burns to determine retention times, combustion-chamber and after-burner temperatures, destruction andremoval efficiency, and fuel requirements for the incineration ofa waste; endurance performance tests on membranes inreverse-osmosis units for ground-water treatment; in situmicrobial-degradation testing of nutrient-dose and aerationrates to support in-place degradation of underground leak;evaluation of in-place mixing procedures for the solidificationof a sludge in a lagoon

Bench: Determination of soil-adsorptive (cation exchangecapacity) properties and chemical composition

Pilot: Small-scale dredging to assess sediment resuspensionor production rates

Table 5-4. Data Quality for Treatability InvestigationsAnalytical Level Field Data

Level II/ Feasibility screeningLevel III

Bench/Pilot Data

Testing to optimize operating conditionsMonitoringPredesign sizing

Level IV/Level V

Enforcement related evaluations and Establish design criteria establishing standards documentingrecommendations of alternatives performance in treatability studies to screen alternatives

include procedures to be employed to ensure thatthe results are protected from loss.

Data Analysis and interpretation - Describe indetail the procedures to be followed to reduce

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Table 5-5. Suggested Format for Bench-Scale WorkPlan

1. Project Description and Site Background2. Remediation Technology Description3. Test Objectives4. Specialized Equipment and Materials5. Laboratory Test Procedures6. Treatability Test Plan Matrix and Parameters to Measure

8.Analytical MethodsData Management

9. Data Analysis and Interpretation10. Health and Safety11. Residuals Management

raw analyt ical data to a form useful forinterpretation. The most helpful are methods ofgraphical interpretation based on known physicalor chemical phenomena or common practice(e.g., plotting concentrations of metal remaining insolution versus pH or chemical dosage).

Health and Safety - Modify the site health andsafety plan as needed to account for wastehandling and onsite testing operations.

Residual Management - Describe the types ofresiduals anticipated and how they will bemanaged.

5.52 Pilot-Scale Treatability Work Plan

Table 5-6 contains a suggested work plan format.Although many of the sections are similar to those ofthe bench-scale work plan format, differencesbetween the two are discussed below.

Table 5-6. Suggested Format for Pilot-Scale WorkPlan

1. Project Description and Site Background2. Remedial Technology Description3. Test Objectives4. Pilot Plant Installation and Startup5. Pilot Plant Operation and Maintenance Procedures6. Parameters to be Tested7. Sampling Plan8. Analytical Methods9. Data Management10. Data Analysis and Interpretation11. Health and Safety12. Residuals Management

Pilot Plant Installation and Startup - For onsitepilot studies, describe the equipment required andmethod to be employed to get the equipmentonsite and installed for the test period.

P i l o t P l a n t O p e r a t i o n a n d M a i n t e n a n c eProcedures - Describe the specific conditionsunder which the pilot test will be conducted. Pilotplants are normally run with relatively largevolumes of waste to simulate full-scale operationand, therefore, waste characteristics usually haveto be measured and operating controls adjusted(e.g., chemical feed rates) to match instructions

for startup and shutdown of the pilot plant. Thesespecif icat ions need to be included in theprocedures list.

Parameters to be Tested - List the operatingconditions under which the pilot units are to betested and the variations in control parametersthat are to be evaluated (e.g., chemical feed ratesor pH set points in a chemical precipitation test,or combustion temperature or gas residence timefor an incinerator test).

Sampling Plan - Describe locations and aschedule for samples to be taken from the pilotplant to determine performance; readings fromin-line instruments, such as pH probes andsampling methods, containers, preservative,labeling, etc., should be included.

Health and Safety Plan - Health and safetyconcerns are more critical during pilot testsbecause larger amounts of waste are involvedand equipment is more complex. Equipmentdesign and construction must comply withapplicable code requirements.

5.6 Application of Results

5.6.1 Data Analysis and Interpretation

Following the completion of the treatability testing,results are reduced to a useful in accordance with thework plan. Data are interpreted on the technology’seffectiveness, implementability, and/or cost, andanticipated results are compared with actual results.Graphical techniques are frequently used to presentthe results. Note that the level of reliability of the testresults is usually based on the accuracy of theanalytical methods employed.

Major differences between the anticipated and actualresults may necessitate a modification of the workplan and retesting of the technology. In addition,raw-waste and effluent characteristics as well asby-products and emissions are evaluated to predictthe ability of a full-scale unit to respond to variationsin waste composit ion and meet performancespecifications.

5.6.2 Use of the Results in the RI/FS Process

The purpose of a treatability evaluation is to provideinformation needed for the detailed analysis ofalternatives and to allow selection of a remedial actionto be made with a reasonable certainty of achievingthe response objectives. All results are useful, evennegative ones, because they can be used to eliminatetechnologies for further consideration. The results ofbench and pilot tests can be used to ensure thatconventional and innovative treatment or destructiontechnologies can be evaluated equally with non-

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treatment alternatives during the detailed analysisphase of the FS. Secondary use of treatability resultsprovides information for the subsequent detaileddesign of the selected remedial technology. Operatingcondi t ions must be careful ly and completelydocumented so that this information can be used inthe full-scale system.

The characteristics of residuals from the remedialtechnology should be determined during pilot testing.This information is useful in determining how theresiduals can be handled or disposed and inpredicting the effects of their disposal or ‘emission.Information can often be collected to determine if theresiduals should be considered hazardous wastes ordisposed of as a non-hazardous waste.

5.6.3 Scaling up to Full-Scale

The study f indings need to be evaluated forapplication of the technology at full-scale; thelimitations of the bench- or pilot-scale test (size,wal l , and boundary effects, etc.) need to becompensated for. Scale-up can be done on thebasis of either previous experience with the treatmentequipment with other wastes or established rules ofsimilitude (used to relate physical laws to variations inscale) and mathematical models. This evaluation mayinclude a sensitivity analysis to identify the keyparameters and unknowns that can affect a full-scale system. The potential need for processmodifications during design or operation must beconsidered.

5.7 Community Relations DuringTreatability Investigations

Treatability testing is potentially controversial within acommunity and, therefore, additional communityrelations activities may be required. An assessment ofissues and concerns the community may have aboutplanned treatability testing should be conducted. Theassessment should augment the previously preparedcommunity relations plan (if treatability testing was notpart of the original work plan) and should include adiscussion of any issues unique to the proposedprocedures such as onsite pilot testing, transportingcontaminated materials offsite, schedule changesresulting from conducting bench or pilot tests,disposal of residuals, uncertainties pertaining toinnovat ive techno log ies , and the degree o fdevelopment of the technology being tested.

Additional community relations implementationactivities may be recommended in the assessmentand may include a public meeting to explain theproposed bench or pilot test, a fact sheet describing

the technology and proposed test, a briefing to publicofficials about the treatability studies, and small groupconsultations with members of the communityconcerned about EPA’s actions at the site. Othercommunity relations activities may be needed, andconsultations between the lead agency’s projectmanager and the community relations coordinatorshould be used to establ ish the appropriatecommunity relations activities.

5.8 Reporting and CommunicationDuring Treatability Investigations

Deliverables for the treatability investigations arelisted in Table 5-7 and include the following:

Revised work plans, as necessary, includingbench and/or pilot tests

Revised QAPP/FSP, as necessary

Test results and evaluation report

Table 5-7. Reporting and Communication DuringTreatability Investigations

Potential Method forInformation Needed Purpose Information Provision

Need for Treatability For lead agency and MeetingTesting contractor to determine Tech Memo

whether more cost andperformance data areneeded to evaluatealternatives and selectremedy; for leadagency to obtainsupport agency reviewand comment

Approval of Site Data Obtain lead agency QAPP (revised)Collection or approval of treatability FSPTreatability Testing activities Treatability Study

Work Plan

The treatability test evaluation report should describethe testing that was performed, the results of thetests, and an interpretation of how the results wouldaffect the evaluation of the remedial alternatives beingconsidered for the site. Effectiveness of the treatmenttechnology for the wastes on the site should bepresented. This report should also contain anevaluation of how the test results would affecttreatment costs developed during the detailedanalysis of alternatives (e.g., chemical requirementsor settling rates required for effective treatment).Because the report may be used as an informationsource by other EPA and contractor staff at othersites with similar characteristics, it should be writtenclearly and concisely.

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CHAPTER 6DETAILED ANALYSIS

OF ALTERNATIVES

6-1

Chapter 6Detailed Analysis of Alternatives

6.1 Introduction

6.1.1 Purpose of the Detailed Analysis ofAlternatives

The detailed analysis of alternatives consists of theanalysis and presentation of the relevant informationneeded to allow decisionmakers to select a siteremedy, not the decisionmaking process itself. Duringthe detailed analysis, each alternative is assessedagainst the evaluation criteria described in thischapter. The results of this assessment are arrayedto compare the alternatives and identify the keytradeoffs among them. This approach to analyzingalternatives is designed to provide decisionmakerswith sufficient information to adequately compare thealternatives, select an appropriate remedy for a site,and demonstrate satisfaction of the CERCLA remedyselection requirements in the ROD.

The specific statutory requirements for remedialactions that must be addressed in the ROD andsupported by the FS report are listed below. Remedialactions must:

l Be pro tec t i ve o f human hea l th and theenvironment

l Attain ARARs (or provide grounds for invoking awaiver)

l Be cost-effective

l Utilize permanent solutions and alternativetreatment technologies or resource recoverytechnologies to the maximum extent practicable

l Satisfy the preference for treatment that reducestoxicity, mobility, or volume as a principal elementor provide an explanation in the ROD as to why itdoes not

In addition, CERCLA places an emphasis onevaluating long-term effectiveness and relatedconsiderations for each of the alternative remediala c t i o n s ( $ 1 2 1 ( b ) ( l ) ( A ) ) . T h e s e s t a t u t o r yconsiderations include:

A) the long-term uncertainties associated with landdisposal;

B) the goals, objectives, and requirements of theSolid Waste Disposal Act:

C) the persistence, toxici ty, and mobil i ty ofhazardous substances and their constituents, andtheir propensity to bioaccumulate;

D) short- and long-term potential for adversehealth effects from human exposure;

E) long-term maintenance costs:

F) the potential for future remedial action costs if thealternative remedial action in question were to fail;and

G) the potential threat to human health and theenv i ronment assoc ia ted w i th excavat ion ,transportation, and redisposal, or containment.

Nine evaluation criteria have been developed toa d d r e s s t h e C E R C L A r e q u i r e m e n t s a n dconsiderations listed above, and to address theadditional technical and policy considerations thathave proven to be important for selecting amongremedial alternatives. These evaluation criteria serveas the basis for conducting the detailed analysesduring the FS and for subsequently selecting anappropriate remedial action. The evaluation criteriawith the associated statutory considerations are:

Overall protection of human health and theenvironment

l Compliance with ARARs (B)

Long- te rm e f fec t i veness and permanence(A,B,C,D,F,G)

l Reduction of toxicity, mobility, or volume (B,C)

l Short-term effectiveness (D,G)

l Implementability

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Cost (E,F)

l State acceptance (relates to Section 121 (f))

l Community acceptance (relates to Sections 113and 117)

6.1.2 The Context of Detailed Analysis

The detailed analysis of alternatives follows thedevelopment and screening of alternatives andprecedes the actual selection of a remedy. Asdiscussed in Chapter 4, the phases of the FS mayoverlap, with one beginning before another iscompleted, or they may vary in the level of detailbased on the complexity or scope of the problem.The extent to which alternatives are analyzed duringthe detailed analysis is influenced by the availabledata, the number and types of alternatives beinganalyzed, and the degree to which alternatives werepreviously analyzed during their development andscreening.

The evaluations conducted during the detailedanalysis phase bui ld on previous evaluat ionsconducted during the development and screening ofalternatives. This phase also incorporates anyt r e a t a b i l i t y s t u d y d a t a a n d a d d i t i o n a l s i t echaracterization information that may have beencollected during the RI.

The results of the detailed analysis provide the basisfor identifying a preferred alternative and preparingthe proposed plan. Upon completion of the detailedanalysis, the FS report, along with the proposed plan(and the RI report if not previously released), issubmitted for public review and comment. The resultsof the detailed analysis supports the final selection ofa remedial action and the foundation for the Recordof Decision.

6 . 1 . 3 Overview of the Detailed Analysis

A detailed analysis of alternatives consists of thefollowing components:

l Further definition of each alternative, if necessary,with respect to the volumes or areas ofcontaminated media to be addressed, thetechnologies to be used, and any performancerequirements associated with those technologies

l An assessment and a summary profile of eachalternative against the evaluation criteria

l A comparative analysis among the alternatives toassess the relat ive performance of eachalternative with respect to each evaluationcriterion

Figure 6-1 illustrates the steps in the detailedanalysis process.

6.2 Detailed Analysis of Alternatives

6.2.1 Alternative DefinitionAlternatives are defined during the development andscreen ing phase (see Chap te r 4 ) to matchcontaminated media with appropriate processoptions.1 However, the alternatives selected as themost promising may need to be better defined duringthe detailed analysis. Each alternative should bereviewed to determine if an additional definition isrequired to apply the evaluation criteria consistentlyand to develop order-of-magnitude cost estimates(i.e., having a desired accuracy of + 50 percent to-30 percent). The information developed to definealternatives at this stage in the RI/FS process mayconsist of preliminary design calculations, processflow diagrams, sizing of key process components,prel iminary si te layouts, and a discussion oflimitations, assumptions, and uncertainties concerningeach alternative. The following examples illustratesituations in which additional alternative definition isappropriate:

l The assumed sizing of the process option mustbe revised on the basis of results of treatabilitydata (e.g., a taller air stripping tower with morepacking is required to attain the treatment target).

l A different process option is to be used torepresent the technology type on the basis of theresults of treatability data (e.g., activated carbonrather than air stripping is required).

l The estimated volume of contaminated media hasbeen refined on the basis of additional sitecharacterization data.

As described in Chapter 4, alternatives can bedeveloped and screened on a medium-specific orsitewide basis at the lead agency’s discretion.Although it is acceptable to continue the evaluation ofalternatives on a medium-specific basis during thedetailed analysis, it is encouraged that alternatives beconfigured to present the decision-maker with arange of discrete options each of which addressesthe entire site or operable unit being addressed bythe FS.2 Therefore, if separate alternatives have beendeveloped for different areas or media of the site, it isrecommended that they be combined during thedetailed analysis phase to present comprehensive

1 This matching is done by identifying specific remedial actionobjectives (e.g., a risk-based cleanup target such as 1x10-s)and sizing process options to attain the objective (e.g., 10ground-water extraction wells extracting 50 gpm each,activated carbon treatment for 500 gpm).

2 This approach will better facilitate and simplify the nine criteriaevaluation and preparation of a rationale for remedy selectionin the Record of Decision.

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Figure 6-1. Detailed analysis of alternatives.

options addressing all potential threats posed by thesite or that area being addressed by the operableunit. This can be accomplished either at thebeginning of the detailed analysis or following theindividual analysis when the alternatives aresummarized and a comparative analysis is performed.

6.2.2 Over view of Evaluation Criteria

The detailed analysis provides the means by whichfacts are assembled and evaluated to develop therationale for a remedy selection. Therefore, it isnecessary to understand the requirements of theremedy selection process to ensure that the FSanalysis provides the sufficient quantity and quality ofinformation to simplify the transition between the FSreport and the actual selection of a remedy. Theanalyt ical process descr ibed here has beendeveloped on the basis of statutory requirements ofCERCLA Section 121 (see Section 6.1.1); earlierprogram initiatives promulgated in the November 20,1985, National Contingency Plan; and site-specific

experience gained in the Super-fund program. Thenine evaluation criteria listed in Section 6.1.1encompass statutory requirements and technical,cost, and institutional considerations the program hasdetermined appropriate for a thorough evaluation.

Assessments against two of the criteria relate directlyto statutory findings that must ultimately be made inthe ROD. Therefore, these are categorized asthreshold criteria in that each alternative must meetthem.3 These two criteria are briefly described below:

l Overall Protection of Human Health and theEnvironment (described in Section 6.2.3.1) - Theassessment against this criterion describes howthe alternative, as a whole, achieves andmaintains protection of human health and theenvironment.

3 The ultimate determination and declaration that these findingscan be made of the selected remedy is contained in the ROD.

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l Compliance with ARARs (described in Section6.2.3.2) - The assessment against this criteriondescribes how the alternative complies withARARs, or if a waiver is required and how it isjustified. The assessment also addresses otherinformation from advisories, criteria, and guidancethat the lead and support agencies have agreed is“to be considered.”

The five criteria listed below are grouped togetherbecause they represent the primary criteria uponwhich the analysis is based.

Long-term Effectiveness and Permanence(described in Section 6.2.3.3) - The assessmentof alternatives against this criterion evaluates thelong-term effect iveness of al ternat ives inmaintaining protection of human health and theenvironment after response objectives have beenmet.

Reduction of Toxicity, Mobility, and VolumeThrough Treatment (described in Section 6.2.3.4)- The assessment against this criterion evaluatesthe anticipated performance of the specifictreatment technologies an alternative mayemploy.

Short-term Effectiveness (described in Section6.2.3.5) - The assessment against this criterionexamines the effectiveness of alternatives inprotecting human health and the environmentduring the construction and implementation of aremedy until response objectives have been met.

Implementability (described in Section 6.2.3.6) -This assessment evaluates the technical andadministrative feasibility of alternatives and theavailability of required goods and services.

Cost (described in Section 6.2.3.7) - Thisassessment evaluates the capital and operationand maintenance (O&M) costs of each alternative.

The level of detail required to analyze each alternativeagainst these evaluation criteria will depend on thetype and complexity of the si te, the type oftechnologies and alternatives being considered, andother project-specific considerations. The analysisshould be conducted in sufficient detail so thatdecisionmakers understand the significant aspects ofeach alternative and any uncertainties associated withthe evaluation (e.g., a cost estimate developed on thebasis of a volume of media that could not be definedprecisely).

The final two criteria, state or support agencyacceptance and community acceptance, will beevaluated following comment on the RI/FS report andthe proposed plan and will be addressed once a finaldecision is being made and the ROD is beingprepared. The criteria are as follows:

l State (Support Agency) Acceptance (described inSection 6.2.3.8) - This assessment reflects thes t a t e ’ s ( o r s u p p o r t a g e n c y ’ s ) a p p a r e n tpreferences among or concerns about alter-natives.

l Community Acceptance (described in Section6 .2 .3 .9 ) - Th is assessment re f lec ts thecommunity’s apparent preferences among orconcerns about alternatives.

Each of the nine evaluation criteria has been furtherdivided into specific factors to allow a thoroughanalysis of the alternatives. These factors are shownin Figure 6-2 and discussed in the fol lowingsections.

6.2.3 Individual Analysis of Alternatives

6.2.3.1 Overall Protection of Human Health andthe Environment

This evaluation criterion provides a final check toassess whether each alternative provides adequateprotection of human health and the environment. Theoverall assessment of protection draws on theassessments conducted under other evaluationcriteria, especially long-term effectiveness andpermanence, shor t - te rm e f fec t i veness , andcompliance with ARARs.

Evaluation of the overall protectiveness of analternative during the RI/FS should focus on whethera specific alternative achieves adequate protectionand should describe how site risks posed througheach pathway being addressed by the FS a r eeliminated, reduced, or controlled through treatment,engineering, or institutional controls. This evaluationalso allows for consideration of whether an alternativeposes any unacceptable short-term or cross-mediaimpacts.

6.2.3.2 Compliance with ARARs

This evaluation criterion is used to determine whethereach alternative will meet all of its Federal and StateARARs (as defined in CERCLA Section 121) thathave been identified in previous stages of the RI/FSprocess. The detailed analysis should summarizewhich requirements are applicable or relevant andappropriate to an alternative4 and describe how thealternative meets these requirements. When anARAR is not met, the basis for justifying one of thesix waivers allowed under CERCLA (see Section1.2.1.1) should be discussed.

4 This effort will require input from the support agency.

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OVERALL PROTECTIONOF HUMAN HEALTH

AND THE ENVIRONMENT

How Alternative Provides HumanHealth and Environmental Protection

LONG-TERMEFFECTIVENESS

AND PERMANENCE

l Magnitude of l Treatment Process Used andResidual Risk Materials Treated

l Adequacy andReliability ofControls

l Amount of HazardousMaterials Destroyed orTreated

l Degree of ExpectedReductions in Toxicity,Mobility, and Volume

l Degree to WhichTreatment Is Irreversible

l Type and Quantity ofResiduals Remaining AfterTreatment

l Compliance With Chemical-SpecificARARs

l Compliance With Action-Specific ARARs

l Compliance With Location-Specific ARARs

l Compliance With Other Criteria, Advisories,and Guidances

SHORT-TERMEFFECTIVENESS

Protection of CommunityDuring Remedial Actions

l Ability to Construct andOperate the Technology

Capitalcosts

l Protection of WorkersDuring Remedial Actions

l Reliability of theTechnology

*Operating andMaintenance Costs

l Environmental Impacts

l Time Until RemedialAction Objectives AreAchieved

l Ease of Undertaking l Present WorthAdditional Remedial costActions, if Necessary

l Ability to Monitor Effective-ness of Remedy

l Ability to ObtainApprovals From OtherAgencies

l Coordination With OtherAgencies

l Availability of OffsiteTreatment, Storage, andDisposal Services andCapacity

l Availability of NecessaryEquipment andSpecialists

l Availability of ProspectiveTechnologies

1 These criteria are assessed following comment on the RI/FS report and the proposed plan.

Figure 6-2. Criteria for detailed analysis of alternatives.

The fol lowing should be addressed for eachalternative during the detailed analysis of ARARs:5

5 Other available information that is not an ARAR (e.g.,advisories, criteria, and guidance) may be considered in theanalysis if it helps to ensure protectiveness or is otherwiseappropriate for use in a specific alternative. These TBCmaterials should be included in the detailed analysis if the leadand support agencies agree that their inclusion is appropriate.

l Compliance with chemical-specific ARARs (e.g.,maximum contaminant levels) - This factoraddresses whether the ARARs can be met, and ifnot, whether a waiver is appropriate.

l Compliance with location-specific ARARs (e.g.,preservation of historic sites) - As with otherA R A R - r e l a t e d f a c t o r s , t h i s i n v o l v e s a

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consideration of whether the ARARs can be metor whether a waiver is appropriate.

l Compliance with action-specific ARARs (e.g.,RCRA minimum technology standards) - It mustbe determined whether ARARs can be met or willbe waived.

The actual determination of which requirements areapplicable or relevant and appropriate is made by thelead agency in consultation with the support agency.A summary of these ARARs and whether they will beattained by a specific alternative should be presentedin an appendix to the RI/FS report. A suggestedformat for this summary is provided in Appendix E ofthis guidance. More detailed guidance on determiningwhether requirements are applicable or relevant andappropriate is provided in the “CERCLA Compliancewith Other Laws Manual” (U.S. EPA, Draft, May1988).

6.2.3.3 Long-term Effectiveness andPermanence

The evaluation of alternatives under this criterionaddresses the results of a remedial action in terms ofthe r isk remaining at the si te after responseobjectives have been met. The primary focus of thisevaluation is the extent and effectiveness of thecontrols that may be required to manage the riskposed by treatment residuals and/or untreatedwastes. The following components of the criterionshould be addressed for each alternative:

l Magnitude of residual risk - This factor assessesthe residual risk remaining from untreated wasteor treatment residuals at the conclusion ofremedial activities, (e.g., after source/soilcontainment and/or treatment are complete, orafter ground-water plume management activitiesare concluded). The potential for this risk may bemeasured by numerical standards such as cancerrisk levels or the volume or concentration ofcontaminants in waste, media, or treatmentr e s i d u a l s r e m a i n i n g o n t h e s i t e . T h echaracteristics of the residuals should beconsidered to the degree that they remainhazardous, taking into account their volume,toxicity, mobility, and propens i ty to b io -accumulate.

l Adequacy and reliability of controls - This factorassesses the adequacy and suitability of controls,if any, that are used to manage treatmentresiduals or untreated wastes that remain at thesite. It may include an assessment of containmentsystems and institutional controls to determine ifthey are sufficient to ensure that any exposure tohuman and environmental receptors is withinprotective levels. This factor also addresses thelong-term reliability of management controls for

providing continued protection from residuals. Itincludes the assessment of the potential need toreplace technical components of the alternative,such as a cap, a slurry wall, or a treatmentsystem; and the potential exposure pathway andthe risks posed should the remedial action needreplacement.

Table 6-1 lists appropriate questions that may needto be addressed during the analysis of long-termeffectiveness.

6.2.3.4 Reduction of Toxicity, Mobility, orVolume Through Treatment

This evaluation criterion addresses the statutorypreference for selecting remedial actions that employtreatment technologies that permanently andsignificantly reduce toxicity, mobility, or volume of thehazardous substances as their principal element. Thispreference is satisfied when treatment is used toreduce the principal threats at a site throughdestruction of toxic contaminants, reduction of thetotal mass of toxic contaminants, irreversiblereduction in contaminant mobility, or reduction of totalvolume of contaminated media.

This evaluation would focus on the following specificfactors for a particular remedial alternative:

l The treatment processes the remedy will employ,and the materials they will treat

l The amount of hazardous materials that will bedestroyed or treated, including how the principalthreat(s) will be addressed

l The degree of expected reduction in toxicity,mobility, or volume measured as a percentage ofreduction (or order of magnitude)

l The degree to which the treatment will beirreversible

l The type and quantity of treatment residuals thatwill remain following treatment

l Whether the alternative would satisfy the statutorypreference for treatment as a principal element6

In evaluating this criterion, an assessment should bemade as to whether treatment is used to reduceprincipal threats, including the extent to which toxicity,mobility, or volume are reduced either alone or in

6 It may be that alternatives for limited actions (e.g., provision ofan alternative water supply) will not address principal threatswithin their narrow scope.

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Table 6-1. Long-Term Effectiveness and PermanenceAnalysis Factor Specific Factor Considerations

Magnitude of residual l What is the magnitude of the remaining risks?risks What remaining sources of risk can be identified? How much is due to treatment residuals. and how

much is due to untreated residual contamination?Will a 5-year review be required?

Adequacy and What is the likelihood that the technologies will meet required process efficiencies or performancereliability of controls specifications?

What type and degree of long-term management is required?What are the requirements for long- term monitoring?What operation and maintenance functions must be performed?What difficulties and uncertainties may be associated with long-term operation and maintenance?What is the potential need for replacement of technical components?What is the magnitude of the threats or risks should the remedial action need replacement?What is the degree of confidence that controls can adequately handle potential problems?What are the uncertainties associated with land disposal of residuals and untreated wastes?

combination. Table 6-2 lists typical questions thatmay need to be addressed during the analysis oftoxicity, mobility, or volume reduction.

6.2.3.5 Short-term EffectivenessThis evaluation criterion addresses the effects of thealternative during the construction and implementationphase until remedial response objectives are met(e.g., a cleanup target has been met). Under thiscriterion, alternatives should be evaluated withrespect to their effects on human health and theenvironment during implementation of the remedialaction. The following factors should be addressed asappropriate for each alternative:

l Protection of the community during remedialactions - This aspect of short-term effectivenessa d d r e s s e s a n y r i s k t h a t r e s u l t s f r o mimplementation of the proposed remedial action,such as dust from excavation, transportation ofhazardous materials, or air-quality impacts froma stripping tower operation that may affect humanhealth.

l Protection of workers during remedial actions -This factor assesses threats that may be posed toworkers and the effectiveness and reliability ofprotective measures that would be taken.

l Environmental impacts - This factor addressesthe potential adverse environmental impacts thatmay result from the construction and imple-mentation of an alternative and evaluates thereliability of the available mitigation measures inpreventing or reducing the potential impacts.

l Time until remedial response objectives areachieved - This factor includes an estimate of thetime required to achieve protection for either the

entire site or individual elements associated withspecific site areas or threats.

Table 6-3 lists appropriate questions that may needto be addressed during the analysis of short-termeffectiveness.

6.2.3.6 Implementability

The implementability criterion addresses the technicaland administrative feasibility of implementing analternative and the availability of various services andmaterials required during its implementation. Thiscriterion involves analysis of the following factors:

l Technical feasibility

- Construction and operation - This relates tothe technical difficulties and unknownsassociated with a technology. This wasinitially identified for specific technologiesduring the development and screening ofalternatives and is addressed again in thedetailed analysis for the alternative as awhole.

- Reliability of technology - This focuses on thelikelihood that technical problems associatedwith implementation will lead to scheduledelays.

- Ease of undertaking additional remedial action- This includes a discussion of what, if any,future remedial actions may need to beundertaken and how difficult it would be toimplement such additional actions. This isparticularly applicable for an FS addressing aninterim action at a site where additionaloperable units may be analyzed at a latertime.

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Table 6-2. Reduction of Toxicity, Mobility, or Volume Through TreatmentAnalysis Factor Specific Factor Considerations

Treatment process and Does the treatment process employed address the principal threats?remedy Are there any special requirements for the treatment process?

Amount of hazardousmaterial destroyed or treated

What portion (mass, volume) of contaminated material is destroyed?What portion (mass, volume) of contaminated material is treated?

Reduction in toxicity, To what extent is the total mass of toxic contaminants reduced?mobility, or volume To what extent is the mobility of toxic contaminants reduced?

To what extent is the volume of toxic contaminants reduced?

Irreversibility of the To what extent are the effects of treatment irreversible?treatment

Type and quantity of What residuals remain?treatment residual What are their quantities and characteristics?

What risks do treatment residuals pose?

Statutory preference Are principal threats within the scope of the action?for treatment as a Is treatment used to reduce inherent hazards posed by principal threats at the site?principal element

Table 6-3. Short-Term Effectiveness

Analysis Factor Basis for Evaluation During Detailed Analysis

Protection of What are the risks to the community during remedial actions that must be addressed?community duringremedial actions

How will the risks to the community be addressed and mitigated?What risks remain to the community that cannot be readily controlled?

Protection of workers What are the risks to the workers that must be addressed?during remedial What risks remain to the workers that cannot be readily controlled?actions How will the risks to the workers be addressed and mitigated?

Environmental What environmental impacts are expected with the construction and implementation of theimpacts alternative?

What are the available mitigation measures to be used and what is their reliability to minimizepotential impacts?What are the impacts that cannot be avoided should the alternative be implemented?

