United States
                Environmental Protection
                Agency
             Office of
             Solid Waste and
             Emergency Response
      &EPA
 DIRECTIVE NUMBER: 932C

 TITLE: Procgdures for Updating the National Priorities LIs



 APPROVAL DATE: May 23, 1984

 EFFECTIVE DATE: my 23 1994

 ORIGINATING OFFICE: OERR/HSCD

& FINAL

 D DRAFT

  STATUS:



 REFERENCE (other documents):

Supplemente 9320.1-02: Giudance for Establishing the NPL, ar
9320.3-01: Guidance for Updating the NPL
  OSWER       OSWER      OSWER
/E   DIRECTIVE   DIRECTIVE

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03/19/87 United States Environmental Protection Agency
Washington, O.C. 20460
EPA OSWER Directive Initiation Reques
2. Originator Information
Name of Contact Parson MaBCode Office
PARRISH OERR/HSCD
1. Directive Number
[ 9320.3-03

Telephone Number
382-5632
3. Title
j PROCEDURES FOR UPDATING THE NPL
1
4. Summary of Directive (Include brief statement of purpose)
!
Sets forth the process for developing updates to
the NPL; and presents the schedule for proposing
the second update; (1/84, ; 8 pp)
Supplements directives 9320.1-02', 9320.1-03 and
9320.3-01.
5. Keywords
'. SUPERFUND, CERCLA, NATIONAL PRIORITIES LIST, NPL, NPL UPDATING
PROCEDURE
6a. Does this Directive Supercede Previous Directives)?} | yes [ Xj No
b. Does It Supplement Previous Directives^)? [ X| yes | No Wr
. • , , 9320.]
7. Draft Level
A-SlgnedbyAA/DAA B - Signed by Office Director 1 C-ForRevte

This Request Meets OSWER Directives System Format
8. Signature of Lead Office Directives Coordinator
9. Name and Title of Approving Official
L. THOMAS
What directive (number, title)
lat directive (number, title)
.-02; 9320.3-01
w & Comment 1 1 In Development

Date
Date
05/23/84
OSWER    OSWER     OSWER
    DIRECTIVE    DIRECTIVE

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  '
  i
  /
 /
           UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                       WASHINGTON, D.C. 20460
MEMORANDUM
                             MAY 23 !°34
                                              °SWER Directive 9320.3-3
                                                        OFFICE OF
                                               SOLID WASTE AND EMERGENCY RESPONSE
TO:
                 retf forr/ Updating the National  Priorities  List

                 Thoma/'L
          Assistant Administrator
                                      •
          Regional Administrators
INTRODUCTION

     The Comprehensive Environmental Response,  Compensation  and
Liability Act of 1980  (CERCLA) requires  that  the  National  Priorities
List (NPL) be updated  at  least annually.   EPA published  the  first
NPL update of 133 sites as a proposed  rule on September  8, 1983,
and we plan to publish the final rule  for  those sites  in May
1984.  The next proposed  rule to update  the NPL is  scheduled for
August 1984.  The purpose of this memorandum  is to  set forth the
processes for developing  updates to the  NPL and present  the
schedule for proposing the second update.  This memorandum supple-
ments and revises guidance set forth in  the June  28,  1982, May 12,
1983, and May 17, 1983, guidance memoranda on the NPL.   The
scheduling for NPL site deletions is also  discussed,  and since
the second update will include Federal facilities,  the general
approach for identifying  and scoring Federal  candidate sites is
presented.
PROCESS FOR UPDATES

     We are revising the process  for updating  the  NPL  in  several
key ways.  Henceforth, rulemaking to update  the  NPL  will  be
proposed in the Federal Register  once per year in  late July  or
August.  Likewise, after completion of  the public  comment period
and review of comments, expected  to take about eight months  from
time of proposal, we will publish final rulemaking once per  year
Regions may submit new sites for  proposed rulemaking to update
the NPL at any time during the year.  In fact,  identifying and
scoring NPL candidate sites should be a routine  activity  that
develops from the Preliminary Assessment/Site  Inspection  (PA/SI)
programs in the Regions and States.  Headquarters  will conduct
quality assurance (QA) on a routine year-round basis as the
Regions submit sites except for that period  of time  when  the QA

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                               -3-
     Where a site consists, of regulated units of a RCRA facility
     operating pursuant to a permit or interim status, it will
     not be included on the NPL but will instead be addressed
     under the authorities of RCRA . . .  EPA does however
     consider eligible for listing on the NPL those RCRA facili-
     ties at which a significant portion of the release appears
     to come from "non-regulated units" of the facility,  that
     is, portions of the facility that ceased operation prior to
     January 26, 1983.

