UNITED STATES ENVIRONMENTAL PROTECTION
               WASHINGTON, D.C. 20460


                   MAY 2 2 1996
                                                       SUPERFUND DIVISION
                                                     OFFICT OF THF- DIRECTOR
                                                             OFFICE OF
                                                       SOLID WASTE AND EMERGENCY
                                                             RESPONSE
                                    'OSWER Directive  9200.1-17
MEMORANDUM
SUBJECT:   Focus Areas for Headquarters Support for Regional
           Decqjsiorv-Mak£?lg
FROM:
TO:
                         tor
                     and Remedial  Response
Director, Office of Site Remediation and Restoration
  Region  I
Director, Emergency and Ramedial  Response Divis
  Region  II
Director, Hazardous Waste Management Division
  Regions III,  IX
Director, Waste Management Division
  Region  IV
Director, Superfund Division
  Regions V,  VI,  VII
Assistant Regional Administrator,  Office of Ecosystems
Protection and  Remediation             >
  Region VIII                          ^
Director, Environmental Cleanup Office
  Region X
Purpose
                                                  f
     This memorandum outlines  the  technical and policy areas the
Office of Emergency and Remedial Response  (OERR)  is  focusing its
regional coordination efforts  on in FY.1996 to promote
appropriately consistent program implementation and  effective
communication between Headquarters and the Regions.
                                                       Recycled/Recyclable
                                                       Printed with Soy/Canola Ink on paper that
                                                       contains at least 50% recycled liber

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     These  focus areas represent critical program areas that
warrant special attention by Regional and Headquarters management
and staff because they 1) have a dramatic impact on the ultimate
cleanup decisions EPA makes; 2) they entail issues of intense
public, Congressional, and stakeholder interest; and/or 3) they
are areas where the policy is changing rapidly due to new
understandings in science or technology.  Targeting regional
coordination will promote continuous improvement in the quality
and public understanding^of EPA's response decision making in
those areas, where the coordination will have the greatest impact.
Appropriately consistent implementation of national program
guidance and policy, and effective communication, will go far
toward demonstrating the rationality, fairness, and
predictability of our decisions,  and enhancing the Superfund
program's overall credibility.

     The goal of consistent implementation is that we all share a
common understanding of program policies and,  as a result, employ
similar rationales in response selection rather than having, for
example, the same cleanup level or identical technologies at
every site.  Hence,  the purpose for focused support for Regions
is to ensure this common understanding and credible dec' sion
making across Regions and to encourage transparent presentation
so that those outside the Agency understand our decisions.

     This effort builds on the long-standing tradition of
regional coordination in OERR.  While the level of involvement of
Headquarters staff in supporting response selection has varied
over the years, we are now in a period where a strong partnership
between the Regions and their Headquarters counterparts on key
technical and policy issues related to response selection
decisions is crucial.

     The persistence and prominence of national consistency as a
concern among stakeholders inspired a special meeting of the
Waste Management Division Directors in. summer of 1995 in Chicago.
Areas of concern discussed at that meeting became the focus of a
consistency initiative during the latter part of FY 1995.  Under
this initiative Headquarters staff reviewed proposed plans and
draft records of decision  (RODs) that related to the focus areas,
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 developed information  on program performance,  and  suggested
 alternate language  or  approaches for  some  RODs.

      In October  1995,  OERR's reorganization placed an emphasis on
 program implementation and the promotion of full program
 integration begun under the Superfund Accelerated  Cleanup Model
 (SACM)  through the  establishment of five Regional  Accelerated
 Response Centers, each of which has responsibility for supporting
 two Regions in their site assessment, removal, and remedial
 activities.

      Continued focus on some key policy areas  remains important
 this  fiscal year.  These focus areas will  enable us to tell the
 story of  our program implementation efforts in a more effective
 way.  Through more direct support of Regional  decision making- in
 critical  areas and the inclusion of an evaluation  component in
 the process,  we will be able to identify trends and good examples
 of effective implementation we can share nationally, with
 Congress, States, and the public.

 Implementation

     This memorandum provides a strategy for OERR  and the Regions
 to work together as partners to ensure that the.directives and
 guidance related to the identified focus areas are implemented in
 an appropriately consistent manner across all  Regions.   A key
 element of focused regional coordination is ensuring that Regions
 receive and understand all policies related to the four focus
 areas.  To the degree that resources allow, Headquarters will
provide face-to-face presentations on the focus areas to
 appropriate Regional personnel.   It is important that all of us
 share an understanding of the policies related to  the focus.areas
 so that they can be incorporated into site activities as early as
possible.  OERR staff will continue to support Regions on any
technical or policy issue that arises, although we will make
 special efforts to promote understanding of these  key issues and
 facilitate effective decision making with respect  to them.

