Site/Incident
Characterization Model
Instruction Booklet
Csis)
N PR0^0
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TABLE QF CONTENTS
Page
Number
Introduction to the Booklet 2
About the Site/Incident Characterization Model 3
Potential Uses of the Model 4
The Components of the Site/Incident Characterization Model 6
Factor I: Degree of Human Health Risk 7
Factor ll: Degree of Environmental Risk 8
Factor III: Degree of Technical Complexity 9
Factor IV: Degree of Regulatory Complexity 11
Factor V: Degree of Management/Administration 12
Factor VI: Degree of Cost 13
Factor VII: Degree of Public Sensitivity 14
How to Use the Model 16
Model Evaluation Sheet 17
The Model Form 19
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Introduction to the Banui*Vi
The Site/Incident Characterization Model (SICM) is being provided to
you as an optional tool to assist you in your job. This booklet is designed to
riZe y°U withthe Site/Inc'dent Characterizati°n Model, its development,
and the potential uses of the model. This booklet provides direction on how
t0^If ^ !he model for a variety of purposes. In addition, specific uses of the
moderf have been identified for Branch/Section Chiefs, First Line Supervisors,
and OSCs/RPMs.
On the following pages you will find some background information
about the model, a general description of its components, and some
potential uses of the model. Some potential uses of the model are presented
on pages 4-5. The Site/Incident Characterization Model consists of seven
factors. In addition, level guidelines are provided to guide you in rating the
actors on a seven-point scale. Pages 7-15 provide in-depth descriptions of
e seven factors. Each factor has its own set of level guidelines presented
on the same pages. Page 16 provides instructions on how to use the model.
In order to further evaluate the usefulness of this model, we are
^ [I? th°S^ '3eoP'e who use t0 provide us with feedback. Enclosed in
this booklet is an evaluation sheet for you to fill out and send to us so that
we may continually monitor how the model is being used, how much the
model is being used, who is using the model, and how the model is viewed
in the Regions.
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About the Model;
The Site/Incident Characterization Model (SICM) was developed as
an aid to hazardous waste managers in rating sites/incidents. The model
was originally conceptualized in a June 1988 meeting of the Advisors to the
OSC/RPM Support Program, and revised during an October 1988 Advisors'
meeting. At the November 1990 Advisors'meeting, Advisors from across the
Regions discussed the possible uses of the model and the mode of
implementation.
The OSC/RPM Support Program Advisors determinedthat the essence
of "site/incident complexity" consisted of how complex a site or incident is
based on each of seven common factors which they felt were always present
and must always be evaluated as part of a site/incident cleanup. These
sevenfactors comprise the model, andtogetherdefine site/incident complexity.
The model was validated and finalized through a process where OSCs
and RPMs were asked to rate a number of actual sites/incidents based on
descriptions provided to them. Their ratings were consistent and proved that
the model is able to determine the overall complexities of real-life sites/
incidents. During the November 1990 Advisors' meeting, the Advisors
determined that the model offered a variety of uses for many people in the
Regions, including Branch/Section Chiefs, First Line Supervisors, and OSCs
and RPMs. Some potential uses of the model are described on the following
pages.
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Potential Uses of the Site/Incident Characterization Model:
For OSCs and RPMs:
1. Learning Tool on the Various Factors Contributing to Site/
Incident Complexity-As part of the OSC/RPM BasicTraining
Academy, the model will provide some guidelines on the factors
to look for when evaluating sites/incidents. New OSCs and
RPMs in particular will be able to benefit from having the model
as a guide for use on their first site/incident assignment.
2. Tool for Mentoring New OSCs and RPMs - The model
provides a useful guide for mentoring new OSCs and RPMs on
the factors to look for when evaluating sites/incidents and
planning cleanup strategies. The model's factors and level
guidelines provide some examples of potential site/incident
situations. Mentors can refer to the model when discussing
actual sites/incidents with proteges and can actually take
proteges through an assessment of a site/incident using the
model.
3. Evaluation of Workload for Use In Performance Appraisals
- The model can be used to provide ratings of sites/incidents
worked on in order to show the types and levels of cleanups
dealt with as an OSC/RPM. The ratings resulting Irom the
model can help you in your pedormance appraisals to pinpoint
the types of sites typically worked on, past achievements
related to site complexities, and future goals in terms of the
types of sites you would like to work on in order to grow in your
career.
