United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
EPA-540-F-98-037
OSWER 9375.2-09FS
PB98-963308
October 1999
SEPA Improving Site Assessment:
Abbreviated Preliminary
Assessments
Office of Emergency and Remedial Response
Site Assessment Team
Quick Reference Guidance Series
ABSTRACT
This guidance document establishes the minimum requirements for conducting an Abbreviated Preliminary Assessment (APA)
instead of a full Preliminary Assessment (PA). The PA process determines and documents whether Superfund action is needed
at a Comprehensive Environmental Response, Compensation, and Liability Information System (CERCLIS) site. The region
may produce an APA report at any phase of the PA (prior to completing a full PA) when enough information is available to
make a decision on further CERCLA action. This guidance document supersedes section 4.4 of the Guidance for Performing
Preliminary Assessments under CERCLA, Publication 9345.0-01A, September 1991.
BACKGROUND
This modified PA approach combines results of pilot
projects and past experience using the existing PA process.
EPA regions have found that they can often determine a
site's location in the Superfund site screening process and
whether it should be removed from the process altogether,
with less information than is required for a conventional
PA. In these early decision instances, you may produce an
APA report in place of a full PA report.
This approach uses the same information as the
conventional PA approach, but relies on your professional
judgment and past site assessment experience to make
decisions about a site at earlier stages of the PA process.
Responsibility and funding for APAs are the same as for
conventional PAs.
WHAT IS THE PURPOSE OF AN APA?
The PA is the first step you take to determine whether a
site warrants Superfund response after a site has been
entered into CERCLIS. The National Oil and Hazardous
Substances Pollution Contingency Plan (NCP) (40 CFR
300.420) requires the lead agency (EPA in most instances)
to perform PAs on all sites in CERCLIS to:
• Eliminate those sites that do not pose a threat to
public health or the environment from further
consideration;
• Determine if there is a need for removal action;
• Set priorities for Sis; and
• Gather data to facilitate later evaluation of the
release through the Hazard Ranking System (HRS).
If you can meet these PA objectives without performing
a full PA, you may perform an APA. In the case of a
citizen petition (see CERCLA 105(d)), the NCP requires
the lead agency to either complete a PA or provide an
explanation to the petitioner of why the assessment is not
appropriate. A brief APA report with a completed
Abbreviated Preliminary Assessment Checklist (see
Attachment A), or equivalent documentation, meets all the
CERCLA and NCP requirements for a PA.
There are three typical situations in which you could
perform an APA instead of a full PA to increase
efficiency and shorten the PA process:
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(1) A site has been unnecessarily listed in CERCLJS
either because it is not eligible or because it could be
deferred to another response program.
(2) Available information allows EPA to make an early
decision to undertake a combined PA/SI, an SI, or
another Superfund investigation.
(3) A No Further Remedial Action Planned (NFRAP)
decision can be made without completing a full PA.
In each situation, an APA can save resources and reduce
costs by eliminating unnecessary efforts. Federal Agencies
and States conducting CERCLA site assessments should
consult with the EPA Regional Office prior to initiating an
APA to ensure that sufficient data will be collected to make
an appropriate decision about the site.
WHAT ARE THE THREE PHASES OF THE
PRELIMINARY ASSESSMENT PROCESS?
You may produce an APA report during any phase of the
PA process prior to completing a full PA. Note that an
APA must meet the basic PA criteria specified in the NCP.
The first phase, the CERCLA eligibility evaluation,
involves collecting and reviewing readily available file
information and reinvestigating the site's CERCLA
eligibility. Collecting this information may begin before
the site is entered into CERCLJS, as part of pre-CERCLJS
screening assessment (see document titled Improving Site
Assessment: Pre-CERCLJS Screening Assessments1).
The second phase is the initial site evaluation which entails
gathering information through file searches. This may
involve visiting the site to determine the appropriate action.
If you decide to take no further action, you should
complete an APA report. An APA report may also be
completed if you decide to move straight to an SI without
completing a full PA.
You complete the third phase of this PA process if you
have insufficient information to make an early decision
about future Superfund response. In this case, you should
complete a full PA to get the information needed to make
a decision about future Superfund action at the site.
Perform full PAs in accordance with the Guidance for
Performing Preliminary Assessments Under CERCLA2.
WHAT ARE THE POSSIBLE DECISIONS?
You could make one of the following decisions, based on
results of an APA:
NFRAP under Superfund;
• Defer the site to another Federal program with
investigation, enforcement or remediation
authority (e.g., RCRA, NRC);
• Delay the decision until State/Tribal program ends
active involvement in response activities;
• Assign high priority for further assessment;
• Assign low priority for further assessment;
• Refer to the removal program; or
• Incorporate this site into an existing CERCLIS site.
See the Superfund Program Implementation Manual
(SPIM) for more information on making decisions.
HOWISACERCIJ^ ELIGIBILITY EVALUATION
PERFORMED?
