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Page Title: USEPA CERCLA Guidance Documents (Cont.)
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decisions made at each phase are similar. The USACE describes four phases in
the site investigation process.
a. Phase I is a preliminary risk screening of the site (known as PA/SI under
CERCLA and an RFA under RCRA).
b. Phase II, a baseline risk assessment (BRA), is performed in an Remedial
Investigation (RI) or Remedial Feasibility Investigation (RFI).
c. Phase III is a risk-based analysis of remedial alternatives in which
different options are evaluated for their potential to reduce the baseline
onsite risk Feasibility Study (FS) or Corrective Measures Study (CMS).
d. In phase IV, the short-term risks associated with remediation of a site are
assessed in a Resource Damages/Risk Assessment (RD/RA), CMI,
removal action, or interim corrective measure.
Within each phase of the site investigation process, the USACE defines five
steps for determining data needs.
a. Step 1. Background information review, site features, hazard information,
and exposure information are collected.
b. Step 2. Using the information collected in Step 1, a project decision
statement (PDS) is made which states whether the assessment should
continue or whether the site can be eliminated from concern.
c. Step 3. The data requires identification defining project study elements.
This step includes the development of a site conceptual exposure model
(SCEM). Note: In phase III of site investigation, two SCEMs are needed.
One SCEM is for the site during remediation or implementation of
corrective measures, and the other SCEM is for the site after remediation.
d. Step 4. The risk assessor must define and group data needs and describe
the methodology used to analyze the data.
e. Step 5. The data needs must be documented.
The authors of this document emphasize that risk assessments should consider
risk management needs. For example, "Under the PA/SI or RFA phase, screening
risk assessment and exposure analysis may be performed to determine the need for
further investigation." In Phase II (Remedial Investigation (RI)), the results of a
BRA are used to develop cleanup levels during the next phase (Feasibility Study
(FS) or Corrective Measures Study (CMS) phase). The purpose of an FS or CMS
is to provide a quantitative and qualitative evaluation of potential health impact
from remedial alternatives. Two types of risk assessments are done in an FS or
CMS. One assessment is done to develop chemical-specific remediation goals
(RGs) to be applied to site cleanup. The purpose of the other assessment is to
evaluate the short and long-term risk associated with each alternative.
A14
Appendix A Summary of Federal, State, and Regional Guidance

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