NEIC
        EPA-330/1-87-001
        MULTI-MEDIA PRIORITY RANKING OF
        SELECTED FEDERAL FACILITIES

        REGION IX
        February 1987
       National Enforcement Investigations Center, Denver
US. Environmental Protection Agenc
                                      Office of Enforcement

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 UNITED  STATES ENVIRONMENTAL PROTECTION AGENCY
 OFFICE  OF  ENFORCEMENT AND COMPLIANCE MONITORING
EPA-330/1-87-002

MULTI-MEDIA PRIORITY RANKING OF
SELECTED FEDERAL FACILITIES
REGION IX


February 1987
Jonathan A. Dion
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
Denver, Colorado

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                                 CONTENTS


INTRODUCTION 	      i

METHODS  	      2

  HAZARDOUS WASTE MANAGEMENT (RCRA)  	      2
  SITE CONTAMINATION. (CERCLA)	      3
  WASTEWATER DISCHARGE (CWA) 	      5
  POLYCHLORINATED BIPHENYL STORAGE AND USE (TSCA)  	      6
  AIR EMISSIONS (CAA)  	      7

RESULTS  	      3


TABLES

1    Facility Rating Criteria  	      4
2    Facility Ratings (by ranking) 	      9
3    Facility Ratings (by location)  	     15

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                               INTRODUCTION

     A multi-media priority ranking system was developed to evaluate selected
Region IX Federal facilities according to their relative potential for having
environmental problems.*  The system was developed to use readily available
information  in a rapid and objective manner  to  identify "high priority"
facilities for further detailed evaluation by EPA.   The  ranking  system was
not designed to compare a facility rating with any fixed number to indicate
whether a  facility  is  environmentally "good"  or "bad".   Rather,  the rating
indicates a facility's potential,  relative to other  installations, for having
major environmental problems (i.e., a high rating indicates that a facility
has a relatively high potential for environmental  problems), and that further
evaluation, if not already completed, may be warranted.

     Rating criteria were  developed  and used to rate facilities according
to the type  and  intensity of facility  activities which  could  actually or
potentially result in environmental contamination.  These activities include
hazardous waste** generation and management,   site contamination, wastewater
discharges, storage and use of polychlorinated biphenyls and air emissions.
For purposes of  this  ranking system and in keeping with EPA Region IX and
Headquarters priorities,  potential  environmental  problems  from  hazardous
waste management  activity  were rated higher  than potential problems  from
other activities.   To  ensure  timely but meaningful comparisons  between
installations,  the  information used  to  rank  the facilities  was confined to
that which  was  easily  accessible  and available for all  or most of the
installations.    Thus,  much of the facility  information  was derived from
various EPA computer databases.  This information was supplemented as neces-
sary with Region IX file data.  More specific  information, such as detailed
site inspection  reports,  was used when such  information was available.***
This report describes the selection of the facilities and the  rating criteria
and information sources used to rank the selected facilities.
  *  Environmental problems,  as used  here,  are directly related to  the
     release of contaminants to the environment.
 **  As defined in 40 CFR 261
***  Specific  facility information would  also be  used as part of the
     detailed followup evaluation of a facility, if warranted.

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                                  METHODS

     The list of facilities to be prioritized was obtained from the Region U
Policy and Management Division.  It was developed from the EPA computerized
Facilities Index System  (FINDS),  which contains approximately 500 Federal
installations:, and  through  information requested from the Air, Water and
Waste Management Divisions  on the significant Federal facilities  covered
within their  media  programs.   Approximately  100  facilities were identified
by this process.

     These identified facilities were ranked based on the type and relative
level of activity in the following five categories:

          Hazardous waste management
          Site contamination  (known and potential)
          Wastewater discharge
          Polychlorinated biphenyls (PCBs) storage and use
          Air emissions

    •These five categories generally reflect pertinent activities regulated
under one or  more  of the five  environmental  acts:   Resource  Conservation
and  Recovery  Act (RCRA),  Comprehensive Environmental  Response Compensation
and  Liability Act (CERCLA), Clean Water Act (CWA), Toxic Substances Control
Act  (TSCA) and the Clean Air  Act (CAA), respectively.  The five rating cate-
gories and an explanation of the  information  used  to rank facilities in
each category follows.

