PB92-963326
Rev i sed Hazard Ranlung System: Evaiuat.ng Sites After Waste Removais
U.S.) Environmental Protectjon Agencj, Wasn.ngton, DC

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linnet Stales Office of Pubiica'ion 9345 1-03FS
Environmental Protection Solid Waste and OctobeM99i
Agency	Emergency Response 		
&EPA The Revised Hazard Ranking
System: Evaluating Sites
After Waste Removals
Wice of Emergency and Remedial Response
lazardous Site Evaluanon Division. OS-230	Quick Reference Faci Sheet
The U S Environmental Protection Agency (EPA) has revised the Hazard Ranking System (HRS)
in response to the Superfund Amendments and Reauthorization An of 1986 (SARA) The HRS is the
primary mechanism for placing sues on the National Priorities List (NPL) Under the original HRS
promulgated under the Comprehensive Environmental Response. Compensation, and Liab.lirv Aci of 19S0
(CERCLA).a site was scored based on conditions that existed prior to any removal actions Under the revised
HRS. waste removals may be considered under certain circumstances The term "waste removal", as used in
this faci sheci. refers to the phvsical removjl from the site of hazardous substance*. or wastes containing
hazardous substances The waste removal policy is designed 10 provide an incentive for rapid response actions
hv poientiallv responsible parties (PRPs). reducine risks to the public and the environment and alio 
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by erecting fences or providing alternate water
supplies These t\pes of actions do not constitute
a qualifying removal for HRS purposes
A qualifying removal for HRS purposes does no^
'.»\r lo wniove nil tltr waste d' u a 11 c ot even (ill
if waste in a pjnit.ul.ir .source Partial removal of
wa\io from a Mio	all ilucc i*s|uiic mcm.s)
..ill be considered in scoring the sue. however. a
complete removal generallv results in the
maximum score reduction
Timing
The second requirement is that the removal
must have occurred prior to the cutoff date
applicable to the sue The HRS preamble states-
thai EPA will onlv ccnsider removals conducted
prkit 10 the sue inspection (SI) Because of
differences in site assessment activities for ditterent
t\pes of mus (e c EPA-lead Stale-lead Federal
facilities) criteria fur determining the appropriate
cutolf date under [his rule dilfer among si'Js
Non-1 fderal Facility Sues An SI for non
Federal facihtv sites begins with development of a
workplan which often includes the sampling
strategv for the sue EPA believes that it would
disrupt Sis to consider the results of removal
actions conducted after this point because to do so
could requite revving sampling plans resampling
or restoring the jiie Therefore the SI cutoll date
cuu'ralK is the date that development ot a
workplan lor the SI begin* or whatever date is
analogous to workplan development (Figure 21 It
no such dau i* available (i e no workplan or
jnalogous event) the cutofl uate is the earliest
documented date lor Super fund SI activities at the
siu For example this date mav include, but is not
limited to the djte when a Supcrfund SI report
collating previou;
development of uork.pl.in for firs. "*l .
analogous Odie. sud)
•	SI start date in CI RCL1S
•	Date of tecMicai directive docune- or
memorandam (TDD 0' TDMl issjed ;o-
work assif.men: tc develop SI wo'kpar.
or
•	Da-.e o! ar 51 rc^oT^ ssanre to doc o- S!
workplan
]f no sue!" d''e >s Cilr-t* „• iV cl d -
carhes docamc" lJ da e o *jr.' ~ s:
a:u\'.ies a, the v ¦
Federal Kicilitv Siifs \s - >- -c
piaccner" oi Federal 'ies Jivf.
facilities doekei Therelore the cuto'i J ;e to-
Federa! taciln\ sites is li» months atur the siu i*
pljced on the Federal facilities dockci
Sites with Multiple Sis For sues w.il, nvu
than one si the euioll eiate lor mos siii> will K
keved to the I'.rM SI however the -Vjcno m. ¦.