In the first phase of the PA process, you will determine
whether the site is eligible for evaluation under CERCLA.
Criteria for determining this are identified below (from
guidance document Medlmproving Site Assessment: Pre-
CERCLJS Screening Assessments1). If a pre-CERCLIS
screening has been completed using these criteria, this
phase of the PA process is unnecessary.
Gather enough data to address the screening criteria
below, to help make a CERCLIS eligibility decision.
These criteria are primarily based on OSWER 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
record into CERCLIS. Check CERCLIS and
archive data for previous entries of a site using site
name, location, and site identification number data.
• 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;
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(2) From products that are pan 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
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).
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 Sites3 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 CERCLJS
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 an incomplete checklist, or
a checklist with what appears to be unreliable data,
you should identify the data deficiencies and
forward these data needs to the site investigator for
further data collection. For more information, see
the Pre-CERCLIS Screening Assessment
Checklist/Decision Form in the guidance document
titled Improving Site Assessment: Pre-CERCLIS
Screening Assessments1. When it is not feasible to
obtain all the information to complete the checklist,
use professional judgement when deciding to place
a site in CERCLJS.
• 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).
If the answer is "yes" to any of these items and there is
no other Federal Superfund interest, you may assign the
site a NFRAP designation or defer it to another program.
This decision should be documented in a brief APA
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report (reporting requirements are described below). This
action terminated the PA process. If the answer is "no"
to any of the bulleted items, you may proceed to the next
phase of the PA process, the initial site evaluation.
HOW IS THE INITIAL SITE EVALUATION
PERFORMED?
The initial site evaluation is the phase in which site
investigators collect and review information on the site
and its surroundings. EPA investigators may use their
professional judgment with site-specific information to
make recommendations about further CERCLA action.
Exhibit 1 identifies different types of site information and
provides some possible recommendations for further site
assessment activities based on that information. You
should use Exhibit 1, or equivalent information, in
determining the need for further action at the site, based
on the answers to the questions in Attachment A.
Exhibit 1 and Part 2 of Attachment A present a series of
site conditions that indicate whether further Superfund
action may be necessary. These site conditions are based
on HRS factors and include characteristics that
commonly cause sites to receive high or low HRS scores.
WHAT ARE THE REPORTING
REQUIREMENTS FOR THE PA PROCESS?
When a full PA is unnecessary, you should develop an
APA report to document the rationale for the decision.
The NCP (40 CFR 300.420) specifies PA requirements,
and an APA report must meet these requirements. The
NCP states that the lead agency may complete the
preliminary assessment form, or its equivalent, and
prepare a PA report to:
• Describe the release;
• Describe the probable nature of the release; and
• Recommend whether further action is warranted,
which lead agency should conduct further action,
and whether an SI and/or a removal action should
be undertaken.
If the PA is the result of a citizen petition, the NCP
further requires the lead Federal agency to notify the
petitioner of the PA outcome and explain its
determination.
The APA report should present and fully support all
information that led to abbreviating the PA process.
Include Attachment A or equivalent information as part
of the APA report. The APA report must also meet all
the NCP requirements for a PA report discussed
previously, including those requirements for response to
acitizen petition. The criteria discussed aboveshouldbe
used to explain the decision.
Adding more information to the APA Checklist is
acceptable (preferably on separate pages), but do not
omit or delete minimum requirements.
If an APA is not appropriate for the site, complete the
full PA discussed in the Guidance for Performing
Preliminary Assessments Under CERCLA1.
How Will the Information be Managed?
CERCLlS/WasteLAN is the official national
information management system for the Superfund
program. Site assessment data must be entered into
CERCLIS/WasteLAN and regularly updated to
effectively and efficiently manage Superfund's site
assessment process. Please refer to the latest version of
EPA's SPIM and CERCLIS/WasteLAN Coding
Guidance Manual for instructions on entering APA
information into CERCLIS/WasteLAN.
REFERENCES
1. U.S. Environmental Protection Agency, October
1999. Quick Reference Guidance Series -
Improving Site Assessment: Pre-CERCUS
Screening Assessments. Publication 9375.2-11FS.
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, 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 APAs, please contact Michael
Hurd at EPA Headquarters, phone (703) 603-8836 or e-
mail at hurd.michael@epa.gov.
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ATTACHMENT A
ABBREVIATED PRELIMINARY ASSESSMENT
CHECKLIST
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ABBREVIATED PRELIMINARY ASSESSMENT CHECKLIST
This checklist can be used to help the site investigator determine if an Abbreviated Preliminary Assessment (APA) is warranted. This
checklist should document the rationale for the decision on 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:
Describe the release (or potential release) and its probable nature:.
Part 1 - Superfund Eligibility Evaluation
If all answers are "no" go on to Part 2, otherwise proceed to Part 3.
1 . Is the site currently in CERCLIS or an "alias" of another site?