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Potential Uses of the Site/Incident Characterization Model:
For Branch/Section Chiefs or First-Line Supervisors:
1. Identification of Types of Sites and Resulting Workforce
Needs - The Site/Incident Characterization Model can provide
a broad view of the types of sites in your Regions and the types
of personnel and skills needed to manage the sites/incidents.
In addition, by rating the sites/incidents using the model, you
can determine the sites/incidents that are most complex and
cumbersome. Using the model to calculate the complexity of
the sites/incidents can assist you in making staffing decisions
and assignments, reassigning/redistributing work, and
determining future FTE needs.
2. Training OSCs/RPMs on the Contributing Factors to Site
Complexity - The Site/incident Characterization Model will be
included in the OSC/RPM Basic Training Academy beginning
In March 1991. The model will be presented as a tool for
teaming and evaluating the seven factors which together
contribute to the work needed to clean up sites/incidents. The
model can be further used for training when new OSCs and
RPMs begin managing their own sites. In addition, the model
wilt be included on the Mentoring checklist to promote its use by
mentors in teaching proteges about the factors that contribute
to the complexity of sites/incidents.
3. Creation of A Database of Information On Sites/Incidents
In the Regions - A database of information of sites/inciderits in
the Region can easily be created using the model. After each
site/incident is rated using the model, this information can be
entered into a common database which would allow for the
summation and comparison of all of the factors across the sites/
incidents.
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The Components of the Site/Incident C^racterlzatlon Model:
The model has seven factors that characterize the complexity of sites/
incidents:
Degree of Human Health Risk
Degree of Environmental Risk
Degree of Technical Complexity
Degree of Regulatory Complexity
• Degree of Management/Administration
Degree of Cost
Degree of Public Sensitivity.
Each of these factors is fully defined on the following pages. The factor
definitions highlight important topics to consider when evaluating the factors.
When using the model, a site/incident would be rated on each of these
factors using a 7-point scale. In order to assist you in rating sites/inadents
on the 7-point scale, level guidelines are provided tor each factor. These
level guidelines describe the least complex (rating of 1), average (rating of
4), and most complex (rating of 7) types of sites/incidents for each factor.
The level guidelines are provided only as examples and are not absolutes
or comprehensive. The intent of the level guidelines is to suggest a scenario
that would be least, average, and high in complexity for that factor.
After the site/incident has been ratedfor each factor, the factor ratings
are totaled to get the site/incident complexity score. The individual factor
ratings seive as useful information on the most volatile aspects of the site/
incident when planning site/incident cleanups. In addition, the overall site/
incident complexity score allows comparisons of sites to each other based
on their relative complexity. A fuil-sized model is provided on page 19 of this
booklet.
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Factor I: Degree of Human Health Risk
DEFINITION
Human Health Risk includes:
Site Access (remoteness, security)
Exposure Routes (number of routes such as air, water, soil
food chain, direct contact)
Fire/explosion threat
Population (size, type and proximity)
LEVEL GUIDELINES
Level I Qvfll Guideline
1 Low human health risk at the site/incident. This level may be
indicated by: site is remote and/or secure; exposure routes are
minimal (e.g., if groundwater threat, an alternative water supply is
available); no fire/explosion threat; minimal number of people and
no sensitive populations (e.g., schools, hospitals, camps, etc.)
nearby.
4 Moderate human health risk at the site/incident. This level may be
indicated by: access to site Is possible and there is evidence of
trespassing; several exposure routes (e.g., on-site soil
contamination and moderate off-site migration); fire/explosion
possible under extreme conditions; population of moderate size
is nearby and is a sensitive population.
7 Extremely high human health risk at the site/incident. This level
can be indicated by: unrestricted site access and regularly used
by local population (e.g., children use site as a playground, etc.);
extreme or numerous exposure routes pose serious threat (e.g.,'
direct contact through soil, air, ground and surface water
contamination); imminent threat of fire/exptosion; high density
residential area surrounds site; several sensitive populations
within close proximity of the site.