For clarification you should note that the off-site portions of
releases from RCRA-regulated operating units are not regulated
and are eligible for NPL listing once the releases have crossed
the facility (as defined under RCRA) boundaries.  For HRS scoring
purposes in such cases, values for "waste characteristics" and
other factors may be based on conditions at the RCRA-regulated
facility.


Emergency Actions

     Any site being considered as an NPL candidate should promptly
be evaluated for any possible emergency actions.  Of course,
results of HRS calculations for Direct Contact and Fire and Explo-
sion should also be considered in this evaluation.
Noncontiguous Facilities

     Current guidance via the Preamble to the final rule
(September 8, 1983) specifies that generally EPA scores sites and
lists them on the NPL individually.  The Preamble to the first
proposed update requested public comments on that policy, and the
Agency may consider alternate approaches.  However, for now the
Regions and States should refer to the September 8, 1983, Preamble
to the final rule in the Federal Register.


Rulemaking for Individual Sites

     On occasion the Agency may find that expeditious rulemaking
actions may be necessary for an extremely limited number of sites
(e.g., Times Beach), and the schedules for the annual update or
final rulemaking will not accommodate the Agency's needs.  In such
cases, where expeditious action is necessary to address human
exposure to toxic substances, the Regions should request that
proposed or final rulemaking be carried out independent of the
regularly scheduled rulemaking.  On making such a request the
Region should clearly specify the unique circumstances that
warrant a special rulemaking.

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                               -5-
     It is especially important to submit complete and legible
Documentation Records.  These are an important part of the
administrative record for the rulemaking.  Please recognize that
an inadequate administrative record can be grounds for the courts
to remand the listing of a site.  Packages containing incomplete
or otherwise unacceptable Documentation Records and other essential
documents will be returned to the Regions without further review.
Site Names

     When you select a site name choose one that most clearly
identifies a site.  For example, location (e.g. Onalaska Municipal
Landfill), the name of the business (e.g. Kin-Buc Landfill), or
a general description of the problem (e.g. Perham Arsenic).
Often you may want to avoid naming businesses which were not
associated with the site during the time the substances were
disposed or deposited.


Narrative Summaries

     Since narrative summaries of NPL sites are important tools .
used to inform members of Congress, the press, and the general
public, we want them to be consistent in the information they
contain.  To help you in this effort we are providing you with
a set of specific instructions for preparing narrative summaries
(attached).  We request that these instructions be followed so
excessive editing or re-typing can be avoided.  You should consult
with the States to ensure that the narrative summaries contain the
most current information possible.
SCHEDULE FOR THE SECOND UPDATE

     We have discussed this schedule and the procedures
previously described with your staff during the last several
months and they have seen earlier drafts of this memo.  Regional
submissions of candidate sites for inclusion on the second update
should have been submitted to Headquarters by May 1, 1984.  The
remaining schedule is as follows:

Quality Assurance (QA) completed	June 15, 1984

Proposed Rulemaking Published 	  August 1, 1984


     If you have any questions regarding the second NPL update,
please contact Joe Gearo (FTS-475-8103) of the Discovery and
Investigations Branch.

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 Hazardous waste site listed under the
 Comprehensive Environmental Response. Compensation, and Liability Act of 1980 (CERCLA)rSuperfund"
                        JOSLYN MANUFACTURING  &  SUPPLY  CC.
                              Brooklyn  Center, Minnesota


     Joslyn Manufacturing  &  Supply  Co.  treated  wood  on a  93-acre site adjacent  to
Twin Lakes In the urban community of Brooklyn Center,  Hennepln  County, Minnesota.
The plant, which operated  from 1920 to 1980,  used  processes  Involving creosote,
pentachlorophenbl, and copper-arsenic.   Before  the 1960s,  the plant  was  called
Consolidated Pole Treating Co. and  before  the 1940s, Naugle  Pole and Tie Co.

     In 1944, this facility  discharged Its waste water to  a  marshy area  connected
to Twin Lakes.  Later, an  unlined surface  Impoundment  adjacent  to the marsh was
used.  In the 1970s, an oil  reclamation unit  preceded  the  surface Impoundment.
In 1976, 216,000 gallons per year were discharged  to the  surface Impoundment.
Waste sludge has also been burled on the site.  A  number  of  nearby residential
wells and surface water sediment are contaminated  by pentachlorophenol and
creosote constituents.

    Joslyn completed a ground water investigation  in October 1981.-   In August
1983, Joslyn is scheduled  to start  excavating and  properly disposing of  2,300
cubic yards of pond sludge and several  hundred  cubic yards of contaminated soil.
The State is negotiating for additional  investigation  and  remedial actions.
 U.S. Environmental Protection Agency/Remedial Response Program

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