&EPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER:
TITLE: National Priori tie
APPROVAL DATE: Juiy 17,
EFFECTIVE DATE: Juiy 17,
ORIGINATING OFFICE: OERR/HSOD
£3 FINAL
D DRAFT
STATUS:
REFERENCE (other documents):
OS WER OS WER OS WER
/E DIRECTIVE DIRECTIVE Di
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03/19/87 United States Environmental Protection Agency
Washington, D.C. 20460
EPA OSWER Directive Initiation Request
2. Originator Information
Name of Contact Person MsHCode Office
PARRISH OERR/HSCD
1. Directive Number
9320.1-04
Telephone Number
382-5632
3. Title
NATIONAL PRIORITIES LIST CATEGORIZATION
i
, 4. Summary of Directive (Include brief statement of purpose)
Develops status codes to denote sites 'where
significant response activities are underway or
> , completed. Status codes will be included in
updated NPL in response to public requests for
information regarding actual site cleanup
Activities. (7/84, 7 pp) ,
i
5. Keywords
SUPERFUND, CERCLA, NATIONAL PRIORITIES LIST, NPL,
PROCEDURE
,NPL LISTING,
6a. Does this Directive Supercede Previous Dlrectlve(s)?| | yes | X| No What directive (number, title)
1 'i
b. Does it Supplement Previous Directives^)? | yes X No What directive (number, title)
i
7. Draft Level
A-SlgnedbyAA/DAA B • Sorted by Office Director 1 C • For Review & Cc
This Request Meets OSWER Directives System Format
. signature 01 Lean omce Dwectives coorainaior i
•
i
i
9. Name and Title of Approving Official (
W. HEDEMAN
xiiTient In Development
)ate
)ate
07/17/84
OSWER OSWER OSWER
DIRECTIVE DIRECTIVE
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/**_"•>/•
,*
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
JUL I T 1934
S--.-VVASTEANOEM = = :••.:• °ES- :--.:r
MEMORANDUM
SUBJECT:
FROM:
TO:
National Priorities List Categorization
William N. Hedeman, Jr., Direct
Office of Emergency & Remedial
Director, Office of Emergency Response
Region II
Director, Air & Waste Management Division
Regions III, IV, VI, VII, & VIII
Director, Waste Management Division
Regions I & V
Director, Toxics & Waste Management Division
Region IX
Director, Air & Waste Division
Region X
Prior categorization of the National Priorities List (NPL)
sites has focused on the type of response at each site (fund-
financed, enforcement and/or voluntary action.) The NPL Update 12
will be the first update to expand the prior categorization system
in two ways. First, Federal enforcement actions will be separated
from State enforcement actions. Secondly, the status of actual
cleanup actions at sites will be designated by three new cleanup
status codes. The status codes have been developed to denote
sites where significant response activities are underway or complet-
ed. The status codes will be included in the updated NPL in response
to public requests for information regarding actual site cleanup
activities.
Attached is the guidance for the revised categorization of
final and proposed sites on the NPL. Also included is a copy of
the format developed for site-specific categorizations. We are
currently working with the Office of Waste Programs Enforcement
to initially evaluate all sites for revised categorization. We
will then forward the forms showing our draft categorizations to
you for review. Any necessary corrections may be made directly
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on these forms. Please be prepared to provide updated informa-
tion regarding negotiated response actions, State response actions
and State enforcement actions since our information for these
projects is often limited. The categorizations should be determined
based on the status of sites as of August 15, 1984.
We will send our draft categorizations to you by July 20,
1984. We will need your final revisions by August 3, 1984, so
that the second update of the NPL can be published on schedule.
Please send your submissions directly to the Hazardous Site
Control Division.
Thank you for your assistance. For additional information
or clarification, please contact the following:
Kitty Taimi - Hazardous Site Control Division (382-2449)
Hans Crump - Emergency Response Division (382-2188)
Barbara Elkus - Office of Waste Programs Enforcement (382-4819)
Attachment
cc: Fred Stiehl, OEC
Dan Berry, OGC
Frank Biros, OWPE
Hans Crump, ERD
Hal Snyder, HSCD
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NATIONAL PRIORITIES LIST CATEGORIES
Prior categorization of the NPL sites has focused on the
type of response at each site (fund-financed, enforcement and/or
voluntary action). Future updates to the NPL will expand the prior
categorization system in two ways. First, Federal enforcement actions
will be separated from state enforcement actions. Secondly, the
status of site actions will be designated by three new cleanup
status codes. The status codes have been developed to denote
sites where significant response activities are underway or
completed. The status codes will be Included in the updated
NPL in response to public requests for information regarding
actual site cleanup activities.
RESPONSE CATEGORIES
The following response categories are used to denote the
type of responses underway. One or more categories apply to each
site.
V • Voluntary or Negotiated Response; Sites are included
in this category if private parties are taking, or have
completed, response actions pursuant to consent orders or
consent decrees to which EPA and/or the State is a party.
This category may include privately-financed
remedial planning, removal actions, initial remedial
measures,and/or remedial actions*
R » Federal and/or State Response; The Federal and/or State
Response category includes sites at which EPA or State
agencies have commenced or completed response actions.
These may include removal actions, non-enforcement remedial
planning, initial remedial measures and/or remedial actions as
defined under CERCLA [NCP, 5300.66 (f)-(i) 47FR 31217, July 16,
1982] . For purposes of categorization, the response
action commences when EPA obligates funds.