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Factor II. Degree of Environmental Risk
DEFINITION
Environmental pj§K includes:
• Exposure routes (number of routes)
Population (flora, fauna, aquatic— size, types and
proximity)
Sensitive environments/endangered species
(e.g., archaeological, wetlands, historical)
LEVEL GUIDELINES
Level Guideline
1 Low level of risk to environment. Low environmental risk may be
indicated by: minimal exposure routes; endemic populations not
affected; sensitive environments/endangered species not nearby
and not affected.
4 Moderate level of risk to environment. Moderate environmental
risk may be indicated by: several exposure routes; stress and
death evident in vegetation and some endemic populations;
potential threat to sensitive environment/endangered species in
the area.
7 Extremely high level of risk to environment. This level may be
indicated by: numerous exposure routes posing extreme risks to
environment (e.g., on- andoff-srte contamination via contaminated
son, surface water, etc.); wide variety of flora, fauna, and aquatic
populations of which indicator species have suffered serious
losses; pristine and sensitive environments (e.g., wetlands) and/
or endangered species on and adjacent to site.
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Factor III. Degree of Technical ComplexHv
DEFINITION
Technical Complexity includes:
• Amount of data available
• Physical condition of the site (geological, accessibility)
Type and volume of contaminants
Number of sources
Extent of contamination (number of media, off-site
migration)
• Variety of waste management situations
Worker safety
Type of remedy (off-site/on-site, innovative technology)
LEVEL GUIDELINES
Level Level Guideline
1 Technical complexity is low. Indicators can include: adequate
data available; site is accessible and geologically stable; few
classes of contaminants, containers in good condition, volume of
contaminants is small; one or two primary sources of contaminants
(e.g., drums or lagoons or tanks, etc.); extent of contamination is
limited on-site to areas surrounding the sources; one or two media
affected; one to two straight-forward waste management situations;
worker safety requires minimal protective equipment (e.g., Level
D); remedy(les) Is/are straight-forward with no innovative
technology required.
4 Technical complexity is moderate. Indicators can include:
inadequate existing data requires some additional data collection
and analysis; site accessibility is restricted; several incompatible
classes of contaminants, volume of contaminants is moderate;
several deteriorating sources of contaminants; contamination
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throughout site and potential for off-site migration, two or more
media affected; several waste management situations of varying
complexity; worker safety is a concern requiring moderate
protective equipment/clothing (i.e., levelCto B); type of remedy(ies)
require both on- and off-site treatment/disposal however no
innovative technology.
Technical complexity is high. Indicators can include: little data
available, requiring extensive data collection and analysis efforts;
site accessibility difficult (e.g., requires access agreements with
adjacent property owners and/or construction of access roads,
etc.); multiple, incompatible, mixed classes of contaminants,
large volumes of all types; numerous sources, most of which are
leaking or deteriorating; all media affected with extensive on-site
contamination and actual or potential off-site migration; numerous
and inter-related waste management situations; worker safety
requires maximum level of personal protection (i.e., level A);
remedies require innovative treatment/disposal technologies and
other oompiex approaches.
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FartnrlV- Dagreft nf Regulatory Complexity
DEFINITION
Rttfl.ilfltnrv Complexity includes:
• Compliance with Federal, State and local statutes, regulations and
ordinances (e.g.. CERCLA/SARA, NCP, RCRA.TSCA, CWA, SDWA,
CAA, etc.)
• Compliance with other Federal agency regulations (e.g., DOE,
POT, NIOSH, DOD, BLM, HHS, DOI, etc.)
Absence of regulations/policy (e.g., precedent setting)
LEVEL GUIDELINES
Level Level Guideline
1 Regulatory complexity is low. Indicators of this level can include:
few regulatory requirements (I.e., CERCLA and NCP only);
States and localities have few more stringent requirements to
comply with.
4 Regulatory complexity is moderate. Indicators for this level may
include: Several regulatory statutes to comply with, including
federal (e.g., RCRA, TSCA, CWA, CAA), State, and local; one or
more Federal agency may be involved requiring additional
requirements to be met; absence of EPA policy.
