EPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
Publication 9200.5-3041
July 1991
Site Assessment
Bulletin
Office of Emergency and Remedial Response
Hazardous Site Evaluation Division OS-230
Intermittent Bulletin
Volume 1 Number 1
Branch
Chief's
Welcome to the first
quarterly edition of the Site
Assessment Bulletin! People at
the National Site Assessment
Conference last January expressed
much enthusiasm and eagerness both for
sharing ideas and for learning about initiatives
and innovations going on in all areas of the site
assessment program. In that spirit, this newsletter
is intended to provide a regular opportunity for the
cross-fertilization of ideas among States, EPA Regions,
Headquarters, and the contractor community.
With the revised HRS now final and the vast bulk of the pre-
SARA SI universe completed, we are ready to begin the second
decade of the Superfund screening and site assessment process. Our
goal is to accelerate that process so we can meet the Congressional
mandate of deciding the NPL status of all sites within four years of
CERCLIS listing, while constantly improving the quality of our
outputs.
Fundamental to the process of continual improvement is a regular
means for communication among all involved in the program. The
Site Assessment Bulletin was designed with that in mind - - only
with your help can we bring about a better site assessment program.
Thanks to all those who contributed articles and time to this edition;
we look forward to your suggestions in the future. Enjoy!
INSIDE
Fostering a State/EPA
Partnership 2
Federal Facilities
Lawsuit ., ...3
Around the Regions
Focus on Region 10
and Debbie Flood .. ...4
New Rule for Wood
Preserving Wastes 6
Test Your Site
Assessment Savvy 7
Acronyms List 8
and more-
Editor: Mary Latka
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State's
Point
of
View
V X
FOSTERING A STATE/EPA PARTNERSHIP
Fostering a State/EPA partnership in the site
assessment program involves providing mechanisms
for meaningful State input into management and policy
decisions. These mechanisms range from State participa-
tion in national workgroups and conferences to frequent
discussions with Regional site assessment managers
regarding program direction and site-specific activities.
A critical aspect, however, is a shared attitude and belief
among States and EPA that active State participation
enhances environmental decisions made at particular
sites.
Fostering this partnership is in the interest of many
States since most sites now being assessed were first
brought to EPA's attention by State regulatory agencies.
States often have a history with ind ividual sites as well as
technically trained staff specializing in site assessment
activities. Sites receiving a "no further remedial action
planned" recommendation are returned to States for
possible action. We live in the communities in which
these sites are located and therefore, are impacted di-
rectly. Lastly, we work for State environmental protec-
tion agencies serving a public need our mission at
Wisconsin Department of Natural Resources is "to pro-
tect and enhance our natural resources, to provide a clean
environment and to consider the future and those who
will follow us."
...critical is a shared attitude and belief
among States and EPA...
EPA's task in fostering a State/EPA partnership
requires coordinating with 50 State agencies, which must
be more difficult and demanding than simply directing
the activities of one or two contractors. In addition, a
State's individual priorities may differ from EPA's
national priorities, potentially requiring EPA to engage
in conflict resolution with States. Under the direction of
Administrator Reilly, fostering a State/EPA partnership
was clearly the basis for the State/EPA Policy Forum.
The Forum's Site Assessment Subgroup made specific
recommendations, several of which have already been
implemented.
Many benefits are derived from a strong State/EPA
pa rtnership. The environment and the public will benefit
because sound, consistent site assessments and
recommendations are made and program efficiencies
N
I N
Robin Schmidt
result from coordinated State/Federal sampling and
analysis efforts. EPA benefits because it can demonstrate
to the public and Congress a workable, efficient, and
effective site assessment program. States benefit for all
these reasons.
The States and Region 5 have established a founda-
tion for a true partnership through both the insistence of
the States and EPA on a collegial relationship and through
the realization that States' progressive environmental
programs can complement site assessment. We have a
good communications network among the States and
between the States and EPA. States initiate meetings
among themselves and EPA initiates State meetings to
discuss program issues and strategies. We work hard to
coordinate site assessment needs and activities with
EPA. For example, we have adjusted our program to
assure that the Region's pre-SARA SI commitments are
met, while the Region has recognized our needs by
instituting two-year cooperative agreements.
A dilemma remains, however: how to provide mean-
ingful State involvement in setting site assessment pro-
gram policies beyond the Regional level, when EPA
must deal with 50 differing State agendas and programs?
