&EPA
Unrt«d Sum
Environmental Protection
Offmof
Solid WMM «nd
DIRECTIVE NUMBER:
9345.2-03
, 1990
January 5, 1990
Superfund
TITLE: Regional Site Assessment Program
Objectives for FY 90
APPROVAL DATE:
EFFECTIVE DATE:
ORIGINATING OFFICE:
£1 FINAL
D DRAFT
STATUS.
REFERENCE (other documents):
OSWER OSWER OSWER
/£ DIRECTIVE DIRECTIVE D
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AEPA
Washington. OC 20480
OSWER Directive Initiation Request
.Diraav* Number
9345.2-03
2. Ortolnatof Information
Name el Contact Parson
B. VanEpps, SDC
Mai Cod*
OS-240
3. Title
Office
OERR, OPM/ MSDS
TataplMMCod*
475-r8864
Regional Site Assessment Program Objectives for FY 90
t. Summary ol OirtcUvt (tndudt brief statamant of purpo*t)
I am transmitting the subject document for your use in implementing
the Regional site assessment program during FY 90.
5. Keyword*
M. Does TIUS orecove superseoe rrevious urtcuv«tu.'
b,Oo«ltSupplOT«ntPrtviouil>waiv«(i)?
I [No | | Yes Whatolractfve(number.ttte)
j | Yea What dHdtve (number, floe)
I No
i——i i"^
A-SlgntdbyAA/DAA |x| B - Sonad by OfBc* Dfradof | | C - For R»vt»» & Commant Pj D - IH OMtapnvnt
8. Document to be distributed to States by Headquarters? I I YM I I
Thl* R«o,uut MMti OSWER Directive* System Format Standard*.
9. Signature ol Lead Otfica Oirtctivt* Coordinator
Betti VanEpps, Superfund Document Coordinator
10. Nam* and Titla ol Approving Official
Henry L. .Longest II, Director
Office of Emergency and Reipe'Hial Rpsnon.sp
Oat*
January 5,
Daw
January 5,
1990
1990
EPA Form 1315*17 (Rav. 5-17) Praviouf •dilion* arc obsoltta.
OSWER OSWER OSWER O
VE DIRECTIVE DIRECTIVE DIRECTIVE
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OASYS
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. O.C. 20460
51990
MEMORANDOM
SUBJECT:
FROM:
SOLID WASTE 4NO :M-3Oi>.C' 'ss»-.--.:
OSWER Directive 9345.2-03
Regional Site Assessment Program Objectives for FY 90
I
»6nse
Henry L. Longest II, Director
Office of Emergency and Remedia
TO:
Directors, Waste Management Division
Regions I, IV, V, VII and VIII
Director, Emergency and Remedial Response Division
Region II
Directors, 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 site assessment program during FY 90.
BACKGROUND
This document updates earlier documents entitled, "Regional
Pre-Remedial Program Objectives for FY 89 and First Quarter of FY
90" (OSWER Directive 9345.2-02; March 10,1989), "Pre-Remedial
Priorities" (Memo from Longest to Division Directors, April 4,
1988) and "Pre-Remedial Strategy for Implementing SARA" (OSWER
Directive 9345.2-01; February 12, 1988).
OBJECTIVES
The overall goal of Regional pre-remedial activity remains the
identification of the most serious hazardous waste release sites
in the. najfettg and evaluating them for the National Priorities List
(NPL). ^^•Blcally, eight Regional objectives for FY 90 are
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 and to quickly define the
appropriate response for each site;
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2) Maintain site inspection (SI) momentum during the transition
to the revised HRS, particularly in those Regions that have
yet to achieve the - SARA goal of conducting Sis on all
appropriate sites that were in CERCLIS prior to October 17,
1986.
3) Continue the effort initiated in FY89 to review completed Sis
to determine which sites require .listing site inspections
(LSIs) or the development of_ HRS listing packages.
Participate with Headquarters in designing appropriate
prioritization factors to assure that "worst sites" are moved
to the front of the listing queue.
