UnrMd State*
Environmental Protection
Agency
Off « of
Solid W»«t« and
Emergency Response
3EPA
DIRECTIVE NUMBER: 9932.0
TITLE: Method for Prioritizing CERCLA Preliminary
" Assessments at RCRA Facilities
MAY 3 I 1988
APPROVAL DATE:
EFFECTIVE DATE: MAY 3 1 1988
ORIGINATING OFFICE: OWPE
0 FINAL
DDRAFT
LEVEL OF DRAFT
©A Signed by AA or OAA
D 8 Signed by Office Director
Q C Review & Comment
REFERENCE (other documents):
9421.00" RCRA Program Directions for FY 1989"
OSWER OSWER OSWER
VE DIRECTIVE DIRECTIVE Dl
-------
United States
Environmental Pro:ec:ion
Agency
Soi«3
oEPA
DIRECTIVE NUMBER: 9932.0
TITLE: Method for Prioricizing CERCLA Preliminary
Assessments at RCRA Facilities
MAY 3 I 1988
APPROVAL DATE:
EFFECTIVE DATE: MAY 3 I JS88
ORIGINATING OFFICE: OWPE
£3 FINAL
D DRAFT
LEVEL OF DRAFT
© A Signed by AA or OAA
Da Signed by Office Director
DC Review & Comment
REFERENCE (other documents):
9421.00" RCRA Program Directions for FY 1989"
S WER OS WER OS WER
DIRECTIVE DIRECTIVE Dl
-------
onrtea oiates environmental Hrctecncn Agency
Wasnrngton. QC 2Q*6Q
OSWER Directive Initiation Request
' Directive Nu
9932.0
2. Originator Information
Name cf Contact Person
Ellen Brown
Mail Coda
WH-527
OWPE
475-9843
3. Title
Method for Prioritizing CERCLA Preliminary Assessments at RCRA Facilities.
Provides Regions a method of assigning priorities to RCRA Sites, to determine
the order in which they will be entered on CERCLIS. Summarizes the EPI Purpose
and Process for distribution to the public.
5. Keywords
EPI, CONCEPT, PRIORITY
6a. Does This Directive Superseae Previous Oirectiveis;?
b. Does It Supplement Previous Oirective(s)?
IJLJ
No
Yes What directive (number, title)
Yes What directive (number, title)
9421.00 "RCRA Program Direction for FY 1989"
7. Draft Leve(
A - Signed by AA/DAA
B - Signed by Office Director
C - For Review 4 Comment
0 - In Development
8. Document to be distributed to States by Headquarters?
X
Yea
No
This Requaat Meats OSWER Olractlvaa System Format Standards.
3. Signature of Lead Office Directives Coordinator
Date
10. Naore and TTtleerf-Approyhg Official
/ i
Date
EPA Form 1315-17 (R«v. S-87) Previous editions are obsolete.
\J
OSWER OSWER OSWER O
VE DIRECTIVE DIRECTIVE DIRECTIVE
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OSWER Directive # 9932.0"
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
MAT 3
OF?!C; Or
50LIO WAS" A.NO EMERGENC
MEMORANDUM
SUBJECT: method for Prioritizing CERCLA Preliminary
kssessmen-ts at RCRA Facilities
11 fi^/'ji
FROM: JJ^ Wffts^^n Porter
/yAssistant Administrator ' . ' '
TO: Waste Management Division Directors
Regions I-X
Last October, I established the Environmental Priorities
Initiative (EPI) Task Force. Its mission is to develop an
approach to coordinate the RCRA and CERCLA programs to ensure
that this Agency address the most environmentally significant
hazardous waste contamination problems first. One of its.first
tasks was to determine the universe of possible EPI sites. The
. EPI universe is made up of RCRA closing land disposal facilities
and storage and treatment facilities. These facilities may
present hazardous substance problems which may require action
under CERCLA or RCRA. We have provided lists of facilities that
we think constitute the EPI universe to your representatives on
the Task Force for their review, so that a total universe can be
identified. It includes close to 5,000 facilities. Approxi-
mately 2,000 of these sites are already on CERCLIS. Most of
these have received CERCLA Preliminary Assessments (PA's) and
some have received CERCLA Site Investigations (Si's).
The remaining 3,000 facilities would be placed, in a phased
manner, on'the CERCLIS list of facilities and could be eligible
for Superfund action. They also -would continue to be subject to
RCRA action and authority. The Superfund program has agreed to
perform PA's for these EPI sites on a phased-in schedule based
on the environmental priority assigned to each facility. The
Task Force has developed a method that Regions and states could
use to assign priorities to facilities. Assigning priorities
should result in three roughly equally sized groups of
facilities: those ranked highest priority; those ranked medium
priority; and those ranked lowest priority. The priority ranking
will determine the order in which EPI facilities will be entered
onto CERCLIS and receive PA's under CERCLA.
