United States
                       Environmental Protection
                       Agency
Office of
Solid Waste and
Emergency Response
                                                                      Directive 9345.1-15FS
                                                                      August 1993
                                  Inspection  Prioritization
                        Guidance
   Office of Emergency and Remedial Response
   Hazardous Site Evaluation Division (5204G)
                            EPA/540/F-93/037
                     Quick Reference Fact Sheet
The purpose of this fact sheet is .to provide guidance to Environmental Protection Agency (EPA), State, and
contractor staff responsible for conducting Site Inspection Prioritizations (SIPs).  Of the 36,000 sites currently in
the Comprehensive Environmental Response,  Compensation, and Liability Act Information System (CERCLIS)
inventory, approximately 16,700 have undergone Site Inspections (Sis). Of those, however, over 6,000 sites still
require final site disposition decisions (Figure 1).  This backlog has made it difficult for EPA to evaluate sites
efficiently on a worst sites first basis. Consequently, EPA established the SIP to address this backlog and to make
decisions on these  sites.
                   Figure 1
   SITE INSPECTION PRIORITIZATION BACKLOG
               Regional Breakdown
 1.400

, 1.200

) 1.000

i ftOO

I 800

• 400

' 900

   0
                B
                      v  vi vn
                     REGION
   Data as of 5/7/83
BACKGROUND

The Superfund Amendments and Reauthorization Act
(SARA) of 1986 required that EPA revise the Hazard
Ranking System (HRS), the primary mechanism used
to list sites on the National Priorities List (NPL).  In
December 1990, EPA promulgated and published the
revised HRS in the Federal Register (55 FR 51532),
 superseding the original HRS.  During a period of
 transition to the revised HRS, sites were evaluated
 through the  SI  stage under  the  original HRS;
 however, EPA felt it would be preferable to make
 final site disposition decisions on these sites after
 revising the HRS. Information for these sites needs
 to be updated to evaluate the site using the revised
 HRS.  A final decision may be to list the site on the
 NPL, make a Site Evaluation Accomplished (SEA)
 determination,  or defer the site to another Federal
 authority (e.g. Resource Conservation and Recovery
 Act  (RCRA) or Nuclear  Regulatory Commission
 (NRC)).   An SEA  decision  means that, based on
 currently available information, the site does not meet
 the criteria for inclusion on the NPL and Federally
 funded  remediation.  Sites  designated  SEA are
 subsequently referred to the appropriate State agency
 for any further action.

 The goal  of the SIP  is  to  gather  any  additional
 information necessary, following the completion of
 the SI, to help set priorities  among  these sites for
 NPL listing or to screen them from further Superfund
 attention.   At a minimum,  this would generally
 require gathering data  to update the  site evaluation
 and determining whether the HRS score  is greater
 than 28.5.  Typical  SIP data gathering efforts  may

-------
 include  collecting  additional  site information (e.g.
 historical use) and "target" information (e.g., wells
 within 4 miles, surface water intakes, fisheries and
 sensitive environments within 15 miles downstream).
 SIPs may also entail collecting limited samples if this
 is  required  to  make  a screening decision.   The
 number  of samples for an SIP should range from a
 few up to the normal number typically collected for
 an SI.  An SIP should rarely result in the need for
 further  investigation  through the  Expanded  Site
 Inspection (ESI) stage.  ESIs should be reserved for
 those  sites clearly  headed for  the NPL  and where
 significant  fieldwork  (e.g.,  well  installation  or
 extensive air  monitoring) or other non-routine data
 collection activities are necessary.

 The SIP is a temporary, intermediate step in the Site
 Assessment program to update old Sis and make
 screening decisions on a discrete universe of sites
 using minimal resources.  Therefore funding for SIP
 activities is expected to be available for the next two
 to four years.  The SIP backlog should not continue
 to grow. Current Preliminary Assessments (PAs) and
 Sis  are  being  completed  according to  guidance
 developed for the revised HRS (see Guidance for
 Performing Preliminary Assessments Under CERCLA,
 OSWER Directive 9345.1-01A, September 1991 and
 Guidance for Performing Site  Inspections  Under
 CERCLA, OSWER Directive 9345.1-05,  September
 1992). The updated guidance documents recommend
 the use of intermediate scoring tools (PA Scoresheets,
 PA-Score,  and SI Worksheets) to make  screening
 decisions using site information normally available at
 the PA and SI stages.  These scoring tools typically
 require less site information and effort to make a
 screening decision than using PREscore.  At the SIP
 stage the majority of sites should be scored using SI
 Worksheets at a minimum; however,  the decision of
 which scoring tool (PA Scoresheets, PA-Score, SI
 Worksheets, or PREscore) to  use for SIPs will be
 made on a site by site basis.

