&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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                              -2-
      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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