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OSWER Direc-cive it 9932.0
The attached paper outlines this suggested method for
assigning priorities to sites to determine the order in which EPI
facilities will receive Preliminary Assessments. Several of
the Regions have their own way of assigning priorities to such
facilities and of managing that process, such as through the
Environmental Services Division. We are forwarding this
information to you because we believe that it may be helpful to
those Regions that have not developed a method for assigning
priorities to these sites. It is based on two criteria that the
Task Force agreed should be included in setting priorities:.the
environmental sensitivity of the location and the facility's
history of releases. Any Region that is interested in using this
method or that needs additional information on the attached
material should contact Ellen Brown of my staff at 475-9848.
This process of setting priorities is not designed to be
resource intensive; the important thing is to roughly order
facilities at the start of the PA process. I am hopeful that
this prioritization can be completed this year.
In addition, I am attaching a copy of a paper entitled "The
Environmental Priorities Initiative: An Integrated Approach to
Identifying and Addressing Environmental Problems." This paper
is designed to be.useful in explaining EPI to the public and to
State officials. I am sending it to the Regional Administrators
as well. " .''-:.
Please feel free to give comments on these two items to
myself or Elaine Stanley,/Chairman of the Task Force. The EPI is
an important element in our FY '89 and out-year program planning.
It will, I feel, lay the groundwork for reconciling the priori-
ties of our individual programs with the agency's overall
environmental goals.
Attachment
cc: EPI Task Force Members
Jon Cannon
Sylvia Lowrance
Henry Longest
RCRA Enforcement Branch Chiefs, Regions I-X
Superfund Branch Chiefs, Regions I-X
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OSWER Directive & 9932.0
METHOD FOR PRIORITIZING CERCLA PRELIMINARY
ASSESSMENTS AT RCRA FACILITIES
Background
This paper describes a method to assign priorities to RCRA
sites that are to receive CERCLA Preliminary Assessments as part
of the Environmental Priorities Initiative. These RCRA
facilities include closing land disposal facilities and storage
and treatment facilities. These facilities would be placed on
the CERCLIS list of facilities where/ as a first step, they would
receive a Preliminary Assessment. This paper outlines a method
for prioritizing preliminary assessments.
Summary of Method
The prioritzation scheme is based on two general factors:
environmentally sensitive location and history of releases.
Several data sources exist for each of these factors. Each
Region should use at least one data source for each factor,
preferably one that is either available or easy to obtain. The
outline of the method to be used to derive the final score for
each site is given below.
Outline of Method
Preliminary assessments would be prioritized based on an
assessment 'of the potential hazard posed by each former RCRA
facility. Hazard would be assessed based on two criteria:
o Is the facility located in an environmentally sensitive
area? .
o Does the facility have a history of releases?
Data to assess the facility against each criterion would be
drawn from a variety of sources. Each Region would be free to
use data sources that are convenient or available. Regions must
use at least one data source for each of the two criterion,
i.e., environmentally sensitive location and history of releases.
One data source, among five that may be ch-osen, that satisfies
the first criterion is the DRASTIC ranking. Regions may use one
or more of the four alternative data sources to satisfy this
criterion. For the second criterion, history of releases,
Regions may choose from four data sources. Exhibit 1 summarizes
each data source for each criterion.
Exhibit 2 provides a table ranking each of the two general
factors; environmentally sensitive location and site-specific
problems (release potential) on a three-part scale. Sites are
ranked with respect to environmental sensitivity as being
-------
OSWER Directive # 9932.0
either "Highly Sensitive1/ "Sensitive1/ or "Not Sensitive1, and
are ranked as having eit.her "High1/ "Medium1/ or "Low1 history of
releases. This results in a site being ranked within one of nine
boxes as shown in Exhibit 2. The prioritization scheme chooses
the sites with the higher score first/ i.e. sites scoring a nine
have the highest priority/ whereas sites scoring a one have the
lowest priority.
Example: How to rank a facility
o Determine the characteristics of the site with respect
to environmentally sensitive location and history of
releases using the various possible data sources.
o Use Exhibit 2 to determine which box best describes the
characteristics of the site.
o The score for the site is obtained by
putting the site in one of the boxes in
Exhibit 2.
The scheme presented here would require an average of
approximately 4 to 6 hours per site of staff time to rank each
variable. EPA estimates that a CERCLA preliminary assessment
itself requires 40 to 60 hours.
Review of Data Sources
Appendix A contains an explanation of the acceptable data
sources for determining environmental sensitivity of the location
of the facility. We have included an assessment of how easy it
is to obtain the information as well as how reliable it is
thought to be.
Appendix B contains a summary of discussions with Regional
personnel about Section 3007 SWMU letters/ Facility Management
Plans (FMPs)/ and quality of information in State or Regional
files. These discussions took place via telephone; there was no
attempt on our part to verify the information we received.