REVISED HRS REQUIREMENTS

EPA   revised  the  HRS   to  comply   with  the
requirements set forth by  SARA.  To better  assess
the relative degree of risk to human health and the
environment,  EPA  modified  the  approach  for
evaluating the ground water, surface water, and air
migration pathways that  were addressed  in  the
original HRS  and  incorporated a direct  exposure
 pathway (soil exposure) into the composite score used
 to evaluate sites.  In general, the HRS score reflects
 the risk associated with each pathway by estimating:
 (1)  the  likelihood  of  a release  of  hazardous
 substances; (2) the quantity and toxicity or other
 harmful characteristics of on-site wastes; and (3) the
 risk to both human and environmental targets.

 The revised HRS requires more data than the original
 HRS to evaluate a site.  The revised HRS evaluates
 ground water discharge to surface water, human food
 chain exposure, soil exposure,  and the potential for
 air release.  In addition, the evaluation  of risk to
 ecosystems or environmental targets is broader in the
 revised  HRS  than  the original  HRS,  and  the
 calculation of waste quantity is more comprehensive.
 However, the most crucial information that will need
 updating for an SIP is the target data.   Table 1
 presents a comparison of target  needs between  the
 original and the revised HRS  models and identifies
 what information might be missing in old Sis.

 SIP UNIVERSE

 In general, an SIP should be assigned for non-Federal
 facility  sites which had  Sis completed prior to  the
 implementation  of the revised HRS  and have  not
 received a final NPL decision.  SIPs are appropriate
 where more information is  necessary  to  determine
 whether a  site should be screened out (designated
 SEA or deferred to another Federal  authority), or
 investigated further  for  probable inclusion on  the
 NPL.  The extent of additional information required
 to make this final decision and the probability of NPL
 listing are both important in determining whether an
 SIP or an ESI is appropriate. SIP candidates are sites
 with an SI completion date entered into CERCLIS
 prior to the implementation of the revised HRS (i.e.,
 August  1, 1992) and may include: (1)  sites without
 an event qualifier  (i.e., high priority, low priority,
 SEA, or deferred), or (2) sites with an event qualifier
 of high or low priority.

 Sites may not have event qualifiers due to CERCLIS
 coding  errors.    The  Region  should review file
 information for  these sites to  determine whether a
decision is  possible.  Sufficient information may be
available to screen out the site from further CERCLA
investigation (SEA  or   defer  to  another Federal
authority).   The appropriate event  qualifier should
then be entered  into  CERCLIS.    If  additional

-------
                     Table  1:   Original vs. Revised HRS Target Data Requirements
       PATHWAY
         ORIGINAL HRS
            TARGETS
                                                                                   REVISED HRS
                                                                                     TARGETS
 Ground Water Migration
 Pathway
 •  Ground water use
 •  Distance to the nearest
   well/population served within 3
   miles
   Distance from a source to the nearest drinking water well
   Population served by drinking water wells within four
   miles
   Apportioned population for blended systems
   Resources
   Wellhead protection areas
 Surface Water Migration
 Pathway

 Overland/Flood
 Migration Component
•  Surface water use
•  Distance to the nearest intake/
   population served
•  Distance to sensitive environment
 Drinking Water Threat:
 •  Distance to nearest drinking water intake
 •  Average flow (cubic feet per second)
 •  Population served by drinking water drawn by intakes
   along the surface water migration pathway within 15
   downstream miles
 •  Apportioned population for blended systems
 •  Resources

 Human Food Chain Threat:
 •  Location of fisheries
 •  Annual harvest (in pounds) of human food chain organisms

 Environmental Threat:
 •  Location of sensitive environments
 •  Wetlands frontage length (in miles)
Ground Water to Surface
Water Migration
Component
               NA
                                                         Same as above

