&EPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER: 9320.3-05
TITLE: National Priorities List Information Update #4
APPROVAL DATE:
EFFECTIVE DATE:
ORIGINATING OFFICE: OERR/HSCD
m FINAL
D DRAFT
STATUS:
REFERENCE (other documents):
OSWER OSWER OSWER
/E DIRECTIVE DIRECTIVE D
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03/19/87 united States Environmental Protection Agency
Washington, D.C. 20460
EPA OSWER Directive Initiation Requ<
2. Originator Information
Name of Contact Person Mall Cod* Office
PARRISH OERR/HSC
1. Directive Number
5St 9320.3-05
1
Telephone Number
D 362-5632
3. Title
NPL INFORMATION UPDATE #4
4. Summary of Directive (Include brief statement of purpose)
Provides background information on NPL Response
Category/Status Codes. (4/85, 6 pp)
5. Keywords
SUPERFUND, CERCLA, NATIONAL PRIORITIES LIST
PROCEDURE
6a. Does this Directive Supercede Previous Dlrectlve(s)?| | yes | *| No
b. Does it Supplement Previous Directives^)? ___ yes | £| N°
7. Draft Level
' • ' f
~" A-SlgnedbyAA/DAA ~~] B - Signed by Office Director C-ForF
This Request Meets OSWER Directives System Format
8. Signature of Lead Office Directives Coordinator
9. Name and THIe of Approving Official
R. WYER
, NPL, NPL UPDATING
What directive (number, title)
What directive (number, title)
leview & Comment 1 In Development
Date
Date
04/30/85
OSWER OSWER OSWER
DIRECTIVE DIRECTIVE
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\
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
APR 30
MEMORANDUM
OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE
OSWER Directive 9320.3-5
SUBJECT: NPL Information Update - Update J4
FROM: Russel H. Wyer, Director KZ*^\
Hazardous Site Control Division\
TO;
Director, Office of Emergency and Remedial Response
Region II
Director, Air & Waste Management Division
Regions III, IV, VII & VIII.
Director, Waste Management Division
Regions I & V
Director, Toxics and Waste Management Division
Region IX
Director, Air and Waste Division
Region X
Puroose
The purpose of this memorandum is to request each Region
to provide information for proposed and final NPL sites.
Specifically:
0 Revise categories/codes
0 Review narrative summaries
0 Identify RCRA-related sites
0 Identify mining-related sites
This information is needed to prepare the June 1985 NPL
update. This update will include promulgating Update #3 and
proposing Update 14.
Categories/Codes
The response categories (V, R, S, F, D) and cleanup
status codes (I, 0, C) are intended to provide the public with
information concerning the conditions existing at each site.
The codes are also an effective mechanism to indicate the
progress of the Superfund program. Specifically, we intend
to highlight the "C" cleanup status codes for the June 1985 ..
update.
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We have revised the response categories and cleanup
status codes (Attachment 1) to clarify the various designations
based on the experience of the last few NPL updates. We have
provided a list of currently proposed and final NPL sites
(Attachment 2). Please indicate the appropriate codes on
these sheets and return them to Harold J. Snyder, Jr., Chief,
Discovery and Investigation Branch, Hazardous Site Control
Division (WH-548E) by May 6, 1985.
Narrative Summaries
The narrative summaries are an important element of the
Agency's public information program for the NPL announcements.
The narrative summaries for sites previously proposed (Attach-
ment 3) must be revised to indicate current status and indicate
the appropriate response categories and status codes. Please
type (double spaced) the required information on the sheets
provided, obtain concurrences from office of Regional Counsel
and the appropriate Regional enforcement personnel, and return
the originals to Harold J. Snyder, Jr. by May 13., 1985.
We have also provided the edited narrative summaries for
proposed Update #4 (Attachment 4). Please review the summaries,
indicate appropriate codes, and provide any additional informa-
tion requested. These must also by reviewed and approved by
the Office of Regional Counsel and appropriate Regional
enforcement personnel. Please return the originals to
Harold J. Snyder, Jr. by May 13, 1985.
RCRA-Related Sites and Mining-Related Sites
The preamble to proposed Update S3 (50 FR 14115, April 10,
1985) described the Agency's intentions for a deferred listing
policy for RCRA-related sites. To develop a final policy, we
need to identify all RCRA-related sites as defined in the
preamble to Update #3 (Attachment 5) for currently proposed
and currently final sites.
Please use the various categories of RCRA-related sites
described in the preamble and indicate these sites on
Attachment 2. Please return Attachment 2 to Harold J. Snyder,
Jr. by May 6, 1985.
