UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                        WASHINGTON D.C. 20460
                              JAN 26 1990
                                                     OFFICE OF
                                            SOLID WASTE AND EMERGENCY RESPONSE

                                       OSWER Directive # 9355.4-02A
MEMORANDUM

SUBJECT:  Supplement  to Interim Guidance  on Establishing  Soil
          Lead Cleanup Levels at Superfund Sites

FROM:     Henry  L.  Longest II, Director  /s/
          Office  of Emergency and Remedial Response

          Bruce  M.  Diamond,  Director  /s/
          Office  of Waste Programs Enforcement

TO:       Directors,  Waste Management  Division,  Regions I,
          IV, V,  VII,  and VIII
          Director, Emergency and Remedial Response Division,
          Region  II
          Directors,  Hazardous Waste Management Division,
          Regions III  and VI
          Director, Toxic Waste Management Division, Region  IX
          Director, Hazardous Waste Division,  Region X

     The purpose of this directive  is  to reiterate  that OSWER
Directive  #9355.4-02, titled  "Interim Guidance  on  Establishing
Soil Lead  Cleanup Levels at Superfund Sites"  and dated September
7, 1989, is  a guidance document  and not a  regulation.  As  is the
case with  other  guidance documents,  this guidance  should  not be
used as  a  regulation.

     The lead level range provided  in the directive is  to be
considered by a  Regional Administrator in  arriving at  cleanup
levels to  be entered into Records  of  Decisions  for individual
Superfund  sites. The  directive  is  not binding in formulating
individual cleanup levels.1  The directive  is  clear on its
face
      The "Effective Date" provision of the directive should not be read to
suggest that the directive has regulatory impact. The provision simply
clarifies that the directive does not require or contemplate that Agency
decision makers will re-open Records of Decisions already entered into in
order to consider the data provided in the directive.


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that it provides only "interim guidance," that EPA  is
continuing to evaluate studies on the toxicity of lead,  and
that the guidance may be revised as additional information
becomes available with respect to the bioavailability  of lead
in soil. Moreover, the directive plainly states that site-
specific conditions and data may be taken into account  in
setting soil cleanup levels for individual sites, which may  be
above or below the levels set forth in the directive,  and that
the administrative record for any particular site should
include site-specific information as well as background
documents on the toxicology of lead.

     In summary,  the cleanup levels for a particular response
action must be based on the entire administrative record for
that response action, of which the guidance will typically be
only a part.
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