establish a later cutoti d.iie unde'i cco-ii
cireumsiances
•	II a suonJ SI impli nuniing a convletcK new
sampling strategy. conducted the Xeencv 'm.^
consider basing tfe cutofl date on se or 1- pi in
development for the second SI Considering
removals in these cjses i> noi likel. to undid,
disrupt the sue assessment process
•	For sues whore the first SI wa' tondut led more
than 4 vears prior to HRS scoring ihe Agenov
mav consider on a case bv-case basis (.hanging
the cutofl djte to a la'cr date (CFRCLa
Section 116 added b\ SARA mandates thai
EPA conduct site ascesvmen. work wnhin 4
vears
However the transition to the revised HRS ni.iv
mean that some site evaluations will exceed -J vears
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because sites will require kllow-up sampling
Follow-up sampling mil not be used 10 determine
a new cutoff date even if more than 4 years have
elapsed since the first cutoff date because the bulk
of sampling genera]l\ will have been conducted
previously
Proper Destruction or Disposal
The third requirement for a qualifying removal
is that all waste removed must be disposed or
destroyed at a facilin, permitted under ihe
Resource Conservation and Recovery Act (RCRA)
or the Toxic Substance Control Act (TSCA) or by
the Nuclear Regulatory Commission (NRC) This
requirement encourages proper disposal of the
removed wastes and discourages simph movinc
waste and associated hazards 10 another louition
SCORING HAZARDOUS WASTE QUANTITY
Hazardous waste quanutv (HWQ) is scored as
follow;, for sues where waste has been removed
•	Do not count ihe amount of waste removed in
anv qualifvinc removal when scoring HWQ
(.Certain minimum HWQ factor values nuv
apply, howevc j
•	Store HWQ as if the waste was not removed for
all non-qudhhinc removal*
For partial qualifvinc removals, the ..corer
generally may subtract the amount ol waste
removed from the total amount of waste deposited
in a source, if the same tier can be u^ed for
scoring That is, the total (pre-removal) and
removed HWQs musi be determined using the
same HWQ tier For example, if HWQ for a
source is scored using Tier B (hazardous
wastestrcam quantity) but onlv Tier C (volume) of
the removed waste is known, the HWQ for the
removed waste cannot be subtracted from the
HWQ for ihe entire source If both the source
and removed waste arc scored using Tier C. HWQ
for the removed waste can be subtracted In
addition. where HWQ is estimated as the once-
filled volume and the total volume 01 waste
deposited is known to be manv times this volume
(c g , surface impoundments), the amount of waste
amoved cannot be subtracteJ
The accuracy of scoring sues with qualifying
removals depends on being able to determine with
reasonable confidence the quanmv of hazardouv
substances remaining in sources at the site and the
quanutv already released into the environment
Consequent!}, minimum factor \alues (MFV; for
HWQ apply in the absence of sufficient
information to adequately determine the quanutv
remaining and the quantity released Figure 3
explains how to determine appropnaie minimum
HWQ factor values for migration pathways (1 c ,
ground water, surface water, and air pathways)
HWQ for M.grallon Pathways
Tier A (hazardous constituent quantity) of the
HWQ evaluation involves determining the quanutv
of CERCLA hazardous substances remaining in
the sources and in releases to the environment
To score HWQ completely using Tier A the 101.il
mass of all CERCLa hazardous substances in all
sources and in releases from the sources to trie
environment for that pathway mus' be known or
estimated with reasonable confidence If Tilt B
(hazardous wastestrcam quanmv j. C (volume) or
D (area) is evaluated for anv source for the
pathvvav. the HWQ factor \aluc for that mieraiion
pathway ib subject to minimum values
For migrauc" pathways, a pathwjv-speufu
minin.um factor value applies to all sues where
hazardous constituent ouanmv cannot fx
adequately determined At s lev where no
qualifvinc removal has taken place and there are
no Leve1 1 or 11 targets in a given pathway ihi
HWQ factor for that pathway is subject 10 a
minimum value of 10. if there are Loci I or 11
targets, the minimum value is 100 At sues vVu
a qualifying removal has occurred, the minimum
HWQ factor value for a given migratior pathway
depends on several considerations
• If a target in that migration pathway is subject
to Le.el I or II concentrations, the minimum
HV'Q factor value for that pathwav is 100
¦ if no targets in that migration pathwav are
subject to Level 1 or Level 11 concentrations
then
If the HWQ factor value would be 10C1 or
greater without considering the removal
then the minimum HW'Q factor value for
that pat iwav is 100
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FIGURE 3
Determining Minimum Factor Values (MFV) for Hazardous Waste Quantity (HWQ)
at Sjtes with Removals (Migration Pathways Only)
Is HWQ fac:or. « ilJiuui
of ihe rcmcji-aS.
| rtaicr Lhaji or equal us 100'
Note Minimum HWQ factor values are pathway-specific
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subsurface samples 10 \crif> the PRPs evaluation
of hazardous constituent quantm for the
remaining waste Sis are not intended to address
the full extent cf contamination at sites, therefore.
