&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 ------- 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 ------- 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; ------- - 2 - 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. ------- - 3 - 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 ------- 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 ------- - 2 - 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 ------- 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. ------- - J. . 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. ------- - 3 - 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. ------- 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 ------- |