vv EPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER: 9285.4-02
TITLE: GUIDANCE FOR COORDINATING ATSDR HEALTH
• _ASSESSSMENT ACTIVITIES INTO THE SUFERrUND
REMEDIAL PROCESS
APPROVAL DATE: 3/11/87
EFFECTIVE DATE: 3/11/87
ORIGINATING OFFICE:
0 FINAL
D DRAFT
STATUS:
REFERENCE (other documents):
of Solid Waste
OS WER OS WER OS WER
/£ DIRECTIVE DIRECTIVE Di
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*CPA un«eo ^SSSSfo^f^ **** ji8i~.Nw.-ir- •
ocm OSWER Directive Initiation Request 9235.4-02
. . 1. Qrlqlnalar Information
Name at Contact Person . Man Cage
n. Bennett ' OS23&
0lf!c*HSED Teieonore Caae ^K ™
idlnce for Coordinating ATSDR Health Assessment Activities with
iperfund Remedial Process
citizen petitions.
5. Keyword* Superfund.CEHCLA.SAFA
6a_ Does This Oireenve Supersede Previous Direcovets)? i i
1 |N°-
B. Ooea It Suoplement Previous Oirecnve
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9285 .4-02
GUIDANCE FOR COORDINATING ATSDR HEALTH
ASSESSSMENT ACTIVITIES INTO THE SUPERFUND
I~ REMEDIAL PROCESS
TABLE OF CONTENTS
Page Number
INTRODUCTION 1
Purpose of Document 1
Outline of Document 1
SECTION
1.0 EPA"RISK ASSESSMENTS 2
2.0 . ATSDR HEALTH ASSESSMENTS 2
3.0 EPA/ATSDR COORDINATION IN THE REMEDIAL PROCESS 2
3.1 Overview of the ATSDR Health Assessment -:
Process * -f
3.2 Prioritization of Sites 6 *
3.3 Procedures for EPA/ATSDR Coordination
(Federal/PRP-lead) 7
3.4 Procedures for EPA/ATSDR Coordination
(State-lead) 9
4.0 ATSDR ADDITIONAL SUPPORT/CONSULTATION
ACTIVITIES 9
5.0 CITIZEN PETITION FOR HEALTH ASSESSMENTS 10
5.1 Notification Process 10
5.2 Management of Petitions 11
APPENDIX
1.0 -iff* Bflo*di*l Process
2.0 *JBJfea* Health Assessment Format
3.0 JHMDK Regional Representatives
4.0 ATSOR Data Requirements for Health Assessments
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9285.4-02
INTRODUCTION
The Superfund Amendments and Reauthorization Act (SARA)
mandates that the Agency for Toxic Substances and Disease
Registry (ATSDR) perform specific public health activities
associated with actual or potential exposure to toxic
substances identified at hazardous waste sites. Although this
mandate covers a wide range of health-related activities, this
document focuses on the specific requirement that ATSDR conduct
a health assessment for each site on, or proposed for inclusion
to, the National Priorities List (NPL). (5110(6) (a)). Health
assessments are to be completed by December 10, 1988 for those
facilities proposed for inclusion prior to October 17, 1986 and
within a year of the date of proposal for those facilities
proposed for inclusion after October 17, 1986. Furthermore,
SARA directs ATSDR to consider NPL schedules and the needs of
EPA pursuant to remedial investigations and feasibility studies
(RI/FS) when determining its priorities, and to complete health
assessments "promptly" and to the "maximum extent practicable"
before completion of the RI/FS.
Purpose of Document J$
'.
The purpose of this document is to (1) provide guidance to*T
support ATSDR in meeting its health assessment requirements as
outlined in Section 110 under SARA, (2) summarize the various
EPA response activities for which consultation with ATSDR may
be requested and (3) outline ATSDR1s management process for
citizen petitions. The new health assessment requirements will
necessitate the exchange of information and data on sites
between ATSDR and EPA and will require continual coordination
to address priorities and to clarify schedules for performing
health assessments. The procedures outlined in this document
are intended to facilitate the completion of health assessments
in a timely fashion and to minimize potential delays in the
remedial process (see Appendix 1.0 for a summary of this
process). This document is intended for use by EPA Remedial
Project Managers (RPMs), ATSDR Regional Representatives (RRs)
and other parties participating in the health assessment
process.