HAZARDOUS WASTE MANAGEMENT (RCRA)

     This category  ranks facilities according  to the potential for environ-
mental contamination  through  their hazardous  waste management practices.
For  rating purposes,  the category was divided into four activity subcate-
gories:  (1)  annual quantity  of hazardous waste generated, (2) waste storage
design capacity, (3) waste treatment design capacity and (4) waste disposal
design  capacity.   These subcategories were  used because of the  type of

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information readily available and the wide range of possible activities and
level of activities related to hazardous waste management.

     The major  source of  information was  the  EPA Hazardous Waste Data Man-
agement System (HVIDMS),  a computer database containing information submitted
to EPA by  hazardous waste generation/handling*  facilities as part of their
Part A RCRA permit application.   The data include (1) the type of hazardous
waste management  activity,  (2)  the design capacity of waste processes and
(3) the  type  and  quanitity of waste generated  and  subsequently handled.
Additional  information was  obtained from the EPA Region IX RCRA files to
supplement the computer data base.

     The minimum  rating  for any facility generating hazardous waste is 3.
This accounts for activities  involving the actual  generation of waste by
the facility.  Generating facilities  with regulated storage,  treatment or
disposal  operations were  rated  according  to the relative activity level in
these areas [Table 1].   An additional  rating point was assigned to all  these
facilities to account for potential problems involved in the actual waste
generating process(es).   The subcategory ratings and this additional rating
point were added  to obtain  the  overall  "Hazardous Waste Management" rating
[column 3 in Tables 2 and 3].   This rating indicates the relative potential
for contaminating the environment and causing environmental  problems because
of improper hazardous waste management practices.

SITE CONTAMINATION (CERCLA)

     The site contamination category ranks facilities according to  actual,
suspected or potential  site contamination from either past waste handling
or present storage  of  bulk quantities  of hazardous liquid material (fuel
oil, gasoline, etc.) [Table 1].   The category is divided into three activity
subcategories:   (1) seriousness of site contamination problems, (2) contami-
nation of soil and water and (3) management of bulk quantities of hazardous
liquid organic material.
     Handling includes  treatment,  storage and disposal of hazardous waste.

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         Table 1
FACILITY RATING CRITERIA




Hazardous Waste Management1 Site

Quantity Storage Treatment Disposal Capacity
Generated Capacity Capacity Landfill Land Application
Rating (m tons/yr) (gal.) (gal. /day) (acres-ft) (acres) Seriousness

0
1
2

3
4

5

0000 0 No4
<12 <10.000 <1.000
12-50 10.000- 1.000- - - Low6
100.000 50.000
50-500 > 100. 000 >50.000 <5 <10 Average"
500- - - ?5 >10 High6
50.000
>50.000 ... - NpL<<
Contamination
Bulk
Soil /Water Storage
Contami- of Haz
nation Material

•No4 No4
Known
Potential
or ,'s.uspecleiJ
-
Known

-
Wastewaler
Discharges
Flow2 SIP
Rate Hazard
(mgd) PuUMilial

No4 -5
>5
< 5

5-1 5
15-25

>2 5
1 The minimum rating for any facility generating hazardous waste, regardless of any storage, treatment or disposal activities is J
storage, treatment and/or disposal activities are assigned subcategory ratings as indicated in the table An

*
j

4
&
G
7
8
a
1 U
ities if they are also generators (sen text).
Subcategory rating is based on industrial or combined (industrial and sanitary) flow rates


SIC Hazard Potential la number from 1 (lowest) to 9 (highest)/ is an indication oi potentially liaiuiful health
trial Classification (SIC) code (see text)
Ho - Ho known or suspected activity in this activity cateyuiy or subcategory
Known activity in this category and cuirentjy in compliance



additional point is


effects related to a





HCB
Storage/
Use

No4
Known0
Suspected
or known- U7
Known- K'J
-

-
fucil ities
added to all






Air Emissior.i.