Time until remedial How long until protection against the threats being addressed by the specific action is achieved?response objectives are achieved

How long until any remaining site threats will be addressed?How long until remedial response objectives are achieved?

- Monitoring considerations - This addressesthe ability to monitor the effectiveness of theremedy and includes an evaluation of therisks of exposure should monitoring beinsufficient to detect a system failure.

l Administrative feasibility

- Activities needed to coordinate with otheroffices and agencies (e.g., obtaining permitsfor offsite activities or rights-of-way forconstruction)

l Availability of services and materials 6.2.3.7 Cost

- Availability of adequate offsite treatment,storage capacity, and disposal services

- Availability of necessary equipment andspecialists, and provisions to ensure anynecessary additional resources

- Availability of services and materials, plus thepotential for obtaining competitive bids, whichmay be particularly important for innovativetechnologies

- Availability of prospective technologies

Table 6-4 lists typical questions that may need to beaddressed during the analysis of implementability.

A comprehensive discussion of costing proceduresfor CERCLA sites is contained in the Remedial Action

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Table 6-4. ImplementabilityAnalysis Factor

Technical FeasibilitySpecific Factor Considerations

Ability to construct andoperate technology

Reliability of technology

Ease of undertaking additionalremedial action, if necessary

Monitoring considerations

Administrative Feasibility

Coordination with otheragencies

Availability of Services andMaterials

Availability oftreatment, storage capacity,and disposal services

Availability of necessaryequipment and specialists

Availability of prospectivetechnologies

What difficulties may be associated with construction?What uncertainties are related to construction?

What steps are required to coordinate with other agencies?What steps are required to set up long-term or future coordination among agencies?Can permits for offsite activities be obtained if required?

What is the likelihood that technical problems will lead to schedule delays?

What likely future remedial actions may be anticipated?How difficult would it be to implement the additional remedial actions, if required?

Do migration or exposure pathways exist that cannot be monitored adequately?What risks of exposure exist should monitoring be insufficient to detect failure?

Are adequate treatment, storage capacity, and disposal services available?How much additional capacity is necessary?Does the lack of capacity prevent implementation?What additional provisions are required to ensure the needed additional capacity?

Are the necessary equipment and specialists available?What additional equipment and specialists are required?Does the lack of equipment and specialists prevent implementation?What additional provisions are required to ensure the needed equipment andspecialists?

Are technologies under consideration generally available and sufficiently demonstratedfor the specific application?Will technologies require further development before they can be applied full-scale tothe type of waste at the site?When should the technology be available for full-scale use?Will more than one vendor be available to provide a competitive bid?

Costing Procedures Manual (U.S. EPA, September1985). The application of cost estimates to thedetailed analysis is discussed in the followingparagraphs.

Capital Costs. Capital costs consist of direct(construction) and indirect (nonconstruction andoverhead) costs. Direct costs include expenditures forthe equipment, labor, and materials necessary toinstall remedial actions. Indirect costs includeexpenditures for engineering, financial, and otherservices that are not part of actual installationactivities but are required to complete the installationof remedial alternatives. (Sales taxes normally do notapply to Superfund actions.) Costs that must beincurred in the future as part of the remedial actionalternative should be identified and noted for the yearin which they will occur. The distribution of costs overtime will be a critical factor in making tradeoffsbetween capital-intensive technologies (includingalternative treatment and destruction technologies)

and less capital-intensive technologies (such aspump and treatment systems).

Direct capital costs may include the following:

Construction costs - Costs of materials, labor andequipment required to install a remedial action

Equipment costs - Costs of remedial action andservice equipment necessary to enact the remedy(these materials remain until the site remedy iscomplete)

Land and site-development costs - Expensesassociated with the purchase of land and the sitepreparation costs of existing property

Buildings and services costs - Costs of processand nonprocess buildings, utility connections,purchased services, and disposal costs

Relocation expenses - Costs of temporary orpermanent accommodations for affected nearby

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residents. (Since cost estimates for relocationscan be complicated, FEMA authorities and EPAHeadquarters should be consulted in estimatingthese costs.)

Disposal costs - Costs of transporting anddisposing of waste material such as drums andcontaminated soils

Indirect capital costs may include:

Engineering expenses - Costs of administration,design, construction supervision, drafting, andtreatability testing

License or permit costs - Administrative andtechnical costs necessary to obtain licenses andpermits for installation and operation of offsiteactivities

Startup and shakedown costs - Costs incurred toensure system is operational and functional

Contingency allowances - Funds to cover costsresulting from unforeseen circumstances, such asadverse weather cond i t ions , s t r i kes , o rc o n t a m i n a n t n o t d e t e c t e d d u r i n g s i t echaracterization

Annual O&M Costs. Annual O&M costs are post-construction costs necessary to ensure the continuedeffectiveness of a remedial action. The followingannual O&M cost components should be considered:

Operating labor costs - Wages, salaries, training,overhead, and fringe benefits associated with thelabor needed for post-construction operations

Maintenance materials and labor costs - Costs forlabor, parts, and other resources required forroutine maintenance of facilities and equipment

Auxiliary materials and energy - Costs of suchitems as chemicals and electricity for treatmentplant operations, water and sewer services, andfuel

Disposal of residues - Costs to treat or disposeof residuals such as sludges from treatmentprocesses or spent activated carbon

Purchased services - Sampling costs, laboratoryfees, and professional fees for which the needcan be predicted

Administrative costs - Costs associated with theadministration of remedial O&M not includedunder other categories

Insurance, taxes, and licensing costs - Costs ofsuch items as liability and sudden accidental

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insurance; real estate taxes on purchased land orrights-of-way; l i cens ing fees fo r ce r ta intechnologies: and permit renewal and reportingcosts

Maintenance reserve and contingency funds -Annual payments into escrow funds to covercosts of anticipated replacement or rebuilding ofequipment and any large unanticipated O&Mcosts

Rehabilitation costs - Cost for maintainingequipment or structures that wear out over time

Costs of periodic site reviews - Costs for sitereviews that are conducted at least every 5 yearsif wastes above health-based levels remain atthe site

The costs of potential future remedial actions shouldbe addressed, and if appropriate, should be includedwhen there is a reasonable expectation that a majorcomponent of the alternative will fail and requirereplacement to prevent significant exposure tocontaminants. Analyses described under Section6.2.3.3, “Long-term Effectiveness and Perma-nence,” should be used to determine whichalternatives may result in future costs. It is notexpected that a detailed statistical analysis will berequired to identify probable future costs. Rather,qualitative engineering judgment should be used andthe rationale documented in the FS report.

Accuracy of Cost Estimates. Site characterization andtreatability investigation information should permit theuser to refine cost estimates for remedial actionalternatives. It is important to consider the accuracyof costs developed for alternatives in the FS.Typically, these “study estimate” costs made duringthe FS are expected to provide an accuracy of + 50percent to -30 percent and are prepared using dataavailable from the RI. It should be indicated when it isnot realistic to achieve this level of accuracy.

Present Worth Analysis. A present worth analysis isused to evaluate expenditures that occur overdifferent time periods by discounting all future coststo a common base year, usually the current year.This allows the cost of remedial action alternatives tobe compared on the basis of a single figurerepresenting the amount of money that, if invested inthe base year and disbursed as needed, would besufficient to cover all costs associated with theremedial action over its planned life.

In conduct ing the present wor th ana lys is ,assumptions must be made regarding the discountrate and the period of performance. The Superfundprogram recommends that a discount rate of 5percent before taxes and after inflation be assumed.Estimates of costs in each of the planning years are

made in constant dollars, representing the generalpurchasing power at the time of construction. Ingeneral, the period of performance for costingpurposes should not exceed 30 years for the purposeof the detailed analysis.

Cost Sensitivity Analysis. After the present worth ofeach remedial action alternative is calculated,individual costs may be evaluated through asensitivity analysis if there is sufficient uncertaintyconcerning specific assumptions. A sensitivityanalysis assesses the effect that variations in specificassumptions a s s o c i a t e d w i t h t h e d e s i g n ,implementation, operation, discount rate, and effectivelife of an alternative can have on the estimated costof the alternative. These assumptions depend on theaccuracy of the data developed during the sitecharacterization and treatability investigation and onpredictions of the future behavior of the technology.Therefore, these assumptions are subject to varyingdegrees of uncertainty from site to site. The potentialeffect on the cost of an alternative because of theseuncertainties can be observed by varying theassumptions and noting the effects on estimatedcosts. Sensitivity analyses can also be used tooptimize the design of a remedial action alternative,p a r t i c u l a r l y w h e n d e s i g n p a r a m e t e r s a r einterdependent (e.g., treatment plant capacity forcontaminated ground water and the length of theperiod of performance).

Use of sensitivity analyses should be considered forthe factors that can significantly change overall costsof an alternative with only small changes in theirvalues, especially if the factors have a high degree ofuncertainty associated with them. Other factorschosen for analysis may include those factors forwhich the expected (or estimated) value is highlyuncertain. The results of such an analysis can beused to identify worst-case scenarios and to reviseestimates of contingency or reserve funds.

The following factors are potential candidates forconsideration in conducting a sensitivity analysis:

The effective life of a remedial action

The O&M costs

The duration of cleanup

The volume of contaminated material, given theuncertainty about site conditions

Other design parameters (e.g., the size of thetreatment system)

The discount rate (5 percent should be used tocompare alternative costs, however, a range of 3to 10 percent can be used to invest igateuncertainties)

The results of a sensitivity analysis’ should bediscussed during the comparison of alternatives.Areas of uncertainty that may have a significant effecton the cost of an alternative should be highlighted,and a rationale should be presented for selection ofthe most probable value of the parameter.

6.2.3.8 State (Support Agency) AcceptanceThis assessment evaluates the technical andadministrative issues and concerns the state (orsupport agency in the case of State-lead sites) mayhave regarding each of the alternatives. As discussedearlier, this criterion will be addressed in the RODonce comments on the RI/FS report and proposedplan have been received.

6.2.3.9 Community AcceptanceThis assessment evaluates the issues and concernsthe publ ic may have regarding each of thealternatives. As with state acceptance, this criterionwill be addressed in the ROD once comments on theRI/FS report and proposed plan have been received.

6.2.4 Presentation of Individual Analysis

The analysis of individual alternatives with respect tothe specified criteria should be presented in the FSreport as a narrative discussion accompanied by asummary table. This information will be used tocompare the alternatives and support a subsequentanalysis of the alternatives made by the decision-maker in the remedy selection process. The narrativediscussion should, for each alternative, provide (1) adescription of the alternative and (2) a discussion ofthe individual criteria assessment.

The alternative description should provide data ontechno logy components (use o f innova t ivetechnologies should be identified), quantities ofhazardous materials handled, time required forimplementation, process sizing, implementationrequirements, and assumptions. These descriptions,by clearly articulating the various waste managementstrategies for each alternative, will also serve as thebasis for documenting the rationale of the applicabilityor relevance and appropriateness of potential Federaland State requirements. Therefore, the significantARARs for each alternative should be identified andintegrated into these discussions.

The narrative discussion of the analysis should, foreach alternative, present the assessment of thealternat ive against each of the cr i ter ia.7 T h i sdiscussion should focus on how, and to what extent,the various factors within each of the criteria are

7 As noted previously, State and community acceptance will beaddressed in the ROD once comments have been received onthe RI/FS report and proposed plan.

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addressed .8 The uncertainties associated withspecific alternatives should be included whenchanges in assumptions or unknown conditions couldaffect the analysis (e.g., the time to attain ground-water cleanup targets may be twice as long asestimated if assumptions made about aquifercharacteristics for a specific ground-water extractionalternative are incorrect.) An example of an individualanalysis is presented in Appendix F.

The FS also should include a summary tablehighlighting the assessment of each alternative withrespect to each of the nine criteria. Appendix Fprovides an example of such a summary table.

6.2.5 Comparative Analysis of Alternatives

Once the alternatives have been described andindividual ly assessed against the cri ter ia, acomparative analysis should be conducted to evaluatethe relative performance of each alternative in relationto each specific evaluation criterion. This is incontrast to the preceding analysis in which eachalternative was analyzed independently without aconsideration of other alternatives. The purpose ofthis comparative analysis is to identify the advantagesand disadvantages of each alternative relative to oneanother so that the key tradeoffs the decisionmakermust balance can be identified.

Overal l protect ion of human heal th and theenvironment and compliance with ARARs willgenerally serve as threshold determinations in thatthey must be met by any alternative in order for it tobe eligible for selection. The next five criteria (long-term effectiveness and permanence; reduction oftoxicity, mobility, and volume through treatment;short-term effectiveness; implementability; and cost)will generally require the most discussion because themajor tradeoffs among alternatives will mostfrequently relate to one or more of these five.

State and community acceptance will be addressed inthe ROD once formal comments on the RI/FS reportand the proposed plan have been received and a finalremedy selection decision is being made.

6.2.6 Presentation of Comparative Analysis

The comparative analysis should include a narrativediscussion describing the strengths and weaknessesof the alternatives relative to one another with respectto each criterion, and how reasonable variations of

8 The factors presented in Tables 6-1 through 6-4 have beenincluded to illustrate typical concerns that may need to beaddressed during the detailed analysis. It will not be necessaryor appropriate in all situations to address every factor in thesetables for each alternative being evaluated. Under somecircumstances, it may be useful to address other factors notpresented in these tables to ensure a better understanding ofhow an alternative performs with respect to a particular criterion.

key uncertainties could change the expectations oftheir relative performance. An effective way oforganizing this section is, under each individualcriterion, to discuss the alternative(s) that performsthe best overal l in that category, with otheralternatives discussed in the relative order in whichthey perform. If innovative technologies are beingconsidered, their potential advantages in cost orperformance and the degree of uncertainty in theirexpected performance (as compared with moredemonstrated technologies) should also bediscussed. Appendix F provides an example of acomparative analysis.

The presentation of differences among alternativescan be measured either qualitatively or quantitatively,as appropriate, and should identify substantivedifferences (e.g., greater short-term effectivenessconcerns, greater cost, etc.). Quantitative informationthat was used to assess the alternatives (e.g.,specific cost estimates, time until response objectiveswould be obtained, and levels of residual con-tamination) should be included in these discussions.

6.3 Post-RI/FS Selection of thePreferred Alternative

Following completion of the RI/FS, the results of thedetailed analyses, when combined with the riskmanagement judgments made by the decision-maker, become the rationale for selecting a preferredalternative and preparing the proposed plan.Therefore, the results of the detailed analysis, ormore specifically the comparative analysis, shouldserve to highlight the relative advantages anddisadvantages of each alternative so that the keytradeoffs can be identified. It will be these keytradeoffs coupled with risk management decisionsthat will serve as the basis for the rationale andprovide a transition between the RI/FS report and thedevelopment of a proposed plan (and ultimately aROD). Specific guidance for preparing proposedplans and RODS is provided in the draft guidance onpreparing Superfund decision documents.

6.4 Community Relations DuringDetailed Analysis

Site-specific community relations activities should beidentified in the community relations plan preparedpreviously. While appropriate modifications ofactivities may be made to the community relationsplan as the project progresses, the plan shouldgenerally be implemented as written to ensure thatthe community is informed of the alternatives beingevaluated and is provided a reasonable opportunity toprovide input to the decision-making process.

Often, a fact sheet is prepared that summarizes thefeasible alternatives being evaluated. As appropriate,small group consultations or public meetings may be

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held to discuss community concerns and explainalternatives under consideration. Public officials

6.5 Reporting and Communicationshould be briefed and press releases prepared

During Detailed Analysisdescribing the alternatives: Other activities ‘identifiedin the community relations plan should be imple-

Once the draft RI/FS report is prepared, the leadagency obtains the support agency’s review and

mented. concurrence, the public’s review and comment, and

The objective of community relations during thedetailed analysis is to assist the community inunderstanding the alternatives and the specificconsiderations the lead agency must take intoaccount in selecting an alternative. In this way, thecommunity is prepared to provide meaningful inputduring the upcoming public comment period.

Table 6-5. Suggested FS Report Format

local agency and PRP input, if appropriate. The RI/FSreport also provides a basis for remedy selection byEPA (or concurrence on State and Federal facilityremedy) and documents the development andanalysis of alternatives. A suggested FS report formatis given in Table 6-5.

Executive Summary1. Introduction

1.1 Purpose and Organization of Report1.2 Background Information (Summarized from RI Report)

1.2.1 Site Description1.2.2 Site History1.2.3 Nature and Extent of Contamination1.2.4 Contaminant Fate and Transport1.2.5 Baseline Risk Assessment

2. Identification and Screening of Technologies2.1 Introduction2.2 Remedial Action Objectives -

Presents the development of remedial action objectives for each medium of interest (i.e., ground water, soil, surfacewater, air, etc.). For each medium, the following should be discussed:- Contaminants of interest- Allowable exposure based on risk assessment (including ARARs)- Development of remediation goals

2.3 General Response Actions -For each medium of interest, describes the estimation of areas or volumes to which treatment, containment, or

exposure technologies may be applied.2.4 Identification and Screening of Technology Types and Process Options - For each medium of interest, describes:

2.4.1 Identification and Screening of Technologies2.4.2 Evaluation of Technologies and Selection of Representative Technologies

3. Development and Screening of Alternatives3.1 Development of Alternatives -

Describes rationale for combination of technologies/media into alternatives. Note: This discussion may be by mediumor for the site as a whole.

3.2 Screening of Alternatives (if conducted)3.2.1 Introduction3.2.2 Alternative 1

3.2.2.1 Description3.2.2.2 Evaluation

3.2.3 Alternative 23.2.3.1 Description3.2.3.2 Evaluation

3.2.4 Alternative 34. Detailed Analysis of Alternatives

4.1 Introduction4.2 Individual Analysis of Alternatives

4.2.1 Alternative 14.2.1.1 Description4.2.1.2 Assessment

4.2.2 Alternative 24.2.2.1 Description4.2.2.2 Assessment

4.2.3 Alternative 34.3 Comparative Analysis

BibliographyAppendices

6 - 1 5

Bibliography

American National Standards Institute. 1980.American Nat ional Standard, Pract ices forRespiratory Protection. ANSI Z88.2, 1980k. ANSI,New York.

Ford, P.J., P.J. Turina, and D.E. Seely. 1983.Characterization of Hazardous Waste Sites - AMethods Manual. Volume II - Available SamplingMethods. EPA Report No. 600/4-83-040. NTISNo. PB 84-126920. U.S. EPA, Las Vegas.

National Fire Protection Association. 1981. NationalF i r e C o d e s . V o l u m e s l - 1 6 . Q u i n c y ,Massachusetts.

National Institute for Occupational Safety and Health.1985. Guidance Manual for Superfund Activities.Volumes 1-9. U.S. Department of Health andHuman Services, National Institute for OccupationalSafety and Health, Cincinnati, Ohio.

U.S. EPA. April 1985. Characterization of HazardousWaste Sites - A Methods Manual. Volume II.EPA/600/4-841075.

U.S. EPA. May 1985. Guidance Document forCleanup of Surface Tanks and Drums. OSWERDirective No. 9380.0-3.

U.S. EPA. May 1985. Guidance on RemedialInvestigations Under CERCLA. EPA, OSWER,HWERL; EPA Report #540/6-85/002; NTIS Ref#PB-85-268616; OSWER Direct ive 9355.0-06B. U.S. EPA, Cincinnati, Ohio.

U.S. EPA. June 1985. Guidance on FeasibilityStudies Under CERCLA. EPA, OSWER, OWPE;EPA Report #540/G-85/003; NTIS Ref #PB-85-238-590; OSWER Directive 9355.0-05C. U.S.EPA, Washington, D.C.

U.S. EPA. June 1985. NEIC Policies and Procedures.Revised. EPA-33019-78-001-R.

National Institute for Occupational Safety and Health.1978. NIOSH/OSHA Pocket Guide to Chemical

U.S. EPA. September 1985. Remedial Action Costing

Hazards. NIOSH Publication No. 78-210. NationalP r o c e d u r e s M a n u a l . W a s h i n g t o n , D . C .

Institute for Occupational Safety and Health andEPA/OERR/HSCD; EPA Report #600/8-87/049;

Occupational Safety and Health Administration,OSWER Directive 9355.0-10.

U.S. Government Printing Office, Washington, D.C.

National Institute for Occupational Safety and Health.

U.S. EPA. November 1985. Chemical EmergencyPreparedness Program: Interim Guidance. OSWERDirective No. 9223.0-1A.

Printing Office, Washington, D.C.

1981. Occupational Health Guidelines for ChemicalHazards. DHHS (NIOSH) Publication No. 81-123.Superintendent of Documents, U.S. Government

9285.5-01. U.S. EPA, Washington, D.C.

U.S. EPA. January 1986. Superfund ExposureAssessment Manual. Draft. OSWER Directive

NIOSH/OSHA/USCG/USEPA. 1985. OccupationalSafety and Health Guidance Manual for HazardousWaste Site Activities. U.S. DHHS.

U.S. EPA. 1979. Safety Manual for Hazardous WasteSite Investigations. Nat ional EnforcementInvestigations Center, Washington, D.C.

U.S. EPA. September 1982. Interim StandardOperating Safety Guides. Hazardous ResponseSupport Division, Office of Emergency andRemedial Response, Washington, D.C.

U.S. EPA. October 1986. Superfund Public HealthEvaluation Manual (SPHEM). EPA/540/1-86/060,O S W E R D i r e c t i v e 9 2 8 5 . 4 - l . U . S . E P A ,Washington, D.C.

U.S. EPA. December 1986. Superfund Federal-LeadRemedial Project Management Handbook. OSWERDirective No. 9355.1-l.

U.S. EPA. December 1986. Superfund InnovativeTechnology Evaluation (SITE) Strategy andProgram Plan. OSWER Directive No. 9380.2-3.

U.S. EPA. December 1986. Superfund State-LeadRemedial Project Management Handbook.EPA/OERR/HSCD, EPA Report #540/G-87/001,O S W E R D i r e c t i v e 9 3 5 5 . 2 - 0 1 . U . S . E P A ,Washington, D.C.

U.S. EPA. December 1986. User’s Guide to theContract Laboratory Program.

U.S. EPA. March 1987. Data Qualify Objectives forRemedial Response Activities. OSWER Directive9335.0-7B. (Also called DQO Guidance.) U.S.EPA, Washington, D.C.

U.S. EPA. March 1987. Guidance for CoordinatingATSDR Health Assessment Activities with theSuperfund Remedial Process. OSWER DirectiveNo. 9285.4-02.

U.S. EPA. September 1987. Compend ium o fSuperfund Field Operations Methods. OSWERDirective 9355.0-14, EPA/540/P-87/00/a (alsocalled Compendium).

U.S. EPA. March 1988. Draft Guidance on PreparingSuperfund Decision Documents. OSWER Directive9355.3-02.

U.S. EPA. May 1988. CERCLA Compliance withOther Laws Manual. Draft. OSWER Directive9234.1-01. U.S. EPA, Washington, D.C.

U.S. EPA. June 1988. Community Relations inSuperfund: A Handbook. Interim. OSWER Directive9230.0-3A.

U.S. EPA. June 1988. “ Inter im Guidance onAdministrative Records for Selection of CERCLAResponse Actions.” Draft. OSWER Directive No.9833.3A.

U.S. EPA. August 1988. Guidance on RemedialActions for Contaminated Ground Water atSuperfund Sites, Draft. OSWER Directive No.9283.1-2.

U.S. EPA. September 1988. Guidance on Preparationof Superfund Memorandum of Agreement. OSWERDirective No. 9375.0-01.

U.S. EPA. September 1988. Technology ScreeningGuide for Treatment of CERCLA Soils andSludges. EPA/540/2-88/004.

U.S. EPA. Apri l 1988. S u p e r f u n d E x p o s u r eAssessment Manual. OSWER Directive No.9285.5-1.

U.S. EPA. CLP Invitation for Bids.

U.S. EPA. Functional Guidelines for EvaluatingOrganic Analyses. (EPA 69-01-6699.)

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Appendix AInterim Guidance on PRP Participation in the RI/FS Process*

I. Introduction

This memorandum sets forth the pol icy andprocedures governing the participation of potentiallyresponsible parties (PRPs) in the development ofremedial investigations (RI) and feasibility studies (FS)under the Comprehensive Environmental Response,

Compensation, and Liability Act (CERCLA), asamended by the Superfund Amendments andReauthor iza t ion Ac t (SARA) o f 1986. Th ismemorandum discusses:

The initiation of enforcement activities includingPRP searches and PRP notification;

The circumstances in which PRPs may conductthe RI/FS;

The development of enforceable agreementsgoverning PRP RI/FS activities;

Initiation of PRP RI/FS activities and oversight ofthe RI/FS by EPA;

EPA control over PRP RI/FS activities; and

PRP participation in Agency-financed RI/FSactivities.

More detailed information regarding each of the abovetopics is included in Attachments l -4 of thisappendix.

This document is consistent with CERCLA and EPAguidance in effect as of October 1988, and isin tended to supersede the March 20 , 1984memorandum from Assistant Administrators Lee M.Thomas and Courtney M. Price entitled “Participationof Potentially Responsible Parties in Development ofRemedial Investigations and Feasibility Studies UnderCERCLA” (OSWER Directive No. 9835.1). Users ofthis guidance should consult the RI/FS Guidance orany relevant guidance or policies issued afterdistribution of this document before establishing

* This memorandum was signed by the AA OSWER andreleased for distribution on May 16, 1988. Technicalclarifications/updates have been made to this guidance forinsertion into Appendix A of the “Interim Final Guidance forConducting Remedial Investigations and Feasibility Studies”(October 1988-OSWER Directive No. 9355.3-01) (Referredto herein as the RI/FS Guidance).

EPA/PRP responsibilities for conducting RI/FSactivities. Additional guidance regarding proceduresfor EPA oversight activities will be available in theOffice of Waste Program Enforcement’s (OWPE)forthcoming “Guidance Manual on Oversight ofPotentially Responsible Party Remedial Investigationand Feasibility Studies”.

II. BackgroundSections 104/122 of CERCLA provide PRPs with theopportunity to conduct the RI/FS when EPAdetermines (1) that the PRPs are qualified to conductsuch activities and (2) they will carry out the activitiesin accordance with CERCLA requirements and EPAprocedures. 1 The Agency will continue its policy ofearly and timely PRP searches as well as early PRPnotification and negotiation for RI/FS activities.

It is also the policy of EPA to encourage the early andactive participation of PRPs in conducting RI/FSactivities. EPA believes that early participation ofPRPs in the remedial process will encourage PRPimplementation of the selected remedy. PRPparticipation in RI/FS activities will ensure that theyhave a better and more complete understanding ofthe selected remedy, and thus will be more likely toagree on implementation of the remedy. Remedialactivities performed by PRPs will also conserve Fundmonies, thus making additional resources available toaddress other sites.

As part of the Agency’s effort to encourage PRPparticipation in remedial activities, EPA will considerthe PRPs’ role in conducting RI/FS activities whenassessing an overall settlement proposal for theremedial design and remedial action. For example,when the Agency performs a non-binding allocationof responsibility (NBAR), the Agency may considerprevious PRP efforts and cooperation. This willprovide an additional incentive for PRPs to becooperative in conducting RI/FS activities.

1 The legal authority to enter into agreements with PRPs isfound in CERCLA Section 122(a). This section then refers toresponse actions conducted pursuant to Section 104(b). Forthe purposes of this guidance, Sections 104/122 will be citedwhen referring to such authority.

Although EPA encourages PRP participation inconducting the RI/FS, the Agency and CERCLAimpose certain conditions governing their partici-pation. These conditions are intended to assure thatthe RI/FS performed by the PRPs is consistent withFederal requirements and that there is adequateoversight of those activities. These conditions arediscussed both in Section Ill and Attachment I of thismemorandum.

At the discretion of EPA, a PRP (or group of PRPs)may assume full responsibility for undertaking RI/FSactivities pursuant to Sections 104/122 of CERCLA.The terms and conditions governing the RI/FSactivities should be specified in an AdministrativeOrder. The use of Administrative Orders is authorizedin CERCLA Section 122(d)(3); they are the preferredtype of agreement for RI/FS activities since they areauthorized internally and therefore, may be negotiatedmore quickly than Consent Decrees. Before SARA,Administrat ive Orders were signed using theauthor i t ies of Sect ion 106 of CERCLA. Newprovisions in SARA allow for Orders to be signedusing the authorities of Sections 1041122; Section104/122 Orders do not require EPA to make a findingof imminent and substantial endangerment.

RI/FS activities developed subsequent to theAdministrative Order are set forth in a Statement ofWork, which is then embodied or incorporated byreference into the Order. A Work Plan describingdetailed procedures and criteria by which the RI/FSwill be performed is developed by the PRPs and, afterapproval by EPA, should also be incorporated byreference into the Administrative Order.

It is the responsibility of the lead agency to ensurethe qual i ty of the effort i f the PRPs assumeresponsibility for conducting the RI/FS. Therefore,EPA will establish oversight procedures and projectcontrols to ensure that the response actions arec o n s i s t e n t w i t h C E R C L A a n d t h e N a t i o n a lContingency Plan (NCP). Section 104(a)(1) ofCERCLA mandates that no PRP be allowed toundertake an RI/FS unless EPA determines that theparty(ies) conducting the RI/FS is qualified to do so.In addition, Section 104(a)(l) requires that a qualifiedparty be contracted with or arranged for to assist inoverseeing and reviewing the conduct of the RI/FSand, that the PRPs agree to reimburse EPA for thecosts associated with the oversight contract orarrangement.

III. Initiation of Enforcement ActivitiesAs part of effective management of enforcementactivities, timely settlements for RI/FS activities are tobe pursued. This includes conducting PRP searchesearly in the site discovery process and subsequentnotification to all PRPs of their potential liability and oftheir opportunity to perform response activities.

Guidance on conducting timely and effective PRPsearches is contained in the guidance manual,"Potentially Responsible Party Search Manual"(August 17, 1987 - OSWER Directive No. 9834.6).