Out1ins
sections of this document briefly describe
EPA risk assessments and ATSDR health assessments. Section 3.0
outlines the procedures for coordinating EPA's remedial
activities with ATSDR's health assessment activities and
clarifies the roles and responsibilities of each agency.
Section 4.0 summarizes those additional support activities
provided by ATSDR upon request from EPA. The last section
outlines ATSDR's management process for citizen petitions.
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9285.4-02
1.0 EPA RISK ASSESSMENTS
EPA is responsible for conducting quantitative risk
assessments (i.e., the public health evaluation and
endangerment assessment) which characterize the nature and
magnitude of potential risks to human health and the
environment from exposure to hazardous substances, pollutants
or contaminants released from specific sites. This process is
initiated during the RI and consists of an evaluation of the
nature and extent of contamination, the potential pathways of
human exposure, and a comparison of expected human exposure
levels with recommended exposure levels. The results of the
public health evaluation are reported in the feasibility study
and the analysis of remedial alternatives. EPA risk
assessments are prepared by scientists from a variety of fields
.(e.g., toxicology, hydrology, chemistry); the complexity of an
assessment depends upon site-specific factors such as the
number and type of chemicals present; the number and complexity
of exposure pathways; and the availability of appropriate
standards and/or toxicity information.
2.0 ATSDR HEALTH ASSESSMENTS J
-i
ATSDR health assessments are qualitative assessments of the
potential risks to human health posed by individual sites. The
ATSDR health assessment is performed by a multi-disciplinary
team (e.g., physicians, toxicologists, public health
specialists, etc.) and consists of reviewing environmental
sampling data and other site-related information (e.g.,
remedial investigation reports, risk assessments) available
from EPA. These data are evaluated to (1) assess whether any
current or potential health threat exists; (2) to develop
health advisories as necessary; and (3) to identify studies
needed to evaluate human health effects. The ATSDR assessment
will serve to assist EPA in determining whether immediate
actions (e.g., provision of alternate water supply, relocation
of individuals) are necessary to reduce human exposure. The
format for ATSDR health assessments is provided in Appendix 2.0.
3.0 EPA/AT8PR COORDINATION IN THE REMEDIAL PROCESS
of this section is to outline the health
assessastocess and discuss the procedures by which ATSDR
will obtWuTth* necessary information to complete health
assessments for HPL sites. Under these procedures, ATSDR is to
review information and participate in technical project
briefings at specified points in the RI/FS procese (Figure 1).
ATSDR has assigned personnel to each of the ten EPA Regional
Offices to facilitate interaction with EPA. (See Appendix 3.0
for a listing of the current assignees and telephone numbers.)
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FIGURE 1
ATSDR/EPA INTERFACE
EPA RI/FS ACTIVITIES
SITE DISCOVERY
SITE INSPECTION
i.
PROPOSAL TO NPL
i
>
ASSIGN PRIORITY
FOR RI/FS
1
FEASJBOJTe
STUDY m
• 1
<
REMEDIAL
INVESTIGATION
.t
•"*.'•
i. x-
1^. »
r — .
>
RI/FS PUBLIC MEETING
ROD SIGNATURE
ATSDR HEALTH ASSESSMENT
ACTIVITIES
PA/SI
REPORT
ATSDR REVIEW
1
SITE VISIT
AS APPROPRIATE
I
HEALTH ASSESSMENT
BASED ON AVAILABLE INFO.