No4
Class 6
Class A"

Haiaidous1"
-

-
with KCKA
these tacil-


specific Standdid InJub-






Assessment assigned by Regional personnel A/PC means the facility has been proposed lot listing on the National Pi lot itias List
High probability of activity or known activity in this category but current compliance status tilth TSCA is unknown
Class Al and A2 sources included
Known activity in this category and known noncoupliance with TSCA regulations
Hazardous air pollutant (40 CFR 61) emission sources with or without other sources













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     Information was obtained from the Comprehensive Environmental Response,
Compensation and  Liability  Information  System  (CERCLIS)  and  the Compliance
Data System  (CDS)  databases,  Regional files and  through discussions with
Region IX staff.   CERCLIS  tracks various EPA  and  State  activities  at  all
known or suspected sites which were contaminated as a result of past improper
waste management practices.  CDS identifies facilities that  store bulk quan-
tities of organic  materials such as gasoline and  fuel oil.   Regional files
contain Installation Restoration Program (IRP) reports for military facili-
ties and EPA inspection reports for other facilities.   The  latter reports
contain site descriptions and preliminary assessment results.

     Rating points were assigned to each facility for activity in the three
subcategorfes  discussed above  [Table 1].   Seriousness   was  assessed  by
Regional personnel based  on their knowledge of the facility.  The facili-
ties were rated  low,  average, high or  NPL  (proposed for listing on the
National Priorities List)  and received 2, 3,  4 or 5  points  respectively.
The soil/water contamination  rating  was based on data in the IRPs and EPA
reports.  If adequate  data were available to  indicate site  contamination,
the facility rated a 4, otherwise  it  rated a 2.   Bulk storage of  hazardous
material was based on data  in CDS and knowledge of the facility.   The facil-
ities identified in CDS as  having bulk storage of organic materials or listed
as fuel supply  centers were given one  point.  The sum of the subcategory
ratings is  the  overall rating for "Site  Contamination"  [Tables 2 and  3].

WASTEWATER DISCHARGE (CWA)

     This category rates  facilities  according to  the actual or potential
for discharge of contaminants through wastewater outfalls.   Two subcategories
were used to rate facility activity  in  this category:   (1)  average daily
flow rate and  (2) the Standard  Industrial Classification (SIC)*  code  for
the facility processes.
     The SIC  code is a number which  describes  an industry by the  type  of
     activity in which it is engaged.  Federal  facilities often have indus-
     trial processes which have SIC numbers.

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     The flow rate and the SIC codes for wastewater discharges were obtained
from the Permit Compliance System (PCS) and Regional files.  In cases where
a discharge permit had been issued but the flow rate could not be determined
a rating of 2 was assigned.

     The wastewater hazard potential, a number from 1 (lowest) to 9 (highest)
which relates potentially harmful health effects to environmental contamina-
tion from  a  specific  industry (as identified by the SIC code), was deter-
mined using the installation SIC code and "A Manual for Evaluating Contami-
nation Potential  of Surface  Impoundments",  June 1978,  EPA 570/9-78-003".
Appropriate  SIC  codes were not  readily available  for most installations
rated.   In these cases, Regional file information regarding general facility
operations and waste generation was used to determine an appropriate Hazard
Potential  for that  installation.   Hazard  Potential was used  to  rank the
wastewater discharge in lieu of specific information on priority pollutants
[Table 1].*  The  flow rates and  Hazard  Potential were used with  Table 1  to
rate the  facility in  each subcategory.  Subcategory  ratings  were then
totaled to obtain the wastewater discharge rating presented for a particular
facility [column 5 in Tables 2 and 3].

     Many  of the  facilities prioritized do not  have direct wastewater dis-
charges (i.e., do  not treat their own wastewater); rather, the wastewater
is discharged to a regional treatment system.  Because wastewater treatment
and discharge are not under the Federal facilities control, these installa-
tions were given a zero rating.

