Feasibility Study Checklist
Toxics Cleanup Program
FOR ECOLOGY USE ONLY
Site Name/FSID:
Report Name:
Date Submitted:
Reviewed By:
Review Date:
May 2016
Publication No. 16-09-007
Feasibility Study (FS) Checklist
Feasibility Study (FS) Checklist Guidance
The Model Toxics Control Act (MTCA) regulation Washington Administrative Code (WAC) 173-340-350(8) broadly
describes the elements necessary to complete an FS. The purpose of an FS is to develop and evaluate cleanup action
alternatives to enable a cleanup action to be selected for the site. At this point in the cleanup process, all remedial
investigation (RI) work should be completed and the site should be fully characterized. When selecting cleanup
alternatives, make sure remedies are not selected or dismissed prematurely; the FS process should be performed
objectively without a preferred remedy in mind.
This FS checklist is considered guidance based on the MTCA cleanup regulation WAC 173-340. Cleanup project
managers with the Washington State Department of Ecology (Ecology) have discretion when reviewing and accepting FS
reports as site-specific circumstances dictate the necessary scope and breadth of each report.
Note: This document assumes that an FS and disproportionate cost analysis (DCA) are necessary for the site. If
concentrations of hazardous substances do not exceed the cleanup level at a standard point of compliance, no further
action is necessary, and an FS is not required. If a potentially liable person (PLP) meets the eligibility criteria and
appropriately follows the requirements for use of a model remedy, they are not required to conduct an FS or a DCA. If
a PLP and Ecology agree on a permanent remedy a DCA is not required [WAC 173-340-360(3)(d)].
In addition, there may be circumstances where selection of the appropriate remedy is straightforward or where a
comprehensive remedial action will be implemented so that MTCA Method A
cleanup levels are ultimately met throughout the site. If either of these FOR ECOLOGY USE ONLY
situations apply, Ecology encourages PLPs to discuss their preferred approach Comments
with a cleanup project manager.
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Feasibility Study Report Body
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I. Cover Letter
Include a letter describing the submittal and specifying the desired
department action or response.
II. Introduction
For a stand-alone FS, the introduction should include a brief summary of
the RI results and previous site investigations; this summary should
include the following information, updated with the most recent data:
a. Brief background of the site, site investigations, and any interim
actions.
b. Results of any additional investigations conducted since completion
of the RI.
c. Conceptual Site Model (CSM). Describe the location, extents,
estimated amount, and concentration distribution of contaminants of
concern (COC) greater than proposed screening levels for each
affected medium.
d. Preliminary cleanup levels for indicator hazardous substances in each
medium.
e. Proposed point of compliance for each affected medium, if different
from the standard.
f. Applicable local, state, and federal laws
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Feasibility Study (FS) Checklist
III. Alternatives FOR ECOLOGY USE ONLY
a. Identify Remedial Action Objectives. Describe the cleanup Comments
objectives and their compliance with MTCA.
b. Identify a Reasonable Number and Type of Alternatives. Include
a brief description of each alternative. Ecology recommends
evaluating at least three alternatives, taking into account the
characteristics and complexity of the facility, including current site
conditions and physical constraints. Include at least one permanent
alternative, at least one alternative with a standard point of
compliance, and a no action alternative if applicable (see WAC 197-
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11-440(5)). Do not include alternatives that clearly do not meet the
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minimum requirements per WAC 173-340-360, do not pass the DCA
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per WAC 173-340-360(3)(e), or are technically impossible to
implement.
Note: For sites conducting an FS under an order or decree, Ecology makes
the final determination of which alternatives must be evaluated in detail in
the FS.
IV. Detailed Evaluation and Selection of Alternatives
a. Threshold and Other Requirements [see WAC 173-340-360(2)].
Describe in detail how each alternative meets the criteria outlined
below. Alternatives must meet the threshold requirements and use
permanent solutions to the maximum extent practicable. If an
alternative does not meet these criteria, it should be eliminated from
further consideration.
i. Protect human health and the environment. This is a critical
requirement. Consider to what degree the alternative reduces
risk, how much time it will take to meet cleanup standards, and
any on-site or off-site risks related to implementing the cleanup.
If necessary, evaluate residual threats posed by each alternative,
and determine if remedies that are protective of human health are
also protective of ecological receptors.
ii. Comply with cleanup standards. See WAC 173-340-700
through 173-340-760.
iii. Comply with applicable state and federal laws. See WAC
173-340-710.
iv. Provide for compliance monitoring. See WAC 173-340-410
and WAC 173-340-720 through 173-340-760.
v. Reasonable Restoration Time Frame. Describe the estimated
restoration time frame for each alternative and the basis for this
estimate. Discuss the reasonableness of this time frame using the
criteria in WAC 173-340-360(4).
b. DCA Ranking Criteria. Compare and contrast each alternative for
each of the following criterion [WAC 173-340-360(3)(f)]. Rank each
alternative from most to least permanent, based on the evaluation of
the criteria below.
i. Protectiveness. Overall protectiveness of human health and the
environment.