EPA policy has been to notify PRPs of their potentialliability for the planned response activities, toexchange information about the site, and to providePRPs with an opportunity to undertake or finance theresponse activities themselves. In the past this hasbeen accomplished by issuing a “general notice”letter to the PRPs. In addition to the use of thegeneral notice letter, Section 122(e) of CERCLA nowauthorizes EPA to use “special notice” procedures,which for an RI/FS, establish a 60 to 90 daymoratorium and formal negotiation period. Thepurpose of the moratorium is to provide time forformal negotiation between EPA and the PRPs forconduct of RI/FS activities. In particular, use of thespecial not ice procedures tr iggers a 60 daymoratorium on EPA conduct of the RI/FS. During the60 day moratorium, if the PRPs provide EPA with a“good faith offer” to conduct or finance the RI/FS, thenegotiation period can be extended to a total of 90days. EPA considers a good faith offer to be a writtenproposal where the PRPs make a showing of theirqualifications and willingness to conduct or financethe RI/FS. Minor deficiencies in the PRPs’ initialsubmittals should not be grounds for a determinationthat the offer is not a good faith offer or that thePRPs are unable to perform the RI/FS.

To facilitate, among other things, PRP participation inthe RI/FS process, Section 122(e)( 1) requires thespecial notice letter to provide the names andaddresses of other PRPs, the volume and nature ofsubstances contributed by each PRP, and a rankingby volume of substances at the site, to the extent thisinformation is available at the time of special notice.Regions are encouraged to release this information toPRPs when the notice letters are issued. To expeditesettlements, Regions are also encouraged to givePRPs as much guidance as possible concerning theRI/FS process. It is appropriate to transmit to PRPscopies of important guidance documents such as theRI/FS Guidance, as well as model AdministrativeOrders and S ta tements o f Work . A mode lA d m i n i s t r a t i v e O r d e r c a n b e f o u n d i n t h ememorandum from Gene Lucero entitled, “ModelCERCLA Section 106 Consent Order for an RI/FS”(January 31, 1985 - OSWER Directive No. 9835.5).This model order is currently being revised to reflectSARA requirements and will be forthcoming. A modelStatement of Work has been included as Appendix Cto the RI/FS Guidance, while a model Statement ofWork for PRP-lead RI/FSs is currently beingd e v e l o p e d b y O W P E . O t h e r R e g i o n a l a n dHeadquarters guidance relating to technical issuesmay be given to PRPs, as well as examples of projectplans (plans that must be developed prior to theconduct of the RI/FS) that are of high quality. A

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description of the required project plans is included inAttachment II.

Although use of the special notice procedures isdiscretionary, Regions are encouraged to use theseprocedures in the majority of cases. If EPA decidesnot to employ the special not ice proceduresdescribed in Section 122(e), the Agency will notify thePRPs in writing of such a decision, including anexplanation as to why EPA believes the use of thespecial notice procedures is inappropriate. Additionalinformation on the content of special notice letters,including the use of these notice provisions, can befound in the memorandum entitled “Interim Guidanceon Notice Letters, Negotiations, and InformationExchange” (October 19, 1987 - OSWER DirectiveNo. 9834.10).

Section 121 (f)( 1) requires that the State be notified ofPRP negotiations and that an opportunity for Stateparticipation in such negotiations be provided. Inaddition, Section 12 2(j)(l) requires that if a release orthreat of release at the site in question may haveresulted in damages to natural resources, EPA mustnotify the appropriate Federal or State Trustee andprovide an opportunity for the Trustee to participate inthe negotiations. To simplify the notification of FederalTrustees, the Agency intends to provide a list ofp r o j e c t s i n t h e S u p e r f u n d C o m p r e h e n s i v eAccomplishments Plan (SCAP) to the Trustees asnotice to participate in the negotiations. In thosecases where there is reason to believe that asignificant natural resource will be affected, directcoordination with the Federal and/or State Trustee willbe required.

IV. Conditions for EPA Involvement in,and PRP Initiation of, RI/FS Activities

Under Section 104(a)( 1) EPA may authorize PRPs toconduct RI/FS activities at any site, provided thePRPs can do so promptly and properly and can meetthe conditions specified by EPA for conducting theRI/FS. These conditions are discussed in AttachmentI of this appendix and involve the scope of activities,the organization of the PRPs, and the PRPs’ (andtheir contractors’) demonstrated expertise. EPAencourages PRPs to conduct the RI/FS provided thatthe PRPs commit in an Order (or Consent Decree)under CERCLA Sections 104/122 (or Sections106/122 for a Decree) to conduct a complete RI/FS tothe satisfaction of EPA, under EPA oversight.2

Oversight of RI/FS activities by the lead agency isrequired by Section 104(a)(l) and is intended toassure that the RI/FS is adequate for lead agency

2 For a State-lead enforcement site the State is responsible foroversight unless otherwise specified in the agreement betweenthe State and EPA. EPA should maintain communication withthe State to ensure that the State is providing oversight of theremedial activities.

identification of an appropriate remedy, and that it willotherwise meet the Agency requirements of CERCLA,the NCP, and relevant Agency guidance. EPA willallow PRPs to conduct RI/FS activities and willprovide review and oversight under the followinggeneral circumstances.

EPA’s priority is to address those NPL sites that havebeen identified on the SCAP. The SCAP is an EPAmanagement plan which ident i f ies si te- andactivity-specific Superfund financial allocations foreach quarter of the current fiscal year. Whenemploying Section 122(e) notice procedures, EPA willnotify PRPs of its intention to conduct RI/FS activitiesat NPL sites in a manner that allows at least 90 daysnotice before obligating the funds necessary tocomplete the RI/FS (see Section Ill of this guidance).During this time frame PRPs may elect to conduct theRI/FS, under the review and oversight of EPA. If thePRPs agree to conduct the RI/FS they must meet theconditions discussed in Attachment I. The scope andterms for conducting the studies are embodied in anAgreement; as mentioned in Section II, AdministrativeOrders are the preferred type of Agreement for RI/FSactivities.

EPA will not engage in lengthy discussions with PRPsover whether the PRPs will conduct the RI/FS; rather,EPA will adhere to the time frames established by theSection 122 special notice provisions. In mostinstances, once Fund resources have been obligatedto conduct the RI/FS, the PRPs will no longer beeligible to conduct the RI/FS activities at the site.

The actions described below are typically taken toinitiate RI/FS activities:

EPA develops a site-specific Statement of Work(SOW) in advance of the scheduled RI/FS start.This SOW is then provided to the PRPs alongwith a draft of the Administrative Order (orConsent Decree) at the initiation of negotiations.(PRPs may, with EPA approval, submit a singlesite plan that incorporates the elements of anSOW and a detailed Work Plan as a firstdeliverable once the Agreement has been signed.This combined site plan must clearly set forth thescope of the proposed RI/FS and would beincorporated into the Agreement in place of theSOW.)

Final provisions of the SOW are negotiated withthe Order.

EPA determines whether the PRPs possess thenecessary capabilities to conduct an RI/FS in at ime ly and e f fec t i ve manner (conduc tedsimultaneously with other negotiations).

EPA develops a Community Relations Planspecifying any activities that may be required of

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the PRPs. (Community relations activities arediscussed in Attachment II.)

EPA determines contractor and staff resourcesrequired for oversight and initiates planning thenecessary oversight requirements. This processmay include preparing a Statement of Work, if acontractor is to develop an “oversight plan.”

EPA and PRPs ident i fy and procure anynecessary assistance.

PRPs submit a Work Plan to EPA for Agencyreview and approval. The Work Plan must presentthe methodology and rationale for conducting theRI/FS as well as detailed procedures andrequirements, if such procedures have not beenset forth in the Agreement. This Work Plan, whichin most instances is one of the first deliverablesunder the Order, is commonly incorporated intothe Agreement following EPA approval.

PRPs are responsible for obtaining access to thesite; however, if access cannot be obtained, EPA,with the assistance of DOJ, will secure accesssubject to PRP reimbursement for the costsincurred in securing such access.

These standardized actions ensure that the scope ofthe RI/FS activities to be conducted by the PRPs, andthe procedures by which the RI/FS is performed, areconsistent with EPA policy and guidance. Additionalactions may be required either for a technicallycomplex site or for a site where a number of PRPsare involved. Regardless of the circumstances, theactions listed in this section should be negotiated asexpeditiously as possible. Specific elements of theseactions are discussed in Attachment II.

V. Development of the RI/FSAdministrative Order or ConsentDecree

The PRPs must respond to EPA’s notice letter byeither declining, within the t ime specif ied, toparticipate in the RI/FS, or by offering a good faithproposal to EPA for performing the RI/FS. Decliningto participate in the RI/FS may be implied if the PRPsdo not negotiate during the moratorium established bythe notice letter. If the PRPs have declined toparticipate, or the time specified has lapsed, EPA willobligate funds for performing the RI/FS. If a good faithproposal is submitted, EPA will negotiate with thePRPs on the scope and terms for conducting theRI/FS.

The results of successful negotiations will, in mostcases, be contained in an Administrative Order, orwhere the site is in litigation, in a Judicial ConsentDecree entered into pursuant to Section 122(d) ofCERCLA. Guidance for the development of an

Administrat ive Order is provided in OWPE’sdocument “Administrative Order: Workshop andGuidance Materials” (September 1984), and in thememorandum from Gene Lucero entitled “ModelCERCLA Section 106 Consent Order for an RI/FS”(January 31, 1985). (The latter guidance is currentlybeing revised since the provisions in SARA allow forOrders to be signed using the authorities of Sections104/122.)

An Administrative Order (or Consent Decree) willgenerally contain the scope of activities to beperformed (either as a Statement of Work or WorkPlan), the oversight roles and responsibilities, andenforcement options that may be exercised in theevent of noncompl iance (such as st ipulatedpenalties). In addition to the above, the Agreementwill typically include the following elements, as agreedupon by EPA, the PRPs, and other signatories to theAgreement.

Jurisdiction - Describes EPA’s authority to enterinto Administrative Orders or Consent Decrees.

Parties bound - Descr ibes to whom theAgreement applies and is binding upon.

Purpose - Describes the purpose of theAgreement in terms of mutual objectives andpublic benefit.

Findings of fact, determination, and conclusionsof law - Provides an outline of facts upon whichthe Agreement is based, including the fact thatPRPs are not subject to a lesser standard ofliability and will not receive preferential treatmentfrom the Agency in conducting the RI/FS.

Notice to the State - Verifies that the State hasbeen notified of pending site activities.

Work to be performed - Provides that PRPssubmit project plans to the lead-agency forreview and approval before commencing RI/FSactivities. Project plans are those plans developedin order to effectively conduct the RI/FS projectand include: a Work Plan, describing themethodology, rationale, and schedule of all tasksto be performed during the RI/FS; a Sampling andAnalysis Plan, describing the field samplingprocedures to be performed as well as the qualityassurance procedures which will be followed forsampling and analysis (including a description ofhow the data gathered during the RI/FS will bemanaged) and the analytical procedures to beemployed; and a Health and Safety Plandescribing health and safety precautions to beexercised while onsite. (More information on thecontents of these project plans can be found inAttachment II of this appendix.)

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Compliance with CERCLA, the NCP, andRelevant Agency Guidance - Specifies that theactions at a site will comply with the requirementsof CERCLA, the NCP, and relevant Agencyguidance determined to be appropriate for siteremediation.

Reimbursement of costs - Specifies that PRPswill assume all costs of performing the workrequired by the Agreement. In addition, thissection commits PRPs to reimbursement of costsassociated with oversight activities. This includesreimbursement for qualified party assistance inoversight, as required by Section 104(a)(l). Thissection should also specify the nature and kind ofcost documentation to be provided and theprocess for billing and receiving payment.

Reporting - Specifies the type and frequency ofreporting that PRPs must provide to EPA.Normally the reporting requirements will, at aminimum, include the required project plans aswell as those deliverables required by the RI/FSGuidance. Additional reporting requirements areleft to the discretion of the Regions. That is,Regions may require additional deliverables suchas interim reports on particular RI or FS activities.

Designated EPA, State, and PRP projectcoordinators - Specifies that EPA, the State, andPRPs shall each designate a project coordinator.

Site access and data availability - Stipulates thatPRPs shall allow access to the site by EPA, theState, and oversight personnel. Access will beprovided for inspection and monitoring purposesthat in any way pertain to the work undertakenpursuant to the Order. In addition, access will beprovided in the event of project takeover. Thissection also stipulates that EPA will be providedwith all currently available data.

Record preservation - Specifies that all recordsmust be maintained by both parties for aminimum of 6 years after termination of theAgreement, followed by a provision requiringPRPs to offer the site records to EPA beforedestruction.

Administrative record requirements - Providesthat all information upon which the selection ofremedy is based must be submitted to EPA infu l f i l lmen t o f the admin is t ra t i ve recordrequirements pursuant to Sect ion 113 ofCERCLA. (Additional information on administrativerecord requirements is contained in AttachmentIll.)

Dispute resolution - Specifies steps to be taken ifa dispute occurs. The Administrative Order states

that with respect to all submittals and workperformed, EPA will be the final arbiter, while thecourt is the final arbiter for a Consent Decree.(More information on dispute resolution can befound in Attachment IV of this appendix.)

Delay in performance/stipulated penalties -Specifies EPA’s authority to invoke stipulatedpenalties for noncompliance with Order or Decreeprovisions. Section 121 of CERCLA requires thatConsent Decrees contain provisions for penaltiesin an amount not to exceed $25,000 per day. Inaddition to stipulated penalties, Section 122(l)provides that Section 109 civil penalties apply forviolations of Administrative Orders and ConsentDecrees. Delays that endanger public healthand/or the environment may result in terminationof the Agreement and EPA takeover of the RI/FS.(More information on stipulated penalties can befound in the Of f i ce o f En fo rcement andCompliance Monitoring’s (OECM) “Guidance onthe Use of Stipulated Penalties in HazardousWaste Consent Decrees” (September 21, 1987)and in Attachment IV of this appendix.)

Financial assurance - Specifies that PRPs shouldhave adequate financial resources or insurancecoverage to address liabilities resulting from theirRI/FS activities. When using contractors, PRPsshould certify that the contractors have adequateinsurance coverage or that contractor liabilitiesare indemnified.

Reservation of rights - States that PRPs are notreleased from all CERCLA liability throughcompliance with the Agreement, or completion ofthe RI/FS. PRPs may be released from liabilityrelating directly to RI/FS requirements, if PRPscomplete the RI/FS activities to the satisfaction ofEPA.

Other claims - Provides that nothing in theAgreement shall constitute a release from anyclaim or liability other than, perhaps, for the costof the RI/FS, if completed to EPA satisfaction.Also provides that nothing in the Agreement shallconstitute preauthorization of a claim against theFund under CERCLA. This section should alsospecify the conditions for indemnification of theU.S. Government.

Subsequent modifications/additional work -Specifies that the PRPs are committed to performany additional work or subsequent modificationswhich are not explicitly stated in the Work Plan, ifEPA determines that such work is needed toenable the selection of an appropriate responseaction. (Attachment IV contains additionalinformation on this clause.)

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VI. Statement of Work and Work PlanBased upon available models and guidance, theRegion should present to the PRPs at the initiation ofnegotiations a Statement of Work (SOW) and draftAdministrative Order. The SOW describes the broadobjectives and general activities to be undertaken inthe RI/FS. (The PRPs may develop the SOW if it isdetermined to be appropriate for a particular case.)Once the PRPs receive the SOW they develop amore de ta i l ed Work P lan , wh ich shou ld beincorporated by reference into the Order followingEPA approval. The Work Plan expands the tasksdescribed in the SOW and presents the rationale andmethodology (including detailed procedures andschedules) for conducting the RI/FS. It should benoted that EPA, rather than the PRPs, may developthe work plan in the event of unusual circumstances.

VII. Review and Oversight of the RI/FSTo ensure that the RI/FS conforms to the NCP andthe requirements of CERCLA, including Sections104(a)( 1) and 121, EPA will review and oversee PRPactivities. Oversight is also required to ensure that theRI/FS will result in sufficient information to allow forremedy selection by the lead agency.

The oversight activities that EPA, the State, and otheroversight personnel will be performing should bedetermined prior to the initiation of the RI/FS.Different mechanisms will be used for the review andoversight of different PRP products and activities.These mechanisms, and corresponding PRPactivities, should be determined and if possibleincorporated in the Order. Generally, the followingoversight activities should be specified:

Review of plans, reports, and records;

Oversight of field activities (including maintenanceof records and documentation);

Meetings; and

Special studies.

Section 104(a)(l) requires that the President contractwith or arrange for a “qualified person” to assist inthe oversight and review of the conduct of the RI/FS.EPA believes that qualified persons, for the purposesof overseeing RI/FS activities, are those firms orindividuals with the professional qualifications,expertise, and experience necessary to provideassurance that the Agency is conducting meaningfuland effective oversight of PRP activities. In thiscontext, the qualified person generally will be eitheran ARCS, TES, or REM contractor. EPA employees,employees of other Federal agencies, Stateemployees, or any other qualified person EPA

determines to be appropriate however, may be askedto perform the necessary oversight functions.

As part of the Section 104 requirements, PRPs arerequired to reimburse EPA for qualified partyoversight costs. It is Agency policy to recover allresponse costs at a site including all costs associatedwith oversight. Additional guidance on oversight andproject control activities is presented in AttachmentsIll and IV, respectively.

VI I I. Control of ActivitiesEPA will usually not intervene in a PRP RI/FS ifactivities are conducted in conformance with theconditions and terms specified by the Order. Whendeficiencies are detected, EPA will take immediatesteps to correct the PRP activities. Deficiencies willbe corrected through the use of the followingactivities: (1) identification of the deficiency; (2)demand for corrective measures; (3) use of disputeresolution mechanisms, where appropriate; (4)imposition of penalties; and if necessary, (5) PRPRI/FS termination and project takeover or judicialenforcement. These activities are described in detailin Attachment IV of this appendix.

IX. PRP Participation in Agency-Financed RI/FS Activities

PRPs that elect not to perform the RI/FS should beallowed an opportunity for involvement in a Fund-financed RI/FS. Private parties may possess technicalexpertise or knowledge about a site which would beuseful in developing a sound RI/FS. Involvement byPRPs in the development of a Fund-financed RI/FSmay also expedite remediation by identifying andsatisfactorily resolving differences between theAgency and private parties.

Section 113(k)(2)(B) requires that interested persons,including PRPs, be provided an opportunity forparticipation in the development of the administrativerecord. PRP participation may include the submittal ofinformation, relevant to the selection of remedy, forinclusion in the record and/or the review of recordcontents and submittal of comments on suchcontents.

The extent of additional PRP involvement will be leftto the discretion of the Region and may includeactivities such as:

Access to the site to observe sampling andanalysis activities;

Access to validated data and draft reports.

With respect to PRP access to a site, it is within theRegions’ discretion to impose conditions based on

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safety and other relevant considerations. To theextent that the Region determines that access isappropriate under the circumstances, PRPs mustreimburse EPA for all identifiable costs incurred withthe connection of the accesses afforded the PRPs,and must execute appropriate releases in favor of theEPA and its contractors. With respect to providingdata, it should be noted that the Region is required toallow private citizens access to the same informationthat is provided to the PRPs. The Regions mustthere fo re take th is in to cons idera t ion whendetermining the extent of the PRP’s involvement in aFund-financed RI/FS.

Aside from participation in the administrative record,which is a statutory requirement, the final decisionwhether to permit PRPs to participate in otheraspects of the Fund-financed RI/FS (as well as the

scope of any participation) rests with the Regions.This decision should be based on the ability of PRPsto organize themselves so that they can participate asa single entity, and the ability of PRPs to participatewithout undue interference with or delay in completionof the RI/FS, and other factors that the Regionsdetermine are relevant. The Region may terminatePRP par t ic ipa t ion in RI /FS deve lopment i funnecessary expenses or delays occur.

X. ContactFor further information on the subject matterdiscussed in this interim guidance, please contactSusan Cange (FTS 475-9805) of the Guidance andOversight Branch, Off ice of Waste ProgramEnforcement.

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Attachment IConditions for PRP Conduct of the RI/FS

Organization and ManagementWhen several potentially responsible parties areinvolved at a site they must be able to organizethemselves quickly into a single representative bodyto negotiate with EPA. To facilitate this negotiationprocess, EPA will make available the names andaddresses of other PRPs, in accordance with thesettlement provisions of CERCLA Section 122(e).Either a single PRP or an organized group of PRPsmay assume responsibility for development of theRI/FS.

Scope of ActivitiesAs part of the negotiation process PRPs must agreeto follow the site-specific Statement of Work (SOW)as the basis for conducting an RI/FS. PRPs arerequired to submit an RI/FS Work Plan setting forthdetai led procedures and tasks necessary toaccomplish the RI/FS activities described in the SOW.EPA may approve reasonable modifications to theSOW and will reject any requests for modificationsthat are not consistent with CERCLA (as amended bySARA), the NCP, the requirements set forth in thisguidance document, the RI/FS Guidance, or otherrelevant CERCLA guidance documents.

Demonstrated Capabilities

PRPs must demonstrate to EPA that they possess, orare able to obtain, the technical expertise necessaryto perform all relevant activities identified in the SOW,and any amendments that may be reasonablyanticipated to that document. In addition, PRPs mustdemonstrate that they possess the managerialexpertise and have developed a management plansufficient to ensure that the proposed activities will beproperly controlled and efficiently implemented. PRPsmust also demonstrate that they possess the financialcapability to conduct and complete the RI/FS in atimely and effective manner. These capabilities arediscussed briefly below.

Demonstrated Technical Capability

PRPs should be required to demonstrate thetechnical capabilities of key personnel involved inexecuting the project. Personnel qualifications may be

demonstrated by submitting resumes and references.PRPs may demonstrate the capabilities of the firmthat will perform the work by outlining their past areasof business, relevant projects and experience, andoverall familiarity with the types of activities to beperformed as part of the remedial investigation andfeasibility study.

It is important that qualified firms be retained forperforming RI/FS activities. Firms that do not have thenecessary expertise for performing RI/FS studies maycreate unnecessary delays in the project and maycreate situations which further endanger public healthor the environment. These situations may be createdwhen PRP contractors submit insufficient projectplans, submit deficient reports, or perform inadequatefield work. Furthermore, excessive Agency oversightmay be required in the event that an unqualifiedcontractor performs the RI/FS; the Agency may haveto significantly increase its workload by providingrepeated reviews of project plans, reports, andoversight of field activities.

The PRPs must also demonstrate the technicalcapabilities of the laboratory chosen to do theanalysis of samples collected during the RI/FS. If anon-CLP laboratory is selected, EPA may require asubmission from the laboratory which provides acomprehensive statement of the laboratories’personnel qualifications, equipment specifications,security measures, and any other material necessaryto prove the laboratory is qualified to conduct thework.

Demonstrated Management Capability

PRPs must demonstrate that they have theadministrative capabilities necessary for conductingthe RI/FS in a responsible and timely manner. Amanagement plan should be submitted to EPA eitherduring negotiations or as a part of the Work Planw h i c h i n c l u d e s a d i s c u s s i o n o f r o l e s a n dresponsibilities of key personnel. This managementplan should include an RI/FS team organization chartdescribing responsibilities and lines of authority.Positions and responsibilities should be clearly relatedto technical and managerial qualifications. The PRPsshould also demonstrate an understanding of effectivecommunications, information management, quality

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assurance, and quality control systems. PRPs usuallyprocure the services of consultants to conduct therequired RI/FS activities. The consultants mustdemonstrate, in addition to those requirements statedabove, effective contract management capabilities.

Demonstrated Financial Capability

The PRPs should develop a comprehensive andreasonable estimate of the total cost of anticipatedRI/FS activities. EPA will decide on a case-by-casebasis if the PRPs will be required to demonstrate thatthey have the necessary financial resources availableand committed to conduct the RI/FS activities. Theresources estimated should be adequate to cover theanticipated costs for the RI/FS as well as the costsfor oversight, plus a margin for unexpected expenses.If, during the conduct of the RI/FS the net worth ofthe financial mechanism providing funding for theRI/FS is reduced to less than that required tocomplete the remaining activities, the PRPs shouldimmediately notify EPA. Under conditions specified inthe Order, PRPs are required to complete the RI/FS

irregardless of initial cost estimates or financialmechanisms.

Assistance for PRP Activities

If PRPs propose to use consultants for conducting orassisting in the RI/FS, the PRPs should specify thetasks to be conducted by the consultants and submitpersonnel and corporate qualifications of the pro-posed firms to the EPA for review. Verification shouldbe made that the PRPs’ consultants have no conflictof interest with respect to the project. Any consultantshaving current EPA assignments as prime contractorsor as subcontractors must obtain approval from theirEPA Contract Officers before performing work forPRPs. Lack of clarification on possible conflicts ofinterest may delay the PRP RI/FS. EPA will reservethe right to review the PRPs’ proposed selection ofconsultants and will disapprove their selection if, inEPA’s opinion, they either do not possess adequatetechnical capabilities or there exists a conflict ofinterest. It should be noted that the responsibility forselection of consultants rests with the PRPs.

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Attachment IIInitiation of PRP RI/FS Activities

Development of the Statement of Work

After the PRPs have been identified in the PRPSearch Report they are sent either a general noticeletter followed by a special notice letter or a generalnotice letter followed by an explanation pursuant toSection 122(a) why special notice procedures are notbeing used. EPA will engage in negotiations withthose PRPs who have submitted a good faith offer inresponse to the notice letter and therefore havevolunteered to perform the RI/FS. While the PRPs aredemonstrating their capabilities for conducting theRI /FS, EPA wi l l negot ia te the te rms o f theAdministrative Order. Either an acceptable Statementof Work or Work Plan must be incorporated byreference into the Agreement.

The Statement of Work (SOW) is typically developedby EPA and describes, in a comprehensive manner,all RI/FS activities to be performed, as reasonablyanticipated, prior to the onset of the project. TheSOW focuses on broad objectives and describesgeneral activities that will be undertaken to achievethese objectives. Detailed procedures by which thework will be accomplished are not presented in theSOW, but are described in the subsequent Work Planthat is developed by the PRPs. In certain instances,with the approval of EPA, PRPs may prepare a singlesite plan incorporating the elements of an SOW and aWork Plan. In such instances, the site plan will beincorporated into the Order in place of the broaders o w .

Use of the EPA Model SOW

EPA has developed a model SOW defining acomprehensive RI/FS effort which is contained in theRI/FS Guidance. Additionally, a model SOW for aPRP-lead RI/FS is being developed by OWPE andwill be forthcoming. The Regions should develop asite-specific SOW based upon the model(s). RI/FSprojects managed by PRPs will involve, at aminimum, all relevant activities set forth in the EPAmodel SOW. Further, all plans and reports identifiedas deliverables in the EPA model SOW must beidentified as deliverables in the site-specific SOWand/or the Work Plan developed by the PRPs.Additional deliverables may be required by the

Regions and should be added to the AdministrativeOrder.

Modification of the EPA Draft SOW Requirements

The activities set forth in the model SOW areconsidered by EPA to be the critical RI/FS activitiesthat are required by the NCP. PRPs should presentdetailed justifications for any proposed modificationsand amendments to the activities set forth in theSOW. EPA will review all proposed modifications andapprove or disapprove their inclusion in the SOWbased on available information, EPA policy andguidance, overall program objectives, and therequirements of the NCP and CERCLA. EPA will notallow modifications that, in the judgment of theAgency, will lead to an unsatisfactory RI/FS orinconsistencies with the NCP.

Review of the RI/FS Project Plans

RI/FS project plans include those plans developed forthe RI/FS. At a minimum the project plans shouldinclude a Work Plan, a Sampling and Analysis Plan, aHealth and Safety Plan, and a Community RelationsPlan. The Community Relations Plan is developed byEPA and should include a description of the PRPs’role in community relations activities, if any. EPAreview and approval of the work plan and samplingand analysis plan will usually be required before PRPscan begin site activities. An example when limitedproject activities may be initiated prior to approval ofthe project plans would be if additional information isrequired to complete the Sampling and Analysis Plan.Additionally, conditional approvals to the Work Planand Sampling and Analysis Plan may be provided inorder to initiate field activities in a more timelymanner. It should be noted that EPA does not“approve” the PRPs’ Health and Safety Plan butrather, it is reviewed to ensure the protection of publichealth and the environment. The PRPs may berequired to amend the plan if EPA determines that itdoes not adequately provide for such protection.

Contents of the Work Plan

The Work Plan expands the tasks of the SOW, andthe responsibilities specified in the Agreement, bypresenting the rationale and methodology (including

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detailed procedures) for conducting the RI/FS.Typically the Work Plan is developed after the draftOrder and then incorporated into the Agreement. Insome cases however, it may be appropriate for EPAto develop the Work Plan prior to actual negotiationwith the PRPs and attach the plan to the draftAgreement. The PRP RI/FS Work Plan must beconsistent with current EPA guidance. Guidance ondeveloping acceptable Work Plans is available in theRI/FS Guidance. Addit ional guidance wi l l beforthcoming in the proposed NCP. Once the WorkPlan is approved by EPA, it becomes a publicdocument and by the terms of the Agreement, shouldbe incorporated by reference into that document. TheWork Plan should, at a minimum, contain thefollowing elements.

Inroduction/Background Statement - PRPs shouldprovide an introductory or background statementdescribing their understanding of the work to beperformed at the site. This should includehistorical site information and should highlightpresent site conditions.

Objectives - A statement of what is to beaccomplished and how the information will beutilized.

Scope - A detailed description of the work to beperformed including a definition of work limits.

Management Plan - A description of the projectmanagement showing personnel with authority andresponsibility for the appropriate aspects of theproject and specific tasks to be performed. Asingle person should be identified as having

overall responsibility for the project.

Work Schedule - A statement outlining theschedule for each of the required activities. Thiscould be presented in the form of a Gantt ormilestone chart. The schedule in the Work Planmust match that in the draft Order.

Deliverables - A description of the work productsthat will be submitted and their schedule fordelivery. The schedule should include specificdates, if possible. Otherwise, the schedule shouldbe in terms of the number of days/week afterapproval of the work plan.

Contents of the Sampling and Analysis Plan.