4) Enter all site assessment decisions/priority recommendations
at each step of the evaluation process and all appropriate
identifiers (Federal facilities, RCRA, Indian lands, etc.)
into CERCLIS as rapidly as possible to facilitate overall
program planning and to expedite response to Congressional and
public inquiries.
5) Assist Headquarters in finalizing the remaining proposed sites
on the NPL.
6) Using Agency sponsored Total Quality Management techniques',
work with the Field Investigation Teams, appropriate state
agencies, Headquarters quality assurance contractors, and
Headquarters Regional coordinators to develop and improve FA,
SSI, LSI, HRS package preparation procedures.
7) Participate in the design and implementation of guidance and
training activities to implement the revised HRS and new N?L
procedures.
8) Participate in the preparation of listing packages for the
first NPL Update issued under the revised HRS, presently
planned for submittal to OMB by September 30, 1990.
IMPLEMENTATION
The attached document contains implementation guidance to help
you address the above objectives. Please review this guidance
carefully and apply it to your site assessment efforts over the
next year.
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CONTACTS
I would Ilk* to thank you and your staff for providing many helpful
comments on our previous draft. Pleasa call Larry Reed (FTS 475-
8602) or Penelope Hansen (FTS 382-6357), if you have questions
regarding this document.
Attachment
cc: Superfund Branch Chiefs (Regions I-X)
Superfund Section Chiefs (Regions I-X)
Betti VanEpps
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OASY5
RBOIOHAX, 0XTB A88B88KBHT PROGRAM OBJECTIVES
F0» FT 90
(00WBS Directive 9345.2-03)
This document contains the Office of Emergency and Remedial
Response (OERR) site assessment objectives for EPA Regions during
FY 90. It updates earlier documents entitled, Regional Pre-
Renedial Program objectives for FY 89 and First Quarter of FY 90
(OSWER Directive 9345.2-02; March 10, 1989), "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). It is recommended that the reader
review these formerly published directives since all policies of
those documents remain in effect unless otherwise changed by this
document.
BACKGROUND:
Site assessment program objectives for FY 90 remain
substantially the same as outlined in FY 89; to maintain momentum
in evaluating sites for inclusion on the National Priorities List
(NPL), while factoring in the new requirements of the revised
Hazard Ranking System (MRS). Headquarters development of training
programs and guidance to implement the revised HRS will begin after
the rule has completed Red Border and has been submitted to OMB.
other than the overriding goal of identifying the most serious
hazardous waste release sites in the nation and evaluating them for
the NPL, the elimination of the backlog of pre-SARA sites requiring
Site Inspections (Sis) prior to reauthorization remains the most
important goal of this program. Headquarters is working with the
Regions that have not yet achieved the pre-SARA SI goal to evaluate
various alternatives for the achievement of this goal prior to
reauthorization of SARA.
OBJECTIVES:
Regional objectives for FY 90 are listed below:
1) Continue BPA's policy of conducting preliminary assessments
(PAs) within one year of CERCLIS listing in order to prevent
the buildup of a PA backlog and to quickly define the
appropriate response for each site (i.e., a recommendation to
the Removal Program for further evaluation, a recommendation
for an SI, or a determination that no further Federal response
is warranted).
2) Maintain site inspection momentum during the transition to the
revised HRS, particularly in those Regions that have yet to
achieve the SARA goal of conducting Sis on all appropriate
sites contained in CERCLIS prior to October 17, 1986. oti-.er
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than the overriding goal of identifying the aost serious
hazardous waste release sites in the nation and listing t.".er.
on the NPL, the elimination of the backlog of pre-SARA sites
requiring Sis prior to reauthorization remains the aost
important goal of this program.
3) Continue the effort initiated in FY89 to review all completed
Sis to determine which sites require listing site inspections
(LSIs) or the development of HRS listing packages.
Participate with Headquarters in designing appropriate
* • prioritization factors to assure that "worst sites" are moved
- ;^ .to, the front of the listing queue. ~ ^ ^ "_." ,?~^., -.--
4) Enter all site assessment decisions/priority recommendations
at each step of the evaluation process and all appropriate
identifiers (Federal facilities, RCRA, Indian lands, etc.)
into CERCLIS as rapidly as possible to facilitate overall
program planning and to expedite response to Congressional and
public inquiries.
