&EPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER: 9320.3-04
TITLE: Guidance for Proposed National Priorities List
Update S3
APPROVAL DATE: Decentoer 10, 1984
EFFECTIVE DATE: Decentoer 10, 1984
ORIGINATING OFFICE: OERR/HSCD
FINAL
D DRAFT
STATUS:
REFERENCE (other documents):
OSWER OSWER OSWER
/E DIRECTIVE DIRECTIVE D
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\ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
° WASHINGTON, D.C. 20460
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DEC i 0 ;334
OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE
\
OSWER Directive 9320.3-4
MEMORANDUM
SUBJECT: iGuldantffti£oD Proposed NPL Update #3 - February 1985
ZjSe n~* TnOujflS I •
.Assistant Administrator
TO: Regional Administrators
Regions I-X
Introduction
The Comprehensive Environmental Response, Compensation and
Liability Act of 1980 (CERCLA) requires that -the National
Priorities List (NPL) be updated at least annually. Most
recently, EPA published NPL Update #2 proposal in the Federal
Register on October 15, 1984. The next proposed update to the
NPL, Update #3, is scheduled for February 1985. The purpose of
this memorandum is to discuss the schedule and scope of the next
update.
Following the October 1984 proposal of Update #2, Regional
Superfund managers and staff met in Washington to discuss various
options for increasing the frequency of updating the NPL and
procedures to improve the process. Although a complete analysis
of the issues discussed at this meeting has not been completed,
we believe that there is sufficient demand in the Regional
programs to Justify a third proposed update to the NPL as early
as February 1985. A proposed fourth update is currently being
planned for June 1985.
Scope of Update #3
The purpose of proposed Update #3 is to allow Regions to
submit sites that were not completed in time for inclusion in the
Update #2 proposed rule in October 1984. Because of the short
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OSWhK Directive 9320.3-04
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schedule and limited Regional, Headquarters, and quality assurance
(QA) resources, we expect to have a limited number of sites (50-75
nationwide) submitted for Update #3. We expect a much larger
number of sites' to be submitted for proposed Update #4 in June of
1985.
Eligibility
In order to assure our mutual awareness of sites entered into
the QA process, we are requesting that sites (including Federal
facilities) which have passed Regional quality control (QC) be
transmitted by the Regional Division Director prior to the initia-
tion of the Headquarters QA review. Sites that have previously
been submitted for QA for earlier NPL proposals must also be resub-
raitted by the Regional Division Director. Prior to proposed rule-
making, Headquarters will provide to the Regional Division Directors
a list of sites that have passed QA and considered eligible for
proposed Update #3. This list should be reviewed by you and then
transmitted under your signiture to me.
Because of the short time frame, we will limit our considera-
tion for Update #3 to classic NPL industrial waste sites as opposed
to sites for which complex policy issues have yet to be resolved.
Such sites may be considered in following updates when more time
is available to resolve issues or develop appropriate policies
for N.PL listing.
Categories of sites that will not be considered for listing
on proposed Update #3 are RCRA sites (non-regulated units associated
with active RCRA facilities) and sites where releases occurred as
a result of the application of pesticides registered under the
Federal Insecticide, Fungicide and Rodenticlde Act (FIFRA). The
policy which permitted the listing of RCRA facilities Is currently
under review following the recent RCRA reauthorization. The Agency
intends to discuss the various options regarding the existing RCRA
sites on the NPL as well as the listing of additional RCRA sites
in a Federal Register notice and seek public comment on the various
proposals.
The proposed listing of six Hawaii pesticide sites in the
October 1984 NPL Update #2 represented a new category of sites for
Inclusion on the NPL. A1* discussed in the preamble to Update #2
(49 PR 40320, October 15, 1984), the Agency is currently seeking
public comment on the appropriateness of listing such FIFRA sites
on the NPL. Therefore, the Agency will not consider listing any
such sites for the Update #3 proposed ruleraaking.
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OSWER Directive 9320.3-04
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Schedule
Sites that have passed Regional QC review and transmitted by
the Regional Division ^Director must be submitted to Harold Snyder>
Chief, Discovery and Investigation Branch by December 31, 1984, in
order to .be eligible for QA review. Because .of the resource
requirements of responding to comments on proposed Update #2, the
QA resource for Update #3 will be limited. Regions are strongly
encouraged to submit only well prepared, completely documented
HRS packages prior to the December 31, 1984, deadline.. Sites
which fail QA and are not corrected by the Regions in time for a
second QA review, and sites submitted beyond the resources available
for QA will not be considered for Update #3- Such sites may be
resubmitted for proposed Update #4, which is currently planned
for June 1985.
December 31 - Deadline for HRS package submissions
January 27 - QA Ends. Deadline for completed HRS packages
February 3 - Regional Division Director receives list of
eligible sites
February 10 - Regional Administrator transmits memo to AA,
x| OSWER, recommending sites
February >3 - Start Agency-wide Red Border & OMB review
An HRS package will not be considered for proposed rule-
making until QA is complete, all appropriate HRS documents have
been received, and a site narrative summary has been approved by
Headquarters. In order to streamline the narrative summary
process, we recommend the following:
1) Use the attached outline for narrative summaries to
ensure that the information is complete and consistent across
all sites. If Regional staff has any questions regarding
the narrative summaries, they should contact Irene Klefer
(FTS-382-3335).
2) Commit enforcement personnel from the Office of Regional
Counsel to review each narrative to ensure that no enforcement
confidential information is included.
I believe that proposing additional sites by the end of
February 1985 will help alleviate the pressures you may now have
to propose additional sites. We can meet this goal only if we
work closely together to focus on a limited number of sites which
have high quality and complete HRS packages and stay within the
dates indicated in this memo. We appreciate your hard work on
previous NPL proposals and look forward to your assistance on
this one. If you have any questions, please contact Scott Parrish
(FTS 475-8103).
Attachments
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