-------
.,. --a ?v
** ^ • UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, O.C. 20460
DEC 2 8 1987
Of
SOLID WASTE ANO EMERGENCY RESPONSE
MEMORANDUM
OSWER DIRECTIVE 9355.0-24
UBRAR* U.S.
SUBJECT: OSWER Strategy for Management Oversight of the CERCLA
Remedial Actixjftx£tart Mandate
/ . / '~77f~
/^—, J ^&*i
FROM: J. Winston Porter
Assistant Administrator
TO: Regional Administrators
Regions I-X
This memorandum establishes a process for managing EPA's
efforts to achieve the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA) SllS'e) statutory man-
date for remedial action starts. It also establishes a process
for setting expectations as to each Region's contribution toward
this end, and providing guidance to enhance JPA's ability to meet
these requirements. The attached OSWER strategy document con-
tains the detailed information for this program.
Section 116(e) of CERCLA requires that we ensure that
substantial and continuous on-site remedial action commences at
facilities on the National Priorities List. Our mandate is to
begin 175 first start remedial action projects by October 16, 1989,
and an additional 200 first start remedial action projects by
October 16, 1991. Specifics as to which projects will qualify
against the mandate are provided in the strategy document.
One challenge presented to us by this statutory directive
is to both begin new remedial action (RA) starts and proceed
with subsequent operable unit starts at sites where RAs began
prior to the Superfund Amendments and Reauthorization Act of
1986.(SARA). In most instances the subsequent starts will not
count towards the RA goal, but we must balance the need to con-
duct work at the most serious environmental and health threat-
tening sites with the need to meet the "175" figure.
-------
9355.0-24
(2)
The Agency will have to take aggressive action to ensure '
that the mandate- is met. We will have to effectively plan and
manage projects to avoid, or at least minimize, project slippage.
I am committed to provide Headquarters support to help with
project planning and problem solving so that schedules can be
met.
We have examined our performance since SARA was passed as
well as the FY'88 targets and FY'89 planning projections and
believe that the "175" figure can be achieved, but we have little
margin for project slippage. We must keep the remedial pipeline
moving smoothly in order to initiate RAs on schedule. For example,
ROOs will have to be signed by the second quarter of FY'88 in
order for the RD to be completed in time to start the RA by
October 16, 1989.
In order to monitor our progress towards achieving the di-
rective of 175 RA starts/ Headquarters is developing a management
plan (see the attached strategy) to help the Regions to closely
track projects and anticipate/ identify/ and resolve issues
that may cause delays.
A key element in our strategy is a review of the "175"
candidate list of Fund and enforcement-lead sites by each Region.
This review is to be completed by the Regions by January 23,
1938, *od submitted to Paul Nadeau, Acting director of the Ha-
zardous Site Control Division/ OCRR/ (WH-54b£).
Your attention to this initiative is essential for the
Agency to meet the statutory mandate. I look forward to working
closely with each of your Regions in order to facilitate imple-
mentation of this strategy. Should you or your staff have any
questions or comments/ please contact Hal Snyder of OCRR at
475-6707 or Mike Kilpatrick of OWPE at 382-4819.
Attachment
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OSWER DIRECTIVE 9355.0-24
OSWER STRATEGY FOR MANAGEMENT OVERSIGHT OF THE CERCLA
REMEDIAL ACTION START MANDATE
I. PURPOSE
OSWER developed this strategy for managing EPA's efforts to
achieve the Comprehensive Environmental Response/ Compensation
and Liability Act (CERCLA) 5116(e) statutory mandate for reme-
dial action starts. This strategy establishes expectations as
to each Region's contribution toward this end, and provides
guidance to enhance EPA's ability to meet these requirements.
II. BACKGROUND
Section 116(e) of CERCLA, which was enacted as part of the
Superfund Amendments and Reauthorization Act (SARA) of 1986, re-
quires the following:
The President shall ensure that substantial and continuous physical
onsite remedial action commences at facilities on the National
Priorities List (NPL), in addition to those facilities on which
remedial action has commenced prior to the date of enactment of
SARA, at a rate not fewer than:
(1) 175 facilities during the first 36-Ti-,nth period after enactment
of SARA (by Oct. 16, 1989); and
(2) 200 additional facilities during the 'following 24 months
after such 36-month period (by Oct. .5, 1991).