5) Assist Headquarters in finalizing the last remaining proposed
sites on the NPL.
6) Using Agency sponsored Total Quality Management (TQM)
techniques, work with the Field Investigation Teams,
appropriate State agencies, Headquarters quality assurance
contractors, and Headquarters Regional site assessment
coordinators to develop and improve PA, SSI, LSI, HRS package
preparation, and Headquarters listing procedures.
7) Participate in the design and implementation of guidance and
training activities to implement the revised HRS and new N'PL
procedures.
8) Participate in the preparation of listing packages for the
first NPL Update issued under the revised HRS, presently
planned for submittal to OMB by September 30, 1990.
IMPLEMENTATION!
Specific comments concerning different components of site
assessment activities covered by the above objectives are provided
below.
PRELIMINARY ASSESSMENTS fpbiective f 1) i
All comments contained in last year's Directive on this
subject still pertain and should be reviewed. In additicr.,
Regional staff, along with FIT contractors and State personnel
responsible for conducting PAs, should review the Preliminary
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Assessment Guidance for Fiscal Year 1988 (OSWER Directive *
9345.01). This guidance remains in effect and adherence to the
prescribed methodologies guarantees consistent decision making
throughout the nation. The SCAP goal for FY90, 1875 PAs, has been
reduced fro* that of previous years due to a decrease in CERCLIS
entries. All appropriate sites submitted to the Agency for
assessment under the Superfund program or identified through
Regional discovery activities are to be entered into CERCLIS as
expeditiously as possible and evaluated within one year.
SITE INSPECTIONS (Qbleetiva J21 ; '-•-'- --'' ' — ~~
•-- .-.-."-sao^-i- - -• '•i--'^-'• -*-~~
Only Regions VI and X achieved the SARA goal of completing Sis
on all appropriate pre-SARA site* by January 1, 1989. We .expect
Regions III, VII, VIII and IX to. achieve this goal In .1990.
Regions I, II, IV, and V have a formidable task ahead if they are
to eliminate their pre-SARA SI backlog prior to reauthorization.
Headquarters and these Regions are working together to evaluate
various alternatives for the achievement of this goal. The SCAP
target for FY90 has been raised to 1660 Sis, and we expect this
number to be exceeded.
Last year's comments on both SSIs and LSIs remain accurate and
should be reviewed. Guidance set forth in the SI/HRS Information
Bulletin, vol 1, no 1, November 1987, and SI/HRS Information
Bulletin, Issue #2, April 1989 (OSWER Directive 9200.5-302) should
continue to be used along with the Expanded Site Inspection
Transitional Guidance for Fiscal Year 1988 (OSWER Directive 9345,1-
02, October 1987) to conduct Sis until additional guidance is
issued later in the year. This year all HRS packages will be
prepared through a cooperative effort of Headquarters, Regional,
State and contractor staff. This will ensure consistant decision
making on a national basis for our first NPL update under the
revised HRS (see objective IS).
SI REASSESSMENT PROJECT fObjective 031;
Thousands of sites are listed in CERCLIS as having received
Sis, but not a decision on further NPL activity. We are unable to
tell States and the general public the status of these sites, i.e.
if the site is classified NFRAP or is an LSI or NPL candidate. The
goal of the SI reassessment project is identical to the goal of
1988's PA reassessment [project, i.e., to review all previously
completed- SI reports that do not have decisions indicated in
CERCLIS aaffBsJce the decision that (1) an LSI should be conducted
or an HRft package developed, or (2) that inadequate information
exists to make the decision and additional data must be gathered;
or (3) that no further Federal Superfund activity is appropriate.
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Although the SI reassessment project was originally projected zs
be completed in FY89, few Regions were abl« to review all of the
documents necessary to make decisions for all sites that may
require further federal activity beyond the SI. For this reason,
this project is .-extended into FY90. Please review last years
comments on Objective 13 for more detailed instructions on carrying
out the reassessment.
Efforts to determine a nationally consistent method of
prioritizing sites for LSIs and the development of HRS packages
will be discussed at subsequent Site Assessment Workgroup meetings.