     Since decision documents provide one of the most succinct
and objective demonstrations of policy implementation,  they will
be used to assess our progress in implementing the focus areas,
as was done last year.   Review of draft documents  provides an
opportunity to positively impact decision documents before they

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 are  made final.   Our purpose is  to ensure  that Agency decisions
 are-  clear and consistent in presentation and  content and not  to
 second-guess Regional decision-making.   However, we will flag
 inconsistencies  and expect  to work through such  issues  as may
 arise.   Headquarters will also compile  results for discussion at
 year's  end.   This will allow us  to gauge our  progress toward
 continuous improvement and  to shift our focus to other  areas,"  as
 appropriate.

 Non-Federal Facility Sites:   To  implement  this effort.  Regions
 should  send their draft proposed plans  to  the appropriate
 Accelerated Response Centers for review.   The Accelerated
 Response Centers will determine  the need to obtain draft RODs;
 and  we  will  prioritize our  further attention  on  those documents
 based on their relation, to  the focus areas.   For non-tirs-
 critical removal, actions, the Region should contact the
 appropriate  Regional Coordinator to determine the need,  to send in
 the  draft. Engineering Evaluation/Cost Assessment or Action
•Memorandum.   We  will work diligently to accomodate Regional
 schedules in providing our  feedback to  you.   Sending these
 documents to Headquarters will enable us to document the national
 progress of  the  Superfund program,  as well as demonstrate
 effective implementation of  the  focus, areas.  In addition, some.
 compilation  of national statistics regarding  the focus  areas  will
 be developed from review of  draft  excision documents.

 Federal Facility Sites:   The Federal Facilities  Restoration and
 Reuse Office  (FFRRO)  will look at  decision documents for Federal '
 Facility sites,  to the extent that FFRRO Headquarters staff can
 meet necessary site-specific schedules,  particularly where the
 Region  has an interest in Headquarters  review.   Therefore, draft
 decision documents for Federal Facilities  should be sent to
 FFRRO.   OERR will provide assistance, to FFRRO as needed on
 technical issues associated  with the focus areas.

 FOCUS AREAS

     OERR's  Regional Accelerated Response  Centers will  focus
 particular attention on the  following four areas:

 •    Risk management and cost-effectiveness decision
     documentation:   ensuring that all  Superfund decision
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     documents clearly present the risks that warrant taking an
     action, how the risks will be addressed by  the response
     action, the other benefits of the response  action, the
     •response costs, and how  it was determined that the
     effectiveness of the response justifies the cost.  Risk
     management decisions include land use and exposure
     assumptions, which should be reasonable, not speculative;

•    Ground water policy:  ensuring implementation of the phased
     approach to ground water remediation, use of the. Technical
     Impracticability Guidance, and measurement  of response
     performance;

•    Lead policy:  ensuring implementation of the OSWER lead
     directive !OSWER Directive #9255.4-12) issued in July 1994,
     including the use of-the integrated exposure ~nd uptake
     biokinetic model (IEUBK);
   k
••    Presumptive remedies:  ensuring implementation of
     presumptive remedy guidances at all appropriate sites and
     measuring resulting impacts (e.g.,  time and cost saving).

     Attachment 1 to this memorandum describes each focus area in
more detail,  highlighting why each focus area has been
identified,  and explains the Regions'  and Headquarters'
anticipated, roles.

     The four focus areas apply to response actions taken under
both removal authority and remedial authority,  although the
specific application of guidance in a particular area may be
different depending on the specific authority involved.   For
example, the clarification of risk management and cost-
effectiveness decisions should be tailored to the specific
decision document and the magnitude of the response.  For some
actions performed under removal authority, the discussion of
risks to be addressed and the benefits of the response may be
qualitative and less detailed than that for more complex,
extensive actions for which more detailed information will be
available.  In contrast, however,  presumptive remedies identify
appropriate technologies for specific situations, regardless of
the response authority.   Similarly, when developing a final
response action that addresses lead problems, cleanup levels
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should consider health-based  levels developed witth  the  IEUBK for
both removal and  remedial actions.  The attached outlines provide
more detail on specific  implications fox actions under  removal
authority.