7 Regulatory complexity is high. Indicators of high regulatory
complexity can include: multiple Federal, State or local statutes
and/or policies must be complied with for each removal incident,
operable unit, remedy or discrete types of remediation; extremely
sensitive and complex regulatory situation (e.g., involves Indian
land, etc.); other federal agencies play a large role in the
development and implementation of the remedy; several unique
circumstances are complicated by lackof policy and/orregulations.
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Factor V. Degree of Management/Administration
DEFINITION
Management/Administration includes:
• Enforcement (PRP and title search, PBP dispute resolution/
negotiations, PRP oversight)
Contractor management
• Coordination with other participants (e.g., State, local and
other federal agency officials, EPA HQ staff, ATSDR,
USCG, strike teams, ERT, RRT, PRPs, etc.)
• Documentation (administrative record, site logs, other
required documentation)
• Site Safety
LEVEL GUIDELINES
LfiXfil Level Guideline
1 Management/Administration complexity is low. Indicators can
Include: no known PRP (e.g., site inspection, title and PRP
search did not identify a PRP); minimal number of contractors
required; no other parties involved; minimal documentation;
standard site safety requirements.
4 Management/Administration complexity is moderate. Indicators
can include: PRP is identified and is involved in dispute resolutions/
negotiations; multiple contractors are involved; other parties are
involved (e.g., State, local, special assistance teams); another
agency is involved; documentation is increased; special site
safety measures required; for removal sites/incidents, statutory
exemptions may be required.
7 Management/Administration complexity is extremely high.
Indicators can include: numerous PRPs, some contributing to
remedy; numerous contractors, some contributing only to specific
remedies; multiple participants from other Federal, State and
local agencies and special assistance teams; large documentation
effort; complex site safety requirements; for removal sites/incidents,
statutory exemptions are required.
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FflCtfffvl DftflreeofCost
DEFINITION
Consider the impact of cost on action; including cost management and
budgeting requirements.
LEVEL GUIDELINES
Level Level Guideline
1 Low cost requirements. Indicators include: funding Is available
from Superfund; no cost recovery is sought; fund balancing is not
an issue; standard cost management and budgeting requirements.
4 Moderate cost requirements. Indicators include: balancing the
remedy with protectiveness; mixed funding may be sought or cost
recovery if the PRP is known; fund balancing is not a concern; cost
management and budgeting requirements increased; for removal
sites/incidents, cleanup may exceed 2 million dollars.
7 High cost requirements. Indicators include: cleanup requires
large outlay of capital; mixed funding is pursued but cost recovery
is more likely; fund balancing may be an issue in extreme
circumstances; extensive costs management and budgeting
requirements; for removal sites/incidents, cleanup exceeds 2
million dollars.
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Factor VII. Degree of Public Sensitivity
DEFINITION
Public Sensitivity includes:
Type of community (e.g., urban city, rural, suburb, elc.)
Sensitive populations (e.g., hospital, school, etc.)
Political sensitivity
• Involvement of local government
• Status of PRP in community (e.g., supports economic
well-being of community, history of environmental
non-compliance, etc.)
• Community experience/Involvement (history of community
Involvement, status of public interest groups, awareness of/
experience with hazardous substances, perception of health
risk)
• Communication requirements (media coverage —size of
market, type (i.e., local, State, national), frequency; public
meetings; FOIAs; Congressional)
• Economic impact of remedy
LEVEL GUIDELINES
LfiXfil Leva!
1 Public sensitivity appears to be veiy low. Indicators may include:
rural area; no sensitive populations nearby, little or no political
sensitivity, no prior experience with EPA and State cleanup
actions; no known PRP; no existing public interest groups;
unlikely formationof public interest group; public perceives health
risks to be low; minimal media coverage expected; no economic
Impact.
4 Public sensitivity Is average. Indicators may include: small town
with some sensitive populations; community has existing public
interest groups likely to be active in tracking cleanup progress:
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local and State media coverage is expected; community has
mixed experiences with State and EPA; PRP has some influence
over the economic well-being ot the area (e.g., employs 10% or
less of the community labor force); public opinion of the PRP is
mixed; public perceives health risk to be serious but unequal for
whole community (e.g., site borders some residential and
commercial properties or site is contaminated media not used by
all of the public); remedy may require some affected citizens to
expend money; moderate media coverage.
