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DIRECTIVE NUMBER:
9345,2=02
• ITLE: Regional Pre-remedial Program Objectives For
FY-89 and First Quarter FY-90
APPROVAL DATE:
EFFECTIVE DATE:
ORIGINATING OFFICE:
GT FINAL
3/10/89
3/10/89
EET
D DRAFT
STATUS:
I
A- Pending OMB approval
B- Pending AA-OSWER approval
C- For review &/or comment
I ] D- In development or circulating
REFERENCE (other document*): headquarters
(
DIRECTIVE DIRECTIVE
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ed St
gency
wasnttgion. OC 204«0
OSWER Directive initiation Request
Directive Numotr
9345.2-02
2. Originator Information
Name of Contact Person
Carolyn Previ
Code
OS-230
[Office
I HSED
Tsiepnore Coat
3. Title
Regional Pre-Remedial Program Ojbectives for FY-89 and First Quarter FY-90
4. Summary oi Directive (inauae onet statement of purpose) ~
Provides instructions for implementing the REgional pre-remedial program during the
transition period between proposal and promulgation of the revised Hazard Ranking
System (MRS).
*eyv,oros Superfund,CERCIA,SARA
Dots This Oirecuve Supersede Previous OweetJve(s)?
b. Does It Supplement Previous Oirective(s)?
. I I I
X NO - _
Vee What directive (number, title)
IT/"! f~~I
IX I No I _ I Yt> Wn« directive (number.
oran Level
A - Signed by AA/OAA
8 - Signed by Office Director
i - Par Review A Comment
DB-
8. Document to b« distributed to States by Headquarters?
i/
Yes
No
Tnl« Requeat Meeu OSWgH Qlreetlvee Syitem Format SUndarda.
9. Signature of Lead Office Directives Coordinator
Betti C. VanEpps
Date
3/10/89
10. Name and Title of Approving Official
Henry L. Longest II, Director OERR
lOate
3/10/889
EPA Form 1315-17 (Rev. 5-97} Previous editions are oosoiete.
OSWER OSWER OSWER O
VE DIRECTIVE DIRECTIVE DIRECTIVE
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
MAR I 0 I939
OFFICE OF
SOLID WASTE AND EMERGENCY RESPONSE
MEMORANDUM
SUBJECT: Regional Pre-remedial Program Objectives for FY 89 and
First Quarter of FY 90 (OSWER Ditecfkve 9345.2-02)
FROM:
TO:
Henry L. Longest II, Director
Office of Emergency and
Directors, Waste Management Division
Regions I, IV, V, VII, and VIII
Director, Emergency and Remedial Response Division
Region II
Director, Hazardous Waste Management Division
Regions III and VI
Director, Toxic and Waste Management Division
Region IX
Director, Hazardous Waste Division, Region X
PURPOSE
I am transmitting the subject document for your use in
implementing the Regional pre-remedial program during the
transition period between proposal and promulgation of the revised
Hazard Ranking System (HRS) .
BACKGROUND
This document updates earlier documents entitled, "Pre-Remedial
Strategy for Implementing SARA" (OSWER Directive 9345.2-01;
February 12, 1988) and "Pre-Remedial Priorities" (Memo from Longest
to Division Directors, April 4, 1988).
OBJECTIVES
The overall goal of Regional pre-remedial activity will be to
maintain momentum in evaluating sites for inclusion on the National
Priority List, while gradually factoring in the new requirements of
the revised HRS. Specifically, six Regional objectives are
outlined:
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1) Continue EPA's policy of conducting preliminary assessments
(PA) within one year of CERCLIS listing in order to prevent the
build-up of a PA backlog;
2) Maintain site inspection (SI) momentum during the transition to
the revised HRS, stressing commitment to completing pre-SARA sites
within the context of "worst sites first";
3) Review all completed Sis to determine which sites require
listing site inspections (LSIs) or the development of HRS listing
packages, i.e., "SI reassessment";
4) Enter all pre-remedial decisions/priority recommendations at
each step of the evaluation process and all appropriate identifiers
(RCRA, Federal facilities, Indian lands, etc.) into CERCLIS as
rapidly as possible to facilitate overall program planning and to
expedite response to Congressional and public inquiries;
5) Gradually phase in use of the revised HRS in all parts of the
pre-remedial process as data collection requirements become more
clearly defined; and
6) Assist Headquarters to finalize some 400 currently
proposed NPL sites by providing input to EPA's response-to-comment
activity.