EPa generalK wi,i relv on PRPs to quantifv the
extent of releases to all media, so that thev can
receive the maximum possible reduction in HWQ
factor value. If subsequent Regional sampling
reveals that hTWQ is greater than that estimated bv
the PRP dunng the removal, the HWQ factor
value is calculated based on these new. data
SCORING OTHER FACTORS
For the migration path.vavs, a number of factors
other than HWQ can be affected bv the removal of
waste and. in some cases, are scored to reflect a
qualifying removal (Figure 5)
Likelihood of Release Factors
The results of ? quahfving removal mav be taken
into account in scoring several factor in the
likelihood of release facior categorv for the source
subject to the removal These factor? include
•	obsened release {or ob^er\cd contamina'ion t
•	containment and
•	source t\pe
An ob^er\ed release 10 one of ihe miration
pathway documenied heiore or after a qualifying
removal car, be used 10 ^corc likelihood o' release
That is a qualifying removal doe<. not negate the
fact thai the source alreadv has released to the
environment However. areas of obsened
contamination in the soil exposure pathwav are
intended to reflect continuing risks ai the sue
Therefore, soil ex-posure pathwav factors should be
documented b\ sampling that represents conditions
at the time of the SI
Chances in source containment should be
considered onK when
•	the change results from a qualifying removal
•	no observed release of a hazardous substance
associated with that source is established for a
given pathwav, and
•	the containmeni factor value for the affected
source is equal to 0 for that pathwav after the
removal
FIGURE 5
Scoring Other Factors
Chances in factor other than HWQ should be
considered in scoring a migration pathw3\ onN if
•	The chance in that factor was a direct result
of a qualifvmg removal
•	No observed release of a baza'dous
sjbstance associated urh the source is
established for tha' pathwav and
•	The removal cornpletetv e'iminaied a source
(and us associated releases) or resjlted in a
cor:£-".~)e- facto: \ aluc oi 0 for (ha1 source
in that pathwav
It change^ in containment result in a )ovs<.r but
non-zero -- containment fjctor vjluc then lfui
source is assigned a containment factor that doi>
not refk».t the change*, that resulted irom the
qualiiving removal Sim.iarK chance-, in source
tvpe that result in a non zero source rvpe factor
value are not considered in scoring Chance' ihat
result in a source tvpt factor value of (.' art.
considered
Substance-specific Factors
Some substance »n.cific HRS fa».ior* tn be
aflecied if a qualifying removal completeh
eliminate* a hazardous substance from a p
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will be ur.sble 10 obtain such information and will
rely on PRPs 10 produce these data If i jrtion
of a source is eliminated in a qualifying removal,
the remaining portion of that source is assumed to
contain the same hazardous substances 2S ihe
removed portion, unless the PRP can document
otherwise (e g, provide analytical results or
manifest data that convincingly demonstrate a
given hazardous substance is not present in the
remaining portion of the source) For the soil
exposure pathway, toxicity should be based oniy on
hazardous substances meeting tlK criteria for
observed contamination at the time of the SI
Targets Factors
Sue-specific target distance limns or distance
rings in migration pathwavs mav change it a
qualifying removal eliminates a source or changes
a source in such a wav that it is not available to y
patlf-av (i e conuinment factor value of 0)
For a mieration paihwav
•	If an observed release (or observed
contamination) is associated with a source,
include that source wh-n measunng target
distances, regardless of whether a qualifving
removal has occurred or whether the
containment factor value is 0
•	It a source is completely eliminated or the
characteristic of the source are changed such
ihat the source < containment factor value for a
eiven paihwav is o and no observed release of a
hazardous substance a--ociated with lhai source
to that paihwav ha- occurred do run include
that source in measuring target distances for that
paihwav
•	If the characteristics of a source are changed, but
that source is still available to a given pathway
(i e . non-zero containment factor value), then
include that source when measuring target
distances for that pathway
For t! e soil exposure pathwav
•	If all or part of an area of observed
contamination is removed do not include the
remove'' area when determining the target
distance limits
EPA generally will not be able to document the
complete removal of a source within the normal SI
field sampling EPA will rely on PRPs to provide
the additional information thai is needed to
document complete removal of a source
MANAGEMENT IMPLICATIONS
Site managers should be aware of the changes in
sue scores that may occur under the waste removal
policy and understand the need to document
releases at removal sites in addition. EP-\s