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OSWER Directive // 9932.0
EXHIBIT I
SUMMARY QF DATA SOURCES
Dele Source
Steps Required
Produces
Meaningful Priorities
Effort Required
Msndstory
or
Opt Ions)
Environmentelly Sensitive Location;
DRASTIC
Countles
IdantIf led
through
assessments by
State and EPA
officials
LocetIon near
dense ly
populated areas
LocatIon near
pub IIc water
supply Intake
LocatIon near
environmentally
sens I t I ve areas.
such as net lends
Identify which hydrogeoIogIc
region In which the site Is
located using State maps In
the USCS National Meter
Summary, and/or the proper
USGS 7ft' quadrangular map.
Reed the DRASTIC Index for the
s I ta.
Identify factors by which
counties will be ranked (ground
water, surface water, air).
Define how each factor will be
ranked.
Identify the latitude and
longitude of the facility.
Use this locetton to generate
the population denalty within e
pre-aiatgnad radius with GEMS
(Geographic Exposure Modelling
System).
Use PROS database to Identify
PMSs near facilities.
Check In detailed state/county
maps to see If the location of
the PwS Is correct.
Calculate the distance botween
the PWS end the facility.
OafIne environmentally
sensitive areas In detail.
Obtain detailed maps showing
these areas.
- Locate the facility on the
map .
Calculate the effect of the
fac I I I Iy base on distance.
lull purmeobI I I Iy. etc.
Madlum-Hluhi The DRASTIC
Indexing system, will produce an
ordinal ranking of facilities
that Is consistent among EPA
Regions.
Medium; This can be used
effectively as an Initial
screening measure.
Medium-High; If the dete Is
accurate, this crIterIon can be
very Important, as It affects
the people.
Medium-High; If -the dete Is
accurate, this criterion can be
very Important In prlorttl/a-
t Ion.
Low: After acquiring the
necessary materials (7ft* maps.
National Water Summary. DRASTIC
Manual), the time necessary to do
a score Is around 15 minutes.
Medium; After Identifying end
defining the ranking system, thu
actual ranking process should not
take about I or 2 hours.
Low: About 2-3 hours per site.
Mandatory
Opt I one I .
Opt tonal.
Medium; Approximately 2-4 hours
per site.
Medium; If the del a Is
accurate, this criteria could
be useful as an Initial
screening measure.
Medlum-Hlflh; Approximately 2-3
days per site.
OptlonaI
because the
accuracy of
thu data Is
uncer tain.
Opt tonal
because the
nature and
accuracy of
dut Is
uncar tsIn.
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EXHIBIT I
(ConItnued)
SUMMAHV OF DATA SOURCES
OSWER Directive // 9932.0
Data Source
Produces
Steps Required Meaningful Priorities Effort Required
Manila tory
or
Opt lonel
History of Releases:
Sect Ion 3007
SMMU Letter
Responses
feel I I ty
Management Plan
and Discussions
Un State and
Loril Officials
HWOMS Release
Data
Reviews of Stete
or Local fI las
or Inspect Ion
Reports
Sending and receiving of
letters. Compiling of data.
reviewing of responses.
Compiling and reviewing of FMPs.
Identifying appropriate
officials and discussing the
fee I I Ity Ith them.
Identify the EPA Identification
number for the facility.
Identify the Activity Code for
the activity In question.
Use HWOMS to generate relevant
data and analyze the data.
Identifying location of
pertinent records et either
State. Local, or Regional
offices. Gather records, and
review them for:
- Compliance history
He Iease prof Ile
Uuuree of public concern
Douroo of financial solvency
Medium to High: Data highly
varied among and within the
Regions.
At worst case, the data Is
simply an Inaccurate Mat of
SWMUs. Best case Includes
complete Release History. SWMU
descriptions, and General
Substance Inventory.
Medium: Although the FMPs
contain minimal data and are
generally considered less then
Ideal, dlacuaslons with Stete
end Regional and Local
officials may prove fruitful.
Low-Medlumi The quality of the
data varies sIgnIf(cent Iy.
Extensive and reliable data
exists on LOs. however. Data
on TS fact I It las Is less
rel(able.
Medium to High; Data quality
Is highly varied among Regions.
Mad I urn; Most of the responses
III require approximately 2 to 3
hours. May also require new
effort to sand out and tabulate
responses to SWMU response
let ters .
Medium to High; Review of
existing FMPs would require IS
minutes to I hour per facility.
Compiling FMPs for remaining
unlvarae would require hours or
days to complete for each site.
Low; Approximately I hour per
site.
Optlonel.
Opt lone I .
Optlonal .*
High; On average. It will
require a full day per facility
to review these records.
Opt tonal.
For history of releases, each data source Is optional, but Regions must use at least one of these.
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exhibit 2
RANKING MATRIX
OSWErk-Direc-cive fa
12.0
Env 11 onmenl a I
Sens 1 I i v iIy
Ml <|h I y Senn I I i ve
"\Pol on IIa1ReleaseHigh
\
Medium
There exists a history
or frequent releases.
