United States
                Environmental Protection
           Office of
           Solid Waste and
           Emergency Response
                  TITLE; Procedural Guidance for Reviewing Exposure
                       Information Under .RCRA Section 3019
                  APPROVAL DATE:  September 26, 1986

                  EFFECTIVE DATE:  September 26, 1986

                  ORIGINATING OFFICE:  office of solid waste

                  0 FINAL

                  D DRAFT

                   LEVEL OF DRAFT

                     DA — Signed by AA or DAA
                     OB — Signed by Office Director
                     DC — Review & Comment

                  REFERENCE (other documents):
                  Permit Applicants' Guidance Manual for Exposure"
                  Information Requirements under RCRA Section 3019
  OSWER       OSWER       OSWER


Terry Groran

vV*»nmg,«on. DC 20460
OSWER Directive Initiation Reauest
'r-« •"• C/.it .:.., :,..ir.j,»»
9523.00 24 ,

f '
!!H 563 _ Assistance Dranch 332-^740
Approved tor Revttw
Signature ol 0«rfviouaOirKtiva   LJ Yes   LJ No   Does It Supplement Previous Directive)*)'  (_j *••   LJ No
If "Yes" to Either Question. What Directive f/»umA«r.
  remit  Applicants1  Guidance Manual for Exposure Information  Requirements  Under RCRA
Review Plan
   03 AA-OSWEft
   D OEM
LJ Regions
Concurrences obtained
                                                                      Sectr'.on 301?
Th.s Request Meets OSWER Directives System Format
Signature ol Lead 0
                                       OStTER POLICY DIRECTIVE NO.  9523. C^-2.
    *             --       WASH.NGTON, D.C. 20460          DSWER «"» DIRECTIVE NO.

t «o^
SEP 26 1986
                                                          OFFICE OF
                                                 SOLID WASTE AND EMERGENCY RESPONSE
  SUBJECT:   Procedural  Guidance  for  Review of  Exposure
  FROM:      J. Wltffston  Pfcrter
             Assistant Administrator

  TO:        Hazardous Waste  Management  Division  Directors
             Regions  I-X

  Attached for your use  is  the  final Procedural Guidance for
  Reviewing Exposure  Information  under RCRA Section 3019.   This
  guidance describes  suggested  procedures  for evaluating Exposure
  Information Reports  (EIRs)  and  related materials, and how this
  review should be integrated into  existing RCRA  activities.  This
  guidance was developed with Regional input, and reflects comments
  received from the Regions on  earlier drafts.  There are  several
  points covered in the  guidance  that I  would like to stress.

  First, Section 3019  is applicable to landfills  and surface
  impoundments subject to operating or post-closure permits.  The
  requirement to submit  a Part  B  triggers  the duty to submit the
  EIR.  Therefore, whenever a post-closure permit application is
  requested, the Regions (or  authorized  States) should notify the
  owner/operator that  an EIR  is required.   An EIR is not needed for
  units for which a post-closure  permit  is not  required (e.g., those
  which have not received hazardous waste  after July 26, 1982).

  Second, the permit writer should  conduct an initial review of the
  EIR as soon as possible after the EIR  is received.  If the review
  reveals evidence of  a  release and potential human exposure,  the
  permit writer should give a high  priority to the detailed technical
  review of the EIR (and Part B).   At any  stage of review  that the
  permit writer suspects a  health hazard,  other program and enforcement
  staff should be consulted to  formulate an appropriate response,
  which may include contacting  Headquarters and seeking a  health

  Third, before seeking  a health  assessment from  the Agency for
  Toxic Substances and Disease  Registry  (ATSDR) under §3019, the
  Region must obtain  the concurrence of  Headquarters, even though
  the authority to refer a  facility to ATSDR has  been delegated to

                                  OSWER POLICY DIRECTIVE NO.  9523.00-2
                                                     OSWER POLICY DIRECTIVE

                              ~2~                 9523-00-2

the Regional Administrator  (with redelegation possible to the
Division Director level).   The Headquarters concurrence requirement
is designed to ensure that  important sites are assessed first,
and to obtain national consistency in the types of sites referred
to ATSDR.  Regions seeking  concurrence or other assistance should
contact Terry Grogan of the Permit Assistance Team  (FTS 382-4740).

Finally, I urge the permit  writers not to allow the §3019 review
process to unduly delay the permitting process.  RCRA programs are
already in place to identify, investigate, and clean up releases
to qround water and other exposure pathways.  Therefore, the two
major goals in reviewing exposure information under §3019 are:
(1) to identify human exposures to prior/continuing releases that
require ATSDR involvement,  and (2) to identify potential exposures
from possible future releases that may be mitigated by specific
permit conditions.

I encourage you and your staff to use the procedures outlined  in
this guidance.  If you have any questions about the guidance or
the implementation of §3019, please contact Terry Grogan or
Bob Kayser at the number noted above.


cc:  Hazardous Waste Branch Chiefs, Regions I-X
     Permits Section Chiefs, Regions I-X
     Exposure Information Contacts, Regions I-X

                                              OSWER POLICY DIRECTIVE NO;

                       OSWER POLICY DIRECTIVE NO.  9523.00-2

               UNDER RCRA SECTION 3019
                Office of Solid Waste
    United States Environmental Protection Agency

                   September, 1986

                                                        CULM DIRECTIVE KO.

                             OSWER POLICY DIRECTIVE NO.   9523.00-2
This guidance was prepared by the Assistance Branch of the  Office
of Solid Waste,  with the assistance of other Headquarters and
Regional EPA staff.  Major contributors to this  document were
Robert Kayser and Terry Grogan.   Numerous helpful  comments  and
suggestions were provided by Allen Maples,  Art Day,  Susan
Green, Carrie Wehling,  and other EPA staff.   Andrew Teplitzky
and.Amy Schaffer of A.T. Kearney,  Inc. also played a role in
the preparation of this document.   This guidance has borrowed
freely from existing EPA documents, either through the citation
of other guidances, or the incorporation of approaches that
might be useful to th« EIR reviewer in assessing exposure
potential from hazardous waste sites.

                                                     OSIVER POLICV DIRECTIVE NO,
                             OSWER POLICY DIRECTIVE NO.
                      TABLE OF CONTENTS




I .     INTRODUCTION	    1

      A.  Background	    1

      B.  Three Components of Human Exposure 	    2

      C.  Gathering Additional Information 	    2

          1. Additional Information Sources	    2
          2. Using Permitting and Corrective
               Action Processes	    3

      D.  General EIR Review Procedures	  .    4

      E.  Relationship to Existing RCRA Programs ....    6

      F.  State Roles in EIR Reviews	    7


      A.  Setting Priorities for EIR Reviews
            and Identifying Imminent Hazards 	    7

      B.  Performing the EIR Completeness Review ....    8

          1. EIR Completeness Review Format	    8
          2. Other Information Sources 	    9
          3. Determining the Adequacy of Submitted
               Information 	    9


      A.  Evidence of Significant Prior or Continuing
            Release.	   11

          1. Definition of "Significant Release" ....   11
          2. Useful Information Sources	   11
          3. Deciding Future Course of Action	   13

      B.  Determination of Known/Suspected Public
            Exposures at Significant Levels	   16

                            OSWER POLICY DIRECTIVE NO.  9523.00-2

                                                    OSWER POLICY DIRECTIVE NO,
                TABLE OF CONTENTS (Continued)      n

         1.  Human Exposure Components 	 ...   16
         2.  Gathering Data to Document Exposure ....   17
         3.  Technical Assistance	   19

     C.  Possible Actions in Cases of Human Exposure.  .   22

         1.  Interim Remedial Action 	   23
         2.  Referral to ATSDR for Health Assessment .  .   23
         3.  Corrective Action 	   25

     D.  Determining the Potential for Significant
           Public Exposure From Future Releases / ...   26

         1.  General Approach	   27
         2.  Pathway-Specific Factors	   28
         3.  Transportation Factors	   33
         4.  History of Management Practices 	   33
         5.  Example of Exposure Potential Determination   34

     E.  Considering Permit Conditions to Mitigate
           Potential Exposure 	   36
Attachment I     Section 3019 Statute

Attachment II    Exposure Information Report Requirement

Attachment III   Levels of ATSDR Assistance

                              OSWER POLICY DIRECTIVE NO.  9523.00-2

                         EXECUTIVE SUMMARY         A „,               "'
     Section 3019 of RCRA requires an owner or operator of a
hazardous waste surface  impoundment or landfill to submit an
Exposure Information Report  (EIR) along with the Part B permit
application.  The requirement to submit a Part B triggers the
duty to submit an EIR, and the regulation is applicable to both
operating and post-closure permits.  The purpose of §3019 is to
identify whether releases from the facility pose a significant
potential risk to public health.  These cases may be addressed
through appropriate permitting or enforcement responses, and
through referral to the Agency for Toxic Substances and Disease
Registry (ATSDR) for a health assessment.  The public may also
submit information about releases from a site to EPA, an
authorized State, or ATSDR.

     Exposure information will be collected and evaulated by the
EPA Regions until the States receive authorization for S3019.
Until then, State assistance in reviewing the EIRs is desirable,
especially where the State is already reviewing the Part B appli-
cation.  Because the EIR may make reference to information      . -
already contained in the Part B, the EIR and Part B are best
reviewed concurrently.  However, the EIR is not legally a part of
(but merely "accompanies") the Part B, and the permit cannot be
judged incomplete due to deficiencies in the EIR alone.  While
the EIR should be reviewed before permit issuance, the review
should not unduly delay the permitting process.

     A previously issued document, the Permit Applicants' Guidance
Manual for Exposure Information Requirements under RCRA Section 3019,
provides guidance on the information that must be submitted to
EPA by the owner/operator.  The following new guidance describes
the procedures the permit writer/EIR reviewer should follow in
evaluating the EIR and related information for human exposure
potential and how this review should be integrated into existing
RCRA activities.  RCRA programs are already in place to identify,
investigate, and clean up releases to ground water and other
pathways.  Therefore, the two major goals in reviewing exposure
information are: (1) to identify human exposures to past releases
from subject units that may require ATSDR involvement; and,
(2) to identify potential exposures from future releases that
may be mitigated by specific permit conditions. [Note that the
term "future release" also includes a release that has occurred
but has not yet been detected.]

     The steps to follow in reviewing the EIR and related material
include: (1) a completeness review to ensure that the EIR submittal
is adequate, and an initial screen to determine if the existing
release and exposure evidence warrants immediate action; (2) deciding
if the available evidence indicates that a significant release
has occurred; (3) deciding if such a release has resulted in
known or suspected exposure to the public at significant levels;
(4) considering appropriate responses in cases of human exposure

                            OSWER POLICY DIRECTIVE NO      R3 P. (&tp^ DIRECTIVE NO
                                                      9523  . 00-2
 (interim measures, ATSDR referral, corrective action); (5) deter-
mining the potential for public exposure to future releases;
and,  (6) considering new permit conditions to mitigate potential
exposure to future releases.  The EIR reviewer may not complete
each  step in the process in the order given, e.g., if the
reviewer suspects an imminent hazard at any point in the evaluation,
(s)he should immediately consult with permitting and enforcement
staff to formulate an appropriate response.

      Pathways that should be examined include ground water, air,
surface water, subsurface gas, soil, and food chain contamination.
Three elements are needed to establish a complete exposure
pathway: (1) a confirmed release of hazardous constituents of
concern; (2) migration of the released constituents off-site; and,
(3) a population known (or suspected) to have come into contact
with  the contaminated media.  The EIR reviewer should use the EIR
information in conjunction with data collected during the
permitting process or from investigations conducted as part of
the corrective action program for prior/continuing releases
(under §3004(u) and 3008(h)) to determine if a complete exposure
pathway exists.

      In assessing the adequacy of exposure information, the
reviewer may consult with the Permit Assistance Team (PAT) ,
the Office of Research and Development (ORD) , or ATSDR.  However,
the Region should contact the PAT for more extensive technical
assistance,  and the PAT will coordinate assistance from OSW, ORD,
and ATSDR as needed.  The Region must obtain the concurrence of
EPA Headquarters prior to referring a facility to ATSDR for a
health assessment.   Interim remedial measures and long term
corrective action should be considered even if the site is not
referred to ATSDR (e.g. , to prevent future exposure to past

     The reason for examining the exposure potential from future
releases (Step 5) is to identify pathways of concern and design
permit conditions to mitigate these potential problems (Step 6).
The occurrence of past releases and exposures will be a primary
indicator of the impact of possible future releases.  The EIR
reviewer is also encouraged to qualitatively screen subject
units to examine potential exposure if a release should occur.
If a  pathway of concern is found, the relevant design and
operating features should be critically examined to decide if
additional permit conditions are necessary.

                                                   OSWEK fGLiCY



 A.   Background

     Section 3019 of the Resource Conservation and Recovery Act
 (RCRA) requires an owner or operator of a hazardous waste surface
 impoundment or landfill to submit an Exposure Information Report
 (EIR) in conjunction with permit applications submitted under RCRA.
 The  EIR must identify known releases, the potential for releases,
 the  potential pathways for human exposure to hazardous waste or
 constituents associated with these releases, and the potential
 magnitude of human exposure resulting from these releases.  The
 purpose of Section 3019 is to identify whether releases of hazardous
 waste or hazardous constituents from the facility pose a significant
 potential risk to public health.  When such cases are found, the
 Agency may address the problem through a variety1 of RCRA permitting
 and  enforcement authorities, through a request for a health assess-
 ment as described in Section 3019 or, if appropriate, through the
 Comprehensive Environmental Response, Compensation, and Liability
 Act  (CERCLA).  The Permit Applicants' Guidance Manual for Exposure
 Information Requirements Under RCRA Section 3019 (PAGM), issued".in
 July 1985, provides additional background on this requirement.
 Attachement I contains the statutory language for §3019.

    The deadline for submission of permit applications and
 associated EIRs for all operating land disposal facilities was
November 8, 1985.   Therefore,  many EIRs have been submitted to EPA
and await review.   The Agency expects to issue technical guidance
 for permit writers on the review of Exposure Information Reports.
The following procedural guidance has been developed to assist
permit writers in the review of EIRs for facilities whose Part Bs
 are being processed now.  This procedural guidance presents the
 steps for evaluating an EIR and related materials for human
 exposure potential and identifies how other regulatory tools and
 information sources may be utilized during various stages of the
 EIR  review process.  This guidance will use the terms "EIR reviewer"
 and  "permit writer" interchangeably, with the realization that
 various Regional and State staff may be involved in the review
process.  Because the EIR is closely tied to the Part B, however,
 the permit writer familiar with the facility should have a major
 role in reviewing the exposure information.