removal and sue assessment program^ mus>
coordinate at sites where the remo.a! program i-
considering taking action
Changes in Site Scores
The waste removal polio is intended to provide
an incentive for timelv and thorough removal- b\
potentially lowering the HRS score lor sues where
a qualifying removal >s conducted Th.- store
lowering mav be major or minor depending on the
characteristics of the sue and the extent of the
removal action
•	Because the HWQ factor values are grouped in
iwo-order-of-magnuud' ranges (100 H'dOUand
1000.000). large changes in the HWQ factor
value mav occur for two npe- oi sues (l, -lie-
where very large quantities ol waste h ivc been
removed and (2) sue- where the HWQ laitoi
prior to removal was slighth above ilu lower
boundary of o HV»Q range
•	Likelihood of release could be aft-.«.ied to
migration pathwavs uhe;1 no observed release
lias been deie' ted arid j source compleieh
eliminated from a pathwav bv a qualiivini;
removal (or is chanced such that t he
containment factor value now equals 0)
•	Large changes in target factor values could oecur
if surface soil contamination is removed from
areas occupied bv resident individuals or u
source elimination significantlv chance- the
targets evaluated
Documenting Releases
At sues where the PRP claims t,< |,.i\e
compleieh eliminated a source (including an\
associated releases) the PRP must conlirm ihi-
claim through adequate sampling A source will be
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If the HWQ facior value would be less than
100 without considering the removal, then
the minimum HWQ factor value for thai
pathway is 10
The minimum HWQ facior value of 10 (i e . final
bullet abo- ej ensures thai a sue will not receive a
higher score simply because a removal has been
conducied Under no circumstances will a partv be
penalized for conducting a qualifying removal
HWQ for Soil Exposure Pathway
HWQ is evaluated different!) for the soil
exposure pathway than for the migration pathwass
In the soil exposure pathway. HWQ is akavs
based on condmons at the time ol the SI Onl\
the first ? feet of areas nj observed contamination
plus tanks, drums, and other container sources arc
included in evaluating HWQ The HWQ factor is
subject to a minimum value of 10 (if hazardous
constituent quantity cannot be adequately
determined), regardless of whether there has been
a qua'ifyine removal Section 5 1 2 2 of ihe HRS
rule provides further information on evaluating
HWQ for the soil exposure pathwav
DETERMINING QUANTITY OF
HAZARDOUS SUBSTANCES REMAINING
EPA's removal polic\ is meant to eitourjee ilit
PRP conducting the removal 10 determine the
quaniitv of CERCLA hazardous substances
remaining in sources at the sue and ihe full extern
of the associated releases 10 the environment If a
release to the environment has occurred or is
suspected, ihe PRP must determine wnh
reasonable confidence the total quantity of all
CERCLA hazardous substances in releases to all
media to receive the maximum reduction in score
(ie, to avoid use of the minimum factor value)
This requires determining HWQ (or all sources
completely using Tier A {Figure 4) As discussed
previouslv, if the toirl mass of all CERCLA
hazardous substances in al] sources and in teleascs
to the environment (or in areas of observed
contamination for the soil exposure pathway)
cannoi be adequately determined for a pathway,
the HWQ facior for that pathway is subject 10
minimum values
At site< where surface soils or wastes have been
removed. Regions are encouraged to collect a
reasonable number of additional soil and/or
FIGURE 4
Adequately Determining Hazardous
Constituent Quantity
Hazardous constituent quantity can be calculated
for a source using the following equal ion
HCQ ¦ EC, x DmxVt
i-i
where
HCQ = hazardous consilient quantr.v (o:
source S (mass)
C, = average concentration of const.-ru'tni
i (mass'mass)
n = toial nun "xr o'CEUCLA hazardous
substances
Dc = densm of source medium
(mass/volume)
\ . = volume ot soi-rce S (volume)
I'o use this equation ic adeaurs civ dciermri
hazardous constituent quanntv lur a sour
•	the equation must be applied to each midiu m
« the '.olj-ne of itic snjrce hum he kne^x ^ u
rcoscna^lc confidence
•	-c preservative values frr ihv avcitivt
ronren'rniioR ol each haATdoj^ sub*'.1- i
deposited in the source must he kr.oun r. j-
•	there must be no release fro"i the source
The kev to using concentrat.on data to cv .r,. ,t
hazardcus constituent ouannu is deicrminr,;. a
representative value tor the average concentra'.ion
of each hazardous substance in the source or
paruon of the source This can be virv difficUi
for sources where ihe distribution of hazardous
subsiances shows hich spatial or tempo;.ii
variabituy In addition if a release from the
source has occurred, then the total mass of jIi
h?zardou< substances released 10 the environment
must also be adequatclv determined
Hazardous comiiiucm quanurv also can N
adequatelv determined if complete data are
available on the quanntv of hazardous substances