The hazardous materials
released are easily
Ir anapor ted Into
environmental media,
having potentially
adverse effects on human
health and the environment
Few hazardous releases
have occurred historically.
Future releases can be
easily transported Into
environmental media and may
have adverse effects on
human health and the
env I r onment.
There exists no history of
hazardous releases. Should
future releases occur, the
hazardous materials trans-
ported Into environmental
media may have adverse
effects on human health
and environment.
Sens i t i VR
Score
There Is a history of
frequent releases. However,.
hazardous materials havln env i r <>n -
mi* nI .11 med i a .
Few releases have occurred
l.n the past. If future
releases occur, they may
or may not have potentially
minimal adverse effects on
human health and the envl-
i onment, since they are not
easily transported Into envl
r onment a I medla.
There exists no history of
releases. Should future releases
occur, they could have an adverse
effect on human health arid
environment since they are not
easily transported Into environ-
ment a t medla.
Score I
Sites hav I in) /i
first , whei e.is
higher scoie have greater priority, i.e., stlea scoring a 9 should have preliminary assessments dune
.sites soor I n
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OSWER Directive // 9932.0
APPENDIX A
REVIEW OF DATA SOURCES
Drastic Hydrogeoloqie Assessments
The DRASTIC ranking of a region's potential for groundwacer pollution is
a very quick and easy way to" establish an ordinal list of facilities based on
hazardous potential. The only requirements for doing a DRASTIC racing for a
facility are the DRASTIC manual and the tJ.S. Geological Survey National Water
Summary and/or the appropriate USGS 7-i1 quadrangular nap.
DRASTIC was-developed by the National Water Well Association, in
cooperation with the U.S. Environmental Protection Agency. The purpose for
the project was to create a method that would screen the groundwater pollution
potential of any hydrogeologic setting with existing information anywhere in
the United States. - ;
In order to perform a DRASTIC Indexing of a site, one must first locate
the site on a State or U.S. map. By comparing this location with the map
guide provided in the DRASTIC user's manual, it is possible to identify which
hydrogeologic region contains the site. The specific hydrogeologic setting
can then be determined by using the National Water Summary, and/or the United
States Geological Survey 7-t' quadrangular map of the site's location.
Finally, the user reads the DRASTIC Score printed at the bottom of the chart
that breaks down-the score.
-; The -DRASTIC process is a very quick way to evaluate and prioritize a
site. Once the initial materials are assembled, the actual indexing process
tak'es about 15 minutes. Gathering the correct maps and the su.-r^ary could ca.ke
a good deal of time for a Region that does not have ready access to them.
Discussions with the USGS indicated that ordering of quadrangular maps would
have to be done through the Denver office and they could not give a time
estimate on delivery.
The primary advantage to the DRASTIC system, in addition to the short
time it would take to use, is that the system gives an ordinal ranking based
on ground water pollution potential. The system is one that can be readily
used by all the Regions and would generate consistent and comparable results
provided that the scorer(s) were somewhat familiar with hydrogeology. People
without a background in hydrogeology would also be able to do the indexing but
the results would be less reliable if the site specific settings were not
identified precisely.
Counties identified through assessments of state officials:
Region III prioritized 245 counties in that region based on potential for
groundwater and drinking water contamination. The prioritization of counties
was based on the rankings of 5 factors, listed below.
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OSWER Directive # 9932.0
A-2
Based on the hydrogeology, the groundwacer availability was ranked
as 'Sigh', 'Moderate', and 'Low'.
The susceptibility for contamination is ranked based chiefly on the
history of contamination, and the permeability of the area.
.The. percentage of the population served by public water facilities
that draw on groundwater.
The total population that draws on groundwater.
The total number of potential sources of contamination.
Each alternative was ranked on a scale of 1-5, and the higher the total,
the greater the environmental sensitivity.
The primary resources needed to do a similar study are as follows. The
FERDS database of public water supplies, along with region and state-wide
maps, which are available, can provide adequate data for the factors listed
above. A time estimate is not readily available, however, the entire process
should not take a long time, not more than 1-2 hours per site, once the data
required becomes available. The Region III method prioritizes inspections
based on groundwater. This method could be expanded to include surface water,
industrial density, or other factors. This expansion will probably be costly,
though 'the results could be very helpful in a more complete prior itization of
.counties. ' '
Location near densely populated areas
According to the Hazard Ranking System (ESS), for groundwater and surface
water, a radius of 3 miles is defined as the critical radius, for populations
in the area of Superfund sites. For air, the critical radius is 4 miles.
Extensive population data exists in the United States Census. In
addition, a database, Geographic Exposure Modelling System (GEMS) developed by
the Office of Toxic Substances, provides ready access to many other models and
databases. This database has the ability to provide population densities, for
any radius around a facility, given the latitude and longitude of the
facility.