F • Federal Enforcement: This category includes sites where
the United States has filed a civil complaint (including
cost recovery actions), or issued an administrative order.
It also includes sites at which a Federal court has
mandated some form of response action following a
judicial proceeding. All sites for which funds have been
obligated for enforcement-lead remedial investigations
and feasibility studies are also included in this category.
A number of sites on the NPL are the subject of legal
investigations or have been formally referred to the
Department of Justice for enforcement action. EPA's policy
is not to release information concerning a possible enforce-
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ment action until a lawsuit has been filed. Accordingly,
these sites are not included in this category, but are
included under "Category To Be Determined".
S « State Enforcement: This category includes sites where a
State has filed a civil complaint or issued an administrative
order. It also includes sites at which a State court
has mandated some form of response action following
a judicial proceeding. Sites where States have obligated
funds for enforcement-lead remedial investigations and feasibility
studies are underway are also included in this category.
It is assumed that State policy is to not'-release
information concerning possible enforcement actions until
such action has been formally taken. Accordingly, sites
subject to pending State legal action are not included
in this category, but are included under "Category To Be
Determined".
D » Category To Be Determined; This category includes
all sites not listed in any other category. A wide range
of activities may be in progress at sites in this category.
EPA or a State may be evaluating the type of response action
to undertake, a response action may be determined but funds
not yet obligated, or an enforcement case may be under
development. Responsible parties may be undertaking
cleanup actions that are not covered by a consent
decree, consent order, or an administrative order.
CLEANUP STATUS CODES
Sites where actual cleanup activities are underway or
completed will also be coded to designate the status of cleanup
activities. (Sites where only remedial planning work is underway
will not have a status code.) Fund-financed response
activities to be coded include significant removal actions,
initial remedial measures, source control remedial actions and
off-site remedial actions. The status of cleanup activities
conducted by responsible parties under a consent decree, court
order, or an administrative order should also be coded.
Many sites listed on the NPL are cleaned up in phases, or operable
units. For purposes of status coding, an operable unit is
a discrete action taken as part of the entire site cleanup
that significantly decreases or eliminates a release, threat
of release, or pathway of exposure. One or more operable units
may be necessary to complete the cleanup of a site. Operable units
may include significant removal actions which stabilize deteriorating
site conditions or provide alternative water supplies, initial remedial
measures, and remedial actions. Simple removal actions
(fences, berms or lowering freeboard) which do not eliminate
a significant release, threat of release or pathway of exposure
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are not considered operable units for purposes of status coding.
The following codes denote the status of actual cleanup
activities at sites. Only one status code will apply to a
site where cleanup actions have been initiated. Examples of
sites categorized and coded for status are given after the
code definitions.
I » Implementation Activities Are Underway For One Or More
Operable Units: Field work is in progress at the site for
implementation of one or more removal or remedial operable
units, but no operable units are completed.
O • One Or More Operable Units Are Completed. Implementation
Activities May Be Underway For Additional Operable Units.
Field work has been completed for one or more operable
units, but additional site cleanup actions are necessary.
C • Implementation Activities For All Operable Units Are
Completed: The approved remedy has been implemented. All
actions required to clean up the site have been completed
and a final construction inspection/certification report
has been approved. Performance monitoring has commenced
preparatory to deletion of the site from the NPL.
Further site activities could occur if field conditions
change.
SITE EXAMPLES
Site Name/State Category
Response Cleanup
1) Berlin i Parro Site, MI R F V
Explanation:
R * Federal and State Response; removal,
remedial planning and remedial actions
have been taken at the site by both EPA
and the State.
F « Federal Enforcement; a Federal
Status
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enforcement-lead remedial investiga-
tion/feasibility study is being
conducted at this site.
V • Voluntary or Negotiated Response;
responsible parties have initiated
remedial response actions.
O « One remedial operable unit has been completed
Responsible parties have implemented a second
operable unit.
Response Cleanup
Site Name/State Category Status
2) Swope Oil Site, N.J. R V
Explanation:
R • Federal and State Response; a
Federal-lead remedial investigation/
feasibility study is ongoing
at this site.
V » Voluntary or Negotiated Response;
the responsible parties have
initiated reponse actions.
I » Implementation activities are under-
way for one operable unit conducted
by responsible parties.
Response
Category
3) Price Landfill, N.J. R F
Explanation:
R • Federal and State Response; State-
lead remedial planning activities
and remedial actions are underway.
F * Federal Enforcement; litigation has
commenced.
I » Implementation activities are underway
Cleanup
Status
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for «n operable unit to provide alternative
water supplies.
Response
Site Name/State Category
4) Byron Salvage Site, IL.
Explanation:
R • Federal and State Response;
State-lead remedial planning
is underway.
I • Implementation activities are
underway for one operable unit
(removal action to provide
alternative water supplies.)
Cleanup
Status
SCHEDULE FOR REVISING NPL CATEGORIZATION
The following schedule for revision of NPL sites categorization
is necessary in order for the NPL Update 12 to be published on
schedule.
• Revise NPL site categorizations 7/19/84
in Headquarters according to
available information.
• Send draft categorizations of sites 7/20/84
to Regions for review.
* Regions submit categorizations to 8/03/84
Headquarters with revisions/corrections.
* BO prepares final categorizations 8/15/84
of sites for NPL Update 12 Red
Border Review.
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