2. Is the site being addressed by some other remedial program (Federal, State, or Tribal)?
3. Are the hazardous substances potentially released at the site 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 regulated by the NRC, UMTRCA, or OSHA)?
4. Are the hazardous substances potentially released at the site excluded by policy considerations (i.e.,
deferred to RCRA corrective action)?
5. Is there sufficient documentation to demonstrate that no potential for a release that could cause adverse
environmental or human health impacts exists (e.g., comprehensive remedial investigation equivalent data
showing no release above ARARs, completed removal action, documentation showing that no hazardous
substance releases have occurred, or an EPA approved risk assessment completed)?
YES
a
a
D
D
D
NO
a
a
a
a
a
Please explain all "yes" answers).
A-l
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Part 2 - Initial Site Evaluation
For Part 2, if information is not available to make a "yes" or "no" response, further investigation may be needed. In these cases,
determine whether an APA is appropriate. Exhibit 1 parallels the questions in Part 2. Use Exhibit 1 to make decisions in Part 3.
If the answer is "no" to any of questions 1, 2, or 3, proceed directly to Part 3.
1 . Does the site have a release or a potential to release?
2. Does the site have uncontained sources containing CERCLA eligible substances?
3. Does the site have documented on-site, adjacent, or nearby targets?
YES
a
a
a
NO
a
a
a
If the answers to questions 1, 2, and 3 above were all "yes" then answer the questions below before
proceeding to Part 3.
4. Does documentation indicate that a target (e.g., drinking water wells, drinking surface water intakes,
etc.) has been exposed to a hazardous substance released from the site?
5. Is there an apparent release at the site with no documentation of exposed targets, but there are targets
on site or immediately adjacent to the site?
6. Is there an apparent release and no documented on-site targets or targets immediately adjacent to the
site, but there are nearby targets (e.g., targets within 1 mile)?
7. Is there no indication of a hazardous substance release, and there are uncontained sources containing
CERCLA hazardous substances, but there is a potential to release with targets present on site or in
proximity to the site?
YES
n
n
n
n
NO
n
n
n
n
Notes:
A-2
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EXHIBIT 1
SITE ASSESSMENT DECISION GUIDELINES FOR A SITE
Exhibit 1 identifies different types of site information and provides some possible recommendations for further site assessment activities
based on that information. You will use Exhibit 1 in determining the need for further action at the site, based on the answers to the
questions in Part 2, Please use your professional judgement when evaluating a site. Your judgement may be different from the general
recommendations for a site given below.
Suspected/Documented Site Conditions
1 . There are no releases or potential to release.
2. No uncontained sources with CERCLA-eligible substances are
present on site.
3. There are no on-site, adjacent, or nearby targets.
4. There is documentation indicating
that a target (e.g., drinking water
wells, drinking surface water intakes,
etc.) has been exposed to a hazardous
substance released from the site.
5. There is an apparent release at the
site with no documentation of
exposed targets, but there arc targets
on site or immediately adjacent to the
site.
Option 1 : APA O SI
Option 2; PA/SI
Option 1: APA 0 SI
Option 2: PA/SI
6. There is an apparent release and no documented on-site targets
and no documented targets immediately adjacent to the site, but
there are nearby targets. Nearby targets are those targets that are
located within 1 mile of the site and have a relatively high
likelihood of exposure to a hazardous substance migration from
the site.
7. There is no indication of a hazardous substance release, and
there are uncontained sources containing CERCLA hazardous
substances, but there is a potential to release with targets present
on site or in proximity to the site.
APA
Yes
Yes
Yes
Yes
No
Yes
No
No
No
Full PA
No
No
No
No
No
No
No
Yes
Yes
PA/SI
No
No
No
No
Yes
No
Yes
No
No
SI
No
No
No
Yes
NA
Yes
NA
No
No
Part 3 - EPA Site Assessment Decision
When completing Part 3, use Part 2 and Exhibit 1 to select the appropriate decision. For example, if the answer to question 1 in Part 2
was "no," then an APA may be performed and the "NFRAP" box below should be checked- Additionally, if the answer to question 4 in
Part 2 is **yes)" 'hen Y°u nave tw° options (as indicated in Exhibit 1): Option 1 — conduct an APA and check the "Lower Priority SI" or
"Higher Priority SI" box below; or Option 2 — proceed with a combined PA/SI assessment.
Check the box that applies based on the conclusions of the APA:
a NFRAP
D Higher Priority SI
D Lower Priority SI
D Defer to RCRA Subtitle C
D Defer to NRG
Regional EPA Reviewer:
D Refer to Removal Program - further site assessment needed
O Refer to Removal Program - NFRAP
D Site is being addressed as part of another CERCLIS site
D Other;
Print Name/Signature
Date
A-3
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PLEASE EXPLAIN THE RATIONALE FOR YOUR DECISION:
NOTES:
A-4
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