REGION VIII SUPPLEMENTARY GUIDANCE FOR PERFORMING PRELIMINARY ASSESSMENTS UNDER CERCLA August 20, 1993 ------- August 1993 EPA REGION VIII Preliminary Assessment Guidance U. S. EPA Headquarters released National Preliminary Assessment (PA) Guidance in September 1991. Region VIII issued Regional PA Guidance shortly thereafter, to focus the Guidance on Regional data collection needs. After one year of implementation, the Region finds that the Regional PA Guidance should be revisited. This guidance replaces the previous regional Guidance of January 1992 and continues to act as supplement to the National PA Guidance. The Region places a priority on clearly differentiating between fact and interpretation in the PA deliverables. This remains the primary reason for the regional supplemental guidance. This guidance also clearly defines the deliverable which is to be submitted to EPA in Region VIII. Knowledge of the Hazard Ranking System (HRS) is critical to the performance of PAs and Sis under Superfund. Data elements should be collected and reported with HRS criteria in mind. The Region promotes the use of the PREscore computer program as a learning tool and as a tool to determine when enough relevant data has been collected and now requires PREscore as part of the PA deliverable. Deliverables Basic data should be collected with the assistance of the PA Worksheets, Attachment V. This is intended to be submitted to the Region as part of the PA, and should be typed. The PA narrative is a presentation of the facts, with a summary which highlights the most relevant data elements with respect to the HRS. The text and worksheets are not appreciably different from the format we have used for the last several years in this region, however the worksheet has been revised. The PA Worksheets should prompt the writer to include pertinent data elements in the text. No interpretation should appear in any part of the PA deliverable without factual support in the PA narrative or worksheets. Because the PA Form requires interpretation (of primary and secondary targets) on pages 3 and 4, only pages 1 and 2 will be filled out in the current deliverable. Data elements requested on pages 3 and 4 of the PA form are incorporated, without interpretive interference, in the PA Worksheet. The Region finds that PA-score is not a worthwhile use of contractor or EPA resources in this part of the country. There was not a close correlation between PA-scores and PREscores run using the same basic data. Both false-positive and false- negative decisions to perform Sis were possible (12% and 18% of cases 1 ------- PA Guidance EPA Region VIII August 1993 respectively) using PA-score. PA-score is no longer part of the required deliverable. It has been replace by PREscore. It is our intention to continue to make accurate data collection the focus of the PA, rather than interpretation (via scoring models). Federal Facilities Federal Facilities are not required or expected to submit scores of any kind to this Region as part of a PA or equivalent under CERCLA 120 (d). The basic facts as outlined on the PA Worksheets are our highest need. However, if any PA scores or scoresheets are created, the Region requests they be sent for our information. We will retain them as part of the file, and consider them in the decision process. As stated above, no interpretation should appear without factual support in the PA text or worksheets. Freedom of Information Act (FOIA) Issues All scores are interpretive and some PA-scores and PREscores will exist in our files which have not been checked for accuracy and documentation. They will sometimes contain hypothetical samples or conditions which help us determine whether it is reasonable to believe a particular site could have the potential to be a candidate for the NPL. The Agency does not stand behind these scores. Official scores are only those printed in the Federal Register for proposal or finaiization on the NPL. As a matter of policy, the EPA does not release predecisional material. The Region applies this to scores and interpretive documents, except the PA form, by not releasing them until a final determination is complete. Once a No Further Remedial Action Planned (NFA or NFRAP) decision has been made, the materials used in making that decision, including the score if one exists, will be released upon request. Official scores are always released upon request after NPL proposal or final listing. PA Short Format There are a number of sites which may require Preliminary Assessments under CERCLA pursuant to the National Contingency Plan but which are quickly eliminated as candidates for the National Priorities List (NPL) under Superfund. 