United States
                  Environmental Protection
                  Agency
Office of
Solid Waste and
Emergency Response
EPA-540-F-98-039
OSWER 9375.2-11FS
PB98-963310
October 1999
&EPA        Improving Site  Assessment:   Pre-
                  CERCLIS  Screening Assessments
  Office of Emergency and Remedial Response
  Site Assessment Team
                       U.S. EPA Headquarters Library
                              Mail code 3201
                       1200 Pennsylvania Avenue NW
                          Washington DC 20460

                  Quick Reference Guidance Series
 ABSTRACT

 Pre-CERCLJS screening is a review of information on potential Superfund sites to determine whether the site should be entered
 into EPA's Comprehensive Environmental Response, Compensation and Liability Information System (CERCLJS). Pre-
 CERCLJS screening is an initial low-cost look at potential sites to ensure  that uncontaminated sites or sites ineligible under
 CERCLA are not unnecessarily entered into CERCLIS for further Superfund-fmanced assessment activities. This guidance
 document establishes minimum requirements for conducting pre-CERCLIS screening assessments and supplements existing
 pre-CERCLIS screening guidance.
 BACKGROUND

 All sites brought to the Agency's attention should be
 screened before we enter them into CERCLIS (OERR
 Directive #  9200.4-05, Pre-CERCLIS  Screening
 Guidance,  September 30, 1996)'.    Pre-CERCLIS
 screening is the process of reviewing data on a potential
 site to determine whether it should be entered into
 CERCLIS for further evaluation.  EPA is required to
 further assess risks to human health and the environment
 posed by sites entered into CERCLIS and to determine
 whether Federal response action (e.g., removal action,
 remedial action, oversight) is warranted.  Pre-CERCLIS
 screening minimizes the number of sites unnecessarily
 entered into CERCLIS  by providing a  cost efficient
 mechanism for screening sites.

 The pre-CERCLIS screening process begins when you are
 informed of a new site by a phone call or referral from
 State, Tribal or other Federal agency staff. The designated
 site investigator (regional, State, or Tribal  staff or
 contractor) will  complete  the attached  Pre-CERCLIS
 Screening  Assessment   Checklist/Decision  Form
 (Attachment A), or equivalent documentation, to provide
 site information on deciding whether entry of the site into
 CERCLIS is warranted.  If equivalent documentation is
     used, it must address the  information  requested in
     Attachment A.   Only enter sites that require further
     Superfund assessment/response  into  CERCLIS.
     Information about  sites deemed  inappropriate for
     CERCLIS  entry should be maintained for possible future
     reference and retrieval to avoid duplication of effort.

     WHY USE PRE-CERCLIS SCREENING?

     Pre-CERCLIS screening  prevents unnecessary entry of
     sites into  CERCLIS (e.g., uncontaminated sites, sites
     ineligible under CERCLA, or sites not requiring Federal
     Superfund  response actions). Federal Agencies and States
     conducting CERCLA site assessments should consult with
     the EPA Regional Office prior to initiating Pre-CERCLIS
     screening to ensure that sufficient data will be collected to
     make an appropriate decision about the site.

     HOW WILL  PRE-CERCLIS SCREENING BE
     IMPLEMENTED?

     The standard procedures for implementing pre-CERCLIS
     screening activities are presented below.

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Who Will Fund Pre-CERCLIS Activities?
EPA Headquarters provides funding to EPA Regions for
Superfund site assessment activities through an Advice of
Allowance (AOA) as described in the Superfund Program
Implementation Manual.  These funds may be used to
conduct pre-CERCLIS screening work; however, Regions
need to  balance  the amount of funds used for pre-
CERCLIS screenings with funding needs for other site
assessment activities.

You may implement pre-CERCLIS screening activities
through three primary mechanisms:
(1)  Funding States and Tribes through site or multi-site
     assessment cooperative agreements;
(2)  Funding Federal contractors (e.g., through START
     contracts); and
(3)  Using EPA regional staff.

EPA regions should specify  pre-CERCLIS screening
activities  in  the  statements  of work  associated  with
site/multi-site assessment cooperative agreements and with
Federal contract work assignments as appropriate.

What Are Regional Staff Responsibilities?
Regional   site assessment  staff are  responsible for
reviewing screening reports  for completeness and for
ensuring that appropriate sites are entered into CERCLJS.
A  completed  Pre-CERCLIS  Screening  Assessment
Checklist/Decision Form (see Attachment A) or equivalent
documentation as referenced above can serve as a final
report for a site. The decision to enter or not enter a site
into CERCLIS should be based on current information. If
new information becomes available on a site that was not
entered, you may reconsider the decision.

Site investigators should collect enough data to complete
the   Pre-CERCLIS  Screening   Assessment
Checklist/Decision Form (see Attachment A). From the
time of initial notification of a potential site, the site
investigator should review the information to evaluate the
need for additional assessment and entry into CERCLIS.
See specific information requirements identified in the
checklist.  If  more site  information  is available,  the site
investigator should examine the information at this  time.
The information collection/screening process is normally
limited to one or two  days.   If the site is placed in
CERCLIS, EPA will use the gathered information in the
next step  of the  site evaluation  (e.g.,  Preliminary
Assessment (PA)2, Abbreviated Preliminary Assessment
(APA)3, or Combined PA/SI4).