This data, if accurately obtained, may be very useful. Despite the
uncertain accuracy of the data for sparsely populated areas, this data source
could be a potentially mandatory criterion.
HVDHS release data
HWDMS is a dynamic database, that OSW created approximately 5 years ago
to keep track of RCRA facilities. The database contains information on
compliance status, permit status, whether a facility is a generator,
transporter, or a TSD facility of hazardous waste, and other items. The data
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OSWER Directive if 9932.0
A-3
cover che universe of RCRA facilities. Data on releases are usually available
if inspection reports have been filed.
The database is segmented, and consists of several records, hence, it is
easy to access even highly specific information. To access the data and
manipulate it, the EPA identification number, and the activity code number is
needed. These codes are. readily available within the database itself, and in
the HWDMS dictionary, v
The quality of data available in this database varies significantly.
Extensive and reliable data exist on land disposal facilities, however, data
on treatment and storage facilities are not as reliable. Due to the
uncertainty of the existence and reliability of data, this data source should
be optional until the database is updated. '
.Location near environmentally sensitive areas; e.g. wetlands,
: Great Lakes, Chesapeake Bay, etc.
There are numerous ways for a region to define 'environmental
sensitivity'. The definition can be based on natural features such as
wetlands, lakes, rivers, etc. In addition, there are various definitions for
these natural resources; for example, the U.S. Army Corps of Engineers and the
U.S. EPA use one definition, whereas the Federal Executive Order 1190 provides
another. . ' ,
Definitions of-' ' environmentally 'sensitive areas' usually deal wich areas
having saturated soil conditions such as swamps, marshes, bogs, and other
similar areas. Other potential 'environmentally' sens itive areas' are major
rivers, lakes, bays, and other similar areas. Another possible way of
defining 'environmentally sensitive areas', is by having the EPA Regions
determine areas similar to the ones described above, that need to be
preserved.
Because of the various definitions and nature of 'environmentally
sensitive areas,' there is very little data available that can be used on a
national basis. However, data such as maps of states, showing the physical
features, the underground soil and rock features, do exist in the National
Water Summary. Once 'environmentally sensitive areas' are defined, it may be
possible to get the relevant data. Due to the numerous possible definitions,
the data are hard to obtain, variy significantly, and are of uncertain
accuracy. Owing to the uncertainty of the data, this data source should be
optional.
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OSWER Directive // 9932.0
A-4
Location near public water supply intake
The proximity of a facility to a public water supply is potentially a
useful criterion in a prioritization scheme. EPA created a database called
the Federal Reporting Data System (FRDS), of Public Water Systems (PWSs), that
is administered by the Office of Drinking Water. Using this database, it is
possible to findTout the number and distribution of PWSs, within any radius of
the facility^." This data, should however/ be used carefully because the public
water systems are not all groundwater sources but are sometimes the water
treatment plants. The data contained in this database are sometimes
inconsistent, e.g., if the exact location of the PWS is not determined, then
the PWS is shown at the central point of the zip code in which it exists. In
additional, it was found that more than half of the PWSs have no source data
and nearly two-thirds of the sources have invalid/missing data. Also, the
latitudes and longitudes as used in the FRDS database are limited to degrees
and minutes which can represent an inaccuracy of as much as one mile in
latitude and 0.75 to 0.95 miles in longitude.'
This database is readily available. However, owing to the variable
accuracy of the data, this data source should be optional.
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13
SECTION 3007 SWMU REQUEST LETTERS
OSWEIT Directive
O2.0
Region
Universe Covered
Qua II t y of Inf a rant I i on
Future Resource Needs
Region I
Region I I
Region 111
Region IV
Region V
Region VI
Letters sent to most
not )I fee I IItlas.
depending on stale. .
but
Region VI11
Region IX
Region X
Let tars sent
feel I 11lea.
Latter* cent
fact I It lee.
to al I
to all
Letters sent to all land
disposal facilities and to
approximately 25% of non-
lanu disposal facilities.
Varied by State.
tatters sant to all land
disposal facilities, and
all treatment and storage
facl I 11 las .
Letters cant to all land
disposal facI I I I las. all
Incineration and storage
fee I I 11 las . and to all
facilities needing Federal
Enforcement Action.
Letters were sant to the
universe of facilities
that neru closing.
tatters Hera sent to about
75» of the 69 TSOFs.
Letters sent only to
people asking for permits.
(Not avaIlabla)
Letters sent to all I and
disposal facilities, and
to appro> linale I y IOX of
the rest.
Fair: Highly varied'data. Some give complete
release history and site-specific Information
while others give only a Mil of enlstlng
SWMUS.
( a J_r: Highly varied data, some are very
comprehensive, some are limited to listing of
units. Accuracy of some data Is questionable;
would be advisable to supplement with permit
writer's records.
Good: Good for non-reguI ated SWMU units.
Regulated units submitted Part 0 applications.
Has list of units, function, capacity etc.
Data on past and po&slblu releases.