7 Public sensitivity is extremely high. Indicators may include; large,
politically active town or city; previous negative experience with
State and/or EPA (e.g., feelings of betrayal or inadequate
environmental/health and safety protection or promises unkept);
PRP has a major influence on the economic well-being of the
community (e.g., employs more that 25% of the community labor
force); PRP actively conducts public relations campaign; public
perceives highly persistent and toxic substances are present
(e.g., PCBs or dioxin); sensitive populations (e.g., hospitals,
schools, etc.) and other public groups perceive migration pathways
directly affect them (e.g., contaminated ground water); portions of
mitigative actions may pose direct economic impact on the
community (e.g., requirement to pay for water main or hookups);
or require drastic/dramatic changes in the lifestyles (e.g., removal
of contamination from home, yard or temporary or permanent
relocation).
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How to Use the Site/Incident Characterization Model;
1. Familiarize yourself completely with the Site/incident to he
rated, if you are not the OSC/RPM managing the site/incident,
you should consult with the OSC or RPM most familiar with the
site/incident for current, relevant information about the site/
incident. Refer to current, appropriate documentation when
completing the model form.
2. Read and familiarize yourself with the definitions for each factor
and the level guidelines for each factor.
3. Photocopy the model form from page 19 of this booklet Record
the name of the site/incident, the Region, and your name on the
blank model form. Circle the current phase of action of the site/
incident and fill in the date of the rating.
4. Circle a slnnle rating for each factor that best depicts the
of complexity for that factor. Use the level guidelines to assist
you In estimating the complexity for each factor. Be sure to
realistically depict the level of complexity at the site/incident as
currently known.
5. Record the selected score for each factor in the rioht-hanri
column. When each factor score is recorded, sum all seven
scores and record the total at the bottom. This total site/incident
complexity score will provide a reference by which comparisons
of sites across the Region can be made.
6. File the model form with the other documents on the site/
incident. In the future, you may want to rate the same site/
incident again to determine the changes in co mplexity that have
occurred over time.
7. Fill out the evaluation font] fihout the model on paoe 17 of this
booklet and send to;
Karen Argain
EPA Headquarters
Technology Innovation Office
401 M Street, SW
Mail Code OS-110
Washington, D.C. 20460
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Site/Incident Characterization Model Evaluation Sheet:
Your name: Circle one: Branch Chief
Dale: Section Chief OSC RPM
Please answer the following questions related to the model and your
experience with it. When you have completed this form, please mail it to:
Karen Argain
EPA Headquarters
Technology Innovation Office
401 M Street, SW
Mail Code OS-110
Washington, D.C. 20460
1. On a scale of 1 (low) to 7 (high), to what extent was the model useful
in rating the site/incident? Please explain
2. On a scale of 1 (difficult) to 7 (easy), how difficult did you find the model
to use? Please explain
3. Based on your experience with the model, would you use it again?
4. Are there any changes to the model that you feel would make it more
useful?
5. On a scale of 1 (poor) to 7 (excellent), what is youroverall rating of the
model? Please explain
Thank you for taking the time to complete this evaluation form.
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Model
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SITE/INCIDENT CHARACTERIZATION MODEL
SITE/INCIDENT NAME REGION
RATER'S NAME RATING DATE:
PHASE OF ACTION: REMEDIAL: RI/FS ROD RD/RA
REMOVAL: START ONGOING COMPLETED
EMERGENCY
SITE/INCIDENT FACTORS SITE/INCIDENT RATING
1.
Degree of Human Health Risk
Degree of Environmental Risk
Degree of Technical Complexity
Degree of Regulatory Complexity
1
2
3
4
5
5
7
II.
1
2
3
4
5
e
7
III.
1
2
3
4
5
§
7
IV.
1
2
3
4
5
e
7
V.
Degree of Management/Administration
1
2
3
4
5
5
7
VI.
Degree of Cost
1
2
3
4
5
7
VII.
Degree of Public Sensitivity
1
Z
3
4
5
e
7
Total Site/Incident Score
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56". 3
¦ Hb
n°ii
025093
7 -
date due
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Richard Hammond
Mailcode: 4WD-RCRA
U,S. EPA Region 4
Waste Management Division
RCRA and Federal Facilities Branch
345 Courtland Street, N.E.
Atlanta, GA 30365
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