IMPLEMENTATION
The attached document contains implementation guidance to help
you address the above objectives. Please review this guidance
carefully and apply it to your pre-remedial efforts over the next
year.
CONTACTS
I would like to thank you and your staff for providing many
helpful comments on our previous draft. Please call Penelope
Hansen (FTS 382-6357), if you have questions regarding this
document.
Attachment
cc: Superfund Branch Chiefs (Regions I-X)
Betti VanEpps
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REGIONAL PRE-REMEDIAL PROGRAM OBJECTIVES FOR
FY 89 AND FIRST QUARTER OF FY 90
PURPOSE:
This document contains the Office of Emergency and Remedial
Response (OERR) pre-remedial objectives for EPA Regions during the
transition period between proposal and promulgation of the revised
Hazard Ranking System (HRS). The period is expected to encompass
the remainder of FY 89 and the first quarter of FY 90. The
document updates earlier documents entitled, "Pre-Remedial
Strategy for Implementing SARA" (OSWER Directive 9345.2-01;
February 12, 1988) and "Pre-Remedial Priorities" (Memo from Longest
to Division Directors, April 4, 1988). Additional background
information related to FY 89 objectives is found in Tables 1 and 2
of this document.
BACKGROUND:
On January 1, 1988, EPA accomplished the SARA preliminary
assessment (PA) goal of completing PAs on all pre-SARA sites.
Meeting the PA completion goal was our major pre-remedial
achievement of FY 88. The next SARA pre-remedial goal was to
complete site inspections (Sis) as warranted, at all pre-SARA
sites by January 1, 1989. Due to resource constraints, most
Regions were not able to meet the similar SI goal. We offer
congratulations to Regions VI and X who, through an extraordinary
effort, were able to achieve the SI goal.
We have made, and must continue to make, good-faith efforts to
reduce the pre-SARA SI backlog as expeditiously as possible. We
have made notable progress in defining the scope and distribution
of the SI backlog for both pre- and post-SARA sites through the
Region's efforts in the PA Reassessment Project. (Statistics from
this project are now being compiled on a Region by Region basis and
will be published in the Agency's Report to Congress on the SI
backlog.) Preliminary findings indicate that a large number of
pre-SARA sites needing Sis are found in the five eastern Regions.
A specific strategy to address this problem is discussed elsewhere
in this document.
On December 23, 1988, the Agency proposed revisions to the HRS.
Final promulgation is presently scheduled for January 1990. We are
now beginning a gradual transition from use of the current HRS to
the revised HRS. The current HRS will continue to be used in
proposing and finalizing sites on the NPL until the revised HRS is
promulgated.
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In order to obtain data on implementing the revised HRS and to
furnish Regions with a working knowledge of the proposal, OERR has
sponsored an extensive nationwide field testing program involving
each Regional office and its Field Investigation Team (FIT)
contractors. More than 100 sites have been evaluated under Phase I
and Phase II of the field test. The Phase I testing of the revised
HRS was performed to identify both technical and implementation
issues with the proposed model; Phase II testing focuses on finding
ways to maximize the efficiency of each step of the pre-remedial
process, i.e., PA, SSI and LSI, and identifies the necessary LOE
required to perform these steps. The results and lessons learned
from the test will soon be made available under separate reports
covering all phases of the project. These documents will both
report the results of the field test and suggest ways to optimize
the process based on test results.
In addition, we are refining the development of a computerized
PreScore program using the revised HRS through distribution of
interim versions for use and comment by the Regions. After the*
revised HRS is promulgated, Headquarters will offer formal' training
on its application to PAs, SSIs, listing site inspections (LSIs),
and the preparation of listing packages for sites being proposed to
the NPL. Prior to that time, we encourage the Regions to provide
informal training utilizing those Regional/FIT personnel
experienced in the Phase I and Phase II field testing when it is
feasible to do so.
Headquarters will periodically sponsor Pre-remedial Workgroup
Meetings, and other national meetings as needed to address
transition issues. Further interim information/guidance memos will
be prepared and distributed as warranted. However, all of us must
communicate our pre-remedial objectives and strategy in a manner
that will result in building public confidence in our program.