REGIONAL COORDINATION

     Each of the  five Regional Accelerated Response Centers in
OERR has designated several staff to serve as Regional
Coordinators for  the two Regions that each Center is designed to.
serve.  These staff are. specifically charged to work with the
Regions to resolve general and site-specific policy issues of
concern;, to provide the Regions with guidance, expertise,.and
national policy perspectives; to collect and analyze information
from the Regions  on program implementation, and to promote
Regional involvement in the development and implementation of new
Superfund initiatives.  Attached is a list of Headquarters staff
and their responsibilities for regional service.

     These Regional Coordinators will assist the Regions with. the.
implementation of these focus areas.  They can help ensure that
pertinent information regarding the focus areas (e.g., guidance,
directives)  is disseminated to the Regional staff and management.
They can also assist Regions in achieving.the specific goals for
focus areas by providing project managers with relevant
information or specific contacts with subject matter experts,  as
necessary.   Additionally, they will help Headquarters tracking
and/or evaluation activities that will be conducted to assess our
progress and tell our story.

OTHER IMPORTANT REGIONAL ACTIVITIES

     While much of OERR's communications with Regions will focus
on the areas described above, your continued attention to several
other program implementation goals is important.  Headquarters
will continue its support to help achieve those goals.  The
following list is intended to encourage the Regions to  implement
new guidances or  continue progress in the following areas:

•    Construction completions.  Over 800 of the.nearly  1300 NPL
     sites have remedies under construction or are  "construction
     complete."   OERR will continue to track construction
     completions.  OERR will assist the Regions by reviewing
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      closeout  reports and providing  assistance  in  accordance  with
      the  Construction Completions  Care  Package.

 •     Community involvement.  Communities  should be involved
      throughout the entire response  process,  for example  in
      developing land use assumptions.   Several  recently announced
      reforms provide new opportunities  to involve  the  public  in
      risk assessments and remedy decisions.

 •     Partial deletions.  A recent  policy  change (60  Federal
      Register  55466, November 1, 1995)  allows portions of' sites
      to be deleted before the remedy is completed  for  the whole
      site.  This tool may be useful  in  getting  sites or portions"
      of sites  back into productive use.

,•     CERCLTS III..  All Regions will.  begi". using CERCLIS III
      rather than CERCLIS II for program management activities by
      early summer.  .By late summer,  use of the  system  for all
      Tier I data will expand to other Regional  staff,  e.g.,
   ,   remedial  project managers  (RPMs), on-scene  coordinators,
      site assessment managers.

 •    Alternative approaches -to site  cleanup.  Given  the
      limit?"ions on site assessment  and listing sites,
     alternative approaches tOx site  cleanup may be appropriate,
     such as the use of voluntary cleanup programs,  removal
     authorities,  and state authorities.

HEADQUARTERS CONTACTS

For more information on regional coordination and  the  focus
areas, please  feel free to contact appropriate  staff of the
Accelerated Response Center associated with your Region,  as
provided in Attachment 2.                          .     •
The following list provides a key to the attachments.

ATTACHMENT 1:  . REGIONAL COORDINATION FOCUS AREAS
1)   Risk Management and Cost-effectiveness Decision
     Documentation	1.1
2)   Ground Water	1.4
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3)   Implementing Lead Policy	1.7
4)   Presumptive Remedies	1.10
ATTACHMENT 2 : REGIONAL COORDINATORS	2.1
Attachments

cc:   OERR Center Directors
     OERR Senior Process Managers
     Elaine Davies, OERR
     Larry Reed, OERR
     Gershon Bergeisen
     Jerry Clifford, OSRE
     Jim Woolford, FFRRO
     Kris Hoellen, ASTSWMO
     Sharon Jaffess, Region 2, Co-chair, NARPM
     Lesley Brunker, Region 3, Co-chair, NARPM
     Jay Bassett, Region 4, Co-chair, NARPM
     Shelley Brodie, Region 7, Co-chair, NARPM
     Carl Pelligrino, Region 2, Chair, NOSCA
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ATTACHMENT 1:  REGIONAL COORDINATION FOCUS AREAS

1)  Risk Management and Cost-effectiveness Decision Documentation

Why it is important:

•     Critical information. Risk and  cost are  two  critical pieces
      of information in deciding to take a response action,
      determining the appropriate scope of the action,  and
      ultimately selecting the response action.

.••    Criticism.  Program decision making has been criticized.
      This criticism may have been caused by our failure  to
      clearly explain the links between the risks  present at  sites
      and the response actions taken  to address them.   Similarly,
      the role of cost in our decisions may not have been
      presented clearly.  As a consequence, the program has taken
      severe criticism for making decisions that, are perceived as
      not cost-effective.  By focusing on improving the
      documentation of the role risks'and costs play in our
      decisions, we hope to improve the transparency of our
      decision-making and the public's trust in it.