POLYCHLORINATEO BIPHENYL STORAGE AND USE (TSCA)

     This  category ranks  facilities  according to information regarding PCB
use and known instances of noncompliance with TSCA regulations.  Information
to  identify  facilities storing/using  these  compounds was obtained  from
Regional personnel and computerized Regional  files.  The PCB rating criteria
is shown  in  Table 1.   The Department of Defense  facilities and  Veterans
     Priority pollutants, as defined in 40 CFR 401.15

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Administration  (VA)  Hospitals  that had no information available regarding
PCB  use  or their  compliance  status (with  TSCA  regulations) were  rated 2,  a
point  lower  than  facilities  with  known TSCA  noncompliance [Table 1].  This
was  done  because  it is generally  known that most military  installations
handle RGBs  and most VA Hospitals  have equipment containing  PCBs.   Past
inspection results  suggest  that a majority of these facilities are out of
compliance with applicable TSCA  regulations.  Category  ratings  for each
facility are presented in Tables 2 and 3.

AIR EMISSIONS (CAA)

     This  category  ranks  facilities according  to  emission rates  and  types.
Emission rate information was obtained from the Compliance Data System (COS),
an EPA computer database containing  information on permitted point air emis-
sion sources.

     Facilities were rated quantitatively using the criteria in Table 1.   A
rating based on the facility classification, which is  the CDS  category for
emission  rates  of criteria  pollutants,* was  developed.   Sources  classified
in CDS as  Al or A2  (actually  emitting  >100  tons per year or potentially
emitting >100 tons per year, respectively) were given a 2 and sources clas-
sified as B (emitting <100 tons per year) were rated 1.  In addition, those
facilities identified by the Region as sources of hazardous air pollutants**
were rated 3.   Facility ratings are presented in Tables 2 and 3.  No attempt
was made  to  qualitatively rate the air emissions  for each installation due
to the scarcity of pertinent information.   Likewise, no attempt was made to
incorporate fugitive emissions  into the rating system.
 *   As listed in 40 CFR 50
**   Aa listed in 40 CFR 61

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                                 RESULTS

     Using the assigned ratings, the selected Federal facilities were ranked
in decreasing order  of overall  potential to cause environmental problems
[Table 2].   These  same facilities were  ranked  in decreasing order by State
and alphabetized by  the city in which  located [Table 3].  These Tables 2
and 3 are useful  in  identifying facilities with relatively high potential
for environmental  problems,  and they also show which activity(ies)  at a
facility contribute  most/least  to this  potential.  This  information can be
used to help develop strategies for followup site inspections.

     As previously stated, the  facility rating was not designed to be  com-
pared to a fixed number to indicate whether an installation is environment-
ally  "good"  or  "bad".   Rather, the  rating  indicates the potential  of a
particular facility to have environmental problems relative to other instal-
lations.  A  relatively high  total rating indicates that, based on the  type
and level of onsite activities, a facility has a high probability for causing
environmental problems.  It also indicates that further in-depth evaluation
of the facility may be warranted.

     It should be noted that this prioritization system is meant to provide
only an  initial evaluation of  selected  facilities.   Because of the general
nature of the information used, site-specific information should be obtained
to verify or deny a facility rating prior to an onsite investigation.   Site
information can be obtained from Regional program staff and State and local
agencies familiar with the facility.

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                                                   Table  2
                                      FACILITY  RATING  BY  RANKING
               -3CILITY

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W21J090CC6
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                -«y ?! 4 -wy
                          MV

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                              Table 2  (cont.)
                                                                                      10
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 5 ic 13 t :5
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 ^1  1^3 «i/£':-
 530-. I'.i-S iC
 iivar:ar«,  I?

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                                Table 2  (cont.)
                                                                                           11
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:)

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                                               Table 2  (cont.)
                                                                                                         12
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                                               Table 2 (cont.)
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                                Table  2  (cont.)
                                                                                          14
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                                                                         15
                          Table 2  (cont.)
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                                             Table  3
                                 FACILITY  RATING  BY  LOCATION
                                                                                             16
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                                                  Table  3  (cont.)
                                                                                                             17
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                                              Table 3  (cont.}
                                                                                                     18
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                                                Table  3  (cent.)
                                                                                                         19
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                                       Table 3  (cont.)
                                                                                           20
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                                              Table  3  (cont.)
                                                                                                     21
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                                        Table 3  (cent.)
                                                                                       22
             ::TY
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-------