Feasibility STUDY

Scoping is the initial planning phase of site remediation and is a part of the funding allocation and planning process.12 Scoping of the RI/FS comprises the following steps:

1. Evaluating existing data

2. Developing the conceptual site model

3. Identifying the initial project/operable unit, likely response scenarios, and remedial action objects

4. Initiating potential federal/state ARARs identification

5. Identifying initial data quality objectives

6. Preparing project plans

16.4.1 Project Planning

There are 12 tasks involved in project planning:

1. Conducting project meetings. This includes meeting with the lead agency, the support agency, and contractor personnel to discuss site issues and assign responsibilities for RI/FS activities.

2. Collecting and analyzing existing data. Existing data (Table 16.1) are collected and analyzed to develop a conceptual site model that can be used to assess both the nature and the extent of contamination and to identify potential exposure pathways and potential human health or environmental receptors.

3. Describing the current situation.

4. Developing a conceptual site model. An example of this is presented in Figure 16.4.12

5. Developing preliminary remedial action alternatives. This involves initiating limited field investigations if available data are inadequate to develop a conceptual site model and adequately scope the project, and identifying preliminary remedial action objectives and likely response actions for the specific project.

6. Evaluating the need for a treatability study. The requirement and schedule for treatability studies so as to better evaluate potential remedial alternatives are identified. If remedial actions involving treatment have been identified for a site, then the need for treatability studies should be evaluated as early as possible in the RI/FS process. This is because many treatability studies may take several months or longer to complete.

7. Beginning preliminary identification of ARARs and "to be considered" (TBC) information. This preliminarily identifies the ARARs that are expected to apply to site characterization and site remediation activities.

8. Identifying data needs. Data requirements and the level of analytical and sampling certainty required for additional data if currently available data are inadequate to conduct the FS is

PSCS report ID/revise AEAE 1-1 1-1

Scoping

ID prelim ARARs

ID prelim RA objectives i-1

Prepare SAP Agency n

1 Prepare CRP 1 ' Prepare WP '

Site characterization

Limited sampling

(Optional)

Field investigation 1-

Risk assessment & environmental characterization

Additional site characterization (If required)

Investigations data needs pilot studies

Treatability investigation ' I I I '

ID/revise ID Screen Assemble Define Screen

Development and screening RAobj. technologies technologies alts alts alts of alternatives 1 I I I I I '

RIFS

Detailed evaluation of alts report (draft)

Detailed analysis of alternatives 1 I

FIGURE 16.3 Generic phased RI/FS timeline.

ui vo

TABLE 16.1

Data Collection Information

TABLE 16.1

Hazardous Waste

Migration

Pathways

Information Source

Sources

Subsurface

Surface

Air

Recep

U.S. EPA files

X

X

X

X

X

U.S. Geological Survey

X

X

U.S. DOA, Soil Conservation Service

X

X

U.S. DOA, Agricultural Stabilization and

X

X

Conservation Service

U.S. DOA, Forest Service

X

X

U.S. DOI, Fish and Wildlife Agencies

X

U.S. DOI, Bureau of Reclamation

X

X

X

U.S. Army Corps of Engineers

X

Federal Emergency Management Agency

X

U.S. Census Bureau

X

National Oceanic and Atmospheric

X

Administration

State Environmental Protection or

X

X

X

X

X

Public Health Agencies

State Geological Survey

X

X

State Fish and Wildlife Agencies

X

Local Planning Boards

X

X

X

X

County or City Health Departments

X

X

X

X

X

Town Engineer or Town Hall

X

X

Local Chamber of Commerce

X

X

Local airport

X

Local library

X

X

Local well drillers

X

Sewage treatment plants

X

X

X

Local water authorities

X

X

City fire departments

X

X

X

X

Regional geologic and hydrologic publications

X

X

Court records of legal action

X

Department of Justice files

X

State Attorney General files

X

Facility records

X

Facility owners and employees

X

X

X

Citizens residing near site

X

X

X

X

X

Waste haulers and generators

X

X

Site visit reports

X

X

X

X

Photographs

X

X

X

Preliminary assessment report

X

X

X

X

X

Field investigation analytical data

X

X

X

X

FIT/TAT reports

X

X

X

X

X

Site inspection report

X

X

X

X

X

HRS scoring package

X

X

X

X

X

EMSL/EPIC

X

X

X

Source: From U.S. EPA, Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA,

EPA/540/G-89/004, October, U.S. EPA, Washington, DC, 1988. EMSL, Environmental Monitoring Support Laboratory; EPIC, Environmental Photographic Information Center; DOA, Department of Agriculture; DOI, Department of Interior; FIT, Field Investigation Team; TAT, Technical Assistance Team.