    The requirement to submit an EIR has been added to the RCRA
permitting regulations in 40 CFR 270.10(j).  [The regulation
essentially repeats the statutory language found in §3019(a).]
As noted in the preamble to the codification rule in the Federal
Register (50 FR 28726, July 15, 1985), 40 CFR 270.10(j) is
 applicable to both operating and post-closure permits.  The
 requirement to submit a Part B triggers the duty to submit the
 EIR.  If a closing unit does not require a post-closure permit
 (and consequently, a Part B is not required), owners and operators
 would not have to submit an EIR.  Therefore, owners and operators
 of closing units who intend to "clean-close" are not required to
 submit an EIR until or unless the Region (or authorized State)
 requests submission of a post-closure permit application.

                                                    GSiVt,; POLICY DIRECTIVE NO,
                            - 2 -

B.  Three Components of Human Exposure

     The reader will find reference throughout this document to
three elements that must be considered tor each unit in order
to decide if the potential for human exposure exists.  The three
elements needed to establish a complete exposure pathway are:

   o   a release of hazardous wastes or hazardous
       constituents from the unit;

   o   movement of the release off-site (or to on-site human
       exposure points) via a media pathway (e.g., groundwater,
       surface water, or air); and,

   o   a nearby population likely to come into contact with such
       a release.    .                      '-.,•.

These "human exposure" components form the basis of the evaluation
of each EIR in order to focus the EIR reviewer on the data
necessary to determine whether there is a "substantial potential
risk" to human health from prior releases from a facility.
When considering possible public exposure due to a future
release of hazardous wastes from a unit, the reviewer may not
have data documenting a release.  In this case, the unit must
be evaluated by tocusing on the potential for release and
migration and possible impacts on nearby populations.

     All pathways for off-site migration must be reviewed in
order to determine the potential for exposure to hazardous waste
releases.  Potential pathways mentioned in the PAGM include:
ground water, surface water, air, subsurface gas, soil, and food
chain contamination.  The potential for human exposure through
all of these pathways should be examined with the three elements
given above in mind.

C.  Gathering Additional Information

1.  Additional Information Sources

     The EIR is only one of many sources of information which are
available to assist the EIR reviewer in determining whether a
facility presents .a. potential for human exposure.  Other sources
of information include the Part B application, results from the
RCRA Section 3004(u) and Section 3008(h) corrective action
processes, compliance monitoring and enforcement reports,  files
from other State and Federal agencies, information or complaints
from the public, and the permit writer's general knowledge of the
facility.  Independent sources of information will be useful
to the EIR reviewer in evaluating the accuracy of the EIR
information and in determining the seriousness of potential
problems.  The use of these other information sources at various
stages of the EIR review is described in the relevant sections
of this document.

                                                    OSWER POLICY DIRECTIVE WO.

 2.  Use of Permitting and Corrective Action Processes

     The EIR reviewer is encouraged to use all sources  available
 within the existing permitting process or the various corrective
 action procedures for gathering the data necessary  to identify
 the potential for human exposure.  The permit writer should be
 well aware of the permitting authorities that are used  in'
 detecting and cleaning up releases to ground water  from disposal
 facilities.  The use of the new corrective action authorities
 granted to EPA under Sections 3004(u) and 3008(h) of HSWA will be
 invaluable in addressing releases via other pathways besides
 ground water (e.g., surface water, air, subsurface  gas), and
 these authorities are briefly described below.

     In contrast to the more limited applicability  of Section
 3019, the Section 3004(u) corrective action provision applies to
 all types of solid waste management units (-SWMUs).,  inactive or
 active, at any treatment, storage or disposal facility  seeking a
 RCRA permit.  Section 3008(h) authorizes the Agency to  bring
 enforcement action to address releases from any  Interim Status
 treatment,  storage and disposal facility.  Both  corrective action
 authorities may be used to address releases to any major pathway.
 The Section 3019 exposure information requirements  apply only to
 a subset (i.e., RCKA permitted surface impoundments and landfills)
 of the SWMU universe addressed under Sections 3004(u) and 3008(h).

     EPA has developed a phased process for implementing the
corrective  action provisions that consists of a  preliminary RCRA
Facility Assessment (RFA), a RCRA Facility Investigation (RFI),
and implementation of corrective measures.  The  RFA process
 (previously identified as a preliminary assessment/site investiation,
or PA/SI) is designed to identify significant releases  from
SWMUs and to determine the need for, and scope of,  further investi-
gation (RFI) by the owner/operator.  The RFI will typically be
used to confirm the existence of releases, characterize the
extent and  nature of such releases, and determine whether or not
 such releases pose a threat to human health and  the environment.
The EIR reviewer should consult the Draft RCRA PA/SI Guidancet
 (August 5,  1985) for details on the RFA process.  The memorandum
entitled "Interpretation of Section 3008(h) of the  Solid Waste
 Disposal Act" (December 16, 1985) from J. Winston Porter and
Courtney M.  Price should be consulted for more  details on the
use of Section 30U8(h).

     The reasons for relying on the corrective action RFA/RFI
process to identify and investigate significant  releases are
several.  First, the procedures and policies for conducting
RFAs have been described in existing guidance in a  fairly compre-
hensive and detailed manner.  Many of the Regions and States
will have some experience in implementing RFAs and  should be at
 least tamiliar with the process.
tSoon to be reissued as the RCRA Facility Assessment Guidance
 and referred to as such throughout this document.

     Second, the information-gathering authorities under 3004(u)
and 3U08(h) are much broader than under Section 3019.  In support
of the 3004(u) corrective action program, information may be
gathered to identify releases to many different pathways, and
the owner/operator may be required to conduct investigations (RFI)
to determine the extent and significance of releases.  Additionally,
a Section 3008(h) order might require that the owner/operator
conduct a study to characterize the nature and extent of contamin-
ation from a release.

     The EIR submission required under Section 3019 is not part
of the permit application and does not have the weight of Section
3005 behind it.  In addition, the provision limits the level of
effort that the owner/operator needs to put forth in developing
information for the EIR.  Only "reasonably ascertainable infor-
mation" need be provided by the owner/operator in'-the EIR. (See-
the PAGM for further discussion on the obligation of the owner
or operator to submit exposure information.)

     Finally, the Agency has placed a high priority on RCRA RFA
activities; at least the initial stages of the process should
be completed before a RCRA permit is issued.  Therefore, the
EIR reviewer will have the opportunity to examine data relating
to possible releases and human exposure gathered through the
RFA process.

D.  General EIR Review Procedures

     The suggested procedures involved in performing the EIR
review are summarized in Figure 1.  The review of an EIR follows
the same basic steps employed in the review of a Part B application,
i.e.,  a completeness review followed by a technical evaluation.
Step 1 in Figure 1 represents an initial screen and the complete-
ness review, while Steps 2 through 6 may be considered the EIR
Technical Evaluation.

     Steps 2, 3, and 5 ask the important questions regarding
exposure: is there evidence of a prior or continuing release; is
there known or suspected exposure to the public at significant
levels; and, could future releases result in significant public
exposure?  Steps 4 and 6 are essentially responses to those
questions.  While the steps outlined in Figure 1 represent the
basic decision-making process tor EIR reviews, reviewers will
not necessarily complete each step in turn before moving to the
next.   Cases of apparent significant public exposure wj.ll require
response before all of the other steps have been completed.
Some activities may be taken simultaneously, e.g., reviewers may
conduct the analysis needed for Step 5 at the same time a RFA
is being conducted under Step 2.  It is expected that the EIR
review process will help the permit writer focus on the potential
for exposure throughout the permit review process.

                                     - 5 -
                   Figure 1.  Outline of EIR Review Process
                                                OSWER POLICY UiRECT'

                                               9523 .00-2
                         [Applicant submits EIR[
 To ATSDR and
 to EPA/State
     EPA/State does initial screen

     Completeness review of EIR
     based on Permit Applicants'
           Guidance Manual
   (coordinated with Part B review)
                 Additional data
                 from applicant
                       Technical review of EIR
                    to address steps 2 through 6
                    (using other data as needed)
Gather further
 data, using
permit process,
3004(u) RFA,
 orders, etc.
new data.
Is there evidence
 of significant
    prior or
Gather further
 data, using
permit process,
 3004(u) RFI,
 orders, etc.
  Use of ORD,
 for technical
  Could future
 release result
in significant
public exposure?
   Is there known or
 suspected exposure to
    the public at
 significant levels?
               Consider permit
                conditions to
              mitigate potential
              (or permit denial)
         corrective action
             as needed
              Consider interim
             remedial action and
             public involvement
                 as needed
                             Consider Health
                           Assessment by ATSDR,
                             with HQ (OSWER)

                                                  OSWER POLICY

                                                9523 .00-2

     This Guidance  is organized according to the  steps  in Figure 1.
A checklist and^tables are presented in this Guidance to assist in
summarizing the results of the EIR review.  These checklists and
tables are provided as examples only.  The Regions are welcome to
revise the format and content of these documents  in order to conform
to Regional priorities and methods.  Attachments  at the end of the
Guidance include a  completeness checklist (Attachment II), and
the types of health evaluations ATSDR may perform when requested

E.  Relationship to Existing RCRA Programs

     This Guidance describes the overall §3019 review process, and
how this review should be integrated into existing RCRA activities.
RCRA programs are already in place to identify, investigate, and
clean up prior/continuing releases to ground water (Subpart F
regulations) and other pathways (RFA/RFI process).  Therefore,
the two primary goals in implementing §3019 are to: (1) identify
human exposures to past releases that may require ATSDR involvement;
and, (2) to identify potential exposures from future releases that
may be mitigated by specific permit conditions.

     The RFA/RFI and permitting programs should provide the infor-
mation needed to determine if a release has occurred and if human
exposure is likely.  These activities should also generate most of
the documentation the EIR reviewer needs for the  §3019 review
process.  The EIR reviewer is required to prepare a separate report
for §3019 when the Regional Administrator (or his designee) believes
that a site is a candidate for referral to ATSDR for a health
assessment.  This requires the submittal of a summary report to
EPA Headquarters for concurrence prior to referral to ATSDR (see
Section III.C.2).  The EIR reviewer should also produce a brief
memorandum for the administrative record at other important
decision points, i.e., the results of the completeness check/initial
screen (Step 1), and the examination of potential exposures to
future releases (Step 5).  In addition, the reviewer should write
a short memorandum for the record documenting a decision not to
refer a site to ATSDR, and summarizing why the site does not meet
the necessary criteria for referral (see Section III.B.I).
Documentation of these decisions may be more important for sites
where public concerns exist.

     The prevention of releases and subsequent human exposure
should already be an integral part of the permitting process.
However, Step 5 of the EIR review process provides the permit
writer with the opportunity to identify sites that require
special permit conditions to mitigate possible risks from
future releases.  Section III.D provides a qualitative approach
that may be used in completing Step 5.

     The exposure information review process outlined in Figure 1
illustrates the need to integrate this review with ongoing and
planned permitting and enforcement activities.  Which of the
Steps are completed prior to permit issuance depends, to some
extent, on Regional priorities for a particular site.  Normally,

                              -  7  -
                                                  9523 .00-2
Steps  1, 2, 5, and 6 will be completed at most sites prior to
issuing the permit.  In addition, the permit writer should make
at least an initial decision whether the potential for significant
public exposure  (Step 3) warrants action via enforcement orders
(e.g., 3008(h))  before permitting.  Recommendations on the
appropriate use  of the investigation/corrective measure authorities
for the EIR review are described in Section III.B.

F.  State Roles  in EIR Reviews

     States with final authorization are required under 40 CFR
271.21(e) to adopt requirements equivalent to any new Federal
requirements.  Pursuant to Section 3006(g) of RCRA, the require-
ments of Section 3019 will be implemented by EPA until each
State receives authorization for this provision.  Until States
receive such authorization, the Regions may amend existing
grant Memoranda  of Agreement (MOA) with States t© allow them  -
to assist in reviewing the EIRs.  This may be especially helpful
where the State  is already reviewing the Part B application.
The State's role in implementing Section 3019 should be clearly
defined in the MOA or other agreements with EPA.  The Region
will need to oversee State reviews and follow up if more infor- '
mation is needed under Section 3019, if referral to the Agency
for Toxic Substances and Diseases Registry (ATSDR) is deemed
necessary,  or if new permit conditions are needed under 3005(c).
Section 3005(c)  (the "omnibus" provision) is discussed in
Section III.E. of this guidance.


A.  Setting Priorities for EIR Reviews/Identifying Imminent

    Since the EIR is based in large part on information from the
Part B application, it makes sense in most cases to perform the
Part B and  EIR reviews concurrently.  Accordingly, the order
in which EIRs are reviewed depends largely on the order in
which the Part B applications are reviewed.  (Since Part B
reviews should generally be conducted in order of environmental
significance, as reflected in the annual Agency Guidance and
the National Permits Strategy,  the priorities for EIR reviews
will therefore have an environmental basis as well.)  Never-
theless, the permit writer should conduct an initial screen
of all EIRs upon receipt.  If the initial screen indicates
that the EIR provides- new evidence of a release and/or potential
exposure, the permit writer should reevaluate the environmental
significance of the facility and consider raising the technical
review of the Part B and EIR to a higher priority.  If the EIR
reviewer suspects an imminent hazard, program and enforcement
personnel should be consulted immediately to formulate an
appropriate course of action.  Section III.C describes interim
remedial measures and corrective action responses that may be
necessary in these cases.

                             - 8 -

9523 .00-2
     There will .be situations where the Part B and the EIR will
not be reviewed concurrently.  For instance, when an EIR is
submitted for a facility whose draft permit has been prepared,
it will usually be appropriate to conduct a full EIR review as
soon as possible even though the Part B review has already been
completed.  The EIR reviewer in this case must be particularly
careful to ensure that the data provided in the EIR and in the
Part B are consistent and that no new information is provided in
the EIR which affects the draft permit conditions.  Unless the
draft permit has already been issued, the EIR reviewer is advised
to review the EIR before the draft permit goes to public notice.