EPA has interpreted key elements of the SARA requirement as follows:
0 Substantial and continuous - the remedial action represents
an operable unit of the remedy leading to final cleanup and
deletion of the site from the NPL. (These actions may include
remedies at sites where removal authority is used to complete
the remedial action leading to deletion from the NPL.)
0 Commencement of physical on-site remedial action - the remedial
action (RA) commences on the date when the managing 'agency
(i.e., EPA, US Army Corps of Engineers, State) awards the
construction contract for the operable unit or the potentially
responsible party (PRP) has taken action equivalent to EPA
contract award or taken equivalent action with their own work
force.
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9355.0-24 .
* In addition to those facilities on which some remedial action
has commenced prior to the enactment of SARA - the remedial
actions to be applied toward the "175" figure w.ill be
SPMS first start projects commencing after the enactment of
SARA.
A preliminary evaluation of FY '87 performance, FY '88 SPMS
targets, and FY '89 projections indicates that it is possible to
achieve the mandate. The following chart indicates where we stand:
Fund-lead PRP-lead
FY87 RA Starts: 25 15
FY88 SPMS Targets 49 24
FY89 Projected 53 35
Total .127 74 .
Grand Total 201
The statutory definition of an RA start (i.e., construction
contract award) differs from EPA's budget (SPMS) definition
(i.e., obligation of funds) b/ about 2-3 months. Therefore, you
should understand that achieving FY'89 expectations may be sig-
nificantly affected unless projects can be started sufficiently
early in the fiscal year to compensate for fJie difference in
definitions.
III. MANAGEMENT PLAN FOR MEETING THE MANDATE
A key element in being able to meet the statutory mandate
will be an effective management plan shared by both Headquarters
and the Regions. This plan will help tracking of projects and
identifying and resolving problems and issues that might cause
project delays.
The Agency will use the current SCAP/SPMS accountability
system to track projects and focus attention on the early portions
of project schedules. By focusing on the early' portions of projects,
site managers will be able to identify projects that could slip and
arrange for appropriate assistance to keep projects on schedule.
OERR has developed example SCAP planning schedules for RDs
(attachment A) and these schedules indicate that RODs should be
signed by the second quarter of FY'88 in order to allow sufficient
time to complete the RD and begin the RA in time to meet the
statutory timeframe. Two of the most critical elements of the
schedule are timely completion of the PRP negotiation moratorium
prior to commencing design and the RA procurement process. These
procurements must occur on a tight schedule, but should be
procedurally correct in order to avoid bid protests which would
cause the project to.miss the "175 Program" mandate.
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9355.0-24 .
A. Determining the Candidate Sites
The first phase of the management plan is to identify
candidate "sites to be" applied toward the "175" figure. Our
immediate- goal during the next several weeks will be to work
with the Regions to accurately determine the number of likely
projects.
Headquarters examined the SCAP/CERCLIS data base (includes
negotiated SPMS RD and RA targets for FY'88 and preliminary
expectations for FY'89) and identified the universe of sites
that could potentially satisfy the SARA "175" mandate using the
following criteria: 1) all sites currently showing an RA start
in the fourth quarter of FY'89 or before on the SCAP; 2) all
sites that have RODs by second quarter of FY'88 but have no RA
start dates (predominantly Federal enforcement-(FE) and respon-
sible party-(RP) lead); and 3) all sites with RODs through the
second quarter of FY'88 but with no RA start dates scheduled
until the first or second quarter of FY'90. The universe also
included Federal facilities and state enforcement-lead actions.
A candidate list has been developed considering the above
criteria (Attachment B) and the list shows both the total number
of RA starts expected from the Region and the maximum number
from this total that will likely be Fund-financed. The numbers
show the need for EPA to have a successful settlement and enforce-
ment program.
The next step will be for each Region to review and/ if
appropriate/ add or drop sites from the dra:w. candidate list.
Regions should also identify first quarter :Y'90 RA starts that
could be potential candidates. In addition, if Regions propose
to drop sites from the candidate list/ please provide an ex-
planation. For each Fund-financed candidate for FY'88, FY'89/
and beyond/ you should indicate the likelihood that a PRP will
assume responsibility for the cleanup. This review is to be
accomplished and returned to Paul Nadeau, Acting Director/
Hazardous Site Control Division (WH-548E) in Headquarters by
January 23, 1988.