Two established groups could enhance this effort the
National Governors' Association Site Assessment Work-
group and the Association of State and Territorial Solid
Waste Management Officials (ASTSWMO) Site Infor-
mation and Evaluation Task Force. EPA Headquarters
and the Regions should rely on both groups to provide
meaningful State guidance and direction for the site
assessment program.
With the current field investigation contracts ending,
States have an opportunity to enhance their involvement
in site assessment. For example, in Wisconsin we are
pursuing a greater role as EPA will rely exclusively upon
the State to conduct all site assessment work. The future
looks bright for successful State/EPA partnerships in site
assessment. Both EPA and the States must work together
to make such partnerships work. ^
Robin Schmidt has been a hydrogeologist and the Lead
Worker for the Site Assessment Program for Wisconsin for 5
years. Ms. Schmidt received a Masters Degree in Land
Resources from the University of Wisconsin, as well as a BS in
Environmental Policy and Geography.
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FEDERAL FACILITIES LAWSUIT
In a lawsuit in Boston, a Federal court recently ordered
EPA to complete PAs for all Federal facilities on the original
(February 1988) Federal Facilities Hazardous Waste Com-
pliance Docket by July 15,1992 and include eligible facilities
on the NPL by July 15,1993. The lawsuit involves more than
800 facilities.
The lawsuit concerns the proper interpretation of
CERCLA section 120(d), added when SARA was enacted on
October 17,1986. The section required EPA to take steps to
ensure that PAs are conducted at all Federal facilities on the
original docket by April 1988,18 months after the enactment
of SARA. The statute further required that following the PA,
where appropriate, EPA must evaluate Federal facilities for
the NPL by April 1989,30 months after SARA enactment.
The lawsuit was brought by a New England-based
public interest group, the Conservation Law Foundation
(CLF), which contended that section 120(d) imposed a non-
discretionary duty EPA has failed to carry out. CLF argued
that all PAs should have been completed by April 1988, and
all evaluations by April 1989.
In response, EPA argued:
The statutory language regarding both the PAs and
final evaluations suggests that the Agency could
use its discretion in implementing the statute.
Meeting these deadlines is beyond its control
because EPA relies on other Federal agencies to
provide necessary site evaluation information.
CLF, whose members live primarily in Region 1,
does not have sufficient interest in facilities outside
Region 1 (legally referred to as "standing") to seek
an order with respect to those facilities.
Federal Facilities
Sites Subject to Lawsuit: 836
NFRAP or
NPL
Decision
Needed
58%
On NPL
11%
No Further
Action
Required
31%
June 5,1991
The court has ruled in favor of CLF, concluding:
SARA imposed a non-discretionary duty upon
EPA to complete all PAs and evaluations by the
specified dates.
CLF did, in fact, have legal standing and therefore
could argue for the evaluations of sites nationwide.
EPA did demonstrate many complicating factors
that could affect the timely evaluation of Federal
facilities on the docket, such as EPA's dependence
on other agencies for site information. However,
EPA did not prove that compliance with the court-
imposed deadlines would be impossible.
continued on page 8
Five Years Ago on EARTH DAY...
535 sites were listed on the NPL
18,117 sites had completed PAs
5,911 sites had completed Sis
April 20,1986
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R
Around
the
Regions
N
1 0
egion 10 has an innovative approach to site
assessment that is dictated, in part, by the diverse
geography of the Region, the organization of the
Branch in which it is located, and by the compara-
tively small number of CERCLIS and NPL sites in the
Region.
The States in Region 10Alaska, Idaho, Oregon,
and Washington vary widely in geographic, cli-
matic, and other conditions. Arctic weather, temper-
ate rain forests, sand dunes, lava fields, and range-
lands are some of the wide variations in which the
site assessment team conducts its field work. Some
areas of the Region have 200
inches of snowfall per year, oth-
ers 200 inches of rain. Forty-
seven percent of Alaskan lands
are wetlands, and climatic con-
ditions allow only two months
each year for conducting field
work. Because of this diversity,
the Region has Operations Of-
fices in each State with staff who
act as liaisons with their State
site assessment counterparts and
as reviewers of work produced
through cooperative agree-
ments.