OBJECTIVES:
The Regional objectives of the pre-remedial program for FY 89
and the first quarter of FY 90 are as follows:
I) Continue EPA's policy of conducting preliminary assessments
(PA) within one year of CERCLIS listing in order to prevent the
build-up of a PA backlog;
2) Maintain site inspection (SI) momentum during the transition to
the revised HRS, stressing commitment to completing pre-SARA sites
within the context of "worst sites first";
3) Review all completed Sis to determine which sites require
listing site inspections (LSIs) or the development of HRS listing
packages, i.e., "SI reassessment";
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4) Enter all pre-remedial decisions/priority recommendations at
each step of the evaluation process and all appropriate identifiers
(RCRA, Federal facilities, Indian lands, etc.) into CERCLIS as
rapidly as possible to facilitate overall program planning and to
expedite response to Congressional and public inquiries;
5) Gradually phase in use of the revised HRS in all parts of the
pre-remedial process as data collection requirements become more
clearly defined; and
6) Assist Headquarters to finalize some 400 currently proposed NPL
sites by providing input to EPA's response-to-comment activity.
IMPLEMENTATION:
Specific comments concerning different components of pre-
remedial activities covered by the above objectives are provided
below:
PRELIMINARY ASSESSMENTS (Objective #1);
Having met the SARA PA goal, we are now in a "steady-state"
situation in which PAs are performed on sites within a year of
their entry in CERCLIS (the one-year turn around time is required
by SARA for PA petition sites and has been extended by Agency
policy to all sites.) We intend to maintain this steady-state
situation to prevent the build-up of a new PA backlog. For FY 89,
this means meeting the Regional SCAP target of completing 2,500 PAs
nationwide, which include approximately 800 - 1,000 EPI sites.
EPI sites are RCRA Subtitle C storage and treatment facilities
and/or closing RCRA land disposal facilities. The PAs for EPI
sites should be similar to the PAs for CERCLA sites in terms of the
way they are conducted, the level of effort, and the criteria used
to recommend or not recommend continued evaluation through an SI.
The specific number of PAs to be conducted on EPI sites over the
next three years is at each Region's discretion. (See Porter's
EPI memos of 5/31/88 and 1/31/89.)
There are three possible recommendations at the completion of a
PA:
o No further remedial action planned (NFRAP) - those sites with
no reasonable potential to score above the HRS cutoff (States must
be informed of these findings and the sites may be reactivated if
additional data are forthcoming indicating potential risks. If
applicable, Regional EPI coordinators should also be informed of
NFRAP decisions.)
o Medium priority SI - those sites with a potential to score
above the HRS cutoff and recommended for an SI; and
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o High priority SI - those sites likely to score above the HRS
cutoff and recommended for an SI.
EPI facilities should be evaluated and recommended for an SI
according to the same criteria as all other sites. As a reminder,
a PA is not completed for SCAP purposes until one of the above
recommendations has been entered into CERCLIS.
SITE INSPECTIONS (Objective #21;
Regions VI and X have recently achieved the SARA-mandated goal
of completing Sis on all pre-SARA sites requiring them. The other
eight Regions are at various stages of addressing their pre-SARA SI
backlogs. It is our goal to have as few remaining pre-SARA sites
needing Sis as possible at the time of Superfund re-authorization.
This will require a substantial workload for Regions 1-5 over the
next few years. During FY 89, however, our policy on SI priority
remains as it has always been: "worst sites first1*. Sites that,
in the Region's best professional judgment, pose the most serious
environmental threat should be addressed first, no matter what date
they were placed in CERCLIS. For sites of similar perceived risk,
however, we encourage the Regions to preferentially select those
sites that were placed in CERCLIS prior to SARA date of enactment.
The final mix of sites selected for FY 89 SSIs is at the Region's
discretion, noting that EPI sites recommended for an SSI should be
included in the mix as well.
The SI SCAP target in FY 89 is 1250 SI completions nationwide.