Based upon this information, Headquarters will then revise
FY'89 Regional expectations by identifying each Region's minimum
contribution to the "175" figure. We will identify those sites
where po«t-SARA RAs have already occurred along with the aaximum
number of Fund-financed RAs and minimum number of RP-lead
RAs expected for FY'88. This will tell us how many RAs we will
have to start in FY'89, and then we can proportionally assign
Regional commitments.
Both Regions and Headquarters should rely on the CERCLIS
Data Base to track each project after convergence of the other
data systems is completed. The OECM docket will also be used to
track enforcement cases and Consent Decrees. The OECM docket
may require modification by including SSID numbers in order to
facilitate tracking.
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9355.0-24 .
B. Develop Site-Specific Schedules and Action Plans
The ••cond phase of the management plan will be to develop
schedule* and action plans for the candidate sites.
As mentioned earlier, OERR is currently developing example
design schedules based upon our design experience to date with a
variety of remedial alternatives. These schedules can assist
Regional Project Managers in preparing accurate site-specific
schedules. Hopefully/ new program initiatives, such as the
project management approach/ will allow us to adopt shorter
schedules for our new projects.
We expect the Regions to develop detailed site-specific
schedules and action plans for each site very soon. For Fund-
lead sites/ project schedules should include all key milestones
leading to construction contract award. Action plans should
describe the project delivery approach (Corps/ State/ etc); define
operable unit strategies; identify potential issues that could
impact the project schedule (State cost share; site access;
requirement for treatability testing during the RD; etc); and
assign responsibilities for resolving the issues. The Corps of
Engineers should be involved in setting schedules for projects
for which they will be responsible. Headquarters (Fund and
Enforcement) staff will visit the Regions to review the schedules
and provide appropriate assistance. These visits should commence
in January 1988 and hopefully involve both Regional staff and
section chiefs.
In addition/ these Regional visits will provide the first
opportunity to identify major policy issues or other site-specific
issues that may require assistance or resolution by Headquarters.
Based upon the site-specific schedules that are developed during
the visits/ you may need to use fast track analysis to accele-
rate projects that could fall outside the "175" window.
C. Tracking Progress and Providing Technical Assistance
The third phase of the management plan will be to track
progress in the quarterly reports showing planned and actual
dates for each of the candidate sites. These will be developed
from CERCLIS. Along with these basic site completion schedules/
exception reports will be generated showing any projects where
schedules have slipped/ and any projects where planned or actual
dates are beyond the dates for achieving timely RA starts. This
report will form the basis for an OSWER management and Regional
management quarterly progress briefing on each site.
IV. PROGRAM INITIATIVES 70 ENHANCE PERFORMANCE AGAINST THE MANDATE
OERR and OWPE are currently working on several initiatives
that will enhance our ability to minimize project slippage and
meet our mandate.
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9355.0-24
A. Fund-Lead Projects
OERR ifl currently negotiating RD and RA workloads with the
U.S. Army Corps of Engineers (USAGE) and Bureau of Reclamation
(BUREC). The negotiations will focus on the projected workload,
the role of these agencies in the Superfund program, the need for
close working relationships with the Regions, and faster contracting
procedures for assigned ROs and RAs.
In addition, OERR is currently implementing an Alternative
Remedial Contracts Strategy (ARCS) to provide each Region with
more and diverse contractor capability to perform RI/FSs, RDs,
construction management, and selected RAs.
OERR is also considering a construction management support
program to provide comprehensive program and project support for
the planning and execution of RDs and RAs by making available a
construction management specialist in the Region that might come
from the REM/ARCS contractors, BUREC/ or USAGE.
Furthermore, OERR will conduct an analysis that will enable
us to identify and resolve major issues inherent to the Fund
program such as state cost assurances, disposal capacity, property
acquisition, and 0 & M. This review would also include the poten-
tial for phased funding in order to allow for more initial starts,
the implications of the land disposal restrictions beginning in
November 1988, and RD/RA contracting procedures.
B. Enforcement-Lead Projects
OWPE intends to work with the Regions t5 set higher settlement
expectations for FY'88 in order to increase the universe of sites
where RAs will begin. The settlement process itself will also
be expedited, where possible, and issues resolved, where necessary.
Discussions with OECM and DOJ management are underway on this
subject. All phases of the negotiation process are presently
being examined and proposals being evaluated to improve the over-
all efficiency. Some specific initiatives are detailed below.
For pre-negotiation activities, Regions are encouraged
to continue to send general notice letters early to allow better
coalescing of PRPs. Headquarters will also be developing a Model
Consent Decree in order to expedite discussions on legal "boiler
plate".
