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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