B.  Performing the EIR Completeness Review

1.  EIR Completeness Review Format

     The EIR should be reviewed for completeness :based on the -
Permit Applicants' Guidance Manual for Exposure Information
Under RCRA 3019 (PAGM).  The EIR completeness review may be
conducted in a fashion similar to that used for a Part B
application completeness review.  The EIR reviewer may fill out
a completeness checklist and develop corresponding comments
to summarize any important omissions in the EIR.  A completeness
checklist has been provided in Attachment II and may be used
as a guide by the EIR reviewer during a completeness check.
This checklist is based on the permit applicants' checklist
found in the PAGM; however, it has been expanded and revised
to include a section on the "potential for human exposure"
narrative required of the owner/operator.

     Although the Part B and EIR reviews should be conducted
concurrently whenever possible, any requests to the owner/operator
for missing information required under 3019 should remain separate
from a Part B Notice of Deficiency (NOD) because the EIR is not
legally a part of the permit application.  The regulations in
40 CFR 270.10(c) were amended on July 15, 1985 to provide that
a Part B which is not accompanied by an EIR will not be deemed
incomplete on that basis alone.  The permit writer may find
deficiencies in the Part B which impact the EIR.  In this
case, a warning letter or enforcement order containing the EIR
completeness comments should note these deficiencies by referencing
the deficiency comments in the Part B Notice of Deficiency (NOD).
For example, if the Part B inadequately described overtopping
control at the surface impoundment, then the EIR checklist and
comments may simply instruct the applicant to: "See Part B NOD
Comment # 	 regarding overtopping control."  Any comments
generated from an EIR review should be simply entitled "EIR
Completeness Review Comments" rather than "Notice of Deficiency
Comments", to further distinguish the EIR review from the Part
B review.

                                                    OSWER POLICY DIRECTIVE NO.

                              '9-                9523.00-2
2.  Other  Information Sources

   a.   Permit Writer and Compliance/Enforcement Personnel

      In addition to the Part  B application, several other infor-
mation  sources may be useful  in a completeness review of the
EIR.  Both the permit writer  and the enforcement official may
have  knowledge of the facility's history which will be helpful
in determining whether there  are significant omissions in the
applicant's submittal or in pursuing any EIR reference to
other RCRA documents, such as 3004(u) SWMU response letters or
previous facility inspection, compliance, or enforcement reports.

   b.  Other Federal/State Agencies

      The EIR reviewer may consider contacting other Federal or
State environmental agencies  during the completeaess review if-
an applicant's EIR refers to  relevant information which is
contained in documents located at these agencies.   For example,
the EIR may reference or summarize NPDES permit information or
air monitoring reports which may be located in the Regional
EPA offices or State Water/Air Offices.  If the information
appears to be important (e.g. , if a release is indicated) the
reviewer may wish to confirm  that the document is accessible
and contains the expected information.   If important documents
are not accessible to the EIR reviewer (s)he may request the
applicant to submit a copy of the relevant information.

   c.   Public Submissions

     The Exposure Information provision of RCRA also allows the
public to submit information on possible exposures.   Public
submittals may be received by EPA either directly, or via
reports forwarded to EPA from ATSDR.  Upon receipt of public
submissions relating to a RCRA site, ATSDR should contact the
appropriate EPA Regional staff and forward a copy of the submission.
Regional staff should attempt to coordinate any needed response
to the public with any response planned by ATSDR,  and EPA Public
Involvement staff should be consulted in these situations.  In
addition to providing important information to the reviewer, a
report of suspected human exposure from the public may create
a rather sensitive situation  in terms of public fears and
expectations.  The Revised National Permits Strategy (July,
1985)  encourages .early public involvement in permitting facilities
and directs the Region or authorized State to prepare public
participation plans for "environmentally significant" facilities.
Furthermore,  the Permits Strategy recommends that  the exposure
information be included early in the public participation
process for these environmentally significant facilities.

3.  Determining the Adequacy of Submitted Information

     RCRA Section 3019 requires the applicant to provide all
"reasonably ascertainable information.'  Although much of the
information in the EIR can be cross-referenced to  the Part B
application,  the PAGM does require the applicant to submit

                            - 10 -
                                                      OSWER POLICY DIRECTIVE NO.

                                                    9523 .00-2
additional information.  The legislative history of Section 3019
indicates that Congress did not expect applicants to develop
major pieces of new information; however, if applicants do have
access to already existing data, they should submit or cite the
data, or provide an explanation as to why they could not obtain
the data.  See the PAGM for additional discussion of this topic.

     Unlike the requirements for the Part B, there is no regula-•
tory requirement for a "complete" EIR beyond the 40 CFR 270.10(j)
requirement to submit exposure information.   The PAGM states
that applicants who fully provide the information outlined in
that document will be considered to have satisfied the infor-
mation requirements of Section 3019.   From a practical viewpoint,
EIR reviewers should focus on missing information that will be
important in defining one of the three components of exposure,
i.e., data on releases, pathway characteristics,=and target
populations.  Therefore, a reviewer need not literally apply
the PAGM information requirements and request that the applicant
submit missing information just for the sake of completeness.
Additional or missing information should only be requested
when it would be useful in determining human exposure.  For
example, if an applicant discussed surface water use within a
two-mile radius of the facility, rather than the three-mile
radius requested in the PAGM, the permit writer should decide
whether the additional one-mile radius would really be helpful
in determining human exposure potential.

     An important question the EIR reviewer needs to consider
is the best way to collect the further information he/she feels
is necessary to complete the EIR review.  If the EIR submission
is obviously incomplete and information missing is deemed impor-
tant, the EIR reviewer may request through a warning letter or
an enforcement order issued under the authority of Section
3008, that the owner/operator submit the information.   If a
Part B Notice of Deficiency (NOD) is issued for the facility, the
EIR warning letter should accompany the NOD, if possible.
Additionally, the EIR information request may be included in
an enforcement order that is issued to require additional Part
B information.

     However, the needed information might also be gathered by
the reviewer directly from other sources (e.g., State files)
either during the EIR review or, perhaps, as part of the initial
data gathering efforts for any RCRA Facility Assessment activities
planned under Section.3004(u).  The EIR reviewer must determine
which approach makes the most efficient use of resources while  .
also allowing important information to be gathered in a timely
and complete fashion.

                                                      OSWER POUCY DIRECTIVE NO,

                             '  n '                  9523-00-2

 III.   EIR TECHNICAL REVIEW  (Steps 2 through 6)

 A.   Evidence of Significant Prior or Continuing Release  (Step  2)

     Once the EIR is determined to be complete, the  reviewer
 should review existing data for evidence of significant prior
 or continuing releases from the subject landfill or  surface
 impoundment.  As noted previously, existing RCRA permitting and
 corrective action programs should provide the information to
 answer this question.

 1.   Definition of "Significant Release"

     In the case of ground-water releases, Subparts  F to
 40 CFR Parts 264 and 265 provide regulatory definitions of a
 "release".  Detection of any parameter above background usually
 forces the owner/operator to undertake an extensive  monitoring
 program to characterize the extent of the contamination.
 Therefore, essentially all releases to ground water  from units
 subject to §3019 will be examined through the permitting process.

     Definitions of "release" for the corrective action authorities
 (3004(u) and 3008(h)) are given in the RFA Guidance  and in the
 Preamble to the Codification Rule (50 FR 28713, July 15, 1985).
 These documents define "release" as any spilling, leaking,
 pumping, pouring, emitting, emptying, discharging, injecting,
 escaping, leaching, dumping, or disposing into the environment.
 Furthermore, the "environment" includes all media, i.e., air,
 surface water,  ground water, and unsaturated soils.  The RFA
 process attempts to identify releases that threaten  human
 health and the environment.  Although Section 3019 is concerned
with only human exposure, these definitions used by  the RFA
 process are generally applicable to the 3019 process.

     A "significant" release can be further analyzed in terms of
 the three exposure criteria, i.e., the type and amount of material
 released, possible pathways for migration, and the presence of
 nearby populations.  However, in this initial stage  of identifying
 releases, the primary concern is gathering enough data to confirm
 that a release of potential significance has occurred.  The
extent and seriousness of a release will usually require further
 investigation by the owner/operator.

 2.  Useful Information Sources

    If the EIR does not contain conclusive evidence  of prior or
 continuing releases at the facility, or if the data  concerning
 the release are not complete, then the EIR reviewer  can obtain
 additional data via a number of information sources.  These
 sources are described in more detail in the RFA Guidance, and
 relevant information should be gathered and assessed during
 the  initial stage of the RFA process.

                                                      OSWtR POLICY DiKcCTut .:j.

                                                    9523 .00-2
   a.  RCRA Part B Permit Application

     One of the best sources of information is the Part B permit
application.  Most importantly, information concerning releases
to ground water is a required element of the application.  If
the facility has an adequate well system, the ground-water
monitoring data developed under Part 265 and § 270.14(c) should
reveal if releases to ground water have occurred.  Owners/operators
that have submitted inadequate ground-water data in their Part
Bs must upgrade their monitoring systems or conduct additional
sampling as needed.  See the Draft RCRA Ground-Water Monitoring
Technical Enforcement Guidance Document (August, 1985) for details
in addressing inadequate ground-water data.

     In addition, required Part B information concerning
contingency plans, unit designs, and other features of the
facility can provide useful background on any releases indicated.
The completeness checklist for the EIR given in Attachment II
lists portions of the Part B that may be relevant for assessing
releases .

   b.  RCRA Sections 3004(u) and 3008(h)

     Information concerning releases to surface water, air,
soil, and via subsurface gas may be obtained under the authority
of RCRA Sections 3004(u) and 3008(h), which authorize corrective
action for continuing releases.  Data can be gathered from the
SWMU letter responses,  from the RFA process, and through 3008(h)
Interim Status Compliance Orders.  As described previously,
these authorities will perhaps provide the most effective means
of obtaining additional information.  The EIR reviewer should
consult the RFA Guidance for implementing 3004(u) and the
Porter/Price memo (December 16, 1985) on the use of 3008(h).

   c.  Compliance and Enforcement Records

     Information pertaining to the general compliance and
enforcement status of the facility should be evaluated with the
EIR.   In addition to the records of the operator's compliance
with the 40 CFR 265 requirements for ground-water monitoring, any
problems in compliance with other RCRA Standards may also be
indicative of potential releases.  Both the permitting and
enforcement files should be examined for evidence of improper
management of waste that may have led to releases to any other

     Additional data gathered from other EPA programs, especially
CERCLA and NPDES, may also provide data on possible releases.
Superfund sources that may be useful include CERCLA PA/SI and
RI/FS reports and Reportable Quantity notifications.  Information
from Federal/State air and water agencies, 03HA, and transportation
related agencies may provide further evidence of release 'via

                                                     OSWER POLICY DfRECW't

                                                   9523 . 00-2
 the  air,  water,  worker  management,  and  transportation  pathways,
 respectively.   Especially  useful  are  records  of  chronic  violations
 indicative  of  releases.  Although the owner/operator should
 have summarized  much  of  this  data in  the  EIR,  the  reviewer may
 have to  gather  referenced  documents or  incomplete/missing data
 from these  sources.

 3.   Deciding Future Course of Action

      After  considering  the data  initially available the  EIR
 reviewer  must  decide  whether or not (s)he needs  additional data
 to rule  out or confirm  the occurrence of  a prior (or continuing)
 release.  If the available information  is adeguate, the  reviewer
 may  decide  that  no evidence for a significant  release  exists; in
 this  case, the only Steps  remaining in  the EIR review  process are
 5 and  6,  i.e., the consideration of any impacts  of future releases
 and  possible permit conditions needed to  address these concerns.
 On the other hand, if releases of potential significance are
 known  (or suspected)  to have occurred,  then a more detailed
 examination of the exposure potential is  reguired  as described
 in the following section (Step 3).

      In some cases additional information will be  needed to address
 possible releases to one or more of the exposure pathways.  As
 noted above, these Questions may be answered through the RFA
or normal permitting processes.  Alternatively,  the EIR  reviewer
may be able to gather enough  information  from existing records
or other Regional,  State,  or local officials to  satisfy  lingering
doubts or conerns about particular leaks,  accidents,  etc.

     Figure 2 provides an  example of how evidence  of releases
and possible follow-up actions for each pathway  were summarized,
 following review of an actual EIR and other information regarding
a RCRA site.  While this example was derived from a review of
data from an actual facility, the case was simplified  somewhat
for  illustratative  purposes.   In order to put this example in
perspective, Figure 2 also contains background information on
the site.

     Figure 2 describes the follow up actions that might be
undertaken during Step 2 to determine if a release has in fact
occurred, and whether the  release warrants further investigation.
The EIR reviewer may wish  to write up a short summary  of the
results of his/her  analysis at this stage  in the process.
However,  other reports or  records produced as part of  the
permitting or RFA process  should be adeguate to  document this
stage of EIR review.

                                      -  14  -
                  Fiqure  2.   Example of Summary Sheet Following Initial Review
                             of Release Data:  Release Evidence and Suggested
                             Follow Up.
 Units of Concern:
               Background Summary of Example Site

    A small off-site comnercial facility treats and stores hazardous
    waste; operations  include waste oil/gasoline recycling, cyanide
    waste treatment, solvent recovery, other treatment.

    Surface impoundments are used to store and treat wastes before
    discharge to waste water treatment plant on site.

    The facility is located in an industrialized area, also bounded
    by residential areas.

Ground Water
 Summary of Release Evidence
Existing Part B data not adeguate;
monitoring plan in development.
Possible releases via contaminated
run-off fron area around unit which
enters water through municipal sewer
Systran; subseguent treatment by POTW

Definite release based on odor.
State monitoring program in
development.  Sane corrective
action also taken.
Likely releases from spills,
leaks, and accidents.  Extent
of clean up of these past
releases unclear.
  Possible Follow Up Action
Follow permitting/enforcement
procedures to obtain necessary
monitoring data.

Determine if run-off should be
managed as hazardous waste.
Collect available analytical
data on run-off and determine
if discharge goes to POTW.

Obtain data ?ron air monitoring
program whe:. available, then
consider need for futher inves-
tigation to study extent of
potential exposure and adequacy
of corrective action taken.

Examine any existing soil
analysis undertaken and assess
need for RFA or RFI follow up.