In addition, the Region has embarked upon an
ambitious new site discovery project. Using a
Geographic Information System (GIS) that incorpo-
rates HRS data elements, the Region is able to pro-
duce maps depicting the geographic vulnerability of
an area according to the air, surface water, and
ground water pathways of the HRS. These GIS-
generated maps, coupled with a systematic search of
historical waste generators, assist in identifying new
CERCLIS sites that may represent the Region's
"worst" sites. The project also has produced extra
dividends by reducing the effort necessary to con-
duct PAs since it produces much of the desk-top
People in Site Assessment
Debbie
Flood
Region 10 has been active in
tailoring the most current tech-
nologies to its ad vantage. In the
field, innovative technologies
are used to decrease sample
costs while providing real-time
data. For example, the Field
Analytical Screening Program (FASP) and soil-gas information required for a PA. Other Regions can
sampling have been used in approximately 13 inves- adopt Region 10's approach without incurring the
tigations in the last two years. FASP allows for rapid, same start-up costs. Also, other EPA programs and
on-site sample analysis, enabling field personnel to the States can use the data already in the GIS for other
revise their sampling strategies during site investi- purposes.
In 1970, Debbie Flood, a Seattle native with an educational back-
ground in life sciences, joined the Department of Health, Education and
Welfare's Environmental Health Services Division in Seattle. A few
months later, it merged with the Federal Water Quality Administration
in Portland, Oregon to become EPA's Region 10. Flood is one of only
two employees still at Region 10 from those days.
gations. The FASP also serves as an effective tool for
targeting samples requiring Contract Laboratory
Program analysis.
continued on page 5
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CONTACTS HQ SITE ASSESSMENT
FTS or (202)
Environmental Priorities Initiative Deborah Duffy 382-6941
FIT to TAT Transition Rick Webster 475-9703
FIT to ARCS Transition John Hollister 475-8106
MRS Guidance Art Johnson 475-9749
Investigation Derived Waste Policy John Hollister 475-8106
PA Guidance Barbara Bach 382-6942
PA Score Tim Fontaine 475-9748
PREscore Art Johnson 475-9749
QA for PAs Rick Webster 475-9703
QC Manual Marti Otto / June Wiaz 382-5745
Removal Policy Short Sheet Mary Latka 475-9700
Site Assessment Training Tina Maragousis 382-7393
SI Guidance Barbara Bach 382-6942
Superfund Universe Study Mary Latka 475-9700
Site Assessment Bulletin July 1991
Comments...
Clip coupon and return comments to:
Mary Latka
OS-230
U.S. EPA
401 M Street, SW
Washington, DC 20460 Name: __
Affiliation: .
Address:
Phone / FTS:
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SAM CONTACTS
Region 1
Jane Anderson FTS or (617) 833-1698
Region 2
BenConetta FTS or (212) 264-6696
Region 3
Lori Acker FTS or (215) 597-3165
Region 4
Debbie Vaughn-Wright FTS or (404) 347-5065
Region 5
Linda Martin FTS or (312) 353-9486
Region 6
Barbara Driscoll FTS or (214) 255-6740
Region 7
Pete Culver FTS or (913) 276-7707
Region 8
Pat Smith FTS or (303) 330-1262
Region 9
Carolyn Douglas FTS or (415) 744-2343
Region 10
Deborah Flood FTS or (206) 399-2722
Headquarters
Tina Maragousis FTS or (202) 382-7393
We're Almost There!
10,420
10,176
Estimated Backlog*
SI Evaluations
as of May 1991
Pre-SARA SI Evaluations
Regions 6 and 10 have eliminated their backlogs.
Well done!
*as of October 17,1986
We want your feedback!
I would like to read and/or contribute future newsletter articles on:
Name the Newsletter
Q National Priorities
Q Rankings
Q The Investigator
Q Site Assessment Story
Q Site Assessment Update
Q Site Assessment Bulletin
Q Site Assessment News
Q Other
Where would you like the next National Site Assessment Conference
to be?
Clip coupon and return to address on reverse side
-------
continued from page 4
Site assessment in the Region employs a team
concept. Current team members include Team Leader
Debbie Flood, David Bennett, Debbie Robinson, and
Monica Rolluda. The team approach means that the
decision to propose a site for the NPL must be made
through the team's peer review process. In this
process, the team decides whether to develop an
HRS package for a site. After the NPL coordinator's
technical review of a package, peer reviewers exam-
ine the package to ensure its accuracy and that all of
the necessary documentation is included.