                                    New component to the surface water pathway.  If both the
                                    overland/flood and the ground water to surface water
                                    components are scored, the greater of the two component
                                    scores is selected.
Soil Exposure Pathway
               NA

The original HRS included a direct
contact pathway, but that pathway
was not calculated in the overall
HRS migration score.
Resident Population Threat:
•  Number of individuals who live, work, attend school or
   day care within property boundaries and within 200 feet of
   observed contamination
•  Location of terrestrial sensitive environments within the
   area of observed contamination
•  Resources

Nearby Population Threat:
•  Number of individuals who live or attend school within a
   one-mile travel distance  from any source with observed
   contamination
•  Attractiveness/accessibility of sources
Air Migration Pathway
   Land use
   Population within four miles
   Distance to sensitive
   environments
   Distance from an emission source to the nearest individual
   Population within a four-mile radius of sources
   Resources within one-half mile of sources
   Distance from sources to  sensitive environments within
   four miles of sources
   Total wetland acreage within four miles of sources

-------
 information  is required to make  a final decision,
 either a high priority or low priority recommendation
 should  be entered as the  event qualifier (Regional
 guidance should be consulted to distinguish between
 high and low priority recommendations).  These sites
 would then fall into the second category of sites.

 Sites with high or low priority  event qualifiers may
 still  require additional  data,  either  desktop  or
 analytical, to support a revised HRS score. Since the
 average  level of effort per SIP is 190  hours, sites
 which require significantly more effort to support  a
 final decision (> 550 hours) may not be appropriate
 for an SIP assignment. If a greater level of effort is
 required to fill SI data gaps  and to support a final
 decision,  particularly if the site is likely to be listed
 on the NPL, then an ESI may be more appropriate.
 In general, an ESI  should  be assigned if extensive
 fieldwork  or unusual data collection activities  are
 required prior to preparing an NPL package. Factors
 that should be examined to help determine whether an
 SIP or  an ESI should be assigned are provided in
 Table 2.   In addition to sites with and  without SI
 event qualifiers, there may be other sites evaluated
 under the original HRS which need further evaluation
 via the SIP.  This includes sites where an incorrect
 site decision was  made or  new file information is
 made available which might  significantly alter the
HRS  evaluation of the  site.    The decision as to
whether an SIP is  appropriate for these sites will be
made on a case by case basis.  Note, however, that
these sites are not included as part of the SIP backlog
 (Figure 1) because site decisions have already  been
entered into CERCLIS.
 SETTING PRIORITIES

 Figure 1 shows that some Regions have a very large
 SIP backlog and may need to incorporate additional
 measures to set priorities among their SIP candidates.
 One  method  may be  to  identify  sites  located  in
 vulnerable geographic  areas.   Features  that may
 characterize an area as vulnerable include: population
 density, geologic and hydrogeologic features, surface
 water intakes, fisheries,  municipal  drinking water
 wells, wetlands, and other considerations. Much  of
 this information is available in existing databases that
 can be  incorporated  into  a Regional geographic
 information system (GIS). By plotting these features,
 sites  located  in  vulnerable  areas  could then  be
 identified.

 The issue of setting priorities is not  limited to SIPs.
 If further investigation is warranted at the  conclusion
 of an  SIP, these sites, which are now ESI candidates,
 must  also be prioritized. It is critical to set priorities
 for ESI candidates, not only to comply with EPA's
 policy of assessing the  worst sites first, but also  to
 allow for the efficient use of limited resources.  ESIs
 consume  an  average  of   1,000  hours;  therefore
 Regions must  set priorities for ESI candidates while
 keeping in mind their budgetary constraints. Regions
 may  use  more detailed prioritization schemes  to
 further identify ESI candidates.