                                     - 15 -
                                             OSWtR POLICY DIRECTIVE NO,

                                           9523  .00--2
                                Fiqure 2.    (continied)
     Release Evidence
 Possible Follow Up Action
No evidence; unlikely for
surface impoundment.
     None necessary.
Facility sweeps nearby streets
to remove dirt, perhaps due to  •
track-out problem;  nay not be
related to operation of surface
impoundments.  No record of
releases from spills off-site.

Occupational records submitted do
not indicate significant illnesses
due to unsafe operating conditions.
No other serious enforcement  problems
found for facility operation,  beyond
those already noted.
Review existing soil  analysis
as noted above.  Consider
requiring o/o to analyze dirt
found on nearby residential
street for likely hazardous
constituents via RFA  or RFI.

     None necessary

                                                     OSWER POLICY DIRECTIVE Me.

 B.   Determination  of  Known/Suspected  Public  Exposures at  •"•  -   , <,- ->
     Significant 'Levels   (Step  3)

      Once a  prior  or  continuing release  from the surface
 impoundment  or  landfill  has  been documented, the EIR reviewer
 must determine  whether the public has been exposed to the
 release, and  if  so, whether  there is  "substantial potential  risk"
 due  to that  exposure  (see §3019(b)).

      The three  human  exposure  elements noted earlier must be
 addressed in order to determine whether the public has been
 exposed to a hazardous release and the significance of this
 exposure.  Listed  below  are the three exposure elements and the
 information  needed by the reviewer to assess the presence of
 these components.  When  a release of concern from a unit is
 identified, then the  reviewer must assess the adequacy of the
 supporting evidence to confirm that all three elements for
 public exposure are documented.

 1.   Human Exposure Component^

   a.  Evidence that the release from the landfill or surface
 impoundment contains hazardous wastes or constituents.
 Documentation would include:

 o   Monitoring data confirming a release from the unit; and

 o   Data indicating that the hazardous materials or constituents
     of concern are present in the release from the unit.

   b.  Evidence that the release containing hazardous materials
or constituents of  concern has migrated off-site (or to on-site human
exposure  point).  Evidence includes:

 o   Monitoring data confirming off-site contamination;  and

 o   Monitoring/modeling data indicating the extent of release
     and  migration via a plausible pathway.

   c.  Evidence showing a likelihood that a nearby population
has been, or is being, exposed to toxic constituents from the
release at levels constituting a substantial risk to human health.
Information needed  would include:

 o   Monitor ing/mode ling data suggesting  that the public is being,
     or has been, exposed (e.g., contaminated drinking water
     wells );  and

 o   Data showing levels of  constituents at the exposure point
     indicative of  a health  threat (e.g., levels exceed  existing
     Agency standards  or criteria).

 2.  Gathering Da'ta to Document Exposure

    a. Use of the Permitting Process

     The permit writer should use the permit process and the
 3004 (u) program to gather information concerning possible releases
 and human exposure.  The first exposure element, the existence of
 a documented release, should have largely been satisfied by a
 positive determination for Step 2.  Any release should be documented
 through the usual permitting process (for ground water) or through
 3004(u)/3008(h) RFA studies (for other pathways).  The second
 element, documented off-site migration, will normally require the
 owner/operator to investigate the extent of migration, both in
 terms of the constituents released and the area contaminated.

     In the case of ground water contamination, the existing RCRA
 Subpart F regulations require the owner/operator to characterize
 the plume of contamination in some detail, and devise a corrective
 action program.  The contaminated ground water must be cleaned up
 to Ground Water Protection Standards set at background levels or
 existing drinking water standards, unless an Alternate Concen-
 tration Limit (ACL) is approved.  An ACL demonstration is
 essentially an exposure/risk assessment for a ground water
 contaminant, and a successful demonstration should be sufficient
 evidence that no potential for significant human exposure
 exists for that constituent.  An unsuccessful ACL demonstration
may still provide information useful to the EIR reviewer in
deciding if human exposure is likely.

      However, the existing Subpart F regulations only require
the owner/operator to clean up contamination to the facility
 boundary.   Section 3004 (v) of HWSA requires corrective measures
 (tor releases to all pathways) beyond the facility boundary, but
 §3004(v) has not yet been codified in the regulations. (Pending
promulgation of these regulations, EPA may issue 3008(h) orders
 to implement the directives of 3004(v).)

     In some cases of suspected off-site migration of unit
releases,  the owner/operator may elect to gather off-site data
 to establish the presence and extent of any contamination.  In
 the past,  cooperative owner/operators have been willing to
monitor off-site ground water for plume movement in order to
devise adequate corrective action plans, or to support ACL
demonstrations.   Permit writers are encouraged to try to obtain
data on oft-site releases from willing owners /opera tors.

     for releases to pathways other than ground water, the
owner/operator may be required to gather data on the extent of
contamination under either 3004(u) or 3008(h) authorities.  The
permit writer must realize,  however, that an investigation under
 3004 (u) on the extent of the contamination may not be initiated
 until  after the permit is issued.  Generally, compliance schedules
will be used in the permit to require the owner/operator to

                                                    OSKVER POLICY DIRECTIVE

                               "  18  '              i9523  .00*2
 conduct  a  RCRA  Facility  Investigation  (RFI)  under  3004(u).   Some
 information  on  tTie level  of  contamination may  be gathered  from
 the  owner/operator's  response  to  the initial SWMU  letter and
 from the RFA investigation performed under 3004(u).   However, in
 most cases,  monitoring results at this  stage will  probably be
 focused  on detecting  a release from a SWMU, not on determining
 the  extent of contamination.

      Because  RFIs  reauired under  3004(u)  will  not  generally  be used
 to gather  data  prior  to permit issuance,  the permit writer (in
 conjunct ion with appropriate enforcement  staff) should  consider
 whether  enforcement orders are needed to  ensure an  investigation
 of releases  and the likely human  exposure potential before permit
 issuance.  The  following  section  describe  the enforcement
 authorities  that might be used and the  situations  that may warrant
 their use.

   b. Use  of  Enforcement  Orders

     An  enforcement order may be  issued to reguire  the
 owner/operator  (o/o)  to gather information (on-site or  off-site)
 under 3013 or 3008(h) authorities for releases to  ajiy pathway.
 The  issuance  of a  3013 order reauires evidence showing  that  the
 presence or release of hazardous  waste  from a  facility may present
 a substantial hazard  to human health or the environment.   Note
 that 3013 gives EPA the authority to perform any needed investi-
 aations  and recover the costs later  if  the o/o is  incapable  of
 (or  refuses to) gather the reguired information.  The use  of a
 3008(h) order requires evidence that a  release (to  any medium)
 has  occurred.  See the RCRA Ground-Water  Monitoring Complicance
 Order Guidance  (August, 1985) for a description of  these two
 types of orders, and  the  recent Porter/Price Memo on the use of
 3008(h), "Interpretation  of Section 3008(h) of the Solid Waste
 Disposal Act" (December 16, 1985).

     Whether to undertake the investigation of a release from a
 facility through the  permitting process or an enforcement  order
i.r^\^.i.LX\-.y u i ii_ v-su v^ii u ii^ ^/^ t, iiii u u J. 1114 \Ji~ w v w o .3 w j. ait c 11 i.w i- \~ ^ uic iiu w i. va<^ J.
will depend on Regional priorities, resources, and various site
specific factors.  This decision will encompass considerations
that go beyond the human exposure concerns of the 3019 EIR review
process.  For example, 3008(h) orders may be used when a release
is migrating rapidly and may move off-site.  In addition, the
corrective action programs will be used to investigate releases
from all suspect SWMUs at a facility, not just regulated landfills
and surface impoundments.

     Another important factor to consider is how close the
facility is to receiving a permit.  If permit issuance appears
likely within the near future, the permit writer might decide to
incorporate a compliance schedule for a RFI in the permit, rather
than hold up the permit while awaiting the issuance of an order
to gather more information.  A related concern is the level of
cooperation exhibited by the owner/operator in the past, and the
likelihood that he will meet the compliance schedule for RFI in
the permit.

                              - 19 -
                                                       POLICY DIJJECriVt NO,

     Situations-which might prompt the permit writer to seek more
immediate exposure information than could be provided through
the 3004(u) process include cases in which the existing data
indicate a high potential for human exposure.  The EIR reviewer
should undertake a preliminary analysis of available information to
estimate the potential impact of a known release.   For example,
if evidence of a release and movement off-site to  surface water
exists (e.g., fish kill, complaints of tainted water), the EIR
reviewer should consider the likelihood of releases from the
unit reaching surface water (distance to river, characteristics
of intervening terrain), potential transport and dilution
(river flow and size vs. potential release, the properties of
likely constituents in a release), and the likelihood of human
exposure (distance to downstream intakes, other uses of surface

     After such a preliminary analysis, the EIR reviewer may  -
determine that the release requires attention prior to permit
issuance.  In such cases, the EIR reviewer should  consult with
enforcement and permitting personnel to map out an appropriate
strategy (which may include the use of 3008(h) or  3013 orders)
to obtain the needed data and initiate corrective  action.

     Even in cases of suspected human exposure, the RFI may be
implemented through the use of 3004(u) compliance  schedules if
there is no current (or imminent) exposure potential.  For example,
a case of past human exposure (e.g., eating of contaminated
fish)  due to a prior (but not continuing) release  to surface
water, might be addressed after permit issuance if no current or
imminent human exposure is expected. [Note, that if the elements
of exposure can be adequately documented, these situations may
still be candidates for referral to ATSDR as described in
Section III.C.2.]

   c.   Other Sources of Information

     Many of the additional information sources used in determining
evidence of a release may also provide data on migration of the
waste off-site and possible human exposure.  Particularly important
at this stage in the review is any evidence of health complaints
related to the site.   Public submissions may provide indications
of exposure.  For sites with suspected human exposure, local or
State health departments should also be contacted  by the EIR
reviewer to check for any reports of health concerns in the
immediate vicinity of the facility.  It is important for Regional
and State permitting -staff to establish contacts with the local
health departments for sites at which real problems may exist.
For sites that are eventually referred to ATSDR for health asses-
sments, one of the first steps taken by ATSDR would be to contact
these local departments for health complaints in the area.

3.  Technical Assistance

     The EIR reviewer is encouraged to use all of  the above infor-
mation sources and routes for gathering the data necessary to

                                                  OSWER POLICY DIRECTIVE
                             - 20  -

confirm che existence  (or absence) of all three e*x fro Hi re "coin-
ponents (release, migration, receptor location).  After examining
the data gathered under the  permitting and enforcement processes,
the EIR reviewer may have some questions concerning the potential
health impacts of documented/suspected human exposures.  The primary
contact for technical  assistance will be the Permit Assistance
Team (PAT) at Headquarters as described below.  The capabilities
and possible uses of ORD and ATSDR are also discussed.  Finally,
existing EPA manuals which could provide the EIR reviewer with
possible approaches for interpreting the assembled data are

   a.  Permit Assistance Team (PAT)

     The EPA Permit Assistance Team (PAT) at Headquarters
(FTS/382-4740) stands  ready  to provide technical assistance,
to coordinate assistance from ORD and ATSDR, and to provide help
in deciding when referral to ATSDR is warranted."  ORD and ATSDR
may, to a limited extent, be accessed directly by the EIR reviewer
on a consultative basis by telephoning the appropriate individuals
(see below).  Such informal  consultations could provide quick
response to questions  on possible health effects raised by infor-
mation available at that point.   However, if the EIR reviewer
needs more extensive technical assistance (e.g., detailed review
of written reports, monitoring data, models, etc.), (s)he should
contact the PAT at Headquarters.  The PAT will draw on the
expertise available within OSW,  other EPA Offices, and ATSDR
as needed to respond to the  Regional request for assistance.
If warranted, health assessments may be recommended for some
facilities, as described in  Step 4 of EIR review process.

   b.  Office of Research and Development (ORD)

     The office within ORD which may be useful to the EIR
reviewer is the Office of Health and Environmental Assessment
(OHEA).  Within OHEA,   the two groups which can provide the most
assistance in evaluating EIRs are the Exposure Assessment Group
(EAG),  located in Washington, D.C., and the Environmental Criteria
and Assessment Office  located in Cincinnati, Ohio (ECAO-Cin).

     ECAO-Cin can provide assistance in determining whether any
constituents found at  off-site exposure points constitute a
public health threat at measured or projected exposure levels.
ECAO-Cin has developed a Rapid Response Toxicity Program to aid
Regional and State offices in quickly (i.e., 48 hrs.) evaluating
potential human health hazards posed by chemical releases.
These responses may include: rough estimates of cancer risk or
toxic potential; identification of key chemicals for further
monitoring; a rough description of possible exposure situations
and their potential health hazards; and some recommendations for
future assessment efforts.

                                                     OSWER POLICY DIRECTIVE N&

                              - 21 -               9523 .00=2

     Most recommendations will require the involvement of EAG to
evaluate monitoring data/methods and for a discussion of likely
exposure scenarios and their uncertainties.  While this program
is designed to provide only preliminary estimates of health
hazards, more detailed site assessments can also be provided.
Requests for rapid technical response from ECAO-Cin may be
forwarded directly to Chris DeRosa (FTS/684-7534).  Requests for
more detailed assessments should be sent to the PAT, which will
coordinate ECAO/EAG assistance.

     Through the PAT, OHEA may be able to help the EIR reviewer
complete an exposure/risk analysis to project the likely effects
from past or ongoing exposure to hazardous constituents.  With
the expertise available in OSW and ORD, the PAT can recommend a
variety of models for use at a particular site, and may be able
to assist in using this type of analysis in determining the
extent of constituent transport via the usual pathways and the
likely levels of contamination at projected exposure points.
The PAT may also provide assistance in reviewing any analyses or
projections submitted by the owner/operator.

   b.  The Agency for Toxic Substances and Disease Registry

     RCRA §3019 specifically identifies ATSDR as a potential
participant in the evaluation of exposure information.  ATSDR is
an agency within the Public Health Service, Department of Health
and Human Services.  Its overall function is  to carry out
health-related responsibilities under CERCLA and RCRA.  An Inter-
agency Agreement (IAG) has been established to define RCRA-ATSDR
interactions, and a Memorandum of Understanding  (MOU) is currently
under development.