IDENTIFY SPECIAL DATA
NEEDS AND DISCUSS
SAMPLING STRATEGY
DRAFT Rl REPORT
ATSDR REVIEW
ISSUE HEALTH ASSESSMENT
ATSDR PARTICIPATION
AS APPROPRIATE
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9235.4-02
3.1 Overview of the Health Assessment Process
In determining the priority in which to conduct health
assessments, SARA directs ATSDR, in consultation with EPA, to
give priority to those facilities at which there is documented
evidence- of the release of hazardous substances and where the
potential risk to human health appears highest. Furthermore,
Congress has directed ATSDR to complete health assessments
promptly, and to the maximum extent practicable, before
completion of the RI/FS, and to consider NPL schedules and EPA
needs pursuant to RI/FS schedules.
Because of the need to consider the congressionally
mandated schedules for completing health assessments and EPA
remediation schedules, the first task in the process will be to
establish priorities among sites. This prioritization process
consists of two concurrent acivities: (1) an ATSOR review of
all NPL sites to identify those that have no prior ATSOR
review/recommendation; and (2) EPA orderly submission of sites
to ATSDR based on EPA remediation schedules (discussed in the
following section). EPA and ATSDR will work together to
establish priorities for all sites. Sites posing an imminent
health threat (i.e., evidence of significant acute or chronic^
exposure presently occurring) will receive the highest 'I
priority. Sites not posing an imminent health threat will be
prioritized according to EPA remediation schedules.
Due to the scheduling requirements for completing health
assessments (refer to Table 1.0) and the number of sites in the
various stages of the remedial process, there will be varying
amounts of data available for specific sites on which to base
the health assessment. For sites where only preliminary
assessment (PA) and site inspection (SI) data are available, a
subsequent assessment may be performed once the remedial
investigation report is completed. Therefore, coordination
between the RR and RPM will be needed to assure that data and
information are provided at appropriate times and arrangements
made to procure and transmit new information when necessary.
Due to the large number of sites presently on the NPL and
the short.time frame allotted to complete health assessments,
the statna^ of health assessments will be tracked and updated
through CBKLIS, a national database that contains information
on all pdOBtial hazardous waste sites including information on
Superfund removal, remedial, and enforcement activities. These
updates are intended to serve both a managerial and tracking
function and to assure that health assessments are completed in
a timely fashion while avoiding unnecessary delays in the
remedial process. Updates to CERCLIS should indicate
specifically whether a health assessment has been completed or
whether additional data/information is needed. The RPM and RR
will coordinate and track the statue of ATSDR data requests.
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9285 . 4-02.,
Table 1
INITIAL ATSDR HEALTH ASSESSMENT DEADLINES
•
NPL PROPOSAL ATSDR HEALTH
DATE ASSESSMENT DEADLINE
Update 6 - January 1987 January 1988
Update 7 • September 1987 (planned) September 1988
NPL Sites Proposed prior December 1988
to October 17,1986
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3235.4-02
3.2 Prioritization of Sites
The prioritization approach presented below reflects EPA's
desire to have health assessments completed at sites prior to
the signing of RODs and to assure that all health concerns are
adequately addressed prior to initiating last operable unit
response actions. Although this approach should be followed to
the extent practicable, sites posing an imminent health threat
(i.e., evidence of significant acute or chronic exposure
presently occurring), regardless of their stage in the remedial
process, constitute the highest priority and therefore, would
require a more expeditious response. The priorities are as
follows:
First Ongoing Projects — includes those projects which
Priority have an approved workplan and the RI/FS is currently
underway or has been completed:
(a) ROD or FS expected within 3-6 months
(b) RD/RA stage (only if last operable unit)
(c) On-going RI/FS '.".
(d) RD/RA stage (other than last operable unit).
Second New Start Projects — includes those projects which
Priority have not yet begun and/or do not have a finalized
workplan:
(a) New RI/FS
(b) No RI/FS (i.e., may not be initiated within the time
frame requirement for health assessment).
Third Completed Projects — includes those projects where
Priority all response actions have been completed other than a
long-term response (e.g., 20-year ground water
pumping and treatment) and those sites eligible for
deletion:
leted sites eligible for deletion
,g-term response actions (LTRAs)
Deleted sites.
