&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  -


 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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                            - 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

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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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                             - 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

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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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                             - 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.

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                            - 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.

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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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