Special Notice guidance is completed and emphasizes moratorium
imposition when the feasibility study and proposed plan are
released for public comment to ensure minimum delay in implementing
projects once the ROD is signed. Headquarters will also be
tracking negotiations to ensure that extensions are provided
consistent with the February 12, 1987, guidance on "Streamlining
the CERCLA Settlement Process".
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9355.0-24
Other discussions with DOJ and OECM are addressing
post-settlement -activities and focus on DOJ accountability,
ensuring timely lodging of settlement. Other discussion topics
include: pre-negotiation subraittals, and requiring PRPs to
initate RO at the time the consent decree is lodged. OWPE and
OECM are preparing guidance on these topics. In addition, OWPE
encourages the use of motions for summary judgment, and preli-
minary injunctions as appropriate.
Finally, OWPE and OERR are working with others in the
Agency to develop a streamlined decision process by which a
conditional remedy might be selected. For certain, appropriate
cases this should permit earlier starts on the remedial action.
V. RECOMMENDED REGIONAL INITIATIVES TO ENHANCE PERFORMANCE
AGAINST THE MANDATE
In addition to Headquarters initiatives, we are recommending
several concurrent initiatives that will help the Regions prevent
or minimize project slippage. The recommendations are listed
below:
0 Use the project management concept whereby the same A/E firm is
used for remedial investigation/feasibility study/ remedial
design, and construction management.
0 Include schedules in all cooperative agreements, interagency
agreements, contracts and work assignments, and Consent Decrees
that will ensure that EPA meets the mandaced targets.
• Consider State sanctions, penalty and award fee provisions
of contracts, and enforcement of stipulated penalties of
enforcement agreements when project schedules slip.
0 Expand the universe of borderline cases for each.Region by
breaking out operable units, especially at sites including
short-term surface cleanups and long-term, ground water reme-
diation.
* Subject designs to value engineering, biddability, construct-
ability, claims prevention, environmental, and operability
reviews as appropriate to avoid construction initiation
slippages and help ensure efficient implementation after
award. These reviews must be carefully scheduled to avoid
delaying the completion of the design phas.e.
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9355.0-24
Attachment A
EXAMPLE DESIGN MANAGEMENT SCHEDULE
The following example indicates that in order for construction
to be initiated (construction contract awarded) at a hypothetical
site before October 17, 1989, the ROD would have to be signed no
later than March 31, 1988. The actual duration of the design,
which will affect both the scheduled ROD and construction contract
award dates, will depend upon whether the project is Federal,-
State-or enforcement-lead, the procedures to be used to procure
the design firm, and the complexity of the remedy. Remember that
these example schedules were derived from our experience to date;
our intention for the future is to reduce the time for designs
whenever possible.
Milestones
Date
ROD signature March 31
PRP Negotiations Completed April 30
RD Start - Obligation April 30
. - Consent Decree Lodging May 31
RA Fund Obligation
RD Complete/Construction.
Presolicitation Notice
Invitation for Bids
Submission of Bids
Contract Award
July 1
Jily
Aug.
Sept.
Oct.