NPL sites should be prioritized in each upcoming quarter by
the appropriate RPMs, their Branch Chiefs, and the RR. The RR
will then transmit the priority list to ATSDR's office of
Health Assessment for a comparison of priorities among all
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9285.4-02
Regional submissions. Once sites posing an imminent health
threat have been identified, the remaining sites will be ranked
according to EPA remediation schedules. Because actual
exposure situations are rarely documented upfront, most health
assessment priorities will likely be established by remediation
schedules.
3.3 Procedures for EPA/ATSDR Coordination (Federal/PRP-lead)
Mechanisms by which ATSDR may interface with the process
may vary depending on which organization (EPA, State, PRP, or
COE) has lead responsibility for the RI/FS. The primary
participants in the coordination process are the ATSOR RR and
the EPA RPM. The RPM is the prime coordinator for projects and
is responsible for arranging the transfer of information and
identifying appropriate contacts in other agencies. The RRs
serve as liaisons between ATSDR and EPA and are the principal
contact on all ATSDR-related matters.
Because the procedures for addressing a new-start Federal-
lead RI/FS offer the most complete scenario and serve as a
model applicable to most other situations, they will be X
discussed first. .-.
New Start Projects — The appropriate EPA Regional Branch Chief
will supply the ATSDR RR with copies of the integrated
Superfund Comprehensive Accomplishments Plan (SCAP) on a
quarterly basis consistent with the Regional quarterly update.
RRs will be responsible for contacting the appropriate EPA RPMs
to obtain information on those projects that have been selected
for ATSDR action (based upon the prioritization process
described in section 3.2).
ATSDR has previously identified the general types of data
that will be needed to complete health assessments (see
Appendix 4.0). These data should be adequate for the majority
of sites investigated/ however, both agencies recognize that
some sites will require additional data beyond that described
in Appendix 4.0. It is important that ATSDR identify such
sites and the nature of any additional data required, as early
in the proc««» as possible. Therefore the RPM should supply
the RR wit%.atcopy of the SI report and the Hazard Ranking
System iaBtepation for all sites proposed for inclusion to the
NFL. Thc^Kvill then be responsible for notifying the RPM of
any special data requirements anticipated after reviewing the
SI report. This notification should be accomplished by
memorandum in a timely manner following receipt of the SI
report so the appropriate administrative procedures can be
implemented to obtain contract assistance. The memorandum
should address the nature of the data required as well as the
rationale for justifying the collection of these additional
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9285.4-02
data; for'potential responsible party lead sites, the
additional data would be collected by the PRPs and the RPM
would serve as the coordinator between ATSDR and the PRPs.
Through discussions with the RPM, any additional contractor
efforts to address these needs should be identified and
categorized as a separate task within the RI/FS work
assignment. This will allow EPA to identify contract resources
expended at the request of ATSDR that are not typically
collected in an RI/FS effort. The RPM will manage all
contractor efforts and supply the RR with copies of sampling
and work plans.for informational purposes.
The RPM will issue a copy of the draft RI (when available)
to the RR for use in the development of the health assessment.
To the extent that they are available at this time/ EPA will
also provide to ATSDR copies of any site-related risk
assessment documents for their use in developing a health
assessment. Following review of the RI, a discussion meeting
should be held between the RPM and the RR to raise any issues
regarding the site.
When feasible and appropriate, the RR will participate in *
the pre-FS meeting which will cover initial sampling results;'"
proposed remedies to be considered in the FS, and strategies
for addressing site remediation. (In the cases where a RI/FS
is being conducted by a PRP or Federal agency, the RPM will
coordinate meetings.) These discussions will focus on those
operable units comprising the final remedy and plans for their
implementation. This meeting provides a forum for raising any
additional issues or concerns associated with the project and
serves as a planning session to update timeframes for future
project milestones (including ATSDR schedules for preparing
health assessments). Health assessments are to be completed by
ATSDR, to the maximum extent practicable, prior to the release
of the RI/FS for public comment.