What Are The Screening Criteria?
To make a CERCLIS entry decision, site investigators
need to gather enough data to address the screening criteria
below.  These criteria are primarily based on  OERR
Directive #9200.4-05.

A site should not be entered into CERCLIS if:

•    The site is  currently in  CERCLIS. or has been
     removed from CERCLIS and no new data warrant
     CERCLIS entry.  Determine whether the site  has
     previously  been  evaluated  under the  Federal
     Superfund Program to avoid entering a duplicate site
     recordintoCERCLIS. Check CERCLIS and archive
     data for previous  entries of a site using site name,
     location, and site identification number data.

        Note: Sites already in CERCLIS with no work
        started may warrant CERCLIS screening as part
        of an APA. (See the guidance document titled,
        Improving Site  Assessment:  Abbreviated
        Preliminary Assessments3 for more information
        on conducting APAs.)

•    The site and some contaminants are subject to certain
     limitations based on definitions in CERCLA. This
     includes cases where the release is:
     (1) Of  a naturally  occurring  substance  in  its
        unaltered  form,   or   altered  solely  through
        naturally occurring processes or phenomena,
        from a location where it is naturally found;
     (2) From products that are part of the structure of,
        and  result in  exposure  within,  residential
        buildings or business or community structures; or
     (3) Into public or private drinking water supplies due
        to deterioration of the  system through ordinary
        use.

•    A State or Tribal remediation program is involved in
     response at  a site that is  in the process of a final
     clean-up (e.g., a  State Superfund program, State
     voluntary clean-up  program, and  State or local
     Brownfields programs).

     During the screening process, a file search of other
     Agency  programs eliminates sites where  other
     programs are actively involved. Based on the search
     of the geographical location of the site and the  site
     name, conduct the search using current databases or
     telephone calls to staff of other potentially involved
     programs. You, in consultation with State and Tribal
     program  representatives,  are  responsible   for
     determining whether another program is actively
     involved with the site.

     When another program with sufficient investigation,
     enforcement, and remediation resources is actively

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involved with a  site,  postpone a decision  on
CERCLJS  entry  until  all actions  have  been
completed.  EPA is responsible for determining if
the actions  are sufficient and will then determine
whether  any further Superfund involvement  is
warranted.

The hazardous  substance  release at the site  is
regulated  under  a  statutory  exclusion  (e.g.,
petroleum, natural gas, natural gas liquids, synthetic
gas usable for fuel, normal application of fertilizer,
release located in a workplace, naturally occurring,
or covered by the Nuclear Regulatory Commission
(NRC), and  Uranium  Mill Tailings Radiation
Control Act (UMTRCA), see CERCLA  Section
101(22).

If entry into CERCLIS is not warranted due  to
statutory exclusion, the site data should be sent to
the appropriate Federal and StatefTribal program for
possible future follow-up.  You should confirm
notification of sites referred to other programs.

The hazardous  substance release at the site  is
deferred  by policy  considerations (e.g.,  RCRA
Corrective Action).  Refer to the Regional QC
Guidance for NPL Candidate Sites5  for  more
examples.

The site investigator should, at a minimum, search
other current EPA data sets using site identification
data (name and location) to determine whether the
site is already being addressed by other authorities.

The NPL/RCRA deferral policy states that sites
should not be placed on the NPL if they can be
addressed under RCRA Subtitle C corrective action
authorities. However, according to the NPL/RCRA
policies published June 10,  1986 (51 FR 21057),
June 24,1988 (53 FR 23978), and October 4,1989
(54 FR 41000), facilities that are subject to RCRA
Subtitle C may be listed on the NPL when corrective
action is unlikely to succeed or occur promptly, as in
the following situations: (1) inability to finance, (2)
unwillingness/loss of authorization to operate, (3)
unwillingness/case-by-case  determination,  (4)
converters,  non- or late  filers, (5)  pre-HSWA
(Hazardous  and  Solid  Waste  Amendments)
permittees, and (6) when not all of the release from
the facility is covered by RCRA corrective action.

Site data are insufficient to determine CERCLIS
entry (i.e., based on potentially unreliable sources or
with no information to support the presence  of
    hazardous  substances   or  CERCLA-eligible
    pollutants and contaminants).

    If you are presented with incomplete pre-CERCLJS
    screening information or with what appears to be
    unreliable data for a site, you should identify the data
    deficiencies and forward these data needs to the site
    investigator for further data collection. Refer to the
    attached  pre-CERCLIS  screening  checklist  for
    minimum required site information. When it is not
    feasible to obtain all the information to complete the
    checklist, use professional judgement when deciding
    to place a site in CERCLIS.