2 ------- PA Guidance EPA Region VIII August 1993 These sites may qualify for a less cumbersome and less time consuming PA than other sites. These can include sites for which a complete removal has been performed by EPAs Emergency Response Branch, or where the waste is no longer present; sites where the waste is fully contained and a release is found not to have occurred, RCRA subtitle C permitted facilities where an effective corrective action plan is in place, or sites which are under a Federal Nuclear Regulatory Commission (NRC) permit. PA Deliverables required are itemized on the Table of Preliminary Assessment Activities and Deliverables. The PA narrative may be as little as several paragraphs. It may include as little as sections 1.0, 3.0, 5.0, the PA Form (p. 1 and 2), and Attachment III. Consult the EPA Site Assessment Manager (SAM) to determine whether an individual site is eligible for this reduced reporting format. Conclusions Recommendations for future work, site priority, HRS listing potential or NFA status of a site are not appropriate in the body of a PA report. They are welcome in the cover letter which accompanies the report. Site scores, if they are generated, should not appear in any part of the report. References to site scores should not appear in the text. Conclusions should generally summarize the most critical data elements gathered in the PA such as identified targets, potential pathways of exposure, data needs, etc. Attachments: I Activities and Deliverables Table II Sample PA Narrative Table of Contents III CERCLA Eligibility Worksheet IV PA Form V PA Worksheets This acts as a Regional Addendum to the National PA Guidance. 3 ------- PA Guidance EPA Region VIII August 1993 ATTACHMENT I PRELIMINARY ASSESSMENT ACTIVITIES and DELIVERABLES Activity/Deliverable -PA Worksheet -CERCLA Eligibility Worksheet -Site Recon (windshield survey) Photo Log Separate Site Visit Report Initial Health and Safety Plan -Aerial Photography ** -PA Report (narrative) (condensed narrative) -EPA PA report Form 2050-0095 PA Form—1st 2 pages only -PREscore Deliverable Type PA Short Form Standard PA optional by case x x x x x x x * with EPA approval, not required. ** where available 4 ------- PA Guidance EPA Region VIII August 1993 ATTACHMENT II PRELIMINARY ASSESSMENT NARRATIVE REPORT TABLE OF CONTENTS (AS OF 1/24/92) 1.0 INTRODUCTION Include site name, location, CERCLIS ID; contractor or State agency performing PA, contract and work assignment numbers or cooperative agreement- mention Cooperative Agreement if applicable. State that the work is being performed under Superfund. 2.0 OBJECTIVES—State PA objectives. Specify that this is under Superfund. 3.0 SITE DESCRIPTION 3.1 Site location, description-include township and range, county, street address, and aliases as applicable. 3.2 Site history, including history of hazardous substance related activities and regulation. 3.3 Site characteristics: Physical geography, geology, hydrogeology, hydrology, meteorology (air studies only). 4.0 PRELIMINARY PATHWAY ANALYSIS-presented by pathway 4.1 Waste Characterization-contaminant quantity, concentrations, source types, waste streams, containment. 4.2 Air Pathway-meteorology, air targets, evidence of release (analytic, direct observation, or strong possibility of release) 4.3 Ground Water Pathway-hydrogeologic setting, GW targets, evidence or likelihood of release 4.4 Surface Water Pathway-hydrologic setting, SW targets, evidence or likelihood of release 5 ------- PA Guidance EPA Region VIII August 1993 4.5 Soil Exposure Pathway-soil conditions, SE targets, likelihood of resident population 5.0 SUMMARY and CONCLUSIONS-summarize the most important findings of the PA. Clearly identify principle pathways and targets of concern. 6.0 REFERENCES FIGURES 1. General Location Map 2. Detailed site map 3. Additional maps to support PA (i.e., well locations) TABLES as needed to support the PA APPENDICES A. EPA Preliminary Assessment Form B. Preliminary Assessment Worksheets C. CERCLA Eligibility Worksheet D. Photo Log 6 ------- PA Guidance EPA Region VIII August 1993 ATTACHMENT III CERCLA ELIGIBILITY WORKSHEET ------- PA Guidance EPA Region VIII August 1993 CERCLA Eligibility Worksheet Site Name City State EPA ID Number Note: The site is automatically CERCLA eligible if it is a Federally owned or operated RCRA site. I. CERCLA Eligibility Did the facility cease operations prior to November 19,1980? If YES, then STOP. The facility is probably a CERCLA site. If NO, continue to part II II. RCRA Deferral Factors Did the facility file a RCRA Part A application? If YES: 1. Does the facility currently have interim status? 