The method developed should ensure national consistency Awhile at
the same .time allowing for specific Regional priorities.'7 It is
expected that this issue will be the subject of an OERR Directive
in the third quarter of this fiscal year. ' .',•
This reassessment process to evaluate previous SI documents
should be considered part of the original SI work. Therefore, for
SCAP purposes, the decisions made as part of the reassessment will
not count towards SCAP Completed SI targets.
COMPLETING THE CERCLIS UPDATE fObjective *41t
Although most Regions have done an excellent job of updating
CERCLIS and keeping it current, a few Regions have not completed
this task. These Regions have recently received nemos from Henry
Longest on this issue. We suggest that readers review last year's
comments on Objective #4, particularly those on the site
qualifiers.
NPL FINALIZATIOK CObleetive »5):
Enormous efforts were made in 1989 by everyone concerned to
keep to the very ambitious schedule set out at the beginning of the
year for listing hundreds of sites final prior to the promulgation
of the revised HRS. As you know, 90 sites were proposed last year
in four Updates, and 101 sites were finalized in two Final Rules.
We are now coming into the home stretch and must complete the
finalization of 209 remaining sites before April. Final Rule a,
containing 73 sites, is scheduled for January; Final Rule 9 with
approximately 90 sites is scheduled for February 1990; and Final
Rule 10, containing some of the most difficult policy decisions the
Agency has had to face, is scheduled for March 1990. We request
that any information needed from the Regions to assist in
finalizing specific sites be sent as soon as possible.
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TQM IMPROVEMENTS TO SITE ASSESSMENT fOb-iaetive ifi) ;
As was discussed with the Regional Site Assessment Staff at
the recant San . Francisco Workgroup Meeting, tha Agancy has
committed itsalf to tha continuous improvement of tha way in which
we conduct tha nation's environmental business. Tha evaluation and
listing of sites under Suparfund has bean selected as one of the
pilots for this program. Tha goal of TQM is to make constant
small, but significant, changes to tha process in which one is
involved in order to make that process more efficiently produce
products of higher quality. This initiative could not come at a
better time for our program. Because va ara making numerous
changes pursuant to the revised HRS, we ara in an excellent
position to institutionalize the process of continuous improvement.
While we are only in the beginning stages of this effort, we are
interested in the creative ideas and participation of all members
of the site assessment community. A TQM workgroup was formed in
San Francisco to assist Headquarters in the development of this
project. More information on this important initiative will be
forthcoming in the near future.
GUIDANCE AND TRAINING DEVELOPMENT fObjective i7^;
We expect to begin work with the Guidance and Training
Development Workgroup recently formed in San Francisco, after the
HRS is sent to OMB. This workgroup is expected to work closely
with the TQM workgroup mentioned above. The major difference
between the two will be that the guidance and training workgroup
is expected to focus on the more technical aspects of work
conducted for site assessment, e.g., field procedures, sampling
techniques, aerial photography utilization, population data bases,
etc. (The TQM group will focus on the more procedural aspects of
site assessment and listing.) Documents to be developed will
include at a minimum guidance on PAs, SSIs, LSIs, HRS packages,
PreScore, Regional QC, and Headquarters QA.
FIRST NPL UPDATE UNDER THE REVISED HRS (Objective $8):
Headquarters, Regional, FIT and State staff, along with
Headquarters contractor QA staff, will participate together in the
preparation of listing packages for the first NPL Update to be
issued under tha ravisad HRS. This update will consist primarily
of sites evaluated under Phase I and Phase II of the revised HRS
testing program, although other sites may also be considered. SAB
plans to implement Total Quality Management objectives in preparing
HRS packages under the revised HRS. This will involve -ere
interaction earlier in the process to ensure HRS packages are
complete when they are submitted for QA review. This Update is
presently planned for submittal to OMB by September 30, 1990.
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CONCLUSION:
Directive 9345.2-02 (FY89 program objectives) should be used as a
supplement to this document. I have attached a copy for your
convenience. If- you need any other documents referenced in this
directive or hav« any questions or comments please contact LarrC
Reed at FTS 475-8602 or Penelope Hansen at FTS 392-6357? ^
Attachment
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