     Sites will be referred to ATSDR when a health assessment is
warranted, as described in Step 4(b).   ATSDR has the ability to
perform several different levels of health assessment (see
Attachment III), and the more extensive studies will usually be
preceded by more limited investigations.  ATSDR's major task in
any level of health assessment will be to evaluate populations
with known (or suspected) exposure to hazardous constituents
as a result of a release from a regulated surface impoundment or

     As noted in the Attachment III,  ATSDR may also provide
informal "health consultations" to provide health advice and/or
health effects information regarding  a specific site.  The Regions
should limit their consultative use of ATSDR before referral
to situations that require relatively short-term assistance,
e.g., assistance available through a telephone call.  Requests
for more extensive work should be sent to the PAT (ATSDR will
also have a representative on the PAT), and the PAT will coordinate
ATSDR assistance.  The EIR reviewer may contact Ralph Touch at
ATSDR (FTS/236-4551) directly for short-term technical assistance.

                                                     OSWER POLICY DIRECTIVE NO.

                              - 22 -               9523 . 00- 2
       Technical Documents
     The EIR reviewer may consult a number of EPA manuals
which provide a variety of approaches in assessing the exposure
potential and health impact of releases from hazardous waste
sites.  As mentioned previously, the RFA Guidance may prove
useful in the early stages of release investigation.   Perhaps
most helpful in cases when the EIR reviewer feels a more extensive
analysis of exposure potential is waranted is the Superfund
Public Health Evaluation Manual (December, 1985)  and  the companion
Superfund Assessment Manual (January, 1986).  Copies  of these
manuals have been distributed to Regional Division Directors and
Branch Chiefs; current information on the availability of these
documents may be obtained by contacting OERR (382-2182).

     Elements of the Public Health Evaluation Manual  that may be
useful in cases where serious exposure problems are suspected
include: procedures for selecting indicator chemicals;
physical/chemical and toxicity data for chemicals; and a summary
of existing EPA standards and criteria for hazardous  substances.

     The Exposure Assessment Manual is a complex  and  highly
technical compendium of approaches and models to  use  in assessing
exposure potential.  The data requirements of the various models
discussed are provided.   The extensive data needs illustrate
the major problem in undertaking such a detailed  analysis,
i.e., much of the information needed to use quantitative modeling
will not be available at many RCRA sites, and expensive and
lengthy data gathering efforts would be required.  Therefore, the
EIR reviewer is urged to limit the use of complex models unless
the data are available,  and may seek assistance in the use of
these manuals from the PAT.

C.  Possible Actions in Cases of Human Exposure
    (Steps 4(a), 4(b), and 4(c))

     If the EIR reviewer believes that more information is required
to decide if a release has resulted in known or suspected exposure
to the public at significant levels, (s)he should obtain the
necessary data as outlined above.   If (s)he decides that the
criteria for human exposure (see Section III.B.I) are not met,
and that significant human exposure is unlikely,  then the EIR
reviewer must still consider whether corrective action is needed
to clean up the release (Step 4(c)).  After this, the reviewer
should also consider the impact of future releases (Step 5) and
possible permit changes, if needed (Step 6).  These steps are
discussed in later sections of this guidance.  The EIR reviewer
may wish to prepare a short report for the administrative record
summarizing decisions not to refer facilities for health assessments.
Such reports may be useful documents tor explaining the decision
during public hearings.

     If the components for human exposure given in Section III.B.1
are present, there are several actions the EIR reviewer should

                                                       OSWER POLICY DIRECTIVE NO.

                            - 23 -                    9523 .00* B

consider.  These._ actions include implementing interim remedial
actions with appropriate public involvement (Step 4(a)), referral
to ATSDR for a health assessment (Step 4(b)), and final corrective
action  (Step 4(c).  Which actions are completed and the order
in which these activities are pursued will depend on the situation;
normally, however, the need for interim measures should be
assessed first to insure that continuing public exposure is
minimized.  Furthermore, while a completed health assessment
could be useful in designing a final corrective action plan,
corrective action should not be significantly delayed.

1. Interim Remedial Action  (Step 4(a))

     Interim remedial measures may be necessary to prevent
further human exposure.  These may be pursued through the various
enforcement and program authorities available to EPA, such as
RCRA Sections 3008 and 7003, and CERCLA Sections 404 and 106. -
Examples of interim remedial action would include off-site and
source control measures, such as:

   o  evacuation of the public from the area if the problem is
      so serious as to pose an imminent and substantial

   o  requiring the owner/operator to provide bottled water
      and/or drinking water treatment when public drinking
      water is the pathway of exposure;

   o  temporary suspension of facility operations that may cause
      or exacerbate the problem;

   o  temporary removal/storage of wastes of concern, and
      other interim measures to contain or prevent releases (e.g.,
      berm stabilization).

The EIR reviewer should consult with appropriate permitting and
enforcement staff to map out a plan for needed remedial actions.
A review of response actions available under §3008(h) may be found
in the draft guidance, "RCRA §3008(h) Corrective Action Interim
Measures", issued by OWPE (latest draft,  May 13, 1986).  The reviewer
should also contact public participation staff in order to design
and implement a public information program to inform the public of
the health concerns associated with the facility and the immediate
and long-term actions planned to address the problems.

2. Referral to ATSDR for Health Assessment  (Step 4(b))

   a.  Referral Authority and Concurrence

     If there is sufficient evidence that a release from a
regulated surface impoundment or landfill has resulted in
significant human exposure  (i.e., if the three necessary components
of exposure have been established for any of the exposure pathways),
then EPA (or authorized States) may refer the facility to ATSDR
for a health assessment (Step 4(b)).  While the statute originally

                                                        OSWER POLICY DIRECTIVE N(

                                                      * O & &  . \)\
assigned the authority to refer a facility to ATSDR to the  EPA
Administrator, this authority has been delegated to the Regional
Administrators.  The Regional Administrator,  if" (s)he so chooses,
may redelegate the authority to the Division  Director level.
     However, the Delegation provides that, before seeking a
health assessment from ATSDR under §3019. the Region must obtain
the concurrence of the Assistant Administrator for Solid Waste and
Emergency Response.This concurrence requirement is designed to
ensure that important sites are assessed first, and to encourage
national consistency in the types of sites that are referred to
ATSDR.  Regions seeking concurrence for referrals to ATSDR should
contact the Permit Assistance Team (PAT) at EPA Headquarters
(contact Terry Grogan or Bob Kayser, FTS/382-4740).   The PAT will
coordinate the review of the information by OSW, OWPE, ATSDR, and
other EPA offices (e.g., ORD) as needed, and make recommendations
to the Assistant Administrator concerning the referral.

   b.  Documentation of Referral Request

     When a Region believes that a health assessment by ATSDR is
necessary, the EIR reviewer must prepare a written report for submission
to Headquarters which summarizes the exposure analysis completed
to date, and identifies the pathways of concern.  This report will
serve several functions, including: (1) forcing the EIR reviewer
to formally consider the adequacy of the assembled evidence prior
to referral; (2) allowing the Headquarters concurrence group to
review the data in a timely manner; and, (3) providing a useful
summary document for initial review by ATSDR, if a health assessment
is required.

   ,  This report must summarize the evidence that the three elements
for human exposure are present at the site.  Section III.B.1
describes the kinds of evidence needed to document human exposure.
The report should follow a logical format and should include:

0  background information on the facility (location, types of
   wastes handled, brief description of all units on site, nearby
   land use, map of facility);

0  evidence confirming a significant release from the regulated
   surface impoundment or landfill (monitoring data and the level
   of confidence in data, all hazardous constituents detected,
   approximate quantitity of wastes released, identification of
   major constituents in waste);

0  evidence indicating extent of contamination and migration path-
   way of released constituents (monitoring data or modeling results
   showing movement off-site, the ranges of substances detected
   throughout contaminated area);

0  evidence indicating a likelihood of human exposure via ingestion,
   inhalation, or direct contact at levels suggesting a potential
   health threat (location of nearby populations, monitoring

                                                     <*WER P8yCY DIRECTIVE NO.

                               -  25 -               9528 .00=2

    data at exposure point, health complaints from public, records
    of  local health departments,  constituents measured or projected
    at  levels exceeding Agency  standards or other health-based

 0   on-going or planned activities to collect more data and institute
    remedial action at the site (including public participation

 0   results of any preliminary evaluations or assessments of site
    data undertaken by the State, Region, ORD, ATSDR, the o/o, or
    others ;

 0   level of health assessment sought (if possible, include specific
    questions); and,

 0   name and phone number of Regional/State contacts most familiar with
    details of the site.

     The report should summarize pertinent monitoring data in
 tabular form with clear indications (i.e., on a map) of the sampling
 locations.  Any analysis of the data (e.g., by the owner/operator,
 contractors, Regional/State staff) should be succinctly described,
 and any references used must be cited.  While the level of effort
 required to prepare the referral report will vary with the complexity
 of  the site, the report should be a summary document, not a lengthy
 treatise on the facility.  Source documents (Part B, EIR, etc.)
 should be referenced for details, and copies of important pages
 from these documents may be provided.

 3.  Corrective Action  (Step 4(c))

     Corrective action will be considered whether or not the EIR
 reviewer determines that significant exposure to the public has
 occurred.   If exposure routes have been documented and a health
 assessment is initiated, appropriate permitting and enforcement
 staff should be kept informed.  Permit and/or enforcement staff
 developing the corrective action plan should coordinate the plan
with the health assessment, if necessary.  The level of clean-up
may be affected by the results of the assessment, if for example,
 the health assessment uncovers a causal link between the level
 of  the hazardous constituent at the exposure point and the parti-
 cular health effects in the exposed population.  In most cases,
 however, the permit writer is urged to proceed with permit issuance
 to  begin initial clean up activities if the available data on
 the extent of contamination are adequate.  The permit may be
modified to incorporate any useful information arising out of
 health assessment activities.  As described in section III.B,
 §3008(h) orders may be used to institute corrective action prior
 to permit issuance.

     The EIR reviewer may decide that the evidence does not
 indicate that significant public exposure due to prior/continuing
 releases has occurred, and therefore,  that referral to ATSDR is  not
 warranted.  However, the permit writer should still examine the  need

                                                    OSWER POUCY DIRECTIVE NO.

                              -26-              9523.00*2

for corrective measures to lessen the possibility of future
exposures to past releases.  In the case of ground-water
contamination, of course, the Subpart F regulations (§264.100)
require clean up to levels set by Ground-Water Protection Standards.
There are other corrective action measures to take and several
vehicles for requiring these measures.  Guidance is being developed
to assist the permit writer in instituting corrective measures
under 3004(u), 3004(v), and 3008(h).  These authorities are the
primary vehicles available to the permit writer for clean up of
releases from regulated units to media other than ground water.

     In those situations involving an imminent and substantial
endangerment to public health, EPA may take action under 7003 of
RCRA or 106(a) of CERCLA to institute remedial action.  The
"Endangerment Assessment Memorandum" issued by J. Winston Porter
(November 22, 1985) provides guidance on the preparation of
endangerment assessments to support all administrative and judicial
enforcement actions under CERCLA Section 106 and RCRA Section
7003.  An endangerment assessment must be developed in order to
document and justify that an imminent and substantial endangerment
to public health or welfare exists.  A supplement to the Guidance
has also been prepared by the Office of Waste Programs Enforcement,
in draft form, entitled the Endangerment Assessment Handbook
(August, 1985).

     These authorities described above allow EPA to force clean
up of releases prior to actual human exposure.  Therefore, the
EIR reviewer and/or permit writer should consult with enforcement
staff in cases that warrant corrective measures prior to permit
issuance.  Section III.E. of this guidance should also be consulted
for possible use of the new "omnibus" provision (3005(c){3)) in
establishing additional permit conditions to address potential
exposure concerns.

D. Determining the Potential for Significant Public Exposure From
   Future Releases (Step 5)

     In addition to evaluating prior/continuing releases from all
regulated surface impoundments or landfills (steps 2 through 4  in
Figure 1), the EIR reviewer must also address the potential for
human exposure in the case of future releasest (step 5).  As such,
Step 5 is the most conjectural part of the EIR review.  When
reviewing EIRs for new landfills and surface impoundments, the
EIR review will  consist only of this Step and Step 6, consider-
ation of permit  conditions necessary to prevent human exposure.
The timing of Step 5 may vary depending on the need to investigate
prior releases.    In addition, the EIR reviewer and/or permit writer
may wish to use  this analysis of the impact of future releases
as a tool in focusing attention on human exposure potential
throughout the permitting and RFA/RFI processes.
f'Future releases" also include releases that may have already
 occurred, but are not yet detected.

                                                   OSWER POLICV DIRECTIVE

                              ' 27 '              9523.00-2
1. General Approach
     The reason for examining the impact of future releases is
to highlight pathways of concern and allow permit conditions to
be modified or strengthened to mitigate site-specific potential
problems (Step 6).  Of course, the occurrence of prior releases
to a particular pathway, and any evidence of subsequent migration
and human exposure,.should be used as the primary indicator of
the potential impact of future releases.  This is why the flow
chart in Figure 1 also leads the EIR reviewer to consider the
impacts of future releases (Step 5) after the process for prior
releases (Steps 2-4) is followed.

     In the absence of a history of past releases, however, the
EIR reviewer should consider the potential exposure if a release
should occur.  The EIR reviewer is encouraged to,use a qualitative
approach for screening facilities for possible exposure concerns
from future releases.  In a limited number of cases a more detailed
evaluation may be warranted if the initial qualitative screen
indicates that a future release from the unit is likely to result
in significant human exposure.  In these cases, the permit writer
may wish to quantify possible exposure scenarios in order to
justify the imposition of permit conditions that go beyond the
existing Part 264 standards (see next section for a discussion
of the new "omnibus"  provision).  Future guidance will provide
information on applying a more quantitative approach.

     The EIR reviewer may follow the general approach outlined
below to qualitatively screen units.  This approach examines the
same elements for exposure as defined for past releases (i.e.,
release, migration, and receptor location).  Due to the prospective
nature of the evaluation, however, the approach first examines
the route characteristics and receptor information assuming a
release occurs.   If a potential concern is identified, the design
and operating features of the unit should be critically examined
for their adequacy to prevent or detect releases.   The infomation
needed to evaluate the major pathways should be available from
the EIR, the Part B,  or the other information sources mentioned
in Section I.

     The requirement under 3019 to consider the impact of future
releases (i.e.,  Step 5) has many features in common with the RCRA
RFA process designed  to implement 3004(u) and 3008(h).  The
potential for future releases becomes an important factor if the EIR
reviewer decides that a particular pathway is of concern.  There-
fore, the EIR reviewer (and permit writer) should use the results
of a RFA investigation as a valuable source of information in
deciding if the  location, design, and operating features of the unit
are adequate to prevent (or render less likely) future releases
to pathways of concern.

