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Remedial Investigation - RI

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Confidential Documents
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Glossary of terms relating to file structure phase activities and file categories

Descriptions of 20.00 - 20.99 SRC Folder Code HZ/SF/RE/RI NARA General Records Schedule  N1-412-99-23

Definition

The Remedial Investigation (RI) file opens with the first technical correspondence about RI, and closes with the Record of Decision (ROD) and comments. This phase investigates the remediation alternatives for a site, and defines the extent of the threat posed to human health or the environment by any contamination at the site.  Often abbreviated to RI/FS.  Although they are two distinct studies, they are related and are usually performed together.  The intent of the RI is to gather the data necessary to determine the type and extent of contamination at the site, the baseline risk assessment, and the environmental assessment.  The baseline risk assessment and the environmental assessment reports are filed in the Health Assessment (HE) phase.  The Feasibility Study (FS) continues with that information by establishing criteria for cleaning up the site; identifying alternatives for Remedial Actions; and presenting in detail the technology and costs of the alternatives.

Note that each operable unit may require its own RI set; separation of operable units should be made upon consultation with the site management team. Contractor documentation which contains material protected as Confidential Business Information, or, due to the Privacy Act should not be  included within this category, and such protected information must be redacted.  Alternatively, contractor reports may be designed to facilitate  separation of progress reporting, total hours, and total hours for that month from protected  information. The sections of the monthly progress reports containing detailed cost information (not cost estimates) are filed in Contractor Confidential (CC) phase.


SDMS Keyword (Click on keyword to see description)

20.21 Applicable or Relevant and Appropriate Requirements (ARARs)
20.25 Conflict of Interest
20.14 Contractor Selection Information
20.20 Environmental Risk Assessment [Moved to HE phase]
20.28 Explanation of Significant Differences (ESD)
20.18 Feasibility Study
20.27 General Correspondence
20.26 Initial / Interim Remedial Measures [Moved to EM phase]
20.24 Innovative Technology
20.23 Natural Resource Trustee [Moved to RT phase]
20.22 Proposed Plan for Remedial Action
20.03 Public Comments (First folder of RI)
20.19 Public Health Assessment [Moved to HE phase]
20.01 Record of Decision (ROD) and Related Correspondence
20.29 Record of Decision (ROD) Amendment
20.16 Remedial Investigation Report
20.02 Responsiveness Summary and Related Correspondence
20.09 Sampling and Analysis Done by EPA
20.12 Sampling and Analysis Done by any Others than EPA, State, or PRP
20.11 Sampling and Analysis Done by PRP
20.10 Sampling and Analysis Done by State
20.04 Site Status Summary (Monthly)  (Unless Confidential)
20.13 Statement of Work
20.05 Technical Progress Report, EPA Contractor
20.08 Technical Progress Report, Oversight Contractor
20.07 Technical Progress Report, PRP Contractor
20.06 Technical Progress Report, State Contractor
20.17 Treatability Study
20.15 Workplan and/or Amendment

20.99 Other


SDMS Keyword Description

20.01 Record of Decision (ROD) and Related Correspondence
The Record of Decision (ROD) documents the selected remedial action for a site or operable unit.  It is prepared by the lead agency in consultation wit the support agency.  The ROD serves as:

20.02 Responsiveness Summary
The Responsiveness Summary, a component of the ROD, summarizes information about the views and comments of the public and the support agency's responses regarding both the remedial alternatives and general concerns about the site submitted during the public comment period.  It also documents in the record how public comments were integrated into the decision-making process.  The Responsiveness Summary reflects a genuine attempt to address citizen's questions and concerns, and not a simple re-assertion of the correctness of EPA's determination. 

20.03 Public Comment
Public comments on the ROD or the alternative proposed for remediation of the site.

20.04 Site Status Summary (Monthly)
This is the monthly summary of work done on the site prepared by the Remedial Project Manager (RPM) during the RI/FS phase.

20.05 EPA Contractor Technical Progress Report
These are the monthly progress reports or other reports required of the EPA contractor doing work during the RI/FS phase.  These reports cover the technical information about work performed.  If the report includes cost information,  the cost information should be re-filed in Contractor Confidential (CC) [91.01].

20.06 State Contractor Technical Progress Report
These are the monthly progress reports or other reports required of the state contractor doing work during the RI/FS phase.  These reports cover the technical information about work performed.  If the report includes detailed cost information, the cost information should be re-filed in Contractor Confidential (CC) [91.01].

20.07 PRP Contractor Technical Progress Report
When the contractor is hired directly by the PRP to do RI/FS work, a monthly progress report must be submitted to EPA.  This report details work performed, community relations activities, change orders, problems encountered, projected work for the next period, and daily reports.

20.08 Technical Progress Report, Oversight Contractor
These are any formal reports filed by EPA's oversight contractor about RI/FS work being performed by the PRP or their contractor.

20.09 Sampling and Analysis Done by EPA
These are reports summarizing  raw data related to any samples taken at the site by EPA or their contractors and sent to the Contract Lab Program (CLP), EPA Lab, Agency Ranking Committee (ARC Lab), etc., for analysis during the RI/FS phase. Sampling and Analysis (done by CLP, PRP, or others) are stored in-house until QA/QC done, then sent to off-site storage; only transmittals, analytical summaries and chain-of-custody forms should be placed  in the  phase activity file.  Target sheets with the accession numbers of the boxes containing full packages should be placed with copied documents.  The entire packages will stay intact for off-site storage.