This target should be readily achievable by the Regions if they:
1) continue to use the current HRS as the primary evaluation
mechanism, where appropriate, through the earlier part of the
transition period; gradually adding elements of the revised HRS as
guidance is forthcoming;
2) encourage State participation in all phases of the pre-remedial
program where practicable, while effectively monitoring State
outputs and resource allocations; and
3) continue to efficiently utilize FIT resources by directing
their assignments toward "core" pre-remedial activities, i.e., the
bulk of assignments is always the SI category.
There are three possible of SSI decisions at the completion of
an SI:
o NFRAP (Region should inform the appropriate State of this
finding);
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o Deferral to another authority (This indicates that the site has
the potential to score above the cutoff score for NPL listing but
the release could be more effectively addressed by another statute
or authority, i.e., RCRA Subtitle C or the Nuclear Regulatory
Commission. EPA is soliciting comments on additional deferral
authorities in the 12/21/88, proposed National Oil and Hazardous
Substances Pollution Contingency Plan (NCP)); and
o Recommended for an LSI. Similar to the decision-making
process at the end of a PA for an SI recommendation, the LSI
recommendation is predicated on the projected revised HRS score
which does not entail "HRS documented" data. (Remaining issues
such as whether a site may proceed directly into the NPL listing
process at the SSI stage, without an LSI, will be decided later
this year. For now, the assumption is made that sites likely to be
listed under the revised HRS will receive LSIs, although there will
be exceptions.)
LISTING SITE INSPECTIONS;
As shown in Table 2, 75 LSI starts are part of the FY 89 SCAP
goals. By definition, an LSI start is a Regional approval of a
full scale workplan covering different elements of an LSI. LSIs
are performed at sites that appear to be likely candidates for
listing on the NPL (i.e., sites with projected revised HRS scores
above the cutoff.) The primary objective of an LSI is to acquire
the data needed to support an NPL listing (i.e., a documented HRS
package).
We recognize that there are inherent difficulties regarding LSI
SCAP measure for FY 89. First, the revised HRS will not be
promulgated until FY 90. Second, LSIs are extensive undertakings
with considerable lead time and planning required; but the final
form of the revised HRS for which LSI data are to be collected is
not exactly defined at this time. Headquarters recommendations to
resolve these dilemmas are as follows: (1) Planning and
performing FY 89 LSIs should maximize use of the proposed revised
HRS. However, no final HRS packages should be prepared. (2) LSI
planning should retain as much flexibility as practicable to
accommodate modification of the revised HRS as it moves from
proposal to promulgation. (3) Unique and costly field activities
(e.g., fish tissue sampling, extensive soil/source sampling to
document constituent waste quantity) are not encouraged and should
not be routinely approved.
SI REASSESSMENT PROJECT (Objective 3);
Just as the PA reassessment process enabled us to establish our
pre- and post-SARA SSI backlogs (and supplied vital information for
the Agency's Report to Congress). we also need to know our LSI
backlog. in preparing for the reauthorization debate, it is
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imperative that we know our workload for FY 90 and beyond. To this
end, we ask that Regions evaluate the SI files for which an SI has
been performed, but no decision entered into CERCLIS, to determine
the SSI recommendation (i.e., NFRAP, deferred to another authority,
or recommended for an LSI), and enter the decision into CERCLIS.
An SI reassessment is an one-time exercise in FY 89 to decide
whether a site with a completed SI should be recommended for an
LSI. For many sites, little if any reassessment will be required
because the appropriate decision will be readily apparent from a
brief review of the files. In order to provide resources to
perform this task, however, the SCAP target for FY 89 NPL
proposal/HRS packages prepared is suspended.
Sites with completed HRS packages and draft scores above 25
that have not been (or are not scheduled to be) proposed for the
NPL, should receive an LSI (unless deferral to another authority is
appropriate). Those sites with draft scores below 25 should be
NFRAP-recommended. (A completed HRS package means one that has
passed Regional QC.) If substantial increases in the score would*
be likely if the revised HRS were used (e.g., contaminated drinking
water, possible on-site exposure, potential air release with large
nearby population, significant environmental, food chain or
recreational impacts), a PreScore analysis to develop a projected
revised HRS score for a site should be performed to assure
consistent LSI decisions. Otherwise, sites with draft scores of
below 25 will not be rescored under the revised HRS.