16
16
16
16
1988
1988
1988
1988
1989
1989
1989
1989
1989
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FUND-LEAD
REMEDIAL ACTIONS
9355.0-24
RZ
II NY
NY
III PA
PA
PA
PA
PA
PA
PA
WV
IL
IN
MI
MI
MI
OH
WI
VI AR
IX
VIII OD
IX CA
CA
CA
175 CANDIDATE
FY 1987
Site Name
Western Sand & Gravel
Brewster Well Field
Vestal Water Supply 1-1
Blosenski Landfill
Industrial Lane
Lackawanna Refuse
Lansdowne
Tysons Dunp
Wade (ABM)
West line Site
Leetown Pesticide
Lasalle Electric Utilities
Lake Sandy Jo (M&M Landfill)
Ceraetary Dunp
Forest Waste Products
Northernaire Plating
Old Mill
Schnalz Dunp
Cecil Lindsey
United Creosoting
Wbodbury
Celtor Chemical Works
Operating Industries Inc. L/F
San Fernanado Valley (Area 1)
LIST
Lead
F
F
F
F
F •
F
f
F
F
F
F
S
F
S
F
S
F
F
F
S
F
F
FE
S
QtrStart
4/87
4/87
4/87
2/87
3/87
3/87
2/87
3/87
2/87
4/87
3/87
4/87
4/87
3/87
4/87
3/87
4/87
3/87
3/87
3/88
2/87
3/87
3/87
4/87
QtrCorp
3/89
4/88
4/88
2/88
2/88
1/90
1/89
2/89
1/88
3/88
1/88
1/90
2/89
2/89
3/88
2/88
3/90
1/88
1/89
2/94
1/89
2/89
1/90
1/89
OR United Chro» Products, Inc. F 4/87 4/88
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REMEDIAL ACTIONS 93aj.0-2i
175 CANDIDATE LIST
FY 1988
Region St>t« Site Name Lead QtrStart QtrCcnp
I M& Nyanza Chemical Waste Dump F 1/88 3/39
II NJ Beg Creek Farm F 4/88 2/89
NJ Caldwell Trucking F 4/88 1/89
NJ Conbe Fill North Landfill S 4/88 4/90
NJ Combe Fill South Landfill S 4/88 4/89
NJ GEMS Landfill s 4/88 4/39
NJ Glen Ridge Radium Site F 2/88 2/92
NJ Helen Kramer Landfill F 4/88 2/90
NJ Lang Property F 3/88 4/88
NJ Lone Pine Landfill F 4/88 1/90
NJ Metaltec/Aerosystems F 3/88 4/89
MJ Montclair/W. Orange Radium F 2/88 2/92
NY American Thermostat Co. F 4/88 4/89
NY Endicott Village Welfield S 4/88 4/89
NY Haviland Complex F 4/88 1/90
NY Katonah Municipal Well F 4/88 4/89
NY Kentucky Avenue Well Field S 3/88 3/89
NY Sinclair Refinery S 2/88 1/90
III MD Kane & Lombard Street Drums F 4/88 2/92 '
PA Mill Creek Dump F 4/88 2/89
PA . Meyers Landfill P 4/88 3/89
PA Palmerton Zinc Pile F 2/88 4/90
IV FL Coleraan-Evans Wood Pres. F 4/88 2/90
FL Davie Landfill S 1/88 4/89
FL Hollingsworth Solderless F 1/88 2/90
FL Miami Drum Services S 1/88 3/89
FL White House Oil Pits F • 4/88 4/91
\
KY Distler Brickyard F 4/88 4/89
KY Distler Farm F 4/88 4/89
SG Geiger (CM1 Oil) F 1/88 4/91
SC SCPDI Dixiana F 3/88 4/89
V MI Burrows Sanitation F 3/88 4/90
MI Metamora Landfill S 2/88 4/89
MI Noyaco Industries F 2/88 1/90
MI Spiegelburg Landfill S 2/88 3/90
MN Lehillier/Mankato Site S 2/88 2/90
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9355.0-24
(FY'88 Continued)
Region State Site Name Lead QtrStart QtrCcnp
GH
OH
Arcanum Iron & Metal
New Lyme Landfill
P
F
4/88
2/88
4/89
2/89
VI AR Gurley Pit P 4/88 3/90
TX Geneva Industries/Furhrmann S 1/88 2/89
IX Odessa Chromium #1 S 1/88 1/89
TX Odessa Chromium *2/Andrews S 1/88 1/89
TX Petro-Chemical Systems F 1/88 4/88
VIII CO Denver Radium Site F 2/88 3/89
CO Rocky Mountain Arsenal S 2/88 3/89
ND Arsenic Trioxide Site S 2/88 3/89
IX CA Del Norte Pesticide Storage F 2/88 1/89
CA Iron Mountain Mine F 3/88 2/89
X TO Frontier Hard Chrome, Inc. S 4/88 2/89
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FUND-LEAD 9355.0-24
REMEDIAL ACTIONS
175 CANDIDATE LIST
FY 1989
Region Start*
I CT
MA
RI
II NJ
NJ
NJ
NJ
NJ
NJ
NJ
NY
NY
NY
III MD
PA
VA
VA
VA
FL
FL
FL
SC
SC
Site Name
Yaworski Waste Lagoon
Baird & McGuire
Davis Liquid Waste
Florence Land Recon touring
Goose Farm
Pi jack Farm
Sharkey Landfill
Sperice Farm
Syncon Resins
Waldick Aerospace Devices
Fulton Terminals
Marathon Battery Corp.