Washington State Department of Ecology
Publication No. 16-09-007 2
Feasibility Study (FS) Checklist
ii. Permanence. The degree to which the alternative permanently FOR ECOLOGY USE ONLY
reduces the toxicity, mobility, or volume of hazardous Comments
substances. Consider treatment capability, reduction of releases,
management of the sources of release, degree of irreversibility of
treatment, and the quantity and quality of treatment wastes.
iii. Cost. The cost to implement the alternative. Includes present
capital costs, future capital costs, indirect costs, and operation
and maintenance costs.
iv. Effectiveness over the long-term. Consider the degree of
certainty for cleanup success, long-term reliability, magnitude of
residual risk, management of treatment wastes, and management
of wastes left untreated.
v. Management of short-term risks. Assess the risk to human
health and the environment associated with the alternative
during construction and implementation.
vi. Technical and administrative implementability. Ability to be
implemented including consideration of whether the alternative
is technically and administratively possible.
vii. Consider public concerns. Provide a narrative regarding
whether the community has concerns regarding the alternative
and, if so, the extent to which the alternative addresses those
concerns.
V. Remedy Selection
Detail the rationale behind the selection of the preferred alternative.
Detail how the alternative meets the expectations in WAC 173-340-370
and addresses public concerns.
Feasibility Study Figures
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General – Figures should include a north arrow, scale, complete legend,
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measurement units, and annotated clarification as necessary. Figures should not
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be cluttered and must be legible and explicable. Document text must reference
figures and draw conclusions consistent with information presented on figures.
Consider using multiple figures when showing large amounts of information.
I. Vicinity Map(s)
a. Show property in relation to surrounding region. Area covered by
Vicinity Map should be proportional to site size.
b. Show other applicable items including (but not limited to): surface
topography, natural areas, surrounding land uses, location of
groundwater supply and monitoring wells within a one mile radius.
II. Site Map(s)
a. Show overall site layout with site features and existing well, boring,
and sampling locations labeled consistently with current and
historical site data and sample names used in the report. If multiple
names exist for a sampling location or area of the site indicate this.
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Feasibility Study (FS) Checklist
b. Include COC locations, concentrations, and estimated vertical and FOR ECOLOGY USE ONLY
horizontal extent of contamination for site media, as applicable. Comments
Include any waste materials present on site as well as hazardous
substance treatment, storage, or disposal areas (show current and
applicable historical features).
c. Show geologic/hydrogeologic information including soil types, wells,
screened intervals, and water levels (cross sections are useful for
showing this information). Show groundwater flow direction and
gradient.
d. Show other relevant information including (but not limited to): site
and property boundaries, buildings/facilities on site, historical site
features, underground storage tanks (USTs), previous
excavation/interim action activity, etc.
III. Conceptual Site Model
Provide figures showing contaminant release(s), fate and transport,
exposure pathways, and potential and/or actual receptors. The lateral and
vertical extent of contamination, as currently understood, should be
clearly conveyed.
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Feasibility Study Tables
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General - Tables should include detailed notes that explain any assumptions or
references. All acronyms used in the table should be defined in a section of the
notes even if they are defined in the body of the report so table information can
be quickly understood.
I. ARARs. Include potentially applicable ARAR values, their sources, and
whether or not they apply to each alternative.
II. Evaluation of Remedial Alternatives. Include description of each
alternative, compliance with the MTCA threshold criteria, and alternative
ranking for each DCA criteria.
III. Cost/Quantity Summary. Include any quantity or cost assumptions made
for each alternative.
IV. Cost Detail for Alternatives. Itemize costs for each alternative, including
(but not limited to) permitting, oversight, labor, disposal, transportation of
materials, material costs, incidentals, operations and maintenance, and
reporting costs, and provide a total cost for each alternative.
V. If additional site investigations were conducted after completion of the RI,
include sampling information, laboratory methods, applicable cleanup
levels, and analytical and field measured data. Group by media type. For
larger data sets, consider making a summary table to exceedances. Tables
should include cleanup or proposed cleanup levels with any contaminant
exceedances clearly indicated using bold font or shading. Non-detecible
levels should be noted as “U” with the numerical laboratory reporting limit
(RL) provided rather than “ND”.
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Feasibility Study (FS) Checklist
Feasibility Study Appendices FOR ECOLOGY USE ONLY
General. Appendices should contain a description of content and explain how Comments
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to interpret the information for use. Not all of the following suggestions will
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apply to all sites.
VI. Contractor bids or other documents showing how quantity and/or cost
estimates were made.
VII. If additional site investigations were conducted after completion of the RI,
include exploratory logs, well installation diagrams, field records,
analytical laboratory reports, details of field and analytical methods, and
any applicable Work Plans, Sampling and Analysis Plans, etc.
VIII. Limitations. Explain any limitations that apply to the work.
IX. Other documents that provide additional context or contribute to the
understanding of the site or remedial alternatives; see suggested report
format for additional information.
Miscellaneous Items
X. Certification (Licensed Professional Stamp). Engineering, geologic,
and hydrogeologic work must be performed under the seal of an
appropriately licensed professional, as required by RCW 18.43 and
18.220.
XI. Environmental Information Management (EIM). All sampling data
must be uploaded into Ecology’s EIM database. This allows Ecology to
access data, check results, and/or perform additional analyses. For more
information, reference: Submittal Data Requirements.
XII. Additional information may be requested by Ecology as required to fully
assess remedial alternatives.
XIII. Submittal Requirements: Ecology requests three copies of reports
submitted per WAC 173-340-850. Please contact the cleanup project
manager for specific submittal requirements.
To request ADA accommodation or materials in a format for the visually
impaired, call Ecology at 509-454-7834, Relay Service 711,
or TTY 877-833-6341.
Washington State Department of Ecology
Publication No. 16-09-007 5