Description of wasted handled.
fair: Highly varied data. Some give data on
RFIs. some very little. . About half have good
Informal Ion.
Good: Information enlsts on releases, quantity
of wastes generated and on whether wastes are
hazardous.
Fair; Information basica.lly covers the units.
There is also some Information on releases.
Pooi: InlormatIon covered Is mostly limited to
number of SWMU's at a particular site.
Fair: Information that exists Is good as a
starling point for further study.
l.uuil: I it t o illicit ion u « I i I i on the units, past
releases arid on s i t e - spec i i ts .
Universe would noj be difficult to complete.
Time necessary to'go through and review
responses It less'than a day per response.
Could review all (elters In Caribbean In 2
days. Not known (now long for NV and NJ.
Should not be toojhard. Would be time-
consuming for the facilities. For someone
with technical background. It would require
lase than an hour!to review each record.
Mould not be problem to complete the
universe. Collating responses would be hard.
Review of responses would require around S to
10 minutes each.
Files are entenslye. Mill be very hard
collate all the letters. It would take
around I to 2 hours to review each file.
to
To complete the universe It would not be
difficult. Mould Just have to define the
universe and send out letters. Would be hard
to collate all letters. It Is unknown how
long a .review would take.
Completing the universe would be very easy.
Collating letters and gathering more data
would be very time-consuming. lime to review
each Is about 15 to 30 minutes.
It would probably be very hard to complete a
universe. Mould take about 3-6 months. It
would take anywhere from I hour to a full day
to review each record. This Is dependent 011
the sUe of the facility and of the response.
Would lake about 30-60 days to complete the
universe. Mould be hard lo collate the
letters.
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B-2
OSWER Directive // 9932.0
DISCUSSIONS Will! STATE/LOCAL OFFICIALS: FACILITV MANAGEMENT PLANS (FMPa)
Region
Universe Covered
Quality of Information
Future Resource Neuds
Region I
Region 11
Region I 11
Region IV
Region V
Region VI
Region VI1
Region VIII
FMP* done for all land
disposal units and for
storage treatment
fact I 11la*.
fa.
FMP* done for
dispose I fac I I
all land
It lea.
FMPs done for I3I/ISO
plus Incinerators nd
commercial sewers.
LOs.
FMPs done for all land
dl»po»al facilities, but
not all TA.S fee I I 1 I lea .
FMPs done on a I I land
dlbposaI facI I 11 lea.
FMPs done for all LD
fact I 11 lea. and all
closing facilities. Done
for most T8.S facilities.
FMPs done for
facI I 11les.
FMPs done for
faclittles.
all ISO
all ISO
Poor; 2 page summary of very limited
Informal I on.
f_aj.r to Poor: Information Is the same as for
Inspection Reports Hut Includes a chart for
»hen permits are scheduled to be granted and
applied for.
fLsLLr.: FMPs were used to affirm what was
already known at Regional and Stale offices.
However, a Delphi approach, consisting of a
panel from both status and Motional Offices was
usud. Consislunt format usuil in each states.
GooH: Especially useful to coordinate between
Sidle arid Regional Offices. Have ranked
facilities on eiivl ronmeiil al significance; done
by e«purls basud on' the criteria of the RCRA
Implementation plan.
Good: Information consists of SWMU request
luTters. FMPs didn't prioritize situs; they
just looked at the facility and did the
needful. I.e.. gave a permit or suggested
L I o & u r u .
Fair: Information exists on schedule of
activities required. Data quality varies
wIdeIy .
Fair: Basud upon SWMU lut.lur responses. The
status keup the FMPs updated. FMPs were
created by tPA Reviewer and then sent to state
for concurrence. Muglon claims that Part B
applications provide better data.
I &U informal ion Is vary Mmitud.
It would take a great deal of time to upgrad
existing FMPs and'generate new onus. It
would take about 10-15 minutes each to revlu
exist Ing FMPs.
Existing FMPs required about 2 weeks to
complete each.
Existing FMPs reqv'red 2 days each to
complete. i
Would take about $ months to do FMPs for the
other sites, would need a lot of stale and
ReglonaI staff tIme.
Sent the Initial screening results to states
and asked them to do a draft FMP. Not known
how this was dona or how much effort was
required. FMPs on TS.S facilities not
planned, until Part B applications are callei
In. Cannot estimate time and/or resources
needed to complete the universe.
Further work will be done by the state.
Should not be hard to do. May take a long
lima, unsure of how long.
The entire universe completed with only
undiscovered Illegal SWMUs left to target.
Resource requirement would be very limited.
Would take a great deal of tImu and effort to
upgrade the FMPs. Existing FMPs would
require 15 minutes each In order to review.
Region IX (Not available)
Region X FMPs done on all land
disposal facilities.
Incinerators and about
of the rest.
I OK
fair: 11»: I Mt'b were devulopcd through a
dynamic process, anil I lie i i>l orma I i on varies
yrejlly on a iaie- by -case basis.
