A continuous process for assessing site-specific conditions and the need for action;
Cross-program coordination of response planning;
Prompt risk reduction through early action (removal or remedial);
Appropriate cleanup of long-term environmental problems;
Early public notification and participation; an.i
Early initiation of enforcement activities.

SACM is a process change that should be considered for all Superfund activities. Implementation of this policy will be
consistent with the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) and the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA). Overall Superfund priorities remain the same: deal
with the worst problems first; aggressively pursue enforcement; and involve the public and relevant State agencies at all
appropriate stages of the work.
SACM Assessment

Assessing sites under SACM involves
the following principles:
The process integrates tradi-
tional site assessment func-
tions to allow continuous as-
sessment for high priority
sites that proceeds until all
necessary data are collected
to screen sites or support any
needed response actions.
SACM goals indudecombin-
ing activities to support both removal and remedial
assessments.Thecontinuingassessmentprocesssup-
ports both National Priorities List (NPL) listing and
remedial actions.

P.esponse action decisions should be initiated as soon
as evidence indicates that early action is warranted.
Any appropriate enforcement actions should be ini-
tiated as well. Assessment work can continue concur-
rently with early actions.

Assessment procedures are coordinated to ensure
that data collected in one phase of assessment sup-
port other assessment, enforcement, and response
activities.
Faster... C/eaner...Safer
• Sites posing the greatest threat are ad-
dressed first ("Worst Sites First"). All sites
Oy will be reviewed to determine site prior-
Ob ity for continued assessment
Superfund assessment under
SACM integrates previously sepa-
rate removal and remedial assess-
ments intoa singleprocess. Under
SACM the assessment processes
operate concurrently; specific
functions need not be completed
before other functions can start.
Integrating assessment functions
will cut several years from the assessment and cleanup
process. Sites receive the appropriate level of effort needed
to make assessment decisions, and sites needing no further
action under Superfund are designated as Site Evaluation
Accomplished (SEA). Sites assigned an SEA designation
are referred to the States or other regulatory authorities for
further action, as appropriate. Whenever possible,
Superfund assessment activities are conducted concur-
rently with response and enforcement actions. The basic
principles of SACM assessment are built upon the need to
eliminate redundancy and expedite the Superfund pro-
cess.

The SACM assessment approach can screen out a large
percentage of potential releases early in the process. Where

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it is clear no CERCLA response action will be taken, the
assessment is completed by documenting the basis of the
decision through an SEA designation. If further data indi-
cate that the site is likely to have a Hazard Ranking System
(HRS) score  of 285 or more, EPA (or the State, under a
cooperative agreement) may initiate a Remedial Investiga-
tion (RI). Additional data  needed to  prepare the HRS
package can be collected while the RI is underway. RI data
can be used to support removal action decisions and HRS
scores, as well as remedial  action decisions. The Region
must include documentation required by the NCP for
moving from one phase of assessment to another.

The Regional Decision Team (RDT) is an integral part of the
site assessment process. Under S ACM, coordination among
removal, remedial, and State agency personnel is critical,
and fostering that coordination is a role of the RDT. At the
point where assessment information is adequate for deci-
sion-making, the RDT convenes to consider options for
sites. The RDT can men direct or recommend a response
action (e.g. time critical removal), decide to collect addi-
tional data, develop an enforcement strategy, and recom-
mend placing the site on the NPL.

The States have always played a critical role in site assess-
ment,  performing most of the Preliminary Assessments
(PA) and many of the Site Investigations (SI). EPA expects
that role to continue under SACM. The EPA Regions and
the States will coordinate to develop two-way communica-
tion concerning Federal and State response actions. EPA
Regions are responsible for working out the appropriate
arrangement with each of their States.

Coordination of assessment and enforcement activities is
also critical. When it is feasible, the site assessment reports
should identify owners, operators, and witnesses, with the
appropriate  documentation. Likewise, they should de-
scribe generator  records and other useful information,
such as  drum labels. The decision to start a Potentially
Responsible  Party (PRP) search requires a balancing of
resources. Although many sites (i.e.,  those designated
SEA) will not need PRP searches, rapid action under SACM
may require tliat PRP searches begin early in the process
for some sites. As a general  rule, PRP search activities
should begin as soon as possible after the decision is made
that a response action is likely to be required at the site.

Experience has shown mat early and frequent communica-
tion with local communities can enhance site response, and
this will be particularly true under SACM. Where appro-
priate, EPA and the State  should take the initiative in
commencing community involvement early in the assess-
ment  process. The Agency is developing guidance  for
community involvement activities at the assessment stage
of the process.
Consistent with the NCP, listing sites on the NPL will
continue to be a prerequisite to spending remedial action
funds to clean up sites. The  HRS will continue to be the
primary basis for selecting sites for the NPL. SACM does
not change the role of the HRS and NPL, and in general
SACM should not significantly affect the number of sites
that EPA will place on the NPL.