A Sampling and Analysis Plan (SAP) must besubmitted by the PRPs before initiation of relevantfield activities. This plan contains two separateelements: a Field Sampling Plan and a QualityAssurance Project Plan. These documents werepreviously submitted as separate deliverables, but arenow combined into one document. Though the SAPs typically implemented by PRP contractors, it is the

responsibility of the PRPs to ensure that the goalsand standards of the plan are met. (Verification thatthe goals and standards of the SAP are met will alsobe part of EPA’s oversight responsibilities.) The SAPshould contain the following elements:

Field Sampling Plan - The Field Sampling Planincludes a detailed description of all RI/FSsampling and analytical activities that will beperformed. These activities should be consistentwith the NCP and relevant CERCLA guidance.Further guidance on developing Field SamplingPlans is presented in the RI/FS Guidance.

Quality Assurance Project Plan - The SAP mustinclude a detai led descr ipt ion of qual i tyassurance/quality control (QAQC) procedures tobe employed during the RI/FS. This section isintended to ensure that the RI/FS is based on thecorrect level or extent of sampling and analysisrequired to produce sufficient data for evaluatingremedial alternatives for a specific site. A secondobjective is to ensure the quality of the datacol lected during the RI/FS. Guidance onappropriate QAQC procedures may be found inthe RI/FS Guidance as well as “Data QualityObjectives for the RI/FS Process” (March 1987 -OSWER Directive No. 9355.0-7B).

If the SAP modifies any procedures established inrelevant guidance, it must provide an explanation andjustification for the change.

Other Project Plans

Other project plans that are likely to be required in theRI/FS process include the Health and Safety Plan andthe Community Relations Plan.

Health and Safety Plan - PRPs should include aHealth and Safety Plan either as part of the WorkPlan or as a separate document. The Health andSafety Plan should address the measures takenby the PRPs to ensure that all activities will beconducted in an environmentally safe manner forthe workers and the surrounding community. EPAreviews the Health and Safety Plan to ensureprotection of public health and the environment.EPA does not, however, “approve” this plan.Guidance on the appropriate contents of a Healthand Safety Plan may be found in the RI/FSGuidance. In addit ion, Health and Safetyrequirements are found in “OSHA Safety andHealth Standards: Hazardous Waste Operationsand Emergency Response” (40 CFR Part1910.120).

Community Relations Plan - EPA must prepare aCommunity Relations Plan for each NPL site. Theextent of PRP involvement in community relationsactivities should be detailed in this plan. Additional

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information on Community Relations activities iscontained below.

Review and Approval

PRPs must submit all of the required RI/FS projectplans (with the exception of the Community RelationsPlan which is developed by EPA) to EPA for review,and in the case of the Work Plan and SAP, approval.EPA will review the plans for their technical validityand consistency with the NCP and relevant EPAguidance. Typically, the Agency must review andapprove these plans before PRPs can begin any siteactivities. Any disagreements that arise between EPAand PRPs over the contents of the plans should beresolved according to the procedures set forth in thedispute resolution section of the relevant EPA/PRPAgreement.

Community Relations

EPA is responsible for developing and implementingan effective community relations program, regardlessof whether RI/FS activities are Fund-financed orconducted by PRPs. At State-lead enforcementsites, funded by EPA under Superfund Memoranda ofAgreement (see the “Draft Guidance on Preparationof a Superfund Memorandum of Agreement (October5, 1987 - OSWER Directive No. 9375.0-01)), theState has the responsibility for development andimplementation of a community relations program.PRPs may, under certain circumstances, assist EPAor the State in implementing the community relationsactivities. For example, PRPs may wish to participatein community meetings and in preparing fact sheets.PRP participation in community relations activitieswould, however, be at the discretion of the RegionalOffice, or the State, and would require oversight bythe lead-agency. E P A w i l l n o t u n d e r a n ycircumstances negotiate press releases with PRPs.

EPA designs and implements community relationsactivities according to CERCLA and the NCP. ACommunity Relations Plan must be developed byEPA for all NPL sites as described by the EPAguidance, “Community Relations in Superfund: AHandbook” (U.S. EPA, 1988 - OSWER Directive No.9230.0-03). The Community Relations Plan must beindependent of negotiations with PRPs. Guidance forconduct ing community relat ions act iv i t ies atSuperfund enforcement sites is specifically addressedby Chapter VI of the Handbook and the EPA memoentitled “Community Relations Activities at SuperfundEnforcement Sites--Interim Guidance” (November1988 - OSWER Directive No. 9230.0-38). In someinstances the decision regarding PRP participation incommunity relations activities will be made after theCommunity Relations Plan has been developed. As aresult, the plan will need to be modified by EPA toreflect Agency and PRP roles and responsibilities.

EPA, or the State, will provide the CommunityRelations Plan to all interested parties at the sametime. In general, if the case has not been referred tothe Department of Justice (DOJ) for litigation,community relations activities during the RI/FS shouldbe the same for Fund- and PRP-lead sites. If thecase has been (or may potentially be) referred toDOJ for litigation, constraints will probably be placedon the scope of activities. The EPA CommunityRelations Plan may be modified after consultation withthe technical enforcement staff, the Regional Counseland other negotiation team members, including, if thecase is referred, the lead DOJ or Assistant UnitedStates Attorneys (i.e., the litigation team). Thistechnical and legal staff must be consulted prior toany public meetings or dissemination of fact sheets orother information; approval must be obtained prior toreleases of information and discussions of technicalinformation in advance. PRP part ic ipat ion inimplementing community relations activities will besubject to EPA (or State) approval in administrativesettlements and EPA/DOJ in civil actions. Keyactivities specific to community relations programs forenforcement sites include the following:

Public Review of Work Plans for AdministrativeOrders

The PRP Work Plan, as approved by EPA, isincorporated into the Administrative Order (orConsent Decree). Once the Agreement is signed, itbecomes a public document. Although there is norequirement for public comment on an AdministrativeOrder, Regional staff are encouraged to announce,after the Order is final, that the PRP is conducting theRI/FS. Publication of notice and a corresponding 30-day comment period is required however, for ConsentDecrees.

Availability of RI/FS Information from the PRPs

PRPs, in agreeing to conduct the RI/FS, must alsoagree to provide all information necessary for EPA toimplement a Community Relations Plan. TheAgreement should identify the types of informationthat PRPs will provide, and contain conditionsconcerning the provision of this information. EPAshould provide the PRPs with the content of the planso that the PRPs can fully anticipate the type ofinformation that will be made public. All informationsubmitted by PRPs will be subject to public inspection(i.e., available through Freedom of Information Actrequests, public dockets, or the administrative record)unless the information meets an exemption. Anexample would be if the information is deemed eitheras enforcement sensitive by EPA, or businessc o n f i d e n t i a l b y E P A ( b a s e d o n t h e PRPs’representations), in conformance with 40 CFR Part 2.

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Development of the ATSDR Health Assessment

Section 104(j)(6) of CERCLA requires the Agency forToxic Substances and Disease Registry (ATSDR) toperform health assessments at all NPL facilitiesaccording to a specified schedule. The purpose of thehealth assessment is to assist in determining whetherany current or potential threat to human health existsand to determine whether additional information onhuman exposure and associated health risks isneeded.

The EPA remedial project manager (RPM) shouldcoordinate with the appropriate ATSDR Regionalrepresentative for initiation of the health assessment.In general, the health assessment should be initiatedat the start of the RI/FS. The ATSDR Regionalrepresentative will provide information on data needsspecific to performing a health assessment to ensurethat all necessary data will be collected during the RI.The RPM and the ATSDR Regional representativeshould also coordinate the transmission and review ofpertinent documents dealing with the extent andnature of site contamination (i.e., applicable technicalmemoranda and the draft RI). As ATSDR has noprovisions for withholding documents, if requested bythe public, the RPM must discuss enforcementsensitive documents and drafts with the ATSDRRegional representative rather than providing copiesto them. This will ensure EPA’s enforcementconfidentiality. Further guidance on coordination ofRI/FS activities with ATSDR can be found in thedocument entitled “Guidance for Coordinating ATSDRHealth Assessment Activities with the SuperfundRemedial Process” (March 1987 - OSWER DirectiveNo. 9285.4-02).

Identification of Oversight Activities

EPA will review RI/FS plans and reports as well as provide field oversight of PRP activities during the

RI/FS. To ensure that adequate resources arecommitted and that appropriate activities are

performed, EPA should develop an oversight plan thatdefines the oversight act ivi t ies that must beperformed including EPA responsibilities, RI/FSproducts to be reviewed, and site activities that EPAwill oversee. In planning for oversight, EPA shouldconsider such factors as who will be performingoversight and the schedule of activities that will bemonitored. A tracking system for recording PRPmilestones should be developed. This system shouldalso track activities performed by oversight personneland other appropriate cost items such as travelexpenses.

Identification and Procurement of EPA AssistanceIn accordance with Section 104(a)(1) EPA mustarrange for a qualified party to assist in oversight ofthe RI/FS. The following section provides guidance foridentifying and procuring such assistance for EPAactivities.

l Assistance for EPA Activities

As specified in Section 104(a)(l), EPA is required tocontract with or arrange for a qualified person toassist in oversight of the RI/FS. Qualified individualsare those groups with the professional qualifications,expertise, and experience necessary to provideassurance that the Agency is conducting appropriateoversight of PRP RI/FS activities.

Normally, EPA will obtain oversight assistance eitherthrough the Technical Enforcement Support (TES)contract, the Alternative Remedial Contracts StrategyContract (ARCS), or occasionally through theRemedial Action (REM) contracts. In some casesoversight assistance may be provided by Statesthrough the use of Cooperat ive Agreements.Oversight assistance may also be obtained throughthe U.S. Army Corps o f Eng ineers o r o thergovernmental agencies; interagency Agreementsshould be utilized to obtain such assistance.

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Attachment IIIReview and Oversight of the RI/FS

Review of Plans, Reports, and Records

EPA will review all RI/FS products which aresubmitted to the Agency as specified in the WorkPlan or Administrative Order. PRPs should ensuret h a t a l l p l a n s , r e p o r t s , a n d r e c o r d s a r ecomprehensive, accurate, and consistent in contentand format with the NCP and relevant EPA guidance.After this review process, EPA will either approve ordisapprove the product. If the product is found to beunsatisfactory, EPA will notify the PRPs of thediscrepancies or deficiencies and will requirecorrections within a specified time period.

Project Plans

EPA will review all project plans that are submitted asdeliverables in fulfillment of the Agreement. Theseplans include the Work Plan, the Sampling andAnalysis Plan (including both the Field Sampling Planand the Quality Assurance Project Plan), and theHealth and Safety Plan. If the initial submittals are notsufficient in content or scope, the RPM will requestthat the PRPs submit revised document(s) for review.EPA does not “approve” the PRP’s Health andSafety Plan but rather, it is reviewed to ensure theprotection of public health and the environment. ThePRP’s Work Plan and Sampling and Analysis Plan, onthe other hand, must be reviewed and approved priorto the initiation of field activities. Conditional approvalto these plans may be provided in order to initiatefield activities in a more timely manner.

The PRPs may be required to develop additionalWork Plans or modify the initial Work Plan containedin or created pursuant to the Agreement. Thesechanges may result from the need to: (1) re-evaluate the RI/FS activities due either to changes inor unexpected site conditions; (2) expand the initialWork Plan when additional detail is necessary; or (3)modify or add products to the Work Plan based onnew information (e.g., a new population at risk). EPAwill review and approve all Work Plans and/ormodifications to Work Plans once they are submittedfor review.

Reports

PRPs will, at a minimum, submit monthly progressreports, technical memorandums or reports, and thedraft and final RI/FS reports as required in theAgreement. To assist in the development of the RI/FSand review of documents, additional deliverables maybe specified by the Region and included in theAgreement. These reports and deliverables will bereviewed by EPA to ensure that the activitiesspecified in the Order and approved Work Plan arebeing properly implemented. These reports willgenerally be submitted according to the conditionsand schedule set forth in the Agreement. Elements ofthe PRP reports are discussed below.

Monthly Progress Reports - The review of monthlyprogress reports is an important activity performedduring oversight. These reports should providesufficient detail to allow EPA to evaluate the past andprojected progress of the RI/FS. PRPs should submitthese written progress reports to the RPM. The reportshould describe the actions and decisions takenduring the previous month and activities scheduledduring the upcoming reporting period. In addition,technical data generated during the month (i.e.,analytical results) should be appended to the report.Progress reports should also include a detailedstatement of the manner and extent to which theprocedures and dates set forth in the Agreement/Work Plan are being met. Generally, EPA willdetermine the adequacy of the performance of theRI/FS by reviewing the following subjects discussed inprogress reports:

Technical Summary of Work

The monthly report will describe the activities andaccomplishments performed to date. This willgenerally include a description of all field workcompleted, such as sampling events andinstallation of wells; a discussion of analyticalresults received; a discussion of data reviewactivities; and a discussion of the development,screening, and detailed analysis of alternatives.The report will also describe the activities to beperformed during the upcoming month.

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Schedule

EPA will oversee PRP compliance with respect tothose schedules specified in the Order. Delays,with the exception of those specified under theForce Majeure clause of the Agreement, mayresult in penalties, if warranted. The RPM shouldbe immediately notified if PRPs cannot performrequired activities or cannot provide the requireddeliverables in accordance with the schedulespecified in the Work Plan. In addition, PRPsshould notify the RPM when circumstances maydelay the completion of any phase of the work orwhen circumstances may delay access to thesite. PRPs should also provide to the RPM, inwriting, the reasons for, and the anticipatedduration of, such delays. Any measures taken orto be taken by the PRPs to prevent or minimizethe delay should be described including thetimetables for implementing such measures.

Budget

The relationship of budgets to expendituresshould be tracked where the RI/FS is funded witha financial mechanism established by the PRPs. Ifsite activities require more funds than originallyestimated, EPA must be assured that the PRPsare financially able to undertake additionalexpenditures. While EPA does not have theauthority to review or approve a PRP budget,evaluating costs during the course of the RI/FSallows EPA to effectively monitor activity toensure timely completion of RI/FS activities. If thePRPs run over budget, EPA must be assured thatthey can continue the RI/FS act ivi t ies asscheduled. Therefore, i f speci f ied in theAgreement, PRPs shou ld submi t budgetexpenditures and cost overrun information toEPA. Budget reports need not present dollaramounts, but should indicate the relationshipbetween remaining available funds and theestimate of the costs of remaining activities.

ProblemsAny problems that the PRPs encounter whichcould affect the satisfactory performance of theRI/FS should be brought to the immediateattention of EPA. Such problems may or may notbe a force majeure event, or caused by a forcemajeure event. EPA will review problems andadvise the PRPs accordingly. Problems whichmay arise include, but are not limited to:

- Delays in mobilization or access to necessaryequipment;

- Unant ic ipated laboratory/analyt ical t imerequirements:

- Unsatisfactory QA/QC performance;

- Requirements for additional or more complexsampling;

- Prolonged unsatisfactory weather conditions;

- Unanticipated site conditions; and

- Unexpected, complex community relationsactivities.

Other Reports - All other reports, such astechnical reports and draft and final RI/FS reports,should be submitted to EPA according to theschedule contained in the Order or the approvedWork Plan. EPA will review and approve thesereports as they are submitted. Suggested formatsfor the RI/FS reports are presented in the RI/FSGuidance.

Records

PRPs should preserve all records, documents, andinformation of any kind relating to the performance ofwork at the site for a minimum of 6 years aftercompletion of the work and termination of theAdministrative Order. After the 6-year period, thePRPs should offer the records to EPA before theirdestruction.

Document control should be a key element of allrecordkeeping. The following activities require carefulrecordkeeping and will be subject to EPA oversight:

Administration - PRP administrative activitiesshould be accurately documented and recorded.Necessary precautions to prevent errors or theloss or misinterpretation of data should be taken.At a minimum, the following administrative actionsshould be documented and recorded:

- Contractor work plans, contracts, and changeorders;

- Personnel changes;

- Communications between and among PRPs,the State, and EPA officials regardingtechnical aspects of the RI/FS;

- Permit application and award (if applicable);and

- Cost overruns.

Technical Analysis - Samples and data should behandled according to procedures set forth in theSampling and Analysis Plan. Documentation

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establishing adherence to these proceduresshould include:

- Sample labels:

- Shipping forms;

- Chain-of-custody forms; and

- Field log books.

All analytical data in the RI/FS process should bemanaged as set forth in the Sampling andAnalysis Plan. Such analytical data may be theproduct of:

- Contractor laboratories;

- Environmental and public health studies; and

- Reliability, performance, and implementabilitystudies of remedial alternatives.

Decision Making - Actions or communicationsamong PRPs that involve decisions affectingtechnical aspects of the RI/FS should bedocumented. Such actions and communicationsinclude those of the project manager (or otherPRP management entity), steering committees, orcontractors.

l Administrative Record Requirements

Section 113(k) of CERCLA requires that the Agencyestablish an administrative record upon which theselection of a response action is based. A suggestedlist of documents which are most likely to be includedin any adequate administrative record is provided inthe memorandum entitled “Draft Interim Guidance onAdministrative Records for Selection of CERCLAResponse Actions” (June 23, 1988 - OSWERDirective No. 9833.3A). More detailed guidance willbe forthcoming, including guidance provided in therevisions to the NCP. There are, however, certaindetails associated with compiling and maintaining anadministrative record that are unique to PRP RI/FSactivities.

EPA is responsible for compiling and maintaining theadministrative record, and generating and updating anindex. If EPA and the PRPs mutually agree, the PRPsmay be al lowed to house and maintain theadministrative record file at or near the site; they maynot, however, be responsible for the actualcompilation of the record. Housing and maintainingthe administrative record would include setting up apublicly accessible area at or near the site andensuring that documents remain and are updated asnecessary. EPA must always be responsible fordeciding whether documents are included in the

administrative record; transmitting records to thePRPs; and maintaining the index to the repository.

T h e i n f o r m a t i o n w h i c h m a y c o m p r i s e t h eadministrative record must be available to the publicfrom the time an RI/FS Work Plan is approved byEPA. Once the Work Plan has been approved thePRPs must transmit to EPA, at reasonable, regularintervals, all of the information that is generatedduring the RI/FS that is related to selection of theremedy. The required documentation should bespecified in the Administrative Order. The Agreementshould also specify those documents generated priorto the RI/FS that must be obtained from the PRPs forinclusion in the record file. This may include anyprevious studies conducted under State or localauthorities, management documents held by thePRPs such as hazardous waste shipping manifests,and other information about site characteristics orconditions not contained in any of the abovedocuments.

Field Activitiesl Field Inspections

Field inspect ions are an important oversightmechanism for determining the adequacy of the workperformed. EPA wi l l therefore conduct f ie ldinspections as part of its oversight responsibilities.The oversight inspections should be performed in away that minimizes interference with PRP siteactivities or undue complication of field activities. EPAwill take corrective steps, as described in Section VIIand Attachment IV of this appendix, if unsatisfactoryperformance or other deficiencies are identified.

Several field-related tasks may be performed duringoversight inspections. These tasks include:

On-site presence/inspection - As specified inSection 104(e)(3), EPA reserves the right toconduct on-site inspections at any reasonabletime. EPA will therefore establish an on-sitepresence to assure itself of the quality of workbeing conducted by PRPs. At a minimum, fieldoversight will be conducted during critical times,such as the installation of monitoring wells andduring sampling events. EPA will focus onwhether the PRPs adhere to procedures specifiedin the SOW and Work Plan(s), especially thoseconcerning QA/QC procedures. Further guidanceregarding site characterization activities isp r e s e n t e d i n t h e R I / F S G u i d a n c e , t h e“Compendium of Superfund Field OperationsMethods” (August 1987 - OSWER Directive No.9355.0-l 41), the “ R C R A G r o u n d W a t e rTechnical Enforcement Guidance Document”(September 1986 - OSWER Directive No.9950.1) the NEIC Manual for Groundwater lSubsurface Investigations at Hazardous Waste

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Si tes ( U . S . E P A , 1 9 8 1 c ) , a n d O W P E ’ sforthcoming “Guidance on Oversight of PotentiallyResponsible Party Remedial Investigations andFeasibility Studies.”

Collection and analysis of samples - EPA maycollect a number of QA/QC samples includingblank, duplicate, and split samples. The results ofthese sample analyses will be compared to theresults of PRP analyses. This comparison willenable EPA to identify potential quality controlproblems and therefore help to evaluate thequality of the PRP investigation.

Environmental Monitoring - EPA may supplementany PRP environmental monitoring activity. Suchsupplemental monitoring may include air or waterstudies to determine additional migration ofsudden releases that may have occurred as aresult of site activities.

QA/QC Audits

EPA may either conduct, or require the PRPs toconduct (if specified in the Agreement), laboratoryaudits to ensure compliance with proper QA/QC andanalytical procedures, as specified in the Samplingand Analysis Plan. These audits will involve on-siteinspections of laboratories used by PRPs andanalyses of selected QA/QC samples. All proceduresmust be in accordance with those outlined in TheUser’s Guide to the Contract Laboratory Program,(U.S. EPA, 1986) or otherwise specified in theSampling and Analysis Plan.

Cha in -o f -Cus tody

Chain-of-custody procedures will be evaluated byEPA. This evaluation will focus on determining if thePRPs and their contractors adhere to the proceduresset forth in the Sampling and Analysis Plan. Properchain-of-custody procedures are described in theNational Enforcement Investigation Center (NEIC)Policies and Procedures Manual, (U.S. EPA, 1981 b).Evaluation of chain-of-custody procedures willoccur during laboratory audits as well as during on-site inspections of sampling activities.

Meetings

Meetings between EPA, the State, and PRPs shouldbe held on a regular basis (as specified in theAgreement) and at critical times during the RI/FS.Such critical times may at a minimum include whenthe SOW and the Work Plan are reviewed, the RI isin progress and completed, remedial alternatives aredeveloped and screened, detailed analysis of the

alternatives is performed, and the draft and final RI/FSreports are submitted. These meetings will discussoverall progress, d isc repanc ies in the workperformed, problems encountered in the performanceof RI/FS activities and their resolution, communityrelations, and other related issues and concerns.While meetings may be initiated by either the PRPsor EPA at any time, they will generally be conductedat the stages of the RI/FS listed below.

Initiation of Activities

EPA, the State, and the PRPs may meet at varioustimes before field activities begin to discuss the initialplanning of the RI/FS. Meetings may be arranged todiscuss, review, and approve the SOW; to developthe EPA/PRP Agreement; and to develop, review, andapprove the Work Plan.

Progress

EPA may request meetings to discuss the progress ofthe RI/FS. These meetings should be held at leastquarterly and will focus on the items submitted in themonthly progress reports and the findings from EPAoversight activities. Any problems or deficiencies inthe work will be identified and corrective measureswill be requested (see Section VIII and Attachment IVof this appendix).

Closeout

EPA may reques t a c loseou t meet ing uponcompletion of the RI/FS. This meeting will focus onthe review and approval of the final RI/FS report,termination of the RI/FS Agreement, and any finalon-site activities which the PRPs may be required toperform. These activities may include maintaining thesite and ensuring that fences and warning signs areproperly installed. The transition to remedial designand remedial action will also be discussed during thismeeting.

Special StudiesEPA may determine that special studies related to thePRP RI/FS are required. These studies can beconducted to verify the progress and results of RI/FSactivities or to address a specific complex orcontroversial issue. Normally, special studies areperformed by the PRPs; however, there may becases in which EPA will want to conduct theindependent studies. The +PRPs should be informedof any such studies and given adequate time toprovide necessary coordination of site personnel andresources. If not provided for in the Agreement,modifications to the Work Plan may be required.

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Attachment IVControl of Activities

Identification of DeficienciesOversight activities may identify unsatisfactory ordeficient PRP performance. The determination ofsuch performance may be based upon findings suchas:

Work products are inconsistent with the SOW orWork Plan;

Technical deficiencies exist in submittals or otherRI/FS products;

Unreasonable delays occur while performingRI/FS activities; and

Procedures are inconsistent with the NCP.

Corrective Measures

The need to perform corrective measures may arisein the event of deficiencies in reports or other workproducts, or unsatisfactory performance of field orlaboratory activities. When deficiencies are identifiedcorrective measures may be sought by: (1) notifyingthe PRPs; (2) describing the nature of the deficiency;and (3) either requesting the PRPs to take whateveractions they regard as appropriate or setting forthappropriate corrective measures. The followingsubsections describe this process for each of the twogeneral types of activities that may require correctivemeasures.

Corrective Measures Regarding Work Products

Agency review and approval procedures for workproducts generally allow three types of responses: (1)approval; (2) approval with modifications; and (3)non-approval. Non-approval of a work product(including project plans) immediately constitutes anotice of deficiency. EPA will immediately notify thePRPs if any work product is not approved and willexplain the reason for such a finding.

Approval with modifications will not lead to a notice ofdeficiency if the modifications are made by the PRPswithout delay. If the PRPs significantly delay in

responding to the modifications, the RPM would issuea notice of deficiency to the PRP project managerdetailing the following elements:

- A description of the deficiency or a statementdescribing in what manner the work productwas found to be deficient or unsatisfactory;

- Modifications that the PRPs should make inthe work product to obtain approval;

- A request that the PRPs prepare a plan, ifnecessary, or otherwise identify actions thatwill lead to an acceptable work product;

- A schedule for submission of the correctedwork product;

- An invitation to the PRPs to discuss thematter in a conference; and

- A statement of the possibility of EPA takeoverat the PRPs’ expense, EPA enforcement, orpenalties (as appropriate).

Corrective Measures Regarding Field Activities

When the lead agency discovers that the PRPs (ortheir contractors) are performing the RI/FS field workin a manner that is inconsistent with the Work Plan,the PRPs should be notified of the finding and askedto voluntarily take appropriate corrective measures.The request is generally made at a progress meeting,or, if immediate action is required, at a specialmeeting held specifically to discuss the problem. Ifcorrective measures are not voluntarily taken, theRPM should, in conjunction with appropriate RegionalCounsel, issue a notice of deficiency containing thefollowing elements:

- A description of the deficiency;

- A request for an explanation of the failure toper fo rm sa t i s fac to r i l y and a p lan fo raddress ing the necessary cor rec t i vemeasures;

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- A statement that fai lure to present anexplanation may be taken as an admissionthat there is no valid explanation;

- An invitat ion to discuss the matter in aconference (where appropriate);

- A statement that stipulates penalties mayaccrue or are accruing, project terminationmay occur, and/or civil action may be initiatedif appropriate actions are not taken to correctthe deficiency; and

- A descript ion of the potent ial l iabi l i t iesincurred in the event that appropriate actionsare not taken.

Modifications to the Work Plan/Additional Work

Under the Administrative Order (or Consent Decree),PRPs agree to complete the RI/FS, including thetasks required under either the original Work Plan ora subsequent or modified Work Plan. This mayinclude determinations and evaluations of conditionsthat are unknown at the time of execution of theAgreement. Modifications to the original RI/FS WorkPlan are frequently required as field work progresses.Work not explicitly covered in the Work Plan is oftenrequired and therefore provided for in the Order. Thiswork is usually identified during the RI and is drivenby the need for further information in a specific area.In general, the Agreement should provide for fine-tuning of the RI, or the investigation of an areapreviously unidentified. As it becomes clear whatadditional work is necessary, EPA will notify the PRPsof the work to be performed and determine aschedule for completion of the work.

EPA must ensure that clauses for modifications to theWork Plan are included in the Agreement so that thePRPs will carry out the modifications as the need forthem is identified. To facilitate negotiation on thesepoints, EPA may consider one or more of thefollowing provisions in the Agreement for addressingsuch situations:

- Def in ing the l im i ts o f add i t iona l workrequirements;

- Specifying the dispute resolution process formodified Work Plans and additional workrequirements;

- Defining the appl icabi l i ty of st ipulatedpenalties to any additional work which thePRPs agree to undertake.

Dispute Resolution

As discussed elsewhere in this guidance, the RI/FSOrder developed between EPA and the PRPs sets

forth the terms and conditions for conducting theRI/FS. An element of this Agreement is a statementof the specific steps to be taken if a dispute arisesbetween EPA (or its representatives) and the PRPs.These steps should be well defined and agreed uponby all signatories to the Agreement.

A dispute with respect to the Order is followed by aspecific period of discussion with the PRPs. After thediscussion period, EPA issues a final decision whichbecomes incorpora ted in to the Agreement .Administrative Orders should clarify that with respectto all submittals and work performed, EPA will be thefinal arbiter. The court, on the other hand, is the finalarbiter for Consent Decrees.

Penalties

As an incentive for PRPs to properly conduct theRI/FS and correct any deficiencies discovered duringthe conduct of the Agreement, EPA should includestipulated penalties. Section 121 provides up to$25,000 per day in stipulated penalties for violationsof a Consent Decree while Section 122 allows EPA toseek or impose civil penalties for violations ofAdministrative Orders.3 Penalties should begin toaccrue on the first day of the deficiency and continueto be assessed until the deficiency is corrected. Thetype of violation (i.e., reporting requirements vs.implementation of construction requirements), as wellas the amounts, should be specified as stipulatedpenalties in the Agreement to avoid negotiations onthis point which may delay the correction. Theamounts should be set pursuant to the criteria ofSection 109 and as such must take into account thenature, circumstances, extent, and gravity of theviolations as well as the PRPs’ ability to pay, priorhistory of violations, degree of culpability, and theeconomic benefit resulting from noncompliance.Additional information on stipulated penalties can befound in OECM’s “Guidance on the Use of StipulatedPenalties in Hazardous Waste Consent Decrees”(September 27, 1987).

Project TakeoverGenerally, EPA will consult with PRPs to discussdeficiencies and corrective measures. If thesediscussions fail, EPA has two options: (1) pursuelegal action to force the PRPs to continue the work;or (2) take over the RI/FS. If taking legal action willnot significantly delay implementation of necessaryremedial or removal actions, EPA may commencecivil action against the noncomplying PRP to enforcethe Administrative Order. Under a Consent Decree,the matter would be presented to the court in which

3 In order to provide for stipulated penalties in an AdministrativeOrder the parties must voluntarily include them in the terms ofthe Agreement.

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the Decree was filed to enforce the provisions of theDecree.