Region 10 has a unique Superfund organiza-
tional structure. The Emergency Response Pro-
gram, the Chemical Emergency Preparedness Pro-
gram, and the Site Assessment Program are within
the same Branch. This arrangement is beginning to
lead to closer coordination among these programs.
For example, Region 10's site assessment and re-
moval programs plan to conduct a joint site inspec-
tion. Region 10 has also enjoyed close interaction
with the Headquarters Site Assessment Branch
though participation in many workgroups, and looks
forward to continued lively interaction. *
Rood's association with Superfund dates back
to 1983 when she started working on CERCUS. PA
and SI work was moving slowly at that time, without
an EPA staff person specifically responsible for
taskingcontractors. Debbie reorganized the Region's
site assessment program into a dynamic team. She
has also witnessed the amazing growth of and
changes in EPA and the Superfund program. For
example, in 1983, there was little guidance for imple-
menting the site assessment program. Debbie feels
this gave her a great deal of room for creativity in
addressing site issues. While she appreciates the
formal procedures developed since then and under-
stands the need for national consistency, she some-
times misses the creativity that was called for in the
past.
Debbie's lifestyle allows her to take advantage
of living in the Northwest. Since 1983, she has lived
on Bainbridge Island where she and her husband
designed and are still building a "new old house"
a new house in the style of their turn-of-the-century
furniture and the quilts she makes. Quilting, ac-
cording to Debbie, is a therapeutic hobby. She and
her husband also maintain rose and herb gardens
on their two acres of land. Living on an island
presentsan interesting commutingchallenge. Rood
takes the ferry to work, about a half-hour commute,
and often brings SI reports along for some uninter-
rupted reading.
Debbie believes the biggest challenge in her
work is "trying to do what makes sense" while
juggling the diverse demands of her job. In particu-
lar, the variation in State relations and the geo-
graphic diversity require the Region's site assess-
mentteamtodevelop innovative approaches to site
problems. Debbie looks forward to the challenges
associated with continued success in Region 10's
site assessment activities.
David Bennett
Debbie Flood
Penny Hansen
THANKS !
To the many contributors to this issue:
Linda Martin
Tina Maragousis
Linda Rutsch
Robin Schmidt
George Wyeth
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SAM
NATIONAL ASSOCIATION
Linda Martin, a Region 5 Site Assessment
Manager (SAM), has taken the initiative in forming
a national organization of SAMs. The organization
will be composed of EPA employees involved in all
stages of the site assessment process. Formation of
such a national organization is particularly impor-
tant at this time as the site assessment program is
going through several major changes including the
implementation of the revised HRS and use of the
Alternative Remedial Contracting Strategy con-
tractors for site assessment work. Because site
assessment is the first step in the Superfund pro-
cess, and communication among SAMs is critical at
this point in order to improve the process, a national
organization for SAMs will greatly benefit the
Superfund program as a whole.
The goals of the organization are to develop a
strong communication network among all SAMs,
identify Regional strengths, and capitalize on those
strengths. The organization will attempt to pin-
point critical issues in the site assessment program
and will form workgroups and committees to ad-
dress these issues. The organization may also
develop a technical training program to enhance
the skills of SAMs nationwide.
One EPA representative from each Region has
been designated as a contact point to provide infor-
mation to their SAMs. The representatives have
held one conference call that focused on the devel-
opment of a SAM survey form. The survey, in-
tended to determine individual interest in such an
organization, was distributed in April. The re-
sponses are being analyzed, and more information
about the survey and this Association will appear in
the next issue of this bulletin. *
If you have any questions or ideas about this
organization, please contact Linda Martin at FTS
or (312) 353-9486.
New Rule for Wood Preserving Wastes
In December 6,1990, EPA published in the Federal
Register a final rule for wood preserving wastes. The
wood preserving industry treats wood used as railroad
ties, utility poles, and outdoor lumber with chemical
formulations to retard decay. This rule adds three cat-
egories of waste to the Resource Conservation and Re-
covery Act (RCRA) hazardous waste list: wastewaters,
process residuals, preservative drippage, and spent for-
mulations from wood preserving processes generated at
plants that use chlorophenolic formulations, creosote
formulations, and inorganic preservatives containing
arsenic or chromium.
The newly listed wastes will also be designated as
hazardous substances under CERCLA. If quantities of
these wastes exceeding one pound (known as "Report-
able Quantities" or RQs) are released into the environ-
ment, the release must be reported to the Federal, State,
and local emergency response centers.