     Because the RFA and EIR review processes share many similar
concerns relating to the potential for a release and subsequent
migration off-site, many elements of the methods given in the RFA
guidance have been incorporated into the following qualitative

                                                     OSWER POLICY DIRECTIVE N&
 approach.   The  followinq  sections describe  important  factors for
 each  pathway  that  should  by  considered  in an  initial qualitative

 2.  Pathway-Specific Factors

    a.  Ground Water

      The EIR  reviewer should examine the pertinent hydrogeological
 and geoloqical  factors  of the site, as well as the location of
 possible tarqet populations, in order to assess the potential
 impact it_ a future release to the ground-water pathway occurred.
 The important route characteristics and receptor information to
 examine are described below.

 Route Characteristics Affecting Exposure Pptentia.1

     An evaluation of the ground water pathway should indicate
 the potential for  contaminant movement through the unsaturated
 zone  to the aquifer and subsequent off-site migration in the ground
 water to human  receptors.  Therefore, the important characteristics
 to examine should  include the soil characteristics (i.e., per-
meability) of the  unsaturated zone, the depth of the aquifer, and the
 flow rate and direction of the ground water.  If the hydrogeology
of the site is properly defined in the Part B (including at least
the permeablity of the saturated zone and the hydraulic head),
the EIR reviewer should be able to estimate the time-of-travel (TOT)
 for the ground water to the facility boundary, and perhaps to
the nearest off-site downqradient well.  Other factors which may
be important at some sites include the local climate (e.g. , net
precipitation, which would effect the generation of leachate),
the existence of confined aquifers, the discharge of ground
water to surface water, and seasonal variations in the water

     Receptor information of prime importance include the location
of the nearest down gradient wells, the uses of the ground water
 in the area, and magnitude of the population served by nearby wells.
While  drinking ground water is an obvious exposure route, other
ground water uses may lead to human exposure through contamination
of food crops (irrigation uses) or other food products (milk).   In
addition, nearby populations may be impacted if the site character-
istics promote basement seepage into nearby buildings.

     An example of a site of obvious concern would be one at which
the unit overlies a highly permeable unsaturated zone (sand, silt,
permeability > 10~4 cm/sec), the aquifer is shallow,  the ground-
water flow is moderately fast,  perhaps due to faults, joints,  or
solution channels  (TOT to facility boundary < 5  yrs.), and
nearby drinkinq water wells lie down qradient (TOT to nearest
well < 10 yrs.).  Conversely, if the aquifer were situated
below an extensive impermeable layer (clay;  permeability < 10"~6
cm/sec), the qround water flow was slow (TOT to facility boundary
 > 50 yrs.), and the aquifer was not presently used by nearby

 populations, then the EIR reviewer could decide that exposure's"
 via  this route are unlikely if a release occurred.

      Situations which are not so clear-cut may still be of only
 limited concern if either a reasonable migration route (i.e.,
 moderately fast ground water flow to off-site wells),  or likely
 target receptors (i.e., nearby populations using the ground
 water) are not present.  For these intermediate cases, however,
 the  EIR reviewer may require more information on the hydrogeology,
 receptor locations, or aquifer uses.  More definitive guidance
 on evaluating ground-water vunerability may be found in the manual
 Criteria for Identifying Areas of Vunerable Hydrogeology Under
 the  Resource Conservation and Recovery Act (OSWER7 July,1986).
 The  EIR reviewer should refer to this guidance if a more complete
 analysis of ground water location characteristics is warranted.

 Unit  Design and Operating Features         •

      If the EIR reviewer has some concerns about the possible
 exposure to the public from releases to the ground water, then
 (s)he should undertake a review of the relevant design and
 operating features of the unit.  The relevant features of landfills
 and  surface impoundments are related to the containment of
 leachate and the leak detection/monitoring systems.   The adequacy
 of the liner and leachate collection systems, leak detection
 procedures (e.g. , routine leachate analysis), and the ground-water
monitoring systems around the units should be reexamined.  During
 this examination, the EIR reviewer should decide if any modifications
 to the existing systems are necessary to reduce the likelihood
of releases (or increase the probability of detecting  releases)
 to the ground water.   Any special waste characteristics, or pre-
 treatment process that might affect the amount of liquid waste
managed should also be considered.

   b.  Surface Water and Drainage

     Assuming a release might occur, the EIR  reviewer  should first
 evaluate the potential for human exposure.  Releases that occur
 to surface water and off-site surface drainage areas may arise
 from leaks, surface run-off, spills, or floods.  The effectiveness
of pertinent design/operating features should be examined if the
 EIR reviewer concludes that this pathway is of concern.

 Route Characteristics Affecting Exposure Potential

     The primary considerations in evaluating the potential
 for human exposure for this pathway are the proximity  of the
 unit to surface water, the likelihood that a  release would
migrate overland, and the current uses of the surface  water.
 Therefore, the requirements for a realistic surface water pathway
 for human exposure generally would include all of the  following:

                                                    OSWER POLICY DIRECTIVE NO.
                              -  30  -               -


 0  surface  water  located  close to the  unit;

 0  the  characteristics  (slope, soil type, vegetation, paved areas)
   of the likely  paths  for  run-off  from the unit are sufficient
   for  a  relase to  reach  the water; and

 0  use  of the surface water for drinking water, commercial fishing,
   shellfish harvesting,  or extensive  agricultural (irrigation of '
   food crops) or recreational uses.

     For example,  releases from units located in topographically
 depressed areas are unlikely  to leave the site as run-off.  Also,
 facilities located close to surface water may still be unlikely
 to contaminate this medium if the  intervening terrain is
 characterized by sandy soil and heavy vegetation; in this case
 run-off is likely  to migrate  into the unsaturated=or saturated -
 zone.  On  the other hand, a pathway characterized by clayey
 soils, little vegetation, and/or the  presence of natural or
 man-made run-off routes  (e.g., ditches, paved areas, storm sewer
 systems, etc.) may indicate a potential problem if the usage of
 the surface water makes  human exposure likely (e.g., drinking
 water intake or commercial fishing areas are a short distance
 downstream).  The permit writer should also consider possible
 discharge of contaminated groundwater into surface water.

     In the case of a likely route to the surface water, the EIR
 reviewer may examine the features of the surface water itself
 to estimate the impact of a release.  For example, a release
 from a relatively small surface impoundment or a limited amount
of run-off frcm a nearby landfill may not have a significant
 impact on a large, fast flowing river due to dilution.  However,
 the validity of this type of  assumption depends to a great
degree on the  characteristics of the chemical constituents
which might be released, i.e., the toxicity and fate/transport
properties of  the substances.  If the EIR reviewer feels that a
more detailed  evaluation of the potential for significant exposure
due to future  releases to surface water is required, (s)he may
 refer to the procedures contained in the RFA Guidance which
discuss how to assess such releases.

Design and Operating Features

     If a sionificant potential for exposure due to a future
release to nearby surface water exists, the EIR reviewer should
examine the pertinent-design  features.  The effectiveness of
 landfill and surface impoundment run-off and erosion controls,
the adeguacy of collection and secondary containment systems,
overflow alarms, automatic cut-off  systems, and dike design
should be considered for surface impoundments.  .(The EIR reviewer
should also consult' an OSW policy memorandum from John Skinner
 to the Regions dated November 14, 1985 for details on the manage-
ment of precipitation run-off at landfills).   In addition, if the
unit is within the 100-year foodplain, procedures to ensure

                               - 31 -
                                                  OSWER POLICY DIRECTIVE NO.

 protection  from-wash-out  during  flooding  should  be  reviewed.
 The EIR reviewer and/or the  permit  writer should decide  if changes
 or additions  to  the  unit  design/operating features  in the permit
 are needed  to address  potential  exposure  from  releases  to a
 surface-water pathway  identified as a concern.

    c.   Air

      In general,  the two  types of air releases of concern are
 continuous, chronic  releases, and releases that  are  intermittent
 and sudden  in nature.   Continuous air releases associated with
 surface impoundments usually arise  from the volatilization of
 oroanic constituents of the waste handled.  For  landfills, air
 releases may  occur by  volatilization through inadeguate  daily
 covers, or  by narticulate  releases generated by  filling  operations
 or wind erosion.   (Subsurface gas is a uni-gue  ty,pe  of ai.r. problem
 treated separately in  the  next section).   Intermittent air releases
 may result  from  accidents  (fires, explosions) occuring during
 the mishandling  of incompatible, reactive, or  ignitable wastes.

 Route Characteristics  Affecting Exposure  Potential

     Population  density and distance from  the unit  are the primary
 factors in the potential  for exposure to an air  release.  Another
 factor  to consider is  if  people are located along the line of
 the predominant wind direction at the site.  While wind  velocity
 and direction  are variable at most  locations, people located
 along this vector are  more likely to receive increased exposures
 to  air  releases  (esoecially chronic releases).   In general,
 however, releases to the atmosphere may be rapidly dispersed
 throughout the area  around the facility, and some exposure to
 any of the nearby populations may occur.

 Design and Operating Features

     Because  route characteristics are of  limited use in
 determining if a release from a unit would pose an exposure
problem, the  EIR reviewer may instead focus on the potential for
air releases.   This apnroach is essentially identical to the
approach incorporated  in the RFA Guidance and the EIR reviewer
 should refer  to this manual for details.In general, this approach
 relies heavily on the  characteristics of the wastes handled and
 unit design/operating  features to uncover potential releases.
For example, an impoundment with a large surface area containing
 fairly concentrated solutions of volatile organics may warrant
examination if people  are immediately downwind from the unit.
Conversely, surface impoundments handling wastewaters containing
only non-volatile metals should not pose a significant exposure
 problem.  If volatile  wastes are handled at the unit, and population
centers are nearby, the EIR reviewer should examine (and consider
permit changes to correct) unit characteristics that may promote
air releases,  such as: large, uncovered surface  impoundments,
 treatment methods using aeration, inadequate daily/permanent
 landfill covers,  and trench fill operations.

                               -  32 -
                                                    OSWER POLICY DIRECTIVE K3.

      Potent! al "release  and  exposures  to  nearby  populations due
 to accidents  such  as  fires  and  explosions  also  will  depend on
 waste  characteristics.   If  siqnificant amounts  of  iqnitable,
 reactive,  or  incompatible wastes  are  handled, the  EIR  reviewer
 should  examine  the  Part B submission  to  ensure  that  the relevant
 264 standards  (264.17,  264.312-314,  264.229-230) are adequately
 addressed.  Waste  analysis/management plans, including procedures
 to identify  such wa-stes when  received and  special  handling,
 treatment, or mixing  procedures employed,  should be  scrutinized
 to ensure  that  additional oermit  conditions are not  needed to
 prevent  violent reactions,  fire,  or exolosions.

    d.   Subsurface  Gas

     Routine subsurface qas releases  are most likely from sites
 where biodegradable wastes  are  manaqed.  Landfills used for
 codisposal of putrescible refuse  with hazardous waste pose the
 most serious problem because  of the potential for  other volatile
 hazardous  constituents  to become  mixed with the methane generated
 from the decomposable material.   If codisposal  has not occurred
 (and will  not occur in  the  future), the  EIR reviewer may generally
 disregard  this exposure  pathway.  However, if codisposal is
 known or suspected, the factors that  affect migration of subsurface
 gas should be examined.

     If an analysis is  warranted  by codisposal practices, the
 RFA Guidance should be  consulted  for details on procedures to
 assess the potential for release  and off-site migration of sub-
 surface gas.  Subsurface gas  migration may be facilitated by
 man-made underground conduits used for power lines, drainage/sewer
 pipes, and teleohone cables.  The presence of natural or engineered
 barriers or controls (surface water, ground water, synthetic
 liners, slurry walls,  gas venting systems) will impede or prevent
 lateral miqration of qas produced.  The geological setting and
 climate will have a large impact on gas movement,  e.g., soils
with high permeability  and effective porosity tend to allow
upward (rather than lateral)  gas miqration, while  relatively
 impermeable (or frozen) soils may promote  lateral  movement.
 Nearby buildings must also be present in order  for subsurface
gas to consitute a potential  threat via explosion  of methane
 gas, or through human exposure to toxic gases (e.g., vinyl chloride)

     If codisposal at a  landfill  is known or suspected, and if
the site characteristics promote the lateral migration of gas
to nearby buildings, then a potential for human exposure exists.
Any existing monitoring or control systems for subsurface gas
should be examined, including any passive venting designs (gravel
walls,  vents to surface), any active recovery system/ and treatment
procedures used for recovered or vented gas.  Normally, the
usual path to assess the significance of  this pathway would be
as part of a RFA investigation.  Probably only after completion
 of the RFA (and RFI, if necessary) would the permit writer consider
additions to the permit that would address these concerns, e.g.,
 installation of gas venting systems.

                                                  OSWER POLICY DIRECTIVE NO.

                             '  33 '               9523 .00-2
   e.   Soil
      Potential  exposures  due  to  direct  contact with  contaminated
 soils should  be  negligible  if  the site  at  which  the  unit  is  located
 has  the  required security  (see relevant section  of Part B).
 Therefore,  the  crime concern  should be  intermedia transfer of con-
 taminated soil  to another pathway and subsequent off-site transport.
 For  example-,  any potential  for transport off-site by run-off to
 surface water or through  wind  dispersion to  air  should be examined
 under the appropriate pathway  evaluations  described  in the preceding
 sections.   The  potential  for  food chain contamination should also
 be considered if  any food crops  are grown  near contaminated  soils.

      Design and  operating features relevant  to contaminated soil
 intermedia  transfer have  been  previously described.  The EIR
 reviewer should  review these procedures, as  well as  the
 security procedures .and equipment used  to  limit "public access-to
 active portions  of the units,  and spill clean-up procedures
 for  routine spills, accidents, and leaks.  An additional concern
 related to  the  transportation  of waste  (see  next section) is the
 adequacy of current operating  procedures in  preventing the "track
 out"  of contaminated soils  by  transportation vehicles from active
 portions of the  site.
3. Transportation Factors

     Routine transportation releases are associated with leaks or
unloading/loading practices.  The EIR reviewer should examine the
type, capacity, and adeguacy of vehicles and other conveyances
(e.g., pipelines) used, and the procedures taken to minimize
releases.  The traffic pattern information should be examined
to determine if the routes traveled through nearby populated
areas pose potential exposure concerns.  For example, the potential
for exposure is increased if large quantities of waste (especially
acutely toxic, highly volatile, ignitable, or explosive wastes)
are transported through highly populated areas.  Transportation
routes through thinly populated area, or on-site waste disposal,
are less likely to lead to significant human exposure.