Wide Beach Development
Southern MD Wood Treating
Berks Sand Pit
L. A. Clarke & Son
Rhinehart Tire Fire Dump
Saltville Waste Disp. Ponds
Pioneer. Sand Co
Tower Chemical Co.
Zellwood Ground Water
IMrlnMntfirlnMh M*i 1 l^«
noepenoent Nan co.
Palmetto Wood Preserving
Lead
F
F
F
S
F
F
S
F
S
F
F
F
F
F
S
F
F
F
F
F .
F
F
F
CtrStart
4/89
3/89
1/89
2/89
1/89
2/89
3/89
2/89
2/89
3/89
3/89
3/89
1/89
3/89
4/89
4/89
4/89
1/89
1/89
3/89
3/89
2/89
2/89
QtrComp
4/90
3/91
4/89
1/90
2/90
3/89
2/91
4/89
3/90
4/90
3/90
2/91
3/90
3/91
4/90
4/91
4/90
1/90
4/89
4/90
4/91
2/91
2/90
TO American Creosote/Jackson F 4/89 4/90
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9355.0-24.
(FY'89 Continued)
Region Strt* ' Site Name __ Lead QtrStart QtrConp
V IL Belvidere Municipal Larxlfill S 4/89 1/91
IL Byron Salvage Yard S 4/89 3/91
IN Marion (Bragg) Dump F 2/89 1/91
MI Liquid Disposal, Inc. S 3/89 1/91
MI Rose Township Dunp S 3/89 1/91
MI Springfield Twp Dunp S 3/89 1/91
MN Arrowhead Refinery Co. F 2/89 1/91
MN South Andover Site S 4/89 2/91
OH Laskin/Poplar Oil Co. F 3/89 4/90
OH Pristine, Inc. F 4/89 1/91
OH United Scrap Lead Co., Inc. F • 4/89 1/93
WI Eau Claire Mun Well Field F 4/89 2/91
VI LA Bayou Bdnfouca F 1/89 2/92
OK Conpass Industries (Avery Dr.) S 4/89 4/90
TX Crystal City Airport S 1/89 4/90
TX Sikes Disposal Pits S 4/89 2/94
TX Sol Lynn/Indust. Transf. S 4/89 2/90
VII KS Arkansas City Dunp S 4/89 1/90
KS Cherokee County F 3/89 4/90
VIII CO Central City-Clear Creek F • 2/89 4/90
IX AZ Litchf ield Airport Area FE 2/89 1/90
A2 Tucson Int'l Airport Area S 3/89 1/91
CA' San Gabriel Valley/Area 2 F 2/89 1/90
CA Selma Treating Co. F 3/89 3/90
X ID Bunker Hill Mining & Metal F 2/89 4/89
TO Colbert Landfill S 4/89 4/91
m • Sdrthwest Transformer F 4/89 3/91
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FY'87 Enforcement RA Candidates (Actual)
9355.0-24
REGION
I
II
III
IV
V
VI
VII
State
ME
NH
CT
ME
NY
NJ
PA
PL
IN
IL
IL
MN
IL
LA
IA
SITE NAME
Winthrop Township
Auburn Road L/F
Kellogg-Daering
McKin
Hooker (Hyde Park)
Olean Well Field
Taylor Borough Dump
Pepper Steel
Seymour
ACME Solvent
Wauconda S & G
TCAAP
Savanna Array Depot
Petro Processors
Oes Moines TCE
LEAD
RP
RP
RP
RP
RP
RP
RP
RP
RP
RP
RP
FT
FF
RP
RP
RD
QtrStart
3/24/86
87/3
87/3
7/10/86
86/4
5/28/87
3/1/86
1/15/87
9/30/86
5/1/87
9/23/86
10/1/86
RA
QtrStart
11/19/86
4/15/87
9/3/87
3/16/87
87/3
87/4
5/28/87
3/26/87
8/17/87
2/1/87
5/1/87
9/29/87
87/3
6/30/87
87/3
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9355.0-24.
FY'88 Enforcement RA Start Candidates
(ENFORCEMENT CONFIDENTIAL)
REGION State SITE NAME
I NH Ottati & Goes
MA Hocononco Pond
CT Beacon Heights L/F
RI Picillo Farm
II PR UoJohn Facility
NJ Renora Inc.
NY Swope Oil
NY Clean Well Field
III PA McAdoo Associates
WV West Virginia Ord
DE Delaware City PVC
VA Chisman Creek
V MN Northern Engraving
VI AR Mid-South
LA Bayou Sorrel •
LA LA Array Depot
VII MO Conservation Chem.