Receptor

Receptor

FIGURE 16.4 Example of a conceptual site model. (From U.S. EPA, Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA, EPA/540/G-89/004, U.S. EPA, Washington, October 1988.)

identified, as well as possible uses of the data, including monitoring during implementation, health and safety planning, site characterization, risk assessment, evaluating alternatives, determining the potential responsible party (PRP), and the design of alternatives.

9. Designing a data collection program. A data collection program is designed to describe the selection of sampling approaches and analytic options, to establish the level of confidence required for the data, and to develop strategies for sampling and analysis.

10. Developing a work plan. A work plan is established that documents the scoping process and presents anticipated future tasks.

11. Identifying health and safety protocols. In this stage, health and safety protocols required during field investigations are identified and documented, and a site health and safety plan is prepared to support the field effort and conform to the firm's or agency's health and safety program.

12. Conducting community interviews. Community interviews are carried out to obtain information that can be used to develop a site-specific community relations plan that documents the objectives and approaches of the community relations program.

The identification of sampling requirements involves specifying the sampling design, the sampling method, sample numbers, types, and locations, and the level of sampling quality control. Data quality requirements include precision, accuracy, representativeness, completeness, and comparability.

The purpose of a sampling and analysis plan (SAP) is to ensure that sampling data collection activities will be comparable to and compatible with previous data collection activities performed at the site, while providing a mechanism for planning and approving field activities. The plan also serves as a basis for estimating costs of field efforts for inclusion in the work plan.

The SAP consists of the field sampling plan (FSP) and the quality assurance project plan (QAPP) elements. The QAPP describes the policy, organization, functional activities, and quality assurance and quality control protocols necessary to achieve data quality objects dictated by the intended use of the data. The FSP provides guidance for all fieldwork by defining in detail the sampling and data-gathering methods to be used on a project, including plan preparation and responsibilities (timing, preparation and review, field sampling plan, and so on). Table 16.2 lists the format for the FSP and QaPP.

16.4.2 Deliverables and Communications

There are several points during the scoping process when communication is required between the lead agency and its contractor or the support agency (Table 16.3). It is especially important that discussion and information exchange occur if interim actions or limited field investigations are considered necessary.

Deliverables required for all RI/FSs in which field investigations are planned consist of a work plan, an SAP, a health and safety plan (HSP), and a community relations plan (CRP).

16.5 REMEDIAL INVESTIGATION 16.5.1 Site Characterization

Site characterization is necessary in order to determine to what extent a site poses a threat to human health or the environment.12 Site characterization is the core of RI, and includes the following stages:

1. Conducting field investigations as appropriate

2. Analyzing field samples in the laboratory

TABLE 16.2

Suggested Format for the Sampling and Analysis Plan (Comprising the Field Sampling Plan and Quality Assurance Project Plan)

Site background

Sampling objectives

Sample location and frequency

Sample designation

Sampling equipment and procedures

Sample handling and analysis

QAPP

Title page

Table of contents

Project description

Project organization and responsibilities

QA objectives for measurement

Sampling procedures

Sample custody

Calibration procedures

Analytical procedures

Data reduction, validation, and reporting

Internal quality control

Performance and systems audits

Preventative maintenance

Data assessment procedures

Corrective actions

Quality assurance reports

Source: U.S. EPA, Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA, EPA/540/ G-89/004, U.S. EPA, Washington, DC, October 1988.

3. Evaluating the results of data analysis to characterize the site and develop a baseline risk assessment

4. Determining if data are sufficient for developing and evaluating potential remedial alternatives

16.5.1.1 Field Investigation

The major components of field investigation are air, biota, close support laboratories, RI-derived waste disposal, soil, gas, support, well logging, mapping and survey, geophysical characteristics, well installation, groundwater, source testing, and surface water. A complete field investigation includes at least prefield work, site physical characteristics investigation, contamination sources identification, and contamination determination.

Prefield work

The following prefield work is often needed before beginning an official field work:

1. Analyzing the collected existing data, including site characteristics, history of site (including disposal practices, disposal locations, disposed waste condition, waste degradations, storage of raw materials)

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