Ongoing Projects — To ensure that ATSDR is informed of all
current RI/FS efforts and projected ROD signatures for that
year, EPA. Branch- Chiefs will provide RRs with a list of all
ongoing OMdial projects with estimated completion dates
(final jj^Kf*0**? > • Subsequent to receiving this project
list, tl^^KllllX notify appropriate RPMs (in conjunction with
the BraMHSl«£}L;|o identify and prioritize projects for
health atf*l«bMB*«v. Depending upon the stage of the project,
an appropriate schedule for supplying required documents should
be arranged between the RPM and the RR. Although health
assessments should be completed prior to completion of the
RI/FS, in some situations this will not be possible. In such
cases EPA and ATSDR should discuss preliminary findings of the
health assessment prior to ROD signature. Health assessments
are desirable as early as possible and should precede* the
initial ROD whenever possible. However, the ROD should not
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9285.4-02"
be delayed solely because the health assessment is not
complete. RODs for limited site actions (e.g., alternate water
supply) may be signed prior to obtaining the health assessment.
If additional data needs are identified by ATSDR, the RPM
should issue a work assignment amendment to incorporate the
required contractor efforts. This amendment will constitute a
separate work task. PRP-lead RI/FSs should be addressed as
discussed for newstart projects. . In addition, ATSOR will
coordinate with the RPM so that qualified persons are hired to
supplement ATSDR for oversight of PR? activities.
Completed Projects — Because ATSDR must complete health
assessments for all NPL sites by December 10, 1988, Regional
Branch Chiefs are to assemble the appropriate documentation for
all completed projects and make it available to the RR in a
timely manner. The appropriate Regional staff person to serve
as a contact for each respective project should be identified.
3.4 Procedures for EPA/ATSDR Coordination (State-lead)
State-lead projects are administered under different
procedures than Federal-Lead projects, however, the same '
priority approach discussed earlier will be followed. The RPBC';
will serve as the liaison and will arrange for the RR to work 7
with their State agency counterparts. The State will supply
all necessary information to the RPM and the ATSDR RR. The RPM
will be advised on the progress of health assessments, and
notified in the event that additional data are needed. Where
contractor support is needed to collect additional data, the
State must submit budget and scope amendments to EPA for the
cooperative agreement. The RPM and the State will establish
procedures for State-lead enforcement sites on a site-by-site
basis.
4.0 ATSDR ADDITIONAL SUPPORT/CONSULTATION ACTIVITIES
In addition to the health assessments required by SARA,
ATSDR assessments and consultation may be requested for a
variety of other remedial-related activities. Other types of
consultation* that nay be requested of ATSDR include, but are
not liiiiiqjfr te, the following:
ev and comment on remedial and removal
alternatives. This doe* not include selection of the
remedial action (an EPA risk management decision) but
can include a review of such action to ensure it
adequately addresses public health concerns.
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9285.4-02
Review and comment on various documents or papers
(e.g., risk assessments, health reports, etc.),
prepared by EPA or other involved parties.
Review and comment on worker health issues. ATSDR,
with technical assistance from the National Institute
for Occupational Safety and Health (NIOSH), may
review site safety plans or address additional
concerns such as evaluation criteria.
ATSDR consultation concerning these EPA response-related
activities may be requested by Regions in separate memoranda.
Because ATSDR responses relevant to selection of response
action will become part of the Administrative Record, memoranda
should state clearly the type and extent of review that is
desired and the time frame in which the response is needed.
These requests should be made through the ATSDR RR.
5.0 CITIZEN PETITION FOR HEALTH ASSESSMENTS
SARA permits a private citizen to petition ATSDR to perform
a health assessment of a site or an incident. A complete i
health assessment may not be necessary to address the citizen>V
concerns/ i.e./ an ATSDR health consultation may be sufficiehtf-
to answer the inquiry. It must also be anticipated/ however/
that sufficient environmental data may not be currently
available to provide either a consultation or to perform a
health assessment.