If a delay in RI/FS activities endangers public healthand/or the environment or will significantly delayimplementation of necessary remedial actions, EPAshould move to replace the PRP activities withFund-financed actions. The RPM will take theappropriate steps to assume responsibility for the

RI/FS, including issuing a stop-work order to thePRPs and notifying the EPA remedial contractors. Inissuing stop work orders, RPMs should be aware thatFund resources may not be automatically available.But, in the case of PRP actions which threatenhuman health or the environment, there may be noother course of action. Once this stop work order isissued, a fund-financed RI/FS will be undertakenconsistent with EPA funding procedures.

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Appendix BElements of RI/FS Project PIans

I. Elements of a Work Plan1

Introduction - A general explanation of the reasonsfor the RI/FS and the expected results or goals of theRI/FS process are presented.

Site Background and Physical Setting - The currentunderstanding of the physical setting of the site, thesite history, and the existing information on thecondition of the site are described. (See Section2.2.2.1.)

Initial Evaluation - The conceptual site modeldeveloped during scoping is presented, describing thepotential migration and exposure pathways and thepreliminary assessment of human health andenvironmental impacts. (See Section 2.2.2.2).

Work Plan Rationale - Data requirements for both therisk assessment and the alternatives evaluationidentified during the formulation of the DQOs aredocumented, and the work plan approach ispresented to illustrate how the activities will satisfydata needs.

RI/FS Tasks - The tasks to be performed during theRI/FS are presented. This description incorporates RIsite characterization tasks identified in the QAPP andthe FSP, the data evaluation methods identifiedduring scoping (see Sect ion 2.2.9), and thepreliminary determination of tasks to be conductedafter site characterization (see Section 2.2.7 of thisguidance).

II. Standard Federal-Lead RI/FS WorkPlan Tasks

Task 1. Project Planning (Project Scoping)

This task includes efforts related to initiating a projectafter the SOW is issued. The project planning task isdefined as complete when the work plan andsupplemental plans are approved (in whole or in part).The following typical elements are included in thistask:

1 These elements are required in a work plan but do notnecessarily represent the organization of a work plan.

Work plan memorandum

Kickoff meeting (RI/FS brainstorming meeting)

Site visit/meeting

Obtaining easements/permits/site access

Site reconnaissance and limited field investigation

Site survey2/topographic map/review of existingaerial photographs

Collection and evaluation of existing data

Development of conceptual site model

Identification of data needs and DQOs

Identification of preliminary remedial actionobjectives and potential remedial alternatives

Identification of treatability studies that may benecessary

Preliminary identification of ARARs

Preparation of plans (e.g., work plan, health andsafety plan, QAPP, FSP)

Initiation of subcontract procurement

In i t ia t ion o f coord inat ion wi th ana ly t ica llaboratories (CLP and non-CLP)

Task management and quality control

Task 2. Community Relations

This task incorporates all efforts related to thepreparation and implementation of the communityrelations plan for the site and is initiated during thescoping process. It includes time expended by bothtechnical and community relations personnel. Thistask ends when community relations work under Task

2 A site survey may be conducted during project planning ormay occur during the field investigation task but should notoccur in both.

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12 is completed, but the task does not include workon the responsiveness summary in the ROD (seeTask 12). The following are typical elements includedin this task:

Conducting community interviews

Preparing a community relations plan

Preparing fact sheets

Providing public meeting support

Providing technical support for communityrelations

Implementing community relations

Managing tasks and conducting quality control

Task 3. Field Investigation

This task involves efforts related to fieldwork inconducting the RI. It includes the procurement ofsubcontractors related to field efforts. The task beginswhen any element, as outlined in the work plan, isapproved (in whole or in part) and fieldwork isauthorized. 3 Field investigation is defined as completewhen the contractor and subcontractors aredemobilized from the field. The following activities aretypically included in this task:

Procurement of subcontracts

Mobilization

Media sampling

Source testing

Geology/hydrogeological investigations

Geophysics

Site survey/topographic mapping (if not performedin project planning task)

Field screening/analyses

Procurement of subcontractors

RI waste disposal

Task management and quality control

Task 4. Sample Analysis/ Validation

This task includes efforts relating to the analysis andvalidation of samples after they leave the field.Separate monitoring of close support laboratories maybe required. Any efforts associated with laboratoryprocurement are also included in this task. The task

3 Note that limited fieldwork during project scoping may beauthorized as part of the work assignment to prepare the RI/FSwork plan.

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ends on the date that data validation is complete. Thefollowing typical activities are usually included in thistask:

Sample management

Non-CLP analyses

Use of mobile laboratories

Data validation

Testing of physical parameters

Task management and quality control

Task 5. Data Evaluation

This task includes efforts related to the analysis ofdata once it has been verified that the data are ofacceptable accuracy and precision. The task beginson the date that the first set of validated data isreceived by the contractor project team and endsduring preparation of the RI report when it is deemedthat no additional data are required. The following aretypical activities:

Data evaluation

Data reduction and tabulation

E n v i r o n m e n t a l f a t e a n d t r a n s p o r t m o d e l -ing/evaluation

Task management and quality control

Task 6. Assessment of RisksThis task includes efforts related to conducting thebaseline risk assessment. The task will include workt o a s s e s s t h e p o t e n t i a l h u m a n h e a l t h a n denvironmental risks associated with the site. Work willbegin during the RI and is completed once thebaseline risk assessment is completed.4 The followingare typical activities:

Identification of contaminants of concern (orindicator chemicals)

Exposure assessment (including any modelingperformed specifically for this function)

Toxicity assessment

Risk characterization

Task management and quality control

4 Limited efforts to assess potential human health andenvironmental risks are, to some extent, initiated duringscoping when the conceptual site model is being developed.

Task 7. Treatability Study/Pilot Testing

This task includes efforts to prepare and conductpilot, bench, and treatability studies. This task beginswith the development of work plans for conductingthe tests and is complete once the report has beencompleted. The following are typical activities:

Work plan preparation or work plan amendment

Test facility and equipment procurement

Vendor and analytical service procurement

Equipment operation and testing

Sample analysis and validation

Evaluation of results

Report preparation

Task management and quality control

Task 8. Remedial Investigation Reports

This task covers all efforts related to the preparationof the findings once the data have been evaluatedunder Tasks 5 and 6. The task covers all draft andfinal RI reports as well as task management andquality control. The task ends when the last RIdocument is submitted by the contractor to EPA. Thefollowing are typical activities:

Preparation of a preliminary site characterizationsummary (see Section 3.7.2 of this guidance)

Data presentation (formatting tables, preparinggraphics)

Writing the report

Reviewing and providing QC efforts

Printing and distributing the report

Holding review meetings

Revising the report on the basis of agencycomments

Providing task management and control

Task 9. Remedial AlternativesDevelopment/Screening

This task includes efforts to select the alternatives toundergo full evaluation. The task is initiated oncesufficient data are available to develop general

response actions and begin the initial evaluation ofpotential technologies. This task is def ined ascomplete when a final set of alternatives is chosen fordetailed evaluation. The following are typical activities:

Identifying/screening potential technologies

Assembling potential alternatives

Identifying action-specific ARARs

Evaluating each alternative on the basis ofscreening criteria (effectiveness, implementability,cost)

Reviewing and providing QC of work effort

Preparing the report or technical memorandum

Holding review meetings

Refining the list of alternatives to be evaluated

Task 10. Detailed Analysis of RemedialAlternatives

This task applies to the detailed analysis andcomparison of alternatives. The evaluation activitiesinc lude pe r fo rm ing de ta i l ed human hea l th ,environmental, and institutional analyses. The taskbegins when the alternatives to undergo detailedanalysis have been identified and agreed upon andends when the analysis is complete. The following aretypical activities:5

Refinement of alternatives

Individual analysis against the criteria

Comparative analysis of alternatives against thecriteria

Review of QC efforts

Review meetings

Task management and QC

Task 11. Feasibility Study (or RI/FS) Reports

Similar to the RI reports task, this task is used toreport FS deliverables. However, this task should beused in lieu of the RI reports task to report costs andschedules for combined RI/FS deliverables. The taskends when the FS (or RI/FS) is released to the public.The following are typical activities:

5 State and community acceptance will be evaluated by the leadagency during remedy selection.

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Presenting data (formatting tables, preparinggraphics)

Writing the report

Printing and distributing the report

Holding review meetings

Revising the report on the basis of agencycomments

Providing task management and quality control

Task 12. Post RI/FS Support

This task includes efforts to prepare the proposedplan, the responsiveness summary, support the ROD,conduct any predesign activities, and close out thework assignment. All activities occurring after therelease of the FS to the public should be reportedunder this task. The following are typical activities:

Preparing the predesign report

Preparing the conceptual design

Attending public meetings

Wr i t ing and rev iewing the respons ivenesssummary

Supporting ROD preparation and briefings

Reviewing and providing QC of the work effort

Providing task management and QC

Task 13. Enforcement SupportThis task includes efforts during the RI/FS associatedwith enforcement aspects of the project. Activitiesvary but are to be associated with efforts related toPRPs. The following are typical activities:

Reviewing PRP documents

Attending negotiation meetings

Preparing briefing materials

Assisting in the preparation of ROD

Providing task management and QC

Task 14. Miscellaneous Support

This task is used to report on work that is associatedwith the project but is outside the normal RI/FS scopeof work. Activities will vary but include the following:

Specific support for coordination with and reviewof ATSDR activities and reports

Support for review of special State or localprojects

The following are some specific comments applicableto the 14 tasks described above:

All standard tasks or all work activities under eachtask need not be used for every RI/FS. Onlythose that are relevant to a given project shouldbe used.

Tasks include both draft and final versions ofdeliverables unless otherwise noted.

The phases of a task should be reported in thesame task (e.g., field investigation Phase I andPhase II will appear as one field investigationtask).

If an RI/FS is divided into distinct operable units,each operable unit should be monitored andreported on separately. Therefore, an RI/FS withseveral operable units may, in fact, have morethan 15 tasks, although each of the tasks will beone of the 15 standard tasks.

Costs associated with project management andtechnical QA are included in each task.

Costs associated with procuring subcontractorsa r e i n c l u d e d i n t h e t a s k i n w h i c h t h esubcontractor will perform work (not the projectplanning task).

Lists of standard tasks define the minimum levelof reporting. For federal-lead tasks, some RPMsand contractors currently report progress in amore detailed fashion and may continue to do soas long as activities are associated with standardtasks.

III. Elements of a Quality AssuranceProject Plan

Title Page - At the bottom of the title page, provisionsshould be made for the signatures of approvingpersonnel. As a minimum, the QAPP must beapproved by the following:

S u b c o n t r a c t o r ’ s p r o j e c t m a n a g e r ( i f asubcontractor is used)

Subcontractor’s QA manager (if a subcontractoris used)

Contractor’s project manager (if applicable)

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Contractor’s QA manager (if applicable)

Lead agency’s project officer

Lead agency’s QA officer (if applicable)

Provision should be made for the approval or reviewof others (e.g., regional laboratory directors), ifapplicable.

Table of Contents - The table of contents will includean introduction, a serial listing of the 16 QAPPelements, and a listing of any appendixes that arerequired to augment the QAPP. The end of the tableof contents should include a list of the recipients ofofficial copies of the QAPP.

Project Description - The introduction to the projectdescription consists of a general paragraph identifyingthe phase of the work and the general objectives ofthe investigation. A description of the location, size,and important physical features of the site such asponds, lagoons, streams, and roads should beincluded (a figure showing the site location and layoutis helpful). A chronological site history includingdescriptions of the use of the site, complaints byneighbors, permitting, and use of chemicals needs tobe provided along with a brief summary of previoussampling efforts and an overview of the results.Finally, specific project objectives for this phase ofdata gathering need to be listed, and ways in whichthe data will be used to address each of theobjectives must be identified. Those items abovethat are also included in the work plan need notbe repeated in the QAPP and, instead, may beincorporated by reference.

Project Organization and Responsibilities - Thiselement identifies key personnel or organizations thatare necessary for each activity during the study. Atable or chart showing the organization and line ofauthority should be included. When specific personnelcannot be identified, the organization with theresponsibility should be listed.

QA Objectives for Measurement - For individualmatrix groups and parameters, a cooperative effortshould be undertaken by the lead agency, theprincipal engineering firm, and the laboratory staff todefine what levels of quality should be required forthe data. These QA objectives will be based on acommon understanding of the intended use of thedata, available laboratory procedures, and availableresources. The field blanks and duplicate field samplealiquots to be collected for QA purposes should beitemized for the matrix groups identified in the projectdescription.

The selection of analytical methods requires afamiliarity with regulatory or legal requirementsconcerning data usage. Any regulations that mandate

the use of certain methods for any of the samplematrices and parameters listed in the projectdescription should be specified.

The detection limits needed for the project should bereviewed against the detection limits of the laboratoryused. Special attention should be paid to thedetection limits provided by the laboratory for volatileorganic compounds, because these limits aresometimes insufficient for the analysis of drinkingwater. Detection limits may also be insufficient toassess attainment of ARARs. For Federal-leadprojects, if QA objectives are not met by CLP RASs,then one or more CLP SASS can be written.

Quantitative limits should be established for thefollowing QA objectives:

1. Accuracy of spikes, reference compounds

2. Precision

3. Method detection limits

These limits may be specified by referencing theSOW for CLP analysis, including SAS requests, in anappendix and referring to the appendix or owner/operator manuals for field equipment.

Completeness, representativeness, and comparabilityare quality characteristics that should be consideredduring study planning. Laboratories should providedata that meet QC acceptance criteria for 90 percentor more of the requested determinations. Any sampletypes, such as control or background locations, thatrequire a higher degree of completeness should beidentified. “Representativeness“ of the data is mostoften thought of in terms of the collection ofrepresen ta t i ve samples o r the se lec t ion o frepresentative sample aliquots during laboratoryanalysis. "Comparability" is a consideration forplanning to avoid having to use data gathered bydifferent organizations or among different analyticalmethods that cannot reasonably be comparedbecause of differences in sampling conditions,sampling procedures, etc.

Sampling Procedures - These procedures appendthe site-specific sampling plan. Either the samplingplan or the analytical procedures element maydocument field measurements or test procedures forhydrogeological investigations.

For each major measurement, including pollutantmeasurement systems, a description of the samplingprocedures to be used should be provided. Whereapplicable, the following should be included:

A description of techniques or guidelines used toselect sampling sites

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A description of the specific sampling proceduresto be used

Charts, flow diagrams, or tables delineatingsampling program

A description of containers, procedures, reagents,and so forth, used for sample collection,preservation, transport, and storage

A discussion of special conditions for thepreparation of sampling equipment and containersto avoid sample contamination

A description of sample preservation methods

A discussion of the time considerations forshipping samples promptly to the laboratory

Examples of the custody or chain-of-custodyprocedures and forms

A description of the forms, notebooks, andprocedures to be used to record sample history,sampling conditions, and ana lyses to beperformed

The DQO document described above can also beincorporated by reference in this section. In addition,the Compendium of Superfund Field OperationsMethods (U.S. EPA, September 1987) containsinformation pertinent to this section and can beincorporated by reference.

Sample Custody - Sample custody is a part of anygood laboratory or field operation. If samples wereneeded for legal purposes, chain-of-custodyprocedures, as defined by the NEIC Policies andProcedures (U.S. EPA, June 1985), would be used.Custody is divided into three parts:

Sample collection

Labora to ry

Final evidence files

The QAPP should address all three areas of custodyand should refer to the User’s Guide to the ContractLaboratory Program (U.S. EPA, December 1986) andRegional guidance documents for examples andinstructions. For federal-lead projects, laboratorycustody is described in the CLP SOW; this may bereferenced. Final evidence files include all originals oflaboratory reports and are maintained underdocumented control in a secure area.

A sample or an evidence file is under custody if:

It is in your possession.

It is in your view, after being in your possession.

It was in your possession and you placed it in asecure area.

It is in a designated secure area.

A QAPP should provide examples of chain-of-custody records or forms used to record the chain ofcustody for samples, laboratories, and evidence files.

Calibration Procedures - These procedures shouldbe identified for each parameter measured and shouldinclude field and laboratory testing. The appropriatestandard operating procedures (SOPS) should bereferenced, or a written description of the calibrationprocedures to be used should be provided.

Analytical Procedures - For each measurement,either the applicable SOP should be referenced or awritten description of the analytical procedures to beused should be provided. Approved EPA proceduresor their equivalent should be used.

Data Reduction, Validation, and Reporting - For eachmeasurement, the data reduction scheme planned forcollected data, including all equations used tocalculate the concentration or value of the measuredparameter, should be described. The principal criteriathat will be used to validate the integrity of the dataduring collection and reporting should be referenced.

lnternal Qualify Control - All specific internal QCmethods to be used should be identified. Thesemethods include the use of replicates, spike samples,split samples, blanks, standards, and QC samples.Ways in which the QC information will be used toqualify the field data should be identified.

Performance and Systems Audits - The QAPP shoulddescribe the internal and external performance andsystems audits that will be required to monitor thecapability and performance of the total measurementsystem. The current CLP Invitation for Bids fororganic and inorganic analyses may be referenced forCLP RAS performance and systems audits. TheCompendium of Superfund Field Operations Methods(U.S. EPA, September 1987) may be referenced forroutine fieldwork.

The systems audits consist of the evaluation of thecomponents of the measurement systems todetermine their proper selection and use. Theseaudits include a careful evaluation of both field andlaboratory QC procedures and are normally performedbefore or shortly after systems are operational.However, such audits should be performed on aregular schedule during the lifetime of the project orcontinuing operation. An onsite systems audit may berequired for formal laboratory certification programs.

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After systems are operational and are generatingdata, performance audits are conducted periodicallyto determine the accuracy of the total measurementsystem or its component parts. The QAPP shouldinclude a schedule for conducting performance auditsfor each measurement parameter. Laboratories maybe required to part ic ipate in the analysis ofperformance evaluation samples related to specificprojects. Project plans should also indicate, whereapplicable, scheduled participation in all otherinterlaboratory performance evaluation studies.

In support of performance audits, the environmentalmonitoring systems and support laboratories providenecessary audit materials and devices, as well astechnical assistance. These laboratories conductregular interlaboratory performance tests and provideguidance and assistance in the conduct of systemsaudits. The laboratories should be contacted ifassistance is needed in the above areas.

Preventive Maintenance - A schedule should beprovided of the major preventative maintenance tasksthat will be carried out to minimize downtime of fieldand laboratory instruments. Owner’s manuals may bereferenced for field equipment.

Specific Routine Procedures Used to Assess Data(Precision, Accuracy, and Completeness) - Theprecision and accuracy of data must be routinelyassessed for all environmental monitoring andmeasurement data. The QAPP should describespecific procedures to accomplish this assessment. Ifenough data are generated, statistical proceduresmay be used to assess the precision, accuracy, andcompleteness. If statistical procedures are used, theyshould be documented.

Corrective Actions - In the context of QA, correctiveactions are procedures that might be implemented onsamples that do not meet QA specifications.Corrective actions are usually addressed on a case-by-case basis for each project. The need forcorrective actions is based on predetermined limitsfor acceptability. Corrective actions may includeresampling, reanalyzing samples, or audit inglaboratory procedures. The QAPP should identifypersons responsible for initiating these actions,procedures for identifying and documenting correctiveactions, and procedures for reporting and followup.

Quality Assurance Project Plans - QAPPs shouldidentify the method to be used to report theperformance of measurement systems and dataquality. This reporting should include results ofperformance audits, results of systems audits, andsignificant QA problems encountered, along withrecommended solutions. The RI report should includea separate QA section that summarizes the dataquality.

IV. Elements of a Field Sampling Plan6

Site Background - If the analysis of existing data isnot included in the work plan or QAPP, it must beincluded in the FSP. This analysis would include adescription of the site and surrounding areas and adiscussion of known and suspected contaminantsources, probable transport pathways, and otherinformation about the site. The analysis should alsoinclude descriptions of specific data gaps and ways inwhich sampling is designed to fil l those gaps.Including this discussion in the FSP will help orientthe sampling team in the field.

Sampling Objectives - Specific objectives of asampling effort that describe the intended uses ofdata should be clearly and succinctly stated.

Sample Location and Frequency - This section of thesampling plan identifies each sample matrix to becollected and the constituents to be analyzed. A tablemay be used to clearly identify the number ofsamples to be collected along with the appropriatenumber of replicates and blanks. A figure should beincluded to show the locations of existing or proposedsample points.

Sample Designation - A sample numbering systemshould be established for each project. The sampledesignation should include the sample or wellnumber, the sampling round, the sample matrix (e.g.,surface soil, ground water, soil boring), and the nameof the site.

Sampling Equipment and Procedures - Samplingprocedures must be clearly written. Step-by-stepinstructions for each type of sampling are necessaryto enable the field team to gather data that will meetthe DQOs. A list should include the equipment to beused and the material composition (e.g., Teflon,stainless steel) of the equipment along withdecontamination procedures.

Sample Handling and Analysis - A table should beincluded that identifies sample preservation methods,types of sampling jars, shipping requirements, andholding times. SAS requests and CLP SOWS may bereferenced for some of this information.

Examples of paperwork and instructions for filling outthe paperwork should be included. Use of the CLPrequires that t raf f ic reports, chain-of-custodyforms, SAS packing lists, and sample tags be filledout for each sample. If other laboratories are to beused, the specific documentation required should be

6 Field sampling plans are site-specific and may includeadditional elements.

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identified. Field documentation includes fieldnotebooks and photographs.

Provision should be made for the proper handling anddisposal of wastes generated onsite. The site-specific procedures need to be described to preventcontamination of clean areas and to comply withexisting regulations.

V.

1.

2.

3.

Elements of a Health and SafetyPlan

Medical surveillance requirements

A description of the frequency and types of airmonitoring, personnel monitoring, and environ-mental sampling techniques and instrumentationto be used

The name of a site health and safety officer andthe names of key personnel and alternatesresponsible for site safety and health

7. Site control measures

8. Decontamination procedures

9. Standard operating procedures for the site

A health and safety risk analysis for existing site 10. A contingency plan that meets the requirementsconditions, and for each site task and operation of 29 CFR 1910.120(l)(1) and (l)(2)

Employee training assignments 11. Entry procedures for confined spaces

4.

5.

6.

A description of personal protective equipment tobe used by employees for each of the site tasksand operations being conducted

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Appendix CModel Statement of Work for Remedial Investigations and Feasibility Studies

IntroductionThis model statement of work (SOW) was developedto provide users of this guidance with an illustrativeexample of how the specific tasks1 carried out duringa remedial investigation (RI) and feasibility study (FS)may be presented. Because an RI/FS is phased inaccordance with a site’s complexity and the amountof available information, it may be necessary tomodify components of the SOW in order to tailor thetasks to the specific conditions at a site. Similarly, thelevel of detail and the specification of individual taskswill vary according to the budget, size, and complexityof the contract. Therefore, a SOW may differ, or

additional tasks may be added to what is presentedhere.

A SOW should begin with a section identifying thesite, its regulatory history, if any, and a statement anddiscussion of the purpose and objectives of the RI/FSwithin the context of that particular site. This sectionshould be followed by a discussion of the specifictasks that will be necessary to meet the statedobjectives. The SOW should be accompanied by U.S.EPA’s Guidance for Conducting Remedial Investi-gations and Feasibility Studies Under CERCLA (EPA,October 1988).

1 REM contractor standard tasks have been developed for costaccounting purposes (see Appendix B) and are the basis of theformat of this model SOW.

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Model SOW for Conducting an R/IFS

Purpose

The purpose of this remedial investigation/feasibilitystudy (RI/FS) is to investigate the nature and extent ofcontamination at the OTR site and to develop andevaluate remedial alternatives, as appropriate. Thecontractor will furnish all necessary personnel,materials, and services needed for, or incidental to,performing the RI/FS, except as otherwise specifiedherein. The contractor will conduct the RI/FS inaccordance with the Guidance for ConductingRemedial Investigations and Feasibility Studies UnderCERCLA (U.S. EPA, October 1988).

This statement of work (SOW) has been developedfor the OTR site that operated as a former drumrecycling center from 1968 through 1979. OTR wasproposed for inclusion to the NPL in September 1980and appeared as final on the NPL in September 1981.A removal action taken in 1982 removed all visibledrums and disposed of them in an offsite landfill.Three buildings remain onsite along with visiblystained soil that is assumed to be contaminated withTCE, benzene, and other organics. It is suspectedthat releases from the site have contaminated nearbysurface waters and ground waters beneath the site.

S c o p eThe specific RI/FS activities to be conducted at theOTR site are segregated into 11 separate tasks.

Task 1 - Project Planning

Task 2 - Community Relations

Task 3 - Field Investigations

Task 4 - Sample Analysis/Validation

Task 5 - Data Evaluation

Task 6 - Risk Assessment

Task 7 - Treatability Studies

Task 8 - RI Report(s)

Task 9 - Remedial Alternatives Development andScreening

Task 10 - Detailed Analysis of Alternatives

Task 11 - FS Report(s)

The contractor shall specify a schedule of activitiesand deliverables, a budget estimate, and staffingrequirements for each of the tasks which aredescribed below.

Task 1 Project Planning

Upon receipt of an interim authorization memorandum(used to authorize work plan preparation) and thisSOW from U.S. EPA outlining the general scope ofthe project, the contractor shall begin planning thespecif ic RI/FS activi t ies that wi l l need to beconducted. As part of this planning effort, thecontractor will compile existing information (e.g.,topographic maps, aerial photographs, data collectedas part of the NPL listing process, and data collectedas part of the drum removal of 1982) and conduct asite visit to become familiar with site topography,access routes, and the proximity of potentialreceptors to site contaminants. Based on thisinformation (and any other available data), thecontractor will prepare a site background summarythat should include the following:

Local Regional Summary - A summary of thelocation of the site, pertinent area boundaryfea tu res and genera l s i te phys iography ,hydrology, geology, and the location(s) of anynearby drinking water supply wells.

Nature and Extent of Problem - A summary of theactual and potential onsite and offsite health andenvironmental effects posed by any remainingcontamination at the site. Emphasis should be onproviding a conceptual understanding of thesources of contamination, potential releasemechanisms, potential routes of migration, andpotential human and environmental receptors.

History of Regulatory and Response Actions - Asummary of any previous response actionsconducted by local, State, Federal, or private

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parties. This summary should address anyenforcement activities undertaken to identifyresponsible parties, compel private cleanup, andrecover costs. Site reference documents andtheir locations should be identified.

Preliminary Site Boundary - A preliminary siteboundary to define the initial area(s) of theremedial investigation. This preliminary boundarymay also be used to define an area of accesscontrol and site security.

The contractor will meet with EPA to discuss thefollowing:

The proposed scope of the project and thespecific investigative and analytical activities thatwill be required

Whether there is a need to conduct limitedsampling to adequately scope the project anddevelop project plans

Preliminary remedial action objectives and generalresponse actions

Potential remedial technologies and the need foror usefulness of treatability studies

Potential ARARs associated with the location andcontaminants of the site and the potentialresponse actions being contemplated

Whether a temporary site office should be set upto support site work

Once the scope has been agreed upon with EPA, thecontractor will (1) develop the specific project plans tomeet the objectives of the RI/FS2 and (2) initiatesubcontractor procurement and coordination withanalytical laboratories. The project plans will include:a work plan which provides a project description andoutlines the overall technical approach, complete withcorresponding personnel requirements, activityschedules, deliverable due dates, and budgetestimates for each of the specified tasks; a samplingand analysis plan [composed of the field samplingplan (FSP) and the quality assurance project plan(QAPP)]; a health and safety plan; and a communityrelations plan. The latter three plans are describedbelow.

Sampling and Analysis Plan - The contractor willprepare a SAP which will consist of the following:

2 At some sites it may be necessary toplan initially until more is learned aboutmore thorough project planning effortdevelop final workplans.

submit an interim workthe site. A subsequent,can then be used to

Field Sampling Plan. The FSP should specify andoutline all necessary activities to obtain additional sitedata. It should contain an evaluation explaining whatadd i t iona l da ta a re requ i red to adequate lycharacterize the site, conduct a baseline riskassessment, and support the evaluation of remedialtechnologies in the FS. The FSP should clearly statesampling objectives; necessary equipment; sampletypes, locations, and frequency; analyses of interest;and a schedule stating when events will take placeand when deliverables will be submitted.

Quality Assurance Project Plan. The QAPP shouldaddress all types of investigations conducted andshould include the following discussions:

A project description (should be duplicated fromthe work plan)

A project organization chart illustrating the lines ofresponsibility of the personnel involved in thesampling phase of the project

Quality assurance objectives for data such as therequired precision and accuracy, completeness ofdata, representativeness of data, comparability ofdata, and the intended use of collected data

Sample custody procedures during samplecollection, in the laboratory, and as part of thefinal evidence files

The type and frequency of calibration proceduresfor field and laboratory instruments, internalquality control checks, and quality assuranceperformance audits and system audits

Preventative maintenance procedures andschedule and corrective action procedures forfield and laboratory instruments

Specific procedures to assess data precision,representativeness, comparability, accuracy, andcomp le teness o f spec i f i c measurementparameters

Data documentation and tracking procedures

Standard operating procedures for QA/QC thathave been established within EPA will bereferenced and not duplicated in the QAPP.

Health and Safety Plan - The contractor will developan HSP on the basis of site conditions to protectpersonnel involved in site act ivi t ies and thesurrounding community. The plan should address allapplicable regulatory requirements contained in 20CFR 1910.120(i)(2) - Occupational Health and SafetyAdministration, Hazardous Waste Operations andEmergency Response, Interim Rule, December 19,1986; U.S. EPA Order 1440.2 - Health and Safety

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Requirements for Employees Engaged in FieldActivities; U.S. EPA Order 1440.3 - RespiratoryProtection; U.S. EPA Occupational Health and SafetyManual; and U.S. EPA Interim Standard OperatingProcedures (September, 1982). The plan shouldprovide a site background discussion and describepersonnel responsibilities, protective equipment,heal th and safety procedures and protocols,decontamination procedures, personnel training, andtype and extent of medical surveillance. The planshould identify problems or hazards that may beencountered and how these are to be addressed.Procedures for protecting third parties, such asvisitors or the surrounding community, should also beprovided. Standard operating procedures forensuring worker safety should be referenced andnot duplicated in the HSP.

Community Relations Plan - The contractor willprepare a community relations plan on how citizenswant to be involved in the process based oninterviews with community representatives andleaders. The CLP wi l l descr ibe the types ofinformation to be provided to the public and outlinethe opportunities for community comment and inputduring the RI/FS. Deliverables, schedule, staffing, andbudget requirements should be included in the plan.