Regions are encouraged to investigate their Regional
GIS  capabilities  as  well  as  other  prioritization
methods, not  only to address the SIP  backlog, but
also to help  direct  other environmental  protection
efforts on a worst sites first basis.
                       Table 2:  Factors to Determine SIP or ESI Assignment
SIP
Limited data are necessary to determine whether or
not the site will attain a score greater than the cutoff
score for NPL eligibility
NPL eligibility is uncertain
SI completed but no HRS score calculated
SI completed but preliminary HRS scoring assumes
primary targets without sample results
ESI
Substantial data collection is necessary to prepare NPL quality
HRS package (>550 hours)
Probable NPL site
SI score (completed with SI Worksheets) is greater than the cutoff
score for NPL eligibility
SI sampling has verified contamination at primary targets; site
score is greater than the cutoff score for NPL eligibility

-------
 SIPS and SACM

 The Superfund Accelerated Cleanup Model (SACM)
 requires better integration of all Superfund program
 components  to make  cleanups  more timely  and
 efficient.   During  an  SIP,  activities  should  be
 coordinated to  ensure  that data  collected  support
 assessment, enforcement,  and response  activities.
 The  Regional  Decision  Team  (RDT),  which is
 responsible for making site decisions to ensure early
 risk  reduction,  will  establish  the  strategy  for
 addressing sites. SIP data collection efforts should be
 consistent with these strategy decisions.

 The basic principles of SACM assessment are built
 upon the need to eliminate redundancy and expedite
 the  Superfund  process.   SIPs will help  identify
 priority sites so that EPA resources are expended on
 sites that require prompt risk reduction. For further
 information, refer to Assessing Sites Under SACM -
Interim  Guidance OSWER  Directive  9203.1-051,
December  1992.

 SIP ACTIVITIES

Activities to be conducted for an SIP will depend on
the additional information necessary to update the old
SI  in  accordance with  current  guidance and  the
revised HRS.  In all cases, however, site information
must be reexamined to update current site conditions,
satisfy revised HRS requirements,  and identify the
potential need for removal  actions  (see the  next
section  for  further   information  on  identifying
potential removal actions during SIPs).

Because activities necessary for SIPs will vary due to
the quality and comprehensiveness of site information
that is available, three levels have been identified to
meet the goal of an SIP as illustrated in Table 3.

It is estimated that each SIP will require at  least
updated HRS scoring; two-thirds will require desktop
data collection and updated scoring; and  one-third
will require desktop data collection, updated scoring,
and limited sampling. It is estimated that an SIP will
average 190 hours per site.  EPA Regional staff will
help determine the level of effort necessary for each
SIP assigned.  The choice of which HRS scoring tool
to use (PA Scoresheets, PA-Score, SI Worksheets, or
PREscore) will depend on the amount of information
available for  the site.  At a minimum, revised  HRS
scores must support each SIP decision.  Sites with
revised HRS  scores  below the cutoff (28.5) are
screened out, and will receive an SEA decision in
CERCLIS. Sites with revised HRS scores above the
cutoff  will be  recommended for either an ESI  (if
extensive information/data collection is still required)
or for a full HRS package.

Level A: The first step in  conducting  an  SIP  is to
generate a  revised HRS   score.   This  typically
requires  collecting  new  target information for the
revised HRS target distance limits (see  Table 1).
This first activity is necessary for all SIPs to generate
a site score according to the revised HRS, identify
data gaps, and determine  whether additional SIP
activities (desktop data collection and/or sampling)
are necessary  to  make a final  site  disposition
decision. If desktop data collection and sampling are
not necessary, the site's revised HRS score should be
documented with these new target data incorporated,
and a final site disposition decision should be entered
into CERCLIS.

Level B: Most SIPs will likely require the collection
of additional site specific desktop data beyond
                              Table 3:  SIP Levels versus SIP Activities
SIP LEVEL
LEVEL A
LEVEL B
LEVEL C
SIP ACTIVITIES
• Updated (revised HRS) scoring
• Updated (revised HRS) scoring
• Desktop data collection
• Updated (revised HRS) scoring
• Desktop data collection
• Limited Sampling
APPROXIMATE
TOTAL HOURS
40-60
80- 100
350 - 550

-------
updating a site's target information.  Level B SIPs
typically  include  researching  and  updating  site
information because site conditions may have changed
significantly since the completion of the old SI. All
appropriate data sources (EPA, State, municipal, etc.)
should be  researched to ensure that  information is
updated  for  the SIP.   The SI  Data  Summary
(Appendix B of the Guidance for Performing Site
Inspections Under CERCLA) and the Site Assessment
Information Directory (SAID) may be useful  data
collection  tools for  this  task.    After  this  new
information is collected, the site's revised HRS score
should be documented incorporating this new data,
and a final site disposition decision should be entered
into CERCLIS.