To complete the universe, FMPs have lo be
done on all T&.S facilities. Not feasible
given the region's current resource.
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OSWElTDirective
32.0
REVIEWS O» SIAIE OH LOC
'FILES. AND INSPECTION REPORTS
Region
Universe Covered
Quality of Information
Future.Resource Needs
Region I
Region II
Region III
Region IV
Region V
Region VI
Region VII
Region VI I I
Region IX
Region X
Unlve'ree Include* all
TSDs.
Unlveree
TSOs.
Unlvert*
TSDs.
(nc ludes ) I
Includes a)
A I I land disposal
facilities, and most
storage facilities. The
state office has files for
al I fact I 11les In the
state.
Information covering most.
If not alI the fee I I Itles
In the state, would be In
the state off Ices.
Information should
probably be available on
entire TSO universe.
Covers a I I land
fact I 11 les. and
faclI 11les.
dIsposa I
most I&S
Covers all TSO facilities.
Covers a I I land
fee littles, and
fact I It les .
dIsposa I
most T4S
(Not aval table)
Covers the ISO universe.
Good: Regional office contains permitting
dala. Inspection reports, enforcement actions.
SWMU responses and RFAs., Records of State
Action only kept al facility. Records of
General substance data also kept. Records are
duplicated In states, but are more current In
VI . HI . NH, and MA.
Good: States and region each contain unique
Information. Both contain Inspection reports
Best records exist at authorized states.
Ranked based on SWMU letters.
F_aJ.r: Based upon SWMU responses and DRASTIC
scores. Inspection reports enlsl In state
fIles.
Good: Extens Ive fI Ies unist In Doth state and
Regional offices. far storaye facilities.
state files are more comprehensive.
Assessments for all land dis'posal facilities
have been done.
Gaud: As of right now. s I te-specIfIC
Information exists In,the slate offices. If
RFAs have been done, they are at the regional
office. Part B applications for I&S facilities
are required by May 1968; these Hill be Kept at
Iliti Regional office.
Fair: Majority of the Information Is In
facilities files at the Regional office. Some
information exists in the state offices as
well. HFAs exist and are being completed for
land disposal facilities. for facilities that
do not have RFAs. It Is doubtful whether the
Information Is useful.
Good: Site-specific Information for all
facilities seeking permitting or closure exists
at states. Regional office contains Part B
applications. PA/Sls. and any completed or In
progress RFAs.
Fair: Site-specific Information exists for
facilities applying for permits. Information
exists at both stale and Regional offices.
though sialu information Is more comprehensive.
The records range In slxe from 10 pages to
300-500 pages. On an average, one can expei
to spend K a day (or each file.
Facilities have already been ranked using
3007 letter responses. This Mill save time
but still expect \o spend large amounts of
time to review alj records.
It would require an average of 2 hours per
file to review these records.
Time needed to go' through files Is a lot. I
would be better to ask a few knowledgeable
people In state and regional offices. Time
required to examine records Is around 2 hour
each.
Cannot estimate how long It would lake
collate Part 8 applications.
poor: Fllus are in Ihu
Ihu information varies
regional offices and
To look for LO facilities need to look only
at RFAs. For Information on TILS facilities,
3-5 days of file-searching are needed.
For reasonably detailed Information, expect
one full day at Region and one full day at
state per site. For a general feeling It
would take 2-3 hours.
Mould take a long time to collate. For a
prlor 11liatton scheme, would be better to
talk to people. Review of files would
require 2 to 3 days eacti.
Would take a long time to look through Mlu.
-------
OSWER Directive // 9932.0
THE ENVIRONMENTAL PRIORITIES INITIATIVE: AN INTEGRATED
APPROACH TO IDENTIFYING AND ADDRESSING ENVIRONMENTAL PROBLEMS
Introduction: The Environmental Priorities Initiative
The Environmental Priorities Initiative (EPI) is a new
approach to managing environmental problems, particularly at
RCRA facilities. It is an integrated RCRA/CERCLA effort
that will enable the Agency and the States to identify,
evaluate, and cleanup first those sites that present the
greatest threat to human health and the environment.
Why Is An Integrated Management Approach Needed?
It is imperative that EPA address the worst
environmental problems first. .However, our current approach
often precludes this. We sometimes handle sites reactively
as they become the subject of public concern and we 'may not.
always respond to .the worst environmental problems first..
The public highlights such situations when the site
threatens the surrounding community's health and well-being,
a point well past the reach of changes in facility
management, preventative measures or early corrective
action.
Also, the Agency does not always deal with our nation's
worst environmental problems first because it tends to
address cleanups on a program-specific basis. That is,
there is a tendency to use only those authorities available
under a single program's authorizing legislation. As we
address facilities, we can enhance our effectiveness if we
do not limit our approach to only those authorities
available under a single program. EPI is based on the
belief that the Agency should use whichever authorities are
available including a combination of RCRA and CERCLA
authorities -- to achieve cleanup at a site.