For sites without completed HRS packages, a PreScore analysis
to develop a projected revised HRS score should generally be
performed. Sites that have projected scores above 25 should be
considered for an LSI; sites that have projected scores below 25
should be recommended for NFRAP. Note that the PreScore analysis
is a tool designed to promote national consistency and is not
intended to replace the Regional decision process. If a Region is
confident that a site would not score above 25, it has the
discretion not to require a PreScore analysis prior to making the
NFRAP recommendation. However, the rationale should be thoroughly
explained in the SI report.
COMPLETING THE CERCLIS UPDATE (Objective #4)t
While significant progress has been made toward accomplishing
this time-consuming task, at present, a substantial number of pre-
remedial decisions/priority recommendations have not been entered
into CERCLIS. Without this information in the data base, CERCLIS
does not give the true status of pre-remedial work to be done or
the disposition of the completed work. We must complete entering
past qualifiers and as an ongoing priority, enter into CERCLIS, all
future decisions/priority recommendations made at the completion of
PAs, SSIs and LSIs. As you know, beginning October 31, 1988 SCAP
credits are given only when a decision/priority recommendation is
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RUN DATE: 02/07/89
*»CERCLIS*ft
REGN-10: PRE-REMEDIAL STATUS REPORT
REGION: 03 STATE: PA
PAGE NO. 289
SENSITIVE INFORMATION
••INTERNAL USE ONLY**
SITE NAME
HENRY'S LANDFILL
HERALD PRODUCTS
HERBERT POE
HERCEG LANDFILL
HERCULES INC
HEREFORD TWP SITE
HERITAGE METAL FINISHING
HERMAN MOYER PROPERTY
HERMAN RYNNELDS SON CORP
HERRICK TOWNSHIP FILL
HH ROBERTSON CO
HICKOCK CO
HIGH QUALITY POLISHING •
HIGHWAY MATERIALS, INC
HILLSGROVE DISP SITE
HILLTOWN QUARRY
HIMMELBERGEH'S LANDFILL
HINKLE INCINERATOR
HN CROSBY CO
HOCKENSMITH CORP
HOOES INDUSTRIES INC
EPA 10
PAD9811051Z5
PAD 901114906
PAD980706774
PA0059285676
PAD981035116
PAD 981 740061
PA0003012077
PAD980832760
PAD003046216
PAD 981 114564
PA0004496816
PAD 981 110489
PA0002399210
PAD 98 1034028
PAD 981 105000
PAD980538647
PAD98 11 14861
PAD 982 36 3921
PAD 0 04 3Z 1345
PA0004393500
PAD014346118
DISCOVERY
09/17/85
06/10/86
11/01/79
11/01/79
04/18/85
06/30/87
02/01/82
03/01/80
09/19/85
07/18/86
03/29/85
04/24/86
01/27/86
03/01/85
12/02/85
06/01/81
04/30/86
12/31/87
03/29/85
03/29/85
05/09/85
PA
QUAL
M
M
M
M
N
H
M
M
N
N
N
N
M
M
N
H
M
N
N
N
N
REMOVED
PA SI SI H« PROPOSAL FROM FINAL ON NPL
COMPLETE QUAL COMPLETE COMPLETE TO NPL PROPOSED NPL DELETION
08/13/87 N 12/21/88
11/19/87
03/01/80
04/01/81 12/01/81
11/21/85
08/13/87
06/01/64 R 12/33/88
03/27/86
12/01/83 01/20/66
11/26/86
06/11/87
12/31/85
06/09/86
12/22/87 R 01/20/89
05/22/87
12/21/87
04/01/83
08/17/87 N 09/06/88
12/31/87
11/19/87
10/15/87
05/09/85
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entered into CERCLIS. A qualifier of HIGH or MEDIUM PRIORITY or NO
FURTHER REMEDIAL ACTION PLANNED (NFRAP) must be entered into the
decision category at the completion of a PA or the PA will not be
counted as a completion. A qualifier of RECOMMEND FOR LSI,
DEFERRED TO ANOTHER AUTHORITY or NFRAP must be recorded for each
SSI or the SSI will not be counted as a completion. A qualifier of
RECOMMEND FOR HRS SCORING or NFRAP must be recorded for each LSI or
the LSI will not be counted as a completion. Attached (see
attachment fl) is an excerpt from a CERCLIS Pre-Remedial Status
Report that accurately reflects the current status of each site,
with respect to the pre-remedial process. (While decision
qualifiers have not been entered for a few older Sis on this page,
it is expected that these will be added after completion of this
year's SI reassessment project). The only way CERCLIS will
accurately reflect the status of each site is when all Regions have
entered all appropriate qualifiers for all sites. Once all pre-
remedial qualifiers have been entered into CERCLIS, the true status
of pre-remedial work to be done and the disposition of the
completed work will be readily available and easily accessible for
all sites in CERCLIS.