•     Reauthorization.  Both Congress and the Administration  are
      examining the role of cost in Federal remediation programs.
      The reauthorization bills and EPA's Superfund. Reforms
      reflect increased scrutiny of the role of cost
      considerations in the Superfund remedy selection  process.
      Consistent decision making and documentation  of EPA's
      response selection has become more important  than ever.

Through this focus area we are highlighting the need to  make
sound and transparent risk management decisions and to encourage
the proper documentation .of those decisions, as well as  the
information used to make those decisions.

Key Messages for Region Action:

•     It is very important that Regional risk assessor  and risk
      managers (RPMs and OSCs) discuss site issues  and  coordinate
      efforts so that the response actions relate  to the  risks
      found at sites.                            .    .

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Clearly present risks that warrant action and clearly
demonstrate how the response will take care of these risks.

Decision documents  (i.e., RODs and action memoranda) should
explicitly identify the risks that warrant taking an action
and how the remedy will address those risks,  quantified to
the extent appropriate.

Use only reasonable exposure pathways for risk assessments.
While EPA remains committed to basing decisions on a
reasonable maximum exposure case, it is important to
remember that this is defined as the highest exposure that
is reasonably expected to occur.  Look carefully at the
exposure pathways of concern to ensure that the pathways
used to justify taking an action are reasonable (e.g.,
generally, residential land use of a landfill is not
reasonable unless that land use currently exists).

Clearly explain and clearly present the costs of the
selected response action and of alternative remedies
considere'd, 'and how the costs were balanced with other
tradeoffs in the presentation of the rationale for the
decision.  These should include a thoughtful consideration
of long-term operations and maintenance (O&M) costs.  It is
important that O&M costs are sufficiently considered so that
the States have a realistic .understanding of the O&M costs
they will be assuming.

Clearly state the benefits.  Although we perform cost-
effectiveness rather than cost benefit analysis in the
Superfund program, the decision document should clearly
identify the benefits of different alternatives in the nine
criteria analysis and the benefits of the selected response
action in the rationale for selection.  This includes the
risks and exposure pathways that will be addressed by the
remedy.  Nonquantifiable benefits, such as reuse of
brownfields,  should also be described.

EPA's effort to more clearly describe the role of cost does
not modify the already important role of cost in our
program.  Rather, these activities emphasize EPA being more
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     consistent and transparent when considering the costs of
     cleanup actions and what they are accomplishing.

Headquarters Action Items:

•    Review proposed plans, as they become available, or draft
     RODs to ensure that risk and cost data are clear and
     presented in a consistent manner nationally, and that
     decision rationales clearly discuss the role that cost and
     consideration of benefits considered under the other
     criteria played in the decision.  Action memoranda for large
     dollar removal sites will also be reviewed.  Exposure
     scenarios or risk assessment assumptions will also be
     reviewed for appropriateness and consistency.

•    Provide advice and national perspective to the Regions in
     the consistent implementation of guidance on presentation of
     risk and cost information in decision documents for FY 1996
     ROD decisions.

••    Continue the Interagency Workgroup on Cost-Effectiveness in
     the Superfund Remedy Selection Process,  which is developing
     "rules of thumb" in this area (expected late in FY 1996) ..

Key Guidance:                                 '       .  .       . .

•    "Interim Final Guidance on Preparing Superfund Decision
     Documents,"  OSWER Directive: 9355.3-02 (EPA 624/1-87/001),
     November 1989 (to be updated soon).

•    "Role of the Baseline Risk Assessment in Superfund Remedy
     Selection Decisions,"  OSWER Directive 9355.0-30, April
     1991.

•(    New guidance resulting from Superfund Reform initiatives
     should be available in the near future,  and will include the'
     following:
          Role of Cost Directive,
          Rules of Thumb, and
          ROD Summary Sheet/
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                         2)   Ground Water

Why it is important:

   •      Large number of ground-water RODs.  Ground-water RODs
          have consistently made up approximately two-thirds of
          the total RODs signed each year since the beginning of
          the program.                                  .

   •      Potentially high cost.  Ground-water remedies vary
          widely in cost, but can be quite high.

   •      Controversy.  Restoration of ground-water sites on the
          National Priorities List can be time- and resource-
          intensive.  These issues have lead to Congressional
          concerns about Superfund's 1) not matching cleanup
          objectives with specific problems at sites.; 2) alleged
          inconsistent remedy selection among Regions and sites;
          3) apparent lack of flexibility in remedy selection
          process.; and 4) incorporation of the latest
          developments being out of step with the "science."