The procedures for petitioning ATSDR and the process for
responding to petitions will be developed by ATSDR as Federal
regulations and promulgated in the Federal Register. This
section provides an overview of the process which may be
subject to change as the regulations are developed.
5.1 Notification Process
ATSDR's policy is to require petitioners for a health
assessment to do so in writing to the Associate Administrator
of ATSDR. It is likely that petitioners who are not aware of
the formal petitioning procedure may contact the Regional
Office*. -^Tbe ATSDR RRs will inform the petitioner to submit
their rerffert'for « health assessment in writing to the
AssociatJI*teinistrator of ATSDR.
Citizen inquiries for assistance and/or information may be
addressed at the regional level by the ATSDR RR. If such
inquiries evolve into a formal petition for a health assessment
the petitioner will be advised to submit their petition in
writing to the Associate Administrator of ATSDR. Citizens with
health concerns who contact the RPMs should be referred to the
RR.
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9233.. 4-02
5.2. Management of Petitions
Based upon a review of the citizen petition, and any
accompanying data, as well as current ATSDR priorities and
activities, ATSDR will determine whether 1) a health assessment
is warranted at the particular site; or 2) the petition can be
addressed through some ATSDR activity other than a health
assessment; or 3) additional information is required to
determine whether a health assessment is warranted. If ATSDR
determines that a health assessment is not warranted, it will
notify the petitioner of this fact in writing. Should ATSDR
determine that additional information is required to decide
whether a health assessment is warranted, it will notify in
writing the petitioner and seek the additional data from other
sources.
If ATSDR decides to conduct a health assessment, it will
notify the petitioner and will request data relevant to the
site in question from the petitioner, EPA, state or local
agencies, or other appropriate parties. In the event that the
data necessary to perform a health assessment is not available
from other sources, ATSDR may arrange for sampling or
additional data gathering at a site for the sole purpose of
determining the existence of current or potential health
problems at the site. Handling of all additional data
requirements will be coordinated by ATSDR's RR (on NPL sites
ATSDR's RR will coordinate with the RPM).
If additional environmental sampling is required and/or a
full health assessment is warranted, the citizen's petition may
not be completely addressed for several months; ATSDR will
respond to the citizen in writing/ notifying the citizen of
what course of action will be followed and when a full response
to their request may be anticipated. Other consultation and
advice will be provided that could help alleviate their
concerns. If ATSDR concludes that a health problem does exist
at a site or incident.(i.e., actual exposure and/or health
effects have been documented), ATSDR will advise the citizen in
writing about other public health actions if any are
appropriate.
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9285.4-02
APPENDICES
/
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9285.4-02
APPENDIX 1.0
OVERVIEW OF THE REMEDIAL RESPONSE PROCESS
The National Contingency Plan (NCP), the "blueprint" for
implementing the Superfund program under CERCLA, defines two
specific types of action to respond to releases of hazardous
substances.
(1) Removal Action - prompt response to prevent or mitigate
harm to human health or the environment. Removals usually
must be completed in twelve months or after expenditure of
$2 million.
(2) Remedial Response - generally involves a more extensive
response than removals with additional outlays of time and
money and is intended to achieve a permanent solution to
the maximum extent practicable.
Removal actions will, by definition, be accomplished within
a short time frame. The remedial response process, however, -is
more extensive and involves a series of steps. Each of the '-.-
steps in the process is briefly described below. * -
Site Identification
Hazardous waste sites are generally identified in one of
two ways. Sites come to EPA's attention following the report
of a release. These reports may be directed to the National
Response Center or the Emergency and Remedial Response
Information System which maintains a current listing of those
facilities at which hazardous wastes are located. Sites may
also be identified as part of ongoing State or Federal
hazardous waste site discovery programs.
Site Evaluation
Once a site has been identified, a preliminary assessment
is performed to determine the extent of potential release.