Level C:  It is estimated that approximately one-third
of SIPs will require sampling activities in addition to
the activities described for Level A or B SIPs. EPA
Regional   staff will  determine   the  appropriate
sampling  strategies  necessary for Level C  SIPs.
After sampling activities are conducted,  the site's
revised   HRS   score  should   be   documented
incorporating the new analytical data, and a final site
disposition decision should be entered into CERCLIS.

Site visits  may be necessary for Level  A, B, or C
SIPs to verify and update site conditions, evaluate the
need for a potential removal  action,  identify target
information  for  HRS  scoring,   and/or  conduct
sampling  activities.    As a  cost savings measure,
Regions   should  consider   scheduling  SIPs   in
geographic  clusters  so  that  site  visits  can  be
combined. SIP field activities may also be combined
with other Site Assessment and integrated assessment
field activities.

SIP  products  will  depend  on  what activities  are
conducted  and will be determined by  EPA Regional
staff.  For example, the final product for an SIP
requiring  only  Level A  activities  may  consist of a
brief memo updating site and target information along
with completed revised HRS scoresheets. Products
for an SIP requiring Level  B or  C  activities may
consist of a full report,  similar to the SI reporting
format, along with completed HRS  scoresheets.

SIPs will  be tracked in CERCLIS  as a subevent of
the SI.   Refer to  the sidebar  for the appropriate
CERCLIS entry protocols.
      CERCLIS Data Entry for SIPs

     •    Enter the SIP as a subevent (SP) to the
         last SI.

     •    The completion date is the date the report
         is accepted by the Region and a
         disposition (event qualifier) is made on
         the report.

     •    Replace the last SI event qualifier with
         the new SIP event qualifier (Higher,
         Lower, Deferred,  or SEA).

     Only sites where the last SI completion  date is
     prior to August  1, 1992 are eligible for  SIPs.
     Sites with SI qualifier "N" or "D" are not
     eligible for  SIPs unless new information
     relevant to the decision becomes available.
IDENTIFYING POTENTIAL REMOVAL
ACTIONS DURING SIPs

SIP field activities can be very useful in identifying
sites  where  a potential  removal  action  may  be
necessary.    Removals  are  relatively  short-term
actions, compared to the long-term remedial solutions
that  the NPL addresses.   Removal  actions are
designed  to  respond  to situations  that  require
immediate action to eliminate a present threat or  to
avoid a more serious future problem (for example,
containing leaking drums of hazardous substances  to
prevent ground water  contamination).   Removal
actions can be of an  emergency, time-critical, or non-
time-critical  nature and can  include, but  are not
limited  to,  any of the following (see Superfund
Removal Procedures,  OSWER Directive 9360.3-01,
February 1988):
     •   Fencing the  site
     •   Providing  24 hour security to restrict public
         access
     •   Stabilizing waste sources  such as leaking
         drums   or  overflowing  surface
         impoundments
     •   Physical removal of hazardous substances
     •   Capping areas of obvious contamination
     •   Assessing  the  need to temporarily  relocate
         populations
     •   Providing    alternative   drinking   water
         supplies

-------
Table 4 outlines the factors that EPA considers in
determining the appropriateness of a removal action
pursuant to section 300.415(b) of the National Oil
and  Hazardous Substances  Pollution Contingency
Plan, commonly known as the NCP  (40 CFR Part
300).

Under the revised  HRS,  waste  removals may be
considered for HRS scoring purposes under certain
circumstances. For more information concerning the
requirements for considering removal actions, refer
to The Revised Hazard Ranking System: Evaluating
Sites After  Waste  Removals,  OSWER  Directive
9345.1-03FS, October 1991.