     If the permit writer has concerns about the potential exposure
arising from transportation of waste, (s)he should examine the
past compliance records of the facility, noting any accidents and
transportation violations.  The permit writer should also consider
requiring improved emergency spill/clean-up procedures used for
transportation accidents, special contingency plans with nearby
localities,  or other ways of dealing with the problem.

4.  History of Management Practices

     Proper management practices are necessary to ensure the
operation of the unit is adeguate to render releases unlikely
or to detect and correct problems.  Obviously, the most definitive

                               -  34 -
 indicator  of  problems  is  a  past  release,  and  the  EIR  reviewer
 must examine  the desiqn  and operation of  the  unit to  see  if
 chanqes  in permit  conditions  are warranted  to address  these
 nast problems.   Other  less  definitive types of  information  that
 are  indicative  of  the  adequacy of  the operation/design  of the
 unit include  insurance claims and  settlements,  and  the  compliance
 history  of 'the  unit  with  Federal,  State,  and  local  regulations,
 especially inspection  records and  any violation citations.
 The  EIR  reviewer should consider the  history  of complicance  with
 RCRA requlations,  as well as  other records  that the owner/operator
 submitted  or  identified in  the EIR, such  as:

 0 occupational  health  and safety records;

 0 NPDES  compliance records;               -                .

 0 compliance  records for  applicable air requlations;  and

 0 spills reported  under CERCLA.

      For example,  worker  data on injuries, accidents, and illnesses
 related  to operation of the unit may  be used  to help  identify those
 facilities with questionable  manaqement practices,  and  hence, with
 potential  for releases.   The  EIR reviewer should  focus  on the
 nature and frequency of these and  other chronic violations
 to assess  the likelihood  that a  future release  to any pathway
miqht occur.

      If  a  chronic  compliance  problem  exists,  the  EIR  reviewer
should examine relevant permit conditions (e.g.,  worker training
problems,  contingency  plans,  inspection schedules,  proposed
compliance schedules)  to  ensure  that  the  unit is  operated in
an adequate manner.  The  EIR  reviewer should  also discuss compliance
problems and possible  remedies with appropriate RCRA enforcement

5.  Example of Exposure Potential  Determination

     Figure 3 summarizes  an example of the results  of a qualitative
screen of  the potential for exposure  from future  releases (Step 5).
This example examines  the same site that was  reviewed in Figure 2
 (for prior releases,  Step 2)  and the  same background  information
applies.  Figure 3 illustrates the types of decisions that can .be
made concerning: the potential impact of  future releases to each
pathway? when release  potential  should be considered; and, possible
follow up  action to address potential problems.  Note that the
existence of prior releases is given  important  consideration in
assessing  release potential, and the  outcome  of investigations
of past releases will  greatly affect  possible follow up actions.

                                   - 35 -
        Figure  3.  Example of Summary Sheet Following Qualitative Screen for
                  Future Releases
                                 Background Summary

 See Figure 2 for general background.  Concerning Management Practices, no chronic
 RCRA compliance problems documented; occupational and CERCLA records do not
 indicate problems.  (Odor violation being examined through prior release analysis;
 see air pathway)
 Potential for Exposure
  Release Potential and
Possible Follow-Up Action
Ground Water
Very low.  Aquifer not used for
drinking water;  ground-water
flow very slow (K < 10~5on/sec,
minimal hydraulic head).
 Not required due to low
 exposure potential.
Very low.  Use of nearest surface
water severely limited due to
existing pollution.  No overland
route; run-off goes to POIW before
 Not required due to low
 exposure potrential.
Transportat ion
Possible due to population areas
adjacent to site and the handling
of some volatile wastes.  Level
of concern raised due to odor

Very low.  While underground con-
duits exist, unlikely route for
surface impoundment.

Possible concern due to record of
facility sweeping nearby resi-
dential street.  Direct exposure
of nearby population could result
from track-out of contaminated
No indication of potential problems
beyond track-out concern raised under
soil pathway.
 Based on past releases,
 future release likely.
 Await results of monitoring
 to decide if new permit
 conditions warranted.

 Not required due to low
 exposure potential.
 Potential for track-out
 exists; if subsequent
 RFA or RFI shows soil
 contamination, consider
 permit conditions (e.g.,
 cleaning trucks prior to
 off-site transport).

 Not required due to low
 exposure potential.

                                                             IRECTIVE r;o.

                               - 36 -                  3 . 00-2

 E.   Considering Permit Conditions to Mitigate Potential
     Exposure  (Step 6)

      If  the analysis outlined  for Step 5 indicates the potential
 for  significant public exposure due to future releases, then the
 EIR  reviewer  should examine the design and operating features of
 the  unit as described in the preceding section to decide if
 additional permit conditions are necessary to decrease the potential
 for  releases.  If this examination suggests that the existing
 design and operating features  are adequate to address any potential
 exposure pathways, then the EIR reviewer may end the EIR review

      Alternatively, if the EIR reviewer feels that additional
 permit conditions are required, (s)he must consider what conditions
 are warranted and how these can be required in the permit.  In
 some  cases, strengthening permit conditions already required under
 existing 264  standards may be  adequate.  In the case of concerns
 over  releases to ground water, for example, the owner/operator.
might be required to undertake more frequent monitoring of existing
wells, or sink new wells, in order to insure that a release will be
detected in a timely manner.   Because the existing regulations
were  designed to address primarily ground-water contamination, the
permit writer may find a variety of ways to decrease exposure
potential for this pathway under the existing regulations.

      Concerns about releases to other media may also be addressed,
 to a  limited  degree, under existing 264 standards.  For example,
release potential to the air might be reduced through a strengthening
of conditions related to waste analysis (to ensure that accidental
releases through explosion, fire,  or productions of toxic gases do
not occur through mismanagement).   Exposure potential via air
releases may be decreased by insisting on well designed contingency
plans and other agreements with the surrounding communities.  In
 some  cases, however, the permit writer may have to go beyond the
 standards contained in Part 264.   Permit denial (the "ultimate"
permit condition)  is the final option in extreme cases of serious
exposure potential.

     The Hazardous and Solid Waste Amendments of 1984 (HWSA)
provided EPA with a new "omnibus"  authority in Section 3005(c)(3),
and this provision has been codified in the RCRA regulations in
40 CFR Part 270.32(b)(2).  This provision enables the permit
writei to require the owner/operator to comply with permit
conditions "necessary to protect public health and the environment".
The accompanying  legislative history indicates that Congress
 intended EPA  to add permit conditions beyond those specified in
the exisiting regulations (see the codification rule, 50 FR
28722, July 15, 1985).

     Therefore, EPA may require permit conditions that go beyond
existing 264  standards if an examination of the exposure potential
of the facility warrants such action.   In these cases, the EIR

                             -  37 -

reviewer/permit writer may wish to perform a more extensive
analysis of future release/exposure potential to justify additional
permit conditions.  However, for sites at which past releases and
exposures have been documented for a particular pathway (e.g.,
via the process beqinninq with Step 2 in the EIR review process),
further documentation of future release potential via this route
may not be needed.

     Examples of additional permit conditions that could be added
under 3005(c) include:

0   new desiqn/operatinq features to rapidly detect releases (e.g.,
   require routine air monitorinq for indicator parameters at or
   near the site);

0   additional release control design features (e.g., covers or
   wind screens to decrease air emissions "from surface impoundments;
   increased dike stability requirements and/or secondary containment
   systems to prevent release to surface water); and,

0   limitations on the operations of the unit/site (e.g., limit
   the handling of wastes with volatile constituents to mitigate
   air releases;  limit the acceptance and treatment of ignitable
   or  reactive wastes to prevent possible explosions or intermittent
   air releases;  limit the acceptance of certain acutely toxic

                                                             OSWER POLICY DIRECTIVE NO.


                    Attachment I  Section 3019 Statute

 Section  3019.   Exposure  Information  and  Health  Assessments

     •Sec. 3019. (a) EXPOSURE INFORM ATION.-Begtnning on tht date nine  months
after the enactment of  the Hazardous and Solid Waste Amendments of 1984, each
application for t  final determination regarding t  permit wider lection 3005(c) for a
landfill or surface  impoundment  shall be  accompanied  by  Information  reasonably
asocrtainable by the owner or operator on the potential for  the public to be exposed to
hazardous wastes or hazardous constituents through releases related to the unit.  At a
minimum, such information must address:
           "(1)  reasonably  forseeable potential releases from both normal operations
     and accidents at the unit, including releases associated with transportation to or
     from the units                                       =
           12)  the potential  pathways of human exposure to hazardous wastes or
     constituents resulting from the releases described under paragraph (1); and,
           "(3)  the  potential magnitude  and  nature of the human exposure resulting
     from such releases.
The owner or operator of a landfill or surface impoundment for which an application for
such a final determination under section 300S(c) has been submitted prior to the date of
enactment  of the Hazardous and Solid Waste Amendments of 1984 shall submit the
information required by this subsection to the Administrator  (or the State, in the case of
a State with an authorized program) no later than the date 9 months after such date of
           "(1)  The  Administrator (or the State, in  the  case of  a  State  with an
     authorized program)  shall make the information required by subsection (a), together
     with other relevant information, available to the Agency for Toxic Substances and
     Disease Registry  established by section 104(0 of the Comprehensive Environmental
     Response, Compensation and Liability Act of 1980.
           "(2) Whenever in the judgment of the Administrator, or the State (in the case
     of a State with an authorized program), a landfill or a surface Impoundment poses a
     substantial potential risk to human health, due to the existence of releases of
     hazardous  constituents,  tht  magnitude  of  contamination  with  hazardous
     constituents  which  may be  tht result of  a release,  or  the magnitude of the
     population exposed to such release or contamination, the Administrator or the State
     (with tht concurrence of tht Administrator) may request tht  Administrator of the
     Agency  for Toxic Substances and Disease  Registry to conduct a health assessment
     in connection with such facility and take other appropriate action with respect to
     such  risks  at  authorized  by  section  104(b) and  (t)  of   tht  Comprehensive
     Environmental Response, Compensation and Liability Act of  1980.  If funds are
     provided In connection with such request  tht  Administrator of such Agency shall
     conduct such health assessment.
  '  "(e) MEMBERS OF THE PUBLIC.—Any member of tht public may submit evidence
of releases of or exposure to hazardous constituents from such a facility, or as to the
risks or health effects associated with such releases or exposure, to tht Administrator of
tht Agency for Toxic Substances and Disease Registry, tht Administrator, or the State
(in tht cast of a State with an authorized program).
     "(d) PRIORITY.—In determining tht order in which to conduct health assessments
under this subsection, tht  Administrator of tht Agency for Toxic Substances and Disease

                                                              OSWER POLICV DIRECTIVE MO.

                         Attachment I  (Continued)
Registry shall fivt priority to those facilities or sites  at  where there is documented
evidence of  release of hazardous  constituents,  at  which the potential risk  to  human
health appears highest, and for  which in the judgment of the Administrator of such
Agency existing  health assessment data  is  inadequate  to  assess the potential risk  to
human health as provided in subjection (f).
     "(e) PERIODIC REPORTS.—The Administrator of such Agency shall issue periodic
reports which include  the  results of all the  assessments carried out under this section.
Such assessments or other activities shall be reported after appropriate peer review.
     "(f) DEFINITION.—For the  purposes of this section, the term  health assessments'
shall  include preliminary assessments of the potential risk to human health posed  by
individual sites and facilities subject to this section, based on such factors as the nature
and extent of contamination, the existence of potential for pathways of human exposure
(including  ground or  surface water  contamination, air  emissions, and  food  chain
contamination), the size and potential susceptibility of the  community within the b'kely
pathways of  exposure, the comparison of expected human exposure levels to  the short-
term  and long-term health  effects associated  with  identified contaminants ~and any
available recommended exposure or tolerance limits for such  contaminants, and  the
comparison of existing morbidity and mortality data on diseases that may be associated
with the observed levels of exposure. The assessment shall  include an evaluation of the
risks  to the  potentially affected  population from  all  sources  of such contaminants,
cinluding known point or nonpoint sources other than the site or facility in question. A
purpose of such preliminary  assessments  shall be to help determine whether full-scale
health or epidemiological studies and medical evaluations of exposed populations shall be
     "(g) COST RECOVERY.—In  any case in which a health  assessment performed under
this  section  discloses the exposure of  a  population to the  release  of a  hazardous
substance,  the costs of such health assessment may be recovered as a cost of response
under  section 107 of  the  Comprehensive Environmental Response, Compensation, and
Liability Act of 1980  from  persons causing or contributing  to such release of such
hazardous substance or, in the case of multiple releases contributing to such exposure, to
all such release.

                                                                      ATTACWENT  II
                                                                                                   ID Ho.
                                                  EXPOSURE  INFORMATION REPORT  (B1R)  REQUIREMENT CHECKLIST
A.  General Information

Numbers  	Information Requirement
A-l.     Information In Part B Application

  A-la   General description of facility

  A-lb   ChMlcal and physical analyses of wastes
  A-lc   Access control and security
         description of active portion
  A-ld   General inspection schedule and  procedures

  A-le   Preparedness and prevention documentation

  A-lf   Contingency plan

  A-lg   Preventive procedures

  A-lh   Facility location information

  A-li   Closure plan

  A-lj   Post-closure care plan

  A-lk   Documentation of Insurance
  A-ll   Topographic mad .(site plotted on OSGS
         quadrangle maps)

  A-lm   List of wastes placed or to be placed
         in each unit
   Reg. Cite

and (J)

                                                 BXfOSORK IHroUHfcTIOH RETORT (Et») KEQUIRBMEMT CHECKLIST
A.  General Information  (continued)
                      Information Requirement

A-2.     Additional  Information

  A-2a   Existing risk assessment report* and
         information,  including  liability insurance
         analyses, claims,  and settlements

  A-2b   Und use and  Boning map(s) for an area of
         4 miles around the unit

  A-2c   Existing aerial photographs of the facility

  A-2d   Identify and  summarise  any waste analysis
         data not already submitted! provide
         additional  data as discussed in text

  A-2e   Current estimate of annual amount of waste
         received and  description of any pretreatment
         process used

  A-2f   Identification of  any Federal, State, or
         local inspection or compliance records
         related to  environmental and health programs}
         Include descriptions of any major violations
                 Provided  Complete     Not
   Reg.  Cite      (T/H)      U/H)     Applicable
Location in Part B or  EIR/C





270.101 J)




                                                 EXPOSURE INFORMATION HBPOBT (BIR) REQUIREMENT CHECKLIST
a.  Ground-Mater Pathway
                      Information Requirement

B-l.     information in Part  B Application

  B-la   Interim status ground-water monitoring results

  B-lb   Identification of uppermost aquifer.
         Including flow rate  and direction

  B-lc   Topographic maps related  to ground-water
         protection (well location, water table
         elevation contours,  etc.)