MO Syntex Facilty
VIII CO Marshall Landfill
MT Anaconda Smelter
00 Snuggler Mountain
CO Rocky Flats
LEAD
RP
RP
RP
RP
RP
RP
RP
RP
RP
RP
RP
RP
RP
RD
QtrStart
88/1
87/4
9/1/86
87/4
87/4
87/4
87/4
4/15/87
87/4
RA
QtrStart
88/3
88/4
88/2
88/3
88/4
88/3
88/4
88/1
88/4
88/4
88/2
88/2
88/2
RP
RP
FF
RP
RP
RP
RP
RP
FF
87/4
87/4
9/1/86
87/4
87/3
88/1
87/2
88/2
88/2
88/4
88/1
88/4
88/3
88/4
88/3
88/3
88/4
IX CA IBM (San Jose)
CA Motorola (52nd ST)
SE
SE
88/4
88/4
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9355.0-24
REGICN State
I
II
MA
NH
NY
NY
NJ
PR
NJ
PR
NY
NY
NY
FY'89 Enforcement RA Start Candidates
(ENFORCEMENT CONFIDENTIAL)
SITE NAME
Industri-Plex
Tinkham Garage
Sarney Farm
Ciba Geigy
Diamond Alkali
Vega Alta
Ringwood Mines
GE Wriring
Hooker (S-area)
Ludlow S & G
GM/Cen. Foundry
LEAD
RP
RP
RP
RP
RP
RP
RP
RP
RP
RP
RP
RD
QtrStart
88/1
87/4
88/4
RA
QtrStart
89/1
89/1
89/2
89/2
89/1
89/1
89/2
89/2
89/4
90/1
90/2
III DE Army Creek L/F RP 87/4 89/2
MO Sand, Gravel & Stone RP 88/1 89/1
MD • Limestone Road • RP 88/2 89/2
DE Tytouts Corner L/F RP 88/2 89/2
DE Harvey & Knott RP 87/4 89/1
PA Henderson Rd. RP 89/4
WV Ordnance Works Disp RP 89/4
VA Avtex Fibers RP 89/4
PA Whitraoyer Lab RP 90/1
PA Middletown Air Field RP 90/1
IV FL Brown Wood Pres. RP 88/2 89/2
SC Carolawn RP 89/1
FL Alpha Chemical RP 89/2
FL Gold Coast RP . 89/3
FL NW 58 St L/F RP 89/4
NC Martin Marietta/Sodeyco RP 89/4
NC Celanese Fiber RP 90/1
KY AIHCO RP 89/3
KY BF Goodrich RP 89/3
NC Chamtronics RP 90/1
MS Mowood RP 90/1
V IN Northaide L/F RP 88/1 89/2
IN Envirochem Corp. RP 88/1 89/1
IN Meal's Landfill RP 2/15/86 89/2
MN Waste Disposal RP 87/4 89/1
MN FMC Corp. RP 88/1 89/1
OH Coshocton L/F RP 88/1 89/1
IL Johns-Manville RP 87/3 89/2
IN Lemon Lane L/F RP 89/3
IN Neal13 Dump/Spencer RP 89/4
IN Bennett Stone RP 89/4
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9355.0-24
FY'89 Enforcement Candidates (cont.)
(ENFORCEMENT CONFIDENTIAL)
REGION State
VI
VII
VIII
IX
OK
IX
TX
TX
NM
TX
OK
OK
NM
KS
SD
HI
00
00
CA
CA
CA
AZ
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
AZ
OR
OR
SITE NAME LEAD
Tinker AFB FF
Motco Inc. RP
Brio Refining RP
Dixie Oil Processors RP
AT&SF (Clovis) RP
French RP
Hardage/Criner RP
Sand Spring RP
South Valley RP
Doepke Disposal RP
Wiitewcod Creek RP
Burlington Northern RP
California Gulch RP
Broderick Wood RP
MGM Brakes RP
Coast Mood Pres. SE
Firestone Tire SE
19th Ave L/F SE
Liquid Gold Oil SE
Fairchild Caraera/Mt.View RP
Signetics
Intel Corp (Mt. View)
Raytheon
Koppers Co.
Fairchild Camera/ S.J.
Westinghouse Electrical
Hewlitt Packard
Montrose Chem.
Utchf ield Airport
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