Until recently we have focused our resources on
permitting and requiring corrective action at land disposal
facilities and incinerators, consequently, the RCRA program
has not systematically addressed corrective action needs in
other segments of the Subtitle C universe, such, as closing
land disposal facilities and most storage and treatment
facilities. Many of these facilities may present serious
threats to human health and the environment. Although
closure plans for some of these facilities may be submitted
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OSWER Directive # 9932.0
and approved by FY 1989, the reality is that the extent of
corrective action needed at many if not most of these
facilities may not be determined until well into the 1990 's.
We must begin to address facilities that need corrective
actions or closure to prevent serious threats to human
health and the environment.
As an Agency, we need to develop a management scheme that
will enable us to target our cleanup efforts at sites with
the most serious environmental problems first. Superfund
includes a process to screen a large number of sites to
determine which sites present the most serious environmental
problems. By applying this process to certain RCRA sites,
the RCRA sites that present the worst environmental problems
can be identified systematically for priority action.
Through the use of joint RCRA and CERCLA corrective action
authorities, sites can be addressed quickly and efficiently
to prevent facilities from becoming tomorrow's Superfund
sites. The creation of such an integrated process for
assessing and cleaning up RCRA sites is consistent with the
Agency's mission to protect human health and the
environment.
The Universe of Sites To Be Addressed Under EPI
The Agency has identified a. large universe of sites that
may require corrective action for hazardous waste
contamination under the authority of RCRA or Superfund.
Initially EPI will focus on the following types of
facilities:
o Operating RCRA storage and treatment facilities;
o Closed or closing RCRA storage, treatment, and land
disposal facilities; and
o Ninety-day.accumulators generators officially
included in the RCRA universe as storers.
Operating RCRA incinerator and land disposal facilities
also may require corrective action, but are currently being
addressed as a priority under RCRA.
There are additional types of sites that may merit this
focused integrated RCRA/Superfund management approach that
the EPI is now applying to Subtitle C RCRA facilities.
Examples of such facilities might include Subtitle D
facilities, facilities that store, treat, and dispose of
PCB's, or certain underground storage tanks. In the future,
the Agency will consider how it can best apply the EPI
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OSWER Directive it 9932.0
principles to such facilities to ensure that we address the
worst environmental problems first and use RCRA and CERCLA
authorities in an integrated way to achieve effective and
expeditious clean-up.
How EPI Will Work
The EPI would enable the Agency to address facilities,
such as closing RCRA facilities, that otherwise would not be
addressed for some time, under current Agency priorities.
The EPI will:
1. Require a streamlined, priority-setting mechanism
for RCRA closing land disposal and storage and
treatment facilities to determine for which
facilities an assessment should be performed, and in
what fiscal year. This screening process could be
implemented at the Regional or State level, using
approaches most appropriate and efficient for each
Region.' Several Regions have expressed a desire to
take a more integrated approach to directing
resources toward the most environmentally
significant facilities. Effective ways are needed
to identify these facilities and some Regions
have begun already to establish priorities based on
potential threats to human health and environmental
significance. .
2. Enable the Agency to conduct Preliminary Assessments
("PA's") at RCRA storage and treatment and closing
land disposal facilities which are not on a
permitting path. The PA's will provide information
to allow an estimate to be made of environmental
significance. This estimate would include a
preliminary score based on CERCLA's Hazard Ranking
System ("HRS"). Those sites that do not meet the
HRS cut-off will be removed from the EPI universe
and put back in the RCRA queue. Most of the
remaining facilities will receive an SI/RFA. The
. SI/RFA will be comprised of the elements of a
Superfund SI under CERCLA and a RFA under RCRA.
Once performed the SI/RFA will provide a basis for
permitting or enforcement action.
3. Provide a process by which the Regions and States
can determine an appropriate enforcement strategy
for a site using authorities available under RCRA
-------
OSWIR Directive # 9932.0
and/or CERCLA to assure that a site is cleaned up.
If an owner/operator is unwilling or unable to
perform corrective action, clean up of the site
under CERCLA would be considered.1
In summary, the Environmental Priorities Initiative (EPI)
will enable the Agency to determine which sites pose the
greatest environmental threat and deal with those sites
quickly and effectively by using the authorities that work
best for the particular site.
facilities for which corrective action
authorities are available, are not eligible for listing on
CERCLAfs National Priorities List ("NPL") unless the Agency
determines that RCRA corrective measures are not likely to
succeed due to one or more of the following factors:
(1) The owner/operator is bankrupt;
(2) The owner/operator has lost authorization to operate
and his compliance history indicates an
unwillingness to perform corrective action; or
(3) The owner/operator is unwilling to perform
corrective action, to be determined in a case-by-
case basis.
The agency will publish a policy notice defining the
criteria by which it will determine that an owner/operator
is "unwilling" in the future.
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