•   There  is sufficient documentation  that clearly
    demonstrates that there is no potential for a release
    that could cause adverse environmental or human
    health  impacts  (e.g.,  comprehensive  remedial
    investigation equivalent data showing no release
    above  applicable or  relevant  and appropriate
    requirements (ARARs), completed removal action
    of all sources and releases, documentation showing
    that no hazardous substance releases have occurred,
    or a completed  EPA approved  risk assessment
    showing  no risk).

You should communicate CERCLIS site entry decisions
to States and Tribes on a regular basis.

Does  Pre-CERCLIS Screening Apply To Citizen-
Petitioned Sites?
Citizen-petitioned sites are eligible for pre-CERCLIS
screening assessments and must meet the same criteria.
According to  Section 105(d) of CERCLA, EPA must
perform a PA  or provide an explanation for why the PA
was not appropriate within 12 months of receiving the
petition.   The  Pre-CERCLIS Screening Assessment
Checklist/Decision  Form  (see Attachment  A)  or
equivalent documentation may be used to support the
decision to enter the site into CERCLIS and perform a
PA or to explain to the petitioner why a PA is  not
appropriate.

How Will Information be Managed?
See the Superfund Program Implementation Manual for
procedures  on managing pre-CERCLIS  screening
information in the Superfund data system.

REFERENCES

1.    U.S. Environmental Protection Agency, September
     1996.  Pre-CERCLIS Screening Guidance. Office
     of   Solid Waste   and  Emergency  Response.
     Directive #9200.4-05.

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2.    U.S. Environmental Protection Agency, September
     1991.   Guidance for Performing  Preliminary
     Assessments Under CERCLA.  Office of Solid
     Waste and Emergency Response.  Publication
     9345.0-01 A.

3.    U.S. Environmental Protection Agency, October
     1999.    Quick Reference  Guidance  Series  -
     Improving  Site  Assessment:   Abbreviated
     Preliminary Assessments.  Publication OSWER
     9375.2-09FS.

4.    U.S. Environmental Protection Agency, October
     1999.    Quick Reference  Guidance  Series  -
     Improving  Site Assessment:  Combined  PA/SI
     Assessments.  Publication OSWER 9375.2-10FS.

5.    U.S. Environmental Protection Agency, December
     1991. Regional Quality Control Guidance for NPL
     Candidate  Sites.   Office  of  Solid Waste  and
     Emergency Response.  Publication 9345.1 -08.

FOR MORE INFORMATION

For  more information  on  pre-CERCLJS  screening
activities, please contact Randy  Hippen  at  EPA
Headquarters, phone  (703)  603-8829 or  e-mail at
hippen. randy @ epa.gov.

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         ATTACHMENT A
PRE-CERCLIS SCREENING ASSESSMENT
    CHECKLIST/DECISION FORM

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     PRE-CERCLIS SCREENING ASSESSMENT CHECKLIST/DECISION FORM

This checklist can assist the site investigator during the Pre-CERCLIS screening. It will be used to determine whether further steps in
the site investigation process are required under CERCLA. Use additional sheets, if necessary.

Checklist Preparer:         	   	
                         (Name/Title)
                                                       (Date)
                         (Address)
                                                       (Phone)
                         (E-Mail Address)
Site Name:


Previous Names (if any):


Site Location:




Latitude:       	
(Street)
(City)
(ST)
(Zip)
                           Longitude:
Complete the following checklist If "yes" is marked, please explain below.
1.
2.
3.
4.
5.
6.
7.
Does the site already appear in CERCLIS?
Is the release from products that are part of the structure of, and result in exposure within, residential buildings or
businesses or community structures?
Does the site consist of a release of a naturally occurring substance in its unaltered form, or altered solely through
naturally occurring processes or phenomena, from a location where it is naturally found?
Is the release into a public or private drinking water supply due to deterioration of the system through ordinary use?
Is some other program actively involved with the site (i.e., another Federal, State, or Tribal program)?
Are the hazardous substances potentially released at the site regulated under a statutory exclusion (i.e., petroleum,
natural gas, natural gas liquids, synthetic gas usable for fuel, normal application of fertilizer, release located in a
workplace, naturally occurring, or regulated by the NRC, UMTRCA, or OSHA)?
Are the hazardous substances potentially released at the site excluded by policy considerations (e.g., deferral to
RCRA Corrective Action)?
8. Is there sufficient documentation that clearly demonstrates that there is no potential for a release that could cause
adverse environmental or human health impacts (e.g., comprehensive remedial investigation equivalent data
showing no release above ARARs, completed removal action, documentation showing that no hazardous substance
releases have occurred, EPA approved risk assessment completed)?
YES
D
D
D
D
D
D
D
D
NO
D
D
D
D
D
D
D
D
Please explain all "yes" answer(s), attach additional sheets if necessary:
                                                A-l

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Site Determination:            D Enter the site into CERCLIS. Further assessment is recommended (explain below).




                             D The site is not recommended for placement into CERCLIS (explain below).
DECISION/DISCUSSION/RATIONALE:
Regional EPA Reviewer:
                          Print Name/Signature                                       Date




State Agencj/Tribe:         	        	
                          Print Name/Signature                                        Date
                                                    A-2

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