Key messages for Regional Action:

•    Always evaluate the.likelihood of dense non-aqueous phase
     liquids (DNAPL) presence;

•    Always consider use of a phased (sequential) approach to
     remediation  (i.e., early/interim.actions preceding the final
     action) to reduce immediate risks and to help assess the
     long-term restoration potential of the site;

•'    Always consider the sources of flexibility available in
     ground-water remediation decisions:  Technical
     Impracticability  (TI)  ARAR waivers; longer remediation
     timeframes; natural attenuation; Alternate Concentration
     Limits (ACLs); and Ground-Water Classification/Future Use;

•--    Use Comprehensive State Ground Water Protection Program
     input if available to determine the classification of the
     impacted ground water.
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••    Integrate the future land and ground-water use scenarios
     into the overall site remediation objectives to ensure
     compatibility.

••    Recognize that use of pump and treat remedies may still be
     appropriate for achieving many remediation goals.

Headquarters Action Items:

•    Track number of remedy decisions employing phased approach,
     TI waivers,  natural attenuation, ACLs,  and other sources of
     flexibility.

•    Track estimated costs of ground-water remedies in RODs.

•    Consult with Regional staff on ground-water issues and
     record the number and type of consultations.

•    Qualitatively evaluate-level of awareness, interest, and use
     of guidance in Regions.

Key Guidance:

•-    "Estimating the Potential for Occurrence of DNAPL c.l
     Superfund Sites.," OSWER Directive:  9355.4-07FS, January,
     1992.

•    "Considerations in Ground Water Remediation at Superfund
     Sites and RCRA Facilities-Update,"   OSWER Directive 9283.1-
     06,  May 1992.                                   .

•    "Guidance for Evaluating the Technical Impracticability of
     Ground-Water Restoration," OSWER Directive 9234.2-25,
     September 1993.

•    "DNAPL Site Characterization," OSWER Publication 9355.4-
     1.6FS, September 1993.

•    New guidances under development that should be available in
     the near, future include the following:
          "Presumptive Response Strategy and Treatment
          Technologies for Contaminated Ground Water at CERCLA
          Sites"

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          "Consideration of  'Comprehensive State Ground Water
          Protection Programs' by EPA Remediation Programs"

Useful Background:

•••    "Guidance on Remedial Actions for Contaminated Ground Water
     at Superfund S.ites,"  OSWER Directive.: 9283.1-2, December
     1988.

• •    "Considerations in Ground Water Remediation at . Superfund
     Sites,"  OSWER Directive: 9355.4-03, October 1989.

•    "Suggested ROD Language for Various Ground Water Remediation
     Options,"  OSWER Directive: 9283.1-03, October 1990.

•-    "Methods for Monitoring Pump-and-Treat Performance," ORD
     publication EPA/600/R-94/123 .

•'    "Methods for Evaluating the Attainment of Cleanup Standards,
     Volume 2: Ground Water," EPA/230- R-92-014, July 1992.

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                  3)  Implementing Lead Policy

Why it is important:

•"-   Frequently occurring.  Lead is one of the most frequently
     occurring contaminants at Superfund sites.

•    Large and potentially costly sites.  Some types of sites
     that typically have lead contamination  (i.e., mining sites
     and smelters) are very large, and cleanup level decisions
     have significant cost implications.

•    Special methods developed.  Special methods for considering
     lead toxicity have been developed and must be followed.

•'•    Inconsistencies among sites.  H?A has been criticized for
     inconsistencies in setting site-specific lead cleanup
     levels.

•    Technically and emotionally complex.   Lead sites are
     technically complex and often have emotionally charged
     communities.   The many other potential sources of lead
     contamination (pipes,  lead-based paint)  complicate the
     issues, and may be beyond the scope of Superfund to address.

Key Messages for Regional Action:

•    Apply consistent methodology to set site-specific lead
     cleanup levels.   The IEUBK model should be used to assist in
     developing a cleanup level for all response actions with a
     residential land use,  unless time limitations associated
     with emergency or time critical removals prevents its use.
     It should be used with as much site-specific .data as
     possible;, at a minimum,  soil and house dust must be included
     in IEUBK application.   Cleanup levels should be consistent
     between the responses taken under removal and remedial
     authority to the extent possible.  .        .