This preliminary assessment includes the collection and review.
of all arMEiltble information regarding the source and nature of
the hassjlpui"substances present. A site inspection, is then
performaJFiBfctfL includes sampling, surveying, monitoring and
other field activities required to characterize the problem.
Data gathered during the site evaluation serves as the basis
for the ranking of sites on the NPL.
Initial Planning
The information generated through the site evaluation
process is reviewed during the initial planning phase to
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9285.4-02
determine the scope of prospective remedial activities. The
decision as to who will"take the lead (?RP, State or EPA) for
the remedial investigation and feasibility study (RI/FS) is
made at this stage.
Remedial Investigation (RI)
The purpose of the RI is to collect and analyze those data
necessary to define the nature and extent of threats to human
health and the environment, and to support development and
evaluation of alternatives in the feasibility study. During
this phase of the process, the initial scope may be revised as
additional information is gathered. Typical RI activities
include: waste analysis and development of profiles,
hydrogeologic investigations, surface/ground water analyses and
air monitoring.
EPA's public health assessment and risk assessment are
usually initiated during the RI stage. These quantitative
evaluations of the potential health threats posed by specific
sites are utilized by decision-makers in the final selection of
an alternative and to guide them in making risk-management
decisions. ..'
»
Feasibility Study (FS)
The purpose of the FS is to identify and assess those
remedial alternatives that would be appropriate for application
at a site. Typically an FS involves several steps:
development of alternatives, initial screening of alternatives
(based on health/environmental, technical feasibility, and cost
impacts), detailed analyses of remaining alternatives,
recommendation of an alternative and development of a
preliminary conceptual design.
Remedy Selection
In selecting remedial alternatives, EPA must consider which
remedies are protective of human health and the environment,
cost effective, and utilize permanent solutions and alternative
technologies to the maximum extent practicable. Remedies must
also mneftf^ppplicable or relevant and appropriate Federal and
State stdHpid*.. Once all requirements are satisfied, a Record
of DecisJwMBQ&Jt is signed to formalize the remedy selection
process.
Remedial Design/Remedial Action
The last step in the process is to clearly define the
selected remedy and outline the necessary plans and
specifications in a bid package (remedial design). After the
award of a contract, construction activities necessary to
implement the selected remedy begin (remedial action).
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9235.4-22
Completion/Deletion
fcu 2££e a11 of ^he re<5uired response actions as described in
the ROD are completed, a site may be classified as a coraDlet^on
(i.e., receives a "C" cleanup status on the NPL). Completed"
sites undergo a technical evaluation to assure they satisfy the
necessary deletion criteria as delineated in the NCP and
related guidance before they are deleted from the NPL.
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9285.4-02
APPENDIX 2.0
ATSDR HEALTH ASSESSMENT FORMAT
Depending on the individual sites, and the extensiveness of
the material being reviewed, and the report prepared, the
actual health assessment may or may not contain the formal
sections presented below, but will usually cover material which
would be appropriate in each section.
I. Executive Summary: A one paragraph summary of the
report should be provided if the report exceeds
several pages.
II. Statement of the Problem
A. Questions asked by EPA.
B. Background and history of.the project.
III. List of Documents Reviewed
IV. .List of Principal Contaminants
V. Environmental Pathways -_Z
• *
VI. Human Exposure Pathways
VII. Health Evaluation (Include information on human
complaints.)
VIII. Health Effects (lexicological information on the
principal contaminants. Include this if it is a
specific guestion. Otherwise, put it in the
discussion.)