2. Did the facility withdraw its Part A application? 3. Is the facility a known or possible protective filer? (filed in error) 4. Does the facility have a RCRA operating or post closure permit? 5. Is the facility a late (after 11/19/80) or non-filer that has been identified by the EPA or the State? (facility did not know it needed to file under RCRA) l ------- PA Guidance EPA Region VIII August 1993 Type of facility: Generator Transporter Recycler TSD (Treatment/Storage/Disposal) If all answers to questions 1, 2, and 3 are NO, STOP. The facility is a CERCLA eligible site. If answer to #2 or #3 is YES, STOP. The facility is a CERCLA eligible site. If answer to #2 and #3 are NO and any other answer is YES, site is RCRA, continue to part III. III. RCRA Sites Eligible for the NPL Has the facility owner filed for bankruptcy under Federal or State laws? Has the facility lost RCRA authorization to operate or shown probable unwillingness to carry out corrective action? Is the facility a TSD that converted to a generator, transporter or recycler facility after November 19,1980? IV. Exempted substances: Does the release involve hazardous substances other than petroleum? 2 ------- PA Guidance EPA Region VIII August 1993 V. Other programs: The site may never reach the NPL or be a candidate for removal. We need to be able to refer it to any other programs in EPA or state agencies which may have jurisdiction, and thus be able to effect a cleanup. Responses should summarize available information pertaining to the question. Include information in existing files in these programs as part of the PA. Answer all that apply. Is there an owner or operator? NPDES-CWA: Is there a discharge water containing pollutants with surface water through a point source (pipe, ditch, channel, conduit, etc.)? CWA (404): Have fill or dredged material been deposited in a wetland or on the banks of a stream? Is there evidence of heavy equipment operating in ponds, streams or wetlands? UIC-SDWA: Are fluids being disposed of to the subsurface through a well, cesspool, septic system, pit, etc.? TSCA: Is it suspected that there are PCB's on the site which came from a source with greater than 50 ppm PCB's such as oil from electrical transformers or capacitors? FIFRA: Is there a suspected release of pesticides from a pesticide storage site? Are there pesticide containers on site? 3 ------- PA Guidance EPA Region VIII August 1993 RCRA (D): Is there an owner or operator who is obligated to manage solid waste storage or disposal units under State solid waste or ground water protection regulations? UST: Is it suspected that there is a leaking underground storage tank containing a product which is a hazardous substance or petroleum? 4 ------- PA Guidance EPA Region VIII August 1993 ATTACHMENT IV PA Form ------- OMB Approval Number: 2050-0095 Approved for Use Through: 1/92 5-EPA Potential Hazardous Waste Site Preliminary Assessment Form Identification Stale: CERCUS Number CERCL1S Discovery Date: 1. General Site Information Name: Street Address: City: State: Zip Code: County: Co. Code: Cong. DhL Longitude; Approximate Area of Site: Acres ______ Square Ft Status of Site: ~ Active ~ Not Specified G Inactive 0 NA (GW plume, etc.) 2. Owner/Operator Information Owner Operator Street Address: Street Address: City: City: Stale: Zip Code: Telephone: ( State: Zip Code: Telephone: ( ) Type of Ownership: ~ Private ~ Federal Agency Name ~ State ~ Indian ~ County ~ Municipal G Not Specified Q Other How Initially Identified: G Citi2co Complaint G PA Petition G State/Local Program G RCRA/CERCLA Notification G Federal Program G Incidental G Not Specified Q Other 3. Site Evaluator Information Name of Evsluator: Agency/Organization: Date Prepared: Street Address: City: State: Name of EJ>A or State Agency Contact: Street Address: City: State: Telephone: ( ) 4. Site Disposition (for EPA use only) Emergency Response/Removal Assessment Recommendation: ~ Yea ~ No Dale: CERCLIS Recommendauon: O Higher Priority SI O Lower Priority SI Q NFRAP Q RCRA O Other Dale: Signature: Name (typed) Position: D-3 ------- O, CPA Potential Hazardous Waste Site Preliminary Assessment Form - Page 2 of 4 CERCLIS Number 5. General Site Characteristics Predominant Land Uae> Within 1 Mile of Site (check til that apply): ~ Industrial ~ Agriculture ~ DOI Q Commercial ~ Mining ~ Other Federal Facility ~ Reaidenliai ~ DOD ~ Forest/Fields ~ DOE ~ Other Site Setting: ~ Urban ~ Suburban ~ Rural Yean of Operation: Beginning Year _ Ending Year _ ~ Unknown Type of Site Operations (cheek all that apply): ~ Manufacturing (muat check subcategory) ~ Lumber and Wood Product! ~ Inorganic Chemicals G Plastic and/or Rubber Products