The final rule for wood preserving wastes requires
wood treaters to install drip pads that meet specific
technical design and operating standards. After treated
wood from pressure and non pressure processes is re-
moved from the treatment vessel, it must be held on the
drip pad until drippage has stopped. Wood treaters are
urged to assess the extent of contamination at their plants
to ensure proper cleanup before building new drip pads.
The final rule does not require wood treaters to
obtain a RCRA Subtitle C permit to store hazardous
waste as long as all wastes are removed from the drip
pads and associated collection systems at least once
every 90 days, and the drip pads meet the technical
design and operating standards. These wood treaters
will be considered 90-day accumulators.
EPA expects the majority of wood treaters to be 90-
day accumulators. Ninety-day accumulator wood treater
sites will be eligible for the NPL if they score above 28.50
on the HRS. Wood treaters that become treatment,
storage and disposal facilities will generally not be eli-
gible for the NPL, and will be handled under the RCRA
corrective actions program. However, facilities that did
not engage in treatment, storage, or disposal of wood
preserving waste after June 5,1991 and did not engage in
any other activity that would subject them to RCRA,
would not be eligible for corrective action and are eligible
for NPL listing. *
For more information on this final rule, consult the fact
sheet, "New Rule for Wood Preserving Wastes"
(EPA / 530-SW-91-012).
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Your Site Assessment Savvy
1. What is the most frequently
found chemical at NPL sites?
a. Trichloroethylene (TCE)
b. Lead
c. Toluene
d. Zinc
2. What percentage of sites on the
NPL are municipal landfills?
How many sites have been
deleted from the NPL?
8.
a. 59
b. 25
c. 42
d. 34
Approximately what percentage
or PAs conducted between FY80
and FY90 were State-lead?
a. 25%
b. 72%
c. 59%
d. 41%
a. 45%
b. 11%
c. 23%
d. 34%
3. How many States have identfied
their top priority site?
a. 20
b. 38
c. 43
d. 31
4.. Which Region has the most NPL
sites?
What is the most common
method by which NPL sites
are discovered?
a. RCRA Notification
b. State Programs
c. CERCLA Notification
d. Citizen Complaints
How many sites were added
to CERCLIS during calendar
year 1990?
9.
Approximately what percentage
or the NPL is made up of Federal
facilities?
a. 3%
b. 22%
c. 16%
d. 10%
10. How many ATSDR sites are on
the NPL?
a. 3
b. 17
c. 320
d. 98
a. 28
b. 6,754
c. 1,584
d. 962
a. 1
b. 2
c. 5
d. 9
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Federal Facilities Lawsuit continued from page 3
EPA is appealing the Boston court's decision to a higher
court. CLF has also appealed the court's decision, seeking
even tighter deadlines than those the court imposed and is
seeking to have the order apply to facilities not on the initial
docket. Until the higher court issues its ruling, however, the
present order remains in effect and the deadlines remain in
force. Since the higher court's decision may not be issued
until late this year, dose to the July 1992 deadline for
completion of all PAs, theSite AssessmentBranchisworking
with the Office of Federal Facilities Enforcement and the
Office of General Counsel to develop strategies to help EPA
meet the manda te. The site assessment program has alread y
identified, by Region, the number of sites subject to the
lawsuit, those sites requiring PAs, and those needing final
listing decisions. ^
If you have general questions about the effect of this
court decision, please contact Deborah Duffy at FTS or
(202) 382-6941. If you have questions about a particular
Federal facility, contact Linda Rutsch, Office of Federal
Facilities Enforcement, at FTS or (202) 475-9801.
Acronyms
ATSDR- Agency for Toxic Substances
and Disease Registry
CERCLA - Comprehensive Environmental
Response, Compensation, and
Liability Act
CERCLIS - Comprehensive Environmental
Response, Compensation, and
Liability Information System
EPA - Environmental Protection Agency
MRS - Hazard Ranking System
NPL - National Priorities List
PA - Preliminary Assessment
SAB - Site Assessment Branch
SARA - Superfund Amendments
and Reauthorization Act
SI- Site Inspection
EPA
United States
Hnvi roil mental Protection
Agency OS-230
Washington, DC 20461)
First-Class Mail
Postage and Fees Paid
EPA
Permit No. G-35
Official Business
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