The preamble to proposed Update #3 also described the
Agency's decision to defer the proposal of a mining site in
Utah until the Agency and the Department of Interior determine
the ability of the Surface Mining Reclamation and Control Act
(SMCRA) to protect the public health, welfare, or the
environment at this site. In order to determine the number
of mining sites which may be affected by the authorities of
SMCRA, we need to identify all potentially mining related
sites on the currently proposed and currently final NPL.
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-3-
please indicate which sites are mining related on
Attachment 2 and return that attachment to Harold J. Snyder
jr. by May 6, 1985.
We
If you
382-5632)
appreciate your assistance in providing this information,
have any questions, please contact Scott Parrish (FTS-
o ^
Attachments
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NPL RESPONSE CATEGORIES/STATUS CODES
RESPONSE CATEGORIES
Response categories R, F, S, V, or D are used to denote the
type of responses underway. One or more categories apply to each
site, except for "D", which is-used alone.
R = Federal and/or State Response: This category includes sites
where EPA or State-agencies have commenced or completed
response actions defined under CERCLA [NCP, §300.66(f}-(i )
47 FR 31217, July 16, 1982]. These may include:
Removal actions
Nonenforcement remedial investigations/
feasibility studies
Initial remedial measures
Remedial actions.
For purposes of categorization, the response action commences
when EPA obligates funds. The "D" category applies to actions
taken independently of EPA and/or the State -'(i.e., local
agencies and responsible parties).
F = Federal Enforcement
- The
This
Deoartment of
category includes sites where:
Justice has filed a civil complaint
(including cost recovery 'actions)
Issued an administrative order under CERCLA or RGRA
A Federal court has mandated some form of response
action following a judicial proceeding
EPA has obligated funds for enforcement-lead remedial
investigations/feasibility studies.
A number of sites on the NPL are the subject of legal investi-
gations or have been formally referred to the Department of
Justice for enforcement action. EPA's policy is not to release
information concerning a possible enforcement action until a
lawsuit has been filed. Accordingly:
- Sites subject to pending Federal action are not included
in this category, but are included under the "D" category.
The "D" category should also be assigned where:
- A Federal legal action has been initiated under
authorities other than CERCLA or RCRA.
S = State Enforcement; This category includes sites where:
A State has filed a civil complaint or issued an
administrative order under CERCLA or RCRA
A State court has mandated some form of response
action following a judicial proceeding
A State has obligated funds for enforcement-lead
remedial investigations/feasibility studies.
It is assumed that State policy is to not release information
concerning possible enforcement actions until such action has
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been formally taken. Accordingly:
- Sites subject to pending State legal action are not
included in this category, but are included under the "D"
category.
The "D" category should also be assigned where:
— ••
- A State legal action has been initiated under authorities
other than CERCLA or RCRA.
V = Voluntary or Negotiated Response; This category includes
sites where responsible parties are taking, or have completed,
response actions"pursuant to consent orders consent decrees,
or consent agreements to which EPA and/or the State is a
party. Usually the response actions result from a Federal
or State enforcement action. Response actions covered by
such orders, decrees, or agreements include:
Removal actions
Remedial investigations/feasibility studies
Initial remedial measures
Remedial actions.
The "D" category applies to response actions not covered by
such orders, decrees, or agreements.
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
An enforcement action may be under development
A Federal or State legal action has been initiated
under authorities other than CERCLA or RCRA.
Responsible parties may be undertaking cleanup
actions that are not covered by a consent order,
consent decree, consent agreement, or administrative
order.
Federal Facilities
Assign the response category "R" to Department of Defense
facilities where at least Phase II of the Installation Restoration
Program is underway or has been completed.
Apply usual "R" criteria to other Federal facilities.
CLEANUP STATUS CODES
Sites, both Federal and non-Federal, where actual cleanup
activities are underway or completed will also be coded to desig-
nate the status of cleanup activities. (Sites where only remedial
investigations/feasibility studies are underway will not have a
status code). Response activities to be coded include:
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Significant removal actions, initial remedial measures,
source control remedial actions, and off-site remedial
actions financed by the Fund
Similar cleanup activities conducted by responsible
parties under a consent order, decree, or agreement,
court order, or administrative order
Similar cleanup activities taken independently of EPA
and/or the State.
Many sites 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 actions such
as building fences and berms which do not eliminate a significant
release, threat of release, or pathway of exposure 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.
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.
0 = Implementation activities are completed for one or more
operable units; Implementation activities may be underway
for additional operable units, but further cleanup actions
are necessary.
C = Implementation activities are completed for all operable •
units:The approved remedy has been implemented."All actions
agreed upon for remedial action at the site have been completed
and performance monitoring has commenced. The site will be
considered for deletion from the NPL subsequent to the comple-
tion of performance monitoring and preparation of a deletion
recommendation. Further site activities could occur if EPA
considers such activities necessary.
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