•:    The  OSWER Interim Soil Lead Directive.(OSWER Directive:
     9355.4-12,  July 14,  1994)  is the current guidance and
     supersedes previous OSWER directives  on lead in soil.  A new
     memorandum,  "Administrative Reforms for Lead Risk


                             - 1.7 -                             .

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     Assessment"  (April  17, 1996) outlines specific steps to
     implement lead-policy.

•-   The Technical Review Workgroup of'Headquarters and Regional
     risk assessment experts provides assistance in implementing
     the IEUBK model.. Pat Van Leeuwen  (Region V, 312-886-4904)
     and Paul White  (Headquarters, 202-260-2589) are the co-
     chairs of the workgroup.

•    The 400 ppm screening level in soil is NOT A CLEANUP LEVEL,
     but provides a screening level appropriate for children in a
     residential setting.

••   'A soil concentration of 1000 ppm is not a priori an
     appropriate cleanup level for industrial sites.  The
     technical review workgroup can assist in developing an
     appropriate industrial cleanup level as well as levels
     associated with other land uses.

•    Factors such as lead species, chemical form, and
     bioavailability may need to be considered when developing
     risks and cleanup levels.  For example, mining wastes may be
     less bioavailable to children than other sources of lead.
     Good site-specific  information will be useful in determining
     bioavailability, lead speciation, and specific, chemical
     forms..

•    The large scale of  the problem at some sites will make
     removal or treatment impracticable.  Full soil removal may
     not be appropriate, especially at large sites.  Protective
     remedies may include exposure intervention to ensure cost-
     effective yet protective remedies.

•-•   Where there are multiple sources of lead; all sources of
     lead should be considered in determining appropriate cleanup
     responses.

Headquarters Action Items:

•-•   Identify lead si'tes and work with RPMs/OSCs to ensure that
     they understand the issues.
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     Review proposed plans to evaluate consistency with lead
     policy.
Key Guidance:

•    Revised Interim Soil Lead guidance for CERCLA sites and RCRA
     Corrective Action Facilities, OSWER Directive: 9355.4-12
     (PB94-963282),  July 14, 1994.  This reference contains the
     full reference for the IEUBK model and supersedes previous
    •OSWER lead guidances including Sept,  1989; May 9, 1990; and
     June ,1990..

•    Guidance  on Residential Lead-Based Paint, Lead Contaminated
     Dust,  and Lead-Contaminated Soil, (PB 94-962284), July 14,
     1994.  (This guidance from the Office of Toxic Substances
     addresses lead paint hazards.)

•    Administrative Reforms for Lead Risk Assessment,  April 17,
   ,  1996.
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                     4)   Presumptive Remedies

Why it is important:

•    Streamlined Investigation.  Presumptive remedies streamline
     site investigations and speed up the remedy selection
     process by reducing documentation and feasibility study
     requirements.

•    Fewer Arguments with Stakeholders.  In addition to
     significant cost and time savings in the RI/FS process,
     Superfund stakeholders have indicated that by our clearly
     presenting acceptable remedy preferences,  there will be less
     cause to argue over cleanup approaches.  This will result in
     better buy-in by states, local communities and PRPs.

••    Voluntary Cleanup.  Certain presumptive remedies may also
     promote more voluntary cleanups (e.g.,  manufactured gas
     plants).

•    Streamlines remedial design.  Additional savings can also be
     realized in the design phase,  as presumptive remedies can
     minimize or eliminate extensive data collection by
     anticipating and supporting design needs during th^ RI/FS
     process.

•    Reform Initiative.  Presumptive remedies have been
     identified as  both administrative improvements and reforms.

Key Messages for Regional Action:

•    Use presumptive remedy guidances at all sites where they are
     appropriate.  Presumptive remedy guidance is available for
     municipal landfills, volatile contaminants in soil,- and wood
     treaters.  User's Guides for RPMs are also available.

•    Involve stakeholders early  (e.g.,  community, state and local
     officials,  site owners and/or potentially responsible
     parties)  to familiarize them with the concept of presumptive
     remedies and how they will be used to streamline site
     response.
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•    Establish future land use assumptions and protective cleanup
     levels as part of the remedy selection process; they are
     developed independent of the application of a presumptive
     remedy.  At specific sites, the need to achieve protective
     levels consistent with anticipated land use may impact the
     application of specific presumptive remedies  (e.g.,
     protective levels associated with residential land use may
     preclude the use of biotreatment as one of the presumptive
     remedies at some woodtreater sites.

•    Recognize that some presumptive remedy guidances only
     address materials comprising "principal threats," while
     others are more comprehensive.