CERCLIS must also be updated to include accurate idenitifiers
for RCRA Subtitle C facilities. Federal facilities, or sites on or
near Indian lands. The following clarifications should be
considered when entering these qualifiers.
o The RCRA qualifier should be used for all sites entering
CERCLIS as a result of the Environmental Priorities Initiative. In
addition, as older sites proceed through the Pre-remedial
evaluation process, if it is noted that a sites is a RCRA Subtitle
C facility, and the RCRA qualifier has not been entered into
CERCLIS, it should be entered at this time.
o The Federal facilities qualifier should be used for all Federal
facilities. Currently, CERCLIS indicates that this has already
been accomplished for many Federal facilities; however, if it is
discovered that a Federal facility does not have this qualifier
entered, it should be done immediately.
o A new qualifier is being added in order to identify CERCLIS
sites that nay be of interest to an Indian tribe. In instances
where either of the two following conditions are met, the qualifier
should be entered:
- the CERCLIS site is ON a Federally recognized Indian
reservation; or
- the CERCLIS site IMPACTS a Federally recognized Indian
reservation. (i.e. reservation land is within a three mile
radius or population of the reservation is considered a target
population due to surface or ground water use or air exposure)
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TRANSITION TO NEW HPS fObjective #51 ;
As stated numerous times in this document, FY 89 will be the
year in which the Agency's pre-remedial program move from operation
under the existing MRS to operation under the revised version of
the model. In general, Regions can promote a smooth transition to
the revised HRS by:
o continuing to actively participate in the field testing
projects and the pre-remedial Work Group;
o making use of Regional/FIT personnel experienced in Phase I and
Phase II of the field testing program to informally train others;
o utilizing results from both phases of the field test to
optimize pre-remedial process; and
o learning and utilizing the computerized version of PreScore to
project revised HRS scores at all stages in the process.
Field test results will be issued throughout the course of the
coming year as data are analyzed and decisions are made on the
appropriate procedures for all steps in the pre-remedial process.
Phase I of the project focused on all data requirements of HRS
whether they are acquired at the PA, SSI or LSI stage. Because the
Agency will use this information to make decisions on the final
promulgation of the revised HRS, the public will be notified of the
issuance of the field test final report through the Federal
Register Notice in June 1989. Specific comments on the
transitional activities affecting various components of the pre-
remedial program are as follows:
1) Preliminary results from the PA portion of the test indicate
that the appropriate level of effort (LOE) for PAs using the
revised HRS will rise from the present 80 hours per PA to between
100 and 120 hours. This is due to the need for expanded data
collection for additional pathways and the implementation of
preliminary scoring at the PA stage. The PA field test report is
due to be published in May 1989.
Although HRS documented data are not required at the PA stage,
a site will be "PreScored" based on the revised HRS to provide an
objective measure for deciding whether it should be recommended for
an SSI. Thus, the best of effort is required to project the
revised HRS score based on limited data. When best-estimate type
data (default values) or best professional judgment are used, the
rationale for their use should be documented.
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2) Preliminary information from the SI portion of the study
indicates that SSIs under the revised HRS will not differ
substantially from those performed under the existing model unless
a significant new pathway is impacted, e.g., on-site exposure. The
SSI report will be published in August 1989.
3) The field test program indicates that LSIs can be very resource
intensive in terms of LOE hours, number of samples collected and
sent to the Contract Laboratory Program (CLP), and total dollars
expended. Preliminary estimates of the LOE range from 1,200 -
1,500 hours, which will be refined based on further analysis of
data.