20.10 Sampling and Analysis Done by State
These are reports summarizing  raw data related to any samples taken at the site by the state or their contractors for analysis during the RI/FS phase.  Contractor Sampling and Analysis (done by CLP, PRP, or others) are stored in-house until QA/QC done, then sent to off-site storage; only transmittals, analytical summaries and chain-of-custody forms should be placed  in the  phase activity file.  Target sheets with the accession numbers of the boxes containing full packages should be placed with copied documents.  The entire packages will stay intact for off-site storage.

20.11 Sampling and Analysis Done by PRP
These are reports summarizing  raw data related to any samples taken at the site by the PRP or their contractors during the RI/FS phase.  Sampling and Analysis (done by CLP, PRP, or others) are stored in-house until QA/QC done, then sent to off-site storage; only transmittals, analytical summaries and chain-of-custody forms should be placed in the  phase/activity file.  Target sheets with the accession numbers of the boxes containing full packages should be placed with copied documents.  The entire package will stay intact for off-site storage.

20.12 Sampling and Analysis Done by Others
These are reports summarizing raw data related to any samples taken at the site during the RI/FS phase by some party other than EPA or the PRP or their contractors.  This could be sampling done by the state or local government, environmental green groups, etc.  Sampling and Analysis (done by CLP, PRP, or others) are stored in-house until QA/QC done, then sent to off-site storage; only transmittals, analytical summaries and chain-of-custody forms should be copied into phase file.  Target sheets with the accession numbers of the boxes containing full packages should be placed with copied documents.  The entire packages will stay intact for off-site storage.

20.13 Statement of Work
This is an EPA document outlining work to be performed.  This is the technical direction from the EPA.  Also included is an Independent Government Cost Estimate (IGCE) of the time and costs for each task.

20.14 Contractor Selection Information
These are any documents related to the selection of a contractor, and includes qualifications information about the contractor and EPA approval as specified in the Consent Decree for a PRP contractor.

20.15 Workplan and/or Amendment
Workplans/Amendments (Includes workplans for sampling, treatability study, pilot studies, groundwater modeling, health & safety plan, etc.)  A workplan outlines the approach for studies or activities as submitted by those responsible for undertaking the work for the RI or FS.  There is generally a draft submitted for review and a final based on comments received back.  Following final approval to the workplan, amendments are used to change what was originally designated or agreed upon.  Workplans can include plans for sampling plans, the health and safety plan, contingency plan, QA/QC plans, etc.  If the workplan is for an EPA contractor and includes detailed cost information, the entire Workplan should be filed in Contractor Confidential [91.01].

20.16 Remedial Investigation Report
This is a report that characterizes the site and assesses the threats or potential threats to human health and the environment posed by the site.

20.17 Treatability Study
This is either a test, study, or sampling and analysis to optimize the required treatment and/or disposal operations and systems.  It could also be referred to as a bench, scale, or pilot study.

20.18 Feasibility Study
This is a study or report on the development and evaluation of cleanup alternatives using environmental, engineering, and economic factors.

20.21 Applicable or Relevant and Appropriate Requirements (ARARs)
The alternative remedies set forth in the FS must meet all applicable or relevant and appropriate requirements for protecting human health and the environment.  This includes federal, state, and local regulations and requirements.  Often this is a part of the RI report, in which case this would be a secondary keyword.

20.22 Proposed Plan for Remedial Action
This is the plan or alternative that has been proposed to remedy the problems found at the site.

20.24 Innovative Technology
This is a clean-up method that has a limited application and is not considered traditional due to lack of data on performance and cost.  Also included are newly developed technologies or application of technologies that do not yet have a proven track record.  This term should only be used as a secondary keyword.  When innovative technology is a keyword, a description of the type of technology should be given; for example bioremediation, soil washing, etc.

20.25 Conflict of Interest

20.27 General Correspondence

20.28 Explanation of Significant Differences and Related Correspondence
An Explanation of Significant Differences (ESD) must describe to the public the nature of the significant changes, summarize the information that led to making the changes, and affirm that the revised remedy complies with the NCP and the statutory requirements of CERCLA.  The ESD should provide additional information on changes that have resulted in the remedy as a result of the change (e.g. changes in the cleanup cost estimate or remediation time frame).  

20.29 ROD Amendment
After a ROD is signed, new information may be received or generated that could affect the implementation of the remedy selected in the ROD, or could prompt the reassessment of that remedy.  A fundamental change involves an appreciable change or changes in the scope, performance, and/or cost or may be a number of significant changes that together have the effect of a fundamental change.  When a fundamental change is made to the basic features of the remedy selected in a ROD with respect to scope, performance, or cost, the lead agency is required to develop and document the change consistent with the ROD process.  The focus of the amendment is to document the rationale for the amendment and provide assurances that the proposed remedy satisfies the statutory requirements.

20.99 Other
;If the needed keyword code is not available, then code to 20.99.

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