IX. Discussion of the Presence of a Health Hazard
A. Imminent
B. Chronic.
C. Potential
X. Conclusions
XI. jMEpbendfations (In numbered, "bullet" format.)
for immediate action
.for long-term action
>nal data needs
XII. References
XIII. Attachments (Optional)
XIV. Signature Block
A. Office Director
B. Copy to 6. Buynoski and H. Longest
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9285.4-02
APPENDIX 3.0
ATSDR Field Office Public Health Advisors
Ms. Marilyn DiSirio
EPA Superfund Office
Region I - Room 1903
Waste Management Division
John F. Kennedy Building
Boston, MA 02203
FTS 835-3639
Comm. (617) 565-3639
Tues. & Thurs. -
Lexington, MA (617) 861-6700
Mr. William Q. Nelson (Bill) Nelson
Emergency & Remedial Response
EPA Region II/ Room 737
26 Federal Plaza
New York, New York 10007
FTS 264-8676
Comm. (212) 264-8676
Tues. - Edison, NY FTS 340-6657/8
Mr. Charles J. (Bucky) Walters
EPA Superfund Office
Region III
841 Chestnut Street
Philadelphia, PA 19107
FTS 597-7291
Comm. (215) 597-7291
Mr. Casimer V. (Chuck) Pietrosewicz
Air & Waste Management Division
EPA Region IV
345 Court land Street, HE
Atlanta, GA
FTS 257-3931
Comm. (404)
Ms. Louise A. Fabinski
Emergency & Remedial Branch (5HR)
EPA Region V
230 South Dearborn
Chicago, IL 60604
FTS 886-0398
Comm. (312) 886-0398
Mr. Carl R. Hickam
Region VI
1201 Elm Street
Dallas, TX 75270
FTS 729-9872
Comm. (214) 767-9872
Mr. Edward J. (Ed) Skowronski
Waste Management Branch
EPA Region VII
726 Minnesota Avenue
Kansas City, KS 66101
FTS 757-2856
Comm. (913) 236-2856
Mr. Michael A. (Mike) McGeehin
Waste Management Division
EPA Region VIII, Suite 1300
999 18th Street
Denver, CO 80202-2413
FTS 564-1526
Comm. (303) 293-1526
Mr. Donald W. (Don) Hawkins*
Toxics & Waste Management Division
EPA Region. IX
215 Fremont Street
San Francisco, CA 94105
FTS 454-7742
Comm. (415) 974-7742
Mr. Joel D. Mulder
Hazardous Waste
EPA Region X (M/S 525)
1200 6th Avenue
Seattle, WA 98101
FTS 399-2711
Comm. (206) 442-2711
•Address mail to: P.O. Box 2453, Daly City, CA 94017
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Relationship to Nearby Community
Activities on the site (estimated number of people involved
in each activity)
^ Records of environmental and health complaints by public
about sites
Estimated frequency of activities on-site (e.g., dirt
biking, camping, hunting, fishing, etc.)
Log of actions taken by State/county health unit at/near
site regarding health issues, concerns, complaints, etc.
Data on Environmental Pathways
Ground water
Geologic Profile
Map of water table contours and monitoring wells, if
any
Map showing locations and uses of wells within 2 miles
of site
Map showing locations and uses of wells within 2 miles
of site (within +/- 60 degrees of ground water
direction if flow direction is constant)
Approximate number of users as source of potable water
Average net rainfall and evaporation rate
Hydraulic conductivity of saturated zone (estimated or
measured)
Sampling data and description of sampling survey with
summary table
Locations of contaminated monitoring wells
Contaminant concentrations over time
Surface Water
Indication on site map of 100 year flood plain
Stream classifications and water uses downstream from
site
Sampling data and description of sampling strategy
with summary table
Soil and Sediment
Sampling data and description of sampling strategy
with summary table
Ait
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Site History
Dates of operation and significant events
Description of prior release and actions taken by EPA to
remedy
Description of physical barriers to prevent pollutant
transport (i.e-., liners, slurry, walls, fences, dikes)
Current CERCLA/RCRA status of site
Information on oruality control/crualitv assurance
Data Review Summary prepared by EPA Regional staff. This
documents the validation of sample holding times,
instrument, performance, calibration, blanks, surrogate
recovery, matrix spike recovery, and compound
identification. It includes documentation of actions taken
to resolve data quality problems and an overall case
assessment.
For non-CLP data, equivalent information should be provided
(see Guidelines for Providing Laboratory Data and Qualitym
Control Information, CEH, CDC)
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