Expediting Cleanup Through SACM Assessment

SACM promotes performing risk assessment and RI activi-
ties earlier in the assessment  process for a site where data
indicate remedial action will be needed. Once a decision
has been made to conduct the RI in conjunction with HRS
data collection, integrated assessment data collection and
sampling efforts continue to:

   o Obtain documentation for the HRS; and

   ° Characterize site sources, extent of contamination,
     and risks to determine appropriate cleanup actions.
Consistent data collection approaches and appropriate
data quality objectives that serve the needs of early action,
long-term action, and NPL listing will promote efficiency
in Superfund. A single team should collect samples and
select analytical methods to serve multiple program needs.
A coordinated site mobilization eliminates duplication of
tasks and reduces sampling and analyses, saving both time
and money.

The scoping and planning of the RI should begin as soon as
EPA determines that the site will most likely require reme-
dial action. The RDT may decide to begin an RI at any time
during the assessment process. Once RI activities begin,
assessment activities continue concurrently to collect suf-
ficient information to determine the site score for possible
listing on the NPL. While a site might be designated as SEA
during that process, the RDT should select sites for early
RIs only where it appears the site will meet the criteria for
the NPL. Removal actions can, of course, be taken at any
time in the assessment process, and the RDT should con-
sider an early action at any site selected for an early RI.

One key to the success of the SACM approach is to select
the appropriate sites for starting the  RI prior to HRS
scoring. It is important to avoid committing high levels of
resources to sites that may not be eligible for the NPL. Some
site conditions, in particular where human exposure or
contamination of a sensitive environment has been found,
clearly indicate that the HRS score will be above 28.5 and
that a response action will be needed (see Figure 1). These
"NPL-caliber"  sites will be a focus of integrated assess-
ments and early actions.

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Even where a site appears to warrant an early RI, there is
some possibility that the site will not score high enough to
be placed on the NPL. EPA recognizes this and is willing
to proceed with the RI early in the assessment process to
                     FIGURE 1:
        Examples of NPL-caliber Sites

     Public  drinking water  supplies are contaminated
     with a hazardous substance.

     Private wells are contaminated with a  hazardous
     substance above a health-based benchmark

     Soils on school, daycare center, or residential proper-
     ties are contaminated by a hazardous substance above
     background levels.

     A hazardous substance is detected above background
     in an offsite air release in a populated area.

     A highly toxic substance known to bioaccumulate
     (e.g., PCBs, mercury, dioxin,  PAHs) is discharged
     into surface waters.

     Sensitive environments  (e.g., critical habitats for en-
     dangered species) are contaminated with a hazard-
     ous substance above background levels.
encourage faster response actions at the majority of cases.
Moreover, sites with the conditions described above will
often meet the criteria for removal actions anyway, and the
RI will provide valuable information for any response that
is ultimately selected.

In addition to the risk related conditions, the RDT should
consider the following when evaluating whether an RI
should be initiated at a site:

   • Some sites may be excluded from Superfund consid-
     eration under policy, regulatory, or legislative re-
     strictions. For instance, EPA policy is to defer from
     the NPL those facilities subject to corrective action
     authorities of the Resource Conservation and Recov-
     ery Act (RCRAXsee 54 FR 41000, October 4,1989).

   • At sites where receptors have been exposed to haz-
     ardous substances, but the source or sources are
     unknown, the decision to perform an early RI may
     depend on the nature of the potential sources. For
  example, if a RCRA facility is a potential source, an
  early RI should generally not be performed based on
  the RCRA deferral policy. However, in most other
  cases, an early RI may contribute to identifying the
  source or sources of contamination.

 The PRP search and other enforcement actions should
 indicate whether ensuing site response will be Fund-
 or PRP-lead, under the policy that enforcement first is
 the preferred strategy. While the above serve as gen-
 eral guidelines, the RDT will need to evaluate indi-
 vidual cases to determine whether to proceed with an
 early RI and whether enforcement or the Fund  offers
 the more appropriate course of action.
 NOTICE The policies set out in this fact sheet are not
 final Agency action, but are intended solely as guid-
 ance. They are not intended, nor can they be  relied
 upon, to create any rights enforceable by any party in
 litigation with the United States. EPA officials should
 follow the guidance provided in this fact sheet, or may
 act at variance with the guidance, based on an analysis
 of site-specific circumstances. The Agency also re-
 serves the right to change this guidance at any time
 without public notice.
Assessing Sites Under SACM — Interim Guidance

This paper is one of five fact sheets published by EPA
under publication number  9203.1-051 (Volume 1,
Numbers 1-5) to describe the Superfund Accelerated
Cleanup Model (SACM) and should be reviewed in
conjunction with the other SACM fact sheets. Com-
ments on this document should be directed to Janet
Grubbs of the Hazardous 
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