U3£,
            UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                       WASHINGTON, D.C. 20460
                             JUN  27 !9S5
                                    OERR Directive 9210.0-01
MEMORANDUM
   SUBJECT:
FROM:
TO:
           Transmittal  of Guidance for Data Collection at
           State-lead NPL Sites
             Stephen D.  Luftig, Acting Director
             Office of Emergency and Remedial Response

             Director, Waste Management Division
               Regions I,  IV, V, VII
             Director, Emergency and Remedial Response Division
               Region II                        •     ,
             Director, Hazardous Waste Management Division
               Regions III,  VI, VIII, IX
             Director, Hazardous Waste Division
               Region X
PURPOSE
     This memorandum  transmits guidance for collecting data at
National Priorities List  (NPL)  sites where the CERCLIS lead code
is "SN"  (State,  No Fund Money)  or "SR" (PRP Response Under.State
Order).

BACKGROUND

     An audit of FY 1993  CERCLIS data was completed by the
General Accounting Office (GAO)  last fall.  During the course of
the audit, GAO discovered data inaccuracies related to State lead
NPL sites.  In some instances,  data for these sites were
extremely outdated, and in other cases, sites had not been coded
with any previous events  when they were already in the RA
construction phase.   These State-lead sites are on the NPL and
therefore, must  be tracked accurately.

OBJECTIVE

     The objective of this memorandum is to provide guidance to
ensure that CERCLIS/WasteLAN  contains accurate and timely state
lead accomplishments  data.
        Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Recycled Paper (40% Postconsumer)

-------
                                   OERR Directive 9210.0-01

     Guidance for Data Collection at  SN and SR Lead  NPL Sites

Timeframe

     The Regions will consult with their state representatives on
an annual basis to obtain accurate information on SN and SR lead
events at NPL sites. J To ensure consistency, we are requesting
that the information be updated as of September 30 to coincide
with the end of the fiscal year.  We believe many regions meet
with their state representatives throughout the year so this
would be the ideal time to collect the data.

Data Required

     Since these sites do not qualify for SCAP credit, many of
the specific data elements associated with SCAP will NOT be
required.  While technical data qualifiers, actual costs
associated with events, and planning data are not required, the
data would be extremely valuable for future discussions on
comparing cleanup at State and EPA sites.  Information on State
Enforcement activities is not required.  However, the following
data elements will be required by operable unit:

          RV    - Start and Complete Dates  (Actual)
          RI/FS - Start and Complete Dates  (Actual)
          ROD   - Complete Date  (Actual)
          RD    - Start and Complete Dates  (Actual)
          RA    - Start and Complete Dates  (Actual)
          Construction Completion - Sites that are going to be
          included in the "construction completion" list must
          have the proper dates and documentation (i.e.,
          Preliminary Close Out Report, Close Out Report, No
          Action ROD Certification or comparable State'document
          with EPA certification) required of all other sites
          reaching this milestone.

     Since many states do not follow the "standard pipeline
process" for addressing their sites,  the region will have to work
with,the state to categorize the site correctly before entering
the information in WASTELAN.

Dates

     State records do not always show the specific date that an
event occurred.  In many cases, months or even seasons of the
year are the best the state can provide.  To make sure coding of
dates is consistent, please adhere to the following guidelines:

          Exact Dates - Use the exact-date if provided.

                                1

-------
Dates  (cont'd)

          Month. Year - Use the last day of the month provided,
          for example December 1993 would be coded as 12/31/93.

          Seasons     - Use the last day of the last month of the
          season of the year.

          Fall   = 1st Quarter (Oct, Nov, Dec)
          Winter = 2nd Quarter (Jan, Feb, March)
          Spring = 3rd Quarter (April, May, June)
          Summer = 4th Quarter (July, Aug, Sept)

          For example, Spring 1993 would be coded as June 30,
          1993.  A note to the site file should be written
          explaining how this date was derived.

Documentation

     All data contained in the CERCLIS/WASTELAN database must be
documented and state-lead data are no exception.  However, the
type of documents required to justify a state-lead accomplishment
will not exactly coincide with documents required for Fund-lead
accomplishments.  For example, documentation to support the
conclusion of the RI/FS (the ROD) will probably not be available
for state lead sites.  Jf EPA and the state agree that a site is
at the ROD stage, some type of official state document should be
put in the file with a note explaining why EPA feels this
justifies the accomplishment ;  If an official document is not
available, a signed letter from the state certifying that the
accomplishment is valid would be sufficient.
                  i
     Maintenance of documentation is the responsibility of either
the state or the region.  If a state and a region determine that
the state is the appropriate entity .to maintain documents, then
EPA regional files should reflect where the substantiating
documents are stored.

Reports

     Headquarters will develop, in conjunction' with CERCLIS III,
a PC-based report that will allow regions to obtain a. list of
sites needing updates.  The report will also enable the regions
to provide states with documentation that CERCLIS/WasteLAN has
been updated with the correct information.

-------
INCORPORATION OF REGIONAL COMMENTS

     In response to regional comments, we modified the draft
guidance to require reporting on an annual basis only.  We also
included removals and added the option of either the states or
the regions maintaining accomplishment documentation.  We believe
these changes address regional concerns.

IMPLEMENTATION

     Please review the following guidance and begin
implementation immediately to ensure that your region can report
state lead activities for Fiscal Year 1995.

CONCLUSION

     If you have any questions regarding this guidance, please
contact Ed Ziomkoski at (703) 603-8907.

cc:  Superfund Program Management Branch Chiefs
     Information Management Coordinators
     Linda Boornazian
     Jim Woolford
     Alan Youkeles

-------