Headquarters Action Items:        .

•    Develop a questionnaire/survey instrument to evaluate the
     implementation of presumptive remedies,  both where they have
     been used and where they should have been used but were not
     used.  This survey may be an electronic evaluation form for
     use by site managers and may include telephone inquiries.
     OSWER's Federal Facilities Restorati6n and Reuse Office will
     address presumptive remedy use at Federal Facilities.

•    Track the implementation of presumptive remedies to ensure
     consistent 'application of the guidance.   Evaluations will be
     performed and results  circulated to communicate lessons
     learned.

•    Monitor the potential  application of presumptive remedies
     through the CERCLIS III database.

•'    Identify sites which should be employing presumptive
     remedies.  Inform those RPMs them about the use of the
     presumptive remedy, and provide information on where they
     can obtain additional  guidance- and support.

Key Guidance:

•<    "Presumptive Remedies: Policy and Procedures,"  OSWER
     Directive: 9355.0-47FS (PB93-963345),  September 1993.
                             -  1.11  -

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 "Presumptive Remedy for  CERCLA Municipal Landfill  Sites,"
 OSWER Directive:  9355.0-49FS  (PB93-963339),  September 1993.

 "Presumptive Remedies: Site Characterization and Technology
 Selection.for CERCLA Sites with Volatile Organic Compounds
 in Soil,"  OSWER Directive: 9355.0-48FS (PB93-963346),
 September  1993.

""Presumptive Remedies for Soils,  Sediments  and Sludges at  .
 Wood  Treater Sites,"  OSWER Directive:  9200.5-162
 (PB95-963410),  November  1995.

 New presumptive remedy guidances under development that
 should be  available in the near future include the
 following:

      Presumptive  Response Strategy and Treatment
      Technologies for Contaminated Ground Water at .CERCLA
      Sites
      Manufactured Gas Plants
      Sites  Contaminated  with PCBs
      Grain  Storage Sites.
                        - 1.12.-

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ATTACHMENT 2: REGIONAL COORDINATORS
REGION 1/9 ACCELERATED RESPONSE CENTER

     REGION 1 REGIONAL COORDINATORS:
          Mike Kurd	703-603-8836
          Charles Sands	703-603-8857
     REGION 9 REGIONAL COORDINATORS:
          Karen Bankert. .	703-603-9046
          Alan Youkeles	703-603-8784
     REMOVAL COORDINATORS:
          Richard Jeng	703-603-8749
          Art Johnson.	703-603-8705
REGION 2/6 ACCELERATED RESPONSE CENTER

     LEAD CONTACT FOR REGIONAL OPERATIONS
          JoAnn .Griffith	703-603-8774
     REGION 2 REGIONAL COORDINATORS - REMEDIAL PROGRAM
          Loren Kenning	703-603-8776
          Marlene Berg	703-603-8701
          Sherri Clark. . .	703-603-9043
     REGION '6 REGIONAL COORDINATORS - REMEDIAL PROGRAM
          Matt Charsky (lead)	.703-603-8777
          Sherri CLark. . .	703-603-9043.
          Karen Tomimatsu	 703-603-8738
     REMOVAL, SITE ASSESSMENT
          Terri Johnson	;	703-603-8718
     EMERGENCIES/OIL/BUDGET/PROGRAM MANAGEMENT
          Schatzi. Fitz-James	703-603-8725
     RISK ASSESSMENT, SITE ASSESSMENT
          Janine Dinan	703-603-8824
     ADMINISTRATIVE REFORMS
          Mike Goldstein	703-603-9045
     REMEDIAL DESIGN AND ACTION/O&M/RELOCATION/5 YEAR REVIEW
          JoAnn Griffith	 .703-603-8774
                             - 2.1 -

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REGION 3/8 ACCELERATED RESPONSE CENTER