deposited (e g manitesi data) The procedure
described above does not applv to RCR\ wastes
or radionud.des
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evaluated on the basis of S] sampling unless the
PRP can produce additional information thai
documents compleie removal Furthermore, if
Regions believe that hazardous constituent
quantm for the remaining source and its releases
is not adequately determined, the mmimjm HWO
factor values for remo- al sites apply At sitei
where a PRP has caldiated hazar^ -:s constituent
quantity for a source. Regions are encouraged to
conduct sampling, to the extent practicable, to
verify this information
QUESTIONS AND ANSWERS
Q How are multiple removals at the same site
treated''
\ The number of individual removals does not
matier lone as each removal considered in
sco;ins: is a quahfving removal AJ1 qualifying
rcmovjK should be considered and all non-
qualifving removals should not be considered
when ^dlcuLning the HRS score
Q W hoc removals are convidered"'
A Thi v.jvu remov.il polio applies 10 all site<
regardle^ of the identity of the partv
conducting the removal EPA State, and PRP
removal- are subject to the same requirements
under ihe HRS removal policv
y Does the waste removal poliov applv to
Federal ijv ilnv sues'
\ "i es The onK dillerenu in applving the
removal pt1110. to Federal Jacihties is the
dn'terem.e in determining the cutoff date
Q Are Sis conducted bv States under cooperative
agreements considered EPA Sis for the
purpose- ot the HRS removal policy"
\ ^i es
Q If a qualifvmc removal eliminates the onK
drums in a croup for which data concerning
the conient- are available how should
substance specific factors be scored for this
source 1
\ In the absence of information to the contrarv.
Regions mav assume that the remaining
portion of a source contains the same
hazardous substances as the removed portion
If a PRP can produce convirune evidence that
i.: hazardous substances in the removed
portion of a source are roi present in ihe
remaining portion, these substances should
not be used to score any substance-specific
factors for that source Regions should not,
however, assume that hazardous substances
present in one source (e g , a group of drums)
are present m a different source (eg, a
landfill) without supporting information
Q. Prior to the cutoff dale for a site, the PRP
removed all of the waste from z pile and
transferred it to an on-sitecontammentsvstem
that would he assigned a containment factor
of 0 for all pathwavs Should the pile snll be
considered a source in 'coring the site''
A ^es "The pile should be considered when
scoring this sue Th1- response action did not
phvsicalh remove wa-te from ihe sue
mere fore, it is no.. a quahfving removal
Q A site had an SI three \ear<; ago bui a
number of addmonal samples were taken
subscquentlv to support HRS scoring Whuh
investigation should be used to assign the
cutoff date'
A Because the overa'l sampling stra egv is
developed in the fiM SI the cutofl date i<;
based on the first SI
Q Whdi if the cutoff dale fall- in the middle of
a waste removal that uj<. conducied over an
extended period oi time '
A Those wastes that were removed prior to the
cutoff date (in compliance with all three
requirements) are not considered in scoring
the sue
Q Can a removal assessment conducted bv ihe
EPA removal program be used to determine
the cutoff date1
\ No Sis conducted und'.r the aeci^ of
Superfund s sue assessment program art used
to determine the cutoff date for qualifving
reniov als
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FIGURE 6 - EXAMPLES
Example 1
A sue has a large landfill as its only source The lop 4 feet of the landfill were excavated and replaced with
uncontammated soil thai is now heavily vegetated The excavated materials were removed from the sue and were
propcrK disposed prior 10 i!k cuiofi date An observed release to ground water was established pnor to the removal
using datd from an on-site monitoring well
Qua'ifiration This is a qualihing remo\al benuse it meets all ihree requirements Consider the removal in scoring
the source
ir\VQ	Do not consider the quanntv of excavated materials in scoring HWQ Because it is unlikeh th?t the '
teal may of all CERCLA hazardous substances in the landfill and releases 10 environmental media
will be known or estimated w:ih reasonable confidence, this site is likely 10 be subject to a minimum
'-jWQ factor value of either 10 or 100 Calculate the HWQ factor value considering and not
considering the "moved materials to determine the appropriate minimum value if the landTi11 is
scored using Tier C [volume), ifien subtract the removed 4 feet from i*ie total voi-imc of the wasrc
If the landfill is scored using Tier D (urea), then ihe removl will no: change the HV.Q factor vjlue
Other kiaurs 5o 1 Hvposurc Because this pathway is. (.oncerncd v,Kh potential direct e\posurcs iosurfr.ee sourit^
ard the top 2 feet of soil onlv, replacing the lop 4 feet of contaminated material with clean soil h.t^.
