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
Seale, ;;_
^i^:/"i «r* r 2A. ;•; ";*r *
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"ear. -arso". -I
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2v«3-E
Z.cy ;•* -.
W21J090CC6
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, Cfl
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MV
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Table 2 (cont.)
10
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:s« aeo
5 ic 13 t :5
Za^larc, 13
^1 1^3 «i/£':-
530-. I'.i-S iC
iivar:ar«, I?
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Table 2 (cont.)
11
•flCILITY
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so. 31:30 ""
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a. TOO
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Santa Ana, Cfl
15306 Nort«ai< s'.-
U, Cfl
C3 Center
3ort "uaneot, CA
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aeai Sear: Give
Sell Bead, C3
:)
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Table 2 (cont.)
12
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Table 2 (cont.)
13
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aooiC
::TY
IMSSOOl&lifi
&5 11 * of .as Vegas
'arcury, M»
•i'JO si aeguroo EIvo
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nan i am, .-i
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San Francisco, CA
Pacific flvt
San ^eoro, Cfl
•J
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Table 2 (cont.)
14
-OCILITY
J
it
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:ii(DH NP"I7«C-_ _-sC'fi"I;;-3
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.;30t
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•laroala, -I
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15
Table 2 (cont.)
-5CIUTY
-DME9
".esc*,
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Table 3
FACILITY RATING BY LOCATION
16
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\cr» Q;^ ?o.iC£ 3s«
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San 3emard iro, !A
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Table 3 (cont.)
17
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fiOMOi
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MISSILE ~a
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T:1' ire »aritiie
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530<) Claus ^fl
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Table 3 (cont.}
18
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I:S.".;-ir5 ~£\
=ar
"'935.'* :3.--C
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?£ 1700^3323
SJC1700Z4491
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kin flurwt, CP
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Cuncordf CM
SIERRA AMY DEPOT
County ft fl£6
nerlong, CA
SEreME nJEL SUP CTS CIS.
Careuirez Scenic Or
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Table 3 (cent.)
19
ID
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CITY
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Table 3 (cont.)
20
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^ici-.c jrove, ~*r
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1.301
Sivc *
•ac-aaen:?, 14
-uiiton r:eia
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Table 3 (cont.)
21
•30
AOOflHB
:;TY
San r-arc;sco,-.3A
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aeou.veea, TA
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-I063CC3CC1* >
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Table 3 (cent.)
22
::TY
<*:'." :i."
.as
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