  B-ld   Description of existing contamination

  B-le   Detailed plans for ground-water monitoring

  B-lf   Description of detection  monitoring
         program (if applicable)

  B-lg   Description of compliance monitoring
         program and characterisation of
         contaminated ground  water (if applicable)

  B-lh   ACL demonstration (if any)

  B-ll   Corrective action program (if applicable)
   Reg. Cite


                                                            270.1«(c)(3> and
                                                            (i) and (11)

                                                            and  (c)(7)Ul)

                                                                             Provided  Complete     Not
                                                                              «/M)     (»/H)    applicable
Location in Part B or EIR/Comment
  B-lj   Description of liner and leachate collection        270.17(6X11
         systems (if applicable)                             270.21(b)(l)

                                                 EXPOSURE INPORHATION REPORT (BIR) REQUIREMENT CHECH LIST
ft.  Ground-Hater Pathway (continued)
                      Information Requirement

B-2.     Additional Intonation

  B-2a   Btistlng aap  showing  location of all known
         well* within  thte* mllest number and
         location of drinking  water walla

  B-2b   Diacuaaion of ground-water uaea within
         three Mi lea of unit
  B-2c   Regional  nap ahowing areaa of ground-water
         recharge  and diacharge

  B-2d   Nat precipitation ualng net aeaaonal rainfall
         or other, available data

  B-2e   Unless otherwise reported to BPA, available
         well data Indicating a release, and
         information on any affected public or private
         water supplies.  Including populations aerved

  B-2f   Any known food chain contamination due to
         prior releaae from the unit to ground water
                 Provided  Complete     Not
   Reg. Cite      (y/N)     (Y/N)     Applicable
location In Part B or  E1R/C







                                                 Exrosum iMPcmmTioM RETORT (era)
C.  Surface Mater Pathway
                      Information Requirement

C-l.     Information in Part B Application

  C-l«   location inforMtlon related to 100 yr flood
         plain including variance deannatrationa

  C-lb   System for control of run-on fro* each
         peak discharge of 25 yr atom

  C-lc   Syatea) for control of run-off fro* 24 hr,
         2i yr atorm

  C-ld   Procedurea/equlpment to prevent overtopping

  C-le   Structural Integrity of dikea
                                                               •eg.  Cite
                                                            (111)  thru (v)


Provided  Coaplete     Not
           (Y/H)     Applicable
                                                                                                                   location in Part  B or Kin/Comment
C-2.     Additional Inforaation

  C-2a   Dlacuaaion of aurface water uaea within
         three aillea of the unit, including a MP
         •hewing the location of all aurface water
         bodlea and downatreaai drinking water intakea        270.101 j)

  C-2b   velocltlea of atreaaa and rivera paaaing
         through and adjacent to the property                270.10(J)

  C-2c   Dtacrlptioa of any ayatea) uaed to »onltor
         aurface water quality, and a auMMry of the data    270.10())

  C-2d   Deacrlptlon of known releaaea to aurface water;
         the eiteat of contaMinatlont revedlal action,
         if anyi and if known, severity of iaipact            270.10(j)

  C-2e   Any known food1 chain contamination resulting
         fro* prior release fro* the unit to aurface
         water                                              270.10IJ)
                                                                                                                                                    o    -<
                                                                                                                                                    o    s=>
                                                                                                                                                     I     m
                                                                                                                                                    10    §

                                                                          II  - *
                                                 BiroSURB IHPORHATIOM REPORT (EIB) REQUIRgMEMT CHECKLIST
D.  Air Pathway
                      Information Requirement

D-l.     Information in Pact B Application

  D-la   Documentation of procedures to prevent
         accidental ignition or reaction
  D-lb   Mans to control wind dispersal  of
         particular matter at landfills

  D-lc   A wind rose showing prevailing wlndspeed
         and direction
   Reg. Cite
27U.21 and
(g), 271).2Kb)
and (1)

270.2Kb) (5)
Provided  Complete     Not
 (if/N)     (Y/H)    Applicable
Location in Part B or  EIR/C
0-2.     Additional Information

  D-2a   Summary of air monitoring data and a
         description of current monitoring system,  if any     270.10(1)

  D-2b   Population within a four mile radius  of  the unit     270.10(j)

  D-.*c   Describe any known releases to ain the  extent
         of contaminatloni remedial action, if any*
         and severity of impact, if known                    270.10(1)
                                                                                                                                                 - o
                                                                                                                                                '- o

                                                 BXtOSUKB INFORMATION BBPORT (EM)  REQUIREMENT CHECKLIST
B.  Subsurface Gas Pathway
                      Information Requirement
Reg. Cite
Provided  Couplet*     Not
 (Y/N)     (Y/M)    Applicable
Location in Part B or  EIR/Comment
B-l.      Information  in Part B Application

             (Note:   None  in addition to General Information Requirements)
         Additional  Information
  B-2a   Any past diapoaal of Huniclpal-typ* waat«a in the
         unit; approilMte quantities and dates of
         disposal,  if known                                  270.10(1)

  B-2b   Hap location of any underground conduits
         within the site ard known underground
         conduits within 1000 feet of property boundary      270.10(j)

  B-2c   Descriptions of any Monitoring or control
         •echanlsM for subsurface gas release*
         suMMrlze  resulting data                            270.10(J)

  B-2d   Description of any known releases; extent of
         contamination; remedial action taken, if any;
         and the severity of impact, If known                270.10(1)
                                                                                     O    -c|
                                                                                     O    o

                                                                          II  -  8
                                                 BXP03UB8 IMPOKHHTIOH RETORT (BIR) KBUUIRBHBMT CHECK LIST
P.  contaminated Soil  Pathway
Information Requirement
Numbers  _

r-1.     Information in Part  B Application
Reg. Cite
Provided  Complete     Mot
 (t/H)     (y/H)    Applicable
                                                                                                                    Location in Part 8 or  tin/ Comment
             I Not*:   None In addition to General Information Requl recent • I
P-2.     Additional Information '

  P-2a   If soil sampling has been done, a map showing
         areas of soil contamination, and a summary of
         analytical results                                 270.10(J)

  P-2b   Description of the types of major releases
         that resulted in aoil  contamination, and any
         clean-up action                                    27U.10(j)

  P-2c   Any known food-chain contamination reaultlng from
         the use of contaminated soils for raising crops     270.10IJ)

                                                          mronmTioM REPORT (Bin) neoutnBK8HT CHECKLIST
G.  Transportation Information
numbers               Information Bsqutrement	     Keg.  Cite

G-l.     Information in  Part • Application

  G-la   Traffic pattern,  volume, and controls* access       270.14(b) (10)
         road characteristics
                                                                             Provided  Complete     Hot
                                                                              (Y/M)      (t/H)     Applicable
Location in Part  B or BlB/Comment
         Additional Inforaation
  G-2a   Description of the type* and capacities of
         vehicles used to transport waste                    270.10(})

  G-2b   Identification of noraal transport routes
         for hazardous waste into the site and within
         one Mile of the facility entries                    270.101))

  G-2c   Description of procedures for clean-up of
         transportation-related spills or leaks              270.10(j)

  G-2d   Description of any transportation accidents
         releasing hazardous wastes on-site, or in the
         i-Mediate vicinity                                 270.lot))


                                                                         II  •*
                                                 JXroSUM 1HPOHHATIOH REPORT (BIR)  REQUIREMENT CHECKLIST
H.  Management Practices  Intonation
                      Information »jqiiire«ent

B-l.     Information in Part * Application

  H-la   Outline of  progrM* to  train vaploy*** to
         •ately operate and Maintain facility,
         including emergency reapona* actlvitlea
   Reg,  cite
Provided  Complete     Hot
 (t/H)     (VN)     Applicable
Location in Part  B or 11*/Comment
H-2.     Additional  Intoraation

  H-2a   SuMary of  existing  recorda on worker lllneaa
         or injury,  related to the operation of the unttj
         Include auMMrlea of HorkMen'a Compensation
         clalaia, or  hoapltal  recorda


                                                                         II -
                                                 EXPOSURE IMPOHHATIOH RBPOUT (JIR) HeQUIRBIgNT CHBCTL1ST
I.  Potential for Human Exposure.
                      Information  Requirement
Numbers  _______	

1-1.     Croundwater  Pathway

  I-la   Description  of  how the units'  location
         affects the  potential for and  possible
         Magnitude ot huaan exposure  fro* releases
         to groundwater
                 Provided  Complete     Not
   Reg, cite      (*/N)      (Y/N)     Applicable
location in Part B or  BIR/Comment
  I-lb   Description of the design and operating
         features that affect  the  potential
         for releases to groundwater and the
         Magnitude of these releases
1-2.     Surface Mater  Pathway

  I-2a   Description of how the units'  location affects
         the potential  for and  possible magnitude of
         human exposure from releases to surface
         water.                                             270.10(j)

  I-2b   Description of the design and  operating
         features that  affect the potential for
         releases to surface water and  the
         magnitude of these releases.                        270.101j)

                                                          1MPOKHATIOH KeroKT (81R) R-BQUIKCTBHT CHECKLIST

I.  Potential tor Human Exposure (Continued)

                                                                             Provided  Complete     Not
Numbers  _ IntonMitton Requirement _     Reg. Cite      «/N)     (Y/N)    Applicable         location In Part B or B IK/ Cogent

1-3.     Air

  1-39   Description of how the  units* location affect*
         the  potential for  and possible magnitude of
         human exposure fro» release* to the air.            270.10(1)         _     _     _      _ .
  I-Jb   Description of  the design and operating
         features that affect  the potential for
         releases to the air and the
         Magnitude of these releases.                        270.10(]>

  I-Jc   Description of  wastes indicative of air
         releases and Management of these wastes.            270.10(j)

  l-Jc(l) Description of any waste characteristics
          (e.g.,  Incompatibility, reactivity, ignlia-
          bility, volatility)  Indicative of potential
          for releases to the  air.                           270.10(])

  I-3c(2) Description of special handling, treatment,
          or mixing procedures used to prevent violent
          reactions, fires, explosions, or extensive
          evaporation of volatile constituents.              27U.10(j)
1-4.     subsurface Gas Releases

  I-«a   Description of how the'units' location affects
         the potential  for  and possible magnitude of
         human exposure from subsurface gas releases.        270.10(j(
  I-4b   Description of  the design and operating
         features that affect  the potential for                                                                                                   (£>
         subsurface gas  releases and  the                                                                                                          fTI    o
         magnitude of these releases                         270.10(j)         	     	     	      	.	
                                                                                                                                                 O    ^
                                                                                                                                                 O    53

                                                                                                                                                  1    §
                                                                                                                                                 1^7    ^J


                                                          IMPOKHHTIOM REPORT (81») KEQUHEMMT CHBCTLIST

I.  potential for HUMan Exposure (Continued)

                                                                             Provided  Complete     Not
HuMbers  	Information Requirement	     Reg. Cite      (Y/N)     «/M)    Applicable         Location In Part  a or  tin/Comment

         Releases to Soil

         Description of how the unit*'  location affects
         the potential for and possible Magnitude of
         human exposure fro* releases to soil.               270.101])         	     	     	      	•
  I-5b   Description of the design and operating
         features that affect the potential for
         releases to soil and the Magnitude of
         these releases.                                     270.10(J)
1-6.     Transportation-Related Releases

  !-*•   Description of how Methods  and routes of
         transportation of waste on-site and in the
         iNwdiate vicinity of the facility affect
         the potential for hu»an etposure fro*
         transportation-related releases.                    270.101))
1-7.     Morfcer-Hanageaent Practices

  I-7a   Analysis of worker data and discussion of the
         potential for off-site Migration and public
         exposure resulting froM any releases
         related to worker-ManageMent practices.             270.10(1)

  I-7b   Description of training programs in place for
         the Workers to ensure the safe handling of
         wastes and MlniMlie the potential for
         releases fro* noraal operation of the units.        270.101})
                                                                                                                                              c*    g

                                                                                                                                              05    ^
                                                                                                                                               •     §
                                                                                                                                               o    ^

                                                  EWtRTOUW DIRECTIVE NO.

          Attachment III.  Levels of ATSDR Assistance*
1.  Health Consultation;  Immediate or short-term consultation
    by ATSDR to provide health advice and/or health effects
    information regarding a specific site.

2.  Health Assessment;  Initial multi-disciplinary reviews by
    ATSDR of all readily available data to evaluate the nature
    and magnitude of any threat to human health at a site.
    These evaluations will adapt EPA's risk assessment for the
    characterization of potential health threats at a site or sites,
    and may include literature searches, information summarization,
    and evaluation of existing environmental data, pilot samples,
    testing for food chain contamination, and similar activities.

3.  Pilot Study;  A preliminary or short-term medical, laboratory,
    or epidemiologic study on a limited human population to
    decide if additional, large-scale studies are warranted.   The
    study populations can include those living at, or near,  a
    site and those not residing at, or near, a site (control
    or reference population).

4.  Epidemiologic Study;  Long-term study by ATSDR involving  a
    comprehensive protocol designed to add knowledge of the
    health effects of a specific substance or substances at  a
    site or sites.

5.  Health Registry;  A site-specific or adverse health effects-
    specific registry established and maintained to track
    specific diseases and illnesses and long-term health effects
    to persons exposed to toxic substances.

* These levels of assistance are taken from the EPA/ATSDR
  MOU for CERCLA; definitions of these ATSDR activities may
  change in the EPA/ATSDR MOU for RCRA.