SIP SAMPLING

Because SIPs  that include  sampling will  require
significantly  more  hours,  some  analysis should be
conducted  to determine if sampling  is critical for
making  a final  decision.    For  example,  if  a
preliminary site score is 28.5 or greater, all targets
for which  actual contamination  (level I and  II) is
suspected should be identified. By examining various
scoring scenarios, the site score  should be tested to
determine whether  the site score will  fall below the
28.5 cutoff for NPL  eligibility  if the targets  with
suspected  actual   contamination  are  scored  as
potentially contaminated. If the site score falls below
28.5 with this modification, sampling is necessary to
verify  the suspected  contamination  of  the target
receptors.  If the site score remains 28.5 or greater,
sampling may not be necessary.  On the rare occasion
where  an  SIP  results  in the  need  for further
investigation via an  ESI, new data obtained from
samples collected for the SIP may help set priorities
for sites needing further work.

For additional  information  concerning sampling
guidance for the revised HRS requirements, refer to
Guidance for  Performing  Site  Inspections  Under
CERCLA,  OSWER  Directive  9345.1-05  and  the
Hazard Ranking System Guidance Manual, OSWER
Directive 9345.1-07.

In summary, the goal  of the SIP is  to  gather  any
additional  information  necessary,  following  the
completion  of  the SI,  to  make  decisions on  this
discrete universe of sites. Activities conducted for an
SIP should  be consistent  with  current  guidance,
including SACM, and  should result in  sites  being
either removed from further Superfund attention or
recommended for NPL package preparation.

EPA  developed  the  SIP  as  a  cost  effective,
intermediate step in the Site Assessment process to
screen out less  serious problems and expedite action
at sites  that require additional Superfund response.
Site priorities must continue to be set on a worst first
basis  to ensure that Superfund  cleanups are timely
and efficient.
                                   Table 4:  Removal Action Criteria
       1    Actual or potential exposure to nearby human populations, animals, or the food chain from hazardous substances
           or pollutants or contaminants;
       2.   Actual or potential contamination of drinking water supplies or sensitive ecosystems;
       3.   Hazardous substances or pollutants or contaminants in drums, barrels, tanks, or other bulk storage containers,
           that may pose a threat of release;
       4   High levels of hazardous substances or pollutants or contaminants in soils largely at or near the surface, that
           may migrate;                                         	
       5    Weather conditions that may cause hazardous substances or pollutants or contaminants to migrate or be released;
       6.   Threat of fire or explosion;
       7.   The availability of other appropriate Federal or State response mechanisms to respond to the release; and
       8.   Other situations or factors that may pose threats to public health or welfare or the environment.

-------
REFERENCES
U S  Environmental Protection Agency, 1988.  Superfund Removal Procedures, OSWER Directive 9360.3-01.
U.S. Environmental Protection Agency, 1990. Hazard Ranking System, Final Rule, 55 FR 51532, December 14,
1990.
U.S. Environmental Protection Agency, 1990. National Oil and Hazardous Substances Pollution Contingency Plan.
40 CFR Part 300.  55 FR 8666, March 8, 1990.
U.S. Environmental Protection Agency,  1991.   Guidance for  Performing  Preliminary  Assessments Under
CERCLA, OSWER Directive 9345.0-01A.
U.S. Environmental Protection Agency, 1991.  Revised Hazard Ranking System:  Evaluating Sites After Waste
Removals, OSWER Directive 9345.1-03FS.                                                   ,.  I0ft,
U S  Environmental Protection Agency, 1991. Site Assessment Information Directory (SAID), October 31, 1991.
u!s. Environmental  Protection Agency, 1992.  Assessing Sites Under SACM-Interim Guidance, OSWER
Directive 9203.1-051.                                                          .           n™~i A
U.S. Environmental  Protection Agency, 1992.  Guidance for Performing Site Inspections Under  CERCLA,
OSWER Directive 9345 1-05
U.S. Environmental Protection Agency, 1992.  Hazard Ranking  System Guidance Manual, OSWER Directive
9345.1-07.	_	

                               Additional copies can be obtained from:
                D..UU-                                              P.PA Employees
                Public                                               •*" muyivjww     /rTV-rv
National Technical Information Service (NTIS)        or           Superfund Documents Center (SDC)
US  Department of Commerce                                  U.S. Environmental Protection Agency
5285 Port Royal Road                                          «>1 M Street, SW (OS-245)
Sorinfffield VA  22161                                         Washington, DC 20460
CHSwSaO                                                (202^260^760 or (202) 260-2596 (FAX)

Order f:  PB93-963340

-------