REGION 3 REGIONAL SUPPORT TEAM
     EMERGENCIES/REMOVALS/OIL/ USCG
          Roxanna Mero   (lead)	703-603-9150
          Anne Spencer   (support)	703-603-8716
     REMEDY SELECTION  (includes RI/FS, RODs)
          David Cooper  (lead)	703-603-8763
          Lisa Askari  (support)	703-603-8799
          Shahid Mahmud  (support)	703-603-8789
     REMEDY IMPLEMENTATION  (Design and construction)
          Ken Skahn	703-603-8801
     BUDGET
          Anne Spencer  (lead) . . . .•	'. .703-603-8716
          Shahid Mahmud  (support)	703-603-8789
          Roxanna Mero  (support)	703-603-9150
     PROGRESS(SCAP, CERCLIS,Constuction Completion,  etc.)
          Rafael Gonzalez  (lead)	703-603-8892
          Susan Sladek  (support)	703-603-8848
     POST COMPLETION  (5  YEAR, O&M)
          Ken Skahn  (lead)	703-603-8801
          Susan Sladek  (support)	703-603-8848
REGION 8 REGIONAL SUPPORT TEAM
     EMERGENCIES/REMOVALS/OIL/USCG
          Anne Spencer  (lead) . . . .-	703-603-8716
          Shahid. Mahmud  (support) ..	703-603-8789
     REMEDY SELECTION  (includes RI/FS, RODs)
          Shahid Mahmud  (lead)	703-603-8789
          Lisa Askari  (support)	..703-603-8799
          David Cooper  (support)	703-603-8763
     REMEDY IMPLEMENTATION  (Design and Construction)
          Rafael Gonzalez  (lead)	.703-603-8892
          Ken Skahn  (support).	703-603-8801
    . BUDGET      '           '    -                      .
          Anne Spencer  (lead)	....703-603-8716
          Shahid Mahmud  (support)	703-603-8789.
          Roxanna Mero  (support) .•	703-603-9150
     PROGRESS  (SCAP, CERCLIS,Constuction  Completion,  etc.)
          Rafael Gonzalez  (lead)	703-603-8892
          Susan Sladek  (support) . . :	703-603-8848
     POST COMPLETION  (5  Year  review,  O&M)
          Ken Skahn  (lead)....,	703-603-8801
          Susan Sladek  (support)	703-603-8848

                              - 2.2 -

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REGION 4/10 ACCELERATED RESPONSE CENTER

     PRIMARY REGIONAL COORDINATION CONTACTS:
          John Blanchard	 703-603-9031
          Dan Thornton	703-603-8811
          Steve. Chang	703-603-8758
          Carolyn Kenmore	703-603-9033
          Richard Troast.(ROD review lead) ... 703-603-8805
     GENERAL EMERGENCY RESPONSE AND REMOVALS:
          Terry Eby	703-603-8741
        .  Greg Weigel	703-603-9058
REGION 5/7 ACCELERATED RESPONSE CENTER

     EMERGENCIES/REMOVALS
          REGION 5
               Ernie Watkins	703-603-9011
               Duane Geuder (backup) ......... 703-603-8891
          REGION 7
               Awilda Fuentes.	703-603-8748 .
               Bonnie Gitlin . (backup) ......... 703-603-8868
     EARLY r^IONS
          Andrea McLaughlin		703-603-8793
     SITE ASSESSMENT
          Scott Fredericks	703-603-8771
     RISK ISSUES        .
          Jack Arthur	;	703-603-9041.
     FS/ROD ISSUES (GENERAL)
          Robin Anderson. . .	'	703-603-8747
     GROUNDWATER   .
          Ken Lovelace	703-603-8787
     PRESUMPTIVE REMEDIES  •
          Scott Fredericks (OERR lead)	703-603-8771
          Andrea McLaughlin. (munic.  landfills) ... 703-603-8793
     FOCUS AREAS REVIEW POINT  OF CONTACT
          Bonnie Gitlin	703-603-8868
          (Specific sites will be assigned to other Regional Team
          members)
                             - 2,3 -

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REMEDIAL DESIGN / REMEDIAL ACTIONS ISSUES
     REGION 5
          Awilda Fuentes	703-603-8748
     REGION 7
          Ernie Watkins	703-603-9011
NATIONAL REMEDY REVIEW BOARD
     Bonnie Gitlin	703-603-8868
COST ESTIMATING
     Tom Whalen	703-603-8807
OPERATIONS AND MAINTENENCE
     Tom Whalen	•	703-603-8807
CONSTRUCTION COMPLETIONS
     Awilda Fuentes. .	703-603-8748
U.S. ARMY CORPS OF ENGINEERS LIAISON
     Bill Zobel	.	.,	202-761-5517
BUDGET COORDINATION
     Duane Geuder	703-603-8891
QA/QC,  DQOs
     Duane Geuder	 .703-603-8891
REPORTABLE QUANTITIES
     Jack Arthur (lead)	703-603-9041
     Dan Chellaraj  (AARP)	703-603-8706
 CONTINUOUS RELEASES
     Bob Cattell (AARP) . . . .	703-603-9054
   .  .Stan Barkin (AARP)	703-603-8987
                         - 2.4  -

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