Q Paints, Varnishes G Industrial Organic Chemicals G Agricultural Chemicals (e.g., pesticides, fertilizers) G Miscellaneous Chemical Products (e.g., adhcaives, explosives, ink) Q Primary Meuls O Metal Coating, Plating, Engraving G Metal Forging, Stamping G Fabricated Structural Metal Products G Electronic Equipment G Other Manufacturing G Mining G Metals G Coal G Oil and Oaa G Non-metallic Minerals G Retail G Recycling G Junky Salvage Yard O Municipal Landfill Q Other Landfill G DOD DOE DOI Waste Generated: ~ Onsite G Offsite G Onsite snd Offsite Other Federal Facility_ RCRA ~ Treatment. Storage, or Disposal ~ Larg e Quantity Generator G Small Quantity Generator G Subtitle D C Municipal ~ Industrial O 'Convener" 0 "Protective Filer' G "Noo- or Late Flier" G Not Specified O Other Waste Deposition Authorized By: G Present Owner O Former Owner G Present Jt Former Owner G Unauthorized G Unknown Waste Accessible to the Public: G Yes G No Distance to Nearest Dwelling, School, or Workplace: Feet 6. Waste Characteristics information Source Waste Quantity: (include units) Source Type: (check ail that apply) ~ Landfill ~ Surface Impoundment ~ Drums O Tanks and Moo-Drum Containers G Waste Pile ~ Scrap Metal or Junk Pile O Tailings Pile G Traah Pile (open dump) G Land Treatment ~ Cooummated Ground Water Plume (unidentified source) G Contaminated Surface Water/Sediment (unidentified source) G Cooummated Soil G Other G No Sources C « Constituent, W = Wastes (ream. V = Volume. A — Area Tier General Types of Waste (check all that spply) G Metals G Orgamcs G Inorganics G Solvents G Paints/Pigments G Pesticides/Herbicides G Acids/Bases ~ Oily Waste G Municipal Waste G Mining Waste G Laboratory/Hospital Waste ~ Explosives Q Radioactive Waste O Other G Comtructiou/Det&oiiboQ Waste Physical State of Waste as Deposited (check all that *PP»y): G Solid G Sludge G Powder G Liquid G Gas D-4 ------- PA Guidance EPA Region VIII August 1993 ATTACHMENT V PA Worksheet ------- PA WORKSHEET Site Name CERCLIS ID # City, State Reported by Date ------- HIGHLIGHTS: A) IS THERE QUALITATIVE OR QUANTITATIVE EVIDENCE OF A RELEASE TO AIR, SURFACE WATER, GROUND WATER, OR SURFACE SOIL? DESCRIBE BRIEFLY. More detail in items GW-1 (for GW), SW-5 (for SW), A-1 (for air), and SE-1 (for soil exposure pathway). B) IS THERE EVIDENCE OF AN IMPACTED TARGET POPULATION? DESCRIBE. Pathway Target none/target size Brief description More discussion in Ground Water public drinking water supply domestic drinking water supply Surface Water drinking water fishery sens. env. Soil Exposure people w/in 200' terrestrial sens. env. Air population PA Worksheet version August 1993 1 ------- SITE INFORMATION G-1. Directions to the site (from nearest easily recognized point). G-2. Are there other potential sources in the neighborhood to be aware of as the site is evaluated? eg. Is the site in an industrial area, near a railroad, along a highway? Are sources with similar contaminants to this site in the vicinity? Background/Operating History G-3. Describe the operating history of the site: Source of information: G-4. Describe site and nature of operations (property size, manufacturing, waste disposal, storage etc.): Source of information: G-5. Describe any emergency or remedial actions that have occurred at the site: Source of information: PA Worksheet version August 1993 2 ------- G-6. Are there records or knowledge of accidents or spills involving site wastes? Are there Emergency Response Notification (ERNs) reports for this location? Source of information: G-7. Describe existing sampling data and briefly summarize data quality (e.g. sample objective, age/comparability, analytical methods, detection limits, QA/QC, validatability): Source of information: G-8. Is there any other local, state or federal regulatory involvement? Describe. Include permits, and names of contact individuals within each government organization. AGENCY PROGRAM CONTACT PHONE PERMIT G-9. Attach site sketch or schematic. Include all pertinent features including wells, storage areas, underground storage tanks, source areas, buildings, access roads, areas of ponded water. Refer to figure(s) submitted with text of report if appropriate. PA Worksheet version August 1993 3 ------- SOURCE CHARACTERIZATION WC-1. Describe each source at the site, on Table 1, in terms of source type, containment, size/area/volume/quantity, and substances present. See HRS Tables 2-5 and 5-2 for source descriptions, Tables 3-2, 4-2, 4-8, 5-6, 6-3, and 6-9 for containment. WC-2. Briefly describe how waste quantity was estimated (eg. historical records or manifests, permit applications, air photo measurements, etc.): Source of information: WC-3. Describe any restrictions or barriers to accessibility of onsite sources. Source of information: PA Worksheet version August 1993 4 ------- GROUND WATER CHARACTERISTICS GW-1. Any positive or circumstantial evidence of a release to ground water? Describe. Source of information: GW-2. Any positive or circumstantial evidence of a release to drinking water users? Describe analytes, detection limits, background, hits, number of users, locations, QA/QC. Source of information: GW-3. Briefly describe the geologic setting. GW-4. Describe geologic/hydrogeologic units on Table 2. Give names, descriptions, and characteristics of consolidated and unconsolidated zones beneath the site. GW-5. Is the site in an area of karst terrain or a karst aquifer? GW-6. Net Precipitation (per HRS section 3.1.2.2). PA Worksheet version August 1993 ------- SURFACE WATER CHARACTERISTICS SW-1. Mean annual precipitation (per HRS section 4.0.2) = . If less than 20", then count intermittant channels as surface water. SW-2. Discuss the probable surface water flow pattern from the site to surface waters: Source of information: SW-3. If surface water exists within 2 miles of the site, describe surface water segments within the 15-mile distance limit. Segment Name River/ Lake/ type Fresh/ Salt Water Start (mi.) End (mi.) flow in cfs Ground water to surface water distance Angle 0 SW-4. Provide a schematic diagram or simple figure which describes surface water segments, locates targets, identifies flow direction, PPE(s), etc. Refer to figure(s) submitted with text of report if appropriate. PA Worksheet version August 1993 6 ------- SW-5. Any positive or circumstantial evidence of a release to surface water? Evidence of a release by direct observation? Is the source located in surface water? Describe. Source of information: SW-6. Any positive or circumstantial evidence of a release to surface water target populations? Describe analytes, detection limits, background, hits, number of users, locations, QA/QC. Source of information: SW-8. Is the site or portions thereof located in surface water? Is the site located in the 1 - < 10 yr floodplain? >10-100 yr? >100-500 yr? > 500 yr? SW-9. Two-year 24-hour rainfall PA Worksheet version August 1993 7 ------- TARGETS T-1. Discuss ground water usage within four mile of the site: Source of information: T-2. Summarize the drinking water population served via Ground Water within 4 miles of the site: 0-1/4 mi 1/4-1/2 mi 1/2- 1 mi 1 - 2 mi 2-3 mi 3-4 mi Attach calculations for population apportionment in blended systems. T-3. Identify and locate any of the following surface water targets within 15 miles of the site: drinking water population^) served by intakes, fisheries, sensitive environments described in Table 4-23 of the HRS, and wetlands as defined in the Federal Register. Targets dist. from site SW body flow in cfs population served/size (incl. units) contaminat ion known/ suspected PA Worksheet version August 1993 8 ------- T-4. Summarize the population within a four-mile radius of the site: total pod. worker pop. onsite 0-1/4 mi 1/4-1/2 mi 1/2-1 mi 1-2 mi 2-3 mi 3-4 mi T-5. Identify and locate any terrestrial sensitive environments described in Table 5-5 of the HRS. T-6. Describe any positive or circumstantial evidence of a release to air target populations? Of a release by direct observation where target population exists within 1/4 mile of the site? Describe analytes, detection limits, background, hits, number of users, locations, QA/QC. T-7. Identify and locate any potential or known resident soil exposure populations, if present. Describe conditions which lead the researcher to suspect contaminated soil within 200' of residences, if this condition exists. PA Worksheet version August 1993 9 ------- TABLE 1 WASTE CONTAINMENT AND HAZARDOUS SUBSTANCE IDENTIFICATION1 SOURCE TYPE SIZE (Volume/Area) ESTIMATED WASTE QUANTITY SPECIFIC COMPOUNDS CONTAINMENT1 SOURCES OF INFORMATION 'Use additional sheets if necessary. 'Evaluate containment of each source from the perspective of each migration pathway (e.g., ground water pathway - non-existent, natural or synthetic liner, corroding underground storage tank; surface water - inadequate freeboard, corroding bulk tanks; air - unstabilized slag piles, leaking drums, etc.) PA Worksheet version August 1993 10 ------- TABLE 2 HYDROGEOLOGIC INFORMATION1 STRATA NAME/DESCRIPTION THICKNESS (ft.) HYDRAULIC CON DUCTI VITY(cm/sec) TYPE OF DISCONTINUITY2 SOURCE OF INFORMATION lUse additional sheets if necessary. 2ldentify the type of aquifer discontinuity within four-miles from the site (e.g., river, strata "pinches out", etc.) PA Worksheet version August 1993 11 ------- |