eliminated the soil exposure ^aihwa^ for this site Unless contamination can be found in the top i»j
feet of soil ai this sue, the soil evposure naihwav receives a score of 0
Ajr The changes made in conjunction with the reniova1 result in a containment factor of zero for 'he
air pathwnv, therefore the landfill is no longer considered a source for ihe 3ir pathwav and is not
rcnsidcru" in am air pn'h\vj\ calculation (c g HVv 0 target distance) Bccjusc toe landfill is the o. a
s^urre a; this sue the air paihw.iv would receive a sccre of 0. unlev. an observed release to air v.. <¦
documented prior to the removal
Ground Water The observed release to ground water can still be used io score likelihood cf relent
Do noi consider he efiects of ihe removal m scorng factors otnc- than HWQ for the ground vwtc,
pathway
Surface Water The changes made in conjunction with the removal do not resi t in a containment
factor of 0 for surface water Do not take the effects of ihe removal into accoui, in scoring lacurs
other than HWQ for the surface water pathway
Example 2
One of ihe sources at a sue is a waste pile The wastes in this pile were transferred to drums that currentlv are stored
on-site while plans for ihcir disposition are made The cutoff date ij the date ihe work assignmeni for development of
ihe SI workplan was issued (1/1^89), this response action took place on 9/5/S9
Qualificjtion This is rji a qurhfung rcmo\al First ihis response action did not phvsicaJIv remove wastes from the
sue Second, the response action took place after the cutoff date for qualifying removals Do not
consider ihe removal in scorine the source
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FIGURE 6 -- EXAMPLES (concluded)
Example 3
One of the sources ai a sue is a group of approximately 20 drums All were removed and properl) treated and disposed
off-site prior to the cutoff date These drums appeared to be intact when removed, and extensive environmental
monitoring conducted by the PRP has Dot demonstrated a release in the area of the drums
Qujlification This is a qualifying removal because it meets all three requirements Consider the removal in scoring
the source
H^Q	Do noi include the quanttt% of waste m the removed drums in scoring HW'C If the Rcgior, is
convinced that no release to the environment has occurred and if all other sources at the sue can be
scored complcteh usinc Tier A no minimum HWQ value applies
Other Factors If the Region is convinces that the data indicate no release to the environment occurred do no;
include the removed drums as a source for an\ pathwav Do not use the area where the drums were
located to determine target distance limits Do not use hazardous substances that were present orlv
in the renoved drums and not in an\ other sources to score an\ substance-specific factors
Example 4
Ore of the sources at a sue is a waste pile containing hazardous substances Prior 10 the cutoff date the waste pile u.is
removed and ihc contents were propcrt> disposed off-site The SI indicated that the surface and subsurface soil arounO
ihc .ircj whe.v.' the pile was located contains elevated levels of arsenic ana chromium, hazardous sjbs'ances Isjiour. ic
be present in the removed wastes
Qu.iliTkntion This is a qualifying remi/ a! because it meets all three requirements Consider the removal in scor.rc
the source
HWQ	Do not include the haza.dous substances in the waste pile in scoring HWQ Unless oil sources and
releases at this site can be scored compluelv using Tier A, this sue will be subject to a minimum
HWQ factor value of either 10 or 100 Calculate the HWQ factor value both considering and not
considering the removed materials to determine the appropriate minimum value (i c the sue should
not receive a higher score because of the removal)
Other Factors This qualifying removal d.d not reduce the containment factor for this source to 0 for am of the
migration paihwjvs Therclore, do net cons.ocr changes related to this source thai could affcci
scoring of other HRS factors (e g , containment, targets factors) in scoring these factors other th.ir
HW'q"
Score the sou exposure pathwav using the arc,is of obscned contamination documented at the SI
NOTICE
The information set forth in this document is intended solelv for the guidance of Government personnel It is noi intended
nor can it be relied upon, to create an\ rights enforceable b\ am part\ in litigation with the U-.ued States EPA mav decide
to folk*- the guidance provided in this fact sheet, or to act at variance wuh ihe guidance, based on an analvsis of specific si:<.
urcumstarcrs The Agenc> also reserves the right to change this guidance at am time without public nonce
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