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Environmental Protection
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DIRECTIVE NUMBER: 9345.1-16
TITLE: Integrating Removal/and Remedial Site Assessment
Investigations v
APPROVAL DATE: October 21, 1993
EFFECTIVE DATE: October 21, 1993
ORIGINATING OFFICE: OERR/HSED
Q FINAL
D DRAFT
STATUS:
[ 1
A- Pending OMB approval
B- Pending AA-OSWfiR approval
C- For review 4/or comment
D- In development or circulating
REFERENCE (other documents): headquarters
[ ]
[ ]
[ 1
JE DIRECTIVE
O.QVI/PP
DIRECTIVE D
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SERA
united Slates environmental protection Agency
Washington DC 20460
OSWER Directive Initiation Request
1 Directive Number
9345.1-16
2. Originator Information
Name of Contact Person
S. Caldwell
Man Code
Office
OERR/HSED
Telephone Code
3. Title
Integrating Removal and Remedial Site Assessment Investigations
4. Summary of Directive (include bnef statement of purpose)
Provides a model of an integrated assessment process that the Regions can apply
in developing plans to meet their specific needs
5. Keywords
Integrating.
, Remedial
6a. Does This Directive Supersede Previous Oirective(s)
b. Does It Supplement Previous Directive^)'
|X | No | I Yes What directive (number, -e)
No
Yes What directive (number.
7 Draft Level
A-SignedbyAA/DAA
B - Signed by Office Director
C - For Review & Comment
D - In Development
8. Document to be distributed to States by Headquarters? I x IYes
No
This Request Meets OSWER Directives System Format Standards.
9. Sgnature of Lead Offiot
10. Name and Title of App
Henry Lonqest/
! Directives Coordinator
£
^ ^%<^
rovingloMoal
II
Date
Date
/ '
8/25/94
EPA Form 1315-17 (Rev. 5-87) Previous editions are obsolete.
OSWER OSWER OS WE" O
VE DIRECTIVE DIRECTIVE DIRECTIVE
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
' WASHINGTON, D.C. 20460
OCT 2 '. 1993
OFFICE OF
SOLID WASTE AND EMERGENCY
RESPONSE
Oswer Directive # 9345.1-16]
MEMORANDUM
SUBJECT: Integrating Removal and Remedial £ite Assessment
Investigations
FROM: Henry Longest II, Director
Office of Emergency and RematUifel'Response
TO: Director, Waste Management Division
Regions I, IV, V, VI, VII, VIII
Director, Emergency and Remedial Response Division
Region II
Director, Environmental Services Division
.Regions I, VI, VII
Director, Hazardous Waste Management Division
Regions III, IX
Director, Hazardous Waste Division
Region X
PURPOSE
The purpose of this directive is to implement the Superfund
Accelerated Cleanup Model (SACM) objective of integrating
assessment activities across programs. This directive focuses
primarily on the early aspects of the assessment process,
typically prior to a determination that a site will be included
on the National Priorities List (NPL). It is intended to provide
a conceptual model of an integrated assessment process that the
Regions can apply in developing plans to meet their specific
needs. The directive is intended to support full implementation
Of SACM in FY 94.
BACKGROUND
Many aspects of assessments for removal actions and pre-
remedial site assessments are similar or even identical. In
spite of that, the two programs have typically operated
independently, occasionally duplicating effort at a site or
conducting activities with less than optimal efficiency. For
example, one program may collect samples that could be used for
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contain* at teut 50% recycled liber
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the other program's decision-making but might omit some element
critical to the other program's mission (e.g., a background
sample, analysis of physical characteristics of sample, etc.).
Integrated assessments under SACM are designed to ensure
that all appropriate assessment work is done in the most
efficient manner possible. That involves identifying the common
denominators as well as the differences across programs and
designing systems of data collection so that only the data needed
for appropriate decisions are collected at a site. Thus,
integrated assessments are more than simply coordinating sampling
plans or collecting all possible removal and remedial data needs
in a single assessment. Integrated assessments will require that
each Region redesign their site notification/discovery efforts,
screening processes, and all other aspects of the assessment data
collection and decision processes.
OBJECTIVES
The primary objectives of this integrated assessment process are:
Faster assessment and response times
Improved efficiency by eliminating redundant work
Improved communications
Better assessment and response decisions
Specific objectives of the integrated removal and remedial site
assessments are:
Perform the initial visit to the site so that it serves
the needs of both programs
Collect common data elements so that they are usable by
both programs
Collect only the data specifically needed for decisions
at the site e.g., don't collect removal data if the
site is clearly not a removal candidate
Coordinate sample plans across all interested programs
Minimize "down time" between operations
The conceptual model presented in the fact sheet offers an
approach that can meet these objectives. The similarities and
differences in approaches are summarized, providing the Regions
with information that can be used to develop implementation
plans.
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IMPLEMENTATION
. The Regions have been developing various solutions to the
problem of integrating removal and pre-remedial site assessments.
Given the variation in Regional organization structures, somewhat
different approaches are to be expected among Regions. However,
each Region should develop a conceptual approach that takes into
account the general principles of this fact sheet and meets the
needs of removal and pre-remedial assessments as efficiently as
possible.
The degree of integration will also vary from one site to
another. For example, at many sites it is possible to conclude
early in the process that no remedial action will ever be taken,
even if there is a clear need for a removal. Under those
circumstances, the focus of an integrated assessment would be
removal data needs. At other sites/ pre-remedial site assessment
data needs would be foremost. In some cases, both sets of data
needs should be addressed. What is of paramount importance is
that the possible need to integrate assessment activities is
taken into account at every site. Having an integrated
assessment process is not simply a matter of performing some
integrated assessments that meet the definition of the SCAP
measure at selected sites.
While the Regions should be fully operational for integrated
assessment in FY 94, we recognize that the current contractor
support approach (ARCS and TAT) is not optimal. Under the START
contracts, expected to be operational by early FY 95, both
removal and pre-remedial site assessment support will be by the
same contractor, facilitating the process.
If you have comments or questions regarding this aspect of
SACH assessments, please call Steve Caldwell (HSED) at 703-603-
8817 or Art Johnson (ERD), 703-603-8705.
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