The work plan and corresponding activity plans will besubmitted to EPA as specified in the contract or asdiscussed in the initial meeting(s). The contractor willprovide a quality review of all project planningdeliverables.

Task 2 Community Relations

The contractor will provide the personnel, services,materials, and equipment to assist EPA in undertakinga community relations program. This program will beintegrated closely with all remedial response activities

to ensure community understanding of actions beingtaken and to obtain community input on RI/FSprogress. Community relations support provided bythe contractor will include, but may not be limited to,the following:

Revisions or additions to community relationsplans, including definition of community relationsprogram needs for each remedial activity

Es tab l i shment o f a commun i ty in fo rmat ionrepository(ies), one of which will house a copy ofthe administrative record

Preparation and dissemination of news releases,fact sheets, slide shows, exhibits, and otheraudio-visual materials designed to apprise thecommunity of current or proposed activities

Arrangements of briefings, press conferences,workshops, and public and other informalmeetings

Analysis of community attitudes toward theproposed actions

Assessment of the successes and failures of thecommunity relations program to date

Preparation of reports and participation in publicmeetings, project review meetings, and othermeetings as necessary for the normal progress ofthe work

S o l i c i t a t i o n , s e l e c t i o n , a n d a p p r o v a l o fsubcontractors, if needed

Deliverables and the schedule for submittal will beidentified in the community relations plan discussedunder Task 1.

Task 3 Field Investigations

The contractor will conduct those investigationsnecessary to characterize the site and to evaluate theactual or potential risk to human health and theenvironment posed by the site. Investigation activitieswill focus on problem definition and result in data ofadequate technical content to evaluate potential risksand to support the development and evaluation ofremedial alternatives during the FS. The aerial extentof investigation will be finalized during the remedialinvestigation.

Site investigation activities will follow the plansdeveloped in Task 1. Strict chain-of-custodyprocedures will be followed and all sample locationswill be identified on a site map. The contractor willprovide management and QC review of all activitiesconducted under this task. Activities anticipated forthis site are as follows:

Surveying and Mapping of the Site3 - Develop amap of the site that includes topographicinformation and physical features on and near thesite. If no detailed topographic map for the siteand surrounding area exists, a survey of the sitewill be conducted. Aerial photographs should beused, when available, along with informationgathered during the preliminary site visit toidentify physical features of the area.

Waste Characterization - Determine the location,type, and quantities as well as the physical orchemical characteristics of any waste remainingat the site. If hazardous substances are held in

3 May be conducted under Task 1 as part of the site visit orlimited investigation.

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containment vessels, the integri ty of thecontainment structure and the characteristics ofthe contents will be determined.

Hydrogeologic Investigation - Determine thepresence and potential extent of ground watercontamination. Efforts should begin with a surveyof previous hydrogeologic studies and otherexisting data. The survey should address thesoi l ’s retent ion capacity/mechanisms, dis-charge/recharge areas, regional flow directionsand qual i ty, and the l ikely ef fects of anyalternatives that are developed involving thepumping and disruption of ground water flow.Results from the sampling program shouldestimate the horizontal and vertical distribution ofcontaminants, the contaminants’ mobility, andp r e d i c t t h e l o n g - t e r m d i s p o s i t i o n o fcontaminants.

Soils and Sediments Investigation - Determinethe vertical and horizontal extent of contaminationof surface and subsurface soils and sedimentsand identify any uncertainties with this analysis.Information on local background levels, degree ofhazard, location of samples, techniques used, andmethods of analysis should be included. If initialefforts indicate that buried waste may be present,the probable locations and quantities of thesesubsurface wastes should be identified throughthe use of appropriate geophysical methods.

Surface Water Investigation - Estimate the extentand fate of any contamination in the nearbysurface waters. This effort should include anevaluation of possible future discharges and thedegree of contaminant dilution expected.

Air Investigation - Investigate the extent ofatmospheric c o n t a m i n a t i o n f r o m t h o s econtaminants found to be present at the site. Thiseffort should assess the potent ial of thecontaminants to enter the atmosphere, local windpatterns, and the anticipated fate of airbornecontaminants.

Information from this task will be summarized andincluded in the RI/FS report appendixes.

Task 4 Sample AnalysislValidationThe contractor will develop a data managementsystem including field logs, sample management andtracking procedures, and document control andinventory procedures for both laboratory data andfield measurements to ensure that the data collectedduring the investigation are of adequate quality andquantity to support the risk assessment and the FS.Collected data should be validated at the appropriatefield or laboratory QC level to determine whether it isappropriate for its intended use. Task management

and quality controls will be provided by the contractor.The contractor will incorporate information from thistask into the RI/FS report appendixes.

Task 5 Data EvaluationThe contractor will analyze all site investigation dataand present the results of the analyses in anorganized and logical manner so that the relationshipsbetween site investigation results for each mediumare apparent. The contractor will prepare a summarythat describes (1) the quantities and concentrations ofspecific chemicals at the site and the ambient levelssurrounding the site; (2) the number, locations, andtypes of nearby populations and activities; and (3) thepotential transport mechanism and the expected fateof the contaminant in the environment.

Task 6 Risk Assessment

The contractor shal l conduct a basel ine r iskassessment to assess the potential human health andenvironmental risks posed by the site in the absenceof any remedial action. This effort will involve fourcomponents: contaminant identification, exposureassessment, t o x i c i t y a s s e s s m e n t , a n d r i s kcharacterization.

Contaminant Identification - The contractor willreview available information on the hazardoussubstances present at the site and identify themajor contaminants of concern. Contaminants ofconcern should be selected based on theirintrinsic toxicological properties because they arepresent in large quantities, and/or because theyare currently in, or potentially may migrate into,critical exposure pathways (e.g., drinking water).

Exposure Assessment - The contractor willidentify actual or potential exposure pathways,characterize potentially exposed populations, andevaluate the actual or potent ial extent ofexposure.

Toxicity Assessment - The contractor will providea toxicity assessment of those chemicals found tobe of concern during site investigation activities.This will involve an assessment of the types ofadverse hea l th o r env i ronmenta l e f fec tsassociated with chemical exposures, therelationships between magnitude of exposuresand adverse effects, and the related uncertaintiesfor contaminant toxicity, (e.g., weight of evidencefor a chemical’s carcinogenicity).

Risk Characterization - The contractor willintegrate information developed during thee x p o s u r e a n d t o x i c i t y a s s e s s m e n t s t ocharacterize the current or potential risk to humanhealth and/or the environment posed by the site.This characterization should identify the potential

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for adverse health or environmental effects for thec h e m i c a l s o f c o n c e r n a n d i d e n t i f y a n yuncertainties associated with contaminant(s),toxicity(ies), and/or exposure assumptions.

The risk assessment will be submitted to EPA as partof the RI report.

Task 7 Treatability StudiesThe contractor will conduct bench and/or pilot studiesas necessary to determine the suitability of remedialtechnologies to site conditions and problems.Technologies that may be suitable to the site shouldbe identified as early as possible to determinewhether there is a need to conduct treatability studiesto better estimate costs and performance capabilities.Should treatability studies be determined to benecessary, a testing plan identifying the types andgoals of the studies, the level of effort needed, aschedule for completion, and the data managementguidelines should be submitted to EPA for review andapproval. Upon EPA approval, a test facility and anynecessary equipment, vendors, and analyticalservices will be procured by the contractor.

Upon completion of the testing, the contractor willevaluate the results to assess the technologies withrespect to the goals identified in the test plan. Areport summarizing the testing program and its resultsshould be prepared by the contractor and presentedin the final RI/FS report. The contractor will implementall management and QC review activities for this task.

Task 8 RI Report

Monthly reports will be prepared by the contractor todescribe the technical and financial progress at theOTR site. Each month the following items will bereported:

Status of work and the progress to date

Percentage of the work completed and the statusof the schedule

Difficulties encountered and corrective actions tobe taken

The activity(ies) in progress

Activities planned for the next reporting period

Any changes in key project personnel

Actual expenditures (including fee) and directlabor hours for the reporting period and for thecumulative term of the project

Projection of expenditures needed to completethe project and an explanation of significantdepartures from the original budget estimate

Monthly reports will be submitted to U.S. EPA asspecified in the contract. In addition, the activitiesconducted and the conclusions drawn during theremedial investigation (Tasks 3 through 7) will bedocumented in an RI report (supporting data andinformation should be included in the appendixes ofthe report). The contractor will prepare and submit adraft RI report to EPA for review. Once comments onthe draft RI report are received, the contractor willprepare a final RI report reflecting these comments.

Task 9 Remedial Alternatives Development andScreening

The contractor will develop a range of distinct,hazardous waste management alternatives that willremediate or control any contaminated media (soil,surface water, ground water, sediments) remaining atthe site, as deemed necessary in the RI, to provideadequate protection of human health and theenvironment. The potential alternatives shouldencompass, as appropriate, a range of alternatives inwhich treatment is used to reduce the toxicity,mobility, or volume of wastes but vary in the degreeto which long-term management of residuals oruntreated waste is required, one or more alternativesinvolving containment with little or no treatment; and ano-action alternative. Alternatives that involveminimal efforts to reduce potential exposures (e.g.,site fencing, deed restrictions) should be presentedas “limited action” alternatives.

The following steps will be conducted to determinethe appropriate range of alternatives for this site:

Establish Remedial Action Objectives andGeneral Response Actions 4 - Based on existinginformation, si te-specif ic remedial act ionobjectives to protect human health and theenvironment should be developed. The objectivesshould specify the contaminant(s) and media ofconcern, the exposure route(s) and receptor(s),and an acceptable contaminant level or range oflevels for each exposure route (i.e., preliminaryremediation goals).

Preliminary remediation goals should be establishedbased on readily available information (e.g., Rfds) orchemical-specif ic ARARs (e.g., MCLs). .Thecontractor should meet with EPA to discuss theremedial action objectives for the site. As moreinformation is collected during the RI, the contractor,

4 Preliminary remedial action objectives are developed as part ofthe project planning phase.

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in consultation with EPA, will refine remedial actionobjectives as appropriate.

General response actions will be developed for eachmedium of interest defining contaminant, treatment,excavation, pumping, or other actions, singly or incombination to satisfy remedial action objectives.Volumes or areas of media to which general responseactions may apply shall be identified, taking intoaccount requirements for protectiveness as identifiedin the remedial action objectives and the chemicaland physical characteristics of the site.

Identify and Screen Technologies - Based on thedeveloped general response actions, hazardouswaste treatment technologies should be identifiedand sc reened to ensure tha t on ly thosetechnologies applicable to the contaminantspresent, their physical matrix, and other sitecharacteristics will be considered. This screeningwill be based primarily on a technology’s ability toeffectively address the contaminants at the site,but will also take into account a technology’simplementability and cost. The contractor willselect representat ive process opt ions, asappropriate, to carry forward into alternativedevelopment. The contractor will identify the needfor treatability testing (as described under Task 7)for those technologies that are probablecandidates for consideration during the detailedanalysis.

Configure and Screen Alternatives - The potentialtechnologies and process opt ions wi l l becombined into media-specif ic or si tewidealternatives. The developed alternatives should bedefined with respect to size and configuration ofthe representative process options; time forremediation; rates of flow or treatment; spatialrequirements; distances for disposal; and requiredpermits, imposed limitations, and other factorsnecessary to evaluate the alternatives. If manydist inct, viable opt ions are avai lable anddeveloped, a screening of alternatives will beconducted to limit the number of alternatives thatundergo the detailed analysis and to provideconsideration of the most promising processoptions. The alternatives should be screened on ageneral basis with respect to their effectiveness,implementability, and cost. The contractor willmeet with EPA to discuss which alternatives willbe evaluated in the detailed analysis and tofacilitate the identification of action-specificARARs.

Task 10 Detailed Analysis of Alternatives

The contractor will conduct a detailed analysis ofalternatives which will consist of an individual analysisof each alternative against a set of evaluation criteria

and a comparative analysis of all options against theevaluation criteria with respect to one another.

The evaluation criteria are as follows:

Overall Protection of Human Health and theEnvironment addresses whether or not a remedyprovides adequate protection and describes howrisks posed through each pathway are eliminated,reduced, or controlled through treatment,engineering controls, or institutional controls.

Compliance with ARARs addresses whether ornot a remedy will meet all of the applicable orrelevant and appropriate requirements of otherFederal and State environmental statutes and/orprovide grounds for invoking a waiver.

Long-Term Effectiveness and Permanencerefers to the ability of a remedy to maintainreliable protection of human health and theenvironment over time once cleanup goals havebeen met.

Reduction of Toxicity, Mobility, or Volume ThroughTreatment is the anticipated performance of thetreatment technologies a remedy may employ.

Short-Term Effectiveness addresses the periodof time needed to achieve protection and anyadverse impacts on human health and theenvironment that may be posed during theconstruction and implementation period untilcleanup goals are achieved.

I m p l e m e n t a b i l i t y i s the techn ica l andadministrative feasibility of a remedy, includingthe availability of materials and services neededto implement a particular option.

Cost includes estimated capital and operation andmaintenance costs. and net present worth costs.

State Acceptances (Support Agency) addressesthe technical or administrative issues andconcerns the support agency may have regardingeach alternative.

Community Acceptance5 addresses the issuesand concerns the public may have to each of thealternatives.

The individual analysis should include: (1) a technicaldescription of each alternative that outlines the wastemanagement strategy involved and identifies the key

5 These criteria will be addressed in the ROD once commentson the RI/FS report and proposed plan have been receivedand will not be included in the RI/FS report..

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ARARs associated with each alternative; and (2) adiscussion that profiles the performance of thatalternative with respect to each of the evaluationcriteria. A table summarizing the results of thisanalysis should be prepared. Once the individualanalysis is complete, the alternatives wi l l becompared and contrasted to one another with respectto each of the evaluation criteria.

Task 11 FS Report(s)

Monthly contractor reporting requirements for the FSare the same as those specified for the RI under Task8.

The contractor will present the results of Tasks 9 and10 in a FS report. Support data, information, andcalculations will be included in appendixes to thereport. The contractor will prepare and submit a draftFS report to EPA for review. Once comments on thedraft FS have been received, the contractor willprepare a final FS report reflecting the comments.6

Copies of the final report will be made and distributedto those individuals identified by EPA.

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6 The final FS report may be bound with the final RI report.

Appendix DBibliography of Technology Process Resource Documents

I. Containment Technologies

Capping

Lutton, R.J. 1982. Evaluating Cover Systems for Solidand Hazardous Waste. SW867 (Revised Edition),U.S. EPA, Washington, DC.

The Asphalt Institute. Nov. 1976. Aspha l t inHydraulics. Manual Series No. 12 (MS-12), The

Lutton, R.J. et al. 1979. Design and Construction ofCovers for Solid Waste Landfills. EPA-600/2-

Asphalt Institute. 79-165, U.S. EPA, Cincinnati, OH.

Brady, N.C. 1974. The Nature and Properties of Soils.8th Ed., MacMillan, NY.

Brawner, C.O., Ed. 1980. First Internat ionalConference on Uranium Mine Waste Disposal.Society of Mining Engineers AIME, NY.

Chamberlain, E.J., and A.J. Gow. 1979. Effect ofFreezing and Thawing on the Permeability andStructure of Soils. Engineering Geology, 13 ,Elsevier Scientific Publishing Co., Amsterdam, TheNetherlands, pp. 73-92.

Daniel, D.E., and H.M. Liljestrant, Univ. of Texas.Jan. 1984. Effects of Landfill Leachates on NaturalL iner Sys tems. Chemical Manufacturer ’sAssociation.

England, C.B. 1970. Land Capability; A HydrologicResponse Unit in Agricultural Watersheds. ARS41-172, Agricultural Research Service, U.S.Department of Agriculture.

Ghassemi, M. May 1983. Assessment of Technologyfor Constructing and Installing Cover and BottomLiner Systems for Hazardous Waste Facilities. Vol.1 , E P A C o n t r a c t N o . 6 8 - 0 2 - 3 1 7 4 , w o r kassignment No. 109, U.S. EPA.

Kays, W.B. 1977. Construction of Linings forReservoirs, Tanks, and Pollution Control Facilities.John Wiley & Sons, NY.

Kmet, P., K.J. Quinn, and C. Slavik. Sept. 1981.Analysis of Design Parameters Affecting theCollection Efficiency of Clay Lined Landfills. Univ.of Wisconsin Extension.

Lambe, W.T., and R.V. Whitman. 1979. Sol idMechanics, SI Version. John Wiley and Sons, NY.

Morrison, W.R., and L.R. Simmons. 1977. Chemicaland Vegetative Stabilization of Soil: Laboratory andField Investigations of New Materials and Methodsfor Soil Stabilization and Erosion Control. Bureau ofReclamation Report No. 7613.

Oldham, J.C., et al. 1977. Materials Evaluated asPotential Soil Stabilizers. Paper No. S-77-15Army Engineers, Waterways Experimental Station,Vicksburg, MS.

Richards, L.A. 1965. Physical Condition of Water inSoil. In: Methods of Soil Analysis - Part . C.A.Black, Ed., American Society of Agronomy, Inc.

Schroeder, P.R., et al. The Hydrologic Evaluation ofLandfil l Performance (HELP) Model. Vol. 1,EPA/530-SW-84-009, U.S. EPA.

Tchobanoglous, G., et al. 1977. So l id Was tes :Engineering Principles and Management Issues.McGraw-Hill, NY.

U.S. EPA. Construction Quality Assurance forHazardous Waste Land Disposal Facilities. PublicComment Draft, J.G. Herrmann, Project Officer.EPA/530-SW-85-021, U.S. EPA.

U.S. EPA. July 1982. Draft RCRA GuidanceDocument Landfill Design, Liner Systems and FinalCover. U.S. EPA.

D - 1

U.S. EPA. 1983. Lining of Waste Impoundment andDisposal Facilities. SW870, U.S. EPA.

U.S. EPA. Procedures for Modeling Flow ThroughClay L iners to De te rmine Requ i red L inerThickness. EPA/530-SW-84-001, U.S. EPA.

Warner, R.C., et al. Demonstration and Evaluation ofthe Hydrologic Effectiveness of a Three LayerLandf i l l Surface Cover Under S tab le a n dSubsidence Conditions - Phase I, Final ProjectReport.

Warner, R.C., et al. Multiple Soil Layer HazardousWaste Landfill Cover: Design, Construction,Instrumentation and Monitoring. In: Land Disposalof Hazardous Waste Proceedings of the TenthAnnual Research Symposium.

Dust Controls

Ritter, L. J., Jr., and R.J. Paquette. 1967. HighwayEngineering. 3d Ed., The Ronald Press Co., NY.pp. 726-728.

Horizontal Barriers

Bureau of Reclamation. Pressure Grouting. TechnicalMemo 646.

U.S. EPA. Handbook for Evaluating Remedial ActionTechnology Plans.

Sediment Control Barriers

California Department of Conservation. May 1978.Erosion and Sediment Control Handbook.Department of Conservation, State of California.

U.S. EPA. August 1972. Guidelines for Erosion andSediment Control Planning and Implementation.U.S. EPA, Environmental Protection TechnicalServices.

U.S. EPA. Sept. 1978. Management of BottomSediment Containing Toxic Substance Procedure,3rd vs - Japan Meeting. U.S. EPA.

U.S. EPA. June 1982. Handbook - Remedial Actionat Waste Disposal Sites. EPA-625/6 -6 -82-006, U.S. EPA, Cincinnati, OH.

Surface Controls

Lutton, R.J., et al. 1979. Design and Construction ofCovers for Solid Waste Landfills. EPA-600/2-79-165, U.S. EPA Cincinnati, OH.

U.S. EPA. July 1982. Draft RCRA GuidanceDocument Landfill Design, Liner Systems, andFinal Cover. U.S. EPA.

U.S. EPA. June 1982. Handbook - Remedial Actionat Waste Disposal Sites. EPA-625/6 -6 -82-006, U.S. EPA, Cincinnati, OH.

Vertical Barriers

Bureau of Reclamation. Pressure Grouting. TechnicalMemo. 646.

Shuster, J. 1972. Controlled Freezing for TemporaryGround Support. Proceedings, 1st North AmericanRapid Excavation and Tunneling Conference.

Xanthakos, P. SIurry Walls. McGraw Hill, NY.

II. Treatment Technologies

Air Emission Controls/Gas Treatment

Bonner, T., et al. 1981. Hazardous Waste IncinerationEngineering. Noyes Data Corporation.

Kern, D.Q. 1950. Process Heat Transfer. McGraw-Hill, NY.

Kohl, A., and F. Riesenfeld. 1979. Gas Purification.Gulf Publishing Co.

Perry and Chilton Chemical Engineers’ Handbook. 5thEd., 1973, McGraw-Hill, NY.

Research and Education Association. 1978. ModernPollution Control Technology. Vol. 1, Air PollutionControl. Research and Education Association.

Biological Treatment

Benefield, L.D., and C.W. Randall. 1980. BiologicalProcess Design for Wastewater Treatment.Prentice- Hall, Englewood Cliffs, NJ.

Clark, J.W., W. Viessman, Jr., and J. Hammar. 1977.Water Supply and Pollution Control. IEP, Dun-Donnelly, NY.

Eckenfelder, W., Jr. 1980. Principles of Water QualityManagement. CBI Publishing, Boston.

Fair, G., J. Geyer, and D. Okun. 1968. Water andWastewater Engineering. Vol. 2, John Wiley, NY.

Junkins, R., et al. 1983. The Activated SludgeProcess: Fundamentals of Operation. Ann ArborScience Publishers, Ann Arbor, Ml.

Manual of Practice No. 16, Anaerobic SludgeDigestion. W PCF, 1968.

Metcalf & Eddy. 1972. Wastewater Engineering:Treatment, Disposal, Reuse. 2nd Ed., McGraw-Hill, NY.

D - 2

Overcash. 1979. Design of Land Treatment Systemsfor Industrial Wastes.

Shreve, R. N., and J.A. Brink, Jr. 1977. ChemicalProcess Industries. McGraw-Hill, NY.

Smith, E.D., et al. 1980. Proceedings First NationalSymposium/Workshop, Rotat ing BiologicalContractor Technology. University of Pittsburgh.

Speece, R.E., and J.F. Malina, Jr., Eds. 1973.Applications of Commercial Oxygen to Water andWastewater Systems. Univ. of Texas, Austin.

U.S. EPA. Dec. 1985. Guide for Identifying CleanupAlternatives at Hazardous- Waste Sites and Spills.EPA/600/3-83/063; NTIS PB86-144664, U.S.EPA.

U.S. EPA. 1980. Hazardous Waste Land Treatment,EPA SW 874, U.S. EPA.

U.S. EPA. Dec. 1984. Permit Guidance Manual onHazardous Waste Land Treatment Demonstrations.Draft, EPA 530-SW-84-015, U.S. EPA.

U.S. EPA. Process Des ign Manua l , S ludgeTreatment and Disposal. U.S. EPA.

U.S. Municipal Environmental Research Laboratory.Oct. 1983. Process Design Manual for LandApplication of Municipal Sludge. EPA 625/l-83-016, U.S. EPA.

Vesilind, P.A. Sludge Treatment and Disposal.

Chemical Treatment

Audrieth, L.F., and B.A. Ogg. 1951. The Chemistry ofHydrazine. John Wiley, NY.

Berkowitz, J.B., et al. 1978. Unit Operations forTreatment of Industrial Wastes. Noyces DataCorp., Park Ridge, NJ.

Butler, J.W. 1964. Solubility and pH Calculations.Addision-Wesley.

Duffey, J.G., S.B. Gale, and S. Bruckenstein.Electrochemical Removal of Chromates and OtherMetals. In: Cooling Towers. Vol. 2, pp 44-50.

Metcalf & Eddy, Inc., revised by Tchobanoglous, G.1979. Wastewater Engineering: Treatment,Disposal, Reuse. 2nd Ed.

McHugh, M.A., and V.J. Krukonis. 1986. SupercriticalF lu id Ex t rac t ion Pr inc ip les and Prac t i ce .Butterworth Publishers, Boston.

Reduction by Direct Current (ElectrochemicalTreatment) References: Scull, G.W., and K.D.Uhrich. Electrochemical Removal of Heavy Metalsin the Presence of Chelating Agents. A n d c oEnvironmental Processes, Inc., Amherst, NY.

Simpson, D.K. Safety Handling Hydrazine. Preparedfor the Water Industrial Power Conference,Southfield, MI, Oct. 16-19, 1983.

Tsusita, R.A., et al. 1981. Pretreatment of IndustrialWastes Manual of Practice. No. FD-3, WaterPollution Control Federation, Washington, DC.

In Situ Treatment

Ahlert, R.C., and D.S. Kosson. In-Situ and On-SiteBiodegradation of Industrial Landfill Leachate.NTIS, Springfield, VA.

American Petroleum Institute. Feb. 1982. Enhancingthe Microbial Degradat ion of UndergroundGasoline by Increasing Available Oxygen. TexasResearch Institute.

References on the use of H202 in SubsurfaceBioreclamation: American Petroleum Institute.1985. Feasibility Studies on the Use of HydrogenPeroxide to Enhance Microbial Degrations ofGasoline. API Publication 4389.

Baker, R., et al. Oct. 1986. In Situ Treatment for SiteRemediation. Paper presented at Third AnnualHazardous Was te Law and ManagementConference, Seattle, WA, and Portland, OR.

Ellis, W.D., and T.R. Fogg. August 1986. Treatmentof Soi ls Contaminated With Heavy Metals.EPA/600/9-86/022, U.S. EPA, pp. 201-207.

Flathman, P.E., and J.A. Caplan. April 1985.Biological Cleanup of Chemical Spills. Paperpresented at Hazmacon ‘85 Conference, Oakland,CA.

Nyer, E.K. 1985. Treatment Methods for OrganicContaminants: Biological Methods - In SituTreatment. In Groundwater Treatment Technology.Van Nostrand Reinhold. pp: 10-108.

U.S. EPA. 1985. In Situ Treatment - Bioreclamation.In Remedial Action at Waste Disposal Sites.Revised, EPA/625/6/-85/006, U.S. EPA.

U.S. EPA. Sept./Nov. 1984. Review of In-PlaceTreatment Techniques for Contaminated SurfaceSoils. Vol. 1, Technical Evaluation, Vol. 2,Background Information for In Situ Treatment.E P A - 5 4 0 / 2 - 8 4 - 0 0 3 a , a n d E P A - 5 4 0 / 2 8 4 -003b, (NTIS PB-124881 and PB-124899), U.S.EPA.

D - 3

Ward, C.H., a n d M . D . L e e . 1 9 8 5 . I n S i t uTechnologies. In Groundwater Pollution Control.Canter and Knox, Eds., Lewis Publishers.

Wetzel, R.S., et al. August 1986. Field Demonstrationof In Situ Biological Treatment of ContaminatedGroundwater and Soils. EPA/600/9-86/022, U.S.EPA, pp. 146-160.

Yaniga, P.M., and W. Sanith. 1984. AquiferRestoration via Accelerated In Situ Biodegradationof Organic Contaminants. In Proceed ings ,N W W A / A P I C o n f e r e n c e o n P e t r o l e u mHydrocarbons and Organ ic Chemica ls i nGroundwater - Prevent ion, Detect ion, andRestoration. pp. 451-470.

Physical Treatment

Cheremisinoff, P.N., and F. Ellerbusch. 1980. CarbonAdsorption Handbook. Science Publishers, AnnArbor, Ml.

Cheremisinoff, N., and Azbel, D. 1983. L iqu idFiltration. Science Publishers, Ann Arbor, Ml.

Dobbs, R.A., and J.M. Cohen. April, 1980. CarbonAdsorption Isotherms for Toxic Organics. EPA-600/8-80-023, U.S. EPA.

Gosset, J.M., et al. June 1985. Mass TransferCoefficients and Henry’s Constants for Packed-Tower Air Str ipping of Volat i le Organics:Measurement and Correlation. ESL-TR-85-18,Final Report, U.S. Air Force.

Kavanaugh, M.C., and R.R. Trussel. Dec. 1980.Design of Aeration Towers to Strip VolatileContaminants from Drinking Water. Journal AWWA.

Modern Pollution Control Technology, Vol. 2, WaterPollution Control. Research and Educat ionAssociation, 1978.

Perry and Chilton, Chemical Engineers’ Handbook.5th Ed., 1973, McGraw-Hill, NY.

Schweitzer, P.A. 1979. Handbook of SeparationTechniques for Chemical Engineers. McGraw-Hill,NY.

Shukla, Harish M., and Hicks, R.E. Process DesignManual for Stripping of Organics. EPA/600-/2-84-130, U.S. EPA.

Treybal, R. 1983. Mass Transfer Operations. 3rd Ed.McGraw-Hill, NY.

Solids Dewatering

Metca l f and Eddy , Inc . 1972. W a s t e w a t e rEngineering: Collection, Treatment, Disposal.McGraw-Hill, NY.

Perry and Chilton, Chemical Engineers’ Handbook.5th Ed., 1973, McGraw-Hill, NY.

Research and Education Association. 1978. ModernPollution Control Technology Vol. II, So/id WasteDisposal. Research and Education Association.

Solids Processing

Given, I.A. 1973. Mining Engineering Handbook.Society of Mining Engineers, NY.

Taggert, A.F. 1951. Elements of Ore Dressing. JohnWiley, NY.

Solidification, Fixation and Stabilization

Technical Handbook for Stabilization/SolidificationAlternatives for Remedial Action at UncontrolledHazardous Waste Sites. Environmental Laboratory,U.S. Army Engineers Waterways ExperimentStation, Vicksburg, MS.

U.S. EPA. Sept. 1982. Guide to the Disposal ofChemically Stabilized and Solidified Waste. EPADoc. No. SW-872. Municipal EnvironmentalResearch Laboratory, U.S. EPA, Cincinnati, OH.

U.S. EPA. June 1982. Remedial Action at WasteDisposal Sites. Municipal Environmental ResearchLaboratory, U.S. EPA, Cincinnati, OH.

Thermal Treatment

Ahling, B. Nov. 1979. Destruction of ChlorinatedHydrocarbons in a Cement Kiln EnvironmentalScience and Technology. Vol. 13, No. 11.

