vv EPA
               United States
               Environmental Protection
               Agency
            Office of
            Solid Waste and
            Emergency Response
DIRECTIVE NUMBER: 9355.0-24

TITLE: OSWER STRATEGY FOB' MANAGEMENT OVERSIGHT
       '   OF CERCLA^REMEDIAL ACTION START
                  MANDATE •
APPROVAL DATE: 12/28/87

EFFECTIVE DATE: 12/28/87

ORIGINATING OFFICE:

0 FINAL
                                   of Solid Waste
                D DRAFT

                 STATUS:
          [ ] A- Pending OMB approval
          { j B- Pending AA-OSWER approval
          [ ] C- For review &/or comment
          [ ] D- .In development or circulating

                        headquarters
                REFERENCE (other documents):
  OS WER      OS WER       OS WER
/£    DIRECTIVE    DIRECTIVE   Di

-------
                       unitea Slates crrvirorimtnTat Election Agency
                              Wasnmgron. OC 20*60
             OSWER Directive Initiation Request
                                                                          Numo«r

                                                                     9355.0-24
                                    7. Originator information
        Mama of Contac: Person
            Hal Snvder
                               .Man C
                                i Coot
                                OS220
|0«ic
                                            feCD
Coct
382-48
            OSWER STRATEGY FOR MANAGEMENT OVERSIGHT OF -CERCLA
            REMEDIAL ACTION START MANDATE
           "*V of Directive (i/tciudt on«f sui«m«nt of purpose*                                  '
            Establishes a process form managing EPA's efforts to achieve CERCLA
            Section 115(e) statutory mandate for remedial action starts. Establishes a
            process for setting Regional expectations and provides guidance to enhance EPA
            ability to meet theses requirements.
       (.Keyword* Superfund, CEPCLA. SARA
Ja. Ooes This Oireeave Supersede Previous Oirecuve
-------
.,. --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

-------
                     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.

-------
                                                      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.

-------
                                                        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.

-------
                                                           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.

-------
                                                         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".

-------
                                                            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.

-------
                                                            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

-------
                                  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

-------
                                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

-------
                                                                        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

-------
                           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

-------
                                                                   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

-------
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

-------
                                                                             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

-------
                                                                        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

-------
                                                                              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
                 
-------