NPL FINALIZATION robiective #61 ;
It is the Agency's intention to finalize all of the sites
proposed to the NPL sites under the existing HRS prior to the
promulgation of the revised HRS. This prevents substantial
duplication of previous efforts by avoiding the rescoring of these
sites with the revised HRS. Update #8 and Update #9 (Federal
facilities) are scheduled for proposal in early 1989. A final
proposal, Update #10, will occur in the summer of 1989.
With these updates, the number of proposed sites on the NPL will
exceed 400. Regional assistance is needed in terms of providing
response to comments (including QA and public comments) and
clarifying site-specific technical issues. Note that the first
proposed update using the revised HRS is not anticipated until
several months following its promulgation (i.e., June/July 1990
following scheduled final rule publication in January 1990).
OTHER ISSUES:
PRE-REMEDIAL DOCUMENTS;
PA, SSI and LSI reports must be prepared as separate items from
the associated PreScore and draft HRS packages. The reports should
focus on factual depiction of site conditions (with limited HRS
jargon such as extensive descriptions of factors or models) and
conclusions. The HRS scoring aspects for the PA and SSI should be
covered in the PreScore package, which is considered pre-decisional
until the tine when a Regional decision is made on the site.
Special care in this regard is advised for releasing information to
States with "Sunshine" laws.
FEDERAL FACILITIES;
Since NPL Update #9 will be proposed in FY 89, this year's SCAP
target for Federal facility proposals is expected to be met. The
FY 89 SCAP also calls for PA/SI review of 100 Federal facilities.
Regions may conduct these reviews in-house or reviews may be
assigned to FIT. However, the FIT contractors are not to be used
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10
to perform PAs and Sis on Federal facilities. Federal agencies
are responsible for conducting these activities. FIT LOE for PA/SI
reviews has been budgeted for approximately 40 hours per review.
INDIAN LANDS;
In accordance with SARA, it is our policy to maximize the
participation of Indian tribes and to ensure that hazardous waste
site problems on Indian lands are addressed. Section 126 of
CERCLA, as amended by SARA, requires the governing body of an
Indian tribe to be accorded the same treatment as a State with
respect to certain provisions of CERCLA. Therefore, the definition
of "State" in the NCP has been revised to include Indian tribes.
If Federally recognized tribes can demonstrate that they
satisfy equivalency to State requirements, EPA will offer such
tribes the opportunity to enter into cooperative agreements to
enable them to undertake pre-remedial or remedial response actions
at sites that are within their jurisdictional boundaries. For
tribes without appropriate capabilities and/or lacking a
sufficient number of sites to make a cooperative agreement, cost-
effective for both parties, EPA will conduct preliminary
assessments and, if necessary, site inspections of potential sites
on Indian lands using its own resources. As with other sites, any
site on Indian land added to CERCLIS after enactment of SARA will
be assessed (PA) within one year of being listed in CERCLIS.
CONCLUSION:
FY 89 and 90 will present substantial challenges to EPA's pre-
remedial programs both in the Regions and at Headquarters. The
goal of accelerating progress in the midst of making programmatic
change is difficult but achievable. Concentration on the
fulfillment of the six objectives contained in the above document
will substantially advance that goal.
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Table 1
SITE INSPECTION BACKLOG
(as of October 1.1988)
REGION
I
II
III
IV
V
VI
VII
VIII
IX
X
TOTAL
SI
BACKLOG*
950
630
1,000
1,880
1,840
261
167
111
164
147 .
7,150
FY89
SCAP
90
121
164
220
260
130
75
40
100
50
1,250
FY88
COMPLETIONS
68
135
155
176
228
232
82
31
51
79
1,237
* Data presented for the SI backlog are preliminary; do not cite or quote.
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DRAFT
Table 2
PRE-REMEDIAL SCAP SCORECARO
(for FY 89)
Fedtral Facilities
REGION
1
II
III
IV
V
VI
VII
VIII
IX
X
TOTAL
PA
214
272
312
168
696
232
172
48
300
86
2,500
SSI
90
121
164
220
260
130
75
40
100
so
1,250
LSI
4
6
12
12
13
10
5
1
8
4
75
NPL
4
6
12
12
13
10
5
1
8
4
75
PA/SI R«v
4
9
12
11
8
9
3
7
22
15
100
NPL
2
4
6
6
4
4
2
4
11
7
SO
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Figure 1
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