Brunner, C.R. 1984. Incineration Systems Selectionand Design. Van Nostrand Reinhold, NY.

Environment Canada, Environmental ProtectionService, Environmental Impact Control Directorate,Waste Management Branch. 1982. DestructionTechnologies for Polychlorinated Biphenyls( P C B ) . B a s e d o n a r e p o r t t o t h e W a s t eManagement Branch by M.M. Di l lon Ltd.,Consulting Engineers and Planners, Toronto,Ontario, Canada.

Frankel, I., Sanders, N., and Vogel, G. 1983. Surveyof the Incineration Manufacturing Industry. CEP,March 1983.

D - 4

Journal of the Air Pollution Control Association. July1982, Vol. 32, No. 7.

U.S. EPA. Oct. 1983. Demonstration of SewerRelining by the lnsituform Process, Northbrook, IL.EPA-600/2-83-064.

Lauber, J.D. 1982. Burning Chemical Wastes asFuels in Cement Kilns. Journal of the Air PollutionControl Association, July 1982, Vol. 32, No. 7.

McBride, J.L., and Heimback, J.A. Skid MountedSystem Gives California Hazardous Wastes HotTime. Pollution Engineering, July 1982.

WPCF. 1980. Operation and Maintenance ofWastewater Collection Systems. Manual ofPractice No. 7, WPCF.

Drum and Debris Removal

McCarthy, J.J. Feb. 1982. Technology Assessment ofthe Vertical Well Chemical Reactor. EPA-600/2-82-005, Prepared for U.S. EPA, MunicipalEnvironmental Research Laboratory, Office ofResearch and Development.

U.S. EPA. June 1982. - Handbook - Remedial Actionat Waste Disposal Sites. EPA-625-6-6-82-006, Cincinnati, OH.

Enhanced Removal

Oberacker, D.A. 1984. Hazardous Waste Incineration Donaldson, E.C., G.U. Chilingarian, and T.F. Ven.Performance Evaluations by the United States 1985. Enhanced Oil Recovery. Fundamentals andEnvironmental Protection Agency. EPA-600/D-84-285. Prepared for U.S. EPA, Cincinnati, OH.

Analyses, 1, Elsevier Science Publishers B.V.,Amsterdam, The Netherlands.

Peters, J.A., T.W. Hughes, and R.E. Mourninghan.1983. Evaluation of Hazardous Waste Incinerationin a Cement Kiln at San Juan Cement. MonsantoResearch Co., Dayton, OH.

H.K. Van Poollen and Assoc., Inc. 1980. EnhancedOil Recovery. Pennwells Publishing Company,Tulsa, OK.

Seebold, J. A. Practical Flare Design. ChemicalEngineering, December 10, 1984.

Koltuniak, D.L. In Situ Air Str ipping CleansContaminated Soils. Chemical Engineering, August18, 1986, pp. 30-31.

U.S. Congress, Office of Technology Assessment,Industry, Technology, and Employment Program.1985. Superfund Strategy-Preventing a ToxicTomorrow.

Patton, C.C. 1981. Oilfield Water Systems, Norman,Oklahoma. Campbell Petroleum Series.

U.S. EPA. Sept. 1981. Engineering Handbook forHazardous Waste Incineration. NTIS Report No.P881-248163, Prepared fo r U .S . EPA byMonsanto Research Corp., Dayton, OH.

Schumacher, M.M., Ed. 1980. Enhanced Recovery ofResidual and Heavy Oils. Noyes Data Corp., ParkRidge, NJ. (Contains references.)

Excavation

Weltzman, L. 1983. Cement Kilns as HazardousWaste Incinerators. Environmental Progress, Feb.1983, Vol. 2, No. 1.

Peurifoy, R.L. 1970. Construction Planning,Equipment and Methods. 2nd Ed., McGraw-Hill,NY. (Somewhat dated but a good overview ofsolids handling equipment.)

Wilhelmi, A.R., and Knopp, P.V. Wet Air Oxidation -An Alternative to Incineration. CEP, Aug. 1979. Gas Collection

Williams, I.M., Jr. 1982. Pyrolytic IncinerationDestroys Toxic Wastes Recovers Energy. PollutionEngineering, July 1982.

Zanetti, W.J. Plasma: Warming Up to New CPIApplications. Chemical Engineering, December1983.

A r g o n n e N a t i o n a l L a b o r a t o r y . F e b . 1 9 8 2 .Environmental Impacts of Sanitary Landfills andAssociated Gas Recovery Systems. (ANL/CNSV-27), Argonne National Laboratory, Argonne, IL.

Emcon Associates. 1980. Methane Generation andRecovery From Landfills. Science Publishers, AnnArbor, Ml.

III. Removal/Collection Technologies

Clean/Replace Contaminated Water and SewerLines

Landfill Methane Recovery. 1983. Energy TechnologyReview #80. Noyes Data Corp.

Cleaning Pipelines: A Pigging Primer. ChemicalEngineering, Feb. 4, 1985.

Tchobanoglous, Theisen, and Eliassen. 1977. SolidWastes - Eng inee r i ng P r i nc ipa l s andManagement Issues. McGraw-Hill, NY.

D - 5

Groundwater Collection/Pumping IV. Disposal Technologies

Bureau of Reclamation. 1978. Drainage Manual. U.S.GPO, Washington, DC, 286 pp.

Bureau of Reclamation. 1981. Groundwater Manual.2nd Ed., U.S. GPO, Washington, DC, 480 pp.

Freeze, et al. 1979. Groundwater. Prentice-Hall inc.,Englewood Cliffs, NJ.

Johnson Division, UOP, Inc. 1975. Groundwater andWells. Johnson Division, UOP, Inc., Saint Paul,MN.

U.S. Army. 1971. Dewatering: Groundwater Controlfor Deep Excavations. Technical Manual No. 5818-5 , Prepared by the Army Eng ineersWaterways Experiment Station.

U.S. Department of Agriculture. 1971. Section 16,Drainage of Agricultural Land. In SCS NationalEngineering Handbook. Engineering Division SoilConservation Service, Washington, DC.

U.S. EPA. June 1982. Handbook for Remedial Actionat Waste Disposal Sites (Revised). EPA-625/6-85/006, Prepared by Hazardous Waste EngineeringResearch Laboratory, Cincinnati, OH.

U.S. EPA. RCRA Groundwater Monitoring TechnicalEnforcement Guidance Document (TEGD).

Atmospheric DischargeGCA Corp. Dec. 1984. Evaluation and Selection of

Models for Est imat ing Air Emissions fromHazardous Waste Treatment, Storage andDisposal Facilities. EPS-450/3-84-020.

Kohl, A., and F. Riesenfeld. 1979. Gas Purification,3rd Ed. Gulf Publishing Co.

Vogel, G. May 1985. Air Emission Control atHazardous Waste Management Facilities. Journalof the Air Pollution Control Association, May 1985.

Wastewater DischargeAprilFlorida Department of Environmental Regulation.

1981. Class V Injection Well Inventory.

U.S. EPA. Dec. 1977. An Introduction to theTechnology of Subsurface Wastewater Injection.EPA-600/2-77-240. Prepared for the U.S. EPAby Don L. Warner, University of Missouri-Rollaand Jay H. Lehr, National Water Well Association.

U.S. EPA. Sept. 1982. Fate of Priority Pollutants inPublicly Owned Treatment Works. Volumes I and II,EPA 440/1-82/303, U.S. EPA, Water and WasteManagement Series, Effluent Guidelines DivisionWH-522.

U.S. EPA. July 1980. Treatability Manual, VolumeTreatability Data. EPA-600/8-80-042a, U.S.EPA Research and Development Series.

V e r s a r , I n c . D e c . 1 9 7 9 . W a t e r - R e l a t e dEnvironmental Fate of 129 Priority Pollutants.Volumes I and II, NTIS PB80-204381, Versar,Inc., Springfield, VA. Prepared for U.S. EPA,Washington, DC.

D - 6

Appendix EDocumentation of ARARs

The accompanying table presents a suggested formatfor summarizing the identification and documentationof ARARs in the RI/FS process. This format assumesthat two previous ARARs identification steps havetaken place during the RI/FS. First, it assumes that alist of Federal and State ARARs has been developedthrough consultations between the lead and supportagencies. This list should include chemical-,location-, and action-specific requirements and, inthe case of multiple ARARs (e.g., both a Federal andState requirement for a particular chemical), theARAR to be used for the site or alternative (generallythe more stringent) should be specified. Second, itassumes that the key requirements and the reasonsfor their applicability or relevance and appropriatenesshave been integrated into the narrative descriptions ofeach alternative as part of the “Detailed Analysis”chapter in the FS report. This appendix, therefore,serves as a summary of the ARARs for eachalternative and indicates whether the alternative isanticipated to meet those ARARs, or, if not, what typeof waiver would be justified.

The suggested format for the documentation ofARARs is presented here in the form of an example.The example is intended for illustrative purposes only;the ARARs identified for the sample alternatives maynot be appropriate in a specific site situation.

The site in the example was a battery and cleaningsolution storage facility operated and closed prior tothe effective date of the RCRA hazardous wastestorage regulations. The site is also located in afloodplain. The site consists of two areas ofcontaminated soil: Area 1 is contaminated with lead;Area 2 is contaminated with TCE. There is also aground water plume associated with the site thatcontains levels of TCE as high as 100 ppb and leadas high as 500 ppb. The alternatives evaluated indetail for the site are:

Alternative 1 - No action

Alternative 2 - Capping of the contaminated soil;natural attenuation of the ground water

Alternative 3 - In situ soil vapor extraction of theTCE-contaminated soil; capping of the lead-

contaminated soil; ground water pump/treat withoffsite discharge to a nearby creek

Alternative 4 - In situ soil vapor extraction of theTCE-contaminated soil; in situ fixation of thelead-contaminated area, followed by a soil cap;ground water pump/treat with offsite discharge toa nearby creek

A l te rnat ive 5 - Inc inera t ion o f the TCE-con tamina ted so i l ; o f f s i t e d i s p o s a l o fnonhazardous ash in the Subtitle D facility; in situfixation of the lead-contaminated soil, followedby a soil cap; ground water pump/treat with offsite discharge to a nearby creek

For this example, it has been assumed that the TCEis not an RCRA-listed or characteristic waste but thatthe lead-contaminated area is hazardous because ofits characteristic of EP toxicity. Following in-situfixation, the lead-contaminated soil is anticipated tobe nonhazardous. Because none of the alternativesinvolves the placement of RCRA hazardous waste( lead-con tamina ted so i l ) , the land d isposa lrestrictions are assumed to be neither applicable norrelevant and appropriate.

The example also assumes that post-closure carerequ i rements o f RCRA (e .g . , g round wate rmonitoring) will generally be relevant and appropriatewherever closure is performed with waste in place.

Finally, it is also assumed that the RCRA locationstandards, while not applicable because none of thealternatives involve RCRA-regulated treatment,storage, or disposal, are nonetheless relevant andappropriate to all the action alternatives. Typically, therationale for determinations of applicability orrelevance and appropriateness will be integrated intothe description of alternatives in the detailed analysisof the FS report.

The following table identifies the applicable or relevantand appropriate requirements for each of the fivealternatives, indicates whether the alternative isexpected to achieve that standard, and notes anyARAR waivers that may be required-

E- 1

Case Example of Detailed Analysis

IntroductionPurpose

Site Background

This appendix provides an example of how the resultsof the individual and comparative analyses of remedialalternatives may be presented in the FS report. Asdiscussed in Chapter 6 of this guidance, the individualanalysis consists of a narrative description of thealternative including a discussion of how thealternative performs with respect to each of theevaluation criteria1 The comparative analysis thatfollows the individual analysis consists of a narrativediscussion summarizing the relative performance ofthe alternatives in relation to one another.

The amount of information presented in a detailedanalysis will depend on the complexity of the site andon the extent of invest igat ions and analysisconducted. In addition, as noted in Chapter 6, thelevel of detail and extent of discussion for theindividual subfactors under each criterion will varybased on the relevance of that particular criterion tothe alternatives being considered and the scope ofthe action being taken. Therefore, the amount ofdetail required to adequately document the results ofthe evaluations and the specific subfactors that willactually be discussed may differ somewhat from thatpresented in this case example.

The site used in this example is an old battery andcleaning solution storage facility located in a ruralarea. Improper handling and storage activities at thissite from 1968 to 1978 resulted in both soil andg r o u n d w a t e r c o n t a m i n a t i o n . T h e a r e a o fcontamination referred to as Area 1 contains 25,000cub ic yards (cy ) o f con tamina ted so i l w i thconcentrat ions of lead exceeding 200 mg/kg(concentrations of lead reach 500 mg/kg at severallocations within this area). There is also a discretearea of approximately 20,000 cy of TCE-contami-nated soil at the site referred to as Area 2. Analysis ofsoil samples from this area show TCE concentrationsup to 6 percent and slightly elevated levels of metalscompared to background. Al though the r iskassessment did not identify a human health orenvironmental risk from these metals, there is a smallpossibility that hot spots of metal contamination mayhave been missed. The soils of both Areas 1 and 2are fairly permeable. Figure F-l presents a simplisticmap of the site.

The reader should also keep in mind that an actualRI/FS report will typically include maps, plans,schematics, and cost details that would be presentedin previous chapters of the report (e.g., Developmentand Screening of Alternatives) or in the detailedanalysis chapter itself. The purpose of this particularexample is to give readers an idea of the types ofinformation that should be provided when describingind iv idua l a l te rnat ives and d iscuss ing the i rperformance against the evaluation criteria.

1 The criteria are discussed in the following order: overallprotection of human health and the environment; compliancewith ARARs; long-term effectiveness and permanence;reduction of toxicity, mobility, or volume through treatment;short-term effectiveness; implementability; and cost.Community and state acceptance will generally not beaddressed until the ROD, following receipt of formal commentson the RI/FS report and the proposed plan.

F-1

The affected aquifer is shallow, with the water tablelying approximately 12 feet under the site, and iscurrently used for drinking water. This aquifer has thecharacteristics of a Class IIA aquifer as defined underU.S. EPA’s Ground Water Classification System. Theaquifer consists of fractured bedrock, making groundwater containment technologies difficult to implement.Ground water extraction may also be difficult due tothe fractured bedrock. A plume of TCE above the 5mg/l Maximum Contaminant Level (MCL) (measuredas high as 50 ppm) is estimated to be moving in thedirection of residential wells at an interstitial velocityof 65 ft/yr. The nearest residential well is 600 feetf r o m t h e s i t e b o u n d a r y a n d t h e p l u m e o fcontaminated ground water is likely to reach the wellin an estimated 1 to 3 years at concentrationsexceeding federal drinking water standards. Samplingconducted during the RI shows that no existingresidential wells are currently contaminated.

The exposure pathways of concern identified duringthe baseline risk assessment include direct contactwith possible ingestion of contaminated soil (1 x1 0-3 associated excess cancer risk), and potentialingestion of contaminated ground water in the future

Figure F-1. Site map case example.

through existing or newly installed offsite wells (2 x1 0-2 associated excess cancer risk). The MCL forTCE (5 ) has been determined to be a relevanta n d a p p r o p r i a t e r e m e d i a t i o n l e v e l f o r t h econtaminated ground water at this site since theground water is used for drinking water. Based on thesite-specif ic r isk assessment, the MCL was

determined to be sufficiently protective as the aquiferremediation goal.

The risk assessment also concluded that 200 mg/kgfor lead in soil would be a protective level forexpected site exposures along with a 1 x 1 0- 6

F - 2

excess cancer risk level for TCE-contaminated soil(56 ppm). Based on investigations of activities at thesite, the TCE-contaminated soil has not beendetermined to be a listed, RCRA hazardous wastesince the cleaning solution records indicate thesolutions contained less than 10 percent TCE.However, the lead-contaminated soil is an RCRAhazardous waste by characteristic in this instance dueto EP-toxicity. None of the waste is believed to havebeen disposed at the site after November 19, 1980(the effective date for most of the RCRA treatment,storage, and disposal requirements).

the alternative reduces the risk from potentialexposure pathways through treatment, engineering, orinstitutional controls. This evaluation also examineswhether alternatives pose any unacceptable short-term or cross-media impacts.

The major Federal and State requirements that areapplicable or relevant and appropriate to eachalternative are identified. The ability of eachalternative to meet all of its respective ARARs or theneed to justify a waiver is noted for each.

The site is located in a state with an authorizedRCRA program for closure which subsumes Federalrequirements and specifies more stringent staterequirements. Therefore, only the state closurerequirements need to be analyzed for potentialapplicability or relevance and appropriateness to theremedial alternatives considered. No potentiallocation-specific ARARs have been identified for thissite.2 Additionally, this example assumes that EPAand the State have agreed upon what non-ARARinformation (i.e., guidance, advisories) is to beconsidered in designing the remedial alternatives.

Long-term effectiveness and permanence areevaluated with respect to the magnitude of residualrisk and the adequacy and reliability of controls usedto manage remaining waste (untreated waste andtreatment residuals) over the long-term. Alternativesthat af ford the highest degrees of long-termeffectiveness and permanence are those that leavelittle or no waste remaining at the site such thatlong- te rm ma in tenance and mon i to r ing a reunnecessary and reliance on institutional controls isminimized.

Detailed Analysis - Case ExampleIndividual Analysis of Alternatives

The assembled remedial action alternatives representa range of distinct waste management strategieswhich address the human health and environmentalconcerns associated with the site. Although theselected alternative will be further refined asnecessary dur ing the p redes ign phase, thedescription of the alternatives and the analysis withrespect to the nine criteria presented below reflectthe fundamental components of the var iousalternative hazardous waste management approachesbeing considered for this site.

The discussion on the reduction of toxicity, mobility,or volume through treatment addresses theanticipated performance of the treatment technologiesa remedy may employ. This evaluation relates to thestatutory preference for selecting a remedial actionthat employs treatment to reduce the toxicity,mobility, or volume of hazardous substances. Aspectsof this criterion include the amount of waste treatedor destroyed, the reduction in toxicity, mobility, orvolume, the irreversibility of the treatment process,and the type and quantity of residuals resulting fromany treatment process.

The primary components of each alternative are listedin Figure F-2 and a technical description of thesecomponents is presented. After the technicaldescription, a discussion of the alternative withrespect to overall protection of human health and theenvironment; compliance with ARARs; long-termeffectiveness and permanence; reduction of toxicity,mobility, or volume through treatment; short-termeffectiveness; implementability; and cost follows.

Evaluation of alternatives with respect to short-termeffectiveness takes into account protection of workersand the community during the remedial action,environmental impacts from implementing the action,and the time required to achieve cleanup goals.

The analysis of each alternative with respect tooveral l protect ion of human heal th and theenvironment provides a summary evaluation of how

The analysis of implementability deals with thetechnical and administrative feasibility of implementingthe alternatives as well as the availability of necessarygoods and services. This criterion includes suchitems as: the ability to construct and operatecomponents of the alternatives; the ability to obtainservices, capacities, equipment, and specialists; theability to monitor the performance and effectivenessof technologies; and the ability to obtain necessaryapprovals from other agencies.

2 Determinations of what standards/requirements are applicableor relevant and appropriate are made on a site-specific basisand, in some cases, on an alternative-specific basis.Therefore, the ARAR determinations in this example shouldnot be construed necessarily as appropriate rationales for suchdeterminations at other sites.

The cost estimates presented in this report areorder-of-magnitude level estimates. These costsare based on a variety of information including quotesfrom suppliers in the area of the site, generic unitcosts, vendor information, convent ional costestimating guides, and prior experience. Thefeasibility study level cost estimates shown have been

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Figure F-2. Alternative components case example.

prepared for guidance in project evaluation andimplementation from the information available at thetime of the estimate. The actual costs of the projectwill depend on true labor and material costs, actualsite conditions, competitive market conditions, finalproject scope, the implementation schedule, andother variable factors. A significant uncertainty thatwould affect the cost is the actual volumes ofcontaminated soil and ground water. Most of theseuncertainties would affect all of the costs presented inthis FS similarly.

Capital costs include those expenditures required toimplement a remedial action. Both direct and indirectcosts are considered in the development of capitalcost estimates. Direct costs include constructioncosts or expenditures for equipment, labor, andmaterials required to implement a remedial action.Indirect costs include those associated withengineering, permitting (as required), constructionmanagement, and other services necessary to carryout a remedial action.

Annual O&M costs, which include operation labor,maintenance materials, and labor, energy, and

purchased services, have also been determined. Theestimates include those O&M costs that may beincurred even after the initial remedial activity iscomplete. The present worth costs have beendetermined for 30 years at a 5 percent discount rate.

Alternative 1 - No Action

The no-action alternative provides a baseline forcomparing other alternatives. Because no remedialactivities would be implemented with the no-actionalternat ive, l o n g - t e r m h u m a n hea l t h andenvironmental risks for the site essentially would bethe same as those identified in the baseline riskassessment.

Criteria Assessment

Alternative 1 provides no control of exposure to thecontaminated soil and no reduction in risk to humanhealth posed through the ground water. It also allowsfo r the poss ib le con t inued mig ra t ion o f thecontaminant plume and further degradation of theground water.

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Because no action is being taken, it would not meetany app l i cab le o r re levan t and appropr ia terequirements such as the MCL for TCE.

This alternative includes no controls for exposure andno long-term management measures. All currentand potential future risks would remain under thisalternative.

This alternative provides no reduction in toxicity,mobility, or volume of the contaminated soil or groundwater through treatment.

There would be no additional risks posed to thecommunity, the workers, or the environment as aresult of this alternative being implemented.

There are no implementability concerns posed by thisremedy since no action would be taken.

The present worth cost and capital cost of Alternative1 are estimated to be $0 since there would be noaction.

Alternative 2-5: Common Components

Al l o f the remain ing a l te rna t i ves have fourcomponents in common (use of institutional controls,reconstruction of access road, erection of a fencearound the site, and ground water monitoring).Although the description of these components is notrepeated in the discussions for each alternative,differences in their planned implementation areidentified where appropriate.

Institutional controls: The current owner hasagreed to allow the state to place a deedrestriction on the site which would prohibit soilexcavation and construction of buildings on anypart of the site still containing hazardous materialsupon completion of the remedy.3 In addition, alocal ground water well regulation requiring statereview of all installation plans for ground waterwells would be used to prohibit the installation ofdrinking water supply wells in contaminated partsof the aquifer.

Road reconstruction: Some of the road on thesite (primarily near Area 2) would be restabilizedand improved to allow construction activities andthe movement of materials.

Fencing: Approximately 1,600 feet of fencingwould be installed around the perimeter of the siteto restrict public access. Signs warning of thepresence and potential danger of hazardousmaterials would be posted on the fence to furtherdiscourage unauthorized access to the site.

3 The legal authority to implement deed restrictions will vary fromstate to state. Therefore, a key factor to consider during theevaluation of institutional controls is whether a particular statecan actually impose restrictions on specific activities orwhether their authorities are limited to nonenforceable actionssuch as deed notices.

Ground water monitoring: Two new monitoringwells would be installed offsite. Analytical resultsfrom the new wells, some of the existing wells,and the residential wells would be used to monitorfuture conditions and to assess the effectivenessof the final action. Sampling would be conductedquarterly with four replicate samples at each well.The samples would be analyzed for volatiles andmetals and results compared to backgroundvalues using the Student’s T-test. If the meanvalue of any compound at any facility boundarywell is greater than background at the 0.05significance level in two successive samplingrounds, appropriate investigative and remedialaction(s) would be initiated as necessary.

Alternative 2 - Cap and Natural Attenuation

The primary components of Alternative 2 are cappingof Areas 1 and 2 and natural attenuation of thecontaminated ground water. Two caps would beins ta l led , a 3 -ac re cap over Area 1 ( lead-contaminated soil) and a 3-acre cap over Area 2(TCE-contaminated soi l ) . The cap would beconsistent with the State RCRA landfill closurerequirements. While these requirements are notapplicable since the action does not involve thedisposal of any RCRA hazardous waste, certainclosure requirements have nevertheless beendetermined to be relevant and appropriate to thisalternative. The State’s RCRA requirements are morespecific and stringent than the Federal requirements,which require a cap to have a permeability less thanor equal to the permeability of natural underlying soil.The soil/clay caps would include a 2-foot thickcompacted clay barrier layer with a permeability not toexceed 10-7 cm/sec, a geonet drainage layer, and acover layer equal to the average frost level(approximately 3.5 feet) above the barrier layer. Thiscover layer would include 6 inches of topsoil and 3feet of compacted native soil materials. The drainagelayer and the extra frost protection depth arenecessary because the rainfall rate would exceedsurface runoff and evaporation rates, and the averagefrost depth (3.5 feet) is greater than the minimum 2feet of cover recommended by U.S. EPA.

A geonet drainage layer was chosen for thisalternative since the Hydrologic Evaluation of LandfillPerformance (HELP) model showed it to be moreeffective than sand in controlling leachate productionbut it is comparable in cost. The HELP modelpredicted a 75 to 80 percent reduction in leachateproduction. Geotextile layers would be laid on eitherside of the geonet drain to prevent clogging. Aminimum slope of 3 percent would be provided tomeet state requirements. To achieve this slope, it isestimated that 4,000 cy of backfill material fromelsewhere on the site would have to be placed priorto cap construction.

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To determine the effect of natural attenuation on thecontaminated ground water, two assumptions aboutthe subsurface have been made. First, despite thefractured nature of the bedrock, it has been assumedthat the subsurface is homogeneous to facilitate theevaluation. Second, the potential for reduction in TCEconcent ra t ions has been assessed us ing ahydrogeologic model. The model took into accountthe fact that the cap would reduce existing leachateproduction by 75 percent. This model predicted thatthe concentration of TCE in the ground water wouldbe reduced to a 1 x 10-4 excess cancer risk level(280 at the edge of the contaminated soil areaswithin 35 years, a 1 x 10-5 excess cancer risk level(28 in 60 years, and a 1 x 10 -6 excess cancerrisk level (2.8 approximately equal to the MCL) inapproximately 100 years.

An alternate water supply would be included in thisalternative to provide a safe and reliable source ofdrinking water until levels in the aquifer reachedacceptable levels. The alternate system would consistof two new community wells4 installed upgradient ofthe contamination, 1,000 to 2,000 feet from the siteand a water main along the county road to feederpipes for each resident. The required pumpingcapacity is estimated to be 100 gpm and the wellswould provide water for the four residents locatedclosest to the site, downgradient of the contaminatedplume. The well water would be monitored for TCEand lead as part of the site-wide monitoring plan ona semiannual basis until the MCL levels are met andthen thereafter consistent with the relevant andappropriate aspects of the RCRA post-closure careprogram.

Criteria Assessment

Although protective of human health since exposureto all contamination would be controlled, Alternative 2would allow continued migration of the existingcontaminated ground water. I t would preventexposure to the contaminated soil and wouldminimize further release of contaminants to theground water by limiting future infiltration through thecap.

This alternative would control exposure to thecontaminated ground water through provision of analternate supply of dr inking water and deedrestrictions until the MCL for TCE is eventuallyreached. The ground water may require up to 100years of natural attenuation to reach the chemical-specific ARAR of 5 of TCE at the edge of thecontaminated soil. Landfill closure requirements arenot applicable to this alternative since the plannedactions do not involve the disposal of any RCRA

4 The actual location of these wells would be determined duringpredesign activities.

hazardous waste; however, certain landfill closurerequirements have been determined to be relevantand appropriate. This alternative would meet theRCRA landfill closure requirements by constructing asoil/clay cap that meets the State RCRA standards,and the guidance specifications that the lead andsupport agencies have agreed are to be considered(TBC).

In order for this alternative to remain effective overthe long-term, careful maintenance of the alternatewater supply through monitoring and periodic repair ofpipes and pumps and careful maintenance of ahealthy vegetative layer over the caps would berequired. Any erosional damage of the caps wouldhave to be repaired. Failure to address reduction inthe cap’s impermeability could result in increasedleachate production, subsequent ground watercontamination, and the potential for direct contactwith the contaminated soil. Because the contaminatedsoil would remain onsite and because the groundwater may remain contaminated above health-basedlevels for 100 years, long-term monitor ing,maintenance, and control would be required underthis alternative. An alternate water supply andinstitutional controls would be used to limit risk top r e s e n t a n d p o t e n t i a l f u t u r e u s e r s o f t h econtaminated ground water. The institutional controlswould only be effective with a high degree of certaintyin the short term, not over the long term; once alldesign and construction activities are complete. Thelocal municipality cannot ensure the enforceability ofthe local water use regulation beyond a few years.Because this alternative would leave hazardoussubstances onsite, a review would be conducted atleast every 5 years to ensure that the remedycontinues to provide adequate protection of humanhealth and the environment in accordance withCERCLA 121 (c).

This alternative would provide no reduction in thetoxicity, mobility, or volume of the contaminated soilor ground water through treatment. The 20,000 cy ofTCE-contaminated soil and 25,000 cy of lead-contaminated soil would remain onsite.

Within an est imated 6 months of beginningconstruction, the caps and the alternate water supplywould be installed preventing direct exposure andreducing ground water contaminant migration.Provision of the alternate water supply would alleviatethe risk from ingestion of contaminated ground water.The potential for a slight, temporary increase of riskto the community (and workers) due to particulateemissions during construction of the caps would becon t ro l l ed th rough the use o f dus t con t ro ltechnologies (e.g., water or foam sprays).

No special techniques, materials, permits, or laborwould be required to construct either the wells orcaps. The native soil and clay are available locally,

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within 20 miles of the site. About 50,000 cy of soiland clay would be needed to construct the caps. Theaction could be enhanced by enlarging the caps ifmore contaminat ion were discovered and byexpanding the alternate water supply if more residentswere affected than originally estimated.

The 30-year present worth cost of this alternative isestimated to be $4,800,000, with a capital cost of$4,200,000 and an annual O&M cost of $60,000.The capital cost is primarily for the installation of thecaps. The annual O&M costs are primarily for theground water monitoring program and for maintainingthe caps.

Alternative 3 - In Situ Soil Vapor Extraction, Cap,Ground Water Pump and Treat

This alternative consists of capping Area 1 (lead-contaminated soil) with the same soil/clay cap asdescribed in Alternative 2 (2 feet of clay underlying asurface drainage layer and 3.5 feet of soil), using insitu vapor extraction to treat the TCE-contaminatedsoil in Area 2, extracting the ground water, andtreating it onsite through an air stripping system anddischarging it to a tributary of North Creek.

The soil vapor extraction technology involvescollection of soil vapor from the unsaturated zone byapplying a vacuum at a series of extraction points.The vacuum not only draws vapor f rom theunsaturated zone, but also decreases the pressurearound the soil particles, thereby releasing additionalvolatiles. In addition, due to the pressure differential,clean air from the atmosphere enters the soil toreplace the extracted air.

Pilot tests conducted during the RI showed vaporextraction to be a feasible and effective technologyfor removing TCE from the soil at this site. It isanticipated that the TCE can be removed to 56 ppmwhich is the 1 x 10-6 risk level for the directcontact exposure route within 3 to 5 years. Thisrepresen ts a 99 .9 percen t reduc t ion in theconcentration. To provide flexibility of operation, thecontaminated area would be divided into two discreteareas, each with its own vapor extraction system. Themajor components of each vapor extraction systemwould include: 20 extraction wells, the necessarypiping and valves, and a positive displacement blower(vacuum pump). The air discharged would be sentthrough two activated carbon units and the carbonwould be regenerated for reuse.

Because the evacuation and collection of volatileswould be through a vacuum system, volat i lecontaminants would be controlled as a single pointemission. The potential for fugitive losses of aircontaminants would be minimal.

A ground water extraction scenario consisting of fivewells at a combined pumping rate of 300 gpm wasselected after a series of numerical simulations with avariety of well arrangements. This arrangement wasfound to provide more rapid restoration of the shallowaquifer than other arrangements evaluated (seeChapter # of the FS). The three onsite extractionwells would be located within the TCE plume butdowngradient of its center. They would reverse thena tu ra l g round wate r f l ow d i rec t ion o f fs i teimmediately, so the contaminants would not migratefurther than their existing location. The residentialwells should not be contaminated in the future.Because it was determined that the pumping rateshould not depress the ground water table more than10 feet, not all of the plume could be captured by theonsite wells. Two offsite wells would be used toremediate the area of the offsite contaminatedaquifer.

The ground water model simulation for this scenarioassumed that the soil remedial action would includetreatment of the TCE-contaminated soil to levelsindicated above, and that the lead-contaminated soilwould be capped. The simulation indicated that theshallow aquifer could be restored to 5 mg/l (MCL) in25 to 40 years. Without soil remediation, from 60 to100 years would be required. Monitoring would beused to determine when the ground water cleanupgoal of 5 had been reached at the boundaries ofthe waste management area and to evaluate theeffectiveness of the alternative.

To treat the extracted ground water, an air stripperwould be constructed on the site. The air stripperwould be a counter-current packed tower, where airenters at the bottom and exhausts at the top while theground water flows down through the media. The airstripper would be approximately 45 feet tall and 4 feetin diameter and would be designed to meet theperformance goal of 5 mg/l TCE concentrations. Theexhaust air would be discharged through carbon bedsto collect the volatiles by adsorption. The carbonwould be sent offsite for regeneration upon bedexhaustion. Because little iron or other metals are inthe ground water, no pretreatment to prevent foulingof the air stripper would be required.

Upon completion of ground water treatment, the waterwould be discharged offsite to the nearby tributary ofNorth Creek. An NPDES permit would be obtainedbefore implementation.

Criteria AssessmentThis alternative would protect both human health andthe environment. Soil vapor extraction and the capover the contaminated soil would reduce risk tohuman health by direct contact and soil ingestion.Ground water extraction and onsite treatment wouldreduce the threat to human health by ingestion of

contaminated ground water, and reduce the possibilityof further environmental degradation.

This alternative would meet the MCL for TCE. Tomeet action-specific ARARs, the air treatmentsystems for this alternative would be designed tomeet State air pollution control standards. Preliminaryanalysis also indicates that the ground watertreatment system can be designed to meet StateN P D E S l i m i t a t i o n s w h i c h w i l l r e s u l t i n n oexceedances of the Water Quality Standards in thec reek . Because the t rea tment o f the TCE-contaminated soil would be conducted entirely in situand the TCE is not a listed, RCRA hazardous waste,placement of RCRA hazardous waste would notoccur and the land disposal restrictions would not beapplicable nor relevant and appropriate. The capconstructed over Area 1 would meet the State RCRArequirements for landfill closure as under Alternative2.

To provide for long-term effectiveness of thisalternative, careful maintenance of the controls wouldbe needed. As discussed for Alternative 2, thealternate water supply and cap would requiremaintenance. Further ground water contamination isreduced by removal of TCE through soil vaporextraction. Because lead is not expected to migraterapidly, failure of the cap would increase the potentialrisk through direct contact but pose little or noconcern for further ground water contamination.Human health risks posed by ingestion of groundwater in the future would be reduced to less than5 by the pump and treat systems. However,because of the fractured nature of the bedrock, theability of the pump and treat system to effectivelyreach the cleanup goal is somewhat uncertain. Todetermine its long-term effectiveness and to lessenthe uncertainty of reaching cleanup goals, the ground

water pump and treat systems would be monitoredunder a long-term program. Necessary modificationsto either system would be made based on monitoringresults. The area treated by soil vapor extractionwould not require any additional maintenance ormonitoring upon completion of the technology. Thisalternative also would require a 5-year review.

Vapor extraction is an irreversible treatment processthat would reduce the toxicity of contaminated soil byremoving over 99.9 percent of TCE from 20,000 cy ofsoil. The TCE would be collected on carbon.5 The airstripper would also reduce the toxicity and mobility ofTCE in the ground water. Contaminants in the airstream would be collected on carbon and destroyedduring regeneration making this ground watertreatment component irreversible. This alternativew o u l d l e a v e 2 5 , 0 0 0 c y o f u n t r e a t e d l e a d -

5TCE would be destroyed by incineration when the carbon isregenerated.

contaminated soil onsite under a soil/clay cap. Thisalternative meets the statutory preference for usingtreatment as a principal element since the principalthreats are addressed through treatment.

During operation of the vapor extraction system, thecontaminated soil would remain uncovered, althoughthe fence to be installed around the site woulddiscourage trespassers and limit potential exposure.Although unlikely, the possibility of a small additionalrisk through inhalation to the community would exist ifthe extracted air collection system were to fail. Aswith the soil vapor extraction system, there is theslight additional risk of failure of the air collectionsystem on the air stripper. Safety techniquesincluding monitoring the equipment would be used tominimize any failures of the components. Once theextraction and treatment systems are installed, thecontaminant plume would begin to recede from itscurrent position. Between 25 and 40 years would berequired to reach ground water remediation goals,and 3 to 5 years of soil vapor extraction would berequired to reach soil remediation goals.

Th is a l te rna t ive invo lves the use o f p roventechnologies. The cap requires 25,000 cy of soil andclay to be brought to the site, placed, and graded toconstruct the cap. The onsite air stripper and bothgaseous carbon adsorption systems require availableequipment. Operation of the alternative would requirefrequent monitoring of the ground water and the air toassess the effectiveness of the soil vapor extractionand ground water extraction and treatment systems.Controlling operating conditions would be necessaryto improve the effectiveness of these systems. Soilvapor extraction uses reliable equipment. Engineeringjudgment would be required during operation todetermine the operating parameters of the alternative,such as air flow rate in the air stripper, the blowerspeed in the vapor extraction system, and TCE in theexhaust gas. All of the components could beexpanded if additional contamination were discovered.The 30-year present worth cost is estimated to be$7,300,000 with a projected $3,300,000 for capitalexpenditures and $440,000 for year 1 annual O&Mcosts. The most expensive item is the soil/clay capfollowed by the ground water treatment system. TheO&M costs would cover operating the soil and groundwater treatment systems from year 1 to 5. After year5 the O&M costs would drop to approximately$200,000 to continue ground water treatment andmonitoring.

Alternative 4 - In Situ Soil Vapor Extraction, InSitu Soil Fixation, Cap, and Ground Water Pumpand TreatThis alternative includes in situ soil vapor extraction ofTCE-contaminated soil (Area 2), in situ soil fixationof lead-contaminated soil (Area 1), cap (Area 1), and

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ground water pump and treat components ofAlternative 3.

The moisture content of the soil has been determinedto be approximately 50 percent under worst caseconditions. Using this information and results fromvendor tests, it has been determined that a minimumdose of one part solidification reagent to two parts soilis required for migration control of lead. Testing hasshown that the optimum solidification reagent mixturewould consist of approximately 50 percent fly ash and50 percent kiln dust. Thus, approximately 7,000 tonseach of fly ash and cement kiln dust would berequired. The reagents would be added in situ with abackhoe. As one area of the soil is fixed, theequipment could be moved onto the fixed soil toblend the next section. It is anticipated that the soilvolume would expand approximately 20 percent dueto the fixation process. This additional volume wouldbe used to achieve the needed slope for the cap. AnRCRA soil/clay cap placed over the solidified materialis necessary to prevent infiltration and additionalhydraulic stress on the fixed soil. It is estimated thatthe fixation would reduce lead migration by 40percent and that the fixed soil would pass the EPToxlevels for lead.

Criteria Assessment

This alternative would protect human health and theenvironment. This alternative protects against directcontact with contaminated soil and further groundwater degradation by treating part of the soil andfixing and capping the remaining soil. It protectsagainst ingestion of contaminated ground water bycollecting and treating the affected aquifer to health-based levels.

This alternative meets the MCL for TCE and action-specific ARARs such as air and water dischargelimits. As with Alternative 3, the land disposalrestrictions are not an ARAR for this alternative sinceplacement does not occur. The cap would meet StateRCRA requirements for landfill closure.

The long-term effectiveness of this alternative wouldbe enhanced by the application of treatmenttechnologies that reduce the inherent hazards posedby the sources; all of the contaminated soil would bet rea ted or immobi l i zed by f i xa t ion and thecontaminated ground water would also be extractedand treated. Even in the unlikely event of cap failurein Area 1, the fixed soil would pose little if any risk ofground water contamination. The potential for capfailure would be minimized through the maintenanceprogram. This alternative would also require a 5-yearreview.

Soil vapor extraction and air stripping with gaseouscarbon adsorption are irreversible. Soil fixation wouldreduce the mobility of lead by about 40 percent but

would increase the volume of contaminated soil from25,000 cy to about 30,000 cy. Al though thistechnology is not completely irreversible, thepossibility exists that the contaminants could regainsome mobility should the cap fail. However, the riskwould be small. The residual soil remaining followingtreatment would not pose a risk to human health orthe environment. This alternative satisfies thestatutory preference for using treatment as a principalelement since it addresses principal threats posed bythe site through treatment.

D u r i n g t h e v a p o r e x t r a c t i o n p r o c e s s , t h econtaminated soil would be uncovered and thepotential exists for contaminant release into the air(although the risk would be small due to the controlsystem that would be used). In situ soil fixation wouldrelease some particulate matter into the atmosphere.However, the fixation process would require only afew months for implementation, lessening thelikelihood of any potential risk. Dust control methodswould be used to limit the release of particulatematter.

Implementability information for the soil vaporextraction system, the cap, and the ground waterpump and treat systems to be used for th isevaluation, is provided under Alternative 3. As for theadditional fixation process, vendors needed to fix thesoil are readily available. The necessary reagents areavailable within 50 miles of the site. All of thecomponents could be expanded i f addit ionalcontamination was discovered.

The 30-year present worth cost of this alternative isestimated to be $10,200,000. The primary cost itemsare the cap, the ground water treatment system, andthe soil fixation of Area 2. The capital cost isestimated to be $6,200,000, with an annual O&Mcost of $480,000 for the first 5 years. After year 5,the O&M costs would decrease to $200,000 forground water treatment and monitoring.

Alternative 5 - Incineration, In Situ Soil Fixation,Ground Water Pump and Treat

This alternative contains components of Alternatives 3and 4 bu t in t roduces a therma l des t ruc t ioncomponent to address the TCE-contaminated soil.The lead-contaminated soil in Area 1 would be fixedand covered with a soil/clay cap, as described inAlternative 4. The ground water would be addressedthrough pumping and treating, via an air stripper, asdescribed in Alternat ives 3 and 4. The TCE-contaminated soil in Area 2 would be excavated andtreated onsite by a thermal destruction unit.

For the purposes of this analysis, the thermaldestruction unit is assumed to be a rotary kiln unit.The specific type of incineration would be determinedin the Remedial Design phase after competitive

bidding has taken place. The incinerator would bemobilized, operated, and closed according to thespecific requirements found in RCRA, Subpart O (40CFR 264.340). The substantive requirements of thepermitting process, though not applicable because theaction does not involve RCRA-regulated hazardouswaste, have been determined to be relevant andappropriate. A discussion of the ARARs associatedwith the remediation of Area 1 and the ground watercan be found under Alternative 4.

It is estimated that approximately 20,000 cy ofcontaminated soil would need to be excavated andtreated. The risk from the remaining soil would notexceed 1 x 10-6 excess cancer risk level as soilcontaining TCE at concentrations greater than 56ppm would be excavated. There are still someuncertainties with this volume estimate so it would benecessary to sample during excavation to determinewhen sufficient material has been removed.

Incineration of soils contaminated with organiccompounds is a proven technology. Conservativeestimates about the organic and moisture contentswere made to develop the incineration component.The incinerator would be operated continuously (24hours/day, 365 days/year) in order to reduce thethermal stress on the refractory, although some downtime would be required (20 percent) for regularmaintenance. Due to the need to maintain continuousoperation, a waste pile for the purpose of temporarystorage would be constructed in accordance with therelevant and appropriate requirements of RCRA (40CFR 264.251) which requires a liner and leachatecollection system. This storage would ensureoperation during periods of poor weather whenexcavation may not be possible.

The incinerator would operate at a feed rate of 3.5 tons/hr. At this feed rate and assuming that about

20,000 cy of material would be excavated, more than1 year would be required for incineration. About 30gallons/hr of fuel oil would be required to run theincinerator. It is assumed that the incinerator wouldbe operated to achieve 99.8 percent TCE removalfrom the soil and a destruction efficiency as requiredby RCRA. Specific operating practices to meet theperformance objectives, including 99.99 percentdestruction of stack emissions as dictated by SubpartO of RCRA, would be determined through a trial burnat the site after installation of the incinerator. Otherperformance standards include hydrogen chlorideemissions not to exceed 1.8 kg/hr and particulatematter emissions of less than 0.08 grains per daystandard cubic foot.

The facility would use a dry scrubber system foremission control, which would almost eliminate theneed for wastewater treatment. Any water fromemission control and from decontaminat ionprocedures would be treated in the onsite ground

water treatment system. The residual soil andcollected ash is assumed to be nonhazardous andcan be disposed of in a solid waste disposal facility incompliance with Subtitle D of RCRA. In the event thatthey cannot be delisted due to the presence ofmetals, either residuals will be managed as part of theclosure of Area 2 (lead-contaminated soil).

Criteria AssessmentThis alternative would be protective of human healthand the environment. The contaminated ground waterwould be collected and treated, reducing further thethreat of ingesting contaminated ground water. Therisk from ingesting ground water would be lowered toless than 1 x 10-6. The direct contact risk would bereduced by fixing soil exceeding 200 lead andincinerating TCE-contaminated soil with an excesscancer risk level greater than 1 x 10-6.

Although this alternative would involve the excavationand placement of waste, thus making the landdisposal restr ict ions a potent ial ARAR, TCE-contaminated soil at this site is not an RCRAhazardous waste and therefore these requirementswould not be applicable. The U.S. EPA is undertakingan LDR rulemaking that will specifically apply to soiland debris. Until that rulemaking is completed, theCERCLA program will not consider the land disposalrestrictions to be relevant and appropriate to soil anddebris that does not contain RCRA-restrictedwastes.

The long-term effectiveness of this alternative isenhanced by the destruction of about half of thecontaminated soil by thermal destruction andreduction in the mobility of contaminants in the otherhalf through fixation. The ground water pump andtreat component is also effective but would requirel o n g - t e r m m a n a g e m e n t o r m o n i t o r i n g a n dmaintenance. The area where soil is removed forincineration would not require long-term monitoringwhereas the contaminated soil that is fixed wouldremain under a cap and would require long-termmonitoring and maintenance. This alternative could beenhanced to effectively control greater areas ofcontamination or different contaminants (i.e., possiblemetals in Area 2). Because the fixed soil will remainonsite, this alternative would require a 5-year review.

This alternative reduces the toxicity, mobility, andvolume of soi l contaminants by incinerat ion.Incineration would destroy an estimated 99.8 percentof the hazardous constituents present in the soil ofArea 2, based on previous experience with thistechnology at other sites. Approximately 18,000 cy oftreated soil that would pose minimal risk to humanhealth or the environment would be disposed offsitein the local municipal landfill. Approximately 30,000 cyof soil in Area 1 would remain although the mobility ofthe lead would be reduced by approximately 40percent through fixation. Virtually no risk from this soil

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would exist as long as the cap is properly maintainedto control exposure. Ninety-six percent of thecontaminants in the ground water would be removedand eventually destroyed as discussed underAlternatives 3 and 4. This alternative meets thestatutory preference for using treatment as a principalelement since it addresses the principal threats posedby the site through treatment.

Fixation would require approximately 6 months tocomplete and would potentially release particulatematter into the air. Excavation and incineration wouldrequire approximately a year and may releasevolatiles into the air. The minor risks from bothsituations to both workers and the community wouldbe temporary. Air monitoring and foam covers wouldbe used to further minimize the likelihood of risk. Theadditional risk to workers through operating anincinerator (because of the complexity of theequipment and the high operational temperatures)would be mitigated through the proper use of safetyprotocols, proper drainage controls, and restrictionson access to contaminated areas. Although emissionsfrom the incinerator would comply with all air qualityregulations, potential accidental releases couldtemporarily affect air quality in the vicinity of the site.

This alternative is inherently difficult to implement dueto the incineration component. Operation of anincinerator is mechanically complex and has stringentmon i to r ing requ i rements to p rov ide p roper .performance. Consequently, the incinerator andassociated facilities require highly trained staff and asubstantial amount of attention. In addition, it may benecessary to postpone the implementation until anavailable mobile incinerator can be found. If metalconcentrations in the soil are very high, incinerationwould not be used and the soil would be fixed alongwith the soil in Area 1.

It has been estimated that the present worth cost forthis alternative would be $16,000,000, primarilybecause of the incineration component. The capitalcost would be $13,000,000 and the first year annualO&M is estimated at $1,200,000 with most of thecost as a result of operating the incinerator.Subsequent year O&M costs would be about$200,000 since only the ground water treatment andmonitoring systems would be operating.

Table F-l summarizes the above discussion.

Comparative AnalysisIn the following analysis, the alternatives areevaluated in relation to one another for each of theevaluation criteria.6 The purpose of this analysis is to

6 State and community acceptance will be addressed in theROD following comments on the RI/FS report and theproposed plan.

identify the relative advantages and disadvantages ofeach alternative.

Overall Protection of Human Health and theEnvironment

All of the alternatives, except Alternative 1 (no action),provide adequate protection of human health and theenvironment. Risk through direct contact and groundwater ingestion are reduced to cancer risk levels lessthan 1 x 10-6 through each pathway. Alternatives 3,4, and 5 prevent further migration of the contaminatedground water by extracting and treating the plume tohealth-based ARAR levels.

Alternative 2 achieves protection by preventingexposure through capping and natural attenuation ofthe contaminated ground water. Alternative 3combines treatment to reduce the risk from theTCE-contaminated soil and ground water andcapping of the lead area. Alternatives 4 and 5 reducerisks posed by all portions of the site throughtreatment.

There is some uncertainty about the potentialpresence of metals in the TCE-contaminated soil ofArea 2. If metal concentrations of concern arepresent, only Alternatives 2 and 5 would protectagainst direct contact and further ground-watercontamination through a cap and incineration,respectively. Incineration of metal-contaminated soilmay result in a hazardous waste residue which wouldhave to be disposed of in a hazardous waste landfill.Alternatives 3 and 4 rely on vapor extraction toremedy the soil in Area 2. Soil vapor extraction wouldnot lower risks from metals to human health or theenvironment.

Compliance with ARARs

The evaluation of the ability of the alternatives tocomply with ARARs included a review of chemical-specif ic and act ion-specif ic ARARs that waspresented earlier in the report. There are no knownlocation-specific ARARs for this site. All alternativeswill meet all of their respective ARARs except theno-action alternative.

Long-Term Effectiveness and Permanence

Alternatives 4 and 5 afford the highest degrees oflong-term effectiveness and permanence becauseboth a l te rna t ives use t rea tment o r f i xa t iontechnologies to reduce hazards posed by all knownwastes at the site. While some contaminated soilwou ld rema in a f te r imp lementa t ion o f bo thalternatives, it would be fixed to reduce mobility.These two alternatives differ only in the technologyused to t rea t the TCE- laden so i l . A l thoughincineration would destroy more TCE than soil vapor

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extraction, both alternatives reduce risks posed by thewaste to a 1 x 10-6 cancer risk levels through boththe ground water and soil pathways.

Alternatives 4 and 5 would rely on a soil/clay cap tocontrol infiltration, a reliable technology if properlymaintained. In addition, Alternative 5 would alsoemploy a solid waste landfill to manage the residuefrom incineration. Upon completion, some long-termmaintenance of the cap and ground water monitoringwould be required for both alternatives until thealternative has met the health-based cleanup goalsfor ground water, at which point the monitoring canbe discontinued. These alternatives would havealmost no long-term rel iance on inst i tut ionalcontrols.

Alternative 3 eliminates the risk of exposure at thesite to the same levels as Alternatives 4 and 5 in theshort-term; however, it relies solely upon a cap forcontrolling the waste remaining in Area 1. Althoughcapping is an effective and accepted approach forreducing risk from direct contact with wastes, it isless reliable in the long-term than treatment toremove or fix contaminants in soil since the inherenthazard of the lead would remain. Since a potential forcap failure, however small, would exist, the long-term effectiveness of Alternative 3 would not be asrel iable as Alternat ives 4 and 5. Long-termmanagement requirements for Alternative 3 aresimilar as those of Alternative 4 or 5; operation of theground water pump and treat systems would berequired for 25 to 40 years. However, the cappedarea under Alternative 3 is greater in size than thecapped areas under Alternatives 4 and 5.

Alternative 2 leaves all of the contaminated waste atthe site and relies solely upon a cap and institutionalcontrols to prevent exposure. Although the alternatew a t e r s u p p l y l o w e r s t h e r i s k o f i n g e s t i n gcontaminated ground water from existing wells, thelocal municipality estimates that the existingregulations to be used as institutional controls wouldnot be effective with a high degree of certainty formore than 5 to 10 years in preventing the installationof new wells and the ingestion of contaminatedground water.

Alternative 2 also has long-term ground watermonitoring and cap maintenance requirements(mowing, revegetation, cap repair) which are morecritical for the effectiveness of this alternative since allof the waste (without any type of treatment to reducetheir mobility, toxicity, or volume) remains at the siteunder the caps. Failure to detect a problem with thecap may result in direct contact with the contaminatedsoil and further degradation of the ground waterthrough leachate production. Monitoring will continueuntil the health-based cleanup goals are met. A 5-

year review would be necessary to verify that theremedy remains protective.

Reduction of Toxicity, Mobility, or VolumeThrough Treatment

Alternatives 4 and 5 use treatment or fixationtechnologies to reduce the inherent hazards posed byall known waste at the site. Both of these alternativeswould either treat, fix, or excavate and incinerate allsoil posing more than a 1 x 10-6 excess cancer risklevel by ingestion. Both alternatives treat the groundwater and then treat the contaminated air stream fromthe air stripper with GAC. Regeneration of the GACultimately destroys the ICE. The soil vapor extractionsystem also contains GAC gaseous treatment. Bothalternatives also fix the soil contaminated with lead,reducing the mobility of the lead by an estimated 40percent. Neither alternative completely treats all of thesoil at the site. Both alternatives produce 30,000 cy offixed soil, and 18,000 to 20,000 cy of treated soil.Under Alternative 5, 18,000 cy of soil (with 99.8percent of the TCE destroyed) would remain. UnderAlternative 4, 20,000 cy of soil (with 99.9 percent ofthe TCE removed and ultimately destroyed) wouldremain. These two alternatives would satisfy thestatutory preference for treatment as a principalelement.

Alternative 3 treats the principal threats posed by thesoil and the ground water and thus also satisfies thestatutory preference for treatment as a principale lement . Approx imate ly 25 ,000 cy o f lead-contaminated soil would remain untreated onsite.However, the mobility of this lead is very low.Alternative 3 reduces the toxicity of 20,000 cy ofTCE-contaminated soil by using soil vapor extractionat Area 1. Alternative 3 also reduces the volume andtoxicity of contaminated ground water.

Alternative 2 uses no treatment technologies. All ofthe contaminated soil, controlled by a cap, and all ofthe contaminated ground water would remain,although the contaminants in the groundwater willnaturally attenuate.

Short-Term EffectivenessAlternative 2 is anticipated to have the greatestshort-term effectiveness. Alternative 2 presents theleast amount of risk to workers, the community, andthe environment. Some particulate emissions fromcap installation is anticipated during implementation;however, dust control methods should reduce thisrisk. The other alternatives could release volatilesduring excavation activities or soil vapor extraction.These emissions may be more difficult to control.

The time required to achieve short-term protectionwould be shorter than for any other alternative. It isanticipated that only 6 months would be required to

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install a new cap and to provide an alternate watersupply. Alternatives 3 and 4, involving vaporextraction require 3 to 5 years before the risk fromdirect soil contact and ingestion is controlled.

Alternatives 3 and 4 are very similar with respect toshort-term effectiveness. Implementing the soilvapor extraction system requires the most time of thesource control actions. There is a small potential forrisk to the community, workers, and the environmentthrough volatile emissions during extraction to the airin the unlikely event of control failure.

Alternative 5 would take longer to implement thanAlternative 2 and has a greater potential of releasingvolatiles to the atmosphere during excavation thanAlternatives 3 and 4. However, implementation ofAlternative 5 would take less time than Alternatives 3and 4 since incineration would require less time thansoil vapor extraction to remediate the soil to safelevels. However there may be a possibility of volatileemissions during excavation that would need to becontrolled. Alternative 5 has the disadvantage ofrequiring incineration equipment (the most technicallycomplex equipment of any of the alternatives) whichcould increase the risk to workers in the event of afailure. Careful implementation of standard safetyprotocols would lessen this risk.

ImplementabilityAlternative 2 would be the simplest to construct andoperate. While construction of a cap would havesignificant materials handling requirements, thematerials are available locally. Expansion of the capcould incorporate other areas of contamination ifdiscovered during activities at the site, specifically ifmetals become an issue at Area 2. Periodicmaintenance of the cap should control its reliability inthe future. The ground water monitoring programwould determine the effectiveness of the cap atdecreasing future contamination of the ground water.The alternate water supply would reliably supply safedrinking water despite the fractured nature of theaquifer.

Construction requirements for Alternative 3 are fairlys imp le . A l te rna t i ve 3 has more opera t iona lrequirements than Alternatives 1 and 2 because ofthe soil vapor extraction system and the air stripper.As with the other alternatives, i f addit ionalcontamination is found at the site, the componentscould be sized to include the additional areas.However, if metals were found in Area 2, soil vaporextraction would not effectively treat the soil andanother technology would need to be used to controlthe risk from direct contact.

Soil vapor extraction is a fairly reliable technologybecause of its mechanical simplicity. Very little

downtime is anticipated. However, as with any in situtreatment system, samples throughout the soil (bothvarying in location and in depth) must be takenfrequently to determine the effectiveness of thetechnology.

Alternat ive 3 would require readi ly avai lableengineering services and cap materials. An airstripper could readily be obtained and constructedonsite. All of the treatment technologies proposed forthis alternative are proven. However, it would bedifficult to evaluate the effectiveness of the groundwater extraction system in the fractured aquifer. Itwould be difficult to determine where to installextraction wells to intercept contamination since thefractures would be difficult to locate. Additionaltreatability studies for the soil treatment component ofthis alternative and some fracture trace analysiswould help ensure the success of this alternative.

Alternative 4 is more complex than Alternative 3because of the in situ soil fixation component. Whilethis component has no addit ional operat ionrequirements, it would require additional constructiontechniques that would have to be supplied byspecialists in this area. Vendors for soil fixation arereadily available. Additional treatability work may berequired to optimize the reagent doses. Other thanthe in-situ solidification component, Alternative 4 issimilar to Alternative 3 in terms of implementability.However, the solidification component could be easilyused on Area 2 if significant metal contaminationwere found.

Alternative 5 is the most complex alternative toconstruct and, during implementation, to operate.However, despite anticipated frequent downtime dueto mechanical complexity,, incineration could reliablymeet the cleanup goals. A mobile incinerator wouldhave to be located and brought onsite. Duringoperation of the incinerator, this alternative wouldrequire the most attention because incineratorsrequire periodic sampling of the residue andmodification of operating parameters. However, theincinerator would operate for slightly more than ayear, whereas the soil vapor extraction system ofAlternative 4 would operate for 3 to 5 years.

As with Alternatives 3 and 4, some initial treatabilitywork would be necessary to determine operatingparameters. Other than locating, constructing, andoperating the incinerator, the other implementabilityaspects of this alternative are similar to Alternatives 3and 4. Incineration would also not be effective intreating Area 2 soils if metals are determined to be ahealth risk. The ash would be a hazardous wasteunder this scenario and would require disposal at anRCRA Subtitle C landfill.

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Cost alternatives because of the incinerator component.The cost details of all of the alternatives are includedin the appendix to this FS report.

Alternative 2 has a lower present worth and O&Mcost than Alternative 3, but because of the additionalcap required, it has a higher capital cost ($4,200,000versus $3,300,000). The cap is one of the mostexpensive components to construct. Alternative 4 hasa higher capital, O&M, and present worth cost thanAlternatives 2 and 3. Alternative 5 has the highestcapital ($13,000,000), first year O&M ($1,200,000),and present worth cost ($16,000,000) of all of the

State AcceptanceTo be addressed in the ROD.

Community Acceptance

To be addressed in the ROD.

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